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1 U.S. Department of Energy

2

3

4

5 Public Meeting on

6 Commercial Prerinse Spray Valve Framework

7 [Docket No. EERE-2014-BT-STD-0027]

8

9

10

11 9:05 to 11:29 a.m.

12 Tuesday, September 30, 2014

13

14 U.S. Department of Energy

15 Room 8E-089

16 1000 Independence Avenue, S.W.

17 Washington, D.C.

18

19

20

21

22
2

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1 ATTENDEES:

2 JOHN CYMBALSKY, Equipment and Appliance

3 Standards Program Manager

4 DOUG BROOKMAN, Facilitator for Public Solutions

5 JEFF BALDWIN, Engineering Manager,

6 T&S Brass and Bronze Works

7 STEPHANIE TANNER, Lead Engineer, Water Sense,

8 Environmental Protection Agency 

9 HOLLY CANNON, Environmental Scientist,

10 Eastern Research Group, Inc.

11 CELIA SHER, General Counsel's Office, DOE

12 JIM RABA, Appliance Standards Program, DOE

13 JENNIFER WILLIAMSON,

14 Pacific Northwest National Laboratory

15 SCOTT MORRIS,

16 Pacific Northwest National Laboratory

17 ARIS MARANTAN, Navigant Consulting

18 MYTHRI KUMAR, Navigant Consulting

19 STEPHANIE SALMON,

20 Plumbing Manufacturers International

21 DAIN HANSEN, International Association of

22 Plumbing and Mechanical Officials
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1 ATTENDEES: (continued)

2 JOANNA MAUER, Appliance Standards Awareness

3 Project

4 ED OSANN, Natural Resources Defense Council

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22
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1 C O N T E N T S

2 PAGE

3 Public Meeting Topics

4 Housekeeping Items 5

5 Rulemaking Process Overview 14

6 Authority and Definitions 19

7 Test Procedure and Test Metrics 22

8 Rulemaking Analyses 28

9 Closing Remarks 115

10

11

12

13

14

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1 P R O C E E D I N G S

2 HOUSEKEEPING ITEMS

3 MR. BROOKMAN: Good morning, everyone. 

4 Welcome. This is the Energy Conservation 

5 Standards Framework meeting for Commercial 

6 Prerinse Spray Valves. Today is September 30th, 

7 2014, here in the Forrestal Building in 

8 Washington, D.C. It's so nice to see you here 

9 this morning.

10 My name is Doug Brookman from Public 

11 Solutions in Baltimore. We're going to start 

12 this morning with welcoming remarks from John 

13 Cymbalsky.

14 AGENDA REVIEW - OPENING REMARKS

15 MR. CYMBALSKY: Thank you, Doug. My name 

16 is John Cymbalsky. I am the Program Manager for 

17 Appliance Standards, here at DOE. I'd like to 

18 welcome you all to the public meeting on prerinse 

19 spray valves.

20 Hopefully, we have a productive meeting. 

21 We have quite a bit of slides and material to go 

22 through, which we will, and please feel free to 
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1 speak up, ask questions, and hopefully, we have a 

2 healthy debate over material presented here 

3 today.

4 Thank you.

5 MR. BROOKMAN: Thank you.

6 We always start with introductions, and I 

7 will start with my immediate left. You can get 

8 used to turning these microphones on and off. 

9 The little green light illuminates there. Your 

10 name and organizational affiliation.

11 MR. BALDWIN: I am Jeff Baldwin, 

12 Engineering Manager for T&S Brass and Bronze 

13 Works. We are the original inventor and the lead 

14 manufacturer for prerinse spray valves.

15 MS. TANNER: I am Stephanie Tanner. I am 

16 the Lead Engineer for the EPA's WaterSense

17 program, which labels prerinse spray valves.

18 MS. CANNON: I'm Holly Cannon, I'm an 

19 environmental scientist with Eastern Research 

20 Group, Incorporated, and I am a contractor to the 

21 WaterSense program.

22 MR. BROOKMAN: And where are you located?
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1 MS. CANNON: I actually work from home in 

2 Blacksburg, Virginia, so my office base is in 

3 Chantilly.

4 MR. BROOKMAN: Thank you.

5 Please.

6 MS. SHER: I'm Celia Sher. I'm with 

7 General Counsel's office at DOE.

8 MR. RABA: Jim Raba, U.S. Department of 

9 Energy, Appliance Standards Program.

10 MR. BROOKMAN: Please stand up.

11 MS. WILLIAMSON: Jennifer Williamson, 

12 Pacific Northwest National Laboratory.

13 MR. MORRIS: Scott Morris, Pacific 

14 Northwest National Laboratory, or PNNL.

15 MR. MARANTAN: Aris Marantan, Navigant 

16 Consulting.

17 MS. KUMAR: Mythri Kumar, Navigant 

18 Consulting.

19 MR. BROOKMAN: So glad you could join us 

20 here this morning.

21 All of you received a packet of 

22 information as you came in today. On page 3 of 
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1 the packet is the agenda, which I am going to go 

2 through very briefly. Immediately following this 

3 agenda review, there is an opportunity for anyone 

4 that wishes to, to make opening remarks, brief 

5 summary comments about issues that matter to you. 

6 Following that, there is some housekeeping items. 

7 Immediately following that, we'll go into the 

8 rulemaking process overview, and then on to 

9 authority and definitions.

10 This agenda lists a coffee break around 

11 about 10:30 or so. That sounds sensible to me. 

12 Whenever we get to that time frame, we'll take a 

13 break. When we return from the break or whenever 

14 we get there, test procedure and test metrics, 

15 and then following on, market technology 

16 assessments, screening and analysis, from there 

17 engineering analysis.

18 Around about twelve o'clock or 12:30 or 

19 so, we will break for lunch. It's hard to say 

20 how long this material -- we'll be efficient as

21 we go along. If we get on towards twelve o'clock 

22 or 12:30 and we're getting close to the end, 
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1 we'll probably just push on through and finish 

2 out the day early, but we'll just see where we 

3 end up.

4 As reflected in the agenda, we will 

5 continue on with markups in energy and water use 

6 analysis, then life cycle costs and payback 

7 period analysis. We'll take a break 

8 midafternoon, as needed. Then shipments 

9 analysis, national impact analysis, preliminary 

10 manufacturing impact analysis, NOPR analyses, 

11 plural, and then at the end of the day, yet 

12 another opportunity for individuals, anybody that 

13 wishes to, to make final comments, any other 

14 issues that you wish to raise that haven't been 

15 handled or covered sufficiently during the course 

16 of this meeting.

17 And, of course, you will get plenty of 

18 information about how to submit written comments. 

19 The Department likes to see copious, detailed 

20 written comments on all these matters, and that 

21 is really important to them.

22 And if you look back on page 2 of your 
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1 packet, there's some simple ground rules there 

2 that I'd ask you to obviously serve. Please 

3 speak one at a time. Please say your name for 

4 the record each time you speak.

5 There will be a complete transcript of 

6 this meeting made available, and we'll describe 

7 where you can find that. If you can be concise, 

8 share the air time, keep the focus here, cell 

9 phones on silent, if you haven't turned them off 

10 already, and limit your sidebar conversations. 

11 Everyone has gotten used to using these 

12 microphones already.

13 Webinar participants, we welcome you. 

14 The Department of Energy is trying hard to make 

15 these meetings totally accessible to those via 

16 the Web. The software has been working well 

17 recently in our experience. Please keep your 

18 telephone on mute. You can raise your hand using 

19 the software program to be recognized to speak, 

20 and recently, we've been able to hear people in 

21 the room. So you ought to be able to unmute your 

22 phone, and we ought to be able to hear you in the 
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1 room. And if not, we will find a way to get your 

2 voice into this conversation. We will write down 

3 notes and read them into the record here.

4 Those of you that are joining us online, 

5 I'd also encourage you, please, the fact that you 

6 are joining us remotely doesn't mean that you 

7 should skip sending in detailed written comments. 

8 Please make sure that everyone -- the Department 

9 really benefits from all the written comments 

10 they receive in these matters.

11 So, as reflected in the agenda, I welcome 

12 now any opening remarks, any brief summary 

13 statements here at the outset about issues that 

14 are important to you.

15 We just missed you as you came in the 

16 door. Would you say your name and organizational 

17 affiliation. You can use --

18 MS. SALMON: Sure.

19 MR. BROOKMAN: Yes.

20 MS. SALMON: Stephanie Salmon. I'm with 

21 Plumbing Manufacturers International.

22 MR. BROOKMAN: Is that thing on? Say it 
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1 again.

2 MS. SALMON: Stephanie Salmon with 

3 Plumbing Manufacturers International. Good 

4 morning.

5 MR. BROOKMAN: Thank you. Good morning.

6 Does anybody wish to make an opening 

7 statement?

8 [No audible response.]

9 MR. BROOKMAN: Okay. I see none at this 

10 point.

11 So then we're going to go to some 

12 housekeeping items with Jim Raba first. 

13 Those joining us via the Web, I think I 

14 have covered all the material on Slide 7, and 

15 once again, as it says, the last bullet provided 

16 on Slide 7, all stakeholders are encouraged to 

17 submit written comments after the public meeting.

18 And now we'll turn it over to Jim Raba.

19 MR. RABA: Good morning again. I'm Jim 

20 Raba.

21 For openers, today's public meeting will

22 address the procedural and analytical framework, 
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1 models, and other analysis tools that the 

2 Department of Energy would use to evaluate 

3 efficiency standards for this equipment.

4 As you move forward today, we encourage 

5 you to consider and discuss the process and 

6 approach the Department intends to take. 

7 Throughout the rulemaking process, we encourage 

8 you and other interested parties to submit 

9 comments, pertinent information, and data.

10 Before we address the regulatory history, 

11 steps and the standards in the rulemaking 

12 process, market and technology assessment, the 

13 engineering analysis, life cycle cost analysis, 

14 national impacts, and more, we want to hear from 

15 you.

16 During today's presentations, certain 

17 issues will be prompted for discussion on slides, 

18 such as this, a comment box. Otherwise, comments 

19 about any part of the presentation are welcome 

20 throughout.

21 Please note that the comment period 

22 closes October 27th. You may submit comments by 
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1 e-mail, postal mail, courier. Please include the 

2 docket number and regulation identifier number to 

3 comments.

4 So we look forward to hearing from you 

5 today.

6 Rulemaking Process Overview

7 MR. BROOKMAN: So we're going to proceed 

8 with the content that's in the packet, and we 

9 would now be on Slide 12. We are going to hear 

10 first from Jennifer Williamson.

11 MS. WILLIAMSON: Good morning, everyone. 

12 My name is Jennifer Williamson. I am with the 

13 Pacific Northwest National Laboratory. I am 

14 going to walk us through this process overview 

15 for rulemaking and then talk about some 

16 definitions, as well as the test procedures that 

17 are relevant to commercial prerinse spray valves.

18 So, first of all, the Energy Policy and 

19 Conservation Act, or EPCA, of 1975 established 

20 the Energy Conservation Program for consumer 

21 products, and that includes commercial prerinse 

22 spray valves.
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1 EPCA directs DOE to develop new or 

2 amended standards that are designed to achieve 

3 maximum improvement in energy -- or water, in 

4 this case -- efficiency that is technologically 

5 feasible and economically justified.

6 EPCA also requires that not later than 6

7 years after the issuance of a Final Rule 

8 establishing a standard, that DOE publish either 

9 a Notice of Proposed Rulemaking for a new 

10 standard or a determination that a new standard 

11 is not required.

12 The last Final Rule for this product was 

13 actually part of EPAct 2005, and the Final Rule 

14 was in October of 2005 that just codified those 

15 requirements into the CFR. At that time, the 

16 maximum flow rate for these products was set at 

17 1.6 gallons per minute.

18 So EPCA directs DOE to consider seven 

19 separate factors for analysis when setting 

20 standards to verify that they are technologically 

21 feasible and economically justifiable. 

22 This table, the left hand shows the 
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1 factor that EPCA presents. The right-hand column 

2 is the analysis that DOE performs in order to 

3 meet that requirement. Each of these analyses 

4 will be discussed in further detail later on.

5 So this is moving into the overall 

6 process of the rulemaking. First, on top, is the 

7 Energy Conservation Standard, which has four 

8 steps, starting with the framework, preliminary 

9 analysis, NOPR, and Final Rule. A test 

10 procedure, if it's required in this case, would 

11 have a NOPR and a Final Rule. Test procedures 

12 and conservation standards do not always run 

13 concurrently; however, the Department expects 

14 that if we do a test procedure, it will run in 

15 parallel with the standards rulemaking.

16 This rule is also on a bit of an 

17 accelerated schedule, so we expect that the 

18 conservation standard rulemaking will take about 

19 2 years, and the test procedure will take about a 

20 year and a half.

