Date: March 18, 2015

Case: The Portable Air Conditioners Standards Meeting

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 U.S. DEPARTMENT OF ENERGY PUBLIC MEETING 

THE PORTABLE AIR CONDITIONERS STANDARDS MEETING 

 U.S. Department of Energy 

 1000 Independence Avenue, SW 

 Washington, DC 20585 

 Room No. 8E-089 

 Wednesday, March 18, 2015 

 11:54 p.m. 
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1 Appearances for Department of Energy Meeting: 

2

3 Doug Brookman, Public Solutions, -- Moderator 

4 Bryan Berringer, DOE 

5 Sarah Butler, DOE 

6 John Cymbalsky, DOE 

7 Ashley Armstrong, DOE 

8 Steve Goering, DOE 

9 Alberto Aloisi, DeLonghi Appliances 

10 Stefano Vit, DeLonghi Appliances 

11 Michael Prager, DeLonghi America, Inc. 

12 Martin L. Besant, Electrolux Major Appliances North 

13 America 

14 Nicole Buccitelli, Navigant 

15 Judith Reich, Navigant 

16 Nadav Singerman, Navigant 

17 Troy Watson, Navigant 

18 Jim Crawford, HVAC Regulatory Consultant 

19 Camilla Dunham, Lawrence Berkeley National Laboratory 

20 Chun Chun Ni, Lawrence Berkeley National Laboratory 

21 Jennifer Cleary, AHAM 

22
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1 APPEARANCES (CONTINUED): 

2

3 Melissa Fiffer, US EPA 

4 John A. Hodges, Wiley Rein LLP 

5 Sang Lee, DENSO Products and Services Americas, Inc. 

6 Joanna Mauer, ASAP, Appliance Standards Awareness 

7 Project 

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1 AFTERNOON SESSION 

2 11:54 A.M. 

3 MR. BROOKMAN: Okay so let's resume then. 

4 Good afternoon everyone. This is the public meeting 

5 on portable air conditioners. The Energy 

6 Conservation Standards portion of the meeting -- we 

7 this morning did a meeting on the test procedures. 

8 Hopefully anybody who is here to participate in the 

9 meeting on the Conservation Standards has joined us 

10 by now. 

11 Today is March 18, 2015 here in the 

12 Forrestal Building in Washington, D.C. My name is 

13 Doug Brookman, Public Solutions, Baltimore. So glad 

14 you could join us this afternoon. We are going to 

15 start with welcoming remarks from Bryan Berringer. 

16 MR. BERRINGER: Yes good afternoon this is 

17 Bryan Berringer from the Department of Energy. I am 

18 currently filling in for Ron Majette, Project 

19 Manager. He'll be here momentarily but we are going 

20 to start with the standard rulemaking now. We are 

21 going to talk today about the preliminary analysis 

22 that was presented and discuss that in further detail 
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1 today and just welcome everybody and thank everybody 

2 for their participation. I look forward to a lively 

3 discussion. 

4 So at this point I will open it up for the 

5 opening remarks from any companies, one, -- 

6 MR. BROOKMAN: Stefano? 

7 MR. VIT: I am Stefano Vit, Regulatory 

8 Affairs and Standardization at De'Longhi Appliances. 

9 And De'Longhi would support a reasonable DOE standard 

10 for portable air conditioners. We have comments on 

11 two specific points of the preliminary technical 

12 support document. 

13 First, we believe that EF efficiency 

14 factor level 3 is not available in commercial 

15 products offered on the market or in working 

16 prototypes. As such this should not be considered at 

17 all in the study. As specified in the basic factors 

18 in Chapter 4, Screening Analysis of the TSD, if it is 

19 determined that a technology has not been 

20 incorporated in commercial products or in working 

21 prototypes, then that technology will not be 

22 considered further. 
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1 We further stress in this regard that DOE 

2 did not observe this air flow configuration for any 

3 products in its test sample. It only included this 

4 configuration in its analysis because it tentatively 

5 concludes it is technically feasible and results in a 

6 significant increase in efficiency. Even this weak 

7 statement is unwarranted in light of that lack of 

8 availability in commercial products or working 

9 prototypes. 

10 Second, as discussed this morning in 

11 relation to test procedures, there are serious 

12 implications to the use of an unwarranted 

13 infiltration air temperature. Such a temperature 

14 would affect the ability to achieve efficiency 

15 improvements. This would undermine a key requirement 

16 for a standard that substantial improvement in energy 

17 efficiency is technologically feasible. 

18 It also gives a false impression of the 

19 performance of single-duct portable air conditioner, 

20 which have been meeting the needs of satisfied 

21 customers for over the last 25 years. 

22 MR. BROOKMAN: Okay thank you Stefano. 
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1 Additional opening remarks, comments or anything else 

2 to say? Nothing additional, okay then let's proceed 

3 with the content in your packet and in this packet 

4 here will be I believe we are on slide 77. 

5 MR. BERRINGER: What we are looking at 

6 here is just the overall agenda that we are going to 

7 be looking for standards today and the first topic 

8 that I am going to address is the regulatory history, 

9 test procedure and overview. Okay as far as the 

10 regulatory history the Energy Policy Conservation Act 

11 of 1975, or EPCA, talks about the different 

12 standards there and again we talk about coverage of 

13 -- establishing coverage for standards for products 

14 and in this case again we are looking at specific 

15 covered products, commercial products continued to 

16 produce and classify additional products as covered 

17 under EPCA. So again, as far as classification, it is 

18 necessary to fulfill the purpose of EPCA taking the 

19 average annual household energy use is likely to 

20 exceed 100 kilowatts per year. 

21 And so we -- the first step was the notice 

22 of determination that was published on July 5th of 
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1 2013. DOE tentatively determined the classification 

2 provisions and we know currently there are no federal 

3 test procedures or standards for portable ACs at this 

4 time. 

5 So the definition of coverage on February 

6 25th, test procedure notice of public rulemaking 

7 proposed the following definition for portable air 

8 conditioners, which is a consumer product, other than 

9 a packaged terminal air conditioner, room air 

10 conditioner and dehumidifier designed as a portable 

11 unit for delivering cool, conditioned air to an 

12 enclosed space that is powered by single phase 

13 electric current which may rest on the floor or other 

14 elevated surface. 

15 It includes a source of refrigerant. It may 

16 include additional means of air circulation. So if 

17 you are just looking at the timeline for standards, 

18 here again the NOPR was published on -- the Notice of 

19 Determination was published on July 5, 2013. The 

20 Preliminary Analysis was published on February 27th 

21 of 2015 and today we are having the Preliminary 

22 Analysis meeting, March 18th. Comment period for 
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1 this ends on April 28, 2015. 

2 We are projecting that a Notice of 

3 Proposed Rulemaking for Standards in this case would 

4 be at the end of the year, at December 31, 2015, and 

5 also projecting a final rule to be August 1st of 

6 2016. Are there any comments on the questions? 

7 MR. BROOKMAN: Jennifer Cleary? 

8 MS. CLEARY: I'm Jennifer Cleary of AHAM. 

9 So I think from the test procedure meeting my 

10 understanding is that the final test procedure would 

11 be published also projected around December 31, 2015. 

12 Is that correct? 

13 MR. BERRINGER: That is correct. 

14 MS. CLEARY: Okay so I think that's 

15 helpful for DOE because you presumably will know what 

16 your final test procedure is. Well let me ask -- go 

17 back and ask a question. As you are developing the 

18 proposed rule on standards, I assume that between the 

19 time that we submit comments on the test procedure 

20 and you develop the proposed rule for standards, you 

21 will also be internally deciding on the final test 

22 procedure. Is that correct? 
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1 MS. ARMSTRONG: Correct. 

2 MR. BROOKMAN: Thank you Ashley, now back 

3 to Jennifer. 

4 MS. CLEARY: And so actually then, you will 

5 be using what will be the final test procedure to 

6 develop the NOPR on standards. Is that correct? 

7 MS. ARMSTRONG: Correct. 

8 MR. BROOKMAN: Thank you Ashley. 

9 MS. CLEARY: But, this is Jennifer, we will 

10 as commenters not know before the NOPR on standards 

11 what the final test procedure will be, correct? 

12 MS. ARMSTRONG: So the plan is to publish 

13 -- the plan is to publish the final rule for the test 

14 procedure in advance of the NOPR publication, so the 

15 hope is that you will know. At least have the tools 

16 available to. Obviously that depends on the magnitude 

17 of the comments that we get and the decisions that we 

18 need to make in response to those comments, but 

19 that's all we could hope that you would have a test 

20 procedure in advance of the NOPR for standards, okay. 

21 MS. CLEARY: This is Jennifer. We 

22 appreciate that. I think there are a lot of serious 
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1 concerns we have with not having the test procedure 

2 well in advance, you know not like a month in advance 

3 or even six months in advance of the NOPR because -- 

4 on standards, and it really stems from our desire to 

5 help the Department. So you know, leading up to this 

6 preliminary analysis for example, AHAM was asked to 

7 provide data and we tried really, really hard for 

8 months and months as Judy knows, many conversations 

9 that we had. 

10 We could not provide data and the reason 

11 for that was because we didn't have the test 

12 procedure. Manufacturers are not testing to 

13 what's being proposed necessarily right now, and so in 

14 order for them to be able to provide AHAM with data 

15 and then AHAM to provide the Department with data, 

16 they need to have time to do the testing and that's, 

17 you know, particularly for a new product like this as 

18 opposed to many of our other products that are and 

19 have been covered by the present rule on time where 

20 manufacturers have some kind of basic understanding 

21 about how their product may be tested and how this 

22 procedure amendment might affect that. 
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1 In this case you know we were trying to, 

2 say, figure out could there be a conversion factor 

3 between certain test procedures, and there isn't one. 

4 So manufacturers, in order to really be helpful to the 

5 Department, could need to test their entire product 

6 line, and that takes time and we need that time to do 

7 that in order to make a proposed rule on standards at 

8 all meaningful. 

9 So our concern is that if we do not have 

10 that, the Department does not issue a test procedure 

11 well in advance so that we can do that testing and 

12 manufacturers could provide that information to 

13 Navigant during the manufacturer interviews, that 

14 whatever NOPR is published will suffer from serious 

15 flaws due to the lack of data. 

16 We don't want to see that happen. We want 

17 to work with the Department and we can only do so if 

18 you give us the tools to do that so we would request 

19 that we have the final rule for the test procedure. 

20 MR. BROOKMAN: Okay thank you. So Bryan 

21 was just laying out the timeline which is on slide 79 

22 and do we have additional comments, questions related 
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1 to the timeline that's listed here? Okay so I guess 

2 we are going to move on then to the market technology 

3 assessment screening. 

4 MR. BERRINGER: And just for the record 

5 Ron Majette is now here, the project manager, if you 

6 want to introduce yourself. 

7 MR. MAJETTE: Ron Majette, the U.S. 

8 Department of Energy. I was tied up in another 

9 meeting, so since we have this meeting started a 

10 little early I was a little bit behind, but welcome 

11 everybody. I'm glad to see everybody made it out, 

12 thank you. 

13 MR. BROOKMAN: Thank you Ron. 

14 MR. BERRINGER: And at this time I would 

15 like to introduce Judy Reich from Navigant Consulting 

16 to talk about the market technology assessment and 

17 screening. 

18 MS. REICH: Hello everyone. Judith 

19 Reich, and I will be leading off the discussion of the 

20 analyses that DOE is conducting as part of this 

21 rulemaking. As you know we are at the preliminary 

22 analysis stage to consider potential energy 
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1 conservation standards for portable air conditioners 

2 in the event that DOE makes the final determination 

3 that portable air conditioners are covered products. 

4 So I'm going to focus on the first three 

5 elements shown in this flow chart, starting with the 

6 market and technology assessment and moving through 

7 the engineering analysis. The market and technology 

8 assessment pretty much lays the ground work for 

9 subsequent analyses by setting the structure for how 

10 to consider the products that are the subject of the 

11 rulemaking, giving a portrait of the industry and 

12 regulatory landscape, and then identifying all of the 

13 technologies and technological developments that are 

14 available for improving efficiency. 

15 So on that first bullet point, defining 

16 product classes, DOE generally considers a number of 

17 factors when deciding to divide products up into 

18 different classes for analysis, and factors that it 

19 considers are typically the type of energy used, the 

20 capacity or other performance-related features, and in 

21 this case DOE identified two different potential 

22 factors that could be used for separation of portable 
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1 air conditioners into different product classes, and 

2 that would be the duct configuration and cooling 

3 capacity. 

4 In terms of duct configuration, as we 

5 discussed in the test procedure discussion, we looked 

6 at, or DOE looked at, two different duct 

7 configurations, single-duct and dual-duct and is not 

8 considering at this time a class for spot coolers. 

9 But in terms of the single-duct and 

10 dual-duct units, there was no consumer utility that 

11 DOE could identify associated with one versus the 

12 other. Through its research, evaluation of product 

13 literature, evaluation of products themselves, direct 

14 teardowns, discussions with manufacturers, it was found 

15 that there were no installation locations that 

16 couldn't accommodate either a single-duct or 

17 dual-duct unit. 

18 Also, there was no information to suggest 

19 that there was a correlation between available noise 

20 performance data and duct configuration, so again 

21 there was no particular consumer utility that DOE is 

22 aware of at this time that would warrant separating 
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1 single, or separating portable air conditioners into 

2 product classes on the basis of being either 

3 single-duct or dual-duct. 

4 However, it's pretty clear from data that, 

5 both DOE's data and data that manufacturers make 

6 available, that portable air conditioner efficiencies 

7 are a function of the cooling capacity of the 

8 product. In that higher capacity units, typically, are 

9 achieving higher efficiencies, and in particular when 

10 I talk about it in today's discussion, it's going to 

11 be referring to efficiencies in cooling capacity as 

12 measured under the proposed test procedure. 

