# -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 Mr. Juan Aroix Avanti Products 8885 NW 23rd Street Miami, FL 33172 Dear Mr. Aroix: March 29, 1996

Thank you for attending the Department ofEnergy's Appliance Standards Process ImprovementWorkshop held on March 19-20, 1996. Your participation provided useful information to betterdevelop the improved process for setting appliance energy conservation standards. Enclosed for yourreview are the flip chartnotes taken during the plenary sessions and small group discussions. In April, we will be sending you a draft report detailing the Department'sproposal. Itwill address our goals and objectives, and how we plan to initiate the newprocess. A copy ofthe transcript ofthe workshop is available for inspection at the Department ofEnergy's FreedomofInformation Reading Room, Forrestal Building, Room lE-190, Washington D.C. 20585-0121, between the hours of 9:00 a.m. and 4:00p.m. Ifyou have any further comments, please send them to Deborah E. Miller in my office at the U.S. DepartmentofEnergy, EE-l, 1000 Independence Avenue, S.W., Washington, D.C. 20585-0121, facsimile (202) 586-9260. Ifyou have any questions, please contactBryan Berringer at (202) 586-0371 or facsimile (202) 586-4617.

Enclosure Sincerely,

Christine A. Ervin Assistant Secretary Energy Efficiency and Renewable EnergyApril 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 

### Mr. Phil Hopkinson Director, Engineering Square D Company P.O. Box 500 1809 Airport Road Monroe, NC 28110 DearMr.Hopkinson: April 1, 1996

Thank you for your interestin the DepartmentofEnergy'sAppliance Standards Process Improvementeffort. Enclosed for yourreview 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 reportdetailing the Department'sproposal. It

### wi1l address our goals and objectives, and how we plan to initiate the new process. A copy ofthe transcript ofthe workshop is available for inspection at the Department ofEnergy's Freedom ofInformation 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.

,Ifyou have any further comments, please send them to Deborah E. Miller in my office at the U.S. DepartmentofEnergy, EE-l, 1000 Independence Avenue, S.W., Washington, D.C. 20585-0121, facsimile (202) 586-9260. If

### you have any questions, please contactBryan BelTinger at (202) 586-0371 or facsimile (202) 586-4617.

Enclosure Sincerely,

Christine A. 

### Ervin Assistant Secretary Energy Efficiency and Renewable EnergyAPPLIANCE 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 APPLIANCE STAQNDARDS PROCESS IMPROVEMENTWORKSHOP 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 AssistantVicePresident 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. TimBegoske 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 PEOPLEWHO REQUESTED INFORMATION 3/26/96

MI. Ron Anderson Maytag 1801 Monmouth Blvd. Galesburg, IL 61401
MI. Ted W. Atkins Vice President

Industry Relations & GovernmentAffairs 5711 R. S. BorehamJI. 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 01923Mr. 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 Mr. John C. Bock President/CEO BockWaterHeaters, 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 WestMorris Street Indianapolis, IN 46231
Mr. Lake Coulson Manager, GovernmentAffairs 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 MarketDevelopment Consolidated Natural Gas Co. 625 Liberty Avenue Pittsburgh, PA ]5222-3199

Mr. Terry L. Chapp Modine HeatTransfer, Inc. 1500 DeKoven 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 DeLimaAssociates 6723 Whittier Avenue Suite L6 McLean, VA 22101

Mr. Terry G. DuBois U.S. Department ofEnergy EE-422, Rm. 5E-098/FOR Washington, DC 20585Mr. 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 Mr. TomEckman NorthwestPower Planning Council Suite 1100 851 S.W. Sixth Avenue Portland, OR 97204-1348
Mr. Timothy'Feldman Vice President, GovernmentAffairs 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 ofEnrgy FE-32, Room 3E-028 Forrestal Building Washington, DC 20585'

Mr. James H. Gazda International Approval Services 8501 E. PleasantValley Road Cleveland,OH 44131-5575

Mr. David B. Goldstein Natural Resources Defense Council 71 Stevenson Street San Francisco, CA 94105

