202-234-4433

Neal R. Gross & Co., Inc.

Page 1

 U.S. DEPARTMENT OF ENERGY 

 + + + + + 

 ENERGY CONSERVATION PROGRAM FOR CONSUMER 

 PRODUCTS: TEST PROCEDURES FOR REFRIGERATORS, 

 REFRIGERATOR-FREEZERS, AND FREEZERS 

 + + + + + 

 PUBLIC MEETING 

 + + + + + 

 THURSDAY 

 JULY 25, 2013 

 + + + + + 

 The Public Meeting convened in 

the Forrestal Building, Room 8E-089, 1000 

Independence Avenue, SW, Washington, DC, at 

9:00 a.m., Doug Brookman, Facilitator, 

presiding. 

PRESENT: 

DOUG BROOKMAN, Facilitator, Public Solutions, 

Inc. 

LUCAS ADIN, Department of Energy 

MICHAEL KIDO, Department of Energy 

ANDREW JEAN-LOUIS, Navigant Consulting 

DETLEF WESTPHALEN, Navigant Consulting 

EMILY MARCHETTI, Energetics 

ALSO PRESENT: 
202-234-4433

Neal R. Gross & Co., Inc.

Page 2

JENNIFER AMANN, American Council for an 

 Energy-Efficient Economy (ACEEE) 

BILL BROWN, G.E. Appliances 

ANDREW KRAUSE, G.E. Appliances 

STEVE LEYBOURN, Association of Home 

 Appliance Manufacturers (AHAM) 

ROBERT McARVER, Association of Home 

 Appliance Manufacturers (AHAM) 

NATHAN MOUW, Whirlpool Corporation 

AMANDA STEVENS, U.S. EPA, EnergyStar 

SCOTT YOUNG, Lawrence Berkeley National 

 Laboratory 
202-234-4433

Neal R. Gross & Co., Inc.

Page 3

 A G E N D A 

Welcome................................ 4 

Opening Remarks, Introductions and 

 Agenda Review........................ 4 

Introduction and Background............ 10 

Regulatory History and Products 

 Covered by the Test Procedure 

 Changes.............................. 21 

Test Procedure Amendments: Icemaking... 24 

Test Procedure Amendments.............. 73 

Other Issues Under Consideration....... 112 

Compliance With Other EPCA 

 Requirements......................... 144 

Conclusions and Closing Remarks........ 153 
202-234-4433

Neal R. Gross & Co., Inc.

Page 4

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

2 9:23 a.m. 

3 Welcome 

4 MR. BROOKMAN: Good morning, 

5 everyone. Welcome. This is the U.S. 

6 Department of Energy's public meeting on 

7 Energy Conservation Program for Consumer 

8 Products, specifically test procedures for 

9 refrigerators, refrigerators-freezers and 

10 freezers. 

11 Today is Thursday, July 25th, 

12 2013 here in the Forrestal Building in 

13 Washington, D.C. My name is Doug Brookman 

14 from Public Solutions in Baltimore. Nice to 

15 see you here. We're going to start with 

16 welcoming remarks from Lucas Adin. 

17 Opening Remarks, Intros and Agenda Review 

18 MR. ADIN: Hello everyone. I'm 

19 Lucas Adin. I'm with Department of Energy's 

20 Appliance Equipment Standards Program, and 

21 I'm the product manager for Essential 

22 Refrigeration Products, and I just want to 
202-234-4433

Neal R. Gross & Co., Inc.

Page 5

1 welcome you all here today. We very much 

2 appreciate your participation and we expect 

3 we'll have a pretty good discussion today. 

4 Hopefully, we can provide some clarification 

5 on all the proposals that we've made in this 

6 notice, and to the extent you have questions 

7 about the proposal or specific comments on 

8 any of these items, we strongly encourage you 

9 to bring those up today. 

10 Hopefully you leave today with a 

11 better understanding of what we've proposed, 

12 and that we'll get some good written 

13 comments. Thanks to all the folks 

14 participating in the webinar as well. We 

15 certainly appreciate all the participation we 

16 can get. 

17 MR. BROOKMAN: Thank you. 

18 MR. ADIN: So we'll move on from 

19 there. Thank you. 

20 MR. BROOKMAN: Thank you. So we 

21 typically start with introductions, and you 

22 can get used to turning these microphones on 
202-234-4433

Neal R. Gross & Co., Inc.

Page 6

1 and off. Please say your name and 

2 organizational affiliation, and we'll go 

3 around the room. 

4 MR. MOUW: Nathan Mouw from 

5 Whirlpool Corporation. 

6 MR. BROWN: Bill Brown, GE 

7 Appliances. 

8 MR. KRAUSE: Andrew Krause, GE 

9 Appliances. 

10 MR. McARVER: Rob McArver with 

11 the Association of Home Appliance 

12 Manufacturers. 

13 MR. LEYBOURN: Steve Leybourn, 

14 also from the Association of Home Appliance 

15 Manufacturers. 

16 MS. STEVENS: Amanda Stevens, 

17 EnergyStar. 

18 MS. AMANN: Jennifer Amann, 

19 American Council for an Energy Efficient 

20 Economy. 

21 MR. KIDO: Michael Kido, DOE 

22 Office of the General Counsel. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 7

1 MR. ADIN: Lucas Adin, DOE. 

2 MR. BROOKMAN: Please stand up. 

3 MR. WESTPHALEN: Detlef 

4 Westphalen, Navigant Consulting. 

5 MR. JEAN-LOUIS: Andrew Jean6 Louis, Navigant Consulting. 

7 MR. YOUNG: Steve Young, Lawrence 

8 Berkeley National Laboratory. 

9 MR. BROOKMAN: Again, thanks to 

10 all of you for being here. Our apologies for 

11 starting a few minutes late. All of you 

12 received a packet of information when you 

13 came in this morning and registered. 

14 I'm going to do a very brief 

15 agenda review immediately following these -- 

16 this agenda review, and a very brief bit of 

17 content on the regulatory overview. There is 

18 an opportunity for anyone that wishes to do 

19 so to make brief summary comments here at the 

20 outset, issues that matter to you, issues you 

21 wish to bring to the fore. 

22 From there, we'll launch straight 
202-234-4433

Neal R. Gross & Co., Inc.

Page 8

1 into the content that's in this colorful 

2 PowerPoint packet presentation. We will hear 

3 regulatory history and products covered by 

4 the test procedure changes. From there, Test 

5 Procedure Amendments in Icemaking. 

6 We'll take a break mid-morning, 

7 around about 10:30 or so. Following that, 

8 Test Procedure Amendments Icemaking 

9 continued, and then continuing on from there, 

10 Test Procedure Amendments, continued. We'll 

11 take a break for lunch around about 12:30 or 

12 so, and then the Test Procedure Amendments 

13 discussion and content continue from there. 

14 So the agenda, we anticipate that 

15 probably, as listed in the agenda, we're 

16 going to finish today around about three 

17 o'clock or so, maybe a little bit earlier, 

18 we'll see how it turns out. Our job is to be 

19 as efficient and effective, and not diminish 

20 your ability to comment on things that are 

21 important to you. 

22 I would ask for your 
202-234-4433

Neal R. Gross & Co., Inc.

Page 9

1 consideration. Many of you are familiar with 

2 the meeting format here. If you would speak 

3 one at a time, please get used to turning 

4 this microphone on and off please. 

5 Say your name for the record. 

6 Each time you speak be concise, share the air 

7 time. If you can keep the focus here, turn 

8 your cell phones on silent mode. Limit 

9 sidebar conversations. 

10 For the web participants, we are 

11 very happy to have you join us. The 

12 Department of Energy is trying hard to make 

13 these meetings accessible to everyone. 

14 If you could keep your telephone 

15 on mute and you can raise your hand if you 

16 wish to comment, wish to speak. We ought to 

17 be able to hear you here in the room. How 

18 many, Emily, do we have joining us? 

19 Fourteen? 

20 MS. MARCHETTI: Do you want me to 

21 list their names for the record? 

22 MR. BROOKMAN: We can do that. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 10

1 Yeah, here. We're going to read the names of 

2 the individuals present into the record. 

3 MS. MARCHETTI: Steve Polinski, 

4 Eric Zehr, Fabian Cerrito, sorry; Mark Drake, 

5 Michael Woodford, Mizanur Chowdhury, Nestor 

6 Salazar, Patrick Powell, Paul Griffin, Ryan 

7 Fogle. 

8 MR. BROOKMAN: Okay, and of 

9 course the reason we do that, is because 

10 individuals here in the room would like to 

11 know who, friends and colleagues who might be 

12 listening in, who might be participating as 

13 well. 

14 So I think that's the preliminary 

15 stuff. Do you want to run through a content 

16 slides before we take opening remarks? Yes, 

17 yes. Typically, you -- yeah, yeah. 

18 Typically you do that. 

19 Introduction and Background 

20 MR. ADIN: So we'll just go over 

21 a few basic ground rule items. I think most 

22 of these are things that the folks in this 
202-234-4433

Neal R. Gross & Co., Inc.

Page 11

1 room are pretty well familiar with. But just 

2 basic meeting ground rules. It's generally 

3 -- 

4 MR. BROOKMAN: I've done those. 

5 MR. ADIN: I'm sorry? 

6 MR. BROOKMAN: I've done those. 

7 MR. ADIN: Oh, you did those. 

8 I'm sorry. 

9 MR. BROOKMAN: Yep. 

10 MR. ADIN: So there's the agenda 

11 generally. You all have a copy of that, so I 

12 don't know that we need to go through that in 

13 detail. 

14 So I'll proceed to introductions. 

15 We do have this meeting occurring via 

16 webinar, as folks on the webinar are 

17 certainly are well aware. So I don't know 

18 that we need to linger on this one. 

19 The purpose of this meeting is to 

20 present DOE's proposal for revisions to the 

21 test procedures for residential 

22 refrigerators, refrigerators and freezers, 
202-234-4433

Neal R. Gross & Co., Inc.

Page 12

1 which includes a number of amendments, as I 

2 know all of you are aware. 

3 We invite comments on a number of 

4 items, and there will be various points 

5 throughout the presentation, at which we'll 

6 be asking for specific comments on particular 

7 items. But certainly you're free to make 

8 comments or ask questions at any point during 

9 that presentation today, also discuss 

10 generally our next steps. 

11 The rulemaking progression for a 

12 test procedure is relatively simple. At the 

13 most basic level, there are just two steps. 

14 We do a proposal through a notice of proposed 

15 rulemaking, and then proceed to final rule. 

16 The proposal, which you've all 

17 seen, is in the notice that we published on 

18 July 10th, or the public meeting today, July 

19 25th. 

20 We'll receive comments through or 

21 up until September 23rd, and then after DOE 

22 has had an opportunity to review and consider 
202-234-4433

Neal R. Gross & Co., Inc.

Page 13

1 all comments that we've received, we'll 

2 proceed to a final rule. 

3 MR. BROOKMAN: Okay. So now, 

4 thank you, and we will proceed to opening 

5 remarks, stakeholder comments here at the 

6 outset, for anybody that wishes to. Do you 

7 wish to? Rob, please. 

8 MR. McARVER: This is Rob McArver 

9 with AHAM. Good morning. So I'd like to 

10 thank the Department of Energy for the 

11 opportunity comment today on the proposed 

12 amendment to DOE's refrigerator-freezer test 

13 procedures. 

14 As always, AHAM supports DOE in 

15 its efforts to save energy, and we recognize 

16 that the representativeness and accuracy of 

17 these test procedures are an important part 

18 of those efforts. 

19 AHAM also appreciates DOE's 

20 willingness to review and respond to 

21 regulated parties' concerns regarding the 

22 need for clarity in certain sections of the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 14

1 test procedures. 

2 As a threshold matter, however, 

3 we firmly believe that now is not the time to 

4 propose or promulgate what we see as 

5 significant changes to test procedures that 

6 will become effective next year. 

