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 UNITED STATES DEPARTMENT OF ENERGY 

 + + + + + 

 ENERGY EFFICIENCY AND RENEWABLE ENERGY 

 BUILDING TECHNOLOGY PROGRAM 

 + + + + + 

 NOTICE OF PROPOSED RULEMAKING PUBLIC MEETING 

 FOR ALTERNATIVE EFFICIENCY 

 DETERMINATION METHODS 

 + + + + + 

 TUESDAY 

 JUNE 5, 2012 

 + + + + + 

 The Public Meeting convened, in 

Room 8E-089, Department of Energy, Forrestal 

Building, 1000 Independence Avenue SW, 

Washington, D.C., at 9:00 a.m., Ashley 

Armstrong, Department of Energy, Building 

Technology Program, presiding. 
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PRESENT 

ASHLEY ARMSTRONG, DOE, EERE, BTP, Facilitator 

KARIM AMRANE, PhD, Air-Conditioning, Heating, 

 and Refrigeration Institute 

LAURA BARHYDT, DOE, Office of the General 

Counsel 

ALEX BOESENBERG, National Electrical 

 Manufacturers Association 

DEBRA BRUNK, Navigant Consulting 

DAVID CASE, DOE, Office of General Counsel 

ADAM CHRISTENSEN, PhD, Appliance Standards 

 Awareness Project 

ROGER H. DAUGHERTY, PhD, Baldor Electric 

PAUL L. DOPPEL, Mitsubishi Electric 

MARK FLY, AAON, Inc. 

MIKE GARST, Lennox International 

HELMUTH GLATT, Nidec Motor Corporation 

CHARLES HON, True Manufacturing Company 

JILL HOOTMAN, Trane 

JEFF KLEISS, Lochinvar, LLC 

REBECCA LEGETT, Navigant Consulting 

HARMON S. LEWIS, American Panel 

DICK LORD, Carrier Corporation 

KAREN B. MEYERS, Rheem Manufacturing Company 

MASSOUD NESHAN, Southern Store Fixtures, Inc 

DOUG RAWALD, DOE, Office of General Counsel 

CARL ROBERTS, Zero Zone Inc. 

HARVEY SACHS, PhD, American Council for an 

 Energy-Efficient Economy 

FRANK STANONIK, Air-Conditioning, Heating, and 

 Refrigeration Institute 

MIKE STRAUB, Heatcraft Refrigeration Products 

COREY TUCKER, Navigant Consulting 

JAMES VerSHAW, Ingersoll Rand 

ROBERT WILKINS, Danfoss 
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 C-O-N-T-E-N-T-S 

Call to Order 5 

 Ashley Armstrong 

 Department of Energy 

Introductions 6 

Opening Remarks, Agenda Review 10 

 Ashley Armstrong 

 Department of Energy 

 Karim Amrane 11 

 AHRI 

 Harmon Lewis 12 

 American Panel 

 Massoud Neshan 13 

 Southern Store Fixtures 

 Mark Fly 14 

 AAON 

 Alex Boesenberg 15 

 NEMA 

 Mike Garst 16 

 Lennox International 

 Dick Lord 16 

 Carrier 

 Harvey Sachs 17 

 ACEEE 

 Carl Roberts 18 

 Zero Zone 

 Paul Doppel 18 

 Mitsubishi 

 Craig Messmer 19 

 Unico 
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 C-O-N-T-E-N-T-S (CONTINUED) 

Opening Remarks (Continued) 

 Roger Daugherty 20 

 Baldor Electric 

Rulemaking Overview 23, 28, 51 

and 

Definitions and Scope of Coverage 

 Ashley Armstrong 

 Department of Energy 

 Questions and Comments 24, 29, 52 

Substantiation Requirements 79, 101 

 Ashley Armstrong 

 Department of Energy 

 Questions and Comments 79, 103 

Number of Testing Rounds 165 

 Ashley Armstrong 

 Department of Energy 

 Questions and Comments 

DOE Validation 181, 183, 229 

 Ashley Armstrong 233, 236 

 Department of Energy 

 Questions and Comments 182, 184, 231 

 233, 236 
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1 P-R-O-C-E-E-D-I-N-G-S 

2 9:01 a.m. 

3 MS. ARMSTRONG: Good morning, 

4 everyone. 

5 My name is Ashley Armstrong, and I 

6 would like to welcome you to our public 

7 meeting to discuss the proposed rule on 

8 alternative efficiency determination methods. 

9 I would like to welcome everyone 

10 that came in person on such short notice, as 

11 well as all those attending by webinar on the 

12 phone. 

13 We are going to try something new 

14 this time to open up the webinar line, so that 

15 they can communicate with the people in the 

16 room as well. So, for those of you on the 

17 line, if you want to talk, please just raise 

18 your hand. There is a way you can do it from 

19 the webinar and then wait to be called on, and 

20 we will unmute your line and you can speak 

21 freely to the rest of us in the room. So, you 

22 can participate in the meeting itself. 
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1 Before we start, we are going to 

2 go around the room and do introductions. 

3 Please say your full name as well as your 

4 company affiliation for the record. I ask 

5 that each time you speak you do that as well, 

6 and speak clearly into the microphone. 

7 So, with that -- 

8 MS. BARHYDT: I am Laura Barhydt. 

9 I am with the U.S. Department of Energy, 

10 Office of General Counsel. 

11 MS. ARMSTRONG: Ashley Armstrong, 

12 Department of Energy. 

13 MR. GARST: Mike Garst, Lennox 

14 International. 

15 MR. AMRANE: Karim Amrane, Air 

16 Conditioning, Heating, and Refrigeration 

17 Institute. 

18 MR. SACHS: Harvey Sachs, American 

19 Council for an Energy Efficient Economy. 

20 MR. VerSHAW: Jim VerShaw, 

21 Ingersoll Rand, Trane Residential. 

22 MS. HOOTMAN: Jill Hootman, Trane, 
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1 Ingersoll Rand. 

2 MR. LEWIS: Harmon Lewis, American 

3 Panel. 

4 MR. WILKINS: Robert Wilkins, 

5 Danfoss. 

6 MR. FLY: Mark Fly, AAON 

7 Incorporated. 

8 MR. BOESENBERG: Alex Boesenberg, 

9 National Electrical Manufacturers Association. 

10 MR. GLATT: Helmuth Glatt, Nidec 

11 Motor Corporation. 

12 MR. ROBERTS: Carl Roberts, Zero 

13 Zone. 

14 MR. HON: Charlie Hon, True 

15 Manufacturing. 

16 MR. LORD: Dick Lord, Carrier. 

17 MS. ARMSTRONG: And so, I also ask 

18 the people in the back if you can make your 

19 way to the sides, where there are microphones, 

20 and introduce yourself with your name as well 

21 and your company affiliation for the record, 

22 please. 
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1 MR. NESHAN: I am Massoud Neshan, 

2 Southern Store Fixtures. 

3 MR. ROY: Aniruddh Roy, AHRI. 

4 MR. STANONIK: Frank Stanonik, 

5 AHRI. 

6 MR. STRAUB: Mike Straub, 

7 Heatcraft Refrigeration. 

8 MR. CHRISTENSEN: Adam 

9 Christensen, Appliance Standards Awareness 

10 Project. 

11 MR. DAUGHERTY: Roger Daugherty, 

12 Baldor Electric, member of the ABB Group. 

13 MR. RANSOM: David Ransom, 

14 McDermott, Will and Emergy for Goodman. 

15 MR. HOLT: John Holt, National 

16 Rural Electric Cooperative Association. 

17 MS. REAMER: Laura Reamer with 

18 Regal-Beloit Corporation. 

19 MR. NOE: Gary Noe with Regal20 Beloit. 

21 MS. LEGETT: Rebecca Legett, 

22 Navigant Consulting. 
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1 MR. HOYT: Bill Hoyt, National 

2 Electrical Manufacturers Association. 

3 MS. BRUNK: Debra Brunk, Navigant 

4 Consulting. 

5 MS. TUCKER: Corey Tucker, 

6 Navigant Consulting. 

7 MR. CASE: David Case, DOE, Office 

8 of General Counsel. 

9 MR. RAWALD: Doug Rawald, 

10 Department of Energy, General Counsel. 

11 MS. ARMSTRONG: All right. So, 

12 the purpose of this public meeting is to 

13 really gather feedback on the Department's 

14 proposal, understand where there may be 

15 issues, questions, or concerns. So, we really 

16 encourage participation. 

17 With that, we have a brief 

18 presentation, but feel free to chime in 

19 whenever you would like. 

20 As you can tell, I am the 

21 moderator for today as well as the presenter. 

22 So, I am going to present from here, just to 
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1 make life easier, a little bit. 

2 So, if you need to hold sidebar 

3 conversations, please go outside. Bathrooms 

4 are to the left. Coffee shop, all the way at 

5 the bottom. 

6 Just let us know when you want to 

7 speak. Some of the ground rules: if you are 

8 not speaking, I ask that you put your 

9 microphone off because, that way, it minimizes 

10 the feedback that we get from the microphones 

11 all around the room and the webinar. 

12 Here is a brief agenda review 

13 before I open up. This is just what we plan 

14 to talk about today. 

15 Okay. So, the purpose of today's 

16 meeting, as I said, is to really present the 

17 notice, some of the key items in the proposal 

18 as they relate to AEDMs, to provide a forum 

19 for public discussion, encourage you guys to 

20 submit all kinds of data as well as comments 

21 on the Notice of Proposed Rulemaking, to help 

22 better inform the Department's final rule, and 
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1 just to allow a forum for discussion. 

2 So, at this time, I am going to go 

3 ahead and welcome and turn the floor over to 

4 opening remarks. Please say your name and 

5 your company affiliation for the record, and 

6 we will go around the room, as well as I will 

7 open up the webinar lines if anybody wants to 

8 make comments at the outset of the meeting. 

9 Anybody? Sure, go ahead, Karim. 

10 MR. AMRANE: My name is Karim 

11 Amrane with the AHRI. Of course, we would 

12 like to thank DOE for issuing this proposed 

13 rule. It is well overdue. It is very 

14 important for the manufacturers for air 

15 conditioning, heating, water heating 

16 equipment, refrigeration equipment as well. 

17 I would like to raise an issue 

18 that has not been addressed in the NOPR and 

19 which has to do with the effective date by 

20 which manufacturers of commercial equipment 

21 will have to comply with the certification 

22 requirements to the Department of Energy. 
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1 As you all know, that date has 

2 been set as January 1st, 2013. Honestly, even 

3 if this is completed tomorrow, there is no way 

4 that the manufacturers can comply with this 

5 effective date. Many manufacturers don't have 

6 AEDMs. We don't know yet what the 

7 requirements of the AEDM would be. Of course, 

8 we have the NOPR in front of us, but still 

9 that rule has to be finalized. So, there is 

10 no way in four months or six months that 

11 manufacturers are going to be ready by January 

12 1st, 2013. 

13 So, AHRI would like to officially 

14 request that the effective date of compliance 

15 with certification reports to DOE be postponed 

16 by at least 18 months from the date this AEDM 

17 rulemaking is finalized. 

18 Thank you. 

19 MS. ARMSTRONG: Sure. 

20 MR. LEWIS: Harmon Lewis with 

21 American Panel. 

22 I would like to second that 
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1 motion. 

2 MS. ARMSTRONG: Thank you. 

3 Anybody else want to make opening 

4 remarks at this time before we go into the 

5 presentation? Sure. 

6 MR. NESHAN: This is Massoud 

7 Neshan with Southern Store Fixtures. 

8 And thank you for setting up this 

9 meeting. 

10 We manufacture commercial 

11 refrigerated equipment. We have been waiting 

12 for over a year for a definition or 

13 clarification from DOE to tell us what is the 

14 definition of a basic model, since everything 

15 is based on a basic model, and we have still 

16 yet to hear a response from DOE. We are 

17 talking about methodology to put into place; 

18 whereas, we do not know what is the definition 

19 of basic model. And that is extremely 

20 critical for us for the purpose of testing or 

21 modeling these basic models. 

22 MS. ARMSTRONG: Okay. Thank you. 
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1 Anybody else? Please feel free. 

2 MR. FLY: Yes, Mark Fly with AAON. 

3 Just following up on that, the 

4 basic model definition is very important, 

5 especially with my company, but I think to 

6 everybody in this room. For example, our 

7 complete model string has about 100 

8 characters, and each one of those characters 

9 has 25 options underneath it. So, the 

10 combinations and permutations of all these 

11 options can create thousands or millions or 

12 trillions of different models, depending on 

13 how you wanted to define a basic model. So, 

14 we need some clear definition on what that is. 

15 Many of these options will only 

16 minorly affect the energy. It may be a 

17 different kind of filter, which might affect 

18 some of the fan energy in a minor way. Or it 

19 might have an economizer or it might have a 

20 heat recovery device that isn't really covered 

21 in the testing standard, but will impose a 

22 static pressure drop on the fan and cause an 
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1 energy increase. 

2 So, if we are going to define a 

3 basic model by any change in energy 

4 consumption, that is going to generate so many 

5 basic models that none of us can deal with it. 

6 MS. ARMSTRONG: Sure. 

7 MR. BOESENBERG: Alex Boesenberg, 

8 NEMA. 

9 Like everybody else, I want to 

10 thank the Department for having this meeting 

11 today and for the draft. I am looking forward 

12 to see how the webinar audio goes. Thank you 

13 for trying that. We have had trouble in the 

14 past and appreciate the efforts that DOE has 

15 made, then, to repair that. 

16 As to the short notice, we will 

17 thank you in advance for giving us at least 30 

18 days next time, not just to afford time in 

19 schedules, but because of the expense of 

20 airfare and hotels. Some people could not be 

21 here today due to a 250 percent difference in 

22 the price of a ticket bought on short notice. 
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1 Thank you. 

2 MR. GARST: And just to add to the 

3 basic model issue, there is also product 

4 class, and I think we need some clarification 

5 on what a product class is. 

6 MS. ARMSTRONG: Anyone else before 

7 we move to the presentation itself? Sure. 

8 MR. LORD: Yes, Dick Lord with 

9 Carrier. 

10 One of the things that we have 

11 kind of hinted at, but really haven't 

12 addressed is there are products that really 

13 aren't designed to run at standard rating 

14 conditions. I will give you a good example. 

15 You can put an energy recovery wheel on a 

16 rooftop and actually save significant energy, 

17 but when you rate it at the standard rating 

18 point, it is actually going to show a little 

19 lower efficiency, which really aren't 

20 addressed by a lot of these procedures. So, 

21 we have got to figure out how to do those and 

22 how to handle them. 
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1 MS. ARMSTRONG: Go ahead. 

2 MR. SACHS: Harvey Sachs, ACEEE. 

3 The new concern I would express is 

4 how the information we are using for this will 

5 play with other programs that will yield much 

6 more information on performance for use by 

7 designers, modelers, and others, such as the 

8 recently-announced AHRI initiative for release 

9 of supplemental information across product 

10 classes. 

11 And it would seem very worthwhile 

12 for us to all be thinking about how the AEDM 

13 and programs like this evolve together rather 

14 than leading to duplicative effort without 

15 giving any additional help to anyone who needs 

16 to use the information. 

17 Thank you. 

18 One additional note. Harvey 

19 Sachs. I am not saying AHRI is right. 

20 Thanks. 

21 Laughter.) 

22 MS. ARMSTRONG: Does anybody else 
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1 wish to make opening remarks at this time? 

2 Sure. 

3 MR. ROBERTS: Carl Roberts, Zero 

4 Zone. 

5 We do appreciate this move. It is 

6 a big step in the right direction. I just 

7 wanted to mention or keep in mind that the 95 

8 percent confidence interval one-tailed T-value 

9 wasn't taken into account at the time the 

10 standard energy levels were set. So, what 

11 this is doing is raising the bar. 

12 Thank you. 

13 MS. ARMSTRONG: Anyone else? Last 

14 call. Sure. 

15 MR. DOPPEL: Paul Doppel with 

16 Mitsubishi. 

17 I also want to support Karim's 

18 suggestion that we have 18 months before 

19 implementation effective date. 

20 MS. ARMSTRONG: Thank you. 

21 All right. Moving along, so what 

22 are AEDMs? They are basically computer 
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1 simulations, mathematical tools, modeling, 

2 engineering simulations that are used to 

3 predict the performance of non-tested basic 

4 models. Use of AEDMs allows manufacturers to 

5 rate and certify their performance of their 

6 equipment without actual testing, once the 

7 simulated energy use or efficiency results are 

8 derived, as well as we believe it may reduce 

9 testing burden because there is only a subset 

10 of the whole model offering that would have to 

11 be tested. 

12 So, Craig Messmer also would like 

13 to say something at this point. 

14 MR. MESSMER: Good morning, 

15 everybody. Sorry I couldn't be there. Thank 

16 you, Ashley. 

17 This is Craig Messmer with Unico. 

18 We are classified as an ICM, and 

19 we noticed that the ARM has seemingly been 

20 deleted from the regulations. We don't really 

21 have a problem with that. We are wondering 

22 why the ARMs for specific products, especially 
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1 ICMs has been removed. We thought the AEDMs 

2 were primarily for other products than 

3 commercial. So, anyway, that is more of a 

4 question, but very much of a concern. 

5 Thank you. 

6 MS. ARMSTRONG: Okay. Thank you. 

7 We will get to answering, I think, 

8 some of those in a little bit. But, as they 

9 come up, if you have additional questions, 

10 Craig, just let us know. 

11 So, just to set the stage with 

12 some background -- go ahead. 

13 MR. DAUGHERTY: Roger Daugherty, 

14 Baldor Electric. 

15 Back on your definition of AEDM, I 

16 also notice that inside the NOPR you stated 

17 that you referred to an AEDM since it could be 

18 used to simulate testing under DOE test 

19 conditions. Is that some other type of AEDM 

20 other than that which you have defined that 

21 can also be used? And what is the intent of 

22 that meaning? That is on page 32041 in The 
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1 Federal Register publication. 

2 MS. ARMSTRONG: Okay. So, I am 

3 not quite sure exactly what you are referring 

4 to. I have 41 open here, and I am happy to 

5 take this conversation a bit offline. 

6 But the definition generally in 

7 the back, in the actual regulatory text just 

8 is a general definition and describes any type 

9 of calculation or algorithm, engineering 

10 algorithm, that predicts the efficiency as 

11 measured by the descriptor in DOE's 

12 regulation. So, it doesn't specifically talk 

13 about, at least in the regulatory text, it 

14 doesn't specifically talk about test procedure 

15 conditions. 

16 That being said, if you had an 

17 AEDM that would simulate use over a wide 

18 variety of conditions, I mean, it doesn't 

19 preclude that, if that is what you are asking. 

20 MR. DAUGHERTY: Roger Daugherty. 

21 I guess what I am trying to get at 

22 is I understand what my AEDM and its method of 
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1 calculating losses in electric motors, in 

2 small electric motors, to determine 

3 efficiency. But I was trying to figure out 

4 why DOE seems to be relating it to the way 

5 that motor would be tested; whereas, that 

6 doesn't take into account that I am using an 

7 IEEE 112 test method to determine losses. It 

8 is totally different. So, I was just trying 

9 to get clarification on what you mean by this, 

10 or if it is not intended to be stated the way 

11 it is in the NOPR. 

12 MS. ARMSTRONG: This is Ashley 

13 from DOE. 

14 And other manufacturers in the 

15 room may speak up as they wish. It is meant 

16 to predict the efficiency that you would also 

17 get from testing. That being said, if you 

18 implement an engineering equation or an 

19 algorithm, obviously, that may be different 

20 than the actual testing. However, it is meant 

21 to get results that are comparable to those 

22 that you would get under the actual DOE test 
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1 method. 

2 Does that make sense? Does that 

3 help? Okay. Thank you. 

4 Okay. So, just to set the stage 

5 with some background, currently, DOE's 

6 regulations permit the use of the AEDMs for 

7 commercial HVAC equipment, commercial water 

8 heating equipment, distribution transformers, 

9 as well as electric motors. In addition, as 

10 noted earlier in the presentation, 

11 manufacturers of central air conditioners and 

12 heat pumps are allowed to use ARMs to rate 

13 their equipment currently. 

14 So, DOE issued a Request for 

15 Information a while back, a little over a year 

16 ago, about other types of equipment that may 

17 be similar that could benefit from the use of 

18 AEDM regulations as well as what procedural 

19 changes the Department could consider for 

20 their AEDM regulations, including tolerances. 

21 We sought comment on a variety of 

22 issues. Some of those topics are, then, 
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1 addressed in this proposed rule. 

2 All right. The proposal. So, 

3 just on its face, naming conventions, DOE is 

4 proposing to marry the terms "ARM" and "AEDM" 

5 and just use one single naming convention 

6 across the board for simulation methods. We 

7 are proposing to use the term AEDM. So, 

8 therefore, to Craig's point earlier, we are 

9 proposing to get rid of the term "ARM," 

10 although we are proposing to allow the use of 

11 simulation methods still for central air 

12 conditioners and heat pumps, just to clarify 

13 that. Okay? 

14 MR. AMRANE: I guess I have a 

15 question. Are you now requiring the old ARM 

16 to be consistent with the requirements that we 

17 have in this proposed rule? 

18 MS. ARMSTRONG: Yes. 

19 MR. AMRANE: Okay. So, 

20 manufacturers that have ARMs today don't have 

21 to revalidate their ARMs based on this 

22 proposed rule? 
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1 MS. ARMSTRONG: Upon the 

2 compliance date of the new provisions, the 

3 ARMs in use to date would have to meet the 

4 provisions as they are written here. 

5 MR. AMRANE: Okay. Then, we have 

6 a problem as well because those residential 

7 central ACs have to comply today with the DOE 

8 requirements. And today they are not using 

9 exactly what is proposed in this rule. So, 

10 are you going to provide any time for those 

11 manufacturers to have time to comply with the 

12 new one? 

13 MS. ARMSTRONG: Sure. DOE would 

14 consider a compliance date. It would be very 

15 helpful if we could hear what a necessary 

16 timeframe might be and why. 

17 MR. AMRANE: Well, the time 

18 necessary to revalidate, to develop a new 

19 AEDM. 

20 (Laughter.) 

21 MS. ARMSTRONG: This is Ashley. 

22 So, I think we understand why. It 
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1 is a matter of what that magnitude should be, 

2 the number. 

3 MS. MEYERS: Ashley, this is Karen 

4 with Rheem. 

5 So, just so I understand, we have 

6 now expanded the scope of this rule to include 

7 all residential air conditioning and heat pump 

8 systems? Is that what we were saying here? 

9 MS. ARMSTRONG: Correct. 

10 MS. MEYERS: Wow. 

11 MS. ARMSTRONG: Yes? 

12 MR. LORD: Just to kind of 

13 reconfirm what I think you told Karim, 

14 basically, we have an ARM that is all 

15 qualified today. We are going to have to get 

16 all new units, retest all those units -- 

17 MS. ARMSTRONG: Go ahead, finish. 

18 (Laughter.) 

19 MR. LORD: That's enough. You are 

20 getting my drift. 

21 MS. ARMSTRONG: Okay. So, the 

22 answer is possibly. So, it depends on what 
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1 your ARM is based on. If you have an ARM 

2 today that meets the criteria as written -- 

3 so, you have tested a unit from each product 

4 class. You have tested no less than five 

5 basic models, one of the lowest capacity, one 

6 of a capacity in the highest 25 percent, if 

7 you have basically done that and you have 

8 tested ones that are compliant with the 

9 current standards and current test procedures, 

10 then you are good to go, I mean assuming that 

11 these get adopted and the tolerances as well, 

12 assuming these get adopted as final as they 

13 are proposed. 

14 But that being said, if not, and 

15 you need to make minor tweaks, then you are 

16 going to need to make minor tweaks. It might 

17 require more than minor tweaks. 

18 And to Karim's point, if it does 

19 require major changes, we are interested in 

20 knowing what a reasonable compliance date 

21 should be for the Department to consider. 

22 MR. LORD: So, maybe to just 
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1 restate it, say we had three units that were 

2 already tested that we could use. 

3 MS. ARMSTRONG: Uh-huh. 

4 MR. LORD: And we just show that 

5 data, maybe add two more units? 

6 MS. ARMSTRONG: Yes. So, that is 

7 a great segue to this next slide. 

8 DOE is proposing no preapproval. 

9 You don't even have to show that data. You 

10 just maintain the records. And, yes, if you 

11 had three, you would just test two more, 

12 assuming that that is the minimum set of 

13 criteria that need to be met. But, yes, you 

14 would be fine. 

15 So, DOE is not proposing to add a 

16 preapproval process for AEDMs. This is 

17 currently, for those that have AEDMs, this is 

18 currently how the regulations go for AEDMs 

19 now. For ARMs, it is a change. We would not 

20 require any kind of notification to the 

21 Department. You would just, when you certify 

22 your products, you would have to state that 
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1 you used an AEDM to rate those untested 

2 combinations. 

3 MR. STANONIK: Frank Stanonik with 

4 AHRI. 

5 Ashley, residential AC 

6 manufacturers have used ARMs for 10, 15, 20 

7 years. Is there anything procedurally that 

8 prohibits DOE from essentially grandfathering 

9 those methods and just saying that, without 

10 meeting the letter of whatever the AEDM 

11 criteria come out to be -- there is a long 

12 history of testing and compliance. Can't they 

13 just be grandfathered? 

14 MS. BARHYDT: This is Laura 

15 Barhydt at DOE. 

16 This isn't exactly in answer to 

17 your question, but I will say that we are 

18 concerned that some of the ARMs currently in 

19 use were granted, were approved a very long 

20 time ago. And we are concerned about the 

21 validity of the test data that they are based 

22 on. 
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1 And so, part of the idea here is 

2 to get everybody onto a level footing where 

3 the ratings are all being based on a similar 

4 methodology to make sure that everyone's 

5 ratings are in accordance with the current 

6 standards and test procedure. 

7 MR. SACHS: Harvey Sachs, ACEEE. 

8 I am not asking this judgmentally, 

9 but my inference from this slide No. 12 is 

10 that the AEDM is fundamentally a simulation of 

11 equipment performance, and the Department will 

12 treat this as a black box for which the 

13 manufacturer confirms or asserts compliance 

14 with test data. But the underlying algorithms 

15 will not be seen by the DOE, the public, 

16 competitors, or anyone else. 

17 MS. ARMSTRONG: Yes, that is 

18 correct. That is the proposal as written. 

19 MR. SACHS: Thank you, I think. 

20 MS. ARMSTRONG: I mean, that being 

21 said, I will say that part of the proposal is 

22 that records be maintained and, upon request 
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1 from the Department, all of that information 

2 would be made available to the Department, if 

3 we had a reason to request such information. 

4 MR. SACHS: Harvey Sachs again. 

5 My concern, Ashley, is that this 

6 works fine with long-established, legitimate 

7 manufacturers, but I think that in some other 

8 industries we have seen this kind of thing 

9 used as a loophole generator to do, shall we 

10 say, a shady batch of code, and when finally 

11 challenged, just drop the certification of the 

12 non-complying models, climb into a hole, or go 

13 bankrupt. 

14 So, my concern is whether this 

15 will actually lead to a level playing field 

16 among all the manufacturers without imposing 

17 even greater burdens to entry than we have 

18 now. I don't know the answer, but I think it 

19 is a question that does matter. 

20 MR. GLATT: Helmuth Glatt, Nidec 

21 Motor Corporation. 

22 We are kind of on the opposite 
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1 side of that. We love our AEDM, and we don't 

2 want to share the source code of it with 

3 anybody. So, treating it as a black box needs 

4 to be highly emphasized at this point. 

5 So, by underlying records, that 

6 definition is basically correlation between 

7 test data and the AEDM output? 

8 MS. ARMSTRONG: Yes, I would say 

9 we are going to get to part of that. But, 

10 yes, I mean, it is any test data used to 

11 substantiate your AEDM, any subsequent 

12 verification that you may do just on your own, 

13 anything that supports how you came about with 

14 your AEDM. All those records you would 

15 maintain. And then, if we ever got into a 

16 situation, I think, where we needed to discuss 

17 those records with you, we could talk about 

18 more details as to what exactly the Department 

19 wanted to see and stuff like that. 

20 But I would maintain it all in 

21 terms of what you have rated with your AEDM, 

22 what you used to substantiate your AEDM, all 
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1 the testing underlying that, et cetera. 

2 MR. VerSHAW: Jim VerShaw, 

3 Ingersoll Rand. 

4 Two questions. The first one is, 

5 when looking at residential ARMs, today we 

6 have to have testing on the basic model with 

7 the highest sales volume combination. When 

8 you go to an AEDM under the definition, do we 

9 no longer have to do that testing? We just 

10 simulate everything? 

11 MS. ARMSTRONG: So, simulate 

12 everything is not quite right. You do have to 

13 do some testing. There is a different subset 

14 of testing that has to be done. It is not 

15 necessarily the highest sales volume 

16 combination for each basic model. 

17 MR. VerSHAW: You had to do so 

18 much testing to substantiate the AEDM. Once 

19 that is substantiated, then, are you 

20 eliminating the requirement to have the 

21 highest sales volume test combinations tested? 

22 MS. ARMSTRONG: Yes. 
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1 MR. VerSHAW: Okay. 

2 MS. ARMSTRONG: Are you advocating 

3 that we retain it? 

4 MR. VerSHAW: No, I am just trying 

5 to get clarification. I haven't thought it 

6 all the way through yet. 

7 The second question is, with this 

8 setup where you don't prequalify/preapprove 

9 simulation methods, and now I see you 

10 eliminate the need for a lot of testing 

11 ongoing, are you planning on setting up a much 

12 more robust or aggressive enforcement plan to 

13 do a lot of testing by DOE outside of maybe 

14 other industry groups? Or is that driving 

15 that? Or if you did preapproval, would that 

16 reduce the need to do that ongoing testing by 

17 DOE? And maybe I am looking at spending and 

18 cost and duplicate programs and everything. 

19 It raises some questions in that area. 

20 MS. ARMSTRONG: I don't think 

21 there is any specific intention to increase 

22 testing or decrease testing in terms of 
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1 verification and enforcement one way or the 

2 other that is driving these proposals. 

3 I think the majority of the 

4 comments that we got in response to the RFI 

5 kind of pushed for the balance between getting 

6 approval quicker for ARMs and AEDMs generally 

7 versus, you know, manufacturers assuming the 

8 responsibility to make sure their AEDMs and 

9 ARMs are in accordance with our regulations 

10 and maintaining that data and DOE getting it 

11 upon request. 

12 I mean, as you can tell, we are 

13 expanding -- it is on the next slide -- but we 

14 are expanding the scope of ARMs and AEDMs 

15 quite a bit here. So, to say that we were 

16 going to, then, preapprove all of them would 

17 be quite an increase, not only in DOE 

18 reviewing them, but the information that 

19 manufacturers would have to submit. 

20 So, we were more concerned, I 

21 think, with the comments that were worried 

22 about the delay in getting an approved 
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1 simulation. We have also proposed more 

2 reoccurring means by which testing has to 

3 occur. If the models used to substantiate 

4 aren't tested with the new test procedures 

5 each time they are amended or don't meet new 

6 standards, they also have to be 

7 resubstantiated. So, those types of things. 

8 MR. VerSHAW: All right. 

9 MS. ARMSTRONG: Okay. So, we had 

10 a question come in on the line. It said, 

11 "What would the basic model definition be for 

12 mixed systems and ICMs?" This is for Craig 

13 Messmer. 

14 So, I mean, I think for the 

15 context for the AEDMs, and I realize that the 

16 basic model definition and the testing and the 

17 certification is a little mixed, but I don't 

18 think the basic model definition changes with 

19 respect to the AEDM itself. It is just the 

20 AEDM allows for a wider applicability of 

21 simulating the results of each combination 

22 that may be a basic model rather than actually 
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1 testing it. 

2 MR. FLY: Yes, Ashley, kind of 

3 related to the point, and I think this is an 

4 error -- I hope it is an error -- but in The 

5 Federal Register, on 32055, toward the bottom 

6 of the last column, it would be 429.7(C)(2), 

7 you stated that the "test of at least one unit 

8 of each basic model to which the AEDM is 

9 applied in accordance with the applicable 

10 provisions". I am hoping that it was supposed 

11 to have been one unit of each class, not each 

12 basic model, because that kind of infers that 

13 we are going to have to test every basic model 

14 to validate our AEDM, which would kind of 

15 negate the whole idea of an AEDM. 

16 MS. ARMSTRONG: You're correct, it 

17 is product class. Sorry. Thank you. That is 

18 a good one. 

19 MR. LORD: Ashley, along with 

20 that, it would be good to put a definition 

21 someplace on what a product class is. 

22 MS. ARMSTRONG: Yes, that is one 
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1 of the issues for which we sought additional 

2 comment. We will get to that, as to what type 

3 of information or what direction you all may 

4 need as to what exactly a product class is as 

5 it may relate, since you are testing one basic 

6 model from each product class with certain 

7 characteristics, correct. 

8 MR. AMRANE: If I may, Karim 

9 Amrane. 

10 I guess there are certain 

11 products, like commercial refrigeration, where 

12 you have maybe over 20 product classes today. 

13 So, you are going to be asking manufacturers 

14 of commercial refrigeration to test for all 

15 those product classes? I mean, I think that 

16 you need to maybe look at product-by-product 

17 category and see in this particular case, and 

18 see what the burden is going to be. 

19 MS. ARMSTRONG: So, as drafted, 

20 that is the intention, that the manufacturers 

21 of commercial refrigeration equipment, even if 

22 they have upwards of 30 equipment classes, 
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1 would have to test one from each. 

2 That being said, if there is a 

3 way, if there are models that may be similar 

4 or if there is a way to pare those down, or if 

5 you have specific ideas of how that could be 

6 different, or maybe that is reasonable because 

7 it is only 30 models versus 300, or something, 

8 I don't know, you know, please feel free to 

9 speak freely. There are different rating 

10 conditions or different configurations. So, I 

11 encourage you to please speak up to that. 

12 MR. NESHAN: Massoud Neshan, 

13 Southern Store Fixtures. 

14 In a way, you have already defined 

15 those classes in the different energy level 

16 that is allowed for each category or each of 

17 equipment. I don't know why you want to go 

18 beyond that, since you have defined it. You 

19 have been working on that for the past five20 six years, to define those classes, and now 

21 you are talking about additional ones? And 

22 now, also, not only you have defined these 
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1 classes, but one thing you haven't defined is 

2 the basic model. It still is an issue with 

3 not defining basic model. 

4 MS. ARMSTRONG: Okay. One second. 

5 Just to your point, the equipment classes are 

6 going to be the same as the ones that are 

7 defined by the standards. So, for commercial 

8 refrigeration, the ones that are common that 

9 you know about, that are in the standard 

10 rulemaking -- there are 30-some of them, I 

11 believe -- those are the same ones we are 

12 talking about here. It is less obvious for 

13 some of the other products that we are talking 

14 about here, specifically for the ASHRAE table 

15 that make things a little more complicated as 

16 to what an equipment class actually is. 

17 But let me go over here just for 

18 commercial refrigeration, and then I am going 

19 to go back there. 