Ms. LindaW. 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 TheAlliance 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-EfficientEconomy 1001 ConnecticutAve., 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. SmithWater Products Company U.S. Hwy 1North, P.O. Box 600 McBee, South Carolina 29101Mr. 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 Mr. David C. Haataja Manager, Governmental Affairs Underwriters Laboratories Inc. Suite 230 818 18th Street, NW Washington, DC 20006-3513
Mr. RobertJ. Hemphill Principal Product Manager Gas Research Institute 8600 WestBryn MawrAve. Chicago,IL 60631-3562
Mr. RobertL. Holding Association ofHome Appliance Manufacturers 20 NorthWacker Drive Suite 1500 Chicago, IL 60606
Mr. Douglass C. Horstman Maytag 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. BertramKalisch American Gas Association 1515 Wilson Blvd Arlington, VA 22209
Mr. RobertB. Latta Mathematical Statistician DOE, Energy Information Administration 1000 Independence Ave, S.W. Washington, DC 20585 Mr. Harold W. Heiss American Electric Power Marketing Department 1Riverside Plaza Columbus, OH 43215-2373

Mr. James E. Hill National Institute ofStandards 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 AppliancePark, 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 75379-9900Mr. 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 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 ofSenator Harkin 531 Hart Office Building Washington, DC 20510

Mr. StevenM. 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 Applaincepark, AP3-215D Louisville, KY 40225
Mr. Mark S. Menzer Air-Conditioning & Refrigeration Institute 4301 NorthFairfax Drive Suite 425 Arlington, V A 22203
Ms. Sharon E. Miner Legislative Correspondent Office ofSenator 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 ofFlorida Department ofCommunity Affairs 2740 Centerview Drive Tallahassee, FL 32399-2lO0
Mr. Philip J. Manthei SeniorMgr., 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 NorthMoore 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 ofConsumer Protection 601 Pennsylvania Avenue, NW Washington, DC 20580 Mr. RobertW. Murray V.P., CommunicationsInvestorRelations MagneTek, Inc. 26 Century Blvd., 37214 P.O. Box 290159 Nashville, TN 37229-0159Mr. 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 

### Mr. Wayne M. Myrick Sharp Electronics Corporation Sharp Plaza (Box 13) Mahwah, NJ 07430-2135 Ms. Shirley 1. 

### Neff StaffEconomist COlmnittee on Energy & Natural Resources United States Senate 364 Dirksen Building Washington, DC 20510

Mr. Edward R. 

### Osann American Council for an Energy-EfficientEconomy 1001 ConnecticutAve., NW, Suite 801 Washington, DC 20036 Mr. MarkW. 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. WilliamB. Prendergast Vice President, GovernmentAffairs 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 ConnecticutAve., 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 WestMorris 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 ValmontElectric, Inc. 1770 Commerce ParkDr. ElPasso, TX 79912Mr. 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 

### Mr. Bill Prindle Alliance to Save Energy 1725 K Street, NW, Suite 509 Washington, DC 20006
Mr. W. A. ( 

### Buzz) Reed Vice President, ChiefEngineer U -Line Corporation 8900 N. 55th Street, P.O. Box 23220 Milwaukee, WI 53223 Mr. Edward A. 

### Reid, Jr. Vice PresidentMarketing 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. BillShahin 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 PresidentEngineering Nordyne 1801 Park 270 Drive Box46911 St. Louis, MO 63146-6911

Mr. John O. Richardson Tennessee Valley Authority 110 I Market Street, WR5H Chattanooga, Tennessee 37402-2801

Mr. Michael C. Rivest Arthur D. Little, Inc. 955 L'EnfantPlaza SW, Suite 4200 Washington, DC 20024-2119
Mr. Charles A. 

### Samuels GovernmentRelations Counsel Association ofHome 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 98052Mr. 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 

### 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 ofEnergy Polic'y & 

### 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 ofStandards 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 WestMorris Street Indianapolis, IN 46231

Mr. Richard F. 

