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 DEPARTMENT OF ENERGY

 APPLIANCE STANDARDS AND RULEMAKING

 FEDERAL ADVISORY COMMITTEE MEETING

 Department of Energy

 1000 Independence Avenue, S.W.

 Forrestal Building

 Washington, D.C.

 Thursday, August 1, 2013

 8:10 a.m.

Reported by: Christine Allen,

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1 A P P E A R A N C E S

2 FACILITATOR:

3 Neil Eisner, Navigant Consulting

4

5 PARTICIPANTS:

6 Karim Amrane, Air-Conditioning, Heating, and

7 Refrigeration Institute (AHRI)

8 Ashley Armstrong, U.S. Department of Energy

9 Timothy Ballo, EarthJustice

10 Laura Barhydt, U.S. Department of Energy

11 Jeff Bauman, National Refrigeration & Air-Conditioning

12 John Cymbalsky, U.S. Department of Energy

13 Mary Dane, Traulsen

14 Laura Degitz, Navigant

15 Paul L. Doppel, Mitsubishi Electric US, Inc.

16 Mark Fly, AAON Heating & Cooling Products

17 Geoffrey M. Halley, Sji Consultants, Inc.

18 Charles Hon, True Manufacturing

19 Jill Hootman, Trane

20 Marshall Hunt, Pacific Gas and Electric Company

21 John Hurst, Hex Technologies, Inc.

22 Diane Jakobs, Rheem Manufacturing Co.
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1 PARTICIPANTS:

2 Tom Johnson, Daikin McQuay

3 Jeff Kleiss, Lochinvar

4 Michael Kojak, Underwriters Laboratories LLC

5 Karen Meyers, Rheem Manufacturing Co.

6 Peter Molvie, Cleaver-Brooks Product Development

7 Frank Myers, PVI Industries, Inc.

8 Michael Rivest, Navigant

9 Harvey Sachs, American Council for an Energy-Efficient

10 Economy

11 Ronald Shebik, Hussmann Corporation

12 Frank Stanonik, Air-Conditioning, Heating, and

13 Refrigeration Institute (AHRI)

14 Louis Starr, Northwest Energy Efficiency Alliance

15 Mike Stem, Intertek

16 Phillip Stephens, Heat Transfer Products

17 Rusty Tharp, Goodman Manufacturing

18 Bill Tritsis, AHRI

19 Corey Tucker, Navigant

20 Collin Weber, Navigant

21 Robert J. Whitwell, Carrier Corporation

22 Wes Wostal, ClimateMaster
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1 P R O C E E D I N G S

2 (8:10 a.m.)

3 MR. EISNER: Let's get started. Apparently

4 John forgot to get the rest of you the dress code for

5 today.

6 All right. Okay, we want to talk some more

7 about scheduling the effective or implementation date.

8 Any suggestions from the meeting last night?

9 MR. THARP: This is Rusty Tharp with Goodman,

10 and I'm happy to report that we have -- are in the

11 process of making agreements for a scheduled roll out

12 over time and we'll start with, if your company name

13 begins with MI, it's two months.

14 MR. BAUMAN: Reverse alphabetical.

15 MR. THARP: Seriously, though, varying from

16 six months to 18 months, by product category, they'll

17 roll it out and we would like to ask for another week

18 to discuss and finalize amongst the members which

19 products would be which timeframe, but it would be 6

20 months, 9 months, 12 months, 15 months, and 18 months.

21 And the effective date would be from the

22 issue date of the AEDM final rule as long as there were
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1 no changes to the other certification information that

2 we agree here. If there is changes in the final issue

3 of the certification agreement, then we would want it

4 to be from that date.

5 MR. SACHS: Can you repeat the effective

6 date, please?

7 MR. THARP: The effective date would be based

8 on the final rule of the AEDM unless something changed

9 in the certification over what we agree, and then we

10 want it to be based on the final rule issue of the

11 certification.

12 MR. EISNER: Okay. Any questions?

13 MS. BARHYDT: And you think we'll have enough

14 time between now and the next meeting to iron out which

15 products? And I'm not pressuring that you need to, I'm

16 just asking because you mentioned a week, so since

17 we're meeting in a week, I was just wondering.

18 MS. MEYERS: We'll have to see. This is

19 Karen with Rheem. We have all agreement of the

20 companies in this room --

21 MR. AMRANE: Right.

22 MS. MEYERS: -- the proposal, but we have
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1 not had a chance to reach out to the other companies.

2 MR. AMRANE: This is Karim with AHRI. I

3 mean, we will have, you know, again maybe by next week

4 -- we will try, but I don't want to commit to next week

5 because we have a much larger group.

6 MR. CYMBALSKY: And so this idea takes away

7 what was talked about at the end with this grace period

8 concept. So, this is hard six-month, hard 12-month,

9 hard 15-month. Is that right?

10 MR. AMRANE: Yes, this is what it is.

11 MR. THARP: Yeah, and Mark just reminded me

12 that we'd ask for a six-month grace period.

13 MS. BARHYDT: For each one individually? So,

14 six months after the cert's due?

15 MR. THARP: Yes. From everything.

16 MR. EISNER: And --

17 MR. THARP: And if you want to extend it to

18 six years, that's okay.

19 MR. EISNER: In terms of changes to the final

20 rule that might be made, do you have any plans in terms

21 of whether you want to reconvene the advisory

22 committee? I think that was mentioned, but not clearly
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1 in the rulemaking documents.

2 MS. BARHYDT: I think what we said was that

3 this committee would want to reconvene if there were

4 going to be changes, but that that would be contingent

5 on the ASRAC agreeing to our -- getting to have that

6 second say, but assuming ASRAC's okay with it, we

7 certainly have no qualms about meeting again if it

8 looks like we're going to have to make changes to the

9 final rule.

10 MR. EISNER: What this generally means, and

11 we talked about this at the very first meeting of this

12 group, is that generally the agency would prepare a

13 summary of the comments to the docket. They would be

14 circulated to everybody and then there'd be a decision

15 as to whether there needed to be a meeting or it could

16 be done via conference calls or emails to decide

17 whether or not to reconvene the group to decide whether

18 any changes should be made or whether everybody feels

19 that no changes are necessary.

20 So, any changes that would be made would be

21 made after review and consideration by this group.

22 does everybody understand that? So, you won't be
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1 surprised by it, you'd participate in the process.

2 Okay, any further questions? And if they

3 can't get everything ready by next week, are you

4 comfortable with this being an issue at the final

5 meeting at the end of August?

6 MS. BARHYDT: That's fine.

7 MR. EISNER: You discussed that?

8 MS. BARHYDT: If we can get a timeframe

9 that's really going to work and meet everybody's needs,

10 then absolutely.

11 MR. EISNER: Okay. All right. Ready for

12 verification?

13 MR. WHITWELL: Sorry, this is Bob Whitwell,

14 one more question. So, Laura, right now the CCE rule

15 goes into effect January 1, 2014. So, between --

16 before then, you expect that we will have -- that DOE

17 will issue a revised rule -- the revised rule that will

18 change that effective date?

19 MS. BARHYDT: Yeah, so if we get to a

20 resolution here and we have a complete package to send

21 to the ASRAC, DOE will do whatever rulemaking we have

22 to do in order to deal with that date.
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1 MR. WHITWELL: Okay, thanks.

2 MR. AMRANE: Karim with AHRI. And if we

3 don't have a deal?

4 MS. BARHYDT: Then the date stands.

5 MR. AMRANE: With no AEDM, nothing in place?

6 MS. BARHYDT: We've got to reach a deal,

7 folks.

8 MR. BAUMAN: The nuclear option.

9 MS. BARHYDT: Okay, would you like to explain

10 what it is that you have -- we have a proposal for a

11 verification program and some terms and I haven't seen

12 this and I don't know if any of you have either, so

13 we'll just see what we've got here.

14 MR. MYERS: This is Frank Myers, PVI. This

15 is not meant to be anything other than a framework for

16 discussion. I believe it has all of the pieces that we

17 need, but I'm sure there's some back up and support and

18 definitions that would be required.

19 The fundamental issue is that when we're

20 talking about verification testing, testing based on

21 selecting something where we would cover all basic

22 models, have to be tested during some period of time,
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1 most manufacturers or certainly many manufacturers have

2 hundreds, if not thousands, of basic models so it's

3 intractable to be able to test all of those.

4 So, this uses -- if you'd scroll down to the

5 bottom -- a product family concept, and the definition

6 of product family is basically every manufacturer

7 groups their products for sale into product families or

8 into groups, whatever they say it is, but basically if

9 you have an electric water heater with certain

10 characteristics, it would be a family, because that's

11 the way it's promoted, that's the way it's advertised,

12 or any of the other covered products would be grouped

13 into product families.

14 So, the selection would be from a product

15 family, is what's being proposed in this -- if you'd

16 scroll back up to the top -- with that definition in

17 mind, there's not a lot of difference between the first

18 two methods for selection of what products to be

19 verified, but if you are using an AEDM, it basically

20 says that if a manufacturer utilizes more than five --

21 which means, if you don't, you don't have to do this --

22 if you have more than five AEDMs to qualify equipment
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1 efficiency, then you randomly divide all AEDMs into

2 five groups. Make it simple, if you had 15 AEDMs,

3 you'd have five groups of three, so then you select a

4 different AEDM if you have five or less, or AEDM group,

5 if you have more than five, and each year -- my eyes

6 are blurring, excuse me -- select -- oh, thank you --

7 select a representative basic model for verification

8 testing from each product family that's covered by

9 number two, either the AEDM or AEDM group, and after

10 you have rotated through all AEDMs, then you repeat the

11 process.

12 What that means is obviously if you have

13 five, then you do one each year, or five groups, you do

14 those groups each year, and then every product family

15 that's covered by the AEDM has to be tested within that

16 five- year period.

17 If you only have one or two, then you rotate

18 through -- you never stop. If you have two AEDMs, then

19 after two years you would start back over with the

20 first AEDM and then the second. So, you're constantly

21 testing through on a rotating basis, no more than five

22 years, where every product family has a representative
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1 basic model that is tested.

2 And then if you don't use an AEDM, it's

3 essentially the same thing except you can divide your

4 product families into five or less, if you have less

5 than five, groups and you have to test a representative

6 model of all of those product families at least every

7 five years. And DOE -- the manufacturer would make

8 that selection, but that would be reported to DOE and

9 DOE can say, nope, test this basic model instead.

10 So, whatever -- that keeps it flowing better

11 so that we're not waiting on DOE for all of these

12 pieces of information, but if DOE chooses, they can

13 direct every test that's conducted, so it doesn't stop

14 DOE from being able to say, oh, you manufacture, I want

15 you to test this one this year, that one, that one, you

16 can still substitute within this framework.

17 And if you'd scroll on down, if a basic --

18 and this is really for manufacturers that are build-to19 order, if the product that is selected can't be

20 negotiated during that 12-month period with DOE to

21 select another representative or what I call an

22 alternate basic model, then the world doesn't stop, it
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1 just means you cannot -- as a manufacturer, you cannot

2 ship for any use other than testing -- for the

3 verification testing, a unit until the successful

4 verification and compliance testing is concluded.

5 So, if a manufacturer has a product that they

6 might not build for seven years, but they're still

7 promoting it, what this says if that one was one that

8 was selected, it cannot be shipped -- it can be built,

9 but it cannot be shipped for anything other than

10 testing until that testing is successfully concluded.

11 And the last part is, who can conduct the

12 testing. Again, thinking about a manufacturer,

13 particularly when you get to build-to-order, you can't

14 block out a month to make arrangements for a test lab

15 to come in, so it really needs to be -- there needs to

16 be an avenue by which the manufacturer can conduct the

17 test. So, there, for verification testing, can be

18 conducted by DOE, it can be done by a DOE-approved

19 verification program, like, for example, the AHRI

20 certification program, an independent third-party

21 laboratory accredited to ISO 17025, or the

22 manufacturer, if the manufacturer's laboratory and its
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1 test personnel are found to be compliant with and is

2 subject to the continuing review and monitoring program

3 required to conduct testing acceptable to an

4 independent third-party laboratory accredit to ISO

5 17025. That's the best accreditation a manufacturer's

6 facility can get, 17025 does not allow a manufacturer

7 to certify their facility for testing their products.

8 That's one of the tenants of 17025 is that there has to

9 be some level of independence.

10 But a 17025 lab -- UL, Intertek -- all have

11 programs where they can verify -- and it's a continuing

12 annual or sometimes more often review, you have to set

13 up training programs and conduct investigations each

14 year. In our case, it's a two- to three-day

15 investigation every year to verify that all of our

16 systems are in place, and if you do that, we are

17 extended the opportunity to provide test data without

18 witnessing to that 17025 lab.

19 So, that's what I'm proposing in number four.

20 If you have that accreditation, then you're allowed to

21 conduct the test yourself. So, that's the proposal.

22 MS. BARHYDT: Thank you. That has a lot of
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1 really good ideas in it. I think you've presented a

2 lot of things for us to talk about.

3 MR. MYERS: Sure.

4 MS. BARHYDT: I actually want to take one

5 step higher and so I think we'll come back --

6 MR. MYERS: Okay.

7 MS. BARHYDT: -- to the information you have

8 here and I want to start out with talking about -- DOE

9 already does assessment testing and we've heard that

10 manufacturers have concerns about the transparency of

11 what we do, or they don't understand what we do. And

12 so, where I'd like to start is when DOE does

13 verification testing, what is it that you want to see

14 that will answer the questions that you have about what

15 we do right now that we can put into the regs that will

16 make the process more clear to everyone?

17 So, with that in mind, go ahead and go down

18 to the next slide. So, how much should we be testing?

19 What is the -- should it be based on basic models?

20 Should it be based on the groupings of basic models?

21 Now that we have a better idea of what exactly DOE

22 considers to be a basic model, that may change your
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1 calculus of what you think it is a reasonable amount to

2 test each year.

3 So, those are some of the things we'd like to

4 talk about. How should models be selected for testing?

5 Should it be random? Should there be some provision

6 for challenge testing? Should there be targeting?

7 That's a whole other area that we'd like to talk about.

8 Process for low volume products. How should

9 we coordinate with the manufacturer with production

10 schedules? Should production be monitored for

11 compliance to the model design specifications to make

12 sure that the units being tested are not specially made

13 for tests, that kind of thing?

14 So, we would like to engage with you about

15 what it is you would like to see in a DOE verification

16 program and then we'll go from there to what you would

17 like to see in terms of DOE recognizing third-party

18 testing programs. And a good starting point might be

19 from what we talked about with the AEDM and when DOE

20 does testing and how we compare that to ratings from

21 AEDMs.

22 I mean, there's a lot of ways we could go
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1 about this. Or if everybody just wants to say, well,

2 we already agreed to the way we do the AEDM program.

3 Just, if you have any thoughts before we --

4 MR. MYERS: This is Frank Myers, PVI. When

5 you say the testing that we agreed to on the AEDM

6 program, are you talking about DOE's testing?

7 MS. BARHYDT: Yes, so we could use that as a

8 model, because we talked about how DOE would select

9 things, we talked about how things would be tested,

10 where they would be tested. I mean, we talked about a

11 lot of these same issues in the context of AEDM where

12 DOE does verification of AEDM testing of units rated by

13 AEDMs.

14 MR. MYERS: Right, this is Frank Myers, PVI

15 again. I don't think that that's a reasonable model

16 for continued verification testing. I understand the

17 need for that when DOE wants to bear down and do

18 everything independent and then take that manufacturer

19 to the mat if need be. I understand the need for the

20 level of independence that is maintained in that

21 program.

22 We had a lot of discussion about that and we
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1 all know the parts that we don't embrace, but

2 understand. With this, we're talking about a lot of

3 testing and testing that has to fit within a

4 manufacturer's production and delivery capabilities,

5 providing free equipment that goes away somewhere and

6 is tested would be financially ruinous for a lot of

7 companies. So, this needs to be something that we can

8 get a lot of information out to DOE and to the

9 advocates and to our competitors that they can look at

10 and scrutinize.

11 And then we have both the DOE's more

12 independent test program available should it be needed,

13 as well as Challenge Testing, particularly a Challenge

14 Test within VICPs, and we could set up something

15 outside of a VICP for Challenge Testing.

16 MR. FLY: Mark Fly with AAON. If DOE runs a

17 verification testing program, I'm concerned that you

18 have a budget, I assume, and you have all this testing

19 to do, you know, can you fund, if we pick so many

20 units, who pays for that? Is that something that the

21 manufacturers would have to pay for the testing to --

22 as part of the verification? And can you run that
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1 through your program? Is that allowed? Or -- because,

2 you know, as we do this and we look at -- we don't want

3 to give an unfair advantage -- I understand not giving

4 an unfair advantage to people who belong to a voluntary

5 certification program, but I don't want to give an

6 unfair disadvantage to people that do that because we

7 spend a lot of money testing that equipment.

8 So, I would like to see anything that's

9 independent outside that program to be at least

10 reasonably close in scale so that we have equal

11 verification with both groups.

12 So, can you speak to how you fund, if we

13 decide we're going to do, you know, 5 percent of our

14 basic models, or we do a grouping and we do, you know,

15 20 percent so that we catch it every year, or whatever

16 the math works out, how does that get funded? And can

17 DOE afford to do that for everybody who's outside a

18 voluntary program?

19 MR. HURST: I would like to add to that

20 before you answer. Maybe it would be helpful if you

21 gave kind of a macro overview, not only of the funding,

22 but the breadth. Because, I think, John, you mentioned
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1 a number a while back and then you cover a number of

2 product classes outside of what we're even talking

3 about, and I think as a manufacturer another concern

4 would be if the funding goes up or down or away over

5 time, how that would impact the program.

6 So, just some macro thoughts on how the

7 program is maybe funded and administered.

8 MR. CYMBALSKY: So, for funding, you know, my

9 budget is given to me as one number and it applies to

10 both codes and standards currently. With that said,

11 obviously meeting our legislative deadlines for

12 standards and test procedures comes first. So,

13 whatever we're doing in that space, that's -- depending

14 if the funding goes up or down -- that's kind of the

15 sacred part of the budget.

16 Lately, you know, the budget hasn't been an

17 issue for any of that and we've been able to add new

18 products and we've been able to also do the

19 verification, both for Energy Star and Certification

20 and Enforcement. So, the budget currently is about $5

21 million for that activity. So, in the future, if the

22 budget gets to a critically low point, I could say,
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1 what will be saved is meeting the statutory deadlines

2 that are imposed on the program.

3 Other than that, I really can't say much

4 more.

5 MR. HURST: Thank you.

6 MS. BARHYDT: So, given that, DOE is very

7 interested in coming up with a scheme that will make

8 sure all manufacturers are treated equally in terms of

9 not disadvantaging people who are running -- who are

10 participating in a voluntary certification program.

11 So, what DOE is looking at is requiring some level of

12 verification testing across the board, and whether that

13 is done through a program run by DOE, a program run by

14 a manufacturer, or a program run by a lab, program run

15 by an industry group, whatever that mechanism is,

16 requires some level of verification testing and that

17 there would be some level of controls and oversight by

18 the Department to make sure that everybody is running a

19 fair program and that everybody is being treated the

20 same.

21 And so, that's really where we're looking to

22 go with this, is that there would be verification
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1 testing for everyone and that way everybody is on the

2 same playing field.

3 MR. THARP: Rusty Tharp with Goodman. I'd

4 like to suggest that the way it might be handled is

5 that DOE would publish minimum requirements for any

6 verification program, and that if an industry

7 certification program, VICP, were to meet those

8 requirements, then DOE would do no testing, would

9 accept that as the verification. For manufacturers not

10 part of VICP, they would have to participate with DOE

11 or another organization for meeting those minimum

12 requirements of verification.

13 So, I think what we ought to discuss is what

14 those minimum requirements for verification are.

15 MS. BARHYDT: Exactly.

16 MR. AMRANE: This is Karim with AHRI. So,

17 you're planning to do what EPA is currently doing for

18 its Energy Star program?

19 MS. BARHYDT: Can you explain what Energy

20 Star is doing? Because I don't know enough about it.

21 MR. AMRANE: Energy Star has a verification

22 program and has recognized what they call certification
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1 bodies who are doing the testing for manufacturers, and

2 AHRI is part of it, but DOL is also part of the

3 program.

4 So, there is already something in place that

5 EPA is doing. Again, there's some concern with what

6 EPA is doing in terms of burden to manufacturers and

7 because does not totally mimic what industry is doing

8 and maybe that's something we'll have to work out with

9 EPA in the future, but at least there's a starting

10 place where you could look and maybe we can start off

11 that and see whether it's something that we would all

12 agree to.

13 MR. HON: This is Charlie Hon. There is more

14 than one program involved here. Number one is Energy

15 Star program. Number two is certification to

16 NRCanada's regulations. There are different reasons

17 for different programs. Energy Star is only the more

18 efficient pieces of equipment. At this time they're

19 requiring approximately 10 percent of the products

20 listed under Energy Star to be tested every year.

21 That is an issue because Energy Star test

22 standard testing is not potentially what we're agreeing
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1 to here at this time because they define everything on

2 all possible power consuming items built in and on, and

3 that's a question that we haven't verified yet.

4 So, that can be a problem. The

5 certifications are done by the same basic laboratories

6 for NRCanada, those certifications are to the standards

7 -- the test standards that we're applying today under

8 the Energy Star program, but it has far less -- you're

9 testing units that may or may not be Energy Star

10 approvable. So, you have a broader spectrum of

11 products available to you.

12 And, again, they're running between 7 and 10

13 percent of the total unit base. And, again, NRCanada

14 has everything on, so we have some questions, number

15 one in test procedure, number two, and because some of

16 the industry groups do not have the same level of

17 review or they allow for much broader grouping. Energy

18 Star says, okay, you have 60 products listed. We're

19 going to test six this year. There's no question about

20 it. It's no base models. Everything is a tested unit,

21 submitted to Energy Star, and then verification tested

22 over a period of years. And they will pull out of
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1 groups so that you don't let one group just fall by the

2 wayside.

3 So, they will look at different groupings,

4 not necessarily the DOE groupings, but different

5 groupings that have some industry understanding, and

6 they will pull from those groups representative samples

7 and say, well, we haven't tested anything from this

8 group for a while, so we'll go over there.

9 They will dictate which units get tested, not

10 the manufacturer. It can be a different approach, and

11 we may end up with conflict in the future if we're not

12 careful how we clarify our issues of accessories.

13 MR. STANONIK: Frank Stanonik, AHRI. Two

14 comments. Going back to some of your prefacing

15 comments, Laura, I think that certainly the regulation

16 needs to clearly describe assessment testing, because

17 right now, in fact, what's on the books, you have

18 certification, you have enforcement, and at least in

19 terms of what's written there, enforcement doesn't

20 really describe the interim point of assessment

21 testing.

22 And, by the way, that's not a criticism. You
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1 know, I think you found out what we have known for a

2 long time, that, you know, in balancing looking at a

3 lot of models and what's available to you in terms of

4 resources, assessment testing, let's say you call it a

5 first cut, makes a lot of sense. But I think it needs

6 to be clearly spelled out in the regulations.

7 The other issue I want to talk about is

8 Energy Star, and I certainly appreciate it's very

9 important to the commercial refrigeration

10 manufacturers, but we're talking about commercial

11 products, okay. There aren't that many Energy Star

12 programs for commercial products. I mean, there's some.

13 They have requirements and we're here because, in fact,

14 effectively there's really nothing that everyone's

15 agreed to between the manufacturers of DOE and everyone

16 else, and as far as certification and verification

17 enforcement for commercial products. So, there's a

18 void, if you will, okay?

19 I think that we should keep -- one of the

20 objectives should be that whatever comes out of here,

21 in fact, should be developed and looked at to --

22 insofar as efficiency metrics that are governed by DOE,
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1 it should replace Energy Star's verification

2 certification requirements.

3 You know, letters have flown back from AHRI

4 for a long time. The business of certification and

5 enforcement of efficiency ratings covered by federal

6 regulations should be the business of DOE, and if we

7 can write something that we can give the EPA and say,

8 you don't need to do anything else, that should be part

9 of this objective.

10 UNIDENTIFIED SPEAKER: That is something we

11 can all agree on.

12 MR. BAUMAN: This is Jeff Bauman from

13 National Refrigeration. As you -- again, with

14 commercial refrigeration, we have a lot of experience

15 with the EPA and the requirements they had, and as

16 Charlie said, the 10 percent retesting. There's some

17 very significant things to keep in mind there that when

18 that was being developed, there was a lot of push back

19 from industry and a lot of companies became involved

20 across the board with the National Association for Food

21 Equipment Manufacturers, and even having said all that,

22 understanding that Energy Star is an optional program.
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1 You can be in it, and some manufacturers don't, but

2 even the manufacturers that wanted to be in it, the

3 burden -- everything I'm hearing here, and I can't

4 imagine that with your $5 million, John, you're going

5 to able to really do an effective -- you know, that DOE

6 is necessarily going to be able to pay for all that

7 with the level that I think we all would really want.

8 So, I think there's going to be -- it sounds

9 like there's going to be some burden on manufacturers

10 to supply equipment or to pay for testing, or whatever,

11 so that's obviously something we have to keep in mind.

12 But there was -- again, I think in this case,

13 I can talk for a lot more people than those in this

14 room as far as experiences with EPA is the burden is

15 hugely significant even at 10 percent of products being

16 retested.

17 The other thing to keep in mind, too, in the

18 experience that we've had so far with being in that

19 verification program for a couple years is the third20 party labs have had a lot of difficulty understanding,

21 keeping up with, managing that testing, and I've had

22 experience on the Energy Star side and on -- with the
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1 AHRI program, so the burden on the labs, they're out

2 there, is a significant part of this and their ability

3 to keep up with it.

4 MR. KLEISS: Jeff Kleiss, Lochinvar. I just

5 want to make sure that I understand what we're actually

6 talking about in terms of verification. Is this

7 intended to be for people that are not participating in

8 a voluntary certification program would then have to

9 have their products verified by DOE before they could

10 put them on the market and then as an ongoing program?

11 MS. BARHYDT: No. So, that would be a

12 significant difference from what I understand about

13 Energy Star, is that now, to get something Energy Star

14 listed, it has to be verified before it can be sold as

15 Energy Star, and we're not talking about that.

16 We're talking about, on an ongoing basis,

17 some percentage of models being sold are being

18 verification tested, but not any kind of prior to sale.

19 MR. KLEISS: Okay, then based on -- or, in

20 response to that then, how is what you're asking -- how

21 is the verification program that you're asking for some

22 guidance and response on, how is that different from
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1 what action DOE is already in the process of doing as

2 far as testing manufacturer's equipment?

3 MS. BARHYDT: So, the difference is that it

4 would be a regulatory requirement to participate in

5 some kind of verification testing like what AHRI does.

6 It would impose a requirement to have some kind of

7 verification testing done. So, it would be a new

8 requirement for verification testing, and then who

9 actually is doing that testing may vary. If somebody

10 didn't participate in a plan at all, they would be

11 subject to DOE. If they were in an industry run

12 program, that would be in lieu of DOE testing. If they

13 were running their own program that had been approved

14 by DOE, that would be another option, if the labs

15 wanted to run one and they wanted to participate in

16 that, but the idea is that everybody would be subjected

17 to some level of verification testing.

18 MR. KOJAK: This is Mike Kojak with UL. I've

19 got a question. When it's a one-off manufacturer that

20 makes custom equipment and you're asking the percentage

21 of basic models to test per year, if everyone is a

22 basic model, how would that affect them if they're
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1 making one of a kinds all the time?

2 MS. BARHYDT: So, they're still going to have

3 to certify it. So, they're going to be grouping them

4 somehow. I mean, there should be the ability to still

5 identify what the basic models are.

6 MR. HON: This is Charlie Hon. I have some

7 very big concerns about your terminology there because

8 it could be very different if you interpret it

9 different ways.

10 MS. BARHYDT: Okay.

11 MR. HON: The basic model can be nothing more

12 than a product and we can have a basic model, which is

13 a particular size unit. We could also have that same

14 basic unit with a different lighting system, which the

15 customer wants, which makes it a lot -- it consumes

16 more energy. But it is still that basic unit with add17 on features, which then consume more energy, but we

18 don't want to list the truly basic model as a de-rated

19 product because of a much more demanding customer.

20 So, do they then become two basic models?

21 MS. BARHYDT: So, so --

22 MR. HON: Because they're going to be listed
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1 separately.

2 MS. BARHYDT: I think you're raising a very

3 important issue and I think that that's something we're

4 probably going to spend a considerable amount of time

5 talking about. I'm not saying that basic model is the

6 right metric for us to use. I'm throwing that out just

7 because it's a term that now we all understand what

8 that means, but I'm not saying that it has to be a

9 percent of a basic model. All I'm saying is that we

10 would like to see some level of verification testing

11 across the board, and how we're actually going to get

12 to that point and what the regulations circumscribing

13 that would be, is what we want to talk about.

14 And so, I mean, definitely that's one of the

15 details we're going to have to figure out.

16 MR. AMRANE: This is Karim with AHRI. And

17 that's why, I mean, a long time ago AHRI found out

18 about it and that's why we created this basic model

19 group.

20 MS. BARHYDT: Right.

21 MR. AMRANE: Just to reduce the number

22 testing burden on manufacturers. So, there is a
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1 solution, of course you'll have to work out the

2 details.

3 MR. BALLO: On the idea of product families

4 that I think Frank raised earlier, I don't have a

5 problem with that sort of grouping of basic models. It

6 would be a concern to me if we were solely looking to

7 the manufacturer literature, because that can change

8 and be sort of unclear. What I think might be helpful

9 is maybe if, at the time of certification, the

10 manufacturer indicates which product family the basic

11 model belongs to so that it's clear for everyone to see

12 when it should be tested.

13 MR. FLY: This is Mark Fly with AAON. I'm

14 just going to throw a few things out there. You know,

15 the number of models or the number of -- I mean, the

16 number of basic models is not necessarily reflective of

17 the volume or sales volume of any company. I'm not --

18 I don't have a solution, I'm just throwing things on

19 the table. So, you know, going off the number of

20 models is not equitable across the board to the number

21 of products that are out being sold.

