-41L-t-16

March 29, 1996

Mr. Juan Aroix

Avanti Products

8885 NW 23rd Street

Miami, FL 33172

Dear Mr. Aroix:

Thank you for attending the Department of Energy's Appliance Standards

Process Improvement Workshop held on March 19-20, 1996. Your

participation provided useful information to better develop the improved

process for setting appliance energy conservation standards.

Enclosed for your review are the flip chart notes taken during the plenary

sessions and small group discussions. In April, we will be sending you a draft

report detailing the Department's proposal. It will address our goals and

objectives, and how we plan to initiate the new process.

A copy of the transcript of the workshop is available for inspection at the

Department of Energy's Freedom of Information Reading Room, Forrestal

Building, Room 1E-190, Washington D.C. 20585-0121, between the hours of

9:00 a. m. and 4:00 p.m.

If you have any further comments, please send them to Deborah E. Miller in

my office at the U.S. Department of Energy, EE-1, 1000 Independence Avenue,

S.W., Washington, D.C. 20585-0121, facsimile (202) 586-9260. If you have

any questions, please contact Bryan Berringer at (202) 586-0371 or facsimile

(202) 586-4617.

Sincerely,

Christine A. Ervin

Assistant Secretary

Energy Efficiency and Renewable Energy

Enclosure

 EE-PI-96-001 COMMENT 21

Mr. Juan Aroix 

A vanti Products 

8885 NW 23rd Street 

Miami, FL 33172 

Dear Mr. Aroix: 

March 29, 1996 

Thank you for attending the Department of Energy's Appliance Standards 

Process Improvement Workshop held on March 19-20, 1996. Your 

participation provided useful information to better develop the improved 

process for setting appliance energy conservation standards. 

Enclosed for your review are the flip chart notes taken during the plenary 

sessions and small group discussions. In April, we will be sending you a draft 

report detailing the Department's proposal. It will address our goals and 

objectives, and how we plan to initiate the new process. 

A copy of the transcript of the workshop is available for inspection at the 

Department of Energy's Freedom of Information Reading Room, Forrestal 

Building, Room lE-190, Washington D.C. 20585-0121, between the hours of 

9:00 a.m. and 4:00 p.m. 

If you have any further comments, please send them to Deborah E. Miller in 

my office at the U.S. Department of Energy, EE-l, 1000 Independence Avenue, 

S.W., Washington, D.C. 20585-0121, facsimile (202) 586-9260. If you have 

any questions, please contact Bryan Berringer at (202) 586-0371 or facsimile 

(202) 586-4617. 

Enclosure 

Sincerely, 

Christine A. Ervin 

Assistant Secretary 

Energy Efficiency and Renewable Energy 
April 1, 1996

Mr. Phil Hopkinson

Director, Engineering

Square D Company

P.O. Box 500

1809 Airport Road

Monroe, NC 28110

Dear Mr. Hopkinson:

Thank you for your interest in the Department of Energy's Appliance Standards

Process Improvement effort. Enclosed for your review are the flip chart notes

taken during the plenary sessions and small group discussions from the

workshop held on March 19-20, 1996. In April, we will be sending you a draft

report detailing the Department's proposal. It will address our goals and

objectives, and how we plan to initiate the new process.

A copy of the transcript of the workshop is available for inspection at the

Department of Energy's Freedom of Information Reading Room, Forrestal

Building, Room 1E-190, Washington D.C. 20585-0121, between the hours of

9:00 a.m. and 4:00 p.m.

If you have any further comments, please send them to Deborah E. Miller in

.my office at the U.S. Department of Energy, EE-1, 1000 Independence Avenue,

S.W., Washington, D.C. 20585-0121, facsimile (202) 586-9260. If you have

any questions, please contact Bryan Beiringer at (202) 586-0371 or facsimile

(202) 586-4617.

Sincerely,

Christine A. Ervin

Assistant Secretary

Energy Efficiency and Renewable Energy

Enclosure

 EE-PI-96-001 COMMENT 21

Mr. Phil Hopkinson 

Director, Engineering 

Square D Company 

P.O. Box 500 

1809 Airport Road 

Monroe, NC 28110 

Dear Mr. Hopkinson: 

April 1, 1996 

Thank you for your interest in the Department of Energy's Appliance Standards 

Process Improvement effort. Enclosed for your review are the flip chart notes 

taken during the plenary sessions and small group discussions from the 

workshop held on March 19-20, 1996. In April, we will be sending you a draft 

report detailing the Department's proposal. It wi1l address our goals and 

objectives, and how we plan to initiate the new process. 

A copy of the transcript of the workshop is available for inspection at the 

Department of Energy's Freedom of Information Reading Room, Forrestal 

Building, Room 1E-190, Washington D.C. 20585-0121, between the hours of 

9:00 a.m. and 4:00 p.m. 

, If you have any further comments, please send them to Deborah E. Miller in 

my office at the U.S. Department of Energy, EE-l, 1000 Independence Avenue, 

S.W., Washington, D.C. 20585-0121, facsimile (202) 586-9260. If you have 

any questions, please contact Bryan BelTinger at (202) 586-0371 or facsimile 

(202) 586-4617. 

Enclosure 

Sincerely, 

Christine A. Ervin 

Assistant Secretary 

Energy Efficiency and Renewable Energy 
APPLIANCE STAQNDARDS PROCESS

IMPROVEMENT WORKSHOP

MARCH 19-20, 1996

Mr. Juan Aroix

Avanti Products

8885 NW 23rd Street

Miami, FL 33172

Mr. Vince Anderson

Director, Environmental Programs

Whirlpool Corp.

5401 U.S. Highway 41 North

Evansville, Indiana 47727-0001

Mr. Sayed "Aziz" Azimi

Assistant Vice President

Energetics

7164 Gateway Drive

Columbia, MD 21046

Mr. L. Dan Barzel

Senior National Buyer

Circuit City Stores, Inc.

9950 Maryland Drive

Richmond, VA 23233-1464

Mr. Tim Begoske

Effikal International Inc.

143 Northpointe Drive

Orion, MI 48359

Mr. Timothy A. Bernadowski, Sr.

Virginia Power

701 East Cary Street

8th Floor

Richmond, VA 23219

ATTENDEES AND PEOPLE WHO REQUESTED

INFORMATION

3/26/96

Mr. Ron Anderson

Maytag

1801 Monmouth Blvd.

Galesburg , IL 61401

Mr. Ted W. Atkins

Vice President

Industry Relations & Government Affairs

5711 R. S. Boreham Jr. Street

Fort Smith, AR 72902-2400

Ms. Donna Banks

American Gas Association

1515 Wilson Boulevard

Arlington, VA 22209

Mr. Floyd E. Barwig

Pacific Northwest National Laboratory

Battelle Boulevard

P.O. Box 999

Richland, WA 99352

Mr. Kathleen B. Billy

Pennsylvania Power and Light Company

Two North Ninth Street

Allentown, PA 18101-1179

Mr. Peter A. Bleasby

Director, Industry Relations & Standards

OSRAM Sylvania Inc.

100 Endicott Street

Danvers, MA 01923

 EE-PI-96-001 COMMENT 21

APPLIANCE STAQNDARDS PROCESS 

IMPROVEMENT WORKSHOP 

MARCH 19-20, 1996 

MI. Juan Aroix 

A vanti Products 

8885 NW 23rd Street 

Miami, FL 33172 

MI. Vince Anderson 

Director, Environmental Programs 

Whirlpool Corp. 

5401 U.S. Highway 41 North 

Evansville, Indiana 47727-0001 

Mr. Sayed "Aziz" Azimi 

Assistant Vice President 

Energetics 

7164 Gateway Drive 

Columbia, MD 21046 

Mr. L. Dan Barzel 

Senior National Buyer 

Circuit City Stores, Inc. 

9950 Maryland Drive 

Richmond, VA 23233-1464 

Mr. Tim Begoske 

Effikal International Inc. 

143 Northpointe Drive 

Orion, MI 48359 

Mr. Timothy A. Bernadowski, Sr. 

Virginia Power 

701 East Cary Street 

8th Floor 

Richmond, VA 23219 

ATTENDEES AND PEOPLE WHO REQUESTED 

INFORMATION 

3/26/96 

MI. Ron Anderson 

May tag 

1801 Monmouth Blvd. 

Galesburg, IL 61401 

MI. Ted W. Atkins 

Vice President 

Industry Relations & Government Affairs 

5711 R. S. Boreham JI. Street 

Fort Smith, AR 72902-2400 

Ms. Donna Banks 

American Gas Association 

1515 Wilson Boulevard 

Arlington, VA 22209 

Mr. Floyd E. Barwig 

Pacific Northwest National Laboratory 

Battelle Boulevard 

P.O. Box 999 

Richland, W A 99352 

Mr. Kathleen B. Billy 

Pennsylvania Power and Light Company 

Two North Ninth Street 

Allentown, PA 18101-1179 

Mr. Peter A. Bleasby 

Director, Industry Relations & Standards 

OSRAM Sylvania Inc. ' 

100 Endicott Street 

Danvers, MA 01923 
Mr. John C. Bock

President/CEO

Bock Water Heaters, Inc.

110 S. Dickinson Street

Madison, WI 53703

Mr. Donald M. Brundage, P.E. ,

Southern Company Services, Inc.

64 Perimeter Center East

Atlanta, Georgia 30346-6401.

Mr. Matthew J. Chadderdon

Carrier Corporation

P.O. Box 4808

Syracuse, NY 13221

Mr. Gary L. Clark

Carrier Corporation

P.O. Box 70

7310 West Morris Street

Indianapolis, IN 46231

Mr. Lake Coulson

Manager, Government Affairs

National Electric Manufacturers Association

1300 North 17th St., Suite 1847

Rosslyn, VA 22209

Ms. Joy Weis Daniel

Sharp Electronics Corporation

Sharp Plaza

Mahwah, NJ 07430-2135

Mr. Daniel J. Dempsey

Carrier Corporation

P.O. Box 70

Indianapolis, IN 46206

Mr. Paul M. Brodie

Pacific Gas and Electric Company

Mail Code T16A

P.O. Box 770000

San Francisco, CA 94177

Mr. Glenn E. Camus

Manager, Technical Market Development

Consolidated Natural Gas Co.

625 Liberty Avenue

Pittsburgh, PA 15222-3199

Mr. Terry L. Chapp

Modine Heat Transfer, Inc.

1500 DeKoven Avenue

Racine, WI 53403-2552

Mr. John Cockburn

Natural Resources Canada

Energy Demand Branch

580 Booth, 18th Floor

Ottawa, Ontario

K1A OE4

Mr. Jim Crawford

American Standard Inc.

2020 14th Street, N.

Arlington, VA 22201

Mr. Henry DeLima

DeLima Associates

6723 Whittier Avenue

Suite L6

McLean, VA 22101

Mr. Terry G. DuBois

U.S. Department of Energy

EE-422, Rm. 5E-098/FOR

Washington, DC 20585

 EE-PI-96-001 COMMENT 21

Mr. John C. Bock 

President/CEO 

Bock Water Heaters, Inc. 

110 S. Dickinson Street 

Madison, WI 53703 

Mr. Donald M. Brundage, P.E .. 

Southern Company Services, Inc. 

64 Perimeter Center East 

Atlanta, Georgia 30346-6401 

Mr. Matthew J. Chadderdon 

Carrier Corporation 

P.O. Box 4808 

Syracuse, NY l3221 

Mr. Gary L. Clark 

Carrier Corporation 

P.O. Box 70 

7310 West Morris Street 

Indianapolis, IN 46231 

Mr. Lake Coulson 

Manager, Government Affairs 

National Electric Manufacturers Association 

l300 North 17th St., Suite 1847 

Rosslyn, VA 22209 

Ms. Joy Weis Daniel 

Sharp Electronics Corporation 

Sharp Plaza 

Mahwah, NJ 07430-2l35 

Mr. Daniel J. Dempsey 

Canier Corporation 

P.O. Box 70 

Indianapolis, IN 46206 

Mr. Paul M. Brodie 

Pacific Gas and Electric Company 

Mail Code T16A 

P.o. Box 770000 

San Francisco, CA 94177 

Mr. Glenn E. Camus 

Manager, Technical Market Development 

Consolidated Natural Gas Co. 

625 Liberty Avenue 

Pittsburgh, PA ] 5222-3199 

Mr. Terry L. Chapp 

Modine Heat Transfer, Inc. 

1500 De Koven Avenue 

Racine, WI 53403-2552 

Mr. John Cockburn 

Natural Resources Canada 

Energy Demand Branch 

580 Booth, 18th Floor 

Ottawa, Ontario 

KIA OE4 

Mr. Jim Crawford 

American Standard Inc. 

2020 14th Street, N. 

Arlington, V A 22201 

Mr. Henry DeLima 

DeLima Associates 

6723 Whittier Avenue 

Suite L6 

McLean, VA 22101 

Mr. Terry G. DuBois 

U.S. Department of Energy 

EE-422, Rm. 5E-098/FOR 

Washington, DC 20585 
Mr. Tom Eckman

Northwest Power Planning Council

Suite 1100

851 S.W. Sixth Avenue

Portland, OR 97204-1348

Mr. Timothy' Feldman

Vice President, Government Affairs

National Electrical Manufacturers Association

1300 North 17th Street, Suite 1847

Rosslyn, VA 22209

Mr. Howard 1. Forman

Albidale-Windmill Circle

P.O. Box 66

Huntingdon Valley, PA 19006

Mr. Christopher J. Freitas

U.S. Department of Enrgy

FE-32, Room 3E-028

Forrestal Building

Washington, DC 20585

Mr. James H. Gazda

International Approval Services

8501 E. Pleasant Valley Road

Cleveland, OH 44131-5575

Mr. David B. Goldstein

Natural Resources Defense Council

71 Stevenson Street

San Francisco , CA 94105

Ms. Linda W. Greiner

White Consolidated

1317 F Street, NW, Suite 350

Washington, DC 20004

Mr. Thomas A. Farkas

Edison Electric Institute

701 Pennsylvania Avenue, NW

Washington, DC 20004-2696

Mr. Gene Foley

The Alliance to Save Energy

1725 K Street, N.W.

Suite 509

Washington, DC 20006-1401

Ms. Lisa Frantzis

Arthur D. Little, Inc.

Acorn Park

Cambridge, Massachusetts 02140-2390

Mr. John Gaughan

Bracy, Williams and Company

601 Thirteenth Street, N.W., Suite 510 South

Washington, DC 20005

Mr. Howard Geller

American Council for an Energy-Efficient Economy

1001 Connecticut Ave., N.W.

Washington, DC 20036

Mr. Keith M. Grahl

Rheem Manufacturing Co.