21 The Web address on the bottom is just the 

22 Appliance and Commercial Standards Home Page, 
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1 which will take you to any information about both 

2 this rule, any other rules, processes that the 

3 Department uses.

4 So the framework document, which 

5 hopefully you have seen, is accompanied by a 

6 Federal Register Notice of Public Meeting. It 

7 gives the details about today's meeting, 

8 announces that the framework document is 

9 available on DOE's website, and encourages all of 

10 you to submit your comments.

11 The framework itself was posted on 

12 September 8th at this website. The accompanying 

13 NOPM was published on September 11th.

14 The preliminary analysis is the first 

15 step where we actually have some data to share 

16 with you. It again has a NOPM with it that 

17 provides the notice of the public meeting with 

18 its details and the availability of the 

19 preliminary analysis, technical support document, 

20 or TSD. We will also be addressing any comments 

21 that we receive from all of you today.

22 The analyses listed on the bottom are the 
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1 analyses that will be included in the preliminary 

2 analysis, TSD. As we move through the process 

3 into the NOPR and the Final Rule, these analyses 

4 will be updated, and additional analyses will be 

5 performed.

6 So the NOPR phase again, Federal Register 

7 publication, public meeting, a revised TSD with 

8 everything that was in the preliminary analysis, 

9 as well as these additional analyses that will 

10 appear for the first time in the NOPR as well as 

11 what everybody here probably really cares about, 

12 which is the standard that DOE is proposing to 

13 set for these products.

14 Then the Final Rule, that Federal 

15 Register publication announces the availability 

16 of the final TSD. It addresses any comments we 

17 received in response to the proposed standard. 

18 It presents the standard level that DOE is 

19 adopting, along with the compliance date for 

20 those standards.

21 This is just an overview of each of those 

22 steps on a timeline with the dates that the 
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1 Department expects each of these pieces of 

2 information will be published.

3 Authority and Definitions

4 MS. WILLIAMSON: Authority and 

5 Definitions.

6 Authority and background. Title III of 

7 the Energy Policy and Conservation Act set forth 

8 a variety of a provisions designed to improve 

9 energy efficiency -- in this case, water 

10 efficiency -- of various products and equipment.

11 Part B of Title III provides for the 

12 Energy Conservation Program for Consumer Products 

13 Other than Automobiles.

14 The Energy Policy Act of 2005, or EPAct 

15 '05, amended Section 325 of EPCA, which now 

16 states that commercial prerinse spray valves 

17 manufactured on or after January 1, 2006, shall 

18 not have a flow rate of more than 1.6 gallons per 

19 minute.

20 Scope of coverage. The current 

21 definition contained in EPCA of a commercial 

22 prerinse spray valve is, "A handheld device 
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1 designed and marketed for use with commercial 

2 dishwashing and ware-washing equipment that 

3 sprays water on dishes, flatware, and other food 

4 service items for the purpose of removing food 

5 residue before cleaning the items."

6 DOE is considering modifications to this 

7 definition if they are necessary to clarify the 

8 scope of coverage.

9 So before we start talking about what we 

10 might do to modify the definition, this language 

11 is also included in EPCA, which provides the 

12 authority, the limited authority that we have to 

13 change the definition.

14 So, in general, we can include products 

15 that are extensively used in conjunction with 

16 commercial dishwashing and ware-washing 

17 equipment. We can change it if the standards 

18 applied to those products would result in 

19 significant energy savings, or if the application 

20 of standards meets the criteria specified in 

21 6295(o)(4), which basically states that new 

22 standards cannot be prescribed if they will 
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1 remove products from the market that were 

2 previously available.

3 Excluded products are those that are used 

4 for specialty food service applications, those 

5 that are unlikely to be used in conjunction with 

6 commercial dishwashing and ware-washing 

7 equipment, and products that when the standards 

8 are applied to them would not result in 

9 significant energy savings.

10 So, at this point, DOE requests comment 

11 on modifications to the definition that may 

12 clarify what equipment is covered.

13 What we are looking for here is if anyone 

14 has some specific examples of equipment that they 

15 know is used in commercial kitchens that may not 

16 fit into the definition that we have here.

17 MR. BROOKMAN: This is really quite 

18 fundamental. If you can see ways to improve the 

19 definition or make the definition more consistent 

20 with scope in the actual application, then that 

21 would be good.

22 [No audible response.]
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1 MR. BROOKMAN: Okay. I see none at this 

2 time.

3 Test Procedure and Test Metrics

4 MR. WILLIAMSON: All right. So we'll 

5 move on to the metric. 

6 As part of this rulemaking, DOE may 

7 consider adopting an alternative metric to the 

8 current flow rate (gpm) metric. DOE will 

9 consider alternatives that achieve energy and 

10 water savings and preserve equipment utility.

11 Two possible metrics that could be 

12 considered are a performance metric that accounts 

13 for both flow rate and spray force or a metric 

14 that directly correlates water use to the time 

15 taken to clean a dish measured in gallons per 

16 dish. So, at this point, DOE requests comment on 

17 potential metrics other than flow rate that may 

18 be used to achieve greater water savings in 

19 commercial prerinse spray valves, and if there is 

20 sufficient benefit to using an alternative metric 

21 to justify changing from the current flow rate 

22 metric of gpm.
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1 MR. BROOKMAN: Please. Ed Osann.

2 MR. OSANN: Yeah. Hi.

3 This is a comment in the form of a 

4 question, and that is, would the revision to the 

5 metric require a change in the test procedure, or 

6 could either of these possible metrics be 

7 accounted for under the current test procedure?

8 MS. WILLIAMSON: So we're going to get 

9 there next. We're going to talk about the test 

10 procedure next.

11 MR. OSANN: Okay.

12 MS. WILLIAMSON: And at that time, we 

13 will invite comment on whether or not the test 

14 procedure is needed to support a potential new 

15 metric.

16 MR. BROOKMAN: Stephanie.

17 MS. TANNER: Can I just go back a little 

18 bit?

19 MR. BROOKMAN: Yes.

20 MS. TANNER: You mentioned that this 

21 process was on an accelerated timeline, and I 

22 guess I wondered why or what was driving it to be 
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1 on an accelerated timeline versus the standard 

2 timeline.

3 MR. CYMBALSKY: This is John Cymbalsky 

4 from DOE.

5 So the general timeline for standards is 

6 roughly 3 years, give or take. Some go faster. 

7 Some actually go slower. This one, in our minds, 

8 we think, it's a candidate to go faster. We're 

9 going to do the best we can to finish in 2 years, 

10 but obviously, this process has its obstacles, 

11 shall we say, from time to time. So this is the 

12 schedule that we've created. We're going to try 

13 to stick to it.

14 MS. TANNER: Okay.

15 MR. BROOKMAN: The question there in item 

16 1-2 is about metrics and alternatives to the 

17 current metrics or additions, enhancements. Any 

18 thoughts on that?

19 [No audible response.]

20 MR. BROOKMAN: Okay, nothing at this 

21 time.

22 MS. WILLIAMSON: So moving on to the test 
25

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1 procedure. Currently, EPCA specifies that the 

2 test procedure for measuring flow rate in gpm for 

3 commercial prerinse spray vales shall be based on 

4 ASTM Standard F2324, "Standard Test Method for 

5 Prerinse Spray Valves."

6 In October of 2013, DOE published a final 

7 rule that incorporated by reference the test 

8 procedure specified in ASTM Standard F2324, the 

9 2003 version, reaffirmed in 2009. So there were 

10 no technical changes. It was just to update to 

11 the most current version of the ASTM standard.

12 Although the ASTM Standard includes a 

13 test for qualitative cleanability, that was not 

14 incorporated by reference into DOE's test 

15 procedure. We are only using it to measure flow 

16 rate.

17 Since that publication of DOE's 2013 test 

18 procedure, ASTM has issued a new standard, the 

19 2013 version of F2324, to reflect some changes in 

20 the industry. The primary change to the ASTM 

21 test procedure was to replace the cleanability 

22 test, which was removed to an appendix, with a 
26

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1 spray force test.

2 The cleanability test, just a little 

3 overview, evaluates the cleaning time of a 

4 standard dinner plate measured in seconds per 

5 plate. The spray force test, which is new, 

6 measures the amount of force exerted by the flow 

7 of water measured in ounces of force, and while 

8 these changes don't impact the energy or water 

9 use measurement of the DOE test procedure, they 

10 could be used as a way to establish equipment 

11 classes.

12 So, at this time, DOE requests comment on 

13 the potential use of ASTM F2324, the 2013 

14 version, as the method of test for measuring 

15 water consumption.

16 MR. BROOKMAN: One of the individuals 

17 joining us online, Joanna Mauer, requests to make 

18 a comment or ask a question.

19 Joanna, unmute your phone, and hopefully, 

20 we'll hear you in the room.

21 MS. MAUER: Thanks.

22 You mentioned that one potential 
27

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1 alternative metric would account for both flow 

2 rate and spray force. I was just wondering if 

3 you could provide any more detail about what that 

4 metric might look like.

5 MS. WILLIAMSON: I'm going to defer to my 

6 colleagues that are looking into the metric 

7 further.

8 MR. BROOKMAN: Yes. Aris Marantan.

9 MR. MARANTAN: Yes. This is Aris 

10 Marantan, Navigant Consulting.

11 We have been investigating possible other 

12 metrics, including spray force, and one of them 

13 that we have considered is gpm divided by spray 

14 force. So while that's slightly different than 

15 the normal gpm, we do have to consider keeping 

16 the 1.6 gpm standard in mind, so as to not 

17 backslide. So we have to make sure to abide by 

18 the backsliding provision, so that's one that 

19 we've --

20 MS. MAUER: Thank you.

21 MR. MARANTAN: -- considered.

22 MR. BROOKMAN: Okay. Thank you, Joanna.
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1 You see the comment box there, 1.3, 

2 related to test procedure updates. Any 

3 additional comments emerging from this request?

4 [No audible response.]

5 MR. BROOKMAN: Okay.

6 MS. WILLIAMSON: All right. I am going 

7 to turn it over to Mythri.

8 Rulemaking Analyses

9 MS. KUMAR: Thank you, Jennifer.

10 Good morning. My name is Mythri Kumar, 

11 and I work for Navigant Consulting, and today I 

12 will be presenting the market and technology 

13 assessment, screening analysis, engineering 

14 analysis, and the preliminary manufacturer impact 

15 analyses.

16 So the first analysis that we undertake 

17 for the preliminary rulemaking analysis is the 

18 market and technology assessment.

19 The purpose of the market and technology 

20 assessment is to characterize the commercial 

21 prerinse spray valve market and the technologies 

22 that improve efficiency.
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1 So, to do this, DOE looks into commercial 

2 prerinse spray valve manufacturers, trade 

3 associations, retailers, and then also estimates

4 shipments and market trends. DOE then uses this 

5 information to determine equipment classes and 

6 technology options that could improve the 

7 efficiency of commercial prerinse spry valves.

8 For this rulemaking, improving efficiency 

9 would mean a reduction of water consumption or 

10 water use.

11 So based on the initial research, DOE has 

12 identified two main trade groups. The first is 

13 Plumbing Manufacturers International, PMI, is a 

14 primary trade organization that supports and has 

15 an interest in commercial prerinse spray valves.

16 The second is North American Association 

17 of Food Equipment Manufacturers. It is a trade 

18 association of over 500 food service equipment 

19 manufacturers and is another organization that 

20 may be interested in commercial prerinse spray 

21 valves.

22 In terms of the retailers, DOE has 
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1 identified three main categories. The first is 

2 brick and mortar retailers, which include mass 

3 market retailers, specialty stores, club or 

4 warehouse stores, Internet sellers, and the third 

5 is showrooms.

6 So, at this point, DOE requests comment 

7 on item 3.3. DOE seeks information regarding any

8 other trade organizations that represent the 

9 commercial prerinse spray valve industry.

10 MR. BROOKMAN: Is that the list?

11 [Laughter.]

12 MR. BALDWIN: This is Jeff Baldwin, T&S 

13 Brass.

14 You may want to look at NRA. National 

15 Restaurant Association would have interest in 

16 this rulemaking process, as well.

17 MR. BROOKMAN: Thank you, Jeff.

18 MS. KUMAR: Thank you.

19 MR. BROOKMAN: Yes. And your name, 

20 please?

21 MR. HANSEN: Dain Hansen.

22 Are you looking just for organizations 
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1 that represent like trade associations or any 

2 organization that has an interest in this.

3 MS. KUMAR: Both.

4 MR. HANSEN: Both?

5 MS. KUMAR: Yes.

6 MR. HANSEN: I mean, there is a long list 

7 of industries in the plumbing industry that would 

8 be interested. I mean ourselves --

9 MS. KUMAR: Okay.

10 MR. HANSEN: -- the International 

11 Association of Plumbing and Mechanical Officials, 

12 we test and certify the products to make sure 

13 they meet the mandated levels, and then there's a 

14 long list of certification bodies and also -- I 

15 mean, you're looking at a lot of the 

16 environmental groups, as well, that have an 

17 interest there.

18 MS. KUMAR: Sure.

19 MR. HANSEN: We will put a longer list in 

20 our comments we write, but I wasn't sure what 

21 that was looking at, if it's just trade 

22 organizations or true -- any interested 
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1 organization in the industry.

