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 DEPARTMENT OF ENERGY

 ENERGY CONSERVATION STANDARD

 FRAMEWORK PUBLIC MEETING

 REFRIGERATED BEVERAGE VENDING MACHINES

 U.S. Department of Energy

 1000 Independence Avenue, S.W.

 Room 8E-089

 Washington, D.C. 20585

 Thursday, June 20, 2013

 9:00 a.m.

Reported by: Christine Allen,

 Capital Reporting Company
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1 A P P E A R A N C E S

2 FACILITATOR

3 Douglas Brookman, Public Solutions

4

5 PARTICIPANTS

6 Ari Altman, DOE, Office of the General Counsel

7 Steven Bouyelas

8 Satish Bapanapalli, PhD, Pacific Northwest National

9 Laboratory

10 Jim Collins, Automated Merchandising Systems, Inc.

11 (AMS)

12 Sean Gouw, Southern California Edison

13 James Jenkins

14 Christopher Lau

15 Erick Layseca-Flores, Wellington Drive Technologies

16 Charles Llenza, DOE, Project Manager

17 Emily Marchetti, DOE

18 Jim Mathis, Crane Merchandising Systems

19 Mike Mau, Royal Vendors

20 Mark Menzer, Intertek

21 Scott Morris, Pacific Northwest National Laboratory

22 Dipak Negandhi, Royal Vendors
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1 A P P E A R A N C E S

2 Laura Nicholson

3 Elaina Present, Navigant

4 Patrick Powell, Underwriters Laboratories

5 Harvey Sachs, American Council For An

6 Energy Efficient Economy (ACEEE)

7 Susan Sieben, Wellington Drive Technologies

8 Meg Waltner

9 Collin Weber, Navigant

10 Linda Wilson, NYS Office of the Attorney General

11 Arshak Zakarian, Energy Solutions

12 Erick Zehr, Underwriters Laboratories

13

14

15

16

17

18

19

20

21

22
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1 C O N T E N T S

2 Welcome - Douglas Brookman, Facilitator 5

3 Opening Remarks, Introductions, and Agenda 5

4 Review - Douglas Brookman

5 Rulemaking Process Overview - Charles Llenza 11

6 Authority and Definitions - Charles Llenza 20

7 Test Procedures and Test Metrics - Elaina 24

8 Present, Navigant Consulting, Inc.

9 Market and Technology Assessment and Screening 36

10 Analysis - Elaina Present

11 Engineering Analysis - Elaina Present 68

12 Markup and Energy Use Analysis - Scott Morris, 84

13 Pacific Northwest National Laboratory

14 Life-Cycle Cost and Payback Period Analysis - 96

15 Scott Morris

16 Shipments Analysis and National Impacts 111

17 Analysis - Scott Morris

18 Preliminary Manufacturer Impact Analysis - 121

19 Elaina Present

20 NOPR Analyses - Scott Morris 134

21 Other Issues and Comments - Douglas Brookman 145

22 Closing Remarks 147
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1 P R O C E E D I N G S

2 MR. BROOKMAN: Good morning, everyone, and

3 welcome. This is -- are you all set, Christine? Are

4 you all set? This is the U.S. Department of Energy's

5 energy conservation standard framework public meeting,

6 refrigerated beverage vending machines. Today is

7 Thursday, June 20th, 2013, here in the Forrestal

8 Building in Washington, D.C. My name is Doug Brookman

9 from Public Solutions in Washington.

10 We are going to start off with welcoming

11 remarks from Charles Llenza.

12 MR. LLENZA: Welcome to the beverage vending

13 machine framework public meeting. And, on behalf of

14 the Department of Energy, I welcome you to the meeting,

15 all five of us plus the technical staff. And we hope

16 to have a good meeting today. And on behalf of my

17 boss, John Cymbalski, I also welcome you to the

18 Department.

19 MR. BROOKMAN: Thank you.

20 We will start off with introductions. Please

21 say your name and organizational affiliation. Start to

22 my immediate left. You can get used to turning the
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1 microphone on and off.

2 MR. SACHS: Harvey Sachs, American Council

3 for an Energy Efficient Economy.

4 MR. BROOKMAN: Please?

5 MR. COLLINS: Jim Collins, Automated

6 Merchandising Systems.

7 MR. MATHIS: Jim Mathis with Crane

8 Merchandising Systems.

9 MR. MAU: Mike Mau, Royal Vendors.

10 MR. NEGANDHI: Dipak Negandhi, Royal Vendors.

11 MR. WEBER: Collin Weber, Navigant

12 Consulting.

13 MR. MORRIS: Scott Morris, Pacific Northwest

14 National Laboratory.

15 DR. BAPANAPALLI: Satish Bapanapalli, Pacific

16 Northwest National Laboratory.

17 MS. PRESENT: Elaina Present, Navigant

18 Consulting.

19 MR. BROOKMAN: And folks joining us online,

20 welcome. We're glad to have you joining us via the

21 web. How many do we have joining us, Emily?

22 MS. MARCHETTI: Four.
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1 MR. BROOKMAN: Four? Okay. So light

2 attendance today. Maybe we will have more as we go

3 along.

4 Yes, Harvey?

5 MR. SACHS: Is there a chance that our

6 meeting might condense?

7 MR. BROOKMAN: As you know, we will be as

8 efficient and expeditious as we can.

9 MR. SACHS: I will try to be quiet and --

10 MR. BROOKMAN: As a further inducement. I'll

11 try hard not to waste anyone's time here.

12 All of you received a packet of information

13 when you came in this morning. I am going to do a very

14 brief agenda review. You can see we have already done

15 the welcomes. Immediately following this agenda

16 review, there is an opportunity for anyone who wishes

17 to to make opening remarks, brief statements at the

18 outset about what matters to you. Following that, we

19 are going to have a rulemaking process overview and

20 then authority and definitions from Charles Llenza. We

21 will take a break midmorning, around about 10:30,

22 whenever the content in the meeting causes us to get to
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1 it around about 10:30. In sequence, we will continue

2 test procedures and test metrics, following that market

3 and technology assessment and screening analysis, then

4 engineering analysis. We will break for lunch around

5 about 12:00 or 12:30 or so and, following that, markup

6 and energy use analysis, life-cycle cost, and payback

7 period analysis. We will take a break mid-afternoon

8 and then, quickly moving on, shipments analysis, and

9 national impacts analysis, preliminary manufacturer

10 impact analysis, NOPR analyses. And, then, finally, at

11 the end of the day today, whenever we get there,

12 whenever we are finished with this context, there is

13 another opportunity for public comment. Anybody who

14 wishes to make additional comments about issues that

15 haven't been fully covered, sufficiently covered, that

16 would be another time to do that. Okay?

17 And so yes?

18 MR. LLENZA: Can we introduce legal?

19 MR. BROOKMAN: Yes. Yes. Ari, please

20 introduce yourself.

21 MR. ALTMAN: Ari Altman from the General

22 Counsel's Office here.
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1 MR. BROOKMAN: Thank you.

2 MR. LLENZA: Also, can we also get a reading

3 on who is on the web?

4 MR. BROOKMAN: Yes. Let's do that as soon as

5 Emily returns to her seat.

6 MR. LLENZA: Okay.

7 MR. BROOKMAN: So I would ask your

8 consideration as I have written up here on this chart.

9 If you would please speak one at a time? You are

10 already used to turning the microphones on and off.

11 Please say your name for the record each time you

12 speak. There will be a complete transcript of this

13 meeting made available. And we will describe where you

14 can find that. I will be cuing individuals by name to

15 speak. I also wish to encourage follow-on comments by

16 individual. Sometimes the back and forth is very

17 useful for the Department. Please keep the focus here.

18 Turn your machines on silent mode. And if you can keep

19 the focus here as well? Be precise. Share the air

20 time. And, webinar participants, if you would keep

21 your telephones on mute? And if you can raise your

22 hand, and our web mistress will cue me. And then we
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1 will cue you to speak. And you ought to be able to be

2 heard via the a/v system here in the Forrestal

3 Building.

4 MS. MARCHETTI: Here's a list.

5 MR. BROOKMAN: And these individuals Emily

6 tells me have joined us via the web. Arshak Zakarian,

7 Linda Wilson, Patrick Powell, and Susan Sieben.

8 Are there questions here at the outset before

9 we begin? This gentleman just joined us. Do you want

10 to introduce yourself, please? Say your name for the

11 record.

12 MR. MENZER: My name is Mark Menzer. I'm

13 with Intertek Labs.

14 MR. BROOKMAN: Thank you very much.

15 So it's then to Charles Llenza.

16 MR. LLENZA: Okay.

17 MR. SACHS: Can anything be done about the

18 hum on the audio system?

19 COURT REPORTER: I think it's there.

20 MR. LLENZA: I think so, too. It sounds like

21 it's the a/c.

22 MR. BROOKMAN: It was worse earlier. It was
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1 big feedback.

2 MR. SACHS: Always blame the air conditioner

3 people.

4 MS. MARCHETTI: Yes, it is the a/c. It's

5 above us.

6 MR. BROOKMAN: Okay.

7 MR. LLENZA: Okay.

8 MR. BROOKMAN: Charles Llenza?

9 MR. LLENZA: Okay. We have gone over the

10 agenda and a couple of the ground rules. So I will

11 start. The purpose of today's meeting, public meeting,

12 is to present DOE's analytical approaches to be used to

13 evaluate the energy conservation standards for the

14 beverage vending machine rulemaking. This process is

15 part of the process that we use to inform the

16 stakeholders and other parties, manufacturers, et

17 cetera, parties of interest, in terms of the rulemaking

18 process and also provides a forum for discussion in

19 terms of issues that may arise that we may have at this

20 point in time in terms of the equipment. And I

21 encourage all interested parties to please submit data,

22 information, written comments, et cetera, as we go
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1 through this process.

2 You will see these little blue boxes, where

3 we have a request for information. And they're

4 structured in such a way that there is an item number.

5 And we'll make specific question. And throughout the

6 presentation, these issues will be highlighted. We are

7 very interested in having responses from all parties.

8 They're in the framework document, and they're all

9 pretty much codified. So if at any time you refer to

10 any of the questions, please use the numbering system.

11 Okay. So any instructions for submitting

12 comments, as you can see here, we have set up an

13 electronic email box. Please make sure you put the

14 docket number and/or the RIN number as a reference.

15 You can send things in via mail, although we don't

16 encourage that, to Ms. Brenda Edwards. And the address

17 in the information is there. You could send something

18 via courier. And we don't really take phone messages.

19 But any problems that you may have or any issues or

20 concerns or questions, please call. Feel free to call

21 Brenda at the number that is addressed here.

22 The comment period ends July 19, 2013.
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1 That's important. It's a target date in order for us

2 to execute the rulemaking within the schedule. We have

3 limits. It's 45 days from the issuance of the framework

4 document, which has already been issued, June 4th, I

5 believe.

6 MR. BROOKMAN: Maybe you can pause right

7 there --

8 MR. LLENZA: Okay.

9 MR. BROOKMAN: -- and, as we promised at the

10 outset, entertain opening remarks. Any summary

11 statements here at the outset, should there be any at

12 this point?

13 I see none. So proceed.

14 MR. LLENZA: Okay. So I'm going to talk

15 about a little bit of an overview on the rulemaking

16 process here.

17 The Energy Policy Conservation Act of 1975,

18 EPCA, as we refer to it, as amended, directs DOE to

19 prescribe energy conservation standards for these

20 particular types of equipment: beverage vending

21 machines. It also directs DOE to develop or amend

22 standards designed to achieve the maximum improved
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1 energy efficiency that is technologically feasible and

2 economically justified. That's a very critical

3 statement because that's what we strive through

4 throughout the rulemaking process here. And we end up

5 in standards that are meeting those objectives. We do

6 this through the rulemaking process here at DOE and

7 through a schedule and the analyses. As we go through

8 the schedule, the analysis becomes more robust. It

9 also will be disclosed on the website and provided in

10 the Federal Register for the public record.

11 So under 42 U.S.C. 6295(m)(1), we have a

12 requirement that within six years to issue a final rule

13 establishing or amending standards. So basically what

14 this says is that we are required by law to reissue

15 standards on the beverage vending machines every six

16 years. So, basically, within that time frame, we will

17 go again through this rulemaking process and set new

18 standards if that is what we determine here at the

19 Department.

20 Okay. EPCA also directs the Department of

21 Energy to consider seven factors for analysis when

22 setting technologically feasible and economically
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1 justified standards. So in the left-hand column, you

2 see the EPCA requirements. There are seven. And then

3 you see the corresponding DOE analysis that will set up

4 answering those seven requirements that EPCA

5 establishes. And the source of that is quoted on the

6 bottom of the table there.

7 Rulemaking process. The test procedure and

8 the standard rulemakings have specific timelines. In

9 the energy conservation standard, we usually follow

10 four steps. We have a framework document, a

11 preliminary analysis, NOPR, and final rule. Notice of

12 proposed rulemaking is the NOPR, by the way.

13 In the test procedure, you have two steps,

14 which you have a notice of proposed rulemaking and a

15 final rule. Now, these two processes, while separate,

16 still are integrated. And they are integrated

17 timeline-wise because since we are doing background

18 research and analyses for the energy conservation

19 standard, that is a good opportunity to amend the test

20 procedure standards in order to be able to execute the

21 energy conservation standard at the end of the time

22 frame.
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1 In terms of process, the energy conservation

2 standard takes about three years. And the test

3 procedure, while it is a year and a half, that test

4 procedure can slide within the time frame of the energy

5 conservation standard timeline in order to accommodate

6 adjustments as we go through the process since it takes

7 three years. And there is a link at the bottom for

8 additional information on the rulemaking process if you

9 are interested.

10 Okay. So I am going to talk again about the

11 energy conservation standard process and just go

12 through the steps briefly. Today we are doing the

13 framework document. Basically, it provides an overview

14 of the rulemaking process. And it sets the ground

15 rules for everybody to understand what it is that the

16 Department is trying to do. It provides information

17 that we have available at this moment in time. It

18 invites for comments on the proposed approach on the

19 issues. And it was issued -- the framework was issued

20 on June 4th, 2013.

21 Okay. So the most important issue of the

22 framework document I think is we have a list of
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1 questions. And I think that that is one of the things

2 that we encourage everybody, to go through the list of

3 questions. And if you have contributions to the

4 rulemaking process, to please provide us information or

5 comment, questions, or even your opinions in terms of

6 which direction the rulemaking should take in terms of

7 the technical analysis and/or standards.

8 Okay. So the next step in the process, which

9 will be the next six months to eight months, will be

10 the preliminary analysis. So after this meeting, we

11 will go back. And the teams will continue to do work.

12 We will have some information that was maybe released

13 at this time, but certainly by the time that the

14 comment period closes, we will go back and take all of

15 that information, go review our analysis, go review our

16 data, and then come back again with additional

17 recommendations, adjustments, et cetera, and more of

18 our analysis in terms of a preliminary analysis. And

19 we will have a meeting for that.

20 So the different analyses that you see listed

21 here are the ones that we start developing in more

22 detail. We will publish all of this stuff, information
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1 on the website, on the web page that we have for this

2 rulemaking so that people have access to it. And that

3 information will be public, for public consumption.

4 In addition to that, any comments that are

5 made throughout this process would also be placed in

6 the docket. And the docket also will be available for

7 the public to look at, to see other people can compare

8 comments that are made or just people that are

9 interested in seeing what other parties say.

10 The next step would be putting together a

11 notice of proposed rulemaking. That's a draft rule if

12 you want to call it that. We will have received by

13 then hopefully a robust amount of comments and

14 responses to the preliminary analysis, TSD, which is

15 the technical support document. And at this point, we

16 will be proposing potential standards for consumer

17 manufacturers and also the impacts. And we will be

18 providing the analysis that supports that. We expect

19 to do that by the third quarter in 2015.

20 Okay. One of the things I want to make

21 comment to is that each one of these steps, preliminary

22 analysis and the NOPR, will have public meetings also
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1 and a 60-day comment period. So there will be plenty

2 of time to provide input to the Department as we go

3 through the rulemaking process. And after the 60-day

4 comment period closes for the notice of proposed

5 rulemaking, which is the proposed rule, the Department

6 will go back, take the comments from all the

7 manufacturers and stakeholders and interested parties.

8 And we will finalize a rule. And we are expecting to

9 accomplish that in the third quarter of

10 2016.

11 So what does that look like? Here is a

12 little bit of a timeline to show how this process works

13 and the different planned meetings that we have.

14 Again, today is the framework, is the first public

15 meeting that we will have. And then we will issue a TP

16 NOPR. And then we will have a public meeting, which is

17 a test procedure NOPR. We will have a public meeting

18 on the test procedure NOPR. And then we will have a

19 preliminary analysis TSD and then followed by a public

20 meeting. We will take all of the information that we

21 have gathered. And we will finalize the test procedure

22 because without a test procedure, we can't necessarily
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1 do an energy conservation standard. We have to have

2 all these test metrics for establishing that energy

3 conservation standard. And we will then go back and

4 provide a notice of proposed rulemaking, which is the

5 draft rule. We will have a public meeting. And then

6 at the end, we will issue a final rule.

7 And, as you can see, the compliance date,

8 which is the effective date that the standard becomes

9 effective, is three years after the publication of the

10 final rule. So one thing to keep in mind is that it

11 takes three years to get there and another three years

12 for the standard to become effective. So we're not

13 talking about an overnight process here. We're talking

14 about six years. It gives I think plenty of time for

15 everybody to get geared up for that new standard.

16 Okay.

17 We will talk a little bit about authority and

18 definitions in terms of what we have in place now in

19 terms of the rulemakings. Title III of EPCA sets forth

20 a variety of provisions designed to improve various

21 products and equipment. Of course, Title III also

22 establishes our energy conservation program here at the
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1 Department of Energy. So as part of that, we are

2 allowed to prescribe standards for beverage vending

3 machines. That is our authority here based on the EPCA

4 standards. The background. DOE conducted a rulemaking

5 in 2006 for 2009. And we set standards in 2009 and a

6 final rule August 2009.

7 So, again, within the six years, it is what

8 they call a look back provision. We are supposed to

9 come up again and review those standards to make sure

10 that either they are sufficient or if there is other

11 energy to be gained, energy savings to be gained, from

12 these products. And this is all done under the EPCA

13 provisions again.

14 Test procedure authority and background. In

15 December of 2006 the test procedures were issued in an

16 en masse rule, which meant basically that we bundled

17 the test procedures with other test procedures that

18 were incorporated by reference, by law, that we had

19 available to start the rulemaking process here at the

20 Department. And there is a look back provision on the

21 test procedures, also that seven years. And so that

22 coincides with the rulemaking process for the energy
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1 conservation standards and the look back provisions for

2 the energy conservation standard. So we are doing this

3 under EPCA and also under the authority of the look

4 back provisions for both the test procedure and the

5 energy conservation standard.

6 Okay. Definitions. The definition we used

7 for beverage bottled and canned beverage vending

8 machines comes out of EPCA. And the reference is here:

9 42 U.S.C. 6291(40). The definitions added in 10 CFR

10 431.292 in the 2009 BVM final rule were amended to

11 include bottled or canned beverage. And it means

12 beverage in a sealed container; Class A type of

13 equipment, which means refrigerated bottled or canned

14 beverage vending machines that are fully cooled and is

15 not a combination vending machine. Class B machines

16 means any refrigerated bottle or canned beverage

17 vending machine not considered to be Class A and is not

18 a combination vending machine. We determined that

19 there is a combination vending machine category, which

20 means refrigerated bottled and canned beverage vending

21 machines that also has non-refrigerated volumes for the

22 purpose of vending other non-sealed beverage vending
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1 merchandise. So the volume means the refrigerated

2 volume -- and it is in cubic feet -- of the

3 refrigerated bottle or canned beverage vending machine

4 as measured by ANSI/AHAM HRF-1-2004. Okay. It is

5 pretty specific. And all of this is available either

6 through the website or in the rules specifically.

7 Okay. The coverage. We cover all of the

8 equipment that meets the definition. And that is

9 important to understand. If it doesn't fall within the

10 definition, it is not covered. And active standards

11 exist for Class A and Class B vending machines. The

12 effective date was August 31st, 2012. That was last

13 year. So the thing to remember, the 2009 BVM final

14 rule included a placeholder for reserving standards for

15 combination beverage vending machines. That means

16 basically that that does not have a standard currently.

17 And that's also important to know.

18 Okay. That pretty much covers my section.

19 So I am going to turn this over to my colleague,

20 Elaina. And she is going to talk about test procedure

21 and test metrics.

22 MS. PRESENT: Good morning. I am Elaina
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1 Present with Navigant Consulting. And I am going over

2 the test procedure/test metrics. This is the section

3 where we will start getting into some of the DOE

4 requests for comment.

5 As was mentioned, the current DOE test

6 procedure for refrigerated beverage vending machines

7 was published in December 2006. ANSI/ASHRAE 32.1-2004

8 was adopted as the DOE test procedure, with a

9 modification to test equipment with dual nameplate

10 voltages at the lower of the two voltages only.

11 Additionally, section 5.2 of AHAM HRF-1-2004 was

12 referenced for measuring refrigerator volume. And the

13 metric for refrigerated beverage vending machines is

14 daily energy consumption, which is DEC from

15 32.1.

16 In the framework, DOE outlines seven BVM test

17 procedure updates, clarifications, or modifications

18 that it is considering. I have requests for comment on

19 all seven in a few slides.

20 The first of these potential changes is

21 updating the reference method of test. Since the

22 publication of the DOE test procedure, ANSI/ASHRAE
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1 32.1-2010 was issued to supersede ANSI/ASHRAE 32.1-

2 2004.

3 The second of these is clarifying the next4 to- vend beverage temperature test condition with an

5 explicit instruction not to perform any time averaging

6 of temperature data as part of testing using the DOE

7 test procedure.

8 The third is regarding testing at a 90-degree

9 Fahrenheit ambient test condition. DOE is considering

10 elimination of the 90-degree Fahrenheit ambient test

11 condition from the DOE test procedure.

12 The fourth change to the BVM test procedure

13 that DOE is considering is the inclusion of lowest

14 application product temperature. This would

15 accommodate beverage vending machines that dispense

16 product at a temperature other than 36 degrees

17 Fahrenheit.

18 The fifth change under consideration is with

19 regards to product temperature measurements. DOE is

20 considering requiring beverage temperature measurements

21 other than in the next-to-vend position. These

22 additional measurements could assist in identifying the
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1 product class of the equipment being tested.

2 The sixth modification that DOE is

3 considering is an expanded range of lighting and

4 control settings. The current DOE test procedures

5 requires operation with normal lighting and control

6 settings, using only those energy management controls

7 that are permanently operational and not capable of

8 being adjusted by a machine operator. There is no

9 specification for testing machines with permanently

10 operational controls that can be adjusted. DOE is

11 considering the addition of such a specification.

12 Finally, the seventh modification that DOE is

13 considering is the creation of a provision to measure

14 the impact of low-power modes of operation. This would

15 account for energy savings from controls, including

16 those that can be disabled.

17 Now we're getting into the first set of

18 requests for comment. I am going to go ahead and read

19 these aloud. "Item 1-1: DOE requests comment

20 regarding adoption of updated test procedure for the

21 beverage vending machines covered this rulemaking.

22 "Item 1-2: DOE requests comment on the
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1 possible elimination of the requirement to test units

2 at 90 degrees Fahrenheit.

3 "Item 1-3: DOE requests comment regarding a

4 requirement of measurement of product temperature at

5 other than the next-to-vend positions.

6 "Item 1-4: DOE requests comment on the

7 current utilization of low-power modes in certification

8 testing." We are interested in whether "any current

9 models meet the requirements of the current test

10 procedure regarding energy management controls and

11 utilize a low-power mode during the test."

12 MR. BROOKMAN: If you could just pause there?

13 MS. PRESENT: Sure.

14 MR. BROOKMAN: Yes. So you see the requests

15 for comments there on slide 30. Let's just start with

16 those before we proceed to the next bunch. Comments on

17 these four? Harvey Sachs?

18 MR. SACHS: Harvey Sachs. With respect to

19 item 1-2, does DOE have any information, from surveys

20 or elsewhere, on the relative fraction of Class A

21 machines which are installed outdoors? My own down

22 home impression of beverage vendors is that they are
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1 always facing south, just outside the entrance to the

2 service station.

