1

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### U.S. Department of Energy 1

2

3

4


### Public Meeting on 5


### Commercial Prerinse Spray Valve Framework 6



### [Docket No. EERE

- 2014

- BT

- STD

- 0027] 7

8

9

10



### 9:05 t o 11:2 9 a.m. 11


### Tuesday, September 30 , 2014 12

13


### U.S. Department of Energy 14



### Room 8E

- 089 15


### 1000 Independence Avenue, S.W. 16


### Washington , D.C. 17

18

19

20

21

222

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### ATTENDEES : 1


### JOHN CYMBALSKY, Equipment and Appliance 2


### Standards Program Manager 3


### DOUG BROOKMAN, Facilitator for Public Solutions 4


### JEFF BALDWIN, Engineering Manager, 5



### T&S Brass and Bronze Works 6


### STEPHANIE TANNER, Lead Engineer, Water Sense, 7



### Envi ronmental Protection Agency 8



### HOLLY CANNON, Environmental Scientist, 9


### Eastern Research Group, Inc. 10


### CELIA SHER, General Counsel's Office, DOE 11


### JIM RABA, Appliance Standards Program, DOE 12



### JENNIFER WILLIAMSON, 13


### Pacific Northwest National Laboratory 14



### SCOTT MOR RIS, 15


### Pacific Northwest National Laboratory 16


### ARIS MARANTAN, Navigant Consulting 17



### MYTHRI KUMAR, Navigant Consulting 18



### STEPHANIE SALMON, 19


### Plumbing Manufacturers International 20



### DA I N HANS E N , International Association of 21


### Plumbing and Mechanical Officials 223

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### ATTENDE ES : (continued) 1



### JOAN N A MAUER, Appliance Standards Awareness 2


### Project 3


### ED OSANN, Natural Resources Defense Council 4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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### C O N T E N T S 1



### PAGE 2


### Public Meeting Topics 3


### Housekeeping Items 5 4


### Rulemaking Process Overview 1 4 5


### Authority and Definitions 1 9 6



### Test Procedure and Test Metrics 2 2 7


### Rulemaking Analyses 28 8


### Closing Remarks 115 9

10

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



### HOUSEKEEPING ITEMS 2



### MR. BROOKMAN: Good morning, everyone. 3


### Welcome. This is the Energy Conservation 4


### Standards Framework meeting for Commercial 5


### Prerinse Spray Valve s

. Today is September 30th, 6


### 2014, here in the Forrestal Building in 7


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


### this morning. 9


### My name is Doug Brookman from Public 10


### Solutions in Baltimore. We're going to start 11


### this morning with welcoming remarks from John 12


### Cymbalsky. 13



### AGENDA REVIEW

- OPENING REMARKS 14


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


### is John Cymbalsky. I am the Program Manager for 16


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


### welcome you all to the public meeting on prerinse 18


### spray valves. 19


### Hopefully, we have a productive meeting. 20


### We have q uite a bit of slides and material to go 21


### through, which we will, and please feel free to 226

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### speak up, ask questions, and hopefully, we have a 1


### healthy debate over material presented here 2


### today. 3


### Thank you. 4


### MR. BROOKMAN: Thank you. 5


### We always start with introd uctions, and I 6


### will start with my immediate left. You can get 7


### used to turning these microphones on and off. 8


### The little green light illuminates there. Your 9


### name and organizational affiliation

. 10


### MR. BALDWIN: I am Jeff Baldwin, 11


### Engineering Manager for T&S Brass and Bronze 12


### Works. We are the original inventor and the lead 13


### manufacturer for prerinse spray valves. 14


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


### the Lead Engineer for the EPA's WaterSense 16


### program, which labels prerinse spray valves. 17



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



### environmental scientist with Eastern Research 19


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



### WaterSense program. 21


### MR. BROOKMAN: And where are you located? 227

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### MS. CANNON: I actually work from home in 1


### Blacksburg, Virginia, so my offi ce base is in 2


### Chantilly. 3


### MR. BROOKMAN: Thank you. 4



### Please. 5



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



### General Counsel's office at DOE. 7



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


### Energy, Appliance Standards Program. 9


### MR. BROOKMAN: Please stand up. 10



### MS. WILLIAMS ON: Jennifer Williamson, 11


### Pacific Northwest National Laboratory. 12


### MR. MORRIS: Scott Morris, Pacific 13


### Northwest National Laboratory, or PNNL. 14


### MR. MARANTAN: Aris Marantan, Navigant 15


### Consulting. 16


### MS. KUMAR: Mythri Kumar, Navigant 17


### Consulting. 18



### MR. BROOKMAN: So glad you could join us 19


### here this morning. 20


### All of you received a packet of 21


### information as you came in today. On page 3 of 228

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### the packet is the agenda, which I am going to go 1


### through very briefly. Immediately following this 2


### agenda review, there is an opp ortunity for anyone 3


### that wishes to, to make opening remarks, brief 4


### summary comments about issues that matter to you. 5


### Following that, there is some housekeeping items. 6


### Immediately following that, we'll go into the 7


### rulemaking process overview, and then on to 8


### authority and definitions. 9


### This agenda lists a coffee break around 10



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


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



### break. When we return from the break or whenever 13


### we get there, test procedure and test metrics, 14


### and then following on, market technology 15


### assessments, screening and analysis, from there 16


### engineering analysis. 17



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


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


### how long this material

-- we' ll be efficient as 20


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


### or 12:30 and we're getting close to the end, 229

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### we'll probably just push on through and finish 1


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


### end up. 3


### As reflected in the agenda, we will 4



### continue on with mark ups in energy and water use 5


### analysis, then life cycle costs and payback 6


### period analysis. We'll take a break 7


### midafternoon, as needed. Then shipments 8


### analysis, national impact analysis, preliminary 9


### manufacturing impact analysis, NOPR analyses, 10


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


### another opportunity for individuals, anybody that 12


### wishes to, to make final comments, any other 13


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


### handled or covered sufficiently during the course 15


### of this meeting. 16



### And, of cours e, you will get plenty of 17



### information about how to submit written comments. 18


### The Department likes to see copious, detailed 19


### written comments on all these matters, and that 20


### is really important to them. 21


### And if you look back on page 2 of your 2210

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### packet, there's some simple ground rules there 1


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


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


### the record each time you speak. 4


### There will be a complete transcript of 5


### this meeting made available, and we'll describe 6


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


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


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


### already, and limit your sidebar conversations. 10


### Everyone has gotten used to using these 11


### microphones already. 12


### Webinar partici pants, we welcome you. 13


### The Department of Energy is trying hard to make 14


### these meetings totally accessible to those via 15


### the Web. The software has been working well 16


### recently in our experience. Please keep your 17


### telephone on mute. You can raise your hand us ing 18


### the software program to be recognized to speak, 19


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


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


### phone, and we ought to be able to hear you in the 2211

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### room. And if not, we will find a way to get your 1



### voice into this conversation. We will write down 2



### notes and read them into the record here. 3


### Those of you that are joining us online, 4


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


### are joining us remotely doesn't mean that you 6


### should skip sending in detailed written comments. 7


### Please make sure that everyone

-- the Department 8


### really benefits from all the written comments 9


### they receive in these matters. 10


### So, as reflected in the agenda, I welcome 11


### now any opening remarks, any brief summary 12



### statements here at the ou tset about issues that 13


### are important to you. 14


### We just missed you as you came in the 15


### door. Would you say your name and organizational 16



### affiliation. You can use

-- 17



### MS. SALMON: Sure. 18



### MR. BROOKMAN: Yes. 19


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


### Plumbing M anufacturers International. 21


### MR. BROOKMAN: Is that thing on? Say it 2212

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### again. 1


### MS. SALMON: Stephanie Salmon with 2


### Plumbing Manufacturers International. Good 3


### morning. 4


### MR. BROOKMAN: Thank you. Good morning. 5


### Does anybody wish to make an opening 6



### statement? 7


### [No audible response.] 8


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


### point. 10


### So then we're going to go to some 11


### housekeeping items with Jim Raba first. 12


### Those joining us via the Web, I think I 13


### have covered all the material on Slide 7, and 14


### once again, as it s ays, the last bullet provided 15


### on Slide 7, all stakeholders are encouraged to 16


### submit written comments after the public meeting. 17



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


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



### Raba. 20


### For openers, today's public meeting will 21


### address the procedural and analytica l framework, 2213

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### models, and other analysis tools that the 1


### Department of Energy would use to evaluate 2


### efficiency standards for this equipment. 3


### As you move forward today, we encourage 4


### you to consider and discuss the process and 5


### approach the Department intends to take. 6


### Throughout the rulemaking process, we encourage 7


### you and other interested parties to submit 8


### comments, pertinent information, and data. 9


### Before we address the regulatory history, 10


### steps and the standards in the r ulemaking 11


### process, market and technology assessment, the 12


### engineering analysis, life cycle cost analysis, 13


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



### you. 15


### During today's presentations, certain 16


### issues will be prompted for discussion on slides, 17



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


### about any part of the presentation are welcome 19


### throughout. 20


### Please note that the comment period 21


### closes October 27th. You may submit comments by 2214

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### e
- mail, postal mail, courier. Please include the 1



### docket number and r egulation identifier number to 2



### comments. 3


### So we look forward to hearing from you 4


### today. 5


### Rulemaking Process Overview 6


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


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


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



### firs t from Jennifer Williamson. 10


### MS. WILLIAMSON: Good morning, everyone. 11


### My name is Jennifer Williamson. I am with the 12


### Pacific Northwest National Laboratory. I am 13


### going to walk us through this process overview 14


### for rulemaking and then talk about some 15



### defini tions, as well as the test procedures that 16


### are relevant to commercial prerinse spray valves. 17


### So, first of all, the Energy Policy and 18


### Conservation Act, or EPCA, of 1975 established 19


### the Energy Conservation Program for consumer 20


### products, and that includes co mmercial prerinse 21


### spray valves. 2215

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### EPCA directs DOE to develop new or 1


### amended standards that are designed to achieve 2


### maximum improvement in energy

-- or water, in 3



### this case

-- efficiency that is technologically 4


### feasible and economically justified. 5



### EPCA also requires that not later than 6 6


### years after the issuance of a F inal R ule 7


### establishing a standard, that DOE publish either 8


### a Notice of Proposed Rulemaking for a new 9



### standard or a determination that a new standard 10


### is not required. 11



### The last F inal R ule for th is product was 12


### actually part of EPAct 2005, and the F inal R ule 13


### was in October of 2005 that just codified those 14


### requirements into the CFR . At that time, the 15


### maximum flow rate for these products was set at 16


### 1.6 gallons per minute

. 17



### So EPCA directs DOE to con sider seven 18


### separate factors for analysis when setting 19


### standards to verify that they are technologically 20


### feasible and economically justifiable. 21


### This table, the left hand shows the 2216

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### factor that EPCA presents. The right

- hand column 1


### is the analysis that DOE performs in order to 2


### meet that requirement. Each of these analyses 3



### will be discussed in further detail later on. 4


### So this is moving into the overall 5


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


### Energy Conservation Standard, which has four 7



### steps, sta rting with the framework, preliminary 8


### analysis, NOPR, and Final Rule. A test 9


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


### have a NOPR and a Final Rule. Test procedures 11


### and conservation standards do not always run 12


### concurrently; however, the Department expects 13


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


### parallel with the standards rulemaking. 15



### This rule is also on a bit of an 16


### accelerated schedule, so we expect that the 17


### conservation standard rulemaking will take about 18


### 2 years, and the test procedure wi ll take about a 19


### year and a half. 20


### The Web address on the bottom is just the 21


### Appliance and Commercial Standards Home Page, 2217

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### which will take you to any information about both 1


### this rule, any other rules, processes that the 2



### Department uses. 3



### So the framework do cument, which 4


### hopefully you have seen, is accompanied by a 5


### Federal Register Notice of Public Meeting. It 6


### gives the details about today's meeting, 7



### announces that the framework document is 8


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


### you to submit your comments. 10


### The framework itself was posted on 11


### September 8th at this website. The accompanying 12


### NOPM was published on September 11th. 13


### The preliminary analysis is the first 14


### step where we actually have some data to share 15


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


### provides the notice of the public meeting with 17


### its details and the availability of the 18


### preliminary analysis, technical support document, 19


### or TSD. We will also be addressing any comments 20


### that we receive from all of you today. 21


### The analyses listed on the bottom are the 2218

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### analyses that will be included in the preliminary 1