### Topping, P.E. ArthurD. Little, Inc. 20-529 Acorn Park Cambridge, MA 02140-2390

Mr. Otto Z. Vago State Industries, Inc. 500 By Pass Road Ashland City, TN 37015-1299Mr. 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 

### 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. RobertW. Wisbey Vice President, Product Technology Advance Transformer Company 10275 WestHiggins 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 DriveWest Richardson, Texas 75081
Mr. Lawrence R. Wethje Air-Conditioning & 

### Refrigeration Institute 4301 North Fairfax Drive Suite 425 Arlington, VA 22203

Mr. John A. Wilson CaliforniaEnergy 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 95518-1101Mr. 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 

### 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 PresidentValue 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, PAl7604 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, Room7-126 Palo Alto, CA 94304
Mr. Jim Campbell EnergyEfficiency and Renewable Energy Customer Service Center P.O. Box 3048 Merryfield, VA 22116
Ms. Jane Ransdell Senior Engineer, Home Laundry General Electgric Company AppliancePark, APl-2NN-95 Louisville, KY 40225
Mr. JeffFollett Design Engineer, Laundry Products Frigidaire Company 400 Des Moines Street Webster City, IA 50595-1499Ms. 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 Ms. DebraBedyn Executive Director, National Association

ofState 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. ChiefEngineer-Bldg. MatI. & Hearth Products Warnock Hersey, Inc. 8451 Murphy Dirve Middleton, WI 53562
Mr. MikeMcGraph 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 DevelopmentAssociation 260 Madison Avenue New York, NY 10016 Mr. CarlMayor Dunkirk Radiator Corp. 85 Middle Road DunkIrk, NY 14048

Mr. Steve Navener National Institute ofStandards & Technology Building 226, Room A-313 Gaithersburg, MD 20899
Mr. RobertMarson, P. Eng. Senior Standards Engineer InternationalApproval 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 BrooklynUnion 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 H3C457Mr. 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. Larry Moon Martin Industry P.O. Box 128 Florence, AL 35631 Mr. Gordy Schnabel Manager, ContractPrograms Raytheon Suite 1500 1215 Jefferson Davis Hwy. Arlington, VA 22202

Mr. JohnCrouch Harth ProductAssociation 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 ProductDesign Manager lumisitemas, s.a.dc c.v.blvd. toluca 520-A naucalpan dejurez 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 StreetNW Suite 700 Washington, DC 20005

Ms. LiraBehrens 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. JackLinard Lever Brothers Company Research & Development Center 45 River Road Edgewater, NJ 07020

Mr. Eric Sikkema NCSL 1560 Broadway, Suite 700 Denver, CO 80202Mr. 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 

### Mr. John Batey Energy Resource Center 35 Fawn Road Easton, Connecticut 06612
Mr. Atul Vir Equator Corporation Arena Tower II 7324 SouthwestFreeway, 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 ofState Energy Officials 1615 M Street, NW Washington, DC 20035 Mr. JimTaite Director Florida Energy Office Department ofCommunity 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. CindyMerrie 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 13221Flip 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 Flip Chart Notes ofParticipants 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 BREAKOUTSESSION
................................ 16

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

- 19 WHITE GOODS BREAKOUT SESSION
................................... 20

- 21 ELECTRICALPRODUCTS BREAKOUT SESSION
................. 22

- 24 PLENARY SESSION DISCUSSION

- NEXT STEPS
................ 

### 25

1 pitscrn.002 March 29, 1996MARCH 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 ., . MARCH 19 - PLENARY SESSION DISCUSSION 

### The questions that arose during the first day ofthe 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: Whatcriteriawill be applied to screening and prioritizing? Analysis: What methods ofanalysis will be used? Goals: What are DOE's goals, targets? Consumers: How are consumers part ofthe process? Evaluation: Whatare 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? Whatlevel ofinformation will be required before design option will be considered (e.g. patent)?
2 pitscrn.OO2 March 29, 1996Technology 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**~echnology** 

### on which standards are based mustbe generally available. Patent submissions

- where do theyfit? Patents alone do notdetermine that aproduct should be considered as a viable design option. (Complex issues raised and industry input was invited) Evaluate an unsuccessful lUlemaking episode and try to learnfrom it. Change nature ofpublications that occur at ANOPR stage by including proposals ofinterested**parti~s.** 

