Date: October 29, 2014 

Case: NOPR For PTACs and PTHPs 

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NOPR For PTACs and PTHPs 

October 29,2014 

DEPARTMENT OF ENERGY MEETING 

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NOTICE OF PROPOSED RULEMAKING (NOPR) FOR PACKAGED 

TERMINAL AIR CONDITIONERS (PTACs) AND PACKAGED 

TERMINAL HEAT PUMPS (PTHPs) 

Wednesday, October 29, 2014 

9:00 A.M. 

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NOPR For PTACs and PTHPs 

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Appearances for Department of Energy Meeting 

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3 Ron Majette, DOE 

4 Doug Brookman, Public Solutions, -- Moderator 

5 Alison Williams, LBNL 

6 Pete Cochran, DOE 

7 Sarah Butler, DOE 

8 Johnson Balski, DOE 

9 John Cymbalsky, DOE 

10 Ashley Armstrong, DOE 

II Christopher Lau, Navigant 

12 Aniruddh Roy, Goodman Manufacturing 

13 Dain M. Hansen, IAPMO 

14 Jessica Lewis, Navigant 

15 J. Decker Ringo, Navigant 

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16 Laura G. Petrillo-Groh, Air-Conditioning, Heating, & 

17 Refrigeration Institute 

18 Marshall Hunt, Pacific Gas and Electric Company 

19 Donald M. Brundage, Southern Company 

20 Steve Bonner, Texas Instruments 

21 Steven J. Rosenstock, Edison Electric Institute 

22 Detlef Westphalen, Navigant 

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NOPR For PTACs and PTHPs 

October 29, 2014 

Appearances for Department of Energy Meeting 

Bingyi Yu, Lawrence Berkeley National Laboratory 

Yoolanda Williams, General Electric Home & Business 

Solutions 

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NOPR For PTACs and PTHPs 

October 29, 2014 

PRO C E E DIN G S 

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MR. BROOKMAN: Let's begin. Good morning 

everyone, welcome. This is the Notice of Proposed 

Rulemaking for Packaged Terminal Air Conditioners and 

Packaged Terminal Heat Pumps. Today is October 29, 

2014, here at the Forrestal Building in the 

Department of Energy. My name is Doug Brookman, 

Public Solutions, Baltimore, nice to see you here we 

are going to start with welcoming remarks from Ron 

Majette. 

MR. MAJETTE: Good morning everybody. My 

name is Ron Majette from the O.S. Department of 

Energy, Project Lead for this package that we are 

going to discuss today. I wanted to welcome 

everybody, the Department of Energy I hope you 

enjoyed your entrance into the building and you got 

your laptops in, I hope that was a fun experience. 

Anyway, I just kind of do the purpose of 

the meeting. Today we are going to present the 

Energy and Conservation Standards that DOE is 

proposing for PTACS and packaged terminal heat pumps. 

We are inviting comment on the analysis from the 

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participants. 

NOPR For PTACs and PTHPs 

October 29, 20 14 

We are going to have open discussion 

Page 5 

2 for the next steps for the rulemaking and I wanted to 

3 make sure we encourage everybody to submit data and 

4 information, any summary statements, written comments 

5 and you know anything helpful to move the project 

6 along, all right? Thank you very much. 

7 MR. BROOKMAN: Thank you. We always 

8 start with introductions. I'll start to my immediate 

9 left, you can get used to turning this microphone on 

10 and off, your name and organizational affiliation. 

1 I Don Brundage, Southern Company; Steve Rosenstock, 

12 Edison Electric Institute; I'm Aniruddh Roy, Goodman 

13 Manufacturing; Laura Petrillo-Groh, 

14 Air-Conditioning, Heating & Refrigeration Institute; 

15 Yoolanda Williams, GE Appliances; Marshall Hunt, 

16 Pacific Gas and Electric and the statewide IE Team 

17 from California; Pete Cochran , Department of 

18 Energy, General Counsel's Office; Sara Butler, DOE; 

19 Ron Majette, DOE; Johnson Balski, DOE; Decker 

20 Ringer, Navigant Consulting; Bingyi Yu, Lawrence 

21 Berkeley National Laboratory; Jessica Lewis, 

22 Navigant; Detlef Westphalen, Navigant Consulting. 

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Page 6 

MR. BROOKMAN: Thanks to all of you. All 

2 of you received a packet of information as you 

3 entered the building this morning. I am going to do 

4 a very quick spin through the agenda. You will find 

5 that on slide number 3, immediately following this 

6 agenda review, there's an opportunity for anybody 

7 that wishes to make brief summary remarks here at the 

8 outset, brief comments about issues that matter to 

9 you -- Moving on from there, Market and Technology 

10 Assessment, Screening Analysis, then Engineering 

11 Analysis. 

12 We'll take a break mid-morning around 

13 about 10:45 or so, following on from there Equipment 

14 Price Determination, Trial Standard Levels, Energy 

15 Use, Life-Cycle Cost Analysis. We'll take lunch 

16 around about noon and then returning from lunch, 

17 Shipments, National Impact Analysis, Manufacturer 

18 Impact Analysis Emissions and Monetization of 

19 Emissions, Utility Impact, Employment Impact, 

20 Regulatory Impact Analyses and then a description at 

21 the end of the day of the Proposed Standard. 

22 At the very end of the day the last item 

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for this group would be yet another opportunity to 

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2 make closing remarks. Any other issues that haven't 

3 been covered sufficiently, anything you wish to bring 

4 to the floor that would be the time to do it. I 

5 would ask for your consideration to observe the 

6 following ground rules. 

7 Please speak one at a time and say your 

8 name for the record each time you speak. There will 

9 be a complete transcript of this meeting. If you 

10 can be concise share the air time, keep the focus 

11 here, if your cell phones aren't on silent mode yet 

12 please turn them on silent mode and Webinar 

13 participants we welcome you. The Department of 

14 Energy is trying to make these meetings accessible to 

15 all live over the internet and they provide these 

16 webcasts to accommodate stakeholders who are unable 

17 to attend the public meeting in person. 

18 You should be able to listen in and view 

19 the sides and I would encourage you, the Department 

20 would encourage you to submit written comments after 

21 the public meeting like every other participant here 

22 in the room and if you would please, please have your 

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either telephones on mute and raise your hand to be 

2 recognized to speak. 

3 Most of the time works these days that we 

4 can hear you in the room as you speak via the 

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5 software. So that is most of the introductory stuff, 

6 if you look at slide number 6 these issue boxes are 

7 what the Department of Energy places in the packet to 

8 ask for specific comment. That's where they call 

9 out specific issues they wish to receive comment on 

10 so as we are going along, we will pause to try and 

II elaborate the points associated with those and then 

12 finally how to submit written comments. 

13 MR. MAJETTE: Ron Majette, DOE. For all 

14 correspondence needs to be referred to the PTAC PTHP 

15 Rulemaking -- Energy Conservation Standards for 

16 packaged terminal air conditioners and packaged 

17 terminal heat pumps. Docket Number EERE-2012-BT18 STD-0029 and Regulatory Identification Number 

19 1904-AC82. We have the email information here as 

20 well and you would just send it to Miss Brenda 

21 Edwards, okay. Do not send direct comments to me, 

22 there are public comments where they have to go 

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through the process so it's seen by everybody okay, 

2 thank you. 

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3 MR. BROOKMAN: It's important to note that 

4 the way this is listed here, try and be accurate 

5 because it may end up in the wrong spot if you don't 

6 get all the dashes and dots and everything correct, 

7 okay. So then opening remarks, anybody? Yes, 

8 Laura please? 

9 MS. PETRILLO-GROH: Thanks. Good morning 

10 my name is Laura Petrillo-Groh, I'm the Engineering 

II Manager of Regulatory Affairs at the 

12 Air-Conditioning, Heating and Refrigeration 

13 Institute. AHRI is a trade association representing 

14 over 300 manufacturers of heating, cooling, water 

15 heating and commercial refrigeration equipment. 

16 In the United States alone, AHRI's member 

17 companies employ approximately 130,000 people and 

18 support some 800,000 dealers, contractors and 

19 technicians. We appreciate the opportunity to 

20 comment on the U.S. Department of Energy's Notice of 

21 Proposed Rulemaking on the Energy Conservation 

22 Standards for Packaged Terminal Air-conditioners and 

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Packaged Terminal Heat Pumps, 

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2 However, we have several pressing concerns 

3 that need to be addressed before this Regulation goes 

4 into effect, The proposed levels stand to place 

5 significant burden on industry. Based on data from 

6 AHRI's certification directory accessed within the 

7 past two weeks, 85% of PTACs and 77% of PTHPs will 

8 require redesign to meet proposed level TSL2. 

9 It is not clear from the analysis 

10 accompanying the NOPR what the efficiency gains that 

11 the equipment will achieve based on implementing the 

12 technology options that DOE has considered. 

13 Further, we have noticed that the DOE has selected 

14 equipment for testing and teardowns in two different 

15 size bins which may not accurately represent the full 

16 capacity range of the product category. 

17 We have prepared a brief slideshow and 

18 would like to present it today on this issue. 

19 Another concern that members have with this 

20 rulemaking is that the median payback period for 

21 PTAC's and PTHP's is in no case greater -- is with 

22 the median payback period for PTAC's and PTHP's. In 

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no case is the median payback period shorter than the 

2 life of the product. This places a burden on the 

3 consumers of the product. 

4 Finally, for PTAC's and PTHP's greater 

5 than or equal to 12,000 Btu's per hour, the average 

6 lifecycle cost savings is negative and for all of the 

7 products the average lifecycle cost is zero. It's 

8 unclear how DOE is proposing a level with a negative 

9 LCC is economically justified. It is also unclear 

10 what the future of the industry will look like should 

11 the DOE proceed with setting such severe levels. 

12 Over the years regulations have forced 

13 manufacturing facilities for these products to move 

14 overseas. If the DOE were to adopt such stringent 

15 standards, we doubt that any PTAC's or PTHP's would 

16 remain as made in the USA. AHRI looks forward to 

17 working with the Department and others in 

18 establishing workable and credible energy 

19 conservation standards for packaged terminal 

20 air-conditioners and heat pumps. Thank you for the 

21 opportunity to present our views. We will provide 

22 more detailed comments in writing. 

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Page 12 

MR. BROOKMAN: Okay, thank you and we will 

see those presentation slides when we reach the 

appropriate spot in the agenda. You said before they 

correspond to the 

(Discussion off mic.) 

MR. BROOKMAN: So you would like to do 

them now? 

MS. PETRILLO-GROH: Yeah if that's okay. 

MR. BROOKMAN: Okay, let's do them now. 

MR. HUNT: Excuse me will we have a copy 

of this somewhere? 

MR. BROOKMAN: It will be in the docket. 

MR. HUNT: Thank you, Marshall Hunt, PGE 

MS. PETRILLO-GROH: So thank you for 

continuing to let me present on this. A few weeks 

ago our manufacturers downloaded information from 

AHRI's certification data base and compared it with 

the current and proposed DOE minimum efficiency 

standards for these products. The current DOE 

requirement is different from the baseline 

requirement in the standard. The baseline 

requirement in the standard, in terms of this 

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rulemaking is 90.1-2013 which is 1.8% higher 

2 efficiency for PTACs and is currently in place. 

3 We understand that that's the statutory 

4 requirement that DOE needs to fulfill but you know 

5 there are some areas of concerns that we have 

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6 regarding making sure that that is consistent across 

7 the board with the analysis. 

8 If you look at our first slide for PTACs, 

9 we've plotted what the models from the AHRI directory 

10 against the proposed levels. On the Y-axis, this is 

11 the PTACs certified EER. On the X-axis is the 

12 capacity. The proposed level is shown in I guess 

13 orange on the slide and there are very few models 

14 that meet this proposed level. I think 85% of PTACs 

15 would need to be redesigned and if you notice, as I 

16 mentioned in the opening statement the size bins that 

17 the DOE looked at for testing and teardown was in the 

18 -- I'm not sure, do you have a pointer? 

19 The units the DOE tested were -- you can't 

20 see that can you? In this size bin and this size 

21 bin, and as I mentioned that you may not be able to 

22 -- in the size bin about 9,000 -- around 9,000 Btu's 

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and around 14 to 15,000 Btu's. 

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And as you see 

2 those are the only two places where you have product 

3 that is meeting these proposed levels at all. 

4 Thanks. 

5 For PTHPs the situation is slightly better 

6 but not what we would consider fundamentally feasible 

7 to manufacture these products. For the COP again, 

8 the orange line is proposed TSL2 and you still see 

9 the same size bins that were analyzed and not 

10 necessarily represent the full capacity range of the 

11 product. There are the spikes at 9,000 and these 

12 are just around 9,000. 

13 So for the models eliminated in the 

14 directory you have got 85% at TSL2. Even at TSL1 we 

15 are looking at 66% of models requiring redesign for 

16 PTACs and almost 60% at TSL1 for PTHPs. 77% will 

17 require redesign at TSL2. We are not sure if this is 

18 consistent with the information you reviewed, but we 

19 hope it is not because it is very significant and it 

20 will place a severe burden on the industry. Thank 

21 you for letting me present, do you have any 

22 questions? 

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from DOE. Do 

the shipments 

NOPR For PTACs and PTHPs 

October 29, 2014 

CYMBALSKY: This is 

you have a sense for 

by the size bins that 

Page 15 

John Cyrnbalsky 

the percentage of 

you showed up 

there because I know there is a lot of different size 

classes, but I am curious as to whether or not they 

are bunched in, you know, like 9,000 what percent of 

the market is 12,000 and other percent? 

MS. PETRlLLO-GROH: I don't have a 

breakdown of shipments by efficiency if that would 

help persuade the DOE I would be -- I might be able 

to obtain that information however I might not be 

able to get it by the end of the comment period. 

MR. CYMBALSKY: Okay yeah, I was asking 

more about the different size bins irrespective of 

efficiency level are PTACs concentrated, I know 

there's a large range but are they concentrated in 

certain size bins? 

MR. ROSENSTOCK: Steve Rosenstock, EEl are 

you talking about shipments by capacity is that what 

you were? 

MS. PETRlLLlO-GROH: Again I wouldn't -- I 

don't have that information but I would be able to 

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Page 16 

obtain that information just maybe not by the comment 

2 period, is that of interest to the DOE? 

3 MR. CYMBALSKY: Yeah, well the 

4 manufacturers are here so maybe they can answer as 

5 well. 

6 MR. ROY: Aniruddh Roy, Goodman. John 

7 that's a very good question unfortunately the 

8 directory does not classify units by shipment, just 

9 pure ratings but I can tell you for a fact that there 

10 are manufacturers out there that have all of their 

II products -- rather none of their products currently 

12 on the directory. There exists manufacturers 

13 none of their products would meet the proposed 

14 standard as of now. 

15 So it's a very easy exercise if someone 

16 wanted to do it they could actually go to a 

17 manufacturer and just analyze data and determine 

18 which ones would not even be able to meet --

19 MR. CYMBALSKY: Thanks. My real question 

20 is so these go into hotel rooms right and as I travel 

21 a little bit around I notice that they look all the 

22 same. The size of the rooms look the same, so given 

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a certain comment I'm assuming the capacity is 

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2 roughly the same on all of these units that at least 

3 I've seen, I guess my question is you as a 

4 manufacturer I'm sure you know off your line are all 

5 of these 9,000 capacity or 12,000 or do you make a 

6 few in 30 or 40 bins that are here. 

7 I mean you can rate one everywhere but are 

8 there it seems to me that this stuff is you know I 

9 don't want you to use the term cookie cutter but a 

10 lot of these appear at least to be the same 

11 size-wise. 

12 MR. ROY: For us I can say that we make 

13 the standard PTACs and PTHPs so that's what we are 

14 1imi ted to. 

15 MR. BROOKMAN: Right, so those are -- need 

16 a lot of them do you wish to comment? 

17 MS. WILLIAMS: Yes, Yoolanda Williams, GE 

18 Appliances. GE makes PTACs and PTHPs and several 

19 what you call bins or capacity size and will 

20 typically group those you know, although it may not 

21 be exactly a 9,000 or 15,000 we'll group them under 

22 those categories. I think in terms of shipment by 

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each of those categories, if you wanted to get a 

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2 broad or concise view or summary for the industry or 

3 at least with AHRI members are producing I think it's 

4 something or data that could be collected. 

5 It may vary by manufacturer so you can get 

6 you know, an aggregate. 

7 MS. PETRILLO-GROH: We could -- aggregate 

8 that -- I'm also you know we do have product listed 

9 at all of these different size ranges so maybe 

10 motel's might be a very common application for this 

11 product but by manufacturers producing product in all 

12 these size ranges clearly there is market for each of 

13 the size ranges and does not just exclusively just 

14 9,000 or 15,000 Btu's. 

15 MR. CYMBALSKY: Okay thank you Laura. If 

16 the manufacturers producing in all these size ranges, 

17 it's a process that's not so concentrated it would 

18 appear one manufacturer is producing 45 different 

19 capacity sizes that they are pretty flexible in their 

20 process but I'm not an engineer but it seems to me 

21 that that's the case. 

22 MR. ROY: Aniruddh Roy, Goodman so John to 

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answer your question on the ranges -- so I think DOE 

2 did the analysis on 9,000 and 15,000 right. So ours 

3 range from for PTACs, our size ranges are from 9,000 

4 to close to 15,000, I'm sorry 7,000 to close to 

5 15,000. And then for PTHPs we are anywhere between 

6 7,700 to 14,400 that's just for our models. 

7 MR. BROOKMAN: Okay, thank you. 

8 MS. ARMSTRONG: I just want to know one 

9 thing. So now we did the rule in 2008, the data was 

10 provided that showed that those were the peaks for 

II the shipment weighed capacities and they had changed 

12 over time but at least to the DOE's knowledge we get 

13 the fact that people make products over the range, I 

14 don't think it's reasonable to think that DOE is 

15 going to analyze every single discrete capacity and 

16 obviously our inclusions account for the differences 

17 those capacities may have and the impacts they may 

18 have on efficiency but at the same time -- I mean to 

19 John's question. 

20 The last time the data we got did support 

21 this so and it was provided by the manufacturers. 

22 You guys track your sales, it's a fairly easy 

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exercise to do, it's not something that should take 

2 45 days so that being said you know I think it would 

3 be helpful if the data has changed since that time to 

4 provide DOE with that answer. 

5 MS. PEETRILLO-GROH: 45 days I think 

6 would be longer than we would need however I think 30 

7 days would be reasonable, we do have to aggregate the 

8 data to make sure that no one particular market is 

9 exposed. 

10 MR. BROOKMAN: Thank you Laura, thank you 

II Ashley. Okay so final comments in this segment and 

12 this new data that was presented by AHRI before we 

13 move on -- okay we are going to move on to the 

14 Context slides. 

15 MR. MAJETTE: Ron Majette, U.S. Department 

16 of Energy. Laura thanks for your presentation. I 

17 want to go ahead now and go back to the DOE 

18 presentation so we are going into the overview, scope 

19 and coverage. The first thing I want to make sure we 

20 do is cover the regulatory history. 

21 The Energy Policy Act of 1992 amended the 

22 Energy Policy and Conservation Act of 1975 to include 

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packaged terminal air conditions and packaged 

terminal heat pumps as a covered equipment type and 

established the first energy conservation standards 

for PTACs and PTHPs. 

On October 7, 2008 DOE published a final 

Page 21 

rule amending existing standards for PTACs and PTHPs 

hereafter named the -- we are going to call that the 

2008 final rule. On February 22, 2013 DOE initiated 

the rulemaking cycle by publishing a framework 

document and holding a public meeting on March 18, 

2013. 

On October 9, 2013 ASHRAE Standard 90.1 

2013 amended Standard 90.1 requirements for PTACs and 

triggered a DOE review. On March 13, 2014 DOE 

published a Notice of Proposed Rulemaking regarding 

test procedures for PTACs and PTHPs and on April 11, 

2014 DOE published a Notice of Data Availability in 

response to the Amended Standard 90.1 requirements 

for PTACs. 

I'm not going to read all of this but this 

next slide represents the current standards as they 

stand. The next slide is the PTACs and PTHPs energy 

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conservation standards rulemaking schedule. As you 

2 see we are projecting to have a final rule finished 

3 by the end of next year so that's our goal. 

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4 Yep, was there a question? Oh I'm sorry. 

5 MR. HUNT: Marshall, Marshall Hunt PGE. 

6 There's also the method of test in process so how do 

7 these two proceedings interact? 

8 MS. ARMSTRONG: There is a method of 

9 tests. Most of the changes in the method of tests 

10 at least that are proposed today are fairly 

11 clarification in nature and shouldn't change the 

12 values as you see them today or at least that's what 

13 we heard. The test procedure will be finalized well 

14 in advance of this standard's proceeding. We have 

15 already put out the NOPR, the comment period ended, 

16 the comments will come in so we are working on the 

17 final rule now so I would expect you to see that 

18 sometime early next year. 

19 MR. HUNT: All right, fair enough. Thank 

20 you. 

21 MS. PETRILLO-GROH: Laura Petrillo-Groh 

22 AHRI. Ron would you explain how this works with 

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90.1 2013 implementation? I believe that is January 

2 1, 2015 the new standards for PTACs are effective but 

3 I'm not entirely sure how it works with the rest of 

4 the adoption of the standard thanks. 

5 MS. ARMSTRONG: So the way this works is 

6 that DOE once ASHRAE 90.1 comes out the new version 

7 DOE is triggered to review and obviously we are 

8 triggered to review and adopt unless we can prove 

9 that there are significant energy savings at levels 

10 at or above ASHRAE in which case we go to a typical, 

II what we would call a 7 Factor Rule and that's what we 

12 are in now so it's a different timeframe. 

13 So if we end up not adopting something 

14 more stringent than the standards at 90.1 you will 

15 see the Associated Final Rule dates and the 

16 compliance dates associated with that rule they will 

17 be different so they trump basically so it's all 

18 dependent on the outcome, this is what happened when 

19 we did the last rule. We ended up going more 

20 stringent than the ASHRAE 90.1 at that time so that's 

21 how it works. 

22 MR. ROSENSTOCK: So Steve Rosenstock, 

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Edison Electric Institute. A quick question -- the 

2 last rule was published in October of 2008 and the 

3 effective date was September, 2012. On this calendar 

4 you are looking at I will say September, 2015 and an 

5 effective date of 2019, the time period has shrunk 

6 and I'm just wondering why you are giving less time 

7 to the manufacturers to comply compared to the last 

8 time? 

9 MS. ARMSTRONG: So the compliance, I think 

10 the lead time in the subject is four years, so it's 

11 all going to be dependent upon when we issue the 

12 Final Rule. 

13 It's going to move. It's a compliance date projected 

14 based on what's on that screen. 

15 MR. CYMBALSKY: Yeah look at projected, 

16 not required so. 

17 MS. ARMSTRONG: It should just say 

18 September. 

19 MR. CYMBALSKY: Right, so the statutory 

20 deadline is in 2016 so if it comes out in 2016 it 

21 will be 2020 but we are projecting 2015, plus 4 is 

22 2019. 

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MS. ARMSTRONG: It's the month's right 

that are off. It's just going to be a four year 

difference, whatever 

MR. ROSENSTOCK: Steve Rosenstock, EEl 

it's just not showing four years on that one. 

MS. ARMSTRONG: Correct. 

MR. BROOKMAN: Laura, do you have an 

additional comment? 

MS. PETRILLO-GROH: So assuming that --

just in case this Final Rule does decide to go with 

ASHRAE 90.1 2013 although I'm not sure that will be 

the way it's going would then that date still by 

January 2, 2017? 

Page 25 

MS. BUTLER: Sarah Butler DOE, it's a two 

year time period if we go with the 90.1 so that would 

be 2017, projected. 

MR. BRUNDAGE: I guess I have sort of a 

philosophical problem with the way you are 

approaching this because you reject the ASHRAE levels 

and then all of your paperwork is based on the last 

rulemaking and was cost effective beyond that it 

would seem like if you are saying that ASHRAE didn't 

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Page 26 

set the levels high enough you would also be looking 

2 at cost effectiveness from the proposed ASHRAE level 

3 you said was not -- was not high enough. 

4 And that's a tougher test than it would be 

5 for going back to the old baseline. 

6 MR. CYMBALSKY: So, John Cymbalsky DOE, so 

7 we are statutorily required to pick up ASHRAE. So 

8 using yeah, the baseline ASHRAE we have to do. 

9 MS. ARMSTRONG: The ASHRAE is the 

10 baseline. 

I I MR. CYMBALSKY: Is the baseline so the 

12 tougher test is going above that that is what this 

13 rule is. 

14 MR. BRUNDAGE: So your baseline in this 

15 rulemaking is ASHRAE 2013? 

16 MS. ARMSTRONG: Correct. So we did it 

17 as you would suggest. 

18 MR. CYMBALSKY: So I don't mean to put you 

19 on the spot, just so that I heard you right. You 

20 think that's the correct method of doing the 

21 analysis? 

22 MR. BRUNDAGE: That's the correct method 

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of doing the analysis to start from ASHRAE 2013. 

2 MR. CYMBALSKY: Thank you so much. 

3 MR. ROY: Aniruddh Roy, Goodman. So --

4 and during the course of your analysis was a 

5 comparison made between the effective date of 2017 

Page 27 

6 versus 2019, let's say if you were to adopt 90.1 2013 

7 and the energy savings that would be achieved to an 

8 accelerated timeframe versus the implementation date 

9 of 2019 and the energy savings you would realize with 

10 the effective date with the products having to comply 

II with the standards then, were those two comparisons 

12 done in this rule? 

13 MS. ARMSTRONG: So I don't know off the 

14 top of my head but I'll go look. I mean I see your 

IS point about what's the difference in additional 

16 energy savings between TSL2 over the 30 years versus 

17 the 2 years you would get from early compliance of 

18 the ASHRAE level. 

19 MR. ROY: Right, the reason I ask is 

20 because ASHRAE 

21 MS. ARMSTRONG: I think we did calculate 

22 the numbers, I'm not sure it's presented on the 

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presentation but we could show you where that is, 

MR. ROY: The reason I ask is because is 

3 ASHRAE 90.1 statutorily that was made the baseline, 

4 the 2013 standard but the design options that were 

5 evaluated I don't think in the analysis it captured 

6 the design changes that manufacturers made in the 

Page 28 

7 product to go beyond the current federal minimum and 

8 achieve the 90.1 2013 standard which is 1.8% more 

9 stringent for the PTACs side. 

10 As an example, you use rotary compressors 

11 as a technology that's promising but from my 

12 knowledge everyone in the industry is using the low 

13 grade compressors. And just to give you another 

14 example of past rulemakings for the ice makers and 

15 the commercial refrigeration, there was a point made 

16 in those rulemakings of compressors where you would 

17 achieve a certain amount -- you would predict an 

18 efficiency savings of a certain percentage over a 

19 certain period of time for compressors. 

20 That was not mentioned in the screening analysis 

21 here. 

22 So that's the reason I ask, is that you 

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Page 29 

know if that comparison was made and we can get into 

2 the details later once we explore those technology 

3 options. 

4 MS. ARMSTRONG: So to answer your 

5 question, and I don't have it the exact comparison 

6 but I think this provides you with enough information 

7 to get your answer. The cumulative energy savings 

8 for adopting ASHRAE are .001 quads whereas the 

9 cumulative energy savings for adopting TSL2 are .065. 

10 So I mean two years of .001, I mean cumulative 30 

II years is far less than -- I think that gives you your 

12 answer. That's in Chapter 10 of the TSD if you want 

13 to know it specifically, table 10.6.5. 

14 MR. CYMBALSKY: Yeah I have a question, 

15 you mentioned the investment and whatnot to meet the 

16 ASHRAE standard, can you -- does that mean the market 

17 has already moved all the way to that level? 

18 MR. ROY: Well you see ASHRAE 90.1 goes 

19 into effect in 2015 so for new construction which is 

20 about 20% of the buildings, if states adopt it, we 

21 have to be able to make those products available in 

22 the market. 

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MR. CYMBALSKY: I think you made the 

Page 30 

2 statement you have invested a bunch of money to do it 

3 already so I guess I'm asking you know what part of 

4 your shipments or what part of the market is already 

5 at that level, since you've made the investment and 

6 have already started producing them? 

7 MR. ROY: Well I think you mentioned 

8 manufacturers in the process of making that shift 

9 because again it depends on demand and supply. 

10 Obviously we know what changes we need to make in our 

11 design to comply with 90.1-2013 but the real fact is 

12 that 20% of the buildings will have to make sure for 

13 new construction that we have those products 

14 available by 2015 so we have our engineers working on 

15 that to come up with new designs. 

16 But if DOE were to go to these TSL2's and 

17 obviously in other design changes would need to be 

18 made because they are more stringent than the levels 

19 in 90.1 right now. 

20 MS. ARMSTRONG: So can I ask you a 

21 question and this is hopefully the manufacturers in 

22 the room can help. Before we had done our analysis 

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Page 31 

you guys commonly build a single platform or similar 

2 platforms for air-conditioners and heat pumps, is 

3 that accurate to say? 

4 In other words you build them over on 

5 similar designs and you do minor modifications 

6 because the platforms are generally the same, is that 

7 accurate for AC's and heat pumps? Okay, you are 

8 saying yes. 

9 And so right now the ASHRAE 90.1 levels, 

10 you are basically just bringing up air-conditioners 

II to heat pumps, so I'm actually wondering what level 

12 of redesign will that really take because the heat 

13 pump standards are unchanged. They are at the 

14 federal minimums in 90.1-2013 and you are bringing up 

15 AC's and if they are both on a common platform 

16 wouldn't those platforms already have them designed? 

17 MS. PETRILLO-GROH: Laura Petrillo-Groh 

18 AHRI. They are clearly not the same platforms. If 

19 there was a reason to increase the -- or have had the 

20 PTAC level lower than the PTHP lower for ASHRAE there 

21 were reasons involved, and persuasive reasons 

22 involved because ASHRAE 90.1 is a standard, it has a 

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Page 32 

consensus body that approves and writes the standard 

2 so it's not just the manufacturers involved with 

3 that. There are advocates there are users of the 

4 standard involved with it so there was a persuasive 

5 reason to have had different levels to begin with. 

6 I was not in the room at that time and you know we 

7 would like to follow up with that on our written 

8 comments. 

9 But no, they are different. They are 

10 1.8% different. 

11 MR. ROY: Aniruddh Roy, Goodman. So 

12 actually when you say a platform just to clarify that 

13 is that like different assembly lines? Are you 

14 referring to different 

15 MS. ARMSTRONG: The chassis is what I was 

16 getting at which I think were the same based on -- I 

17 mean I don't have far the expertise as you guys do 

18 on your manufacturing lines and your different 

19 options, but my understanding at least from my 

20 experiences previously was that they are similar 

21 chassis. You can say yes, it's okay. 

22 MR. ROY: I can't comment on that right 

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MR. MAJETTE: Okay are there any more 

Page 33 

3 questions? All right we'll just move on and speed up 

4 a little bit. This slide represents the EPCA Factors 

5 and there are 7 of them that we are directed by 

6 through legislation, they are listed here. All 

7 right, so I want to go over the Scope of Coverage. 

8 DOE is proposing standards for PTACs and 

9 PTHPs defined by EPCA Section 340 as follows. A 

10 packaged terminal air conditioner is a wall sleeve 

II and a separate un-encased combination of heating and 

12 cooling assemblies specified by the builder and 

13 intended for mounting through the wall and includes a 

14 prime source of refrigeration, separable outdoor 

15 louvers, forced ventilation and heating availability 

16 by builder's choice of hot water, steam or 

17 electricity. 

18 A packaged terminal heat pump is a 

19 packaged terminal air conditioner that utilizes 

20 reverse cycle refrigeration as its prime heat source 

21 and should have supplementary heat source available 

22 to builders with the choice of hot water, steam or 

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electric resistance heat. 

Page 34 

2 Okay, this last slide represents where we 

3 are in the NOPR stage. 

4 MR. BROOKMAN: Any comments on the 

5 definitions? They are established they are okay? 

6 Heads nodding yes, okay thank you. 

7 PARTICIPANT: Go talk to your Congressman 

8 if you don't like them. 

9 MR. WESTPHALEN: Hi I'm Detlef Westphalen. 

10 I'm going to be presenting on the Market and 

11 Technology Assessment and the Screening Analysis. 

12 The Market and Technology Assessment includes 

13 determining equipment classes, research on the 

14 market, the manufacturers and shipment trends and 

15 identifying technology options to improve efficiency. 

16 The Screening Analysis takes over from the 

17 Technology Assessment and screens out technologies 

18 that will not be considered in the Engineering 

19 Analysis that occurs later and there are 4 screening 

20 criteria listed here: technological feasibility; 

21 manufacturability, install ability, service ability; 

22 adverse impacts on equipment utility or availability; 

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and health and safety issues. 

2 As you know DOE divides equipment 

Page 35 

3 categories into equipment classes and sets different 

4 standard levels for each of those classes. So, 

5 classes are divided according to the type of energy 

6 used, the capacity of equipment or other performance 

7 related features that effect energy use but also 

8 represent utility features. 

9 DOE is proposing to maintain the existing 

10 equipment class provisions and here I might skip to 

II the next slide first. Ron already showed a table 

12 with some of the classes but there are 3 parameters 

13 that are used to distinguish the different PTAC and 

14 PTHP classes. First of all Type of Equipment - AC 

15 versus heat pump; next Physical Dimensions - there 

16 are standard sizes in which the width is 42 inches 

17 and height is 16 inches and non-standard sizes where 

18 one of those dimensions is less than for a standard 

19 size and also there are different standards, 

20 equations and values depending on the cooling 

21 capacity range and so here are the 12 different 

22 classes that have been established initially by 

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Page 36 

statute which DOE is not proposing to change at this 

2 point. 