### analysis, TSD. As we move through the process 2


### into the NOPR and the Final Rule, these analyses 3


### will be updated, and additional analyses will be 4


### performed. 5


### So the NOPR phase again, Fede ral Register 6


### publication, public meeting, a revised TSD with 7


### everything that was in the preliminary analysis, 8


### as well as these additional analyses that will 9


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


### what everybody here probably really cares about, 11



### w hich is the standard that DOE is proposing to 12


### set for these products. 13


### Then the Final Rule, that Federal 14


### Register publication announces the availability 15


### of the final TSD. It addresses any comments we 16


### received in response to the proposed standard. 17



### It pres ents the standard level that DOE is 18


### adopting, along with the compliance date for 19



### those standards. 20


### This is just an overview of each of those 21


### steps on a timeline with the dates that the 2219

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### Department expects each of these pieces of 1


### information will be publishe d. 2


### Authority and Definitions 3


### MS. WILLIAMSON: Authority and 4



### Definitions. 5


### Authority and background. Title III of 6


### the Energy Policy and Conservation Act set forth 7


### a variety of a provisions designed to improve 8


### energy efficiency

-- in this case, water 9



### effic iency

-- of various products and equipment. 10


### Part B of Title III provides for the 11


### Energy Conservation Program for Consumer Products 12



### Other than Automobiles. 13


### The Energy Policy Act of 2005, or EPAct 14



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



### states that com mercial prerinse spray valves 16


### manufactured on or after January 1, 2006, shall 17


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



### minute. 19


### Scope of coverage. The current 20



### definition contained in EPCA of a commercial 21


### prerinse spray valve is, "A handheld devic e 2220

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### designed and marketed for use with commercial 1


### dishwashing and ware

- washing equipment that 2


### sprays water on dishes, flatware, and other food 3


### service items for the purpose of removing food 4


### residue before cleaning the items." 5


### DOE is considering modification s to this 6


### definition if they are necessary to clarify the 7


### scope of coverage. 8


### So before we start talking about what we 9


### might do to modify the definition, this language 10


### is also included in EPCA, which provides the 11


### authority, the limited authority that we ha ve to 12


### change the definition. 13


### So, in general, we can include products 14


### that are extensively used in conjunction with 15


### commercial dishwashing and ware

- washing 16


### equipment. We can change it if the standards 17


### applied to those products would result in 18


### significant energy savings, or if the application 19


### of standards meets the criteria specified in 20


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


### standards cannot be prescribed if they will 2221

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### remove products from the market that were 1


### previously available. 2


### Excluded products ar e those that are used 3


### for specialty food service applications, those 4


### that are unlikely to be used in conjunction with 5


### commercial dishwashing and ware

- washing 6


### equipment, and products that when the standards 7


### are applied to them would not result in 8


### significan t energy savings. 9


### So, at this point, DOE requests comment 10


### on modifications to the definition that may 11


### clarify what equipment is covered. 12


### What we are looking for here is if anyone 13


### has some specific examples of equipment that they 14



### know is used in commercia l kitchens that may not 15



### fit into the definition that we have here. 16


### MR. BROOKMAN: This is really quite 17


### fundamental. If you can see ways to improve the 18



### definition or make the definition more consistent 19


### with scope in the actual application, then that 20



### would be good. 21


### [No audible response.] 2222

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### MR. BROOKMAN: Okay. I see none at this 1



### time. 2



### Test Procedure and Test Metrics 3


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



### move on to the metric. 5


### As part of this rulemaking, DOE may 6


### consider adopting an alternative metric to the 7



### current flow rate (gpm) metric. DOE will 8


### consider alternatives that achieve energy and 9


### water savings and preserve equipment utility. 10


### Two possible metrics that could be 11


### considered are a performance metric that accounts 12


### for both flow rate and spray fo rce or a metric 13


### that directly correlates water use to the time 14


### taken to clean a dish measured in gallons per 15


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


### potential metrics other than flow rate that may 17


### be used to achieve greater water savings in 18



### comme rcial prerinse spray valves, and if there is 19


### sufficient benefit to using an alternative metric 20


### to justify changing from the current flow rate 21


### metric of gpm. 2223

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### MR. BROOKMAN: Please. Ed Osa n n. 1



### MR. OSA N N: Yeah. Hi. 2



### This is a comment in the form of a 3



### ques tion, and that is, would the revision to the 4


### metric require a change in the test procedure, or 5


### could either of these possible metrics be 6


### accounted for under the current test procedure? 7


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


### there next. We're going to tal k about the test 9


### procedure next. 10



### MR. OSA N N: Okay. 11



### MS. WILLIAMSON: And at that time, we 12



### will invite comment on whether or not the test 13


### procedure is needed to support a potential new 14



### metric. 15


### MR. BROOKMAN: Stephanie. 16


### MS. TANNER: Can I just go back a l ittle 17



### bit? 18



### MR. BROOKMAN: Yes. 19



### MS. TANNER: You mentioned that this 20


### process was on an accelerated timeline, and I 21


### guess I wondered why or what was driving it to be 2224

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### on an accelerated timeline versus the standard 1



### timeline. 2


### MR. CYMBALSKY: This is John Cym balsky 3



### from DOE. 4


### So the general timeline for standards is 5


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


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


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


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


### but obviously, this process has its obstacles, 10


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


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



### to stick to it. 13


### MS. TANNER: Okay. 14


### MR. BROOKMAN: The question there in item 15



### 1

- 2 is about metrics and alterna tives to the 16


### current metrics or additions, enhancements. Any 17


### thoughts on that? 18


### [No audible response.] 19


### MR. BROOKMAN: Okay, nothing at this 20



### time. 21


### MS. WILLIAMSON: So moving on to the test 2225

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### procedure. Currently, EPCA specifies that the 1


### test procedure for measuring flow rate in gpm for 2


### commercial prerinse spray vales shall be based on 3



### ASTM Standard F2324, "Standard Test Method for 4


### Prerinse Spray Valves." 5


### In October of 2013, DOE published a final 6


### rule that incorporated by reference the test 7


### procedure speci fied in ASTM Standard F2324, the 8



### 2003 version, reaffirmed in 2009. So there were 9


### no technical changes. It was just to update to 10



### the most current version of the ASTM standard. 11


### Although the ASTM Standard includes a 12


### test for qualitative cleanability, that was not 13


### incorporated by reference into DOE's test 14


### procedure. We are only using it to measure flow 15



### rate. 16


### Since that publication of DOE's 2013 test 17


### procedure, ASTM has issued a new standard, the 18


### 2013 version of F2324, to reflect some changes in 19



### the industr y. The primary change to the ASTM 20


### test procedure was to replace the cleanability 21


### test, which was removed to an appendix, with a 2226

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### spray force test. 1


### The cleanability test, just a little 2


### overview, evaluates the cleaning time of a 3


### standard dinner plate measur ed in seconds per 4


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


### measures the amount of force exerted by the flow 6


### of water measured in ounces of force, and while 7


### these changes don't impact the energy or water 8


### use measurement of the DOE test procedure, they 9



### co uld be used as a way to establish equipment 10



### classes. 11


### So, at this time, DOE requests comment on 12


### the potential use of ASTM F2324, the 2013 13


### version, as the method of test for measuring 14


### water consumption. 15



### MR. BROOKMAN: One of the individuals 16


### joining us onli ne, Joanna Mauer, requests to make 17



### a comment or ask a question

. 18


### Joanna, unmute your phone, and hopefully, 19


### we'll hear you in the room. 20



### MS. MAUER: Thanks. 21


### You mentioned that one potential 2227

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### alternative metric would account for both flow 1


### rate and spray forc e. I was just wondering if 2


### you could provide any more detail about what that 3


### metric might look like. 4


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


### colleagues that are looking into the metric 6



### further. 7



### MR. BROOKMAN: Yes. Aris Marantan. 8



### MR. MARANTAN: Yes. This is Aris 9


### Marantan, Navigant Consulting. 10


### We have been investigating possible other 11


### metrics, including spray force, and one of them 12


### that we have considered is gpm divided by spray 13


### force. So while that's slightly different than 14


### the normal gpm, we do ha ve to consider keeping 15


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


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


### the backsliding provision, so that's one that 18



### we've

-- 19


### MS. MAUER: Thank you. 20



### MR. MARANTAN:

-- considered. 21


### MR. BROOKMAN: Okay. Thank you, Joanna. 2228

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### You see the comment box there, 1.3, 1


### related to test procedure updates. Any 2


### additional comments emerging from this request? 3


### [No audible response.] 4


### MR. BROOKMAN: Okay. 5


### MS. WILLIAMSON: All right. I am going 6



### to turn it over to Mythri. 7



### Rulemaki ng Analyses 8


### MS. KUMAR: Thank you, Jennifer. 9


### Good morning. My name is Mythri Kumar, 10


### and I work for Navigant Consulting, and today I 11


### will be presenting the market and technology 12


### assessment, screening analysis, engineering 13


### analysis, and the preliminary ma nufacturer impact 14


### analyses. 15


### So the first analysis that we undertake 16


### for the preliminary rulemaking analysis is the 17


### market and technology assessment. 18


### The purpose of the market and technology 19



### assessment is to characterize the commercial 20


### prerinse spray valv e market and the technologies 21


### that improve efficiency. 2229

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### So, to do this, DOE looks into commercial 1


### prerinse spray valve manufacturers, trade 2



### associations, retailers, and then also estimate s 3


### shipments and market trends. DOE then uses this 4



### information to det ermine equipment classes and 5


### technology options that c ould improve the 6


### efficiency of commercial prerinse spry valves. 7


### For this rulemaking, improving efficiency 8



### would mean a reduction of water consumption or 9



### water use. 10


### So based on the initial research, DO E has 11


### identified two main trade groups. The first is 12


### Plumbing Manufacturers International, PMI, is a 13


### primary trade organization that supports and has 14


### an interest in commercial prerinse spray valves. 15



### The second is North American Association 16


### of Food Equipm ent Manufacturers. It is a trade 17


### association of over 500 food service equipment 18


### manufacturers and is another organization that 19


### may be interested in commercial prerinse spray 20



### valves. 21


### In terms of the retailers, DOE has 2230

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### identified three main categories. Th e first is 1


### brick and mortar retailers, which include mass 2


### market retailers, specialty stores, club or 3


### warehouse stores, Internet sellers, and the third 4



### is showrooms. 5


### So, at this point, DOE requests comment 6


### on item 3.3. DOE seeks information regarding any 7


### other trade organizations that represent the 8


### commercial prerinse spray valve industry. 9



### MR. BROOKMAN: Is that the list? 10


### [Laughter.] 11



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



### Brass. 13


### You may want to look at NRA. National 14



### Restaurant Association would have interest in 15


### this rulemaking process, as well. 16


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


### MS. KUMAR: Thank you. 18


### MR. BROOKMAN: Yes. And your name, 19


### please? 20



### MR. HANS E N: Da in Hans e n. 21


### Are you looking just for organizations 2231

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### that represent like trade associations o r any 1


### organization that has an interest in this. 2



### MS. KUMAR: Both. 3



### MR. HANSEN: Both? 4



### MS. KUMAR: Yes. 5


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


### of industries in the plumbing industry that would 7



### be interested. I mean ourselves

-- 8


### MS. KUMAR: Okay. 9



### M R. HANSEN:

-- the International 10


### Association of Plumbing and Mechanical Officials, 11


### we test and certify the products to make sure 12


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


### long list of certification bodies and also

-- I 14


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


### environmental groups, as well, that have an 16



### interest there. 17



### MS. KUMAR: Sure. 18


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


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


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


### organizations or true

-- any interested 2232

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### organization in the industry. 1