Air Conditioning Division

5600 Old Greenwood Road

Fort Smith, AR 72917-7010

Mr. Wilbur L. Haag, Jr.

Application Engineer

A.O. Smith Water Products Company

U.S. Hwy 1 North, P.O. Box 600

McBee, South Carolina 29101

 EE-PI-96-001 COMMENT 21

Mr. Tom Eckman 

Northwest Power Planning Council 

Suite 1100 

851 S.W. Sixth Avenue 

Portland, OR 97204-1348 

Mr. Timothy' Feldman 

Vice President, Government Affairs 

National Electrical Manufacturers Association 

1300 North 17th Street, Suite 1847 

Rosslyn, VA 22209 

Mr. Howard 1. Forman. 

Albidale-Windmill Circle 

P.O. Box 66 

Huntingdon Valley, PA 19006 

Mr. Christopher J. Freitas 

U.S. Department of Enrgy 

FE-32, Room 3E-028 

Forrestal Building 

Washington, DC 20585' 

Mr. James H. Gazda 

International Approval Services 

8501 E. Pleasant Valley Road 

Cleveland,OH 44131-5575 

Mr. David B. Goldstein 

Natural Resources Defense Council 

71 Stevenson Street 

San Francisco, CA 94105 

Ms. Linda W. Greiner 

White Consolidated 

1317 F Street, NW, Suite 350 

Washington, DC 20004 

Mr. Thomas A. Farkas 

Edison Electric Institute 

70l Pennsylvania Avenue, NW 

Washington, DC 20004-2696 

Mr. Gene Foley 

The Alliance to Save Energy 

1725 K Street, N.W. 

Suite 509 

Washington, DC 20006-1401 

Ms. Lisa Frantzis 

Arthur D. Little, Inc. 

Acorn Park 

Cambridge, Massachusetts 02140-2390 

Mr. John Gaughan 

Bracy, Williams and Company 

601 Thirteenth Street, N.W., Suite 510 South 

Washington, DC 20005 

Mr. Howard Geller 

American Council for an Energy-Efficient Economy 

1001 Connecticut Ave., N.W. 

Washington, DC 20036 

Mr. Keith M. Grahl 

Rheem Manufacturing Co. 

Air Conditioning Division 

5600 Old Greenwood Road 

Fort Smith, AR 72917-7010 

Mr. Wilbur L. Haag, Jr. 

Application Engineer 

A.O. Smith Water Products Company 

U.S. Hwy 1 North, P.O. Box 600 

McBee, South Carolina 29101 
Mr. David C. Haataja

Manager, Governmental Affairs

Underwriters Laboratories Inc.

Suite 230

818 18th Street, NW

Washington, DC 20006-3513

Mr. Robert J. Hemphill

Principal Product Manager

Gas Research Institute

8600 West Bryn Mawr Ave.

Chicago, IL 60631-3562

Mr. Robert L. Holding

Association of Home Appliance Manufacturers

20 North Wacker Drive

Suite 1500

Chicago, IL 60606

Mr. Douglass C. Horstman

Maytag

1310 G Street, NW

Suite 720

Washington, DC 20005

Mr. Thomas O. Johnson

Energy Standards Engineer

GE Appliance

Refrigeration Technology

AP5-2NN

Louisville, KY 40225

Mr. Bertram Kalisch

American Gas Association

1515 Wilson Blvd

Arlington, VA 22209

Mr. Robert B. Latta

Mathematical Statistician

DOE, Energy Information Administration

1000 Independence Ave, S.W.

Washington, DC 20585

Mr. Harold W. Heiss

American Electric Power

Marketing Department

1 Riverside Plaza

Columbus, OH 43215-2373

Mr. James E. Hill

National Institute of Standards and Technology

Building 226, Room B-306

Gaithersburg, MD 20899

Mr. John W. Holt

Manager, Fuels and Transportation

National Rural Electric Coop. Assoc.

4301 Wilson Boulevard, GR/EEP11-253

Arlington, VA 22203-1860

Mr. Daryl L. Hosler

Codes & Standards Manager

Southern California Gas Company

Box 3249, ML25A11

Los Angeles, CA 90051-1249

Mr. Earl F. Jones, Senior Counsel

Government & Industry Relations

General Electric Company

Appliance Park, AP1-310

Louisville, KY 40225

Ms. Pamela Lam

Lever Brothers Company

45 River Road

Edgewater, NJ 07020

Mr. David F. Lewis

Lennox Industries,-Inc.

P.O. Box 799900

Dallas, TX 75379-9900

 EE-PI-96-001 COMMENT 21

Mr. David C. Haataja 

Manager, Governmental Affairs 

Underwriters Laboratories Inc. 

Suite 230 

818 18th Street, NW 

Washington, DC 20006-3513 

Mr. Robert J. Hemphill 

Principal Product Manager 

Gas Research Institute 

8600 West Bryn Mawr Ave. 

Chicago,IL 60631-3562 

Mr. Robert L. Holding 

Association of Home Appliance Manufacturers 

20 North Wacker Drive 

Suite 1500 

Chicago, IL 60606 

Mr. Douglass C. Horstman 

May tag 

1310 G Street, NW 

Suite 720 

Washington, bc 20005 

Mr. Thomas O. Johnson 

Energy Standards Engineer 

GE Appliance 

Refrigeration Technology 

AP5-2NN 

Louisville, KY 40225 

Mr. Bertram Kalisch 

American Gas Association 

1515 Wilson Blvd 

Arlington, VA 22209 

Mr. Robert B. Latta 

Mathematical Statistician 

DOE, Energy Information Administration 

1000 Independence Ave, S.W. 

Washington, DC 20585 

Mr. Harold W. Heiss 

American Electric Power 

Marketing Department 

1 Riverside Plaza 

Columbus, OH 43215-2373 

Mr. James E. Hill 

National Institute of Standards and Technology 

Building 226, Room B-306 

Gaithersburg, MD 20899 

Mr. John W. Holt 

Manager, Fuels and Transportation 

National Rural Electric Coop. Assoc. 

4301 Wilson Boulevard,GRIEEPll-253 

Arlington, VA 22203-1860 

Mr. Daryl L. Hosler 

Codes & Standards Manager 

Southern California Gas Company 

Box 3249, ML25Ali 

Los Angeles, CA 90051-1249 

Mr. Earl F. Jones, Senior Counsel 

Government & Industry Relations 

General Electric Company 

Appliance Park, APl-31O 

Louisville, KY 40225 

Ms. Pamela Lam 

Lever Brothers Company 

45 River Road 

Edgewater, NJ 07020 

Mr. David F. Lewis 

Lennox Industries,· Inc. 

P.O. Box 799900 

Dallas, TX 75379-9900 
Mr. Alexander T. Lim

Vice President, Engineering

Inter-City Products Corp.

651 Heil-Quaker Ave.

P.O. Box 128

Lewisburg, TN 37091

Mr. Bob Ludke

Office of Senator Harkin

531 Hart Office Building

Washington, DC 20510

Mr. Steven M. Madara

York International

P.O. Box 4022

Elyria, Ohio 44036

Mr. R. Michael Martin

Codes and Standards Coordinator

California Energy Commission

1516 9th St., MS-42

Sacramento, CA 95814-5512

Mr. Edward J. McInerney

Purchasing, Technology & Manufacturing

General Electric Company

Applaince park, AP3-215D

Louisville, KY 40225

Mr. Mark S. Menzer

Air-Conditioning & Refrigeration Institute

4301 North Fairfax Drive

Suite 425

Arlington, VA 22203

Ms. Sharon E. Miner

Legislative Correspondent

Office of Senator Binghaman

703 Hart Building

Washington, DC 20510

Mr. Peter B. Logsdon

Allied Signal Inc.

20 Peabody Street

Buffalo, NY 14210

Mr. Mo Madani

Energy and Radon Programs

State of Florida

Department of Community Affairs

2740 Centerview Drive

Tallahassee, FL 32399-2100

Mr. Philip J. Manthei

Senior Mgr., Washer Engineering

Speed Queen Company

Shepard Street, P.O. Box 990

Ripon, WI 54971-0990

Mr. Joseph M. Mattingly

Gas Appliance Manufacturers Association, Inc.

1901 North Moore Street

Arlington , VA 22209

Mr. Roy Meacham

American Metal Products

8601 Hacks Cross Road

Olive Branch, MS 38654

Mr. James G. Mills

Federal Trade Commission

Bureau of Consumer Protection

601 Pennsylvania Avenue, NW

Washington, DC 20580

Mr. Robert W. Murray

V.P., Communications Investor Relations

MagneTek, Inc.

26 Century Blvd., 37214

P.O. Box 2901.59

Nashville, TN 37229-0159

 EE-PI-96-001 COMMENT 21

Mr. Alexander T. Lim 

Vice President, Engineering 

Inter-City Products Corp. 

651 Heil-Quaker Ave. 

P.O. Box 128 

Lewisburg, TN 37091 

Mr. Bob Ludke 

Office of Senator Harkin 

531 Hart Office Building 

Washington, DC 20510 

Mr. Steven M. Madara 

York International 

P.O. Box 4022 

Elyria, Ohio 44036 

Mr. R. Michael Martin 

Codes and Standards Coordinator 

California Energy Commission 

1516 9th St., MS-42 

Sacramento, CA 95814-5512 

Mr. Edward J. McInerney 

Purchasing, Technology & Manufacturing 

General Electric Company 

Applaince park, AP3-215D 

Louisville, KY 40225 

Mr. Mark S. Menzer 

Air-Conditioning & Refrigeration Institute 

4301 North Fairfax Drive 

Suite 425 

Arlington, V A 22203 

Ms. Sharon E. Miner 

Legislative Correspondent 

Office of Senator Binghaman 

703 Hart Building 

Washington, DC 205lO 

Mr. Peter B. Logsdon 

Allied Signal Inc. 

20 Peabody Street 

Buffalo, NY 142lO 

Mr. Mo Madani 

Energy and Radon Programs 

State of Florida 

Department of Community Affairs 

2740 Centerview Drive 

Tallahassee, FL 32399-2lO0 

Mr. Philip J. Manthei 

Senior Mgr., Washer Engineering 

Speed Queen Company 

Shepard Street, P.O. Box 990 

Ripon, WI 54971-0990 

Mr. Joseph M. Mattingly 

Gas Appliance Manufacturers Association, Inc. 

1901 North Moore Street 

Arlington, VA 22209 

Mr. Roy Meacham 

American Metal Products 

8601 Hacks Cross Road 

Olive Branch, MS 38654 

Mr. James G. Mills 

Federal Trade Commission 

Bureau of Consumer Protection 

601 Pennsylvania Avenue, NW 

Washington, DC 20580 

Mr. Robert W. Murray 

V.P., Communications Investor Relations 

MagneTek, Inc. 

26 Century Blvd., 37214 

P.O. Box 290159 

Nashville, TN 37229-0159 
Mr. Wayne M. Myrick

Sharp Electronics Corporation

Sharp Plaza (Box 13)

Mahwah, NJ 07430-2135

Ms. Shirley J. Neff

Staff Economist

Committee on Energy & Natural Resources

United States Senate

364 Dirksen Building

Washington, DC 20510

Mr. Edward R. Osann

American Council for an Energy-Efficient Economy

1001 Connecticut Ave., NW, Suite 801

Washington, DC 20036

Mr. Mark W. Paquette

Inchcape Testing Services

ETL Testing Laboratories

3933 U.S. Route 11

P.O. Box 2040

Cortland, NY 13045-0950

Mr. Mark L. Perlis

Dickstein, Shapiro & Morin, L.L.P.

2101 L Street, NW

Washington, D.C. 20037-1526

Mr. Kyle Pitsor

Industry Director

National Electrical Manufacturers Association

1300 N 17th Street, Suite 1847

Rosslyn, VA 22209

Mr. William B. Prendergast

Vice President, Government Affairs

Air-Conditioning & Refrigeration Institute

4301 North Fairfax Drive, Suite 425

Arlington, VA 22203

Mr. Steven M. Nadel

Deputy Director

American Council for an Energy-Efficient Economy

1001 Connecticut Ave., NW

Washington, DC 20036

Mr. David Nemtzow

Alliance to Save Energy

1725 K Street, NW

Washington, DC 20006

Mr. Darrell Paul

Battelle

505 King Avenue

Columbus, OH 43201-2693

Mr. Bob Peitz

Carrier Corporation

P.O. Box 70 (46206)

7310 West Morris Street

Indianapolis, Indiana 46231

Mr. Mikel D. Pistole

Effikal International Inc.

143 Northpointe Drive

Orion, MI 48359

Mr. Bob Poole

Duke Power

EC12L

526 S. Church Street

P.O. Box 1006

Charlotte, NC 28201-1006

Mr. Jerry J. Prideaux

Valmont Electric, Inc.

1770 Commerce Park Dr.

El Passo, TX 79912

 EE-PI-96-001 COMMENT 21

Mr. Wayne M. Myrick 

Sharp Electronics Corporation 

Sharp Plaza (Box 13) 

Mahwah, NJ 07430-2135 

Ms. Shirley 1. Neff 

Staff Economist 

COlmnittee on Energy & Natural Resources 

United States Senate 

364 Dirksen Building 

Washington, DC 20510 

Mr. Edward R. Osann 

American Council for an Energy-Efficient Economy 

1001 Connecticut Ave., NW, Suite 801 

Washington, DC 20036 

Mr. Mark W. Paquette 

Inchcape Testing Services 

ETL Testing Laboratories 

3933 U.S. Route 11 

P.O. Box 2040 

Cortland, NY 13045-0950 

Mr. Mark L. Pedis 

Dickstein, Shapiro & Morin, L.L.P. 

2101 L Street, NW 

Washington, D.C. 20037-1526 

Mr. Kyle Pitsor 

Industry Director 

National Electrical Manufacturers Association 

1300 N 17th Street, Suite 1847 

Rosslyn, VA 22209 

Mr. William B. Prendergast 

Vice President, Government Affairs 

Air-Conditioning & Refrigeration Institute 

4301 North Fairfax Drive, Suite 425 

Arlington, VA 22203 

Mr. Steven M. Nadel 

Deputy Director 

American Council for an Energy-Efficient Economy 

1001 Connecticut Ave., NW 

Washington, DC 20036 

Mr. David Nemtzow 

Alliance to Save Energy 

1725 K Street, NW 

Washington, DC 20006 

Mr. Darrell Paul 

Battelle 

505 King Avenue 

Columbus, OH 43201-2693 

Mr. Bob Peitz 

Carrier Corporation 

P.O. Box 70 (46206) 

7310 West Morris Street 

Indianapolis, Indiana 46231 

Mr. Mikel D. Pistole 

Effikal International Inc. 

