1 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) 2344433 

### UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

WORKSHOP ON ENERGY DESCRIPTOR/TEST PROCEDURE

WEDNESDAY, OCTOBER.18, 1995

, 1

The workshop was held in the Potomac Room at the Holiday Inn, Eisenhower, 2460 Eisenhower Avenue, Alexandria, Virginia 22314, at 8:30a.m., Jack Langmead, workshop moderator, presiding.

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44332 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 Company 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) 234-4433 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, 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 Company JIM HICKSON, Lennox DARYL HOSLER, The Southern California Gas Co. FRANK JAKOB, Battelle RONALD JARNAGIN, Pacific Northwest Laboratory

NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-4433PRESENT: (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) 234-4433 3 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 Appliance

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 REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE.**~.w.** WASHINGTON. D.C.20005 (202)234-4433A-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) 234-4433

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 REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 4

PAGE NO.

9 17 28

30 33 35 36 89 93

124 136 187 200

(202)234-44335 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. My name is Kathy Epping and I work for the Department of Energy, Office of Codes and Standards Supplies Division. If you haven't signed-in, if you could do 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. If you don't have one, could you sign our sign-in sheet.

As far as logistics go, there is various telephones throughout the hotel. There are some as you enter the building. There' s some by the front desk . There is bathrooms, if you go out the ballroom doors and make a right, they're on your left-hand side. We're going to break for lunch at noon. There is a couple of restaurants. There is one restaurant and a lounge here at the hotel. There is a cafeteria over at the Hoffman Building across the street. There is a deli a little ways down Eisenhower Avenue headed west . If you need better directions than that, ask the front desk.

And to start us off we're going to have

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON, D.C. 20005 (202) 234-4433 5 1 P-R-O-C-E-E-D-I-N-G-S 2 8:57 a.m. 3 MR. ADAMS: Good morning everybody. My 4 name is Kathy Epping and I work for the Department of 5 Energy, Office of Codes and Standards Supplies 6 Division. 7 If you haven't signedin, if you could do 8 so. There is name tags overthere. There is agendas, 9 if you haven't gotten a copy off the agenda. And 10 we're asking everybodyto giveus a business card. If 11 you don't have one, could you sign our sign-in sheet. 12 As far as logistics go, there is various 13 telephones throughout the hotel. There are some as 14 you enter the building. There's some by the front 15 desk. There is bathrooms, if you go out the ballroom 16 doors and make a right, they're on your left-hand 17 side. 18 We're going to break for lunch at noon. 19 There is a couple of restaurants. There is one 20 restaurant and a lounge here at the hotel. There is 21 a cafeteria over at the Hoffman Building across the 22 street. There is a deli a littleways down Eisenhower 23 Avenue headed west. If you need better directions 24 than that, ask the front desk. 25 And to start us off we're going to have

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44331

3 4 5

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 6

Carl Adams who is the Director of the Appliance Division, the Appliance Standards Division, and he's going to give the introductory remarks.

MR. ADAMS: Good morning and welcome to the Department of Energy Workshop on Test Procedures and Energy Efficiency Descriptors.

I must say I am delighted at the turnout 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 much interest. So we're glad to see everybody here. The facilities here may be stretched a bit for the number of people, with microphones and so forth, but we hope you' 11 bear with us and we' 11 do the best we can here.

Over the last several years of conducting engineering analysis in support of rulemakings for energy efficiency standards and in processing waiver requests from the DOE test procedures determining energy efficiency for appliances, several issues have arisen regarding the testing and rating of certain 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) 234-4433 6 

### 1 Carl Adams who is the Director of the Appliance 2 Division, the Appliance Standards Division, and he's 3 going to give the introductory remarks. 4 

### MR. ADAMS: Good morning and welcome to 5 the Department of Energy Workshop on Test Procedures 6 and Energy Efficiency Descriptors. 7 I must say I am delighted at the turnout 8 

### that we have here. When we first started kicking 9 around this idea some time ago, we talked with a few 10 people and we didn't think that we'd have this much 11 interest. So we're glad to see everybody here. The 12 facilities here may be stretched a bit for the number 13 of people, with microphones and so forth, but we hope 14 you'11bear withus and we'll do the best we canhere. 15 Over the last several years of conducting 16 engineering analysis in support of rulemakings for 17 energy efficiency standards and in processing waiver 18 requests from the DOE test procedures determining 19 energyefficiency for appliances, several issues have 20 arisen regarding the testing and rating of certain 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 COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C.20005 (202)234-44332 3 4 5

7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 7 MAN: is that a radio station coming through there?

MAN: It sounds like a radio station to

me. MAN: Well, somebody check with the hotel and see if they can turn that down.

MR. ADAMS : The Department of Energy is in the process of developing a research agenda regarding the resolution of these issues, among other items. As part of this process we are encouraging public discussions on various test procedures issues. Today's discussions should assist us establishing next year's research agenda for test procedure issues.

Today's workshop will focus on energy efficiency descriptors and test procedures regarding the energy consumption and efficiency of appliances that combine more than one fuel source such as furnaces, boilers, and multi-fuel heat pumps, and of appliances that perform more than one function such as space conditioning heat pumps which also heat water. Additionally, we would like to have discussions on the pros and cons of using international test procedures and their associated energy efficiency descriptors. 2511 The workshop will be divided into four

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 7 1 

### MAN: Is that a radio station coming 2 through there? 3 

### MAN: It sounds like a radio station to 4 me. 5 

### MAN: Well, somebodycheck with the hotel 6 and see if they can turn that down. 7 

### MR. ADAMS: TheDepartmentofEnergyisin 8 the process of developing a research agenda regarding 9 the resolutionof these issues, among other items. As 10 part of this process we are encouraging public 11 discussions on various**~est procedur~s**  

### issues. 12 Today's discussions shouldassistusestablishingnext 13 year's research agenda for test procedure issues. 14 

### Today's workshop will focus on energy 15 efficiency descriptors and test procedures regarding 16 the energy consumption and efficiency of appliances 17 that combine more than one fuel source such as 18 furnaces, boilers, and multi-fuel heat pumps, and of 19 appliancesthatperformmore thanone function suchas 20 space conditioning heat pumps which also heat water. 21 Additionally, we would like to have discussions on 22 the pros and cons of uSing international test 23 procedures and their associated energy efficiency 24 descriptors. 25 The workshop will be divided into four

(202) 234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44332 3 4

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 consecutive sessions: energy efficiency descriptors

for multi-fuel appliances; energy efficiency descriptors for multi-function appliances; test procedures and energy efficiency descriptors for multi-fuel heat pumps; and international test procedures. Each session will begin with one or two briefings to give some background information and to start the discussion.

On your agenda you will'see a list of possible discussion items for each topic. We will conduct each session as a forum with a moderator. Jack Langmead will be moderating the sessions and will be responsible for keeping the discussions on track. Jack worked at AGA Labs for 13 years, and the next 24 years at GAMA as the Vice President and Director of Technical Services. He was also part of the industry team that worked on the original NEACA legislation. He is now an independent consultant.

This workshop is not an evidentiary hearing, but a transcript of the workshop will be made. To assist the court reports, it would be appreciated if throughout the day participants would identify themselves each time they speak. I know that gets hard to do and we forget to dot hat, but it does make the recorder's job easier. And also given the

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 8 

### 1 consecutive sessions: energy efficiency descriptors 2 

### for multi-fuel appliances; energy efficiency 3 descriptors for multi-function appliances; test 4 procedures and energy efficiency descriptors for 5 

### multi-fuel heat pumps; and international test 6 procedures. Each session will begin with one or two 7 briefings to give some background information and to 8 start the discussion. 9 On your agenda you will·see a list of 10 

### possible discussion items for each topic. We will 11 conduct each session as a forum with a moderator. 12 JackLangmeadwillbemoderatingthe sessionsandwill 13 be responsible for keeping the discussions on track. 14 Jack worked at AGA Labs for 13 years, and the next 24 15 years at GAMA as the Vice President and Director of 16 Technical Services. He was also part of the industry 17 team that worked on the original NEACA**l~gislation.** 

### 18 He is 

### now an independent consultant. 19 

### This wOrkshop is 

### not an evidentiary 20 hearing, but a transcript of the workshop will be 21 made. To assist the court reports, it would be 22 appreciated if throughout the day participants would 23 identifythemselveseachtimethey speak. I knowthat 24 gets hard to do and we forget to dot hat, but it does 25 make the recorder's job easier. And also given the

(202)234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODEISLANDAVENUE. N.w. WASHINGTON. D.C. 20005 (202)234-44333 4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 9

number of people relative to the microphones that we have, the recorder said, if everybody will speak up, he thinks that the mics will be sufficient, but if not, if he's not getting the signal, he'll start waving his arms, so keep your eye on him, if you would. The transcript of the workshop will be available for inspection and copy at the Department of Energy Freedom of Information Reading Room in 1E-109 Forstal Building, Washington, D.C. between the hours of 9:00 a.m. and 4:00 p.m. Anyone wishing to purchase a copy of the transcript may make arrangements with the court reporter.

To commence the session on energy efficiency descriptors for multi-fuel appliances, George Kelly of the. National Institute of Standards and Technology, which is under contract to the Department of Energy for the development of test procedures will present a briefing on the current furnace test procedures.

George? MR. KELLY: Hello. Is this working? MAN: It's working. MR. KELLY: Okay. Nobody else can hear 2511 it. He can hear it. I'll just talk loud. I'm going

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON, D.C. 20005 (202) 234-4433 9 

### 1 number of people relative to the microphones that we 2 have, the recorder said, if everybody will speak up, 3 he thinks that the mics will be sufficient, but if 4 not, if he's not getting the signal, he'll start 5 waving his arms, so keep your eye on him, if you 6 would. 7 The transcript of the workshop will be 8 availablefor inspectionandcopyattheDepartmentof 9 Energy Freedom of Information Reading Room in 1E-109 10 Forsta1 Building, Washington, D.C. between the hours 11 of 9:00 a.m. and 4:00 p.m. Anyone wishing to purchase 12 a copy of the transcript may make arrangements with 13 the court reporter. 14 To commence the ,session on energy 15 efficiency descriptors for multi-fuel appliances, 16 George Kelly of the National Institute of Standards 17 and Technology, which is under contract to the 18 Department of Energy for the development of test 19 procedures will present a briefing on the current 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 hear 25 it. He can hear it. I'll just talk loud. I'm going

(202)234-4433 

### NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N,W. WASHINGTON. D.C.20005 (202)234-44331 2 3 4

6

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 10

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 to be having a problem with this. Thank you.

The"original furnace test procedure was 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 published a revised Federal Register version of the furnace test procedure which referenced the ASHRAE ANSI test procedure. In '88 ASHRAE again revised it -- changes and waivers and stuff, so they revised it. And then in 193 DOE proposed a new version of it in the Federal Register which has not been finalized yet.

All right, is this one of those energy saving things? It's a green light projector. Okay, a little flaky. And this one ended up referencing, at the same time ASHRAE pushed a revised version of the test procedure, this one now references the '93 one, and it was never finalized, that's one -- it will refer to the ASHRAE one, and they're pretty much the

same , a few minor changes here and there.

Back to the test procedure which is what 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) 2344433 

### 10 1 to talk about the furnace bOiler testprocedure, okay. 2 Now, there is a little bit of history to this thing. 3 Whoever set this up never used

-- thanks. I seem to 4 be having a problem with this. Thank you. 5 The'original furnace test procedure was 6 promulgated in 1978, okay, for furnace and boilers. 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 published 10 a revisedFederalRegisterversionof the furnace test 11 procedure which referenced the ASHRAE ANSI test 12 procedure. In '88 ASHRAE again revised it

-- changes 13 and waivers and stuff, so they revised it. And then 14 in '93 DOE proposed a newversionof it inthe Federal 15 Register which has not been finalized yet. 16 All right, is this one of those energy 17 saving things? It's a green light projector. Okay, 18 a little flaky. And this oneendedup referencing, at 19 the same time ASHRAE pushed a revised version of the 20 test procedure, this one now references the '93 one, 21 and it was never finalized, that's one -- it will 22**ref~r** 

### to the ASHRAE one, and they're pretty much the 23 same, a few minor changes here and there. 24 

### Back to the test procedure which is what 25 we're reallyhere. Certain assumptions are involved.

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NoW. WASHINGTON. D.C. 20005 {202)234-44331 2 3

5

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 11

Furnaces and boilers are installed indoor, outdoor, or isolating combustion. If installed indoors -- oh, I'm sorry, yes, there's no jacket loss. If it's isolating combustion or outdoor, then jacket losses are considered. There's no duct losses, there's no heat gain from the chimney -- we're just simply considering appliance. We're also considering how the dynamic operation of the appliance works over a heating season. And for those units that use indoor combustion gear, the infiltration effect on the building is also taken into account.

The procedure is based upon taking some simplified measurements and then using a calculation procedure, I'll show the benefits of that in a minute, basically you measure the steady state efficiency of the furnace or boiler . You measure the steady state, flue gas temperature and C02 concentration. You obtain information on the shape of the flue gas, temperature of cool-down and heat-up curve, and there is some optional tracer gas test procedures for things like power burners.

You do have to assign some factors. You either take a default value or measures and things like ratio of stack flow to flue flow , the ratio mass NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 

### 11 1 Furnaces andboilersare installedindoor, outdoor, or 2 isolatingcombustion. If installedindoors

-- oh, I'm 3 sorry, yes, there'snojacketloss. If it'sisolating 4 

### combustion or outdoor, then jacket losses are 5 considered. There's no duct losses, there's no heat 6 

### gainfrom thechimney we'rejustsimplyconsidering 7 appliance. 8 We're also considering how the dynamic 9 operation of the appliance works over a heating 10 season. And for those units that use indoor 11 combustion gear, the infiltration effect on the 12 building is also taken into account. 13 The procedure is based upon taking some 14 simplified measurements and then using a calculation 15 procedure, I'll showthe benefitsof that ina minute, 16 basically you 

### measure the steady state efficiency of 17 

### the furnace or boiler. You measure the steady state 18 flue gas temperature and C02 concentration. You 19 obtain information on the shape of the flue gas, 20 temperature of cool-down and heat-up curve, and there 21 is someoptionaltracergas testprocedures for things 22 like power burners. 23 You do have to assign some factors. You 24 either take a default value or measures and things 25 like ratio of stack flow to flue flow, the ratio mass

(202)234-4433 NEAL

### R. GROSS COURT REPORT.ERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C.20005 (202)234-44331 2 3

5

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12

flow during the off-period to the ratio during the onperiod -- is a fraction of the combustion air relief air and draft air which actually contributes to additional infiltration on the resonance. Alphas and over-sizing factors -- takes into account the effect of the stack damper effectiveness, and there is a tracer gas procedure you may use if you want, or you can take a default value.

So again basically steady state temperature and steady state C02 concentration gives you a steady state efficiency. You also measure the flue, C02. concentration and the steady state flue temperature. You have to -- you run the unit to steady state and then you let it cool down, and during the cool-down period you measure the flue temperature at two points by -- equilibrium, slide it back out and then measure the flue temperature again at, well, three point during the off-period, two points during the warm-up period. And the specific time is filled out for the furnaces and boilers when you do these measurements.

This allows you to do a expediential fit to the profile of a heat-up and cool-down curve. Basically theta endurance and steady state and the actual temperatures -- by a function theta FO times an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202)23 4-4433 WASHINGTON

. D.C. 20005 (202) 2344433 12 1 flow during the off-period to the ratioduringtheon2 period

-- is a fraction of the combustion air relief 3 air and draft air which actually contributes to 4 additional infiltration on the resonance. Alphas and 5 over-sizing factors

-- takes into account the effect 6 of the stack damper effectiveness, and there is a 7 tracer gas procedure you may use if you want, or you 8 can take 

### a default value. 9 So again basically steady state 10 temperature and steady state C02 concentration gives 11 you a steady state efficiency. You also measure the 12 flue, C02. concentration and the steady state flue 13 temperature. You have to

- - you run the unit to 14 steady state and thenyou let itcool down, and during 15 the cool-down period youmeasure the flue temperature 16 at two points by

-- equilibrium, slide itback'out and 17 then measure the flue temperature again at, well, 18 three point during the off-period, two points during 19 the warm-up period. And the specific time is filled 20 out for the furnaces and boilers when you do these 21 measurements. 22 This allows you to do a expediential fit 23 to the profile of a heat-up and cool-down curve. 24 Basically theta endurance and steady state and the 25 actual temperatures

-- bya function theta Fa times an

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C.20005 (202)234-44331

3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 13

expediential E to the minus t over tau. You can determine the coefficients and the expediential for the cool-down and heat-up curve using the measurements that you make.

This is then corrected for the fact that units of cycling, okay, and during a cyclic operation never reach steady state temperature of cool-down, so there is correction factors for the on cycle and the off cycle to give you the actual flue gas temperature profile on the cyclic condition.

The losses, the loss during the on cycle, is then to steady state loss minus -- well he went into the unit during the on cycle basically, you can see it here. If it as at steady state he would have steady state loss, but the unit hasn"t heated up to steady state, some of the heat has gone into the heat exchanger, so there is a credit given during the on cycle for that heat that the unit absorbs, and this term just reduces that. It's the mass flow rate times the temperature. So this is the on cycle sensible loss. There's an on cycle infiltration loss, which basically depends upon the difference. between the anthra air and what the indoor air and outdoor air, in this case it was assumed to be 40 degrees. This phi fact, which is the amount of air going up the flue

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 13 1 expediential E to the minus t over tau. You can 2 determine the coefficients and the expediential for 3 thecool-down andheat-upcurveusingthemeasurements 4 that you make. 5 This is then corrected for the fact that 6 units of cycling, okay, and during a cyclic operation 7 never reach steady state temperature of cool-down, so 8 there is correction factors for the on cycle arid the 9 off cycle to give you the actual flue gas temperature 10 profile on the cyclic condition. 11 The losses, the loss during the on cycle, 12 is then to steady state loss minus

-- well he went 13 into the unit during the on cycle basically, you can 14 see it here. If it as at steady state he would have 15 steady state loss, but the unit hasn1t heated up to 16 steady state, some of the heat has gone into the heat 17 exchanger, so there'is a credit given during the on 18 cycle for that heat that the unit absorbs, and this 19 termjustreduces that. It's themass flow rate times 20 the temperature. So this is the on cycle sensible 21 loss. There's an on cycle infiltration loss, which 22 basically depends upon the difference,between the 23 anthra air and what the indoor air,andoutdoor air, in 24 this case it was assumed to be 40 degrees. This phi 25 fact, which is the amount of air going up the flue

(202)234-4433 

### NEALR. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NoW, WASHINGTON, D,C,20005 (202)234-443314 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 house

infiltration. For units using an anthra combustion air, the infiltration loss is zero. .

Of-period loss, off-period sensible loss is basically the mass, the integral of the mass flow rate times the delpha 2, the air stream, the flue temperature and the ambient temperature, the room temperature, and you integrate over the of f period and this is your off-cycle loss. If the unit employees a stack damper, you use the mass flow rate. If you have an off-period infiltration loss, again it depends upon phi and the difference between 70 degrees and the outdoor air temperature. Units using anthra combustion -- infiltration loss is again zero.

Based upon just physical equations for considering buoyancy of gas, heated gas, you can come up with equations for the mass flow rate during the off period and a stack flow rate during off period which ware a function of the off period temperature, and the difference between the off period temperature and the room temperature. So these equations are used for the mass flow rate in the previous loss equations that I showed you.

All right, put it altogether and you have the part load efficiency is 100 percent minus the

(202) 2344433 . NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON. D.C. 20005 (202) 234-4433 14 1 that actually contributes to additional house 2 infiltration. For units using an anthra combustion 3 air, the infiltration loss is zero. 4 Of-period loss, off-period sensible loss 5 is basically the mass, the integral of the mass flow 6 rate times the delpha 2, the air stream, the flue 7 temperature and the ambient temperature, the room 8 temperature, andyou integrateovertheoffperiod and 9 this is your off-cycle loss. If the unit employees a 10 stackdamper, you use themass flow rate. If you have 11 anoff-periodinfiltrationloss, againitdependsupon 12 phi and the difference between 70 degrees and the 13 outdoor air temperature. Units using anthra .14 combustion infiltration loss is again zero. 15 Based upon just physical equations for 16 consideringbuoyancy of gas, heated gas, you cancome 17 up with equations for the mass flow rate during the 18 off period and a stack flow rate during off period 19 which ware a function of the off period temperature, 20 and the differencebetween the off period temperature 21 and theroomtemperature. Sothese equations areused 22 for the mass flow rate in the previous loss equations 23 that I showed you. 24 All right, put it altogether and you have 25 the part load efficiency is 100 percent minus the

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C.20005 (202)234-44331

4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15

latent loss, minus the sensible on-cycle loss, the infiltration on-cycle loss, the sensible off period loss, the infiltration off period loss, and there is a correction factor to just bring it back to the factor of the units only on a portion of the time. Reassure the one time to the on and off times basically. Okay, this part load utilization efficiency is calculated at a cyclic time of 22-1/2 percent, and outdoor temperature of 42 degrees, and we call it a part load efficiency for the appliance. The -- I'm sorry. The annual, which is this case, since it's just the heating appliance , the seasonable utilization efficiency or annual fuel utilization efficient, AFUE, that is just you add into the account 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 energy consumption during the whole year, and that gives you the term that appears in the Federal Register for AFUE. We did do -- so this is based upon ADU here, the part load utilization efficiency which is calculated at one point. We did`do bin analysis and determine that it really didn't make any difference

(202) 234.4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 15 1 latent loss, minus the sensible on-cycle loss, the 2 infiltration on-cycle loss, the sensible off period 3 loss, the infiltration off period loss,and there is 4 a correction factor to just bring it back to the 5 factor of the units only on a portion of the time. 6 Reassure the one time to the on and off times 7 basically. 8 

### Okay," this part load utilization 9 efficiency is calculated at a cyclic time of 22-1/2 10 percent, andoutdoortemperatureof42 degrees, andwe 11 call itapart loadefficiency for the appliance. The 12

-- I'm sorry. The annual, which is this case, since 13 it's just the heating appliance, the seasonable 14 utilization efficiency or annual fuel utilization 15 efficient, AFUE, that isjustyou add intothe account 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 energy 19 consumption during the whole year, and that gives you 20 the term that appears in the Feder.al Register for 21 AFUE. 

### 22 We did do

-- so this is based upon ADU 23 here, the part load utilization efficiency which is 24 calculated at one point. We did'do bin analysis and 25 determine that it really didn't make any difference

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44332 3 4 5 6

8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 16

for most of the products and most of the regions of the country, and therefore, we calculated it only at-- one cyclic condition, 22-1/2 percent on time and one outdoor temperature of 42 degrees.

This term, this "AFUE," does not include any electrical energy consumption, okay. It is purely the gas or oil. The fuel, fossil fuel, energy, the credits for it and the energy consumption that's in there. There is another descriptor that I'll just briefly mention, and I don't want to get into it There is a definition of energy factor in the test procedure, furnace-boiler test procedure , DOE one, that it basically includes a little bit of electrical energy consumption. It doesn't give any credit for the electrical heat energy that goes into the blower that's converted to heat and gets into the house. The numerator is basically is just the fuel output, the denominator is the fuel input plus the electrical energy consumption. The 3.412 is just the conversion factor to convert kilowatts into BTUs , and there is no tern or F factors, as we 'll be talking about in a minute, to correct for generation efficiency or, cost or anything like that. It' s a rather weak way of trying to account for the electrical energy

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 16 1 for most of the products and most of the regions of 2 thecountry, andtherefore, we calculateditonlyat-- 3 one cyclic condition, 22-1/2 percent on time and one 4 outdoor temperature of 42 degrees. 5 This term, this "AFUE," does not include 6 anyelectrical energyconsumption, okay. Itispurely 7 the gas or oil. The fuel, fossil fuel, energy, the 8 credits for it and the energy consumption that's in 9 there. 10 Thereisanotherdescriptorthat 1'11just 11 briefly mention, and I don't want to get into it 12 There is a definition of energy factor in the test 13 procedure, furnace-boiler test procedure, DOE one, 14 that it basically includes a littlebit of electrical 15 energy consumption. It doesn't give any credit for 16 the electrical heat energy that goes into the blower 17 that's converted toheat and gets into thehouse. The 18 numerator is basically is just the fuel output, the 19 denominator is the fuel input plus the electrical 20 energy consumption. The 3.412 isjust the conversion 21 factor to convertkilowatts intoBTUs, and there isno 22 tern or F factors, as we'11 be talking about in a 23 minute, to correct for generation efficiency or cost 24 

### 25 or anything like that. ItI S a rather weak way of trying

(202)234-4433 to account for the electrical NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 energy

(202)234-44331 17 consumption . It results in a variance slower lower than AFUE, but there is no real physical meaning to it and it's not a very good term.

So that basically describes the furnace5 boiler test procedure. As I said, it involves on

taking a limited number of measurements and then, as basically a model that you use to calculate part load 8 efficiency and eventually getting an AFUE efficiency. 9 The value of doing it that way is it's very 10 repeatable, okay. The that do the study for us on 11 the errors associated with that, the typical error for 12 doing measurements like buss alliance 1.2 percent. If 13 you were doing input/output -- the error would be plus 14 or minus 12 percent, okay. So the order of magnitude 15 would be larger if you were trying to do input/output. 16 Okay, so that brings you up to date on the 17 test procedure, and now I'd like to introduce Cyrus 18 Nasseri from DOE and he's going to talk about these 19 i

d energy escr ptors. 20 MR.NASSERI : Thank you, Jack. 21 Good morning ladies and gentlemen and 22 welcome to this gathering. It's a very impressive 23 crowd. And I would like to go ahead and go as fast as 24 I can over where we were , or I should say how I 25 started it, what we have done, and where we are today

(202) 234.4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON, D.C. 20005 (202) 2344433 

### 17 1 

### consumption. It results in a variance slower lower 2 thanAFUE, but there is no real physical meaning to it 3 and it's not a very good term. 4 So that basically describes the furnace5 

### boiler test procedure. As I said, it involves on 6 taking a limited number of measurements and then, as 7 basically a model that you use tocalculate part load 8 efficiency and eventuallygetting anAFUE efficiency. 9 The value of doing it that way is it's very 10 repeatable, okay. The

-- that do the study for us on 11 theerrors associatedwiththat, thetypical error for 12 doing measurements like buss alliance 1.2percent. If 13 you weredoing input/output

-- theerrorwouldbeplus 14 or minus 12 percent, okay. So the order of magnitude 15 would be largerifyouweretrying todo input/output

.. 16 Okay, sothatbringsyouup todateonthe 17 test procedure, and now I'd like to introduce Cyrus 18 Nasseri from DOE and he's going to talk about these 19 energy descriptors. 

### 20 MR. NASSERI: Thank you, Jack. 21 Good morning ladies and gentlemen and 22 welcome to this gathering. It's a very impressive 23 crowd. And I would like to go ahead and go as fast as 24 I can over where we were, or I should say how I 25 started it, what we have done, and where we are today

(202)234-4433 

### NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C.20005 (202)234-44331

3 4 5 6 7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 18

as fast as I can so we can get to the more important parts of this workshop, which is a discussion and hopefully resolution of some of the issues that DOE is looking forward to accomplish with this type of a gathering. Next slide please. I'll go real fast to give you a little bit of legislative drivers on what the minimum standards, the test procedure and descriptor and the test procedure is, as you see, and then I'll go ahead to other things.

Next slide please. The elements of the program is obviously test procedures, labeling and the standards and the issues of today's discussion would be -- relates to the test procedures or the descriptor. The existing energy descriptor, annual fuel utilization efficiency, AFUE, or some people all it AFUE, I've heard that before, is defined as the ratio of annual output energy to annual input energy. Some fossil fuel including off-season pilot loss if used does not include, does not include, electricity consumption of auxiliary equipment. Auxiliary equipment meaning blower fan controls or for oil furnace pump for electric consumption.

Is based on isolated combustion system installation, meaning for non -- furnaces. The

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 18 1 as fast as I can so we can get to the more important 2 parts of this workshop, which is a discussion and 3 hopefullyresolution of someof the issues that DOE is 4 looking forward to accomplish with this type of a 5 gathering. 6 Next slide please. I'll go real fast to 

### 7 give you a little bit of legislative drivers on what 8 the minimum standards, the test procedure and 9 descriptor and the test procedure is, as you see, and 10 then I'll go ahead to other things. 11 Next slide please. The elements of the 12 programisobviouslytestprocedures, labelingandthe 13 standards and the issues of today's discussion would 14 be relates to the test procedures or the 15 descriptor. The existing energy descriptor, annual 16 fuel utilization efficiency, AFUE, or some people all 17 it AFUE, I've heard that before, is defined as the 18 ratio of annual output energy to annual input energy. 19 Some fossil fuel including off-season pilot loss if 

### 20 used does not include, does not include, electricity 21 consumption of auxiliary equipment. Auxiliary 22 equipment meaning blower fan controls or for oil 23 furnace pump for electric consumption. 24 Is based on isolated combustion system 25 installation, meaning for non

(202)234-4433 NEALR. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 furnaces. The

(202)234-44331 2

4 5

8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 19

combustion and dilution air is introduced from outside to the furnace or ambient air. Is for fossil fuel furnaces and also rates for rating for all electric furnaces. Another descriptor with name o`f energy factor is in the existing DOE test procedure which does not or is not used for any rating purposes of the standards. It defines as the ratio of the fossil fuel output to the sum of the fossil input and electrical energy input.

Next slide please. An existing energy descriptor, deficiencies. AFUE does not account for electricity usage by the air conditioning, I mean air circulating blower. Basically furnaces could be designed to operate the blower during the burner off period to extract residual elements of heat from the heat exchanger. This would inflate, this would inflate the AFUE value, yet would actually consume more electricity and increase the operation or operating cost. AFUE does not encourage the use of more efficient motors and controls to save energy, which obviously this is a part which DOE is very sensitive because of the minimum energy standards for this type of appliances.

Next slide please. In order to resolve

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 

### 19 1 combustionanddilutionairisintroducedfromoutside 2 to the furnace or ambient air. Is for fossil fuel 3 furnaces and also rates for rating for all electric 4 furnaces. 5 Another descriptor with name**o~** 

### energy 6 factor is in the existing DOE test procedure which 7 does not oris notused for anyrating purposes of the 8 standards. Itdefines as the ratioof the fossil fuel 9 output to the sum of the fossil input and electrical 10 energy input. 11 Next slide please. An existing energy 12 descriptor, deficiencies. AFUE does not account for 13 electricityusage by the air conditioning, I mean air circulating blower. Basically furnaces could be 15 designed to operate the,blower during the burner off 16 period to extract residual elements of heat from the 17 

### heat exchanger. This would inflate, this would 18 inflate the AFUE value, yet would actually consume 19 more electricity and increase the operation or 20 operating cost.AFUE does not encourage the use of 21 more efficient motors and controls to save energy, 22 which obviously this is a part which DOE is very 23 sensitivebecause of theminimum energy standards for 24 this type of appliances. 25

(202)234-4433 

### Next slide please. In order to resolve NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C.20005 (202)234-44331 2

4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 20

these efficiencies DOE proposed test procedure revision in 1993 in the notice of proposal published in the Federal Register. We told everybody what we proposed for a new energy efficiency. Also in January of 1995 we had another small notice which we call it "Notice of proposal rulemaking commentary reopen" which at that point- we have redefined the energy factor, which I will cover later on a little bit, in the term of economics.

Next slide please. Proposed energy descriptor definition that DOE proposed in the proposed ruling of 1993 is defined as annual efficiency, we call it AE, which is for' rating the fossil fuel furnaces and includes or covers fossil fuel and auxiliary electrical energy used by a fossil fuel furnace. Is for rating indoor or outdoor installation. Also, we have modified energy factor, which, is in a test procedure, so it can cover the fossil fuel and auxiliary electricity and also is used for ICS installation.

Next slide please. Proposed energy descriptor, the AE, or the proposed objective, to account for both fossil fuel consumption and auxiliary electricity consumption of the furnace, to provide consumer information regarding overall performance of

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 20 1 these efficiencies DOE proposed test procedure 2 revision in 1993 in the notice of proposal published 3 in the Federal Register. We told everybody what we 4 proposed for a newenergyefficiency. Also inJanuary 5 of 1995 we had another small notice which we call it 6 "Notice of proposal rulemaking commentary reopen" 7 which at that point' we have redefined the energy 8 factor, which I will cover later on a little bit, in 9 the term of economics. 10 

### Next slide please. Proposed energy 11 descriptor**definit~on** 

### that DOE proposed in the 12 proposed ruling of 1993 is defined as annual 13 efficiency, we call it AE, which is for rating the 14 fossil fuel furnaces and includes or covers fossil 15 fuel and auxiliary electrical energy used by a fossil 16 

### fuel furnace. Is for rating indoor or outdoor 17 installation. Also, we have modified energy factor, 18 which,is in a test procedure, so it can cover the 19 fossil fuel andauxiliaryelectricityand alsoisused 20 for Ies installation. 21 Next slide please. Proposed energy 22 descriptor, the AE, or the proposed objective, to 23 account forbothfossil fuel consumptionand auxiliary

.24 electricity consumption of the furnace, to provide

25 consumer informationregardingoverallperformanceof

(202)2344433 

### NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW, WASHINGTON. D,C,20005 (202)234-44331

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 21

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 George 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 numerators describe the cost to meet the heating load without any appliance loss, with energy priced solely based on the fossil fuel rate. And the denominator represent a total cost fossil fuel and auxiliary electricity to 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 factor F is defined. I go back to ASHRAE standard 103, American Society of Heating, Refrigerating and Air Conditioning, appendix in that standard which also defines this factor as the energy consumption of the electrical generation or at the power plant, divided by what is delivered to the appliance at the point of usage, simply furnace at the consumer's home, this factor was defined in the term of "energy" in the original rulemaking, and then it was comments that is

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 21 1 the appliance both in the form of energy efficiency 2 and energy cost with a single, with a single, 3 

### descriptor. 4 

### Next slideplease. Go back towhat George 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 numerators 8 describe thecosttomeet theheating loadwithout any 9 applianceloss, withenergypriced solelybasedonthe 10 fossil fuel rate. And the denominator represent a 11 total cost fossil fuel and auxiliary electricity to 12 operate the appliance. 13 The components in this formula are 14 basicallythe annual fossil fuel consumptionE, subF, 15 annual auxiliary electricity consumption E, sub AE, 16 our existing descriptorAFUE, a multiplication factor 17 

### F is defined. I go back to ASHRAE standard 103, 18 American Society of Heating, Refrigerating and Air 19 Conditioning, appendix in that standard which also 20 defines this factor as the energy consumption of the 21 electrical generation or at the power plant, divided 22 by what is delivered to the appliance at the point of 23 usage, simply furnace at the consumer's home, this 24 factor was defined in the term of "energy" in the 25 original rulemaking, and then itwas comments that is

(202)234-4433 

### NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C.20005 (202)234-44331 2

7

10 11 12 13 14 15

17 18 19 20 21 22 23 24 25 22

more or better described or meaningful to the consumers for the sake of their rating and finding out what their consumption and utility bills are, if it's defined in the term of "economics" or "cost," price of electricity to the price of fossil fuel. We have reopened the proposed rule in 1995 and we did propose it in that fashion.

Next slide please. Application of the proposed efficiency, I mean descriptor, not, not applied to electric furnaces or heat pumps. I should mention this was the intention or is the intention of the DOE when we published this. Apply to fossil fuel furnaces-boilers where electricity consumption constitutes a small portion, two to six percent, of the total appliance energy consumption. And finally, based upon the cost to consumers, not an efficiency of power generation, transmission or source energy production. The purpose of this last slide obviously was basically because there was a confusion among the commentators as far as the intention of the DOE for proposing this type of descriptor, so I find out that this is a good time to actually show this, overhead and talk about it. As a result of why they proposed, we 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) 2344433 22 1 more or better described or meaningful to the 2 consumers for the sakeof theirrating and finding out 3 what their consumption and utilitybills are, if it's 4 defined inthe termof "economics" or "cost," priceof 5 electricity to the price of fossil fuel. We have 6 reopened the proposed rule in 1995 and we did propose 7 it in that fashion. 8 Next slide please. Application of the 9 proposed efficiency, I mean descriptor, not, not 10 applied to electric furnaces or heat pumps. I should 11 mention this was the intention or is the intention of 12 the DOE when we published this. Apply to fossil fuel 13 furnaces-boilers where electricity consumption 14 constitutes a small portion, two to six percent, of 15 the total appliance energyconsumption. And finally, 16 basedupon the cost toconsumers, not anefficiencyof 17 power generation, transmission or source**ene~gy** 18 production. 19 The purpose of this last slide obviously 20 was basicallybecause**the~e** was a confusion among the 21 commentators as far as the intention of the DOE for 22 proposing this type of descriptor, so I find out that 23 this is a good time to actually show this.overhead and 24 talk about it. As a result of why they proposed, we 25 have the numerous comments from different people,**(202)~** NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N,W. WASHINGTON. D.C. 20005 (202)234-44331 2

4 5 6

8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23

electric, gas energy organizations, and most of the people opposed to our proposed descriptor, a delay was proposed. So today we are where we were two years ago, and hope by having this type of a gathering that this type of background and interest and different people would accomplish necessary and sufficient, or I should say gain, necessary and sufficient information and knowledge to accomplish what DOE would like to accomplish.

I think at this point I am going to turn the stage to Jack Langmead to proceed with the rest of the agenda, and I'm presenting him with a whistle --

MODERATOR LANGMEAD: Thank you. MR. NASSERI: -- so he can conduct his business with the size of this gathering.

MODERATOR LANGMEAD: Thank you very much. Just to get some idea, so we all know who is here, maybe we ought to take just a minute and go around the room from the outside, back up, and then around the inside and just give us your name and who you work for?

MS. EPPING: I'm Kathy Epping, and I work for DOE. 2511 MR. ADAMS: Carl Adams. You've already

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 23 1 electric, gas energy organizations, and most of the 2 peopleopposedtoourproposeddescriptor, a delaywas 3 proposed. 4 So today we are where we were two years 5 ago, and hope by having this type of a gathering that 6 this type of background and interest and different 7 people would accomplish necessary and sufficient, or 8 I should say gain, necessary and sufficient 9 informationandknowledgetoaccomplishwhatDOE would 10 like to accomplish. 11 I think at this point I am going to turn 12 the stage to Jack Langmead toproceedwiththerest of 13 the agenda, and I'm presenting him with a whistle 14 MODERATOR LANGMEAD: Thank you. 15 MR. NASSERI:

-- so he can conduct his 16 business with the size of this gathering. 17 MODERATOR LANGMEAD: Thankyou verymuch. 18 Just to get some idea, so we all,know who 19 is here, maybe we ought to take just a minute and go 20 around the room from the outside, back up, and then 21 around the inside and just give us your name and who 22 you work for? 23 24 for DOE. 25

(202)234-4433 MS. EPPING: I'm Kathy Epping, and I work

MR. ADAMS: Carl Adams. You've already NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-443324

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 the 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 General 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 Gas Distribution Companies.

MR. DeLIMA: Henry DeLima, DeLima Associates. MR. CHWALOWSKI: Matt Chwalowski, EEI.

MR. JARNAGIN: Ron Jarnagin, Pacific Northwest Laboratory.

MR. LIU: Stan Liu, NIST. MR. KALISCH: Bert Kalisch, American Gas Association. MR. FRITTS : Charlie Fritts , also American Gas Association.

MS. BANKS: Donna Banks, American Gas 2511 Association.

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 24 1 heard from me. 2 MR. MILLS: I'm James Mills with the 3 Federal Trade Commission. 4 MR. PAQUETTE: MarkPaquette, ETL Testing. 5 MS. SUOZZO: Margaret Suozzo, ACEEE. 6 MR. MARRAN: JohnMarran, EnergyKinetics. 7 MR. SAWRUK: Jim Sawruk from General 8 Machine Corporation, Electric Furnace. 9 MR. MOSKWA: KennethMoskwa, Weil-McLain. 10 MR. FREITAS: Christopher Freitas, U.S. 11 Department of Energy, Office of Fossil Energy. 12 MR. PETCHUL: MartinPetchul, ColumbiaGas 13 Distribution Companies. .14 MR. DeLIMA: Henry DeLima, DeLima

15 Associates. 16 MR. CHWALOWSKI: Matt Chwalowski, EEl. 

### 17 MR. JARNAGIN: Ron Jarnagin, Pacific 18 Northwest Laboratory. 19 MR. LIU: Stan Liu, NIST. 20 MR. KALISCH: Bert Kalisch, American Gas 21 Association. 22 MR. FRITTS: CharlieFritts, alsoAmerican 

### 23 Gas Association. 24 MS. BANKS: Donna Banks, American Gas 25 Association.

(202)234-4433 NEAL

### A. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44331 2

4 5

7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. HOSLER: Daryl Hosler, Southern California Gas Company.

MR. RANFONE: Jim Ranfone, American Gas Association. MR. DARD: Mike Dard, Canadian Standards.

MR. PIETSCH: Joe Pietsch, I'm an engineering consultant and one of my clients in the industry asked me to attend this meeting.

MR. MINTON: Steve Minton, Apollo State Industries. MR. STANONIK: Frank Stanonik, GAMA.

MR. MATTINGLY: Joe Mattingly, GAMA. MR. GEDCKE: Jeff Gedcke, Amana Refrigeration.

MR. DEMPSEY: Dan Dempsey, Carrier. MR. VERDERBER: Jacob Verderber, Rheem Manufacturing.

MR. ADAMS: Charlie Adams, Ducane Company. MR. VERSHAW: Jim Vershaw, Trane Company. MR. BURNES: Jim Burnes, Nordyne. MR. WILHELM: Barry'Wilhelm, Virginia Power. MR. HICKSON: Jim Hickson, Lennox 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) 234-4433 25 1 MR. HOSLER: Daryl Hosler, Southern 2 California Gas Company. 3 MR. RANFONE: Jim Ranfone, American Gas 

### 4 Association. 5 MR. DARD: Mike Dard, Canadian Standards. 6 MR. PIETSCH: Joe Pietsch, I'm an 7 engineering consultant and one of my clients in the 8 industry asked me to attend this meeting. 9 MR. MINTON: Steve Minton, Apollo State 10 Industries. 11 MR. STANONIK: Frank Stanonik, GAMA. 12 MR. MATTINGLY: Joe Mattingly, GAMA. 13 MR. GEDCKE: Jeff Gedcke, Amana 14 Refrigeration. 

### 15 MR. DEMPSEY: Dan Dempsey, Carrier. 16 MR. VERDERBER: Jacob Verderber, Rheem 17 Manufacturing. 18 MR. ADAMS: CharlieAdams, DucaneCompany. 19 20 21 22 Power. 23 24 Industries. 25

(202)234-4433 MR. VERSHAW: JimVershaw, Trane Company. MR. BURNES: Jim Burnes, Nordyne. MR. WILHELM: Barry'Wilhelm, Virginia 

## MR. HICKSON: Jim Hickson,

MR. LEWIS: Dave Lewis, Lennox. NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, NW. WASHINGTON. D.C. 20005 Lennox

(202)234-443326 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 Water Products Company.

MR. RYAN: Bill Ryan , Gas Research Institute. MR. SWEETSER: Rich Sweetser, American Gas Cooling Center.

MR. STANBOULY: Loutiel Stanbouly, York International.

MR. DOMANSKI: Peter Domanski, NIST. MR. KELLY: George Kelly, NIST. MR. POLLOCK: Ed Pollock, Office of Codes and Standards, DOE.

MR. THRASHER: Bill Thrasher, American Gas Association Research.

MR. CRISAFULLI: Jeff Crisafulli, Batelle. MR. LESLIE: Neil Leslie, Gas Users 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) 234-4433 26 l' MR. CLARK: Jim Clark, Natural Resources, 2 Canada. 3 MR. CANE: Doug Cane, Caneta Research. 4 MR. HAAG: Wilbur Haag, A.O. Smith Water 5 Products Company. 6 MR. RYAN: Bill Ryan, Gas Research 7 Institute. 8 MR. SWEETSER: RichSweetser, AmericanGas 9 Cooling Center. 10 MR. STANBOULY: Loutiel Stanbouly, York 11 International. 12 MR. DOMANSKI: Peter Domanski, NIST. 13 MR. KELLY: George Kelly, NIST. 14 MR. POLLOCK: Ed Pollock, Office of Codes 15 and Standards, DOE. 16 MR. THRASHER: BillThrasher, AmericanGas 17 Association Research. 18 MR. CRISAFULLI: JeffCrisafulli, Batelle. 19 20 Institute. 21 22 

### 23 24 25

(202)234-4433 MR. LESLIE: Neil Leslie, Gas Users

MR. WETHJE: Larry Wethje with ARI. MR. JAKOB: FrankJakob, BatelleColumbus. MR. DOUGHERTY: BrianDoughertywithNIST. MR. RAYMOND: Mike Raymond, DOE. MR. HUI: Bill Hui with DOE. 

### NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331 2

4

8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 27 MR. YOUNG: Dave Young, Ontario Hydro Technologies.

MR. PISTOLE: Mike Pi stole, Effikal International.

MR. BEGOSKE: Tim Begoske, Effikal International.

MR. McCABE: Michael McCabe, Department of Energy.

of Energy.-

of Energy.

of Energy. MR. BERRIGER: Bryan Berriger, Department

MR. LAUGHLIN: Qonnie Laughlin, Department

MR. MARGOLIS: Eugene Margolis, Department

MODERATOR LANGMEAD: Thank you all. As we went through let me remind everybody that you do have to speak up. I heard many names , a few of them were a little hard to pick out. There are name tags at your places. If you haven't filled the name tag out, I guess I'd request you to do so, so the people will know who you are.

I think we've got four major interest groups of utilities and manufacturers here. There is AGA, EEI, GAMA, and ARI. Have I left out any major groups other than the compliments of Canadian visitors

(202) 234-444333 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 

### 27 1 MR. YOUNG: Dave Young, Ontario Hydro 2 Technologies. '3 

### MR. PISTOLE: Mike Pistole, Effikal

4 International. 5 

### MR. BEGOSKE: Tim Begoske, Effikal 6 International. 7 MR. McCABE: MichaelMeCabe, Departmentof 8 Energy. 9 

### MR. BERRIGER: BryanBerriger, Department 10 of Energy.- 11 MR. LAUGHLIN: QonnieLaughlin, Department 12 of Energy. 13 MR. MARGOLIS: EugeneMargolis, Department 14 of Energy

.. 15 

### MODERATOR LANGMEAD: Thankyou all. As we 16 went through letme remind everybody that you do have 17 to speak up. I heard many names, a few of them were 18 a little hard to pick out. There are name tags at 19 your places. If you haven't filled the name tag out, 20 I guess I'd request you to do so, so the people will 21 know who you are. 22 I think we've got four major interest 23 groups of utilities and manufacturers here. There is 24 AGA, EEl, GAMA, and ARI. Have I left out any major 25 groupsotherthanthecomplimentsofCanadianvisitors

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-443328 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 little opening statement on the subject of energy efficiency descriptors , they' d be welcome to do so at this point in time. Does anybody want to give an opening statement remark?