3 MS. PRESENT: While that would probably be

4 useful for the rulemaking itself, the issue at hand

5 here is that currently certification is based entirely

6 on the test result at 75 degrees Fahrenheit, which

7 means that the 90-degree Fahrenheit test is required

8 but not used. If we were to require certification using

9 90 degrees Fahrenheit for, for example, machines that

10 are UL-listed for outdoor use, is that what you are

11 suggesting?

12 MR. SACHS: I am suggesting that I am not

13 particularly knowledgeable in this area, but it

14 certainly seems to me that, whether it is through UL or

15 otherwise, the differentiation of what in the HVAC side

16 would be called weatherized products, products designed

17 to operate outdoors, would be important for this class

18 of equipment.

19 Now, I don't know if that is a subclass of A

20 or something else, but whoever is at the other end of

21 the distribution chain putting this thing in place

22 certainly would seem to have a right to know whether it
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1 is designed for that service.

2 MS. PRESENT: Thank you.

3 MR. BROOKMAN: Charles Llenza?

4 MR. LLENZA: Yes. And we would welcome any

5 additional information that people at the meeting and

6 on the webinar or stakeholders in general may have on

7 this particular topic. I think we just don't have a

8 lot of detailed information in terms of that. I mean,

9 that would probably come better from the manufacturers

10 or people that sell these machines; right?

11 MR. BROOKMAN: Any additional comments? Yes,

12 Jim?

13 MR. MATHIS: Jim Mathis with Crane

14 Merchandising Systems. What we would look to -- and I

15 am certainly not trying to speak for the other

16 manufacturers, but we would look to NAMA to provide

17 that information from an industry perspective as to

18 what volume of Class A machines versus Class B machines

19 are used in a possible outdoor application. Speaking

20 for Crane Merchandising Systems, we currently do not

21 produce a Class A machine that is for use outdoors.

22 All of our equipment that classifies as a Class A piece
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1 of equipment is for indoor use only.

2 MR. BROOKMAN: Thank you.

3 MR. SACHS: This is Harvey. Thank you, Jim.

4 MR. BROOKMAN: Is NAMA represented here

5 today?

6 No. Okay.

7 MR. MATHIS: Jim Mathis, Crane. Eric Dell

8 was going to participate. He let us know earlier in

9 the week that his wife was expecting any day --

10 MR. BROOKMAN: Okay.

11 MR. MATHIS: -- and that he may or may not be

12 here.

13 MR. BROOKMAN: Okay. Well, sometimes an

14 individual manufacturer can speak on behalf of the

15 association. That's the reason I was asking. Okay.

16 Thank you.

17 Well, let's keep going. Any additional

18 comments on 1-1 through 1-4 before we move on? Yes?

19 MR. NEGANDHI: Dipak Negandhi at Royal

20 Vendors. One general comment I would like to make, some

21 of these comments that any rulemaking change to the

22 test procedure should be within the confines of the
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1 ASHRAE standards, because then that is a standard that

2 has been established based on a consensus process. I

3 mean, when rules are made that are outside the standard

4 that are not specified in the standard, it becomes very

5 confusing because the test methods vary so much.

6 MR. BROOKMAN: Okay. Thank you. Okay.

7 We'll move on.

8 MS. PRESENT: Okay.

9 MR. BROOKMAN: Harvey Sachs? We won't move

10 on.

11 MS. PRESENT: Whenever you are ready.

12 MR. SACHS: Harvey Sachs. I have a question,

13 really, just for the manufacturers. The non-covered

14 products are those which mix refrigerated and non15 refrigerated vending. And our groups would be

16 concerned about the possibility of this being used as a

17 loophole that I had a stack of nominally non18 refrigerated and call it a non-classified. And that is

19 not even insulated from the rest of the machine. So it

20 winds up being cooled. So the question I am asking is,

21 is there a need for additional temperature measurements

22 or some other provision to prevent the non-regulated
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1 mixed units from becoming a huge loophole through which

2 an unscrupulous manufacturer might market products that

3 do not conform?

4 MS. PRESENT: Shall I go back to the

5 definition slide while we have this discussion?

6 MR. BROOKMAN: Sounds good.

7 MR. SACHS: So I'm sorry. Combination

8 vending machine is clearly what I am talking about.

9 MR. WEBER: This is Collin Weber from

10 Navigant. I just want to clarify your point. They are

11 not considered non-covered products. They are products

12 for which standards were reserved. And as we get later

13 into today's meeting, I think it will be quite clear

14 that those are in the potential for standards being

15 applied to this rulemaking.

16 MR. BROOKMAN: Okay.

17 MR. SACHS: Thank you, Collin. How does that

18 impact the test method?

19 MR. WEBER: How does that impact --

20 MR. SACHS: Is that going to be discussed

21 also?

22 MR. WEBER: Certainly open for discussion.
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1 MR. SACHS: Thank you.

2 MR. LLENZA: It's open. This is Charles

3 Llenza, the Department of Energy. We won't get into

4 great detail, but obviously that will be part of our

5 test methodology proposal because we don't currently

6 have good, established test methodologies for that type

7 of equipment right now. So that is important to keep

8 in mind. We may not be able to solve it today, but we

9 certainly appreciate lots of comments on that from the

10 manufacturers, by the way -- that would be great -- and

11 the stakeholders, of course.

12 MR. BROOKMAN: Mike?

13 MS. PRESENT: Oh, sorry.

14 MR. MAU: This is Mike Mau from Royal

15 Vendors. This combination vending machine, that's not

16 at all anything that we as a manufacturer produce. So,

17 you know, I don't know about anyone else here, but

18 that's got to be pretty unique, I think, in terms of

19 what is out there.

20 MR. BROOKMAN: Okay. Thank you.

21 So let's move ahead.

22 MS. PRESENT: Okay. This is the second set
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1 of comments under test procedure and test metrics. We

2 have "Item 1-5: DOE requests comment on the testing of

3 low- power modes in a revised test procedure. What are

4 the typical functions of low-power mode in beverage

5 vending machines? Are these low-power modes triggered

6 by scheduled timers, activity, motion sensors, or other

7 environment or state changes? What lengths of time

8 should DOE consider for the full-power mode and low9 power mode?"

10 We have "Item 1-6: DOE requests comment on

11 the applicability of the current test procedure, and

12 all test procedure modifications under consideration,

13 to combination vending machines."

14 And "Item 1-7: DOE requests comment on its

15 proposal to consider modifications to the test

16 procedure to account for energy management systems."

17 MR. BROOKMAN: Harvey Sachs?

18 MR. SACHS: Harvey Sachs. Just a

19 clarification on 1-7. Do you mean energy management

20 systems that are part of the beverage vendor or are you

21 referring to interconnection with building energy

22 management systems or both?
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1 MS. PRESENT: So we can only test the

2 equipment as it is sold or shipped. So this would be

3 when -- in the case energy management controls are

4 integrated into the equipment, that would be what we

5 are discussing.

6 MR. SACHS: Thank you.

7 MR. BROOKMAN: Comments, especially on 1-5 to

8 start, lengths of time DOE should consider for full9 power mode or low-power mode? Thoughts on that?

10 And 1-6? Just scan through the questions

11 there and see if we can get any responses.

12 Okay. I see no additional comments.

13 MS. PRESENT: All right. If you do have

14 comments later on on these items, we can certainly come

15 back.

16 MR. BROOKMAN: Yes.

17 MS. PRESENT: At this point, we are going to

18 move into the rulemaking analyses, beginning with the

19 content of the preliminary analysis, which, as Charlie

20 mentioned, is the next step in this process. We will

21 go through each chapter. And I will start with the

22 market and technology assessment.
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1 The purpose of the market and technology

2 assessment is to characterize the BVM market and the

3 measures available to improve efficiency. The method

4 that DOE uses is to identify and characterize

5 manufacturers of beverage vending machines, estimate

6 shipments and trends in the market, identify

7 technologies that could improve efficiency, and

8 identify regulatory and non-regulatory initiatives

9 intended to improve the efficiency of the equipment

10 covered under this rulemaking.

11 Market and technology assessment has quite a

12 lot of requests for comments. So here is the first

13 slide of them. "Item 3-1: DOE seeks information that

14 would contribute to the market assessment; for example,

15 the manufacturers of this equipment in the United

16 States and the equipment they sell, by equipment class.

17 It is particularly important that DOE be aware of the

18 major and the small or niche manufacturers.

19 "Item 3-2: DOE seeks information on

20 historical annual equipment shipments, both domestic

21 and imports, by equipment class and the corresponding

22 efficiency distributions of these" systems.
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1 "Item 3-3: DOE seeks information on the

2 proportion of equipment shipped annually that replaces

3 existing equipment for each equipment class."

4 MR. BROOKMAN: So it may be that NAMA would

5 be the one that would respond to that kind of a

6 question. Do you know from your association with NAMA,

7 do they collect that kind of data, Jim?

8 MR. MATHIS: Jim Mathis with Crane. NAMA

9 carries that information annually. They would

10 definitely be the clearinghouse for this and any

11 additional information that they did not have because

12 we are limited within the industry related to the

13 number of manufacturers that participate in the

14 program. Crane would feel more comfortable using NAMA

15 as a clearinghouse --

16 MR. BROOKMAN: Sure.

17 MR. MATHIS: -- related to the data.

18 MR. BROOKMAN: Sure. Are there a bunch of

19 manufacturers that don't belong to NAMA?

20 MR. MATHIS: Typically, there are a few. The

21 majority of them that are represented within this

22 portion of our industry that build beverage vending
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1 machines are represented.

2 MR. BROOKMAN: I see. Okay. Good. That's

3 good to know. So, once again, the comment period will

4 be relevant here. And the Department would really very

5 much like to elicit the participation of NAMA and the

6 member companies to get that data in.

7 Okay. So we're going to move on.

8 MS. PRESENT: All right. Equipment

9 characteristics that the DOE has recognized of beverage

10 vending machines include the cooling mechanism, whether

11 the machine is fully cooled or not; the door type,

12 whether it's transparent or opaque; the storage type,

13 whether it's stack or shelf storage; the machine-use

14 designation, which would be the UL-categorized

15 indoor/outdoor or indoor only; the presence of a

16 separate, non-refrigerated volume; and the type of

17 products dispensed.

18 "Item 3-4: DOE requests comment on whether

19 all transparent-front beverage vending machines

20 currently available on the market are fully cooled.

21 "Item 3-5: DOE requests comment on whether

22 all opaque-front beverage vending machines currently
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1 available on the market are zone-cooled.

2 "Item 3-6: DOE requests information on

3 perishable items in beverage vending machines. Do

4 machines that sell perishable items, in addition to or

5 including beverages, ship with different software or

6 controls than machines that sell only non-perishable

7 items? Are they rated differently, such as to food

8 safety specifications? What portion of the BVM market

9 is composed of machines that sell perishable items?"

10 MR. BROOKMAN: So a lot of data potentially

11 there.

12 Dipak?

13 MR. NEGANDHI: Dipak Negandhi, Royal Vendors.

14 The units that are manufactured by Royal Vendors follow

15 categories 3 and 4. Really, there's not a question.

16 Essentially, yes. That's the answer.

17 MS. PRESENT: You're saying all opaque fronts

18 are zone-cooled?

19 MR. NEGANDHI: Right, are zone-cooled --

20 MS. PRESENT: And all --

21 MR. NEGANDHI: -- that we manufacture; right.

22 MS. PRESENT: Right. And all --
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1 MR. NEGANDHI: Glass fronts are fully cooled.

2 MS. PRESENT: Okay.

3 MR. BROOKMAN: Thank you.

4 MR. NEGANDHI: It has been the industry norm

5 and --

6 MR. BROOKMAN: Dipak, maybe you could move

7 that microphone a little closer to you. Thank you.

8 MR. NEGANDHI: That has been the industry

9 norm for some time.

10 MR. BROOKMAN: Okay.

11 MR. NEGANDHI: So that is the current

12 classification of Class A and Class B that DOE follows.

13 And that is how it has been established, I guess.

14 MR. BROOKMAN: Okay. And can you comment on

15 3-6? Do you know? Are there different --

16 MR. NEGANDHI: 3-6, we are not involved in

17 that type of market's products. So we cannot comment

18 on that.

19 MR. BROOKMAN: Okay. Thank you. Jim?

20 MR. COLLINS: Jim Collins, AMS. On 3-4, the

21 answer is many front, transparent-front, machines are

22 combination machines. So they have non-refrigerated
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1 zones and refrigerated zones. So that's kind of a

2 split bag from our industry.

3 Item 3-6, from the food side, yes, if you are

4 vending perishable foods, you need other control

5 software to protect the safety of the food, although in

6 this case if you are reducing your energy, it just ends

7 up being, you know, out-of-service conditions when the

8 food becomes unsafe. And typically of these systems

9 with high efficiency, it is very difficult to pull down

10 a load of food from a higher temperature in time as

11 specified. So it becomes more of a nuisance for the

12 operators when they do so. So they certainly want to

13 have high energy- consuming machines in order to get

14 that pull-down time where they need it to be.

15 MS. PRESENT: I'm going to ask a follow-up

16 question. DOE is aware that there are vending machines

17 that sell things such as, for instance, milk that would

18 be considered perishable. Do these meet different

19 codes or standard requirements in order to vend

20 perishable items?

21 MR. COLLINS: Yes. The basics of the law are

22 established by the FDA. And they are enforced through
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1 our NAMA committee that publishes rules and inspect the

2 manufacturers on an annual basis to be sure that those

3 rules are being followed to ensure food safety.

4 Certainly, yes, milk is a beverage and milk is a food.

5 So we're in the middle on that one.

6 MR. BROOKMAN: Okay.

7 MS. PRESENT: Is there a particular test

8 standard?

9 MR. COLLINS: The standard is written, again,

10 in cooperation with members of the food safety

11 community around the country, actually. And the

12 standard is written and maintained by NAMA.

13 MS. PRESENT: Okay. Thank you.

14 MR. WEBER: This is Collin Weber from

15 Navigant. Just a follow-on. You don't have to meet NSF

16 7 or anything like that?

17 MR. COLLINS: I'm not familiar with NSF 7.

18 It may be part of the standard, but I am not sure.

19 MR. WEBER: Okay. That would be the food

20 safety standard, for example, about refrigerated

21 display merchandise. So I didn't know if there was

22 overlap to vending as well.
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1 MR. NEGANDHI: Dipak Negandhi, Royal Vendors.

2 MR. BROOKMAN: Excuse me. Dipak? Go ahead.

3 MR. NEGANDHI: Dipak Negandhi at Royal

4 Vendors. Jim, there is a NAMA standard for vending

5 equipment and refrigerated equipment. And there is

6 also an NSF standard, 7, for refrigerated

7 merchandisers. And there is an NSF standard also for

8 vending machines in general, not beverage but just

9 vending machines, which is different than the NSF 7. I

10 don't recall the number of the vending machine

11 standard.

12 MR. BROOKMAN: Okay. And Jim?

13 MR. MATHIS: Jim Mathis with Crane. The

14 standard that Jim Collins is referring to is the

15 standard for the sanitary design and construction of

16 beverage vending machines. And, to his point, it is

17 something that NAMA has developed and has represented

18 is from. The FDA participates as well as other

19 organizations throughout the industry and throughout

20 the country as well. And that is the standard that the

21 majority of the vending industry focuses on when we are

22 looking to design a machine that is going to vend
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1 perishable or food items. It does pull from NSF as well

2 as other standards.

3 MS. PRESENT: Thank you very much. That was

4 very helpful.

5 MR. BROOKMAN: Do you have follow-on

6 questions or is that it?

7 MS. PRESENT: I think I'm good. Collin, do

8 you have anything else you want to ask?

9 MR. BROOKMAN: Okay. Great. Thanks very

10 much.

11 MR. SACHS: I have one.

12 MR. BROOKMAN: Harvey?

13 MR. SACHS: Harvey Sachs with a follow-on.

14 What I am hearing is that the issue is that you need a

15 much larger refrigeration system for pull-down than for

16 maintaining temperatures in the unit. And the question

17 is whether either the DOE has authority or it would be

18 wise to treat separately machines which might

19 inherently be more capable of energy-efficient

20 operation by using, for example, variable, variable21 speed compressors so you get both the rapid pull-down

22 and the efficiency associated with part load operation
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1 with the larger heat exchangers. And the question,

2 again, is whether there is either authority or

3 interest. It would seem that that might have some

4 benefits for the regulated industry in allowing some

5 innovation and saving some energy.

6 MR. BROOKMAN: Thank you.

7 Comments from industry? Jim?

8 MR. COLLINS: We had experience with

9 variable- speed compressors and actually produced and

10 shipped several of them until they went obsolete. The

11 general problem that we have in this industry is that

12 our refrigeration capacity, the size of our compressor

13 system, is so small and the volume shipments are so

14 small that the manufacturers of those products are

15 really not interested.

16 MR. BROOKMAN: Thank you.

17 Let's move on.

18 MS. PRESENT: All right. We're on to DOE

19 equipment classes. I don't have the definitions up

20 here, which maybe I should have, but -- well, I'll go

21 ahead. "DOE divides covered equipment into classes

22 based on performance-related features that justify
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1 different standard levels, such as features affecting

2 consumer utility. DOE establishes separate energy

3 conservation standards for each equipment class. For

4 BVMs, the equipment classes were established in the

5 2009 final rule," where DOE established three equipment

6 classes, which are, as we have said, the Class A, Class

7 B, and the combination vending machine. "As part of

8 this rulemaking, DOE could further subdivide existing

9 classes were it warranted due to inherent differences

10 within equipment currently covered by a class.

11 "Equipment class distinctions set in the 2009

12 BVM final rule were based on cooling

13 mechanism, meaning whether a unit is fully cooled or

14 not, and the presence of a separate, non-refrigerated

15 volume. However, fully cooled has no statutory

16 definition. DOE is considering the following

17 definition: fully-cooled beverage vending machine: a

18 refrigerated bottled or canned beverage vending machine

19 within which each item in the beverage vending machine

20 is brought to and stored at temperatures that fall

21 within plus or minus 2 degrees Fahrenheit of the

22 average beverage temperature, which is the average of
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1 the temperatures of all items in the next-to-be-vended

2 position for each selection.

3 "Item 3-7: DOE seeks comment on the

4 equipment classes for beverage vending machines, and on

5 the criteria used in creating the classes. Are the

6 equipment classes appropriate? Are there other factors

7 that should be considered in equipment class

8 distinctions and definitions?"

9 And "Item 3-8: DOE seeks comment regarding

10 the possible use of alternative equipment classes in

11 this rulemaking. Specifically, are there other

12 equipment characteristics that should be considered for

13 equipment class distinctions and definitions?"

14 I'm going to go ahead and read 3-9 and 3-10

15 as well.

16 "Item 3-9: DOE seeks comment on the

17 considered definition of fully cooled vending machine.

18 Does the current language reflect what is used in

19 industry?

20 And "Item 3-10: DOE requests comment on the

21 creation of a new equipment class for machines that are

22 manufactured and sold to vend perishable items,
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1 including or in addition to beverages. How should DOE

2 define equipment sold to vend perishable items? Does

3 this equipment," as we have discussed, "obtain other

4 certifications for vending perishable items? Is it

5 common for beverage vending machines to vend both

6 perishable and non-perishable items? Is the same

7 beverage vending machine offered to vend both

8 perishable and non- perishable items," as in "the

9 equipment is not currently differentiated" in "the

10 marketplace?" So we have got four requests for

11 comment.

12 MR. BROOKMAN: Okay. Let's start with 3-7

13 and 3-8, criteria creating classes, are the equipment

14 classes appropriate, and other factors that should be

15 considered. Mike?

16 MR. MAU: As for the classes, it is

17 acceptable for Royal Vendors.

18 MR. BROOKMAN: The existing classes? Okay.

19 MR. MAU: Yes.

20 MR. BROOKMAN: Additional comments on this

21 point?

22 MR. SACHS: Yes.
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1 MR. BROOKMAN: Harvey?

2 MR. SACHS: Harvey Sachs. With respect to

3 item 3-9, the question, "Does the current language

4 reflect what is used in industry?" I just want to

5 commend the Department. I haven't seen that kind of

6 language in prior rulemakings, but I may have missed

7 it, the effort to align DOE's product classifications

8 with the way the terms are used in the industry. My

9 hat is off.

10 MR. BROOKMAN: Thank you.

11 MS. PRESENT: So, following on that, if

12 someone could tell us if that is what is used in the

13 industry?

14 MR. NEGANDHI: Dipak Negandhi, Royal Vendors.

15 Yes, Elaina, it is used because that is -- again, this

16 all rolls back to the ASHRAE standard, the way ASHRAE

17 32 defines Class A and Class B as fully cooled versus

18 zone.

19 MR. MAU: Well, they are saying everything

20 plus or minus two degrees.

21 MR. NEGANDHI: Do you mean the average

22 temperatures? Is that what you're --
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1 MS. PRESENT: So we are interested in all

2 parts of the definition.

3 MR. NEGANDHI: Right. But, in general,

4 that's what --

5 MR. BROOKMAN: Dipak, do you have your

6 microphone on?

7 MR. NEGANDHI: Yes.

8 MR. BROOKMAN: Okay. Good.

9 MR. NEGANDHI: It's on. So the plus or two,

10 that is the detailed definition. That portion is not

11 in the ASHRAE standard.

12 MS. PRESENT: Right.

13 MR. NEGANDHI: But as far as how it is

14 defined as Class A versus Class B is part of the ASHRAE

15 standards.

16 MS. PRESENT: Right. DOE is interested in

17 finding a line where we can determine if you are on one

18 side, it's Class A and the other, it's Class B.

19 MR. NEGANDHI: Again, I think that DOE should

20 stay within established and approved standards for

21 definition purposes, rather than trying to define new

22 standards and classifications.
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1 MS. PRESENT: Okay. Thank you.

2 MR. BROOKMAN: Of course, DOE is interested

3 if the machines out there are morphing, they want to be

4 able to -- right?

5 MR. NEGANDHI: I agree, yes. If the machines

6 are changing, then it should be right.

7 MR. BROOKMAN: Yes.

8 MR. NEGANDHI: As far as Royal Vendors is

9 concerned, what we manufacture and what we offer our

10 customers are within these classifications.

11 MR. BROOKMAN: Collin, do you want to follow

12 on?

13 Okay. Jim?

14 MR. COLLINS: Jim Collins, AMS. I would just

15 say that, you know, the definition as it stands is

16 probably all right until you get into the technical

17 part. And that, plus or minus two degrees, that is not

18 what is used in industry. I don't know which item

19 number this comment is really directed at, but plus or

20 minus two degrees, very, very difficult to do that.

21 And I know our machines do not do that today. And I

22 don't know if it can be economically feasible to do
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1 that. That's a very tight range.

2 MR. BROOKMAN: What's a sensible, practical

3 range?

4 MR. COLLINS: Maybe plus and minus six.

5 MR. BROOKMAN: Oh.

6 MS. PRESENT: That's something we would

7 definitely be interested in hearing, what you think a

8 reasonable range is. And if you can include that in

9 the written comments as well, that would be very

10 helpful.

11 MR. BROOKMAN: Harvey Sachs?

12 MR. SACHS: Harvey Sachs. A couple of

13 comments. My experience with the ASHRAE standards

14 process is mostly on the HVAC side. And there, there

15 has been a firm line that ASHRAE was doing the method

16 of test and the AHRI was doing the test conditions. So

17 that ASHRAE standards in my experience rarely would set

18 things like the precision or the test temperature. And

19 so it may just be a cultural thing, particularly the 36

20 degrees.

21 With respect to the temperature band, I would

22 ask a question that is an amplification of your item.
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1 And that is, in the ASRAC working group, on certain

2 commercial products, there has been an acceptance of a

3 shift from a two-sided band to a one-sided band. Would

4 that be helpful to the industry, that as far as the

5 government is concerned, if it is 36 or lower, you guys

6 have an implicit lower bound of not wanting it to

7 freeze. Would an approach like that be helpful?

8 MR. BROOKMAN: Dipak?

9 MR. NEGANDHI: Dipak Negandhi. Yes,

10 certainly. That would broaden the allowable ranges.

