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U.S. DEPARTMENT OF ENERGY

APPLIANCE STANDARDS PROCESS IMPROVEMENT -

PRIORITY SETTING WORKSHOP

OPENING REMARKS AND

OVERVIEW OF EVALUATION CRITERIA

FRIDAY, JUNE 14, 1996

The Workshop was held in the Ambassador

Room of the Embassy Row Hotel, 2015 Massachusetts

Avenue, N.W., Washington, D.C., at 9:00 a.m., Doug

Brookman, facilitator, moderating.

PRESENT:

(202) 234-4433

DOUG BROOKMAN, Moderator

ED POLLOCK

VINCE ANDERSON

BRYAN BERRING

TIM BEGOSKE

PETER BLEASBY

ROB CURRY

LAKE COULSON

JIM CRAWFORD

SUZANNE FALONI

MARK FRIEDRICHS

GENE FOLEY

CHUCK FOSTER

LINDA GREINER

DAVID GOLDSTEIN

JOHN HOLT

DOUG HORSTMAN

WILBUR HAAG

PHIL HOPKINSON

THOMAS JOHN ON

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON , D.C. 20005 (202) 234-4433

 EE-PI-96-001 COMMENT 59

1 

U.S. DEPARTMENT OF ENERGY 

APPLIANCE STANDARDS PROCESS IMPROVEMENT -

PRIORITY SETTING WORKSHOP 

OPENING REMARKS AND 

OVERVIEW OF EVALUATION CRITERIA 

FRIDAY, JUNE 14, 1996 

The Workshop was held in the Ambassador 

Room of the Embassy Row Hotel, 2015 Massachusetts 

Avenue, N.W., Washington, D.C., at 9:00 a.m., Doug 

Brookman, facilitator, moderating. 

(202) 234-4433 

PRESENT: 

DOUG BROOKMAN, Moderator 

ED POLLOCK 

VINCE ANDERSON 

BRYAN BERRING 

TIM BEGOSKE 

PETER BLEASBY 

ROB CURRY 

LAKE COULSON 

JIM CRAWFORD 

SUZANNE FALONI 

MARK FRIEDRICHS 

GENE FOLEY 

CHUCK FOSTER 

LINDA GREINER 

DAVID GOLDSTEIN 

JOHN HOLT 

DOUG HORSTMAN 

WILBUR HAAG 

PHIL HOPKINSON 

THOMAS J~WAtO~. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVENUE. N.w. 

WASHINGTON. D.C. 20005 (202) 234-4433 
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PRESENT: (continued)

EARL JONES

BERT KALISCH

DAVE LEWIS

MARK LeFRANCE

TED LELAND

MARY ELLEN MURPHY

MICHAEL McCABE

JOE MATTINGLY

STEVE NADEL

MARK RAYMOND

MIKE RIVEST

SANDRA RUITER

MARK RABA

CHARLIE STEPHENS

CHUCK SAMUELS

MIKE STEIN

TERRY THIELE

BOB WISBEY

MICHAEL WASSON

LARRY WETHJE

DONNA BANKS

GLENN SCHLEEDE

RON JARNAGIN

CYRUS NASSERI

MIKE THOMPSON

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVENUE, N.W.

WASHINGTON, D.C. 20005 (202) 234-4433

 EE-PI-96-001 COMMENT 59

(202) 234-4433 

PRESENT: (continued) 

EARL JONES 

BERT KALISCH 

DAVE LEWIS 

MARK LeFRANCE 

TED LELAND 

MARY ELLEN MURPHY 

MICHAEL McCABE 

JOE MATTINGLY 

STEVE NADEL 

MARK RAYMOND 

MIKE RIVEST 

SANDRA RUITER 

MARK RABA 

CHARLIE STEPHENS 

CHUCK SAMUELS 

MIKE STEIN 

TERRY THIELE 

BOB WISBEY 

MICHAEL WASSON 

LARRY WETHJE 

DONNA BANKS 

GLENN SCHLEEDE 

RON JARNAGIN 

CYRUS NASSERI 

MIKE THOMPSON 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

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P R O C E E D I N G S

Time: 9:05 a.m.

MODERATOR BROOKMAN: Let me welcome you

and thank you for being here and allowing us to start

just about on time. Appreciate that. We've got-a

full day ahead of us, and with no further ado, let me

turn it over to Michael McCabe for welcoming remarks.

MR. McCABE: I'm Michael McCabe. I'd like

to welcome everybody here. The majority of the faces

are rather familiar, but as far as introduction, I am

the Director of the Department's Office of Codes and

Standards. I have the responsibility for managing,

among other things, the Appliance Standards Program.

I'd like to welcome everybody here to

today's continuing process of meetings to help

implement procedures that we are committed to, as far

as the agency, for developing a new and open process

for establishing standards where they are technically

feasible and economically justified.

The workshops that we've had for the last

seven months or so have been in a variety of places.

I'd say this is probably the most hospitable. I was

just talking to a couple of people a few minutes ago,

reminiscing about some of the places where we 've been

over the last -- where I've been in the last couple of

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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WASHINGTON , D.C. 20005 (202) 234-4433

 EE-PI-96-001 COMMENT 59

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1 PRO C E E DIN G S 

2 Time: 9:05 a.m. 

3 MODERATOR BROOKMAN: Let me welcome you 

4 and thank you for being here and allowing us to start 

5 just about on time. Appreciate that. We've got·a 

.. 

6 full day ahead of us, and with no further ado, let me 

7 turn it over to Michael McCabe for welcoming remarks. 

8 MR. McCABE: I'm Michael McCabe. I'd like 

9 to welcome everybody here. The majority of the faces 

10 are rather familiar, but as far as introduction, I am 

11 the Director of the Department's Office of Codes and 

12 Standards. I have the responsibility for managing, 

13 among other things, the Appliance Standards Program. 

14 I'd like to welcome everybody here to 

15 today's continuing process of meetings to help 

16 implement procedures that we are committed to, as far 

17 as the agency, for developing a new and open process 

18 for establishing standards where they are technically 

19 feasible and economically justified. 

20 The workshops that we've had for the last 

21 seven months or so have been in a variety of places. 

22 I'd say this is probably the most hospitable. I was 

23 just talking to a couple of people a few minutes ago, 

24 reminiscing about some of the places where we've been 

25 over the last -- where I've been in the last couple of 

(202) 234-4433 

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years.

Almost 16 years to the day today we had a

hearing on proposed rule for appliance standards for

nine types of appliances. It was in the Postmaster

General's conference room in the new Post Office

building at 12th and Pennsylvania Avenue, and it was

99 degrees, near 100, 101 degrees, thereabouts,

outside. There were about 150 people at the hearing.

So it was about -- a few more than we have here today.

The air conditioning didn't work anywhere near as well

as it does here today. It's definitely an improved

environment, and people were falling like flies at

that meeting. Hopefully, we will all remain and join

in the discussion today.

My staff, which many people have dealt

with, are going to play a lot more principal role in

today's meeting than will I, but it's their turn. The

prioritization process -- it's a new one for us.

There are the data which we developed in conversations

with industry representatives and others. Some of it

is the best which we had. I'll have to admit that

it's not as good as it could be.

This is an opportunity for full and

complete discussion of it, offering alternatives,

suggestions as far as issues that need to be

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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 EE-PI-96-001 COMMENT 59

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1 years. 

2 Almost 16 years to the day today we had a 

3 hearing on proposed rule for appliance standards for 

4 nine types of appliances. It was in the Postmaster 

5 General's conference room in the new Post Office 

6 building at 12th and Pennsylvania Avenue, and it was 

7 99 degrees, near 100, 101 degrees, thereabouts, 

8 outside. There were about 150 people at the hearing. 

9 So it was about -- a few more than we have here today. 

10 The air conditioning didn't work anywhere near as well 

11 as it does here today. It's definitely an improved 

12 environment, and people were falling like flies at 

13 that meeting. Hopefully, we will all remain and join 

14 in the discussion today. 

15 My staff, which many people have dealt 

16 with, are going to playa lot more principal role in 

17 today's meeting than will I, but it's their turn. The 

18 prioritization process it's a new one for us. 

19 There are the data which we developed in conversations 

20 with industry representatives and others. Some of it 

21 is the best which we had. I'll have to admit that 

22 it's not as good as it could be. 

23 This is an opportunity for full and 

24 complete discussion of it, offering alternatives, 

25 suggestions as far as issues that need to be 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

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considered. I'dlike to get everybody's comments. We

are not here to defend the analysis and information

that we are presenting, because today's objective is

to receive your comment and your direction as to where

we^, are to go next.

The principal individual who will be

guiding us from my staff will be Ed Pollock who is my

Deputy, the Deputy Director of the Office of Codes and

Standards.

With that, what I' d like to do before Doug

gets into a number of administrative items is to ask

my staff to stand up and introduce themselves to you.

Most everybody is familiar to people in their own

industry that they've worked with, but not to the

group as a whole. We'll start with Ed Pollock to my

right.

MR. POLLOCK: I'm Ed Pollock, Deputy

Director of the Office of Codes and Standards. I

would ask that the staff, when they stand up and

introduce themselves, also say which products it is

that they are responsible for right now.

MR. LeFRANCE: I am Mark LeFrance. I work

with laundry products.

MR. RABA: Jim Raba. I work in electric

25 11 motors.

(202) 234.4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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 EE-PI-96-001 COMMENT 59

5 

1 considered. I'd like to get everybody's comments. We 

2 are not here to defend the analysis and information 

3 that we are presenting, because today's objective is 

4 to receive your comment and your direction as to where 

5 w~,are to go next. 

6 The principal individual who will be 

7 guiding us from my staff will be Ed Pollock who is my 

8 Deputy, the Deputy Director of the Office of Codes and 

9 Standards. 

10 Wi th that, what I'd like to do before Doug 

11 gets into a number of administrative items is to ask 

12 my staff to stand up and introduce themselves to you. 

13 Most everybody is familiar to people in their own 

14 industry that they've worked with, but not to the 

15 group as a whole. We'll start with Ed Pollock to my 

16 right. 

17 MR. POLLOCK: I'm Ed Pollock, Deputy 

18 Director of the Office of Codes and Standards. I 

19 would ask that the staff, when they stand up and 

20 introduce themselves, also say which products it is 

21 that they are responsible for right now. 

22 MR. LeFRANCE: I am Mark LeFrance. I work 

23 with laundry products. 

24 

25 motors. 

(202) 234-4433 

MR. RABA: Jim Raba. I work in electric 

NEAL R. GROSS 

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MS. EPPING: Kathi Epping, air

conditioners.

MR. NASSERI: Cyrus Nasseri, commercial

products and also furnaces.

MS. TWIG: Barbara Twig.

DR. BERLIN: Barry Berlin. I'm the

economist in the Office, and I work on all products.

MR. HUI: Bill Hui --

MS. WATSON: Ingrid Watson, kitchen

products.

MR. ADAMS: Carl Adams. I'm the team

leader for residential appliances.