Frank? MR. STANONIK: Frank Stanonik with GAMA. Obviously we've got a lot of people here to talk about the possibility of changing energy descriptors. If you listen to Cyrus from DOE and other people from DOE, the two things driving this are to give consumers better information in particular to the electrical consumption associated with gas and oil furnaces and boilers, and then the other issue is perhaps a means to promote more efficient in the sense of less electrical consumption in those products, better efficiency in that sense.

But the thing is that we currently have in the test procedures a measure that tells you the efficiency of this product in terms of the base fuel it consumes, whether that' s gas and oil, and you now have a measure that tells you the electrical 

# 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) 234-4433 

### 28 1 

### here? 2 I thought that what we might want to do, 3 

### if anyone of those groups would liketomake a little 

### 4 opening statement on the subject of energyefficiency 5 

### descriptors, they'd be welcome to do so at this point 6 

### in time. Does anybody want to give an opening 

### 7 statement remark? 8 

### Frank? 9 MR. 

### STANONIK: Frank Stanonik with GAMA. 10 

### Obviouslywe've got a lot ofpeoplehere to talk about 11 

### the possibility of changing energy descriptors. If 12 you listen to Cyrus from DOE and other people from 13 DOE, the two things drivingthis·aretogiveconsumers 14 better information in particular to the electrical 15 consumption associated with gas and oil furnaces and 16 boilers, and then the other issue is perhaps a means 17 to promote more efficient in the sense of less 18 electrical consumption in those products, better 19 efficiency in that sense. 20 Butthething is thatwe currentlyhave in 21 the test procedures a measure that tells you the 22 efficiency of this product in terms of the base fuel 23 it consumes, whether that's gas and oil, and you now 24 have a measure that tells you the electrical 25 consumption of that associated product.

(202)234-4433 

### NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44331 2 3 4 5

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2,9 And to the extent the general public knows 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 what 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 gained from the consumer's perspective, and as I recall the whole effort of this was appliance efficiency to get 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 be inadequate and will certainly not simplify things but confuse things.

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

were listening to what was said , all of the other descriptors that are being talked about here, such as the AE and things like that, include the electrical consumption, but for good reasons, purposely ignore the fact that some of that electrical energy in, fact ends up as heat and as part of the heat that comes off

(202) 234-44393 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 2.9 1 

### And totheextentthegeneralpublicknows 2 

### anything about or understands anything about 3 effLciencies, the one number they seem to furnish is 4 

### AFUE. And if there was the same effort put in 5 explaining what the EAE number is, the electrical 6 consumption, you thenhave allthenecessarytools for 7 thosewho areinterestedtodetermine orestimatewhat 8 their annual cost of operation is. And theycoulduse 9 that with national average fuel cost, and they could 10 do that with their local fuel cost. 11 

### And on that basis what is to be gained 12 from the consumer's perspective, and as I recall the 13 whole effort of this was appliance efficiency to get 14 the informationtoconsumers, what istobe gained for 15 consumers to have new descriptors which up to this 16 point have all proved in one case or another to be 17 inadequate and will certainlynot simplifythings but 18 confuse things. 19 And I'lljust make one pOint here, ifyou 20 were listening to what was said, all of the other 21 descriptors that are being talked about here, such as 22 the AE and things like that, include the electrical 23 consumption, but for good reasons, purposely ignore 24 the fact that some of that electrical energy in,fact 25 ends up as heat and as part of the heat that comes off

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C.20005 (202)234-44331 2 3

5 6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 30

of the appliance. So on the one hand you're talking about a descriptor that would lower the efficiency of a gas or oil furnace because you're just accounting for the electrical consumption that occurs associated with producing that energy, but ignores the contribution of that energy to the end result of heating. And in fact that's inappropriate.

Now, there's reasons not to do that and we agree with those reasons, but if you look at all that, the current descriptors, we believe the best you can do, and in fact they give all the necessary information for those people that want to determine what is my cost of operation both for the gas or oil I consume and the electricity that I consume in running that appliance. We don't see that. Either there's been an exceptional alternative put forth or the likelihood that there will be one.

MODERATOR LANGMEAD: Is there anybody else that wants to make any opening remarks, any other organization that wants to make any opening remarks on this subject?

Jim? MR. RANFONE: Yes, Jim Ranfone with AGA. I guess I would agree with Frank that the whole idea is to give consumers information. Now, whether or not

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 30 

### 1 of the appliance. So on the one hand you're talking 2 about a descriptor that would lower the efficiency of 3 a gas or oil furnace because you're just accounting 4 for the electrical consumption that occurs associated 5 

### with producing that energy, but ignores the 6 

### contribution of that energy to the end result of 7 

### heating. And in fact that's inappropriate. 8 

### Now, there's reasonsnottodo that andwe 9 

### agreewiththose reasons, but ifyou look at all that, 10 

### the current descriptors, we believe the best you can 11 do, and in fact they give all the necessary 12 information for those people that want to determine 13 what is my cost of operation both for the gas or oil

.14 I consume and the electricity that I consume in

15 

### running that appliance. We don't see that. Either 16 there's been an exceptional alternative put forth or 17 the likelihood that there will be one. 18 MODERATORLANGMEAD: Isthereanybodyelse 19 that wants to make any opening remarks, any other 20 organizationthatwants tomakeanyopeningremarks on 21 this subject? 22 Jim? 23 MR. RANFONE: Yes, Jim Ranfone with AGA. 24 I guess I would agree with Frank that the whole idea 25 is togiveconsumers information. Now, whetherornot

(202)234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C.20005 (202)234-44331 2

4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 31

we agree as to the best methodology to do that remains to be seen. I don't want to pre-judge what's going to be discussed today or make any conclusions that we have the best methodology out there. I had hoped that the workshop would start with a clean slate and take a look at the existing descriptors. I think there is going to be some discussion about the alternative approaches. And before we make a judgment that what we have is the best and we can't do any better, why don't we hear what else is out there, other potential.

Our basic problem with this proposal from DOE was basically the way it was presented by Cyrus when he indicated that the primary purpose was the new energy descriptor was to promote improvements in the electrical consumption for fossil fuel products. He suggested that in doing so that was the entire purpose of that proposal and that it wouldn't apply to electric furnaces or heat pumps.

Our contention is that it should be looked at for other products. How can one justify taking a cost ratio and applying it to the electric consumption of a fossil fuel product and ignoring the same type of procedure for any electric product. I think that is a basic philosophical difference we have and we' d like to talk it out today and possibly come up with some

(202) 2344433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 31 1 we agree as to thebestmethodologytodo that remains 2 tobe seen. I don't want to pre-judgewhat's going to 3 be discussed today or make any conclusions that we 4 have thebestmethodology out there. I hadhoped that 5 the workshop would start with a clean slate and take 6 a look at the existing descriptors. I think there is 7 going to be some discussion about the alternative 8 approaches. And before we make a judgment that what 9 we have is the best and we can't do any better, why 10 don'twe hearwhat elseis out there, otherpotential. 11 Our basicproblemwith this proposal from 12 DOE was basically the way it was presented by Cyrus 13 whenhe indicatedthat theprimarypurposewas thenew 14 energy descriptor was to promote improvements in the 15 electrical consumption for fossil fuel products. He 16 suggested that indoing sothatwas theentirepurpose 17 of that proposal and that it wouldn't apply to 18 electric furnaces or heat pumps. 19 Ourcontentionisthat itshouldbelooked 20 at for other products. How can one justify taking a 21 costratio and applying itto theelectricconsumption 22 of a fossil fuel product and ignoring the same type of 23 procedure for any electric product. I think that is 24 a basicphilosophicaldifferencewe have andwe'd like 25 to talk it out today and possibly come up with some

(202)234-4433 

### NEAL R. GROS.S COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202)234-443332

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 proposal that essentially applies to a small portion of the energy consumed by one product and ignores it as the major energy source for other products. It's just not rational. Now, you want to argue about energy ratios, cost ratios as being not valid, we can do that, but let's take a look at what we've got out there and what can we present to consumers, if a consumer is to look at a piece of equipment and try and make a decision.

Whether we will agree or disagree with the 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 product and it has an AFUE number of 98 on it versus a product that has an AFUE number of 78 on it, one would have to make the assumption that the 98 is going to cost them less to operate. That would be a wrong assumption based on the current energy descriptors, and that's what we would like to discuss today and possibly make some progress . We don't think we're going to make quantum leaps today, but at least get it on the table and let's talk about it and then we have our flight 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) 234-4433 32 1 kind of remedies. 2 Butthere isno logictomaking a proposal 3 that essentially applies to a small portion of the 4 energy consumed by one product and ignores it as the 5 majorenergy source for other products. It'sjustnot 6 rational. Now, you want to argue about energyratios, 7 cost ratios as being not valid, we can do that, but 8. let Is take a look at what we've got out there and what 9 can we present to consumers, if a consumer is to look 10 at a piece of equipment and try and make a decision. 11 Whetherwe will agreeordisagreewiththe 12 effectiveness of a labeling program, it's the law, 13 we'vegot the enforcementmechanism inplacetodo it. 14 The question is, when a consumer looks at a product 15 and ithas anAFUE number of 98 on itversus a product 16 that has anAFUE number of 78 on it, one would have to 17 make the assumption that the 98 is going to cost them 18 less to operate. That would be a wrong assumption 19 based o.n the current energy descriptors, and that's 20 what we would like to discuss today and possibly make 21 some progress. We don't think we're going to make 22 quantum leaps today, but at least get it on the table 23 and let's talk about it and then we have our flight 24 test voucher. 25 MODERATOR LANGMEAD: Thank you, Jim.

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44331 2

4

6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 33 Matt, do you have anything else to say, or somebody from EEI at this point in time, any opening remarks? Larry?

MR. WETHJE: Yes. MODERATOR LANGMEAD: This is Larry Wethje of ARI. MR. WETHJE: Larry Wethje with ARI. I think I'd like to underscore what Frank Stanonik again has said that from ARI's perspective and our members, we don't really see that there is any need for a change in the energy descriptors as they exist today. It doesn't seem like this request is coming from the marketplace or the manufactures. It seems to us that it's more of an issue between utility interests and utility industries rather than a real need in the marketplace or a request from a manufacturer.

There is a means that exist right now for consumers to compare products that use different fuels on an annual operating cost basis, and that's the way it ought to be. The consumers are interested in how much is this product going to cost them to operate, not necessarily how efficient the product is. And there are mechanisms and means that currently exist today for the consumer to be able to do that, and

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 33 1 Matt, do youhave anythingelse to say, or 

### 2 somebody from EEl at this point in time, any opening 3 remarks? 

### 4 Larry? 5 MR. WETHJE: Yes. 6 MODERATOR LANGMEAD: This is LarryWethje 7 of ARI. 8 MR. WETHJE: Larry Wethje with ARI. I 9 think I'd liketo underscorewhat Frank Stanonik again 10 has said that from ARI's perspective and our members, 11 we don't really see that there is any need for a 

### 12 change in the energy descriptors as they**ex~st** today. 13 It doesn't seem like this request is coming from the 14 marketplace or the manufactures. It seems to us that 

### 15 it's more of an issue between utility interests and 16 utility industries rather than a real need in the 17 marketplace or a request from a manufacturer. 

### 18 There is a means that exist right now for 19 consumers tocompareproductsthatusedifferent fuels 

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

### 21 it ought to be. The consumers are interested in how 

### 22 much is this product going to cost them to operate, 23 not necessarily how efficient the product is. And 24 there are mechanisms and means that currently exist 25 today for the consumer to be able to do that, and

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NoW. WASHINGTON, D.C. 20005 (202)234-443334 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 with what Jim Ranfone just said and take issue with what Cyrus Nasseri from DOE said that there was no intention for the F factor to apply to all types of heating products because in the proposed rule there was a clear statement that we took issue with that 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 heating equipment. So I'm a little confused as to DOE's position when they put up the overhead and said that that was not the intention , because it clearly was the intention as stated in the Federal Register. I'd like to get some clarity on that, if I could, from DOE. But I guess also just his opening remarks, again, to say that -- I'm not sure whether it's need or it's alleged need or the request is coming from other than I can speculate from utility interest because manufacturers and consumers seem to be satisfied with 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) 234-4433 34 1 that's what matters to them. 

### 2 Furthermore, I also think I agree with 3 what Jim Ranfone just said and take issue with what 

### 4 Cyrus Nasseri from DOE said that there was no 5 intention for the F factor to apply to all types of 6 heating products because in the proposed rule there 

### 7 was a clear statement that we took issue with that 8 said, and I can quote from page 4350 of the Federal 9 Register and the proposed rule that the F factor 10 wasn't intended to applyto all types of spaceheating 11 equipment. 

### 12 So I'm a li,ttle confused as to DOE's 13 position when they put up the overhead and said that 14 thatwas not the intention, because itclearlywas the 15 intention as stated. in theFederalRegister. I'dlike 

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

### 17 But I guess also just his opening remarks, again, to 

### 18 say that

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

### 19 alleged need or the request is coming from other than 20 I can speculate from utility interest because 

### 21 manufacturers and consumers seem to be satisfied with 

### 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. NEALR. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, NW, WASHINGTON. D,C, 20005 (202)234-44331

4

7

9 10 11 12 13 . 14 15 16 17 18 19 20 21 22 23 24 25 35 MR.FRITTS: My name is Charlie Fritts. I'm with American Gas, and I'll be brief. The labels are confusing. We may understand them, consumers don't. What we think is worthwhile for this whole group, and also for DOE to look at, is to get a system where consumers can figure out how efficient that product is and the consumers want to know cost. It may be cost per BTU. We would obviously source analysis over sight, but the people have to follow cost. That's what consumers want.

And one of our presentations today by Frank Jakob, will relate to cost per BTU at the site. But I think in the bigger picture we have to develope a uniform standard so people can look at appliances

f and say how much does this cost to operate. AEs don't mean anything to the consuming public, and I think that's the long term goal of this. Because Congress is not going to be behind a series of different evaluations of different appliances that the public cannot understand. I think we have to look to a bigger picture of getting a unified standard that's essentially based on cost.

MODERATOR LANGMEAD: Larry, do you have another comment?

MR. WETHJE: I would actually just like to

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON, D.C. 20005 (202) 234-4433 35 1 MR. FRITTS: My name is Charlie Fritts. 2 I'm with American Gas, and I'll be brief. The labels 3 are confusing. We may understand them, consumers 4 don't. What we think is worthwhile for this whole 5 group, and also for DOE to look at, is to get a system 6 where consumers can figure out how efficient that 7 product is and the consumers want to know cost. It 8 may be cost per BTU. We would obviously source 9 analysis over sight, but the people have to follow 10 cost. That's what consumers want. 11 And one of our presentations today by 12 Frank Jakob, will relate to cost per BTU at the site. 13 But I think in the bigger picture we have to develope .14 a uniform standard so people can look at appliances

, 15 and say how much does this cost to operate. AEs don't 16 mean anything to the consuming public, and I think 17 that's the long term goal of this. Because Congress 18 is not going to be behind a series of different 19 evaluations of different appliances that the public 20 cannot understand. I think we have to look to a 21 bigger picture of getting a unified standard that's 22 essentially based on cost. 

### 23 MODERATOR LANGMEAD: Larry, do you have 24 another comment? 25

(202)234-4433 MR. WETHJE: I would actuallyjustliketo 

### NEALR. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-443336 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 to compare products on a cost basis. The directories that are nationally recognized by the trade associations offer such a basis. The DOE test procedures offer such a basis.

Furthermore, I think we're all kidding ourselves if anybody in the room believes that consumers look at the energy descriptors and base their purchasing decisions on those. The trade associations and manufacturers have long argued with FTC that the energy guide labels really are not a factor in making a decision on the purchase. These products, furnaces, boilers, air conditioners are not purchased based upon looking at the yellow energy guide labels. Consumers typically don't make a purchase based on those. They purchase through contractors and contractors probably very often get down to what is it going to cost me or you to operate this product, and they have a means of being able to explain that to the consumer very thoroughly right

now.

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 36 1 respond. 2 MODERATOR LANGMEAD: Identify yourself, 3 please. 4 MR. WETHJE: Larry Wethje withARI again. 5 As I said there is a means right now for consumers to 6 compare products on a cost basis. The directories 7 that are nationally recognized by the trade 8 associations offer such a basis. The DOE test 9 procedures offer such a basis. 

### 10 Furthermore, I think we're all kidding 11 ourselves if anybody in the room believes that 12 consumers look at the energy descriptors and base 13 their purchasing decisions on those. The trade 14 associations and manufacturers have long argued with 15 FTC that the energy guide labels rea'lly are not a 16 factor in making a decision on the purchase. These 17 products, furnaces, boilers, air conditioners are not 18 purchased based upon looking at the yellow energy 19 guide labels. Consumers typically don't make a 20 purchase based on those. They purchase through 21 contractors and contractors probably very often get 22 down to what is it going to cost me or you to operate 23 this product, and they have a means of being able to 24 explain that to the consumer very thoroughly right 25 now.

(202)234-4433 

### NEALR. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234443337

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 sheets in the agenda, and I think we can run through a few of those and get into some more open discussion.

One of the first ones was "To what extent do the energy descriptors not account for total energy consumption of appliances?" Well, we're talking about furnaces and boilers, we know that, they don't account for electrical energy. I think we've answered that.

There's total agreement on that issue, is there not, on current test procedures?

The second question is "Do consumers have adequate means to calculate annual operating cost of appliances using current descriptors?" If I am correct, and I heard correctly around the room, there is means . Now, whether it's adequate or not is another issue , but there are means in the current side. Does anybody disagree with that, that the current procedures allow the calculation cost?

MR. WETHJE: I would back up, I think, Jack, and just -- Larry Wethje again from ARI. And the first question, I'm not sure I agree, depending on what we're talking about there, to what extent to the

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 37 1 MODERATOR LANGMEAD: Thank you, Larry. 2 Any other opening statements? 3 There were a few questions on the sheets 4 in the agenda, and I think we can run through a few of 5 those and get into some more open discussion. 6 One of the first ones was "To what extent 7 do the energydescriptors not account for total energy 8 consumptionofappliances?" Well, we'retalkingabout 9 furnaces andboilers, we knowthat, theydon't account 10 for electrical energy. I think we've answered that. ·11 There's total agreement on that issue, is

12 there not, on current test procedures? 13 The second question is "Do consumers have 

### 14 adequate means to calculate annual operating cost of 15 appliances using current descriptors?" If I am 16 correct, and I heard correctly around the room, there 17 is means. Now, whether it's adequate or not is 18 another issue, but there are means in the current 19 side. 20 Does anybody disagree with that, that the 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. And 24 the first question, I'mnot sure I agree, dependingon 25 what we're talking about there, to what extent to the

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44331 2 3 4 5

8 9 10 11 12 13 14 15 16. 17 18 19 20 21 22 23 24 25 38

efficiency descriptors not account for the total energy consumption of appliances. I think efficiency descriptors exist that do account for the total energy consumption of appliances. Perhaps not in the manner that everyone agrees with, but efficiency descriptors do exist that account for the electrical energy consumption because there is a way to account for that on a manual operating cost basis.

MODERATOR LANGMEAD: Larry, what I meant was the AFUE does not, and we've got agreement on that. Now, there's an energy factor that does do that, so there is an'issue we can come back to, but I just want to make sure we are trying to get down a few points we have agreement on, and certainly there is going to be other issues that we don't.

The next question on the list is "Is there a marketplace need for new descriptors? Now, several people addressed that in their opening remarks, particularly AGA, that the current things are confusing. Is there any other discussion on the marketplace need for new descriptors? We heard some 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) 234-4433 38 

### 1 efficiency descriptors not account for the total 2 energy consumption of appliances. I think efficiency 3 descriptorsexistthatdo account for thetotal energy 4 consumption of appliances. Perhaps not in the manner 5 that everyone agrees with, but efficiencydescriptors 6 ' do exist that account for the electrical energy 7 consumptionbecausethere is a way to account for that 8 on a manual operating cost basis. 9 

### MODERATOR LANGMEAD: Larry, what I meant 10 was the AFUE does not, and we've got agreement on 11 that. 12 Nbw, there's anenergyfactorthatdoesdo 13 that, so there is an issue we can come back to, but I 14 justwant to make surewe are trying to get down a few 15, 

### pOints we have agreement on, and certainly there is 16 going to be other issues that we don't. 17 Thenextquestiononthelistis "Isthere 18 a marketplace need for new descriptors? Now, several 19 people addressed that in their opening remarks, 20 

### particularly AGA, that the current things are 21 confusing. 22 Is there any other discussion on the 23 marketplace need for new descriptors? We heard some 24 that said there wasn't any need. 25 Frank?

(202)234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44332 3

5

7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 39 MR. JAKOB: Jack, may I present two or three of them?

MODERATOR LANGMEAD: That would be fine. Frank, why don't you try feeling that microphone and see if it will come on.

MR. JAKOB: I'm not sure that's connected with the sound system. I think that's connected with the tape recorder.

MODERATOR LANGMEAD: Okay. MR. JAKOB: Can you hear me, if I use my Walter Cronkite voice, in the back of the room? What I heard people say this morning is that what consumers see, and I'll just restrict my comments to furnaces. I'm Frank Jakob, I'm with Batelle Columbus Laboratories, and I'm here under the auspices of a projected sponsored by the Gas Research Institute.

What consumers see in terms of efficiency are gas furnaces that have minimum efficiency set at 78 and , if you look in the directory, it goes as high as 96.6 , there' s a range there. And for electric furnaces efficiency range from about 96 percent up to 98 percent . Those are the numbers in terms of AFUE and efficiency that they see.

What might be down here in the fine print and, if you look in terms of dollars per year for

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 39 1 

### MR. JAKOB: Jack, may I present two or 2 three of them? 3 

### MODERATOR LANGMEAD: That would be fine. 4 Frank, why don't you try feeling that microphone and 5 see if it will come on. 6 

### MR. JAKOB: I'm not sure that's connected 7 

### with the sound system. I think that's connected with 8 

### the tape recorder. 9 

### MODERATOR LANGMEAD: Okay. 10 

### MR. JAKOB: Can you hear me, if I use my 11 Walter Cronkite voice, in the back of the room? What 12 I heardpeople saythis morningis thatwhat consumers 13 see, and I'll just restrict my comments to furnaces. 14 I'm Frank Jakob, I'm with Batel1e Columbus 15 Laboratories, and I'm here under the auspices of a 16 projected sponsored by the Gas Research Institute. 17 What consumers see interms of efficiency 18 are gas furnaces that have minimum efficiency set at 19 78 and, if you look in the directory, it goes as high 20 

### as 96.6, there's a range there. And for electric 21 furnaces efficiencyrange from about 96 percent up to 22 98 percent. Those are the numbers in terms of AFUE 23 and efficiency that they see. 24 What might be down here in the fine print 25 and, if you look in terms of dollars per year for

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C.20005 (202)234-44332

5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 40

operation, those furnaces that had lower efficiencies cost a third to operate. That was the point I heard this morning. If you look on a full fuel cycle basis, it uses about a third of the energy. Those numbers are related because the amount that you pay is related to the total inventory of fuel.

Now, the point is, someone mentioned about the marketplace, is it asking for such things? If you look at the shipment data for electric furnaces and gas furnaces over the last couple of years, these are fossil fuel and electric furnace boilers, and this is shipment growth over that, that is each year we ship, we hopefully ship, more and more furnaces to bigger and bigger businesses. Last year there were almost as many electric furnaces shipped as there are condensing furnaces shipped.

And prior to 1992 that's an interesting year, something must have happened in 1992. Prior to 1992 you can see that shipment growth and electric furnaces was negative or.only slightly positive. The

same is true here in blue for gas furnaces as well. Starting in 1992 and for each of these three following year, '92, '93, '94, electric furnace shipments have been growing at 15 to 20 percent a year while fossil fuel furnaces have been growing an average about half

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 40 1 operation, those furnaces that had lower efficiencies 2 cost a third to operate. That was the point I heard 3 this morning. Ifyou look on a full fuel cyclebasis, 4 

### it uses about a third of the energy. Those numbers 5 arerelatedbecausethe amount thatyoupay isrelated 6 to the total inventory of fuel. 7 Now, thepOintis, someonementionedabout 8 the marketplace, is itasking for suchthings? Ifyou 9 look at the shipment data for electric furnaces and 10 gas furnaces over the last couple of years, these are 11 fossil .fuel and electric furnace boilers, and this is 12 shipment growth over that, that is each year we ship, 13 we hopefully ship, more and more furnaces to bigger

.14 and biggerbusinesses. Lastyeartherewere almost as

15 manyelectricfurnaces shipped astherearecondensing 16 furnaces shipped. 17 And prior to 1992 that's an interesting 18 year, something must have happened in 1992. Prior to 19 1992 you can see that shipment growth and electric 20**furnace~** 

### was negative**or~nly** 

### slightlypositive. The 21 same is true here in blue for gas furnaces as well. 22 Startingin 1992 and for eachof thesethree following 23 year, '92, '93, '94, electric furnace shipments have 24 been growing at 15 to 20 percent a year while fossil 25 fuel furnaces have been growing an average about half

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331 2 3

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 41

that. 1992 is when minimum efficiency rules went into effect. And 1992 is when gas furnaces suddenly cost 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, there were--put on the appliance; added cost, and that kind of changes the economics.

If you look at the appliance shipment data, year to date for this year, the same trend holds, that shipments, you know, the increase in shipments over the last year for electric furnaces is out pacing that of gas and oil furnaces. So in a way we might need another five years of data, but there's an indication there, I think, that something is happening in the marketplace and the consumers are buying the 98 percent efficient appliances.

Charlie? MR. ADAMS: Charlie Adams from Ducane. Just to clarify the devices of the -- blue is fossil fuel appliances for residential sizes, all shipments, all efficiency levels, is that correct?

MR. JAKOB: That's correct. MR. ADAMS: And the red is electrical 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) 234-4433 

### 41 1 that. 1992 iswhenminimumefficiencyruleswent into 2 effect. And 1992 is when gas furnaces suddenly cost 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, there 6 were--put on the appliance, added cost, and that kind 7 of changes the economics. 8 If you look at the appliance shipment 9 data, year to date for this year, the same trend 10 holds, that shipments, you know, the increase in 11 shipments over the last year for electric furnaces is 12 out pacing that of gas and oil furnaces. So in a way 13 we might need another five years of data, but there's 14 an indication there, I think, that something is 15 happening in the marketplace and the consumers are 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 fossil 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 electrical 24 furnaces and boilers and such things? 25

(202)234-4433 

### MR. JAKOB: Electricfurnaces andboilers, NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C.20005 (202)234-44331 2 3

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 42

yes, yes. That's the segregation that I found in Appliance magazine.

MODERATOR LANGMEAD: Go ahead, sir? MR. KELLY: George Kelly. Have you eliminated any other factors like availability of gas for instance in areas where construction is going on?

MR. JAKOB: No, I haven't. That would be a worthwhile further analysis to try to understand the meaning behind these trends.

MODERATOR LANGMEAD: Dave Lewis? MR. LEWIS: Dave Lewis, Lennox. Does that include boiler coil units?

MR. JAKOB: I don't believe so. I asked that question of GAMA. There's a listing, which the data is attributed to in Appliance magazine, there's a listing for gas furnaces and a separate listing for oil furnaces, a listing for gas boilers and oil boilers, electric boilers and electric furnaces, and I ask if that shipment data of electric furnaces includes fan coil units or not?

MR. LEWIS: Frank, it's my understanding that Appliance magazine, and what they are reporting is, what they're reporting is a little bit different today than what they were reporting some time ago because the difference there is your electric furnaces

(202) 2344433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 42 1 yes, yes. That's the segregation that I found in 2 Appliance magazine. 3 MODERATOR LANGMEAD: Go ahead, sir? 4 MR. KELLY: George Kelly. Have you 5 eliminated any other factors like availability of gas 6 for instance in areas where construction is going on? 7 MR. JAKOB: No, I haven't. That would be 8 a worthwhile further analysis totrytounderstand the 9 meaning behind these trends. 10 MODERATOR LANGMEAD: Dave Lewis? 11 MR. LEWIS: Dave Lewis, Lennox. Does that 12 include boiler coil units? 13 MR. JAKOB: I don't believe so. I asked 14 that question of GAMA. There's a listing, which the 15 data is attributed to in Appliance magazine, there's 16 a listing for gas furnaces and a separate listing for 17 oil furnaces, a listing for gas boilers and oil 18 boilers, electric boilers and electric furnaces, and 19 I ask if that shipment data of electric furnaces 20 includes fan coil units or not? 21 MR. LEWIS: Frank, it's my understanding 22 that Appliance magazine, and what they are reporting 23 is, what they're reporting is a little bit different 24 today than what they were reporting some time ago 25 becausethedifferencethereisyourelectricfurnaces

(202)234-4433 NEAL

### A. GROSS COURT REPORTERSANDTRANSCRIBERS**13~** RHODE ISLANDAVENUE, N,W. WASHINGTON, D.C.20005 (202)234-44331 2

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 43

now are really considered -- which previously were just air-handling units.

MR. JAKOB: Is that true? MR. RANFONE: I would like an answer to that because I know there's a traditional electric furnace that I'm familiar with, and then the fan coil units where resistance heat is added in the field. Is that covered, and if it isn't, that would really boost up the electric because I'm not sure that they're labeled. I was trying to get some labels for electric furnaces, but I can't seem to find any.

MODERATOR LANGMEAD: I'll remind everybody to identify yourselves before you speak so that we can figure out what's on the transcript later on.

MR. RANFONE: Jim Ranfone - MR. JAKOB: The number associated with this is 400,000 electric furnaces a year. Does someone know the number related to fan coil units to know whether that comprehends those or not?

MR. LEWIS: Dave Lewis, Lennox . I can't report to you the number , but I can say that what we report has changed because we technically no longer make electric furnaces , but yet at the same time we're supply product both in the gas and electric market. And in the electric market where gas is not available

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 43 

### 1 now are really considered

-- which previously were 2 just air-handling units. 3 

### MR. JAKOB: Is that true? 4 

### MR. RANFONE: I would like an answer to 5 that because I know there's a traditional electric 6 furnace that I'm familiar with, and then the fan coil 7 units where resistanceheat is added inthe field. Is 8 thatcovered, and ifitisn't, thatwouldreallyboost 9 up the electric because I'm not sure that they're 10 labeled. I was trying to get some labels for electric 11 furnaces, but I can't seem to find any. 12 MODERATORLANGMEAD: I'llremindeverybody 13 to identifyyourselves beforeyou speak sothatwe can 14 figure out what's on the transcript later on. 15 MR. RANFONE: Jim Ranfone

-- 16 MR. JAKOB: The number associated with 17 

### this is 400,000 electric furnaces a year. Does 18 someone know the number related to fan coil units to 19 know whether that comprehends those or not? 20 MR. LEWIS: Dave Lewis, Lennox. I can't 21 report to you the number, but I can say that what we 22 report has changed because we technically no longer 23 make electric furnaces, butyet at.the same timewe're 24 supply product both in the gas and electric market. 25 And in the electric market where gas is not available

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331

4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 44

and a heat pump is supplied, there is electric elements within the boiler coil unit which supplies heat under those conditions where the heat pump isn't operating, but those are now considered part of the electric furnace market. So there is a disparity as far as the information that you are presenting, not that it is put together inacurately, but as far as the means in which we're reporting information as far as what the marketplace is doing.

MR. JAKOB: So there are two points here, perhaps regionalization of this trend or perhaps segregation of what appliances are really considered electrical --

MODERATOR LANGMEAD: Well, I think it's what comparison of what was done before 1992 afterwards of 1992. The data was recorded differently. I think that was Dave's point.

MR. RANFONE: Jim Ranfone, AGA. What was the difference in the definition prior to 1992 and then after 1992 because -- key point, if this information is skewed because there has been a change in definition, we'd like to know what that change was that indicated that now electric furnaces or not electric furnaces -- it was or vice versa. Can 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) 234-4433 44 1 and a heat pump is supplied, there is electric 2 elements within the boiler coil unit which supplies 3 heat under those conditions where the heat pump isn't 

### 4 operating, but those are now considered part of the 5 electric furnace market. So there is a disparity as 6 far as the information that you are presenting, not 7 that it isput together inacurately, but as far as the 8 means in which we're reporting information as far as 9 what the marketplace is doing. 10 MR. JAKOB: So there are two points here, 11 perhaps regionalization of this trend or perhaps 12 segregation of what appliances are really considered 13 electrical 14 MODERATOR LANGMEAD: Well, I think it's 15 what comparison of what was done before 1992 16 afterwards of 1992. The data was recorded 

### 17 differently. 

### I think that was Dave's point. 18 MR. RANFONE: Jim Ranfone, AGA. What was 19 the difference in the definition prior to 1992 and 20 then after 1992 because key point, if this 21 information is skewed because there has been a change 22 in definition, we'd like to know what that change was 23 that indicated that now electric furnaces or not 24 electric furnaces it was or vice versa. 25 anybody supply that definition?

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 Can

(202)234-443345 MR. RYAN: Yes, just a quick point. I 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 change 6 in definition between 1991 and 1992 .you wouldn't be looking in a graph of that shape, instead you'd have 8 a spike in 1992 and far lower data in 1993 and '94. 9 Instead what you've got is a fairly consistent curve 10 there.. So whatever change there was seems to have 11 been buried in your numbers. The other concern seems 12 to be that you have the electric heating backup for 13 electric heat pumps. And these numbers of the 14 electric heat pump volume is on the order of a million 15 a year and you're not talking numbers in that range. 16 Clearly those numbers have not been integrated into 17 those numbers. 18 So there may be less unclarity here than 19 we thing. Whatever the change was between '91 and '92 20 it couldn't have been that dramatic, if you just 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're 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) 234-4433 45 

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

### 2 don't know 3 

### MODERATOR LANGMEAD: Your name, sir. 4 

### MR. RYAN: Pardonme. BillRyan from GRI. 5 Just a quickpOint, and that is, 

### if therewas a change 6 in definition between 1991 and 1992 you wouldn't be 7 looking in a graph of that shape, instead you'd have 8 a spike in 1992 and far lower data in 1993 and '94. 9 Instead what you've got is 

### a fairly consistent curve 10 there. So whatever change there was seems to have 11 been buried in your numbers. The other concern seems 12 to be that you have the electric heating backup for 13 electric heat pumps. And these numbers of the 14 electricheat pump volume is 

### onthe orderof a million 15 a year and you're not talking numbers in that range. 16 Clearly those numbers have not been integrated into 17 those numbers. \ 

### 18 So there may be less unclarity here than 19 we thing. Whatever thechangewas between'91 and'92 20 it couldn't have been that dramatic, if you just 21 concentrate on the '93 and '94 numbers. 22 MODERATOR LANGMEAD: Frank, canyouhelp? 23 MR. STANONIK: Frank Stanonik with GAMA. 24 No, I can't help because I don't know how we're 25 defining electric furnace in our statistics program.

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-443346 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 office

and I don't really know that question. And I was trying to let Frank Jakob go through his presentation here, but I am getting concerned that we're getting off track here. I mean we're talking about efficiency descriptors and there is a concern that people are being or getting the wrong message that a 98 percent electric furnace is. the superior product to a 78 percent or an 80 percent AFUE gas furnace or whatever.

But the point is, is if we're talking about efficiency descriptors, the reason that's happening is because they don't have the cost information or they're not getting the message on the cost information. And I would tell you that anybody who has only an electric furnace in their house and doesn't have gas available well knows, well knows, if they're in any kind of a winter climate area, the cost of operating that furnace, and they know it's a lot, okay. An so, if there is a problem here, the problem is that the people for whatever reasons are not getting information on the cost, the cost, of operation for them of that appliance, all right. And the fact is, that's got nothing to do with the 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) 234-4433 46 

### 1 I assume you've talked to someone else in our office 2 and I don't really know that question. And I was 3 trying to let Frank Jakob go through his presentation 4 here, but I am getting concerned that we're getting 5 off trackhere. I meanwe'retalking about efficiency 6 descriptors and there is a concern that people are 7 being or getting the wrong message that a 98 percent 8 electric furnace is the superior product to a 78 9 percentoran 80 percentAFUE gas furnace orwhatever. 10 But the point is, is if we're talking 11 about efficiency descriptors, the reason that's 12 happening is because they don't have the cost 13 information or they're not getting the message on the .14 

### cost information. And I would tell you that anybody 15 who has only an electric furnace in their house and 16 doesn't have gas availablewell knows, well knows, if 17 they're inanykindof a winterclimate area, thecost 18 of operating that furnace, and they know it's a lot, 19 okay. 20 An so, if there is a problem here, the 21 problem is that the people for whatever reasons are 22 not getting information on the cost, the cost, of 23 operation for them of that appliance, all right. And 24 the fact is, that's got nothing to do with the 25 efficiencydescriptorsofthis, itI S 

### one stepfarther,

(202)234-4433

, . NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON. D.C.20005 (202)234-44331 2 3

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 47

it's taking that efficiency descriptor and giving them the tools which in fact exist, they don't know it, but the tools that exist that say this is how you translate that to dollars, which is what I think we all believe the consumer really cares about.

MODERATOR LANGMEAD: Joe Mattingly, do you want to answer?

MR. MATTINGLY: Joe Mattingly. Let me just add to that, you know, the shipments data may be correct that Frank Jakob put on the screen there, but obviously he's got some fallibilities in his database there which have already been illuminated here. People may be buying electric furnaces for some

reason , but it isn't because they are looking at an electric furnace label versus a gas furnace label and deciding oh, well I'll buy the electric one. Because we sincerely believe that consumers don't make their purchase decision on the basis of AFUE labels on 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 think it's pointing to the fact that Americans buy first cost and maybe the $200.00 to $300.00 extra about to get the efficiency of gas furnaces up is increasing

(202) 2344433 

### NEAL 'R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, O.C. 20005 (202) 234-4433 47 

### 1 it'stakingthatefficiencydescriptorandgivingthem 2 the toolswhich in fact exist, theydon't know it, but 3 the tools that exist that say this is 

### how you 4 translate that to dollars, which is 

### what I think we 5 all believe the consumer really cares about. 6 MODERATOR LANGMEAD: JoeMattingly, doyou 7 want to answer? 8 

### MR. MATTINGLY: Joe Mattingly. Let me 9 just add to that, you 

### know, the shipments data may be 10 correct that Frank Jakob put on the screen there, but 11 obviouslyhe's got some fallibilities inhis database 12 there which have already been illuminated here. 13 People may be buying electric furnaces for some 14 reason, but it isn't because they are looking at an 15 electric furnace label versus a gas furnace label and 16 deciding oh, well I'll buy the electric one. Because 17 we sincerely believe that consumers don't make their 18 purchase decision on. the basis of AFUE labels on 19 furnaces. It has nothing to do with. 20 MODERATOR LANGMEAD: yes. 21 MR. MARRAN: JohnMarran, EnergyKinetics. 22 I think some of these factors are correct. I think

j 

### 23 it's pointing to the fact that Americans buy first 24 cost and maybe the $200.00 to $300.00 extra about to 25 get the efficiency of gas furnaces up is 

### increasing

(202)234-4433 

### NEALA.GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C.20005 (202)234-44331 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 48

the builder and the consumer purchase of the lower cost electric furnace and maybe what we really have to talk about is life cycle cost in evaluating the efficiency of equipment. And the consumer at this 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're going to make it ballast it has to show people life cycle cost of operating the appliance compared to its first cost. And those numbers would dramatically change if a person buying a house saw the appliance life cycle cost and they -- just a suggestion.

MODERATOR LANGMEAD : Yes, Dan? MR. DEMPSEY: Dan Dempsey , Carrier. I guess I would urge that the ship numbers be researched as to why there was a discrete jump. Because I know from Carrier's perspective,,if there was a significant jump in electric furnace shipments in the industry at the expense of other types of products, we would certainly be aware of that. And, you know, we don't have any data that indicates that there is a huge growing electric furnace market out there, so I would urge that the statistics be reviewed as to why the jump. It could be you have a manufacturer that started reporting in 92 that hadn't reported in years

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 48 

### 1 the builder and the consumer purchase of the lower 2 cost electric furnace andmaybe whatwe reallyhaveto 3 talk about is life cycle cost in evaluating the 4 

### efficiency of equipment. And the consumer at this 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're 8 going to make it ballast it has to show people life 9 cycle cost of operating the appliance compared to its 10 

### first cost. And those numbers would dramatically 11 change if a person buying a house saw the appliance 12 life cycle cost and they

-- just a suggestion. 13 

### MODERATOR LANGMEAD: Yes, Dan? 14 

### MR. DEMPSEY: Dan Dempsey, Carrier. I 

### 15 guess I wouldurge that the ship numbers beresearched 16 as to why there was a discrete jump. Because I know 17 fromCarrier'sperspective,

.iftherewas a significant 18 jump in electric furnace shipments in the**indust~** 

### at 19 the expense of other types of products, we would 20 certainly be aware of that. And, you know, we don't 21 have any data that indicates that there is a huge 22 growing electric furnace market out there, so I would 23 urge that the statistics be reviewed as to why the 24 

### jump. It could be you have a manufacturer that 25 startedreporting in '92 thathadn'treported inyears

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-443349

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 the apparent discontinuity in the data in '92. We shouldn't be lulled in to believing that the decision based on the information on the yellow hang tag had anything to do with that data in ' 92, accurate or not, because the efficiency number on the little bar scale showing where this appliance compares with other appliances, in '92 there was not a scale and was not 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 the American Gas Cooling Center. I want to just get us thinking, we're talking in the buggy whip days. What I mean by that is, we 're looking at today and past history. I know my brother from the HVAC industry will not publicly talk about this, so I'll put it on the table. The future of the HVAC industry is going to change like the energy industry. We now have a two tier distribution, and if you talk in the back rooms of what we're going to have in ten years or 15 years

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 49 

### 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 the 5 

### apparent discontinuity in the data in '92. 

### We 6 shouldn't be lulled in t9 believing that the decision 7 based on the information on the yellow hang tag had 8 .anything to do withthat data in '92, 

### accurateornot, 9 

### because the efficiency number on the little bar scale 10 showing where this appliance compares with other 11 appliances, in '92 

### there was not a scale and was not 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 the .16 

### American Gas Cooling Center. I want to just get us

17 thinking, we're talking in the buggy whip days. What 18 I mean by that is, 

### we're looking at today and past 19 

### history. I know my brother from the HVAC industry 20 will not publicly talk about this, so I'll put it on 21 the table. 22 The future of the HVAC industry is 

### going 23 tochange like theenergy industry. We now have a two 24 tier distribution, and if you talk in the back rooms 25 of what we're going to have in ten years or 15 years

(202)234-4433 

### NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C.20005 (202)234-44331 2 3

5 6

8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 50

is a one tier distribution system. You're already starting to see if when people who have companies like Home Depot. So even though we are currently going to market through dealers and distributors, we're probably going to have some changes in the future and we really should look forward with anything that we do, not backward. And we have to put that into consideration and that may make whatever types of labeling that we put on more important, not less important, when Home Depot people by the way, my Home Depot, when you can buy an split system today for a whole house. MODERATOR LANGMEAD: Let me just add, summarize some little points'that I've heard and you can try throwing rocks this way. I think we would all like to know and have some further analysis of the shipment data so that we have some confidence what's being shipped and how it compares to the past. We need some help in that way and hopefully we can figure out a way to get that job done.

Secondly, there is another need that's been expressed by virtually everybody and that is to find out exactly what motivates a consumer to make a choice between one furnace, one heating type and another. And we really haven't done that kind, or

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 50 1 is a one tier distribution system. You Ire already 2 startingto see ifwhen peoplewho have companies like 3 Home Depot. So even though we are currently going to 4 market through dealers and distributors, we're 5 probably going to have some changes in the future and 6 we really should look forward with anything that we 7 do, not backward. And we have to put that into 8 consideration and that may make whatever types of 9 labeling that we put on more important, not less 10 important, when Home Depot people by the way, my Home 11 Depot, when you can buy an split system today for a 12 whole house. 13 MODERATOR LANGMEAD: Let me just add, 14 summarize some little points'that I've heard and you 15 can try throwing rocks this way. I think wewould all 16 like to know and have some further analysis of the 17 shipment data so that we have some confidence what's 18 being shipped and how it compares to the past. We 19 need somehelp in that way and hopefullywe can figure 20 out a way to get that job done. 21 Secondly, there is another need that's 22 been expressed by virtually everybody and that is to 23 find out exactly what motivates a consumer to make a 24 choice between one furnace, one heating type and 25 another.

(202)234-4433 And we really haven't done that kind, or 

### NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-443351

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 a number of times, I don't think the label on the furnace is what's making that choice. But there is something making that choice, and we need to know what that is so we can properly communicate with consumers.

Dave Lewis? MR. LEWIS: Dave Lewis of Lennox. One thing we did before we came to this meeting was to kind of study when people were purchasing what product. And it's very clear, Jack, that our sales of Pultz furnaces were dynamics during a period of time when we had an energy oil crisis.

When the cost of energy and the awareness of the cost of 'energy was escalating dynamically, consumers were making a decision based on the information that they had at that time, and interestingly that same information remains available today. So at least from our review of our sales data, we're seeing that consumers do make a decision based 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 gas 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) 234-4433 

### 51 1 collectively put that together. 2 I tend to agree with what's been said a 3 number of times, I don't think the label on the 4 

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

### 5 somethingmaking thatchoice, andwe needto know what 6 that is sowe canproperlycommunicatewithconsumers. 7 Dave Lewis? 8 

### MR. LEWIS: Dave Lewis of Lennox. One 9 thing we did before we came to this meeting was to 10 kind of study when people were purchasing what 11 product. And it'sveryclear, Jack, that our sales of 12 Pultz furnaces were dynamics during a period of time 13 when we had an energy oil crisis

.

.14 When the cost of energy and the awareness 15 of the cost of energy was escalating dynamically, 16 consumers were making a decision based on the 17 

### information that they had at that time, and 18 interestinglythat same informationremains available 19 today. So at least from ourreviewof our sales data, 20 we're seeing that consumers do make a decision based 21 on what it costs them to operate their appliance. 22 Now, there is a one disconnect in that, 23 and that is 

### where gas isn't available, obviously gas 24 products are not purchased. 25

(202)234-4433 

### MODERATOR LANGMEAD: Yes, Jim? NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331 2 3 4

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 52 MR. RANFONE: Jim Ranfone again. I just wanted to clarify a couple of things at least from our perspective. One, the data that was presented apparently people are taking issuewith it, but it was presented based on industry input, not AGA's input. We looked at data, in fact I've got projections that have been brought out for the next five years on electric furnaces, electric warm air furnaces, that 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 an 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 -- this 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, the labels are physically going to be put on units and they are going to show a 98 percent, 100 percent 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) 2344433 52 

### 1 MR. RANFONE: Jim Ranfone again. I just 2 wanted to clarifya coupleof things at least from our 3 

### perspective. One, the data that was presented 4 apparentlypeople are taking issuewithit, but itwas 5 presented based on industry input, not AGA's input. 6 We looked at data, in fact I've got projections that 7 have been brought out for the next five years on 8 electric furnaces, electric warm air furnaces, that 9 have been presented that show an increase. So before 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 an 13 electricwarm airfurnace is, ifthat I

### s different than 14 it was in 1992, we'd like to know about it. I think 15 the point that Frank was making is that there is a 16 trend upward. 17 Number 'two, on the label itself, our 18 

### concern is that the label is now going this 19 December and one year prior to that they weren't 20 labeled. That's the issue. Whether you believe in 21 the effectiveness of labeling problem or not, the 22 labels are physically going to be put on units and 23 they are going to show a 98 percent, 100 percent 24 electricfurnace AFUE number. That'swhatourconcern 25 is, notwhat happened in 1992 iftheyweren't labeled,

(202)234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202)234-44331 2 3 4 5 6

8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 53

that the coming products -- what are we going to say five years from now, oh yes, by the way the labeling 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 all the technical details for you and what it's going to cost, what it's going to cost to operate and so on and so forth. And there was a time when a large number of products were sold by home delivery right down to milk, but those days are no longer.