11 The thing is, going to a tighter or a time-based

12 averaging, when you do that, it does not necessarily

13 reduce your energy compressor run time. It could very

14 well. So what the current method does is provides the

15 plus/minus one degree. That is adequate. But, having

16 a broader range to say, "not to exceed" temperatures,

17 which is more practical, it would allow for more design

18 freedom for the purpose of manufacturing the equipment.

19 MR. BROOKMAN: Charles Llenza?

20 MR. LLENZA: This is Charles Llenza. I think

21 we would be very interested in the opinions of the

22 experts here that work with these machines in terms of
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1 efficiency ratios based on those tolerances also

2 because part of the problem is we try to set standards

3 that save us energy. So the greater the tolerance, the

4 less we are going to lose some of that. So we could

5 theoretically set a higher standard, but, you know,

6 that is not necessarily what we want to do. We want to

7 do something that is more practical and that makes

8 sense with what is available outside, out in the

9 industry. I suppose that if you had an opinion of the

10 ratios or any relationships in terms of testing, in

11 terms of the actual energy savings, relations, that

12 would be of interest to the Department.

13 MR. BROOKMAN: Collin, do you have a follow14 on?

15 MR. WEBER: Yes. This is Collin Weber from

16 Navigant. I just want to take this opportunity because

17 it seemed like a couple of issues were brought up. And

18 it's fair given the fact that there are a number of

19 requests for comments. But I wanted to clarify a

20 couple of things.

21 Jim, Jim Collins, if you could clarify your

22 statement and, you know, just taking away any temporal
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1 variation, just assuming that we know the absolute

2 temperatures within a machine and that's just a

3 function of geometry? Aside from this within two

4 degrees that was suggested in the slides here by the

5 Department, what do you think? You mentioned six, and

6 I would just like to confirm that for a fully cooled,

7 coveredglass-front machine where everything is cooled

8 to the temperature at which it could be vended or

9 approaches by the consumer, you would say that from

10 bottom selection to top selection, six would be a valid

11 range?

12 MR. COLLINS: This is Jim Collins, AMS. I

13 don't want to state an exact number, but if you wanted

14 a typical remark, I think six is probably a viable

15 number based on our machines. And, frankly, it is the

16 top that is the coldest and the bottom that is the

17 warmest. And near the refrigeration output is colder

18 than farther away. So there is a lot of gradient

19 across a machine. The test method today, the ASHRAE

20 test, allows you to average those next-to-vend numbers

21 to come out with the 36 degrees. And that we can

22 handle, but to say that each of those next-to-vend is
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1 within plus or minus, that is difficult. And I also

2 question whether that type of a statement belongs in an

3 equipment definition. That is more of a test

4 procedure, isn't it?

5 MR. BROOKMAN: Okay. Thank you.

6 Yes, Jim?

7 MR. MATHIS: Jim Mathis with Crane

8 Merchandising Systems. The one thing I would like to

9 bring up and remind the Department to consider is the

10 main purchasers of these machines and the operators of

11 this equipment are not here today. And they typically

12 provide us with quality standards and product metrics

13 and product scope design requirements that we as

14 manufacturers drive to obtain. That standard and those

15 requests based on product acceptance on their behalf is

16 what drives a lot of what our products do at the end of

17 the day. So, with regards to temperature bandwidths

18 within the machines, those types of things, Coca-Cola

19 and PepsiCo as the main operators within the industry

20 provide a lot of input towards that, that design.

21 MR. WEBER: Collin Weber with Navigant. So,

22 just back to Jim, so as it's stated here, fully cooled
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1 currently has no statutory definition. So things are,

2 you know, wide open. DOE wants to clarify that. DOE

3 wants to make that, you know, more quantitative. So

4 would a definition based on an average of next-to-vend

5 in the case of a fully cooled machine across the entire

6 face be more acceptable than a temperature band?

7 MR. BROOKMAN: Jim?

8 MR. COLLINS: Yes.

9 MR. WEBER: Thank you.

10 MR. BROOKMAN: Thank you.

11 Okay. Anything else you want to pursue?

12 MS. PRESENT: I think I am good to move on.

13 MR. BROOKMAN: Okay.

14 MS. PRESENT: All right. Another part of the

15 market and technology assessment is to identify the

16 technology options to improve efficiency. Here we have

17 listed the technology options that are listed in the

18 framework document. This is a very wide range. And we

19 won't be using all of these, but we wanted to make sure

20 nothing escaped the net. I am going to come back and

21 put these up again after I have read the request for

22 comment in this section.
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1 "Item 3-11: DOE requests comment on whether

2 any technologies or designs should be added to or

3 removed from the above list. For example, do any of

4 the technologies above raise issues with proprietary

5 designs or issues where testing pursuant to the DOE

6 test procedure does not reflect a change in measured

7 energy efficiency?

8 "Item 3-12: DOE requests comments,

9 recommendations, and data on max-tech levels for Class

10 A equipment, Class B equipment, and combination vending

11 machines.

12 "Item 3-13: DOE requests comment on whether

13 max-tech levels can only be achieved using proprietary

14 designs or whether there are alternative design paths

15 available that can achieve the same energy use level.

16 "Item 3-14: DOE requests comment on whether

17 any technologies or designs should be treated

18 individually, or be incorporated into a few standard

19 'design packages.' If 'design packages' are possible,

20 how should the packages be assembled? DOE would

21 develop potential standard levels based on these

22 packages, but manufacturers could meet any established
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1 standards through the use of any design options.

2 "Item 3-15: DOE requests comment on low3 power modes. What types of low-power modes are

4 currently used in the BVM market? Are there other

5 types of energy management systems about which DOE

6 should be aware that are applicable to beverage vending

7 machines?

8 And "Item 3-16: DOE requests comment on

9 whether transparent-front machines could be designed

10 with zone cooling."

11 MR. BROOKMAN: Yes, Mike?

12 MR. MAU: Mike, Royal Vendors. I have

13 trouble understanding item 3-14. I don't really

14 understand the design packages. Is DOE saying that if

15 we use really high efficient glass pack and a variable16 speed compressor, then we would have a different level

17 of standard that the vending machines would have to

18 meet.

19 MS. PRESENT: Okay. Go ahead.

20 MR. WEBER: This is Collin Weber with

21 Navigant. What we're asking here, it's nothing to do

22 with the regulatory side. It's the engineering side.
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1 We're asking if there are things that have synergistic

2 effects. For example, a variable-speed compressor, you

3 know, might warrant variable-speed fan motors. And

4 those would work better together than if you have a

5 variable-speed compressor but couldn't vary the

6 condenser fan speed. So that's the kind of thing we're

7 asking, is on the engineering side, if there are

8 synergistic things that are always packaged together.

9 MR. MAU: Thank you.

10 MR. BROOKMAN: Let's start with 3-11 through

11 3- 13. Harvey Sachs?

12 MR. SACHS: I said I would try to be quiet.

13 MR. BROOKMAN: It's okay.

14 MR. SACHS: Harvey Sachs, ACEEE. With

15 respect to item 3-11, to us, one critical question is

16 the universe which you are sampling to see what

17 technologies are out there. I am very much taken with

18 Jim's comment from Automated Measuring that compressor

19 sourcing for small variable-speed compressors has been

20 a challenge. I think it is obligatory for DOE to do a

21 little bit of a survey to find out what is in use in

22 comparable capacity products globally. This is now a
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1 global market, compressor side. I can't say the

2 beverage vendor side is. But across these

3 technologies, to us, it is a key question, what is used

4 internationally and can be soured for domestic

5 products. Thank you.

6 MR. BROOKMAN: Okay. Thank you.

7 3-11 through 3-13? And if you could -- good

8 job. That's the slide I want. Yes.

9 MS. PRESENT: Once in a while.

10 MR. BROOKMAN: If you could take a peek at

11 the screen and also, then, look down in your handout to

12 slide 43 and look at these possible technologies?

13 MR. LLENZA: This is Charles Llenza. I just

14 also wanted to make comments. I mean, if there is

15 anything else to add to that list, please also feel

16 free to make comment to that nature.

17 MR. SACHS: Just a note that we certainly are

18 seeing ECM-type, permanent magnet-type fan motors down

19 to the sizes used for the heat exchangers in

20 residential refrigerators, at relatively competitive

21 prices according to one of the manufacturers.

22 MR. BROOKMAN: Thank you.
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1 So if there is no comment on 3-11, how about

2 3- 12, "max-tech levels for Class A and B equipment and

3 combination"?

4 Then, moving on to 3-13, "Max-tech levels can

5 only be achieved using proprietary designs." It would

6 be useful to know early on if proprietary designs were

7 getting in the way of stopping manufacturers from

8 adopting certain options.

9 Yes, Mike?

10 MR. MAU: Mike, Royal Vendors. Something to

11 keep in mind -- and it was mentioned before -- is the

12 customers. There are only a couple. You know, there

13 are not a lot. So when it comes to max-tech levels, it

14 is kind of driven by them. You know, it's -- and then

15 to 3- 13 for can they only be achieved with proprietary

16 designs, well, there are a lot of things that aren't

17 proprietary, like foam wall thickness and efficient

18 compressors, glass packs, you know, actual things that

19 are purchased on the market or manufactured. So I

20 would say that it is not proprietary only.

21 MR. BROOKMAN: Ari?

22 MR. ALTMAN: Hi. This is Ari Altman from GC.
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1 Would you then say that on that list -- it's a pretty

2 long list on slide 42. Would you say any of these must

3 be proprietary, are only proprietary, or are all of

4 those items potentially sourced on the market?

5 MR. MAU: Give me a minute.

6 MR. WEBER: Collin Weber, Navigant. I think

7 one thing that also might clarify, we traditionally --

8 in slides like this, we always use the word

9 "proprietary." But I think what we really mean is

10 protected intellectual property or patented that you

11 could not all go out and obtain and things were really

12 getting --

13 MR. BROOKMAN: Thanks for that clarification.

14 Yes? Go ahead, Harvey. Here.

15 MR. SACHS: This is Harvey again. I think

16 there is a nuance there for this industry, which buys

17 so many of its components outside, as many others do.

18 The question is not whether it is proprietary motor

19 from Regal Beloit or whoever or proprietary compressor

20 but the level at which there is a competitive market,

21 even though the individual components might be

22 protected, in one way or another, by IP. So if there
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1 are multiple compressor manufacturers who are equipped

2 to source their own proprietary solutions at a

3 particular efficiency level, my understanding is that

4 that is important to DOE, not the fact that the basic

5 compressor or motor has some intellectual property

6 around it.

7 Collin is shaking his head yes. Thank you.

8 MR. MAU: I don't recall your name. I'm

9 sorry.

10 MR. ALTMAN: Yes. Ari Altman from GC.

11 MR. MAU: To answer your question, I can't.

12 I can't go through. Without further review, I am

13 unable to make a generalized comment of if they are all

14 one way or another.

15 MR. ALTMAN: Okay. Thank you.

16 MR. BROOKMAN: Thanks.

17 Let's move on to item 3-14 through 16, design

18 packages, low-power modes, and transparent-front

19 machines designed with zone cooling. No comments at

20 this time?

21 Okay.

22 MS. PRESENT: All right. I'll move on, then.
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1 The market and technology assessment includes the

2 identification of baseline models. These represent

3 equipment with the lowest efficiency that's currently

4 available on the market. DOE selects one baseline

5 model per equipment class and, where available,

6 typically selects models that just meet current energy

7 conservation standards.

8 The request for comment, "Item 3-17: DOE

9 seeks comment on how to select baseline efficiency

10 levels for equipment classes without a previous energy

11 conservation standard; for example, combination

12 machines.

13 "Item 3-18: What machine sizes and

14 capacities," in "cubic feet" or "vendible capacity,

15 should be used as analysis points for each equipment

16 class?" I have another question on that later.

17 "Item 3-19: DOE seeks information on what

18 particular components and features characterize the

19 baseline model in each equipment class." And there are

20 some examples of features.

21 MR. BROOKMAN: No comments here?

22 I guess not.
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1 MS. PRESENT: All right. The next analysis

2 that

3 I will be covering is the screening analysis.

4 In the screening analysis, DOE will take the technology

5 options that are identified in the market and

6 technology assessment and screen them using the four

7 following criteria: technological feasibility;

8 practicability to manufacture, install, and service;

9 impacts on product utility or impacts to consumers; and

10 impacts on health and safety. The remaining technology

11 options are referred to as design options and are then

12 fed into the engineering analysis.

13 Request for comment, "Item 4-1: DOE welcomes

14 comment on how the above four screening criteria might

15 apply to any additional technology options that an

16 interested party recommends to DOE.

17 "Item 4-2: DOE welcomes comments on the

18 applicability of the four screening criteria to the

19 technologies listed in the market and technology

20 assessment section."

21 MR. BROOKMAN: Mike?

22 MR. MAU: For 4-2, for the market and
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1 technology assessment, it will be complex when you do

2 that. You need to keep in mind the different

3 refrigerants that are coming to market between

4 (inaudible), CO2, and their different technology levels

5 available in those markets.

6 MR. BROOKMAN: Okay. Thank you. Additional

7 thoughts on these two?

8 MS. PRESENT: All right. And that was the

9 screening analysis. Now --

10 MR. SACHS: I'm slow off --

11 MR. BROOKMAN: Harvey Sachs. Yes?

12 MR. SACHS: Harvey. One of the things in the

13 screening analysis should be to survey what

14 refrigerants are in commercial use in other markets.

15 Are hydrocarbons being used? And are the quantities

16 allowed under the recent SNAP quantities, which would

17 be within the range of requirements for beverage

18 vendors? So that kind of question seems to be an

19 important one for regulations that will come into place

20 in six years and last for a long time.

21 MR. BROOKMAN: Thank you.

22 On to preliminary analysis?
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1 MR. MAU: This is Mike Mau, Royal Vendors.

2 That SNAP ruling I do not believe applies to beverage

3 vending machine.

4 MR. SACHS: I certainly defer to you on that.

5 On the other hand, it does represent a precedent for

6 indoor installations; for example, domestic

7 refrigerators. And I think it is starting to be

8 thought about in some other commercial classes as well.

9 So it seems to be an important part of the baseline is

10 what EPA considers to be acceptable in terms of its

11 safety and other characteristics. Thanks for the

12 clarification.

13 MS. PRESENT: All right. The market and

14 technology assessment and screening analysis both feed

15 into the engineering analysis. The purpose of the

16 engineering analysis is to characterize the

17 relationship between manufacturer selling price and

18 improvements in energy efficiency. The outcome will be

19 cost-efficiency curves for each equipment class similar

20 to the ones seem on the left there, though do make a

21 note that this is a stylized version that is not based

22 on any data. It is just to show what the trend would
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1 look like.

2 These cost-efficiency curves are then used in

3 downstream analyses, like the LCC and payback period

4 analysis, the national impact analysis, the

5 manufacturer impact analysis, and the employment impact

6 analysis.

7 This slide outlines the methodology of the

8 engineering analysis. Starting from the baseline units

9 identified in the market and technology assessment, DOE

10 defines baseline specifications for each equipment

11 class. Both the manufacturer production cost, or MPC,

12 and energy consumption of the baseline units are

13 modeled. The manufacturer production cost is evaluated

14 from sources including public information, such as

15 manufacturer and component manufacturer catalogues,

16 equipment teardowns, manufacturer interviews, and

17 internal research. The energy consumption modeling I

18 will explain a little bit more about on the next slide.

19 Once the baselines are modeled, design options are

20 implemented one by one in the order of shortest payback

21 to longest payback. Both the MPC and energy use models

22 are rerun as the design options are implemented.
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1 Finally, a manufacturer markup is applied to the MPC to

2 calculate manufacturer selling price.

3 Here is a diagram of the components of our

4 energy consumption model. The model we use is a first

5 principles analytical model simulated under the

6 conditions of the DOE test procedure. There are two

7 types of energy consumption in a BVM: a compressor

8 energy consumption due to the heat load and component

9 energy consumption from components, including lights

10 and fan motors. As I mentioned, we used this model for

11 the baseline and then substitute energy-saving

12 components to simulate increasingly efficient models up

13 to max-tech.

14 "Item 5-1: Within each equipment class, for

15 energy consumption levels below the baseline, DOE seeks

16 information on daily energy consumption and on

17 incremental manufacturing costs and components.

18 "Item 5-2: DOE is also interested in any

19 equipment test data that stakeholders can provide,

20 including equipment parameters, test results, and in

21 the case that a test procedure other than the DOE test

22 procedure was used, the test procedures used, and
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1 rating conditions. Test data for the baseline model in

2 each equipment class is particularly important.

3 "Item 5-3: DOE requests feedback on the use

4 of the design option approach to determine the

5 relationship between manufacturer selling price and

6 energy efficiency for beverage vending machines."

7 MR. BROOKMAN: Harvey Sachs?

8 MR. SACHS: Harvey Sachs. For about a

9 decade, ACEEE and others have challenged the simplistic

10 cartoon in slide 51. This is a static picture, not a

11 dynamic picture, and repeatedly, almost without

12 exception, our group has published on this. The

13 dynamics are that the adoption of a standard leads to

14 improvements in design, in sourcing, in component

15 availability, and other factors that lead to decreases

16 in energy consumption, rather than at constant cost.

17 If DOE is to apply a static model in this proceeding,

18 it is incumbent upon DOE to show why it is valid here

19 when that would be an exception to the trend that DOE

20 has accepted. One example of a way it might be

21 appropriate is if this market is so small that it has

22 no leverage at all on the suppliers of its key
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1 components if these are not assembled, rather than

2 being mass-produced. Frankly, it is of concern that

3 DOE's conceptual model continues to be framed on this

4 cartoon without accounting for any of the dynamic

5 effects that have been documented so often. End of

6 rant.

7 MS. PRESENT: Thank you.

8 MR. BROOKMAN: Okay. Thank you.

9 MS. PRESENT: Okay.

10 MR. WEBER: This is --

11 MR. BROOKMAN: We have a request for

12 comments. Yes, Collin?

13 MR. WEBER: May I make one response to

14 Harvey, just from a very general perspective? This is

15 actually going back to one of the very first slides. I

16 just want to point out that some of the dynamic effects

17 and market- shifting effects that you had mentioned

18 would be captured in the fact that DOE is compelled by

19 statute to review these standards every six years.

20 MR. SACHS: I'm sorry, Collin. We can take

21 this offline, but this is irrelevant when the next

22 review is over a decade away.
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1 MR. BROOKMAN: It sounds like a lunchtime

2 conversation.

3 MR. SACHS: Yes.

4 MR. BROOKMAN: Okay. Yes, over lunch. Okay.

5 So we haven't yet addressed item 5-1 through

6 5- 3. Comments on any of these?

7 MR. SACHS: I was addressing 5-1.

8 MR. BROOKMAN: Noting, I mean, the specifics,

9 that is, Harvey. Any additional thoughts on these

10 three?

11 Okay. We're moving on.

12 MS. PRESENT: As I have mentioned, DOE will

13 also develop estimates for manufacturer selling price.

14 This is essentially applying a markup to manufacturer

15 production costs to account for nonproduction costs,

16 such as maintenance, depreciation, R&D, et cetera.

17 "Item 5-4: DOE seeks comment on the markup

18 approach proposed for developing estimates of

19 manufacturer selling prices."

20 MR. BROOKMAN: Charlie? Brenda? So any

21 additional thoughts on manufacturer selling price and

22 the markup approach?
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1 No comments here.

2 MS. PRESENT: All right. A note about

3 proprietary designs. DOE considers in its engineering

4 and economic analyses all design options that have not

5 been screened out, which can include proprietary

6 designs. However, DOE will consider proprietary designs

7 in the subsequent analyses only if they are not part of

8 a unique path to a given efficiency level.

9 "Item 5-5: Are there proprietary designs

10 that DOE should consider for any of the equipment under

11 consideration by this rulemaking? If so, how should

12 DOE acquire the cost data necessary for evaluating

13 these designs?

14 "Item 5-6: Are there alternative design

15 paths that can achieve the same level of max-tech

16 energy use as those that may use proprietary designs?"

17 MR. BROOKMAN: And I thought Collin's

18 clarification was useful. So are there patent19 protected or other mechanisms that would constrain

20 manufacturers from deploying, utilizing new technology

21 options? Dipak?

22 MR. NEGANDHI: Dipak Negandhi. In general,
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1 the patent-protected designs for refrigeration system

2 will always be more cost. And this is where that graph

3 that was shown does show up. It is true that for

4 manufacturers to increase the efficiencies, there is an

5 increased cost to it. It has not happened otherwise.

6 Thank you.

7 MR. BROOKMAN: Okay. Thank you.

8 Yes, Jim?

9 MR. COLLINS: Jim Collins, AMS. Just to say

10 in this very short time, it is difficult to make sure

11 all of the IP is analyzed because that changes, of

12 course, every day. And if we don't go and do searches

13 on that kind of a basis, it's hard to respond this

14 quickly to a question like that.

15 MR. BROOKMAN: Thank you. And I think the

16 Department understands that. Does NAMA undertake that

17 kind of cataloguing scrutiny?

18 MR. COLLINS: No.

19 MR. BROOKMAN: No. I was just curious.

20 Okay.

21 Collin?

22 MR. WEBER: Sure. Collin Weber from
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1 Navigant. If the time frame that you are referring to

2 is in the context of this public meeting, then

3 obviously we understand. And that's the reason why the

4 Department provides the comment period until July 19th,

5 I think. So we would definitely welcome as thorough of

6 comments on that matter as you would be willing to

7 provide given the time to do that due diligence.

8 MR. BROOKMAN: Thanks. Okay. We're moving

9 on.

10 MS. PRESENT: All right. As part of the

11 engineering analysis, DOE selects representative unit

12 sizes within each equipment class. These

13 representative size beverage vending machines are in

14 sizes that represent typical units of the equipment

15 class. The representative unit sizes analyzed for the

16 2009 BVM final rule are shown in the table below.

17 There are small, medium, and large sizes for both Class

18 A and Class B beverage vending machines, represented

19 both in terms of vendible capacity and in refrigerated

20 volume.

21 "Item 5-7: DOE requests feedback on

22 representative sizes. Are the representative sizes
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1 used for the 2009 BVM final rule adequate? Should they

2 be retained or modified?"

3 MR. BROOKMAN: So go back to 58, please.

4 MS. PRESENT: Okay.

5 MR. BROOKMAN: So we ought to be able to get

6 some comments on these; right? You are familiar with

7 what is out there in terms of capacity and in the

8 various classes. Will these work going ahead? Yes,

9 Jim?

10 MR. MATHIS: Jim Mathis with Crane. This

11 table is very representative of the equipment we still

12 produce today.

13 MR. BROOKMAN: Okay.

14 MR. MATHIS: We haven't seen a major shift in

15 market size related to equipment.

16 MR. BROOKMAN: Or demands from your

17 customers.

18 MR. MATHIS: No, we have not.

19 MR. BROOKMAN: Okay. Thank you. That's

20 helpful.

21 Additional comments on this? Let me see.

22 And specifically 5-8 about combination equipment class.
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1 MS. PRESENT: Right. I haven't read that

2 one.

3 MR. BROOKMAN: Go right ahead.

4 MS. PRESENT: "Item 5-8: If DOE were to

5 analyze a combination equipment class, perishables,

6 including or in addition to beverages, equipment class

7 or other new equipment class, what should be the

8 relevant representative sizes for that class?"

9 MR. BROOKMAN: Yes, Jim?

10 MR. COLLINS: Jim Collins, AMS. That is an

11 extremely difficult definition to make, I would think,

12 particularly with vendible capacity. If you're talking

13 about non-beverage items, you know, you can get a lot

14 of Hershey Bars in a machine but, you know, not too

15 many Honey Buns. So that --

16 MS. PRESENT: Well, in volume, perhaps.

17 MR. COLLINS: -- is rather wide open.

18 Pardon me?

19 MS. PRESENT: In volume, perhaps.

20 MR. COLLINS: I'll just make one comment

21 about volume. That AHAM standard is extremely

22 difficult to interpolate into refrigerated volume of
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1 our type of equipment. I mean, I did my calculations.

2 I went to my astute third party, which happens to be

3 Intertek, and he came up with totally different

4 numbers. And we had to try to reconcile our

5 calculations. And we did. But that standard is not in

6 any way directly applicable to our type of equipment.