### MS. KUMAR: Thank you so much. 2



### MR. BROOKMAN: Thank s, Dain

. 3



### Additional comments? 4


### [No audible response.] 5


### MR. BROOKMAN: Okay. 6


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


### identified 49 basic models of commercial prerinse 8



### spray valves available in the market. These 9


### basic models were found using the DOE Compliance 10


### Certification Management System

-- CCMS

-- 11


### database, the EPA WaterSense product database, 12


### manufacturer websites, and Web searches. 13


### So this graphic in this slide provid es 14


### the estimated percentages of basic models by 15


### manufacturers in the U.S. market currently. 16


### Doug, I would like to pause here to just 17


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


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


### looking at basic models here, n ot all models that 20


### are available in the market. And are there any 21



### manufacturers that we have missed out? 2233

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### MR. BROOKMAN: Jeff. 1


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



### Is this s uppos ed to represent potential 3


### market share or strictly basic model numbers? 4



### There is a drastic difference in how these 5



### manufacturers would list their basic models. I 6


### would hate for this pie chart to be turned into 7


### an assumption of market share, which is 8


### drastically different than this pie chart shows. 9


### MS. KUMAR: Yes. This is j ust basic 10


### models. This is not necessarily talking about 11


### market share. We would like to get that 12


### information also, but this is just based on 13



### information that we found on the CCMS database 14


### and the WaterSense product database and Web 15



### searches. 16


### So if you do have more information on 17


### market shares, we would appreciate you providing 18


### us either written comments or in general comments 19



### about it. 20


### MR. BROOKMAN: However, for today's 21


### purposes, we would appreciate any additional 2234

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### comments on manufacturers who are missi ng from 1



### this list. 2


### [No audible response.] 3


### MR. BROOKMAN: Nothing additional at this 4


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



### written comments, as well. 6


### Okay. 7


### MS. KUMAR: Thank you. 8


### MR. OSANN: I have a question. 9



### MR. BROOKMAN: Ed Osann. 10



### MR. OSA NN: Yeah. Is this intended to 11


### encompass imported products, as well? 12


### MS. KUMAR: This is just U.S.

- based 13



### manufacturers. 14


### MS. TANNER: This is Stephanie Salmon 15


### with Plumbing Manufacturers. 16


### Are you going to be looking at the import 17


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



### -- 19


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


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


### but I can defer to one of my colleagues here. 2235

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### MR. BROOKMAN: Aris. 1



### MR. MARANTAN: This is Aris Marantan. 2



### Yeah. I think we would like t hat 3


### information, as well. Any information that you 4


### have on domestic manufacturers or foreign 5



### manufacturers, we will consider that in the 6


### analysis. 7


### MR. BROOKMAN: Foreign manufacturers that 8


### import product into the U.S.? 9


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



### MR. BROOKMAN: Yes. 11



### MR. BALDWIN: What we have seen is a 12


### general lack of enforcement of this requirement 13



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


### reporting basis. So what you see here on this 15


### list are manufacturers who do that due diligence 16



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


### the imported products that we compete against 18


### every day that are either inferior quality, 19


### inferior performance, and do not follow the 20


### federal regulations reporting to the CCMS. So 21



### we'll make sure this is fair to all participants, 2236

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### and there is a chunk of import products that 1


### should be addressed during this process. 2


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


### Jeff speaking, and, Jeff, that provides an 4


### incentive for both you and your colleagues to 5


### provide a detailed l isting of that to the 6


### Department of Energy. 7


### Okay. 8


### MS. KUMAR: Thank you. 9



### MR. BROOKMAN: Additional comments here 10



### before we move on? 11


### [No audible response.] 12


### MR. BROOKMAN: Okay. 13


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


### of the market and technology ass essment is the 15


### establishment of equipment classes, each of which 16


### is subject to its own standard. As directed by 17


### EPCA, DOE establishes different equipment classes 18



### based on three main criteria. The first is the 19


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


### the product, and the third, any other 21


### performance

- related features that require 2237

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### different standard levels, such as features 1


### affecting customer utility. 2


### Currently, all commercial prerinse spray 3


### valves are included in a single equipment class, 4


### subject t o a maximum flow of 1.6 gpm. So for 5


### this rulemaking, DOE will examine whether any of 6


### the following characteristics could be used to 7


### establish equipment classes. 8


### The first is flow rate in terms of gpm; 9


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



### thi rd is cleanability time in terms of seconds 11


### per plate. The fourth is design of flow control 12


### insert, and the fifth is other equipment features 13


### that change functionality; for example, spray 14



### patterns. 15


### At this point, we are keeping flow rate 16


### and design of fl ow control insert in the list of 17


### equipment classes in case we change the metric to 18


### something other than flow rate. 19


### So the possibilities listed here for 20


### equipment classes could also be used as 21


### technology options to improve efficiency and vice 2238

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### versa. So th e preliminary analysis will actually 1


### analyze this and determine whether these 2


### possibilities are better suited as equipment 3


### classes or technology options. 4


### So at this point, DOE has several items 5



### for comment. Item 3

- 8, DOE requests input from 6


### interested pa rties about the design 7


### characteristics and criteria that are being 8


### considered to create equipment classes. In 9


### particular, do other performance

- related features 10


### warrant separate standard levels? 11



### Item 3

- 9, DOE seeks comment on whether 12


### spray force or cleana bility are useful 13


### characteristics that could define the equipment 14


### classes of a prerinse spray valve. 15



### Item 3

- 10, DOE requests comment on how 16



### ultra

- low flow spray valves differ from other 17


### spray valves in usage, functionality, features, 18


### and cleaning ability. 19



### MR. BROOKMAN: Ed Osann. 20



### MR. OSANN: Ed Osann with NRDC. 21



### It would seem that if the metric does not 2239

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### change, then holding out flow rate as a potential 1


### differentiator for equipment classes would seem 2



### to be kind of

-- almost kind of an oxymoron, 3


### right? Ki nd of inconsistent with that approach. 4



### MS. KUMAR: Sure. Yeah, that makes 5



### sense. 6



### MR. BROOKMAN: You can see those three 7


### requests for comment there. Please take a peek. 8


### In particular, I am looking at 3

- 10, 9



### ultra

- low flow spray valves, how they differ f rom 10


### other spray valves and usage functionality 11


### features and cleaning ability. That strikes me 12



### as sort of an inside

- baseball comment that we 13


### might get here. 14



### Jeff. 15



### MR. BALDWIN: We will offer further 16


### comments on this, but you should recognize there 17



### are a lot of different applications in the food 18


### service industry and not all of them require the 19


### amount of spray force that we have on other 20


### products. 21


### Only speaking for T&S here, we offer a 2240

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### myriad of prerinse spray valves that fall under 1


### the current 1.6 gpm def inition, but there is a 2


### vast array of applications and options and 3


### different design features based upon the end 4


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



### clients, our customers, to determine those 6


### applications to recommend product, instead of a 7



### one
- size

- fits

- all mentality. 8


### MR. BROOKMAN: Thank you. 9



### Yes. 10



### MR. MORRIS: This is Scott Morris at 11



### PNNL. 12


### Jeff, I know you are going to offer more 13


### comments, written comments. Could you give us an 14


### example of a couple applications at this time, 15


### just a few? 16



### M R. BALDWIN: Variations of applications 17


### could range from rinse and off

- baked product. 18


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


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


### creations of the original ASTM F2324

- 2003 test 21


### protocol, was based on kind of that rugged, 2241

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### heavy

- duty, more

-- you know, needing more of a 1


### cleaning force, cleaning from the current spray 2


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


### The other end of the spectrum could be 4


### they are merely rinsing off something that's 5


### already basic ally clean, but they're just doing a 6


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


### could be just a tray that a fast food restaurant 8


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


### washing off maybe some stray ketchup or some salt 10


### or pepper that somebody had o n that tray. 11


### So you have to be very careful and not 12


### narrow it down to one type product, because you 13


### may not want that amount of spray force if you 14


### are washing something like a fast food tray, and 15


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



### thousands in between there. 17


### MR. MORRIS: Thank you very much. 18



### MR. BROOKMAN: Additional comments on 19



### these three items? 20


### [No audible response.] 21


### MR. BROOKMAN: Okay. 2242

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### MS. KUMAR: So, next, we go to technology 1


### options. As mentioned previously, technology 2


### options are used to improve the efficiency of the 3


### product, which for commercial prerinse spray 4


### valves would be technology options that reduce 5


### water consumption or water use. 6


### At this time, DOE is considering the 7


### following technology options to improve 8


### efficiency. 9



### The first is the addition of a flow 10



### control insert. The second is a smaller nozzle 11


### tip opening. The third is incorporation of 12


### additional components; for example, backflow 13


### preventers or additional valves or hoses. And 14


### fourth is specially designed spray patt erns; for 15


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


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


### provides more details on these different spray 18



### patterns. 19


### The cone spray pattern is what we 20



### describe as a nozzle with a hollow or solid cone 21



### spray with a variety of cone angles. We've also 2243

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### known it is called a "fan spray pattern," and you 1


### can see the images on this slide. 2


### The solid stream spray pattern is a 3


### nozzle with a single solid jet stream. 4


### The triple solid stream is a nozzle with 5


### three spra y holes, each with solid jet streams, 6


### also called "triple action" or "tri

- tip." 7


### The flat fan is a nozzle producing flat 8


### fan jet streams at various angles, also called as 9



### a "knife

- like pattern." 10


### And the shower is a spray face with 11


### multiple spray holes, re sembling a common 12


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


### pattern." 14



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


### item, item 3

- 12. DOE seeks information on what 16


### technology options are av ailable to improve the 17


### performance of commercial prerinse spray v alves. 18



### MR. BROOKMAN: Jeff. 19


### MR. BALDWIN: I'm the only manufacturer 20


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


### lot, I feel like. 2244

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### I'd caution to make sure we don't try to 1


### put too many design restrictions on the products, 2



### because I have mentioned the myriad of 3


### applications we have to deal with. Depending on 4


### the application, any one of these technologies 5


### could be what was required for that application, 6


### or it could be another technology that may not 7


### even be developed yet or could be in process of 8


### being developed. 9


### So I would hate for this rulemaking 10


### process to turn into a design

- restrictive 11


### performance requirement that says you can only 12


### have spray valves with these following two design 13



### characteristics. I would make sure we were not 14


### limiting ourself, bec ause we will stifle 15



### innovation if we do find ourselves in that corner 16


### of only having certain types of products. 17


### MR. BROOKMAN: Okay, thank you. 18


### Are there, nevertheless, technology 19


### options not listed that the Department should 20



### consider? 21



### MR. BALDWIN: You 're reaching into a 2245

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### realm of proprietary information at that point, 1



### and so

-- 2


### MR. BROOKMAN: Okay. Well, we understand 3


### that. Okay, got it. 4


### Additional thoughts, comments here? 5



### Yes, Aris. 6



### MR. MARANTAN: This is Aris Marantan. 7



### Just a follow

- up question . Thank you, 8


### Jeff, for providing that information. Is there 9


### anything on the list on Slide 35 that you 10


### wouldn't consider as an option that would improve 11


### water consumption? 12


### MR. BALDWIN: The bullet point that says 13


### "incorporation of additional components," I'm 14


### curious, kind of the origin of that bullet point 15


### and how those products shown as example there 16


### would have any effect on conservation of water 17



### energy. 18


### These types of products get mixed with a 19


### myriad of other products, just in the normal 20



### realm of the a pplication, whether it's a spray 21


### valve on a prerinse unit or other types of myriad 2246

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### of applications there. So I'm not sure how that 1


### bullet point would lead to improved efficiency. 2


### MR. BROOKMAN: Thank you. 3



### MS. KUMAR: Thanks. 4


### MR. MARANTAN: Thank you. 5


### MS. KUMAR: Okay. So the next analysis 6


### that we will be looking at is the screening 7


### analysis. 8


### MR. OSANN: Before we leave this point

-- 9



### MR. BROOKMAN: Ed Osann. 10


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


### Presumably, these examples of spray 12


### patterns and their associated nozzles are 13


### nonproprietary or available for multiple

-- 14



### MS. KUMAR: Correct. 15



### MR. OSANN:

-- sources, and the 16


### information that you are seeking would be for 17



### other non

- proprietary options; is that right? 18


### MS. KUMAR: Right. Mm

- hmm. 19



### MR. OSANN: Okay. 20


### MS. KUMAR: Sure. Okay. 21


### So the purpose of the screening analysis 2247

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### is to screen out the technology options that DOE 1


