UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

WORKSHOP ON ENERGY DESCRIPTOR/TEST

PROCEDURE

WEDNESDAY , OCTOBER . 18, 1995

The workshop was held in the Potomac Room

at the Holiday Inn, Eisenhower, 2460 Eisenhower

Avenue, Alexandria, Virginia 22314, at 8:30 a.m., Jack

Langmead, workshop moderator, presiding.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON . D.C. 20005 (202) 

EE-DET-94-101 COMMENT 0D

UNITED STATES OF AMERICA 

DEPARTMENT OF ENERGY 

WORKSHOP ON ENERGY DESCRIPTOR/TEST 

PROCEDURE 

WEDNESDAY, OCTOBER.18, 1995 , 

The workshop was held in the Potomac Room 

at the Holiday Inn, Eisenhower, 2460 Eisenhowe

Avenue, Alexandria, Virginia 22314, at 8:30 a.m., Jac

Langmead, workshop moderator, presiding. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
PRESENT:

(202) 234-4433

JACK LANGMEAD, Moderator

CARL ADAMS, DOE

KATHY EPPING, DOE

BRYAN BERRINGER, DOE

QONNIE LAUGHLIN, DOE

BILL HUI, DOE

ED POLLOCK, DOE

CYRUS NASSERI, DOE

MICHAEL McCABE, DOE

EUGENE MARGOLIS, DOE

CHRISTOPHER FREITAS, DOE

MIKE RAYMOND, DOE

GEORGE KELLY, NIST

JIM RANFONE, AGA

HARVEY SACHS, GeoThermal Heat Pump Consortium

MICHAEL PARAINO, GRI

JIM CRAWFORD, The Trane Co.

MIKE DARD, Canadian Standards Assoc.

RON FISKUM, DOE

ESHER KWELLER, DOE

CHARLES ADAMS, The Ducane Company

RICHARD STEYER, Howe, Skyer, and Anderson

CRAIG CHRISTIANSON, NREL

ANDY ANDERSON, State Industries, Inc.

MARK HAWKINS, State Industries, Inc.

MIKEL PISTOLE, Effikal International

TIM BEGOSKE, Effikal International

DONNA BANKS, AGA

JIM BURNES, Nordyne

R.L. DOUGLAS CANE, Caneta

MATT CHWALOWSKI, EEI

JIM CLARK, Natural Resources Canada

JEFFREY CRISAFULLI, Battelle

HENRY DeLIMA, DeLima Assoc.

DANIEL DEMPSEY, United Technologies Carrier

PIOTR DOMANSKI, NIST

BRIAN DOUGHERTY, NIST

CHARLES FRITTS, AGA

JEFF GEDCKE, Amana

WILBUR HAAG, A.O. Smith Water Products Compan

JIM HICKSON, Lennox

DARYL HOSLER, The Southern California Gas Co

FRANK JAKOB, Battelle

RONALD JARNAGIN, Pacific Northwest Laboratory

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

PRESENT: 

(202) 234-4433 

JACK LANGMEAD, Moderator 

CARL ADAMS, DOE 

KATHY EPPING, DOE 

BRYAN BERRINGER, DOE 

QONNIE LAUGHLIN, DOE 

BILL HUI, DOE 

ED POLLOCK, DOE 

CYRUS NASSERI, DOE 

MICHAEL McCABE, DOE 

EUGENE MARGOLIS, DOE 

CHRISTOPHER FREITAS, DOE 

MIKE RAYMOND, DOE 

GEORGE KELLY, NIST 

JIM RANFONE, AGA 

HARVEY SACHS, GeoThermal Heat Pump Consortium 

MICHAEL PARAINO, GRI 

JIM CRAWFORD, The Trane Co. 

MIKE DARD, Canadian Standards Assoc. 

RON FISKUM, DOE 

ESHER KWELLER, DOE 

CHARLES ADAMS, The Ducane Company 

RICHARD STEYER, Howe, Skyer, and Anderson 

CRAIG CHRISTIANSON, NREL 

ANDY ANDERSON, State Industries, Inc. 

MARK HAWKINS, State Industries, Inc. 

MIKEL PISTOLE, Effikal International 

TIM BEGOSKE, Effikal International 

DONNA BANKS, AGA 

JIM BURNES, Nordyrie 

R.L. DOUGLAS CANE, Caneta 

MATT CHWALOWSKI, EEl 

JIM CLARK, Natural Resources Canada 

JEFFREY CRISAFULLI, Battelle 

HENRY DeLIMA, DeLima Assoc. 

DANIEL DEMPSEY, United Technologies Carrier 

PIOTR DOMANSKI, NIST 

BRIAN DOUGHERTY, NIST 

CHARLES FRITTS, AGA 

JEFF GEDCKE, Amana 

WILBUR HAAG, A.O. Smith Water Products Compan

JIM HICKSON, Lennox 

DARYL HOSLER, The Southern California Gas Co

FRANK JAKOB, Battelle 

RONALD JARNAGIN, Pacific Northwest Laboratory 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
PRESENT: (cont.)

BERTRAM KALISCH, AGA

GEORGE KELLY, NIST

J.P. LANGMEAD, Consultant to Appliance

Manufacturer

NEIL LESLIE, GRI

DAVID LEWIS, Lennox

STAN LIU,NIST

JOHN MARRAN, Energy Kinetics

JOSEPH MATTINGLY, GAMA

JAMES MILLS, FTC

STEVE MINTON, Apollo

KENNETH MOSKWA, Weil-McLain

MARK PAQUETTE, Inchcape Testing Services

JOSEPH PIETSCH, Engineering Consultant

MARTIN PETCHUL, Columbia Gas

MICHAEL RIVEST

WILLIAM RYAN, GRI

JAMES SAWRUK, General Machine Corporation

SOUTIEL STANBOULY, York

FRANK STANONIK, GAMA

RICHARD SWEETSER, American Gas Cooling Center

MARGARET SUOZZO, ACEEE

WILLIAM THRASHER,AGA

JACOB VERDERBER, Rheem

JAMES VERSHAW, Trane

LAWRENCE WETHJE, ARI

BARRY WILHELM, Virginia Power

DAVID YOUNG, Ontario Hydro Technologies

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

PRESENT: (cont.) 

(202) 234-4433 

BERTRAM KALISCH, AGA 

GEORGE KELLY, NIST 

J.P. LANGMEAD, Consultant 

Manufacturer 

NEIL LESLIE, GRI 

DAVID LEWIS, Lennox 

STAN LIU, NIST 

JOHN MARRAN, Energy Kinetics 

JOSEPH MATTINGLY, GAMA 

JAMES MILLS, FTC 

STEVE MINTON, Apollo 

KENNETH MOSKWA, Weil-McLain 

to Applianc

MARK PAQUETTE, Inchcape Testing Services 

JOSEPH PIETSCH, Engineering Consultant 

MARTIN PETCHUL, Columbia Gas 

MICHAEL RIVEST 

WILLIAM RYAN, GRI 

JAMES SAWRUK, General Machine Corporation 

SOUTIEL STANBOULY, York 

FRANK STANONIK, GAMA 

RICHARD SWEETSER, American Gas Cooling Center 

MARGARET SUOZZO, ACEEE 

WILLIAM THRASHER, AGA 

JACOB VERDERBER, Rheem 

JAMES VERSHAW, Trane 

LAWRENCE WETHJE, ARI 

BARRY WILHELM, Virginia Power 

DAVID YOUNG, Ontario Hydro Technologies 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. ~.w. 

WASHINGTON. D.C. 20005 (202) 2
A-G-E-N-D-A

SPEAKER: PAGE NO

GEORGE KELLY, NIST

Furnace and Boiler Test Procedures 9

CYRUS NASSERI, DOE

Energy Descriptors 17

FRANK STANONIK, GAMA

Opening Remarks 28

JIM RANFONE, AGA

Opening Remarks 30

LAWRENCE WETHJE, ARI

Opening Remarks 33

CHARLIE FRITTS, AGA

Opening Remarks 35

OPEN DISCUSSION 36

ED POLLOCK, DOE

Multifunction Appliances 89

GEORGE KELLY, NIST

Fossil Fuel Heating Appliances 93

FRANK JAKOB, Battelle

Multi-Fuel Heat Pumps,

ANSI Z21.40.4 Standard Briefing 124

POINT BY POINT DISCUSSION 136

ED POLLOCK, DOE

International Test Procedures Briefing 187

CARL ADAMS, DOE

Closing Remarks 200

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON . D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

A-G-E-N-D-A 

SPEAKER: 

GEORGE KELLY, NIST 

Furnace and Boiler Test Procedures 

CYRUS NASSERI, DOE 

Energy Descriptors 

FRANK STANONIK, GAMA 

Opening Remarks 

JIM RANFONE, AGA 

Opening Remarks 

LAWRENCE WETHJE, ARI 

Opening Remarks 

CHARLIE FRITTS, AGA 

Opening Remarks 

OPEN DISCUSSION 

ED POLLOCK, DOE 

Multifunction Appliances 

GEORGE KELLY, NIST 

Fossil Fuel Heating Appliances 

FRANK JAKOB, Battelle 

Multi-Fuel Heat Pumps, 

ANSI Z21.40.4 Standard Briefing 

POINT BY POINT DISCUSSION 

ED POLLOCK, DOE 

International Test Procedures Briefing 

CARL ADAMS, DOE 

Closing Remarks 

(202) 234-4433 

NEAL R. GROSS 

. COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 

PAGE NO

9 

17 

28 

30 

33 

35 

36 

89 

93 

124 

136 

187 

200 

(202) 2
1

4

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

P-R-0-C-E-E-D-I-N-G-S

8:57 a.m

MR. ADAMS: Good morning everybody. M

name is Kathy Epping and I work for the Department o

Energy, Office of Codes and Standards Supplie

Division.

If you haven't signed-in, if you could d

so. There is name tags over there. There is agendas

if you haven't gotten a copy off the agenda. And

we're asking everybody to give us a business card. I

you don't have one, could you sign our sign-in sheet

As far as logistics go, there is variou

telephones throughout the hotel. There are some a

you enter the building. There' s some by the fron

desk . There is bathrooms, if you go out the ballroo

doors and make a right, they're on your left-han

side.

We're going to break for lunch at noon

There is a couple of restaurants. There is on

restaurant and a lounge here at the hotel. There i

a cafeteria over at the Hoffman Building across th

street. There is a deli a little ways down Eisenhowe

Avenue headed west . If you need better direction

than that, ask the front desk.

And to start us off we're going to hav

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

(202) 23444 33 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

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

2 8:57 a.m

3 MR. ADAMS: Good morning everybody. M

4 name is Kathy Epping and I work for the Department o

5 Energy, Office of Codes and Standards Supplie

6 Division. 

7 If you haven't signed in, if you could d

8 so. There is name tags over there. There is agendas

9 if you haven't gotten a copy off the agenda. An

10 we're asking everybody to give us a business card. I

11 you don't have one, could you sign our sign-in sheet

12 As far as logistics go, there is variou

13 telephones throughout the hotel. There are some a

14 you enter the building. There's some by the fron

15 desk. There is bathrooms, if you go out the ballroom 

16 doors and make a right, they're on your left-han

17 side. 

18 We're going to break for lunch at noon

19 There is a couple of restaurants. There is on

20 restaurant and a lounge here at the hotel. There i

21 a cafeteria over at the Hoffman Building across th

22 street. There is a deli a little ways down Eisenhow

23 Avenue headed west. If you need better direction

24 than that, ask the front desk. 

25 And to start us off we're going to hav

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 
1

3

4

5

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Carl Adams who is the Director of the Applianc

Division, the Appliance Standards Division, and he'

going to give the introductory remarks.

MR. ADAMS: Good morning and welcome t

the Department of Energy Workshop on Test Procedure

and Energy Efficiency Descriptors.

I must say I am delighted at the turnou

that we have here. When we first started kicking

around this idea some time ago, we talked with a few

people and we didn't think that we'd have this muc

interest. So we're glad to see everybody here. Th

facilities here may be stretched a bit for the numbe

of people, with microphones and so forth, but we hop

you' 11 bear with us and we' 11 do the best we can here.

Over the last several years of conductin

engineering analysis in support of rulemakings fo

energy efficiency standards and in processing waive

requests from the DOE test procedures determinin

energy efficiency for appliances, several issues hav

arisen regarding the testing and rating of certai

appliances.

You re getting another station?

MAN: Talk into the microphone.

MR. ADAMS: Is that any better?

CHORUS: Yes.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1 Carl Adams who is the Director of the Applianc

2 Division, the Appliance Standards Division, and he'

3 going to give the introductory remarks. 

4 MR. ADAMS: Good morning and welcome t

5 the Department of Energy Workshop on Test Procedure

6 and Energy Efficiency Descriptors. 

7 I must say I am delighted at the turnou

8 that we have here. When we first started kickin

9 around this idea some time ago, we talked with a fe

10 people and we didn't think that we'd have this muc

11 interest. So we're glad to see everybody here. Th

12 facilities here may be stretched a bit for the numbe

13 of people, with microphones and so forth, but we hop

14 you' 11 bear with us and we'll do the best we can here

15 Over the last several years of conductin

16 engineering analysis in support of rulemakings fo

17 energy efficiency standards and in processing waive

18 requests from the DOE test procedures determinin

19 energy efficiency for appliances, several issues hav

20 arisen regarding the testing and rating of certai

21 appliances. 

22 You're getting another station? 

23 

24 

25 

(202) 234-4433 

MAN: Talk into the microphone. 

MR. ADAMS: Is that any better? 

CHORUS: Yes. 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
2

3

4

5

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

MAN: is that a radio station coming

through there?

MAN: It sounds like a radio station to

me.

MAN: Well, somebody check with the hote

and see if they can turn that down.

MR. ADAMS : The Department of Energy is i

the process of developing a research agenda regardin

the resolution of these issues, among other items. A

part of this process we are encouraging public

discussions on various test procedures issues

Today's discussions should assist us establishing nex

year's research agenda for test procedure issues.

Today's workshop will focus on energy

efficiency descriptors and test procedures regardin

the energy consumption and efficiency of appliance

that combine more than one fuel source such a

furnaces, boilers, and multi-fuel heat pumps, and o

appliances that perform more than one function such a

space conditioning heat pumps which also heat water

Additionally, we would like to have discussions o

the pros and cons of using international tes

procedures and their associated energy efficienc

descriptors.

2511 The workshop will be divided into fou

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1 MAN: Is that a radio station comin

2 through there? 

3 MAN: It sounds like a radio station t

4 me. 

5 MAN: Well, somebody check with the hote

6 and see if they can turn that down. 

7 MR. ADAMS: The Department of Energy is i

8 the process of developing a research agenda regardin

9 the resolution of these issues, among other items. A

10 part of this process we are encouraging publi

11 discussions on various ~est procedur~s issues

12 Today' s discussions should assist us establishing nex

13 year's research agenda for test procedure issues. 

14 Today's workshop will focus on energ

15 efficiency descriptors and test procedures regardin

16 the energy consumption and efficiency of appliance

17 that combine more than one fuel source such a

18 furnaces, boilers, and multi-fuel heat pumps, and o

19 appliances that perform more than one function such a

20 space conditioning heat pumps which also heat water

21 Additionally, we would like to have discussions o

22 the pros and cons of uSing international tes

23 procedures and their associated energy efficienc

24 descriptors. 

25 The workshop will be divided into fou

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
2

3

4

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

consecutive sessions: energy efficiency descriptor

for multi-fuel appliances; energy efficienc

descriptors for multi-function appliances; tes

procedures and energy efficiency descriptors fo

multi-fuel heat pumps; and international tes

procedures. Each session will begin with one or tw

briefings to give some background information and t

start the discussion.

On your agenda you will'see a list o

possible discussion items for each topic. We wil

conduct each session as a forum with a moderator

Jack Langmead will be moderating the sessions and wil

be responsible for keeping the discussions on track

Jack worked at AGA Labs for 13 years, and the next 2

years at GAMA as the Vice President and Director o

Technical Services. He was also part of the industr

team that worked on the original NEACA legislation

He is now an independent consultant.

This workshop is not an evidentiar

hearing, but a transcript of the workshop will b

made. To assist the court reports, it would b

appreciated if throughout the day participants woul

identify themselves each time they speak. I know tha

gets hard to do and we forget to dot hat, but it doe

make the recorder's job easier. And also given th

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 

EE-DET-94-101 COMMENT 0D

1 consecutive sessions: energy efficiency descripto

2 for multi-fuel appliances; energy efficienc

3 descriptors for multi-function appliances; te

4 procedures and energy efficiency descriptors fo

5 mul ti-fuel heat pumps; and international te

6 procedures. Each session will begin with one or tw

7 briefings to give some background information and t

8 start the discussion. 

9 On your agenda you will· see a list o

10 possible discussion items for each topic. We wi

11 conduct each session as a forum with a moderato

12 Jack Langmead will be moderating the sessions and wi

13 be responsible for keeping the discussions on track

14 Jack worked at AGA Labs for 13 years, and the next 2

15 years at GAMA as the Vice President and Director o

16 Technical Services. He was also part of the industr

17 team that worked on the original NEACA l~gislation

18 He is now an independent consultant. 

19 This wOrkshop is not an evidentia

20 hearing, but a transcript of the workshop will b

21 made. To assist the court reports, it would 

22 appreciated if throughout the day participants wou

23 identify themselves each time they speak. I know th

24 gets hard to do and we forget to dot hat, but it do

25 make the recorder's job easier. And also given th

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 
3

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

number of people relative to the microphones that w

have, the recorder said, if everybody will speak up

he thinks that the mics will be sufficient, but i

not, if he's not getting the signal, he'll star

waving his arms, so keep your eye on him, if yo

would.

The transcript of the workshop will b

available for inspection and copy at the Department o

Energy Freedom of Information Reading Room in 1E-10

Forstal Building, Washington, D.C. between the hour

of 9:00 a.m. and 4:00 p.m. Anyone wishing to purchas

a copy of the transcript may make arrangements wit

the court reporter.

To commence the session on energ

efficiency descriptors for multi-fuel appliances

George Kelly of the. National Institute of Standard

and Technology, which is under contract to th

Department of Energy for the development of tes

procedures will present a briefing on the curren

furnace test procedures.

George?

MR. KELLY: Hello. Is this working?

MAN: It's working.

MR. KELLY: Okay. Nobody else can hea

2511 it. He can hear it. I'll just talk loud. I'm goin

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1 number of people relative to the microphones that w

2 have, the recorder said, if everybody will speak up

3 he thinks that the mics will be sufficient, but i

4 not, if he's not getting the signal, he'll star

5 waving his arms, so keep your eye on him, if yo

6 would. 

7 The transcript of the workshop will b

8 available for inspection and copy at the Department o

9 Energy Freedom of Information Reading Room in 1E-10

10 Forsta1 Building, Washington, D.C. between the hour

11 of 9:00 a.m. and 4:00 p.m. Anyone wishing to purchas

12 a copy of the transcript may make arrangements wit

13 the court reporter. 

14 To commence the ,session on energ

15 efficiency descriptors for multi-fuel appliances

16 George Kelly of the National Institute of Standard

17 and Technology, which is under contract to th

18 Department of Energy for the development of tes

19 procedures will present a briefing on the curren

20 furnace test procedures. 

21 George? 

22 MR. KELLY: Hello. Is this working? 

23 MAN: It's working. 

24 MR. KELLY: Okay. Nobody else can he

25 it. He can hear it. I'll just talk loud. I'm goin

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N,W. 

WASHINGTON. D.C. 20005 (202) 
1

2

3

4

6

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

to talk about the furnace boiler test procedure, okay

Now, there is a little bit of history to this thing

Whoever set this up never used -- thanks. I seem t

be having a problem with this. Thank you.

The"original furnace test procedure wa

promulgated in 1978, okay, for furnace and boilers

In 1982 ASHRAE came up with their own version of it

which was basically the same as the DOE version

following it very closely. And in '84 DOE publish

a revised Federal Register version of the furnace te

procedure which referenced the ASHRAE ANSI tes

procedure. In '88 ASHRAE again revised it -- chang

and waivers and stuff, so they revised it. And the

in 193 DOE proposed a new version of it in the Federa

Register which has not been finalized yet.

All right, is this one of those energ

saving things? It's a green light projector. Okay

a little flaky. And this one ended up referencing, a

the same time ASHRAE pushed a revised version of th

test procedure, this one now references the '93 one

and it was never finalized, that's one -- it wil

refer to the ASHRAE one, and they're pretty much th

same , a few minor changes here and there.

Back to the test procedure which is wha

we're really here. Certain assumptions are involved

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 

EE-DET-94-101 COMMENT 0D

1 to talk about the furnace bOiler test procedure, oka

2 Now, there is a little bit of history to this thing

3 Whoever set this up never used -- thanks. I seem 

4 be having a problem with this. Thank you. 

5 The'original furnace test procedure w

6 promulgated in 1978, okay, for furnace and boiler

7 In 1982 ASHRAE came up with their own version of it

8 which was basically the same as the DOE version

9 following it very closely. And in '84 DOE publishe

10 a revised Federal Register version of the furnace te

11 procedure which referenced the ASHRAE ANSI te

12 procedure. In '88 ASHRAE again revised it -- chang

13 and waivers and stuff, so they revised it. And the

14 in '93 DOE proposed a new version of it in the Feder

15 Register which has not been finalized yet. 

16 All right, is this one of those ener

17 saving things? It's a green light projector. Oka

18 a little flaky. And this one ended up referencing, 

19 the same time ASHRAE pushed a revised version of th

20 test procedure, this one now references the '93 on

21 and it was never finalized, that's one -- it wi

22 ref~r to the ASHRAE one, and they're pretty much t

23 same, a few minor changes here and there. 

24 Back to the test procedure which is wh

25 we're really here. Certain assumptions are involve

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NoW. 

WASHINGTON. D.C. 20005 {202) 
1

2

3

5

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

Furnaces and boilers are installed indoor, outdoor, o

isolating combustion. If installed indoors -- oh, I'

sorry, yes, there's no jacket loss. If it's isolatin

combustion or outdoor, then jacket losses ar

considered. There's no duct losses, there's no heat

gain from the chimney -- we're just simply considerin

appliance.

We're also considering how the dynami

operation of the appliance works over a heatin

season. And for those units that use indoor

combustion gear, the infiltration effect on th

building is also taken into account.

The procedure is based upon taking som

simplified measurements and then using a calculatio

procedure, I'll show the benefits of that in a minute,

basically you measure the steady state efficiency o

the furnace or boiler . You measure the steady stat

flue gas temperature and C02 concentration. Yo

obtain information on the shape of the flue gas

temperature of cool-down and heat-up curve, and ther

is some optional tracer gas test procedures for thing

like power burners.

You do have to assign some factors. Yo

either take a default value or measures and thing

like ratio of stack flow to flue flow , the ratio mas

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4

EE-DET-94-101 COMMENT 0D

1

1 Furnaces and boilers are installed indoor, outdoor, o

2 isolating combustion. If installed indoors -- oh, I'm 

3 sorry, yes, there's no jacket loss. If it's isolatin

4 combustion or outdoor, then jacket losses ar

5 considered. There's no duct losses, there's no hea

6 gain from the chimney we're just simply considerin

7 appliance. 

8 We're also considering how the dynami

9 operation of the appliance works over a heatin

10 season. And for those units that use indoo

11 combustion gear, the infiltration effect on th

12 building is also taken into account. 

13 The procedure is based upon taking som

14 simplified measurements and then using a calculatio

15 procedure, I'll show the benefits of that in a minute

16 basically you measure the steady state efficiency o

17 the furnace or boiler. You measure the steady stat

18 flue gas temperature and C02 concentration. Yo

19 obtain information on the shape of the flue gas

20 temperature of cool-down and heat-up curve, and ther

21 is some optional tracer gas test procedures for thing

22 like power burners. 

23 You do have to assign some factors. Yo

24 ei ther take a default value or measures and thing

25 like ratio of stack flow to flue flow, the ratio ma

(202) 234-4433 

NEAL R. GROSS 

COURT REPORT.ERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

5

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

flow during the off-period to the ratio during the on

period -- is a fraction of the combustion air relie

air and draft air which actually contributes t

additional infiltration on the resonance. Alphas an

over-sizing factors -- takes into account the effec

of the stack damper effectiveness, and there is 

tracer gas procedure you may use if you want, or yo

can take a default value.

So again basically steady stat

temperature and steady state C02 concentration give

you a steady state efficiency. You also measure th

flue, C02. concentration and the steady state flu

temperature. You have to -- you run the unit t

steady state and then you let it cool down, and durin

the cool-down period you measure the flue temperatur

at two points by -- equilibrium, slide it back out an

then measure the flue temperature again at, well

three point during the off-period, two points durin

the warm-up period. And the specific time is fille

out for the furnaces and boilers when you do thes

measurements.

This allows you to do a expediential fi

to the profile of a heat-up and cool-down curve

Basically theta endurance and steady state and th

actual temperatures -- by a function theta FO times 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202)23 4-4433 WASHINGTON. D.C. 20005 (202) 2344

EE-DET-94-101 COMMENT 0D

1

1 flow during the off-period to the ratio during the on

2 period -- is a fraction of the combustion air relie

3 air and draft air which actually contributes t

4 additional infiltration on the resonance. Alphas an

5 over-sizing factors -- takes into account the effec

6 of the stack damper effectiveness, and there is 

7 tracer gas procedure you may use if you want, or yo

8 can take a default value. 

9 So again basically steady stat

10 temperature and steady state C02 concentration give

11 you a steady state efficiency. You also measure th

12 flue, C02. concentration and the steady state flu

13 temperature. You have to - - you run the unit t

14 steady state and then you let it cool down, and durin

15 the cool-down period you measure the flue temperatur

16 at two points by -- equilibrium, slide it back 'out an

17 then measure the flue temperature again at, wel

18 three point during the off-period, two points durin

19 the warm-up period. And the specific time is fille

20 out for the furnaces and boilers when you do thes

21 measurements. 

22 This allows you to do a expediential f

23 to the profile of a heat-up and cool-down curv

24 Basically theta endurance and steady state and th

25 actual temperatures -- by a function theta Fa times 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

3

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

expediential E to the minus t over tau. You ca

determine the coefficients and the expediential fo

the cool-down and heat-up curve using the measuremen

that you make.

This is then corrected for the fact tha

units of cycling, okay, and during a cyclic operatio

never reach steady state temperature of cool-down, s

there is correction factors for the on cycle and th

off cycle to give you the actual flue gas temperatur

profile on the cyclic condition.

The losses, the loss during the on cycle

is then to steady state loss minus -- well he wen

into the unit during the on cycle basically, you ca

see it here. If it as at steady state he would hav

steady state loss, but the unit hasn"t heated up t

steady state, some of the heat has gone into the hea

exchanger, so there is a credit given during the o

cycle for that heat that the unit absorbs, and thi

term just reduces that. It's the mass flow rate time

the temperature. So this is the on cycle sensibl

loss. There's an on cycle infiltration loss, whic

basically depends upon the difference. between th

anthra air and what the indoor air and outdoor air, i

this case it was assumed to be 40 degrees. This ph

fact, which is the amount of air going up the flu

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1

1 expediential E to the minus t over tau. You ca

2 determine the coefficients and the expediential fo

3 the cool-down and heat-up curve using the measurement

4 that you make. 

5 This is then corrected for the fact tha

6 units of cycling, okay, and during a cyclic operatio

7 never reach steady state temperature of cool-down, s

8 there is correction factors for the on cycle arid th

9 off cycle to give you the actual flue gas temperatur

10 profile on the cyclic condition. 

11 The losses, the loss during the on cycl

12 is then to steady state loss minus -- well he wen

13 into the unit during the on cycle basically, you ca

14 see it here. If it as at steady state he would hav

15 steady state loss, but the unit hasn1 t heated up t

16 steady state, some of the heat has gone into the hea

17 exchanger, so there'is a credit given during the o

18 cycle for that heat that the unit absorbs, and thi

19 term just reduces that. It's the mass flow rate time

20 the temperature. So this is the on cycle sensibl

21 loss. There's an on cycle infiltration loss, whic

22 basically depends upon the difference, between th

23 anthra air and what the indoor air ,and outdoor air, i

24 this case it was assumed to be 40 degrees. This ph

25 fact, which is the amount of air going up the flu

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NoW, 

WASHINGTON, D,C, 20005 (202) 2
1

1

2

3

4

5

9

10

11

12

13

.14

15

16

17

18

19

20

21

22

23

24

25

that actually contributes to additional hous

infiltration. For units using an anthra combustio

air, the infiltration loss is zero. .

Of-period loss, off-period sensible los

is basically the mass, the integral of the mass flo

rate times the delpha 2, the air stream, the flu

temperature and the ambient temperature, the roo

temperature, and you integrate over the of f period an

this is your off-cycle loss. If the unit employees a

stack damper, you use the mass flow rate. If you hav

an off-period infiltration loss, again it depends upo

phi and the difference between 70 degrees and th

outdoor air temperature. Units using anthr

combustion -- infiltration loss is again zero.

Based upon just physical equations fo

considering buoyancy of gas, heated gas, you can com

up with equations for the mass flow rate during th

off period and a stack flow rate during off perio

which ware a function of the off period temperature

and the difference between the off period temperatur

and the room temperature. So these equations are use

for the mass flow rate in the previous loss equation

that I showed you.

All right, put it altogether and you hav

the part load efficiency is 100 percent minus th

(202) 2344433

. NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON. D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1

1 that actually contributes to additional hous

2 infiltration. For units using an anthra combustio

3 air, the infiltration loss is zero. 

4 Of-period loss, off-period sensible los

5 is basically the mass, the integral of the mass flow 

6 rate times the delpha 2, the air stream, the flu

7 temperature and the ambient temperature, the room 

8 temperature, and you integrate over the off period an

9 this is your off-cycle loss. If the unit employees 

10 stack damper, you use the mass flow rate. If you hav

11 an off-period infiltration loss, again it depends upo

12 phi and the difference between 70 degrees and th

13 outdoor air temperature. Units using anthr

.14 combustion infiltration loss is again zero. 

15 Based upon just physical equations fo

16 considering buoyancy of gas, heated gas, you can com

17 up with equations for the mass flow rate during th

18 off period and a stack flow rate during off perio

19 which ware a function of the off period temperature

20 and the difference between the off period temperatur

21 and the room temperature. So these equations are use

22 for the mass flow rate in the previous loss equation

23 that I showed you. 

24 All right, put it altogether and you hav

25 the part load efficiency is 100 percent minus th

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

latent loss, minus the sensible on-cycle loss, th

infiltration on-cycle loss, the sensible off perio

loss, the infiltration off period loss, and there i

a correction factor to just bring it back to th

factor of the units only on a portion of the time

Reassure the one time to the on and off time

basically.

Okay, this part load utilizatio

efficiency is calculated at a cyclic time of 22-1/

percent, and outdoor temperature of 42 degrees, and w

call it a part load efficiency for the appliance. Th

-- I'm sorry. The annual, which is this case, sinc

it's just the heating appliance , the seasonabl

utilization efficiency or annual fuel utilizatio

efficient, AFUE, that is just you add into the accoun

the effect of pilot energy consumption. So the top

the numerator is just the output of the appliance -

denominator is the input, plus the pilot light ener

consumption during the whole year, and that gives yo

the term that appears in the Federal Register fo

AFUE.

We did do - - so this is based upon AD

here, the part load utilization efficiency which i

calculated at one point. We did`do bin analysis an

determine that it really didn't make any differenc

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1

1 latent loss, minus the sensible on-cycle loss, th

2 infiltration on-cycle loss, the sensible off perio

3 loss, the infiltration off period loss ,and there i

4 a correction factor to just bring it back to th

5 factor of the units only on a portion of the time

6 Reassure the one time to the on and off time

7 basically. 

8 Okay, " this part load utilizatio

9 efficiency is calculated at a cyclic time of 22-1/

10 percent, and outdoor temperature of 42 degrees, and w

11 call ita part load efficiency for the appliance. Th

12 -- I'm sorry. The annual, which is this case, sinc

13 it's just the heating appliance, the seasonab

14 utilization efficiency or annual fuel utilizatio

15 efficient, AFUE, that is just you add into the accoun

16 the effect of pilot energy consumption. So the top

17 the numerator is just the output of the appliance -

18 denominator is the input, plus the pilot light energ

19 consumption during the whole year, and that gives yo

20 the term that appears in the Feder.al Register fo

21 AFUE. 

22 We did do -- so this is based upon AD

23 here, the part load utilization efficiency which i

24 calculated at one point. We did'do bin analysis an

25 determine that it really didn't make any differenc

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
2

3

4

5

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

for most of the products and most of the regions o

the country, and therefore, we calculated it only at-

one cyclic condition, 22-1/2 percent on time and on

outdoor temperature of 42 degrees.

This term, this "AFUE," does not includ

any electrical energy consumption, okay. It is purel

the gas or oil. The fuel, fossil fuel, energy, th

credits for it and the energy consumption that's i

there.

There is another descriptor that I'll jus

briefly mention, and I don't want to get into i

There is a definition of energy factor in the tes

procedure, furnace-boiler test procedure , DOE one

that it basically includes a little bit of electrica

energy consumption. It doesn't give any credit fo

the electrical heat energy that goes into the blowe

that's converted to heat and gets into the house. Th

numerator is basically is just the fuel output, th

denominator is the fuel input plus the electrica

energy consumption. The 3.412 is just the conversio

factor to convert kilowatts into BTUs , and there is n

tern or F factors, as we 'll be talking about in 

minute, to correct for generation efficiency or, cos

or anything like that. It' s a rather weak way o

trying to account for the electrical energ

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1 for most of the products and most of the regions o

2 the country, and therefore, we calculated it only at-

3 one cyclic condition, 22-1/2 percent on time and on

4 outdoor temperature of 42 degrees. 

5 This term, this "AFUE," does not includ

6 any electrical energy consumption, okay. It is purel

7 the gas or oil. The fuel, fossil fuel, energy, th

8 credits for it and the energy consumption that's i

9 there. 

10 There is another descriptor that 1'11 ju

11 briefly mention, and I don't want to get into i

12 There is a definition of energy factor in the tes

13 procedure, furnace-boiler test procedure, DOE one

14 that it basically includes a little bit of electrica

15 energy consumption. It doesn't give any credit fo

16 the electrical heat energy that goes into the blow

17 that's converted to heat and gets into the house. Th

18 numerator is basically is just the fuel output, th

19 denominator is the fuel input plus the electrica

20 energy consumption. The 3.412 is just the conversio

21 factor to convert kilowatts into BTUs, and there is n

22 tern or F factors, as we' 11 be talking about in 

23 minute, to correct for generation efficiency or co

24 

25 

or anything like that. It I S a rather weak way o

trying 

(202) 234-4433 

to account for the electrical 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 

energ

(202) 2
1

1

consumption . It results in a variance slower lowe

than AFUE , but there is no real physical meaning to 

and it's not a very good term.

So that basically describes the furnace

5 boiler test procedure . As I said, it involves o

taking a limited number of measurements and then, a

basically a model that you use to calculate part loa

8 efficiency and eventually getting an AFUE efficiency

9 The value of doing it that way is it's ver

10 repeatable , okay. The that do the study for us o

11 the errors associated with that, the typical error fo

12 doing measurements like buss alliance 1.2 percent. I

13 you were doing input/output -- the error would be plu

14 or minus 12 percent, okay . So the order of magnitud

15 would be larger if you were trying to do input/output

16 Okay, so that brings you up to date on th

17 test procedure , and now I'd like to introduce Cyru

18 Nasseri from DOE and he's going to talk about thes

19 energy descriptors.

20 MR.NASSERI : Thank you, Jack.

21 Good morning ladies and gentlemen an

22 welcome to this gathering. It's a very impressiv

23 crowd. And I would like to go ahead and go as fast a

24 I can over where we were , or I should say how 

25 started it, what we have done , and where we are toda

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1

1 consumption. It results in a variance slower low

2 than AFUE, but there is no real physical meaning to i

3 and it's not a very good term. 

4 So that basically describes the furnace

5 boiler test procedure. As I said, it involves o

6 taking a limited number of measurements and then, a

7 basically a model that you use to calculate part loa

8 efficiency and eventually getting an AFUE efficiency

9 The value of doing it that way is it's ver

10 repeatable, okay. The -- that do the study for us o

11 the errors associated wi th that, the typical error fo

12 doing measurements like buss alliance 1.2 percent. I

13 you were doing input/output -- the error would be plu

14 or minus 12 percent, okay. So the order of magnitud

15 would be larger if you were trying to do input/outpu

16 Okay, so that brings you up to date on th

17 test procedure, and now I'd like to introduce Cyru

18 Nasseri from DOE and he's going to talk about thes

19 energy descriptors. 

20 MR. NASSERI: Thank you, Jack. 

21 Good morning ladies and gentlemen an

22 welcome to this gathering. It's a very impressiv

23 crowd. And I would like to go ahead and go as fast a

24 I can over where we were, or I should say how 

25 started it, what we have done, and where we are toda

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 2
1

3

4

5

6

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

as fast as I can so we can get to the more importan

parts of this workshop, which is a discussion an

hopefully resolution of some of the issues that DOE i

looking forward to accomplish with this type of 

gathering.

Next slide please. I'll go real fast t

give you a little bit of legislative drivers on wha

the minimum standards, the test procedure an

descriptor and the test procedure is, as you see, an

then I'll go ahead to other things.

Next slide please. The elements of th

program is obviously test procedures, labeling and th

standards and the issues of today's discussion woul

be -- relates to the test procedures or th

descriptor. The existing energy descriptor, annua

fuel utilization efficiency, AFUE, or some people al

it AFUE, I've heard that before, is defined as th

ratio of annual output energy to annual input energ

Some fossil fuel including off-season pilot loss i

used does not include, does not include, electrici

consumption of auxiliary equipment. Auxiliar

equipment meaning blower fan controls or for oi

furnace pump for electric consumption.

Is based on isolated combustion syste

installation, meaning for non -- furnaces. Th

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1 as fast as I can so we can get to the more importa

2 parts of this workshop, which is a discussion an

3 hopefully resolution of some of the issues that DOE i

4 looking forward to accomplish with this type of 

5 gathering. 

6 Next slide please. I'll go real fast t

7 give you a little bit of legislative drivers on wh

8 the minimum standards, the test procedure an

9 descriptor and the test procedure is, as you see, an

10 then I'll go ahead to other things. 

11 Next slide please. The elements of th

12 program is obviously test procedures, labeling and th

13 standards and the issues of today's discussion wou

14 be relates to the test procedures or th

15 descriptor. The existing energy descriptor, annu

16 fuel utilization efficiency, AFUE, or some people a

17 it AFUE, I've heard that before, is defined as th

18 ratio of annual output energy to annual input energy

19 Some fossil fuel including off-season pilot loss 

20 used does not include, does not include, electricit

21 consumption of auxiliary equipment. Auxilia

22 equipment meaning blower fan controls or for o

23 furnace pump for electric consumption. 

24 Is based on isolated combustion syste

25 installation, meaning for non 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 

furnaces. T

(202) 2
1

2

4

5

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

combustion and dilution air is introduced from outsid

to the furnace or ambient air. Is for fossil fue

furnaces and also rates for rating for all electri

furnaces.

Another descriptor with name o`f energ

factor is in the existing DOE test procedure whi

does not or is not used for any rating purposes of t

standards. It defines as the ratio of the fossil fu

output to the sum of the fossil input and electrica

energy input.

Next slide please. An existing energ

descriptor, deficiencies. AFUE does not account fo

electricity usage by the air conditioning, I mean ai

circulating blower. Basically furnaces could b

designed to operate the blower during the burner of

period to extract residual elements of heat from th

heat exchanger. This would inflate, this wou

inflate the AFUE value, yet would actually consu

more electricity and increase the operation o

operating cost. AFUE does not encourage the use o

more efficient motors and controls to save energy

which obviously this is a part which DOE is ver

sensitive because of the minimum energy standards fo

this type of appliances.

Next slide please. In order to resolv

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1 combustion and dilution air is introduced from outsid

2 to the furnace or ambient air. Is for fossil fu

3 furnaces and also rates for rating for all electr

4 furnaces. 

5 Another descriptor with name o~ energ

6 factor is in the existing DOE test procedure whi

7 does not or is not used for any rating purposes of th

8 standards. It defines as the ratio of the fossil fu

9 output to the sum of the fossil input and electric

10 energy input. 

11 Next slide please. An existing energ

12 descriptor, deficiencies. AFUE does not account fo

13 electricity usage by the air conditioning, I mean a

circulating blower. Basically furnaces could 

15 designed to operate the, blower during the burner o

16 period to extract residual elements of heat from th

17 heat exchanger. This would inflate, this wou

18 inflate the AFUE value, yet would actually consum

19 more electricity and increase the operation 

20 operating cost.AFUE does not encourage the use 

21 more efficient motors and controls to save energ

22 which obviously this is a part which DOE is ve

23 sensitive because of the minimum energy standards f

24 this type of appliances. 

25 

(202) 234-4433 

Next slide please. In order to resol

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 
1

2

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

these efficiencies DOE proposed test procedur

revision in 1993 in the notice of proposal publishe

in the Federal Register. We told everybody what w

proposed for a new energy efficiency. Also in Januar

of 1995 we had another small notice which we call i

"Notice of proposal rulemaking commentary reopen

which at that point- we have redefined the energ

factor, which I will cover later on a little bit, i

the term of economics.

Next slide please. Proposed energ

descriptor definition that DOE proposed in th

proposed ruling of 1993 is defined as annua

efficiency, we call it AE, which is for' rating th

fossil fuel furnaces and includes or covers fossi

fuel and auxiliary electrical energy used by a fossi

fuel furnace. Is for rating indoor or outdoo

installation. Also, we have modified energy factor

which, is in a test procedure, so it can cover th

fossil fuel and auxiliary electricity and also is use

for ICS installation.

Next slide please. Proposed energ

descriptor, the AE, or the proposed objective, t

account for both fossil fuel consumption and auxiliar

electricity consumption of the furnace, to provid

consumer information regarding overall performance o

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

2

1 these efficiencies DOE proposed test procedur

2 revision in 1993 in the notice of proposal publishe

3 in the Federal Register. We told everybody what w

4 proposed for a new energy efficiency. Also in Januar

5 of 1995 we had another small notice which we call i

6 "Notice of proposal rulemaking commentary reopen

7 which at that point' we have redefined the energ

8 factor, which I will cover later on a little bit, i

9 the term of economics. 

10 Next slide please. Proposed energ

11 descriptor definit~on that DOE proposed in th

12 proposed ruling of 1993 is defined as annua

13 efficiency, we call it AE, which is for rating th

14 fossil fuel furnaces and includes or covers fossi

15 fuel and auxiliary electrical energy used by a fossi

16 fuel furnace. Is for rating indoor or outdoo

17 installation. Also, we have modified energy factor

18 which, is in a test procedure, so it can cover th

19 fossil fuel and auxiliary electricity and also is use

20 for Ies installation. 

21 Next slide please. Proposed energ

22 descriptor, the AE, or the proposed objective, t

23 account for both fossil fuel consumption and auxiliar

. 24 electrici ty consumption of the furnace, to provid

25 consumer information regarding overall performance o

(202) 2344433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW, 

WASHINGTON. D,C, 20005 (202) 2
1

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

2

the appliance both in the form of energy efficiency

and energy cost with a single, with a single,

descriptor.

Next slide please. Go back to what Georg

had with the fancy thing that satisfies the formula,

this is basically what we proposed in our proposal,

AE. As you see the components-of the numerator

describe the cost to meet the heating load without an

appliance loss, with energy priced solely based on th

fossil fuel rate. And the denominator represent 

total cost fossil fuel and auxiliary electricity t

operate the appliance.

The components in this formula are

basically the annual fossil fuel consumption E, sub F,

annual auxiliary electricity consumption E, sub AE,

our existing descriptor AFUE, a multiplication facto

F is defined. I go back to ASHRAE standard 103

American Society of Heating, Refrigerating and Ai

Conditioning, appendix in that standard which als

defines this factor as the energy consumption of th

electrical generation or at the power plant, divide

by what is delivered to the appliance at the point o

usage, simply furnace at the consumer's home, thi

factor was defined in the term of "energy" in th

original rulemaking, and then it was comments that i

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

2

1 the appliance both in the form of energy efficienc

2 and energy cost with a single, with a single

3 descriptor. 

4 Next slide please. Go back to what Georg

5 had with the fancy thing that satisfies the formula

6 this is basically what we proposed in our proposal

7 AE. As you see the components - of the numerator

8 describe the cost to meet the heating load without an

9 appliance loss, with energy priced solely based on th

10 fossil fuel rate. And the denominator represent 

11 total cost fossil fuel and auxiliary electricity t

12 operate the appliance. 

13 The components in this formula ar

14 basically the annual fossil fuel consumption E, sub F

15 annual auxiliary electricity consumption E, sub AE

16 our existing descriptor AFUE, a multiplication facto

17 F is defined. I go back to ASHRAE standard 103

18 American Society of Heating, Refrigerating and Ai

19 Condi tioning, appendix in that standard which als

20 defines this factor as the energy consumption of th

21 electrical generation or at the power plant, divide

22 by what is delivered to the appliance at the point o

23 usage, simply furnace at the consumer's home, thi

24 factor was defined in the term of "energy" in th

25 original rulemaking, and then it was comments that i

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 23
1

2

7

10

11

12

13

14

15

17

18

19

20

21

22

23

24

25

2

more or better described or meaningful to th

consumers for the sake of their rating and finding ou

what their consumption and utility bills are, if it'

defined in the term of "economics" or "cost," price o

electricity to the price of fossil fuel. We hav

reopened the proposed rule in 1995 and we did propos

it in that fashion.

Next slide please. Application of th

proposed efficiency, I mean descriptor, not, no

applied to electric furnaces or heat pumps. I shoul

mention this was the intention or is the intention o

the DOE when we published this. Apply to fossil fue

furnaces-boilers where electricity consumptio

constitutes a small portion, two to six percent, o

the total appliance energy consumption. And finally

based upon the cost to consumers, not an efficiency o

power generation, transmission or source energ

production.

The purpose of this last slide obviousl

was basically because there was a confusion among th

commentators as far as the intention of the DOE fo

proposing this type of descriptor, so I find out tha

this is a good time to actually show this, overhead an

talk about it. As a result of why they proposed, w

have the numerous comments from different people

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

2

1 more or better described or meaningful to th

2 consumers for the sake of their rating and finding ou

3 what their consumption and utility bills are, if it'

4 defined in the term of "economics" or "cost," price o

5 electricity to the price of fossil fuel. We hav

6 reopened the proposed rule in 1995 and we did propos

7 it in that fashion. 

8 Next slide please. Application of th

9 proposed efficiency, I mean descriptor, not, no

10 applied to electric furnaces or heat pumps. I shoul

11 mention this was the intention or is the intention o

12 the DOE when we published this. Apply to fossil fue

13 furnaces-boilers where electricity consumptio

14 constitutes a small portion, two to six percent, o

15 the total appliance energy consumption. And finally

16 based upon the cost to consumers, not an efficiency o

17 power generation, transmission or source ene~g

18 production. 

19 The purpose of this last slide obviousl

20 was basically because the~e was a confusion among th

21 commentators as far as the intention of the DOE fo

22 proposing this type of descriptor, so I find out tha

23 this is a good time to actually show this. overhead an

24 talk about it. As a result of why they proposed, w

25 have the numerous comments from different people

(202)~ 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N,W. 

WASHINGTON. D.C. 20005 (202) 2
1

2

4

5

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

electric, gas energy organizations, and most of th

people opposed to our proposed descriptor, a delay wa

proposed.

So today we are where we were two year

ago, and hope by having this type of a gathering tha

this type of background and interest and differen

people would accomplish necessary and sufficient, o

I should say gain, necessary and sufficien

information and knowledge to accomplish what DOE woul

like to accomplish.

I think at this point I am going to tur

the stage to Jack Langmead to proceed with the rest o

the agenda, and I'm presenting him with a whistle -

MODERATOR LANGMEAD: Thank you.

MR. NASSERI: -- so he can conduct hi

business with the size of this gathering.

MODERATOR LANGMEAD: Thank you very much

Just to get some idea, so we all know wh

is here, maybe we ought to take just a minute and g

around the room from the outside, back up, and the

around the inside and just give us your name and wh

you work for?

MS. EPPING: I'm Kathy Epping, and I wo

for DOE.

2511 MR. ADAMS: Carl Adams. You've alread

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

2

1 electric, gas energy organizations, and most of th

2 people opposed to our proposed descriptor, a delay w

3 proposed. 

4 So today we are where we were two year

5 ago, and hope by having this type of a gathering tha

6 this type of background and interest and differen

7 people would accomplish necessary and sufficient, o

8 I should say gain, necessary and sufficien

9 information and knowledge to accomplish what DOE wou

10 like to accomplish. 

11 I think at this point I am going to tur

12 the stage to Jack Langmead to proceed with the rest o

13 the agenda, and I'm presenting him with a whistle 

14 MODERATOR LANGMEAD: Thank you. 

15 MR. NASSERI: -- so he can conduct h

16 business with the size of this gathering. 

17 MODERATOR LANGMEAD: Thank you very muc

18 Just to get some idea, so we all ,know w

19 is here, maybe we ought to take just a minute and g

20 around the room from the outside, back up, and the

21 around the inside and just give us your name and w

22 you work for? 

23 

24 for DOE. 

25 

(202) 234-4433 

MS. EPPING: I'm Kathy Epping, and I wo

MR. ADAMS: Carl Adams. You've alread

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 
2

3

4

7

8

9

10

11

12

13

.14

15

16

17

18

19

20

21

22

23

24

heard from me.

MR. MILLS: I'm James Mills with th

Federal Trade Commission.

MR. PAQUETTE: Mark Paquette, ETL Testing

MS. SUOZZO: Margaret Suozzo, ACEEE.

MR. MARRAN: John Marran, Energy Kinetics

MR. SAWRUK: Jim Sawruk from Genera

Machine Corporation, Electric Furnace.

MR. MOSKWA: Kenneth Moskwa, Weil-McLain

MR. FREITAS: Christopher Freitas, U.S

Department of Energy, Office of Fossil Energy.

MR. PETCHUL: Martin Petchul, Columbia Ga

Distribution Companies.

MR. DeLIMA: Henry DeLima, DeLim

Associates.

MR. CHWALOWSKI: Matt Chwalowski, EEI.

MR. JARNAGIN: Ron Jarnagin, Pacifi

Northwest Laboratory.

MR. LIU: Stan Liu, NIST.

MR. KALISCH: Bert Kalisch, American Ga

Association.

MR. FRITTS : Charlie Fritts , also Americ

Gas Association.

MS. BANKS: Donna Banks, American Ga

2511 Association.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

2

1 heard from me. 

2 MR. MILLS: I'm James Mills with th

3 Federal Trade Commission. 

4 MR. PAQUETTE: Mark Paquette, ETL Testing

5 MS. SUOZZO: Margaret Suozzo, ACEEE. 

6 MR. MARRAN: John Marran, Energy Kinetics

7 MR. SAWRUK: Jim Sawruk from Gener

8 Machine Corporation, Electric Furnace. 

9 MR. MOSKWA: Kenneth Moskwa, Weil-McLain

10 MR. FREITAS: Christopher Freitas, U.S

11 Department of Energy, Office of Fossil Energy. 

12 MR. PETCHUL: Martin Petchul, Columbia G

13 Distribution Companies. 

.14 MR. DeLIMA: Henry DeLima, DeLim

15 Associates. 

16 MR. CHWALOWSKI: Matt Chwalowski, EEl. 

17 MR. JARNAGIN: Ron Jarnagin, Pacif

18 Northwest Laboratory. 

19 MR. LIU: Stan Liu, NIST. 

20 MR. KALISCH: Bert Kalisch, American G

21 Association. 

22 MR. FRITTS: Charlie Fritts, also Americ

23 Gas Association. 

24 MS. BANKS: Donna Banks, American G

25 Association. 

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 
1

2

4

5

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

2

MR. HOSLER: Daryl Hosler, Souther

California Gas Company.

MR. RANFONE: Jim Ranfone, American Ga

Association.

MR. DARD: Mike Dard, Canadian Standards

MR. PIETSCH: Joe Pietsch, I'm a

engineering consultant and one of my clients in th

industry asked me to attend this meeting.

MR. MINTON: Steve Minton, Apollo Stat

Industries.

MR. STANONIK: Frank Stanonik, GAMA.

MR. MATTINGLY: Joe Mattingly, GAMA.

MR. GEDCKE: Jeff Gedcke, Aman

Refrigeration.

MR. DEMPSEY: Dan Dempsey, Carrier.

MR. VERDERBER : Jacob Verderber, Rhee

Manufacturing.

MR. ADAMS: Charlie Adams, Ducane Company

MR. VERSHAW: Jim Vershaw, Trane Company

MR. BURNES: Jim Burnes, Nordyne.

MR. WILHELM: Barry'Wilhelm, Virgini

Power.

MR. HICKSON : Jim Hickson , Lenno

Industries.