7 Regarding today's discussion, the 

8 Department's timing with this proposed rule 

9 is extremely challenging for appliance 

10 manufacturers. DOE released the notice and 

11 scheduled this public meeting right when 

12 manufacturers are preparing their annual 

13 reports on energy efficiency performance to 

14 DOE and FTC. 

15 The deadline for these reports is 

16 August 1, next week. Because of the demand 

17 this places on company resources, it was 

18 virtually impossible for manufacturers to 

19 review the notice in detail and prepare 

20 adequately for the public meeting. More 

21 importantly, now is not an appropriate time 

22 to make significant changes to the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 15

1 refrigerator freezer test procedures, some of 

2 which in AHAM's view, will significantly 

3 impact calculations of measured energy use. 

4 Manufacturers have already 

5 designed their products for 2014, or are 

6 nearing completion of the design phase, and 

7 are nearly or currently ready to begin 

8 testing. There simply isn't time to 

9 reengineer these products if the new test 

10 procedures produce adverse results. 

11 Furthermore, the comment deadline 

12 on this notice is September 23rd, less a year 

13 before the 2014 standards become effective. 

14 Even under a best case scenario, it does not 

15 seem likely that a final rule could be issued 

16 in time, to allow manufacturers to launch 

17 products that comply with these additional 

18 changes to the test procedures by the 1st of 

19 January, which is the date FTC has permitted 

20 for early compliance labeling. 

21 Many manufacturers have long been 

22 planning to launch 2014 compliant products on 
202-234-4433

Neal R. Gross & Co., Inc.

Page 16

1 or soon after that date. To do so, however, 

2 product testing must begin immediately. It 

3 is simply too late for DOE to be proposing 

4 these significant changes. 

5 Finally, AHAM questions whether 

6 DOE has authority under the Energy Policy and 

7 Conservation Act to make de minimis 

8 determinations regarding the impact of test 

9 procedure changes on measured energy. 

10 DOE proposes to do so in several 

11 instances in this rulemaking. DOE's approach 

12 ignores situations in which there is a broad 

13 range of impacts across basic models, at the 

14 average near zero. 

15 For those manufacturers whose 

16 products show more significant impacts, the 

17 proposed change to the test procedures could 

18 be the difference between meeting and falling 

19 short of the requirements of the standard. 

20 We believe that DOE's approach in 

21 this rulemaking, when applied to an amended 

22 standard that has already been promulgated, 
202-234-4433

Neal R. Gross & Co., Inc.

Page 17

1 undercuts the three-year lead-in period 

2 required by law, especially because the 

3 grandfathering protections in EPCA often will 

4 not apply. This can put manufacturers at a 

5 severe disadvantage and have grave commercial 

6 implications. 

7 Thank you for the opportunity to 

8 provide input at today's public meeting. 

9 AHAM will provide more detail on these issues 

10 in its written comments, and will comment on 

11 some of the specific issues raised in the 

12 notice throughout the meeting today. 

13 MR. BROOKMAN: Thank you, Rob. 

14 Other comments here at the outset? Nathan. 

15 MR. MOUW: Yes, good morning. 

16 This is Nathan Mouw from Whirlpool. 

17 Whirlpool values the effort that DOE takes to 

18 continuously improve its energy test 

19 procedure. 

20 It's very important that we 

21 continue to do that, as far as accuracy, 

22 repeatability and reproducibility, and we 
202-234-4433

Neal R. Gross & Co., Inc.

Page 18

1 thank DOE for the opportunity to comment on 

2 this proposal that was released on the 

3 Federal Register on July 10th, and we also 

4 acknowledge that many of these changes that 

5 have been proposed are a result of our 

6 request from AHAM and its member companies. 

7 We agree with the merit of many 

8 of the proposed changes, and look forward to 

9 the benefits that they will provide our 

10 consumers' understanding of real energy 

11 consumption. However, we do echo the concern 

12 raised by AHAM in their opening statement 

13 regarding the timing of these changes. 

14 We have directed a large portion 

15 of our engineering resources for the last 15 

16 months away from innovation to focus on 

17 redesign of most of our refrigerator and 

18 freezer line to meet these energy 

19 requirements that are the new requirements 

20 that are effective next year. 

21 These engineers will continue 

22 this focus work up until launch of these new 
202-234-4433

Neal R. Gross & Co., Inc.

Page 19

1 products starting as early as January, less 

2 than six months from now. Introducing a 

3 significant number of changes right now is a 

4 real distraction from this work that we need 

5 to accomplish, to navigate this transition 

6 successfully. 

7 In the event that these changes, 

8 some or all of these changes to the test 

9 procedure are made effective during this 

10 time, we do ask that for clarity from DOE and 

11 how we plan to coordinate these changes with 

12 the early compliance exemption allowed by the 

13 FTC. 

14 We also echo the concern of AHAM 

15 that many of these proposed amendments may 

16 impact measured energy. Our engineers have 

17 been busy designing new platforms to meet a 

18 federal standard based on a DOE test 

19 procedure that we released last year. Any 

20 changes to this test procedure that do impact 

21 measured energy, even seemingly small, can 

22 put this work and possibly these new 
202-234-4433

Neal R. Gross & Co., Inc.

Page 20

1 redesigned platforms at risk from meeting the 

2 federal energy standard. 

3 In summary, we look forward to 

4 working with DOE to finalize these 

5 improvements, and will submit detailed 

6 written comments in support of this work. 

7 But we emphasize that now is not the time to 

8 make changes, especially those changes that 

9 may have any chance of impacting measured 

10 energy for any basic model. Thanks a lot. 

11 MR. BROOKMAN: Thank you. 

12 Jennifer. 

13 MS. AMANN: Hi. This is Jennifer 

14 Amann with ACEEE. Just a brief comment. We 

15 recognize that there have been some changes 

16 to the time line, and that DOE hasn't been 

17 able to maintain the time line that we have 

18 recommended in the consensus agreement, that 

19 the advocates and the manufacturers put 

20 forward on these products. 

21 But what we'd like to do is see 

22 that we can get as much of the spirit in that 
202-234-4433

Neal R. Gross & Co., Inc.

Page 21

1 consensus agreement incorporated into the 

2 test procedures now. 

3 So we're very interested today to 

4 learn from DOE kind of what the limitations 

5 are, what the possibilities are, and to 

6 understand from the manufacturers, you know, 

7 how much of the spirit of the agreement we 

8 can stick to, in getting some changes into 

9 the test procedures and what things would be 

10 delayed and how we can minimize the delay in 

11 terms of, you know, better using the test 

12 procedures to understand energy consumption 

13 of the products and to reflect that in the 

14 information that's provided to consumers on 

15 the energy use of these products. Thanks. 

16 MR. BROOKMAN: Okay, thank you. 

17 Additional comments? Nothing additional 

18 here? 

19 Okay. Then let's proceed. We're 

20 going to start off with content from Lucas 

21 Adin. 

22 Regulatory History and Products Covered 
202-234-4433

Neal R. Gross & Co., Inc.

Page 22

1 MR. ADIN: So as I mentioned 

2 earlier, there are a number of places in the 

3 rule where, I'm sorry in the presentation, 

4 where we're requesting comment on specific 

5 items, and this is just what those issue 

6 boxes look like. 

7 So just as a reminder to 

8 everyone, we will be requesting comment on 

9 specific items as we go through. So we've 

10 done opening statements. So this slide lays 

11 out the general regulatory time line for 

12 these test procedures. 

13 The first DOE final rule that 

14 established a federal test procedure for 

15 these products was published in 1977, and 

16 then a second final rule in 1982 established 

17 the test procedure that essentially is the 

18 foundation of the procedure that is still 

19 used today, which is based on the AHAM HRF-1-

20 1979 procedure. 

21 The rules that occurred after 

22 that were, in most respects, modifications to 
202-234-4433

Neal R. Gross & Co., Inc.

Page 23

1 add testing for various other features that 

2 had come along. 

3 But the basic foundation was 

4 established in that 1982 rule, and then in 

5 2012, DOE published a final rule that 

6 established a new Appendix A test procedure 

7 that's based on, in part on HRF-1-2008, and 

8 will be the procedure required for use to 

9 establish compliance with the new amended DOE 

10 energy conservation standards in 2014. 

11 There are also a few waivers that 

12 are still in effect for some of these 

13 products, as are shown on the bottom there. 

14 Generally speaking, DOE tries to address 

15 waivers in each test procedure rulemaking to 

16 eliminate the need for those waivers. So a 

17 few of those will be addressed today. 

18 For freezers, the timeline is 

19 essentially identical. We've dealt with 

20 freezers in parallel with refrigerators in 

21 each rule. I think the only one that's not 

22 there is that 2003 rule which dealt with a 
202-234-4433

Neal R. Gross & Co., Inc.

Page 24

1 feature that was not present in freezers at 

2 that time anyway. 

3 So I'll briefly mention the scope 

4 of products that are covered by the test 

5 procedure changes. I think this is probably 

6 clear to everyone here, but just in case, 

7 this rule affects three types of products 

8 defined by DOE, which are defined 

9 specifically in the regulations in Section 

10 430.2. 

11 That's electric refrigerators, 

12 electric refrigerator-freezers and freezers. 

13 So I don't think there are any questions 

14 about that one. 

15 So we'll move into the specific 

16 test procedure amendments, and this slide 

17 shows the overall list of items that we're 

18 going to be discussing today. There are 

19 quite a few. So I think we're ready to move 

20 into discussion about the icemaking test 

21 procedure. That's our first item for 

22 discussion today. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 25

1 So I'll turn over to Andrew Jean2 Louis, who is going to explain that part of 

3 the proposal. All right. 

4 Test Procedure Amendments: Icemaking 

5 MR. JEAN-LOUIS: Thank you. 

6 Thank you, Lucas. Again, I'm Andrew Jean7 Louis from Navigant, and I'll talk about the 

8 icemaking portion of the modifications that 

9 we're proposing today. This is just a 

10 summary of the modifications to -- how's 

11 that? 

12 MR. ADIN: Yeah. Speak loudly. 

13 MR. JEAN-LOUIS: Okay. All 

14 right. This is a list of the key 

15 modifications that DOE is proposing to the 

16 AHAM test procedure for icemaking that was 

17 submitted in 2012. I'm not going to go 

18 through it, but just an overall view of what 

19 we're looking at today. 

20 So DOE is proposing not to 

21 specifically address specifically 

22 refrigerators, or products with manual 
202-234-4433

Neal R. Gross & Co., Inc.

Page 26

1 defrost for the icemaking test procedure. 

2 DOE is requesting comment on that approach, 

3 and whether any refrigerators that are sold 

4 with -- any refrigerators are, mainly defrost 

5 freezers, are sold with automatic icemakers, 

6 and if so, DOE is requesting comment on 

7 whether the test procedures for automatic 

8 icemakers should cover those products. 

9 And I guess finally, DOE is also 

10 seeking comment on this issue, in part to 

11 ascertain whether today's proposal should 

12 apply to refrigerators or refrigerator13 freezers if those products do have icemakers. 

14 So I guess at this time, it would 

15 be great to hear if anyone has any feedback 

16 on whether those type of products have 

17 icemakers, and if so, should the icemaking 

18 test procedure be addressed for those 

19 products. 

20 MR. BROOKMAN: Andrew, can you go 

21 back to the preceding slide? 

22 MR. JEAN-LOUIS: Oh sure. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 27

1 MR. BROOKMAN: Just put this 

2 slide up there. Leave it up there for you to 

3 refer to as you're thinking about your 

4 comments. 

5 No comments here? Nothing come 

6 from online. Okay. Let's proceed. 

7 MR. JEAN-LOUIS: Okay. So DOE is 

8 also proposing to establish some definitions 

9 for the icemaking test procedure. Just to 

10 make things more familiar for those who are 

11 following the test procedure for icemakers. 