### will not consider in the engineering analysis for 2


### commercial prerinse spray valves. 3


### DOE will screen out technology options 4



### based on four main criteria. The first is 5


### technological feasibility, which means whether 6


### it's incorporated in commercially available 7


### products or in working prototypes. The second is 8


### practicability to manufacture, install, and 9


### service, where it should be possible to achieve 10


### mass production and reliable installation and 11


### servicing. The third is adverse impacts on 12


### product utility or availability to customers, and 13


### the fourth is adverse impact on health and 14


### safety. 15


### The technology options that are not 16



### screened out in t he screening analysis will be 17


### adopted as design options in the engineering 18


### analysis. 19


### The next analysis that we will be looking 20


### at is the engineering analysis. 21


### The purpose of the engineering analysis 2248

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### is to determine the relationship between cost and 1



### effic iency. For our analysis, efficiency would 2


### be water use or water consumption. Typically, 3


### what we see in a rulemaking is that as the 4


### efficiency improves or water use decreases, the 5


### cost of producing the product increases, as shown 6


### on the figure in this sli de. 7


### The results from the engineering analysis 8



### are then later used as a basis for the life

- cycle 9


### cost, payback period, and national impact 10


### analyses, which will be discussed further on in 11


### this presentation. 12


### So this slide gives more detail on the 13


### steps need ed to conduct the engineering analysis 14


### for commercial prerinse spray valves. 15


### First, we choose representative equipment 16


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


### to be an overwhelming amount of equipment classes 18


### for this rulemaking, we expect to be a nalyzing 19


### all equipment classes. 20



### The second, we select the baseline 21


### efficiency level. Since there is a current 2249

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### standard for commercial prerinse spray valves, 1


### the baseline efficiency level would be that 2


### standard which is 1.6 gpm. 3


### The third is to identify higher 4


### efficiency units. For all equipment classes, DOE 5


### identifies efficiency and cost of more efficient 6


### units based on a combination of design option 7


### modeling, product testing, and teardowns. DOE 8


### then identifies the maximum technologically 9



### feasible leve l, or what we call the "max

- tech," 10


### for each equipment class. This provides the 11


### upper bound for the efficiency. 12


### Fourth, we develop efficiency levels for 13


### the analyses. The efficiency levels are 14


### developed, so that they range from the baseline 15


### all the way t o the max

- tech for all equipment 16


### classes. The levels are determined by 17


### implementing the screened

- in design options to 18


### improve spray valve efficiency from baseline to 19



### max
- tech. 20



### And then fifth, we determine the 21



### cost

- efficiency relationship. The end result for 2250

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### the engineering analysis is a set of 1



### cost

- efficiency curves for all equipment classes, 2


### and this takes the form of manufacturer's selling 3


### price versus efficiency. 4



### The baseline models are selected based on 5


### common features and minimally compliant equipm ent 6


### efficiency. Since there is a current standard 7


### for commercial prerinse spray valves, the 8


### baseline efficiency would be the current 9


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


### as mentioned previously, DOE is considering an 11


### alternative efficiency metr ic other than gpm. If 12


### another efficiency metric is chosen, the baseline 13


### efficiency with this new metric should 14


### incorporate the current standard of 1.6 gpm, so 15


### as to prevent backsliding. 16


### At this point, DOE seeks an item for 17



### comment. DOE seeks information regarding the 18


### specific technological characteristics of 19



### baseline models. 20



### [Pause.] 21


### MR. BROOKMAN: No comment here. Okay, 2251

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### okay. 1


### MS. KUMAR: As described previously, DOE 2


### will identify the highest efficiency model in the 3


### market, which is the max

- tech for each class. 4


### Based on initial research, DOE has identified the 5



### current max

- tech as a commercial prerinse spray 6



### valve with a max flow of 0.64 gpm. 7


### At this point, I would want to ask a 8


### question whether there are any other commercial 9


### prerinse spray valves th at have an even lower 10


### water consumption rate than the identified 11



### max
- tech. 12



### MR. BROOKMAN: Jeff. 13


### MR. BALDWIN: I would caution in picking 14


### the highest efficiency model based on flow rate 15


### only. There are inferior products on the market 16



### that have an extreme ly low flow rate but have an 17


### unsatisfactory user rating, and we have learned 18


### that quite frequently through the WaterSense 19


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


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


### flow rate when you're trying to tal k about 2252

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### max
- tech only. 1



### MS. KUMAR: I have a follow

- up question. 2


### So what other characteristics would you consider 3



### for a max

- tech model? 4


### MR. BALDWIN: You really need to look at 5


### the application, but, I mean, forced

- spray force 6


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


### got to look at the application. 8


### What you're defining as max

- tech, if you 9


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


### may work for certain applications, but it may 11


### work very poorly for the baseline or what you 12



### would call a "standar d market application." 13


### MS. KUMAR: Okay, thank you. 14



### MR. BROOKMAN: Scott. 15



### MR. MORRIS: This is Scott Morris from 16



### PNNL. 17


### Jeff, you had mentioned earlier about

-- 18


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


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


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


### useful if in your written comments, you could 2253

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### provide information such as perhaps what flow 1


### rates, for example, are typical in which 2


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


### possible to provide t hat type of information. I 4


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


### would be very helpful. 6


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


### and it's also a lot of proprietary research 8


### that's been taking place with our customers over 9


### 65 years of making spray va lves. It's not 10


### something that T&S as a family

- owned company 11


### would put into comments, unfortunately. 12


### We may offer some of that information 13


### through our NDA that we are working on with 14


### Navigant, but we would not offer that in our 15


### public comments. 16



### MR. MORRI S: Thank you. 17


### MR. BROOKMAN: I was wondering if there 18


### was kind of a nomenclature that has emerged among 19



### the

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



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


### something like that. 2254

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### MR. BALDWIN: Right now, you rea lly have 1


### basically what we would consider as four classes 2


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


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


### prerinse. It may look like a prerinse spray 5


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


### may be for a myriad of applications, including 7



### wash

- down of walls or floors or a trash bin 8


### receptacle, but it looks like a prerinse spray 9


### valve, so a lot of people call them "high

- flow 10


### prerinse spray valves." They are not really for 11


### prerinsing. That is one class. 12



### A nd there's a lot of confusion in the 13


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


### the DOE on some of the interpretations or 15


### clarifications there with legal counsel on the 16



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


### [Laughter.] 18



### MR. BALDWIN: The next cl ass would be 19


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


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


### federal regulation today. 2255

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### Then we have the voluntary measure t hat 1


### was just released here in recent months and has 2


### been growing a little bit of stea m. It is 3


### WaterSense, which is 1 .2 8 gpm. 4



### And then we have what we would call 5



### "ultra

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


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


### or which program that you're dealing with. 8


### Usually, it's about a 50 percent reducti on, so it 9



### would be like at a 0 .8 level. That's not a fixed 10


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



### about ultra

- low flow. 12


### And that terminology is the market 13


### terminology. As a manufacturer, we hate to hear 14



### ultra

- low flow, because in the market, pe ople 15



### think that means ultra

- low performance, and so we 16


### have to be very careful when we talk about high 17


### efficiency or low efficiency or low flow or high 18


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


### misnomer into the marketplace. 20


### MR. BROOKMAN: Okay. T hanks a lot. That 21


### was helpful. 2256

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### Additional comments here? 1


### [No audible response.] 2


### MR. BROOKMAN: Okay. 3


### MS. KUMAR: Thank you. 4


### So then DOE will analyze the costs 5


### associated with implementing the screened

- in 6


### design options to improve spray valve efficien cy 7


### from baseline efficiency to max

- tech. 8


### Currently, the design options that DOE is 9


### tentatively considering include the addition of a 10


### flow control insert, smaller nozzle tip openings, 11


### incorporation of additional components, and 12


### specially designed spray pat terns, which are the 13


### technology options that I previously described. 14


### The design options currently being 15



### considered could have characteristics to warrant 16


### them as equipment classes and vice versa, and 17


### that will be analyzed in the preliminary 18


### analysis. Howe ver, they will be used in one or 19


### the other, either as a design option or an 20


### equipment class, and not in both. 21


### The final result of the engineering 2257

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### analysis is a cost

- efficiency relationship. To 1


### determine the costs for this relationship, DOE 2


### will develop a cost model that converts the bill 3


### of materials for both baseline and higher 4


### efficiency units into manufacturer production 5



### costs. 6


### The component cost for the design options 7


### are determined using a combination of reverse 8


### engineering, which are product teardo wns, and 9


### manufacturer feedback, which would be through 10


### engineering interviews. 11


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


### back and mention the engineering interviews. 13


### This is actually the next step in the rulemaking 14


### for us, and we have already started reach ing out 15



### to some manufacturers to conduct these 16


### confidential engineering interviews. But just to 17


### give an overview, the engineering interviews are 18


### generally one day, where the first half of the 19


### day, we have an interview guide that we provide 20



### to the manufact urers, and there are questions 21


### related there to the engineering analysis. Then 2258

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### the second half of the day, we look to try and 1


### visit the production facilities, if they are in 2


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


### production of the commercial prerinse spr ay 4



### valves. 5


### Note that we also sign nondisclosure 6


### agreements before the whole process, so all the 7



### information will not be disclosed in the 8


### engineering analysis, except they will be 9


### aggregated. So they are masked when we use them 10



### -- we use the information p rovided during these 11


### engineering interviews in the engineering 12


### analysis. 13


### Any participation would be helpful, and I 14


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


### conduct these confidential engineering 16



### interviews. 17



### MR. BALDWIN: Question there. This 18



### mark etplace for this product is small when you 19



### look at the number of manufacturers, and then 20


### when you look at the market share analysis, once 21


### you gather that information, you will see that 2259

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### there is a small, small number of manufacturers 1


### that actually control t he majority of this 2


### market, because it is a niche product. 3


### When you say this information is going to 4


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



### manufacturers in this market that have the bulk 6


### of the share and most of them are family

- owned 7


### smaller compani es that don't report this stuff as 8


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


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


### our numbers and see the numbers of our top 11


### competitor in this marketplace? How is that 12


### protected as we start to share this i nformation 13


### through our NDA? 14



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


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


### question. This is Aris Marantan from Navigant. 17


### We are very cognizant of that situation, 18


### so we won't be disclosing anything whenever there 19


### is only two parties involved. 20



### MR. BROOKMAN: Or even three. 21


### MR. MARANTAN: We're very careful with 2260

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### three, as well. 1


### We just pay attention to the data, and if 2


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


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



### What we can do is take the information 5


### that you are willing to provide and bring it back 6



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


### willing to provide information and just be very 8



### cautious with that data. 9


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



### makes th at decision whether or not to share that 11


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



### two, three, or four manufacturers? Where does 13


### that final decision rest, and what

-- I know we 14


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


### should say. Where is the p rotection fallback to 16


### the manufacturers sharing this data? 17


### MR. MARANTAN: It goes back to the NDA 18



### that we

-- 19



### MR. BALDWIN: The NDA doesn't guarantee 20


### that this information won't be aggregated and 21



### shared. 2261

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### MR. MARANTAN: I'm sorry? 1



### MR. BALDWIN: The NDA d oesn't say that 2


### this information will not be aggregated and 3


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


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


### Your practice or your process normally says that 6


### you would not, but where does that protection 7



### fall back on the manufacturer as a guarantee that 8


### that aggregate would not be published if you only 9



### have two or three manufacturers? 10



### MR. MARANTAN: We will have to work with 11


### you on that. 12


### MR. BALDWIN: Okay. 13


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



### process t hat we have done, which is we don't 15


### disclose that type of information. 16


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



### work on those details. 18


### MR. MARANTAN: Thank you. 19


### MS. KUMAR: Okay. So the manufacturer 20


### selling price then is calculated based on the 21



### manufactu rer production cost and the manufacturer 2262

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### markup, as shown in the graphic on this slide. 1