20 MR. HON: Charlie Hon, True 

21 Manufacturing. 

22 Unfortunately, the classifications 
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1 have secondary nuances built into them to make 

2 them totally different, and you will end up 

3 with well in excess of 100 models in some of 

4 our manufacturing facilities. So, that is 

5 really a large amount of testing that we have 

6 already taken most of it and it is done. So, 

7 now we are redefining it again way late in the 

8 game, because these models should have been 

9 tested a year ago to meet the standard which 

10 was in effect. 

11 MS. ARMSTRONG: So, can I ask you 

12 a question? Do you advocate retaining the 

13 requirements to test each equipment class, 

14 test at least one basic model from each 

15 equipment class? 

16 MR. HON: We should have already 

17 done that years ago. 

18 MS. ARMSTRONG: So, your point of 

19 view would be that manufacturers should 

20 already have that data? They could just use 

21 that data, then, for the AEDM? 

22 MR. HON: Yes. 
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1 MS. ARMSTRONG: But it is not an 

2 increase in testing burden? 

3 MR. HON: It is not an increase in 

4 testing burden, but it gives an advantage to 

5 those who haven't done their homework and are 

6 not up-to-date. Since we have no reporting 

7 requirements, they are still not reported; 

8 those who have cheated on the standard are 

9 going to get a payback on their lack of 

10 effort. 

11 MS. ARMSTRONG: Okay. Thank you. 

12 MR. KLEISS: Jeff Kleiss, 

13 Lochinvar and A.O. Smith. 

14 The term "product class" may be 

15 something that is well-known, I guess, within 

16 the ARMs, but as boilers and water heaters, I 

17 am not familiar with that term. Could you 

18 please define or characterize what that means 

19 or represents? 

20 MS. ARMSTRONG: So, I don't think 

21 we have a specific definition, and perhaps 

22 that is something we need to consider. If you 
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1 look in the standards tables, there are 

2 specific different energy conservation 

3 standards for different product losses. So, I 

4 will give you an example. 

5 For water heaters, it is electric 

6 storage versus gas storage versus oil storage 

7 versus electric instantaneous versus gas 

8 instantaneous. So, those are the five product 

9 classes for water heaters. 

10 MR. KLEISS: Okay. 

11 MS. ARMSTRONG: So, they are 

12 pretty aggregate levels. Usually, they are 

13 either defined by capacity-related features or 

14 fuel types or any other attributes that affect 

15 the energy performance. We usually define 

16 them through our standards rulemaking 

17 processes. 

18 So, if you look in our standards 

19 tables, that speaks to our product classes, 

20 but I hear the need and we kind of foresaw the 

21 need to, yes. Okay. 

22 Sure. 
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1 MR. FLY: I just want to clarify 

2 that just a little bit. So, are you saying 

3 that a product class is any group of equipment 

4 for which a minimum federal standard exists, a 

5 unique minimum federal standard exists? 

6 MS. ARMSTRONG: Yes. 

7 MS. HOOTMAN: Jill Hootman, Trane. 

8 So, to further that explanation, 

9 the ASHRAE table would be for commercial HVAC 

10 below 65,000 btu's, 65 to 135, air-cooled, 

11 obviously -- 

12 MS. ARMSTRONG: Correct. 

13 MS. HOOTMAN: One thirty-five to 

14 240, 240 to 63 tons. 

15 MS. ARMSTRONG: Correct. 

16 MS. HOOTMAN: Is that correct? 

17 MS. ARMSTRONG: That is correct. 

18 And then, depending on the type of heating -- 

19 MS. HOOTMAN: Right. 

20 MS. ARMSTRONG: -- the .2 

21 difference. 

22 MS. HOOTMAN: Right. 
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1 MS. ARMSTRONG: And then, ACs and 

2 heat pumps are different. 

3 MS. HOOTMAN: Right. And then, 

4 the water-cooled -- 

5 MS. ARMSTRONG: Air-cooled, water6 cooled, evap, yes. 

7 MS. HOOTMAN: And then, 65,000 and 

8 below, single-phase and three-phase? 

9 MS. ARMSTRONG: Correct, because 

10 one is residential; one is in commercial. 

11 MS. HOOTMAN: Okay. 

12 MS. ARMSTRONG: Yes, ma'am. 

13 MS. HOOTMAN: Thanks. 

14 MR. DAUGHERTY: Roger Daugherty, 

15 Baldor Electric. 

16 You are getting me a little bit 

17 confused here between basic models, product 

18 classes, and now you are using a term called 

19 "equipment classes". We have been using basic 

20 models for electric motors since the final 

21 rule was published in 1999. It has been very 

22 workable. It has been a very good definition 
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1 of basic model, and it has been used to 

2 substantiate our AEDMs with a well-defined 

3 process of doing so in Part 431. 

4 However, if you switch over to 

5 product classes, then during the rulemaking 

6 process for small electric motors recently, 

7 for the eight power ratings of those motors, 

8 you came up with 72 product classes. 

9 Then, during the present 

10 rulemaking that is going on right now with 

11 respect to electric motors, then you broke 

12 those and you said that there were basically 

13 four product classes, and then you introduced 

14 something called 10 representative product 

15 classes. 

16 However, if you went back to the 

17 same type of definition that you used in the 

18 small electric motor rulemaking, that comes to 

19 roughly 24,014 product classes for electric 

20 motors. The test time to do that exceeds 185 

21 years of testing to cover those product 

22 classes. 
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1 So, our problem with electric 

2 motors and small electric motors there has 

3 never been a clear definition of what a 

4 product class is. If you look at electric 

5 motors, all the electric motors are polyphase 

6 squirrel-cage induction motors. No 

7 difference, whether it is a 1 horsepower or 

8 500 horsepower, whatever; they are all basic, 

9 you might say they are basically the same. 

10 They are just a different size. 

11 If that was a product class, you 

12 would be telling me I test one motor from 1 to 

13 500 horsepower out of that product class. Our 

14 present requirement is to test five different 

15 designs because of the definition of basic 

16 model. And that is why I say basic model for 

17 electric motors and small electric motors is a 

18 very workable definition, and we would not 

19 like to see a change from that over the 

20 product classes. 

21 MS. ARMSTRONG: Okay. 

22 MR. LORD: Yes, just to follow up, 
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1 you kind of quickly said on rooftops and 

2 packaged units that the two-tenths for other 

3 heat would be another product class? 

4 MS. ARMSTRONG: Confirmed, yes. 

5 It is a different level, right? 

6 MR. LORD: But it is very 

7 mathematically-predictable. 

8 MS. ARMSTRONG: So, that could be 

9 a comment. 

10 MR. LORD: Yes, we can provide a 

11 comment. We will. 

12 (Laughter.) 

13 MR. KLEISS: Jeff Kleiss with 

14 Lochinvar and A.O. Smith again. 

15 This goes back to the scope of 

16 coverage. 

17 MS. ARMSTRONG: Uh-huh. 

18 MR. KLEISS: Currently, 

19 residential air conditioning, heat pump units 

20 are covered by AEDMs and ARMs. Has it been 

21 considered adding those to residential water 

22 heaters, residential boilers? If not, is 
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1 there a reason why not? 

2 MS. ARMSTRONG: Okay. So, I am 

3 going to table that for just one second. 

4 MR. KLEISS: Okay. 

5 MS. ARMSTRONG: And I will go 

6 back. 

7 So, any other comments before we 

8 move on to scope of applicability on 

9 preapproval? Just whether the Department 

10 should or shouldn't review and preapprove 

11 AEDMs before they are allowed use. Is there 

12 general support for preapproval? Is there 

13 general support for no preapproval? 

14 MR. GARST: I would say -- Mike 

15 Garst with Lennox -- I think we would support 

16 no preapproval. The only concern we would 

17 have is if someone new comes in the market, 

18 that DOE has some way to at least do some 

19 assessment testing, so that they don't get in 

20 the market a long time, if they have got a 

21 problem. 

22 MR. LORD: Yes, Dick Lord, 
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1 Carrier. 

2 Yes, we support no preapproval, 

3 and you stated it somewhat in the document, is 

4 define exactly what has to be documented. So, 

5 it is very clear to a newcomer what he has to 

6 do. 

7 MR. ROBERTS: Carl Roberts, Zero 

8 Zone. 

9 Eliminating preapproval is a good 

10 and necessary proposal to make compliance 

11 practical. 

12 MS. ARMSTRONG: Anyone else? 

13 MR. AMRANE: Karim Amrane, AHRI. 

14 I think we would support that as 

15 well. And I am not even sure the DOE has the 

16 capabilities of approving all the AEDMs. 

17 MS. ARMSTRONG: You have so little 

18 faith in me. 

19 (Laughter.) 

20 MR. VerSHAW: Ingersoll Rand can 

21 support no preapproval. 

22 MS. ARMSTRONG: Okay. Thank you. 
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1 Okay. Back to the topic of 

2 applicability, so we have proposed it to 

3 expand the use of AEDMs to other types. This 

4 includes commercial refrigeration equipment, 

5 automatic icemakers, small electric motors, 

6 beverage vending machines, walk-in cooler and 

7 freezer ( refrigeration systems only), and 

8 then, continue the use for commercial HVAC and 

9 water heating equipment, distribution 

10 transformers, electric motors, including small 

11 electric motors, as well as CACs, central air 

12 conditioners and heat pumps. 

13 So, to answer your question in the 

14 back about did we consider expanding to other 

15 types of residential equipment, you know, when 

16 we issued the RFI and received comments, the 

17 Department mainly got comments about the need 

18 for AEDMs to rate custom-built, low-volume19 type equipment. And I guess from the 

20 Department's perspective, and we would like to 

21 hear comments on that, as to how residential 

22 water heaters and residential maybe boilers 
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1 fall into that custom-built, made-to-order 

2 type of classification or characterization, if 

3 we should consider, and why we should 

4 consider. 

5 You guys are already testing and 

6 rating and certifying your equipment now. So, 

7 I ask what you do now to get the ratings. Do 

8 you test currently all those? 

9 So, I will open the floor at this 

10 point. 

11 MR. AMRANE: Karim Amrane, AHRI. 

12 We did submit comments to DOE 

13 asking, did you expand the AEDM coverage to 

14 other residential products? Yes, 

15 manufacturers today do test. But, again, we 

16 are talking about reducing the burden of 

17 testing. So, an AEDM would be helpful to 

18 those manufacturers as well. 

19 MS. ARMSTRONG: Can you turn your 

20 microphone on? 

21 MR. STANONIK: Yes, I got it. 

22 MS. ARMSTRONG: Thanks. 
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1 MR. STANONIK: Frank Stanonik, 

2 AHRI. 

3 Ashley, one specific point that 

4 actually has kind of gotten lost here in the 

5 NOPR is that, in the case of residential 

6 boilers, one subclass of products has 

7 something akin to an AEDM and the other 

8 doesn't. And specifically, the rule has 

9 always allowed cast-iron sectionals to do 

10 something like an AEDM. 

11 And we would certainly suggest 

12 that, at least in the case of residential 

13 boilers, make it equal for all boilers and 

14 allow them all to have that option. In the 

15 case of boilers, you are dealing with a market 

16 that on an annual basis is probably in the 

17 200,000s. Maybe in a good year it was 

18 300,000, but a large number of models. 

19 We can talk water heaters; it is 

20 totally different. You are talking about a 

21 market of 9-10 million units. In the case of 

22 boilers, you don't have that magnitude of 
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1 sales. And yet, you have a 

2 disproportionately-large number of models. 

3 And so, while they may not be made to order, 

4 they certainly don't have anywhere near, let's 

5 say, the number of sales per specific model. 

6 And so, it is kind of a unique situation for 

7 residential boilers. 

8 MS. ARMSTRONG: Go ahead, Harvey. 

9 MR. SACHS: Harvey Sachs, ACEEE. 

10 Ashley, the concern with the 

11 contrast between real production-line products 

12 and things with a large degree of 

13 customization is an important one. I am glad 

14 to see it reflected. 

15 On the other hand, if an AEDM's 

16 underlying algorithm is robust and sound, then 

17 even for things which we think of as large 

18 production volumes, the opportunity to use it 

19 reduces the burden of innovation. It makes it 

20 more likely that a manufacturer might respond 

21 to a potential market, for example, for a very 

22 small central air conditioner for a very well-
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1 insulated house. 

2 And here, we have that balance 

3 between not knowing how the AEDM will 

4 extrapolate versus wanting to encourage that 

5 kind of innovation. I think it is a pretty 

6 serious question, but we should not 

7 automatically exclude new products from 

8 classes that we typically think of as being 

9 large-scale production. 

10 MS. ARMSTRONG: I mean, this is 

11 definitely something we have sought comment 

12 on, including the proposed scope of 

13 applicability. So, if there is a wider net 

14 that needs to be considered, we welcome 

15 comments on that. I think the majority of the 

16 comments that we have received so far have 

17 surrounded the idea of the low-volume custom 

18 order. That being said, we are open. 

19 And Frank, to your point about 

20 boilers, I mean, there is no change for the 

21 existing test procedure linear interpolation 

22 for the certain types of boilers, obviously. 
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1 That is inherent within the test procedure, 

2 and that is the same as we have in certain 

3 types of -- other types of commercial 

4 applications also have inherent extrapolation 

5 or estimation-type methods. Those still 

6 remain intact, even with this rule. 

7 Okay. So, we have a bunch of 

8 questions here. One question is, what is the 

9 difference between an equipment class and a 

10 product class? And I apologize. That is 

11 probably myself mixing up the terms. 

12 We use covered product for 

13 residential products, covered equipment for 

14 commercial products, product class for 

15 residential, equipment class for commercial. 

16 The terms are synonymous in their meanings. 

17 One is just the residential market, and one is 

18 just the commercial market. It is just a DOE 

19 terminology thing. So, I apologize for 

20 causing confusion there. 

21 Okay. So, this one is just a 

22 comment, not a question. 
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1 "Under the current mixed/matched 

2 AC/heat pump split system ARM rating rules for 

3 ICMs, the ICM using an ARM must simulate its 

4 rating based on the matched system's highest 

5 sales volume tested combination rating. For 

6 each matched system, basic model may under 

7 your proposal no longer need to be tested. It 

8 is wise to be doing a computer simulation on 

9 someone else's computer simulation" -- I am 

10 not sure exactly what the last one is, but 

11 that is what it says. 

12 So, Mr. Craig has a question 

13 regarding, "Why are AEDMs not available for 

14 walk-in cooler enclosures?" If you mean walk15 in coolers, the whole box, our test method 

16 recently promulgated for walk-in coolers and 

17 freezers is a test method based on components. 

18 There is a different test for the panel. 

19 There is a different test for the 

20 refrigeration system. There is a different 

21 test for the doors. 

22 So, what we have tried to do here 
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1 is allow the simulation, and we explained why 

2 we didn't allow it for other components in the 

3 actual NOPR, but allow the simulation for the 

4 refrigeration system, which we feel was the 

5 most necessary. 

6 Any other comments or questions on 

7 applicability at this point? Please. 

8 MR. DAUGHERTY: Roger Daugherty, 

9 Baldor Electric. 

10 With regard to the small electric 

11 motors, the AEDM was actually added to Part 

12 431 by the final rule of July 7th, 2009. That 

13 final rule added the sampling procedure to 

14 select your basic models, to substantiate the 

15 AEDM, and how you compare it against test data 

16 to substantiate the AEDM. 

17 One problem is that this NOPR 

18 deletes that AEDM from Part 431 and does not 

19 add any information to Part 429 covering small 

20 electric motors. So, now we are left with we 

21 had an AEDM, now it has gone away. Yet, in 

22 429.70, you do apply requirements for the AEDM 
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1 on tolerances and average tolerances, but you 

2 will find there is no section that describes 

3 how to substantiate the AEDM for small 

4 electric motors, since you have eliminated it 

5 from Part 431. 

6 I might also note that I assume it 

7 is an oversight, but throughout the NOPR you 

8 refer to the commercial equipment and other 

9 type of equipment. Small electric motors and 

10 electric motors are classified as industrial 

11 equipment, which is part of the title of Part 

12 431. So, I am assuming your references to 

13 commercial may also be referring to industrial 

14 equipment. 

15 MS. ARMSTRONG: That is correct. 

16 MR. DOPPEL: Paul Doppel with 

17 Mitsubishi Electric. 

18 VRF systems aren't specifically 

19 mentioned here. Should they be included? 

20 MS. ARMSTRONG: Okay. So, I 

21 believe -- and cross-check my math here -- but 

22 in the ASHRAE rule, DOE added VRFs as a type 
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1 of commercial air conditioning and heating 

2 equipment, and AEDMs apply to all commercial 

3 air conditioning and heating equipment. 

4 MR. DOPPEL: Okay. Thank you. 

5 MS. ARMSTRONG: Just make sure 

6 that the reg text -- we will check it as well, 

7 but make sure that that is in. That was the 

8 intention, though. 

9 MR. STRAUB: Mike Straub, 

10 Heatcraft Refrigeration. 

11 We appreciate the ability to 

12 utilize AEDMs on the refrigeration systems for 

13 walk-in coolers and freezers. The issue that 

14 we have is the definition of product classes. 

15 You stated that the product classes would be 

16 defined when the performance standards are 

17 revealed, but that was supposed to be January 

18 of this year. That hasn't been done. Is it a 

19 matter of manufacturers submitting information 

20 to you on what we believe product classes 

21 should be? Or do we have to wait? Because we 

22 would like to be doing our testing to develop 
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1 AEDMs now. 

2 MS. ARMSTRONG: So, first of all, 

3 we would welcome information that suggests 

4 what product classes should be. That being 

5 said, the rulemaking is also ongoing 

6 considering standards for them. I am sure the 

7 preliminary analysis at least speaks to some 

8 of that. So, I would cross-check with that. 

9 But, yes, you are right, the final 

10 product class or equipment class wouldn't come 

11 out until amended standards. And so, we could 

12 deal with that here. 

13 Yes, thank you for pointing that 

14 out. 

15 Okay. So, we have talked about 

16 most of this, but the idea, the premise that 

17 the Department had was that we believe that 

18 manufacturers should have the ability to come 

19 up with a single AEDM or multiple AEDMs at 

20 their discretion for use across a wide range 

21 of their product offering. It could be one 

22 simulation for all the products. It could be 
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1 multiple ones. Really, our proposal is just 

2 that. It is left to your discretion. 

3 So, we have gotten a lot of 

4 comments already on what are product classes 

5 and equipment classes in terms of that. We 

6 noted that we would be interested in knowing 

7 if you needed additional clarification on 

8 that. 

9 But we wondered what you guys 

10 thought about the use of a single AEDM or 

11 multiple AEDMs or leaving it at your 

12 discretion to use a single AEDM across a wide 

13 range of product classes in your entire 

14 product offering, if you so choose to and they 

15 met the substantiation requirement. 

16 So, I open the floor for that 

17 proposal. 

18 MR. LORD: Dick Lord with Carrier. 

19 We favor that. I mean, you can 

20 leave it to our discretion whether we want to 

21 do it for a small product or a large product 

22 class. So, we support that. 
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1 MR. FLY: Mark Fly with AAON. 

2 I, too, support that. The basic 

3 components that are going into all these 

4 products are the same are similar, and we have 

5 product models developed for each component. 

6 And so, the AEDM is a balance of all the 

7 components that we have put together. So, it 

8 seems reasonable that we can do that. 

9 Now are you going to discuss at 

10 some point the tolerances on the AEDM? 

11 MS. ARMSTRONG: Yes, that is next, 

12 and I might seek a break before that for my 

13 own benefit. 

14 (Laughter.) 

15 Does anyone else want to -- sure. 

16 Sorry, Harvey. 

17 MR. SACHS: Harvey Sachs, ACEEE. 

18 To turn back to your example of 

19 product classes, which might be electric 

20 resistance water heaters, gas water heaters, 

21 tank and tankless, and all the other 

22 permutations that we have now as product 
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1 classes, you can certainly take Dick Lord's 

2 approach and have different modules and call 

3 that a single AEDM. Or you can be using 

4 different models for product class. And the 

5 question is, does or should DOE have an 

6 interest in which way a manufacturer chooses 

7 to do his AEDMs? 

8 I might be a manufacturer who only 

9 does super-insulated tank water heaters. Do I 

10 need to have a broadly-applicable AEDM? 

11 MS. ARMSTRONG: So, this is 

12 Ashley. 

13 Okay. So, what we tried to do was 

14 allow the manufacturer the discretion to have 

15 the broadly-applicable AEDM or have the not16 broadly-applicable AEDM. In other words, it 

17 doesn't require broad applicability. 

18 If they are only going to use it 

19 for a single product class, then it only has 

20 to be tested with that product class, although 

21 the minimum number of models is five. So, it 

22 would be five models, period. 
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1 But I get where you are going with 

2 this, but it doesn't have to have like this 

3 wide-range applicability if it didn't need to. 

4 MR. ROBERTS: This is Carl at Zero 

5 Zone. 

6 Based on working with this over 

7 the past couple of years, the reality is that 

8 we have to use AEDMs in order to rate untested 

9 basic models for compliance to be practical. 

10 In all reality, we end up testing several 

11 models from each product class or equipment 

12 class. 

13 And it is necessary to use more 

14 than one AEDM, even within a particular 

15 equipment class. That is how it works out so 

16 far. And even then, it is going to be 

17 difficult for small manufacturers to comply. 

18 MS. ARMSTRONG: I am going to ask 

19 a followup. Can you explain why that is? And 

20 do you have a suggestion to help? I mean, 

21 what would you change? 

22 MR. ROBERTS: That is a good 
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1 question. To answer the question why, testing 

2 is very complex. And for a small manufacturer 

3 or a startup, it would represent a very large 

4 part of what they are doing. It might exceed 

5 the effort put into manufacturing. 

6 I am not sure what the answer is, 

7 you know, how do you solve that problem. I 

8 guess one possibility is that you give very 

9 small manufacturers a pass or some permutation 

10 of that. That is all I can think of. 

11 MR. NESHAN: Massoud Neshan, 

12 Southern Store Fixtures. 

13 I would like to add to what was 

14 just stated. We are a small manufacturer of 

15 commercial refrigeration equipment, and we 

16 manufacture highly-customized and unique and 

17 different display cases on a daily basis. 

18 In our standard catalog, we have 

19 over 500 basic models. And then, on a daily 

20 basis, we design new equipment. And we might 

21 only sell one case of that unique design in a 

22 given year, but the effort that goes into 
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1 testing that or developing AEDM is the same as 

2 when we manufacture a thousand of the same 

3 model. So, it is a very back-breaking process 

4 and costly process that kind of prohibits 

5 innovation and providing what the customers 

6 require. 

7 What is the solution? It is very 

8 simple. And I know we have discussed this in 

9 the past, but the answer has been no. But you 

10 have to set a limit on, if you sell two pieces 

11 of equipment a year, does it need to be going 

12 through the same process? That is the 

13 question. Or should it be a limit of 10 or 20 

14 or 50? I don't know what the answer is. 

15 But there has to be a solution, so 

16 that it would allow us, as a small 

17 manufacturer, to design, manufacture, and sell 

18 the piece of equipment that we need to do. 

19 Under current test conditions, we 

20 have to test at least two units before we can 

21 enter that unit into commerce. Well, picture 

22 this: we manufacture one. We sell one. But 
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1 we have to manufacture two to test. It just 

2 doesn't make sense. 

3 I mean, we waste more energy 

4 manufacturing the second unit than we would 

5 ever save in the entire life of that unit that 

6 was sold into the marketplace. It just 

7 doesn't make sense. 

8 Maybe we have to look at what some 

9 Europeans and other countries have 

10 established. They have established, for 

11 example, Australia and New Zealand, if you 

12 import less than 50 units per year, they are 

13 exempt from their requirements, which is 

14 practical. 

15 Thank you. 

16 MR. WILKINS: Robert Wilkins, 

17 Danfoss. 

18 Just an observation that this has 

19 to do with materiality. Materiality from the 

20 manufacturer's point of view, but also 

21 materiality from the customer and from the 

22 market-at-large point of view. 
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1 You might be able to deal with 

2 some of these kinds of issues by a materiality 

3 provision that puts a cutoff, that sets some 

4 limits or thresholds. Just an idea. 

5 MS. ARMSTRONG: Thank you. 

6 Sure, Karim, go ahead. 

7 MR. AMRANE: Karim Amrane, AHRI. 

8 I guess I have a question for DOE. 

9 Does DOE have the authority to, for example, 

10 put the limit on a minimum, a production limit 

11 or something like that? Or does it need some 

12 legislation? 

13 MS. BARHYDT: Can I respond to 

14 that after the break? 

15 MR. AMRANE: Sure. 

16 MS. ARMSTRONG: Okay. 

17 MR. DAUGHERTY: Roger Daugherty, 

18 Baldor Electric. 

19 I think it is becoming obvious 

20 that over the many years that we have been 

21 working on the various final rules and NOPRs 

22 for electric motors and small electric motors, 
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1 that those are being lumped over and looked at 

2 like some of these other products. Once we 

3 get into electric motors, as I said, just at a 

4 single mechanical configuration, you are 

5 looking at 24,000 basic models covered by the 

6 present standards in Part 431. Add on those 

7 for the small electric motors. 

8 So, if you were to define the 

9 product classes the way you did for small 

10 electric motors, this idea of testing one 

11 basic model from each product class just is 

12 inconceivable for electric motors and small 

13 electric motors. That is why I encourage you 

14 to reconsider what is in presently Part 431 

15 for electric motors and small electric motors 

16 as to how to properly select at least five 

17 basic models that cover the ratings that are 

18 covered by the standards and make 

19 substantiation of AEDM from that. 

20 And it may be necessary that in 

21 Part 429 that you bring that information over 

22 for electric motors and small electric motors 
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1 and not do the substantiation on product 

2 classes and things like you are doing it for 

3 other equipment. 

4 Thank you. 

5 MS. ARMSTRONG: Thank you. 

6 MR. DOPPEL: Ashley? 

7 MS. ARMSTRONG: Yes? 

8 MR. DOPPEL: Paul Doppel with 

9 Mitsubishi Electric. 

10 In The Federal Register on page 

11 32056, and this is under paragraph 5, 

12 "Additional Test Units," "Each AEDM must be 

13 supported by test data obtained from physical 

14 tests of current models." 

15 MS. ARMSTRONG: Right. 

16 MR. DOPPEL: That is kind of an 

17 implication that every time you change your 

18 model lineup you have to change your AEDM. Is 

19 that the intent there? 

20 MS. ARMSTRONG: That is not how -- 

21 well, perhaps we need to clarify. 

22 But this is Ashley from DOE. 
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1 If one of the models you use to 

2 substantiate your AEDM is discontinued, you 

3 need to replace it with an active model. That 

4 is what it means. In other words, if a new 

5 standard goes into effect and three of the 

6 five units you use to substantiate your AEDM 

7 will no longer meet the standard and are 

8 either (a) redesigned and rerated or (b) 

9 discontinued, then you need to go through and 

10 make sure, resubstantiate your AEDM. 

11 That does not necessarily imply 

12 that you need to change your AEDM, but if you 

13 rerun it and the results are no longer valid 

14 for the simulation, you would need to retest 

15 those models with actual testing, compare it 

16 to the simulation. And for each model beyond 

17 the 5 percent, if the mean is not within the 3 

18 percent, then you would need to do something 

19 at that point, whatever it may be. Okay? 

20 There is like a more reoccurring thing rather 

21 than a never. 

22 Yes? 
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1 MR. SACHS: Do you want to get 

2 into the substantiation part now or do you 

3 want to wait? 

4 MS. ARMSTRONG: No. No, let's 

5 take a break. 

6 (Laughter.) 

7 MR. VerSHAW: I have got a 

8 question, though, first. 

9 MS. ARMSTRONG: Oh, sure. 

10 MR. VerSHAW: You know, I think if 

11 you look at each type of product you are 

12 trying to cover -- oh, Jim VerShaw with 

13 Ingersoll Rand -- you know, we do air 

14 conditioning and heat pumps and heating. For 

15 air conditioning on the residential side, it 

16 is the same engine that does the simulations, 

17 whether it is a heat pump or an air 

18 conditioner. And we are relatively, you know, 

19 one and a half to five tons, it is fairly 

20 straightforward. 

21 If you get into the bigger 

22 equipment, and I don't see any difference 
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1 between a 15-ton and a 25-ton in terms of how 

2 you would simulate that. It still has got a 

3 compressor. It has got two coils and it has 

4 got a couple of fans. 

5 So, why you need to go into those 

6 air conditioners and have one from each one, 

7 it might be better to know which of those 

8 models are the ones that are pushing the 

9 design the hardest, which one is most compact 

10 or most open or that type of thing. Whether 

11 or not it is gas heat or electric heat may not 

12 be an issue. 

13 I think we need to have an open 

14 mind by product family as to how you would go 

15 about doing that. I think that we may be 

16 asking for more tests upfront than are really 

17 necessary. Or maybe it is too easy to pass it 

18 in some cases, you know, if you want to 

19 cherry-pick some of those. 

20 We will be making comments on 

21 that, but -- 

22 MS. ARMSTRONG: Yes, I mean, at 
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1 this point, the Department is open. It was 

2 very clear when we wrote the notice 

3 -- hopefully, it is clear to you as well -- 

4 that we would consider alternatives. So, 

5 suggestions are welcome both ways. 

6 So, at this point, we are going to 

7 take about a 15-minute break. We are going to 

8 come back to talk about substantiation 

9 requirements. 

10 Please come back at about 10:30 or 

11 so. 

12 (Whereupon, the foregoing matter 

13 went off the record at 10:13 a.m. and went 

14 back on the record at 10:34 a.m.) 

15 MS. ARMSTRONG: Okay. Getting 

16 back, before we get into substantiation 

17 requirements, we have two questions on the 

18 phone. 

19 So, the first one I am going to go 

20 to is Robert Barry. 

21 MR. BARRY: Yes, hi. This is 

22 Robert Barry with Unico. 
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1 This is a question pertaining to 

2 ICMs. Before the break, we talked about the 

3 conditions under which a manufacturer would 

4 have to resubstantiate their own AEDM. I was 

5 just wondering, going back a step, what is the 

6 responsibility of ICM manufacturers to 

7 resubstantiate their AEDM if one of the 

8 manufacturers with whom they pair has to 

9 resubstantiate their AEDM? And what is the 

10 responsibility of an ICM for modeling results, 

11 tolerances, for the overall mixed system, 

12 especially in light of the black-box nature of 

13 each manufacturer's simulation methods and 

14 algorithms? And would DOE consider providing 

15 data or standard AEDMs for the various classes 

16 that ICMs could use in lieu of manufacturer 

17 data for the purposes of ratings and 

18 substantiation from systems? 

19 MS. ARMSTRONG: Okay. So, I am 

20 going to go one-by-one because that was a lot 

21 of questions. 

22 MR. BERRY: Yes, sure. 
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1 MS. ARMSTRONG: Okay. So, I am 

2 going to start with the last one first. Right 

3 now, this proposal doesn't contemplate like a 

4 DOE kind of an overall AEDM. That is the 

5 first thing. Right now, it just allows 

6 manufacturers at their discretion. So, at 

7 this point, we have not considered anything 

8 like that. 

9 As far as ICMs go, and if a 

10 condensing unit specifically is discontinued 

11 that you built your AEDM off of for the ICM, 

12 even though you are not the manufacturer of 

13 the condensing unit, you know, it doesn't 

14 specifically separate requirements between an 

15 OEM and an ICM, and maybe that is something 

16 the Department should consider. Right now, it 

17 seems to read the same. 

18 So, if a model was discontinued, 

19 like a condensing unit was discontinued for 

20 what you used to substantiate your AEDM, it 

21 seems -- this is just the way I read it -- 

22 that you would need to replace that unit by a 
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1 new condensing unit, test it in the same way 

2 an OEM would. And to the extent you have 

3 certain suggestions that we should consider 

4 specific to ICMs, we would welcome those. 

5 Okay. So, the next question is 

6 from Ron Shebik. 

7 Okay. Ron? 

8 MR. SHEBIK: Yes, hi, Ashley. Can 

9 you hear me? 

10 MS. ARMSTRONG: I can hear you. 

11 Just make sure you talk pretty closely to the 

12 phone. 

13 MR. SHEBIK: Okay. Hey, Ashley, I 

14 would just make a comment that, in general, I 

15 agree with the discussion on page 16, but I 

16 think maybe a useful exercise, since there 

17 seems to be some confusion amongst the people 

18 in this meeting, a useful exercise may be to 

19 look at product classifications, basic model 

20 groups, and equipment classification, and 

21 maybe discuss how they all relate to each 

22 other. 
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1 MS. ARMSTRONG: Sure. Thank you. 

2 MR. SHEBIK: Thanks. 

3 MS. ARMSTRONG: Okay. So, if we 

4 don't have any other general questions before 

5 we move into substantiation requirements, we 

6 are going to do just that. 

7 So, the AEDM tolerances, 

8 currently, the Department, for those products 

9 for which we have simulations where we have 

10 two tolerances -- well, we have three -- one 

11 is 1 percent and one is 5 percent and one is 

12 10 percent, and they vary by product type. 

13 So, in this rulemaking, DOE has 

14 individual tolerances for most of the 

15 equipment, commercial HVAC, refrigeration-type 

16 equipment, residential CACs and CHBs at 5 

17 percent. So, each individual unit tested must 

18 be within 5 percent of the AEDM simulation 

19 results. 

20 Yes? 

21 MR. VerSHAW: I just find it 

22 interesting -- Jim VerShaw, Ingersoll Rand -- 
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1 that motors have a 10 percent tolerance and 

2 HVAC, which takes -- what? -- 95 percent or 99 

3 percent of this energy comes from three 

4 motors, maybe four, and we are only doing 5 

5 percent, along with scroll and piston 

6 machining and prop fans and blower wheels, and 

7 all the other things that you get variations 

8 in, along with an extreme amount of lab 

9 variation. 

10 MR. WILKINS: Robert Wilkins, 

11 Danfoss. 

12 I was just going to comment on the 

13 lab variation inherent in unitary air 

14 conditioning compared to motors. 

15 MS. ARMSTRONG: Can you speak to 

16 what you think the magnitude of each of those 

17 is? 

18 MR. VerSHAW: This is Jim Vershaw. 

19 Through work at Ingersoll Rand 

20 and, also, with AHRI, we have been digging 

21 into this lab issue. There is a lot to it. 

22 If you look at repeatability, a major third-
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1 party lab does round robins with a single 

2 unit, and they think they are doing well if 

3 they are plus or minus 2 percent from the test 

4 from facility-to-facility. 

5 Now, if you have a unit that 

6 essentially has a performance of one, but you 

7 test it in one room and you get .98 and you 

8 test it another room and you get 1.02, the DOE 

9 rules won't allow us to rate it at the mean. 

10 It is too far apart. And that is just 

11 repeatability from room to room. 

12 Now in terms of variability, 

13 instrumentation for measuring volts and all 

14 these things has been improved over the years. 