MR. McCABE: Qonnie Laughlin, who is

sitting to Carl's left, isn't sure what she is, since

she does an awful lot and has played a major role in

pulling together much of what we have done and

accomplished in the last seven months, particularly

developing the interpretive rule that was discussed at

length yesterday. Qonnie has been invaluable to me in

putting that together.

MR. RAYMOND; Michael Raymond, central air

conditioners and refrigerators.

MR. McCABE: And the last one, but not the

least.

(202) 234-4433

MR. BALDUCCI: Anthony Balducci, electric

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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 EE-PI-96-001 COMMENT 59

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1 MS. EPPING: Kathi Epping, air 

2 conditioners. 

3 MR. NASSERI: Cyrus Nasseri, commercial 

4 products and also furnaces. 

5 MS. TWIG: Barbara Twig. 

6 DR. BERLIN: Barry Berlin. I'm the 

7 economist in the Office, and I work on all products. 

8 MR. HUI: Bill Hui 

9 MS. WATSON: Ingrid Watson, kitchen 

10 products. 

11 MR. ADAMS: Carl Adams. I'm the team 

12 leader for residential appliances. 

13 MR. McCABE: Qonnie Laughlin, who is 

14 sitting to Carl's left, isn't sure what she is, since 

15 she does an awful lot and has played a major role in 

16 pulling together much of what we have done and 

17 accomplished in the last seven months, particularly 

18 developing the interpretive rule that was discussed at 

19 length yesterday. Qonnie has been invaluable to me in 

20 putting that together. 

21 MR. RAYMOND; Michael Raymond, central air 

22 conditioners and refrigerators. 

23 

24 least. 

25 

(202) 234-4433 

MR. McCABE: And the last one, but not the 

MR. BALDUCCI: Anthony Balducci, electric 

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motors and dishwashers.

MR. McCABE: I'd like to welcome everybody

here and, with that, turn it back to Doug for

housekeeping.

MODERATOR BROOKMAN: Thank you, Michael.

I'd like to have everybody introduce themselves, and

give your organizational affiliation, if you would,

please, as we go along, so we have a sense of who is

in the room.

This workshop today is being taped. So as

we go through the day's work, it would be helpful if

you could say your name prior to making your comments,

and I'll try and keep reminding you to do that. it

will make a better record and, if you do that, it

allows the Department to come back to you and say,

what did you mean when you said that, and explore it

more fully.

Let's start over here with you, Dave. I

guess we 're going to try and use the microphones.

Will these mikes pick up, if they just stay in the

center of the table? Let's try that, rather than

force everybody to speak into a mike like this.

MR. LEWIS : Dave Lewis , Lennox.

MR. CHAPP : Terry Chapp , Modine.

MR. DeVUORO: Tony DeVuoro, Modine

(202) 234-4433

NEAP R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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 EE-PI-96-001 COMMENT 59

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1 motors and dishwashers. 

2 MR. McCABE: I'd like to welcome everybody 

3 here and, with that, turn it back to Doug for 

4 housekeeping. 

5 MODERATOR BROOKMAN: Thank you, Michael. 

6 I'd like to have everybody introduce themselves, and 

7 give your organizational affiliation, if you would, 

8 please, as we go along, so we have a sense of who is 

9 in the room. 

10 This workshop today is being taped. So as 

11 we go through the day's work, it would be helpful if 

12 you could say your name prior to making your comments, 

13 and I'll try and keep reminding you to do that. It 

14 will make a better record and, if you do that, it 

15 allows the Department to come back to you and say, 

16 what did you mean when you said that, and explore it 

17 more fully. 

18 Let's start over here with you, Dave. I 

19 guess we're going to try and use che microphones. 

20 Will these mikes pick up, if they just stay in the 

21 center of the table? Let's try that, rather than 

22 force eve~body to speak into a mike like this. 

23 

24 

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(202) 234-4433 

MR. LEWIS: Dave Lewis, Lennox. 

MR. CHAPP: Terry Chapp, Modine. 

MR. DeVUORO: Tony DeVuoro, 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

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Modine 

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Manufacturing.

MR. HOPKINSON: Phil Hopkinson, Square D

Company, transformers.

MR. STEIN: Mike Stein, MagneTek,

fluorescent ballasts.

MR. WISBEY: Bob Wisbey, Advanced

Transformer Company, fluorescent ballasts.

MR. BLEASBY: Peter Bleasby, Sylvania,

lamps as in lightbulbs.

MR. GRENNAN: Rich Grennan, Raytheon,

commercial laundry.

MR. MANTHEI: Phil Manthei, Raytheon

Appliances, commercial laundry.

MR. WEINGARTNER: Roland Weingartner,

Miele Appliances.

MR. HORSTMAN: Doug Horstman, Maytag.

MR. SAMUELS: Chuck Samuels, AHAM.

MR. JONES: Earl Jones, G.E. Appliances.

MS. GREINER: Linda Greiner, Frigidaire.

MR. THIELE: Terry Thiele, Frigidaire.

MS. FALONI: Suzanne Faloni, York

International.

MR. HOLT: John Holt, National Rural

Electric Cooperative Association.

MR. CURRY: Robert Curry, Plumbing

(202) 234-4433

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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 EE-PI-96-001 COMMENT 59 i j 8 

1 Manufacturing. 

2 MR. HOPKINSON: Phil Hopkinson, Square D 

3 Company, transformers. 

4 MR. STEIN: Mike Stein, MagneTek, 

5 fluorescent ballasts. 

6 MR. WISBEY: Bob Wisbey, Advanced 

7 Transformer Company, fluorescent ballasts. 

8 MR. BLEASBY : Peter Bleasby , Sylvania, 

9 lamps as in lightbulbs. 

10 MR. GRENNAN: Rich Grennan, Raytheon, 

11 commercial laundry. 

12 MR. MANTHE I : Phil Manthei, Raytheon 

13 Appliances, commercial laundry. 

14 MR. WEINGARTNER: Roland Weingartner, 

15 Miele Appliances. 

16 MR. HORSTMAN: Doug Horstman, May tag. 

17 MR. SAMUELS: Chuck Samuels, AHAM. 

18 MR. JONES: Earl Jones, G.E. Appliances. 

19 MS. GREINER: Linda Greiner, Frigidaire. 

20 MR. THIELE: Terry Thiele, Frigidaire. 

21 MS. FALONI: Suzanne Faloni, York 

22 International. 

23 MR. HOLT: John HoI t , National Rural 

24 Electric Cooperative Association. 

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(202) 234-4433 

MR. CURRY: Robert Curry, 

NEAL A. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

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Manufacturers Institute.

MR. FOSTER: Chuck Foster, EEI.

MR. WETHJE: Larry Wethje with ARI.

MR. CRAWFORD: Jim Crawford, TraneAmerican Standard.

MR. MATTINGLY: Joe Mattingly --

MR. DUBOIS: Terry Dubois, U.S. Department

of Energy, Systems Analysis.

MS. BANKS: Donna Banks, The American Gas

Association.

MR. BRODERICK: Jim Broderick, The

American Gas Association, government relations.

MR. ANDERSON: Vince Anderson with

Whirlpool.

MR. STEPHENS: Charlie Stephens,

Department of Energy.

MR. WASSON: Michael Wasson, ASKO

Appliances.

MR. GOLDSTEIN: David Goldstein, NRDC.

MR. BEGOSKE: Tim Begoske --

MS. RUITER: Sandy Ruiter with

Underwriter's Laboratories.

MR. HAAG: Wilbur Haag, A.O. Smith Water

Products Company.

MS. MURPHY: Mary Ellen Murphy, Bracey

(202) 234-4433

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1 Manufacturers Institute. 

2 MR. FOSTER: Chuck Foster, EEl. 

3 MR. WETHJE: Larry Wethje with ARI. 

4 MR. CRAWFORD: Jim Crawford, Trane5 American Standard. 

6 MR. MATTINGLY: Joe Mattingly 

7 MR. DUBOIS: Terry Dubois, U. S. Department 

8 of Energy, Systems Analysis. 

9 MS. BANKS: Donna Banks, The American Gas 

10 Association. 

11 MR. BRODERICK: Jim Broderick, The 

12 American Gas Association, government relations. 

13 MR. ANDERSON: Vince Anderson with 

14 Whirlpool. 

15 MR. STEPHENS: Charlie Stephens, 

16 Department of Energy. 

17 MR. WASSON: Michael Wasson, ASKO 

18 Appliances. 

19 MR. GOLDSTEIN: David Goldstein, NRDC. 

20 MR. BEGOSKE: Tim Begoske 

21 MS. RUITER: Sandy Rui ter wi th 

22 Underwrit~r's Laboratories. 

23 MR. HAAG: Wilbur Haag, A.O. Smith Water 

24 Products Company. 

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MS. MURPHY: Mary Ellen Murphy, Bracey 

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Williams and Company, for Clorox.

MR. JARNAGIN: Ron Jarnagin, Pacific

Northwest National Laboratory.

MR. SECREST: Tom Secrest, Pacific

Northwest National Laboratory.

MR. FOLEY: Gene Foley, The Alliance to

Save Energy.

MR. NADEL: Steve Nadel, American Council

for an Energy Efficient Economy.

MODERATOR BROOKMAN: Thank you. There are

a few in the front of the room.

MR. FRIEDRICHS: Mark Friedrichs from the

Department of Energy Police Office.

MR. RIVEST: Mike Rivest from Arthur D.

Little.

MODERATOR BROOKMAN: For those of you that

have just joined us, please take a seat and make

yourself comfortable, and we'll do another round of

introductions later for those that joined us a few

minutes late.

Again, let me welcome you and thank you

for allowing us to start on time. I think we have a

full day ahead of us.

The purpose of this workshop, as is

written on your agenda, is to receive your input on

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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1 Williams and Company, for Clorox. 

2 MR. JARNAGIN: Ron Jarnagin, Pacific 

3 Northwest National Laboratory. 

4 MR. SECREST: Torn Secrest, Pacific 

5 Northwest National Laboratory. 

6 MR. FOLEY: Gene Foley, The Alliance to 

7 Save Energy. 

8 MR. NADEL: Steve Nadel, American Council 

9 for an Energy Efficient Economy. 

10 MODERATOR BROOKMAN: Thank you. There are 

11 a few in the front of the room. 

12 MR. FRIEDRICHS: Mark Friedrichs from the 

13 Department of Energy Police Office. 

14 MR. RIVEST: Mike Rivest from Arthur D. 

15 Little. 

16 MODERATOR BROOKMAN: For those of you that 

17 have just joined us, please take a seat and make 

18 yourself comfortable, and we'll do another round of 

19 introductions later for those that joined US a few 

20 minutes late. 

21 Again, let me welcome you and thank you 

22 for allowing uS to start on time. I think we have a 

23 full day ahead of us. 

24 The purpose of this workshop, as is 

2S written on your agenda, is to receive your input on 

(202) 2344433 

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proposed draft product data sheets which we are going

to go through today in detail and hear your comments.

I heard Michael McCabe say at the outset

that some of the analysis isn't as good as the

Department would like it to be. This is your

opportunity to try and make it as good as you can, and

I would invite you to speak clearly about how it can

be improved.