7 MR. BROOKMAN: Okay. Thank you. I guess one

8 thing that would be useful here is if -- to me, 5-8

9 speaks to things like trend line. If it is headed in a

10 direction that DOE would spot from knowing about it, as

11 you look at 58 again and what is there in terms of

12 class and size.

13 MS. PRESENT: I will also say in reference to

14 the comment you just made, if there are other standards

15 or methods that would be more amenable to beverage

16 vending machines, we are very open to hearing about

17 them.

18 MR. BROOKMAN: In your written comments.

19 Okay. Okay.

20 So final comments on 5-7 to 5-8?

21 MS. PRESENT: The engineering analysis

22 continues from the baseline all the way through max-
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1 tech. DOE is required to analyze the max-tech level,

2 which is the maximum technologically feasible

3 efficiency level. DOE will seek interested party input

4 on the appropriate max- tech levels. In the outside

5 regulatory changes portion of the engineering analysis,

6 DOE will consider the effects of other DOE energy

7 conservation standards and regulatory changes outside

8 DOE's rulemaking process that can impact manufacturers

9 of covered equipment.

10 Some regulatory changes can also affect the

11 efficiency, energy consumption, and/or engineering

12 costs of the beverage vending machines covered under

13 this rulemaking.

14 DOE will attempt to identify any outside

15 engineering issues that could impact the engineering

16 analysis.

17 "Item 5-9: DOE requests information on the

18 use of alternative refrigerants in beverage vending

19 machines, including shipment, cost, and energy

20 consumption information."

21 And "Item 5-10: Are there additional

22 regulatory issues that DOE should consider in its
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1 analysis of beverage vending machines? Do the issues

2 discussed in this section affect shipments, cost, or

3 energy efficiency?"; "this section" referring to the

4 framework document.

5 MR. BROOKMAN: We mentioned refrigerants

6 earlier today. Additional thoughts, comments on that?

7 Dipak?

8 MR. NEGANDHI: Yes. Dipak Negandhi, Royal

9 Vendors. With respect to 5-10, using alternative

10 refrigerants will impact energy efficiency. I think we

11 had earlier discussions on the SNAP setup. For

12 beverage vending machines, the SNAP has approved carbon

13 dioxide as an alternate hydrocarbon refrigerant only.

14 And typical indications are that that type of

15 refrigerant causes a higher energy penalty, actually,

16 going towards the lower, zero, GWP refrigerant.

17 The propane portion, which is the other

18 hydrocarbon being considered, is not yet approved by

19 SNAP for beverage vending machines.

20 MR. BROOKMAN: Okay. Harvey?

21 MR. SACHS: Thank you very much. I may have

22 missed something. We are certainly seeing some
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1 manufacturers suggesting that they are getting

2 efficiency improvements in relatively large charged

3 propane machines, that are in the range of 20 to 25, 30

4 percent. So I am sure you are right that no one has yet

5 submitted a SNAP application for beverage vendors, but

6 that doesn't mean it should not be considered. To me,

7 it doesn't mean it should not be considered in this

8 proceeding as a potential technology that could be

9 applicable in the time scale of interest before a

10 standard goes into effect.

11 MR. NEGANDHI: Dipak Negandhi, Royal Vendors.

12 I agree with Harvey that the potential may be there,

13 but there are two paths. And there are other consumer14 related instances where our customers have to find

15 acceptance of the refrigerants. And, as it was

16 mentioned earlier in this proceeding, there are

17 basically two major users of the equipment that

18 literally dictate this market. And then that's where

19 we will need input from them for alternative

20 refrigerants.

21 MR. SACHS: Thank you.

22 MR. NEGANDHI: Thank you.
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1 MR. BROOKMAN: Additional and perhaps final

2 comments on 5-9 and 5-10? Nothing additional?

3 Okay. Let's take a break. We covered a lot

4 of ground. We are ahead of schedule. It is now 20

5 minutes until 11:00. Let's take a 15-minute break,

6 which means we will resume at 5 minutes to 11:00.

7 As you walk around the building here, the

8 Forrestal Building, you must wear this badge and

9 visible. There are restrooms on both ends of the hall.

10 There is a coffee shop on the ground floor, almost

11 directly beneath us on the other side of the hallway.

12 So if you go back to the elevators and get off the

13 elevators to the ground floor and hang a left, there is

14 a coffee shop, Dunkin' Donuts, that sort of a thing,

15 there. What else should I say? Let's go quickly to

16 get coffee. Sometimes they are stacked up. And we

17 will start back here at 5 minutes to 11:00. Thanks for

18 a good start. We will be back then.

19 (Whereupon, there was a brief recess.)

20 MR. BROOKMAN: Let's resume. For those

21 jointing us via the web, we are happy to have you

22 joining us. The Department of Energy is trying hard to
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1 make these meetings accessible to all. So please feel

2 free to participate as you wish as we go along. We are

3 now going to proceed, pick up where we left off. And

4 we are going to hear from Scott Morris.

5 MR. MORRIS: Thank you.

6 I am Scott Morris from Pacific Northwest

7 National Laboratory, or PNNL. I will start, basically

8 expounding the wonders of the economic analyses that

9 the Department will be performing.

10 First of all, the markups analysis and energy

11 use analysis, shown just below, are important bridges

12 between the engineering analysis and the detailed

13 economic and energy analyses to come.

14 So, in practical terms, the markups analysis

15 translates to manufacturer selling prices, or MSPs,

16 produced in the engineering analysis into final

17 equipment purchase prices. There are three primary

18 steps taken to, or in, developing the markup values,

19 first of which is to identify the individual markup

20 levels in a given distribution channel. And the next

21 slide will show some distribution channels. Second,

22 actual markup values for each level within a
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1 distribution channel need to be determined. And,

2 finally, a determination regarding the percentage of

3 equipment passing through each distribution channel

4 needs to be made.

5 So DOE has initially developed the following

6 four distribution channels for BVMs, or beverage

7 vending machines, and requests comment, officially

8 coming in two more slides, regarding these channels and

9 the relative fractions of equipment passing or expected

10 to pass through each of these distribution channels.

11 There are two main types of markups:

12 baseline and incremental. Combining these markups

13 appropriately with sales tax yields overall markups.

14 So baseline markups convert MSPs to final purchase

15 prices for baseline efficiency equipment.

16 Incremental markups only deal with varying

17 costs, such as insurance and appreciation and profit,

18 just to name a few examples. Incremental markups are

19 applied to the differential in MSPs between baseline

20 and higher efficiency equipment.

21 And, finally, the last major step in the

22 markups analysis is to determine the overall markups,
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1 which is done by combining distribution channel

2 information, baseline and incremental markups, and

3 sales tax. Put those things together to get the

4 overall markups for a given piece of equipment.

5 This brings us to the first request for

6 comment slide. "7-1: DOE requests information on the

7 distribution channels described above for the beverage

8 vending machines covered under this rulemaking. The

9 Department also requests information on the relative

10 fractions of shipments expected for each distribution

11 channel. Do distribution channels vary by equipment

12 class?

13 "7-2: DOE requests information on how the

14 overall markups for the beverage vending machines

15 covered under this rulemaking may vary for each

16 distribution channel.

17 "7-3: DOE requests feedback on its proposal

18 to use baseline and incremental markups."

19 And "7-4: DOE requests comment on sources of

20 relevant data that could be used to calculate markups

21 for each distribution channel."

22 MR. BROOKMAN: Can we do this? Can you go
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1 back to slide 65 for these distribution channels? Can

2 you give an estimate of the fraction of product that

3 flows through each? Jim?

4 MR. MATHIS: Jim Mathis with Crane

5 Merchandising Systems. This is an area where Crane

6 would specifically look to NAMA to provide the

7 distribution through these. And the reason why I say

8 that is because from an industry perspective, we are a

9 small industry. And when we start talking about what

10 our personal quantities are --

11 MR. BROOKMAN: Okay. Yes.

12 MR. MATHIS: -- to each distribution channel,

13 we start, you know, --

14 MR. BROOKMAN: Right.

15 MR. MATHIS: -- kind of just throwing out

16 competing information there. So we would look for NAMA

17 to provide this information through them being the

18 clearinghouse.

19 MR. BROOKMAN: Gotcha. Okay.

20 MR. MATHIS: And, of course, if they need

21 information from each of the manufacturers, we are more

22 than happy to support that.
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1 MR. BROOKMAN: Does the Association do that

2 on a regular basis?

3 MR. MATHIS: They do.

4 MR. BROOKMAN: Okay.

5 MR. MATHIS: They provide that information

6 annually and track that throughout the industry.

7 MR. BROOKMAN: I am just interested to know

8 their capacity or to confirm their capacity, more

9 particularly. Great. It's good to know. Okay.

10 So, then, I don't guess, then -- no one here

11 wishes to comment on overall markups either or baseline

12 or incremental markups? Can you comment on the

13 proposal to use both baseline and incremental markups?

14 Does that make sense to you? Yes, Jim?

15 MR. COLLINS: Jim Collins, AMS. Can I ask

16 why that is important?

17 MR. MORRIS: Baseline versus incremental

18 markups?

19 MR. COLLINS: Right.

20 MR. BROOKMAN: Yes.

21 MR. MORRIS: Baseline markups -- so one thing

22 I had to keep reminding myself is that these markups
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1 are referring to markups from a manufacturer to

2 essentially the end user. And the reason it is

3 different, I guess, is baseline markups are typically

4 used to -- they incorporate the profit margins and

5 daily operating expenses that wholesalers and

6 distributors have. And the reason -- well, maybe

7 everybody here can specify why there is a good reason

8 not to use incremental markups, but incremental markups

9 capture the idea that just because a piece of equipment

10 is more expensive to a wholesaler to purchase from a

11 manufacturer does not necessarily imply that other

12 costs rise besides the initial expense from the

13 manufacturer. It implies that other costs are not

14 going to be elevated between the manufacturer and the

15 end user; so, for example, insurance costs to cover the

16 stock that a wholesaler has in their warehouse. They

17 might go up a little bit due to having more expensive

18 stock on hand, but at the same time, incremental

19 markups are -- I guess they are designed to not be

20 marking up everything as much between baseline and more

21 efficient equipment.

22 MR. BROOKMAN: Yes, please, Satish?
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1 DR. BAPANAPALLI: This is Satish Bapanapalli

2 with PNNL. Just to clarify, we are trying to

3 differentiate between fixed costs and variable costs.

4 And by "variable costs," I mean the costs that vary

5 with the price of the equipment; whereas, things like

6 rent, location expenses, and things like that don't

7 change just because the equipment is more expensive.

8 So that is what we are trying to differentiate between,

9 fixed costs and variable costs, "variable" being with

10 the price of the equipment.

11 MR. BROOKMAN: Thank you.

12 So additional comments, any comments on 7-3

13 or 7-4?

14 Okay.

15 MR. MORRIS: The energy use analysis we will

16 talk about now simply calculates how much energy a

17 given piece of equipment uses. It is a relatively

18 straightforward, yet crucial input to the life-cycle

19 costs and payback period analysis and the other

20 national- level analyses that we will be discussing.

21 So, as Elaina talked about earlier, daily

22 operating hours contributes to daily energy use or
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1 energy consumption. So operating hours are important

2 factors in determining how much energy equipment uses.

3 And, again, how much energy the equipment uses is kind

4 of, I guess, the whole point of us being here today.

5 This brings us to a slightly different request for

6 comment, "6-1: How should DOE treat energy use in

7 heating mode for outdoor machines in cold climates?"

8 MR. BROOKMAN: Jim?

9 MR. MATHIS: Jim Mathis with Crane

10 Merchandising. From an industry standpoint -- and this

11 is something that I am not sure if the other

12 manufacturers are interested in commenting on, but from

13 an overall standpoint, this is a small quantity of

14 machines that are produced that actually have heating

15 elements tied to them that are put into the field for

16 use in colder climates. There is a portion of them,

17 but historically the machines that are produced by the

18 manufacturers that actually have elements tied to them

19 is very small.

20 MR. BROOKMAN: Could you quantify it?

21 MR. MATHIS: I really can't, honestly, Doug.

22 MR. BROOKMAN: One percent? Five percent?
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1 MR. MATHIS: Typically for us right now, we

2 are not producing any equipment that has heating

3 elements tied to it.

4 MR. BROOKMAN: Okay.

5 MR. MATHIS: So from an industry standpoint,

6 I really couldn't quantify it.

7 MR. BROOKMAN: Okay. Thanks.

8 Yes, Dipak?

9 MR. NEGANDHI: I agree with Jim. None of the

10 vending machines for outdoor applications either have

11 heaters or gas defrost mode. So they are designed to

12 withstand the cold climate without having any heaters

13 installed in them. Heaters that are being installed

14 are probably an after-market component or an optional

15 accessory. So it is not a standard component of the

16 vending equipment market.

17 MR. BROOKMAN: Okay. Yes, Jim?

18 MR. COLLINS: Jim Collins, AMS. I will say

19 we do ship machines with heaters. Particularly the

20 fresh bait vending industry needs that kind of thing

21 for outdoor machines in the cold. But on the technical

22 side of that, I would just say I think it could be
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1 ignored and the reason being if you are efficient, if

2 you are at high efficiency on the cooling side, then,

3 almost by definition, you are equally at high

4 efficiency on the heating side. Since most of these

5 heating systems are based on electricity, which is

6 essentially 100 percent efficient on heating, then I

7 think you could just ignore this as adding to the

8 energy consumption of the machine as a whole.

9 MR. BROOKMAN: Thank you.

10 MR. SACHS: What does a fresh bait beverage

11 vending machine look like?

12 MR. COLLINS: The thing is, you know, again,

13 I'm just going to take this opportunity to say I feel

14 like the small fish in the ponds here being our

15 machines aren't really like their machines. We can

16 vend a beverage, but we really vend everything. And

17 so, you know, I hate to even say this, but we shouldn't

18 be in this category, although we would fall under the

19 definition for sure. But it is the same machines. And

20 I can't tell you that a machine that is going out next

21 to the river in Wisconsin, where we do have a lot of

22 machines, isn't next month going to be moved indoors
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1 and they're going to load it up with beverages or food

2 or snacks.

3 MR. SACHS: That's really very helpful. I

4 appreciate that.

5 MR. BROOKMAN: Harvey, microphone, please.

6 Thank you.

7 MR. SACHS: Thank you, Jim. The question was

8 in jest, and you have given me some real things to

9 think about. I very much appreciate it. And I will

10 not think about a machine that is liquefying worms for

11 you to drink.

12 MR. BROOKMAN: Okay. Final comments on this

13 one because we are going to move -- yes, Mike?

14 MR. MAU: I'd like to just follow up to Jim's

15 comment. This is Mike Mau from Royal Vendors. With

16 that style of equipment, that is not the typical

17 equipment that has been part of the ASHRAE standard.

18 So, you know, with what DOE is trying to look into, it

19 is trying to bridge this gap that there isn't any

20 bridge there currently, you know, like beverage vending

21 equipment is beverage vending equipment. There is not

22 really the perishable or bait vending equipment. It is
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1 pretty unique.

2 MR. BROOKMAN: Okay. Thank you.

3 We're moving on.

4 MR. MORRIS: Energy use and economics. Ari,

5 did you have a --

6 MR. BROOKMAN: Yes. Ari has a question.

7 MR. ALTMAN: Yes. This is Ari Altman from

8 the General Counsel's Office. Following up on the

9 point you made about vending machines that aren't

10 specifically for beverages, are there any vending

11 machines made that cannot be used for beverages, that

12 cannot be used for cross purposes but are only for

13 either non-beverage or non-food items entirely?

14 MR. COLLINS: Jim Collins from AMS. Yes,

15 there are. Ambient temperature machines are commonly

16 shipped, but they don't have refrigeration. An in17 between class, for which we were granted an exemption

18 in the present rule, is a machine that is basically an

19 ambient temperature machine with a small refrigeration

20 unit that can keep the chocolates from melting. Okay.

21 So a very small compressor, uses very little energy,

22 but you could throw a beverage in it. So yes, there
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1 are almost no machines built today on the market that

2 couldn't vend a beverage.

3 MR. BROOKMAN: Ari?

4 MR. ALTMAN: Great to know. That's what I

5 wanted to know. Thank you.

6 MR. BROOKMAN: Okay. Great.

7 MR. MORRIS: So, again, energy use and

8 economics and the analysis from the markups analysis

9 come together in the LCC, or life-cycle costs, and

10 payback period analysis. So in a few minutes, we will

11 discuss the national impact analysis, which assesses

12 the overall energy and economic impacts of different

13 efficiency levels on the nation as a whole. But the

14 life-cycle cost and payback period analysis looks at

15 these impacts for individual customers. So life-cycle

16 cost is the sum of purchase installation and operating

17 costs of equipment for its entire lifetime discounted

18 to some base year.

19 We will further discuss the operating costs

20 and break them out a little bit more on the next slide.

21 And LCC results are expressed as the difference in

22 total cost, in total cost during its lifetime, between
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1 baseline efficiency and higher efficiency equipment.

2 A payback period is the number of years it

3 takes a customer to recover the typically higher

4 initial cost of more efficient equipment through

5 decreased operating expenses.

6 There are two main types of cost associated

7 with calculating the LCC, life-cycle cost, of

8 equipment. The first type, shown here as equipment

9 purchase price and installation costs, encompasses the

10 capital up-front costs of new equipment. The second

11 general type, shown here as maintenance, repair, and

12 energy costs, is expenses incurred during the lifetime

13 of the equipment after the initial purchase and

14 installation. Some other important inputs to the LCC

15 analysis include discount rates, base case

16 distributions, and equipment lifetime. We're going to

17 talk about a couple of these in a bit, but I would like

18 to focus specifically on the base case distribution of

19 efficiency-level shares bullet.

20 Elaina had already alluded to this earlier.

21 This is more of a shipments issue that has LCC

22 ramifications. For example, if there are differences
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1 in maintenance or repair costs between more efficient

2 and less efficient equipment in the current stock or in

3 the projected future stock of installed machines, this

4 would be useful information to incorporate into the LCC

5 analysis. We will have a specific request in a few

6 slides.

7 So as nice as it would be to pinpoint every

8 LCC input with perfect precision, obviously it can't be

9 done. There is variability in many inputs, which vary

10 by region, by time, and in other ways. So the Monte

11 Carlo approach, shown in this slide, will be formally

12 carried out in the NOPR phase of this rulemaking, but

13 in the preliminary analysis, average values for

14 variables, such as electricity prices, sales tax, and

15 others, will be used, which brings us to several more

16 requests for comment. "8-1: DOE seeks comment on the

17 proposed approaches for estimating current and

18 forecasted energy prices.

19 "8-2: DOE seeks comment on the proposed

20 approaches for estimating discount rates for customers

21 using the equipment covered under this rulemaking.

22 "8-3: DOE recognizes that a large fraction
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1 of the customers of beverage vending machines are

2 beverage bottlers. Which commercial sectors besides

3 the bottlers should be considered in the evaluation of

4 discount rates? In addition, do stakeholders believe

5 that government direct purchases of this equipment are

6 large enough to require that they be included in the

7 evaluation of discount rates?"

8 MR. BROOKMAN: So there you see those. Let's

9 pause, and let's address those three. Comments on 8-1,

10 8-2, and 8-3? Dipak?

11 MR. NEGANDHI: Dipak Negandhi, Royal Vendors.

12 Scott, in general terms, one thing I'm missing here on

13 the life-cycle cost analysis is what is the life of the

14 equipment that you put in because that is the biggest

15 factor for the life-cycle cost?

16 MR. MORRIS: What is the lifetime?

17 MR. NEGANDHI: Yes.

18 MR. MORRIS: That is a good question. And I

19 am hoping you can tell me the answer.

20 MR. NEGANDHI: So here is the thing. The

21 trend has been in the last few years we have observed a

22 lot of users, instead of scrapping the equipment, are
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1 remanufacturing them to extend the life span. And in

2 the process, Royal offers the process of upgrading the

3 energy efficiency to current ENERGY STAR standards

4 also. Now, I shouldn't say that 100 percent of the

5 equipment when it is refurbished is upgraded on the

6 efficiency side, but a number of them are. And I don't

7 know how that is going to be accounted for in this

8 model.

9 MR. MORRIS: Charlie?

10 MR. BROOKMAN: Charles Llenza?

11 MR. LLENZA: This rulemaking does not

12 preclude refurbished equipment. So we don't account

13 for it.

14 MR. NEGANDHI: So that is outside the scope

15 if I may understand.

16 MR. LLENZA: Yes, that's outside the scope.

17 And I don't think we have authority, really, to do

18 remanufactured equipment.

19 MR. NEGANDHI: Yes. But that's my concern,

20 is that the life number of span of years may be

21 misrepresented in that.

22 MR. BROOKMAN: Gotcha. Okay.
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1 MR. NEGANDHI: That is all at this point.

2 MR. BROOKMAN: Yes. That would be useful

3 data to have. And, of course, the Department of Energy

4 is serious data-hungry folks. So any kind of

5 information along those lines would be tremendously

6 helpful to them.

7 So you see there current and forecasted

8 energy prices, discount rates. Let's start with those

9 two. Thoughts on those two? Yes, Jim?

10 MR. MATHIS: Jim Mathis with Crane

11 Merchandising Systems. One of the things that the

12 Department needs to keep into consideration as it is

13 reviewing this particular industry is the purchasers of

14 this equipment typically aren't the ones who are using

15 the equipment and paying the bills at the end of the

16 day with regards to the energy usage of the equipment.

17 It is very different than your typical consumer going

18 to a big box store, picking out which piece of

19 equipment they want to put in their home, and taking

20 the hit on the energy consumption themselves.

21 Typically, the users are the ones who are paying the

22 energy prices and the fees associated with using that
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1 energy, and the purchaser of the equipment never see

2 any impact to that. So from an overall standpoint,

3 just keep that in mind as you are doing your research

4 for your LCC analysis.

5 MR. BROOKMAN: Okay.

6 MR. MORRIS: Thank you.

7 MR. BROOKMAN: Thank you.

8 Any thought on discount rates? Harvey?

9 MR. SACHS: Harvey Sachs, ACEEE. With

10 respect to items 8-1 and 8-2, it seems to me that the

11 least risky approach is to go ahead and use the same

12 OMB discount rates and the same EIA energy forecasts,

13 as are used in almost all the other equipment

14 rulemakings, rather than having this become a very big

15 deal as an exception. We always find the EIA

16 projections to be wrong. And so does everyone else,

17 but there's nothing less bad or nothing widely accepted

18 that is less bad.

19 MR. BROOKMAN: 8-3? Any additional comments

20 on 8-3 from anyone?

21 MR. SACHS: Harvey again. There's a question

22 on 8-3. And I really don't know the answer. I have
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1 had the impression that some of the refrigerant

2 alternatives that are being considered are driven by

3 the purchasers; that is, the bottling companies,

4 interested in projecting green. And the question is

5 really to what extent that is true and to what extent

6 that carries over to giving the end user some options

7 in terms of his contract or some desire to market that,

8 gee, this is the lowest-energy cost, greenest unit on

9 the market. I mean, that is why the standard itself is

10 a benchmark or comparison stand.

11 Now, I don't know the answers, but it seems

12 to me that given this very unusual market structure, it

13 is a relevant question, soliciting comments from the

14 bottlers on what it is what their criteria are.

15 MR. BROOKMAN: Yes. Okay. Let's move on to

16 8- 4, 5, 6, and 7.

17 MR. MORRIS: "8-4: DOE seeks feedback on

18 what fraction of the installation, maintenance, and

19 repairs involve efficiency improvements and what are

20 the typical practices during the life cycle of an

21 originally manufactured beverage vending machine; for

22 example, changing lamps but not the compressor.
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1 "8-5: What is a typical time period between

2 the sale of a new BVM unit and the first maintenance or

3 repairs? What are the typical cycles of maintenance

4 and repairs?

5 "8-6: DOE seeks feedback on whether and how

6 routine maintenance, repair, and installation costs

7 will change for more efficient equipment.

8 "8-7: DOE seeks feedback on appropriate

9 methodologies for assessing changes to maintenance,

10 repair, and installation costs."