### The industry

- wide manufacturer markup is 2


### determined based on publicly available financial 3



### sources, such as the SEC Form 10

- K's and 4


### manufacturer feedback through the en gineering 5



### interviews. 6


### The final result for the engineering 7


### analysis is a cost

- efficiency relationship in 8


### terms of manufacturer selling price, MSP, versus 9


### efficiency. 10


### The next analysis we will be looking at 11


### is the preliminary manufacturer impact analysis. 12


### There are three main purposes of the 13


### manufacturer impact analysis, or the MIA. The 14


### first is to quantitatively assess the financial 15


### impact of energy conservation standards on the 16


### manufacturers of commercial prerinse spray 17



### valves. 18



### The second is to identi fy any potential 19


### manufacturer subgroups whose cost structure 20


### differs significantly from the industry average. 21


### One such common subgroup is the small business 2263

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### manufacturers. 1


### The third is to quantitatively and 2


### qualitatively examine other non

- direct financia l 3


### impacts of energy conservation standards on 4


### manufacturers. These include direct employee 5


### impacts, manufacturing capacity, and the 6


### cumulative regulatory impact on the manufacturing 7


### industry. 8


### The methodology for the MIA is typically 9


### performed in three ph ases, which will be shown in 10


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


### MIA is the change in industry net present value, 12


### or INPV, resulting from energy conservation 13



### standards. 14


### Here are the three phases of the 15


### manufacturer impact analysis. In the fir st 16


### phase, DOE creates an industry profile building 17


### on the market and technology assessment. This 18


### takes place during the preliminary analysis. 19


### During this time, DOE also identifies the key 20


### issues concerning manufacturers. 21


### In the second phase, which spans both the 2264

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### Notice of Proposed Rulemaking, NOPR, and the 1


### Final Rule analyses, DOE builds a strawman 2


### industry cash

- flow model called the "Government 3


### Regulatory Impact Model," or GRIM, to forecast 4



### free cash flows in the industry. It does this 5



### both for the bas e case and the standards case, 6



### and calculates the INPV for each case. 7


### Also, in Phase 2, DOE develops an 8


### interview guide that it will use to lead 9


### subsequent discussions with manufacturers during 10


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



### Note that t hese interviews are actually different 12


### than the engineering interviews that we just 13


### discussed. The engineering interviews generally 14


### happen right after the framework comment period; 15


### whereas, the MIA interviews happen right after 16


### the preliminary analysis co mment period. So the 17


### engineering interviews are more focused on the 18


### engineering analysis; whereas, the manufacturing 19



### interviews are more focused on the manufacturer 20


### impacts. 21


### In Phase 3, the MIA interviews take 2265

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### place, and then following the interviews, DO E 1



### then refines the GRIM and evaluates other 2


### qualitative issues, such as the direct 3


### employment, manufacturing capacity, and the 4


### cumulative regulatory burden. 5


### Finally, the MIA results are finalized 6



### for the NOPR. 7


### At this time, DOE seeks an item for 8



### comment, item 12

- 1. DOE seeks comment on the 9


### appropriate manufacturer subgroups, if any, for 10


### commercial prerinse spray valves that DOE should 11


### consider in the manufacturer subgroup analysis. 12



### MR. BROOKMAN: Jeff. 13



### MR. BALDWIN: You mentioned small 14



### business as a su bgroup. I would second that 15



### motion. 16


### MR. BROOKMAN: Thank you. 17


### MS. KUMAR: Thank you. 18


### MR. BROOKMAN: Additional subgroups that 19


### you would note? 20


### [No audible response.] 21


### MR. BALDWIN: Nothing additional. 2266

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### MS. KUMAR: Okay. 1


### So DOE also is requesting comme nt on any 2


### existing or pending regulations that should be 3


### examined in the cumulative regulatory burden 4


### analyses. 5


### The next is the markup analysis. I wi ll 6



### hand it over to Scott Morris from PNNL. 7


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



### are on Slide 48, an d the remaining slides, there 9



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


### better than halfway through, and the remaining 11


### slides tend to move rather rapidly. 12



### Do we need a short coffee break at this 13


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


### certainly go ing to finish by noon today. Should 15


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


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


### [Laughter.] 18



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


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



### now 10:15, and so we wi ll break for 15 minutes. 21


### For those of you that aren't familiar 2267

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### with the Forrestal Building, you must wear this 1


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


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


### the elevators to the ground floor and go in tha t 4


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


### you back here to resume at 10:30. 6



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


### MR. BROOKMAN: We are going to pick up 8


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



### Scott Morris. Scott. 10



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


### Ready to go? Excellent. 12


### My name is Scott Morris. I work for 13


### Pacific Northwest National Laboratory, and I will 14


### be talking about the remaining principles and 15


### analyses that you see in the slide in front of 16



### you. 17



### These are all anal yses that would be 18


### performed in the preliminary analysis phase of 19


### this rulemaking as well as updated and refreshed 20



### and revised as needed for the NOPR and Final Rule 21


### analyses. 2268

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### First, we'll talk about the markups 1


### analysis. The purpose of the markups analys is is 2


### to determine the final price an end user pays for 3


### baseline and more efficient equipment. 4


### Specifically, the markups analysis transforms 5


### MSPs from the engineering analysis into final 6



### end

- user prices. 7


### There are two main components of this 8


### analysis. T he first requires identifying the 9


### distribution channels through which equipment 10


### passes between manufacturers and end users, and 11


### the second component is estimating the markups 12


### for each step within the distribution channels. 13


### The slide shows the first compon ent of 14


### the markups analysis or the distribution 15



### channels. DOE has so far identified three 16


### distribution channels in the commercial prerinse 17


### spray valve market. The first one is a 18


### distribution channel where products or equipment 19


### go from the manufacturer st raight to the final 20



### customer. 21


### The second is where equipment goes from 2269

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### manufacturers through an authorized distributor, 1


### to a final customer. Mythri earlier talked about 2


### some of the ways that the equipment gets into the 3


### marketplace. She had mentioned show rooms. We 4


### would anticipate that showrooms might be an 5


### example of this second distribution channel. 6



### Third is a manufacturer to a retail 7


### merchant to the final customer. A couple 8


### examples of this type of distribution channel 9


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



### Internet sellers. 11


### The two most critical pieces of 12


### information DOE seeks input on here are, first, 13


### how many distribution channels are there or 14



### should there be. Are there more channels than 15


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



### Th at's first. And second, what percentage of all 17


### commercial prerinse spray valves go through each 18



### of these channels? 19


### So this brings us to a request for 20



### comment, 6

- 1. DOE seeks comment on the 21


### distribution channels and the share of industry 2270

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### shipments for e ach distribution channel as they 1


### apply to the range of commercial prerinse spray 2


### valves that are covered by this potential rule. 3


### MR. BROOKMAN: The first question is 4



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



### Are there other distribution channels tha t are 6


### meaningful? Is that a good characterization? 7


### MR. MORRIS: For example, is there a 8


### channel perhaps where contractors get involved in 9


### installing the equipment somehow? 10



### MR. BROOKMAN: Jeff. 11


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


### don't get into sale s a whole lot. 13


### [Laughter.] 14


### MR. BALDWIN: I will tell you the answers 15


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



### distribution channel s , and it could be a 17


### combination thereof of what you have on the 18


### screen. It could be anywhere from directly to a 19



### fina l customer that is not normally like your 20



### Harry Homeowner

- type customer. It would be more 21


### of your large national chain customer. Then you 2271

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### have a host of options through distributors, 1


### merchants, Internet resellers, and it could be a 2


### combination where it g oes through three or four 3


### points before it gets to that final customer, 4


### because sometimes you have the contractor, 5


### whether it's a general contractor or a plumbing 6


### contractor involved also. So it could be very 7


### complicated looking at that whole model of 8



### dis tribution. 9


### MR. MORRIS: Thank you, Jeff. 10


### So you would agree that what you see on 11


### the screen is perhaps just a small subset of 12


### every possible combination? 13



### MR. BALDWIN: Correct. 14


### MR. MORRIS: Thank you. 15



### MR. BROOKMAN: Can you venture a guess 16


### about the p ercentages among these three broad 17



### bands of distribution? 18


### MR. BALDWIN: I would not be the right 19


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


### that percentage of information there. 21


### MR. BROOKMAN: Okay. I was just 2272

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### wondering if any of the trade associa tions have 1


### any information about such things. 2


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


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


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


### They're proprietary. 6


### MR. BROOKMAN: Okay. Thank you, 7


### Stephanie. 8


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



### MR. MORRIS: I will explain the equation 10


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


### fixated by the pretty green lettering down there. 12


### But first, the take

- home message from 13


### this slide is that DOE calculates markups which 14


### are applied again to manufac turer selling prices 15


### to get the end user final purchase prices. 16


### Baseline markups include fixed costs such 17


### as occupancy expenses and labor expenses that do 18


### not scale with equipment cost. 19


### Incremental markups are calculated based 20



### on distribution channel co sts that vary only with 21


### equipment costs, such as insurance, profit, and 2273

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### depreciation

. 1


### Overall markups combine baseline and 2


### incremental markups, as shown in the equation, to 3


### develop the final purchase price for a given 4


### piece of equipment. 5


### DOE plans on usi ng data from, for 6


### example, the SEC 10

- K reports and other sources 7


### to develop baseline incremental and, by 8


### extension, the overall markups for each of the 9


### steps in the individual distribution channels, 10


### and is, of course, interested in any other 11



### methods for c alculating markups and/or sources of 12


### data that can be used in the markups analysis. 13


### Just to briefly cover that equation in 14



### the bottom for those that are interested, for 15


### baseline efficiency equipment, the way that the 16


### final purchase price is calculated is given by 17


### the black, the black writing only. The final 18


### purchase price for baseline equipment is simply 19


### the manufacturer selling price of that baseline 20


### equipment times the baseline markup, that 21


### quantity multiplied by sales tax. 2274

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### For equipment that is higher or more 1


### efficient than the baseline efficiency, the 2


### calculation for determining the final purchase 3


### price of that equipment is simply within that 4


### equipment class , y ou take the MSP of the baseline 5


### equipment within that equipment class times the 6



### baseline mar kup plus this MSP EL minus MSP 7


### baseline is the manufacturer's selling price of 8


### the more efficient equipment minus the 9


### manufacturer's selling price of the baseline 10


### equipment, which is essentially the incremental 11



### cost difference between the more efficient 12



### eq uipment and the baseline equipment. That 13


### quantity is multiplied by the incremental markup, 14


### and then again, that whole quantity is multiplied 15


### by sales tax. 16


### Anybody have any comments or questions 17


### regarding this equation or anything on this 18



### slide? 19


### Yes, sir

. 20



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



### uniform

-- 2275

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### MR. BROOKMAN: Ed Osann. 1



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



### Since sales tax is not uniform, what is 3


### your approach to getting a composite for that? 4


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



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


### analysis where we incorporate variability in 7


### sales tax is typically by state. 8



### Is that sufficient for now? 9



### MR. OSANN: Yeah. That does take into 10


### account states that have no sales tax, right? 11



### MR. MORRIS: With no sales tax? 12



### MR. OSANN: Yeah. 13


### MR. MORRIS: Yes, sir. Yep. 14


### All right. We will move on to the energy 15


### and water use analysis. 16


### Notice that the results of this analysis 17


### in conjunction with the outputs from the markups 18


### analysis and the engineering analys is are inputs 19



### to the life

- cycle cost and payback period 20


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


### essentially as the "LCC analysis." 2276

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### We are going to talk about energy and 1


### water use. The energy and water use analysis has 2


### two primary purposes. The first is to assess how 3


### much energy and water is used for every equipment 4


### class and for each efficiency level. The second 5


### purpose is to provide the cost basis for energy 6



### and water use. 7


### The equation here shows a simple example 8


### of calculating daily water u se. As an example, a 9


### calculation for calculating how much water is 10


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


### gallons, just daily water use in gallons equals 12


### daily operating time in minutes, for example, 13


### times average flow rate in gallons per minute. 14



### Noth ing more complicated than that. 15


### For LCC and national impact analysis 16



### purposes, waste

- water discharge will be assumed 17


### to be 100 percent of water used by the equipment

. 18



### The WaterS ense field study offers some insights 19


### into energy use as a function of water use and 20



### average operating times per day, which can be 21


### annualized by accounting for the number of 2277

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### operating days per year by equipment class. 1