The outcomes of this workshop, which are

also written on this agenda, is that this, plus

additional stakeholder input, will lead to the

Department ' s issuing in October a final set of

rulemaking priorities and the schedules for all

priority rulemakings it anticipates in the next two

years.

So that's where we're headed. That's

where the Department is headed with this activity

today and in subsequent activities. The agenda, as

listed -- We are now doing the first segment, which is

opening remarks, introductions, and I'm reviewing the

agenda.

We're going to have a brief review of the

evaluation criteria that are used in considering how

someone -- how one of these products would be listed

or prioritized. We'll take a quick coffee break.

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11 

1 proposed draft product data sheets which we are going 

2 to go through today in detail and hear your comments. 

3 I heard Michael McCabe say at the outset 

4 that some of the analysis isn't as good as the 

5 Department would like it to be. This is your 

6 opportunity to try and make it as good as you can, and 

7 I would invite you to speak clearly about how it can 

8 be improved. 

9 The outcomes of this workshop, which are 

10 also written on this agenda, is that this, plus 

11 additional stakeholder input, will lead to the 

12 Department's issuing in October a final set of 

13 rulemaking priorities and the schedules for all 

14 priority rulemakings it anticipates in the next two 

15 years. 

16 So that's where we're headed. That's 

17 where the Department is headed with this activity 

18 today and in subsequent activities. The agenda, as 

19 listed -- We are now doing the first segment, which is 

20 opening remarks, introductions, and I'm reviewing the 

21 agenda. 

22 We're going to have a brief review of the 

23 evaluation criteria that are used in considering how 

24 someone -- how one of these products would be listed 

25 or prioritized. We'll take a quick coffee break. 

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We're going to go from the coffee break to

a discussion of the individual draft product data

sheets, and the order as listed on this handout --

Hopefully, all of you -- Did all of you receive the

handouts? All of you got a copy of the handouts?

They are listed alphabetically by trade association,

and that's how we intend to take them up.

Ed, when he starts off, he's going to say

why they are organized that way.

We will take a lunch break. You're on

your own for lunch. We're going to come back and take

up the additional product data sheets that we haven't

covered yet, and then after the afternoon break, the

group collectively are going to see what they can do

to work towards a priority ranking, talk about how to

do it procedurally and the practicalities of it.

I want to end the day by talking about how

to improve future prioritization workshops. It's

envisioned that some format like this will be done at

least on an annual basis to get your input and to help

the Department to figure out which rules should be

prioritized for action.

Are there questions at the outset on the

agenda? If we uncover a more dynamic pathway here,

we'll take it. We just haven't figured it out yet.

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12 

1 We're going to go from the coffee break to 

2 a discussion of the individual draft product data 

3 sheets, and the order as listed on this handout --

4 Hopefully, all of you -- Did all of you receive the 

5 handouts? All of you got a copy of the handouts? 

6 They are listed alphabetically by trade association, 

7 and that's how we intend to take them up. 

8 Ed, when he starts off, he's going to say 

9 why they are organized that way. 

10 We will take a lunch break. You're on 

11 your own for lunch. We're going to come back and take 

12 up the additional product data sheets that we haven't 

13 covered yet, and then after the afternoon break, the 

14 group collectively are going to see what they can do 

15 to work towards a priority ranking, talk about how to 

16 do it procedurally and the practicalities of it. 

1 7 I want to end the day by talking about how 

18 to improve future prioritization workshops. It's 

19 envisioned that some format like this will be done at 

20 least on an annual basis to get your input and to help 

21 the Department to figure out which rules should be 

22 prioritiz~d for action. 

23 Are there questions at the outset on the 

24 agenda? If we uncover a more dynamic pathway here, 

25 we'll take it. 

(202)2~ 

We just haven't figured it out yet. 

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Questions at the outset? I don't see any.

How many of you were at the March

.workshop? Okay. So most of you were there. How many

of you were here yesterday to talk about the

interpretive rule? Okay. Thank you.

Just a few very simple ground rules which

this group has been kind enough to adhere to in the

past: I'd like to request that we speak one at a

time. I'd like also to ask that, as you're listening,

that you listen as an ally where this is a cooperative

effort to try and come forward with good information.

Good information is the kind of thing that will make

all of us prosper in this.

I' d like to ask that we focus on solutions

as we're going through this, and that will keep moving

the ball forward in that cooperative spirit. We'd

like you to say what you're thinking. Better to have

it out on the table and to hear what you're thinking

at this point, and all of us will do better if we put

it right out there.

Since this is a taped session, I'd like

you to say your name prior to giving your comments on

specifics -- on the specifics of the product or

whatever it is you're commenting on.

I think that is basically it. Ed, are you

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1 Questions at the outset? I don't see any. 

2 How many of you were at the March 

3 .workshop? Okay. So most of you were there. How many 

4 of you were here yesterday to talk about the 

5 interpretive rule? Okay. Thank you. 

6 Just a few very simple ground rules which 

7 this group has been kind enough to adhere to in the 

8 past: I'd like to request that we speak one at a 

9 time. I'd like also to ask that, as you're listening, 

10 that you listen as an ally where this is a cooperative 

11 effort to try and come forward with good information. 

12 Good information is the kind of thing that will make 

13 all of us prosper in this. 

14 I'd like to ask that we focus on solutions 

15 as we're going through this, and that will keep moving 

16 the ball forward in that cooperative spirit. We'd 

17 like you to say what you're thinking. Better to have 

18 it out on the table and to .hear what you're thinking 

19 at this point, and all of us will do better if we put 

20 it right out there. 

21 Since this is a taped session, I'd like 

22 you to say your name prior to giving your comments on 

23 specifics on the specifics of the product or 

24 whatever it is you're commenting on. 

25 

(202) 234-4433 

I think that is basically it. Ed, are you 

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going to do the first segment on your criteria? Okay.

Additional comments, questions, at the outset? Yes,

ma'am. Would you speak into the microphone, please?

I'm going to keep reminding people at the outset --

and your name?

MS. RUITER: Sandy Ruiter, Underwriters

Laboratories. The material you FAX'ed on the 11th of

June, draft -- can that stuff be thrown away? May it

be thrown away?

MODERATOR BROOKMAN: Yes. The current

draft supersedes all previous drafts. Yes. What is

passed out today, yes.

Additional comments, questions, at the

outset? Okay, I think we're about to begin.

MR. POLLOCK: Let's start off by reminding

everyone that what we're here to do today is

prioritize the work that we'll be doing during the

next year and, to some extent, the following year as

far as standards rulemaking; but there is another

large part of our program which deals with the testing

of the products to ensure that they are -- or to

define the measurement of energy efficiency that's

being used, as well as, in the case of the commercial

products, the labeling of that information as it

applies to the product.

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14 

1 going to do the first segment on your criteria? Okay. 

2 Additional comments, questions, at the outset? Yes, 

3 ma'am. Would you speak into the microphone, please? 

4 I'm going to keep reminding people at the outset --

5 and your name? 

6 MS. RUITER: Sandy Ruiter, Underwriters 

7 Laboratories. The material you FAX'ed on the 11th of 

8 June, draft -- can that stuff be thrown away? May it 

9 be thrown away? 

10 MODERATOR BROOKMAN: Yes. The current 

11 draft supersedes all previous drafts. Yes. What is 

12 passed out today, yes. 

13 Additional comments, questions, at the 

14 outset? Okay, I think we're about to begin. 

15 MR. POLLOCK: Let's start off by reminding 

16 everyone that what we're here to do today is 

17 prioritize the work that we'll be doing during the 

18 next year and, to some extent, the following year as 

19 far as standards rulemaking; but there is another 

20 large part of our program which deals with the testing 

21 of the products to ensure that they are - - or to 

22 define the measurement of energy efficiency that's 

23 being used, as well as, in the case of the commercial 

24 products, the labeling of that information as it 

25 applies to the product. 

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So while we're looking at what areas we'll

do the standards rulemaking in, when we're looking at

our total budget and the ability of us to complete

rulemakings during the next year, keep in the backs of

ydur minds that we are limited to how many of these

rules we can cover during the next year by the fact

that we have to do this other work also.

In some cases, tests will have to be

completed, and revisions to the testing will have to

be completed before we go on to the rulemaking and the

final rule. In no case will we issue a final rule for

standards if we still haven't -- Most people know

that, but there have been some questions in the past.

For today what I would propose we do is to

go through the discussion, as Doug says, in this

order. If there are people, beginning with AHAM and

the ARI products, the GAMA products and the NEMA

products -- If there are people who have travel plans

who are concerned about leaving early in the

afternoon, to accommodate them we will consider

adjusting this order in order to make sure that the

products that they are interested in are covered

before they leave.

Why we are grouping them by product like

this is that there is the issue of cumulative burden,

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15 

1 So while we're looking at what areas we'll 

2 do the standards rulemaking in, when we're looking at 

3 ,our total budget and the ability of us to complete 

4 rulemakings during the next year, keep in the backs of 

5 your minds that we are limited to how many of these 

6 'rules we can cover during the next year by the fact 

7 that we have to do this other work also. 

8 In some cases, tests will have to be 

9 completed, and revisions to the testing will have to 

10 be completed before we go on to the rulemaking and the 

11 final rule. In no case will we issue a final rule for 

12 standards if we still haven't - - Most people know 

13 that, but there have been some questions in the past. 

14 For today what I would propose we do is to 

15 go through the discussion, as Doug says, in this 

16 order. If there are people, beginning with AHAM and 

17 the ARI products, the GAMA products and the NEMA 

18 products -- If there are people who have travel plans 

19 who are concerned about leaving early in the 

20 afternoon, to accommodate them we will consider 

21 adjusting this order in order to make sure that the 

22 products that they are interested in are covered 

23 before they leave. 

24 Why we are grouping them by product like 

25 this is that there is the issue of cumulative burden, 

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and so we wanted to talk about products that bigger

manufacturers may be interested in, more or less,

together in one group.

There's the other side of that. There may

be some cases -- in the case of, for instance, an air

conditioner -- where the two products are actually a

system for space conditioning and, therefore , instead

of cumulative burden issue, we may want to be talking

about bringing those two rulemakings together so that

we minimize the burden by dealing with them as

systems.

So those are the types of things we want

comments from manufacturers as we go through these

data sheets. Those are the types of issues that we

need to identify so, as we're planning our schedule

and our workload for the next couple of years, we can

factor that into the schedules that we ultimately

develop on the information which you provide to us

here today.

You don't have this information. I'm just

going to put it up here. You can probably read it,

but I want to go over it briefly.

What we are trying to do today is to come

up with a grouping of the products. So, therefore, I

want to emphasize from the very beginning that the

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1 and so we wanted to talk about products that bigger 

2 manufacturers may be interested in, more or less, 

3 together in one group. 

4 There I S the other side of that. There may 

5 be some cases -- in the case of, for instance, an air 

6 conditioner -- where the two products are actually a 

7 system for space conditioning and, therefore, instead 

8 of cumulative burden issue, we may want to be talking 

9 about bringing those two rulemakings together so that 

10 we minimize the burden by dealing with them as 

11 systems. 