There is a 'very strong indication, it's not a sure thing, but there's a strong indication that there is going to be a large market segment in the future which involves the consumer going to a store, Home Depot, Sears, whatever, and standing in front of a long line of furnace and air conditioning products and deciding, and this store may do installation, someone else may do installation, whatever, the consumer would be confronted with this selection

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 53 1 that the coming products

-- what are we going to say 2 five years from now, oh yes, by the way the labeling 3 program was effective, they are buying a lot more 4 electric furnaces. 5 MODERATOR LANGMEAD: Yes? 6 MR. RYAN: Bill Ryan from Gas Research 7 again. Just a bit of clarification or I just wanted 8 to add to Rich's comment. In the past the standard 9 way of buying furnaces and air conditions has been 10 that you have the dealer come into your home and 11 presentyou withyouroptions and tryto translate all 12 the technical details for you and what it's going to 13 cost, what it's going to cost to operate and so on and 14 so forth. And there was a time when a largenumber of 15 products were sold by home delivery right down to 16 milk, but those days are no longer. 17 There is a very strong indication, it's 18 not a surething, but there's a strong indicationthat 19 there is going to be a large market segment in the 20 future which involves the consumer going to a store, 21 Home Depot, Sears, whatever, and standing in front of 22 a long line of furnace and air conditioning products 23 and deciding, and this store may do installation, 24 someone else may do installation, whatever, the 25 consumer would be confronted with this selection

(202) 234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C.20005 (202)234-44331 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 54

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 for 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 appliances 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 think what's being presented is a great idea, I just don't see any data that documents that that is in fact the 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 that are too large or too small to adequately take care of the comfort of the space that they need.

I think the real key is rather than mass merchandising, what we're really seeing in the marketplace today is much more nitch marketing, which means that the product is applied to the specific need

(202) 234

-44.'33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 54 1 retail. And what he's going to see is a large 2 collection of gray boxes and yellow tags with these 3 numbers on them, and no really to translate them for 4 him. 5 That makes the yellow tags perhaps more 6 important inthe future thanthey'vebeen inthepast. 7 And, therefore, I think a point where we have to 8 really ask serious questions about how communicative 9 thesethings are across theentirerangeof appliances 10 to the consumer that is not all that familiar with a 11 once or twice in a lifetime decision of buying a 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't 16 see any data that documents that that is in fact the 17 trend that's occurring. In fact contrary to that, 18 consumers need to buy products that fit the home, not 19 genericcookie-cutterproductsthatmaybeboughtthat 20 are too large or too small to adequately take care of 21 the comfort of the space that they need. 22 I think the real key is rather than mass 23 merchandising, what we're really seeing in the 24 marketplace today is much more nitchmarketing, which 25 means that the product is applied tothe specificneed

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323RHODE ISLANDAVENUE, N,W. WASHINGTON, D.C. 20005 (202)234-443355

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. So

contrary to what has been presented as far as a long line of furnaces, all of which would have beautiful yellow tags on that they could make decisions off of, we see instead a much wiser consumer that's making the purchase that meets the need of their specific requirements.

MODERATOR LANGMEAD: Let me try covering just one more thing, and I think we're going to come back into this thing, but I think we' ve got some agreement on some things that DOE or that industry can do, and I' d like to get those kind of agreements down.

I'm not criticizing Frank Jakob' s data on shipments or sales, but I think everybody would have

more comfort in the numbers if we had a good clear picture of what the sales pattern was in the past as compared to today. `

Does anybody have any objection to that being an agreement out of this thing, not criticizing what' s there , but just you'd like a little better understanding that we' ve compared apples to apples.

The second point being that -- I'll get him in just a minute . The second point being that there is some need -- I don't know how much FTC has done in looking at motivation of consumers in buying

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 55. 

### 1 of the consumer rather,than one product fits all. So 2 contrary to what has been presented as far as a long 3 line of furnaces, all of which would have beautiful 4 yellow tags on that they could make decisions off of, 5 

### we see instead a much wiserconsumerthat'smakingthe 6 purchase that meets the need of their specific 7 requirements. 8 

### MODERATOR LANGMEAD: Let me try covering 9 just one more thing, and I think we're going to come 10 back into this thing, but I think we've got some 11 agreement on somethings that DOE orthat industrycan 12 do, and I'd liketo get thosekind of agreements down. 13 I'm not criticizingFrank Jakob's dataon 14 shipments or sales, but I think everybody would have 15 more comfort in the numbers if we had a good clear 16 picture of what the sales pattern was in the past as 17 compared to today. 18 Does anybody have any objection to that 19 being an agreement out of this thing, not criticizing 20 what's there, but just you'd like a little better 21 understanding that we've compared apples to apples. 22 The second point being that I'll get 23 him in just a minute. The second point being that 24 there is some need

-- I don't know how much FTC has 25 done in looking at motivation of consumers in buying

(202)234-4433 NEAL

### A. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-44331 2 3 4

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 56

particularly furnaces or air conditioners, whether that label does anything for those people. Certainly the label is going to be there.. If there was market research done to see what motivated homeowners in purchases, what motivated builders in purchases, what motivated the decision in high rise buildings versus single story building versus townhouses, that data would all be useful in better designing of whatever label is going to be on there sometime in the future.

Can I get any understanding that that is also something that would be valuable for everybody to have so we're all making decisions off of a good sound database? Unless somebody shoots me, we'll count on that. Frank, you had a point on the first one?

MR. STANONIK: Yes, I take exception to the first one about it would be interesting to get better clarification on the graph. And my question 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 annual shipments, we're talking about shipments of just gas furnaces of what, about 2 million a year?

So obviously if I -- the other thing that 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) 234-4433 56 

### 1 particularly furnaces or air conditioners, whether 2 that label does anything for those people. Certainly 3 the label is going to be there. If there was market 4 research done to see what motivated homeowners in 5 purchases, what motivated builders inpurchases, what 6 motivated the decision in high rise buildings versus 7 single story building versus townhouses, that data 8 would all be useful in better designing of whatever 9 label is going to be on there sometime in the future. 10 Can I get any understanding that that is 11 also something thatwouldbevaluable foreverybodyto 12 have sowe're allmaking decisions off of a good sound 13 database? Unless somebody shoots me, we'll count on 14 that. 15 Frank, you had a point on the first one? 16 

### MR. STANONIK: Yes, I take exception to 17 the first one about it would be interesting to get 18 better clarification on the graph. And my question 19 would be why? The graph showed you relative growth, 20 all right, so the discussion we're talking about, 21 howeverit'sdefined, 400,000electricfurnaces annual 22 shipments, we're talking about shipments of just gas 23 furnaces of what, about 2 million a year? 24 So obviously if I

-- the other thing that 25 you lose there is the gas furnaces aren't going down.

(202)234-4433 

### NEALA. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C.20005 (202)234-44332 31 4!

12 13 14 15 16 17 18 19 20 21 22 23 24 25 57

All right, 2.5 million. The shipments of gas furnaces are not going down. But if my base is 400,000 rather than 2.5 million, well then a growth of 100,000 looks much bigger, and that's what you're seeing. And my question is, what's the point of that?

The fact is that gas furnace shipments are still going up, they're not -- it doesn't appear to be suffering in direct or any proportion to this apparent growth in electric furnaces.

And the other significant thing is, if you look at new housing starts, new ,housing starts, gas heating dominates, which again seems to counteract. So what's the point of this issue? I don't see the relevancy and why discuss it further.

MODERATOR LANGMEAD: Well, let me just answer you, if I can, briefly on that. I've talked to a lot of furnace manufacturers that make gas furnaces, oil furnaces, and electric furnaces, and I haven't found anybody yet that told me that they thought the electric furnace industry was expanding at some great rate. And I guess I want to get a handle, I think it would be good to have a handle on that because Frank's data shows something otherwise.

Dan? MR. DEMPSEY: Dan Dempsey, Carrier. I

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 57 Ii All right, 2.5 million. The shipments of gas furnaces 2 are not going down. But if my base is 400,000 rather 3 than 2.5 million, well then a growth of 100,000 looks

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

I

9 

# 101 I 11 12 question is, what's the point of that? The fact is thatgas furnace shipmentsare still going up, they're not

-- it doesn't appear tobe sufferingindirector anyproportionto this apparent growth in electric furnaces. And theothersignificantthingis, ifyou look at new housing starts, new ,housing starts, gas heating dominates, which again seems to counteract. 13 So what's the point of this issue? I don't see the 14 relevancy and why discuss it further. 15 MODERATOR LANGMEAD: Well, let me just 16 answeryou, if I can, briefly onthat. I've talked to 17 a lotof furnace manufacturers thatmake gas furnaces, 18 oil furnaces, and electric furnaces, and I haven't 19 found anybody yet that told me that they thought the 20 electric furnace industrywas expanding at some great 21 rate. And I guess I want to get a handle, I think it 22 would be good tohave a handle on thatbecause Frank's 23 data shows something otherwise. 24 Dan? 25 MR. DEMPSEY: Dan Dempsey, Carrier. I

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W, WASHINGTON. D,C. 20005 (202)234-44331 2 3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 58

guess the other issue in the statistics is, is it replacement market or new construction? If it's replacement market, then AFUE or whatever it's labeled, can be sold. But if it isn't replacement market then, you know, there may not be gas available because it's replacing an old electric furnace. If it's a new construction market, that's sold to the builders, so really you need to know whether those statistics are biased towards replacement or new construction.

MODERATOR LANGMEAD: And you've got to look at them segmented into new replacement, high rise, single family, etcetera, so you know what's going on. Gene Margolis?

MR. MARGOLIS: Eugene Margolis, Department of Energy, Office of General Counsel. If this graph is a graph of the growth, could we also have one of just of sales to see what the volume of a electric furnaces sold as against the volume of gas furnaces sold per year?

My second point is that , if it' s being 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, I

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 58 1 guess the other issue in the statistics is, is it 2 replacement market or new construction? If it's 3 replacement market, then AFUE or whatever it's 4 labeled, can be sold. But if it isn't replacement 5 market then, you know, there may not be gas available 6 because it's replacing an old electric furnace. If 7 .it 's a new construction market, that's sold to the 8 builders, so really you need to know whether those 9 statistics are biased towards replacement or new 10 construction. 11 MODERATOR LANGMEAD: And you've got to 12 look at them segmented into new replacement, high 13 rise, single family, etcetera, so you know what's 14 going on. 15 Gene Margolis? 16 MR. MARGOLIS: EugeneMargolis, Department 17 of Energy, Office of General Counsel. If this graph 18 is a graph of the growth, could we also have one of 19 just of sales to see what the volume of a electric 20 furnaces sold as against the volume of gas furnaces 21 sold per year? 22 My second point is that, if it's being 23 trying to say that the growth of electric furnaces 24 over gas furnaces is because of the higher AFUE value 25 on electric furnaces and a lower on gas furnaces, I

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202)234-44332 3

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 59

don't think that just by showing the growth rate would be quite to the reasons why. And the reason why being said that it's the higher AFUE for electric. I don't think that one necessitates the other.

And my final point is, if the discussion is going away from the energy -- well, going away from the energy descriptor and talking about ,what information is on the label, then I believe this is not the place for that. It is before the FTC because the FTC is the sole authority on labeling, and I thought one of the things that we were talking about here is a possible new energy efficiency descriptors that would take into consideration the electric energy being used in a gas furnace. And I understand what the gas people -- that it lowers the AFUE, but it doesn't do anything to the electric. And that, I

mean, is what the law says , that we' re supposed to use site and not source.

So I want to get back to the other point of the labeling where people were talking about maybe the information on the label might be "one-sided," then maybe , if that's what you really feel, then maybe you can come up with some way that would be okay with the Federal Trade Commission to somehow balance those two appliances, gas and electric, or an oil furnace

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 59 

### 1 don't think thatjustby showing thegrowthratewould 2 be quite to the reasons why. And the reason why being 3 said that it's the higher AFUE for electric. I don't 4 think that one necessitates the other. 5 And my final point is, if the discussion 6 isgoing away from the energy -- well, going away from 7 the energy descriptor and talking about ,what 8 information is on the label, then I believe this is 9 not the place for that. It is before the FTC because 10 the FTC is the sole authority on labeling, and I 11 thought one of the things that we were talking about 12 here is a possible new energy efficiency descriptors 13 thatwouldtakeintoconsiderationtheelectricenergy 14 being used in a gas furnace. And I understand what 15 the gas people

-- that it lowers the AFUE, but it 16 doesn't do anything to the electric. And that, I 17 mean, iswhat the law says, thatwe're supposed touse 18 site and not source. 19 So I want to get back to the other point 20 of the labeling where people were talking about maybe 21 the information on the label might be "one-sided," 22 thenmaybe, if that'swhatyou really feel, thenmaybe 23 you can corne up with some way that would be okay with 24 the Federal Trade Commission to somehowbalance those 25 two appliances, gas and electric, or an oil furnace

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-443360

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 to 4 talk about here the energy descriptors.

MODERATOR LANGMEAD: Anybody want to respond to Gene?

Dave Lewis? MR. LEWIS: Dave Lewis, Lennox. There is basic inaccuracy in the assumption that people make decisions in buying their furnace based on the data of the yellow label. And I guess that needs to be corrected. People are not making that decision by a yellow label. They don't see the yellow label until it's installed in the house. So I think the more we focus on the yellow label, which is fraught with 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 decisions have not been made on the yellow label in the past. And our experience in air conditioning, which is not the topic here is that decisions are not made on the 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) 234-4433 60 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 to 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 is 9 

## abasic inaccuracy in the assumption that people make 10 decisions inbuyingtheir furnace based on thedata of 11 the yellow label. And I guess that needs to be 12 corrected. People are not making that decision by a 13 yellow label. They don't see the yellow label until 14 it's installed in the house. So I think the more we 15 focus on the yellow label, which is fraught with 16 inaccuracyas far as theunderlying assumptionthat it 17 actually has value, I think we're wasting our time. 18 I think much better, we need to be addressing some of 19 the issues outside of that because actuallydecisions 20 have not been made on the yellow label in the past. 21 And our experience in air conditioning, which is not 22 the topic here is that decisions are not made on the 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 COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-443361 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 some information on how consumers make decisions. -- we used to field a lot of questions on what type furnace we should should buy and so on and so forth, not so much anymore. But I never encountered a consumer that did not realize that the cost of electric energy was three times the cost of gas. And even it said 98 or even if it said 200 efficiency on the label, they were 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 it wasn't, then they would consider whether they wanted a heat pump or an electric furnace and what the first cost was versus the operating cost.

But that efficiency of 98 percent in an 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. We have reason to believe, or I have reason to believe 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) 234-4433 61 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 some 5 

### information on how consumers make decisions.

-- we 6 used to field a lot of questions on what type furnace 7 we should should buy and so on and so forth, not so 8 muchanymore. But I neverencountered a consumerthat 9 did not realize that the cost of electric energy was 10 three times the cost of gas. And even it said 98 or 11 even if it said 200 efficiencyonthe label, theywere 12 not going to buy electric unless they had to. 13 So they'd look at whether gas was 14 available or oil was available in their area, and it 15 wasn't, then they would consider whether they wanted 16 a heat pump or an electric furnace and what the first 17 cost was versus the operating cost. 18 But that efficiency of 98 percent in an 19 electric furnace, I don't think ever swayed somebody 20 to buy an electric furnace over a gas furnace. 21 MODERATOR LANGMEAD: Charlie Adams? 22 MR. ADAMS: Charlie Adams, Ducane. We 

### 23 have reason to believe, or I have reason to believe 24 that some of presumably magnificent growth in the 25 electric furnace rate of increase, at least for the

(202) 234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, NW.

, WASHINGTON, D.C. 20005 (202)234-443362 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 jump in '92 when the lower cost gas appliances, the 72 percent draft equipment went away and 78 became the minimum, the standard cost of a cheap furnace went up dramatically. There was a substantial portion of people out there and it doesn't matter what the efficiency is, my heating, appliance broke and I got to go buy a new one, and I can only spend (x) dollars, and that's where I believe some of that first year ripple of stupendous grown Ken put on the chart may be related to. I don't care what the efficiency is or what it cost to run, I only have this much money to buy a new one, so. Let's not get too confused about that ripple in the data.

MODERATOR LANGMEAD: Other comments? Yes? MR. FRITTS: On this discussion of the descriptor or what do we need to talk about, how does the descriptor lead to the label, I know Batelle has done some interesting work on combining or integrating ,costs and energy. And if you'd give Frank Jakob a few more minutes, I think he could summarize that. And I

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON, D.C. 20005 (202) 234-4433 62 

### 1 post'92 timeframe, is directly related to that, 2 related to not caring about whether it's more 3 efficient, less efficient, or whatever. 4 We have reasontobelievetherewas a jump 5 in'92 when the lower cost gas appliances, the 72 6 percent draft equipment went away and 78 became the 7 minimum, the standard cost of a cheap furnace went up 8 

### dramatically. There was a substantial portion of .9 

### people out there and it doesn't matter what the 10 efficiencyis, my heatingappliancebroke and I got to 11 go buy a new one, and I can only spend (x) dollars, 12 and that's where I believe some of that first year 13 rippleof stupendous grownKen put onthe chartmaybe 14 

### related to. I don't care what the efficiency is or 15 what it cost to run, I only have this much money to 16 buy a new one, so. Let's not get too confused about 17 that ripple in the data. 18 MODERATOR LANGMEAD: Other comments? 19 Yes? 20 

### MR. FRITTS: On this discussion of the 21 descriptor or what do we need to talk about, ho.w does 22 the descriptor lead to the label, I know Batelle has 23 done someinterestingworkoncombiningorintegrating 24 \costs and energy. And ifyou'd give Frank Jakob a few 25 more minutes, I think he could summarize that. And I

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44331

4 5 6 7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 63

think it's worth putting it on the table at least for discussions purposes. Go you want to give him three 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'll let Frank go ahead now. I think we have time.

MR. FRITTS: Can we get a explanation for 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 as far back as I could find them in our files, '87 through recently. And -- set of bars are -- first shipments over time. This set of bars are the heat pump shipments over time. This considers central 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 condensing furnaces over time. Each year they publish not only the total number of shipments, but the division mid efficiency and high efficiency break that out and this is the point on electric furnaces.

And what Frank Stanonik said earlier is

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 63 1 

### think it's worth putting it on the table at least for 2 discussions purposes. Go you want to give him three 3 minutes? 4 

### MODERATOR LANGMEAD: That's fine withme. 5 

### I think we've got

-- it's 10:20 and we're going to 6 

### quite this discussion at 11:00 o'clock. We've got 7 

### just a couple more subjects to touch on, and so I'll 8 

### let Frank go ahead now. I think we have time. 9 

### MR. FRITTS: Canwe get a explanation for 10 this? 11 

### MR. JAKOB: You had asked for an 12 explanation of the shipment data, and this I took out 13 of Air Conditioning News and Appliance magazines as 14 far back as I could find them in our files, '87 15 through recently. And

-- set of bars are -- first 16 shipments over time. This set of bars are the heat 

### 17 pump shipments over time. This considers central 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 condensing 21 furnaces over time. Each year they publish not only 22 the total number of shipments, but the division mid 23 efficiencyandhighefficiencybreakthatout andthis 24 is the point on electric furnaces. 25 And what Frank Stanonik said earlier is

(202) 234-4433 

### NEALR. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44331 2

5 6

8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 64

true, that in terms of relative numbers there were 300,000 here and maybe 300,000 here or 400, 000, and so the relative growth is bigger with the smaller actual number of units, but the main point is when it gets back. to energy descriptors is each one of those electric furnaces consumes total energy, the input energy, the oil energy that's the interest -- of three condensing furnaces. So every one of those electric furnaces is consuming three times as much energy as a condensing furnace.

And so in terms of the overall volume of energy impact on the country, that's significant. And if that's growing at twice the rate of gas furnaces over time, five, six years, you're going to see a magnificent impact on our U.S. total energy consumption, if these trends continue. And there is no indication from the data to date that they're turning down.

MODERATOR LANGMEAD: Are there any responses to that?

Dan? MR. DEMPSEY: Dan Dempsey, Carrier again. I guess I go back to my replacement market scenario in that you've got a certain install population of electric furnaces, and you go back to '87 it's pretty NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234

.4433 WASHINGTON, D.C. 20005 (202) 234-4433 64 1 true, that in terms of relative numbers there were 2 300,000here andmaybe 300,000 hereor400,000, and so 3 the relative growth is bigger with the smaller actual 4 number of units, but the main point is when it gets 5 back to energy descriptors is each one of those 6 electric furnaces consumes total energy, the input 7 energy, theoil energythat's the interest

-- of three 8 condensing furnaces. So everyone of those electric 9 furnaces is consuming three times as much energy as a 10 condensing furnace. 11 And so in terms of the overall volume of 12 energyimpact onthecountry, that's significant. And 13 if that's growing at twice the rate of gas furnaces 14 over time, five, six years, you're going to see a 15 magnificent impact on our 

## u.S. total energy 16 consumption, if these**tr~nds** continue. And there is 17 no indication from the data to date that they're 18 turning down. 19 MODERATOR LANGMEAD: Are there any 20 responses to that? 21 Dan? 22 MR. DEMPSEY: Dan Dempsey, Carrier again. 23 I guess I goback tomy replacementmarket scenario in 24 that you've got a certain install population of 25 electric furnaces, and you go back to '87 it's pretty

(202)234-4433 NEAL

### A. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C.20005 (202)234-443365 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 it

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's going to cycle as the previous year's trends that existed. MODERATOR LANGMEAD: I saw another hand go up over here.

Yes? MR. YOUNG: Maybe somebody could -- MODERATOR LANGMEAD: Would you introduce yourself please?

MR. YOUNG: Oh, Dave Young, Ontario Hydro. Maybe somebody from EEI could comment on this, but I just heard a statement from Frank that was saying that one hundred percent of the electricity in the United States comes from the generating stations fired with oil or with gas. And I don't think I approve --

MODERATOR LANGMEAD: Good point. MR. YOUNG: -- and it certainly isn't true in Canada. And maybe I could get the ratio for the U.S.? MODERATOR LANGMEAD: Matt, do you want to address that?

MR. CHWALOWSKI: Just for an issue, 57

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 65 1 significant. And the question would be, what was it 2 ten years prior to that because, if gas is not 3 available, you're going to have a fixed amount of 4 market for replacingthoseelectricfurnaces, and it's 5 going to cycle as the previous year's trends that 6 existed. 7 MODERATOR LANGMEAD: I saw anotherhandgo 8 up over here. 9 Yes? 10 MR. YOUNG: Maybe somebody could

-- 11 MODERATOR LANGMEAD: Would you introduce 12 yourself please? 13 MR. YOUNG: Oh, DaveYoung, OntarioHydro. 14 Maybe somebody from EEl could comment on this, but I 15 justheard a statement from Frankthat was sayingthat 16 one hundred percent of the electricity in the United 17 States comes from the generating stations fired with 18 oil or with gas. And I don't think I approve 19 MODERATOR LANGMEAD: Good point. 20 MR. YOUNG:

-- anditcertainlyisn'ttrue 21 in Canada. And maybe I could get the ratio for the 22 U.S.? 23 MODERATOR LANGMEAD: Matt, do you want to 24 address that? 25

(202)234-4433 MR. CHWALOWSKl: Just for an issue, 57 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C. 20005 (202)234-44331 2

5 6

9 10 11 12 13- 14 15 16 17 18 19 20 21 22 23 24 25 66

percent of electricity is generated by coal. About eight percent, and again it depends on -- about eight percent by natural gas, ten percent by hydro, 20 percent by nuclear, and nationally about four percent by oil. On the Eastern Seaboard it's different. I didn't report -- that you ordered oil or gas is maybe not the issue here.

MODERATOR LANGMEAD: Dave Lewis? MR. LEWIS: Dave Lewis, Lennox. I think the last point is a good one, and I think additionally it needs to be looked at, that it depends on where you are within the United States as far as what power generating actually what exists. And it isn't as though•a consumer has a choice between connectingtheir 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 in 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) 234-4433 66 1 percent of electricity is generated by coal. About 2 eight percent, and again it depends on -- about eight 3 percent by natural gas, ten percent by hydro, 20 4 percent bynuclear, and nationally about four percent 5 by oil. On the Eastern Seaboard it's different. I 6 didn't report thatyou ordered oil or gas ismaybe 7 not the issue here. 8 MODERATOR LANGMEAD: Dave Lewis? 9 MR. LEWIS: Dave Lewis, Lennox. I think 10 the lastpoint is a good one, and I think additionally 11 itneeds tobe looked at, that itdepends onwhere you 12 are within the United States as far as what power 13 generating actually what exists. And it isn't as 14 though' a consumer has a choice between connecting 15 their power cord to a cogenerating plant or a hydro16 generating plant, therefore, it's a little bit 17 stretching the issue to try to compare our tremendous 18 energy dilemma today all to the electric furnace. 19 I think much more it has to do with 20 whether natural gas is available and especially in 21 that retrofit situation, if there isn't natural gas 22 available, it surely will go to the only other 23 alternative that is. 24 25

(202)234-4433 MODERATOR LANGMEAD: That's oil? Okay. MR. LEWIS: Maybe. 

### NEALR. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44332 3

5 6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 67 MODERATOR LANGMEAD: Frank, you had some other points that you wanted to get into on different descriptors?MR. JAKOB: This morning Cyrus and George quoted some interesting equations that look at the way DOE had proposed an energy descriptor -- And what I did here was just a simple power matrix study. You take those equations and here is a 90 percent AFUE condensing furnace. Here is an 80 percent AFUE mid efficiency furnace. And here is a 78 AFUE minimum efficiency furnace. And what you look at is how the energy factor as defined by DOE would vary depending on how much electricity a furnace uses.

And in general about two to six percent of a furnace's site energy consumption is electricity. That number is easily deduced from the data that's available for furnaces. Every library apparently has a GAMA directory where a consumer can go and look up any furnace's electric or gas consumption.

Now, what happens is that with the efficiency descriptor as defined, as you increase the amount of electricity for whatever reason, sometimes as you increase electrical consumption because you have a less efficient motor, that's an efficiency the DOE has added in. Most of the time you increase

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 67 1 MODERATOR LANGMEAD: Frank, you had some 2 other points that you wanted to get into on different 3 descriptors? 4 MR. JAKOB: This morning Cyrus and George 5 quoted some interestingequations thatlook attheway 6 DOE had proposed an energy descriptor And what I 7 did here was just a simple power matrix study. You 8 take those equations and here is a 90 percent AFUE 9 condensing furpace. Here is an 80 percent AFUE mid 10 efficiency furnace. And here is a 78 AFUE minimum 11 efficiency furnace. And what you look at is how the 12 energy factor as defined by DOE would vary depending 13 on how much electricity a furnace uses. 14 And ingeneral about twoto sixpercentof 15' a furnace's site energy consumption is electricity. 16 That number is easily deduced from the data that's 17 available for furnaces. Every library apparently has 18 a GAMA directory where a consumer can go and look up 19 any furnace's electric or gas consumption. 20 Now, what happens is that with the 21 efficiencydescriptor as defined, asyou increase the 22 amount of electricity for whatever reason, sometimes 23 as you increase electrical consumption because you 24 have a less efficient motor, that's an efficiency the 25 DOE has added in. Most of the time you increase

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-44331 2 3 4

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 68

electrical consumption because in a small furnace you put in a big air handler, and that big air handler is 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 to vents perhaps that's come on the table where right now these numbers very easily convey to an installer what sort of venting system he should. put on the appliance to get BPC or B vent. But if they all had the same numeric value, then it becomes a little more confusion issue , and that's something that we're looking to 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) 234-4433 68 1 electrical consumption because in a small furnace you 2 put in a big air handler, and that big air handler is 3 there. It can handle a five ton load perhaps in the 

### 4 summer, but then you've got to carry that amount of 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 that 10 a condensing furnace with a big enough air handler 11 would end up having the same energy factor as a mid or 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 tablewhere right now



### 18 these numbers very easily convey to an installer what 19 sort of venting system he should.put on the appliance 20 to get BPC or B vent. But if they all had the same 

### 21 numericvalue, thenitbecomes a littlemore confusion 22 issue, and that's something that we're looking to 

### 23 eliminate. 24 

### 25

(202)234-4433 MODERATOR LANGMEAD: Dan? MR.DEMPSY: Dan Dempsy, Carrier. 

### NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 I'd

(202)234-44331

3 4 5

7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 69

just like to point out in that hypothetical example that to have a 80 AFUE unit that has a higher energy factor than the 90 AFUE unit, the 80 AFUE unit would likely cost more to produce because the technology requires to get the electrical consumption down that low is not in and of itself cost effective.

MR. JAKOB: The range here though, Dan, is the range of typical values available today. I didn't put numbers that are -- we have products that have very low electrical consumption, 80 AFUE and the cost to produce is higher than the standard 90 AFUE product. MODERATOR LANGMEAD: George?

MR. KELLY: George Kelly, NIST. I would just like to point out that the range of two percent and six percent, if the two percent was boilers, okay -- the pump. Six percent is typical for furnaces. you're not going to be comparing six of one with two of another, you're going to be comparing all at roughly six percent, okay. So, you know, they're not. going to have the same value. They're going to be different. They can all be lower.

MR. JAKOB: If you look at the current directory I think you'll be surprised to see the range for furnaces only.

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE'ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 69 

### 1 just like to point out in that hypothetical example 2 that to have a 80 AFUE unit that has a higher energy 3 factor than the 90 AFUE unit, the 80 AFUE unit would 4 likely cost more to produce because the technology 5 requires to get the electrical consumption down that 6 low is not in and of itself cost effective. 7 

### MR. JAKOB: Therangehere though, Dan, is 8 the range of typicalvalues availabletoday. I didn't 9 put numbers that are -- we have products that have 10 very low electrical consumption, 80 AFUE and the cost 11 to produce is higher than the standard 90 AFUE 12 product. 13 MODERATOR LANGMEAD: George? 14 

### MR. KELLY: George Kelly, NIST. I would 15 just like to point out that the range of two percent 16 and six percent, if the two percent was boilers, okay 17

-- the pump. Sixpercent is typical for furnaces. So 18 you're not going to be comparing six of one with two 19 of another, you're going to be comparing all at 20 roughly six percent, okay. So, you know, they're not 21 

### going to have the same value. They're going to be 22 different. They can all be lower. 23 

### MR. JAKOB: If you look at the current 24 directory I thinkyou'll be surprisedto seetherange 25 for furnaces only.

(202) 234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON. D.C. 20005 (202)234-44331 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 you 25H want to move on?

(202) 234-4433 70 MODERATOR LANGMEAD: Is this based on furnaces only or furnaces and boilers?

MR. JAKOB: This is just the mathematical equation parametrically looked at -- and the equation of-- MR. KELLY: So this is an idealistic case where you really can't tell me that boilers -- furnaces have two percent --

MR. JAKOB: I think there are a few. I put the range there and the raw data I didn't bring with me. MR. KELLY: Where did you get the range 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 the cost of the technology to get the electrical consumption down to the two percent level is extremely high.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 70 1 MODERATOR LANGMEAD: Is this based on 2 furnaces only or furnaces and boilers? 3 MR. JAKOB: This isjust the mathematical 4 equation parametrically looked at

-- and the equation 5 of

-- 6 MR. KELLY: So this is an idealistic case 7 where you really can't tell me that boilers 8 furnaces have two percent 9 MR. JAKOB: I think there are a few. I 10 put the range there and the raw data I didn't bring 11 with me. 12 MR. KELLY: Where did you get the range 13 from? 14 MR. JAKOB: From looking at the GAMA 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 the 21 cost of the technology to get the electrical 22 consumptiondowntothe twopercent level is extremely 23 high. 24 MODERATOR LANGMEAD: All right. 25 want to move on?

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 Do you

(202)234-44331

4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 71 MR. JAKOB: There is a analysis that was performed earlier this year that was. derived from, interestingly enough, some work we'll be talking about later this afternoon with regard to gas heat pumps and the rating procedures that have been developed for those, that seem to be in appropriate fix for some of the confusion that might be entering the marketplace, not that that might come out on the table that a 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 how those numbers would correlate with costs based on the proposal that's in the Federal Register. And the reason for this segregation of numbers is that indeed the proposal was based on a single national average value of cost ratio of about 3.36 when actually gas has a value of four, oil has a value of about 3, propane has a value of about 2.5 or something, and so operating costs would depend on the particular fuel that's being used to fire that furnace if -- electricity. The alternative that's been proposed, that I won't necessarily go into the mathematical formulation of, but I could if you'd enjoy that,

(202) 2344433 NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 71 1 

### MR. JAKOB: There is a analysis that was 2**~erformed** 

### earlier this year that was.derived from, 3 interestinglyenough, someworkwe'llbetalkingabout 4 laterthis afternoonwithregardto gas heat pumps and 5 the rating procedures that have been developed for 6 those, that seem to be in appropriate fix for some of 7 the confusion that might be entering the marketplace, 8 not that that might come out on the table that a 9 different type ofconfusionmightresult. Butwhat

-- 10 is a correlationof operatingcostwithenergy factor, 11 this EF value. 12 And this graph over here would be how 13 those numbers would correlatewith costs based on the 14 

### proposal that's in the Federal Register. And the 15 reason for this segregation of numbers is that indeed 16 the proposal was based on a single national average 17 value of cost ratio of about 3.36 when actually gas 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 so 20 operating costs would depend on the particular fuel 21 that's being used to fire that furnace if 22 electricity. 23 Thealternativethat'sbeenproposed, that 24 I won't necessarily go into the mathematical 25 formulation of, but I could if you'd enjoy that,

(202)234-4433 

### NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)23444331

3 4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 72

produces the correlation of this nature where all of those factors with regard to different fossil fuel energy costs cost ratios end up correlating exceedingly well with operating costs. And the fact that you have two values for the same AFUE no longer shows up as was evident on the previous chart.

Another facet that shows up here is that these numbers for energy factor are now offset from this range of zero to a hundred, and as George pointed out, the EF is kind of a mathematical definition and it's hard to put a real physical explanation on it. It's more a numerical measure of it's combined efficiency and cost.

This would give it a numerical value very different than what we have today being the 2`to 350 range and we have to get used to that, but is that possible? I don't know, last summer I took my kids to the beach and I bought sunscreen with an SPF of 40. And I think you all know what that means, somehow we've gotten a real appreciation for what that arbitrary scale means in terms of sun protection factor with regard to sunscreen.

And so a shift from numerical values, significant shift, not 78, 72, 75, might cause confusion, but a shift from something below a hundred

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 72 1 produces the correlation of this nature where all of 2 those factors with regard to different fossil fuel 3 

### energy costs cost ratios end up correlating 4 exceedingly well with operating costs. And the fact 5 that you have two values for the same AFUE no longer 6 shows up as was evident on the previous chart. 7 Another facet that shows up here is that 8 these numbers for energy factor are now offset from 9 this range of zero to a hundred, and as Georgepointed 10 out, the EF is kind of a mathematical definition and 11 it's hard to put a real physical explanation on it. 12 It's more a numerical measure of it's combined 13 efficiency and cost. 14 This would give it a**n~merical** 

### value very 15 different than what we have today being the 2'to 350 16 range and we have to get used to that, but is that 17 possible? I don't know, last summer I tookmy kids to 18 the beach and I bought sunscreen with an SPF of 40. 19 And I think you all know what that means, somehow 20 we've gotten a real appreciation for what that 21 arbitrary scale means in terms of sun protection 22 factor with regard to sunscreen. 23 And so a shift from numerical values

### r a 

## I 24 significant shi£t, not 78, 72, 75, migpt cause 25 confusion, but a shift from something below a hundred

(202)234-4433 NEAL

### A. GROSS COURT REPORTERSAND TRANSCRIBERS 1323RHODE ISLANDAVENUE. NoW. WASHINGTON. D.C.20005 (202)234-44331 2 3 4

6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 73

to well over a hundred might be something that could 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 the market. -- would fit in here. The answer to that question is we found with the proposed EF descriptors and even modifying the cost ratio so that there is not a one to one correlation with cost and energy factors for the two speed or modulating products. In fact one of the products that we offer under current procedures 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 go through a variety of assumptions, here is not savings reflected in those energy factors.

MR. DEMPSEY: So -- technical innovations that might still not be comprehended?

MR. JAKOB: Correct. In most of the low electrical consuming products on the market today are two speed or modulating and not fixed speed.

MODERATOR LANGMEAD: Okay, that was a good 251 point, Dan.

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 73 

### 1 to well over a hundred might be something that could 2 enter the marketplace more easily 3 

### MR. DEMPSEY: Dan Dempsey, Carrier. 4 Frank, was that based on the assumption of a single 5 speed product? 6 

### MR. JAKOB: I believe I was studying a 7 large body of fixed capacity furnaces that are on the 8 

### market.

-- would fit in here. The answer to that 9 question is we found with the proposed EF descriptors 10 and evenmodifying thecost ratio so that there is not 11 a one to one correlationwith cost and energy factors 12 for the two speed ormodulatingproducts. In fact one 13 oftheproducts thatwe offerundercurrentprocedures 14 in calculating operating costs we show a slight 15 savings from a single speed to a two speed product. 16 However when you calculate the energy factors and go 17 through a variety of assumptions, here is not a 18 savings reflected in those energy factors. 19 

### MR. DEMPSEY: So

-- technical innovations 20 that might still not be qomprehended? 21 MR. JAKOB: Correct. In most of the low 22 electrical consuming products on the market today are 23 two speed or modulating and not fixed speed. 24 

### 25 point, Dan.

(202) 234-4433 

### MODERATOR LANGMEAD: Okay, thatwas a good



### NEALR. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODEISLANDAVENUE,NW. WASHINGTON, D.C. 20005 (202)234-443374 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 about another 35 minutes, a couple of other issues we want to talk to you about, but I think we've kind of 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 them understand, one camp says that all the information is there that will provide cost of operation that's being used and the consumers are using that. Another camp is saying that the descriptors are going to be there and the descriptors are going to shift decisions even above the -- even though you understand the operating costs. I go back to where I was at some point in time, I would think we would all benefit as an industry to have some more professional look at what motivates consumers to make a purchase decision between furnaces of different fuel types. And I think that's something you almost have to do before you can get to the point of putting in the right descriptor. And the right descriptor has to be in the test procedure before FTC can use it, so you've got to go

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON. D.C. 20005 (202)' 234.4433 74 

### 1 Other comments on this? 2 Frank, doyouwant togo throughanymore? 3 

### MR. JAKOB: That's it. 4 

### MODERATOR LANGMEAD: We've got about 5 another 35 minutes, a couple of other issues we want 6 to talk to you 

### about, but I think we've kind of 7 isolated a major issue. And**what~is** 

### going to be the 8 easiest for consumers to tinderstand, what's going to 9 be the best two motivate consumers and let them 10 understand, one camp says that'all the information is 11 therethatwillprovidecostofoperationthat'sbeing 12 used and the consumers are using that. Another camp 13 is saying that the descriptors are going to be there 14 and the descriptors are going to shift decisions even 15 above the

-- even though you understand the operating 16 costs. 17 I go back to where I was at some point in 18 time, I would think we would all benefit as an 19 industry to have some more professional look at what 20 motivates consumers to make a purchase decision 21 betweenfurnaces ofdifferent fuel types. And I think 22 that's something you 

### almost have to do before you can 23 get to the point of putting in the right descriptor. 24 And the right descriptor has to be in the test 25 procedure before FTC can use it, so you've got to go

(202)234-4433 

### NEALA. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NoW. WASHINGTON. D.C. 20005 (202)234-443375 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 know a little bit mote of what's motivating the consumer to make a choice. And that needs to be organized in some way and shape, and maybe the industry can get together and assist DOE in gathering that information in some way. Other questions on -- we'll come back to this. Let's finish a couple of other things here. A couple of questions on here. The last one on there

was use of separate or combined energy descriptors for each energy source buying appliance.

Is there anybody that feels we ought to delve into that anymore? We've talked about descriptor, and we've already had two.

.Dan, I'll stop and let you talk. MR. DEMPSEY: One last comment. Going back about ten years, Carrier was involved in helping to generate a combined gas/electrical descriptor' that was called SUEF. And I think -- from DOE is going to present papers on that.

In more recent years we've also supported the development of a combined energy descriptor, and we've been involved in the GAMA in a work group. But when you get down to the details of it and you look at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202)'2344433 WASHINGTON, D.C. 20005 (202) 234-4433 75 1 back at something. 2 Andmy personalopinion iswe needtoknow 3 a littlebitmore ofwhat's motivatingthe consumerto 4 make a choice. And that needs to be organized"in some 5 way and shape, andmaybe the industrycanget together 6 and assist DOE in gathering that information.in some 7 way. 8 Other questions on -- we'll come back to 9 this. Let's finish a couple of other things here. A 10 couple of questions on here. The last one on there 11 was useof separateorcombinedenergydescriptors for 12 each>energy source buying appliance. 13 Is there anybody that feels we ought to 14 delve into that anymore? We've talked about 15 descriptor, and we've already had two. 16 Dan, I'll stop and let you talk. 17 MR. DEMPSEY: One last comment. Going 18 9ack about ten years, Carrier was involved in helping 19 to generate a combined gas/electrical descriptor'that 20 was called SUEF. And I think

-- from DOE is going to 21 present papers on that. 22 Inmore recent years we've also supported 23 the development of a combined energy descriptor, and 24 we've been involved in the GAMA in a work group. But 25 when you get down to the details of it and you look at

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C.20005 (202)234-44331 2 3 4

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 76

a combined energy descriptor and the impact on a complete model line, we came to the conclusion that there is a serious concern over the impact on high airflow products. Mainly the southern market, multifamily type products.

And to give you a perfect example of that is the proposed annual efficiency minimum for mobile home furnaces, which was 74.3 percent. If that minimum was applied today to our current AFUE fixed speed product line, three higher flow low heat models would not comply and would have to utilize very expensive technology to reduce the electrical consumption. And so we were very concerned that because of the differences from model to model, not on a baseline unit, but for a whole model line, that it would be very difficult and very impractical to set one minimum that would-be equitable across the whole product line and equitable to the whole market. That's the reason why we no longer support those.

MODERATOR LANGMEAD: Just so everybody else understands that. The point was the descriptor is there, you're going to -- you have to assume you're going to set the minimum on that descriptor rather than just communicating to the public and it has an

(202) 234-4433 NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 76 

### 1 a combined energy descriptor and the impact on a 2 complete model line, we came to the conclusion that 3 there is a serious concernover the impact onhigh air 4 

### flow products. Mainly the southern market, multi5 family type products. 6 And to give you a perfect example of that 7 is the proposed annual efficiency minimum for mobile 8 

### home furnaces, which was 74.3 percent. If that 9 minimum was applied today to our current AFUE fixed 10 speed product line, three higher flow lowheat models 11 would not comply and would have to utilize very 12 expensive technology to reduce the electrical 13 consumption. 14 And sowe wereveryconcernedthatbecause 15 of the differences from model to model, not on a 16 baseline unit, but £or a whole model line, that it 17 would be very difficult and very impractical to set 18 one minimum that would be equitable across the whole 19 product line and equitable to the whole market. 20 That's the reason why we no longer support those. 21 MODERATOR LANGMEAD: 

### Just so everybody 22 else understands that. The point was the descriptor 23 is there, you'regoing to

-- youhave to assumeyou're 24 going to set the minimum on that descriptor rather 25 than just communicating to the public and it has an

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-443377

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'd just like to point out in the alternative that I'm using two descriptors, okay, one for -- and for fossil fuel. I think it's just unhandled by the consumer. I just don't think he can make heads or tails out of the AFUE of 70 and an electrical of 60 or -- at 83 and electrical of 55, I mean how• does it go come together, it doesn't mean anything, you know. So I think -- and -- but it's going to really confuse the consumer.

MODERATOR LANGMEAD: Well, we have two issues already. We've got an AFUE and cost, and the comparison does get made in cost.

Yes? MR. YOUNG: Dave Young from Ontario Hydro again. What would be wrong with keeping the necessary number of descriptors to express the performance of the product in engineering terms and then only carry cost to the customer?

MODERATOR LANGMEAD: Dave Lewis? MR. LEWIS: Dave Lewis, Lennox. The only way that cost can be calculated that is fair to the consumer is at that particular consumer's address. And to try to do that on any national basis, to try to

(202) 234.4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 77 1 

### impact. 2 George? 3 

### MR. KELLY: George Kelly from NIST. I'd 4 just like to point out in the alternative that I'm 5 usingtwo descriptors, okay, one for

-- and for fossil 6 

### fuel. I think it's just unhandled by the consumer. 7 I just don't think he can make heads or tails out of 8 the AFUE of 70 and an electrical of 60 or -- at 83 and 9 electrical of 55, I meanhow,does itgocome together, 10 itdoesn't mean anything, youknow. So I think

-- and 11 but it's going to really confuse the consumer. 12 MODERATOR LANGMEAD: Well, we have two 13 issues already. We've got an AFUE and cost, and the 14 comparison does get made in cost. 15 Yes? 16 MR. YOUNG: Dave Young from OntarioHydro 17 again. Whatwouldbewrongwithkeepingthenecessary 18 number of descriptors to express the performance of 19 the product in engineering terms and then only carry 20 cost to the customer? 21 MODERATOR LANGMEAD: Dave Lewis? 22 MR. LEWIS: Dave'Lewis, Lennox. The only 23 way that cost can be calculated that is fair to the 24 consumer is at that particular consumer's address. 25 And to try to do that on any national basis, to try to

(202)234-4433 NEAL

### A. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w, WASHINGTON, D.C.20005 (202)234-44331 2 3 4

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 78

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 point is we need to, all together, work towards educating the consumer towards making that decision with the information that's available.

MODERATOR LANGMEAD: Okay. Yes? MR. SWEETSER: Rich Sweetser with the American Gas Cooling Center. I beg to slightly differ with my brother, Lennox, as far as getting good information to the consumer . We made a compromise when we created AFUE. We made a compromise when we creased SEER and HSPF, and that compromises selection of DOE's zone 4 as our weather data and basis for our engineering calculations.