22 So, you know, I don't know how to handle
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1 that. We really are not handling that any better or any

2 worse in AHRI today, so if you want to be in AHRI and

3 you're a small business and you have lots of model, you

4 do probably a bigger percent, you spend a bigger

5 percentage of your revenue on testing than someone who

6 sells a few models but sells a whole lot of them.

7 So, I don't know if that figures in there.

8 Our definition that we've been working on for three

9 months on basic models is somewhere between where we

10 started and the basic model group that AHRI has. We've

11 pulled some things in, but we've pulled a lot of -- but

12 there still are a lot of differences, and one of the

13 things I talked to Karim yesterday about was, you know,

14 just as a I think AHRI could probably figure out -- I'm

15 sure he doesn't have it on the top of his head, but we

16 could look at the number of AHRI listings versus the

17 number of AHRI model groups and see what it is.

18 I suspect it's somewhere between 5:1 and

19 10:1. And I think the number of models listed in the

20 AHRI program is fairly close to what we're going to end

21 up with, maybe a little bit lower because we've had a

22 few things in our copper coils and some other things
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1 that I think deviated from what AHRI has been talking

2 about in the past. So, I think that number would be

3 good to have before we finish this, and maybe we could

4 have that next week.

5 And then I'd just like everybody's opinion.

6 Do we want to try to make this proportional to sales

7 somehow? Or do we want to try to keep it proportional

8 to the number of models offered? I don't have an

9 answer.

10 MR. THARP: Rusty Tharp with Goodman. I

11 would suggest that we wouldn't base it off of sales

12 because reporting information -- of course, with the

13 AHRI program it's anywhere from 20 to 33 percent, one14 fifth to one- third of your basic models every year

15 that are audited.

16 MS. MEYERS: Basic model groups.

17 MR. THARP: Basic model groups that are

18 audited every year.

19 MR. HON: This is Charlie Hon. Is it possible

20 to have an alternate for the small manufacturers or not

21 necessarily saying, okay, well, we have 40 different

22 basic model groups, but we only sell 1,200 products a
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1 year, and that's a very, very arduous percentage for a

2 small manufacturer. We certainly don't fall in that

3 category, we have a broad spectrum, but we sell a lot

4 of equipment.

5 But could it be an option for that small

6 manufacturer as a possible way to avoid some of the

7 burden to be willing to voluntarily submit their total

8 sales and then have a percentage of units out of their

9 total sales tested as an alternate? But that would be

10 their choice to do it or they could stay with the base

11 model numbers like everyone else is working with.

12 MS. BARHYDT: We could do it that way or we

13 could also use the small business rules that if you

14 qualify as a small business, there's a different

15 threshold. I mean, there's a lot of ways to get there.

16 MS. MEYERS: Is it -- we've kind of come up

17 with a definition for basic models for certification.

18 Is it possible to come up with another definition for

19 verification, like a basic model group?

20 MS. BARHYDT: The product family concept?

21 Yeah, sure.

22 MR. MYERS: This is Frank Myers. We're a
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1 very small company with a very large product line and

2 what I had proposed in the program would cause us to

3 test at least one of every -- and we have a lot of

4 product families, to test at least one of those every

5 five years. That's a lot of testing for us. But we can

6 do that, spread out even with our number of basic model

7 families that something as long as we can do it as a

8 part, because we're also build-to-order. We have no

9 inventory. We can't afford to build things just for

10 tests, so the proposal that I had made embedded in that

11 is our ability to take a few days, and a customer has

12 ordered a product, but before we ship the product we

13 have to conduct the verification test on it.

14 If we can have a program that allows us to do

15 that, then we can test at least one basic model of

16 every product family we have, at least every five

17 years. That's very similar to -- except for the

18 difference in product family versus basic model group -

19 - that's very similar to the testing requirements for

20 the AHRI program.

21 So, that was one reason that I looked at

22 that, but the key here is our ability to do that as a
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1 part of our normal take an order, build, and then add

2 in a small slice for tests, then ship, because the

3 customers, you know, they're paying for that product,

4 they want it as quickly as they can get it, so we have

5 to minimize that disruption.

6 If we can do that, then we can run that

7 number of tests.

8 MR. KLEISS: Jeff Kleiss, Lochinvar. One of

9 the problems with this is that we're looking at a rule

10 that would apply to our 80,000 BTU per hour

11 instantaneous hot water heaters that have no options,

12 variations, they're prepackaged, and stacked five high

13 and ten deep on our shelves. And talking about

14 applying the same criteria for selection and

15 verification for highly customized, extremely expensive

16 equipment, is there some way that we can differentiate

17 products? Within the AHRI program there's the Certify

18 All Rule. There are some exemptions from that Certify

19 All Rule recognizing those difficulties of producing

20 product simply for the business of verification.

21 So, I don't have a suggestion at this, but

22 I'm just proposing this as an idea that there might
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1 need to be different classes of product that should

2 have different thresholds for verification.

3 MS. BARHYDT: So, in DOE's regs right now, in

4 the enforcement context, there's already a distinction

5 between high volume and low volume build-to-order, and

6 so certainly we've already drawn some of those lines in

7 our regs and we could follow those guidelines already.

8 As to if it's something that's stacked up in

9 boxes, then it's high volume, and if it's built to

10 order or if it's very, very low volume, then have a

11 different threshold for testing, but I think DOE would

12 like to see all of it in the pool somewhere so that low

13 volume stuff isn't not getting verification tested.

14 MR. FLY: This is Mark Fly with AAON, I'm

15 talking way too much today. The other issue that we're

16 going to have to face as we look at verification

17 testing, and it relates back to some of the others, as

18 we've expanded the scope of some of these product

19 categories, there's not necessarily laboratories that

20 are capable, available today, that can test all of --

21 evap condensing -- some of the very large unit does not

22 fit in any of the existing chambers. That may get
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1 rectified in the next two or three years, but --

2 MS. BARHYDT: Including the manufacturer?

3 The manufacturer doesn't have the facilities either?

4 MR. FLY: I don't think the manufacturer has

5 the facilities either.

6 MS. BARHYDT: Okay.

7 MR. STEPHENS: Phillips Stephens, HTP.

8 Harvey, you're going to love this, I hope. I think

9 something else we need to recognize is the difference

10 in standard production products and innovative products

11 and technologies. They typically don't fit -- it's a

12 round peg trying to go into a square hole. They just

13 don't fit sometimes.

14 So, having to have something innovative to

15 fit the same structure as something high volume,

16 standard production, is a burden to bringing innovative

17 products into a marketplace.

18 MR. SACHS: Phillip, this is Harvey, and if I

19 understand the question, it would be a product such as

20 an integrated, fully condensing water heater boiler

21 combination, for which we do not have a test procedure

22 that's adequate today. And it seems to me that we've -
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1 - and I'm looking for reactions -- we've had a waiver

2 process, which was used for VRF for a while, it's been

3 used for a lot of things, and it seems to have worked

4 okay. If it hasn't, I need to be reeducated and DOE

5 needs to be beat up, and I wonder if we can use the

6 waiver process for things that we really just don't

7 have an adequate test procedure for. And that's one

8 example of innovation.

9 MR. STEPHENS: Phillip Stephens, HTP. That

10 may be as simple as we need to make it, as long as the

11 manufacturers would have assurance that the waiver

12 process would apply to the annual verification methods

13 as well as the method of test for it.

14 MR. SACHS: Harvey Sachs. ACEEE, to the best

15 of my knowledge, has opposed exactly one waiver since

16 2001, that waiver request was for a category of "space

17 constrained" residential air conditioners. That's the

18 only thing that -- these are split systems -- that's

19 the only thing that we have ever felt warranted any

20 kind of opposition, but we may have missed some we

21 should have opposed.

22 This is Harvey. Let me add to that that as a
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1 general observation, if something is innovative,

2 efficient, and doesn't look like it's going to have

3 high volume, it doesn't have substantial effect on

4 national energy savings. If it's not affecting the

5 credibility of the certification programs, we have no

6 reason to oppose it. Tim may, but we don't.

7 MR. DOPPEL: Paul Doppel, Mitsubishi. The

8 waiver process is good, and having had a lot of

9 experience with it the only problem that we had was the

10 length of time that it took for waivers, and I know DOE

11 has made efforts to shorten the time, but, you know,

12 this could possibly bring many, many new waivers, so

13 DOE would have to kind of gear up for that.

14 I mean, we -- I think our first waiver, we

15 waited a year and a half, but I know it's better than

16 that now.

17 MS. BARHYDT: Okay, just so long as we're

18 clear that it is much, much better than that now.

19 MR. SACHS: This is Harvey again. I have

20 enormous sympathy for the issues that Paul faced, but

21 this was a case where there was a lot of uncertainty

22 among other manufacturers about how these products
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1 would play competitively. There were a lot of basic

2 understandings and it really is, in some senses, it's

3 an advanced product that wasn't innovative because of

4 the global experience, it wasn't something where --

5 we're looking at something that had not been marketed

6 before.

7 So, DOE may have been inefficient, but I

8 don't think all of your competitors in the HVAC

9 industry were bending over backwards to help that go

10 fast.

11 (Off record discussion.)

12 MS. BARHYDT: So, I've heard that people are

13 concerned about making sure that we recognize the

14 difference between low volume and high volume, the

15 difference between small manufacturers and larger

16 manufacturers, and what the right metric is for how to

17 decide how much should be tested in any given year.

18 Going back to the -- what I started with in a

19 DOE program, we've heard that there's a lot of

20 confusion about what DOE currently does, and so we also

21 want to make sure that we address that in a process

22 that everybody understands and so that expectations are
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1 clear in terms of when DOE does testing.

2 MS. MEYERS: Say that again.

3 MS. BARHYDT: So, to the extent that any of

4 you have concerns about how DOE does assessment testing

5 right now, or believes that there is a lack of clarity,

6 please state what your concerns are so that we can

7 maybe address some of those.

8 MR. WHITWELL: What is the process?

9 MS. BARHYDT: So, DOE goes out and we buy

10 things and we test them in accordance with the DOE test

11 procedure, and that is under 10 CFR 429.104, which is

12 entitled "Assessment Testing" and we look at the

13 results, and based on those results, we either say,

14 great, good to go, and that's the end of it, or we

15 notify the manufacturer and we proceed under Section

16 110 and proceed with the enforcement testing process,

17 which is laid out in the regs.

18 MR. EISNER: How do you determine which

19 product to test?

20 MS. BARHYDT: We just buy things.

21 MR. THARP: How do you select which models

22 you're going to test? Is there some criteria that you
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1 use? Is it absolutely random?

2 MS. BARHYDT: No, I mean, it really is. We

3 go out and we say, hmm, let's try this one, we haven't

4 tested one of these lately. Except for we previously

5 hadn't done hardly any testing at all, so that's really

6 easy. So, you know, realistically, it's -- we don't

7 have a long history of testing, so for us, we just pick

8 things. It's not based on we want to target this

9 manufacturer or this type of product or this industry,

10 it's -- we just go buy things that we haven't tested

11 before.

12 We do a lot of testing in support of our

13 rulemakings and all of that we look at to make sure

14 that the product meets the standards. Whenever the

15 ratings are really far off, we usually send a letter to

16 the manufacturer telling them that, hey, by the way, we

17 tested this thing and it's nowhere near your rating,

18 but that's the extent of what we've been doing there.

19 MR. SACHS: Laura, this is Harvey, and I have

20 two concerns, relative, particularly to the term

21 targeted. One of them is, in general, I think given

22 the modest budget available and the large spectrum of
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1 products, the Department should avail itself of a good

2 "ear to the ground." There always are rumors about

3 who's --

4 MS. BARHYDT: Yes, we do testing where we

5 receive complaints, always.

6 MR. SACHS: I think that's an important thing

7 to have clear to those at this table. The second

8 concern I have about targeting is the question of who

9 is -- whether DOE is buying these products. I can

10 certainly conceive of an administration, which decides

11 that some manufacturer is an enemy for some reason and

12 really wants to put inordinate pressure on it,

13 including financial pressure. And, as a

14 generalization, for which there may be exceptions, I

15 would be concerned about the DOE subpoenaing a unit

16 instead of buying it.

17 MR. MYERS: Excuse me, this is Frank Myers.

18 Could you repeat that last bit? You're concerned about

19 DOE subpoenaing and then I didn't hear the rest.

20 MR. SACHS: This is Harvey again. I would be

21 concerned about a process that allowed DOE to demand

22 that a unit be provided of some specification that
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1 perhaps might not even be sellable, and provide it to

2 DOE at no cost, because that would open the possibility

3 of abuse of the regulatory process. This is the

4 libertarian side of me.

5 MS. BARHYDT: So, assessment testing, DOE

6 buys the units, in enforcement testing, the

7 manufacturer is required to provide the units, and

8 that's in the statute.

9 MR. EISNER: When you say you select a

10 product, first you said, you know, you just select

11 anything, and then you said it does depend on

12 complaints. Several complaints? One complaint? From

13 particular companies? From customers?

14 MS. BARHYDT: So we do the random selection

15 and we just pick things.

16 MR. EISNER: Who is the "we"? John?

17 MS. BARHYDT: He has the money.

18 MR. EISNER: Okay.

19 MS. BARHYDT: So, there's the random

20 selection, but we also have a policy of investigating

21 all complaints. So, if somebody makes a complaint, we

22 will go buy a unit and we will test it.
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1 MR. EISNER: Just one person?

2 MS. BARHYDT: Just one person.

3 MR. EISNER: So, even if a competitor is

4 trying to get you to check another company, you'll just

5 do it because they asked?

6 MS. BARHYDT: Sure. And I guaranty you, the

7 competitors then complain about the other one and we

8 buy one of the other ones. So, everybody makes money

9 off the deal.

10 UNIDENTIFIED SPEAKER: Can we talk during the

11 break?

12 MS. MEYERS: This is Karen with Rheem. So,

13 is it possible that -- or is there a process -- this

14 random selection, is it made at the beginning of the

15 year so that, you know -- and it's not so -- if it

16 could be at least a little bit more transparent between

17 the manufacturer and DOE, hey, heads up, you know,

18 you've been selected to have one of these units tested

19 sometime this year.

20 So, I mean, you're obviously managing a

21 budget, you're doing this random selection. Seems like

22 it would be helpful -- I mean, we kind of -- you know,
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1 so that, you know, just -- you know, just not trying to

2 hide anything or anything, just, you know, these units

3 have been selected by DOE or this unit or this basic

4 model group, however we decide -- this product family

5 will have a unit tested by DOE in the year 2013.

6 MR. CYMBALSKY: So we're going to go -- what

7 we do is a pop quiz. We don't do midterm exams here.

8 So, we said this before, and I think Mike had the

9 analogy correct, if I'm the food critic and I'm telling

10 you I'm coming to the restaurant, you know, that steak

11 is going to be darn good, I'm sure.

12 So, the random -- I think it's twice a year

13 we sit down and we pick a bunch of batches, I would

14 say, pretty much randomly. Not so much your products,

15 but in home appliances there's cycles when things hit

16 the market, so that comes into play, so like room air

17 conditioners generally come out for sale in the late

18 winter, early springtime.

19 So, maybe it will be weighted more towards

20 products like that. So, there are some cycles in the

21 course of the year where more product is available for

22 us to pick off the shelf.
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1 So, that comes into our thinking. For Energy

2 Star it's a little different because we've had more

3 years of experience in that verification program. And

4 we've seen patterns in Energy Star by product, and

5 those reports are on the web, you can see it yourself

6 as well.

7 But otherwise it is, there's no -- it's not

8 like, let's go pick on Charley's products this month.

9 I mean, we don't -- you know, when she said that I was

10 thinking, oh, no, here we go.

11 MR. HURST: John when you say patterns --

12 this is John Hurst with Lennox -- what patterns do you

13 mean? Are you talking sales patterns or patterns that

14 you see in testing.

15 MR. CYMBALSKY: Patterns in the products,

16 like for Energy Star, and this is not enforcement

17 testing, we've seen certain products fail Energy Star

18 more frequently than others. We've seen brands fail

19 more frequently than others. We see the way they're

20 rated, how they rate them, be more susceptible to

21 failing than others. You know, logical things that

22 we've learned through the process. It's -- and again,
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1 since this is pretty new, we don't have a long track

2 record of coming up with a really good process by which

3 we can do more tailored.

4 So, in the beginning it's going to be

5 completely random because we don't have any experience

6 at all. So, I think that's kind of where we're at.

7 MR. KLEISS: Is there any weighting based on

8 the expectation of power consumption within that --

9 MR. CYMBALSKY: Like how much the unit would

10 use versus --

11 MR. KLEISS: Or rather, as an example, there

12 are about 9:1 volume of furnaces versus boilers for

13 home heating.

14 MR. CYMBALSKY: Right.

15 MR. KLEISS: So, is your sampling --

16 MR. CYMBALSKY: We focus more on the furnaces

17 because they're more prevalently sold. Probably that's

18 true. I mean, there's more available to pick from.

19 So, other important factors -- so, Laura said, I think

20 this is important and may have been missed, that we

21 purchase a lot of things just to test for our standards

22 process, so let's say we're doing a CRE rule. We'll go
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1 out and buy the spectrum, just to do tear-downs with,

2 but before we tear it down, we do a test to see what it

3 rates out at.

4 So, we're learning a lot that way, too.

5 We're getting -- one test is giving us a lot of

6 information for both the rulemakings, the test

7 procedure, and the assessment. So, you know, we're

8 trying to do these things in a smart way to have the

9 money stretch as far as possible.

10 MR. BALLO: This is Tim Ballo. I'm trying to

11 get a sense of to what extent you're essentially

12 running a challenge testing program with DOE funds

13 rather than the manufacturer's funds, and so what

14 portion of when you say you get a complaint from

15 someone you start looking at that product? How much

16 of those or what percentage of those complaints come

17 from manufacturers? What percent come from

18 dissatisfied customers of the product?

19 MS. BARHYDT: Ninety percent come from

20 manufacturers. But that testing makes up a very small

21 proportion of the overall testing that we're doing. I

22 mean, realistically, we don't get that many complaints.
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1 And I think that some of that may reflect the fact that

2 the process takes a very long time, and so some people

3 have made complaints, I know, think that it takes way

4 too long for us to get to the end of the process, but

5 there is a real need, and I'm sure you would all agree

6 with this, for the manufacturer to get due process.

7 And so, we do take a long time going through

8 the process and make sure we get to the right result at

9 the end. And so, I think that if people saw their

10 complaints bear fruit more frequently, we might get

11 more complaints, but the process takes a really long

12 time.

13 MR. EISNER: Do manufacturers provide you

14 with just their understanding there's been a failure,

15 or have they tested it and supplied you --

16 MS. BARHYDT: Usually the manufacturer

17 provides us with their own test data.

18 MR. EISNER: Of this other product?

19 MS. BARHYDT: Of the other product.

20 MR. FLY: Mark Fly with AAON. So, on the

21 other verification programs you have, you have no

22 sampling rate that we've been talking about here, there
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1 is not -- you don't test some percentage of the basic

2 models? That's totally random --

3 MS. BARHYDT: No.

4 MR. FLY: -- so, it is not a continuous,

5 broad- based verification program?

6 MS. BARHYDT: No.

7 MR. MYERS: This is Frank Myers, PVI. That

8 really brings out -- the question that was just asked

9 brings out the concern I have, and I suspect others

10 have, that enforcement should be something consistently

11 done that doesn't depend on funding or that sort of

12 thing -- I'm sorry, I said enforcement, testing, the

13 continuing testing that we're talking about shouldn't

14 depend on DOE funding or timelines, that should be a

15 regular process that goes through a manufacturer's

16 product families either through a VICP or directly,

17 where that continues on and is required through the

18 regulation to be delivered year after year after year.

19 MS. BARHYDT: We agree.

20 MR. MYERS: And the DOE testing seems best

21 suited for the enforcement/challenge that you just

22 described as opposed to the continuing testing.
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1 MR. BAUMAN: This is Jeff Bauman from

2 National. I guess one of the things, and I've been

3 thinking a lot about that, Frank, is, you know, again,

4 having some experience on the -- and with DOE we kind

5 of have the extreme now of random and the manufacturer

6 may or might go years or if ever having tested a

7 product to a 10 percent of all manufacturer's products

8 or 30 percent, which is very burdensome.

9 Almost -- I'm trying to think about the

10 minimum, but across the board evenly, is if you took --

11 every manufacturer had to test one product every year

12 for DOE. I mean, would DOE even be able to fund that

13 program? Or, you know, because that's your bare, bare

14 minimum where across the board, everybody would be

15 subject to it.

16 MS. BARHYDT: So, what we're looking at with

17 the verification program would be the manufacturer18 funded testing, not the DOE funded testing.

19 MR. BAUMAN: Okay, and that's -- and even, I

20 think, for some companies having one product tested a

21 year would be -- that they're paying for, is going to

22 be very burdensome. You know, there's product
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1 categories that aren't so -- you know, it's not so much

2 with CRE, some may be, but I know large boilers and

3 things, you know, you'd want a manufacturer to have to

4 verify something every year, and even that level would

5 be burdensome.

6 MR. KLEISS: Jeff Kleiss, Lochinvar. As

7 we've been talking about this and challenge tests and

8 we're talking about verification, one of the things

9 that has leapt out in my mind, and we're also talking

10 about voluntary certification programs and comparing

11 those to what we might recommend for DOE to apply, or

12 for limits for other VICPs, there is a huge difference

13 between what we're talking about for product

14 verification for DOE and what AHRI does, at least in

15 the product classes that I'm involved with.

16 And that being related to challenge testing,

17 there are tolerances. And when there are challenges

18 made, those tolerances provide a significant amount of

19 grace.

20 When we certify products in our VICP with

21 AHRI, first we have to qualify the products we test and

22 we cannot claim anything higher than the average
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1 efficiency of our qualification tests, and then there

2 are -- or submittal --

3 MS. BARHYDT: Wait, before you go on, can you

4 explain that?

5 MR. KLEISS: For example, when we're

6 submitting a new boiler for listing in the AHRI

7 program, we have to run at least two tests on that

8 model that we're submitting and we cannot claim to them

9 any higher efficiency than the average of those two

10 tests for publication.

11 Then, AHRI has a third-party test of our

12 product with a tighter tolerance than what we do for

13 verification, and we have to pass that test with that

14 tighter tolerance before we can list our product on the

15 AHRI directory.

16 That is a huge step, I think, of tighter

17 control and that qualification process creates a much

18 higher threshold for the claims of efficiency than what

19 we're talking about with a verification program. And

20 there's a significant up front expense for those

21 participants in that VICP. I think that's something

22 for us to bear in mind when we're comparing what we're
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1 talking about for DOE programs versus what's going on

2 with AHRI.

3 MS. BARHYDT: That's for all models? Or

4 whenever you have a new model group?

5 MR. KLEISS: That's the introduction of the

6 new product or if we were going to try and increase the

7 rating of a product we would have to go through that

8 same process.

9 MS. BARHYDT: Okay.

10 MR. STANONIK: Frank Stanonik with AHRI.

11 Jeff, you've got to be careful with your terminology.

12 Everything you described is not verification. That is

13 certification. And what we're trying to figure out

14 here is verification. All the processes you described

15 for the program are for listing a model, that's

16 certification, and that really doesn't -- is not really

17 what would be done for subsequent verification testing

18 in the AHRI program, so, I mean -- and it is, to a

19 large extent, in fact, follows federal regulations. We

20 actually want to make sure they're following federal

21 regulations. Imagine that.

22 But anyhow, that's not verification, and the
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1 subject here is really verification or what we're

2 trying to sort out is what might be verification.

3 MR. EISNER: What does certification mean?

4 When you put it on your site saying, this has been

5 certified, what do you mean by certified?

6 MR. STANONIK: Well, it's entering -- let me

7 talk about a new model, because it's easier, although

8 we're actually talking about programs that are

9 overlaying a market that's existed for a long time,

10 right, but for a new model, first of all, the federal

11 regulation is that you have to have the ratings

12 certified, you have to have a certified rating before

13 you can introduce the commerce.

14 So, we essentially are, in our certification

15 programs, pretty much doing the same thing. We have to

16 have -- the manufacturer has to tell us, here is the

17 rating for this new model, here's test data that

18 supports the rating, and as Jeff was saying, in certain

19 cases we do a qualification test, in essence to kind of

20 make -- I'll say to be comfortable that the test was

21 done properly, and then we list the model. And then,

22 in theory, the manufacturer is free to -- and that
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1 information, by the way, now is set up so it also is

2 delivered to DOE, so there's that next, almost

3 simultaneous step, it gets delivered to DOE, and now

4 the manufacturer can sell the product in commerce.

5 But what I was trying to make the point is,

6 okay, so we're past that point and let's say a year

7 later our folks make a -- say, we're going to select a

8 production unit of this model that was entered last

9 year and we're going to test it to verify that it

10 continues to have the same rating that was claimed.

11 That's where the verification comes in.

12 MR. EISNER: And how do you determine which

13 ones to do verification testing?

14 MR. STANONIK: Well, Bill can talk to that,

15 but basically, I mean, we have a staff that -- we have

16 some general guidelines in terms of, let's say, cycling

17 through a full manufacturer's listing in three, four,

18 five years or something of that nature, and then we

19 have other factors by which we determine which ones we

20 will test in a given year.

21 You know, it's random, but not totally

22 random.
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1 MR. EISNER: Do you get complaints?

2 MR. STANONIK: Pardon me?

3 MR. EISNER: Do you get complaints from

4 others that lead to verification testing?

5 MR. STANONIK: We have a challenge process,

6 absolutely, both open both to participants and non7 participants, yeah.

8 MR. HURST: This is John Hurst from Lennox.

9 The other thing we get is we do get an advance

10 notification of what we're going to be -- it's not the

11 pop quiz, I guess, it's the midterm, and the reason

12 it's valuable to a manufacturer is we can plan our

13 production. It's not that we, you know, all run back

14 and figure out how we're going to get that equipment up

15 to standard, that's not the case, but you know, it is

16 somewhat of a pain because they do randomly select, and

17 sometimes it's high volume, it's easy to do, sometimes

18 it's rather custom, and we like to fit it in to the

19 production cycle where we're not jumping through hoops

20 to make a specific unit for the verification testing.

21 MR. STEPHENS: Phillip Stephens, HTP. I'd

22 like a clarification, if possible, because I seem to
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1 have possibly misunderstood what was said earlier. For

2 the verification testing, who does the Department

3 expect to cover the cost of the products and the

4 testing?

5 MS. BARHYDT: Manufacturers. It would be a

6 new regulatory requirement and we recognize that there

7 would be burden associated with that.

8 MR. STEPHENS: And then the same for any

9 enforcement activities?

10 MS. BARHYDT: So, for enforcement, the

11 manufacturer is required to provide units, but DOE pays

12 for the testing.

13 MR. WHITWELL: Bob Whitwell, Carrier. So,

14 how does verification testing differ from assessment

15 testing?

16 MS. BARHYDT: They're the same thing.

17 MR. WHITWELL: So, the regs currently say --

18 MS. BARHYDT: It's a spot check.

19 MR. WHITWELL: -- assessment testing, the

20 Department buys the equipment?

21 MS. BARHYDT: Yes. Assessment testing and

22 verification testing are a spot check, enforcement
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1 testing is different.

2 MR. STANONIK: Laura -- Frank Stanonik, AHI -

3 - but Laura, I think you maybe inadvertently misspoke

4 because --

5 MS. BARHYDT: Okay.

6 MR. STANONIK: -- you indicated that the

7 intent would be that there would be, in the

8 regulations, verification requirements applicable to

9 every manufacturer, but then, in addition to that, DOE

10 would still continue to do assessment testing on their

11 dollar.

12 MS. BARHYDT: So, what we would like to do is

13 get to a point where everybody is having verification

14 testing and that could be -- and so, let me make clear,

15 the question I was answering was, what is happening

16 right now? DOE pays for assessment testing and we buy

17 the units.

18 MR. STANONIK: Right.

19 MS. BARHYDT: What we would like to do is get

20 to a point where there is verification testing across

21 the industry and manufacturers pay for the testing, but

22 the manufacturers can meet this regulatory requirement
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1 either through a third-party industry association

2 testing, through lab testing, through their own

3 manufacturer-run program, through a DOE-run program.

4 The DOE-run program would still be manufacturer paid

5 for, but DOE would help administer some of the

6 technical parts of it.

7 MR. STANONIK: And in that future objective,

8 would there still be any assessment testing, and I mean

9 that different than enforcement testing?

10 MS. BARHYDT: No, our notion -- so, somewhat.

11 MR. STANONIK: Minimal.

12 MS. BARHYDT: So, there would still be

13 assessment testing in as much as DOE would still do

14 testing in support of its rulemakings, we would still

15 do assessment tests where we received a complaint, so

16 we would, but it would not be the same kind of random

17 testing that we're doing right now. We would stop

18 that.

19 MR. STANONIK: Okay, so -- Frank Stanonik,

20 AHRI -- so then let's say that would progress to that -

21 - okay, DOE could and may -- let's say would do

22 enforcement testing, but that would be the full bore,
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1 you know, testing of multiple samples with statistical

2 analysis, blah, blah, blah.

3 MS. BARHYDT: Right. And that's never a spot

4 check.

5 MR. STANONIK: Right. Right. Okay.

6 MR. FLY: Mark Fly with AAON. You know,

7 looking at the AHRI program today, before we can enter

8 a program, a certification program, we kind of have to

9 pre-approve, you know, there's a preapproval process,

10 we have to basically pretest the first year's sample

11 products and pass those tests before we're accepted

12 into the program, at least in some of the programs, the

13 ones that I'm familiar with.

14 If DOE administers this or we have these

15 other programs, and basically you've kind of got that

16 first year for free if you introduce -- if you're new

17 to the process and you really don't know what your

18 numbers are and maybe you have some tests that will

19 validate your AEDM, but you have to ask for it first,

20 so I mean, there is a difference there in the fact

21 that, you know, once you're in the program and you're

22 running for several years, you are getting continuous
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1 certification. So, if you're a bad actor, you're going

2 to get caught fairly quickly.

3 But that first year test, you know, is

4 vulnerable to a flash-in-the-pan introduction and the

5 guy's gone, because there's not testing that's really

6 required for me to hold up my hand and say, I'm a new

7 manufacturer of some product.