12 So those are the types of things we want 

13 comments from manufacturers as we go through these 

14 data sheets. Those are the types of issues that we 

15 need to identify so, as we're planning our schedule 

16 and our workload for the next couple of years, we can 

17 factor that into the schedules that we ultimately 

18 develop on the information which you provide to us 

19 here today. 

20 You doni t have this information. Ilm just 

21 going to put it up here. You can probably read it, 

22 but I want to go over it briefly. 

23 What we are trying to do today is to come 

24 up with a grouping of the products. So, therefore, I 

25 want to emphasize from the very beginning that the 

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actual placement -- where we place the decimal point

on the numbers for energy savings are not so important

as a relative ranking of the different products.

We basically have come up with three

different groupings which we expect to be able to

develop out of the information on the product data

sheets that we've given to you in the handout. That

is, high priority products which, for whatever reason,

the issues that we'll discuss today we should place

our primary emphasis on during the next year.

These are rules which will have high

energy savings or ones which we've completed most of

the analysis for. So we can quickly bring them to

completion into the final rule and put them out.

The second group are those in the medium

level which will be ones that we'll be primarily

focusing on during the following year . However, I

should emphasize that we do expect to be doing some

preliminary work on those products during this

following year , depending on where -- how much funding

Congress gives us and where other issues and workload

go. So that --

MR. CURRY : Could you describe following

year, this year?

MR. POLLOCK; Okay . I'm talking about

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1 actual placement where we place the decimal point 

2 on the numbers for energy savings are not so important 

3 as a relative ranking of the different products. 

4 We basically have come up with three 

5 different groupings which we expect to be able to 

6 develop out of the information on the product data 

7 sheets that we've given to you in the handout. That 

8 is, high priority products which, for whatever reason, 

9 the issues that we'll discuss today we should place 

10 our primary emphasis on during the next year. 

11 These are rules which will have high 

12 energy savings or ones which we've completed most of 

13 the analysis for. So we can quickly bring them to 

14 completion into the final rule and put them out. 

15 The second group are those in the medium 

16 level which will be ones that we'll be primarily 

17 focusing on during the following year. However, I 

18 should emphasize that we do expect to be doing some 

19 preliminary work on those products during this 

20 following year, depending on where - - how much funding 

21 Congress gives us and where other issues and workload 

22 go. So t~at --

23 MR. CURRY: Could you describe following 

24 year, this year? 

25 MR • POLLOCK; Okay. I'm talking about 

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fiscal year, 1997 fiscal year and 1998 fiscal year,

which starts in October of each year.

MR. CURRY: Rob Curry. So high priority

is fiscal year 1996. Medium priority --

MR. POLLOCK: 1997. Ninety-six is almost

-- yes.

MR. CURRY; Okay. So high priority is

fiscal year 1997?

MR. POLLOCK: Right. During the -- For

the medium priority group, we're looking at doing the

preliminary ground work. We'll begin to collect

information on the products. What are the design

options which should be considered in efficiency for

the product? How are we going to go about getting

that information on the cost for it, the economics of

the product, the performance of it? How do we model

it or attain the information that we need for decision

making, but we won't get into heavy analytical work on

those products until 1998.

Then there's the bottom group, and those

are those products which have very low energy savings

or, for some reason such as dates that are established

in the law, we should not be moving forward with a

rulemaking at this time; because they either, as I

said, have a low savings or else something that's

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1 fiscal year, 1~97 fiscal year and 1998 fiscal year, 

2 which starts in October of each year. 

3 MR. CURRY: Rob Curry. So high priority 

4 is fiscal year 1996. Medium priority --

5 MR. POLLOCK: 1997. Ninety-six is almost 

6 yes. 

7 MR. CURRY; Okay. So high priority is 

8 fiscal year 1997? 

9 MR. POLLOCK: Right. During the -- For 

10 the medium priority group, we're looking at doing the 

11 prel iminary ground work. We'll begin to collect 

12 information on the products. What are the design 

13 options which should be considered in efficiency for 

14 the product? How are we going to go about getting 

15 that information on the cost for it, the economics of 

16 the product, the performance of it? How do we model 

17 it or attain the information that we need for decision 

18 making, but we won't get into heavy analytical work on 

19 those products until 1998. 

20 Then there's the bottom group, and those 

21 are those products which have very low energy savings 

22 or, for some reason such as dates that are established 

23 in the law, we should not be moving forward with a 

24 rulemaking at this time; because they either, as I 

25 said, have a low savings or else something that 's 

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triggered in the future.

For example, the commercial products are

established as being when ASHRAE 90.1 changes the

standard level for commercial central air

conditioning, furnaces, for the space -- or for water

heating. Then the Department is direct to consider

those standards that are in that new version of ASHRAE

1990.

So because they are in the process right

now of revising those levels, but that has not been

published as a final version of the revised 90.1, we

would not be considering them as either high or medium

level at this time, but in subsequent prioritizations

after ASHRAE has published their proposal or their

final decision on what those levels should be, then we

would move forward in putting them in the priority and

doing the rulemaking on them.

MODERATOR BROOKMAN: Maybe there are

questions at this point on the high priority, medium

priority, and low priority standard. Yes?

MR. THIELE : Terry Thiele, Frigidaire.

I'm confused, because the description of high priority

was predicated upon DOE resources , but your

description of low priority was based upon energy

savings. Are you prioritizing based upon what DOE can

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1 triggered in the future. 

2 For example, the commercial products are 

3 established as being when ASHRAE 90.1 changes the 

4 standard level for commercial central air 

5 conditioning, furnaces, for the space -- or for water 

6 heating. Then the Department is direct to consider 

7 those standards that are in that new version of ASHRAE 

8 1990. 

9 So because they are in the process right 

10 now of revising those levels, but that has not been 

11 published as a final version of the revised 90.1, we 

12 would not be considering them as either high or medium 

13 level at this time, but in subsequent prioritizations 

14 after ASHRAE has published their proposal or their 

15 final decision on what those levels should be, then we 

16 would move forward in putting them in the priority and 

17 doing the rulemaking on them. 

18 MODERATOR BROOKMAN: Maybe there are 

19 questions at this point on the high priority, medium 

20 priority, and low priority standard. Yes? 

21 MR. THIELE: Terry Thiele, Frigidaire. 

22 I'm confused, because the description of high priority 

23 was predicated upon DOE resources, but your 

24 description of low priority was based upon energy 

25 savings. Are you prioritizing based upon what DOE can 

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do next year , regardless of how much energy gets saved

off of that rule ? Are you prioritizing based upon the

act of the rulemaking?

MR. POLLOCK: I'm sorry for the confusion,

Terry. We are prioritizing on the impact of the

rulemaking. The issue will be where we draw that line

between each one of these groups -- Well, the low

priority we would not do, but where we draw the line

between the high priority and the medium priority will

have to depend on our resources.

So there may be some products that, in our

discussions today, we might have some debate about

whether they should go in high priority or in low

priority, and in that case then we would -- we might

put those in a separate category, and it would fall

one way or the other, depending on the level of

resources.

MR. THIELE: The reason I ask is, if

you've got a rule ready to go where there is little to

virtually no energy savings, does that, nonetheless,

remain a high priority item because it's ready to go?

MR. POLLOCK: Okay. That is the other

side of it and, yes, resources do come into play in

that case; because it is something that we could

25 11 complete and, therefore, a minimum amount of resources

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1 do next year, regardless of how much energy gets saved 

2 off of that rule? Are you prioritizing based upon the 

3 act of the rulemaking? 

4 MR. POLLOCK: I'm sorry for the confusion, 

5 We are prioritizing on the impact of the 

6 . rulemaking. The issue will be where we draw that line 

7 between each one of these groups - - Well, the low 

8 priority we would not do, but where we draw the line 

9 between the high priority and the medium priority will 

10 have to depend on our resources. 

11 So there may be some products that, in our 

12 discussions today, we might have some debate about 

13 whether they should go in high priority or in low 

14 priority, and in that case then we would -- we might 

15 put those in a separate category, and it would fall 

16 one way or the other, depending on the level of 

17 resources. 

18 MR. THIELE: The reason I ask is, if 

19 you've got a rule ready to go where there is little to 

20 virtually no energy savings, does that, nonetheless, 

21 remain a high priority item because it's ready to go? 

22 MR. POLLOCK: Okay. That is the other 

23 side of it and, yes, resources do come into play in 

24 that case; because it is something that we could 

25 complete and, therefore, a minimum amount of resources 

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for us to complete . So there are the two paths in

this prioritization that we are doing.

This will be different from what happens

in the future where we have already established the

priority for work that's in process , and we would be

only adding new tasks or new products to be considered

in grouping in the priority.

So we do have a little bit different

situation and the criteria is a little bit different

for the workshop that we're going through today,

because we do have to take a look at the work that has

already been completed, the amount of resources that

we would have to expend in order to complete that

rulemaking, and that ' s a tradeoff to energy savings,

which would be -- and other issues which I've

discussed , which would be of more major concern later

on where we ' ve already established some schedule for

the work that ' s in process.

MODERATOR BROOKMAN: Dave? I saw Dave,

and then to this gentleman in the back.

MR. LEWIS : Dave Lewis, Lennox . Ed, could

you -- You're describing then that the high priority

products would start October ' 96 through October '97.

That would be the work , and it would begin with a

ANPR. Is that what you're saying?

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21 

1 for us to complete. So there are the two paths in 

2 this prioritization that we are doing. 

3 This will be different from what happens 

4 in the future where we have already established the 

5 p~iority for work that's in process, and we would be 

6 only adding new tasks or new products to be considered 

7 in grouping in the priority. 

8 So we do have a little bit different 

9 situation and the criteria is a little bit different 

10 for the workshop that we're going through today, 

11 because we do have to take a look at the work that has 

12 already been completed, the amount of resources that 

13 we would have to expend in order to complete that 

14 rulemaking, and that's a tradeoff to energy savings, 

15 which would be and other issues which I've 

16 discussed, which would be of more major concern later 

17 on where we've already established some schedule for 

18 the work that's in process. 

19 MODERATOR BROOKMAN: Dave? I saw Dave, 

20 and then to this gentleman in the back. 

21 MR. LEWIS: Dave Lewis I Lennox. Ed, could 

22 you -- You're describing then that the high priority 

23 products would start October '96 through October '97. 

24 That would be the work, and it would begin with a 

25 ANPR. Is that what you're saying? 

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MR. POLLOCK; Well, that takes us back to

the process approval we were talking about, and we

have defined that process as saying that we begin and

a major chunk of the work is done prior to publishing

the advance notice of proposed rulemaking. The data

collection, the determination of the model and the

actual preliminary analysis will all be completed

prior to publishing that advanced notice.

MR. LEWIS: So just in final, you're

really talking about when you will begin a process.

You're not necessarily flagging the conclusion of a

process.

MODERATOR BROOKMAN: Mark Friedrichs has

a follow-on comment.