### During screening process publish intentto hold workshop which will gatherinput 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 ofthe process? The lack oftlUst in and experience with the new process is a critical issue. Take a standard and lUn itthrough 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 inthe future impact analysis? Has DOE puttogether 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 aregulatory schedule? Does DOE have adequate staffto conductthe kinds ofparticipatory processes being talked about? Where will this process be applied? New class ofproducts? 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 

### Once ANOPR wlitten, will itbe a closed standard? Can there be anotherloop? Can variance from averages be betterunderstood and appreciated

-- nothomogenized with majority? (Pay more attention to needs at the margin.) Insufficientdifferentiation between the issues presented today. More priOlitization is needed.
STAKEHOLDERS 

### "Stakeholders" (the ad hoc group) are notjustthose who did the work before this meeting (workshop). We are all "stakeholders". Define "stakeholders". Who are the "peers" in peerreview? How do the differentinterests get brought to bear on screening (e.g. consumers, manufacturers, nation)? Will testprocedures be peerreviewed? Will peer review be done by contractors, experts, stakeholders? Does the process involve stakeholdernegotiations as aparallel process? Interested party negotiations are one tool, to be evaluated in context oflikelihood ofyielding useful information. Can we submitcomments after this meeting? How will you get full range ofinputto decision-makers?

.Who were the people involved in the stakeholderwork group and their affiliations? Are the decisions already made

-- the report written? What will this meeting resultin? How will you organize and operate stakeholderreview? How will stakeholders be selected? Are the same people addressingprioritization and screening?



### 4 pitscrn.OO2 March 29, 1996Where 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 

### Where did contractorexpertise get discussed? How will interested**partie~** 

### be invited to offer input. Note gov'tprocedures for selection? Whatconstitutes "stakeholders"? Invite and accepthelp from private sector in developing models/processes.

AUTHORITY 

### Wha1 is the scope ofMcCabe's authority? What commitments can DOE make to transition? Sho'w us DOE is really going to do things differently! Iffederal regulations were suspended, could states pre-empt them? How do you reconcile a desire to apply a market-driven regulatory developmentprocess with acommand and control"approach?

....And whatis DOE's range offlexibility 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 improvementinitiative) lead to statutory action? Are new regulations needed? Ifthere is consensus on either ofthese, how will this occur?

CRITERIA 

### Benefits exceed burdens. (This is one criteriaimplied 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 productdesign questions. Identify and define the criteriafor "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. 1996How 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 How have you grappled with "max tech", "technology forcing" issue? Are codes designed to be energy source neutral and productneutral? Prioritization.-- What are the criteria

### t9 be? What objectives are they designed to meet? Source Btus and End-use Btus

-- neithershould be sole basis for detetmination ofstandards.

ANALYSIS Will testprocedures have to be consistent with old standards? How will you ensure technical experts are the tight and**qualif~ed** ones? To whatextentcan models be replaced wit}1 more accurate methods ofanalysis? Can we speak in plain English aboutmodels (simplify and rp.ake more understandable)? Can we do away with models (replace with information)?

-Run through a "model" (testcase) ofthe rulemaking process and of design suggestions.

Process changes mustbe 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 ofproposed models/ctitetiaand draft regulations from ptivate industry sources needed by DOE.

GOALS Enunciate clearergoals and considerations: Economic Environmental Energy Secutity 

### ------------> Avoid negative impact on future generations
Should the process be performance focused rather than productfocused? i.e, broader conservation/consumption goals with more flexibility in how to reach them?

6 pitscrn.002 March 29, 1996Priority 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 PriOlity setting is still ambiguous. Whose agendais itdriven by andto whatend? What are the targets? Whatprecludes targets being setthat could be reached more efficiently outside the regulatory process, i.e. the**~arketplace?** Has DOE ever gone through the rulemaking process and not seta standard? Can you estimate when DOE will have the rulemaking done? (Ref. 10/96) Whatdissatisfactions gave rise to this initiative? Whatdoes it mean to add stakeholderdialog to this process? How do energy forecasts impactpolicy? What are the overall goals and objectives ofDOE's rule-making process?