8 MS. BARHYDT: Well, there's still the

9 regulatory requirements to have testing. I mean, you

10 either have to have your two tests and certify, or you

11 have to have your testing underlying your AEDM.

12 MR. FLY: But DOE isn't necessarily seeing

13 that test unless they request it, right?

14 MS. BARHYDT: That's correct.

15 MR. KLEISS: Jeff Kleiss. To that end, I

16 would think in regulatory bang for your buck, DOE

17 requiring to see -- more so than spot testing or even

18 the verification testing -- DOE requiring to see a

19 manufacturer's test data and calculations compliant

20 with 10 CFR Part 429 with the lower confidence level

21 and all that, is that widely done? And if not, I would

22 think that that would be --
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1 MS. BARHYDT: We do request test data

2 frequently.

3 MR. KLEISS: Okay.

4 MR. MYERS: This is Frank Myers, PVI. I'm

5 not sure, could you explain -- or what drives you to

6 enforcement testing?

7 MS. BARHYDT: So, the legal standard is that

8 there has to be a reason to believe that the product,

9 when tested and evaluated under the enforcement

10 statistics would not meet the standard.

11 MR. MYERS: Okay, so what do you see that

12 causes you to believe that's the case.

13 MS. BARHYDT: A failing test.

14 MR. MYERS: So, if a manufacturer provided

15 data that failed or the VICP program said, here's a

16 unit that failed, then you would either go into

17 enforcement, or obviously if that product family, if

18 it's -- or that basic model is removed from the market,

19 then there would be no need for enforcement testing.

20 MS. BARHYDT: Well, I don't know that I would

21 agree with that. If they've been selling the product,

22 just simply removing it from the market doesn't make
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1 the problem go away. If the product is non-compliant -

2 - so, let's say as our base that this really is a non3 compliant product. If DOE says we want to do

4 enforcement testing, we have reason to believe that

5 you're selling a non- compliant product, it's not

6 enough for us -- to us for the manufacturer to say,

7 well, I'll just stop selling it.

8 If they've been selling it and it's non9 compliant, then they're subject to civil penalties, so

10 we will want to go ahead with the enforcement testing.

11 It's not enough to just remove it.

12 MR. MYERS: That being said, the enforcement

13 testing for a small manufacturer, build-to-order

14 manufacturer would be devastating. You know, if we had

15 to provide the number of models built just for that

16 test, they would have no value to the manufacturer when

17 they're one, it would be much more punitive than if

18 you're talking about the same kind of thing for

19 residential appliances.

20 MS. BARHYDT: So, the regulations do

21 contemplate smaller sample sizes for built to order

22 products. In our experience, we've had manufacturers
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1 who basically said, well, we'll build one more just

2 because we're not real sure, and we've tested it and

3 it's failed, and they've said, we're done. We've made

4 two, you've tested two, they both failed, we'll concede

5 that it's non-compliant, and we don't ever get to a

6 larger sample size.

7 A lot of that is just in discussions with the

8 manufacturer. I mean, we like to have as big of a

9 sample size as possible, but some of it is the

10 manufacturer decision as to whether or not they want to

11 actually contest it or not.

12 MR. MYERS: So, one conceivably could not

13 contest after the first sample?

14 MS. BARHYDT: Yes.

15 MR. MYERS: It could -- even though they

16 might be convinced that that was an error, the cost of

17 building the second sample just for test, best just to

18 eliminate that and admit to guilt?

19 MS. BARHYDT: I suppose they could. That's

20 not been our experience.

21 MR. MYERS: Obviously, it depends a lot on

22 exactly which model is involved.
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1 MS. BARHYDT: Yeah.

2 MR. MYERS: If you pick some of our models, I

3 assure you that would be the consequence because we

4 couldn't afford to do that, but other models, okay, we

5 could build those and vindicate ourselves from an

6 erroneous test if that's what happened.

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

8 just a point of clarification. For your enforcement

9 testing, a non-compliant unit would be a unit that

10 would fail to meet the federal minimum standard, right?

11 MS. BARHYDT: Yes, but we do not prosecute

12 all cases.

13 MR. AMRANE: Okay. But in your verification

14 program, it would be the same? I mean, you would be

15 looking at making sure that products just meet the

16 federal minimum standard? Or will you be looking at

17 what AHRI does, which is making sure that the rating is

18 correct?

19 MS. BARHYDT: I think we would be looking at

20 both, but whether or not we would actually be seeking

21 penalties or something like that is a different matter.

22 But certainly we have an interest in making sure that,
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1 particularly with AEDMs, and we've already talked about

2 AEDMs, that we have a real interest in making sure the

3 AEDM is generating numbers that are reasonable, because

4 if they're not generating numbers that are reasonable

5 three points above the standard, then maybe they're not

6 generating reasonable results down at the standard

7 either.

8 MR. KLEISS: Jeff Kleiss. Could we see Frank

9 Myers' proposal up there again? Because as I'm

10 thinking through this, just about every point that

11 you're calling for, I think is covered within that

12 proposal.

13 MR. SACHS: Laura, would it be possible in a

14 reasonable time -- this is Harvey -- just to provide

15 printed copies so that we could write notes on them?

16 MS. BARHYDT: Of that?

17 MR. SACHS: Yeah.

18 MS. BARHYDT: I think we can do that.

19 MR. SACHS: That would be quite a favor.

20 Thank you.

21 MS. BARHYDT: Why don't we take a break and

22 we'll make copies?
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1 MR. EISNER: Are we going to start discussing

2 this?

3 MS. BARHYDT: Yeah, sure.

4 MR. EISNER: Why don't we take a ten-minute

5 break?

6 (Whereupon, there was a brief recess.)

7 MR. EISNER: I called you all together again

8 for another recess. Karim said.

9 (Whereupon, there was a brief recess.)

10 MR. EISNER: All right. Are we ready to

11 begin discussion? Who wants to lead off?

12 MR. AMRANE: This is Karim with AHRI. I

13 think we have a proposal we would like the chairman to

14 type it on the board first and --

15 MR. EISNER: Would everybody who is on the

16 phone please mute your phone?

17 (Pause.)

18 UNIDENTIFIED SPEAKER: Rusty will say what

19 this is for.

20 MR. THARP: This would be for the basic

21 requirements for any certification or verification --

22 any verification program, whether it's a VICP or a DOE
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1 run or whoever runs the program. And there's an

2 additional requirement under the second bullet that if

3 your company name starts with MI, you have 40 percent

4 of your products tested.

5 MR. THARP: So, the first is basically that

6 480 verification program, that any and all models that

7 are part of that program would be available in a public

8 list of all the models that are certified, then a

9 program would have 20 percent of product families would

10 be verified by test on an annual basis, I didn't --

11 actually, it would probably be good to type that up

12 there if you would on the annual basis, the second main

13 bullet.

14 And whoever is running the program would

15 provide a list of the models to be tested to DOE prior

16 to the annual testing so that DOE could have some input

17 on the models that were being tested. That program

18 would require a changing of a rating or removal of the

19 rating if there was a failure of the test.

20 The program should require some sort of

21 qualification procedure of any new participants. That

22 would include things such as testing of models to be
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1 initially qualified and/or submission of test data or

2 AEDM data, something of that nature, to the person or

3 persons running this certification program.

4 The program should also allow some method of

5 challenge testing for those people within the program

6 or somebody from outside the program, similar basically

7 to AHRI certify all policy that any models in that

8 product family or any models that the participant

9 offers for sale that are in that product category must

10 be certified along with all the other ones, so you

11 can't pick and choose which ones you want to certify.

12 The certification program would need to

13 provide a summary of all verification testing, at least

14 annually, and if there are any failures, that there

15 would have to be some specified timeframe for how fast

16 the notifications are provided to DOE.

17 UNIDENTIFIED SPEAKER: And that's to DOE?

18 MR. THARP: Right. That's notification to

19 DOE. And you may want to put that in there, if you

20 would, the quick notification "to" DOE, please, thank

21 you, Jeremiah.

22 Whoever does the testing should be
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1 independent, third party laboratory that's ISO 17025

2 certified unless, as we've noted before, there's not

3 such an animal facility that can test a certain

4 product, and obviously, the testing would need to be

5 done via DOE test procedures and, as indicated earlier,

6 a test report would need to be made available.

7 MS. JAKOBS: A summarized test?

8 MR. THARP: A summarized test report. And

9 that's a -- I guess a starting point for the baseline

10 requirements for a verification program of certified

11 ratings.

12 MR. BAUMAN: Russ, was this -- I guess I

13 still have some confusion. So, this is being proposed

14 for across the board for all products versus a third

15 party industry program that would be an optional

16 possibility for DOE to approve outside of normal --

17 MR. THARP: This would be the base

18 requirements for any verification program of certified

19 ratings, whether it's a DOE run, whether it's a VICP.

20 Obviously, a VICP could go even beyond this. I feel

21 that AHRI's certification program is more stringent

22 even than this.
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1 MR. EISNER: So, if DOE was doing testing it

2 would have to test 20 percent of the product family?

3 MR. THARP: Correct. And part of that is

4 making it a level playing field. So, regardless of who

5 you are, whether you're part of a VICP or part of a

6 DICP or whoever's running the program, that you have

7 the same verification requirements of your certified

8 ratings.

9 MR. STEPHENS: Phillip Stephens, HTP. I

10 think the question I would have would be a Certify All

11 Requirement on the baseline because we have some

12 manufacturers that are with AHRI, but AHRI doesn't

13 offer a program for their products. So, having the

14 Certify All on the baseline, would that mean they can't

15 do any of their products with AHRI?

16 MR. AMRANE: I guess in this context, I mean,

17 those are products that are regulated by DOE, so, I

18 mean, so all of them would have to be within -- subject

19 to verification.

20 MR. FLY: So, the Certify All rule in AHRI

21 applies to a program, to a certification, for large air

22 conditioners, but if I can go build chillers and not be
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1 certified then I haven't violated the Certify All rule.

2 The other thing is, you know, when you say Certify All,

3 it has to be within the program scope, which you have

4 defined as the product class scope. So, you know, 300-

5 ton air conditioners are not currently a regulated

6 product, they're not currently in a certified program,

7 so they're not being discussed here.

8 MR. STEPHENS: Phillip Stephens, HTP.

9 I think possibly a better way to phrase it

10 would just be to simply say, all products must be

11 certified, because the Certify All rule brings up

12 different connotations if you're talking about a VICP

13 versus --

14 MR. FLY: Mark Fly with AAON again. But you

15 could also have part of your product certified through

16 -- one VICP part of it certified through DOE if you

17 want, if you chose to do so.

18 MS. BARHYDT: So, are we talking about Verify

19 All? Because everything's already required to be

20 certified. And so just making sure we're clear on

21 terminology.

22 MR. STANONIK: Frank Stanonik with AHRI.
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1 Again, couple of things. We're talking about a

2 verification program and none of us should forget that

3 this working group spent a lot of time developing AEDM

4 criteria, which applied to the certification of all of

5 your models covered by federal regulations. Okay. So,

6 yeah, the question of Certify All really is not a

7 verification program in the terms of DOE

8 certifications, not a program requirement, okay, but

9 what I think we want -- what we're saying is that if

10 someone is operating a verification program, all -- and

11 a manufacturer is participating, all of that

12 manufacturer's products that fit within the scope of

13 that program must be listed in the program. That's

14 what we're saying.

15 Because, again, yeah, in terms of DOE's

16 regulation, everything is certified.

17 MR. WHITWELL: Yeah, and I would suggest that

18 be changed to "all products must be in the verification

19 program", because if you say "all must be verified"

20 that implies they're all tested.

21 MR. STANONIK: Right, right.

22 MR. SACHS: This is Harvey. And I'm not
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1 quite sure how to understand the term "verification

2 program". I've got a pretty ornery friend, Charlie Hon,

3 and he's not part of AHRI for his own good reasons, he

4 doesn't want to be part of any -- any trade group. He

5 wants to be out on his own. And what does it mean to

6 think about a -- sorry I'm using you for an example,

7 Charlie -- what does it mean to have a one manufacturer

8 program?

9 MS. BARHYDT: So --

10 MR. SACHS: This is really a question to AHRI

11 because it's theirs. Laura, you're off the hook. But

12 what Does it mean if I've got a firm in --

13 MR. AMRANE: Karim Amrane. We're not saying

14 that you have to be in the AHRI program here. I mean,

15 it could be UL, it could be somebody else. I don't

16 know. Like for Energy Star today, I mean, Charlie

17 participate in one of those programs.

18 MR. SACHS: Well, Karim, I'm hearing from you

19 that UL is a program and I think of it as a test lab.

20 MR. AMRANE: Well, I think they do have a

21 program for Energy Star, I believe, I mean, I don't

22 know. You can speak for yourself.
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1 MR. THARP: UL has a verification services

2 division.

3 MR. SACHS: How would you treat -- I can

4 think of a boiler company that's in the same category

5 or is a particularly good example -- how do you treat

6 an individual company that might want to use CSA one

7 year, might want to use UL one year, might want to use

8 Intertek, but wants to have full responsibility for its

9 own verification, wants to be a good player, but

10 doesn't want to be pushed to join anything other than

11 having a 17025 lab do its testing?

12 MR. STANONIK: Frank Stanonik with AHRI.

13 Harvey, I think you've maybe jumped a little ahead,

14 okay. First of all, our intent -- to be absolutely

15 clear on this -- our intent and our belief is that the

16 criteria for acceptance of -- let's call them VICPs,

17 okay, that in this regulation that should be the

18 baseline, and so what we're trying to do is establish

19 the baseline.

20 We're also operating off of Laura's statement

21 that DOE's intent is that every manufacturer will have

22 to have some kind of verification on an annual basis.
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1 Is that correct?

2 MS. BARHYDT: (Shakes head yes.)

3 MR. STANONIK: Okay. And so, the question

4 of, okay, what will be the requirements for

5 verification for any manufacturer not in a VICP of

6 whoever's operating it, I would say, still needs to be

7 developed as part of the working group recommendation,

8 but we feel very strongly the baseline from which those

9 requirements would be developed should be working off

10 of this.

11 So, the answer to your question, I think

12 right now, unless other people in the working group

13 know, I think that the answer is to be determined.

14 MR. SACHS: Thank you, Frank. That's

15 helpful, and my question then is that really this is

16 basic requirements for a VICP verification program.

17 MR. FLY: This is Mark Fly with AAON. I

18 think I heard earlier, though, that DOE's intent is to

19 run a program for those people who aren't in a VICP

20 program, so if it wasn't one of our VICP programs or

21 UL's, then I would assume DOE would be administering

22 this to similar rules.
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1 MS. HOOTMAN: Exactly. At the very same

2 minimum rules.

3 MS. BARHYDT: So, I can't say that we're

4 wanting to just pick up everybody, but what we would

5 like to do is, as you all said, have a single set of

6 rules for these are the minimum requirements for DOE to

7 recognize a program. We actually think that it could

8 be possible for Charlie to come up with a plan for True

9 Manufacturing that DOE could approve that would let

10 them do in-house testing, I'm not sure whether or not

11 we would be okay with him selecting the units himself,

12 but maybe an algorithm or something, we might even

13 agree to something like that, where he could have his

14 own plan that is an approved plan, and DOE would

15 provide oversight and make sure that people were

16 adhering to those plans, but that he wouldn't

17 necessarily have to go and participate in a larger

18 group program.

19 MR. KOJAK: This is Mike Kojak with UL. I

20 had a question about that same thing. If it's a

21 smaller manufacturer that doesn't have its own test

22 lab, but they don't want to be part of a voluntary
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1 certification program, couldn't they just send, you

2 know, X amount of units every year that randomly is

3 picked by them or by the DOE to a third party test lab

4 to have it verified that it meets the requirements

5 without being part of some verification group?

6 MS. BARHYDT: Without agreeing to the

7 specifics of how that would work, yes. Conceptually,

8 yes.

9 MR. EISNER: I have a question about the

10 third bullet, required qualification of new

11 participants. Is this new testing facilities, the ones

12 doing the verification? Or is this a new entrant into,

13 for example, one of the existing testing facility

14 programs? Do you qualify as a manufacturer or qualify

15 as a tester?

16 MR. DOPPEL: Paul Doppel, Mitsubishi. It's

17 intended to be a manufacturer. And this is not

18 intended to be a group thing, this is anybody, any

19 manufacturer would have to comply with this, is the

20 intent of that, and I think just the bullet that's

21 highlighted in red, I think that should say, all

22 products within the DOE covered -- this is additive
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1 words, you're not removing anything, but all products

2 within DOE covered product category must be in the

3 verification program.

4 MR. EISNER: Okay, Rod Beever had a question

5 online. He said, "This does not appear to line up with

6 the proposed rules for the use of an AEDM. How do they

7 address this difference?"

8 MR. AMRANE: Karim Amrane with AHRI. This is

9 separate from the AEDM requirements, so we're not

10 talking about verifying the AEDM, we're talking about a

11 verification program, once you have already certified

12 your product with DOE, whether you have used an AEDM or

13 not, so that comes after that process. I don't know,

14 you can have --

15 MR. THARP: The AEDM is used to certify or

16 create the rating, and this is a verification program

17 to verify that what is already in commerce is correct.

18 MR. BALLO: There is one point of

19 intersection between the two issues, though. For AEDMs

20 we went through a lot of discussion about the role of

21 the manufacturer involvement in the testing that DOE

22 would do to substantiate or confirm, validate the
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1 AEDMs. So, I think we do need to address the role of

2 the manufacturer in any verification testing as part of

3 this criteria.

4 MR. HALLEY: Geoff Halley with AEDM. I would

5 like to follow up. I like what Laura put forth

6 recently in reference to Charlie's problem to deal with

7 some of the realities that I see. When you get into

8 the larger boilers, we've still got the problem of

9 testing in the manufacturer's facility. We've also got

10 the problem that I don't know for sure, but I suspect a

11 good proportion are not qualified to ISO 17025 and

12 probably may never be qualified to that because they

13 don't have a formal test lab. They test in what's

14 known as a fire test area, which is the end of the

15 production line, if you like, where they do a fire test

16 and it's the only place in the plant where they have

17 the capability of the utilities, if you like, the

18 water, the fuel, oil, natural gas, flow capabilities,

19 that sort of thing.

20 So, you know, I think there are a couple of

21 ways to address it. Yeah, it would be nice for ISO

22 17025, but what are the basic requirements for a test
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1 that is acceptable to DOE? And I think they could be

2 something like, you know, an agreed test procedure to

3 start between DOE and the manufacturer -- obviously,

4 that's one -- a selection process has got to be agreed

5 on. And I think beyond that, you need the right

6 instrumentation properly calibrated, the right

7 environment, if you like, or as close to it as you can

8 get.

9 Obviously, if you're somewhere in the Midwest

10 in summer, you're going to get different air densities

11 than you would in the winter, and that sort of thing,

12 so that's going to be a problem area if you're going to

13 split hairs and go to the n-th degree.

14 You know, we're not dealing with a Swiss

15 watch here, we're dealing with something a lot cruder

16 than a Swiss watch, and so I think those things should

17 be considered when you get to this, and I think DOE

18 could probably save a lot of grief all around by

19 putting a cap on this rather than 25 million -- 2.5

20 million BTUs an hour. I know it can't be done

21 immediately, but I think it should be considered and

22 I'll throw out a number, 12.5 million.
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1 Beyond that, the boilers tend to become more

2 industrial type boilers, but in a heating application,

3 you know, the controls are -- there's a control split

4 at 12.5 million for one thing.

5 MR. SHEBIK: Ron Shebik with Hussmann. I

6 just have a couple questions to make sure I understand.

7 The second bullet where it says "20 percent of product

8 family verified testing annual basis", looking at

9 commercial refrigeration equipment, which I'm familiar

10 with, using it as an example, we've got self-contained

11 remote, medium temp, low temp, open and closed, so we

12 have eight product families would be the potential. Is

13 that what you -- so, we test 20 percent, so it would be

14 two cases per year?

15 MR. AMRANE: Again, this is Karim with AHRI.

16 Again, this product family has to be defined, but it's

17 a concept that's -- it's broader than the basic model

18 definition that just came out a few days ago, okay --

19 MR. SHEBIK: Okay.

20 MR. AMRANE: So, that's to group product a

21 little bit differently.

22 MR. SHEBIK: And the last question I have is
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1 -- for now, is -- the last bullet, testing by a third

2 party, ISO 17025 lab, if a manufacturer is part of

3 Intertek satellite program or UL client test data

4 program, part of the requirement of being in those

5 programs is to be -- is to meet ISO 17025 requirements.

6 You're not certified by ISO as being a lab, but you

7 meet the UL and Intertek requirements. Is that

8 satisfactory?

9 MR. AMRANE: This Karim with AHRI. And,

10 again, it might be satisfactory. I think the intent

11 here is to make sure that it's somehow an accredited

12 lab to 17025 that follows those rules, so at least

13 there is some legitimacy to the test.

14 MR. SHEBIK: Okay.

15 MR. WHITWELL: Bob Whitwell from Carrier. It

16 needs to be ISO -- needs to be qualified for ISO 17025

17 to run the performance, the rating test, and not just

18 the UL 1995 test. There are differences. Okay. So,

19 just being part of the UL satellite program doesn't

20 necessarily mean that you are ISO 17025 certified to

21 run the rating tests.

22 MR. SHEBIK: Okay, I understand. Thank you.
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1 MR. KLEISS: Jeff Kleiss, Lochinvar.

2 MS. HOOTMAN: Jill Hootman, Trane

3 MR. KLEISS: Go ahead.

4 MS. HOOTMAN: Go ahead, Jeff.

5 MR. KLEISS: Okay.

6 MS. HOOTMAN: I was just going to say -- so,

7 would we say ISO 17025 certified or just, you know,

8 accredited to those factors?

9 MR. WHITWELL: Yeah, I think certified --

10 MS. HOOTMAN: Not everyone might be exactly

11 certified with an ISO inspector, but there might be

12 labs that are doing all of those criteria, but just not

13 having an ISO person coming in and doing that

14 certification.

15 MR. WHITWELL: Yeah, I think certified is not

16 really the right word, it's more like what is required

17 by -- for Energy Star, right?

18 MS. HOOTMAN: Yes.

19 MR. WHITWELL: A CB needs to come in and

20 audit, I think is --

21 MR. KOJAK: Yeah, so, like an ISO 17 --

22 MS. HOOTMAN: Audit.
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1 MR. KOJAK: -- an ISO 17025 third party lab

2 would come in and audit the manufacturer's test

3 facility and, you know, be the certification body for

4 them saying that they're up to the standards of an ISO

5 lab, so the third party ISO 17025 lab is basically

6 giving the accreditation to your lab saying it's good

7 enough to do it.

8 MR. SACHS: Can you give us actual words for

9 that?

10 MR. KOJAK: No.

11 MS. MEYERS: Wouldn't it just be accredited.

12 UNIDENTIFIED SPEAKER: Accredited.

13 MS. MEYERS: Accredited. I'm sorry. Testing

14 by an accredited third party ISO 17025 -- isn't -- does

15 that work?

16 UNIDENTIFIED: I like that.

17 MR. HON: Charlie Hon. There's a legal issue

18 here. As a third party, as a lab certified to run the

19 test audited by a third party like UL or ETL, the labs

20 are not technically ISO 17025 certified themselves.

21 The body above them is the certified because they're

22 the independent tester.
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1 As a manufacturer, you're really questionable

2 whether you can legally have 17025 to test your own

3 products. There's a distinction there that can't be

4 crossed and by having the third party viewing our labs,

5 we meet the criteria of being 17025 but we're

6 technically not. But we have all the competency by the

7 third party verification of our labs to meet the lab

8 test requirements for all the conditions.

9 MR. EISNER: Could we say "audited by"?

10 MR. STANONIK: Frank Stanonik with AHRI. It

11 seems to me what we're saying is "tested by" or under

12 the auspices of a third party ISO 17025 lab.

13 MR. HON: Charlie Hon again. That's the

14 problem because if by chance we want to be an

15 independent -- in sending data to DOE ourselves on some

16 products, then we fall out from under that scope.

17 MR. STANONIK: Well, I was just trying to

18 correct what is, at this point, again, what we're

19 considering the baseline principle and I think the

20 point, not dismissing what Charlie just said, because

21 it needs to be resolved, but the point of the

22 recommendation here would be that it's either testing
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1 done by the lab, or in essence, it's done under their

2 control, and that's why you were saying under the

3 auspices of. That, to me, was what I was trying to

4 say.

5 MR. THARP: Rusty Tharp with Goodman. I'm

6 not comfortable with my competition doing their own

7 verification testing. If we want to do it that way,

8 I'll be happy to do my own verification testing of all

9 the products. That's why I think it's important that

10 the testing for the verification be done by an -- at an

11 independent, third party laboratory or under the direct

12 control of an independent, third party laboratory.

13 MR. HON: I think that's what we're trying to

14 discern here, what really needs to be done. Charlie

15 Hon.

16 MR. EISNER: How about testing by or under

17 the control of an accredited third party ISO lab?

18 MS. BARHYDT: What would you call testing in19 house but with a representative of the third party lab

20 present? Because we know that there are some issues of

21 labs being able to accommodate it and some of the

22 manufacturers have better lab set ups for their
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1 particular equipment, so how would you describe that --

2 MR. KOJAK: With the way UL works is there's

3 different levels. It's Mike Kojak with UL. The first

4 level is the witness test program, which is exactly

5 that. Someone from UL will actually travel to the lab

6 site and witness the testing being done to verify

7 everything is being done properly, and then there's a

8 higher level, which is a client test data, which is,

9 you know, also known as a satellite program, which once

10 that remote lab has gone through a higher level of

11 auditing and oversight, they are allowed to do the

12 testing without having a person from, you know, the

13 accreditor's location witnessing everything.

14 So, basically, they've earned the right to,

15 you know, conduct their own testing because they have

16 the proper documentation and the proper oversight from

17 yearly audits and things like that.

18 MS. BARHYDT: Rusty, would witness testing

19 address your concern that you just expressed?

20 MR. WHITWELL: Before you answer. Bob

21 Whitwell from Carrier. Maybe Karim and Frank can help

22 me on this or Bill, but, for example, chiller programs,
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1 right, the chiller program at AHRI, I know that we test

2 in our lab some chillers and we have the third -- for

3 AHRI certification program, and we have the third party

4 lab representative come in and make sure that we are

5 running that test properly, and it actually takes the

6 data away. So, Bill, maybe you can add to that.

7 MR. TRITSIS: This is Bill Tritsis, AHRI.

8 You're correct. So, what we're talking about here is,

9 you know, and I guess we're noodling around here the

10 concept that Energy Star has already in place, we're

11 talking about supervised testing, either it is through

12 an independent laboratory such as UL or Intertek, or

13 through AHRI supervising the testing at the

14 manufacturer's facility, at the manufacturer's facility

15 which is approved, okay, by the certification body,

16 either, again, it is AHRI or UL or Intertek. AHRI,

17 again, has a list of requirements that the laboratory,

18 the manufacturer's laboratory, has to meet, okay, and

19 these requirements are close, I guess, to what ISO

20 17025 is prescribing, okay, that makes the

21 manufacturer's laboratory not necessarily accredited,

22 but approved, okay, by a certification body.
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1 And we have a testing done, which is

2 witnessed by the certification body.

3 MR. EISNER: Again, language seems to be what

4 we're talking about here. Instead of "under the

5 control of" should we be saying "witnessed and verified

6 by" or something like that?

7 MR. THARP: This is Rusty. I agree that

8 under the supervision or witness --

9 MR. STEM: This is Mike Stem with Intertek.

10 There is specific language in ISO 17025 that deals with

11 what you're talking about, which is basically a

12 recognize test lab. It's not a certified test lab, a

13 CBTL, but an RTL, and there's four different levels for

14 both -- or any of those CBTLs to be able to assign a

15 competency level for a recognized test lab underneath

16 their umbrella or scope of accreditations.

17 So, I don't think we probably have to

18 reinvent the wheel here. We can probably pull that

19 specific RTL language out of the ISO documents if

20 anybody was interested in that.

21 MS. DANE: This is Mary Dane from Traulsen.

22 MR. EISNER: Mike, was that the question I
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1 was handed that you wanted to -- or the point that you

2 wanted to make?

3 MR. STEM: It's one of them.

4 MR. EISNER: Okay. Jump in when you want to.

5 Go ahead, Mary.

6 MS. DANE: I just want to make sure that

7 we're not wandering away, because where I'm seeing this

8 going is now we're starting to go from talking about

9 belonging to a voluntary industry program --

10 certification program, into being in a required

11 program, which is going to remove a manufacturer's

12 ability to test in their own laboratories, and I want

13 to be very careful -- I'm not trying to take away from

14 AHRI and the investment that those members have made,

15 but for CRE, we're not generally part of that now.

16 So, as we're going on and we're adding this

17 verbiage, where testing is done by or under the

18 supervision of a third party, now this starts to look

19 to me like we're not talking about a voluntary industry

20 program, we're talking about the basic requirements to

21 certify certified ratings. So, you know, maybe --

22 (Simultaneous discussion.)
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1 MS. DANE: So, I still want to make sure

2 because, you know, as I say, I don't want to take away

3 from the investment that people have made into the

4 program, but I want to make sure it remains a voluntary

5 --

6 MS. BARHYDT: So, Mary, what we're talking

7 about is a requirement to participate in a verification

8 plan.

9 MS. DANE: That makes me feel better. I just

10 feel like I have to say something because I see this

11 going under --

12 MS. BARHYDT: Yeah, so, the idea is that all

13 manufacturers would have some level of verification.

14 Now, how they met those requirements may vary, some may

15 do it through a VICP, some may do it through some other

16 mechanism, but the general idea is that DOE would

17 approve whatever plan or program that manufacturer was

18 participating in, and that that would be the mechanism

19 for them to meet their verification requirement.

20 MS. DANE: Okay.

21 MS. BARHYDT: So, we are talking about a

22 requirement, and -- but I think that that doesn't
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1 necessarily preclude manufacturers being able to do the

2 testing in-house, it's just a question of what level of

3 supervision is occurring when that testing happens at

4 the manufacturer's facility.

5 MR. EISNER: Are people happy with this

6 language? Does somebody want to pull up the ISO

7 language?