11 MR. BROOKMAN: Dipak?

12 MR. NEGANDHI: Dipak Negandhi, Royal Vendors.

13 The only comment, again, I have to make is with

14 relation to the maintenance costs. As the

15 manufacturers -- and we have discussed this before

16 earlier about using hydrocarbon refrigerants. As we

17 move to the hydrocarbon refrigerants, this being a new

18 technology, we expect the maintenance costs to go up,

19 actually, rather than lower.

20 MR. MORRIS: Do you anticipate the actual

21 cost at the time of service to go up or the maintenance

22 schedule to be more frequent or both?
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1 MR. NEGANDHI: Right, right, just the overall

2 maintenance and repair expenses.

3 MR. BROOKMAN: For both the schedule and the

4 actual expense of the visit?

5 MR. NEGANDHI: Of the visit, right.

6 MR. MORRIS: Okay. Thank you.

7 MR. NEGANDHI: Until this technology kind of

8 settles down.

9 MR. BROOKMAN: But 8-4 goes to your earlier

10 comment, Dipak. What fraction of your installation,

11 maintenance, and repairs involve efficiency

12 improvements would you say? Can you say? Can you

13 answer the question in 8-4, "What fraction of the

14 installation, maintenance, and repairs involve

15 efficiency improvements?" I guess you were talking

16 about a wholesale reworking of the equipment or

17 something.

18 MR. NEGANDHI: That's correct, yes.

19 MR. BROOKMAN: Refurbishment?

20 MR. NEGANDHI: Refurbishment or

21 remanufacturing, right.

22 MR. BROOKMAN: Yes. Okay. That's different.
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1 MR. NEGANDHI: Yes.

2 MR. BROOKMAN: Thank you.

3 MR. MORRIS: What about --

4 MR. SACHS: I have a question for the

5 manufacturers.

6 MR. BROOKMAN: Yes? Go ahead, Harvey.

7 MR. SACHS: Harvey Sachs again. During the

8 last rulemaking round, there was a fair amount of

9 discussion, if I recall correctly, about a possible

10 trend toward pallet-mounted refrigeration systems that

11 could be slid out and serviced back at the shop, rather

12 than worked on in the field. And it may be relevant to

13 understand that, for the Department to understand that,

14 better and whether these are likely to be repaired,

15 replaced, and if replaced, whether replaced with more

16 advanced systems or with exactly the same as they were.

17 Again, I am asking because I don't know if this is a

18 significant trend.

19 MR. BROOKMAN: Yes, Jim?

20 MR. MATHIS: Jim Mathis with Crane

21 Merchandising Systems. In response to Harvey's

22 question, it depends on within industry which bottling
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1 company you are actually referring to and which user of

2 the equipment as to what their standard methods are of

3 dealing with repairs in the field. There has been a

4 shift recently -- when I say "recently," within the

5 past 2 to 3 years -- and more of a trend toward

6 actually picking up a defective piece of equipment

7 completely, as opposed to repairing it in the field,

8 and replacing it with a refurbished or a reworked piece

9 of equipment or a known good piece of equipment and

10 then taking the suspect back to the shop and working on

11 it there, as opposed to previous 2 or 3 years ago, the

12 trend was to have equipment that was easily accessible,

13 to your point, where a refrigeration system could be

14 swapped within 10 to 15 minutes and the machine

15 returned to service and then the old deck replaced or

16 worked on back at the shop. So, from an overall

17 standpoint, there has been more of a trend of relieving

18 equipment from the field that is suspect at the time.

19 With an overall standpoint, the newer designs

20 of the equipment, although very modular in

21 construction, still take a significant amount of work

22 to disassemble. A lot of the newer customers that these
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1 companies are dealing with placing equipment don't want

2 someone dragging the torque set out and brazing a leak

3 in the middle of their lobby, which is what has driven

4 the companies to actually pick the equipment up and

5 take it back to the facility and rework it there.

6 MR. SACHS: Harvey Sachs again. Belaboring,

7 that sounds like it will have impact on some of the

8 questions that Dipak raised about field servicing of

9 hydrocarbon units.

10 MR. MATHIS: Yes. And this is Jim Mathis

11 again with Crane Merchandising. The technology he

12 specifically is referring to of transitioning to non13 HFC refrigerant- type systems is going to require work

14 to be done back at the shop and not in the field. So

15 he's exactly right with the comment he makes about fuel

16 services being involved with newer technologies at this

17 point in time.

18 MR. BROOKMAN: Scan through these. We didn't

19 answer all of them. We started. 8-4, 8-5, 8-6, 8-7.

20 MR. MORRIS: Oops. I forget this. This

21 keeps going. This is the third and final one here.

22 "8-8: DOE seeks feedback on appropriate equipment
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1 lifetimes for the beverage vending machines covered

2 under this rulemaking," keeping in mind what Charlie

3 mentioned, that these are for new equipment only.

4 "8-9: DOE seeks comment on whether energy

5 conservation standards will have an impact on lifetimes

6 of beverage vending machines.

7 "8-10: Is there a suitable inventory model

8 that could be used to estimate the fraction of new

9 versus rebuilt/refurbished machines in the market? If

10 no inventory model exists, what is the impact of

11 refurbishment on the equipment lifetime? DOE also

12 seeks feedback on the number of refurbishment cycles in

13 the typical lifetime of the beverage vending machines.

14 DOE also seeks information on the effect of

15 refurbishments on equipment utility and energy

16 consumption. In a typical refurbishment, for example,

17 are features added to the beverage vending machine that

18 affect its utility and/or are changes made that affect

19 the energy consumption of the equipment?"

20 MR. BROOKMAN: Maybe we could start with

21 lifetimes. Typical lifetimes for new equipment? What

22 would they be? Jim?
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1 MR. MATHIS: Jim Mathis, Crane Merchandising

2 Systems. I think items 8-8, 8-9, and 8-10 are all

3 items that need to be addressed through the users of

4 the equipment. From a manufacturing standpoint, we

5 have scopes and design criteria that we design around

6 for the expected life cycle of a piece of equipment,

7 but the majority of these decisions are made based on

8 the individual piece of equipment, its use, its

9 history, where it has been used as to what its life

10 expectancy really looks like, as well as the return on

11 investment as how that asset is depreciated over time

12 through those particular companies that own that asset

13 and operate that asset.

14 MR. BROOKMAN: Okay. Thank you.

15 Patrick Powell has a comment from online.

16 Patrick says, "I will unmute him."

17 MS. MARCHETTI: I will unmute him.

18 MR. BROOKMAN: Oh. Patrick, you should be

19 unmuted. Speak. Maybe your own phone is muted. We

20 can't hear you. Patrick, are you there? Not yet. No?

21 Okay. Well, we'll try later.

22 Do we have any additional thoughts, comments
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1 on 8-8, 8-9, 8-10?

2 Patrick, I'll give you one more chance here.

3 No luck, Emily?

4 Okay. Well, Patrick, when we get you on

5 line, we will bring you back into the conversation.

6 Let's proceed.

7 MR. MORRIS: Okay. Now, the LCC and payback

8 period analysis concerns the economic costs to

9 individual customers. The national impact analysis, on

10 the far right here, quantifies the energy savings and

11 economic costs, or savings, to the nation as a whole.

12 The shipments analysis, circled here, is essentially

13 the glue, and, I should say, very important glue, that

14 binds the life-cycle costs and national impact analysis

15 together.

16 So the shipments analysis ultimately dictates

17 the current and future shipments and stock of equipment

18 nationwide. The most important component of the

19 shipments analysis is correctly estimating the overall

20 volume of equipment shipped for the 30-year period

21 mentioned in this first sub-bullet. DOE will use as

22 many relevant data sources as possible to estimate
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1 future shipments. The Department also appreciates

2 input from manufacturers and other knowledgeable

3 parties.

4 Another important component of the shipments

5 analysis, as mentioned several slides ago, regards the

6 mix of efficiencies within the national stock of

7 equipment; that is, in the absence of a standard, of a

8 new standard or amended standard, what is the mix of

9 efficiencies by equipment class installed in the

10 country, both now and in the future?

11 That brings us to some more comments,

12 requests for comment. "9-1: DOE requests data on,

13 sources of data related to, or any information

14 pertaining to historical shipments and the market

15 shares of the different efficiency levels offered in

16 each equipment class.

17 "9-2: DOE seeks information on

18 representative saturation rates for each equipment

19 class covered under this rulemaking, as well as

20 industry-trend data regarding relative stock and growth

21 in each equipment class.

22 "Item 9-3: DOE seeks input on methods of
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1 projecting the markets for each equipment class and

2 access to models or methods that could be used to

3 estimate shipments."

4 And "9-4: DOE seeks input on likely impacts

5 on the shipments due to new or amended standards for

6 beverage vending machines. Please comment on what the

7 possible scenarios are and the estimated quantitative

8 impacts or "impact" of each scenario on the shipments

9 numbers."

10 MR. BROOKMAN: So it seems based on our

11 previous conversation that 9-1 and 9-2, you would

12 expect NAMA to answer those two. What about 9-3 and 9-

13 4, particularly 9-4, possible scenarios, estimated

14 quantitative impact of scenarios on shipment numbers?

15 Any thoughts on that? Yes, Jim?

16 MR. MATHIS: Jim Mathis with Crane

17 Merchandising Systems. The only thing I would like to

18 add to this is the vending industry has been a

19 declining industry over the past several years. We

20 have been very stagnant. And the number of machines in

21 the field has actually been declining. That goes back

22 to some of the comments Dipak made earlier about the
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1 refurbishment and remanufacture of existing assets to

2 prolong the life. So with regards to the placement of

3 new equipment, it has been very stagnant.

4 MR. BROOKMAN: Okay. Thank you.

5 MR. MORRIS: Can I ask -- go ahead. Sorry.

6 MR. COLLINS: Jim Collins with AMS. One of

7 the areas that would make this a bigger issue would be

8 if there were any type of recognition for compliance to

9 these standards. And the example I use is our

10 customers that will pay the extra money for efficient

11 equipment typically are doing so because they are

12 taking bids in LEED-certified buildings. And they

13 require ENERGY STAR. They don't know a darn thing about

14 these DOE things. If this program could be treated as

15 that program, you would have a higher impact and this

16 question would make a lot more sense.

17 MR. BROOKMAN: Okay.

18 Charles Llenza?

19 MR. LLENZA: This is Charles Llenza,

20 Department of Energy. They are separate programs, and

21 ENERGY STAR is voluntary. And the Department when they

22 establish energy conservation standards, they are
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1 mandatory across all product lines. So it is a little

2 bit of a different program. What I can say is that

3 there is more integration now with what we do and

4 energy does, ENERGY STAR does. So, at least from that

5 perspective, the baseline will come out of DOE and

6 ENERGY STAR will build on that baseline.

7 MR. BROOKMAN: Yes, Jim?

8 MR. MATHIS: Jim Mathis, Crane Merchandising

9 Systems. From an historical standpoint, what we have

10 experienced throughout our industry is, although ENERGY

11 STAR is driven to be the top 20-25 percent of the

12 products produced in the market, we have ended up being

13 almost 100 percent ENERGY STAR because the parent

14 companies driving this industry only want to buy ENERGY

15 STAR pieces of equipment because they don't want to be

16 limited as to what assets can go into what locations.

17 That is kind of where this is a unique situation for

18 us. You know, we are cognizant of the DOE standards.

19 And, of course, every piece of equipment we produce

20 meets those standards.

21 But, to Jim Collins' point, the majority of

22 the demand on our products is for that extra five to
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1 ten percent, whatever ENERGY STAR sets above the DOE

2 threshold. So we are driving towards that threshold as

3 our minimum basis for our criteria.

4 MR. BROOKMAN: Okay. Final comments on 9-3

5 and 9-4?

6 MR. MORRIS: Can I ask a follow-up question

7 to Jim Mathis? You mentioned new shipments of machines

8 have been declining in the last several years. Can you

9 make any general statements about the overall stock of

10 equipment? Is that increasing over time still? Is

11 that remaining stable or going down?

12 MR. MATHIS: Jim Mathis, Crane Merchandising.

13 With regards to the install base of equipment that is

14 in the field, the operators of this equipment have

15 continued to rationalize whether a location and an

16 asset is producing money. And the majority of that is

17 based around the rising cost of fuel, servicing the

18 equipment, and driving profits down.

19 With regards to the number of machines that

20 are in the industry today, there has been a surplus of

21 equipment and not enough locations to cover that

22 equipment. So the users of the equipment have been
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1 maintaining a high level of used stock and not

2 purchasing a significant amount of new stock. The new

3 stock purchases have been fairly consistent, although

4 turbulent at times given the state of the economy, but

5 they have had an excess that they are just now starting

6 to get past some of that.

7 And, you know, we made the comment earlier

8 about refurbishment and remanufacture. They are

9 continuing to look to those options to prolong the life

10 of the equipment because it is a large purchased piece

11 of equipment that does have a high cost associated with

12 it.

13 MR. MORRIS: Thank you very much.

14 MR. BROOKMAN: Harvey?

15 MR. SACHS: Again, this is sort of -- Harvey

16 Sachs -- a trend question, but am I hearing that we are

17 seeing some sort of a shift in the market from the

18 service station with the beverage vendor outside toward

19 the integrated service station/convenience store, which

20 is using commercial refrigeration equipment, rather

21 than the freestanding beverage vendors?

22 MR. BROOKMAN: Jim?
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1 MR. MATHIS: Jim Mathis, Crane Merchandising.

2 You are exactly right, Harvey. What we have

3 experienced is the traditional service station no

4 longer really exists within the United States. What

5 you find now is your integrated c-store, convenience

6 store, that has all of the opportunities for all the

7 food service items within the store. And the other

8 thing that you are seeing, too, is the expansion of

9 what we refer to in our industry as micro markets, that

10 aren't vending machine- based but, from an overall

11 standpoint, they are unattended like a vending machine

12 would be but it is an unattended self-service kiosk.

13 You know, there is this drive to self-service within

14 our nation.

15 MR. BROOKMAN: Thank you.

16 Okay. We will move on.

17 MR. MORRIS: So I just mentioned the life18 cycle costs and shipments analyses come together to

19 inform the national impact analysis. So all of the

20 bullet points in this slide can be boiled down into two

21 main points. First of all, the national impact

22 analysis, or NIA, assesses national energy savings, or
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1 NES, resulting from a standard; and, second, it

2 determines national economic impacts, which is net

3 present value, or NPV, of a newer amended standard.

4 The shipments and life-cycle cost analyses are used

5 together to develop the energy savings, capital costs,

6 and operating expenditures of the national stock for

7 every year during the analysis period. The value of

8 money over time is accounted for using defined discount

9 rates, Harvey, that you had mentioned earlier, at three

10 and seven percent.

11 So, again, there are two main purposes of the

12 NIA, which is to calculate NES and NPV. So national

13 energy savings, or NES, inputs include national energy

14 consumption at each efficiency level by equipment

15 class; projected shipments; stock, which is based on

16 historical and projected shipments; and site-to-source

17 conversion factors, which convert energy use at the

18 site of the equipment, into source or primary energy.

19 And, to calculate NPV, the total installed cost

20 increase and operating cost savings are calculated for

21 each year of the analysis period and effectively summed

22 to determine the economic benefit (or detriment in some
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1 cases) to the nation.

2 This brings us to a request for comments

3 slide, "10-1: DOE seeks comment on the share of the

4 market that is met by refurbished or rebuilt machines

5 and whether there are a substantial number of machines

6 in stock that are not in active use. In particular,

7 DOE seeks comment on the impact of refurbishment or

8 rebuilding on the energy consumption and lifetime of

9 the existing fleet in the absence of standards, and the

10 impact of new standards on refurbishment kits, the

11 subsequent cost, and performance of the stock of

12 existing equipment.

13 "10-2: DOE seeks comment on its plan to

14 develop NIA spreadsheet models for estimating national

15 impacts of amended energy conservation standards."

16 MR. BROOKMAN: It seems like NAMA again would

17 be the one to answer 10-1. Any thoughts on 10-2, plan

18 to develop NIA spreadsheet models for estimating

19 national impacts?

20 (No response.)

21 Nothing there. Okay.

22 MR. MORRIS: Okay. Thank you.
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1 I will turn the time back over to Elaina for

2 a few minutes to talk about the preliminary

3 manufacturer impact analysis.

4 MS. PRESENT: As mentioned earlier, DOE also

5 conducts a manufacturer impacts analysis. The

6 activities for the manufacturer impact analysis are

7 greatly expanded in the NOPR phase, but DOE does take

8 advantage of the preliminary analysis by conducting a

9 preliminary manufacturer impact analysis.

10 The primary purpose of this analysis is to

11 assess the potential impacts of energy conservation

12 standards on the manufacturers of BVMs.

13 The method that DOE uses is to conduct

14 interviews with manufacturers and to analyze public

15 data, including SEC 10k filings. During these

16 interviews for the preliminary manufacturer impact

17 analysis, a lot of the discussion is focused on the

18 engineering side. However, they are also used to

19 identify major issues and concerns for manufacturers.

20 Afterwards, DOE will collate the interview responses,

21 prepare a summary of these major issues and outcomes,

22 and start to conduct a straw man industry cash flow
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1 analysis based on the interview responses and publicly

2 available financial information.

3 One of the major goals of the preliminary

4 manufacturer impact analysis is to identify

5 manufacturer subgroups. By "subgroups," what I mean is

6 niche manufacturers and any manufacturers that might be

7 disproportionately affected by the efficiency

8 standards.

9 One subgroup that DOE is always concerned

10 with is small businesses. DOE identifies small

11 businesses and conducts a Regulatory Flexibility Act

12 analysis to determine the impacts of the standards on

13 these small manufacturers.

14 Another major goal is to assess the

15 cumulative regulatory burden. This is about

16 identifying and considering the impact of multiple

17 product-specific regulations on the manufacturers,

18 whether the regulations are part of the DOE's defined

19 standards program or outside regulations.

20 And then the request for comment, "Item 12-1:

21 DOE seeks comment on appropriate manufacturer

22 subgroups, if any, that DOE should consider in the
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1 manufacturer subgroup analysis for beverage vending

2 machines.

3 "Item 12-2: DOE seeks comment from small

4 businesses that could be impacted by amended energy

5 conservation standards for beverage vending machines

6 and what those impacts might entail.

7 "Item 12-3: DOE welcomes comments on other

8 existing or pending regulations it should consider in

9 its examination of cumulative regulatory burden."

10 MR. BROOKMAN: Thank you.

11 Dipak?

12 MR. NEGANDHI: Dipak Negandhi, Royal Vendors.

13 The only comment I have is I want to reemphasize what

14 Jim had said earlier, that within this industry, ENERGY

15 STAR and DOE literally drive the standard because the

16 penetration of ENERGY STAR equipment is so high. And

17 that should be part of the consideration. I mean, that

18 is one of the specific questions about cumulative

19 regulatory impacts. The other, of course, is the SNAP

20 regulations that affect the refrigeration industry, but

21 there is a special category for refrigerated beverage

22 machines.
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1 MR. BROOKMAN: Okay. Thank you.

2 MR. NEGANDHI: Thank you.

3 MR. SACHS: This is Harvey. And if I could

4 comment on the ENERGY STAR versus DOE, you all have

5 convinced me that this is a different industry. And

6 the very criteria for ENERGY STAR of supposedly being

7 the upper 25 percent of available models are irrelevant

8 if essentially all customers are asking for essentially

9 all product to be ENERGY STAR. Now, that would argue

10 for collapsing the two together, but the issue then is

11 be careful what you're asking for because at that

12 point, there are no longer any LEED credits if the

13 maximum and the minimum in the market are the same,

14 that people will no longer ask for the LEED for the

15 ENERGY STAR equipment because they can't get anything

16 less efficient. So I don't know how to work on that,

17 but certainly the ENERGY STAR definition is bad for

18 BVM. And that is something that needs to be brought to

19 ENERGY STAR's attention.

20 MR. LLENZA: This is Charles Llenza, the

21 Department of Energy. I am not sure if people

22 understand the relationship between ENERGY STAR and our
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1 standards. So we establish standards. And then ENERGY

2 STAR looks for ways of increasing the metric so that

3 there is a marked value added in energy efficiency.

4 And so one of the things that we look at to establish

5 our baselines are those ENERGY STAR levels. So we are

6 constantly interchanging our efficiency levels with

7 ENERGY STAR. So what is considered an ENERGY STAR

8 level in the past now becomes our baseline. And they

9 look for new higher levels of efficiency in their

10 equipment to establish the ENERGY STAR levels.

11 So we did BVM, the first BVM rulemaking. So

12 one of the complaints from ENERGY STAR was we didn't

13 give them much room for Class A equipment. I said,

14 "Well, that's your job. Your job is to go find that

15 level so that you can set ENERGY STAR levels for Class

16 A type of equipment."

17 We worked with them with the test procedure

18 and other discussions in terms of how to get to that

19 level. And then they reestablished ENERGY STAR levels

20 for Class A kind of equipment. So now in this

21 rulemaking, we look at that ENERGY STAR level within

22 our rulemaking to see what is the next step.
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1 So I think both programs have separate

2 purposes, but they are intertwined in pushing each

3 other to the next level as the cycle goes. ENERGY STAR

4 has the advantage of not having a three-year process.

5 And it is voluntary because the purpose of ENERGY STAR

6 is to set levels beyond the baseline, which we are

7 regulated by legislation in terms of setting those

8 baselines.

9 So I am not seeing a real problem. I am just

10 saying things are happening at different paces, but

11 ENERGY STAR helps us set the baseline for this

12 rulemaking, for example. And we will move that

13 baseline up. ENERGY STAR then will take that baseline

14 and set another level.

15 So your label, the idea is for them to push

16 us by pushing the market and changing the baselines.

17 And then once we set that in legislation and then have

18 that enacted in terms of what the new baseline is in

19 law, they then will set another level for that. So in

20 terms of energy efficiency, that works very well.

21 I clearly understand what the manufacturers

22 and other parties are telling me here, that you want
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1 the label. And the good news is in obtaining that

2 label, you have to produce more efficient equipment

3 because the ENERGY STAR level is always going to be

4 higher than a DOE level. So if we are doing our job,

5 we are pushing them and they are pushing us, they are

6 pushing by that nature the entire market to higher

7 efficiency levels on the equipment.

8 MS. PRESENT: I do want to clarify one thing

9 quickly. For the first beverage vending machine

10 rulemaking, we did use the ENERGY STAR level as the

11 baseline unit because the entire market was meeting it.

12 For this proposed modification, we are not suggesting

13 at this point to use the current ENERGY STAR level as

14 the baseline. We would be using the current DOE level

15 as the baseline.

16 MR. BROOKMAN: Yes, Jim?

17 MR. COLLINS: Jim Collins, AMS. I guess the

18 one big problem that we faced back last August, when

19 the current ruling went into effect, was the questions

20 from our customers of "Why did you just increase my

21 price hundreds of dollars?" There is nothing to show

22 for that. We didn't have anything to point to, any real
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1 public splash, any label, anything that we could

2 justify that cost that was very public. We had to send

3 them into, you know, federal rules. And our customers

4 don't want that. But they did want an explanation as to

5 "Why did our prices go up like that?"

6 MR. BROOKMAN: Yes.

7 MR. COLLINS: And any assistance you could

8 give us along those lines would certainly be

9 appreciated.

10 ENERGY STAR, again, it's self-evident. It's

11 widely recognized. Everybody can see the label.

12 Everybody says, "Oh, it's ENERGY STAR. I'll pay the

13 extra bucks." But for these mandatory rules, and not

14 to argue that they are good and of benefit to the

15 nation, are hidden from the public.

16 MR. LLENZA: The only thing I could add to

17 that is if you didn't have a baseline, you wouldn't

18 have an ENERGY STAR program. So it's a Catch-22 in

19 that sense, you know, what comes first. But when we

20 set the baseline, then ENERGY STAR highers a target

21 level to be able to set beyond the baseline.

22 And, you know, we are not doing these rules
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1 overnight. They take quite a bit of time. The first

2 rule was done in 2009. The standards became effective

3 in 2012. We're starting that process one more time.

4 They won't be in effect until 2019. So we're not

5 talking overnight. And, I mean, in the overall mission

6 that the Department has to conserve energy, this is

7 part of the process which we use.

8 So you could think of ENERGY STAR as the

9 tiered process in between, the setting/resetting of the

10 baseline to the current technology levels. And, you

11 know, I would think that six years, though, gives

12 plenty of time for the industry overall to catch up

13 with that.