143 Northpointe Drive 

Orion, MI 48359 

Mr. Bob PQole 

Duke Power 

EC12L 

, 526 S. Church Street 

P.O. Box 1006 

Charlotte, NC 28201-1006 

Mr. Jerry 1. Prideaux 

Valmont Electric, Inc. 

1770 Commerce Park Dr. 

El Passo, TX 79912 
Mr. Bill Prindle

Alliance to Save Energy

1725 K Street, NW, Suite 509

Washington, DC 20006

Mr. W. A. (Buzz) Reed

Vice President, Chief Engineer

U-Line Corporation

8900 N. 55th Street, P.O. Box 23220

Milwaukee, WI 53223

Mr. Edward A. Reid, Jr.

Vice President Marketing

Columbia Gas Distribution Companies

200 Civic Center Drive

P.O. Box 117

Columbus, OH 43216-0117

Mr. Doug Ringger

Maytag

One Dependability Square

Newton, Iowa 50208

Mr. Michael Rutherford ,

Gas Technology Information

1331 Pennsylvania Ave., NW

Suite 730 North

Washington, DC 20004

Mr. Glenn R. Schleede

President

Energy Market & Policy Analysis, Inc.

P.O. Box 3875

Reston, VA 22090-3875

Mr. Bill Shahin

State Industries

500 Bypass Road

Ashland City, TN 37015

Mr. James A. Ranfone

American Gas Association

1515 Wilson Blvd

Arlington, VA 22209

Mr. Wayne Reedy

Vice President Engineering

Nordyne

1801 Park 270 Drive

Box 46911

St. Louis, MO 63146-6911

Mr. John O. Richardson

Tennessee Valley Authority

1101 Market Street, WR5H

Chattanooga, Tennessee 37402-2801

Mr. Michael C. Rivest

Arthur D. Little, Inc.

955 L'Enfant Plaza SW, Suite 4200

Washington, DC 20024-2119

Mr. Charles A. Samuels

Government Relations Counsel

Association of Home Appliance Manufacturers

701 Pennsylvania Ave., NW, Suite 900

Washington, DC 20004

Mr. Michael Schultz

Honeywell Home & Building Controls

1985 Douglas Drive N.

Minneapolis, Minnesota 55422

Mr. Jack Sharrow

Vice President

Cascade Conservation

3972 150th Avenue, NE

Redmond, WA 98052

 EE-PI-96-001 COMMENT 21

Mr. Bill Prindle 

Alliance to Save Energy 

1725 K Street, NW, Suite 509 

Washington, DC 20006 

Mr. W. A. ( Buzz) Reed 

Vice President, Chief Engineer 

U -Line Corporation 

8900 N. 55th Street, P.O. Box 23220 

Milwaukee, WI 53223 

Mr. Edward A. Reid, Jr. 

Vice President Marketing 

Columbia Gas Distribution Companies 

200 Civic Center Drive 

P.O. Box 117 

Columbus,OH 43216-0117 

Mr. Doug Ringger 

May tag 

One Dependability Square 

Newton, Iowa 50208 

Mr. Michael Rutherford , 

Gas Technology Information 

1331 Pennsylvania Ave., NW 

Suite 730 North 

Washington, DC 20004 

Mr. Glenn R. Schleede 

President 

Energy Market & Policy Analysis, Inc. 

P.O. Box 3875 

Reston, VA 22090-3875 

Mr. BillS hahin 

State Industries 

500 Bypass Road 

Ashland City, TN 37015 

Mr. James A. Ranfone 

American Gas Association 

1515 Wilson Blvd 

Arlington, VA 22209 

Mr. Wayne Reedy 

Vice President Engineering 

Nordyne 

1801 Park 270 Drive 

Box 46911 

St. Louis, MO 63146-6911 

Mr. John O. Richardson 

Tennessee Valley Authority 

11 0 I Market Street, WR5H 

Chattanooga, Tennessee 37402-2801 

Mr. Michael C. Rivest 

Arthur D. Little, Inc. 

955 L'Enfant Plaza SW, Suite 4200 

Washington, DC 20024-2119 

Mr. Charles A. Samuels 

Government Relations Counsel 

Association of Home Appliance Manufacturers 

701 Pennsylvania Ave., NW, Suite 900 

Washington, DC 20004 

Mr. Michael Schultz 

Honeywell Home & Building Controls 

1985 Douglas Drive N. 

Minneapolis, Minnesota 55422 

Mr. Jack Sharrow 

Vice President 

Cascade Conservation 

3972 150th Avenue, NE 

Redmond, W A 98052 
Mr. Alan C. Shedd

D.W. Abrams & Associates

1720 Peachtree Road, Suite 584

Atlanta, GA 30309

Mr. Mark V. Stanga

Vice President Government Affairs

York International Corporation

1725 Jefferson Davis Highway

Crystal Square Two, Suite 204A

Arlington, VA 22202

Mr. Charles Stephens

.Oregon Department of Energy

Policy & Planning Division

625 Marion St., NE

Salem, Oregon 97310

Mr. Richard E. Stillwell

Maytag

One Dependability Square

Newton, Iowa 50208

Mr. Charles A. Straub

Manager, Application Engineering Motors

Marathon Electric Manufacturing Corporation

P.O. Box 8003

100 East Randolph Street

Wausau, WI 54402-8003

Mr. Michael C. Thompson

Director, Government Relations

Whirlpool Corporation

701 Main St. (9025)

St. Joseph, MI 49085

Mr. Stephen J. Treado

Project Leader, Lighting Group

Room A313, Building 226

National Institute of Standards and Technology

Gaithersburg, MD 20899

Mr. Tim Shellenberger

American Water Heater Group

1100 E. Fairview Avenue

Johnson City, TN 37605

Mr. Michael A. Stein

MagneTek, Inc.

40 Alize Drive

Kinnelon, NJ 07405

Ms. Joan E. Sterling

Inchcape Inc.

9900 Main St., Suite 500

Fairfax, VA 22031

Mr. Irving E. Stine

DIC Tool/Hytron

114 Poplar Street

Meadville, PA 16335

Mr. Lou Sullivan

Carrier Corporation

P.O. Box 70

7310 West Morris Street

Indianapolis, IN 46231

Mr. Richard F. Topping, P.E.

Arthur D. Little, Inc.

20-529 Acorn Park

Cambridge, MA 02140-2390

Mr. Otto Z. Vago

State Industries, Inc.

500 By Pass Road

Ashland City, TN 37015-1299

 EE-PI-96-001 COMMENT 21

Mr. Alan C. Shedd 

D.W. Abrams & Associates 

1720 Peachtree Road, Suite 584 

Atlanta, GA 30309 

Mr. Mark V. Stanga 

Vice President Government Affairs 

York International Corporation 

1725 Jefferson Davis Highway 

Crystal Square Two, Suite 204A 

Arlington, VA 22202 

Mr. Charles Stephens 

_ Oregon Department of Energy 

Polic'y & Planning Division 

625 Marion St., NE 

Salem, Oregon 97310 

Mr. Richard E. Stillwell 

May tag 

One Dependability Square 

Newton, Iowa 50208 

Mr. Charles A. Straub 

Manager, Application Engineering Motors 

Marathon Electric Manufacturing Corporation 

P.O. Box 8003 

100 East Randolph Street 

Wausau, WI 54402-8003 

Mr. Michael C. Thompson 

Director, Government Relations 

Whirlpool Corporation 

701 Main St. (9025) 

St. Joseph, MI 49085 

Mr. Stephen J. Treado 

Project Leader, Lighting Group 

Room A313, Building 226 

National Institute of Standards and Technology 

Gaithersburg, MD 20899 

Mr. Tim Shellenberger 

American Water Heater Group 

1100 E. Fairview Avenue 

Johnson City, TN 37605 

Mr. Michael A. Stein 

MagneTek, Inc. 

40 Alize Drive 

Kinnelon, NJ 07405 

Ms. Joan E. Sterling 

Inchcape Inc. 

9900 Main St., Suite 500 

Fairfax, VA 22031 

Mr. Irving E. Stine 

DIC Tool/Hytron . 

114 Poplar Street 

Meadville, PA 16335 

Mr. Lou Sullivan 

CalTier Corporation 

P.O. Box 70 

7310 West Morris Street 

Indianapolis, IN 46231 

Mr. Richard F. Topping, P.E. 

Arthur D. Little, Inc. 

20-529 Acorn Park 

Cambridge, MA 02140-2390 

Mr. Otto Z. Vago 

State Industries, Inc. 

500 By Pass Road 

Ashland City, TN 37015-1299 
Mr. James F. Vaughn Jr.

Vaughn Manufacturing Corporation

386 Elm Street

Salisbury, Massachusetts 01952-5431

Mr. William F. Walters

Carrier Corporation

Carrier Parkway, A&R Building

P.O. Box 4808

Syracuse, NY 13221

Ms. Carol Werner

Energy & Climate Program Director

Environmental and Energy Study Institute

122 C Street, NW, Suite 700

Washington, DC 20001-2109

Mr. Charles R. Williams

Underwriters Laboratories Inc.

333 Pfingsten Road

Northbrook, IL 60062-2096

Mr. Robert W. Wisbey

Vice President, Product Technology

Advance Transformer Company

10275 West Higgins Road

Rosemont, IL 60018

PEOPLE WHO REQUESTED INFORMATION

Mr. Phil Hopkinson

Director, Engineering

Square D Company

P.O. Box 500

1809 Airport Road

Monroe, NC 28110

Mr. David S. Versfelt

Donovan Leisure Newton & Irvine

30 Rockefeller Plaza

New York, NY 10112

Mr. Michael Wasson

Standards & Quality Assurance Manager

Asko, Inc.

1161 Executive Drive West

Richardson, Texas 75081

Mr. Lawrence R. Wethje

Air-Conditioning & Refrigeration Institute

4301 North Fairfax Drive

Suite 425

Arlington , VA 22203

Mr. John A. Wilson

California Energy Commission

1516 9th Street, MS-31

Sacramento, CA 95814-5512

Ms. Ellen S. Young

Stuntz & Davis Attorneys at Law

1201 Pennsylvania Avenue, NW

Suite 819

Washington, DC 20004

Mr. Larry Schlussler

Sun Frost

P.O. Box 1101

Arcata, CA 95518-1101

 EE-PI-96-001 COMMENT 21

Mr. James F. Vaughn Jr. 

Vaughn Manufacturing Corporation 

386 Elm Street 

Salisbury, Massachusetts 01952-5431 

Mr. William F. Walters 

CatTier Corporation 

Carrier Parkway, A&R Building 

P.O. Box 4808 

Syracuse, NY 13221 

Ms. Carol Werner 

Energy & Climate Program Director 

Environmental and Energy Study Institute 

122 C Street, NW, Suite 700 

Washington, DC 20001-2109 

Mr. Charles R. Williams 

Underwriters Laboratories Inc. 

333 Pfingsten Road 

Northbrook, IL 60062-2096 

Mr. Robert W. Wisbey 

Vice President, Product Technology 

Advance Transformer Company 

1027 5 West Higgins Road 

Rosemont, IL 60018 

PEOPLE WHO REQUESTED INFORMATION 

Mr. Phil Hopkinson 

Director, Engineering 

Square D Company 

P.O. Box 500 

1809 Airport Road 

Monroe, NC 28110 

Mr. David S. Versfelt 

Donovan Leisure Newton & Irvine 

30 Rockefeller Plaza 

New York, NY 10112 

Mr. Michael Wasson 

Standards & Quality Assurance Manager 

Asko, Inc. 

1161 Executive Drive West 

Richardson, Texas 75081 

Mr. Lawrence R. Wethje 

Air-Conditioning & Refrigeration Institute 

4301 North Fairfax Drive 

Suite 425 

Arlington, VA 22203 

Mr. John A. Wilson 

California Energy Commission 

1516 9th Street, MS-31 

Sacramento, CA 95814-5512 

Ms. Ellen S. Young 

Stuntz & Davis Attorneys at Law 

1201 Pennsylvania Avenue, NW 

Suite 819 

Washington, DC 20004 

Mr. Larry Schlussler 

Sun Frost 

P.O. Box 1101 

Arcata, CA 95518-1101 
Mr. Bob Pritz

Carrier Corporation

P.O. Box 70

Indianapolis, IN 46206

Mr. Jim Sawruk

General Machine Corp.

302 S. Forth Street

Emmaus, PA 18049-3891

Mr. Philip McKittrick

Vice President Value Engineering

Feders Corporation

415 Wabash Avenue

Effingham, IL 62401

Mr. James D. Kirsch, Manager

Hot Springs Rural Electric Assoc.

P.O. Box 630

504 Fremont Street

Thermopolis, Wyoming 82443

Mr. Joseph G. Howley

Manager

GE Lighting

1975 Noble Rd., Nela Park

Cleveland, OH 44112-6300

Mr. Charlie Fritts

American Gas Association

1515 Wilson Blvd

Arlington, VA 22209

Mr. Lawrence J. Stempnik, P.E.

12883 Commerce Road

Milford, MI 48380-1217

Mr. Kurt Saul

Burnham Corporation

Hydronics Division

PO Box 3079

Lancaster, PA 17604

Mr. Ed Yandek, Manager

World Wide Industry Standards

GE Lighting

Nela Park, Building 321

1975 Noble Road

East Cleveland, Ohio 44112

Mr. Mike Dodds

Howard Industries

P.O. Box 1590

Laurel, Mississippi 39441

Mr. Carl Hiller

Manager, Residential Systems

Electric Power Research Institute

3412 Hillview Avenue, Room 7-126

Palo Alto, CA 94304

Mr. Jim Campbell

Energy Efficiency and Renewable Energy

Customer Service Center

P.O. Box 3048

Merryfield, VA 22116

Ms. Jane Ransdell

Senior Engineer, Home Laundry

General Electgric Company

Appliance Park, AP1-2NN-95

Louisville, KY 40225

Mr. Jeff Follett

Design Engineer, Laundry Products

Frigidaire Company

400 Des Moines Street

Webster City, IA 50595-1499

 EE-PI-96-001 COMMENT 21

Mr. Bob Pritz 

Carrier Corporation 

P.O. Box 70 

Indianapolis, IN 46206 

Mr. Jim Sawruk 

General Machine Corp. 

302 S. Forth Street 

Emmaus, PA 18049-3891 

Mr. Philip McKittrick 

Vice President Value Engineering 

Feders Corporation 

415 Wabash Avenue 

Effingham, IL 62401 

Mr. James D. Kirsch, Manager 

Hot Springs Rural Electric Assoc. 

P.O. Box 630 

504 Fremont Street 

Thermopolis, Wyoming 82443 

Mr. Joseph G. Howley 

Manager 

GE Lighting 

1975 Noble Rd., Nela Park 

Cleveland, OH 44112-6300 

Mr. Charlie Fritts 

American Gas Association 

1515 Wilson Blvd 

Arlington, VA 22209 

Mr. Lawrence J. S tempnik, P.E. 