I' ll tell you quite frankly HSPF, AFUE and 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's

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON.. D.C. 20005 (202) 234-4433 78 1 come up with any kind of descriptor that would take 2 into the factoring of what the consumer would see 3 would be so confusing that I think the effort would 4 not be worthwhile. 5 I think what exists today, this is the 6 fundamental point that we really stand with, what 7 exists today is adequate for a consumer to make an 8 intelligent energy-wise decision. We**th~nk** the pOint 9 is we need to, all together, work towards educating 10 the consumer towards making that decision with the 11 information that's available. 12 MODERATOR LANGMEAD: Okay. 13 Yes? 14 MR. SWEETSER: Rich Sweetser with the 15 AmericanGas CoolingCenter. I beg to slightlydiffer 16 with my brother, Lennox, as far as getting good 17 information to the consumer. We made a compromise 18 when we created AFUE. We made a compromise when we 19 creased SEER and HSPF, and that compromises selection 20 of DOE's zone 4 as our weather data and basis for our 21 engineering calculations. 22 I'lltellyouquite franklyHSPF, AFUE and 23 SEER have little relevance to the guy in Miami, 24 Florida, and little relevance to the guy up in 25 Seattle, Washington or perhaps in Ontario Hydro's

(202)234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON

..D.C. 20005 (202)234-44332

4

6

8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 79

case, and that's going to get even more interesting as we develope new technologies such as which are both electric and gas type technologies, and that's going to change and confuse people even more.

MODERATOR LANGMEAD: Dave, do you want to respond? MR. LEWIS: Yes. Dave Lewis, Lennox. Obviously, if we look at it from an engineering perspective, the statement that was just made has some accuracy there. The point though that I think we need to look at is what was the intent of energy descriptors and appliance standards when they are initially put in place. And I would draw a parallel to whether you'd call it the Frank Jakob's 40 on the, what was it, SBF or whatever that is, or whether you look at car mileage. It is a means by which a consumer can make a comparative decision. And I think that's the intent. If we are trying to make it into an engineering, an elaborate engineering accurate to the precise 14th digit, obviously it's incorrect.

But can the consumer make an intelligent decision based on comparative products in the marketplace? The answer is yes. And what we need to do is keep it simple enough so that the consumer actually uses the nomenclature that exists in the

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 79 1 case, and that's goingto get evenmore interesting as 2 we develope new technologies such as which are both 3 electric and gas type technologies, and that's going 4 to change and confuse people even more. 5 

### MODERATOR LANGMEAD: Dave, do you want to 6 respond? 7 

### MR. LEWIS: Yes. Dave Lewis, Lennox. 8 Obviously, if we look at it from an engineering 9 perspective, the statementthatwasjustmadehas some 10 accuracythere. Thepoint though that I thinkwe need 11 to look at is 

### what was the intent of energy 12 descriptors and appliance standards when they are 13 initially put in place. And I would draw a parallel 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 you 16 look at car mileage. It is 

### a means by which a 17 consumercanmake a comparative**d~cision.** 

### And I think 18 that's the intent. If we are trying to make it into 19 an engineering, an elaborate engineering accurate to 20 the precise 14th digit, obviously it's incorrect. 21 But can the consumer make an intelligent 22 decision based on comparative products in the 23 marketplace? The answer is 

### yes. And what we need to 24 do is 

### keep it simple enough so that the consumer 25 actually uses the nomenGlature that exists in the

(202)234-4433 

### NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202)234-443380 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 prohibited to make those adjustments in the electrical part of the gas furnace. I was wondering if you could give us whether here now or just send it to the Department why these type of furnaces can't have improvement in their electrical consumption. That would be a reasonable cost. It just doesn't -- what you're saying is that you cannot improve the electrical without really getting rid of the furnace because you won't be able to sell it. MR. DEMPSEY: No, the improvement in the electrical that would be required for certain models to raise their annual efficiency, the AE descriptor which is proposed for -- furnaces , some of the small units with high air flow, to get the electrical consumption down would require the use of the brushless DC motor technology. And in and of itself that technology is technologically feasible. But in 2511 terms of spacing hearing performance, it's not just

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 80 1 marketplace today. 2 MODERATOR LANGMEAD: Okay. 3 

### Gene? 4 

### MR. MARGOLIS: I have a question to ask 5 

### Dan Dempsey. You said that there is for gas, for 6 models of gas furnaces, at the 80 percent AFUE, to 7 improvetheelectricalefficiency, wouldbeprohibited 8 to make those adjustments in the electrical part of 9 the gas furnace. I was wondering ifyou couldgive us 10 whetherherenow orjust send itto the Departmentwhy 11 thesetypeoffurnaces can'thave improvement intheir 12 electrical consumption. That would be a reasonable 13 cost. It just doesn't

-- what you're saying is that 14 you cannot improve the electrical without really 15 getting rid of the furnace because you won't be able 16 to sell it. 17 

### MR. DEMPSEY: No, the improvement in the 18 electrical that would be required for certain models 19 to raise their annual efficiency, the AE descriptor 20 which is proposed for

-- furnaces, some of the small 21 units with high air flow, to get the electrical 22 consumption down would require the use of the 23 brushless DC motor technology. And in and of itself 24 that technology is technologically feasible. But in 25 terms of spacing hearing performance, it's not just

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODEISLANDAVENUE, N.w. WASHINGTON, D.C.20005 (202)234-44331 2

4 5

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 81

viable economically, and that it would be-cheaper to go to a bottom line condensing furnace with standard motor technology.

MR. MARGOLIS: Are you saying that this is just for mobile home furnaces or --

MR. DEMPSEY: No, if the mobile home minimum was applied to central furnaces, our current AFUE product line, there would be 25 percent of the models in that model family that would not meet the minimum because of the high air flow need for the southern for multi family market.

MR. MARGOLIS: But don't you think that your engineers would be able to in the future to redesign it such that they could meet the better electrical consumption?

MR. DEMPSEY: I would see that as highly unlikely. It would be motor technology.

MODERATOR LANGMEAD: Jim Ranfone, you had something? MR. RANFONE: Jim Ranfone. I guess I will comment, Dave made the comment that the. consumer has adequate energy descriptors today, 78 and the 98, and that's our basic premise, that that isn't adequate for consumers, but it is misleading. That's number one.

Number two, I'm talking a different

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 

### 81 1 viable economically, and that it would be·cheaper to 2 go to a bottom line condensing furnace with standard 3 motor technology. 4 

### MR. MARGOLIS: Areyou sayingthatthis is 5 just for mobile home furnaces or -- 6 

### MR. DEMPSEY: No, if the mobile home 7 minimum was applied to central furnaces, our current 8 AFUE product line, there would be 25 percent of the 9 models in that model family that would not meet the 10 minimum because of the high air flow need for the 11 southern for multi family market. 12 MR. MARGOLIS: But don't you think that 13 your engineers would be able to in the future to 14 redesign it such that they could meet the better 15 electrical consumption? 16 MR. DEMPSEY: I would see that as highly 17 unlikely. It would be

-- motor technology. 18 MODERATOR LANGMEAD: JimRanfone, youhad 19 something? 20 

### MR. RANFONE: JimRanfone. 

### t guess I will 21 cpmment, Dave made the comment that the.consumer has 22 adequate energy descriptors today, 78 and the 98, and 23 that'sourbasicpremise, that that isn'tadequate for 24 consumers, but it is misleading. That's number one. 25

(202)234-4433 

### Number two, I'm talking a different NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44331

3 4 5 6

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 82

entity. Number two, I would like to address this to Mr. Margolis because he made a comment early on that he believes that the DOE cannot propose or institute an energy descriptor based on site or based on source energy, and he said that was the law. I believe he 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 ratio factor being applied, is that within the realm of the existing legislation, and that factor based on energy -- because he did propose that.

MODERATOR LANGMEAD: Jim, thank you for leading into that. That's exactly where I want to get. The next question was statutory and marketplace limitations on descriptors. We've talked about the marketplace limitations on them, and then there are some statutory limitations.

And, Joe, I saw you had your hand up, do you want to address that?

MR. MATTINGLY: Yes. I think the record before it closes on this issue ought to have this comment in it, and Jim has raised it. If GAMA

(202) 234

-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 82 1 entity. Number two, I would like to address this to 2 Mr. Margolis because he made a comment early on that 3 he believes that the DOE cannot propose or institute 4 an energy descriptor based on site or based on source 5 energy, and he said that was the law. I believe he 6 said that, legislatively couldn't do that. I have 7 never seen that in writing from- DOE, that type of 8 interpretation. Although I know at ARI has certainly 9 made that interpretation. 10 Second, what about the energy cost ratio 11 factor being applied, is that within the realm of the 12 existing legislation, and that factor based on energy 13

-- because he did propose that. 14 MODERATOR LANGMEAD: Jim, thank you for 15 leading into that. That's exactly where I want to 16 get. 

### 17 The' next question was statutory and 18 marketplace limitations on descriptors. We've talked 19 about the marketplace limitations on them, and then 20 there are some statutory limitations. 21And, Joe, I saw you had your hand up, do 22 you want to address that? 23 MR. MATTINGLY: Yes. I think the record 24 before it closes on this issue ought to have this 25 comment in it, and Jim has raised it.

(202)234-4433 

### NEAL

### R. GROSS COURTREPORTERSAND TRANSCRIBERS 1323RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C.20005 If GAMA

(202)234-44331 2 3 4 5

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 83

believes that DOE does not have the legal authority to prescribe a multiplier and F factor, and it was clear when they prescribed a source energy multiplier that that was really outside the bounds of their authority. And we also believe that the cost based multiplier besides being a bad idea from an engineering standpoint mixes up economics with thermodynamics. But we also believe it's really just a source energy multiplier disguised, and that it also would be unlawful. And also I might add that I don't think -- I think it's a very substantial question whether DOE has the legal authority to prescribe new multipliers. NEACA states what -- I don't mean multiplier, I mean descriptors. NEACA states what the descriptors are for the various products in a couple of different places, and I don't think DOE really has the legal authority to prescribe the new descriptors without amending the statute.

MODERATOR LANGMEAD: There's something back here> MR. WILHELM: Barry Wilhelm. I'd like to follow up on that comment and get back to Cyrus' draft there that said, that talked about the cost factor, F factor, what -- source energy factor. But when you

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 83 1 believes that DOE does nothave the legal authorityto 2 prescribe a multiplier and F factor, and it was clear 3 when they prescribed a source energy multiplier that 4 thatwas reallyoutside thebounds of their authority. 5 And we also believe that the cost based multiplier 6 besides being a bad idea ( from an engineering 7 standpoint mixes up economics with thermodynamics. 8 But we also believe it's really just a source energy 9 multiplier disguised, and that it also would be 10 unlawful. 11 And also I might add that 1; don't think

-- 12 I think it's a very substantial question whether DOE 13 has the legal authority to prescribe new multipliers. 14 NEACA states what

-- I don't mean multiplier, I mean 15 descriptors. NEACA states what the descriptors are 16 for the various products in a couple of different 17 places, and I don't think DOE really has the legal 18 authority to prescribe the new descriptors without 19 amending the statute. 20 MODERATOR LANGMEAD: There's something 21 back here> 22 MR. WILHELM: BarryWilhelm. I'd like to 23 follow up onthatcomment and get back to Cyrus' draft 24 there that said, that talked about the cost factor, F 25 factor, what

-- source energy factor.

(202)234-4433 NEAL

### A. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C.20005 But when you

(202)234-44332 3

S 6 7 8 9 10 11 12 13 14 15. 16 17 18 19 20 21 22 23 24 25 84

look at cost, any electrical gadget tool, you're looking at transmission, distribution, generation of that electricity or that BTU or whatever, it all goes into the cost. So anything you throw in with the cost gets back to source energy. I agree with the statutory discussion that I am very unclear as to whether this allowed by DOE to bring in this cost factor. MODERATOR LANGMEAD: Further comments on this issue? Dave Lewis?

MR. LEWIS: Dave Lewis from Lennox. I think the benefit that we have here is that we all agree that the consumer makes their decision on cost and the real benefit is, is we need to give them enough information so that they can continue to do that. We can play with numbers all we want with descriptors, we can divide all these by seven and add three, but the real factor is the consumer makes a decision on what it costs them for operation. As long as that information is adequately supplied to them, they'll make an intelligent decision because it costs them money. MR. KALISCH: Bert Kalisch from AGA. My first point, DOE's authority, I believe that there is

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234.4433 84 

### 1 look at cost, any electrical gadget tool, you're 2 looking at transmission, distribution, generation of 3 that electricityor that BTU or whatever, it all goes 4 intothe cost. So anyt'hing you throw inwith the cost 5 

### gets back to source energy. I agree with the 6 statutory discussion that I am very unclear as to 7 whether this allowed by DOE to bring in this cost 8 factor. 9 

### MODERATOR LANGMEAD: Further comments on 10 this issue? 11 Dave Lewis? 12 MR. LEWIS: Dave Lewis from Lennox. I 

### 13 think the benefit that we have here is that we all 14 agree that the consumer makes their decision on cost 15 and the real benefit is, is we need to give them 16 enough information so that they can continue to do 17 

### that. We can play with numbers all we want with 18 descriptors, we can divide all these by seven and add 19 three, but the real factor is the consumer makes a 20 decisiononwhat itcosts them for operation. As long 21 as' that information is adequately supplied to them, 22 they'll make an intelligent decisionbecause it costs 23 them money. 24 

### MR. KALISCH: Bert Kalisch from AGA. My 25 first point, DOE's authority, I believe that there is

(202)234-4433 NEAL

### A. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-443385 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 that

gives the Secretary of Energy quite a bit of flexibility and discretion to operate in the statute to implement the intent -- AGA's view is there is sufficient discretion.

The second point is to address Dave Lewis' question or point about cost. It's a point well taken that the average annual operating cost for a furnace in Florida may not be the same as it is in Maine. What if that cost were to be indexed, be average estimated annual operating costs would be indexed across the appliances that would be indexed to be applied whether the appliance --

MODERATOR LANGMEAD: Yes, Dave? MR. LEWIS: Dave Lewis, Lennox. It's an interesting idea. The only problem is, is that the statute doesn't reflect anything of that nature. Instead it's focused on the consumer and where they use the appliance. Indexing, averaging, multiplying it by numbers, none of those are really allowable from the standpoint that the consumer does not really see what's reflected at their place of installation. Therefore, what we need to go back to is, we need to make sure that each product adequately shows the amount of electricity that's being used that currently NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 85 1 sufficient flexibility in the statute itself that 2 gives the Secretary of Energy quite a bit of 3 flexibility and discretion to operate in the statute 4 to implement the intent

-- AGA's view is there is 5 sufficient discretion. 6 The secondpOint isto addressDaveLewis' 7 question orpoint about cost. It's a point well taken 8 that the average annual operating cost for a furnace 9 in Florida may not be the same as it is in Maine. 10 What if that cost were to be indexed, be average 11 estimated annual operating costs would be indexed 12 across the appliances that would be indexed to be 13 applied whether the appliance

-- f ·14 MODERATOR LANGMEAD: Yes, Dave? 15 MR. LEWIS: Dave Lewis, Lennox. It's an 16 interesting idea. The only problem is, is that the 17 statute doesn't reflect anything of that nature. 18 Instead it's focused on the consumer and where they 19 use the appliance. Indexing, averaging, multiplying 20 itbynumbers, none of those are really allowable from 21 the standpoint that the consumer does not really see 22 what's reflected at their place of installation. 23 Therefore, what we need to go back to is, we need to 24 make sure that each product adequately shows the 25 amountofelectricitythat'sbeingused thatcurrently

(202)234-4433 

### NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C.20005 (202)234-44331 2 3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 86

is displayed and has been in the GAMA directory and in the ARI directory for their respective products.

And the information is available based on where they live to look at the regional patterns and find out exactly what the cost of that product's operation will be. It's when that is attacked that the decision is made in a good way for the consumer, the information is available today.

MR. KALISCH: Bert Kalisch, AGA. But it's quite explicit in the statute that the estimated annual operating cost may be used. And of course the annual operating cost has to be a national average, that's also a statutory requirement. So it would be applicable and DOE certainly would be within their right in using the annual estimated annual operating cost as a national average.

MODERATOR LANGMEAD: It's now 10:50, and can we take just a small break and come back.

MR. LEWIS: I would like to respond to that. MODERATOR LANGMEAD: Okay, Dave, go ahead and then Joe is going to have one, and then we're going to take a little break.

MR. LEWIS: It's clear that the FTC shows that on the label, and there is no question about

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 86 

### 1 is displayed andhas been intheGAMA directory and in 2 the ARI directory for their respective products. 3 And the information is 

### availablebasedon 4 where they live to look at the regional patterns and 5 find out exactly what the cost of that product's 6 operation will be. It's when that is attacked that 7 the decision is 

### made in a good wa¥ for the consumer, 8 the information is available today. 9 

### MR. KALISCH: BertKalisch, AGA. But it's 10 quite explicit in 

### the statute that the estimated 11 annual operating cost may be used. And of course the 12 annual operating cost has to be a national average, 13 that's also a statutory requirement. So it would be 14 applicable and DOE certainly would be within their 15 right in using 

### the annual estimated annual operating 16 cost as a national average. 17 MODERATOR LANGMEAD: It's now 10:50, and 18 can we take just a small break and come back. 19 

### MR. LEWIS: I would like to respond to 20 that. 21 MODERATOR LANGMEAD: Okay, Dave, go ahead 22 and then Joe is going to have one, and then we're 23 going to take a little break. 24 

### MR. LEWIS: It's clear that the FTC shows 25 that on the label, and there is no question about

(202)234-4433 NEALR. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44331 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 87

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 be misleading to the consumer because in effect what you 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 cost NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 87 1 that, but there is a lot of difference between what's 2 on a label and the decision that a consumer makes. 3 And I think what we need to look at is the consumer 4 makes the decision based on their place of living, 5 where they Iive. Any other information would be 6 misleading to the consumer because in effect what you 7 could have is a product being applied thinking that 8 they would get energy savings and in fact they could 9 have an actual added in cost to their energy bill on 10 an annual basis. 11 So we need to make sure that the 12 information they receive is not misleading, but 13 accurate information. 14 MR. KALISCH: AGA, justonelastquestion. 15 Do you believe that DOE does nothave the authorityto 16 index a cost number? 17 MR. LEWIS: We don't think Congress ever 18 intended that the consuming public would be hurt by 19 energy descriptor. 20 MODERATOR LANGMEAD: Joe did you have a 21 point to make? 22 MR. MATTINGLY: Yes. The consumer wants 23 to know operating cost. He's got to know certain 24 things about, youknow, thekind of househe lives in, 25 hisdesignheatingrequirements, his local energycost

(202)234-4433 

### NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C. 20005 (202)234-44332 3

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 88

for indexing, find out what his local energy cost is, everything else is right there. To the extent the DOE or FTC has any research funds, a good use for it would be to promote this directory and the use of the calculation in here, or probably your own, you know. I don't mean a new directory, but publicized the way that consumers can calculate their cost of operation. I suggest this is the best way though.

MODERATOR LANGMEAD: Dan, last one and then we're going to take time out.

MR. DEMPSEY: I guess I support that from Carrier's standpoint. I don't know about my competitors over here to my left, but we have been 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 our products. We feel that that's the most effective way in terms of addressing this issue.

MODERATOR LANGMEAD: Gentlemen, let's take 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 record 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) 234.4433 

### 88 1 for indexing, find out what his local ehergy cost is, 2 everythingelse is right there. To the extenttheDOE 3 orFTC has any research funds, a good use for itwould 4 be to promote this directory and the use of the 5 calculation in here, or probably your own, you know. 6 I don't mean a new directory, but publicized the way 7 that consumers cancalculate their cost of operation. 8 I suggest this is the best way though. 9 

### MODERATOR LANGMEAD: Dan, last one and 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 my 13 competitors over here to my left, but we have been 14 spending a lot of time working on a local basis, 15 taking the GAMA directory information, using local 16 electrical and fuel cost in terms of marketing of our 17 products. We feel that that's the most effective way 18 in terms of addressing this issue. 19 MODERATORLANGMEAD: Gentlemen, let'stake 20 a break and ,we're going to come back at 11:05 and 21 we'll talk about multifunctional appliances. 22 (Whereupon, at 10:55 a.m., off the record 23 until 11:08 a.m.) 24 

### 25 MODERATOR LANGMEAD: Gentlemen, we're all ready to resume. We're going to talk about

(202)234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODEISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44331 2 3

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 89

multifunction appliances. I'd like to start out with multifunction appliances with Ed Pollock going over the Carrier and Nordyne waivers, and then George Kelly will cover a briefing on the testing NIST has performed on multifunction appliances.

Ed, it's all your's. MR. POLLOCK: Thank you, Jack. We're going to take a break now and talk about some easy issues, multifunction appliances, particularly the products that we primarily think of when we think about multifunction products are the space heating, space conditioning products which also serve to heat water for domestic use. The two categories, of course, the electrical ones which the heat pump, air conditioning units, and water heaters, simple versions of those would be the desuperheaters and then there are those systems which are full service year round performance. In the space water heating combination, furnace type combination, we're looking at those which have primarily space heating function or those which have primarily water heating function. George Kelly is going to talk in more detail about the furnace water heating combination.

The two that I wanted to address, it looks

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 89 

### 1 multifunction appliances. I'd like to start out with 2 multifunction appliances with Ed Pollock going over 3 theCarrierandNordyne waivers, and thenGeorgeKelly 4 will cover a briefing on the testing NIST has 5 performed on multifunction appliances. 6 Ed, it's all your's. 7 

### MR. POLLOCK: Thank you, Jack. We're 8 going to take a break now and talk about some easy 9 issues, multifunction appliances, particularly the 10 products that we primarily think of when we think 11 about multifunction products are the space heating, 12 space conditioning products which also serve to heat 13 water for domestic use. The two categories, of 14 course, the electrical ones which the heat pump, air 15 conditioningunits, andwaterheaters, simpleversions 16 of those would be the desuperheaters and then there 17 are those systems which are full service year round 18 performance. 19 In the space water heating combination, 20 furnacetypecombination, we'relookingatthosewhich 21 have primarily space heating function or those which 22 have primarily water heating function. George Kelly 23 is going to talk in.more detail about the furnace 24 water heating combination. 25 Thetwo that I wantedto address, itlooks

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, NW. WASHINGTON, D.C.20005 (202)234-44331

3 4

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 90

like we're a little bit off the scale on the size here on my viewgraph. The two that I want to address were the two products which we granted waivers for. One was Carrier system which did air conditioning and water heating and space heating, and the other the Nordyne which more :recently we have given a waiver for them to rate their product. -

I just wanted to put this up and give you 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 can see from the list of the different components here.

Those of you who were involved with the rating of air conditioning systems are familiar with this list, it's the list of the tests that are conducted for heat pump, air conditioning units using the ARI different test conditions. Of course thrown in with it when you have water heating, then you need to consider what happens to the system in each of the functions when it's combined with water heating. And so the list gets very long, it's very costly for the manufacturers to test the product in order to obtain the data and in order to come up with some idea of what the system performs under the various operating conditions. As you can see from this list, combining

(202) 234433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON, O.C. 20005 (202) 234-4433 90 

### 1 likewe're a littlebit off the scale on the size here 2 on my viewgraph. The two that I want to address were 3 the two products which we granted waivers for. One 4 was Carrier system which did air conditioning and 5 water heating and space heating, and the other the 6 Nordyne whichmore,recentlywe havegiven a waiver for 7 them to rate their product. 8 I justwanted to put this up and give you 9 someideaofthe differencesbetweenthetwoproducts. 10 Basically they perform the same functions. Carrier 11 had a few more bells and whistles on it, as you can 12 see from the list of the different components here. 13 Those .of you who were involved with the ·14 rating of air conditioning systems are familiar with 15 this list, it's the list of the tests that are 16 conducted for heatpump, air conditioning units using 17 the ARI different test conditions. Of course thrown 18 in with it when you have water heating, then you need 19 to consider what happens to the system in each of the 20 functions when it's combined withwater heating. And 21 so the list gets very long, it's very costly for the 22 manufacturers to test the product in order to obtain 23 the data and in order to come up with some idea of 24 what the system performs under the various operating 25 conditions. As you can see from this list, combining**(202)~** 

### NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202)234-44334 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 91

both space heating and space cooling, we have, what, about 15 different which have to be run.

As far as the energy descriptors, there has been a long debate about what descriptor do you use for describing the performance of a product which does more than one function. For the consumer, as we've talked about this morning, it would be nice to have one number where he can compare the product, but now we have two different loads being satisfied, so how are those combined.

In the case of Hydrotech 2000, they reported the heating and cooling performance factors as you would have for the normal heat pump type system, and operating costs as well as the annual energy savings comparing the energy savings of a typical heat pump air conditioning system and the water heating load under typical rating with what it cost for the combined or save energy use for the combined products. So you had a savings, the difference between the separate products and the integrated product.

Nordyne is reporting somewhat similar as far as the separate costs for operating the efficiency for the product, but they have proposed, and we have given them a waiver to allow them to have a rating for

(202) 234-4433 

### NEAL R. GROSS , COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-3433 91 

### 1 both space heating and space cooling, we have, what, 2 about 15 different which have to be run. 3 

### As far as the energy descriptors, there 4 has been a long debate about what descriptor do you 5 use for describing the performance of a product which 6 

### does more than one function. For the consumer, as 7 we've talked about this morning, it would be nice to 8 have one number where he can compare the product, but 9 now we have two different loads being satisfied, so 10 how are those combined. 11 

### In the case of Hydrotech 2000, they 12 reported the heating and cooling performance factors 13 as you would have for the normal heat pump type 14 system, and operating costs as well as the annual 15 energy. savings comparing the energy savings of a 16 typical heat pump air conditioning system and the 17 water heating load under typical rating with what it 18 cost for the combined or save energy use for the 19 

### combined products. So you had a savings, the 20 difference between the separate products and the 21 integrated product. 22 Nordyne is reporting somewhat similar as 23 far as the separatecosts for operatingtheefficiency 24 for the product, but they have proposed, and we have 25 giventhem a waiver to allowthemtohave a rating for

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-443392 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 up

all of the operating energy that's used under various 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 possible 14 ways of combining these which have been suggested. I 15 have noted two of them here. One would be an 16 equivalence SEER or an equivalent HSPF. The problem 17 with any of these, when you start combining in these 18 equivalences, what credit do you give for savings to 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, because 22 of demand side management programs , and credits that 23 are given there, to want to give all the credit for 24 the water heating savings to the -- cooling or heating 25 efficiency so that that SEER value of the HSPF value

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 92 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 up 4 all of the operating energy that's used under various 5 .load conditionS and the energy that's used or the 6 output of the system under various operating 7 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**SEE~** ratio, 11 onlythey'recallingitacombinedheatingperformance 12 factor and a combined cooling performance factor. 13 There have been several other possible 14 ways of combining these which have been suggested. I 15 have noted two of them here. One would be an 16 equivalence SEER or an equivalent HSPF. The problem 17 with any of these, when you start combining in these 18 equivalences, what credit do you give for savings to 19 the one load, theheating load orthecooling load and 20 to the water heating load. 21 The tendency has been to want to, because 22 of demand side management programs, and credits that 23 are given there, to want to give all the credit for 24 the waterheating savings to the

-- coolingorheating 25 efficiency so that that SEER value of the HSPF value

(202)234-4433 

### NEAL

### R. GROSS COURTREPORTERSAND TRANSCRIBERS 1323 RHODE ISLANDAVENUE, NW. WASHINGTON, D.C.20005 (202)23444331

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) 234-4433 93 

### 1 goes higher and not to consider any of the savings 2 that's a result of the water heating. And this is of 3 

### course very misleading to the consumer. It does 4 sometimes increase sales I guess as a combiqed 5 product. 6 And the otherway that's beenproposed is 7 an energy equivalent factor which would be strictly 8 similartothecombinedheatingorcoolingperformance 9 factor, but in this case would be using the same 10 units, kilowatt hours in and kilowatt hours out or 11 BTUs in, BTUs out, so that you had a dimensionless 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 of 15 course the problem still comes, what is the most 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 fossil 19 fuel type systems. 20 

### MR. KELLY: Again, I'm George Kelly from 21 NIST. You'vebeengivena littlebitofbackgroundon 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. JoePietschandotherswere 25 involved in developing it. Basically there are two

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON. D.C.20005 (202)234-44331 2 3 4

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 94

types of appliances, type one and type two. Type one is the kind that's primary function is space heating, second function water heating, and examples of those are space heating boiler with a tankless water heater or a space heating coil with an interact heated hot water storage tank.

And type two, the primary function is water heating, secondary function is space heating, and that's your typical water heater.

And a diagram of type one appliance which is a boiler, a boiler with a tankless coil here. If you have an oil fired boiler, typically your appliance is hearing your hot water. Another type one is also a boiler with a storage tank. Water is circulated through a coil in the storage tank and this is domestic hot water stored in the storage tank. Again it's a type one.

Type two, most of you recognize this is your typical hot water heater with domestic water being supplied to your taps, and then water either to an air handling unit, in this case with a coil in it, and then air is ducted to your rooms , or else to baseboard. It could be baseboard heat too. That is again a type two appliance.

Okay, the 124 test procedure requires two

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 94 

### 1 types of appliances, type one and type two. Type one 2 is thekind that's primary function is space heating, 3 second function water heating, and examples of those 4 are space heating boilerwith a tankless water heater 5 or a space heating coil with an interact heated hot 6 water storage tank. 7 

### And type two, the primary function is 8 water heating, secondary function is space heating, 9 and that's your typical water heater. 10 And a diagram of type one appliance which 11 is a boiler, a boiler with a tankless coil here. If 12 youhave anoil firedboiler, typicallyyour appliance 13 is hearing your hot water. Another type one is also 14 a boiler with a storage tank. Water is circulated 15 through a coil in the storage tank and this is 16 domestic hot water stored in the storage tank. Again 17 it's a type one. 18 Type two, most of you recognize this is 19 your typical hot water heater with domestic water 20 being supplied to your taps, and then water either to 21 an air handling unit, in this case with a coil in it, 22 and then air is 

### ducted to your rooms, or else to 23 baseboard. It could be baseboard heat too. That is 24 again a type two appliance. 25 Okay, the 124 test procedure requires two

(202)234-4433 

### NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331 2

4 5 6 7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 95

separate tests. A space heating test which is done in accordance with ASHRAE 103 standard which is basically the furnace boiler test I was talking about this morning. The steady state cool-down and warm-up, that sort of stuff.

And then test 2 is a water heating test done in accordance with the DOE test procedure for type two or a similar type test procedure that's spelled out on 124. It's basically the same as the DOE water heating test procedure. And that comes up with an energy factor.

124 also has a calculation section and allows you to determine the space heating seasonal efficiency. Space heating is assumed to be done at the efficiency of the heating season, they call it EFFHS. It's actually an ADU, that far load efficiency that I showed you this morning. The water heating efficiency is done at stead state efficiency of the appliance during the non heating season and water heating season it's done at the energy factor calculated by the DOE procedure, DOE water heating procedure. Okay, those have been combined into the efficiency descriptors. You have a combined heating

season efficiency descriptor that includes space and

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 95 1 separate tests. Aspaceheating testwhich is done in 2 accordancewithASHRAE 103 standardwhichisbasically 3 the furnace boiler test I was talking about this 4 morning. The steady statecool-down andwarm-up, that 5 sort of stuff. 6 And then test 2 is a water heating test 7 done in accordance with the DOE test procedure for 8 type two or a similar type test procedure that's 9 spelled out on 124.**It~s** basically the same as the 10 DOE water heating test procedure. And that comes up 11 with an energy factor. 12 124 also has a calculation section and 13 allows you to determine the space heating seasonal ·14 efficiency. Spape heating is assumed to be done at 15 the efficiency of the heating season, they call it 16 EFFHS. It's actually anADU, that far loadefficiency 17 that I showed you this morning. The water heating 18 efficiency is done at stead state efficiency of the 19 appliance during the non heating season and water 20 ,heating season it's done at the energy factor 21 calculated by the DOE procedure, DOE water heating 22 procedure. 23 Okay, those have been combined into the 24 efficiency descriptors. You have a combined heating 25 season efficiency descriptor that includes space and

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHOOE ISLANDAVENUE. N.w. WASHINGTON. D.C.20005 (202)234-44331

3 4 5

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 96

water heating during the heating season. You have a non heating season descriptor. And finally you have a combined annual efficiency, the CAE term which is a combination of space and water heating in the heating

season and water heating in the non heating season. And those terms are derived from the previous terms by weighting them with the filling loads and water loads, and also the lengthy non heating season versus the length of the heating season.

Okay, we did some tests in this, and comparing the 124, the results in the 124 standard with -- calculated and determined in the lab, we looked at two types. One was a type one oil fired boiler where the tank was here. The other one was a type two, a gas fired water heater with an air handling unit. And what we actually did was we did combined testing which we cycled the unit. We imposed a heating load on it, okay, and cycled the unit for heating mod and we imposed a water drill loan on top of that and actually measured the input/output and determined the efficiency of both these type one and type two appliances, and then we compared that result with the ASHRAE 124 standard.

So we got a good agreement as you can see here. For the type ones, the space heating, primary

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 96 

### 1 water heating during the heating season. You have a 2 non heating season qescriptor. And finally you have 3 a combined annual efficiency, the CAE term which is a 4 combination of space and water heating in the heating 5 season and water heating in the non heating season. 6 And thoseterms arederived from theprevious terms by 7 weightingthemwiththe filling loads andwaterloads, 8 and also the lengthy non heating season versus the 9 length of the heating season. 10 

### Okay, we did some tests in this, and 11 comparing the 124, the results in the 124 standard 12 with

-- calculated and determined in the lab, we 13 looked at two types. One was a type one oil fired 14 boiler where the tank was here. The other one was a 15 type two, a gas fired water heater with an air 16 handling unit. And what we actually did was we did 17 combined testingwhichwe cycledtheunit. We imposed 18 a heating load on it, okay, and cycled the unit for 19 heating mod and we imposed a water drill loan on top 20 o£ that and actually measured the input/output and 21 determined the efficiency of both these type one and 22 type two appliances, and thenwe compared that result 23 with the ASHRAE 124 standard. 24 So we got a good agreement as you can see 25 here. For the type ones, the space heating, primary

(202)234-4433 NEAL

### A. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C.20005 (202)234-44332 3 4

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 97

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 five percent. So this seems to confirm the accuracy of the 124 standard. Just for your information type one appliances, the boiler had a steady state efficiency of 83; it was a oil unit. The combined efficiency came out to be 76. The efficiency for the type two energy factor was .54, but it came out with a combined efficiency of 73.8.

Generally the primary reason is it's heating season efficiency. It's prior load efficiency during the heating season is typically lower. The type one was 78, and the type two was 76. Unless you've got a condensing type two appliances, you're going to generally see a lower CAE than if you're

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 97 1 function spaceheating, secondaryiswaterheating, we 2 came up with in the lab test, cyclic test, the actual 3 input/output test efficiency of 79.4. We had a 124 4 calculations and came up with 79.2, 2/10ths of a 5 

### percent difference. For the type two, again the 6 measure of the efficiency was 77.1. The 124 came up 7 with 76.8, a difference of 3/10th efficiency points. 8 

### Tests were also performed by AGA and 9 Batelle on four products of this nature, type one and 10 type two, and they found results that showed that the 11 measuredlabresultsonthecyclicoperatingcondition 12 was agreed with the 124 calculations within five 13 percent. Sothis seems toconfirmthe accuracyof the 14 124 standard. Just for your information type one 15 appliances, the boiler had a steady state efficiency 16 of 83i 

### it was a oil unit. The combined efficiency 17 came out to be 76. The efficiency for the type two 18 energy factorwas .54, but itcame outwith a combined 19 efficiency of 73.8. 20 Generally the primary reason is it's 21 heatingseasonefficiency. It'spriorloadefficiency 22 during the heating season is typically lower. The 23 type one was 78, and the type two was 76. Unless 24 you've got a condensing type two appliances, you're 25 going to generally see a lower CAE than if you're

(202)2344433 

### NEALR. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202) 234-44331 2 3

5 6 7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 98

dealing with a type one product. It does have some impact on how you set your minimum standards.

Okay. And just very briefly we did some other tests. If you look at family series of type one appliances, and we looked at gas fired type one, gas fired boilers, different gas lines with identical water storage tanks. Different boilers using the same external water tank, and we also looked at oil fired boilers with the same tankless coil heater. One tankless here that's used in different oil fired boilers, and we performed the ASHRAE 103 and 124 tests and let me just show you the results. We plotted steady state efficiency, heating season efficiency, CAE, energy factor, and this is with the one storage tank with different size boilers and show that you could pretty much come up in a straight line.

The purpose of this was to say that if you had a family of boilers, could you reduce, the test burden by maybe just testing the highest one and the lowest one. And it looks like the straight line correlation for the storage tank and pretty much for the tankless coil too, a little bit of bend in the energy factor down there.

Our conclusion was item here, number four, results indicated that -- interpretation of the rating NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 98 1 

### dealing with a type one product. It does have some 2 impact on how you set your minimum standards. 3 

### Okay. And just very briefly we did some 4 othertests. If you look at family series of type one 5 appliances, and we looked at gas fired type one, gas 6 fired boilers, different gas lines with identical 7 water storagetanks. Differentboilersusingthe same 8 external water tank, and we also looked at oil fired 9 

### boilers with the same tankless coil heater. One 10 tankless here that's used in different oil fired 11 boilers, andwe performedtheASHRAE 103 and 124tests 12 and let me just show you the results. We plotted 13 steady state efficiency, heating season efficiency, 14 CAE, energy factor, and this is with the one storage 15 tank with different size boilers and show that you 16 could pretty much come up in a straight line. 17 Thepurpose ofthiswas to saythat ifyou 18 had a family of boilers, could you reduce,the test 19 burden by maybe just testing the highest one and the 20 lowest one. And it looks like the straight line 21 correlation for the storage tank and pretty much for 22 the tankless coil too, a little bit of bend in the 23 energy factor down there. 24 Ourconclusionwasitemhere, numberfour, 25 resultsindicatedthat

-- interpretationoftherating

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331 2

4 5 6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 99

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 will 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 tested indoors. MR. KELLY: Everything was indoors.

MR. DEMPSEY: Okay. I guess one of the concerns we have is that in the appendix to 124 there is a procedure to calculate an equivalent AFUE and since the type two products are predominantly forced air heating products, the equivalent AFUE is being compared to ICSA if you read the forced air furnace and that we believe that there should be some change

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 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, andwill reduce the test 4 burden on manufacturers, so I presume that we will 5 propose something like testing the largest one and 6 testing the smallest one and using that to rate the 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 indoor 11 or an ICS environment? 12 MR. KELLY: The calculated CAE you're 13 talking about? 14 MR. DEMPSEY: Yes. 15 MR. KELLY: Stan? The type two. 16 MR. LIV: Yes, the boiler are all tested 

### 17 indoors. 

### 18 MR. KELLY: Everything was indoors. 19 MR. DEMPSEY: Okay. I guess one of the 20 concerns we have is that in the appendix to 124 there 21 is a procedure to calculate an equivalent AFUE and 22 since the type two products are predominantly forced 23 air heating products, the equivalent AFUE is being 24 compared to ICSA if you read the forced air furnace 25 and that we believe that there should be some change

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODEISLANDAVENUE, NoW. WASHINGTON, D.C. 20005 (202)234-44332 3 4 5

7 8

10 11 12 13 .14 15 16 17 18 19 20 21 22 23 24 25 100

made to put those on the same scale. Such as the type 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 to 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 the primary function, okay. So the type one which primary function is space heating, you would be able to reduce you AFUE by the combined savings . Type two you'd be able to reduce your energy factor coming up with a -- energy factor, but you can't do it on both, you can't double-dip or claim the savings twice.

Unfortunately there 's been some, I guess, advertising after that which does not take that into account and does apply the savings to the -- water savings in space heating. It's a serious issue, and I guess there' s another issue that you're just raising too, comparing apples and oranges a little bit with isolating combustion -- NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 

### 100 1 made to put those on the same scale. Such as the type 2 two products today, there is cabinet loss, jacket 3 loss, piping loss is not conducted. 4 

### MR. KELLY: Okay, there are some -- yes, 5 there is somediscrepancies likethat. In additionto 6 that in the 124, and there's a lot of pushing and 7 shovingonthe committee, theyeliminated it. You get8 into the problem of double-dipping too, okay. And as 9 was just explained you can take the savings from the 10 water andput itonthe spaceheating, oryou can take 11 the savings and put it on the water heating, okay. 12 And 124 specifies that you have to put it on the 13 primaryfunction, okay. Sothe typeonewhichprimary -14 function is spaceheating, you wouldbe able toreduce

15 you AFUE by the combined savings. Type two you'd be 16 able to reduce your energy factor coming up with a 17 energy factor, but you can't do it on both, you can't 18 double-dip or claim the savings twice. 19 Unfortunatelythere'sbeen some, I guess, 20 advertising after that which does not take that into 21 account and does apply the savings to the

-- water 22 savings in space heating. It's a serious issue, and 23 I guessthere's another issuethatyou'rejustraising 24 too, comparing apples and oranges a little bit with 25 isolating combustion

--

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-44332 3 4 5 6

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 101 MR. DEMPSEY: Also, I have a follow up on the type two system. Was the actual air handler tested or was it just a delta T presumed to exist?

MR. KELLY: Actually the air handler was tested. MR. STANONIK: George, Frank Stanonik with GAMA, in the test work you did, on the first series of 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. Like 130,000, something like that, compared with a water heater. MR. STANONIK: Okay. Now, in the second set of. tests that you did where you were looking at if there was a relationship between the specific boiler and the coil you put in or whatever, what was the highest input you measured there?

MR. KELLY: I don't -- the reports, so. MR. STANONIK: All right. Well, the reason I asked is it' s been said to me without any follow-up technical information that 124 seems to break down when you get into the -- it could cover, in terms of residential boilers, it could cover something up to 300, 000 BTU, and it has been suggested to me that 124 breaks down when you start dealing with

(202) 234-4493 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 101 1 MR. DEMPSEY: Also, I have a follow up on 2 the type two system. Was the actual air handler 3 tested or was it just a delta T presumed to exist? 4 MR. KELLY: Actually the air handler was 5 tested. 6 MR. STANONIK: George, FrankStanonikwith 7 GAMA, in the test workyou did, on the first series of 8 tests you did a type one which was an oil fired 9 boiler, do you recall what the input of that was? 10 MR. KELLY: It's over in here. Like 11 130,000, something like that, compared with a water 12 heater. 13 MR. STANONIK: Okay. Now, in the second 14 set**o~** tests that you did whereyou were looking at if 15 there was a relationship between the specific boiler 16 and the coil you put in or whatever, what was the 17 highest input you measured there? 18 MR. KELLY: I don't --the reports, so. 19 MR. STANONIK: All right. Well, the 20 reason I asked is it's been said to me without any 21 follow-up technical information that 124 seems to 22 breakdownwhenyou get into the

-- itcouldcover, in 23 termsofresidentialboilers, itcouldcoversomething 24 up to 300,000 BTU, and it has been suggested to me 25 that 124 breaks down when you start dealing with

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C. 20005 (202)234-44331 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 102

appliances that are in the, let's say 200,000 BTU per hour plus range, and I just wondered if you had looked at any of those?

MR. KELLY: No, I hadn't seen that. The range here was 25, the gas unit was 25, and the KW to 45 KW input. MR. STANONIK: Okay, - that's not a lot. And I just mention it because it's been mentioned to me and I have nothing to say that it's true or false.

MR. KELLY: Okay. There's nothing to look at. MR. RANFONE: Jim Ranfone here. Just a question, George. You said that type two equipment is based on or assume it's the cyclic time of the boiler. Was there any discussion, were you looking at doing different cycle times?

MR. KELLY: We did a range of cycling times and it didn't seem to have much --

MR. RANFONE: -- factor using the force air type -- MR. KELLY: -- that's right.

MODERATOR LANGMEAD: Are there other question for Joe or for George?

MR. PIETSCH: Joe Pietsch. I'm an engineering consultant and I was very much active with

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 102 1 appliances that are in the, let's say 200,000 BTU per 2 hour plus range, and I just.wondered ifyouhad looked 3 at any of those? 4 MR. KELLY: No, I hadn't seen that. The 5 range here was 25, the gas unit was 25, and the KW to 6 45 KW input. 7 MR. STANONIK: Okay,

-·that's not a lot. 8 And I just mention it because it's been mentioned to 9 me and I have nothing to say that it's true or false. 10 MR. KELLY: Okay. There's nothingto look 11 at. 12 MR. RANFONE: Jim Ranfone here. Just a 13 question, George. You saidthat type two equipment is 14 based onor assume it's the cyclic time of theboiler. 15 Was there any discussion, were you looking at doing 16 different cycle times? 17 MR. KELLY: We did a range of cycling 18 times and it didn't seem to have much

-- 19 MR. RANFONE:

-- factor usingthe force air ,20 type

--

21 MR. KELLY:

-- that's right. 22 MODERATOR LANGMEAD: Are there other 

### 23 question for Joe or for George? 24 MR. PIETSCH: Joe Pietsch. I'm an 25 engineeringconsultant and I wasverymuch activewith

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C. 20005 (202)234-44332 3

5 6 7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 103

the 124 standard. First of all, it isn't 124 that says to apply all the savings from the 124 of each 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 space 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) 234-4433 

### 103 1 

### the 124 standard. First of all, it isn't 124 that 2 says to apply all the savings from the 124 of each 3 

### combined approach. Type one, apply that to water 4 

### heating. And on the type two which is 

### basically a 5 water heater, apply the same things over in the space 6 heating section 7 

### MR. KELLY: We have a total combined 8 equivalent factor, but for the primary function. 9 

### MR. PIETSCH: Well, no, there was a 10 directive that came out of a government agency that 11 said if you have a water heater and you add space 12 heating to it, you have to give the energy factor for 13 water heating and you can't take any credit on 14 providing the appliance for the water heating 15 function. You had to use the energy factor for the 16 water heating test 17 On the other side ifyou had a boiler and 18 add water heating to it, you've got to come up with 19 the AFUE for the boiler. So that just leaves them, 20 whatever savings you get not only bywhat maybe makes 21 good sense, but also bywhat the government has said. 22 You've got to apply it to the secondary function. 

### 23 MR. KELLY: Correct. You can have an 24 equivalent energy factor for type one appliances or 25 you can have na equivalent for effective AFUE for the

(202)234-4433 

### NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-4433104 1 type two appliance, yes. MR. PIETSCH: Do it wasn't the 124 that

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 be the government regulation--

MR. KELLY: -- but that's being violated right now I think.

MR. PIETSCH: Where is it being violated at? MR. KELLY: We've seen some ads that are doing -- MR. PIETSCH: -- doesn't have them. These products are listed in the GAMA director and I don't there is any violation.

MR. KELLY: I'm sure it's not there. But there certainly is a potential for that, okay. You just need to watch it when you're dealing with these inspections. MR. PIETSCH: Well, do you have records you've seen ads of this type?