2511 MR. LEWIS: Dave Lewis, Lennox.

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

2

1 MR. HOSLER: Daryl Hosler, Souther

2 California Gas Company. 

3 MR. RANFONE: Jim Ranfone, American Ga

4 Association. 

5 MR. DARD: Mike Dard, Canadian Standards

6 MR. PIETSCH: Joe Pietsch, I'm a

7 engineering consultant and one of my clients in th

8 industry asked me to attend this meeting. 

9 MR. MINTON: Steve Minton, Apollo Stat

10 Industries. 

11 MR. STANONIK: Frank Stanonik, GAMA. 

12 MR. MATTINGLY: Joe Mattingly, GAMA. 

13 MR. GEDCKE: Jeff Gedcke, Aman

14 Refrigeration. 

15 MR. DEMPSEY: Dan Dempsey, Carrier. 

16 MR. VERDERBER: Jacob Verderber, Rhee

17 Manufacturing. 

18 MR. ADAMS: Charlie Adams, Ducane Company

19 

20 

21 

22 Power. 

23 

24 Industries. 

25 

(202) 234-4433 

MR. VERSHAW: Jim Vershaw, Trane Compan

MR. BURNES: Jim Burnes, Nordyne. 

MR. WILHELM: Barry' Wilhelm, Virgin

MR. HICKSON: Jim Hickson, 

MR. LEWIS: Dave Lewis, Lennox. 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON. D.C. 20005 

Lenno

(202) 2
MR. CLARK: Jim Clark, Natural Resources

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Canada.

MR. CANE: Doug Cane, Caneta Research.

MR. HAAG: Wilbur Haag, A.O. Smith Wate

Products Company.

MR. RYAN: Bill Ryan , Gas Researc

Institute.

MR. SWEETSER: Rich Sweetser, American Ga

Cooling Center.

MR. STANBOULY: Loutiel Stanbouly, Yor

International.

MR. DOMANSKI: Peter Domanski, NIST.

MR. KELLY: George Kelly, NIST.

MR. POLLOCK: Ed Pollock, Office of Code

and Standards, DOE.

MR. THRASHER: Bill Thrasher, American Ga

Association Research.

MR. CRISAFULLI: Jeff Crisafulli, Batelle

MR. LESLIE: Neil Leslie, Gas User

Institute.

(202) 234-4433

MR. WETHJE: Larry Wethje with ARI.

MR. JAKOB: Frank Jakob, Batelle Columbus

MR. DOUGHERTY: Brian Dougherty with NIST

MR. RAYMOND: Mike Raymond, DOE.

MR. HUI: Bill Hui with DOE.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

2

l' MR. CLARK: Jim Clark, Natural Resources

2 Canada. 

3 MR. CANE: Doug Cane, Caneta Research. 

4 MR. HAAG: Wilbur Haag, A.O. Smith Wate

5 Products Company. 

6 MR. RYAN: Bill Ryan, Gas Researc

7 Institute. 

8 MR. SWEETSER: Rich Sweetser, American Ga

9 Cooling Center. 

10 MR. STANBOULY: Loutiel Stanbouly, Yor

11 International. 

12 MR. DOMANSKI: Peter Domanski, NIST. 

13 MR. KELLY: George Kelly, NIST. 

14 MR. POLLOCK: Ed Pollock, Office of Code

15 and Standards, DOE. 

16 MR. THRASHER: Bill Thrasher, American G

17 Association Research. 

18 MR. CRISAFULLI: Jeff Crisafulli, Batelle

19 

20 Institute. 

21 

22 

23 

24 

25 

(202) 234-4433 

MR. LESLIE: Neil Leslie, Gas Use

MR. WETHJE: Larry Wethje with ARI. 

MR. JAKOB: Frank Jakob, Batelle Columbu

MR. DOUGHERTY: Brian Dougherty with NIST

MR. RAYMOND: Mike Raymond, DOE. 

MR. HUI: Bill Hui with DOE. 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

2

4

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

MR. YOUNG: Dave Young, Ontario Hydr

Technologies.

MR. PISTOLE: Mike Pi stole, Effika

International.

MR. BEGOSKE: Tim Begoske, Effika

International.

MR. McCABE: Michael McCabe, Department o

Energy.

of Energy.-

of Energy.

of Energy.

MR. BERRIGER: Bryan Berriger, Departmen

MR. LAUGHLIN: Qonnie Laughlin, Departmen

MR. MARGOLIS: Eugene Margolis, Departmen

MODERATOR LANGMEAD: Thank you all. As w

went through let me remind everybody that you do hav

to speak up. I heard many names , a few of them we

a little hard to pick out. There are name tags a

your places. If you haven't filled the name tag out

I guess I'd request you to do so, so the people wil

know who you are.

I think we've got four major interes

groups of utilities and manufacturers here. There i

AGA, EEI, GAMA, and ARI. Have I left out any majo

groups other than the compliments of Canadian visitor

(202) 234-444333

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1 MR. YOUNG: Dave Young, Ontario Hyd

2 Technologies. 

'3 MR. PISTOLE: Mike Pistole, Effik

4 International. 

5 MR. BEGOSKE: Tim Begoske, Effik

6 International. 

7 MR. McCABE: Michael MeCabe, Department o

8 Energy. 

9 MR. BERRIGER: Bryan Berriger, Departme

10 of Energy.-

11 MR. LAUGHLIN: Qonnie Laughlin, Departme

12 of Energy. 

13 MR. MARGOLIS: Eugene Margolis, Departme

14 of Energy .. 

15 MODERATOR LANGMEAD: Thank you all. As w

16 went through let me remind everybody that you do hav

17 to speak up. I heard many names, a few of them we

18 a little hard to pick out. There are name tags 

19 your places. If you haven't filled the name tag ou

20 I guess I'd request you to do so, so the people wi

21 know who you are. 

22 I think we've got four maj or intere

23 groups of utilities and manufacturers here. There 

24 AGA, EEl, GAMA, and ARI. Have I left out any maj

25 groups other than the compliments of Canadian visito

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
2

1

2

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

here?

I thought that what we might want to do

if any one of those groups would like to make a littl

opening statement on the subject of energy efficienc

descriptors , they' d be welcome to do so at this poin

in time . Does anybody want to give an openin

statement remark?

Frank?

MR. STANONIK : Frank Stanonik with GAMA

Obviously we've got a lot of people here to talk abou

the possibility of changing energy descriptors. I

you listen to Cyrus from DOE and other people fro

DOE, the two things driving this are to give consumer

better information in particular to the electrical

consumption associated with gas and oil furnaces an

boilers, and then the other issue is perhaps a mean

to promote more efficient in the sense of less

electrical consumption in those products , bette

efficiency in that sense.

But the thing is that we currently have i

the test procedures a measure that tells you th

efficiency of this product in terms of the base fue

it consumes , whether that ' s gas and oil, and you no

have a measure that tells you the electrica

2511 consumption of that associated product.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

2

1 here? 

2 I thought that what we might want to do

3 if anyone of those groups would like to make a littl

4 opening statement on the subject of energy efficienc

5 descriptors, they'd be welcome to do so at this poin

6 in time. Does anybody want to gi ve an openin

7 statement remark? 

8 Frank? 

9 MR. STANONIK: Frank Stanonik with GAMA

10 Obviously we've got a lot of people here to talk abou

11 the possibility of changing energy descriptors. I

12 you listen to Cyrus from DOE and other people from 

13 DOE, the two things driving this ·are to give consumer

14 better information in particular to the electrica

15 consumption associated with gas and oil furnaces an

16 boilers, and then the other issue is perhaps a mean

17 to promote more efficient in the sense of les

18 electrical consumption in those products, bette

19 efficiency in that sense. 

20 But the thing is that we currently have i

21 the test procedures a measure that tells you th

22 efficiency of this product in terms of the base fue

23 it consumes, whether that's gas and oil, and you no

24 have a measure that tells you the electrica

25 consumption of that associated product. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 23
1

2

3

4

5

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

2,

And to the extent the general public know

anything about or understands anything about

efficiencies, the one number they seem to furnish is

AFUE. And if there was the same effort put in

explaining what the EAE number is, the electrical

consumption, you then have all the necessary tools for

those who are interested to determine or estimate wha

their annual cost of operation is. And they could use

that with national average fuel cost, and they could

do that with their local fuel cost.

And on that basis what is to be gaine

from the consumer's perspective, and as I recall th

whole effort of this was appliance efficiency to ge

the information to consumers, what is to be gained for

consumers to have new descriptors which up to this

point have all proved in one case or another to b

inadequate and will certainly not simplify things but

confuse things.

And I'll just make one point here, if yo

were listening to what was said , all of the othe

descriptors that are being talked about here , such a

the AE and things like that, include the electrical

consumption, but for good reasons, purposely ignor

the fact that some of that electrical energy in, fac

ends up as heat and as part of the heat that comes of

(202) 234-44393

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

2.

1 And to the extent the general public know

2 anything about or understands anything abou

3 effLciencies, the one number they seem to furnish i

4 AFUE. And if there was the same effort put in 

5 explaining what the EAE number is, the electrica

6 consumption, you then have all the necessary tools fo

7 those who are interested to determine or estimate wha

8 their annual cost of operation is. And they could us

9 that with national average fuel cost, and they coul

10 do that with their local fuel cost. 

11 And on that basis what is to be gaine

12 from the consumer's perspective, and as I recall th

13 whole effort of this was appliance efficiency to ge

14 the information to consumers, what is to be gained fo

15 consumers to have new descriptors which up to thi

16 point have all proved in one case or another to b

17 inadequate and will certainly not simplify things bu

18 confuse things. 

19 And I'll just make one pOint here, if yo

20 were listening to what was said, all of the othe

21 descriptors that are being talked about here, such a

22 the AE and things like that, include the electrica

23 consumption, but for good reasons, purposely ignor

24 the fact that some of that electrical energy in, fac

25 ends up as heat and as part of the heat that comes of

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 23
1

2

3

5

6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

3

of the appliance. So on the one hand you're talkin

about a descriptor that would lower the efficiency o

a gas or oil furnace because you're just accountin

for the electrical consumption that occurs associate

with producing that energy, but ignores th

contribution of that energy to the end result o

heating. And in fact that's inappropriate.

Now, there's reasons not to do that and w

agree with those reasons, but if you look at all that

the current descriptors, we believe the best you ca

do, and in fact they give all the necessar

information for those people that want to determin

what is my cost of operation both for the gas or oi

I consume and the electricity that I consume i

running that appliance. We don't see that. Eithe

there's been an exceptional alternative put forth o

the likelihood that there will be one.

MODERATOR LANGMEAD: Is there anybody els

that wants to make any opening remarks, any othe

organization that wants to make any opening remarks o

this subject?

Jim?

MR. RANFONE: Yes, Jim Ranfone with AGA

I guess I would agree with Frank that the whole ide

is to give consumers information. Now, whether or no

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

3

1 of the appliance. So on the one hand you're talkin

2 about a descriptor that would lower the efficiency o

3 a gas or oil furnace because you're just accountin

4 for the electrical consumption that occurs associate

5 wi th producing that energy, but ignores th

6 contribution of that energy to the end result o

7 heating. And in fact that's inappropriate. 

8 Now, there's reasons not to do that and w

9 agree with those reasons, but if you look at all that

10 the current descriptors, we believe the best you ca

11 do, and in fact they give all the necessar

12 information for those people that want to determin

13 what is my cost of operation both for the gas or o

. 14 I consume and the electricity that I consume i

15 running that appliance. We don't see that. Eithe

16 there's been an exceptional alternative put forth o

17 the likelihood that there will be one. 

18 MODERATOR LANGMEAD: Is there anybody els

19 that wants to make any opening remarks, any othe

20 organization that wants to make any opening remarks o

21 this subject? 

22 Jim? 

23 MR. RANFONE: Yes, Jim Ranfone with AG

24 I guess I would agree with Frank that the whole ide

25 is to give consumers information. Now, whether or n

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

2

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

3

we agree as to the best methodology to do that remain

to be seen. I don't want to pre-judge what's going t

be discussed today or make any conclusions that w

have the best methodology out there. I had hoped tha

the workshop would start with a clean slate and tak

a look at the existing descriptors. I think there i

going to be some discussion about the alternativ

approaches. And before we make a judgment that wha

we have is the best and we can't do any better, wh

don't we hear what else is out there, other potential

Our basic problem with this proposal fro

DOE was basically the way it was presented by Cyru

when he indicated that the primary purpose was the ne

energy descriptor was to promote improvements in th

electrical consumption for fossil fuel products. H

suggested that in doing so that was the entire purpos

of that proposal and that it wouldn't apply t

electric furnaces or heat pumps.

Our contention is that it should be looke

at for other products. How can one justify taking 

cost ratio and applying it to the electric consumptio

of a fossil fuel product and ignoring the same type o

procedure for any electric product. I think that i

a basic philosophical difference we have and we' d lik

to talk it out today and possibly come up with som

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

3

1 we agree as to the best methodology to do that remain

2 to be seen. I don't want to pre-judge what's going t

3 be discussed today or make any conclusions that w

4 have the best methodology out there. I had hoped tha

5 the workshop would start with a clean slate and tak

6 a look at the existing descriptors. I think there i

7 going to be some discussion about the alternativ

8 approaches. And before we make a judgment that wha

9 we have is the best and we can't do any better, wh

10 don't we hear what else is out there, other potential

11 Our basic problem with this proposal from 

12 DOE was basically the way it was presented by Cyru

13 when he indicated that the primary purpose was the ne

14 energy descriptor was to promote improvements in th

15 electrical consumption for fossil fuel products. H

16 suggested that in doing so that was the entire purpos

17 of that proposal and that it wouldn't apply t

18 electric furnaces or heat pumps. 

19 Our contention is that it should be looke

20 at for other products. How can one justify taking 

21 cost ratio and applying it to the electric consumptio

22 of a fossil fuel product and ignoring the same type o

23 procedure for any electric product. I think that i

24 a basic philosophical difference we have and we'd lik

25 to talk it out today and possibly come up with som

(202) 234-4433 

NEAL R. GROS.S 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
3

5

8.

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

'24

25

kind of remedies.

But there is no logic to making a proposa

that essentially applies to a small portion of th

energy consumed by one product and ignores it as th

major energy source for other products. It's just no

rational. Now, you want to argue about energy ratios

cost ratios as being not valid, we can do that, bu

let's take a look at what we've got out there and wha

can we present to consumers, if a consumer is to loo

at a piece of equipment and try and make a decision.

Whether we will agree or disagree with th

effectiveness of a labeling program, it's the law

we've got the enforcement mechanism in place to do it

The question is, when a consumer looks at a produc

and it has an AFUE number of 98 on it versus a produc

that has an AFUE number of 78 on it, one would have t

make the assumption that the 98 is going to cost the

less to operate. That would be a wrong assumptio

based on the current energy descriptors, and that'

what we would like to discuss today and possibly mak

some progress . We don't think we're going to mak

quantum leaps today, but at least get it on the tabl

and let's talk about it and then we have our fligh

test voucher.

MODERATOR LANGMEAD: Thank you, Jim.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

3

1 kind of remedies. 

2 But there is no logic to making a proposa

3 that essentially applies to a small portion of th

4 energy consumed by one product and ignores it as th

5 maj or energy source for other products. It's just no

6 rational. Now, you want to argue about energy ratios

7 cost ratios as being not valid, we can do that, bu

8. let I s take a look at what we've got out there and wh

9 can we present to consumers, if a consumer is to loo

10 at a piece of equipment and try and make a decision. 

11 Whether we will agree or disagree with th

12 effectiveness of a labeling program, it's the law

13 we've got the enforcement mechanism in place to do it

14 The question is, when a consumer looks at a produc

15 and it has an AFUE number of 98 on it versus a produc

16 that has an AFUE number of 78 on it, one would have t

17 make the assumption that the 98 is going to cost the

18 less to operate. That would be a wrong assumptio

19 based o.n the current energy descriptors, and that

20 what we would like to discuss today and possibly mak

21 some progress. We don't think we're going to mak

22 quantum leaps today, but at least get it on the tabl

23 and let's talk about it and then we have our fligh

24 test voucher. 

25 MODERATOR LANGMEAD: Thank you, Jim. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

4

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

3

Matt, do you have anything else to say, o

somebody from EEI at this point in time, any openin

remarks?

Larry?

MR. WETHJE: Yes.

MODERATOR LANGMEAD : This is Larry Wethj

of ARI.

MR. WETHJE: Larry Wethje with ARI. 

think I'd like to underscore what Frank Stanonik agai

has said that from ARI's perspective and our members

we don't really see that there is any need for 

change in the energy descriptors as they exist today

It doesn't seem like this request is coming from th

marketplace or the manufactures. It seems to us tha

it's more of an issue between utility interests an

utility industries rather than a real need in th

marketplace or a request from a manufacturer.

There is a means that exist right now fo

consumers to compare products that use different fuel

on an annual operating cost basis, and that's the wa

it ought to be. The consumers are interested in ho

much is this product going to cost them to operate

not necessarily how efficient the product is. An

there are mechanisms and means that currently exis

today for the consumer to be able to do that, an

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

3

1 Matt, do you have anything else to say, o

2 somebody from EEl at this point in time, any openin

3 remarks? 

4 Larry? 

5 MR. WETHJE: Yes. 

6 MODERATOR LANGMEAD: This is Larry Wethj

7 of ARI. 

8 MR. WETHJE: Larry Wethj e with ARI. 

9 think I'd like to underscore what Frank Stanonik agai

10 has said that from ARI's perspective and our members

11 we don't really see that there is any need for 

12 change in the energy descriptors as they ex~st today

13 It doesn't seem like this request is coming from th

14 marketplace or the manufactures. It seems to us tha

15 it's more of an issue between utility interests an

16 utili ty industries rather than a real need in th

17 marketplace or a request from a manufacturer. 

18 There is a means that exist right now fo

19 consumers to compare products that use different fuel

20 on an annual operating cost basis, and that's the w

21 it ought to be. The consumers are interested in ho

22 much is this product going to cost them to operate

23 not necessarily how efficient the product is. A

24 there are mechanisms and means that currently exi

25 today for the consumer to be able to do that, an

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NoW. 

WASHINGTON, D.C. 20005 (202) 2
3

1

3

4

6

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

that's what matters to them.

Furthermore, I also think I agree wit

what Jim Ranfone just said and take issue with what

Cyrus Nasseri from DOE said that there was n

intention for the F factor to apply to all types o

heating products because in the proposed rule ther

was a clear statement that we took issue with tha

said, and I can quote from page 4350 of the Federal

Register and the proposed rule that the F factor

wasn't intended to apply to all types of space heatin

equipment.

So I'm a little confused as to DOE'

position when they put up the overhead and said tha

that was not the intention , because it clearly was th

intention as stated in the Federal Register. I'd lik

to get some clarity on that, if I could, from DOE

But I guess also just his opening remarks, again, t

say that -- I'm not sure whether it's need or it'

alleged need or the request is coming from other tha

I can speculate from utility interest becaus

manufacturers and consumers seem to be satisfied wit

the current descriptors that are in place today.

MODERATOR LANGMEAD: All right.

Are there any other individuals?

25 Yes.

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON . D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

3

1 that's what matters to them. 

2 Furthermore, I also think I agree wit

3 what Jim Ranfone just said and take issue with wha

4 Cyrus Nasseri from DOE said that there was n

5 intention for the F factor to apply to all types o

6 heating products because in the proposed rule ther

7 was a clear statement that we took issue with tha

8 said, and I can quote from page 4350 of the Federa

9 Register and the proposed rule that the F facto

10 wasn't intended to apply to all types of space heatin

11 equipment. 

12 So I'm a li,ttle confused as to DOE

13 position when they put up the overhead and said tha

14 that was not the intention, because it clearly was th

15 intention as stated. in the Federal Register. I'd lik

16 to get some clarity on that, if I could, from DOE

17 But I guess also just his opening remarks, again, t

18 say that -- I'm not sure whether it's need or it'

19 alleged need or the request is coming from other tha

20 I can speculate from utility interest becaus

21 manufacturers and consumers seem to be satisfied wit

22 the current descriptors that are in place today. 

23 

24 

25 

(202) 234-4433 

MODERATOR LANGMEAD: All right. 

Are there any other individuals? 

Yes. 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW, 

WASHINGTON. D,C, 20005 (202) 2
1

4

7

9

10

11

12

13

. 14

15

16

17

18

19

20

21

22

23

24

25

MR.FRITTS: My name is Charlie Fritts

I'm with American Gas, and I'll be brief. The labe

are confusing. We may understand them, consumer

don't. What we think is worthwhile for this whol

group, and also for DOE to look at, is to get a syst

where consumers can figure out how efficient tha

product is and the consumers want to know cost. I

may be cost per BTU. We would obviously sourc

analysis over sight, but the people have to follo

cost. That's what consumers want.

And one of our presentations today b

Frank Jakob, will relate to cost per BTU at the site

But I think in the bigger picture we have to develop

a uniform standard so people can look at appliance

f

and say how much does this cost to operate. AEs don'

mean anything to the consuming public, and I thin

that's the long term goal of this. Because Congres

is not going to be behind a series of differen

evaluations of different appliances that the publ

cannot understand. I think we have to look to 

bigger picture of getting a unified standard that'

essentially based on cost.

MODERATOR LANGMEAD: Larry, do you hav

another comment?

MR. WETHJE: I would actually just like 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 2344433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

3

1 MR. FRITTS: My name is Charlie Fritts

2 I'm with American Gas, and I'll be brief. The labe

3 are confusing. We may understand them, consume

4 don't. What we think is worthwhile for this who

5 group, and also for DOE to look at, is to get a syste

6 where consumers can figure out how efficient th

7 product is and the consumers want to know cost. 

8 may be cost per BTU. We would obviously sourc

9 analysis over sight, but the people have to follo

10 cost. That's what consumers want. 

11 And one of our presentations today b

12 Frank Jakob, will relate to cost per BTU at the site

13 But I think in the bigger picture we have to develop

.14 a uniform standard so people can look at applianc

, 

15 and say how much does this cost to operate. AEs don

16 mean anything to the consuming public, and I thin

17 that's the long term goal of this. Because Congre

18 is not going to be behind a series of differe

19 evaluations of different appliances that the publ

20 cannot understand. I think we have to look to 

21 bigger picture of getting a unified standard that

22 essentially based on cost. 

23 MODERATOR LANGMEAD: Larry, do you ha

24 another comment? 

25 

(202) 234-4433 

MR. WETHJE: I would actually just like 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 
3

1

2

3

4

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

respond.

MODERATOR LANGMEAD: Identify yourself

please.

MR. WETHJE: Larry Wethje with ARI again

As I said there is a means right now for consumers t

compare products on a cost basis. The directorie

that are nationally recognized by the trad

associations offer such a basis. The DOE tes

procedures offer such a basis.

Furthermore, I think we're all kiddin

ourselves if anybody in the room believes tha

consumers look at the energy descriptors and bas

their purchasing decisions on those. The trad

associations and manufacturers have long argued wit

FTC that the energy guide labels really are not 

factor in making a decision on the purchase. Thes

products, furnaces, boilers, air conditioners are no

purchased based upon looking at the yellow energ

guide labels. Consumers typically don't make 

purchase based on those. They purchase throug

contractors and contractors probably very often ge

down to what is it going to cost me or you to operat

this product, and they have a means of being able t

explain that to the consumer very thoroughly righ

now.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

3

1 respond. 

2 MODERATOR LANGMEAD: Identify yourself

3 please. 

4 MR. WETHJE: Larry Wethje with ARI again

5 As I said there is a means right now for consumers t

6 compare products on a cost basis. The directorie

7 that are nationally recognized by the trad

8 associations offer such a basis. The DOE tes

9 procedures offer such a basis. 

10 Furthermore, I think we're all kiddin

11 ourselves if anybody in the room believes tha

12 consumers look at the energy descriptors and bas

13 their purchasing decisions on those. The trad

14 associations and manufacturers have long argued wit

15 FTC that the energy guide labels rea'lly are not 

16 factor in making a decision on the purchase. Thes

17 products, furnaces, boilers, air conditioners are no

18 purchased based upon looking at the yellow energ

19 guide labels. Consumers typically don't make 

20 purchase based on those. They purchase throug

21 contractors and contractors probably very often g

22 down to what is it going to cost me or you to opera

23 this product, and they have a means of being able t

24 explain that to the consumer very thoroughly righ

25 now. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
2

3

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

MODERATOR LANGMEAD: Thank you, Larry.

Any other opening statements?

There were a few questions on the sheet

in the agenda, and I think we can run through a few o

those and get into some more open discussion.

One of the first ones was "To what exten

do the energy descriptors not account for total energ

consumption of appliances?" Well, we're talking abou

furnaces and boilers, we know that, they don't accoun

for electrical energy. I think we've answered that.

There's total agreement on that issue, i

there not, on current test procedures?

The second question is "Do consumers hav

adequate means to calculate annual operating cost o

appliances using current descriptors?" If I a

correct, and I heard correctly around the room, ther

is means . Now, whether it's adequate or not i

another issue , but there are means in the curren

side.

Does anybody disagree with that, that th

current procedures allow the calculation cost?

MR. WETHJE: I would back up, I think

Jack, and just -- Larry Wethje again from ARI. An

the first question, I'm not sure I agree, depending o

what we're talking about there, to what extent to th

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

3

1 MODERATOR LANGMEAD: Thank you, Larry. 

2 Any other opening statements? 

3 There were a few questions on the sheet

4 in the agenda, and I think we can run through a few o

5 those and get into some more open discussion. 

6 One of the first ones was "To what exten

7 do the energy descriptors not account for total energ

8 consumption of appliances?" Well, we're talking abou

9 furnaces and boilers, we know that, they don't accoun

10 for electrical energy. I think we've answered that. 

·11 There's total agreement on that issue, i

12 there not, on current test procedures? 

13 The second question is "Do consumers hav

14 adequate means to calculate annual operating cost o

15 appliances using current descriptors?" If I a

16 correct, and I heard correctly around the room, ther

17 is means. Now, whether it's adequate or not i

18 another issue, but there are means in the curren

19 side. 

20 Does anybody disagree with that, that th

21 current procedures allow the calculation cost? 

22 MR. WETHJE: I would back up, I think

23 Jack, and just -- Larry Wethje again from ARI. A

24 the first question, I'm not sure I agree, depending 

25 what we're talking about there, to what extent to th

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

5

8

9

10

11

12

13

14

15

16.

17

18

19

20

21

22

23

24

25

3

efficiency descriptors not account for the tota

energy consumption of appliances. I think efficienc

descriptors exist that do account for the total energ

consumption of appliances. Perhaps not in the manne

that everyone agrees with, but efficiency descriptor

do exist that account for the electrical energy

consumption because there is a way to account for tha

on a manual operating cost basis.

MODERATOR LANGMEAD: Larry, what I mean

was the AFUE does not, and we've got agreement on

that.

Now, there's an energy factor that does d

that, so there is an'issue we can come back to, but 

just want to make sure we are trying to get down a few

points we have agreement on, and certainly there i

going to be other issues that we don't.

The next question on the list is "Is ther

a marketplace need for new descriptors? Now, severa

people addressed that in their opening remarks

particularly AGA, that the current things ar

confusing.

Is there any other discussion on th

marketplace need for new descriptors ? We heard som

that said there wasn't any need.

Frank?

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

3

1 efficiency descriptors not account for the tota

2 energy consumption of appliances. I think efficienc

3 descriptors exist that do account for the total energ

4 consumption of appliances. Perhaps not in the manne

5 that everyone agrees with, but efficiency descriptor

6 ' do exist that account for the electrical energ

7 consumption because there is a way to account for tha

8 on a manual operating cost basis. 

9 MODERATOR LANGMEAD: Larry, what I mean

10 was the AFUE does not, and we've got agreement o

11 that. 

12 Nbw, there's an energy factor that does d

13 that, so there is an issue we can come back to, but 

14 just want to make sure we are trying to get down a few 

15, pOints we have agreement on, and certainly there i

16 going to be other issues that we don't. 

17 The next question on the list is "Is ther

18 a marketplace need for new descriptors? Now, severa

19 people addressed that in their opening remarks

20 particularly AGA, that the current things ar

21 confusing. 

22 Is there any other discussion on th

23 marketplace need for new descriptors? We heard som

24 that said there wasn't any need. 

25 Frank? 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 23
2

3

5

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

MR. JAKOB: Jack, may I present two o

three of them?

MODERATOR LANGMEAD: That would be fine

Frank, why don't you try feeling that microphone an

see if it will come on.

MR. JAKOB: I'm not sure that's connecte

with the sound system. I think that's connected wit

the tape recorder.

MODERATOR LANGMEAD: Okay.

MR. JAKOB: Can you hear me, if I use m

Walter Cronkite voice, in the back of the room? Wha

I heard people say this morning is that what consumer

see, and I'll just restrict my comments to furnaces

I'm Frank Jakob, I'm with Batelle Columbu

Laboratories, and I'm here under the auspices of 

projected sponsored by the Gas Research Institute.

What consumers see in terms of efficienc

are gas furnaces that have minimum efficiency set a

78 and , if you look in the directory, it goes as hig

as 96.6 , there' s a range there. And for electri

furnaces efficiency range from about 96 percent up t

98 percent . Those are the numbers in terms of AFU

and efficiency that they see.

What might be down here in the fine prin

and, if you look in terms of dollars per year fo

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

3

1 MR. JAKOB: Jack, may I present two o

2 three of them? 

3 MODERATOR LANGMEAD: That would be fine

4 Frank, why don't you try feeling that microphone an

5 see if it will come on. 

6 MR. JAKOB: I'm not sure that's connecte

7 with the sound system. I think that's connected wit

8 the tape recorder. 

9 MODERATOR LANGMEAD: Okay. 

10 MR. JAKOB: Can you hear me, if I use m

11 Walter Cronkite voice, in the back of the room? Wh

12 I heard people say this morning is that what consume

13 see, and I'll just restrict my comments to furnaces

14 I'm Frank Jakob, I'm wi th Batel1e Columbu

15 Laboratories, and I'm here under the auspices of 

16 projected sponsored by the Gas Research Institute. 

17 What consumers see in terms of efficienc

18 are gas furnaces that have minimum efficiency set a

19 78 and, if you look in the directory, it goes as hig

20 as 96.6, there's a range there. And for electri

21 furnaces efficiency range from about 96 percent up t

22 98 percent. Those are the numbers in terms of AFU

23 and efficiency that they see. 

24 What might be down here in the fine prin

25 and, if you look in terms of dollars per year fo

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
2

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

4

operation, those furnaces that had lower efficiencie

cost a third to operate. That was the point I hear

this morning. If you look on a full fuel cycle basis

it uses about a third of the energy. Those number

are related because the amount that you pay is relate

to the total inventory of fuel.

Now, the point is, someone mentioned abou

the marketplace, is it asking for such things? If yo

look at the shipment data for electric furnaces an

gas furnaces over the last couple of years, these ar

fossil fuel and electric furnace boilers, and this i

shipment growth over that, that is each year we ship

we hopefully ship, more and more furnaces to bigge

and bigger businesses. Last year there were almost a

many electric furnaces shipped as there are condensin

furnaces shipped.

And prior to 1992 that's an interestin

year, something must have happened in 1992. Prior t

1992 you can see that shipment growth and electri

furnaces was negative or.only slightly positive. Th

same is true here in blue for gas furnaces as well

Starting in 1992 and for each of these three followin

year, '92, '93, '94, electric furnace shipments hav

been growing at 15 to 20 percent a year while fossi

fuel furnaces have been growing an average about hal

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

4

1 operation, those furnaces that had lower efficiencie

2 cost a third to operate. That was the point I hear

3 this morning. If you look on a full fuel cycle basis

4 it uses about a third of the energy. Those numbe

5 are related because the amount that you pay is relate

6 to the total inventory of fuel. 

7 Now, the pOint is, someone mentioned abou

8 the marketplace, is it asking for such things? If yo

9 look at the shipment data for electric furnaces an

10 gas furnaces over the last couple of years, these ar

11 fossil .fuel and electric furnace boilers, and this i

12 shipment growth over that, that is each year we ship

13 we hopefully ship, more and more furnaces to bigge

. 14 and bigger businesses. Last year there were almost a

15 many electric furnaces shipped as there are condensin

16 furnaces shipped. 

17 And prior to 1992 that's an interestin

18 year, something must have happened in 1992. Prior t

19 1992 you can see that shipment growth and electri

20 furnace~ was negative or~nly slightly positive. Th

21 same is true here in blue for gas furnaces as wel

22 Starting in 1992 and for each of these three followin

23 year, '92, '93, '94, electric furnace shipments hav

24 been growing at 15 to 20 percent a year while foss

25 fuel furnaces have been growing an average about ha

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

4

that. 1992 is when minimum efficiency rules went int

effect. And 1992 is when gas furnaces suddenly cos

a couple of hundred dollars more than they used to

No more drafted appliances except for a clever one

their induced draft codes put on the appliance, ther

were--put on the appliance; added cost, and that kin

of changes the economics.

If you look at the appliance shipmen

data, year to date for this year, the same tren

holds, that shipments, you know, the increase i

shipments over the last year for electric furnaces i

out pacing that of gas and oil furnaces. So in a wa

we might need another five years of data, but there'

an indication there, I think, that something is

happening in the marketplace and the consumers ar

buying the 98 percent efficient appliances.

Charlie?

MR. ADAMS: Charlie Adams from Ducane

Just to clarify the devices of the -- blue is fossi

fuel appliances for residential sizes, all shipments

all efficiency levels, is that correct?

MR. JAKOB: That's correct.

MR. ADAMS: And the red is electrica

furnaces and boilers and such things?

(202) 2344433

MR. JAKOB: Electric furnaces and boilers

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

4

1 that. 1992 is when minimum efficiency rules went int

2 effect. And 1992 is when gas furnaces suddenly cos

3 a couple of hundred dollars more than they used to

4 No more drafted appliances except for a clever one

5 their induced draft codes put on the appliance, ther

6 were--put on the appliance, added cost, and that kin

7 of changes the economics. 

8 If you look at the appliance shipmen

9 data, year to date for this year, the same tren

10 holds, that shipments, you know, the increase i

11 shipments over the last year for electric furnaces i

12 out pacing that of gas and oil furnaces. So in a wa

13 we might need another five years of data, but there'

14 an indication there, I think, that something i

15 happening in the marketplace and the consumers ar

16 buying the 98 percent efficient appliances. 

17 Charlie? 

18 MR. ADAMS: Charlie Adams from Ducane

19 Just to clarify the devices of the -- blue is fossi

20 fuel appliances for residential sizes, all shipments

21 all efficiency levels, is that correct? 

22 MR. JAKOB: That's correct. 

23 MR. ADAMS: And the red is electrica

24 furnaces and boilers and such things? 

25 

(202) 234-4433 

MR. JAKOB: Electric furnaces and boilers

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

yes, yes. That's the segregation that I found i

Appliance magazine.

MODERATOR LANGMEAD: Go ahead, sir?

MR. KELLY: George Kelly. Have yo

eliminated any other factors like availability of ga

for instance in areas where construction is going on

MR. JAKOB: No, I haven't. That would b

a worthwhile further analysis to try to understand th

meaning behind these trends.

MODERATOR LANGMEAD: Dave Lewis?

MR. LEWIS: Dave Lewis, Lennox. Does tha

include boiler coil units?

MR. JAKOB: I don't believe so. I aske

that question of GAMA. There's a listing, which th

data is attributed to in Appliance magazine, there'

a listing for gas furnaces and a separate listing fo

oil furnaces, a listing for gas boilers and oi

boilers, electric boilers and electric furnaces, an

I ask if that shipment data of electric furnace

includes fan coil units or not?

MR. LEWIS: Frank, it's my understandin

that Appliance magazine, and what they are reportin

is, what they're reporting is a little bit differen

today than what they were reporting some time ag

because the difference there is your electric furnace

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

4

1 yes, yes. That's the segregation that I found i

2 Appliance magazine. 

3 MODERATOR LANGMEAD: Go ahead, sir? 

4 MR. KELLY: George Kelly. Have yo

5 eliminated any other factors like availability of ga

6 for instance in areas where construction is going on

7 MR. JAKOB: No, I haven't. That would b

8 a worthwhile further analysis to try to understand th

9 meaning behind these trends. 

10 MODERATOR LANGMEAD: Dave Lewis? 

11 MR. LEWIS: Dave Lewis, Lennox. Does tha

12 include boiler coil units? 

13 MR. JAKOB: I don't believe so. I aske

14 that question of GAMA. There's a listing, which th

15 data is attributed to in Appliance magazine, there

16 a listing for gas furnaces and a separate listing fo

17 oil furnaces, a listing for gas boilers and o

18 boilers, electric boilers and electric furnaces, an

19 I ask if that shipment data of electric furnace

20 includes fan coil units or not? 

21 MR. LEWIS: Frank, it's my understandin

22 that Appliance magazine, and what they are reportin

23 is, what they're reporting is a little bit differen

24 today than what they were reporting some time ag

25 because the difference there is your electric furnace

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

13~ RHODE ISLAND AVENUE, N,W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

4

now are really considered -- which previously wer

just air-handling units.

MR. JAKOB: Is that true?

MR. RANFONE: I would like an answer t

that because I know there's a traditional electri

furnace that I'm familiar with, and then the fan coi

units where resistance heat is added in the field. I

that covered, and if it isn't, that would really boos

up the electric because I'm not sure that they'r

labeled. I was trying to get some labels for electri

furnaces, but I can't seem to find any.

MODERATOR LANGMEAD: I'll remind everybod

to identify yourselves before you speak so that we ca

figure out what's on the transcript later on.

MR. RANFONE: Jim Ranfone -

MR. JAKOB: The number associated wit

this is 400,000 electric furnaces a year. Doe

someone know the number related to fan coil units t

know whether that comprehends those or not?

MR. LEWIS: Dave Lewis, Lennox . I can'

report to you the number , but I can say that what w

report has changed because we technically no longe

make electric furnaces , but yet at the same time we'r

supply product both in the gas and electric market

And in the electric market where gas is not availabl

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

4

1 now are really considered -- which previously wer

2 just air-handling units. 

3 MR. JAKOB: Is that true? 

4 MR. RANFONE: I would like an answer t

5 that because I know there's a traditional electri

6 furnace that I'm familiar with, and then the fan coi

7 uni ts where resistance heat is added in the field. I

8 that covered, and if it isn't, that would really boos

9 up the electric because I'm not sure that they'r

10 labeled. I was trying to get some labels for electri

11 furnaces, but I can't seem to find any. 

12 MODERATOR LANGMEAD: I'll remind everybod

13 to identify yourselves before you speak so that we ca

14 figure out what's on the transcript later on. 

15 MR. RANFONE: Jim Ranfone --

16 MR. JAKOB: The number associated wit

17 this is 400, 000 electric furnaces a year. Doe

18 someone know the number related to fan coil units t

19 know whether that comprehends those or not? 

20 MR. LEWIS: Dave Lewis, Lennox. I can

21 report to you the number, but I can say that what w

22 report has changed because we technically no longe

23 make electric furnaces, but yet at.the same time we'r

24 supply product both in the gas and electric marke

25 And in the electric market where gas is not availabl

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

4

and a heat pump is supplied, there is electri

elements within the boiler coil unit which supplie

heat under those conditions where the heat pump isn'

operating, but those are now considered part of th

electric furnace market. So there is a disparity a

far as the information that you are presenting, no

that it is put together inacurately, but as far as th

means in which we're reporting information as far a

what the marketplace is doing.

MR. JAKOB: So there are two points here

perhaps regionalization of this trend or perhap

segregation of what appliances are really considere

electrical --

MODERATOR LANGMEAD: Well, I think it'

what comparison of what was done before 199

afterwards of 1992. The data was recorde

differently. I think that was Dave's point.

MR. RANFONE: Jim Ranfone, AGA. What wa

the difference in the definition prior to 1992 an

then after 1992 because -- key point, if thi

information is skewed because there has been a chang

in definition, we'd like to know what that change wa

that indicated that now electric furnaces or no

electric furnaces -- it was or vice versa. Ca

anybody supply that definition?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.VV.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4

EE-DET-94-101 COMMENT 0D

4

1 and a heat pump is supplied, there is electri

2 elements within the boiler coil unit which supplie

3 heat under those conditions where the heat pump isn

4 operating, but those are now considered part of th

5 electric furnace market. So there is a disparity a

6 far as the information that you are presenting, no

7 that it is put together inacurately, but as far as th

8 means in which we're reporting information as far a

9 what the marketplace is doing. 

10 MR. JAKOB: So there are two points here

11 perhaps regionalization of this trend or perhap

12 segregation of what appliances are really considere

13 electrical 

14 MODERATOR LANGMEAD: Well, I think it'

15 what comparison of what was done before 199

16 afterwards of 1992. The data was recorde

17 differently. I think that was Dave's point. 

18 MR. RANFONE: Jim Ranfone, AGA. What w

19 the difference in the definition prior to 1992 an

20 then after 1992 because key point, if thi

21 information is skewed because there has been a chang

22 in definition, we'd like to know what that change w

23 that indicated that now electric furnaces or n

24 electric furnaces it was or vice versa. 

25 anybody supply that definition? 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 

C

(202) 2
MR. RYAN: Yes, just a quick point. 

don't know --

3 MODERATOR LANGMEAD: Your name, sir.

4 MR. RYAN: Pardon me. Bill Ryan from GRI

5 Just a quick point, and that is, if there was a chang

6 in definition between 1991 and 1992.you wouldn't b

looking in a graph of that shape, instead you'd hav

8 a spike in 1992 and far lower data in 1993 and '94

9 Instead what you've got is a fairly consistent curv

10 there.. So whatever change there was seems to hav

11 been buried in your numbers. The other concern seem

12 to be that you have the electric heating backup fo

13 electric heat pumps. And these numbers of th

14 electric heat pump volume is on the order of a millio

15 a year and you're not talking numbers in that range

16 Clearly those numbers have not been integrated int

17 those numbers.

18 So there may be less unclarity here tha

19 we thing. Whatever the change was between '91 and '9

20 it couldn't have been that dramatic, if you jus

21 concentrate on the '93 and '94 numbers.

22 MODERATOR LANGMEAD: Frank, can you help

23 MR. STANONIK: Frank Stanonik with GAMA

24 No, I can't help because I don't know how we'r

25 defining electric furnace in our statistics program

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND" AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

4

1 MR. RYAN: Yes, just a quick point. 

2 don't know 

3 MODERATOR LANGMEAD: Your name, sir. 

4 MR. RYAN: Pardon me. Bill Ryan from GR

5 Just a quick pOint, and that is, if there was a chang

6 in definition between 1991 and 1992 you wouldn't b

7 looking in a graph of that shape, instead you'd hav

8 a spike in 1992 and far lower data in 1993 and '94

9 Instead what you've got is a fairly consistent curv

10 there. So whatever change there was seems to hav

11 been buried in your numbers. The other concern seem

12 to be that you have the electric heating backup fo

13 electric heat pumps. And these numbers of th

14 electric heat pump volume is on the order of a millio

15 a year and you're not talking numbers in that range

16 Clearly those numbers have not been integrated int

17 those numbers. \ 

18 So there may be less unclarity here tha

19 we thing. Whatever the change was between' 91 and' 9

20 it couldn't have been that dramatic, if you ju

21 concentrate on the '93 and '94 numbers. 

22 MODERATOR LANGMEAD: Frank, can you help

23 MR. STANONIK: Frank Stanonik with GAM

24 No, I can't help because I don't know how we'

25 defining electric furnace in our statistics program

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

5

7

10

11

12

13

.14

15

16

17

18

19

20

21

22

23

24

25

I assume you 've talked to someone else in our offic

and I don't really know that question. And I wa

trying to let Frank Jakob go through his presentatio

here, but I am getting concerned that we're gettin

off track here. I mean we're talking about efficienc

descriptors and there is a concern that people ar

being or getting the wrong message that a 98 percen

electric furnace is. the superior product to a 7

percent or an 80 percent AFUE gas furnace or whatever

But the point is, is if we're talkin

about efficiency descriptors, the reason that'

happening is because they don't have the cos

information or they're not getting the message on th

cost information. And I would tell you that anybod

who has only an electric furnace in their house an

doesn't have gas available well knows, well knows, i

they're in any kind of a winter climate area, the cos

of operating that furnace, and they know it's a lot

okay.

An so, if there is a problem here, th

problem is that the people for whatever reasons ar

not getting information on the cost, the cost, o

operation for them of that appliance, all right. An

the fact is, that's got nothing to do with th

efficiency descriptors of this, it's one step farther

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

4

1 I assume you've talked to someone else in our offic

2 and I don't really know that question. And I w

3 trying to let Frank Jakob go through his presentatio

4 here, but I am getting concerned that we're gettin

5 off track here. I mean we're talking about efficienc

6 descriptors and there is a concern that people ar

7 being or getting the wrong message that a 98 percen

8 electric furnace is the superior product to a 7

9 percent or an 80 percent AFUE gas furnace or whateve

10 But the point is, is if we're talkin

11 about efficiency descriptors, the reason that

12 happening is because they don't have the co

13 information or they're not getting the message on th

.14 cost information. And I would tell you that anybod

15 who has only an electric furnace in their house an

16 doesn't have gas available well knows, well knows, i

17 they're in any kind of a winter climate area, the co

18 of operating that furnace, and they know it's a lo

19 okay. 

20 An so, if there is a problem here, th

21 problem is that the people for whatever reasons a

22 not getting information on the cost, the cost, 

23 operation for them of that appliance, all right. A

24 the fact is, that's got nothing to do with th

25 efficiency descriptors of this, it I S one step farthe

(202) 234-4433 , . 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

it's taking that efficiency descriptor and giving the

the tools which in fact exist, they don't know it, bu

the tools that exist that say this is how yo

translate that to dollars, which is what I think w

all believe the consumer really cares about.

MODERATOR LANGMEAD: Joe Mattingly, do yo

want to answer?

MR. MATTINGLY: Joe Mattingly. Let m

just add to that, you know, the shipments data may b

correct that Frank Jakob put on the screen there, bu

obviously he's got some fallibilities in his databas

there which have already been illuminated here

People may be buying electric furnaces for som

reason , but it isn't because they are looking at a

electric furnace label versus a gas furnace label an

deciding oh, well I'll buy the electric one. Becaus

we sincerely believe that consumers don't make thei

purchase decision on the basis of AFUE labels o

furnaces . It has nothing to do with.

MODERATOR LANGMEAD: yes.

MR. MARRAN : John Marran, Energy Kinetics

I think some of these factors are correct. I thin

it's pointing to the fact that Americans buy firs

cost and maybe the $200.00 to $300.00 extra about t

get the efficiency of gas furnaces up is increasin

(202) 2344433

NEAL 'R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, O.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

4

1 it's taking that efficiency descriptor and giving the

2 the tools which in fact exist, they don't know it, bu

3 the tools that exist that say this is how yo

4 translate that to dollars, which is what I think w

5 all believe the consumer really cares about. 

6 MODERATOR LANGMEAD: Joe Mattingly, do yo

7 want to answer? 

8 MR. MATTINGLY: Joe Mattingly. Let m

9 just add to that, you know, the shipments data may b

10 correct that Frank Jakob put on the screen there, b

11 obviously he's got some fallibili ties in his databa

12 there which have already been illuminated here

13 People may be buying electric furnaces for som

14 reason, but it isn't because they are looking at a

15 electric furnace label versus a gas furnace label an

16 deciding oh, well I'll buy the electric one. Becau

17 we sincerely believe that consumers don't make the

18 purchase decision on. the basis of AFUE labels 

19 furnaces. It has nothing to do with. 

20 MODERATOR LANGMEAD: yes. 

21 MR. MARRAN: John Marran, Energy Kinetic

22 I think some of these factors are correct. I thin

j 

23 it's pointing to the fact that Americans buy fir

24 cost and maybe the $200.00 to $300.00 extra about 

25 get the efficiency of gas furnaces up is increasin

(202) 234-4433 

NEALA. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

4

the builder and the consumer purchase of the lowe

cost electric furnace and maybe what we really have t

talk about is life cycle cost in evaluating th

efficiency of equipment. And the consumer at thi

point is buying based on first cost, not AFUE label

I didn't come in here thinking that all

but I think maybe the labeling program, if you'r

going to make it ballast it has to show people lif

cycle cost of operating the appliance compared to it

first cost. And those numbers would dramaticall

change if a person buying a house saw the applianc

life cycle cost and they -- just a suggestion.

MODERATOR LANGMEAD : Yes, Dan?

MR. DEMPSEY: Dan Dempsey , Carrier. 

guess I would urge that the ship numbers be researche

as to why there was a discrete jump. Because I kno

from Carrier's perspective,,if there was a significan

jump in electric furnace shipments in the industry a

the expense of other types of products, we woul

certainly be aware of that. And, you know, we don'

have any data that indicates that there is a hug

growing electric furnace market out there, so I woul

urge that the statistics be reviewed as to why th

jump. It could be you have a manufacturer tha

started reporting in 92 that hadn't reported in year

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

4

1 the builder and the consumer purchase of the lowe

2 cost electric furnace and maybe what we really have t

3 talk about is life cycle cost in evaluating th

4 efficiency of equipment. And the consumer at thi

5 pOint is buying based on first cost, not AFUE label

6 I didn't come in here thinking that all

7 but I think maybe the labeling program, if you'r

8 going to make it ballast it has to show people lif

9 cycle cost of operating the appliance compared to it

10 first cost. And those numbers would dramaticall

11 change if a person buying a house saw the applianc

12 life cycle cost and they -- just a suggestion. 

13 MODERATOR LANGMEAD: Yes, Dan? 

14 MR. DEMPSEY: Dan Dempsey, Carrier. 

15 guess I would urge that the ship numbers be researche

16 as to why there was a discrete jump. Because I kno

17 from Carrier's perspective, . if there was a significan

18 jump in electric furnace shipments in the indust~ a

19 the expense of other types of products, we wou

20 certainly be aware of that. And, you know, we don

21 have any data that indicates that there is a hug

22 growing electric furnace market out there, so I wou

23 urge that the statistics be reviewed as to why th

24 jump. It could be you have a manufacturer tha

25 started reporting in '92 that hadn't reported in yea

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
4

2

3

4

5

9

10

11

12

13

14

15

.16

17

18

19

20

21

22

23

24

25

past, so.

MODERATOR LANGMEAD: Okay. Yes, Charlie

MR. ADAMS: Charlie Adams with Ducane

Just an observation to provide some input on to th

apparent discontinuity in the data in '92. W

shouldn't be lulled in to believing that the decisio

based on the information on the yellow hang tag ha

anything to do with that data in ' 92, accurate or not

because the efficiency number on the little bar scal

showing where this appliance compares with othe

appliances, in '92 there was not a scale and was no

a number on the yellow tag on furnaces.

MODERATOR LANGMEAD: Thank you, Charlie

I was just going to point that out, thank you.

MR. SWEETSER: Rick Sweetser with th

American Gas Cooling Center. I want to just get u

thinking, we're talking in the buggy whip days. Wha

I mean by that is, we 're looking at today and pas

history. I know my brother from the HVAC industry

will not publicly talk about this, so I'll put it o

the table.

The future of the HVAC industry is goin

to change like the energy industry. We now have a tw

tier distribution, and if you talk in the back room

of what we're going to have in ten years or 15 year

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

4

1 past, so. 

2 MODERATOR LANGMEAD: Okay. Yes, Charlie

3 MR. ADAMS: Charlie Adams with Ducane

4 Just an observation to provide some input on to th

5 apparent discontinuity in the data in '92. W

6 shouldn't be lulled in t9 believing that the decisio

7 based on the information on the yellow hang tag ha

8 . anything to do with that data in '92, accurate or not

9 because the efficiency number on the little bar scal

10 showing where this appliance compares with othe

11 appliances, in '92 there was not a scale and was no

12 a number on the yellow tag on furnaces. 

13 MODERATOR LANGMEAD: Thank you, Charlie

14 I was just going to paint that out, thank you. 

15 MR. SWEETSER: Rick Sweetser with th

.16 American Gas Cooling Center. I want to just get u

17 thinking, we're talking in the buggy whip days. Wh

18 I mean by that is, we're looking at today and pas

19 history. I know my brother from the HVAC industr

20 will not publicly talk about this, so I'll put it o

21 the table. 

22 The future of the HVAC industry is goin

23 to change like the energy industry. We now have a tw

24 tier distribution, and if you talk in the back room

25 of what we're going to have in ten years or 15 year

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

5

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

is a one tier distribution system. You're alread

starting to see if when people who have companies lik

Home Depot. So even though we are currently going t

market through dealers and distributors, we'r

probably going to have some changes in the future an

we really should look forward with anything that w

do, not backward. And we have to put that int

consideration and that may make whatever types o

labeling that we put on more important, not les

important, when Home Depot people by the way, my Hom

Depot, when you can buy an split system today for 

whole house.

MODERATOR LANGMEAD: Let me just add

summarize some little points'that I've heard and yo

can try throwing rocks this way. I think we would al

like to know and have some further analysis of th

shipment data so that we have some confidence what'

being shipped and how it compares to the past. W

need some help in that way and hopefully we can figur

out a way to get that job done.