12883 Commerce Road 

Milford, MI 48380-1217 

Mr. Kurt Saul 

Burnham Corporation 

Hydronics Division 

PO Box 3079 

Lancaster, PAl 7 604 

Mr. Ed Yandek, Manager 

World Wide Industry Standards 

GE Lighting 

Nela Park, Building 321 

1975 Noble Road 

East Cleveland, Ohio 44112 

Mr. Mike Dodds 

Howard Industries 

P.O. Box 1590 

Laurel, Mississippi 39441 

Mr. Carl Hiller 

Manager, Residential Systems 

Electric Power Research Institute 

3412 Hillview Avenue, Room 7-126 

Palo Alto, CA 94304 

Mr. Jim Campbell 

Energy Efficiency and Renewable Energy 

Customer Service Center 

P.O. Box 3048 

Merryfield, VA 22116 

Ms. Jane Ransdell 

Senior Engineer, Home Laundry 

General Electgric Company 

Appliance Park, APl-2NN-95 

Louisville, KY 40225 

Mr. Jeff Follett 

Design Engineer, Laundry Products 

Frigidaire Company 

400 Des Moines Street 

Webster City, IA 50595-1499 
Ms. Debra Berlyn

Executive Director, National Association

of State Utility Consumer Advocates

1133 15th Street, NW

Washington, DC 20005

Ms. Elizabeth C. Klumpp

Washington State Energy Office

925 Plum Street, SE

P.O. Box 43165

Olympia, WA 98504-3165

Mr. Rick Curkeet, P.E.

Chief Engineer-Bldg. Matt & Hearth Products

Warnock Hersey, Inc.

8451 Murphy Dirve

Middleton, WI 53562

Mr. Mike McGraph

Director Customer Programs

Edison Electric Institute

701 Pennsylvania Avenue, NW

Washington, DC 20004

Mr. Don Rolfe

50 Taylor Road

Franklin, NC 28734

Mr. Richard McMahon

Edison Electric Institute

701 Pennsylvania Ave., NW

Washington, DC 20004

Mr. David Barder

Cooper Development Association

260 Madison Avenue

New York, NY 10016

Mr. Carl Mayor

Dunkirk Radiator Corp.

85 Middle Road

Dunkirk, NY 14048

Mr. Steve Navener

National Institute of Standards & Technology

Building 226, Room A-313

Gaithersburg, MD 20899

Mr. Robert Marson, P. Eng.

Senior Standards Engineer

International Approval Services, Inc.

55 Scarsdale Road

Toronto, Ontario CANADA M3B 2R3

Mr. Michael Dodd

Canadian Standards Association

178 Rexdale Boulevard

Etobicoke, Ontario, CANADA M9W 1R3

Mr. Ed Angelone

Brooklyn Union Gas

1 Metro Tech. Center

Brooklyn, NY 11201

Ms. Jackie Erwin

Merchandising Dept.

Circuit City

9950 Maryland Drive

Richmond, VA 23233-1464

Lve Boutin

IRO Quebec

1010 St. Cathrines St. W

9th Floor

Montreal CANADA H3C 457

 EE-PI-96-001 COMMENT 21

Ms. Debra Bedyn 

Executive Director, National Association 

of State Utility Consumer Advocates 

1133 15th Street, NW 

Washington, DC 20005 

Ms. Elizabeth C. Klumpp 

Washington State Ener'gy Office 

925 Plum Street, SE 

P.O. Box 43165 

Olympia, WA 98504-3165 

Mr. Rick Curkeet, P.E. 

Chief Engineer-Bldg. MatI. & Hearth Products 

Warnock Hersey, Inc. 

8451 Murphy Dirve 

Middleton, WI 53562 

Mr. Mike McGraph 

Director Customer Programs 

Edison Electric Institute 

701 Pennsylvania Avenue, NW 

Washington, DC 20004 

Mr. Don Rolfe 

50 Taylor Road 

Franklin, NC 28734 

Mr. Richard McMahon 

Edison Electric Institute 

701 Pennsylvania Ave., NW 

Washington, DC 20004 

Mr. David Barder 

Cooper Development Association 

260 Madison Avenue 

New York, NY 10016 

Mr. Carl Mayor 

Dunkirk Radiator Corp. 

85 Middle Road 

DunkIrk, NY 14048 

Mr. Steve Navener 

National Institute of Standards & Technology 

Building 226, Room A-313 

Gaithersburg, MD 20899 

Mr. Robert Marson, P. Eng. 

Senior Standards Engineer 

International Approval Services, Inc. 

55 Scarsdale Road 

Toronto, Ontario CANADA M3B 2R3 

Mr. Michael Dodd 

Canadian Standards Association 

178 Rexdale Boulevard 

Etobicoke, Ontario, CANADA M9W lR3 

Mr. Ed Angelone 

Brooklyn Union Gas 

1 Metro Tech. Center 

Brooklyn, NY 11201 

Ms. Jackie Erwin 

Merchandising Dept. 

Circuit City 

9950 Maryland Drive 

Richmond, VA 23233-1464 

Lve Boutin 

IRO Quebec 

1010 St. Cathrines St. W 

9th Floor 

Montreal CANADA H3C 457 
Mr. Larry Moon

Martin Industry

P.O. Box 128

Florence, AL 35631

Mr. Gordy Schnabel

Manager, Contract Programs

Raytheon

Suite 1500

1215 Jefferson Davis Hwy.

Arlington, VA 22202

Mr. John Crouch

Harth Product Association

2848 Arden Way, Suite 200

Sacramento, CA 95825

Mr. Vince Richter

Rinnai American Corporation

1662 Lukken Industrial Drive, West

LaGrange, GA 30240

Mr. Patrick C. O'Connor

Washington Representative

American Supply Association

1990 M Street, NW, Suite 340

Washington, DC 20036

Mr. Jose Luis Bonilla

Product Design Manager

lumisitemas, s.a.dc c.v.blvd.

toluca 520-A naucalpan de jurez 53500

edo. de Mexico

Mr. Scott Spiller

General Counsel

Speed Queen Company

Shepard Street, P.O. Box 990

Ripon, WI 54971

Ms. Jennifer Schafer

American Gas Cooling Center

499 S Capitol Street, SW

Suite 520

Washington, DC 20003

Mr. Rob McDonald

Emerson Electric

700 13th Street NW

Suite 700

Washington, DC 20005

Ms. Lira Behrens

1200 G Street, NW

Suite 1100

Washington, DC 20005

Mr. Murray Liebeman

American Gas Association

1515 Wilson Boulevard

Arlington, VA 22209

Mr. Noe Garcia

Standards Coordinator

Mabe Technologia y Desarrollo

Acceso B No. 406

Parque Industrial Jurica

76120 Querataro, Qro. MEXICO

Mr. Jack Linard

Lever Brothers Company

Research & Development Center

45 River Road

Edgewater, NJ 07020

Mr. Eric Sikkema

NCSL

1560 Broadway, Suite 700

Denver, CO 80202

 EE-PI-96-001 COMMENT 21

Mr. Larry Moon 

Martin Industry 

P.O. Box 128 

Florence, AL 35631 

Mr. Gordy Schnabel 

Manager, Contract Programs 

Raytheon 

Suite 1500 

1215 Jefferson Davis Hwy. 

Arlington, VA 22202 

Mr. John Crouch 

Harth Product Association 

2848 Arden Way, Suite 200 

Sacramento, CA 95825 

Mr. Vince Richter 

Rinnai American Corporation 

1662 Lukken Industrial Drive, West 

LaGrange, GA 30240 

Mr. Patrick C. O'Connor 

Washington Representative 

American Supply Association 

1990 M Street, NW, Suite 340 

Washington, DC 20036 

Mr. Jose Luis Bonilla 

Product Design Manager 

lumisitemas, s.a.dc c.v.blvd. 

toluca 520-A naucalpan de jurez 53500 

edo. de Mexico 

Mr. Scott Spiller 

General Counsel 

Speed Queen Company 

Shepard Street, P.O. Box 990 

Ripon, WI 54971 

Ms. Jennifer Schafer 

American Gas Cooling Center 

499 S Capitol Street, SW 

Suite 520 

Washington, DC 20003 

Mr. Rob McDonald 

Emerson Electric 

700 13th Street NW 

Suite 700 

Washington, DC 20005 

Ms. Lira Behrens 

1200 G Street, NW 

Suite 1100 

Washington, DC 20005 

Mr. Murray Liebeman 

American Gas Association 

1515 Wilson Boulevard 

Arlington, VA 22209 

Mr. Noe Garcia 

Standards Coordinator 

Mabe Technologia y Desarrollo 

Acceso B No. 406 

Parque Industrial Jurica 

76120 Querataro, Qro. MEXICO 

Mr. Jack Linard 

Lever Brothers Company 

Research & Development Center 

45 River Road 

Edgewater, NJ 07020 

Mr. Eric Sikkema 

NCSL 

1560 Broadway, Suite 700 

Denver, CO 80202 
Mr. John Batey

Energy Resource Center

35 Fawn Road

Easton, Connecticut 06612

Mr. Atul Vir

Equator Corporation

Arena Tower II

7324 Southwest Freeway, Suite 855

Houston, TX 77074-2037

Mr. Richard Steyer

Howe, Anderson & Steyer

1747 Pennsylvania Ave., NW

Suite 1050

Washington, DC 20006

Mr. Frank Bishop

Executive Director

National Association of State Energy Officials

1615 M Street, NW

Washington, DC 20035

Mr. Jim Taite

Director

Florida Energy Office

Department of Community Affairs

2740 Centerville Drive

Tallahassee, FL 32399

Mr. Ted Pope

Seattle City Light

Mail Stop 3446

700 Fifth Avenue, Suite 3100

Seattle, WA 98104

Ms. Cindy Merric

Gorenja USA Inc.

2450 Middle Country Road

Centereach, NY 11720

Mr. Steve Barlas

Appliance Magazine

3560 North Nottingham St.

Arlington, VA 22207

Mr. Rick Fedrizzi

U.S. Green Building Council

c/o Carrier Corporation

Carrier Parkway

A&R Building

Syracuse, NY 13221

 EE-PI-96-001 COMMENT 21

Mr. John Batey 

Energy Resource Center 

35 Fawn Road 

Easton, Connecticut 06612 

Mr. Atul Vir 

Equator Corporation 

Arena Tower II 

7324 Southwest Freeway, Suite 855 

Houston, TX 77074-2037 

Mr. Richard Steyer 

Howe, Anderson & Steyer 

1747 Pennsylvania Ave., NW 

Suite 1050 

Washington, DC 20006 

Mr. Frank Bishop 

Executive Director 

National Association of State Energy Officials 

1615 M Street, NW 

Washington, DC 20035 

Mr. Jim Taite 

Director 

Florida Energy Office 

Department of Community Affairs 

2740 Centerville Drive 

Tallahassee, FL 32399 

Mr. Ted Pope 

Seattle City Light 

Mail Stop 3446 

700 Fifth Avenue, Suite 3100 

Seattle, W A 98104 

Ms. Cindy Merrie 

Gorenja USA Inc. 

2450 Middle Country Road 

Centereach, NY 11720 

Mr. Steve Barlas 

Appliance Magazine 

3560 North Nottingham St. 

Arlington, VA 22207 

Mr. Rick Fedrizzi 

U.S. Green Building Council 

c/o Carrier Corporation 

Carrier Parkway 

A&R Building 

Syracuse, NY 13221 
Flip Chart Notes of Participants Discussion

at the Appliance Standards

Process Improvement Workshop

Held on March 19-20, 1996

TABLE OF CONTENTS

Page(s)

PLENARY SESSION DISCUSSION ............................................. 2- 8

SCREENING BREAKOUT SESSION 9 - 12

IMPACT ANALYSIS BREAKOUT SESSION ............................. 13 15

PRIORITIZATION BREAKOUT SESSION ................................ 16 - 17

HVAC & WATER HEATING BREAKOUT SESSION .............. 18 - 19

WHITE GOODS BREAKOUT SESSION .............................. 20 - 21

ELECTRICAL PRODUCTS BREAKOUT SESSION ................. 22 - 24

PLENARY SESSION DISCUSSION - NEXT STEPS ................ 25

1 pitscrn.002

March 29, 1996

 EE-PI-96-001 COMMENT 21

Flip Chart Notes of Participants Discussion 

at the Appliance Standards 

Process Improvement Workshop 

Held on March 19-20, 1996 

TABLE OF CONTENTS 

Page(s) 

PLENARY SESSION DISCUSSION ............................................. 2 - 8 

SCREENING BREAKOUT SESSION .......................................... 9 - 12 

IMPACT ANALYSIS BREAKOUT SESSION ............................. 13 - 15 

PRIORITIZATION BREAKOUT SESSION ................................ 16 - 17 

HVAC & WATER HEATING BREAKOUT SESSION .............. 18 - 19 

WHITE GOODS BREAKOUT SESSION ................................... 20 - 21 

ELECTRICAL PRODUCTS BREAKOUT SESSION ................. 22 - 24 

PLENARY SESSION DISCUSSION - NEXT STEPS ............... . 25 

1 pi tscrn. 002 

March 29, 1996 
MARCH 19 - PLENARY SESSION DISCUSSION

The questions that arose during the first day of Ethe workshop are categorized as follows:

Process: How will the new process work? (big picture)

Stakeholders: Who will be involved? Who are the "stakeholders"?

Authority: What are the limits and constraints placed on DOE's authority?

Crit6 ia: What criteria will be applied to screening and prioritizing?

Analysis: What methods of analysis will be used?

Goals: What are DOE's goals, targets?

Consumers: How are consumers part of the process?

Evaluation: What. are the outcomes and how will they be measured?

PROCESS

How will the process to handle:

Consumer vs. commercial?

Complete products vs. components?

Legislation differs from area to area.

Can process flow be simplified?

Will there be parallel proposals from DOE and interested parties?

Prioritization and screening before ANOPR, NOPR and Final Rule will be less model

dependent and more detailed than in the past.

When a rulemaking is terminated in the new process, will it be published?

How will proprietary, breakthrough design data be protected?

What level of information will be required before design option will be considered (e.g.

patent)?

pitscrn.002

March 29, 1996

 EE-PI-96-001 COMMENT 21

., . 

MARCH 19 - PLENARY SESSION DISCUSSION 

The questions that arose during the first day of the workshop ,are categorized as follows: 

Process: How will the new process work? (big picture) 

Stakeholders: Who will be involved? Who are the "stakeholders"? 

AuthOlity: What are the limits and constraints placed on DOE's authority? 

Criteha: What criteria will be applied to screening and prioritizing? 