2 MS. KUMAR: Thank you so much.

3 MR. BROOKMAN: Thanks, Dain.

4 Additional comments?

5 [No audible response.]

6 MR. BROOKMAN: Okay.

7 MS. KUMAR: So, at this point, DOE has 

8 identified 49 basic models of commercial prerinse 

9 spray valves available in the market. These 

10 basic models were found using the DOE Compliance 

11 Certification Management System -- CCMS --

12 database, the EPA WaterSense product database, 

13 manufacturer websites, and Web searches.

14 So this graphic in this slide provides 

15 the estimated percentages of basic models by 

16 manufacturers in the U.S. market currently.

17 Doug, I would like to pause here to just 

18 ask a question, the inputs in this graphic, do 

19 they make sense? Keep in mind, we are only 

20 looking at basic models here, not all models that 

21 are available in the market. And are there any 

22 manufacturers that we have missed out?
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1 MR. BROOKMAN: Jeff.

2 MR. BALDWIN: Jeff Baldwin, T&S Brass.

3 Is this supposed to represent potential 

4 market share or strictly basic model numbers? 

5 There is a drastic difference in how these 

6 manufacturers would list their basic models. I 

7 would hate for this pie chart to be turned into 

8 an assumption of market share, which is 

9 drastically different than this pie chart shows.

10 MS. KUMAR: Yes. This is just basic 

11 models. This is not necessarily talking about 

12 market share. We would like to get that 

13 information also, but this is just based on 

14 information that we found on the CCMS database 

15 and the WaterSense product database and Web 

16 searches.

17 So if you do have more information on 

18 market shares, we would appreciate you providing 

19 us either written comments or in general comments 

20 about it.

21 MR. BROOKMAN: However, for today's 

22 purposes, we would appreciate any additional 
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1 comments on manufacturers who are missing from 

2 this list.

3 [No audible response.]

4 MR. BROOKMAN: Nothing additional at this 

5 time. Of course, you can submit that in your 

6 written comments, as well.

7 Okay.

8 MS. KUMAR: Thank you.

9 MR. OSANN: I have a question.

10 MR. BROOKMAN: Ed Osann.

11 MR. OSANN: Yeah. Is this intended to 

12 encompass imported products, as well?

13 MS. KUMAR: This is just U.S.-based 

14 manufacturers.

15 MS. TANNER: This is Stephanie Salmon 

16 with Plumbing Manufacturers.

17 Are you going to be looking at the import 

18 side, as well, or doing any research on that with 

19 --

20 MS. KUMAR: I believe we're not looking 

21 at imports. We're just using the U.S. market, 

22 but I can defer to one of my colleagues here.
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1 MR. BROOKMAN: Aris.

2 MR. MARANTAN: This is Aris Marantan.

3 Yeah. I think we would like that 

4 information, as well. Any information that you 

5 have on domestic manufacturers or foreign 

6 manufacturers, we will consider that in the 

7 analysis.

8 MR. BROOKMAN: Foreign manufacturers that 

9 import product into the U.S.?

10 MR. MARANTAN: Into the U.S., yes.

11 MR. BROOKMAN: Yes.

12 MR. BALDWIN: What we have seen is a 

13 general lack of enforcement of this requirement 

14 to file with the DOE or the FTC on an annual 

15 reporting basis. So what you see here on this 

16 list are manufacturers who do that due diligence 

17 and do report to the CCMS. What you don't see is 

18 the imported products that we compete against 

19 every day that are either inferior quality, 

20 inferior performance, and do not follow the 

21 federal regulations reporting to the CCMS. So 

22 we'll make sure this is fair to all participants, 
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1 and there is a chunk of import products that 

2 should be addressed during this process.

3 MR. BROOKMAN: Thank you, Jeff. That was 

4 Jeff speaking, and, Jeff, that provides an 

5 incentive for both you and your colleagues to 

6 provide a detailed listing of that to the 

7 Department of Energy.

8 Okay.

9 MS. KUMAR: Thank you.

10 MR. BROOKMAN: Additional comments here 

11 before we move on?

12 [No audible response.]

13 MR. BROOKMAN: Okay.

14 MS. KUMAR: Okay. One of the main results 

15 of the market and technology assessment is the 

16 establishment of equipment classes, each of which 

17 is subject to its own standard. As directed by 

18 EPCA, DOE establishes different equipment classes 

19 based on three main criteria. The first is the 

20 type of energy used; the second, the capacity of 

21 the product, and the third, any other 

22 performance-related features that require 
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1 different standard levels, such as features 

2 affecting customer utility.

3 Currently, all commercial prerinse spray 

4 valves are included in a single equipment class, 

5 subject to a maximum flow of 1.6 gpm. So for 

6 this rulemaking, DOE will examine whether any of 

7 the following characteristics could be used to 

8 establish equipment classes.

9 The first is flow rate in terms of gpm; 

10 second, spray force in terms of ounce-force. The 

11 third is cleanability time in terms of seconds 

12 per plate. The fourth is design of flow control 

13 insert, and the fifth is other equipment features 

14 that change functionality; for example, spray 

15 patterns.

16 At this point, we are keeping flow rate 

17 and design of flow control insert in the list of 

18 equipment classes in case we change the metric to 

19 something other than flow rate.

20 So the possibilities listed here for 

21 equipment classes could also be used as 

22 technology options to improve efficiency and vice 
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1 versa. So the preliminary analysis will actually 

2 analyze this and determine whether these 

3 possibilities are better suited as equipment 

4 classes or technology options.

5 So at this point, DOE has several items 

6 for comment. Item 3-8, DOE requests input from 

7 interested parties about the design 

8 characteristics and criteria that are being 

9 considered to create equipment classes. In 

10 particular, do other performance-related features 

11 warrant separate standard levels?

12 Item 3-9, DOE seeks comment on whether 

13 spray force or cleanability are useful 

14 characteristics that could define the equipment 

15 classes of a prerinse spray valve.

16 Item 3-10, DOE requests comment on how 

17 ultra-low flow spray valves differ from other 

18 spray valves in usage, functionality, features, 

19 and cleaning ability.

20 MR. BROOKMAN: Ed Osann.

21 MR. OSANN: Ed Osann with NRDC.

22 It would seem that if the metric does not 
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1 change, then holding out flow rate as a potential 

2 differentiator for equipment classes would seem 

3 to be kind of -- almost kind of an oxymoron, 

4 right? Kind of inconsistent with that approach.

5 MS. KUMAR: Sure. Yeah, that makes 

6 sense.

7 MR. BROOKMAN: You can see those three 

8 requests for comment there. Please take a peek.

9 In particular, I am looking at 3-10, 

10 ultra-low flow spray valves, how they differ from 

11 other spray valves and usage functionality 

12 features and cleaning ability. That strikes me 

13 as sort of an inside-baseball comment that we 

14 might get here.

15 Jeff.

16 MR. BALDWIN: We will offer further 

17 comments on this, but you should recognize there 

18 are a lot of different applications in the food 

19 service industry and not all of them require the 

20 amount of spray force that we have on other 

21 products.

22 Only speaking for T&S here, we offer a 
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1 myriad of prerinse spray valves that fall under 

2 the current 1.6 gpm definition, but there is a 

3 vast array of applications and options and 

4 different design features based upon the end 

5 user's application. So we actually work with our 

6 clients, our customers, to determine those 

7 applications to recommend product, instead of a 

8 one-size-fits-all mentality.

9 MR. BROOKMAN: Thank you.

10 Yes.

11 MR. MORRIS: This is Scott Morris at 

12 PNNL.

13 Jeff, I know you are going to offer more 

14 comments, written comments. Could you give us an 

15 example of a couple applications at this time, 

16 just a few?

17 MR. BALDWIN: Variations of applications 

18 could range from rinse and off-baked product. 

19 Let's say you're in an Italian restaurant and you 

20 had baked tomato paste. That's really one of the 

21 creations of the original ASTM F2324-2003 test 

22 protocol, was based on kind of that rugged, 
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1 heavy-duty, more -- you know, needing more of a 

2 cleaning force, cleaning from the current spray 

3 valve. That's one end of the spectrum.

4 The other end of the spectrum could be 

5 they are merely rinsing off something that's 

6 already basically clean, but they're just doing a 

7 light rinse, and it could be a dry good or it 

8 could be just a tray that a fast food restaurant 

9 would use. That's not really dirty. You're 

10 washing off maybe some stray ketchup or some salt 

11 or pepper that somebody had on that tray.

12 So you have to be very careful and not 

13 narrow it down to one type product, because you 

14 may not want that amount of spray force if you 

15 are washing something like a fast food tray, and 

16 so that's just two quick examples, and there's 

17 thousands in between there.

18 MR. MORRIS: Thank you very much.

19 MR. BROOKMAN: Additional comments on 

20 these three items?

21 [No audible response.]

22 MR. BROOKMAN: Okay.
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1 MS. KUMAR: So, next, we go to technology 

2 options. As mentioned previously, technology 

3 options are used to improve the efficiency of the 

4 product, which for commercial prerinse spray 

5 valves would be technology options that reduce 

6 water consumption or water use.

7 At this time, DOE is considering the 

8 following technology options to improve 

9 efficiency.

10 The first is the addition of a flow 

11 control insert. The second is a smaller nozzle 

12 tip opening. The third is incorporation of 

13 additional components; for example, backflow 

14 preventers or additional valves or hoses. And 

15 fourth is specially designed spray patterns; for 

16 example, cone, solid stream, triple solid stream, 

17 flat fan, and shower, and the next slide actually 

18 provides more details on these different spray 

19 patterns.

20 The cone spray pattern is what we 

21 describe as a nozzle with a hollow or solid cone 

22 spray with a variety of cone angles. We've also 
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1 known it is called a "fan spray pattern," and you 

2 can see the images on this slide.

3 The solid stream spray pattern is a 

4 nozzle with a single solid jet stream.

5 The triple solid stream is a nozzle with 

6 three spray holes, each with solid jet streams, 

7 also called "triple action" or "tri-tip."

8 The flat fan is a nozzle producing flat 

9 fan jet streams at various angles, also called as 

10 a "knife-like pattern."

11 And the shower is a spray face with 

12 multiple spray holes, resembling a common 

13 showerhead, and it's also called a "rose spray 

14 pattern."

15 So, at this time, DOE seeks comment on an 

16 item, item 3-12. DOE seeks information on what 

17 technology options are available to improve the 

18 performance of commercial prerinse spray valves.

19 MR. BROOKMAN: Jeff.

20 MR. BALDWIN: I'm the only manufacturer 

21 in the room, so you're going to hear from me a 

22 lot, I feel like.
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1 I'd caution to make sure we don't try to 

2 put too many design restrictions on the products, 

3 because I have mentioned the myriad of 

4 applications we have to deal with. Depending on 

5 the application, any one of these technologies 

6 could be what was required for that application, 

7 or it could be another technology that may not 

8 even be developed yet or could be in process of 

9 being developed.

10 So I would hate for this rulemaking 

11 process to turn into a design-restrictive 

12 performance requirement that says you can only 

13 have spray valves with these following two design 

14 characteristics. I would make sure we were not 

15 limiting ourself, because we will stifle 

16 innovation if we do find ourselves in that corner 

17 of only having certain types of products.

18 MR. BROOKMAN: Okay, thank you.

19 Are there, nevertheless, technology 

20 options not listed that the Department should 

21 consider?

22 MR. BALDWIN: You're reaching into a 
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1 realm of proprietary information at that point, 

2 and so --

3 MR. BROOKMAN: Okay. Well, we understand 

4 that. Okay, got it.

5 Additional thoughts, comments here?

6 Yes, Aris.

7 MR. MARANTAN: This is Aris Marantan.

8 Just a follow-up question. Thank you, 

9 Jeff, for providing that information. Is there 

10 anything on the list on Slide 35 that you 

11 wouldn't consider as an option that would improve 

12 water consumption?

13 MR. BALDWIN: The bullet point that says 

14 "incorporation of additional components," I'm 

15 curious, kind of the origin of that bullet point 

16 and how those products shown as example there 

17 would have any effect on conservation of water 

18 energy.

19 These types of products get mixed with a 

20 myriad of other products, just in the normal 

21 realm of the application, whether it's a spray 

22 valve on a prerinse unit or other types of myriad 
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1 of applications there. So I'm not sure how that 

2 bullet point would lead to improved efficiency.

3 MR. BROOKMAN: Thank you.

4 MS. KUMAR: Thanks.

5 MR. MARANTAN: Thank you.

6 MS. KUMAR: Okay. So the next analysis 

7 that we will be looking at is the screening 

8 analysis.

9 MR. OSANN: Before we leave this point --

10 MR. BROOKMAN: Ed Osann.

11 MR. OSANN: This is Ed Osann, NRDC.

12 Presumably, these examples of spray 

13 patterns and their associated nozzles are 

14 nonproprietary or available for multiple --

15 MS. KUMAR: Correct.

16 MR. OSANN: -- sources, and the 

17 information that you are seeking would be for 

18 other non-proprietary options; is that right?