12 So specifically, definitions for 

13 the harvest, the operation of removing ice 

14 from the ice mold, the definition for ice 

15 storage bin which is pretty straightforward, 

16 and ice piece, I guess also known as like an 

17 ice cube, something that's more general, so 

18 that you don't reduce the scope to something 

19 that's a specific shape. 

20 Lastly, a definition for the 

21 through the door ice dispenser. So I guess 

22 at this point we're requesting comment on 
202-234-4433

Neal R. Gross & Co., Inc.

Page 28

1 these definitions. 

2 MR. BROOKMAN: No comments here? 

3 All right. 

4 MR. JEAN-LOUIS: Okay. So in 

5 terms of test procedure for the icemaking 

6 portion, DOE is proposing to require that the 

7 anti-sweat heater switch be turned off during 

8 the icemaking portion of the test. So this 

9 strategy would prevent the random activation 

10 of a variable anti-sweat heater triggering 

11 during the test procedure. 

12 We'll also call for a strategy 

13 where, for variable anti-sweat heaters that 

14 don't have a switch, to require a test to 

15 have -- the test chamber to have a humidity 

16 level that's below the threshold that would 

17 trigger operation of that anti-sweat heater. 

18 So at this point, we're 

19 requesting comment on that strategy, and 

20 suggestions for other ways to deal with this 

21 type of heating operation in refrigerators. 

22 MR. BROOKMAN: Rob. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 29

1 MR. McARVER: If I could make a 

2 quick comment. 

3 MR. BROOKMAN: Rob, please turn 

4 the microphone on. 

5 MR. McARVER: Sorry. Rob McArver 

6 with AHAM. If I could make a quick comment 

7 about this. There were two flaws that we saw 

8 in this particular provision and we'll 

9 highlight in more detail in our comments, 

10 written comments. 

11 But one, I think the assumption 

12 is wrong. There are several basic models 

13 that do not use an anti-sweat heater switch, 

14 and we'll go in more detail on that again in 

15 the written comments. 

16 The second item is the data 

17 manufacturers is based on a 72 degree 

18 Fahrenheit ambient condition, and I don't 

19 think that's reflected in the proposal as 

20 drafted. 

21 MR. BROOKMAN: And that would 

22 apply in this section here? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 30

1 MR. McARVER: Yeah. This is for 

2 2(d), the anti-sweat heater switches. 

3 MR. BROOKMAN: Okay, okay. 

4 Thanks. Detlef. 

5 MR. WESTPHALEN: Detlef 

6 Westphalen, Navigant. If I recall correctly, 

7 you know, maybe the wording changed a little 

8 bit, but I think the proposal was that for 

9 products without a switch, that the test 

10 would be conducted in conditions where the 

11 anti-sweat heater would not be activated. 

12 It doesn't specify that that's 

13 the certification reported relative humidity 

14 would be the relative humidity that would be 

15 used as the threshold. 

16 MR. BROOKMAN: Okay, Bill. 

17 MR. BROWN: Bill Brown, GE 

18 Appliances. In the DOE's comments, they did 

19 note that based on the manufacturers' 

20 submittals, that the threshold seemed to be 

21 around 30 to 35 percent relative humidity, 

22 where the heaters do not come on. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 31

1 That obviously is based on our 

2 submittals at 72 degrees. At 90 degrees, 

3 it's quite a bit different, and I would say 

4 even with one of our products, you know, the 

5 threshold is more like ten percent relative 

6 humidity for a 90 degree ambient. 

7 So a couple of things that are a 

8 flaw there, in that the DOE said in their 

9 research that they were not aware of any 

10 products with a variable anti-sweat heater 

11 system that did not have a switch, and I 

12 think many manufacturers have that. 

13 I know that the factory that I'm 

14 in makes nothing but that type of product. 

15 As far as the humidity levels go, the 

16 assumption of 30 to 35 percent was based on 

17 72 degree information from the manufacturers. 

18 The real information of 90 

19 degrees was quite a bit different, and I 

20 don't believe that it would be feasible 

21 economically to be able to pull rooms down to 

22 levels so low that at 90 degrees, anti-sweat 
202-234-4433

Neal R. Gross & Co., Inc.

Page 32

1 heaters would not come on. 

2 MR. WESTPHALEN: Okay. I guess, 

3 you know, in written comments DOE would 

4 request some discussion and consideration of 

5 potential alternative approaches that could 

6 be used, to assure that variations associated 

7 with random activation of the heaters could 

8 be afforded. 

9 MR. BROOKMAN: Okay. Thank you, 

10 Detlef. Other comments in response to Issue 

11 2(d)? Okay. 

12 MR. JEAN-LOUIS: So DOE's next 

13 proposal is to modify the requirements for 

14 unit installation with the current -- in 

15 Appendix A, because the procedures require 

16 certain conditions that would not jibe well 

17 with the operation of the icemaking test. 

18 So DOE is proposing to allow the 

19 connection of water lines for the icemaking 

20 test, and also allowing for the ice storage 

21 bin to not be empty during the icemaking 

22 test. So it's just another area where we 
202-234-4433

Neal R. Gross & Co., Inc.

Page 33

1 request comment on these proposed 

2 modifications to the installation. 

3 MR. BROOKMAN: Andrew. 

4 MR. KRAUSE: This is Andrew 

5 Krause from GE. The one question we had was 

6 in reference to why the water filter is being 

7 specified and concerns about interpretation 

8 of that, and potential changes in water 

9 filters. 

10 For instance, if we changed the 

11 water filter design in Year 2, would that 

12 require us to reevaluate energy when you do 

13 that. There are multiple water filters that 

14 fit some refrigerators. So which one do you 

15 select? So a lot of different questions 

16 about the interpretation of what that rule 

17 means we have. 

18 MR. BROOKMAN: Lucas. 

19 MR. ADIN: Lucas Adin, DOE. It's 

20 a good question, and I guess I'd follow it up 

21 with a question in response, which is whether 

22 there's actually an extent to which a change 
202-234-4433

Neal R. Gross & Co., Inc.

Page 34

1 in the filter would be likely to affect the 

2 operation of the component or the icemaker or 

3 its energy use? 

4 I mean to the extent, you can be 

5 specific about what that impact might be. 

6 That would be useful for us in considering 

7 how we might address an aspect like that. 

8 MR. KRAUSE: Just some ideas on 

9 what that could be, location of the filter or 

10 the volume of water that's contained inside 

11 of it, and the temperature that's at it would 

12 affect the energy in some regards, depending 

13 on how much heat you have to remove from the 

14 water. 

15 So you know, if I was to put the 

16 water filter on the outside of the 

17 refrigerator versus the inside of the 

18 refrigerator, it affects the -- it would 

19 affect the energy in some regards. 

20 Likewise, again, the capacity of 

21 water inside that filter has to do with how 

22 much energy you have to remove from it when 
202-234-4433

Neal R. Gross & Co., Inc.

Page 35

1 you're putting it inside the refrigerator, 

2 and you put it in much cooler water, and the 

3 icemaker would affect the energy too. 

4 So the mass of water would change 

5 the results you would get. So there would be 

6 some things that would be affected there. 

7 Don't know entirely how much without doing 

8 some analysis on it, which we could do. 

9 MR. BROOKMAN: Okay, thank you. 

10 Other comments here? All right. 

11 MR. JEAN-LOUIS: So the next 

12 proposal is regarding the ambient temperature 

13 of the icemaking test. DOE is proposing a 90 

14 degree ambient temperature, which is 

15 consistent with the current requirement for 

16 the test in general, for the energy test. 

17 In addition, we're proposing, DOE 

18 is proposing that the inlet water have 

19 conditions of 90 degrees Fahrenheit, and 60 

20 psig, which would require no temperature 

21 control for the inlet water, and allow the 

22 water to equilibrate with the ambient test 
202-234-4433

Neal R. Gross & Co., Inc.

Page 36

1 chamber. 

2 Also, the pressure range falls 

3 within what we find, what we found in the 

4 product literature for most icemakers. 

5 Lastly, it's consistent with what AHAM 

6 proposed in its revised draft. So at this 

7 moment, we would like to request comment on 

8 the proposal, the ambient temperature and 

9 also the temperature of the inlet water and 

10 pressure of the inlet water. 

11 No comments here. Okay. 

12 MR. JEAN-LOUIS: So the next 

13 proposal is regarding the acquisition rate. 

14 DOE is proposing an acquisition rate that's 

15 at least once every minute, rather than 

16 what's in the current test procedure of every 

17 four minutes. 

18 Icemaking operation involves so 

19 many activities and increasing the frequency 

20 of acquisition would improve the resolution, 

21 and would also help ensure accuracy of the 

22 measurement. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 37

1 Also, DOE believes that most test 

2 facilities are already recording time resolve 

3 data of once per minute, and have the ability 

4 to do so, most likely won't add test burden 

5 here. So we're requesting comment on this 

6 acquisition rate of once per minute. 

7 MR. BROOKMAN: One of our webinar 

8 participants, Patrick Powell, has a comment, 

9 and Patrick, if you unmute your phone and 

10 speak clearly and loudly, we should be able 

11 to hear you. 

12 MR. POWELL: Yes. This is 

13 Patrick Powell with Underwriters Laboratory. 

14 I'd like to talk about the previous slide, 

15 about the water pressure. 

16 MR. BROOKMAN: Please do. 

17 MR. POWELL: I'd like 

18 clarification as to how you guys are going to 

19 measure, how a laboratory is going to measure 

20 this 60 psig plus or minus 15. Will that be 

21 as the unit is taking in water, or will it be 

22 we're to maintain that throughout the cycle 
202-234-4433

Neal R. Gross & Co., Inc.

Page 38

1 of the machine taking in water? Thank you. 

2 MR. BROOKMAN: Thank you. 

3 Detlef. 

4 MR. WESTPHALEN: Detlef 

5 Westphalen, Navigant. That is not specified 

6 in the proposal. It's something that could 

7 be considered. Andrew mentioned the review 

8 of product literature, which mentions 

9 pressure ranges that are acceptable for the 

10 connection to the refrigerator water lines, 

11 and potentially a question for the 

12 manufacturers, is that intended to imply as 

13 the water is flowing, static without flow. 

14 MR. POWELL: Correct. Thank you. 

15 MR. BROOKMAN: Additional 

16 comments here? 

17 Nothing additional. Okay. 

18 MR. JEAN-LOUIS: Okay. I guess 

19 in regard quickly to the acquisition rate, is 

20 there anything else? 

21 Okay. I'll move on then. So the 

22 next proposal regards the icemaking cycle end 
202-234-4433

Neal R. Gross & Co., Inc.

Page 39

1 points, and this proposal, DOE's proposal 

2 identifying the icemaking cycles without 

3 harvest heaters, and to -- oh, speak up. Got 

4 it. So I guess DOE is aware of several 

5 icemaker assembly designs that don't utilize 

6 an ice mold heater. 

7 So strategies for measuring or 

8 identifying the icemaking cycle have been 

9 highlighted here, which would include making 

10 measurements to or placing temperature 

11 measurements on the ice mold itself, 

12 measuring the water supply temperature and 

13 also I guess looking at the water solenoid 

14 valve, to identify when the icemaker cycle 

15 starts and stuff. 

16 So in regards to that, DOE is 

17 requesting comment on its identification of 

18 when the icemaking cycle really is, and is 

19 requesting comment on three laid out methods 

20 for identifying icemaking cycles, and the 

21 requirement of using one of these three 

22 methods. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 40

1 I guess in addition, DOE is 

2 requesting comment on whether it should 

3 further clarify when an alternative test 

4 should be used, whether additional 

5 alternative methods should be allowed, and 

6 finally an icemaking cycle delineation based 

7 on water flow into the icemaker. 

8 So I guess at this time, it would 

9 be great to hear any comments on this issue. 

10 MR. BROOKMAN: I see some notes 

11 being taken. Are there any comments for the 

12 record here? 

13 Nothing at this time. Go ahead. 

14 MR. JEAN-LOUIS: So DOE's next 

15 proposal regards the temperature control 

16 setting. I guess we have a comment coming 

17 in. 