3 Going back up to the next slide here, the 

4 last bullet, DOE is not in this rulemaking proposing 

5 any new energy conservation standards for 

6 non-standard size PTACs and PTHPs. As mentioned 

7 non-standard size would have one of the dimensions 

8 less than 16 high or 42 inch wide. The non-standard 

9 equipment category holds a very small part of the 

10 market and the energy savings that would be realized 

11 by amending the standards for these products would be 

12 small. 

13 Moving on to technology options and 

14 screening analysis. DOE identified technology 

15 options that can improve energy efficiency, PTACs and 

16 PTHPs. We already talked about the criteria that 

17 are used in the screening analysis to take some of 

18 these technology options off the table and then DOE 

19 also eliminates some of technology options where for 

20 one reason or another there would not be any savings 

21 according to the existing test procedure. For 

22 instance available data suggests there are negligible 

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efficiency benefits. 

Page 37 

There is not any data available 

2 to evaluate the efficiency characteristics for the 

3 test procedure the EER or COP that is used for 

4 evaluating PTAC efficiency does not measure the 

5 benefit of the technology. 

6 So the table on this slide we show -- we 

7 deal with the Technology Options and the Screening 

8 all at once. All of those technology options were 

9 identified. A lot of them were screened out and we 

10 are left with the 4 at the top, higher efficiency 

II compressors, higher efficiency fan motors, increased 

12 heat exchange area and improved air flow and fan 

13 design. 

14 And I don't want to get into what Decker 

15 is going to be talking about, you know the 

16 Engineering Analysis too much but the analysis was 

17 conducted on an efficiency level based approach 

18 looking at different products and either based on 

19 rating or testing basically saying okay that's the 

20 efficiency of that particular design and some of the 

21 products evaluated had different compressors with 

22 different efficiency levels. These are all existing 

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The analysis did not consider any 

2 future efficiency levels of compressors. 

3 Likewise some of the models had higher 

Page 38 

4 efficiency fan motors than others. In the analysis 

5 there is no consideration of any future fan motor 

6 efficiency, likewise for the other design options. 

7 MR. BROOKMAN: Laura? 

8 MS. PETRILLO-GROB: Detlef, I think you 

9 might be getting into this later in the presentation 

10 but just one, two questions I have. Will you please 

11 go over some of the information you have on the 

12 compressors that were evaluated, as Aniruddh 

13 mentioned earlier, -- these compressors are being 

14 used across the board. 

15 Also, we are also interested in what your 

16 analysis showed in terms of implementing improved air 

17 flow design and fan design along with the heat 

18 exchanger area. Some of us have looked at that and 

19 have wondered if those two technology actions 

20 actually fight each other, but we would really be 

21 interested to see what your analysis showed on those 

22 two items. 

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MR. WESTPHALEN: Well I'll say from the 

Page 39 

2 get-go that you know we didn't do focused analysis on 

3 design options such as improved air flow pattern. 

4 We did an efficiency level based analysis. Our 

5 conclusion regarding these design options were based 

6 on looking at the products and saying okay well 

7 there's a design difference here, there are 

8 dimensional differences. It's likely that there are 

9 some improvements in air flow and fan design that is 

10 contributing to the better efficiency of this 

II particular product and we didn't necessarily drill 

12 down into the level of okay how much of the 

13 efficiency benefit is associated with this improved 

14 air flow and fan design versus the compressor versus 

15 the heat exchanger? 

16 I should say a lot of the response to your 

17 questions I think Decker is going to be in a better 

18 position to respond to regarding say the EER's of the 

19 compressors that we found in these products that we 

20 tested. 

21 MS. PETRILLO-GROH: Thanks I'm really 

22 interested in seeing how the analysis went if there 

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weren't quantifiable energy savings associated with 

each of these design options. 

Page 40 

MR. BROOKMAN: Yes, Decker do you want to 

chime in here or do you want to wait? 

MR. RINGO: I think once we discuss the 

efficiency level approach 

MR. BROOKMAN: Decker there's a dead spot 

there, find --

MR. RINGO: Decker Ringo, Navigant 

consultant. 

MR. BROOKMAN: Yeah, thank you. 

MR. RINGO: I think once we talked about 

the efficiency level approach and the creation of the 

cost efficiency curves that we conducted, this might 

become more clear. 

MR. BROOKMAN: Okay thank you, Don 

Brundage? 

MR. BRUNDAGE: Don Brundage, Southern 

Company. I'm a little confused with a few lines she 

gave alternative refrigerants particularly HCFC 32 

with HCFCs being phased out I don't know why they 

would be considered an alternate for the future but I 

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think the big issue with alternate refrigerants is 

2 not opportunities for increasing efficiency is with 

Page 41 

3 restrictions increasingly being proposed over on the 

4 EPA side for the use of standard refrigerants. 

5 The potential degradation of the possible 

6 efficiency from not being able to not having as 

7 much choice of refrigerants as we have now and to add 

8 any consideration of impact of other rulemakings on 

9 what refrigerants you can use. 

10 MR. WESTPHALEN: Well I think you will 

II find that my response is similar to the response in a 

12 whole lot of other DOE rulemakings that you know, 

13 until there is a rule that has been finalized, the 

14 DOE analysis can't be based on consideration of that 

15 rule being finalized. 

16 In some cases if a particular proposal is 

17 put forth, we might consider it an alternative 

18 analysis to consider the direction the particular 

19 other rulemaking might be headed. In this case we 

20 are aware that EPA has proposed that hydrocarbons 

21 could be used in PTACs and we have a request for 

22 comment that addresses that later. I don't know if 

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that's what your question is. 

MR. BRUNDAGE: Well I understand that, 

Page 42 

that it is something that will not be considered as a 

hard and fast thing, it should be considered a threat 

for the future just like the potential impact of 

higher raw materials costs would be. It is even 

that you don't know what it is going to be, it would 

have a negative impact on the future capability of 

efficiency levels. And with the anti-backsliding 

rule it's critical to not set a level so high that 

with a monitored change like that it may not be 

technically possible to meet the standard in the 

future, thank you. 

MR. ROSENSTOCK: Steve Rosenstock, yeah I 

know it's a little early because we are going to talk 

about alternative efficiency but to follow-up with 

what Don said, when I looked at July, 2014 EPA NOPR 

the effective dates start January 1, 2016 and it 

depends on the type of technology, whether you talk 

about new commercial equipment and the retrofit, but 

the range of effective dates was anywhere from 2016 

to 2021 and the later dates were for mobile 

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Page 43 

The earlier dates were for commercial 

2 refrigeration, ice makers, et cetera so I think 

3 that's going to playa very big role possibly in this 

4 rulemaking. 

5 The second thing I wanted to ask about was 

6 the line about high efficiency fan motors, you know 

7 the final rule for small motors goes into effect in 

8 2015 and in ASHRAE 90.1 there were other standards 

9 put in for small motors so basically the baseline is 

10 now for the small motors has gone up and so I'm just 

II kind of curious where the levels considered, were 

12 they the levels now going to be basically cemented 

13 into the new rule in 2015 or where they above those 

14 levels that are going to go into effect in 2015? 

15 Just on the fan motors side? 

16 MR. WESTPHALEN: I can't answer the 

17 question as to what range of motor efficiencies you 

18 know were considered at the different TSL or would 

19 have been required to get to the different TSL 

20 levels. Certainly the highest TSLs would far 

21 surpass the motor regulations requiring permanent 

22 magnet motors. 

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MR. ROSENSTOCK: Okay thank you. 

2 MR. BROOKMAN: Chris do you want to 

3 contribute here? 

4 MR. LAU: Chris Lau, Navigant. Just to 

5 clarify the statement Steve, the HCFC phase out 

6 that's in the proposed EPA rule equipment class is 

Page 44 

7 product specific and as you mentioned it's you know, 

8 ice makers, commercial refrigeration equipment but at 

9 this stage, that proposed rulemaking does not cover 

10 PTACs. Am I correct? I just want to make sure. 

II MR. ROSENSTOCK: Steve Rosenstock, yes for 

12 now. 

13 MR. LAU: Right but there is no proposed 

14 rule at this point that would cover this equipment 

15 but we recognize, we understand the industry's 

16 concerned that since there is a trend but to Detlef's 

17 point, you know it's always been DOE's policy 

18 it's always been DOE's policy that they can't 

19 speculate on future legislation regulation that 

20 doesn't have a definitive plan. 

21 MR. BRUNDAGE: Don Brundage, it's not 

22 speculating on future possibilities when you have got 

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a rule on the books already under the Montreal 

2 protocol that new HCFC equipment is not going to be 

3 shipped out the door of manufacturer's after 2020, 

Page 45 

4 that's been on the books for like 10 years or more so 

5 I don't think it's speculative to say that the 

6 manufacturer is not going to be shipping HCFC 

7 equipment of any type after 2020. 

8 MR. ROY: Aniruddh Roy. Chris you make a 

9 very good point but I think it's safe to say that 

10 this analysis covers 2019 a period of 2019 to 2048 so 

II anytime between that period, I think it's safe to say 

12 that there will be a phase out rule. 

13 MR. LAU: Thank you. 

14 MR. BROOKMAN: Let's make sure that we 

15 address sufficiently issue number 1, issue box number 

16 1 Detlef? 

17 MR. WESTPHALEN: Sure I think that next 

18 page -- this issue for comment asks about alternative 

19 refrigerants. DOE did not consider alternate 

20 refrigerants in the analysis because the DOE is not 

21 aware of any SNAP-approved refrigerants that are 

22 known to have better efficiency than the R410A for 

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this equipment. DOE requests feedback from the 

2 efficacy of alternative refrigerants for PTACs and 

3 PTHPs. 

4 MR. ROY: Aniruddh, I'm going to 

5 reiterate some of the points that Don Brundage 

6 raised. One being that switching into the 

7 alternative refrigerants will affect the energy 

Page 46 

8 performance of products and you know that's something 

9 that needs to be considered in DOE rulemaking. I 

10 understand that DOE's hands are kind of tied on this 

11 issue, but when you do an analysis over a 30 year 

12 time period, it has to be accounted for that there is 

13 going to be change in the refrigerants or a 

14 compromise has to be made in terms of backsliding 

15 efficiency levels because if you cannot predict what 

16 the performance of the unit is going to be -- for 

17 some reason if you switch refrigerant and it 

18 adversely effects equipment performance. 

19 Right now DOE's hands are tied by statute 

20 that they cannot go back on the levels that they have 

21 set so that puts manufacturers in a precarious 

22 position for the future because it's a cumulative 

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Page 47 

regulatory burden. We are required by EPA to follow 

certain steps and then we are required by DOE to 

follow certain steps and so that should be part of 

DOE's cumulative regulatory burden analysis and 

should be factored into the INPV which I am sure you 

know you have already done. 

But you know again, these issues I think 

have been pointed out in previous rulemakings and the 

fact that they are not being acknowledged in current 

rulemakings you know, is not adequate. I think DOE 

needs to give this a serious thought. 

MR. BROOKMAN: Thank you, additional 

comments on alternative refrigerants? Steve 

Rosenstock? 

MR. ROSENSTOCK: Steve Rosenstock yeah 

again I think that that ruling in July, that proposed 

rule was -- there was actually another role in I 

think it was August about flammable refrigerants and 

I think that's just going in another direction as 

well. They are now approved but I was just really 

-- I was kind of surprised in terms of the use 

conditions that are going to be required by EPA in 

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terms of -- and the reason I mentioned that is for 

2 certain as I recall on that rule for certain 

Page 48 

3 flammable refrigerant, and I think they did do things 

4 on PTACs, they are limiting the amount of refrigerant 

5 in those units based on certain use conditions. 

6 As I recall from that rule they have 

7 specific conditions and one of the conditions was you 

8 are only allowed to use a certain amount of 

9 refrigerant in certain size units and I believe as I 

10 recall, I wish I had that rule in front of me that it 

11 was -- I think they were talking about it was either 

12 -- I think it was room air conditioners, it might not 

13 have been PTAC's it was room air conditioners. 

14 But again similar capacity type units just 

IS you know there are these new directions coming out 

16 just to follow up to say hey there are certain things 

17 that will have an impact, that could have an impact 

18 on performance. 

19 MR. WESTPHALEN: Yeah I think the proposal 

20 was for say a 9,000 Btu PTAC could use 140 grams of 

21 propane. 

22 MR. ROSENSTOCK: Something like that yes, 

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I don't remember the exact numbers but I just 

2 remember the capacity sizes were exactly similar to 

3 what we are talking about here in terms of 9,000, 

4 8,000 up to 12 or 15,000 Btu's for hour. 

5 MR. WESTPHALEN: And if we look at the 

6 units that we tore down and considered changes in 

7 heat exchanger sizes or tube diameters to reduce 

Page 49 

8 charge, you know some of those units if we went down 

9 to smaller diameter round tubes could potentially get 

10 you know, if you consider the differences in 

11 densities between HFC's and the HC's. You could 

12 potentially get close to that 140 gram limit but you 

13 know it would be a stretch. 

14 MR. BROOKMAN: Okay, yes Aniruddh? 

15 MR. ROY: I'm Aniruddh, of Goodman. This 

16 question is for Ron Majette so Ron with respect to 

17 back-sliding just a question that came up in my mind. 

18 Let's assume that DOE does go back, slides back to 

19 lower level accounting for a refrigerant which is 

20 highly unlikely but if that happens would you be able 

21 to do carbon dioxide emissions analysis using 

22 refrigerants? Just based on the GWP? 

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MR. MAJETTE: Unfortunately in a case like 

this we are limited by what EPCA allows so it's going 

to be dependent on that. 

MR. ROY: I was just thinking from the C02 

emissions because that's something you have added you 

know, as a factor that goes into selecting TSL's you 

know, but social costs of carbons so any GWP savings 

that you get from switching refrigerants and 

comparing that to let's say reducing the EER to 

account for the refrigerant switch. I think that 

type of an analysis would be very useful as well to 

do in the future. 

MR. MAJETTE: Okay can you provide that as 

a comment? 

MR. ROY: Yes. 

MR. MAJETTE: Because it looks like 

there's something you gave us another dynamic to 

research so let's look into that. 

MR. ROY: Yes, right. Because that might 

help you know, again it's contingent upon if you 

reduce the EER but that might help in providing those 

arguments as to why even the reduction of EER overall 

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October 29,2014 

you know, still saves the nation energy. 

MR. BROOKMAN: Final comments on 

3 refrigerants because we are about to move on, okay. 

4 I think at this point we move on to the Engineering 

5 Analysis and I will hand it over to Decker. 

6 MR. RINGO: Good morning, Decker Ringo 

7 from Navigant Consulting. I'm going to discuss the 

8 engineering analysis methodology and the results. 

Page 51 

9 The purpose of the engineering analysis is to examine 

10 the relationship between manufacturing production 

11 costs and efficiency levels for the PTAC and PTHP 

12 equipment. 

13 The engineering analysis uses as input a 

14 market and technology assessment and the screening 

15 analysis results and the output of the engineering 

16 analysis is a set of cost efficiency relationships 

17 for different equipment classes and capacities and 

18 those cost efficiency relationships serve as the 

19 basis for the remainder of DOE's downstream analyses. 

20 So I'm going to discuss now how we derive 

21 these cost efficiency relationships. There are 

22 different approaches that one can take to assess the 

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Page 52 

relationship between cost and efficiency. We alluded 

2 to a design option approach where for each design 

3 option you calculate or estimate the amount of 

4 efficiency that will gain you in a particular 

5 machine. That is not the approach that we used in 

6 this rulemaking. We've seen it in other rulemakings 

7 such as ice makers but in this rulemaking, we use the 

8 combination of an efficiency level approach and a 

9 reverse engineering approach. 

10 And what that means is that we selected 

II certain representative equipment classes and 

12 capacities to represent the entire PTAC and PTHP 

13 market. We developed a set of efficiency levels 

14 ranging from the baseline efficiency up to the 

15 maximum feasible technology. We chose units from 

16 the market that span that range of efficiency levels 

17 and then we tested and tore down those units to 

18 estimate the manufacturing production costs 

19 associated with producing those individual units. 

W I'm going to walk through each step of 

21 this analysis now. 

22 MR. PETRILLO-GROH: Laura Petrillo-Groh, 

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Decker, would you explain why this approach 

2 was taken as opposed to the design option approach? 

3 MR. RINGO: Certainly. Decker Ringo, 

4 Navigant. In the collection of units that we tore 

5 down we observed that manufacturers took different 

Page 53 

6 steps to reach different efficiency levels and we do 

7 not want to pre-judge how manufacturers -- what 

8 approach they will take to reach a given efficiency 

9 level but we do want to estimate the cost associated 

10 with different efficiency levels. 

11 They may reach it by using more efficient 

12 fan motors or compressors or what have you, better 

13 insulation, whatever. What we are trying to 

14 develop is a set of cost efficiency curves that can 

15 allow the downstream analysis to estimate the 

16 national impacts and the employer manufacturer 

17 impacts. 

18 MS. PETRILLO-GROH: Since I'm not as 

19 familiar with this approach as the design option 

20 approach I want to make sure I fully understand. So 

21 in reviewing specific models the DOE observed 

22 technology options that were implemented and used the 

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Page 54 

cost of that unit against the efficiency of that unit 

2 to generate the cost efficiency curves? 

3 MR. RINGO: That's correct. As you will 

4 see in the coming slides we selected a range of units 

5 so we have low efficiency and high efficiency units 

6 and those in between and we estimated the 

7 manufacturing production cost of each of those units 

8 across that range. 

9 And then that enabled us to create a cost 

10 efficiency curve to fit the equation to those points 

II and then at each efficiency level we essentially took 

12 a slice out of that equation to say to reach this 

13 efficiency we estimated we would have to incur this 

14 specific incremental cost. 

15 MR. ROY: Aniruddh Roy, Goodman. So I 

16 guess for the other efficiencies did you use a factor 

17 to kind of you know, predict the levels for those 

18 efficiencies? 

19 MR. RINGO: I want to make sure I 

20 understand your question. Are you talking about 

21 within the range? 

22 MR. ROY: Within the range right, so for a 

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12,000 -- let's say they are 12,000 capacity --

MR. RINGO: Right. 

Page 55 

3 MR. ROY: And you use the predictive tool 

4 to--

5 MR. RINGO: We used the representative 

6 cooling capacities of 9,000 - 15,000 Btu's per hour. 

7 It enabled us to create a weighted average to 

8 represent the entire PTAC and PTHP market which would 

9 include shipments of the 12,000 Btu. 

10 MR. ROY: Okay the reason I ask this 

II question is that I think you guys did a great job on 

12 the 9,000 and 15,000 as the AHRI showed the data in 

13 those ranges. I think some of the products are able 

14 to meet TSL2 but I think somewhere along the way the 

15 predictive analysis for the other ranges might need 

16 to be re-evaluated because there are several products 

17 that just don't even meet TSL2, based on the AHRI 

18 data. 

19 MR. RINGO: Thank you, that's a comment we 

20 will take into consideration. Okay, I'm going to 

21 walk through the individual steps of this analysis 

22 and provide the details of what we did to arrive at 

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the cost of the efficiency relationship. 

Page 56 

2 In the market for PTAC and PTHP equipment, 

3 there are variations in the cooling capacities and 

4 the efficiencies, there is different equipment 

5 available and to account for these variations in our 

6 analysis we selected representative cooling 

7 capacities to represent the PTAC and PTHP market. 

8 As a first step we examined the AHRI 

9 directory of certified product performance. Laura 

10 presented the histogram representing the different 

II models that are contained in that directory earlier. 

12 We observed that the largest number of models listed 

13 in the directory, are clustered around the 9,000 Btu 

14 per hour capacity so we selected that to represent a 

15 wide swath of the market. 

16 Additionally our interviews with 

17 manufacturers, several manufacturers indicated that 

18 the bulk of their shipments are in the 9,000 Btu per 

19 hour capacity. Also in manufacturer interviews, 

20 manufacturers asked that we examine the 15,000 Btu 

21 per hour capacity because this capacity poses the 

22 greatest technical hurdles in terms of increasing 

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Those are the two representative 

cooling capacities that we considered for this 

analysis. 

The next step in the analysis was to 

develop a set of efficiency levels ranging from the 

baseline efficiency up to the maximum tech level. 

As we have discussed earlier today the ASHRAE 

standard 90.1 was issued in the course of this 

rulemaking and it raised its minimum standard for 

PTACs to 1.8% above the current federal minimum 

standard for PTACs. 

At a minimum, DOE is obligated to adopt 

this revised ASHRAE 90.1 standard or it may adopt a 

more stringent standard. But because of that we 

selected the ASHRAE 90.1 standard as the baseline 

efficiency level for this analysis. 

Page 57 

At the other end of the spectrum, the max 

tech efficiency level represents the most efficient 

model or models that we observed in the market. Now 

in the framework documents for this rulemaking, DOE 

said it would consider using a max tech level equal 

to 20% above the current federal minimum PTAC 

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standard. After acquiring equipment rated at that 

2 level, DOE has revised the max tech level to 18% 

3 above the current federal minimum standard. 

4 So that's the baseline and the maximum 

5 tech level. In between those bounds, DOE selected 

6 efficiency levels in increments of 4%. As you can 

Page 58 

7 see here on slide 27, we selected 6 efficiency levels 

8 at 1.8%, 4%, 8%, 12%, 16% and 18% above the current 

9 federal standards for PTACs. 

10 The table on the following slide presents 

11 these efficiency levels and their corresponding 

12 values. This table is quite dense so I will call 

13 your attention to several points about it. 

14 MS. PETRILLO-GROH: In this sort of 

15 analysis is max tech the same as max available? 

16 MR. RINGO: Can I defer that question? 

17 MS. BUTLER: Sarah Butler, DOE. Max tech 

18 is a statutory requirement under EPCA that we have to 

19 evaluate. I'm not sure what you mean by max 

20 available? 

21 MS. PETRILLO-GROH: This is I think one of 

22 the questions I had regarding the differences between 

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this approach and the design option approach where 

Page 59 

2 the design option approach you can I don't know, put 

3 together a Frankenstein machine implementing all of 

4 the design options and get to an efficiency level 

5 which would be the max available. However, if you 

6 are looking at implementing design options based on 

7 models currently in the marketplace, it would seem 

8 that the max available would be the same as the max 

9 tech. 

10 MR. RINGO: Decker Ringo from Navigant. 

11 The max tech level proposed here is a level that we 

12 observed tested in the piece of equipment. 

13 MR. BROOKMAN: It's in the market. 

14 MR. RINGO: It's in the market. 

15 MS. PETRILLO-GROH: Both PTACs and PTHPs? 

16 MR. RINGO: I believe so yes. 

17 MR. BROOKMAN: Thank you, so now we are to 

18 this large table this one -- Aniruddh? 

19 MR. ROY: Aniruddh Roy, Goodman. So 

20 Decker the TSL2, does that coincide with EL2 or is it 

21 a mix of EL2 and other ELs? 

22 MR. RINGO: The TSL2 corresponds with EL3 

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for PTACs and EL2 for PTHPs. 

Page 60 

2 MR. ROY: Okay. So basically it's an 8% 

3 increase over the 2012? 

4 MR. RINGO: That's correct. 

5 MR. ROY: Okay, thank you. 

6 MR. RINGO: I want to draw your attention 

7 to several points in this table. The presents the 

8 efficiency levels that I just discussed for the PTAC 

9 and PTHP equipment. These efficiency levels are 

10 calculated based on an equation that is based on the 

11 cooling capacity of the equipment. 

12 For both PTACs and PTHPs the cooling 

13 efficiency is calculated as the energy efficiency 

14 ratio EER, expressed in Btu's per watt hour and for 

15 PTHPs the heating efficiency is calculated as the 

16 coefficient of performance, COP which is unit-less. 

17 On this table we have calculated the efficiency 

18 levels for the representative cooling capacities of 

19 9,000 and 15,000 Btu's per hour. 

20 The current federal minimum standard for 

21 PTHPs is higher than the current minimum standard for 

22 PTACs and where this table refers to percentages, 4 Sl-0, 

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8% and so forth, those are percentages relative to 

2 the current federal standard for PTACs. 

3 Because the current standards for PTACs 

4 and PTHPs, oh sorry, one point first. As we noted 

5 on the previous slide the baseline level for both 

6 PTACs and PTHPs is equivalent to 1.8% above the 

Page 61 

7 current federal standard that is equal to the ASHRAE 

8 90.1-2013. Now because PTAC and PTHP minimum 

9 standards are not equal, the efficiency level 

10 numbering in this table does not line up and I 

11 apologize for that. 

12 But I want to draw your attention the 

13 efficiency level 2 for PTACs is the same as 

14 efficiency level 1 for PTHPs. Efficiency level 3 

15 for PTACs is the same as efficiency level 2 for PTHPs 

16 and so forth. I wanted to get that out so that it 

17 does not cause any confusion. The trial standard 

18 levels that Bingyi will present will clarify that 

19 further. Are there any questions on this table 

20 before we move on? 

21 MR. BROOKMAN: Just a lot of data here, 

22 give them one moment to take a peek, Marshall? 

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MR, HUNT: This is Marshall Hunt, PGE. 

2 So I look at the equations and that doesn't compute 

Page 62 

3 for me so let's look at the equation EL3 for PTAC 4.9 

4 minus that EL2 oh I see they are lined up, okay I 

5 MR. BROOKMAN: I tried that first also but 

6 they are lined up, yes. They are vertical, the 

7 correspondence is vertical, yeah Laura? 

8 MS. PETRILLO-GROH: I do have a quick 

9 question about -- so you mentioned the 4% and 8% was 

10 an increase over the current PTAC federal minimums? 

11 MR. RINGO: That's correct. 

12 MS. PETRILLO-GROH: For PTHPs is it the 

13 same? 

14 MR. RINGO: No, all of the percentages in 

15 this table are referred to the PTACs standard and so 

16 currently the federal minimum standard for PTHPs is 

17 1.8% above the federal standard for PTACs and that's 

18 the baseline level which is why you see the NA -

19 non-applicable under the current federal PTAC 

20 standard column. 

21 MS. PETRILLO-GROH: Why was the percent 

22 savings for PTHPs not compared to the current level? 

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I'm just curious why it is all compared back to 

2 PTACs when the PTHPs really won't be seeing that 

3 significant of any energy efficiency increase 

4 compared to the current baseline? 

5 MR. RINGO: That's an excellent question 

6 and that's why I wanted to clarify what these 

7 percentage levels mean so that there isn't any 

8 confusion. 

9 MR. ROSENSTOCK: Steve Rosenstock EEl. 

10 probably should draw these but I'm just kind of 

II curious so I'm just looking at the heat pumps and 

12 again I'm just looking at EL3, EL2 just that one 

13 line. When you are saying 8% is that the increase 

14 in the EER and the COP or is that just the EER and 

15 there's a different percentage for the COP? 

Page 63 

I 

16 MR. RINGO: That's just the EER. The COP 

17 was calculated using a regression based on models 

18 observed in AHRI directory as certified product 

19 performance. 

20 MR. ROSENSTOCK: Thanks and Steve 

21 Rosenstock, I didn't do it on my calculator yet but 

22 what is the percentage increase on the COP side? I 

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should have done it on my calculator but I didn't 

2 have time yet. 

3 MR. RINGO: I should have done it on my 

4 calculator too, I don't know that off the top of my 

5 head. 

Page 64 

6 MR. ROSENSTOCK: I'll figure it out thank 

7 you. 

8 MR. BROOKMAN: Okay, so additional 

9 comments or questions on this table with the 

10 efficiency levels for PTACs and PTHPs? Nothing 

11 addi tional? 

12 MR. RINGO: Thank you. Now that we have 

13 developed the efficiency levels that will be 

14 considered in this analysis, the next step in the 

15 analysis is to select representative units from the 

16 market that will be used in the testing and tear down 

17 portion of the analysis. 

18 This slide 29, presents the 5 criteria 

19 that DOE used in selecting units for testing and tear 

20 down -- first DOE selected equipment that would cover 

21 the entire range from the baseline efficiency level 

22 up to the max tech efficiency level. The selected 

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equipment was picked around the cooling capacities 

Page 65 

2 that I described earlier, 9,000 and -15,000 Btu's per 

3 hour, DOE tried to select equipment that was 

4 similar in nature from similar equipment lines from 

5 the same manufacturer so that we could observe 

6 differences between the lower and higher capacity 

7 equipment. 

8 We selected equipment from manufacturers 

9 who have a large share of the market so it would be 

10 representative of the industry and the selected 

II equipment we picked units without any additional 

12 features or add-ons that would add cost without 

13 affecting equipment efficiency. 

14 The next slide 30, presents a chart 

15 showing the capacity, cooling capacity and Btu's per 

16 hour on the X axis versus the cooling efficiency EER 

17 on the Y axis. This chart has markers representing 

18 the 20 units that were selected for testing and 

19 teardown analysis. The colored lines on the chart 

20 indicate the current federal minimum standard for 

21 PTACs and then the 6 efficiency levels above that. 

22 What you can see looking at the chart is 

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October 29, 2014 

that the selected units, as I mentioned, are around 

the representative cooling capacities of 9,000 and 

15,000 Btu's per hour and they span the range from 

the baseline up to the max tech. 

Page 66 

I should note that these markers represent 

the rated efficiency of the units after DOE acquired 

these units and tests were done to verify the heating 

efficiency and cooling efficiency. 

MR. BROOKMAN: Joanna Moyer who is joining 

us via the web has a question or a comment. Joanna I 

need your phone, let's see if we can hear you. 

MS. MAUER: Thanks, this is Joanna Mauer 

from ASCEP I just wanted to quickly note that I also 

took a look at the efficiency levels of models that 

are available today and there are models available 

across the range of capacity levels with efficiency 

levels that significantly exceed the proposed 

standard levels, including capacity around 7,000 and 

12,000 Btu's per hour in addition to models around 

9,000 and 15,000 Btu's per hour thank you. 

MR. BROOKMAN: Thank you. Yes please 

Laura? 

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Page 67 

MS. PETRILLO-GROH: I just wanted to point 

2 out that in the slide the highest efficiency PTAC you 

3 see is it 16% and that's in the 9,000 Btu per hour 

4 category but in the you know 15,000 Btu per hour 

5 category the highest efficiency is less than 12% so 

6 it's not entirely clear to me how the max tech works 

7 for the PTAC units given this data. 

8 MR. WESTPHALEN: I know Decker would want 

9 to talk about all of this a little bit more rather 

10 than letting me talk about it but many of or I should 

11 say at least one and I don't know how many of the 

12 PTACs that we ordered were actually PTHPs. Also it 

13 is our understanding that it is easier to attain a 

14 certain efficiency level with a PTAC than a PTHP 

15 because of the additional losses associated with the 

16 reversing valve and also the reduced flexibility you 

17 have when you have to deal with both the reverse 

18 cycle and forward cycle in designing the heat 

19 exchange. 

20 MR. HUNT: Marshall Hunt, PGE. Just a 

21 clarification, Decker you said that the chart is for 

22 the rated efficiencies? 

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MR, RINGO: That's correct, 

Page 68 

2 MR, HUNT: And you did test them, how did 

3 the rated efficiency compare to your test efficiency? 

4 MR, RINGO: I encourage you to look at the 

5 technical support document for the NOPR it includes 

6 the testing result data, As a summary they also 

7 spanned much of the range of the efficiency levels we 

8 considered, 

9 MR. HUNT: Thank you. 

10 MR. ROSENSTOCK: Steve Rosenstock EEl. 

II Now again please forgive me I didn't -- I haven't 

12 read the technical support document yet but I see the 

13 things kind of the curves they just flat line above 

14 15,000 and then below 7,000 and I'm just kind of 

15 curious was that based on your test or is that just 

16 figured that that would be -- or is that based on the 

17 AHRI directory or I'm just kind of curious you 

18 have this linear fit for all these other sizes then 

19 it is literally stopped at 15 and it literally stops 

20 at 7 I'm just kind of curious. 

21 MR. RINGO: That's a good question and 

22 that's based on the current federal standards and 

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Page 69 

the ASHRAE 90.1 standards. I use those equations we 

discussed in the efficiency level table between 7,000 

and 15,000 Btu's per hour and above 15,000 and below 

7,000 there is a set value. 

MR. ROSENSTOCK: Thank you. 

MS. WILLIAMS: Yoo1anda William, GE 

Appliances. Just a question, I know you have 

referenced the technical support document for 

additional information on the test of the values, the 

question is within your presentation do you have a 

similar chart than the one you have up now with the 

tested bodies laid on top of the levels? 

MR. RINGO: I do not. 

MR. BROOKMAN: Additional comments before 

we move on? 

MR. RINGO: Okay thank you. The final 

step in the analysis is to test and disassemble the 

units to estimate the manufacturing production cost 

for the individual units and then create the cost 

efficiency relationship curves. DOE disassembled 

each of the units, purchased as indicated on the 

previous slide and created detailed bills of 

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These bills of materials account for 

Page 70 

2 every single component part in that unit and estimate 

3 the cost associated with either fabricating or 

4 purchasing each part. 

5 The purpose of the bills of materials is 

6 to estimate the materials, labor, capital and 

7 overhead costs associated with fabricating and 

8 assembling the piece of equipment. More details 

9 about the teardown and cost estimation methodology 

10 can be found in chapter 5 of the technical support 

II document. 