Analysis: What methods of analysis will be used? 

Goals: What are DOE's goals, targets? 

Consumers: How are consumers part of the process? 

Evaluation: What are the outcomes and how will they be measured? 

PROCESS 

How will the process to handle: 

Consumer vs. commercial? 

Complete products vs. components? 

Legislation differs from area to area. 

Can process flow be simplified? 

\\Till there be parallel proposals from DOE and interested parties? 

Prioritization and screening before ANOPR, NOPR and Final Rule will be less model 

dependent and more detailed than in the past. 

When a mlemaking is terminated in the new process, will it be published? 

How will proprietary, breakthrough design data be protected? 

What level of information will be required before design option will be considered (e.g. 

patent)? 

2 pitscrn.OO2 

March 29, 1996 
Technology on which standards are based must be generally available.

Patent submissions - where do they fit? Patents alone do not determine that a product should

be considered as a viable design option. (Complex issues raised and industry input was

invited)

Evaluate an unsuccessful rulemaking episode and try to learn from it.

Change nature of publications that occur at ANOPR stage by including proposals of interested

parties. During screening process publish intent to hold workshop which will gather input

through dialogue; allow interested parties to set agenda.

How does the impact analysis feedback into the final analysis?

Is there a formal mechanism?

Are public hearings still part of the process?

The lack of trust in and experience with the new process is a critical issue. Take a standard

and run it through as a test case.

You should still be able to return to initial criteria after impact analysis process.

How will the "small manufacturer" be handled in the future impact analysis?

Has DOE put together a time line comparing old process vs. new? Define and articulate

process.

Will new rules apply to existing 13 products? Are transition plans open to input?

As review process proceeds through funnel, will the same issues get revisited at each stage?

Yes.

Will this new process allow greater consideration of multiple class standards?

What is "intrinsic" to this process that will get DOE back "on track" to a regulatory schedule?

Does DOE have adequate staff to conduct the kinds of participatory processes being talked

about?

Where will this process be applied? New class of products? Existing products?

Once final rule is set, how often will DOE revisit standard for review?

3 pitscrn.002

March 29, 1996

 EE-PI-96-001 COMMENT 21

~echnology on which standards are based must be generally available. 

Patent submissions - where do they fit? Patents alone do not determine that a product should 

be considered as a viable design option. (Complex issues raised and industry input was 

invited) 

Evaluate an unsuccessful lUlemaking episode and try to learn from it. 

Change nature of publications that occur at ANOPR stage by including proposals of interested 

parti~s. During screening process publish intent to hold workshop which will gather input 

through dialogue; allow interested parties to set agenda. 

How does the impact analysis feedback into the final analysis? 

Is there a formal mechanism? 

Are public hearings still part of the process? 

The lack of tlUst in and experience with the new process is a critical issue. Take a standard 

and lUn it through as a test case. 

You should still be able to return to initial criteria after impact analysis process. 

How will the "small manufacturer" be handled in the future impact analysis? 

Has DOE put together a time line comparing old process vs. new? Define and articulate 

process. 

Will new lUles apply to existing 13 products? Are transition plans open to input? 

As review process proceeds through funnel, will the same issues get revisited at each stage? 

Yes. . 

Will this new process allow greater consideration of _multiple class standards? 

, 

What is "intrinsic" to this process that .will get DOE back "on track" to a regulatory schedule? 

Does DOE have adequate staff to conduct the kinds of participatory processes being talked 

about? 

Where will this process be applied? New class of products? Existing products? 

Once final lUle is set, how often will DOE revisit standard for review? 

3 pitscrn.OO2 

March 29, 1996 
Once ANOPR written, will it be a closed standard? Can there be another loop?

Can variance from averages be better understood and appreciated -- not homogenized with

majority? (Pay more attention to needs at the margin.)

Insufficient differentiation between the issues presented today.

More prioritization is needed.

STAKEHOLDERS

"Stakeholders" (the ad hoc group) are not just those who did the work before this meeting

(workshop). We are all "stakeholders". Define "stakeholders".

Who are the "peers" in peer review?

How do the different interests get brought to bear on screening (e.g. consumers,

manufacturers, nation)?

Will test procedures be peer reviewed?

Will peer review be done by contractors, experts, stakeholders?

Does the process involve stakeholder negotiations as a parallel process?

Interested party negotiations are one tool, to be evaluated in context of likelihood of yielding

useful information.

Can we submit comments after this meeting?

How will you get full range of input to decision-makers?

Who were the people involved in the stakeholder work group and their affiliations?

Are the decisions already made -- the report written?

What will this meeting result in?

How will you organize and operate stakeholder review? How will stakeholders be selected?

Are the same people addressing prioritization and screening?

4 pitscrn.002

March 29, 1996

 EE-PI-96-001 COMMENT 21

Once ANOPR wlitten, will it be a closed standard? Can there be another loop? 

Can variance from averages be better understood and appreciated -- not homogenized with 

majority? (Pay more attention to needs at the margin.) 

Insufficient differentiation between the issues presented today. 

More priOlitization is needed. 

STAKEHOLDERS 

"Stakeholders" (the ad hoc group) are not just those who did the work before this meeting 

(workshop). We are all "stakeholders". Define "stakeholders". 

Who are the "peers" in peer review? 

How do the different interests get brought to bear on screening (e.g. consumers, 

manufacturers, nation)? 

Will test procedures be peer reviewed? 

Will peer review be done by contractors, experts, stakeholders? 

Does the process involve stakeholder negotiations as a parallel process? 

Interested party negotiations are one tool, to be evaluated in context of likelihood of yielding 

useful information. 

Can we submit comments after this meeting? 

How will you get full range of input to decision-makers? 

. Who were the people involved in the stakeholder work group and their affiliations? 

Are the decisions already made -- the report written? 

What will this meeting result in? 

How will you organize and operate stakeholder review? How will stakeholders be selected? 

Are the same people addressing prioritization and screening? 

4 pitscrn.OO2 

March 29, 1996 
Where did contractor expertise get discussed ? How will interested parties be invited to offer

input. Note gov't procedures for selection?

What constitutes "stakeholders"?

Invite and accept help from private sector in developing models /processes.

AUTHORITY

Whal is the scope of McCabe's authority?

What commitments can DOE make to transition ? Show us DOE is really going to do things

differently !

If federal regulations were suspended , could states pre-empt them?

How do you reconcile a desire to apply a market-driven regulatory development process with

a command and control approach?

...And what is DOE's range of flexibility on this?

DOE: What's our discretion to not be in the rulemaking business?

Is DOE bound by life-cycle analysis in developing its standards?

Will this (process improvement initiative) lead to statutory action?

Are new regulations needed?

If there is consensus on either of these, how will this occur?

CRITERIA

Benefits exceed burdens. (This is one criteria implied in the statute)

What are the criteria applied to the screening process? Is it driven by statute?

Qualitative questions should be posed first before considering product design questions.

Identify and define the criteria for "MAX TECH".

Qualitative/Analytical processes have been discussed , e.g. economic benefits, life-cycles.

How will those REALLY be considered?

5 pitscrn.002

March 29, 1996

 EE-PI-96-001 COMMENT 21

Where did contractor expertise get discussed? How will interested partie~ be invited to offer 

input. Note gov't procedures for selection? 

What constitutes "stakeholders"? 

Invite and accept help from private sector in developing models/processes. 

AUTHORITY 

Wha1 is the scope of McCabe's authority? 

What commitments can DOE make to transition? Sho'w us DOE is really going to do things 

differently! 

If federal regulations were suspended, could states pre-empt them? 

How do you reconcile a desire to apply a market-driven regulatory development process with 

a command and control" approach? 

.... And what is DOE's range of flexibility on this? 

DOE: What's our discretion to not be in the rulemaking business? 

Is DOE bound by life-cycle analysis in developing its standards? 

Will this (process improvement initiative) lead to statutory action? 

Are new regulations needed? 

If there is consensus on either of these, how will this occur? 

CRITERIA 

Benefits exceed burdens. (This is one criteria implied in the statute) 

What are the criteria applied to the screening process? Is it driven by statute? 

Qualitative questions should be posed first before considering product design questions. 

Identify and define the criteria for "MAX TECH". 

Qualitative/Analytical processes have been discussed, e.g. economic benefits, life-cycles. 

How will those REALLY be considered? 

5 pitscrn.OO2 

March 29. 1996 
How have you grappled with "max tech", "technology forcing" issue?

Are codes designed to be energy source neutral and product neutral?

Prioritization -- What are the criteria to be? What objectives are they designed to meet?

Source Btus and End-use Btus -- neither should be sole basis for determination of standards.

ANALYSIS

Will test procedures have to be consistent with old standards?

How will you ensure technical experts are the right and qualified ones?

To what extent can models be replaced witjl more accurate methods of analysis?

Can we speak in plain English about models (simplify and make more understandable)?

Can we do away with models (replace with information)?

Run through a "model" (test case) of the rulemaking process and of design suggestions.

Process changes must be integrated with substantive changes in analytical process.

The more detailed analysis still will require models.

Some models are useful, but are less so when the data used to feed them are inadequate.

More receptivity of proposed models/criteria and draft regulations from private industry

sources needed by DOE.

GOALS

Enunciate clearer goals and considerations:

Economic

Environmental ------------> Avoid negative impact on future generations

Energy Security

Should the process be performance focused rather than product focused? i.e, broader

conservation/consumption goals with more flexibility in how to reach them?

pitscrn.002

March 29, 1996

 EE-PI-96-001 COMMENT 21

How have you grappled with "max tech", "technology forcing" issue? 

Are codes designed to be energy source neutral and product neutral? 

Prioritization .-- What are the criteria t9 be? What objectives are they designed to meet? 

Source Btus and End-use Btus -- neither should be sole basis for detetmination of standards. 

ANALYSIS 

Will test procedures have to be consistent with old standards? 

How will you ensure technical experts are the tight and qualif~ed ones? 

To what extent can models be replaced wit}1 more accurate methods of analysis? 

Can we speak in plain English about models (simplify and rp.ake more understandable)? 

Can we do away with models (replace with information)? 

- Run through a "model" (test case) of the rulemaking process and of design suggestions. 

Process changes must be integrated with substantive changes in analytical process. 

The more detailed analysis still will require models. 

Some models are useful, but are less so when the data used to feed them are inadequate. 

More receptivity of proposed models/ctitetia and draft regulations from ptivate industry 

sources needed by DOE. 

GOALS 

Enunciate clearer goals and considerations: 

Economic 

Environmental 

Energy Secutity 

------------> Avoid negative impact on future generations 

Should the process be performance focused rather than product focused? i.e, broader 

conservation/consumption goals with more flexibility in how to reach them? 

6 pi tscrn. 002 

March 29, 1996 
Priority setting is still ambiguous. Whose agenda is it driven by and to what end? What are

the targets?

What precludes targets being set that could be reached more efficiently outside the regulatory

process, i.e. the marketplace?

Has DOE ever gone through the rulemaking process and not set a standard?

Can you estimate when DOE will have the rulemaking done? (Ref. 10/96)

What dissatisfactions gave rise to this initiative?

What does it mean to add stakeholder dialog to this process?

How do energy forecasts impact policy?

What are the overall goals and objectives of DOE's rule-making process?

CONSUMER

We need to better educated consumer with respect to energy trade-offs.

Have consumer advocates contributed to the work so far?

Is there a consumer agenda? What is the extent of consumer outreach/what new ways are

there of getting input.

When and how will consumers be provided with information to help them select among

products?

Complex technical efficiency measures are not helpful to consumers.

How to get input from "real" consumers?

EVALUATION

What has been the change over the past 5 +/- years of hi-tech/hi-efficiency products in the

marketplace? (i.e. how have standards affected the marketplace?)

When will the cumulative impact of standards be addressed?

pitscrn.002

March 29, 1996

 EE-PI-96-001 COMMENT 21

PriOlity setting is still ambiguous. Whose agenda is it driven by and to what end? What are 

the targets? 

What precludes targets being set that could be reached more efficiently outside the regulatory 

process, i.e. the ~arketplace? 

Has DOE ever gone through the rulemaking process and not set a standard? 

Can you estimate when DOE will have the rulemaking done? (Ref. 10/96) 

What dissatisfactions gave rise to this initiative? 

What does it mean to add stakeholder dialog to this process? 

How do energy forecasts impact policy? 

What are the overall goals and objectives of DOE's rule-making process? 

CONSUMER 

We need to better educated consumer with respect to energy trade-offs. 

Have consumer advocates contributed to the work so far? 

Is there a consumer agenda? What is the extent of consumer outreachlwhat new ways are 

there of getting input. 

When and how will consumers be provided with information to help them select among 

products? 

Complex technical efficiency measures are not helpful to consumers. 

How to get input from "real" consumers? 

EVALUATION 

What has been the change over the past 5 +/- years of hi-techlhi-efficiency products in the 

marketplace? (i.e. how have standards affected the marketplace?) 

When will the cumulative impact of standards be addressed? 

7 pitscrn.002 

March 29, 1996 
Will new process cost more or less than existing process? Goal: less resource intensive.

What was the outcome of the last set of standards re: manufacturer impact? Testimony

regarding specific impacts in several areas.

How does DOE measure job creation and promotion of competitiveness?

8 - pitscrn.002

March 29, 1996

 EE-PI-96-001 COMMENT 21

., . 

Will new process cost more or less than existing process? Goal: less resource intensive. 

What was the outcome of the last set of standards re: manufacturer impact? Testimony 

regarding specific impacts in several areas. 

How does DOE measure job creation and promotion of competitiveness? 

8 pi tscm. 002 

March 29, 1996 
MARCH 20 - PROCESS IMPROVEMENT WORKSHOP

REPORT ON THE BREAKOUT SESSION FOR SCREENING

ISSUES:

Participants in the breakout session were requested to respond to the following questions:

• What criteria should be applied to screen products for potential regulation?

• y Who should be involved in the screening process?

• How should these people be utilized?

• What is the timeline and/or sequencing of activities in the screening process?

BACKGROUND:

• The first stage of the rulemaking process is to determine, through a process of

screening through predetermined criteria, what options apply to a product, whether or

not products identified in a statute are in fact candidates for regulation, and what the

extent of that regulation should be.

DISCUSSION:

• Identify stakeholders and interested parties to set out issues, analytical methods, and

experts to become involved.

• "Technologically feasible according to the statute may be different from "practically

feasible" in the real world. Even though a product can be manufactured at max tech,

is it practical to go into full production? Can a product be serviced? What effects

will efficiency have on product performance or product application: Will it fit? Will

it work?

• How does the positive impact of a regulation on only a few areas affect the entire

standards process? Should positive and negative effects be weighted to determine net

benefit? What constitutes significant net benefits? The answers may be subjective.