19 MS. KUMAR: Right. Mm-hmm.

20 MR. OSANN: Okay.

21 MS. KUMAR: Sure. Okay.

22 So the purpose of the screening analysis 
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1 is to screen out the technology options that DOE 

2 will not consider in the engineering analysis for 

3 commercial prerinse spray valves.

4 DOE will screen out technology options 

5 based on four main criteria. The first is 

6 technological feasibility, which means whether 

7 it's incorporated in commercially available 

8 products or in working prototypes. The second is 

9 practicability to manufacture, install, and 

10 service, where it should be possible to achieve 

11 mass production and reliable installation and 

12 servicing. The third is adverse impacts on 

13 product utility or availability to customers, and 

14 the fourth is adverse impact on health and 

15 safety.

16 The technology options that are not 

17 screened out in the screening analysis will be 

18 adopted as design options in the engineering 

19 analysis.

20 The next analysis that we will be looking 

21 at is the engineering analysis.

22 The purpose of the engineering analysis 
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1 is to determine the relationship between cost and 

2 efficiency. For our analysis, efficiency would 

3 be water use or water consumption. Typically, 

4 what we see in a rulemaking is that as the 

5 efficiency improves or water use decreases, the 

6 cost of producing the product increases, as shown 

7 on the figure in this slide.

8 The results from the engineering analysis 

9 are then later used as a basis for the life-cycle 

10 cost, payback period, and national impact 

11 analyses, which will be discussed further on in 

12 this presentation.

13 So this slide gives more detail on the 

14 steps needed to conduct the engineering analysis 

15 for commercial prerinse spray valves.

16 First, we choose representative equipment 

17 classes and sizes. Since we don't expect there 

18 to be an overwhelming amount of equipment classes 

19 for this rulemaking, we expect to be analyzing 

20 all equipment classes.

21 The second, we select the baseline 

22 efficiency level. Since there is a current 
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1 standard for commercial prerinse spray valves, 

2 the baseline efficiency level would be that 

3 standard which is 1.6 gpm.

4 The third is to identify higher 

5 efficiency units. For all equipment classes, DOE 

6 identifies efficiency and cost of more efficient 

7 units based on a combination of design option 

8 modeling, product testing, and teardowns. DOE 

9 then identifies the maximum technologically 

10 feasible level, or what we call the "max-tech," 

11 for each equipment class. This provides the 

12 upper bound for the efficiency.

13 Fourth, we develop efficiency levels for 

14 the analyses. The efficiency levels are 

15 developed, so that they range from the baseline 

16 all the way to the max-tech for all equipment 

17 classes. The levels are determined by 

18 implementing the screened-in design options to 

19 improve spray valve efficiency from baseline to 

20 max-tech.

21 And then fifth, we determine the 

22 cost-efficiency relationship. The end result for 
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1 the engineering analysis is a set of 

2 cost-efficiency curves for all equipment classes, 

3 and this takes the form of manufacturer's selling 

4 price versus efficiency.

5 The baseline models are selected based on 

6 common features and minimally compliant equipment 

7 efficiency. Since there is a current standard 

8 for commercial prerinse spray valves, the 

9 baseline efficiency would be the current 

10 standard, which is 1.6 gpm at 60 psi. However, 

11 as mentioned previously, DOE is considering an 

12 alternative efficiency metric other than gpm. If 

13 another efficiency metric is chosen, the baseline 

14 efficiency with this new metric should 

15 incorporate the current standard of 1.6 gpm, so 

16 as to prevent backsliding.

17 At this point, DOE seeks an item for 

18 comment. DOE seeks information regarding the 

19 specific technological characteristics of 

20 baseline models.

21 [Pause.]

22 MR. BROOKMAN: No comment here. Okay, 
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1 okay.

2 MS. KUMAR: As described previously, DOE 

3 will identify the highest efficiency model in the 

4 market, which is the max-tech for each class. 

5 Based on initial research, DOE has identified the 

6 current max-tech as a commercial prerinse spray 

7 valve with a max flow of 0.64 gpm.

8 At this point, I would want to ask a 

9 question whether there are any other commercial 

10 prerinse spray valves that have an even lower 

11 water consumption rate than the identified 

12 max-tech.

13 MR. BROOKMAN: Jeff.

14 MR. BALDWIN: I would caution in picking 

15 the highest efficiency model based on flow rate 

16 only. There are inferior products on the market 

17 that have an extremely low flow rate but have an 

18 unsatisfactory user rating, and we have learned 

19 that quite frequently through the WaterSense 

20 effort that we went through with the EPA and ERG, 

21 sitting to my left. Be careful to not grab onto 

22 flow rate when you're trying to talk about 
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1 max-tech only.

2 MS. KUMAR: I have a follow-up question. 

3 So what other characteristics would you consider 

4 for a max-tech model?

5 MR. BALDWIN: You really need to look at 

6 the application, but, I mean, forced-spray force 

7 is always one thing that we look at. But you've 

8 got to look at the application.

9 What you're defining as max-tech, if you 

10 say it's the lowest flow rate on the market, it 

11 may work for certain applications, but it may 

12 work very poorly for the baseline or what you 

13 would call a "standard market application."

14 MS. KUMAR: Okay, thank you.

15 MR. BROOKMAN: Scott.

16 MR. MORRIS: This is Scott Morris from 

17 PNNL.

18 Jeff, you had mentioned earlier about --

19 we talked briefly about the applications, and I'm 

20 not trying to put you on the spot here and ask 

21 you to talk about it here, but it would be very 

22 useful if in your written comments, you could 
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1 provide information such as perhaps what flow 

2 rates, for example, are typical in which 

3 application that the product is used in, if it's 

4 possible to provide that type of information. I 

5 realize there's lots of gray areas, but that 

6 would be very helpful.

7 MR. BALDWIN: That's a huge gray area, 

8 and it's also a lot of proprietary research 

9 that's been taking place with our customers over 

10 65 years of making spray valves. It's not 

11 something that T&S as a family-owned company 

12 would put into comments, unfortunately.

13 We may offer some of that information 

14 through our NDA that we are working on with 

15 Navigant, but we would not offer that in our 

16 public comments.

17 MR. MORRIS: Thank you.

18 MR. BROOKMAN: I was wondering if there 

19 was kind of a nomenclature that has emerged among 

20 the -- as you say, the myriad of applications, if 

21 it breaks down into 10 or 12 or 20 classes or 

22 something like that.
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1 MR. BALDWIN: Right now, you really have 

2 basically what we would consider as four classes 

3 out there. You have what we call "high flow," 

4 which is greater than 1.6, but it's not for 

5 prerinse. It may look like a prerinse spray 

6 valve, but the flow rate is greater than 1.6. It 

7 may be for a myriad of applications, including 

8 wash-down of walls or floors or a trash bin 

9 receptacle, but it looks like a prerinse spray 

10 valve, so a lot of people call them "high-flow 

11 prerinse spray valves." They are not really for 

12 prerinsing. That is one class.

13 And there's a lot of confusion in the 

14 marketplace. I know we spend a lot of time with 

15 the DOE on some of the interpretations or 

16 clarifications there with legal counsel on the 

17 DOE side. Take that for what it's worth.

18 [Laughter.]

19 MR. BALDWIN: The next class would be 

20 what we call EPAct 2005, which would be your 1.6. 

21 That is where we are at today. That is our 

22 federal regulation today.
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1 Then we have the voluntary measure that 

2 was just released here in recent months and has 

3 been growing a little bit of steam. It is 

4 WaterSense, which is 1.28 gpm.

5 And then we have what we would call 

6 "ultra-low flow," which where that number is, 

7 it's kind of up to debate on which manufacturer 

8 or which program that you're dealing with. 

9 Usually, it's about a 50 percent reduction, so it 

10 would be like at a 0.8 level. That's not a fixed 

11 number, but that's where we would start talking 

12 about ultra-low flow.

13 And that terminology is the market 

14 terminology. As a manufacturer, we hate to hear 

15 ultra-low flow, because in the market, people 

16 think that means ultra-low performance, and so we 

17 have to be very careful when we talk about high 

18 efficiency or low efficiency or low flow or high 

19 flow, make sure those terminologies don't give a 

20 misnomer into the marketplace.

21 MR. BROOKMAN: Okay. Thanks a lot. That 

22 was helpful.
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1 Additional comments here?

2 [No audible response.]

3 MR. BROOKMAN: Okay.

4 MS. KUMAR: Thank you.

5 So then DOE will analyze the costs 

6 associated with implementing the screened-in 

7 design options to improve spray valve efficiency 

8 from baseline efficiency to max-tech.

9 Currently, the design options that DOE is 

10 tentatively considering include the addition of a 

11 flow control insert, smaller nozzle tip openings, 

12 incorporation of additional components, and 

13 specially designed spray patterns, which are the 

14 technology options that I previously described.

15 The design options currently being 

16 considered could have characteristics to warrant 

17 them as equipment classes and vice versa, and 

18 that will be analyzed in the preliminary 

19 analysis. However, they will be used in one or 

20 the other, either as a design option or an 

21 equipment class, and not in both.

22 The final result of the engineering 
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1 analysis is a cost-efficiency relationship. To 

2 determine the costs for this relationship, DOE 

3 will develop a cost model that converts the bill 

4 of materials for both baseline and higher 

5 efficiency units into manufacturer production 

6 costs.

7 The component cost for the design options 

8 are determined using a combination of reverse 

9 engineering, which are product teardowns, and 

10 manufacturer feedback, which would be through 

11 engineering interviews.

12 So, at this point, I would like to step 

13 back and mention the engineering interviews. 

14 This is actually the next step in the rulemaking 

15 for us, and we have already started reaching out 

16 to some manufacturers to conduct these 

17 confidential engineering interviews. But just to 

18 give an overview, the engineering interviews are 

19 generally one day, where the first half of the 

20 day, we have an interview guide that we provide 

21 to the manufacturers, and there are questions 

22 related there to the engineering analysis. Then 
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1 the second half of the day, we look to try and 

2 visit the production facilities, if they are in 

3 the U.S., so that we get an idea of the 

4 production of the commercial prerinse spray 

5 valves.

6 Note that we also sign nondisclosure 

7 agreements before the whole process, so all the 

8 information will not be disclosed in the 

9 engineering analysis, except they will be 

10 aggregated. So they are masked when we use them 

11 -- we use the information provided during these 

12 engineering interviews in the engineering 

13 analysis.

14 Any participation would be helpful, and I 

15 guess, hopefully, we will work with you guys to 

16 conduct these confidential engineering 

17 interviews.

18 MR. BALDWIN: Question there. This 

19 marketplace for this product is small when you 

20 look at the number of manufacturers, and then 

21 when you look at the market share analysis, once 

22 you gather that information, you will see that 
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1 there is a small, small number of manufacturers 

2 that actually control the majority of this 

3 market, because it is a niche product.

4 When you say this information is going to 

5 be aggregated, if there's only two or three 

6 manufacturers in this market that have the bulk 

7 of the share and most of them are family-owned 

8 smaller companies that don't report this stuff as 

9 part of a public company, how do you mask that 

10 data where we just don't take the sum and deduct 

11 our numbers and see the numbers of our top 

12 competitor in this marketplace? How is that 

13 protected as we start to share this information 

14 through our NDA?

15 MS. KUMAR: I could defer this to Aris.

16 MR. MARANTAN: Yes, that's a very good 

17 question. This is Aris Marantan from Navigant.

18 We are very cognizant of that situation, 

19 so we won't be disclosing anything whenever there 

20 is only two parties involved.

21 MR. BROOKMAN: Or even three.

22 MR. MARANTAN: We're very careful with 
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1 three, as well. 

2 We just pay attention to the data, and if 

3 there's any way to reveal the information, we'll 

4 just avoid it, so we won't be disclosing that.

5 What we can do is take the information 

6 that you are willing to provide and bring it back 

7 home with us to our home offices and see who was 

8 willing to provide information and just be very 

9 cautious with that data.

10 MR. BALDWIN: At the end of the day, who 

11 makes that decision whether or not to share that 

12 data that's been aggregated among, whether it's 

13 two, three, or four manufacturers? Where does 

14 that final decision rest, and what -- I know we 

15 have the NDA, and it's a pretty basic NDA, I 

16 should say. Where is the protection fallback to 

17 the manufacturers sharing this data?

18 MR. MARANTAN: It goes back to the NDA 

19 that we --

20 MR. BALDWIN: The NDA doesn't guarantee 

21 that this information won't be aggregated and 

22 shared.
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1 MR. MARANTAN: I'm sorry?

2 MR. BALDWIN: The NDA doesn't say that 

3 this information will not be aggregated and 

4 shared. Let's say you have two participants. 

5 The NDA doesn't say that we won't publish that. 

6 Your practice or your process normally says that 

7 you would not, but where does that protection 

8 fall back on the manufacturer as a guarantee that 

9 that aggregate would not be published if you only 

10 have two or three manufacturers?