15 However, the subsystems that they are used on 

16 haven't. In fact, work that has been done by 

17 the AHRI subcommittee has found that there are 

18 inadequacies in the ASHRAE standards for 

19 psychrometers, for mixers, for damper boxes. 

20 And there is really five things. 

21 So, measuring wet bulb, which is 

22 key to the air conditioning, is not done very 
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1 well. Measuring airflow is not done very 

2 well. In fact, we have found substantial 

3 error, depending on which nozzles you were 

4 using. Mixer boxes aren't defined well 

5 enough. The sample trees in which you try to 

6 sample the air going into the heat exchangers 

7 are not well-defined. 

8 And so, there are about five 

9 things, and each one of those five things has 

10 a variation of about 1.5 to 3 percent effect 

11 on testing. Now does that add up to 15 

12 percent? No, but 5 percent is really a 

13 stretch on those things. 

14 Now let's put on top of that you 

15 have got the 10 percent motor variation. And 

16 compressors tend not to come out of the box at 

17 mature performance. Most compressors, 

18 especially scroll manufacturers, will supply a 

19 compressor to us that is somewhere between 95 

20 and 97 percent of its rated performance, which 

21 after about 75 hours of run time is probably 

22 pushing, then, closer to 99 to 100 percent. 
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1 So, lots of issues in here as far 

2 as what can happen. We have been dealing with 

3 the 5 percent tolerance for quite a bit of 

4 time through the AHRI program. Of course, we 

5 conservatively rate equipment and the like. 

6 And so, I think that some of these numbers 

7 like 3 percent is difficult. 

8 MS. ARMSTRONG: So, just to 

9 clarify, are we okay with the 5 percent, but 

10 you are advocating a 5 percent for motors? 

11 MR. AMRANE: Karim Amrane. 

12 I guess I think what we need here, 

13 we need to revisit all those tolerances and 

14 those percentages. I mean, why 5 percent? 

15 Why 10 percent? On what basis is DOE picking 

16 10 percent for motors and 5 percent for air 

17 conditioners? I think those things have to be 

18 revisited. They have been there for many, 

19 many years, but I think it is about time to 

20 review them. 

21 MS. ARMSTRONG: We will go to the 

22 back one second. 
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1 MR. DAUGHERTY: Roger Daugherty, 

2 Baldor Electric. 

3 I think I can clarify some of the 

4 confusion here. But, first, what I think is a 

5 rather simple question to DOE. When a final 

6 rule is published and makes changes to one of 

7 the parts, when are those changes effective? 

8 I ask because, in preparing comments on this 

9 NOPR, there is a final rule May 4th of this 

10 month that made changes to things that are 

11 being changed by this NOPR. 

12 So, I would like to know whether 

13 or not that final rule is in place and the 

14 comments go against that final rule or if the 

15 final rule, then, replaces over this NOPR, 

16 which means the change is made through this 

17 NOPR, get replaced by that final rule. 

18 MS. ARMSTRONG: So, these are 

19 proposed. These would overwrite the final 

20 rule changes. 

21 MR. DAUGHERTY: Okay. 

22 MS. ARMSTRONG: So, the comments 
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1 go to this docket. 

2 MR. DAUGHERTY: Okay. Now, to try 

3 to clarify what is here -- and I found it very 

4 interesting that, under the present procedure 

5 for electric motors and small electric motors, 

6 for substantiating the AEDM, the tolerance 

7 that is applied of 10 percent is to total 

8 losses, not to efficiency. Yet, in preparing 

9 this NOPR, DOE has changed that to be a 

10 tolerance on efficiency. 

11 Was that the actual intent of DOE 

12 to change the tolerance for electric motors 

13 and small electric motors to be based on 

14 efficiency rather than total losses? And I 

15 only point that out because that is a 

16 substantial difference between the tolerance 

17 on efficiency values. 

18 MR. HON: Charlie Hon, True 

19 Manufacturing. 

20 I am sitting here looking at 

21 commercial refrigeration equipment, self22 contained materials. I can tell you for a 
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1 fact that I can take the standard procedure, 

2 the test procedure available to us today, 

3 within the scope of the range of electrical 

4 current, ambient temperatures within the room, 

5 and the temperature inside the cabinet, and 

6 keep them all in the specification, and come 

7 up with about 8 percent variation unit-to-unit 

8 on the same unit. 

9 MR. VerSHAW: Yes, this is Jim 

10 Vershaw again. 

11 There has been some work done, the 

12 ISO group, a working group on looking at 

13 efficiencies, again, for HVAC-type equipment 

14 where you do an entropy balance. They are 

15 pushing for a 10 percent uncertainty because 

16 they found it was close to 7 percent for air 

17 conditioning in that work, which kind of 

18 supports the issues that I brought up earlier. 

19 MR. ROBERTS: This is Carl from 

20 Zero Zone. 

21 With regard to CRE, there is a 

22 number of things that affect this percentage. 
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1 There is a surprising amount of variability 

2 in the manufacturing of things like the glass 

3 doors. In fact, our tolerance from our glass 

4 door vendors for the heat on the glass doors, 

5 plus or minus 10 percent. There are a number 

6 of things that are hard to measure, short of 

7 having a million-dollar lab, such as mass 

8 flow. There are things that are hard to 

9 regulate, such as voltage and humidity. 

10 For a reasonably-equipped third11 party test facility, I think the 5 percent and 

12 3 percent is too tight. I think 10 percent 

13 and 5 percent might be more like it. 

14 MR. FLY: You know, having mostly 

15 air conditioning guys having been testing with 

16 ARI for a number of years, and comparing it 

17 with one lab, which does chamber-to-chamber 

18 tests that are in the 2 percent range, we have 

19 all calibrated our ratings, basically, to the 

20 results of that lab. That is the meter stick 

21 today. 

22 My big concern is, if we start 
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1 going out to other labs and we are just using 

2 some ISO standard that basically says I have 

3 got smart people running the place, and that 

4 my equipment has been calibrated, we all know 

5 who are sitting in this room that there is a 

6 whole lot more to getting repeatable results 

7 than that. 

8 I would strongly encourage, when 

9 you are looking at these tolerances, that you 

10 look at tolerances only on one side, 

11 whichever, so that we can conservatively rate 

12 equipment and even conservatively calibrate 

13 our AEDM, so that we are sure to not only 

14 account for our lab tolerances and our 

15 manufacturing tolerances, even if they happen 

16 to be beyond what we see up here. 

17 So, the ability to be able to not 

18 do plus or minus when we are looking at the 

19 AEDM qualifications, to fall along the same 

20 lines as you have done with the testing and 

21 the confidence levels, so that you only go to 

22 the negative side, would be very helpful. 
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1 MS. ARMSTRONG: Yes. So, before I 

2 keep going, I am just going to answer that. 

3 Throughout 429 in the individual product 

4 sections, you will notice that we restructured 

5 a bit. Perhaps you haven't had a chance to 

6 fully read through this. 

7 But what it does is the first 

8 part, it sets forth any representative value 

9 from testing. And then, the second part, it 

10 sets out any representative value from an 

11 AEDM. What it allows is either to use 

12 something more conservative than the AEDM 

13 value all the way up to the AEDM value. So, I 

14 believe that is what you are asking for, and 

15 that is in the proposal for each product. 

16 MR. FLY: Yes, but within the 3 

17 percent average of the mean is plus or minus. 

18 MS. ARMSTRONG: I understand. 

19 MR. FLY: Which means I have got 

20 to have test data that falls within that 3 

21 percent and I have to be at the center of it. 

22 I may want to conservatively rate or 
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1 calibrate my AEDM to be lower than that, so 

2 that I can ensure that I can account for any 

3 lab-to-lab. 

4 MS. ARMSTRONG: You would rather 

5 just go to the negative range? Okay. 

6 Keep going around. 

7 MS. HOOTMAN: Yes, I was going to 

8 say I agree just on the negative range -- 

9 MS. ARMSTRONG: Okay. 

10 MS. HOOTMAN: -- and let the 

11 upside potential be there. 

12 MR. SACHS: Harvey Sachs, ACEEE. 

13 We have no objection on policy 

14 grounds for manufacturers who wish to mislead 

15 the public by selling products that are more 

16 efficient than their ratings would indicate. 

17 (Laughter.) 

18 We support the negative. 

19 MS. ARMSTRONG: Sure. Sure. 

20 Thank you. 

21 Go ahead. 

22 MR. GARST: Mike Garst at Lennox. 
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1 Just support the negative only. 

2 It is really especially important for the ICMs 

3 because they have got very limited information 

4 from the high-side manufacturers, and they 

5 have to be conservative. 

6 MS. ARMSTRONG: Sure. 

7 MR. LORD: I have a little bit 

8 different take on what you are asking here. 

9 The way I understood it, I test five units and 

10 they have to be within 5 percent and the 

11 average has to be 3 percent. Now that proves 

12 my AEDM. 

13 Now I can add an additional 2 

14 percent, 5 percent, whatever I want, to my 

15 AEDM when I publish my ratings. So, I am 

16 conservative, right? 

17 MS. ARMSTRONG: That is correct. 

18 MR. LORD: Yes. 

19 MS. ARMSTRONG: That is exactly 

20 correct. 

21 MR. LORD: So, this just validates 

22 your test -- 
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1 MS. ARMSTRONG: This is validating 

2 your rating. Your rating, then, I mean, you 

3 can then use your AEDMs, once they are 

4 substantiated, to get the certified ratings 

5 for everything else and those can be 

6 conservative all the way down to the standard. 

7 MR. LORD: Yes. 

8 MR. FLY: So, what point is the 3 

9 percent? 

10 MR. LORD: So, basically, you have 

11 five tests. And I can keep going. I will 

12 answer it. I won't do that. 

13 (Laughter.) 

14 You have five tests. In those 

15 five tests, none can be more than 5 percent 

16 off, plus or minus 5 percent, and the average 

17 has to be plus or minus 3 percent. That 

18 substantiates your AEDM. 

19 Now, when you publish, you can say 

20 we don't feel confident; we are going to add 

21 another 2 percent safety factor. And that is 

22 what she is saying is okay. 
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1 MS. ARMSTRONG: That is correct. 

2 I mean, his explanation is right. 

3 Go ahead. Go ahead. Yes. 

4 MR. WILKINS: Robert Wilkins, 

5 Danfoss. 

6 I would like to reiterate a point 

7 Karim Amrane made about maybe stepping back 

8 and taking a fresh look or a deeper look at 

9 some of this. And some of the dimensions that 

10 I would like to comment on are you have a wide 

11 range of equipment listed up there. Some 

12 equipment is self-contained. It is factory13 charged. It is factory-sealed. It is very 

14 controllable by the manufacturer. 

15 Some of that equipment is field16 connected and even field-charged or at least 

17 field-topoff. And in the lab, there are some 

18 restrictions as to how much tweaking of the 

19 refrigerant charge is appropriate. And even 

20 if the manufacturer specifies that certain 

21 amount of adjustment is in order, it may not 

22 be done in the lab. 
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1 And so, there is a wide range of 

2 variability attributable to the type of the 

3 equipment that might be considered here as 

4 well, self-contained versus field-connected 

5 and field-charged, for example. 

6 MS. ARMSTRONG: Okay. Go ahead. 

7 MR. LORD: Yes, maybe to add, and 

8 I was going to bring it up later, but this is 

9 probably a good point. When you get into 

10 commercial equipment, it is a very complex 

11 piece of equipment. Most have microprocessors 

12 on it. 

13 I know on our equipment, and I 

14 think a lot of the competitors also do the 

15 same thing, we require factory commissioning. 

16 You know, they have to set it up because the 

17 average guy is not trained to set up that 

18 piece of equipment. 

19 So, I know you have allowed that 

20 on VRF systems. We need to also consider that 

21 on large commercial equipment. 

22 MS. ARMSTRONG: Okay. 
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1 MR. WILKINS: My one rule would be 

2 anytime factory commissioning is required in 

3 the field, it should be considered in the 

4 laboratory as well. 

5 MS. ARMSTRONG: Okay. 

6 MR. VerSHAW: Jim VerShaw, 

7 Ingersoll Rand. 

8 For the testing, these tests, Test 

9 X-1 on, are those manufacturers' tests or are 

10 they third-party tests? 

11 MS. ARMSTRONG: No, there is no -- 

12 this is Ashley from DOE -- there is no third13 party testing requirements. They are 

14 manufacturer tests. 

15 MR. VerSHAW: Oh, I guess it is 

16 manufacturer setup then. 

17 (Laughter.) 

18 MS. ARMSTRONG: Correct. I think 

19 he was referring to verification and 

20 enforcement potentially. 

21 Sure. Please. 

22 MR. DAUGHERTY: Roger Daugherty, 
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1 Baldor Electric. 

2 With regard to this plus or minus 

3 3 percent, throughout the discussion in the 

4 NOPR, in the actual title of Figure C-1, it 

5 says, "except for electric motors and small 

6 electric motors," but that exception is not in 

7 the text, in the actual 429.75(i). 

8 MS. ARMSTRONG: Okay. 

9 MR. DAUGHERTY: Oh, I guess it is 

10 four, under "Average Tolerances". 

11 And maybe give a little bit more 

12 information. I realize, again, there is this 

13 thing of electric motors and small electric 

14 motors, and they are treated very differently 

15 than many of these other products. 

16 In EPAct in 1992, they were the 

17 only equipment that was actually required to 

18 have to be tested in an accredited test 

19 facility. And so, in the 1990s, between NEMA 

20 in conjunction with NIST/NAVLAP, so that they 

21 could create an accreditation program, we 

22 conducted round-robin testing to determine 
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1 what the tolerance was as a factor of testing, 

2 both during the round robin, so we could see 

3 between test facilities, and also see just for 

4 testing motors within a facility. 

5 And as a result of that, we 

6 actually conducted a second round of round 

7 robin after modifying the IEEE 112 test 

8 standard and created the NAVLAP Handbook 

9 150-10 for the accreditation program. 

10 So, there is a very great deal of 

11 background that goes into the various levels 

12 of tolerances that are in the test 

13 requirements for testing a sample of five of a 

14 basic model within Part 431, as well as the 

15 comparison to AEDM. So, while I would suggest 

16 for electric motors and small electric motors 

17 that you reconsider what is in Part 431 and 

18 the use of the word "tolerance" against total 

19 losses, but also that tightening that up would 

20 be extremely difficult. And you need to go 

21 back into the history that really supports all 

22 of that information. 
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1 Thank you. 

2 MR. FLY: In looking for some of 

3 this information on your website -- 

4 MS. ARMSTRONG: State your name. 

5 State your name. 

6 MR. FLY: Oh, Mark Fly with AAON. 

7 In looking at some of the 

8 information on your website, it looked DOE had 

9 been running a round-robin test. Is any of 

10 this information that you have got here based 

11 on any -- I haven't seen any results of that 

12 -- of any round-robin lab-to-lab test data on 

13 HVAC equipment? 

14 MS. ARMSTRONG: So, the round 

15 robin we have run so far is mostly for 

16 residential household appliances, not 

17 necessarily for this type of equipment yet. 

18 And most of these were informed either by -- 

19 we have existing sampling procedures which 

20 have test tolerances for actual testing, as 

21 well as comments we received in response to 

22 the RFI from manufacturers. 
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1 Karen? 

2 MS. MEYERS: Yes, this is Karen 

3 Meyers with Rheem Manufacturing. 

4 My question was similar. I was 

5 just curious, you know, what was the analysis 

6 that DOE used to come up with this 5 percent, 

7 10 percent, and 3 percent? How do we know? I 

8 mean, where do those numbers come from? Are 

9 they just -- 

10 MS. ARMSTRONG: It is the same 

11 thing I just said. 

12 MS. MEYERS: Yes. So, I mean, I 

13 think it would be, if we are going to set a 

14 rule on how we should do this, there should be 

15 some type of statistical analysis to find out, 

16 are these, in fact, the right percentages? I 

17 mean, I don't know; maybe they are. But it 

18 seems like there should be some type of 

19 analysis, then, to substantiate these 

20 percentages. 

21 MS. ARMSTRONG: Okay. We have a 

22 couple of questions from the phone. 
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1 Steve Ruffing, you should be 

2 unmuted. 

3 MR. RUFFING: Okay. I wanted to 

4 expand on a previous comment that Roger 

5 Daugherty made about whether the electric 

6 motor and small electric motor tolerance is 

7 based on efficiency or total losses. 

8 What is presently codified in 10 

9 CFR Part 431 is a tolerance based on total 

10 losses. So, for instance, if you had a 

11 nominal full-load efficiency of 91.7 percent, 

12 if you took 10 percent greater losses than 

13 that, you would actually end up with an 

14 efficiency of 90.9 percent. And if you took 

15 10 percent lower losses than that, you would 

16 end up with an efficiency of 92.4 percent. 

17 So, the tolerance on the 

18 efficiency is presently codified. It is, 

19 actually, in this particular case plus or 

20 minus 1 percent. But what is being proposed 

21 here in the NOPR is to change the tolerance to 

22 plus or minus 10 percent on the efficiency, 
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1 not the total losses. 

2 So, going back to this example of 

3 a nominal efficiency of 91.7 percent, that 

4 would widen the tolerance range to 90.9 

5 percent to 101 percent. And that is a 

6 substantial change, as Roger pointed out. 

7 MS. ARMSTRONG: Okay. Thank you. 

8 So, we have another question from 

9 the phone from Kunal Kapoor. Oh, maybe it was 

10 just a question. 

11 Five percent, is that plus or 

12 minus 5? And the answer is yes, the way it is 

13 written right now. 

14 Okay. Any other comments on 

15 tolerances specifically? 

16 (No response.) 

17 Okay. Now we are going to talk 

18 about selecting units for substantiation. 

19 Test a minimum of five basic models, including 

20 at least one from each product class. So, if 

21 you have less than five product classes, you 

22 still have to test five. If you have more 
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1 than five product classes for which you want 

2 to apply an AEDM, you must test more than 

3 five. 

4 Distribution transformers is 

5 different, and it is retained at the same 

6 requirement it is today. Test the smallest 

7 and largest capacity basic models from the 

8 product class of the highest field volume. 

9 That largest capacity is within the 25 percent 

10 of the largest capacity. Test the model with 

11 the highest sales volume the previous year or 

12 the basic model which is expected to have the 

13 highest volume sales. 

14 And then, obviously, the test data 

15 -- this is something new -- the test data 

16 underlying the substantiation must be current. 

17 So, it must meet the existing federal energy 

18 conservation standards and be tested with the 

19 applicable test procedure. So, if there is a 

20 test procedure change or if there is a 

21 standard change and those models weren't 

22 tested in accordance with whatever the new 
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1 regulations are, they would need to be 

2 retested. 

3 So, at this point, I will open the 

4 floor to questions and comments on those. 

5 Sure, Frank. 

6 MR. STANONIK: I am Frank Stanonik 

7 with AHRI. 

8 I certainly appreciate the idea to 

9 try to keep this simple. But if someone -- 

10 and you can't rule it out -- but if someone 

11 chose to have an AEDM that only applied to 

12 five basic models, this would say, yes, that 

13 company has to test each one of those five 

14 basic models. And yet, if I had an AEDM that 

15 applied to 50 basic models, I still only have 

16 to test five. 

17 Without having a specific proposal 

18 at this time, it seems like it might make some 

19 sense to say that if you -- again, this might 

20 be a rare circumstance -- but if you had an 

21 AEDM that was only applicable to five or six 

22 models, then you should maybe only test three 
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1 of them, or something like that. In other 

2 words, maybe a little subcategory that, if 

3 there is that rare case where an AEDM is 

4 actually not very expansive, let's say, then 

5 you don't necessarily have to test all the 

6 models, because at that point you are kind of 

7 undermining why have an AEDM. If I have to 

8 test all my models, I will just test all my 

9 models. It is a fine point, but I think it is 

10 something that makes some sense. 

11 MS. ARMSTRONG: Okay. Thank you. 

12 Sure. 

13 MR. LORD: In the selection of the 

14 models, you said meet the requirements. Is it 

15 okay for units to exceed the requirements? 

16 MS. ARMSTRONG: Of course. 

17 MR. LORD: So, like we use Energy 

18 Star so we can cover -- 

19 MS. ARMSTRONG: Of course. 

20 MR. LORD: Okay. Good. 

21 MR. DAUGHERTY: Roger Daugherty, 

22 Baldor Electric. 
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1 A couple of items. With respect 

2 to testing 25 units for distribution 

3 transformers, I think you will find that that 

4 is also true for electric motors and small 

5 electric motors. The actual rules for 

6 distribution transformers were actually 

7 created from the establishment of those for 

8 electric motors. 

9 The last item about, if standards, 

10 test standards, or so, were to change -- for 

11 example, the IEEE 112 Working Group is 

12 presently meeting to modify that test 

13 standard. In the present final rule, the 

14 recent final rule on test standards, DOE 

15 adopted the 2004 version; whereas, presently, 

16 we were testing under the much earlier version 

17 that existed. 

18 Most of those changes are 

19 numerical calculations. There are no changes 

20 in the actual test procedure itself. They are 

21 just trying to fine-tune how you determine 

22 some of the individual losses in the 
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1 calculation. 

2 So, at what extent does a change 

3 in a test standard require going back and 

4 repeating all the testing to substantiate an 

5 AEDM? 

6 MS. ARMSTRONG: So, I mean, I 

7 think your point is a good one. At this 

8 point, it does not clarify which way it goes. 

9 I mean, for all intents and purposes, if the 

10 exact test is the same, the calculations are 

11 different such that the numbers would be 

12 different, it could be one plausible situation 

13 or outcome could be one where you don't 

14 necessarily retest because the test data is 

15 the same. You rerun all the calculations, 

16 though, feed that into your AEDM to make sure 

17 the substantiation requirements are still met, 

18 and then go from there. But that is not 

19 something right now that is specific in the 

20 rule. 

21 MR. DAUGHERTY: Would that be made 

22 specific in a final rule? 
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1 MS. ARMSTRONG: It could be, yes. 

2 It could be. 

3 MR. DAUGHERTY: Thank you. 

4 MS. ARMSTRONG: Sure. Thank you. 

5 Sure. Jill? 

6 MS. HOOTMAN: Jill Hootman, Trane. 

7 Okay. So, we said before the 

8 product classes for commercial HVAC, air9 cooled, were those ASHRAE classes. If I am 

10 reading it correctly, I have to do the 

11 smallest and largest basic models from that 

12 product class. That is 15 tests, if I add 

13 that up. 

14 MS. ARMSTRONG: Fifteen. So, I 

15 don't have the numbers, but you have to do it 

16 from just the product class with the highest 

17 sales volume. So, highest and lowest is just 

18 one -- 

19 MS. HOOTMAN: So, it is the five 

20 plus the two? 

21 MS. ARMSTRONG: Plus one, right? 

22 So, one of those will be the five, and the 
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1 other one. So, that is six. But, obviously, 

2 there is more product classes than five. 

3 MS. HOOTMAN: Right. 

4 MS. ARMSTRONG: So, there will be 

5 more, but I can't imagine it is more than 20 

6 or 30, off the top of my head. I could count 

7 them, though, at break, if you wanted to go 

8 through that. 

9 MS. HOOTMAN: Right. Okay. Let's 

10 do that. 

11 MS. ARMSTRONG: Okay. Sure. 

12 Please. 

13 MR. KLEISS: Okay. This goes back 

14 to, I guess, the product classes and how those 

15 apply to these. If I am understanding 

16 correctly, validating an AEDM, that we have to 

17 validate an AEDM for each different product 

18 class that we are involved in. Is that 

19 correct? 

20 MS. ARMSTRONG: That is correct. 

21 MR. KLEISS: Okay. So -- 

22 MS. ARMSTRONG: But you don't have 
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1 to -- okay, keep going, first of all. 

2 MR. KLEISS: Okay. In the case 

3 of, say, commercial boilers, commercial 

4 boilers are classified by The Federal Register 

5 in large and small. 

6 MS. ARMSTRONG: Correct. 

7 MR. KLEISS: Now we could have one 

8 product family, I will say, that uses the same 

9 kind of construction that bridges the gap 

10 between small and commercial. And the small 

11 boilers, they would be measuring thermal 

12 efficiency and large boilers they would 

13 measure combustion efficiency. So, a 

14 different test methodology there. 

15 Now setting up those boilers could 

16 take a couple of days to a couple of weeks in 

17 order for us to be able to do those tests. It 

18 is to our advantage, when we are setting up 

19 those small commercial boilers, that we would 

20 test both commercial and thermal efficiency. 

21 And when we set up a large boiler, we would 

22 test both thermal and commercial efficiency. 
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1 Now, since the efficiencies are 

2 not covered by the ruling, can we use those 

3 efficiencies measured outside of the product 

4 class to still determine our AEDM for the 

5 product? By definition, we can't use data 

6 that falls outside of the product class -- 

7 MS. ARMSTRONG: Oh, no, no, no. 

8 MR. KLEISS: -- based on what you 

9 said earlier. 

10 MS. ARMSTRONG: Okay. 

11 MR. KLEISS: You are getting where 

12 I am going with the question? 

13 MS. ARMSTRONG: I understand your 

14 question -- 

15 MR. KLEISS: Okay. 

16 MS. ARMSTRONG: -- if that is what 

17 you are asking. I think I do at least. Let's 

18 try the answer and see if it works. 

19 MR. KLEISS: Okay. 

20 MS. ARMSTRONG: So, this is Ashley 

21 from DOE. 

22 At your discretion, you can use 
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1 any additional information you may want to 

2 substantiate your AEDM. If that is different 

3 metrics, if that is other units, like if you 

4 wanted to test 50 instead of 20, you could 

5 always do more. However, you can't switch out 

6 a non-regulating metric for a regulating 

7 metric. But if you did combustion, in your 

8 example, if you did combustion and thermal, 

9 and for the one -- I don't know off the top of 

10 my head, but if it is small, it is combustion, 

11 then you would use combustion. You could also 

12 use thermal if you wanted to tweak something 

13 there. 

14 And then, for the larger ones, if 

15 you wanted to use thermal but you also used 

16 the combustion data point to shrink your 

17 simulation for whatever, you could do that, 

18 but you couldn't swap it as one of the ones. 

19 Does that make sense? 

20 MR. KLEISS: Right, right. We 

21 wouldn't use a different test methodology -- 

22 MS. ARMSTRONG: Correct. 
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1 MR. KLEISS: -- in order to 

2 generate a data point, but we would want to 

3 use a boiler that is outside of the range of 

4 coverage in order to generate a data point to 

5 validate that AEDM? 

6 MS. ARMSTRONG: I think the answer 

7 is yes. Perhaps we can look at what exactly 

8 you are talking about. You know, there is no 

9 problem with doing more, let's put it that 

10 way. 

11 MR. KLEISS: Okay. 

12 MS. ARMSTRONG: It is just this is 

13 the minimum set of requirements. As Frank 

14 alluded to, we tried to keep them simple, 

15 maybe too simple; I don't know. But we tried 

16 to keep them simple. 

17 MR. KLEISS: Yes, and this is not 

18 a matter of trying, just saying we want to do 

19 extra testing -- 

20 MS. ARMSTRONG: But -- 

21 MR. KLEISS: -- but, rather -- 

22 MS. ARMSTRONG: Understanding. 
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1 MR. KLEISS: -- we are bridging 

2 some gaps, and we are wanting to make sure 

3 that we can do the appropriate testing, but 

4 without setting up more units than what we 

5 have to. 

6 MS. ARMSTRONG: Sure. Sure. 

7 Okay. Mark? 

8 MR. FLY: Mark Fly with AAON. 

9 On several of the HVAC products, 

10 DOE has listed, basically grouped everything 

11 up to 63 tons on products that traditionally 

12 have not been under any kind of listing 

13 program at near that high a rate. So, like 

14 for water-source heat pumps, air-source heat 

15 pumps, and some of these products, there are 

16 not labs in existence that can test a 63-ton 

17 air-source heat pump, independent or most 

18 manufacturers. There may be some 

19 manufacturers, but they don't really want to 

20 test my equipment, and I don't really want 

21 them to. 

22 I think, on the upside, that is a 
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1 problem, that we do have a discontinuity 

2 between the traditional AHRI rating standards 

3 and the limits and what DOE has listed. 

4 MS. ARMSTRONG: Okay. I am not 

5 100 percent sure I understand you. So, 

6 perhaps you and I can look at this table at 

7 the break, so I do understand it, because I 

8 think it is important. 

9 Sure. Jill? 

10 MS. HOOTMAN: What was the 

11 methodology in picking the smallest and 

12 largest of the basic model from a product 

13 class? I guess I am asking that methodology 

14 because usually in a lot of cases when you are 

15 substantiating AEDMs and outliers that might 

16 be causing conditions different, it is not 

17 always the smallest and largest. It could very 

18 well be a design issue within a product class 

19 that you are then looking at. For instance, 

20 it could be something like the cabinet size 

21 and how much is being fit in that particular 

22 cabinet size. And that might not fall in that 
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1 smallest and largest. So, if you are trying 

2 to find what is defining the outliers of an 

3 AEDM, smallest and largest isn't always it. 

4 MS. ARMSTRONG: Right. This is 

5 Ashley. 

6 I think we were trying to, for the 

7 most part, bound the range. So, at this 

8 point, if we open up the AEDM applicability 

9 across the board -- you can use one AEDM for 

10 everything, whether it is a 6-ton or a 69-ton 

11 unit, I mean whatever it is. The idea here 

12 would be getting a test point somewhere toward 

13 the lower end of the range and somewhere 

14 toward the higher end of the range to make 

15 sure. And that is just one test. 

16 If there is a different way to do 

17 it or maybe a better way to do it, we are open 

18 to it, but that is the idea. And this doesn't 

19 show it on the -- it is 25 percent of the 

20 largest basic model or the largest capacity, 

21 because we do realize that the largest 

22 capacity could be quite challenging, may not 
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1 even be built on a regular basis. 

2 So, like I said, though, we are 

3 open here. We were just trying to get some 

4 sense of bounding, a range there, because of 

5 opening up the scope to the wide range of 

6 applicability there. 

7 MR. NESHAN: Massoud Neshan, 

8 Southern Store Fixtures. 

9 The use of AEDM, at least for CRE, 

10 was discussed about last year when we started 

11 talking about how to reduce the burden of 

12 testing on the basic model definition that 

13 exists. My question is now for us, as a small 

14 manufacturer, how this AEDM is going to help 

15 us when I am designing one case, manufacturing 

16 one case, selling one case. How is all this 

17 process going to reduce that burden of 

18 testing, question No. 1? 

19 Specifically, you haven't even 

20 defined the basic model yet again. I keep on 

21 coming back to this because the foundation of 

22 this thing is not settled yet and you are 
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1 talking about what we should be doing on the 

2 10th floor. 

3 So, what is AEDM? How is it going 

4 to reduce the burden of testing on our kind of 

5 equipment? 

6 MS. ARMSTRONG: Okay. So, I don't 

7 know off the top of my head all the product 

8 lines and offerings. So, I am going to give 

9 an example that is just theoretical here in 

10 nature. 

11 But say, as a commercial 

12 refrigeration equipment manufacturer you 

13 manufacture 100 different models, just 100 

14 different models. Those span 20 different 

15 equipment classes as defined by the standards. 

16 So, they are either like semi-vertical, 

17 vertical; they are opened or closed. They are 

18 self-contained or remote. There's 20 there, 

19 right? 

20 So, of those 100, you need to test 

21 20. Those 20 need to meet these 

22 characteristics. Actually, it would be 21. 
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1 The 21 need to meet these characteristics, and 

2 the 79 others you could use the AEDM and not 

3 test those. That is my example of how it 

4 would work for your company. 

5 I don't know if that example is a 

6 good representation of your company, but that 

7 is how it would work in theory. Okay? 

8 MR. FLY: Mark Fly with AAON. 

9 So, I am just trying to get my 

10 head around this. Do you have to test the 

11 largest and smallest in each class? Or you 

12 just have to test one in each class and the 

13 smallest and largest across a product line? 

14 MS. ARMSTRONG: You have to test 

15 one in each class and the highest and lowest 

16 in the class with the highest sales volume. 

17 MR. FLY: Okay. 

18 MS. ARMSTRONG: I realize that 

19 there is some confusion generally because 

20 there are multiple classes that can span the 

21 range, right? So, I get that part. That will 

22 be something we need to clarify. 
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1 MR. ROBERTS: This is Carl from 

2 Zero Zone. 

3 Just a quick comment on the last 

4 item on slide 20 here, "The test data used for 

5 substantiation must meet the applicable DOE 

6 test procedure." We are constantly rewriting 

7 the procedure. It is a moving target because 

8 the equipment itself is a moving target. 

9 It might make more sense to say 

10 that the test data used for substantiation 

11 must meet the applicable DOE testing procedure 

12 or properly adjust to the applicable DOE 

13 testing procedure. In other words, to adjust 

14 the test data within the AEDM to represent the 

15 current test procedure. 

16 MS. ARMSTRONG: This is the first 

17 time I have ever heard that our regulatory 

18 program is a fast-moving target. 

19 (Laughter.) 

20 But I thank you for that, that 

21 compliment. 

22 I do want to point out that, when 
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1 we talk about it here, I realize that a lot of 

2 your test procedures, due to either the great 

3 work done by AHRI committees or ASHRAE 

4 committees or IEC committees, whatever it may 

5 be, it is constantly under revision or they 

6 are thinking about changing things. 

7 What we are talking about here is 

8 the actual version in the DOE regs, which in 

9 some cases is a moving target, but is a much 

10 slower moving target than the ASHRAE 

11 standards. You know, it is when DOE actually 

12 issues a new final rule, we adopt it with a 

13 compliance date of a new test procedure. That 

14 is when whatever is in our regulations, if it 

15 is different, if it causes changes in ratings, 

16 if it is a different test procedure, those 

17 base models would need to be retested. 

18 So, that is what I meant there. 

19 That doesn't mean we shouldn't consider other 

20 things, and we are open to them. As you can 

21 see, we are open to a lot of changes here, but 

22 that is what the intention was there. 
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1 Hang on one second. Let me get to 

2 a couple of people on the phone because they 

3 have been patiently waiting for a while. 

4 So, Tom Petrosino, I apologize if 

5 I am saying anyone's name wrong. 

6 You should be on. 

7 MR. PETROSINO: Yes. 

8 MS. ARMSTRONG: Hi. 

9 MR. PETROSINO: Hello. 

10 My question relates to the 

11 highest-volume requirement for AEDM basic 

12 model testing. If we did a test in 2009 using 

13 the highest-volume basic model that year or 

14 expected for that year, and this year it is no 

15 longer the highest-volume basic model, but 

16 still a valid basic model, do we have to 

17 retest to replace that unit with today's 

18 highest volume? 

19 MS. ARMSTRONG: So, I would say 

20 that we didn't specifically articulate one way 

21 or the other. So, do you have a suggestion, 

22 or does anyone else in the room have a 
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1 suggestion, as to whether it should be at the 

2 time of substantiation, whatever the highest 

3 sales volume is, or if that highest sales 

4 volume changes over time, whether that should 

5 also be lumped into the substantiation 

6 package? 

7 MR. PETROSINO: My suggestion is 

8 that you not get into that kind of requirement 

9 because it is a constantly-changing picture. 