18 MR. BROOKMAN: Yes, here we go. 

19 So Patrick Powell, he writes "How will a lab 

20 know when to harvest and heater would be on 

21 or off. Or when to harvest, heater would be 

22 on or off." 
202-234-4433

Neal R. Gross & Co., Inc.

Page 41

1 MR. JEAN-LOUIS: So could you 

2 read that one more time? 

3 MR. BROOKMAN: Patrick, why don't 

4 you just speak. You were effective. You 

5 came in loudly and clearly before. So unmute 

6 yourself and ask the question. 

7 MR. POWELL: Yes. I have a 

8 question concerning the statement in Slide 

9 26, concerning the harvest heater. How would 

10 we know, as a testing facility, when the 

11 harvest heater turns on and off? 

12 MR. JEAN-LOUIS: Right. Well 

13 from the data -- 

14 MR. POWELL: Without having to go 

15 back and look at the energy usage after the 

16 test. How would we pick it up? Yeah. 

17 MR. JEAN-LOUIS: So if I 

18 understand your question correctly, you're 

19 asking how you would be able to identify -- 

20 MR. POWELL: How would we know? 

21 How would a testing lab know when the harvest 

22 heater turns on or off? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 42

1 MR. JEAN-LOUIS: I guess it would 

2 just be an analysis of the power trace of the 

3 unit operating. So looking at the power 

4 levels and identifying when the compressor is 

5 triggering, and when what looks like a heater 

6 on ice mold is triggering. 

7 I guess based on average and 

8 typical compressor power levels and typical 

9 heater power levels and durations, to be able 

10 to identify either one. 

11 MR. POWELL: Okay, all right. 

12 MR. BROOKMAN: Patrick, do you 

13 want to comment on whether you think that's 

14 workable or not? 

15 MR. POWELL: From our 

16 laboratory's point of view, when we conduct 

17 the test for monitoring or recording the data 

18 and the energy usage during the entire test, 

19 and what you're saying is, you know, we're to 

20 go back at the end of a test and try to pick 

21 off when this heater turns on and off, what 

22 kind of watts are we looking at, you know? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 43

1 Is it 20, is it 50, is it 100? 

2 Will it be easy for us to pick this on and 

3 off, pick it when it turns on and off. 

4 MR. BROOKMAN: Okay. Thanks for 

5 the question. Here's Detlef. 

6 MR. WESTPHALEN: This is Detlef 

7 Westphalen from Navigant. Yeah, most of 

8 these harvest heaters have a wattage level of 

9 somewhere around 100 watts, and if you're 

10 looking at a wattage trace, it's very easy to 

11 identify when they energize. Does that 

12 answer the question? 

13 MR. POWELL: Yes, it does. Thank 

14 you. 

15 MR. BROOKMAN: Okay, thanks. 

16 Additional comments here? We'll a little 

17 further ahead than that. We're now on what 

18 26 or something. If you'd go to Slide 27. 

19 So we're still seeking comments 

20 on Issue 2(h) and 2(i), and particularly the 

21 three proposed methods and the requirement to 

22 use one of these three proposed or identified 
202-234-4433

Neal R. Gross & Co., Inc.

Page 44

1 methods. 

2 So I guess from your perspective, 

3 it's okay? No comment here. Okay, all 

4 right. 

5 MR. JEAN-LOUIS: Well then I'll 

6 move on to the next proposal, which involves 

7 temperature control settings for both the 

8 baseline and icemaking parts of the test. 

9 DOE took a look at its research, 

10 to identify the variation of compartments’ 

11 temperatures during the test, and how it 

12 drifted from standardized temperatures. As a 

13 result, DOE concluded that its proposal 

14 should require that compartment temperatures 

15 rise no more than one degree Fahrenheit in 

16 either compartment during the baseline test, 

17 and that same requirement holds true for the 

18 icemaking test. 

19 Those figures down below kind of 

20 show change in temperature on X axis, and 

21 percent impact on energy on the Y, and this 

22 is the data that DOE looked at to determine 
202-234-4433

Neal R. Gross & Co., Inc.

Page 45

1 that one degree Fahrenheit would be its 

2 proposal for a maximum temperature rise 

3 during the test. 

4 So as a result, DOE is requesting 

5 comment on its proposed variation limits on 

6 compartment temperatures during these parts 

7 of the test, which would require one, that 

8 compartment temperatures be set to the 

9 warmest setting that doesn't exceed one 

10 degree Fahrenheit from the baseline test. 

11 Two, that compartment 

12 temperatures increase through icemaking, that 

13 they be adjusted to their warmest setting for 

14 which the requirement are no more than one 

15 degree Fahrenheit warmer during the icemaking 

16 test than they were during the baseline test, 

17 for units that are controlled by mechanical 

18 knobs, that they be in line with the symbol 

19 on the dial. 

20 Lastly, that products that use 

21 the quick freeze control during icemaking be 

22 tested without disabling this feature during 
202-234-4433

Neal R. Gross & Co., Inc.

Page 46

1 a test. 

2 MR. BROOKMAN: Bill 

3 MR. BROWN: Bill Brown with GE 

4 Appliances. There's a couple of things I 

5 would comment regarding this. First, let's 

6 start off with the test burden of having to 

7 change the controls, in order to achieve this 

8 one degree equivalence with the baseline 

9 test. 

10 With the initial AHAM revised 

11 test procedure, you'll see that you've tested 

12 for stability. Then you enable icemaking and 

13 then collect the data and your test is 

14 complete at that point. 

15 This proposed test procedure here 

16 requires possible iteration, and that you 

17 would run the test first, get some 

18 temperatures for the fresh food and freezer 

19 compartments, then have to run the icemaking 

20 portion a number of times, depending on how 

21 good you are at changing the control setting 

22 to get within the one degree. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 47

1 So test burden-wise, this is not 

2 a favorable test procedure for manufacturers, 

3 for test labs to have to run. This greatly 

4 would increase the test time. 

5 Secondly, as far as some DOE 

6 comments regarding what the AHAM revised test 

7 procedure said, I think that there were some 

8 assumptions that DOE made about what AHAM 

9 said, that were not exactly accurate, in that 

10 the DOE stated in initial comments that AHAM 

11 believed that temperatures would vary in the 

12 field, like they do in the test, and that's 

13 not what the AHAM test procedure said. 

14 It said that customers would not 

15 be adjusting the temperatures in the field 

16 once you turn on the icemaking. It did not 

17 say that customers in the field should 

18 experience a wide range of temperatures once 

19 you start icemaking. 

20 The DOE did comment that in the 

21 field, you would have loaded freezers, and 

22 this test is an unloaded freezer. So I 
202-234-4433

Neal R. Gross & Co., Inc.

Page 48

1 believe that the comments that DOE was 

2 making, that you want to keep these 

3 temperatures within one degree, should change 

4 the control settings. 

5 Your arguments are really saying 

6 you should not change the controls, because 

7 in the field you would have a loaded freezer, 

8 and that thermal mass would not change 

9 temperature like an unloaded refrigerator or 

10 unloaded freezer. 

11 Therefore, we believe two reasons 

12 you should not change the temperature 

13 controls once you start the icemaking. One, 

14 test burden; two, in the field you would have 

15 a loaded freezer and the temperature would 

16 not change. The fact that it does in the 

17 unloaded test is not meant to be indicative 

18 of what happens in the field. 

19 MR. BROOKMAN: Okay, thank you. 

20 Additional thoughts here? 

21 Nothing additional. Okay. 

22 MR. BROWN: Oh, sorry. One other 
202-234-4433

Neal R. Gross & Co., Inc.

Page 49

1 comment on Item No. 4. This is Bill Brown 

2 with GE again, the quick freeze control 

3 during the icemaking. We believe that this 

4 really should not be part of the test. 

5 Quick freeze control is a specific feature 

6 that many products have to make a large 

7 amount of ice in a small period of time. 

8 This would be for customers who 

9 want to have -- typically, we think of if you 

10 have a party or something like that, and you 

11 want a large amount of ice. For the most 

12 part, this is a seldomly used feature. 

13 Most of the time we expect 

14 customers would use just the regular settings 

15 and not use this quick freeze control. 

16 Therefore, by mandating that this quick 

17 freeze control is on all the time is really 

18 not indicative of what we think customers, 

19 how customers would be using the product by 

20 and large. 

21 MR. BROOKMAN: Okay. Yes, 

22 Detlef. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 50

1 MR. WESTPHALEN: Detlef 

2 Westphalen, Navigant. The discussion of the 

3 quick freeze, maybe there was some 

4 misunderstanding. The intent was that quick 

5 freeze would not be activated during the 

6 icemaking test. DOE has observed at least 

7 one unit that automatically shifts into quick 

8 freeze when icemaking is active, and hence 

9 this part of the proposal. 

10 MR. BROOKMAN: Bill. 

11 MR. BROWN: Okay. This is Bill 

12 again with GE. We read this to say that you 

13 would have to turn on quick freeze. So if 

14 your intent was not that, that if it went 

15 into quick freeze on its own, then I would 

16 agree. But we read this to say if you have a 

17 quick freeze option, you must turn on quick 

18 freeze when you run the icemaking test. So 

19 is that not correct? 

20 MR. WESTPHALEN: That is not 

21 correct, and I guess we need to review the 

22 language to make sure it's more clear. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 51

1 MR. BROWN: Okay. 

2 MR. BROOKMAN: So state it again. 

3 What was your intention? What was you trying 

4 to convey? 

5 MR. WESTPHALEN: The intent is 

6 that if a product automatically goes into 

7 quick freeze when icemaking is active, that 

8 that feature not be deactivated for an 

9 icemaking test, because that is something 

10 that happens in the field when consumers are 

11 making ice, and it should be part of the test 

12 when you have, you know, trying to represent 

13 field action. 

14 MR. BROOKMAN: Okay. Additional 

15 comments here? Okay. 

16 MR. JEAN-LOUIS: So the next 

17 topic of discussion is regarding the DOE 

18 production rate for icemaking that is typical 

19 in the field. DOE proposes to use 1.8 for 

20 the ice production rate, that was initially 

21 suggested by AHAM in its update to DOE back 

22 in 2009. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 52

1 So although higher than estimates 

2 based on NEEA data, this is consistent with 

3 the current placeholder for icemaking in 

4 energy use in Appendix A. DOE is also 

5 proposing for temperature control settings 

6 during icemaking tests, that are based on the 

7 assumption that there is a little bit of 

8 deviation of cabinet temperatures during the 

9 field icemaking operations. 

10 So I guess this is looking at an 

11 extended, consecutive cycle operation, and 

12 also the thermal mass of loaded refrigerator 

13 limits on temperature deviation. 

14 So two areas of comment here. 

15 DOE is requesting comment on the daily ice 

16 production rate, and is also seeking comment 

17 on whether 1.8 pounds per day should be 

18 retained, or whether a lower rate, as 

19 suggested by the Northwest Energy Efficiency 

20 Alliance, should be considered. 

21 Secondly, DOE is also assuming 

22 that in the field, icemaking typically occurs 
202-234-4433

Neal R. Gross & Co., Inc.

Page 53

1 only during initial filling of a bin, and 

2 excessive icemaking cycles after a portion of 

3 ice has been withdrawn from the bin. 

4 So DOE is requesting comment on 

5 DOE's assumptions, and if that assumption is 

6 incorrect, information that supports an 

7 alternative approach and description of 

8 icemaking operation in the field. 

9 MR. BROOKMAN: Yes, Rob. 

10 MR. McARVER: This is Rob McArver 

11 with AHAM. I'd like to address the first 

12 issue there, the ice production rate. 

13 AHAM, together with advocates in 

14 considering NIST research and 

15 recommendations, submitted to DOE a test 

16 procedure for measuring the incremental 

17 energy to make ice, that we believe to be 

18 accurate, repeatable, and reproducible, and 

19 to represent an appropriate and acceptable 

20 balance between accuracy and test burden. 