13 DOE also observed that this relationship 

14 between the two parameters is consistent across a 

15 wide range of measured capacities and so for that 

16 reason, DOE is not proposing separate product classes 

17 on the basis of cooling capacity, but is considering 

18 the possibility of standards based on an equation 

19 that relates energy efficiency to capacity when 

20 developing its various energy efficiency levels. 

21 MR. BROOKMAN: Jennifer Cleary? 

22 MS. CLEARY: Jennifer Cleary with AHAM. 
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1 We will have comments on this. We don't have any today 

2 for the immediate perspective but we certainly will 

3 provide some. 

4 MR. BROOKMAN: Thank you. Joanna Mauer. 

5 MS. MAUER: We support the single product 

6 class preferably and we agree with DOE's 

7 preliminary determination that there is no distinct 

8 consumer utility -- I'm just going to wait until -- 

9 MR. BROOKMAN: Thanks for doing that yes. 

10 MS. MAUER: This is Joanna again. The 

11 second part of the request for comment is the 

12 determination that the efficiency is a function of 

13 product capacity, so clearly the DOE testing to the 

14 proposed test procedure shows correlation between 

15 cooling capacity and efficiency. I guess I'm having 

16 trouble with going to the next step and saying that 

17 efficiency is a function of capacity, since the two 

18 are kind of so closely tied together and the DOE 

19 analysis is based on reducing air infiltration, 

20 which has the impact of both increasing, you are 

21 increasing cooling capacity as a way essentially to 

22 increase efficiency. 
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1 You know and I think, in general, like for a 

2 room AC unit, we talk about capacity, I think we are 

3 talking about higher capacity and you don't want to 

4 have a higher capacity compressor, larger heat 

5 exchangers, the other things, whereas here it seems 

6 like capacity is really related to how much air 

7 infiltration you have. 

8 And also a room AC, the standards aren't 

9 very different for different capacity ranges and 

10 actually they are slightly higher for smaller 

11 capacity units. So I am trying to understand why we 

12 have such a different relationship here where 

13 efficiency would require -- required efficiency would 

14 increase with capacity. 

15 MS. REICH: So there are a number of 

16 questions that maybe she really had, and I'll see if I 

17 can step through them and some of them may be best 

18 explained when we get to the later discussion of the 

19 engineering analysis. You are correct that larger 

20 capacity units have different heat exchangers and 

21 different components, but that is a separate issue 

22 from the reduction of the infiltration air that you 
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1 can achieve the higher efficiency levels for a given 

2 starting configuration in different capacity. You can 

3 still incrementally improve it and not just by moving 

4 up a curve in capacity in the same relationship 

5 between EER and capacity. 

6 It actually shifts the curve upwards so it 

7 is a step change in efficiency. So let me see, I 

8 think DOE tested a wide range of products that are on 

9 the market, and I think what you will see from that 

10 starting curve is that there was a single unique 

11 relationship at a baseline configuration that relates 

12 capacity to energy efficiency. You are right that 

13 they are interrelated because the EER metric has 

14 capacity in it, but at the baseline there is that 

15 single, that very well defined curve that you saw in 

16 the test procedures discussion. So again, we can talk 

17 about some of these issues further when we get to the 

18 engineering analysis. 

19 MR. BROOKMAN: Additional questions or 

20 comments before we proceed? 

21 MS. REICH: Okay just before I go on, I 

22 just want to mention that if anybody has or is 
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1 looking for further information on the market and 

2 tech assessment, that's chapter three of the 

3 technical support document. 

4 So in terms of the industry landscape, DOE 

5 estimates that the majority of portable ACs are 

6 manufactured overseas. There are three major OEM's 

7 but these products that are sold in the U.S. 

8 under a large number of brands. DOE identified 

9 approximately 29 of them, and the list below shows 

10 very approximate market shares of manufacturers that 

11 are selling products in the U.S. 

12 DOE also looks at the availability of 

13 products currently on the market and characterizes 

14 distributions of efficiencies. I want to emphasize 

15 that these data are taken from the California Energy 

16 Commission's appliance database, and this requires the 

17 use of what is now an obsolete ASHRAE standard, 

18 ASHRAE Standard 128-2001, so that this is -- this data 

19 is really for comparative purposes because the new 

20 ASHRAE test standard and the proposed DOE test 

21 procedure would produce different EER values. 

22 But you can see the range of products in 
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1 terms of cooling capacity and also sorted into 

2 standards to show the general distribution in 

3 capacity. Everybody is I'm sure very familiar with 

4 the products -- 

5 MR. BROOKMAN: Let's hear from Jennifer, 

6 Jennifer Cleary? 

7 MS. CLEARY: Just on your last slide, I 

8 just wanted to point out that this is a really good 

9 example of the type of data AHAM would like to be 

10 able to provide because the reality is that the test 

11 procedures aren't final and at the time wasn't even 

12 proposed. We tried very hard to collect this, but 

13 because we didn't have a good understanding of, for 

14 example, all the products and how the test procedure 

15 would apply, so we would like to be able to do that in 

16 the future. 

17 MR. CYMBALSKY: This is John from DOE. Was 

18 there any testing done in support of the development 

19 of an AHAM PAC-1? 

20 MS. CLEARY: I will look into that. I 

21 think the problem is was that done on units that 

22 exist today, for example. So we will look into it. And 
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1 we did investigate trying to do testing on the units 

2 that represent the most shipments for some companies, 

3 and we can look into that again. The problem we had 

4 was the ability to get that from enough manufacturers, 

5 and we weren't able to present it in the aggregate. So 

6 DOE had better luck getting some of that data 

7 from individual companies, but did it represent the 

8 full market? 

9 So I think as we continue to have a better 

10 understanding of where the test procedure will go, 

11 there will be a willingness for companies to develop 

12 that testing across their products, because their 

13 certainty with the test procedure will be instead of 

14 a sense of a certain futility in work. So as things 

15 progress hopefully we will be able to do more, but 

16 until we know what that test procedure is, I think 

17 there's some challenges to that because of course 

18 companies have a lot more than just this going on and 

19 it requires the use of their lab, and so to get into 

20 the lab you really need to -- companies need to know 

21 that doing that testing is going to have value. 

22 MS. REICH: All right, just a quick 
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1 schematic here to make sure we are all on the same 

2 page of what a portable air conditioner looks like. 

3 It's basically a product that contains a 

4 refrigeration system for the purpose of removing the 

5 sensible and latent heat from your conditioned space. 

6 You know all the components you would 

7 expect to be associated with that, compressor, heat 

8 exchangers, blowers, one or two ducts on the condenser 

9 side and then some of which we talked a little bit 

10 about before in terms of the auto evaporation 

11 feature, there are means for removing condensate. 

12 In most of the units they have a device, 

13 typically a slinger wheel, that would allow any 

14 condensate that collects in an internal bucket to be 

15 re-applied to the hot surface to evaporate and then 

16 be carried out through the exhaust outside of the conditioned

17 space. If they do not provide that, or in addition to 

18 providing that, they may provide a collection pan or a 

19 gravity drain, in some cases an internal pump, to 

20 handle any condensate that may accumulate, either 

21 because there's no auto evaporation feature or 

22 because the conditions in usage, which may be very 
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1 different from the way these may be in the test 

2 procedure, you can end up with a fair amount of 

3 condensate being collected and then pumped out. 

4 So the final piece of this portion of the 

5 analysis is the technology assessment where DOE 

6 identifies the various technology options that are 

7 available. Now I disconnected the -- I will have to 

8 stand further -- so I'm not going to go through all 

9 of these but just in general, these may be familiar to 

10 you folks. 

11 They are similar to technologies that are 

12 looked at or have been looked at for dehumidifiers 

13 and room air conditioners. Examples are increasing 

14 the heat transfer surface area, improving the heat 

15 transfer, individual component improvements and 

16 looking at technology improvements that would be 

17 effective under variable conditions. 

18 I do want to mention that not listed here 

19 is more of an approach, but something we are going to 

20 talk about in a little bit, is the approach of air 

21 flow optimization, and that is the concept of reducing 

22 the amount of infiltration air by adding the second 
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1 duct on the dual-duct configuration. 

2 And associated with that is the 

3 requirement to bump up the blower size so that it can 

4 be associated with the static pressure increases as 

5 you put more of the air flow out of the exhaust duct. 

6 Any comments? 

7 MR. BROOKMAN: Questions or comments here? 

8 Stefano? 

9 MR. VIT: I just want to underline that 

10 the ability is a key issue and is a strong constrainment to 

11 design such a new product with the nature's way to be really

12 careful. So for this kind of product, I really would like 

13 to consider to invite you to consider this kind of prospect

14 as when you design these it is paramont these -- how soon

15 until we see that and I don't see that these reflected here,

16 if you can consider that, please. Thank you. 

17 MR. BROOKMAN: Thank you. Jennifer? 

18 MS. CLEARY: AHAM fully agrees with that 

19 comment and will provide some details in their 

20 written comments as to which of these technology 

21 options could have an impact. 

22 MR. BROOKMAN: Okay, thank you. John 
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1 Cymbalsky? 

2 MR. CYMBALSKY: This is John from DOE. So 

3 my recollection here is that we saw a pretty big 

4 range in the weight of these things or at least that is 

5 what I was told. I don't know if you know that off 

6 the top of your head but -- 

7 MS. REICH: I'm going to defer that 

8 question to Troy. 

9 MR. BROOKMAN: Troy? 

10 MR. WATSON: This is Troy Watson from 

11 Navigant. Yeah there was a pretty big range in weights, and

12 I think the slide that showed the parameters of different

13 types of units showed that the single-duct units were

14 typically less than 50 pounds. It's around 50 to 100,

15 between 50 and 100. 

16 MR. BROOKMAN: Do you wish to comment 

17 further? No, not at this time. Maybe in written 

18 comments you could add on. Okay, we are going to 

19 proceed then. 

20 MS. REICH: All right. The next step is the 

21 screening analysis, and that is where DOE evaluates 

22 all of its technology options that were identified 
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1 and determines which of them are appropriate to carry 

2 through to the engineering analysis. In screening 

3 out technology options, there are four factors that 

4 DOE considers. 

5 First of all, it must be technologically 

6 feasible to implement. It must be practicable to 

7 manufacture, install and service on the scale that's 

8 necessary at the time that the standards would become 

9 effective. It looks at whether there would be 

10 impacts on the utility of the product to consumers and 

11 of course, if there are any safety issues that are 

12 raised, that would cause the technology to be screened 

13 out as well. 

14 So actually, to the point about portability 

15 and the impact on consumers of larger sizes, DOE 

16 screened out one of the technology options, namely 

17 the ducting insulation, because DOE is not aware of 

18 any collapsible ducts that are insulated that have 

19 been successfully used in any working prototypes or 

20 any product that's on the market, and therefore if it 

21 was not collapsible, an insulated duct would be 

22 really reduced consumer utility in terms of being 
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1 able to move it around and perhaps store it when the 

2 product is not in use, and also that such ducts would 

3 not be feasible to manufacture. 

4 So before I move on to the engineering 

5 analysis, I would direct people, if you have further 

6 questions on that, chapter 4 of the TSD contains the 

7 screening analysis. If anybody has final thoughts 

8 before we go to the engineering analysis please let 

9 me know, okay. 

10 The basic purpose of the engineering 

11 analysis is to evaluate those design options that 

12 made it through the screening analysis and to 

13 determine how these technologies could be used to 

14 improve efficiency, and fundamentally the end result 

15 is to characterize the incremental manufacturer 

16 production cost that would be required at each 

17 incrementally higher efficiency level. 

18 The results, that cost efficiency curve, 

19 leads into various subsequent analyses that DOE 

20 conducts to look at impacts to consumers, in the nation, 

21 and also to manufacturers themselves. The steps that 

22 were followed for portable air conditioners were to 
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1 first of all identify the sample of products that 

2 would be selected to be representative with the 

3 current market. DOE selects products that are in a 

4 range of capacities and configurations and 

5 manufacturers, and with the information that's 

6 available to us, a range of efficiencies. 

7 DOE conducted testing of these products 

8 according to the proposed test procedure and then 

9 took all of them and tore them down, reverse 

10 engineered them, to determine exactly what 

11 technologies were implemented into each one of them, 

12 and using some very detailed modeling, to identify the 

13 manufacturing costs that are associated just with the 

14 incremental efficiencies of those products. 

15 Because of the limitations of the 

16 available data and because of the desire to expand 

17 the results beyond just the data points that were 

18 available in the test sample, DOE used a numerical 

19 model to generate some additional data points, and 

20 from all this information determined what the 

21 appropriate baseline relationship between capacity 

22 and EER was, and then to determine incrementally 
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1 higher efficiency levels, and finally from that 

2 information, to determine cost efficiency 

3 relationships. 

4 The sample that DOE used in the chart was 24 

5 portable ACs. Of those, 17 were single-duct units and 7 

6 were dual-duct. One unit had shipped with an optional 

7 conversion kit, so DOE tested that unit both ways. 

8 The selection was based on the rated information or 

9 the information that manufacturers provided in terms 

10 of capacity and efficiency, EERs, and again an attempt 

11 was made to get a broad range of manufacturers so 

12 that if manufacturers used different design 

13 approaches, DOE would be able to evaluate all of 

14 them. 

15 So again because this was based on 

16 available information to DOE in making the selection 

17 before the testing was completed, those rated 

18 capacities and the EER's are not necessarily what DOE 

19 is going to come up with in terms of its performance 

20 results using the proposed test procedures. 