10 Would you have to monitor this daily, monthly, 

11 yearly? I think as long as you did the AEDM 

12 at a time and followed and it was applicable, 

13 and you didn't subsequently discontinue that 

14 model, and you have no other reason to repeat 

15 an AEDM, then I think it should stay. 

16 MS. BARHYDT: This is Laura 

17 Barhydt with DOE. 

18 In terms of the highest sales 

19 volume, since it is tied to the product class 

20 and not to a particular basic model, would 

21 that reduce the need to test something new? 

22 Does the highest sales volume product class 
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1 actually change that frequently? 

2 MR. PETROSINO: The highest -- I 

3 am not sure I understand that question. Are 

4 you saying that, for a given product class, 

5 you want the highest-volume product class unit 

6 tested? I'm unclear. 

7 MS. BARHYDT: Okay. So, this is 

8 different from the current CAC ARM provisions. 

9 What this is proposing is that, if you have 

10 models in multiple product classes, you look 

11 at where your highest sales volume is. Is it 

12 in the first product class, the second product 

13 class, the third product class? Whichever one 

14 has the highest sales volume, you select the 

15 smallest and largest capacity basic models 

16 from that product class. 

17 And so, if your highest sales 

18 volume remains in that product class, then 

19 that is not something that is changing from 

20 year to year, would be my guess. But 

21 certainly that is something we would like more 

22 information on. 
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1 MR. PETROSINO: Actually, this is 

2 related to distribution transformers. So, 

3 that particular requirement would not apply. 

4 MS. BARHYDT: Okay. 

5 MS. ARMSTRONG: That's correct. 

6 MR. WILKINS: Question. Robert 

7 Wilkins, Danfoss. 

8 Could you apply some tolerance 

9 there on these kinds of things, maybe a little 

10 clause that says highest volume within the 

11 past three years or "X" years? So that you 

12 are not constantly having to shift from one, 

13 and, oh, my God, that shifted back to the 

14 other, and now I've got to redo it again. 

15 MS. ARMSTRONG: Sure. Or, I mean, 

16 one of the reasons we migrated, I think, to 

17 the highest sales volume product class, 

18 because we didn't think it was as much of a 

19 moving target as highest sales volume model. 

20 But that being said, sure, there is always 

21 ways for improvement. 

22 MR. KLEISS: There is a potential 
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1 pit there in terms of the boilers. I would 

2 say that the highest sales volume boilers -- 

3 well, no, I'm sorry. I'm thinking of 

4 residential. This only applies to commercial. 

5 (Laughter.) 

6 MS. ARMSTRONG: We're okay? Okay. 

7 Thank you. 

8 Frank? And then, we will go 

9 across. Or either one. 

10 MR. LORD: I think you are right. 

11 Take, for example, we do an AEDM on packaged 

12 rooftops. It goes 65 to 760,000, less than 

13 65, or say it goes 65 to 760,000; 65 to 135 is 

14 always going to be the highest sales line. It 

15 is never going to change, not in that 

16 category, yes. 

17 MS. ARMSTRONG: Okay. Thank you. 

18 Frank? 

19 MR. STANONIK: Yes, I would 

20 suggest that we should look at this as kind of 

21 analogous to certification versus 

22 verification, certification of a model versus 
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1 verification of your production. 

2 The AEDM has to be substantiated 

3 as a valid tool. Okay? Whenever you do that, 

4 it only makes sense that you want to have that 

5 justification based on, let's just call it 

6 your most popular models. You want to have 

7 the closest correlation to the things you sell 

8 the most of. Okay? 

9 But once you have got that 

10 substantiation, once you have determined, 

11 okay, I have a good tool and it meets the 

12 requirements of, let's say, acceptable 

13 predictability, or whatever, it is a valid 

14 tool until something changes relative to 

15 either test procedures or the minimums, or 

16 whatever, or you totally redo your product 

17 line or something. 

18 But I don't think there is 

19 inherently a requirement here for, let's say, 

20 continued substantiation. Verification of 

21 your AEDM will occur as you go forward and 

22 models are tested under whatever program, you 
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1 know, randomly-selected models, or whatever. 

2 And that will either show that your AEDM was 

3 proper or not. 

4 But substantiation, I think we 

5 should consider as a one-time thing until 

6 circumstances change. As a one-time thing, it 

7 should be based on, again, those things that 

8 you sell most of. 

9 MR. FLY: Mark Fly with AAON. 

10 I think one of the concerns here, 

11 especially in the substantiation, is not that 

12 we think that we are going to have a big 

13 tolerance on our AEDM, because if you put the 

14 same numbers in, you get the same numbers out 

15 every time. 

16 But the test data, if we have a 

17 large tolerance like we talked about 

18 previously in the test data that falls 

19 outside, say, that 5 percent range, that is 

20 going to make it very hard to validate that 

21 AEDM or get that AEDM to tune within the 

22 average of these five or ten or twenty tests 
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1 that we have got. 

2 So, the tolerance on the AEDM is 

3 really driven by the tolerance on the test 

4 more than anything else, assuming that we can 

5 all model our equipment and get it close to 

6 the reality, once we have the test data to do 

7 it with. 

8 MS. ARMSTRONG: Right, and the 

9 tolerance on the test I think is already 

10 established in our regs, right? I mean, that 

11 is the 95 percent confidence limit thing, and 

12 that is established. 

13 MR. FLY: But what's behind that, 

14 and is that really the right number? 

15 MS. ARMSTRONG: I understand. I 

16 mean, I get that part, but that is 

17 established. 

18 So, let me jump to one on the 

19 phone. Can you unmute Ron? 

20 So, Ron, you should be unmuted 

21 now. 

22 MR. SHEBIK: Hi, Ashley. I am 
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1 sorry, I wanted to go back to your scenario. 

2 You ran with 100 different models and how that 

3 compares to what is outlined on page 20. 

4 I may have misunderstood or may 

5 have missed something, but you said there was 

6 100 different models. And of those 100 

7 different models, they are represented by 20 

8 different equipment classifications. 

9 Based on that, you came up with 

10 you test 21 cases. But when you look at page 

11 20, it says you are testing a minimum of five 

12 basic models, including at least one from each 

13 product class. So, I just want to make sure I 

14 understand. How are you equating the 20 

15 different equipment classifications to your 

16 basic models? Are you saying there's four 

17 product classes? 

18 MS. ARMSTRONG: No. 

19 MR. SHEBIK: Or are you saying the 

20 classification is equal to a basic model? 

21 MS. ARMSTRONG: Yes. So, what I 

22 said was the 100 models span 20 equipment 
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1 classes. The first requirement on there means 

2 you need to test at least one from each 

3 equipment class, which would get you 20 that 

4 you would have to test, because there's 20 

5 different equipment classes for those 100 

6 models. 

7 And then, No. 3, test the smallest 

8 and the 25 percent of the largest capacity, 

9 which would get you two units from one 

10 equipment class. So, that would add one more. 

11 So, you would test 21 of those 100, and then 

12 you could rate with 79, with the rest. 

13 MR. SHEBIK: Okay. So, the 

14 equipment classification is equivalent to a 

15 product classification? 

16 MS. ARMSTRONG: Product class, 

17 correct. Equipment class and product class 

18 are synonymous. One is commercial; one is 

19 residential. Sorry. Yes. 

20 MR. SHEBIK: Okay. That is my 

21 confusion. Okay. Thank you. 

22 MS. ARMSTRONG: Thank you. 
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1 MR. DAUGHERTY: Roger Daugherty, 

2 Baldor Electric. 

3 I don't know if it might help if 

4 you sort of consider what has been going on 

5 with electric motors. Since 1999, we have 

6 been using this concept of the AEDM. It has 

7 the rule of trying to select at least one of 

8 the basic models from the highest volume of 

9 motor. 

10 When you realize that once you 

11 have substantiated the AEDM, the manufacturer 

12 is using that AEDM not only to design motors 

13 that are in compliance with the efficiency 

14 standard level, but also with those motors 

15 that have to comply by being higher than that 

16 level. 

17 So, when the next final rule came 

18 out more recently that raised those levels for 

19 electric motors, that same AEDM is applicable. 

20 There has been no change in the technology. 

21 There is no change in how you calculate the 

22 losses. The only change is in how much 
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1 material you put in to meet the new efficiency 

2 standards. 

3 But that motor that you may be 

4 designing is the same one that you designed in 

5 1999 for that same efficiency level. So, the 

6 fact that the standards changed really had no 

7 effect on the AEDM or its model. And so, 

8 consideration should really be given that, 

9 unless there is a real change in technology or 

10 the test standard, and not necessarily the 

11 efficiency standards, that you should not have 

12 to resubstantiate the AEDM just for changes in 

13 the standards. 

14 But, again, I encourage you. This 

15 has been in place. It has been working very 

16 well since 1999. Look at the way that has 

17 been working. That might help you towards 

18 some of these other products. 

19 MS. BARHYDT: This is Laura 

20 Barhydt at DOE. 

21 One point I want to clarify is 

22 that let's say you had tested five models that 
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1 were all below the change in standards. Then, 

2 when the standard changed, you would end up 

3 with an AEDM that had no test data that 

4 actually showed a motor that met the new 

5 standard. If you had three motors that were 

6 below the new standard and two that were above 

7 the new standard, but that had been tested 

8 back before the new standards came into 

9 effect, you would effectively have two tests 

10 that could continue to be used to substantiate 

11 the AEDM. You would just have to test three 

12 new motors to replace those three that didn't 

13 meet the standard. 

14 So, this proposal -- and this 

15 would apply to all the different product types 

16 -- the idea is that, if you have some of your 

17 tests underlying your AEDM that were well 

18 above the standard, and the standard changes, 

19 those wouldn't necessarily be kicked out. You 

20 could continue to use those. It is just that 

21 anything that didn't meet the standard could 

22 not continue to be used to substantiate that 
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1 AEDM. 

2 Does that make sense? 

3 MR. DAUGHERTY: But Roger 

4 Daugherty, if I could follow up on that, 

5 though. But when you substantiate the AEDM, 

6 you substantiated it, and, technically, 

7 usually, there are some motors that are tested 

8 that use a higher efficiency because at that 

9 time those might have been the ones that had 

10 the highest volume of sale. 

11 But the AEDM is a set of 

12 calculations and simulations that determine 

13 how losses are calculated. As I said, that 

14 technology doesn't change just because you 

15 change the efficiency level. It only changes 

16 the components that you put in and the size of 

17 those components. 

18 So, if that AEDM was substantiated 

19 by testing to those motors that had efficiency 

20 standards of 1992 that were in EPAct, and it 

21 worked for the motors that have premium 

22 efficiency levels, which are those that were 
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1 put in EISA in 2007, and it has been working 

2 since 1999, then why does it not continue to 

3 work just because you change the standards? 

4 There has been no change in technology, no 

5 change in the test standard, no change in 

6 anything. 

7 So, if the manufacturer has been 

8 in total compliance with those premium 

9 efficiency motors using that AEDM, why would 

10 there be an issue now that, just because you 

11 change the standards and eliminated the 

12 production or distribution of motors of the 

13 lower efficiency levels below the premium 

14 levels, that that raises any issue at all with 

15 respect to the AEDM? 

16 MS. ARMSTRONG: Okay. Harvey. 

17 MR. SACHS: Harvey Sachs, ACEEE. 

18 I have found this dialog just now 

19 between Laura and Roger to be very 

20 instructive. I would like to try to translate 

21 into terms that some of the rest of us may 

22 think about. 
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1 In particular, what I am hearing 

2 from Roger, as I am looking at polyphase 

3 induction motors as one large class, and I am 

4 saying that my simulation model for those will 

5 extrapolate well, that is, behave well, beyond 

6 the calibration dataset, which may not have 

7 included motors of as high efficiency as we 

8 are now selling. 

9 And I am hearing DOE implicitly 

10 not ready to accept, and perhaps not 

11 understanding, as I don't, the limits of what 

12 that smooth extrapolation might look like. 

13 For example, again, in the motors class, it is 

14 not clear to me that this simulation for 

15 polyphase induction motors would work well on 

16 some other class of motors, that it would be 

17 applicable, just as I earlier asked whether an 

18 AEDM applicable to an electric resistance tank 

19 water heater would necessarily be applicable 

20 to a condensing-gas tankless. 

21 So, I think that is where our 

22 misunderstanding is at this point. I hope 
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1 that is a helpful observation. 

2 MR. VerSHAW: Jim VerShaw, 

3 Ingersoll Rand. 

4 You know, when you think about -- 

5 and I will bring it back to air conditioning, 

6 what I know best. So, you have got the 

7 compressor and a couple of coils and some 

8 airflow, and whether it makes 13 SEER or 22 

9 SEER, it is the same basic engine. So, if the 

10 standard currently is a 13, if it goes to 14, 

11 and because we had to do a lot of 13s because 

12 they are the highest sales volume, we were 

13 using that rating to do, that AEDM or ARM to 

14 do all those other ones. And it fundamentally 

15 doesn't change the physics. Now, if I put in 

16 a microchannel heat exchanger or if I put in 

17 some other new technology, that is another 

18 whole thing. 

19 But the point, I think, at least 

20 from our aspect, if you are not changing 

21 technology, I am not sure why a change in 

22 standards or a model that drops out of 
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1 production is going to disqualify the AEDM. 

2 MS. ARMSTRONG: But, Harvey, can I 

3 actually chime in on that one real quick? 

4 That's fine. You can go next. 

5 I guess from the Department's 

6 perspective, we based it off standards, 

7 understanding that technology changes may be 

8 needed to meet those standards. We don't 

9 actually know when a technology change will 

10 occur. We know when the efficiency level is 

11 going to change. 

12 We don't necessarily know when the 

13 technology is going to change. And that 

14 technology change may be different timing-wise 

15 for different manufacturers. So, we don't 

16 know, like in your example, when a 

17 manufacturer is going to employ, say, 

18 microchannels to meet a given standard level 

19 or make that migration or a different type of 

20 motors. 

21 And so, what we were trying to do 

22 here is just make sure that the AEDM is 
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1 current, that we don't have a situation for 

2 which the AEDM was substantiated in 1950 and 

3 hasn't been touched since. 

4 And maybe that is okay that it 

5 hasn't been touched since or maybe it isn't. 

6 But that is for comment. 

7 Harvey, do you want to go back 

8 since I kind of cut you off? 

9 MR. VerSHAW: Well, first, 1950 

10 wasn't that long ago. 

11 (Laughter.) 

12 It depends on your perspective. 

13 MR. WILKINS: Robert Wilkins, 

14 Danfoss. 

15 I think I understand your concern 

16 about extrapolation of performance outside of 

17 a certain range. I think the people have 

18 commented that maybe there is really not much 

19 difference between a 13 SEER unit and a 14 

20 SEER unit. And so, why prohibit 

21 extrapolation? 

22 But if you are going from 13 SEER 
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1 to 18 SEER, then you are deploying other 

2 technologies. You may have microchannel heat 

3 exchangers. You may have variable-speed 

4 compressors. 

5 But maybe the answer is not to 

6 prohibit extrapolation, but put some bounds on 

7 it. So that maybe a bound of "X" percent 

8 improvement in efficiency would force the 

9 elimination of the extrapolation or a change 

10 in basic technology in the unit. Just add a 

11 little flexibility to it maybe is the point. 

12 MS. ARMSTRONG: Sure. Go ahead. 

13 MR. LORD: Yes, Dick Lord with 

14 Carrier. 

15 What may be confusing a lot of 

16 people is that there are a lot of ways to 

17 approach an AEDM. Some of us think it is a 

18 full physics-based model with all the heat 

19 transfer coefficients. Somebody might take a 

20 simplistic approach and just say, "I've got a 

21 bunch of ratings. I am going to put factors 

22 up and down as I add features." And then, I 
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1 could see you would want to substantiate it 

2 because your base has changed. 

3 So, a lot of depends on how you do 

4 your AEDM. You guys are not going to know 

5 that. So, you kind of in a way have to do 

6 what you are doing really. 

7 MS. ARMSTRONG: Okay. Thank you. 

8 Go ahead. And then, I am going to 

9 go to the phone. 

10 MR. DAUGHERTY: Roger Daugherty, 

11 Baldor Electric. 

12 I would just like to answer that 

13 the idea of extrapolation doesn't apply to the 

14 electric motors and small electric motors, at 

15 least as far as I know the AEDMs are. If you 

16 want more efficiency and you put in more 

17 material, if you put in six inches of core 

18 instead of five, you determine the losses in 

19 that six inches of core instead of the five. 

20 You account for the change in 

21 copper wire that you had to put in. You 

22 account for the changes in the aluminum that 
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1 you had to put in the rotor. You are 

2 calculating five different losses in that 

3 machine and adding them up, and they are all 

4 very well-defined calculations and physics 

5 involved. There is no extrapolation that goes 

6 on. 

7 Maybe part of the problem here is 

8 that we have not gotten to it yet, but the 

9 other part in Part 431 for electric motors and 

10 small electric motors is the revalidation that 

11 is done. And maybe that is where, by 

12 continuing to validate the AEDM over time, 

13 rather than go back and say, because the 

14 standard changed, now you suddenly have to go 

15 back and retest a certain number of models, 

16 and right now it is annual for electric 

17 motors. But this continual revalidation of 

18 the AEDM would take care of the issue of the 

19 AEDM being up-to-date when there are changes 

20 in standards, efficiency standards, and 

21 changes in test standards. 

22 Thank you. 
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1 MS. ARMSTRONG: Okay. So, before 

2 I follow up on that idea, I am going to go to 

3 the phone for two things. 

4 One, Kunal Kapoor. 

5 Can you please unmute that line? 

6 Okay. You should be good. 

7 MR. KAPOOR: Yes. Hi. Ron Shebik 

8 already asked the same question I wanted to 

9 ask. So, no more questions at this time. 

10 MS. ARMSTRONG: Oh, okay. Thank 

11 you. 

12 Aaron Meyers? 

13 MR. MEYERS: Thanks for taking my 

14 question. 

15 My question is really related to 

16 timing as it relates to the highest-volume 

17 production basic model, or whatever, being 

18 tested, coupled with a change in the 

19 efficiency standard. 

20 So, just to give you an example on 

21 this from the distribution transformer world, 

22 under normal operating conditions, the highest 
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1 basic model for our company -- it may or may 

2 not be this, but it is a very popular one -- 

3 would be 25 kVA, single-phase, with a primary 

4 voltage of 7200 volts, secondary of 122/40, 95 

5 kV BIL. And the efficiency level would be the 

6 absolute minimum required by the DOE, so 

7 98.91. 

8 Now, if the efficiency level 

9 changes in 2016 -- say it goes up to 99 -- our 

10 most popular basic model from the last 12 

11 months will be a non-compliant basic model. 

12 So, my question is, do we substantiate with 

13 the highest-volume basic model from the 

14 previous year, which would be non-compliant? 

15 I don't think that is an option, from what I 

16 am hearing. 

17 Or the second option would be, do 

18 we take that basic configuration, so 25 kVA, 

19 7200 volts, 122/40, 95 kVA or kV BIL, and say, 

20 okay, do I test that configuration with the 

21 new efficiency level? Because when we migrate 

22 to 2016, that will most likely be the highest 
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1 volume. Or do I look at what the highest 

2 volume was of a product that met the new 

3 standard, but in late 2015, so that I can 

4 continue using an AEDM once the new standard 

5 goes into effect? 

6 And that could be just based on 

7 random luck, some customer who is buying a 

8 higher-efficiency unit than what is required 

9 by the standard 2015. And then, it would drop 

10 off the face of the earth in terms of 

11 production volume once the new standard goes 

12 into effect. So, there is really a lot of 

13 uncertainty there. 

14 MS. ARMSTRONG: Okay. Thanks, 

15 Aaron. 

16 MR. MEYERS: I know that was a 

17 mouthful. I don't know how you want to answer 

18 it, if you have clarifying questions. 

19 MS. ARMSTRONG: I am going to try 

20 to answer it. We are going to see. 

21 So, that is one of the reasons why 

22 we put "or the basic model which is expected 
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1 to have the highest sales volume for newly2 introduced basic models." And maybe it needs 

3 to be expanded not only for newly, but 

4 continuation of existing. That is something 

5 we could do. But it would be your estimation 

6 of what you think the highest sales volume 

7 would be over the next year from when those 

8 standards come into effect, so that you could 

9 continue with your AEDM. It would not be the 

10 non-compliant model. 

11 MR. DAUGHERTY: Roger Daugherty, 

12 Baldor Electric. 

13 Maybe what is being overlooked is 

14 you have a very important paragraph in a 

15 conclusion of this section that you didn't put 

16 on your slide. And that is down on page 

17 32056, under 429.75, and follow all the stuff, 

18 but it is the bottom of the left column. 

19 "In any instance where it is not 

20 possible for a manufacturer to select basic 

21 models for testing in accordance with all of 

22 these criteria, the criteria shall be given 
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1 priority in the order in which they were 

2 listed. Within the limits imposed by the 

3 criteria, basic models shall be selected 

4 randomly." 

5 So, if you read that, that may 

6 overcome some of the obstacles that are being 

7 imposed here, trying to follow every one of 

8 these items exactly. 

9 MR. KLEISS: Jeff Kleiss with A.O. 

10 Smith and Lochinvar. 

11 When you were going through the 

12 example, you know, your theoretical example 

13 with the coolers, I feel like I don't 

14 understand what I thought I understood about 

15 the process. 

16 So, for our example with the 

17 boilers, dealing with commercial products, 

18 there are two different product classes, if I 

19 understand correctly. There would be the 

20 large and the small. 

21 So, based on that, and say I have 

22 eight different families of models, are we 
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1 required to run only five tests, so that we 

2 would do two to substantiate our AEDM on the 

3 highest-volume product family, and then that 

4 AEDM could be applied to both different 

5 product classes and the eight different model 

6 groups? 

7 MS. ARMSTRONG: Okay. So, not 

8 quite, but almost. 

9 MR. KLEISS: Okay. 

10 MS. ARMSTRONG: So, I am not sure 

11 I agree with the premise that there is only -- 

12 well, currently, there may be only two product 

13 classes for boilers. We should look at the 

14 product classes for commercial boilers. Hot 

15 water/steam, that impacts it as well. So, I 

16 am not sure I agree with you that that is the 

17 premise. 

18 But if I did and it was two, your 

19 example, the number is six; it is not five. 

20 And it is six because the highest sales volume 

21 and the lowest has to be from the same. Well, 

22 I guess it could be five. It could be five. 
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1 I'm sorry. It could be five; you're right. 

2 So, you've got it. But I think your premise 

3 of two is not right. 

4 MR. KLEISS: Okay. 

5 MS. ARMSTRONG: And I can show you 

6 that in the regs. 

7 MR. KLEISS: Okay. 

8 MS. ARMSTRONG: Yes. 

9 MR. KLEISS: But, just to be 

10 clear, we don't even have to provide test data 

11 from every family of models -- 

12 MS. ARMSTRONG: No. Once you have 

13 five, you can go. 

14 MR. KLEISS: Okay. Thank you. 

15 MS. ARMSTRONG: Unless, I mean, 

16 are you proposing something, that the 

17 Department consider something different? 

18 (Laughter.) 

19 MR. KLEISS: No. No, it is just 

20 -- thank you. 

21 MS. ARMSTRONG: So, you support 

22 this as written, kind of? 
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1 MR. KLEISS: Yes, I do. 

2 MS. ARMSTRONG: Okay. Thank you. 

3 Frank? 

4 MR. STANONIK: Well, I don't want 

5 to lose sight of this. But that puts a 

6 significant responsibility on the manufacturer 

7 to have a very robust AEDM. In your example, 

8 that would be able to encompass those eight 

9 model families. Okay? I mean, so it is not a 

10 trivial thing. 

11 MS. ARMSTRONG: I will say, just 

12 as a follow-on, that with the rest of those 

13 model families, it is your responsibility to 

14 make sure those tolerances are kept. If you 

15 happen to do checking or whatever, if anyone 

16 else did checking, the 5 percent would need to 

17 come in. But the substantiation requirements 

18 for that example would be five. 

19 Let's go here, and then we will go 

20 to Karim. 

21 MR. HON: Okay. I have some very 

22 serious negative comments about this project 
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1 so far because a lot of the products that are 

2 on the market today are already regulated and 

3 standardized, and the testing should have 

4 already been completed for hundreds of models, 

5 not just a few. 

6 That means that several of us who 

7 have what we would consider base models in the 

8 hundreds have already expended huge amounts of 

9 capital to develop information bases. And 

10 this is opening a can of worms that will be 

11 unbelievable because the next question I have 

12 for you is, how are we going to have, shall we 

13 say, protest of someone else's product? 

14 Because the minute you start this 

15 modeling that you are doing here, you are 

16 going to open the can of worms that I don't 

17 know that the government can control, that we 

18 can come in and show that our competition is 

19 not within 5 percent or some target number of 

20 theirs. 

21 And then, we are going to have 

22 this context started that no one will ever 
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1 stop on what is accurately rated, because 

2 their models aren't any good. There are some 

3 very unusual models in our industry that are 

4 very difficult to model. If I test one of 

5 those and come up with some idea of how it 

6 fits with all the other models, it may consume 

7 twice as much energy per unit as one, and then 

8 the next one which may be a little different, 

9 even though it fits in the same, quote, 

10 "category," it may have twice as much glass 

11 surface area on it, which means it is far less 

12 efficient. 

13 But in the models, if you are only 

14 testing one unit, how do you know how that is? 

15 Your physics has to have a basis on science 

16 and tests. This is so broad and so 

17 encompassing when you have such vast product 

18 differences. 

19 If you are a motor manufacturer, 

20 the motor manufacturer controls the components 

21 much more tightly than those of us who buy 

22 componentry and assemble the equipment. We do 
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1 not have control of the compressor. We can 

2 specify compressors. We do not necessarily 

3 have control, complete control, of the way the 

4 coils are built. We do not have complete 

5 control of several other components in the 

6 system, some of the controls sometimes. And 

7 any of these variables can suddenly blow up in 

8 our face. That is the nature of it. And so, 

9 we have constant, ongoing testing. 

10 But this system could be relying 

11 on 10-year data, but all these variables may 

12 have changed. Without a consistent program of 

13 verification, without a consistent program set 

14 up so that protests can be built into it, we 

15 are just opening the door to do whatever 

16 anybody wants to do. 

17 MR. AMRANE: I have a different 

18 question, related but different, though. And 

19 I am sorry if this question was addressed 

20 before; I was out of the room for a half an 

21 hour or so. 

22 I think, as I read the NOPR, it 
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1 says that you have to test a minimum of five 

2 models, five different basic models to 

3 substantiate AEDM. But let's say we have a 

4 small manufacturer, and that small 

5 manufacturer has only two basic models. 

6 It was already addressed? I'm 

7 sorry. Oh, we think alike? Okay. 

8 (Laughter.) 

9 So, I don't want to repeat the 

10 question then. 

11 MS. ARMSTRONG: That is good for 

12 interoffice dynamics. 

13 MR. AMRANE: But I think we need 

14 to revisit that because it doesn't make a lot 

15 of sense to ask a manufacturer with two basic 

16 models to test five units of the same two 

17 basic models. 

18 MS. ARMSTRONG: I mean, I guess I 

19 am going to turn the question around. This 

20 does not indicate that the Department is not 

21 open to providing something like that. 

22 But if you only had two basic 
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1 models, is it really worth the resources to 

2 come up with a simulation as compared to just 

3 testing it? I mean, are those provisions 

4 actually necessary? 

5 I guess my preconceived notion 

6 would be it would be just easier to test them. 

7 But if there are just really two, and that is 

8 all you are going to offer -- I mean, this is 

9 really, you know -- 

10 MR. STANONIK: Absolutely. What 

11 resonated with me is more -- well, let's use 

12 as an example Jeff's boilers, okay? Let's say 

13 you have a boiler company that has been making 

14 traditionally atmospherically-vented products. 

15 Okay? 

16 And at some point, they are 

17 developing a line of condensing boilers. 

18 Okay? And so, initially, this first offering 

19 is going to be five basic models with 

20 condensing boilers. 

21 In that kind of a circumstance 

22 where the company is, let's say, evolving its 
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1 product line, that would possibly require a 

2 new AEDM. Okay? And in that kind of 

3 situation, to me, it would make sense to say, 

4 wait a minute, I shouldn't necessarily have to 

5 test all five to create, to substantiate the 

6 AEDM for this, in my case, this new technology 

7 that I am now making part of my product line. 

8 So, that is kind of more the 

9 situation I was thinking about. Again, 

10 granted, it is going to be somewhat unusual 

11 because, obviously, you succeed in business by 

12 offering more models, I think, you know, 

13 having more flexibility for what your 

14 customers want. 

15 But I think it is something we 

16 will try to work up a proposal that will fit. 

17 MS. ARMSTRONG: Yes. I am 

18 actually going to ask some questions in the 

19 room. For those of you that may use 

20 simulations now to rate the equipment, either 

21 for residential settings or for commercial 

22 settings, do you have like one, what I would 
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1 call, AEDM and multiple different modules, 

2 either technology or whatever? Is it really 

3 one AEDM or do you have like a lot of 

4 different ones? And maybe it is variable 

5 depending on industry or by manufacturer 

6 choice. But I kind of want to know what you 

7 do now. 

8 MR. LORD: I think we have tools 

9 -- this is Dick Lord of Carrier -- we have 

10 tools for designing equipment that can predict 

11 performance over a broad range from full load 

12 to part load. 

13 What we are talking about is 

14 probably a different tool that we use for an 

15 AEDM that is tailored to just the specific 

16 ratings that are being certified. So, it is 

17 not going to be one and the same. 

18 We were discussing this the other 

19 day. We may have one AEDM; we may have 

20 multiple AEDMs, depending on how broad we want 

21 to do it and how many units we are going to 

22 test. 
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1 I mean, we like the flexibility of 

2 the way you have outlined it. It gives us the 

3 prerogative on how to do it. 

4 MS. ARMSTRONG: Okay. 

5 MR. VerSHAW: Jim VerShaw, 

6 Ingersoll Rand. 

7 For residential products, we have 

8 a design tool that predicts performance, and 

9 it is a 2x2 heavy-duty calculation method that 

10 we have adapted with other -- I didn't write 

11 it; you know, I am still in Fortran. So, it 

12 has got other subroutines on there that will 

13 bring in the highest sales test, the sales 

14 volume combination, make the adjustments so 

15 that the curves go through that point, so we 

16 follow the ARM requirements. 

17 And then, we also build in some 

18 adjustments for issues we find lab-to-lab. 

19 So, it brings it down a little bit, depending 

20 upon what it is. 

21 So, it is fundamentally the same 

22 tool we use for design, but it has got other 
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1 things added onto it, so we can use it to put 

2 ratings out. 

3 MR. KLEISS: Jeff Kleiss with 

4 Lochinvar. 

5 This could apply to multiple 

6 different boiler manufacturers, but, 

7 typically, we would test bookends for each 

8 different product family and then do linear 

9 interpolation between the two, possibly 

10 testing an intermediate size; either that or 

11 else test each individual model within a 

12 product family. 

13 MS. ARMSTRONG: Sure. 

14 MR. ROBERTS: Carl from Zero Zone. 

15 In our case, in commercial 

16 refrigeration equipment, certain terms within 

17 the AEDM change with some of the design 

18 choices. So, the answer to the question would 

19 be we have several different AEDMs. 

20 MS. ARMSTRONG: Okay. I just have 

21 one other question. I mean, it sounds 

22 generally like maybe the majority of you may 
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1 not have all the testing that would meet this 

2 criteria done already, but you may be a good 

3 way down that pathway. Is that a fair 

4 characterization? I mean, I don't think we 

5 were writing requirements necessarily that 

6 would make you start from ground zero. 

7 MR. VerSHAW: Well, I guess I came 

8 in thinking we had to have third-party testing 

9 for this because that is the way the ARMS is. 

10 MS. ARMSTRONG: No third-party 

11 testing. 

12 MR. VerSHAW: But we have a lot 

13 more testing that we are comfortable with. 

14 Our biggest issue is going to come in the next 

15 section, where we are doing verification 

16 testing and the lab-to-lab issues and all 

17 that. That is where, actually, we have more 

18 trouble than anything else. 

19 MS. HOOTMAN: Yes, I would agree 

20 on the commercial side we have this. 

21 MS. ARMSTRONG: Okay. 

22 MR. LORD: This is Dick Lord, 
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1 Carrier. 

2 The same thing for us. One 

3 question I had for you, though. If you have a 

4 product that has two metrics, I assume you 

5 will still only have to use one unit to get 

6 the two metrics? Say, for example, a heat 

7 pump that has got a cooling and a heating -- 

8 MS. ARMSTRONG: Correct. 

9 MR. LORD: Okay. 

10 MR. KLEISS: I will say, within 

11 the boiler industry, often there are data 

12 points that are available to substantiate 

13 things. The problem is having the appropriate 

14 documentation to say that we have properly15 calibrated instruments that generated that 

16 data. That kind of support is often not going 

17 to be there. 

18 MS. ARMSTRONG: Okay. Thank you. 

19 MR. AMRANE: Karim Amrane, AHRI. 

20 Well, that is a product like, for 

21 example, walk-ins, which we don't have yet -- 

22 MS. ARMSTRONG: Sure. 
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1 MR. AMRANE: -- conservation 

2 standards. 

3 MS. ARMSTRONG: Right. 

4 MR. AMRANE: So, there is not much 

5 data out there. 

6 MS. ARMSTRONG: Right. 

7 MR. AMRANE: So, don't assume that 

8 everybody is on the same level playing field. 

9 MS. ARMSTRONG: Definitely. 

10 Definitely. No. 

11 Yes? 

12 MR. ROBERTS: Carl from Zero Zone. 

13 I think it is fair to say that 

14 this proposal is written in such a way that we 

15 are partway there. 

16 MS. ARMSTRONG: Part? Part, we 

17 will take it. We will take something. 

18 MS. HOOTMAN: Ashley? 

19 MS. ARMSTRONG: Sure. 

20 MS. HOOTMAN: Jill Hootman from 

21 Trane. 

22 One thing that I did remember, you 
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1 know, yes, we have tools, and our AEDM is fit 

2 around both air-cooled and water-cooled and 

3 water-source heat pumps. I would say that 

4 most of the other water-source heat pumps 

5 manufacturers are probably not at the same 

6 point. 

7 MS. ARMSTRONG: Okay. Thank you. 

8 Okay. So, any other last-minute 

9 comments on selecting units? 

10 (No response.) 

11 So, I will, since someone brought 

12 it up, I will go ahead and open the floor. 

13 Do you guys want to break for 

14 lunch or do you want to keep going? It is 

15 noon now. 

16 Well, one, two, three, four, five, 

17 six, seven more, eight more slides. Now, that 

18 being said, probably at least an hour, if I 

19 had to guess. Two? Really? Okay, maybe two 

20 hours. Two hours maybe. 

21 Lunch? All right, we will break 

22 for lunch. We will be back here at one 
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1 o'clock. So, an hour. Is that okay? 