MR. FRIEDRICHS: You have to keep in mind

that there are a number of rulemakings that are in the

midst of the process right now, and as part of the

process improvement, we've talked about at what stage

we would restart those product standard development

efforts.

In some cases, we still -- We may be after

a proposed. rule and be going to a final rule. In some

cases, we're going back to an advanced notice. In

most cases , actually, we're going back to some form of

advanced notice. So there is a little uncertainty

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1 MR. POLLOCK; Well, that takes us back to 

2 the process approval we were talking about, and we 

3 have defined that process as saying that we begin and 

4 a major chunk of the work is done prior to publishing 

5 the advance notice of proposed rulemaking. The data 

6 collection, the determination of the model and the 

7 actual preliminary analysis will all be completed 

8 prior to publishing that advanced notice. 

9 MR. LEWIS: So just in final, you're 

10 really talking about when you will begin a process. 

11 You're not necessarily flagging the conclusion of a 

12 process. 

13 MODERATOR BROOKMAN: Mark Friedrichs has 

14 a follow-on comment. 

15 MR. FRIEDRICHS: You have to keep in mind 

16 that there are a number of rulemakings that are in the 

17 midst of the process right now, and as part of the 

18 process improvement, we've talked about at what stage 

19 we would restart those product standard development 

20 efforts. 

21 In some cases, we still - - We may be after 

22 a proposed. rule and be going to a final rule. In some 

23 cases, we're going back to an advanced notice. In 

24 most cases, actually, we're going back to some form of 

25 advanced notice. 

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So there is a little uncertainty 

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about where we would start the process.

What Ed is saying is that any high

priority product for which we have adequate resources

to proceed, we would commit those resources in '97 and

get as far as we can with those . We're not committing

to complete the process in '97. Of course, we all

recognize that the full rulemaking process we expect

to take two or three years for any product.

So high priority simply means that we're

going to commit those resources necessary to move

forward at the beginning of fiscal year '97, October

First.

MR. LEWIS: Thank you.

MR. SCHLEEDE: My name is Glenn Schleede.

I had some rather basic questions -- I'm new to the

process -- that I probably should have asked earlier,

but I thought they were coming up under this topic,

but this has a different meaning than I interpreted on

the agenda.

Can you tell me where the basic

information is, like how you do your cost

calculations, what you do with -- what you use in the

way of energy price forecasts, how you define energy

security, all those basic stuff? Is that written down

someplace that a newcomer can get hold of it, or where

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i I 

23 

1 about where we would start the process. 

2 What Ed is saying is that any high 

3 priority product for which we have adequate resources 

4 to proceed, we would commit those resources in '97 and 

5 get as far as we can with those. We're not committing 

6 to complete the process in '97. Of course, we all 

7 recognize that the full rulemaking process we expect 

8 to take two or three years for any product. 

9 So high priority simply means that we're 

10 going to commit those resources necessary to move 

11 forward at the beginning of fiscal year '97, October 

12 First. 

13 MR. LEWIS: Thank you. 

14 MR. SCHLEEDE: My name is Glenn Schleede. 

15 I had some rather basic questions -- I'm new to the 

16 process -- that I probably should have asked earlier, 

17 but I thought they were coming up under this topic, 

18 but this has a different meaning than I interpreted on 

19 the agenda. 

20 Can you tell me where the basic 

21 information is, like how you do your cost 

22 calculations, what you do with -- what you use in the 

23 way of energy price forecasts, how you define energy 

24 security, all those basic stuff? Is that written down 

25 someplace that a newcomer can get hold of it, or where 

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is it, because it -- All that basic stuff seems not to

be present in any document I've seen so far.

A further question: Where does one get

copies of all the little studies referred to in the

footnotes on these data sheets?

MR. POLLOCK: The best place to find the

type of information you're asking for is, for those

products where we have done a notice of proposed

rulemaking or a final rule, we issue as a complement

to the information that's in the Federal Register a

document we call the Technical Support Document.

That has fairly extensive description of

the analytical methods that we go through and how the

different values that you're referring to are

calculated.

MR. SCHLEEDE: A while back, as I recall,

it was published in the Federal Register a description

of how the cost calculation process worked. This was

done a couple of years ago when you were looking at

including externalities in the process. Does that --

Is that set of rules -- Is that what you follow?

There must be some generic set of rules as

to what you -- how you make calculations, what price

forecasts you use, and I'm particularly interested in

price forecasts since those have changed so much.

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1 is it, because it All that basic stuff seems not to 

2 be present in any document I've seen so far. 

3 A further question: Where does one get 

4 copies of all the little studies referred to in the 

5 footnotes on these data sheets? 

6 MR. POLLOCK: The best place to find the 

7 type of information you're asking for is, for those 

8 products where we have done a notice of proposed 

9 rulemaking or a final rule, we issue as a complement 

10 to the information that's in the Federal Register a 

11 document we call the Technical Support Document. 

12 That has fairly extensive description of 

13 the analytical methods that we go through and how the 

14 different values that you're referring to are 

15 calculated. 

16 MR. SCHLEEDE: A while back, as I recall, 

17 it was published in the Federal Register a description 

18 of how the cost calculation process worked. This was 

19 done a couple of years ago when you were looking at 

20 including externalities in the process. Does that 

21 Is that set of rules -- Is that what you follow? 

22 There must be some generic set of rules as 

23 to what you -- how you make calculations, what price 

24 forecasts you use, and I'm particularly interested in 

25 price forecasts since those have changed so much. 

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MR.-_POLLOCK: I'll let Mark respond to

that.

MR. FRIEDRICHS: Unfortunately, we tried

to pull together for this exercise the best

information we had available. Sometimes this

'information was several years old. One of the reasons

for this meeting is to try to find out whether or not

there's better information.

As Ed mentioned, all we're trying to do

here is not determine specifically what savings are

going to result from specific design options. That's

going to happen in the standards development process.

This information isn't really going to go

any further beyond the priority setting process. So

we're just trying to get the best information we can

about the relative energy, economic, environmental

impacts of standards in different areas, as well as

those other factors discussed on the sheets.

Because the Technical Support Documents

were developed at different times, that are referenced

-- some, I think, go back to 1990; some were in 1993

to 1995 -- they each use slightly different price

forecasts, because each year we update the price

forecasts based on what the Energy Information

Administration does.

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1 MR. POLLOCK: I'll let Mark respond to 

2 that. 

3 MR. FRIEDRICHS: Unfortunately, we tried 

4 to pull together for this exercise the best 

5 information we had available. Sometimes this 

6 'information was several years old. One of the reasons 

7 for this meeting is to try to find out whether or not 

8 there's better information. 

9 As Ed mentioned, all we're trying to do 

10 here is not determine specifically what savings are 

11 going to result from specific design options. That's 

12 going to happen in the standards development process. 

13 This information isn't really going to go 

14 any further beyond the priority setting process. So 

15 we're just trying to get the best information we can 

16 about the relative energy, economic, environmental 

17 impacts of standards in different areas, as well as 

18 those other factors discussed on the sheets. 

19 Because the Technical Support Documents 

20 were developed at different times, that are referenced 

21 some, I think, go back to 1990; some were in 1993 

22 to 1995 they each use slightly different price 

23 forecasts, because each year we update the price 

24 forecasts based on what the Energy Information 

25 Administration does. 

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Sometimes they've used slightly different

assumptions about discount rates for calculating the

new present value of benefits. So, unfortunately,

there isn't one single methodology, but at this stage

we don't think that single methodology is necessary;

because we're really just trying to get an idea of

relative impacts of possible standards in different

categories. We're not looking for a lot of precision.

MR. SCHLEEDE: I hate to beat this into

the ground, but still there must be some kind of a

process that you've got that you even make these rough

estimates. I mean, when EIA changes their price

forecast by 38 percent, that must have some

significance --

MR. FRIEDRICHS: But if you're looking --

MR. SCHLEEDE: and unless you're

willing to divulge where this stuff is --

MR. FRIEDRICHS: In each case, the process

used, discount rates, price forecast, everything, are

described in the Technical Support Documents.

MR. SCHLEEDE: Are they available?

MR. FRIEDRICHS: Those are available and,

if you have difficulty getting them, I'm sure that Ed

and his staff can locate them for you. I'm just

saying that there is not a single set of assumptions

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1 Sometimes they've used slightly different 

2 assumptions about discount rates for calculating the 

3 new present value of benefits. So, unfortunately, 

4 there isn't one single methodology, but at this stage 

5 we don't think that single methodology is necessary; 

6 because we're really just trying to get an idea of 

7 relative impacts of possible standards in different 

8 categories. We're not looking for a lot of precision. 

9 MR. SCHLEEDE: I hate to beat this into 

10 the ground, but still there must be some kind of a 

11 process that you've got that you even make these rough 

12 estimates. I mean, when EIA changes their price 

13 forecast by 38 percent, that must have some 

14 significance 

15 MR. FRIEDRICHS: But if you're looking --

16 MR. SCHLEEDE: and unless you're 

17 willing to divulge where this stuff is --

18 MR. FRIEDRICHS: In each case, the process 

19 used, discount rates, price forecast, everything, are 

20 described in the Technical Support Documents. 

21 MR. SCHLEEDE: Are they available? 

22 MR. FRIEDRICHS: Those are available and, 

23 if you have difficulty getting them, I'm sure that Ed 

24 and his staff can locate them for you. I'm just 

25 saying that there is not a single set of assumptions 

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which have been used for all of the savings, because

they have been done at different times.

So the price forecasts have changed, and

we haven ' t gone back to update this analysis. We'll

do that in the rulemaking process, if there's. a

determination that we should go forward with a rule in

that area.

MODERATOR BROOKMAN: And there's the

interpretive rule also.

MR. POLLOCK: Which does describe some of

those steps.

MODERATOR BROOKMAN: Some of the steps.

Additional questions here about the criteria?

MR. POLLOCK: Let me point out that what

we come out with at the end of this prioritization

process is just a grouping. As I pointed out, we do

have the task of the test procedures, and what is

published in the Federal Register notice on the

regulatory agenda will be a proposed schedule which

identifies when we would expect to publish the notice

of proposed rulemaking and when we would expect to

publish the final rule.

That will be different from the final type

of information that comes out of this meeting. We

will take this information, based on determining what

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1 which have been used for all of the savings, because 

2 they have been done at different times. 

3 So the price forecasts have changed, and 

4 we haven't gone back to update this analysis. We'll 

5 do that in the rulemaking process, if there's. a 

6 determination that we should go forward with a rule in 

7 that area. 

8 MODERATOR BROOKMAN: And there's the 

9 interpretive rule also. 

10 MR. POLLOCK: Which does describe some of 

11 those steps. 

12 MODERATOR BROOKMAN: Some of the steps. 

13 Additional questions here about the criteria? 

14 MR. POLLOCK: Let me point out that what 

15 we come out with at the end of this prioritization 

16 process is just a grouping. As I pointed out, we do 

17 have the task of the test procedures, and what is 

18 published in the Federal Register notice on the 

19 regulatory agenda will be a proposed schedule which 

20 identifies when we would expect to publish the notice 

21 of proposed rulemaking and when we would expect to 

22 publish the final rule. 