11 MR. MARANTAN: We will have to work with 

12 you on that.

13 MR. BALDWIN: Okay.

14 MR. MARANTAN: I think I can speak to the 

15 process that we have done, which is we don't 

16 disclose that type of information.

17 MR. BALDWIN: Okay. All right. We'll 

18 work on those details.

19 MR. MARANTAN: Thank you.

20 MS. KUMAR: Okay. So the manufacturer 

21 selling price then is calculated based on the 

22 manufacturer production cost and the manufacturer 
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1 markup, as shown in the graphic on this slide. 

2 The industry-wide manufacturer markup is 

3 determined based on publicly available financial 

4 sources, such as the SEC Form 10-K's and 

5 manufacturer feedback through the engineering 

6 interviews.

7 The final result for the engineering 

8 analysis is a cost-efficiency relationship in 

9 terms of manufacturer selling price, MSP, versus 

10 efficiency.

11 The next analysis we will be looking at 

12 is the preliminary manufacturer impact analysis.

13 There are three main purposes of the 

14 manufacturer impact analysis, or the MIA. The 

15 first is to quantitatively assess the financial 

16 impact of energy conservation standards on the 

17 manufacturers of commercial prerinse spray 

18 valves.

19 The second is to identify any potential 

20 manufacturer subgroups whose cost structure 

21 differs significantly from the industry average. 

22 One such common subgroup is the small business 
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1 manufacturers.

2 The third is to quantitatively and 

3 qualitatively examine other non-direct financial 

4 impacts of energy conservation standards on 

5 manufacturers. These include direct employee 

6 impacts, manufacturing capacity, and the 

7 cumulative regulatory impact on the manufacturing 

8 industry.

9 The methodology for the MIA is typically 

10 performed in three phases, which will be shown in 

11 the next slide. However, the key output of the 

12 MIA is the change in industry net present value, 

13 or INPV, resulting from energy conservation 

14 standards.

15 Here are the three phases of the 

16 manufacturer impact analysis. In the first 

17 phase, DOE creates an industry profile building 

18 on the market and technology assessment. This 

19 takes place during the preliminary analysis. 

20 During this time, DOE also identifies the key 

21 issues concerning manufacturers.

22 In the second phase, which spans both the 
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1 Notice of Proposed Rulemaking, NOPR, and the 

2 Final Rule analyses, DOE builds a strawman 

3 industry cash-flow model called the "Government 

4 Regulatory Impact Model," or GRIM, to forecast 

5 free cash flows in the industry. It does this 

6 both for the base case and the standards case, 

7 and calculates the INPV for each case.

8 Also, in Phase 2, DOE develops an 

9 interview guide that it will use to lead 

10 subsequent discussions with manufacturers during 

11 the MIA interviews, which take place in Phase 3. 

12 Note that these interviews are actually different 

13 than the engineering interviews that we just 

14 discussed. The engineering interviews generally 

15 happen right after the framework comment period; 

16 whereas, the MIA interviews happen right after 

17 the preliminary analysis comment period. So the 

18 engineering interviews are more focused on the 

19 engineering analysis; whereas, the manufacturing 

20 interviews are more focused on the manufacturer 

21 impacts.

22 In Phase 3, the MIA interviews take 
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1 place, and then following the interviews, DOE 

2 then refines the GRIM and evaluates other 

3 qualitative issues, such as the direct 

4 employment, manufacturing capacity, and the 

5 cumulative regulatory burden.

6 Finally, the MIA results are finalized 

7 for the NOPR.

8 At this time, DOE seeks an item for 

9 comment, item 12-1. DOE seeks comment on the 

10 appropriate manufacturer subgroups, if any, for 

11 commercial prerinse spray valves that DOE should 

12 consider in the manufacturer subgroup analysis.

13 MR. BROOKMAN: Jeff.

14 MR. BALDWIN: You mentioned small 

15 business as a subgroup. I would second that 

16 motion.

17 MR. BROOKMAN: Thank you.

18 MS. KUMAR: Thank you.

19 MR. BROOKMAN: Additional subgroups that 

20 you would note?

21 [No audible response.]

22 MR. BALDWIN: Nothing additional.
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1 MS. KUMAR: Okay.

2 So DOE also is requesting comment on any 

3 existing or pending regulations that should be 

4 examined in the cumulative regulatory burden 

5 analyses.

6 The next is the markup analysis. I will 

7 hand it over to Scott Morris from PNNL.

8 MR. BROOKMAN: How are you all doing? We 

9 are on Slide 48, and the remaining slides, there 

10 are about 80 or so slides total. So we're much 

11 better than halfway through, and the remaining 

12 slides tend to move rather rapidly.

13 Do we need a short coffee break at this 

14 point, or should we just plug on? We are 

15 certainly going to finish by noon today. Should 

16 we take a short coffee break right now, or should 

17 we just keep going? What's your comfort level?

18 [Laughter.]

19 MR. BROOKMAN: We've been at this a 

20 couple hours. Let's take a short break. It is 

21 now 10:15, and so we will break for 15 minutes.

22 For those of you that aren't familiar 
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1 with the Forrestal Building, you must wear this 

2 badge visible if you're in the building. There 

3 is a coffee shop down on the ground floor. Take 

4 the elevators to the ground floor and go in that 

5 direction, just about 30, 40 yards, and we'll see 

6 you back here to resume at 10:30.

7 [Recess taken from 10:13 to 10:32 a.m.]

8 MR. BROOKMAN: We are going to pick up 

9 where we left off, and we are going to hear from 

10 Scott Morris. Scott.

11 MR. MORRIS: All right. Thank you, Doug. 

12 Ready to go? Excellent.

13 My name is Scott Morris. I work for 

14 Pacific Northwest National Laboratory, and I will 

15 be talking about the remaining principles and 

16 analyses that you see in the slide in front of 

17 you.

18 These are all analyses that would be 

19 performed in the preliminary analysis phase of 

20 this rulemaking as well as updated and refreshed 

21 and revised as needed for the NOPR and Final Rule 

22 analyses.
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1 First, we'll talk about the markups 

2 analysis. The purpose of the markups analysis is 

3 to determine the final price an end user pays for 

4 baseline and more efficient equipment. 

5 Specifically, the markups analysis transforms 

6 MSPs from the engineering analysis into final 

7 end-user prices.

8 There are two main components of this 

9 analysis. The first requires identifying the 

10 distribution channels through which equipment 

11 passes between manufacturers and end users, and 

12 the second component is estimating the markups 

13 for each step within the distribution channels.

14 The slide shows the first component of 

15 the markups analysis or the distribution 

16 channels. DOE has so far identified three 

17 distribution channels in the commercial prerinse 

18 spray valve market. The first one is a 

19 distribution channel where products or equipment 

20 go from the manufacturer straight to the final 

21 customer.

22 The second is where equipment goes from 
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1 manufacturers through an authorized distributor, 

2 to a final customer. Mythri earlier talked about 

3 some of the ways that the equipment gets into the 

4 marketplace. She had mentioned showrooms. We 

5 would anticipate that showrooms might be an 

6 example of this second distribution channel.

7 Third is a manufacturer to a retail 

8 merchant to the final customer. A couple 

9 examples of this type of distribution channel 

10 might be, for example, box and mortar stores and 

11 Internet sellers.

12 The two most critical pieces of 

13 information DOE seeks input on here are, first, 

14 how many distribution channels are there or 

15 should there be. Are there more channels than 

16 what you see here? Are there not this many? 

17 That's first. And second, what percentage of all 

18 commercial prerinse spray valves go through each 

19 of these channels? 

20 So this brings us to a request for 

21 comment, 6-1. DOE seeks comment on the 

22 distribution channels and the share of industry 
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1 shipments for each distribution channel as they 

2 apply to the range of commercial prerinse spray 

3 valves that are covered by this potential rule.

4 MR. BROOKMAN: The first question is 

5 these three that are listed here. Is that it? 

6 Are there other distribution channels that are 

7 meaningful? Is that a good characterization?

8 MR. MORRIS: For example, is there a 

9 channel perhaps where contractors get involved in 

10 installing the equipment somehow?

11 MR. BROOKMAN: Jeff.

12 MR. BALDWIN: I'm an engineer, and so I 

13 don't get into sales a whole lot.

14 [Laughter.]

15 MR. BALDWIN: I will tell you the answers 

16 I do know on this. There could be a myriad of 

17 distribution channels, and it could be a 

18 combination thereof of what you have on the 

19 screen. It could be anywhere from directly to a 

20 final customer that is not normally like your 

21 Harry Homeowner-type customer. It would be more 

22 of your large national chain customer. Then you 
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1 have a host of options through distributors, 

2 merchants, Internet resellers, and it could be a 

3 combination where it goes through three or four 

4 points before it gets to that final customer, 

5 because sometimes you have the contractor, 

6 whether it's a general contractor or a plumbing 

7 contractor involved also. So it could be very 

8 complicated looking at that whole model of 

9 distribution.

10 MR. MORRIS: Thank you, Jeff.

11 So you would agree that what you see on 

12 the screen is perhaps just a small subset of 

13 every possible combination?

14 MR. BALDWIN: Correct.

15 MR. MORRIS: Thank you.

16 MR. BROOKMAN: Can you venture a guess 

17 about the percentages among these three broad 

18 bands of distribution?

19 MR. BALDWIN: I would not be the right 

20 person, but even if I was, we would not give out 

21 that percentage of information there.

22 MR. BROOKMAN: Okay. I was just 
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1 wondering if any of the trade associations have 

2 any information about such things.

3 MS. SALMON: We don't keep it.

4 MR. BROOKMAN: You don't keep that?

5 MS. SALMON: We don't keep values. 

6 They're proprietary.

7 MR. BROOKMAN: Okay. Thank you, 

8 Stephanie.

9 Okay. Well, then we're going to move on.

10 MR. MORRIS: I will explain the equation 

11 at the bottom momentarily, so don't get too 

12 fixated by the pretty green lettering down there.

13 But first, the take-home message from 

14 this slide is that DOE calculates markups which 

15 are applied again to manufacturer selling prices 

16 to get the end user final purchase prices.

17 Baseline markups include fixed costs such 

18 as occupancy expenses and labor expenses that do 

19 not scale with equipment cost. 

20 Incremental markups are calculated based 

21 on distribution channel costs that vary only with 

22 equipment costs, such as insurance, profit, and 
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1 depreciation.

2 Overall markups combine baseline and 

3 incremental markups, as shown in the equation, to 

4 develop the final purchase price for a given 

5 piece of equipment.

6 DOE plans on using data from, for 

7 example, the SEC 10-K reports and other sources 

8 to develop baseline incremental and, by 

9 extension, the overall markups for each of the 

10 steps in the individual distribution channels, 

11 and is, of course, interested in any other 

12 methods for calculating markups and/or sources of 

13 data that can be used in the markups analysis.

14 Just to briefly cover that equation in 

15 the bottom for those that are interested, for 

16 baseline efficiency equipment, the way that the 

17 final purchase price is calculated is given by 

18 the black, the black writing only. The final 

19 purchase price for baseline equipment is simply 

20 the manufacturer selling price of that baseline 

21 equipment times the baseline markup, that 

22 quantity multiplied by sales tax.
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1 For equipment that is higher or more 

2 efficient than the baseline efficiency, the 

3 calculation for determining the final purchase 

4 price of that equipment is simply within that 

5 equipment class, you take the MSP of the baseline 

6 equipment within that equipment class times the 

7 baseline markup plus this MSP EL minus MSP 

8 baseline is the manufacturer's selling price of 

9 the more efficient equipment minus the 

10 manufacturer's selling price of the baseline 

11 equipment, which is essentially the incremental 

12 cost difference between the more efficient 

13 equipment and the baseline equipment. That 

14 quantity is multiplied by the incremental markup, 

15 and then again, that whole quantity is multiplied 

16 by sales tax.

17 Anybody have any comments or questions 

18 regarding this equation or anything on this 

19 slide?

20 Yes, sir.

21 MR. OSANN: Yeah. Since sales tax isn't 

22 uniform --
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1 MR. BROOKMAN: Ed Osann.

2 MR. OSANN: Yeah. Ed Osann with NRDC.

3 Since sales tax is not uniform, what is 

4 your approach to getting a composite for that?

5 MR. MORRIS: We'll get to that in a few 

6 slides, but to answer the question, a Monte Carlo 

7 analysis where we incorporate variability in 

8 sales tax is typically by state.

9 Is that sufficient for now?

10 MR. OSANN: Yeah. That does take into 

11 account states that have no sales tax, right?

12 MR. MORRIS: With no sales tax?

13 MR. OSANN: Yeah.

14 MR. MORRIS: Yes, sir. Yep.

15 All right. We will move on to the energy 

16 and water use analysis.