Secondly, there is another need that'

been expressed by virtually everybody and that is t

find out exactly what motivates a consumer to make 

choice between one furnace, one heating type an

another. And we really haven't done that kind, o

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

5

1 is a one tier distribution system. You I re alread

2 starting to see if when people who have companies lik

3 Home Depot. So even though we are currently going t

4 market through dealers and distributors, we'r

5 probably going to have some changes in the future an

6 we really should look forward with anything that w

7 do, not backward. And we have to put that int

8 consideration and that may make whatever types o

9 labeling that we put on more important, not les

10 important, when Home Depot people by the way, my Hom

11 Depot, when you can buy an split system today for 

12 whole house. 

13 MODERATOR LANGMEAD: Let me just add

14 summarize some little points' that I've heard and yo

15 can try throwing rocks this way. I think we would al

16 like to know and have some further analysis of th

17 shipment data so that we have some confidence what

18 being shipped and how it compares to the past. W

19 need some help in that way and hopefully we can figur

20 out a way to get that job done. 

21 Secondly, there is another need that

22 been expressed by virtually everybody and that is t

23 find out exactly what motivates a consumer to make 

24 choice between one furnace, one heating type an

25 another. 

(202) 234-4433 

And we really haven't done that kind, o

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
4

5

7

8

9

10

11

12

13

.14

15

16

17

18

19

20

21

22

23

24

25

collectively put that together.

I tend to agree with what's been said 

number of times, I don't think the label on th

furnace is what's making that choice. But there i

something making that choice, and we need to know wha

that is so we can properly communicate with consumers

Dave Lewis?

MR. LEWIS: Dave Lewis of Lennox. On

thing we did before we came to this meeting was t

kind of study when people were purchasing wha

product. And it's very clear, Jack, that our sales o

Pultz furnaces were dynamics during a period of tim

when we had an energy oil crisis.

When the cost of energy and the awarenes

of the cost of 'energy was escalating dynamically

consumers were making a decision based on th

information that they had at that time, an

interestingly that same information remains availabl

today. So at least from our review of our sales data

we're seeing that consumers do make a decision base

on what it costs them to operate their appliance.

Now, there is a one disconnect in that

and that is where gas isn't available, obviously ga

products are not purchased.,

MODERATOR LANGMEAD: Yes, Jim?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

5

1 collectively put that together. 

2 I tend to agree with what's been said 

3 number of times, I don't think the label on th

4 furnace is what's making that choice. But there i

5 something making that choice, and we need to know wh

6 that is so we can properly communicate with consumers

7 Dave Lewis? 

8 MR. LEWIS: Dave Lewis of Lennox. On

9 thing we did before we came to this meeting was t

10 kind of study when people were purchasing wh

11 product. And it's very clear, Jack, that our sales o

12 Pultz furnaces were dynamics during a period of tim

13 when we had an energy oil crisis . 

. 14 When the cost of energy and the awarene

15 of the cost of energy was escalating dynamically

16 consumers were making a decision based on th

17 information that they had at that time, an

18 interestingly that same information remains availab

19 today. So at least from our review of our sales data

20 we're seeing that consumers do make a decision base

21 on what it costs them to operate their appliance. 

22 Now, there is a one disconnect in tha

23 and that is where gas isn't available, obviously g

24 products are not purchased. 

25 

(202) 234-4433 

MODERATOR LANGMEAD: Yes, Jim? 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

5

MR. RANFONE: Jim Ranfone again. I jus

wanted to clarify a couple of things at least from ou

perspective. One, the data that was presente

apparently people are taking issuewith it, but it wa

presented based on industry input, not AGA's input

We looked at data, in fact I've got projections tha

have been brought out for the next five years on

electric furnaces, electric warm air furnaces, tha

have been presented that show an increase. So before

we go ahead and criticize the data as being flawed,

this has been presented to us by the industry.

Now, if one was to interpret what a

electric warm air furnace is, if that's different than

it was in 1992, we'd like to know about it. I think

the point that Frank was making is that there is a

trend upward.

Number two, on the label itself, our

concern is that the label is now going -- thi

December and one year prior to that they weren't

labeled. That's the issue. Whether you believe in

the effectiveness of labeling problem or not, th

labels are physically going to be put on units and

they are going to show a 98 percent, 100 percen

electric furnace AFUE number. That's what our concern

is, not what happened in 1992 if they weren't labeled,

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

5

1 MR. RANFONE: Jim Ranfone again. I jus

2 wanted to clarify a couple of things at least from ou

3 perspective. One, the data that was presente

4 apparently people are taking issue with it, but it wa

5 presented based on industry input, not AGA's input

6 We looked at data, in fact I've got projections tha

7 have been brought out for the next five years o

8 electric furnaces, electric warm air furnaces, tha

9 have been presented that show an increase. So befor

10 we go ahead and criticize the data as being flawed

11 this has been presented to us by the industry. 

12 Now, if one was to interpret what a

13 electric warm air furnace is, if that I s different tha

14 it was in 1992, we'd like to know about it. I thin

15 the point that Frank was making is that there is 

16 trend upward. 

17 Number 'two, on the label itself, ou

18 concern is that the label is now going thi

19 December and one year prior to that they weren

20 labeled. That's the issue. Whether you believe i

21 the effecti veness of labeling problem or not, th

22 labels are physically going to be put on units an

23 they are going to show a 98 percent, 100 percen

24 electric furnace AFUE number. That's what our concer

25 is, not what happened in 1992 if they weren't labeled

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 23
1

2

3

4

5

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

5

that the coming products -- what are we going to sa

five years from now, oh yes, by the way the labelin

program was effective, they are buying a lot more

electric furnaces.

MODERATOR LANGMEAD: Yes?

MR. RYAN: Bill Ryan from Gas Research

again. Just a bit of clarification or I just wanted

to add to Rich's comment. In the past the standard

way of buying furnaces and air conditions has been

that you have the dealer come into your home and

present you with your options and try to translate al

the technical details for you and what it's going t

cost, what it's going to cost to operate and so on and

so forth. And there was a time when a large number o

products were sold by home delivery right down to

milk, but those days are no longer.

There is a 'very strong indication, it'

not a sure thing, but there's a strong indication that

there is going to be a large market segment in th

future which involves the consumer going to a store

Home Depot, Sears, whatever, and standing in front o

a long line of furnace and air conditioning product

and deciding, and this store may do installation

someone else may do installation, whatever, th

consumer would be confronted with this selectio

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

5

1 that the coming products -- what are we going to sa

2 five years from now, oh yes, by the way the labelin

3 program was effective, they are buying a lot mor

4 electric furnaces. 

5 MODERATOR LANGMEAD: Yes? 

6 MR. RYAN: Bill Ryan from Gas Researc

7 again. Just a bit of clarification or I just wante

8 to add to Rich's comment. In the past the standar

9 way of buying furnaces and air conditions has bee

10 that you have the dealer come into your home an

11 present you with your options and try to translate al

12 the technical details for you and what it's going t

13 cost, what it's going to cost to operate and so on an

14 so forth. And there was a time when a large number o

15 products were sold by home deli very right down t

16 milk, but those days are no longer. 

17 There is a very strong indication, it'

18 not a sure thing, but there's a strong indication tha

19 there is going to be a large market segment in th

20 future which involves the consumer going to a store

21 Home Depot, Sears, whatever, and standing in front o

22 a long line of furnace and air conditioning product

23 and deciding, and this store may do installation

24 someone else may do installation, whatever, th

25 consumer would be confronted with this selectio

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 23
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

5

retail. And what he's going to see is a large

collection of gray boxes and yellow tags with these

numbers on them, and no really to translate them fo

him.

That makes the yellow tags perhaps more

important in the future than they've been in the past.

And, therefore, I think a point where we have to

really ask serious questions about how communicative

these things are across the entire range of appliance

to the consumer that is not all that familiar with a

once or twice in a lifetime decision of buying a

furnace or air conditioner.

MODERATOR LANGMEAD: Dave Lewis?

MR. LEWIS: Dave Lewis, Lennox. I thin

what's being presented is a great idea, I just don'

see any data that documents that that is in fact th

trend that's occurring. In fact contrary to that,

consumers need to buy products that fit the home, not

generic cookie-cutter products that may be bought tha

are too large or too small to adequately take care o

the comfort of the space that they need.

I think the real key is rather than mas

merchandising, what we're really seeing in th

marketplace today is much more nitch marketing, whic

means that the product is applied to the specific nee

(202) 234-44.'33

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

5

1 retail. And what he's going to see is a larg

2 collection of gray boxes and yellow tags with thes

3 numbers on them, and no really to translate them fo

4 him. 

5 That makes the yellow tags perhaps mor

6 important in the future than they've been in the past

7 And, therefore, I think a point where we have to 

8 really ask serious questions about how communicativ

9 these things are across the entire range of appliance

10 to the consumer that is not all that familiar with 

11 once or twice in a lifetime decision of buying 

12 furnace or air conditioner. 

13 MODERATOR LANGMEAD: Dave Lewis? 

14 MR. LEWIS: Dave Lewis, Lennox. I think 

15 what's being presented is a great idea, I just don'

16 see any data that documents that that is in fact th

17 trend that's occurring. In fact contrary to that

18 consumers need to buy products that fit the home, no

19 generic cookie-cutter products that may be bought tha

20 are too large or too small to adequately take care o

21 the comfort of the space that they need. 

22 I think the real key is rather than mas

23 merchandising, what we're really seeing in th

24 marketplace today is much more nitch marketing, whic

25 means that the product is applied to the specific nee

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N,W. 

WASHINGTON, D.C. 20005 (202) 23
2

3

4

5

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

of the consumer rather, than one product fits all. S

contrary to what has been presented as far as a lon

line of furnaces, all of which would have beautifu

yellow tags on that they could make decisions off of

we see instead a much wiser consumer that's making th

purchase that meets the need of their specifi

requirements.

MODERATOR LANGMEAD: Let me try coverin

just one more thing, and I think we're going to com

back into this thing, but I think we' ve got som

agreement on some things that DOE or that industry ca

do, and I' d like to get those kind of agreements down

I'm not criticizing Frank Jakob' s data 

shipments or sales, but I think everybody would hav

more comfort in the numbers if we had a good clea

picture of what the sales pattern was in the past a

compared to today. `

Does anybody have any objection to tha

being an agreement out of this thing, not criticizin

what' s there , but just you'd like a little bette

understanding that we' ve compared apples to apples

The second point being that -- I'll ge

him in just a minute . The second point being tha

there is some need -- I don't know how much FTC ha

done in looking at motivation of consumers in buyin

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1 of the consumer rather, than one product fits all. S

2 contrary to what has been presented as far as a lon

3 line of furnaces, all of which would have beautifu

4 yellow tags on that they could make decisions off o

5 we see instead a much wiser consumer that's making th

6 purchase that meets the need of their specif

7 requirements. 

8 MODERATOR LANGMEAD: Let me try coverin

9 just one more thing, and I think we're going to com

10 back into this thing, but I think we've got som

11 agreement on some things that DOE or that industry ca

12 do, and I'd like to get those kind of agreements dow

13 I'm not criticizing Frank Jakob's data o

14 shipments or sales, but I think everybody would hav

15 more comfort in the numbers if we had a good cle

16 picture of what the sales pattern was in the past 

17 compared to today. 

18 Does anybody have any objection to th

19 being an agreement out of this thing, not criticizin

20 what's there, but just you'd like a little bett

21 understanding that we've compared apples to apples

22 The second point being that I'll g

23 him in just a minute. The second point being th

24 there is some need -- I don't know how much FTC h

25 done in looking at motivation of consumers in buyi

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

5

particularly furnaces or air conditioners, whethe

that label does anything for those people. Certainl

the label is going to be there.. If there was marke

research done to see what motivated homeowners in

purchases, what motivated builders in purchases, wha

motivated the decision in high rise buildings versus

single story building versus townhouses, that dat

would all be useful in better designing of whateve

label is going to be on there sometime in the future

Can I get any understanding that that i

also something that would be valuable for everybody t

have so we're all making decisions off of a good soun

database? Unless somebody shoots me, we'll count o

that.

Frank, you had a point on the first one

MR. STANONIK: Yes, I take exception t

the first one about it would be interesting to ge

better clarification on the graph. And my questio

would be why? The graph showed you relative growth

all right, so the discussion we're talking about

however it's defined , 400,000 electric furnaces annua

shipments, we're talking about shipments of just ga

furnaces of what, about 2 million a year?

So obviously if I -- the other thing tha

you lose there is the gas furnaces aren't going down

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

5

1 particularly furnaces or air conditioners, whethe

2 that label does anything for those people. Certainl

3 the label is going to be there. If there was marke

4 research done to see what moti vated homeowners i

5 purchases, what motivated builders in purchases, wha

6 motivated the decision in high rise buildings versu

7 single story building versus townhouses, that dat

8 would all be useful in better designing of whateve

9 label is going to be on there sometime in the future

10 Can I get any understanding that that i

11 also something that would be valuable for everybody t

12 have so we're all making decisions off of a good soun

13 database? Unless somebody shoots me, we'll count o

14 that. 

15 Frank, you had a point on the first one

16 MR. STANONIK: Yes, I take exception t

17 the first one about it would be interesting to ge

18 better clarification on the graph. And my questio

19 would be why? The graph showed you relative growth

20 all right, so the discussion we're talking about

21 however it's defined, 400,000 electric furnaces annua

22 shipments, we're talking about shipments of just ga

23 furnaces of what, about 2 million a year? 

24 So obviously if I -- the other thing tha

25 you lose there is the gas furnaces aren't going down

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
2

31

4!

12

13

14

15

16

17

18

19

20

21

22

23

24

25

All right, 2.5 million. The shipments of gas furnace

are not going down. But if my base is 400,000 rathe

than 2.5 million, well then a growth of 100,000 look

much bigger, and that's what you're seeing. And m

question is, what's the point of that?

The fact is that gas furnace shipments ar

still going up, they're not -- it doesn't appear to b

suffering in direct or any proportion to this apparen

growth in electric furnaces.

And the other significant thing is, if yo

look at new housing starts, new ,housing starts, ga

heating dominates, which again seems to counteract

So what's the point of this issue? I don't see th

relevancy and why discuss it further.

MODERATOR LANGMEAD: Well, let me ju

answer you, if I can, briefly on that. I've talked t

a lot of furnace manufacturers that make gas furnaces

oil furnaces, and electric furnaces, and I haven

found anybody yet that told me that they thought th

electric furnace industry was expanding at some gre

rate. And I guess I want to get a handle, I think i

would be good to have a handle on that because Frank

data shows something otherwise.

Dan?

MR. DEMPSEY: Dan Dempsey, Carrier. 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4

EE-DET-94-101 COMMENT 0D

Ii All right, 2.5 million. The shipments of gas furnac

2 are not going down. But if my base is 400,000 rath

3 than 2.5 million, well then a growth of 100,000 loo

i 

4! much bigger, and that's what you're seeing. And 

I 

9 

101 

I 

11 

12 

question is, what's the point of that? 

The fact is that gas furnace shipments a

still going up, they're not -- it doesn't appear to 

suffering in direct or any proportion to this appare

growth in electric furnaces. 

And the other significant thing is, if y

look at new housing starts, new ,housing starts, g

heating dominates, which again seems to counterac

13 So what's the point of this issue? I don't see th

14 relevancy and why discuss it further. 

15 MODERA TOR LANGMEAD: Well, let me ju

16 answer you, if I can, briefly on that. I've talked 

17 a lot of furnace manufacturers that make gas furnace

18 oil furnaces, and electric furnaces, and I haven

19 found anybody yet that told me that they thought th

20 electric furnace industry was expanding at some gre

21 rate. And I guess I want to get a handle, I think 

22 would be good to have a handle on that because Frank

23 data shows something otherwise. 

24 Dan? 

25 MR. DEMPSEY: Dan Dempsey, Carrier. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W, 

WASHINGTON. D,C. 20005 (202) 
1

2

3

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

5

guess the other issue in the statistics is, is i

replacement market or new construction? If it'

replacement market, then AFUE or whatever it'

labeled, can be sold. But if it isn't replacemen

market then, you know, there may not be gas availabl

because it's replacing an old electric furnace. I

it's a new construction market, that's sold to th

builders, so really you need to know whether thos

statistics are biased towards replacement or new

construction.

MODERATOR LANGMEAD: And you've got t

look at them segmented into new replacement, hig

rise, single family, etcetera, so you know what'

going on.

Gene Margolis?

MR. MARGOLIS: Eugene Margolis, Departmen

of Energy, Office of General Counsel. If this grap

is a graph of the growth , could we also have one o

just of sales to see what the volume of a electri

furnaces sold as against the volume of gas furnaces

sold per year?

My second point is that , if it' s bein

trying to say that the growth of electric furnaces

over gas furnaces is because of the higher AFUE value

on electric furnaces and a lower on gas furnaces, 

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

5

1 guess the other issue in the statistics is, is i

2 replacement market or new construction? If it'

3 replacement market, then AFUE or whatever it'

4 labeled, can be sold. But if it isn't replacemen

5 market then, you know, there may not be gas availabl

6 because it's replacing an old electric furnace. I

7 .i t 's a new construction market, that's sold to th

8 builders, so really you need to know whether thos

9 statistics are biased towards replacement or ne

10 construction. 

11 MODERATOR LANGMEAD: And you've got t

12 look at them segmented into new replacement, hig

13 rise, single family, etcetera, so you know what'

14 going on. 

15 Gene Margolis? 

16 MR. MARGOLIS: Eugene Margolis, Departmen

17 of Energy, Office of General Counsel. If this grap

18 is a graph of the growth, could we also have one o

19 just of sales to see what the volume of a electri

20 furnaces sold as against the volume of gas furnace

21 sold per year? 

22 My second point is that, if it's bein

23 trying to say that the growth of electric furnace

24 over gas furnaces is because of the higher AFUE valu

25 on electric furnaces and a lower on gas furnaces, 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
2

3

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

don't think that just by showing the growth rate woul

be quite to the reasons why. And the reason why bein

said that it's the higher AFUE for electric. I don'

think that one necessitates the other.

And my final point is, if the discussio

is going away from the energy -- well, going away fro

the energy descriptor and talking about ,wha

information is on the label, then I believe this i

not the place for that. It is before the FTC becaus

the FTC is the sole authority on labeling, and 

thought one of the things that we were talking abou

here is a possible new energy efficiency descriptor

that would take into consideration the electric energ

being used in a gas furnace. And I understand wha

the gas people -- that it lowers the AFUE, but i

doesn't do anything to the electric. And that, 

mean , is what the law says , that we' re supposed to us

site and not source.

So I want to get back to the other poin

of the labeling where people were talking about mayb

the information on the label might be "one-sided,

then maybe , if that's what you really feel, then mayb

you can come up with some way that would be okay wit

the Federal Trade Commission to somehow balance thos

two appliances, gas and electric, or an oil furnac

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

5

1 don't think that just by showing the growth rate wou

2 be quite to the reasons why. And the reason why bein

3 said that it's the higher AFUE for electric. I don

4 think that one necessitates the other. 

5 And my final point is, if the discussio

6 is going away from the energy -- well, going away fro

7 the energy descriptor and talking about ,wh

8 information is on the label, then I believe this i

9 not the place for that. It is before the FTC becaus

10 the FTC is the sole authority on labeling, and 

11 thought one of the things that we were talking abou

12 here is a possible new energy efficiency descriptor

13 that would take into consideration the electric energ

14 being used in a gas furnace. And I understand wh

15 the gas people -- that it lowers the AFUE, but i

16 doesn't do anything to the electric. And that, 

17 mean, is what the law says, that we're supposed to us

18 site and not source. 

19 So I want to get back to the other poin

20 of the labeling where people were talking about may

21 the information on the label might be "one-sided

22 then maybe, if that's what you really feel, then may

23 you can corne up with some way that would be okay wi

24 the Federal Trade Commission to somehow balance tho

25 two appliances, gas and electric, or an oil furnac

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
6

2

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

and an electric furnace.

So if we're talking more about the label

that's with the FTC, but I thought we were trying t

4

talk about here the energy descriptors.

MODERATOR LANGMEAD : Anybody want t

respond to Gene?

Dave Lewis?

MR. LEWIS: Dave Lewis, Lennox. There i

basic inaccuracy in the assumption that people make

decisions in buying their furnace based on the data o

the yellow label. And I guess that needs to be

corrected. People are not making that decision by 

yellow label. They don't see the yellow label unti

it's installed in the house. So I think the more w

focus on the yellow label, which is fraught wit

inaccuracy as far as the underlying assumption that it

actually has value, I think we're wasting our time.

I think much better, we need to be addressing some of

the issues outside of that because actually decision

have not been made on the yellow label in the past

And our experience in air conditioning, which is no

the topic here is that decisions are not made on th

yellow label even though they're installed there.

MODERATOR LANGMEAD: George Kelly?

MR. KELLY: I'd like to --

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

6

1 and an electric furnace. 

2 So if we're talking more about the label

3 that's with the FTC, but I thought we were trying t

4 talk about here the energy descriptors. 

5 MODERATOR LANGMEAD: Anybody want to 

6 respond to Gene? 

7 Dave Lewis? 

8 MR. LEWIS: Dave Lewis, Lennox. There i

9 a basic inaccuracy in the assumption that people mak

10 decisions in buying their furnace based on the data o

11 the yellow label. And I guess that needs to b

12 corrected. People are not making that decision by 

13 yellow label. They don't see the yellow label unti

14 it's installed in the house. So I think the more w

15 focus on the yellow label, which is fraught wit

16 inaccuracy as far as the underlying assumption that i

17 actually has value, I think we're wasting our time

18 I think much better, we need to be addressing some o

19 the issues outside of that because actually decision

20 have not been made on the yellow label in the past

21 And our experience in air conditioning, which is no

22 the topic here is that decisions are not made on th

23 yellow label even though they're installed there. 

24 

25 

(202) 234-4433 

MODERATOR LANGMEAD: George Kelly? 

MR. KELLY: I'd like to 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 23
6

1

2

3

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

George.

MODERATOR LANGMEAD: A little louder

MR. KELLY: I'd like to agree with Gene

you know, and what you were saying, we need som

information on how consumers make decisions. -- w

used to field a lot of questions on what type furnac

we should should buy and so on and so forth, not s

much anymore. But I never encountered a consumer tha

did not realize that the cost of electric energy was

three times the cost of gas. And even it said 98 o

even if it said 200 efficiency on the label, they wer

not going to buy electric unless they had to.

they'd look at whether gas was

available or oil was available in their area, and i

wasn't, then they would consider whether they wante

a heat pump or an electric furnace and what the first

cost was versus the operating cost.

But that efficiency of 98 percent in a

electric furnace, I don't think ever swayed somebody

to buy an electric furnace over a gas furnace.

MODERATOR LANGMEAD: Charlie Adams?

MR. ADAMS: Charlie Adams, Ducane. W

have reason to believe, or I have reason to believ

that some of presumably magnificent growth in the

electric furnace rate of increase, at least for the

(202)234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 234

EE-DET-94-101 COMMENT 0D

6

1 MODERATOR LANGMEAD: A little louder

2 George. 

3 MR. KELLY: I'd like t.o agree with Gene

4 you know, and what you were saying, we need som

5 information on how consumers make decisions. -- w

6 used to field a lot of questions on what type furnac

7 we should should buy and so on and so forth, not s

8 much anymore. But I never encountered a consumer tha

9 did not realize that the cost of electric energy wa

10 three times the cost of gas. And even it said 98 o

11 even if it said 200 efficiency on the label, they wer

12 not going to buy electric unless they had to. 

13 So they'd look at whether gas wa

14 available or oil was available in their area, and i

15 wasn't, then they would consider whether they wante

16 a heat pump or an electric furnace and what the firs

17 cost was versus the operating cost. 

18 But that efficiency of 98 percent in a

19 electric furnace, I don't think ever swayed somebod

20 to buy an electric furnace over a gas furnace. 

21 MODERATOR LANGMEAD: Charlie Adams? 

22 MR. ADAMS: Charlie Adams, Ducane. W

23 have reason to believe, or I have reason to believ

24 that some of presumably magnificent growth in th

25 electric furnace rate of increase, at least for th

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

, WASHINGTON, D.C. 20005 (202) 23
6

1

3

6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

post ' 92 timeframe , is directly related to that

related to not caring about whether it's more

efficient, less efficient, or whatever.

We have reason to believe there was a jum

in '92 when the lower cost gas appliances, the 7

percent draft equipment went away and 78 became th

minimum, the standard cost of a cheap furnace went u

dramatically. There was a substantial portion o

people out there and it doesn't matter what th

efficiency is, my heating, appliance broke and I got t

go buy a new one, and I can only spend (x) dollars

and that's where I believe some of that first yea

ripple of stupendous grown Ken put on the chart may b

related to. I don't care what the efficiency is o

what it cost to run, I only have this much money t

buy a new one, so. Let's not get too confused abou

that ripple in the data.

MODERATOR LANGMEAD: Other comments?

Yes?

MR. FRITTS: On this discussion of th

descriptor or what do we need to talk about, how doe

the descriptor lead to the label, I know Batelle ha

done some interesting work on combining or integratin

,costs and energy. And if you'd give Frank Jakob a fe

more minutes, I think he could summarize that. And 

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

6

1 post' 92 timeframe, is directly related to that

2 related to not caring about whether it's mor

3 efficient, less efficient, or whatever. 

4 We have reason to believe there was a jum

5 in' 92 when the lower cost gas appliances, the 7

6 percent draft equipment went away and 78 became th

7 minimum, the standard cost of a cheap furnace went u

8 dramatically. There was a substantial portion o

.9 people out there and it doesn't matter what th

10 efficiency is, my heating appliance broke and I got t

11 go buy a new one, and I can only spend (x) dollars

12 and that's where I believe some of that first yea

13 ripple of stupendous grown Ken put on the chart may b

14 related to. I don't care what the efficiency is o

15 what it cost to run, I only have this much money t

16 buy a new one, so. Let's not get too confused abou

17 that ripple in the data. 

18 MODERATOR LANGMEAD: Other comments? 

19 Yes? 

20 MR. FRITTS: On this discussion of th

21 descriptor or what do we need to talk about, ho.w doe

22 the descriptor lead to the label, I know Batelle ha

23 done some interesting work on combining or integratin

24 \ costs and energy. And if you'd give Frank Jakob a fe

25 more minutes, I think he could summarize that. And 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

4

5

6

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

6

think it's worth putting it on the table at least fo

discussions purposes. Go you want to give him thre

minutes?

MODERATOR LANGMEAD: That's fine with me

I think we've got -- it's 10:20 and we're going t

quite this discussion at 11:00 o'clock. We've got

just a couple more subjects to touch on, and so I'l

let Frank go ahead now. I think we have time.

MR. FRITTS: Can we get a explanation fo

this?

MR. JAKOB: You had asked for an

explanation of the shipment data, and this I took out

of Air Conditioning News and Appliance magazines a

far back as I could find them in our files, '87

through recently. And -- set of bars are -- firs

shipments over time. This set of bars are the heat

pump shipments over time. This considers centra

space heating, and you put air conditioners in here,

they're way up to 5 or 6 million a year.

This bar here is shipments of condensin

furnaces over time. Each year they publish not only

the total number of shipments, but the division mi

efficiency and high efficiency break that out and thi

is the point on electric furnaces.

And what Frank Stanonik said earlier i

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

6

1 think it's worth putting it on the table at least fo

2 discussions purposes. Go you want to give him thre

3 minutes? 

4 MODERATOR LANGMEAD: That's fine with me

5 I think we've got -- it's 10:20 and we're going t

6 quite this discussion at 11:00 o'clock. We've go

7 just a couple more subjects to touch on, and so I'l

8 let Frank go ahead now. I think we have time. 

9 MR. FRITTS: Can we get a explanation fo

10 this? 

11 MR. JAKOB: You had asked for a

12 explanation of the shipment data, and this I took ou

13 of Air Conditioning News and Appliance magazines a

14 far back as I could find them in our files, '8

15 through recently. And -- set of bars are -- firs

16 shipments over time. This set of bars are the hea

17 pump shipments over time. This considers centra

18 space heating, and you put air conditioners in here

19 they're way up to 5 or 6 million a year. 

20 This bar here is shipments of condensin

21 furnaces over time. Each year they publish not onl

22 the total number of shipments, but the division mi

23 efficiency and high efficiency break that out and thi

24 is the point on electric furnaces. 

25 And what Frank Stanonik said earlier i

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 23
1

2

5

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

true, that in terms of relative numbers there wer

300,000 here and maybe 300,000 here or 400, 000, and s

the relative growth is bigger with the smaller actua

number of units, but the main point is when it get

back. to energy descriptors is each one of thos

electric furnaces consumes total energy, the inpu

energy, the oil energy that's the interest -- of thre

condensing furnaces. So every one of those electri

furnaces is consuming three times as much energy as 

condensing furnace.

And so in terms of the overall volume o

energy impact on the country, that's significant. An

if that's growing at twice the rate of gas furnace

over time, five, six years, you're going to see 

magnificent impact on our U.S. total energ

consumption, if these trends continue. And there i

no indication from the data to date that they'r

turning down.

MODERATOR LANGMEAD: Are there an

responses to that?

Dan?

MR. DEMPSEY: Dan Dempsey, Carrier again

I guess I go back to my replacement market scenario 

that you've got a certain install population o

electric furnaces, and you go back to '87 it's prett

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234.4433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1 true, that in terms of relative numbers there we

2 300, 000 here and maybe 300, 000 here or 400, 000, and 

3 the relative growth is bigger with the smaller actu

4 number of units, but the main point is when it ge

5 back to energy descriptors is each one of tho

6 electric furnaces consumes total energy, the inp

7 energy, the oil energy that's the interest -- of thre

8 condensing furnaces. So everyone of those electri

9 furnaces is consuming three times as much energy as 

10 condensing furnace. 

11 And so in terms of the overall volume o

12 energy impact on the country, that's significant. A

13 if that's growing at twice the rate of gas furnace

14 over time, five, six years, you're going to see 

15 magnificent impact on our u.S. total energ

16 consumption, if these tr~nds continue. And there i

17 no indication from the data to date that they'r

18 turning down. 

19 MODERATOR LANGMEAD: Are there an

20 responses to that? 

21 Dan? 

22 MR. DEMPSEY: Dan Dempsey, Carrier again

23 I guess I go back to my replacement market scenario 

24 that you've got a certain install population 

25 electric furnaces, and you go back to '87 it's pret

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
6

1

2

4

5

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

significant. And the question would be, what was i

ten years prior to that because, if gas is not

available, you're going to have a fixed amount of

market for replacing those electric furnaces, and it'

going to cycle as the previous year's trends that

existed.

MODERATOR LANGMEAD: I saw another hand g

up over here.

Yes?

MR. YOUNG: Maybe somebody could --

MODERATOR LANGMEAD: Would you introduc

yourself please?

MR. YOUNG: Oh, Dave Young, Ontario Hydro

Maybe somebody from EEI could comment on this, but 

just heard a statement from Frank that was saying that

one hundred percent of the electricity in the Unite

States comes from the generating stations fired wit

oil or with gas. And I don't think I approve --

MODERATOR LANGMEAD: Good point.

MR. YOUNG: -- and it certainly isn't tru

in Canada. And maybe I could get the ratio for th

U.S.?

MODERATOR LANGMEAD: Matt, do you want t

address that?

MR. CHWALOWSKI: Just for an issue, 5

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

6

1 significant. And the question would be, what was i

2 ten years prior to that because, if gas is no

3 available, you're going to have a fixed amount o

4 market for replacing those electric furnaces, and it's 

5 going to cycle as the previous year's trends tha

6 existed. 

7 MODERATOR LANGMEAD: I saw another hand g

8 up over here. 

9 Yes? 

10 MR. YOUNG: Maybe somebody could --

11 MODERATOR LANGMEAD: Would you introduc

12 yourself please? 

13 MR. YOUNG: Oh, Dave Young, Ontario Hydro

14 Maybe somebody from EEl could comment on this, but 

15 just heard a statement from Frank that was saying tha

16 one hundred percent of the electricity in the Unite

17 States comes from the generating stations fired wit

18 oil or with gas. And I don't think I approve 

19 MODERATOR LANGMEAD: Good point. 

20 MR. YOUNG: -- and it certainly isn't tru

21 in Canada. And maybe I could get the ratio for th

22 U.S.? 

23 MODERATOR LANGMEAD: Matt, do you want t

24 address that? 

25 

(202) 234-4433 

MR. CHWALOWSKl : Just for an issue, 5

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 2
1

2

5

6

9

10

11

12

13 -

14

15

16

17

18

19

20

21

22

23

24

25

6

percent of electricity is generated by coal. Abou

eight percent, and again it depends on -- about eigh

percent by natural gas, ten percent by hydro, 2

percent by nuclear, and nationally about four percen

by oil. On the Eastern Seaboard it's different. 

didn't report -- that you ordered oil or gas is mayb

not the issue here.

MODERATOR LANGMEAD: Dave Lewis?

MR. LEWIS: Dave Lewis, Lennox. I thin

the last point is a good one, and I think additionall

it needs to be looked at, that it depends on where yo

are within the United States as far as what powe

generating actually what exists. And it isn't a

though•a consumer has a choice between connectin

their power cord to a cogenerating plant or a hydrogenerating plant, therefore, it's a little bit

stretching the issue to try to compare our tremendous

energy dilemma today all to the electric furnace.

I think much more it has to do with

whether natural gas is available and especially i

that retrofit situation, if there isn't natural gas

available, it surely will go to the only other

alternative that is.

MODERATOR LANGMEAD: That's oil? Okay.

MR. LEWIS: Maybe.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 2344433 WASHINGTON , D.C. 20005 (202) 234-44

EE-DET-94-101 COMMENT 0D

6

1 percent of electricity is generated by coal. Abou

2 eight percent, and again it depends on -- about eigh

3 percent by natural gas, ten percent by hydro, 2

4 percent by nuclear, and nationally about four percen

5 by oil. On the Eastern Seaboard it's different. 

6 didn't report that you ordered oil or gas is mayb

7 not the issue here. 

8 MODERATOR LANGMEAD: Dave Lewis? 

9 MR. LEWIS: Dave Lewis, Lennox. I thin

10 the last point is a good one, and I think additionall

11 it needs to be looked at, that it depends on where yo

12 are wi thin the United States as far as what powe

13 generating actually what exists. And it isn't a

14 though' a consumer has a choice between connectin

15 their power cord to a cogenerating plant or a hydro

16 generating plant, therefore, it's a little bi

17 stretching the issue to try to compare our tremendou

18 energy dilemma today all to the electric furnace. 

19 I think much more it has to do wit

20 whether natural gas is available and especially i

21 that retrofit situation, if there isn't natural ga

22 available, it surely will go to the only othe

23 alternative that is. 

24 

25 

(202) 234-4433 

MODERATOR LANGMEAD: That's oil? Okay. 

MR. LEWIS: Maybe. 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
2

3

5

6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

6

MODERATOR LANGMEAD: Frank, you had som

other points that you wanted to get into on differen

descriptors?

MR. JAKOB: This morning Cyrus and Georg

quoted some interesting equations that look at the wa

DOE had proposed an energy descriptor -- And what 

did here was just a simple power matrix study. Yo

take those equations and here is a 90 percent AFU

condensing furnace. Here is an 80 percent AFUE mi

efficiency furnace. And here is a 78 AFUE minimu

efficiency furnace. And what you look at is how th

energy factor as defined by DOE would vary dependin

on how much electricity a furnace uses.

And in general about two to six percent o

a furnace's site energy consumption is electricity

That number is easily deduced from the data that'

available for furnaces. Every library apparently ha

a GAMA directory where a consumer can go and look u

any furnace's electric or gas consumption.

Now, what happens is that with th

efficiency descriptor as defined, as you increase th

amount of electricity for whatever reason , sometime

as you increase electrical consumption because yo

have a less efficient motor, that's an efficiency th

DOE has added in. Most of the time you increas

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

6

1 MODERATOR LANGMEAD: Frank, you had som

2 other points that you wanted to get into on differen

3 descriptors? 

4 MR. JAKOB: This morning Cyrus and Georg

5 quoted some interesting equations that look at the wa

6 DOE had proposed an energy descriptor And what 

7 did here was just a simple power matrix study. Yo

8 take those equations and here is a 90 percent AFU

9 condensing furpace. Here is an 80 percent AFUE mi

10 efficiency furnace. And here is a 78 AFUE minimu

11 efficiency furnace. And what you look at is how th

12 energy factor as defined by DOE would vary dependin

13 on how much electricity a furnace uses. 

14 And in general about two to six percent o

15' a furnace's site energy consumption is electricity

16 That number is easily deduced from the data that'

17 available for furnaces. Every library apparently ha

18 a GAMA directory where a consumer can go and look u

19 any furnace's electric or gas consumption. 

20 Now, what happens is that with th

21 efficiency descriptor as defined, as you increase th

22 amount of electricity for whatever reason, sometime

23 as you increase electrical consumption because yo

24 have a less efficient motor, that's an efficiency th

25 DOE has added in. Most of the time you increas

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

6

electrical consumption because in a small furnace you

put in a big air handler, and that big air handler i

there. It can handle a five ton load perhaps'in the

summer, but then you've got to carry that amount of

air handling capacity and electricity throughout the

heating season too. So that furnace is particularly

outfitted for an annual effect, but it's only being

rated on a seasonable heating effect.

And the way the mathematics works is that

a condensing furnace with a big enough air handler

would end up having the same energy factor as a mid or

low efficiency furnace with less energy consumption.

And that's the point of confusion that's entered into

the marketplace because the descriptor as currently

proposed.

There is a related issue with regard t

vents perhaps that's come on the table where right no

these numbers very easily convey to an installer what

sort of venting system he should. put on the applianc

to get BPC or B vent. But if they all had the sam

numeric value, then it becomes a little more confusio

issue , and that's something that we're looking t

eliminate.

(202) 234-4433

MODERATOR LANGMEAD: Dan?

MR. DEMPSY: Dan Dempsy, Carrier. I'd

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 234-4

EE-DET-94-101 COMMENT 0D

6

1 electrical consumption because in a small furnace yo

2 put in a big air handler, and that big air handler i

3 there. It can handle a five ton load perhaps in th

4 summer, but then you've got to carry that amount o

5 air handling capacity and electricity throughout the 

6 heating season too. So that furnace is particularly 

7 outfitted for an annual effect, but it's only being 

8 rated on a seasonable heating effect. 

9 And the way the mathematics works is tha

10 a condensing furnace wi th a big enough air handle

11 would end up having the same energy factor as a mid o

12 low efficiency furnace with less energy consumption

13 And that's the point of confusion that's entered into 

14 the marketplace because the descriptor as currently 

15 proposed. 

16 There is a related issue with regard to 

. 17 vents perhaps that's come on the table where right now 

18 these numbers very easily convey to an installer wha

19 sort of venting system he should. put on the applianc

20 to get BPC or B vent. But if they all had the sam

21 numeric value, then it becomes a little more confusio

22 issue, and that's something that we're looking t

23 eliminate. 

24 

25 

(202) 234-4433 

MODERATOR LANGMEAD: Dan? 

MR.DEMPSY: Dan Dempsy, Carrier. 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 

I'

(202) 23
1

3

4

5

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

just like to point out in that hypothetical exampl

that to have a 80 AFUE unit that has a higher energ

factor than the 90 AFUE unit, the 80 AFUE unit woul

likely cost more to produce because the technolog

requires to get the electrical consumption down tha

low is not in and of itself cost effective.

MR. JAKOB: The range here though, Dan, i

the range of typical values available today. I didn

put numbers that are -- we have products that hav

very low electrical consumption, 80 AFUE and the cos

to produce is higher than the standard 90 AFU

product.

MODERATOR LANGMEAD: George?

MR. KELLY: George Kelly, NIST. I woul

just like to point out that the range of two percen

and six percent, if the two percent was boilers, oka

-- the pump. Six percent is typical for furnaces.

you're not going to be comparing six of one with tw

of another, you're going to be comparing all a

roughly six percent, okay. So, you know, they're not

going to have the same value. They're going to b

different. They can all be lower.

MR. JAKOB: If you look at the curren

directory I think you'll be surprised to see the rang

for furnaces only.

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE'ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

6

1 just like to point out in that hypothetical examp

2 that to have a 80 AFUE unit that has a higher energ

3 factor than the 90 AFUE unit, the 80 AFUE unit wou

4 likely cost more to produce because the technolog

5 requires to get the electrical consumption down tha

6 low is not in and of itself cost effective. 

7 MR. JAKOB: The range here though, Dan, i

8 the range of typical values available today. I didn

9 put numbers that are -- we have products that hav

10 very low electrical consumption, 80 AFUE and the co

11 to produce is higher than the standard 90 AFU

12 product. 

13 MODERATOR LANGMEAD: George? 

14 MR. KELLY: George Kelly, NIST. I wou

15 just like to point out that the range of two percen

16 and six percent, if the two percent was boilers, oka

17 -- the pump. Six percent is typical for furnaces. S

18 you're not going to be comparing six of one with tw

19 of another, you're going to be comparing all a

20 roughly six percent, okay. So, you know, they're n

21 going to have the same value. They're going to b

22 different. They can all be lower. 

23 MR. JAKOB: If you look at the curren

24 directory I think you'll be surprised to see the rang

25 for furnaces only. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

2

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24 MODERATOR LANGMEAD: All right. Do yo

25H want to move on?

(202) 234-4433

7

MODERATOR LANGMEAD: Is this based o

furnaces only or furnaces and boilers?

MR. JAKOB: This is just the mathematica

equation parametrically looked at -- and the equatio

of--

MR. KELLY: So this is an idealistic cas

where you really can't tell me that boilers -

furnaces have two percent --

MR. JAKOB: I think there are a few. 

put the range there and the raw data I didn't brin

with me.

MR. KELLY: Where did you get the rang

from?

directory.

MR. JAKOB: From looking at the GAMA

MR. KELLY: For furnaces?

MR. JAKOB: For furnaces.

MODERATOR LANGMEAD: Dan?

MR. DEMPSEY: Dan Dempsey again. George

there are products available, but as I mentioned th

cost of the technology to get the electrica

consumption down to the two percent level is extremel

high.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

7

1 MODERATOR LANGMEAD: Is this based o

2 furnaces only or furnaces and boilers? 

3 MR. JAKOB: This is just the mathematica

4 equation parametrically looked at -- and the equatio

5 of --

6 MR. KELLY: So this is an idealistic cas

7 where you really can't tell me that boilers 

8 furnaces have two percent 

9 MR. JAKOB: I think there are a few. 

10 put the range there and the raw data I didn't brin

11 with me. 

12 MR. KELLY: Where did you get the rang

13 from? 

14 MR. JAKOB: From looking at the GAM

15 directory. 

16 MR. KELLY: For furnaces? 

17 MR. JAKOB: For furnaces. 

18 MODERATOR LANGMEAD: Dan? 

19 MR. DEMPSEY: Dan Dempsey again. George

20 there are products available, but as I mentioned th

21 cost of the technology to get the electrica

22 consumption down to the two percent level is extremel

23 high. 

24 MODERATOR LANGMEAD: All right. 

25 want to move on? 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 

Do yo

(202) 2
1

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

MR. JAKOB: There is a analysis that wa

performed earlier this year that was. derived from

interestingly enough, some work we'll be talking abou

later this afternoon with regard to gas heat pumps an

the rating procedures that have been developed fo

those, that seem to be in appropriate fix for some o

the confusion that might be entering the marketplace

not that that might come out on the table that 

different type of confusion might result. But what -

is a correlation of operating cost with energy factor

this EF value.

And this graph over here would be ho

those numbers would correlate with costs based on th

proposal that's in the Federal Register. And th

reason for this segregation of numbers is that indee

the proposal was based on a single national averag

value of cost ratio of about 3.36 when actually ga

has a value of four, oil has a value of about 3

propane has a value of about 2.5 or something, and s

operating costs would depend on the particular fue

that's being used to fire that furnace if -

electricity.

The alternative that's been proposed, tha

I won't necessarily go into the mathematica

formulation of, but I could if you'd enjoy that

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

7

1 MR. JAKOB: There is a analysis that wa

2 ~erformed earlier this year that was. derived from

3 interestingly enough, some work we'll be talking abou

4 later this afternoon with regard to gas heat pumps an

5 the rating procedures that have been developed fo

6 those, that seem to be in appropriate fix for some o

7 the confusion that might be entering the marketplace

8 not that that might come out on the table that 

9 different type of confusion might result. But what -

10 is a correlation of operating cost with energy factor

11 this EF value. 

12 And this graph over here would be ho

13 those numbers would correlate with costs based on th

14 proposal that's in the Federal Register. And th

15 reason for this segregation of numbers is that indee

16 the proposal was based on a single national averag

17 value of cost ratio of about 3.36 when actually ga

18 has a value of four, oil has a value of about 3

19 propane has a value of about 2.5 or something, and s

20 operating costs would depend on the particular fue

21 that's being used to fire that furnace if 

22 electricity. 

23 The alternative that's been proposed, th

24 I won't necessarily go into the mathematic

25 formulation of, but I could if you'd enjoy tha

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

3

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

7

produces the correlation of this nature where all o

those factors with regard to different fossil fue

energy costs cost ratios end up correlatin

exceedingly well with operating costs. And the fac

that you have two values for the same AFUE no longe

shows up as was evident on the previous chart.

Another facet that shows up here is tha

these numbers for energy factor are now offset fro

this range of zero to a hundred, and as George pointe

out, the EF is kind of a mathematical definition an

it's hard to put a real physical explanation on it

It's more a numerical measure of it's combine

efficiency and cost.

This would give it a numerical value ver

different than what we have today being the 2`to 35

range and we have to get used to that, but is tha

possible ? I don't know, last summer I took my kids t

the beach and I bought sunscreen with an SPF of 40

And I think you all know what that means , someho

we've gotten a real appreciation for what tha

arbitrary scale means in terms of sun protectio

factor with regard to sunscreen.

And so a shift from numerical values,

significant shift, not 78, 72, 75, might caus

confusion , but a shift from something below a hundre

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

7

1 produces the correlation of this nature where all o

2 those factors with regard to different fossil fue

3 energy costs cost ratios end up correlatin

4 exceedingly well with operating costs. And the fac

5 that you have two values for the same AFUE no longe

6 shows up as was evident on the previous chart. 

7 Another facet that shows up here is tha

8 these numbers for energy factor are now offset fro

9 this range of zero to a hundred, and as George pointe

10 out, the EF is kind of a mathematical definition an

11 it's hard to put a real physical explanation on it

12 It's more a numerical measure of it's combine

13 efficiency and cost. 

14 This would give it a n~merical value ver

15 different than what we have today being the 2'to 35

16 range and we have to get used to that, but is tha

17 possible? I don't know, last summer I took my kids t

18 the beach and I bought sunscreen with an SPF of 40

19 And I think you all know what that means, someho

20 we've gotten a real appreciation for what tha

21 arbi trary scale means in terms of sun protectio

22 factor with regard to sunscreen. 

23 And so a shift from numerical valuesr 

I 

24 significant shi£t, not 78, 72, 75, migpt cau

25 confusion, but a shift from something below a hundre

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NoW. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

4

6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

7

to well over a hundred might be something that coul

enter the marketplace more easily --

MR. DEMPSEY: Dan Dempsey, Carrier

Frank, was that based on the assumption of a single

speed product?

MR. JAKOB: I believe I was studying

large body of fixed capacity furnaces that are on th

market. -- would fit in here. The answer to that

question is we found with the proposed EF descriptor

and even modifying the cost ratio so that there is no

a one to one correlation with cost and energy factor

for the two speed or modulating products. In fact on

of the products that we offer under current procedure

in calculating operating costs we show a slight

savings from a single speed to a two speed product.

However when you calculate the energy factors and g

through a variety of assumptions, here is not

savings reflected in those energy factors.

MR. DEMPSEY: So -- technical innovation

that might still not be comprehended?

MR. JAKOB: Correct. In most of the lo

electrical consuming products on the market today ar

two speed or modulating and not fixed speed.

MODERATOR LANGMEAD: Okay, that was a goo

251 point, Dan.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

7

1 to well over a hundred might be something that coul

2 enter the marketplace more easily 

3 MR. DEMPSEY: Dan Dempsey, Carrier

4 Frank, was that based on the assumption of a singl

5 speed product? 

6 MR. JAKOB: I believe I was studying 

7 large body of fixed capacity furnaces that are on th

8 market. -- would fit in here. The answer to tha

9 question is we found with the proposed EF descriptor

10 and even modifying the cost ratio so that there is no

11 a one to one correlation with cost and energy factor

12 for the two speed or modulating products. In fact on

13 of the products that we offer under current procedure

14 in calculating operating costs we show a sligh

15 savings from a single speed to a two speed product

16 However when you calculate the energy factors and g

17 through a variety of assumptions, here is not 

18 savings reflected in those energy factors. 

19 MR. DEMPSEY: So -- technical innovation

20 that might still not be qomprehended? 

21 MR. JAKOB: Correct. In most of the lo

22 electrical consuming products on the market today ar

23 two speed or modulating and not fixed speed. 

24 

25 point, Dan. 

(202) 234-4433 

MODERATOR LANGMEAD: Okay, that was a goo

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 23
7

1

2

3

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Other comments on this?

Frank, do you want to go through any more

MR. JAKOB: That's it.

MODERATOR LANGMEAD: We've got abou

another 35 minutes, a couple of other issues we wan

to talk to you about, but I think we've kind o

isolated a major issue. And what'is going to be the

easiest for consumers to understand, what's going to

be the best two motivate consumers and let the

understand, one camp says that all the information i

there that will provide cost of operation that's bein

used and the consumers are using that. Another cam

is saying that the descriptors are going to be ther

and the descriptors are going to shift decisions ev

above the -- even though you understand the operating

costs.

I go back to where I was at some point i

time, I would think we would all benefit as a

industry to have some more professional look at wha

motivates consumers to make a purchase decisio

between furnaces of different fuel types. And I thin

that's something you almost have to do before you ca

get to the point of putting in the right descriptor

And the right descriptor has to be in the tes

procedure before FTC can use it, so you've got to g

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON. D.C. 20005 (202)' 23

EE-DET-94-101 COMMENT 0D

7

1 Other comments on this? 

2 Frank, do you want to go through any more

3 MR. JAKOB: That's it. 

4 MODERATOR LANGMEAD: We've got abou

5 another 35 minutes, a couple of other issues we wan

6 to talk to you about, but I think we've kind o

7 isolated a major issue. And what~is going to be th

8 easiest for consumers to tinderstand, what's going t

9 be the best two moti vate consumers and let them 

10 understand, one camp says that'all the information i

11 there that will provide cost of operation that's bein

12 used and the consumers are using that. Another cam

13 is saying that the descriptors are going to be ther

14 and the descriptors are going to shift decisions eve

15 above the -- even though you understand the operatin

16 costs. 

17 I go back to where I was at some point i

18 time, I would think we would all benefit as a

19 industry to have some more professional look at wha

20 motivates consumers to make a purchase decisio

21 between furnaces of different fuel types. And I thin

22 that's something you almost have to do before you ca

23 get to the point of putting in the right descriptor

24 And the right descriptor has to be in the tes

25 procedure before FTC can use it, so you've got to g

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NoW. 

WASHINGTON. D.C. 20005 (202) 23
7

1

2

3

4

5

8

9

10

11

12

13,

14

15

16

17

18

19

20

21

22

23

24

25

back at something.

And my personal opinion is we need to kno

a little bit mote of what's motivating the consumer t

make a choice. And that needs to be organized in som

way and shape, and maybe the industry can get togethe

and assist DOE in gathering that information in som

way.

Other questions on -- we'll come back t

this. Let's finish a couple of other things here. 

couple of questions on here. The last one on ther

was use of separate or combined energy descriptors fo

each energy source buying appliance.

Is there anybody that feels we ought t

delve into that anymore? We've talked abou

descriptor, and we've already had two.

.Dan, I'll stop and let you talk.

MR. DEMPSEY: One last comment. Goin

back about ten years, Carrier was involved in helpin

to generate a combined gas/electrical descriptor' tha

was called SUEF. And I think -- from DOE is going t

present papers on that.

In more recent years we've also supporte

the development of a combined energy descriptor, an

we've been involved in the GAMA in a work group. Bu

when you get down to the details of it and you look a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

(202)'2344433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

7

1 back at something. 

2 And my personal opinion is we need to kno

3 a little bit more of what's motivating the consumer t

4 make a choice. And that needs to be organized "in som

5 way and shape, and maybe the industry can get togethe

6 and assist DOE in gathering that information. in som

7 way. 

8 Other questions on -- we'll come back t

9 this. Let's finish a couple of other things here. 

10 couple of questions on here. The last one on ther

11 was use of separate or combined energy descriptors fo

12 each>energy source buying appliance. 

13 Is there anybody that feels we ought t

14 delve into that anymore? We've talked abo

15 descriptor, and we've already had two. 