21 And so this is, Joanna, starting to address 

22 some of your questions where we performed the initial 
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1 testing that accounted for the infiltration and the 

2 additional heat transfer effects and found that there 

3 was essentially a single relationship between -- for 

4 all the products and in all the configurations and 

5 manufacturers -- between cooling capacity and the 

6 cooling mode energy efficiency ratio. So for that 

7 reason, DOE determined that the single relationship 

8 between those would accommodate all of the products 

9 without requiring separate product classes. 

10 MR. BROOKMAN: And this is Jim Crawford? 

11 MR. CRAWFORD: This diagram is test 

12 results? 

13 MS. REICH: That's correct. 

14 MR. BROOKMAN: Yes please, Alberto? 

15 MR. ALOISI: Following questions, this was 

16 according to the proposal of the test procedure 

17 we saw this morning? 

18 MS. REICH: That's correct yes. 

19 MR. ALOISI: If I remember this morning on 

20 the table which you showed, there were also negative 

21 values of efficiency? 

22 MS. REICH: That's right. For the 
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1 purposes of the engineering analysis, DOE only 

2 considered the products that are actually providing 

3 net cooling of the space, -- 

4 MR. ALOISI: And so you selected part of 

5 the units that you tested. 

6 MS. REICH: At the baseline we did not 

7 consider products that were -- that did not provide 

8 net cooling, but those particular units in terms of 

9 once we had additional information from modeling, if 

10 the data points wound up positive they would be 

11 included. 

12 MR. ALOISI: Thank you. 

13 MS. REICH: So after its testing and 

14 teardowns, DOE identified five potential approaches 

15 that are being used or are likely to be used to 

16 increase efficiency, and these are the air flow 

17 optimizations that I discussed previously, which is 

18 the reduction in infiltration air and the addition of 

19 the second condenser duct, increase in the heat 

20 exchanger area, improvements to both the compressor 

21 and blower motor efficiency, and low standby 

22 electronic controls. 
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1 There were many other technology options 

2 that made it through the screening analysis but DOE 

3 does not believe that they were likely to be used for 

4 increasing efficiency, so therefore didn't consider 

5 them further in the engineering analysis. And there 

6 were several reasons why. Either there was not 

7 sufficient information to indicate that there would 

8 be a specific gain in efficiency if we proceeded with 

9 them, the proposed DOE test procedure might not 

10 capture the incremental efficiency improvement 

11 associated with them, and then that third point, and 

12 this was based on both the teardowns, the testing and 

13 discussions with manufacturers and observation of 

14 products on the market, were that there were a number 

15 of technologies that manufacturers were not likely to 

16 pursue simply because the approaches above are more 

17 cost effective so those would be the ones that they 

18 focus on. 

19 During the reverse engineering, the product 

20 teardown process, DOE calculates the incremental 

21 manufacturer production costs by tearing down these 

22 units from the sample of manufacturers, creating very 
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1 detailed bills of material. These describe the 

2 components that are included in the products, and the 

3 cost model includes everything from the material 

4 unit costs, parts costs, labor, capital equipment and 

5 overhead costs. 

6 And again those bills of materials, because 

7 of the detail of them, allows DOE to separate out the 

8 costs associated strictly with the improvement in 

9 efficiency versus the overall cost of the product. 

10 So DOE is interested in comments, whether some of the 

11 design options that were not included because they aren't 

12 measured in the test procedure, namely, the variable 

13 operating conditions or design options that result in 

14 efficiency improvement under varying operating 

15 conditions, and whether you have any comments on 

16 whether the test procedures should include varying 

17 ambient conditions. 

18 MR. BROOKMAN: Yes, Jim Crawford? 

19 MR. CRAWFORD: On the chart 98 you talk 

20 about improved motor efficiency, compressor efficiency, 

21 and improved blower efficiency. Are you assuming that 

22 you would stay within the induction motor technology? 
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1 MS. REICH: So for the blower motor 

2 efficiency improvements, that was moving from PSC to a 

3 permanent magnet motor. 

4 MR. CRAWFORD: And the same thing on the 

5 compressor? 

6 MS. REICH: For the compressor, the 

7 efficiency improvement was taken to be moving to a 

8 compressor with a 10.5 Btu per watt hour EER rating, and that

9 was 

10 based on a survey of compressors available on the 

11 market now in the capacity ranges that are compatible 

12 with the portable ACs. 

13 MR. CRAWFORD: Same compressor technology? 

14 MS. REICH: Yes. 

15 MR. CRAWFORD: Thank you. 

16 MR. BROOKMAN: You see there the request 

17 for comment. Comments on the design options and 

18 other issues that Judy had noted, okay. 

19 MS. REICH: Okay so the next step is to 

20 define the efficiency levels that would be used as 

21 the basis of the subsequent analyses. So although a 

22 sample was relatively large in terms of the number of 
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1 products that are available on the market, it did not 

2 cover the entire range of efficiency levels and 

3 design options that are technically technologically 

4 feasible and therefore DOE would want to consider. 

5 So in order to generate efficiency levels, 

6 DOE supplemented its test data with modeling to 

7 expand the number of data points that were used to 

8 generate these efficiency levels. So the efficiency 

9 levels that DOE selected were, at the baseline it 

10 would be single-duct units from its test sample, and 

11 what that means too is that that is all of the 

12 condenser exhaust air is coming in through infiltration, so 

13 100% infiltration. 

14 Efficiency level 1 was moving to a 

15 dual-duct design with 50% of the infiltration, with 

16 50% of the exhaust air coming in through infiltration. 

17 Efficiency level 2 is the same, but with 

18 only 25% infiltration. And efficiency level 3 

19 assumes that there is no infiltration air, so all of 

20 the condenser exhaust air is coming in from outside 

21 the conditioned space through the condenser inlet 

22 duct. 
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1 So with each one of efficiency levels 1 through 3, in 

2 addition to the -- in addition to adding the second 

3 duct and decreasing the infiltration air, there were 

4 some minor adjustments that would be made to the 

5 blower size, and there would also be, therefore, 

6 associated impacts in temperatures and conditions of 

7 the air flow that were required to be modeled using 

8 this modeling tool that DOE has developed for room 

9 air conditioners, that is called Mark N, that was 

10 adapted for use with portable ACs. 

11 The final efficiency level, the maximum 

12 technologically feasible level, is efficiency level 4, 

13 and that is starting from efficiency level 3 and 

14 adding some additional component improvements that 

15 included the increased heat exchanger size, 

16 improvements to compressor efficiency and blower 

17 motor efficiency that I just mentioned, and the low 

18 standby electronic controls. And there was some 

19 consideration made to how much the heat exchanger 

20 size could grow without substantially impacting 

21 portability. 

22 So I believe that was a 10% heat exchanger 
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1 size increase that was modeled. 

2 MR. BROOKMAN: Stefano? 

3 MR. VIT: This approach is incremental -- 

4 MR. BROOKMAN: Speak louder. 

5 MR. VIT: This approach where efficiency 

6 under 1, 2 and 3 is due to the fact that main 

7 contribution was a negative effect of infiltration 

8 and we want to remind that the first one is not -- is 

9 because you are considering 95, which is associated 

10 with 2% -- when we change this kind of 

11 improvement potential scenario should be adopted. It 

12 is true only if you will see the infiltration in the 

13 worst condition that happens in 2% of the cooling 

14 season. 

15 MS. REICH: That's a very good point that 

16 you make about its dependence on the infiltration air 

17 conditions, so any information that stakeholders may 

18 be able to provide about what the best and most 

19 representative condition is, would be very 

20 helpful. 

21 MR. VIT: We will provide you with data. 

22 MR. BROOKMAN: Thank you Stefano, thank 
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1 you. 

2 MS. REICH: So the next few slides are 

3 going to be charts, and so I'm going to do my best to 

4 walk you through them. If you have tricky questions 

5 I'm going to hand them over to Troy. So this plot is 

6 a combination of all the data that DOE developed from 

7 its test sample both from testing and from using its 

8 modeling tools to generate additional data points at 

9 higher efficiency levels. 

10 So each one of these curves in a different 

11 color represents a single test unit, where the 

12 starting data point on the lower left would be 

13 product as tested and then the additional data points 

14 along the curve as you move upward represent the 

15 modeling results. 

16 You can see that the curves generally 

17 increase in cooling capacity as the infiltration area 

18 is reduced and then that final very vertical segment 

19 of the line represents the max tech level where 

20 component improvements are added that don't have a 

21 lot of effect on cooling capacity, but do result in an 

22 incremental efficiency improvement. 
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1 MR. BROOKMAN: Yes, Joanna? 

2 MS. MAUER: Joanna Mauer, so I'm still 

3 trying to think through the test efficiency 

4 relationship, but this plot suggests to me that 

5 achievable efficiency is not a function of capacity, 

6 that EL 4 level across that fairly wide range of 

7 capacity is 3,000 to 9,000 BTU's per hour, units can 

8 achieve the same EER level. So I'm trying to 

9 reference them, and this graph was the proposal for 

10 efficiency to be a function of capacity. 

11 MS. REICH: I think as we step through to 

12 the next couple plots I think you will see hopefully 

13 a little more clearly. I think the reason why there 

14 is a fair amount of scatter here is that there are, 

15 among the products tested, there were a variety of 

16 different design approaches and different product 

17 configurations that manufacturers chose to implement. 

18 So what you will see in the next graphs is means that 

19 DOE used to separate out just looking at a whole set 

20 of possible design options at each potential 

21 efficiency level and trying to reorganize the data 

22 that way. 
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1 So because the cooling mode energy 

2 efficiency ratio includes cooling capacity, we wanted 

3 to find a more fundamental relationship between the 

4 cooling capacity and the power consumption of the 

5 unit, and so this is just the same data from the 

6 previous plot with the cooling capacity removed from 

7 the EER metric to just wind up with the power 

8 consumption. 

9 And so one of the things that you can note 

10 here is that although the different products may wind up, 

11 may start out at different efficiencies. The slopes 

12 of these, except for that max tech level, but the 

13 slopes where we are reducing the infiltration area 

14 are all quite similar, so it indicates that kind of 

15 the same relative efficiency improvement is 

16 achievable, or it would be expected on a product 

17 regardless of where its starting point was. 

18 So then, rather than organizing the data by 

19 unit, by test unit, DOE took that same data and 

20 merged the data points together by which efficiency 

21 level each data point was associated with. So the 

22 different colors here, the data points represent -- 
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1 starting with the green data point, that's the 

2 baseline efficiency level, and then as you go to 50% 

3 and 25% and zero% infiltration area and then 

4 component improvements, you have separate clusters of 

5 data for each efficiency level. 

6 And then from each one of those sets of 

7 data points, DOE fit a curve to describe the general 

8 trend between capacity and power, and DOE tried, you 

9 know, a number of different curve fits and determined 

10 that a linear fit is indeed most appropriate. It 

11 provided the best fit to those data and also the 

12 slopes again, the slopes are relatively similar so 

13 that there is a constant incremental change as you 

14 move to higher and higher efficiency levels, 

15 regardless of the cooling -- it was independent of 

16 cooling capacity. 

17 MR. BROOKMAN: Stefano? 

18 MR. VIT: And we would like to underline 

19 that this proves that when the outdoor temperature, 

20 it will be really interesting to see, the sensitivity 

21 -- when outdoor temperature is -- . 

22 MR. BROOKMAN: Yes, Jim Crawford? 
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1 MR. CRAWFORD: What kind of R squared did 

2 you have on those curves? 

3 MS. REICH: I don't know off hand. 

4 MR. BROOKMAN: Troy? 

5 MR. WATSON: This is Troy Watson. I don't 

6 know off the top of my head but you can see it's not 

7 a great fit here. We tried the different curve types 

8 and the linear fit had the best R squared. 

9 MR. CRAWFORD: I'd be surprised if it's a 

10 number that is kind of embarrassingly low. 

11 MR. WATSON: As Judy was mentioning before, 

12 the starting point for all these data points was the 

13 test unit we had in our sample, and those units gave a 

14 variety of data points for the potential configurations. 

15 So DOE found improvements to the air flow and then 

16 the max tech changes based on those starting points. 

17 So those are your range of data points at the start, and 

18 they kind of carried on. 

19 What we had to do is, the test sample included 

20 several units, and DOE tried to capture a wide 

21 range of the market, DOE believes these are 

22 representative of the marketplace efficiency. 
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1 MR. CRAWFORD: But you have done a 

2 regression analysis. You decided there was a linear 

3 model and looking at the data I don't know what else 

4 you would use, and you have given two coefficients. 

5 But the regression assumes that the correlation 

6 coefficient is equally important to know whether or 

7 not those are really good representations of the 

8 data. 

9 MR. WATSON: So just to respond, if you 

10 would go back a slide please. So the point of those 

11 linear fits was to try to quantify the jumps to the 

12 right and then down on this chart, so that by coming 

13 up with overall linear equations on the last slide, 

14 we had to quantify the changes between the efficiency 

15 levels. 

16 MR. BROOKMAN: Jim? 

17 MR. CRAWFORD: Taken as an average, power 

18 versus capacity curves, these are nice in terms of 

19 correlation. The next set of curves, they look like 

20 scatter diagrams. 

21 MR. WATSON: So those are all the same 

22 data points just presented in a different way. So if 
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1 you were to draw a line between the baseline and EL1, 

2 EL2 and EL3 on this plot you would end up with the 

3 lines on the previous plot, and so in this one if they 

4 separated out all the data points, looking at these, that 

5 are all baseline units, et cetera, and then the linear 

6 fits to those data points allowed us to quantify the 

7 jumps to the efficiency levels. 

8 MR. CRAWFORD: Except that in the 

9 preceding diagram you did try to begin to group 

10 things together, group the data from individual 

11 curves together. Your individual curves look good. 

12 You group them together and you have a scatter, 

13 pretty close to a scatter diagram, and you know the 

14 correlation coefficients are very important to know 

15 how comfortable one ought to be with going anywhere 

16 with that diagram. 