2 The cafeteria is downstairs. 

3 There is a Subway all the way down. And then, 

4 if you need to go to the cafeteria, you have 

5 to go to the first floor, down, and around, is 

6 the best way I can explain. 

7 (Whereupon, the foregoing matter 

8 went off the record for lunch at 12:01 p.m. 

9 and went back on the record at 1:07 p.m.) 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22
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1 

2 
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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 

2 1:07 p.m. 

3 MS. ARMSTRONG: Okay. Welcome 

4 back. I hope everyone had a pretty good lunch 

5 here at the DOE cafeteria or Subway. 

6 We are going to move right into 

7 the number of testing rounds. So, current 

8 regulations -- and this was something brought 

9 up earlier for motors, which require one round 

10 for substantiation and, then, subsequent 

11 rounds or even on a regular basis, multiple 

12 rounds of what we would call the verification 

13 testing over time against your AEDM. 

14 And the Department proposed to get 

15 rid of the second round of testing for what 

16 you would call subsequent verification of the 

17 AEDM and the NOPR, and add in requirements 

18 which would, for all intents and purposes, 

19 require that the models underlying the 

20 substantiation be current. So, recognizing 

21 that that, in and of itself, would require 

22 some probably testing over time. 
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1 So, what I am going to do is open 

2 the floor to the idea of not doing subsequent 

3 rounds of verification or even an annual basis 

4 of verification testing for your AEDM on a 

5 subset of models. And instead, leaving those 

6 requirements that we talked about before we 

7 took a break on the books or weighting those 

8 two. 

9 So, I will open it up at this 

10 point. Anybody? Do we agree with the 

11 proposal? 

12 PARTICIPANT: We do. 

13 (Laughter.) 

14 MS. ARMSTRONG: Okay. 

15 MR. GARST: Yes, Mike with Lennox. 

16 We agree. No second rounds 

17 needed. 

18 MS. ARMSTRONG: And so, you would 

19 be more in favor of requirements which apply 

20 to the models required for substantiation, 

21 keeping those current, rather than requiring 

22 periodic review and verification of an AEDM? 
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1 I imagine there might be some 

2 differences of opinion, depending on product 

3 type. And maybe not. 

4 Sure. 

5 MR. HON: In a dynamic market, I 

6 don't know how you can possibly expect a 

7 simple computer model to maintain itself 

8 without some verification, with all the 

9 engineering changes that are going on in some 

10 markets. In our market, I know that is a 

11 fact. There are so many new compressors 

12 coming out, so many new fan motors coming out, 

13 so many new coils coming out, and iterations 

14 of all that, if you don't verify them, I don't 

15 know how you are going to defend your 

16 position. 

17 MS. ARMSTRONG: Okay. So, that 

18 was Charlie from True. 

19 MR. HON: Charlie Hon. 

20 MS. ARMSTRONG: And I have a 

21 question, actually, a follow-up question to 

22 that, or to anyone else who wants to speak to 
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1 this. So, if we do do some type of periodic 

2 review or verification, there are two ways we 

3 could look at this. One is that we keep the 

4 tolerances intact. And obviously, the 

5 tolerances stay, and we leave it to the 

6 manufacturers' discretion how many units they 

7 may want to test and check over time. That is 

8 one way. That is the way it has been done 

9 here. There is no formal requirements, 

10 acknowledging that manufacturers will probably 

11 do some type of audits to make sure their AEDM 

12 is valid over time. 

13 Or we could do a more formalized 

14 proposal where the Department actually has 

15 certain set of requirements that apply on an 

16 annual basis for subsequent verification and 

17 for new models that may come out or changes 

18 that will be made over time. And maybe annual 

19 is not the right number. Maybe three years is 

20 the right number, maybe five years, whatever 

21 it may be. 

22 But I am asking for different 
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1 opinions and pros and cons and ideas for what 

2 maybe the Department should consider with 

3 respect to those. 

4 Sure, go ahead, Frank. 

5 MR. STANONIK: Frank Stanonik, 

6 AHRI. 

7 I am fully aware this is not part 

8 of this rulemaking, but the question you raise 

9 leads right to that point, that if there is 

10 recognition of VICPs it changes your question 

11 a lot because, in fact, if a company is 

12 participating in a VICP, there inherently will 

13 be, I will call it, continuous validation of 

14 whatever AEDM they used because the ratings of 

15 a particular model will either be verified or 

16 not. 

17 And so, it is difficult to answer 

18 your question right now because, according to 

19 DOE's current schedule, VICP is another 

20 rulemaking, right? 

21 MS. ARMSTRONG: Yes, it is. It is 

22 another currently ongoing rulemaking. And as 
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1 we learned this morning, speed of light here. 

2 But I do have a question for you. 

3 That is great for those who participate in 

4 what we would call a voluntary industry 

5 program right now. And perhaps when we go 

6 down the pathway of looking at those more 

7 specifically in our regulations, that is one 

8 thing. 

9 Do you think that that requirement 

10 should be applicable to a manufacturer across 

11 the board? In other words, either the VICP 

12 does it or a certain percentage of models 

13 should be verified, period? 

14 MR. STANONIK: Going out a little 

15 bit on a limb here, I think the answer is, 

16 yes, in the same way that if a manufacturer -- 

17 forget the current subject, okay. But if I am 

18 manufacturing something, and I am interested 

19 in just putting out a product that meets my 

20 design, I have my own internal QC, right? It 

21 is hard to imagine the modern-day manufacturer 

22 doesn't have some level of QC that checks 
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1 their production. 

2 So, I would say, just taking that 

3 basic concept, I could see where it would 

4 apply to efficiency ratings and, then, the 

5 AEDM. 

6 MS. ARMSTRONG: This is Ashley 

7 from DOE. 

8 Just a follow-on, as Mr. Daugherty 

9 explained earlier, for motors we have 

10 something more formal where there is like this 

11 periodic verification that is required. I 

12 guess, are you advocating that that actually 

13 is a requirement? Or should it be left to the 

14 risk and discretion of the manufacturer? 

15 MR. STANONIK: Frank Stanonik, 

16 AHRI. 

17 I think, because, again, we are 

18 talking about a huge variety of products, I 

19 think in terms of DOE's regulation, it should 

20 be left to the manufacturer to determine what 

21 is the proper level of checking, whatever we 

22 are going to call that. Motors may be a 
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1 unique situation, which I am not very familiar 

2 with. 

3 MS. HOOTMAN: Yes, yes. Jill 

4 Hootman, Trane. 

5 I would agree with what you said. 

6 I think it is the risk of the manufacturer. 

7 They have to determine -- I mean, obviously, 

8 federal penalties are onerous. So, I mean, 

9 you are going to determine some way to 

10 continually upgrade and continually maintain 

11 an AEDM in order to hold that risk inside, 

12 internal to your company. 

13 MS. ARMSTRONG: Okay. Thank you. 

14 Sure, Charlie? 

15 MR. HON: This is Charlie Hon, 

16 True Manufacturing. 

17 We basically worked on a 

18 statistical maneuver here to reduce testing. 

19 You are taking it from -- for us, it would be, 

20 giving a basic idea, we would be going from 

21 700 basic models, which would fit into 20 

22 different categories, and right now we are 
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1 required to do two per. So, over 1400 tests 

2 which have pretty much been completed; now go 

3 back and we could come up with 20 tests, 

4 highest volume, 21 samples. From 1400 to 21 

5 is a huge reduction in validity. And now not 

6 certify those? Not have an ongoing basis for 

7 that? I don't understand that at all. I am 

8 just totally befuddled by this whole thing. 

9 I can understand it used on 

10 certain applications and a need for certain 

11 applications, but how can you possibly turn, 

12 unless we have arduous and very strict 

13 enforcement, so that there is constant testing 

14 of product -- without that, we have 

15 competitors who cheat every day; we know that. 

16 They are thick. They are blatant. And the 

17 Department is well aware of some of them 

18 through the Energy Star programs and through 

19 just basic testing, in California problems 

20 that have developed. 

21 So, they know that our industry is 

22 dirty. And yet, now we are going to have, 
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1 well, industry will monitor itself. That is 

2 tough to believe because right now we are not. 

3 MS. ARMSTRONG: Okay. Paul? 

4 MR. DOPPEL: Paul Doppel with 

5 Mitsubishi. 

6 I think that there probably might 

7 need to be a requirement for manufacturers, 

8 even though they are coming up with their own 

9 AEDM, if the Department is thinking that 

10 verification is needed, then the VICP should 

11 be given the highest degree of authority or 

12 support to be that verification body. 

13 MS. ARMSTRONG: Okay. Thank you. 

14 Sure. Go ahead. 

15 MR. DAUGHERTY: Roger Daugherty, 

16 Baldor Electric. 

17 I guess I would just like to give 

18 a good plug for what is going on in the motor 

19 business. We have gone to the trouble of 

20 creating a laboratory accreditation program 

21 for testing. And so, all samples that are 

22 tested for certification have to be done in an 
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1 accredited test facility or one that is 

2 recognized as participation in a third-party 

3 independent certification program. 

4 And so, we feel that we have got 

5 very good control over the testing that is 

6 done, the results that come out of the 

7 testing, and the tolerances that went into 

8 certification. The results of that testing 

9 are used to support the AEDM. 

10 And again, I feel that I know we 

11 are in a very different situation, that we are 

12 talking about a product that is very well13 defined by the physics of the product. We are 

14 not putting together a lot of different 

15 combinations of parts that alter the 

16 efficiency and characteristics. So, we are in 

17 a very certain situation. 

18 But I would not like to see 

19 something go into the final rule that alters 

20 away from the way we are today. It is 

21 working. We have confidence in it. 

22 Through NEMA, they have now 
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1 created a verification program that 

2 manufacturers can participate in as an 

3 independent party. We have a CSA and a UL 

4 recognized third-party certification program 

5 that we can participate in to cover the 

6 certification of products and verifications of 

7 the AEDMs. 

8 So, I would just caution that, as 

9 I have expressed today, there are concerns 

10 that you are trying to do one-size-fits-all 

11 type of language in Part 429. Some of those 

12 parts don't seem to really fit and apply to 

13 electric motors and small electric motors. I 

14 would like however you can consider carrying 

15 forward what is in Part 431, as you move it to 

16 Part 429. 

17 Thank you. 

18 MS. ARMSTRONG: Karim? 

19 MR. AMRANE: Karim Amrane, AHRI. 

20 I guess I would like to respond to 

21 Charlie's statement about industry being dirty 

22 and industry policing itself. I mean, I am 
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1 not sure which product you are talking about, 

2 but industry has been policing itself for more 

3 than 50 years. We have certification programs 

4 in place that are very strong certification 

5 programs. Maybe you are referring to your own 

6 product; I don't know. But that is the 

7 general statement here. Let's be clear about 

8 this. 

9 MR. NESHAN: This is Massoud 

10 Neshan. 

11 And I would like, kind of in 

12 support of what Karim said, I strongly 

13 disagree with the language that was used, and 

14 maybe it is inappropriate to talk about it 

15 here. But this industry is not dirty, and I 

16 personally am offended by its being said that 

17 this industry is dirty. This is uncalled for. 

18 MR. HON: I did not say which -- I 

19 said quite clearly, if you gentlemen remember 

20 -- this is Charlie Hon again -- there have 

21 been several incidents in California which we 

22 know have happened. They are documented. 
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1 They are in the court records. We have had 

2 companies reprimanded, companies fined. 

3 That's dirty. 

4 If you are not on the other end of 

5 that, and maybe you are not, but we still have 

6 these players in the field. The players in 

7 this room know what they are doing because 

8 they are not the ones who are going to be 

9 violating the laws, but there are others who 

10 do. The players who violate the laws don't 

11 come to these meetings. 

12 MR. KLEISS: I would just support 

13 the comment that was made of cautioning you 

14 against the one-size-fits-all kind of a ruling 

15 here, and the comment about having, say, 

16 compressors or components that can contribute 

17 significantly to the efficiency changing over 

18 time. That just does not apply to all types 

19 of products now. So, please bear that in mind 

20 when you are making the rules. 

21 MS. ARMSTRONG: Sure. Thank you. 

22 MR. ROBERTS: This is Carl from 
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1 Zero Zone. 

2 I think it is safe to say that the 

3 manufacturers who are in this room, if you 

4 give them the responsibility for making the 

5 AEDM work, they have the ability to do that. 

6 MS. ARMSTRONG: Oh, go ahead. 

7 MR. GARST: Mike Garst, Lennox. 

8 I want to make sure that we are 

9 clear here because you are using the word 

10 "verification" and we have substantiation and 

11 validation and assessment testing. Is 

12 verification the assessment testing or 

13 something else? 

14 MS. ARMSTRONG: No. So, we are 

15 not talking about assessment testing yet. 

16 This would just be a second round of testing. 

17 I'm sorry. This is Ashley from 

18 DOE. 

19 We are not talking about 

20 assessment testing yet. This is just 

21 currently in the regulations for AEDMs there 

22 are two rounds of what you would call 
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1 substantiation and subsequent manufacturer 

2 verification before a full use of an AEDM can 

3 occur. 

4 And for motors, there is a 

5 periodic verification. And this is all 

6 manufacturer-initiated. So, it has nothing to 

7 do with any DOE-initiated subsequent testing. 

8 So, we had proposed to get rid of 

9 that second round. And it sounds like from 

10 what I am hearing that the majority supports 

11 that with the exception of one for HVAC and 

12 CRE, and motors seem to be working the way 

13 they are. 

14 Not to say what the Department may 

15 do. And we encourage you -- I guess, you 

16 know, when you write written comments, maybe 

17 there is some middle ground here and maybe 

18 there is something -- I don't know what it 

19 would be -- but maybe there are ideas. You 

20 have ideas. I strongly encourage you to submit 

21 them. I mean, if you don't want verification 

22 or if you do but you want it limited or you 
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1 have other ideas, I strongly encourage you to 

2 bring them to the table because we are open at 

3 this point. Okay? 

4 Okay. So, we kind of talked about 

5 this earlier in terms of AEDM validation and 

6 what we proposed. We didn't propose any 

7 specific frequency that the AEDM must be 

8 updated. 

9 There was just a requirement that, 

10 No. 1, DOE reserves the right to request 

11 documentation underlying the AEDM at any point 

12 in time. You must retain documentation 

13 describing the AEDMs, supporting the test data 

14 and anything that goes into it; obviously, the 

15 AEDM itself. If you do any subsequent 

16 verification or auditing yourself, it would be 

17 a good idea to maintain that as well, and 

18 anything else you think to support your AEDM 

19 kind of substantiation and use package, as I 

20 would say it. 

21 And so, with that, the only 

22 frequency we had in there was regarding the 
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1 test procedures and standards being current, 

2 as we spoke to earlier. 

3 So, I think we talked about this, 

4 but does anyone else have any comments on 

5 frequency-type things or any other proposals 

6 the Department should consider about frequency 

7 of updating or maintaining or testing? 

8 (No response.) 

9 No? Okay. 

10 Oh, please. 

11 MR. LORD: Yes, this is Dick Lord 

12 with Carrier. 

13 At the bottom of page 32046, in 

14 the left-hand column, it says, "DOE intends to 

15 address this topic further in upcoming 

16 certification compliance/enforcement 

17 rulemaking." 

18 MS. ARMSTRONG: Uh-huh. 

19 MR. LORD: That is talking about 

20 the documentation. Is there going to be 

21 another -- okay. 

22 MS. ARMSTRONG: Yes. 
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1 MR. LORD: Which is great. The 

2 more you can document it, the better. 

3 MS. ARMSTRONG: Right. 

4 Okay. I am guessing this is where 

5 we have comments. 

6 Assessment testing. So, from the 

7 March certification and enforcement 

8 rulemaking, DOE made it clear that we may 

9 conduct assessment testing at any time to 

10 evaluate compliance with our standards. The 

11 test results from one unit are compared to 

12 both the standard and the rating for the 

13 product. I realize for commercial equipment 

14 -- well, see, you guys have certified ratings 

15 or AHRI rating out there, and that is what we 

16 would use in our comparisons for now. 

17 So, I will keep going for now. 

18 So, potential outcomes of an assessment test 

19 result. So, failure to meet ratings. In 

20 other words, if we test a single unit and the 

21 results of that give rise to a potential where 

22 the rating, something looks like it is off, we 
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1 propose that manufacturers must resubstantiate 

2 their AEDM within 30 days using the test data 

3 obtained from DOE-initiated testing. In other 

4 words, we would give you that testing. If you 

5 had a substantiation -- say you had just the 

6 minimum of five; you would add it as a sixth 

7 unit, resubstantiate your AEDM for any new 

8 ratings that come out that were less 

9 efficient, you would then recertify those 

10 ratings. 

11 We wouldn't necessarily require 

12 any new testing. It is just that we would 

13 say, hey, here are the results from our tests; 

14 incorporate it in. 

15 MR. AMRANE: Karim Amrane. 

16 Just a question. What did you 

17 mean by something is off? If you are not 

18 within the 5 percent, is what you mean? 

19 MS. ARMSTRONG: There is no 5 

20 percent in DOE's reg, Karim. 

21 MR. AMRANE: No, no, no, no. 

22 Let's say that you are rating your product 
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1 with an AEDM. Okay? Now DOE does a test. 

2 What will be the basis for DOE to say this is 

3 a valid test or this is not a valid test? We 

4 need to know that. 

5 MS. ARMSTRONG: Okay. So, you are 

6 asking, if we went back and we had 

7 certification data that says, yes, this rating 

8 came from an AEDM, you're right, we would look 

9 at the 5 percent. You're correct. I'm sorry. 

10 I thought you meant -- 

11 MR. AMRANE: No. 

12 MS. ARMSTRONG: Never mind. 

13 So, the 5 percent tolerance, yes. 

14 MR. AMRANE: Fine. 

15 MS. ARMSTRONG: Yes. 

16 MR. VerSHAW: Okay. So, I guess 

17 we go back to the earlier slide, the 10 CFR 

18 429.70(c) -- this is Jim VerShaw from 

19 Ingersoll Rand -- 429.70(c) says that, if you 

20 test something that is bigger than 5 percent 

21 of the AEDM or 5 percent of your rating -- 

22 MS. ARMSTRONG: Five percent of 
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1 your rating from the AEDM. 

2 MR. VerSHAW: Now, you know, that 

3 could be derated from what the AEDM would give 

4 you. 

5 And the other issue is a single 

6 test? What about some kind of defect in that 

7 particular sample or what about a test that 

8 was not set up correctly, which happens a lot? 

9 Or not charged correctly? Or I don't know. 

10 MS. ARMSTRONG: Okay. So, just 

11 some caution here. You know, if we had a test 

12 result back that, say, it looks like the 

13 certified rating is this and it looks like our 

14 test result is 8 percent off or so, the first 

15 thing I think we would do is just contact the 

16 manufacturer and have a dialog, about the test 

17 data, about the AEDM. And before anything was 

18 required to happen, we would have that 

19 discussion and to see where things -- 

20 MR. VerSHAW: Of course, you know, 

21 the way it was written, the way we read it 

22 coming into today, it didn't include that 
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1 step. 

2 MS. ARMSTRONG: We're not that -- 

3 (Laughter.) 

4 MR. VerSHAW: Well, if it is not 

5 written down, it is not done that way. This 

6 is the government here, right? 

7 (Laughter.) 

8 MS. BARHYDT: Go ahead, Frank. 

9 MR. STANONIK: But I guess I want 

10 to try to make sure we have the same 

11 understanding. What is on this slide says, if 

12 DOE determines that the model fails to meet 

13 its certified rating, okay? Getting to that 

14 point involves several steps and is most 

15 definitely a process, possibly starting with 

16 testing one unit, but potentially testing some 

17 more. 

18 But for DOE to get to the point 

19 that they can say, okay, we believe your model 

20 is not rated properly is, to me, that is a 

21 defined decision, and if that is what you are 

22 meaning here, then everything else makes sense 
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1 because, in fact, you have gone through your 

2 procedures and you have done the tests that 

3 say, wait a minute, this product is not rated 

4 correctly, and it is done. The decision is 

5 done. 

6 And if you are at that point, 

7 then, in fact, the things you have under there 

8 I say would be appropriate and correct. But 

9 some of the discussion I was hearing was, 

10 okay, you pulled in one unit, and let's just 

11 say you weren't happy with the results of the 

12 one unit, okay? That is not the same as DOE 

13 has determined the model's rating is 

14 incorrect. That the start of the process. 

15 This is the end of the process, right? 

16 MS. ARMSTRONG: That is correct -- 

17 MR. STANONIK: Okay. 

18 MS. ARMSTRONG: -- for the most 

19 part. There is one caveat. 

20 MR. STANONIK: Oh, okay. 

21 MS. ARMSTRONG: This repercussion 

22 is, once DOE has made a definitive 
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1 determination -- and, obviously, there would 

2 be some discussions at the outset. What you 

3 said is multiple tests. That is not the 

4 proposal right now. 

5 As it stands right now, we could 

6 have one test, but we would go through a 

7 process of which that test data could be 

8 scrutinized. Plenty of discussions could be 

9 had. We would also look at other test data 

10 that the manufacturer might have, a variety of 

11 different things before a definitive 

12 determination is made. But once it is made, 

13 this is the repercussion, that is, as 

14 proposed. 

15 Sure. 

16 MR. LORD: So, some unit does 

17 fail, and we all agree it has failed. So, I 

18 have five units. Going through the math, 

19 let's say, of those five units, I had one that 

20 was a plus 5 percent, this one is coming in at 

21 minus 6 percent. So, I have got to take this 

22 sixth unit and add it in. Do I throw that 
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1 plus 5 percent unit out because it is too 

2 good? The math doesn't kind of work, you 

3 know, because it has got to be within plus or 

4 minus 5 percent. So, I had five units before, 

5 one of which was at a plus 5 percent, a very 

6 good unit. 

7 So, now we are saying, well, you 

8 have got to derate your AEDM because you have 

9 got a unit that is at minus 6. That is going 

10 to throw that plus unit out of the mix then. 

11 MS. BARHYDT: Well, the plus 5 

12 wouldn't be the very good unit. The plus 

13 5/minus 5 is how close did your model come to 

14 your test result. So, I am just questioning 

15 your wording a little bit there because it 

16 sounded like that was a high-performance unit, 

17 and that is not what the AEDM is supposed to 

18 be. 

19 MR. LORD: No, no. It is just a 

20 range of the units I have, just to give an 

21 example. It means that I can't meet that plus 

22 or minus 5 percent then. So, I will have to 
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1 throw one of the other units out. 

2 MS. ARMSTRONG: So, I don't know 

3 if that is the case. So, for example, if you 

4 have one unit that fails, a determination is 

5 made that it failed the certified rating, and 

6 that unit happens to be 6 percent off, like 

7 you said, it may mean that your simulation is 

8 just off for that specific design or that 

9 product. It doesn't necessarily mean that the 

10 ratings for all the other ones would change. 

11 MR. LORD: Yes. No, we had that 

12 discussion internally. It was not that we may 

13 have forgotten to put in a factor for coil 

14 coolings or something. 

15 MS. ARMSTRONG: Correct. Exactly. 

16 MR. LORD: You know, that fixes 

17 that problem. 

18 MS. ARMSTRONG: But if you go back 

19 and it does result in other changes, you are 

20 going to need to have a substantiation package 

21 that then meets the criteria. So, if that 

22 change results in other models falling out, 
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1 you would have to then -- 

2 MR. LORD: Do it. 

3 MS. ARMSTRONG: Yes. Correct. 

4 MR. DOPPEL: Paul Doppel, 

5 Mitsubishi. 

6 All the discussion has been 

7 centered around like one unit, the whole unit. 

8 And especially like if you have a heat pump, 

9 you can have multiple metrics for each. So, 

10 if there is just one of the metrics that does 

11 not meet the requirements, does that require 

12 resubstantiation of all the others as well or 

13 just that one? 

14 MS. ARMSTRONG: So, regardless of 

15 one metric or two, if one unit fails, it 

16 requires resubstantiation of the AEDM with 

17 that unit. Now, that being said, if you rerun 

18 your simulation and your ratings don't change 

19 for anything else in that, then it is not a 

20 big deal, right? Nothing else has changed. 

21 Just that unit has been incorporated in. You 

22 fix that unit. You fix that rating. Done 
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1 deal. 

2 Now, if you include it in and 50 

3 percent of your ratings change to be lower 

4 because you forgot a loss or something that is 

5 applicable to like half your product line, 

6 then you need to recertify all those ratings 

7 that would result in less efficient and more 

8 consumptive products. 

9 Does that make sense? 

10 MR. LEWIS: Okay. To come back to 

11 one thing that Jim said, when you get to this 

12 stage, you are notifying the manufacturer that 

13 there is an issue. And when you do the 

14 testing that Jim has mentioned here, at the 

15 prior meeting we talked that the manufacturer 

16 will be notified. We would be able to go to 

17 that lab and not supervise, but review that 

18 testing? Was that not true? Because, then, 

19 how do we know that the test was operated 

20 properly? I mean, you are talking about our 

21 livelihood. You know, innocent until proven 

22 guilty. We need to be able to watch what is 
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1 going on to just say, "Wait, you just missed a 

2 step." I mean human error. 

3 MR. DOPPEL: And the 

4 resubstantiation, that is a tremendous amount 

5 of work. 

6 Paul Doppel, Mitsubishi. 

7 MR. LORD: And what you really 

8 need to probably think about is some appeal 

9 process. Like, for example, a unit may fail 

10 in a laboratory. We take it back to our 

11 laboratory and say we didn't confirm that. 

12 You know, right now, with the ITS and AHRI 

13 program, there is a way to work through that. 

14 Because labs do make mistakes. 

15 Instrumentation goes off in a lab. 

16 MR. VerSHAW: Jim VerShaw here 

17 again. 

18 Remember, earlier a round-robin 

19 test at a third-party lab will get you a 4 

20 percent swing. So, you could take that unit 

21 that came in at 6 percent below or 7 percent 

22 below, put it in another room, test it the 
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1 next day, and be 2 percent low or 3 percent 

2 low. And if you hadn't done the first-day 

3 test, you wouldn't be talking to us. And we 

4 didn't do anything different. 

5 MR. FLY: Well, and remember, that 

6 is in the same lab, too, being calibrated 

7 against each other. So, lab-to-lab, facility8 to-facility, it may be higher than that. I 

9 don't think anybody in this room knows for 

10 sure that plus or minus 5 percent, or has any 

11 data that says plus or minus 5 percent is the 

12 right number. So, if the number is plus or 

13 minus 10 percent, proven through some big 

14 study with round-robin tests, you know, I can 

15 selectively go through and find the 5 percent 

16 that will meet and validate my AEDM, but the 

17 first time you test one outside of my window 

18 of tests, then I could invalidate my AEDM and 

19 I am back to ground zero again. 

20 MS. ARMSTRONG: Let me switch to 

21 the phone because we have a couple of people 

22 who have been waiting patiently. 
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1 Jeff Bauman, do you want to speak? 

2 MR. BAUMAN: Yes. Am I there? 

3 MS. ARMSTRONG: Yes, you're good. 

4 MR. BAUMAN: Okay. I just had, 

5 going back on the verification, it is a little 

6 late getting back to it, but -- from 

7 Continental Refrigerator, Jeff Bauman, 

8 hopefully one of the people who is not 

9 considered dirty in this industry. I think it 

10 is a good industry, reliable, but yet there 

11 have to be checks and balances in place to 

12 make sure that people who might not try to do 

13 things the right way are not able to do that. 

14 One of the things that has been 

15 discussed and proposed to EPA, and possibly to 

16 DOE, as far as Energy Star, and I would like 

17 to put it out there for consideration on this 

18 side, too, is using component verification 

19 instead of actual retesting on a regular basis 

20 to verify the proper components and, 

21 basically, the products that are being built 

22 are what the manufacturer has claimed in their 
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1 original studies with their energy 

2 consumption, or whatnot. 

3 I know some of the issues that 

4 happened in California were with the 

5 manufacturer basically claiming or saying that 

6 the product that was made, that was tested and 

7 failed was not actually the same product it 

8 was supposed to be, and it was kind of a back9 and-forth there. But it certainly seemed to 

10 be a component issue there. 

11 And I think that if there is a set 

12 of criteria that says, okay, these are the 

13 components that make up that unit, and groups 

14 such as UL inspector or an NSF-type inspector 

15 on a regular basis is doing a blind factory 

16 audit, that they be able to cover and check 

17 those things and have a more accurate and more 

18 comprehensive evaluation. 

19 Thanks. 

20 MS. ARMSTRONG: Thank you. 

21 So, one more from the phone before 

22 we turn it back over to the floor here. 
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1 Craig? 

2 MR. MESSMER: Yes, hi, Ashley. 

3 MS. ARMSTRONG: Hi. 

4 MR. MESSMER: This is Craig 

5 Messmer from Unico. 

6 On your slide, you say, "It fails 

7 to meet its certified rating." Are you 

8 talking about the rating or the minimum 

9 efficiencies? Because what is DOE trying to 

10 achieve here? What is their interest level? 

11 MS. ARMSTRONG: So, on slide 26, 

12 we actually talk about the rating. When we 

13 get to slide 28, we will be talking about 

14 standards. Okay? 

15 Anyone? Oh, go ahead. 

16 MR. HON: There was a question 

17 posed about validity. We have done some 

18 validity testing, taken the same unit in the 

19 same test room the next day, and started the 

20 test again, changed the legitimate conditions 

21 within the parameters of the test standard 

22 from high to low on the range of internal and 
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1 external temperatures, and found a 7 percent 

2 difference in the same piece of equipment, all 

3 within legal limits of the test standard. 

4 It is 38 plus or minus 2. We 

5 would run one warm voltages. We would crank 

6 the opposite direction and go high to low 

7 voltages. And by changing two parameters of 

8 the test standard, which there are more than 

9 that, we changed the outcome by 7 percent. 

10 MS. ARMSTRONG: Thank you. 

11 Sure. 

12 MR. DAUGHERTY: Roger Daugherty, 

13 Baldor Electric. 

14 To follow up on the issue of where 

15 a piece of equipment may get tested, again, 

16 going back in the history of electric motors 

17 and conducting round-robin testing, in a NEMA 

18 standard the value of efficiency of any 

19 particular unit out of the basic model, out of 

20 a population, could have total losses 

21 approximately 20 percent higher than that of 

22 the NEMA nominal efficiency value. 
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1 Based on the round-robin testing 

2 and the variation that was observed in it by 

3 testing in different laboratories, then when 

4 we were working with DOE to establish the 

5 tolerance requirements for the sample testing 

6 of five units of a basic model -- I am not 

7 talking about this 10 percent thing that deals 

8 with the AEDM. But the issue here under 

9 meeting certified rating is that testing of 

10 that sample of five. 

11 And while the round-robin testing 

12 and everything supported that 20 percent 

13 variation, when the rule was written into Part 

14 431, DOE discounted the variation between 

15 laboratories and only accepted the variation 

16 of testing performed in the same laboratory, 

17 because the manufacturer most typically will 

18 do all of his testing of that particular size 

19 unit in the same facility rather than shipping 

20 them around. Okay? 

21 So, the tolerances that are based 

22 upon certification of the efficiency rating 
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1 for an electric motor of a sample of five is 

2 based upon testing only being performed in a 

3 common facility by that manufacturer. So, 

4 yes, he does have the possibility that, if 

5 that unit or the five were tested by someone 

6 else in some other facility, that he could be 

7 outside of the allowable variation. 

8 And so, DOE could make a finding 

9 and question that rating, that certified 

10 rating, while the manufacturer's test would 

11 have supported that rating. Okay? 

12 So, yes, variation between test 

13 facilities is very important. And so, some of 

14 that process needs to be included when you are 

15 going to into enforcement. 

16 The other concern we have with 

17 enforcement is that we have one set of 

18 criteria for approval of a sample when the 

19 manufacturer is certifying the product. And 

20 that is based upon percent of total losses 

21 over the average of the sample. 

22 In enforcement, the rule is 
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1 written around a lower control limit of the 95 

2 percentile of the T-distribution, a totally 

3 different concept. So, when a motor is 

4 examined to determine if it meets its 

5 certified rating under enforcement, it is a 

6 different rule that is applied than is applied 

7 when the manufacturer actually certifies the 

8 product. 

9 And then, we have the rule against 

10 the AEDM that he may have actually used to 

11 certify that particular one that is now being 

12 tested under enforcement. 

13 But we do realize that within the 

14 enforcement procedure there are the processes 

15 of the consultation with DOE to try to resolve 

16 any differences that were observed before it 

17 gets into a finding that you actually are in 

18 non-compliance. 

19 MR. GLATT: Helmuth Glatt, Nidec 

20 Corporation. 

21 I just want to expand on what 

22 Roger has been saying. It is possible, under 
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1 I think Part 431, that we already have the 

2 rule in place, that of that sample of five 

3 motors, the average of those shall be within 5 

4 percent of the NEMA nominal efficiency. But 

5 one unit could possibly be as low as 15 

6 percent below. 

7 So, in that case, if you happened 

8 to pick that particular unit for this testing, 

9 you will have us requalify the entire AEDM. 

10 So, while we are okay for compliance, we would 

11 still be okay for compliance, but yet the 

12 AEDM, which already showed that the product 

13 was in compliance, would be out of compliance. 

14 So, it is confusing. 

15 MS. ARMSTRONG: So, I do just want 

16 to make one thing clear. And maybe this is 

17 something just generally I am not sure that 

18 everyone recognizes. 

19 If we talk about testing and we 

20 take away the AEDM for a second, if the 

21 Department were to pull a unit for tests and 

22 you had certified your rating using testing, 
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1 too, running the sampling statistics and 

2 coming up with their certified rating, then 

3 sending that to the Department, if we were to 

4 subsequently test one in a lab and we got a 

5 number that was, you know, different than your 

6 certified rating -- let's say it is 8 percent 

7 off, just for lack of a better -- we would do 

8 the same thing. This exercise would be the 

9 same regardless of whether you did testing or 

10 whether you used an AEDM. 

11 We would come to you. We would 

12 say, "Here's the testing that we got. Let's 

13 see your test data." We would go through that 

14 same process. 

15 So, from the Department's 

16 perspective, we didn't understand why, just 

17 because you are coming up with a simulation, 

18 or coming up with a number with a simulation, 

19 why that process should necessarily be 

20 different. And maybe it should; maybe it 

21 shouldn't. 

22 So, I just want to make clear that 
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1 this is the same process that we use if you 

2 had tested. I don't know if that changes 

3 anyone's opinion of things. Or perhaps it 

4 changes our opinion of where we did the other 

5 thing. 

6 MR. VerSHAW: Well, Jim VerShaw 

7 here. 

8 So, the steps that the Department 

9 would take on getting a test that was 8 

10 percent low, where is that written down? And 

11 if you two folks aren't here next year, God 

12 forbid, would the next folks follow the same 

13 rules and processes that you were just 

14 discussing? 

15 MS. BARHYDT: The processes are 

16 all in Part 429, Subpart C. 

17 MR. VerSHAW: Well, I thought in 

18 there it said, if you get a unit that falls 

19 below the -- and we are not talking about 18 

20 -- below 13, you immediately test more units. 