8 MR. KOJAK: This is Mike Kojak with UL. I

9 just wanted to bring something up. What we're talking

10 about here is for verification only. For

11 certification, a lab doesn't have to be ISO 17025.

12 MS. BARHYDT: Right.

13 MR. KOJAK: A manufacturer can test their

14 product in their own lab, certify it at DOE, but the

15 verification portion, this is the only part we're

16 talking about where it has to go through this. Okay.

17 MR. MYERS: This is Frank Myers, PVI. This

18 basically is saying you have to participate in a VICP.

19 It's structured to be a VICP. If we're looking at base

20 requirements that all manufacturers have to comply

21 with, there's a lot in here that I like. But I'd like

22 to be able to do it without being forced into a VICP.
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1 The 20 percent product family verified by

2 test annually, that seems reasonable. Provide a list

3 to DOE for their review before test, I understand, but

4 we'll have to work out, for those of us that build-to5 order, we don't know at the first of the year what

6 we're going to sell during the year. We might know the

7 first month or so, but we will have to be in closer

8 communication with DOE to provide them, here's what we

9 have coming up, because a lot of our products have six10 week windows from the time we accept an order until we

11 deliver, and that's the window we have to insert some

12 testing.

13 So, I don't have a problem with that as long

14 as it's understood that for manufacturers that don't

15 know what they're going to build during the year, we

16 can't say we'll test these units. We can say, we'll

17 test these product families is a unit is built that

18 year. And then require changing ratings or removal if

19 fail, absolutely. That should be inherent in the

20 program. Qualification of new participants, if that

21 means verifying their ability to conduct the test, I'm

22 going to propose that would be covered by the last
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1 section, the third party ISO 17025, so that, to me, is

2 a bit redundant. I don't have a problem with making

3 sure the manufacturer can run the test. Allow

4 challenge testing is a VICP tenant. In terms of general

5 verification, the challenge for a non-VICP would be

6 through DOE or you could go, like the AHRI programs

7 allow external challenge to products that are not in

8 the VICP program. So, there are means to have

9 challenge if you're not in a VICP, so allow challenge

10 testing doesn't really play if you're looking at a base

11 requirement.

12 To me, it's redundant that all products

13 within DOE covered category must be in a verification

14 program.

15 That's what we're saying: everything has to

16 be in a verification program. So, it doesn't seem to

17 be necessary here since that's a part of what we're

18 doing is making sure everything is covered.

19 Summarize verification testing annually and

20 quick notification, I absolutely agree.

21 The last line, if we can, as I had proposed

22 in my section, even if it's limited to build-to-order
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1 manufacturers, I've got to have something where I can

2 run the test. I'll be as qualified as I need to be and

3 we currently do that under the auspices of a satellite

4 approval where we go through all the things that the

5 laboratories have talked about where we have to be

6 approved for the testing that we do, we have to set up

7 training programs, we have to have feedback loops,

8 annual audits to be sure that we're doing it correctly,

9 because we need to be able to take a product that is --

10 we receive an order for, and before we ship, we have to

11 be able to test, and we can't put in there weeks or

12 months to have somebody scheduled to come in because we

13 don't have weeks or months to do that.

14 We have to be able to deliver, basically, our

15 testing when it needs to be a two- or a three-day

16 window for this to be practical. If we can test under

17 the auspices of a 17025 laboratory, then we can do

18 that, but if we have to wait for a member of a third

19 party lab to come watch the test, for us that build-to20 order, that would be almost impossible.

21 So, a lot of this I like, just a few items, I

22 think, need to be adjusted to allow this to be a
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1 general requirement as opposed to a VICP requirement.

2 MR. KOJAK: This is Mike Kojak with UL.

3 Under the red -- the whole line that's in red, I think

4 you should add in at the end there, "must be in the DOE

5 verification program" -- no, not there, the one above

6 it.

7 MS. BARHYDT: The idea is that -- well, what

8 exactly are you trying to clarify? Maybe I'm not

9 understanding.

10 MR. KOJAK: Because it -- you know, you're

11 going to have your own rules because you're going to be

12 kind of the overseer of your verification program only,

13 it's not -- you know, it's not going to be a bunch of

14 different verification programs having all the same

15 rules, you're going to set the rules for all of us that

16 we have to abide by for your verification program.

17 MS. BARHYDT: What about "must be in a DOE

18 approved verification program"?

19 MR. THARP: I like that. This is Rusty Tharp

20 with Goodman. This is really sort of intended, you

21 know, to the point that Bob made earlier, and Frank --

22 this was sort of -- this was meant to be a basic
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1 requirement for a verification program for a huge

2 majority of products, and then there would be,

3 obviously, the one-offs and things of that nature where

4 it would need to have something separate because of the

5 uniqueness of those particular products.

6 I agree with Laura's comment to Mike's

7 comment, in a DOE approved verification program.

8 MR. EISNER: The last bullet still seems to

9 be of concern to some. Anybody have solutions?

10 MS. BARHYDT: So, for the labs, how long --

11 how quick can you get out to witness a test?

12 MR. KOJAK: For witnessing a test, for one,

13 it would be where they're located and, you know, what

14 Frank was talking about, you know, I think it is

15 possible for people to witness a test, because if

16 they're in the manufacturing process, there's going to

17 be a schedule when it's -- the manufacturing of that

18 product is going to be complete and when they're going

19 to start the testing, so they'll have a good idea of

20 some dates when their testing will take place, so then

21 the witness people can schedule their time accordingly

22 to be there, you know, to witness the test.
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1 You know, it's not -- I would assume they

2 would know when their manufacturing process was going

3 to be over and they were going to be testing it

4 themselves. You know, I wouldn't think that would just

5 all come up in three days.

6 MR. SMITH: This is Judd Smith from CSA. It

7 would depend on when they notify us. Yeah, this is

8 Judd. It would depend on when they notify us for the

9 witness testing, but I think we have enough resources

10 to meet their needs within a couple weeks or a month.

11 MS. BARHYDT: So, up to a month of notice.

12 MR. STEM: This is Mike with Intertek.

13 Sorry. I think it would also be very dependent on the

14 specific technology that's being witnessed and the lab

15 readiness as far as instrumentation and set up

16 accuracies. That's probably going to be the bigger

17 determination in time.

18 MS. BARHYDT: So, Mike, are you saying that

19 the -- it would depend on how -- because we're talking

20 about it being in a manufacturer's test facility, so

21 presumably they have their lab all set up and the

22 instrumentation. Are you saying it may take additional
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1 time for the person witnessing to verify that

2 everything is properly calibrated and prepared? Or

3 what exactly is your concern there?

4 MR. STEM: Well, for all other witnessed-type

5 tests there's a pre-test process that goes through

6 where you verify the calibrated equipment and

7 methodologies of the testing for the specific standards

8 and scope. But that's assumed to be correct when you

9 go, it's not a big deal. You go and you witness the

10 test, run the calculations, and report the results.

11 But more often than not, there are issues, because

12 there's always issues when you deal with mechanical

13 components.

14 A timeline is -- I think you're going to have

15 to -- and, Mike, I understand where you're going with

16 this, you know, looking for the time, but you're going

17 to have different pieces, you know, as far as timelines

18 for scheduling, timelines for testing, timelines for

19 reporting.

20 MR. KOJAK: This is Mike Kojak with UL. With

21 the AHRI witness program for chillers, like the power

22 measuring equipment that is used is sent by the third
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1 party labs either ahead of time or with the person

2 witnessing it to put in line with the lab's equipment.

3 So, you know, if it was the case, if we were

4 coming to witness a test at a third party's facility,

5 you know, the instrumentation, depending on size, could

6 be shipped ahead of time to be added in from the third

7 party, you know, the witness testing lab, so, I mean,

8 it might be an option just to have the witness testing

9 lab ship, you know, like the power reading equipment,

10 which is ISO 17025 calibrated and traced, to be sent to

11 the location for that to take the ultimate reading of

12 the power consumed and things like that, kind of like

13 the AHRI witness program is for chillers.

14 MS. BARHYDT: So, rather than using the

15 manufacturer's and verifying that everything is

16 calibrated and has all the complete documentation,

17 having the lab use -- ship theirs, seems to me like

18 that's going to add a lot of burden to the manufacturer

19 to actually set up their lab using different equipment,

20 but maybe not, maybe that's really straightforward.

21 MR. KOJAK: UL has got like travel kits of

22 the power reading equipment, so when we do go witness a
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1 test for the AHRI program, that gets either shipped

2 ahead of time to be installed depending on the size of

3 it or it's brought with the person that's going to

4 witness the test and they install it the day of, you

5 know, and it's usually in combination with their own

6 equipment just to verify, you know, their stuff is

7 reading the same as our stuff, you know, things like

8 that.

9 MR. MYERS: This is Frank Myers. I

10 appreciate the fact that AHRI's certification program

11 handles it that way, but there is a federal test

12 procedure that gives the specification for the test

13 equipment and the tolerances of the test equipment, and

14 I think anybody that has that verified that they have

15 the proper tolerance specified in the test procedure,

16 then they should be able to use that equipment.

17 MR. STEM: This is Mike with Intertek.

18 That's what I was going to say. That's handled as a

19 Level II RTLs. There's also Level III and Level IV

20 RTLs. Level III, you know, you can use your own

21 equipment, and then Level IV actually doesn't even

22 require any supervision.
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1 So, I don't know, you know, how far up the

2 levels you want to discuss, but I do think Level III,

3 in most cases, for manufacturers would be acceptable

4 given that most of their equipment probably will be

5 calibrated in that instance.

6 MS. HOOTMAN: This is Jill with Trane. Let

7 me give you an example of, I guess, you know, I'll walk

8 through an example of an AHRI test that physically

9 could not fit in any of the approved laboratories, and

10 it's directly under this rulemaking. Commercial

11 furnaces. Commercial furnaces are 225,000 BTUs and up,

12 we make furnaces that go up to 2 million BTUs and they

13 go on our very large rooftops. There is no physical

14 lab outside of Trane, you know, independent lab that

15 can fit that. So, AHRI said they were picking one of

16 these units, it happened to be 105-ton unit with a 1

17 million BTU heat exchanger.

18 We worked with AHRI and Intertek, in this

19 case, and it took us -- first of all, it takes us a

20 long time to build one of those units, 12 weeks to

21 build one of those units, so, you know, we had a long

22 time in scheduling this out. We could set the test
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1 date out for our lab knowing what the build cycle was,

2 et cetera, worked with the lab on setting that test

3 date up.

4 They sent all the information, a checklist of

5 what had to be -- what the equipment had to be, what it

6 had to be calibrated to, et cetera, so that was all

7 done -- pre done before they came, and, you know, we

8 coordinated then the actual witnessed test of the test

9 at our laboratory.

10 And this is a one-off, build-to-order, custom

11 unit.

12 Now, oh, by the way, that's a very expensive

13 unit. So, don't do it too often.

14 MR. CYMBALSKY: I hope somebody bought it.

15 MR. THARP: Again, this is Rusty. So, there

16 obviously should be some differences between one-off or

17 low-volume type products and higher volume products.

18 I'll point out that Bill Tritsis commented that there's

19 a ISO Guide 65, which are the general requirements for

20 bodies operating product certification systems that

21 could be referenced here.

22 MR. STEPHENS: Phillip Stephens. HTP. I
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1 have some proposed language for the last major bullet

2 point. I pulled this up from Guide 17025.

3 "Manufacturers shall submit accredited verification

4 test results using ISO 17025 with the most recent

5 version as the basis for their accreditation." Now,

6 along the same lines as the low- volume products and

7 the difficult products to do, we could also add

8 verbiage along the lines of "unless the Department

9 approves a waiver of this requirement due to

10 extenuating circumstances" and just leave it open ended

11 because there are so many various reasons why we would

12 not need that.

13 Wow, I really know how to quiet a room.

14 MS. BARHYDT: Can we come back to the lab

15 accreditation issue a little later? I'd like to

16 actually sit down and look at some of the language from

17 17025 before we get -- figure out exactly what language

18 we want to use there.

19 It's 11:30. Do you all want to deal with the

20 product family issue? Start talking about it? Do you

21 want to go to lunch?

22 MR. KLEISS: Keep talking.
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1 MS. BARHYDT: Okay. So, we've seen the

2 concept of a product family introduced, but I'm not at

3 all sure that everybody is envisioning the same scope

4 or magnitude on that, so if people could talk a little

5 bit about what they are thinking when they use that

6 word.

7 MR. KLEISS: Can I touch the language on that

8 just while I've got it on my mind? Jeff Kleiss,

9 Lochinvar. On the second bullet, "20 percent of

10 product families" I believe is an important distinction

11 and add "rounded up" so that if you have one product

12 family, you would have to test one unit. If you have

13 six product families, you would have to test two units.

14 The next distinction is on the second sub15 bullet, "requiring changing of product family rating or

16 removal".

17 MR. STANONIK: Frank Stanonik, AHRI. That's

18 going too far. The -- we've got AEDMs, you've got

19 product families, the particular circumstances of a

20 failure will determine what has to be re-rated and that

21 should be up to the operator of the program and the

22 manufacturer to just say automatically that if I had a
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1 product family and I had one -- the particular model I

2 tested failed, and that means absolutely at 100 percent

3 of all cases that the product family has to be re-rated

4 is an overstatement. You don't know that until you've

5 got the test data.

6 I think that's part of where the

7 certification program can figure out what is the next

8 appropriate step of a failed result.

9 MR. HON: This is Charlie Hon. A product

10 family can be done by AEDMs or by testing, and so that

11 would be ludicrous to remove other tested product just

12 because one product in the family would fail if there's

13 other test data to verify the others.

14 MR. THARP: Maybe we should discuss what

15 "product family" is.

16 MS. HOOTMAN: Yeah.

17 MR. MYERS: This is Frank Myers, PVI. I made

18 a proposal earlier that "product family" be "a grouping

19 of models identified and advertised by a manufacturer".

20 MR. EISNER: People want to talk about this?

21 Do they want to change it? Are they okay with it?

22 MR. HON: That encompasses our entire product
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1 line in one family.

2 MR. BALLO: This is Tim and not to take us

3 back where we just were -- I guess, actually to do that

4 -- I don't have a problem with limiting the re-rate to

5 the basic model that was tested, but I think at that

6 point, because there is an indication that at least

7 there may be a problem with the product family, I think

8 that should be a case where maybe if you do have a re9 rate you have an additional test within the product

10 family of a different basic model.

11 MR. THARP: Well, since -- going along those

12 lines, since we would be submitting whether the models

13 are rated by AEDM or by test, that information would be

14 available -- so, if it is an AEDM, that may be an

15 indication that your AEDM has a problem. But if you

16 have a product family that's all models are done by

17 test, then it's probably just that one particular

18 model. So, maybe there should be a requirement as, you

19 know, the action based on a failure is dependent on

20 whether it's an AEDM or test data generated rating.

21 MS. BARHYDT: So, we talked at length about

22 what would happen if an AEDM rating was off. So, I
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1 mean, we can use what we already came up with if the

2 AEDM rating is off. We have a whole mechanism that we

3 already worked out. So, really, I think the issue is

4 what happens if it wasn't an AEDM.

5 MR. MYERS: This is Frank Myers. I tend to

6 agree with what was just stated. If it was AEDM

7 generated we use the mechanism that we already have for

8 how you deal with models covered by that AEDM. If it

9 was test generated, then that test was inaccurate, so

10 it would be just that basic model, all the models under

11 the basic model would have to be dealt with.

12 MR. STEPHENS: Phillip Stephens, HTP. I

13 guess my question is, would the product family be

14 limited to one AEDM or could we use multiple AEDM in a

15 product family?

16 MS. BARHYDT: I haven't really thought out

17 exactly how this would work, but it seems to me that a

18 product family should not span AEDMs.

19 MR. EISNER: So, would that change

20 manufacturer's current advertising?

21 MR. SACHS: Laura --

22 MS. HOOTMAN: Laura, can you explain why you
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1 think that way?

2 MS. BARHYDT: Like I said, I hadn't really

3 given it any thought. It would just seem -- that was

4 more of a knee-jerk reaction of --

5 MR. SACHS: Well, Laura maybe I can address

6 this as a consumer. I get a brochure from a humongous

7 furnace company from my contractor and it says, "I

8 think you need the 80" and I say, "Well, maybe I can

9 get away with a 60,000 BTU because we keep the house

10 cold" or vice versa. Now, because those are two

11 different capacities, I think they have to be different

12 AEDMs.

13 MS. HOOTMAN: No. No, no, no.

14 MR. SACHS: Okay. Then I'll crawl back in my

15 hole.

16 MS. HOOTMAN: No.

17 MR. SACHS: We resolved that.

18 MS. HOOTMAN: I mean, no, the laws of physics

19 and the way refrigeration works, you can easily go

20 across.

21 MR. SACHS: Well, I would think that too, but

22 I thought we had come up against a barrier. So, I'm
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1 glad I'm mistaken. Thank you.

2 MR. STEPHENS: Phillip Stephens --

3 MR. EISNER: This is based on the way the

4 manufacturer advertises its products. Do manufacturers

5 advertise products in a way that would cause the family

6 to cross AEDM categories?

7 MR. MYERS: This is Frank Myers, PVI. It

8 certainly could. You might have one AEDM that works

9 well for larger pieces of equipment in that product

10 family and another AEDM that works well for smaller

11 pieces of equipment in that family.

12 I think here, understanding that that could

13 take place, I don't think changes things if you find

14 that a product test low and it was -- there were other

15 products under the same AEDM, all of those products

16 then would be suspect.

17 MR. EISNER: Is there any problem, Laura,

18 with having a product family here that crosses AEDMs?

19 I mean, could DOE live with that?

20 MS. BARHYDT: I'm just not sure. I'm going

21 to have to think about that one a little bit.

22 MR. HON: This is Charlie Hon. We've already
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1 discussed this in our category, we easily could,

2 because we've already been told that glass-doored

3 merchandisers and solid-doored merchandisers are

4 separate categories, yet those basic units, the only

5 difference may be the door, and there's definite

6 parallel between the energy usage -- they're not the

7 same, but there are definite parallels, and so they

8 could easily fall within AEDM.

9 MR. THARP: Rusty Tharp with Goodman. You

10 know, we could have an 11-0ER line of commercial HVAC

11 product where some of them have round two-plate fin

12 coils and some of them have micro channel coils and

13 those would definitely be different AEDMs, I would

14 believe, so I think that AEDM -- crossing multiple

15 AEDMs in one product family is actually something we

16 agreed to previously even and very possibly could be

17 done.

18 I'll also throw in, Bob had a good idea in

19 basically saying something to the nature that a product

20 family is a grouping of basic models as defined

21 separately, and I think he suggested that we might want

22 to talk about it over lunch.
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1 MR. FLY: This is Mark Fly with AAON. I'll

2 throw one more thing out. You know, when you're

3 talking about a product family, you could have a line

4 of products that crossed test standards because three

5 phase below five tons is classified by DOE as

6 commercial equipment and therefore, you know, you're

7 crossing from 210 based standards to 34360 based

8 standards. But you could also have an AEDM that

9 covered both of those, that spanned all the way through

10 that range, or an arm -- well, I guess you can't have -

11 - well, I guess it's an AEDM if it's three phase, it's

12 an arm if it's single phase.

13 MR. EISNER: It looks like we have an

14 equipment failure at the end of the table. Do we want

15 to break for lunch so this issue can be discussed?

16 MS. BARHYDT: Sounds like it.

17 (Simultaneous discussion.)

18 MR. EISNER: Is an hour going to be enough

19 for discussions on this subject and eating? All right,

20 why don't we get back here at 12:35?

21 (Whereupon, at 11:36 a.m., a luncheon recess

22 was taken.)
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1 MR. EISNER: How many people got here via

2 L'Enfant Plaza subway station? How many of you know

3 there was a baby born there during rush hour this

4 morning? The Washington Post was reporting that.

5 All right, we're ready to begin.

6 UNIDENTIFIED SPEAKER: The subway station?

7 MR. EISNER: The subway station way.

8 L'Enfant.

9 MR. KLEISS: What's the meaning of that name?

10 MR. EISNER: L'Enfant is the French engineer

11 who designed Washington, D.C., originally.

12 All right. Do we still have some discussion

13 on the last bullet? Anything worked out over lunch?

14 Any changes suggested?

15 MR. KLEISS: Jeff Kleiss, Lochinvar. I don't

16 think that we have reached a consensus, but the leaning

17 seems to be toward rather than saying "20 percent of

18 product families finding another way," to word that so

19 that we get the same scope of frequency of covering all

20 of the products that a manufacturer has in annual

21 testing, but not necessarily defining the groups by the

22 name product families. But I don't think that we've
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1 got satisfactory text to get us there yet.

2 MR. EISNER: Is it because there are too many

3 exceptions or because everybody's having a hard time

4 defining the general standard they want?

5 MR. KLEISS: Well, we go back to using the

6 term "basic model," but "basic model" could be an

7 individual product or it could be a whole group of

8 products, and that creates some lack of parity in the

9 assigned number of tests.

10 MR. HURST: I think conceptually we can agree

11 on a definition, but it would be hard to put a metric

12 to the definition, if that makes any sense. I mean,

13 Jill Hootman forwarded kind of a textbook definition,

14 which I can read, but attempting to put a metric

15 against that would be rather difficult.

16 MR. EISNER: In terms of coming up with a

17 number that had to be tested.

18 MR. HURST: Yes.

19 MR. MYERS: This is Frank Myers. I can toss

20 out something that might help with this. It's one

21 concept of being sure that nobody plays games with the

22 definition that's down at the bottom of the screen.
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1 MR. EISNER: Why don't we --

2 MR. MYERS: And that is to add following that

3 sentence, and I'll just read it and then we can type it

4 if there's any interest, in addition to that

5 requirement

6 "a minimum number of different basic models

7 must be tested every 5 years according to the following

8 chart:" 1 to 25, you have to test 5; 26 to 50, you test

9 7; 51 to 75, 9; 76 to 100 basic models, 11; 101 to 200,

10 you test 13; 201 or more, you test 15. That assures

11 that no matter how someone interprets their grouping of

12 models identified as advertised, if they have lots of

13 basic models, they're going to have some minimum number

14 of tests that they have to run.

15 MR. EISNER: And what was the first one, 1 to

16 25 was how many tests?

17 MR. MYERS: One to 25 would be 5.

18 MR. EISNER: And what if you had 5 or fewer?

19 MR. MYERS: I'm sorry?

20 MR. EISNER: If you had 5 or fewer. Instead

21 of 1 to 25, you had 3.

22 MR. MYERS: If you had 3, then you would test
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1 1 per year.

2 MR. EISNER: Okay, that wasn't inherent in --

3 MR. MYERS: I didn't put that in, but that

4 was -- again, this was just kind of tossing out a

5 thought. The 1 to 5 is -- or, I'm sorry, the 5 falls in

6 line with most, though not all right now, but I think

7 they're all changing to it, where every manufacturer,

8 even if they only make one model, one basic model or

9 one model, they have to test at least one unit each

10 year. So if it's retest that same one model, then

11 that's what it is. But to maintain -- to make sure

12 that their product is continuing to be produced, they

13 have to test at least 1 per year and 5, since these

14 numbers were per 5 years. If you have 1 to 25 basic

15 models, you have to test at least 5, which is 1 per

16 year.

17 MR. EISNER: People want to see this typed up

18 on the screen?

19 MR. MYERS: A minimum number of --

20 JEREMIAH: Where am I putting this?

21 MR. EISNER: At the end of the list.

22 MR. MYERS: It's right at the end of that
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1 sentence. It's the second sentence after that. A

2 minimum number of different basic models must be tested

3 every 5 years according to the following. Bad

4 language, but -- and then I had a semicolon there, 1 to

5 25 basic models, you must test 5; 26 to 50 is 7; 51 to

6 75 is 9; 76 to 100 is 11; 101 to 200 is 13; 201 or more

7 is 15.

8 So the manufacturer groups according to their

9 identified and advertised -- how they sell and market

10 their products. But this keeps somebody from playing a

11 game, hey, I make water heaters, I advertise water

12 heaters, I have one test to run. At a minimum they

13 have to do -- based on those tests according to how

14 many basic models they have.

15 MR. EISNER: Okay, comments? Mark, go ahead.

16 MR. FLY: Mark Fly with AAON. The only

17 problem I see with this is something that we really

18 haven't addressed yet. But if we have to create a

19 basic model for each one-off unit that we build as part

20 of the process, then that's going to drive everybody to

21 that 200 and above. So for small manufacturers who

22 make custom units that tend to build one-offs for
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1 everything, this is going to be -- you're going to be

2 doing the maximum number of tests for DOE.

3 MS. BARHYDT: Do you think that -- but given

4 the basic model definitions that we've come up with is

5 that your expectation that every one-off is going to

6 have to be a different basic model?

7 MR. FLY: I think that over time, with the

8 definitions that we have, because there may be other

9 things that we did not exclude that come up -- you

10 know, I guess either that or I've got to file a test

11 waiver every time I want to build a one-off model

12 because it doesn't fall within the category.

13 MS. BARHYDT: So a test procedure waiver

14 would be something different.

15 MR. FLY: Okay. So I can't really do that.

16 So if something else comes on the market, some new

17 widget that makes our efficiency great and that we

18 haven't thought of in our list, what happens? Do I get

19 a new model for that? One would think I would under

20 the current regulations that we're talking about.

21 MS. BARHYDT: So I think you could group it

22 in the same basic model if the characteristics were
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1 such that it was -- I'll use our language --

2 essentially identical. But given our understanding of

3 what it means to group things, but it would require you

4 to de-rate it, which, presumably, if it's a new

5 technology and you don't want to de-rate it, then,

6 yeah, that would be different basic model. But that

7 would be within the manufacturer's control as to how

8 they wanted to group or not group that. But if you --

9 say, you've got this new widget that makes it super10 efficient and you use that in five different one-off

11 designs, it seems like that still you might have your

12 new widget basic model as opposed to it being five

13 different basic models.

14 MR. FLY: But, you know, if the new widget

15 what it tends to do, at least in the air-conditioning

16 business, what it tends to do, if I'm applying it

17 broadly across a bunch of models, is it takes my basic

18 models and multiplies the number by 2 because I have

19 different, you know, capacities, I have different

20 efficiencies for the model before I put the widget on

21 there. So I'm just bringing it up. And we really

22 haven't delved deep into the one-off issue.
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1 MR. EISNER: Would there be room for an

2 exception for small businesses under the Small Business

3 Administration code? So you say if you are a small

4 business pursuant to definition in the SBA list and you

5 make one-off equipment, the testing shall be as

6 follows, with separate numbers.

7 MR. FLY: The Small Business code makes

8 businesses pretty small is my only comment. I mean,

9 it'd be nice if there was a little more graduation in

10 that, but there's not.

11 MR. EISNER: But DOE probably has authority

12 to set a different standard if it can justify it. They

13 have to do that through the regulation. But would that

14 be an approach that would --

15 MR. AMRANE: Karim Amrane, AHRI. But this is

16 not just a small business issue. I mean, there could

17 be large manufacturers who just make one-off type of

18 unit, too.

19 MR. EISNER: Yeah, but would it affect them

20 if they're a large business and they have lots of other

21 kinds of equipment? Would it be the same effect that

22 it would have on a small business that does just that?
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1 MR. HON: Charlie Hon. I have a question

2 because, unfortunately, when you start defining one3 off, I could take a base product and tweak it a

4 fraction different and it's suddenly a one-off because

5 it is not the original. And where do we get -- that's

6 the difficult part because we make some very small7 volume orders. They're slightly different than

8 anything else we've made. And energy test-wise we

9 could use a justification process and maybe in the AEDM

10 or something and come up with a number so we didn't

11 have to test it. But on this, then we have -- that'd be

12 just different numbers. We could manipulate the

13 numbers well. But the danger is if we suddenly have

14 everybody producing one, one, one, one, by some simple

15 changes, very basic design changes that may not make

16 any difference in energy efficiency, it's no longer the

17 same product.

18 MR. KLEISS: Jeff Kleiss, Lochinvar. If a

19 manufacturer has 200 different variants of products

20 that would have potentially different efficiency,

21 testing three units a year does not seem to be -- well,

22 it strikes me as reasonable.
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1 MR. HON: This is Charlie Hon. To give you

2 an idea, though, Energy Star's program we have 60-some

3 units, we test 6 a year.

4 MR. MYERS: This is Frank Myers, PVI. Do

5 note, although it's separated into two areas, the red

6 typing after the first part of the definition of

7 "product family." It says, "A minimum number of

8 different basic models to be tested every 5 years." So

9 where we're talking that this is a big number, that is

10 just three units per year at the maximum. I would say

11 it differently: If you have 200 basic models, a

12 minimum of 3 per year has to be done. You still should

13 be grouping -- a basic model should be as you identify

14 and advertise.

15 The addition was to put a floor on

16 manufacturers so they couldn't play games and say, hey,

17 I make -- using our company, we make water heaters. We

18 advertise water heaters, that's one model. Yes, we

19 make electric, gas, oil, combination, this technology,

20 that technology. We advertise all of those

21 differences, so we would be held to something

22 significantly more than 15. But any way you slice it,
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1 if we have 200 basic models, no matter what we told DOE

2 in terms of how we group our models, we would have a

3 floor of 15. It's just a way to protect the integrity

4 so you'd have to test it if you had that many models,

5 at least three per year.

6 MR. EISNER: Other thoughts?

7 MR. WHITWELL: This is Bob Whitwell, Carrier.

8 I'm having a little trouble here because I think, you

9 know, this scale type of thing or, you know, a

10 percentage is probably okay. But if I try to relate

11 this, and it's difficult because we're talking about

12 DOE basic models versus -- I'm trying to relate to what

13 we do today within AHRI. And the DOE basic model

14 definition is different than the basic model groups

15 that we use within AHRI. So there will be more basic

16 models per the DOE definition than we have today. And

17 I'm not sure, I haven't figured out what that is yet

18 for my company.

19 MS. BARHYDT: Right.

20 MR. WHITWELL: But today in AHRI we test 20

21 percent of the basic models -- model group every year

22 and this is much less than that. And so I'm just not
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1 quite sure how to reconcile that and whether that means

2 that we will reduce the number of units that we test in

3 the AHRI program or we have to increase the number of

4 units that are tested for manufacturers that are not

5 part of an AHRI or similar type program.