MR. KELLY: I don't have them. I've seen them, yes. MR. PIETSCH: Well, this is kind of a generalization, George.

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 104 1 type two appliance, yes. 2 MR. PIETSCH: Do it wasn't the 124 that 3 came up -- 4 

### MR. KELLY: But that's

-- 5 

### MR. PIETSCH: callingwhat appeartobe 6 the government regulation-- 7 

### MR. KELLY:

-- but that's being violated 8 right now I think. 9 

### MR. PIETSCH: Where is it being violated 10 at? 11 MR. KELLY: We've seen some ads that are 12 doing

-- 13 MR. PIETSCH:

-- doesn'thavethem. These 14 products are listed in the GAMA director and I don't 15 there is any violation. 16 MR. KELLY: I'm sure it's not there. But 17 there certainly is a potential for that, okay. You 18 just need to watch it when yqu're 

### dealing with these 19 inspections. 20 MR. PIETSCH: Well, do you 

### have records 21 you've seen ads of this type? 22 MR. KELLY: I don't have them. I've seen 23 them, yes. 24 

### MR. PIETSCH: Well, this is kind of a 25 generalization, George.

(202)234-4433 

### NEALR. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C.20005 (202)234-44331 2 3 4 5 6 7 8

10 11 12 13 .14 15 16 17 18 19 20 21 22 23 24 25 105 MR. KELLY: It's not a --, Joe. I'm just pointing out that there is some potential for this problem, okay, and just be aware of it in developing energy descriptors.

MR. PIETSCH: And I have another comment about for the use of boiler timing or the furnace timing. You said it didn't make much difference, but people don't recognize that these --

MR. KELLY: The- air handler used the furnace cycle, and you have a variety of them.

MR. PIETSCH: -- but the combustion system does not cycle with the air handler, it cycles with the thermostat that's on the tank.

MODERATOR LANGMEAD: Keep it a little louder, Joe, I can't hear you.

MR. KELLY: And the control system on the water heater took care of itself. That's what I recall. Those are --

MODERATOR LANGMEAD: Dan? MR. DEMPSEY : Just a reiteration, I don't think it's whether you assume it's a boiler or a furnace in terms of the cycle timing, the it's the end use of the product in the marketplace, and all forced air heating systems should be treated alike.

(202) 234-4433 MR. KELLY: We did. As I said I believe NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 105 1 MR. KELLY: It's not a --, Joe. I'mjust 2 pointing out that there is some potential for this 3 problem, okay, and just be aware of it in developing 4 energy descriptors. 5 MR. PIETSCH: And I have another comment 6 about for the use of boiler timing or the furnace 7 timing. You said it didn't make much difference, but 8 people don't recognize that these 9 MR. KELLY: The air handler used the 10 furnace cycle, and you have a variety of them. 11 MR. PIETSCH: butthecombustionsystem 12 does not cycle with the air handler, it cycles with 13 the thermostat that's on the tank.



# . 14 MODERATOR LANGMEAD: Keep it a little 15 louder, Joe, I can't hear you. 

### 16 MR. KELLY: And the control system on the 17 water heater took care of itself. That's what I 18 recall. Those are 19 MODERATOR LANGMEAD: Dan? 20 MR. DEMPSEY: Just a reiteration, I don't 21 think it's whether you assume it's a boiler or a 22 furnace interms of thecycletiming, the it'stheend 23 use of the product in the marketplace, and all forced 24 air heating systems should be treated alike. 25

(202)234-4433 MR. KELLY: We did. As I said I believe NEAL

### A. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-4433106

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 of Energy. This type of work has been given to NIST by the Department of Energy because of the importance of having eventually a test procedure similar to ASHRAE 124. DOE test procedure to rate this type of appliances, combination of items type one and type two, as George described.

The reports, two reports has been published by KIST, we call it NIST Air. Well, that's NIST's reports, and they are available if anybody is interested to have a copy of it. You can contact me. And eventually all this research and some of these other studies as far as the linearity of some of these number of tests for making the test presume more less time consuming for manufacturers and all that would result in a proposed rule.

I'm not promising any time soon, but it's an agenda proposed as a DOE test procedure for combination appliances covering this type of appliances very soon. And obviously it would be a

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 

### 106 1 

### it was furnace cycle times we were doing. And 2 whatever the unit did by its own -- it did. 3 

### MODERATOR LANGMEAD: Are there other 4 questions for George? 5 Cyrus? 6 

### MR. NASSERI: CyrusNasseri, Departmentof 7 Energy. This type of work has been given to NIST by 8 the Department of Energybecause of the importance of 9 having eventually a test procedure similar to ASHRAE 10 124. DOE test procedure to rate this type of 11 appliances, combination of items type one and type 12 two, as George described. 13 

### The reports, two reports has been 14 published by NIST, we call itNIST Air. Well, that's 15 NIST's reports, and they are available if anybody is 16 interested to have a copy of it. You can contact me. 17 And eventually all this research and some of these 18 other studies as far as the linearityof some ofthese 19 number of tests for making the test presume more less 20 time consuming for manufacturers and all that would 21 result in a proposed rule. 22 I'mnot promising anytime soon, but it's 23 an agenda proposed as a DOE test procedure for 24 

### 25 combination appliances covering this type of appliances very soon. And obviously it would be a

(202)234-4433 

### NEALR. GROSS COURTREPORTERSAND TRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44331

4 5 6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 107

reference , actually 124 plus all the other findings that we had as a result of the research by NIST given by DOE. MODERATOR LANGMEAD: Any additional questions for George or for Cyrus?

Jim Ranfone? MR. KELLY: Joe Pietsch, I have another comment. ASHRAE 124 had a 1991 date on it. by ASHRAE procedures it should be reviewed every five years. So in 1996 it probably will be sent to one of the ASHRAE committees to determine whether it should be reaffirmed or revised. So if anybody has any thoughts about problems with 124, I think that's the proper to address -- not necessarily --

MR. NASSERI: As a matter of fact this is a very good point because the other day I was asking somebody -- which TC sponsored 124, which I found out is 6.6. And I was planning at Atlanta an ASHRAE Atlanta meeting to approach the 6.6 chairman and bring this issue up with him, and as you know the ASHRAE regulation that TC has to initiate, the SPC which the cycle is there, you're correct on your's and we would like to approach TC 6.6 to discuss the issue and ask the chairman if they can assign a chairman for SPC for 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) 234-4433 

### 107 1 reference, actually 124 plus all the other findings 2 that we had as a result of the research by NIST given 3 

### by DOE. 4 

### MODERATOR LANGMEAD: Any additional 5 

### questions for George or for Cyrus? 6 Jim Ranfone? 7 

### MR. KELLY: Joe Pietsch, I have another 8 

### comment. ASHRAE 124 had a 1991 date on it. by 9 

### ASHRAE procedures it should be reviewed every five 10 years. So in 1996 it 

### probably will be sent to one of 11 the ASHRAE committees to determine whether it 

### should 12 be reaffirmed or revised. So if anybody has any 13 thoughts about problems with 124, I think that's the 14 proper to address

-- not necessarily

-- 15 MR. NASSERI: As a matter of fact this is 16 a very good point because the other day I was asking 17 somebody

-- which TC sponsored 124, which I found out 18 

### is 6.6. And I was planning at Atlanta an ASHRAE 19 Atlantameetingtoappz;oachthe 6.6 chairmanandbring 20 this issue 

### up with him, and as you know the ASHRAE 21 regulation that TC has to initiate, the SPC which the 22 cycle is there, you're correct onyour's and we would 23 like to approach TC 6.6 to discuss the issue 

### and ask 24 the**c~airman** 

### iftheycan assign 

### a chairman for SPC for 25 the revision of the 124.

(202)234-4433 NEAL

### A. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODEISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44331 2 3

5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 108 Obviously the findings that we have on this would be presented to the SPC and hopefully to revise the 124, moreso the need working on the rulemaking on a test procedure, DOE has -- for a combination appliances , we have less write up in there and have basically referenced the 124 as much as we

can. MODERATOR LANGMEAD: Jim Ranfone, do you have a question?

MR. RANFONE: Yes. I guess I'll direct to Cyrus since you opened it up. Jim Ranfone, AGA. I had a situation which was alluded to here where some states are taking, looking at combination systems and trying to apply the minimum efficiency requirements to the heating side of a combination system, specifically a water heating use for space heating. And we've tried to argue with them that the intent of the law and the question of equity indicates that the primary purpose of equipment is for water heating and it's certified safety-wise underwater heater standard that it only has to meet the minimum efficiencies of water heating. By the way this also applies -- and the state has come back and said to us and well, if you install in our state, since it uses much more energy

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 108 1 

### Obviously the findings that we have on 2 this would be presented to the SPC and hopefully to 3 revise the 124, moreso the need working on the 4 rulemaking on a test procedure, DOE has

-- for a 5 combinationappliances, we have lesswriteup inthere 6 and have basically referenced the 124 as much as we 7 can. 8 

### MODERATOR LANGMEAD: Jim Ranfone, do you 9 have a question? 10 MR. RANFONE: Yes. I guess I'll direct to 11 Cyrus since you opened it up. Jim Ranfone, AGA. I 

### 12 had a situation which was alluded to here where some 13 states are taking, looking at combination systems and 14 tryingtoapplytheminimumefficiencyrequirements to 15 theheatingsideofa combinationsystem, specifically 16 a water heating use for space heating. And we've 17 tried to argue with them that the intent of the law 18 and the question of equity indicates that the primary 19 purpose of equipment is for water heating and it's 

## 20 certifiedsafety-wiseunderwaterheaterstandardthat 21 it onlyhas to meet the minimum efficiencies of water 22 heating. 23 By the way this also applies

-- and the 24 state has come back and said to us and well, if you 

### 25 install in our state, since it uses much more energy

(202)2344433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331 2 3 4 5 6

8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 109

for heating, we consider it a heating appliance and therefore the 78 percent. or 80 percent minimum applies. Has DOE come out with anything on record on interpretation of the congressional record to clarify that particular issue?

MR. NASSERI: Realize the fact -- Cyrus Nasseri, DOE, that we do not have a minimum energy standard for this type of appliances at the present time. And the first thing to do is basically to have a test procedure, official test procedure, a DOE test procedure for rating these appliances. That's the first step, what we are doing at the,present time, to have a test procedure.

And then the next step would be to basically do the analysis which is DOE is basically signed by legislation, the type of things that we have to do as far as what would be the minimum energy efficiency for this type of appliances. And this wasn't originally the make up for these type of appliances. Again, you have to separate standards for this type of appliances, furnaces and for water heaters, minimum energy efficiency. But the issue is what would be the minimum energy efficiency standards

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 109 1 for heating, we consider it a heating appliance and 2 therefore the 78 percent, or 80 percent minimum 3 applies. 4 Has DOE come out with anything on record 5 on interpretation of the congressional record to 6 clarify that particular issue? 7 MR. NASSER!: Realize the fact

-- Cyrus 8 Nasseri, DOE, that we do not have a minimum energy 9 standard for this type of appliances at the present 10 time. And the first thing to do is basically to have 11 a test procedure, official test procedure, a DOE test 12 procedure for rating these appliances. That's the 13 first step, what we are doing at the'present time, to 14 have a test procedure. 15 And then the next step w'ould be to 16 basically do the analysis which is DOE is basically 17 signedby legislation, thetypeof things thatwe have 18 to do as far as what would be the minimum energy 19 efficiency for this type of appliances. And this 20 wasn't originally the make up for these type of 21 appliances. 22 Again, you have to separate standards for 23 this type of appliances, furnaces and for water 24 heaters, minimum energy efficiency. But the issue is 25 what would be the minimum energyefficiency standards

(202)234-4433 NEALA. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44331 2 3 4

6 7 8 9 10 11 12 13 .14 15 16 17 18 19 20 21 22 23 24 25 110

for the combined appliances, and that's something that DOE has to look at to see what legal or what engineering of final test is.

MR. RANFONE: Well, Cyrus, I understand that part. The question is that when you are selling in a state that has either high peak load hours or -- for that matter some of the states are suggesting or stating that we have to meet the efficiency for the heating portion of that combined appliance. And what you just said was, as I understand it, that DOE would come back and say that equipment isn't rated now, we don't have any test methodology, there 's no minimums for that, and would you go one step further and say that in reviewing the congressional record the intent is that the product has to meet only the minimum for its primary function?

MODERATOR LANGMEAD: Gene, do you want to respond to that?

MR. MARGOLIS: Eugene Margolis, DOE. If you feel that the state is preempted by the 'legislation and the state disagrees with you and is applying their own standards to a product that you feel is preempted, it would then be for you to go into the state court or into federal court in that state and bring an action against that state energy office

(202) 2344433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 110 1 for thecombinedappliances, andthat's somethingthat 2 DOE has to look at to see what legal or what 3 engineering of final test is. 4 

### MR. RANFONE: Well, Cyrus, I understand 5 that part. The question is that when you are selling 6 in a state that has**ei~her** 

### high peak load hours or 7 for that matter some of the states are suggesting or 8 stating that we have to meet the efficiency for the 9 heating portion of that combined appliance. And what 10 you just said was, as I understand it, that DOE would 11 come back and say that equipment isn't rated now, we 12 don't have any test methodology, there's no minimums 13 for that, and would you go one step further and say .14 

### that inreviewing the congressional record the intent

15 is that the product has to meet only the minimum for 16 its primary function? 17 

### MODERATOR LANGMEAD: Gene, do you want to 18 respond to that? 19 MR. MARGOLIS: Eugene Margolis, DOE. If 20 you feel that the state is preempted by the 21 'legislation and the state disagrees with you and is 22 applying their own standards to a product that you 23 feel is preempted, itwould thenbe for you togo into 24 the state court or into federal court in that state 25 and bring an action against that state energy office

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44332 3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 111

or whatever office of that state is implementing it.

Because that is something that the state is doing that, if you feel is improper, you can take legal remedies against the state based on the statute with it's section on preemption. But that is not, as Cyrus said, we're coming out or we will investigate on 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 cannot 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 little thought on that. Is there some reason that if a manufacturer wrote to you and said we believe the state is preempted because of the way it's covered in the act and the primary function is covered, do you agree with us, couldn't you write back to that manufacturer?

MR. MARGOLIS: Well, in the past we have not. We have just said that that argument , since it is argumentative, it's something for you to take up

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 III 1 or whatever office of that state is implementing it. 2 Because that is something that the state 3 is doing that, if you feel is improper, you can take 4 legal remedies against the statebased on the statute 5 with it's section on preemption. But that is not, as 6 Cyrus said, we'recoming out orwe will investigateon 7 this combinationappliance, butwe do not, we have not 8 done in the past, when we have been asked by 9 manufacturers to go to some states and tell themthat, 10 you know, you cannot have standards, you cannot 11 enforce state standards on these products because the 12 statute says it's preempted and gives the state a 13 remedy to come to us to get and exemption from 14 preemption. We do not go into the states and tell 15 them how they should do their business. 16 MODERATOR LANGMEAD: Gene, one little 17 thought on that. Is there some reason that if a 18 manufacturer wrote to you and said we believe the 19 state is preempted because of the way it's covered in 20 the act and the primary function is covered, do you 21 agree with us, couldn't you write back to that 22 manufacturer? 23 MR. MARGOLIS: Well, in the past we have 24 not. We have just said that that argument, since it 25 is argumentative, it's something for you to take up

(202)2344433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202)234-44332

4

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 112

with the state. And if the state disagrees with you, then your remedy lies in the court system to tell the state that they are preempt.

MODERATOR LANGMEAD: Mike? MR. McCABE: Michael McCabe, Department of Energy. To answer to your question, we have not addressed that issue, we have not come out with any position on that matter. I'm not aware that it has been put to us in a formal fashion. We have in the past offered to manufacturers and others in response the question, you placed, Jack, interpretations with respect to our regulations. But when it gets to the 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 have not been able to address those because it's a state issue and we do not have any standard defense on the question. If the question is put to us, we will certainly be required to consider it, but what sort of consideration, how we would respond to it would depend 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) 234-4433 

### 112 1 with the state. And if the state disagrees with you, 2 then your remedy lies in the court system to tell the 3 state that they are preempt. 4 

### MODERATOR LANGMEAD: Mike? 5 

### MR. McCABE: MichaelMcCabe, Departmentof 6 

### Energy. To answer to your question, we have not 7 addressed that issue, we have not come out with any 8 

### position on that matter. I'm not aware that it has 9 been put to us in a formal fashion. We have in the 10 past offered to manufacturers and others in response 11 the question, you placed, Jack, interpretations with 12 respect to our regulations. But when it gets to the 13 states and what the states can do, there is a wide 14 range of law that goes beyond our regulations. 15 And inmany instances in the past we have 16 not been able to address those because it's a state 17 issue and we do not have any standard defense on the 18 question. I f the question is put to us, we will 19 certainlyberequired toconsiderit, butwhat sortof 20 consideration, howwe wouldrespondto itwoulddepend 21 upon the nature of the question and the issues at 22 hand. 23 MODERATOR LANGMEAD: Very useful. 24 Other comments?' Were there any other 25 questions for Ed Pollock? He had gone through a

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44332 3 4

7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 113

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 we start on some open discussion on this issue? Everybody happy with where we are.

There were a number of questions on the sheet, and I'd like to move the first one down a little bit and talk about identifying all types of multifunctional residential HVAC appliances now in the marketplace and how the energy efficiency of each appliance type is currently being described.

Ed and George both basically described most of those products. Is there anything more to say on that point?

Mike? MR. McCABE: Michael McCabe. This is getting into an area where I as the Director of the Office of Codes and Standards am particularly interested and concerned with. What Ed has described, what George has described essentially a number of different measures of efficiency.

In a manner of speaking right now we have AFUE, we have energy factor in the test procedure, we have SHBF, we have the COP that's floating around, we have SEER, EERs , and now enhanced or equivalent

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 113 1 presentation for George. No more questionsonthose. 2 Are the major interest groups, does AGA, 3 ARI, GAMA or EEl have anything else to say before we 4 start on some open discussion on this issue? 5 Everybody happy with where we are. 6 There were a number of questions on the 7 sheet, and I'd like to move the first one down a 8 Iitt1e bit and talk about identifying all types of 9 

### multifunctionalresidentialHVAC appliancesnowinthe 10 marketplace and how the energy efficiency of each 11 appliance type is currently being described. 12 Ed and George both basically described 13 most of those products. Is there anythingmore to say 14 on that pOint? 15 Mike? 16 MR. McCABE: Michael McCabe. This is 17 getting into an area where I as the Director of the 18 Office of Codes and Standards am particularly 19 interestedandconcernedwith. What Edhas described, 20 what George has described essentially a number of 21 different measures of efficiency. 22 In a manner of speaking right now we have 23 AFUE, we have energy factor in the test procedure, we 24 have SHBF, we have the COP that's floating around, we 25 have SEER, EERs, and now enhanced or equivalent

(202)234-4433 NEAL

### A. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44331 2 3 4

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 114

values. And as we have these variety of products going into the market, Richard Sweetser had mentioned about -- products later this afternoon, engine driven. And a concern which I have is are we going to end up with such an array of efficiency descriptors back to the consumer we do not provide any valuable information. When I look at the Hydrotech 2000 and it' s attempt to over-simplify things in describing, and I'll make some apologies beforehand, that it did not succeed in the marketplace some could argue because consumers didn't understand the product, because the utilities and the demand-side management programs were every strong when that product came out, that the DOE

measures that we offered in the waiver were such that one could say that we failed in providing a meaningful measure of efficiency for the market.

Whether or not that market, individual

consumers , are looking at fact sheets, directories, talking to contractors, that market is utilities and the rebate programs , what have you, that maybe we failed by coming up with values that from an engineering perspective, I think in this group we have very few people who are not engineers, I with an engineering degree tend to follow my micrometer to

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 114 1 

### values. And as we have these variety of products 2 going into themarket, Richard Sweetser had mentioned 3 about

-- productslaterthis afternoon, enginedriven. 4 And a concern which I have is are we going to end up 5 with such an array of efficiency descriptors back to 6 the consumer we do not provide any valuable 7 information. 8 When I look at theHydrotech 2000 and it's 9 attempt to over-simplify things in describing, and 10 I'll make some apologies beforehand, that it did not 11 

### succeed in the marketplace some could argue because 12 consumers didn't understand the product, because the 13 utilitiesandthedemand-sidemanagementprogramswere 14' 

### every strong when that product came out, that the DOE 15 measures that we offered in the waiver were such that 16 onecould saythatwe failed inprovidinga meaningful 17 measure of efficiency for the market. 18 Whether or not that market, individual 19 consumers, are looking at fact sheets, directories, 20 talking to contractors, that market is utilities and 21 the rebate programs, what have you, 

### that maybe we 22 failed by coming up with values that from an 23 engineeringperspective, I thinkinthis groupwe have 24 very few people who are not engineers, I with an 25 engineering degree tend to follow my micrometer to

(202)234-4433 

### NEALR. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44331 2

4

6 7 8

10 ,11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 115

measure the thickness of a pillow. I think in this case, a yardstick in some cases is all that's necessary. And it may be that we have gotten to caught up with what is the precise measure without really understanding or appreciating what will be meaningful to the market and what will help bring the product, some of these new advance designs into the product and promote their sales.

Because one of the major parts of our responsibilities for the Department is to promote energy efficiency and reduce reductions in energy consumption. And some of these new and exciting products that are coming out, we cannot come up with something to help market them, help the electric utilities, help the 'gas utilities market for the manufacturers. We failed, and I hope that we can put the micrometers away and really look at what needs to be done and work with that in the back of your minds as well. MODERATOR LANGMEAD: Anybody want to 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 the combined cycle systems. And we were going to come up

(202) 234.4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 115 1 measure the thickness of a pillow. I think in this 2 case, a yardstick in some cases is all that's 3 

### necessary. And it may be that we have gotten to 4 caught up with what is the precise measure without 5 really understanding or appreciating what will be 6 meaningful to the market and what will help bring the 7 product, some of these new advance designs into the 8 product and promote their sales. 9 Because one of the major parts of our 10 responsibilities for the Department is to promote .11 eoergy efficiency and reduce reductions in energy 12 consumption. And some of these new and exciting 13 products that are coming out, we cannot come up with .14 something to help market them, help. the electric

15 utilities, help the 'gas utilities market for the 16 manufacturers. We failed, and I hope that we can put 17 the micrometers away and really look at what needs to 18 be done and work with that in the back of your minds 19 as well. 20 

### MODERATOR LANGMEAD: Anybody want to 21 respond at all to Mike on that, or add something? 22 Yes? 23 MR. MARRAN: JohnMarran, EnergyKinetics. 24 I came to a meeting in 1985 in which we discussed the 25 combined cycle systems. And we were going to come up

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-44331

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 116

with -- 124 reports, recommendations, efficiency numbers, and here it is 1995 and we still do not have to through the Department of Energy a descriptor that allows a manufacturer such as Carrier or myself to accurately portray the advantages of a combined cycle system. And I've got to say it's very difficult to operate in a world where you are "not in-the system, not recognized, no way to evaluate you," and I've got to say it's very discouraging. So we came out with the combined cycle system in 1980 and we think we do a super job. And the marketplace where they're installed thinks we do a super job, but we can't publish any efficiency number that is meaningful.

MODERATOR LANGMEAD: We do have, and Ed went through the status of ASHRAE 137 and the ARI standard air conditioning and heat pump equipment including a -- of water heating devices, and then there is ASHRAE standard 124 that covers the furnace boiler, fossil fuel furnace boiler water heater. Is there a deficiency in those standards that doesn't cover the products?

Dave? MR. LEWIS: Dave Lewis, Lennox. Lennox Industries feels very comfortable with both ASHRAE 124

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 116 1 

### with 124 reports, recommendations, efficiency 2 numbers, and here it is 1995 and we still do not have 3 to through the Department of Energy a descriptor that 4 allows a manufacturer such as Carrier or myself to 5 accuratelyportray the advantages of a combined cycle 6 system. 7 And I'vegotto sayit'sverydifficultto 8 operate in a world where you 

### are "not in the system, 9 not recognized, no way to evaluate you," 

### and I've got 10 to say it's very discouraging. So we came out with 11 the combined cycle system in 1980 and we think we do 12 a super job. And the marketplace where they're 13 

### installed thinks we do a super job, but we can't 14 publish any efficiency number that is meaningful. 15 MODERATOR LANGMEAD: We do have, and Ed 16 

### went through the status of ASHRAE 137 

### and the ARI 17 

### standard air conditioning and heat pump equipment 18 including a -- of water heating devices, and then 19 there is ASHRAE st.andard 124 that covers the furnace 20 boiler, fossil fuel furnace boiler water heater. Is 21 there a deficiency in those standards that doesn't 22 cover the products? 23 Dave? 24 MR. LEWIS: Dave Lewis, Lennox. Lennox 25 Industries feelsverycomfortablewithbothASHRAE 124

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON. D.C.20005 (202)234-44331 2 3 4 5 6

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 117

and 137, feels they are adequate . And that we should 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't think there 's any doubt that'the underlying technical substance is there to justify these different descriptors. But once again it sounds as though the conversation is heading, back to cost and what happens out in the marketplace. Apparently there is no 'descriptors for the multifunction appliances there to compete against the separate systems, and we need to get back to cost because that is going to be thecommon denominator among the operation of all theseappliances. That's certainly something that the consumer understands , and I think that we should focus on how to get a cost number out there that will allow that type of comparison.

MODERATOR LANGMEAD: Don't let me put words in your mouth, but are you saying that with the use of 137 , the ARI standard for heat pumps including -- water heating devices, and in 124 you've got basis to come up with cost numbers. And if that was promoted and recognized and you could work toward the 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) 234-4433 117 1 and 137, feels they are adequate. And that we should 2 follow with that the professional end of our industry 3 has put together. I think what we see there is fair 4 and pretty easy to apply. 5 MR. KALISCH: Bert Kalisch, AGA. I don't 6 think there's anydoubt that the underlying technical 7 substance is there to justify these different 8 descriptors. But once again it sounds as though the 9 conversation is heading'back to cost and what happens 10 out in the marketplace. Apparently there is no 11 descriptors for the multifunction appliances there to 12 compete against the separate systems, and we need to 13 get back to cost because that is going to be the 14 common denominator among the operation of all these' 15 appliances. ,That's certainly something that the 16 consumerunderstands, and I thinkthatwe should focus 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 put 20 words in your mouth, but are you saying that with the 21 use of 137, the ARI standard for heat pumps including 22

-- water heating devices, and in 124 you've got a 23 basis to come up with cost numbers. And if that was 24 promoted and recognized and you could work toward the 25 process of DOE adopting those standards at some time.

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N,W, WASHINGTON. D,C,20005 (202)234-4433118 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. As far as I know 124 does not provide the means to 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 for estimating operating cost?

MR. POLLOCK: Yes. MR. RANFONE: 124 does not. MODERATOR LANGMEAD: Joe, is there a reason why 124 doesn't cover, do you have any history on why 124 doesn't cover method of getting the operating cost?

MR. PIETSCH: If you know what the equivalent AFUE and equivalent energy factor is for a particular product, you could use the water heating

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 118 1 But you can get the cost numbers. 2 Dan? 3 

### MR. DEMPSEY: Dan Dempsey, Carrier. As 4 far as I know 124 does not provide the means to 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: Itdoeshave a procedure for 16 estimating operating cost? 17 MR. POLLOCK: Yes. 18 MR. RANFONE: 124 does not. 19 MODERATOR LANGMEAD: Joe, is there a 20 reasonwhy 124 doesn't cover, do you have any history 21 on why 124 doesn't cover method of getting the 22 operating cost? 23 MR. PIETSCH: If you know what the 24 equivalent AFUE and equivalent energy factor is for a 25 particular product, you could use the water heating

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331 2 3

5

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 119

procedure for calculating annual. energy costs and use the furnace procedure for calculating annual energy cost. So there was no need to duplicate that particular procedure in a national standard.

It could have been put in there, but it would have to be duplicating exactly what was in, you know, existing procedures.

MODERATOR LANGMEAD: Dan, do you want to respond? MR. DEMPSEY: That's true on a national average basis, but you go back to the definition of primary function. I mean DOE region four, a water heater that's large enough to heat heating space, the space heating cost would probably be four to five times the water heating cost. So it's not something that can be just literally extracted and extrapolated to other regions of the country.

MR. PIETSCH: But that's considered a shortcoming that the -- brought up. The electric standard was written quite a few years ago, it was completed five years ago, but was written ten years ago. MODERATOR LANGMEAD: Am I hearing some kind of kind of universal agreement that in the revision process of 124 we should encourage that group

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 119 1 procedure for calculating annual energycosts and use 2 the furnace procedure for calculating annual energy 3 

### cost. So there was no need to duplicate that 4 particular procedure in a national standard. 5 It could have been put in there, but it 6 would have to be duplicating exactly what was in, you 7 know, existing procedures. 8 

### MODERATOR LANGMEAD: Dan, do you want to 9 respond? 10 

### MR. DEMPSEY: That's true on a national 11 average basis, but you go back to the definition of 12 primary function. I mean DOE region four, a water 13 heater that's large enough to heat heating space, the 14 space heating cost would probably be four to five 15 times the water heating cost. So it's not something 16 that canbejust literallyextracted and extrapolated 17 to other regions of the country. 18 MR. PIETSCH: But that's considered a 19 shortcoming that the brought up. The electric 20 standard was written quite a few years ago, it was 21 completed five years ago, but was written ten years 22 ago. 23 MODERATOR LANGMEAD: Am 

### I hearing some 24 kind of kind of universal agreement that in the 25 revisionprocessof 124we shouldencouragethat group

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44331 2

4 5 6 7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 120

to look at methods of getting back to annual operating cost and getting down the specific application and location? MR. PIETSCH: I think that should be an individual concern and they can address that.

MODERATOR LANGMEAD: I was just trying to raise if there is concern in this audience. In the end we're going to ask for people to, if you want to supplement any of the things that are said here, please feel free to do so in writing. We're just trying to get to where we have no objection in this

room. Frank?

MR. STANONIK: Frank Stanonik with GAMA. One of the questions on the agenda outline here is, is there a need to develope a simple way to combine the ratings for different functions of combined products in such a way that they can be compared to single function products. And I think you heard the discussions earlier from George Kelly and others that that presents a challenge simply because how you choose to allocate your savings can be somewhat arbitrary. And in fact I think in any way. how you do it, it' s somewhat arbitrary.

And because of that, I think what you were

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 23444333 WASHINGTON, D.C. 20005 (202) 2344433 

### 120 1 to look at methods of gettingback to annual operating 2 cost and getting down the specific application and 3 location? 4 

### MR. PIETSCH: I think that should be an 5 individual concern and they can address that. 6 

### MODERATOR LANGMEAD: I was just trying to 7 

### raise if there is concern in this audience. In the 8 end we're going to ask for people to, if you want to 9 supplement any of the things that are said here, 10 please feel free to do so in writing. We're just 11 trying to get to where we have no objection in this 12 room. 13 Frank?

.14 

### MR. STANONIK: Frank Stanonik with GAMA

.

15 One ofthequestions onthe agenda outlinehere is, is 16 there a need to develope a simple way to combine the 17 ratings for different functions of combined products 18 in such a way that they can be compared to single 19 function products. And I think you heard the 20 discussions earlier from George Kelly and others that 21 that presents a challenge simply because how you 22 choose to allocate your savings can be somewhat 23 arbitrary. And in fact I think in anyway. how you do 24 it, it's somewhat arbitrary. 25 And becauseofthat, I thinkwhatyouwere

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C.20005 (202)234-44331 2 3 4

7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 121

saying, Jack, that perhaps the agreeable approach would be to come up with method or methods where you could get to a annual cost of operation, in which case you don't have to worry about separate efficiencies of separate functions, but the bottom line which is what is it going to cost the consumer on an annual basis to run this combined appliance, doing all its jobs, or what's it going to cost this consumer to run a separate water heater, a separate furnace, a separate boiler or whatever.

To me there is a desirable simplicity to in fact try and go in direction of when you get to the point of comparing combined appliances with other things rather than try and manipulative effective efficiencies or what have you, it should be just looking at the cost of operation.

MODERATOR LANGMEAD: Dave Lewis? MR. LEWIS: Dave Lewis, Lennox. We feel like the ASHRAE process is'the process that needs to be used. It gives the opportunity, unlike a meeting of this sort, for specific issues to be addressed and dug into. It's real difficult to try to catch this issue in a U-shaped table, and the kind of discussion that we're having because there is a lot of aspects to 25 11 it.

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 121 1 saying, Jack, that perhaps the· agreeable approach 2**wou~d** be to come up with method or methods where you 3**cou~d** get to a annual cost of operation, inwhichcase 4 you don'thavetoworryabout separateefficienciesof 5 separate functions, but the bottom line which is what 6 is it going to cost the consumeron an annual basis to 7 run this combined appliance, doing all its jobs, or -8 what's it going to cost this consumer to run a

9 separate water heater, a separate furnace, a separate 10**boi~er** or whatever. 11 To me there is a desirable simplicity to 12 in fact try and go in direction of when you get to the 13 point of comparing combined appliances with other 14 things rather than try and manipulative effective 15 efficiencies or what have you, it should be just 

### 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 to 20 be used. It gives the opportunity, unlike a meeting 21 of this sort, for specific issues to be addressed and 22 dug into. It's real difficult to try to catch this 

### 23 issue in a U-shaped table, and the kind of discussion 24 that we'rehaving because there is a lot of aspects to 25 it.

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. NW. WASHINGTON. D.C.20005 (202)234-44331 2

4

6

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 122 I guess we would encourage the effort being put into ASHRAE and supporting ASHRAE in the development and further enhancement even of the standards as they exist. We basically believe that there is adequate information available through 124 and 137 to come up to an consumer making a good decision. But there is still that unique aspect of where the residence is, how many people are there. If it's anything like my home, how many teenagers are in the home as far as how much hot water is used. I mean there are a lot of very specific issues that need to be looked at that can only be looked at as the consumer uses the product.

MODERATOR LANGMEAD: Agreed. And I think, Dave, and what Frank said, about the only way you're ever going to get back there in comparing against different product types is not with different descriptors but with dollars or cost at the site. I think it's the only simple way to get there.

Other questions? Frank brought up, he came into the point of if there was need to develope a single way to compare ratings, that's why I left that down because I thought that would fall out of the other discussion.

(202) 234-4433 The last question on the sheet was use of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 

### 122 1 

### I guess we would encourage the effort 2 being put into ASHRAE and supporting ASHRAE in the 3 development and further enhancement even of the 4 standards as they exist. We basically believe that 5 there is adequate information available through 124 6 and 137 to come up to an consumer making a good 7 decision. But there is still that unique aspect of 8 where the residence is, how manypeople are there. If 9 it's anything likemy home, how many teenagers are in 10 the home as far as how much hot water is used. I mean 11 there are a lot of very specific issues that need to 12 be looked at that can only be looked at as the 13 consumer uses the product. ·14 MODERATOR LANGMEAD: Agreed. And I think, 15 Dave, and what Frank said, about the only way you're 16 ever going to get .back there in comparing against 17 different product types is not with different 18 descriptors but with dollars or cost at the site. I 19 think it's the only simple way to get there. 20 Other questions? 21 Frank brought up, he came into the point 22 of if there was need to develope a single way to 23 compare ratings, that's why I left that down because 24 I thought thatwould fallout of theotherdiscussion. 25 The last question on the sheet was use of

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)23444331 2

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 123

separate descriptors for each energy source used by an appliance. Would consumers have adequate means to calculate an annual operating cost. I think if we base that, if the ASHRAE procedures are looked at, you can get there, and at the present time we don't have it and people have said they'd like DOE to use that ASHRAE process.

Are there other comments or something that anybody else wants to add on this whole theory of multifunction appliances, or is there anything that anybody from DOE wants to raise and get a response to?

Now, with that, unless somebody has something else to add, it's a good time to break for lunch. It's 11:58. Is everybody happy on breaking for lunch with that point? Lunch, and we'll be back here, I think we're planning to be back here at 1:30, is that correct?

(Whereupon , at 12:00 p.m., the proceedings in the above entitled matter were adjourned to

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) 234-4433 

### 123 1 separatedescriptors foreachenergysourceusedbyan 2 appliance. Would consumers have adequate means to 3 

### calculate an annual operating cost. I think if we 4 base that, if theASHRAE procedures are looked at, you 5 can get there, and at the present time we don't have 6 it and people have said they'd like DOE to use that 7 ASHRAE process. 8 Arethereothercommentsorsomethingthat 9 anybody else wants to add on this whole theory of 10 multifunction appliances, or is there anything that 11 anybody from DOE wants to raise and get a response to? 12 Now, with that, unless somebody has 13 something else to add, it's a good time to break for 14 lunch. It's 11:58. Is everybody happy on breaking 15 for lunch with that point? Lunch, and we'll be back 16 here, I think we're planning to be back here at 1:30, 17 is that correct? 18 (Whereupon, at 12:00p.m., theproceedings 19 in the above entitled matter were adjourned to 20 reconvene this same day at 1:14 p.m.) 21 22 23 24 

### 25

(202)234-4433 NEAL

### A. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-4433124 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 time 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 that off Frank Jakob has a little briefing on the ANSI 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 me describes the situation that we enter into beyond just multi-fuel appliances like we talked about this morning, gas furnaces'that consume electricity, but these higher level multi-fuel appliances, gas heat pumps that use less gas but more electricity and proportionately that changes.

And what this is, along the bottom axis, is gas in therms, and out there , there are gas furnaces that consume so much gas, and this is for a

(202) 234.4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON

. D.C. 20005 (202) 234-4433 

### 124 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're 4 readytoreconvene. We'vebeenthroughthe subjectof 5 energy efficiency descriptors thatwe might have time 6 

### to come back to again this afternoon. We've gone 7 through multifunction appliances.- I hope everybody 8 had a good relaxed lunch. 9 At this time we'd like to start into the 10 subject of multi-fuel heat pumps. And to kick that 11 off Frank Jakob has a little briefing on the ANSI 12 Z2l.40.4 standard, and we'll start off with that and 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 me 17 describes the situationthatwe enterintobeyondjust 18 multi-fuel appliances like we talked about this 19 morning, gas furnaces that consume electricity, but 20 these higher level multi

-fuel appliances, gas heat 21 pumps that use less gas but more electricity and 22 proportionately that changes. 23 And what this is, along the bottom axis, 24 is gas in therms, and out there, there are gas 25 furnaces that consume so much gas, and this is for a

(202)234-4433 NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331

4

6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 125

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 is such that the purple appliances are heating appliances. It should be the bluish appliances are exclusively cooling appliances. We've got gas air conditions over here that consume a significant amount gas and some electricity. We have air conditioners, electric air conditions, over here that consume exclusively electricity.

The hatching means that there are standards for those appliances. There are efficiency .standards for air conditions. There are efficiency standards for heat pumps, electric furnaces, gas air conditioners. This should be cross hatched here, and these are gas furnaces.

But then the other appliances in green are appliances that perform multifunctions as well using increasing amounts of both types of fuel. And for

(202) 234.4433 - NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 125 1 standard 36,000 BTU per hour heating load, a house 2 

### thathasthischaracteristic. And combinationsystems 3 

### do both the heating and the water heating functions, 4 

### so they consume a little more gas. And they're 5 

### slightlyoff the axis,here because this vertical axis 6 

### is the amount o'f electric the appliance consumes. 7 

### And along this axis we've got air 8 

### conditioners that consume exclusively electricity, 9 

### heatpumps, electric furnace. And thecolorcoding is 10 such that the purple appliances are heating 11 appliances. It should be the bluish appliances are 12 exclusively cooling appliances. We've got gas air 13 conditionsoverherethatconsumea significantamount 14 

### of gas and some electricity. We have air 15 conditioners, electric air conditions, overhere that 16 consume exclusively electricity. 17 

### The hatching means that there are 18 standards for those appliances. There are efficiency 19 .standards for air conditions. There are efficiency 20 standards for heat pumps, electric furnaces, gas air 21 conditioners. This shouldbe cross hatched here, and 22 these are gas furnaces. 23 Butthentheotherappliances ingreenare 24 appliances that perform multifunctions as well using 25 increasing amounts of both types of fuel.

(202)234-4433

. 

### NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NoW. WASHINGTON,D.C, 20005 

### And for

(202)234-44332 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 126

instance over here is the gas heat pump. It used more gas than your gas furnace because it's doing both the 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 furnace 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 to 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) 2344433 

### 126 1 instance over here is the gas heat pump. Itused more 2 gas thanyour 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 more 7 

### electricity. And then you can conceive of other 8 systems. Here is where gas furnaces and electric air 9 conditioners might as a system, if theywere going to 10 be rated in some fashion. Here is where gas furnaces 11 with heat pumps stand. That is an add-on gas furnace 12 to a heat pump, it uses less energy than a gas 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 parallel 16 lines that indicate dollars per year for operating 17 cost. 18 And it seems like ifyou consider this to 19 be a lake, you know, where the edge around here is 20 like the shore, as long as we're on the shore, we're 21 fine. You know, we're over here on the shore 22 exclusively electricity, we've got AFUE for electric 23 furnaces, heat pumps, air conditioners. 24 We staydownhereonthe shoreorcloseto 25 the shore with gas furnaces, gas air conditions, but

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C.20005 (202)234-44332 3 4 5

7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 127

these new systems came in, combo systems, and they started confusing the issue. And once you're off the shore, swimming here in the water, those are a variety of appliances that are coming out and that's the situation that this ANSI committee tried to deal with when it comes to gas heat pumps.

I'll summarize first. My premise, and this was affirmed this morning, is that right now there are very well established procedures for taking the efficiency of a covered product in calculating operating costs. You've heard about that today, the GAMA directory allows you to calculate operating costs based on some function of its efficiency, the load and energy cost. There's a worksheet right in the front of the GAMA director that's derived directly from the test procedure. And -- director, so too. In front of there, there is a worksheet that allows you calculate operating cost based on SEER load and energy cost, operating cost based on for heat pump, HSPF load and energy cost. And so given that, I'm assuming that premise is correct, does anybody object to that? Given those mathematical functions then, they were there for inverse functions where you could calculate efficiency if you know the operating cost. That is

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 127 1 these new systems came in, combo systems, and they 2 started confusing the issue. And once you're off the 3 shore, swimming here in thewater, those are a variety 4 of appliances that are coming out and that's the 5 situation that this ANSI committee tried to deal with 6 when it comes to gas heat pumps. 7 I'll summarize first. My premise, and 8 this was affirmed this morning, is that right now 9 there are very well established procedures for taking 10 the efficiency of a covered product in calculating 11 operating costs. You've heard about that today, the 12 GAMAdirectoryallowsyou tocalculateoperatingcosts 13 basedon some function of its efficiency, the load and ·14 energy cost. There's a worksheet right in the front 15 of the GAMA director that's derived directly from the 16 testprocedure. And

- - director, so too. In front of 17 there, there is a worksheet that allows you calculate 18 operating cost based on SEER load and energy cost, 19 operating cost based on for heat pump, HSPF load and 20 energy cost. 21 And so given that, I'm assuming that 22 premise is correct, does anybody object to that? 23 Given those mathematical functions then, they were 24 there for inverse functions where you could calculate 

### 25 efficiency if you know the operating cost.

(202)234-4433 NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 That is

(202)234-4433128 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 is

a simple mathematical, well not so simple, there is a mathematical relationship that would allow you to calculate an AFUE if you knew the operating cost, the load and the energy cost. Same too with the SEER, if you knew the operating cost, full load and the energy cost. Putting that all together what will appear in the ANSI standard, what has appeared, for gas heat pump, given an operating cost, and there is a main body of the standard that specifies a whole slew of steady state, cyclic tests, that allow you to develope 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 a gas heat pump that heats, what would be the efficiency, what would be the AFUE of the same. gas furnace that has that operating cost? It's a simple question and it's easily calculated mathematically.

Given the cooling operating cost for the gas heat pump, answer the question, what is the efficiency of a same size electrical air conditioner that has the same operating cost? That's a question 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) 234-4433 

### 128 1 given those equations on the previous table, there is 

### 2 a simple mathematical, well not so simple, there is 

### a 3 mathematical relationship that would allow you to 4 calculate anAFUE if you knew the operating cost, the 5 load and the energy cost. Same too with the SEER, if 6 you knew the operating cost, full load and the energy 7 cost. 8 Puttingthatalltogetherwhatwillappear 9 in the ANSI standard, what has appeared, for gas heat 10 pump, given an operating cost, and there is 

### a main 11 body of the standard that specifies a whole slew of 12 steadystate, cyclictests, that allowyoutodevelope 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 a 16 gas heat pump that heats, what would be the 17 efficiency, what would be the AFUE of the same gas 18 furnace that has that operating cost? It's a simple 19 question and it's easily calculated mathematically. 20 Given the cooling operating cost for the 21 gas heat pump, answer the question, what is 

### the 22 efficiency of a same size electrical air conditioner 23 that has the same operating cost? That's a question 24 that I as a consumer want to know. 25

(202)234-4433 

### MR. NASSERI: Frank? NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. NoW. WASHINGTON. D.C. 20005 (202)234-4433129 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 on the standard, in 1984 there is a committee -- well, the committee process started, and in 1984 to '86 the need for the standard developed. That is there was a renewed interest in developing gas heat pumps, a number of companies, there were seven to ten research 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 pump related equipment, a variety of equipment that's currently not covered under the auspices of some other committee. And they started working on the process, started developing various drafts and then that draft went out for public review and comment here in late 1992. The comments were assimilated by the committee and the final assessment of those comments went to the 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) 234-4433 

### 129 1 

### MR. JAKOB: Yes. \ i1'\-: {\.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 Togiveyou somehistoryandbackgroundon 7 

### the standard, in 1984 there is a committee

-- well, 8 the committee process started, and in 1984 to '86 the 9 

### need for the standard developed. That is there was a 10 renewed interest in developing gas heat pumps, a 11 

### number of companies, there were seven to ten research 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 ANSI 15 subcommittee that deals with gas appliances. It 16 covers gas heat pumps, fuel cells, gas heat pump 17 related equipment, a variety of equipment that's 18 currentlynotcoveredundertheauspices of someother 19 committee. And they started working on the process, 20 started developing various drafts and then that draft 21 went out for public review and comment here in late 22 1992. The comments were assimilated by the committee 23 and the final assessment of thosecommentswent tothe 24 parent committee. And that's when the committee 25 process ends.

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-44331 2 3 4 5 6 7 8 9 10 11 12 13 14 15 '16 17 18 19 20 21 22 23 24 25 130 The committee consists of a number of technical experts dealing with that area. And then 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 that 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 starting point. Back in the '60s there was an existing standard, Z21.40.2, gas engine driven summer air conditioning appliances, that had covered some appliances that were around at that time.

In 1972 that came up for renewal, as standards regularly do, at that point in time that product was no longer available and so it was withdrawn, but the standard did contain a section on how to measure the capacity of an appliance.' And so that was already established.

In 1984 gas engine heat pump development was revived. There were GRI projects, DOE projects, as well as private industry.