17 MR. WATSON: Well I guess the difficulty 

18 here is we have to come up with numbers in some way 

19 that tries to best reflect the overall market. So we 

20 have to move from some of those individual curves to 

21 an overall kind of summary of the market at some point. 

22 This was the best way we could determine this. If you 
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1 or anyone else want to give us some improvements we 

2 would appreciate it. 

3 MR. BROOKMAN: Judy? 

4 MS. REICH: Before I move on I just want 

5 to point out that each one of these linear fits 

6 provides a set of coefficients that DOE then used to 

7 generate the EER versus cooling capacity equations 

8 that characterize the industry average baseline and 

9 then subsequent higher efficiency levels that the DOE 

10 used in its analysis. So in this table, the A&B 

11 coefficients came from those linear fits, and then 

12 EER in cooling mode is just cooling capacity 

13 divided by the average power. 

14 MR. BROOKMAN: Joanna? 

15 MS. MAUER: One observation related to, I 

16 think, one of those earlier questions. So if you do 

17 continue the curves to the negative cooling capacity 

18 range, the ordering of the curves flips, so it looks like 

19 the units that you tested that do have negative 

20 cooling capacities actually would meet all of the 

21 efficiency levels that were evaluated. Presumably, if 

22 the manufacturers have to use the DOE test procedure 
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1 as the basis for information about cooling capacity, 

2 they will have an incentive to not to produce units 

3 with negative cooling capacities, but it still seems 

4 better to not have that kind of odd result where you 

5 could have a unit with a negative cooling capacity 

6 that meets you know, the EL 4 for example. 

7 MS. REICH: Because we didn't include 

8 negative data points in generating these curves, it's 

9 not valid to extend them into the negative range. So 

10 this analysis is based on the assumption that a 

11 portable AC be intended for the purpose to provide net 

12 cooling capacity. 

13 MS. MAUER: This is Joanna, so if a 

14 manufacturer did produce a negative cooling capacity, 

15 would it mean that that product couldn't be rated or 

16 -- 

17 MR. CYMBALSKY: These are all on the 

18 market. 

19 MR. BROOKMAN: John Cymbalsky, microphone. 

20 MR. CYMBALSKY: The testing that we did, we 

21 found units that provided that. 

22 MS. MAUER: And I'm just, and those units I 
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1 think have higher efficiency levels than EL 4 because 

2 of what happens to the curve when you get up to the 

3 negative capacity range, just an observation. 

4 MR. BROOKMAN: Jim Crawford? 

5 MR. CRAWFORD: What will happen to the 

6 curve is they will really do something squirrely 

7 because they are going to go up as you get into the 

8 second quadrant. You think of them as continuing on 

9 down. They won't, they are going to go up. If they 

10 continued on down it would say that the unit was 

11 producing power. 

12 MS. MAUER: This is Joanna. When I 

13 plotted them they did continue to go down and the 

14 ordering shifted. 

15 MR. CRAWFORD: They are going to go back 

16 up. 

17 MR. BROOKMAN: Okay, yes? 

18 MS. MAUER: This is Joanna, if I could 

19 just ask another question. I was looking at the 

20 earlier plot showing the modeled EER values on slide 

21 102 versus capacity, where the maximum values are in 

22 the range of 7 to 7.5 EER, and I was just trying to 
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1 understand how that relates to the efficiency level 

2 curves, so that the modeled EER values at EL 4 seemed 

3 to be higher than the EL 4 curve? 

4 MS. REICH: So as you can see in this 

5 chart on slide 1 and 2, there is an entire range of 

6 data points at EL 4 that, oh I'm seeing one that's 

7 just over 4 to over 7. So again, what we are trying to 

8 do is model the industry average with the EL 4 curve, 

9 so there will be some data points that are above it 

10 and some that are below it. 

11 MS. MAUER: This is Joanna. I guess I am 

12 having trouble understanding why it makes sense to 

13 model the industry average when you are looking at 

14 the maximum technology values? 

15 MS. REICH: Because the max tech level is 

16 a function of particular products that you are 

17 starting with and then the application of all of the 

18 potential efficiency improvements to it, so different 

19 design approaches will have a different potential 

20 maximum efficiency improvement. 

21 MS. MAUER: This is Joanna. But is there 

22 some reason why all units wouldn't be able to achieve 
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1 the maximum values that you found through the 

2 modeling? 

3 MR. WATSON: This Troy Watson again. I 

4 think by going to the average values, were hoping to 

5 get rid of some of the uncertainty with the modeling. 

6 So on this plot you can see, I think the two data 

7 points are the top left ones, and I think those 

8 started off with net heating first. So it's a 

9 huge jump to go from the net heating to where those 

10 ended up. So those two specific data points may not 

11 actually be representing a max tech. By taking the 

12 average of those and the other ones, I think you have 

13 more appropriate data. 

14 MS. MAUER: Okay, it looks like even the 

15 one on the higher end where there are some units having 

16 EER's of 7 or above which are higher than El 4. 

17 MR. BROOKMAN: Let's keep going. 

18 MS. REICH: So finally the last step in 

19 the engineering analysis is to develop cost 

20 efficiency relationships, and as I mentioned before, DOE 

21 used its reverse engineering process to develop the 

22 incremental manufacturer production costs for each 
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1 unit, and then it determined an average incremental 

2 cost at each of the higher efficiency levels based on 

3 those incremental costs for each unit. 

4 And this slide presents the cost 

5 information that DOE has estimated in their analysis. 

6 So you can see that the first three efficiency 

7 levels, 1, 2, 3, have relatively modest incremental 

8 costs because the only changes that would be 

9 associated with those levels is that air flow 

10 optimization, the addition of a second duct and 

11 potentially a small increase in the blower size. More 

12 significant modifications would be made at EL 4 

13 because of the inclusion of higher efficiency 

14 components, so therefore there's a significant jump 

15 between EL 3 and the max tech level. 

16 MR. BROOKMAN: There is no request for 

17 comment box here but any additional thoughts, 

18 questions or comments on these last few slides? Cost 

19 efficiency relationships on 106 and 107? Yes Stefano? 

20 MR. VIT: Just to underline what we said 

21 before -- 

22 MR. BROOKMAN: Louder, Stefano. 
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1 MR. VIT: Just to underline what we said 

2 already in our statement, EL 3 is a double duct -- I 

3 see a differently priced of -- I wonder how this 

4 could be incorporated as we don't have any example or 

5 what example of this solution. 

6 MS. REICH: I believe that cost was 

7 associated with the different case design that 

8 included sealing, so that there would be no additional 

9 or no infiltration air. 

10 MR. BROOKMAN: Jim Crawford? 

11 MR. CRAWFORD: Well as I look at this 

12 diagram 107, I wonder what capacity those incremental 

13 costs relate to. Like we have been talking about a 

14 range of 5,000 to 14,000 and I would think that 

15 incremental efficiency bump at the lower end of the 

16 capacity would be different costs than the bump 

17 at the higher capacity. 

18 MS. REICH: This represents an average 

19 across all capacities. 

20 MR. CRAWFORD: Thank you. 

21 MR. BROOKMAN: Thank you Judy. Final 

22 comments? We should go for lunch. We are overdue for 
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1 lunch and it's now almost 10 minutes after 1. 

2 Typically we go for an hour for lunch. Do you think 

3 we could try for 45 minutes? Several individuals 

4 have indicated they would like to press on with this. 

5 Let's try for 45 minutes, which means we will resume 

6 at 5 minutes until 2 in this room. Please make sure 

7 to wear a badge if you go to the big cafeteria. You 

8 might need -- probably will need an ID a photo ID to 

9 get back to the security portal. This room will be 

10 secured and watched so you could leave your stuff 

11 here. 

12 For those of you that don't -- aren't 

13 familiar with the layout, you need to go down to the 

14 ground floor and about 100 yards in that direction. 

15 There will be a bunch of us going in that direction. 

16 There's also a Subway sandwich shop down where the 

17 Dunkin Donuts is on the ground floor that a way okay? So 45 

18 minutes, don't linger. 

19 (OFF THE RECORD) 

20 MR. BROOKMAN: Okay let's start back up. 

21 I should probably start by congratulating you all. I 

22 don't think any regulatory meeting here at DOE has 
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1 ever successfully reconvened after only 45 minutes of 

2 lunch. We did well. So let's pick up where we left 

3 off and we are going to hear from Nicole. 

4 MS. BUCCITELLI: I'm Nicole Buccitelli 

5 from Navigant, presenting the preliminary manufacturer 

6 impact analysis. The purpose of the manufacturer 

7 impact analysis is to assess the impacts of the 

8 energy conservation standards on 

9 manufacturers, and in doing this, estimate impacts on 

10 manufacturer subgroups such as small businesses that 

11 may be disproportionately impacted and also 

12 to examine cumulative regulatory burdens, impacts to 

13 direct employment, competition and manufacturing 

14 capacity within the industry. 

15 In terms of methodology, the government 

16 regulatory impact model is used to analyze industry 

17 cash flows and to estimate industry net present value 

18 at the base case and at possible standard levels. 

19 Interviews with manufacturers were used to find 

20 inputs to the GRIM, develop subgroup analyses and in 

21 order to address the qualitative issues that arise. 

22 In a bit more detail, the MIA is 
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1 broken down into three phases of analysis. In phase 

2 1, DOE builds from the information developed in the 

3 market and target assessment, supplementing the 

4 information with additional market research in order 

5 to create an industry profile. 

6 During this phase, DOE also identifies 

7 important issues that will require further 

8 investigation. In phase 2, DOE developed a 

9 preliminary industry cash flow model using the 

10 information compiled in phase 1 and initial inputs 

11 from the engineering and shipments analyses, and 

12 prepares an interview guide which will form the basis 

13 of discussions with manufacturers. 

14 In phase 3, DOE interviews manufacturers 

15 and uses information obtained from the interviews to 

16 refine the GRIM and to qualitatively assess impacts 

17 on employment, competition, manufacturing capacity 

18 and regulatory burdens. 

19 In the preliminary interviews for this 

20 rule, manufacturers voiced several concerns relating 

21 to potential standards for portable ACs. First, 

22 manufacturers believe that higher selling prices 
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1 could price out a segment of customers or that 

2 customers could choose to purchase room ACs 

3 instead of portable ACs. Manufacturers are also 

4 concerned that these standards could lessen 

5 competition within the industry and could negatively 

6 impact consumer utility associated with the product 

7 features such as size, noise level and ease of water 

8 disposal. 

9 Finally, manufacturers expressed concerns 

10 about the cumulative regulatory burdens they face as 

11 portable ACs are typically only one of a suite of 

12 products that they produce. 

13 Navigant will be contacting manufacturers 

14 relatively soon in order to schedule NOPR phase 

15 interviews, and we would encourage participation in 

16 those interviews and those will provide an 

17 opportunity to inform the more major components of 

18 the manufacturer impact analysis including conversion 

19 costs. 

20 DOE seeks comments on the identification 

21 of key issues and requests information from 

22 interested parties that can assist in evaluating the 
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1 potential impact on manufacturers, and then also DOE 

2 requests feedback on subgroups to analyze and or 

3 characteristics appropriate for sub group 

4 analyses. 

5 MR. BROOKMAN: Jennifer? 

6 MS. CLEARY: Jennifer Cleary, at the risk 

7 of sounding like a broken record here, manufacturers 

8 really do want to participate and of course will 

9 encourage their members to participate in the areas 

10 with Navigant, but I am concerned that the test 

11 procedure is not close to being final and therefore 

12 is going to be very difficult, and not necessarily 

13 for all aspects of the rulemaking, but for many, it is 

14 going to be very difficult for manufacturers to 

15 provide you with the full input that includes test 

16 data, and therefore is going to be very difficult for 

17 DOE to get an accurate picture of a market that 

18 doesn't you know, have large amounts of -- so I would 

19 just urge DOE again to release the final test 

20 procedure before it goes to the manufacturer 

21 interviews and is in place. 

22 MR. BROOKMAN: Okay. You see two comment 
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1 boxes there, identification of key issues and 

2 requests for data information, and also manufacturer 

3 subgroups including small business manufacturers, 

4 those with different cost structures, et cetera. Any 

5 additional thoughts or comments here? Okay. 

6 MS. DUNHAM: Good afternoon my name is 

7 Camilla Dunham, I work at Lawrence Berkeley National 

8 Laboratory. We are now getting into economic 

9 analyses that are part of the standards rulemaking, 

10 specifically the lifecycle costs and payback period 

11 analysis and the national impact analysis. I am 

12 going to talk about the LCC in my comments and Chun Chun Ni 

13 will talk about the NIA. 

14 So for the lifecycle cost analysis, it's a 

15 sum of the total installed cost and the lifetime 

16 operating costs. I am going to focus now on one of 

17 the inputs into the total installed cost, which is the 

18 markup development. 

19 From the engineering analysis we receive 

20 manufacturer costs. We need to transform those 

21 manufacturer costs into their consumer price. 

22 Markups are the multipliers that permit that 
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1 adjustment. So from manufacturer to consumer, 

2 markups reflect each step along the distribution 

3 chain. 

4 For portable air conditioners the 

5 distribution chain is pretty straight forward. 

6 Manufacturers sell to retailers who then sell to 

7 consumers. The first markup is the manufacturer 

8 markup, which is developed from the Security and 

9 Exchange Commission 10K reports. The retailer 

10 markup comes from the annual retail trade survey, 

11 ARTS, and the consumer markup is the sales tax which 

12 is developed from the Sales Tax Clearing House. That 

13 information is used in the model. 

14 We also have baseline markups and 

15 incremental markups. Baseline markups relate the 

16 cost to price, prior to efficiency improvements. 