17 Notice that the results of this analysis 

18 in conjunction with the outputs from the markups 

19 analysis and the engineering analysis are inputs 

20 to the life-cycle cost and payback period 

21 analysis, which I will refer to from here on out 

22 essentially as the "LCC analysis."
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1 We are going to talk about energy and 

2 water use. The energy and water use analysis has 

3 two primary purposes. The first is to assess how 

4 much energy and water is used for every equipment 

5 class and for each efficiency level. The second 

6 purpose is to provide the cost basis for energy 

7 and water use. 

8 The equation here shows a simple example 

9 of calculating daily water use. As an example, a 

10 calculation for calculating how much water is 

11 used in a day, if you are measuring it in 

12 gallons, just daily water use in gallons equals 

13 daily operating time in minutes, for example, 

14 times average flow rate in gallons per minute. 

15 Nothing more complicated than that.

16 For LCC and national impact analysis 

17 purposes, waste-water discharge will be assumed 

18 to be 100 percent of water used by the equipment. 

19 The WaterSense field study offers some insights 

20 into energy use as a function of water use and 

21 average operating times per day, which can be 

22 annualized by accounting for the number of 
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1 operating days per year by equipment class.

2 At this point, we have several requests 

3 for comment.

4 Item 7-1, DOE requests input on 

5 operational patterns of commercial prerinse spray 

6 valves for different equipment classes and 

7 applications that may impact water use.

8 Item 7-2, DOE seeks recommendations on 

9 sources of data for regional potable water supply 

10 temperatures and typical operational water 

11 temperatures used in commercial prerinse spray 

12 valves for different applications and equipment 

13 classes.

14 And item 7-3, DOE seeks comment on the 

15 inclusion of associated reduction in wastewater 

16 discharge as a result of lower flow rate for 

17 prerinse spray valves.

18 MR. BROOKMAN: Dain.

19 MR. HANSEN: This is more of a general 

20 question. When developing this, have you been 

21 involved with the WETT team, the Water Energy and 

22 Technology Team here at DOE to develop this? 
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1 This is the agency of the Department, within the 

2 Department of Energy that we work with closely, 

3 and their whole purpose is the energy water 

4 nexus, the energy loss, water loss between the 

5 two, and it's comprised mostly of National Labs. 

6 I think Sandia, Berkeley, and several other 

7 groups, but I would just encourage reaching out 

8 to them as well. 

9 I don't think it will be this micro in 

10 focusing on this specific technology, but they 

11 may have some input there, as well.

12 MR. BROOKMAN: Okay, thank you.

13 MR. MORRIS: Thank you for that feedback.

14 MR. BROOKMAN: You see the three comment 

15 boxes there: operational patterns, sources of 

16 data, and thoughts about inclusion of associated 

17 reduction in wastewater.

18 [No audible response.]

19 MR. BROOKMAN: Nothing additional here?

20 MS. TANNER: Hi. This is Stephanie 

21 Tanner from the WaterSense program.

22 I just wondered if you don't get any 
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1 sources of data, would DOE collect primary data 

2 on this?

3 MR. BROOKMAN: If they would initiate the 

4 data collection themselves?

5 MS. TANNER: Yeah, mm-hmm.

6 MR. BROOKMAN: What does WaterSense have, 

7 Stephanie?

8 MS. TANNER: Do you mean in terms of --

9 MR. BROOKMAN: In the way of data, yeah.

10 MS. TANNER: We don't collect operational 

11 data --

12 MR. BROOKMAN: I see.

13 MS. TANNER: -- on prerinse spray valves.

14 MR. BROOKMAN: okay.

15 MS. TANNER: We just collect the data 

16 that's used to create our product list, so . . .

17 MR. BROOKMAN: I see.

18 MR. MORRIS: If we don't receive comments 

19 -- this is Scott Morris. If we don't receive 

20 comments or data from interested parties, we will 

21 do our best to find it somewhere, somehow.

22 MR. BROOKMAN: There are probably pockets 
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1 of data collection in various places.

2 MR. MORRIS: There are, and within PNNL, 

3 we have a couple folks that are knowledgeable in 

4 the ways of water, and we will draw upon their 

5 expertise for some data in the absence of 

6 stakeholder input.

7 MR. BROOKMAN: Jeff.

8 MR. BALDWIN: We will offer further 

9 comments in our written comments, but there are 

10 several, as you say, pocket data, whether you're 

11 talking about NAFEM with food equipment or NRA 

12 with restaurant association or even the Food 

13 Service Tech Center out in California, who has 

14 done a lot of the work and actually helped 

15 develop the original ASTM F2324 standard and did 

16 a lot of operational -- they're kind of like the 

17 Consumer Reports of food service equipment, and 

18 so those are just a handful. But there's others, 

19 and we'll offer further comments on that in our 

20 written statement.

21 MR. BROOKMAN: Thank you.

22 Final comments here before we move on?
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1 [No audible response.]

2 MR. BROOKMAN: Okay.

3 MR. MORRIS: The LCC analysis uses inputs 

4 from the analyses we have discussed today so far 

5 as well as other data inputs.

6 This analysis in general determines 

7 impacts of different efficiency levels on a 

8 customer. LCC, or life-cycle cost, is the total

9 cost of equipment over its lifetime.

10 In the equation shown, installed cost is 

11 labor plus the final equipment purchase price, 

12 including all markups and sales tax. Operating 

13 costs include maintenance, repair, energy, water, 

14 and wastewater costs. Operating costs are 

15 typically annualized, and the last bullet there, 

16 payback period is the number of years required 

17 for operating cost savings to pay back any 

18 incremental costs of higher efficiency equipment.

19 And on the following slide, we've got a 

20 table that is going to give some more meat 

21 essentially to this equation here, and we will 

22 jump back and forth a couple of times, as needed, 
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1 between slides to illustrate that point.

2 In general, regarding the information on 

3 this slide, of most interest to DOE is whether 

4 any of the costs shown vary by efficiency level. 

5 As flow rates decrease, for example, do any of 

6 these costs change? 

7 The first two rows in this table, the 

8 equipment purchase price and installation cost 

9 rows, refer to the installed cost component of 

10 the equation shown in this slide, and the 

11 maintenance cost, repair cost, and energy and 

12 water cost rows in this table, refer on this 

13 previous slide to operating costs, which again 

14 you add the installed cost plus the operating 

15 cost to get life-cycle costs for a given piece of 

16 equipment.

17 So I will just briefly read through this 

18 table, just to say verbally what the LCC 

19 component is versus how it is actually 

20 calculated, the method that we'll use.

21 The equipment purchase price, it is 

22 simply done by marking up the MSPs from the 
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1 engineering analysis by the appropriate 

2 distribution channels and markup values, 

3 essentially marking those MSPs up by the overall 

4 markups, which include sales tax.

5 Installation cost includes labor and 

6 material costs to place the equipment into 

7 service. When I say material costs, depending on 

8 the type of equipment that we're talking about, I 

9 would imagine that in the prerinse spray valve 

10 market, there is not a lot of extra equipment. 

11 For example, this is not outdoor lighting where 

12 you have to rent a bucket truck to replace 

13 ballasts or lamps in high fixtures, but I guess 

14 on that tangential note, is there any equipment 

15 or materials that anyone can identify or think of 

16 that are required when installing prerinse spray 

17 valves, as well as, again, would the cost of the 

18 materials needed to install a prerinse spray 

19 valve change between baseline versus more 

20 efficient equipment?

21 MR. BALDWIN: I'd say that your 

22 comparison would be negligible between the 
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1 standard versus the higher efficient or however 

2 we want to call it.

3 I would caution against simply looking at 

4 it as a swap-out program. Because you have 

5 different manufacturers with different 

6 adaptations of their products, it may not fit 

7 together. Everybody doesn't always use the same 

8 thread, per se. The major manufacturers do, but 

9 some of the other ones do not.

10 If you are going into a facility that 

11 happens to have one of those unique brands -- I 

12 don't want to list any names here -- you may have 

13 difficulty in adapting one of the more common 

14 manufacturer's products. You may have to have an 

15 extra adaptor, or you may end up having to 

16 replace more than the spray valve. So you may be 

17 looking at it as a simple swap-out of a spray 

18 valve, but you may end up having to replace the 

19 prerinse hose or even the complete prerinse unit 

20 when you do that, so we have learned that through 

21 programs that we've done.

22 In California, we did the Rinse and Save 
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1 Program with the California Urban Water 

2 Conservation Council, and we've done other 

3 programs like that throughout North America. It 

4 is always a caution because everybody goes into 

5 it thinking it is a simple swap-out, and that's 

6 not always the case.

7 MR. BROOKMAN: Thank you.

8 MR. MORRIS: Thank you, Jeff.

9 Can I go a little bit farther down the 

10 rabbit hole and ask this following question? I 

11 was going to ask it later, but this is a fitting 

12 time now.

13 It's DOE's current understanding that for 

14 the most part, the commercial prerinse spray 

15 valve market is kind of a throwaway market, 

16 meaning at the end of the usable life of the 

17 prerinse spray valves, they are essentially 

18 replaced upon failure. My question for the 

19 general assembly here would be, Is that true? At 

20 the end of a usable life of a prerinse spray 

21 valve, are they typically thrown away?

22 We're aware of a couple refurbishment 
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1 kits, for example, but do those actually get 

2 used, and is equipment refurbished or simply 

3 thrown away?

4 MR. BALDWIN: Again, that will depend on 

5 the manufacturer. Your more common mainstay 

6 brands have repair kits, and we sell a lot of 

7 repair kits for our products. 

8 We do not classify our spray valves as

9 throwaways. There are some on the market that 

10 are classified as that. T&S holds true that our 

11 products will last forever. So you can buy a 

12 repair kit for a spray valve that was made in 

13 1947 when we first invented the commercial 

14 prerinse spray valve. You still can buy that 

15 repair kit today, and we do have pictures and 

16 documentations of spray valves that have been in 

17 use for over 60 years.

18 MR. BROOKMAN: Thank you.

19 MR. MORRIS: Thank you

20 I will continue down this list here. 

21 Maintenance costs are incurred by the 

22 customer for preventative maintenance of the 
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1 equipment. Repair costs are costs incurred in 

2 repairing or replacing damaged or malfunctioning 

3 components of the equipment, and energy and water 

4 costs are paid by the customer for the energy and 

5 water used by hot-water-using equipment, such as 

6 these prerinse spray valves.

7 In general, to calculate the costs of 

8 energy, DOE plans on using the Energy Information 

9 Administration's Annual Energy Outlook to 

10 estimate energy prices, and based on limited 

11 research thus far in this rulemaking process, DOE 

12 is aware of the American Water Works 

13 Association's Water Rate Survey, which could be 

14 used perhaps to estimate current water and 

15 wastewater prices; and then in order to project 

16 those costs of water and wastewater into the 

17 future may use the Consumer Price Index Water 

18 Utility Costs to develop a growth rate, which can 

19 then be applied to the current AWWA water and 

20 wastewater costs.

21 I guess I would ask at this point, as 

22 well, even though it is not a formal request for 
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1 comment, Are there other sources of information 

2 or data that folks are aware of for estimating 

3 the cost of water?

4 MR. BROOKMAN: No. Okay.

5 MR. BALDWIN: That's the best resource.

6 MR. MORRIS: Several other inputs to the

7 LCC analysis include discount rates, a base case 

8 efficiency distribution, and equipment lifetime.

9 Discount rates will be derived by 

10 calculating the weighted average cost of capital 

11 for different businesses that own the equipment.

12 Base case efficiency distributions, which 

13 give the relative percentage of units at each 

14 efficiency level and equipment class in the 

15 absence of a standard, are very important because 

16 they determine much about the magnitude of energy 

17 and monetary savings, resulting from an amended

18 standard.

19 While the percentages used in the base 

20 case efficiency distribution are not necessarily 

21 identical to the shipments of each efficiency 

22 level, the two, as you can imagine, are closely 
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1 related.

2 Regarding equipment lifetime, it is also 

3 of interest to the Department whether more 

4 efficient equipment, for example, equipment that 

5 has a lower flow rate perhaps, has a different 

6 lifetime than the baseline equipment.

7 Finally, the Department has a great 

8 desire to know any information that people have 

9 regarding the base case efficiency distribution: 

10 What does the, perhaps, current installed stock 

11 of equipment in the country look like right now?

12 We are going to get to some comments in a 

13 couple of slides, but that particular question 

14 regarding base case efficiency distributions is 

15 not a specific item that DOE requests comment on.

16 I guess to reiterate and to formally ask 

17 the question here, are there any folks in the 

18 room here or online who know or have any data or 

19 information that they may be able to share 

20 regarding a base case efficiency distribution, 

21 or, in other words, in general terms, how many or 

22 what percentage of equipment currently being sold 
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1 and/or is currently installed -- how much of that 

2 uses 1.6 gallons per minute? How much uses 1.4, 

3 et cetera, et cetera?

4 I realize it's another gray area, I'm 

5 sure, but any input is appreciated.

6 MR. BROOKMAN: None of the trade 

7 associations gather that information?

8 [No audible response.]

9 MR. BROOKMAN: No.

10 MR. MORRIS: Do you know where we might 

11 be able to find such information?