### At this point, we have several requests 2



### for comment. 3



### Item 7

- 1, DOE requests input on 4


### operational patterns of comm ercial prerinse spray 5


### valves for different equipment classes and 6


### applications that may impact water use. 7



### Item 7

- 2, DOE seeks recommendations on 8


### sources of data for regional potable water supply 9


### temperatures and typical operational water 10


### temperatures used in commercial prerinse spray 11


### valves for different applications and equipment 12



### classes. 13



### And item 7

- 3, DOE seeks comment on the 14



### inclusion of associated reduction in wastewater 15


### discharge as a result of lower flow rate for 16


### prerinse spray valves. 17



### MR. BROOKMAN: Dain

. 18


### MR. HANSEN: This is more of a general 19


### question. When developing this, have you been 20


### involved with the WETT team, the Water Energy and 21


### Technology Team here at DOE to develop this? 2278

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### This is the agency of the Department, within the 1


### Department of En ergy that we work with closely, 2


### and their whole purpose is the energy water 3


### nexus, the energy loss, water loss between the 4


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


### I think Sandia, Berkeley, and several other 6


### groups, but I would just encourage reac hing out 7



### to them as well. 8



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


### focusing on this specific technology, but they 10


### may have some input there, as well. 11


### MR. BROOKMAN: Okay, thank you. 12


### MR. MORRIS: Thank you for that feedback. 13



### MR. BROOKMAN: You see the t hree comment 14


### boxes there: operational patterns, sources of 15


### data, and thoughts about inclusion of associated 16



### reduction in wastewater. 17


### [No audible response.] 18


### MR. BROOKMAN: Nothing additional here? 19


### MS. TANNER: Hi. This is Stephanie 20



### Tanner from the Wate rSense program. 21


### I just wondered if you don't get any 2279

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### sources of data, would DOE collect primary data 1



### on this? 2


### MR. BROOKMAN: If they would initiate the 3



### data collection themselves? 4



### MS. TANNER: Yeah, mm

- hmm. 5



### MR. BROOKMAN: What does WaterSense have, 6



### Ste phanie? 7


### MS. TANNER: Do you mean in terms of

-- 8


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


### MS. TANNER: We don't collect operational 10



### data

-- 11



### MR. BROOKMAN: I see. 12



### MS. TANNER:

-- on prerinse spray valves. 13


### MR. BROOKMAN: okay. 14


### MS. TANNER: We just coll ect the data 15


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



### MR. BROOKMAN: I see. 17



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



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


### comments or data from interested parties, we will 20



### do our best to find it somewhere , somehow. 21


### MR. BROOKMAN: There are probably pockets 2280

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### of data collection in various places. 1


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


### we have a couple folks that are knowledgeable in 3


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


### expertise for some data in the absence of 5


### stakeholder input. 6



### MR. BROOKMAN: Jeff. 7



### MR. BALDWIN: We will offer further 8



### comments in our written comments, but there are 9


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


### talking about NAFEM with food equipment or NRA 11



### with restaurant as sociation or even the Food 12


### Service Tech Center out in California, who has 13


### done a lot of the work and actually helped 14


### develop the original ASTM F2324 standard and did 15


### a lot of operational

-- they're kind of like the 16


### Consumer Reports of food service equipmen t, and 17


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



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



### written statement. 20


### MR. BROOKMAN: Thank you. 21



### Final comments here before we move on? 2281

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### [No audible response.] 1


### MR. BROOKMAN: Okay. 2



### MR. MORRIS: The L CC analysis uses inputs 3


### from the analyses we have discussed today so far 4


### as well as other data inputs. 5


### This analysis in general determines 6


### impacts of different efficiency levels on a 7


### customer. LCC, or life

- cycle cost, is the total 8


### cost of equipment over its lifetime. 9


### In the equation shown, installed cost is 10


### labor plus the final equipment purchase price, 11


### including all markups and sales tax. Operating 12


### costs include maintenance, repair, energy, water, 13


### and wastewater costs. Operating costs are 14


### typically an nualized , and the last bullet there, 15


### payback period is the number of years required 16


### for operating cost savings to pay back any 17


### incremental costs of higher efficiency equipment. 18


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


### table that is going to give some more meat 20


### essentially to this equation here, and we will 21


### jump back and forth a couple of times, as needed, 2282

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### between slides to illustrate that point. 1


### In general, regarding the information on 2



### this slide, of most interest to DOE is whether 3


### any of the costs shown v ary by efficiency level. 4


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


### these costs change? 6


### The first two rows in this table, the 7


### equipment purchase price and installation cost 8


### rows, refer to the installed cost component of 9


### the equation shown in this sl ide, and the 10


### maintenance cost, repair cost, and energy and 11



### water cost rows in this table, refer on this 12


### previous slide to operating costs, which again 13


### you add the installed cost plus the operating 14


### cost to get life

- cycle costs for a given piece of 15


### equipment

. 16


### So I will just briefly read through this 17


### table, just to say verbally what the LCC 18


### component is versus how it is actually 19



### calculated, the method that we'll use. 20


### The equipment purchase price, it is 21


### simply done by marking up the MSPs from the 2283

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### engineering analysis by the appropriate 1


### distribution channels and markup values, 2


### essentially marking those MSPs up by the overall 3


### markups, which include sales tax. 4



### Installation cost includes labor and 5


### material costs to place the equipment into 6


### service. When I say ma terial costs, depending on 7


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


### would imagine that in the prerinse spray valve 9


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


### For example, this is not outdoor lighting where 11


### you have to rent a bucket truck to r eplace 12


### ballasts or lamps in high fixtures, but I guess 13


### on that tangential note, is there any equipment 14


### or materials that anyone can identify or think of 15


### that are required when installing prerinse spray 16


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



### mater ials needed to install a prerinse spray 18


### valve change between baseline versus more 19


### efficient equipment? 20


### MR. BALDWIN: I'd say that your 21


### comparison would be negligible between the 2284

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### standard versus the higher efficient or however 1



### we want to call it. 2



### I would caution against simply looking at 3


### it as a swap

- out program. Because you have 4



### different manufacturers with different 5


### adaptations of their products, it may not fit 6


### together. Everybody doesn't always use the same 7


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



### some of the other ones do not. 9


### If you are going into a facility that 10


### happens to have one of those unique brands

-- I 11


### don't want to list any names here

-- you may have 12


### difficulty in adapting one of the more common 13


### manufacturer's products. You may hav e to have an 14


### extra adaptor, or you may end up having to 15


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


### looking at it as a simple swap

- out of a spray 17


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


### prerinse hose or even the complete prerinse unit 19


### when yo u do that, so we have learned that through 20


### programs that we've done. 21


### In California, we did the Rinse and Save 2285

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### Program with the California Urban Water 1


### Conservation Council, and we've done other 2


### programs like that throughout North America. It 3


### is always a c aution because everybody goes into 4


### it thinking it is a simple swap

- out, and that's 5


### not always the case. 6


### MR. BROOKMAN: Thank you. 7


### MR. MORRIS: Thank you, Jeff. 8


### Can I go a little bit farther down the 9


### rabbit hole and ask this following question? I 10



### was go ing to ask it later, but this is a fitting 11



### time now. 12


### It's DOE's current understanding that for 13


### the most part, the commercial prerinse spray 14


### valve market is kind of a throwaway market, 15


### meaning at the end of the usable life of the 16


### prerinse spray valves, the y are essentially 17


### replaced upon failure. My question for the 18


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


### the end of a usable life of a prerinse spray 20


### valve, are they typically thrown away? 21


### We're aware of a couple refurbishment 2286

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### kits, for example, bu t do those actually get 1


### used, and is equipment refurbished or simply 2


### thrown away? 3


### MR. BALDWIN: Again, that will depend on 4


### the manufacturer. Your more common mainstay 5


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


### repair kits for our products. 7



### We do not classify our spray valves as 8


### throwaways. There are some on the market that 9



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


### products will last forever. So you can buy a 11


### repair kit for a spray valve that was made in 12



### 1947 when we first invented the commer cial 13


### prerinse spray valve. You still can buy that 14


### repair kit today, and we do have pictures and 15


### documentations of spray valves that have been in 16


### use for over 60 years. 17


### MR. BROOKMAN: Thank you. 18


### MR. MORRIS: Thank you 19



### I will continue down this list here

. 20


### Maintenance costs are incurred by the 21


### customer for preventative maintenance of the 2287

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### equipment. Repair costs are costs incurred in 1


### repairing or replacing damaged or malfunctioning 2


### components of the equipment, and energy and water 3


### costs are paid by the customer for the energy and 4


### water used by hot

- water

- using equipment, such as 5


### these prerinse spray valves. 6


### In general, to calculate the costs of 7


### energy, DOE plans on using the Energy Information 8



### Administration's Annual Energy Outlook to 9


### estimate energy pri ces, and based on limited 10


### research thus far in this rulemaking process, DOE 11



### is aware of the American Water W orks 12


### Association's Water Rate Survey, which could be 13


### used perhaps to estimate current water and 14


### wastewater prices; and then in order to project 15



### thos e costs of water and wastewater into the 16


### future may use the Consumer Price Index Water 17


### Utility Costs to develop a growth rate, which can 18


### then be applied to the current AWWA water and 19



### wastewater costs. 20


### I guess I would ask at this point, as 21


### well, even thoug h it is not a formal request for 2288

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### comment, Are there other sources of information 1


### or data that folks are aware of for estimating 2



### the cost of water? 3


### MR. BROOKMAN: No. Okay. 4



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


### MR. MORRIS: Several other inputs to the 6


### LCC analysis include discount rates, a base case 7


### efficiency distribution, and equipment lifetime. 8


### Discount rates will be derived by 9


### calculating the weighted average cost of capital 10


### for different businesses that own the equipment. 11


### Base case efficiency di stributions, which 12


### give the relative percentage of units at each 13


### efficiency level and equipment class in the 14


### absence of a standard, are very important because 15


### they determine much about the magnitude of energy 16


### and monetary savings, resulting from an amended 17



### standard. 18


### While the percentages used in the base 19


### case efficiency distribution are not necessarily 20


### identical to the shipments of each efficiency 21


### level, the two, as you can imagine, are closely 2289

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### related. 1


### Regarding equipment lifetime, it is also 2



### of interest to the Department whether more 3


### efficient equipment, for example, equipment that 4


### has a lower flow rate perhaps, has a different 5


### lifetime than the baseline equipment. 6


### Finally, the Department has a great 7


### desire to know any information that people have 8



### regar ding the base case efficiency distribution: 9


### What does the, perhaps, current installed stock 10


### of equipment in the country look like right now? 11


### We are going to get to some comments in a 12


### couple of slides, but that particular question 13


### regarding base case effi ciency distributions is 14


### not a specific item that DOE requests comment on. 15


### I guess to reiterate and to formally ask 16


### the question here, are there any folks in the 17


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


### information that they may be able to share 19



### re garding a base case efficiency distribution, 20


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


### what percentage of equipment currently being sold 2290

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### and/or is currently installed

-- how much of that 1


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



### et cetera, e t cetera? 3


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


### sure, but any input is appreciated. 5



### MR. BROOKMAN: None of the trade 6


### associations gather that information? 7


### [No audible response.] 8



### MR. BROOKMAN: No. 9


### MR. MORRIS: Do you know where we might 10



### be able to fin d such information? 11


### MR. BROOKMAN: Please use the microphone. 12



### Ed Osann. 13



### MR. OSANN: Ed Osann with NRDC. 14


### I think WaterSense partners report their 15



### share of

-- their shipment of labeled product and 16


### unlabeled product in the same category. 17



### MR. BROOKMAN: O kay. Thank you, Ed. 18


### MR. MORRIS: Thank you. 19



### MR. BROOKMAN: Jeff. 20



### MR. BALDWIN: Yeah. The drawback to that 21


### is the WaterSense program is fairly new. As I 2291

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### mentioned earlier, it's only been released this 1