23 That will be different from the final type 

24 of information that comes out of this meeting. We 

25 will take this information, based on determining what 

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we should put at the high level, what we should focus

our effort on during 1997, and then factor that into

.the resources and the workload that we have, to come

up with what we issue in that agenda.

It is our intent to put that schedule

together and to circulate that for industry comment

before we publish that as a final rule. We will not

have another workshop on it, but we do seek your input

on that schedule so that we can consider your concerns

in developing that schedule before it's finalized.

Other questions? Okay, let's go on and

talk a little bit about the process that we of us on

the staff had used to develop a methodology for

ranking these products.

The preliminary set of criteria for

ranking the products was proposed during the early

meetings with the interested parties, what we call the

Ad Hoc Committee, and was presented at the workshop in

March. It is listed also in the interpretive rule.

There have been some amendments to the

language, but basically the criteria that we're using

have remained pretty much the same. Foremost in our

concern, because that is our job, is saving energy.

So the number one criteria, the thing that you find at

the top of the list if you look at any one of these --

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i! 28 

1 we should put at the high level, what we should focus 

2 our effort on during 1997, and then factor that into 

3 .the resources and the workload that we have, to come 

4 up with what we issue in that agenda. 

5 It is our intent to put that schedule 

. -

6 together and to circulate that for industry comment 

7 before we publish that as a final rule. We will not 

8 have another workshop on it, but we do seek your input 

9 on that schedule so that we can consider your concerns 

10 in developing that schedule before it's finalized. 

11 Other questions? Okay, let's go on and 

12 talk a little bit about the process that we of us on 

13 the staff had used to develop a methodology for 

14 ranking these products. 

15 The preliminary set of criteria for 

16 ranking the products was proposed during the early 

17 meetings with the interested parties, what we call the 

18 Ad Hoc Conunittee, and was presented at the workshop in 

19 March. It is listed also in the interpretive rule. 

20 There have been some amendments to the 

21 language, but basically the criteria that we're using 

22 have remained pretty much the same. Foremost in our 

23 concern, because that is our jobr is saving energy. 

24 So the number one criteria, the thing that you find at 

25 the top of the list if you look at anyone of these 

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Right now I don't want to focus on going through the

bigger product but just focus on these different

categories that we have identified for ranking the

priorities.

Energy savings and costs -- These numbers

here represent source energy, because we put them into

a common reference database relationship so that we

can compare electric product with gas product and so

on. So the numbers that you see in the block on any

one of the tables will be source energy.

They can range over quite a range. What

we have done, depending on how far along, what sources

we had for information, if we've done some analysis,

we use the analysis for projected efficiency and

projection of national energy savings.

Again, I want to emphasize. The important

thing here is to give us relative ranking. We

recognize that in many cases the high end of these may

represent technologies which are not economically

justified, which may have severe impact on the

industry, but at this point in time we have not made

an attempt. to filter those out.

What we are looking for, though, is in the

next block where we talk about economic benefits and

where we talk about the burdens, we would want people

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1 Right now I don't want to focus on going through the 

2 bigger product but just focus on these different 

3 categories that we have identified for ranking the 

4 priorities. 

5 Energy savings and costs -- These numbers 

6 here represent source energy, because we put them into 

7 a common reference database relationship so that we 

8 can compare electric product with gas product and so 

9 on. So the numbers that you see in the block on any 

10 one of the tables will be source energy. 

11 They can range over quite a range. What 

12 we have done, depending on how far along, what sources 

13 we had for information, if we've done some analysis, 

14 we use the analysis for proj ected efficiency and 

15 projection of national energy savings. 

16 Again, I want to emphasize. The important 

17 thing here is to give us relative ranking. We 

18 recognize that in many cases the high end of these may 

19 represent technologies which are not economically 

20 justified, which may have severe impact on the 

21 industry, but at this point in time we have not made 

22 an attempt. to filter those out. 

23 What we are looking for, though, is in the 

24 next block where we talk about economic benefits and 

25 where we talk about the burdens, we would want people 

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who have information concerning both sides , benefits

and burdens, to provide us with comment of issues that

we should consider for any of the energy levels which

are represented above.

So that if there is, in the case of water

heaters , heat pump water heaters , you probably will

already find , because we know about that already, that

this imposes a severe burden on the existing water

heater manufacturers, because there ' s a radical change

in technology . We realize it puts a burden on a

large part of the population.

We're aware of that . We've still put the

number up there, just for consideration, to show, yes,

there is this potential range, but we want to better

identify the problems with going to that range so

that, when we actually come to the point of making a

decision on what the energy potential savings really

is, we can narrow that down a little bit; but at this

point in time, in many cases we won't have done, and

especially in the future , much analysis to get to

these numbers . We're looking at the range of

potential.

So, therefore, it has to be somewhat

subjective, and we're going to be taking a best guess

25 11 of where we think the final next level of energy

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who have information concerning both sides, benefits 

and burdens, to provide us with comment of issues that 

we should consider for any of the energy levels which 

are represented above. 

'I So that if there is, in the case of water 

heaters, heat pump water heaters, you probably will 

already find, because we know about that already, that 

this imposes a severe burden on the existing water 

heater manufacturers, because there's a radical change 

in technology. We realize it puts a burden on a 

large part of the population. 

We're aware of that. We've still put the 

number up there, just for consideration, to show, yes, 

there is this potential range, but we want to better 

identify the problems with going to that range so 

that, when we actually come to the point of making a 

decision on what the energy potential savings really 

is, we can narrow that down a little bit; but at this 

point in time, in many cases we won't have done, and 

especially in the future, much analysis to get to 

these numbers. We're looking at the range of 

potential. 

So, therefore, it has to be somewhat 

subjective, and we're going to be taking a best guess 

of where we think the final next level of energy 

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efficiency will fall in making our decision, but

there's also the risk, when we do something like this,

of signaling a level of efficiency which may or may

not be the final answer when you go through the

analysis.

Jim, I see you have a question.

MR. CRAWFORD: One, is this the only class

of appliance for which you've done a 15 year energy

projection versus a 30 year projection?

MR. POLLOCK: At the present time, I

didn't want to get into -- When you're referring to

energy projection --

MR. CRAWFORD: Well, you've got -- I don't

care about the numbers, but this is a 15 year span.

MR. POLLOCK: Let's let Mike respond to

that.

MR. CRAWFORD: I'm sorry, '93.

MR. RIVEST: Mike Rivest, ABL. I believe

the forecasts that end in the year 2015 were taken out

of 1990 TSDs that were prepared for laundry products.

MR. CRAWFORD: All the others go out to

30.

MR. RIVEST : Right. They do go to 30, and

you're right. In most cases , we have tried to be

consistent. When you were asking the question, I

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1 efficiency will fall in making our decision, but 

2 there's also the risk, when we do something like this, 

3 of signaling a level of efficiency which mayor may 

4 not be the final answer when you go through the 

5 analysis. 

6 Jim, I see you have a question. 

7 MR. CRAWFORD: One, is this the only class 

8 of appliance for which you've done a 15 year energy 

9 projection versus a 30 year projection? 

10 MR . POLLOCK: At the present time, I 

11 didn't want to get into When you're referring to 

12 energy projection --

13 MR. CRAWFORD: Well, you've got - - I don't 

14 care about the numbers, but this is a 15 year span. 

15 MR. POLLOCK: Let's let Mike respond to 

16 that. 

17 MR. CRAWFORD: I'm sorry, '93. 

18 MR. RIVEST: Mike Rivest, ABL. I believe 

19 the forecasts that end in the year 2015 were taken out 

20 of 1990 TSDs that were prepared for laundry products. 

21 MR. CRAWFORD: All the others go out to 

22 30. 

23 MR. RIVEST: Right. They do go to 30, and 

24 you're right. In most cases I we have tried to be 

25 consistent. 

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didn't realize we had the shorter time frame here.

MR. CRAWFORD: Second question that goes

right along with that, which will apply all the way

across the board: Do we have a base number for total

energy consumption in the U.S. over this 2000 to 2030

period, so we know whether we're talking about 10

percent of the energy consumption is on the table here

or .0001 percent is on the table here? I think that

should have something to do with our determinations.

MR. POLLOCK: We do have numbers that were

generated by a study that the man sitting back there

looking at his paper --Jim Broderick' s group has done.

There was a report that was issued. I don't know if

we have a copy of it here today.

MR. FRIEDRICHS: There is a very simple

rule of thumb. We consume about 88 quads now a year.

You can take that up to about 100, about 3,000 quads

between now -- over a 30-year period. You can make it

2500 or 3500, but that's the rule of thumb.

MR. POLLOCK: The report I'm referring to

actually breaks it out product by product. So that,

if you're looking at a bigger product and where it

ranks, it gives you some -- and I agree with you, Jim

-- it gives you some relative merit to say, well, if

we get 10 percent because it's such a large amount of

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1 didn't realize we had the shorter time frame here. 

2 MR. CRAWFORD: Second question that goes 

3 right along with that, which will apply all the way 

4 across the board: Do we have a base number for total 

5 energy consumption in the U.S. over this 2000 to 2030 

6 period, so we know whether we're talking about 10 

7 percent of the energy consumption is on the table here 

8 or .0001 percent is on the table here? I think that 

9 should have something to do with our determinations. 

10 MR. POLLOCK: We do have numbers that were 

11 generated by a study that the man sitting back there 

12 looking at his paper - -Jim Broderick's group has done. 

13 There was a report that was issued. I don't know if 

14 we have a copy of it here today. 

15 MR. FRIEDRICHS: There is a very simple 

16 rule of thumb. We consume about 88 quads now a year. 

17 You can take that up to about 100, about 3,000 quads 

18 between now -- over a 30-year period. You can make it 

19 2500 or 3500, but that's the rule of thumb. 

20 MR. POLLOCK: The report I'm referring to 

21 actually breaks it out product by product. So that, 

22 if you're. looking at a bigger product and where it 

23 ranks, it gives you some -- and I agree with you, Jim 

24 it gives you some relative merit to say, well, if 

25 we get 10 percent because it's such a large amount of 

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energy being used, that --

MR. CRAWFORD: This is exactly what I was

.looking for, so that we knew where our economy is

going and we knew where to focus.

MODERATOR BROOKMAN: You're comfortable

with that number, Jim?

MR. POLLOCK: The next block below the

benefit burden block is the environmental impact.

Certainly, that is very important for the nation, for

the world, considering the benefits from the

environmental pollution reductions as well as, if the

energy is oil especially, the national security,

although most of our products represent a smaller

percentage of that.

The thing that we're really looking for,

for our decision making purposes, in this block is not

those quantities of carbon or CO2 reduction but more

discriminators. If we are.looking at standards for

water heating and we go to one level, will there be

fuel switching, and what will that impact be on the

environment as far as pollutants go, or are there

components which might be used in reaching a higher

energy efficiency, a different type of insulation

which represents some sort of environmental hazard?

Hopefully, that won't exist, but those are

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'i 33 

1 energy being used, that 

2 MR. CRAWFORD: This is exactly what I was 

3 looking for, so that we knew where our economy is 

4 going and we knew where to focus. 