RECOMMENDATIONS:

The following criteria were deemed important. Priority was not considered.

What criteria should be applied to screen products for potential regulation? ation?

pitscrn.002

9 March 29, 1996

 EE-PI-96-001 COMMENT 21

MARCH 20 - PROCESS IMPROVEMENT WORKSHOP 

REPORT ON THE BREAKOUT SESSION FOR SCREENING 

ISSUES: 

Participants in the breakout session were requested to respond to the following questions: 

• What criteria should be applied to screen products for potential regulation? 

• .. Who should be involved in the screening process? 

• How should these people be utilized? 

• What is the timeline and/or sequencing of activities in the screening process? 

BACKGROUND: 

• The first stage of the rulemaking process is to determine, through a process of 

screening through predetermined criteria, what 'options apply to a product, whether or 

not products identified in a statute are in fact candidates for regulation, and what the 

extent of !hat regulation should be. 

DISCUSSION: 

• Identify stakeholders and interested parties to set out iss4es, analytical methods, and 

experts to become involved. 

• "Technologically feasible" according to the statute may be different from "practically 

feasible" in the real world. Even though a product can be manufactured at max tech, 

is it practical to go into full production? Can a product be serviced? What effects 

will efficiency have on product performance or product application: Will it fit? Will 

it work? 

• How does the positive impact of a regulation on only a few areas affect the entire 

standards process? Should positive and negative effects be weighted to determine net 

benefit? What constitutes significant net benefits? The answers may be subjective. 

RECOMMENDATIONS: 

The following criteria were deemed impOltant. Priority was not considered. 

What criteria should be applied to screen products for potential regulation? 

9 pit~crn.002 

March 29, 1996 
• Product performance versus benefits: Is it "doable" by the manufacturer? Can a

certain level of efficiency be achieved while maintaining the expected performance of

a product. Is it "controllable" by the manufacturer? Does the manufacturer control the

end-use efficiency of a product, or will the product be used as a component in a larger

system where the efficiency per se may lose significance?

• Is it commercially feasible to produce an energy efficient product (not simply

economically justified) from a marketing viewpoint?

-What is the cost to manufacturer versus the price to consumer?

-What are the cost differences between a basic technology product and a high

technology product?

-What is the overall impact on system efficiency and what modifications to the

system are needed to accommodate the energy efficient product?

-Does the user need or want the energy efficient product?

-Other cost considerations: site costs; installation, including hardware and

skilled labor; maintainability; long term serviceability and servicing

infrastructure.

-Cost of training or retraining an industry in a new technology.

• Utility (gas; electric; and other fuels and fuel transportation) factors: What is the

location of the cognizant utility company, the area serviced by state or region, state

regulatory implications, and the utility rate structure?

• When outside experts are used, are they neutral and objective, without bias toward a

certain outcome?

-Should there be experts who advocate advantages?

-Should there be experts who advocate disadvantages?

-Both?

• When does it makes sense to use national "average" temperature or climatic conditions

to determine product performance, costs, and benefits? When does it make sense to

use geographic and regional considerations?

-Manufacturers are not always able to design a product for the "average" user.

-Department models should utilize the full spectrum of data, not just averages.

-Can the range of effects be estimated by using the expected or known extreme

values in the models, such as sensitivity analysis.

• How much screening is necessary for a product whose anticipated impact on energy

savings is small versus a product whose anticipated impact on energy savings is large?

• How should differences in the energy efficiency of competing design options be

compared: percentage variation or actual efficiency? (Don't just look at the

differences in efficiency, but the percent of difference between competing design

options.)

pitscrn.002

10 March 29, 1996

 EE-PI-96-001 COMMENT 21

• Product perfonnance versus benefits: Is it "doable" by the manufacturer? Can a 

certain level of efficiency be achieved while maintaining the expected pelfonnance of 

a product. Is it "contmllable" by the manufacturer? Does the manufacturer control the 

end-use efficiency of a product, or will the product be used as a component in a larger 

system where the efficiency per se may lose significance? . 

• Is it commercially feasible to produce an energy efficient product (not simply 

economically justified) from a marketing viewpoint? 

-What is the cost to manufacturer versus the price to consumer? 

-What are the cost differences between a basic technology product and a high 

technology product? 

-What is the overall impact on system efficiency and what modifications to the 

system are needed to accommodate the energy efficient product? 

-Does the user need or want the energy efficient product? 

-Other cost considerations: site costs; installation, including hardware and 

skilled labor; maintainability; long term serviceability and servicing 

infras tructure. 

-Cost of training or retraining an industry in a new technology. 

• Utility (gas; electric; and other fuels and fuel transportation) factors: What is the 

location of the cognizant utility company, the area serviced by state or region, state 

regulatory implications, and the utility rate structure? 

• When outside experts are used, are they neutral and objective, without bias toward a 

certain outcome? 

-Should there be experts who advocate advantages? 

-Should there be experts who advocate disadvantages? 

-Both? 

• When does it makes sense to use national "average" temperature or climatic conditions 

to detennine product performance, costs, and benefits? When does it make sense to 

use geographic and regional considerations? 

-Manufacturers are not always able to design a product for the "average" user. 

-Department models should utilize the full spectrum of data, not just averages. 

-Can the range of effects be estimated by using the expected or known extreme 

values in the models, such as sensitivity analysis. 

• How much screening is necessary for a product whose anticipated impact on energy 

savings is small versus a product whose anticipated impact on energy savings is large? 

• How should differences ·in the energy efficiency of competing design options be 

compared: percentage variation or actual efficiency? (Don't just look at the 

differences in efficiency, but the percent of difference between competing design 

options.) 

pitscrn.002 

10 . March 29, 1996 
• What externalities ("out of the box") should be considered?

-Environmental effects.

-Emissions.

-Sanitary.

-Subjective purchasing decisions.

-Will the energy product efficient perform its intended function:

--will the motor start a high torque load?

--will a water closet flush materials thoroughly?

--will a showerhead provide sufficient water to wash hair?

• - How should regional considerations be utilized when developing a national standard?

• Will natural market forces, qualitative and quantitative , pull certain energy efficient

products into the marketplace voluntarily in lieu of mandatory standards ? (Can apply

to screening and priority phases.)

-When mandatory standards may have "no negative impact ", they may act as

" insurance " to "make it happen".

• How should economic margins be considered in the supply and demand of an energy

efficient product? What are realistic margins (discount rates)? (These criteria may

belong to the manufacturing phase.)

• What quick and accurate decision-making questions should.be asked up front before a

detailed screening process is undertaken?

-Is such a product technically feasible?

-Is manufacture , marketing, and servicing practical?

-Are there opportunities for consensus among stakeholders and interested

parties?

• What issues or types of issues should be identified during the screening process and

when?

-Sort issues prior to conducting the technical and economic analysis.

-Use an analyst (contractor) who can provide an unbiased analysis.

--findings may be pro standards or con standards.

--analysis should not provide an "a priori " means of arriving at a

predetermined conclusion.

Who should be involved in the screening process?

• What skill sets should persons conducting screening offer?

-Corporate officers and experts ("decision-makers" ): policy; marketing and

statistics; engineering ; finance/accounting.

-Consumers

--What consumers or consumer groups are interested and

pitscrn.002

11 March 29, 1996

 EE-PI-96-001 COMMENT 21

• What externalities ("out of the box") should be considered? 

-Environmental effects. 

-Emissions. 

-Sanitary. 

-Subjective purchasing .decisions. 

-Will the energy product efficient perform its intended function: 

--will the motor start a high torque load? 

--will a water closet flush materials thoroughly? 

--will a showerhead provide sufficient water to wash hair? 

• How should regional considerations be utilized when developing a national standard? 

• Will natural market forces, qualitative and quantitative, pull certain energy efficient 

products into the marketplace voluntarily in lieu of mandatory standards? (Can apply 

to screening and priQrity phases.) 

-When mandatory standards may have "ho negative impact", they may act as 

"insurance" to "make it happen". 

• How should economic margins be considered in the supply and demand of an energy 

efficient product? What are realistic margins (discount rates)? (These criteria may 

belong to the manufacturing phase.) 

• What quick and accurate decision-making questions should. be asked up front before a 

detailed screening process is undertaken? 

-Is such a product technically feasible? 

-Is manufacture, marketing, and servicing practical? 

-Are there opportunities for consensus among stakeholders and interested 

parties? 

• What issues or types of issues should be identified during the screening process and 

when? 

-Sort issues prior to conducting the technical and economic analysis. 

-Use an analyst (contractor) who can provide an unbiased analysis. 

--findings may be pro standards or con standards. 

--analysis should not provide an "a priori" means of arriving at a 

predetermined conclusion. 

Who should be involved in the screening process? 

• What skill sets should persons conducting screening offer? 

-Corporate officers and experts ("decision-makers"): policy; marketing and 

statistics; engineering; finance/accounting. 

-Consumers 

--What consumers or consumer groups are interested and 

11 

pitscrn.002 

March 29, 1996 
knowledgeable?

--What means of communication are needed to invite consumers to

participate in the screening process: Federal Register? commercial "

channels? other media?

NOTE: 'Communication solely by Federal Register notice was

considered inadequate, since.it is not read by the majority of

stakeholders and consumers.

How should these people be utilized?

How should the screening process be divided and who should be involved?.

-Phase I: identification of broad issues requires broad industry knowledge at a

high corporate level.

-Phase II: implementation decisions require specific knowledge or expertise at

a technical level.

ACTION:

What is the timeline and/or sequencing of activities in the screening process?

• What is next? (Do these quickly.)

-What are the big issues or problem areas?

-What are the top three or four criteria?

-What are the top three or four design options?

-What is the degree of impact?

• Should the screening process work with the Department of Energy or independently?

• Should the screening process be" "front-loaded" with expert advice in order to narrow

the issues early in the process? When should the contractor get involved?

• What does the Department look for in the screening process? What does the group

provide?

-What form should the recommendations to the Department take?

-What are the. recommendations for screening criteria?

-What are the legal latitudes and legal constraints of the screening process?

-What are the procedural hurdles?

• How much flexibility does the Department have in changing the existing procedures

and still meet the statutory requirements?

• Where is the boundary between the screening and impact phases? What criteria will

be used to separate them?

pitscrn.002

12 March 29, 1996

 EE-PI-96-001 COMMENT 21

knowledgeable? 

--What means of communication are needed to invite consumers to 

palticipate in the screening process: Federal Register? commercial -

channels? other media? 

NOTE: 'Communication solely by Federal Register notice was 

considered inadequate, since it is not read by the majority of 

stakeholders and consumers. . 

How should these people be utilized? 

• How should the screening process be divided and who should be involved?, 

ACTION: 

-Phase I: identification of broad issues requires broad industry knowledge at a 

high corporate level. 

-Phase II: implementation decisions require specific knowledge or expertise at 

a technical level. 

What is the time line and/or sequencing of activities in the screening process? 

• What is next? (Do these quickly.) 

-What are the big issues or problem areas? 

-What are the top three or four criteria? 

-What are the top three or four design options? 

-What is the degree of impact? 

• Should the screening process work with the Department of Energy or independently? 

• Should the screening process be' "front-loaded" with expert advice in order to narrow 

the issues early in the process? When should the contractor get involved? 

• What does the Department look for in the screening process? What does the group 

provide? 

-What form should the recommendations to the Department take? 

-What are the. recommendations for screening criteria? 

-What are the legal latitudes and legal constraints of the screening process? 

-What are the' procedural hurdles?' 

• How much flexibility does the Department have in changing the existing procedures 

and still meet the statutory requirements? 

• Where is the boundary between the screening and impact phases? What criteria will 

be used to separate them? 

12 

pitscrn.002 

March 29, 1996 
MARCH 20 - REPORT ON THE BREAKOUT SESSION FOR IMPACT ANALYSIS

The questions we were asked to respond to are:

1.) What are the approaches (modeling, etc.)?

2.) Who should be involved?

3.) How should they be involved?

4.) What is the time line and sequencing for these issues? [did not get addressed

in this breakout session]

A general discussion and definition of the meaning of-impact analysis (mostly modeling) was

sought by the group before addressing these questions:

• What is the breadth of impact analysis? Where does it fit in the rulemaking process?

• The manufacturers are making the most objections to modeling. Utility modeling,is

generally done using models supplied by the utilities, and is less controversial.

• Ed Pollock was asked for a brief description of the LBL-MAM manufacturer impact

analysis model, which Ed supplied.

• It would be desirable, and maybe possible, to get the answers we need with less

modeling.

• What impacts are we talking about?

• Emission reduction (relationship to efficiency?)

• Impacts on manufacturers

• Impacts on utilities

Fuel switching issues

Energy supply & demand

• Impacts on consumers

• Relationship to regulations imposed by other agencies (e.g. CFC phaseout)

• Impact on job creation and' elimination

• Impact on energy supply and demand

pitscrn.002

13 March 29, 1996

 EE-PI-96-001 COMMENT 21

MARCH 20 - REPORT ON THE BREAKOUT SESSION FOR IMPACT ANALYSIS 

. The questions we were asked to respond to are: 

1.) W~at are the approaches (modeling, etc.)? 

2.) Who should be involved? 

3.) How should they be involved? 

., 4.) What is the time line and sequencing for these issues? [did not get addressed 

in this breakout session] 

A general discussion and definition of the meaning of impact analysis (mostly modeling) was 

sought by the group before addressing these questions: 

• What is the breadth of impact analysis? Where does it fit in the rulemaking process? 

• The manufacturers are making the most objections to modeling. Utility modeling is 

generally done using models supplied by the utilities, and is less controversiaL 

• Ed Pollock was asked "for a brief description of the LBL-MAM manufacturer impact 

analysis model, which Ed supplied. 

• It would be desirable, and maybe possible, to get the answers we need with less 

modeling. 

• What impacts are we talking about? 

• Emission reduction (relationship to efficiency?) 

• Impacts on manufacturers 

• Impacts on utilities 

" Fuel switching issues 

Energy supply & demand 

• Impacts on consumers 

• Relationship to regulations imposed by other agencies (e.g. CFC phaseout) 

• Impact on job creation and elimination 

• Impact on energy supply and demand 

13 

pitscrn.002 

March 29, 1996 
• Impact on existing work force (e.g. training)

• What is the goal of impact analysis?

• Ed Pollock summarized the rulemaking process - design options, life cycle cost

analysis, trial standards, impacts on manufacturers, consumers, economy, environment.

• EPCA requires standards to be set at the highest level that is technologically feasible

and economically justified.

Discussion 'of the impact of new standards.

• Need to separate resource from technological gap. Standards may be set for which the

technology does not exist.

• Standards may impact manufacturability, maintainability, safety and reliability of

product.

• Impact on marketplace acceptance and market size.