16 Dan, I'll stop and let you talk. 

17 MR. DEMPSEY: One last comment. Goin

18 9ack about ten years, Carrier was involved in helpin

19 to generate a combined gas/electrical descriptor 'th

20 was called SUEF. And I think -- from DOE is going t

21 present papers on that. 

22 In more recent years we've also supporte

23 the development of a combined energy descriptor, an

24 we've been involved in the GAMA in a work group. B

25 when you get down to the details of it and you look 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

4

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

7

a combined energy descriptor and the impact on 

complete model line, we came to the conclusion tha

there is a serious concern over the impact on high ai

flow products. Mainly the southern market, multi

family type products.

And to give you a perfect example of tha

is the proposed annual efficiency minimum for mobil

home furnaces, which was 74.3 percent. If tha

minimum was applied today to our current AFUE fixe

speed product line, three higher flow low heat model

would not comply and would have to utilize ver

expensive technology to reduce the electrica

consumption.

And so we were very concerned that becaus

of the differences from model to model, not on 

baseline unit, but for a whole model line, that i

would be very difficult and very impractical to se

one minimum that would-be equitable across the whol

product line and equitable to the whole market

That's the reason why we no longer support those.

MODERATOR LANGMEAD: Just so everybod

else understands that. The point was the descripto

is there, you're going to -- you have to assume you'r

going to set the minimum on that descriptor rathe

than just communicating to the public and it has a

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

7

1 a combined energy descriptor and the impact on 

2 complete model line, we came to the conclusion tha

3 there is a serious concern over the impact on high ai

4 flow products. Mainly the southern market, multi

5 family type products. 

6 And to give you a perfect example of tha

7 is the proposed annual efficiency minimum for mobil

8 home furnaces, which was 74. 3 percent. If tha

9 minimum was applied today to our current AFUE fixe

10 speed product line, three higher flow low heat mode

11 would not comply and would have to utilize ver

12 expensive technology to reduce the electrica

13 consumption. 

14 And so we were very concerned that becaus

15 of the differences from model to model, not on 

16 baseline unit, but £or a whole model line, that i

17 would be very difficult and very impractical to se

18 one minimum that would be equitable across the who

19 product line and equitable to the whole marke

20 That's the reason why we no longer support those. 

21 MODERA TOR LANGMEAD: Just so everybod

22 else understands that. The point was the descripto

23 is there, you're going to -- you have to assume you'r

24 going to set the minimum on that descriptor rathe

25 than just communicating to the public and it has a

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
7

2

3

5

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

impact.

George?

MR. KELLY: George Kelly from NIST. I'

just like to point out in the alternative that I'

using two descriptors, okay, one for -- and for fossi

fuel. I think it's just unhandled by the consumer

I just don't think he can make heads or tails out o

the AFUE of 70 and an electrical of 60 or -- at 83 an

electrical of 55, I mean how• does it go come together

it doesn't mean anything, you know. So I think -- an

-- but it's going to really confuse the consumer.

MODERATOR LANGMEAD: Well, we have tw

issues already. We've got an AFUE and cost, and th

comparison does get made in cost.

Yes?

MR. YOUNG: Dave Young from Ontario Hydr

again. What would be wrong with keeping the necessar

number of descriptors to express the performance o

the product in engineering terms and then only carr

cost to the customer?

MODERATOR LANGMEAD: Dave Lewis?

MR. LEWIS: Dave Lewis, Lennox. The onl

way that cost can be calculated that is fair to th

consumer is at that particular consumer's address

And to try to do that on any national basis, to try t

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

7

1 impact. 

2 George? 

3 MR. KELLY: George Kelly from NIST. I'

4 just like to point out in the alternative that I'm 

5 using two descriptors, okay, one for -- and for fossi

6 fuel. I think it's just unhandled by the consumer

7 I just don't think he can make heads or tails out o

8 the AFUE of 70 and an electrical of 60 or -- at 83 an

9 electrical of 55, I mean how, does it go come together

10 it doesn't mean anything, you know. So I think -- an

11 but it's going to really confuse the consumer. 

12 MODERATOR LANGMEAD: Well, we have tw

13 issues already. We've got an AFUE and cost, and th

14 comparison does get made in cost. 

15 Yes? 

16 MR. YOUNG: Dave Young from Ontario Hydr

17 again. What would be wrong with keeping the necessar

18 number of descriptors to express the performance o

19 the product in engineering terms and then only carr

20 cost to the customer? 

21 MODERATOR LANGMEAD: Dave Lewis? 

22 MR. LEWIS: Dave'Lewis, Lennox. The on

23 way that cost can be calculated that is fair to th

24 consumer is at that particular consumer's address

25 And to try to do that on any national basis, to try t

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w, 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

7

come up with any kind of descriptor that would take

into the factoring of what the consumer would see

would be so confusing that I think the effort would

not be worthwhile.

I think what exists today, this is the

fundamental point that we really stand with, what

exists today is adequate for a consumer to make an

intelligent energy-wise decision . We think the poin

is we need to, all together, work towards educating

the consumer towards making that decision with th

information that's available.

MODERATOR LANGMEAD: Okay.

Yes?

MR. SWEETSER : Rich Sweetser with th

American Gas Cooling Center. I beg to slightly diffe

with my brother , Lennox , as far as getting good

information to the consumer . We made a compromis

when we created AFUE. We made a compromise when we

creased SEER and HSPF , and that compromises selectio

of DOE's zone 4 as our weather data and basis for ou

engineering calculations.

I' ll tell you quite frankly HSPF , AFUE an

SEER have little relevance to the guy in Miami,

Florida , and little relevance to the guy up in

Seattle , Washington or perhaps in Ontario Hydro'

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON.. D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

7

1 come up with any kind of descriptor that would tak

2 into the factoring of what the consumer would se

3 would be so confusing that I think the effort woul

4 not be worthwhile. 

5 I think what exists today, this is the 

6 fundamental point that we really stand with, wha

7 exists today is adequate for a consumer to make a

8 intelligent energy-wise decision. We th~nk the pOin

9 is we need to, all together, work towards educatin

10 the consumer towards making that decision with th

11 information that's available. 

12 MODERATOR LANGMEAD: Okay. 

13 Yes? 

14 MR. SWEETSER: Rich Sweetser with th

15 American Gas Cooling Center. I beg to slightly diffe

16 wi th my brother, Lennox, as far as getting goo

17 information to the consumer. We made a compromis

18 when we created AFUE. We made a compromise when w

19 creased SEER and HSPF, and that compromises selectio

20 of DOE's zone 4 as our weather data and basis for ou

21 engineering calculations. 

22 I'll tell you quite frankly HSPF, AFUE an

23 SEER have little relevance to the guy in Miami

24 Florida, and little relevance to the guy up i

25 Seattle, Washington or perhaps in Ontario Hydro

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON .. D.C. 20005 (202) 23
2

4

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

case, and that's going to get even more interesting a

we develope new technologies such as which are bot

electric and gas type technologies, and that's goin

to change and confuse people even more.

MODERATOR LANGMEAD: Dave, do you want t

respond?

MR. LEWIS: Yes. Dave Lewis, Lennox

Obviously, if we look at it from an engineerin

perspective, the statement that was just made has som

accuracy there. The point though that I think we nee

to look at is what was the intent of energ

descriptors and appliance standards when they ar

initially put in place. And I would draw a paralle

to whether you'd call it the Frank Jakob's 40 on the

what was it, SBF or whatever that is, or whether yo

look at car mileage. It is a means by which 

consumer can make a comparative decision. And I thin

that's the intent. If we are trying to make it in

an engineering, an elaborate engineering accurate t

the precise 14th digit, obviously it's incorrect.

But can the consumer make an intelligen

decision based on comparative products in th

marketplace? The answer is yes. And what we need t

do is keep it simple enough so that the consume

actually uses the nomenclature that exists in th

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

7

1 case, and that's going to get even more interesting 

2 we develope new technologies such as which are bo

3 electric and gas type technologies, and that's goin

4 to change and confuse people even more. 

5 MODERATOR LANGMEAD: Dave, do you want t

6 respond? 

7 MR. LEWIS: Yes. Dave Lewis, Lenno

8 Obviously, if we look at it from an engineerin

9 perspecti ve, the statement that was just made has som

10 accuracy there. The point though that I think we nee

11 to look at is what was the intent of energ

12 descriptors and appliance standards when they a

13 initially put in place. And I would draw a parall

14 to whether you'd call it the Frank Jakob's 40 on the

15 what was it, SBF or whatever that is, or whether yo

16 look at car mileage. It is a means by which 

17 consumer can make a comparative d~cision. And I thin

18 that's the intent. If we are trying to make it in

19 an engineering, an elaborate engineering accurate 

20 the precise 14th digit, obviously it's incorrect. 

21 But can the consumer make an intelligen

22 decision based on comparative products in th

23 marketplace? The answer is yes. And what we need 

24 do is keep it simple enough so that the consum

25 actually uses the nomenGlature that exists in th

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
8

1

2

3

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

marketplace today.

MODERATOR LANGMEAD: Okay.

Gene?

MR. MARGOLIS: I have a question to ask

Dan Dempsey. You said that there is for gas, for

models of gas furnaces, at the 80 percent AFUE, to

improve the electrical efficiency, would be prohibite

to make those adjustments in the electrical part o

the gas furnace. I was wondering if you could give u

whether here now or just send it to the Department why

these type of furnaces can't have improvement in thei

electrical consumption. That would be a reasonable

cost. It just doesn't -- what you're saying is tha

you cannot improve the electrical without really

getting rid of the furnace because you won't be abl

to sell it.

MR. DEMPSEY: No, the improvement in th

electrical that would be required for certain model

to raise their annual efficiency, the AE descriptor

which is proposed for -- furnaces , some of the smal

units with high air flow, to get the electrica

consumption down would require the use of the

brushless DC motor technology. And in and of itsel

that technology is technologically feasible. But i

2511 terms of spacing hearing performance, it's not jus

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

8

1 marketplace today. 

2 MODERATOR LANGMEAD: Okay. 

3 Gene? 

4 MR. MARGOLIS: I have a question to as

5 Dan Dempsey. You said that there is for gas, fo

6 models of gas furnaces, at the 80 percent AFUE, t

7 improve the electrical efficiency, would be prohibite

8 to make those adjustments in the electrical part o

9 the gas furnace. I was wondering if you could give u

10 whether here now or just send it to the Department wh

11 these type of furnaces can't have improvement in thei

12 electrical consumption. That would be a reasonabl

13 cost. It just doesn't -- what you're saying is tha

14 you cannot improve the electrical without reall

15 getting rid of the furnace because you won't be abl

16 to sell it. 

17 MR. DEMPSEY: No, the improvement in th

18 electrical that would be required for certain model

19 to raise their annual efficiency, the AE descripto

20 which is proposed for -- furnaces, some of the sma

21 uni ts with high air flow, to get the electrica

22 consumption down would require the use of th

23 brushless DC motor technology. And in and of itsel

24 that technology is technologically feasible. But i

25 terms of spacing hearing performance, it's not jus

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 23
1

2

4

5

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

viable economically, and that it would be-cheaper t

go to a bottom line condensing furnace with standar

motor technology.

MR. MARGOLIS: Are you saying that this 

just for mobile home furnaces or --

MR. DEMPSEY: No, if the mobile hom

minimum was applied to central furnaces, our curren

AFUE product line, there would be 25 percent of th

models in that model family that would not meet th

minimum because of the high air flow need for th

southern for multi family market.

MR. MARGOLIS: But don't you think tha

your engineers would be able to in the future t

redesign it such that they could meet the bette

electrical consumption?

MR. DEMPSEY: I would see that as highl

unlikely. It would be motor technology.

MODERATOR LANGMEAD: Jim Ranfone, you ha

something?

MR. RANFONE: Jim Ranfone. I guess I wil

comment, Dave made the comment that the. consumer ha

adequate energy descriptors today, 78 and the 98, an

that's our basic premise, that that isn't adequate fo

consumers, but it is misleading. That's number one

Number two, I'm talking a differen

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

8

1 viable economically, and that it would be·cheaper t

2 go to a bottom line condensing furnace with standar

3 motor technology. 

4 MR. MARGOLIS: Are you saying that this i

5 just for mobile home furnaces or --

6 MR. DEMPSEY: No, if the mobile hom

7 minimum was applied to central furnaces, our curren

8 AFUE product line, there would be 25 percent of th

9 models in that model family that would not meet th

10 minimum because of the high air flow need for th

11 southern for multi family market. 

12 MR. MARGOLIS: But don't you think tha

13 your engineers would be able to in the future t

14 redesign it such that they could meet the bette

15 electrical consumption? 

16 MR. DEMPSEY: I would see that as highl

17 unlikely. It would be -- motor technology. 

18 MODERATOR LANGMEAD: Jim Ranfone, you ha

19 something? 

20 MR. RANFONE: Jim Ranfone. t guess I wi

21 cpmment, Dave made the comment that the. consumer ha

22 adequate energy descriptors today, 78 and the 98, an

23 that's our basic premise, that that isn't adequate fo

24 consumers, but it is misleading. That's number on

25 

(202) 234-4433 

Number two, I'm talking a differen

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

3

4

5

6

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

8

entity. Number two, I would like to address this to

Mr. Margolis because he made a comment early on tha

he believes that the DOE cannot propose or institut

an energy descriptor based on site or based on sourc

energy, and he said that was the law. I believe h

said that, legislatively couldn't do that. I have

never seen that in writing from-DOE, that type of

interpretation. Although I know at ARI has certainly

made that interpretation.

Second, what about the energy cost rati

factor being applied, is that within the realm of th

existing legislation, and that factor based on energy

-- because he did propose that.

MODERATOR LANGMEAD: Jim, thank you fo

leading into that. That's exactly where I want t

get.

The next question was statutory an

marketplace limitations on descriptors. We've talke

about the marketplace limitations on them, and the

there are some statutory limitations.

And, Joe , I saw you had your hand up, d

you want to address that?

MR. MATTINGLY: Yes. I think the recor

before it closes on this issue ought to have thi

comment in it, and Jim has raised it. If GAM

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

8

1 entity. Number two, I would like to address this t

2 Mr. Margolis because he made a comment early on tha

3 he believes that the DOE cannot propose or institut

4 an energy descriptor based on site or based on sourc

5 energy, and he said that was the law. I believe h

6 said that, legislatively couldn't do that. I hav

7 never seen that in writing from- DOE, that type o

8 interpretation. Although I know at ARI has certainl

9 made that interpretation. 

10 Second, what about the energy cost rati

11 factor being applied, is that within the realm of th

12 existing legislation, and that factor based on energ

13 -- because he did propose that. 

14 MODERATOR LANGMEAD: Jim, thank you fo

15 leading into that. That's exactly where I want t

16 get. 

17 The' next question was statutory an

18 marketplace limitations on descriptors. We've talke

19 about the marketplace limitations on them, and the

20 there are some statutory limitations. 

21And, Joe, I saw you had your hand up, d

22 you want to address that? 

23 MR. MATTINGLY: Yes. I think the recor

24 before it closes on this issue ought to have thi

25 comment in it, and Jim has raised it. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 

If GAM

(202) 2
1

2

3

4

5

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

8

believes that DOE does not have the legal authority t

prescribe a multiplier and F factor, and it was clea

when they prescribed a source energy multiplier tha

that was really outside the bounds of their authority

And we also believe that the cost based multiplie

besides being a bad idea from an engineerin

standpoint mixes up economics with thermodynamics

But we also believe it's really just a source energ

multiplier disguised, and that it also would b

unlawful.

And also I might add that I don't think -

I think it's a very substantial question whether DO

has the legal authority to prescribe new multipliers

NEACA states what -- I don't mean multiplier, I mea

descriptors. NEACA states what the descriptors ar

for the various products in a couple of differen

places, and I don't think DOE really has the lega

authority to prescribe the new descriptors withou

amending the statute.

MODERATOR LANGMEAD: There's somethin

back here>

MR. WILHELM: Barry Wilhelm. I'd like t

follow up on that comment and get back to Cyrus' draf

there that said, that talked about the cost factor, 

factor, what -- source energy factor. But when yo

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

8

1 believes that DOE does not have the legal authority t

2 prescribe a multiplier and F factor, and it was clea

3 when they prescribed a source energy multiplier tha

4 that was really outside the bounds of their authority

5 And we also believe that the cost based multiplie

6 besides being a bad idea ( from an engineerin

7 standpoint mixes up economics with thermodynamics

8 But we also believe it's really just a source energ

9 mul tiplier disguised, and that it also would b

10 unlawful. 

11 And also I might add that 1; don't think -

12 I think it's a very substantial question whether DO

13 has the legal authority to prescribe new multipliers

14 NEACA states what -- I don't mean multiplier, I mea

15 descriptors. NEACA states what the descriptors ar

16 for the various products in a couple of differen

17 places, and I don't think DOE really has the lega

18 authori ty to prescribe the new descriptors withou

19 amending the statute. 

20 MODERATOR LANGMEAD: There's somethin

21 back here> 

22 MR. WILHELM: Barry Wilhelm. I'd like t

23 follow up on that comment and get back to Cyrus' dra

24 there that said, that talked about the cost factor, 

25 factor, what -- source energy factor. 

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 

But when yo

(202) 2
2

3

S

6

7

8

9

10

11

12

13

14

15.

16

17

18

19

20

21

22

23

24

25

8

look at cost, any electrical gadget tool, you'r

looking at transmission, distribution, generation o

that electricity or that BTU or whatever, it all goe

into the cost. So anything you throw in with the cos

gets back to source energy. I agree with th

statutory discussion that I am very unclear as t

whether this allowed by DOE to bring in this cos

factor.

MODERATOR LANGMEAD: Further comments o

this issue?

Dave Lewis?

MR. LEWIS: Dave Lewis from Lennox. 

think the benefit that we have here is that we al

agree that the consumer makes their decision on cos

and the real benefit is, is we need to give the

enough information so that they can continue to d

that. We can play with numbers all we want wit

descriptors, we can divide all these by seven and ad

three, but the real factor is the consumer makes 

decision on what it costs them for operation. As lon

as that information is adequately supplied to them

they'll make an intelligent decision because it cost

them money.

MR. KALISCH: Bert Kalisch from AGA. M

first point, DOE's authority, I believe that there i

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

8

1 look at cost, any electrical gadget tool, you'r

2 looking at transmission, distribution, generation o

3 that electricity or that BTU or whatever, it all goe

4 into the cost. So anyt'hing you throw in with the cos

5 gets back to source energy. I agree with th

6 statutory discussion that I am very unclear as t

7 whether this allowed by DOE to bring in this cos

8 factor. 

9 MODERATOR LANGMEAD: Further comments o

10 this issue? 

11 Dave Lewis? 

12 MR. LEWIS: Dave Lewis from Lennox. 

13 think the benefit that we have here is that we al

14 agree that the consumer makes their decision on cos

15 and the real benefit is, is we need to give them 

16 enough information so that they can continue to d

17 that. We can play with numbers all we want wit

18 descriptors, we can divide all these by seven and ad

19 three, but the real factor is the consumer makes 

20 decision on what it costs them for operation. As lon

21 as' that information is adequately supplied to them

22 they'll make an intelligent decision because it cost

23 them money. 

24 MR. KALISCH: Bert Kalisch from AGA. M

25 first point, DOE's authority, I believe that there i

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
8

1

2

3

4

6

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

sufficient flexibility in the statute itself tha

gives the Secretary of Energy quite a bit o

flexibility and discretion to operate in the statut

to implement the intent -- AGA's view is there i

sufficient discretion.

The second point is to address Dave Lewis

question or point about cost. It's a point well take

that the average annual operating cost for a furnac

in Florida may not be the same as it is in Maine

What if that cost were to be indexed, be averag

estimated annual operating costs would be indexe

across the appliances that would be indexed to b

applied whether the appliance --

MODERATOR LANGMEAD: Yes, Dave?

MR. LEWIS: Dave Lewis, Lennox. It's a

interesting idea. The only problem is, is that th

statute doesn't reflect anything of that nature

Instead it's focused on the consumer and where the

use the appliance. Indexing, averaging, multiplyin

it by numbers, none of those are really allowable fro

the standpoint that the consumer does not really se

what's reflected at their place of installation

Therefore, what we need to go back to is, we need t

make sure that each product adequately shows th

amount of electricity that's being used that currentl

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-44

EE-DET-94-101 COMMENT 0D

8

1 sufficient flexibility in the statute itself tha

2 gives the Secretary of Energy quite a bit o

3 flexibility and discretion to operate in the statut

4 to implement the intent -- AGA' s view is there i

5 sufficient discretion. 

6 The second pOint is to address Dave Lewis

7 question or point about cost. It's a point well take

8 that the average annual operating cost for a furnac

9 in Florida may not be the same as it is in Maine

10 What if that cost were to be indexed, be averag

11 estimated annual operating costs would be indexe

12 across the appliances that would be indexed to b

13 applied whether the appliance -- f 

·14 MODERATOR LANGMEAD: Yes, Dave? 

15 MR. LEWIS: Dave Lewis, Lennox. It's a

16 interesting idea. The only problem is, is that th

17 statute doesn't reflect anything of that nature

18 Instead it's focused on the consumer and where the

19 use the appliance. Indexing, averaging, multiplyin

20 it by numbers, none of those are really allowable fro

21 the standpoint that the consumer does not really se

22 what's reflected at their place of installation

23 Therefore, what we need to go back to is, we need t

24 make sure that each product adequately shows th

25 amount of electricity that's being used that currentl

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

8

is displayed and has been in the GAMA directory and i

the ARI directory for their respective products.

And the information is available based o

where they live to look at the regional patterns an

find out exactly what the cost of that product'

operation will be. It's when that is attacked tha

the decision is made in a good way for the consumer

the information is available today.

MR. KALISCH: Bert Kalisch, AGA. But it'

quite explicit in the statute that the estimate

annual operating cost may be used. And of course th

annual operating cost has to be a national average

that's also a statutory requirement. So it would b

applicable and DOE certainly would be within thei

right in using the annual estimated annual operatin

cost as a national average.

MODERATOR LANGMEAD: It's now 10:50, an

can we take just a small break and come back.

MR. LEWIS: I would like to respond t

that.

MODERATOR LANGMEAD: Okay, Dave, go ahea

and then Joe is going to have one, and then we'r

going to take a little break.

MR. LEWIS: It's clear that the FTC show

that on the label, and there is no question abou

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

8

1 is displayed and has been in the GAMA directory and i

2 the ARI directory for their respective products. 

3 And the information is available based o

4 where they live to look at the regional patterns an

5 find out exactly what the cost of that product

6 operation will be. It's when that is attacked tha

7 the decision is made in a good wa¥ for the consumer

8 the information is available today. 

9 MR. KALISCH: Bert Kalisch, AGA. But it'

10 qui te explicit in the statute that the estimate

11 annual operating cost may be used. And of course th

12 annual operating cost has to be a national average

13 that's also a statutory requirement. So it would b

14 applicable and DOE certainly would be wi thin thei

15 right in using the annual estimated annual operatin

16 cost as a national average. 

17 MODERATOR LANGMEAD: It's now 10:50, an

18 can we take just a small break and come back. 

19 MR. LEWIS: I would like to respond t

20 that. 

21 MODERATOR LANGMEAD: Okay, Dave, go ahea

22 and then Joe is going to have one, and then we'r

23 going to take a little break. 

24 MR. LEWIS: It's clear that the FTC show

25 that on the label, and there is no question abo

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

8

that, but there is a lot of difference between what's

on a label and the decision that a consumer makes

And I think what we need to look at is the consumer

makes the decision based on their place of living,

where they live. Any other information would b

misleading to the consumer because in effect what yo

could have is a product being applied thinking that

they would get energy savings and in fact they could

have an actual added in cost to their energy bill on

an annual basis.

So we need to make sure that the

information they receive is not misleading, but

accurate information.

MR. KALISCH: AGA, just one last question

Do you believe that DOE does not have the authority to

index a cost number?

MR. LEWIS: We don't think Congress ever

intended that the consuming public would be hurt by

energy descriptor.

MODERATOR LANGMEAD: Joe did you have a

point to make?

MR. MATTINGLY: Yes. The consumer wants

to know operating cost. He's got to know certain

things about, you know, the kind of house he lives in,

his design heating requirements, his local energy cos

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

8

1 that, but there is a lot of difference between what'

2 on a label and the decision that a consumer makes

3 And I think what we need to look at is the consume

4 makes the decision based on their place of living

5 where they Ii ve. Any other information would b

6 misleading to the consumer because in effect what you 

7 could have is a product being applied thinking tha

8 they would get energy savings and in fact they coul

9 have an actual added in cost to their energy bill o

10 an annual basis. 

11 So we need to make sure that th

12 information they receive is not misleading, bu

13 accurate information. 

14 MR. KALISCH: AGA, just one last question

15 Do you believe that DOE does not have the authority t

16 index a cost number? 

17 MR. LEWIS: We don't think Congress eve

18 intended that the consuming public would be hurt b

19 energy descriptor. 

20 MODERATOR LANGMEAD: Joe did you have 

21 point to make? 

22 MR. MATTINGLY: Yes. The consumer want

23 to know operating cost. He's got to know certai

24 things about, you know, the kind of house he lives in

25 his design heating requirements, his local energy cos

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 2
2

3

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

8

for indexing, find out what his local energy cost is

everything else is right there. To the extent the DO

or FTC has any research funds, a good use for it woul

be to promote this directory and the use of th

calculation in here, or probably your own, you know

I don't mean a new directory, but publicized the wa

that consumers can calculate their cost of operation

I suggest this is the best way though.

MODERATOR LANGMEAD: Dan, last one an

then we're going to take time out.

MR. DEMPSEY: I guess I support that fro

Carrier's standpoint. I don't know about my

competitors over here to my left, but we have bee

spending a lot of time working on a local basis

taking the GAMA directory information, using local

electrical and fuel cost in terms of marketing of ou

products. We feel that that's the most effective way

in terms of addressing this issue.

MODERATOR LANGMEAD: Gentlemen, let's tak

a break and we're going to come back at 11:05 and

we'll talk about multifunctional appliances.

(Whereupon, at 10:55 a.m., off the recor

until 11: 08 a.m.)

MODERATOR LANGMEAD: Gentlemen, we're all

ready to resume. We're going to talk about

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 29005 (202) 23

EE-DET-94-101 COMMENT 0D

8

1 for indexing, find out what his local ehergy cost is

2 everything else is right there. To the extent the DO

3 or FTC has any research funds, a good use for it woul

4 be to promote this directory and the use of th

5 calculation in here, or probably your own, you know

6 I don't mean a new directory, but publicized the wa

7 that consumers can calculate their cost of operation

8 I suggest this is the best way though. 

9 MODERATOR LANGMEAD: Dan, last one an

10 then we're going to take time out. 

11 MR. DEMPSEY: I guess I support that from 

12 Carrier's standpoint. I don't know about m

13 competitors over here to my left, but we have bee

14 spending a lot of time working on a local basis

15 taking the GAMA directory information, using loca

16 electrical and fuel cost in terms of marketing of ou

17 products. We feel that that's the most effective wa

18 in terms of addressing this issue. 

19 MODERATOR LANGMEAD: Gentlemen, let's tak

20 a break and ,we're going to come back at 11: 05 an

21 we'll talk about multifunctional appliances. 

22 (Whereupon, at 10:55 a.m., off the recor

23 until 11:08 a.m.) 

24 

25 

MODERATOR LANGMEAD: Gentlemen, we're al

ready to resume. We're going to talk abou

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

multifunction appliances. I'd like to start out wi

multifunction appliances with Ed Pollock going ove

the Carrier and Nordyne waivers, and then George Kell

will cover a briefing on the testing NIST ha

performed on multifunction appliances.

Ed, it's all your's.

MR. POLLOCK: Thank you, Jack. We'r

going to take a break now and talk about some eas

issues, multifunction appliances, particularly th

products that we primarily think of when we thi

about multifunction products are the space heating

space conditioning products which also serve to hea

water for domestic use. The two categories, o

course, the electrical ones which the heat pump, ai

conditioning units, and water heaters, simple version

of those would be the desuperheaters and then ther

are those systems which are full service year roun

performance.

In the space water heating combination

furnace type combination, we're looking at those whic

have primarily space heating function or those whic

have primarily water heating function. George Kell

is going to talk in more detail about the furnac

water heating combination.

The two that I wanted to address, it look

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

8

1 multifunction appliances. I'd like to start out wi

2 multifunction appliances with Ed Pollock going ov

3 the Carrier and Nordyne waivers, and then George Kel

4 will cover a briefing on the testing NIST h

5 performed on multifunction appliances. 

6 Ed, it's all your's. 

7 MR. POLLOCK: Thank you, Jack. We'

8 going to take a break now and talk about some ea

9 issues, multifunction appliances, particularly th

10 products that we primarily think of when we thin

11 about multifunction products are the space heating

12 space conditioning products which also serve to he

13 water for domestic use. The two categories, o

14 course, the electrical ones which the heat pump, a

15 condi tioning units, and water heaters, simple version

16 of those would be the desuperheaters and then the

17 are those systems which are full service year roun

18 performance. 

19 In the space water heating combinatio

20 furnace type combination, we're looking at those whi

21 have primarily space heating function or those whi

22 have primarily water heating function. George Kel

23 is going to talk in. more detail about the furna

24 water heating combination. 

25 The two that I wanted to address, it loo

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 
1

3

4

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

9

like we're a little bit off the scale on the size her

on my viewgraph. The two that I want to address wer

the two products which we granted waivers for. On

was Carrier system which did air conditioning an

water heating and space heating, and the other th

Nordyne which more :recently we have given a waiver fo

them to rate their product. -

I just wanted to put this up and give yo

some idea of the differences between the two products

Basically they perform the same functions. Carrier

had a few more bells and whistles on it, as you ca

see from the list of the different components here.

Those of you who were involved with th

rating of air conditioning systems are familiar wit

this list, it's the list of the tests that are

conducted for heat pump, air conditioning units usin

the ARI different test conditions. Of course throw

in with it when you have water heating, then you nee

to consider what happens to the system in each of th

functions when it's combined with water heating. An

so the list gets very long, it's very costly for th

manufacturers to test the product in order to obtai

the data and in order to come up with some idea o

what the system performs under the various operatin

conditions. As you can see from this list, combinin

(202) 234433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON , O.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

9

1 like we're a little bit off the scale on the size her

2 on my viewgraph. The two that I want to address wer

3 the two products which we granted waivers for. On

4 was Carrier system which did air conditioning an

5 water heating and space heating, and the other th

6 Nordyne which more ,recently we have given a waiver fo

7 them to rate their product. 

8 I just wanted to put this up and give yo

9 some idea of the differences between the two products

10 Basically they perform the same functions. Carrie

11 had a few more bells and whistles on it, as you ca

12 see from the list of the different components here. 

13 Those .of you who were involved with th

·14 rating of air conditioning systems are familiar wit

15 this list, it's the list of the tests that ar

16 conducted for heat pump, air conditioning units usin

17 the ARI different test conditions. Of course throw

18 in with it when you have water heating, then you nee

19 to consider what happens to the system in each of th

20 functions when it's combined with water heating. An

21 so the list gets very long, it's very costly for th

22 manufacturers to test the product in order to obtai

23 the data and in order to come up with some idea o

24 what the system performs under the various operatin

25 conditions. As you can see from this list, combinin

(202)~ 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

9

both space heating and space cooling, we have, what

about 15 different which have to be run.

As far as the energy descriptors, the

has been a long debate about what descriptor do yo

use for describing the performance of a product whic

does more than one function. For the consumer, a

we've talked about this morning, it would be nice t

have one number where he can compare the product, bu

now we have two different loads being satisfied, s

how are those combined.

In the case of Hydrotech 2000, the

reported the heating and cooling performance factor

as you would have for the normal heat pump typ

system, and operating costs as well as the annua

energy savings comparing the energy savings of 

typical heat pump air conditioning system and th

water heating load under typical rating with what i

cost for the combined or save energy use for th

combined products. So you had a savings, th

difference between the separate products and th

integrated product.

Nordyne is reporting somewhat similar a

far as the separate costs for operating the efficienc

for the product, but they have proposed, and we hav

given them a waiver to allow them to have a rating fo

(202) 234-4433

NEAL R. GROSS ,

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

9

1 both space heating and space cooling, we have, wha

2 about 15 different which have to be run. 

3 As far as the energy descriptors, ther

4 has been a long debate about what descriptor do yo

5 use for describing the performance of a product whic

6 does more than one function. For the consumer, a

7 we've talked about this morning, it would be nice t

8 have one number where he can compare the product, bu

9 now we have two different loads being satisfied, s

10 how are those combined. 

11 In the case of Hydrotech 2000, the

12 reported the heating and cooling performance factor

13 as you would have for the normal heat pump typ

14 system, and operating costs as well as the annu

15 energy. savings comparing the energy savings of 

16 typical heat pump air conditioning system and th

17 water heating load under typical rating with what i

18 cost for the combined or save energy use for th

19 combined products. So you had a savings, th

20 difference between the separate products and th

21 integrated product. 

22 Nordyne is reporting somewhat similar a

23 far as the separate costs for operating the efficienc

24 for the product, but they have proposed, and we hav

25 given them a waiver to allow them to have a rating fo

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
9

1 the integrated product in the cooling season and i

2 the heating load. And what they've done basically in

3 order to get this number is to calculate and sum up

all of the operating energy that's used under variou

5 load conditions and the energy that's used or the

6 output of the system under various operating

conditions and just as we would do in calculating

8 SEER, it's a BTU out divided by the kilowatt hours in

9 and so you have the sum of the outputs divided by the

10 input, to give you a ratio similar to the SEER ratio,

11 only they're calling it a combined heating performance

12 factor and a combined cooling performance factor.

13 There have been several other possibl

14 ways of combining these which have been suggested. 

15 have noted two of them here. One would be a

16 equivalence SEER or an equivalent HSPF. The problem

17 with any of these, when you start combining in thes

18 equivalences, what credit do you give for savings t

19 the one load, the heating load or the cooling load and

20 to the water heating load.

21 The tendency has been to want to , becaus

22 of demand side management programs , and credits tha

23 are given there, to want to give all the credit fo

24 the water heating savings to the -- cooling or heating

25 efficiency so that that SEER value of the HSPF valu

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

9

1 the integrated product in the cooling season and in 

2 the heating load. And what they've done basically in 

3 order to get this number is to calculate and sum u

4 all of the operating energy that's used under variou

5 . load conditionS and the energy that's used or th

6 output of the system under various operating 

7 condi tions and just as we would do in calculating 

8 SEER" it's a BTU out divided by the kilowatt hours in 

9 and so you have the sum of the outputs divided by th

10 input, to give you a ratio similar to the SEE~ ratio

11 only they're calling ita combined heating performanc

12 factor and a combined cooling performance factor. 

13 There have been several other possibl

14 ways of combining these which have been suggested. 

15 have noted two of them here. One would be a

16 equivalence SEER or an equivalent HSPF. The problem 

17 with any of these, when you start combining in thes

18 equivalences, what credit do you give for savings t

19 the one load, the heating load or the cooling load an

20 to the water heating load. 

21 The tendency has been to want to, becaus

22 of demand side management programs, and credits tha

23 are given there, to want to give all the credit fo

24 the water heating savings to the -- cooling or heatin

25 efficiency so that that SEER value of the HSPF valu

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

3

5

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

93

goes higher and not to consider any of the savings

that's a result of the water heating. And this is of

course very misleading to the consumer. It does

sometimes increase sales I guess as a combined

product.

And the other way that' s been proposed is

an energy equivalent factor which would be strictly

similar to the combined heating or cooling performance

factor, but in this case would be using the same

units, kilowatt hours in and kilowatt hours out or

BTUs in, BTUs out, so that you had a dimensionless

number similar to the COP or EER.

So that's what has been proposed and I'm

sure there are descriptors that could be used, but of

course the problem still comes, what is the most

useful to the consumer when we get down to sales.

And I'm going to let George then talk a

little bit about what happens on the heating fossil

fuel type systems.

MR. KELLY: Again, I'm George Kelly from

NIST. You've been given a little bit of background on

the existing test procedure now that is the industry

standard, it's not a DOE test procedure. It's

ASHRAE/ANSI standard 124. Joe Pietsch and others were

involved in developing it. Basically there are two

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 234

EE-DET-94-101 COMMENT 0D

93 

1 goes higher and not to consider any of the saving

2 that's a result of the water heating. And this is o

3 course very misleading to the consumer. It doe

4 sometimes increase sales I guess as a combiqed 

5 product. 

6 And the other way that's been proposed is 

7 an energy equivalent factor which would be strictly 

8 similar to the combined heating or cooling performance 

9 factor, but in this case would be using the sam

10 units, kilowatt hours in and kilowatt hours out o

11 BTUs in, BTUs out, so that you had a dimensionles

12 number similar to the COP or EER. 

13 So that's what has been proposed and I'm 

14 sure there are descriptors that could be used, but o

15 course the problem still comes, what is the mos

16 useful to the consumer when we get down to sales. 

17 And I'm going to let George then talk a 

18 little bit about what happens on the heating fossi

19 fuel type systems. 

20 MR. KELLY: Again, I'm George Kelly from 

21 NIST. You've been given a little bit of background o

22 the existing test procedure now that is the industry 

23 standard, it's not a DOE test procedure. It's 

24 ASHRAE/ANSI standard 124. Joe Pietsch and others wer

25 involved in developing it. Basically there are tw

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON. D.C. 20005 (202) 23
1

2

3

4

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

9

types of appliances, type one and type two. Type on

is the kind that's primary function is space heating

second function water heating, and examples of thos

are space heating boiler with a tankless water heate

or a space heating coil with an interact heated hot

water storage tank.

And type two, the primary function i

water heating, secondary function is space heating

and that's your typical water heater.

And a diagram of type one appliance whic

is a boiler, a boiler with a tankless coil here. I

you have an oil fired boiler, typically your applianc

is hearing your hot water. Another type one is als

a boiler with a storage tank. Water is circulate

through a coil in the storage tank and this i

domestic hot water stored in the storage tank. Agai

it's a type one.

Type two, most of you recognize this i

your typical hot water heater with domestic wate

being supplied to your taps, and then water either t

an air handling unit, in this case with a coil in it

and then air is ducted to your rooms , or else t

baseboard. It could be baseboard heat too. That i

again a type two appliance.

Okay, the 124 test procedure requires tw

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

9

1 types of appliances, type one and type two. Type on

2 is the kind that's primary function is space heating

3 second function water heating, and examples of thos

4 are space heating boiler with a tankless water heate

5 or a space heating coil with an interact heated ho

6 water storage tank. 

7 And type two, the primary function i

8 water heating, secondary function is space heating

9 and that's your typical water heater. 

10 And a diagram of type one appliance whic

11 is a boiler, a boiler with a tankless coil here. I

12 you have an oil fired boiler, typically your applianc

13 is hearing your hot water. Another type one is als

14 a boiler with a storage tank. Water is circulate

15 through a coil in the storage tank and this i

16 domestic hot water stored in the storage tank. Agai

17 it's a type one. 

18 Type two, most of you recognize this i

19 your typical hot water heater with domestic wate

20 being supplied to your taps, and then water either t

21 an air handling unit, in this case with a coil in it

22 and then air is ducted to your rooms, or else t

23 baseboard. It could be baseboard heat too. That i

24 again a type two appliance. 

25 Okay, the 124 test procedure requires tw

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

2

4

5

6

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

9

separate tests. A space heating test which is done i

accordance with ASHRAE 103 standard which is basicall

the furnace boiler test I was talking about thi

morning. The steady state cool-down and warm-up, tha

sort of stuff.

And then test 2 is a water heating tes

done in accordance with the DOE test procedure fo

type two or a similar type test procedure that'

spelled out on 124. It's basically the same as th

DOE water heating test procedure. And that comes u

with an energy factor.

124 also has a calculation section an

allows you to determine the space heating seasona

efficiency. Space heating is assumed to be done a

the efficiency of the heating season, they call i

EFFHS. It's actually an ADU, that far load efficienc

that I showed you this morning. The water heatin

efficiency is done at stead state efficiency of th

appliance during the non heating season and wat

heating season it's done at the energy facto

calculated by the DOE procedure, DOE water heatin

procedure.

Okay, those have been combined into th

efficiency descriptors. You have a combined heatin

season efficiency descriptor that includes space an

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

9

1 separate tests. A space heating test which is done i

2 accordance with ASHRAE 103 standard which is basicall

3 the furnace boiler test I was talking about thi

4 morning. The steady state cool-down and warm-up, tha

5 sort of stuff. 

6 And then test 2 is a water heating tes

7 done in accordance with the DOE test procedure fo

8 type two or a similar type test procedure that

9 spelled out on 124. It~s basically the same as th

10 DOE water heating test procedure. And that comes u

11 with an energy factor. 

12 124 also has a calculation section an

13 allows you to determine the space heating seasona

·14 efficiency. Spape heating is assumed to be done a

15 the efficiency of the heating season, they call i

16 EFFHS. It's actually an ADU, that far load efficienc

17 that I showed you this morning. The water heatin

18 efficiency is done at stead state efficiency of th

19 appliance during the non heating season and wat

20 ,heating season it's done at the energy facto

21 calculated by the DOE procedure, DOE water heatin

22 procedure. 

23 Okay, those have been combined into th

24 efficiency descriptors. You have a combined heatin

25 season efficiency descriptor that includes space an

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHOOE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 2
1

3

4

5

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

9

water heating during the heating season. You have 

non heating season descriptor. And finally you hav

a combined annual efficiency, the CAE term which is 

combination of space and water heating in the heatin

season and water heating in the non heating season

And those terms are derived from the previous terms b

weighting them with the filling loads and water loads

and also the lengthy non heating season versus th

length of the heating season.

Okay, we did some tests in this, an

comparing the 124, the results in the 124 standar

with -- calculated and determined in the lab, w

looked at two types. One was a type one oil fire

boiler where the tank was here. The other one was 

type two, a gas fired water heater with an air

handling unit. And what we actually did was we di

combined testing which we cycled the unit. We impose

a heating load on it, okay, and cycled the unit fo

heating mod and we imposed a water drill loan on to

of that and actually measured the input/output an

determined the efficiency of both these type one an

type two appliances, and then we compared that resul

with the ASHRAE 124 standard.

So we got a good agreement as you can se

here. For the type ones, the space heating, primar

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

9

1 water heating during the heating season. You have 

2 non heating season qescriptor. And finally you hav

3 a combined annual efficiency, the CAE term which is 

4 combination of space and water heating in the heatin

5 season and water heating in the non heating season

6 And those terms are derived from the previous terms b

7 weighting them with the filling loads and water loads

8 and also the lengthy non heating season versus th

9 length of the heating season. 

10 Okay, we did some tests in this, an

11 comparing the 124, the results in the 124 standar

12 wi th -- calculated and determined in the lab, w

13 looked at two types. One was a type one oil fire

14 boiler where the tank was here. The other one was 

15 type two, a gas fired water heater with an ai

16 handling unit. And what we actually did was we di

17 combined testing which we cycled the unit. We impose

18 a heating load on it, okay, and cycled the unit fo

19 heating mod and we imposed a water drill loan on to

20 o£ that and actually measured the input/output an

21 determined the efficiency of both these type one an

22 type two appliances, and then we compared that resu

23 with the ASHRAE 124 standard. 

24 So we got a good agreement as you can se

25 here. For the type ones, the space heating, prima

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 2
2

3

4

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

9

function space heating, secondary is water heating, we

came up with in the lab test, cyclic test, the actual

input/output test efficiency of 79.4. We had a 124

calculations and came up with 79.2, 2/10ths of a

percent difference. For the type two, again the

measure of the efficiency was 77.1. The 124 came up

with 76.8, a difference of 3/10th efficiency points.

Tests were also performed by AGA and

Batelle on four products of this nature, type one and

type two, and they found results that showed that the

measured lab results on the cyclic operating condition

was agreed with the 124 calculations within fiv

percent. So this seems to confirm the accuracy of th

124 standard. Just for your information type one

appliances, the boiler had a steady state efficienc

of 83; it was a oil unit. The combined efficiency

came out to be 76. The efficiency for the type tw

energy factor was .54, but it came out with a combine

efficiency of 73.8.

Generally the primary reason is it'

heating season efficiency. It's prior load efficiency

during the heating season is typically lower. Th

type one was 78, and the type two was 76. Unles

you've got a condensing type two appliances, you'r

going to generally see a lower CAE than if you'r

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

9

1 function space heating, secondary is water heating, w

2 came up with in the lab test, cyclic test, the actua

3 input/output test efficiency of 79.4. We had a 12

4 calculations and came up with 79.2, 2/10ths of 

5 percent difference. For the type two, again th

6 measure of the efficiency was 77.1. The 124 came u

7 with 76.8, a difference of 3/10th efficiency points

8 Tests were also performed by AGA an

9 Batelle on four products of this nature, type one an

10 type two, and they found results that showed that th

11 measured lab results on the cyclic operating conditio

12 was agreed with the 124 calculations within fiv

13 percent. So this seems to confirm the accuracy of th

14 124 standard. Just for your information type on

15 appliances, the boiler had a steady state efficienc

16 of 83 i it was a oil unit. The combined efficienc

17 came out to be 76. The efficiency for the type tw

18 energy factor was .54, but it came out with a combine

19 efficiency of 73.8. 

20 Generally the primary reason is it'

21 heating season efficiency. It's prior load efficienc

22 during the heating season is typically lower. Th

23 type one was 78, and the type two was 76. Unles

24 you've got a condensing type two appliances, you'r

25 going to generally see a lower CAE than if you'r

(202) 2344433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 23
1

2

3

5

6

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

9

dealing with a type one product. It does have som

impact on how you set your minimum standards.

Okay. And just very briefly we did som

other tests. If you look at family series of type on

appliances, and we looked at gas fired type one, ga

fired boilers, different gas lines with identica

water storage tanks. Different boilers using the sam

external water tank, and we also looked at oil fire

boilers with the same tankless coil heater. On

tankless here that's used in different oil fire

boilers, and we performed the ASHRAE 103 and 124 test

and let me just show you the results. We plotte

steady state efficiency, heating season efficiency

CAE, energy factor, and this is with the one storag

tank with different size boilers and show that yo

could pretty much come up in a straight line.

The purpose of this was to say that if yo

had a family of boilers, could you reduce, the tes

burden by maybe just testing the highest one and th

lowest one. And it looks like the straight lin

correlation for the storage tank and pretty much fo

the tankless coil too, a little bit of bend in th

energy factor down there.

Our conclusion was item here, number four

results indicated that -- interpretation of the ratin

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

9

1 dealing with a type one product. It does have som

2 impact on how you set your minimum standards. 

3 Okay. And just very briefly we did som

4 other tests. If you look at family series of type on

5 appliances, and we looked at gas fired type one, ga

6 fired boilers, different gas lines with identica

7 water storage tanks. Different boilers using the sam

8 external water tank, and we also looked at oil fire

9 boilers with the same tankless coil heater. On

10 tankless here that's used in different oil fire

11 boilers, and we performed the ASHRAE 103 and 124 test

12 and let me just show you the results. We plotte

13 steady state efficiency, heating season efficiency

14 CAE, energy factor, and this is with the one storag

15 tank with different size boilers and show that yo

16 could pretty much come up in a straight line. 

17 The purpose of this was to say that if yo

18 had a family of boilers, could you reduce, the tes

19 burden by maybe just testing the highest one and th

20 lowest one. And it looks like the straight lin

21 correlation for the storage tank and pretty much fo

22 the tankless coil too, a little bit of bend in th

23 energy factor down there. 

24 Our conclusion was item here, number four

25 resul ts indicated that -- interpretation of the ratin

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

2

4

5

6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

9

parameters that a CAE or energy factor or spaced state

efficiency within a family series in buying an

appliance, so it is possible, and will reduce the test

burden on manufacturers, so I presume that we wil

propose something like testing the largest one and

testing the smallest one and using that to rate the

family. So that's basically what I have to say.

Dan, do you have a question?

MR. DEMPSEY: Dan Dempsey, Carrier

George on the type two tests, is that based on indoor

or an ICS environment?

MR. KELLY: The calculated CAE you're

talking about?

MR. DEMPSEY: Yes.

MR. KELLY: Stan? The type two.

MR. LIV: Yes, the boiler are all teste

indoors.

MR. KELLY: Everything was indoors.

MR. DEMPSEY: Okay. I guess one of th

concerns we have is that in the appendix to 124 ther

is a procedure to calculate an equivalent AFUE an

since the type two products are predominantly force

air heating products, the equivalent AFUE is bein

compared to ICSA if you read the forced air furnac

and that we believe that there should be some chang

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

99 

1 parameters that a CAE or energy factor or spaced state 

2 efficiency within a family series in buying an 

3 appliance, so it is possible, and will reduce the tes

4 burden on manufacturers, so I presume that we wil

5 propose something like testing the largest one an

6 testing the smallest one and using that to rate th

7 family. So that's basically what I have to say. 

8 Dan, do you have a question? 

9 MR. DEMPSEY: Dan Dempsey, Carrier

10 George on the type two tests, is that based on indoo

11 or an ICS environment? 

12 MR. KELLY: The calculated CAE you'r

13 talking about? 

14 MR. DEMPSEY: Yes. 

15 MR. KELLY: Stan? The type two. 

16 MR. LIV: Yes, the boiler are all teste

17 indoors. 

18 MR. KELLY: Everything was indoors. 

19 MR. DEMPSEY: Okay. I guess one of th

20 concerns we have is that in the appendix to 124 ther

21 is a procedure to calculate an equivalent AFUE an

22 since the type two products are predominantly force

23 air heating products, the equivalent AFUE is bein

24 compared to ICSA if you read the forced air furnac

25 and that we believe that there should be some chang

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NoW. 

WASHINGTON, D.C. 20005 (202) 2
2

3

4

5

7

8

10

11

12

13

.14

15

16

17

18

19

20

21

22

23

24

25

10

made to put those on the same scale. Such as the typ

two products today, there is cabinet loss, jacket

loss, piping loss is not conducted.

MR. KELLY: Okay, there are some -- yes,

there is some discrepancies like that. In addition t

that in the 124, and there's a lot of pushing and

shoving on the committee, they eliminated it. You get

into the problem of double-dipping too, okay. And as

was just explained you can take the savings from the

water and put it on the space heating, or you can take

the savings and put it on the water heating, okay

And 124 specifies that you have to put it on th

primary function, okay. So the type one which primary

function is space heating, you would be able to reduc

you AFUE by the combined savings . Type two you'd b

able to reduce your energy factor coming up with a --

energy factor, but you can't do it on both, you can'

double-dip or claim the savings twice.

Unfortunately there 's been some , I guess

advertising after that which does not take that int

account and does apply the savings to the -- wate

savings in space heating . It's a serious issue, an

I guess there ' s another issue that you're just raisin

too, comparing apples and oranges a little bit wit

isolating combustion --

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

10

1 made to put those on the same scale. Such as the typ

2 two products today, there is cabinet loss, jacke

3 loss, piping loss is not conducted. 

4 MR. KELLY: Okay, there are some -- yes

5 there is some discrepancies like that. In addition to 

6 that in the 124, and there's a lot of pushing an

7 shoving on the committee, they eliminated it. You ge

8 into the problem of double-dipping too, okay. And a

9 was just explained you can take the savings from th

10 water and put it on the space heating, or you can tak

11 the savings and put it on the water heating, okay

12 And 124 specifies that you have to put it on th

13 primary function, okay. So the type one which primar

-14 function is space heating, you would be able to reduc

15 you AFUE by the combined savings. Type two you'd b

16 able to reduce your energy factor coming up with a 

17 energy factor, but you can't do it on both, you can

18 double-dip or claim the savings twice. 

19 Unfortunately there's been some, I guess

20 advertising after that which does not take that int

21 account and does apply the savings to the -- wate

22 savings in space heating. It's a serious issue, an

23 I guess there's another issue that you're just raisin

24 too, comparing apples and oranges a little bit wit

25 isolating combustion --

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 23
2

3

4

5

6

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10

MR. DEMPSEY: Also, I have a follow up o

the type two system. Was the actual air handle

tested or was it just a delta T presumed to exist?

MR. KELLY: Actually the air handler wa

tested.

MR. STANONIK: George, Frank Stanonik wit

GAMA, in the test work you did, on the first series o

tests you did a type one which was an oil fired

boiler, do you recall what the input of that was?

MR. KELLY: It's over in here. Lik

130,000, something like that, compared with a wate

heater.

MR. STANONIK: Okay. Now, in the secon

set of. tests that you did where you were looking at i

there was a relationship between the specific boile

and the coil you put in or whatever, what was th

highest input you measured there?

MR. KELLY: I don't -- the reports, so.

MR. STANONIK: All right. Well, th

reason I asked is it' s been said to me without an

follow-up technical information that 124 seems t

break down when you get into the -- it could cover, i

terms of residential boilers, it could cover somethin

up to 300, 000 BTU, and it has been suggested to m

that 124 breaks down when you start dealing wit

(202) 234-4493

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

10

1 MR. DEMPSEY: Also, I have a follow up o

2 the type two system. Was the actual air handle

3 tested or was it just a delta T presumed to exist? 