CONSUMER We need to bettereducated consumerwith respectto energy trade-offs. Have consumer advocates contributed to the work so far? Is there a consumer agenda? What is the extent ofconsumer outreachlwhatnew ways are there ofgetting input. When and how will consumers be provided with information to help them select among products? Complex technical efficiency measures are nothelpful to consumers. How to getinputfrom "real" consumers?

EVALUATION What has been the change over the past 5 +/- years ofhi-techlhi-efficiency products in the marketplace? (i.e. how have standards affected the marketplace?) When will the cumulative impact ofstandards be addressed?

7 pitscrn.002 March 29, 1996Will 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 ., . 

### Will new process costmore orless than existing process? Goal: less resource intensive.
What was the outcome ofthe last set ofstandards re: manufacturerimpact? Testimony regarding specific impacts in several areas. How does DOE measurejob creation and promotion ofcompetitiveness?

8 pitscm.002 March 29, 1996MARCH 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. ation? What criteria should be applied to screen products for potential regulation?

pitscrn.002 9 March 29, 1996 MARCH 20

- PROCESS IMPROVEMENT WORKSHOP REPORT ON THE BREAKOUT SESSION FOR SCREENING
ISSUES: Participants in the breakoutsession were requested to respond to the following questions:


### • Whatcriteria should be applied to screen products for potential regulation?


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


### • How should these people be utilized?


### • Whatis the timeline and/or sequencing ofactivities in the screening process? BACKGROUND:

• Thefirst stage ofthe rulemaking process is to determine, through a process of screening through predetermined criteria, what'options apply to a product, whether or notproducts identified in a statute are in fact candidates for regulation, and whatthe extent of !hatregulation should be. DISCUSSION:

• Identify stakeholders and interested parties to set out iss4es, analytical methods, and experts to become involved.

• "Technologically feasible" according tothe statute may be differentfrom "practically feasible" in the real world. Even though a product can be manufactured at max tech, is itpractical to go into full production? Can a productbe serviced? Whateffects will efficiency have on product performance orproduct application: Will itfit? Will it work?

• How does the positive impact ofa regulation on only a few areas affect the entire standards process? Should positive and negative effects be weighted to determine net benefit? What constitutes significantnetbenefits? 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 

### • Product perfonnance versus benefits: Is it "doable" by the manufacturer? Can a certain level ofefficiency be achieved while maintaining the expected pelfonnance of aproduct. Is it "contmllable" by the manufacturer? Does themanufacturercontrol the end-use efficiency ofaproduct, or will the productbe used as acomponentin alarger system where the efficiency per se may lose significance?
. • Is it commercially feasible to produce an energy efficientproduct (not simply economicallyjustified) from a marketing viewpoint? -Whatis the costto manufacturer versus the price to consumer? -What are the costdifferences between a basic technology product and ahigh technology product? -Whatis the overall impact on system efficiency and what modifications to the system are needed to accommodate the energy efficientproduct? -Does the user need or want the energy efficient product? -Othercost considerations: site costs; installation, including hardware and skilled labor; maintainability; long term serviceability and servicing infrastructure. -Cost oftraining or retraining an industry in a new technology.
• Utility (gas; electric; and other fuels and fuel transportation) factors: Whatis the location ofthe cognizant utility company, the area serviced by state orregion, 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 productperformance, costs, and benefits? When does itmake sense to use geographic and regional considerations? -Manufacturers are not always able to design aproductfor the "average" user. -Department models should utilize the full spectrum ofdata, notjust averages. -Can the range ofeffects be estimated by using the expected orknown extreme values in the models, such as sensitivity analysis.

• How much screening is necessary for aproductwhose anticipated impact on energy savings is small versus aproduct whose anticipated impact on energy savings is large?