6 MR. MYERS: Bob, keep in mind -- this is

7 Frank Myers, PVI -- keep in mind that this is the

8 floor. If you go back to the chart where we're saying

9 here's the requirements, we use product family in that

10 and it says you have to test 20 percent of your product

11 family every 5 years.

12 MR. WHITWELL: Yeah, but we don't have a

13 definition for "product family," and I'm not sure we're

14 going to develop a good --

15 MR. MYERS: Yeah, that was this or at least

16 this attempt.

17 MR. WHITWELL: So we come up -- each

18 manufacturer comes up with their own definition of

19 "product family."

20 MR. MYERS: No. What they are supposed to do

21 is group the basic models that are identified and

22 advertised by the manufacturer. There was a concern
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1 that somebody might abuse that definition and the rest

2 of that in red was to put some kind of floor on it.

3 MS. MEYERS: Advertise to whom?

4 MR. THARP: Rusty Tharp with Goodman.

5 Actually I think --

6 MS. MEYERS: It makes a difference.

7 MR. THARP: -- what was added would be more

8 appropriate under the second bullet up above rather

9 than as a subpart of product family. And I agree with

10 Bob's comment on the quantity. And again, as an AHRI

11 member, you know, comparing to what we're doing today,

12 where we test a minimum of 20 percent, some product

13 families test one-third of the product family every

14 year, of the basic models every year. And comparing

15 that to these numbers, that basically -- these numbers

16 put it anywhere from half a percent to 7 percent per

17 year.

18 UNIDENTIFIED SPEAKER: In 20 percent.

19 MR. WHITWELL: No, no per 5 years.

20 MR. THARP: No, per year. So it's 2 to 20

21 percent per 5 years or half a percent to 6.7, 6.6666666

22 percent in 5 years.
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1 MR. STEPHENS: Phillip Stephens, HTP. Just a

2 question for clarification. Apparently it was a long

3 lunch. Is this what we're talking about as the

4 baseline or is this the baseline for VICPs or are they

5 the same?

6 MS. BARHYDT: The same.

7 MR. WHITWELL: Yeah, the minimum.

8 MR. STEPHENS: The minimum of 20 percent

9 tested combined with what you said before about the

10 manufacturers will have to pay for that? I cannot

11 support that. That would put too many businesses out.

12 MS. BARHYDT: So potentially testing one a

13 year seems very low to me, so is there some mid-ground?

14 MR. STEPHENS: Yes.

15 MR. AMRANE: This is Karim with AHRI. I

16 understand the concern, but, at the same time, we don't

17 want DOE to lower the bar too low. So there is already

18 an industry program in place for many of the products

19 we're talking about here that test significantly. I

20 don't know how many models a year, but we can give you

21 the statistics if you want to at the next meeting.

22 And I don't think we should be going the
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1 other way around and trying to lower the bar so low

2 that this industry program will mean nothing anymore.

3 MS. BARHYDT: So if -- thinking about the

4 relationship between the basic model definition that

5 we've come up with and the basic model group that AHRI

6 uses for its program, if we converted 20 percent basic

7 model groups into percent of basic models, do you have

8 any sense of what that number would be. Would it be

9 10, 5, 3? I mean, certainly there are a lot more basic

10 models than basic model groups, but do you have any

11 sense of --

12 MR. STEPHENS: Phillip Stephens, HTP. From

13 my experience, manufacturers sometimes choose to use

14 basic model groups, sometimes choose to use basic

15 models. Basic model groups are allowed in some

16 programs; they're not -- well, the interpolation method

17 isn't encouraged in other product groups. So there's

18 not any one specific answer that we have for that.

19 MS. MEYERS: This is Karen with Rheem, and

20 I'll differ with you just a little bit because the

21 discussion we're having now is on commercial HVAC,

22 water heating, refrigeration, et cetera. So, you know,
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1 I think the best way maybe to get to this is try and

2 define what a product family means for these categories

3 that we're talking about and then you can go back to 20

4 percent of product families should be tested. But now

5 how you define a product family for a commercial HVAC

6 product may be different than how you define a product

7 family for a commercial water heater. I think, you

8 know, we all in this room could probably come up with

9 something, but I think we're trying to make "product

10 family" fit a broad range of products here and I'm not

11 sure that's the best way to get to this.

12 MR. AMRANE: Karim with AHRI. I mean, to

13 follow-up on what just Karen said, actually those

14 definitions already exist. I mean, we have programs,

15 we have the definition of basic model groups that have

16 been used by industry for many, many years, so we can

17 start from there.

18 MR. MYERS: This is Frank Myers, PVI. Karim,

19 the one issue that would concern me about that is that

20 I know AHRI has a significant latitude of

21 interpretation of those definitions of basic models.

22 If you read them, they are in each one. AHRI provides
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1 consistency because they interpret it the same way

2 every time. I'm not sure if we use those same

3 definitions in a reg that everybody that read the reg

4 and was responsible to comply with it would interpret

5 it the same way as AHRI. That would be my concern.

6 MR. AMRANE: If the group is interested,

7 maybe the next meeting we could review those

8 definitions and see whether they're acceptable to the

9 group or not.

10 MR. DOPPEL: I think Harvey, Tim, and Louis

11 have been pretty quiet on this topic. It's time for

12 some pontification.

13 MR. SACHS: Same to you, buddy. This is

14 Harvey. I've been quiet because for the last couple of

15 hours I've been thinking what Karen has just said, that

16 I'm not sure that a product family carries across

17 species of products that we're talking about. I'm very

18 sympathetic to or very interested in the idea of

19 reviewing the AHRI definitions if only because they've

20 survived a generation of internecine warfare and,

21 consequently, might save us from some fights. But, on

22 the other hand, I might find that the council here
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1 reminds me that there are really bad definitions for

2 some interests that we have. So I'd love to

3 pontificate, but I'm still learning.

4 MR. HURST: Maybe that's the point. And I

5 don't know if this is feasible, but it seems to me that

6 this is a case of you don't know which -- we won't know

7 how this is going to play out until you kind of get

8 into it. If there was a process by which we could

9 review periodically to see what's working and what

10 isn't, I don't know if that's accounted for, but I

11 don't think you really know.

12 I can conceptualize around the product

13 categories or families or groups that I know. The ones

14 that I'm less familiar with, I can't even get my head

15 around it. And I don't think we could understand it

16 until we start doing it and see where the gaps are in

17 the process.

18 MR. EISNER: Is there a consensus we should

19 get the definitions from AHRI before the next meeting?

20 MS. BARHYDT: Yes.

21 MR. EISNER: Up on slides, we can just go

22 through each one where they can all be on a couple
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1 pages. I don't know how much room they take.

2 MR. SACHS: Neil, perhaps we could get them

3 sent out ahead of time.

4 MR. EISNER: Yeah.

5 MR. SACHS: I think there's a consensus that

6 we can't think of anything smarter.

7 MR. EISNER: So we're asking everybody to

8 agree they're stupid or?

9 MR. STARR: This is Louis Starr with NEEA. I

10 think if we could get that ahead of time because maybe

11 we could look at the -- or actually even DOE, maybe

12 they already have them, but just kind of the legal

13 definitions and how it would work in the context of a

14 regulation as opposed to a voluntary program that has

15 some flexibility and maybe a little more understanding

16 of how things might actually work. It might work

17 differently in the regulation process.

18 MR. EISNER: Think you can get them out by

19 Monday? Is that good enough for everybody, Monday?

20 UNIDENTIFIED SPEAKER: Tomorrow.

21 MR. EISNER: For tomorrow? Can't get it any

22 faster than tomorrow. Okay. Is that okay with
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1 everybody?

2 MS. BARHYDT: Yes. I just want to make one

3 other comment that the reason I asked about scaling

4 from a basic model group or a product family down to a

5 basic model is that that's something that you'll

6 already be certifying and it's a commodity that we've

7 all figured out now. And there are tradeoffs when a

8 manufacturer decides how to group things, and so it

9 seems to me like that already is sort of a mechanism

10 that we could use if we could come up with the right

11 number rather than introducing a second concept and

12 having additional interpretational issues; that that's

13 something that the manufacturer's already making

14 decisions about I want to group these things, I don't

15 want to group these things, and that that might be the

16 easiest thing for us to use as our counter.

17 And so I just ask that you also keep that in

18 mind as a possibility. And certainly we'll look at the

19 groupings and we'll talk about it more next week as to

20 what really makes sense. But I'd like to keep "basic

21 model" as a possibility on the table.

22 MR. STARR: This is Louis Starr with NEEA
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1 again. One last thing I had kind of thought about, but

2 I didn't really see a good solution for. In the

3 testing, I guess you're going for 20 percent a year,

4 but obviously each year you introduce new models, so

5 I'm wondering how much the supply of new models in

6 there and it seems like you will not necessarily cover

7 all of the models in 5 years if you have new models

8 coming in and others ones going out. So I don't know

9 what the percentage should be, but it seems like there

10 might be some thought around that concept.

11 MS. HOOTMAN: This is Jill from Trane.

12 Discontinued models are also included in the count of

13 models certified to AHRI. So your discontinued models

14 are also included and can be pulled for testing. So

15 you do pretty much get, in the 3-year period,

16 everything looked at.

17 Rusty, I think, and others have said that,

18 you know, in light of the basic model description in

19 DOE, which is different than AHRI, recognizing that

20 fact, let's just give -- I'll just give you a little

21 bit of numbers to understand the magnitude you might be

22 talking about. Currently, under AHRI, Trane has over
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1 900 basic model groups. That's not even the definition

2 you just described in DOE. I know our count will go

3 up. Twenty percent of that is 180 models. Ready to

4 test that much? Am I ready to test that much? That's a

5 lot. Are the labs ready for that much?

6 MS. MEYERS: I think we can agree more than

7 one.

8 MS. HOOTMAN: We can agree more than one.

9 MR. HURST: I think the other point is, as

10 you mentioned, new products are introduced, but some of

11 this products last more than a 5-year period, so the

12 length of your platform may extend sometimes 10 years

13 and beyond. So, you know, there's new product coming in

14 all the time, but some of your product's not always

15 going out all the time. I don't know if that makes

16 sense.

17 MR. EISNER: Okay. Anything else on this

18 subject?

19 MS. HOOTMAN: And this is Jill. I guess I

20 would also add that I would roughly put those in around

21 30 product families. So that 900 is in roughly 30

22 product families by my definition of a product family.
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1 MR. THARP: Is that commercial HVAC, Jill?

2 MS. HOOTMAN: That's commercial HVAC, water

3 source heat pumps, you know, everything within those;

4 commercial furnaces, everything within those.

5 MR. BALLO: This is Tim Ballo. You know, we

6 set up a process for the AEDM testing where there were

7 consequences for failures, some of which involves

8 additional or different test results being provided.

9 With more and more testing, the more you fail, then I

10 guess one possibility here is to go the other way for

11 verification testing, where you would start off testing

12 a certain percentage per year and if you just don't

13 have problems, if everything's passing, that number

14 could come down over time. And I don't know if that's

15 one way to address the problem of, you know, test

16 burden, but I found something we haven't suggested yet.

17 MR. SACHS: This is why we have Tim around.

18 MR. BALLO: Oh, that's why.

19 MR. SACHS: This is Harvey. And I like this.

20 My eyes are lighting up because it's a reward for good

21 behavior and building that into the program across

22 small and large, with limits, I think is something
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1 which has worked on some other kinds of programs, some

2 new construction quality verification programs, for

3 example, in California. So we certainly would be open

4 to that concept of good behavior rewards. I don't know

5 how that plays with the different product categories

6 you have at AHRI, but, as a general principle, I could

7 be made happy.

8 MR. AMRANE: Karim with AHRI. The way we do

9 it at AHRI is that if you have a percentage of failure

10 above a certain number, then you're subject to

11 penalties. And penalties mean additional tests and

12 also sometimes financial penalties, too, so that's the

13 incentive to be below the threshold.

14 MR. SACHS: Karim, what I'm hearing novel

15 from Tim is a balance with gold stars for good

16 behavior, to bring it back to the kindergarten metaphor

17 we all understand.

18 MR. STEPHENS: I might be able to go up to

19 two per year with that.

20 MR. EISNER: Do I hear three?

21 MR. SACHS: More.

22 MR. EISNER: Okay, anything else on this page
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1 we want to discuss now before we get on to some of the

2 other issues on verification?

3 MS. BARHYDT: So, I think we talked about the

4 first red bullet point, that all products within DOE5 covered product category must be in a DOE-approved

6 verification program. And so I think that's one of the

7 fundamental ideas that DOE is working from in this

8 discussion.

9 The list of all certified models, obviously

10 everything will already be certified, so we talked

11 about that.

12 We're going to talk more about product

13 families next time.

14 And the third bullet point, I know somebody

15 said that they thought that that wasn't relevant for

16 this. And so I just want to revisit that and see

17 whether everybody agrees to remove that bullet point

18 or?

19 MR. HALLEY: Geoff Halley, ABM. I would like

20 to see it taken out. It sounds like an invitation to

21 join an elite club and I think the fifth bullet covers

22 it really.
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1 MR. THARP: Rusty with Goodman. I think

2 there needs to be some sort of requirement for anybody

3 entering the marketplace. I don't think it's wise to

4 just open the door for anybody to come in and introduce

5 all the products without having some sort of pre-check

6 put in place.

7 MR. SACHS: This is Harvey, and I agree with

8 Rusty's goal. And I'll name what my fear is

9 that we certainly have seen with other kinds of

10 commercial products: what I would consider systematic

11 efforts to subvert U.S. standards by certain categories

12 of imports, where you can do a very quick flood, sell a

13 bunch of crap, and when you get caught and your hand

14 slapped, you get out.

15 I'm not sure what require certification of

16 new participants means. I'm not sure how we protect

17 consumers and industry from that threat and I'm not

18 sure how big a threat it is in commercial equipment.

19 But I would hate to look back and say why didn't we do

20 something, even if it's not the wording of that bullet.

21 MR. MYERS: This is Frank Myers, PVI. Recall

22 that in order to sell something, to introduce into
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1 commerce, it first has to be entered into the

2 directory, and there are two paths to enter it into the

3 directory:

4 you have to either test the basic models or

5 you have to generate an AEDM which you validate test.

6 So there is already testing of new participants in the

7 market by way of their entry into the program. That's

8 even before you get to the verification testing.

9 MR. STEPHENS: Phillip Stephens, HTP. I

10 think the department said they did not want to handle

11 the validation of the AEDMs. They're requiring the

12 manufacturers to maintain their own data for the AEDM

13 validation.

14 MR. MYERS: That's true. The testing,

15 however, is supposed to be made available, not sent in,

16 but made available to DOE, the validation testing.

17 MS. BARHYDT: So I can tell you when I read

18 that and I translate it from a voluntary program into -

19 - sort of translating it into DOE reg speak, the way I

20 would -- if I was going to try and have that kind of a

21 requirement, I would say that it would be a requirement

22 upon initial certification in a product area to provide
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1 DOE the test data with the certification. And I'm not

2 saying that we think that that should be required, but

3 that's what I would interpret that to mean in a

4 regulatory framework.

5 MR. STANONIK: Frank Stanonik with AHRI.

6 Yeah, and Laura, I think, as you kind of said there,

7 and right now nobody is suggesting that that would be

8 the requirement for every new model, okay, I think in

9 terms of the way the thing is structured that becomes

10 very difficult and unworkable for the industry. But

11 from the perspective of an operator of a certification

12 program, let me try and explain why that makes sense.

13 Okay?

14 We have Frank's Furnace Company. I'm

15 entering the AHRI furnace program for the first time.

16 I'm asking the AHRI certification program to stand

17 behind my 100 basic models. All right? And I'm going

18 to give them -- I'm going to send all my entries to

19 Bill and say, hey, Bill, here's by check, put them in.

20 All right. And even though the federal regulations

21 says, Frank's Furnace Company, you have run all those

22 tests for all those ratings and you comply with the
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1 law, you better, you good citizen, okay, the fact is

2 the other part of this, the other part of this contract

3 is that there is now -- I'm going to be able to put

4 AHRI's label on there.

5 And so, as the operator of a certification

6 program, to qualify this new participant we need some

7 assurance, at least some level of assurance, that they

8 have run -- that those tests that would -- that those

9 ratings that we're being asked to, in essence, put our

10 name behind have been determined based on tests run

11 properly. And so that's why that kind of requirement

12 needs to be there for a certification program.

13 Because, in fact, we don't test -- you know, again, it

14 is mainly a verification program. So over some period

15 of time we're going to look at most of those models,

16 but we're not asked to, oh, only list these five this

17 year and add another five next year. We're asked --

18 and we feel our obligation or our services, we list all

19 100 the day you're qualified for the program. And so

20 that's a necessary requirement.

21 MR. STEPHENS: Phillip Stephens, HTP. I

22 think the question I would have after that excellent
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1 point from Frank is the first time a new company enters

2 the market, not a new product, but a new company enters

3 the market, would the DOE validate their very first

4 AEDM or test report?

5 MS. BARHYDT: We don't know. There's no

6 regulatory requirement for it. And so the question is,

7 is that something that you think is appropriate?

8 MR. MYERS: This is Frank Myers, PVI.

9 Phillip, were you saying to validate the AEDM or to

10 accept test data and make sure that the test data is

11 properly done?

12 MR. STEPHENS: Yes, because those are the two

13 methods.

14 MS. BARHYDT: It would have to be the latter.

15 It would DOE asking for test data. It wouldn't be us

16 going in and checking their model.

17 MR. DOPPEL: Paul Doppel with Mitsubishi.

18 Previously, in the past you haven't certified

19 commercial products, so this is all new territory. And

20 so, again, you know, you were asking with your initial

21 slide what should we do? And this is kind of our

22 solution. I mean, this is not a voluntary. This isn't
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1 like requirements for participation in the product

2 categories that we have been covering so far. That's

3 the intent of this.

4 MS. BARHYDT: So is everybody saying that

5 they think that should be a requirement?

6 MR. THARP: Rusty with Goodman says yes.

7 MR. MYERS: This is Frank Myers, PVI. Let me

8 make sure I understand what "that" requirement is. Are

9 you saying, Laura, that should it be a requirement that

10 the validation test for the first AEDMs entered by a

11 company when they're first entering the marketplace,

12 that we send the test data that validates the AEDM to

13 you for your scrutiny? I certainly wouldn't have a

14 problem with that and I think there is some benefit to

15 it if it's actually looked at. So if it were limited

16 to new entrant into the market, like first AEDM for a

17 product class, something like that, I wouldn't have a

18 problem with it.

19 MR. DOPPEL: Yeah, Frank, I think you're

20 confusing this because there's no discussion about

21 AEDMs with this. This is physical tests. The AEDM

22 requirement is separate from this.
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1 MS. BARHYDT: Well, I think what he's saying

2 makes sense in that, okay, so I'm a new company, I've

3 never sold in the U.S. market before and I started

4 manufacturing products, and I submit a certification to

5 DOE. That certification may be based on an AEDM, it

6 may be based on testing. And I think what I'm hearing

7 is that there's at least several people in the room who

8 think that when I submit that certification, I should

9 provide my test data, whether it's test data underlying

10 my AEDM or its test data underlying my certification.

11 One way or the other, I should submit that

12 certification with test data to be reviewed by DOE.

13 MR. DOPPEL: No, I think what we're saying is

14 that this is what would have to happen, that 20 percent

15 of their products would have to be tested by a third

16 party.

17 MR. KOJAK: This is Mike Kojak with UL. Can

18 you clarify something? When you say a "new company,"

19 are you talking about an import company or a domestic

20 company or both?

21 MS. BARHYDT: Either.

22 MR. DOPPEL: All of the above.
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1 MR. KLEISS: Jeff Kleiss, Lochinvar. One way

2 that that could be defined or identified is that the

3 CCE, when you have to --

4 MS. BARHYDT: When you create a CCMS account

5 --

6 MR. KLEISS: Thank you.

7 MS. BARHYDT: -- you have to get a user

8 registration form. It would be very easy for us to

9 tell when there was somebody new certifying.

10 MR. AMRANE: This is Karim with AHRI. But

11 the qualification that you're talking about is

12 basically that. Maybe that should be the role of the

13 VICP that would do that function.

14 MS. MEYERS: There has to be some way for new

15 participants to be qualified because what people like,

16 you know, Tim and Harvey and PG&E, they're going to be

17 comparing the information that they put in that

18 database to other companies who've been going through

19 all this certification and assessment testing for

20 years. So here's a new participant and there needs to

21 be some assurances by, you know, the people that are

22 using this database that the new participant has
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1 properly rated their products. And so for me, if I'm

2 from Rheem, if we've been doing this for a while and we

3 have a lot of test data to back it up and some new

4 participant comes in there, before that can go into the

5 DOE database there needs to be some qualification that

6 their ratings are, in fact, correct. Maybe it's

7 increased assessment for the first 3 years, I mean, I

8 don't know.

9 But there has to be something because people

10 are comparing what they are listing in that database

11 compared to what we are listing. And I'm not going to

12 be happy if Frank's Furnace Company suddenly starts

13 putting all this data in there and he's a brand-new

14 participant, and people are using that data to perhaps

15 select his products versus my products, who have doing

16 this for years. And we have, you know, been properly,

17 you know, tested and all that kind of stuff. I don't

18 think it's fair that new participants are not held up

19 to some type of scrutiny by the department to make sure

20 that their data is, in fact, correct.

21 MR. THARP: Rusty Tharp with Goodman. I'll

22 tack on to that. I guess maybe the way I would compare
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1 it is for most manufacturers, if you're going to have a

2 new supplier, there's a qualification process that

3 pretty much every company has for new suppliers. And

4 once you validate that that supplier can provide you

5 good quality components, then typically the checks that

6 you do, you do some initial checks that are more

7 rigorous than your checks after they have been a

8 supplier for months or years. And it's the same type

9 of principle. So as before we're entering product into

10 commerce, we want to check and make sure that that

11 manufacturer is supplying to the market good quality

12 products that meets its performance ratings.

13 MR. KOJAK: This is Mike Kojak with UL. How

14 about if the company entering the market, if they rated

15 with an AEDM, they have to have tested by a third-party

16 lab the two -- two of the units that they used to

17 develop the AEDM to prove that those are accurate? And

18 if they say they did it by testing, you randomly choose

19 some of the units to randomly test to verify that it

20 was done correctly.

21 MS. BARHYDT: So from my perspective,

22 definitely don't want to go there. We already did
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1 AEDMs and we agreed on it and it's been to the ASRAC

2 and it's going on in a Notice of Proposed Rulemaking,

3 so I really don't want to revisit that.

4 MR. SACHS: This is Harvey, and I'd like to

5 go back and riff on something Karim said about the blue

6 highlighted line. Right now I'm seeing this as

7 qualifications for voluntary programs, whether is an

8 AHRI program or Frank's Accreditation Program or, more

9 likely, Mike Kojak or Judd. And it seems to me that

10 AHRI has invested a great deal in differentiating

11 products that are identified by its service mark. Look

12 for the AHRI seal. It's the Intel of air-conditioners

13 or whatever.

14 Now, I'm worried a little bit about sparking

15 a race to the bottom. But, on the other hand, in terms

16 of qualifying a voluntary program, I'm not sure that

17 DOE needs to set the same bar that AHRI has. If UL or

18 CSA wants to risk its reputation with a program that

19 has a slightly different, more or less stringent

20 qualification, I'm not sure that that's not the way the

21 market's supposed to work, but I do have concerns

22 about, as I say, the race to the bottom of we'll
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1 qualify you for less cost and fewer tests than anybody

2 else in the world. So I'd like to hear reactions to

3 that.

4 MR. THARP: This is Rusty. And as far as the

5 -- I don't want to say that the minimum requirements

6 should be what AHRI has. And reading from the UOEOM,

7 to get into the program, if you're less than 250,000

8 BTUs, you have to test 30 percent of an applicant's

9 basic model shall be tested with a minimum of 2 models.

10 So if it's bigger than 250, it's 20 percent. So that's

11 the minimum just to get into the program.

12 If we do something less than that as the

13 minimum, I'm fine with that, but I think there ought to

14 be some sort of minimum check. If it's 10 percent,

15 whatever this committee feels is the right number, I

16 still think there ought to be some type of check to

17 make sure that what's going into the market on a new

18 entry for a new product line is proper.

19 MR. SACHS: So, this is Harvey. Rusty, we're

20 just arguing about the price. That's an old human

21 transaction question. So I could be comfortable with

22 that, with DOE qualifying VICPs and including some
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1 requirement in the VICP for entry to its program. I'm

2 not sure I'm comfortable with -- or, like you, I think

3 I'm more comfortable with that as a minimum threshold

4 than as necessarily being a replica of what the leading

5 industry association has established for its comfort.

6 MS. MEYERS: This is Karen with Rheem. But I

7 think, you know, this also has to go back to DOE. So

8 this is almost -- this is a requirement for VICPs, but,

9 to me, this also needs to be a requirement for DOE. To

10 post information from a new participant onto the DOE

11 website, I think DOE has to have some responsibility in

12 qualifying this new participant rather than just

13 accepting the data that they send in so that it can be

14 compared to all these other companies who have been

15 doing this for years. So that is my concern is that

16 this is not only a requirement for a VICP, but this is

17 also a requirement for DOE.

18 UNIDENTIFIED SPEAKER: Agreed.

19 MR. BAUMAN: This is Jeff Bauman. I just

20 want to add in. We keep using the word "participant."

21 When we're talking about DOE, we're not talking about

22 choosing to be a participant anymore. We're talking
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1 about a federal requirement. I mean, companies that

2 don't have a VICP now, if it's a DOE program,

3 everybody's a participant. It's not an optional -- I

4 think "participant" is the wrong word. We're not

5 talking about that.

6 MS. BARHYDT: Yeah. could you change that to

7 "require qualification of market entrants," or

8 something like that?

9 MR. EISNER: And what should the requirements

10 be? What would be the sub-bullets under this heading?

11 MR. STEPHENS: Phillip Stephens, HTP. Before

12 we get to that question, I think there's an elephant in

13 the room that we need to pay attention to. Is the DOE

14 going to consider these in addition to VICP

15 participation or will the VICP participation take the

16 place of these federal minimums?

17 MS. BARHYDT: Okay, so I'll try and say this.

18 So what DOE is hoping to do is to require all

19 manufacturers to participate in some sort of

20 verification program, plan, framework, something,

21 whatever you want to call it. And that that program or

22 plan could be administered by a test lab, an industry
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1 group, the manufacturer themselves, but it would have

2 to be DOE- approved and it would have to meet certain

3 requirements to get that DOE approval.

4 MR. HURST: And these are those requirements

5 that we're talking about?

6 MS. BARHYDT: Yes.

7 MR. HURST: Okay.

8 MR. FLY: This is Mark Fly with AAON. So if

9 AHRI becomes a DOE-approved program, then as long as

10 Mark's Air-Conditioning can join AHRI's independent

11 manufacturer, then I have met the requirements of this

12 because I have joined an approved program.

13 MS. BARHYDT: Right.

14 MR. FLY: And so, I don't really have to go

15 through any of this extra stuff direct to DOE. Now, if

16 I choose to develop my own plan, then I have to go to

17 DOE, you have to approve my plan, and you're going to

18 be a lot more involved in this.

19 MS. BARHYDT: And I'm going to make sure that

20 your plan has all of these --

21 MR. FLY: That I've done all these things in

22 it.
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1 MS. BARHYDT: -- requirements in it.

2 MR. FLY: Okay.

3 UNIDENTIFIED SPEAKER: Right.

4 MS. BARHYDT: Yeah.

5 MR. KLEISS: Jeff Kleiss, Lochinvar. If you

6 look on page 13 of the handout, the bottom slide, the

7 bottom bullet I think covers what we're talking about.

8 MS. BARHYDT: Slide 13 or page 13?

9 MR. KLEISS: Page 13.

10 MS. BARHYDT: Page 13, okay.

11 MR. KLEISS: That would be about Slide 26, I

12 guess.

13 MS. BARHYDT: Mm-hmm.

14 MR. KOJAK: This is Mike Kojak with UL. I

15 have a question. If, let's say, a company wants to

16 start its own VICP for the DOE, do they have any

17 responsibility to DOE for the people that they're in

18 their program for?

19 MS. BARHYDT: Say that one more time.

20 MR. KOJAK: So let's say I start my own VICP

21 organization and I have Mark's Air-Conditioning wants

22 to join, and I'm supposed to be witnessing, testing, or
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1 whatever is going to be happening at his location to

2 make sure he's doing the testing properly. If he's

3 doing something found later not to be done correctly,

4 is the owner of the VICP program, approved DOE program,

5 which would be my company, liable for what they're

6 doing since I'm supposed to be witnessing and

7 overseeing what they're doing?

8 MR. SACHS: You got big pockets?

9 MR. KOJAK: Because the reason I'm asking is

10 because then will -- let's say I wanted to start my own

11 VICP organization, can I put my own requirements on a

12 brand-new company that wants to join mine, that they'll

13 have to meet of my requirements for me to believe that

14 they're DOE --

15 MS. BARHYDT: Yeah, these are minimums.

16 MR. HURST: You can do anything you want to,

17 but my understanding is these are the minimum

18 requirements you'd have to meet. You could set up your

19 program. You've got to convince his air-conditioning

20 company or whomever to join your program provided that

21 they meet these base minimum standards.

22 MR. KOJAK: But I can have requirements over
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1 and above this?

2 MR. HURST: You can do anything you want to.

3 MS. BARHYDT: Yeah.

4 MR. HURST: It's a free country.

5 UNIDENTIFIED SPEAKER: But with the owner of

6 the --

7 MR. HURST: Nobody may join.

8 MS. MEYERS: Can we put that other slide back

9 up.

10 MR. KOJAK: With the VICP, let's say if I

11 started my own, would I be partially liable if the

12 people that I'm overseeing are found to do something

13 wrong?