4 MR. KELLY: Actually the air handler wa

5 tested. 

6 MR. STANONIK: George, Frank Stanonik wit

7 GAMA, in the test work you did, on the first series o

8 tests you did a type one which was an oil fire

9 boiler, do you recall what the input of that was? 

10 MR. KELLY: It's over in here. Lik

11 130,000, something like that, compared with a wate

12 heater. 

13 MR. STANONIK: Okay. Now, in the secon

14 set o~ tests that you did where you were looking at i

15 there was a relationship between the specific boile

16 and the coil you put in or whatever, what was th

17 highest input you measured there? 

18 MR. KELLY: I don't --the reports, so. 

19 MR. STANONIK: All right. Well, th

20 reason I asked is it's been said to me without an

21 follow-up technical information that 124 seems t

22 break down when you get into the -- it could cover, i

23 terms of residential boilers, it could cover somethin

24 up to 300,000 BTU, and it has been suggested to m

25 that 124 breaks down when you start dealing wit

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10

appliances that are in the, let's say 200,000 BTU pe

hour plus range, and I just wondered if you had looke

at any of those?

MR. KELLY: No, I hadn't seen that. Th

range here was 25, the gas unit was 25, and the KW t

45 KW input.

MR. STANONIK: Okay, - that's not a lot

And I just mention it because it's been mentioned t

me and I have nothing to say that it's true or false

MR. KELLY: Okay. There's nothing to loo

at.

MR. RANFONE: Jim Ranfone here. Just 

question, George. You said that type two equipment i

based on or assume it's the cyclic time of the boiler

Was there any discussion, were you looking at doin

different cycle times?

MR. KELLY: We did a range of cyclin

times and it didn't seem to have much --

MR. RANFONE: -- factor using the force ai

type --

MR. KELLY: -- that's right.

MODERATOR LANGMEAD: Are there othe

question for Joe or for George?

MR. PIETSCH: Joe Pietsch. I'm a

engineering consultant and I was very much active wit

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

10

1 appliances that are in the, let's say 200,000 BTU pe

2 hour plus range, and I just. wondered if you had looke

3 at any of those? 

4 MR. KELLY: No, I hadn't seen that. Th

5 range here was 25, the gas unit was 25, and the KW t

6 45 KW input. 

7 MR. STANONIK: Okay, -·that 's not a lot

8 And I just mention it because it's been mentioned t

9 me and I have nothing to say that it's true or false

10 MR. KELLY: Okay. There's nothing to loo

11 at. 

12 MR. RANFONE: Jim Ranfone here. Just 

13 question, George. You said that type two equipment i

14 based on or assume it's the cyclic time of the boiler

15 Was there any discussion, were you looking at doin

16 different cycle times? 

17 MR. KELLY: We did a range of cyclin

18 times and it didn't seem to have much --

19 MR. RANFONE: -- factor using the force ai

,20 type --

21 MR. KELLY: -- that's right. 

22 MODERATOR LANGMEAD: Are there othe

23 question for Joe or for George? 

24 MR. PIETSCH: Joe Pietsch. I'm a

25 engineering consultant and I was very much active wi

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 2
2

3

5

6

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10

the 124 standard. First of all, it isn't 124 tha

says to apply all the savings from the 124 of eac

combined approach. Type one, apply that to water

heating. And on the type two which is basically a

water heater, apply the same things over in the spac

heating section --

MR. KELLY: We have a total combined

equivalent factor, but for the primary function.

MR. PIETSCH: Well, no, there was a

directive that came out of a government agency that

said if you have a water heater and you add space

heating to it, you have to give the energy factor for

water heating and you can't take any credit on

providing the appliance for the water heating

function. You had to use the energy factor for the

water heating test --

On the other side if you had a boiler and

add water heating to it, you've got to come up with

the AFUE for the boiler. So that just leaves them,

whatever savings you get not only by what maybe makes

good sense, but also by what the government has said.

You've got to apply it to the secondary function.

MR. KELLY: Correct. You can have an

equivalent energy factor for type one appliances or

you can have na equivalent for effective AFUE for the

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

(202) 23444.33 WASHINGTON. D.C. 20005 (202) 234-44

EE-DET-94-101 COMMENT 0D

103 

1 the 124 standard. First of all, it isn't 124 tha

2 says to apply all the savings from the 124 of each 

3 combined approach. Type one, apply that to wate

4 heating. And on the type two which is basically 

5 water heater, apply the same things over in the spac

6 heating section 

7 MR. KELLY: We have a total combine

8 equivalent factor, but for the primary function. 

9 MR. PIETSCH: Well, no, there was 

10 directive that came out of a government agency tha

11 said if you have a water heater and you add spac

12 heating to it, you have to give the energy factor fo

13 water heating and you can't take any credit o

14 providing the appliance for the water heating 

15 function. You had to use the energy factor for th

16 water heating test 

17 On the other side if you had a boiler an

18 add water heating to it, you've got to come up wit

19 the AFUE for the boiler. So that just leaves them

20 whatever savings you get not only by what maybe make

21 good sense, but also by what the government has said

22 You've got to apply it to the secondary function. 

23 MR. KELLY: Correct. You can have a

24 equivalent energy factor for type one appliances o

25 you can have na equivalent for effective AFUE for th

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 23
10

1 type two appliance, yes.

MR. PIETSCH: Do it wasn't the 124 tha

4

5

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

came up --

MR. KELLY: But that's --

MR. PIETSCH: -- calling what appear to b

the government regulation--

MR. KELLY: -- but that's being violate

right now I think.

MR. PIETSCH: Where is it being violate

at?

MR. KELLY: We've seen some ads that ar

doing --

MR. PIETSCH: -- doesn't have them. Thes

products are listed in the GAMA director and I don'

there is any violation.

MR. KELLY: I'm sure it's not there. Bu

there certainly is a potential for that, okay. Yo

just need to watch it when you're dealing with thes

inspections.

MR. PIETSCH: Well, do you have record

you've seen ads of this type?

MR. KELLY: I don't have them. I've see

them, yes.

MR. PIETSCH: Well, this is kind of 

generalization, George.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

10

1 type two appliance, yes. 

2 MR. PIETSCH: Do it wasn't the 124 tha

3 came up --

4 MR. KELLY: But that's --

5 MR. PIETSCH: calling what appear to b

6 the government regulation--

7 MR. KELLY: -- but that's being violate

8 right now I think. 

9 MR. PIETSCH: Where is it being violate

10 at? 

11 MR. KELLY: We've seen some ads that ar

12 doing --

13 MR. PIETSCH: -- doesn't have them. Thes

14 products are listed in the GAMA director and I don

15 there is any violation. 

16 MR. KELLY: I'm sure it's not there. Bu

17 there certainly is a potential for that, okay. Yo

18 just need to watch it when yqu're dealing with thes

19 inspections. 

20 MR. PIETSCH: Well, do you have record

21 you've seen ads of this type? 

22 MR. KELLY: I don't have them. I've see

23 them, yes. 

24 MR. PIETSCH: Well, this is kind of 

25 generalization, George. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

5

6

7

8

10

11

12

13

.14

15

16

17

18

19

20

21

22

23

24

25

10

MR. KELLY: It's not a --, Joe. I'm jus

pointing out that there is some potential for thi

problem, okay, and just be aware of it in developin

energy descriptors.

MR. PIETSCH: And I have another commen

about for the use of boiler timing or the furnac

timing. You said it didn't make much difference, bu

people don't recognize that these --

MR. KELLY: The- air handler used th

furnace cycle, and you have a variety of them.

MR. PIETSCH: -- but the combustion syste

does not cycle with the air handler, it cycles wit

the thermostat that's on the tank.

MODERATOR LANGMEAD: Keep it a littl

louder, Joe, I can't hear you.

MR. KELLY: And the control system on th

water heater took care of itself. That's what 

recall. Those are --

MODERATOR LANGMEAD: Dan?

MR. DEMPSEY : Just a reiteration, I don

think it's whether you assume it's a boiler or 

furnace in terms of the cycle timing, the it's the en

use of the product in the marketplace , and all forc

air heating systems should be treated alike.

(202) 234-4433

MR. KELLY: We did. As I said I believ

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

10

1 MR. KELLY: It's not a --, Joe. I'm jus

2 pointing out that there is some potential for thi

3 problem, okay, and just be aware of it in developin

4 energy descriptors. 

5 MR. PIETSCH: And I have another comme

6 about for the use of boiler timing or the furnac

7 timing. You said it didn't make much difference, bu

8 people don't recognize that these 

9 MR. KELLY: The air handler used th

10 furnace cycle, and you have a variety of them. 

11 MR. PIETSCH: but the combustion syste

12 does not cycle with the air handler, it cycles wi

13 the thermostat that's on the tank. 

. 14 MODERA TOR LANGMEAD: Keep it a littl

15 louder, Joe, I can't hear you. 

16 MR. KELLY: And the control system on th

17 water heater took care of itself. That's what 

18 recall. Those are 

19 MODERATOR LANGMEAD: Dan? 

20 MR. DEMPSEY: Just a reiteration, I don

21 think it's whether you assume it's a boiler or 

22 furnace in terms of the cycle timing, the it's the e

23 use of the product in the marketplace, and all forc

24 air heating systems should be treated alike. 

25 

(202) 234-4433 

MR. KELLY: We did. As I said I belie

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 
10

2

3

4

5

6-

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

it was furnace cycle times we were doing. And

whatever the unit did by its own -- it did.

MODERATOR LANGMEAD: Are there other

questions for George?

Cyrus?

MR. NASSERI: Cyrus Nasseri, Department o

Energy. This type of work has been given to NIST b

the Department of Energy because of the importance o

having eventually a test procedure similar to ASHRAE

124. DOE test procedure to rate this type o

appliances, combination of items type one and typ

two, as George described.

The reports, two reports has bee

published by KIST, we call it NIST Air. Well, that'

NIST's reports, and they are available if anybody i

interested to have a copy of it. You can contact me

And eventually all this research and some of thes

other studies as far as the linearity of some of thes

number of tests for making the test presume more les

time consuming for manufacturers and all that woul

result in a proposed rule.

I'm not promising any time soon, but it'

an agenda proposed as a DOE test procedure fo

combination appliances covering this type o

appliances very soon. And obviously it would be 

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

10

1 it was furnace cycle times we were doing. An

2 whatever the unit did by its own -- it did. 

3 MODERATOR LANGMEAD: Are there othe

4 questions for George? 

5 Cyrus? 

6 MR. NASSERI: Cyrus Nasseri, Department o

7 Energy. This type of work has been given to NIST b

8 the Department of Energy because of the importance o

9 having eventually a test procedure similar to ASHRA

10 124. DOE test procedure to rate this type o

11 appliances, combination of items type one and typ

12 two, as George described. 

13 The reports, two reports has bee

14 published by NIST, we call it NIST Air. Well, that'

15 NIST's reports, and they are available if anybody i

16 interested to have a copy of it. You can contact me

17 And eventually all this research and some of thes

18 other studies as far as the linearity of some of thes

19 number of tests for making the test presume more les

20 time consuming for manufacturers and all that woul

21 result in a proposed rule. 

22 I'm not promising any time soon, but it'

23 an agenda proposed as a DOE test procedure fo

24 

25 

combination appliances covering this type o

appliances very soon. And obviously it would be 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

4

5

6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

10

reference , actually 124 plus all the other finding

that we had as a result of the research by NIST give

by DOE.

MODERATOR LANGMEAD: Any additiona

questions for George or for Cyrus?

Jim Ranfone?

MR. KELLY: Joe Pietsch, I have anothe

comment. ASHRAE 124 had a 1991 date on it. b

ASHRAE procedures it should be reviewed every fiv

years. So in 1996 it probably will be sent to one o

the ASHRAE committees to determine whether it shoul

be reaffirmed or revised. So if anybody has an

thoughts about problems with 124, I think that's th

proper to address -- not necessarily --

MR. NASSERI: As a matter of fact this i

a very good point because the other day I was askin

somebody -- which TC sponsored 124, which I found ou

is 6.6. And I was planning at Atlanta an ASHRA

Atlanta meeting to approach the 6.6 chairman and brin

this issue up with him, and as you know the ASHRA

regulation that TC has to initiate, the SPC which th

cycle is there, you're correct on your's and we woul

like to approach TC 6.6 to discuss the issue and as

the chairman if they can assign a chairman for SPC fo

2511 the revision of the 124.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

10

1 reference, actually 124 plus all the other finding

2 that we had as a result of the research by NIST give

3 by DOE. 

4 MODERATOR LANGMEAD: Any additiona

5 questions for George or for Cyrus? 

6 Jim Ranfone? 

7 MR. KELLY: Joe Pietsch, I have anothe

8 comment. ASHRAE 124 had a 1991 date on it. b

9 ASHRAE procedures it should be reviewed every fiv

10 years. So in 1996 it probably will be sent to one o

11 the ASHRAE committees to determine whether it shoul

12 be reaffirmed or revised. So if anybody has an

13 thoughts about problems with 124, I think that's th

14 proper to address -- not necessarily --

15 MR. NASSERI: As a matter of fact this i

16 a very good point because the other day I was askin

17 somebody -- which TC sponsored 124, which I found ou

18 is 6.6. And I was planning at Atlanta an ASHRA

19 Atlanta meeting to appz;oach the 6.6 chairman and brin

20 this issue up with him, and as you know the ASHRA

21 regulation that TC has to initiate, the SPC which th

22 cycle is there, you're correct on your's and we wou

23 like to approach TC 6.6 to discuss the issue and as

24 the c~airman if they can assign a chairman for SPC fo

25 the revision of the 124. 

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10

Obviously the findings that we have o

this would be presented to the SPC and hopefully t

revise the 124, moreso the need working on th

rulemaking on a test procedure, DOE has -- for 

combination appliances , we have less write up in ther

and have basically referenced the 124 as much as w

can.

MODERATOR LANGMEAD: Jim Ranfone, do yo

have a question?

MR. RANFONE: Yes. I guess I'll direct t

Cyrus since you opened it up. Jim Ranfone, AGA. 

had a situation which was alluded to here where som

states are taking, looking at combination systems an

trying to apply the minimum efficiency requirements t

the heating side of a combination system, specifically

a water heating use for space heating. And we'v

tried to argue with them that the intent of the la

and the question of equity indicates that the primar

purpose of equipment is for water heating and it'

certified safety-wise underwater heater standard tha

it only has to meet the minimum efficiencies of wate

heating.

By the way this also applies -- and th

state has come back and said to us and well, if yo

install in our state, since it uses much more energ

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

10

1 Obviously the findings that we have o

2 this would be presented to the SPC and hopefully t

3 revise the 124, moreso the need working on th

4 rulemaking on a test procedure, DOE has -- for 

5 combination appliances, we have less write up in ther

6 and have basically referenced the 124 as much as w

7 can. 

8 MODERATOR LANGMEAD: Jim Ranfone, do yo

9 have a question? 

10 MR. RANFONE: Yes. I guess I'll direct t

11 Cyrus since you opened it up. Jim Ranfone, AGA. 

12 had a situation which was alluded to here where som

13 states are taking, looking at combination systems an

14 trying to apply the minimum efficiency requirements t

15 the heating side of a combination system, specificall

16 a water heating use for space heating. And we'v

17 tried to argue with them that the intent of the la

18 and the question of equity indicates that the primar

19 purpose of equipment is for water heating and it'

20 certified safety-wise underwater heater standard tha

21 it only has to meet the minimum efficiencies of wate

22 heating. 

23 By the way this also applies -- and th

24 state has come back and said to us and well, if yo

25 install in our state, since it uses much more energ

(202) 2344433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

5

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

for heating, we consider it a heating appliance an

therefore the 78 percent. or 80 percent minimu

applies.

Has DOE come out with anything on recor

on interpretation of the congressional record t

clarify that particular issue?

MR. NASSERI: Realize the fact -- Cyru

Nasseri, DOE, that we do not have a minimum energ

standard for this type of appliances at the presen

time. And the first thing to do is basically to hav

a test procedure, official test procedure, a DOE tes

procedure for rating these appliances. That's th

first step, what we are doing at the,present time, t

have a test procedure.

And then the next step would be t

basically do the analysis which is DOE is basicall

signed by legislation, the type of things that we hav

to do as far as what would be the minimum energ

efficiency for this type of appliances. And thi

wasn't originally the make up for these type o

appliances.

Again, you have to separate standards fo

this type of appliances, furnaces and for wate

heaters, minimum energy efficiency. But the issue i

what would be the minimum energy efficiency standard

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

10

1 for heating, we consider it a heating appliance an

2 therefore the 78 percent, or 80 percent minimu

3 applies. 

4 Has DOE come out with anything on recor

5 on interpretation of the congressional record t

6 clarify that particular issue? 

7 MR. NASSER!: Realize the fact -- Cyru

8 Nasseri, DOE, that we do not have a minimum energ

9 standard for this type of appliances at the presen

10 time. And the first thing to do is basically to hav

11 a test procedure, official test procedure, a DOE tes

12 procedure for rating these appliances. That's th

13 first step, what we are doing at the'present time, t

14 have a test procedure. 

15 And then the next step w'ould be t

16 basically do the analysis which is DOE is basicall

17 signed by legislation, the type of things that we hav

18 to do as far as what would be the minimum energ

19 efficiency for this type of appliances. And thi

20 wasn't originally the make up for these type o

21 appliances. 

22 Again, you have to separate standards fo

23 this type of appliances, furnaces and for wat

24 heaters, minimum energy efficiency. But the issue 

25 what would be the minimum energy efficiency standard

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

6

7

8

9

10

11

12

13

.14

15

16

17

18

19

20

21

22

23

24

25

11

for the combined appliances, and that's something tha

DOE has to look at to see what legal or wha

engineering of final test is.

MR. RANFONE: Well, Cyrus, I understan

that part. The question is that when you are sellin

in a state that has either high peak load hours or -

for that matter some of the states are suggesting o

stating that we have to meet the efficiency for th

heating portion of that combined appliance. And wha

you just said was, as I understand it, that DOE woul

come back and say that equipment isn't rated now, w

don't have any test methodology, there 's no minimum

for that, and would you go one step further and sa

that in reviewing the congressional record the inten

is that the product has to meet only the minimum fo

its primary function?

MODERATOR LANGMEAD: Gene, do you want t

respond to that?

MR. MARGOLIS: Eugene Margolis, DOE. I

you feel that the state is preempted by th

'legislation and the state disagrees with you and i

applying their own standards to a product that yo

feel is preempted, it would then be for you to go int

the state court or into federal court in that stat

and bring an action against that state energy offic

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

11

1 for the combined appliances, and that's something tha

2 DOE has to look at to see what legal or wh

3 engineering of final test is. 

4 MR. RANFONE: Well, Cyrus, I understan

5 that part. The question is that when you are sellin

6 in a state that has ei~her high peak load hours or 

7 for that matter some of the states are suggesting o

8 stating that we have to meet the efficiency for th

9 heating portion of that combined appliance. And wh

10 you just said was, as I understand it, that DOE woul

11 come back and say that equipment isn't rated now, w

12 don't have any test methodology, there's no minimum

13 for that, and would you go one step further and sa

.14 that in reviewing the congressional record the inten

15 is that the product has to meet only the minimum fo

16 its primary function? 

17 MODERA TOR LANGMEAD: Gene, do you want t

18 respond to that? 

19 MR. MARGOLIS: Eugene Margolis, DOE. I

20 you feel that the state is preempted by th

21 'legislation and the state disagrees with you and i

22 applying their own standards to a product that yo

23 feel is preempted, it would then be for you to go int

24 the state court or into federal court in that stat

25 and bring an action against that state energy offic

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
2

3

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11

or whatever office of that state is implementing it.

Because that is something that the stat

is doing that, if you feel is improper , you can tak

legal remedies against the state based on the statute

with it's section on preemption . But that is not, a

Cyrus said , we're coming out or we will investigate o

this combination appliance , but we do not, we have not

done in the past , when we- have been asked by

,manufacturers to go to some states and tell them that

you know, you cannot have standards , you canno

enforce state standards on these products because the

statute says it's preempted and gives the state a

remedy to come to us to get and exemption from

preemption. We do not go into the states and tell

them how they should do their business.

MODERATOR LANGMEAD: Gene , one littl

thought on that. Is there some reason that if 

manufacturer wrote to you and said we believe the

state is preempted because of the way it's covered i

the act and the primary function is covered, do yo

agree with us, couldn't you write back to tha

manufacturer?

MR. MARGOLIS: Well, in the past we hav

not. We have just said that that argument , since i

is argumentative, it's something for you to take u

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

II

1 or whatever office of that state is implementing it. 

2 Because that is something that the stat

3 is doing that, if you feel is improper, you can tak

4 legal remedies against the state based on the statut

5 with it's section on preemption. But that is not, a

6 Cyrus said, we're coming out or we will investigate o

7 this combination appliance, but we do not, we have no

8 done in the past, when we have been asked b

9 manufacturers to go to some states and tell them that

10 you know, you cannot have standards, you canno

11 enforce state standards on these products because th

12 statute says it's preempted and gives the state 

13 remedy to come to us to get and exemption from 

14 preemption. We do not go into the states and tel

15 them how they should do their business. 

16 MODERA TOR LANGMEAD: Gene, one little 

17 thought on that. Is there some reason that if 

18 manufacturer wrote to you and said we believe th

19 state is preempted because of the way it's covered i

20 the act and the primary function is covered, do yo

21 agree with us, couldn't you write back to tha

22 manufacturer? 

23 MR. MARGOLIS: Well, in the past we hav

24 not. We have just said that that argument, since i

25 is argumentative, it's something for you to take u

(202) 2344433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 23
2

4

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11

with the state. And if the state disagrees with you

then your remedy lies in the court system to tell th

state that they are preempt.

MODERATOR LANGMEAD: Mike?

MR. McCABE: Michael McCabe, Department o

Energy. To answer to your question, we have no

addressed that issue, we have not come out with any

position on that matter. I'm not aware that it ha

been put to us in a formal fashion. We have in th

past offered to manufacturers and others in response

the question, you placed, Jack, interpretations wit

respect to our regulations. But when it gets to th

states and what the states can do, there is a wide

range of law that goes beyond our regulations.

And in many instances in the past we hav

not been able to address those because it's a state

issue and we do not have any standard defense on th

question. If the question is put to us, we wil

certainly be required to consider it, but what sort o

consideration, how we would respond to it would depen

upon the nature of the question and the issues at

hand.

MODERATOR LANGMEAD: Very useful.

Other comments?- Were there any other

questions for Ed Pollock? He had gone through

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

11

1 with the state. And if the state disagrees with you

2 then your remedy lies in the court system to tell th

3 state that they are preempt. 

4 MODERATOR LANGMEAD: Mike? 

5 MR. McCABE: Michael McCabe, Department o

6 Energy. To answer to your question, we have no

7 addressed that issue, we have not come out with an

8 position on that matter. I'm not aware that it ha

9 been put to us in a formal fashion. We have in th

10 past offered to manufacturers and others in respons

11 the question, you placed, Jack, interpretations wit

12 respect to our regulations. But when it gets to th

13 states and what the states can do, there is a wid

14 range of law that goes beyond our regulations. 

15 And in many instances in the past we hav

16 not been able to address those because it's a stat

17 issue and we do not have any standard defense on th

18 question. I f the question is put to us, we wil

19 certainly be required to consider it, but what sort o

20 consideration, how we would respond to it would depen

21 upon the nature of the question and the issues a

22 hand. 

23 MODERATOR LANGMEAD: Very useful. 

24 Other comments?' Were there any othe

25 questions for Ed Pollock? He had gone through 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 23
2

3

4

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11

presentation for George. No more questions on those.

Are the major interest groups, does AGA

ARI, GAMA or EEI have anything else to say before w

start on some open discussion on this issue

Everybody happy with where we are.

There were a number of questions on th

sheet, and I'd like to move the first one down 

little bit and talk about identifying all types o

multifunctional residential HVAC appliances now in th

marketplace and how the energy efficiency of eac

appliance type is currently being described.

Ed and George both basically describ

most of those products. Is there anything more to sa

on that point?

Mike?

MR. McCABE: Michael McCabe. This i

getting into an area where I as the Director of th

Office of Codes and Standards am particularl

interested and concerned with. What Ed has described

what George has described essentially a number o

different measures of efficiency.

In a manner of speaking right now we hav

AFUE, we have energy factor in the test procedure, w

have SHBF, we have the COP that's floating around, w

have SEER, EERs , and now enhanced or equivalen

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

11

1 presentation for George. No more questions on those

2 Are the major interest groups, does AGA

3 ARI, GAMA or EEl have anything else to say before w

4 start on some open discussion on this issue

5 Everybody happy with where we are. 

6 There were a number of questions on th

7 sheet, and I'd like to move the first one down 

8 Ii tt1e bit and talk about identifying all types o

9 mul tifunctional residential HVAC appliances now in th

10 marketplace and how the energy efficiency of eac

11 appliance type is currently being described. 

12 Ed and George both basically describe

13 most of those products. Is there anything more to sa

14 on that pOint? 

15 Mike? 

16 MR. McCABE: Michael McCabe. This i

17 getting into an area where I as the Director of th

18 Office of Codes and Standards am particularl

19 interested and concerned with. What Ed has described

20 what George has described essentially a number o

21 different measures of efficiency. 

22 In a manner of speaking right now we hav

23 AFUE, we have energy factor in the test procedure, w

24 have SHBF, we have the COP that's floating around, w

25 have SEER, EERs, and now enhanced or equivalen

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11

values. And as we have these variety of product

going into the market, Richard Sweetser had mentione

about -- products later this afternoon, engine driven

And a concern which I have is are we going to end u

with such an array of efficiency descriptors back t

the consumer we do not provide any valuabl

information.

When I look at the Hydrotech 2000 and it' 

attempt to over-simplify things in describing, an

I'll make some apologies beforehand, that it did no

succeed in the marketplace some could argue becaus

consumers didn't understand the product, because th

utilities and the demand-side management programs wer

every strong when that product came out, that the DO

measures that we offered in the waiver were such tha

one could say that we failed in providing a meaningfu

measure of efficiency for the market.

Whether or not that market, individua

consumers , are looking at fact sheets, directories

talking to contractors, that market is utilities an

the rebate programs , what have you, that maybe w

failed by coming up with values that from a

engineering perspective, I think in this group we hav

very few people who are not engineers, I with a

engineering degree tend to follow my micrometer t

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

11

1 values. And as we have these variety of product

2 going into the market, Richard Sweetser had mentione

3 about -- products later this afternoon, engine driven

4 And a concern which I have is are we going to end u

5 with such an array of efficiency descriptors back t

6 the consumer we do not provide any valuabl

7 information. 

8 When I look at the Hydrotech 2000 and it'

9 attempt to over-simplify things in describing, an

10 I'll make some apologies beforehand, that it did no

11 succeed in the marketplace some could argue becaus

12 consumers didn't understand the product, because th

13 utili ties and the demand-side management programs wer

14' every strong when that product came out, that the DO

15 measures that we offered in the waiver were such tha

16 one could say that we failed in providing a meaningfu

17 measure of efficiency for the market. 

18 Whether or not that market, indi vidua

19 consumers, are looking at fact sheets, directories

20 talking to contractors, that market is utilities an

21 the rebate programs, what have you, that maybe w

22 failed by coming up with values that from a

23 engineering perspective, I think in this group we hav

24 very few people who are not engineers, I with a

25 engineering degree tend to follow my micrometer t

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

4

6

7

8

10

,11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11

measure the thickness of a pillow. I think in thi

case, a yardstick in some cases is all that'

necessary. And it may be that we have gotten t

caught up with what is the precise measure withou

really understanding or appreciating what will b

meaningful to the market and what will help bring th

product, some of these new advance designs into th

product and promote their sales.

Because one of the major parts of ou

responsibilities for the Department is to promot

energy efficiency and reduce reductions in energ

consumption. And some of these new and excitin

products that are coming out, we cannot come up wit

something to help market them, help the electri

utilities, help the 'gas utilities market for th

manufacturers. We failed, and I hope that we can pu

the micrometers away and really look at what needs t

be done and work with that in the back of your mind

as well.

MODERATOR LANGMEAD: Anybody want t

respond at all to Mike on that, or add something?

Yes?

MR. MARRAN: John Marran, Energy Kinetics

I came to a meeting in 1985 in which we discussed th

combined cycle systems. And we were going to come u

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

11

1 measure the thickness of a pillow. I think in thi

2 case, a yardstick in some cases is all that

3 necessary. And it may be that we have gotten t

4 caught up with what is the precise measure withou

5 really understanding or appreciating what will b

6 meaningful to the market and what will help bring th

7 product, some of these new advance designs into th

8 product and promote their sales. 

9 Because one of the maj or parts of ou

10 responsibili ties for the Department is to promo

.11 eoergy efficiency and reduce reductions in energ

12 consumption. And some of these new and excitin

13 products that are coming out, we cannot come up wit

.14 something to help market them, help. the electri

15 utili ties, help the 'gas utili ties market for th

16 manufacturers. We failed, and I hope that we can pu

17 the micrometers away and really look at what needs t

18 be done and work with that in the back of your mind

19 as well. 

20 MODERATOR LANGMEAD: Anybody want t

21 respond at all to Mike on that, or add something? 

22 Yes? 

23 MR. MARRAN: John Marran, Energy Kinetic

24 I came to a meeting in 1985 in which we discussed th

25 combined cycle systems. And we were going to come u

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11

with -- 124 reports, recommendations, efficienc

numbers, and here it is 1995 and we still do not hav

to through the Department of Energy a descriptor tha

allows a manufacturer such as Carrier or myself t

accurately portray the advantages of a combined cycl

system.

And I've got to say it's very difficult t

operate in a world where you are "not in-the system

not recognized, no way to evaluate you," and I've go

to say it's very discouraging. So we came out wit

the combined cycle system in 1980 and we think we d

a super job. And the marketplace where they'r

installed thinks we do a super job, but we can'

publish any efficiency number that is meaningful.

MODERATOR LANGMEAD: We do have, and E

went through the status of ASHRAE 137 and the AR

standard air conditioning and heat pump equipmen

including a -- of water heating devices, and the

there is ASHRAE standard 124 that covers the furnac

boiler, fossil fuel furnace boiler water heater. I

there a deficiency in those standards that doesn'

cover the products?

Dave?

MR. LEWIS: Dave Lewis, Lennox. Lenno

Industries feels very comfortable with both ASHRAE 12

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

11

1 with 124 reports, recommendations, efficienc

2 numbers, and here it is 1995 and we still do not hav

3 to through the Department of Energy a descriptor tha

4 allows a manufacturer such as Carrier or myself t

5 accurately portray the advantages of a combined cycl

6 system. 

7 And I've got to say it's very difficult t

8 operate in a world where you are "not in the system

9 not recognized, no way to evaluate you," and I've go

10 to say it's very discouraging. So we came out wit

11 the combined cycle system in 1980 and we think we d

12 a super job. And the marketplace where they'r

13 installed thinks we do a super job, but we can

14 publish any efficiency number that is meaningful. 

15 MODERATOR LANGMEAD: We do have, and E

16 went through the status of ASHRAE 137 and the AR

17 standard air conditioning and heat pump equipmen

18 including a -- of water heating devices, and the

19 there is ASHRAE st.andard 124 that covers the furnac

20 boiler, fossil fuel furnace boiler water heater. I

21 there a deficiency in those standards that doesn

22 cover the products? 

23 Dave? 

24 MR. LEWIS: Dave Lewis, Lennox. Lenno

25 Industries feels very comfortable with both ASHRAE 12

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

4

5

6

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11

and 137, feels they are adequate . And that we shoul

follow with that the professional end of our industry

has put together . I think what we see there is fair

and pretty easy to apply.

MR. KALISCH : Bert Kalisch , AGA. I don'

think there ' s any doubt that'the underlying technica

substance is there to justify these differen

descriptors . But once again it sounds as though th

conversation is heading, back to cost and what happen

out in the marketplace . Apparently there is n

'descriptors for the multifunction appliances there to

compete against the separate systems, and we need t

get back to cost because that is going to be th

common denominator among the operation of all these

appliances. That's certainly something that th

consumer understands , and I think that we should focu

on how to get a cost number out there that will allo

that type of comparison.

MODERATOR LANGMEAD : Don't let me pu

words in your mouth , but are you saying that with th

use of 137 , the ARI standard for heat pumps includin

-- water heating devices, and in 124 you've got

basis to come up with cost numbers. And if that wa

promoted and recognized and you could work toward th

process of DOE adopting those standards at some time

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

11

1 and 137, feels they are adequate. And that we shoul

2 follow with that the professional end of our industr

3 has put together. I think what we see there is fai

4 and pretty easy to apply. 

5 MR. KALISCH: Bert Kalisch, AGA. I don

6 think there's any doubt that the underlying technica

7 substance is there to justify these differen

8 descriptors. But once again it sounds as though th

9 conversation is heading'back to cost and what happen

10 out in the marketplace. Apparently there is n

11 descriptors for the multifunction appliances there t

12 compete against the separate systems, and we need t

13 get back to cost because that is going to be th

14 common denominator among the operation of all thes

15 appliances. , That's certainly something that th

16 consumer understands, and I think that we should focu

17 on how to get a cost number out there that will allow 

18 that type of comparison. 

19 MODERATOR LANGMEAD: Don't let me pu

20 words in your mouth, but are you saying that with th

21 use of 137, the ARI standard for heat pumps includin

22 -- water heating devices, and in 124 you've got 

23 basis to come up with cost numbers. And if that wa

24 promoted and recognized and you could work toward th

25 process of DOE adopting those standards at some time

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N,W, 

WASHINGTON. D,C, 20005 (202) 23
1

1

3

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

But you can get the cost numbers.

Dan?

MR. DEMPSEY: Dan Dempsey, Carrier. A

far as I know 124 does not provide the means 

determine annual operating cost.

MODERATOR LANGMEAD: Okay.

MR. RANFONE: 137?

MODERATOR LANGMEAD: Is it 137Z?

MR. POLLOCK: No, it's 124. Does 137 -

MR. RANFONE: No.

MR. POLLOCK: -- yes --

MR. RANFONE: Pardon?

MR. POLLOCK: Yes, a project of NIST. -

137.

MR. RANFONE: It does have a procedure fo

estimating operating cost?

MR. POLLOCK: Yes.

MR. RANFONE: 124 does not.

MODERATOR LANGMEAD: Joe, is there 

reason why 124 doesn't cover, do you have any histor

on why 124 doesn't cover method of getting th

operating cost?

MR. PIETSCH: If you know what th

equivalent AFUE and equivalent energy factor is for 

particular product, you could use the water heatin

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

11

1 But you can get the cost numbers. 

2 Dan? 

3 MR. DEMPSEY: Dan Dempsey, Carrier. A

4 far as I know 124 does not provide the means t

5 determine annual operating cost. 

6 MODERATOR LANGMEAD: Okay. 

7 MR. RANFONE: 137? 

8 MODERATOR LANGMEAD: Is it 137Z? 

9 MR. POLLOCK: No, it's 124. Does 137 

10 MR. RANFONE: No. 

11 MR. POLLOCK: -- yes 

12 MR. RANFONE: Pardon? 

13 MR. POLLOCK: Yes, a project of NIST. 

14 137. 

15 MR. RANFONE: It does have a procedure f

16 estimating operating cost? 

17 MR. POLLOCK: Yes. 

18 MR. RANFONE: 124 does not. 

19 MODERATOR LANGMEAD: Joe, is there 

20 reason why 124 doesn't cover, do you have any histo

21 on why 124 doesn't cover method of getting t

22 operating cost? 

23 MR. PIETSCH: If you know what t

24 equivalent AFUE and equivalent energy factor is for 

25 particular product, you could use the water heati

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 
1

2

3

5

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11

procedure for calculating annual. energy costs and us

the furnace procedure for calculating annual energ

cost. So there was no need to duplicate tha

particular procedure in a national standard.

It could have been put in there, but i

would have to be duplicating exactly what was in, yo

know, existing procedures.

MODERATOR LANGMEAD: Dan, do you want t

respond?

MR. DEMPSEY: That's true on a nationa

average basis, but you go back to the definition o

primary function. I mean DOE region four, a wate

heater that's large enough to heat heating space, th

space heating cost would probably be four to fiv

times the water heating cost. So it's not somethin

that can be just literally extracted and extrapolate

to other regions of the country.

MR. PIETSCH: But that's considered 

shortcoming that the -- brought up. The electri

standard was written quite a few years ago, it wa

completed five years ago, but was written ten year

ago.

MODERATOR LANGMEAD: Am I hearing som

kind of kind of universal agreement that in th

revision process of 124 we should encourage that grou

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

11

1 procedure for calculating annual energy costs and us

2 the furnace procedure for calculating annual energ

3 cost. So there was no need to duplicate tha

4 particular procedure in a national standard. 

5 It could have been put in there, but i

6 would have to be duplicating exactly what was in, yo

7 know, existing procedures. 

8 MODERATOR LANGMEAD: Dan, do you want t

9 respond? 

10 MR. DEMPSEY: That's true on a nationa

11 average basis, but you go back to the definition o

12 primary function. I mean DOE region four, a wate

13 heater that's large enough to heat heating space, th

14 space heating cost would probably be four to fiv

15 times the water heating cost. So it's not somethin

16 that can be just literally extracted and extrapolate

17 to other regions of the country. 

18 MR. PIETSCH: But that's considered 

19 shortcoming that the brought up. The electri

20 standard was written quite a few years ago, it w

21 completed five years ago, but was written ten year

22 ago. 

23 MODERATOR LANGMEAD: Am I hearing som

24 kind of kind of universal agreement that in th

25 revision process of 124 we should encourage that grou

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

2

4

5

6

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12

to look at methods of getting back to annual operatin

cost and getting down the specific application an

location?

MR. PIETSCH: I think that should be a

individual concern and they can address that.

MODERATOR LANGMEAD: I was just trying t

raise if there is concern in this audience. In th

end we're going to ask for people to, if you want t

supplement any of the things that are said here

please feel free to do so in writing. We're ju

trying to get to where we have no objection in thi

room.

Frank?

MR. STANONIK: Frank Stanonik with GAMA

One of the questions on the agenda outline here is, i

there a need to develope a simple way to combine th

ratings for different functions of combined product

in such a way that they can be compared to singl

function products. And I think you heard th

discussions earlier from George Kelly and others tha

that presents a challenge simply because how yo

choose to allocate your savings can be somewha

arbitrary. And in fact I think in any way. how you d

it, it' s somewhat arbitrary.

And because of that, I think what you wer

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 23444333 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

12

1 to look at methods of getting back to annual operatin

2 cost and getting down the specific application an

3 location? 

4 MR. PIETSCH: I think that should be a

5 individual concern and they can address that. 

6 MODERATOR LANGMEAD: I was just trying t

7 raise if there is concern in this audience. In th

8 end we're going to ask for people to, if you want t

9 supplement any of the things that are said here

10 please feel free to do so in writing. We're jus

11 trying to get to where we have no objection in thi

12 room. 

13 Frank? 

. 14 MR. STANONIK: Frank Stanonik with GAMA 

15 One of the questions on the agenda outline here is, i

16 there a need to develope a simple way to combine th

17 ratings for different functions of combined produc

18 in such a way that they can be compared to singl

19 function products. And I think you heard th

20 discussions earlier from George Kelly and others tha

21 that presents a challenge simply because how yo

22 choose to allocate your savings can be somewh

23 arbi trary. And in fact I think in any way. how you d

24 it, it's somewhat arbitrary. 

25 And because of that, I think what you we

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

12

saying, Jack, that perhaps the agreeable approach

would be to come up with method or methods where yo

could get to a annual cost of operation, in which cas

you don't have to worry about separate efficiencies o

separate functions, but the bottom line which is wha

is it going to cost the consumer on an annual basis t

run this combined appliance, doing all its jobs, o

what's it going to cost this consumer to run a

separate water heater, a separate furnace, a separat

boiler or whatever.

To me there is a desirable simplicity t

in fact try and go in direction of when you get to th

point of comparing combined appliances with other

things rather than try and manipulative effectiv

efficiencies or what have you, it should be jus

looking at the cost of operation.

MODERATOR LANGMEAD: Dave Lewis?

MR. LEWIS: Dave Lewis, Lennox. We fee

like the ASHRAE process is'the process that needs t

be used. It gives the opportunity, unlike a meetin

of this sort, for specific issues to be addressed an

dug into. It's real difficult to try to catch thi

issue in a U-shaped table, and the kind of discussio

that we're having because there is a lot of aspects t

25 11 it.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

12

1 saying, Jack, that perhaps the· agreeable approac

2 wou~d be to come up with method or methods where yo

3 cou~d get to a annual cost of operation, in which cas

4 you don't have to worry about separate efficiencies o

5 separate functions, but the bottom line which is wha

6 is it going to cost the consumer on an annual basis t

7 run this combined appliance, doing all its jobs, o

-8 what's it going to cost this consumer to run 

9 separate water heater, a separate furnace, a separat

10 boi~er or whatever. 

11 To me there is a desirable simplicity t

12 in fact try and go in direction of when you get to th

13 point of comparing combined appliances with othe

14 things rather than try and manipulative effectiv

15 efficiencies or what have you, it should be jus

16 looking at the cost of operation. 

17 MODERATOR LANGMEAD: Dave Lewis? 

18 MR. LEWIS: Dave Lewis, Lennox. We fee

19 like the ASHRAE process is the process that needs t

20 be used. It gives the opportunity, unlike a meetin

21 of this sort, for specific issues to be addressed an

22 dug into. It's real difficult to try to catch thi

23 issue in a U-shaped table, and the kind of discussio

24 that we're having because there is a lot of aspects t

25 it. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 23
1

2

4

6

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12

I guess we would encourage the effor

being put into ASHRAE and supporting ASHRAE in th

development and further enhancement even of th

standards as they exist. We basically believe tha

there is adequate information available through 12

and 137 to come up to an consumer making a goo

decision. But there is still that unique aspect o

where the residence is, how many people are there. I

it's anything like my home, how many teenagers are i

the home as far as how much hot water is used. I mea

there are a lot of very specific issues that need t

be looked at that can only be looked at as th

consumer uses the product.

MODERATOR LANGMEAD: Agreed. And I think

Dave, and what Frank said, about the only way you'r

ever going to get back there in comparing agains

different product types is not with differen

descriptors but with dollars or cost at the site. 

think it's the only simple way to get there.

Other questions?

Frank brought up, he came into the poin

of if there was need to develope a single way t

compare ratings, that's why I left that down becaus

I thought that would fall out of the other discussion

(202) 234-4433

The last question on the sheet was use o

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

12

1 I guess we would encourage the effor

2 being put into ASHRAE and supporting ASHRAE in th

3 development and further enhancement even of th

4 standards as they exist. We basically believe tha

5 there is adequate information available through 12

6 and 137 to come up to an consumer making a goo

7 decision. But there is still that unique aspect o

8 where the residence is, how many people are there. I

9 it's anything like my home, how many teenagers are i

10 the home as far as how much hot water is used. I mea

11 there are a lot of very specific issues that need t

12 be looked at that can only be looked at as th

13 consumer uses the product. 

·14 MODERATOR LANGMEAD: Agreed. And I think

15 Dave, and what Frank said, about the only way you'r

16 ever going to get .back there in comparing agains

17 different product types is not with differen

18 descriptors but with dollars or cost at the site. 

19 think it's the only simple way to get there. 

20 Other questions? 

21 Frank brought up, he came into the poin

22 of if there was need to develope a single way t

23 compare ratings, that's why I left that down becaus

24 I thought that would fallout of the other discussion

25 The last question on the sheet was use o

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

2

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

separate descriptors for each energy source used by a

appliance. Would consumers have adequate means t

calculate an annual operating cost. I think if w

base that, if the ASHRAE procedures are looked at, yo

can get there, and at the present time we don't hav

it and people have said they'd like DOE to use tha

ASHRAE process.

Are there other comments or something tha

anybody else wants to add on this whole theory o

multifunction appliances, or is there anything tha

anybody from DOE wants to raise and get a response to

Now, with that, unless somebody ha

something else to add, it's a good time to break fo

lunch. It's 11:58. Is everybody happy on breakin

for lunch with that point? Lunch, and we'll be bac

here, I think we're planning to be back here at 1:30

is that correct?

(Whereupon , at 12:00 p.m., the proceedin

in the above entitled matter were adjourned t

reconvene this same day at 1:14 p.m.)

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

12

1 separate descriptors for each energy source used by a

2 appliance. Would consumers have adequate means t

3 calculate an annual operating cost. I think if w

4 base that, if the ASHRAE procedures are looked at, yo

5 can get there, and at the present time we don't hav

6 it and people have said they'd like DOE to use tha

7 ASHRAE process. 

8 Are there other comments or something tha

9 anybody else wants to add on this whole theory o

10 multifunction appliances, or is there anything th

11 anybody from DOE wants to raise and get a response to

12 Now, with that, unless somebody h

13 something else to add, it's a good time to break fo

14 lunch. It's 11:58. Is everybody happy on breakin

15 for lunch with that point? Lunch, and we'll be ba

16 here, I think we're planning to be back here at 1:3

17 is that correct? 

18 (Whereupon, at 12:00 p.m., the proceedin

19 in the above entitled matter were adjourned 

20 reconvene this same day at 1:14 p.m.) 

21 

22 

23 

24 

25 

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 
12

A-F-T-E-R-N-0-0-N S-E-S-S-I-0-N

2

3

4

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1:14 p.m

MODERATOR LANGMEAD: Okay, I guess we're

ready to reconvene. We've been through the subject of

energy efficiency descriptors that we might have tim

to come back to again this afternoon . We've gone

through multifunction appliances.- I hope everybody

had a good relaxed lunch.

At this time we'd like to start into the

subject of multi-fuel heat pumps. And to kick tha

off Frank Jakob has a little briefing on the ANS

Z21.40.4 standard, and we'll start off with that and

then get into some open discussion.

Frank?

MR. JAKOB: Can I be heard in the back

Frank Jakob, Batelle. This is a picture that for m

describes the situation that we enter into beyond just

multi-fuel appliances like we talked about thi

morning, gas furnaces'that consume electricity, bu

these higher level multi-fuel appliances, gas hea

pumps that use less gas but more electricity an

proportionately that changes.

And what this is, along the bottom axis

is gas in therms, and out there , there are ga

furnaces that consume so much gas, and this is for 

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON . D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

12

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

2 1:14 p.m

3 MODERATOR LANGMEAD: Okay, I guess we'r

4 ready to reconvene. We've been through the subject o

5 energy efficiency descriptors that we might have tim

6 to come back to again this afternoon. We've gon

7 through multifunction appliances.- I hope everybod

8 had a good relaxed lunch. 

9 At this time we'd like to start into th

10 subject of multi-fuel heat pumps. And to kick tha

11 off Frank Jakob has a little briefing on the ANS

12 Z2l.40.4 standard, and we'll start off with that an

13 then get into some open discussion. 

14 Frank? 

15 MR. JAKOB: Can I be heard in the back

16 Frank Jakob, Batelle. This is a picture that for m

17 describes the situation that we enter into beyond jus

18 multi-fuel appliances like we talked about thi

19 morning, gas furnaces that consume electricity, bu

20 these higher level multi - fuel appliances, gas hea

21 pumps that use less gas but more electricity an

22 proportionately that changes. 

23 And what this is, along the bottom axis

24 is gas in therms, and out there, there are ga

25 furnaces that consume so much gas, and this is for 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 23
1

4

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12

standard 36,000 BTU per hour heating load, a house

that has this characteristic. And combination systems

do both the heating and the water heating functions,

so they consume a little more gas. And they're

slightly off the axis. here because this vertical axis

is the amount of electric the appliance consumes.

And along this axis we've got air

conditioners that consume exclusively electricity

heat pumps, electric furnace. And the color coding i

such that the purple appliances are heating

appliances. It should be the bluish appliances are

exclusively cooling appliances. We've got gas ai

conditions over here that consume a significant amoun

gas and some electricity. We have air

conditioners, electric air conditions, over here that

consume exclusively electricity.

The hatching means that there ar

standards for those appliances. There are efficienc

.standards for air conditions. There are efficiency

standards for heat pumps, electric furnaces, gas ai

conditioners. This should be cross hatched here, an

these are gas furnaces.

But then the other appliances in green ar

appliances that perform multifunctions as well usin

increasing amounts of both types of fuel. And fo

(202) 234.4433 -

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

12

1 standard 36,000 BTU per hour heating load, a hous

2 that has this characteristic. And combination system

3 do both the heating and the water heating functions

4 so they consume a little more gas. And they'r

5 slightly off the axis, here because this vertical axi

6 is the amount o'f electric the appliance consumes. 

7 And along this axis we've got ai

8 conditioners that consume exclusively electricity

9 heat pumps, electric furnace. And the color coding i

10 such that the purple appliances are heatin

11 appliances. It should be the bluish appliances ar

12 exclusively cooling appliances. We've got gas ai

13 condi tions over here that consume a significant amoun

14 of gas and some electricity. We have ai

15 conditioners, electric air conditions, over here tha

16 consume exclusively electricity. 

17 The hatching means that there ar

18 standards for those appliances. There are efficienc

19 .standards for air conditions. There are efficienc

20 standards for heat pumps, electric furnaces, gas ai

21 conditioners. This should be cross hatched here, an

22 these are gas furnaces. 

23 But then the other appliances in green ar

24 appliances that perform multifunctions as well usin

25 increasing amounts of both types of fuel. 

(202) 234-4433 . 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NoW. 

WASHINGTON, D.C, 20005 

And fo

(202) 23
2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12

instance over here is the gas heat pump. It used more

gas than your gas furnace because it's doing both th

cooling and heating function throughout the year,

whereas only the gas furnace does the heating

function.

And it consumes a little bit more

electricity. And then you can conceive of other

systems. Here is where gas furnaces and electric air

conditioners might as a system, if they were going to

be rated in some fashion. Here is where gas furnaces

with heat pumps stand. That is an add-on gas furnac

to a heat pump, it uses less energy than a gas

furnace, otherwise more electricity but less so than

heat pumps in general. And they fall somewhere along

these lines that I've shown, a couple of parallel

lines that indicate dollars per year for operating

cost.

And it seems like if you consider this t

be a lake, you know, where the edge around here is

like the shore, as long as we're on the shore, we're

fine. You know , we're over here on the shore

exclusively electricity, we've got AFUE for electric

furnaces, heat pumps, air conditioners.

We stay down here on the shore or close to

the shore with gas furnaces, gas air conditions, but

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

126 

1 instance over here is the gas heat pump. It used mor

2 gas than your gas furnace because it's doing both the 

3 cooling and heating function throughout the year

4 whereas only the gas furnace does the heating 

5 function. 

6 And it consumes a little bit mor

7 electricity. And then you can concei ve of othe

8 systems. Here is where gas furnaces and electric ai

9 conditioners might as a system, if they were going to 

10 be rated in some fashion. Here is where gas furnace

11 with heat pumps stand. That is an add-on gas furnace 

12 to a heat pump, it uses less energy than a ga

13 furnace, otherwise more electricity but less so than 

14 heat pumps in general. And they fall somewhere along 

15 these lines that I' ye shown, a couple of paralle

16 lines that indicate dollars per year for operating 

17 cost. 

18 And it seems like if you consider this to 

19 be a lake, you know, where the edge around here i

20 like the shore, as long as we're on the shore, we'r

21 fine. You know, we're over here on the shor

22 exclusively electricity, we've got AFUE for electri

23 furnaces, heat pumps, air conditioners. 

24 We stay down here on the shore or close t

25 the shore with gas furnaces, gas air conditions, bu

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 23
2

3

4

5

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12

these new systems came in, combo systems, and the

started confusing the issue. And once you're off th

shore, swimming here in the water, those are a variet

of appliances that are coming out and that's th

situation that this ANSI committee tried to deal wit

when it comes to gas heat pumps.

I'll summarize first. My premise, an

this was affirmed this morning, is that right no

there are very well established procedures for takin

the efficiency of a covered product in calculatin

operating costs. You've heard about that today, th

GAMA directory allows you to calculate operating cost

based on some function of its efficiency, the load an

energy cost. There's a worksheet right in the fron

of the GAMA director that's derived directly from th

test procedure. And -- director, so too. In front o

there, there is a worksheet that allows you calculat

operating cost based on SEER load and energy cost

operating cost based on for heat pump, HSPF load an

energy cost.

And so given that, I'm assuming tha

premise is correct, does anybody object to that

Given those mathematical functions then, they wer

there for inverse functions where you could calculat

efficiency if you know the operating cost. That i

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

12

1 these new systems came in, combo systems, and the

2 started confusing the issue. And once you're off th

3 shore, swimming here in the water, those are a variet

4 of appliances that are coming out and that's th

5 situation that this ANSI committee tried to deal wit

6 when it comes to gas heat pumps. 