17 Baseline markups include direct costs such as 

18 salaries, rent and payroll. Incremental markups are 

19 applied to each efficiency level above the baseline 

20 and do not include direct costs. Incremental markups 

21 include costs of goods and services and vary with 

22 efficiency. 
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1 Here you have a slide that shows the three 

2 different types of markups for both residential and 

3 commercial instances or applications. And here is 

4 another comment box. Are there any comments at this 

5 point in terms of the markup determination? 

6 So we are back to this flow chart. You are 

7 going to see it again, but I'm moving to the lower 

8 left-hand side of the slide to talk about an input 

9 into the lifetime operating cost, which is the energy 

10 use. DOE needs to know how much energy portable air 

11 conditioners use so that it can estimate possible 

12 savings with a difference between the baseline and 

13 higher efficiency products. 

14 From the engineering analysis we receive 

15 energy use by efficiency level for different modes, 

16 cooling, fan only and standby power. With the Energy 

17 Information Administration's consumption surveys, RECS 

18 and CBECS, we use room air conditioner information to 

19 approximate the presence of portable air conditioners 

20 in residences and also in the commercial sector. 

21 This slide shows the calculation flow. We 

22 take the sum of the energy use by mode and 
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1 multiply that by the annual energy hours to get the 

2 annual energy use, I'm sorry annual operating hours, 

3 to get the annual energy use, the equation that you 

4 will see on the bottom of the slide. 

5 So available studies allow us to express 

6 the annual energy use for both residential and 

7 commercial installations. These are some of the 

8 sources that we have for operating hours. Due to a 

9 lack of information, a lot of the information we 

10 assumed from room air conditioners. This slide shows 

11 power consumption by efficiency level for the 

12 baseline and then each of the four efficiency levels. 

13 This slide shows the annual energy use 

14 again for the baseline and the four efficiency 

15 levels. A request for comment on the energy use 

16 determination, any comments at this point? 

17 MR. BROOKMAN: Jim Crawford. 

18 MR. CRAWFORD: Jim Crawford, what's the 

19 capacity of the nominal unit using chart 126? 

20 MS. DUNHAM: Troy? 

21 MR. WATSON: I -- 

22 MR. CRAWFORD: I know it's there, I'm 
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1 sorry it's there. 

2 MS. DUNHAM: Sorry, I was looking at 127. 

3 Yes, it's there on 126. 

4 MR. BROOKMAN: Comments on energy use 

5 determination? 

6 MS. DUNHAM: Okay so this flow chart shows 

7 all the remaining inputs -- 

8 MR. BROOKMAN: Excuse me, Len Swatkowski, 

9 you're next. Please, you are unmuted; please speak. 

10 MR. SWATKOWSKI: Yes, this is Len 

11 Swatkowski from OceanAire. As far as the energy use 

12 on commercial, is that looking at a certain unit or 

13 certain size commercial unit? Because a range -- when 

14 Judy talked earlier about the range being up to 

15 14,000 being used, there are commercial units that go 

16 larger in our sector, that we won't get into any 

17 commercial portables, only to the 5,000 BTUs. 

18 MS. DUNHAM: I should have perhaps 

19 underlined this point a little bit more strongly. We 

20 are looking at residential appliances that are used 

21 in commercial establishments. We are not considering 

22 commercial types of portable air conditioners. 
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1 MR. SWATKOWSKI: Okay. 

2 MS. DUNHAM: These are -- 

3 MR. SWATKOWSKI: Thank you. 

4 MR. CYMBALSKY: This is John from DOE so 

5 just to clarify that, you know based on our earlier 

6 discussion about the commercial spot coolers, this 

7 analysis does not, you know, place them into this 

8 analysis; it doesn't consider them. What it does 

9 consider and I think there are many of us probably in 

10 this room who have seen residential portable 

11 ACs that are considered here that are used in 

12 restaurants and other office buildings. They actually 

13 use them here at DOE. I have seen it several times. 

14 So what we are trying to do is capture the 

15 energy use of portable ACs across the spectrum of 

16 their applications so it is going to bleed into the 

17 commercial sector. 

18 MR. BROOKMAN: Jim Crawford? 

19 MR. CRAWFORD: I thought I had the answer 

20 to Len's question and then I found out I'm more 

21 confused than I thought I was because the EERs shown 

22 there that have been taken from page 126 chart 126. Chart
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1 126 shows almost three-to-one treated variation in capacity

2 but some assume capacity constant appears to have been used

3 on 127. Otherwise I don't think that the energy uses would

4 have decreased as you went to higher efficiency 

5 levels. 

6 MS. DUNHAM: You can get more information 

7 about this in chapter 7 of the Technical Support 

8 Document. 

9 MR. BROOKMAN: Okay. 

10 MS. DUNHAM: So in the Life-Cycle Cost and the 

11 Payback Period analysis we look at, the LLC 

12 calculation, produces the total cost to the consumer 

13 over the life of the product. The payback period is 

14 the amount of time needed to recover the increase in 

15 purchase price of a more efficient piece of 

16 equipment, a more efficient portable air conditioner. 

17 The purpose of the LCC analysis is to compare the 

18 lifetime impacts between the baseline efficiency 

19 level and the higher efficiency levels. 

20 Using consumer samples from RECS and CBECS, 

21 we determined the total installed cost and the 

22 lifetime operating cost for each efficiency level. 
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1 We calculate the LCC savings by subtracting the 

2 lifecycle cost of each efficiency level from the 

3 lifecycle cost of what the consumer would have 

4 purchased in the absence of a standard. We 

5 determined both first year and lifetime operating 

6 costs, so the payback period divides the average 

7 increase in installed cost by the average decrease in 

8 first year operating costs. 

9 DOE conducts the LCC using a Monte Carlo 

10 simulation. A Monte Carlo simulation and probability 

11 distributions model both the uncertainties and the 

12 variabilities of the inputs, enabling DOE to identify 

13 the percentages of consumers who either benefit from 

14 or who are negatively impacted by a prospective 

15 standard. 

16 Each Monte Carlo simulation represents 

17 10,000 LCC calculations to reduce the error brought 

18 by uncertainty and variability. As mentioned before, 

19 the RECS household sample is used for residential 

20 appliances and CBECS is used for residential 

21 appliances used in the commercial setting. 

22 So now we are getting into the remaining 
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1 inputs. The total installed cost is the sum of the 

2 consumer product price and the installation costs. 

3 We have already covered the consumer product price 

4 determination in the markups discussion. Installation 

5 costs are based on information from the R.S. Means 

6 residential cost data. DOE assumed that installation 

7 costs would not vary depending on efficiency level, 

8 so this input drops away from the calculation. 

9 Now on to operating costs inputs -- this 

10 slide shows the category of inputs in the lifetime 

11 operating costs. They include 

12 annual operating costs, lifetime discount rates and 

13 electricity price trends. To get annual energy 

14 costs, we include energy prices that we get from 

15 EIA's Form 861 and energy trends are taken from the 

16 Annual Energy Outlook. 

17 Repair and maintenance costs are assumed 

18 not to vary with efficiency level and so these drop 

19 away from the calculation as did installation costs. 

20 So are there any comments or questions to what I 

21 covered so far, specifically we are looking for 

22 repair and maintenance costs that might be specific 
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1 to different efficiency levels. 

2 MR. BROOKMAN: Jennifer? 

3 MS. CLEARY: Jennifer Cleary. This is, I 

4 guess, not specific, so I apologize. But overall, the 

5 analysis we have been discussing and its reliance on 

6 RECS and CBECS -- I think my concern and I need to 

7 investigate it further for our written comments, but 

8 it's concerning to me that a lot of this analysis is 

9 based on that data which is for room air conditioners, 

10 not portable air conditioners. It's really placing a 

11 lot of eggs in the basket, assuming that those 

12 products have similar usage patterns and similar 

13 market penetration. I don't believe that either of 

14 those is necessarily the case. So we will provide 

15 more details in our written comments, but I think that 

16 it's very possible that that data may not be 

17 sufficient for DOE's analysis. 

18 MR. BROOKMAN: John Cymbalsky? 

19 MR. CYMBALSKY: John from DOE. So earlier 

20 I think someone mentioned in their opening remarks 

21 this morning about how De'Longhi has raised concern 

22 about the use of the portable air conditioners, and my 
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1 recollection was it sounded just like the way someone 

2 would use a room air conditioners. I just heard what 

3 he said, but that was my interpretation of the opening 

4 remarks. We will have to go back to the transcript 

5 and look, but if that's true, then I would expect the 

6 operating hours to be similar because it seems like 

7 these things intention is to cool a room. But if 

8 that's not the intention, and I think that's what I 

9 heard him say and I guess I would like to know why 

10 the operating hours would be any different than that. 

11 And if we do think that the temperature 

12 set points at 70 degrees and not 95, I would expect 

13 people are using these things a lot more than a 

14 regular air conditioner, but I don't think people 

15 will turn it on at 70 degrees, at least in the states. 

16 Just a couple of observations with the operating -- 

17 MR. BROOKMAN: Alberto? 

18 MR. ALOISI: Alberto Aloisi, and it was not 

19 my intention to compare portable with 

20 room. I agree that they are two different categories, 

21 but what my intention was to specify on the opposite 

22 premise. Portable conditioners, specific features, 
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1 are different from the other categories of 

2 conditioners. 

3 MS. CLEARY: This is Jennifer. Following 

4 up on that point, I think you mentioned, John, that 

5 both products are used to cool and that's true. But 

6 that doesn't mean consumers use them to cool a room 

7 under the same circumstances, and those circumstances 

8 that the consumers are using them for may change: the 

9 time of year that they are using them and the 

10 frequency with which they are using them, and 

11 certainly can change the number of consumers who even 

12 have the products. And I think that those fundamental 

13 assumptions are what's key for many of these analyses 

14 and could drastically change them. 

15 MR. CYMBALSKY: So maybe we can discuss a 

16 little bit more about what those times are that they 

17 use them, is it when it's cooler out or hotter out, more of 

18 a quick need or not?

19 MS. CLEARY: Jennifer Cleary, we'll gladly 

20 provide more detail in our written comments. 

21 MR. BROOKMAN: Okay, thank you Jennifer. 

22 Ed Wuesthoft asks the question: what is the lifetime 
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1 of portable ACs? 

2 MS. DUNHAM: I'm really glad you gave me 

3 this opportunity to move the slide forward. So to 

4 express annual operating costs and lifetime operating 

5 costs you need to determine the lifetime of portable 

6 air conditioners, and we do that with a Weibull 

7 probability distribution. DOE used historical 

8 shipments data and product saturations for room air 

9 conditioners, lacking other information available, and 

10 estimated a lifetime of about 10 and a half years. Does 

11 that answer the question from -- 

12 MR. BROOKMAN: I think that helps, it 

13 answers his question, yeah. 

14 MS. DUNHAM: When considering future 

15 costs, we need to use a discount rate to establish 

16 their present value. DOE uses publically available 

17 data from the Federal Reserve Board Survey of Consumer 

18 Finance and estimated consumers opportunity cost of funds 

19 related to appliance energy cost savings. The 

20 discount rate value is applied in the LCC model to 

21 future year energy cost savings, non-energy 

22 operations and maintenance costs, yielding an 
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1 estimated net LCC and LCC savings. 

2 DOE notes that the discount rate used in 

3 the LCC analysis is distinct from an implicit 

4 discount rate and that it is not used to model 

5 consumer purchase decisions. 

6 DOE does not assume that all machines in use or to be 

7 purchased are at the baseline efficiency level. 

8 Consumers already use and purchase products at 

9 efficiencies greater than or equal to a prospective 

10 standard level. 

11 Base case efficiency distribution allows a 

12 more accurate estimation of consumer impacts by 

13 representing different efficiency levels, either 

14 currently being used or yet to be purchased. These 

15 are based on analysis of market data of online 

16 portable air conditioner retailers. 

17 A request for question or comment? 

18 MR. BROOKMAN: Comments on base case 

19 efficiency distributions, ok. 

20 MS. DUNHAM: Here are some preliminary 

21 analysis results showing the lifecycle costs and 

22 payback periods. You will note that all of the 
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1 lifecycle costs are positive and less than 2 years. 

2 MR. BROOKMAN: We have a comment box here 

3 do we have comments on the lifecycle costs and 

4 payback period analysis? Yes, Stefano? 

5 MR. VIT: Baseline is market share 90%. 

6 Does it mean that 90% is a single-duct? 

7 MS. DUNHAM: It assumes that the baseline 

8 efficiency level is 90% of the market share at the 

9 time of 2019 will be at 90% or the baseline level. So 

10 it doesn't assume single-duct. It assumes a particular 

11 efficiency level. 

12 MR. VIT: I'm just asking, after the 1, 2, 

13 3, 4 are double duct and the first one is 

14 single-duct, speaking about -- am I wrong? 

15 MS. DUNHAM: What we do in the lifecycle 

16 cost analysis is we consider one product class and we 

17 look at the efficiency levels for that one product 

18 class. So there -- 

19 MR. VIT: I understand. 

20 MS. DUNHAM: Okay. 

21 MR. VIT: In this specific case a 

22 single-duct and double-duct are together? 
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1 MS. DUNHAM: That's correct. 

2 MR. VIT: So baseline 90% is a single-duct, 

3 I suppose, and just need information about that. So you 

4 are assuming that 90% of the market is single-duct 

5 and 5% is double-duct, then 50% of the -- is 

6 efficiency level 1, efficiency level 2 is for a 

7 single-duct, double-duct has 25% penetration, because 

8 the third case is a double-duct that is a sealed 

9 double-duct. 

10 MS. DUNHAM: I'm going to see if I can get 

11 more information. 