1986 and following Z21.40 committee

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON, D.C. 20005 (202) 234-4433 

### 130 1 

### The committee consists of a number of 2 technical experts dealing with that area. And then 3 it's passed off to ANSI, which is the American 4 National Standards Institute that goes on to confirm 5 thattheirprocessof affirming standards is inplace. 6 And then it goes through a public review comment 7 

### period. Those comments again are assimilated. 8 Finally the board of standards has. to review that 9 process at which time it becomes an**AS~RAE** 

### approved, 10 or an ANSI, I'm sorry, ANSI approved process. 11 GOingbackinhistorytherewas a starting 12 point. Back in the '60s there was an existing 13 standard, Z21.40.2, gas engine driven summer air 14 conditioning appliances, that had covered some 15 appliances that were around at that time. 16 In 1972 that came up for renewal, as 17 standards regularly do, at that point in time that 18 product was no longer available and so it was 19 withdrawn, but the standard did contain a section on 20 how to measure the capacity of an appliance. And so 21 that was already established. 22 In 1984 gas engine heat pump development 23 was revived. There were GRI projects, DOE projects, 24 as well as private industry. 25

(202)234-4433 

### 1986 and following Z21.40 committee NEAL R. GROSS COURTREPORTERSAND TRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON.D.C. 20005 (202)234-4433131 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 pump

working group. And that working group met twice a year usually in concert with ASHRAE meetings because many of the members were associated with ASHRAE members and that made it convenient. It also gave us a public forum in which to hold those meetings.

Between 1988 and 1991 the working group evolved the draft standard. They started with the previous one. They took a capacity section and expanded that also to measure steady state efficiency. And then they took the efficiency section and expanded that to measure cycling efficiency. We saw that first efficiency was a needed part of the standard, and second there had been developments in other appliances that had led to duty cycle efficiency and so that aspect was added to the work.

During the course of the work what was that standard was divided into two separate standards. Safety and operational performance that's now called Z21.40.2,, and the second section that was the capacity and efficiency performance. That had become a large enough document and separate enough from the safety aspects that really it didn't deserve to be covered by the same standard.

This item was then the capacity and

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 

### 131 1 established what they called the fuel gas heat pump 2 working group. And that working group met twice a 3 year usually in concert with ASHRAE meetings because 4 many of the members were associated with ASHRAE 5 members and that made it convenient. It also gave us 6 a public forum in which to hold those meetings. 7 Between 1988 and 1991 the working group 8 

### evolved the draft standard. They started with the 9 

### .previous one. They took a capacity section and 10 expandedthat alsotomeasure steadystateefficiency. 11 And thentheytooktheefficiencysectionand expanded 12 that tomeasurecyclingefficiency. We sawthat first 13 efficiency was a needed part of the standard, and 14 secondtherehadbeendevelopments inotherappliances 15 that had led to duty cycle efficiency and so that 16 aspect was added to the work. 17 During the course of the work what was 18 that standardwasdividedintotwo separatestandards. 19 Safety and operational performance that's now called 20 Z21.40.2" and the second section that was the 21 capacity and efficiencyperformance. That had become 22 a large enough document and separate enough from the 23 safety aspects that really it didn't deserve to be 24 covered by the same standard. 25

(202)234-4433 

### This item was then the capacity and NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44332 3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 132

efficiency performance standard evolved. It started as a single ANSI standard during the course of committee deliberations. It was separated into separate capacity and efficiency standards. And then based on discussions of the committee it ended up being a main standard and with an appendix which is an ANSI proof way of providing accompanying materials with any standard. It's now called Z21.40.4, and I've got a copy of it here, if anyone cares to look at it during one of the breaks.

That standard went out for public review in 1992. The Z21.40 subcommittee worked on the comments. They found that the main body received nothing but affirmative comments and yet the appendix received mixed comments. And so what the committee decided to do was to parallel those two sections. That is they broke out the main -body separate from the appendix. The main body in '93 was approved by the parent Z21 committee. It was forwarded to ANSI. In '94 it has its public review by ANSI, was approved by the board of standards review, and was published earlier this year.

There is some future work associated with harmonizing that standard with the Canadian standards as well as work associated with dovetailing it with

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 132 1 efficiency performance standard evolved. It started 2 as a single ANSI standard during the course of 3 

### committee deliberations. It was separated into 4 separate capacity and efficiency standards. And then 5 based on discussions of the committee it ended up 6 being a main standard and with an appendix which is an 7 ANSI proof way of providing accompanying materials 8 with any standard. It'snow calledZ2l.40.4, and I've 9 got a copy of it here, if anyone cares to look at it 10 during one of the breaks. 11 That standard went out for public review 12 in 1992. The Z2l.40 subcommittee worked on the 13 comments. They found that the main body received 14 nothing but affirmative comments and yet the appendix 15 received mixed comments. And so what the committee 16 decided to do was to parallel those two sections. 17 That istheybrokeout themain·body separate from the 18 appendix. The main body in '93 was approved by the 19 parent Z2l committee. It was forwarded to ANSI. In 20 '94 it has its public review by ANSI, was approved by 21 the board of standards review, and was published 22 earlier this year. 23 There is 

### some future work associatedwith 24 harmonizing that standardwith the Canadian standards 25 as well as work associated with dovetailing it with

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44332 3

6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 133

what is now an ASHRAE standard 40. That was the main body. The appendix, the comments were attended to by the Z21 committee . It was passed on and that took about two years worth or work, iterating with various commentators.

1995 we passed it along, the committee passed it along. It was approved by Z21 and it has been forwarded to ANSI where it sits right now in its future. There is a public review that's going to be held. Following that there is comment resolution that's required before it's ultimate dovetailing with the existing main body of the standard.

MR. WETHJE : Frank, could you just clarify, is it out for public review now, did you say?

MR. JAKOB: It's in ANSI's hands right now, and they are scheduling public review.

The scope of the standard is testing and rating gas fired heat pumps for space conditioning performance. And space directly, I divide directly heating and cooling the air, or space conditioning indirectly by producing either a heated or chilled fluid that then goes to some heat exchanges that provide the conditioning.

(202) 2344433. Scope covers factory made space NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON

. D.C. 20005 (202) 234-4433 133**~** 1 what is now an ASHRAE standard 40. That was the main 2 body. 3 The appendix, the comments were attended 4 to by**th~** Z21 committee. It was passed on and that 5 took about two years worth or work, iterating with 6 various commentators. 7 1995 we passed it along, the committee 8 passed it along. It was approved by z21 and it has 9 been forwarded to ANSI where it sits right now in its 10 future. There is a public review that's going to be 11 held. Following that there is comment resolution 12 that's required before it's ultimate dovetailing with 13 the existing main body of the standard. 14 MR. WETHJE: Frank, could you just 15 clarify, is itout for publicreviewnow, didyou say? 16 MR. JAKOB: It's in ANSI's hands right 17 now, and they are scheduling public review. 18 The scope of the standard is testing and 19 rating gas fired heat pumps for space conditioning 20 performance. And**sp~ce** directly, I divide directly 21 heating and cooling the air, or space conditioning 22 indirectly by producing either a heated or chilled 23 fluid that then goes to some heat exchanges that 24 provide the conditioning. 25

(202)234-4433 Scope covers factory NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODEISLANDAVENUE. NW. WASHINGTON.. D.C. 20005 made space

(202)234-44331 2 3 4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 134

conditioning unitary heat pumps that use gas as the primary fuel. For example engine driven, absorption or desiccant systems. Various controls are allowed in the standard, single level, on-off control, discrete level, multilevel control, or continuous variable control. It can provide either heating or a cooling function or both. The appliance may also include other functions such as water heating. All aspects of which we touched on this morning.

In addition the heat source or sink may be either outdoor air, groundwater, or a closed loop water loop. The main body of the standard consists of these sections which are pretty routine titles for any testing standard that will specify the testing required, the conditions, what procedures to follow, steady state tests that are required, seasonal test and calculations, annual performance, references, and sample calculations to help a user.

The basic approach is the same as that used with electric heat pump standards. That is to measure steady state cycling parameters, and then to use a temperature bin analysis to aggregate those results into a seasonable number.

From the main body of the standard comes

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 

### 134 1 conditioning unitary heat pumps that use gas as the 2 primaryfuel. Forexampleenginedriven, absorptionor 3 

### desiccant systems. Various controls are allowed in 4 the standard, single level, on-off control, discrete 5 level, multilevel control, or continuous variable 6 control. It can provide either heating or a cooling 7 

### function or both. The appliance may also include 8 other functions suchas waterheating. All aspectsof 9 which we touched on this morning. 10 Inadditiontheheat sourceor sinkmaybe 11 either outdoor air, groundwater, or a closed loop 12 water loop

.

.13 The main bodyof the standard consists of

14 these sectionswhichareprettyroutinetitlesfor any 15 testing standard that will specify the testing 16 required, the conditions, what procedures to follow, 17 steady state tests that are required, seasonal test 18 and calculations, annual performance, references, and 19 sample calculations to help a user. 20 The basic approach is the same as that 21 used with electric heat pump standards. That is to 22 measure steady state cycling parameters, and then to 23 use a temperature bin analysis to aggregate those 24 results into a seasonable number. 25 From the main body of the standard comes

(202)234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C.20005 (202)234-44331 2

4

6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 135

the bottom line performance to get the space conditioning load, to get the electric energy consumed by the appliance, and the gas energy consumed by the appliance, the bottom line numbers. And again, as I indicated during the public review, that received nothing but favorable comment.

The appendix, it's contents went on to say how to quantify its steady state cooling efficiency or heating efficiency, and then how to quantify their seasonal efficiencies, annual costs, and how to extend that also to commercial appliances.

The basic approach, as I mentioned at the beginning of my presentation, was to choose some normalizing parameter, it could be cost, it could be the local energy content, or some global energy content measure, but it provides not the specification of what to do, but the mathematical formulations of having decided what you the analyst want to do, how will you go about calculating them, and then determine the efficiency that some other appliance would have to have such that the value of the normalizing parameter is the same. For instance with the gas heat pump, it's operating cost is such that a furnace would need to have 125 percent AFUE in order to have the same operating cost.

(202) 2344433, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 135 1 the bottom line performance to get the space 2 conditioningload, togettheelectricenergyconsumed 3 by the appliance, and the gas energy consumed by the 4 appliance, the bottom line numbers. And again, as I 5 indicated during the public review, that received 6 nothing but favorable comment. 7 Theappendix, it'scontentswentonto say 8 how toquantifyits steadystatecoolingefficiencyor 9 heating efficiency, and then how to quantify their 10 seasonalefficiencies, annualcosts, andhow toextend 11 that also to commercial appliances. 12 The basic approach, as I mentioned at the 13 beginning of my presentation, was to choose some 14 normalizing parameter, it could be cost, it could be 15 the local energy content, or some global energy 16 contentmeasure, butitprovidesnotthe specification 17 of what to do, but the mathematical formulations of 18 having decided what you the analyst want to do, how 19 willyougoaboutcalculatingthem, andthendetermine 20 theefficiencythat some otherappliancewouldhaveto 21 have such that the value of the normalizing parameter 22 is the same. For instance with .the gas heat pump, 23 it's operating cost is such that a furnace would need 24 to have 125 percent AFUE in order to have the same 25 operating cost.

(202)234-4433. NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C.20005 (202)234-44331

3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 136 The bottom line performance then is the AFUE of a furnace having the same operating cost, or the SEER of an air conditioner that has that same operating cost. The appendix provides kind of a mathematical formulation which you otherwise might do by hand by crawling through the various directories, finding the correctly sized appliance, and finding ne 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 extremely clear. Everybody understood everything.

Are there any statements that any one of the major associations, ARI, GAMA, AGA, EEI, want to 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 for discussion items. The first one is basically, have all types of multi-fuel heat pumps been identified? It seemed to me that Frank covered that in his

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 136 1 The bottom line performance then is the 2 AFUE of a furnace having the same operating cost, or 3 the SEER of an air conditioner that has that same 4 operating cost. The appendix provides kind of a 5 mathematical formulation whichyou otherwise might do 6 by hand by crawling through the various directories, 7 finding the correctly sized appliance, and finding ne 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 extremely 13 clear. Everybody understood everything. ·14 Are there any statements that anyone of

15 the major associations, ARI, GAMA, AGA, EEl, want to 16 make before we start into point by point discussions. 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 for 23 discussion items. The first one is basically, have 24 all types of multi-fuel heat pumps been identified? 25 It seemed to me that Frank covered that in his

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. NW. WASHINGTON. D.C.20005 (202)23444331 2

4 5

7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 137

remarks. Does anybody have anything to add to those lists? The principal subject seems to be the gas engine driven heat pump that's currently entering the market. So nobody has anything add to identifying different types of products.

We've gone through the status and scope of the revisions of ANSI standard 40. Nobody has any comments. I assume everybody understands that process and they know that that standard, it will be announced for public review in and ANSI report shortly and so everybody will know somewhat of the time and they can get. a copy and comment on that.

Yes? MR. RYAN: Yes, just a quick comment on standard 40. Bill Ryan with GRI. I'm also the chair of the ASHRAE SPC40 committee. What we are in the process of doing is basically working toward a joint action between ASHRAE and the Z21 group so that we will have as a future standard a Z21/ASHRAE standard covering this type of equipment. The comments from the committee, the ASHRAE committee, that has reviewed the Z21 standard thus far has been very positive and they are in general very pleased with the work that

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 137 1 remarks. 2 Doesanybodyhave anythingtoaddtothose 3 lists? 4 The principal subject seems to be the gas 5 engine driven heat pump that's currently entering the 6 market. So nobody has anything add to identifying 7 different types of products. 8 We'vegonethroughthe statusand scopeof 9 the revisions of ANSI standard 40. Nobody has any 10 comments. I assumeeverybodyunderstands thatprocess 11 and theyknow that that standard, itwill beannounced 12 for public review in and ANSI report shortly and so 13 everybody will know somewhat of the time and they can 14 get, a copy and comment on that. 15 Yes? 16 MR. RYAN: Yes, just a quick comment on 17 standard 40. Bill Ryan with GRI. I'm also the chair 18 of the ASHRAE SPC40 committee. What we are in the 19 process of doing is basically working toward a joint 20 action between ASHRAE and the Z2l group so that we 21 will have as a future standard a Z21/ASHRAE standard 22 covering this type of equipment. The comments from 23 thecommittee, theASHRAE committee, thathas reviewed 24 the Z21 standard thus far has been very positive and 25 they are in general very pleased with the work that

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, NW. WASHINGTON, D.C.20005 (202)234-44332 3 4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 138

Z21 did including taking this all the way to an equivalent AFUE, an equivalent SEER type number that allows people, customers, whatever, obviously to make comparisons and also to avoid coming up with yet another energy descriptor that has to be explained to the industry.

We are looking at cross listing with ASHRAE probably on the republication of the Z21 standard which would not be until I think 1998. So basically ASHRAE's role on this 'has been far and away secondary to that of the Z21 committee that really did the development.

MODERATOR LANGMEAD: It's heartening to see the two organizations working together.

MR. RYAN: So far. MODERATOR LANGMEAD : Any other comments on either the ASHRAE or the Z21.40.4 process?

The next issue , item, on the agenda was statutory and marketplace limitations. And I think it's important to take those one at a time because they are distinctively different. On the statutory limitations I have a question of whether the sales volume of gas fired heat pumps at this point in time 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) 234-4433 

### 138 1 Z21 did including taking this all the way to an 2 equivalent AFUE, an equivalent SEER type number that 3 allows people, customers, whatever, obviously tomake 4 comparisons and also to avoid coming up with yet 5 another energy descriptor that has to be explained to 6 the industry. 7 

### We are looking at cross listing with 8 ASHRAE probably on the republication of the Z21 9 standard which would not be until I think 1998. So 10 basicallyASHRAE's role on this has been far and away 11 secondaryto thatof the Z21 committee thatreallydid 12 the development. 13 MODERATOR LANGMEAD: It's heartening to 14 see the two organizations working together. 15 MR. RYAN: So far. 16 MODERATORLANGMEAD: Anyothercommentson 17 either the ASHRAE or the Z21.40.4 process? 18 The next issue, item, on the agenda was 19 statutory and marketplace limitations. And I think 20 it's important to take those one at a time because 21 they are distinctively different. On the statutory 22 limi

### tations I have a question of whether the sales 23 volume of gas fired heat pumps at this point in time 24 qualifies it to be a NEACA covered product. 25 Does anybody know the answer to that?

(202) 234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331

4 5

7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 139 There is limitations in the volume of the product before you start on the NEACA legislation, and I can't remember what those limits are, but I don't think you have enough product there yet, right?

It was how much energy consumed when the product is in use?

MR. ADAMS: Carl Adams here. The only thing that comes to mind on that is there is a limit in there, 100 kilowatt hours per year, as I recall, for considering coverage of new products.

MODERATOR LANGMEAD: That's what I was 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 consumption level or not with this product, you know. I think we've got a good process going where people can get to cost of operation and make a comparison, and there should be, and there is, work going on that when the time comes DOE will have a test procedure you can probably adopt. And I think we all ought be looking in that direction.

Any other. comments on that thought process? 2511 It would seem to me, and I'm looking for

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 

### 139 1 There is limitations in the volume of the 2 productbeforeyou startontheNEACA legislation, and 3 I can't remember what those limits are, but I don't 4 think you have enough product there yet, right? 5 It was how much energy consumed when the 6 product is in use? 7 

### MR. ADAMS: Car1 Adams here. The only 8 thing that comes to mind on that is there is a limit 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 was 12 making reference to? 13 MR. ADAMS: So it's an energyconsumption. 14 

### MODERATOR LANGMEAD: Energy consumption. 15 And I don'tknowwhetherthat's theenergyconsumption 16 

### level or not with this product, you know. I think 17 we've got a goodprocess goingwherepeople canget to 18 cost of operation and make a comparison, and there 19 should be, and there is, work going on that when the 20 time comes DOE will have a test procedure you can 21 probably adopt. And I think we all ought be looking 22 in that direction. 23 Any other comments on that thought 24 process? 25 It would seem to me, and I'm looking for

(202)234-4433 

### NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-4433140 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 heating and cooling equipment that could perform the same 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 this kind of a product into the marketplace provided people can get over the first cost and maintenance cost and insulation cost issues.

Is that generally agreed-? The next issue was use of separate descriptors for each energy source used with the appliance. The work has been going on between ASHRAE and the ANSI committee has come back to, not descriptors, but to cost of operation.

Is that in the correct direction with everybody? I hear no objection.

The next question down there is, would consumers have adequate means to calculate annual 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) 234-4433 

### 140 1 input from otherpeople, thatthere arenomarketplace 2 limi

### tations to theuse of thedraftANSI standardthat 3 will go out for review, and certainly anything like 4 that would want to be changed as it becomes a jOint 5 

### ANSI/ASHRAE standard. So there will be means to 6 compare the operating costs to other costs of heating 7 and cooling equipment that could perform the same 8 subject, perform the same job in a given size. 9 And with that there in place, I wouldn't 10 think there would be any hold up to the entry of this 11 kindof a product intothemarketplaceprovidedpeople 12 can get over the first cost and maintenance cost and 13 insulation cost issues. 14 Is that generally agreed? 15 The next issue was use of separate 16 descriptors for each energy source used with the 17 appliance. The work has been going on between ASHRAE 18 and the ANSI committee has come back to, not 19 descriptors, but to cost of operation. 20 Is that in the correct direction with 21 everybody? 22 I hear no objection. 23 The next question down there is, 

### would 24 consumers have adequate means to calculate annual 25 operating cost of these appliances? And we get into,

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44332 3 4 5

7 8 9 10 11 12 13 -14 15 16 17 18 19 20 21 22 23 24 25 141

would consumers, I guess I want to add the other question, who is the typical consumer of this type of equipment, is it generally a household or is it generally a builder or is it generally going into a more large structures? I think we've got a different mix of consumers of this product than we do with, say residential size furnaces.

And if they would have means, if we've all said we've got standards and people can calculate the cost of operation, it would seem to me that there are plenty of means there for the manufacturer and energy suppliers to make the cost of operation known on a reasonable basis that could be compared to other heating, air conditioning and water heating equipment that would be doing that same function.

Am I making a fair summary of that again? We're going awful fast today, and I want to leave it open for anybody else to say anything. And we've got an issue that we've got -- we've moved ahead and we seem to have everything in place to allow the -product in the market and everybody is in agreement that about the best way to correlate it with other products is through the use of responsibly 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) 2344433 

### 141 1 would consumers, I guess I want to add the other 2 question, who is thatypical consumer of this type of 3 equipment, is it generally a household or is it 4 generally a builder or is it generally going into a 5 more large structures? I think we've got a different 6 mix of consumers of this product than we do with, say 7 residential size furnaces. 8 And iftheywouldhavemeans, ifwe've all 9 said we've got standards and people can calculate the 10 cost of operation, it would seem to me that there are 11 plenty ofmeans there for the manufacturer and energy 12 suppliers to make the cost of operation known on a 13 reasonable basis that could be compared to other -14 heating, air conditioning and waterheating equipment

15 that would be doing that same function. 16 Am 

### I making a fair summaryofthatagain? 17 We're going awful fast today, and I want 18 to leave it open for anybody else to say anything. 19 And we've got an issue that we've got

-- we've moved 20 ahead andwe seemtohaveeverything inplaceto allow 21 the product in the market and everybody is in 22 agreementthat about thebestway tocorrelateitwith 23 other products is through the use of responsibly 24 produced cost of operationnumbers on the samebasis. 25 Yes? NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44331 2 3

5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 142 MR. ADAMS: Carl Adams, DOE. Just to sort of relate this product back to some of the earlier discussions that we were having this morning, going back to Frank's I guess it was his first viewgraph of this afternoon, showing where the gas fired heat pump fell in the gas and electrical energy consumption. It's sort of following on a trend, I suppose, that earlier today we were talking about gas furnaces before induced draft furnaces, yes they used some electricity, then along came induced draft furnaces and you had furnaces that began to use more electricity, and it became a more significant item.

And I guess it was at that point that in the efficiency standards process that DOE began looking at the energy descriptor as a way , to capture this electrical consumption and to possibly include it in the efficiency standards to perhaps gain some efficiency improvements, if there were cost effective ones to be made there. Which is sort of where this process started and it's certainly grown well beyond that. And I guess to respond to a comment that Larry Wethje made earlier, DOE's intent in doing this was to come up with a descriptor for furnaces and boilers for whatever reasons that we seemed to have

(202) 234.4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 

### 142 1 

### MR. ADAMS: CarlAdams, DOE. Just to sort 2 of relate this product back to some of the earlier 3 discussions that we were having this morning, going 4 back to Frank's I guess itwas his first viewgraph of 5 this afternoon, showing where the gas fired heat pump 6 fell in the gas and electrical energy consumption. 7 It's sort of following on a trend, I suppose, that 8 earlier today we were talking about gas furnaces 9 before induced draft furnaces, yes they used some 10 electricity, then along came induced draft furnaces 11 and you had furnaces that began to use more 12 electricity, and it became a more significant item. 13 And I guess it was at that point that in the 14 efficiencystandardsprocessthatDOE beganlookingat 15 the energy descriptor as a way to capture this 16 electrical consumption and to possibly include it in 17 the efficiency standards to perhaps gain some 18 efficiency improvements, if therewere cost effective 19 ones to be made there. Which is sort of where this 20 process started and it's certainly grown well beyond 21 that. 22 And I guess to respond to a comment that 23 LarryWethjemade earlier, DOE's intent in doing this 24 was to come up with a descriptor for furnaces and 25 boilers for whatever reasons that we seemed to have

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331

3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 143

balled up our words in the reopening notice that perhaps implied that we were considering it for all products. We were not. It was tied to furnaces and boilers. But we're seeing this trend towards now possibly the gas fired heat pump which will use proportionately even more electricity getting really 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 this gas fired heat pump you would have to have a furnace with an AFUE of (x) in order to be comparable, is that taking into account the electrical consumption since the AFUE of the furnace does not, is this really a comparison, a fair comparison if the gas fired heat pump is proportionately using more electricity and neither of them is taking into account the electrical consumption. Are we providing apples to apples comparison if we were to adopt that.

And I think trying to put things on the same basis I'm hearing is good, then we don't want to get separate for each little family of products, a different descriptor so that people cannot compare gas furnaces to electric heat pumps to gas fired heat

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 143 1 balled up our words in the reopening notice that 2 perhaps implied that we were considering it for all 3 products. We were not. It was tied to furnaces and 4 boilers. 5 But we're seeing this trend towards now 6 possibly the gas fired heat pump which will use 7 proportionately even more electricity getting really 8 to a mix of electricity and with gas. 9 And I guess I haven't followed the ANSI 10 test procedure quite detailed enough to know, but if 11 there was a comparison made to an AFUE that this 12 gas fired heat pump you would have to have a furnace 13 with anAFUE of (x) inordertobecomparable, is that 14 taking into account the electrica'l consumption since 15 the AFUE of the furnace does not, is this really a 16 comparison, a fair comparison if the gas fired heat 17 pump is proportionately using more electricity and 18 neither of them is taking into account the electrical 19 

### consumption. Are we providing apples to apples 20 comparison if we were to adopt that. 21 And I think trying to put things on the 22 same basis I'm hearing is good, then we don't want to 23 get separate for each little family of products, a 24 differentdescriptorsothatpeoplecannotcomparegas 25 furnaces to electric heat pumps to gas fired heat

(202)234-4433 ,NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C. 20005 (202)234-44331

3 4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 144

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 out earlier, there' s concern that there's all these different types of descriptors, how do they relate, should they relate. But once again the underlying 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 or whether it's electric. I think dollars is really what the focus should be.

MODERATOR LANGMEAD: Frank, do you want to go over your one little slide at the beginning again to say where that comparison came from and what you did compare? I think it covered part of your question and it ties in with the comment you just made.

MR. JAKOB: Is that the part that -- MODERATOR LANGMEAD: That wasn't the one I had in mind, but that's all right. It's the comparison where you said I can go back and pick out NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON, D.C. 20005 (202) 234-4433 

### 144 1 pumps to type one or type two heating appliances. 2 There's getting to be all these different family of 3 appliances andhow do we compareoneto the other, how 4 do we provide the consumer with that information. 5 

### MR. KALISCH: Rick Kalisch from AGA. I 

### 6 thinkthatyou'redancingaroundtheactualdeficiency 7 in the whole system. And that is,-as was pOinted out 8 earlier, there's concern that there's all these 9 different types of descriptors, how do they relate, 10 

### should they relate. But once again the underlying 11 common denominator for all of thesewould be dollars, 12 and it's the operating cost of the system, whether. 13 it's part electric and part gas, whether it's gas or 14 whether it's.electric. I thinkdollars isreallywhat 15 the focus should be. 16 MODERATOR LANGMEAD: Frank, doyouwantto 17 go over your one little slide at the beginning again 18 to say where that comparison came from and what you 19 did compare? 20 I think it covered part of your question 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 one 24 

### I had in mind, but that's all right. It's the 25 comparison where you said I can go back and pick out

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N,W. WASHINGTON, D.C. 20005 (202)234-44331

5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 145

an AFUE of the heating side and.to get a comparable AFUE it would have to be about 125 percent. And Cyrus asked you the question about is that a linear equation, and you said no. That one. Well, that one and the next one.

MR. JAKOB: The premise being here that, as Carl pointed out, I did simply these equations for the purpose of the presentation. Actually with an electric heat pump it's far easier since they're a single energy source. But operating cost is a very simple algebraic function of SEER design heating load and energy costs.

With a gas furnace there's actually an extra parameter you need in here. AFUE electrical consumption load and energy costs in order to fully flesh out that equation. How does that get to the point of -- MODERATOR LANGMEAD: Well, where it gets to is you go back and make your comparison. The comparisons that have been made, and that Frank was looking at, are made on the basis of cost, not the descriptors. And so the cost will take into account the cost of electrical consumption. It doesn't give you a descriptor to work with to build a minimum 2511 efficiency, but it gives the consumer and the buyer

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 145 1 an AFUE of the heating side and to get a comparable 2 AFUE itwould have tobe about 125 percent. And Cyrus 3 asked you the question about is that a linear 4 equation, and you said no. That one. Well, that one 5 and the next one. 6 

### MR. JAKOB: The premise being here that, 7 as Carl pOinted out, I did simply these equations for 8 

### the purpose of the presentation. Actually with an

I 

### 9 electric heat pump it's far easier since they're a 10 single energy source. But operating cost is a very 11 simple algebraic function of SEER designheating load 12 and energy costs. 13 With a gas furnace there's actually an 14 extra parameter you need in here. AFUE electrical 15 consumption load and energy costs in order to fully 16 flesh out that equation. How does that get to the 17 point of

-- 18 

### MODERATOR LANGMEAD: Well, where it gets 19 

### to is you go back and make your comparison. The 20 comparisons that have been made, and that Frank was 21 looking at, are made on the basis of cost, not the 22 descriptors. And so the cost will take into account 23 the cost of electrical consumption. It doesn't give 24 you a descriptor to work with to build a minimum 25 efficiency, but it gives the consumer and the buyer

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C.20005 (202)234-4433146 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 deliver 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're

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 

### 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 separateefficiencies. And for instancethatcouldbe 7 done. Agas heat pump can deliver about 125,000 BTUs 8 of heat for every therm of gas that it consumes. So 9 there is a measure of efficiency 125,000 BTUs per 10 thermo 11 On the electric side it's able todeliver 12 60 BTUs for about everyone hour of electricity that 13 it consumes. And so there is a pair.of numbers based 14 onthe separateenergyconsumptions thatcouldbeused 15 with BTUs per hour, 16 BTUS per one hour, and 125,000 ·16 per thermo But probably just confused a number of

17 people here and, if we're confused, the American 18 people are confused. 19 MODERATORLANGMEAD: Rightoverhere, yes. 20 Introduce yourself please? 21 MR. RIVEST: Does thatmeanthatyourSEER 22 output rating

-- 

### 23 24 yourself? 25

(202)234-4433 

### MODERATOR LANGMEAD: Would you introduce

MR. RIVEST: Michael Rivest

-- if you're 

### NEALA. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON. D.C. 20005 (202)234-44331 2 3 4

7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 147

starting to do a cost, if you're going from SEER to low cost and low cost to SEER, costs change with the SEER rating of your gas --

MODERATOR LANGMEAD: The reporter need to 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 to SEER, for the gas heat pumps, is that correct?

MR. JAKOB: The main profit goes for energy cost to SEER. And you're right, cost is in there in the middle and that would be a number that just like--is based on national averages some sort of technique in order to handle the time variant --

MR. RIVEST: But the SEER rating that comes out at the end for the heat pump, so'does that mean it's relative to cost, if cost changes, does the SEER rating change? I guess that's what,I mean.

MR. JAKOB: If the cost changes, the cost of the gas heat pump changes, the cost of operation changes, then the associated rating of another ,appliance that has the same operating cost will change. The answer is yes.

MODERATOR LANGMEAD: I had another question over here? Yes? Please introduce yourself.

(202) 234-4433 MR. YOUNG: It's Dave Young from Ontario 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 147 1 starting to do a cost, if you're going from SEER to 2 low cost and low cost to SEER, costs change with the 3 SEER rating of your gas -- • 4 MODERATOR LANGMEAD: The reporterneed to 5 hear you better

..He's recording your voice. 6 

### MR. RIVEST: On that, to go from cost, 7 you're going from SEER to the cost, and back, cost to 8 SEER, for the gas heat pumps, is that correct? 9 

### MR. JAKOB: The main profit goes for 10 

### energy cost to SEER. And you're right, cost is in 11 there in the middle and that would be a number that 12 just like--is based on national averages some sort of 13 technique in order to handle the time variant

-- 14 MR. RIVEST: But the SEER rating that 15 comes out at the end for the heat pump, so does that 16 mean it's relative to cost, if cost changes, does the 17 SEER rating change? I guess that's what ,I mean. 18 MR. JAKOB: If the cost changes, the cost 19 of the gas heat pump changes, the cost of operation 20 changes, then the associated rating of another 21 appliance that has the same operating cost will 22 change. The answer is yes. 23 MODERATOR LANGMEAD: I had another 24 question overhere? Yes? Please introduce yourself. 25

(202)234-4433 

### MR. YOUNG: It's Dave Young from Ontario NEALR. GROSS COURTREPORTERSAND TRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202)234-4433148 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 your

presentation that I'm a little bit confused on. I guess you touched on one of them a bit earlier when you drew the analogy between the function that would give you the equivalent AFUE or a gas heat pump, and you used, as an example, 125.

In the case of heat pump function relating to AFUE, that must be a strongly dependent upon the

zone that it's done in. And that 125 might be true for one geographical -location, but it certainly be equal to 125 someplace else in the country. And does that not lead to a rather difficult to label equivalency in terms of AFUE when gas furnace AFUEs are relatively variant with location by geography. But gas heat pump AFUEs are going to vary by say 50 percent. MR. JAKOB: Relative to gas furnaces, there will be that factor, but the fact that the bottom line efficiency of a heat pump varies with region is already comprehended by the test procedures and the fact that we have separate regions and separate bin hours set up for those different regions where things can then be alternatively calculated.

MR. YOUNG: But AFUE is not a number that varies by region. I mean people aren't used seeing a

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 148 1 

### Hydro. There was a couple of things in your 2 presentation that I'm a little bit confused on. I 

### 3 guess you touched on one of them a bit earlier when 4 you drew the analogy between the function that would 5 

### give you the equivalent AFUE or a gas heat pump, and 6 

### you used, as an example, 125. 7 

### Inthecaseofheatpump function relating 8 

### to AFUE, that must be a strongly dependent upon the 9 

### zone that it's done in. And that 125 might be true 10 for one geographical location, but it certainly be 11 equal to 125 someplace else in the country. And does 12 that not lead to a rather difficult to label 13 equivalency in terms of AFUE when gas furnace AFUEs 14 are relatively variant with location by geography. 15 But gas heat pump AFUEs are going to vary by say 50 16 percent. 17 

### MR. JAKOB: Relative to gas furnaces, 18 there will be that factor, but the fact that the 19 bottom line efficiency of a heat pump varies with 20 region is alreadycomprehended by the test procedures 21 and the fact that we have separate regions and 22 separatebinhours set up for those different regions 23 where things can then be alternatively calculated. 24 

### MR. YOUNG: But AFUE is not a number that 25 varies by region. I mean people aren't used seeing a

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202)234-4433149 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' s based on a 42 degree outdoor temperature and various implications.

MR. KELLY: We looked at different regions of the country. It's fairly insensitive to the regions. MR. JAKOB: It's fairly insensitive, but there is some functionality I presume.

MR. KELLY: Right, right. MR. YOUNG: Well, you're dealing with something on the one hand that's fairly insensitive in the case of the gas furnace product versus the heat pump product that it's directly sensitive to. I mean there is a big .difference between those two dimensions. MR. JAKOB: So a sensitivity analysis that would portray the variability with regions would be of value? MR. YOUNG: Well, no. In the consumer's mind the number AFUE bears, is meaningful with respect to this product in which the number does not change with the geographic location. And now you're applying it to a product where the number does change with

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 149 1 AFUE that would vary by region. 2 MR. JAKOB: It's not assessed. The AFUE, 3 and I don't know ifGeorge would ever let us, but it's 4 based on a 42 degree outdoor temperature and various 5 implications. 6 MR. KELLY: We lookedatdifferentregions 7 of the country. It's fairly insensitive to the 8 regions. 9 MR. JAKOB: It's fairly insensitive, but 10 there is some functionality I presume. 11

. MR. KELLY: Right, right. 12 MR. YOUNG: Well, you're dealing with 13 somethingontheonehand that's fairly insensitive in 14 the case of the gas furnace product versus the heat 15 pump product that it's directly sensitive to. I mean 16 there is a big difference between those two 17 dimensions. 18 MR. JAKOB: Soa sensitivityanalysis that 19 wouldportray thevariabilitywithregions wouldbeof 20 value? 21 MR. YOUNG: Well, no. In the consumer's 22 mind thenumberAFUE bears, ismeaningful withrespect 23 to this product in which the number does not change 24 withthegeographiclocation. Andnowyou're applying 25 it to a product where the number does change with

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-4433150 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 a comment on that?

MR. PIETSCH: I have a comment. The Z21.40 standard has provisions that are calculated -- equivalent for all regions of the country, just like the electric heat pump does. So it provides a procedure for developing the heat pump performance in all climates. Now, if somebody wants to go and set a standard rating for labeling or something like that, they could select one, and just like the electric heat pump as selected in region 4. But it does have provisions in that standard for all climates to calculate it by the bin calculation.

MR. JAKOB: The calculation techniques are there to allow you to go to any region and use the local bin to calculate what that AFUE of the other appliance has to be.

MODERATOR LANGMEAD: I saw another question over here somewhere. Okay.

Anybody else want to add anything to the multi-fuel heat pump subject, from DOE, from any place else?

(202) 234-4433 Yes? MR. DOUGHERTY: Brian Dougherty, NIST. I



### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 150 1 geographic location. 2 MR. JAKOB: Joe Pietsch,.do you have a 3 comment on that? 4 

### MR. PIETSCH: I have a comment. The 5 Z21.40 standard has provisions that are calculated

-- 6 equivalent for all regions of the country, just like 7 

### the electric heat pump does. So it provides a 8 procedure for developing theheat pump performance in 9 all climates. Now, if somebodywants to go and set a 10 standard rating for labeling or something like that, 11 theycould selectone, andjustliketheelectricheat 12 pump .as selected in region 4. But it does have 13 provisions in that standard for all climates to 14 calculate it by the bin calculation. 15 MR. JAKOB: Thecalculationtechniquesare 16 there to allow you to go to any region and use the 17 local bin to calculate what that AFUE of the other 18 appliance has to be. 19 

### MODERATOR LANGMEAD: I saw another 20 question over here somewhere. Okay. 21 Anybody else want to add anything to the 22 multi-fuelheatpump subject, fromDOE, from anyplace 23 else? 24 Yes? 25

(202)234-4433 

### MR. DOUGHERTY: BrianDougherty, NIST. I NEALR. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NoW. WASHINGTON, D.C. 20005 (202)234-4433151 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 of

conversion factors where you convert gas to electricity, and electricity to gas, is okay for this 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 an inconsistency of not combining them with furnaces and boilers, but of combing them on --

MR. WETHJE: Well, what's the manner -- Larry Wethje, GRI. What's the manner in which they're combined in the appendix.

Frank, I guess I would ask you that. Is that on a site or a strict conversion of 3.4.13 times ,the electrical or on a source basis?

MR. JAKOB:. As Joe pointed out it's not a standard in terms of a descriptive efficiency standard, it's a standard in terms of a method of test. And so the mathematical calculations are specified but you, the analyst, would have to determine what the cost is, be it the local cost, what the load is, what the size and criteria are. All those are open.

MR. DOUGHERTY: The descriptors used in the appendix that I have, there is one called source 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) 234-4433 

### 151 1 just want to understand that the application of 2 conversion factors where you convert gas to 3 electricity, and electricity to gas, is okay for this 4 appliance, and the arguments that were discussed this 5 morningwithregards to thefurnace applicationdonot 6 

### apply. It seems like there is a little bit of an 7 inconsistency of not combining themwith furnaces and 8 boilers, but of combing them on -- 9 

### MR. WETHJE: Well, what's the manner -- 10 LarryWethje, GRI. What's themanner inwhichthey're 11 combined in the appendix. 12 

### Frank, I guess I would ask you that. Is 13 that on a site or a strict conversion of 3.4.13 times 14 ,the electrical or on a source basis? 15 MR. JAKOB: As Joe pOinted ou·t it's not a 16 standard in terms of a descriptive efficiency 17 standard, it's a standard in terms of a method of 18 test. And so the mathematical calculations are 19 specified but you, the analyst, would have to 20 determinewhat thecost is, be itthe local cost, what 21 

### the load is, what the size and criteria are. All 22 those are open. 23 MR. DOUGHERTY: The descriptors used in 24 the appendix that I have, there is one called source 25 fuel leERorHSPF, and theotherones arecalledcost,

(202)234-4433 

### NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW, WASHINGTON.,D.C,20005 (202)234-44332 3 4 5

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 152

SEER, and HSPF, so you use a cost ratio of fuels or this source fuel ratio to get these equivalent values?

MR. WETHJE: Either way. There is some kind of a "F factor" involved in the conversion of electric to gas.

MR. DOUGHERTY: Right, right. MR. JAKOB: It seems-like we're back at the same place where we were this morning.

MR. WETHJE: Well, hopefully there's some consistency on all appliances. But maybe there's reasons why there shouldn't be and that's what I was trying to ask.

MODERATOR LANGMEAD: I might suggest that that becomes an issue, it seems to me, only if you're going to set a minimum standard, and if the comparison was made by the consumer on a cost at that site, then that issue kind of goes away. And if you're talking about a gas fired heat pump, I guess one of the broader questions is, would there be a need to gave a minimum efficiency set on a product that the least efficient one is going to be more efficient than anything that's on the market at this point in time until you get some additional volume.

And the tools to do what you want to do 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) 2344433 

### 152 1 SEER, and HSPF, so you use a cost ratio of fuels or 2 this sourcefuel ratio toget theseequivalentvalues? 3 

### MR. WETHJE: Either way. There is some 4 kind of a ifF factor" involved in the conversion of 5 electric to gas. 6 

### MR. DOUGHERTY: Right, right. 7 

### MR. JAKOB: It seems- like we're back at 8 the same place where we**werethi~** 

### morning. 9 

### MR. WETHJE: Well, hopefullythere's some 10 

### consistency on all appliances. But maybe there's 11 reasons why there shouldn't be and that's what I was 12 trying to ask. 13 MODERATOR LANGMEAD: I might suggest that 14 that becomes an issue, it seems to me, only if you're 15 going to set a minimum standard, and ifthecomparison 16 was made by the consumer on a cost at that site, then 17 that issue kind of goes away. And if you're talking 18 about a gas fired heat pump, I guess one of the 19 broader questions is, would there be a need to gave a 20 minimum efficiency set on a product that the least 21 efficient one is going to be more efficient than 22 anything that's on the market at this point in time 23 until you get some additional volume. 24 And the tools to do what you want to do 25 are sitting here, it's how you're going to use them.

(202)234-4433 NEAL

### A. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44333 4 5

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 153

And so nobody has been saying, I think the F factor issue doesn 't come up if you compare it on a cost basis. MR. WETHJE: No, but what I just said was the method of comparing it on a cost basis was to use an F factor multiplier in the process. It's the only way to get a cost factor --

MODERATOR LANGMEAD: Let's -- MR. WETHJE: -- that's what's in the appendix, Frank.

MR. KALISCH: Bert Kalisch from AGA. One of the objections that we have to the furnace rule that was commented on this past March was the electrical consumption of a fossil fuel fired furnace was treated differently than the electrical consumption of an electric furnace. So we. didn't object to the F factor but in the application of the F factor. MODERATOR LANGMEAD: Yes?

MR. DOUGHERTY: I wanted to ask too, Brian Dougherty, NIST, whether or not there is because the test procedure itself is structured like the test procedures -- heat pump, whether or not the descriptor of comparison in going after an equivalent descriptor 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) 2344433 153 1 And so nobody has been saying, I think the F factor 2 issue doesn't come up if you compare it on a cost 3 basis. 4 MR. WETHJE: No, but what I just saidwas 5**~he** method of comparing it on a cost basis was to use 6 an F factor multiplier in the process. It's the only 7 way to get a cost factor

-- 8 MODERATOR LANGMEAD: Let's-- 9 MR. WETHJE: that's what's in the 10 appendix, Frank. 11 MR. KALISCH: Bert Kalisch from AGA. One 12 of the objections that we have to the furnace rule 13 that was commented on this past March was the 14 electrical consumptionof a fossil fuel fired furnace 15 was treated differently than the electrical 16 consumption of an electric furnace. So we, didn't 17 object to the**~** factor but in the application of the 18 F factor. 19 MODERATOR LANGMEAD: Yes? 20 MR. DOUGHERTY: I wantedto asktoo, Brian 21 Dougherty, NIST, whether or not there is because the 22 test procedure itself is structured like the test 23 procedures

- - heatpump, whetherornotthedescriptor 24 of comparison in going after an equivalent descriptor 25 should be more HSPF than AFUE.

(202)234-4433 NEALA. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW, WASHINGTON, D.C.20005 (202)234-44331 2 3 4 5 6 7 8 9 10 11 12 13 -14 15 16 17 18 19 20 21 22 23 24 25 154 I understand obviously if you use gas it would be best to probably go after AFUE, but the rest procedure is structured to the all electric equipment, so the question is, if you*do that, why don't you have for heat pumps use AFUE as --was a reason why they did the HSPF for heat pumps and AFUE for boilers and furnaces, and I assume that was driven by trying to make a comparison to most like appliances.

And if we change the test procedure, you don't know what effects you have as far as the relative ranking. Now, that you've put them out in the field, do you know what an HSPF, if you divide it by 3.413 to get the dimensionless quantities, would the difference between the AFUE method, test method, and the heat pump test method then correlate to what is actually seen in the field. I don't know that anyone has ever looked at that to my knowledge.

So I question whether or not the comparison should be made , if made at all, to HSPF on the heating side as opposed to AFUE?

MODERATOR LANGMEAD: Anybody else want to comment on this issue at this time?

Yes. MR. SWEETSER : Rich Sweetser, American Gas Cooling Center. The ANSI Z21.40 standard allows for

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 154 1 I understand obviously if you use gas it 2 would be best to probably go after AFUE, but the rest 3 procedureis structuredtotheall electricequipment, 4 so the question is, ifyou'do that, why don'tyou have 5 for heat pumps use AFUE as --was a reasonwhy theydid 6 the HSPF for heat'pumps and AFUE for boilers and 7 furnaces, and I assume that was driven by trying to 8 make a comparison to most like appliances. 9 And if we change the test procedure, you 10 don't know what effects you have as far as the 11 relative ranking. Now, that you've put them out in 12 the field, do you know what an HSPF, if you divide it 13 by 3.413 to get the dimensionless quantities, would ·14 the difference between the AFUE method, test method, 15 and the heat pump test method then correlate to what 16 is actually seen in the field. I don't know that 17 anyone has ever looked at that to my knowledge. 18 So I question whether or not· the 19 comparison should be made, if made at all, to HSPF on 20 the heating side as opposed to AFUE? 21 MODERATOR LANGMEAD: Anybody elsewant to 22 comment on this issue at this time? 23 Yes. 24 MR. SWEETSER: RichSweetser, AmericanGas 25 Cooling Center. The ANSI Z21.40 standard allows for

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NoW. WASHINGTON, D.C. 20005 (202)234-44331 2 3

5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 155

both comparisons. And, you know, in part, we do have to go back to again our customer we're trying to provide information to and that customer I would think we would want to be able to make comparisons from a gas heat pump, electric pump to electric furnace or a gas furnace in some way, shape or form. So that really ought to be our guide. Maybe we've put a little bit too much information because of the weather sensitivity. Hopefully the standard allows for enough in the appendix, enough input to get it right.

MODERATOR LANGMEAD: George? MR. KELLY: I believe Brian's point is the test procedures are slightly different for furnaces --

MODERATOR LANGMEAD: A little louder, George. MR. KELLY: -- for furnaces if you're outdoor or isolating combustion, we have jacket losses. And if you're indoor you have infiltration losses that are imposed upon the house. You don't have that in the heat pump area.