• Impact on manufacturer's capital investment.

• Impacts may vary by region of country.

• Proprietary technology may impact a standard by favoring an exclusive technology.

• Impacts on replacement market - compatibility of replacement product in terms of size,

hookups, etc.

• Impacts on state and local governments.

• Variability of impacts on different manufacturers depending on size and other factors.

• Impact on competition.

• Impact on supporting industries such as component suppliers.

• International impacts on trade, foreign regulations and standards, etc.

• Cumulative impact of standards on multi product industries.

Discussion of MODELS - Their limitations and deficiencies

pitscrn.002

14 March 29, 1996

 EE-PI-96-001 COMMENT 21

• Impact on existing work force (e.g. training) 

• What is the goal of impact analysis? 

• Ed Pollock summarized the rulemaking process - design options, life cycle cost 

analysis, trial standards, impacts on manufactui:ers, consumers, economy, environinent. 

• EPCA requires standards to be set at the highest level that is technologically feasible 

and economically justified. 

Discussion of the impact of new standards. 

• Need to separate resource from technological gap. Standards may be set for which the 

technology does not exist. 

• Standards may impact manufacturability, maintainability, safety and reliability of 

product. 

• Impact on marketplace acceptance and market· size. 

• Impact on manufacturer's capital investment. . 

• Impacts may vary by region of country. 

• Proprietary technology may impact a standard by favoring an exclusive technology. 

• Impacts on replacement market - compatibility of replacement product in terms of size, 

hookups, etc. 

• Impacts on state and local governments. 

• Variability of impacts on different manufacturers depending on size and other factors. 

• Impact on competition. 

• Impact on supporting industries such as component suppliers. 

• International impacts on trade, foreign regulations and standards, etc. 

• Cumulative impact of standards on multi product industries. 

Discussion of MODELS - Their limitations and deficiencies 

14 

pitscrn.002 

March 29, 1996 
• Models depend on the many assumptions - there is a great deal of judgment in

modeling.

• There should be a confidence range for all the model inputs, and the confidence range

of the output should be calculated and allowed for in the analysis.

• Models are tools, not solutions.

• A good sensitivity analysis should be performed to allow concentration on the

important factors.

y

• Models sometimes are too complex and not understood.

• DOE needs to evaluate the range of models and analysis methods, and determine

which are appropriate in each case.

• Use of statistical bench marking as a way of establishing impact was suggested.

Here the facilitator asked the group to focus on who should be involved in model

development?

• Stakeholders must be involved in model development to gain trust in results of

modeling.

• Who is obvious, but proportion of involvement by manufacturers, utilities,

environmental groups and other stakeholders must be "balanced"

• Independent/objective parties should be involved.

• Manufacturer representatives need knowledge of models' impact.

The last question to be answered, concerning the time line, was not discussed.

pitscrn.002

15 March 29, 1996

 EE-PI-96-001 COMMENT 21

• Models depend on the many assumptions - there is a great deal of judgment in 

modeling. 

• There should be a confidence range for all the model inputs, and the confidence range 

of the output should be calculated and allowed for in the analysis. 

• Models are tools, not solutions. 

• A good sensitivity analysis should be performed to allow concentration on the 

important factors. 

• Models sometimes are too complex and not understood. 

• DOE needs to evaluate the range of models and analysis methods, and determine 

which are appropriate in each case. 

• Use of statistical bench marking as a way of establishing impact was suggested. 

Here the facilitator asked the group to focus on who should be involved in model 

development? 

• Stakeholders must be involved in model development to gain trust in results of 

modeling. 

• Who is obvious, but proportion of involvement by manufacturers, utilities, 

environmental groups and other stakeholders must be "balanced" 

• Independent/objective parties should be involved. 

• Manufacturer representatives need knowledge of models' impact. 

The last question to be answered, concerning the time line, was not discussed. 

15 

pi tscm. 002 

March 29, 1996 
MARCH 20 - REPORT ON BREAKOUT SESSION FOR PRIORITIZATION

The questions to be addressed in this workshop were dealt with in a brainstorming fashion,

resulting in many recommendations . These are not presented in any order of priority, becauseno priority was given to them in the discussion.

1. WHAT CRITERIA SHOULD BE USED TO DETERMINE PRIORITY OF

RULEMAKING?

• Potential energy savings (Total - as set in EPCA)

• Projected energy consumption

Achieve maximum potential energy savings under economically justified

circumstances (NAECA)

• Life cycle costs

• Consumer vs. commercial products

Complete products vs. components

• Potential dollar savings to consumer (relates to energy sources)

• Potential impact on manufacturers-upsetting competitive balance

a. GIVEN THE NUMBER OF PRODUCTS, HOW FINELY SHOULD THEY

BE PRIORITIZED

• Devote staff time to high priority rulemakings

• First step would be to categorize into high, medium and low priorityconsidering such factors as current status, status of the test procedure , what is

going on in other agencies , market place status, etc.

b. MACRO VS. MICRO

• If one is looking at establishing a process , then the criteria must be clear so

that it will focus the decision making at this stage , e.g should DOE proceed

with the rulemaking . ( For example , "Economic justification," an important

criteria needs more clarification from DOE)

• Qualitative factors that haven 't been considered before, e.g. other national

initiatives, market forces (which products work better without being

standardized), major international protocols , extent of already existing

consensus, need to be considered as well as those in legislation .

• Need to balance between potential savings and degree of controversy

pitscrn.002

16 March 29, 1996

 EE-PI-96-001 COMMENT 21

MARCH 20 - REPORT ON BREAKOUT SESSION FOR PRIORITIZATION 

The questions to be addressed in this workshop were dealt with in a brainstorming fashion, 

resulting in many recommendations. These are not presented in any order of priority, becauseno priority was given to them in the discussion. 

1. \y'HAT CRITERIA SHOULD BE USED TO DETERMINE PRIORITY OF 

RULEMAKING? 

• 

• 

• 

• 

• 

• 

• 

a. 

• 

• 

b. 

• 

• 

• 

Potential energy savings (Total - as set in EPCA) 

Projected energy consumption 

Achieve maximum potential energy savings under economically justified 

circumstances (NAECA) 

Life cycle costs 

Consumer vs. commercial products 

Complete products vs. components 

Potential dollar savings to consumer (relates to energy sources) 

Potential impact on manufacturers-upsetting competitive balance 

GIVEN THE NUMBER OF PRODUCTS, HOW PINEL Y SHOULD THEY 

BE PRIORITIZED 

Devote staff time to high priority rulemakings 

First step would be to categorize into high, medium and low priorityconsidering such factors as current status, status of the test procedure, what is 

going on in other agencies, market place status, etc. -

MACRO VS. MICRO 

If one is looking at establishing a process, then the criteria must be clear so 

that it will focus the decision making at this stage, e.g should DOE proceed 

with the rulemakin g. ( For .example, "Economic justification, "an important 

criteria needs more clarification from DOE) 

Qualitative factors that haven't been considered before, e.g. other national 

initiatives, market forces (which products work better without being 

standardized), major international protocols, extent of already existing 

consensus, need to be considered.as well as those in legislation. 

Need to balance between potential savings and degree of controversy 

16 

pitscrn.002 

March 29, 1996 
2. WHO SHOULD BE INVOLVED

• ' Manufacturers

• Environmental advocates

• Experts on products

• Trade and professional associations

• Utilities

• State/local governments

• Consumer groups

• Retailers

3. HOW OFTEN

• Probably yearly or possibly every five years

4. IMPORTANT QUESTION STILL UNANSWERED

• What are DOE's priorities?

• If it is necessary to implement this new process, will DOE seek to change the

legislation?

• Asked for the following in writing

• How much flexibility does DOE have under the law

• Restate objectives of standards

• How will each aspect of the new process work

• Discuss legal constraints-don't just restate law

pitscrn.002

17 March 29, 1996

 EE-PI-96-001 COMMENT 21

2. WHO SHOULD BE INVOLVED 

• Manufacturers 

• Environmental advocates 

• Experts on products 

• Trade and professional 'associations 

• Utilities 

• State/local governments 

• Consumer groups 

• Retailers 

3. HOW OffEN 

• Probably yearly or possibly every five years 

4. IMPOR,T ANT QUESTION STILL UNANSWERED' 

• What are DOE's priorities? 

• If it is necessary to implement this new process, will DOE seek to change the 

legislation? 

• Asked for the following in writing 

• How much flexibility does DOE have under the law 

• Restate objectives of standards 

• How will each aspect of the new process work 

• Discuss legal constraints-don't just restate law 

17 

pitscrn.OO2 

March 29, 1996 
MARCH 20 - REPORT ON BREAKOUT SESSION FOR

HVAC & WATER HEATING

1 . What are the key issues DOE should consider as it decides how to proceed?

• Go back to the beginning and come out of the closet--be explicit about assumptions,

hold workshops to review and refine assumptions. If assumptions are wrong, so is

everything that follows. (Some disagree with going back to the beginning after so

much work has already been done, e.g., in the case of furnaces; others say back up

one full step from whatever has already been done.) Wide. participation is the key.

Y

• Tailor the process by product class; uniformity across all product classes is

unworkable. Hold product-specific workshops and really listen to what people say.

• Involve interested parties in setting of criteria through workshops. Get full spectrum

of input. Criteria supported by the majority and/or large manufacturers don't

necessarily work for more specialized products, smaller manufacturers. Look askance

at consensus standards--they may be the result of power group lobbying.

• Standards should be performance-based, not on such things as emissions.

• Don't mandate technologies which are not in the marketplace.

• Cumulative effect of overlapping regulation, additive effects on components,

conflicting requirements. A process is needed to break impasse between competing

agencies, provide guidance with respect to outlawed design options (e.g., CFCs).

• Sizing of equipment by installation contractors.

• Educate industry about the rulemaking process; avoid surprises.

• Effects on international agreements.

• Government contractors don't work for analysis of leading edge technology--they just

don't have the expertise. Industry experts are essential to the process.

• Don't confuse price and cost.

2. Why are these issues important?

• Survival, profitability, international competitiveness.

• To achieve benefits which outweigh costs and burdens.

pitscrn.002

18 March 29, 1996

 EE-PI-96-001 COMMENT 21

MARCH 20 - REPORT ON BREAKOUT SESSION FOR 

HVAC & WATER HEATING 

1. What are the key issues DOE should consider as it decides how to proceed? 

• Go back to the beginning and come out of the closet--be explicit about assumptions;' 

hold workshops to review and refine assumptions. If assumptions are wrong, so is 

everything that follows. (Some disagree with going back to the beginning after so 

much work has already been done, e.g., in the case of furnaces; others say back up 

one full step from whatever has already been done.) Wide participation is the key. 

• Tailor the process by product class; uniformity across all product classes is 

unworkable. Hold product-specific workshops and really listen to what people say. 

• Involve interested parties in setting of criteria through workshops. Get full spectrum 

of input. Criteria supported by the majority and/or large manufacturers don't 

necessarily work for more specialized products, smaller manufacturers. Look askance 

at consensus standards--they may be the result of power group lobbying. 

• Standards should be performance-based, not on such things as emissions. 

• Don't mandate technologies which are not in the marketplace. 

• Cumulative effect of overlapping regulation, additive effects on components, 

conflicting requirements. A process is needed to break impasse between competing 

agencies, provide guidance with respect to outlawed design options (e.g., CFCs). 

• Sizing of equipment by installation contractors. 

• Educate industry about the rulemaking process; avoid surprises. 

• Effects on international agreements. 

• Government contractors don't work for analysis of leading edge technology--they just 

don't have the expertise. Industry experts are essential to the process. 

• Don't confuse price and cost. 

2. Why are these issues important? 

• Survival, profitability, international competitiveness . 

. • To achieve benefits which outweigh costs and burdens. 

18 

pitscrn.002 

March 29, 1996 
3. What products should be used as a "test case" for the new process?

• There is tremendous reluctance to single out specific products areas, and most would

prefer to test the rulemaking process itself.

0 Commercial labeling may be a candidate for the review process.

• Many feel the test products. should be in areas with the highest potential for costeffective energy savings, e.g., residential central air conditioners and heat pumps,

- residential water heaters (not heat pump water heaters).

• Other advocate revisiting from the very beginning a rulemaking process which has to

date been a disaster.

• Still other advise testing the lulemaking process with products which present the most

complexity and uncertainty of potential savings. A related suggestion is to choose a

product which is furthest from having stakeholder consensus.

pitscrn.002

19 March 29, 1996

 EE-PI-96-001 COMMENT 21

3. What products should be used as a "test case" for the new process? 

• There is tremendous reluctance to single out specific products areas, and most would 

prefer to test the rulemaking process itself. 

• Commercial labeling may be a candidate for the review process. 

• Many feel the test products should be in areas with the highest potential for costeffective energy savings, e.g., residential central air conditioners and heat pumps, 

residential water heaters (not heat pump water heaters). 

• Other advocate revisiting from the very beginning a rulemaking process which has to 

date been a disaster. 

• Still other advise testing the rulemaking process with products which present the most 

complexity and uncertainty of potential savings. A related suggestion is to choose a 

product which is furthest from having stakeholder consensus. 

19 

pi tscm. 002 

March 29, 1996 
MARCH 20 - REPORT ON BREAKOUT SESSION FOR WHITE GOODS

The questions to be addressed in this workshop resulted in two major point of views which

are presented below.

1. WHAT ARE THE KEY ISSUES DOE SHOULD CONSIDER AS IT DECIDES HOW TO

PROCEED

Viewpoint A :

• One fallacy here is idea that we have a new process -- we have

proposals about new procedures and analytical methods.

• Acknowledges that old process is badly broken. Maybe it is so broken,

it is no good for any product, even those that are already done,

including ranges and refrigerators

• How will DOE apply new, maybe not yet developed, analytical

techniques to any one product - all of this assumes that a standard is the

best approach

• Process that is not well developed will not have a good product-- wants

more certainty with regard to process and tools -- evolutionary approach

gives no certainty

Viewpoint B:

• Expediency in getting results will hopefully be outcome. Lets not drag

it out-need start date

• Start transition from where we are-don't backtrack

• More thought has gone into new process than went into old

• All agree old process delayed by gridlock; let's not go back and reinvent

processes that are almost done, e.g. refrigerator

• Can't wait for perfect tool to go forward

General:

• Incorporate uncertainty into the impact analysis

• Everyone agrees on the open participation part of the new process, but

not on the rest. Details will have to be fleshed out product by product

using this process _

• Don't lump together refrigerators with other rulemakings-don't

revisit standards for refrigerators

• Ranges, ovens, microwave ovens-would not want to apply new

process to these; want most to get it done quickly

• If you delay at the national level, must delay state preemption

• Issues concerning the analysis of impacts are substantive and difficult

• Law doesn't ask DOE to prioritize rulemakings or products

pitscrn.002

20 March 29, 1996

 EE-PI-96-001 COMMENT 21

• 

MARCH 20 - REPORT ON BREAKOUT SESSION FOR WHITE GOODS 

The questions to be addressed in this workshop resulted in two major point of views which 

are presented below. 