12 MR. BROOKMAN: Please use the microphone. 

13 Ed Osann.

14 MR. OSANN: Ed Osann with NRDC.

15 I think WaterSense partners report their 

16 share of -- their shipment of labeled product and 

17 unlabeled product in the same category.

18 MR. BROOKMAN: Okay. Thank you, Ed.

19 MR. MORRIS: Thank you.

20 MR. BROOKMAN: Jeff.

21 MR. BALDWIN: Yeah. The drawback to that 

22 is the WaterSense program is fairly new. As I 
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1 mentioned earlier, it's only been released this 

2 year, and right now, you only have two 

3 manufacturers that are participating in that 

4 program, and so you are missing a lot of 

5 manufacturers there. Plus, the reporting 

6 actually hasn't even happened yet, because we 

7 just started this year, and that's an annual 

8 reporting that we do in the February time frame.

9 I will let Stephanie answer that.

10 MS. TANNER: This is Stephanie Tanner 

11 with the WaterSense program.

12 Right. We only get data from 

13 manufacturers who choose to report. So we don't 

14 really believe that our data is like market-share 

15 data, and so, like Jeff said, we only have two 

16 manufacturers that have labeled products now. 

17 All the other products that are on your list that 

18 were on your original pie chart, we don't have 

19 any data for them. 

20 We haven't really started collecting that 

21 much data on prerinse spray valves at this point, 

22 so I would not say that we have like base case 
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1 information for the market in terms of prerinse 

2 spray valves at this point.

3 MR. BROOKMAN: Thank you.

4 MR. MORRIS: This is Scott Morris again.

5 Another question I just thought of, and 

6 this is not specifically aimed at Jeff, but he so 

7 far has been a source of walking information, a 

8 walking encyclopedia.

9 Regarding the equipment you had mentioned 

10 that, for example, has been in service since 

11 1946, your refurbishment kits -- and I'm sorry if 

12 this is obvious for everybody else in the room. 

13 For example, would your equipment from 1946, for 

14 example, with a refurbishment kit be able to 

15 meet, for example, a 1.6-gallon-per-minute 

16 standard?

17 I guess I am not asking that question 

18 specifically. What I am trying to ask is, Do 

19 refurbishment kits or can refurbishment kits have 

20 the capability and potential of reducing the flow 

21 rate or changing the energy efficiency or 

22 performance or products?
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1 MR. BALDWIN: That's a yes and a no.

2 You have complete kits that would rebuild 

3 that spray valve from the metal up, so you would 

4 start with the main body, and you would rebuild 

5 from that point, but you also have very specific 

6 repair kits, if they have a leak or a worn handle 

7 or something else that is missing or broke on 

8 part of that product. So the answer is yes and 

9 no. We offer it both ways. It really depends on 

10 what repair is needing to be made in the field.

11 MR. MORRIS: Thank you very much.

12 [Pause.]

13 MR. MORRIS: Okay, good. Thank you.

14 So, as a statistician and somebody who 

15 appreciates variability and the information 

16 contained in variability, I personally appreciate 

17 the depth that Monte Carlo simulations give to 

18 the LCC analysis.

19 In general, just about any data input 

20 whose variation can be characterized will have 

21 its variability analyzed in the LCC analysis, 

22 such as sales tax. So other examples include 
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1 energy prices, discount rates, and -- I'm coming 

2 up short on examples, but basically any input to 

3 the LCC analysis that has a distribution that can 

4 be estimated will be varied in order to capture 

5 the wide range of variability present in the 

6 marketplace.

7 Outputs from the Monte Carlo simulations 

8 and, hence, the LCC analysis in general include 

9 life-cycle cost, life-cycle cost savings, payback 

10 period, and percentages of customers that benefit 

11 from, are adversely affected by, or are 

12 unaffected by an amended standard.

13 This brings us to a laundry list of 

14 requests for comment, items 8-3 through 8-7.

15 8-3. DOE seeks comment on sources of 

16 data for determining marginal water and 

17 wastewater rates and methods to break out water 

18 and wastewater rates across different pricing 

19 segments, such as regionally or by state.

20 8-4. DOE seeks data sources and methods 

21 to determine future trends in water and 

22 wastewater rate escalations.
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1 8-5. DOE invites comment on whether 

2 repair costs may change for more efficient 

3 commercial prerinse spray valves.

4 8-6. DOE invites comment on whether 

5 commercial prerinse spray valves are typically 

6 replaced upon failure or repaired.

7 8-7. DOE seeks comment on appropriate 

8 commercial prerinse spray valve lifetimes for the 

9 equipment under consideration, as well as data 

10 regarding correlation between hours of use and 

11 commercial prerinse spray valve lifetime.

12 [Pause.]

13 MR. BROOKMAN: No additional comment 

14 here?

15 Jeff.

16 MR. BALDWIN: Your first two items there, 

17 I would refer to the American Water Works 

18 Associations for items 8-3 and 8-4. Yeah, 8-3 

19 and 8-4.

20 Items 8-5 through 8-7, that could vary, 

21 depending on the manufacturer and how they go to 

22 market with their product. Some, of course, 
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1 manufacturers and distributors see a premium for 

2 more efficient products. Others see it as doing 

3 their service to the environment and to their 

4 customers by offering it at the same price, so 

5 that could vary from manufacturer to 

6 manufacturer.

7 MR. BROOKMAN: Okay, thank you.

8 MR. MORRIS: One comment about the 

9 equipment lifetime -- this is an example of 

10 something that will be most likely given a 

11 distribution in the Monte Carlo analysis -- is 

12 DOE's current -- and again, this is based on, 

13 shall we say, entry-level research thus far --

14 current understanding is that, again, in very 

15 general terms, perhaps the average lifetime of a 

16 prerinse spray valve is in the neighborhood of 5 

17 years. Can anybody comment on a ball-park 

18 figure? Is that in the right ball park? Is that 

19 way out of bounds?

20 MR. BALDWIN: On every research project 

21 we've seen, we have seen that assumption over and 

22 over. So it started somewhere, and it's been 
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1 repeated. Where that assumption was gathered, I 

2 can't answer that. As I said, our products can 

3 last longer than 5 years. It's really up to the 

4 end user whether to take that expense of complete 

5 replacement or a field repair.

6 MR. BROOKMAN: Thank you.

7 MR. MORRIS: Okay. Thank you very much.

8 We will now talk about the shipments 

9 analysis, which connects the LCC analysis and the 

10 national impact analyses together.

11 The shipments analysis is, in a way, 

12 ultimately what scales the energy savings -- or 

13 the water savings and energy savings at an 

14 individual customer level to savings at a 

15 national level.

16 The purpose of the shipments analysis is 

17 to project future equipment shipments and 

18 nationally installed stock by equipment class and 

19 efficiency level.

20 DOE typically projects shipments for 30 

21 years, beginning with the expected date of 

22 compliance or the compliance date.
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1 DOE will try to find historical and 

2 current shipments from resources such as industry 

3 trade organization surveys and will project 

4 future shipments using data such as the EIA's 

5 Annual Energy Outlook forecast of new commercial 

6 construction.

7 Now, having said this, obtaining reliable 

8 shipments data, as you can imagine, can sometimes 

9 be difficult for DOE to come by, and the 

10 Department appreciates any and all comments, 

11 resources, sources to look at, or data from 

12 interested parties.

13 I think I will pose that as a question, 

14 which is, anybody here, do you have comments 

15 regarding shipments? I realize it's very early 

16 in the rulemaking process, but I realize there is 

17 NDAs and other stuff. But DOE greatly 

18 appreciates any information regarding shipments.

19 MR. BROOKMAN: Let's move on to the next 

20 slide.

21 MR. MORRIS: Which are some requests for 

22 comment. 
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1 You're right, Doug. I should have gone 

2 here first.

3 Item 9-1, DOE seeks comment on an 

4 appropriate shipments projection methodology, 

5 including the selection of appropriate economic 

6 drivers. Economic drivers would be things such 

7 as commercial floor space growth, an appropriate 

8 proxy to use for the growth of the industry in 

9 general, or population growth, things like that.

10 Item 9-2, DOE requests historical 

11 shipments data for the equipment discussed, 

12 including shipments for differing equipment flow 

13 rates.

14 Item 9-3, DOE seeks comment on how an 

15 energy conservation standard for commercial 

16 prerinse spray valves might impact shipments of 

17 the equipment.

18 MR. BROOKMAN: Jeff.

19 MR. BALDWIN: I would think it would be 

20 very difficult for the DOE to gather that 

21 historical shipment data for this product.

22 MR. BROOKMAN: Is there a methodology 
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1 that they might employ?

2 MR. BALDWIN: I mean, the closest thing 

3 we have to a shipment data would be the 

4 WaterSense program that has just started, as I 

5 mentioned earlier. This information doesn't 

6 exist, because you're talking about a couple of 

7 the lead manufacturers here are family-owned 

8 companies that do not report that information.

9 MR. BROOKMAN: Okay.

10 MR. MORRIS: So, in general -- this is 

11 Scott Morris again. In general, the way I have 

12 seen shipments information developed over time is 

13 DOE will make a best estimate based on any 

14 possible data they can find and throw it out to 

15 the public and request comment. Something along 

16 the lines of that's way too high, that's way too 

17 low, any feedback is appreciated.

18 But we certainly understand the 

19 sensitivity, the sensitive nature of that type of 

20 data.

21 We will now discuss the national impact 

22 analysis, or NIA, which is the final economic 
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1 analysis DOE will conduct in the preliminary 

2 analysis phase of this rulemaking.

3 The purpose of the national impact 

4 analysis is to calculate three quantities 

5 associated with an amended standard: National 

6 energy savings, or NES, national water savings, 

7 and national monetary savings or net present 

8 value, NPV.

9 The method for calculating these 

10 quantities includes developing annual figures for 

11 every year of the analysis period, which again is 

12 30 years, beginning with the expected compliance 

13 date, and then essentially summing across all 

14 years to calculate cumulative totals.

15 The LCC analysis contributes information 

16 about installed costs and energy and water use 

17 per unit. 

18 The shipments analysis contributes 

19 shipment and stock information.

20 NES, again, national energy savings, is 

21 reported in both primary and full fuel cycle 

22 energy savings. NPV is reported in billions of 
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1 dollars, and water and wastewater savings will be 

2 reported in billions of gallons or some 

3 appropriate measurement of water volume.

4 Finally, the time value of money will be 

5 accounted for using defined discount rates.

6 Inputs for national energy savings, I 

7 need to make one little clarification here, in 

8 case anybody is going to call me out on it or 

9 not, but under the inputs for calculating 

10 national energy savings, national water savings, 

11 the projected shipment sub-bullet actually 

12 belongs as an input for calculating NPV.

13 In general, inputs for national energy 

14 savings and national water savings include annual 

15 energy and water use per unit at each efficiency 

16 level for all equipment classes, equipment stock, 

17 which is how many are using -- how many units are 

18 using energy and water nationwide, and for energy 

19 savings in particular, a site-to-source 

20 conversion factor, which converts energy use at 

21 the site of use to energy produced at the source.

22 The main inputs for calculating NPV 
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1 include installed and operating costs of all 

2 equipment for each year of the analysis period, 

3 projected shipments starting, again, with the 

4 compliance date, and accounting for the time 

5 value of money through defined discount rates of 

6 3 and 7 percent.

7 The next slide is several requests for 

8 comment. Item 10-1, DOE seeks comment on how the 

9 efficiency of commercial prerinse spray valves 

10 would be likely to change in the future in the 

11 absence of standards.

12 Item 10-2, DOE seeks comment on the 

13 likelihood of increased commercial prerinse spray 

14 valve usage as a direct result of improved 

15 equipment efficiency.

16 MR. BROOKMAN: Comments on either of 

17 these? 

18 Jeff.

19 MR. BALDWIN: As I mentioned, T&S 

20 invented the prerinse spray valve in the 1940s, 

21 but we also invented what a lot of people call 

22 the "low-flow prerinse spray valve" in the 1980s.
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1 The market has evolved without extra 

2 standards or regulations being placed on prerinse 

3 spray valves. A lot of that is the world in 

4 which we live in where conservation is top of 

5 mind for all organizations and companies that we 

6 do business with, and so we have made products

7 that have been more efficient. We have not been 

8 forced to make them by a regulation. We have 

9 made them based on customer request or customer 

10 satisfaction.

11 The efficiency of commercial prerinse 

12 spray valves will change in the future, 

13 regardless of the standard, because that's just a 

14 part of being a competitor in the market and 

15 listening to our customers.

16 MR. BROOKMAN: Thank you.

17 MR. MORRIS: That essentially wraps up 

18 the analyses that DOE will conduct for the 

19 preliminary analysis phase of this rulemaking.

20 The analyses shown in this slide are 

21 something we worry about way in the future, which 

22 means next fall, which are conducted in the NOPR 
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1 and Final Rule analyses.