MR. THRASHER : That's true. MODERATOR LANGMEAD: Yes? MR. RYAN : Bill Ryan, GRI. There are some simplifications here in that we have -- I believe uniformity --

(202) 234.4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 155 1 both comparisons. And, you know, in part, we do have 2 to go back to again our customer we're trying to 3 provideinformation to and thatcustomer I would think 4 we would want to be able to make comparisons from a 5 gas heat pump, electric pump to electric furnace or a 6 gas furnace in some way, shape or form. So that 7 really ought to be our guide. Maybe we've put a 8 Iittlebit toomuch informationbecauseoftheweather 9 sensitivity. Hopefully the standard allows for enough 10 in the appendix, enough input to get it right. 11 MODERATOR LANGMEAD: George? 

### 12 MR. KELLY: I believeBrian'spointis the 13 testprocedures are slightlydifferent for furnaces --' 14 MODERATOR LANGMEAD: A little louder, 15 George. 

### 16 MR. KELLY:

-- for furnaces if you're 17 outdoor or isolating combustion, we have jacket 18 losses. And if you're indoor you have infiltration 

### 19 losses that are imposed upon the house. You don't 20 have that in the heat pump area. 

### 21 MR. THRASHER: That's true. 22 MODERATOR LANGMEAD: Yes? 

### 23 MR. RYAN: BillRyan, GRI. There are some 24 simplifications here in that we have

-- I believe 25 uniformity

--

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-4433156 MODERATOR LANGMEAD: Bill, a little louder

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 heat

pump is located outdoors and that does simplify any concerns about jacket losses and ICS.

Other than that, one of the chief interests in using equivalency or equivalent HSPF is that you introduce the energy costs into the calculation to come up with operating costs, but you don't end up with dollars per year in the end. You then back the same energy costs back out so that you

can come up with the equivalent numbers.

It makes it a bit more independent of operating cost, but there is obviously a ratio between fuel source prices that remains within the calculation, and that's right there in the arithmetic. But at least you do end up with a number that doesn't 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 it rolls off the assembly line. There is,-however, that one last ratio that remains within it that's basically 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) 234-4433 156 1 MODERATOR LANGMEAD: Bill, a littlelouder 2 please. 3 MR. RYAN:

-- assume that the gas heat 4 pump is located outdoors and that does simplify any 5 concerns about jacket losses and IeS. 6 Other than that, one of the chief 7 interests in using equivalency orequivalent HSPF is 8 that you introduce the energy costs into the 9 calculation to corne up with operating costs, but you 10 don't end up with dollars per year in the end. You 11 then back the same energy costs back out so that you 12 can corne up with the equivalent numbers. 13 It makes ita bit more independent of 14 operatingcost, buttheJ;e isobviouslya ratiobetween 15 fuel source prices that remains within the 16 calculation, andthat'srightthereinthearithmetic. 17 But at least you do end up with a number that doesn't 18 have to corne down to dollars per year for Wichita, 19 Kansas. It's something a little more general and a 20 little more specific than a piece of equipment as it 21 rolls off the assembly line. There is, ·however, that 22 one lastratiothat remainswithin itthat'sbasically 23 impossible to eliminate. 24 25

(202)234-4433 MODERATOR LANGMEAD: Frank? MR. STANONIK: Just a different question, NEAL

### R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323RHODE fSLANDAVENUE, NW. WASHINGTON, D.C.20005 (202)234-44331 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 157

and I apologize if it throws things off here, but in the A40 standard, I mean we had this discussion this morning where you have the standard gas furnace where your primary fuel is gas and then you have what I'm going to call auxiliary electrical consumption, mainly your blower motor, okay. Now, on a gas fired heat pump the unit itself still has primarily gas consumption and has some associated electric consumption, you still have the auxiliary electrical consumption of what is now an air handling unit, okay. Where does that get entered into the equation, if, you will, in the A40 standard, the electrical consumption that occurs from your motor to turn the blower to move the air through the house?

MR. JAKOB: It's set up to test as a split system or as just a condenser only with some assumptions. But it's a split system and it consists of an indoor and an outdoor unit. The outdoor unit has fans and pumps associated with it. The indoor unit has a blower associated with it. And the standard specifies that you make a total electrical input to that entire system. And so the total electrical energy is comprehended out of it.

MR. STANONIK: I asked my question poorly I guess. Under the current procedures for AFUE that

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON. D.C. 20005 (202) 234-4433 

### 157 1 and I apologize if it throws things off here, but in 2 the A40 standard, I mean we had this discussion this 3 morning where you have the standard gas furnace where 4 your primary fuel is gas and then you have what I'm 5 goingtocallauxiliaryelectricalconsumption, mainly 6 

### your blower motor, okay. Now, on a gas fired heat 7 pump the unit itself still has primarily gas 8 

### consumption and has some associated electric 9 

### consumption, you still have the auxiliary electrical 10 consumptionofwhat isnow an airhandlingunit, okay. 11 Where does that get entered into the equation, if you 12 will, in the A40 standard, the electrical consumption 13 that occurs fromyourmotor to turn theblowertomove 14 the air through the house? 15 MR. 

### JAKOB: It's setup to test as a split 16 system or as just a condenser only with some 17 assumptions. But it's a split system and it consists 18 of an indoor and an outdoor unit. The outdoor unit 19 has fans and pumps associated with it. The indoor' 20 unit has a blower associated with it. And the 21 standard specifies that you make a total electrical 22 input to that entire system. And so the total 23 electrical energy is comprehended out of it. 24 MR. 

### STANONIK: I asked my questionpoorly 25 I guess. Under the current procedures for AFUE that

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW, WASHINGTON. D,C,20005 (202)234-44331 2

4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 158

electrical assumption that occurs at your blower is in fact -- at for AFUE. You were in the course of your discussion saying well, you could work backwards and say that with my gas fired heat pump, if I had a furnace it would have to have an AFUE of 125 or something, okay. In that process does A40 -- does the Z21.40 standard also discount , the electrical consumption that occurred at the blower or is it now all rolled in. And I don't know because I'm not that familiar with the standard.

MR. DOUGHERTY: The question is does the equivalent AFUE reflect the --

MR. STANONIK: I guess that would be it, yes. MR. JAKOB: As currently configured, I believe it does.

MR. DOUGHERTY: So it's different from the regular AFUE we currently have?

MR. JAKOB: If you consider gas only, then the AFUE would be much higher.

MODERATOR LANGMEAD: I would think that needs to be looked at.

Larry? MR. WETHJE: Larry Wethje, ARI. I ,guess I am unclear as to why -- approved Z21.40.4 standard

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 158 1 electricalassumptionthatoccurs·atyourbloweris in 2 fact

-- at for AFUE. You were in the course of your 3 discussion saying well, you could work backwards and 4 say that with my gas fired heat pump, if I had a 5 furnace it would have to have an AFUE of 125 or 6 something, okay. Inthatprocess does A40

-- does the 7 

### Z21.40 standard also discount the electrical 8 consumption that occurred at the blower or is it now 9 

### all rolled in. And I don't know because I'm not that 10 familiar with the standard. 11 MR. DOUGHERTY: The question is does the 12 equivalent AFUE reflect the 13 MR. STANONIK: I guess that would be it, 14 yes. 15 MR. JAKOB: As currently configured, I 16 believe it does. 

### 17 MR. DOUGHERTY: Soit'sdifferent fromthe 18 regular AFUE we currently have? 19 MR. 

### JAKOa: Ifyouconsidergasonly, then 20 the AFUE would be mUch higher. 21 MODERATOR LANGMEAD: I 

### would think that 22 needs to be looked at. 23 Larry? 24 MR. WETHJE: Larry Wethje, ARl. 19uess 25 I am unclear as to why

-- approved Z21.40.4 standard

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44331 2 3 4 5

7

9 10 11 12 13 .14 15 16 17 18 19 20 21 22 23 24 25 159

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 times your local utility rates separately to get your annual operating cost of the gas and your annual operating 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 AE factor. MR. JAKOB: Comparing operating cost is one of the chapters in the appendix that allows you to do that. MR. WETHJE : Using a F factor multiplier?

MR. JAKOB: No, using the individual operating costs.

MODERATOR LANGMEAD: And that's what I thought I was saying earlier, Larry. I guess it

(202) 2344433 

### NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 159 1 allowsyou todetermine a seasonableefficiencyonthe 2 gas usage and a seasonable efficiency on the 3 electrical usage, correct? 4 MR. JAKOB: Not efficiency. Seasonal 5 total in terms of BTUs and kilowatt hours. 6 MR. WETHJE: Okay. So why can't you then 7 just simplytakethose numbers andmultiplythem times 8 your local utilityrates separatelyto getyour annual 9 operating cost of the gas and your annual operating 10 cost of the electric and get a total annual operating 11 cost of the appliance and compare that to the annual 12 operating cost of a furnace from the GAMA director or 13 an electric heat pump from the ARI directory? It 14 seems to me that's the most straight forward and 15 simplest way to compare the products. 16 MR. KELLY: Well, you're picking an AE 17 factor. 18 MR. JAKOB: Comparing operating cost is 19 one of the chapters in the appendix that allows you to 20 do that. 21 MR. WETHJE: Using a F factor multiplier? 22 MR. JAKOB: No, using the individual 23 operating costs. 24 25 MODERATOR LANGMEAD: And that's what I thought I was saying earlier, Larry.

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C.20005 I guess it

(202)234-4433160 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 point though I think is that in a procedure you can compare to a specific model that's listed in a director, but you couldn't compare it to a hypothetical 90 AFUE furnace because not all 90 AFUE furnaces have the same electrical consumption.

MODERATOR LANGMEAD : And so you have to go 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'm hearing that people see the equivalent HSPF being a more direct and understandable way of doing it, comparing heat pump and heating to a heat pump --

MODERATOR LANGMEAD: I don't think you were hearing that.

MR. RYAN: Okay. MODERATOR LANGMEAD: But there were some questions. MR. RYAN: My concern was there seemed to be a comparison to a furnace, not what you do with the electricity. Well, if I go back to an equivalent HSPF, then I'm going back to an equivalent device that

(202) 234+1433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 160 1 didn't come out that way. 2 Dan's got a pOint? 3 MR. DEMPSEY: DanDempsey. TheonlypOint 4 though I think is that in a procedure you can compare 5 to a**~pecific** model that's listed in a director, but 6 you couldn't compare it to a hypothetical 90 AFUE 7 furnace becausenot all 90AFUE furnaces have the same 8 electrical consumption. 9 MODERATOR LANGMEAD: And soyouhavetogo 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'm 14 hearing that people see the equivalent HSPF being a 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 you 18 were hearing that. 19 MR. RYAN: Okay. 20 MODERATOR LANGMEAD: But there were some 21 questions. 22 MR. RYAN: My concern was there seemed to 23 be a comparisonto a furnace, not what you dowiththe 24 electricity. Well, if I go back to an equivalent 25 HSPF, then I'mgoingback to anequivalentdevice that

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44331

3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 161

only uses one energy input and so it's fairly straight forward. MODERATOR LANGMEAD: Charlie Adams?

MR. ADAMS: Charlie Adams, Ducane. I think to address your problem, perceived problem -- to expand on what Dan was saying, aren't we really saying instead of taking an energy descriptor and calculating a cost and then back calculating some other energy descriptor out of that, what we're really saying is 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 and back figure an AFUE and pick up the GAMA directory and look down the columns until you see that number and say geez , I want that one. That's not really what we're saying. We're saying I want to compare this one to this one, and this one costs this much and this one costs that much, and that includes all the electrical consumptions from all of anything.

It has the multiplier factor in there because you're paying 3., whatever it is, times for the electrical energy that you're paying for the gas energy, and in my mind I'm still a site energy kind of a guy. When I plug it into the wall I'm paying for

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 161 1 onlyuses one energy input and so it's fairly straight 2 forward. 3 

### MODERATOR LANGMEAD: Charlie Adams? 4 

### MR. ADAMS: Charlie Adams, Ducane. I 

### 5 thinkto addressyourproblem, perceivedproblem

-- to 6 expand onwhatDanwas saying, aren'twe reallysaying 7 insteadoftakinganenergydescriptorandcalculating 8 a cost and then back calculating some other energy 9 descriptor out of that, what we" re really saying is 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-fuel, 13 the gas driven heat pump, gas engine heat pump and 14 back figure anAFUE andpickup theGAMA directory and 15 look down the columns until you see that number and 16 say geez, I want that one. That's not really what 17 we're saying. We're saying I want to compare this one 18 to this one, and this one costs this much and this one 19 costs that much, and that includes all the electrical 20 consumptions from all of anything. 21 It has the multiplier factor in there 22 because you're paying 3., whatever it is, times for 23 the electrical energy that you're paying for the gas 24 energy, and inmy mind I'm still a site energykind of 25 a guy. When I plug it into the wall I'm**payi~g** 

### for

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44331

3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 162

what comes out of the plug, whether it's gas or electric. And that's really what we're saying.

Frank, whatever you're comparing, go to a dollar number and that's what's going to make a difference to the --

MODERATOR LANGMEAD: And I think as you sell this thing, this product, if you're not trying to put a minimum standard on it or a number on the minimum standard, if you're trying to sell the product to people, you're going to have to give them some cost of operation comparisons about the gas engine driven heat pump as it would relate to the cost of operating

some other kind of systems to do that job..

And the dollar comes, and that comparison comes down in the cost of both the gas and the electricity to do the job-several different ways. I think that's the only real fair comparison you can make. Yes?

MR. YOUNG: Dave Young from Ontario Hydro. I just wonder if we went around this argument a few more times we might come to a point where we admit to ourselves that maybe the one thing we should label with all these different products might be dollars per 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) 234-4433 162 1 what comes out of the plug, whether it's gas or 2 electric. And that's really what we're saying. 3 Frank, whateveryou're comparing, go to a 4 dollar number and that's what's going to make a 5 difference to the

-- 6 MODERATOR LANGMEAD: And I think as you 7 sell this thing, thisproduct, ifyou're not trying to 8 put a minimum standard on it or a number on the 9 minimum standard, ifyou're tryingto sell the product 10 to people, you're going to have to give them some cost 11 of operation comparisons about the gas engine driven 12 heat pump as it would relate to the cost of operating 13 some other kind of systems to do that job. 14 And the dollar comes, and that comparison 15 comes down in the cost of both the gas and the 16 electricity to do the job,several different ways. I 17 think that's the only real fair comparison you can 18 make. 19 Yes? 20 MR. YOUNG: DaveYoung from OntarioHydro. 21 I just wonder if we went around this argument a few 22 more times we might come to a point where we admit to 23 ourselves that maybe the one thing we should label 24 withall these different productsmight bedollarsper 25 million BTUs delivered, like a normalized

(202)234-4433 NEALR. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44334

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 163 MODERATOR LANGMEAD: It gets a little 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 the intended use of the product.

MODERATOR LANGMEAD: -- well, it becomes hard to develope a minimum standard on that basis because now you're going to take it down to one point and make all these comparisons and it's going to be wrong somewhere.

Yes? MR. DOUGHERTY: Brian Dougherty, NIST. I believe if you want wanted to apply your local fuel cost to evaluate the fuel heat pump, you would have to also be in a position to provide either the annual operating cost or one of these descriptors from which you get operating costs. You'd also have to provide now a ratio of how much of the input was gas, how much it was electricity, otherwise you can't back it out again what their local cost. You have to get them more information than just a descriptor or annual operating cost, you have to give them also --

MODERATOR LANGMEAD: The GAMA director and the ARI directory already do that on conventional

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 163 1 

### MODERATOR LANGMEAD: It gets a little 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 the 6 intended use of the product. 7 

### MODERATOR LANGMEAD:

-- well, it becomes 8 hard to develope a minimum standard on that basis 9 because now you're going to take it down to one point 10 and make all these comparisons and it's going to be 11 wrong somewhere. 12 Yes? 13 MR. DOUGHERTY: BrianDougherty, NIST. I 14 believe if you want wanted to apply your local fuel 15 costtoevaluatethe fuel heatpump, you wouldhave to 16 also be 

### ip a position to provide either the annual 17 operating cost or one of these descriptors from which 18 you get operating costs. You'd also have to provide 19 now a ratio of how muchof the inputwas gas, how much 20 it was electricity, otherwise you can't back it out 21 again what their local cost. You have to get them 22 more information than just a descriptor or annual 23 operating cost, you have to give them also

-- 24 MODERATORLANGMEAD: TheGAMAdirectorand 25 the ARI directory already do that on conventional

(202)234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44332

4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 164

products. They give them the AFUE plus the electrical consumption . It's there today and has been for some time. MR. DOUGHERTY: Okay, so then what will be reported in the GAMA directory and the ARI director will be -- you can break it out by fuel --

MODERATOR LANGMEAD: You can break it out by fuels. You can get there, yes.

Yes? MR. JAKOB: Frank Jakob, Batelle. I misspoke earlier with regard to the AFUE. Only the gas consumption of the appliance is considered in calculating operating costs and then translating it to AFUE. And so when I was implying earlier that perhaps all energy is involved, that was incorrect and it came out in the discussion that it would be more apples to apples if we did it on a gas only basis. That is 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 a point where you have a unit maybe that's 51 percent gas and 49 percent electric, and they come out with an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON. D.C. 20005 (202) 234-4433 164 1 products. Theygivethem theAFUE plus the electrical 2 consumption. It's there today and has been for some 3 time. 4 MR. DOUGHERTY: Okay, sothenwhatwillbe 5 reported in the GAMA directory and the ARI director 6 will be

-- you can break it out by fuel 7 MODERATOR LANGMEAD: You canbreak it out 8 by fuels. You can get there, yes. 9 Yes? 10 MR. JAKOB: Frank Jakob, Batelle. I 11 misspoke earlier with regard to the AFUE. Only the 12 gas consumption of the appliance is considered in 13 calculatingoperatingcosts andthentranslatingitto 14 AFUE. And sowhen I was implying earlierthatperhaps 15 all energyis involved, thatwas incorrect and itcame 16 out in the discussion that it would be more apples to 17 apples if we did it on a gas only basis. That is 18 indeed how this clever committee wrote it. 19 MODERATOR LANGMEAD: I hope somebody 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 a 24 point where you have a unit maybe that's 51 percent 25 gas and 49 percent electric, and theycome outwith an

(202)234-4433 

### NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C.20005 (202)234-44331

5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 165

AFUE then the AFUE goes to the sky because you're not accounting for the --

MR. YOUNG: Yes, I -- MODERATOR LANGMEAD: There was a question over here. Yes?

MR. MARRAN: John Marran, Energy Kinetics. We're all engineers in this room. By nature we want to put a specific number on the paper and make that number stand that the consumer can stand back and make an educated decision. And I think we're all buried in two things. The first is we want to put the number on the paper, and the second is that number has to be regulated as a minimum energy efficiency standard. We want to be able to put a number on the paper that's a minimum energy efficiency standard.

And because of this concept, we're trapped. Everything we do has to be so specific that

we can 't delineate it all for every house in every part of the country everywhere, and yet we're trying to come up with all these factors so, the poor consumer can go into a GAMA directory, take out his slide ruler, his calculator, and do a complete energy analysis and a cost effective analysis and they're not capable of doing it. They're just not capable of

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 165 1 AFUE then the AFUE goes to the sky because you're not 2 accounting for the

-- 3 

### MR. YOUNG: Yes, I

-- 4 

### MODERATOR LANGMEAD: Therewas a question 5 over here.

7 

### MR. MARRAN: JohnMarran, EnergyKinetics. 8 We're all engineers in this room. By nature we want 9 to put a specific number on the paper and make that 10 number standthat theconsumercan standback andmake 11 aneducateddecision. And I think we're allburiedin 12 two things. The first iswe want toput the number on 13 the paper, and the second is that number has to be 14 regulatedas a minimumenergyefficiency standard. We 15 want to be able to put a number on the paper that's a 16 minimum energy efficiency standard. 

### 17 And because of this concept, we're 18 trapped. Everything we do has to be so specific that 19 we can't delineate it all for every house in every 20 part of the country everywhere, and yet we're trying 21 tocomeup withall these factors so'thepoor consumer 22 can go into a GAMA directory, take out his slide 23 ruler, his calculator, and do a complete energy 24 analysis and a costeffectiveanalysis andthey'renot 25 

### capable of doing it. They're just not capable of

(202)234-4433 NEAL R. GROSS COURTREPORTE!,!SANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C.20005 (202)234-4433166 doing it. And you all know, nobody does that. Even 2 your best contractors don't do that. How do you 3 expect the consumer to do it? 4 And I think maybe we're in an era of 5 change in this country, I think, and that we want a 6 market driven economy and market driven decisions. 7 And if we really took that into account, we would say 8 let's put the cost to operate the equipment for a year 9 or for ten years on the paper, everybody goes to the 10 same formulation. And you might have regions, and you 11 might have to put six regions or something on it, but 12 at least for region six you could look at the cost to 13 run all of these different ways, add them up as a 14 dollar number for the ear. y 15 And you wouldn't even know what the 16 efficiency was, but you'd know by buying that 17 appliance that you're going to spend $600.00 more a 18 year, I might get my money back in two years, I might 19 get my money back in five years, or I should never 20 have bought it in the first place. It's tough when 21 you've got government regulations sitting back here 22 that you've got to work to. But can we always be 23 driven by the status quo, can we not break out and say 24 what is really good for the country, what is really 25 good for the consumer. I don't know, I come at it

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 7323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 166 1 doing it. And you all know, nobody does that. Even 2 your best contractors don't do that. How do you 3 expect the consumer to do it? 4 

### And I think maybe we're in an era of 5 change in this country, I think, and that we want a 6 market driven economy and market driven decisions. 7 And if we really took that into account, we would say 8 let'sput the costto operatetheequipment for a year 9 or for ten years on the paper, everybody goes to the 10 same formulation. And youmight have regions, andyou 11 might have to put six regions or something on it, but 12 at least for region six you could look at the cost to 13 run all of these ditferent ways, add them up as a ·14 dollar number for the year. 15 And you wouldn't even know what the 16 efficiency was, but you'd know by buying that 17 appliance that you're going to spend $600.00 more a 18 year, I might get my money back in two years, I might 19 get my money back in five years, or I should never 20 have bought it in the first-place. It's tough when 21 you've got government regulations sitting back here 22 that you've got to work to. But can we always be 23 drivenby the status quo, canwe not break out and say 24 'what is really good for the country, what is really 25 good for the consumer. I don't know, I come at it

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSAND TRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202).234-4433167 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 somebody must want to respond to that?

Cyrus, do you? MR. NASSERI: Well, disregarding where I'm coming from, as just a private citizen in answer to 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 these efficient appliances available in the market?

MR. MARRAN: If maybe we had better energy descriptors, it might have worked.

MR. NASSERI.: No, my question was -- MR. MARRAN: I think if we had dollars to operate as our descriptor, maybe it might have worked.

MR. NASSERI: Well, there is improving process of labeling maybe and rating. But my question was in the program you're talking about, because you referred to government regulators and this sort of general terms, and my question to you is, if you did not have such a program, which was obviously before my time when it started, would we today have refrigerators which are probably 60 to 70 percent more efficient than ten years ago?

MODERATOR LANGMEAD: Cyrus, let me try to

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON

. D.C. 20005 (202) 234-4433 167 1 differently I guess. 

### 2 MODERATOR LANGMEAD: I'm sure somebody 3 must want to respond to that? 

### 4 Cyrus, do you? 5 MR. NASSERI: Well, disregardingwhere I'm 6 coming from, as just a private citizen in answer to 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 these 10 efficient appliances available in the market? 11 MR. MARRAN: Ifmaybewehadbetterenergy 12 descriptors, it might have worked. 

### 13 MR.**NASSERI~:** No, my question was -- 

### 14 MR. MARRAN: I think if we had dollars to 15 operate as ourdescriptor, maybe itmighthaveworked. 16 MR. NASSERI: Well, there is improving 17 process of labelingmaybe and rating. Butmy question 18 was in the program you're talking about, because you 19 referred to government regulators and this sort of 20 general terms, and my question to you is, if you did 21 nothave sucha program, whichwas obviouslybeforemy 

### 22 time when it started, would we today have 23 refrigeratorswhich areprobably 60 to 70percentmore 24 efficient than ten years ago? 

### 25

(202)234-4433 MODERATOR LANGMEAD: Cyrus, let me try to NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44331 2 3 4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 168

give a brief answer to that. I can't resist any longer. The original concept between EPCA and then NEACA was to set some minimum efficiencies that address some perceived market imperfections that occur and was to get the lower efficient units off the market and bring the level up to those that were going to be cost effective at the bottom end of the market.

This whole discussion is driven by a gas engine heat pump that is not at the bottom of the market. And I ask a question, does it really need minimum standards and is there any point to have it? And I was serious.

Now, because I don' t know there's a product that needs to fall under NEACA regulations at all. Now, it wouldn't sell unless the marketplace can move that unit as an efficient market and more efficient and at less cost of operation than existing equipment in the marketplace.

I think I 'm answering your question. You 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 to project out to the cost of operation of that unit in 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) 234-4433 168 1 give a brief answer to that. I can't resist any 2 longer. 3 TheoriginalconceptbetweenEPCA andthen 4 NEACA was to set some minimum efficiencies that 5 address someperceivedmarketimperfectionsthatoccur 6 and was to get the lower efficient units off the 7 market and bringthe level up to those thatwere going 8 to be cost effective at the bottom end of the market. 9 This whole discussion is driven by a gas 10 engine heat pump that is not at the bottom of the 11 market. And I ask a question, does it really need 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 a 15 product that needs to fall under NEACA regulations at 16 all. Now, itwouldn't sell unless themarketplace can 17 move that unit as an efficient market and more 18 efficient and at less cost of operation than existing 19 equipment in the marketplace. 20 I think I'm answering your question. You 21 know, I have a question of whether or not the whole

-- 22 heat pumps needs to be considered for setting a 23 minimum standard. If it's not, we've got good ways to 24 project out to the cost of operation of that unit in 25 a given site. And somebody can make a comparison, a

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202)234-44331

4 5

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 169

person, it isn't going to be a homeowner, but the sales is going to have to be a better salesman, and he's going to have to come in with a program to show differences in cost.

MODERATOR LANGMEAD: Yes? MR. MARGOLIS: Eugene Margolis, Department of Energy. From my reading of the statute, gas fired heat pump is not a covered product. It doesn't fall under the definition of heat pump. Therefore, if it is not a covered product, then as Carl said, and you had said, we have to look at how a new product, a new product becomes a covered product and then we have so many kilowatts, and some millions of kilowatt hours, and it has to be meet that.

What I'm saying is that just based on the definition of a heat pump, a gas fire heat pump, doesn 't come under that definition because it says in the definition a heat pump is electrically fired.

Now, if someone or everybody or whoever thinks that that is wrong, I would appreciate very much that they would submit in writing how, why a gas fired heat pump presently is a covered product and comes under the definition section where a heat pump is defined. 

## 251

## 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) 2344433 

### 169 1 person, it isn't going to be a homeowner, but the 2 sales is going to have to be a better salesman, and 3 he's going to have to come in with a program to show 4 differences in cost. 5 

### MODERATOR LANGMEAD: Yes? 6 

### MR. MARGOLIS: EugeneMargolis, Department 7 of Energy. From my reading of the statute, gas fired 8 heat pump is not a covered product. It doesn't fall 9 under the definition of heat pump. Therefore, if it 10 is not a covered product, then as Carl said, and you 11 had said, we have to look at how a new product, a new 12 product becomes a covered product and then we have so 13 many kilowatts, and some millions of kilowatt hours, 14 and it has to be meet that. 15 What I'm saying is thatjustbased on the 16 definition of a heat pump, a gas fire heat pump, 17 doesn't come under that definition because it says in 18 the definition a heat pump is electrically fired. 19 Now, if someone or everybody or whoever 20 thinks that that is wrong, I would appreciate very 21 much that they would submit in writing how, why a gas 22 fired heat pump presently is a covered product and 23 comes under the definition section where a heat pump 24 is defined. 25

(202)234-4433 

### MODERATOR LANGMEAD: Gene, thank you for 

### NEALA. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C.20005 (202)234-4433170

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 Gas Cooling Center. That raises a interesting issue. When we rate the gas fired heat pump under, say the ANSI standard of equivalency, equivalent SEER or equivalent HSPF, does that mean from a DOE perspective and a statutory perspective we are allowed to do that, put that in the marketplace as an equivalency for comparative purposes as far as the seasonal efficiency of the unit, if you will, from a cost perspective. Is that a viable, reliable point that we can make?

MR. MARGOLIS: All I would say now in answer to that is that if it is not a covered product, it is not a covered product. DOE to then make it a covered product, it would have to have-a rulemaking first to say that this is a covered product, and then setting test procedures for it, if they don't exist already. If industry or trade association has them, we can incorporate those by reference, but we still would have to have a hearing to do that. And then we would go out and then set standards to another rulemaking based on those test procedures.

What you would do, I mean what you would do otherwise, I don't know. I mean I would just say

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 170 1 that clarification. 2 Yes? 3 

### MR. SWEETSER: RichSweetser., AmericanGas 4 

### Cooling Center. That raises a interesting issue. 5 When we rate the gas fired heat pump under, say the 6 ANSI standard of equivalency, equivalent SEER or 7 equivalentHSPF, does thatmeanfrom a DOE perspective 8 and a statutoryperspectivewe are allowedtodothat, 9 put that in the marketplace as an equivalency for 10 comparativepurposes asfar asthe seasonal efficiency ·11 of the unit, ifyou will, from a cost perspective. Is

12 that a viable, reliable point that we can make? 13 MR. MARGOLIS: All I would say now in 14 answer to that is that if it is not a covered product, 15 it is not a covered product. DOE to then make it a 16 covered product, it would have to have#.a rulemaking 17 first to say that this is a covered product, and then 18 setting test procedures for it, if they don't exist

r 

### 19 already. If industry or trade association has them, 20 we can incorporate those by reference, but we still 21 would have to have a hearing to do that. And then we 22 would go out and then set standards to another 23 rulemaking based on those test procedures. 24 What you would do, I mean what you would 25 do otherwise, I don't know. I mean I would just say

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44332 3

6

8

10 11 12 13 .14 15 16 17 18 19 20 21 .22 23 24 171

personally and not a Department position, is that it' s not a covered product, you can do anything you want. If what you're doing might be in violation of the FTC Act, I'm not saying the labeling, then, you know, those consequences, if it's an unfair presentation by you, which then might be in violation of the FTC Act. I understand.

MR. SWEETSER: I understand. In other words, if we're making unfair representation, we would follow whatever the FTC Act is for false advertising.

MR. MARGOLIS: That's right. MR. SWEETSER: Okay. But what I'm trying to get to, and this is any new class of products whether it's a combination product, whether it's a dual fuel heat pump, whether it-'s a desiccant system which we really haven't talked much about yet, these products come out, there's always this fuzzy area which says under the Energy Policy Act as far as appliance efficiency standards, DOE is the only one that can set appliance sufficiency standards.

Now, you're saying that if it's not a covered product, it's not a covered product and we don't care about it --

MR. MARGOLIS: I'm not saying don't care 2511 about it.

(202) 2344433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 

### 171 1 personallyandnot a Departmentposition, is that it's 2 

### not a covered product, you can do anything you want. 3 If what you're doing might be in violation of the FTC 4 Act, I'm not saying the labeling, then, you know, 5 those consequences, if it's anunfair presentationby 6 you, which then might be in violation of the FTC Act. 7 I understand. 8 

### MR. SWEETSER: I understand. In other 9 words, ifwe'remakingunfairrepresentation, we would 10 follow whatever the FTC Act is for false advertising. 11 MR. MARGOLIS: That's right. 12 MR. SWEETSER: Okay. But what I'm trying 13 to get to, and this is any new class of products .14 whether it's a combination product, whether it's a 15 dual fuel heat pump, whether it's a desiccant system 16 which we really haven't talked much about yet, these 17 products come out, there's always this fuzzy area 18 which says under the Energy Policy Act as far as 19 appliance efficiency standards, DOE is the only one 20 that can set appliance sufficiency standards. 21 Now, you're saying that if it's not a .22 

### covered product, it's not a covered product and we 23 don't care about it

-- 24 

### 25 about it.

(202)234-4433 

### MR. MARGOLIS: I'm not saying don't care

NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODEISLANDAVEN!JE.NoW. WASHINGTON. D.C.20005 (202)234-44333 4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 172 MR. SWEETSER: -- I understand. But DOE has no position on it, it's not a covered product, and we are free as long as we are good stewards under the FTC as its structured --

MR. MARGOLIS: I'm saying that right now we have not looked at that and gotten an official -- it has not been brought to the general counsel to get a sign-off on the legal position on that. But I'm saying I don't see where that is any different than if a state would have a standard out there for a product that is not a covered product --

MR. SWEETSER: So you're saying -- MR. MARGOLIS: -- and I'm not -- MODERATOR LANGMEAD: Mike, do. you want to add something?

MR. McCABE: Yes, let me jump in. Mike McCabe. As long as we have not issued a test procedure for a product or for an efficiency descriptor, that descriptor does not have any standing with the Department . And there are a number of instances within industries which have come to DOE and wanted to change their positions. And we'd like to have a descriptor, and I'm thinking about two examples .: One is the ground couple heat pumps. We have been working to develope a efficiency descriptor

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 172 1 MR. SWEETSER:

-- I understand. But DOE 2 has no positionon it, it's not a covered product, and 3 we are free as long as we are good stewards under the 4 FTC as its structured

-- 5 MR. MARGOLIS: I'm saying that right now 6 we have not looked at that and gotten an official

-- 7 it has not been brought to the general counsel to get 8 a sign-off on the legal position on that. But I'm 9 saying I don't seewhere that :i,s anydifferent than if 10 a state would have a standard out there for a product 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 to 15 add something? 16 MR. McCABE: Yes, let me jump in. Mike 17 McCabe. As long as we have not issued a test 18 procedure fora product or for an efficiency 19 descriptor, thatdescriptordoesnothave any standing 20 with the Department. And there are a number of 21 instanceswithinindustrieswhichhavecometoDOE and 22 wanted to change their positions. And we'd like to 23 have a descriptor, and I'm thinking about two 24 examples.

. One is the ground couple heat pumps. We 25 have been working to develope a efficiency descriptor

(202)234-4433 

### NEALR. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C.20005 (202)234-44331

3

5 6 7

10 11 12 13 -14 15 16 17 18 19 20 21 22 23 24 25 173

for those products compared to the electric products. Less electricity, there are some benefits for them, but to make amendments, expressly excluded them from the program. Subsequent to that they found some of the manufacturers in the association said that they found that they needed to have, they would like to have, someone would like to have a descriptor in order to market the product. You're on your own, but you cannot have a DOE sanctioned descriptor which some utilities wanted to have. So they have a descriptor, but there are a lot of deficiencies with that. Not necessarily technical deficiencies, but market deficiencies.

MODERATOR LANGMEAD: No, Good Housekeeping Seal of Approval? .

MR McCABE: Solar water heaters. The EPCA legislation defines what energy is, wood, coal, solar, they're not energy, at least not as far as this program is concerned .- We have tried to work with the industry who would like to be able to market their product and compete against electric resistance heat pump water heaters to show they're better . We cannot give them the same Good Housekeeping Seal of Approval.

(202) 234-4433 And while engine driven heat pumps are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 173 1 for those products compared to the electric products. 2 Less electricity, there are some benefits for them, 3 but to make amendments, expressly excluded them from 4 the program. 5 Subsequent to that they found some of the 6 manufacturers in the association said that they found 7 that they needed to have, they would like to have, 8 someone would like to have a descriptor in order to 9 market the product. You're on your own, but you 10 cannot have a DOE sanctioned descriptor which some 11 utilities wanted to have. So they have a descriptor, 12 but there are a lot of deficiencies with that. Not 13 necessarily technical deficiencies, but market ·14 deficiencies. 15 MODERATORLANGMEAD: No, GoodHousekeeping 16 Seal of Approval? 17 MR. McCABE: Solar water heaters. The 18 EPCA legislation defines what energy is, wood, coal, 19 solar, they'renot energy, at leastnot as far as this 20 program is concerned. We have tried to work with the 21 industry who would like to be able to market their 22 product and compete against electric resistance heat 23 pump water heaters to show they're better. We cannot 24 givethemthe sameGoodHousekeepingSealofApproval. 25 And while engine driven heat pumps are

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-44331 2 3 4 5

7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 174

really very efficient, use substantially less energy, and DOE may never want to set minimum efficiency standards for those products, my question is, given 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 in the marketplace that would warrant a test procedure for the product sanctioned from the Department so that manufacturers could go out and market the hell out of these products with us being able to do things to support that. And if we don't have a test produce and don't have a DOE measure of efficiency, is that a good thing or is that a bad thing? Can we develope a test procedure that will help market these products?

That' s one the things that the labeling program is all about, and test procedures is an integral part of that, is to be able to help provide information to the market so that more efficient products can be sold and can be accepted. And if we have confusion in the marketplace, it's not going to help manufacturers sell products.

And we may not have a standard for some of these products. I agree that when we look at -- water heater, when we look at it by itself, it's - or an

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 174 1 reallyveryefficient, use substantially less energy, 2 and DOE may never want to set minimum efficiency 3 standards for those products, my question is, given 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 Butaretherethingsthat arehappeningin 8 the marketplace that would warrant a test procedure 9 for theproduct sanctioned fromtheDepartment so that 10 manufacturers could go out and market the hell out of 11 these products with us being able to do things to 12 supportthat. And ifwe don'thave a testproduce and 13 don'thave a DOE measure of efficiency, is that a good 14 thing or is that a bad thing? Can we develope a test 15 procedure that will help market these products? 16 That's one the things that the labeling 17 program is all about, and test procedures is an 18 integral part of that, is to be able to help provide 19 information to the market so that more efficient 20 products can be sold and can be accepted. And if we 21 have confusion in the marketplace, it's not going to 22 help manufacturers sell products. 23 Andwe maynothave a standard for someof 24 theseproducts. I agree that whenwe look at**-~** 

### water 25 heater, when we look at it by itself, it's

-- or an

(202)234-4433 

### , NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C.20005 (202)234-4433175

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 new

technologies, more efficient than some similar products, whether or not you're talking about 100 to 125 percent improvement over some other base -- who really gives a damn. Because you want to get those products at that marketplace, and one must, for the Department to do anything, that would limit their admission into the market.

I think that some of the things we've done in the past has caused some anxiety in the marketplace and has limited some of these products from getting out there, and so what can we do.

MODERATOR LANGMEAD: And let me just add to what Mike is saying. We've got with the engine driven heat pump, we've got an ANSI Z21.40. There is an ASHRAE revisions of the ASHRAE standard 40 going on. I understand the groups are working together. In that process would be a beautiful place to set up what is needed fo DOE to adopt a test procedure and, if necessary , a discussion of a descriptor so the mechanism is set up to get from here to there and the product can use descriptors that are derived from and based on, or cost of operation, is based entirely on a voluntary standard.

And I think it would stand the test of

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 

### 175 1 

### engine driven heat pump, some of these new 2 technologies, more efficient than some similar 3 products, whether or not you're talking about 100 to 4 125 percent improvement over some other base

-- who 5 really gives a damn. Because you want to get those 6 products at that marketplace, and one must, for the 7 Department to do anything, that would limit their 8 admission into the market. 9 I think that someofthethingswe'vedone 10 inthepasthascaused some anxietyinthemarketplace 11 and has limited some of these products from getting 12 out there, and so what can we do. 13 MODERATOR LANGMEAD: And let me just add 14 to what Mike is saying. We've got with the engine 15 driven heat pump, we've got an ANSI Z21.40. There is 16 an ASHRAE revisions of the ASHRAE standard 40 going 17 on. I understand the groups areworkingtogether. In 18 thatprocess wouldbe a beautiful'placeto setupwhat 19 is needed fo DOE to adopt a test procedure and, if 20 necessary, a discussion of a descriptor so the 21 mechanism is set up to get from here to there and the 22 product can use descriptors that are derived from and 23 based on, or cost of operation, is based entirely on 24 a voluntary standard. 25 And I think it would stand the test of

(202)234-4433 NEAL

### A. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44331

4 5

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 176

being in compliance with the Federal Trade Commission Regulations because it was based on national standard. So I think the mechanism is there and to refine the process is coming.

MR. MARGOLIS: Eugene Margolis. I just want to add, if we are talking about a test procedure, as Michael is saying , are we presuming that it is a covered product because you can have first a covered product and we didn't set a test procedure yet and we will set one now, so therefore you can have as an ANSI 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 procedure we would have to say that it is a covered product, and I'm saying that under that, I think it's section 323 of EPCA, which defines how do you cover a new product.

So even if you have a test procedure, if the use of energy doesn 't qualify under 323, it won't be a covered product. So if ANSI is doing this, I think they would also, it would behoove them, submit to us that it is a covered product and meeting those requirements of having energy users and so on. You know, we could do that ourselves, but you're 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) 234-4433 176 1 being in compliance with the Federal Trade Commission 2 Regulationsbecauseitwasbasedonnational standard. 3 So I think the mechanism is there and to refine the 4 process is coming. 5 MR. MARGOLIS: Eugene Margolis. I just 6 want to add, ifwe are talking about a test procedure, 7 as Michael is saying, are we presuming that it is a 8 covered product because you can have first a covered 9 product and we didn't set a test procedure yet and we 10 will set onenow, so therefore you canhave as anANSI 11 comes up and we could adopt their test procedure. 12 However, if the product under the statute is not a 13 covered product, before we can set the test procedure 14 we would have to saythat itis a coveredproduct, and 15 I'm saying that under that, I think it's section 323 16 of EPCA, which defines how do you cover a new product. 17 So even if you have a test procedure, if 18 the use of energy doesn't qualify under 323, it won't 19 be a covered product. So if ANSI is dOing this, I 

### 20 think they would also, it would behoove them, to 21 submit to us that it is a covered product and meeting 22 those requirements of having energy users and so on. 23 You know, we could do that ourselves, but you're 24 presenting the whole, you know, a test procedure and 25 everything.

(202)234-4433 

### NEAL R. GROSS COURT REPPRTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202)234-44331

3

5 6

8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 177 I think before you even go to that test procedure you should determine whether or not we can make it a covered product.

MODERATOR LANGMEAD: Well, Joe, do you want to make a point?

MR. PIETSCH: Joe Pietsch, Engineering Consultant. The partial value of our covered product is one that has an aggregate household energy use in the United States that apprises such types exceeding 4.2 million kilowatt hours or equivalent. And I just make 'kind of a rough calculation, but it looks like you have to have to have on the order of 100,000 to 200,000 engine driven heat pumps to meet that criteria. So that kind of gives you a feel for how many heat pumps would have to be out there --

MODERATOR LANGMEAD: So it's going to probably take some time as we progress in that direction. MR. PIETSCH: Next year.

MR. SWEETSER : Well, one point of clarification, all of these new class of technologies to prevent a natural confusion, Rich Sweetser, American Gas Cooling Center, that happens out in the marketplace is how do you evaluate those units. And if they are not covered products, the manufacturers or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 2344433 

### 177 1 I think before you even go to that test 2 procedure you should determine whether or not we can 3 make it a covered product. 4 

### MODERATOR LANGMEAD: Well, Joe, do you 5 want to make a paint? 6 

### MR. PIETSCH: Joe Pietsch, Engineering 7 Consultant. The partial value of our covered product 8 is one that has an aggregate household energy use in 9 the United States that apprises such types exceeding 10 4.2 million kilowatt hours or equivalent. And I just 11 make'kind of a rough calculation, but it looks like 12 you have to have to have on the order of 100,000 to 13 200,000 engine driven heat pumps to meet that 14 criteria. So that kind of· gives you a feel for how 15 many heat pumps would have to be out there 16 MODERATOR LANGMEAD: So it's going to 17 probably take some time as we progress in that 18 direction. 19 MR. PIETSCH: Next year. 20 MR. SWEETSER: Well, one point of 21 clarification, all of these new class of technologies 22 to prevent a natural confusion, Rich Sweetser, 23 American Gas Cooling Center, that happens out in the 24 marketplace is how do you evaluate those units. And 25 ifthey arenot coveredproducts, themanufacturersor

(202)234-4433 NEALA. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w, WASHINGTON, D.C.20005 (202)234-44332

4 5 6 7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 178

other entities come in and they do their best within, hopefully, legal terms and ethical terms to have a covered product out there.

My understanding of what you have told us is, not being covered product means we don 't have the Good Housekeeping Seal of Approval yet, but it is not covered by the NEACA standards, they're not subject to the NEACA standard issues at this juncture. Is that fair? MR. MARGOLIS: Right. And all of the penalties that --

MR. SWEETSER: Penalties or benefits that accrue there of, of course.

MODERATOR LANGMEAD: Okay, let's not repeat things now, and we'll just try to wrap this one 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 an advertisement an HSPF, an AFUE, an SEER?

MR. McCABE: Michael McCabe. No. MR. DOUGHERTY: Okay. MR. MARGOLIS: I think they would be then 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) 234-4433 178 1 other entities come in and they do their best within, 2 hopefully, legal terms and ethical terms to have a 3 covered product out there. 

### 4 My understanding of what you have told us 5 is, not being covered product means we don't have the 6 Good Housekeeping Seal of Approval yet, but it is not 7 coveredbytheNEACA standards, they'renot subjectto 

### 8 the NEACA standard issues at this juncture. Is that 9 fair? 10 MR. MARGOLIS: Right. And all of the 11 penalties that

-- 12 MR. SWEETSER: Penalties orbenefits that 13 accrue there of, of course. 

### 14 MODERATOR LANGMEAD: Okay, let's not 15 repeat things now, and we'lljusttryto wrap this one 16 up. 17 Yes? 18 MR. DOUGHERTY: Brian Dougherty, NIST. 19 May I take it one step further? So then if it's not. 20 a covered appliance, they can report in an 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 then 25 coming to the FTC and be giving false information.

(202)234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C.20005 (202)234-4433 

### I I3 4

6

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 179 MR. SWEETSER: Can we report an equivalent 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 time has to speak.

All right, Jack Langmead. If you're basing your numbers on a nationally recognized standard, I believe I said before, I think it would pass the FTC test equivalency, but you would have to do it in accordance with that nationally recognized standard. Maybe that nationally recognized standard would be found deficient, but that would be another question. Yes?