14 MS. BARHYDT: To DOE?

15 MR. KOJAK: Yeah.

16 MS. BARHYDT: So my expectation is that the

17 VICP -- the DOE-approved program, whoever's running

18 that program, is responsible for making sure that the

19 program is run in accordance with whatever was the

20 document that DOE approved as the framework. If the

21 manufacturer's pulling fast ones and manages to get

22 away with something, that's on the manufacturer. If
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1 you didn't do your job, the consequence would be we

2 would revoke your approval.

3 MR. KOJAK: Thank you.

4 (Off microphone discussion.)

5 MS. BARHYDT: Oh yeah, I don't like lawyers

6 either.

7 So where did we end up? Is this something

8 that you think should be -- well, and actually we've

9 talked about it two different ways. One is that it

10 would be a requirement for somebody running a program

11 to have some kind of a qualification to be in the

12 program, but then the other way that I had talked about

13 it was simply across the board, before DOE accepts an

14 initial certification from a new market entrant, they

15 would have to provide test data to support their

16 certifications.

17 So we've talked about it two different ways

18 and we've heard a lot of different views. Where are

19 people on what we've discussed?

20 MR. HALLEY: Geoff Halley, ABM. I like the

21 idea of submitting test data. In the segment of the

22 boiler industry that I'm involved there are a lot of
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1 other things that a new company would have to do to

2 produce in this country.

3 For example, they've got to set up an ASME

4 code qualification program. They've got to have, you

5 know, a written and an audited inspection program on

6 the (inaudible) itself. I've got to comply with the

7 emissions, you know, from EPA. They've got to have a

8 UL label in the great majority of cases, so they've got

9 to interface with UL from the point of view of safety

10 circuits, you know, the whole safety of the product.

11 So there are a lot of things that they've got to do

12 already and I think that, you know, submitting the test

13 data to DOE should be one of them, yeah.

14 MR. MYERS: This is Frank Myers, PVI. I

15 think if the starting point for VICPs that have been

16 approved by DOE, there would not be a need for

17 submission to DOE of any of the initial qualification

18 of a new market entrant. That would be handled by the

19 VICP because that's a part of the program requirements.

20 So I don't think the VICP needs to be turning in new

21 entrant data.

22 For someone not in a VICP, I think it makes
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1 all the sense in the world that for each product class

2 that is newly entered into the system, that a set of

3 test data be provided to DOE to determine Does this

4 person even know what they're talking about when they

5 provide me all these numbers? So I wouldn't have a

6 problem with that. But I wouldn't want --

7 MS. BARHYDT: Can you say the last part

8 again? Because I thought it was different from what you

9 said at the beginning, so I'm a little confused.

10 MR. MYERS: For VICP programs, I don't think

11 they should need to provide this test data to DOE for a

12 new entrant. If you are not in a VICP program where

13 they're taking care of that monitoring and supervision

14 of the new entrant, then it makes sense to send to DOE

15 the test package for each product class that you're

16 entering in. So it's not just that you've been in a

17 program before, but maybe you were in for water

18 heaters, now you've begun making furnaces. You should

19 send in data from a furnace test. So whenever you

20 enter a -- not just a new entrant into the program, but

21 a new entrant into a new product class, there should be

22 an associated test data provided to DOE.
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1 MR. FLY: Mark Fly with AAON. So you have

2 already approved DOE at this point, the VICP's

3 requirements which you're looking to see that has some

4 initial test data to approve. So I only really see

5 this as one path: either you join a prequalified VICP,

6 which requires you to do testing or submit test data as

7 part of that you have vetted through the approval

8 process, or you have to do that to DOE as part of your

9 test plan.

10 MS. BARHYDT: So I'm going throw in a little

11 concept here that if we're requiring that you

12 participate in a verification program, a DOE-approved

13 verification program, then I would like to see in the

14 certification, whether it's for -- in a mechanic,

15 mechanistic sort of way, whether it's on the user

16 registration form or it's somewhere in the

17 certification report, an identification of which

18 program you're in. And that might address this if we

19 said whatever program you're in, they have to have some

20 kind of initial qualification. And then whenever we

21 get a certification from somebody new, if it doesn't

22 say that they're in a -- which program they're in, then
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1 they haven't provided one of the things they're

2 required to do to make a valid certification. So they

3 have to identify which program they're going to be

4 participating in.

5 MR. SACHS: Laura, this is Harvey. I think I

6 was hearing something slightly different and marking

7 Mark's fly-by-night -- oh, wait, that wasn't the name.

8 Came closest to it that I'm seeing it as two

9 paths: there's having the VICP as an interlocutor

10 between the manufacturer and DOE, an agent, and there's

11 self-certification. In self-certification, the test

12 data must be provided and that's a little different

13 from saying that everybody's got to join AHRI or Mark

14 or UL or CSA. Is there going to be a route for

15 submitting the data as Charlie's Refrigerators without

16 joining anybody else's program?

17 MS. BARHYDT: No, what we're talking about is

18 requiring participation in some kind of verification

19 program. It can be a self-run program if it meets all

20 of these criteria and it has the independence that we

21 want to see. But there should be some plan by which

22 that manufacturer's products are going to get verified.
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1 MR. EISNER: So the answer's yes, but they

2 have to meet the requirements.

3 MR. HON: So basically I won't --

4 MR. SACHS: No, the answer is no. Self5 certification --

6 MS. BARHYDT: To his question it's no.

7 MR. SACHS: Self-certification is not an

8 option for those manufacturers who don't want to join a

9 trade association. They will have to join some other

10 VICP.

11 MS. BARHYDT: Or run their own.

12 MR. SACHS: I heard Laura saying they could

13 create their own program. What's the difference

14 between run your own and self-certification?

15 MR. HON: I think I can explain the

16 difference. I think I've got this pretty well down

17 because we had previous discussions. Basically, what I

18 would do is I will take what we have, we will send it

19 in to them. I will, in the process, set up a schedule

20 with the DOE and say, okay, I'm going to have a third21 party verifier verify X, Y, Z over here, over here,

22 over here, and then submit the data from the
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1 verification testing to them. The third party verified

2 our program setup.

3 And then in a few months, I will send her

4 another notification saying, okay, here's our

5 spreadsheet of different units in different families.

6 We did A, B, C, so this time we haven't done C, D, E

7 yet, so let's take one of those and give her a choice

8 or give her an option. You know, this is what we'd

9 prefer because it's in stock, and then submit it to you

10 and you would approve those. Right?

11 MS. BARHYDT: That would be one way to do it.

12 I mean, I don't want to limit how this might work.

13 MR. HON: Right.

14 MS. BARHYDT: But that is a --

15 MR. HON: A viable system --

16 MS. BARHYDT: -- possible way of doing it.

17 MR. HON: -- because we have third-party

18 verification of our product, we do not have to go

19 through a secondary source as long as we meet your

20 minimum criteria.

21 MR. THARP: So then Mark's Fly-By-Night Air22 Conditioning can come over to Mike Kojak's UL or some
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1 facility and have them come to his lab and all the

2 testing's done at his lab, witnessed by UL, and that

3 meets -- and DOE's satisfied with that.

4 MS. BARHYDT: So I'm not going to say yes to

5 that. I'm going to say --

6 MR. WHITWELL: And you shouldn't.

7 MS. BARHYDT: -- we haven't figured out what

8 these requirements are going to be, but based on the

9 premise that we have a set of criteria that is what

10 constitutes DOE approval and that -- and a key element

11 of that is going to be a level of independence that DOE

12 is comfortable with. And so that's why I'm kind of

13 hedging is that I think it's going to be challenging

14 for a manufacturer to achieve that level of

15 independence, but I don't think it's impossible for a

16 manufacturer to achieve that. And I can think of a

17 variety of different ways that that might be obtained

18 for different manufacturers. They may come up with

19 different mechanisms to do that, but it would be

20 possible for a manufacturer to have their own plan that

21 DOE approves to get their products verification tested.

22 MR. KOJAK: This is Mike Kojak with UL. To
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1 make a comment, what Charlie was talking about, that

2 would kind of contradict the last bullet unless their

3 lab was under the supervision of an ISO 17025 lab.

4 That was something that was left out with that. I

5 mean, if his lab was already under scrutiny from a

6 third-party lab that ISO 17025, I would think what he

7 explained would work.

8 MR. HON: Well, that's one of the things that

9 we are, so we don't have that issue because --

10 MR. STEPHENS: I think we that as an

11 outstanding item. Laura mentioned she wants to review

12 the 17025 guide before we actually put the text in.

13 MR. STARR: This is Louis Starr with NEEA.

14 You know, it seems like if you just -- instead of just

15 requiring the new market entries to provide the test to

16 DOE, it takes a level of DOE having some of the things

17 you're not sure about what you're going to do. If that

18 happens, then it kind of protects everybody from the

19 legitimate labs to the people that maybe aren't doing

20 it well.

21 In other words, AHRI is going to have no

22 problem with what they're doing whereas Bob's new
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1 testing laboratory might have some problems. But if

2 you just get the test data, then you're kind of taking

3 care of it that way. It seems like that might be

4 something that works in the interest of everybody,

5 legitimate people as well as - - well, not in the

6 interest of the people who are not legitimate, but just

7 a thought.

8 MS. DANE: This is Mary from Traulsen. Just

9 a question. So as you're collecting all this test data

10 for those of us who don't join a voluntary industry

11 program, where does our test data go? And is it

12 something that somebody could FOIA out of you?

13 MS. BARHYDT: So people can file FOIA

14 requests. Whether or not that test data would be

15 released is an open question, but it is not --

16 MS. DANE: But participation in a voluntary

17 certification program, they're allowed to hold the test

18 data. Is that what you're saying?

19 MS. BARHYDT: We haven't actually discussed

20 that yet.

21 MS. DANE: Okay, because that would be one of

22 the things that wouldn't be a level playing field for
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1 us, that their data would be protected under that level

2 and ours would be out available for FOIA. We couldn't

3 agree to that.

4 MR. FLY: This is Mark Fly. I mean, that

5 data can always be subpoenaed, too.

6 MS. DANE: That's fine, but whether it's -- I

7 mean, it might be easier -- it's a little bit harder

8 for them to go through it and subpoena it and we have

9 our own lawyers and stuff like that.

10 MS. MEYERS: So I have a question. So to

11 ensure we keep this on a level playing field, if you

12 are a company that has submitted your own plan to DOE

13 to, you know, self-assess or whatever, are you given an

14 advantage because then you can pick and choose what

15 products you want to test per year? Or should there --

16 it seems like there should be some qualification for

17 companies that do that.

18 MS. BARHYDT: I agree and we have not

19 discussed selection yet. I mean, to me --

20 MS. MEYERS: I think that's important because

21 --

22 MS. BARHYDT: Selection is going to be a key
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1 element of how this works.

2 MR. WHITWELL: Bob Whitwell from

3 Carrier. There's another thing, too, that we need to do

4 to make sure we have a level playing field and that's

5 to do something like with the AHRI program. AHRI goes

6 and picks the units. And then they get sealed, you

7 know, marked and shipped, and so the manufacturer

8 doesn't get a chance to take that unit, test it quick

9 first to make sure it's okay. So there needs to be

10 some process to make sure that some third party picks

11 the units right off the production floor or out of the

12 warehouse or whatever, and then those are the units

13 that get tested without any --

14 MS. MEYERS: And Bob, isn't that rating

15 frozen, too, until after that --

16 MR. WHITWELL: Once the units are selected,

17 you can't go in and change a rating, so yeah.

18 MR. MYERS: This is Frank Myers, PVI.

19 Although that's true for a number of AHRI programs,

20 that is not true for all AHRI programs. Products are

21 not independently selected and sealed in all AHRI

22 certification programs.
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1 MR. WHITWELL: Okay. Well, where they are I

2 certainly wouldn't want it to be different for members

3 -- for others that aren't members of the AHRI program.

4 MR. KOJAK: This is Mike Kojak with UL.

5 Another issue that really hasn't been brought up yet is

6 if it goes back to our big argument a couple weeks ago

7 about witnessing the testing for the verification

8 testing. So if it is done through AHRI, that is able

9 to be witnessed by the manufacturers. And also, if the

10 manufacturer, you know, has its own certification for

11 DOE testing, they're going to be doing it themselves,

12 which totally contradicts that because they're actually

13 running their own tests without any direct supervision.

14 So that's another thing we've got to address as well.

15 MR. AMRANE: Can you elaborate a little bit

16 here? I don't understand that.

17 MR. WHITWELL: Do we have that situation on

18 any of these products? I'm not aware of it.

19 UNIDENTIFIED SPEAKER: What do you mean?

20 MR. KOJAK: So what I mean is when AHRI

21 performs testing with their contracted labs, the

22 manufacturer can be present. So the whole discussion
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1 we had earlier in these meetings was when there's

2 verification testing being done by the DOE, there's no

3 manufacturer witnessing or participation whatsoever

4 with the first test. And that's what we all agreed on.

5 So now we're saying if the AHRI testing is part of the

6 verification process for the DOE, how do you get around

7 with the AHRI requirement -- you know, ability for the

8 manufacturer to be present at the third-party test

9 facility to witness the test?

10 MR. WHITWELL: My question was really the

11 second part of your statement where you said that tests

12 could be done -- the AHRI program allowed tests at

13 manufacturer's lab without any third party presence.

14 MR. KOJAK: No, not that AHRI would -- the

15 situation Charlie was mentioning with being a DOE16 approved verification program, that the actual

17 manufacturers can get a DOE-approved verification

18 program themselves, you know, right there, I mean, if

19 the manufacturer creates their own VICP and is

20 conducting their own testing, who's monitoring that?

21 That's what I was trying to say.

22 MR. WHITWELL: Okay, I agree. I
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1 misunderstood your comment. I thought you were

2 referring to AHRI programs.

3 MR. KOJAK: No.

4 MR. TRITSIS: Just a clarification, this is

5 Bill Tritsis, to what Mike was saying. Manufacturers

6 are allowed to be present during the setup, not during,

7 you know -- or influence the set. There are strict

8 rules and guidelines what the manufacturers can do

9 during their presence at the independent laboratories.

10 That's to witness the setup only.

11 MR. WHITWELL: Yeah.

12 MR. KOJAK: And what we have discussed here

13 and at our previous meetings is the DOE stance was the

14 manufacturer cannot be at the location whatsoever or

15 even have knowledge where the testing is being done.

16 MR. AMRANE: It is not -- I'm not sure if DOE

17 was talking about verification testing.

18 MR. WHITWELL: No. No.

19 MR. AMRANE: Right. We're not talking about

20 the verification testing. We were talking about the

21 qualification -- the validation of the AEDM.

22 MR. STANONIK: This is Frank Stanonik with
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1 AHRI. That previous discussion was, in fact, about

2 assessment testing that has been ongoing. And Laura

3 can certainly correct me, but that assessment -- I

4 mean, right now there are no DOE regulations for

5 verification specifically, so we're creating a new

6 subsection.

7 MR. KOJAK: No, when -- you know, not

8 everybody in the room has been here the entire time, so

9 in the beginning, when they discussed how they were

10 going to pick a product from the market and they were

11 going to test it without any knowledge of the

12 manufacturers knowing, there was a lot of discussion

13 show the manufacturers wanted to be, you know --

14 MR. STANONIK: Right.

15 MR. KOJAK: -- told about the testing so

16 they can have input on setup and things. And it was

17 the DOE's stance that the manufacturers would have no -

18 - that they couldn't know that it was being done or

19 being contacted by the third-party lab doing the

20 testing or any of that.

21 MR. STANONIK: Right. And that assessment --

22 that was assessment testing that at least was, I would
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1 say, in most people's minds, a prelude to enforcement

2 testing.

3 MS. MEYERS: AEDM.

4 MR. STANONIK: But --

5 MR. KOJAK: What currently happens right now

6 with Navigant, I wish somebody would speak because when

7 you do testing for the DOE right now, there is no

8 communication with the manufacturer whatsoever.

9 MR. STANONIK: Right, right.

10 MR. KOJAK: So it's --

11 MR. AMRANE: And it says we are referring to

12 assessment testing or enforcement testing. We're not

13 talking -- we're talking about --

14 MR. KOJAK: Well, enforcement testing is

15 after you've already failed the rating test, correct?

16 MR. AMRANE: Yeah, but you're not talking

17 about --

18 MR. KOJAK: But that's not what this is.

19 MR. AMRANE: This is a verification test.

20 MR. KOJAK: It's verification.

21 MR. AMRANE: Yes. So it's a new chapter.

22 MR. KOJAK: Yeah, so it's --
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1 MR. AMRANE: We haven't defined the rules

2 yet.

3 MR. KOJAK: It's testing units randomly

4 throughout the -- help me out here, Laura. Which one

5 is it?

6 MS. BARHYDT: Okay, so this is what we talked

7 about with AEDMs and it was how DOE would do a single

8 unit spot check to verify an AEDM. So this is what DOE

9 was looking at in terms of doing verification tests

10 where something had been certified using an AEDM.

11 MR. WHITWELL: This is verification for an

12 AEDM versus verification rating.

13 MS. BARHYDT: Well, I mean --

14 MR. WHITWELL: So there's some --

15 MR. BARHYDT: There's real overlap there.

16 MR. STANONIK: Yes. Frank Stanonik, AHRI.

17 There's overlap, but there's also some distinction.

18 MR. WHITWELL: Yeah.

19 MR. STANONIK: Because the verification we're

20 talking about right now is a continual, ongoing

21 process.

22 MS. BARHYDT: Right.
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1 MR. STANONIK: I would venture that -- and

2 this would certainly be up to DOE, but I'd venture that

3 this kind of verification testing to, let's say, check

4 your AEDM may happen, but it's not like, you know --

5 it's not going to be we're doing it every month

6 situation. In one case the verification --

7 MS. BARHYDT: So you're drawing a volume

8 distinction, I think.

9 MR. STANONIK: Well, yeah. Well, yes, a

10 volume distinction and also, in the one sense, the

11 verification is essentially verifying that the rating

12 of this particular model, the rating of this unit of

13 this model is, in fact, correct. This verification has

14 a much deeper implication because you're really

15 checking the -- you know, the ultimate purpose would be

16 to check the AEDM. And if the AEDM proves invalid or

17 incorrect, that's a lot bigger deal.

18 MR. KOJAK: But what if the company's not

19 using an AEDM?

20 MR. STANONIK: Well, then you don't have to

21 worry about this.

22 MR. KOJAK: Well, that's -- exactly, because
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1 in the beginning of all these conversations the two

2 ways you can rate to the DOE was running your own

3 testing of the actual product or you can use an AEDM.

4 MR. STANONIK: Well, okay. So let me go back

5 to, I think, something you said at the beginning in

6 terms of this verification and the option where the

7 manufacturer has set up their own verification program

8 with DOE's approval. I think what you had raised the

9 point was that this manufacturer's program could

10 potentially operate without any other, lack of a better

11 word here, supervision. And I think, at least in our

12 proposal and even I think what Frank Myers has said,

13 there is still -- even within the let's call it the

14 manufacturer's self-operated verification program --

15 well, let me rephrase this.

16 We put forth the VICP requirements as the

17 baseline. We believe a critical part of that baseline

18 is that there is that supervision by a 17025 lab. And

19 that has to -- we haven't really talked about the

20 details of, okay, what's the requirements for a

21 manufacturer's self- operated verification? But I

22 would put forth that one of the requirements, even for
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1 a manufacturer self-operated, is there has to be that

2 oversight, supervision, whatever the right verb may be,

3 of a 17025 lab at some point, at some stage. That

4 makes it equitable.

5 MR. WHITWELL: Bob Whitwell, Carrier. But,

6 Laura, I mean, we're talking about two different

7 things, I think, right?

8 MS. BARHYDT: I'm not sure.

9 MR. WHITWELL: No, remember --

10 MR. BAUMAN: Because, Laura, I mean, DOE can

11 still spot check a unit. I mean, that's what you're

12 doing now, you're random or spot-checking or whatever.

13 I don't see how -- because this was where you'd be

14 potentially in addition to an annual verification

15 program with ongoing, every year you had to do a

16 certain amount. You guys can still go out and buy a

17 unit or whatever and check it. Or are we saying

18 there'd be restrictions on you not to do that?

19 MS. BARHYDT: So, DOE actually is okay with

20 the idea of us not doing spot checks the way we

21 currently do assessment testing if all the

22 manufacturers are in a DOE- approved verification
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1 program. And the idea there is that all of the

2 manufacturers will be subjected to verification without

3 DOE doing that. So DOE's testing would be limited to

4 doing enforcement testing, following up on complaints,

5 and rulemaking testing.

6 MR. FLY: This is Mark Fly with AAON. So,

7 you know, as I would see this, DOE would still have the

8 ability to do a spot check when they felt they needed

9 to do a spot check. Say we've got some verification

10 program that you're suspicious is not working, you're

11 getting complaints, then you may want to pull one. And

12 you may want to pull one off the open market and you

13 may not want anybody to know about it and you may want

14 to test it. I think, you know, you have the ability to

15 check any of the things that we're laying out here to

16 check quality of those programs that we have at random.

17 But it's not something, you know -- but the difference

18 being is that you're buying the equipment, you're

19 paying for the test as opposed to this much broader,

20 where we're doing much more testing, but the

21 manufacturers are buying the equipment and the

22 manufacturers are paying for the test.
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1 MS. BARHYDT: Well, I don't know if it's much

2 more testing. I'm hearing one and two units.

3 MS. MEYERS: So this Karen with Rheem. And

4 based upon our discussion today, I would say that this

5 slide is no longer applicable and should be deleted

6 from the proposal. Because if DOE -- because this is a

7 verification of, and DOE's going to be approving the

8 verification program. Manufacturers are going to be

9 funding that with their units. So I don't know that we

10 need this slide anymore.

11 MR. BALLO: This is Tim. I don't want to

12 preclude DOE from having the authority to pull one

13 product if it hears something bad about it rather than

14 having to go through an enforcement testing process

15 right off the bat. So I do think there is still value

16 in having the ability for DOE to do a single unit spot

17 check.

18 But sort of the flip side of the verification

19 process taking the place of this, though, is that when

20 a product is pulled for a verification test and fails,

21 it, number one, gets re-rated; number two, triggers the

22 AEDM consequences, which may require more testing; and,
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1 number three, is then subject to potential enforcement

2 testing by DOE if it fails to meet the standard. Am I

3 right?

4 MS. BARHYDT: Mm-hmm.

5 MR. BALLO: Okay.

6 MR. MYERS: This is Frank Myers, PVI. I

7 actually have thought all along that if you were in a

8 VICP program, there would be no need for DOE to ever

9 implement this kind of spot check if you're in a VICP

10 program, a DOE-approved VICP program. But for those

11 that are not in a VICP program, part of the control

12 over them not doing something they shouldn't was that

13 they would -- all of the money that you spread across

14 the market before, you can now focus the spot checks on

15 the ones that are not in VICP programs to give them

16 additional reason to behave. So I've always thought

17 this was a good thing and that it should stay in place

18 for non-VICP participants where more direct information

19 would be provided by a manufacturer to DOE to give DOE

20 the continued option of going out and pulling a unit

21 and, in secret, test it, and you've been a bad

22 manufacturer and done wrong things and we have the
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1 evidence to show it, but that that was largely

2 unnecessary for DOE-approved VICP programs.

3 MR. EISNER: Why don't we take a quick 5-

4 minute break? Come back at a quarter after 12, 17

5 after.

6 (Whereupon, a brief recess was taken.)

7 MR. EISNER: Can everybody get to their seat?

8 Mike Kojak and I talked with Laura over the

9 break because we were both getting more and more

10 confused and Laura's going to explain where she thinks

11 we are and how we should handle this discussion.

12 MS. BARHYDT: Okay, when we talked about

13 AEDMs, we -- multiple times people said what about

14 VICPs, what about VICPs? And we kept saying we'll talk

15 about VICPs later. And we wanted to make sure that in

16 the context of the AEDM discussion before that went to

17 the ASRAC, we had some very clear framework for how DOE

18 verification for AEDMs would work. And so, that's what

19 we worked out and from DOE's perspective as far as a

20 verification program is concerned, I wouldn't say maybe

21 it's solid gold but that is a gold-plated program. I

22 mean, it has a huge amount of controls in terms of
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1 independence from the manufacturer in the selection, in

2 the testing. There are a lot of controls in the

3 program that we've come up with for AEDMs.

4 We would absolutely love to adopt that for

5 all verification programs. I am realistic and don't

6 actually think that's going to happen, but -- so that's

7 the context for what we discussed before if how DOE

8 would do verification testing in the absence of DOE

9 approved verification programs.

10 If we get a DOE approved verification program

11 framework set up, then that's what we'll apply. And if

12 DOE does rulemaking testing, if we do follow-up on

13 complaints, I think there was a third one. The three

14 different instances where we still might do spot

15 checking, that's what would apply.

16 Does that make sense to everyone?

17 MR. EISNER: And what is on the table as I

18 understand it are some of the issues that we're still

19 saying, well hey this would be unfair. Their

20 information was made public, but other information was

21 not made public. Laura said that's' all open to

22 discussion and how it's handled.
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1 MS. BARHYDT: I mean if you --

2 MR. EISNER: If it has to go to DOE, for

3 example, or whether it stays with the independent third

4 party testers.

5 MS. BARHYDT: I mean if you look at the

6 slides, slides 27, 28, 29, 30. I mean all of those --

7 we've only started to scratch the surface of all those

8 issues and those are all things that we have to

9 resolve.

10 Or we can just adopt what with did with the

11 AEDM provisions.

12 MR. EISNER: So much of it in simple terms,

13 this group can decide what the verification testing

14 will look like. I don't mean your delegated authority

15 by the agency, but if everybody agrees that will be the

16 verification testing program.

17 So comments, suggestions? Do we want to

18 continue going through some of these terms?

19 MR. MYERS: This is Frank Myers. To the

20 degree that we have discussed a number of the items

21 that are in the pages that you just mentioned, I was

22 thinking that we were proposing alternates in
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1 conjunction with the program requirements. I know that

2 we didn't discuss all of these items, but --

3 MS. BARHYDT: No, we've discussed a lot of

4 them. But there are definitely things that we still

5 haven't discussed.

6 MR. MYERS: Right.

7 MS. BARHYDT: And some of the concerns that

8 have been raised are some of those items that we have

9 not discussed yet.

10 MR. WHITWELL: So Bob Whitwell, Carrier.

11 Just to make sure that I'm clear and maybe I missed

12 some of what you said. So the prior discussion that we

13 had several meetings back, that was up there, is

14 verification testing for potential -- or verification

15 testing for manufacturers that are not in the VICP.

16 For those in the VICP, it could be different. We've

17 still got to work out some of those details.

18 MS. BARHYDT: Yes and DOE's goal is to get

19 everybody into some kind of a vacation program plan.

20 MR. WHITWELL: Okay, thanks.

21 MR. EISNER: And as I understand it, some

22 other things that concern people about the first
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1 discussions about the testing the DOE did -- for

2 example, they couldn't be there to witness the test.

3 This could change some of that as I understand it, if

4 this group decides that you want to get everybody into

5 a program and alleviate some of the concerns that were

6 raised during the initial discussions.

7 That's partly -- I know Mike and I were very

8 confused about that. We thought we had a lot of these

9 discussions and they were resolved.

10 MR. WHITWELL: Yeah, and that was the reason

11 for my question. My question about these are two

12 different things because I didn't understand that. I

13 was thinking that we were talking about two different

14 things. Now, it's the same thing but two different

15 cases. If that makes sense.

16 MR. EISNER: Yeah.

17 FM: Frank Myers, PVI.

18 MS. BARHYDT: That's why had difficulty

19 answering that. They're not exactly different, but

20 they're not exactly the same either.

21 MR. MYERS: This is Frank Myers, PVI. Laura

22 where you were talking about everyone would be any
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1 program, that's DOE's expectation is everyone would be

2 in the program. You've mentioned several times, I just

3 wanted to confirm that's not everybody has to be in a

4 VICP program, but in a DOE approved program.

5 MS. BARHYDT: Correct.

6 MR. EISNER: So comments on where --

7 MS. BARHYDT: That's where we would like to

8 be.

9 MR. EISNER: Comments on where this

10 discussion is going to whether there's a better way to

11 approach it? Should we continue going through some of

12 these charts and some of these questions? Make good

13 use of the time.

14 MS. BARHYDT: So we've agreed to hold off on

15 the percent or whatever metric we use for how much

16 should be verified. We haven't really talked about how

17 the models would be selected yet. And that, I think,

18 goes hand-in- hand with the next bullet point of

19 process for low-volume products.

20 So do you all want to start on that issue

21 next?

22 MR. STEPHENS: Okay.
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1 MS. BARHYDT: Okay. So DOE think everything

2 should be completely random and that the selection

3 should be out of the control of the manufacturer and

4 the manufacturer should not know in advance what is

5 going to be tested. So there's a starting point.

6 MR. HON: Charlie Hon. We seldomly do this,

7 but there are a few low-volume products which are not

8 stocked, but most low-volume products are not stocked.

9 So the only way you're going to get them is to order

10 them from the manufacturer. Whether it be for third11 party verification outside just in case you decide to

12 run one or in a verification program. So, that's

13 almost impossible not to do it that way. The

14 manufacturer will know about it and likely will be

15 testing it in their own facility, and a lot of areas.

16 MR. STEPHENS: Phillip Stephens, HTP. I'd

17 like to propose that we break it into two sections and

18 do low- volume and then the standard production.

19 Because you're absolutely right, the answers are going

20 to be vastly different and will confuse ourselves if we

21 try to talk about them all at the same time.

22 MR. FLY: This is Mark Fly with AAON. My
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1 company and I think I represent some part of the

2 industry, probably not all the industry. We're

3 completely build-to-order. So, like you said, it's

4 going to have to be ordered and built so it's not going

5 to be a particular surprise. You know, I don't really

6 have a problem with it being random, although I think

7 you need to get a distribution across the range over

8 some period of time.

9 And I absolutely agree with you that the

10 manufacturer should not be the one picking the models

11 for it. Because I don't want my competitors to be able

12 to do that. But, you know, I have a little problem

13 with the other part of your deal.

14 MR. SACHS: Laura -- this is Harvey. I've

15 wandered through a factory or two in my day, and this

16 looks -- your bullet two is fine for products like

17 water heaters, where you might see 6,000 a day running

18 through a factory. Much of what we're talking about

19 here, I tend to think about as engineered products.