14 MR. BROOKMAN: Ari?

15 MR. ALTMAN: Ari Altman from the General

16 Counsel's Office. I just wanted to follow up on kind

17 of two issues that have come up, the one being that in

18 some cases, 100 percent of products being sold are

19 ENERGY STAR, which seems to call into question the

20 value of ENERGY STAR. We're not setting ENERGY STAR

21 standards here today. This is not an ENERGY STAR

22 rulemaking. But I will say that there is some
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1 precedent for that occurring with other appliances and

2 other products and that in a sense is a sign that

3 people are paying attention to ENERGY STAR. But,

4 again, this is not an ENERGY STAR rulemaking, but there

5 is precedent for that. And then ENERGY STAR needs to

6 take a look at that and do a new rulemaking.

7 On this other issue that you mentioned about

8 getting the word out about mandatory standards and the

9 lack of publicity, I think we should take that under

10 advisement. And perhaps the Department should do more

11 to publicize its efforts in this regard. We do send

12 out press releases, but these are not necessarily to

13 your customers. They would not necessarily receive

14 them. And perhaps we need to do a bit more on the

15 marketing side. Again, that is outside of this

16 rulemaking, but it is a good point to be considered.

17 But do consider also that ENERGY STAR is a

18 voluntary program. And you do get a star. You get

19 kind of a reward for complying. And so it has a built20 in incentive. And people like that. Our program is

21 mandatory. And so we don't award any kind of symbol or

22 emblem because you have to comply. That doesn't mean
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1 that we couldn't do a better job getting the word out

2 as to why we're doing it and what the benefits are to

3 the nation as a whole. And we do calculate that. It's

4 obviously part of our rulemaking. And the benefits as

5 to each particular customer, there may be a net

6 positive or perhaps a negative, which is what you are

7 referring to.

8 But your comment is definitely worth

9 considering broadly at the Department. So thank you.

10 MR. BROOKMAN: Yes, Harvey?

11 MR. SACHS: This is Harvey Sachs. And this

12 is really a question to Charles. My memory is that DOE

13 since the prior rulemaking on BVMs has moved to doing a

14 press release, which for standards at time of

15 implementation, that basically says, "Hey, there's a

16 new standard. It's more stringent. And here is why it

17 is good for everybody." And if you all aren't doing

18 that, that would certainly seem to be an easy thing to

19 do to give a one-pager that you guys can link to that

20 would answer some of the customer questions or at least

21 take you all off the hook. You have to do it.

22 MR. LLENZA: This is Charles Llenza. Well,
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1 we did one back in 2009, but, you know, it is 2013. So

2 there is a little bit of loss in translation here over

3 time. And I think people sort of forget what we are

4 doing because, you know, it is a new time frame and we

5 are doing the rulemaking.

6 On the web page, there is some quick

7 capturing of the benefits. Okay? You could see how

8 many quads we are saving with the first rulemaking. We

9 could see some dollar benefits to the nation. So that

10 is the quick information.

11 In terms of the consumer, you get a better

12 product that is more efficient. That should lower the

13 cost of operating that product from the energy

14 standpoint of view. The first cost is more expensive.

15 The long- term energy cost of that product is less.

16 The problem is that that is a more sophisticated way of

17 looking at a product because most people are concerned

18 with the first cost is what you are telling me right

19 now.

20 So I think, to complement what Ari says,

21 maybe the Department should take better time, more time

22 to explain the cost of money over time and how that is
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1 benefitting everybody, not just, you know, setting new

2 standards for the beverage vending machine industry.

3 MR. BROOKMAN: So have we addressed 12-1, 12-

4 2, and 12-3 sufficiently? I haven't heard anything

5 about pending regulations, cumulative regulatory burden

6 yet.

7 MS. PRESENT: We did some on 12-3.

8 MR. BROOKMAN: Just for example. Did you

9 read these?

10 MS. PRESENT: Yes. So a lot of this

11 discussion of E-STAR I think was centered around 12-3 -

12 -

13 MR. BROOKMAN: Yes.

14 MS. PRESENT: -- but certainly the small

15 business aspect.

16 MR. BROOKMAN: Any other additional comments

17 on these?

18 Okay. We're moving on.

19 MS. PRESENT: All right. Thank you.

20 MR. MORRIS: I have the privilege of talking

21 about what happens a year from now. As Charlie

22 mentioned this morning in his opening slides, we're
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1 currently doing the preliminary analysis in the coming

2 months. After that process has gone through, we will

3 be doing the notice of proposed rulemaking.

4 I want to mention really quickly the

5 engineering analysis, LCC costs and payback period

6 analysis, and national impact analysis down below

7 there. As you can probably imagine, once we go through

8 this process of the preliminary analysis, we will have

9 the next public meeting and comment period, receive

10 responses to requests for comment, incorporate changes

11 that need to be made. And, essentially, we will be

12 redoing everything that we are working on now and

13 updating it for the NOPR phase.

14 So the customer subgroup analysis concerns

15 those in the population who may be significantly

16 affected by a new or amended standard. In practice, --

17 this is probably too much information for now, but the

18 analysis is done by considering alternate inputs to the

19 LCC model, inputs that might be different for a

20 particular subgroup. The identified subgroups are then

21 compared to the general population to determine if they

22 have been disproportionately affected by a standard.
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1 So, regarding the customer subgroup analysis,

2 "Item 11-1: DOE seeks input on which customer

3 subgroups DOE should consider in the present

4 rulemaking. Examples of possible subgroups DOE could

5 consider appropriate for beverage vending machines are

6 manufacturing facilities that own their own BVM units,

7 which was the identified subgroup in the 2009 BVM final

8 rule analysis, and site owners that pay the utilities

9 but don't own or stock the equipment."

10 MR. BROOKMAN: 11-1, comments on 11-1?

11 Okay.

12 MR. MORRIS: We'll talk about the employment

13 impact analysis, which, again, all of these analyses

14 that we're talking about are done at the NOPR phase.

15 This differs from the manufacturer impact analysis.

16 Unlike the manufacturer impact analysis, the employment

17 impact analysis only addresses the jobs impact of a

18 standard on the general economy. That is, it

19 quantifies the jobs created or destroyed resulting from

20 the complex interactions of shifting expenditures among

21 goods and services and changing energy and equipment

22 costs. The Department plans to use the ImSET model to
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1 evaluate these indirect employment impacts.

2 "Item 13-1: DOE requests feedback on this

3 approach to assessing employment impacts." Okay.

4 The utility impact analysis assesses the

5 impacts on domestic energy supply as a result of

6 standards. DOE plans to use NEMS, slightly modified

7 for this particular rulemaking, for modeling these

8 impacts, which include electricity sales and price,

9 generation, and capacity.

10 "Item 14-1: DOE seeks input on its proposed

11 use of NEMS-BT to conduct the utility impact analysis.

12 "14-2: Should DOE consider using methods

13 other than NEMS in the utility impact analysis?"

14 MR. BROOKMAN: Any thoughts on other

15 methodologies?

16 No. No comments.

17 MR. MORRIS: Okay. Easy enough.

18 We will talk about the emissions analysis and

19 monetization of emissions. So the emissions analysis

20 estimates the environmental impacts stemming from a

21 standard, including full fuel cycle emissions, carbon

22 and sulfur dioxide. Nitrogen oxide, methane nitrous
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1 oxide, and mercury are all estimated. The savings of

2 those emissions are estimated.

3 The benefits of reduced emissions can be

4 monetized as well. DOE intends to use the most current

5 social cost of carbon values developed by interagency

6 reviews. The analysis will estimate the potential

7 monetary benefit of reduced carbon dioxide and nitrogen

8 oxide emissions resulting from the standard.

9 "Item 15-1: DOE seeks input on its approach

10 to conduct the emissions analysis for the equipment

11 covered by this rulemaking.

12 "Item 16-1: DOE requests comments on the

13 approach it plans to use for estimating monetary values

14 associated with the emissions reductions."

15 MR. BROOKMAN: Yes, Mark?

16 MR. MENZER: Yes. Mark Menzer with Intertek.

17 This is going back, actually, to the utility impact

18 analysis. Is any consideration given to smart grid19 ready equipment that might, you know, be able to react

20 in, say, peak energy from a smart grid signal?

21 MR. MORRIS: I'd have to talk to my NEMS

22 people to give that question justice.
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1 MR. BROOKMAN: Satish?

2 DR. BAPANAPALLI: This is Satish Bapanapalli,

3 PNNL. So mostly the utility impact analysis is not at

4 our level. Mostly it is based on some of the

5 interagency guidance. And this encompasses the entire

6 rulemaking process, not just particular to BVM. And so

7 this guidance may change. And, based on that, we will

8 be doing the analysis. So some of the factors that we

9 get from NEMS from some of the inputs that go into NEMS

10 will be determined as a policy matter, not -- and it

11 won't be specific to the rulemaking. So, based on that

12 as the policy changes in a couple of years, one year

13 when we start doing this analysis, we will implement

14 those changes.

15 MR. BROOKMAN: Yes, please, Mark?

16 MR. MENZER: So I take that as a no? It's

17 not considered currently?

18 DR. BAPANAPALLI: Yes, currently not.

19 MR. MENZER: Can it be considered elsewhere

20 in other impact analysis? Is there another appropriate

21 place?

22 MR. BROOKMAN: Charles Llenza?
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1 MR. LLENZA: This is Charles Llenza,

2 Department of Energy. Usually a smart grid-type

3 decision would be interagency-type decision, how to

4 treat those in terms of the modeling, et cetera. So

5 the problem that we have right now, there's a lot of

6 stuff that's being talked about, but not necessarily

7 being factored into some of the modeling at the moment.

8 MR. BROOKMAN: Yes?

9 MR. SACHS: Harvey Sachs. Mark, a short

10 answer would be that it's one of the differentiating

11 factors that ENERGY STAR can use. There is already

12 credit for smart grid or grid-ready equipment in some

13 of the consumer products. So if that were a factor

14 that could be of value to the customers of this

15 equipment, ENERGY STAR can incorporate that quickly.

16 MR. LLENZA: And then at some point, we would

17 make it the baseline.

18 MR. SACHS: You've got to put it into the

19 test procedure to do that.

20 MR. LLENZA: Well, that's why we're redoing

21 the test procedure at this moment. And we work with

22 ENERGY STAR when we do the test procedure, by the way.
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1 MR. BROOKMAN: Comments back to 15-1 and 16-1

2 on emissions analysis and the monetary values

3 associated with emissions reductions? Yes, Dipak?

4 MR. NEGANDHI: Dipak Negandhi, Royal Vendors.

5 I am not sure the comment I am making is specifically

6 related to emissions from energy use, but the fact is

7 that as the industry moves to non-HFC-based

8 refrigerants, like CO2, that is where the energy use

9 impact comes in. And I think DOE should take into

10 account that the country as a whole is going away from

11 HFCs and HCFCs and as the newer technologies that come

12 into play are not necessarily more energy-efficient.

13 Yes, there are some that are more energy-efficient, and

14 some are not. But there is an overall model that there

15 is a benefit from going to that. And the extra energy

16 that may be required for some refrigerants should be

17 part of the evaluation.

18 MR. MORRIS: Thank you.

19 MR. BROOKMAN: Yes? Okay. Nothing

20 additional. Okay. Thank you for that comment.

21 We are moving on to the next element.

22 MR. MORRIS: The last thing that I will be
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1 discussing is the regulatory impact analysis, which

2 explores the potential for energy and monetary savings

3 for non-regulatory alternatives to a standard. In

4 addition to considering the impacts of any incentive

5 program or initiative to date, the future impact of

6 such programs will be considered. This is likely to be

7 accomplished -- again, this is probably more than you

8 need to know at this point, but likely to be

9 accomplished by modifying impacts or modifying inputs

10 to the LCC and/or NIA models to reflect capital cost

11 changes, market acceptance rates, and other impacts

12 from such programs.

13 It brings us to items 17-1 and 17-2. "17-1:

14 DOE is aware of the existing ENERGY STAR program for

15 the beverage vending machine industry covered under

16 this rulemaking. Are stakeholders aware of any other

17 such programs that should be examined as optional non18 regulatory approaches?

19 "17-2: Are there specific subgroups of end

20 users whom DOE should consider in its review of

21 potential adverse impacts from standards developed

22 under this rulemaking?"
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1 MR. BROOKMAN: Mike?

2 MR. MAU: Yes. Mike Mau, Royal Vendors. I

3 think this goes back to some of what was mentioned

4 before of the purchasers of this equipment being mainly

5 Coca- Cola and PepsiCo. The equipment needs to meet

6 their specifications. Otherwise, it is not going to be

7 purchased. So there is the potential that something

8 gets to an energy efficiency level, but it is not going

9 to be able to meet pull-down requirements, say. Well,

10 that is not good. So maybe they need to be involved

11 for comment on that as well.

12 MR. LLENZA: This is Charles Llenza, the

13 Department of Energy. Well, you also could share those

14 specifications with us. You know, you can be the sort

15 of intermediary if Pepsi -- I'm sure that PepsiCo and

16 Coca- Cola are going to make comments, but I also think

17 that you could be proactive in providing "These are the

18 requirements that" -- you have a list of constant

19 requirements that you are being asked to meet. And

20 that would probably be something good that you could

21 share with the Department that, you know, where if it

22 conflicts with our standards or our test procedures,
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1 that that can be harmonized somehow.

2 MR. MAU: Mike Mau from Royal Vendors. I

3 want to be as proactive as possible, but there are

4 things like that that are confidential. It's not up to

5 us to disclose. It's their procedure, not ours.

6 MR. BROOKMAN: Right. Okay.

7 MR. LLENZA: Just to comment on any kind of

8 confidential information, we also can handle that.

9 Information that we could become aware of that we will

10 not disclose to other parties, but we can use that in

11 considering, in setting our analyses up, so just so you

12 guys know that.

13 MR. BROOKMAN: Yes, Ari?

14 MR. ALTMAN: Ari Altman from the General

15 Counsel's Office. This is a good point you are making,

16 and it is a valid concern. Keep in mind that our rules

17 regulate manufacturers, and we do not regulate your

18 customers. To the extent they want to comment, it is

19 voluntary. And I would encourage you to encourage your

20 customers to be involved in this rulemaking. We don't

21 have a lot of pull in terms of bringing them in.

22 Charles mentioned that it is likely they will comment,
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1 but they don't have to and we don't regulate them.

2 But if there is information that you believe

3 is confidential that is their confidential information

4 and you cannot release it, you may want to mention to

5 your customers that you are involved in this rulemaking

6 and that their internal standards, which are not

7 regulatory standards, may be affected. And to the

8 extent we can take into consideration what their

9 particular internal standards are, we will, but we need

10 to know what they are.

11 MR. BROOKMAN: Okay. And, finally, on to 17-

12 2, are there specific subgroups of end users DOE should

13 consider in its review of potential adverse impacts of

14 standards? Any groups that you think come to mind?

15 No comments there. Okay. That is the last

16 of the slides.

17 MR. MORRIS: Yes, sir.

18 MR. BROOKMAN: As we promised this morning,

19 there is an opportunity now for anybody that wants to

20 to raise issues that weren't covered fully. Additional

21 issues that you wish to cover at this time? Yes,

22 Dipak?
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1 MR. NEGANDHI: Dipak Negandhi, Royal Vendors.

2 Really, I want to thank the DOE for inviting us to

3 allow us to make our comments at this early stage, but

4 the comment was made earlier that the time window

5 allocated for responding to this broad range of

6 questions is very small for small manufacturers like

7 us. And I know Eric Dell from NAMA has already sent in

8 a letter requesting an extension of the timeline. And

9 I would as well request the same, if there is any way

10 possible, to get a 90-day extension, which will allow

11 us to more comprehensively respond to the questions

12 that have been asked.

13 MR. BROOKMAN: Rather than 60 days, 90 days?

14 MR. NEGANDHI: I think the letter from NAMA

15 was requesting a 90-day extension.

16 MR. BROOKMAN: In addition? Ninety in

17 addition to the 60?

18 MR. NEGANDHI: Well, I think their --

19 MR. LLENZA: Forty-five.

20 MR. NEGANDHI: -- current date is 45 days;

21 right?

22 MR. LLENZA: Forty-five, right.
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1 MR. BROOKMAN: Okay.

2 MR. NEGANDHI: Right.

3 MR. BROOKMAN: Gotcha. Thank you.

4 MR. NEGANDHI: So a 90-day extension was

5 requested.

6 MR. LLENZA: It's on top of the 45.

7 MR. BROOKMAN: Okay.

8 MR. LLENZA: Okay.

9 MR. BROOKMAN: Thank you.

10 Additional comments here as we move towards

11 closure? So your last comment, Dipak, causes me to

12 think that NAMA is engaged. They are tracking what is

13 going on here; correct?

14 MR. NEGANDHI: Yes, they are. Unfortunately,

15 as was mentioned, --

16 MR. BROOKMAN: Yes.

17 MR. NEGANDHI: -- Eric had a personal

18 situation today.

19 MR. BROOKMAN: Right. I just wanted to make

20 sure they were on the same page here.

21 MR. NEGANDHI: Yes.

22 MR. BROOKMAN: Okay. So, then, my thanks to
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1 all of you, a very productive meeting, very beginnings

2 of this process but good start. And back to Charles

3 Llenza.

4 MR. LLENZA: Yes. I want to thank everybody

5 for attending who have. I want to encourage that you

6 get the word out that those parties that could not make

7 it to the meeting or are not on our webinar, that they

8 please provide us comments.

9 We will take your comment on the extension

10 period under advisement. I will bring it up with my

11 management.

12 And I do think that one thing to keep in

13 mind, this is a partnership between us and you people

14 that are attending and parties of interest here. The

15 Department always strives to find an economically

16 justified and technologically feasible solution to

17 provide these standards. So the more the industry and

18 everybody weighs in with their comments in terms of

19 their concerns because that is part of what we tried to

20 deal with here, in addition to information the

21 Department doesn't necessarily have or has not

22 currently displayed through the website or in the
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1 technical support documents in the past, et cetera,

2 that would be greatly appreciated because we do strive

3 to get the story right. And we're all in this

4 together. That is the way I see it.

5 So one last comment. This slide is just

6 showing you again how to submit the comments. Docket

7 number and RIN number are key. And then also you could

8 submit things electronically through the email address

9 that is on here. And, then again, there are other

10 methods here.

11 The comment period closes July 19. You

12 should hear back with a certain amount of -- in the

13 next couple of weeks in terms of an extension if that

14 is going to be happening.

15 MR. ALTMAN: This Ari Altman from GC's

16 Office. Charles, can you just clarify for everyone

17 attending how they would hear about an extension? Will

18 it be published in the Federal Register?

19 MR. LLENZA: Right. So what a typical

20 extension and comment period would entail would be a

21 short notice that we would provide that goes in and is

22 published in the Federal Register. We will send out an
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1 email blast to all of the parties in our database,

2 notifying that the comment period has been extended and

3 you will get a new date, whatever time frame it is that

4 we have decided on. Because I have been personally

5 involved with several extensions, I think the

6 Department has been very receptive to that.

7 I know that we do have time constraints in

8 our schedule. That is one thing to keep in mind. I

9 think we are at a point in time in the rulemaking, that

10 it is early enough that we have a little bit of a

11 luxury of convenience to be able to do extensions, but

12 I do want to keep reminding people on time that we do

13 have a deadline. And within that deadline, we will try

14 to accommodate the needs of the parties of interest

15 here.

16 MR. BROOKMAN: Okay.

17 MR. LLENZA: So thank you for coming.

18 (Whereupon, at 12:19 p.m., the Energy

19 Conservation Standard Framework Public

20 Meeting, Refrigerated Beverage Vending

21 Machines was concluded.)

22
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www.CapitaIReportingCompany.com © 2013 

150 
Capital Reporting Company 

Energy Conservation Standard Framework Public Meeting 06-20-2013 

1 CERTIFICATE OF TRANSCRIPTION 

2 I, SARAH VEACH, hereby certify that I am not 

3 the Court Reporter who reported the following 

4 proceeding and that I have typed the transcript of this 

5 proceeding using the Court Reporter's notes and 

6 recordings. The foregoing/attached transcript is a 

7 true, correct and complete transcription of said 

8 proceeding. 