2 Although the NOPR phase is highlighted 

3 here, the analyses shown are also included in the

4 Final Rule phase, and that first chevron that's 

5 to the left of the circle, revising the 

6 preliminary analysis means incorporating 

7 information and data for all of the analyses we 

8 have discussed today and not just the ones shown 

9 here.

10 For example, in the NOPR phase -- and I 

11 know Mythri -- we have talked about this already, 

12 but in the NOPR phase, we will be looking at 

13 inputs for the engineering analysis, the markups, 

14 and energy and water use analyses, life-cycle 

15 cost, and national impact analyses.

16 We will jump into just talking about 

17 these individual analyses, which will be done at 

18 the NOPR phase. This will be quite brief, 

19 because we're sort of jumping the gun talking 

20 about the NOPR phase.

21 The customer subgroup analysis, also 

22 known as the "LCC subgroup analysis," assesses 
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1 the economic impacts of standards on identifiable 

2 subgroups within the general population. Results 

3 from the individual subgroups are compared 

4 against the results from the main LCC analysis.

5 Some examples of consumer or customer 

6 subgroups may include things like churches, 

7 mom-and-pop restaurants, and nursing homes, for 

8 example.

9 This brings us to item 11-1. DOE seeks 

10 comment on what, if any, user subgroups should be 

11 considered in evaluating potential standards for 

12 commercial prerinse spray valves.

13 I should specify also we are talking 

14 about customer subgroups, not manufacturer 

15 subgroups.

16 MR. BROOKMAN: Jeff.

17 MR. BALDWIN: You have a wide array of 

18 subgroups there, starting with your national 

19 large chain customers, whether it's a national 

20 restaurant chain or worldwide international 

21 restaurant chain, all the way down to, as you 

22 said, your mom-and-pop restaurants. So you have 
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1 a wide array there, and it will be very 

2 interesting how you categorize those into 

3 subgroups to catch all the different ones there.

4 MR. BROOKMAN: Thank you.

5 MR. HANSEN: This is Dain. Just really 

6 quick, this isn't really -- I mean, somewhat a 

7 customer subgroup, but I'd also say as a testing 

8 certification body, that is a whole new realm if 

9 there's new standards being developed and new 

10 federal regulations. Then there must be tests 

11 and certified to a certain level. So that brings 

12 in a whole nother subgroup as well that you are 

13 going to be looking into, and so just to keep 

14 that in mind that it's not just the regulation, 

15 then enactment. There's other steps that will be 

16 used in the marketplace, as well.

17 MR. MORRIS: Okay, thank you.

18 MR. BROOKMAN: Thank you.

19 MR. MORRIS: We will talk briefly about 

20 the utility impact analysis. The utility impact 

21 analysis examines the impacts on domestic energy 

22 supplies that result from the imposition of 
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1 standards.

2 DOE plans on using factors derived from 

3 NEMS-BT, which is a variant of the National 

4 Energy Modeling System, to project energy sales 

5 and prices, generation, and capacity.

6 This brings us to a few items. 13-1. 

7 DOE seeks comment from interested parties about 

8 its proposed use of NEMS-BT to conduct the 

9 utility impact analysis.

10 13-2. DOE seeks comment and information 

11 on potential methods and data sources that can be 

12 used to assess the impacts on water and 

13 wastewater utilities as a result of energy 

14 conservation standards for commercial prerinse 

15 spray valves.

16 In other words, that item 13-2, DOE has a 

17 great resources in NEMS-BT to calculate the 

18 impacts on electrical-generating utilities and 

19 natural gas utilities. Is there similar data or 

20 tools that anybody can identify that could be 

21 applied to water and wastewater utilities?

22 [No audible response.]
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1 MR. MORRIS: We will talk about the 

2 employment impact analysis.

3 The employment impact analysis assesses 

4 the indirect employment impact on the general 

5 economy stemming from standards. These are 

6 different impacts than the direct employment 

7 impacts discussed in the manufacturer impact 

8 analysis. DOE plans on using the ImSET model, 

9 which is the Impact of Sector Energy Technologies 

10 model, for evaluating indirect employment 

11 impacts.

12 Item 14-1, DOE seeks comments about a 

13 suggested approach for assessing national 

14 indirect employment impacts.

15 MR. BROOKMAN: Jeff.

16 MR. BALDWIN: Again, I would mention the 

17 National Restaurant Association. It may be a 

18 question you could tee up to them and see what 

19 work they have done or work they would want to 

20 participate in there, because they represent a 

21 huge share of the market that utilizes this 

22 product.
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1 MR. BROOKMAN: Thank you.

2 MR. MORRIS: Thank you.

3 MR. BROOKMAN: Additional comments here?

4 [No audible response.]

5 MR. MORRIS: Okay. We'll talk about the 

6 emissions analysis and monetization of emissions 

7 for the next few slides.

8 The emissions analysis looks at 

9 environmental impacts from standards, including 

10 FFC or full fuel cycle emissions. DOE bases 

11 emission factors on NEMS, supplemented with other 

12 sources, to examine the standards' impacts on the 

13 handful of the emissions shown in the slide.

14 Item 15-1, DOE seeks comment about its 

15 approach to conduct the emissions analysis for 

16 the equipment that would be covered under this 

17 proposed rulemaking -- I shouldn't say "proposed" 

18 yet -- under this rulemaking, in general.

19 Item 15-2, DOE seeks comment and 

20 information on potential methods and data sources 

21 that can be used to assess emissions reductions 

22 as a result of water savings.
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1 MR. BROOKMAN: Jeff? No? Nothing? 

2 Nothing here?

3 [No audible response.]

4 MR. BROOKMAN: Okay.

5 MR. MORRIS: Ed?

6 MR. OSANN: Ed Osann with NRDC.

7 In previous rulemakings, DOE has resisted 

8 comments and recommendations regarding the 

9 incorporation of embedded energy savings from 

10 water-saving products and water-saving standard 

11 levels.

12 With this request for information on 

13 emission reductions associated with water 

14 savings, are you anticipating a willingness to 

15 consider embedded energy savings at the NOPR 

16 stage?

17 MR. MORRIS: I believe the answer is yes. 

18 Part of the reason DOE has historically not used 

19 or not really examined closely the impact of 

20 water savings in terms of how it saved energy in 

21 water and wastewater utilities -- for example, in 

22 the commercial clothes washer rule -- is because 
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1 the water and wastewater utilities are extremely 

2 variable by region, and it is very difficult to 

3 summarize or model such large variations.

4 With this comment, I think DOE is 

5 definitely open to the idea of it, of looking at 

6 these embedded energy savings. The question is 

7 is it feasible to do so, and can we have a 

8 defensible -- not a case, but I guess you could 

9 say a defensible case for including it in the 

10 analysis.

11 So if we can, within DOE and with help 

12 from interested parties, develop a methodology 

13 that will allow us to defensibly and justifiably 

14 look at it, it will certainly be done.

15 MR. BALDWIN: I'd like to make a comment. 

16 As Ed mentioned, I'd have to go out on record 

17 saying I think it would be shortsighted -- and 

18 I'll use the word "asinine" -- not to look into 

19 embedded energy savings when you're dealing with 

20 commercial prerinse spray valves. The product 

21 uses tempered water all the way up to what we 

22 would call "hot water," and to not look at the 
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1 energy part of that calculation would not be 

2 recommended.

3 If you look at any of the water savings 

4 calculators that the manufacturers use for 

5 prerinse spray valves, you will see that energy 

6 is really where the savings is when you are 

7 looking at commercial prerinse spray valves. 

8 It's not all about the water, and so we have to 

9 make sure we are not shortsighted there to only 

10 look at one component of the calculation.

11 MR. BROOKMAN: Okay. Thanks, Jeff.

12 MR. MORRIS: Jennifer Williamson has some 

13 input here.

14 MR. BROOKMAN: Yes.

15 MS. WILLIAMSON: Jennifer Williamson, 

16 PNNL.

17 I just wanted to point out that here we 

18 are talking about the impacts at the utility 

19 level, not at the end-use level. So we will be 

20 looking at the energy use associated with 

21 producing the hot water to be used by the spray 

22 valves.
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1 MR. BROOKMAN: Thank you.

2 MR. MORRIS: Thank you.

3 Regarding monetization of emissions, DOE 

4 plans to use the most current Social Cost of 

5 Carbon values from interagency reviews to 

6 quantify the monetary savings associated with 

7 emissions reductions.

8 In item 16-1, DOE requests comment about 

9 the approach it plans to use for estimating 

10 monetary benefits associated with emissions 

11 reductions.

12 [No audible response.]

13 MR. BROOKMAN: Nothing here. Okay.

14 MR. MORRIS: Okay. We will talk about 

15 the regulatory impact analysis, which brings us 

16 to the bitter end of the NOPR and Final Rule 

17 phase analyses.

18 The regulatory impact analysis explores 

19 non-regulatory alternatives to standards that can 

20 save energy. Some examples include tax credits, 

21 rebate programs, bulk purchase programs, and the 

22 WaterSense program.
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1 There is no official request for comment 

2 on the regulatory impact analysis, but DOE is 

3 open and would like input regarding any other 

4 programs specifically in this market that have 

5 the potential for saving energy.

6 MR. BALDWIN: Again, I would mention the 

7 programs that have been very successful in doing 

8 this without new standards.

9 The one, top of mind, would be the Rinse 

10 and Save program that California Urban Water 

11 Conservation Council completed in a couple of 

12 phases before the EPAct 2005 was ever released, 

13 and it was kind of the precipitous for that being 

14 done. It was so successful. So I would look at 

15 those programs and garner the information and the 

16 calculations that they had done at that time.

17 MR. BROOKMAN: Okay. Thank you, Jeff.

18 Any additional examples or models that 

19 the Department might rely upon?

20 [No audible response.]

21 MR. BROOKMAN: Nothing additional. Okay.

22 MR. MORRIS: Okay. We'll turn it back to 
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1 you, Doug, for closing remarks.

2 Closing Remarks.

3 MR. BROOKMAN: Thank you. Thank you, 

4 Scott.

5 So, as we had promised first thing this 

6 morning, now is an opportunity for anybody that 

7 wishes to make concluding remarks, to bring other 

8 issues to the fore that haven't been fully 

9 covered at this stage of the rulemaking, and 

10 final comments here.

11 [No audible response.]

12 MR. BROOKMAN: Nothing additional, okay.

13 So then we will go to the final slide and 

14 back to Jim Raba.

15 MR. RABA: Wow!

16 MR. BROOKMAN: Microphone.

17 MR. RABA: I should know better.

18 MR. BROOKMAN: Yeah.

19 MR. RABA: Hey, many thanks for your very 

20 thoughtful and productive participation today. I 

21 learned a lot myself, and I think we all 

22 appreciate the comments that came in from all 
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1 sources, live and on the webinar, as well. Thank 

2 you.

3 So you have seen an overview of the 

4 rulemaking process, all that goes into it. 

5 There's more to come. Analyses are just getting 

6 started for sure. I look forward to your input, 

7 your comments and data to provide.

8 The comment period closes October 27th, 

9 as a reminder.

10 In about 2 weeks or so, the transcript of 

11 this public meeting should appear on our 

12 Department of Energy Web page for commercial 

13 prerinse spray valves, so take a look there and 

14 kind of monitor that about 2 weeks hence.

15 Then again, we look forward to your 

16 comments, your written comments.

17 Safe travels, everybody. Thank you.

18 MR. HANSEN: Quick question.

19 MR. RABA: Dain.

20 MR. HANSEN: When are these going to be 

21 available? Because I want to get this over to 

22 our engineers in our lab, so they can help 
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1 develop comments, and hopefully, it's sooner than 

2 2 weeks, so they can start working.

3 MR. RABA: You're saying the --

4 MR. HANSEN: The PowerPoint from today.

5 MR. RABA: We should have that up on the 

6 Web page by tomorrow late.

7 MR. HANSEN: Okay.

8 MR. BALDWIN: It was posted yesterday.

9 MR. HANSEN: Oh, was it? Okay. Thank 

10 you.

11 MR. RABA: Thank you, Dain.

12 MR. OSANN: There is usually a point of 

13 contact for technical questions given. I don't 

14 see one on the slide deck.

15 MR. RABA: That would be John Cymbalsky.

16 MR. OSANN: For technical questions?

17 MR. RABA: Yes.

18 MR. OSANN: Okay.

19 MR. BROOKMAN: So thanks to all of you.

20 MR. RABA: John will get the answer for 

21 you, Ed. Thank you.

22 MR. BROOKMAN: And safe travels.
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1 [Whereupon, at 11:29 a.m., the public 

2 meeting concluded.]

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1 CERTIFICATE OF NOTARY PUBLIC 

2 I, Brian Knieser, Notary Public in 

3 and for the District of Columbia, the officer 

4 before whom the foregoing proceedings were 

s recorded, do hereby certify the foregoing 

G transcript of said proceedings was taken by me 

1 and thereafter reduced to typewriting under my 

s direction. 

9 

10 BRIAN KNIESER 

11 Notary Public in and for 

12 

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The District of Columbia 

Commission Expires: 

03.14.2019 

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