12 I will note that during the teardown and 

13 cost estimate analysis, DOE observed that typical 

14 PTHP model has a manufacturing production cost of 

15 roughly $37.00 more than an otherwise identical PTAC 

16 model associated with the reversing value and the 

17 additional labor and assembly required. We observed 

18 that additional cost for PTHPs does not vary by 

19 efficiency level. 

20 MS. WILLIAMS: Yoolanda Williams, GE 

21 Appliances. Could you review the testing process 

22 that you used on these units that were selected in 

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Page 71 

terms of you know number of samples, were they tested 

2 right out of the box, were you using the proposed 

3 test procedures? 

4 MR. RINGO: Yes, these tests were 

5 conducted by a third party contractor using federal 

6 test procedures for PTAC and PTHP equipment and the 

7 testing values provided in the technical support 

8 document only for the single pieces of equipment 

9 between equipment units that were purchased for this 

10 analysis. 

11 MS. WILLIAMS: Okay. And again we're 

12 sorry I'm sorry were they tested new, out of the 

13 box? 

14 MR. RINGO: They were tested out of the 

15 box, with a break-in period. 

16 MS. WILLIAMS: Okay no break-in period. 

17 MR. RINGO: I believe there was a break-in 

18 period. 

19 MS. WILLIAMS: Okay. 

20 MR. BROOKMAN: Is there supposed to be a 

21 break-in period? 

22 MR. RINGO: Yes, yes there is. 

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MR. ROY: Aniruddh Roy, Goodman. So 

Page 72 

2 there is a NOPR test procedure out there and so that 

3 has not been finalized and there are I know Ashley 

4 Armstrong mentioned that you know it's very minor 

5 changes that will not affect the overall efficiency 

6 level in any way but there is I think, there was a 

7 consideration of moving from ASHRAE 37 to ASHRAE 16 

8 which would impact the testing in a major way. In 

9 between using I guess calorimetric rooms or 

10 psychrometric rooms so was that evaluated in any way 

11 in the course of testing the 9, 000 and 15, 000 Btu 

12 capacities? 

13 MR. WESTPHALEN: The tests were done using 

14 the ASHRAE 16 approach. I believe the Goodman 

15 comments on the test procedure NOPR indicated that 

16 there was not a significant difference in the results 

17 between ASHRAE 16 and ASHRAE 37 and as Ashley said 

18 that rulemaking is still in process and not finalized 

19 so DOE hasn't make final decisions on what direction 

20 to take. 

21 MR. ROY: Okay so you are saying that it 

22 was tested per the NOPR? Because ASHRAE 16 was 

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recommended in the NOPR right? 

MR. WESTPHALEN: That is correct, ASHRAE 

3 16 was used and that was proposed in the NOPR. 

4 MS. PETRILLO-GROH: To further clarify 

5 ASHRAE 16 and I honestly don't remember, the two 

Page 73 

6 tests that are currently allowed to be used on these 

7 products, I believe the recommendation to move to 

8 ASHRAE 16 was based on ASHRAE 16 adopting both of 

9 those methods, is that correct? 

10 MR. WESTPHALEN: Detlef Westphalen. I 

II think you probably have to go to the NOPR to read 

12 what the justifications were for proposing moving to 

13 16 but if I recall correctly it was based on DOE, 

14 third party funded testing. DOE funded testing at 

15 third party labs which showed there was a significant 

16 difference and so that was somewhat more limited test 

17 data that then was later provided by some of the 

18 manufacturers as part of commentary and so DOE is 

19 taking all of that into consideration. 

20 MR. BROOKMAN: Okay. 

21 MR. RINGO: Thank you. I want to -- so 

22 as I mentioned earlier the results of this estimate 

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of manufacturing production costs for individual 

2 units were compiled into cost efficiency curves for 

3 the different cooling capacities and the equipment 

4 types. You can see a visualization of those cost 

5 efficiency curves on slide 32 here. In the 

6 shipments analysis which we will present later, DOE 

Page 74 

7 combined these representative curves based on market 

8 share to create a weighted average curve that 

9 represents the cost efficiency for the PTAC and PTHP 

10 market. 

11 That combination is illustrated here. I 

12 want to talk about some results from the cost 

13 efficiency analysis here, slide 33 presents the 

14 results for the 9,000 Btu's per hour capacity. I 

15 want to note that the costs in this table are 

16 incremental costs associated with efficiency 

17 increases above the baseline efficiency level. The 

18 first step from 1.8% above federal PTAC standards to 

19 4% above incurs incremental costs of $3.88 and those 

20 incremental costs increase up to the max tech level 

21 which by our estimates would cost about $35.94 more 

22 to manufacture when compared to baseline. 

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Page 75 

These cost efficiency results are charted 

2 in the plot on the right with efficiency on the X 

3 axis versus incremental cost on the Y axis. 

4 MS. PETRILLO-GROH: Ron this is really for 

5 you. If the charge here is to review increasing 

6 efficiency levels over ASHRAE 90.1-2013 levels, I'm 

7 just curious why it's still being compared back to 

8 the baseline of today's standards for PTACs? 

9 It seems contradictory to the purpose or the stated 

10 purpose of the rule. 

11 MR. RINGO: I'll field that one. The 

12 baseline represented here in the first row of this 

13 table is the ASHRAE 90.1-2013 level. It's not 

14 referring to the current federal minimum PTACs, are 

15 you curious why we are using the percentages? 

16 MS. PETRILLO-GROH: The 1.8% above 2012 

17 PTAC energy conservation standards, that's what's in 

18 effect today. 

19 MR. RINGO: Right and that 1.8% level is 

20 considered as the baseline for this analysis. 

21 MR. BROOKMAN: And that's the ASHRAE, the 

22 current ASHRAE 1.8% above that's what we heard 

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MS. WILLIAMS: The incremental cost at 

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that level there's a bar so everything above it, like 

the $3.88 is being compared to that ASHRAE level. 

The 1.8% maybe just -- so think about it. 

MS. PETRILLLO-GROH: Its 4% increase in 

efficiency over the ASHRAE 90.1-2013 level? 

MS. WILLIAMS: No. 

MR. RINGO: The 4% is relevant relative to 

the current federal PTAC standards but the cost, the 

incremental cost is relative to the first line of 

that table the baseline for this analysis. And I 

included -- because I foresaw this would be an issue 

with communication I included the efficiency level 

and baseline and percentage there on each of these 

tables so that it's consistent and we can be talking 

about the same thing. 

MS. WILLIAMS: So, this is Allison. I 

think what happened really is at the framework stage, 

that's when these percentages were developed and that 

was before ASHRAE came out so they've kept these 

just for consistency with what's in the framework 

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document so I apologize if it's a little confusing 

2 right now, does that help you at all? 

Page 77 

3 MS. PETRILLO-GROH: It is confusing but I 

4 do appreciate the background. My real concern here 

5 is that we are talking about efficiency increases 

6 over the current level which is not what we are 

7 supposed to be looking at in terms of this rulemaking 

8 is additional savings with energy and emissions above 

9 the 90.1 level so is that, you know can we really 

10 call that maybe 3. ---

11 MS. WILLIAMS: I think this is really just 

12 like a nomenclature thing, all the numbers that you 

13 are going to see, the costs, the energy savings, 

14 everything are going to be compared to the ASHRAE 

15 level so it's only those percentages that are off and 

16 you are right, we can certainly adjust those 

17 percentages against the ASHRAE baseline. 

18 MS. PETRILLO-GROH: Would you be able to 

19 publish that before the final or at least revise the 

20 slides? 

21 MS. WILLIAMS: I'm not sure but those 

22 numbers are just nomenclature for reference they are 

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not actually used per the analysis, correct, yeah. 

MS. PETRILLO-GROH: Okay. 

MR. BRUNDAGE: I was just going to make 

the comment we have pretty much already covered it. 

It looks like you are buying 4% greater efficiency 

for $3.88 but you are really buying 2.2% greater 

Page 78 

efficiency for the $3.88 so I agree with Laura it is 

very confusing. 

MR. HUNT: Marshall Hunt, PGE. Where 

would I find the KWH savings per year that would be 

offset by this incremental? 

MS. WILLIAMS: This is Allison, we are 

going to get there once Decker finishes it will be 

several slides later. 

MR. HUNT: Thank you, I'll wait. 

MR. RINGO: Sorry I'm being long-winded 

I'll be done shortly. 

MR. BROOKMAN: Let's move on to 15,000. 

MR. MAJETTE: Ron Majette, DOE just one 

clarification. Laura and Don I guess for 

presentation purposes what do you need to see? 

What's causing you the confusion? 

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Page 79 

MR. BRUNDAGE: Well it's just you have got 

2 two numbers side by side on the table that are off of 

3 different baselines which is confusing so incremental 

4 costs versus baseline would be one thing, incremental 

5 costs versus a different baseline that starts at 1.8% 

6 is -- I mean if you had 2.2% and 6.2% and so forth 

7 for incremental savings above 90.1 I don't know, it's 

8 just somewhat misleading the way the table is 

9 written. 

10 MS. PETRILLO-GROH: And my main concern is 

11 that it is it provides a real opaqueness to the 

12 rulemaking in terms of what is being presented as the 

13 efficiency increase that you are going to see versus 

14 maybe what's buried in several hundred pages of the 

15 technical support document and you know the 

16 additional difficulties it creates in communicating 

17 you know, what the actual effects of this rule are in 

18 terms of energy savings, in terms of cost and 

19 comparison purposes. 

20 Because people reading this see 4% above 

21 -- 4% and it's just not clear, it's just not 

22 consistent, so I think it works it out for me. 

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MR. ROSENSTOCK: Steve Rosenstock, EEl. 

2 I get it's about nomenclature because you know we 

3 are all trying to figure out the TSL's versus the 

Page 80 

4 EL's and there's a baseline and then you show ELI in 

5 a baseline on the same line and it's like wait what's 

6 the baseline for that, that kind of threw me off a 

7 little bit too. But you know until I went to the 

8 Rosettae Stone of TSL's to, EL's and Table V.I in 

9 the NOPR document I was able to figure it out. 

10 But again, looking at the table just gets 

11 confusing just because of the, you know the 

12 nomenclature of EL's versus TSL's and then throwing 

13 in the word baseline also could throw people off, so 

14 it's nomenclature, once you read it like 5 or 7 

15 times, I got it. 

16 MS. WILLIAMS: Thank you, we can try to 

17 make this more clear for the next item that you see 

18 corning at this. 

19 MR. ROY: Aniruddh Roy, Goodman. I guess 

20 I'll take this slide as an opportunity to comment on 

21 the technology options. I know we discussed that 

22 briefly in the screening analysis. So again, I'll 

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make the point on the high efficiency compressors. 

2 As you saw in the commercial refrigeration and 

Page 81 

3 ice-maker rulemakings, DOE approximated a set of high 

4 efficiency compressors using a constant multiplier. 

5 That sort of a multiplier is not evident in the 

6 screening analysis TSD. In the previous 

7 rulemakings, a multiplier assumed a certain 

8 percentage reduction in energy consumption with an 

9 associated cost premium. 

10 I think that's more important in this 

11 rulemaking because you are setting the baseline as 

12 90.1-2013 so there's a 1.8% efficiency gain that as 

13 Don and Laura pointed out, that's just lost in the 

14 scope of this rulemaking because the baseline is 

15 ASHRAE 90.1-2013 and not the current federal 

16 standards which I understand you have to comply with 

17 for the statute. 

18 But I think DOE needs to somehow account 

19 for the options that were used, the technology 

20 options that were used for the industry to get from 

21 the current federal minimum to 90.1-2013 which I 

22 guess compressors would be one of those options. 

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And so it is very important to be able to quantify 

2 the percentage efficiency improvements if you see 

Page 82 

3 that you might observe and compressors leading up to 

4 2019 because that information would be very important 

5 you know, to go into your multiplier that you have 

6 been using similar you know, for the previous 

7 rulemakings and would be able to justify these cost 

8 efficiency curves that you have on the screen. 

9 Another point that Laura had previously 

10 brought up was on the increased heat exchanger area 

II where you are talking about the bent heat exchangers 

12 and so you also talk about improved air flow and fan 

13 design so you know, those two are contradictory in a 

14 way because sometimes when you have bent heat 

15 exchange you also have to account for the air flow, 

16 the restrictive path for the air flow and how that 

17 will impact air flow. 

18 So I think it's important, if not now, at 

19 least in the final rule for DOE to elucidate exactly 

20 what those designs are that can help achieve these 

21 savings. Because if you are talking about a bent 

22 heat exchanger, you need to give an example of what 

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kind of a pathway you have in terms of improved air 

2 flow and fan design to be able to put two and two 

3 together as a manufacturer and achieve those energy 

4 savings that are you this TSL2. 

5 MR. WESTPHALEN: I don't know if I'm the 

Page 83 

6 right one to answer this, but we generally don't give 

7 the design details of what we tore apart in the 

8 public information, that's proprietary. 

9 MS. PETRILLO-GROH: At least -- Laura 

10 Petrillo-Groh I'll give it a try. At least in 

11 terms of some of the other rulemakings there was a 

12 specific increase in heat exchanger area that was 

13 associated with the design change. What the 

14 manufacturers will be able to you know how much they 

15 would be able to increase without going to a larger 

16 chassis size. I don't think it's clear whether that 

17 design option is associated with -- similar to small 

18 ice-makers, an increase of heat exchanger size will 

19 force a manufacturer to put the unit into a larger 

20 chassis, a larger box. 

21 MR. WESTPHALEN: This is Detlef again. 

22 We will consider what we can divulge. It might be 

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not quite as specific as you know, here's a 12 EER 

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2 unit that had exactly three row condenser this high, 

3 this wide and exactly at 10.2 EER compressor but we 

4 will think about how we can represent that okay at 

5 this level typically you have to use, you know, this 

6 suite of design options in order to get to that 

7 level. We will consider how we can present that and 

8 make it a little bit more clear. 

9 MS. PETRILLO-GROH: And I'm not a lawyer 

10 so maybe this question is for Sarah. I mean in 

II terms of the statutory requirement difference that 

12 this rulemaking as, we are looking at efficiency 

13 levels and energy savings over ASHRAE 90.1-2013 has 

14 any different burden of proof than the standard 

15 rulemaking process. Is it statutorily written in a 

16 separate place and there were clear and convincing 

17 evidence I think is what was used but like I said, 

18 I'm not a lawyer. 

19 MS. BUTLER: Sarah Butler, DOE. The 

20 ASHRAE 90.1 triggers an exception to the traditional 

21 requirements under EPCA but if we do decide to adopt 

22 a more stringent standard then we go back to our 

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October 29, 2014 

normal rulemaking process where we look at what is 

technologically feasible and economically justified 

Page 85 

and go through the normal max tech and 7 step process 

that we would with any other rulemaking for the more 

stringent standard. 

MS. PETRILLO-GROH: Would you do me a 

favor and look at the specific language in EPCA 

regarding this trigger because I do think it does ask 

for slightly different burden of proof and having 

numbers associated with these you know, these energy 

efficiency levels so I think would be important to 

making the case that you are saving significant 

energy. 

MS. BOTER: Sure and can you include that 

in your written comments? 

MS. PETRILLO-GROH: Of course, thank you. 

MS. WILLIAMS: So I just want to add that 

in the TSD we do show results compared to the federal 

baseline as well as the results for that ASHRAE level 

compared to the final baseline so all the analysis 

starting with the federal baseline has been done and 

is available but we are just analyzing the increment 

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between ASHRAE and the higher levels because we are 

Page 86 

2 required to show significant additional conservation 

3 of energy beyond the ASHRAE level. 

4 MR. BROOKMAN: Let's look at 15,000 Btu 

5 that table, because we are just about due for a break 

6 here. Aniruddh? 

7 MR. ROY: One quick comment on Detlef's 

8 comment. So I'm going back to the commercial 

9 refrigeration rulemaking and you know there was a 

10 discussion on improved condensing coil design and in 

II that I believe DOE had done extensive analysis on the 

12 normalized UA value, the increased thin-pitched rifle 

13 tubing, so there was a lot of analysis done on 

14 specific design options and that's something I'm 

15 looking for. 

16 I know heat exchangers are different but 

17 you know I think that level of analysis has been done 

18 before in previous rulemakings and is missing in this 

19 particular rulemaking and so I think it would be very 

20 helpful if DOE would be able to do that, at least 

21 present that in the form of okay this is, you know 

22 what we see in the heat exchange designs and so I 

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don't think this information is proprietary because 

2 you know it's been shared before on other 

Page 87 

3 rulemakings, albeit it's for a different -- it is for 

4 a coil design, it's not heat exchanger, but I think 

5 that level of detail is important. 

6 MR. BROOKMAN: Let's move on now 15,000. 

7 MR. RINGO: Thank you slide 34 here 

8 represents the cost efficiency results for the 15,000 

9 Btu's per hour capacity. It's the same format as 

10 the table on the previous slide and I apologize for 

II the confusion. The first row there is the baseline 

12 equal to ASHRAE 90.1-2013. On the incremental costs 

13 are incrementing off of that ASHRAE baseline. You 

14 see the increase to the first step there is a $3.73 

IS and it goes up to the max tech level which according 

16 to our estimates would cost $53.42 above the baseline 

17 manufacturing costs. 

18 Again the cost efficiency curve is plotted 

19 on the right. I want to just share some summary 

20 results from our engineering analysis before we move 

21 on. We observed that the cost efficiency curves are 

22 not linear, that is to say that as efficiency goes 

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Page 88 

up, additional gains in efficiency become more costly 

to manufacturers. This one may be obvious -- the 

baseline manufacturing costs for a 15,000 Btu per 

hour unit is greater than the baseline manufacturing 

costs for a 9,000 Btu per hour unit. 

And as you saw on the previous two slides, 

the slope of the cost efficiency curve is steeper for 

the higher capacity units indicating that the 

efficiency becomes more costly faster at higher 

capacity. 

I want to turn the presentation over to 

Bingyi. 

MR. BROOKMAN: We are going to pause now 

for a break. It's now almost 10:50 by my watch. We 

are going to take a 15 minute break. I think most 

of you are familiar with the way this works around 

here. You must wear this badge visible if you are 

walking the hallways. So at DOE there are restrooms 

at both ends of the hall, there's a coffee shop down 

on the ground floor and we will resume at 5 minutes 

after 11, we have made good progress already and we 

will see you back here 5 minutes after 11. 

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(Whereupon a 15 minute break was taken.) 

MR. BROOKMAN: Let's start back up. 

3 Welcome back, good to see you. We are going to 

4 proceed where we left off with Markups and Analysis 

5 and Bingyi. 

Page 89 

6 MR. YU: Good morning. Thank you everyone 

7 for attending today. My name is Bingyi Yu, I'm from 

8 the Lawrence Berkeley National Laboratory. I will 

9 be discussing the Markups Analysis, Energy Use 

10 Analysis, Life Cycle and Payback Period Analysis, 

11 Shipments, National Impact Analysis and some of the 

12 other downstream analyses that are to come. 

13 Let's start with the Markups Analysis. 

14 The purpose of this analysis is to characterize PTAC 

15 and PTHP distribution channels as well as the market 

16 segments as well as to estimate the customer prices 

17 based on the manufacturer's selling price. The 

18 methodology DOE used was to derive state level 

19 markups based on confidential interviews, economic 

20 reports from industry trade groups and U.S. Census 

21 data. 

22 The markets are derived for each 

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distribution channel which we will see now. So 

Page 90 

2 there are 4 distribution channels and we will just go 

3 through each one here. Starting from the left, the 

4 product will first be sold from the manufacturer to a 

5 wholesaler, to a mechanical contractor, to a general 

6 contractor then to the customer. 

7 The second distribution channel is from 

8 the manufacturer to the wholesaler to the 

9 manufacturer and then to the customer. The third 

10 distribution channel is from the manufacturer to the 

II wholesaler then directly to the customer. And 

12 lastly, what we are calling national accounts 

13 distribution channel being directly from the 

14 manufacturer to the customer. 

15 And the percentages that you see below are 

16 the percentage of the sales through each of the 

17 distribution channels. 

18 MS. PETRILLO-GROH: I have a quick 

19 question. Laura Petrillo-Groh, AHRI. Do you look 

20 at replacement market versus new construction market 

21 because it's different? 

22 MR. YU: Yes, yes we do. I actually use 

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Page 91 

the percentage at the bottom, or the weighted average 

2 of the replacement applications and new construction 

3 applications. The split, maybe I'll just go over 

4 this now. The split is 14% for new construction, 

5 86% for new construction so that is weighted into 

6 these percentages. 

7 MR. BROOKMAN: Would you repeat that 

8 again please, the last statements with the split, say 

9 it again. 

10 MR. YO: 14% for new construction and 86% 

11 for replacements. 

12 MR. BROOKMAN: Thank you. 

13 MR. BRONDAGE: Don Brundage. Are these 

14 numbers specifically to PTACs and PTHPs or are they 

15 broader, sometimes specifically on this chart here 

16 because if you are talking national accounts for 

17 PTACs which are mostly used in hotels and national 

18 accounts would be the major hotel chain, 5% just 

19 doesn't smell right to me. It would be that low, is 

20 this specifically to PTACs or is this a broader part 

21 of the HVAC equipment market? 

22 MR. YO: I believe this is -- I don't 

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know if I can answer that question at the moment. 

2 Yeah 

3 MS. WILLIAMS: This is Allison. The 

4 intent of this was to be specific to PTAC and PTHP 

5 but of course if anybody has data suggesting the 

6 national account should be bigger or anything like 

Page 92 

7 that please feel free to submit it in your comments. 

8 MS. PETRILLO-GROH: Unfortunately I don't 

9 have data. I just have another quick question. 

10 And I know -- so because this rulemaking is focusing 

lion standard size PTACs is all this information 

12 related to just standard size PTACs or does this 

13 include non-standard size? I don't know at what 

14 point in the analysis the decision was made to only 

15 go with standard size PTAC's so I was just curious 

16 what--

17 MR. YU: I believe the decision between 

18 standard size and non-standard size was presented in 

19 the energy use analysis and so for these slides on, 

20 they only pertain to the standard size equipment. 

21 All right, data sources used to obtain 

22 these, the markups for the distribution channels. 

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For the manufacturer markups DOE based them on the 

2008 final rule, data from that source as well as 

from confidential manufacturer interviews. 

Wholesale markups are based on 2010 profit report 

from the heating, air-conditioning and refrigerator 

distributors international. 

Page 93 

Mechanical contractor markups are based on 

2005 financial analysis of the HVAC contracting 

industry and that's from the Air-conditioning 

Contractors of America source. 

General contractor markups are based on 

2010 U.S. Economic Census and these data sources were 

the most recent ones available at the time of the 

analysis. DOE also obtained State taxes, based on 

the information from the Sales Tax Clearinghouse. 

And lastly for national accounts DOE took 

the weighted percentages of the distribution of the 

other distribution channels and reduced that total 

cost by 50% to account for the price savings realized 

for equipment purchased for national accounts. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. 

Did you get that percentage from the actual like some 

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large customers that are buying this equipment? 

Page 94 

2 MR. YU: DOE just took the 50% to be the 

3 difference between as a reasonable amount of cost 

4 savings that could be obtained through distribution 

5 channel. 

6 MR. ROSENSTOCK: Steve Rosenstock, EEl. 

7 I'm just -- I think for certain products that might 

8 be reasonable again, but I'm just a little, again, a 

9 little concerned that it might be for this product 

10 that could be overstated for national accounts again 

II I'm not one of them but if a typical one for a 

12 national key account is 30% then this is way 

13 overstating the savings. I don't know what the 

14 percentage is, it just seems like well it's kind of 

15 for some other products so we are just going to use 

16 it for this one, this is kind of crucial in terms of 

17 the economic analysis, especially if there is going 

18 to be a significant portion of the customers buying 

19 these products. 

20 MR. YU: We appreciate that comment. If 

21 there is any data available regarding the 

22 distribution of products I just mentioned before 

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Page 95 

through these national accounts as well as the costs 

2 associated with the national accounts, I think DOE 

3 would really appreciate having that info. 

4 So we'll move on to a little bit more 

5 detail about these different types of markups. 

6 There's two types, baseline markups and incremental 

7 markups. The baseline markups relates the 

8 manufacturer selling price to the customer purchase 

9 price and DOE uses these markups to indicate a 

10 customer price that covers expenses plus profit of 

11 each segment in the distribution channels. 

12 The second markup is the incremental 

13 markup and this relates to the increase of the 

14 manufacturer selling price of more efficient 

15 equipment to the increase in the customer purchase 

16 price. Now these expenses, these markups cover only 

17 expenses that vary with the manufacturers selling 

18 price and DOE believes that these costs would be 

19 considered invariant with respect to manufacturer's 

20 selling price. For example, labor and occupancy 

21 costs like rent. 

22 While the other operating costs and 

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profit, these would vary with manufacturer selling 

price and these would be the ones considered in the 

incremental markup. 

So just coming back to the percentages 

again of new construction replacement applications, 

Page 96 

DOE calculated the base line incremental markups for 

various distribution channels for the two 

applications like mentioned earlier in new 

construction applications and the replacement 

applications. 

So lastly the operation performed was that 

DOE applied the baseline markup to the manufacturer's 

selling price at the baseline equipment and applied 

the incremental markup to the incremental difference 

in the manufacturer's selling price for efficient 

equipment above the baseline. 

DOE will now present the results for these 

markups starting with the baseline and then later on 

in the next slide for the incremental markups. 

MR. ROSENSTOCK: Steve Rosenstock, EEl. 

Looking at this table you are showing, again for 

national accounts, 1.49 and I guess you are saying 

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Page 97 

that includes a manufacturer markup plus their profit 

2 margin am I interpreting that correctly? That's why 

3 you don't see the 1.27 in the manufacturing row? 

4 MR. YU: That's right, it would include 

5 all associated costs for that manufacturer to 

6 distribute directly to the customer. 

7 MR. ROSENSTOCK: And again just looking 

8 at this table, maybe it's for national accounts --

9 shouldn't there be a column in the replacement for 

10 national accounts or am I missing something? 

11 MR. YU: For replacement DOE considered 

12 there to be just these distribution channels. 

13 MR. ROSENSTOCK: So national accounts 

14 never replaced their equipment? Oh they have to go 

15 through a different channel? Okay, understood, 

16 okay, thanks. 

17 MR. YU: Thank you and the incremental 

18 baselines are presented on this slide. 

19 MR. HUNT: Marshall Hunt, PG&E so if I had 

20 an $8.00 incremental cost, I would multiply it by 

21 essentially 2 and it would be a $16.00 incremental 

22 cost, thinking of the earlier incremental cost 

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Page 98 

rounding off to 8 and rounding 9.3 off to 2, is that 

2 the way the calculation works? 

3 MR. YU: Could you repeat that calculation 

4 again, I'm sorry. 

5 MR. HUNT: Earlier we had incremental 

6 costs at about $8.00 and so that was without the 

7 markup, that's just straight materials. Okay so 

8 then it's really $16.00 weighted, 8 times 2 

9 essentially. 

10 MR. YU: Well you would have your 

II manufacturer markup and then other markups applied to 

12 that in order to get to the final incremental cost 

13 associated for that change in the manufacturer 

14 production cost. So to use your example, you have 

15 $8.00 to start, you multiply by these factors 

16 depending on the distribution channel you are going 

17 through so let's say 

18 MR. HUNT: I was making -- jumping to 1.93 

19 just to keep it simple .. 

20 MR. YU: So weighted everything. 

21 MR. HUNT: Thank you. 

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issue for comment and I think this was alluded to 

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before but DOE wishes to estimate the number and type 

of distribution channels and the distribution of the 

shipments through the distribution channels and for 

that DOE will average the information from the 200B 

PTAC, PTHP final rule. 

I think in addition to some of the items 

discussed before related to the percentages, if 

there are any other comments that stakeholders would 

like to provide related to markups, DOE would 

appreciate that. 

MS. PETRILLO-GROH: I went searching for 

some of the 200B PTAC information the other day and I 

didn't find it in the docket, maybe I wasn't looking 

in the right place or maybe it's not posted. Could 

you make that information available to someone who 

didn't work on this in 200B? 

MS. WILLIAMS: It looks -- I have a 

docket number here if you want. 

MS. PETRILLO-GROH: I checked. 

MS. WILLIAMS: Okay we'll check and get 

back to you. 

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MS. PETRILLO-GROH: Thank you. 

Page 100 

2 MR. BROOKMAN: And would that information 

3 be available in the docket, let's say if it's not in 

4 the docket presently? Ron? 

5 MR. MAJETTE: Well we can make it 

6 available if it's not there, we can make it 

7 available. We'll double check. 

8 MR. YU: So moving on to the Energy Use 

9 Analysis. The purpose of the Energy Use Analysis is 

10 to determine the unit average annual energy use for 

II PTACs and PTHPs so that energy use is called UEC and 

12 we use that term for the following slides. So to 

13 determine the UEC of PTACs and PTHPs at the 

14 considered efficiency levels to find annual energy 

15 costs and savings, these costs and savings are used 

16 in the lifecycle cost and payback period analysis as 

17 well as the national impact analysis. 

18 The methodology DOE used was to utilize 

19 the post-processed outputs from the previous analysis 

20 and that was 2008 final rule. The outputs consisted 

21 of total UECs from 50 states and DC, for 6 efficiency 

22 levels, for 9,000 Btu/h and 12,000 Btu/h cooling 

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capacities as well as for PTACs and PTHPs. 

2 Now these OEC are determined from 

3 simulations, whole building simulations performed 

Page 101 

4 with CBECS's 2003 building characteristics data which 

5 was the most recent available at that time and is 

6 still the most recent available database at this 

7 time. 

8 Those simulations were performed over 239 

9 climate locations based on TMY2 weather data and 

10 lastly aggregated to the state level for use in this 

11 analysis. Of course there are changes from 2008 to 

12 now and DOE accounted for those changes being these 3 

13 sub-bullets. 

14 The first one considering weather impacts, 

15 the second being equipment efficiency and cooling 

16 capacity differences and the third being population 

17 changes. 

18 MR. ROSENSTOCK: Steve Rosenstock. Just 

19 to clarify you used 12,000 Btu's per hour rather than 

20 15, OOO? 

21 MR. YO: That is correct so in the 

22 previous rulemaking the representative cooling 

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Page 102 

capacity that was 9,000 and 12,000. The simulations 

2 performed in the previous rulemaking at the very 

3 least had these two cooling capacities simulated. 

4 MS. PETRILLO-GROH: I have to check my 

5 ASHRAE years but I believe at a certain point, ASHRAE 

6 90.1 incorporated the thermostats on these projects 

7 as opposed to just on/off switches on the product 

8 itself. I think that might affect the number of 

9 operating hours. There are also provisions for 

10 these units to turn off from the front desk of the 

II motel to turn them off and maybe you will be getting 

12 to this information but I think that that's another 

13 change that happens in 2008. 

14 MR. ROSENSTOCK: Steve Rosenstock, EEl. 

15 I do think there were also some yeah setbacks, 

16 required setbacks for those units for all hotels and 

17 motels. I'm pretty sure it got into 2013, the 

18 required setbacks as well as occupancy sensors. I 

19 think there are certain new controls that are part of 

20 2013 that will affect the operating hours of these 

21 units. 

22 MR. YO: And just to kind of build off of 

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those questions, were those controls required or were 

they just I guess suggestions regarding energy 

efficiency, potential energy efficiency measures? 

MR. ROSENSTOCK: They are required. 

MR. YU: Okay. 

MR. BRUNDAGE: Don Brundage, Southern 

Company. I'm not sure it's even really relevant 

whether they are required. What you should be doing 

is looking at how the equipment is actually going to 

be operated in real life and whether required or not, 

it's going to include factors such as vacancy rates 

on hotels, it's not a residential property if there 

is nobody in that hotel room, the air is not -- for 

that day, it is not going to be on and that needs to 

be reflected in the usage areas. 

If nothing else, figure at a gross level 

the average occupancy rate of hotel rooms and reduce 

the number of operating hours. 

MR. HUNT: Marshall Hunt, PG&E. And to 

further complicate things is the defrost cycle and so 

any time you have a heat pump you bring on existent 

strips based on the controls and section ASHRAE 90.1-

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2013, Section 6.4.3.5 does require control of the 

2 auxiliary heat in a manner similar to unitary split 

3 systems. 

Page 104 

4 So it was a simulation doing anything with 

5 defrost or did it just use a 47 COP, how did it 

6 handle the heating operations heat pump? 

7 MR. YU: In the previous simulations, the 

8 simulations performed in the previous analysis was 

9 actually specifically geared toward buildings that 

10 use PTACs and PTHP so in this case we are talking 

II about hotels and motels, the simulations were 

12 specifically geared for those. So in pertaining to 

13 occupancy hours and the other controls, there's a 

14 potential that those simulations have already 

15 included those controls. 

16 As to defrost we will have to go back and 

17 look at what the previous simulations has performed 

18 but given the, yeah given the robustness of the --

19 performed in 2008, I'm sorry -- given the robustness 

20 of those simulations that were performed in 2008 

21 there's a likelihood that the controls that defrost 

22 and the occupancy variations in hotels and motels 

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would have been considered. 