5 MODERATOR BROOKMAN: You're comfortable 

6 with that number, Jim? 

7 MR. POLLOCK: The next block below the 

8 benefit burden block is the environmental impact. 

9 Certainly, that is very important for the nation, for 

10 the world, considering the benefits from the 

11 environmental pollution reductions as well as, if the 

12 energy is oil especially, the national security, 

13 al though most of our products represent a smaller 

14 percentage of that. 

15 The thing that we're really looking for, 

16 for our decision making purposes, in this block is not 

17 those quantities of carbon or CO2 reduction but more 

18 discriminators. If we are looking at standards for 

19 water heating and we go to one level, will there be 

20 fuel switching, and what will that impact be on the 

21 environment as far as pollutants go, or are there 

22 components which might be used in reaching a higher 

23 energy efficiency, a different type of insulation 

24 which represents some sort of environmental hazard? 

25 Hopefully, that won I t exist I but those are 

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the types of things that we need to have called to our

attention so that, when we are looking at ranking

these energy savings numbers that we have at the top,

we're aware of the environmental impact of going to a

particular standard level and what that represents.

Is that clear? Any questions on that?

MR. FRIEDRICHS: Mark Friedrichs again.

Just an expansion on that. The environmental numbers

are basically just derivatives of the energy savings

numbers, and they use standard conversion factors of

how much CO2 is emitted by the electric utility

sector, how much NOX and SO2 it has, and for direct

combustion products similar conversion factors.

So it's relative -- Once you have the

energy savings numbers, it's relatively easy to get

these rough estimates of environmental impacts. What

Ed is saying is that what we're really looking for

here is the other kinds of environmental impacts that

may not be simply derivative.

MR. POLLOCK: Right, and looking for those

which deviate from the rule of thumb that we may not

be aware of that we need to be alerted to.

The next block is the statutory deadline.

In many cases , for the residential products we are

behind schedule now. So, obviously, that date would

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34 

1 the types of things that we need to have called to our 

2 at tention so that, when we are looking at ranking 

3 these energy savings nuwbers that we have at the top, 

4 we're aware of the environmental impact of going to a 

5 particular standard level and what that represents. 

6 Is that clear? Any questions on that? 

7 MR. FRIEDRICHS: Mark Friedrichs again. 

8 Just an expansion on that. The environmental numbers 

9 are basically just derivatives of the energy savings 

10 numbers, and they use standard conversion factors of 

11 how much CO2 is emitted by the electric utility 

12 sector, how much NOX and S02 it has, and for direct 

13 combustion products similar conversion factors. 

14 So it's relative Once you have the 

15 energy savings numbers, it's relatively easy to get 

16 these rough estimates of environmental impacts. What 

17 Ed is saying is that what we're really looking for 

18 here is the other kinds of environmental impacts that 

19 may not be simply derivative. 

20 MR. POLLOCK: Right, and looking for those 

21 which deviate from the rule of thumb that we may not 

22 be aware of that we need to be alerted to. 

23 The next block is the statutory deadline. 

24 In many cases, for the residential products we are 

25 behind schedule now. So, obviously, that date would 

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indicate to as that it's one that is in for

consideration.

I discussed a little bit earlier, there

are some products which we are triggered by actions

form other organizations. There are also cases where

the EPCA rule proscribes for electric motors that in

1999, I believe it is, we are to begin rulemaking

processes . So that date would represent here and, of

course, would be considered in determining whether we

should be moving forward with work during the next

couple of years on that.

Then the next block, which deals with

Terry' s comment earlier this morning: That is the

amount of resources that were required to complete the

rulemaking process . This data block probably will be

dropped in the future , but right now it's a very

important consideration for us in deciding what we're

going to do during 1997 and '98.

The other regulatory impacts from other

organizations, as well as from DOE, need to be

considered . I already discussed that . I don't know

if we need to go into that any further , but it is a

concern to us that we consider that so that we don't

put undue burden on any particular manufacturer in

25 II developing our rules.

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indicate to us that it's one that is in for 

consideration. 

I discussed a little bit earlier, there 

are some products which we are triggered by actions 

form other organizations. There are also cases where 

'the EPCA rule proscribes for electric motors that in 

1999, I believe it is, we are to begin rulemaking 

processes. So that date would represent here and, of 

course, would be considered in determining whether we 

should be moving forward with work during the next 

couple of years on that. 

Then the next block, which deals with 

Terry's comment earlier this morning: That is the 

amount of resources that were required to complete the 

rulemaking process. This data block probably will be 

dropped in the future, but right now it's a very 

important consideration for us in deciding what we're 

going to do during 1997 and '98. 

The other regulatory impacts from other 

organizations, as well as from DOE, need to be 

considered. I already discussed that. I don't know 

if we need to go into that any further, but it is a 

concern to us that we consider that so that we don't 

put undue burden on any particular manufacturer in 

developing our rules. 

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We can deal with this in two ways. One is

to delay the actual rulemaking process. The other way

would be to change the effective dates of the new

standard. So this is an initial look at that impact,

but it's not the final lcok at that impact.

Stakeholder recommendations: There may be

some cases where the industry has indicated that they

are developing a voluntary program which will augment

or replace any rulemaking that we might be doing.

We've been discussing with Philip here this morning

the work that they are doing with the distribution

transformers.

Certainly, given the fact that we do not

have enough rulemaking or funds to do rulemakings for

every products, where there is an effective program

that is doing the same thing that we would be able to

do with standards, there is no justification for us

moving forward. So, certainly, we will be looking at

those types of issues , and recommendations of other

types from the manufacturers of which rules we should

be doing first.

As we go through today, one of the things

that I would encourage people to comment on -- I've

given you a definition of high, low and medium. I'd

like to hear comments as we go by product by product,

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1 We can deal with this in two ways. One is 

2 to delay the actual rulemaking process. The other way 

3 would be to change the effective dates of the new 

4 standard. So this is an initial look at that impact, 

5 but it's not the final leok at that impact. 

6 Stakeholder recommendations: There may be 

7 some cases where the industry has indicated that they 

8 are developing a voluntary program which will augment 

9 or replace any rulemaking that we might be doing. 

10 We've been discussing with Philip here this morning 

11 the work· that they are doing with the distribution 

12 transformers. 

13 Certainly, given the fact that we do not 

14 have enough rulemaking or funds to do rulemakings for 

15 every products, where there is an effective program 

16 that is doing the same thing that we would be able to 

17 do with standards, there is no justification for us 

18 moving forward. So, certainly, we will be looking at 

19 those types of issues, and recommendations of other 

20 types from the manufacturers of which rules we should 

21 be doing first. 

22 As we go through today, one of the things 

23 that I would encourage people to comment on -- I've 

24 given you a definition of high, low and medium. I'd 

25 like to hear comments as we go by product by product, 

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do you consider this a product which we should be

focusing our work on next year or is it something that

should be delayed a little bit or is it something that

should be put down in that bottom level, in the delay

indefinitely? Philip?

MR. HOPKINSON: Phil Hopkinson from Square

D. My question is, if indeed we have a sufficient

voluntary standard, even though we also have a

significant benefit, does that put us in a low

priority then? What does that do in terms of priority

ranking?

MR. POLLOCK: It is certainly something we

would have to consider. It's one factor. I think we

need to -- It would not be the only factor, and we

would have to have more information on the success of

the program and what it really represents before we

would make a final decision which group it goes into.

MR. FRIEDRICHS: Mark Friedrichs again.

I wanted to make one other comment on stakeholder

recommendations. There are certain products where

we're in the midst of the rulemaking or where we might

initiate a rulemaking where the energy savings or

benefits of the standard might be quite small. So in

other words, normally the priority setting process

might rank the product relatively low.

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37 

1 do you consider this a product which we should be 

2 focusing our work on next year or is it something that 

3 should be delayed a little bit or is it something that 

4 should be put down in that bottom level, in the delay 

5 indefinitely? Philip? 

6 MR. HOPKINSON: Phil Hopkinson from Square 

7 D. My question is, if indeed we have a sufficient 

8 voluntary standard, even though we also have a 

9 significant benefit, does that put us in a low 

10 priority then? What does that do in terms of priority 

11 ranking? . 

12 MR. POLLOCK: It is certainly something we 

13 would have to consider. It's one factor. I think we 

14 need to -- It would not be the only factor, and we 

15 would have to have more information on the success of 

16 the program and what it really represents before we 

17 would make a final decision which group it goes into. 

18 MR. FRIEDRICHS: Mark Friedrichs again. 

19 I wanted to make one other comment on stakeholder 

20 recommendations. There are certain products where 

21 we're in the midst of the rulemaking or where we might 

22 initiate ~ rulemaking where the energy savings or 

23 benefits of the standard might be quite small. So in 

24 other words, normally the priority setting process 

25 might rank the product relatively low. 

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An example might be ranges and microwave

ovens. We're fairly far along in that process. It's

.a relatively small impact or no impact, if we actually

decide not to strengthen the standard, but the

stakeholders, both the manufacturers as well as the

energy efficiency advocates may want us to complete

that rulemaking.

So we would need to hear whether or not

there was some overriding reason why we should go

forward with a rule, even though the rule might

otherwise rank fairly low.

MR. POLLOCK: The stakeholder

recommendations -- Right below that then is the issue

of the voluntary programs -- Oh.

MR. LEWIS: Dave Lewis, Lennox. One more

question on stakeholders. Just because a certain

manufacturer has a unique product that they are

producing or could product,. the Department of Energy

will look at the qualitative aspect of stakeholder

suggestions as well as raw data. Right?

MR. POLLOCK: That's right.

MR. LEWIS: I guess what I'm looking at

is, as I go through here, I see most of this being

very quantitative. I mean, by and large, most of the

information here that we've so far discussed has been

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'. 38 

1 An example might be ranges and microwave 

2 ovens. We're fairly far along in that process. It's 

3a relatively small impact or no impact, if we actually 

4 decide not to strengthen the standard, but the 

5 st'akeholders, both the manufacturers as well as the 

6 energy efficiency advocates may want us to complete 

7 that rulemaking. 

8 So we would need to hear whether or not 

9 there was some overriding reason why we should go 

10 forward with a rule, even though the rule might 

11 otherwise rank fairly low. 

12 MR. POLLOCK: The stakeholder 

13 recommendations Right below that then is the issue 

14 of the voluntary programs -- Oh. 

15 MR. LEWIS: Dave Lewis, Lennox. One more 

16 question on stakeholders. Just because a certain 

17 manufacturer has a unique product that they are 

18 producing or could product, the Department of Energy 

19 will look at the qualitative aspect of stakeholder 

20 suggestions as well as raw data. Right? 

21 MR. POLLOCK: That's right. 

22 MR. LEWIS: I guess what I'm looking at 

23 is, as I go through here, I see most of this being 

24 very quantitative. I mean, by and large, most of the 

25 information here that we've so far discussed has been 

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very much on the more documented side.