• How should differences·in the energy efficiency ofcompeting design options be compared: percentage variation oractual efficiency? (Don'tjustlook

# at the differences in efficiency, butthe percent ofdifference 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 

### • Whatexternalities ("out ofthe box") should be considered? -Environmental effects. -Emissions. -Sanitary. -Subjective purchasing.decisions. -Will the energy productefficientperform its intended function: --will the motor start ahigh torque load? --will a waterclosetflush materials thoroughly? --will a showerhead provide sufficient waterto wash hair?

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

• Will natural marketforces, qualitative and quantitative, pull certain energy efficient products into the marketplace voluntarily in lieu ofmandatory 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 ofan energy efficientproduct? What are realistic margins (discount rates)? (These criteriamay belong to the manufacturing phase.)

• Whatquick and accurate decision-making questions should.be asked up front before a detailed screening process is undertaken?

-Is such a producttechnically feasible? -Is 

### manufacture, marketing, and servicing practical? -Are there opportunities for consensus among stakeholders and interested parties?

• What issues or types ofissues 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 orcon standards. --analysis should notprovide an "a priori" means ofarriving 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 --Whatconsumers orconsumer groups are interested and
11 pitscrn.002 March 29, 1996knowledgeable? --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 knowledgeable? --Whatmeans ofcommunication are needed to invite consumers to palticipate in the screening process: Federal Register? commercial

- channels? other media? NOTE: 'Communicationsolely by Federal Register notice was considered inadequate, sinceitis notread 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 ofbroad issues requires broad industry knowledge at a high corporate level. -Phase II: implementation decisions require specific knowledge or expertise at a technicallevel.

Whatis the timeline and/or sequencing ofactivities in the screening process?

• What is next? (Do these quickly.) -What are the big issues orproblem areas? -What are the top three orfour criteria? -What are the top three orfour design options?

-Whatis the degree ofimpact?

• Should the screening process work with the Department ofEnergy orindependently?

• 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? -Whatform should the recommendations to the Departmenttake? -What are the.recommendations for screening criteria?

-What are the legal latitudes and legal constraints ofthe screening process? -What are the'procedural hurdles?'

• How much flexibility does the Departmenthave in changing the existing procedures and still meetthe statutory requirements?

• Where is the boundary between the screening and impactphases? Whatcriteriawill be used to separate them?

12 pitscrn.002 March 29, 1996MARCH 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 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.) Whatis the time line and sequencing for these issues? [did not get addressed in this breakout session] A general discussion and definition ofthe meaning ofimpact analysis (mostly modeling) was sought by the group before addressing these questions:

• Whatis the breadth ofimpact analysis? Where does it fit in the rulemaking process?

• The manufacturers are making the most objections to modeling. Utility modelingis generally done using models supplied by the utilities, and is less controversiaL

• Ed Pollock was asked"for abriefdescription ofthe LBL-MAM manufacturerimpact analysis model, which Ed supplied.

• Itwould be desirable, and maybe possible, to get the answers we need with less modeling.

• Whatimpacts 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 onjobcreation 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 • Impacton existing workforce (e.g. training)

• Whatis the goal ofimpact analysis?

• Ed Pollock summarized the rulemaking process - design options, life cycle cost analysis, trial standards, impacts on manufactui:ers, consumers, economy, environinent.

• EPCArequires standards to be setat the highestlevel thatis technologically feasible and economicallyjustified. Discussion ofthe impact ofnew standards.

• Need to separate resource from technological gap. Standards may be setfor 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 ofcountry.
• Proprietary technology may impact a standard by favoring an exclusive technology.

• Impacts on replacementmarket

- compatibility ofreplacementproductin terms ofsize, hookups, etc.
• Impacts on state and local governments.
• Variability ofimpacts on different manufacturers depending on size and otherfactors.

• Impact on competition.

• Impact on supporting industries such as component suppliers.

• International impacts on trade, foreign regulations and standards, etc.
• Cumulative impact ofstandards on multi product industries. Discussion ofMODELS

- Theirlimitations 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 

### • Models depend on the many assumptions

- there is a great deal ofjudgmentin modeling.

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

• Models sometimes are too complex and not understood.
• DOE needs to evaluate the range ofmodels and analysis methods, and determine which are appropriate in each case.
• Use ofstatistical bench marking as a way ofestablishing 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, butproportion ofinvolvementby manufacturers, utilities, environmental groups and other stakeholders must be "balanced"

• Independent/objective parties should be involved.