21 DOE's proposed changes will 

22 greatly increase the test burden. We note 
202-234-4433

Neal R. Gross & Co., Inc.

Page 54

1 that DOE indicated that 0.7 pounds per day 

2 may be a more realistic value for the ice 

3 production rate, but still proposes to rely 

4 on AHAM's initial data of 1.8 pounds per day. 

5 AHAM has consistently commented 

6 that DOE should do a national study to 

7 determine a representative value for the ice 

8 production rate, and that the 1.8 pounds per 

9 day AHAM submitted was simply an estimate 

10 based on limited data. 

11 If 0.7 is a more representative 

12 value, that should inform DOE's determination 

13 regarding acceptable test burden. DOE stated 

14 that the current proposal would increase 

15 testing time by 50 percent, as compared with 

16 the current test in order to measure 

17 icemaking energy use. 

18 DOE also stated that energy use 

19 associated with automatic icemaking 

20 represents 10 to 15 percent of the rated 

21 energy use of typical refrigeration products. 

22 The ice production rate impacts that 
202-234-4433

Neal R. Gross & Co., Inc.

Page 55

1 analysis. 

2 Accordingly, AHAM is carefully 

3 reviewing DOE's proposal, and will provide 

4 detailed thoughts in our written comments. 

5 MR. BROOKMAN: Okay, thank you. 

6 Any comments on Issue 2.j? I think that's J 

7 or is it I? I, I guess it's I. I guess it 

8 is. I stand corrected. It is J. 

9 All right. Nothing additional. 

10 Okay. 

11 MR. JEAN-LOUIS: So DOE's 

12 proposal for the baseline on the icemaking 

13 tests are slight adjustments from AHAM's 

14 revised draft proposal. The baseline test 

15 would be consistent with Appendix A, Section 

16 4.1, which is the non-automatic defrost 

17 portion of the test, the first part of the 

18 test, which would be at least three hours' in 

19 duration and consisting of two, at least two 

20 compressor cycles, for systems that have 

21 cycling compressors. 

22 The icemaking test period would 
202-234-4433

Neal R. Gross & Co., Inc.

Page 56

1 be at least 24 hours of icemaking, unless 

2 interrupted by defrost or the bin filling up 

3 before that period. Icemaking would be 

4 initiated during compressor operations 

5 shortly after defrost, prior to the start of 

6 the icemaking test. 

7 For products whose compressors 

8 that do not cycle during icemaking, the test 

9 period would include the whole number of 

10 icemaking cycles. For products whose 

11 compressors do cycle during icemaking, the 

12 test would be based on compressor cycles and 

13 on icemaking cycles, which are used for an 

14 energy use calculation. 

15 Lastly stability, the 

16 temperatures for every one compressor cycle 

17 or icemaking cycle within, would have to be 

18 within three degrees Fahrenheit of the test 

19 period average. So here, DOE is 

20 proposing evaluation of the two icemaking 

21 test periods for products that cycle the 

22 compressors during icemaking. This figure 
202-234-4433

Neal R. Gross & Co., Inc.

Page 57

1 depicts a refrigerator-freezer that is 

2 cycling and is also producing ice. 

3 The red box is a test period 

4 dictated by icemaking cycles. The green box 

5 is a test period dictated by compressor 

6 cycles, and the calculation at the bottom 

7 determines the energy use per mass, using 

8 both test periods. 

9 So the compressor based test 

10 period really is what's driving the energy 

11 use here. So that's an important inclusion 

12 into the energy per mass equation here. 

13 So here is a depiction of using 

14 the single test period versus the dual test 

15 period. The green line is looking at the 

16 number of icemaking cycles and approaching 

17 stabilization energy per, icemaking energy 

18 per mass, and the yellow is looking at just 

19 the single test period, looking at a cycling 

20 compressor that is only using the icemaking 

21 cycles to determine the test period. 

22 So you can see that the dual test 
202-234-4433

Neal R. Gross & Co., Inc.

Page 58

1 period gets to a stabilizing after five-six 

2 cycles, where the single test period takes 

3 quite a long while to get there, and still 

4 isn't as good as the dual test period 

5 calculation. 

6 So here, DOE is requesting 

7 comment on its proposal to adopt the test 

8 period for the baseline part of the test 

9 that's equivalent to the existing period for 

10 products with manual defrost, in other words, 

11 consisting of a period of time of at least 

12 three hours, and also, it's requesting 

13 comment on the proposal to allow the overlap 

14 of the stabilization period with the baseline 

15 part of the test. 

16 Secondly, regarding the icemaking 

17 part of the test, with respect to 

18 refrigeration products that cycle the 

19 compressors during icemaking, DOE is 

20 requesting comment on its proposal to 

21 establish the periods for the icemaking part 

22 of the test. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 59

1 That's based on both icemaking 

2 cycles and compressor cycles. Also, that it 

3 would require that energies be calculated 

4 using both of these periods, and applying 

5 them to the same period of icemaking in order 

6 to provide a more accurate measure of 

7 icemaking energy. 

8 At this time, we'd like to hear 

9 any comments regarding these two issues. 

10 MR. BROOKMAN: Bill. 

11 MR. BROWN: I'm Bill Brown with 

12 GE Appliances. One of the concepts we used 

13 with the AHAM revised test procedure was that 

14 you are calculating the stability of the 

15 product, and you have at least seven hours 

16 for the DOE method to do that. 

17 So you're showing that you're 

18 stable for that seven hours. So we didn't 

19 feel that it was necessary to go any extra 

20 time beyond that, to create the energy for 

21 this baseline period. We've already got the 

22 seven hours. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 60

1 So this is a, you know, kind of a 

2 shortcut in the test method that we 

3 envisioned, of using the stability to become 

4 your test period. That does reduce a little 

5 bit of a burden by least three hours that you 

6 don't have to keep running that. 

7 You've already collected the 

8 data. You show you're stable. You should be 

9 able to use that data for part one of the, or 

10 for the stable part of this test. So I think 

11 if you use that concept, you wouldn't need 

12 the -- wouldn't need to allow this overlap of 

13 baseline data and stabilization data. 

14 Secondly, you had also mentioned 

15 that for any of the icemaking cycles, you've 

16 got to be within three degrees of the test 

17 average for any compressor cycle. 

18 I feel that's an unnecessary 

19 requirement, in that when the product is 

20 making ice, the temperature really depends on 

21 when the icemaker comes on during a 

22 compressor cycle. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 61

1 At the beginning of a cycle, end 

2 of a cycle, could greatly affect that 

3 temperature. So there's really no need. We 

4 would believe to put a requirement on 

5 stability during icemaking itself. 

6 During the stability part, yes. 

7 We understand the baseline part. We do 

8 understand the need for that. But during the 

9 icemaking, you're got several events 

10 happening, and to put a stability criteria at 

11 that point we feel is unnecessary. 

12 MR. BROOKMAN: Additional 

13 comments here? Nothing additional. All 

14 right. 

15 MR. JEAN-LOUIS: All right. So 

16 more comments regarding the test procedure, 

17 in particular the stability tolerance. It's 

18 requesting comment on -- DOE is requesting 

19 comment on the proposal to include a 

20 temperature stability requirement on 

21 icemaking test procedures that would require 

22 that the freezing compartment be measured for 
202-234-4433

Neal R. Gross & Co., Inc.

Page 62

1 any compressor cycle or any icemaking cycle 

2 within the test period be within three degree 

3 Fahrenheit of the compartment temperature 

4 average, as Bill has made comment on that 

5 already. 

6 And also the icemaking test 

7 period duration, DOE is requesting comment on 

8 adoption of a minimum test period of 24 

9 hours, assuming that the defrost cycle or bin 

10 doesn't fill up before then. 

11 So DOE is also seeking comment on 

12 its proposal to require that icemaking be 

13 initiated shortly after the start of a 

14 compressor after defrost. 

15 (No response.) 

16 MR. BROOKMAN: No comments here. 

17 Okay. 

18 MR. JEAN-LOUIS: So with respect 

19 to ice mass, DOE is proposing to provide 

20 clear instructions regarding the correlation 

21 of ice mass within the icemaking cycle test 

22 period. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 63

1 That would involve a method of 

2 measuring the total ice produced, determining 

3 the number of icemaking cycles, and 

4 calculating the ice per mass per cycle, ice 

5 mass per cycle, and determining that number 

6 of icemaking cycles within the icemaking test 

7 period to determine how much ice was produced 

8 in the test period that's dictated by 

9 icemaking cycles. 

10 So DOE is requesting comment on 

11 the strategy of measuring ice mass. 

12 (No response.) 

13 MR. BROOKMAN: All right. No 

14 comments here. Okay. 

15 MR. JEAN-LOUIS: So products with 

16 multiple icemakers, DOE is proposing that the 

17 measurement for icemaking energy be dictated 

18 by the through the door icemaker. So it's 

19 requesting comment on the strategy that's 

20 getting away from what AHAM suggested in its 

21 draft, and that requesting comment on whether 

22 products with multiple icemakers exist, other 
202-234-4433

Neal R. Gross & Co., Inc.

Page 64

1 than what was specified in the notice. 

2 So other configurations, and also 

3 whether or not DOE should consider modifying 

4 the proposed test procedure to address these 

5 products in a different way, and I guess now 

6 is a good time to hear any thoughts on that. 

7 MR. BROOKMAN: Yes, Jennifer. 

8 MS. AMANN: Hi. Jennifer Amann, 

9 ACEEE. In light of the absence of data about 

10 the use of the through the door icemaker, 

11 versus the icemaker -- second icemaker in the 

12 freezer bin or the freezer compartment, we 

13 wanted to encourage DOE to obtain that data, 

14 get better data on usage, and also to 

15 consider other approaches. 

16 These approaches could include 

17 measuring the icemaker of each individually, 

18 and then doing some kind of a weighted 

19 average based on their use, you know, or 

20 there are other mechanisms as well. 

21 But I think we would like to see 

22 a test procedure where we can understand what 
202-234-4433

Neal R. Gross & Co., Inc.

Page 65

1 the differences in energy use for the two. 

2 If someone purchases a refrigerator with two 

3 icemakers, they're likely to use both of 

4 them, and we'd like to have that reflected in 

5 the test. 

6 MR. BROOKMAN: Thank you. 

7 Additional comments? 

8 (No response.) 

9 MR. BROOKMAN: All right. 

10 MR. JEAN-LOUIS: So DOE is 

11 requiring that the measurement of icemaking 

12 energy use would not be required until the 

13 compliance date of future efficiency 

14 standards. 

15 So this would allow careful 

16 evaluation of test procedure changes on the 

17 measurement of overall energy use for 

18 icemakers, and also I guess the next energy 

19 conservation standards would most likely be 

20 initiated by the six-year lookback rule. 

21 So the test procedure and energy 

22 conservation standards would continue to use 
202-234-4433

Neal R. Gross & Co., Inc.

Page 66

1 the 84 kilowatt hour per year placeholder 

2 until those standards take effect. So DOE's 

3 testing suggests that 84 kilowatt hours is an 

4 appropriate energy use contribution for 

5 icemaking, based on the data available, and 

6 that using test procedures would -- 

7 Okay. So we're requesting 

8 comment here on icemaking energy use data, if 

9 any is available for products that are sold 

10 with icemakers, using the test procedure 

11 proposed in its notice. DOE is also seeking 

12 data on, in order to improve its 

13 understanding of icemaking energy use per 

14 pound of ice in typical refrigeration 

15 products. 

16 MR. BROOKMAN: Jennifer. 

17 MS. AMANN: Jennifer Amann, 

18 ACEEE. We'd like to better understand DOE's 

19 concerns with incorporating the icemaking 

20 procedures earlier, and potentially making an 

21 adjustment to the standard if necessary, or 

22 addressing this in another mechanism. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 67

1 We want to just make sure that 

2 we're clear why DOE wants to wait until the 

3 next standard. Given the six-year 

4 requirement for review, any new standard on 

5 refrigerators wouldn't take effect until 

6 after 2020. That's quite a long time frame. 