12 MS. CHUN NI: Based on -- 

13 MR. BROOKMAN: You are not on yet. 

14 MS. CHUN NI: Chun Chun Ni, LBNL, the 

15 baseline here is based on the engineering. It's a 

16 single-duct. The 90% is single-duct products. 

17 MR. VIT: So you are saying that 

18 efficiency level 1 is double-duct and 50% penetration 

19 and efficiency level 2 is double-duct and 30% 

20 penetration? 

21 MS. CHUN NI: The efficiency level 1 and 2 

22 are based on our data base. It contains single and 
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1 two-duct models. 

2 MR. VIT: Sure. 

3 MR. CYMBALSKY: I think if we -- this is 

4 John from DOE. If we go back to slide 101, I think this 

5 is what Stefano was referring to. 

6 MR. VIT: Yes, thank you, okay. 

7 MR. BROOKMAN: Okay. 

8 MR. VIT: So assuming we are in 2019, this 

9 would be the distribution? 

10 MS. DUNHAM: That's right. 

11 MR. CYMBALSKY: So absent any standards -- 

12 all right, so this is before a potential standard. 

13 MR. VIT: Thank you. 

14 MR. BROOKMAN: Any additional thoughts, 

15 comments here, okay. 

16 MS. DUNHAM: I am going to turn the podium 

17 over to my colleague, Chun Chun Ni. 

18 MS. CHUN NI: My name again is Chun Chun 

19 Ni, I'm from LBNL. I will talk about DOE's Shipments 

20 and the National Impact Analysis for portable air 

21 conditioners. First I will talk about the shipments 

22 analysis. The purpose of the shipment analysis is to 
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1 estimate shipments of portable ACs over a 30-year 

2 analysis period for both the base case and the 

3 standards case. 

4 The shipments are the inputs to both the 

5 National Impact Analysis and Manufacturer Impact Analysis. 

6 The analysis relies on a range of 

7 data sources, including historical shipments data. 

8 The shipments analysis considers portable air 

9 conditioners are purchased either for replacement 

10 purposes or are purchased by first time owners. The 

11 flow chart here shows the approach that DOE took for 

12 the shipments analysis. DOE first estimated total 

13 shipments which account for replacement and first 

14 time owners. 

15 DOE then divided the total shipments into the 

16 commercial sector and the residential sector. The 

17 table here summarizes the inputs that DOE used for 

18 the shipments analysis. So first for the historical 

19 shipments data, DOE assumed portable air conditioners 

20 accounted for about 10% of the total shipments of 

21 room air conditioners based on the Natural Resources Canada's

22 report. 
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1 DOE then relied on the historical room ACs 

2 shipments data which was submitted with the previous 

3 rulemaking for room air conditioners. DOE added 

4 2010 to 2012 data points by using UBMs market 

5 research report. For the market share by user 

6 sector, DOE relied on the data that was derived from 

7 the LCC analysis. DOE assumed that that residential 

8 sector accounts for about 99% and the commercial 

9 sector accounts for about 1% of the total amount 

10 here. 

11 As for the replacement, DOE relied on the 

12 lifetime retirement function that was also developed 

13 in the lifecycle cost and the payback period 

14 analysis. Based on the historical shipments data and 

15 the total housing stock data, DOE estimated that 

16 about 0.17% of the households will become first time owners 

17 and will purchase the product annually 

18 between 2013 and 2048. 

19 The product prices were also derived from the 

20 LCC and payback period analysis. DOE also used AEO 

21 2014 to project future total housing stock and 

22 it also used AEO 2014 to estimate the operating cost of 
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1 the product. DOE's shipment analysis includes two 

2 components, that is base case shipments and the 

3 standard case shipments. After developing base case 

4 shipments, DOE also developed the standards case 

5 shipments. In other words, the shipments projected 

6 after a standard is adopted. 

7 The standards case is projected using the same 

8 data sources as the base case shipments projection. Beyond

9 that, the 

10 standards case shipments account for purchase price 

11 increases and operating cost savings due to standards 

12 to estimate any shipments change to the base case 

13 shipments projection. So the figure here shows the 

14 total projected shipments under the base case by market 

15 segment. 

16 As we can see here, the replacement 

17 shipments on average accounted for about 80% of 

18 the total projected shipments as compared to the 

19 first time owners during our analysis period. Here 

20 is a comment box, DOE requests comment and 

21 information related to historical shipments data and 

22 market segment between residential users and 
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1 commercial users. DOE also welcomes comments related 

2 to standards case shipments projection. Any 

3 questions, comments so far? 

4 MR. BROOKMAN: Nothing here. 

5 MS. CHUN NI: Okay then I will move on to 

6 the National Impact Analysis. The purpose of the 

7 National Impact Analysis is to determine the national 

8 energy savings and national net present value over 30 

9 years of the analysis period from 2019 to 2048. DOE 

10 conducted the analysis by developing annual series 

11 of national energy and economic impacts. 

12 The analysis also used the shipments model 

13 as described before. DOE then aggregated all the costs 

14 and energy use in any given year and the reported 

15 estimates for the economic impact as change in 

16 consumer national net present value in constant year dollars.

17

18 DOE also used the discount rate to account 

19 for the time value of money. This is a flow chart of 

20 the National Impact Analysis. As you can see the 

21 analysis relies on the LCC and the shipments model to 

22 get all the numbers. It's basically taking all the 
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1 numbers from the LCC and the shipments and those 

2 numbers feed into the national impact analysis. 

3 The outputs of the analysis are the national 

4 energy savings and the national net present value. 

5 The analysis period is 30 years as mentioned. However, 

6 DOE did account for the national energy savings and 

7 economic impacts for all of those shipments in 30 years, as

8 far as their lifespan last. Therefore, the 

9 results go beyond the 2048. 

10 The flow chart here explains 

11 how the national energy savings analysis is 

12 implemented. As we can see here, the shipments 

13 analysis provides the base case annual energy 

14 consumption and the standards case annual energy 

15 consumption. The analysis period starts from 2019 and 

16 goes through 30 years to 2048. The annual energy 

17 consumptions are then summed together to provide a base 

18 case cumulative energy use and a standards case 

19 cumulative energy use. 

20 These two values, excuse me, these values 

21 are then converted from site to full fuel cycle energy by 

22 using some multipliers per OMB's guideline. The difference 
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1 between the base case and the standards case then 

2 provide us the national energy savings. The net 

3 present value -- the net present value follows a 

4 similar procedure. The inputs also come from the 

5 shipments analysis which provides the base case and 

6 the standards case projection. DOE then looked at 

7 the energy cost, the repair cost and 

8 equipment cost during the same analysis period. 

9 The cumulative operating cost savings are 

10 the differences between the base case and the 

11 standards case, and the same for the cumulative total 

12 equipment costs increase. Those values are then 

13 discounted to the present value. The difference 

14 between the cumulative operating cost savings and the 

15 cumulative total equipment cost increase then provides 

16 a net present value. Yes? 

17 MR. BROOKMAN: Yes, please Stefano? 

18 MR. VIT: I want to just underline that 

19 for the savings that are reiterated here are based 

20 on the worst 2% of the temperature that you have in the

21 cooling season. We are just repeating what we have 

22 said before. 
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1 MS. CHUN NI: Yes the results are 

2 calculated based on the test procedure and 

3 engineering data. Okay, the table here summarizes 

4 the shipments-weighted base case efficiency 

5 distribution in 2019. It was derived from the LCC and the 

6 payback period analysis. 

7 To project the base case efficiency trend, 

8 DOE referenced the previous rulemaking for room air 

9 conditioners. DOE assumed an annual increase in 

10 efficiency of 0.25% during the analysis period. For the 

11 standards case, DOE used a roll up scenario to roll up 

12 inefficient equipment to meet the standard level. 

13 The table here summarizes the inputs 

14 that the DOE used for the national impact 

15 analysis. These inputs have been discussed in 

16 the previous slides so I will move on to the next 

17 slide. 

18 The table here summarizes the national 

19 energy savings for each efficiency level or candidate 

20 standard level by users and we can see the national 

21 full fuel cycle energy savings for portable air 

22 conditioners are between 0.6 quads and 1 quads. The 
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1 table here summarizes a consumer net present value by 

2 discount rate. 

3 The range of NPV at 3% discount rate is 

4 between 4 billion and 6 billion. The range of NPV at 

5 7% discount rate is between 2 and 3 billion. Here is 

6 a comment box. DOE requests comments on the approach 

7 that the DOE took on the base case efficiency trend 

8 and the standards case efficiency trend analysis. Any 

9 questions, comments at this moment? 

10 MR. BROOKMAN: I see no comments here. 

11 MS. CHEN NI: Okay, then I will turn it 

12 over to my colleague. 

13 MS. DUNHAM: At this point in the 

14 presentation we are going to talk about what's coming 

15 down the road. So we presented a preliminary analysis, 

16 and the next phase of the rulemaking is the NOPR 

17 analysis. In the NOPR stage all of the categories of 

18 analyses that you see on the far right of the screen 

19 are incorporated into that overall standards 

20 rulemaking. 

21 Rather than look at things at just an 

22 efficiency level when there are multiple product classes. 
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1 Different product classes may have different 

2 efficiency levels considered for a standard and that 

3 would be called a trial standard level. Because 

4 portable air conditioners have just the one product 

5 class, it will be directly tied in with a particular 

6 efficiency level. 

7 You will see here some of the 

8 considerations taken in when developing particular 

9 trial standard level. We looked for the lowest 

10 lifecycle costs and payback period of under three 

11 years, among other issues, considerations. 

12 This is a request for comment on the 

13 criteria used to develop the trial standard level. 

14 So I am going to step through quite 

15 quickly the different analyses and just talk about 

16 their purpose and mostly their purpose and a little 

17 bit of their methodology. All of these analyses are 

18 covered in the technical support document as a 

19 preview, and then it will be covered in greater depth 

20 in the NOPR down the road. 

21 So in the LCC subgroup, in the consumer 

22 subgroup analysis, we look specifically at senior-only 
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1 and low-income households. DOE will rerun that 

2 lifecycle cost model for those two groups and see how 

3 the results there for those two specific consumer 

4 groups compared with the total 

5 population. So if people feel that DOE should look 

6 at other consumer groups in addition to these two, or 

7 instead of, please let us know by comment. 

8 So in the emissions analysis, DOE looks at 

9 emissions reductions from the proposed energy 

10 conservation standard. This includes both the power 

11 plant emissions and upstream emissions. In other 

12 words, the full fuel cycle. We will produce results 

13 using the time series of energy savings and employ 

14 the Energy Information Administration's National 

15 Energy Modeling System. 

16 To monetize emissions we used the most 

17 current social cost of carbon values that were 

18 developed and are updated by the Interagency process 

19 that is used in all of the DOE rules. Is there a 

20 request for comment? 

21 The utility impact analysis estimates the 

22 changes in the electric installed capacity and 
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1 generation resulting from the new standards. This is 

2 the same method used in the emissions analysis that 

3 is based on the time series of energy savings and 

4 uses the NEMS model. 

5 Comments are welcome. The employment 

6 impact analysis is here. In this particular analysis, 

7 we are looking at indirect employment impacts. The 

8 Manufacturer Impact Analysis looks at direct impacts 

9 for employment. This analysis uses ImSET, which 

10 shows the net labor or market impacts resulting from 

11 the standard. 

12 And finally, the Regulatory Impact Analysis 

13 addresses the potential for non-regulatory approaches 

14 to supplant or augment energy conservation standards 

15 in order to improve the energy efficiency or reduced 

16 energy consumption of portable air conditioners 

17 covered under this rulemaking. 

18 MR. BROOKMAN: So as we had said when we 

19 started the meeting this afternoon now is another 

20 opportunity for comment. Many additional issues that 

21 anybody wishes to bring to the table at this point, 

22 issues that haven't been covered sufficiently during 
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1 the course of the meeting. Okay seeing nothing 

2 additional at this point, Ron do you want to go over 

3 this final slide? 

4 MR. MAJETTE: In our correspondence, we 

5 refer to this rulemaking by and make sure you 

6 distinguish between the standard and the test 

7 procedure. For the most part, our team will catch it 

8 if you make a mistake and send it to the wrong 

9 location but we may lose it. All jokes aside, just 

10 make sure you correctly identify between a test 

11 procedure and a standard. 

12 Feel free to email any of us, either myself 

13 or to John. We cannot directly answer any of your 

14 questions because it wouldn't be fair to the rest of 

15 the manufacturers, so any of your general questions 

16 please email them to the Portable AC's email account 

17 and then that way we can share among all the 

18 entities. 

19 I guess in closing the only other thing I 

20 will say is thank you all for coming out. I 

21 appreciate your comments. I appreciate everybody 

22 that came from a short trip and a few from Italy that 
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1 made a short trip over here, as well as a few from 

2 Alexandria who made the long trip over here. So 

3 that's it. 

4 MR. BROOKMAN: Okay and a reminder that 

5 the comment period closes April 28th, 2015 and thanks 

6 to everyone joining us via the web. Safe travels to 

7 all, see you back here next time. 

8 (Concluded at 2:45 p.m.) 