• Manufacturerrepresentatives need knowledge ofmodels' impact. The last question to be answered, concerning the time line, was notdiscussed.

15 pitscm.002 March 29, 1996MARCH 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 MARCH20

- 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 notpresented in any order ofpriority, 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 setin EPCA) Projected energy consumption Achieve maximum potential energy savings under economicallyjustified circumstances (NAECA) Life cycle costs Consumer vs. commercial products Complete products vs. components Potential dollar savings to consumer (relates to energy sources) Potential impacton manufacturers-upsetting competitive balance GIVEN THENUMBER OFPRODUCTS, HOWPINELY SHOULD THEY BE PRIORITIZED Devote stafftime to high priority rulemakings First step would be to categorize into high, medium and low priorityconsidering such factors as current status, status ofthe 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 mustbe clear so that itwill focus the decision making at this stage, e.g should DOEproceed with the rulemaking. ( For.example, "Economicjustification,"animportant criteria needs more clarification from DOE) Qualitative factors thathaven't been consideredbefore, e.g. othernational initiatives, marketforces (which products work better without being standardized), majorinternational protocols, extent of already existing consensus, need to be considered.as well as those in legislation. Need to balance between potential savings and degree ofcontroversy

16 pitscrn.002 March 29, 19962. 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 

### 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 orpossibly every five years 4. IMPOR,TANT QUESTION STILL UNANSWERED'

• What are DOE's priorities? • Ifitis necessary to implement this new process, will DOE seekto change the legislation? • Asked for the following in writing • How much flexibility does DOE have under the law • Restate objectives ofstandards • How will each aspect ofthe new process work • Discuss legal constraints-don't justrestate law



### 17 pitscrn.OO2 March 29, 1996MARCH 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 MARCH 20

- REPORT ON BREAKOUT SESSION FOR HVAC & WATER HEATING 1. What are the key issues DOE should consider as itdecides how to proceed?

• Go back to the beginning and come out ofthe closet--be explicit about assumptions;' hold workshops to review and refine assumptions. Ifassumptions are wrong, so is everything that follows. (Some disagree with going back to the beginning after so much workhas alreadybeen done, e.g., in the case offurnaces; others say back up one full step from whateverhas already been done.) Wide participation is the key.

• Tailor the process by productclass; uniformity across all productclasses is unworkable. Hold product-specific workshops and really listen to whatpeople say.
• Involve interested parties in setting ofcriteria through workshops. Getfull spectrum ofinput. Criteria supported by the majority and/orlarge manufacturers don't necessarily work for more specialized products, smallermanufacturers. Look askance at consensus standards--they may be the result ofpower group lobbying.

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

• Don'tmandate technologies which are not in the marketplace.

• Cumulative effect ofoverlapping 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 ofequipmentby installation contractors.
• Educate industry about the rulemaking process; avoid surprises.

• Effects on international agreements.
• Governmentcontractors don't work for analysis ofleading edge technology--theyjust don't have the expertise. Industry experts are essential to the process.
• Don'tconfuse price and cost.
2. Why are these issues important?

• Survival, profitability, internationalcompetitiveness
. . • To achievebenefits which outweigh costs and burdens. 18 pitscrn.002 March 29, 19963. 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 

### 3. What products should be used as a "testcase" 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 testproducts should be in areas with the highestpotential for costeffective energy savings, e.g., residential central air conditioners and heatpumps, residential water heaters (not heat pump waterheaters).

• Other advocate revisiting from the very beginning arulemaking process which has to date been a disaster.

• Still other advise testing the rulemaking process with products which present the most complexity and uncertainty ofpotential savings. A related suggestion is to choose a product which is furthest from having stakeholderconsensus.