20 And rather than thinking about it as high volume versus

21 low-volume, I tend to think about it as stockable or

22 stocked versus built-to-order.
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1 And I would -- certainly from my perspective

2 worry about how I picked things from the built-to-order

3 for testing, but I think that's most of what we're

4 talking about here for these products classes.

5 MR. WHITWELL: Bob Whitwell, Carrier. That's

6 true even where in the product range where we would

7 stock products, those products quite often are going to

8 have economizers, they're going to have some other

9 options that are not to be tested. So, to get a basic

10 model is probably going to be a build-to-order.

11 MR. SACHS: Again, this is Harvey. The

12 implication of that is what can we do that gives us a

13 fairness that emulates random, when there is no way the

14 manufacturer can't -- cannot know that this is being

15 built for tests. And I do not know the answer, but I

16 think unless we face that situation that we're not

17 going to get very far.

18 MR. STANONIK: Frank Stanonik, with AHRI.

19 And again, I'm going to emphasize the need for

20 consistency of terminology and I'll specifically talk

21 about the stocked -- the circumstance that we have

22 stocked models. Ten high --
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1 MR. SACHS: Ten high --

2 MR. STANONIK: Yeah, right. In that

3 situation, because for a lot of practical reasons and

4 running certification programs, the selection to check

5 the rating of that model might not be random. But the

6 selection of the actual test sample, might be one unit

7 from a pool that has been pulled aside from three,

8 four, five, six units. Again, recognize that is a

9 variable, but there is some stock of the unit, okay?

10 And so, you know, the manufacturer doesn't

11 get to say, "Oh, take that one in the purple box." He

12 just maybe pulls out six or seven and you say, "We want

13 that one." Okay.

14 So, the random part of it is which one end up

15 being the test unit, because most often, you know, all

16 of this has gradients but most often the manufacturer

17 in that kind of circumstance is not going to do a huge

18 production run for just our test sample. All right.

19 But at the same time, for the practicalities of

20 scheduling testing for the need to, in fact, actually

21 when that selector shows up at the door, to actually

22 find the ones he -- that we want him to test, the
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1 reality is we have to give the manufacturer some

2 indication of what models were planning to check this

3 year. Right, Bill?

4 Otherwise, I mean, the experience says

5 otherwise you have too many wasted days where you sent

6 the tester and wanted to test model Frank's Floor

7 Furnace 42, but I'm sorry all I've got in my warehouse

8 today and all I'm making are Frank's Floor Furnace 98.

9 And I'm not going to be making 42s for the next three

10 weeks.

11 MS. BARHYDT: So why can't the selector not

12 just walk in and pick stuff? Why do you have to pre13 selects something?

14 MR. STANONIK: So if he did that, if he did

15 that then we've got to revisit this whole idea that I'm

16 going to be testing 20 percent, you know, whatever the

17 percentage is -- X percent every year, because you're

18 going to have a lot of repetition. And maybe that's an

19 acceptable think, but basically you're giving up that

20 there's probably some models I may never test.

21 Not test in seven or eight years but I may

22 never test.
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1 MR. RIVEST: I mean, to minimize costs --

2 MS. HOOTMAN: There are several models that

3 we never make. We offer but never make.

4 MR. RIVEST: Right. And models you never

5 make, we probably wouldn't want to test, anyway. So,

6 there's something elegant here about --

7 MS. HOOTMAN: But we're certifying to you

8 some kind of value for those. But, you know, depending

9 on where the market is at any one time we may not make

10 it. We may not make it for two years. So if you're

11 coming in and just randomly selecting, you would be

12 getting the common models every single time and it

13 would be very, very repetitive. And you likely

14 wouldn't get, you know, some of the other ones that are

15 not as repetitive.

16 MR. RIVEST: Okay. But wouldn't that be

17 representative of what's actually being shipped, and

18 therefore, the energy usage? To minimize costs, if

19 someone were to go -- give a little heads up we're

20 coming in look at what's in your production run, look

21 at what's in your inventory. Amongst those may be

22 select the basic models that haven't already been
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1 tested.

2 I don't know if it would delay shipment of

3 those units too much. But it would potentially

4 minimize your costs --

5 MS. HOOTMAN: It would delay shipment of

6 those units largely.

7 MR. WHITWELL: Yeah.

8 MS. HOOTMAN: Just like Mark is describing.

9 Every single unit that goes down my line -- for 20 tons

10 and up, has a customer order attached to it. It is

11 sold.

12 MR. FLY: Yeah --

13 MR. RIVEST: Jill --

14 MS. HOOTMAN: It is being sent to a customer.

15 You are tying up their business.

16 MR. RIVEST: Jill that applies to your stuff.

17 It may not apply to water heaters, it may not apply to

18 everything.

19 MR. FLY: And again, I'm going to interject

20 here. My premise was, I'm talking about stockable

21 stuff, okay? By no means anything we were discussing

22 should be necessarily considered automatically applying
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1 to build- to-order or even a semi-customized whatever.

2 You know, there is a whole different consideration as

3 to how we need to address this.

4 MR. RIVEST: But wouldn't even customized or

5 semi-customized be done in batches around some sort of

6 production schedule? So you're not totally --

7 MR. FLY: It's driven by orders. You know, I

8 mean --

9 MS. HOOTMAN: Yep.

10 MR. FLY: Go ahead.

11 MR. WHITWELL: In our case, it's based on

12 orders. And there's typically not two of the same next

13 to each other on the assembly line. They are -- each

14 one is based on the customer's order. So, they're not

15 batched. They're -- it's mixed model production.

16 MR. FLY: This is Mark Fly with AAON. I

17 mean, the other thing it has -- if we're late on a

18 shipment we get to pay for cranes, we get to pay for

19 liquidation damages, we get lawyer letters. And you

20 know, we're not building things hugely ahead of time.

21 You know, I hire enough people on the factory floor to

22 do the amount of work I have going right now, and when
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1 work slows down I quit hiring and by attrition the

2 workforce goes down.

3 So, I'm not building things and they're not

4 sitting there. I don't even have a place to set them

5 for two weeks. You know, stocked inventory or rolling

6 buffer right thing and that kind of business. Now,

7 like I said this is not build to stock. Build to stock

8 you need to have warehousing for the equipment.

9 MR. STANONIK: Yeah but even -- excuse me.

10 But even in that circumstance, a water heater facility

11 today, okay. They may get -- tomorrow's production run

12 may be the orders they got in the last two days and it

13 may be six of this model and then the next 12 or that

14 model. And so, by the end of the day they've built what

15 has been ordered. What they stock is, in fact, let's

16 say what they know is their most popular products or

17 whatever else, so they can fill some orders straight

18 from stock, but they're still a huge component that

19 okay, you know, here's the orders that came in,

20 whatever and this is what we're building tomorrow to

21 fill those orders. And for many of those models they

22 don't build extra. They just build what they've got
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1 word for.

2 MR. STARR: This is Louis Starr with NEEA.

3 Why doesn't DOE just by their air handler through a

4 mechanical design build contractor.

5 MR. RIVEST: That's what we do.

6 MR. STARR: Well, then what's the problem,

7 because they can just order whatever you have.

8 MS. BARHYDT: So we're talking about --

9 MR. RIVEST: Industry-run.

10 MS. BARHYDT: -- industry-run or

11 manufacturer- run or lab-run verification program,

12 where the selection is not happening by DOE. Where the

13 unit selection is not happening by DOE going out and

14 buying a product.

15 MR. HON: I've been waiting for a few minutes

16 here. Because we built both categories, quite a lot of

17 both. I'm sure Collin can tell you that our warehouses

18 are quite large. We have certain models that are

19 stocked and a lot of others that are not stocked. The

20 problem is, say we bring in a unit. You have a

21 representative or UL has a representative or somebody

22 comes in and says, "Okay, well pull down Model Q. Pull
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1 it down. Pull eight models out. Take the serial

2 number off of one of them to send to our lab." Then we

3 have to move it from our warehousing facility to our

4 laboratory, prep for testing, and it takes three to

5 five days to get it stabilized.

6 Are we going to pay the UL person to stay the

7 three to five days? Are they just going to come in for

8 a day to pick units and then leave and then come back

9 later?

10 MR. RIVEST: Look, the goal is some

11 randomness so that you can design to test specifically

12 for the test, right? And the second one is to minimize

13 the costs. So how to get that?

14 MR. HON: I agree, but I'm just asking

15 questions here. I don't know.

16 MR. RIVEST: I want answers.

17 MR. HON: Okay.

18 MR. KOJAK: This is Mike Kojak with UL. I

19 can tell you how it's done or how was done in the past

20 for some AHRI-witnessed testing, is we would have a UL

21 representative show up at the factory and they would

22 make random selections, mark them, seal them, and then
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1 when it came around time to test it the people who

2 showed up to test it make sure it was the exact same

3 product that was picked.

4 So there are two different trips. Because

5 the one that comes to pick the units, since we have

6 quite an extensive organization of FUS people all over

7 the country and the world, we have people who can show

8 up at almost any location whenever we need them to make

9 any kinds of, you know, picking of product or whatever

10 they need to do.

11 MR. MYERS: This is Frank Myers. Is that for

12 commercial equipment, that you use that technique?

13 That sounds very much like a residential, where there

14 is build-to-stock is the normal practice.

15 MR. KOJAK: That was built as stock

16 equipment.

17 MR. MYERS: Residential or commercial?

18 MR. KOJAK: Whatever's stocked.

19 MR. RIVEST: Another idea. If there are, and

20 I'm sure you have very detailed parts lists and

21 drawings of these things, in that case if you were

22 given ahead notice of what would be tested and the
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1 person doing the selection would make sure that it was

2 built as shown in the technical drawings; then you

3 know, wouldn't that be good enough for everybody?

4 MR. HON: Well, there's an easy way to do

5 this. Almost everybody in this room either builds to

6 UL, ETL -- some sort of technical standard. And those

7 document packages exist for safety reasons. They

8 identify the compressor, the fans, all major electrical

9 components. And so, if you would specify our GDM-10, I

10 can guarantee you that when the UL inspector comes he

11 knows what that is, he has all of the dimensions build

12 into the thing. It's a documented package which is

13 independently handled. They have all of the componentry

14 listed out for them and the basics of everything is

15 there.

16 MR. RIVEST: So would that satisfy everyone,

17 so we could specifically order a base unit or ask you

18 for a base unit and we don't have to worry that it's

19 going to be gold-plated, because it's just going to

20 match drawings that predate the manufacture.

21 MR. HON: That's fine.

22 MS. BARHYDT: Oh no.
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1 MR. STEPHENS: Phillip Stephens, HTP. So,

2 I'm not sure I'm following that. So under that

3 thinking we would open up our certification files to

4 the inspector?

5 MR. HON: To verify that it is the product

6 that says it is, I don't see any problem with that at

7 all. The inspector, whether it be some third-party lab

8 that's going to be looking at it, it's probably the

9 same third- party labs that are doing your safety

10 inspections. Also, let's do a single source that way;

11 whether it be ETL, UL because it's cheaper that way.

12 MR. THARP: Rusty Tharp with Goodman. As

13 long as that -- because that specific information, that

14 has the specific compliments listed, again, that's the

15 type of information that's in some of the DOE test

16 reports. It's online. That is confidential product

17 information and that's not something that should be

18 available to the open public. I don't want my

19 competitors knowing what my billed material is, that

20 goes into it.

21 So we'll need to have some type of method --

22 say what?
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1 MR. RIVEST: (Inaudible).

2 MR. HON: If they just examine it.

3 MR. THARP: As long as it is checked.

4 MR. HON: They say check, check, check. It

5 is what it says it is.

6 MR. THARP: The inspector checks it. The

7 inspector says, "Yes, I checked it, that it meets this

8 UL report." I'm fine with that, but I don't want that

9 information in a test report somewhere that's going to

10 be later subjected to a FOIA request.

11 MR. HON: If the DOE documents are set up,

12 major componentry matches UL file, check.

13 MR. THARP: Yeah, I'm perfectly fine with

14 that. And something else to remember, too, as Karen

15 pointed out as she was leaving, is that one thing we

16 would suggest it is that any verification program would

17 have a provision that ratings are frozen once a model

18 is selected so that reading can't be modified. It was

19 14, now it's 13 type of thing. So that would be

20 something that should be part of any verification

21 program.

22 MR. KOJAK: It's Mike Kojak with UL. With
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1 the minimum requirements for the VICP group, that

2 should be added in there that the program person should

3 be checking the bill of materials to make sure the unit

4 is what it's supposed to be.

5 MR. MYERS: This is Frank Myers with PVI. I

6 know the AHRI certification which has probably the most

7 credibility of any program out there, doesn't do that.

8 MR. THARP: AHRI does check components.

9 MR. MYERS: Does what?

10 MR. THARP: AHRI does check components.

11 MR. MYERS: In your particular program?

12 Okay, I'm speaking about water heaters and boilers,

13 they did not.

14 MS. BARHYDT: So this bullet point we just

15 added, can you help with the language? Because I'm not

16 exactly sure how --

17 MR. THARP: Actually, rating must be frozen

18 upon unit selection for testing. Frozen or locked.

19 The AHRI terminology is locked.

20 MR. WHITWELL: Gets locked in the directory.

21 You can't --

22 MR. THARP: Right. Member cannot change the
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1 rating in any manner, shape or form.

2 MR. AMRANE: This is Karim with AHRI. The

3 reason we do it is because our database is a live

4 database. Data changes every day. Is DOE's database

5 going to be a live database?

6 MS. BARHYDT: DOE's database updates once a

7 week and there's about a two-week lag between when

8 somebody submit something and when it shows up live on

9 the site.

10 MR. BALLO: So how does selection work if

11 you're a manufacturer self-directed certification for a

12 verification program?

13 MS. BARHYDT: Good question.

14 MR. THARP: Harvey and Tim.

15 MR. STEPHENS: Phillip Stephens, HTP. I

16 think at that point the DOE would need to do the

17 selection just have the manufacturer verify that they

18 have the right model number.

19 MR. HON: Well, there's also another thing

20 that can be involved because one of the things for

21 economy is the fact that there is other testing that

22 has to be done in some componentry. Energy Star
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1 requires a certain amount of testing, another

2 government agency. What they do is they all allow our

3 independent certifier to verify and pick models. And

4 they go back, and we have a big spreadsheet of okay,

5 this is groups, this is families. Basically this is

6 similar to what we're developing right here. They'll

7 pick -- we haven't tested anything in this one for a

8 while. They'll pick one of the numbers out of there.

9 We haven't tested any in this one for a while, will

10 pick one of the numbers out of there.

11 And they will do the selection that way

12 rather than us give them. Sometimes will say well, if

13 you've got four out of this one but we still haven't

14 touched this category and make a suggestion for them to

15 be fair about it. You know, just keep testing this one

16 doesn't do us any good. So will make a suggestion, but

17 they don't have to accept it.

18 MR. KOJAK: Are you guys going to add in that

19 the componentry must be checked before the testing

20 occurs, too?

21 MS. HOOTMAN: How will that be done?

22 MS. BARHYDT: So Jill, I believe that the
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1 suggestion was that whoever the third-party lab

2 supervising the testing is would be able to check the

3 componentry against a pre-existing safety componentry

4 list.

5 MR. WHITWELL: Or comparable.

6 MS. HOOTMAN: From the UL file?

7 MR. WHITWELL: Yeah. It could be UL file,

8 Jill, or it could be some other data that is provided

9 to the VICP from the manufacturer. Right? I mean the

10 VICP may have some other --

11 MS. HOOTMAN: So we got to pull bill of

12 materials on every single unit and get it into some

13 kind of package that somebody else can read, because

14 those are in proprietary drawing systems, et cetera

15 right now.

16 MR. WHITWELL: Jill, this is Bob Whitwell. I

17 think, you know, today there's a certain amount of

18 information that goes in as part of the AHRI

19 submission, which I think can be adequate for this.

20 MS. HOOTMAN: It doesn't have bill of

21 materials, it just has compressor model number -- you

22 know.
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1 MR. WHITWELL: Basic model information,

2 right?

3 MS. HOOTMAN: Right.

4 MR. THARP: Compressor, condenser, evaporator

5 information. Primary heat transfer components.

6 UNIDENTIFIED SPEAKER: Yeah.

7 MR. WHITWELL: Surface areas, air flows, so -

8 -

9 MS. HOOTMAN: If that's --

10 MR. STEM: This is Mike with Intertek.

11 MR. EISNER: Go ahead Mike.

12 MR. STEM: I just had a quick question about

13 the timelines here. You're saying that the componentry

14 must be checked before the testing, but if there's an

15 issue then do we not test? Because I kind of tend to

16 agree with Jill here, that you know, basic quality

17 checks for testing is, you know, we'll all document the

18 critical components. Major energy consumptive

19 components. But that also serves almost as a quality

20 check, right? Quality control check. So, I'm kind of a

21 little bit confused as to where this is going.

22 MS. HOOTMAN: Yeah, and I guess how much
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1 detail Mike.

2 MR. STEM: Correct. Yeah, I mean if we're

3 just talking about compressors, you know, condenser fan

4 motors, evaporative fan motors -- the things that are

5 readily available that we can, you know, see a

6 nameplate on the components themselves and make a quick

7 list of four to five items of critical components.

8 It's not an issue, right? It's pretty common practice

9 right now. If were talking about an entire bill

10 materials and you know, going in and getting, you know,

11 fin branch spacings on the coils, a more detailed level

12 then that may be an issue that I don't think the test

13 labs where the manufacturers would be comfortable with.

14 MR. KOJAK: Mike, this is Mike Kojak with UL.

15 It would be the -- like a nameplate data sheet. Just

16 the fan motor, blower motor, compressor, you know, the

17 main energy consuming sources of the equipment. You

18 know, nothing too detailed just to make sure that the

19 bulk of the equipment that's on the unit is what it's

20 supposed to be that's associated to that specific

21 model.

22 MR. DOPPEL: Paul Doppel with Mitsubishi. I
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1 think if you just said it's the componentry that -- the

2 primary componentry that impacts performance and

3 efficiency should be checked.

4 MR. EISNER: Do we want to say what it needs

5 to be checked against?

6 MS. HOOTMAN: Well, wait a minute Paul. You

7 know, a coil fin density, it's dimensions, it's ID,

8 it's tube diameters, all of those have something to do

9 with critical -- about this refrigeration system. But

10 the testing lab is going to have to sit there and

11 verify all of that. We're going to have to give them

12 detailed drawings that say, you know, and I don't know

13 if they're in a physical drawing anymore. They're all

14 in the cyber world, you know. Explaining all the and

15 that's what I'm getting at, is are they going to sit

16 there and check the fin diameters --

17 MR. DOPPEL: Well, come up with a different

18 term. I was just trying to get us focused.

19 MR. KOJAK: I think it should say critical

20 energy consuming components.

21 MS. BARHYDT: So --

22 MR. DOPPEL: Well, that could be the coil,
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214

1 too.

2 MR. KOJAK: Yeah, like when you're doing

3 testing of HVAC units you want to know amps, watts, and

4 volts of the compressors, the blower motors, the fan

5 motors, the compressor, maybe the controls, but you

6 know, those of the components I'm speaking about. The

7 major energy consuming components.

8 MR. DOPPEL: Maybe we she just list --

9 MS. BARHYDT: So I don't want to lose sight

10 of why we were even talking about this, and that is

11 because to the extent that these are built to order and

12 DOE want some kind of assurance that what is being

13 built is not being built special for the test, but is

14 actually what is in your normal production lineup.

15 This was a suggestion of one way to achieve that.

16 There may be other ideas.

17 So, where at 3 o'clock in the room is

18 starting to empty out, so I don't want people to miss

19 out on the discussion. But think some more about what

20 mechanisms we might be able to use. One may be using

21 the componentry list, but I also understand that there

22 are a lot of concerns about how that might work.
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1 MR. DOPPEL: Just one point on the bullet.

2 Above that, that probably should say "Upon unit

3 selection notification for testing."

4 MR. STARR: The other thing is on the last

5 note you can put "energy consuming componentry" and

6 that will kind of handle the last five minutes, I

7 think.

8 MR. EISNER: And I don't think any of this is

9 locked in stone.

10 MS. BARHYDT: No.

11 MR. EISNER: But before we leave, do we want

12 to agree on a few words at the end of the sentence to

13 say what we are checking it against?

14 MR. KLEISS: Jeff Kleiss, Lochinvar. I don't

15 believe were going to reach agreement on that sentence

16 at all today.

17 MR. EISNER: Okay. All right.

18 MS. HOOTMAN: I agree.

19 MR. EISNER: You are all excuse. You can go

20 home.

21 MS. HOOTMAN: See you next week.

22 (Whereupon, at 3:03 p.m., the Appliance
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1 Standards and Rulemaking Federal Advisory

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207:3 210:11,20

212:9

billed 205:19

bit 34:21 46:18

48:16 87:21

100:2 111:5

116:21 133:20

139:21 154:14

172:7 174:15

211:21

blah 65:2

block 13:14

blower 212:16

214:4

blue 154:5

blurring 11:6

board 21:12 27:20

32:11 33:20

55:10,14 72:14

75:14 162:13

Bob 8:13 62:13

88:15 93:20

102:21 117:18

129:7 130:6

173:2,14 182:5

189:10 194:5

210:16

Bob's 131:10

170:22

bodies 23:1 109:20

body 90:3,21

94:15,22 95:2

boiler 40:20 57:6

80:4 162:22

boilers 51:12 56:2

85:8 87:1,2

207:12

books 25:17

bore 64:22

born 119:3

bottom 10:5

120:22

154:15,22

159:6,7

bought 109:14

box 195:11

boxes 39:9

branch 212:11

brand-new 152:13

160:12

brands 50:18

breadth 19:22

break 48:11 71:21

72:5 118:15

186:4,9 192:17

brief 72:6,9 186:6

bring 42:12 98:9

142:16 201:20

bringing 40:16

125:21

brings 54:8,9

77:11

broad 36:3 54:5

134:10

broader 24:10,17

87:17 183:19

broadly 125:17

brochure 115:6

brought 107:3

174:5

BTU 38:10 108:17

115:9

BTUs 86:20

108:11,12 155:8
Capital Reporting Company

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buck 66:16

buddy 135:13

budget 18:18

20:9,15,16,20,22

45:22 48:21

buffer 200:6

build 13:6 37:9

38:1 69:1 70:5

76:22 99:15

108:20,21 109:1

123:19,22

124:11 199:1

200:7,22 201:4

204:11

building 1:8 69:17

141:21 199:20

200:3,20

builds 204:5

build-to 12:18

99:4 101:19

build-to-order

13:13 37:8 39:5

68:13 100:22

109:10 193:3

194:10

build-to-stock

203:14

built 13:8 24:2

39:9 68:15,21

99:17 193:4

194:15 200:14

201:16 203:15

204:2 214:11,13

built-to-order

193:22 194:2

bulk 212:19

bullet 73:2,13

83:10,20 87:7

88:1 103:8 110:1

111:9,15 119:13

131:8

143:4,14,17,21

144:20 159:7

170:2 191:18

193:16 207:14

215:1

bunch 49:13

102:13 125:17

144:13

burden 23:6

28:3,9,14 29:1

32:22 36:7 40:16

62:7 106:18

141:16

burdensome

55:8,22 56:5

business 27:4,6

34:3 36:13,14

38:20 125:16

126:2,4,7,16,20,

22 198:15 200:6

businesses 126:2,8

132:11

buy 44:9,20 45:10

47:22 48:8 52:1

63:16 182:16

buying 46:9,16

183:18,21

201:14

buys 47:6 62:20

C

calculations 66:19

105:10

calculus 16:1

calibrated 86:6

105:2,6

106:10,16 108:5

109:6

California 142:3

cap 86:19

capabilities 18:4

85:18

capability 85:17

capable 39:20

capacities 115:11

125:19

Capital 1:18

care 164:13 171:3

careful 25:12

58:11 96:13

Carrier 3:21 62:13

88:15 93:21

129:7 173:3

182:5 189:10

194:5

carries 135:16

case 14:14 28:12

42:21 61:15

67:12 106:3

108:19 113:8

136:6 180:6

192:11 199:11

203:21

cases 59:19 70:12

87:14 108:3

112:3 163:8

190:15

catch 19:15

categories 39:19

56:1 116:6 117:4

134:2 136:13

142:5 144:11

149:2 201:16

category 4:16 36:3

41:16 74:9 80:4

84:2 100:13

117:1 124:12

143:5 209:14

caught 66:2

144:13

cause 37:2 116:5

causes 67:12

CB 89:19

CBTL 95:13

CBTLs 95:14

CCE 8:14 151:3

CCMS 151:4

certain 10:9 50:17

59:18 75:3

141:12 142:10

144:11 158:2

182:16 201:18

209:1 210:17

certainly 7:7 10:1

25:15 26:8 36:2

39:6 46:10 70:22

116:8 133:9

138:18 142:3

144:9 149:13

174:2 177:3

180:2 194:1

CERTIFICATE

217:1

certification

5:1,3,9,11 13:20

19:5 20:19 21:10

22:7,22 23:15

25:18 26:16

27:2,4 29:8 33:9

36:17 42:5 56:10

58:13,16 59:3,14

65:8 66:1 72:21

74:3,12 75:21

76:21 78:4 83:1

89:14 90:3

94:3,15,22 95:2

96:10 98:11

107:10 109:20

112:7 144:15
Capital Reporting Company

Appliance Standards Federal Advisory Committee Meeting 08-01-2013

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145:22

146:1,11,16

147:5,12

150:4,5,8,10,12

151:19 162:14

165:14,17,21

166:2 167:5

171:17 173:22

174:10 195:4

205:3 207:6

208:11

certifications

24:5,6 78:8

162:16

certified 59:5,12

73:8 74:10

75:2,10,18 76:7

77:1,6,11,15,16,

20 78:16 84:11

88:6,20

89:7,9,11,15

90:18,20,21

95:12 96:21

139:13 143:9,10

148:18 179:10

certifier 209:3

certify 14:7 31:3

38:17,18 56:20

66:10 74:7,11

76:10,14,20

77:1,2,11 78:6

84:15 96:21

98:14 217:4

certifying 138:6

151:9 197:7

cert's 6:14

cetera 109:2,6

133:22 210:14

CFR 44:11 66:20

chairman 72:13

challenge 16:6

18:13,15 52:12

56:7,16 61:5

74:5 100:4,5,7,9

challenges 56:17

challenging

169:13

chambers 39:22

chance 6:1 91:14

173:8

change 8:18 15:22

33:7 112:21

114:19 157:6

173:17 190:3

207:22

changed 5:8 78:18

changes 5:1,2 6:19

7:4,8,18,19,20

116:13 119:14

127:15 208:4

changing 73:18

99:18 111:15

122:7

channel 117:12

chapter 178:21

characteristics

10:10 124:22

Charles 2:18

Charley's 50:8

Charlie 23:13

27:16 31:6 35:19

79:2,7,16 82:8

90:17 91:13,20

92:14 112:9

116:22 127:1

128:1 170:1

175:15 192:6

Charlie's 85:6

166:15

chart 121:8 130:8

charts 191:12

cheaper 205:11

check 48:4

62:18,22 65:4

146:19 153:10

155:14,16 179:8

180:3,16

182:11,17

183:8,9,15,16

184:17 185:9

195:4 196:2

206:4,12

207:8,10 210:2

211:20 213:16

checked 206:3,7

209:19 211:14

213:3,5

checking 148:16

180:15 187:15

207:3 215:13

checklist 109:4

checks 153:5,6,7

182:20 185:14

206:6 211:17

chiller 93:22 94:1

chillers 76:22 94:2

105:21 106:13

choice 36:10 168:7

choose 74:11

133:13,14

153:18 158:16

172:14

chooses 12:12

choosing 156:22

chose 77:17

Christine 1:17

217:2,15

circuits 163:10

circulated 7:14

circumscribing

32:12

circumstance

194:21 195:17

200:10

circumstances

110:10 111:19

citizen 147:1

civil 68:9

claim 56:22 57:8

claimed 60:10

claims 57:18

clarification 61:22

70:8 132:2 176:4

clarify 25:12 102:8

150:18

clarity 44:5

class 77:4 149:17

164:1,15,21

classes 20:2 39:1

56:15 194:4

classified 118:5

clear 15:16 33:11

42:18 44:1 46:7

63:14 77:20

80:15 186:17

189:11

clearly 6:22 25:16

26:6

Cleaver-Brooks

3:6

client 88:3 93:8

ClimateMaster

3:22

close 19:10 34:20

86:7 94:19

closed 87:11
Capital Reporting Company

Appliance Standards Federal Advisory Committee Meeting 08-01-2013

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closer 99:7

closest 166:8

club 143:21

Co 2:22 3:5

code 4:4 126:3,7

163:4

codes 20:10

coil 213:7,22

coils 34:22 117:12

212:11

cold 115:10

collecting 171:9

Collin 3:20 201:17

combination 40:21

107:5 128:19

combined 132:9

comes 20:12 26:20

49:16 50:1 60:11

84:13 124:16

130:18 152:4

201:22 203:5

204:10

comfort 156:5

comfortable 8:4

59:20 92:6

155:21 156:2,3

169:12 212:13

coming 21:7 49:10

51:2 89:13 99:9

106:4 120:16

139:8 140:13

197:11,20

comment 103:6,7

126:8 131:10

138:3 170:1

176:1

commented

109:18

comments 7:13

25:14,15 123:15

188:17 191:6,9

commerce 59:13

60:4 84:17 145:1

153:10

commercial

26:9,10,12,17

27:14 87:9

108:10,11

117:10 118:6

133:21 134:5,7

141:1,2,4

144:10,18

148:19

203:12,17

commit 6:4

committee 1:4

6:22 7:3 155:15

216:2

commodity 138:6

common 197:12

212:8

communication

99:8 178:8

companies 5:20

6:1 18:7 27:19

47:13 55:20

151:18 156:14

157:1 172:17

company 1:18

2:20 4:12 33:17

37:1 48:4 73:3

80:4,6 115:7

128:17 129:18

146:14,21

148:1,2 149:11

150:2,18,19,20

152:12 153:3,14

159:15

160:5,12,20

163:1 172:12

193:1

company's 180:18

comparable 210:5

compare 16:20

152:22

compared 152:11

156:14

comparing 56:10

57:22 131:11,14

151:17 152:10

competency 91:6

95:15

competition 92:6

competitively 43:1

competitor 48:3

competitors 18:9

43:8 48:7 193:11

205:19

complain 48:7

complaint

47:12,21 52:14

64:15

complaints 46:5

47:12,21

52:16,22

53:3,10,11

61:1,3 183:4,11

187:13

complete 8:20

103:18 106:16

completely 51:5

192:2 193:3

compliance 13:4

16:11

compliant 14:1

66:19 68:3,5,9

compliments

205:14

comply 83:19

98:20 135:4

146:22 163:6

component 200:18

componentry

204:13 206:12

208:22 209:19

210:3 211:13

213:1,2 214:21

215:5

components

105:13 153:5

204:9 207:8,10

211:5,18,19

212:6,7 213:20

214:6,7

compressor 204:8

210:21 211:4

212:16 214:5

compressors 212:3

214:4

concede 69:4

conceivably 69:12

conceive 46:10

concept 6:8 10:5

36:20 87:17

94:10 111:2

120:21 138:11

139:10 142:4

165:11

conceptualize

136:12

conceptually 83:7

120:10

concern 20:3 23:5

33:6 46:8 54:9

93:19 103:9

105:3 130:22

132:16 134:19

135:5 156:15
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Appliance Standards Federal Advisory Committee Meeting 08-01-2013