MR. HUNT: So we looked at OEM's, four 

3 different OEM installation manuals, specifications 

4 and essentially all of them turn on and off, the 

5 compressor at 40 and switch to resistant strip 

6 heating so there's really no defrost cycle as 

Page 105 

7 required in ASHRAE 90.1-2013 so I respectfully submit 

8 that the simulations did not do that. They may have 

9 taken that COP and applied some kind of standard DOE 

10 2 point whatever curve which might have that little 

11 dog leg down from defrost, but it doesn't apply to 

12 this equipment. I think that's a really significant 

13 impact on the unit energy consumption. 

14 Whether it's offset by these other 

15 considerations, who knows, but we need to get it 

16 right, thank you. 

17 MS. PETRILLO-GROH: And a question, if 

18 these are all strategies that are required to be 

19 implemented using ASHRAE 90.1-2013 is DOE required to 

20 consider that in the analysis, in terms of energy 

21 savings, so operating hours and all these changes 

22 that are required, is that part of the burden of 

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I'm not sure. 

Page 106 

2 MR. BROOKMAN: So all of these comments 

3 which are very useful in detail, in writing will be 

4 very helpful to the Department and then they will be 

5 able to respond to all of them. 

6 MR. YU: And I will also add if since the 

7 intent of the simulations is to more or less reflect 

8 hotel, motel and other buildings that use PTACs, 

9 PTHPs, these buildings in the field if we could 

10 obtain data related to how or the persistence of 

11 setback requirements, the occupancy sensors defrosts, 

12 and other factors and their commonality in the 

13 buildings in the field I think that would also help 

14 us get an understanding of how persistent some of 

15 these controls are versus being a requirement. 

16 That's in ASHRAE 2013, ASHRAE 90.1-2013 no 

17 doubt but as to their - yeah, as to the satisfaction 

18 of buildings. 

19 MS. PETRILLO-GROH: Laura Petrillo, AHRI. 

20 Maybe someone who is more familiar with ASHRAE 90.1 

21 implementation process could speak to this. I'm not 

22 sure that that would even be -- if right now you 

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could look at any units that would reflect the 

2 changes in ASHRAE 90.1-2013 in other words I'm not 

Page 107 

3 sure that they have been adopted enough by states or 

4 that the levels are required to be implemented yet. 

5 I don't know you know the January 1, 2015 date is 

6 just tied to the efficiency level or if it is tied to 

7 other provisions in there and that even if the 

8 manufacturers don't have to meet that new efficiency 

9 level for the equipment, they also have to tie these 

10 other provisions back in so this is one of the 

11 questions for the crowd, would we be able to get that 

12 data for you? 

13 MR. HUNT: Marshall Hunt, PG&E. So 

14 California Building Standards Title 24 does require 

15 something very similar to this same requirement in 

16 90.1 and it has for years so there is no exemption. 

17 MR. BROOKMAN: Okay. 

18 MR. BRUNDAGE: Don Brundage, Southern 

19 Company. Laura was your questions on state by state 

20 implementation of 90.1-2013? 

21 MS. PETRILLO-GROH: Somewhat, yes I 

22 guess. If a state has adopted those provisions then 

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I would assume that the PTACs sold in that market 

2 would incorporate the thermostats and setback 

3 provisions and if DOE was requesting data on that, 

4 then that would help me go find the data for you. 

Page 108 

5 MR. BRUNDAGE: Okay, just speaking off of 

6 general industry knowledge, very few locations will 

7 actually adopt and enforce 90.1 until at least one 

8 year after implementation because all of the 

9 supporting documentation user manual software is not 

10 caught up with the standard yet, so very few places 

II will actually be using it before something like 

12 January, 2015 and there's some federal legislation 

13 that you need to adopt but to be honest it doesn't 

14 have a lot of teeth. 

15 But starting in 2015 I would think you 

16 would start to see quite a bit of adoption and quite 

17 a bit more within a year after that, but every state 

18 has its own implementation cycle and consideration of 

19 local customizations and has its own process. 

20 MR. ROSENSTOCK: Steve Rosenstock, EEl. 

21 One of my roles is to work with some national key 

22 account energy managers and I have had some 

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discussions in terms of you know, if they have 

2 facilities in multiple states, you know, what is 

Page 109 

3 their -- and for several of them I wish I could give 

4 you more statistics, but several of them have said we 

5 design for Title 24, that spills over into the other 

6 states, because we are Title 24 we can beat anything, 

7 anywhere. It's in Southern California so it is 

8 strict so again that you know, because economy is a 

9 scale you can do it there you can do it anywhere 

10 basically so. 

11 Again, I don't know how you incorporate 

12 that into your analysis but again it's just a matter 

13 of that is a practice among certain national 

14 multi-site customers is to do it that way. 

15 MR. BROOKMAN: Okay. 

16 MR. YO: Thank you, so we will discuss 

17 the OECs in a little bit more detail. The 2008 

18 rulemaking provided total OECs for PTACs and to 

19 PTHPs, however, in this analysis DOE analyzed cooling 

20 and heating separately for PTHPs -- the heating OECs 

21 in this analysis is defined as the heating and fan 

22 energy expended during operation in the heating mode 

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and the cooling UEC is the cooling and fan energy 

Page 110 

2 expended during operation in the cooling mode. So 

3 these were all numbers available at the previous 

4 simulations. 

5 Now because of the similarity between 

6 PTACs and PTHPs beyond just a reversing valve, DOE 

7 assumed that the cooling UEC for PTHPs would be equal 

8 to the PTAC total UEC. Of course, the PTAC and PTHP 

9 using this assumption would have the same efficiency 

10 and cooling capacity. So this bullet actually, DOE 

II would like to request comment on. 

12 Should I read the comment? 

13 MR. BROOKMAN: I don't think that's 

14 necessary, it's brief. 

15 MR. YU: Comments here? 

16 MR. HUNT: Marshall Hunt, PG&E. If we 

17 wanted to do our own analysis to look at this in more 

18 detail than we have done in 2008, how do we get hold 

19 of the building description language so that we can 

20 run the exact same building in the most up to date 

21 software? 

22 MR. YU: I believe the -- well the 

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Page III 

previous simulation used CBEC's 2003 so those are the 

2 building characteristic inputs for that simulation as 

3 to the data. 

4 MR. HUNT: I'm talking about the actual 

5 building description file used in DOE 2.1 or energy 

6 plus because unless you get the exact same input you 

7 can't be sure that you are looking at things the same 

8 way. 

9 MS. WILLIAMS: This is Allison we can 

10 look for that and see what we can do. 

II MR. HUNT: I appreciate that thank you. 

12 MR. BROOKMAN: Thank you. 

13 MR. YU: Okay we'll discuss the changes 

14 that took place between 2008 and 2013 pertaining to 

15 energy use. First of all the weather impacts and DOE 

16 compared TMY3 weather data and compared that to TMY2 

17 data that was used in the previous simulations and 

18 this analysis reviewed that more time spent at higher 

19 temperatures. In fact the monthly cooling degree 

20 days increased by 5% and the heating degree days 

21 decreased by 2%. 

22 So DOE took this to mean that the cooling 

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Page 112 

GEC increased by 5% and the heating GEC decreased by 

2 2% and these were the adjustments made pertaining to 

3 weather to the outputs from the previous simulation 

4 and DOE applied these weather impacts to the GEC's, 

5 to the state lower GECs. 

6 The next changes are the efficiency levels 

7 and the cooling capacities. So for the 9,000 Btu/h 

8 representative cooling capacity in this rulemaking 

9 DOE linearly extrapolated the 6 efficiency levels 

10 considered in the previous rulemaking to find GEC's 

II that they considered in the efficiency levels for 

12 this rulemaking and I'll go into this figure in just 

13 a second. 

14 For the 15,000 Btu/h representative 

15 cooling capacity in this rulemaking, DOE performed a 

16 two dimensional linear extrapolation, I'll explain 

17 that in two parts. The first part DOE extrapolated 

18 the GECs from the efficiency levels of the previous 

19 analysis to the efficiency levels for the cooling 

20 capacity considered in this rulemaking, that's the 

21 first part. 

22 Now the second part is DOE then 

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extrapolated across the 9,000 and 12,000 Btu/h 

2 cooling capacities considered at the previous 

3 rulemaking to the efficiency levels for the 15,000 

Page 113 

4 Btu/h representative cooling capacity considered in 

5 this rulemaking. Now if we look at the figure and 

6 the yellow dotted circles are not showing very well, 

7 but if we look at the squares you can see the first 

8 step being the extrapolation towards the left, toward 

9 the lower EER's and then the arrows highlighting the 

10 second part being the extrapolation upwards or 

11 increasing in capacity to the 15,000 Btu/h 

12 representative cooling capacity. 

13 The next change was in population. 

14 MR. HUNT: Excuse me this is Marshall 

15 Hunt, PG&E. Go back one slide please, am I correct 

16 in looking at that and saying gee whiz it looks like 

17 the distance between yellow and blue and the distance 

18 between blue and green are the same, therefore 

19 implying that the steps in capacity are 3,000 for 

20 each one of those so there's no simulation it's just 

21 a simple extrapolation is what you are saying? 

22 MR. YU: That's right, that's right, yep. 

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MR. BRUNDAGE: Don Brundage. 

Page 114 

Based on 

2 all the discussion there's been design consideration 

3 of larger PTACs and that it's harder to make it more 

4 efficient for larger sizes, it doesn't seem 

5 reasonable to a linear extrapolation because that's 

6 would imply to me unless I'm misunderstanding 

7 something, that it's -- you're just scaling the 

8 energy use upward and not changing the efficiency 

9 here, so you are keeping the same efficiencies on the 

10 -- but you are, but that's not what you are doing, 

II you are moving it downward on the EER line. 

12 So you are keeping the same trend line but 

13 moving it lower? 

14 MR. YU: Right, because the previous 

15 analysis only provided the UEC's at the efficiency 

16 levels for the 9,000 and 12. We need to obtain 

17 that for the efficiency levels for the 15,000. 

18 MR. BRUNDAGE: Okay. 

19 MR. YU: All right and moving on to 

20 population change. The state level UEC's were used 

21 in the payback period in the Lifecycle Costs Analysis 

22 but the national UEC's are used in the National 

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Page 115 

Impact Analysis so DOE used the state population data 

2 from the U.S. Census to scale the state level UEC's, 

3 excuse me, to weight the state UEC's to a national 

4 level. 

5 DOE presents the Energy Use Analysis 

6 results for PTACs and PTHPs on a national level. So 

7 should I move on? 

8 MR. BROOKMAN: Let's take a look at this 

9 table here and -- Steve Rosenstock? 

10 MR. ROSENSTOCK: Steve Rosenstock, EEl. 

11 Make sure you read the footnotes, here we go with the 

12 ELs and the numbers again especially for ELs, the 

13 footnote is very critical there in terms of what is 

14 going on here in terms of the numbers. 

15 MR. BROOKMAN: Thanks. 

16 MR. BRUNDAGE: Just to comment, to go 

17 back to the slide on the state levels. If all you 

18 are doing is ratioing to 100% it's probably all going 

19 to come out in the wash but I suspect that the UEC's 

20 in Alaska with the different weather is going to be 

21 radically higher on heating than in Alabama. If all 

22 you are doing is just ratioing average weather across 

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average population to get the total it may not be 

Page 116 

2 that big a deal, just understand that the individual 

3 numbers on energy use are probably going to be 

4 nonsensical. 

5 MR. BROOKMAN: Additional comments on 

6 this Energy Use Analysis results chart, in fact two 

7 charts? Okay. 

8 MR. YU: All right on to the LCC, the 

9 Lifecycle Cost and Payback Period Analysis. The 

10 purpose of this analysis was to provide an economic 

11 evaluation from the end user perspective. The 

12 lifecycle cost is the total customer cost of the life 

13 of the equipment and the simple payback period is the 

14 time required to recover the increase in purchase 

IS price of more energy efficient equipment through the 

16 reduced first year energy costs. 

17 The methodology DOE used are in two steps 

18 here, the first one being determining energy and 

19 economic inputs and the second being utilizing the 

20 Monte Carlo with those inputs. For the energy and 

21 economic inputs, DOE determined the total installed 

22 costs for each efficiency level, the unit average 

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energy use developed in the Energy Use Analysis as 

2 well as determine other inputs such as other 

Page 117 

3 operating costs for the first year in the lifetime of 

4 the equipment, 

5 These inputs were utilized in the Monte 

6 Carlo simulation which consisted of 10,000 iterations 

7 that select from those inputs that are characterized 

8 by a probability distribution to calculate the LCC 

9 payback period results. So a little bit more detail 

10 on the LCC and payback period the simple payback 

11 period was obtained by dividing average increase in 

12 install cost by the average decrease in first year 

13 operating cost savings, operating costs. 

14 Lifecycle cost was obtained by adding 

15 installed costs and the lifetime operating costs and 

16 the life cycle cost savings are obtained by 

17 subtracting the LCC of each efficiency level from the 

18 LCe of the efficiency level of the equipment that a 

19 customer would purchase in the absence of the amended 

20 standards. 

21 So we'll do a deep dive on these inputs. 

22 MR. HUNT: Excuse me it's Marshall Hunt 

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How could we look further into the Monte 

Carlo simulations, do you have outputs of how the 

distributions went? I always get a little nervous 

when we start doing Monte Carlo simulations it can 

get a little whacky. 

Page liS 

MR. YU: Yeah, some of the outputs are in 

the technical support document and the spreadsheet, 

the LCC spreadsheet is actually provided in the 

docket so I know you could open it and have a field 

day. 

So we'll do a deep dive on these inputs. 

The total installed cost is the sum of equipment 

purchase price and installation costs. We'll first 

talk about the equipment purchase price. This is 

provided in the Engineering Analysis and utilized 

with the markups and the Markups Analysis. The price 

is determined today in 2013 may differ in the 

compliance year 2019 but DOE used a constant price 

assumption for the price in 2019. 

This is based on the price trend based on 

the historical producer price index data for all 

other miscellaneous refrigeration and 

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Page 119 

air-conditioning equipment that span the time period 

1990 to 2013. And because this time period was 

marked by declines and increases, DOE chose to use a 

constant price assumption due to the uncertainty of 

the continuation of those trends. 

The installation costs, these represent 

the labor and materials necessary to install the 

equipment and sources of this cost data was the RS 

Means 2013 booklets. 

MR. ROSENSTOCK: Steve Rosenstock. When 

you say constant pressure are you saying constant 

real price that the price stays constant with 

inflation correct? 

MR. YU: There'd be no external factors 

that would be affecting how the price would change 

from 2013 to 2019. 

MR. ROSENSTOCK: Steve Rosenstock, again 

but since you know there -- when you say a constant 

price, there's constant nominal price and constant 

real price so I'm just -- I just want to get 

clarification that you are really talking about the 

real price. You are saying that the price stays 

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Page 120 

constant and since you are not sure about the actual 

2 price increase or decrease then you are just saying 

3 well prices of all the levels will basically stay 

4 level with inflation. 

5 MR. YO: I can't answer that at the 

6 moment. I will defer that to Alison if we have 

7 that information but if not it's in the technical 

8 support document for reference. 

9 MR. ROSENSTOCK: Okay, the second 

10 question I had was you are talking about installation 

11 costs. Again, so are you assuming that there is no 

12 -- is there any difference in the weight of the PTAC 

13 going to a higher efficiency out of curiosity? 

14 MR. YO: Yeah I apologize I didn't mention 

15 this, but in the last bullet the installation costs 

16 they don't change with efficiency, but they do change 

17 with the cooling capacity of the equipment. 

18 MR. ROSENSTOCK: Okay thank you. Steve 

19 Rosenstock, so they kind of increase marginally as 

20 the cooling capacity and the install costs increase 

21 marginally proportionately? 

22 MR. YO: Well there really isn't a 

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marginal price associated with installation costs, 

2 because there is only two for 9,000/15,000 but if 

3 there were we would use a trend in that case. 

Page 121 

4 We will discuss the annual energy costs. 

5 The annual energy cost is the product of the annual 

6 energy consumption obtained in the Energy Use 

7 Analysis and the energy price. DOE for that energy 

8 price, DOE used the electric utility tariff data to 

9 develop average and marginal electricity prices. It 

10 used the average electricity prices as well as 

11 marginal energy and demand prices were developed for 

12 the 9 Census divisions as well as for California. 

13 Since PTACs and PTHPs are commercial air 

14 conditioners and typically consume peak energy, DOE 

15 used the annual marginal prices by Census division to 

16 calculate the annual energy cost. 

17 MR. ROSENSTOCK: Steve Rosenstock, EEI. 

18 Again, getting into the weeds of this you know heat 

19 pumps are you know when you look at the numbers that 

20 you showed on the previous slide, the heat pumps are 

21 using you know when you compare the air-conditioning 

22 versus annual the heat pumps are 40 to 45% of their 

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energy consumption is not air-conditioning, it's 

Page 122 

2 heating so I -- you are saying annual marginal prices 

3 but I just wanted to ensure that you are using you 

4 know, 12 months of data, not just the summer months 

5 for your annual marginal prices that you are showing. 

6 MR. YU: That's correct, this tariff 

7 method considers both the summer as well as the 

8 winter prices. 

9 MR. ROSENSTOCK: Okay and again Steve 

10 Rosenstock, EEl, you also threw in the word demands 

11 so I am also saying that this is also including the 

12 demand charges are in there. 

13 MR. YU: Demand would be folded in, 

14 that's right. 

15 MR. ROSENSTOCK: Thank you very much. 

16 MR. YU: And lastly related to energy 

17 costs for the future years of the analysis DOE 

18 projected energy prices based on the annual energy 

19 outlook for 2013. 

20 We'll go on to Maintenance and Repair 

21 Costs. The repair costs are based on an annualized 

22 value of an extended warranty contract and DOE 

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Page 123 

obtained this information through third party as well 

as manufacturer provided warranty costs. And these 

3 repair costs increate proportionately with the 

4 manufacturer's selling price of more efficient 

5 equipment. 

6 For the annual maintenance costs, DOE 

7 obtained this information from the RS Means similarly 

8 to how it was obtained for installation costs. 

9 I will discuss Equipment and the Lifetime. 

10 DOE used a weibull distribution to model equipment 

11 and lifetime. DOE used data from the previous 

12 rulemaking and inputs from individuals experienced 

13 with manufacturing to estimate an equipment survival 

14 function. This function again is that Weibull 

15 distribution and it is modeled off equipment having 

16 an average lifetime of 10 years and a maximum 

17 lifetime of 20 years and this lifetime function does 

18 not change with efficiency level or equipment class. 

19 MR. BRUNDAGE: Don Brundage, Southern 

20 Company. What I don't see any sign of in here is 

21 something that I think is pretty common for this sort 

22 of equipment which is a 7 to 10 year redo of hotel 

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Page 124 

rooms and change out of the equipment, whether it is 

2 worn out or not. I don't really see that in that 

3 function and I really wonder how many pieces of 

4 equipment I mean you show about 50% still surviving 

5 after 10 years and I suspect in real life there is 

6 again, the mass replacements of that equipment after 

7 about 10 years so I think your -- and this is 

8 critical to this analysis because I think the 

9 practical life, not just what it's capable of making 

10 it to before it rusts away is substantially shorter 

11 than what you are assuming. 

12 The equipment makers may have more to say 

13 on this. 

14 MS. WILLIAMS: Yoolanda Williams at GE. 

15 We are aware that some folks or customers will do a 

16 mass redo, I don't have specific numbers on the 

17 percentage but we are aware that that does occur in 

18 the industry. 

19 MR. BROOKMAN: Can you characterize the 

20 lifespan of most of these big outfits, do they go 7 

21 years -- they go 10 years? 

22 MS. WILLIAMS: I couldn't speak to that, 

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the number of years between those redo's, but we are 

2 aware that that occurs. 

3 MR. BROOKMAN: Okay thank you. 

4 MR. YU: And if manufacturers could 

5 provide the persistence of these redo's throughout 

6 the hotel/motel chains, or the industry as well as 

7 that lifetime, I think that would help us you know 

8 get a good understanding of lifetime that would be 

9 different than as shown. 

10 We'll discuss Discount Rates. DOE used 

11 discount rates to convert streams of annual operating 

12 costs to the year of purchase which is in the 

13 compliance year 2019. To obtain these discount 

14 rates, DOE estimated as the weighted average, the 

15 cost of using capital asset pricing model. The 

16 discount rates were estimated for types of firms that 

17 commonly use PTACs or PTHPs and these would be for 

18 lodging, office and medical service building types. 

19 DOE used Damodaran Online as a source of 

20 information for company as well as equity finance. 

21 Lastly we will discuss the Energy Efficiency in the 

22 Base Case. The Lifecycle Cost and Payback Period 

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Analysis typically analyzes standard levels relative 

2 to a baseline efficiency. DOE is aware that not all 

3 customers purchase equipment at the baseline levels 

4 and customers with equipment at efficiency levels 

5 above the baseline must be considered to accurately 

6 estimate customer economic impacts. 

7 So DOE utilized a base case efficiency 

8 distribution sample here shown to the right for 9,000 

9 Btu/h representative cooling capacity for PTACs to 

10 characterize the distribution of efficiencies in the 

11 base case. DOE obtained this data through -- so 

12 this slide it says the AHRI Directory of Certified 

13 Pride Performance and DOE used that as well as 

14 historical data. 

15 MS. PETRILLO-GROH: So if you are using 

16 the AHRI data base was it the model availability by 

17 efficiency level but it wouldn't get you market 

18 share? 

19 MS. WILLIAMS: So this is Allison, we 

20 often use model availability as a proxy because it is 

21 difficult to get the actual market share information. 

22 I think we'll double check to see if there is any 

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historical shipment data used in these, but 

2 understand the difference. 

3 MS. PETRILLO-GROH: AHRI submitted 

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4 comments on the commercial ice-makers, NOPR earlier 

5 this year which did have that information for 

6 ice-makers and it was very different from the model 

7 availability. 

8 MR. BROOKMAN: Okay, thanks Laura, quick 

9 comments on this slide and then on to the results. 

10 MR. YU: Here we have the results for the 

11 9,000 Btu/h representative coolant capacity. 

12 MR. ROSENSTACK: Steve Rosenstack, EEl. 

13 A couple of questions when I look back on the cost 

14 efficiency relationship I'll just do two numbers. 

15 For EL4, EL5 you are showing an increase in the 

16 installed cost of $10.00 but I go back to the cost 

17 efficiency relationship, the manufacturer cost 

18 increase is $10.00 so if you add a markup of 1.93 

19 that would indicate a cost increase of $20.00, how 

20 can the incremental cost, installed cost be going 

21 from 4 to 5 be $10.00 when the material cost is 

22 $20. DO? 

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MR. YU: This is a weighting of PTACs and 

2 PTHPs as well as through the entire Monte Carlo 

3 analysis so there could be other factors affecting 

4 exactly the average increase from efficiency level 4 

5 to efficiency level 5. 

6 I understand that if there is a -- if we 

7 are looking at one specific unit right at TSL, excuse 

8 me at EL4 and EL5 then we would go ahead and use that 

9 markup with that incremental cost. 

10 MR. ROSENSTACK: Steve Rosenstack, EEl. 

11 I believe, I think these are TSL's not the EL's, just 

12 seems like an FYI I think if I am reading that right, 

13 it just struck me as kind of you know, a kind of 

14 disconnect there. But the next question I had was a 

15 simple payback, is it the average or the median value 

16 in terms of the simple paybacks? 

17 MS. WILLIAMS: So the simple payback is 

18 the delta, cost in the delta operating costs from the 

19 averages in this table. 

20 MR. ROSENSTACK: Gotcha, thank you. 

21 MS. PETRILLO-GROH: Is this actually 

22 efficiency level or is it TSL? Is this PTACs or 

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MR. YO: Neither these are the actual 

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3 efficiency levels so in the LCC the max tech would be 

4 grouped with the max tech and that would be 

5 efficiency level 5, excuse me so this would be 

6 reflecting the TSL. 

7 MS. PETRILLO-GROH: So this is a TSL not 

8 efficiency level? 

9 MR. YO: Right. 

10 MS. PETRILLO-GROH: So it's for both 

11 PTACs and PTHPs? 

12 MR. YO: That's right. 

13 MS. PETRILLO-GROH: Thank you. 

14 MR. YO: I apologize for the confusion. 

15 MR. BROOKMAN: So remind me which level 

16 is proposed in the rule for adoption on this table, 

17 is that 3? 

18 MR. YO: That would be 2. 

19 MR. BROOKMAN: 2 -- 37% of customers 

20 experiencing net costs and receiving no benefits from 

21 the rulemaking seems like a pretty high number to me, 

22 especially since as we've discussed earlier the 

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language is stronger on showing the language in the 

2 legislation is stronger going beyond an ASHRAE 

3 standard as opposed to a normal rulemaking that is 

4 not deferring to ASHRAE and it seems like that's an 

5 awful lot of losers out of the total, thank you. 

6 MR. YU: The LCC and payback period 

7 results for the 15,000 Btu/h representing cooling 

8 capacity. 

9 MR. BROOKMAN: Final comments on these 

10 two tables before we go to lunch? Steve? 

11 MR. ROSENSTOCK: Steve Rosenstock, EEl. 

12 And again I'm looking at the Federal Register notice 

13 and you know I'm seeing median paybacks of the 

14 weighted average median payback of 8.2 years and for 

15 the larger units it's 9.9 years, smaller units it's 

16 8.0 years and then the customer's with the net 

17 benefits in all the categories, whether it's weighted 

18 or the different sizes, the percentage of customers 

19 with net cost is higher than the customer -- or the 

20 percentage of customers with the net benefits under 

21 TSL2. 

22 And then there's this huge number that 

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says no impacts because they are already doing it 

anyway. Other rules have had a lot higher 

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percentages of customers with net benefits so I think 

that's causing some of the concern you are hearing 

around the table. Other rules in the past have been 

80 to 90% customers with net benefits and much lower 

payback so I think that's why you're -- that's part 

of the concern, because this seems like it's really 

kind of on the edge here in terms of being cost 

effective for a lot of customers, thank you. 

MR. BRUNDAGE: I think another factor did 

you do any customer subgroup analysis of severely 

impacted customers for this rulemaking like you do on 

some of them? 

MR. YU: Yeah we did. 

MR. BRUNDAGE: What were they? 

MR. YU: Small businesses. 

MR. BRUNDAGE: To me for an HVAC 

rulemaking, that's not necessarily the subgroup you 

need to be looking at. The subgroup you need to be 

looking at would probably be the PTACs with the pure 

air-conditioning units in climates with lower cooling 

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degree days. 

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I would suggest that the northern half 

of the country the subgroup that was a separate group 

for the residential air-conditioning standards would 

have absolutely terrible economics with this 

rulemaking because they don't have enough cooling 

degree days, thank you. 

MR. BROOKMAN: Additional comments here? 

MS. WILLIAMS: Yoolanda Williams with GE 

Appliances. Just one more statement, I'm just going 

back to the question or comments about the redo's for 

hotels, motels, one additional suggestion could be to 

reach out to hotel/motel industry and they may have a 

broader or more better view of the percentage of 

replacements that are redo's or purchases that are 

redo's. 

There may be an industry or trade 

associated issue group for that particular industry 

that may also be able to provide information too. 

MR. BROOKMAN: Okay, thank you. 

MR. ROY: One more comment before we go, 

Aniruddh. This question is actually for Decker. 

So regarding the equipment testing just to be clear, 

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the equipment was tested per ASHRAE 16 with the --

2 rules right? 

3 MR. RINGO: Yes I believe so. 

Page 133 

4 MR. ROY: Okay, I would just like to make 

5 the point that we would you know, and I want to 

6 reiterate the point that we made the test procedure 

7 NOPR comment period and I would like to say that DOE 

8 continued to recognize that the testing could be done 

9 through psychrometric rooms as well because it's 

10 obviously something that the manufacturers invested 

11 heavily in, it's very cost effective and we have 

12 actually shared results with DOE suggesting that they 

13 are comparable in terms of the test results and if we 

14 were to make a shift or forced to make a shift to 

15 calorimic rooms that would be very expensive for the 

16 industry overall so I would encourage DOE to think 

17 about that and allow manufacturers to you know, 

18 certify their products based on the psychrometric 

19 rooms but they can go ahead and do their enforcement 

20 testing in the calorimic rooms if they see that as 

21 being fit. So that's my comment on that issue. 

22 MR. RINGO: Decker Ringo, thank you for 

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Page 134 

your comment and thank you for your data submission 

on the test procedure rulemaking, 

MR, ROY: Thank you to Laura. 

MS. PETRILLO-GROH: Thank you, hopefully 

this is quick because I don't want to hold up lunch 

but and I know Steve alluded to it earlier, can you 

go through what the difference is between the payback 

period that you are presenting here versus what's in 

the Federal Register because it's different? 

MR. YU: The simple payback period shown 

here is based on the first year operating cost and I 

believe the content presented in the NOPR is off an 

average cost. 

MS. PETRILLO-GROH: Can you go into why 

you are presenting it differently here, not in the 

climate, I'm just curious as to what I'm looking at. 

MR. YU: I think we also presented simple 

payback in the notice in the TSD as well. 

MS. WILLIAMS: Yeah I thought we presented 

simple payback in the notice as well, I don't have it 

in front of me sorry, but in general we have sort of 

been moving towards simple payback so this rule was 

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one of the ones that was sort of caught in the middle 

2 between what we have been presenting, so I apologize 

3 if there is any inconsistencies between those two. 

4 We tried to document clearly which -- like if it says 

5 median payback period, that's calculated differently 

6 from the simple payback period. 

7 MS. PETRILLO-GROH: Thanks for clarifying 

8 that. 

9 MR. BROOKMAN: Final comments? We can 

10 return to these if additional issues bubble forward 

11 over lunch. It's now 5 minutes after 12, let's take 

12 lunch. A reminder that you will need to wear your 

13 badge inside the building, if you go to the big 

14 cafeteria as you pass through the security portal you 

15 might very well need an ID. This room will be 

16 secured so you can leave your stuff here, we will see 

17 you back here at 5 minutes after 1. Do you all know 

18 where the cafeteria is? Down to the ground floor and 

19 

20 

21 

22 

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AFT ERN 0 0 N S E S S ION 

MR. BROOKMAN: Welcome back. We are 

3 going to proceed with the Shipments and National 

4 Impact Analyses. 

5 MR. YU: I hope everyone had a good 

6 lunch. Now we will discuss the Shipments and the 

7 National Impact Analyses. The purpose of the 

8 Shipments Analysis is to estimate PTAC and PTHP 

Page 136 

9 shipments over the analysis period from 2019 to 2048. 

10 And the National Impact Analysis estimates the 

11 national energy savings from those shipments at 

12 various trial standard levels as well as estimate the 

13 net present value to PTAC and PTHP customers of the 

14 savings from those shipments at the various trial 

15 standard levels. 

16 We will first discuss the shipments 

17 analysis and go into depth there. Again the purpose 

18 is to estimate PTAC and PTHP shipments over the 30 

19 year analysis period. The methodology DOE used was 

20 to develop a single shipment model for all PTACs and 

21 PTHPs. 

22 The model is a stock accounting model, 

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which assumes that each year existing PTAC or PTHP 

ages by one year or fails. The PTAC and PTHP 

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3 shipments are driven by a construction of new floor 

4 space and the replacements of the units that have 

5 failed. 

6 So in this case for the shipments we have 

7 again two applications, new construction and 

8 replacement. So for new construction shipments DOE 

9 developed projections based on projections of new 

10 commercial floor space from the AEO 2013 and the new 

II floor space and multiplied by a saturation value for 

12 new construction that was developed using data from 

13 the 2008 rulemaking. 

14 Now for the replacement shipments there 

15 are two purposes here. First is the DOE built up an 

16 initial stock by using the average of the historical 

17 shipments from 1998 to 2004 for the years 1993 to 

18 2012. DOE developed 

19 MS. PETRILLO-GROH: Quick question, Laura 

20 Petrillo, AHRI. So it seems that the replacement 

21 market is getting larger as the years progress, is 

22 the slope of that line consistent with the period 

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before that you analyzed or is that just assuming 

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2 that all those new buildings will then get replaced? 

3 I just don't know if there's a point where it 

4 reaches saturation and you can't actually build 

5 anymore hotels? 

6 MR. YU: I don't believe, at this point 

7 we are not analyzing whether there is going to be a 

8 maximum limit to the number of buildings that can be 

9 constructed yeah we are not analyzing that here. 

10 I'm sorry. Maybe I'm not understanding the question. 

I I MS. WILLIAMS: So this is Alison. 

12 Replacements are all based on or start out based on 

13 historical data that are being replaced and the new 

14 construction is off AEO and so the replacements just 

15 continue to replace the historical data and the AEO 

16 which actually looks fairly low so I think that -- I 

17 mean we are not specifically accounting for 

18 saturation but since the AEO projections of new 

19 construction are pretty low, there's nothing crazy 

20 going on I think. 

21 MS. PETRILLOO-GROH: Thank you. 

22 MR. BRUNDAGE: Don Brundage, Southern 

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Company. 

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Do you have any data points any place in 

2 what's available to you on total number of existing 

3 PTACs in use? If you had that it would be a good 

4 check on your assumptions on lifespan or whether 

5 there is pre-failure replacement of units. 

6 MR. BROOKMAN: Okay. 

7 MR. ROSENSTOCK: Steve Rosenstock. Yeah 

8 I'm just kind of curious I know with other types of 

9 equipment, you know, shipments went way down during 

10 the recession, I'm just kind of curious as to 2013 is 

11 this reflecting, is this kind of recovery basically 

12 I'll say is this kind of equivalent to what was say 

13 2007 or is it still I'll say at a you know, I'll say 

14 at a recessionary level if shipments haven't come 

15 back yet? 