MR. ADAMS: Carl Adams , DOE. Just to somewhat muddy the waters regarding covered product or not, regarding gas fired heat pumps. In the advance notice that we published when we listed design options for furnaces , we listed gas fired heat pump as the max tech design option to be considered. Everybody may not agree with that, but when you look at the term, the definition of the term "furnace, a product which utilizes only single phase electric current in

(202) 234433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 179 1 

### MR. SWEETSER: Canwe reportanequivalent 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 time 7 has to speak. 8 

### All right, Jack Langmead. If you're 9 basing your numbers on a nationally recognized 10 standard, I believe I said before, I think it would 11 pass the FTC test equivalency, but you would have to 12 do it in accordance with that nationally recognized 13 standard. Maybe that nationally recognized standard 14 would be found deficient, but that would be another 15 question. 16 Yes? 17 MR. ADAMS: Carl Adams, DOE. Just to 18 somewhatmuddythewatersregardingcoveredproductor 19 not, regarding gas fired heat pumps. In the advance 20 noticethatwe publishedwhenwe listeddesignoptions 21 for furnaces, we listedgas fired heatpump as the**ma~** 

### 22 tech design option to be considered. Everybody may 23 not agree with that, but when you look at the term, 24 the definition of the term "furnace, a product which 25 utilizes only single phase electric current in

(202)234-4433 NEALR. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.w. WASHINGTON. D.C.20005 (202)234-44331 2 3 4 5 6 7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 180

conjunction with natural gas, designed to be the principal heating source for the living space of a residence, not in a cabinet with a central air conditioner of more than 65,000 BTUs an hour, is a forced air central furnace and has a heat input rate of less than 220,000 BTUs per hour," I think it could 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 not to count it with a central air conditioner, and the heating side is in the same cabinet with the central 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) 234-4433 

### 180 1 conjunction with natural gas, designed to be the 2 principal heating source for the living space of a 3 residence, not in a cabinet with a central air 4 conditioner of more than 65,000 BTUs an hour, is a 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 heat 8 pump does meet that definition of a furnace. 9 

### MR. SWEETSER: I think so. You said not 10 to count it with a central air conditioner, and the 11 heating side is in the same cabinet with the central 12 air conditioner. 13 

### MR. ADAMS: In a cabinet with less than, 14 a central air condition with less than 65,000 BTUs an 15 hour. 16 

### MR. SWEETSER: Yes, so far we're there. 17 

### MODERATOR LANGMEAD: Jim Ranfone? 18 MR. RANFONE: Jim Ranfone, AGA. I think 19 we're well beyond the discussion that you wanted to 20 take place in the session first of all, and we're 21 wasting a lot of time. 22 I'd like to get back to the energy 23 descriptors themselves and ask a question that, you 24 know, it looks like there are at least some in the 25 room that believe that cost shouldbe thebasis for an

(202)234-4433 

### NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-44331

4

6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 181

energy descriptor or maybe not the basis, but that's what consumers want. And I would ask the question, if you have other products such as water heaters that have labels that have cost on them, and I don't understand your arguments about not having the dollar cost -- and it has climatic interface that changes that cost. But you also have direct heating equipment which includes gas fired room heaters, oil furnaces, and also applies to electric and oil products, if I remember correctly. And I think that while the FTC chose not to require labeling for that product, but it would still fall under the FTC labeling rule such that anybody that manufactured it making a claim about energy usage or cost of operation would have to do it on the basis of dollars per million BTUs.

And I think that's the kind of thing that we're trying to, if that would be an acceptable ,alternative, if you can keep it in that context. You already had a precedent in existing labeling rules as 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) 234-4433 181 

### 1 energy descriptor or maybe not the basis, but that's 2 what consumers want. And I would ask thequestion, if 3 you have other products such as water heaters that 4 have labels that have cost on them, and I don't 5 understand your arguments about not having the dollar 6 cost

-- and it has climatic interface that changes 7 that cost. 8 Butyoualsohavedirectheatingequipment 9 which includes gas fired room heaters, oil furnaces, 10 and**~lso** 

### applies to electric and oil products, if I 11 remember correctly. And I think that while the FTC 12 chosenot torequire labeling for thatproduct, but it 13 would still fall undertheFTC labelingrule suchthat 14 anybody that manufactured it making a claim about 15 energy usage or cost of operation would

..have to do it 16 on the basis of dollars per million BTUs. 17 And I think that's the kind of thing that 18 we're trying to, if that would be an acceptable 19 'alternative, if you can keep it in that context. You 20 alreadyhad a precedent inexisting labeling rules as 21 well as testingprocedures thatpermityou todothat. 22 23 And maybe Cyrus can answer that question, 24 or is Cyrus here? 25

(202)234-4433 

### MODERATOR LANGMEAD: No. NEALR. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N,W. WASHINGTON, D,C.20005 (202)234-44331 2 3

5 6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 182 MR. RANFONE: Anyway, HSPF, James, do you have any idea, is that still true, that the direct heating equipment, if a manufacturer claims energy consumption, be it gas, electric, oil, has to be based on the DOE test procedures, number one, and number two that -- on a national average cost per million BTUs?

MR. MILLS: James Mills, Federal Trade Commission. There is a section of the Energy Policy and Conservation Act that you're referring to, which is section 323C that requires that if a product is a product for which there is a test procedure, which would be the direct heating equipment, a manufacturer. making a representation as to the cost of energy consumed, or not of energy consumed, the efficiency, would have to have the representation fairly reflect 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 the test procedure does say something about the cost would be on dollars per million BTUs. So that may be an existing precedent that you're arguing about here that's already in one test procedure and possibly

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON

. D.C. 20005 (202) 234-4433 

### 182 1 

### MR. RANFONE: Anyway, HSPF, James, do you 2 have any idea, is that still true, that the direct 3 heating equipment, if a manufacturer claims energy 4 consumption, be itgas, electric, oil, has tobebased 5 ontheDOE testprocedures, numberone, and numbertwo 6 that

-- on a national average cost per million BTUs? 7 

### MR. MILLS: James Mills, Federal Trade 8 Commission. There is a section of the Energy Policy 9 and Conservation Act**~hat** 

### you're referring to, which 10 is section 323C that requires that if a product is a 11 product for which there is a test procedure, which 12 would be the direct heating equipment, a manufacturer. 13 making a representation as to the cost of energy 14 consumed, or not of energy consumed, the efficiency, 15 would have to have the representation fairly reflect 16 the resultsof theDOE testprocedureonthat product. 17 

### MR. RANFONE: I think the test procedure, 18 and I'm not sure there's anybody

-- 19 MODERATORLANGMEAD: Alittlelouder, Jim, 20 we can't hear you. 21 MR. RANFONE: Jim Ranfone. I think the 22 testproceduredoes saysomethingabout thecostwould 23 be on dollars per million BTUs. So that may be an 24 existing precedent that you're arguing about here 25 that's already in one test procedure and possibly

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. NW. WASHINGTON. D.C.20005 (202)234-44331

5 '6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 183

could be brought into other test procedures. There seems to be an indication of some that --

MODERATOR LANGMEAD: Any other discussion on this point?

We have seemed to have moved of f of the multi-fuel heat pumps, and if somebody wants to come back on that, they can.

Yes, in the back? MR. WILHELM: Barry Wilhelm with Virginia Power. I would like to just try to forget about this word "equivalent" for just a few seconds. It's very ambiguous and confusing to the consumer and everybody else. But can someone, I'm sure in this room, tell me what the actual efficiency of the unit is, like in COP 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, Brian Dougherty, NIST, as far as output over input, what do you constitute as input in electrical and gas, and how do you make that into one -- that's consistent?

MR. WILHELM: Either one, let's just say gas. Either one, it doesn't matter.

MR. DOUGHERTY: I mean isn't that what 2511 the--

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON

. D.C. 20005 (202) 234-4433 183 1 could be brought into other test procedures. There 2 seems to be an indication of some that

-- 3 MODERATOR LANGMEAD: Any other discussion 

### 4 on this pOint? 5 We have seemed to have moved off of the 6 multi-fuel heat pumps, and if somebody wants to come 7 back on that, they can. 8 Yes, in the back? 9 MR. WILHELM: BarryWilhelm withVirginia 10 Power. I would like to just try to forget about this 11 word "equivalent" for just a few seconds. It's very 12 ambiguous and confusing to the consumer aod everybody 13 else. But can someone, I'm sure in this room, tell me ·14 what the actual efficiencyof theunit is, like inCOP 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, Brian 

### 19 Dougherty, NIST, as far as output over input, what do 20 you constitute as input inelectrical and gas, andhow 21 do you make that into one -- that's consistent? 22 MR. WILHELM: Either one, let's just say 23 gas. Either one, it doesn't matter. 24 25 the--

(202)234-4433 MR. DOUGHERTY: I mean isn't that what

NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C.20005 (202)234-4433184 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 oneMR. DOUGHERTY: -- and the standard that 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 to times that by --

MODERATOR LANGMEAD: Let's identify yourself please.

MR. WILHELM: -- you have a COP of 1.25, multiply that times, what 3. something, and you get a SEER value of about a little less than 4. Air source heat pump, let's say is a 10. So what you've got still is a air source heat pump is at least two and half to three times as efficient as the gas fired heat pump. So what this word "equivalent" does, it gets back to what we talked about this morning which is source and cost. I think pretty much everybody in here has been fairly quiet and I think the reason is, is obviously the word "equivalent" is just truly a sales gimmick and that's about all it is.

MODERATOR LANGMEAD: I have a couple of responses. Let's take Frank first and then go up the

room.

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 184 1 

### MR. WILHELM: Somethinga littleoverone2 3 

### MR. DOUGHERTY: and the standard that 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 to 8 times that by

-- 9 

### MODERATOR LANGMEAD: Let's identify 10 yourself please. 11 MR. WILHELM:

-- you have a COP of 1.25, 12 multiply that times, what 3. something, and you get a 13 SEER value of about a little less than 4. Air source 14 heat pump, let's say is a 10. So what you've got 15 still is a air source heat pump is at least two and 16 half to three times as efficient as the gas fired heat 17 

### pump. So what this word "equivalent" does, it gets 18 back to what we talked about this morning which is 19 

### source and cost. I think pretty much everybody in 20 here has been fairly quiet and I think the reason is, 21 is obviously the word "equivalent" is just truly a 22 sales gimmick and that's about all it is. 23 MODERATOR LANGMEAD: I have a couple of 24 responses. Let's take Frank first and then go up the 25 room.

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202) 234-44331 2 3 4 5 6 7 8 9 10 11 12 13 14 15 1.6 17 18 19 20 21 22 23 24 25 185 MR. JAKOB: Frank Jakob, Batelle. I just heard some mathematical calculations that I didn't quite, follow. The standard does not have the word "equivalent" in it. That's been bantered around this table, but there was careful attention paid to the language in the standard and there is no such thing as "equivalent source" or "equivalent cost" in the body of the standard.

It talks about the SEER of an electric air conditioner, and if you look in the ARI director for a three ton air conditioner that costs $300.00 a ,year to operate, you'll find it has a 14 SEER. And a gas heat pump costs about $300.00 to operate. That's the calculation that's being performed.

MR. WILHELM: Get back to the cost issue-- MODERATOR LANGMEAD: Yes, next? MR. DOUGHERTY: Brian Dougherty, NIST. In ads that I have seen that the manufacturer is producing, I recall seeing SEER and then 14, 15, I can't remember what the number was, but I, remember seeing the advertisement. I don't remember seeing "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 in violation of using the DOE descriptor for appliance

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 185 1 

### MR. JAKOB: Frank Jakob, Batelle. I just 2 heard some mathematical calculations that I didn't 3 

### quite. follow. The standard does not have the word 4 "equivalent" in it. That's beenbantered around this 5 table, but there was careful attention paid to the 6 language inthe standard and there is no suchthing as 7 "equivalent source" or "equivalent cost" in the body 8 of the standard. 9 Ittalks aboutthe SEER of anelectricair 10 conditioner, and if you look in the ARI director for 11 a three ton air conditioner that costs $300.00 a year 12 to operate, you'll find it has a 14 SEER. And a gas 13 heat pump costs about $300.00 to operate. That's the 14 calculation that's being performed. 15 MR. WILHELM: Getbacktothecost issue-- 1.6 

### MODERATOR LANGMEAD: Yes, next? 17 

### MR. DOUGHERTY: BrianDougherty, NIST. In 18 ads that I have seen that the manufacturer is 19 producing, I recall seeing SEER and then 14, 15, I 20 can't remember what the number was, but I remember 21 seeing the advertisement. I don't remember seeing 22 "equivalent," I don't remember seeing "source fuel," 23 I don'tremember seeing "costequivalent,"just "SEER" 24 which is the issue of whether or not that is in 25 violation of using the DOE/descriptor for appliance

(202)234-4433 NEAL R. GROSS COURTREPORTERSAND TRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON

.. D.C. 20005 (202)234-4433186 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 Gas Cooling Center. I think the gentleman down at the end of the table proved our point, that takes us all full circle back to economics. Because if you take the strict engineering sense of comparing apples and oranges, and end up with a 4 SEER versus a 10 or a 12 or whatever SEER , you end up with a very misleading story. If you take the cost ratios on an average or in most parts of this country, the cost ratio of utilizing the gas heat pump versus a 10 SEER air conditioner or a heat pump, the gas heat pump would essentially be about half of the cost of operation or maybe two-thirds in some parts of the country, so that certainly is misleading the consumer.

If you're at all concerned about conserving resources or emissions or any of that sort, this situation is equally confused. You're turning really the information to the consumer on its head. So I think the gentleman really proved our point with 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) 234-4433 186 1 that isn't rated current DOE test

-- 2 MODERATOR LANGMEAD: Yes, next? 3 MR. SWEETSER: RichSweetser, AmericanGas 4 CoolingCenter. I think the gentlemandown at theend 5 of the table proved our point, that takes us all full 6 circle back to economics. Because if you take the 7 strict engineering sense of comparing apples and 8 oranges, and end up with a 4 SEER versus a 10 or a 12 9 or whatever SEER, you end up with a very misleading 10 story. 11 If you take the cost ratios on an average 12 or in most parts of this country, the cost ratio of 13 utilizing the gas heat pump versus a 10 SEER air 14 conditioner or a heat pump, the gas heat pump would 15 essentiallybe about half of the cost of operation or 16 maybe two-thirds in somepartsof thecountry, so that 17 certainly is misleading the consumer. 18 If you're at all concerned about 19 conservingresources oremissions oranyofthat sort, 20 this situation is equally confused. You're turning 21 really the information to the consumer on its head. 22 So I think the gentleman reallyproved our point with 23 his little mathematics. 24 25

(202)234-4433 MR. WILHELM: Thank you. MR. SWEETSER: You're welcome. NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.w. WASHINGTON, D.C. 20005 (202)234-44333 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 187 MODERATOR LANGMEAD: With that can we draw closure on the multi-fuel heat pump?

MR. KELLY: Would you summarize that? MODERATOR LANGMEAD: Yes, we have a disagreement about multipliers. I think that's been summarized over and over again.

Let's move on now and talk about international test procedures. And Ed Pollock had

some introduction into that issue.

WOMAN: Can we do a break first? MODERATOR LANGMEAD: Do you want to do a break or do you -- I think we're going to lose the audience. Does everybody want to take a break or should we just go on into this? Let's finish this and then we can take a break and people can come back and talk if they want to.

Ed? MR. POLLOCK: We're now into maybe an easier area . In the notice in the agenda for today, you have the introductions to the others says a briefing, in this case it says a brief description, so that's what we have, there it is.

Last year the ARI people came to us and asked us to consider moving towards the use of the ISO standard for rating of central air conditioners and

(202) 234.4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 187 1 MODERATOR LANGMEAD: Withthatcanwe draw 2 closure on the multi-fuel heat pump? 3 MR. KELLY: .Would you summarize that? 4 MODERATOR LANGMEAD: Yes, we have a 5 disagreement about multipliers. I think that's been 6 summarized over and over again. 7 Let'smove on now and talk about 8 international test procedures. And Ed Pollock had 9 some introduction into that issue. 

### 10 WOMAN: Can we do a break first? 11 MODERATOR LANGMEAD: Do you want to do a 12 break or do you -- I think we're going to lose the 13 audience. Does everybody want to take a break or 14 shouldwe justgo on into this? Let's finish this and 15 then we can take a break and people can come back and 16 talk if they want to. 17 Ed? 18 MR. POLLOCK: We're now into maybe an 19 easier area. In the notice in the agenda for today, 20 you have the introductions to the others says a 21 briefing, inthiscase it says a briefdescription, so 22 that's what we have, there it is. 23 Last year the ARI people carne to us and 24 askedus toconsidermoving towards theuse of the ISO 25 standard for rating of central air conditioners and

(202)234-4433 NEAL

### R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. NoW. WASHINGTON. D.C.20005 (202)234-44331 2

4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 188

heat pumps. I had already asked NIST to begin to take a look at using the ISO or parts of it because of the edict that we were under from Congress to convert our test procedures and standards over to metric units where there are dimensions involved.

And so what I wanted to find out was, what would be the impact if we did use the ISO temperate climate test criteria and at the same time change it to metric. Would we have to change the descriptor, the SEER, what would be the impact on that? Could we use metric units and some multiplier factor that would take us back to the SEER as people know it now so that we would be able to still have the same number that would be usable for demand side management programs as far as consumers and people being used to seeing those values around 10 as the standard or the other ratings for the products, so that there wouldn't be a need to re-educate the public?

That question, if we

-- the request as the ARI people have asked us, they had asked that we consider doing away with the cyclic test because the ISO standard does not have a cyclic test, it has steady state testing only. This raises a problem for us as far as what the law requires in that the law requires us to provide a methodology which can be used

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 188 1 heatpumps. I had already asked NIST to beginto take 2 a look at using the ISO or parts of it because of the 3 edict that we were under from Congress to convert our 4 test procedures and standards over to metric units 5 where there are dimensions involved. 6 And sowhat I wantedto find outwas, what 7 would be the impact if we did use the ISO temperate 8 climate test criteria and at the same time change it 9 to metric. Would we have to change the descriptor, 10 the SEER, what would be the impact on that? Could we 11 usemetricunits and somemultiplier factor thatwould 12 take us back to the SEER as people know itnow so that 13 we would be able to still have the same number that ·14 wouldbeusable fordemand sidemanagementprograms as 15 far asconsumers and peoplebeingused to seeingthose 16 values around 10 as .the standard or the other ratings 17 for the products, so that there wouldn't be a need to 18 re-educate the public? 19 Thatquestion, ifwe -- therequest as the 20 ARI people have asked us, they had asked that we 21 consider doing away with the cyclic test because the 22 ISO standard does not have a cyclic test, it has 23 steady state testing only. This raises a problem for 24 us as far as what the law requires in that the law 25 requires us to provide a methodologywhichcanbeused

(202)234-4433 NEALR. GROSS COURTREPORTERSAND TRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C.20005 (202)234-44331 2 3 4

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 189

to calculate annual operating costs. I am not sure what the answer to that is. That's another thing that -- for us. Is it possible to come up with some sort of -- value for correlation based on system size or.

some other relationship which will allow us to calculate or determine a cyclic result without having to actually test it? And so that's another one of those questions that remains open right now.

And I'm open to any suggestions or recommendations that people in this room or others might have on ways that we might use that ISO standard and still fulfill the requirements of the law.

So basically that covers the issues. I might say that there is a precedent already for our test procedures in looking for - in that we have gone to the IEC test procedure for testing of heat pump or microwaves . And that in the latest rulemaking we have proposed that and I believe that the we will be moving forward with a final rule to use the international standards. And I think this is the appropriate way to go as the global market becomes more integrated, that we should be looking for, ways to harmonize our standard, especially with NAFTA now where we're

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 189 1 

### to calculate annual operating costs. I am not sure 2 what the answer to that is. That's another thing that 3

-- for us. 4 Is it possible to come up with some sort 5 of

-- value for correlation based on system size or 6 some other relationship which will allow us to 7 calculate or determine a cyclicresult without having 8 to actually test it? And so that's another one of 9 those questions that remains open right now. 10 

### And I'm open to any suggestions or 11 recommendations that people in this room or others 12 might have onways thatwe might use that ISO standard 13 and still fulfill the requirements of the law. 14 So basically that covers the issues. I 

### 15 might say that there is a precedent already for our 16 testprocedures inlooking for

-- inthatwe havegone 17 to the lEe 

### test procedure for testing of heat pump or 18 microwaves. And that inthe latestrulemakingwe have 19 proposed that and I believethat thewe will bemoving 20 forward with a final rule to use the international 21 standards. 22 And I thinkthis isthe appropriatewayto 23 go as the global market becomes more integrated, that 24 we should be looking for- ways to harmonize our 25 standard, especially with NAFTA now where we're

(202)234-4433 

### NEALR. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-44331

3

5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 190

working closely with Canadians and the Mexicans that we should be looking outward toward other countries 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 a non dimensional number that would still allow us to be within the law, that's a question that still remains up in the air. And again, my understanding is that there are a lot of, or have been anyway, a lot of people, manufacturers and others who have used those descriptors to market their products and that they feel that descriptor still is important.

And the question that I would put before this group is, you know, what is the feeling on that, what would happen if we just went to the dimensionless type descriptors like we just mentioned that the SEER or the COP. MR. KELLY: I'd like to add to that, that if you' re considering that you' d also want to consider --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) 234-4433 190 1 working closely with Canadians and the Mexicans that 2 we should be looking outward toward other countries 3 too. 4 MR. KELLY: Ed? 5 MR. POLLOCK: Yes. 6 MR. KELLY: George Kelly. That fourth 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 a 10 nondimensional number thatwould still allowus tobe 11 within the law, that's a question that still remains 12 up in the air. And again, my understanding is that 13 there are a lot of, or have been anyway, a lot of 14 people, manufacturers and others who have used those 15 descriptors to market their products and that they 16 feel that descriptor still is important. 17 And the question that I would put before 18 this group is, you know, what is the feeling on that, 19 whatwouldhappen ifwejustwent tothe dimensionless 20 type descriptors like we justmentioned that the SEER 21 or the COP. 22 MR. KELLY: I'd like to add to that, that 23 ifyou'reconsideringthatyou'dalsowant to consider 24 --in that list. 25 MR. POLLOCK: Well, we went into that.

(202)234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N,W. WASHINGTON•.D.C. 20005 (202)234-44331 2

4 5 6

8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 191

The issue that was addressed, and the reason I'm only addressing ARI here, the air conditioning systems, is because ARI specifically came to us and asked to make this change. As we begin to look at metrification of all our test procedures and standards, certainly this is the type of thing that we would want to evaluate for every one of the products and test procedures --

MODERATOR LANGMEAD: Larry, do you want to take and address this a little bit, and the question I'm going to ask after Larry addresses this, and you can be thinking of the question, we have some of our Canadian friends down here and we've got NAFTA agreements and test procedure issues between Canada in here, and it might be a time for any of the manufacturers of heating, air conditioning and other equipment to address any of their issues they'd like to raise or at least made known to the Canadians here in attendance to work within that community.

MR. WETHJE: Larry Wethje, with ARI. Just a little more background to what Ed has said. What has happened within ARI is our board of directors has issued a mandate , if you want to call it that, to have every product section look at where international standards exist, to adopt those standards and abandon ARI standards, whenever it's feasible, practical, and

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234.4433 191 1 The issue that was addressed, and the reason I'm only 2 addressing ARI here, the air conditioning systems, is 3 because ARI specifically came to us and asked to make 4 this change. As we begin to look at metrification of 5 all our test procedures and standards, certainlythis 6 is the type of thing that we would want to evaluate 7 for everyone of the products and test procedures

-- 8 MODERATOR LANGMEAD: Larry, doyouwantto 9 take and address this a little bit, and the question 10 I'm going to ask after Larry addresses this, and you 11 can be thinking of the question, we have some of our 12 Canadian friends down here and we've got NAFTA 13 agreements andtestprocedureissuesbetweenCanadain 14 here, and it might be a time for any of the 15 manufacturers of heating, air conditioning and other 16 equipment to address any of their issues they'd like 17 to raise or at least made known to the Canadians here 18 in attendance to work within that community. 19 MR. WETHJE: LarryWethje, withARI. Just 20 a little more background to what Ed has said. What 21 has happened within ARI is our board of directors has 22 issued a mandate, if youwant to call it that, to have 23 every product section look at where international 24 standards exist, to adopt those standards and abandon 25 ARI standards, whenever it's feasible, practical, and

(202)2344433 NEALR. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-44331 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 192

if there are no extenuating circumstances that would prohibit us from doing that.

So the unitary section took a look at it and said, yes there are ISO standards that exist for our products, from their perspective they're a little bit more desirable from the standpoint of less burdensome with respect to testing. And so at that point the section voted to ask staff to go discuss the possibility with DOE of adopting the ISO standard in lieu of the current DOE test methods. So we did have

some informal discussions with DOE regarding this.

And in the course of those discussions

some of the issues that Ed brought out were put on the table and rather than formally petition DOE at that point to go that route, what we did was we assigned an engineering task force to take a look at it to see if there was any correlation between SEER and EER as outlined in the ISO test method. The engineering committee has concluded there investigation and determined that indeed there is not a means of correlating those two descriptors. Which significantly complicates the process of going from a DOE SEER descriptor to an ISO EER descriptor.

Basically that's where we are at this point. The engineering committee just concluded its

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 192 1 if there are no extenuating circumstances that would 2 prohibit us from dOing that. 3 So the unitary section took a look at it 

### 4 and said, yes there are ISO standards that exist for 5 our products, from their perspective they're a little 6 bit more desirable from the standpoint of less 

### 7 burdensome with respect to testing. And so at that 8 point the sectionvoted to ask staffto go discuss the 9 possibility with DOE of adopting the ISO standard in 10 lieu of the current DOE test methods. So we did have 11 some informal discussions with DOE regarding this. 12 And in the course of those discussions 13 some of the issues that Ed brought out were put on the 

### 14 table and rather than formally petition DOE at that 15 point to go that route, what we did was we assigned an 16 engineering task force to take a look at it to see if 17 there was any correlation between SEER and EER as 

### 18 outlined in the ISO test method. The engineering 19 committee has concluded there investigation and 20 determined that indeed there is not a means of 21 correlating those two descriptors. Which 22 significantlycomplicates the process of going from a 23 DOE SEER descriptor to an ISO EER descriptor. 24 Basically that's where we are at this 25 pOint. The engineering committee just concluded its

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. NW. WASHINGTON. D.C. 20005 (202)234-44331 2

4 5 6 7

10 11 12 13 -14 15 16 17 18 19 20 21 22 23 24 25 193

work a little while ago and has determined that, you know, they cannot see any easy way of making that correlation. Those results will be passed back to the section in about one month. The section convenes and they will then assess, you know, where to go at this point. MODERATOR LANGMEAD: Any other questions for Larry on that issue?

Frank? MR. STANONIK: Larry, was the U.S. a direct participant in the development of the ISO standard? MR. WETHJE: Yes. But unsuccessful in getting the international bodies to incorporate the cyclic test method into the ISO standard. They tried to, were not even able to get it into an appendix of the standard. And so-it doesn't have it. It simply is steady state method.

MODERATOR LANGMEAD: Yes, Ed? MR. POLLOCK: Ed Pollock, DOE. One of the things that we are considering that may be a compromise to this, again it makes some dependency to what you're trying to determine from the aspect of what it does to the SEER value, and that is that we might be able to use the, as I said, temperate climate

(202) 234.4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 193 1 work a little while ago and has determined that, you 2 know, they cannot see any easy way of making that 3 correlation. Thoseresultswill bepassedback tothe 4 section in about one month. The section convenes and 5 they will then assess, you know, where to go at this 6 point. 7 

### MODERATOR LANGMEAD: Any other questions 8 for Larry on that issue? 9 Frank? 10 

### MR. STANONIK: Larry, was the U.S . a 11 direct participant in the development of the ISO 12 standard? 13 MR. WETHJE: Yes. But unsuccessful in 14 getting the international bodies to incorporate the 15 cyclic test method into the ISO standard. They tried 16 to, were not even able to get it into an appendix of 17 the standard. And so-it doesn't have it. It simply 18 is steady state method. 19 MODERATOR LANGMEAD: Yes, Ed? 20 

### MR. POLLOCK: Ed Pollock, DOE. Oneofthe 21 things that we are considering that may be a 22 compromise to this, again itmakes some dependency to , 

### 23 what you're trying to determine from the aspect of 24 what it does to the SEER value, and that is that we 25 might be able to use the, as I said, temperateclimate

(202)234-4433 

### NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C.20005 (202)234--44332

4 5 6

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 194

conditions for the state test and essentially adopting the ISO state test and then have add on, which we do in some of our other DOE testing for the cyclic test and the defrost test, that type of thing that we need to for heat pumps.

MODERATOR LANGMEAD: Yes? MR. DOUGHERTY: Brian Dougherty, NIST. Frank, the approach that's being taken by myself in concert with working with ARI is to try to make the DOE -- make the ISO test method a subset of the DOE test method as much as possible. And as far as the issue of trying to lessen the burden, people want to do away with the cyclic testing and maybe come up with better defaults. Right now the default value of this cyclic -- coefficient of 0.25. And whether or not that number can. depend on the hardware.

So maybe in the future ARI may consider opening up their database and look at whether or not there is some correlation to -- in the hardware so the default value may be more representative so that more manufacturers may choose the default and then the testing burden becomes essentially almost the same as what is required by ISO.

MR. DEMPSEY: Dan 'Dempsey, United Technologies Carrier. This is more of a gas furnace

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2341433 194 1 conditions for the state testandessentiallyadopting 2 the ISO state test and then have add on, which we do 3 in some of our other DOE testing for the cyclic test 

### 4 and the defrost test, that type of thing that we need 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 in 9 concert with working with ARI is to try to make the 10 DOE

-- make the ISO test method a subset of the DOE 11 test method as much as possible. And as far as the 12 issue of trying to lessen the burden, people want to 13 do awaywith the cyclic testing andmaybe come'up with 14 betterdefaults. Right now thedefault value of this 15 cyclic

-- coefficient of 0.25. And whether or not 

### 16 that number can.depend on the hardware. 17 So maybe in the future ARI may consider 18 opening up their database and look at whether or not 19 there is some correlationto

-- in the hardware so the 20 default value may be more representative so that more 21 manufacturers may choose the default and then the 22 testingburden becomes essentially almost the same as 

### 23 what is required by ISO. 24 MR. DEMPSEY: Dan 'Dempsey, United 25 Technologies Carrier. This is more of a gas furnace

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C. 20005 (202)234-44331

6

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 195

comment. I'm not that familiar with ISO standards for the -- heating product, but if you can come up with a steady state and different design specific defaults for a gas furnace, it would significantly reduce the test burden. MODERATOR LANGMEAD: Dan, where the Europeans have standards for gas appliances, they are based on steady state, and sometimes they different between atmospheric level, the standard level varies between a power burner type unit and an atmospheric unit, but they are based on steady state.

And default values, it opens up a whole

area to look at, if it's --

MR. DEMPSEY: There are proposed changes to the test procedures that would affect AFUE by half a percent or less, but would significantly increase the test burden over and above what it is 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 more work to do on default factors and possibly going beyond air conditioning and heat pumps to look at.

At the same time we are progressing with a series ' of minimum efficiency standards through

(202) 234-4433 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 195 1 comment. I'mnot that familiarwith ISO standards for 2 the

-- heating product, but if you can come up with a 3 steady state and different design specific defaults 4 for a gas furnace, it would significantly reduce the 5 test burden. 6 

### MODERATOR LANGMEAD: Dan, where the 7 Europeans have standards for gas appliances, they are 8 based on steady state, and sometimes they different 9 between atmospheric level, the standard level varies 10 between a power burner type unit and an atmospheric 11 unit, but they are based on steady state. 12 And default values, it opens up a whole 13 area to look at, if it's 14 

### MR. DEMPSEY: There are proposed changes 15 to the test procedures that would affect AFUE by a 

### 16 half a percent or less, but would significantly 17 increase the test burden over and above what it is 18 today, which is a whole separate

-- 19 MODERATORLANGMEAD: Butanimportantone. 20 I saw another hand over here somewhere. 21 Well, it looks like we've got some more 22 work to do on default factors and possibly going 23 beyond air conditioning and heat pumps to look at. 24 At the same time we are progressing with 25 a series of minimum efficiency standards through

(202)234-4433 NEALR. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODEISLANDAVENUE. N.w. WASHINGTON. D.C.20005 (202)234-44331 2 3 4 5 6 7

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 196

Canada, and the test procedures are very slightly, and the test burden or the resting issue is there that what is good one place isn't good in others, and they have to redo it.

How many Canadian officials do we have here? DOUG CANE: Doug Cane,'Canadian Research. I'm the chairman of one of the air conditioning and heat pump standards at CSA. I think what you've just said is true. In fact I was going to say what was Larry -- attitude towards simplifying descriptors in 1988 when Canada proposed a far simpler methodology than you're currently using. We've harmonized. Where does that leave us now, if you're adopting ISO standards? -

MODERATOR LANGMEAD: Well, I know there are all sorts of things going on, not just in air conditioning but in furnaces and in water heaters.

MR. CANE: We've harmonized as far as I know. MODERATOR LANGMEAD: Charlie?

MR. ADAMS: Charlie Adams, Ducane. I sit on the Z21.40.7 CAN 2.3 central furnace harmonize committee to write the safety standard for warm air furnaces in the U.S. and Canada. We're sort of

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON. D.C. 20005 (202) 234-4433 196 

### 1 Canada, and thetestprocedures arevery slightly, and 2 the test burden or the resting issue is there that 3 what is good one place isn't good in others, and they 4 have to redo it. 5 How many Canadian officials do we have 6 here? 7 

### DOUG CANE: Doug Cane,·CanadianResearch. 8 I'm the chairman of one of the air conditioning and 9 heat pump standards at CSA. I think what you'vejust 10 said is true. In fact I was going to say what was 11 Larry

-- attitude towards simplifying descriptors in 12 1988 when Canada proposed a far simpler methodology 13 thanyou'recurrentlyusing. We'veharmonized. Where 14 does that leave us now, if you're adopting ISO 15 standards? 16 

### MODERATOR LANGMEAD: Well, I know there 17 are all sorts of things going on, not just in air 18 conditioning but in furnaces and in water heaters. 19 MR. CANE: We've harmonized as far as I 20 know. 21 MODERATOR LANGMEAD: Charlie? 22 MR. ADAMS: Charlie Adams, Ducane. I sit 23 on the Z21.40.7 CAN 2.3 central furnace harmonize 24 committee to write the safety standard for warm air 25 furnaces in the U . S . and Canada.

(202)234-4433 

### NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 

### We're sort of

(202)234-44333 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 197

harmonized at least in the document -- and the outdoor cooking document, and I sat on that subcommittee also. We're sort of harmonized, but we're not quite there yet because there is still the, under present Exhibit M for those of you that are familiar with Z21.40.7 CAN 2.3, that's an appendix that is set up specifically for issues that are unique to one country.

I would encourage that we have agreed to agree on the harmonization effort, and I'd like to see us actually follow through and finish agreeing on everything so we don't duplicate the test burden not only on efficiency tests, but there are other, some other number of tests that are included in Exhibit M that we, the manufacturers, are required to run for one country that we're not required to run for the other. So the intent of harmony is there, but we're not really a hundred percent harmonized, at least in the warm air furnace end of this industry. And it's a hell of a good idea, so we need to figure 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 Gas

(202) 2344433 NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 2344433 

### 197 1 harmonized at least inthedocument

-- and theoutdoor 2 cookingdocument, and I satonthat subcommittee also. 3 We're sort of harmonized, but we're not quite there 4 yet because there is still the, under present Exhibit 5 Mfor those ofyou that are familiar with Z2l.40.7 CAN 6 2.3, that's an appendix that is set up specifically 7 for issues that are unique to one country. 8 I would encourage that we have agreed to 9 agreeontheharmonizationeffort, and I'd liketo see 10 us actually follow through and finish agreeing on 11 everything so we don't duplicate the test burden not 12 only on efficiency tests, but there are other, some 13 other number of tests that are included in Exhibit M 14 that we, the manufacturers, are required to run for 15 one country that we're not required to run for the 16 other. 17 So the intent of harmony is there, but 18 we're not really a hundred percent harmonized, at 19 least in the warm air furnace end of this industry. 20 And it's a hell of a good idea, so we need to figure 21 out to get there from here. 22 23 24 25 Canada.

(202)234-4433 

### MODERATOR LANGMEAD: Any other comments? Yes? MR. CLARK: JimClark, Natural Resources, We have a work plan with Canadian Gas 

### NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-4433198 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 also

an AGA owned affiliate. And I think we have eight products that we're going through the harmonization process with, with I guess target dates for eventual harmonization ranging from sometime in '96 to sometime in '97, and deals with the test procedure. Also in terms of certification, under our regulations we will accept products for sale in Canada that are certified by an agency that's recognized by the Standards Council of Canada. And there are a number of those such as ETL, UL. UL I believe will soon become accredited. NIS as well. So there may be some areas where there is a duplicate testing required, but we're working to eliminate those in most cases.

Having said that, we still maintain some prerogative even under NAFTA for different standards, if there is an environmental benefit for having those.

MODERATOR LANGMEAD: I just might want to point out one difference that I'm aware of -- well, in

some cases the efficiency test method is identical in this country. In the United States the manufacturer makes a declaration to DOE and FTC that they've tested the product. It gets listed, the product is in the marketplace, and it gets accepted by the Trade 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) 234-4433 

### 198 1 Associationthrough their lES affiliate which is also 2 an AGA owned affiliate. And I think we have eight 3 products that we're going through the harmonization 4 process with, with I guess target dates for eventual 5 harmonizationranging from sometimein '96 to sometime 6 in '97, and deals with the test procedure. Also in 7 terms of certification, under our regulations we will 8 acceptproducts for sale inCanada that are certified 9 by an agency that's recognized by the Standards 10 Council of Canada. And there are a number of those 11 such as ETL, UL. UL I believe will soon become 12 accredited. NlS as well. So there may be some areas 13 wherethere is a duplicatetestingrequired, butwe're 14 working to eliminate those in most cases. 15 Having said that, we still maintain some 16 prerogativeevenunder NAFTA for different standards, 17 ifthereisanenvironmentalbenefit forhavingthose. 18 MODERATOR LANGMEAD: I justmight want to 19 pointoutonedifference that I'm aware of

-- well, in 20 some cases the efficiency testmethod is identical in 21 this country. In the United States the manufacturer 22 makes a declarationtoDOE and'FTC thatthey've tested 23 the product. It gets listed, the product is in the 24 marketplace, and it gets accepted by the Trade 25 Association follow-up verification programs.

(202)234-4433 NEAL

### A. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44331

3 4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 199 In Canada the regulations are such that before the product gets introduced in the marketplace it has to be tested by an organization recognized by Canada which put the testing up at a different point and puts the testing up. What it does is create a situation that you have a great deal of difficulty determining that you have a 95 percent confidence that your rating value is within plus or minus five percent of the true mean which is a DOE regulation before you've got into production.

So there are some details that I would' hope we could continue to work on administratively primarily to straighten out that administrative burden. Does anybody else want to comment on that?

I guess I've said it all. I'm retired, so I don't have to deal with that anymore, but it's an ongoing issue.

Other comments? I guess with that we're ready to close up shop. If there are any final comments on any subject, if we want to get into the energy factor discussion again, we can. If not, hopefully not.

Carl, would you like to give some closing remarks and indicate that if there is anything that

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 

### 199 1 In Canada the regulations are such that 2 before the product gets introduced in themarketplace 3 it has to be tested by an organization recognized by 4 Canada which put the testing up at a different pOint 5 

### and puts the testing up. What it does is create a 6 situation that you have a great deal of difficulty 7 determiningthatyouhave a 95 percentconfidence that 8 yourratingvalueiswithinplusorminus five percent 9 of the true mean which is a DOE regulation before 

## 10 you've got into production. 11 So there are some details that I would 12 hope we could continue to work on**adm~nistratively** 

### 13 primarily to straighten out that administrative 14 burden. 15 Does anybodyelsewanttocommentonthat? 16 I guess I've saiditall. I'mretired, so 17 I don't have to deal with that anymore, but it's an 18 ongoing issue. 19 Other comments? 20 I guess with that we're ready to close up 21 shop. Ifthere are any final comments on any subject, 22 if we want to get into the energy factor discussion 23 again, we can. If not, hopefully not. 24 Carl, would you like to give some closing 25 remarks and indicate that if there is anything that

(202)234-4433 NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-44331 2 3 4

6

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 200

you want to bring to the attention of DOE particularly, that you don't want to mention at this meeting, feel free to write DOE.

MR. ADAMS: Well, as everybody can probably agree, none of these are simple issues. I keep waiting in the regulatory area for the first simple issue to come along. 'I have not found it yet. Everything always seems to be complicated.

But I would like to thank everybody for their participation. We've gotten a lot of 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 this information in developing our research agenda which will largely be reflected in the statement of work in our contract with NIST for 1996, which we will be formulating before the end fo the year.

So I would like to say, if anybody has any supplemental information that they would like to provide to supplement comments or discussions that were here today, if they want to send them in to DOE, they would be considered. If you would send them to the attention to Kathy Epping, who sent out the letters of invitation which I think most of you got. Or that address can be provided at the desk, if you

(202) 2344433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON

. D.C. 20005 (202) 234-4433 

### 200 1 you want to bring to the attention of DOE 2 particularly, that you don't want to mention at this 3 

### meeting, feel free to write DOE. 4 MR. 

### ADAMS: Well, as everybody can 5 

### probably agree, none of these are simple issues. I 6 

### keep waiting in the regulatory area for the first 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 for 10 their participation. We've gotten a lot of 11 information here. Some of it we've heard before. 12 Some of it I think are somenew slants on some issues. 13 And we will be considering this 14 information in developing our research agenda which 15 will largely be reflected in the statement of work in 16 our contract with NIST for 1996, which we will be 17 formulating before the end fo the year. 18 So I would liketo say, if anybodyhas any 19 supplemental information that they would like to 20 provide to supplement comments or discussions that 21 were here today, if they want to send them in to DOE, 22 they would be considered. If you would send them to 23 the attention to Kathy Epping, who sent out the 24 letters of invitation which I think most of you got. 25 Or that address can be provided at the desk, if you

(202)2344433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, N.W. WASHINGTON, D.C.20005 (202)234-44331

3 4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 201

don't have it. It will probably be most helpful to get any additional information by the end of the month so that we can continue on with our statement of work.

I also want to say that the representative from the Federal Trade Commission I believe also found today' s discussion very interesting, and has been inquiring about could he borrow the transcript from

us. Yes?

MR. RANFONE: Jim Ranfone, AGA. Just a comment. First, we appreciated the opportunity to have this kind of workshop. Secondly, we're not sure who was invited to it, what kind of response you had to all interested parties. There seemed to be a number of groups that we're sort of speaking for like consumers that aren't here, and environmentalists -- time frame that they couldn't meet. I'm not really comfortable with the way the process evolved in terms of making the announcement. I think this is a very important subject for our country and for our industry, and perhaps you have more information -- response you've gotten. And I'll leave it at that.

MR. ADAMS: There were people invited who could not show up. I can't tell you what their 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) 234-4433 201 1 don't have it. It will probably be most helpful to 2 get any additional informationby theendof themonth 3 so thatwe cancontinueonwithour statement ofwork. 4 I alsowant to saythattherepresentative 5 from the FederalTradeCommission I believealso found 6 today's discussion very interesting, and has been 7 inquiring about could he borrow the transcript from 8 us. 9 Yes? 10 MR. RANFONE: Jim Ranfone, AGA. Just a 11 comment. First, we appreciated the opportunity to 12 have this kind of workshop. Secondly, we're not sure 13 who was invited to it, what kind of response you had 

### 14 to all interested parties. There seemed to be a 15 number of groups that we're sort of speaking for like 16 consumers that aren't here, and environmentalists

-- 17 time frame that they couldn't meet. I'm not really 18 comfortable with the way the process evolved in terms 19 of making the announcement. I think this is a very 20 important subject for our country and for our 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 invitedwho 24 could not show up. I can't tell you what their 25 schedule was or what those reasons were.

(202)234-4433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-44331 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 202 Again, this is not a public hearing. It's a workshop and it was open to the public. We don't have any wonderful mechanism for announcing these sorts of things. We did not publish this obviously in the Federal Register. People were aware of it. As I say, some of whom could not be here for whatever

reason. But what we are using this information for is to develope an agenda of items that we want to look at. And as we look at these items, be they changes to test procedures or energy descriptors or what have you, we would be going trough a public process, rulemaking process in order to do that.

MR. HOSLER: Daryl Hosler, The Southern California Gas Company. I think you just hit on the point. I appreciate the opportunity to participate in this and look at the information. I also appreciate all the efforts the DOE has put into this. But I find that, you know, you're telling me you're putting some -- to what was brought out here, but the process of letting the industry know that this was going on was completely unsatisfactory. And I think that DOE should recognize that all of these issues are 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) 234-4433 202 1 Again, this isnot a publichearing. It's 2 a workshop and it was open to the public. We don't 3 have any wonderful mechanism for announcing these 4 sorts of things. We did not publishthis obviously in 5 the Federal Register. People were aware of it. As I 6 say, some of whom could not be here for whatever 

### 7 reason. 8 Butwhatwe areusingthis informationfor 9 is to develope an agenda of items that we want to look 10 at. And as we look at these items, be they changes to 11 test procedures or energy descriptors or what have 12 you, we would be going trough a public process, a 13 rulemaking process in order to do that. 

### 14 MR. HOSLER: Daryl**Hos~er,** The Southern 15 California Gas Company. I think you**ju~t** hit on the 16 paint. I appreciatetheopportunitytoparticipatein 

### 17 this and look at the information. 

### I also appreciate 18 all the efforts the DOE has put into this. But I find 19 that, you know, you're telling me you're putting some 20

-- to what was brought out here, but the process of 21 letting the industry know that this was going on was 22 completely unsatisfactory. And I think that DOE 23 should recognize that all of these issues are 24 important to everybody. 25 And

(202)234-4433 if you're trying NEAL

### R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 to gather

(202)234-44331

6

9 10 11 12 13 .14 15 16 17 18 19 20 21 22 23 24 25 203

information, whether it's a workshop or a formal public hearing or something, you bear some responsibility to let people know that these things are going on so that you do get the salient information that you're looking for.

The way this process came about, and the way people got invited to this, I'm not sure that you know everything that you ought to know.

MR. ADAMS: Point well taken. Okay, well with that I will adjourn the workshop. Again, thank you for your participation.

(Whereupon, at 3:10 p.m., the proceedings 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) 234.4433 203 1 information, whether it's a workshop or a formal 2 public hearing or something, you bear some 3**responsibil~ty** to let people know that these things 4 are going on so that you do get the salient 5 information that you're looking for. 6 The way this process came about, and the 7 way people got invited to this, I'm not sure that you 8 know everything that you ought to know. 9 MR. ADAMS: Point well taken. 10 Okay, well with that I will adjourn the 11 workshop. Again, thank you for your participation. 12 (Whereupon, at 3:10 p.m., theproceedings 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 REPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE, NW. WASHINGTON, D.C. 20005 (202)234-4433204 CERTIFICATE

This is to certify that the foregoing transcript in 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 the aforementioned matter, as reported and reduced to typewriting.

MIKE RUDOFF

(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. WASHINGTON, D.C. 20005 (202) 234-4433 II !

204 CERTIFICATE

This is to certify that the foregoing transcript in 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 the aforementioned matter, as reported and reduced to typewriting.

(202)234-4433 MIKE RUDOFF

NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVENUE. N.W. WASHINGTON. D.C. 20005 (202)234-4433