7 So I think we just want to make 

8 sure that we understand DOE's concerns, and 

9 have a chance to potentially address those 

10 concerns. 

11 MR. KIDO: Michael Kido, DOE. 

12 One of the concerns that we did have was that 

13 this particular procedure would, it's my 

14 understanding anyway, that it would actually 

15 impact the measured energy usage of -- it 

16 would change the measured energy usage of 

17 these products that would be affected. 

18 So given that and given the 

19 complexities involved with the procedure 

20 itself and integrating it, I think we also 

21 indicated that there would probably be some 

22 general familiarity issues that I think the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 68

1 manufacturers would need to develop over 

2 time. 

3 I think the agency's position is, 

4 at this point, is to make sure that all the 

5 different potential problems that might arise 

6 and taking into account the change in 

7 measured energy use that would be accompanied 

8 with the incorporation of this particular 

9 procedure. 

10 We want to make sure that 

11 everything was wrapped up within the context 

12 of a more comprehensive review of the 

13 standards themselves. So that's kind of why 

14 the agency has taken this sort of longer view 

15 approach with respect to this aspect of the 

16 test procedure. 

17 MR. BROOKMAN: Thank you. 

18 Additional questions or comments here? 

19 (No response.) 

20 MR. BROOKMAN: Okay, all right. 

21 MR. JEAN-LOUIS: So I guess along 

22 similar lines, DOE is requesting comment on 
202-234-4433

Neal R. Gross & Co., Inc.

Page 69

1 the impacts on energy use measurements of the 

2 proposed icemaking test procedure, and in 

3 addition, comments and data supporting any of 

4 the claimed changes in the measurement. 

5 DOE is also requesting comment on 

6 the proposed delay of adoption of the 

7 laboratory measurement until a future energy 

8 conservation standard takes effect. 

9 So I guess we already touched on 

10 the last, but it would be good to hear about 

11 the first two, effects on energy use and 

12 comments on data regarding what energy use 

13 might be, if it's any different. 

14 MR. BROOKMAN: Lucas Adin. 

15 MR. ADIN: Lucas Adin, DOE. Just 

16 a quick follow-up to Michael's previous, 

17 which I suppose to some extent involves this 

18 question for comment as well. 

19 But the position that DOE took in 

20 the Notice of Proposed Rulemaking regarding 

21 the requirement to measure icemaking energy 

22 use and incorporation of that energy into the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 70

1 standard is really based in large part on the 

2 data that we had available at the time that 

3 we wrote the notice and our best 

4 understanding of the impacts it would likely 

5 have. 

6 So it's not to say that any of 

7 that completely precludes the possibility of 

8 doing it earlier. But we're limited by what 

9 we know. 

10 So the more information we have 

11 about how these products actually function 

12 and what the energy use actually looks like 

13 once it's measured using this test, the 

14 better we can really assess what the impacts 

15 are likely to be and what we could feasibly 

16 do. 

17 So we made the decision that we 

18 seemed, we decided seemed best, based on the 

19 information we had available at the time. 

20 Thanks. 

21 MR. BROOKMAN: Okay. 

22 MR. JEAN-LOUIS: So the next 
202-234-4433

Neal R. Gross & Co., Inc.

Page 71

1 section of the test procedure amendments will 

2 be covered by Detlef Westphalen, so I guess 

3 we'll turn it over to you. 

4 MR. BROOKMAN: Let's take a break 

5 right now. 

6 MR. JEAN-LOUIS: Yes. 

7 MR. BROOKMAN: Okay. It's 10:30. 

8 We've made good progress. Let's take a 15 

9 minute break. Here in the Forrestal 

10 Building, you must wear a badge, visible. 

11 There are restrooms on both ends of the hall. 

12 I think most of you are now aware 

13 of where the coffee shop is, and we will 

14 resume at 10:45 right here. We've got a good 

15 start on the day; more to cover. We'll you 

16 see you back here then. 

17 (Whereupon, the above-entitled 

18 matter went off the record at 10:30 a.m. and 

19 resumed at 10:49 a.m.) 

20 MR. BROOKMAN: Okay. Let's start 

21 back up. Lucas, please. 

22 MR. ADIN: I think before we 
202-234-4433

Neal R. Gross & Co., Inc.

Page 72

1 launch back into the technical discussion, 

2 there were just a few general items that I 

3 wanted to address, and these are a couple of 

4 things that probably we should covered at the 

5 outset. 

6 But I just want to make sure it 

7 was clear for everyone here, just regarding 

8 the general intent of our proposal today, and 

9 what probably would be most helpful for us to 

10 learn from the folks at this table and on the 

11 webinar. 

12 Generally speaking, a lot of the 

13 proposed amendments in the Notice really are 

14 intended to provide clarification to a lot of 

15 parts of the test procedure. We really did 

16 not intend to significantly change the manner 

17 in which products are actually tested. 

18 In many cases, we assume that 

19 they're tested that way already, and we're 

20 simply specifying that in the language, or we 

21 just want to make sure that it's done 

22 consistently. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 73

1 So in many places, we've made an 

2 assumption that there will be no significant 

3 impact either on the measured energy use or 

4 on the burden associated with conducting the 

5 tests that way. 

6 So definitely to the extent that 

7 anyone here believes that there is in fact 

8 some kind of impact, either on the 

9 measurement or on the burden, we need to know 

10 that and the more specific you can be, the 

11 better. Those are all things that we need to 

12 consider in any final rule that we write. 

13 So you know, certainly to the 

14 extent our assumptions were incorrect or 

15 anything else, the more we know, the better. 

16 So I just wanted to make sure that that was 

17 clear for everyone here. Thanks. 

18 MR. BROOKMAN: Okay, thanks. 

19 That's helpful. That's very helpful, I 

20 think, and then I'm not sure whether that 

21 means we want to back up any, or just 

22 proceed. But certainly that could influence 
202-234-4433

Neal R. Gross & Co., Inc.

Page 74

1 the flavor of comments, I would think. 

2 Okay. Bill, you want to -- 

3 Lucas, keep going. 

4 MR. ADIN: Lucas Adin, DOE. 

5 Sorry, just very quickly. I think that in 

6 part the reason I mentioned that here is 

7 because of some of the comments that have 

8 come up already and some of the discussion we 

9 had during the break, but also because we've 

10 already covered the one item that we know has 

11 a significant potential impact on the 

12 measurements to the items going forward we 

13 expect either have a known impact that we've 

14 accounted for, or don't have a significant 

15 impact that we're aware of. 

16 So I think that's another reason 

17 that we thought this would be a good time to 

18 mention that. 

19 MR. BROOKMAN: Good. Thanks for 

20 that. So now the manufacturers, everyone 

21 here present and listening, they can respond 

22 in kind. Okay. So now we're going to hear 
202-234-4433

Neal R. Gross & Co., Inc.

Page 75

1 from Detlef Westphalen, and we're going to 

2 pick up where we left off. 

3 Test Procedure Amendments 

4 MR. WESTPHALEN: Okay. Thanks, 

5 Doug. I'm going to continue discussing the 

6 test procedure amendments that are proposed. 

7 The next one is the multiple compressor test 

8 procedure. Multiple compressor products was 

9 a topic raised in the last test procedure 

10 rulemaking. 

11 Nevertheless, there was some 

12 issues with the existing test procedure, 

13 which required separate metering of the two 

14 compressor systems, and this was a topic that 

15 was addressed with some waivers that were 

16 granted, that allowed single monitoring of 

17 all the energy use in the product. 

18 The proposal essentially adopts 

19 the waiver procedure with some changes that 

20 are not expected to alter the measured energy 

21 use, as compared with use of the waiver test 

22 procedure, and we'll get into the details as 
202-234-4433

Neal R. Gross & Co., Inc.

Page 76

1 we go through. 

2 This slide lists the various 

3 differences as compared with the waiver test 

4 procedures. I'm not going to read them off 

5 one by one. The remaining slides should 

6 touch on all of these. But if there's any 

7 that haven’t been touched on when we get 

8 through, certainly we can go back and take a 

9 look at the list again. 

10 First of all, DOE proposes to 

11 define a multiple compressor product as one 

12 having more than one compressor. DOE 

13 requests comments on that. 

14 (No response.) 

15 MR. BROOKMAN: No comments. 

16 MR. WESTPHALEN: That one should 

17 have been cut and dry. I didn't expect many 

18 comments. DOE proposes to allow test periods 

19 to be defined by temperature cycles as an 

20 alternative to compressor cycles. The 

21 existing test procedure is based primarily on 

22 compressor cycles. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 77

1 However, with multiple compressor 

2 products, sometimes identifying the 

3 compressor cycles in reviewing a wattage 

4 trace is difficult, because of the multiple 

5 compressor starts and stops. 

6 And so DOE, through some of the 

7 discussions with participants associated with 

8 the waivers, the thought of defining the 

9 cycles based on temperature cycles was 

10 mentioned, and hence the proposal allows the 

11 temperature cycles to define the test 

12 periods. 

13 There is a definition or a 

14 description of how the temperature cycles 

15 would be defined, that talks about going from 

16 a temperature minimum to another temperature 

17 minimum that is within a half a degree of 

18 that previous temperature minimum. 

19 This is in order to avoid 

20 potential, you know, mini-dips in 

21 temperature, as you go from one minimum to 

22 the next. Alternatively, the temperature 
202-234-4433

Neal R. Gross & Co., Inc.

Page 78

1 cycles could go from a maximum to a maximum. 

2 So DOE requests comments on the proposal, to 

3 allow use of temperature cycles and on the 

4 details of how these temperature cycles are 

5 described in the proposal. 

6 (No response.) 

7 MR. BROOKMAN: No comments here. 

8 MR. WESTPHALEN: Data collection 

9 is proposed to be required at a rate at least 

10 once a minute, similar to the proposal for 

11 the icemaking test procedure. DOE requests 

12 comments on this proposal. 

13 (No response.) 

14 MR. BROOKMAN: Moving on. 

15 MR. WESTPHALEN: DOE proposes to 

16 require a stabilization period that is 

17 similar to the requirement in Appendix A, the 

18 two hours involving at least one cycle, three 

19 hours in between and then two hours involving 

20 at least one cycle, rather than the fixed 24-

21 hour period that is in the current test 

22 procedure waivers. DOE requests comments on 
202-234-4433

Neal R. Gross & Co., Inc.

Page 79

1 this proposal. 

2 MR. BROOKMAN: Bill. 

3 MR. BROWN: Bill Brown with GE 

4 Appliances. You did note that the current 

5 DOE definition is kind of unworkable, in that 

6 it assumes that each system can be ran 

7 independently of the other. We recognized 

8 that and helped to write the waiver that's 

9 currently in place for many of the companies. 

10 One thing we see with the 

11 stability is you don't really have stability 

12 with multiple compressors, in that you've got 

13 each, the fresh food, the freezer compressor 

14 coming on as they need to come on; defrost 

15 happening when they need to defrost. 

16 So you don't have what the 

17 current DOE procedure really likes to 

18 reference, as far as, you know, a two hour 

19 period, a three hour period, a two hour 

20 period, and the test procedures today really 

21 assume that the compressor cycle you have, 

22 you'll have the entire year, and you'll just 
202-234-4433

Neal R. Gross & Co., Inc.

Page 80

1 interrupt it every once in a while with a 

2 defrost event. 

3 These multiple compressor 

4 refrigerator-freezers are not like that at 

5 all. You don't have any discernible pattern 

6 of compressor operation. 

7 So that's when we wrote the 

8 waiver. We put in the 24 hour period, and I 

9 would be interested to know if DOE has done 

10 any testing themselves, to see whether the 

11 stabilization period that they're proposing 

12 works better than just simply using 24 hours 

13 for the stability. 