16 MR. YU: We considered data in this case 

17 for the initial stock from 1998 to 2004 so we did not 

18 include the shipments data or the yeah -- the 

19 shipments data or the new construction floor space 

20 data for the years a little bit before, during and 

21 after the recession. 

22 MR. BRUNDAGE: Don Brundage again. Just 

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to remake a point, just by the nature of the type of 

2 equipment that it is, we know that there is a certain 

3 percentage of replacement before failure. It's just 

4 inherent with the sort of product and the sort of 

5 market that it is in and it's not going to be like a 

6 residential single family unit, so I think some sort 

7 of assumption for assuming pre-failure replacement, 

8 even if we can't find any hard data is realistic to 

9 assume some, and based upon what you are presenting 

10 here, you are assuming zero. 

11 MR. YU: Thank you we will keep that 

12 under consideration. 

13 MR. ROY: Aniruddh Roy with Goodman so to 

14 Steve's point, I think the first bullet under 

15 replacement shipments you really need to account for 

16 I guess the economic climate, you know between 1998 

17 and 2004 the scenario was very different as compared 

18 to let's say 2008 to the current situation. So I 

19 think that needs to be accounted for somewhere in 

20 your analysis. And also any previous, you know 

21 recessions that did occur and how that impacted your 

22 shipments projection over here. 

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MR. YU: Right, for the purposes of 

building that initial stock, the initial stock was 

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just a set up model so that the number of shipments 

that we had at the start of this announced as being 

2013 was relatively close to the last received AHRI 

shipment which was in 2012. So the shipments were 

relatively lined up so to speak from historical data 

to the beginning of this shipments projection. 

MR. ROY: But you are still using an 

average between '98 and 2004? 

MR. YU: That's just for the build-up, 

for the build-up. 

MS. WILLIAMS: I think also we have plus 

the average is really from 1998 to 2012, we might 

have a small error on there, we will check. But 

yeah, so the data passed 2004 is confidential from 

AHRI so that's why we can't show you explicitly 

what's going on there. 

MR. ROY: But was it used in the analysis 

though? 

MS. WILLIAMS: He's saying that we 

basically took it into account and made sure that it 

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MR. ROY: Okay, thank you. 

Page 142 

3 MR. YU: So to wrap up the second bullet 

4 under replacement shipments, the replacement 

5 shipments were determined based off of the lifetime 

6 function, that's discussed earlier in the lifecycle 

7 costs and payback period analysis. 

8 The last aspect related to the projected 

9 shipments are the stated standards case impacts and 

10 in this analysis you assume that the standards will 

II not impact shipments, therefore the standard's case 

12 shipments equal the base case shipments. 

13 So next we will disaggregate the 

14 shipments by equipment class. This was done for 

15 PTACs and PTHPs based on data so this needs to be 

16 different. This is based on historical data, it 

17 carne from AHRI. And based on the same historical 

18 data set DOE expects that this trend for this 

19 distribution to stay constant for the projection 

20 years. 

21 We have one issue for comment. 

22 Stakeholders mentioned that a number of shipments are 

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October 29,2014 

not accounted for in the AHRI data base because 

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2 certain manufacturers are not AHRI manufacturers and 

3 are not subject to reporting to that database. So 

4 therefore, DOE requests data for the expected 

5 distribution of models that may be unreported to that 

6 data base. 

7 MR. BROOKMAN: Anything here? Okay 

8 thank you. 

9 MR. YU: These shipments are used in the 

10 NIA and that's what we will discuss next. The 

11 purpose of this analysis is to estimate the national 

12 energy savings as well as the national economic 

13 impact from amended energy conservation standards for 

14 the different efficiency levels for that 30 year 

15 analysis period. 

16 DOE performed the following methodology, 

17 calculated national energy savings by multiplying 

18 unit lifetime energy savings by projecting by excuse 

19 me, by projected shipments and accumulating this 

20 projected value over 30 years and for the net present 

21 value DOE accumulated the difference each year 

22 between energy bills savings and increased equipment 

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expenditures for all equipment shipped over the 30 

2 year period which was then discounted to those 

3 discounted. 

Page 144 

4 The inputs that DOE used for that discount 

5 rate is 3% and 7%. Other inputs that are used in 

6 this analysis as shown here in this table, as you can 

7 see discount rates are already there along with total 

8 install costs, repair and maintenance cost, annual 

9 energy use, base-case efficiency, standards-case 

10 efficiency, the efficiency trend, energy prices, full 

11 fuel cycle as well as the present year. 

12 So these inputs were used in a national 

13 impact analysis to determine the net present value 

14 national energy savings for the three equipment 

15 classes as discussed in the engineering analysis. 

16 Some of these inputs are leveraged from 

17 the lifecycle cost and payback period analysis, 

18 specifically for the greater than or equal to 7,000 

19 Btu/h and less than or equal to 15,000 Btu/h 

20 equipment class. DOE used the inputs from the 9,000 

21 Btu/h representative cooling capacity from the LCC 

22 payback period analysis. 

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For the greater than 15,000 Btu/h 

2 equipment class, DOE used the inputs for the 15,000 

Page 145 

3 Btu/h representative cooling capacity in the Lee and 

4 payback period analysis. However for the less than 

5 7,000 Btu/h equipment class, DOE did not analyze 

6 representative cooling capacities in the Lee and 

7 payback period analysis and therefore used the 

8 following techniques to obtain the input data for 

9 that equipment class. 

10 Specifically for the manufacturer 

11 production cost, which is then scaled up with markups 

12 to determine the manufacturer's selling price, DOE 

13 used the cost of the 9,000 Btu/h and 15,000 Btu/h 

14 representative cooling capacities and scaled that 

15 accordingly with modifications to account for lower 

16 capacity compressor, fan motors as well as heat 

17 exchangers. 

18 For other energy as well as economics 

19 data, DOE performed the extrapolations across the 

20 9,000, 15,000 Btu/h representative cooling 

21 capacities. 

22 Preparation for performing the National 

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Impact Analysis, DOE presents the efficiency levels 

Page 146 

that were presented in the Engineering Analysis that 

was discussed here. 

MR. ROY: I'm sorry I have a question on 

the previous slide. 

MR. YU: Yes. 

MR. ROY: So the representative cooling 

capacity in the LCC and payback period analysis for 

the second row, why did you not analyze 9,000 and 

15,000 together? Because that would be 

representative of that range, why only 9,000? You 

could have scaled it accordingly by doing the 

analysis using both those capacities. 

MR. YU: The 9,000 Btu/h was the cooling 

capacity with the highest sales volume and therefore 

that would be the most fitting for that equipment 

capacity range. 

MR. ROY: But one could argue that you 

also had data for the 15,000 and that would have been 

representative of all the 20 tests that were 

conducted and would have given you the best 

representation across the range of efficiencies. 

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MR. YU: I would see that to be an 

Page 147 

2 alternative way of performing this, but in this case 

3 where you have a greater than 15,000 Btu/h equipment 

4 capacity class, you would have to use some sort of 

5 input data right? And if you but then in that 

6 case required that data, it's probably better to use 

7 the 15,000 Btu/h representative cooling capacity 

8 inputs than take those inputs, combine them with the 

9 9,000 to use them for other equipment classes. 

10 MS. WILLIAMS: So this is Alison. All 

11 the results are weighted averages from all 3 of the 

12 7, 9 and 15 so it's being accounted for in that NIA, 

13 it's just attributed to a different bin so they are 

14 all taken into account. 

15 MR. ROY: Okay. 

16 MR. YU: Here are the efficiency levels. 

17 Before grouping these efficiency levels into the 

18 trial standard levels, DOE wanted to estimate market 

19 shifts in efficiency and it performed two key 

20 operations. The first operation was a roll up 

21 scenario to establish the shipment weighted 

22 efficiency for the year that the standards are 

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expected to become effective, which is 2019. 

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So this roll-up scenario is applied to the 

base case, efficiency distribution, and just to 

review again, those are based on AHRI data for the 

year 2013 and was increased from 2013 to 2019 or 

scaled rather at a rate of 1 EER every 35 years. 

The standards-case efficiency distribution 

again is based on that roll-up scenario and 

efficiency below a standard level are considered 

rolled-up or summed to the market of the efficiency 

level being considered. Efficiency above the 

standard level, however are not affected. 

The second operation DOE performed was to 

account for technological improvements in equipment 

it shifts to higher efficiency equipment. Again 

that is the one EER every 35 year trend. And this 

is used in commercial air-conditioner rulemaking. 

So projected efficiency distribution of 

shipments can be seen on the right for the equipment 

class PTACs greater than or equal to 7,000 Btu/h and 

less than or equal to 15,000 Btu/h. One issue for 

comment, DOE requests any comment regarding end data 

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supporting the efficiency trend. 

MR. ROSENSTOCK: Steve Rosenstock, EEl. 

3 On the heat pump side or the COPs do you have any 

Page 149 

4 sort of -- what was your assumption in terms of COPs 

5 because the headroom is a lot smaller. 

6 MR. YU: The COPs were scaled with the 

7 EER based on the Model Availability Analysis from the 

8 AHRI data base. So that was the regression that the 

9 Engineering Analysis had talked about. 

10 MR. ROSENSTOCK: Steve Rosenstock, EEl. 

II Is the slope the same as this or is it lower? 

12 MR. YU: We didn't project the efficiency 

13 of the COP for the future. 

14 MR. ROSENSTOCK: Thank you. 

15 MR. YU: Sorry. 

16 MR. ROY: Aniruddh Roy, Goodman. So a 

17 question on the repair costs, excuse me, so is that 

18 lumped into the maintenance cost? 

19 MR. YU: It wouldn't be lumped into the 

20 maintenance. The maintenance would be your typical 

21 preventative maintenance actions that you could take 

22 on a unit. The repair would be a more heavy change, 

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Page 150 

or heavy repair to your equipment, being maybe a coil 

2 change or a compressor change. 

3 MR. ROY: Because I'm looking at the TSD 

4 in Chapter 8 and it doesn't specify a dollar value 

5 for the repair cost. Do you happen to have that? 

6 MR. YU: Yes we definitely have that. 

7 MR. ROY: I don't need the answer now, if 

8 you can just look into it and let me know what that 

9 is. 

10 MR. YU: Okay it's definitely in 

11 MS. WILLIAMS: It's actually in Chapter 

12 10 we must have missed it in Chapter 8 but yeah. 

13 MR. BROOKMAN: Is there any comment on 

14 issue number 5? Comment regarding and data 

15 supporting the selected efficiency trend? 

16 MR. YU: Let me go back a slide. So for 

17 the efficiency levels as mentioned in the previous 

18 slide, DOE grouped them into the TSLs as described in 

19 the Engineering Analysis. So here are the TSLs. 

20 Again, we discussed before lunch that there would be 

21 some nomenclature inconsistencies here with the 

22 percentages as presented, the 1.8 and the 4% as an 

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Page 151 

2 In this case the baseline here presented 

3 is the ASHRAE 90,1-2013 minimum and TSL would be in 

4 this case 2,2% and is based off that baseline. 

5 MR. ROSENSTOCK: Steve Rosenstock, EEl. 

6 I'm looking at the Federal Register Notice table V.25 

7 and I'm looking at the industry net present value and 

8 you know you show ranges and at TSL2 it goes from 

9 negative.7 to a positive .3 in terms of the change 

10 and then percentage negative 1.3 to .5 so again I 

11 don't know where the median or the average of those 

12 you know, that range is but you are saying the 

13 maximum industry net present value but I am looking 

14 and it kind of -- it seems like it's at least 

15 negative compared to the other choices. 

16 I don't know in terms of other rulemakings 

17 whether it's been like that or not but I'm just -- it 

18 just seems like there is a range of impacts but you 

19 know if you look at the average it's still slightly 

20 negative so I think -- I know we are just doing this 

21 for the table but it still could be negative for the 

22 industry, it's just -- it's not -- they're still a --

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Page 152 

even at TSL2 there's a possibility of a negative 

2 change to the industry NPV and I think it's, again I 

3 know it's a summary table but it is not telling the 

4 story correctly. 

5 It's the least amount of negative change 

6 to the industry NPV and I know this is a summary 

7 table, but I think that -- I think it's a key 

8 difference that it's the least amount of impact, 

9 thank you. 

10 MS. PETRILLO-GROH: I was also hoping 

11 that you would speak a little bit more to the fact 

12 that TSL1 has a negative industry impact and TSL2 may 

13 have a positive impact. 

14 MS. WILLIAMS: This is Alison. I think 

15 they are going to do a whole presentation on the 

16 industry net present value, he just has a couple more 

17 slides to finish the national, we are just showing 

18 these to set up the TSLs for the results so they will 

19 go into a lot more detail on the industry stuff. 

20 MS. PETRILLO-GROH: Thanks Alison. 

21 MR. ROY: Aniruddh Roy, Goodman. So 

22 Alison thank you for referring me to Chapter 10. I 

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Page 153 

was just looking at the repair costs in table 10.4.3 

2 average repair costs across the equipment classes and 

3 across all the efficiency levels and they seem to be 

4 consistent across the board which tome intuitively 

5 does not make sense because I know in some of the 

6 efficiency levels you have analyzed PSE motors, some 

7 of them have been permanent magnet motors and so I am 

8 assuming that there would be a cost difference to 

9 change out those you know, motors in a repair 

10 scenario. 

11 So there would be a cost differential but 

12 it just looks like you know the price per unit, the 

13 repair cost per unit is linear in this table and is 

14 not reflective of what actually happens in the 

15 marketplace. 

16 MR. YO: Those repair prices again are 

17 from a warranty contract so true certain types of 

18 motors, or certain types of compressors might be more 

19 expensive to source than you know other types. 

20 Those would be faced by the supplier of that warranty 

21 contract so the price of the repair for the customer 

22 themselves are actually not the same as what a 

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supplier of that extended warranty contract would 

2 fix. 

Page 154 

3 MS. WILLIAMS: Sorry, we weren't talking 

4 about it the repair cost is scaled with -- is it 

5 scaled with equipment costs? Yes, so we will take a 

6 look at your comments, it is scaled with 

7 manufacturers selling price which theoretically 

8 accounts for the different whatever they are using to 

9 achieve the different efficiency levels, but we will 

10 take a look at that. 

11 MS. PETRILLO-GROH: Laura Petrillo-Groh, 

12 AHRI. I was also interested in based on Aniruddh's 

13 comment and your response was that it was based on 

14 warranty information? Would it be typical for this 

15 equipment to have a warranty that span its entire 

16 lifetime? 

17 MR. YO: No. Typical warranties that we 

18 found for this analysis range from 1 year up to 5 

19 years. 

20 MS. PETRILLO-GROH: So if this equipment 

21 was replaced after 5 years, then is there a different 

22 price of the component? 

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MR. YU: If a piece of equipment was 

2 replaced or repaired after the warranty contract 

3 ended, yes the price would be different from the 

4 price that is paid for the warranty contract. 

Page 155 

5 MS. PETRILLO-GROB: But that hasn't been 

6 taken into account in this? 

7 MR. YU: No, that hasn't been taken into 

8 account. 

9 MS. WILLIAMS: This is Alison. I think 

10 we will have to go back and look at this again, but 

II the assumption generally is that or the assumption 

12 that can be made as what you are paying for a 

13 warranty contract to manufacturer spread out over 

14 everybody it would be somewhat equivalent to your, 

15 the repair costs on average, across the population 

16 but we will take a look at that. 

17 MS. PETRILLO-GROB: Thanks I would 

18 appreciate that. 

19 MR. BROOKMAN: Additional thoughts here? 

20 Questions? 

21 MR. YU: Bere are the groupings of the 

22 efficiency levels into the trial standard levels as 

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Page 156 

well as the results for the National Impact Analysis, 

2 MR, ROSENSTOCK: Steve Rosenstock, EEl. 

3 I'm going back to the Shipment Analysis where it's 

4 basically saying you know the vast majority of the 

5 shipments, again based on your data are 7 to 15,000 

6 Btu's per hour, it looks like about 88% of the 

7 shipments are within that range. 

8 I go to the Federal Register document, 

9 consumer means LCC savings for standard size 

10 equipment 15,000 Btu's per hour negative $2.11 and 

II then for 9,000 Btu's positive 40 cents. I'm just 

12 kind of surprised that -- I'm trying to make a 

13 connection because it just seems like and then it 

14 says a weighted average but I guess that's of all 

15 sizes is positive, it just seems that if a bulk is 

16 between 7,000 and 15,000 has a negative means savings 

17 I'm just surprised that there's a positive net 

18 present value, just to me there seems to be a 

19 disconnect in terms of you know, the customer is 

20 seeing negative savings and then there's somehow a 

21 lifetime net present value or positive net present 

22 value. 

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I'm trying to think what am I missing 

Page 157 

3 MS. WILLIAMS: So Steve I'm trying to look 

4 at the numbers but I think because they are weighted 

5 averages in the LCC and the NIA's also is this PTAC 

6 and PTHP yes, sorry. Yeah, so I think that is a 

7 result of the weighted averages between the different 

8 components. And there's also some other differences 

9 between the LCC and the NIA that can make differences 

10 between them when you are not, you know way far out 

lIon the scale of savings and that kind of thing. 

12 MR. YO: If there are no more questions 

13 we'll switch presenters. 

14 MS. PETRILLO-GROH: Just one, Laura 

15 Petrillo-Groh, AHRI. There is one more. I still 

16 would like to know a little bit more about how that 

17 difference comes about when you are looking at the 

18 bulk of the shipments having a negative LCC and then 

19 you know, stated that there is a benefit to the 

20 consumers. I'm with Steven I'm confused. 

21 MS. WILLIAMS: Yeah so the PTHP has 

22 positive LCC savings at 9,000 that are sort of 

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outweighing the slight negative PTAC savings. I 

think yep 

MR. BROOKMAN: Are you referring to a 

slide? 

Page 158 

MS. WILLIAMS: No, sorry they are not in 

the slide, they are in the documents so yeah, so 

there's a weighting of the PTHP which is positive 

PTAC which is very slightly negative at the 9,000 so 

MR. BROOKMAN: The weighting is based on 

the shipment? 

MS. WILLIAMS: It's on shipments yeah, the 

slide that someone was referring to earlier where the 

vast majority of shipments are between 7 and 15 and 

the PTHP savings outweigh the slight PTAC negative in 

the LCC and so the weighted average is positive and 

that you know, and in the NIA we find the same thing. 

MS. PETRILLO-GROH: Did that use the 

model availability or did that use actual shipments? 

MR. YU: This is describing capacity, if 

it is for capacity then yes. It's the AHRI 

shipments, the circle shipments. 

MS. PETRILLO-GROH: So that used --

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MS. WILLIAMS: Yes it's the shipments 

MS. PETRILLO-GROH: The shipments data 

4 not the model availability. 

5 MS. WILLIAMS: Yeah the model 

6 availability I believe is for the efficiency 

Page 159 

7 distributions and the capacity distributions are by 

8 shipments. 

9 MS. PETRILLO-GROH: Thank you. 

10 MR. BROOKMAN: We're moving on to 

II Manufacturer Impact Analysis. 

12 MS. LEWIS: Hi I'm Jessica Lewis from 

13 Navigant and I'll be discussing the Manufacturer 

14 Impact Analysis or MIA that was conducted as part of 

15 this NOPR. The main purpose of the MIA is to assess 

16 the impact of proposed standards on manufacturers of 

17 PTACs. A second purpose is to identify subgroups of 

18 manufacturers that may be more severely impacted by 

19 proposed standards and to evaluate the potential 

20 impacts of standards on those subgroups. 

21 In the slides that follow I will discuss 

22 impacts on two manufacturer subgroups, small 

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Page 160 

businesses and manufacturers with production assets. 

Finally the MIA addresses direct employment impacts, 

manufacturing capacity and other federal regulations 

that affect PTAC manufacturers and take effect around 

the compliance date for this rulemaking. 

The primary tool DOE uses to evaluate 

impacts on manufacturers is a discounted cash flow 

model called the Government Regulatory Impact Model 

or the GRIM. The major output of this model is the 

industry net present value or INPV which is a metric 

used to represent the financial impacts of amended 

standards on manufacturers. 

As part of the MIA we also conducted 

interviews of manufacturers. These interviews helped 

us refine inputs to the cash flow model and also to 

understand the qualitative impacts of standards on 

manufacturers. 

In general the MIA process takes place in 

3 phases. In the first phase we develop an industry 

profile using publicly available information such as 

Securities and Exchange Commission filings and 

corporate annual reports. 

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In the second phase we develop an 

Page 161 

2 interview guide to gather targeted information from 

3 manufacturers, and we also prepare the cash flow 

4 spread sheets used to estimate financial impacts on 

5 the industry. 

6 In the final phase we conduct interviews 

7 with manufacturers and use manufacturer feedback to 

8 further develop the analysis, finalize inputs to the 

9 cash flow model and examine the potential 

10 qualitative impacts of the standard. 

11 To build the cash flow model for the 

12 industry we rely on content from several of the 

13 analyses already discussed today. These upstream 

14 inputs include financial and product information from 

15 the Market and Technology Assessment, manufacturer 

16 production costs from the Engineering Analysis and 

17 annual shipment projections from the Shipments 

18 Analysis. 

19 We also develop two key pieces of 

20 information as part of the MIA. First we develop 

21 multiple manufacturer markup scenarios which allow us 

22 to model a range of potential impacts on the 

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Page 162 

industry. We also develop a conversion cost model 

2 that allows us to account for various one-time costs 

3 manufacturers may face in order to comply with the 

4 requirements of amended standards. 

5 On the qualitative side of the MIA, one of 

6 the primary outputs is a set of key issues that 

7 manufacturers raised during the course of interviews. 

8 To outline those briefly, manufacturers first raised 

9 concerns regarding their ability to increase the 

10 efficiency of the products while maintaining strict 

II physical dimensions. 

12 Second, manufacturers indicated that PTACs 

13 are often purchased on a first cost basis and that an 

14 increase in the equipment costs could lead to falling 

15 sales and a decline in profitability. 

16 And third, manufacturers indicated that 

17 increasing efficiency can create challenges related 

18 to noise and humidity control. They also indicated 

19 setting standards too high could lead them to 

20 discontinue higher capacity models. 

21 MR. ROSENSTOCK: Hi, Steve Rosenstock, 

22 EEL I always appreciate the information but in 

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Page 163 

terms of the customer utility when it says humidity 

2 control, was that associated with any certain I'll 

3 say certain EER level at certain areas where if you 

4 reach that certain EER that they could do it but they 

5 would meet the efficiency under the test but in real 

6 world conditions with humidity that it wouldn't meet 

7 the -- it wouldn't get rid of the latent heat. I'm 

8 just kind of curious. 

9 MS. LEWIS: It's a good question and we 

10 did not get information that precise. It was kind of 

11 a general comment that as efficiency increases that 

12 can be a challenge. 

13 MR. ROSENSTOCK: Okay, Steve Rosenstock, 

14 EEL Thank you because especially in the more humid 

15 climates if that is happening, people are going to 

16 react by lowering the dryable temperature if it gets 

17 humidity, there could be a loss of energy savings as 

18 people try to get the humidity out of the room. 

19 The second one is also very interesting is 

20 you know in terms of higher capacity models again 

21 without associating with any particular EER I know 

22 you went through TSLI through 5 but again did they 

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Page 164 

say if you increase the EER by X percent over the, 

2 I'll say the ASHRAE level that they might not be able 

3 to make those units anymore, let's say 15,000 Btu's 

4 per hour? 

5 MS. LEWIS: Yeah and we did not get 

6 comments that precise and are very open to data. I 

7 think and Decker spoke to this a bit also but it 

8 tends to be more complicated to increase the 

9 efficiency of these products at higher capacity while 

10 maintaining fixed dimensions. But based on a review 

II of product literature there seem to be models on the 

12 market that meet the proposed standard. 

13 MR. ROSENSTOCK: Thank you. 

14 MR. BRUNDAGE: Don Brundage, Southern 

15 Company. Just a comment I'm not sure anything can 

16 be done about it but the way to provide better 

17 humidity control is to go to variable speed 

18 operations, instead of regulating EER in the standard 

19 there's no incentive to go to variable speed 

20 operation. 

21 If you -- some of the larger equipment is 

22 going toward IER for measuring that would help but 

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the complexity of doing that for rulemaking might I 

Page 165 

2 don't know if that's even an available option, thank 

3 you. 

4 MS. LEWIS: Okay. Moving on to the next 

5 few slides we will walk through the Quantitative 

6 Analysis in more detail. First as I mentioned, one 

7 of the key inputs to the cash flow model is a set of 

8 markup scenarios. The markup is a multiplier 

9 applied to the manufacturer production costs that 

10 captures all non-production cost. So R&D selling 

II general administrative expenses, interest expenses 

12 and also profit. By varying the markup we are able 

13 to model multiple sets of financial impacts on the 

14 industry. In this case we modeled two markup 

15 scenarios. The preservation of gross margin 

16 percentage markup scenario represents an upper bound 

17 or less severe set of impacts and the preservation of 

18 operating profit markup scenario represents the lower 

19 bound or most severe set of impacts. 

20 The preservation of gross margin 

21 percentage scenario assumes manufacturers maintain 

22 their gross margin percentage after the standard 

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This scenario implies that as 

2 production costs increase with efficiency, 

3 manufacturers are able to raise their prices and 

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4 increase their operating profit in absolute dollars 

5 on a per unit basis. 

6 As a contrast, the preservation of 

7 operating profit scenario assumes manufacturers 

8 cannot maintain the same gross margin percentage 

9 after standards take effect. Instead the scenario 

10 assumes manufacturers preserve the same operating 

II profit per unit in absolute dollars before and after 

12 standards, but must reduce their markups to do so. 

13 The other key input we developed as part 

14 of the MIA is a set of conversion cost estimates. 

15 This table shows estimated converted costs for the 

16 industry at each trial standard level broken down 

17 into two categories, product conversion costs and 

18 capital conversion costs. 

19 Capital conversion costs are one-time 

20 investments in equipment, tooling and other physical 

21 assets and product conversion costs are one-time 

22 investments in R&D, testing, certification and other 

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costs required to bring products into compliance. 

2 The conversion costs estimates rely heavily on 

3 feedback obtained from manufacturers during 

Page 167 

4 interviews and also draw on the engineering analysis. 

5 As you can see from this table, total 

6 estimated converted costs for the industry at the 

7 proposed level are 7.6 million dollars. After 

8 developing the conversion cost estimates and markup 

9 scenarios, we use the cash flow model to estimate a 

10 range of potential impacts on industry net present 

11 value. 

12 This table summarizes those impacts at 

13 each TSL analyzed. The lower INPV estimates are 

14 derived from the preservation of operating profit 

15 markup scenario and the higher estimates reflect the 

16 preservation of gross margin percentage markup 

17 scenario. As you can see the proposed standard will 

18 lead to an estimated change in INPV in a range of 

19 negative 1.3% to 0.5%. 

20 MR. ROSENSTOCK: Steve Rosenstock, EEl. 

21 And again I appreciate you know all the explanations, 

22 it just -- I'm looking at the jump in all the 

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Page 168 

conversion costs you know, almost well not going up 

68% from TSLl to TSL2 and then doubling from TSL2 to 

TSL3 and I'm looking at you know and I know about the 

profit margin, it just seems kind of interesting that 

it's always negative at 1 and it can be positive at 2 

then it's always negative at 3 then it can almost be 

breaking even at 4. 

I'm just 

MS. LEWIS: It's a fair question and it's 

kind of counterintuitive looking at it. What you 

are seeing take place here is an inter-play of the 

manufacturer selling prices, the shipments and the 

conversion costs. So as the manufacturer production 

costs rise with more efficient products the 

manufacturer selling price also increases and 

combined with the shipments produced as part of the 

Shipment Analysis, you are seeing an increase in 

industry revenue that's interacting with various 

conversions costs to kind of create the dynamic that 

you just pointed out. So it's an increase in 

projected industry revenues at TSL2 relative to 

conversion costs that's causing a more favorable 

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scenario at TSL2 for manufacturers than at TSL1. 

MS. PETRILLO-GROH: Thank, so you 

mentioned that the INPV interaction was between 

selling price, shipments and conversion costs, is 

that correct? 

MS. LEWIS: That dynamic yes. 

MS. PETRILLO-GROH: So the shipments 

should be the same across the board because it is 

based on building stock correct? 

MS. LEWIS: The shipments are steady. 

The shipment assumption is steady shipments. 

Page 169 

MS. PETRILLO-GROH: And the conversion 

costs go up? 

MS. LEWIS: Correct. 

MS. PETRILLO-GROH: According to the 

current slide. So this is really due to selling 

price? 

MS. LEWIS: Which has to do with the 

manufacturer production costs which Decker outlined 

in the Engineering Analysis and then we apply a 

markup to the production costs to arrive at the 

manufacturer selling price. 

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MR. ROY: Aniruddh Roy, Goodman. 

Page 170 

So 

assuming that the manufacturer selling price goes up 

across the board for all manufacturers, what is the 

guarantee that the behavioral pattern of consumers 

will not change and they will not just simply choose 

to repair net products and stop buying you know, new 

PTACs? Does the study account for that in any way? 

MS. LEWIS: It's a good question and it's 

a concern we did hear from manufacturers also and 

kind of noted in the key issues a concern that sales 

can decline. I think that to the extent you are 

able to provide any data to help us model that and 

quantify that would be very valuable, but right now 

the shipments that they discussed assume steady 

volumes year to year. 

MS. PETRILLO-GROH: Can you point me to 

the production costs that you mentioned from Decker's 

analysis? Are those on earlier slides? 

MS. LEWIS: They would be the 

manufacturer production costs. I would have to 

scroll through those. They are at slides 33 and 34. 

The spreadsheet model is also published along with 

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the technical support document. 

Page 171 

2 MS. PETRILLO-GROB: So just to make sure 

3 I completely understand this looks at for the 

4 conversion costs looks at the cost efficiency curves? 

5 MS. LEWIS: No, the conversion costs are 

6 separate from the manufacturer production costs. 

7 MS. PETRILLO-GROB: I thought you said it 

8 was based on the. 

9 MS. LEWIS: The manufacturer selling 

10 price is based on the manufacturer production costs 

II so there's a markup applied to the manufacturer 

12 production costs to reach the manufacturer's selling 

13 price. The conversion costs are developed based on 

14 a combination of manufacturer feedback and data 

15 obtained through the course of the Engineering 

16 Analysis, the teardowns and those costs try to 

17 capture the investment that manufacturers will have 

18 to make in everything from you know, physical assets 

19 to design engineering in order to bring their product 

20 lines into compliance with the new standard, so those 

21 are separate from the material cost and selling 

22 price. 

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Page 172 

MS, PETRILLO-GROH: Thanks, I misspoke, 

2 The selling price had to do with the production cost. 

3 MS. LEWIS: Exactly. 

4 MS. PETRILLO-GROH: So on slide 33 and 34 

5 the selling price has an increased incremental cost 

6 for each of the efficiency levels. So if the 

7 conversion costs are going up for energy efficiency 

8 level, the shipments are remaining constant across 

9 each efficiency level and the selling price is going 

10 up for each efficiency level, why is the INPV lower 

II in trial standards 2 than in trial standards I? 

12 MS. LEWIS: I think it really just has to 

13 do with the extent to which revenues are rising, 

14 projected revenues are rising relative to the 

15 conversion costs. 

16 MR. LAO: This is Chris Lau from Navigant. 

17 So conversion costs are costs that manufacturers 

18 have to invest to stay in the game and so it's a 

19 trade off on INPV right? The higher conversion 

20 costs are the lower industry net present value gets 

21 in general. 

22 Balancing that is, let's take an example. 

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Page 173 

So I'm looking at slide 80 and I look at TSL2, you 

2 will see the INPV range is from 57.7 to 58.8 and the 

3 lower bound is less than base case value and the 

4 upper bound is above the base case value. All right, 

5 the upper bound that's 0.3 million more than base 

6 case. What's happening is the manufacturer 

7 production cost is going up but we are assuming that 

8 manufacturers keep the same gross margin percentage. 

9 In other words, as their prices go up, 

10 they're increasing the cost to the customer right and 

11 making the same profit margin. So they are actually 

12 making more profit than they would have than in the 

13 base case. 

14 In the lower bound we are assuming that 

15 that cannot happen. Manufacturers are not able to 

16 pass on all their costs and the result once you 

17 subtract out the conversion costs the INPV is below 

18 the base case value. 

19 MS. PETRILLO-GROH: Thank you for the 

20 additional explanation. I'm still hopefully a few 

21 short questions. If I'm a manufacturer and I'm 

22 going to implement a design option, I changed my line 

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Page 174 

in order to increase the efficiency I would want to 

2 do it for the lowest cost option. So for me it 

3 doesn't, I'm still a little unsure of why you are 

4 looking at implementing for the design options to get 

5 more efficiency and you have taken a low-hanging 

6 fruit first, why there is suddenly that how that 

7 goes from negative to positive in terms of the upper 

8 bound and also can you confirm what the base case is 

9 I'm looking at here? 

10 MR. LAU: So to answer the first part of 

II that question, Chris Lau from Navigant. It is 

12 unclear how much of your conversion costs you can 

13 pass on to the market, like what your customers would 

14 bear so we model our range of markups to show that 

15 there's a level of uncertainty right. If you cannot 

16 pass on -- if you can pass on all costs, that's upper 

17 bound. 