19 pitscm.002 March 29, 1996MARCH 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



### •
MARCH 20

- REPORT ON BREAKOUT SESSION FOR WHITE GOODS
The questions to be addressed inthis workshop resulted in two major point ofviews which are presented below. 1. WHAT ARETHE KEY ISSUES DOE SHOULD CONSIDER AS IT DECIDES HOW TO PROCEED Viewpoint A : • One fallacy here is ideathat 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 ofthis assumes that a standard is the best approach • Process that is not well developed will not hav.e a good product-- wants morecertainty 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 • Struttransition 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 perfecttoolto go forward General: • Incorporate uncertainty into the impact analysis • Everyone agrees on the open participation part ofthe new process, but not onthe rest. Details will have to be fleshed outproduct 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 • Ifyou delay at the national.level, must delay state preemption • Issues concerning the analysis ofimpacts are substantive and difficult • Law doesn't ask DOEto prioritize rulemakings orproducts 20 pitscrn.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 "economicallyjustified" • 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 

### • • •



## .. Need definition oftriggering event to initiate process, other than what a particularinterested party wants How will the new process be evaluated to see ifit is working Still need to have defined target, e.g. define "economicallyjustified'i Process is setoftools

- helps ifusing the cOl:recttools. This process is not yet a defined set oftools. 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

.. Criteriafor test case: not great competitive struggle, potential savings, potential savings in the long and short term Viewpoint B:

.. Forbig savings: clothes washers- analysis is in limbo currently. Might be good candidate for test·case

.. Butifyou don't tackle the hardest ones to determine the process, how do we know ifthe new process will work on those in the future?

.. DOEhas to make ajudgementcall 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 ofthe new process

as appropriate for where the process stands in relation to aproduct



### 21 pitscrn.002 March 29, 1996MARCH 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 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 ofrulemaking for electricalproducts. Identification ofpriorities was simply stated, "Do what comes first. Do what you have to do according to the statute." Participants identified a number ofissues that were product-specific and issues that cut across productlines. What are the key issues that the Department should consider as itdecides how to proceed with this rule? Why are these issues important? Participants identified key issues and their importance. 

### • 

# '.

• For aproduct rule that is partially completed, how does the old process compare with the new process? Canthe new process be utilized to complete the product rulemaking in progress? Natural marketforces should be considered in the screening and priority setting process. Is there sufficient market pull that the market will take care ofitself?

-What are the potential savings from rulemaking vs no rulemaking? A contractor should be competent and have no bias or predispositiontoward a certain outcome when conducting a technical oreconomic 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 ofany 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 • Energy forecasting models needbetter explanation.

-Is the model the appropriate analysis tool? -What assumptionswere factored in? -How was datainterpreted? -What assumptions·were entered?

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

• Unlike consumer products, commercial products are typically components oflarger



### •

• systems. They interact with otherthings. -Should standards be set for the component (lamp illballast)? -Should standards be set for the system (lamp and ballast)? -Should the interaction ofother standards be considered?
. --ASHRAE90.1. --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 ofsetting priorities? How often are priorities reviewed? -Forexample, manufacturers provided data showing that a certain high intensity lamp type is disappearing from the market. This should aprime criterion in setting a low priority.

-Ifa 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 ofthe 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 ofthe process: lamp test procedures; electric motortest procedures; and ballast standards.

• Lamp and electric motortest 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 ofthe analysis

- and done soon! -Already a "guineapig" because they have already been reanalyzed using the
23 pitscrn.002 March 29, 1996elements 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 

### elements ofthe 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 improvementbe applied to the three basic products inthe electrical group: lamps; ballasts; and motors?

• Test procedures need to be completed early inthe process, especially for lamps and motors.


### •



### •



### • •

• Determine contractor expertise, any biases, familiarity with the product and the manufacturing process. Provide better explanation ofenergy 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 orthe 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 pitscm.002 March 29, 1996MARCH 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 MARCH 20

- PLENARY SESSION DISCUSSION

.NEXT STEPS



### • DOE has responsibility to state the initiatives.

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

• Circulate results ofthis 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 criteriafor how classes ofproducts are set.
• DOE needs to publish specific goals for transition process.
• Review of "stakeholder" population to ensure appropriate representation ofconsumers and retailers.



### 25 pitscrn.002 March 29, 1996