21 It didn't say anywhere in there that you are 

22 going to talk to the manufacturer. 
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1 MS. BARHYDT: Well, what it says 

2 is that, if the Department has reason to 

3 believe that the product is non-compliant, 

4 that is not necessarily that it is half a 

5 percent below the standard. So, first of all, 

6 there is not an absolute cutoff there. So, if 

7 the Department has reason to believe DOE will, 

8 DOE may -- and even that is not a will; it is 

9 a may -- proceed with enforcement testing. 

10 In order to proceed with 

11 enforcement testing, we have to contact the 

12 manufacturer. That is in the regulations. It 

13 doesn't lay out a specific we will talk to you 

14 for "X" amount of days and all kinds of things 

15 like that. 

16 MR. VerSHAW: Well, I know that. 

17 MS. BARHYDT: But we have to 

18 contact the manufacturer because the 

19 manufacturer has to provide the units for 

20 enforcement testing. 

21 MR. VerSHAW: I thought you just 

22 asked us for units and be done with it. 
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1 (Laughter.) 

2 MS. BARHYDT: No. 

3 MR. VerSHAW: That is the way it 

4 was written. I'm sorry. 

5 MS. ARMSTRONG: And one thing to 

6 make just one distinction here is what we are 

7 talking about here is the ratings. I realize 

8 it could be very different. I mean, something 

9 could be rated at -- I don't know; I am just 

10 going to make up a number -- 15 EER, and in 

11 that case there is no question about the EER 

12 standard. At that point, it is just a ratings 

13 thing. It has nothing to do with compliance 

14 with standards or enforcement testing. So, 

15 there is a nuance there that is different. 

16 MR. VerSHAW: Well, yes, but 

17 -- Jim VerShaw again -- but -- 

18 MS. ARMSTRONG: But we would still 

19 talk to you. 

20 MR. VerSHAW: Pardon me? 

21 MS. ARMSTRONG: We would still 

22 talk to you. 
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1 MR. VerSHAW: I know, but the 

2 ramifications of missing a rating and having 

3 to redo an AEDM and changing other ratings is 

4 pretty big, regardless of whether it is at 13 

5 or 18. 

6 And if you think about it, if I 

7 had to -- luckily, I don't do anything over 5 

8 tons, but if I had to do the stuff that Jill 

9 has to do, I am not sure I could get all those 

10 units built and tested in 30 days. 

11 MS. ARMSTRONG: So, step back. 

12 MR. VerSHAW: Yes. 

13 MS. ARMSTRONG: Why would you need 

14 to build and test? There is no testing 

15 requirement here at all. All it says -- see 

16 at the bottom; there is no new testing. 

17 So, all we are saying is take our 

18 test point -- 

19 MR. VerSHAW: Okay. 

20 MS. ARMSTRONG: -- and plug it in. 

21 MR. VerSHAW: So, you take your 

22 test point and plug it in, and, all of sudden, 
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1 it doesn't meet the 3 percent anymore. 

2 MS. ARMSTRONG: Then, you would 

3 have to have another unit, maybe a seventh. 

4 But not like all of them. I mean, I guess 

5 that is what I am trying to understand. 

6 MR. VerSHAW: Well, we are, too. 

7 MS. ARMSTRONG: Where is the 

8 balance there? I mean, at some point, we 

9 require, once a determination has been made 

10 for testing purposes as it relates to the 

11 certified rating, if you were testing and came 

12 up with a rating, we require a rerate if we go 

13 through that process and make a determination. 

14 Why should this be any different? 

15 MR. VerSHAW: Well, go ahead. 

16 MR. AMRANE: Karim Amrane. 

17 I guess it is a good question. 

18 Then, I would ask you, then, at least for the 

19 AEDM, it seems to be clear to me that you test 

20 the unit. You compare the rating with the 

21 AEDM. If you are not within 5 percent, you 

22 might trigger additional testing, right? 
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1 But if you had tested a unit, 

2 instead of using an AEDM, there is not such a 

3 thing written in the regulation today. It is 

4 very vague. It is up to DOE to decide what is 

5 good, what is not good enough, I guess. It 

6 doesn't say that if you are within 5 percent, 

7 it is okay; we will not do additional testing. 

8 It doesn't say anything like that. 

9 So, let's be consistent then. 

10 Let's put the 5 percent in that part of the 

11 regulation as well, so at least it is 

12 consistent. 

13 MS. ARMSTRONG: Thank you, Karim. 

14 MR. FLY: You know, a lot of this 

15 could go away if we would only require one 

16 side, you know, downside tolerance on this. 

17 The plus or minus is the thing that is really 

18 -- this is Mark Fly with AAON -- that really 

19 concerns me about the whole AEDM and the 

20 testing part. 

21 Because if we discover that the 

22 lab-to-lab tolerance, or whatever we decide 
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1 tolerances, are much bigger than 5 percent, we 

2 can knock our AEDM down 5 percent and cover 

3 everything that we need to cover. But the 

4 plus or minus, you know, my concern is not the 

5 computer program; it will give the same number 

6 with the same input every time. My concern is 

7 the testing that you have to support the 

8 computer program with. 

9 MR. LORD: Well, I was going to 

10 maybe try to answer at least the way I was 

11 interpreting it. When you do your AEDM, you 

12 use the plus or minus 5 percent. If you 

13 conservatively rate and the testing comes in 

14 better than 5 percent, she is not going to say 

15 anything to us. She will send us a gold star. 

16 (Laughter.) 

17 MS. ARMSTRONG: Yes, I mean, that 

18 is exactly right. I mean, if you have rated 

19 conservatively, regardless, we are happy. 

20 That is great. The consumer is going to get 

21 that or better, right? 

22 It is when you get to the negative 
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1 8 percent or the negative 7 percent that we 

2 are going to come knocking at your door and 

3 say, "Hey, we need to have a really friendly 

4 discussion." 

5 MR. FLY: But at that point, you 

6 are going to get into the middle of our 

7 business about how we put the AEDM together, 

8 because at that point you are asking for all 

9 this documentation on our AEDM. 

10 MS. ARMSTRONG: We will be asking 

11 for stuff, some stuff, correct. 

12 Sure. 

13 MR. LORD: We may want to talk 

14 more about the 30 days. Because even if you 

15 didn't have to test another unit, we might 

16 say, well, we question that data. We want to 

17 put it in our laboratory. We want to run 

18 tests. 

19 MS. BARHYDT: This is after the 

20 final finding -- 

21 MR. LORD: After the final 

22 finding. 
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1 MS. BARHYDT: -- after everything, 

2 all the discussions are done. 

3 MR. LORD: That is about three 

4 years. We've got lots of time. 

5 (Laughter.) 

6 MS. ARMSTRONG: It can be. 

7 MS. BARHYDT: In all honesty, it 

8 can and does take more than 30 days. This is 

9 30 days after the final determination. 

10 MR. DOPPEL: Does it specifically 

11 say that in there? I don't remember seeing 

12 it, 30 after final determination. 

13 MS. ARMSTRONG: It does. It does. 

14 MR. DAUGHERTY: Roger Daugherty, 

15 Baldor Electric. 

16 If I could back up to one 

17 statement that you made, you were saying that 

18 the manufacturer would not necessarily be 

19 required to do additional testing due to this 

20 particular unit not meeting certified rating, 

21 but that they were to take DOE-supplied test 

22 data from a separate laboratory and 
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1 incorporate that into their AEDM, which has 

2 been based around their testing in their 

3 facility, and does not necessarily accommodate 

4 results obtained in a different test facility. 

5 And I don't know that 

6 manufacturers would really want to do that, 

7 to, for lack of a better word, contaminate 

8 their AEDM by using data from an unidentified 

9 and uncontrolled facility against all their 

10 other data. 

11 MS. ARMSTRONG: Okay. Well, so 

12 that is the proposal. The unidentified 

13 uncontrollable would always be a third-party 

14 lab, like a third-party lab you guys would use 

15 for certification. So, it may be a mix. You 

16 would know what lab it is from. We would turn 

17 over our test data, and you would see 

18 everything. 

19 You may still have the same 

20 opinion about whether it should be used or 

21 not, but just to clarify, those are some of 

22 the things that would happen. 
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1 MR. DAUGHERTY: Roger Daugherty. 

2 Yes, I guess I would say I don't 

3 have such a problem in the motor industry. 

4 But from what I have been hearing about the 

5 other industries and the way testing is done 

6 in laboratories, I guess I was raising an 

7 issue for them and not necessarily for the 

8 motor industry. 

9 MR. LEWIS: I'm confused. If you 

10 are going to tell us after the test where it 

11 was tested, why couldn't you tell us before 

12 the test, put a gag on us, and let us just 

13 watch the test? Then, we don't have the 

14 variation worries. I mean, what am I missing? 

15 MS. BARHYDT: So, we have actually 

16 been actively doing enforcement testing. And 

17 I can tell you from experience that having 

18 people watch a test does not at all impact the 

19 challenges to the test. It does not seem to 

20 raise the level of comfort with the test. 

21 Honestly, it doesn't change anything. 

22 So, from the Department's 
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1 perspective, we are confident that the test is 

2 being done in accordance with the DOE test 

3 procedures. That is not to say that every 

4 last tweak that the manufacturer may have 

5 instructed the lab when they had it 

6 certification tested was done, but we are 

7 confident that the test is being done in 

8 accordance with the DOE test procedure. 

9 MS. ARMSTRONG: Once we make that 

10 finding. 

11 MS. BARHYDT: Yes, and that is the 

12 other thing, is that if the test is done and 

13 we give it to the manufacturer, and the 

14 manufacturer finds something wrong with it, we 

15 redo the test. This isn't a "well, too bad, 

16 it's all over, a done deal; you're just stuck 

17 with it." I mean, it is an actual dialog. It 

18 is in our interest as well as yours to make 

19 sure that all of our decisions are based on 

20 valid test data. 

21 MR. LORD: Dick Lord with Carrier. 

22 One of the things that can help a 
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1 lot of times is you can allow the manufacturer 

2 to be there to commission the unit to make 

3 sure it is running properly, then ask them to 

4 leave the room during the test. Because a lot 

5 of this big commercial equipment is extremely 

6 complex, and the average person cannot set it 

7 up right. 

8 MS. BARHYDT: This is Laura 

9 Barhydt, DOE. 

10 A real quick follow-up question. 

11 Are these pieces of equipment that you require 

12 the setup for your own representatives to be 

13 present for setup or are these things that 

14 third parties may set up as well? 

15 MR. LORD: Yes, this is kind of 

16 like the statement we had earlier -- 

17 MS. BARHYDT: That is why I was 

18 asking. 

19 MR. LORD: -- that we put in our 

20 literature, factory commissioning required. 

21 MS. BARHYDT: Okay. 

22 MR. LORD: And we actually charge 
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1 the customer for it. 

2 MS. BARHYDT: Okay. 

3 MR. GARST: Mike Garst with 

4 Lennox. 

5 I just want to make sure we 

6 understand on this. On the plus side, we 

7 talked earlier on substantiation, that we 

8 wouldn't be concerned about the plus. I think 

9 you were going to agree to do that. 

10 But on the assessment it says that 

11 it has to be within that. So, as long as you 

12 agree on the substantiation, then we are good. 

13 I just want to make sure. 

14 MS. ARMSTRONG: We agree and we 

15 can clarify that. We have no problem, rate 

16 conservatively all you may want. 

17 Anybody else? Anybody else have 

18 any comments? 

19 (No response.) 

20 Okay. So, we had a question from 

21 the phone, but I am not sure I can answer it 

22 off the top of my head. 
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1 "But, as an example, if DOE 

2 minimums required an energy consumption that 

3 is 11 kilowatts per day, if the AEDM indicates 

4 that the CRE consumes 9 kilowatts a day, but 

5 the published rating by the manufacturer is 10 

6 kilowatts a day, what are the implications?" 

7 So, we compare the 9 to the 10, 

8 right. I think we are good to go. So, the 

9 rating is 10. The test data is -- so you are 

10 good on the standard because it is 9 to 11, 

11 right? So, conservatively rated. You are 

12 good and you are conservatively rated. It is 

13 fine. 

14 Okay. Yes? 

15 MR. HON: Would you notify the 

16 manufacturer that the rating was higher? 

17 Because that may question his validation of 

18 his system, if he is that far off on the other 

19 direction, that he didn't down-rate the 

20 product, but, actually, his model said it 

21 would be that way. He may need to know that 

22 to consider his modeling to be different. 
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1 MS. BARHYDT: In the hypothetical, 

2 there was no actual test data. 

3 MS. ARMSTRONG: The AEDM and -- 

4 MS. BARHYDT: Oh, okay. I thought 

5 that was the standard. 

6 MS. ARMSTRONG: Yes, they just 

7 said as a simulation and that is certified. 

8 So, there was no test data. 

9 MS. BARHYDT: Yes, in the 

10 hypothetical there wasn't any test data. 

11 MS. ARMSTRONG: Generally, I guess 

12 it is a question, even if we don't have a 

13 ratings issue or a compliance issue, is there 

14 general interest to know what the results of 

15 any testing the Department does is? 

16 MR. HON: Charlie Hon. 

17 That is the reason I asked the 

18 question, because if it is showing much 

19 better, then our models may be wrong. We may 

20 need to change our modeling technique. 

21 MS. ARMSTRONG: Okay. So, I 

22 think, generally, the Department is working 
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1 toward making available its test data from 

2 those things that it has tested that are not 

3 subject to ongoing enforcement cases. So, 

4 there are plans in the works to make all the 

5 test data, whether it is being done for Energy 

6 Star assessment, et cetera, available. 

7 Yes? 

8 MS. MEYERS: So, Ashley, this is 

9 Karen Meyers with Rheem. 

10 When you say "make the information 

11 available," is it available to the 

12 manufacturer or to the public? 

13 MS. BARHYDT: To the public. 

14 MS. MEYERS: This is Karen Meyers 

15 with Rheem. 

16 I just have one other. It is not 

17 on? Yes, it is. 

18 So, just listening to the 

19 conversations going around today, DOE seems to 

20 say rate conservatively, we like you to rate 

21 conservatively; you are not going to have any 

22 problem if you rate conservatively, where, as 
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1 a manufacturer, what I want to do is rate 

2 accurately. If the DOE regulations are so 

3 burdensome that I have to rate conservatively, 

4 then to me there is a problem with the DOE 

5 regulations. Because I think it should be the 

6 purpose in this room between manufacturers and 

7 the government to rate accurately. 

8 I am just concerned with all of 

9 these different comments about how 

10 manufacturers are having to do their ratings 

11 to meet the burden of DOE. It seems like it 

12 is a little -- you know, at the end of the 

13 day, it is the consumer or the building owner 

14 or someone who is actually getting hurt. 

15 And so, it is just a general 

16 observation that I think needs to be part of 

17 the public record that DOE is forcing 

18 manufacturers to rate conservatively, so that 

19 there are no issues with this process. 

20 MS. BARHYDT: This is Laura 

21 Barhydt at DOE. 

22 I wouldn't say that we are 
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1 encouraging conservative ratings. We 

2 certainly permit conservative ratings. It is 

3 entirely up to manufacturers how they choose 

4 to rate. 

5 I will say that the certification 

6 statistics in the regulations are set up to 

7 cause a little bit of a conservative rating, 

8 but that has been part of the regulatory 

9 process, the whole framework, for decades. 

10 So, beyond that little bit that is 

11 built into the certification statistics, any 

12 additional conservative rating is entirely up 

13 to a manufacturer. And we are not advocating 

14 or discouraging that practice. 

15 MR. DOPPEL: Paul Doppel with 

16 Mitsubishi. 

17 When you talk about releasing test 

18 information, I mean, to what extent are you 

19 going to go? Are you going to release the 

20 entire testing results? Or is it just certain 

21 criteria like where it was compared with the 

22 metric? Because, otherwise, I think some 
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1 manufacturers would object that maybe it is 

2 releasing too much information. 

3 MS. BARHYDT: Complete test 

4 reports. 

5 MR. DOPPEL: Complete test 

6 reports? 

7 MS. BARHYDT: Yes. 

8 MR. AMRANE: Karim Amrane, AHRI. 

9 I guess, what would be the purpose 

10 of releasing the complete test report? I 

11 mean, for whom? For the consumer? Who is 

12 going to be interested in the complete test 

13 report? 

14 MS. BARHYDT: So, obviously, there 

15 was a federal expenditure of funds for DOE 

16 testing, and this is just part of the 

17 transparency of the government providing to 

18 the public the information paid for by the 

19 American taxpayers. 

20 MS. MEYERS: Laura, this is Karen 

21 Meyers with Rheem. 

22 Does that requirement, though -- 
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1 you know, I understand spending government 

2 funds and stuff, but why to meet that 

3 requirement does it have to include releasing 

4 the entire test report? Because I am afraid 

5 there could be some CBI information in there. 

6 And so, that would be some concern from my 

7 part. 

8 MS. BARHYDT: The information in 

9 the test reports is all information that any 

10 party who purchased a unit and paid for 

11 testing would be able to have. There is 

12 nothing in that test report that we have 

13 obtained from the manufacturer. 

14 So, everything in the test report 

15 is publicly accessible. And the Department 

16 has previously taken the position that test 

17 reports paid for by the Department are public 

18 and do not contain CBI. 

19 MS. MEYERS: Where is that 

20 information publicly available today? 

21 MS. BARHYDT: I am not exactly 

22 sure what you mean, but the test procedure is 
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1 public. And a person could buy a particular 

2 unit and they could pay a test lab to do a 

3 test, and they would get that same 

4 information. There is nothing in that test 

5 report that came from the manufacturer. 

6 MR. DOPPEL: This is Paul Doppel 

7 with Mitsubishi. 

8 This is an exception to that. Any 

9 manufacturer -- and it is not just VRF 

10 manufacturers, ductless manufacturers -- there 

11 are several companies that have variable-speed 

12 equipment. For like a heat pump with a 

13 variable-speed compressor, 10 tests are 

14 required, and the compressor frequency is 

15 provided by the manufacturer for each of those 

16 tests. That would be company-sensitive 

17 information. 

18 MS. BARHYDT: So, Paul, so far, we 

19 haven't tested any VRFs. 

20 (Laughter.) 

21 MR. DOPPEL: Well, I know, but 

22 that is why we are concerned. 
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1 MS. ARMSTRONG: We would have to 

2 contact you. You would know beforehand. 

3 MR. DOPPEL: Right. But, still, 

4 releasing that information is -- 

5 MS. ARMSTRONG: That's fair. 

6 MS. BARHYDT: No, that is fair. 

7 MR. DOPPEL: Okay. 

8 MR. LORD: Yes, Dick Lord, 

9 Carrier. 

10 I mean, a good engineer, if he 

11 gets his data, can sit down and reverse12 engineer that unit. So, I could take a 

13 competitor's unit, look at his test data, and 

14 say, okay, this is where he runs that 

15 condensing temperature, saturated suction, get 

16 all the performance, which I really shouldn't 

17 get. 

18 MS. ARMSTRONG: Are you really 

19 going to make me ask this question? Do you 

20 currently test your competitors' products to 

21 get that information anyway? 

22 MR. LORD: Yes, but now I get it 
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1 free. Now I get it free from you. 

2 (Laughter.) 

3 MS. ARMSTRONG: Let's be honest 

4 here. You have it anyway. 

5 MR. LORD: No, you know, I could 

6 see the key metrics that are important to the 

7 ratings, but all the test data. 

8 MS. MEYERS: Yes, this is Karen 

9 Meyers with Rheem again. 

10 I think having it on a public 

11 website is going to make reverse-engineering 

12 paramount. I mean, that is what everyone is 

13 going to do. 

14 Today, if we have to go out and 

15 buy one of those units, bring it into the 

16 test, tear it down, do the analysis, it is a 

17 much more burdensome deal. So, sure, we 

18 constantly test each other's units, but it is 

19 way different than having it on a public 

20 website, where not only U.S. manufacturers, 

21 but foreign manufacturers and everyone else 

22 can reverse-engineer the unit. 
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1 So, for the record, we are going 

2 to be totally against releasing the entire 

3 test report. And I don't think that it is 

4 necessarily required. 

5 I agree with Dick Lord; you can 

6 release key points of the test data, but the 

7 purpose of putting the whole test report out 

8 there is just lost on me. 

9 MS. ARMSTRONG: Okay. Thank you 

10 for those comments. We will take that under 

11 advisement, but we have ranged far from the 

12 actual topic of this public meeting. So, 

13 let's get back to AEDMs. 

14 So, we are talking about potential 

15 outcomes of assessment testing when the 

16 results of the single-unit test indicate that 

17 there may be a reason to believe that DOE 

18 should undertake an enforcement investigation. 

19 And so, this is actually if we 

20 would go forward with enforcement testing as 

21 if, you know, the same thing, regardless of 

22 whether the unit was rated with AEDM or the 
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1 unit was tested. We would go through our 

2 sample size of four for the low-volume, built3 to-order products. 

4 And then, if the enforcement 

5 testing results definitively come out in non6 compliance determination, so after all the 

7 discussion, after the testing results have 

8 been reviewed, after everything, if the 

9 definitive determination is made, these would 

10 be the repercussions of a unit that was rated 

11 with an AEDM that is found to be non12 compliant. 

13 Obviously, as with everything 

14 else, all other models within that basic 

15 model, they are deemed non-compliant. That is 

16 the same regardless of whether it is tested or 

17 an AEDM. 

18 If the basic model was one of the 

19 ones used to substantiate the AEDM, is found 

20 non-compliant, that one can no longer be used 

21 for substantiation. It must be redone. You 

22 rerate and recertify all basic models as 
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1 necessary. 

2 So, any questions there? Any 

3 concerns there? 

4 Sure. 

5 MR. LORD: Yes, Dick Lord with 

6 Carrier. 

7 This is where the 30 days may be 

8 the issue, like if you have to get another 

9 unit. Like, for example, on large unitary, we 

10 have a 90-day lead time in the ARI program to 

11 get a second sample because it takes that long 

12 to build them. 

13 MS. BARHYDT: So, obviously, we 

14 are proposing 30 days. If you think that that 

15 is not sufficient, we welcome those comments. 

16 Another possibility would be to 

17 specify some normal period of time and 

18 specifically say that DOE will work with you. 

19 We have some language sort of to that effect 

20 in some of the enforcement testing provisions 

21 as well. So, we would certainly welcome 

22 comments on that. 
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1 MR. DOPPEL: Paul Doppel from 

2 Mitsubishi. 

3 Also, if the product comes from 

4 Asia, then it will take much longer. It could 

5 be 60-plus days to get here. 

6 MS. ARMSTRONG: Okay. So, it 

7 might be that case-specific language is 

8 better, in which case the Department would 

9 just work with the manufacturer. 

10 MR. FLY: Mark Fly with AAON. 

11 MS. ARMSTRONG: Yes? 

12 MR. FLY: Now you said, basically, 

13 we are going to have to rerate everything 

14 within the basic model or the equipment class? 

15 MS. ARMSTRONG: So, what this 

16 basically says that you would have to do is, 

17 if one of your substantiation models is found 

18 non-compliant and you bring a new model in, 

19 any of the models that were rated using that 

20 old, what I call, AEDM, as opposed to the 

21 revised AEDM, if the ratings change to be more 

22 consumptive or less efficient as a result of 
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1 any revisions made, you would need to rerate 

2 and recertify those. 

3 MR. FLY: Okay. 

4 MS. ARMSTRONG: Yes. Anyone else? 

5 (No response.) 

6 Okay. And then, this is just a 

7 general DOE proposal to disallow the use of an 

8 AEDM following multiple instances of non9 compliance or if there is evidence that 

10 misrating was willful. So, this is just 

11 consistently on a regular basis, you know, the 

12 ratings are off coming out of an AEDM. DOE 

13 reserves the right to disallow the use of an 

14 AEDM altogether. 

15 MR. LORD: It is a little open. 

16 You know, we like more specific, especially 

17 being engineers. 

18 (Laughter.) 

19 So, 2.5 would be good, you know, 

20 or something. 

21 MS. ARMSTRONG: Do you have 

22 suggestions for specifics that you would like 
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1 to see? 

2 MR. LORD: We will provide some 

3 comments. We will think about it, yes. 

4 MS. ARMSTRONG: Okay. Thank you. 

5 MR. VerSHAW: Yes, this is Jim 

6 VerShaw. 

7 It is kind of hard to determine 

8 the definition of willful. It could just be 

9 bad engineering. 

10 (Laughter.) 

11 MS. BARHYDT: I think when we 

12 drafted willful, what we were thinking of was 

13 something more along the lines of, we look at 

14 your AEDM and it turns out that what came out 

15 of your AEDM bears no resemblance to what you 

16 actually rated it at. 

17 MR. VerSHAW: Yes, yes. 

18 MR. BOESENBERG: Can you provide 

19 or I guess I would like to have a dialog about 

20 the definition of multiple instances? In one 

21 of these ones where there is thousands of 

22 products being represented, you can have 
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1 multiple instances, but it is less than 1 

2 percent or something like that. 

3 MS. ARMSTRONG: I think that gets 

4 to his question earlier. We left it open, and 

5 if there are specific suggestions about what 

6 bounds that range or what the Department 

7 should consider, we welcome them. 

8 MS. BARHYDT: One other thing I 

9 would note is that this is multiple instances 

10 of non-compliance, which means that we have 

11 gone through this process multiple times, 

12 which it is a very long process to get to a 

13 finding of non-compliance. 

14 And so, if we have gone through 

15 this -- I am just throwing out numbers; I have 

16 no idea -- but three or four times over 

17 months, and possibly even years, and the 

18 manufacturer is still not producing an AEDM 

19 that can accurately rate its products, I think 

20 we would have serious doubts about the ability 

21 of that manufacturer to produce an AEDM that 

22 could accurately rate the products. 
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1 MS. ARMSTRONG: I think just an 

2 analogy there would be the same thing about 

3 doing in-house testing. If we went through 

4 multiple rounds where in-house testing has 

5 resulted in just wrong ratings over and over 

6 again, and we actually found non-compliance, 

7 not misrating, but non-compliance out of those 

8 multiple times, there may be need for a 

9 discussion of moving to third-party laboratory 

10 testing solely at that point. So, it is kind 

11 of synonymous at that point. 

12 Okay. Moving along, I think we 

13 already hit this one for the most part. This 

14 has to do with the resubstantiation test 

15 procedure standard or if you discontinue a 

16 model that you used to substantiate your 

17 package, but I will put this up again in case 

18 anyone has any last questions or comments. 

19 MR. AMRANE: I have a question. 

20 MS. ARMSTRONG: Sure. 

21 MR. AMRANE: This is Karim Amrane, 

22 AHRI. 
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1 I guess with respect to changes to 

2 the test procedure, I don't know if it was 

3 addressed before, but sometimes test 

4 procedures are amended, but then there are not 

5 substantial changes made to the test 

6 procedure. It could be, I mean, our standards 

7 that are referenced by DOE, our AHRI standards 

8 are changed all the time. And sometimes that 

9 has no impact on the energy efficiency of the 

10 product. 

11 So, I think we need to be more 

12 specific than just say changes in the 

13 applicable test procedure. I think that 

14 should be substantive changes or changes that 

15 affect the energy efficiency of the product, 

16 or something like that. 

17 MS. ARMSTRONG: Right. We did hit 

18 on this a little bit earlier. Well, I am 

19 actually going to turn around a question to 

20 you. 

21 This was when the Department was 

22 told they worked at lightning speed. You 
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1 missed that part. 

2 (Laughter.) 

3 But I do want to ask you a 

4 question. Right now, it just says a change in 

5 the federal procedure, not the industry and 

6 not the ASHRAE test procedure, just the 

7 federal test procedure, recognizing that that 

8 usually doesn't happen more than every five to 

9 ten years. 

10 But a question to you would be, 

11 what characteristics -- or to everyone -- what 

12 characteristics should the Department consider 

13 if it decides to further clarify what that 

14 means? 

15 MR. AMRANE: I think I stated it. 

16 Karim Amrane, AHRI. 

17 Again, if it has an impact on the 

18 energy efficiency or the energy consumption of 

19 the product. 

20 MS. ARMSTRONG: Period? 

21 MR. AMRANE: Yes. I mean, that is 

22 what we are regulating, right? 
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1 MS. ARMSTRONG: Okay. 

2 MR. AMRANE: Yes. 

3 MR. DOPPEL: Paul Doppel with 

4 Mitsubishi. 

5 Go ahead. 

6 MR. STANONIK: Frank Stanonik, 

7 AHRI. 

8 I think it would be something 

9 along the lines of if that change affects the 

10 ratings of the products to which the AEDM has 

11 been applied. And the reason to do that, a 

12 little more elaboration here, is I can think 

13 of two examples. Okay? 

14 Let's say I got a waiver. Okay, I 

15 got a waiver and I have worked that into my 

16 AEDM already. All right? As we know, 

17 sometimes waivers take a long time to get into 

18 the test procedure. Okay? Well, once the 

19 waiver finally got into the test procedure -- 

20 in fact, my AEDM already adjusted for it -- it 

21 really doesn't need to be changed. Okay? 

22 The other circumstance would be 
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1 you change the test procedure to keep up with 

2 technology. And let's talk about, again, gas 

3 products. Let's say at some point the test 

4 procedure was changed to address products that 

5 fire at multiple rates. Okay? Well, that is 

6 not all models. Okay? 

7 If I had an AEDM that was specific 

8 to models that only fired at a single input 

9 rate, nothing has changed. So, there is going 

10 to have to be some context to explain, to 

11 qualify that. It can't just be a 

12 straightforward change whenever the test 

13 procedure changes. 

14 MS. ARMSTRONG: So, before I open 

15 up, I just want to make one comment to you. 

16 Or maybe it is a question, and then you might 

17 want to answer this one. 

18 What if we get an instance for 

19 which, yes, we have waivers, but in the final 

20 rule we change the method? In other words, we 

21 decide through that test procedure that the 

22 waiver method is not what we are going to use. 
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1 We are going to use some alternative. 

2 In that case, you know, then you 

3 don't have that method in your AEDM. Should 

4 that require something like that? 

5 MR. STANONIK: Frank Stanonik, 

6 AHRI. 

7 Probably yes, because, again, I 

8 think what I initially suggested would be some 

9 kind of text that would say if the change 

10 affects the rating of products to which the 

11 AEDM has been applied. In the situation you 

12 have described, I would say it probably will 

13 because, otherwise, DOE wouldn't have bothered 

14 to change the waiver procedure. So, I think 

15 the answer would be yes. 

16 MR. DOPPEL: Paul Doppel, 

17 Mitsubishi. 

18 The wording should be very 

19 specific other than just saying it changes the 

20 test standard, because I know with a 1230 

21 standard we are going to have some 

22 administrative changes in that that won't 
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1 affect the outcome. So, it has to be 

2 something that would be substantive within the 

3 testing procedure itself that would affect the 

4 outcome of the measured criteria. 

5 MS. ARMSTRONG: Okay. 

6 MR. VerSHAW: Yes, Jim VerShaw. 

7 The upcoming change for 

8 residential air conditioning pumps, we go 

9 regional. If that were the only change, I 

10 wouldn't think that would cause a need to 

11 resubstantiate because we haven't taken any 

12 products off the market. We are still doing 

13 the same descriptors. There might be 

14 different levels for certain places. You had 

15 it in standby power or whatever we call it. 

16 There, that wasn't done before. 

17 That portion of the AEDM would have to be 

18 adjusted and substantiated for that portion of 

19 it, but the other part shouldn't have to be 

20 touched. 

21 MS. ARMSTRONG: Right. 

22 MR. VerSHAW: So, you need some 
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1 kind of language that kind of spells out that 

2 type of thing. 

3 MS. ARMSTRONG: Okay. Thank you. 

4 Sure, Mark. 

5 MR. FLY: Yes, Mark Fly with AAON. 

6 Now, I mean, most of the test 

7 standards that are included in your standards 

8 by reference are changed -- Karim, help me -- 

9 if they are ANSI standards, they change every 

10 three years, I think, three or five. 

11 MR. AMRANE: Five. 

12 MR. FLY: Five. So, every five 

13 years, we are going to have the standard 

14 change. Now, I mean, a lot of times that 

15 standard change is just a reaffirmation or, 

16 like several people said, either we clarified 

17 something or it is a minor change in there. 

18 How does the DOE synch up with 

19 these changes in the reference test standards? 

20 MS. ARMSTRONG: So, for your 

21 products that you are speaking about, the 

22 ASHRAE 90.1 products, when ASHRAE 90.1 goes 
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1 through their process, DOE is, then, triggered 

2 to review it. So, we just did this back in 

3 April and brought all the test procedures and 

4 standards up for the 90.1-2010. So, we have 

5 the latest that are with 90.1-2010, but there 

6 is some lag time there. 

7 MR. FLY: So, it is by reference 

8 then? 

9 MS. ARMSTRONG: Parts are by 

10 reference, yes. So, yes, for the most part. 

11 MR. GARST: Mike Garst, Lennox. 

12 The one example I can think of in 

13 the commercial industry has been going from 

14 IPLV to IEER. And I am assuming that would be 

15 an example of one that would require that, but 

16 I can't think of anything else. That was the 

17 only thing for control, but it is still a 

18 different number that we put out there. 

19 MR. AMRANE: This is Karim Amrane. 

20 I have a question not really 

21 related to the discussion we are having right 

22 now, but it has to do with other descriptors. 
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1 I mean, the Department of Energy is coming up 

2 with additional requirements, let's say, for 

3 example, off-mode energy consumption. Is off4 mode going to be something that the AEDM could 

5 do, for example? Or for the furnace fan, or I 

6 don't know, all those things that are coming 

7 up. 

8 MS. ARMSTRONG: So, as proposed, 

9 the AEDM is drafted to be applicable to 

10 certain product types. So, for CACs, the 

11 answer as proposed off-mode, yes. 

12 MR. AMRANE: Okay. 

13 MS. ARMSTRONG: For furnace fans, 

14 it is no because there is nothing for furnace. 

15 MR. AMRANE: There is no AEDM, 

16 yes, you're right. 

17 MS. ARMSTRONG: There is no such 

18 thing as AEDMs for furnaces. But, yes. 

19 MR. AMRANE: Okay. 

20 MS. ARMSTRONG: Okay? 

21 Yes, please. 

22 MR. DAUGHERTY: Roger Daugherty, 
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1 Baldor Electric. 

2 I guess it is just a request for 

3 some clarification. In the past, I think that 

4 the test standards I have heard being referred 

5 to at present are the industry test standards 

6 as to how to do the tests. In the past, when 

7 DOE has used the term "DOE test procedure," it 

8 has been in reference to how to determine the 

9 average of the sample and make that comparison 

10 against either the representative efficiency, 

11 being either the standard or against the 

12 nameplated efficiency of a motor. 

13 Is it real clear what you are 

14 meaning here by referring to DOE test 

15 procedure? 

16 MS. ARMSTRONG: Motors is 

17 different. 

18 (Laughter.) 

19 MR. DAUGHERTY: It also applies to 

20 transformers. 