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189:22

concerned 18:17

43:13

46:15,18,21

186:20

concerns 15:10

31:7 44:4,6

45:20 154:21

189:7 190:5

214:22

concluded 13:4,10

216:2

condenser 211:4

212:3

condensing 39:21

40:20

conditioners 41:17

49:17 76:22 77:5

Conditioning

168:22

conditions 91:8

conduct 13:11,16

14:3,13,21 37:13

93:15 99:21

conducted 12:13

13:18

conducting 175:20

conference 7:16

confidence 66:20

confidential

205:16

confirm 84:22

191:3

conflict 25:11

confuse 192:20

confused 164:9

186:10 190:8

211:21

confusing 149:20

confusion 43:20

75:13

conjunction 189:1

connotations

77:12

consensus 119:16

136:18 137:5

consequence 70:3

162:1

consequences

141:7 184:22

consequently

135:21

consider 144:10

157:14

considerable 32:4

consideration 7:21

199:2

considered

86:17,21 198:22

considering 91:19

considers 15:22

consistency 135:1

194:20

consistently 54:10

constantly 11:20

constitutes 169:10

constrained 41:17

construction 142:2

Consultants 2:17

Consulting 2:3

consume 31:17

consumed 106:12

consumer 115:6

consumers 144:17

consumes 31:15

consuming 24:2

212:17 213:20

214:7 215:5

consumption 51:8

consumptive

211:18

contacted 177:19

contemplate 68:21

contest 69:11,13

context 17:11 39:4

76:16 137:13

186:16 187:7

contingent 7:4

continual 179:20

continue 63:10

188:18 191:11

continued 17:16

185:20

continues 54:17

60:10

continuing 14:2,11

54:13,22 122:12

continuous 54:4

65:22

contract 147:2

contracted 174:21

contractor 115:7

201:4

contradict 170:2

contradicts 174:12

control 57:17 87:3

92:2,12,17 95:5

125:7 185:11

192:3 211:20

controls 21:17

87:3 186:22

187:2 214:5

conversations

181:1

converted 133:6

convince 160:19

convinced 69:16

Cooling 2:16

coordinate 16:9

coordinated 109:8

copies 71:15,22

copper 34:22

Corey 3:19

Corporation

3:11,21

correct 49:9 66:14

70:18 76:3 81:1

84:17 91:18 94:8

105:8 152:6,20

177:3 178:15

180:13 191:5

212:2

correctly 101:8

153:20 160:3

cost 47:2 62:3

69:16 155:1

costs 197:1,18

198:4 202:13

council 3:9 135:22

count 139:12

140:2

counter 138:16

country 161:4

163:2 203:7

couple 28:19 78:1

85:20 87:6

104:10 135:14

136:22 174:6
Capital Reporting Company

Appliance Standards Federal Advisory Committee Meeting 08-01-2013

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course 33:1 35:12

49:21

Court 217:1,2,15

cover 9:21 20:1

62:3 139:6

covered 10:12

11:8,15 27:5

71:11 78:5 83:22

84:2 99:22

100:13,18 114:8

118:9 143:5

covering 119:19

149:2

covers 143:21

159:7

cranes 199:18

crap 144:13

crawl 115:14

CRE 51:22 56:2

96:15

create 84:16

123:18 151:4

167:13

created 32:18

creates 57:17

120:8 175:19

creating 177:5

credibility 42:5

207:7

criteria 38:14

44:22 78:4 80:16

85:3 89:12 91:5

166:20 168:20

169:9

critic 49:9

critical 181:17

211:18 212:7

213:9,19

critically 20:22

criticism 25:22

cross 116:6

crossed 91:4 118:4

crosses 116:18

crossing 117:14

118:7

cruder 86:15

CSA 80:6 104:6

154:18 166:14

current 114:20

124:20

currently 20:10,20

22:17 43:20

62:17 77:5,6

101:3 139:22

178:5 182:21

custom 30:20

61:18 109:10

123:22

customer 31:15,19

37:11 198:10,14

customers 38:3

47:13 52:18

customer's 199:14

customized 38:15

199:4

cut 26:5

cyber 213:14

cycle 61:19 109:1

cycles 49:15,20

cycling 60:16

Cymbalsky 2:12

6:6 20:8 49:6

50:15 51:9,14,16

109:14

D

D.C 1:9 119:11

Daikin 3:2

damages 199:19

Dane 2:13 95:21

96:6 97:1,9,20

171:8,16,21

172:6

danger 127:13

darn 49:11

data 14:17 53:17

59:17 66:19

67:1,15 74:1,2

88:3 91:15 93:8

94:6 112:5,13

113:20 145:12

146:1 148:10,15

149:12

150:9,10,12

152:3,13,14,20

156:13

162:15,21

163:13,21

164:3,11,19,22

165:4,6

166:12,15

167:22

171:2,9,11,14,18

172:1,5 208:4

210:8 212:15

database

151:18,22

152:5,10

208:3,4,5,6

date 4:7,21,22

5:4,6,7 8:18,22

9:4 109:1,3

dates 103:20

day 107:4 147:19

193:15,17

200:14 202:8

208:4

days 37:11 87:18

104:5 196:5

200:12 202:5,7

deadlines 20:11

21:1

deal 8:22 9:3,6

48:9 85:6

105:9,12 110:19

114:8 154:10

180:17 193:13

dealing 86:14,15

deals 95:10

dealt 114:11

decide 7:16,17

19:13 43:17 49:4

188:13 192:11

decides 46:10

138:8 190:4

decision 7:14

69:10

decisions 138:14

deep 38:13 125:22

deeper 180:14

define 24:1

134:2,5,6

defined 77:4 87:16

117:20 151:2

179:1

defining 119:21

120:4 127:2

definite 117:5,7

definitely 32:14

117:13 153:22

189:4

definition 10:5,16

34:8 36:17,18
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Appliance Standards Federal Advisory Committee Meeting 08-01-2013

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87:18

120:11,12,13,22

126:4 128:6

129:14,16

130:13,18 131:1

133:4 134:15

140:1,22

definitions 9:18

124:4,8

134:14,21

135:3,8,19

136:1,19 137:13

Degitz 2:14

degree 86:13

188:20

delay 198:2,5

delegated 188:14

deleted 184:5

deliver 99:11

101:14

delivered 54:18

60:2,3

delivery 18:4

delved 125:22

demand 46:21

demanding 31:19

densities 86:10

density 213:7

department 1:1,6

2:8,10,12 21:18

46:1 62:2,20

110:8 145:10

152:19

depend 47:11

54:11,14

104:7,8,19

dependent 104:13

113:19

depending 20:13

106:5 107:2

197:8

depends 69:21

de-rate 125:4,5

de-rated 31:18

describe 25:16,20

93:1

described 54:22

58:12,14 140:2

describing 198:8

description 139:18

design 16:11

127:15 201:4

202:11

designed 119:11

designs 125:11

detail 212:1

detailed 203:20

212:11,18

213:12

details 32:15 33:2

181:20 189:17

determination

104:17

determine 44:18

60:12,19 111:20

164:3

determined 81:13

147:10

devastating 68:14

develop 130:14

153:17 158:16

developed 26:21

27:18 81:7,9

developing 78:3

209:6

Development 3:6

deviated 35:1

diameters

213:8,16

Diane 2:22

DICP 76:6

dictate 25:9

differ 62:14

133:20

difference 10:17

29:12 30:3 37:18

40:9 43:14,15

56:12 65:20 84:7

117:5 127:16

131:6 167:13,16

183:17

differences 34:12

88:18 109:16

128:21

different 11:4

23:16,17

25:3,4,10 29:22

31:8,9,14 35:21

36:14 39:1,2,11

50:2 63:1 64:9

70:21 77:12

86:10 93:3 95:13

102:14 105:17

106:19 113:10

115:11 117:13

121:6 123:2

124:6,14

125:6,10,13,19

126:12

127:4,7,12,19,20

128:8 129:14

134:6 139:19

141:8 142:5

154:19

162:9,17,18

164:8 166:6,12

168:5

169:17,18,19

174:2 182:6

187:14 189:16

190:12,13,14,19

192:20 199:2

203:4 213:17

differentiate 38:16

differentiating

154:10

differently 87:21

128:11 137:17

difficult 110:7

120:15 127:6

129:11 146:10

difficulties 38:19

difficulty 28:20

190:18

Digital 217:15

dimensions 204:11

213:7

direct 12:13 92:11

158:15 174:13

185:18

direction 217:6

directly 54:16

108:10

directory 57:15

145:2,3 207:20

disadvantage 19:6

disadvantaging

21:9

discern 92:14

discontinued

139:12,13

discuss 4:18 22:13

108:2 112:14

143:1 189:2

discussed 8:7 77:7
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117:1 118:15

162:19 171:19

172:19 176:12

177:9 187:7

188:20 189:3,5,9

discussing 72:1

198:21

discussion 9:16

17:22 43:11

72:11 84:20

96:22 118:17

119:12 133:21

143:8 149:20

162:4 174:22

177:1,12 184:4

186:11,16

187:22 189:12

191:10 214:19

discussions 69:7

118:19 167:17

190:1,6,9

dismissing 91:20

disruption 38:5

dissatisfied 52:18

distinction 39:4

91:3 111:10,14

179:17 180:8,10

distribution 193:7

divide 11:1 12:3

division 80:2

docket 7:13

document 161:20

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104:7,8
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notion 64:10

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88:8,10 120:1

satisfied 169:3

satisfy 204:16

save 86:18 135:21

saved 21:1

savings 42:4

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scale 19:10 129:9

scaling 138:3

schedule

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scheduled 4:11

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send 8:20 45:15
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174:19 211:6

speaking 207:12

214:6

special 214:13

specially 16:12

species 135:17

specific 61:20

95:10,19 104:14

105:7 133:18

205:13,14

212:20

specifically 177:5

194:20 202:11

204:17

specification

46:22 107:12

specifications

16:11

specifics 83:7

specified 74:15

107:15

specify 204:9

spectrum 24:10

36:3 45:22 52:1

spelled 26:6

spend 19:7 32:4

34:4

spent 78:3

split 41:18 86:13

87:3

spot 62:18,22 65:3

66:17 179:8

182:11,20

183:8,9 184:16

185:9,14 187:14

spot-checking

182:12

spread 37:6

185:13

spreadsheet 168:5

209:4

springtime 49:18

square 40:12

stabilized 202:5

stacked 38:12 39:8

staff 60:15

stage 182:3

stance 176:13

177:17

stand 146:16

standard 23:22

40:10,16 61:15

67:7,10 70:10,16

71:5,6 120:4

126:12 185:2

192:18 204:6

standards 1:3

20:10,12 24:6,7

45:14 51:21 90:4

105:7 118:4,7,8

144:11 160:21

216:1

stands 9:4

Stanonik 3:12

25:13 58:10 59:6

60:14 61:2,5

63:2,6,18

64:7,11,19 65:5

77:22 78:21

80:12 81:3

91:10,17 111:17

146:5 176:22

177:14,21

178:4,9

179:16,19

180:1,9,20 181:4

194:18 195:2

196:14 200:9

Star 20:19

22:18,20,21

23:15,17,20,21

24:8,9,18,21

26:8,11 27:22

28:22 29:13,15

50:2,4,16,17

79:16,21 89:17

94:10 208:22

Starr 3:14 137:9

138:22 170:13

201:2,6 215:4

stars 142:15

Star's 27:1 128:2

start 4:12 11:19

15:8,12 23:10

52:15 72:1 86:3

103:19 110:20

127:2 134:17

136:16 141:11

159:16,20

160:10 191:20

started 4:3 34:10

43:18 150:3

161:11 188:7

starting 16:18

23:9 75:9 96:8

163:15 192:5

214:18

starts 73:3 96:18

152:12

state 44:6

stated 114:6

statement 80:20

175:11

station 119:2,6,7

statistical 65:1

statistics 67:10

132:21

statute 47:8

statutory 21:1

stay 36:10 185:17

202:6

stays 188:3

steak 49:10

Stem 3:15 95:9

96:3 104:12

105:4 107:17
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60:3 112:8

Stephens 3:16

40:7 41:9 61:21

62:8 76:9 77:8

109:22 114:12

116:2 132:1,8,14

133:12 142:18

145:9 147:21

148:12 157:11

170:10 191:22

192:16 205:1

208:15

stock 168:9 194:7

195:9

200:7,15,18

203:15

stockable 193:21

198:20

stocked 192:8

193:22

194:21,22 200:5

201:19 203:18

stone 215:9

stop 11:18

12:13,22 64:17

68:7

straight 200:17

straightforward

106:20

stretch 52:9

strict 176:7

strikes 127:22

stringent 75:21

154:19

strongly 81:8

structure 40:15

structured 98:19

146:9

stuff 39:13 107:6,7

152:17 158:15

172:9 196:12

198:16,21

stupid 137:8

sub 111:14

sub-bullets 157:10

subject 14:2 30:11

55:15 59:1 68:9

76:18 118:19

140:18 142:10

185:1

subjected 30:16

183:2 206:10

submission 74:1

163:17 210:19

submit 36:7 110:3

150:4,8,11 165:6

167:22 168:9

208:8

submittal 57:2

submitted 24:21

172:12

submitting 57:6,8

113:12 162:21

163:12 166:15

subpart 131:9

subpoena 172:8

subpoenaed 172:5

subpoenaing

46:15,19

subsection 177:6

subsequent 58:17

substantial 42:3

substantiate 84:22

substitute 12:16

subvert 144:11

subway 119:2,6,7

successful 13:3

successfully 13:10

suddenly 127:4,13

152:12

suggest 22:4 35:11

78:17 206:16

suggested 117:21

119:14 141:16

suggesting 146:7

suggestion 38:21

209:14,16 210:1

214:15

suggestions 4:8

188:17

suited 54:21

Summarize

100:19

summarized

75:7,8

summary 7:13

74:13

summer 86:10

super 125:9

supervised 94:11

supervising 94:13

210:2

supervision 95:8

96:18 98:3

107:22 164:13

170:3 174:13

181:11,18 182:2

supplied 53:15

supplier 153:2,4,8

suppliers 153:3

supply 28:10

139:5

supplying 153:11

support 9:17

45:12 64:14

132:11 162:15

supports 59:18

suppose 69:19

supposed 130:20

145:15 154:21

159:22 160:6

207:4 212:20

sure 9:17 15:3

16:12 21:8,18

29:5 34:15 36:21

43:13,21 45:13

48:6 49:11

53:5,8 58:20

67:5 69:2

70:15,17,22 71:2

72:3 77:20 79:1

82:10,15 85:10

87:6 88:11 94:4

96:6 97:1,4

100:3,18 101:8

111:3 116:20

120:21 122:11

129:17 130:1,13

134:11 135:2,16

144:15,16,18

148:10 149:8

152:19 153:10

154:16,20

155:17 156:2

158:19 160:2

161:18 170:17

173:4,9,10

176:16 182:8

186:15 189:11

201:17 203:2,20

204:1 205:2

207:3,16 212:18

surface 188:7
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surprise 193:5

surprised 8:1

survived 135:20

susceptible 50:20

suspect 34:18 54:9

85:10 116:16

suspicious 183:10

Swiss 86:14,16

sympathetic

135:18

sympathy 42:20

system 31:14

164:2 168:15

213:9

systematic 144:10

systems 14:16

41:18 109:20

210:14

T

table 33:19 46:7

118:14 138:21

187:17

tack 152:22

tailored 51:3

taking 164:13

171:2 184:19

talk 4:6 15:2

16:4,7 26:7

28:13 32:13

48:10 59:7 60:14

111:4 112:20

117:22 138:19

143:12 186:14

192:21 194:20

talked 6:7 7:11

16:19 17:8,9,10

34:13 71:1 101:5

113:21 143:3,10

162:9,12,17

179:6 181:19

186:8,12 191:16

talking 9:20 15:8

17:6 18:2 20:2

26:10 29:6,15,16

32:5 35:1 38:13

39:15 50:13

53:22 54:13

56:7,8,9,13

57:19 58:1 59:8

68:18 77:12,18

78:1 84:10

94:8,11 95:4,11

96:8,19,20

97:6,21 98:9,16

103:14 104:19

110:20,22 118:3

124:20 128:9

129:11 132:3,19

134:3 135:17

139:22 150:19

151:11

156:21,22 157:5

158:5 159:7

164:4 166:17

170:1

176:17,19,20

178:13,16

179:20 182:6

190:13,22

193:18 194:4

198:20 201:8

212:3,9 214:10

target 45:8

targeted 45:21

targeting 16:6

46:8

tear 52:2

tear-downs 52:1

technical 64:6

204:2,6

technically 90:20

91:6

technique 203:12

technologies 2:21

40:11

technology 104:14

125:5 128:19,20

temp 87:11

ten 38:13 194:22

195:1

tenant 100:4

tenants 14:8

tend 87:1 114:5

123:22

193:19,21

211:15

tends 125:15,16

ten-minute 72:4

term 32:7 45:20

79:1 120:6

213:18

terminology 31:7

58:11 77:21

194:20 207:19

terms 6:19,20 9:11

16:17 21:8 23:6

25:19 26:3 29:6

44:1 60:16

78:7,15 100:4

120:16 129:2

146:9 154:15

179:9 181:6

186:22

188:12,18

territory 148:19

test 10:3

12:5,9,13,15

13:14,17

14:1,17,21 16:2

18:12,14 20:12

23:21 24:7,15,19

30:21

37:3,4,13,15

39:20 40:21

41:7,13

44:10,19,22

47:22 51:21

52:2,5,6 53:17

54:1 55:11 56:21

57:11,13

59:17,19,20

60:9,20

66:3,13,19

67:1,13 68:16

69:17 70:6

73:10,19 74:1

75:3,5,6,7,8 76:2

79:19 82:21 83:3

85:13,14,15,22

86:2 87:13

88:3,13,17,18

90:2,19 91:2,8

93:4,8 94:1,5

95:12,15 96:12

98:13

99:2,3,16,17,21

100:3

101:2,11,16,19

103:11,12,15,22

104:20 105:10

106:4

107:1,4,11,12,13

,15 108:8,22

109:2,8 110:4

111:12,13

112:5,13

113:9,13,17,20

114:9 116:14

118:4

121:8,10,22

122:9,13,15

123:5,12
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124:10,13

127:11 128:3

129:4,20

130:2,10

131:12,13

132:19 140:4

141:8,15 145:4,5

146:1 147:13

148:4,10,15

149:10,12

150:9,10,12

152:3 153:19

155:8 157:22

162:15,21

163:12

164:3,11,15,19,2

2 165:4,6,9

166:11 170:15

171:2,9,11,14,17

172:15 173:8

175:4,8,9 177:11

178:15,19

183:14,19,22

184:20 185:21

190:2

195:6,15,18,22

196:6,20,21,22

197:5 202:11,12

203:1,2 205:15

206:9 211:15

212:12 214:13

tested 9:22 11:15

12:1 16:12

17:9,10 18:6

23:20 24:20,21

25:7,9 29:18

33:12 36:9 39:13

43:17 45:4,10,17

48:18 49:5 53:15

55:6,20 67:9

69:2,4

73:4,15,17 78:20

91:11 112:2,11

113:5 120:17

121:7 123:2

128:8 130:4

132:9 134:4

150:15 152:17

153:15 155:9

169:21 173:13

192:5 194:9

198:1 203:22

209:7,9

tester 83:15 90:22

196:6

testers 188:4

testing 9:20

11:8,21

13:2,3,4,10,12,1

7 14:3,7

15:9,13,18

16:4,6,18,20

17:5,6,12,16

18:3,13,15,17,18

,21 19:7

21:12,16 22:1,8

23:1,22 24:9

25:16,21 26:4

28:10,21

30:2,5,7,8,9,12,1

7 32:10,22 34:5

37:5,19 39:11,17

44:1,4,12,16

45:5,7,12 46:4

47:5,6 50:14,17

52:12,20,21

54:12,13,20,22

55:18 56:16

58:17 60:13

61:4,20

62:2,4,12,14,15,

19,21,22

63:1,10,14,16,20

,21

64:2,8,9,13,14,1

7,22 65:1

66:5,9,11,17,18

67:6,19

68:4,10,13 70:9

73:16,22

74:5,13,22 75:4

76:1 80:11 82:10

83:11,13 84:21

85:2,9 87:8 88:1

90:13 91:22

92:7,8,10,16,18

93:6,12,15,18

94:11,13 95:1

96:17 98:2,3

99:12

100:4,10,19

101:6,15

103:19,20

104:3,9 105:7,18

106:7,8 112:10

119:21 126:5

127:21 132:12

139:3,14

141:6,9,11

145:6,8,14,16

150:6 151:19

153:18 159:22

160:2 165:6

168:1 171:1

174:7,8,11,21

175:2,5,20

176:15,17,20

177:2,15,20,22

178:2,7,12,14

179:3 180:3

181:3 182:21

183:3,4,5,20

184:2,14,22

185:2 187:2,8,12

188:13,16

189:14,15 190:1

192:15 194:3

195:20 196:16

202:4,20 207:18

208:21

209:1,15,19

210:2 211:14,17

213:10 214:3

215:3

testing's 169:2

tests 16:13 37:10

38:2,7 56:7

57:1,7,10 64:15

65:11,18 66:10

88:21 105:5

120:9 121:14,16

123:13 124:2

142:11 146:22

147:8,10 149:21

155:1 174:13

175:11,12 179:9

194:15

test-wise 127:8

text 120:1 170:12

textbook 120:13

thank 11:6 14:22

21:5 71:20 74:20

81:14 88:22

116:1 151:6

162:3

thanks 9:1 189:20

Tharp 3:17 4:9,15

5:7 6:11,15,17

22:3 35:10,17

44:21 72:20 73:5

74:18 75:8,17

76:3 80:1 84:15

92:5 95:7 102:19

109:15 112:14

113:11 117:9

131:4,7,20 141:1

144:1 149:6

152:21 155:4

168:21 205:12

206:3,6,13

207:8,10,17,22

208:14 211:4

that'd 127:11

that's 6:18 8:6,9
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12:13

14:5,8,19,21

16:7 17:15 19:8

20:13,14 21:21

23:8 24:3 25:22

28:11

32:3,14,17,18

36:1 37:5,17,19

39:8 40:22

41:7,17,18 44:14

45:5,18 46:6

47:8 51:6,17

54:2 55:13,19

57:21

58:3,5,15,22

59:9 60:11 61:15

65:3 66:5,14

67:12 69:19 70:6

74:17,18 75:1,9

78:13 80:4 81:14

83:20 86:4,12

87:17,20 91:13

92:2,9,13 99:11

100:15,17 102:3

104:14,16 105:8

106:18,20

107:3,18 109:12

111:17 112:6

113:16 120:22

122:11 123:20

127:5 128:18

134:11 136:4,10

138:5,12 140:1,4

141:2,14,18

142:12 143:6

145:7,14 146:3

147:11,20 149:2

154:20

155:10,20

161:22 163:19

166:12 169:12

170:8 172:6,20

173:4,19 174:14

175:4,21 176:10

178:18

180:17,22

182:11 186:18

187:6,11,15,21

190:7,18

191:1,3,7 192:12

194:3,5 196:18

201:5 204:21

205:8,14,15,17

206:9 211:9

212:19,20

213:15

theirs 79:11

106:17

themselves 90:20

104:4 158:1

174:11 175:18

212:6

theory 59:22

thereafter 217:5

there'd 7:14

182:18

therefore 118:6

197:18

there's 9:17 10:17

16:22 23:5,9

24:19

26:12,14,17

27:16 28:8,9

36:14,15 38:17

39:4,19 43:19

47:19 49:15 50:7

51:18 53:14

55:22 57:20 60:2

65:9 66:5,8 73:1

75:2 87:3 90:17

91:3 93:2,7

95:13 98:21

103:16 105:5,12

107:19 109:18

112:12 117:5

121:4 126:10

133:17 137:5

140:13 148:5

149:20 150:7

153:2 157:12

166:9,10 173:3

175:1,2

179:14,15,17

191:10 192:5

196:20 197:6

199:12 204:4

208:7,19 210:17

211:14

they'll 4:16 103:19

160:12 209:6,8

they're 13:6 23:18

24:12 29:1 30:22

31:2,3,22

38:3,12 50:19

51:17 55:21

58:20 62:16

68:9,17 71:4,5

77:6,7 78:20

90:4,21 99:15

103:13,16,18

117:6 121:13

122:7 126:20

127:7 133:16

135:8 137:8

145:11 149:11

151:16 159:17

160:5,7,14

164:4,13 165:22

166:1,3 170:22

171:17

174:11,12

190:19,20 194:8

199:14,15

200:3,18 213:13

they've 67:21 68:8

69:3 93:14

135:19

163:3,4,7,8,11

200:14,22

third 28:19 35:14

75:1,14 83:3,10

88:1

90:1,5,14,18,19

91:4,7,12

92:11,12,17,19

94:2,3 96:18

100:1 101:18

105:22 106:4,6

143:14 150:15

167:20 168:1

173:10 175:13

187:13 188:3

192:10 205:9

third-party 13:20

14:4 16:17 57:11

64:1 153:15

168:17 170:6

175:8 177:19

205:7 210:1

thoughts 17:3 20:6

129:6

thousands 10:2

threat 144:17,18

three-day 14:14

101:15

threshold 36:15

39:11 57:18

142:13 156:3

thresholds 39:2

throughout 179:4

throw 33:14 86:22

117:18 118:2

165:10

throwing 32:6

33:18

Thursday 1:11

tighter

57:12,14,16

Tim 42:6 52:10
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141:5,17 142:15

151:16 184:11

208:14

timeframe 4:19

8:8 74:15

timeline 105:14

timelines 54:14

105:17,18

211:13

Timothy 2:9

today 4:5 24:7

34:2 39:15,20

40:22 65:7 79:16

129:13,16,20

131:11 184:4

196:8 200:11

210:17 215:16

tolerance 57:12,14

107:15

tolerances

56:17,18 107:13

Tom 3:2

tomorrow

137:20,21,22

200:20

tomorrow's

200:11

ton 77:5

tons 118:5 198:9

to-order 199:1

top 10:16 34:15

topic 135:11

toss 120:19

tossing 122:4

total 24:13 36:7,9

totally 23:7 54:2

60:21 174:12

199:6

touch 111:7

touched 209:14

toward 119:17

towards 49:19

traced 106:10

track 51:1

trade 79:4 167:9

tradeoffs 138:7

training 14:13

101:7

Trane 2:19 89:2

108:6,14

139:11,22

transaction 155:21

transcript 217:6

transfer 3:16

211:5

translate 145:18

translating 145:19

transparency

15:10

transparent 48:16

Traulsen 2:13

95:21 171:8

travel 93:5 106:21

treat 80:3,5

treated 21:8,19

triggers 184:21

trips 203:4

Tritsis 3:18 94:7

109:18 176:4,5

trouble 129:8

true 2:18 51:18

82:8 145:14

173:19,20 194:6

217:6

truly 31:18

try 6:4 35:6,7 45:3

58:6 129:10

134:1 145:20

146:12 157:17

192:21

trying 40:12 48:4

49:1 52:8,10

55:9 58:13 59:2

60:5 80:18 91:17

92:3,13 96:13

102:8 129:12

133:1 134:9

175:21 213:18

tube 213:8

Tucker 3:19

turning 163:20

tweak 127:3

Twenty 140:3

twice 49:12

two-plate 117:11

two-week 208:7

tying 198:15

type 45:9 72:14

73:11 87:2

109:17 121:3

126:17 129:9

130:5 152:19

153:8 155:16

205:15,21

206:19

typed 122:17

typewriting 217:5

typically 40:11

153:5 199:12

typing 128:6

U

U.S 2:8,10,12

144:11 150:3

UL 14:10 30:18

79:15,19 80:1,7

82:19

88:3,7,18,19

90:19 93:2,3,5

94:12,16 98:8

102:2 105:20

106:21 150:17

153:13 154:17

159:14 163:8,9

166:14 168:22

169:2,22 174:4

201:21

202:6,18,20

204:6,10 205:11

206:8,12,22

210:6,7 212:14

UL's 81:21

ultimate 106:11

180:15

umbrella 95:16

uncertainty 42:21

unclear 33:8

underlying 66:11

150:9,10

underneath 95:15

understand 7:22

15:11 17:16,19

18:2 19:3

29:5,12 32:7

40:19 79:1 87:6

88:22 99:3

105:15 132:16

136:15 139:21

142:17 149:8

174:16 187:18

189:21 190:3,12
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understanding

25:5 27:22 28:20

53:14 102:9

116:12 125:2

137:15 160:17

understandings

43:2

understands 43:22

understood 99:14

Underwriters 3:4

unfair 19:3,4,6

187:19

unfortunately

127:2

UNIDENTIFIED

27:10 48:10

72:18 74:17

90:12,16 119:6

131:18 137:20

156:18 159:3

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