9

10

11

12

13

14

15

16

17

18

19

20

21

22
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A

A&B 46:10

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25:10

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22:5,15 28:1

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absence 65:4

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78:18 79:6 86:16

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32:18 37:2,2

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Administration's

60:17 84:14

adopted 38:11 77:6

advance 10:14,20

11:2,2,3 12:11

AEO 76:20,22

Affairs 5:8

affect 6:14 11:22

afternoon 4:1,4,14

4:16 58:6 85:19

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agree 17:6 68:20

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21:9,19 25:18

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32:4,12 68:18,18

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40:14 64:14 76:9

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28:19 35:21 54:20

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32:1 33:2,5 44:2

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33:11 34:8 37:6

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73:22 75:2 77:2,3

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billion 82:4,4,5

bills 34:1,6

bit 13:10 23:9 24:20

54:22 62:19 69:16

83:17

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34:21 35:1 37:5

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29:4 30:18 46:20

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42:13 69:8,11,14

77:12 78:15

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44:14 51:8 84:22

chapter 5:18 20:2

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60:6 61:19 62:6

63:22,22 75:11

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58:12 73:12,14,14

73:14,21 74:17,17

74:18,18,18 78:5

81:1

circulation 8:16

circumstances 69:7

69:7

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72:16,18 83:5

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15:1 16:2,16 31:9

82:22 83:1

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57:6,6 67:3,3 69:3

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closely 17:18

closes 87:5

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clusters 42:4

coefficient 44:6

coefficients 44:4

45:14 46:6,11

collapsible 27:18,21

colleague 74:17

82:12

collect 21:12

collected 24:3

collection 23:18

collects 23:14

color 39:11

colors 41:22

combination 39:6

come 30:19 45:18

80:4

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comfortable 45:15

coming 36:12,16,20

44:12 82:14 86:20

comment 8:22

17:11 25:19 26:16

35:17 51:17 57:22

60:4 61:15 71:17

72:2 77:20,20

82:6 83:12 84:7

84:20 85:20 87:5

commenters 10:10

comments 5:10 7:1

9:6,19 10:17,18

12:22 17:1 19:20

25:6,7,20 26:18

34:10,15 35:17

51:18 52:22 56:20

58:5,12 60:4

61:16 62:4 66:20

67:7,15 69:20

71:18 72:3 74:15

78:1,3 82:6,9,10

85:5 86:21

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6:8 7:15 60:3,20

61:7 62:12,13,15

62:17,21,22 63:6

63:17 65:21 75:16

76:8 78:1

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companies 5:5 22:2

22:7,11,18,20

comparative 20:19

compare 64:17

68:19

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84:4

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competition 54:13

55:17 56:5

compiled 55:10

completed 30:17

component 24:15

37:14 39:20 42:4

components 18:21

23:6 34:2 51:14

56:17 77:2

compressor 18:4

23:7 32:20 34:20

35:5,6,8,13 37:16

compressors 35:10

concept 24:21

concern 12:9 67:6

67:21

concerned 56:4

57:10

concerning 67:8

concerns 11:1 55:20

56:9

Concluded 87:8

concludes 6:5

condensate 23:11

23:14,20 24:3

condenser 23:8

32:19 36:12,20,21

condition 38:13,19

conditioned 8:11

23:5,16 36:21

conditioner 6:19 8:9

8:10 16:6 23:2

60:18 64:16 68:14

71:16

conditioners 1:2 4:5

5:10 8:8 14:1,3

15:1 16:1 24:13

28:22 37:9 59:4

60:11,19 61:10

62:22 67:9,10,22

68:2,22 69:2 70:6

70:9 74:21 75:9

75:19,21 76:3

81:9,22 83:4

85:16

conditions 23:22

24:17 34:13,15,17

37:6 38:17

conducted 29:7
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78:10

conducting 13:20

conducts 28:20 65:9

configuration 6:2,4

15:2,4,20 19:2,11

25:1

configurations 15:7

29:4 31:4 40:17

43:14

confused 63:21

congratulating

53:21

conservation 4:6,9

7:10 14:1 54:8

84:10 85:14

consider 13:22

14:10 25:13,13,16

32:7 33:4 36:4

63:8,9 72:16

consideration 37:19

considerations 83:8

83:11

considered 5:16,22

32:2 63:11 83:2

considering 15:8

16:17 38:9 62:21

70:14

considers 14:16,19

27:4 75:8

consistent 16:14

constant 42:13 64:2

78:16

constrainment

25:10

Consultant 2:18

Consulting 13:15

consumer 8:8 15:10

15:21 17:8 27:22

56:6 58:21 59:1

59:11 64:12,20

65:3 66:2,3 70:17

71:5,12 78:16

82:1 83:21 84:3,6

consumers 27:10,15

28:20 59:7 65:13

69:6,8,11 70:18

71:8

consumption 41:4,8

60:17 61:11 79:14

79:15 85:16

consumptions 79:17

contacting 56:13

contains 23:3 28:6

73:22

content 7:3

continue 22:9 46:17

48:13

continued 3:1 7:15

48:10

continuing 48:8

contribution 38:7

controls 32:22

37:18

conversations 11:8

conversion 12:2

30:7 56:18

converted 79:21

cool 8:11 68:7 69:5

69:6

cooler 69:17

coolers 15:8 63:6

cooling 15:2 16:7,11

16:17 17:15,21

21:1 31:5,6 32:3,8

38:13 39:17,21

41:1,2,4,6 42:15

42:16 46:7,12,12

46:17,20 47:1,3,5

47:12,14 60:16

80:21

correct 9:12,13,22

10:1,6,7,11 18:19

31:13,18 73:1

correctly 86:10

correlation 15:19

17:14 44:5,19

45:14

correspondence

86:4

cost 28:16,18 30:2

33:17 34:3,9

50:19 51:2,4,18

52:6 58:4,14,15

58:17 59:16 60:9

64:10,12,21,22

65:2,3,7 66:1,6

70:18,19,21 72:16

76:13,22 77:11

80:7,7,8,9,14,15

84:2,17

costs 29:13 33:21

34:4,4,5,8 50:22

51:3,8 52:13,16

56:19 58:10,16,20

58:21 59:17,20,21

65:6,8 66:2,5,7,9

66:11,12,14,17,19

66:22 70:4,5,15

70:22 71:21 72:1

72:3 78:13 80:12

83:10

couple 40:12 68:16

course 22:17 27:11

57:8 86:1

cover 36:2

coverage 7:12,13

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11:19 14:3 66:3

66:21 83:18,19

85:17,22

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31:10,11 34:18,19

35:4,13,15 42:22

43:1,9 44:1,17

45:8 48:4,5,15

52:10,11,20 61:17

61:18,18,22 63:18

63:19

create 55:5

creating 33:22

criteria 83:13

cumulative 54:12

56:10 79:18,19

80:9,11,14,15

current 8:13 29:3

84:17

currently 4:18 8:2

20:13 71:14

curve 19:4,6,10,15

28:18 39:14 42:7

42:9 43:7 48:2,6

49:3,8

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43:2 44:18,19

45:11,11,20 46:17

46:18 47:8 49:2

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56:2

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21:17 26:1,2

47:17,19,20 63:4

67:18,19 69:15

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D.C 4:12

data 11:7,10,14,15

12:15 15:20 16:4

16:5,5 20:15,18

21:9 22:6 29:16

29:17,19 32:10

36:6,7 38:21 39:6

39:8,12,13 40:21

41:5,18,19,20,21

41:22 42:1,5,7,11

43:12,14,17 44:3

44:8,22 45:4,6,10

47:8 49:6,9 50:6

50:10,13 57:16

58:2 66:6 67:9,16

70:8,17 71:15

73:22 75:7,7,19

76:2,4,6,14,15

77:8,21 81:3

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December 9:4,11

decided 44:2

deciding 9:21 14:17

decisions 10:17 71:5

decrease 65:7

decreased 64:4

decreasing 37:3

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define 35:20

defined 19:15

defining 14:15

definition 8:5,7

degrees 68:12,15

dehumidifier 8:10

dehumidifiers 24:12

delivering 8:11

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Department 1:1,5

2:1 4:17 11:5,15

12:5,10,17 13:8

dependence 38:16

depending 66:7

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depth 83:19

derived 76:6,19

81:5

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described 78:13

design 25:11,14

28:11 30:12 34:11

34:13 35:17 36:3

36:15 40:16,20

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54:22 69:20

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details 25:19 67:15

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60:5 61:16 62:5

66:4

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29:10,22 30:2

45:22 70:5 78:7

determined 5:19 8:1

29:20 31:7 42:9

51:1 64:21 65:5

determines 27:1

develop 9:20 10:6

22:11 50:19,21

54:20 83:13

developed 37:8 39:6

55:2,8 59:8,12

76:12 77:4 84:18

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58:18

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diagram 31:11 45:9

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difference 60:12

79:22 80:13

differences 80:10

different 7:11 14:18

14:21 15:1,6 18:9

18:9,12,20,21

19:2 20:21 24:1

26:12 30:12 39:10

40:16,16 41:10,11

41:22 42:9 43:7

44:22 49:18,19

52:7,16 58:4 60:2

60:15 67:1 68:10

68:20 69:1 71:13

83:1,1,15

differently 52:3

difficult 57:12,14,16

difficulty 45:17

direct 15:13 28:5

54:13 59:17,20

85:8

direction 53:14,15

directly 83:5 86:13

disconnected 24:7

discount 66:12

70:15,20 71:2,4

78:18 82:2,3,5

discounted 80:13

discuss 4:22 69:15

discussed 6:10 15:5

32:17 81:15

discussing 67:5
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20:4,8,12,20

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34:7,10 36:4,6,9

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43:15,20,21 46:6

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51:5 53:22 55:2,6

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63:4,13 65:9,12

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76:1,3,6,7,11,15

76:20 77:4,20

78:1,9,13,18 79:6

80:6 81:8,9,11,14

82:6,7 84:1,5,8,19

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double 52:2 72:13

double-duct 72:22

73:5,7,8,9,18,19

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32:19 36:22 37:3

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58:7 61:20 62:2,6

62:18 63:2 64:6

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71:20 72:7,15,20

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earlier 46:16 48:20

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16:11 20:14 29:6

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16:19,20 17:12,15

17:17,22 18:13,13

19:1,7,12 28:14

28:17,18 30:1,2

30:10 31:6,21

32:16,21 33:4,8

33:10 34:9,14,20

34:20,21 35:2,7

35:20 36:2,5,8,8

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38:5 39:9,22 40:3

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41:15,20 42:2,5

42:14 43:22 44:14

45:7 46:9,21 48:1

49:1,18,20 50:20

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52:15 59:16,19,22

60:13,15 61:11,12

61:14 64:4,18,19

64:22 65:2 66:7

66:18 67:1 71:7

71:11,13,19 72:8

72:11,17 73:6,6

73:18,19,21 81:4

81:7,10,19 82:7,8

82:22 83:2,6

85:15

efficient 64:15,16

eggs 67:11

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either 15:16 16:2

23:20 33:6 65:13

67:13 71:13 75:9

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43:10

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84:11,16 85:2

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enclosed 8:12

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13:8,22 14:19

16:19,20 19:12

20:15 31:6 41:1

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60:16,22 61:1,2,3

61:6,13,15 62:4

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78:14 79:4,6,11

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79:21 80:2,7

81:19,21 84:9,13

84:14,15 85:3,14

85:15,16

engineered 29:10

engineering 14:7

18:19 19:18 27:2

28:4,8,10 32:1

33:5,19 50:19,21

55:11 58:19 60:14

73:15 81:3

entire 12:5 36:2

49:5

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EPCA 7:11,17,18

equal 71:9

equally 44:6

equation 16:18 61:3

equations 44:13

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equipment 34:4

64:16 80:8,12,15

81:12

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establishing 7:13

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estimate 54:9,17

60:11 75:1 76:22

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37:15,19,22

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express 61:5 70:4

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face 56:10

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24:22 32:19 37:2

48:8 51:10

sector 60:20 62:16

63:17 75:16,16

76:6,8,9

secured 53:10

security 53:9 59:8

see 12:16 13:11

18:16 19:7,9

20:22 25:15,15

35:16 38:12 39:16

40:12,18 42:20

43:6 49:4 50:6

51:6 52:3 57:22

60:7 61:4 73:10

77:16 78:20 79:12

81:20 82:10,18

83:7 84:2 87:7

seeing 49:6 86:1

seeks 56:20

seen 63:10,13

segment 39:18 56:1

77:15,22

selected 29:2 32:4

36:9

selection 30:8,16

selects 29:3

sell 59:6,6

selling 20:11 55:22

send 86:8

senior-only 83:22

sense 22:14 49:12

sensible 23:5

sensitivity 42:20

separate 16:16

18:21 31:9 34:7

40:19 42:4

separated 45:4

separating 15:22

16:1

separation 14:22

series 78:10 84:13

85:3

serious 6:11 10:22
The Portable Air Conditioners Standards Meeting

March 18, 2015

202-347-3700 Ace-Federal Reporters, Inc. 866-928-6509

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12:14

service 27:7

services 3:5 59:21

SESSION 4:1

set 40:19 44:19 46:6

68:12

sets 42:6

setting 14:9 65:21

share 72:5,8 76:5

86:17

shares 20:10

shifted 48:14

shifts 19:6

shipment 74:22

77:1

shipments 22:2

55:11 70:8 74:19

74:21 75:1,4,7,8

75:12,13,15,18,19

75:20 76:2,14

77:2,3,4,5,5,8,10

77:12,13,14,17,18

77:21 78:2,12,21

79:1,7,12 80:5

shipments-weight...