14 MR. WESTPHALEN: DOE has 

15 conducted testing of the multiple compressor 

16 products, probably not as many tests as the 

17 manufacturers have conducted. It's possible 

18 we haven't seen quite as many variations on 

19 the design range that could be considered as 

20 the manufacturers. 

21 We certainly would request data 

22 to review, that would, you know, illustrate 
202-234-4433

Neal R. Gross & Co., Inc.

Page 81

1 some of these issues. In regards to whether 

2 the existing stabilization approach would 

3 work better than the 24 hours, it probably 

4 wouldn't work better. 

5 It's not clear, on the other 

6 hand, that it wouldn't work as well. But you 

7 know, the thought was also that there would 

8 be the potential for test burden reduction. 

9 MR. BROOKMAN: Additional 

10 comments here? 

11 (No response.) 

12 MR. BROOKMAN: Okay. 

13 MR. WESTPHALEN: The proposal 

14 includes test period simplifications where 

15 appropriate. For instance, use of the one16 part test for products with a single 

17 automatic defrost that is neither long time 

18 nor variable. 

19 Based on the description Bill 

20 just provided, it is possible that such a 

21 product does not exist. However, the 

22 proposal does include that and DOE requests 
202-234-4433

Neal R. Gross & Co., Inc.

Page 82

1 comments on this proposal. 

2 (No response.) 

3 MR. BROOKMAN: I see no comments. 

4 MR. WESTPHALEN: Okay. 

5 Additional test period simplifications were 

6 appropriate for products where one or no 

7 cycling compressors exist during normal 

8 operation during the test. The use of a test 

9 period that is at least three hours long, 

10 comprising at least two cycles of the cycling 

11 compressor system would be allowed. 

12 This would be, for instance, for 

13 the first part of the test for a two-part 

14 test, and DOE requests comments on this 

15 proposal. 

16 (No response.) 

17 MR. BROOKMAN: Nothing here. 

18 MR. WESTPHALEN: So the duration 

19 of the test period for the first part of the 

20 test, DOE proposes a 24-hour first part of 

21 the test. 

22 This proposal would require that 
202-234-4433

Neal R. Gross & Co., Inc.

Page 83

1 this test period be defined based on the 

2 primary compressor system, and in cases in 

3 which the freezer compressor cycles, that the 

4 test period would be based on the freezer 

5 compressor that would defined to be the 

6 primary compressor. 

7 And the first part of the test 

8 would be comprised of whole primary 

9 compressor cycles. The proposal also would 

10 not permit multiple individual segments of 

11 stable operation to be combined to satisfy 

12 the 24-hour requirement, as detailed in some 

13 of the discussion in the notice, that there's 

14 really not any evidence that the so-called 

15 truncation error that is the reason for the 

16 24-hour test period duration would be 

17 resolved, if multiple segments of time were 

18 combined to add up the 24 hours. 

19 Alternatively, the proposal 

20 allows a shorter test duration of 18 hours if 

21 the defrosts come frequently enough so that 

22 the 24 hour requirement cannot be met. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 84

1 However, as also indicated in the Notice, 

2 test period durations less than 18 hours 

3 would then lead to potential variation and 

4 error in the results that DOE feels would 

5 start to become significant, and hence DOE 

6 proposes the 18 hour limitation. 

7 So this comment box requests 

8 comment on all of the various aspects of the 

9 proposal for the first part of the test, the 

10 24 hour duration allowing a reduction to 18 

11 hours, the basis of that test period on the 

12 primary compressor cycles, and also the 

13 proposal that the first part of the test 

14 needs to be a single, continuous period. 

15 (No response.) 

16 MR. BROOKMAN: No comments here. 

17 Okay. 

18 MR. WESTPHALEN: DOE proposes 

19 that stabilization for the first part of the 

20 test be evaluated, based on compartment 

21 temperature rate of change less than 0.042 

22 Fahrenheit per hour. As I read this, I am 
202-234-4433

Neal R. Gross & Co., Inc.

Page 85

1 wondering whether there's inconsistency with 

2 what we said previously. 

3 The first part of the test would 

4 need to consist of a period of stable 

5 operation, defined according to the .042 

6 Fahrenheit per hour. DOE requests comment on 

7 this proposal. 

8 MR. BROOKMAN: Bill. 

9 MR. BROWN: Bill with GE 

10 Appliances. Again, I would reiterate that 

11 stability for multiple compressor product is 

12 not the same as stability for a single 

13 compressor product. 

14 If you did achieve this .042 

15 degrees per hour, it may be more due to luck 

16 than actually the product is what you'd 

17 consider to be stable. Again, with both 

18 compressors operating on their own schedule 

19 with their own controls, you may see that the 

20 fresh food is stable and the freezer's not. 

21 Then you'd keep going further and 

22 the freezer is stable and the fresh food is 
202-234-4433

Neal R. Gross & Co., Inc.

Page 86

1 not. So that's again why we chose just to 

2 use a longer period of time, instead of 

3 trying to invoke this .042 degrees per hour. 

4 Also, in some of the comments, as 

5 far as the stability criteria, the way that 

6 the DOE has worded the criteria today is, you 

7 know, a minimum of two hours, a minimum of 

8 three hours, a minimum of two hours for the 

9 three periods. 

10 So you could make those periods 

11 really long, or have a period of time really 

12 long between the two hour periods, and you 

13 could mathematically show stability to that 

14 calculation, but not necessarily have a 

15 stable product. 

16 So again, I would reiterate for 

17 multiple compressor products that probably 

18 looking at stability with a strict .042 

19 degrees per hour like you would on a single 

20 compressor product is -- I don't know. I 

21 would say it's just not applicable to the 

22 multiple compressor product. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 87

1 MR. BROOKMAN: Okay, thank you. 

2 Lucas. 

3 MR. ADIN: Lucas Adin, DOE. Just 

4 a quick follow-up question for clarification. 

5 So it sounds like, based on your comment 

6 Bill, that a single stability criteria for 

7 multiple compressor products may not be 

8 appropriate because of how they operate. 

9 It's different from single compressor 

10 products. 

11 But is it reasonable to say that 

12 multiple compressor products do get to some 

13 form of stability that is, you know, unique 

14 to perhaps each individual product, but at 

15 least it's something that you know will 

16 repeat consistently over time, or is it 

17 something that you can actually identify? 

18 MR. BROWN: Yes. This is Bill 

19 with GE again. You may see a repeating 

20 operation in the freezer, and you may see it 

21 in the fresh food. But you'd see it on 

22 different time frames. So where a freezer 
202-234-4433

Neal R. Gross & Co., Inc.

Page 88

1 temperature may be high, the fresh food may 

2 be low, and you know, if you just picture a 

3 sine curve, these are sine curves that are 

4 out of phase with one another. 

5 So you would never get to a 

6 point, or you may never get a point where 

7 you've got both of these meeting this type of 

8 stability criteria at the same time. So 

9 instead of trying to search through the data, 

10 to find if there just happens to be place 

11 where this occurs, we just chose in our 

12 waiver to just use a long period of time. 

13 MR. BROOKMAN: Okay, thank you. 

14 MR. WESTPHALEN: For the second 

15 part of the test of a two-part test, DOE's 

16 proposal does not require a 24 hour test 

17 period. 

18 The second part of the test would 

19 be conducted for each compressor system that 

20 undergoes defrost. The test period would 

21 extend from one period of stable operation 

22 before the target defrost, to another period 
202-234-4433

Neal R. Gross & Co., Inc.

Page 89

1 of stable operation after the defrost. 

2 The proposal calls for a half 

3 degree Fahrenheit compartment temperature 

4 tolerance for the start and end of the test 

5 period, consistent with the current Appendix 

6 A procedure for the second part of the test. 

7 The evaluation of the test data 

8 as described in the notice suggests that 

9 extending the test period using additional 

10 stable operation on either side of the 

11 defrost, up to 24 hours, does not reduce the 

12 truncation error associated with this part of 

13 the test. 

14 So a long comment box on the 

15 second part of the test, but basically this 

16 comment box is requesting comment on those 

17 key points associated with the second part of 

18 the test. 

19 MR. BROOKMAN: Comments on 3 dot 

20 I? 

21 (No response.) 

22 MR. BROOKMAN: I guess not. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 90

1 MR. WESTPHALEN: Then DOE expects 

2 no change in measured energy use for its 

3 proposal, as compared to the test procedure 

4 described in the waivers. 

5 DOE requests information on any 

6 products with multiple compressors, other 

7 than those already covered by the waivers, 

8 and DOE requests comment on whether the 

9 proposed test procedure would alter the 

10 measurements and what would be the magnitude 

11 of any such change. 

12 MR. BROWN: This is Bill Brown 

13 with GE Appliances. What I do have a 

14 question is your statement is that DOE 

15 expects no change. 

16 The question being have you ran, 

17 performed these tests with the waiver and 

18 with your method, and what has been your 

19 experience as far as the energy difference 

20 between the two tests? 

21 MR. WESTPHALEN: Well, we haven't 

22 conducted a methodical study of the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 91

1 differences. The differences are such that 

2 we would expect, in some cases, a slight 

3 increase in the measurement, in some cases a 

4 slight decrease in the measurement, and that 

5 those changes would depend on, you know, some 

6 of the decisions that say a lab technician 

7 might make regarding exactly when I start 

8 this test period, exactly when I end that 

9 test period. 

10 But that on overall, there would 

11 be no expectation of changes to the 

12 measurement. 

13 (No response.) 

14 MR. WESTPHALEN: Regarding 

15 possible products with multiple compressors, 

16 DOE is not aware of any such products with 

17 manual defrost and requests comment on 

18 whether any such products exist. 

19 (No response.) 

20 MR. WESTPHALEN: All right. Then 

21 we move on to the triangulation test 

22 procedure. This is proposed as an optional 
202-234-4433

Neal R. Gross & Co., Inc.

Page 92

1 test procedure. 

2 This method was discussed during 

3 the previous test procedure rulemaking, but 

4 was not adopted by DOE as part of that 

5 rulemaking. DOE proposes to adopt it with 

6 this rulemaking. 

7 The triangulation energy 

8 interpolation basically applies to products 

9 that have two compartments, a freezer 

10 compartment and a fresh food compartment. 

11 Currently, Appendix A calls for two tests for 

12 such products, and interpolation based on the 

13 measured temperatures in each of those 

14 compartments, and then selection of the 

15 energy calculation of those two 

16 interpolations that is higher. This is 

17 illustrated by the figure there. 

18 Essentially, there are two tests 

19 illustrated on the left chart on the plot of 

20 energy use, versus fresh food temperature on 

21 the right plot energy use, versus freezer 

22 temperature, and a straight line is drawn 
202-234-4433

Neal R. Gross & Co., Inc.

Page 93

1 between the two points, representing the 

2 expected energy use as a function of the 

3 temperatures, and at the standardized 

4 temperature for each of those types of 

5 compartments, the test energy is calculated. 

6 The higher value is used. That's the process 

7 for the current test procedure. 

8 Triangular interpretation is 

9 illustrated in this chart. It involves use 

10 of three tests, and for each of those three 

11 tests, there would be a measurement of the 

12 freezer compartment temperature, a 

13 measurement of a fresh food compartment 

14 temperature and an energy measurement, and 

15 the energy measurements are illustrated by 

16 the dots around the triangle up above the 

17 bottom plane. 

18 The triangular interpolation is 

19 based on the expectation that a plane 

20 connecting those three points there would 

21 describe the energy use for different 

22 combinations of compartment temperatures. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 94

1 Then the test result would be 

2 determined based on for what combination of 

3 standardized temperatures would intersect 

4 with that angled plane. 

5 DOE proposes to implement 

6 triangulation in its test procedures as an 

7 optional test. It would be implemented by 

8 incorporating by reference the Australian-New 

9 Zealand standard, that has the procedure very 

10 well defined in it. 