### year, and right now, you only have two 2



### manufacture rs that are participating in that 3


### program, and so you are missing a lot of 4


### manufacturers there. Plus, the reporting 5


### actually hasn't even happened yet, because we 6


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


### reporting that we do in the February time frame. 8


### I will let Stephanie answer that. 9


### MS. TANNER: This is Stephanie Tanner 10


### with the WaterSense program. 11


### Right. We only get data from 12



### manufacturer s who choose to report. So we don't 13


### really believe that our data is like market

- share 14



### data, and so, like Jef f said, we only have two 15


### manufacturers that have labeled products now. 16


### All the other products that are on your list that 17


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


### any data for them. 19


### We haven't really started collecting that 20


### much data on prerinse s pray valves at this point, 21


### so I would not say that we have like base case 2292

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### information for the market in terms of prerinse 1


### spray valves at this point. 2


### MR. BROOKMAN: Thank you. 3


### MR. MORRIS: This is Scott Morris again. 4


### Another question I just thought of, and 5


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


### far has been a source of walking information, a 7


### walking encyclopedia. 8


### Regarding the equipment you had mentioned 9


### that, for example, has been in service since 10


### 1946, your refurbishment kits

-- and I'm sor ry if 11


### this is obvious for everybody else in the room. 12


### For example, would your equipment from 1946, for 13


### example, with a refurbishment kit be able to 14


### meet, for example, a 1.6

- gallon

- per
- minute 15



### standard? 16


### I guess I am not asking that question 17


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



### refurbishment kits or can refurbishment kits have 19


### the capability and potential of reducing the flow 20


### rate or changing the energy efficiency or 21


### performance or products? 2293

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### MR. BALDWIN: That's a yes and a no. 1


### You have complete kits that would rebuild 2


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


### start with the main body, and you would rebuild 4


### from that point, but you also have very specific 5


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


### or something else that is missing or broke on 7


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


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


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


### MR. MORRIS: Thank you very much. 11



### [Pause.] 12


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


### So, as a statist ician and somebody who 14


### appreciates variability and the information 15


### contained in variability, I personally appreciate 16


### the depth that Monte Carlo simulations give to 17


### the LCC analysis. 18


### In general, just about any data input 19



### whose variation can be characterize d will have 20


### its variability analyzed in the LCC analysis, 21


### such as sales tax. So other examples include 2294

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### energy prices, discount rates, and

-- I'm coming 1


### up short on examples, but basically any input to 2


### the LCC analysis that has a distribution that can 3



### be e stimated will be varied in order to capture 4


### the wide range of variability present in the 5


### marketplace. 6


### Outputs from the Monte Carlo simulations 7


### and, hence, the LCC analysis in general include 8



### life

- cycle cost, life

- cycle cost savings, payback 9


### period, and pe rcentages of customers that benefit 10



### from , are adversely affected by , or are 11


### unaffected by an amended standard. 12


### This brings us to a laundry list of 13


### requests for comment, items 8

- 3 through 8

- 7. 14



### 8

- 3. DOE seeks comment on sources of 15


### data for determining mar ginal water and 16



### wastewater rates and methods to break out water 17


### and wastewater rates across different pricing 18


### segments, such as regionally or by state. 19



### 8

- 4. DOE seeks data sources and methods 20



### to determine future trends in water and 21



### wastewater rate escala tions. 2295

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### 8

- 5. DOE invites comment on whether 1


### repair costs may change for more efficient 2


### commercial prerinse spray valves. 3



### 8

- 6. DOE invites comment on whether 4


### commercial prerinse spray valves are typically 5


### replaced upon failure or repaired. 6



### 8

- 7. DOE see ks comment on appropriate 7


### commercial prerinse spray valve lifetimes for the 8


### equipment under consideration, as well as data 9


### regarding correlation between hours of use and 10


### commercial prerinse spray valve lifetime. 11



### [Pause.] 12



### MR. BROOKMAN: No additional com ment 13



### here? 14



### Jeff. 15


### MR. BALDWIN: Your first two items there, 16



### I would refer to the American Water W orks 17



### Associations for items 8

- 3 and 8

- 4. Yeah, 8

- 3 18



### and 8

- 4. 19



### Items 8

- 5 through 8

- 7, that could vary, 20


### depending on the manufacturer and how they go to 21



### market with their product. Some, of course, 2296

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### manufacturers and distributors see a premium for 1


### more efficient products. Others see it as doing 2



### their service to the environment and to their 3


### customers by offering it at the same price, so 4


### that could vary from manufa cturer to 5



### manufacturer. 6


### MR. BROOKMAN: Okay, thank you. 7



### MR. MORRIS: One comment about the 8


### equipment lifetime

-- this is an example of 9


### something that will be most likely given a 10


### distribution in the Monte Carlo analysis

-- is 11



### DOE's current

-- and again, t his is based on, 12


### shall we say, entry

- level research thus far

-- 13


### current understanding is that, again, in very 14


### general terms, perhaps the average lifetime of a 15


### prerinse spray valve is in the neighborhood of 5 16


### years. Can anybody comment on a ball

- park 17


### figur e? Is that in the right ball park? Is that 18


### way out of bounds? 19


### MR. BALDWIN: On every research project 20


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


### over. So it started somewhere, and it's been 2297

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### repeated. Where that assumption was gathered, I 1



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


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


### end user whether to take that expense of complete 4


### replacement or a field repair. 5


### MR. BROOKMAN: Thank you. 6


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



### We will now ta lk about the shipments 8


### analysis, which connects the LCC analysis and the 9


### national impact analyses together. 10


### The shipments analysis is, in a way, 11


### ultimately what scales the energy savings

-- or 12


### the water savings and energy savings at an 13



### individual customer level to savings at a 14



### national level. 15


### The purpose of the shipments analysis is 16


### to project future equipment shipments and 17


### nationally installed stock by equipment class and 18


### efficiency level. 19


### DOE typically projects shipments for 30 20


### years, beginning with th e expected date of 21


### compliance or the compliance date. 2298

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### DOE will try to find historical and 1


### current shipments from resources such as industry 2


### trade organization surveys and will project 3


### future shipments using data such as the EIA's 4


### Annual Energy Outlook f or ecast of new commercial 5



### construction. 6


### Now, having said this, obtaining reliable 7


### shipments data, as you can imagine, can sometimes 8


### be difficult for DOE to come by, and the 9


### Department appreciates any and all comments, 10



### resources, sources to look at, or data from 11


### interested parties. 12


### I think I will pose that as a question, 13


### which is, anybody here, do you have comments 14


### regarding shipments? I realize it's very early 15


### in the rulemaking process, but I realize there is 16


### NDAs and other stuff. But DOE greatly 17


### apprecia tes any information regarding shipments. 18



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



### slide. 20


### MR. MORRIS: Which are some requests for 21



### comment. 2299

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



### here first. 2



### Item 9

- 1, DOE seeks comment on an 3


### appropriate shipments pro jection methodology, 4


### including the selection of appropriate economic 5


### drivers. Economic drivers would be things such 6


### as commercial floor space growth, an appropriate 7


### proxy to use for the growth of the industry in 8


### general, or population growth, things like that. 9



### Item 9

- 2, DOE requests historical 10


### shipments data for the equipment discussed, 11


### including shipments for differing equipment flow 12



### rates. 13



### Item 9

- 3, DOE seeks comment on how an 14


### energy conservation standard for commercial 15


### prerinse spray valves might impa ct shipments of 16


### the equipment. 17



### MR. BROOKMAN: Jeff. 18



### MR. BALDWIN: I would think it would be 19


### very difficult for the DOE to gather that 20


### historical shipment data for this product. 21


### MR. BROOKMAN: Is there a methodology 22100

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### that they might employ? 1



### MR. BALDWIN: I mean, the closest thing 2


### we have to a shipment data would be the 3


### WaterSense program that has just started, as I 4



### mentioned earlier. This information doesn't 5


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


### the lead manufacturers here are family

- owned 7



### comp anies that do not report that information. 8


### MR. BROOKMAN: Okay. 9


### MR. MORRIS: So, in general

-- this is 10


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


### seen shipments information developed over time is 12


### DOE will make a best estimate based on any 13


### possible d ata they can find and throw it out to 14


### the public and request comment. Something along 15


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


### low, any feedback is appreciated. 17


### But we certainly understand the 18


### sensitivity, the sensitiv e nature of that type of 19



### dat a. 20


### We will now discuss the national impact 21


### analysis, or NIA, which is the final economic 22101

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### analysis DOE will conduct in the preliminary 1


### analysis phase of this rulemaking. 2


### The purpose of the national impact 3


### analysis is to calculate three quantities 4



### associat ed with an amended standard : National 5


### energy savings, or NES, national water savings, 6


### and national monetary savings or net present 7



### value, NPV. 8


### The method for calculating these 9


### quantities includes developing annual figures for 10


### every year of the analysis p eriod, which again is 11


### 30 years, beginning with the expected compliance 12


### date, and then essentially summing across all 13


### years to calculate cumulative totals. 14


### The LCC analysis contributes information 15


### about installed costs and energy and water use 16


### per unit. 17


### The shipments analysis contributes 18


### shipment and stock information. 19


### NES, again, national energy savings, is 20


### reported in both primary and full fuel cycle 21


### energy savings. NPV is reported in billions of 22102

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### dollars, and water and wastewater savings will be 1



### repor ted in billions of gallons or some 2


### appropriate measurement of water volume. 3


### Finally, the time value of money will be 4


### accounted for using defined discount rates. 5


### Inputs for national energy savings, I 6


### need to make one little clarification here, in 7



### case any body is going to call me out on it or 8


### not, but under the inputs for calculating 9


### national energy savings, national water savings, 10


### the projected shipment sub

- bullet actually 11


### belongs as an input for calculating NPV. 12


### In general, inputs for national energy 13



### sav ings and national water savings include annual 14


### energy and water use per unit at each efficiency 15


### level for all equipment classes, equipment stock, 16


### which is how many are using

-- how many units are 17


### using energy and water nationwide, and for energy 18


### savings in particular, a site

- to

- source 19


### conversion factor, which converts energy use at 20


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


### The main inputs for calculating NPV 22103

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### include installed and operating costs of all 1


### equipment for each year of the analysis period , 2


### projected shipments starting, again, with the 3


### compliance date, and accounting for the time 4


### value of money through defined discount rates of 5



### 3 and 7 percent. 6


### The next slide is several requests for 7



### comment. Item 10

- 1, DOE seeks comment on how the 8



### efficie ncy of commercial prerinse spray valves 9


### would be likely to change in the future in the 10



### absence of standards. 11



### Item 10

- 2, DOE seeks comment on the 12


### likelihood of increased commercial prerinse spray 13


### valve usage as a direct result of improved 14


### equipment efficie ncy. 15



### MR. BROOKMAN: Comments on either of 16



### these? 17



### Jeff. 18



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


### invented the prerinse spray valve in the 1940s, 20


### but we also invented what a lot of people call 21



### the "low

- flow prerinse spray valve" in the 1980s. 22104

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### The market has ev olved without extra 1


### standards or regulations being placed on prerinse 2


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


### which we live in where conservation is top of 4


### mind for all organizations and companies that we 5


### do business with, and so we have made products 6



### that have been more efficient. We have not been 7


### forced to make them by a regulation. We have 8


### made them based on customer request or customer 9



### satisfaction. 10


### The efficiency of commercial prerinse 11


### spray valves will change in the future, 12


### regardless of the s tandard, because that's just a 13


### part of being a competitor in the market and 14


### listening to our customers. 15


### MR. BROOKMAN: Thank you. 16


### MR. MORRIS: That essentially wraps up 17


### the analyses that DOE will conduct for the 18


### preliminary analysis phase of this rulemak ing. 19


### The analyses shown in this slide are 20


### something we worry about way in the future, which 21


### means next fall, which are conducted in the NOPR 22105

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### and Final Rule analyses. 1


### Although the NOPR phase is highlighted 2


### here, the analyses shown are also included in the 3


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


### to the left of the circle, revising the 5


### preliminary analysis means incorporating 6


### information and data for all of the analyses we 7


### have discussed today and not just the ones shown 8



### here. 9


### For example, in the NO PR phase

-- and I 10


### know Mythri

-- we have talked about this already, 11


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


### inputs for the engineering analysis, the markups, 13


### and energy and water use analyses, life

- cycle 14


### cost, and national impact analyses. 15


### We will ju mp into just talking about 16


### these individual analyses, which will be done at 17


### the NOPR phase. This will be quite brief, 18


### because we're sort of jumping the gun talking 19


### about the NOPR phase. 20


### The customer subgroup analysis, also 21


### known as the "LCC subgroup anal ysis," assesses 22106

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### the economic impacts of standards on identifiable 1