21 MS. ARMSTRONG: Right. So, we do 

22 mean the actual like, in your case, the IEEE 
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1 testing protocol and the version specifically 

2 incorporated in our regs, not necessarily the 

3 comparison. So, that is what we are referring 

4 to with respect to motors. 

5 I understand that the term rating 

6 also has a completely different meaning for 

7 motors. I have come to appreciate that over 

8 time. 

9 (Laughter.) 

10 Okay. So, with that, any last 

11 questions or comments? 

12 While you think of them, I have a 

13 question from Craig on the line. It has to do 

14 with, for independent coil manufacturers, is 

15 “current model” based on the indoor unit or 

16 the outdoor unit? And ICM only manufactures 

17 the indoor unit. 

18 And the answer would be, while you 

19 only manufacture the indoor unit, you certify 

20 a combination. So, “current” would refer to 

21 the combinations that you have certified. 

22 MR. VerSHAW: I'm sorry, I've got 
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1 a question. This is Jim VerShaw. 

2 So, if a third-party coil 

3 manufacturer doesn't know how to rate 

4 appropriately, is that going to get the OEM of 

5 the outdoor unit in some kind of hot water 

6 that they shouldn't be in? 

7 MS. BARHYDT: All of the 

8 certifications that the Department receives 

9 are certifications from a particular party. 

10 And an outdoor unit manufacturer is only 

11 responsible for the certifications that they 

12 make. 

13 MR. VerSHAW: Okay. 

14 MS. ARMSTRONG: Yes, please. 

15 MR. LORD: I know it is not that 

16 we are going to discuss it today, but we still 

17 have that issue on the table that, when we add 

18 up all of our basic model groups on 

19 commercial, we have that 11-trillion-plus 

20 number. And where do we start populating a 

21 database? And is there another alternative? 

22 We have got to work that out. 
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1 MS. BARHYDT: So, one thing I did 

2 want to mention before we adjourn today, the 

3 Department is exploring the possibility of a 

4 negotiated rulemaking for certification of 

5 commercial HVAC, commercial refrigeration 

6 equipment, and I believe commercial heat -- 

7 MS. ARMSTRONG: And water heating. 

8 MS. BARHYDT: Water heating, that 

9 is the one I forgot. 

10 The first phase of that 

11 exploration is actually conducted by an 

12 independent third party who speaks to 

13 interested parties and gets information and 

14 then writes a report which is presented to the 

15 Department. 

16 So, we will be having -- I think 

17 they are called the convener -- start 

18 contacting parties, hopefully, over the course 

19 of the summer. So, various people in the room 

20 may be getting a phone call. If he says he is 

21 calling about this, you will know what he is 

22 talking about. 
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1 The conversations with the 

2 convener are confidential. We only receive 

3 the summarized general gist of the views that 

4 were presented in the course of those 

5 discussions. 

6 MR. FLY: Will the basic model 

7 group question be resolved before this goes 

8 into effect, since it is so deeply ingrained 

9 in this whole rulemaking? 

10 MS. BARHYDT: This is Laura 

11 Barhydt with DOE. 

12 One would hope. 

13 (Laughter.) 

14 MS. ARMSTRONG: Let's go up there, 

15 and then we will go down. 

16 MR. KLEISS: Thanks. Jeff Kleiss 

17 with Lochinvar. 

18 Going back to the number of tests 

19 that we are required to do, we do a couple of 

20 tests to validate the AEDM, and then sample 

21 within the different product classes. Each 

22 one of those basic models that is tested, is 
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1 that a single test of a single unit within the 

2 basic model or is that the rating for the 

3 basic model with statistical -- for those that 

4 are listening, they are shaking their heads 

5 no. 

6 (Laughter.) 

7 MS. ARMSTRONG: Okay. So, for 

8 substantiation, single model, single test, if 

9 you are rating based on testing, at least two 

10 or more. 

11 Does that make sense? 

12 MR. KLEISS: I'm sorry. Say it 

13 again? 

14 MS. ARMSTRONG: So, for the AEDM 

15 substantiation, single model, single test, 

16 substantiation requirement. If you are purely 

17 basing a model's rating on testing, two or 

18 more. 

19 MR. KLEISS: Thank you. 

20 MS. ARMSTRONG: Sure. 

21 Next? 

22 MR. LORD: Yes, Dick Lord with 
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1 Carrier. 

2 This brought up the question, 

3 which is, if we did elect to rate based on 

4 tests, commercial equipment has a 95 percent 

5 confidence level; residential has a 90 

6 percent. It just doesn't make sense. 

7 MS. ARMSTRONG: Thank you. 

8 (Laughter.) 

9 MR. LORD: Okay. 

10 MR. DAUGHERTY: Roger Daugherty, 

11 Baldor Electric. 

12 I have several items here that 

13 haven't been covered yet today from the NOPR. 

14 One of them deals with the definition of the 

15 AEDM that has been proposed. I have noted 

16 that you did delete the definition of AEDM for 

17 small electric motors from 431.442, but you 

18 left it in for 431.12 for electric motors. 

19 And it is important because that 

20 definition that was in there for small 

21 electric motors and is in for electric motors 

22 makes reference to total losses as being one 
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1 of the criteria for the determination. And 

2 that is not in your present definition. So, 

3 if you are going to move to a common 

4 definition, then we would like total losses to 

5 be included in that definition. 

6 MS. ARMSTRONG: Okay. Thank you. 

7 MR. DAUGHERTY: The next is that, 

8 looking at the present version of Part 429 on 

9 the website, 429.41 is marked as reserved for 

10 electric motors. There is nothing in this 

11 NOPR that includes what is to go into that 

12 section, the same as there is no section 

13 reserved for small electric motors and there 

14 is no proposal in the NOPR for small electric 

15 motors. 

16 I guess I would like to know 

17 whether it is the Department's intent to issue 

18 a separate NOPR to cover those, so that we 

19 have the opportunity to comment prior to a 

20 final rule. 

21 MS. ARMSTRONG: Yes, sir. 

22 MR. DAUGHERTY: Okay. 
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1 MS. ARMSTRONG: That will be in 

2 the certification, compliance, and enforcement 

3 rulemaking round two. 

4 MR. DAUGHERTY: Even though it 

5 deals with AEDM? 

6 MS. ARMSTRONG: The AEDM, so any 

7 provisions that relate to the AEDM should be 

8 dealt with here. Any provisions that relate 

9 to certification and enforcement will be dealt 

10 with there. 

11 MR. DAUGHERTY: Well, what I am 

12 talking about is the -- 

13 MS. ARMSTRONG: I understand. 

14 MR. DAUGHERTY: -- part that deals 

15 with AEDM. 

16 MS. ARMSTRONG: Yes, sir. 

17 MR. DAUGHERTY: Okay. And the 

18 reason I brought up the issue about new final 

19 rules is that the May 4th final rule that just 

20 came out for small electric motors revised 

21 431.445(b), and this NOPR ends up deleting 

22 that and possibly the other parts, because 
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1 they are not included in text in this NOPR. 

2 I wasn't clear whether you were 

3 intending to delete all of (b), not 

4 recognizing the new parts that were in the new 

5 final rule. 

6 And the other is that that final 

7 rule expanded 431.445(c)(2) that was 

8 previously reserved, and it added a Part 3 

9 that states the criteria for determining that 

10 the test of a sample passes requirements for 

11 certification for a basic model. That part is 

12 important not necessarily for the AEDM, but it 

13 is for certification by testing of the basic 

14 model. Yet, this NOPR deletes that. 

15 MS. ARMSTRONG: Okay. 

16 MR. DAUGHERTY: And so, I don't 

17 know what the Department's intent is to try to 

18 keep that somewhere. 

19 And I believe that is all. Thank 

20 you. 

21 MS. ARMSTRONG: Thank you. 

22 Anyone else? 
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1 MR. NESHAN: Yes. 

2 MS. ARMSTRONG: Yes? 

3 MR. NESHAN: This is Massoud 

4 Neshan with Southern Store Fixtures. 

5 I was going to, as a closing, 

6 bring up the basic model definition again and, 

7 also, on the AEDM development and the 

8 timeline. However, based on what I just 

9 heard, that there is possible negotiating 

10 approach, at least as far as the commercial 

11 refrigeration equipment is concerned, I am 

12 going to hold back until we see what is the 

13 outcome of that before we discuss this 

14 further. 

15 Thank you. 

16 MS. ARMSTRONG: Charlie? 

17 MR. HON: What does that do to the 

18 reporting requirements due January 1st? 

19 MS. ARMSTRONG: I don't know. 

20 MS. BARHYDT: Until the Department 

21 modifies the current regulations, the current 

22 regulations stand. 
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1 MR. HON: Thank you. 

2 MR. AMRANE: Karim Amrane, AHRI. 

3 I guess I understand the comment, 

4 but at the same time manufacturers need some 

5 certainty. As I said in my opening statement, 

6 there is no way that the industry can be ready 

7 by January 1st, 2013, at least for the 

8 industry that AHRI represents. 

9 So, we ask for an 18-month delay, 

10 based on the final date of this final rule. 

11 And we will, of course, put that in writing in 

12 our comments, but I would hope that the DOE 

13 would seriously consider that request. 

14 Thank you. 

15 MS. ARMSTRONG: Okay. And just 

16 one more on the line. 

17 Can you unmute Aaron? 

18 Okay, Aaron, you should be good. 

19 MR. MEYERS: All right. Thanks, 

20 Ashley. 

21 Two general comments regarding the 

22 AEDM. The first one is regarding the time to 
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1 resubstantiate. From our perspective, 30 days 

2 is unrealistic, and we would request something 

3 closer to like 120 days. 

4 The reason being we are not 

5 building units specifically for testing and 

6 then throwing them away. We are needing to go 

7 into our production schedule and check what 

8 units are ordered and then build those ahead 

9 of time, so that we can put them through the 

10 specific DOE test procedures and then still 

11 satisfy our customer delivery dates. So, that 

12 is the reason for the 120 days versus the 30. 

13 And it especially becomes tough on three14 phase transformers. 

15 The second comment is regarding 

16 reducing the testing burden. And 

17 specifically, my comment here is regarding 

18 testing in the highest-loss configuration 

19 versus testing in the as-shipped 

20 configuration. So, transformer manufacturers 

21 are required by ANSI/IEEE standards to do 

22 electrical testing sort of as a quality check 
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1 before the units leave the factory. 

2 And we have an issue because we 

3 are unable to correlate the test data that we 

4 acquire by doing this ANSI testing to the 

5 DOE's standards, and the big disconnect is 

6 really in the fact that DOE requires testing 

7 in the highest-loss configuration versus the 

8 as-shipped configuration. 

9 All of the investigation that we 

10 have done in the past shows that it is very 

11 small, like on the order of maybe 2 or 3 

12 percent difference between the two. And I 

13 think this topic has come up several times in 

14 the past, but it has never quite made it into 

15 one of the standards. I am hoping that this 

16 time that might be incorporating into the 

17 standard. 

18 Thank you. 

19 MS. ARMSTRONG: Okay. Thank you. 

20 Yes? 

21 MR. ROBERTS: Carl from Zero Zone. 

22 I would agree with what Aaron said 
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1 about 120 days. We have got some components 

2 that have eight- or ten-week lead times. The 

3 tests take a long time to set up. So, if 

4 there is any retesting, physical testing 

5 required, 90 days probably isn't enough. 

6 MS. ARMSTRONG: Okay. Any other 

7 closing remarks? 

8 (No response.) 

9 Anyone else on the line? 

10 (No response.) 

11 No? 

12 Sure. 

13 MR. LORD: Actually, you know, a 

14 positive thing, I think it is a much better 

15 proposal. So, I appreciate the listening 

16 before -- 

17 MS. ARMSTRONG: Sure. 

18 MR. LORD: -- I think for a lot of 

19 us probably. 

20 And I like the idea of a 

21 negotiated discussion. That would be a good 

22 way to get at some of these problems. 
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1 MS. ARMSTRONG: Okay. Well, with 

2 that, we thank everyone for coming today, 

3 especially on some of the short notice. 

4 Thirty days, the comment period 

5 closes July 2nd, I believe. So, we welcome 

6 all your comments and questions up until then. 

7 And I hope everyone has a safe 

8 trip home. 

9 Thank you. 

10 (Whereupon, at 2:40 p.m., the 

11 meeting was adjourned.) 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22
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A

AAON 2:8 3:12 7:6

14:2 63:1 98:6

113:8 118:8 127:9

211:18 233:10

244:5

Aaron 143:12

145:15 258:17,18

260:22

ABB 8:12

ability 60:11 61:18

88:17 180:5

236:20

able 69:1 88:17

109:17 150:8

194:16,22 197:13

198:16 226:11

absolute 144:6

207:6

Absolutely 155:10

AC 29:5

accept 136:10

acceptable 126:12

accepted 201:15

accessible 226:15

accommodate

215:3

account 18:9 22:6

88:14 90:2 141:20

141:22

accreditation 96:21

97:9 175:20

accredited 96:18

176:1

accurate 198:17

accurately 152:1

223:2,7 236:19,22

ACEEE 3:18 17:2

30:7 54:9 63:17

90:12 135:17

achieve 199:10

acknowledging

169:10

acquire 260:4

ACs 25:7 45:1

active 72:3

actively 216:16

actual 19:6 21:7

22:20,22 58:3

72:15 85:11 96:4

96:7 98:20 105:5

105:20 120:8

197:19 217:17

221:2 230:12

247:22

AC/heat 57:2

Adam 2:6 8:8

adapted 158:10

add 16:2 28:5,15

58:19 66:13 70:6

82:11 91:13 92:20

94:7 107:12

130:10 140:10,22

166:17 185:6

190:22 249:17

added 58:11,13

59:22 159:1 256:8

adding 48:21 142:3

addition 23:9

additional 17:15,18

20:9 38:1 39:21

62:7 71:12 91:13

111:1 210:22

211:7 214:19

224:12 246:2

address 183:15

241:4

addressed 11:18

16:12,20 24:1

153:19 154:6

238:3

adjourn 250:2

adjourned 262:11

adjust 119:12,13

adjusted 240:20

243:18

adjustment 93:21

adjustments

158:14,18

administrative

242:22

adopt 120:12

adopted 27:11,12

105:15

advance 15:17

advantage 42:4

109:18

advisement 230:11

advocate 41:12

advocating 34:2

83:10 172:12

224:13

AEDM 12:7,16

17:12 20:15,17,19

21:17,22 23:18,20

24:4,7 25:19 29:1

29:10 30:10 32:1

32:7,11,14,21,22

33:8,18 36:19,20

37:8,14,15 41:21

52:13,17 53:7,10

55:3 58:11,15,16

58:18,21,22 59:3

61:19 62:10,12

63:6,10 64:3,10

64:15,16 65:14

67:1 70:19 71:12

71:18 72:2,6,10

72:12 76:4,7,9

77:4,11,20 79:7

79:18 85:6 88:13

88:19 89:11,12,13

90:1 91:12,15

92:18 97:15 102:2

103:11,14,21

104:3,7 106:5,16

108:16,17 110:4

111:2 112:5 115:3

115:8,9 116:9,14

117:3 118:2

119:14 121:11

122:11,15 125:11

126:2,21 127:2,13

127:21,21 128:2

131:6,11,12,19

132:7,12 133:3,11

133:17 134:1,5,11

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123:18 124:17

129:13 130:3,10

130:16,17,17

136:3,13,16

233:14

classes 17:10 38:12

38:15,22 39:15,20

40:1,5 43:9,19

45:18,19 46:5,8

46:13,15,19,22

47:20 55:8 60:14

60:15,20 61:4

62:4,5,13 63:19

64:1 70:9 71:2

76:15 101:21

102:1 107:8,9

108:2,14 117:15

118:20 123:10

129:17 130:1,5

147:18 148:5,13

148:14 251:21

classification 52:2

78:20 129:20

130:14,15

classifications

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129:15

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59:10 109:4

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clear 14:14 47:3

50:5 75:2,3

136:14 149:10

178:7 180:9 184:8

204:16 205:22

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climb 31:12

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191:13

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code 31:10 32:2

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Coffee 10:4

coil 192:13 248:14

249:2

coils 74:3 137:7

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column 37:6

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combinations

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36:10 61:10,18

75:8,10 82:16

86:6 99:6,8 146:8

150:17 151:18

152:5 155:2

160:14 169:17

174:3 176:6

179:11 185:8

191:13 194:10

205:11 213:2

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80:3 212:13 233:3

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168:12,12,13

175:8 187:22

190:20 205:2,17

205:18 234:12

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comment 23:21

38:2 48:9,11

55:11 56:22 78:14

80:12 93:10 100:4

119:3 139:6

179:13,15 241:15

254:19 258:3

259:15,17 262:4

commented 139:18

comments 4:7,10

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11:8 35:4,21 49:7

51:16,17,21 52:12

55:15,16 58:6

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84:14,22 98:21

101:14 103:4

150:22 163:9

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153:5 179:16

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compressor 74:3

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computer 18:22

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conditioner 54:22

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20:19 21:15,18

39:10 67:19 76:3

114:16 143:22

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Confirmed 48:4

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Consulting 2:5,11

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Council 2:15 6:19

Counsel 2:4,6,14

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109:16,16 121:2

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19:17 20:10 36:12

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181:12 220:4

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criteria 27:2 28:13

29:11 146:22,22

147:3 160:2

192:21 198:12

202:18 224:21

243:4 254:1 256:9

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cross-check 59:21

61:8

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curious 99:5

current 27:9,9 30:5

57:1 67:19 71:14

86:4 102:16

119:15 123:8

139:1 166:7,20

167:21 170:19

171:17 183:1

248:15,20 257:21

257:21

currently 23:5,13

28:17,18 29:18

48:18 52:8 79:8

137:10 148:12

170:22 180:21

228:20

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custom 55:17

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145:7 219:1

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customers 67:5

156:14

customization

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custom-built 51:18

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cutoff 69:3 207:6

C-O-N-T-E-N-T-S

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C-1 96:4

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daily 66:17,19

122:10

damper 81:19

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68:17 80:11 93:5

124:7 139:14

data 10:20 28:5,9

29:21 30:14 32:7

32:10 35:10 41:20

41:21 58:15 71:13

76:15,17 89:20

98:12 102:14,15

106:14 110:5

111:16 112:2,4

119:4,10,14

127:16,18 128:6

133:3 149:10

153:11 161:11,16

162:5 182:13

185:2 186:7

187:17 190:7,9

196:11 205:13

213:16 214:22

215:8,10,17

217:20 220:9

221:2,8,10 222:1

222:5 228:11,13

229:7 230:6 260:3

database 249:21

dataset 136:6

date 11:19 12:1,5

12:14,16 18:19

25:2,3,14 27:20

120:13 258:10

dates 259:11

Daugherty 2:7 4:3

8:11,11 20:13,13

21:20,20 45:14,14

58:8,8 69:17,17

84:1,1,21 85:2

95:22,22 96:9

100:5 104:21,21

106:21 107:3

131:1,1 134:3,4

141:10,10 146:11

146:11 172:8

175:15,15 200:12

200:12 214:14,14

216:1,1 246:22,22

247:19 253:10,10

254:7,22 255:4,11

255:14,17 256:16

David 2:6 8:13 9:7

day 157:19 174:15

196:1 199:19

220:3,4,6 223:13

days 15:18 109:16

185:2 207:14

209:10 213:14

214:8,9 232:7,14

233:5 259:1,3,12

261:1,5 262:4

deal 15:5 61:12

69:1 97:10 193:20

194:1 217:16

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241:21

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40:7 43:13 60:16

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Department 1:1,12

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110:4 134:12

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173:7,9 203:4

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187:16 217:17

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160:22 183:11

217:21 228:8

230:5 232:5

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43:2,3 45:2 47:10

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102:5 106:11,12

108:17 109:14

111:2,21 114:16

115:16 117:13,14

117:14 120:15,16

123:8 129:2,6,7,8

129:15 130:5

133:15 138:14,15

138:19 142:2

147:18,22 148:4,5

149:17 152:8

153:17,18 154:2

157:1,4,14 159:6

159:8,19 169:22

173:22 176:11,14

190:11 196:4

201:3 203:3,6

205:5,20 208:8,15

210:14 215:4

220:22 223:9

229:19 243:14

245:18 247:17

248:6 251:21

differently 96:14

difficult 65:17 83:7

97:20 152:4

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digging 80:20

dimensions 93:9

direction 18:6 38:3

200:6 220:19

dirty 174:22

177:21 178:15,17

179:3 197:9

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72:9 77:10,18,19

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discouraging

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DOE 2:2,3,6,14

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15:14 20:18 22:4

22:13,22 23:14

24:3 25:7,13 28:8

28:15 29:8,15

30:15 34:13,17

35:10,17 49:18

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59:22 64:5 69:8,9

71:22 76:14 77:4

79:13 81:8 83:15

84:5 85:9,11

95:12 98:8 99:6

105:14 110:21

113:10 114:3

119:5,11,12 120:8

120:11 122:17

132:20 136:9

144:6 166:5 172:7

180:18 182:10

183:14 184:8

186:1,2 188:12,18

189:12,22 197:16

199:9 201:4,14

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elaboration 240:12

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22:1,2 23:9 43:5,7

45:15,20 46:6,11

46:18,19 47:1,2,4

47:5,17,17 51:5

51:10,11 58:9,10

58:20 59:4,9,10

59:17 63:19 69:18

69:22,22 70:3,7

70:10,12,13,15,15

70:22,22 71:9

74:11 84:2 85:5,5

85:12,13 96:1,5,6

96:13,13 97:16,16

100:5,6 104:22

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141:11,14,14

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117:20,21 118:1

118:22 120:17

122:21 130:2

150:16 154:13

164:4 174:10

175:7 186:4

192:20 194:6,22

195:8 209:13

212:3 213:3

220:21 221:20

234:1 237:8

238:11 240:21

243:10,22 258:4

needed 32:16 62:7

138:8 167:17

175:10

needing 259:6

needs 17:15 32:3

55:14 146:2

202:14 223:16

negate 37:15

negative 88:22 90:5

90:8,18 91:1

150:22 212:22

213:1

negotiated 250:4

261:21

negotiating 257:9

NEMA 3:13 15:8

96:19 176:22

200:17,22 204:4

Neshan 2:13 3:10

8:1,1 13:6,7 39:12

39:12 66:11,11

116:7,7 178:9,10
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66:20 68:11 72:4

78:1 102:15,22

120:12,13 122:21

132:1 133:4,6,7,8

133:12 137:17

144:21 145:2,4,11

156:2,6 168:11,12

168:13 169:17

185:7,12 209:16

233:18 255:18

256:4,4

newcomer 50:5

newly 146:1,3

Nidec 2:9 7:10

31:20 203:19

NIST/NAVLAP

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Noe 8:19,19

nominal 100:11

101:3 200:22

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non 231:5,11 234:8

non-compliance

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noon 163:15

NOPR 11:18 12:8

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96:4 100:21

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253:13 254:11,14

254:18 255:21

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NOPRs 69:21

normal 143:22

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note 17:18 59:6

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noted 23:10 62:6

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notice 1:5 5:10

10:17,21 15:16,22

20:16 75:2 89:4

262:3

noticed 19:19

notification 28:20

notified 194:16

notify 220:15

notifying 194:12

notion 155:5

nozzles 82:3

NSF-type 198:14

nuance 208:15

nuances 41:1

number 4:11 26:2

53:18 54:2,5

64:21 86:22 87:5

87:16 128:14

142:15 148:19

151:19 166:7

169:19,20 196:12

196:12 205:5,18

208:10 212:5

245:18 249:20

251:18

numbers 83:6 99:8

106:11 107:15

127:14,14 236:15

numerical 105:19

O

object 225:1

objection 90:13

observation 68:18

137:1 223:16

observed 201:2

203:16

obstacles 147:6

obtained 71:13

185:3 215:4

226:13

obvious 40:12

69:19

obviously 22:19

44:11 55:22

102:14 108:1

156:11 169:4

173:7 182:14

190:1 225:14

231:13 232:13

occur 36:3 126:21

138:10 181:3

OEM 77:15 78:2

249:4

offended 178:16

offer 155:8

offering 19:10

61:21 62:14

155:18 156:12

offerings 117:8

Office 2:3,6,14

6:10 9:7

officially 12:13

offline 21:5

off-mode 246:3,11

oh 73:9,12 95:15

96:9 98:6 101:9

110:7 124:13

143:10 154:7

180:6 183:10

189:20 199:15

221:4

oil 43:6

okay 10:15 13:22

20:6 21:2 23:3,4

24:13,19 25:5

26:21 34:1 36:9

40:4 42:11 43:10

43:21 45:11 47:21

49:2,4 50:22 51:1

56:7,21 59:20

60:4 61:15 64:13

69:16 72:19 75:15

76:19 77:1 78:5,7

78:13 79:3 83:9

84:21 85:2 90:5,9

92:22 94:6,22

95:5 96:8 99:21

100:3 101:7,14,17

104:11,15,20

107:7 108:9,11,13

108:21 109:1,2

110:10,15,19

112:11 113:7

114:4 117:6 118:7

118:17 123:7

124:4 125:6,6,17

126:3,8,11 130:13

130:20,21 135:16

139:4 141:7 143:1

143:6,10 144:20

145:14 148:7,9

149:4,7,14 150:2

150:9,21 154:7

155:12,15,18

156:2 158:4

159:20 160:21

161:9,18 163:7,8

163:19 164:1

166:3 167:14

168:17 171:17

173:13 175:3,13

182:3,4 183:9,21

184:4 186:1,5,16

187:10 188:13,19

189:10,12,17,20

194:10 197:4

198:12 199:14

201:20 202:11

204:10,11 209:19

211:7 215:11

218:21 219:2,20

220:14 221:4,21

228:7,14 230:9

233:6 234:3,6

235:4 237:12

240:1,13,14,18,21

241:5,6 243:5

244:3 246:12,19

246:20 248:10

249:13 252:7

253:9 254:6,22

255:17 256:15

258:15,18 260:19

261:6 262:1

old 24:15 233:20

once 19:6 33:18

70:2 92:3 126:9

126:10 128:6

131:10 145:4,11

149:12 189:22

190:12 210:9

217:9 240:18

onerous 173:8

ones 27:8 39:21

40:6,8,11 62:1

74:8 111:14,18

134:9 137:14

157:4 179:8

192:10 231:19

235:21

one-by-one 76:20

one-size-fits-all

177:10 179:14

one-tailed 18:8

one-time 127:5,6

ongoing 34:11,16

61:5 153:9 170:22

174:6 222:3

open 5:14 10:13

11:7 21:4 52:9

55:18 62:16 74:10

74:13 75:1 103:3

115:8,17 116:3

120:20,21 151:16

154:21 163:12

167:1,9 182:2

234:15 236:4

241:14

opened 117:17

opening 3:5 4:2

11:4 13:3 18:1

116:5 151:10

153:15 258:5

operated 194:19

operating 143:22
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opinions 170:1

opportunity 54:18

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option 53:14

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options 14:9,11,15

order 3:2 54:3

55:18 65:8 93:21

109:17 112:1,4

147:1 173:11

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ordered 259:8

original 198:1

other's 229:18

outcome 106:13

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outcomes 184:18

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outdoor 248:16

249:5,10

outliers 114:15

115:2

outlined 129:3

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output 32:7

outset 11:8 190:2

outside 10:3 34:13

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127:19 139:16

196:17 202:7

overall 76:11 77:4

overcome 147:6

overdue 11:13

overlooked 146:13

oversight 59:7

Overview 4:4

overwrite 84:19

owner 223:13

o'clock 164:1

P

package 122:6

182:19 192:20

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packaged 48:2

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page 20:22 71:10

78:15 129:3,10

146:16 183:13

paid 225:18 226:10

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pair 76:8

panel 2:12 3:9 7:3

12:21 57:18

paragraph 71:11

146:14

parameters 199:21

200:7

paramount 229:12

Pardon 208:20

pare 39:4

part 30:1,21 32:9

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59:5,11,11 66:4

70:6,14,21 73:2

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100:9 115:7

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177:16 189:19

201:13 204:1

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223:16 224:8

225:16 226:7

237:13 239:1

243:19 245:10

254:8 255:14

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PARTICIPANT

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participate 5:22

171:3 177:2,5

participating

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participation 9:16

176:2

particular 38:17

65:14 100:19

114:21 122:20

124:3 136:1

170:15 187:7

200:19 201:18

203:11 204:8

214:20 227:1

249:9

parties 218:14

250:13,18

parts 84:7 176:15

177:12 245:9

255:22 256:4

partway 162:15

party 81:1 87:11

95:13 177:3

226:10 249:9

250:12

pass 66:9 74:17

passes 256:10

pathway 160:3

171:6

patiently 121:3

196:22

Paul 2:8 3:20 18:15

59:16 71:8 175:3

175:4 193:4 195:6

224:15 227:6,18

233:1 240:3

242:16

pay 227:2

payback 42:9

penalties 173:8

people 5:15 7:18

15:20 78:17 88:3

121:2 139:17

140:16 196:21

197:8,12 216:18

244:16 250:19

percent 15:21 18:8

27:6 72:17,18

79:11,11,12,17,18

80:1,2,3,5 81:3

82:10,12,12,15,20

82:22 83:3,7,9,10

83:14,15,16,16

85:7 86:7,15,16

87:5,11,12,12,13

87:18 89:17,21

91:10,11,14,14

92:9,15,16,17,21

96:3 99:6,7,7

100:11,12,14,15

100:16,20,22

101:3,5,5,11

102:9 114:5

115:19 127:19

128:11 130:8

140:7 150:16

151:19 185:18,20

186:9,13,20,21,22

187:14 190:20,21

191:1,4,5,22

192:6 194:3

195:20,21,21

196:1,1,10,11,13

196:15 200:1,9,21

201:7,12 202:20

204:4,6 205:6

206:10 207:5

210:1,21 211:6,10

212:1,2,12,14

213:1,1 236:2

253:4,6 260:12

percentage 86:22

171:12

percentages 83:14

99:16,20

percentile 203:2

performance 17:6

19:3,5 30:11

43:15 60:16 81:6

82:17,20 139:16

157:11 158:8

228:16

performed 201:16

202:2

period 64:22

171:13 232:17

239:20 262:4

periodic 167:22

169:1 172:11

181:5

permit 23:6 224:2

permutation 66:9

permutations

14:10 63:22

person 5:10 218:6

227:1

personally 178:16

perspective 51:20

138:6 139:12

205:16 217:1

259:1

pertaining 76:1

Petrosino 121:4,7,9

122:7 123:2 124:1

phase 250:10

259:14

PhD 2:2,6,7,15

phone 5:12 75:18

78:12 99:22 101:9

121:2 128:19

141:9 143:3

196:21 198:21

219:21 250:20

physical 71:13

261:4

physics 137:15

142:4 152:15

176:13

physics-based

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pick 204:8

picking 83:15

114:11

picture 67:21 122:9

piece 67:18 94:11

94:18 200:2,15

pieces 67:10 218:11

piston 80:5

pit 125:1

place 13:17 84:13

88:3 132:15 178:4

197:11 204:2

places 243:14

plan 10:13 34:12

planning 34:11

plans 222:4

plausible 106:12
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players 179:6,6,10

playing 31:15

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Plenty 190:8

plug 175:18 209:20

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24:8 27:18 32:4

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112:2,4 115:8,12

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136:22 137:19

140:11 155:16

158:15 163:6

167:10 170:9

182:3,11 188:14

188:18 189:6

208:12 209:18,22

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237:10,11 241:3

pointed 101:6

pointing 61:13

points 161:12

230:6

policing 177:22

178:2

policy 90:13

polyphase 47:5

136:2,15

popular 126:6

144:2,10

populating 249:20

population 200:20

portion 243:17,18

posed 199:17

position 168:16

226:16

positive 261:14

possibility 66:8

202:4 232:16

250:3

possible 146:20

203:22 257:9

possibly 26:22

156:1 159:9 168:6

174:11 188:15

197:15 204:5

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postponed 12:15

potential 54:21

90:11 124:22

184:18,21 230:14

potentially 95:20

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power 46:7 243:15

practical 50:11

65:9 68:14

practice 224:14

preapproval 28:8

28:16 34:15 49:9

49:12,13,16 50:2

50:9,21

preapprove 35:16

49:10

preclude 21:19

preconceived 155:5

predict 19:3 22:16

157:10

predictability

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predicts 21:10

158:8

preliminary 61:7

premise 61:16

148:11,17 149:2

premium 134:21

135:8,13

preparing 84:8

85:8

prequalify/preap...

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prerogative 158:3

present 2:1 9:22

10:16 46:9 47:14

70:6 85:4 105:13

218:13 247:5

254:2,8

presentation 9:18

13:5 16:7 23:10

presented 250:14

251:4

presenter 9:21

presently 70:14

100:8,18 105:12

105:15

presiding 1:16

pressure 14:22

pretty 43:12 55:5

78:11 166:4 174:2

209:4

previous 100:4

102:11 144:14

previously 127:18

226:16 256:8

price 15:22

primarily 20:2

primary 144:3

prior 194:15

254:19

priority 147:1

probably 53:16

56:11 82:21 94:9

157:14 163:5,18

166:22 169:10

175:6 195:8 242:7

242:12 261:5,19

problem 19:21

25:6 47:1 49:21

58:17 66:7 112:9

114:1 142:7

161:13 192:17

216:3 219:15

222:22 223:4

problems 174:19

261:22

procedural 23:18

procedurally 29:7

procedure 21:14

30:6 55:21 56:1

58:13 85:4 86:1,2

102:19,20 105:20

119:6,7,11,13,15

120:13,16 203:14

217:8 226:22

237:15 238:2,6,13

239:5,6,7 240:18

240:19 241:1,4,13

241:21 242:14

243:3 247:7,15

procedures 16:20

27:9 36:4 98:19

120:2 126:15

183:1 189:2 217:3

238:4 245:3

259:10

proceed 207:9,10

process 28:16 46:3

46:6 67:3,4,12

116:17 147:15

188:15 189:14,15

190:7 195:9

202:14 205:14,19

206:1 210:13

223:19 224:9

236:11,12 245:1

processes 43:17

203:14 206:13,15

produce 236:21

producing 236:18

product 16:3,5

17:9 27:3 37:17

37:21 38:4,6,12

38:15 42:14 43:3

43:8,19 44:3

45:17 46:5,8,13

46:14,19,21 47:4

47:11,13,20 48:3

56:10,12,14 60:14

60:15,20 61:4,10

61:21 62:4,13,14

62:21,21 63:5,19

63:22 64:4,19,20

65:11 70:9,11

71:1 73:11 74:14

78:19 79:12 89:3

89:15 101:20,21

102:1,8 107:8,12

107:16 108:2,14

108:17 109:8

110:3,5,6 114:12

114:18 117:7

118:13 122:19,22

123:4,5,10,12,12

123:13,16,18

124:17 126:16

129:13,17 130:15

130:16,17 133:15

145:2 147:18

148:3,5,12,14

151:13 152:17

156:1,7 159:8,12

161:4,20 168:2

171:19 174:14

176:12,13 178:1,6

184:13 185:22

189:3 192:9 194:5

198:6,7 202:19

203:8 204:12

207:3 220:20

233:3 238:10,15

239:19 246:10

251:21

production 54:18

55:9 69:10 126:1

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production-line

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158:7 172:18

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product-by-prod...