7 I'll summarize first. My premise, an

8 this was affirmed this morning, is that right no

9 there are very well established procedures for takin

10 the efficiency of a covered product in calculatin

11 operating costs. You've heard about that today, th

12 GAMA directory allows you to calculate operating cos

13 based on some function of its efficiency, the load an

·14 energy cost. There's a worksheet right in the fron

15 of the GAMA director that's derived directly from th

16 test procedure. And - - director, so too. In front o

17 there, there is a worksheet that allows you calcula

18 operating cost based on SEER load and energy cos

19 operating cost based on for heat pump, HSPF load an

20 energy cost. 

21 And so given that, I'm assuming th

22 premise is correct, does anybody obj ect to tha

23 Given those mathematical functions then, they we

24 there for inverse functions where you could calcula

25 efficiency if you know the operating cost. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 

That 

(202) 2
12

1

2

4

6

7

10

11

12

13

14

15

16

17

18

19

20

21

22

'23

24

25

given those equations on the previous table, there i

a simple mathematical, well not so simple, there is 

mathematical relationship that would allow you t

calculate an AFUE if you knew the operating cost, th

load and the energy cost. Same too with the SEER, i

you knew the operating cost, full load and the energ

cost.

Putting that all together what will appea

in the ANSI standard, what has appeared, for gas hea

pump, given an operating cost, and there is a mai

body of the standard that specifies a whole slew o

steady state, cyclic tests, that allow you to develop

operating cost. Then based on the previous premise

how can we find the efficiency of the same size (

that has the same operating cost. That is, given 

gas heat pump that heats, what would be th

efficiency, what would be the AFUE of the same. ga

furnace that has that operating cost? It's a simpl

question and it's easily calculated mathematically.

Given the cooling operating cost for th

gas heat pump, answer the question, what is th

efficiency of a same size electrical air conditione

that has the same operating cost? That's a questio

that I as a consumer want to know.

MR. NASSERI: Frank?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 2344433 WASHINGTON, D.C. 20005 (202) 234-4

EE-DET-94-101 COMMENT 0D

12

1 given those equations on the previous table, there i

2 a simple mathematical, well not so simple, there is 

3 mathematical relationship that would allow you t

4 calculate an AFUE if you knew the operating cost, th

5 load and the energy cost. Same too with the SEER, i

6 you knew the operating cost, full load and the energ

7 cost. 

8 Putting that all together what will appea

9 in the ANSI standard, what has appeared, for gas hea

10 pump, given an operating cost, and there is a mai

11 body of the standard that specifies a whole slew o

12 steady state, cyclic tests, that allow you to develop

13 operating cost. Then based on the previous premise

14 how can we find the efficiency of the same size (x

15 that has the same operating cost. That is, given 

16 gas heat pump that heats, what would be th

17 efficiency, what would be the AFUE of the same ga

18 furnace that has that operating cost? It's a simp

19 question and it's easily calculated mathematically. 

20 Given the cooling operating cost for th

21 gas heat pump, answer the question, what is th

22 efficiency of a same size electrical air conditione

23 that has the same operating cost? That's a questio

24 that I as a consumer want to know. 

25 

(202) 234-4433 

MR. NASSERI: Frank? 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NoW. 

WASHINGTON. D.C. 20005 (202) 2
12

1

4

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

MR. JAKOB: Yes.

MR. NASSERI: Is this a

MR. JAKOB: No.

function?

MR. NASSERI: -- simple. I mean --

MR. JAKOB: I've got a computer.

To give you some history and background o

the standard, in 1984 there is a committee -- well,

the committee process started, and in 1984 to '86 th

need for the standard developed. That is there was a

renewed interest in developing gas heat pumps, 

number of companies, there were seven to ten researc

projects under way at the time.

And so given that need for the standard

what's called the Z21.40 subcommittee, it's a ANSI

subcommittee that deals with gas appliances. it

covers gas heat pumps, fuel cells, gas heat pum

related equipment, a variety of equipment that'

currently not covered under the auspices of some othe

committee. And they started working on the process

started developing various drafts and then that draf

went out for public review and comment here in lat

1992. The comments were assimilated by the committe

and the final assessment of those comments went to th

parent committee. And that's when the committee

process ends.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

12

1 MR. JAKOB: Yes. \ i 1'\-: {\.i· 

2 MR. NASSERI: Is this a 1\ 

-- function? 

3 MR. JAKOB: No. 

4 MR. NASSERI: simple. I mean 

5 MR. JAKOB: I've got a computer. 

6 To give you some history and background o

7 the standard, in 1984 there is a committee -- well

8 the committee process started, and in 1984 to '86 th

9 need for the standard developed. That is there was 

10 renewed interest in developing gas heat pumps, 

11 number of companies, there were seven to ten researc

12 projects under way at the time. 

13 And so given that need for the standard

14 what's called the Z21.40 subcommittee, it's a ANS

15 subcommi ttee that deals with gas appliances. I

16 covers gas heat pumps, fuel cells, gas heat pum

17 related equipment, a variety of equipment that'

18 currently not covered under the auspices of some othe

19 committee. And they started working on the process

20 started developing various drafts and then that draf

21 went out for public review and comment here in lat

22 1992. The comments were assimilated by the committe

23 and the final assessment of those comments went to th

24 parent committee. And that's when the committe

25 process ends. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 23
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

'16

17

18

19

20

21

22

23

24

25

13

The committee consists of a number o

technical experts dealing with that area. And the

it's passed off to ANSI, which is the American

National Standards Institute that goes on to confirm

that their process of affirming standards is in place

And then it goes through a public review comment

period. Those comments again are assimilated

Finally the board of standards has, to review tha

process at which time it becomes an ASHRAE approved

or an ANSI, I'm sorry, ANSI approved process.

Going back in history there was a startin

point. Back in the '60s there was an existing

standard, Z21.40.2, gas engine driven summer ai

conditioning appliances, that had covered some

appliances that were around at that time.

In 1972 that came up for renewal, a

standards regularly do, at that point in time that

product was no longer available and so it wa

withdrawn, but the standard did contain a section o

how to measure the capacity of an appliance.' And s

that was already established.

In 1984 gas engine heat pump developmen

was revived. There were GRI projects, DOE projects

as well as private industry.

1986 and following Z21.40 committe

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 2344433 WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

13

1 The committee consists of a number o

2 technical experts dealing with that area. And the

3 it's passed off to ANSI, which is the America

4 National Standards Institute that goes on to confirm 

5 that their process of affirming standards is in place

6 And then it goes through a public review commen

7 period. Those comments again are assimilated

8 Finally the board of standards has. to review tha

9 process at which time it becomes an AS~RAE approved

10 or an ANSI, I'm sorry, ANSI approved process. 

11 GOing back in history there was a startin

12 point. Back in the ' 60s there was an existin

13 standard, Z21.40.2, gas engine driven summer ai

14 conditioning appliances, that had covered som

15 appliances that were around at that time. 

16 In 1972 that came up for renewal, a

17 standards regularly do, at that point in time tha

18 product was no longer available and so it wa

19 withdrawn, but the standard did contain a section o

20 how to measure the capacity of an appliance. And s

21 that was already established. 

22 In 1984 gas engine heat pump developmen

23 was revived. There were GRI projects, DOE projects

24 as well as private industry. 

25 

(202) 234-4433 

1986 and following Z21.40 committe

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON. D.C. 20005 (202) 2
13

1

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

established what they called the fuel gas heat pum

working group. And that working group met twice 

year usually in concert with ASHRAE meetings becaus

many of the members were associated with ASHRA

members and that made it convenient. It also gave u

a public forum in which to hold those meetings.

Between 1988 and 1991 the working grou

evolved the draft standard. They started with th

previous one. They took a capacity section an

expanded that also to measure steady state efficiency

And then they took the efficiency section and expande

that to measure cycling efficiency. We saw that firs

efficiency was a needed part of the standard, an

second there had been developments in other appliance

that had led to duty cycle efficiency and so tha

aspect was added to the work.

During the course of the work what wa

that standard was divided into two separate standards

Safety and operational performance that's now calle

Z21.40.2,, and the second section that was th

capacity and efficiency performance. That had becom

a large enough document and separate enough from th

safety aspects that really it didn't deserve to b

covered by the same standard.

This item was then the capacity an

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

13

1 established what they called the fuel gas heat pum

2 working group. And that working group met twice 

3 year usually in concert with ASHRAE meetings becaus

4 many of the members were associated with ASHRA

5 members and that made it convenient. It also gave u

6 a public forum in which to hold those meetings. 

7 Between 1988 and 1991 the working grou

8 evolved the draft standard. They started with th

9 . previous one. They took a capaci ty section an

10 expanded that also to measure steady state efficiency

11 And then they took the efficiency section and expande

12 that to measure cycling efficiency. We saw that firs

13 efficiency was a needed part of the standard, an

14 second there had been developments in other appliance

15 that had led to duty cycle efficiency and so tha

16 aspect was added to the work. 

17 During the course of the work what w

18 that standard was divided into two separate standards

19 Safety and operational performance that's now calle

20 Z21.40.2" and the second section that was th

21 capacity and efficiency performance. That had becom

22 a large enough document and separate enough from th

23 safety aspects that really it didn't deserve to b

24 covered by the same standard. 

25 

(202) 234-4433 

This item was then the capacity an

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
2

3

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

efficiency performance standard evolved. It starte

as a single ANSI standard during the course o

committee deliberations. It was separated int

separate capacity and efficiency standards. And the

based on discussions of the committee it ended u

being a main standard and with an appendix which is a

ANSI proof way of providing accompanying material

with any standard. It's now called Z21.40.4, and I'v

got a copy of it here, if anyone cares to look at i

during one of the breaks.

That standard went out for public revie

in 1992. The Z21.40 subcommittee worked on th

comments. They found that the main body receive

nothing but affirmative comments and yet the appendi

received mixed comments. And so what the committe

decided to do was to parallel those two sections

That is they broke out the main -body separate from th

appendix. The main body in '93 was approved by th

parent Z21 committee. It was forwarded to ANSI. I

'94 it has its public review by ANSI, was approved b

the board of standards review, and was publishe

earlier this year.

There is some future work associated wi

harmonizing that standard with the Canadian standard

as well as work associated with dovetailing it wit

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

13

1 efficiency performance standard evolved. It starte

2 as a single ANSI standard during the course o

3 committee deliberations. It was separated int

4 separate capacity and efficiency standards. And the

5 based on discussions of the committee it ended u

6 being a main standard and with an appendix which is a

7 ANSI proof way of providing accompanying materia

8 with any standard. It's now called Z2l.40.4, and I'v

9 got a copy of it here, if anyone cares to look at i

10 during one of the breaks. 

11 That standard went out for public revie

12 in 1992. The Z2l.40 subcommittee worked on th

13 comments. They found that the main body receive

14 nothing but affirmative comments and yet the append

15 received mixed comments. And so what the committ

16 decided to do was to parallel those two section

17 That is they broke out the main· body separate from th

18 appendix. The main body in '93 was approved by th

19 parent Z2l committee. It was forwarded to ANSI. 

20 '94 it has its public review by ANSI, was approved b

21 the board of standards review, and was publishe

22 earlier this year. 

23 There is some future work associated wi

24 harmonizing that standard with the Canadian standard

25 as well as work associated with dovetailing it wi

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
2

3

6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

13

what is now an ASHRAE standard 40. That was the mai

body.

The appendix, the comments were attende

to by the Z21 committee . It was passed on and tha

took about two years worth or work, iterating wit

various commentators.

1995 we passed it along, the committe

passed it along. It was approved by Z21 and it ha

been forwarded to ANSI where it sits right now in it

future. There is a public review that's going to b

held. Following that there is comment resolutio

that's required before it's ultimate dovetailing wit

the existing main body of the standard.

MR. WETHJE : Frank, could you jus

clarify, is it out for public review now, did you say

MR. JAKOB: It's in ANSI's hands righ

now, and they are scheduling public review.

The scope of the standard is testing an

rating gas fired heat pumps for space conditionin

performance . And space directly, I divide direct

heating and cooling the air, or space conditionin

indirectly by producing either a heated or chille

fluid that then goes to some heat exchanges tha

provide the conditioning.

(202) 2344433.

Scope covers factory made spac

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON . D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

13

~ 

1 what is now an ASHRAE standard 40. That was the ma

2 body. 

3 The appendix, the comments were attende

4 to by th~ Z21 committee. It was passed on and tha

5 took about two years worth or work, iterating wit

6 various commentators. 

7 1995 we passed it along, the committe

8 passed it along. It was approved by z21 and it ha

9 been forwarded to ANSI where it sits right now in it

10 future. There is a public review that's going to b

11 held. Following that there is comment resolutio

12 that's required before it's ultimate dovetailing wit

13 the existing main body of the standard. 

14 MR. WETHJE: Frank, could you ju

15 clarify, is it out for public review now, did you say

16 MR. JAKOB: It's in ANSI's hands righ

17 now, and they are scheduling public review. 

18 The scope of the standard is testing an

19 rating gas fired heat pumps for space conditionin

20 performance. And sp~ce directly, I divide directl

21 heating and cooling the air, or space conditionin

22 indirectly by producing either a heated or chille

23 fluid that then goes to some heat exchanges th

24 provide the conditioning. 

25 

(202) 234-4433 

Scope covers factory 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON.. D.C. 20005 

made spa

(202) 2
1

2

3

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

13

conditioning unitary heat pumps that use gas as th

primary fuel. For example engine driven, absorption o

desiccant systems. Various controls are allowed i

the standard, single level, on-off control, discret

level, multilevel control, or continuous variabl

control. It can provide either heating or a coolin

function or both. The appliance may also includ

other functions such as water heating. All aspects o

which we touched on this morning.

In addition the heat source or sink may b

either outdoor air, groundwater, or a closed loo

water loop.

The main body of the standard consists o

these sections which are pretty routine titles for an

testing standard that will specify the testin

required, the conditions, what procedures to follow

steady state tests that are required, seasonal tes

and calculations, annual performance, references, an

sample calculations to help a user.

The basic approach is the same as tha

used with electric heat pump standards. That is t

measure steady state cycling parameters, and then t

use a temperature bin analysis to aggregate thos

results into a seasonable number.

From the main body of the standard come

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

13

1 conditioning unitary heat pumps that use gas as th

2 primary fuel. For example engine driven, absorption o

3 desiccant systems. Various controls are allowed i

4 the standard, single level, on-off control, discret

5 level, multilevel control, or continuous variabl

6 control. It can provide either heating or a coolin

7 function or both. The appliance may also includ

8 other functions such as water heating. All aspects o

9 which we touched on this morning. 

10 In addition the heat source or sink may b

11 ei ther outdoor air, groundwater, or a closed loo

12 water loop . 

. 13 The main body of the standard consists o

14 these sections which are pretty routine titles for an

15 testing standard that will specify the testin

16 required, the conditions, what procedures to follow

17 steady state tests that are required, seasonal tes

18 and calculations, annual performance, references, an

19 sample calculations to help a user. 

20 The basic approach is the same as tha

21 used with electric heat pump standards. That is t

22 measure steady state cycling parameters, and then t

23 use a temperature bin analysis to aggregate thos

24 results into a seasonable number. 

25 From the main body of the standard com

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 23
1

2

4

6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

the bottom line performance to get the spac

conditioning load, to get the electric energy consume

by the appliance, and the gas energy consumed by th

appliance, the bottom line numbers. And again, as 

indicated during the public review, that receive

nothing but favorable comment.

The appendix, it's contents went on to sa

how to quantify its steady state cooling efficiency o

heating efficiency, and then how to quantify thei

seasonal efficiencies, annual costs, and how to exten

that also to commercial appliances.

The basic approach, as I mentioned at th

beginning of my presentation, was to choose som

normalizing parameter, it could be cost, it could b

the local energy content, or some global energ

content measure, but it provides not the specificatio

of what to do, but the mathematical formulations o

having decided what you the analyst want to do, ho

will you go about calculating them, and then determin

the efficiency that some other appliance would have 

have such that the value of the normalizing paramet

is the same . For instance with the gas heat pump

it's operating cost is such that a furnace would nee

to have 125 percent AFUE in order to have the sam

operating cost.

(202) 2344433,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

13

1 the bottom line performance to get the spac

2 condi tioning load, to get the electric energy consume

3 by the appliance, and the gas energy consumed by th

4 appliance, the bottom line numbers. And again, as 

5 indicated during the public review, that receive

6 nothing but favorable comment. 

7 The appendix, it's contents went on to sa

8 how to quantify its steady state cooling efficiency o

9 heating efficiency, and then how to quantify the

10 seasonal efficiencies, annual costs, and how to exten

11 that also to commercial appliances. 

12 The basic approach, as I mentioned at th

13 beginning of my presentation, was to choose som

14 normalizing parameter, it could be cost, it could b

15 the local energy content, or some global energ

16 content measure, but it provides not the specificatio

17 of what to do, but the mathematical formulations 

18 having decided what you the analyst want to do, ho

19 will you go about calculating them, and then determin

20 the efficiency that some other appliance would have 

21 have such that the value of the normalizing paramet

22 is the same. For instance with .the gas heat pum

23 it's operating cost is such that a furnace would ne

24 to have 125 percent AFUE in order to have the sam

25 operating cost. 

(202) 234-4433. 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

13

The bottom line performance then is th

AFUE of a furnace having the same operating cost, o

the SEER of an air conditioner that has that sam

operating cost. The appendix provides kind of 

mathematical formulation which you otherwise might d

by hand by crawling through the various directories

finding the correctly sized appliance, and finding n

that has the same operating cost.

That's it in a nutshell, Jack.

MODERATOR LANGMEAD: Thank you.

Are there questions for Frank?

Frank, that must have been extremel

clear. Everybody understood everything.

Are there any statements that any one o

the major associations, ARI, GAMA, AGA, EEI, want t

make before we start into point by point discussions

Nothing, Larry?

Nothing, Frank?

Nothing, Don?

Sue Hill, nothing? You're not there.

Matt?,

We have a series of questions fo

discussion items. The first one is basically, hav

all types of multi-fuel heat pumps been identified

It seemed to me that Frank covered that in hi

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

13

1 The bottom line performance then is th

2 AFUE of a furnace having the same operating cost, o

3 the SEER of an air conditioner that has that sam

4 operating cost. The appendix provides kind of 

5 mathematical formulation which you otherwise might d

6 by hand by crawling through the various directories

7 finding the correctly sized appliance, and finding n

8 that has the same operating cost. 

9 That's it in a nutshell, Jack. 

10 MODERATOR LANGMEAD: Thank you. 

11 Are there questions for Frank? 

12 Frank, that must have been extreme

13 clear. Everybody understood everything. 

·14 Are there any statements that anyone o

15 the major associations, ARI, GAMA, AGA, EEl, want t

16 make before we start into point by point discussion

17 Nothing, Larry? 

18 Nothing, Frank? 

19 Nothing, Don? 

20 Sue Hill, nothing? You're not there. 

21 Matt? 

22 We have a series of questions f

23 discussion items. The first one is basically, ha

24 all types of multi-fuel heat pumps been identified

25 It seemed to me that Frank covered that in h

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 
1

2

4

5

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

13

remarks.

Does anybody have anything to add to thos

lists?

The principal subject seems to be the ga

engine driven heat pump that's currently entering th

market. So nobody has anything add to identifyin

different types of products.

We've gone through the status and scope o

the revisions of ANSI standard 40. Nobody has an

comments. I assume everybody understands that proces

and they know that that standard, it will be announce

for public review in and ANSI report shortly and s

everybody will know somewhat of the time and they ca

get. a copy and comment on that.

Yes?

MR. RYAN: Yes, just a quick comment o

standard 40. Bill Ryan with GRI. I'm also the chai

of the ASHRAE SPC40 committee. What we are in th

process of doing is basically working toward a join

action between ASHRAE and the Z21 group so that w

will have as a future standard a Z21/ASHRAE standar

covering this type of equipment. The comments fro

the committee, the ASHRAE committee, that has reviewe

the Z21 standard thus far has been very positive an

they are in general very pleased with the work tha

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

13

1 remarks. 

2 Does anybody have anything to add to thos

3 lists? 

4 The principal subject seems to be the ga

5 engine driven heat pump that's currently entering th

6 market. So nobody has anything add to identifyin

7 different types of products. 

8 We've gone through the status and scope o

9 the revisions of ANSI standard 40. Nobody has an

10 comments. I assume everybody understands that proces

11 and they know that that standard, it will be announce

12 for public review in and ANSI report shortly and s

13 everybody will know somewhat of the time and they ca

14 get, a copy and comment on that. 

15 Yes? 

16 MR. RYAN: Yes, just a quick comment o

17 standard 40. Bill Ryan with GRI. I'm also the cha

18 of the ASHRAE SPC40 committee. What we are in th

19 process of doing is basically working toward a join

20 action between ASHRAE and the Z2l group so that w

21 will have as a future standard a Z21/ASHRAE standar

22 covering this type of equipment. The comments fro

23 the committee, the ASHRAE committee, that has reviewe

24 the Z21 standard thus far has been very positive an

25 they are in general very pleased with the work tha

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
2

3

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

13

Z21 did including taking this all the way to a

equivalent AFUE, an equivalent SEER type number tha

allows people, customers, whatever, obviously to mak

comparisons and also to avoid coming up with ye

another energy descriptor that has to be explained t

the industry.

We are looking at cross listing wit

ASHRAE probably on the republication of the Z2

standard which would not be until I think 1998. S

basically ASHRAE's role on this 'has been far and awa

secondary to that of the Z21 committee that really di

the development.

MODERATOR LANGMEAD: It's heartening t

see the two organizations working together.

MR. RYAN: So far.

MODERATOR LANGMEAD : Any other comments o

either the ASHRAE or the Z21.40.4 process?

The next issue , item, on the agenda wa

statutory and marketplace limitations. And I thin

it's important to take those one at a time becaus

they are distinctively different. On the statutor

limitations I have a question of whether the sale

volume of gas fired heat pumps at this point in tim

qualifies it to be a NEACA covered product.

Does anybody know the answer to that?

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234.4433 WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

13

1 Z21 did including taking this all the way to a

2 equivalent AFUE, an equivalent SEER type number tha

3 allows people, customers, whatever, obviously to mak

4 comparisons and also to avoid coming up with ye

5 another energy descriptor that has to be explained t

6 the industry. 

7 We are looking at cross listing wit

8 ASHRAE probably on the republication of the Z2

9 standard which would not be until I think 1998. S

10 basically ASHRAE's role on this has been far and awa

11 secondary to that of the Z21 committee that really di

12 the development. 

13 MODERATOR LANGMEAD: It's heartening t

14 see the two organizations working together. 

15 MR. RYAN: So far. 

16 MODERATOR LANGMEAD: Any other comments o

17 either the ASHRAE or the Z21.40.4 process? 

18 The next issue, item, on the agenda wa

19 statutory and marketplace limitations. And I thin

20 it's important to take those one at a time becaus

21 they are distinctively different. On the statutor

22 limi tations I have a question of whether the sale

23 volume of gas fired heat pumps at this point in tim

24 qualifies it to be a NEACA covered product. 

25 Does anybody know the answer to that? 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

4

5

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

13

There is limitations in the volume of th

product before you start on the NEACA legislation, and

I can't remember what those limits are, but I don'

think you have enough product there yet, right?

It was how much energy consumed when th

product is in use?

MR. ADAMS: Carl Adams here. The only

thing that comes to mind on that is there is a limi

in there, 100 kilowatt hours per year, as I recall

for considering coverage of new products.

MODERATOR LANGMEAD: That's what I wa

making reference to?

MR. ADAMS: So it's an energy consumption

MODERATOR LANGMEAD: Energy consumption

And I don't know whether that's the energy consumptio

level or not with this product, you know. I thin

we've got a good process going where people can get t

cost of operation and make a comparison, and ther

should be, and there is, work going on that when th

time comes DOE will have a test procedure you ca

probably adopt. And I think we all ought be lookin

in that direction.

Any other. comments on that though

process?

2511 It would seem to me, and I'm looking fo

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

13

1 There is limitations in the volume of th

2 product before you start on the NEACA legislation, an

3 I can't remember what those limits are, but I don

4 think you have enough product there yet, right? 

5 It was how much energy consumed when th

6 product is in use? 

7 MR. ADAMS: Car 1 Adams here. The onl

8 thing that comes to mind on that is there is a limi

9 in there, 100 kilowatt hours per year, as I recall

10 for considering coverage of new products. 

11 MODERATOR LANGMEAD: That's what I wa

12 making reference to? 

13 MR. ADAMS: So it's an energy consumption

14 MODERATOR LANGMEAD: Energy consumption

15 And I don't know whether that's the energy consumptio

16 level or not with this product, you know. I thin

17 we've got a good process going where people can get t

18 cost of operation and make a comparison, and ther

19 should be, and there is, work going on that when th

20 time comes DOE will have a test procedure you ca

21 probably adopt. And I think we all ought be lookin

22 in that direction. 

23 Any other comments on that though

24 process? 

25 It would seem to me, and I'm looking fo

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 23
14

1

2

3

4

5

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

input from other people, that there are no marketplace

limitations to the use of the draft ANSI standard that

will go out for review, and certainly anything like

that would want to be changed as it becomes a joint

ANSI/ASHRAE standard. So there will be means to

compare the operating costs to other costs of heatin

and cooling equipment that could perform the sam

subject, perform the same job in a given size.

And with that there in place, I wouldn't

think there would be any hold up to the entry of thi

kind of a product into the marketplace provided peopl

can get over the first cost and maintenance cost an

insulation cost issues.

Is that generally agreed-?

The next issue was use of separate

descriptors for each energy source used with th

appliance. The work has been going on between ASHRA

and the ANSI committee has come back to, no

descriptors, but to cost of operation.

Is that in the correct direction wit

everybody?

I hear no objection.

The next question down there is, woul

consumers have adequate means to calculate annua

operating cost of these appliances? And we get into

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, O.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

14

1 input from other people, that there are no marketplac

2 limi tations to the use of the draft ANSI standard tha

3 will go out for review, and certainly anything lik

4 that would want to be changed as it becomes a jOin

5 ANSI/ASHRAE standard. So there will be means to 

6 compare the operating costs to other costs of heatin

7 and cooling equipment that could perform the sam

8 subject, perform the same job in a given size. 

9 And with that there in place, I wouldn

10 think there would be any hold up to the entry of thi

11 kind of a product into the marketplace provided peopl

12 can get over the first cost and maintenance cost an

13 insulation cost issues. 

14 Is that generally agreed? 

15 The next issue was use of separat

16 descriptors for each energy source used with th

17 appliance. The work has been going on between ASHRA

18 and the ANSI committee has come back to, no

19 descriptors, but to cost of operation. 

20 Is that in the correct direction wit

21 everybody? 

22 I hear no objection. 

23 The next question down there is, woul

24 consumers have adequate means to calculate annua

25 operating cost of these appliances? And we get into

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 23
2

3

4

5

7

8

9

10

11

12

13

-14

15

16

17

18

19

20

21

22

23

24

25

1

would consumers, I guess I want to add the othe

question, who is the typical consumer of this type o

equipment, is it generally a household or is i

generally a builder or is it generally going into 

more large structures? I think we've got a differen

mix of consumers of this product than we do with, sa

residential size furnaces.

And if they would have means, if we've al

said we've got standards and people can calculate th

cost of operation, it would seem to me that there ar

plenty of means there for the manufacturer and energ

suppliers to make the cost of operation known on 

reasonable basis that could be compared to othe

heating, air conditioning and water heating equipmen

that would be doing that same function.

Am I making a fair summary of that again?

We're going awful fast today , and I wan

to leave it open for anybody else to say anything

And we ' ve got an issue that we've got -- we've move

ahead and we seem to have everything in place to allo

the -product in the market and everybody is i

agreement that about the best way to correlate it wit

other products is through the use of responsibl

produced cost of operation numbers on the same'basis

Yes?

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

14

1 would consumers, I guess I want to add the othe

2 question, who is tha typical consumer of this type o

3 equipment, is it generally a household or is i

4 generally a builder or is it generally going into 

5 more large structures? I think we've got a differen

6 mix of consumers of this product than we do with, sa

7 residential size furnaces. 

8 And if they would have means, if we've al

9 said we've got standards and people can calculate th

10 cost of operation, it would seem to me that there ar

11 plenty of means there for the manufacturer and energ

12 suppliers to make the cost of operation known on 

13 reasonable basis that could be compared to othe

-14 heating, air conditioning and water heating equipme

15 that would be doing that same function. 

16 Am I making a fair summary of that again? 

17 We're going awful fast today, and I wa

18 to leave it open for anybody else to say anything

19 And we've got an issue that we've got -- we've mov

20 ahead and we seem to have everything in place to allo

21 the product in the market and everybody is i

22 agreement that about the best way to correlate it wi

23 other products is through the use of responsib

24 produced cost of operation numbers on the same basi

25 Yes? 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

14

MR. ADAMS: Carl Adams, DOE. Just to sor

of relate this product back to some of the earlie

discussions that we were having this morning, goin

back to Frank's I guess it was his first viewgraph o

this afternoon, showing where the gas fired heat pum

fell in the gas and electrical energy consumption

It's sort of following on a trend, I suppose, tha

earlier today we were talking about gas furnace

before induced draft furnaces, yes they used som

electricity, then along came induced draft furnace

and you had furnaces that began to use mor

electricity, and it became a more significant item.

And I guess it was at that point that in th

efficiency standards process that DOE began looking a

the energy descriptor as a way , to capture thi

electrical consumption and to possibly include it i

the efficiency standards to perhaps gain som

efficiency improvements , if there were cost effectiv

ones to be made there. Which is sort of where thi

process started and it's certainly grown well beyon

that.

And I guess to respond to a comment tha

Larry Wethje made earlier, DOE's intent in doing thi

was to come up with a descriptor for furnaces an

boilers for whatever reasons that we seemed to hav

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

14

1 MR. ADAMS: Carl Adams, DOE. Just to sor

2 of relate this product back to some of the earlie

3 discussions that we were having this morning, goin

4 back to Frank's I guess it was his first viewgraph o

5 this afternoon, showing where the gas fired heat pum

6 fell in the gas and electrical energy consumption

7 It's sort of following on a trend, I suppose, tha

8 earlier today we were talking about gas furnace

9 before induced draft furnaces, yes they used som

10 electricity, then along came induced draft furnace

11 and you had furnaces that began to use mo

12 electricity, and it became a more significant item. 

13 And I guess it was at that point that in th

14 efficiency standards process that DOE began looking a

15 the energy descriptor as a way to capture thi

16 electrical consumption and to possibly include it i

17 the efficiency standards to perhaps gain som

18 efficiency improvements, if there were cost effectiv

19 ones to be made there. Which is sort of where thi

20 process started and it's certainly grown well beyon

21 that. 

22 And I guess to respond to a comment th

23 Larry Wethje made earlier, DOE's intent in doing th

24 was to come up with a descriptor for furnaces an

25 boilers for whatever reasons that we seemed to hav

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
1

3

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

14

balled up our words in the reopening notice tha

perhaps implied that we were considering it for all

products. We were not. It was tied to furnaces an

boilers.

But we're seeing this trend towards now

possibly the gas fired heat pump which will use

proportionately even more electricity getting reall

to a mix of electricity and with gas.

And I guess I haven't followed the ANSI

test procedure quite detailed enough to know, but if

there was a comparison made to an AFUE -- that thi

gas fired heat pump you would have to have a furnac

with an AFUE of (x) in order to be comparable, is that

taking into account the electrical consumption sinc

the AFUE of the furnace does not, is this really a

comparison, a fair comparison if the gas fired hea

pump is proportionately using more electricity an

neither of them is taking into account the electrica

consumption. Are we providing apples to apple

comparison if we were to adopt that.

And I think trying to put things on th

same basis I'm hearing is good, then we don't want t

get separate for each little family of products, 

different descriptor so that people cannot compare ga

furnaces to electric heat pumps to gas fired hea

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

14

1 balled up our words in the reopening notice tha

2 perhaps implied that we were considering it for al

3 products. We were not. It was tied to furnaces an

4 boilers. 

5 But we're seeing this trend towards now 

6 possibly the gas fired heat pump which will us

7 proportionately even more electricity getting reall

8 to a mix of electricity and with gas. 

9 And I guess I haven't followed the ANS

10 test procedure quite detailed enough to know, but i

11 there was a comparison made to an AFUE that thi

12 gas fired heat pump you would have to have a furnac

13 with an AFUE of (x) in order to be comparable, is tha

14 taking into account the electrica'l consumption sinc

15 the AFUE of the furnace does not, is this really 

16 comparison, a fair comparison if the gas fired hea

17 pump is proportionately using more electricity an

18 neither of them is taking into account the electrica

19 consumption. Are we providing apples to apple

20 comparison if we were to adopt that. 

21 And I think trying to put things on th

22 same basis I'm hearing is good, then we don't want t

23 get separate for each little family of products, 

24 different descriptor so that people cannot compare ga

25 furnaces to electric heat pumps to gas fired hea

(202) 234-4433 

, NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 23
1

3

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

14

pumps to type one or type two heating appliances.

There's getting to be all these different family of

appliances and how do we compare one to the other, how

do we provide the consumer with that information.

MR. KALISCH: Rick Kalisch from AGA. I

think that you're dancing around the actual deficiency

in the whole system. And that is, - as was pointed ou

earlier, there' s concern that there's all thes

different types of descriptors, how do they relate,

should they relate. But once again the underlyin

common denominator for all of these would be dollars,

and it's the operating cost of the system, whether

it's part electric and part gas, whether it's gas o

whether it's electric. I think dollars is really what

the focus should be.

MODERATOR LANGMEAD: Frank, do you want t

go over your one little slide at the beginning agai

to say where that comparison came from and what yo

did compare?

I think it covered part of your questio

and it ties in with the comment you just made.

MR. JAKOB: Is that the part that --

MODERATOR LANGMEAD: That wasn't the on

I had in mind, but that's all right. It's th

comparison where you said I can go back and pick ou

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 2344433 WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

14

1 pumps to type one or type two heating appliances

2 There's getting to be all these different family o

3 appliances and how do we compare one to the other, how 

4 do we provide the consumer with that information. 

5 MR. KALISCH: Rick Kalisch from AGA. 

6 think that you're dancing around the actual deficienc

7 in the whole system. And that is,-as was pOinted ou

8 earlier, there's concern that there's all thes

9 different types of descriptors, how do they relate

10 should they relate. But once again the underlyin

11 common denominator for all of these would be dollars

12 and it's the operating cost of the system, whethe

13 it's part electric and part gas, whether it's gas o

14 whether it's .electric. I think dollars is really wha

15 the focus should be. 

16 MODERATOR LANGMEAD: Frank, do you want t

17 go over your one little slide at the beginning agai

18 to say where that comparison came from and what yo

19 did compare? 

20 I think it covered part of your questio

21 and it ties in with the comment you just made. 

22 MR. JAKOB: Is that the part that --

23 MODERATOR LANGMEAD: That wasn't the on

24 I had in mind, but that's all right. It's th

25 comparison where you said I can go back and pick ou

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N,W. 

WASHINGTON, D.C. 20005 (202) 23
1

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

14

an AFUE of the heating side and.to get a comparabl

AFUE it would have to be about 125 percent. And Cyru

asked you the question about is that a linea

equation, and you said no. That one. Well, that on

and the next one.

MR. JAKOB: The premise being here that

as Carl pointed out, I did simply these equations fo

the purpose of the presentation. Actually with a

electric heat pump it's far easier since they're 

single energy source. But operating cost is a ver

simple algebraic function of SEER design heating loa

and energy costs.

With a gas furnace there's actually a

extra parameter you need in here. AFUE electrica

consumption load and energy costs in order to full

flesh out that equation. How does that get to th

point of --

MODERATOR LANGMEAD: Well, where it get

to is you go back and make your comparison. Th

comparisons that have been made, and that Frank wa

looking at, are made on the basis of cost, not th

descriptors. And so the cost will take into accoun

the cost of electrical consumption. It doesn't giv

you a descriptor to work with to build a minimu

2511 efficiency, but it gives the consumer and the buye

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

14

1 an AFUE of the heating side and to get a comparabl

2 AFUE it would have to be about 125 percent. And Cyru

3 asked you the question about is that a linea

4 equation, and you said no. That one. Well, that on

5 and the next one. 

6 MR. JAKOB: The premise being here that

7 as Carl pOinted out, I did simply these equations fo

8 the purpose of the presentation. Actually with a

I 

9 electric heat pump it's far easier since they're 

10 single energy source. But operating cost is a ver

11 simple algebraic function of SEER design heating loa

12 and energy costs. 

13 Wi th a gas furnace there's actually a

14 extra parameter you need in here. AFUE electrica

15 consumption load and energy costs in order to full

16 flesh out that equation. How does that get to th

17 point of --

18 MODERATOR LANGMEAD: Well, where it get

19 to is you go back and make your comparison. Th

20 comparisons that have been made, and that Frank w

21 looking at, are made on the basis of cost, not th

22 descriptors. And so the cost will take into accoun

23 the cost of electrical consumption. It doesn't giv

24 you a descriptor to work with to build a minimu

25 efficiency, but it gives the consumer and the buy

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
146

1

2

3

5

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

knowledge and how to compare that with anything else.

And the comparison is truly made on the cost of the

energy to the consumer.

MR. JAKOB: One of the questions in the

list is, should there be separate descriptors for

separate efficiencies. And for instance that could be

done. A gas heat pump can deliver about 125,000 BTUs

of heat for every therm of gas that it consumes. So

there is a measure of efficiency 125,000 BTUs per

therm.

On the electric side it's able to delive

60 BTUs for about every one hour of electricity that

it consumes. And so there is a pair.of numbers based

on the separate energy consumptions that could be used

with BTUs per hour, 16 BTUS per one hour, and 125,000

per therm. But probably just confused a number of

people here and, if we're confused, the American

people are confused.

MODERATOR LANGMEAD: Right over here, yes.

Introduce yourself please?

MR. RIVEST: Does that mean that your SEER

output rating --

MODERATOR LANGMEAD: Would you introduce

yourself?

2511 MR. RIVEST: Michael Rivest - - if you'r

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

146 

1 knowledge and how to compare that with anything else

2 And the comparison is truly made on the cost of the 

3 energy to the consumer. 

4 MR. JAKOB: One of the questions in the 

5 list is, should there be separate descriptors for 

6 separate efficiencies. And for instance that could be 

7 done. A gas heat pump can deliver about 125,000 BTU

8 of heat for every therm of gas that it consumes. So 

9 there is a measure of efficiency 125,000 BTUs pe

10 thermo 

11 On the electric side it's able to delive

12 60 BTUs for about everyone hour of electricity tha

13 it consumes. And so there is a pair.of numbers based 

14 on the separate energy consumptions that could be used 

15 with BTUs per hour, 16 BTUS per one hour, and 125,000 

·16 per thermo But probably just confused a number o

17 people here and, if we're confused, the America

18 people are confused. 

19 MODERATOR LANGMEAD: Right over here, yes

20 Introduce yourself please? 

21 MR. RIVEST: Does that mean that your SEER 

22 output rating --

23 

24 yourself? 

25 

(202) 234-4433 

MODERATOR LANGMEAD: Would you introduc

MR. RIVEST: Michael Rivest -- if you'r

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON. D.C. 20005 (202) 23
1

2

3

4

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

14

starting to do a cost, if you're going from SEER t

low cost and low cost to SEER, costs change with th

SEER rating of your gas --

MODERATOR LANGMEAD: The reporter need t

hear you better. He's recording your voice.

MR. RIVEST: On that, to go from cost

you're going from SEER to the cost, and back, cost t

SEER, for the gas heat pumps, is that correct?

MR. JAKOB: The main profit goes fo

energy cost to SEER. And you're right, cost is i

there in the middle and that would be a number tha

just like--is based on national averages some sort o

technique in order to handle the time variant --

MR. RIVEST: But the SEER rating tha

comes out at the end for the heat pump, so'does tha

mean it's relative to cost, if cost changes, does th

SEER rating change? I guess that's what,I mean.

MR. JAKOB: If the cost changes, the cos

of the gas heat pump changes, the cost of operatio

changes, then the associated rating of anothe

,appliance that has the same operating cost wil

change. The answer is yes.

MODERATOR LANGMEAD: I had anothe

question over here? Yes? Please introduce yoursel

(202) 234-4433

MR. YOUNG: It's Dave Young from Ontari

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

14

1 starting to do a cost, if you're going from SEER t

2 low cost and low cost to SEER, costs change with th

3 SEER rating of your gas -- 

4 MODERATOR LANGMEAD: The reporter need t

5 hear you better .. He's recording your voice. 

6 MR. RIVEST: On that, to go from cos

7 you're going from SEER to the cost, and back, cost t

8 SEER, for the gas heat pumps, is that correct? 

9 MR. JAKOB: The main profit goes fo

10 energy cost to SEER. And you're right, cost is i

11 there in the middle and that would be a number tha

12 just like--is based on national averages some sort o

13 technique in order to handle the time variant --

14 MR. RIVEST: But the SEER rating th

15 comes out at the end for the heat pump, so does th

16 mean it's relative to cost, if cost changes, does th

17 SEER rating change? I guess that's what ,I mean. 

18 MR. JAKOB: If the cost changes, the co

19 of the gas heat pump changes, the cost of operatio

20 changes, then the associated rating of anoth

21 appliance that has the same operating cost wi

22 change. The answer is yes. 

23 MODERATOR LANGMEAD: I had anoth

24 question over here? Yes? Please introduce yoursel

25 

(202) 234-4433 

MR. YOUNG: It's Dave Young from Ontar

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
14

1

2

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Hydro. There was a couple of things in you

presentation that I'm a little bit confused on. 

guess you touched on one of them a bit earlier whe

you drew the analogy between the function that woul

give you the equivalent AFUE or a gas heat pump, an

you used, as an example, 125.

In the case of heat pump function relatin

to AFUE, that must be a strongly dependent upon th

zone that it's done in. And that 125 might be tru

for one geographical -location, but it certainly b

equal to 125 someplace else in the country. And doe

that not lead to a rather difficult to labe

equivalency in terms of AFUE when gas furnace AFUE

are relatively variant with location by geography

But gas heat pump AFUEs are going to vary by say 5

percent.

MR. JAKOB: Relative to gas furnaces

there will be that factor, but the fact that th

bottom line efficiency of a heat pump varies wit

region is already comprehended by the test procedure

and the fact that we have separate regions an

separate bin hours set up for those different region

where things can then be alternatively calculated.

MR. YOUNG: But AFUE is not a number tha

varies by region. I mean people aren't used seeing 

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

14

1 Hydro. There was a couple of things in you

2 presentation that I'm a little bit confused on. 

3 guess you touched on one of them a bit earlier whe

4 you drew the analogy between the function that woul

5 give you the equivalent AFUE or a gas heat pump, an

6 you used, as an example, 125. 

7 In the case of heat pump function relatin

8 to AFUE, that must be a strongly dependent upon th

9 zone that it's done in. And that 125 might be tru

10 for one geographical location, but it certainly b

11 equal to 125 someplace else in the country. And doe

12 that not lead to a rather difficult to labe

13 equivalency in terms of AFUE when gas furnace AFUE

14 are relatively variant with location by geography

15 But gas heat pump AFUEs are going to vary by say 5

16 percent. 

17 MR. JAKOB: Relati ve to gas furnaces

18 there will be that factor, but the fact that th

19 bottom line efficiency of a heat pump varies wi

20 region is already comprehended by the test procedure

21 and the fact that we have separate regions an

22 separate bin hours set up for those different region

23 where things can then be alternatively calculated. 

24 MR. YOUNG: But AFUE is not a number th

25 varies by region. I mean people aren't used seeing 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
14

1

2

3

8

10

11

12

13

.14

15

16

17

18

19

20

21

22

23

24

25

AFUE that would vary by region.

MR. JAKOB: It's not assessed. The AFUE

and' I don' t know if George would ever let us, but it' 

based on a 42 degree outdoor temperature and variou

implications.

MR. KELLY: We looked at different region

of the country. It's fairly insensitive to th

regions.

MR. JAKOB: It's fairly insensitive, bu

there is some functionality I presume.

MR. KELLY: Right, right.

MR. YOUNG: Well, you're dealing wit

something on the one hand that's fairly insensitive i

the case of the gas furnace product versus the he

pump product that it's directly sensitive to. I mea

there is a big .difference between those tw

dimensions.

MR. JAKOB: So a sensitivity analysis tha

would portray the variability with regions would be o

value?

MR. YOUNG: Well, no. In the consumer'

mind the number AFUE bears, is meaningful with respec

to this product in which the number does not chang

with the geographic location. And now you're applyin

it to a product where the number does change wit

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

14

1 AFUE that would vary by region. 

2 MR. JAKOB: It's not assessed. The AFUE

3 and I don't know if George would ever let us, but it'

4 based on a 42 degree outdoor temperature and variou

5 implications. 

6 MR. KELLY: We looked at different region

7 of the country. It's fairly insensitive to th

8 regions. 

9 MR. JAKOB: It's fairly insensitive, bu

10 there is some functionality I presume . 

11 . MR. KELLY: Right, right. 

12 MR. YOUNG: Well, you're dealing wit

13 something on the one hand that's fairly insensi ti ve i

14 the case of the gas furnace product versus the he

15 pump product that it's directly sensitive to. I mea

16 there is a big difference between those tw

17 dimensions. 

18 MR. JAKOB: So a sensitivity analysis tha

19 would portray the variability with regions would be o

20 value? 

21 MR. YOUNG: Well, no. In the consumer

22 mind the number AFUE bears, is meaningful with respe

23 to this product in which the number does not chang

24 wi th the geographic location. And now you're applyin

25 it to a product where the number does change wi

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

1

2

3

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

geographic location.

MR. JAKOB: Joe Pietsch,,do you have 

comment on that?

MR. PIETSCH: I have a comment. Th

Z21.40 standard has provisions that are calculated -

equivalent for all regions of the country, just lik

the electric heat pump does. So it provides 

procedure for developing the heat pump performance i

all climates. Now, if somebody wants to go and set 

standard rating for labeling or something like that

they could select one, and just like the electric hea

pump as selected in region 4. But it does hav

provisions in that standard for all climates t

calculate it by the bin calculation.

MR. JAKOB: The calculation techniques ar

there to allow you to go to any region and use th

local bin to calculate what that AFUE of the othe

appliance has to be.

MODERATOR LANGMEAD: I saw anothe

question over here somewhere. Okay.

Anybody else want to add anything to th

multi-fuel heat pump subject, from DOE, from any plac

else?

(202) 234-4433

Yes?

MR. DOUGHERTY: Brian Dougherty, NIST. 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

15

1 geographic location. 

2 MR. JAKOB: Joe Pietsch,. do you have 

3 comment on that? 

4 MR. PIETSCH: I have a comment. T

5 Z21.40 standard has provisions that are calculated 

6 equivalent for all regions of the country, just lik

7 the electric heat pump does. So it provides 

8 procedure for developing the heat pump performance i

9 all climates. Now, if somebody wants to go and set 

10 standard rating for labeling or something like tha

11 they could select one, and just like the electric he

12 pump . as selected in region 4. But it does hav

13 provisions in that standard for all climates t

14 calculate it by the bin calculation. 

15 MR. JAKOB: The calculation techniques a

16 there to allow you to go to any region and use th

17 local bin to calculate what that AFUE of the oth

18 appliance has to be. 

19 MODERATOR LANGMEAD: I saw anoth

20 question over here somewhere. Okay. 

21 Anybody else want to add anything to th

22 multi-fuel heat pump subject, from DOE, from any pla

23 else? 

24 Yes? 

25 

(202) 234-4433 

MR. DOUGHERTY: Brian Dougherty, NIST. 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NoW. 

WASHINGTON, D.C. 20005 (202) 2
15

1

3

4

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

just want to understand that the application o

conversion factors where you convert gas t

electricity, and electricity to gas, is okay for thi

appliance, and the arguments that were discussed this

morning with regards to the furnace application do not

apply. It seems like there is a little bit of a

inconsistency of not combining them with furnaces an

boilers, but of combing them on --

MR. WETHJE: Well, what's the manner -

Larry Wethje, GRI. What's the manner in which they'r

combined in the appendix.

Frank, I guess I would ask you that. I

that on a site or a strict conversion of 3.4.13 time

,the electrical or on a source basis?

MR. JAKOB:. As Joe pointed out it's not 

standard in terms of a descriptive efficienc

standard, it's a standard in terms of a method o

test. And so the mathematical calculations ar

specified but you, the analyst, would have t

determine what the cost is, be it the local cost, wha

the load is, what the size and criteria are. Al

those are open.

MR. DOUGHERTY: The descriptors used i

the appendix that I have, there is one called sourc

fuel ICER or HSPF, and the other ones are called cost

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

15

1 just want to understand that the application o

2 conversion factors where you convert gas t

3 electricity, and electricity to gas, is okay for thi

4 appliance, and the arguments that were discussed thi

5 morning with regards to the furnace application do no

6 apply. It seems like there is a little bit of a

7 inconsistency of not combining them with furnaces an

8 boilers, but of combing them on --

9 MR. WETHJE: Well, what's the manner -

10 Larry Wethje, GRI. What's the manner in which they'r

11 combined in the appendix. 

12 Frank, I guess I would ask you that. I

13 that on a site or a strict conversion of 3.4.13 time

14 ,the electrical or on a source basis? 

15 MR. JAKOB: As Joe pOinted ou·t it's not 

16 standard in terms of a descriptive efficienc

17 standard, it's a standard in terms of a method o

18 test. And so the mathematical calculations ar

19 specified but you, the analyst, would have t

20 determine what the cost is, be it the local cost, wh

21 the load is, what the size and criteria are. A

22 those are open. 

23 MR. DOUGHERTY: The descriptors used i

24 the appendix that I have, there is one called sourc

25 fuel leER or HSPF, and the other ones are called cos

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW, 

WASHINGTON.,D.C, 20005 (202) 23
2

3

4

5

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

15

SEER, and HSPF, so you use a cost ratio of fuels o

this source fuel ratio to get these equivalent values

MR. WETHJE: Either way. There is som

kind of a "F factor" involved in the conversion o

electric to gas.

MR. DOUGHERTY: Right, right.

MR. JAKOB: It seems-like we're back a

the same place where we were this morning.

MR. WETHJE: Well, hopefully there's som

consistency on all appliances. But maybe there'

reasons why there shouldn't be and that's what I wa

trying to ask.

MODERATOR LANGMEAD: I might suggest tha

that becomes an issue, it seems to me, only if you'r

going to set a minimum standard, and if the compariso

was made by the consumer on a cost at that site, the

that issue kind of goes away. And if you're talkin

about a gas fired heat pump, I guess one of th

broader questions is, would there be a need to gave 

minimum efficiency set on a product that the lea

efficient one is going to be more efficient tha

anything that's on the market at this point in tim

until you get some additional volume.

And the tools to do what you want to d

are sitting here, it's how you're going to use them

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

15

1 SEER, and HSPF, so you use a cost ratio of fuels o

2 this source fuel ratio to get these equivalent values

3 MR. WETHJE: Either way. There is som

4 kind of a ifF factor" involved in the conversion o

5 electric to gas. 

6 MR. DOUGHERTY: Right, right. 

7 MR. JAKOB: It seems- like we're back a

8 the same place where we werethi~ morning. 

9 MR. WETHJE: Well, hopefully there's som

10 consistency on all appliances. But maybe there

11 reasons why there shouldn't be and that's what I w

12 trying to ask. 

13 MODERATOR LANGMEAD: I might suggest tha

14 that becomes an issue, it seems to me, only if you'r

15 going to set a minimum standard, and if the compariso

16 was made by the consumer on a cost at that site, the

17 that issue kind of goes away. And if you're talkin

18 about a gas fired heat pump, I guess one of th

19 broader questions is, would there be a need to gave 

20 minimum efficiency set on a product that the lea

21 efficient one is going to be more efficient tha

22 anything that's on the market at this point in tim

23 until you get some additional volume. 

24 And the tools to do what you want to 

25 are sitting here, it's how you're going to use them

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
3

4

5

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

15

And so nobody has been saying, I think the F facto

issue doesn 't come up if you compare it on a cos

basis.

MR. WETHJE: No, but what I just said wa

the method of comparing it on a cost basis was to us

an F factor multiplier in the process. It's the onl

way to get a cost factor --

MODERATOR LANGMEAD: Let's --

MR. WETHJE: -- that's what's in th

appendix, Frank.

MR. KALISCH: Bert Kalisch from AGA. On

of the objections that we have to the furnace rul

that was commented on this past March was th

electrical consumption of a fossil fuel fired furnac

was treated differently than the electrica

consumption of an electric furnace. So we. didn'

object to the F factor but in the application of th

F factor.

MODERATOR LANGMEAD: Yes?

MR. DOUGHERTY: I wanted to ask too, Bria

Dougherty, NIST, whether or not there is because th

test procedure itself is structured like the tes

procedures -- heat pump, whether or not the descripto

of comparison in going after an equivalent descripto

2511 should be more HSPF than AFUE.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

15

1 And so nobody has been saying, I think the F facto

2 issue doesn't come up if you compare it on a cos

3 basis. 