18 If you can pass on part of the cost, 

19 that's the lower bound, that's what that represents. 

20 It's not saying -- the upper and lower bound aren't 

21 different design options, it's just saying given a 

22 design path, there's uncertainty in terms of how the 

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Page 175 

pricing in the industry will change and so we model a 

2 range of manufacturer's selling prices. Can you 

3 repeat the second half of that question? 

4 MS. PETRILLO-GROH: Sure the base case at 

5 58.5 is that --

6 MR. LAU: That assumes manufacturer's move 

7 to the ASHRAE level. ASHRAE 90.1-2013. 

8 MS. PETRILLO-GROH: Thank you. 

9 MR. ROY: Aniruddh Roy, Goodman. I 

10 think it's impractical to assume that the same profit 

II margins would be maintained once you move to higher 

12 efficiencies. I think it's pretty clear with the 

13 appliance industry, you know the household goods like 

14 refrigerators, you know we have reached a point I 

15 guess in those products and I can't comment for the 

16 industry but the general observation is that they 

17 have been commoditized to an extent and so the profit 

18 margin is not the same for let's say a premium 

19 product versus a commoditized product. 

20 And so now you are going to a higher 

21 efficiency so it's very I think impractical to assume 

22 that manufacturers will be able to maintain the same 

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operating profit margins, I think the conversion 

Page 176 

2 costs that you are mentioning here will affect that 

3 in a way and also I would like to ask the question 

4 over here, like in summary of TSL2 on slide 80 I see 

5 expected conversion costs of a total of 7.6 million 

6 dollars. 

7 At what point do you make a judgment call 

8 that it's too much for the industry? I mean you 

9 know is one million too much, 10 million too much, 15 

10 million too much? What exactly is I guess the 

11 breaking point for our industry because you know 7.6 

12 to me is a very big number. 

13 MR. LAO: So I can't fully speak for DOE 

14 but I think generally the consideration is that you 

15 know conversion costs reduce INPV so INPV tends to be 

16 the factor that DOE looks at, at least at first 

17 blush. In the end it's a 7-factor rule, they take 

18 into account all the costs versus all the benefits so 

19 I don't know if there is a single conversion cost 

20 value or a single percentage that has been defined as 

21 a cut-off. It's a weighting. 

22 MR. ROY: Thank you. 

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Page 177 

MS, LEWIS: And to your first point just 

2 to add that when you see these two numbers, consider 

3 them bounds, They represent a range and we model 

4 the two scenarios and one does take into an account 

5 the prospect that manufacturers would not be able to 

6 maintain the same margins and so this is just sort of 

7 trying to define a range of potential impacts. 

8 MR. ROY: I understand that but and this 

9 is Aniruddh Roy, Goodman. I understand that but I 

10 think this model is assuming that the operating 

11 profit margin stays constant, is that correct? I 

12 don't think it's assuming that it would vary, it 

13 would go down. 

14 MS. LEWIS: Well there are the two markup 

15 scenarios I was talking about a couple of slides back 

16 and in the preservation of gross margin percentage 

17 scenario, it assumes the same gross margin percentage 

18 in the preservation of operating profits scenario it 

19 assumes that the gross margin percentage falls and 

20 that manufacturers are only able to maintain the same 

21 absolute dollar profit per unit sold. 

22 MR. ROY: Is there a scenario where there 

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is absolutely no profit? 

MS. LEWIS: We did not model a scenario 

like that. We selected these scenarios based on 

kind of the feedback we received from manufacturers 

during the course of interviews. If you feel that 

you know, we should be considering a different lower 

bound, that's definitely something we would welcome 

in the comments. 

MR. ROY: Thank you. 

MS. LEWIS: Thank you. 

MR. BROOKMAN: Are we ready to move on? 

MS. LEWIS: So these overall impacts 

reflect our estimated impacts on the industry in 

aggregate, but to try to better capture some of the 

nuance DOE also evaluates impacts on subgroups of 

manufacturers that may be differently impacted by a 

standard. 

This next slide addresses the subgroup of 

manufacturers with production assets. During the 

course of analysis DOE identified 22 manufacturers of 

PTACs and PTHPs however most manufacturers import and 

distribute equipment produced by original equipment 

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manufacturers overseas. 

2 DOE identified a subset of domestic 

3 manufacturers that own their own PTAC production 

Page 179 

4 lines and analyzed these manufacturers as a distinct 

5 subgroup. Part of the rationale for analyzing these 

6 manufacturers separately is that they would be 

7 expected to incur capital conversion costs or 

8 one-time investments in equipment, tooling and other 

9 physical assets that their competitors without 

10 production assets would not face. 

11 And they would also be expected to 

12 experience a heavier R&D burden. This table presents 

13 the lNPV results for manufacturers with production 

14 assets compared with the industry as a whole and at 

15 TSL2 manufacturers with production assets would be 

16 expected to experience a change in lNPV in the range 

17 of negative 2.3 % to negative 0.5% and to incur 

18 conversion costs of 6.8 million dollars which is 

19 equivalent to 89% of the industry total. 

20 MR. ROSENSTOCK: Steve Rosenstock, EEl. 

21 Again, I appreciate the slide but I think you know 

22 again this is my interpretation is that it's 

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Page 180 

basically, the manufacturers that are importing are 

the ones that have a chance at a positive INPV but 

domestic manufacturers it's all negative. 

So the way I'm looking at this is it seems 

to me, appears to me at this table that the only way 

to get a positive INPV is to outsource, import from 

overseas, so you don't have all those costs or am I 

missing something? 

MR. LAU: Chris Lau, Navigant. I could 

see how you would interpret it that way however keep 

in mind that these manufactures with production 

assets are competing today against foreign imports at 

levels both at baseline and above baseline today. 

MR. ROSENSTOCK: Steve Rosenstock, EEl. 

I appreciate that but again what this is saying is 

that the ones that are basically outsourcing are 

going to have a competitive advantage. 

MR. LAU: So what its saying is that 

manufacturers with production assets are having to 

make capital conversion investments and those that 

outsource will not, however I would expect that those 

that out source would see those conversion costs come 

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back in the form of price increases. 

2 MR. ROSENSTOCK: How would that be 

3 possible? 

Page 181 

4 MR. LAU: Because even if you are buying 

5 from a foreign manufacturer and you are buying at 

6 price today and tomorrow you need a more efficient 

7 product, you will likely be paying a different price 

8 for that product. 

9 MR. ROSENSTOCK: Steve Rosenstock, EEl. 

10 But if it's well now we are getting into 

11 international economics here but if the foreign 

12 manufacture--

13 MR. BROOKMAN: And it's speculative 

14 exchange rates or something? 

15 MR. ROSENSTOCK: Well I didn't want to 

16 talk about exchange rates or dumping of materials. 

17 My wife works at an international law firm that's 

18 what they handle is dumping of products and materials 

19 into the U.S. It's very complicated but you know 

20 let's face it with other appliances, you know 

21 production has been outsourced as a way to reduce 

22 prices and to keep their NPV's, that's been a trend 

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Page 182 

over 30 years for a significant number of appliances 

2 so. 

3 Again I know this is a summary table but 

4 this is kind of what it appears to be leaning towards 

5 and that to me, that is concerning, thank you. 

6 MS. PETRILLO-GROH: How many manufacturers 

7 did DOE identify with production assets? 

8 MS. LEWIS: The subgroup includes 3 

9 manufacturers. 

10 MS. PETRILLO-GROH: 3 of 22 

II manufacturers? 

12 MS. LEWIS: Correct. 

13 MS. PETRILLO-GROH: Do any of those 3 

14 also qualify as small businesses? 

IS MS. LEWIS: No. 

16 MS. PETRILLO-GROH: Did DOE conduct the 

17 same analysis in 2008? 

18 MS. LEWIS: I do not believe so no. 

19 MS. PETRILLO-GROH: Did DOE identify 

20 foreign and domestic manufacturers in 2008? 

21 MS. LEWIS: I can't speak to that, I 

22 don't know. 

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MS. PETRILLO-GROH: I see. 

Page 183 

2 MR. MAJETTE: Why don't you submit that 

3 as a comment because we can't, we just won't be able 

4 to answer that on the fly right now. 

5 MS. PETRILLO-GROH: So my concern is that 

6 we have got a significant portion of the industry 

7 total conversion costs being borne by 3 of the 22 

8 manufacturers and as Steve mentioned it looks much 

9 more favorable for those manufacturers who do not 

10 produce units domestically. 

11 MS. LEWIS: I think that's precisely why 

12 DOE looked at this subgroup as distinct from the 

13 industry as a whole. 

14 MS. PETRILLO-GROH: Looked at the 

15 subgroup but still is proposing the level? Is this 

16 also broken out in the TSD perhaps for the other 

17 trial standards levels? 

18 MS. LEWIS: I'm sorry what is that 

19 question exactly -- have what broken out? 

20 MS. PETRILLO-GROH: The subgroup. 

21 MS. LEWIS: The subgroup analysis is 

22 discussed in the technical support document in 

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MS. PETRILLO-GROH: For the other TSLs? 

MS. LEWIS: Correct. 

Page 184 

4 MS. PETRILLO-GROH: Could we just look at 

5 that really quickly, I'm just interested to see. 

6 MS. LEWIS: It's not in the slide deck, 

7 sorry. 

8 MS. WILLIAMS: Feel free to review the 

9 two and please submit those comments to us, I don't 

10 think we are going to be able to answer anything else 

II about that policy decision right now. 

12 MS. PETRILLO-GROH: Thanks the TSD was 

13 posted a little late to the docket. 

14 MS. WILLIAMS: I apologize, I was not 

15 aware. 

16 MS. LEWIS: Any other question on that? 

17 All right, finally DOE looks at the impacts of 

18 standards on small businesses. Of the 22 PTAC 

19 manufacturers identified, DOE identified 12 as small 

20 businesses. This classification is based on the 

21 Small Business Administration's small business size 

22 standards which set a cap of 750 employees for a 

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Page 185 

manufacturer in the PTAC industry to be considered a 

2 small business. 

3 DOE used publicly available information to 

4 research small businesses, contacted small businesses 

5 directly and also asked other manufacturers for 

6 information about small business during the course of 

7 interviews. Based on this research, DOE did not 

8 identify any small businesses that are original 

9 equipment manufacturers of standard size PTACs and 

10 PTHPs. 

II Instead small businesses primarily import, 

12 reb rand and distribute equipment manufactured 

13 overseas, primarily in China. Because of this, DOE 

14 does not expect small business to incur capital 

15 conversion costs related to this rulemaking, however 

16 small business can potentially experience an increase 

17 in product purchase price from overseas original 

18 equipment manufacturers if those manufacturers raise 

19 prices to reflect their own conversion costs. 

20 Small businesses could also incur testing 

21 and certification costs for models redesigned to 

22 comply with an amended standard and these costs were 

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factored into overall industry conversion costs. 

Any questions? 

Page 186 

Before turning it back to Bingyi I would 

like to request comment on the number of small 

business manufacturers identified on the potential 

impacts of amended standards on those small 

businesses and on the severity of those impacts and 

if there are any other comments related to the 

Manufacturer Impact Analysis, please feel free to 

raise those now. 

MR. BROOKMAN: Any other comments, we can 

start on some of the concerns that have been raised 

by industry members. Nothing additional? Okay, 

moving on. 

MR. YU: I promise this is the last time 

you will see me at this -- now we will go into the 

Downstream Analyses. First were the Lee Subgroup 

Analysis. The purpose of the Lee Subgroup Analysis 

is to analyze the impacts of efficiency standards on 

small businesses, particularly independently 

operating lodging businesses. As mentioned in the 

previous analysis, the Small Business Association has 

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this definition of small business and for this 

2 analysis we used the same definition to group 

3 businesses into what they would consider small 

4 businesses. 

5 And for these businesses it applied a 

6 discount rate premium to separate them from the 

Page 187 

7 typical lodging business. The outputs, the LCC and 

8 payback period results show that the effect of higher 

9 PTAC and PTHP standards on small businesses is 

10 similar to the effect on the full sample of 

11 commercial customers. 

12 For the Emissions Analysis the purpose is 

13 to report emission impacts resulting from amended 

14 energy conservation standards, including changes in 

15 power plant emissions and full fuel cycle emissions. 

16 DOE used the National Energy Modeling System to 

17 derive emissions factors for carbon dioxide as well 

18 as other gases. 

19 The results you will see presented on the 

20 next slide, this one. Here we show the cumulative 

21 emissions reductions for PTACs and PTHPs. 

22 MR. ROSENSTOCK Steve Rosenstock, EEI. 

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Page 188 

Did these projections take into account the MATS Rule 

2 that goes into effect next year, that's for the 

3 Mercury and Air Toxic Standard that was finalized in 

4 2011 I believe and takes effect next year basically 

5 next April, that's part one. 

6 Part two I'm sure the TSD was written 

7 before the EPA's Clean Power Plan, you know the Clean 

8 Power Plan calls for a 30% reduction in the C02 

9 emissions from power plants, you know between now and 

10 2030 basically. Is there a possibility of doing a 

11 sensitivity analysis with the projection of that 

12 rule, that's a two part question. 

13 MR. YU: As to the mercury, I don't know 

14 if we have that information handy at the moment 

15 however that's something that we can definitely take 

16 a look at if it's not included and include that in 

17 the Emissions Analysis. 

18 MS. WILLIAMS: This is Alison, MATS is 

19 included in this. 

20 MR. ROSENSTOCK: So this is Steve 

21 Rosenstock, EEl. So this is after I'll say at least 

22 50% reduction that's going to happen next year right? 

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MR. BROOKMAN: Is it that much, 50 

Page 189 

2 really? So if it's in statute, then you would think 

3 the Department would consider that right. 

4 MR. ROSENSTOCK: The other one is more 

5 speculative. Steve Rosenstock, EEl. The EPA rule 

6 right now just announced in June they are going to 

7 finalize it next year but again since the compliance 

8 period for that EPA rule would start under the 

9 schedule basically states have to submit their plans 

10 in 2016 to implement, starting in 2016 so that's well 

II within the -- before the starting period of this 

12 supply standard. 

13 MS. WILLIAMS: This is Alison. As 

14 people have stated before DOE does not include 

15 proposed rules in its analyses and typically does not 

16 consider those until they become final because 

17 obviously with this rule, especially among others you 

18 never know what's going to happen between the 

19 proposal and the final. 

20 MR. ROSENSTOCK: Again Steve Rosenstock, 

21 thank you, but again looking ahead when you see the 

22 numbers in terms of the value of the benefits it can 

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be a -- it's significant just because of the fact 

2 that the estimated value of the benefits that you 

Page 190 

3 will see in a couple of slides is in many cases a lot 

4 higher than the benefits that the consumer is going 

5 to see so in this case in particular, it's such a 

6 massive number that could be seen as a benefit that 

7 for some policy makers it could make a difference, 

8 thank you. 

9 MR. BROOKMAN: Okay thank you, yes Sarah. 

10 MS. BUTLER: Sarah Butler, DOE. I just 

11 want to reiterate first what Alison said that we 

12 can't speculate on proposed rules, we can only look 

13 at what the facts are at the time. But DOE does have 

14 a provision known as exception relief, it's under 42 

15 USC 7194, if the facts change. You will have to look 

16 at the provisions under that law. You can go to the 

17 Office of Hearing and Appeals and ask for it in an 

18 instance where the facts analyzed at the time of the 

19 rulemaking change. 

20 So if EPA issued a rule that completely 

21 changed the circumstances that's something that you 

22 could look into but we can't speculate what EPA might 

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do in the future years down the line while we are 

doing a rulemaking. 

MR. ROSENSTOCK: Steve Rosenstock, EEl. 

I understanding that completely. I am just saying 

Page 191 

that for future rules it wouldn't be bad to have that 

as a part of a Sensitivity Analysis especially when 

the number shown is a benefit for the C02 or show 

much larger than the other numbers being shown in the 

proposed rule. 

MR. BROOKMAN: Yeah okay, we got it. Any 

comments here? We are about to talk about Emissions 

Monetization. 

MS. PETRILLO-GROH: I have one question. 

Okay, so I'm just looking at C02, see an increase 

for each of the trial standards levels. Should -- is 

that, I mean I don't actually know how the carbon 

dioxide is tracked with respect to the equipment, is 

it probably very complex. So simplistically can you 

tell me if I'm on the right track? 

DOE implements a standard. The standard 

is X percent more efficient than the baseline. If 

you are looking at all of the trial standards levels, 

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Page 192 

should there be -- the number of carbon dioxide track 

linearly between the increase in efficiency. 

So increase in efficiency of you know, 

going from the trial standard 1 to trial standard 2 

is that just based on the efficiency increase of the 

equipment? 

MS. WILLIAMS: It's specifically tied to 

the energy savings which mayor may not track exactly 

with efficiency increase depending on what the jumps 

are between the levels. So in general you would see 

in the emissions a similar trend to the energy 

savings, the emissions are yearly factors so I'm 

trying to think through this. 

I don't think there's anything between the 

standard levels that would change like where in time 

the savings occur so yeah, are they --

MR. BRUNDAGE: I'll give it a shot at my 

interpretation. Don Brundage. When you run NEMS 

these are drops in the ocean compared to the total 

energy use of the country when you are on the NEMS 

model so in theory it would vary, but in reality I 

think you would see proportional if you have four 

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times as many kilowatt hours savings you will have 

2 four times as much C02 savings. 

Page 193 

3 Because these when you run the change 

4 cases on NEMS it's going to -- it's not going to 

5 change the total character of the energy use. I 

6 guess this is such a small percentage of the total 

7 country's energy use. Is that close? 

8 MS. WILLIAMS: Thank you, yeah I would 

9 agree it would be a proportional effect, yeah. 

10 MS. PETRILLO-GROH: So since you are 

11 looking at an efficiency increase of I guess 4%, 8%, 

12 12% you know what that's based on, but the 

13 differentials will be the same between 2 and 3 right. 

14 Why would you look at different numbers going from, 

IS if the -- trial standards level 2 to trial standards 

16 level 3 if you are looking at the same net gain in 

17 efficiency? 

18 MR. BROOKMAN: The Department is doing 

19 their diligence there. They wanted to present their 

20 results. 

21 MS. WILLIAMS: Are you just asking like 

22 for example the energy savings at TSL2 are .06 and at 

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Page 194 

TSL3 they are .12, the emissions for carbon from 4 to 

2 8 so they are approximately doubling in both cases, 

3 is that where you are going with this or no? 

4 MS. PETRILLO-GROH: Yes, they are 

5 approximately doubling, but it seems like that's just 

6 from 2 to 3, wouldn't it go from 3 to 4 the same? 

7 MS. WILLIAMS: I mean so 3 to 4 on energy 

8 savings goes from .12 to .15 and here it's 8.6211, 

9 I'm not doing the exact math but it looks roughly 

10 somewhat 

11 MS. PETRILLO-GROH: Isn't it .8 to .12 

12 for that? 

13 MS. WILLIAMS: Sorry. 

14 MS. PETRILLO-GROH: 4%, 8%, 16%. 

15 MS. WILLIAMS: Oh, so I mean again I'm 

16 looking at the energy savings, not the percent 

17 efficiency increase and so those may not be actually 

18 tied together. 

19 MS. PETRILLO-GROH: Thank you that helps. 

20 MR. BROOKMAN: Okay. 

21 MR. YU: Thank you. For the Emissions 

22 Monetization the purpose of this analysis is to 

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estimate the potential monetary benefit of reduced 

Page 195 

2 power plant emissions resulting from the considered 

3 standard levels. Methodology used is utilizing the 

4 social cost of carbon as intended to be a monetary 

5 measure of the incremental damage resulting from 

6 greenhouse gas emissions. 

7 DOE used the most recent U.S. government 

8 interagency estimates of the SCC for emissions in 

9 2015 in per metric ton. SCC is in constant dollars 

10 and it increases over time. 

11 MR. BRUNDAGE: Don Brundage, Southern 

12 Company. It's important to note that the social 

13 costs of carbon is not allowed to be included within 

14 the operating cost of performance metrics benefit to 

15 the consumer. This is another benefit to society 

16 because the cost benefit of the efficiency 

17 improvement is specifically required to be operating 

18 cost to the consumer. I just want to make that 

19 clear. 

20 MR. YU: Thank you. Here are the results 

21 of the Emissions Monetization Analysis. We will move 

22 on to the Utility Impact Analyst. 

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MR. ROSENSTOCK: 

Page 196 

Steve Rosenstock, EEl. 

2 If we could go back again, I'm sorry. Again, on my 

3 previous point you know we were talking about net 

4 present value to customer benefits of a TSL2 of 10.7 

5 to 69 million and here we are showing the C02 values, 

6 numbers of 28 to 412 million so I mean that's another 

7 reason is -- I have seen where sometimes those 

8 numbers get combined in the customer benefits and the 

9 C02 values get combined in certain tables and so I 

10 think that's why we are stressing that things are 

11 dramatically changing in the power sector. 

12 And so as emissions go down these values, 

13 the total values, the cumulative values especially 

14 are going to go down significantly as well and you 

15 know the MATS rule and other rules, you know the 

16 level of MATS is going down 75% over the last 20 

17 years in terms of actual emissions. 

18 MR. BROOKMAN: You would like to find 

19 some way for the Department to consider these things? 

20 MR. ROSENSTOCK: Well let me put it this 

21 way, it's a matter of just -- you know the natural is 

22 final, the Cross State Air Pollution Rule has now 

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been reauthorized that could be implemented again 

Page 197 

starting January 1st. That has to do with regional 

ozone, S02 and NOX, it's just a matter of there --

there can be with these numbers, you are showing a 

range but they can be also, there's also the 

sensitivity of just what's happening with the EPA 

rules they are going to have dramatic impacts on the 

actual physical emissions which also corresponds to 

the monetized options. 

MR. BROOKMAN: Okay, Don? 

MR. BRUNDAGE: Don Brundage. I agree 

that you can't include things that are not -- that 

haven't actually been passed and aren't final. 

However, that does not prevent you from including in 

your intangible considerations just the fact that the 

whole based DOE study because it operates under the 

same rules of not doing anything final tends to be 

higher energy use and higher emissions it is likely 

to actually occur. 

Because EIA operates under the same rules 

you do so it needs to be understood that this is a 

pessimistic view or it is a high view of the amount 

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of C02 savings compared to what's likely to occur. 

Page 198 

2 It's procedurally correct but it needs to understand 

3 that this is probably a higher C02 savings that's 

4 likely to actually occur and that's one of the 

5 intangibles I think you are allowed to include in 

6 your consideration for future rulemakings, thank you. 

7 MR. BROOKMAN: Thank you. 

8 MR. YU: The next analysis is the Utility 

9 Impact Analysis. The purpose of this analysis is to 

10 estimate the changes in the electric utility, 

II electric installed capacity and generation that 

12 results for each TSL. Methodology used here is the 

13 National Energy Savings is used to provide a stream 

14 of energy savings over the analysis period and it 

15 utilizes the NEMS National Energy Modeling System 

16 modified to represent the impacts of the DOE 

17 standards program. 

18 Outputs are reductions in total 

19 electricity generation. Reductions in primary fuel 

20 consumption, changes to the mix of electricity 

21 generation by fuel type as well as changes to total 

22 installed capacity and these outputs can be found in 

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NOPR For PTACs and PTHPs 

October 29, 2014 

the Chapter 15 of the technical support document. 

Page 199 

2 DOE also performed an Employment Analysis 

3 to estimate the number of jobs created or eliminated 

4 nationally as a consequence of the amended national 

5 standards. The methodology DOE used was utilizing 

6 the ImSET model or the impact of Sector Energy 

7 Technologies for the evaluation of indirect 

8 employment impacts as well as direct employment 

9 impacts to the commercial air-conditioning industry. 

10 Changes in equipment and energy 

11 expenditures are taken from the national Energy 

12 Savings Analysis. And the outputs which can be 

13 found in Chapter 16 of the TSD represent change to 

14 commercial and energy sector employment again as a 

15 consequence of amended standards. 

16 DOE also performed another analysis as 

17 well as the last analysis discussed today the 

18 Regulatory Impact Analysis. The purpose is to 

19 investigate the national impacts of non-regulatory 

20 alternatives to mandatory amended conservation 

21 standards. 

22 MS. PETRILLO-GROH: I'm sorry I have a 

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Page 200 

question on the previous slide, the Employment 

Analysis. If memory serves correctly, looking at 

the NOPR, it looks like at one bound, it's given as a 

range right? At one end of that range is -- you 

have 170 in parenthesis which I assume are 170 jobs 

lost at and that's being considered for each TSL? 

MS. LEWIS: This is Jessica with 

Navigant. So there are a couple of different 

employment analyses and there's an indirect 

employment analysis and a direct employment analysis. 

What I think you are referring to is the direct 

employment analysis conducted as part of the 

Manufacturer Impact Analysis. And there we do 

present a range and it's that negative 170 you are 

talking about. 

So the upper end of the range for the 

direct employment impacts which refers to people 

employed directly in the production of this 

equipment, the upper boundary range assumes a slight 

increase which says that if all production stays in 

the U.S. in these, you know the efficiency increases 

and there is a little potentially greater labor 

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Page 201 

demand you might see a slight gain in jobs and then 

2 the lower bound that negative 170 or something right 

3 along those lines assumes that all direct employment 

4 is eliminated and potentially all production shifts 

5 overseas. 

6 MS. PETRILLO-GROH: I'm just curious how 

7 DOE got to that upper limit if 89% of the industry 

8 conversion costs are going to be performed by the 3 

9 manufacturers that employ those 170 people and we saw 

10 a significantly different picture for manufacturers 

II that are overseas, thank you. 

12 MS. LEWIS: That is an upper limit so 

13 it's definitely not saying either/or so much as 

14 here's a range and the likely impact will be 

15 somewhere in there. And then the way that's 

16 calculated is based on data acquired from the annual 

17 survey of manufacturers and it's factored into the 

18 analysis and projected out over a period of years. 

19 MR. BROOKMAN: Chris do you want to add 

20 here? 

21 MR. LAU: Yes just one quick clarifying 

22 comment I probably should have made earlier sorry, 

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Page 202 

Chris Lau, Navigant. When we looked at the subgroup 

manufacturers of production assets, not all of those 

production assets are in the U.S. It's just to 

clarify it's not domestic versus foreign, it's 

manufacturers actually that own tooling. 

MR. YU: So that covers the analyses 

performed for this rulemaking. 

MR. ROY: Just a question on slide 88 so 

the social costs of carbon numbers, those are the 

2013 values right? 

MR. YU: That is correct. I started the 

Regulatory Impact Analysis so I'll go ahead and 

finish that. We were discussing the methodology. 

DOE modified NIA spreadsheet of National Impact 

Analysis spreadsheet, to represent the following 

non-regulatory alternatives. No new regulatory 

action, customer rebates, customer tax credits, 

manufacturer tax credits, voluntary efficiency 

targets, as well as bulk government purchases. 

MR. BRUNDAGE: Don Brundage, Southern 

Company. It should be noted that pushing efficiency 

standards, this and others all the way to the cost 

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effectiveness limit really removes most of the 

2 non-regulatory alternatives from consideration. 

3 There's no reason to have customer rebates, tax 

4 credits, manufacturer tax credits for something 

5 that's already mandatory to do. 

6 And voluntary efficiency targets and 

Page 203 

7 programs such as Energy Star really don't have a lot 

8 of room to operate when you push standards all the 

9 way to the cost effectiveness limit. That just 

10 needs to be understood that it's happening. There's 

11 very little room left for Energy Star or other 

12 voluntary energy programs when the mandatory minimums 

13 are set so high, thank you. 

14 MS. PETRILLO-GROH: Chris thanks for 

15 clarifying the manufacturers with production assets. 

16 I just have another question on that. So 3 of the 

17 22 manufacturers have production assets that are held 

18 in the United States, what is the case for these 

19 other 19, do they have private brand or rent 

20 facilities or I don't know if there is a combination 

21 of the two. 

22 MR. LAU: Generally they are purchasing 

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off the shelf products from overseas, they are 

2 importing them under their own brand. 

3 MR. BROOKMAN: And they are assembling 

4 them? 

5 MR. LAU: They are generally already 

6 assembled as far as I know. 

7 MS. PETRILLO-GROH: Is commercial 

8 equipment typically purchased off the shelf? 

9 MR. LAU: We're talking standard PTACs 

10 right? My understanding is that these are -- my 

11 understanding and I welcome data otherwise is that 

12 these are being made sorry, these are imported 

13 products that are being manufactured by overseas 

Page 204 

14 manufacturers. My understanding is that most of the 

15 standard product is. There's a minimum amount of 

16 specification that goes into them, they are sort of 

17 -- there may be some customization of a standard 

18 model. 

19 MS. PETRILLO-GROH: So I guess my 

20 question is what's the difference between a 

21 manufacturer with a production asset and a foreign 

22 manufacturer without production assets? 

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October 29, 2014 

MR. LAD: The differentiation we are 

2 making is a manufacturer that has no capital 

Page 205 

3 investment so as the standard increases they are not 

4 paying for any new tooling, or production line 

5 changes versus manufacturers actually own the tooling 

6 which in that scenario they incur a much higher 

7 capital conversion cost. 

8 MS. PETRILLO-GROH: So a manufacturer 

9 that doesn't own its own tooling isn't essentially 

10 manufacturing these units? 

II MR. LAD: That's correct. 

12 MS. PETRILLO-GROH: So of the 3 

13 manufacturers that do produce these units, almost 90% 

14 of the conversion costs will be borne by them? 

15 MR. LAD: They're the only manufacturer's 

16 capital conversion costs. 

17 MS. PETRILLO-GROH: Do those 3 

18 manufacturers sell to the other 19? 

19 MR. LAD: I don't believe so. 

20 MS. PETRILLO-GROH: Let me think on that 

21 some more and follow up with a question because it 

22 still isn't making sense to me but I don't want to 

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NOPR For PTACs and PTHPs 

October 29, 2014 

take up any more time, thanks. 

MR. BROOKMAN: We were just about to 

3 finish with Regulatory Impact Analysis. 

Page 206 

4 MR. YO: The National Energy Savings and 

5 the Net Present Value for these non-regulatory 

6 alternatives are an output of this analysis and the 

7 impact of non-regulatory alternatives on purchase 

8 price and the use of energy efficient equipment is 

9 also an output and these outputs can be found in 

10 Chapter 17 of the technical support document. 

11 We will summarize what the proposed 

12 standard is. The proposed standard is trial 

13 standard level 2 for packaged terminal 

14 air-conditioners and packaged terminal heat pumps. 

15 On the table you will see for the different equipment 

16 types, equipment classes, the proposed levels. 

17 MR. ROSENSTOCK: Steve Rosenstock, just a 

18 very quick comment. I just want to say I just want 

19 to thank you for keeping the EER's for the PTACs and 

20 the heat pumps the same, I think that will lead to 

21 some economies that scale, that's what ASHRAE's done, 

22 that's what DOE has done with other rules, so I know 

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we are not at the final rule yet, but keeping those 

2 levels the same, I think is a very good -- is the 

3 right way to go in my view, thank you. 

4 MR. BROOKMAN: Okay thanks. 

5 MR. YU: Here is the summary of the 

6 impacts of the amended standards. At TSL2 the 

Page 207 

7 lifetime energy savings -- I'm going to go ahead and 

8 read this off the slide. The lifetime energy 

9 savings for PTACs and PTHPs purchased in the 30-year 

10 period that begins in the year of expected compliance 

11 with the amended standards 2019-2048 amounts to 0.06 

12 quadrillion British thermal units. 

13 The cumulative net present value of total 

14 customer costs and savings of the proposed standards 

15 for PTACs and PTHPs ranges from 10.7 million dollars 

16 at a 7% discount rate to 69 million dollars at a 3% 

17 discount rate. This NPV expresses the estimated 

18 total value of future operating cost savings minus 

19 the estimated increased equipment cost for equipment 

20 purchased in 2019 to 2048. 

21 And the last slide is information as to 

22 how to submit written comments. Should I be the one 

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NOPR For PTACs and PTHPs 

October 29, 2014 

Page 208 

2 MR. BROOKMAN: Just leave that up there 

3 for now. 

4 MR. YU: Okay, I'm sorry, thanks. 

5 MR. ROY: Aniruddh Roy, Goodman 

6 Manufacturing. A question on slide 95, so you say 

7 .06 quads what exactly constitutes significant in 

8 terms of energy you know quads saved, is there a 

9 specific number that DOE has in mind when you make 

10 the determination that .06 over a 30-year period is 

II significant? Because one could argue that even .001 

12 quads might be significant from you know ASHRAE 

13 90.1-2013 so what constitutes a significant in DOE's 

14 books? 

15 MS. BUTLER: Sarah Butler, DOE. 

16 Significant is not defined in the statute. I said 

17 significant is not defined under the statute so we 

18 just have to look at the facts of each individual 

19 circumstance and make a determination according to 

20 the appropriate burden to determine what significant 

21 is. 

22 MR. BROOKMAN: Additional comments? 

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Page 209 

Okay let's take it to that final slide and as we had 

2 promised first thing this morning now is another 

3 opportunity for anybody who wishes to make closing 

4 remarks to raise any additional issues that haven't 

5 been raised sufficiently during the course of the 

6 day. I see yes please, Marshall? 

7 MR. HUNT: Marshall Hunt, PG&E. I have 

8 prepared a little power point presentation I would be 

9 happy to forward it will be in our comments that 

10 covers the 90.1 ASHRAE 90.1 requirement and Title 24, 

II what's the best way of proceeding to get that out to 

12 people? 