1. WHAT ARE THE KEY ISSUES DOE SHOULD CONSIDER AS IT DECIDES HOW TO 

PROCEED 

Viewpoint A : 

• One fallacy here is idea that we have a new process -- we have 

proposals about new procedures and analytical methods. 

• Acknowledges that old process is badly broken. Maybe it is so broken, 

it is no good for any product, even those that are already done, 

including ranges and refrigerators 

• How will DOE apply new, maybe not yet developed, analytical 

techniques to anyone product - all of this assumes that a standard is the 

best approach 

• Process that is not well developed will not hav.e a good product-- wants 

more certainty with regard to process and tools -- evolutionary approach 

gives no certainty 

Viewpoint B: 

• Expediency in getting results will hopefully be outcome. Lets not drag 

it out-need start date 

• Strut transition from where we are-don't backtrack 

• More thought has gone into new process than went into old 

• All agree old process delayed by gridlock; let's not go back and reinvent 

processes that are almost done, e.g. refrigerator 

• Can't wait for perfect tool to go forward 

General: 

• Incorporate uncertainty into the impact analysis 

• Everyone agrees on the open participation part of the new process, but 

not on the rest. Details will have to be fleshed out product by product 

using this process _ 

• Don't lump together refrigerators with other rulemakings-don't 

revisit standards for refrigerators 

• Ranges, ovens, microwave ovens-would not want to apply new 

process to these; want most to get it done quickly 

• If you delay at the national.level, must delay state preemption 

• Issues concerning the analysis of impacts are substantive and difficult 

• Law doesn't ask DOE to prioritize rulemakings or products 

20 

pi tscrn. 002 

March 29, 1996 
• Need definition of triggering event to initiate process, other than what a

particular interested party wants

• How will the new process be evaluated to see if it is working

• Still need to have defined target, e.g. define "economically justified"

• Process is set of tools - helps if using the correct tools. This process is

not yet a defined set of tools. Need to set agenda to develop tools

efficiently -process needs to be pretty well developed before using it on

a product

2. CANDIDATE PRODUCT TO GO THROUGH THE PROCESS

Viewpoint A:

• Need way to debate/discuss either in a vacuum (abstractly) or around a

product. The latter makes more sense. Do it around one with great

potential savings and one where there is not great controversy and

competitive struggle- this is a vote against clothes washer -- nominates

dishwasher

• Criteria for test case : not great competitive struggle , potential savings,

potential savings in the long and short term

Viewpoint B:

• For big savings: clothes washers- analysis is in limbo currently. Might

be good candidate for test case

• But if you don't tackle the hardest ones to determine the process, how

do we know if the new process will work on those in the future?

• DOE has to make a judgement call on when the process is ready to deal

with a controversial issue

• Maybe a test case is not needed just transition on all products that are

not near completion-DOE can decide to adopt parts of the new process

as appropriate for where the process stands in relation to a product

pitscrn.002

2 1 March 29, 1996

 EE-PI-96-001 COMMENT 21

• 

• 

• 

.. 

Need definition of triggering event to initiate process, other than what a 

particular interested party wants 

How will the new process be evaluated to see if it is working 

Still need to have defined target, e.g. define "economically justified'i 

Process is set of tools - helps if using the cOl:rect tools. This process is 

not yet a defined set of tools. Need to set agenda to develop tools 

efficiently -process needs to be pretty well developed before using it on 

a product 

2. CANDIDATE PRODUCT TO GO THROUGH THE PROCESS 

Viewpoint A: 

.. Need way to debate/discuss either in a vacuum (abstractly) or around a 

product. The latter makes more sense. Do it around one with great 

potential savings and one where there is not great controversy and 

competitive struggle- this is a vote against clothes washer-- nominates 

dishwasher 

.. Criteria for test case: not great competitive struggle, potential savings, 

potential savings in the long and short term 

Viewpoint B: 

.. For big savings: clothes washers- analysis is in limbo currently. Might 

be good candidate for test· case 

.. But if you don't tackle the hardest ones to determine the process, how 

do we know if the new process will work on those in the future? 

.. DOE has to make a judgement call on when the process is ready to deal 

with a controversial issue 

.. Maybe a test case is not heeded-just transition on all products that are 

. not near completion-DOE can decide to adopt parts of the new process 

as appropriate for where the process stands in relation to a product 

21 

pitscrn.002 

March 29, 1996 
MARCH 20 - PROCESS IMPROVEMENT WORKSHOP

REPORT ON THE BREAKOUT SESSION FOR ELECTRICAL PRODUCTS

ISSUES:

Participants responded to the following questions:

• What are the key issues that the Department should consider as it decides how to

proceed with this rule?

• Why are these issues important?

• Which product should serve as a "test case " for the new process and why?

DISCUSSION:

Participants believed that test procedures were very important and necessary for completion of

other aspects of rulemaking for electrical products. Identification of priorities was simply

stated, "Do what comes first. Do what you have to do according to the statute."

Participants identified a number of issues that were product-specific and issues that cut across

product lines.

What are the key issues that the Department should consider as it decides how to proceed

with this rule? Why are these issues important?

Participants identified key issues and their importance.

• For a product rule that is partially completed, how does the old process compare with

the new process? Can the new process be utilized to complete the product rulemaking

in progress?

Natural market forces should be considered in the screening and priority setting

process. Is there sufficient market pull that the market will take care of itself?

-What are the potential savings from rulemaking vs no rulemaking?

A contractor should be competent and have no bias or predisposition toward a certain

outcome when conducting a technical or economic rulemaking analysis for a-candidate

product.

-Manufacturing impact analysis on ballast manufacturers was not completed

and not part of the final analysis.

-Need timely results. Time delays and uncertainty of any results are killers.

pitscrn.002

22 March 29, 1996

 EE-PI-96-001 COMMENT 21

MARCH 20 - PROCESS IMPROVEMENT WORKSHOP 

REPORT ON THE BREAKOUT SESSION FOR ELECTRICAL PRODUCTS 

ISSUES: 

Pruticipants responded to the following questions: 

• What are the key issues that the Department should consider as it decides how to 

proceed with this rule? 

• Why are these issues important? 

• Which product should serve as a "test case" for the new process and why? 

• DISCUSSION: 

Participants believed that 'test procedures were very important and necessary for completion of 

other aspects of rulemaking for electrical products. Identification of priorities was simply 

stated, "Do what comes first. Do what you have to do according to the statute." 

Participants identified a number of issues that were product-specific and issues that cut across 

product lines. 

What are the key issues that the Department should consider as it decides how to proceed 

with this rule? Why are these issues important? 

Participants identified key issues and their importance. 

• 

'. 

• 

For a product rule that is partially completed, how does the old process compare with 

the new process? Can the new process be utilized to complete the product rulemaking 

in progress? 

Natural market forces should be considered in the screening and priority setting 

process. Is there sufficient market pull that the market will take care of itself? 

-What are the potential savings from rulemaking vs no rulemaking? 

A contractor should be competent and have no bias or predisposition toward a certain 

outcome when conducting a technical or economic rulemaking analysis for a candidate 

product. 

-Manufacturing impact analysis on ballast manufacturers was not completed 

and not part ~f the final analysis. 

-Need timely results. Time delays and uncertainty of any results are killers. , 

22 

pitscrn.OO2 

March 29, 1996 
• Energy forecasting models need better explanation.

-Is the model the appropriate analysis tool?

-What assumptions were factored in?

-How was data interpreted?

-What assumptions were entered?

-V' ho did modifications to the COMMEND model and how?

• Unlike consumer products, commercial products are typically components of larger

systems. They interact with other things.

-Should standards be set for the component (lamp _Q^r ballast)?

-Should standards be set for the system (lamp and ballast)?

-Should the interaction of other standards be considered?

--ASHRAE 90.1.

--Building standards vs product standards.

• How will the new process fit into the determinations for high intensity discharge

lamps, distribution transformers, and small motors?

• How are priorities set? What are the consequences of setting priorities? How often

are priorities reviewed?

-For example, manufacturers provided data showing that a certain high intensity

lamp type is disappearing from the market. This should a prime criterion in

setting a low priority.

-If a low priority is given to, for example, certain high intensity discharge

lamps or no standards are established at the Federal level, what action could be

taken by individual states?

--Need to address preemption/release from preemption.

-Review priorities every three years.

--Issue priorities and revised priorities as part of the Regulatory Agenda.

--Publish Regulatory Agenda in the Federal Register.

.Which product should serve as a "test case" for the new process and why?

Participants identified three products as possible candidates for a "test case" study of the

process: lamp test procedures; electric motor test procedures; and ballast .standards.

•' Lamp and electric motor test procedures past the priority phase and now into the

screening phase.

• Ballasts

-Deemed most suitable as a hybrid test case for electrical products.

--the prioritization phase should be done in parallel with the completion

of the analysis - and done soon!

-Already a " guinea pig " because they have already been reanalyzed using the

pitscrn.002

23 March 29, 1996

 EE-PI-96-001 COMMENT 21

• Energy forecasting models need better explanation. 

-Is the model the appropriate analysis tool? 

-What assumptions were factored in? 

-How was data interpreted? 

-What assumptions· were entered? 

-V,fTho did modifications' to the COMMEND model and how? 

• Unlike consumer products, commercial products are typically components of larger 

• 

• 

sy stems. They interact with other things. 

-Should standards be set for the component (lamp ill ballast)? 

-Should standards be set for the system (lamp and ballast)? 

-Should the interaction of other standards be considered? . 

--ASHRAE 90.1. 

--Building standards vs product standards. 

How will the new process fit into the determinations for high intensity discharge 

lamps, distribution transformers, and small motors? 

How are priQrities set? What are the consequences of setting priorities? How often 

are priorities reviewed? 

-For example, manufacturers provided data showing that a certain high intensity 

lamp type is disappearing from the market. This should a prime criterion in 

setting a low priority. 

-If a low priority is given to, for example, certain high intensity discharge 

lamps or no standards are established at the Federal level, what action could be 

taken by individual states? 

--Need to address preemption/release from preemption. 

-Review priorities every three years. 

--Issue priorities and revised priorities as part of the Regulatory Agenda. 

-: Publish Regulatory Agenda in the Federal Register. . 

. Which product should serve as a "test case" for the new process and why? 

Participants identified three products as possible candidates for a "test case" study of the 

process: lamp test procedures; electric motor test procedures; and ballast standards. 

• Lamp and electric motor test procedures past the priority phase and now into the 

screening phase. 

• Ballasts 

-Deemed most suitable as a hybrid test case for electrical products. 

--the prioritization phase should be done in parallel with the completion 

of the analysis - and done soon! 

-Already a "guinea pig" because they have already been reanalyzed using the 

23 

pitscrn.002 

March 29, 1996 
elements of the new process (and the manufacturers like the new process quite

a lot).

-Need to revisit priority-setting implications.

--market "pull" `forces.

--energy savings.

--contractor selection.

--impact analysis.

--modeling in the "sunshine"; need more information about how the

COMMEND model operates.

--what effect will a decision on ballasts have on state regulations and

preemption.

Cross-cutting issues.

Participants identified key issues that cut across product lines.

• How will the process improvement be applied to the three basic products in the

electrical group: lamps; ballasts; and motors?

• Test procedures need to be completed early in the process, especially for lamps and

motors.

Determine contractor expertise, any biases, familiarity with the product and the

manufacturing process.

Provide better explanation of energy forecasting models, such as COMMEND. Where

does the model come from and who developed it? Make modeling transparent.

Should energy efficiency standards be set at the component level or the system level?

Should energy efficiency standards be set for buildings or for building components?

-For commercial products, manufacturers preferred to have building standards.

Examine carefully the relationship between state preemption and the priority setting

process.

How often are priorities established? Revised? How can the priority setting cycle be

improved?

ACTION:

This report is provided for information.

pitscrn.002

24 March 29, 1996

 EE-PI-96-001 COMMENT 21

elements of the new process (and the manufacturers like the new process quite 

a lot). 

-Need to revisit priority-setting implications. 

--market "pull" forces. 

--energy savings: 

--contractor selection. 

--impact analysis. 

--modeling in the "sunshine"; need more information about how the 

COMMEND model operates. 

--what effect will a decision on ballasts have on state regulations and 

preemption. 

Cross-cutting issues. 

Pruticipants identified key issues that cut across product lines. 

• How will the process improvement be applied to the three basic products in the 

electrical group: lamps; ballasts; and motors? 

• Test procedures need to be completed early in the process, especially for lamps and 

motors. 

• 

• 

• 

• 

• 

Determine contractor expertise, any biases, familiarity with the product and the 

manufacturing process. 

Provide better explanation of energy forecasting models, such as COMMEND. Where 

does the model come from and who developed it? Make modeling transparent. 

Should energy efficiency standards be set at the component level or the sy stem level? 

Should energy efficiency standards be set for buildings or for building components? 

-For commercial products, manufacturers preferred to have building standards. 

Examine carefully the relationship between state preemption and the priority setting 

process. 

• How often are priorities established? Revised? How can the priority setting cycle be 

improved? 

ACTION: 

This report is provided for information. 

24 

pi tscm. 002 

March 29, 1996 
MARCH 20 - PLENARY SESSION DISCUSSION

NEXT STEPS

• DOE has responsibility to state the initiatives.

• Communicate further ideas to DOE by April 1 with copy to Assistant Secretary.

• Circulate results of this workshop to all participants.

• Need to move beyond overhead slides to policy guidance and rules.

• Topics:

Prioritizing Process

Modeling Issues

Workshops focusing on specific products

Process to establish criteria for how classes of products are set.

0 DOE needs to publish specific goals for transition process.

• Review of "stakeholder" population to ensure appropriate representation of consumers

and retailers.

pitscrn.002

25 March 29, 1996

 EE-PI-96-001 COMMENT 21

MARCH 20 - PLENARY SESSION DISCUSSION 

. NEXT STEPS 

• DOE has responsibility to state the initiatives. 

• Communicate further ideas to DOE by April 1 with copy to Assistant Secretary. 

• Circulate results of this workshop to all participants. 

• Need to move beyond overhead slides to policy guidance and rules. 

• Topics: 

Prioritizing Process 

Modeling Issues 

Workshops focusing on specific products 

Process to establish criteria for how classes of products are set. 

• DOE needs to publish specific goals for transition process. 

• Review of "stakeholder" population to ensure appropriate representation of consumers 

and retailers. 

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pitscrn.002 

March 29, 1996