### subgroups within the general population. Results 2


### from the individual subgroups are compared 3


### against the results from the main LCC analysis. 4


### Some examples of consumer or customer 5


### subgroups may include things like churches, 6



### mom
- and

- pop restaurants, and nursing homes, for 7


### example. 8


### This brings us to item 11

- 1. DOE seeks 9


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


### considered in evaluating potential standards for 11


### commercial prerinse spray valves. 12


### I should specify also we are talking 13


### about customer subgroups, not manufacturer 14


### subgroups. 15



### MR. BROOKMAN: Jeff. 16


### MR. BALDWIN: You have a wide array of 17


### subgroups there, starting with your national 18


### large chain customers, whether it's a national 19



### r estaurant chain or worldwide international 20


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


### said, your mom

- and

- pop restaurants. So you have 22107

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### a wide array there, and it will be very 1


### interesting how you categorize those into 2


### subgroups to catch all the different ones there. 3


### MR. BROOKMAN: Thank you. 4


### MR. HANSEN: This is Dain. Just really 5


### quick, this isn't really

-- I mean, somewhat a 6


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


### certification body, that is a whole new realm if 8


### there's new standards being de veloped and new 9


### federal regulations. Then there must be tests 10


### and certified to a certain level. So that brings 11


### in a whole nother subgroup as well that you are 12


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


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



### t hen enactment. There's other steps that will be 15


### used in the marketplace, as well. 16


### MR. MORRIS: Okay, thank you. 17


### MR. BROOKMAN: Thank you. 18


### MR. MORRIS: We will talk briefly about 19


### the utility impact analysis. The utility impact 20


### analysis examines the imp acts on domestic energy 21


### supplies that result from the imposition of 22108

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### standards. 1


### DOE plans on using factors derived from 2



### NEMS

- BT, which is a variant of the National 3


### Energy Modeling System, to project energy sales 4


### and prices, generation , and capacity. 5



### This brings us to a few items. 13

- 1. 6


### DOE seeks comment from interested parties about 7


### its proposed use of NEMS

- BT to conduct the 8


### utility impact analysis. 9



### 13

- 2. DOE seeks comment and information 10


### on potential methods and data sources that can be 11



### used to assess the impacts on water and 12


### wastewater utilities as a result of energy 13


### conservation standards for commercial prerinse 14


### spray valves. 15


### In other words, that item 13

- 2, DOE has a 16


### great resources in NEMS

- BT to calculate the 17


### impacts on electrical

- generating utilit ies and 18


### natural gas utilities. Is there similar data or 19


### tools that anybody can identify that could be 20


### applied to water and wastewater utilities? 21


### [No audible response.] 22109

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### MR. MORRIS: We will talk about the 1


### employment impact analysis. 2


### The employment impac t analysis assesses 3


### the indirect employment impact on the general 4


### economy stemming from standards. These are 5


### different impacts than the direct employment 6


### impacts discussed in the manufacturer impact 7


### analysis. DOE plans on using the ImSET model, 8



### which is the Impact of Sector Energy Technologies 9


### model, for evaluating indirect employment 10


### impacts. 11



### Item 14

- 1, DOE seeks comments about a 12


### suggested approach for assessing national 13


### indirect employment impacts. 14



### MR. BROOKMAN: Jeff. 15


### MR. BALDWIN: Again, I would me ntion the 16


### National Restaurant Association. It may be a 17


### question you could tee up to them and see what 18


### work they have done or work they would want to 19


### participate in there, because they represent a 20


### huge share of the market that utilizes this 21


### product. 22110

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### MR. B ROOKMAN: Thank you. 1


### MR. MORRIS: Thank you. 2



### MR. BROOKMAN: Additional comments here? 3


### [No audible response.] 4


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


### emissions analysis and monetization of emissions 6



### for the next few slides. 7


### The emissions analysis look s at 8


### environmental impacts from standards, including 9


### FFC or full fuel cycle emissions. DOE bases 10


### emission factors on NEMS, supplemented with other 11


### sources, to examine the standards' impacts on the 12



### handful of the emissions shown in the slide. 13



### Item 15

- 1, D OE seeks comment about its 14


### approach to conduct the emissions analysis for 15


### the equipment that would be covered under this 16


### proposed rulemaking

-- I shouldn't say "proposed" 17



### yet

-- under this rulemaking, in general. 18



### Item 15

- 2, DOE seeks comment and 19



### informati on on potential methods and data sources 20



### that can be used to assess emissions reductions 21


### as a result of water savings. 22111

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### MR. BROOKMAN: Jeff? No? Nothing? 1


### Nothing here? 2


### [No audible response.] 3


### MR. BROOKMAN: Okay. 4



### MR. MORRIS: Ed? 5



### MR. OSANN: Ed Osann with NRDC. 6


### In previous rulemakings, DOE has resisted 7


### comments and recommendations regarding the 8


### incorporation of embedded energy savings from 9



### water

- saving products and water

- saving standard 10



### levels. 11


### With this request for information on 12



### emission reduction s associated with water 13


### savings, are you anticipating a willingness to 14


### consider embedded energy savings at the NOPR 15



### stage? 16


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


### Part of the reason DOE has historically not used 18


### or not really examined closely the impac t of 19


### water savings in terms of how it saved energy in 20



### water and wastewater utilities

-- for example, in 21



### the commercial clothes washer rule

-- is because 22112

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### the water and wastewater utilities are extremely 1


### variable by region, and it is very difficult to 2



### summar ize or model such large variations. 3


### With this comment, I think DOE is 4


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


### these embedded energy savings. The question is 6


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



### defensible

-- not a case, but I guess you cou ld 8


### say a defensible case for including it in the 9


### analysis. 10


### So if we can, within DOE and with help 11


### from interested parties, develop a methodology 12


### that will allow us to defensibly and justifiably 13


### look at it, it will certainly be done. 14



### MR. BALDWIN: I'd lik e to make a comment. 15


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


### saying I think it would be shortsighted

-- and 17



### I'll use the word "asinine"

-- not to look into 18


### embedded energy savings when you're dealing with 19


### commercial prerinse spray valves. The produ ct 20


### uses tempered water all the way up to what we 21



### would call "hot water," and to not look at the 22113

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### energy part of that calculation would not be 1



### recommended. 2


### If you look at any of the water savings 3



### calculators that the manufacturers use for 4


### prerinse spray val ves, you will see that energy 5


### is really where the savings is when you are 6


### looking at commercial prerinse spray valves. 7



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


### make sure we are not shortsighted there to only 9


### look at one component of the calculation

. 10


### MR. BROOKMAN: Okay. Thanks, Jeff. 11



### MR. MORRIS: Jennifer Williamson has some 12


### input here. 13



### MR. BROOKMAN: Yes. 14



### MS. WILLIAMSON: Jennifer Williamson, 15



### PNNL. 16


### I just wanted to point out that here we 17


### are talking about the impacts at the utility 18



### level, not at the end

- use level. So we will be 19


### looking at the energy use associated with 20


### producing the hot water to be used by the spray 21



### valves. 22114

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### MR. BROOKMAN: Thank you. 1


### MR. MORRIS: Thank you. 2


### Regarding monetization of emissions, DOE 3


### plans to use the most curr ent Social Cost of 4


### Carbon values from interagency reviews to 5


### quantify the monetary savings associated with 6



### emissions reductions. 7



### In item 16

- 1, DOE requests comment about 8


### the approach it plans to use for estimating 9


### monetary benefits associated with emissio ns 10



### reductions. 11


### [No audible response.] 12


### MR. BROOKMAN: Nothing here. Okay. 13


### MR. MORRIS: Okay. We will talk about 14


### the regulatory impact analysis, which brings us 15



### to the bitter end of the NOPR and Final Rule 16


### phase analyses. 17


### The regulatory impact analysis explores 18



### non
- regulatory alternatives to standards that can 19


### save energy. Some examples include tax credits, 20


### rebate programs, bulk purchase programs, and the 21



### WaterSense program. 22115

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### There is no official request for comment 1


### on the regulatory impact analysis, b ut DOE is 2


### open and would like input regarding any other 3


### programs specifically in this market that have 4


### the potential for saving energy. 5


### MR. BALDWIN: Again, I would mention the 6


### programs that have been very successful in doing 7



### this without new standards. 8


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


### and Save program that California Urban Water 10


### Conservation Council completed in a couple of 11


### phases before the EPAct 2005 was ever released, 12


### and it was kind of the precipitous for that being 13



### done. It was so successfu l. So I would look at 14


### those programs and garner the information and the 15


### calculations that they had done at that time. 16


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


### Any additional examples or models that 18


### the Department might rely upon? 19


### [No audible response.] 20


### MR. BROOKMAN: Nothing additional. Okay. 21


### MR. MORRIS: Okay. We'll turn it back to 22116

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### you, Doug, for closing remarks. 1


### Closing Remarks. 2


### MR. BROOKMAN: Thank you. Thank you, 3



### Scott. 4


### So, as we had promised first thing this 5


### morning, now is an opportunity for anybody that 6


### wishes to make concluding remarks, to bring other 7


### issues to the fore that haven't been fully 8


### covered at this stage of the rulemaking, and 9



### final comments here. 10


### [No audible response.] 11


### MR. BROOKMAN: Nothing additional, okay. 12


### So then we will g o to the final slide and 13



### back to Jim Raba. 14



### MR. RABA: Wow! 15


### MR. BROOKMAN: Microphone. 16



### MR. RABA: I should know better. 17



### MR. BROOKMAN: Yeah. 18


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


### thoughtful and productive participation today. I 20


### learned a lot mysel f, and I think we all 21


### appreciate the comments that came in from all 22117

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### sources, live and on the webinar, as well. Thank 1



### you. 2


### So you have seen an overview of the 3


### rulemaking process, all that goes into it. 4


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



### sta rted for sure. I look forward to your input, 6


### your comments and data to provide. 7


### The comment period closes October 27th, 8



### as a reminder. 9


### In about 2 weeks or so, the transcript of 10


### this public meeting should appear on our 11


### Department of Energy Web page for c ommercial 12


### prerinse spray valves, so take a look there and 13



### kind of monitor that about 2 weeks hence. 14


### Then again, we look forward to your 15


### comments, your written comments. 16


### Safe travels, everybody. Thank you. 17


### MR. HANSEN: Quick question. 18



### MR. RABA: Dain. 19


### MR. HANSEN: When are these going to be 20


### available? Because I want to get this over to 21


### our engineers in our lab, so they can help 22118

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### develop comments, and hopefully, it's sooner than 1


### 2 weeks, so they can start working. 2


### MR. RABA: You're saying the

-- 3



### MR. H ANSEN: The PowerPoint from today. 4


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


### Web page by tomorrow late. 6


### MR. HANSEN: Okay. 7


### MR. BALDWIN: It was posted yesterday. 8


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



### you. 10


### MR. RABA: Thank you, Dain. 11



### MR. OSANN: There is usually a point of 12


### contact for technical questions given. I don't 13



### see one on the slide deck. 14


### MR. RABA: That would be John Cymbalsky. 15


### MR. OSANN: For technical questions? 16



### MR. RABA: Yes. 17


### MR. OSANN: Okay. 18


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


### MR. RABA: John will get the answer for 20


### you, Ed. Thank you. 21



### MR. BROOKMAN: And safe travels. 22119

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### [Whereupon, at 11:29 a.m., the public 1


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### CERTIFICATE OF NOTARY PUBLIC

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### I, Brian Knieser, Notary Public in

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### and for the District of Columbia, the officer

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### before whom the foregoing proceedings were



### s recorded, do hereby certify the foregoing

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### transcript of said proceedings was taken by me

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### and thereafter reduced to typewriting under my



### s direction.

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### BRIAN KNIESER

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### Notary Public in and for

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### The District of Columbia

Commission Expires:

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