4 MR. WETHJE: No, but what I just said wa

5 ~he method of comparing it on a cost basis was to us

6 an F factor multiplier in the process. It's the onl

7 way to get a cost factor --

8 MODERATOR LANGMEAD: Let's--

9 MR. WETHJE: that's what's in th

10 appendix, Frank. 

11 MR. KALISCH: Bert Kalisch from AGA. On

12 of the objections that we have to the furnace rul

13 that was commented on this past March was th

14 electrical consumption of a fossil fuel fired furnac

15 was treated differently than the electrica

16 consumption of an electric furnace. So we, didn

17 object to the ~ factor but in the application of th

18 F factor. 

19 MODERATOR LANGMEAD: Yes? 

20 MR. DOUGHERTY: I wanted to ask too, Bria

21 Dougherty, NIST, whether or not there is because th

22 test procedure itself is structured like the tes

23 procedures - - heat pump, whether or not the descripto

24 of comparison in going after an equivalent descripto

25 should be more HSPF than AFUE. 

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW, 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

5

6

7

8

9

10

11

12

13

-14

15

16

17

18

19

20

21

22

23

24

25

1

I understand obviously if you use gas i

would be best to probably go after AFUE, but the res

procedure is structured to the all electric equipment

so the question is, if you*do that, why don't you hav

for heat pumps use AFUE as --was a reason why they di

the HSPF for heat pumps and AFUE for boilers an

furnaces, and I assume that was driven by trying t

make a comparison to most like appliances.

And if we change the test procedure, yo

don't know what effects you have as far as th

relative ranking. Now, that you've put them out i

the field, do you know what an HSPF, if you divide i

by 3.413 to get the dimensionless quantities, woul

the difference between the AFUE method, test method

and the heat pump test method then correlate to wha

is actually seen in the field. I don't know tha

anyone has ever looked at that to my knowledge.

So I question whether or not th

comparison should be made , if made at all, to HSPF o

the heating side as opposed to AFUE?

MODERATOR LANGMEAD: Anybody else want t

comment on this issue at this time?

Yes.

MR. SWEETSER : Rich Sweetser, American Ga

Cooling Center. The ANSI Z21.40 standard allows fo

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

15

1 I understand obviously if you use gas i

2 would be best to probably go after AFUE, but the res

3 procedure is structured to the all electric equipmen

4 so the question is, if you' do that, why don't you hav

5 for heat pumps use AFUE as --was a reason why they di

6 the HSPF for heat' pumps and AFUE for boilers an

7 furnaces, and I assume that was driven by trying t

8 make a comparison to most like appliances. 

9 And if we change the test procedure, yo

10 don't know what effects you have as far as th

11 relative ranking. Now, that you've put them out i

12 the field, do you know what an HSPF, if you divide i

13 by 3.413 to get the dimensionless quantities, wou

·14 the difference between the AFUE method, test method

15 and the heat pump test method then correlate to wh

16 is actually seen in the field. I don't know tha

17 anyone has ever looked at that to my knowledge. 

18 So I question whether or not· th

19 comparison should be made, if made at all, to HSPF o

20 the heating side as opposed to AFUE? 

21 MODERATOR LANGMEAD: Anybody else want t

22 comment on this issue at this time? 

23 Yes. 

24 MR. SWEETSER: Rich Sweetser, American G

25 Cooling Center. The ANSI Z21.40 standard allows f

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NoW. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

15

both comparisons. And, you know, in part, we do hav

to go back to again our customer we're trying t

provide information to and that customer I would thin

we would want to be able to make comparisons from 

gas heat pump, electric pump to electric furnace or 

gas furnace in some way, shape or form. So tha

really ought to be our guide. Maybe we've put 

little bit too much information because of the weathe

sensitivity. Hopefully the standard allows for enoug

in the appendix, enough input to get it right.

MODERATOR LANGMEAD: George?

MR. KELLY: I believe Brian's point is th

test procedures are slightly different for furnaces -

MODERATOR LANGMEAD: A little louder

George.

MR. KELLY: - - for furnaces if you'r

outdoor or isolating combustion, we have jacke

losses. And if you're indoor you have infiltratio

losses that are imposed upon the house. You don

have that in the heat pump area.

MR. THRASHER : That's true.

MODERATOR LANGMEAD: Yes?

MR. RYAN : Bill Ryan, GRI. There are som

simplifications here in that we have -- I believ

uniformity --

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

15

1 both comparisons. And, you know, in part, we do hav

2 to go back to again our customer we're trying t

3 provide information to and that customer I would thin

4 we would want to be able to make comparisons from 

5 gas heat pump, electric pump to electric furnace or 

6 gas furnace in some way, shape or form. So tha

7 really ought to be our guide. Maybe we've put 

8 Ii ttle bit too much information because of the weath

9 sensi ti vi ty. Hopefully the standard allows for enoug

10 in the appendix, enough input to get it right. 

11 MODERATOR LANGMEAD: George? 

12 MR. KELLY: I believe Brian's point is th

13 test procedures are slightly different for furnaces -

14 MODERATOR LANGMEAD: A little loude

15 George. 

16 MR. KELLY: -- for furnaces if you'

17 outdoor or isolating combustion, we have jack

18 losses. And if you're indoor you have infiltratio

19 losses that are imposed upon the house. You don

20 have that in the heat pump area. 

21 MR. THRASHER: That's true. 

22 MODERATOR LANGMEAD: Yes? 

23 MR. RYAN: Bill Ryan, GRI. There are som

24 simplifications here in that we have -- I believ

25 uniformity --

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
15

MODERATOR LANGMEAD: Bill, a little loude

3

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

please.

MR. RYAN: -- assume that the gas hea

pump is located outdoors and that does simplify an

concerns about jacket losses and ICS.

Other than that, one of the chie

interests in using equivalency or equivalent HSPF i

that you introduce the energy costs into th

calculation to come up with operating costs, but yo

don't end up with dollars per year in the end. Yo

then back the same energy costs back out so that yo

can come up with the equivalent numbers.

It makes it a bit more independent o

operating cost, but there is obviously a ratio betwee

fuel source prices that remains within th

calculation, and that's right there in the arithmetic

But at least you do end up with a number that doesn

have to come down to dollars per year for Wichita

Kansas. It's something a little more general and

little more specific than a piece of equipment as i

rolls off the assembly line. There is,-however, tha

one last ratio that remains within it that's basical

impossible to eliminate.

MODERATOR LANGMEAD: Frank?

MR. STANONIK: Just a different question

NEAP R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

15

1 MODERATOR LANGMEAD: Bill, a little loude

2 please. 

3 MR. RYAN: -- assume that the gas he

4 pump is located outdoors and that does simplify an

5 concerns about jacket losses and IeS. 

6 Other than that, one of the chie

7 interests in using equivalency or equivalent HSPF i

8 that you introduce the energy costs into th

9 calculation to corne up with operating costs, but yo

10 don't end up with dollars per year in the end. Y

11 then back the same energy costs back out so that yo

12 can corne up with the equivalent numbers. 

13 It makes ita bit more independent o

14 operating cost, but theJ;e is obviously a ratio betwee

15 fuel source prices that remains within th

16 calculation, and that's right there in the arithmetic

17 But at least you do end up with a number that doesn

18 have to corne down to dollars per year for Wichit

19 Kansas. It's something a little more general and 

20 little more specific than a piece of equipment as i

21 rolls off the assembly line. There is, ·however, th

22 one last ratio that remains wi thin it that's basical

23 impossible to eliminate. 

24 

25 

(202) 234-4433 

MODERATOR LANGMEAD: Frank? 

MR. STANONIK: Just a different questio

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE fSLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

15

and I apologize if it throws things off here, but i

the A40 standard, I mean we had this discussion thi

morning where you have the standard gas furnace wher

your primary fuel is gas and then you have what I'm

going to call auxiliary electrical consumption, mainl

your blower motor, okay. Now, on a gas fired heat

pump the unit itself still has primarily ga

consumption and has some associated electri

consumption, you still have the auxiliary electrica

consumption of what is now an air handling unit, okay.

Where does that get entered into the equation, if, yo

will, in the A40 standard, the electrical consumption

that occurs from your motor to turn the blower to mov

the air through the house?

MR. JAKOB: It's set up to test as a spli

system or as just a condenser only with som

assumptions. But it's a split system and it consist

of an indoor and an outdoor unit. The outdoor uni

has fans and pumps associated with it. The indoo

unit has a blower associated with it. And th

standard specifies that you make a total electrica

input to that entire system. And so the tota

electrical energy is comprehended out of it.

MR. STANONIK: I asked my question poorl

I guess. Under the current procedures for AFUE tha

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON. D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

15

1 and I apologize if it throws things off here, but i

2 the A40 standard, I mean we had this discussion thi

3 morning where you have the standard gas furnace wher

4 your primary fuel is gas and then you have what I'm 

5 going to call auxiliary electrical consumption, mainl

6 your blower motor, okay. Now, on a gas fired hea

7 pump the unit itself still has primarily ga

8 consumption and has some associated electri

9 consumption, you still have the auxiliary electrica

10 consumption of what is now an air handling unit, okay

11 Where does that get entered into the equation, if yo

12 will, in the A40 standard, the electrical consumptio

13 that occurs from your motor to turn the blower to mov

14 the air through the house? 

15 MR. JAKOB: It's set up to test as a spli

16 system or as just a condenser only with som

17 assumptions. But it's a split system and it consist

18 of an indoor and an outdoor unit. The outdoor uni

19 has fans and pumps associated with it. The indoo

20 uni t has a blower associated with it. And th

21 standard specifies that you make a total electrica

22 input to that entire system. And so the tota

23 electrical energy is comprehended out of it. 

24 MR. STANONIK: I asked my question poorl

25 I guess. Under the current procedures for AFUE tha

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW, 

WASHINGTON. D,C, 20005 (202) 23
1

2

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

15

electrical assumption that occurs at your blower is i

fact -- at for AFUE. You were in the course of you

discussion saying well, you could work backwards an

say that with my gas fired heat pump, if I had 

furnace it would have to have an AFUE of 125 o

something, okay. In that process does A40 -- does th

Z21.40 standard also discount , the electrica

consumption that occurred at the blower or is it no

all rolled in. And I don't know because I'm not tha

familiar with the standard.

MR. DOUGHERTY: The question is does th

equivalent AFUE reflect the --

MR. STANONIK: I guess that would be it

yes.

MR. JAKOB: As currently configured, 

believe it does.

MR. DOUGHERTY: So it's different from th

regular AFUE we currently have?

MR. JAKOB: If you consider gas only, the

the AFUE would be much higher.

MODERATOR LANGMEAD: I would think tha

needs to be looked at.

Larry?

MR. WETHJE: Larry Wethje, ARI. I ,gues

I am unclear as to why -- approved Z21.40.4 standar

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

15

1 electrical assumption that occurs· at your blower is i

2 fact -- at for AFUE. You were in the course of you

3 discussion saying well, you could work backwards an

4 say that with my gas fired heat pump, if I had 

5 furnace it would have to have an AFUE of 125 o

6 something, okay. In that process does A40 -- does th

7 Z21.40 standard also discount the electrica

8 consumption that occurred at the blower or is it no

9 all rolled in. And I don't know because I'm not tha

10 familiar with the standard. 

11 MR. DOUGHERTY: The question is does th

12 equivalent AFUE reflect the 

13 MR. STANONIK: I guess that would be it

14 yes. 

15 MR. JAKOB: As currently configured, 

16 believe it does. 

17 MR. DOUGHERTY: So it's different from th

18 regular AFUE we currently have? 

19 MR. JAKOa: If you consider gas only, the

20 the AFUE would be mUch higher. 

21 MODERATOR LANGMEAD: I would think th

22 needs to be looked at. 

23 Larry? 

24 MR. WETHJE: Larry Wethje, ARl. 19ue

25 I am unclear as to why -- approved Z21.40.4 standa

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

4

5

7

9

10

11

12

13

.14

15

16

17

18

19

20

21

22

23

24

25

15

allows you to determine a seasonable efficiency on the

gas usage and a seasonable efficiency on the

electrical usage, correct?

MR. JAKOB: Not efficiency. Seasonal

total in terms of BTUs and kilowatt hours.

MR. WETHJE: Okay. So why can't you then

just simply take those numbers and multiply them time

your local utility rates separately to get your annua

operating cost of the gas and your annual operatin

cost of the electric and get a total annual operating

cost of the appliance and compare that to the annual

operating cost of a furnace from the GAMA director or

an electric heat pump from the ARI directory? It

seems to me that's the most straight forward and

simplest way to compare the products.

MR. KELLY: Well, you're picking an A

factor.

MR. JAKOB: Comparing operating cost i

one of the chapters in the appendix that allows you t

do that.

MR. WETHJE : Using a F factor multiplier

MR. JAKOB: No, using the individua

operating costs.

MODERATOR LANGMEAD: And that's what 

thought I was saying earlier, Larry. I guess i

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

159 

1 allows you to determine a seasonable efficiency on the 

2 gas usage and a seasonable efficiency on the 

3 electrical usage, correct? 

4 MR. JAKOB: Not efficiency. Seasona

5 total in terms of BTUs and kilowatt hours. 

6 MR. WETHJE: Okay. So why can't you then 

7 just simply take those numbers and multiply them time

8 your local utility rates separately to get your annua

9 operating cost of the gas and your annual operatin

10 cost of the electric and get a total annual operatin

11 cost of the appliance and compare that to the annua

12 operating cost of a furnace from the GAMA director o

13 an electric heat pump from the ARI directory? I

14 seems to me that's the most straight forward an

15 simplest way to compare the products. 

16 MR. KELLY: Well, you're picking an A

17 factor. 

18 MR. JAKOB: Comparing operating cost i

19 one of the chapters in the appendix that allows you t

20 do that. 

21 MR. WETHJE: Using a F factor multiplier

22 MR. JAKOB: No, using the indi vidua

23 operating costs. 

24 

25 

MODERATOR LANGMEAD: And that's what 

thought I was saying earlier, Larry. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 

I guess i

(202) 23
1

1

3

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

didn't come out that way.

Dan's got a point?

MR. DEMPSEY: Dan Dempsey. The only poin

though I think is that in a procedure you can compar

to a specific model that's listed in a director, bu

you couldn't compare it to a hypothetical 90 AFU

furnace because not all 90 AFUE furnaces have the sam

electrical consumption.

MODERATOR LANGMEAD : And so you have to g

back to cost at the site that you're talking about.

MR. DEMPSEY: It's all cost based.

MODERATOR LANGMEAD: Yes?

MR. RYAN: Bill Ryan, GRI. Is what I'

hearing that people see the equivalent HSPF being 

more direct and understandable way of doing it

comparing heat pump and heating to a heat pump --

MODERATOR LANGMEAD: I don't think yo

were hearing that.

MR. RYAN: Okay.

MODERATOR LANGMEAD: But there were som

questions.

MR. RYAN: My concern was there seemed t

be a comparison to a furnace, not what you do with th

electricity. Well, if I go back to an equivalen

HSPF, then I'm going back to an equivalent device tha

(202) 234+1433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 

EE-DET-94-101 COMMENT 0D

16

1 didn't come out that way. 

2 Dan's got a pOint? 

3 MR. DEMPSEY: Dan Dempsey. The only pOi

4 though I think is that in a procedure you can compa

5 to a ~pecific model that's listed in a director, bu

6 you couldn't compare it to a hypothetical 90 AFU

7 furnace because not all 90 AFUE furnaces have the sam

8 electrical consumption. 

9 MODERA TOR LANGMEAD: And so you have to g

10 back to cost at the site that you're talking about

11 MR. DEMPSEY: It's all cost based. 

12 MODERATOR LANGMEAD: Yes? 

13 MR. RYAN: Bill Ryan, GRI. Is what I'

14 hearing that people see the equivalent HSPF being 

15 more direct and understandable way of dOing it

16 comparing heat pump and heating to a heat pump --

17 MODERATOR LANGMEAD: I don't think y

18 were hearing that. 

19 MR. RYAN: Okay. 

20 MODERATOR LANGMEAD: But there were som

21 questions. 

22 MR. RYAN: My concern was there seemed 

23 be a comparison to a furnace, not what you do with th

24 electricity. Well, if I go back to an equivale

25 HSPF, then I'm going back to an equivalent device th

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

16

only uses one energy input and so it's fairly straigh

forward.

MODERATOR LANGMEAD: Charlie Adams?

MR. ADAMS: Charlie Adams, Ducane. 

think to address your problem, perceived problem -- t

expand on what Dan was saying, aren't we really sayin

instead of taking an energy descriptor and calculatin

a cost and then back calculating some other energ

descriptor out of that, what we're really saying i

we're going to compare this unit and this unit

calculate cost and compare the numbers.

So you really can't take the multi-fuel

the gas driven heat pump, gas engine heat pump an

back figure an AFUE and pick up the GAMA directory an

look down the columns until you see that number an

say geez , I want that one. That's not really wha

we're saying. We're saying I want to compare this on

to this one, and this one costs this much and this on

costs that much, and that includes all the electrica

consumptions from all of anything.

It has the multiplier factor in ther

because you're paying 3., whatever it is, times fo

the electrical energy that you're paying for the ga

energy, and in my mind I'm still a site energy kind o

a guy. When I plug it into the wall I'm paying fo

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

16

1 only uses one energy input and so it's fairly straigh

2 forward. 

3 MODERATOR LANGMEAD: Charlie Adams? 

4 MR. ADAMS: Charlie Adams, Ducane. 

5 think to address your problem, perceived problem -- t

6 expand on what Dan was saying, aren't we really sayin

7 instead of taking an energy descriptor and calculatin

8 a cost and then back calculating some other energ

9 descriptor out of that, what we" re really saying i

10 we're going to compare this unit and this unit

11 calculate cost and compare the numbers. 

12 So you really can't take the multi-fue

13 the gas driven heat pump, gas engine heat pump an

14 back figure an AFUE and pick up the GAMA directory an

15 look down the columns until you see that number an

16 say geez, I want that one. That's not really wh

17 we're saying. We're saying I want to compare this on

18 to this one, and this one costs this much and this on

19 costs that much, and that includes all the electrica

20 consumptions from all of anything. 

21 It has the multiplier factor in ther

22 because you're paying 3., whatever it is, times fo

23 the electrical energy that you're paying for the g

24 energy, and in my mind I'm still a site energy kind o

25 a guy. When I plug it into the wall I'm payi~g fo

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

3

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

what comes out of the plug, whether it's gas o

electric. And that's really what we're saying.

Frank, whatever you're comparing, go to 

dollar number and that's what's going to make 

difference to the --

MODERATOR LANGMEAD: And I think as yo

sell this thing, this product, if you're not trying t

put a minimum standard on it or a number on th

minimum standard, if you're trying to sell the produc

to people, you're going to have to give them some cos

of operation comparisons about the gas engine drive

heat pump as it would relate to the cost of operatin

some other kind of systems to do that job..

And the dollar comes, and that compariso

comes down in the cost of both the gas and th

electricity to do the job-several different ways. 

think that's the only real fair comparison you ca

make.

Yes?

MR. YOUNG: Dave Young from Ontario Hydro

I just wonder if we went around this argument a fe

more times we might come to a point where we admit t

ourselves that maybe the one thing we should labe

with all these different products might be dollars pe

million BTUs delivered, like a normalized --

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

16

1 what comes out of the plug, whether it's gas o

2 electric. And that's really what we're saying. 

3 Frank, whatever you're comparing, go to 

4 dollar number and that's what's going to make 

5 difference to the --

6 MODERATOR LANGMEAD: And I think as yo

7 sell this thing, this product, if you're not trying t

8 put a minimum standard on it or a number on th

9 minimum standard, if you're trying to sell the produ

10 to people, you're going to have to give them some co

11 of operation comparisons about the gas engine drive

12 heat pump as it would relate to the cost of operatin

13 some other kind of systems to do that job. 

14 And the dollar comes, and that compariso

15 comes down in the cost of both the gas and th

16 electricity to do the job,several different ways. 

17 think that's the only real fair comparison you ca

18 make. 

19 Yes? 

20 MR. YOUNG: Dave Young from Ontario Hydr

21 I just wonder if we went around this argument a fe

22 more times we might come to a point where we admit 

23 ourselves that maybe the one thing we should lab

24 wi th all these different products might be dollars p

25 million BTUs delivered, like a normalized 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
4

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

16

MODERATOR LANGMEAD: It gets a littl

complex when you take in climate region variations

house structure variations, and you start comparing

and energy cost variations, and --

MR. YOUNG: No, associated with th

intended use of the product.

MODERATOR LANGMEAD: -- well, it become

hard to develope a minimum standard on that basi

because now you're going to take it down to one poin

and make all these comparisons and it's going to b

wrong somewhere.

Yes?

MR. DOUGHERTY: Brian Dougherty, NIST. 

believe if you want wanted to apply your local fue

cost to evaluate the fuel heat pump, you would have t

also be in a position to provide either the annua

operating cost or one of these descriptors from whic

you get operating costs. You'd also have to provid

now a ratio of how much of the input was gas, how muc

it was electricity, otherwise you can't back it ou

again what their local cost. You have to get the

more information than just a descriptor or annua

operating cost, you have to give them also --

MODERATOR LANGMEAD: The GAMA director an

the ARI directory already do that on conventiona

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

16

1 MODERATOR LANGMEAD: It gets a littl

2 complex when you take in climate region variations

3 house structure variations, and you start comparing

4 and energy cost variations, and 

5 MR. YOUNG: No, associated with th

6 intended use of the product. 

7 MODERATOR LANGMEAD: -- well, it become

8 hard to develope a minimum standard on that basi

9 because now you're going to take it down to one poin

10 and make all these comparisons and it's going to b

11 wrong somewhere. 

12 Yes? 

13 MR. DOUGHERTY: Brian Dougherty, NIST. 

14 believe if you want wanted to apply your local fue

15 cost to evaluate the fuel heat pump, you would have t

16 also be ip a position to provide either the annu

17 operating cost or one of these descriptors from whic

18 you get operating costs. You'd also have to provid

19 now a ratio of how much of the input was gas, how mu

20 it was electricity, otherwise you can't back it o

21 again what their local cost. You have to get the

22 more information than just a descriptor or annu

23 operating cost, you have to give them also --

24 MODERATOR LANGMEAD: The GAMA director an

25 the ARI directory already do that on convention

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
2

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

16

products. They give them the AFUE plus the electrica

consumption . It's there today and has been for som

time.

MR. DOUGHERTY: Okay, so then what will b

reported in the GAMA directory and the ARI directo

will be -- you can break it out by fuel --

MODERATOR LANGMEAD: You can break it ou

by fuels. You can get there, yes.

Yes?

MR. JAKOB: Frank Jakob, Batelle. 

misspoke earlier with regard to the AFUE. Only the

gas consumption of the appliance is considered i

calculating operating costs and then translating it t

AFUE. And so when I was implying earlier that perhaps

all energy is involved, that was incorrect and it cam

out in the discussion that it would be more apples t

apples if we did it on a gas only basis. That i

indeed how this clever committee wrote it.

MODERATOR LANGMEAD: I hope somebody

advises Frank Snow to get that answer too.

Yes?

MR. DOUGHERTY: Brian Dougherty, NIST

Doesn't that present a problem if you ever get to 

point where you have a unit maybe that's 51 percen

gas and 49 percent electric, and they come out with a

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

(202) 234-4433 WASHINGTON. D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

16

1 products. They give them the AFUE plus the electrica

2 consumption. It's there today and has been for som

3 time. 

4 MR. DOUGHERTY: Okay, so then what will b

5 reported in the GAMA directory and the ARI directo

6 will be -- you can break it out by fuel 

7 MODERATOR LANGMEAD: You can break it ou

8 by fuels. You can get there, yes. 

9 Yes? 

10 MR. JAKOB: Frank Jakob, Batelle. 

11 misspoke earlier with regard to the AFUE. Only th

12 gas consumption of the appliance is considered i

13 calculating operating costs and then translating it t

14 AFUE. And so when I was implying earlier that perhap

15 all energy is involved, that was incorrect and it cam

16 out in the discussion that it would be more apples t

17 apples if we did it on a gas only basis. That i

18 indeed how this clever committee wrote it. 

19 MODERATOR LANGMEAD: I hope somebod

20 advises Frank Snow to get that answer too. 

21 Yes? 

22 MR. DOUGHERTY: Brian Dougherty, NIST

23 Doesn't that present a problem if you ever get to 

24 point where you have a unit maybe that's 51 percen

25 gas and 49 percent electric, and they come out with a

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 23
1

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

16

AFUE then the AFUE goes to the sky because you're no

accounting for the --

MR. YOUNG: Yes, I --

MODERATOR LANGMEAD: There was a questio

over here.

Yes?

MR. MARRAN: John Marran, Energy Kinetics

We're all engineers in this room. By nature we wan

to put a specific number on the paper and make tha

number stand that the consumer can stand back and mak

an educated decision. And I think we're all buried i

two things. The first is we want to put the number o

the paper, and the second is that number has to b

regulated as a minimum energy efficiency standard. W

want to be able to put a number on the paper that's 

minimum energy efficiency standard.

And because of this concept, we'r

trapped. Everything we do has to be so specific tha

we can 't delineate it all for every house in ever

part of the country everywhere, and yet we're tryin

to come up with all these factors so, the poor consume

can go into a GAMA directory, take out his slid

ruler, his calculator, and do a complete energ

analysis and a cost effective analysis and they're no

capable of doing it. They're just not capable o

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

16

1 AFUE then the AFUE goes to the sky because you're no

2 accounting for the --

3 MR. YOUNG: Yes, I --

4 MODERATOR LANGMEAD: There was a questio

5 over here. 

7 MR. MARRAN: John Marran, Energy Kinetics

8 We're all engineers in this room. By nature we wan

9 to put a specific number on the paper and make tha

10 number stand that the consumer can stand back and mak

11 an educated decision. And I think we're all buried i

12 two things. The first is we want to put the number o

13 the paper, and the second is that number has to b

14 regulated as a minimum energy efficiency standard. W

15 want to be able to put a number on the paper that's 

16 minimum energy efficiency standard. 

17 And because of this concept, we'r

18 trapped. Everything we do has to be so specific tha

19 we can't delineate it all for every house in ever

20 part of the country everywhere, and yet we're tryin

21 to come up with all these factors so' the poor consum

22 can go into a GAMA directory, take out his slid

23 ruler, his calculator, and do a complete energ

24 analysis and a cost effective analysis and they're no

25 capable of doing it. They're just not capable o

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTE!,!S AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 23
16

doing it. And you all know, nobody does that. Eve

2 your best contractors don't do that. How do yo

3 expect the consumer to do it?

4 And I think maybe we're in an era o

5 change in this country, I think, and that we want 

6 market driven economy and market driven decisions

7 And if we really took that into account, we would sa

8 let's put the cost to operate the equipment for a yea

9 or for ten years on the paper, everybody goes to th

10 same formulation. And you might have regions, and yo

11 might have to put six regions or something on it, bu

12 at least for region six you could look at the cost t

13 run all of these different ways, add them up as 

14 dollar number for the year .

15 And you wouldn't even know what th

16 efficiency was, but you'd know by buying tha

17 appliance that you're going to spend $600.00 more 

18 year, I might get my money back in two years, I migh

19 get my money back in five years, or I should neve

20 have bought it in the first place. It's tough whe

21 you've got government regulations sitting back her

22 that you've got to work to. But can we always b

23 driven by the status quo, can we not break out and sa

24 what is really good for the country, what is reall

25 good for the consumer. I don't know, I come at i

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

7323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

16

1 doing it. And you all know, nobody does that. Eve

2 your best contractors don't do that. How do yo

3 expect the consumer to do it? 

4 And I think maybe we're in an era o

5 change in this country, I think, and that we want 

6 market driven economy and market driven decisions

7 And if we really took that into account, we would sa

8 let's put the cost to operate the equipment for a yea

9 or for ten years on the paper, everybody goes to th

10 same formulation. And you might have regions, and yo

11 might have to put six regions or something on it, bu

12 at least for region six you could look at the cost t

13 run all of these ditferent ways, add them up as 

·14 dollar number for the year. 

15 And you wouldn't even know what th

16 efficiency was, but you'd know by buying tha

17 appliance that you're going to spend $600.00 more 

18 year, I might get my money back in two years, I migh

19 get my money back in five years, or I should neve

20 have bought it in the first-place. It's tough whe

21 you've got government regulations sitting back her

22 that you've got to work to. But can we always b

23 driven by the status quo, can we not break out and sa

24 'what is really good for the country, what is reall

25 good for the consumer. I don't know, I come at i

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202). 2
16

1

3

4

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

differently I guess.

MODERATOR LANGMEAD: I'm sure somebod

must want to respond to that?

Cyrus, do you?

MR. NASSERI: Well, disregarding where I'

coming from, as just a private citizen in answer t

this gentleman, it wasn't because of the program

makeup , the National Appliance Energy Advisory Act,

you would "think that they would have had all thes

efficient appliances available in the market?

MR. MARRAN: If maybe we had better energ

descriptors, it might have worked.

MR. NASSERI.: No, my question was --

MR. MARRAN: I think if we had dollars t

operate as our descriptor, maybe it might have worked

MR. NASSERI: Well, there is improvin

process of labeling maybe and rating. But my questio

was in the program you're talking about, because yo

referred to government regulators and this sort o

general terms, and my question to you is, if you di

not have such a program, which was obviously before m

time when it started, would we today hav

refrigerators which are probably 60 to 70 percent mor

efficient than ten years ago?

MODERATOR LANGMEAD: Cyrus, let me try t

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON. D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

16

1 differently I guess. 

2 MODERA TOR LANGMEAD: I'm sure somebod

3 must want to respond to that? 

4 Cyrus, do you? 

5 MR. NASSERI: Well, disregarding where I'm 

6 coming from, as just a private citizen in answer t

7 this gentleman, it wasn't because of the program 

8 makeup, the National Appliance Energy Advisory Act

9 you would think that they would have had all thes

10 efficient appliances available in the market? 

11 MR. MARRAN: If maybe we had better energ

12 descriptors, it might have worked. 

13 MR. NASSERI~: No, my question was --

14 MR. MARRAN: I think if we had dollars t

15 operate as our descriptor, maybe it might have worked

16 MR. NASSERI : Well, there is improvin

17 process of labeling maybe and rating. But my questio

18 was in the program you're talking about, because yo

19 referred to government regulators and this sort o

20 general terms, and my question to you is, if you di

21 not have such a program, which was obviously before m

22 time when it started, would we today hav

23 refrigerators which are probably 60 to 70 percent mo

24 efficient than ten years ago? 

25 

(202) 234-4433 

MODERATOR LANGMEAD: Cyrus, let me try t

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 23
1

2

3

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

16

give a brief answer to that. I can't resist an

longer.

The original concept between EPCA and the

NEACA was to set some minimum efficiencies tha

address some perceived market imperfections that occu

and was to get the lower efficient units off th

market and bring the level up to those that were goin

to be cost effective at the bottom end of the market

This whole discussion is driven by a ga

engine heat pump that is not at the bottom of th

market. And I ask a question, does it really nee

minimum standards and is there any point to have it?

And I was serious.

Now, because I don ' t know there's 

product that needs to fall under NEACA regulations at

all. Now, it wouldn't sell unless the marketplace ca

move that unit as an efficient market and mor

efficient and at less cost of operation than existin

equipment in the marketplace.

I think I 'm answering your question. Yo

know, I have a question of whether or not the whole -

heat pumps needs to be considered for setting a

minimum standard . If it's not, we've got good ways t

project out to the cost of operation of that unit i

a given site. And somebody can make a comparison,

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-44.33 WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

16

1 give a brief answer to that. I can't resist an

2 longer. 

3 The original concept between EPCA and the

4 NEACA was to set some minimum efficiencies tha

5 address some perceived market imperfections that occu

6 and was to get the lower efficient units off th

7 market and bring the level up to those that were goin

8 to be cost effective at the bottom end of the market

9 This whole discussion is driven by a ga

10 engine heat pump that is not at the bottom of th

11 market. And I ask a question, does it really nee

12 minimum standards and is there any point to have it

13 And I was serious. 

14 Now, because I don't know there's 

15 product that needs to fall under NEACA regulations a

16 all. Now, it wouldn't sell unless the marketplace ca

17 move that unit as an efficient market and mor

18 efficient and at less cost of operation than existin

19 equipment in the marketplace. 

20 I think I'm answering your question. Yo

21 know, I have a question of whether or not the whole -

22 heat pumps needs to be considered for setting 

23 minimum standard. If it's not, we've got good ways t

24 project out to the cost of operation of that unit i

25 a given site. And somebody can make a comparison, 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
1

4

5

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

16

person, it isn't going to be a homeowner, but th

sales is going to have to be a better salesman, an

he's going to have to come in with a program to sho

differences in cost.

MODERATOR LANGMEAD: Yes?

MR. MARGOLIS: Eugene Margolis, Departmen

of Energy. From my reading of the statute, gas fire

heat pump is not a covered product. It doesn't fal

under the definition of heat pump. Therefore, if it

is not a covered product, then as Carl said, and yo

had said, we have to look at how a new product, a new

product becomes a covered product and then we have s

many kilowatts, and some millions of kilowatt hours

and it has to be meet that.

What I'm saying is that just based on th

definition of a heat pump, a gas fire heat pump

doesn 't come under that definition because it says i

the definition a heat pump is electrically fired.

Now, if someone or everybody or whoeve

thinks that that is wrong, I would appreciate very

much that they would submit in writing how, why a ga

fired heat pump presently is a covered product an

comes under the definition section where a heat pum

is defined.

25 1 1 MODERATOR LANGMEAD: Gene, thank you for

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

16

1 person, it isn't going to be a homeowner, but th

2 sales is going to have to be a better salesman, an

3 he's going to have to come in with a program to sho

4 differences in cost. 

5 MODERATOR LANGMEAD: Yes? 

6 MR. MARGOLIS: Eugene Margolis, Departmen

7 of Energy. From my reading of the statute, gas fire

8 heat pump is not a covered product. It doesn't fal

9 under the definition of heat pump. Therefore, if i

10 is not a covered product, then as Carl said, and yo

11 had said, we have to look at how a new product, a ne

12 product becomes a covered product and then we have s

13 many kilowatts, and some millions of kilowatt hours

14 and it has to be meet that. 

15 What I'm saying is that just based on th

16 defini tion of a heat pump, a gas fire heat pump

17 doesn't come under that definition because it says i

18 the definition a heat pump is electrically fired. 

19 Now, if someone or everybody or whoeve

20 thinks that that is wrong, I would appreciate ver

21 much that they would submit in writing how, why a ga

22 fired heat pump presently is a covered product an

23 comes under the definition section where a heat pum

24 is defined. 

25 

(202) 234-4433 

MODERATOR LANGMEAD: Gene, thank you fo

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 23
17

2

3

4

5

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

that clarification.

Yes?

MR. SWEETSER: Rich Sweetser; American Ga

Cooling Center. That raises a interesting issue

When we rate the gas fired heat pump under, say th

ANSI standard of equivalency, equivalent SEER o

equivalent HSPF, does that mean from a DOE perspectiv

and a statutory perspective we are allowed to do that

put that in the marketplace as an equivalency fo

comparative purposes as far as the seasonal efficienc

of the unit, if you will, from a cost perspective. I

that a viable, reliable point that we can make?

MR. MARGOLIS: All I would say now i

answer to that is that if it is not a covered product

it is not a covered product. DOE to then make it 

covered product, it would have to have-a rulemakin

first to say that this is a covered product, and the

setting test procedures for it, if they don't exis

already. If industry or trade association has them

we can incorporate those by reference, but we stil

would have to have a hearing to do that. And then w

would go out and then set standards to anothe

rulemaking based on those test procedures.

What you would do, I mean what you woul

do otherwise, I don't know. I mean I would just sa

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

17

1 that clarification. 

2 Yes? 

3 MR. SWEETSER: Rich Sweetser., American Ga

4 Cooling Center. That raises a interesting issue

5 When we rate the gas fired heat pump under, say th

6 ANSI standard of equivalency, equivalent SEER o

7 equivalent HSPF, does that mean from a DOE perspectiv

8 and a statutory perspective we are allowed to do that

9 put that in the marketplace as an equivalency fo

10 comparative purposes as far as the seasonal efficienc

·11 of the unit, if you will, from a cost perspective. I

12 that a viable, reliable point that we can make? 

13 MR. MARGOLIS: All I would say now i

14 answer to that is that if it is not a covered produc

15 it is not a covered product. DOE to then make it 

16 covered product, it would have to have #.a rulemakin

17 first to say that this is a covered product, and the

18 setting test procedures for it, if they don't exi

r 

19 already. If industry or trade association has them

20 we can incorporate those by reference, but we stil

21 would have to have a hearing to do that. And then w

22 would go out and then set standards to anoth

23 rulemaking based on those test procedures. 

24 What you would do, I mean what you wou

25 do otherwise, I don't know. I mean I would just sa

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
2

3

6

8

10

11

12

13

.14

15

16

17

18

19

20

21

.22

23

24

17

personally and not a Department position, is that it' 

not a covered product, you can do anything you want

If what you're doing might be in violation of the FT

Act, I'm not saying the labeling, then, you know

those consequences, if it's an unfair presentation b

you, which then might be in violation of the FTC Act

I understand.

MR. SWEETSER: I understand. In othe

words, if we're making unfair representation, we woul

follow whatever the FTC Act is for false advertising

MR. MARGOLIS: That's right.

MR. SWEETSER: Okay. But what I'm tryin

to get to, and this is any new class of product

whether it's a combination product, whether it's 

dual fuel heat pump, whether it-'s a desiccant syste

which we really haven't talked much about yet, thes

products come out, there's always this fuzzy are

which says under the Energy Policy Act as far a

appliance efficiency standards, DOE is the only on

that can set appliance sufficiency standards.

Now, you're saying that if it's not 

covered product, it's not a covered product and w

don't care about it --

MR. MARGOLIS: I'm not saying don't car

2511 about it.

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

17

1 personally and not a Department position, is that it'

2 not a covered product, you can do anything you want

3 If what you're doing might be in violation of the FT

4 Act, I'm not saying the labeling, then, you know

5 those consequences, if it's an unfair presentation b

6 you, which then might be in violation of the FTC Act

7 I understand. 

8 MR. SWEETSER: I understand. In othe

9 words, if we're making unfair representation, we woul

10 follow whatever the FTC Act is for false advertising

11 MR. MARGOLIS: That's right. 

12 MR. SWEETSER: Okay. But what I'm tryin

13 to get to, and this is any new class of product

.14 whether it's a combination product, whether it's 

15 dual fuel heat pump, whether it's a desiccant syste

16 which we really haven't talked much about yet, thes

17 products come out, there's always this fuzzy are

18 which says under the Energy Policy Act as far a

19 appliance efficiency standards, DOE is the only on

20 that can set appliance sufficiency standards. 

21 Now, you're saying that if it's not 

.22 covered product, it's not a covered product and w

23 don't care about it --

24 

25 about it. 

(202) 234-4433 

MR. MARGOLIS: I'm not saying don't car

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVEN!JE. NoW. 

WASHINGTON. D.C. 20005 (202) 2
3

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

MR. SWEETSER: -- I understand. But DO

has no position on it, it's not a covered product, an

we are free as long as we are good stewards under th

FTC as its structured --

MR. MARGOLIS: I'm saying that right no

we have not looked at that and gotten an official -

it has not been brought to the general counsel to ge

a sign-off on the legal position on that. But I

saying I don't see where that is any different than i

a state would have a standard out there for a produc

that is not a covered product --

MR. SWEETSER: So you're saying --

MR. MARGOLIS: -- and I'm not --

MODERATOR LANGMEAD: Mike, do. you want t

add something?

MR. McCABE: Yes, let me jump in. Mik

McCabe. As long as we have not issued a tes

procedure for a product or for an efficienc

descriptor, that descriptor does not have any standin

with the Department . And there are a number o

instances within industries which have come to DOE an

wanted to change their positions. And we'd like t

have a descriptor, and I'm thinking about tw

examples .: One is the ground couple heat pumps. W

have been working to develope a efficiency descripto

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

17

1 MR. SWEETSER: -- I understand. But DO

2 has no posi tion on it, it's not a covered product, an

3 we are free as long as we are good stewards under th

4 FTC as its structured --

5 MR. MARGOLIS: I'm saying that right no

6 we have not looked at that and gotten an official -

7 it has not been brought to the general counsel to ge

8 a sign-off on the legal position on that. But I'

9 saying I don't see where that :i,s any different than i

10 a state would have a standard out there for a produ

11 that is not a covered product 

12 MR. SWEETSER: So you're saying 

13 MR. MARGOLIS: and I'm not --

14 MODERATOR LANGMEAD: Mike, do. you want t

15 add something? 

16 MR. McCABE: Yes, let me jump in. Mik

17 McCabe. As long as we have not issued a tes

18 procedure fora product or for an efficienc

19 descriptor, that descriptor does not have any standin

20 wi th the Department. And there are a number o

21 instances wi thin industries which have come to DOE an

22 wanted to change their positions. And we'd like t

23 have a descriptor, and I'm thinking about tw

24 examples. . One is the ground couple heat pumps. W

25 have been working to develope a efficiency descript

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
1

3

5

6

7

10

11

12

13

-14

15

16

17

18

19

20

21

22

23

24

25

1

for those products compared to the electric products

Less electricity , there are some benefits for them

but to make amendments , expressly excluded them fro

the program.

Subsequent to that they found some of th

manufacturers in the association said that they foun

that they needed to have, they would like to have

someone would like to have a descriptor in order t

market the product. You're on your own, but yo

cannot have a DOE sanctioned descriptor which so

utilities wanted to have. So they have a descriptor

but there are a lot of deficiencies with that. No

necessarily technical deficiencies, but marke

deficiencies.

MODERATOR LANGMEAD: No, Good Housekeepin

Seal of Approval? .

MR McCABE: Solar water heaters. Th

EPCA legislation defines what energy is, wood, coal

solar, they're not energy, at least not as far as th

program is concerned .- We have tried to work with th

industry who would like to be able to market thei

product and compete against electric resistance hea

pump water heaters to show they're better . We canno

give them the same Good Housekeeping Seal of Approval

(202) 234-4433

And while engine driven heat pumps ar

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

17

1 for those products compared to the electric product

2 Less electricity, there are some benefits for them

3 but to make amendments, expressly excluded them fro

4 the program. 

5 Subsequent to that they found some of th

6 manufacturers in the association said that they foun

7 that they needed to have, they would like to hav

8 someone would like to have a descriptor in order t

9 market the product. You're on your own, but yo

10 cannot have a DOE sanctioned descriptor which som

11 utilities wanted to have. So they have a descripto

12 but there are a lot of deficiencies with that. N

13 necessarily technical deficiencies, but mark

·14 deficiencies. 

15 MODERATOR LANGMEAD: No, Good Housekeepin

16 Seal of Approval? 

17 MR. McCABE: Solar water heaters. T

18 EPCA legislation defines what energy is, wood, coa

19 solar, they're not energy, at least not as far as th

20 program is concerned. We have tried to work with th

21 industry who would like to be able to market the

22 product and compete against electric resistance he

23 pump water heaters to show they're better. We cann

24 gi ve them the same Good Housekeeping Seal of Approva

25 And while engine driven heat pumps a

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

5

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

17

really very efficient, use substantially less energy

and DOE may never want to set minimum efficienc

standards for those products, my question is, give

the marketplace with gas utilities offering rebates

you know, what's happened in the utility industry

those are becoming less common.

But are there things that are happening i

the marketplace that would warrant a test procedur

for the product sanctioned from the Department so tha

manufacturers could go out and market the hell out o

these products with us being able to do things t

support that. And if we don't have a test produce an

don't have a DOE measure of efficiency, is that a goo

thing or is that a bad thing? Can we develope a tes

procedure that will help market these products?

That' s one the things that the labelin

program is all about, and test procedures is a

integral part of that, is to be able to help provid

information to the market so that more efficien

products can be sold and can be accepted. And if w

have confusion in the marketplace, it's not going t

help manufacturers sell products.

And we may not have a standard for some o

these products. I agree that when we look at -- wat

heater, when we look at it by itself, it's - or a

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

17

1 really very efficient, use substantially less energy

2 and DOE may never want to set minimum efficienc

3 standards for those products, my question is, give

4 the marketplace with gas utilities offering rebates

5 you know, what's happened in the utility industry

6 those are becoming less common. 

7 But are there things that are happening i

8 the marketplace that would warrant a test procedur

9 for the product sanctioned from the Department so tha

10 manufacturers could go out and market the hell out o

11 these products with us being able to do things t

12 support that. And if we don't have a test produce an

13 don't have a DOE measure of efficiency, is that a goo

14 thing or is that a bad thing? Can we develope a tes

15 procedure that will help market these products? 

16 That's one the things that the labelin

17 program is all about, and test procedures is a

18 integral part of that, is to be able to help provid

19 information to the market so that more efficien

20 products can be sold and can be accepted. And if w

21 have confusion in the marketplace, it's not going t

22 help manufacturers sell products. 

23 And we may not have a standard for some o

24 these products. I agree that when we look at -~ wat

25 heater, when we look at it by itself, it's -- or 

(202) 234-4433 

, 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

2

4

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

engine driven heat pump, some of these ne

technologies, more efficient than some simila

products, whether or not you're talking about 100 t

125 percent improvement over some other base -- wh

really gives a damn. Because you want to get thos

products at that marketplace, and one must, for th

Department to do anything, that would limit thei

admission into the market.

I think that some of the things we've don

in the past has caused some anxiety in the marketplac

and has limited some of these products from gettin

out there, and so what can we do.

MODERATOR LANGMEAD: And let me just ad

to what Mike is saying. We've got with the engin

driven heat pump, we've got an ANSI Z21.40. There i

an ASHRAE revisions of the ASHRAE standard 40 goin

on. I understand the groups are working together. I

that process would be a beautiful place to set up wh

is needed fo DOE to adopt a test procedure and, i

necessary , a discussion of a descriptor so th

mechanism is set up to get from here to there and th

product can use descriptors that are derived from an

based on, or cost of operation, is based entirely 

a voluntary standard.

And I think it would stand the test o

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4

EE-DET-94-101 COMMENT 0D

17

1 engine driven heat pump, some of these ne

2 technologies, more efficient than some simil

3 products, whether or not you're talking about 100 t

4 125 percent improvement over some other base -- w

5 really gives a damn. Because you want to get tho

6 products at that marketplace, and one must, for th

7 Department to do anything, that would limit the

8 admission into the market. 

9 I think that some of the things we've don

10 in the past has caused some anxiety in the marketpla

11 and has limited some of these products from gettin

12 out there, and so what can we do. 

13 MODERATOR LANGMEAD: And let me just ad

14 to what Mike is saying. We've got with the engin

15 driven heat pump, we've got an ANSI Z21.40. There 

16 an ASHRAE revisions of the ASHRAE standard 40 goin

17 on. I understand the groups are working together. 

18 that process would be a beautiful' place to set up wh

19 is needed fo DOE to adopt a test procedure and, 

20 necessary, a discussion of a descriptor so th

21 mechanism is set up to get from here to there and th

22 product can use descriptors that are derived from a

23 based on, or cost of operation, is based entirely 

24 a voluntary standard. 

25 And I think it would stand the test 

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

4

5

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

17

being in compliance with the Federal Trade Commissio

Regulations because it was based on national standard

So I think the mechanism is there and to refine th

process is coming.

MR. MARGOLIS: Eugene Margolis. I jus

want to add, if we are talking about a test procedure

as Michael is saying , are we presuming that it is 

covered product because you can have first a covered

product and we didn't set a test procedure yet and w

will set one now, so therefore you can have as an ANS

comes up and we could adopt their test procedure

However , if the product under the statute is not a

covered product, before we can set the test procedur

we would have to say that it is a covered product, an

I'm saying that under that, I think it's section 32

of EPCA, which defines how do you cover a new product

So even if you have a test procedure, i

the use of energy doesn 't qualify under 323, it won'

be a covered product. So if ANSI is doing this, 

think they would also, it would behoove them,

submit to us that it is a covered product and meetin

those requirements of having energy users and so on

You know, we could do that ourselves, but you'r

presenting the whole, you know, a test procedure and

everything.

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 234

EE-DET-94-101 COMMENT 0D

17

1 being in compliance with the Federal Trade Commissio

2 Regulations because it was based on national standard

3 So I think the mechanism is there and to refine th

4 process is coming. 

5 MR. MARGOLIS: Eugene Margolis. I jus

6 want to add, if we are talking about a test procedure

7 as Michael is saying, are we presuming that it is 

8 covered product because you can have first a covere

9 product and we didn't set a test procedure yet and w

10 will set one now, so therefore you can have as an ANS

11 comes up and we could adopt their test procedure

12 However, if the product under the statute is not 

13 covered product, before we can set the test procedur

14 we would have to say that it is a covered product, an

15 I'm saying that under that, I think it's section 32

16 of EPCA, which defines how do you cover a new product

17 So even if you have a test procedure, i

18 the use of energy doesn't qualify under 323, it won

19 be a covered product. So if ANSI is dOing this, 

20 think they would also, it would behoove them, t

21 submit to us that it is a covered product and meetin

22 those requirements of having energy users and so on

23 You know, we could do that oursel ves, but you'r

24 presenting the whole, you know, a test procedure an

25 everything. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPPRTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 23
1

3

5

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

17

I think before you even go to that tes

procedure you should determine whether or not we ca

make it a covered product.

MODERATOR LANGMEAD: Well, Joe, do yo

want to make a point?

MR. PIETSCH: Joe Pietsch, Engineerin

Consultant. The partial value of our covered produc

is one that has an aggregate household energy use i

the United States that apprises such types exceedin

4.2 million kilowatt hours or equivalent. And I jus

make 'kind of a rough calculation, but it looks lik

you have to have to have on the order of 100,000 t

200,000 engine driven heat pumps to meet tha

criteria. So that kind of gives you a feel for ho

many heat pumps would have to be out there --

MODERATOR LANGMEAD: So it's going t

probably take some time as we progress in tha

direction.

MR. PIETSCH: Next year.

MR. SWEETSER : Well, one point o

clarification, all of these new class of technologie

to prevent a natural confusion, Rich Sweetser

American Gas Cooling Center, that happens out in th

marketplace is how do you evaluate those units. An

if they are not covered products, the manufacturers o

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

17

1 I think before you even go to that tes

2 procedure you should determine whether or not we ca

3 make it a covered product. 

4 MODERATOR LANGMEAD: Well, Joe, do yo

5 want to make a paint? 

6 MR. PIETSCH: Joe Pietsch, Engineerin

7 Consultant. The partial value of our covered produc

8 is one that has an aggregate household energy use i

9 the United States that apprises such types exceedin

10 4.2 million kilowatt hours or equivalent. And I jus

11 make'kind of a rough calculation, but it looks lik

12 you have to have to have on the order of 100,000 t

13 200,000 engine driven heat pumps to meet tha

14 cri teria. So that kind of· gives you a feel for ho

15 many heat pumps would have to be out there 

16 MODERATOR LANGMEAD: So it's going t

17 probably take some time as we progress in tha

18 direction. 

19 MR. PIETSCH: Next year. 

20 MR. SWEETSER: Well, one point o

21 clarification, all of these new class of technologie

22 to prevent a natural confusion, Rich Sweetse

23 American Gas Cooling Center, that happens out in th

24 marketplace is how do you evaluate those units. A

25 if they are not covered products, the manufacturers 

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w, 

WASHINGTON, D.C. 20005 (202) 2
2

4

5

6

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

17

other entities come in and they do their best within

hopefully, legal terms and ethical terms to have 

covered product out there.

My understanding of what you have told u

is, not being covered product means we don 't have th

Good Housekeeping Seal of Approval yet, but it is no

covered by the NEACA standards, they're not subject t

the NEACA standard issues at this juncture. Is tha

fair?

MR. MARGOLIS: Right. And all of th

penalties that --

MR. SWEETSER: Penalties or benefits tha

accrue there of, of course.

MODERATOR LANGMEAD: Okay, let's no

repeat things now, and we'll just try to wrap this on

up.

Yes?

MR. DOUGHERTY: Brian Dougherty, NISI

May I take it one step further? So then if it's not

a covered appliance, they can report in a

advertisement an HSPF, an AFUE, an SEER?

MR. McCABE: Michael McCabe. No.

MR. DOUGHERTY: Okay.

MR. MARGOLIS: I think they would be the

coming to the FTC and be giving false information.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

17

1 other entities come in and they do their best within

2 hopefully, legal terms and ethical terms to have 

3 covered product out there. 

4 My understanding of what you have told u

5 is, not being covered product means we don't have th

6 Good Housekeeping Seal of Approval yet, but it is no

7 covered by the NEACA standards, they're not subj ect t

8 the NEACA standard issues at this juncture. Is tha

9 fair? 

10 MR. MARGOLIS: Right. And all of th

11 penalties that --

12 MR. SWEETSER: Penalties or benefits tha

13 accrue there of, of course. 

14 MODERATOR LANGMEAD: Okay, let's no

15 repeat things now, and we'll just try to wrap this on

16 up. 