81:4

shipped 30:6

shop 53:16

short 86:22 87:1

show 21:2

showed 26:12,13

31:20

showing 48:20

71:21

shown 14:5 63:21

shows 17:14 20:9

60:1,21 61:10,13

62:6 64:1 66:10

75:11 77:13 85:10

side 23:9 60:8

significant 6:6

51:12,14

similar 24:11 41:14

42:12 67:12,12

68:6 80:4

simply 33:16

simulation 65:10,10

65:16

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single 8:12 16:1

17:5 19:10,15

31:3,7 39:11

73:22

single-duct 6:19

15:7,9,16 16:3

26:13 30:5 36:10

72:6,10,14,22

73:2,4,7,16,16

site 79:21

six 11:3

size 25:3 37:5,15,20

38:1 51:11 56:7

62:13

sizes 27:15

slide 7:4 12:21 21:7

26:12 44:10,13

48:20 49:5 51:4

60:1,8,21 61:4,10

61:13 66:10 70:3

74:4 81:17 86:3

slides 39:2 51:18

81:16

slightly 18:10

slinger 23:13

slopes 41:11,13

42:12,12

small 51:11 54:10

58:3

smaller 18:10

social 84:17

sold 20:7

solution 52:5

Solutions 2:3 4:13

soon 25:14 56:14

sorry 61:2 62:1,2

sorted 21:1

sounded 68:1

sounding 57:7

source 8:15

sources 61:8 75:7

77:8

space 8:12 23:5,17

32:3 36:21

speak 38:4 62:9

speaking 72:14

specific 5:11 7:14

33:8 50:10 66:22

67:4 68:22 72:21

84:3

specifically 58:10

66:21 83:22

specified 5:17

specify 68:21

spectrum 63:15

spot 15:8 63:6

squared 43:1,8

squirrely 48:6

stage 13:22 82:17

stakeholders 38:17

stand 24:8

standard 4:20 5:9

6:16 20:17,18,20

54:18 65:4,15

71:10 74:12 77:3

77:6 81:12,20

83:2,3,9,13 84:10

85:11 86:6,11

Standardization 5:8

standards 1:2 3:6

4:6,9 7:7,12,13

8:3,17 9:3,18,20

10:6,10,20 11:4

12:7 14:1 16:18

18:8 21:2 27:8

54:8 55:21 56:4

58:9 74:11 75:3

77:4,7,10,11 78:2

79:14,18 80:1,6

80:11 81:11 82:8

82:19 85:1,14

standby 32:21

37:18 60:16

start 4:15,20 41:11

43:17 53:20,21

started 13:9 50:8

85:19

starting 14:5 19:2

19:10 30:21 37:13

39:12 41:17 42:1

43:12,16 49:17

starts 79:15

statement 6:7 52:2

states 68:15

static 25:4

stay 34:22

Stefano 2:10 5:6,7

6:22 25:8 38:2,22

42:17 51:19,22

72:4 74:5 80:17

stems 11:4

step 7:21 17:16

18:17 19:7 26:20

35:19 40:11 50:18

59:2 83:14

steps 28:21

Steve 2:8

stock 76:15,21

store 28:1

straight 59:5

stress 6:1

strictly 34:8

strong 25:10

strongly 62:19

structure 14:9

structures 58:4

studies 61:5

study 5:17

stuff 53:10

sub 57:3

subgroup 54:20

83:21,22

subgroups 54:10

57:2 58:3

subject 14:10

submit 9:19

submitted 76:2

subsequent 14:9

28:19 35:21 46:9

substantial 6:16

substantially 37:20

subtracting 65:1

Subway 53:16

successfully 27:19

54:1

suffer 12:14

sufficient 33:7

67:17

sufficiently 85:22

suggest 15:18

suggests 40:4

suite 56:11

sum 58:15 60:22

66:1

summarizes 75:17

81:3,13,18 82:1

summary 45:21

summed 79:17

supplant 85:14

supplemented 36:6

supplementing 55:3

support 5:9,12 17:5

20:3 21:18 64:7

83:18

suppose 73:3

sure 21:3 23:1 53:6

74:2 86:5,10

surface 8:14 23:15

24:14

surprised 43:9

survey 35:10 59:10

70:17

surveys 60:17

SW 1:6

Swatkowski 62:8,10

62:11 63:1,3

system 23:4 84:15

T

table 31:20 46:10

75:17 81:3,13,18

82:1 85:21

take 60:22

taken 20:15 35:7

44:17 63:22 66:15

83:8

takes 12:6

talk 4:21 7:12 13:16

16:10 18:2 19:16

24:20 34:19 58:12

58:13 60:8 74:19

74:21 82:14 83:15

talked 23:9 62:14

talking 18:3 52:13

talks 7:11

target 55:3

tax 59:11,12

team 86:7

teardown 33:20

teardowns 15:14

32:14 33:12

tearing 33:21

tech 20:2 39:19

41:12 43:16 49:15

50:11 51:15

technical 5:11 20:3

64:7 83:18

technically 6:5 36:3

technological 14:13

technologically 6:17

27:5 36:3 37:12

technologies 14:13

24:11 28:13 29:11

33:15

technology 5:19,21

13:2,16 14:6,7

24:5,6,16 25:20

26:22 27:3,12,16

33:1 34:22 35:13

49:14

temperature 6:13

6:13 42:19,21

68:11 80:20

temperatures 37:6

tentatively 6:4 8:1

terminal 8:9

terms 15:4,9 20:4

21:1 23:10 27:22

30:9,19 32:8

35:22 44:18 54:15

60:5

test 4:7 6:3,11 7:9

8:3,6 9:9,10,16,19

9:21 10:5,11,13

10:19 11:1,11

12:3,5,10,19 15:5

16:12 17:14 19:16

20:20,20 21:10,14

22:10,13,16 24:1

29:8,18 30:20

31:11,16 33:9
The Portable Air Conditioners Standards Meeting

March 18, 2015

202-347-3700 Ace-Federal Reporters, Inc. 866-928-6509

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34:12,16 36:6,10

39:7,11 40:3

41:19 43:13,19

46:22 57:10,15,19

81:2 86:6,10

tested 11:21 19:8

30:7 32:5 39:13

40:15 46:19

testing 11:12,16

12:11 17:13 21:18

22:1,12,21 29:7

30:17 31:1 32:13

33:12 39:7 47:20

thank 5:1 6:22 10:2

10:8 12:20 13:12

13:13 17:4 25:16

25:17,22 32:12

35:15 38:22,22

52:20,21 63:3

69:21 74:6,13

86:20

thanks 17:9 87:5

thing 35:4 86:19

things 18:5 22:14

26:4 41:9 45:10

68:7,13 82:21

think 9:9,14 10:22

18:1,2 19:8,9

21:21 22:9,16

26:12 40:3,11,12

40:13 46:16 48:1

48:8 50:4,6,7,12

52:14 53:2,22

63:9 64:3 67:6,15

67:20 68:8,11,14

69:4,12 70:12

74:3,4

third 33:11 73:8

thought 63:19,21

thoughts 28:7 51:17

58:5 74:14

three 14:4 20:2,6

51:6 55:1 60:1

83:10

three-to-one 64:1

tied 13:8 17:18 83:5

time 8:4 9:19 11:16

11:19 12:6,6

13:14 15:8,22

21:11 26:17 27:8

64:14 69:9 72:9

75:10,14 76:16

77:19 78:19 84:13

85:3 87:7

timeline 8:17 12:21

13:1

times 63:13 69:16

today 4:11,21 5:1

7:7 8:21 17:1

21:22

today's 16:10

told 26:5

tool 37:8

tools 10:15 12:18

39:8

top 26:6 43:6 50:7

topic 7:7

tore 29:9

total 58:15,17 64:12

64:21 66:1 75:12

75:15,20 76:9,15

76:21 77:14,18

80:11,15 84:4

trade 59:10

transcript 68:4

transfer 24:14,15

31:2

transform 58:20

travels 87:6

treated 64:1

trend 42:8 81:7

82:7,8

trends 66:13,15

trial 83:3,9,13

tricky 39:4

tried 11:7 21:12

42:8 43:7,20

tries 45:19

trip 86:22 87:1,2

trouble 17:16 49:12

Troy 2:17 26:8,9,10

39:5 43:4,5 50:3

61:20

true 38:12 68:5 69:5

try 44:11 45:9 53:3

53:5

trying 12:1 18:11

22:1 40:3,8,21

48:22 49:7 63:14

TSD 5:18 28:6

turn 68:15 74:16

82:11

two 5:11 14:21 15:6

16:14 17:17 23:8

44:4 50:6,10

57:22 68:20 77:1

79:20 84:2,3,6

two-duct 74:1

type 14:19 21:9

types 26:13 43:7

60:2 62:22

typically 14:19 16:8

23:13 26:14 53:2

56:11

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U.S 1:1,5 13:7 20:7

20:11

UBMs 76:4

uncertainties 65:11

uncertainty 50:5

65:18

underline 25:9

42:18 51:20 52:1

80:18

underlined 62:19

undermine 6:15

understand 18:11

49:1 72:19

understanding 9:10

11:20 21:13 22:10

49:12

unique 19:10

unit 8:11 15:17 18:2

30:6,7 34:4 39:11

41:5,19,19 43:13

47:5 48:10 51:1,3

61:19 62:12,13

units 15:10 16:8

18:11,20 21:21

22:1 23:12 26:13

26:13 30:5 32:5,8

33:22 36:10 40:7

43:13,20 45:5

46:19 47:2,21,22

49:22 50:15 62:15

unmuted 62:9

unwarranted 6:7,12

updated 84:18

upstream 84:11

upward 39:14

upwards 19:6

urge 57:19

usage 23:22 67:12

use 6:12 7:19 20:17

22:19 28:2 37:10

44:4 46:22 60:10

60:11,15,18,22

61:2,3,6,13,15

62:4,11 63:13,15

67:22 68:2 69:6

69:17 70:15 71:6

71:8 78:14 79:18

79:19

user 76:5

users 77:22 78:1

81:20

uses 55:15 64:3

70:16 85:4,9

utility 15:10,21 17:8

27:10,22 56:6

84:21

V

valid 47:9

value 22:21 54:17

70:16,20 78:8,16

78:19 79:4 80:3,3

80:13,16 82:1

values 20:21 31:21

48:20,21 49:2,14

50:1,4 79:20,20

80:12 84:17

variabilities 65:12

variability 65:18

variable 24:17

34:12

variation 64:1

variety 40:15 43:14

various 16:20 24:6

28:19

vary 59:21 66:7,18

varying 34:14,16

versus 15:11 34:9

44:18 46:7 48:21

vertical 39:18

Vit 2:10 5:7,7 25:9

38:3,5,21 42:18

51:20 52:1 72:5

72:12,19,21 73:2

73:17 74:2,6,8,13

80:18

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want 12:16,16 13:6

18:3 19:22 20:14

24:18 25:9 36:4

38:8 46:1,4 57:8

80:18 86:2

wanted 21:8 41:2

warrant 15:22

Washington 1:7

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wasn't 21:11

watched 53:10

water 56:7

Watson 2:17 26:10

26:10 43:5,5,11

44:9,21 45:17

50:3,3 61:21

watt 35:8

way 17:21 24:1

25:11 40:22 44:22

45:18,22 53:17

68:1 86:17

ways 30:7

we'll 69:19

weak 6:6

wear 53:7

web 87:6

Wednesday 1:13

Weibull 70:6

weight 26:4

weights 26:11

welcome 5:1 13:10

85:5

welcomes 78:1

welcoming 4:15

went 64:4

weren't 22:5

wheel 23:13

wide 16:15 19:8

40:6 43:20

Wiley 3:4

willingness 22:11

wind 41:7,10

wish 26:16

wishes 85:21

wonder 52:3,12

words 77:5 84:12

work 12:17 14:8

22:14 58:7

working 5:15,20 6:8

27:19

worst 38:13 80:20

wouldn't 49:22

86:14

wound 32:10

written 25:20 26:17

67:7,15 69:20

wrong 72:14 86:8

Wuesthoft 69:22

X

Y

yards 53:14

yeah 26:11 70:13

year 7:20 9:4 65:5,8

69:9 70:21 78:14

78:16

years 6:21 70:10

72:1 78:9 79:5,7

79:16 83:11

yielding 70:22

Z
The Portable Air Conditioners Standards Meeting

March 18, 2015

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zero 42:3

0

0.17 76:16

0.25 81:10

0.6 81:22

1

1 36:14 37:1 38:6

49:5 51:7 53:1

55:2,10 72:12

73:6,18,21 81:22

1% 76:9

10 53:1 70:10

10% 37:22 75:20

10,000 65:17

10.5 35:8

100 7:20 26:14,15

53:14

100% 36:13

1000 1:6

101 74:4

102 48:21

106 51:19

107 51:19 52:12

10K 59:9

11:54 1:14 4:2

126 61:19 62:3

63:22,22 64:1

127 62:2 64:3

128-2001 20:18

14,000 52:14 62:15

17 30:5

18 1:13 4:11

18th 8:22

1975 7:11

1st 9:5

2

2 36:17 38:6 49:5

51:7 53:6 55:8

72:1,12 73:6,19

73:21 82:5

2% 38:10,13 80:20

2:45 87:8

2010 76:4

2012 76:4

2013 8:1,19 76:18

2014 76:21,22

2015 1:13 4:11 8:21

9:1,4,11 87:5

2016 9:6

2019 72:9 74:8 78:9

79:15 81:5

2048 76:18 78:9

79:9,16

20585 1:7

24 30:4

25 6:21

25% 36:18 42:3

73:7

25th 8:6

27th 8:20

28 9:1

28th 87:5

29 20:9

3

3 5:14 36:18 37:1,13

38:6 51:7,15 52:2

55:14 72:13 82:5

3% 82:3

3,000 40:7

30 78:8 79:5,7,16

30-year 75:1

30% 73:19

31 9:4,11

4

4 5:18 28:6 37:12

40:6 47:6 48:1

49:2,3,6,7,8 50:16

51:12 72:13 82:4

45 53:3,5,17 54:1

5

5 8:19 53:6

5% 73:5

5,000 52:14 62:17

50 26:14,14,15

50% 36:15,16 42:2

73:5,18

5th 7:22

6

6 82:4

7

7 30:5 48:22 49:7

50:16 64:7

7% 82:5

7.5 48:22

70 68:12,15

77 7:4

79 12:21

8

80% 77:17

861 66:15

8E-089 1:8

9

9,000 40:7

90% 72:5,6,8,9 73:2

73:4,16

95 38:9 68:12

98 34:19

99% 76:8
100 

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