13 MR. MAJETTE: Just go ahead and send that 

14 out as a comment. 

15 MR. HUNT: Will others be able to see it 

16 before? 

17 MR. MAJETTE: Yes, we will add it to the 

18 documents, so it will be there to be seen. 

19 MR. HUNT: Okay I'll put that in there so 

20 people can find it. 

21 MR. BROOKMAN: And Marshall it's in the 

22 form of power point slides? 

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NOPR For PTACs and PTHPs 

October 29,2014 

MR. HUNT: Yes. 

MR. BROOKMAN: Okay. 

MR. HUNT: Just to summarize it real 

Page 210 

5 MR. ROSENSTOCK: Steve Rosenstock, EEl. 

6 Just to follow-up it won't be on the docket until the 

7 day after you submit it or so. We won't get to see 

8 it until you submit it and then it gets on 

9 regulations.gov so none of us will be able to see it 

10 that way until it gets closer and then they post it 

II on the you know, on the website. 

12 MR. HUNT: I'll try to get it in next 

13 week. I want to have a little more double-checking 

14 to make sure I'm right so I project next week I'll 

15 get it in there. 

16 MR. BROOKMAN: Okay so yes, Don Brundage? 

17 MR. BRUNDAGE: I don't have a lot of 

18 quantitative information to go with it, but I would 

19 suspect that the setting of standards, that slide 

20 particularly, for the smaller units with the higher 

21 EER is likely to have some potential humidity control 

22 impacts in warm, humid climates. 

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NOPR For PTACs and PTHPs 

October 29,2014 

If you look at, I'm just looking at 

Page211 

comparisons to the air-conditioning -- to the single 

family air-conditioning standard and these numbers 

PTAC under 7,000 Btu/h per hour EER of 12.6, that's 

even higher EER than the 12.2 for smaller equipment 

for California and New Mexico and Nevada and Arizona. 

And that was determined based on analysis there that 

it was not a good idea to do in Southern states 

because of the impact on humidity control. 

Some of these issues would go away if you 

had any incentive to do variable speed operation for 

this type of equipment, but you don't have that with 

EER. Going to variable speed will hurt your EER, 

other things being equal because of the additional 

power usage of the variable speed unit. 

But it would definitely save energy. It 

may be something that's beyond the scope of what you 

can do for this rulemaking but I think it would serve 

the interests of energy efficiency and energy 

conservation in real-life maybe not as much through 

modeling of it if you went to something like an IER 

performance metric for this class of equipment, thank 

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NOPR For PTACs and PTHPs 

October 29,2014 

Page 212 

MR. BROOKMAN: Thank you Marshall? Okay 

so I think that covers the content that we set out to 

cover this morning, I'll turn it back to Ron Majette 

to review this final slide and for my part thank you 

we covered a lot of ground today. 

MR. MAJETTE: I just want to thank 

everybody for corning out. I appreciate the 

interactive role play we had today. And again if 

you have more follow-up questions just go ahead and 

submit those as comments. 

If you send comments directly to my email 

address I'll try my best to answer for the most part, 

it has to be viewed as being a public comment, so 

just make sure that any questions that would be 

beneficial to everybody I would have to place that 

into the docket file, all right. 

So I'm not saying I'm not your buddy, or 

I'm not your friend or anything, you can't call me, 

but make sure the comments that are germane to this 

rulemaking and it's for public use and we will be 

putting those into the docket, thanks. 

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Safe travels, 

Page 213 

(Whereupon the meeting adjourned at 2:46 

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October 29, 2014 

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approach 37: 17 asked 56:20 185:5 60:661:12 

40:6,13 52:2,5,8,9 asking 15: 13 30:3 attributed 147:13 

53:1,2,8,19,20 193:21 August 47: 18 

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approaches 51 :22 aspect 142:8 availability 21 : 17 

approaching 25: 19 assembled 204:6 33:1534:22 

appropriate 12:3 assemblies 33: 12 126:16,20127:7 

208:20 assembling 70:8 149:7158:18 

approved 47:20 204:3 159:4,6 

approves 32: 1 assembly 32:13 available 29:21 

approximated 81:3 70:17 30:1433:2136:22 

approximately 9: 17 assess 51 :22 159: 15 37:156:558:15 

194:2,5 assessment 6: 10 58:20 59:5,8 

April 21:16 188:5 34:11,12,17 51:14 66:15,1585:22 

area 37:12 38:18 161: 15 93:1394:2199:16 

82: 1 0 83: 12 asset 125:15 204:21 100:3,6,7101:5,6 

areas 13:5 103:15 assets 160: 1 166:21 110:3 139:2 

163:3 171:18178:19 160:20 165:2 

argue 146: 18 179:9,10,14,15 185:3 

208: 11 180: 12,19 182:7 average 11:5,755:7 

arguments 50:22 202:2,3 203: 15, 17 74:891:199:5 

Arizona 211:6 204:22 100:10103:17 

Armstrong 2: 10 associated 8: 11 115:22116:1,22 

19:8 22:8 23:5 23:15,1639:13 117:11,12121:9 

24:9,17 25: 1,6 40: 1 52: 19 53:9 121:10123:16 

26:9,1627:13,21 67:1570:3,7,16 125:14128:4,15 

29:430:2032: 15 74:1681:983:13 130:14134:13 

72:4 83:1785:1095:2 137:16141:10,14 

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Ace-Federal Reporters, Inc. 

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158:15 

averages 128: 19 

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139:15150:16 

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177:15181:1 

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143: 1,6 148:3 

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25:2032:1637:17 

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122:18,21 133:18 

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156:5 158:9 

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171:8,10,13 178:3 

184:20 185:7 

192:5 193:12 

197:16201:16 

211:7 

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26:5,8,10,11,14 

28:3 43:9 52: 14 

57:6,1558:461:5 

62: 18 63:4 64:21 

66:474:17,22 

75:8,12,2076:12 

76:1577:17 79:4 

79:5 80:4,5,6,13 

81:11,1485:19,20 

85:2187:11,13,16 

88:3,495:6,7 

96:12,13,16,18 

126:2,3,5151:2,4 

180:13,13 191:21 

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31:1037:1943:9 

43:1260:2109:10 

120:3 139:11 

141:22 156:4 

180:1,16188:4,10 

189:9 

basis 51:19162:13 

166:5 

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beat 109:6 

beginning 141:8 

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59:1671:1772:14 

73:786:1191:22 

92:17 102:5 

110:22 128: 11 

133:3 134:12 

138:6 159:6 

182:18 188:4 

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benefit 37:5 39:13 

157:19190:6 

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195:16 

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202-347-3700 

NOPR For PTACs and PTHPs 

October 29,2014 

129:20130:17,20 brand 203:19 204:2 25:1726:14,22 

131:3,6176:18 break 6: 12 86:5 40:17,18,1842:2 

189:22 190:2,4 88:14,1589:1 44:21,2146:5 

196:4,8 break-in 71:15,16 78:3 79: 1 91: 13 

bent 82:11,14,21 71:17,21 91:13 103:6,6 

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89:8 breaking 168:7 114:1,1,18115:16 

best 146:21 209: 11 176: 11 123:19,19131:11 

212: 13 Brenda 8:20 131:16,18138:22 

better 14:5 39:10 brief6:7,810:17 138:22 139:22,22 

39: 1745:22 53: 12 110: 14 164:14,14192:17 

132: 13 147:6 briefly 80:22 162:8 192:18195:11,11 

164:16178:14 bring 7:3 103:21 197:11,11202:20 

beyond 25:2128:7 167:1 171:19 202:20210:16,17 

86:3 110:6 130:2 bringing 31: 10,14 Btu 48:20 55:9 

211: 17 British 207: 12 56:13,18,2067:3 

big41:143:3116:2 broad 18:2 67:4 72: 11 86:4 

124:20 135: 13 broader 91 : 15,20 88:3,5 

176: 12 132: 13 Btu's 11:5 13:22 

bigger 92:6 broken 166:16 14:1 18:1449:4 

bills 69:22 70: 1,5 183:16,19 55:660:14,19 

143:22 Brookman 2:4 4:2 65:2,1566:3,19 

bin 13 :20,21 ,22 4:75:7 6: 1 9:3 66:2069:374:14 

147: 13 12:1,6,9,1217:15 87:9101:19156:6 

Bingyi 3:3 5:20 19:7 20: 1025:7 156:10,11 164:3 

61:1888:1289:5 34:438:740:3,7 Btu/h 100:22,22 

89:7 186:3 40:11,1644:2 112:7,14113:1,4 

bins 10:1513:16 45:1447:1249:14 113:11 126:9 

14:915:3,14,17 51:259:13,17 127:11130:7 

17:6,19 61:2162:564:8 144:19,19,21 

bit 16:2133:467:9 66:9,2169:14 145:1,3,5,13,13 

80:7 84:8 95:4 71 :2073:2075:21 145:20146:14 

108:16,17109:17 78:1886:487:6 147:3,7148:20,21 

117:9 139:20 88:1389:291:7 211 :4 

152:11 157:16 91:12100:2106:2 bubble 135:10 

164:7 107:17109:15 buddy212:18 

blue 113:17,18 110:13111:12 build 31: 1,4 102:22 

blush 176: 17 115:8,15116:5 138:4 161:11 

board 13:738:14 124:19125:3 build-up 141: 11,12 

153:4169:8170:3 127:8129:15,19 builder 33:12 

bodies 69:12 130:9132:7,19 builder's 33:16 

body 32:1 135:9 136:2 139:6 builders 33:22 

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booklets 119:9 155: 19 158:3,9 101:3,4107:14 

books 45: 1,4208: 14 159:10178:11 110:19,20111:2,5 

borne 183:7 205:14 181:13 186:11 125:18135:13 

bottom 91: 1 189:1 190:9 141:2169:9 

bound 165:16,19 191:10193:18 buildings 29:20 

173:3,4,5,14 194:20196:18 30:12104:9106:8 

174:8,17,19,20 197:10198:7 106:9,13,18138:2 

178:7200:3201:2 201:19204:3 138:8 

boundary 200: 19 206:2207:4208:2 built 137:15 

bounds 58:5 177:3 208:22209:21 bulk56:18156:15 

box45:1571:2,13 210:2,16212:2 157:18202:19 

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Ace-Federal Reporters, Inc. 

Page 216 

142:3 

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186:20,21 187:3,4 

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176:7212:19 

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cap 184:22 

capability 42:8 

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capacities 19:11,17 

51:1752:1255:6 

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56:3,757:260:18 

65:166:272:12 

74:3 101:1 102:3 

112:7 113:2 145:6 

145:14,21 146:13 

capacity 10:16 

13:1214:1015:19 

17:1,5,1918:19 

19:1535:6,21 

48:1449:255:1 

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120:20 126:9 

127:11 130:8 

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146:8,15,17147:4 

147:7158:19,20 

159:7 160:3 

162:20 163:20 

164:9198:11,22 

capital70:6 125: 15 

166:18,19179:7 

180:20185:14 

205:2,7,16 

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178: 14 

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187:17191:16 

192:1 194:1 195:4 

195: 13 202:9 

carbons 50:7 

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118:2,4 128:2 

case 10:21 11:1 

18:2123:1025:10 

41:1950:1 85:12 

104:10121:3 

125:22 126:7,11 

137:6139:16 

142:9,11,12147:2 

147:6148:3151:2 

151:4 165:14 

173:3,4,6,13,18 

174:8175:4190:5 

203: 18 

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193:4194:2 

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202-347-3700 

NOPR For PTACs and PTHPs 

October 29, 2014 

161:9,11 165:7 173:22190:21 circle 158:21 

167:9 changes 22:928:6 circles 113:6 

categories 17:22 30:10,1749:6 circumstance 

18:135:3 130:17 72:5101:11,12,17 208:19 

166: 17 105:21 107:2 circumstances 

category 10: 16 36:9 111:13 112:6 190:21 

67:4,5 187:14198:10,20 clarification 22: 11 

caught 108: 10 198:21 199:10 67:21 78:20 

135: 1 205:5 119:21 

cause 61: 17 changing 114:8 clarify 32: 1244:5 

causing 78:22 131:4 196: 11 61:1863:673:4 

168:22 channeI90:1,7,10 101:19202:4 

CREe's 111:1 90:1394:597:15 clarifying 135:7 

CRECS's 101:4 98:16 201:21203:15 

cell 7:11 channels 89:15 90:2 class 35:10 44:6 

cemented 43:12 90:1792:2293:18 123:18142:14 

Census 89:20 93:12 95:1196:797:12 144:20 145:2,5,9 

115:2121:12,15 99:3,4 147:4 148:20 

cents 156: 11 chapter 29: 12 211:22 

certain 15:17 17:1 70:10150:4,11,12 classes 15:5 34:13 

28:17,18,1947:2 152:22 184: 1 35:3,4,5,12,14,22 

47:3 48:2,2,5,8,9 199:1,13 206:10 51:1752:11 

48:1652:1167:14 character 193:5 144:15147:9 

81:794:7102:5 characteristic 153:2206:16 

102:19109:13 111:2 classification 

140:2 143:2 characteristics 37:2 184:20 

153:17,18163:2,3 101 :4 classify 16:8 

163:3,4 196:9 characterize 89: 14 Clean 188:7,7 

certainly 43:20 124:19126:10 clear 10:940:15 

53:3 77: 16 characterized 67:6 79:21 80: 17 

certification 10:6 117:7 83:1684:8,16 

12:17166:22 charge 49:8 75:5 132:22 175: 12 

185:21 charges 122: 12 195:19 

certified 13:1156:9 chart 65: 14,17, 19 Clearinghouse 

63:18126:12 65:22 67:21 69: 11 93:15 

certify 133:18 91:15116:6 clearly 18: 1231: 18 

cetera 43:2 charted 75: I 135:4 

chain 91:18 charts 116:7 climate 101:9 

chains 125:6 chassis 32:15,21 134: 16 140: 16 

challenge 163:12 83:16,20 climates 131 :22 

challenges 162: 17 check 99:21 100:7 163:15210:22 

chance 180:2 102:4 126:22 close 19:4,449:12 

change 22: 11 36: 1 139:4141:15 141:5 193:7 

42:1146:1383:13 checked 99:20 closer210:10 

98:13102:13 chime 40:4 closing 7:2 209:3 

113: 13 114:20 China 185: 13 clustered 56:13 

119:15120:16,16 choice 33: 16,22 C0250:4 188:8 

123:18124:1 41:7 191:7,14193:2 

149:22 150:2,2 choices 151:15 196:5,9198:1,3 

151:9152:2,5 choose 170:5 Cochran 2:6 5: 17 

153:9167:18 chose 52: 15 119:3 coefficient 60:16 

170:5175:1 Chris 44:2,4 45:8 coffee 88: 19 

179:16190:15,19 172:16174:11 coil 86: I 0 87:4 

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Ace-Federal Reporters, Inc. 

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110:11,12115:16 

132:20 133:7,21 

134:1 142:21 

148:22,22150:13 

150:14154:13 

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175:15183:3 

186:4 201:22 

206:18209:14 

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11:2220:1122:16 

32:834:4 47:13 

51:264:969:14 

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99:9106:2110:15 

116:5 127:4,9 

130:9132:7,10 

135:9 154:6 164:6 

178:8184:9186:8 

186:11 191:11 

207:22208:22 

209:9212:11,12 

212:20 

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44:881:286:8 

121:13 127:4 

137:10148:17 

187:11 199:9,14 

204:7 

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commoditized 

175:17,19 

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31:15123:21 

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125:17 

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76:14 

companies 9: 17 

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5:1140:19103:7 

107:19 123:20 

125:20 139: 1 

164:15195:12 

202:21 

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121:21 

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24:762:2263:1,4 

74:22 75:7 76:4 

77:1485:18,20 

111:16,16140:17 

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192:19198:1 

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comparisons 27: 11 

211 :2 

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competitive 180: 17 

competitors 179:9 

compiled 74:2 

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190:20 191:4 

complex 191:18 

complexity 165: 1 

compliance 23: 16 

24:9,1327:17 

118:18 125:13 

160:5 167:1 

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185:22 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29,2014 

component 70:2 199:15 Consulting 5:20,22 

154:22 conservation 4:20 51:7 

components 157:8 8:159:2111:19 consume 121:14 

com pressor 39: 14 20:2221:322:1 consumer 156:9 

84:3 105:5 145:16 36:5 75: 1786:2 190:4195:15,18 

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compressors 28: I 0 199:20211:20 157:20 170:4 

28:13,16,1937:11 consider 14:6 38:1 consumption 81:8 

37:2138:1,2,12 41:17,1845:19 105:13 121:6 

38:1339:1953:12 49:1057:2183:22 122:1 198:20 

81:1,4,2282:3 84:7105:20177:2 contacted 185:4 

153:18 187:3189:3,16 contained 56: 11 

compromise 46: 14 196: 19 content 134: 12 

compute 62:2 consideration 7:5 161:12212:3 

concentrated 15: 15 38:541:8,14 Context 20: 14 

15:1618:17 55:2072:773:19 contingent 50:20 

concern 10:1977:4 108:18114:2 continuation 119:5 

79:10131:4,8 140: 12 176: 14 continue 138:15 

170:9,10 183:5 198:6203:2 continued 133:8 

concerned 44: 16 considerations continuing 12:15 

94:9 105:15197:15 contract 122:22 

concerning 182:5 considered 10:12 153:17,21 154:1 

concerns 10:2 13:5 34: 18 40:22 42:3 155:2,4,13 

162:9186:12 42:443:11,18 contracting 93:8 

concise 7: 1 0 18:2 46:949:657:2 contractor 71:5 

conclusion 39:5 64:1468:875:20 90:5,693:7,11 

condenser 84:2 95:1996:297:11 contractors 9: 18 

condensing 86: 1 0 100:14105:1 93:10 

conditioner 33: 10 112:10,11,20 contradictory 75:9 

33:19 113:2,4 126:5 82:13 

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121: 14 considering 101: 14 contributing 39: 1 0 

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40:1471:5146:21 14:1876:1679:22 104:15,21106:15 

159:14160:13 137:22 153:4 conversion 162: 1 

200:12 constant 81:4 166:14,17,18,19 

confidential 89: 19 118:18119:4,11 166:21 167:2,8 

93:3 141:16 119:11,12,18,19 168:1,13,22169:4 

confirm 174:8 119:19120:1 169:12171:4,5,13 

confused 40:19 142:19172:8 172:7,15,17,19 

157:20 177:11195:9 173:17 174:12 

confusing 77: 1,3 constitutes 208:7 176:1,5,15,19 

78:8 79:3 80: 11 208: 13 179:7,18 180:20 

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129:14 30:1390:2091:2 201:8205:7,14,16 

Congressman 34:7 91:4,5,1096:5,9 conversions 168: 19 

connection 156: 13 137:3,7,8,12 convert 125:11 

consensus 32: 1 138:14,19139:19 converted 166: 15 

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Ace-Federal Reporters, Inc. 

Page 218 

convincing 84: 16 

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125:22 127:13,16 

127:16,17,19,20 

127:20,21 128:9 

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131:9133:11 

134:11,13 144:8 

144:17145:11,13 

149: 18 150:5 

153:8,11,13 154:4 

162:1,13 165:10 

166:14167:8 

171:4,21172:2,5 

173:7,10174:2,18 

176:19195:4,14 

195:16,18202:22 

203:9205:7 

207:18,19 

costly 88: 1,9 

costs 42:6 50:7 

51:1152:1870:7 

74: 1,15,16,19,20 

77:1379:4,5 

87:12,17 88:3,5 

95:1,18,21,22 

97:598:6100:15 

100:15114:21 

116:16,22117:3 

117:13,15,15 

118:13119:6 

120:11,15,20 

121:1,4122:17,21 

122:21 123:2,3,6 

123:8125:12 

128:18129:20 

142:7 144:8 

149:17153:1,2 

154:5155:15 

161:16162:2,14 

165:9166:2,15,17 

166:18,19,21 

167:1,2,6168:1 

168:13,14,19,22 

169:4,13,19,21 

170:17,20171:4,5 

171 :6,10,12,13,16 

172:7,15,17,17,20 

173:16,17174:12 

174:16176:2,5,15 

176:18179:7,18 

180:7,22183:7 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29,2014 

185:15,19,21,22 current 12:18,19 Damodaran 125:19 

186:1 195:13 21:2128:747:9 dashes 9:6 

201:8202:9 57:10,2258:3,8 data 5:3 10:5 12: 17 

205:14,16207:14 60:20,2161:2,3,7 16:1718:419:9 

Counsel's 5:18 62:10,19,22 63:4 19:2020:3,8,12 

counterintuitive 65:2068:2275:14 21:17 36:22 37:1 

168:10 75:22 76: 1 077:6 55:12,1861:21 

country 132:2 81:15,21140:18 67:768:673:17 

192:20 169:16 89:2192:5,9,21 

country's 193:7 currently 13:2 93:2,1294:21 

couple 127: 13 16:1159:762:16 101:4,9106:10 

152:16177:15 73:6 107:12108:3,4 

190:3 200:8 curve 54:1074:8 111:3,16,17115:1 

course 27:457:8 87: 18 88:7 105: 1 0 118:21119:8 

72:1185:1692:5 curves 40:14 53:14 121:8 122:4 

101:11110:8 54:268:1369:20 123:11126:11,14 

162:7171:15 74:2,5,782:8 126:16127:1 

178:5,20 185:6 87:21 171:4 134: 1 137: 12 

209:5 customer 89: 16 138:13,15139:1 

cover 20:20 44:9,14 90:6,9,11,1495:8 139: 16, 18, 19,20 

64:2095:16212:4 95:10,1597:6 140:8141:7,16 

coverage 20: 19 116:12117:19 142:15,16,18 

33:7 126:6130:19 143:1,4,6145:8 

covered 7:3 21:2 131:12153:21 145:19146:19 

78:4212:6 156:19163:1 147:5,6 148:4,22 

covers 45:10 95:10 173:10196:4,8 149:8 150: 14 

202:6 209: 10 202:17,17203:3 156:5 159:2,3 

212:3 207: 14 164:6170:12 

crazy 138:19 customer's 130:16 171:14201:16 

create 54:9 55:7 customers 94: 1, 18 204:11 

69:1974:8162:17 109:14124:15 database 101:6 

168:19 126:3,4 129:19 143:3 

created 69:22 199:3 130:18,20131:3,6 date 24:3,5,13 

creates 79:16 131:10,13 136:13 25:1227:5,8,10 

creation 40:13 174:13 187:11 107:5110:20 

credible 11: 18 customization 160:5 

credits 202: 17,18 204:17 dates 23:15,16 

203:4,4 customizations 42:18,21,2243:1 

criteria 34:20 36: 16 108: 19 day 6:21,2299:13 

64:18 cut-off 176:21 103:14118:10 

critical42: 1 0 cutter 17:9 209:6210:7 

115:13 124:8 cycle 21 :9 33 :20 days 8:3 20:2,5,7 

Cross 196:22 67:18,1889:10 111:20,20132:1,6 

crowd 107: 11 103:20 105:6 DC 100:21 

crucial94:16 108:18117:16 dead 40:7 

cumulative 29:7,9 144:11 187:15 deadline 24:20 

29:1046:2247:4 Cymba1sky2:9 dea137:7 67: 17 

187:20196:13 15:1,1,13 16:3,19 116:2 

207: 13 18:1524:15,19 dealers 9: 18 

curiosity 120: 13 26:6,6,11,1827:2 decide 25:10 84:21 

curious 15:5 43:11 29:1430:1 decision 92: 14, 17 

63:1,1168:15,17 184: 11 

68:2075:7,15 D decisions 72: 19 

92:15 134:16 D4:1 deck 184:6 

139:8,10 163:8 Dain 2:13 Decker 2: 15 5: 19 

201:6 damage 195:5 37:1439:1740:3 

Ace-Federal Reporters, Inc. 

Page 219 

40:7,951:5,653:1 

53:359:10,20 

67:8,2178:13 

132:21 133:22 

164:7169:19 

Decker's 170: 17 

decline 162: 15 

170: 11 

declines 119:3 

decrease 117: 12 

120:2 

decreased 111:21 

112: 1 

deepI17:21118:11 

defer 58:16120:6 

deferring 130:4 

define 177:7 

defined 33:9 109:21 

176:20208:16,17 

definitely 150:6,10 

178:7188:15 

201:13211:16 

definition 187:1,2 

definitions 34:5 

definitive 44:20 

defrost 103:20 

104:5,16,21 105:6 

105:11 

defrosts 106:11 

degradation 41:5 

degree Ill: 19,20 

132: 1,6 

delta 128:18,18 

demand 30:9 

121:11122:12,13 

201:1 

demands 122: 10 

dense 58: 12 

densities 49: 11 

Department 1: 1 2: 1 

3:14:7,12,155:17 

7:13,198:79:20 

11:1720:15106:4 

189:3 193:18 

196: 19 

dependent 23:18 

24: 11 50:3 

depending 35:20 

98:16192:9 

depends 30:9 42: 19 

depth 136: 17 

derive 51:20 89: 18 

187: 17 

derived 89:22 

167:14 

described 65:2 

866-928-6509 
150:18 

describing 158:19 

description 6:20 

110:19111:5 

design 28:4,6 30: 11 

30:1737:13,20 

38:6,17,1739:3,5 

39:7,9,1440:2 

52:2,2 53 :2, 19 

59: I ,2,4,6 82: 13 

83:2,7,13,1784:6 

86:10,1487:4 

109:5 114:2 

171:19 173:22 

174:4,21,22 

designed 31: 16 

designing 67:18 

designs 30:15 31:5 

82:2086:22 

desk 102:10 

detail 87:5 95:5 

106:3 109: 17 

110:18117:9 

152:19165:6 

detailed I 1:22 

69:22 

details 29:2 55:22 

70:883:7 

determination 6: 14 

208:10,19 

determine 16: 17 

100:10,13117:2 

144:13 145:12 

208:20 

determined 101:2 

116:21118:17 

142:5211 :7 

determining 34: 13 

116: 18 

Detlef2:22 5:22 

34:938:845: 16 

73:1083:21 

Detlers44:1686:7 

develop 53:14 57:5 

121:9136:20 

160:19161:1,8,19 

161:20 162:1 

developed 52:13 

64:1376:20117:1 

121:11 137:9,12 

137:18166:13 

171:13 

developing 167:8 

diameter 49:9 

diameters 49:7 

differ 118:17 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29, 2014 

difference 25:3 47:1972:19 159:7,7 

27:1539:772:16 directions 48: 15 distributors 93:6 

73:1684:1194:3 directly 90:11,13 dive117:21118:11 

96: 14 120: 12 97:6 185:5200: 18 divided 35:5 

127:2 134:7 212:12 divides 35:2 

143:21 152:8 directory 10:6 13:9 dividing 117: II 

153:8157:17 14:1416:8,12 division 121:15 

190:7204:20 56:9,11,1363:18 divisions 121:12 

differences 19:16 68:17126:12 divulge 83:22 

39:849:1058:22 disaggregate docket 8: 17 12: 12 

65:6101:16157:8 142: 13 99:14,19 100:3,4 

157:9 disassemble 69: 17 118:9184:13 

different 10:14 disassembled 69:20 210:6212:17,22 

12:20 15:4,14 disconnect 128:14 document21:10 

18:9,1823:12,17 156: 19 68:5,1269:8 

32:5,9,10,13,14 discontinue 162:20 70:1171:877:1 

32:1835:3,13,19 discoun t 125: 10, II 79:1580:9118:7 

35:2137:18,21,22 125:13,16144:4,7 120:8 135:4 156:8 

43:18,1951:17,22 187:6207:16,17 171:1 183:22 

53:5,6,1056:4,10 discounted 144:2,3 199:1206:10 

63:1574:379:3,5 160:7 documentation 

84:1485:986:16 discrete 19: 15 108:9 

87:3 90:21 95:5 discuss 4: 1440:5 documents 57:20 

97:15105:3 51:7,20109:16 158:6209: 18 

115:20 125:9 Ill: 13 121:4 DOE 2:3,6,7,8,9,10 

127:6130:18 123:9125:10,21 4:205:18,19,19 

134:9 140: 17 136:6,16143:10 8:1310:12,13 

142: 16 143: 14 159:21 11:8,11,1412:18 

147:13154:8,9,21 discussed 57:7 60:8 12:1913:4,17,19 

155:3157:7 69:2 80:21 99:8 15:2,1016:219:1 

174:21 178:6 129:22 142:6 19:1420:4,17 

181:7193:14 144:15 146:3 21:5,8,14,14,17 

200:8201:10 150:20161:13 23:6,725:1426:6 

206: 15 170:14183:22 30:1633:835:2,9 

differential153: 11 199:17 36:1,4,14,18 

differentials 193: 13 discussing 89:9 41:12,1445:19,20 

differentiation 159:13202:13 46:1,947:2,10 

205: I discussion 5: I 12:5 49:1853:2157:12 

differently 134: 15 86:10114:2 57:2058:2,5,17 

135:5178:16 discussions 109: 1 64: 19,20 65:3 

difficult 126:21 distance 113:17,17 66:669:2070:13 

difficulties 79: 16 distinct 179:4 72:1973:13,14,18 

diligence 193: 19 183:12 74:678:1981:3 

dimensional39:8 distinguish 35:13 81:1882:1984:19 

ll2:16 distribute 97:6 86:11,2088:18 

dimensions 35: 15 178:22 185: 12 89:1893:1,14,16 

35:1836:7162:11 distribution 89: 15 94:295:2,9,18 

164: 10 90: 1,2,7, I 0, 13, 17 96:6,12,1797:11 

dioxide 49:21 92:2293:17,18 99:2,5,10100:18 

187:17191:17 94:4,2295:11 101:12105:9,19 

192:1 96:797:1298:16 108:3 109: 19 

direct 8:21 160:2 99:3,3,4 117:8 110:6,10111:5,15 

199:8200: 1 0, 11 123:10,15126:8 111:22112:4,9,15 

200: 17201:3 126:10142:19 112:17,22115:1,5 

directed 33:5 143:5148:3,7,18 116:17,21118:18 

direction 41 : 18 distributions 118:3 119:3 121:7,8,14 

- -

Ace-Federal Reporters, Inc. 