17 Yes? 

18 MR. DOUGHERTY: Brian Dougherty, NIST

19 May I take it one step further? So then if it's no

20 a covered appliance, they can report in a

21 advertisement an HSPF, an AFUE, an SEER? 

22 MR. McCABE: Michael McCabe. No. 

23 MR. DOUGHERTY: Okay. 

24 MR. MARGOLIS: I think they would be the

25 coming to the FTC and be giving false information. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 2
3

4

6

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

17

MR. SWEETSER: Can we report an equivalen

as in the ANSI's Z21.40 appendix that is defined?

MODERATOR LANGMEAD: If you base that -

MR. MARGOLIS: If you base that --

MR. SWEETSER: -- in front of --

MODERATOR LANGMEAD: One person at a tim

has to speak.

All right, Jack Langmead. If you'r

basing your numbers on a nationally recognize

standard, I believe I said before, I think it woul

pass the FTC test equivalency, but you would have t

do it in accordance with that nationally recognize

standard. Maybe that nationally recognized standar

would be found deficient, but that would be anothe

question.

Yes?

MR. ADAMS: Carl Adams , DOE. Just t

somewhat muddy the waters regarding covered product o

not, regarding gas fired heat pumps. In the advanc

notice that we published when we listed design option

for furnaces , we listed gas fired heat pump as the ma

tech design option to be considered. Everybody ma

not agree with that, but when you look at the term

the definition of the term "furnace, a product whic

utilizes only single phase electric current i

(202) 234433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

17

1 MR. SWEETSER: Can we report an equivalen

2 as in the ANSI's Z21.40 appendix that is defined? 

3 MODERATOR LANGMEAD: If you base that 

4 MR. MARGOLIS: If you base that --

5 MR. SWEETSER: in front of --

6 MODERATOR LANGMEAD: One person at a tim

7 has to speak. 

8 All right, Jack Langmead. If you'r

9 basing your numbers on a nationally recognize

10 standard, I believe I said before, I think it wou

11 pass the FTC test equivalency, but you would have t

12 do it in accordance with that nationally recognize

13 standard. Maybe that nationally recognized standar

14 would be found deficient, but that would be anothe

15 question. 

16 Yes? 

17 MR. ADAMS: Carl Adams, DOE. Just t

18 somewhat muddy the waters regarding covered product o

19 not, regarding gas fired heat pumps. In the advanc

20 notice that we published when we listed design option

21 for furnaces, we listed gas fired heat pump as the ma

22 tech design option to be considered. Everybody m

23 not agree with that, but when you look at the term

24 the definition of the term "furnace, a product whi

25 utilizes only single phase electric current 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

4

5

6

7

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

18

conjunction with natural gas, designed to be th

principal heating source for the living space of 

residence, not in a cabinet with a central air

conditioner of more than 65,000 BTUs an hour, is 

forced air central furnace and has a heat input rat

of less than 220,000 BTUs per hour," I think it coul

be argued that the heating side of a gas fired heat

pump does meet that definition of a furnace.

MR. SWEETSER: I think so. You said no

to count it with a central air conditioner, and the

heating side is in the same cabinet with the centra

air conditioner.

MR. ADAMS: In a cabinet with less than,

a central air condition with less than 65,000 BTUs an

hour.

MR. SWEETSER: Yes, so far we're there.

MODERATOR LANGMEAD: Jim Ranfone?

.MR. RANFONE: Jim Ranfone, AGA. I think

we're well beyond the discussion that you wanted to

take place in the session first of all, and we're

wasting a lot of time.

I'd like to get back to the energy

descriptors themselves and ask a question that, you

know, it looks like there are at least some in the

room that believe that cost should be the basis for an

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234.4433 WASHINGTON, D.C. 20005 (202) 234

EE-DET-94-101 COMMENT 0D

18

1 conj unction with natural gas, designed to be th

2 principal heating source for the living space of 

3 residence, not in a cabinet with a central ai

4 conditioner of more than 65,000 BTUs an hour, is 

5 forced air central furnace and has a heat input rate 

6 of less than 220,000 BTUs per hour," I think it could 

7 be argued that the heating side of a gas fired hea

8 pump does meet that definition of a furnace. 

9 MR. SWEETSER: I think so. You said no

10 to count it with a central air conditioner, and th

11 heating side is in the same cabinet with the centra

12 air conditioner. 

13 MR. ADAMS: In a cabinet with less than

14 a central air condition with less than 65,000 BTUs a

15 hour. 

16 MR. SWEETSER: Yes, so far we're there. 

17 MODERATOR LANGMEAD: Jim Ranfone? 

18 MR. RANFONE: Jim Ranfone, AGA. I thin

19 we're well beyond the discussion that you wanted t

20 take place in the session first of all, and we'r

21 wasting a lot of time. 

22 I'd like to get back to the energ

23 descriptors themselves and ask a question that, yo

24 know, it looks like there are at least some in th

25 room that believe that cost should be the basis for a

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 23
1

4

6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

energy descriptor or maybe not the basis, but that

what consumers want. And I would ask the question, i

you have other products such as water heaters tha

have labels that have cost on them, and I don

understand your arguments about not having the dolla

cost -- and it has climatic interface that change

that cost.

But you also have direct heating equipmen

which includes gas fired room heaters, oil furnaces

and also applies to electric and oil products, if 

remember correctly. And I think that while the FT

chose not to require labeling for that product, but i

would still fall under the FTC labeling rule such tha

anybody that manufactured it making a claim abou

energy usage or cost of operation would have to do i

on the basis of dollars per million BTUs.

And I think that's the kind of thing tha

we're trying to, if that would be an acceptabl

,alternative, if you can keep it in that context. Yo

already had a precedent in existing labeling rules 

well as testing procedures that permit you to do that

And maybe Cyrus can answer that question

or is Cyrus here?

MODERATOR LANGMEAD: No.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

(202) 234-4433 WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

1

1 energy descriptor or maybe not the basis, but that

2 what consumers want. And I would ask the question, i

3 you have other products such as water heaters th

4 have labels that have cost on them, and I don

5 understand your arguments about not having the doll

6 cost -- and it has climatic interface that chang

7 that cost. 

8 But you also have direct heating equipme

9 which includes gas fired room heaters, oil furnace

10 and ~lso applies to electric and oil products, if 

11 remember correctly. And I think that while the FT

12 chose not to require labeling for that product, but 

13 would still fall under the FTC labeling rule such th

14 anybody that manufactured it making a claim abo

15 energy usage or cost of operation would .. have to do 

16 on the basis of dollars per million BTUs. 

17 And I think that's the kind of thing th

18 we're trying to, if that would be an acceptab

19 'alternative, if you can keep it in that context. Y

20 already had a precedent in existing labeling rules 

21 well as testing procedures that permit you to do tha

22 

23 And maybe Cyrus can answer that questio

24 or is Cyrus here? 

25 

(202) 234-4433 

MODERATOR LANGMEAD: No. 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N,W. 

WASHINGTON, D,C. 20005 (202) 2
1

2

3

5

6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

18

MR. RANFONE: Anyway, HSPF, James, do yo

have any idea, is that still true, that the direc

heating equipment, if a manufacturer claims energ

consumption, be it gas, electric, oil, has to be base

on the DOE test procedures, number one, and number tw

that -- on a national average cost per million BTUs

MR. MILLS: James Mills, Federal Trad

Commission. There is a section of the Energy Polic

and Conservation Act that you're referring to, whic

is section 323C that requires that if a product is 

product for which there is a test procedure, whic

would be the direct heating equipment, a manufacturer

making a representation as to the cost of energ

consumed, or not of energy consumed, the efficiency

would have to have the representation fairly reflec

the results of the DOE test procedure on that product

MR. RANFONE: I think the test procedure

and I'm not sure there's anybody --

MODERATOR LANGMEAD: A little louder, Jim

we can't hear you.

MR. RANFONE: Jim Ranfone. I think th

test procedure does say something about the cost woul

be on dollars per million BTUs. So that may be a

existing precedent that you're arguing about her

that's already in one test procedure and possibl

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON. D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

18

1 MR. RANFONE: Anyway, HSPF, James, do yo

2 have any idea, is that still true, that the direc

3 heating equipment, if a manufacturer claims energ

4 consumption, be it gas, electric, oil, has to be base

5 on the DOE test procedures, number one, and number tw

6 that -- on a national average cost per million BTUs

7 MR. MILLS: James Mills, Federal Trad

8 Commission. There is a section of the Energy Polic

9 and Conservation Act ~hat you're referring to, whic

10 is section 323C that requires that if a product is 

11 product for which there is a test procedure, whic

12 would be the direct heating equipment, a manufacture

13 making a representation as to the cost of energ

14 consumed, or not of energy consumed, the efficiency

15 would have to have the representation fairly reflec

16 the results of the DOE test procedure on that product

17 MR. RANFONE: I think the test procedure

18 and I'm not sure there's anybody --

19 MODERATOR LANGMEAD: A little louder, Jim

20 we can't hear you. 

21 MR. RANFONE: Jim Ranfone. I think th

22 test procedure does say something about the cost wou

23 be on dollars per million BTUs. So that may be a

24 existing precedent that you're arguing about her

25 that's already in one test procedure and possib

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
1

5

'6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

18

could be brought into other test procedures. Ther

seems to be an indication of some that --

MODERATOR LANGMEAD: Any other discussio

on this point?

We have seemed to have moved of f of th

multi-fuel heat pumps, and if somebody wants to com

back on that, they can.

Yes, in the back?

MR. WILHELM: Barry Wilhelm with Virgini

Power. I would like to just try to forget about thi

word "equivalent" for just a few seconds. It's ver

ambiguous and confusing to the consumer and everybod

else. But can someone, I'm sure in this room, tell m

what the actual efficiency of the unit is, like in CO

or SEER or something, what is the actual efficiency

MODERATOR LANGMEAD: Of what unit?

MR. WILHELM: The gas fired heat pumps?

MR. DOUGHERTY: Define efficiency, Bria

Dougherty, NIST, as far as output over input, what d

you constitute as input in electrical and gas, and ho

do you make that into one -- that's consistent?

MR. WILHELM: Either one, let's just sa

gas. Either one, it doesn't matter.

MR. DOUGHERTY: I mean isn't that wha

2511 the--

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON . D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

18

1 could be brought into other test procedures. The

2 seems to be an indication of some that --

3 MODERATOR LANGMEAD: Any other discussio

4 on this pOint? 

5 We have seemed to have moved off of th

6 multi-fuel heat pumps, and if somebody wants to com

7 back on that, they can. 

8 Yes, in the back? 

9 MR. WILHELM: Barry Wilhelm with Virgin

10 Power. I would like to just try to forget about th

11 word "equivalent" for just a few seconds. It's ver

12 ambiguous and confusing to the consumer aod everybod

13 else. But can someone, I'm sure in this room, tell m

·14 what the actual efficiency of the unit is, like in CO

15 or SEER or something, what is the actual efficiency

16 MODERATOR LANGMEAD: Of what unit? 

17 MR. WILHELM: The gas fired heat pumps

18 MR. DOUGHERTY: Define efficiency, Bria

19 Dougherty, NIST, as far as output over input, what d

20 you constitute as input in electrical and gas, and ho

21 do you make that into one -- that's consistent? 

22 MR. WILHELM: Either one, let's just s

23 gas. Either one, it doesn't matter. 

24 

25 the--

(202) 234-4433 

MR. DOUGHERTY: I mean isn't that wh

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
18

1

2

4

5

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

MR. WILHELM: Something a little over one

MR. DOUGHERTY: -- and the standard tha

has it about 1.25.

MR. WILHELM: Okay, so in a SEER value

and that's maybe a,little less than 4?

MR. DOUGHERTY: No, -then you've got t

times that by --

MODERATOR LANGMEAD: Let's identif

yourself please.

MR. WILHELM: -- you have a COP of 1.25

multiply that times, what 3. something, and you get 

SEER value of about a little less than 4. Air sourc

heat pump, let's say is a 10. So what you've go

still is a air source heat pump is at least two an

half to three times as efficient as the gas fired hea

pump. So what this word "equivalent" does, it get

back to what we talked about this morning which i

source and cost. I think pretty much everybody i

here has been fairly quiet and I think the reason is

is obviously the word "equivalent" is just truly 

sales gimmick and that's about all it is.

MODERATOR LANGMEAD: I have a couple o

responses. Let's take Frank first and then go up th

room.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

18

1 MR. WILHELM: Something a little over one

2 

3 MR. DOUGHERTY: and the standard tha

4 has it about 1.25. 

5 MR. WILHELM: Okay, so in a SEER value

6 and that's maybe a ,little less than 41 

7 MR. DOUGHERTY: No, ~hen you've got t

8 times that by --

9 MODERATOR LANGMEAD: Let's identif

10 yourself please. 

11 MR. WILHELM: -- you have a COP of 1.25

12 multiply that times, what 3. something, and you get 

13 SEER value of about a little less than 4. Air sourc

14 heat pump, let's say is a 10. So what you've go

15 still is a air source heat pump is at least two an

16 half to three times as efficient as the gas fired hea

17 pump. So what this word "equivalent" does, it ge

18 back to what we talked about this morning which i

19 source and cost. I think pretty much everybody i

20 here has been fairly quiet and I think the reason is

21 is obviously the word "equivalent" is just truly 

22 sales gimmick and that's about all it is. 

23 MODERATOR LANGMEAD: I have a couple o

24 responses. Let's take Frank first and then go up th

25 room. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

1.6

17

18

19

20

21

22

23

24

25

1

MR. JAKOB: Frank Jakob, Batelle. I jus

heard some mathematical calculations that I didn

quite, follow. The standard does not have the wor

"equivalent" in it. That's been bantered around thi

table, but there was careful attention paid to th

language in the standard and there is no such thing a

"equivalent source" or "equivalent cost" in the bod

of the standard.

It talks about the SEER of an electric ai

conditioner, and if you look in the ARI director fo

a three ton air conditioner that costs $300.00 a ,yea

to operate, you'll find it has a 14 SEER. And a ga

heat pump costs about $300.00 to operate. That's th

calculation that's being performed.

MR. WILHELM: Get back to the cost issue-

MODERATOR LANGMEAD: Yes, next?

MR. DOUGHERTY: Brian Dougherty, NIST. I

ads that I have seen that the manufacturer i

producing, I recall seeing SEER and then 14, 15, 

can't remember what the number was, but I, remembe

seeing the advertisement. I don't remember seein

"equivalent," I don't remember seeing "source fuel,

I don' t remember seeing "cost equivalent, " just "SEER

which is the issue of whether or not that is i

violation of using the DOE descriptor for applianc

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

18

1 MR. JAKOB: Frank Jakob, Batelle. I jus

2 heard some mathematical calculations that I didn

3 qui te. follow. The standard does not have the wor

4 "equivalent" in it. That's been bantered around thi

5 table, but there was careful attention paid to th

6 language in the standard and there is no such thing a

7 "equivalent source" or "equivalent cost" in the bod

8 of the standard. 

9 It talks about the SEER of an electric ai

10 conditioner, and if you look in the ARI director fo

11 a three ton air conditioner that costs $300.00 a yea

12 to operate, you'll find it has a 14 SEER. And a ga

13 heat pump costs about $300.00 to operate. That's th

14 calculation that's being performed. 

15 MR. WILHELM: Get back to the cost issue

1.6 MODERATOR LANGMEAD: Yes, next? 

17 MR. DOUGHERTY: Brian Dougherty, NIST. I

18 ads that I have seen that the manufacturer i

19 producing, I recall seeing SEER and then 14, 15, 

20 can't remember what the number was, but I rememb

21 seeing the advertisement. I don't remember seein

22 "equivalent," I don't remember seeing "source fuel

23 I don't remember seeing "cost equivalent," just "SEER

24 which is the issue of whether or not that is 

25 violation of using the DOE/descriptor for applian

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON .. D.C. 20005 (202) 2
1

1

4

5

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

that isn't rated current DOE test --

MODERATOR LANGMEAD: Yes, next?

MR. SWEETSER: Rich Sweetser, American Ga

Cooling Center. I think the gentleman down at the en

of the table proved our point, that takes us all ful

circle back to economics. Because if you take th

strict engineering sense of comparing apples an

oranges, and end up with a 4 SEER versus a 10 or a 1

or whatever SEER , you end up with a very misleadin

story.

If you take the cost ratios on an averag

or in most parts of this country, the cost ratio o

utilizing the gas heat pump versus a 10 SEER ai

conditioner or a heat pump, the gas heat pump woul

essentially be about half of the cost of operation o

maybe two-thirds in some parts of the country, so tha

certainly is misleading the consumer.

If you're at all concerned abou

conserving resources or emissions or any of that sort

this situation is equally confused. You're turnin

really the information to the consumer on its head

So I think the gentleman really proved our point wi

his little mathematics.

(202) 2344433

MR. WILHELM: Thank you.

MR. SWEETSER : You're welcome.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

18

1 that isn't rated current DOE test --

2 MODERATOR LANGMEAD: Yes, next? 

3 MR. SWEETSER: Rich Sweetser, American G

4 Cooling Center. I think the gentleman down at the en

5 of the table proved our point, that takes us all fu

6 circle back to economics. Because if you take th

7 strict engineering sense of comparing apples an

8 oranges, and end up with a 4 SEER versus a 10 or a 

9 or whatever SEER, you end up with a very misleadin

10 story. 

11 If you take the cost ratios on an averag

12 or in most parts of this country, the cost ratio o

13 utilizing the gas heat pump versus a 10 SEER a

14 conditioner or a heat pump, the gas heat pump wou

15 essentially be about half of the cost of operation o

16 maybe two-thirds in some parts of the country, so th

17 certainly is misleading the consumer. 

18 If you're at all concerned abo

19 conserving resources or emissions or any of that sor

20 this situation is equally confused. You're turnin

21 really the information to the consumer on its hea

22 So I think the gentleman really proved our point wi

23 his little mathematics. 

24 

25 

(202) 234-4433 

MR. WILHELM: Thank you. 

MR. SWEETSER: You're welcome. 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.w. 

WASHINGTON, D.C. 20005 (202) 2
3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

18

MODERATOR LANGMEAD: With that can we dra

closure on the multi-fuel heat pump?

MR. KELLY: Would you summarize that?

MODERATOR LANGMEAD: Yes, we have 

disagreement about multipliers. I think that's bee

summarized over and over again.

Let's move on now and talk abou

international test procedures. And Ed Pollock ha

some introduction into that issue.

WOMAN: Can we do a break first?

MODERATOR LANGMEAD: Do you want to do 

break or do you -- I think we're going to lose th

audience. Does everybody want to take a break o

should we just go on into this? Let's finish this an

then we can take a break and people can come back an

talk if they want to.

Ed?

MR. POLLOCK: We're now into maybe a

easier area . In the notice in the agenda for today

you have the introductions to the others says 

briefing, in this case it says a brief description, s

that's what we have, there it is.

Last year the ARI people came to us an

asked us to consider moving towards the use of the IS

standard for rating of central air conditioners an

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

18

1 MODERATOR LANGMEAD: With that can we dra

2 closure on the multi-fuel heat pump? 

3 MR. KELLY: .Would you summarize that? 

4 MODERATOR LANGMEAD: Yes, we have 

5 disagreement about multipliers. I think that's bee

6 summarized over and over again. 

7 Let' smove on now and talk abou

8 international test procedures. And Ed Pollock ha

9 some introduction into that issue. 

10 WOMAN: Can we do a break first? 

11 MODERATOR LANGMEAD: Do you want to do 

12 break or do you -- I think we're going to lose th

13 audience. Does everybody want to take a break o

14 should we just go on into this? Let's finish this an

15 then we can take a break and people can come back an

16 talk if they want to. 

17 Ed? 

18 MR. POLLOCK: We're now into maybe a

19 easier area. In the notice in the agenda for today

20 you have the introductions to the others says 

21 briefing, in this case it says a brief description, 

22 that's what we have, there it is. 

23 Last year the ARI people carne to us an

24 asked us to consider moving towards the use of the IS

25 standard for rating of central air conditioners an

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NoW. 

WASHINGTON. D.C. 20005 (202) 2
1

2

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

18

heat pumps. I had already asked NIST to begin to tak

a look at using the ISO or parts of it because of th

edict that we were under from Congress to convert ou

test procedures and standards over to metric unit

where there are dimensions involved.

And so what I wanted to find out was, wha

would be the impact if we did use the ISO temperat

climate test criteria and at the same time change i

to metric. Would we have to change the descriptor

the SEER, what would be the impact on that? Could w

use metric units and some multiplier factor that woul

take us back to the SEER as people know it now so tha

we would be able to still have the same number tha

would be usable for demand side management programs a

far as consumers and people being used to seeing thos

values around 10 as the standard or the other rating

for the products, so that there wouldn't be a need t

re-educate the public?

That question, if we -- the request as th

ARI people have asked us, they had asked that w

consider doing away with the cyclic test because th

ISO standard does not have a cyclic test, it ha

steady state testing only . This raises a problem fo

us as far as what the law requires in that the la

requires us to provide a methodology which can be use

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

18

1 heat pumps. I had already asked NIST to begin to tak

2 a look at using the ISO or parts of it because of th

3 edict that we were under from Congress to convert ou

4 test procedures and standards over to metric unit

5 where there are dimensions involved. 

6 And so what I wanted to find out was, wh

7 would be the impact if we did use the ISO temperat

8 climate test criteria and at the same time change i

9 to metric. Would we have to change the descriptor

10 the SEER, what would be the impact on that? Could w

11 use metric units and some multiplier factor that woul

12 take us back to the SEER as people know it now so tha

13 we would be able to still have the same number tha

·14 would be usable for demand side management programs a

15 far as consumers and people being used to seeing thos

16 values around 10 as .the standard or the other rating

17 for the products, so that there wouldn't be a need t

18 re-educate the public? 

19 That question, if we -- the request as th

20 ARI people have asked us, they had asked that w

21 consider doing away with the cyclic test because th

22 ISO standard does not have a cyclic test, it ha

23 steady state testing only. This raises a problem fo

24 us as far as what the law requires in that the la

25 requires us to provide a methodology which can be use

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2
1

2

3

4

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

18

to calculate annual operating costs. I am not sur

what the answer to that is. That's another thing tha

-- for us.

Is it possible to come up with some sor

of -- value for correlation based on system size o

some other relationship which will allow us t

calculate or determine a cyclic result without havin

to actually test it? And so that's another one o

those questions that remains open right now.

And I'm open to any suggestions o

recommendations that people in this room or other

might have on ways that we might use that ISO standar

and still fulfill the requirements of the law.

So basically that covers the issues. 

might say that there is a precedent already for ou

test procedures in looking for - in that we have gon

to the IEC test procedure for testing of heat pump o

microwaves . And that in the latest rulemaking we hav

proposed that and I believe that the we will be movin

forward with a final rule to use the internationa

standards.

And I think this is the appropriate way t

go as the global market becomes more integrated, tha

we should be looking for, ways to harmonize ou

standard, especially with NAFTA now where we'r

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

18

1 to calculate annual operating costs. I am not sur

2 what the answer to that is. That's another thing tha

3 -- for us. 

4 Is it possible to come up with some sor

5 of -- value for correlation based on system size o

6 some other relationship which will allow us t

7 calculate or determine a cyclic result without havin

8 to actually test it? And so that's another one o

9 those questions that remains open right now. 

10 And I'm open to any suggestions o

11 recommendations that people in this room or other

12 might have on ways that we might use that ISO standar

13 and still fulfill the requirements of the law. 

14 So basically that covers the issues. 

15 might say that there is a precedent already for ou

16 test procedures in looking for -- in that we have gon

17 to the lEe test procedure for testing of heat pump o

18 microwaves. And that in the latest rulemaking we hav

19 proposed that and I believe that the we will be movin

20 forward with a final rule to use the internation

21 standards. 

22 And I think this is the appropriate way 

23 go as the global market becomes more integrated, th

24 we should be looking for- ways to harmonize o

25 standard, especially with NAFTA now where we'

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

3

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

19

working closely with Canadians and the Mexicans tha

we should be looking outward toward other countrie

too.

MR. KELLY: Ed?

MR. POLLOCK: Yes.

MR. KELLY: George Kelly. That fourth

line down there "Eliminate SEER and NSPF," -

proposing going to COP, a non dimensional number?

MR. POLLOCK: Well, if we could go to 

non dimensional number that would still allow us to b

within the law, that's a question that still remain

up in the air. And again, my understanding is tha

there are a lot of, or have been anyway, a lot o

people, manufacturers and others who have used thos

descriptors to market their products and that the

feel that descriptor still is important.

And the question that I would put befor

this group is, you know, what is the feeling on that

what would happen if we just went to the dimensionles

type descriptors like we just mentioned that the SEE

or the COP.

MR. KELLY: I'd like to add to that, tha

if you' re considering that you' d also want to conside

--in that list.

MR. POLLOCK: Well, we went into that

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

19

1 working closely with Canadians and the Mexicans tha

2 we should be looking outward toward other countrie

3 too. 

4 MR. KELLY: Ed? 

5 MR. POLLOCK: Yes. 

6 MR. KELLY: George Kelly. That fourt

7 line down there "Eliminate SEER and NSPF," 

8 proposing going to COP, a non dimensional number? 

9 MR. POLLOCK: Well, if we could go to 

10 non dimensional number that would still allow us to b

11 within the law, that's a question that still remain

12 up in the air. And again, my understanding is tha

13 there are a lot of, or have been anyway, a lot o

14 people, manufacturers and others who have used thos

15 descriptors to market their products and that the

16 feel that descriptor still is important. 

17 And the question that I would put befor

18 this group is, you know, what is the feeling on that

19 what would happen if we just went to the dimensionles

20 type descriptors like we just mentioned that the SEE

21 or the COP. 

22 MR. KELLY: I'd like to add to that, tha

23 if you're considering that you'd also want to conside

24 --in that list. 

25 MR. POLLOCK: Well, we went into tha

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N,W. 

WASHINGTON •. D.C. 20005 (202) 2
1

2

4

5

6

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

The issue that was addressed, and the reason I'm on

addressing ARI here, the air conditioning systems, 

because ARI specifically came to us and asked to mak

this change. As we begin to look at metrification o

all our test procedures and standards, certainly th

is the type of thing that we would want to evaluat

for every one of the products and test procedures -

MODERATOR LANGMEAD: Larry, do you want t

take and address this a little bit, and the questio

I'm going to ask after Larry addresses this, and yo

can be thinking of the question, we have some of ou

Canadian friends down here and we've got NAFT

agreements and test procedure issues between Canada 

here, and it might be a time for any of th

manufacturers of heating, air conditioning and othe

equipment to address any of their issues they'd lik

to raise or at least made known to the Canadians her

in attendance to work within that community.

MR. WETHJE: Larry Wethje, with ARI. Jus

a little more background to what Ed has said. Wha

has happened within ARI is our board of directors ha

issued a mandate , if you want to call it that, to hav

every product section look at where internationa

standards exist, to adopt those standards and abando

ARI standards, whenever it's feasible, practical, an

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

19

1 The issue that was addressed, and the reason I'm on

2 addressing ARI here, the air conditioning systems, i

3 because ARI specifically came to us and asked to ma

4 this change. As we begin to look at metrification o

5 all our test procedures and standards, certainly th

6 is the type of thing that we would want to evalua

7 for everyone of the products and test procedures 

8 MODERATOR LANGMEAD: Larry, do you want t

9 take and address this a little bit, and the questio

10 I'm going to ask after Larry addresses this, and yo

11 can be thinking of the question, we have some of ou

12 Canadian friends down here and we've got NAFT

13 agreements and test procedure issues between Canada i

14 here, and it might be a time for any of th

15 manufacturers of heating, air conditioning and oth

16 equipment to address any of their issues they'd lik

17 to raise or at least made known to the Canadians he

18 in attendance to work within that community. 

19 MR. WETHJE: Larry Wethj e, with ARI. Ju

20 a little more background to what Ed has said. Wh

21 has happened within ARI is our board of directors h

22 issued a mandate, if you want to call it that, to ha

23 every product section look at where internation

24 standards exist, to adopt those standards and aband

25 ARI standards, whenever it's feasible, practical, a

(202) 2344433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

if there are no extenuating circumstances that woul

prohibit us from doing that.

So the unitary section took a look at i

and said, yes there are ISO standards that exist fo

our products, from their perspective they're a littl

bit more desirable from the standpoint of les

burdensome with respect to testing. And so at tha

point the section voted to ask staff to go discuss th

possibility with DOE of adopting the ISO standard i

lieu of the current DOE test methods. So we did hav

some informal discussions with DOE regarding this.

And in the course of those discussion

some of the issues that Ed brought out were put on th

table and rather than formally petition DOE at tha

point to go that route, what we did was we assigned a

engineering task force to take a look at it to see i

there was any correlation between SEER and EER a

outlined in the ISO test method. The engineerin

committee has concluded there investigation an

determined that indeed there is not a means o

correlating those two descriptors. Whic

significantly complicates the process of going from 

DOE SEER descriptor to an ISO EER descriptor.

Basically that's where we are at thi

point. The engineering committee just concluded it

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

19

1 if there are no extenuating circumstances that woul

2 prohibit us from dOing that. 

3 So the unitary section took a look at i

4 and said, yes there are ISO standards that exist fo

5 our products, from their perspective they're a littl

6 bit more desirable from the standpoint of les

7 burdensome with respect to testing. And so at tha

8 point the section voted to ask staff to go discuss th

9 possibility with DOE of adopting the ISO standard i

10 lieu of the current DOE test methods. So we did hav

11 some informal discussions with DOE regarding this. 

12 And in the course of those discussion

13 some of the issues that Ed brought out were put on th

14 table and rather than formally petition DOE at tha

15 point to go that route, what we did was we assigned a

16 engineering task force to take a look at it to see i

17 there was any correlation between SEER and EER a

18 outlined in the ISO test method. The engineerin

19 committee has concluded there investigation an

20 determined that indeed there is not a means o

21 correlating those two descriptors. Whi

22 significantly complicates the process of going from 

23 DOE SEER descriptor to an ISO EER descriptor. 

24 Basically that's where we are at th

25 pOint. The engineering committee just concluded i

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. NW. 

WASHINGTON. D.C. 20005 (202) 2
1

2

4

5

6

7

10

11

12

13

-14

15

16

17

18

19

20

21

22

23

24

25

1

work a little while ago and has determined that, yo

know, they cannot see any easy way of making tha

correlation. Those results will be passed back to th

section in about one month. The section convenes an

they will then assess, you know, where to go at thi

point.

MODERATOR LANGMEAD: Any other question

for Larry on that issue?

Frank?

MR. STANONIK: Larry, was the U.S. 

direct participant in the development of the IS

standard?

MR. WETHJE: Yes. But unsuccessful i

getting the international bodies to incorporate th

cyclic test method into the ISO standard. They trie

to, were not even able to get it into an appendix o

the standard. And so-it doesn't have it. It simpl

is steady state method.

MODERATOR LANGMEAD: Yes, Ed?

MR. POLLOCK: Ed Pollock, DOE. One of th

things that we are considering that may be 

compromise to this, again it makes some dependency t

what you're trying to determine from the aspect o

what it does to the SEER value, and that is that w

might be able to use the, as I said, temperate climat

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

19

1 work a little while ago and has determined that, yo

2 know, they cannot see any easy way of making tha

3 correlation. Those results will be passed back to th

4 section in about one month. The section convenes an

5 they will then assess, you know, where to go at thi

6 point. 

7 MODERATOR LANGMEAD: Any other question

8 for Larry on that issue? 

9 Frank? 

10 MR. STANONIK: Larry, was the U. S . 

11 direct participant in the development of the IS

12 standard? 

13 MR. WETHJE: Yes. But unsuccessful i

14 getting the international bodies to incorporate th

15 cyclic test method into the ISO standard. They trie

16 to, were not even able to get it into an appendix o

17 the standard. And so -it doesn't have it. It simp

18 is steady state method. 

19 MODERATOR LANGMEAD: Yes, Ed? 

20 MR. POLLOCK: Ed Pollock, DOE. One of th

21 things that we are considering that may be 

22 compromise to this, again it makes some dependency 

, 

23 what you're trying to determine from the aspect 

24 what it does to the SEER value, and that is that 

25 might be able to use the, as I said, temperate clima

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
2

4

5

6

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

19

conditions for the state test and essentially adoptin

the ISO state test and then have add on, which we d

in some of our other DOE testing for the cyclic tes

and the defrost test, that type of thing that we nee

to for heat pumps.

MODERATOR LANGMEAD: Yes?

MR. DOUGHERTY: Brian Dougherty, NIST

Frank, the approach that's being taken by myself i

concert with working with ARI is to try to make th

DOE -- make the ISO test method a subset of the DO

test method as much as possible. And as far as th

issue of trying to lessen the burden, people want t

do away with the cyclic testing and maybe come up wit

better defaults. Right now the default value of thi

cyclic -- coefficient of 0.25. And whether or no

that number can. depend on the hardware.

So maybe in the future ARI may conside

opening up their database and look at whether or no

there is some correlation to -- in the hardware so th

default value may be more representative so that mor

manufacturers may choose the default and then th

testing burden becomes essentially almost the same a

what is required by ISO.

MR. DEMPSEY: Dan 'Dempsey, Unite

Technologies Carrier. This is more of a gas furnac

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

19

1 condi tions for the state test and essentially adoptin

2 the ISO state test and then have add on, which we d

3 in some of our other DOE testing for the cyclic tes

4 and the defrost test, that type of thing that we nee

5 to for heat pumps. 

6 MODERATOR LANGMEAD: Yes? 

7 MR. DOUGHERTY: Brian Dougherty, NIST

8 Frank, the approach that's being taken by myself i

9 concert with working with ARI is to try to make th

10 DOE -- make the ISO test method a subset of the DO

11 test method as much as possible. And as far as th

12 issue of trying to lessen the burden, people want t

13 do away with the cyclic testing and maybe come' up wit

14 better defaults. Right now the default value of thi

15 cyclic -- coefficient of 0.25. And whether or no

16 that number can. depend on the hardware. 

17 So maybe in the future ARI may conside

18 opening up their database and look at whether or no

19 there is some correlation to -- in the hardware so th

20 default value may be more representative so that mo

21 manufacturers may choose the default and then th

22 testing burden becomes essentially almost the same a

23 what is required by ISO. 

24 MR. DEMPSEY: Dan 'Dempsey, Unite

25 Technologies Carrier. This is more of a gas furnac

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

6

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

comment. I'm not that familiar with ISO standards f

the -- heating product, but if you can come up with 

steady state and different design specific default

for a gas furnace, it would significantly reduce t

test burden.

MODERATOR LANGMEAD: Dan, where th

Europeans have standards for gas appliances, they a

based on steady state, and sometimes they differe

between atmospheric level, the standard level varie

between a power burner type unit and an atmospher

unit, but they are based on steady state.

And default values, it opens up a who

area to look at, if it's --

MR. DEMPSEY: There are proposed chang

to the test procedures that would affect AFUE by

half a percent or less, but would significant

increase the test burden over and above what it 

today, which is a whole separate --

MODERATOR LANGMEAD: But an important one

I saw another hand over here somewhere

Well, it looks like we've got some mo

work to do on default factors and possibly goin

beyond air conditioning and heat pumps to look at.

At the same time we are progressing wi

a series' of minimum efficiency standards throu

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE. N.W.

WASHINGTON, D.C. 20005 (202) 

EE-DET-94-101 COMMENT 0D

1

1 comment. I'm not that familiar with ISO standards f

2 the -- heating product, but if you can come up with 

3 steady state and different design specific defaul

4 for a gas furnace, it would significantly reduce th

5 test burden. 

6 MODERATOR LANGMEAD: Dan, where th

7 Europeans have standards for gas appliances, they a

8 based on steady state, and sometimes they differe

9 between atmospheric level, the standard level vari

10 between a power burner type unit and an atmospher

11 unit, but they are based on steady state. 

12 And default values, it opens up a who

13 area to look at, if it's 

14 MR. DEMPSEY: There are proposed chang

15 to the test procedures that would affect AFUE by 

16 half a percent or less, but would significant

17 increase the test burden over and above what it 

18 today, which is a whole separate --

19 MODERATOR LANGMEAD: But an important on

20 I saw another hand over here somewhere

21 Well, it looks like we've got some m

22 work to do on default factors and possibly goi

23 beyond air conditioning and heat pumps to look at. 

24 At the same time we are progressing w

25 a series of minimum efficiency standards throu

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 
1

2

3

4

5

6

7

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

Canada, and the test procedures are very slightly, an

the test burden or the resting issue is there tha

what is good one place isn't good in others, and the

have to redo it.

How many Canadian officials do we hav

here?

DOUG CANE: Doug Cane,'Canadian Research

I'm the chairman of one of the air conditioning an

heat pump standards at CSA. I think what you've jus

said is true. In fact I was going to say what wa

Larry -- attitude towards simplifying descriptors i

1988 when Canada proposed a far simpler methodolog

than you're currently using. We've harmonized. Wher

does that leave us now, if you're adopting IS

standards? -

MODERATOR LANGMEAD: Well, I know ther

are all sorts of things going on, not just in ai

conditioning but in furnaces and in water heaters.

MR. CANE: We've harmonized as far as 

know.

MODERATOR LANGMEAD: Charlie?

MR. ADAMS: Charlie Adams, Ducane. I si

on the Z21.40.7 CAN 2.3 central furnace harmoniz

committee to write the safety standard for warm ai

furnaces in the U.S. and Canada. We're sort o

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON. D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

19

1 Canada, and the test procedures are very slightly, an

2 the test burden or the resting issue is there tha

3 what is good one place isn't good in others, and the

4 have to redo it. 

5 How many Canadian officials do we hav

6 here? 

7 DOUG CANE: Doug Cane,· Canadian Research

8 I'm the chairman of one of the air conditioning an

9 heat pump standards at CSA. I think what you've jus

10 said is true. In fact I was going to say what wa

11 Larry -- attitude towards simplifying descriptors i

12 1988 when Canada proposed a far simpler methodolog

13 than you're currently using. We've harmonized. Whe

14 does that leave us now, if you're adopting IS

15 standards? 

16 MODERATOR LANGMEAD: Well, I know ther

17 are all sorts of things going on, not just in a

18 conditioning but in furnaces and in water heaters. 

19 MR. CANE: We've harmonized as far as 

20 know. 

21 MODERATOR LANGMEAD: Charlie? 

22 MR. ADAMS: Charlie Adams, Ducane. I s

23 on the Z21.40.7 CAN 2.3 central furnace harmoni

24 committee to write the safety standard for warm a

25 furnaces in the U . S . and Canada. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 

We're sort 

(202) 2
3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

harmonized at least in the document -- and the outdo

cooking document, and I sat on that subcommittee also

We're sort of harmonized, but we're not quite ther

yet because there is still the, under present Exhib

M for those of you that are familiar with Z21.40.7 CA

2.3, that's an appendix that is set up specificall

for issues that are unique to one country.

I would encourage that we have agreed 

agree on the harmonization effort, and I'd like to se

us actually follow through and finish agreeing o

everything so we don't duplicate the test burden n

only on efficiency tests, but there are other, som

other number of tests that are included in Exhibit 

that we, the manufacturers, are required to run fo

one country that we're not required to run for th

other.

So the intent of harmony is there, bu

we're not really a hundred percent harmonized, a

least in the warm air furnace end of this industry

And it's a hell of a good idea, so we need to figur

out to get there from here.

MODERATOR LANGMEAD: Any other comments

Yes?

MR. CLARK: Jim Clark, Natural Resources

Canada. We have a work plan with Canadian Ga

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

19

1 harmonized at least in the document -- and the outdo

2 cooking document, and I sat on that subcommittee also

3 We're sort of harmonized, but we're not quite ther

4 yet because there is still the, under present Exhib

5 M for those of you that are familiar with Z2l. 40.7 CA

6 2.3, that's an appendix that is set up specificall

7 for issues that are unique to one country. 

8 I would encourage that we have agreed 

9 agree on the harmonization effort, and I'd like to se

10 us actually follow through and finish agreeing 

11 everything so we don't duplicate the test burden n

12 only on efficiency tests, but there are other, som

13 other number of tests that are included in Exhibit 

14 that we, the manufacturers, are required to run f

15 one country that we're not required to run for th

16 other. 

17 So the intent of harmony is there, b

18 we're not really a hundred percent harmonized, 

19 least in the warm air furnace end of this industr

20 And it's a hell of a good idea, so we need to figu

21 out to get there from here. 

22 

23 

24 

25 Canada. 

(202) 234-4433 

MODERATOR LANGMEAD: Any other comment

Yes? 

MR. CLARK: Jim Clark, Natural Resource

We have a work plan wi th Canadian G

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 
19

1

2

4

6

10

11

12

13

-14

15

16

17

18

19

20

21

22

23

24

25

Association through their IES affiliate which is als

an AGA owned affiliate. And I think we have eigh

products that we're going through the harmonizatio

process with, with I guess target dates for eventua

harmonization ranging from sometime in '96 to sometim

in '97, and deals with the test procedure. Also i

terms of certification, under our regulations we wil

accept products for sale in Canada that are certifie

by an agency that's recognized by the Standard

Council of Canada. And there are a number of thos

such as ETL, UL. UL I believe will soon becom

accredited. NIS as well. So there may be some area

where there is a duplicate testing required, but we'r

working to eliminate those in most cases.

Having said that, we still maintain som

prerogative even under NAFTA for different standards

if there is an environmental benefit for having those

MODERATOR LANGMEAD: I just might want t

point out one difference that I'm aware of -- well, i

some cases the efficiency test method is identical i

this country. In the United States the manufacture

makes a declaration to DOE and FTC that they've teste

the product. It gets listed, the product is in th

marketplace, and it gets accepted by the Trad

Association follow-up verification programs.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

19

1 Association through their lES affiliate which is als

2 an AGA owned affiliate. And I think we have eigh

3 products that we're going through the harmonizatio

4 process with, with I guess target dates for eventua

5 harmonization ranging from sometime in '96 to sometim

6 in '97, and deals with the test procedure. Also i

7 terms of certification, under our regulations we wil

8 accept products for sale in Canada that are certifie

9 by an agency that's recognized by the Standard

10 Council of Canada. And there are a number of thos

11 such as ETL, UL. UL I believe will soon becom

12 accredited. NlS as well. So there may be some area

13 where there is a duplicate testing required, but we'r

14 working to eliminate those in most cases. 

15 Having said that, we still maintain som

16 prerogative even under NAFTA for different standards

17 if there is an environmental benefit for having those

18 MODERATOR LANGMEAD: I just might want t

19 point out one difference that I'm aware of -- well, i

20 some cases the efficiency test method is identical i

21 this country. In the United States the manufacture

22 makes a declaration to DOE and' FTC that they've teste

23 the product. It gets listed, the product is in th

24 marketplace, and it gets accepted by the Trad

25 Association follow-up verification programs. 

(202) 234-4433 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

3

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

In Canada the regulations are such tha

before the product gets introduced in the marketpla

it has to be tested by an organization recognized b

Canada which put the testing up at a different poin

and puts the testing up. What it does is create 

situation that you have a great deal of difficult

determining that you have a 95 percent confidence th

your rating value is within plus or minus five perce

of the true mean which is a DOE regulation befor

you've got into production.

So there are some details that I woul

hope we could continue to work on administrativel

primarily to straighten out that administrativ

burden.

Does anybody else want to comment on tha

I guess I've said it all. I'm retired, s

I don't have to deal with that anymore, but it's a

ongoing issue.

Other comments?

I guess with that we're ready to close u

shop. If there are any final comments on any subject

if we want to get into the energy factor discussi

again, we can. If not, hopefully not.

Carl, would you like to give some closi

remarks and indicate that if there is anything tha

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D

19

1 In Canada the regulations are such th

2 before the product gets introduced in the marketplac

3 it has to be tested by an organization recognized b

4 Canada which put the testing up at a different pOi

5 and puts the testing up. What it does is create 

6 situation that you have a great deal of difficult

7 determining that you have a 95 percent confidence th

8 your rating value is wi thin plus or minus five perce

9 of the true mean which is a DOE regulation befo

10 you've got into production. 

11 So there are some details that I wou

12 hope we could continue to work on adm~nistrativel

13 primarily to straighten out that administrativ

14 burden. 

15 Does anybody else want to comment on tha

16 I guess I've said it all. I'm retired, 

17 I don't have to deal with that anymore, but it's 

18 ongoing issue. 

19 Other comments? 

20 I guess with that we're ready to close 

21 shop. If there are any final comments on any subjec

22 if we want to get into the energy factor discussi

23 again, we can. If not, hopefully not. 

24 Carl, would you like to give some closi

25 remarks and indicate that if there is anything th

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 
1

2

3

4

6

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

2

you want to bring to the attention of DO

particularly, that you don't want to mention at thi

meeting, feel free to write DOE.

MR. ADAMS: Well, as everybody ca

probably agree, none of these are simple issues. 

keep waiting in the regulatory area for the firs

simple issue to come along. 'I have not found it yet

Everything always seems to be complicated.

But I would like to thank everybody fo

their participation. We've gotten a lot o

information here. Some of it we've heard before

Some of it I think are some new slants on some issues

And we will be considering thi

information in developing our research agenda whic

will largely be reflected in the statement of work i

our contract with NIST for 1996, which we will b

formulating before the end fo the year.

So I would like to say, if anybody has an

supplemental information that they would like t

provide to supplement comments or discussions tha

were here today, if they want to send them in to DOE

they would be considered. If you would send them t

the attention to Kathy Epping, who sent out th

letters of invitation which I think most of you got

Or that address can be provided at the desk, if yo

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON . D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

20

1 you want to bring to the attention of DO

2 particularly, that you don't want to mention at thi

3 meeting, feel free to write DOE. 

4 MR. ADAMS: Well, as everybody ca

5 probably agree, none of these are simple issues. 

6 keep waiting in the regulatory area for the firs

7 simple issue to come along. I have not found it yet

8 Everything always seems to be complicated. 

9 But I would like to thank everybody fo

10 their participation. We've gotten a lot o

11 information here. Some of it we've heard before

12 Some of it I think are some new slants on some issues

13 And we will be considering thi

14 information in developing our research agenda whic

15 will largely be reflected in the statement of work i

16 our contract with NIST for 1996, which we will b

17 formulating before the end fo the year. 

18 So I would like to say, if anybody has an

19 supplemental information that they would like t

20 provide to supplement comments or discussions tha

21 were here today, if they want to send them in to DO

22 they would be considered. If you would send them t

23 the attention to Kathy Epping, who sent out th

24 letters of invitation which I think most of you go

25 Or that address can be provided at the desk, if yo

(202) 2344433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, N.W. 

WASHINGTON, D.C. 20005 (202) 2
1

3

4

5

6

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

20

don't have it. It will probably be most helpful t

get any additional information by the end of the mont

so that we can continue on with our statement of work

I also want to say that the representativ

from the Federal Trade Commission I believe also foun

today ' s discussion very interesting , and has bee

inquiring about could he borrow the transcript fro

us.

Yes?

MR. RANFONE: Jim Ranfone, AGA. Just 

comment. First, we appreciated the opportunity t

have this kind of workshop. Secondly, we're not sur

who was invited to it, what kind of response you ha

to all interested parties. There seemed to be 

number of groups that we're sort of speaking for lik

consumers that aren't here, and environmentalists -

time frame that they couldn't meet. I'm not reall

comfortable with the way the process evolved in ter

of making the announcement. I think this is a ver

important subject for our country and for ou

industry, and perhaps you have more information -

response you've gotten. And I'll leave it at that.

MR. ADAMS: There were people invited wh

could not show up. I can't tell you what thei

schedule was or what those reasons were.

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

20

1 don't have it. It will probably be most helpful t

2 get any additional information by the end of the mont

3 so that we can continue on with our statement of work

4 I also want to say that the representativ

5 from the Federal Trade Commission I believe also foun

6 today' s discussion very interesting, and has bee

7 inquiring about could he borrow the transcript from 

8 us. 

9 Yes? 

10 MR. RANFONE: Jim Ranfone, AGA. Just 

11 comment. First, we appreciated the opportunity t

12 have this kind of workshop. Secondly, we're not sur

13 who was invited to it, what kind of response you ha

14 to all interested parties. There seemed to be 

15 number of groups that we're sort of speaking for lik

16 consumers that aren't here, and environmentalists -

17 time frame that they couldn't meet. I'm not reall

18 comfortable with the way the process evolved in term

19 of making the announcement. I think this is a ver

20 important subject for our country and for ou

21 industry, and perhaps you have more information -

22 response you've gotten. And I'll leave it at that

23 MR. ADAMS: There were people invited w

24 could not show up. I can't tell you what the

25 schedule was or what those reasons were. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

20

Again, this is not a public hearing. It'

a workshop and it was open to the public. We don'

have any wonderful mechanism for announcing thes

sorts of things. We did not publish this obviously i

the Federal Register. People were aware of it. As 

say, some of whom could not be here for whateve

reason.

But what we are using this information fo

is to develope an agenda of items that we want to loo

at. And as we look at these items, be they changes t

test procedures or energy descriptors or what hav

you, we would be going trough a public process,

rulemaking process in order to do that.

MR. HOSLER: Daryl Hosler, The Souther

California Gas Company. I think you just hit on th

point. I appreciate the opportunity to participate i

this and look at the information. I also appreciat

all the efforts the DOE has put into this. But I fin

that, you know, you're telling me you're putting som

-- to what was brought out here, but the process o

letting the industry know that this was going on wa

completely unsatisfactory. And I think that DO

should recognize that all of these issues ar

important to,everybody.

(202) 2344433

And if you're trying to gather

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

20

1 Again, this is not a public hearing. It'

2 a workshop and it was open to the public. We don

3 have any wonderful mechanism for announcing thes

4 sorts of things. We did not publish this obviously i

5 the Federal Register. People were aware of it. As 

6 say, some of whom could not be here for whateve

7 reason. 

8 But what we are using this information fo

9 is to develope an agenda of items that we want to loo

10 at. And as we look at these items, be they changes t

11 test procedures or energy descriptors or what hav

12 you, we would be going trough a public process, 

13 rulemaking process in order to do that. 

14 MR. HOSLER: Daryl Hos~er, The Souther

15 California Gas Company. I think you ju~t hit on th

16 paint. I appreciate the opportunity to participate i

17 this and look at the information. I also appreciat

18 all the efforts the DOE has put into this. But I fin

19 that, you know, you're telling me you're putting som

20 -- to what was brought out here, but the process o

21 letting the industry know that this was going on w

22 completely unsatisfactory. And I think that DO

23 should recognize that all of these issues ar

24 important to everybody. 

25 And 

(202) 234-4433 

if you're trying 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 

to gath

(202) 2
1

6

9

10

11

12

13

.14

15

16

17

18

19

20

21

22

23

24

25

20

information, whether it's a workshop or a forma

public hearing or something, you bear som

responsibility to let people know that these thing

are going on so that you do get the salien

information that you're looking for.

The way this process came about, and th

way people got invited to this, I'm not sure that yo

know everything that you ought to know.

MR. ADAMS: Point well taken.

Okay, well with that I will adjourn th

workshop. Again, thank you for your participation.

(Whereupon, at 3:10 p.m., the proceeding

in the above-entitled matter were concluded.)

(202) 2344433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 23

EE-DET-94-101 COMMENT 0D

20

1 information, whether it's a workshop or a forma

2 public hearing or something, you bear som

3 responsibil~ty to let people know that these thing

4 are going on so that you do get the salien

5 information that you're looking for. 

6 The way this process came about, and th

7 way people got invited to this, I'm not sure that yo

8 know everything that you ought to know. 

9 MR. ADAMS: Point well taken. 

10 Okay, well with that I will adjourn th

11 workshop. Again, thank you for your participation. 

12 (Whereupon, at 3:10 p.m., the proceeding

13 in the above-entitled matter were concluded.) 

·14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE, NW. 

WASHINGTON, D.C. 20005 (202) 2
CERTIFICATE

This is to certify that the foregoing transcript 

the matter of: U.S. DEPARTMENT OFbENERGY

WORKSHOP ON

ENERGY DESCRIPTOR/TEST PROCEDURE

Before: JACK LANGMEAD, MODERATOR

Date: OCTOBER 18, 1995

Place: ALEXANDRIA, VIRGINIA

represents the full and complete proceedings of t

aforementioned matter, as reported and reduced 

typewriting.

MIKE RUDOFF

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 2

EE-DET-94-101 COMMENT 0D II 

! 

CERTIFICATE 

This is to certify that the foregoing transcript 

the matter of: 

Before: 

Date: 

Place: 

u.s. DEPARTMENT OF,ENERGY 

WORKSHOP ON 

ENERGY DESCRIPTOR/TEST PROCEDURE 

JACK LANGMEAD, MODERATOR 

OCTOBER 18, 1995 

ALEXANDRIA, VIRGINIA 

represents the full and complete proceedings of 

aforementioned matter, as reported and reduced 

typewriting. 

(202) 234-4433 

MIKE RUDOFF 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.W. 

WASHINGTON. D.C. 20005 (202) 2