Here, we have stakeholder recommendations,

which is a rather broad topic, and I guess the concern

is we've had a historical experience some years back

with a given competitor that looked to use government

regulations to provide a marketplace advantage for

them. I guess I hope that the Department wouldn't be

caught in that kind of a situation.

MR. POLLOCK: What we're looking for here

more is group recommendations. Certainly, if we could

have a -- In the case of refrigerators where there was

the group of interested people who came together and

provided us with a proposed standard level, that

represents a strong recommendation to us of we should

proceed, because they've already got a recommendation.

It certainly would be of interest to us if

all of the manufacturers came together and provided a

recommendation. Where it's a single manufacturer, how

much value does that have? You know, there's common

sense here of what we place on this, and certainly,

just because one manufacturer is pushing that does not

represent . something that we would put much weight on.

The next block is the market or voluntary

programs . I emphasize -- we stated this morning in

the small group that our Assistant Secretary,

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very much on the more documented side. 

Here, we have stakeholder recommendations, 

which is a rather broad topic, and I guess the concern 

is we've had a historical experience some years back 

with a given competitor that looked to use government 

regulations to provide a marketplace advantage for 

them. I guess I hope that the Department wouldn't be 

caught in that kind of a situation. 

MR. POLLOCK: What we're looking for here 

more is group recommendations. Certainly, if we could 

have a -- In the case of refrigerators where there was 

the group of interested people who came together and 

provided us with a proposed standard level, that 

represents a strong recommendation to us of we should 

proceed, because they've already got a recommendation. 

It certainly would be of interest to us if 

all of the manufacturers came together and provided a 

recommendation. Where it's a single manufacturer, how 

much value does that have? You know, there's common 

sense here of what we place on this, and certainly, 

just because one manufacturer is pushing that does not 

represent. something that we would put much weight on. 

The next block is the market or voluntary 

programs. I emphasize -- we stated this morning in 

the small group that our Assistant Secretary, 

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Christine Irvin; would much rather see us be able to

use a voluntary program rather than go to a mandatory

rogram for these standards.

In our office where we're doing the

analysis, where we see that -- One of the important

factors is the economic justification. Well, if a

voluntary program is doing the same thing as what we

would be doing so that any increase in standards or

even the cost of implementing a mandatory program to

achieve that level of savings, then we can show

economic justification for moving forward.

So it's a very important consideration for

us to include. The other side of the voluntary

programs, and it doesn't play so much in the decision

of prioritization but it certainly might play into the

schedule for issuing the final rule, is that there may

be voluntary programs that complement the standards

rulemaking.

In the case of the distribution

transformers, there may be a situation where we may

not want to move forward with mandatory standards, but

the adoption of the test procedure and coming out with

labeling would help that programs, and so the two

would work in concert.

So there are various mixes of this. Where

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 EE-PI-96-001 COMMENT 59 , I 40 

1 Christine Irvin-, would much rather see us be able to 

2 use a voluntary program rather than go to a mandatory 

3 _program for these standards. 

4 In our office where we're doing the 

5 analysis, where we see that -- One of the important 

6 -factors is the economic justification. Well, if a 

7 voluntary program is doing the same thing as what we 

8 would be doing so that any increase in standards or 

9 even the cost of implementing a mandatory program to 

10 achieve that level of savings, then we can show 

11 economic justification for moving forward. 

12 So it's a very important consideration for 

13 us to include. The other side of the voluntary 

14 programs, and it doesn't play so much in the decision 

15 of prioritization but it certainly might play into the 

16 schedule for issuing the final rule, is that there may 

17 be voluntary programs that complement the standards 

18 rulemaking. 

19 In the case of the distribution 

20 transformers, there may be a situation where we may 

21 not want to move forward with mandatory standards, but 

22 the adoption of the test procedure and coming out with 

23 labeling would help that programs, and so the two 

24 would work in concert. 

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So there are various mixes of this. Where 

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we're issuing a more stringent standard, there may be

market pool programs that would help make the

transition, develop the market for the product before

the effective date of the standard.

This is the type of thing where we're

looking for various people who have an interest in

this particular product or standard to join with us to

find ways that we can work together to develop

programs on the market pool side on the standards

program that make sense, that complement, that

minimize the burden, and to maximize the savings. Any

questions on this?

Then the next block, I have touched on a

little bit already, is the issue of the test

procedures. Certainly, if we are going into

technologies which will -- which are not covered by

current test procedures or, if we're looking at a new

product which we have not yet adopted test procedures

for, then that work has to be completed before we can

complete standards rulemaking.

That doesn't mean that we won 't begin to

look at the analysis, collect information on how we're

going to model or determine what the energy potential

savings is , but we will not go to a final rule until

we have an agreement on the test methodology that will

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1 we're issuing a more stringent standard, there may be 

2 market pool programs that would help make the 

3 transition, develop the market for the product before 

4 the effective date of the standard . 

.5 This is the type of thing where we're 

6 looking for various people who have an interest in 

7 this particular product or standard to join with us to 

8 find ways that we can work together to develop 

9 programs on the market pool side on the standards 

10 program that make sense, that complement, that 

11 minimize the burden, and to maximize the savings. Any 

12 questions on this? 

13 Then the next block, I have touched on a 

14 little bit already, is the issue of the test 

15 procedures. Certainly, if we are going into 

16 technologies which will -- which are not covered by 

17 current test procedures or, if we're looking at a new 

18 product which we have not yet adopted test procedures 

19 for, then that work has to be completed before we can 

20 complete standards rulemaking. 

21 That doesn't mean that we won't begin to 

22 look at the analysis, collect information on how we're 

23 going to model or determine what the energy potential 

24 savings is, but we will not go to a final rule until 

25 we have an agreement on the test methodology that will 

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be used to measure that performance. So we need to

know that in establishing priority.

MR. FRIEDRICHS: Just a small

clarification: We've actually committed to not go to

a proposed rule unless we have completed modification

to the test procedure.

MR. POLLOCK: And have a draft document,

but the final draft --

MR. FRIEDRICHS: The final changes to the

test procedure before we have a proposed standard. I

think that's stated in the new process.

MR. POLLOCK: And then last block is just

the catchall for other information that we as decision

makers on setting these schedules should be aware of,

where we're looking for anyone who has information to

bear on this decision making can provide us with

comment that we should consider.

Are these questions on this in general?

Then after the break we'll come back and begin to go

through product by product and look at some of the

numbers and the comments that we have to date.

I also wanted to just emphasize that we

have made -- In the letter that was sent out to you,

we've made a comment in there that we will receive

written comment on these data sheets until July 12.

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1 be used to measure that performance. So we need to 

2 know that in establishing priority. 

3 MR. FRIEDRICHS: Just a small 

4 clarification: We've actually committed to not go to 

5 a proposed rule unless we have completed modification 

6 to the test procedure. 

7 MR. POLLOCK: And have a draft document, 

8 but the final draft --

9 MR. FRIEDRICHS: The final changes to the 

10 test procedure before we have a proposed standard. I 

11 think that's stated in the new process. 

12 MR. POLLOCK: And then last block is just 

13 the catchall for other information that we as decision 

14 makers on setting these schedules should be aware of, 

15 where we're looking for anyone who has information to 

16 bear on this decision making can provide us with 

17 comment that we should consider. 

18 Are these questions on this in general? 

19 Then after the break we'll come back and begin to go 

20 through product by product and look at some of the 

21 numbers and the comments that we have to date. 

22 I also wanted to just emphasize that we 

23 have made -- In the letter that was sent out to you, 

24 we've made a comment in there that we will receive 

25 written comment on these data sheets until July 12. 

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There may be some of you who are concerned about some

of the numbers that are here , and we would welcome

.corrections to these numbers with some documentation

to justify changes in the numbers , which we will

consider and put into the final version of these data

sheets before we begin our actual final grouping of

the products for proceeding to the regulatory agenda.

MODERATOR BROOKMAN: Additional final

questions before we go to break? I see none. There

were a few individuals that came in that didn't get a

chance to introduce themselves at the outset. Would

you introduce yourselves now? I know, for example,

Mark, you came in. Would you introduce yourself,

please? I thought I saw a few others that didn't

introduce themselves. Yes?

MR. BARZELL: Dan Barzell with Circuit

City.

MODERATOR BROOKMAN: Thank you. Yes?

MR. KUMAR : B.J. Kumar, Energetics.

MODERATOR BROOKMAN: Thank you. Anybody

else that didn ' t get a chance to introduce themselves?

Great.

Let's take -- Let's try and make this a

fairly short break -- 10 minutes, and we're going to

try and start up again. We've got a lot of work to do

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1 There may be some of you who are concerned about some 

2 of the numbers that are here, and we would welcome 

3 corrections to these numbers with some documentation 

4 to justify changes in the numbers, which we will 

5 consider and put into the final version of these data 

6 sheets before we begin our actual final grouping of 

7 the products for proceeding to the regulatory agenda. 

8 MODERATOR BROOKMAN: Additional final 

9 questions before we go to break? I see none. There 

10 were a few individuals that came in that didn't get a 

11 chance to introduce themselves at the outset. Would 

12 you introduce yourselves now? I know, for example, 

13 Mark, you came in. Would you introduce yoursel f , 

14 please? I thought I saw a few others that didn't 

15 introduce themselves. Yes? 

16 MR. BARZELL: Dan Barzell with Circuit 

17 City. 

18 MODERATOR BROOKMAN: Thank you. Yes? 

19 MR. KUMAR: B.J. Kumar, Energetics. 

20 MODERATOR BROOKMAN: Thank you. Anybody 

21 else that didn't get a chance to introduce themselves? 

22 Great. 

23 Let's take -- Let's try and make this a 

24 fairly short break -- 10 minutes, and we're going to 

25 try and start up again. We've got a lot of work to do 

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here.

Please avail yourselves of the

refreshments.

(WHEREUPON, the workshop was recessed

briefly at 10:00 a.m.)

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1 here. 

2 Please avail yourselves of the 

3 refreshments. 

4 (WHEREUPON, the workshop was recessed 

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CERTIFICATE

''This is to certify that the foregoing transcript in the

matter of: U.S. DEPARTMENT OF ENERGY

APPLIANCE STANDARDS WORKSHOP

OVERVIEW OF EVALUATION CRITERIA

Before: DOUG BROOKMAN, FACILITATOR

Date: JUNE 14, 1996

Place: WASHINGTON, D.C.

represents the full and complete proceedings of the

aforementioned matter, as reported and reduced to

typewriting.

JOHN MONGOVI^'

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 EE-PI-96-001 COMMENT 59

45 

CERTIFICATE 

:'This is to certify that the foregoing transcript in the 

matter of: 

Before: 

Date: 

Place: 

u.s. DEPARTMENT OF ENERGY 

APPLIANCE STANDARDS WORKSHOP 

OVERVIEW OF EVALUATION CRITERIA 

DOUG BROOKMAN, FACILITATOR 

JUNE 14, 1996 

WASHINGTON, D.C. 

represents the full and complete proceedings of the 

aforementioned matter, as reported and reduced to 

typewriting. 

(202) 234-4433 

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COURT REPORTERS AND TRANSCRIBERS 

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