9 

10 

11 

12 

13 Date 

14 

15 

16 

17 

18 

19 

20 

21 

22 

~ ~a ~ \kL 

SARA VEACH 

Transcriptionist 

(866) 448 - DEPO 

www.CapitalReportingCompany.com © 2013 

151 
Capital Reporting Company

Energy Conservation Standard Framework Public Meeting 06-20-2013

Page 1

(866) 448 - DEPO

www.CapitalReportingCompany.com © 2013

1

10 22:9 107:14

10:30 7:21 8:1

100 93:6 100:4

115:13 129:18

1000 1:8

10-1 120:3,17

10-2 120:13,17

10k 121:15

11 4:5

1-1 26:19 30:18

11:00 83:5,6,17

111 4:16

11-1 135:2,10

12 62:2 133:3

1-2 26:22 27:19

12:00 8:5

12:19 149:18

12:30 8:5

121 4:18

12-1 122:20 133:3

12-2 123:3

12-3 123:7

133:4,7,11

13 60:11 62:15

1-3 27:3

13-1 136:2

134 4:20

1-4 27:6 30:18

14-1 136:10

14-2 136:12

145 4:21

147 4:22

15 107:14

1-5 34:2 35:7

15-1 137:9 140:1

15-minute 83:5

16 64:17

1-6 34:10 35:10

16-1 137:12 140:1

17 144:11

1-7 34:14,19

17-1 141:13

17-2 141:13,19

19 12:22 148:11

1975 13:17

19th 76:4

2

2 46:21 107:5,11

133:4 144:12

20 1:12 4:6 82:3

83:4

2004 25:2

2006 21:5,15 24:7

2009 21:5,6 22:10

23:13 46:5,11

76:16 77:1 129:2

132:1 135:7

2012 23:12 129:3

2013 1:12 5:7

12:22 16:20

132:1

2015 18:19

2016 19:10

2019 129:4

20-25 115:11

20585 1:10

20th 5:7

24 4:7

25 82:3 124:7

3

3 39:15 60:11

62:2,15 73:6

107:5,11

30 27:15 82:3

30-year 111:20

3-1 36:13

3-10 47:14,20

3-11 58:1 60:10,15

61:7 62:1

3-12 58:8

3-13 58:12 61:7

62:4

3-14 58:16 59:13

64:17

3-15 59:2

3-16 59:8

3-17 65:8

3-18 65:13

3-19 65:17

31st 23:12

32 49:17

3-2 36:19

32.1 24:15 25:1

32.1-2004 24:7

32.1-2010 25:1

3-3 37:1

3-4 38:18 40:20

3-5 38:21

36 4:9 25:16 52:19

53:5 55:21

3-6 39:2 40:15,16

41:3

3-7 47:3 48:12

3-8 47:9 48:13

3-9 47:14,16 49:3

4

4 39:15 103:16

113:13

4-1 66:13

42 14:11 22:9 63:2

4-2 66:17,22

43 61:12

431.292 22:10

45 13:3 145:20

146:6

4th 13:4 16:20

5

5 4:2,3 73:6

83:6,17 103:16

5.2 24:11

51 71:10

5-1 70:14 73:5,7

5-10 80:21 81:9

83:2

5-2 70:18

5-3 71:3

5-4 73:17

5-5 74:9

5-6 74:14

5-7 76:21 79:20

58 77:3 79:11

5-8 77:22 78:4

79:8,20

5-9 80:17 83:2
Capital Reporting Company

Energy Conservation Standard Framework Public Meeting 06-20-2013

Page 2

(866) 448 - DEPO

www.CapitalReportingCompany.com © 2013

6

6 103:16

60 145:13,17

60-day 19:1,3

6-1 91:6

6291(40 22:9

6295(m)(1 14:11

65 87:1

68 4:11

7

7 42:16,17 43:6,9

103:16

7-1 86:6

7-2 86:13

7-3 86:17 90:12

7-4 86:19 90:13

75 28:6

8

8 103:16

8-1 98:16 99:9

102:10

8-10 109:7 110:2

111:1

8-2 98:19 99:10

102:10

8-3 98:22 99:10

102:19,20,22

84 4:12

8-4 103:17

105:9,13 108:19

8-5 104:1 108:19

8-6 104:5 108:19

8-7 104:8 108:19

8-8 108:22 110:2

111:1

8-9 109:4 110:2

111:1

8E-089 1:9

9

9 113:12

9:00 1:13

90 27:2 28:9

145:13

90-day 145:10,15

146:4

90-degree 25:8,10

28:7

9-1 112:12 113:11

9-2 112:17 113:11

9-3 112:22 113:12

116:4

9-4 113:4,13 116:5

96 4:14

A

a.m 1:13

a/c 10:21 11:4

a/v 10:2

able 10:1 15:20

33:8 51:4 77:5

128:21 137:19

142:9 149:11

absence 112:7

120:9

absolute 55:1

acceptable 48:17

57:6 68:10

acceptance 53:2

56:15 82:15

141:11

accepted 71:20

102:17

access 18:2 113:2

accessible 84:1

107:12

accessory 92:15

accommodate

16:5 25:15

149:14

accomplish 19:9

accomplished

141:7,9

according 61:21

account 26:15

34:16 73:15

100:12 140:10

accounted 100:7

119:8

accounting 72:4

accurate 150:7

ACEEE 3:6 60:14

71:9 102:9

achieve 13:22

58:15 74:15

achieved 58:13

62:5,15

acquire 74:12

across 55:19 57:5

61:2 115:1

Act 13:17 122:11

active 23:10 120:6

activities 121:6

activity 34:6

actual 54:11 62:18

84:22 104:20

105:4

actually 42:11

45:9 72:15 81:15

91:14,18 104:19

107:1,6 108:4

113:21 137:17

add 61:15 113:18

128:16

added 22:9 58:2

109:17 125:3

adding 93:7

addition 18:4

26:11 39:4 48:1

78:6 99:4 141:4

145:16,17

147:20

additional 8:14

16:8 17:16 25:22

29:5,11 30:17

31:21 35:12

37:11 48:20

66:15 67:6

73:9,21 77:21

80:21 81:6

83:1,2 90:12

102:19 110:22

133:16 140:20

144:20 146:10

Additionally

24:11

address 12:16 99:9

148:8

addressed 12:21

73:5 110:3 133:3

addresses 135:17

addressing 73:7

adequate 53:15

77:1

adjusted 26:8,10

adjustments 16:6

17:17
Capital Reporting Company

Energy Conservation Standard Framework Public Meeting 06-20-2013

Page 3

(866) 448 - DEPO

www.CapitalReportingCompany.com © 2013

adopted 24:8

adopting 62:8

adoption 26:20

71:13

advanced 106:16

advantage 121:8

126:4

adverse 141:21

144:13

advisement 130:10

147:10

affect 80:10 81:2

109:18 123:20

affected 122:7

134:16,22 144:7

affecting 46:1

affiliation 5:21

after-market

92:14

Afterwards

121:20

agenda 4:3

7:14,15 11:10

ago 107:11 112:5

AHAM 24:11

78:21

ahead 26:18 33:21

43:2 45:21 47:14

59:19 63:14 77:8

78:3 83:4 102:11

106:6 114:5

AHRI 52:16

air 9:19 11:2

align 49:7

Allen 1:19

150:2,15

allocated 145:5

allow 53:17

145:3,10

allowable 53:10

allowed 21:2 67:16

allowing 45:4

allows 55:20

alluded 97:20

aloud 26:19

already 7:14 9:10

13:4 97:20

139:11 145:7

alternate 81:13

134:18

alternative 47:10

58:14 74:14

80:18 81:9 82:19

alternatives 103:2

141:3

Altman 2:6 8:21

62:22 64:10,15

95:7 96:4 129:15

143:14 148:15

am 7:13 16:10

23:19,22 24:1

26:18 28:12

29:15 31:20 32:8

42:18 44:14

57:12,20 60:17

64:12 82:4 84:6

88:7 91:11 99:19

106:17 117:16

124:21 126:9

140:5 150:7

151:2

ambient 25:9,10

95:15,19

amenable 79:15

amend 13:21

15:19

amended 13:18

22:10 112:8

113:5 119:3

120:15 123:4

134:16

amending 14:13

American 3:5 6:2

among 135:20

amount 18:13

106:8 107:21

117:2 148:12

amplification

52:22

AMS 2:11 40:20

51:14 55:12 75:9

78:10 88:15

92:18 95:14

114:6 127:17

analyses 4:20 8:10

14:7 15:18 17:20

35:18 69:3

74:4,7 84:8,13

90:20 118:18

119:4 135:13

143:11

analysis

4:10,11,12,14,16

,17,18

8:3,4,6,7,8,9,10

14:8,21 15:3,11

17:7,10,15,18

18:14,18,22

19:19 35:19

65:15

66:1,3,4,12

67:9,13,22

68:14,15,16

69:4,5,6,8 76:11

79:21 80:5,16

81:1

84:10,11,12,14,1

6 85:22 90:15,19

96:8,10,11,14

97:15 98:5,13

99:13 102:4

111:8,9,12,14,16

,19 112:5

118:19,22

119:7,21

121:3,5,6,8,9,10,

17 122:1,4,12

123:1

134:1,5,6,8,14,1

8

135:1,8,13,15,16

,17

136:4,11,13,18,1

9 137:6,10,18

138:3,8,13,20

140:2 141:1

analytical 11:12

70:5

analyze 78:5 80:1

121:14

analyzed 75:11

76:15

and/or 12:14 17:7

80:11 109:18

141:10

annual 36:20 42:2

annually 37:2,9

88:6

ANSI/AHAM 23:4

ANSI/ASHRAE

24:7,22 25:1

answer 39:16

40:21 64:11

99:19 102:22

105:13 108:19

113:12 120:17

131:20 139:10

answering 15:4
Capital Reporting Company

Energy Conservation Standard Framework Public Meeting 06-20-2013

Page 4

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answers 103:11

anticipate 104:20

anybody 8:13

144:19

anyone 7:16 33:17

102:20

anyone's 7:11

anything 10:17

33:16 42:16 44:8

57:11 61:15

124:15 127:22

128:1 133:4

appliances 130:1

applicability

34:11 66:18

applicable 59:6

79:6 82:9

application 25:14

29:19 82:5

applications 92:10

applied 32:15 70:1

85:19

applies 68:2

apply 66:15 71:17

applying 73:14

appreciate 33:9

94:4,9

appreciated 128:9

148:2

appreciates 112:1

appreciation

85:17

approach 16:18

53:7 71:4

73:18,22 98:11

102:11 136:3

137:9,13

approaches 11:12

55:9 98:17,20

141:18

appropriate 47:6

48:14 71:21 80:4

104:8 108:22

122:21 135:5

138:20

appropriately

85:13

approved 50:20

81:12,18

area 28:13 87:5

areas 114:7

aren't 62:16 93:15

95:9 101:14

118:10 131:17

argue 124:9

128:14

Ari 2:6 8:19,21

62:21,22 64:10

95:4,6,7 96:3

129:14,15

132:20

143:13,14

148:15

arise 11:19

Arshak 3:11 10:6

ASHRAE 31:1

49:16 50:11,14

52:13,15,17

55:19 94:17

Aside 55:3

aspect 133:15

ASRAC 53:1

assembled 58:20

72:1

assess 121:11

122:14

assesses 96:11

118:22 136:4

assessing 104:9

136:3

assessment 4:9 8:3

35:22 36:2,11,14

57:15 65:1

66:6,20 67:1

68:14 69:9

asset 110:11,12,13

116:16

assets 114:1

115:16

assist 25:22

assistance 128:7

associated 44:22

97:6 101:22

117:11 137:14

140:3

association 30:15

37:6 88:1

assuming 55:1

astute 79:2

attempt 80:14

attendance 7:2

attending 147:5,14

148:17

attention 124:19

130:3

Attorney 3:10

audio 10:18

August 21:6 23:12

127:18

authority 4:6 7:20

20:17 21:3,14

22:3 44:17 45:2

100:17

Automated 2:10

6:5 60:18

availability 71:15

available 9:13

16:17 18:6 21:19

23:5 36:3 38:20

39:1 54:8 58:15

65:4,5 67:5

122:2 124:7

Avenue 1:8

average 46:22

49:21 55:20 57:4

98:13

averaging 25:5

53:12

award 130:21

aware 36:17 41:16

59:6 141:14,16

143:9

away 54:22 55:18

72:22 140:10

B

background 15:17

21:4,14

bad 102:17,18

124:17

badge 83:8

bag 41:2

bait 92:20 93:10

94:22

band 52:21 53:3

57:6

bandwidths 56:17

Bapanapalli 2:8

6:15 90:1

138:2,18

Bars 78:14

base 96:18

97:15,18 116:13
Capital Reporting Company

Energy Conservation Standard Framework Public Meeting 06-20-2013

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based 21:3 28:5

31:2 45:22 46:12

54:1 55:15 56:15

57:4 58:21 68:21

93:5 110:7

113:10 116:17

118:10 119:15

122:1 138:4,7,11

baseline

65:2,4,9,19 68:9

69:8,10,12

70:11,15 71:1

79:22

85:12,14,15,19

86:2,18

88:11,13,17,21

89:3,20 97:1

115:5,6 125:8

126:6,11,13,18

127:11,14,15

128:17,20,21

129:10 139:17

baselines 69:19

125:5 126:8,16

basic 64:4

basically 14:13,16

16:13 21:16

23:16 82:17 84:7

95:18 131:15

basics 41:21

basis 42:2 75:13

88:2 116:3

became 129:2

become 20:12

102:14 143:9

becomes 14:8 20:8

31:4 41:8,11

125:8

becoming 32:1

begin 10:9

beginning 35:18

beginnings 147:1

behalf 5:13,16

30:14 56:15

Belaboring 108:6

believe 13:5 68:2

99:4 144:2

Beloit 63:19

belong 37:19

belongs 56:2

benchmark

103:10

beneath 83:11

benefit 119:22

128:14 137:7

140:15

benefits 45:4

131:2,4 132:7,9

137:3

benefitting 133:1

besides 89:12 99:2

better 29:9 60:4

106:14 131:1

132:11,21

beverage 1:5

5:6,12 11:14

13:20 14:15 21:2

22:7,11,12,14,16

,20,22 23:3,15

24:6,13

25:4,15,20 26:21

27:22 34:4,20

36:5 37:22

38:9,19,22 39:3

42:4 43:8,16

46:17,18,19,22

47:4 48:5,7 59:6

61:2 67:17 68:2

71:6 76:13,18

79:15 80:12,18

81:1,12,19 82:5

85:6 86:7,14

93:10,16

94:20,21 95:22

96:2 99:1,2

103:21

109:1,6,13,17

113:6 117:18,21

123:1,5,21 127:9

133:2 135:5

141:15 149:20

beverages 39:5

48:1 78:6 94:1

95:10,11

beyond 126:6

128:21

bids 114:12

bigger 114:7

biggest 99:14

bills 101:15

binds 111:14

bit 13:15 19:12

20:17 60:21

69:18 89:17

96:20 97:17

115:2 129:1

130:14 132:2

149:10

blame 11:2

blast 149:1

blue 12:2

boiled 118:20

boss 5:17

bottle 22:16 23:3

bottled

22:7,11,13,20

46:18

bottlers 99:2,3

103:14

bottling 103:3

106:22

bottom 15:6 16:7

55:10,16

bound 53:6

Bouyelas 2:7

box 12:13 101:18

boxes 12:2

brazing 108:2

break 7:21 8:4,7

83:3,5 96:20

Brenda 12:16,21

73:20

bridge 94:19,20

bridges 84:11

brief 7:14,17

83:19

briefly 16:12

bring 56:9 111:5

147:10

bringing 143:21

brings 86:5 91:5

98:15 112:11

120:2 141:13

broad 145:5

broaden 53:10

broader 53:16

broadly 131:9

Brookman 2:3

4:2,4,21 5:2,8,19

6:4,19 7:1,7,10

8:19 9:1,4,7

10:5,14,22

11:6,8 13:6,9

27:12,14 29:3,11

30:2,4,10,13
Capital Reporting Company

Energy Conservation Standard Framework Public Meeting 06-20-2013

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31:6,9 32:6,16

33:12,20 34:17

35:7,16

37:4,16,18 38:2

39:10

40:3,6,10,14,19

42:6 43:2,12

44:5,9,12

45:6,16

48:12,18,20

49:1,10 50:5,8

51:2,7,11

52:2,5,11

53:8,19 54:13

56:5 57:7,10,13

59:11 60:10,13

61:6,10,22 62:21

63:13 64:16

65:21 66:21

67:6,11,21 71:7

72:8,11

73:1,4,8,20

74:17 75:7,15,19

76:8

77:3,5,13,16,19

78:3,9 79:7,18

81:5,20 83:1,20

86:22

87:11,14,19

88:1,4,7,20

89:22 90:11

91:8,20,22

92:4,7,17 93:9

94:5,12 95:2,6

96:3,6 99:8

100:10,22 101:2

102:5,7,19

103:15 104:11

105:3,9,19,22

106:2,6,19

108:18 109:20

110:14,18

113:10 114:4,17

115:7 116:4

117:14,22

118:15 120:16

123:10 124:1

127:16 128:6

129:14 131:10

133:3,8,13,16

135:10 136:14

137:15

138:1,15,22

139:8 140:1,19

142:1 143:6,13

144:11,18

145:13,16

146:1,3,7,9,16,1

9,22 149:16

brought 46:20

54:17 124:18

bucks 128:13

build 37:22 115:6

building 5:8 10:3

34:21 83:7,8

buildings 114:12

built 96:1 130:19

bullet 97:19

118:20

bunch 27:16 37:18

bundled 21:16

Buns 78:15

burden 122:15

123:9 133:5

business 133:15

businesses

122:10,11 123:4

buy 115:14

buys 63:16

BVM 22:10 23:13

24:16 25:12 36:2

39:8 46:12 59:4

70:7 76:16 77:1

104:2 124:18

125:11 135:6,7

138:6

BVMs 46:4 85:6

121:12 131:13

C

calculate 70:2

86:20 119:12,19

131:3

calculated 119:20

calculates 90:16

calculating 97:7

calculations 79:1,5

California 2:12

canned

22:7,11,13,16,20

23:3 46:18

capable 26:7 44:19

capacities 65:14

capacity 45:12

60:22 65:14

76:19 77:7 78:12

88:8 136:9

capital 1:20 97:10

119:5 141:10

capture 89:9

captured 72:18

capturing 132:7

carbon 81:12

136:21 137:5,7

careful 124:11

Carlo 98:11

carried 98:12

carries 37:9 103:6

cartoon 71:10 72:4

case 35:3 41:6 57:5

70:21 97:15,18

cases 120:1 129:18

cash 121:22

catalogues 69:15

cataloguing 75:17

catch 129:12

Catch-22 128:18

categories 39:15

category 22:19

93:18 123:21

causes 7:22 81:15

146:11

centered 133:11

certain 53:1 62:8

148:12

certainly 17:13

28:14,22 29:15

32:22 33:9 35:14

41:12 42:4 53:10

61:17 68:4 81:22

124:17 128:8

131:18 133:14

CERTIFICATE

150:1 151:1

certification 27:7

28:5,8

certifications 48:4

certify 150:4 151:2

cetera 11:17,22

17:17 73:16

139:4 148:1

CFR 22:9

chain 28:21

challenge 60:20

challenged 71:9

chance 7:5 111:2

change 25:12,18

30:21 58:6 90:7
Capital Reporting Company

Energy Conservation Standard Framework Public Meeting 06-20-2013

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104:7 138:7

changes 24:20

34:7 75:11

80:5,7,10 104:9

109:18 134:10

138:12,14

141:11

changing 51:6

103:22 126:16

135:21

channel 84:20

85:1,3

86:1,11,16,21

87:12

channels 84:21

85:6,8,10

86:7,11 87:1

chapter 35:21

characteristics

38:9 47:12 68:11

characterize

36:2,4 65:18

68:16

charged 82:2

Charles 2:16 4:5,6

5:11 7:20 10:15

11:8 29:3 33:2

53:19,20 61:13

100:10

114:18,19

124:20

131:12,22

138:22 139:1

142:12 143:22

147:2 148:16

Charlie 35:19

73:20 100:9

109:2 133:21

chart 9:8

chocolates 95:20

Christine 1:19 5:3

150:2,15

Christopher 2:14

circled 111:12

clarification 34:19

63:13 68:12

74:18

clarifications

24:17

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54:19,21 57:2

63:7 90:2 127:8

148:16

clarifying 25:3

class 22:12,15,17

23:11 26:1 27:20

28:17

29:18,21,22

36:16,21 37:3

40:12

46:3,6,10,11

47:7,13,21 49:17

50:14,18 58:9,10

62:2 65:5,16,19

68:19 69:11

70:14 71:2

76:12,15,17,18

77:22 78:5,6,7,8

79:12 86:12

95:17

112:9,16,19,21

113:1 119:15

125:13,15,20

classes 45:19,21

46:4,6,9

47:4,5,6,10

48:13,14,16,18

65:10 68:8 77:8

classification

40:12

classifications

49:7 50:22 51:10

classifies 29:22

clear 32:13

clearinghouse

37:10,15 87:18

clearly 32:8

126:21

climate 92:12

climates 91:7,16

closer 40:7

closes 17:14 19:4

148:11

Closing 4:22

closure 146:11

CO2 67:4 140:8

Coca 142:5,16

Coca-Cola 56:18

codes 41:19

codified 12:9

coffee 83:10,14,16

cognizant 115:18

coincides 21:22

Cola 142:5,16

cold 91:7 92:12,21

colder 55:17 91:16

coldest 55:16

collapsing 124:10

collate 121:20

colleague 23:19

collect 37:7

Collin 3:9 6:11

32:9,17 42:14

44:7 51:11

54:13,15 56:21

59:20 63:6 64:7

72:12,20

75:21,22

Collins 2:10 6:5

40:20 43:14

51:14 54:21

55:12 75:9 78:10

88:15 92:18

95:14 114:6

115:21 127:17

Collin's 74:17

COLLINS 6:5

40:20 41:21

42:9,17 45:8

51:14 52:4 55:12

57:8 75:9,18

78:10,17,20

88:15,19 92:18

93:12 95:14

114:6 127:17

128:7

column 15:1

combination

22:15,18,19

23:15 32:7 33:15

34:13 40:22 46:7

58:10 62:3 65:11

77:22 78:5

combining 85:12

86:1

comes 22:8 62:13

128:19 140:9

comfortable 37:14

coming 67:3 85:8

134:1 149:17

commend 49:5

comment 8:13

12:22 17:5,14

18:21 19:1,4

24:4,18

26:18,19,22

27:3,6 30:20
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38:3,18,21

40:14,17

47:3,9,16,20

48:11 51:19

57:22 58:1,12,16

59:2,8 60:18

61:16 62:1 64:13

65:8,9 66:13,14

73:17 76:4 78:20

79:14 85:7

86:6,19 88:11,12

91:6 94:15

98:16,19 104:13

105:10 108:15

109:4 110:15

112:12 113:6

117:7 120:3,7,13

122:20,21

123:3,13 124:4

131:8 134:9,10

140:5,20 142:11

143:7,18,22

145:4 146:11

147:9

148:5,11,20

149:2

commenting 91:12

comments 4:21

8:14 9:15 11:22

12:12 16:18

18:4,8,13 19:6

27:15,16 29:11

30:18,21 33:9

34:1 35:7,12,14

36:12 45:7 48:20

52:9,13 54:19

58:8 61:14 64:19

65:21 66:17

72:12 73:6 74:1

76:6 77:6,21

79:18,20 81:6

83:2 90:12 94:12

99:9 102:19

103:13 110:22

112:11 113:22

116:4 120:2

123:7 133:16

135:10 136:16

137:12 140:1

142:16 144:15

145:3 146:10

147:8,18 148:6

commercial 53:2

67:14 68:8 99:2

117:20

committee 42:1

common 48:5

commonly 95:15

community 42:11

companies 38:6

103:3 108:1,4

110:12 115:14

company 1:20

107:1

comparable 60:22

compare 18:7

compared 134:21

comparison

103:10

compelled 72:18

competing 87:16

competitive 61:20

63:20

complaints 125:12

complement

132:20

complete 9:12

151:7

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complex 67:1

135:20

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114:8

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complying 130:19

component 69:15

70:8 71:14

92:14,15 111:18

112:4

components

63:17,21 65:18

70:3,9,12,17

72:1

composed 39:9

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145:11

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53:13 59:16

60:2,5,18 61:1

63:19 64:1,5

70:7 95:21

103:22

compressors 44:21

45:9 60:19 62:18

conceptual 72:3

concern 72:2

100:19 143:16

concerned 31:16

51:9 53:5 122:9

132:17

concerns 12:20

111:8 121:19

134:14 147:19

concluded 149:21

condense 7:6

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condition

25:4,9,11

conditioner 11:2

conditions 41:7

52:16 70:6 71:1

conduct 121:13,22

136:11 137:10

conducted 21:4

conducting 121:8

conducts 121:5

122:11

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143:4,8 144:3

confines 30:22

confirm 55:6 88:8

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consensus 31:2

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5:5 11:13

13:17,19

15:9,18,21

16:1,5,11

20:1,3,22

22:1,2,5 46:3

65:7,11 80:7

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120:15 121:11

123:5 149:19

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34:8,15 35:8

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123:8 130:17

135:3,5 136:12

141:20 144:13

consideration 9:8

25:18 34:12

74:11 101:12

123:17 137:18
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considered 22:17

32:11 41:18

47:7,12,17 48:15

81:18 82:6,7

99:3 103:2 125:7

130:16

138:17,19 141:6

considering 24:18

25:9,13,20

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122:16 131:9

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74:3

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142:18

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107:21

Consulting 4:8

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46:2 55:9 82:13

101:17 132:11

139:13

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24:14 69:12,17

70:4,7,8,9,15,16

71:16 80:11,20

91:1 93:8 101:20

109:16,19

119:14 120:8

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content 7:22 35:19

context 8:12 76:2

continue 8:1 17:11

continued 116:15

continues 72:3

79:22

continuing 117:9

contract 103:7

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contributes 90:22

contributions 17:3

control 26:4,5 41:4

controls

26:6,10,15 27:10

35:3 39:6

convenience 118:5

149:11

conversation 73:2

111:5 113:11

conversion 119:17

convert 85:14

119:17

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cooled 22:14 31:20

38:11,20 40:1

46:13,15 47:17

49:17 55:6,7

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46:12 59:10

64:19 93:2

cooperation 42:10

correct 105:18

146:13 151:7

correctly 106:9

111:19

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15:3 36:21

cost 4:14 8:6

69:11,13 71:16

74:12 75:2,5

80:19 81:2

96:14,16,22

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99:13,15 103:8

104:21 116:17

117:11

119:4,19,20

120:11 128:2

132:13,14,15,18,

22 137:5 141:10

cost-efficiency

68:19 69:2

costs 70:17 73:15

80:12 85:17

89:12,13,15

90:3,4,9,19

96:9,17,19

97:9,10,12 98:1

104:6,10,14,18

111:8,11,14

118:18 119:5

134:5 135:22

Council 3:5 6:2

Counsel 2:6

Counsel's 8:22

95:8 129:16

143:15

country 42:11

43:20 112:10

140:10

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54:17,20 62:12

97:17 138:12

148:13

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51:2 75:12 87:20

101:3 115:19

123:19

Court 10:19

150:1,2,15

151:3,5

cover 23:7 89:15

116:21 144:21

coverage 23:7

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23:10 26:21

36:10 45:21

46:10 80:9,12

83:3 86:8,15

98:21 109:1

112:19 137:11

141:15 144:20

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29:13,20 30:7

37:8,14 43:13

56:7 77:10

87:4,5 91:9

101:10 106:20

108:11 110:1

113:16 115:8

116:12 118:1

created 135:19

creating 47:5

48:13

creation 26:13

47:21

credit 139:12

credits 124:12

criteria 47:5 48:13

66:7,14,18

103:14 110:5
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critical 14:2 60:15

cross 95:12

crucial 90:18

c-store 118:5

cubic 23:2 65:14

cue 9:22 10:1

cuing 9:14

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cumulative 122:15

123:9,18 133:5

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28:5 29:20 33:5

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48:9 57:1 59:4

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131:5,20 134:14

135:1,2

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62:12 77:17

82:14 96:15

98:20 99:1

107:22 111:9

114:10 124:8

127:20 128:3

130:13 139:14

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cycle 103:20 110:6

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25:6 37:7,17

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68:22 70:19 71:1

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101:3 111:22

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145:13,20

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deal 85:16 102:15

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108:1

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113:19,21 116:8

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124:17

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124:21 129:6

130:10 131:9

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139:2 142:13,21

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20:20 28:16 29:1

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92:11

designs

58:2,5,14,17

62:5,6,16
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75:1 107:19

desire 103:7

destroyed 135:19

detail 17:22 33:4

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2 85:5

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91:6 94:18
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103:17 104:5,8