Page 220 

122:17,22123:6 

123:10,11 125:10 

125:14,19126:2,7 

126: 11,13 133:7 

133:12,16136:19 

137:8,15,18 

142:18143:4,16 

143:21 144:4,20 

145:2,5,12,19 

146: I 147: 18 

148:13,22150:18 

160:6176:13,16 

178:15,20179:2 

182:7,16,19 

183:12184:17,19 

185:3,7,13 187:16 

189:14190:10,13 

191:20195:7 

197:16198:16 

199:2,5,16201:7 

202: 14206:22 

208:9,15 

DOE's 19:1244:17 

44:1846:10,19 

47:4 51:19 208:13 

dog 105:11 

doing 26:2027: I 

103:8 104:4 

114:10115:18,22 

118:4131:1 

146:12151:20 

165:1 188:10 

191:2193:18 

194:9197:17 

dollar 150:4177:21 

dollars 166:4,11 

167:7176:6 

179:18195:9 

207:15,16 

domestic 179:2 

180:3 182:20 

202:4 

domestically 

183:10 

don 5: 11 32: 17 

40:16,1842:17 

44:21 46:5 78:20 

81:1391:13103:6 

107:18114:1 

123:19138:22 

139:22164:14 

192:18195:11 

197:10,1l 202:20 

210:16,17 

Donald 2:19 

door45:3 

866-928-6509 
dots 9:6 

dotted 113:6 

double 100:7 

126:22 

double-checking 

210:13 

doubling 168:2 

194:2,5 

doubt 11:15106:17 

Doug 2:4 4:7 

downloaded 12:16 

downstream 51: 19 

53: 15 89: 12 

186: 17 

downward 114: 11 

dramatic 197:7 

dramatically 

196: 11 

draw 60:661:12 

63:10167:4 

drill 39: 11 

driven 137:3 

drops 192:19 

dryable 163:16 

due 86:5 119:4 

169: 16 

dumping 181:16,18 

dynamic 50: 17 

168:19169:6 

E 

E4:1,1136:1,1 

earlier 38:1343:1 

56: 11 57:7 65:2 

73:2296:897:22 

98:5 127:4 129:22 

134:6 142:6 

158: 12 170: 18 

201 :22 

early 22: 1827: 17 

42:15 

easier 67:13 

easy 16:1519:22 

economic 89: 19 

93:1294:17 

116:10,19,21 

126:6140:16 

143:12 

economically 11:9 

85:2 

economics 132:4 

145:18181:11 

economies 206:21 

economy 109:8 

edge 131:9 

Edison 2:215:12 

"o ___ ,''''',_' __ ~ , 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29,2014 

24:1 45:2246:1551:11 EIA 197:20 

Edwards 8:21 51:16,18,2152:1 either 8: 1 37: 18 

EEl 15:1825:463:9 52:4,8,13,14,16 48: 11 70:3 

68:1080:193:21 53:6,8,10,1454:1 either/or 201: 13 

94:696:20102:14 54:2,5,5,10,11,13 EL's 80:4,8,12 

108:20115:10 56:157:1,5,6,16 128: 11 

121:17122:10 57:1858:6,7,11 EL180:4 

127: 12 128: 1 0 59:460:8,9,13,13 EL2 59:20,21 60: 1 

130:11 149:2,10 60:15,1761:9,13 62:463:12 

151:5 156:2 61:14,14,1563:3 EL3 59:22 62:3 

162:22163:14 64:10,13,21,22 63:12 

167:20179:20 65:13,16,2166:6 EL4 127:15128:8 

180:14181:9 66:8,8,14,1667:2 EL5127:15128:8 

187:22188:21 67:5,14 68:3,3,7 elaborate 8: 11 

189:5191:3 196:1 69:2,20 70: 19 electric 2:18,21 3:4 

210:5 72:5 74:2,5,9,13 5:12,1624:134:1 

EER 13: 11 37:3 74:16,1775:1,2,6 121:8198:10,11 

50:9,21,2260:14 76:7,1477:578:5 electricity 33: 17 

63:14,14,1665:16 78:779:1381:1,4 121:9,10198:19 

84: 1,3 114: 11 81:1282:2,8 198:20 

148:6,16149:7 84:1285:11 87:8 eliminated 14:13 

163:3,4,21 164:1 87: 18,21 ,22 88: 1 199:3201:4 

164:18210:21 88:7,9 100: 14,21 eliminates 36:19 

211:4,5,13,13 101:15103:3,3 ELs59:21 115:12 

EER's39:18113:9 107:6,8110:9 115: 12 

206:19 112:6,9,11,18,19 elucidate 82: 19 

EERE-2012-BT 113:3 114:8,15,17 emaiI8:19212:12 

8:17 116:22117:17,18 emission 187: 13 

effect 10:4 29:19 120:13,16123:18 emissions 6: 18, 19 

35:743:7,14 125:21 126:2,4,7 49:21 50:577:8 

75:18 160:4166:1 126:17127:14,17 187:12,15,15,17 

166:9187:8,10 128:4,5,22 129:3 187:21 188:9,17 

188:2,4 193:9 129:5,8143:14 191:11 192:11,12 

effective 23:224:3 144:9,10,10 146:1 194: 1 ,21 195:2,6 

24:525:2127:5 147: 16, 17,19,22 195:8,21 196:12 

27: 10 42: 18,21 148:3,7,9,10,11 196: 17 197:8,18 

131:10133:11 148:15,18149:1 employ 9:17 201:9 

148:1 149:12150:15,17 employed 200:18 

effectiveness 26:2 153:3,6 154:9 employees 184:22 

203: 1,9 155:22159:6 em p10yer 53: 16 

effects 46: 18 79: 17 162:10,17163:5 em p10yment 6: 19 

efficacy 46:2 163:11164:9 160:2 199:2,8,8 

efficiencies 43: 17 166:2171:4 172:6 199:14200:1,9,10 

54: 16, 18 56:4 172:7,9,10174:1 200:10,12,17 

67:22 114:9 174:5175:21 201:3 

126:10146:22 186: 19 192:2,3,5 enabled 54:9 55:7 

175:12 192:9193:11,17 encourage 5:3 7: 19 

efficiency 10: 10 194:17 195:16 7:2068:4133:16 

12:1813:215:9 200:21 202: 18,21 ended 22:1523:19 

15:15 19:1828:18 203:6211:19 155:3 

34:1536:1537:1 efficient 53:11 ends 88: 19 

37:2,4,10,11,17 57:1895:1496:15 energy 1:12:13:1 

37:20,22 38:2,4,6 114:4116:15 4:7,13,15,205:18 

39:4,10,1340:6 123:4 168:14 6:147:148:7,15 

40:13,1441:2,6 181:6191:21 9:21 11:1820:16 

42:9,1643:6 206:8 20:21,2221:3,22 

Ace-Federal Rep0l1ers, Inc. 

Page 221 

23:927:7,9,16 

29:7,935:5,736:5 

36:10,1540:1 

46:751:160:13 

63:3 75: 1777:8 

77:1379:1881:8 

83:384:1385:10 

85: 13 86:3 89:9 

92:19100:8,9,10 

100:11,14103:2,3 

105: 13,20 108:22 

109:22110:1 

111:5,15114:8 

115:5116:3,6,15 

116:16,18,20 

117:1,1121:4,5,6 

121:6,7,7,11,14 

121:16122:1,16 

122:18,18125:21 

136:11143:12,13 

143:17,18,22 

144:9,10,14 

145:18163:17 

172:7187:14,16 

192:8,11,20 193:5 

193:7,22194:7,16 

197:18198:13,14 

198:15 199:6,10 

199:11,14203:7 

203:11,12206:4,8 

207:7,8208:8 

211:16,19,19 

Energy's 9:20 

enforce 108:7 

enforcement 

133: 19 

engineer 18:20 

engineering 6: 1 0 

9:1034:1837:16 

51:4,8,9,13,15 

52:987:20118:15 

144:15146:2 

149:9 150: 19 

161:16167:4 

169:20171:15,19 

engineers 30: 14 

enjoyed 4: 16 

ensure 122:3 

entered 6:3 

entire 52:1255:8 

64:21 128:2 

154: 15 

entirely 23:3 67:6 

entrance 4: 16 

EPA 41:4,20 42:17 

44:647:1,22 

866-928-6509 
189:5,8190:20,22 

197:6 

EPA's 188:7 

EPCA 33:4,9 50:2 

58: 18 84:21 85:7 

equal 11:5 57:21 

61:7,987:12 

110:7142:12 

144:18,19148:20 

148:21211:14 

equation 54:10,12 

60: 1062:3 

equations 35:20 

62:269:1 

equipment6:13 

9:1510:11,14 

21:234:13,22 

35:2,3,6,10,14 

36:942:2044:6,8 

44:1445:2,746:1 

46:1851:12,17 

52: 11 56:2,4 58: 1 

59: 12 60:9,11 

64:2065:1,3,4,7,8 

65:11,1370:8 

71:6,8,974:3 

( 91:2192:2093:20 

94:195:1596:13 

96:1697:14 

101:15 103:9 

105: 12 107:9 

116:13,15117:4 

117:18118:12,14 

119:1,8120:17 

123:5,9,10,13,15 

123:18,22124:1,4 

124:6,12126:3,4 

132:22 133: 1 

139:9 140:2 

142:14143:22 

144:1,14,20145:2 

145:5,9 146: 16 

147:3,9148:14,15 

148:19150:1 

153:2154:5,15,20 

155:1 156:10 

162:14164:21 

166:20 178:22,22 

179:8185:9,12,18 

191:17192:6 

199:10200:19 

204:8206:8,15,16 

207:19,19211:5 

211:12,22 

equity 125:20 

equivalent 61 :6 

~ . 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29, 2014 

139:12155:14 example 28: 10, 14 explicitly 141:17 

179: 19 82:2295:2098:14 explore 29:2 

error 141:15 151:1 172:22 exposed 20:9 

especially 94: 17 193:22 expressed 60: 14 

115: 12 129:22 exceed 66: 17 expresses 207: 17 

163:14189:17 excellent 63:5 extended 122:22 

191:6196:13 exception 84:20 154:1 

essentially 54: 11 190: 14 extensive 86: 11 

97:2198:9105:4 exchange 37: 12 extent 170: 11 

205:9 67: 19 82: 15 86:22 172: 13 175: 17 

establish 147:21 160:21 181:14,16 external 119: 14 

established 21:3 exchanger 38: 18 extrapolated 112:9 

34:535:22 39:1549:782:10 112:17113:1 

establishing 11:18 82:2283:12,18 extrapolation 

estimate 52:3,18 87:4 112:16113:8,10 

53:9,1569:18 exchangers 82: 11 113:21114:5 

70:2,6,13 73:22 86:16145:17 extrapolations 

89:1699:2123:13 exclusively 18: 13 145:19 

126:6136:8,12,18 excuse 12:10 

143:11147:18 113:14115:3 F 

161:4167:9195:1 117:22 128:7 F 136: 1 

198:10199:3 129:5143:18 fabricating 70:3,7 

estimated 54:6,13 149:17 face 162:3179:10 

125:14,16166:15 exemption 107:16 181 :20 

167:6,18178:13 exercise 16:15 20:1 faced 153:20 

190:2207:17,19 existent 103:21 facilities 11: 13 

estimates 74:21 existing21:635:9 109:2203:20 

87:16136:10 36:2137:22137:1 fact 16:919:13 

166: 14 167:2,8,13 139:2 30:1147:9111:19 

167:15195:8 exists 16:12 116:6152:11 

estimation 70:9 expect 22: 17 180:21 190:1 197:15 

et 43:2 185: 14 factor23:1150:6 

evaluate 37:2 58: 19 expected 143:4 54:16131:11 

159:19160:6 148:1 176:5179:7 176:16 

evaluated 28:5 179:11,16207:10 factored 47:5 186:1 

37:2138:1272:10 expects 142:18 201:17 

evaluates 178: 15 expended 109:22 factors 33:4 98:15 

evaluating 37:4 110:2 103:11 106:12 

evaluation 116: 11 expenditures 144: 1 119:14128:3 

199:7 199: 11 187:17192:12 

everybody 4: 11,15 expenses 95: 1 0, 16 facts 190:13,15,18 

5:39:1155:14 95:17165:11,11 208: 18 

212:8,16 expensive 133: 15 failed 137:5 

evidence 84: 17 153:19 fails 137:2 

evident 81:5 experience 4: 17 failure 140:3 

exact 29:5 49: I 179:12,16185:16 fair22:19 168:9 

110:20111:6 experienced 123: 12 fairly 19:2222:10 

194:9 experiences 32:20 138:16 

exactly 17:21 49:2 experiencing falling 162: 14 

82: 19 84:2,3 129:20 falls 177: 19 

128:4 172:3 expertise 32: 17 familiar 53:19 

176:10183:19 explain 22:22 53: I 88:16106:20 

192:8208:7 112: 16 family 140:6 211:3 

examine 51 :9 56:20 explanation 173:20 fan 37:11,12 38:4,5 

161:9 explanations 38:1739:9,14 

examined 56:8 167:21 43:6,1553:12 

Ace-Federal Reporters, Inc. 

Page 222 

82:1283:2109:21 

110:1145:16 

far 29: 11 32: 17 

43:20 157: 10 

204:6 

fast 42:4 

faster 88:9 

favor 85:7 

favorable 168:22 

183:9 

feasibility 34:20 

feasible 14:6 52:15 

85:2 

features 35:7,8 

65:12 

February 21:8 

federal28:7 31: 14 

57: 1 0,22 58:3,9 

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NOPR For PTACs and PTHPs 

October 29,2014 

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NOPR For PTACs and PTHPs 

October 29,2014 

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202-347-3700 

NOPR ForPTACs and PTHPs 

October 29, 2014 

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NOPR For PTACs and PTHPs 

October 29, 2014 

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165:21 166:8 

175:22 177:6,20 

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maintaining 162:10 

164:10 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29,2014 

maintenance manufacturer's marked 119:3 

122:20 123:6 45:389:1795:19 markers 65: 17 66:5 

144:8 149: 18,20 96: 12, 15 123:4 market 6:9 15:7 

149:20,21 145:12171:12 18:1220:829:16 

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4:125:198:13,13 manufacturers 34:12,1436:10 

20:15,1533:2 9:1412:1616:4 51:1452:13,16 

49:1650:1,13,16 16:10,1218:11,16 55:856:2,7,15 

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44:8 52:7 124: 12 159:16,18160:1,4 marketplace 59:7 

190:7 160:7,12,14,17 153:15 

making 13:6 30:8 161:3,7162:3,7,8 markets 89:22 

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173:11,12205:2 166:3,7,10167:3 96:3,12,1497:1 

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mandatory 199:20 177:5,20178:4,16 165:18167:8,15 

203:5,12 178:19,20,21 167:16169:21 

manner 104:2 179: 1,3,4,6,13,15 171:11177:14 

manual 108:9 180:1,3,19182:6 markups 89:4,9,13 

manuals 105:3 182:9,11,20183:8 89:1992:2293:1 

manufacturability 183:9 184: 19 93:4,7,11 95:5,6,7 

34:21 185:5,9,18,18 95:7,9,1696:6,18 

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74:22 181: 12 202:2,5203:15,17 118:16,16145:11 

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185:12204:13 205: 18 Marshall 2:18 5:15 

manufacturer 6: 17 manufactures 12:1322:5,5 

16:1717:4 18:5 180:11 61:22 62: 1 67:20 

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56:1965:583:3 2:125:1311:13 107:13 110:16 

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170:20 171 :6,9, 1 0 177:11,16,17,19 MATS 188:1,18 

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29:10,1632:17 

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11:1 128:15 

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26:20,22 122:7 

methodology 51:8 

70:989:18100:18 

866-928-6509 
116:17136:19 

143:16 195:3 

198:12199:5 

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methods 73:9 

metric 160:10 

195:9211:22 

metrics 195:14 

Mexico 211:6 

MIA 159:14,15 

160:2,13,18 

161:20162:5 

166:14 

mic 12:5 

microphone 5:9 

mid-morning 6: 12 

middle 135:1 

million 167:7173:5 

176:5,9,9,10 

179:18 196:5,6 

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28:757:9,10,12 

57:22 58:3 60:20 

60:2161:862:16 

65:2075:1481:21 

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minimums31:14 

62:10203:12 

minor 31:5 72:4 

minus 62:4207: 18 

minute88:1589:1 

minutes 88:20,22 

135:11,17 

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118:22 

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157:1 180:8 

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109:22 110:2 

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125:15 126:16,20 

127:6 136:20,22 

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159:4,5160:8,8,9 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29, 2014 

160:15 161:9,11 33:351:3,4 61:20 necessarily 14: I 0 

161:22162:1 69:1573:778:18 39:11 131:19 

165:7,13 167:9 87:6,20 95:4 necessary 110: 14 

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199:6 204: 18 moving 6:9 36:13 30:17 55:15 66:11 

modeled 123: 15 72:773:12100:8 78:21 82:22 

165:14 114:11,13,19 105:15108:13 

modeling 187: 16 134:22 159: 10 114:16131:20,20 

198:15211:21 165:4186:14 135:12,15140:15 

models 13:9,13 Moyer 66:9 150:7181:6 

14:13,1519:6 multi-site 109:14 needs 8:1413:4 

38:3 53:21 56: II multiple 109:2 46:947:1181:18 

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63:17 66:14,15,19 multiplied 137: II 142:15 197:21 

143:5 162:20 multiplier 81 :4,5,7 198:2203:10 

163:20164:11 82:5 165:8 negative 11:6,8 

185:21 multiply 97:20 42:8151:9,10,15 

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Monetization 6: 18 named21:7 Neither 129:2 

191:12194:22 nation 51:1 NEMS 192: 18,20 

195:21 national 3:3 5:21 193:4 198:15 

monetized 197:9 6:1753:1689:8 nervous 118:3 

money 30:2 89:1190:1291:16 net 129:20130:16 

monitored 42: II 91:17 92:6 93:16 130: 19,20 131 :3,6 

Monte 116:20 93:2094:10,12 136:13 143:20 

117:5118:1,4 95: I ,2 96:22 97:8 144:13 151:7,13 

128:2 97:10,13 100:17 152:16156:17,21 

month's25:1 108:21 109:13 156:21 160:10 

monthly III: 19 114:22,22 115:3,6 167:10 170:6 

months 122:4,4 136:3,7,10,11 172:20193:16 

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morning 4:2, II 6:3 144:12,14145:22 207:13 

9:951:689:6 152:17 156:1 Nevada 211 :6 

209:2212:4 187:16198:13,15 never 97:14 189:18 

motel 102:11 106:8 199:4,11,19 new 20: 1223:2,6 

motel's 18:10 202: 14206:4 29:1930:13,15 

motels 102: 17 nationally 199:4 36:542:2043:13 

104:11,22132:11 natural 196:21 45:248:1571:12 

motor 38:5 43: 17 nature 22: II 65:4 90:2091:2,4,5,10 

43:21 140:1 96:5,8102:19 

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53:12145:16 5:2240:944:4 138:13,18139:19 

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nomenclature 

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nominal 119:19 

non-applicable 

62:19 

non-production 

165:10 

non-regulatory 

199:19202:16 

203:2206:5,7 

non-standard 35: 17 

36:6,7,892:13,18 

nonsensical 116:4 

noon 6:16 

NOPR 1:210:10 

22:1534:342:17 

68:5 72:2,15,22 

73:1,3,1180:9 

127:4 133:7 

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200:3 

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noticed 10: 13 

NOX 197:3 

NPV 152:2,6 

207: 17 

NPV's 181:22 

nuance 178:15 

number6:58:6,17 

8:1845:15,15 

56:1271:199:2 

99:19102:8 

103:18125:1 

129:21 130:22 

138:8139:2141:3 

142:22150:14 

176:12182:1 

866-928-6509 
186:4 190:6 191:7 

192:1 199:3208:9 

numbering61:10 

numbers 27:2249: 1 

77:12,2279:2 

85:1091:14110:3 

115:12,14116:3 

121:19124:16 

127:14157:4 

177:2 189:22 

191:8193:14 

196:6,8 197:4 

202:9211:3 

0 

04:1 136:1,1,1 

obligated 57: 12 

observation 175:16 

observe 7:5 65:5 

82:3 

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56:1257:1959:12 

63:1870:13,17 

87:21 

obtain 15:11 16:1 

92:21 106:10 

114:16125:13 

145:8 

obtained 93:14 94:4 

117:11,14,16 

121:6123:1,7,8 

126:11 167:3 

171:15 

obvious 88:2 

obviously 19: 16 

23:730:10,17 

133:10 189:17 

occupancy 95:20 

102:18103:17 

104:13,22106:11 

occur 124:17 

140:21 192:16 

197:19198:1,4 

occurs 34: 19 125:2 

ocean 192: 19 

October 1 :5 4:5 

21:5,1224:2 

OEM 105:3 

OEM's 105:2 

office5:18125:18 

190: 17 

offset 78: 11 105: 14 

oh 22:4 61:4 62:4 

97:14194:15 

okay 8:219:1,7 

12:1,8,915:13 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29, 2014 

18:1519:720:11 147:20 148: 13 185:13,17201:5 

20:1331:732:21 164:20211:11 201:11 204:1,13 

33:234:2,5,6 operations 104:6 overstated 94: 1 0 

37: 1939:6,12 147:20164:18 overstating 94:13 

40:1644:149:14 opportunities 41:2 overview 20:18 

50:1351:355:10 opportunity 6:6 7: 1 ozone 197:3 

55:2060:2,5 62:4 9:1911:21 80:20 

64:869:1671:11 209:3 P 

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73:2078:284:4 130:3 p.m 213:3 

86:2197:15,16 option 52:2,353:2 Pacific 2:18 5:16 

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107: 17 108:5 83:17 165:2 packaged 1 :2,34:4 

109:15111:13 173:22 174:2 4:5,218:16,16 

114:18 116:7 options 10: 1228:4 9:2210:1 11:19 

120:9,18122:9 29:332:1934:15 21:1,133:10,18 

125:3 127:8 36:13,15,18,19 33:19206:13,14 

132:19133:4 37:7,838:639:3,5 packet 6:2 8:7 

139:6 142:2 143:7 40:253:2259:4,6 page45:18 

147:15150:10 80:2181:19,20,22 pages 79:14 

163:13 165:4 84:686:14174:4 paid 155:4 

186:13190:9 174:21 197:9 paperwork 25 :20 

191:10,14194:20 orange 13:1314:8 parameters 35: 12 

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208:4209:1,19 162:3171:19 part 30:3,4 36:9 

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once 23:629:237:8 original 178:22 112:22113:10 

40:5,1278:13 185:8,17 131:7159:14 

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open 5: I 118:9 112:3 118:2,6 particular 20:8 

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operate 203:8 206:9 132:17163:21 

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105:21 117:3,13 outsourcing 180: 16 party 71:573:14,15 

117:13,15125:11 outweigh 158:14 123: 1 

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167:14176:1 133:16 178:12 passed 141:16 

177:10,18186:21 186:1 197:13 

195:14,17207:18 overhead 70:7 path 82:16174:22 

operation 96: 11 overseas 11:14 pathway 83: 1 

109:22 110:2 179:1 180:7 pattern 39:3 170:4 

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112:15143:16 

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148:13 199:2,16 

201:8202:7 

performing 145:22 

147:2 

period 10:20,22 

11:1 15:1216:2 

22:1524:525:15 

28:1945:10,11 

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117:11 119:1,2 

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144:22 145:4,7 

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189:11 198:14 

201:18207:10 

208:10 

permanent 43 :21 

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persistence 106: 1 0 

125:5 

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person 7: 17 

perspective 116: 11 

persuade 15: 1 0 

persuasive 31 :21 

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39:21 52:22,22 

53:1858:14,21 

59:1562:8,12,21 

67:173:475:4,16 

77:3,18 78:2 

79:1083:9,10 

84:985:6,16 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29,2014 

90:18,1992:8 108: 10 188: 10 

99:12,20100:1 plan 44:20188:7,8 possible41:542:12 

102:4 105:17 plans 189:9 181 :3 

106:19107:21 plant 187:15 195:2 possibly 43:3 

126:15 127:3 plants 188:9 post 210: 10 

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138:21 138:3,6140:1,14 140:7 

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103:19107:13 176:7,11 177:1 precarious 46:21 

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11:314:2,1118:8 

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.. ~ 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29,2014 

39: 11 44:7 56:9 172:14201:18 providing 50:21 

63: 18 90:4 94:9 projecting 22:2 provision 190:14 

102:7121:5 140:4 24:21 143:18 provisions 35:10 

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166:17,21 171:19 141:8142:19 108:3 190: 16 

175:19,19181:7,8 188: 11 proxy 126:20 

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52: 18 54:7 69: 18 188: 1 72: 1 0 133:9,18 

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145:11 160:1 promise 186:15 35:1337:4 48:20 

161:16165:9 promised 209:2 51:1152:1255:8 

166:2168:13 promising 28: 11 56:2,7 57:22 60:8 

169:19,21 170:17 proof 84: 14 85:9 61:862:3,10,19 

170:20171:6,10 106:1 67:2,7,1470:15 

171:12172:2 propane 48:21 71:674:9,18 

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203:15,17204:21 proposal41: 16 158:8,14 160:4 

204:22205:4 48:19189:19 179:3 184:18 

products 11:7,13 proposed 1:2 4:3 185:1187:9211:4 

12:1914:716:11 6:219:21 10:4,8 PTAC's 10:21,22 

16:11,13 19:13 12:1813:10,12,14 11:4,1548:13 

27:1029:2130:13 14:3,816:13 92: 15 

36:1137:18,21 21:1522:1026:2 PTACs 1:34:21 

39:6,1946:8 41:3,2044:6,9,13 10:713:2,8,11,14 

55:13,1673:7 47:1659:1166:17 14:1615:1517:13 

94:7,15,19,22 71:273:3129:16 17:1819:321:4,6 

133:18162:10 159:16,19164:12 21:13,16,19,22 

164:9167:1 167:7,17189:15 23:228:933:8 

168: 14 170:6 190:12191:9 36:6,1541:21 

175:15 181:18 206:11,12,16 44:1046:248:4 

204:1,13 207:14 57:10,11 58:9 

profile 160:20 proposing 4:21 59:1560:1,12,22 

profit 93:4 95: 1 0 11:833:835:9 61:2,3,6,13,15 

96:197:1 165:12 36:1,473:12 62:15,1763:2 

165:18166:4,7,11 183:15 64:1065:2167:12 

167:14168:4 proprietary 83:8 75:8,1491:14,17 

173:11,12175:10 87:1 91:2092:11,12 

175:17 176:1 prospect 177:5 100:11,13101:1 

177:11,21178:1 protocol45:2 104:10106:8 

profitability 162: 15 prove 23:8 108:1 109:18 

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program 198: 17 20:4 50: 13 55 :22 121: 13 125: 17 

programs 203:7,12 99:10116:10 126:9128:1,22 

progress 88:21 125:5 132:18 129:11131:21 

137:21 164:16170:12 136:20139:3 

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25:16122:18 114:15118:8,15 185:9187:21 

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. ~'~'-

Ace-Federal Reporters, Inc. 

Page 231 

PTHP 8:1431:20 

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202-347-3700 

NOPR For PTACs and PTHPs 

October 29, 2014 

33:338:1039:17 ratings 16:9 178:4 

58:22 61:19 64:9 ratio 60:14 receiving 129:20 

103:1 107:11,19 ratioing 115:18,22 recession 139:10,21 

127:13 155:20 rationale 179:5 recessionary 

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Page 232 

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866-928-6509 
remake 140: 1 

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represented 75: 12 

representing 9: 13 

56:1065:17130:7 

represents 21 :21 

33:4 34:2 57:18 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29, 2014 

74:987:8 165: 16 147:11152:18 59: 1 0, 10, 14,16,22 

165:18174:19 156:1179:13 60:4,662:11,14 

request 41 :21 187:8,19193:20 63:5,1664:3,12 

110:11186:4 195:20198:12 68:1,4,21 69:13 

requesting 108:3 resume 88:20 69:1671:4,14,17 

requests 46: 1 143:4 retrofit 42:20 71:2273:2175:11 

148:22 return 135:10 75:1976:978:16 

requirel0:814:17 returning 6: 16 87:7 133:3,22,22 

104:1 107:14 revenue 168:18 rise 168:14 

required 24:16 26:7 revenues 168:21 rising 172:13,14 

43:1947:1,2,22 172:13,14 robustness 104:18 

70:1786:2102:16 reverse 33:20 52:9 104:19 

102:18103:1,4,8 67:17 role 43:347:17 

103:10105:7,18 reversing 67:16 212:9 

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requiring 14: 15 rifle 86: 12 48:13103:13 

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resistant 105:5 54:22 55:2 71:2 Rosenstack 127:12 

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result 68:6 157:7 184:11,17188:22 101:18,18102:14 

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5:28:159:21 

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10:2013:121:9 

21:1522:125:21 

26:1536:441:19 

43:444:946:9 

52:6,757:9,20 

72:1877:779:12 

81:11,1484:12,15 

85:1,486:9,19 

92:10101:22 

102:2109:18 

112:8,10,12,15,20 

113:3,5123:12 

129:21 130:3 

131:13,19132:5 

134:2137:13 

148:17 160:5 

165:1 185:15 

190:19191:2 

202:7211:18 

212:21 

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28:1641:8,12 

47:8,1052:681:3 

81:782:783:11 

86:1887:3151:16 

198:6 

rules 7:6 131 :2,5 

133:2189:15 

190:12191:5 

196:15 197:7,17 

197:20 206:22 

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93:15146:15 

162:15 170:10 

sample 126:8 

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58: 17 84: 1 0, 19 

190:9,10208:15 

satisfaction 106: 17 

saturation 137: 11 

138:4,18 

save211:16 

saved 208:8 

saves 51:1 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29,2014 

saving 85:12 screening 6: 10 117:7 

savings 11:6 23:9 28:2034:11,16,19 selected 10: 13 

27:7,9,1628:18 36:14,1737:7 52: 1 0 54:4 56:6 

29:7,936:10,20 51:1480:2281:6 56:1457:1558:5 

40: 1 50:762:22 screens 34: 17 58:7 64:20,22 

77:8,1378:10 scroll 170:21 65:8,10,1866:1 

79:7,1882:21 searching 99: 12 70:22 150: 15 

83:484:1393:19 second 43:590:7 178:3 

94:4,13 100:15,15 95:12101:15 selecting 50:6 64: 19 

105:21 117:13,16 112:13,22113:10 sell 205: 18 

136:11,14143:12 116:19120:9 selling 89: 1795:8 

143:17,18,22 142:3 146:9 95:14,17,2096:1 

144:14156:9,16 148:13 159:17 96:13,15 123:4 

156:20157:11,22 161:1 162:12 145: 12 154:7 

158:1,14163:17 163:19175:3 165:10168:12,15 

192:8,12,16193:1 section 33:9 103:22 169:4,16,22 170:2 

193:2,22194:8,16 104:1 171:9,12,21 172:2 

198:1,3,13,14 sector 196:11 199:6 172:5,9 175:2 

199:12206:4 199:14 send 8:20,21 209: 13 

207:7,9,14,18 secured 135:16 212: 12 

saw 81:288:6201:9 Securities 160:21 sense 15:2 142: 1 

saying 25:22 31:8 security 135: 14 153:5205:22 

37:1939:663:13 see4:8 12:2 13:20 sensitivity 188: 11 

72:21 96:22 14:1,822:2,12,17 191:6197:6 

113:16,21119:11 23:1527:1429:18 sensors 102: 18 

119:22 120:2 38:21 54:458:7 106: 11 

122:2,11 141:21 62:4,1865:22 separable 33:14 

151:12156:4 66:11 67:368:12 separate 33: 11 

174:20,21 180:15 74:477:1378:21 84:16132:2171:6 

180:18191:4 79: 13,20 80: 17 171:21 187:6 

201:13212:18 82:2 86:22 87: 14 separately 109:20 

says 126:12131:1 88:22 89:3 90: 1 179:6 

135:4 156: 14 90:1597:3 108:16 September 24:3,4 

163: 1 200:20 111:10113:7 24:18 

scale 109:9115:2 123:20 124:2 serious 47: 11 

157:11206:21 126:22 133:20 serve 51:18211:18 

scaled 145:11,14 135: 16 144:7 serves 200:2 

146: 12 148:6 147:1 167:5,17 service 34:21 

149:6 154:4,5,6 173:2176:4177:2 125:18 

scaling 114:7 180:10,22 183:1 set 26: 1 42: 1 046:21 

see 195:8,9 184:5186:16 51:1652:1353:14 

scenario 140: 17 187:19189:21 57:569:481 :3 

147:21 148:2,8 190:3,5191:14 141:3142:18 

153:10 165:16,18 192:10,22201:1 152:18162:6 

165:21 166:1,7,9 206: 15 209:6,15 165:7,17,19 

167:15,17169:1 210:7,9 166:14184:22 

177:17,18,22 seeing 39:22 63:2 203:13212:3 

178:2205:6 130:13 156:20 setback 106: 11 

scenarios 161:21 168:11,17 108:2 

165:8,15 167:9 seen 9: 1 17:3 52:6 setbacks 102:15,16 

177:4,15178:3 148:19190:6 102:18 

schedule 22: 1 189:9 196:7209:18 sets 35:3165:13 

scope20:1833:7 segment 20: 11 setting 11:11 81:11 

81:14211:17 95: 11 162:19210:19 

screen 24:14 82:8 segments 89: 16 severe 11 :11 14:20 

screened 37:9 select 64:1565:3 165:17,19 

Ace-Federal Reporters, Inc. 

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127: 1 136:20 

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161:17168:17 

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shipments 6: 17 

15:3,9,1930:4 

55:956:1874:6 

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136:6,8,9,11,14 

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137:8,14,17139:9 

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116:13 117:10 

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situation 14:5 

140: 18 

size 10:1513:16,20 

13 :20,22 14:9 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29,2014 

15:3,4,14,17 185:14,16,20 106:21 124:22 

16:2217:1918:9 186:4,6,20,22 141:7152:11 

18:12,13,1619:3 187:1,3,9193:6 176:13 182:21 

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49:2,768:18 sociaI50:7195:4,12 91:14,15,20104:9 

114:4 130: 18 202:9 104:12138:17 

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34:2 35: 11 36:3 4:8 specify 150:4 

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127:9 146:5 134:21 138:10 164:19211:11,13 

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159:21 165:5 93:2,10125:19 202:14,15 

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Ace-Federal Reporters, Inc. 

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115:9,10119:10 

119:17120:18 

121:17 122:9 

127:12128:10 

130:10,11 134:6 

139:7149:2,10 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29,2014 

151:5156:2157:3 subtract 173:17 surviving 124:4 

162:21 163:13 subtracting 117: 17 suspect 115:19 

167:20 179:20 suddenly 174:6 124:5210:19 

180:14181:9 sufficiently 7:3 swath 56:15 

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stressing 196: 1 0 supplementary 86:5 87: 1 096:21 

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135:16152:19 supposed 71:20 72:2080:2088:15 

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159:20,22178:15 102:17 103:7 taken 53:289:1 

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40:1642:1344:1 

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59: I 760:5 64:6 

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68:969:5,16 

202-347-3700 

NOPR For PTACs and PTHPs 

October 29, 2014 

73:2178:1580:16 47:7,10,16,18,19 101:5,7103:21 

85:1687:789:6 48:3,11,12,19 111:18116:14 

91:1297:1798:21 50:1051:4 55:11 119:1,2186:15 

100:1 105:16 55:13,1458:21 190:13,18192:15 

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125:3 128:20 81:10,1882:18 27:8 

129: 13 130:5 83:1684:4,17 times 80:1598:8 

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159:9163:14 108:15 110:13 TMY3111:16 

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152:20155:17 189:2192:13,14 64:469:12 

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theoretically 154:7 212:3 116:1,12,21 

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108:2 162: 16 183:7192:19 

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thing 19:920: 19 134:19171:7 198:18,21207:13 

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202-347-3700 

NOPR For PTACs and PTHPs 

October 29, 2014 

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202-347-3700 

NOPR For PT ACs and PTHPs 

October 29,2014 

wishes 6:7 99:2 108:8,17116:16 158:19186:15 

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202-347-3700 

NOPR For PTACs and PTHPs 

October 29, 2014 

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866-928-6509 
CERTIFICATE OF COURT REPORTER 

I, GAYNELL T. CATHERINE, Court Reporter, do hereby 

certify that the testimony contained herein is a true record 

of the testimony given by said witness, and I further certify 

that I am neither attorney nor counsel for, related to, or 

employed by any of the parties to the action in which this 

statement is taken; and, further, that I am not a relative or 

an employee of any attorney or counsel employed by the 

parties hereto, or financially interested in the action. 

241