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program 1:3,16

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programs 17:5,13

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prohibit 139:20

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project 2:7 8:10

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promulgated 57:16

prop 80:6

proper 127:3

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properly 70:16

119:12 161:14

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proposal 9:14

10:17 24:2 30:18

30:21 50:10 57:7

62:1,17 77:3

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133:14 156:16

162:14 167:11

169:14 190:4

215:12 234:7

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proposals 35:2

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propose 182:6

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proposed 1:5 5:7

10:21 11:12 24:1

24:17,22 25:9

27:13 36:1 51:2

55:12 84:19

100:20 166:14

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proposing 24:4,7,9

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123:9 149:16

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protest 151:13

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protocol 248:1

proven 194:21

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proves 91:11

provide 10:18

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149:10 207:19

235:2,18

provided 227:15

providing 67:5

76:14 154:21

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provision 69:3

provisions 25:2,4

37:10 123:8 155:3

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psychrometers

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public 1:5,11 5:6

9:12 10:19 30:15

90:15 222:12,13

223:17 225:18

226:17 227:1

229:10,19 230:12

publication 21:1

publicly 226:15,20

publish 91:15

92:19

published 45:21

84:6 220:5

pull 204:21

pulled 189:10

pump 26:7 48:19

57:2 73:17 113:17

161:7 193:8

227:12

pumps 23:12 24:12

45:2 51:12 73:14

113:14,15 163:3,4

243:8

purchased 226:10

purely 252:16

purpose 9:12 10:15

13:20 223:6 225:9

230:7

purposes 76:17

106:9 166:18

210:10

pushed 35:5

pushing 74:8 82:22

86:15

put 10:8 13:17

16:15 37:20 63:7

66:5 69:10 82:14

112:9 127:13

132:1 134:16

135:1 137:15,16

140:6,21 141:16

141:17,21 142:1

145:22 146:15

159:1 192:13

195:22 197:17

211:10 213:7,17

216:12 218:19

237:17 245:18

258:11 259:9

puts 69:3 150:5

putting 171:19

176:14 230:7

P-R-O-C-E-E-D-...

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p.m 164:8,9 166:2

262:10

Q

QC 171:20,22

qualifications

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qualified 26:15

qualify 241:11

quality 259:22

question 20:4

24:15 29:17 31:19

34:7 36:10 41:12

51:13 55:6 56:8

56:22 57:12 64:5

66:1,1 67:13 69:8

73:8 76:1 78:5

84:5 99:4 101:8

101:10 110:12,14

116:13,18 121:10

123:3 124:6 143:8

143:14,15 144:12

151:11 153:18,19

154:10,19 159:18

159:21 161:3

168:21,21 170:8

170:10,18 171:2

185:16 199:16

202:9 208:11

210:17 213:16

218:10 219:20

220:17 221:12,18

228:19 236:4

237:19 238:19

239:4,10 241:16

245:20 248:13

249:1 251:7 253:2

questioning 191:14

questions 4:7,10,13

4:16 9:15 20:9

33:4 34:19 56:8

58:6 75:17 76:21

79:4 99:22 103:4

143:9 145:18

156:18 232:2

237:18 248:11

262:6

quick 119:3 138:3

218:10

quicker 35:6

quickly 48:1

quite 21:3 33:12

35:15,17 83:3

115:22 148:8

178:19 260:14

quote 152:9

R

raise 5:17 11:17

170:8 216:20

raised 131:18

raises 34:19 135:14

raising 18:11 216:6

ramifications

209:2

ran 129:2

Rand 2:18 6:21 7:1

33:3 50:20 73:13

79:22 80:19 95:7

137:3 158:6

186:19

random 145:7

randomly 147:4

randomly-selected

127:1

range 61:20 62:13

86:3 87:18 90:5,8

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stuff 32:19 146:17

209:8 213:11,11

226:2

subcategory 104:2

subclass 53:6

subcommittee

81:17

subject 171:17

222:3

submit 10:20 35:19

52:12 181:20

submitting 60:19

Subpart 206:16

subroutines 158:12

subsequent 32:11

166:10,16 167:2

169:16 181:1,7

182:15

subsequently

122:13 205:4

subset 19:9 33:13

167:5

substantial 82:2

85:16 101:6 238:5

substantiate 32:11

32:22 33:18 36:3

46:2 58:14,16

59:3 72:2,6 77:20

99:19 106:4 111:2

133:10,22 134:5

141:1 144:12

148:2 154:3 156:5

161:12 231:19

237:16

substantiated

33:19 92:4 126:2

131:11 134:6,18

139:2 243:18

substantiates 92:18

substantiating 85:6

114:15

substantiation 4:8

62:15 70:19 71:1

73:2 75:8,16

76:18 79:5 101:18

102:16 106:17

119:5,10 122:2,5

126:10,20 127:4

127:11 150:17

166:10,20 167:20

180:10 181:1

182:19 185:5

192:20 219:7,12

231:21 233:17

252:8,15,16

substantive 238:14

243:2

subsystems 81:15

Subway 164:3

166:5

succeed 156:11

suction 228:15

sudden 209:22

suddenly 142:14

153:7

sufficient 232:15

suggest 53:11

97:15 125:20

suggested 242:8

suggestion 18:18

65:20 121:21

122:1,7

suggestions 75:5

78:3 234:22 236:5

suggests 61:3

summarized 251:3

summer 250:19

supervise 194:17

super-insulated

64:9

supplemental 17:9

supply 82:18

support 18:17

49:12,13,15 50:2

50:14,21 62:22

63:2 90:18 91:1

149:21 161:16

175:12 176:9

178:12 179:12

182:18 212:7

supported 71:13

201:12 202:11

supporting 182:13

supports 32:13

86:18 97:21

181:10

supposed 37:10

60:17 191:17

198:8

sure 11:9 12:19

13:5 15:6 16:7

18:2,14 21:3

25:13 30:4 35:8

43:22 50:15 57:10

60:5,7 61:6 63:15

66:6 69:6,15

72:10 73:9 76:22

78:11 79:1 88:13

90:19,19 91:6

95:21 103:5

104:12 106:16

107:4,5 108:11

113:2,6,6 114:5,9

115:15 123:3

124:15,20 129:13

137:21 138:22

140:12 148:10,16

150:14 159:13

161:22 162:19

168:4 169:11

170:4 173:14

175:14 178:1

179:21 180:8

188:10 190:15

196:10 197:12

200:11 204:17

209:9 213:12

217:19 218:3

219:5,13,21

226:22 229:17

232:4 237:20

244:4 252:20

261:12,17

surface 152:11

surprising 87:1

surrounded 55:17

SW 1:13

swap 111:18

swing 195:20

switch 46:4 111:5

196:20

synch 244:18

synonymous 56:16

130:18 237:11

system 57:2,6,20

58:4 76:11 153:6

153:10 220:18

systems 26:8 36:12

51:7 59:18 60:12

76:18 94:20

system's 57:4

S-E-S-S-I-O-N

166:1

T

table 40:14 44:9

49:3 114:6 182:2

249:17

tables 43:1,19

tailored 157:15

take 21:5 22:6 64:1

73:5 75:7 86:1

91:8 109:16

125:11 140:19

142:18 144:18

162:17,17 190:21

195:10,20 204:20

206:9 209:17,21

214:8,21 228:12

230:10 233:4

240:17 261:3

taken 18:9 41:6

199:18 226:16

243:11

takes 80:2 232:11

talk 5:17 10:14

21:12,14 32:17

53:19 75:8 78:11

101:17 120:1

178:14 199:12

204:19 206:22

207:13 208:19,22

213:13 224:17

241:2

talked 61:15 76:2

127:17 167:6

182:4 183:3

194:15 219:7

talking 13:17 39:21

40:12,13 52:16

53:20 112:8

116:11 117:1

120:7 157:13

172:18 176:12

178:1 180:15,19

183:19 194:20

196:3 199:8,13

201:7 206:19

208:7 230:14

250:22 255:12

tank 63:21 64:9

136:18

tankless 63:21

136:20

target 119:7,8,18

120:9,10 124:19

151:19
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taxpayers 225:19

tear 229:16

technically 134:6

technique 221:20

technologies 140:2

technology 1:3,16

131:20 132:9

134:14 135:4

137:17,21 138:7,9

138:13,14 140:10

156:6 157:2 241:2

tell 9:20 13:13

35:12 85:22

216:10,11,17

telling 47:12

temperature 86:5

228:15

temperatures 86:4

200:1

ten 127:22 239:9

tend 82:16

ten-week 261:2

term 24:7,9 42:14

42:17 45:18 247:7

248:5

terminology 56:19

terms 24:4 32:21

34:22 56:11,16

62:5 74:1 81:12

122:18 125:1

135:21 145:10

159:16 172:19

182:5

test 20:18 21:14

22:7,22 27:9

28:11 29:21 30:6

30:14 32:7,10

33:21 36:4 37:7

37:13 38:14 39:1

41:13,14 46:20

47:12,14 52:8,15

55:21 56:1 57:15

57:17,18,19,21

58:15 67:19,20

68:1 71:12,13

78:1 81:3,7,8 86:2

87:11 89:20 91:9

91:22 95:8 96:18

97:3,7,12 98:9,12

98:20 101:19,22

102:2,6,10,14,15

102:19,20 103:13

103:16,22 104:5,8

104:8 105:10,12

105:14,20 106:3

106:10,14 109:14

109:20,22 111:4

111:21 113:16,20

115:12,15 117:20

118:3,10,12,14

119:4,6,10,14,15

120:2,13,16

121:12 122:21

126:15 127:16,18

128:3,6,9 129:10

130:2,4,7,11

132:10 133:3,11

135:5 142:21

144:20 149:10

152:4 154:1,16

155:6 156:5

157:22 158:13

159:7,11 169:7

176:1 182:13

183:1 184:11,18

184:20 185:2

186:1,3,3,20

187:6,7,11,14,16

190:6,7,9 191:14

194:19 195:19,22

196:3,17 199:19

199:20,21 200:3,8

202:10,12 205:4

205:13 206:9,20

209:14,18,22

210:19 213:15

214:21 215:4,17

216:10,12,13,18

216:19,20 217:1,2

217:7,8,12,15,20

218:4 220:9 221:2

221:8,10 222:1,5

224:17 225:3,5,10

225:12 226:4,9,12

226:14,16,22

227:2,3,4 228:13

228:20 229:7,16

229:18 230:3,6,7

230:16 237:14

238:2,3,5,13

239:6,7 240:18,19

241:1,3,12,21

242:20 244:6,19

245:3 247:4,5,7

247:14 252:1,8,15

256:10 259:10

260:3

tested 19:11 22:5

27:3,4,8 28:2

33:21 36:4 41:9

57:5,7 64:20

79:17 96:18

102:18,22 123:6

126:22 132:22

133:7 134:7

143:18 175:22

198:6 200:15

202:5 203:12

206:2 209:10

211:1 216:11

217:6 222:2

227:19 231:1,16

251:22

testing 4:11 13:20

14:21 19:6,9

20:18 22:17,20

29:12 33:1,6,9,13

33:14,18 34:10,13

34:16,22,22 36:2

36:16 37:1 38:5

41:5 42:2,4 46:21

49:19 52:5,17

60:22 65:10 66:1

67:1 70:10 72:15

82:11 87:15 88:20

89:9 95:8,13

96:22 97:1,4,13

98:20 105:2,16

106:4 112:19

113:3 116:12,18

117:4 119:11,13

121:12 129:11

134:19 146:21

151:3 152:14

153:9 155:3

159:10 160:1,8,11

160:13,16 166:7

166:13,15,22

167:4 173:18

174:13,19 175:21

176:5,7,8 180:11

180:12,15,16,20

181:7 183:7 184:6

184:9 185:3,4,12

188:16,16 194:14

194:18 199:18

200:17 201:1,3,5

201:9,11,16,18

202:2 204:8,19,22

205:9,12 207:9,11

207:20 208:14

209:14,16 210:10

210:11,22 211:7

211:20 212:7,13

214:19 215:2

216:5,16 221:15

224:20 225:16

226:11 230:15,20

231:5,7 232:20

237:3,4,10 243:3

248:1 252:9,17

256:13 259:5,16

259:18,19,22

260:4,6 261:4

tests 71:14 74:16

87:18 92:11,14,15

95:8,9,10,14

107:12 109:17

127:22 133:9,17

148:1 152:16

174:1,3 185:13

189:2 190:3

196:14,18 204:21

213:18 227:13,16

247:6 251:18,20

253:4 261:3

text 21:7,13 60:6

96:7 242:9 256:1

thank 11:12 12:18

13:2,8,22 15:10

15:12,17 16:1

17:17 18:12,20

19:15 20:5,6 23:3

30:19 37:17 42:11

50:22 60:4 61:13

68:15 69:5 71:4,5

79:1 90:20 98:1

101:7 104:11

107:3,4 119:20

125:7,17 130:21

130:22 141:7

142:22 143:10

149:14,20 150:2

161:18 163:7

173:13 175:13

177:17 179:21

198:20 200:10

211:13 230:9

235:4 244:3

252:19 253:7

254:6 256:19,21

257:15 258:1,14

260:18,19 262:2,9

Thanks 17:20

45:13 52:22 79:2

143:13 145:14

198:19 251:16

258:19

theirs 151:20

theoretical 117:9

147:12

theory 118:7

thermal 109:11,20

109:22 111:8,12

111:15

thick 174:16

thing 31:8 40:1

56:19 72:20 74:10

77:5 94:15 96:13

99:11 116:22

127:5,6 128:11

137:18 150:10

161:2 162:22

171:8 174:8

187:15 194:11
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201:7 204:16

205:8 206:5 208:5

208:13 211:3,17

217:12 230:21

236:8 237:2 244:2

245:17 246:18

250:1 261:14

things 16:10 36:7

40:15 54:12,17

71:2 80:7 81:14

81:20 82:9,9,13

83:17 84:10 86:22

87:2,6,8 120:6,20

124:9 126:7 127:7

143:3 159:1

161:13 183:5

187:19 189:7

190:11 197:13,14

198:17 206:3

207:14 215:22

217:22 218:13

222:2 246:6

think 14:5 16:4

20:7 25:22 26:13

30:19 31:7,18

32:16 34:20 35:3

35:21 36:14,18

37:3 38:15 42:20

49:15 50:14 54:17

55:5,8,15 66:10

69:19 73:10 74:13

74:15 78:16 80:16

81:2 83:6,12,17

83:19 84:3,4

87:11,12 94:14

95:18 99:13 104:9

105:3 106:7

110:17 112:6

113:22 114:8

115:6 122:11,15

124:16,18 125:10

126:18 127:4,10

127:12 128:9

135:22 136:21

137:4,19 139:15

139:17 140:17

144:15 146:6

149:2 153:22

154:7,13 156:12

156:15 157:8

160:4 162:13

171:9,15 172:17

172:19 173:6

175:6 180:2

182:18 183:3

187:15 195:8

196:9 197:9

198:11 204:1

209:6 219:8 220:8

221:22 223:5,16

224:22 229:10

230:3 232:14

235:3,11 236:3,19

237:1,12 238:11

238:13 239:15

240:8,12 242:8,14

243:10 244:10

245:12,16 247:3

248:12 250:16

260:13 261:14,18

thinking 17:12

120:6 125:3 156:9

160:8 175:9

235:12

third 80:22 87:10

95:12 123:13

218:14 250:12

third-party 95:10

160:8,10 176:2

177:4 195:19

215:13,14 237:9

249:2

Thirty 262:4

thirty-five 44:13

thought 20:1 34:5

62:10 147:14

186:10 206:17

207:21 221:4

thousand 67:2

thousands 14:11

235:21

three 28:1,11 72:5

79:10 80:3 103:22

124:11 133:5,11

133:12 163:16

169:19 214:3

236:16 244:10,10

259:13

three-phase 45:8

thresholds 69:4

throw 190:22

191:10 192:1

throwing 236:15

259:6

ticket 15:22

tied 122:19

tight 87:12

tightening 97:19

tightly 152:21

time 5:14 6:5 11:2

13:4 15:18,18

18:1,9 25:10,11

25:17 29:20 36:5

46:20 49:20 71:17

82:21 83:4,19

103:18 119:17

122:2,4,12 127:15

134:9 142:12

143:9 166:13,22

169:7,12,18

179:18 182:12

184:9 196:17

212:6 214:4

232:10,17 238:8

240:17 245:6

248:8 258:4,22

259:9 260:16

261:3

timeframe 25:16

timeline 257:8

times 218:1 236:11

236:16 237:8

244:14 260:13

261:2

timing 143:16

timing-wise 138:14

title 59:11 96:4

today 9:21 10:14

15:11,21 24:20

25:7,8 26:15 27:2

33:5 38:12 52:15

86:2 87:21 102:6

151:2 176:20

177:9 187:22

211:3 222:19

226:20 229:14

249:16 250:2

253:13 262:2

today's 10:15

121:17

told 26:13 238:22

tolerance 80:1 83:3

85:6,10,12,16

87:3 97:1,18

100:6,9,17,21

101:4 124:8

127:13,17 128:2,3

128:9 186:13

201:5 211:16,22

tolerances 23:20

27:11 59:1,1

63:10 76:11 79:7

79:10,14 83:13

88:9,10,14,15

96:10 97:12 98:20

101:15 150:14

169:4,5 176:7

201:21 212:1

Tom 121:4

tomorrow 12:3

tons 44:14 73:19

113:11 209:8

tool 126:3,11,14

157:14 158:8,22

tools 19:1 157:8,10

163:1

top 82:14 108:6

111:9 117:7

219:22

topic 51:1 183:15

230:12 260:13

topics 23:22

total 85:7,14 97:18

100:7,9 101:1

135:8 200:20

202:20 253:22

254:4

totally 22:8 41:2

53:20 126:16

174:8 203:2 230:2

touched 139:3,5

243:20

tough 175:2 259:13

to-facility 196:8

to-order 231:3

traditional 114:2

traditionally

113:11 155:14

trained 94:17

Trane 2:10 6:21,22

44:7 107:6 162:21

173:4

transfer 140:19

transformer

143:21 259:20

transformers 23:8

51:10 102:4 105:3

105:6 124:2

247:20 259:14

translate 135:20

transparency

225:17

treat 30:12

treated 96:14

treating 32:3

trees 82:5

tremendous 195:4

tried 57:22 64:13

112:14,15

trigger 210:22

triggered 245:1

trillions 14:12

trip 262:8

trivial 150:10

trouble 15:13

160:18 175:19

true 2:10 7:14

40:20 85:18 105:4

168:18 173:16

194:18

try 5:13 82:5 85:2

103:9 110:18

135:20 145:19

156:16 188:10

197:12 203:15
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trying 15:13 21:21

22:3,8 34:4 73:12

105:21 112:18

115:1,6 116:3

118:9 131:7

138:21 147:7

177:10 199:9

210:5

Tucker 2:17 9:5,5

TUESDAY 1:8

tune 127:21

turn 11:3 52:19

63:18 154:19

174:11 198:22

215:16 238:19

turns 235:14

tweak 111:12 217:4

tweaking 93:18

tweaks 27:15,16,17

twenty 127:22

twice 152:7,10

two 28:5,11 33:4

67:10,20 68:1

74:3 75:17 79:10

107:20 130:9

133:6,9 143:3

147:18 148:2,12

148:18 149:3

154:5,15,16,22

155:7 159:9 161:4

161:6 163:16,19

163:19,20 167:8

169:2 174:1

180:22 193:15

200:7 206:11

240:13 252:9,17

255:3 258:21

260:12

two-tenths 48:2

type 20:19 21:8

38:2 44:18 46:17

51:19 52:2 59:9

59:22 73:11 74:10

79:12 94:2 98:17

99:15,18 138:19

168:3 169:1,11

177:11 244:2

types 23:16 36:7

43:14 51:3,15

55:22 56:3,3

133:15 179:18

246:10

typically 55:8

159:7 201:17

T-distribution

203:2

T-value 18:8

U

Uh-huh 28:3 48:17

183:18

UL 177:3 198:14

unable 260:3

unbelievable

151:11

uncalled 178:17

uncertainty 86:15

145:13

unclear 123:6

uncontrollable

215:13

uncontrolled 215:9

underlying 30:14

32:5 33:1 54:16

102:16 133:17

166:19 182:11

undermining 104:7

underneath 14:9

understand 9:14

21:22 25:22 26:5

89:18 110:13

114:5,7 123:3

128:15 129:14

139:15 147:14,19

174:7,9 205:16

210:5 219:6 226:1

248:5 255:13

258:3

understanding

108:15 112:22

136:11 138:7

188:11

understood 91:9

147:14

undertake 230:18

Unfortunately

40:22

Unico 3:22 19:17

75:22 199:5

unidentified 215:8

215:12

unique 44:5 54:6

66:16,21 173:1

unit 27:3 37:7,11

67:21 68:4,5

77:10,13,19,22

78:1 79:17 81:2,5

86:8 115:11

121:17 123:5

139:19,20 140:10

145:8 152:7,14

161:5 184:11,20

185:7 188:16

189:10,12 190:16

190:22 191:1,6,9

191:10,12,16

192:4,6 193:7,7

193:15,17,21,22

195:9,20 198:13

199:18 200:19

201:19 202:5

204:5,8,21 206:18

210:3,20 211:1

213:15 214:20

218:2 226:10

227:2 228:12,13

229:22 230:22

231:1,10 232:9

248:15,16,17,19

249:5,10 252:1

unitary 80:13

232:9

UNITED 1:1

units 26:16,16 28:1

28:5 48:2,19

53:21 67:20 68:12

71:12 72:6 91:9

101:18 104:15

105:2 111:3 113:4

130:9 154:16

157:21 163:9

169:6 190:18,19

191:4,20 192:1

201:6 206:20

207:19,22 209:10

229:15,18 259:5,8

260:1

unit-to-unit 86:7

unmute 5:20

128:19 143:5

258:17

unmuted 100:2

128:20

unrealistic 259:2

untested 29:1 65:8

unusual 152:3

156:10

upcoming 183:15

243:7

updated 182:8

updating 183:7

upfront 74:16

upgrade 173:10

upside 90:11

113:22

upwards 38:22

up-to-date 42:6

142:19

use 17:6,16 19:4,7

21:17 23:6,12,17

24:5,7,10 25:3

28:2 29:19 41:20

49:11 51:3,8

54:18 56:12 61:20

62:10,12 64:18

65:8,13 72:1,6

76:16 89:11 92:3

97:18 104:17

110:2,5,22 111:11

111:12,15,21

112:3 115:9 116:9

118:2 133:20

134:8 155:11

156:19 157:14

158:22 159:1

161:5 181:2

182:19 184:16

206:1 212:12

215:14 234:7,13

241:22 242:1

useful 78:16,18

uses 109:8

usually 43:12,15

114:14 134:7

239:8

utilize 60:12

U.S 6:9 229:20

V

vague 211:4

valid 72:13 121:16

126:3,13 169:12

186:3,3 217:20

validate 37:14

108:17 112:5

127:20 142:12

196:16 251:20

validates 91:21

validating 92:1

108:16

validation 4:14

170:13 180:11

182:5 220:17

validity 29:21

174:5 199:17,18

value 89:8,10,13,13

200:18,22

values 85:17

variability 81:12

87:1 94:2

variable 157:4

variables 153:7,11

variable-speed

140:3 227:11,13

variation 80:9,13

82:10,15 86:7

201:2,13,14,15

202:7,12 216:14

variations 80:7

variety 21:18 23:21

172:18 190:10

various 69:21

76:15 97:11

250:19
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vary 79:12

vast 152:17

vending 51:6

vendors 87:4

verification 32:12

35:1 95:19 125:22

126:1,20 153:13

160:15 166:12,16

167:3,4,22 168:8

169:2,16 172:11

175:10,12 177:1

180:10,12 181:2,5

181:21 182:16

197:5,18

verifications 177:6

verified 170:15

171:13

verify 168:14

197:20

VerSHAW 2:18

6:20,20 33:2,2,17

34:1,4 36:8 50:20

73:7,10,12 79:21

79:22 80:18,18

86:9,10 95:6,6,15

137:2,2 139:9

158:5,5 160:7,12

186:16,18 187:2

187:20 188:4

195:16,16 206:6,6

206:17 207:16,21

208:3,16,17,20

209:1,12,19,21

210:6,15 235:5,6

235:17 243:6,6,22

248:22 249:1,13

version 105:15,16

120:8 248:1 254:8

versus 35:7 39:7

43:6,6,7,7 55:4

94:4 125:21,22

259:12,19 260:7

vertical 117:17

VICP 170:12,19

171:11 175:10

VICPs 170:10

view 41:19 68:20

68:22

views 251:3

violate 179:10

violating 179:9

voltage 87:9 144:4

voltages 200:5,7

volts 81:13 144:4

144:19

volume 33:7,15,21

57:5 102:8,11,13

107:17 118:16

121:18 122:3,4,19

122:22 123:11,14

123:18 124:10,17

124:19 125:2

131:8 134:10

137:12 145:1,2,11

146:1,6 148:20

158:14 174:4

volumes 54:18

voluntary 171:4

VRF 59:18 94:20

227:9

VRFs 59:22 227:19

W

wait 5:19 60:21

73:3 156:4 189:3

195:1

waiting 13:11

121:3 196:22

waiver 240:14,15

240:19 241:22

242:14

waivers 240:17

241:19

walk 57:14

walk-in 51:6 57:14

57:16 60:13

walk-ins 161:21

want 5:17 10:6

13:3 15:9 18:17

32:2 39:17 44:1

62:20 63:15 73:1

73:3 74:18 89:22

91:14 102:1 111:1

112:2,18 113:19

113:20 119:22

123:5 126:4,6

129:13 132:21

139:7 141:1,16

145:17 150:4

154:9 156:14

157:6,20 163:13

163:14 169:7

180:8 181:21,22

188:9 197:1

203:21 204:15

205:22 213:13,16

213:17 215:6

219:5,13,16 223:1

239:3 241:15,17

250:2

wanted 14:13 18:7

32:19 100:3 108:7

111:4,12,15 129:1

143:8

wanting 55:4 113:2

wants 11:7 153:16

168:22

warm 200:5

Washington 1:14

wasn't 18:9 139:10

221:10 243:16

256:2

waste 68:3

watch 194:22

216:13,18

water 11:15 23:7

42:16 43:5,9 45:5

48:21 51:9,22

53:19 63:20,20

64:9 136:19 249:5

250:7,8

water-cooled 45:4

163:2

water-source

113:14 163:3,4

water/steam

148:15

way 5:18 7:19 10:4

10:9 12:3,10

14:18 22:4,10

34:6 35:1 39:3,4

39:14 41:7 49:18

64:6 70:9 77:21

78:1 89:13 91:9

92:6 101:12 106:8

112:10 115:16,17

121:20 132:16

141:5 153:3 158:2

160:3,9 162:14

164:3,6 169:8,8

171:16 173:9

176:20 181:12

187:21,21 188:5

195:13 197:13

208:3 212:10

216:5 220:21

229:19 258:6

261:22

ways 75:5 124:21

140:16 169:2

webinar 5:11,14,19

10:11 11:7 15:12

website 98:3,8

229:11,20 254:9

weeks 109:16

weighting 167:7

welcome 5:6,9 11:3

55:14 61:3 75:5

78:4 166:3 232:15

232:21 236:7

262:5

well-defined 46:2

82:7 142:4

well-known 42:15

went 46:16 75:13

75:13 164:8,9

176:7 186:6 237:3

weren't 102:21

189:11

wet 81:21

We're 125:6 188:2

We've 214:4

whatnot 198:2

wheel 16:15

wheels 80:6

whichever 88:11

123:13

wide 21:17 61:20

62:12 93:10 94:1

116:5

widen 101:4

wider 36:20 55:13

wide-range 65:3

Wilkins 2:18 7:4,4

68:16,16 80:10,10

93:4,4 95:1 124:6

124:7 139:13,13

willful 234:10

235:8,12

window 196:17

wire 141:21

wise 57:8

wish 18:1 22:15

90:14

wondered 62:9

wondering 19:21

76:5

word 97:18 180:9

215:7

wording 191:15

242:18

words 64:16 72:4

104:2 119:13

171:11 184:20

185:4 241:20

work 80:19 81:16

86:11,17 118:4,7

120:3 135:3

136:15 156:16

180:5 191:2 195:5

195:13 232:18

233:9 249:22

workable 45:22

47:18

worked 134:21

173:17 238:22

240:15

working 39:19 65:6

69:21 86:12

105:11 132:15,17

135:1 176:21

181:12 201:4

221:22

works 31:6 65:15

110:18 222:4
202-234-4433

Neal R. Gross & Co., Inc.

Page 293

world 143:21

worms 151:10,16

worried 35:21

worries 216:14

worth 155:1

worthwhile 17:11

wouldn't 61:10

111:21 133:19

185:11 191:12

196:3 219:8

223:22 242:13

243:10

Wow 26:10

write 158:10

181:16

writes 250:14

writing 160:5

258:11

written 25:4 27:2

30:18 101:13

149:22 162:14

181:16 187:21

188:5 201:13

203:1 206:10

208:4 211:3

wrong 121:5

217:14 221:19

237:5

wrote 75:2

X

X 124:11 140:7

207:14

X-1 95:9

Y

year 13:12 23:15

41:9 53:17 60:18

66:22 67:11 68:12

102:11 116:10

121:13,14,14

123:20,20 144:14

146:7 206:11

yearly 122:11

years 29:7 39:20

41:17 46:21 65:7

69:20 81:14 83:19

87:16 124:11,11

169:19,20 178:3

214:4 236:17

239:9 244:10,13

yield 17:5

Z

Zealand 68:11

zero 2:14 3:19 7:12

18:3 50:7 65:4

86:20 119:2

159:14 160:6

162:12 180:1

196:19 260:21

Zone 2:14 3:19

7:13 18:4 50:8

65:5 86:20 119:2

159:14 162:12

180:1 260:21

1

1 47:7,12 79:11

100:20 116:18

165:1 182:10

236:1

1st 12:2,12 257:18

258:7

1.02 81:8

1.5 82:10

1:07 164:9 166:2

10 3:5 29:6 46:14

67:13 79:12 80:1

82:15 83:15,16

85:7 86:15 87:5

87:12 99:7 100:8

100:12,15,22

186:17 196:13

201:7 220:5,7,9

227:13

10th 117:2

10-year 153:11

10:13 75:13

10:30 75:10

10:34 75:14

100 14:7 41:3 82:22

114:5 117:13,13

117:20 129:2,6,6

129:22 130:5,11

1000 1:13

101 4:8 101:5

103 4:10

11 3:7 220:3,10

11-trillion-plus

249:19

112 22:7 97:7

105:11

12 3:8 30:9 144:10

12:01 164:8

120 259:3,12 261:1

122/40 144:4,19

1230 242:20

13 3:10 137:8,10

139:19,22 206:20

209:4

13s 137:11

135 44:10 125:13

14 3:11 137:10

139:19

1400 174:1,4

15 3:13 29:6 82:11

107:12 204:5

208:10

15-minute 75:7

15-ton 74:1

150-10 97:9

16 3:14,16 78:15

165 4:11

17 3:17

18 3:19,20 12:16

18:18 140:1

206:19 209:5

18-month 258:9

181 4:14

182 4:16

183 4:14

184 4:16

185 46:20

19 3:22

1950 139:2,9

1990s 96:19

1992 96:16 134:20

1999 45:21 131:5

132:5,16 135:2

2

2 44:20 81:3 87:18

91:13 92:21 165:2

196:1 200:4

260:11

2nd 262:5

2x2 158:9

2.5 234:19

2:40 262:10

20 4:3 29:6 38:12

67:13 108:5 111:4

117:14,18,21,21

119:4 129:3,7,11

129:14,22 130:3,4

173:21 174:3

200:21 201:12

200,000s 53:17

2004 105:15

2007 135:1

2009 58:12 121:12

2012 1:9

2013 12:2,12 258:7

2015 145:3,9

2016 144:9,22

21 117:22 118:1

129:10 130:11

174:4,4

22 137:8

229 4:14

23 4:4

231 4:16

233 4:15,17

236 4:15,17

24 4:7

24,000 70:5

24,014 46:19

240 44:14,14

25 14:9 27:6 102:9

105:2 115:19

130:8 144:3,18

25-ton 74:1

250 15:21

26 199:11

28 4:4 199:13

29 4:7

3

3 72:17 82:10 83:7

87:12 89:16,20

91:11 92:8,17

96:3 99:7 130:7

196:1 210:1 256:8

260:11

30 15:17 38:22 39:7

108:6 185:2

209:10 213:14

214:8,9,12 232:7

232:14 259:1,12

30-some 40:10

300 39:7

300,000 53:18

32041 20:22

32046 183:13

32055 37:5

32056 71:11 146:17

38 200:4

4

4 195:19

4th 84:9 255:19

41 21:4

429 58:19 70:21

89:3 177:11,16

206:16 254:8

429.41 254:9

429.7(C)(2) 37:6

429.70 58:22

429.70(c) 186:18,19

429.75 146:17

429.75(i) 96:7

431 46:3 58:12,18

59:5,12 70:6,14

97:14,17 100:9

142:9 177:15

201:14 204:1

431.12 253:18

431.442 253:17

431.445(b) 255:21

431.445(c)(2) 256:7

5

5 1:9 3:2 71:11

72:17 79:11,16,18

80:4 82:12 83:3,9

83:10,14,16 87:11

87:13 91:10,14

92:15,16 99:6
202-234-4433

Neal R. Gross & Co., Inc.

Page 294

101:12 127:19

150:16 151:19

185:18,19 186:9

186:13,20,21

190:20 191:1,4,5

191:11,13,22

196:10,11,15

204:3 209:7

210:21 211:6,10

212:1,2,12,14

5/minus 191:13

50 67:14 68:12

103:15 111:4

178:3 194:2

500 47:8,13 66:19

51 4:4

52 4:7

6

6 3:4 190:21 191:9

192:6 195:21

6-ton 115:10

60-plus 233:5

63 44:14 113:11

63-ton 113:16

65 44:10 125:12,13

125:13,13

65,000 44:10 45:7

69-ton 115:10

7

7 86:16 195:21

200:1,9 213:1

7th 58:12

700 173:21

72 46:8

7200 144:4,19

75 82:21

760,000 125:12,13

79 4:8,10 118:2

130:12

8

8 86:7 187:14 205:6

206:9 213:1

8E-089 1:12

9

9 220:4,7,10

9-10 53:21

9:00 1:14

9:01 5:2

90 253:5 261:5

90-day 232:10

90.1 244:22,22

90.1-2010 245:4,5

90.9 100:14 101:4

91.7 100:11 101:3

92.4 100:16

95 18:7 80:2 82:19

128:11 144:4,19

203:1 253:4

97 82:20

98 81:7

98.91 144:7

99 80:2 82:22 144:9
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

295

Alternate Efficiency

Determination Methods

US DOE

06-05-12

Washington, DC