108:22

109:4,11,14

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138:19

email 12:13 148:8

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Emily 2:17 6:21

9:5 10:5 111:3
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emissions

136:18,19,21

137:2,3,8,10,14

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establishes 15:5

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46:1 65:18,20

109:17
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federal 14:10

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38:11,20 40:1

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getting 24:3 26:17
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130:8 131:1

given 54:18 74:8

76:7 84:20 86:4

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hours 90:22 91:1
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24:11

huge 32:1

hum 10:18

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52:14

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67:15

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106:22

113:18,19
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116:20 118:9

121:22

123:14,20 124:5

129:12 133:2

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34:21

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66:13,17

70:14,18 71:3

73:5,17 74:9,14
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80:17,21 112:22

122:20 123:3,7

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items 35:14

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leverage 71:22

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life-cycle 4:14 8:6
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97:7 99:13,15

111:14 119:4

lifetime 96:17,22

97:12,16 99:16

109:11,13 120:8

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109:1,5,21

light 7:1

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lights 70:9

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113:4 141:6,8

143:22

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115:16

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line 50:17 52:15

79:9 111:5

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128:8

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list 10:4 16:22

17:2 58:3 61:15

63:1,2 142:18

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66:19

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123:15

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19:12 20:17 40:7

60:21 69:18

89:17 95:21

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142:12 143:7

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148:19 149:17

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location 90:6

116:15

locations 115:16

116:21

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132:15

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124:12,14

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39:10 55:18

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139:5 143:21

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81:16 104:19

132:12

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103:8

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27:7,11 34:4,5

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lunchtime 73:1

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M

machine 5:13

11:14

22:15,17,18,19

23:3 26:8 29:21

31:19 32:8 33:15

38:11 43:10,22

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47:17 48:7

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23:11,15 24:6,13

25:15 26:9,21

27:21 28:9

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36:5

38:1,10,19,22

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41:13,16

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80:12,19

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118:21 119:11

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73:16 97:11 98:1

103:18

104:2,3,6,9,14,1

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82:17 85:21

121:19,21
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majority 37:21

43:21 110:7

115:21 116:16

man 121:22

management 26:6

27:10

34:16,19,22 35:3

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128:13 130:8,21

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39:21 51:9 66:8

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39:14 47:22

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11:16 18:17 19:7

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53:18 70:17

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137:15,16

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38:20 39:1,8

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124:13 126:16

127:6,11 141:11

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22:11,13,16,20

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25:19,20,22

31:21

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mechanism 38:10

46:13

mechanisms 74:19

medium 76:17

meet 27:9 41:18

42:15 58:22

59:18 65:6

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19:15,16,17,20

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43:7

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24:17 34:12,15

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137:7,13 140:2

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136:19

monetized 137:4

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95:4 96:7

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102:6 103:17

104:20 105:6
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99:11,17,20

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124:2 140:4

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neither 150:7

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119:12

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108:12 141:17

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78:13 95:13

non-classified

31:18

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32:11

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non-food 95:13

non-HFC-based

140:7

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39:6 48:6

nonproduction

73:15

non-refrigerated

22:21 38:16

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non-regulated

31:22

non-regulatory

36:8 141:3

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74:2

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nothing 57:20

59:21 83:2
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18:11 19:4 20:4

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43:6,7,9 44:1

nuance 63:16

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118:6

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28:17 29:21

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130:15

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86:4,14 88:11

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102:2 105:1

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58:19,20,22

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packet 7:12

packs 62:18

page 18:1 132:6

146:20

pallet-mounted

106:10

parameters 70:20

Pardon 78:18
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115:11,13 116:1

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129:18

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phase 98:12 121:7

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138:3

point 11:20 13:12

18:15 32:10
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21:2

presence 38:15

46:14

present 3:3

4:8,10,11,19

6:17 11:12 23:22

24:1 27:13 28:3

29:2 31:8,11

32:4 33:13,22

35:1,13,17 38:8

39:17,20,22 40:2

41:15 42:7,13

44:3,7 45:18

49:11 50:1,12,16

51:1 52:6

57:12,14 59:19

61:9 64:22 66:1

67:8 68:13

72:7,9 73:12

74:2 76:10 77:4

78:1,4,16,19

79:13,21 95:18

119:3 121:4

127:8

133:7,10,14,19

135:3

presentation 12:6

press 130:12

131:14

pretty 12:9

23:5,18 33:18

63:1 95:1

prevent 31:22

previous 65:10

107:11 113:11

price 68:17 70:2

71:5 73:13,21

90:5,10 97:9

127:21 136:8

prices 61:21 73:19

84:15,17 85:15

98:14,18

101:8,22 128:5

primary 84:17

119:18 121:10

principles 70:5

prior 49:6 131:13

privilege 133:20

proactive 142:17

143:3

probably 28:3

29:9 51:16 55:14

92:14 134:7,17

141:7 142:20

problem 45:11

54:2 126:9

127:18 132:16

139:5

problems 12:19

procedure

15:7,13,20

16:3,4

19:17,18,21,22

21:14 22:4 23:20

24:6,8,17,22

25:7,11,12 26:20

27:10 30:22

34:1,3,11,12,16

56:4 58:6

70:6,21,22

125:17

139:19,21,22

143:5

procedure/test

24:2

procedures 4:7 8:2

21:15,17,21 26:4

70:22 142:22

proceed 13:13

27:16 84:3 111:6

proceeding 71:17

82:8,16

150:3,4,5,7,9,10

151:4,5,8

process 4:5 7:19

11:14,15,18 12:1

13:16 14:4,6,17

15:7

16:1,6,8,11,14

17:4,8 18:5

19:3,12 20:13

21:19,22 31:2

35:20 52:14 80:8

100:2 126:4

129:3,7,9

134:2,8 138:6

147:2

processes 15:15

produce 29:21
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33:16 77:12

115:19 127:2

produced 45:9

84:16 91:14,17

115:12

producing 92:2

116:16

product

25:14,16,19 26:1

27:4 49:7

56:12,13,15 66:9

87:2 115:1 124:9

132:12,13,15,17

production

69:11,13 73:15

productive 147:1

products 20:21

21:12 28:16

31:14 32:2,11

38:17 40:17

45:14 53:2 56:16

60:22 61:5

115:12,22

129:18 130:2

139:13

product-specific

122:17

profit 85:17 89:4

profits 116:18

program 20:22

37:14 114:14,15

115:2 122:19

128:18

130:18,20

141:5,14

programs 114:20

126:1

141:6,12,17

Project 2:16

projected 98:3

119:15,16

projecting 103:4

113:1

projections 102:16

prolong 114:2

117:9

promised 13:9

144:18

propane 81:17

82:3

property 63:10

64:5

proportion 37:2

proposal 33:5

34:15 86:17

88:13

proposed 15:12,14

16:18 18:11

19:4,5 20:4

73:18 98:17,19

127:12 134:3

136:10

proposing 18:16

proprietary

58:4,13

62:5,6,15,17,20

63:3,9,18,19

64:2

74:3,5,6,9,16

protect 41:5

protected 63:10,22

74:19

provide 17:4 19:2

20:4 29:16

56:12,20 70:19

76:7 87:6,17

88:5 147:8,17

148:21

provided 14:9

provides 11:18

16:13,16 53:14

76:4

providing 18:18

142:17

provision 21:8,20

26:13 31:22

provisions 20:20

21:13 22:1,4

public 1:4 2:3

5:5,9,13 8:13

11:11 14:10

18:3,7,22

19:14,16,17,19

20:5 69:14 76:2

121:14

128:1,2,15 134:9

149:19

publication 20:9

24:22

publicity 130:9

publicize 130:11

publicly 122:1

publish 17:22

published 24:7

71:12 148:18,22

publishes 42:1

pull 41:9 44:1

143:21

pull-down 41:14

44:15,21 142:9

purchase 84:17

85:14 89:10

96:16 97:9,13

purchased 62:19

117:10 142:7

purchaser 102:1

purchasers 56:10

101:13 103:3

142:4

purchases 99:5

117:3

purchasing 117:2

purpose 11:11

22:22 36:1 53:18

68:15 121:10

126:5

purposes 50:21

95:12 119:11

126:2

pursuant 58:5

pursue 57:11

push 126:15

pushing 126:2,16

127:5,6

putting 18:10

28:21

Q

quads 132:8

quality 56:12

quantifies 111:10

135:19

quantify 91:20

92:6

quantitative 57:3

113:7,14

quantities

67:15,16 87:10

quantity 91:13

quarter 18:19 19:9

question 12:5

31:12,20 37:6

39:15 41:16

44:16 45:1 49:3

52:22 56:2 60:15

61:3 63:18 64:11
Capital Reporting Company

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65:16 67:18

75:14 94:7 95:6

99:18 102:21

103:4,13 105:13

106:4,22 114:16

116:6 117:16

129:19 131:12

137:22

questions 10:8

12:10,20

17:1,3,5 35:10

44:6 108:8

123:18 127:19

131:20 145:6,11

quick 132:6,10

quickly 8:8 75:14

83:15 127:9

134:4 139:15

quiet 7:9 60:12

quite 32:13 36:11

129:1

quoted 15:5

R

R&D 73:16

raise 9:21 58:4

144:20

raised 108:8

ramifications

97:22

range 26:3

52:1,3,8 53:16

55:11 57:18

67:17 82:3 145:5

ranges 53:10

rant 72:6

rapid 44:21

rarely 52:17

rated 39:7

rates 97:15 98:20

99:4,7 101:8

102:8,12 112:18

119:9 141:11

rather 50:21 71:16

72:1 78:17

102:14 104:19

106:11 117:20

145:13

rating 71:1

rationalize 116:15

ratios 54:1,10

react 137:19

reading 9:2

ready 31:11

137:19

real 94:8 126:9

127:22

really 12:18 31:13

38:4 39:15 45:15

51:19 59:13,15

63:9,11 91:21

92:6 93:15,16

94:3,22 100:17

102:22 103:5

110:10 118:4

131:12 134:4

145:2

reason 30:15 76:3

87:7 89:2,6,7

93:1

reasonable 52:8

rebuilding 120:8

rebuilt 120:4

rebuilt/

refurbished

109:9

recall 43:10 64:8

106:9

receive 130:13

134:9

received 7:12

18:12

recent 67:16

recently 107:4

receptive 149:6

recess 83:19

recognition 114:8

recognized 38:9

128:11

recognizes 98:22

recommendations

17:17 58:9

recommends

66:16

reconcile 79:4

record 9:11 10:11

14:10 150:7

recorded 150:4

recordings 151:6

recover 97:3

redoing 134:12

139:20

reduce 53:13

reduced 137:3,7

150:5

reducing 41:6

reductions 137:14

140:3

reemphasize

123:13

reestablished

125:19

refer 12:9 13:18

118:9

reference 12:14

21:18 22:8 24:21

79:13

referenced 24:12

referred 66:11

referring 34:21

43:14 76:1 81:3

89:1 107:1

108:12 131:7

reflect 47:18 49:4

58:6 141:10

refrigerant

81:13,15,16

103:1 108:13

refrigerants

67:3,14 80:18

81:5,10 82:15,20

104:16,17

140:8,16

refrigerated 1:5

5:6 22:13,16,20

23:1,3 24:6,13

31:14,15,18 41:1

42:20 43:5,6

46:18 76:19

78:22 123:21

149:20

refrigeration

44:15 45:12

55:17 75:1

95:16,19 106:10

107:13 117:20

123:20

refrigerator 24:12

refrigerators

61:20 68:7

refurbished

100:5,12 107:8

120:4

refurbishment
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105:19,20

109:11,12,16

114:1 117:8

120:7,10

refurbishments

109:15

Regal 63:19

regard 130:11

regarding 25:8

26:20 27:3,10

47:9 85:2,8

112:20 135:1

regards 25:19

56:17 101:16

112:5 114:2

116:13,19

region 98:10

Register 14:10

148:18,22

regular 88:2

regulate 143:17

144:1

regulated 45:4

126:7

regulations 67:19

122:17,18,19

123:8,20 133:5

regulatory 36:8

59:22

80:5,7,10,22

122:11,15

123:9,19 133:5

141:1,18 144:7

reissue 14:14

related 37:12,17

77:15 82:14

112:13 140:6

150:8

relation 104:14

relations 54:11

relationship 68:17

71:5 124:22

relationships

54:10

relative 27:20 85:9

86:9 112:20

relatively 61:20

82:2 90:17

release 131:14

144:4

released 17:12

releases 130:12

relevant 38:4 78:8

86:20 103:13

106:12 111:22

relieving 107:17

remaining 66:10

116:11

remanufacture

114:1 117:8

remanufactured

100:18

remanufacturing

100:1 105:21

remark 55:14

remarks 4:3,22

5:11 7:17 13:10

remember 23:13

remind 56:9

reminding 88:22

149:12

removed 58:3

rent 90:6

repair 97:11 98:1

104:6,10 105:2

repaired 106:14

repairing 107:7

repairs 103:19

104:3,4

105:11,14 107:3

repeatedly 71:11

replaced 106:15

107:15

replaces 37:2

replacing 107:8

reported 1:19

151:3

Reporter 10:19

150:1,2,15 151:3

Reporter's 151:5

Reporting 1:20

represent 65:2

68:5 76:14

representative

76:11,13,15,22

77:11 78:8

112:18

represented 30:4

37:21 38:1 43:17

76:18

request 12:3 57:21

65:8 66:13 72:11

86:5 91:5 98:5

120:2 122:20

145:9

requested 146:5

requesting

145:8,15

requests 24:4,18

26:18,19,22

27:3,6,14

34:2,10,14 36:12

38:18,21 39:2

47:20 48:10

54:19 56:15

58:1,8,12,16

59:2,8 71:3

76:21 80:17 85:7

86:6,9,13,17,19

98:16 112:12

134:10 136:2

137:12

require 28:8 99:6

108:13 114:13

required 14:14

28:7 80:1 140:16

requirement 14:12

27:1,4

requirements

15:2,4 27:9

41:19 56:13

67:17

142:9,18,19

requires 26:5

requiring 25:20

rerun 69:22

research 15:18

69:17 102:3

reserved 32:12

reserving 23:14

residential 61:20

respect 27:18 49:2

52:21 60:15 81:9

102:10

respond 37:5

75:13 145:11

responding 145:5

response 72:13

106:21 120:20

responses 12:7

18:14 35:11

121:20 122:1

134:10
Capital Reporting Company

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rest 31:19

restrooms 83:9

result 28:6 136:5

resulting 119:1

135:19 137:8

results 70:20

96:21

resume 83:6,20

retained 77:2

return 110:10

returned 107:15

returns 9:5

review 4:4 7:14,16

17:15 21:9 64:12

72:19,22 141:20

144:13

reviewing 101:13

reviews 137:6

revised 34:3

reward 130:19

rework 108:5

reworked 107:8

reworking 105:16

RIN 12:14 148:7

rise 89:12

rising 116:17

risky 102:11

river 93:21

robust 14:8 18:13

rolls 49:16

room 1:9 125:13

round 106:8

routine 104:6

Royal 2:19,22

6:9,10 30:19

33:14 39:13,14

43:1,3 48:17

49:14 51:8 59:12

62:10 68:1 81:8

82:11 94:15

99:11 100:2

104:12 123:12

140:4 142:2

143:2 145:1

rule 14:12

15:11,15 18:11

19:5,8 20:5,6,10

21:6,16 22:10

23:14 46:5,12

76:16 77:1 95:18

129:2 135:8

rulemaking 4:5

7:19 11:14,17

13:2,15

14:4,6,17

15:7,12,14

16:8,14 17:4,6

18:2,11 19:3,5

20:4 21:4,19,22

26:21 28:4 30:21

32:15 35:18

36:10 46:8 47:11

74:11 80:8,13

86:8,15 98:12,21

100:11 106:8

109:2 112:19

125:11,21,22

126:12 127:10

129:22

130:4,6,16

131:4,13 132:5,8

134:3 135:4

136:7 137:11

138:6,11

141:16,22

143:20 144:5

149:9

rulemakings 15:8

20:19 49:6

102:14

rules 11:10 16:15

23:6 31:3 42:1,3

128:3,13,22

143:16

ruling 68:2 127:19

run 53:13

S

S.W 1:8

Sachs 3:5 6:2 7:5,9

10:17 11:2

27:17,18 28:12

30:3 31:9,12

32:7,17,20 33:1

34:17,18 35:6

44:11,13 48:22

49:2 52:11,12

60:11,12,14

61:17 63:15

67:10,11,12 68:4

71:7,8 72:20

73:3,7 81:21

82:21 93:10

94:3,7 102:9,21

106:4,7 108:6

117:15,16 124:3

131:11 139:9,18

safety 39:8 41:5

42:3,10,20 66:10

68:11

sale 104:2

sales 85:13 86:3

98:14 136:8

sampling 60:16

sanitary 43:15

SARAH 151:2,13

Satish 2:8 6:15

89:22 90:1

138:1,2

saturation 112:18

save 54:3

saving 45:5 132:8

savings 21:11

26:15 54:11

111:10,11

118:22

119:5,13,20

137:1 141:2

scale 82:9

scan 35:10 108:18

scenario 113:8

scenarios

113:7,13,14

schedule 13:2

14:7,8 83:4

104:22 105:3

149:8

scheduled 34:6

scope 56:13

100:14,16

scopes 110:5

Scott 2:21

4:12,15,17,20

6:13 84:4,6

99:12

scrapping 99:22

screen 61:11 66:6

screened 74:5

screening 4:9 8:3

66:3,4,14,18

67:9,13 68:14

scrutiny 75:17

sealed 22:12

Sean 2:12

searches 75:12

seat 9:5
Capital Reporting Company

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SEC 121:15

second 25:3 33:22

84:21 97:10

119:1

section 23:18

24:2,11 57:22

66:20 81:2,3

sectors 99:2

seeing 18:9 61:18

81:22 117:17

118:8 126:9

seek 80:3

seeks 36:13,19

37:1 47:3,9,16

65:9,17 70:15

73:17 98:16,19

103:17 104:5,8

108:22

109:4,12,14

112:17,22 113:4

120:3,7,13

122:21 123:3

135:2 136:10

137:9

seem 28:22 45:3

68:20 131:18

seemed 54:17

seems 28:14 67:18

68:9 102:10

103:11 113:10

120:16 129:19

seen 49:5 77:14

select 65:9

selection 47:2

55:10

selects 65:4,6

76:11

self-evident

128:10

self-service

118:12,13

sell 29:10 36:16

39:4,6,9 41:17

selling 68:17 70:2

71:5 73:13,19,21

84:15

send 12:15,17

128:2 130:11

148:22

sense 54:8 88:14

114:16 128:19

130:2

sensible 52:2

sensors 34:6

sent 145:7

separate 15:15

38:16 46:2,14

114:20 126:1

separately 44:18

sequence 8:1

serious 101:4

service 28:2 29:1

66:8 104:21

107:15

117:18,19

118:3,7

serviced 106:11

services 108:16

135:21

servicing 108:8

116:17

sets 16:14 20:19

116:1

setting 14:22

126:7 129:20

133:1 143:11

setting/resetting

129:9

settings 26:4,6

settles 105:8

setup 81:11

seven 14:21 15:2,4

21:21 24:16,19

119:10

seventh 26:12

several 45:10

98:15 112:5

113:19 116:8

149:5

shaking 64:7

share 9:19 120:3

142:13,21

shares 97:19

112:15

shelf 38:13

shift 53:3 77:14

107:4 117:17

shifting 72:17

135:20

ship 39:5 92:19

shipment 80:19

113:14

shipments 4:16

8:8 36:6,20

45:13 81:2 86:10

97:21

111:12,16,17,19

112:1,4,14

113:3,5,8 116:7

118:18

119:4,15,16

shipped 35:2 37:2

45:10 95:16

111:20

shop 83:10,14

106:11

107:10,16

108:14

short 75:10 139:9

148:21

shortest 69:20

showing 148:6

shown 75:3 76:16

84:11 97:8,11

98:11

Sieben 3:7 10:7

sign 130:2

signal 137:20

significant 106:18

107:21 117:2

significantly

134:15

silent 9:18

similar 68:19

simplistic 71:9

simply 90:16

simulate 70:12

simulated 70:5

sir 144:17

site 119:18 135:8

site-to-source

119:16

situation 115:17

146:18

six 14:12,15 17:9

20:14 21:7 52:4

55:5,10,14 67:20

72:19 129:11

sixth 26:2

size 45:12 76:13

77:15 79:12

sizes 61:19 65:13

76:12,14,15,17,2
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2 78:8

slid 106:11

slide 16:4 27:15

32:5 36:13

61:8,12 63:2

69:7,18 71:10

84:21 86:6 87:1

96:20 98:11

118:20 120:3

148:5

slides 24:19 55:4

63:8 72:15 85:8

98:6 112:5

133:22 144:16

slightly 91:5 136:6

slow 67:10

small 36:18

45:13,14 60:19

71:21 76:17 87:9

91:13,19 93:14

95:19,21

122:10,13 123:3

133:14 145:6

smart 137:18,20

139:2,12

snacks 94:2

SNAP 67:16 68:2

81:11,12,19 82:5

123:19

social 137:5

software 39:5 41:5

sold 35:2 47:22

48:2 129:18

soliciting 103:13

solution 147:16

solutions 2:3 3:11

5:9 64:2

solve 33:8

somehow 143:1

someone 49:12

108:2

sophisticated

132:16

sorry 32:7 33:13

64:9 72:20 114:5

sort 83:14

117:15,17 132:3

142:14

sounds 10:20 32:6

73:1 108:7

source 15:5 64:2

119:18

sourced 63:4

sources 69:14

86:19 111:22

112:13

sourcing 60:19

71:14

soured 61:4

south 28:1

Southern 2:12

span 100:1,20

speak 9:9,12,15

10:1 29:15 30:14

110:19

Speaking 29:19

speaks 79:9

special 123:21

specific 12:5 15:8

23:5 98:5 123:18

138:11 141:19

144:12

specifically 23:6

47:11 77:22 87:6

95:10 97:18

108:12 140:5

specification

26:9,11

specifications 39:8

69:10 142:6,14

specifics 73:8

specified 31:4

41:11

specify 89:7

speed 44:21 45:9

59:16 60:6

splash 128:1

split 41:2

spot 79:10

spreadsheet

120:14,18

stable 116:11

stack 31:17 38:13

stacked 83:16

staff 5:15

stage 145:3

stagnant 113:20

114:3

stakeholders

11:16 19:7 29:6

33:11 70:19 99:4

141:16

stand 103:10

standard 1:3 5:5

15:8,9,19,21

16:2,5,11

20:1,3,8,12,15

22:2,5 23:16

31:1,3,4 41:19

42:8,9,12,18,20

43:4,6,7,11,14,1

5,20 46:1 49:16

50:11 54:5 56:14

58:18,21 59:17

65:11 71:13

78:21 79:5 82:10

92:15 94:17

103:9 107:2

112:7,8 119:1,3

123:15 131:16

134:16,22

135:18 136:21

137:8 141:3

149:19

standards 11:13

13:19,22

14:5,13,15,18

15:1,20 17:7

18:16 21:2,4,5,9

22:1 23:10,14

31:1 32:12,14

44:2 46:3

50:15,20,22

52:13,17 54:2

56:12 59:1 65:7

72:19 79:14 80:7

100:3 109:5

113:5 114:9,22

115:18,20

120:9,10,15

121:12

122:8,12,19

123:5 125:1

129:2,21 130:8

131:14 133:2

136:6 141:21

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