11 The standardized temperatures of 

12 the DOE test would be used as the target 

13 temperatures, t(XA) and t(XB) of the 

14 Australian-New Zealand standard, and then the 

15 energy use EX that is determined by that 

16 standard would then become the energy use 

17 calculated, as per Part 6 of the Appendix A 

18 test procedure. 

19 The DOE proposal calls for the 

20 first two of the three tests to be consistent 

21 with the current method, as described in 

22 Appendix A, and DOE has also proposed certain 
202-234-4433

Neal R. Gross & Co., Inc.

Page 95

1 amendments to address certification 

2 requirements, and also for enforcement and 

3 assessment purposes. 

4 First, manufacturers would be 

5 required to report if triangulation is used 

6 for certification of a particular product, 

7 and all units within the given model must be 

8 tested using the same method. 

9 For example, if you have three 

10 units that are tested for a certification 

11 report for a model, they would all be tested 

12 using triangulation rather than some with a 

13 two-part, two test and some with 

14 triangulation. 

15 Also, DOE proposes that in its 

16 testing for enforcement and assessment 

17 purposes, it would use triangulation if 

18 either triangulation was used for the 

19 certification initially, or if the results of 

20 the first two tests conducted differ by more 

21 than five percent. 

22 These are the first two tests the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 96

1 interpolations associated with the fresh food 

2 and freezer compartment temperature. If they 

3 differ by more than five percent, which would 

4 be an indication that the triangulation 

5 method may be a more accurate way to 

6 represent the energy use of that product. 

7 So DOE requests comments on its 

8 proposal, on its proposals and all aspects of 

9 its proposals, including, first of all, its 

10 intention to include triangulation, and then 

11 on all of the various details associated with 

12 its implementation, including the 

13 certification reporting and the third party 

14 testing. 

15 MR. BROOKMAN: Yes, Bill. 

16 MR. BROWN: Bill Brown with GE. 

17 I've long been an advocate of the 

18 triangulation approach that's been used in 

19 the Australia-New Zealand standard. I would 

20 note on your Slide 56 you've got the 

21 reference incorrect. You've got too many 

22 fours in it. It should just be 4474, not 
202-234-4433

Neal R. Gross & Co., Inc.

Page 97

1 44474. 

2 MR. WESTPHALEN: Thank you. 

3 MR. BROOKMAN: Okay, thanks. 

4 MR. BROWN: And also thanks for 

5 calling it Australia-New Zealand instead of 

6 just Australia. The folks from New Zealand 

7 get very upset that they do not get mentioned 

8 in the same vein as Australia. 

9 (Laughter.) 

10 MR. BROWN: So a couple of things 

11 here. With the current, with the DOE 

12 procedure that's been in place for quite some 

13 time with just a linear interpolation, I mean 

14 it forces the manufacturer, if they want to 

15 use the, get the optimum amount of energy out 

16 of the test, to basically tune the 

17 refrigerator to the test. 

18 For example, today you have 45 

19 and 5 as your reference temperatures in a 

20 refrigerator-freezer. So you'd have to keep 

21 your temperatures between the compartment 40 

22 degrees apart, and then have it go right 
202-234-4433

Neal R. Gross & Co., Inc.

Page 98

1 through the 45 and 5 line. 

2 Otherwise, you're either testing 

3 it too cold for fresh food or too cold for 

4 freezer. Same thing at 39 and 0. Now you've 

5 got to keep it 39 degrees apart, and have it 

6 go right through the 39 and zero point. 

7 Otherwise, you're testing it too cold for 

8 fresh food or too cold for freezer. 

9 The triangulation approach allows 

10 you to get the energy, as if the 

11 refrigerator- freezer were acting exactly at 

12 39 and 0. So I do believe that this is the 

13 preferred approach. I've ran the Australia14 New Zealand test many times, and am satisfied 

15 with running that test. 

16 This test is also incorporated, 

17 will be incorporated in the new IEC standard, 

18 that's supposed to be the globally harmonized 

19 standard that Yashar from NIST and I have 

20 represented the U.S. on the committee for 

21 many years, and we've worked to incorporate 

22 this in their standard as well. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 99

1 One other thing that the 

2 Australia-New Zealand standard allows is when 

3 a manufacturer would run a test. They're 

4 also given one other option of running just a 

5 single point test. If you ran a test below 

6 the reference temperature, for example, below 

7 39 and below zero, they are allowed to just 

8 use that one single point. 

9 Or they can run two points and 

10 interpolate, or run three points and do the 

11 triangulation method. Just point that out 

12 what is different in their standard versus 

13 what you're allowing here as well. 

14 The other piece is you're asking 

15 for comment as far as the triangulation, that 

16 a manufacturer must do it for all the tests. 

17 I'm just wondering whether that's necessary. 

18 If I show with two points that I pass, on 

19 another test I run three, why does it matter 

20 if I ran two on one and three on another? 

21 Why do I have to run three on 

22 every single point if I show that I pass? So 
202-234-4433

Neal R. Gross & Co., Inc.

Page 100

1 the comment would be I'm not sure of the 

2 purpose for forcing a manufacturer who wants 

3 to use triangulation, to use it on every 

4 single unit under, that's being tested for 

5 certification. It seems like you should be 

6 able to use where you want. Thank you. 

7 MR. BROOKMAN: Thank you. 

8 Additional thoughts on this comment box? Did 

9 you actually set up the comment box yet? 

10 MR. WESTPHALEN: Yes. 

11 MR. BROOKMAN: Okay. Okay, let's 

12 move on. 

13 MR. WESTPHALEN: Moving on to 

14 anti-circumvention language. DOE proposes to 

15 modify the anti-circumvention language based 

16 on stakeholder comments submitted during the 

17 previous test procedure rulemaking. 

18 The proposal is nearly identical 

19 to the anti-circumvention provisions of HRF-1 

20 2008. It's rearranged slightly for clarity 

21 and consistency with the CFR structure, and 

22 however, it also adds the clarification that 
202-234-4433

Neal R. Gross & Co., Inc.

Page 101

1 is in the current version of the anti2 circumvention language, that indicates the 

3 need for a waiver if the test procedure is 

4 non-representative. 

5 These revisions would be adopted 

6 in both the sections for refrigerators and 

7 refrigerator-freezers and the section for 

8 freezers within 430.23, and DOE requests 

9 stakeholder comment on the proposal on these 

10 modifications. 

11 (No response.) 

12 MR. WESTPHALEN: DOE may consider 

13 additional modifications to the anti14 circumvention language, to account for 

15 components that operate differently during 

16 testing. 

17 The adoption of the modified 

18 version of the anti-circumvention language 

19 aims to prevent manufacturers from sensing 

20 energy test conditions that might be used to 

21 determine that the product is in an energy 

22 test, and then adjust the control in order to 
202-234-4433

Neal R. Gross & Co., Inc.

Page 102

1 obtain a favorable result that is not 

2 representative of field energy use. 

3 Manufacturers have requested 

4 clarification on the need for waiver 

5 petitions as one example of a control type 

6 that it modifies in a range of conditions 

7 representative of testing, that is not 

8 typical for field operation. This is a 

9 control modification that runs the condenser 

10 fans at different speeds, depending on 

11 ambient temperature. 

12 DOE recognizes that some of these 

13 control features and control details may not 

14 lead to non-representative energy test 

15 measurements, and therefore DOE may consider 

16 some additional modifications to clarify when 

17 waivers would be needed. 

18 DOE seeks comment on the 

19 potential revisions that it could make to the 

20 anti-circumvention language, to provide some 

21 flexibility for such situations. 

22 (No response.) 
202-234-4433

Neal R. Gross & Co., Inc.

Page 103

1 MR. BROOKMAN: No comments here, 

2 nothing. Okay. 

3 MR. WESTPHALEN: We move on to 

4 incomplete cycling. DOE proposes the use of 

5 test periods that align with the compressor 

6 cycles for incomplete cycling products. 

7 The current test procedure calls 

8 for use of a 24 hour test period for 

9 incomplete cycling products. These are 

10 products that do not complete two compressor 

11 cycles within 24 hours. 

12 DOE was concerned about test 

13 burden associated with potentially growing to 

14 48 hour test periods, and included in its 

15 proposal an allowance that if the compressor 

16 cycles are more than 12 hours long, that a 

17 single compressor cycle test period could be 

18 used. 

19 DOE also, in its proposal 

20 associated with incomplete cycling products, 

21 proposes some changes that to some extent are 

22 corrections of some changes that were made 
202-234-4433

Neal R. Gross & Co., Inc.

Page 104

1 during the last test procedure rulemaking. 

2 Essentially, this is associated 

3 with products with automatic defrost that is 

4 not long-time or variable defrost, that 

5 require use of the same test periods for 

6 temperature and energy use measurement. 

7 The additional proposals here 

8 clarify that the temperature measurement for 

9 such products should be made during a period 

10 of stable operation. That does not include 

11 the temperature rise associated with the 

12 defrost. 

13 So DOE requests comments on its 

14 proposed amendments to the incomplete cycling 

15 definition, and also the associated 

16 modification of the test period for such 

17 products, from 24 hours to one complete 

18 compressor cycle, and also on its comments 

19 regarding altering the test period 

20 requirements for measurement of temperatures. 

21 MR. BROOKMAN: Comments on 

22 incomplete cycling. Bill? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 105

1 MR. BROWN: Yes. This is Bill 

2 from GE. GE recognizes that this is an issue 

3 with the current test procedure, and we note 

4 the same issues that DOE does with how you 

5 test a product that has a longer than 12 hour 

6 compressor cycle. 

7 What we've seen all over the 

8 world with test labs is that even though the 

9 DOE's test procedure says to stop the test at 

10 24 hours, we have not seen a test lab 

11 actually do that. They would actually go and 

12 use a whole number of compressor cycles. 

13 We feel that DOE's definition 

14 here of using the single cycle for compressor 

15 cycles greater than 12 hours is acceptable, 

16 and we'd like to see that change. 

17 We'd like a couple of comments. 

18 One is, one comment I have is with the 

19 stability that you need first, if I had, for 

20 example, an 18 hour compressor cycle, before 

21 I even collect the data I'd have to have 

22 three 18 hour cycles, which would be the two 
202-234-4433

Neal R. Gross & Co., Inc.

Page 106

1 hour-three hour-two hour, and then I would 

2 run 18 hours after that. 

3 So in essence to run this, where 

4 you're looking at a test period that's really 

5 18 hours, it really takes me four days to run 

6 that test, just to show that I'm stable. 

7 Then I go and take an 18 hour compressor 

8 cycle, which should not be really any 

9 different than the previous three 18 hour 

10 cycles you just ran. 

11 So that just is to show over 

12 again, if you already showed stability, you 

13 don't need to test again to get the Part 1 of 

14 the test. 

15 Secondly is we feel that this is 

16 something that needs to be addressed now, 

17 instead of waiting, because there are 

18 products on the marketplace that do this. 

19 Labs seem to be testing a whole 

20 number of cycles, and I just want to know if 

21 DOE plans to issue a clarification on this, 

22 or do they expect manufacturers to ask for 
202-234-4433

Neal R. Gross & Co., Inc.

Page 107

1 waivers from testing this type of product. 

2 DOE also notes that given where 

3 you start the 24 hour test, if you start at a 

4 compressor on cycle or a compressor off 

5 cycle, you can have wildly different results. 

6 So in order to make this consistent, I agree 

7 with DOE's approach, but would like some 

8 clarification for today's products. 

9 MR. BROOKMAN: Lucas. 

10 MR. ADIN: Lucas Adin, DOE. We 

11 appreciate that comment very much, and it's 

12 very useful for us to know what's going on 

13 out in the real testing world, and to the 

14 extent we can offer any kind of guidance, we 

15 certainly will. That's something we'll have 

16 to figure out on our end. 

17 But certainly to the extent we 

18 can try and deal with this sooner rather than 

19 later, we will. So thank you. 

20 MR. WESTPHALEN: Next we get to 

21 mechanical control settings. DOE proposes to 

22 specify the meaning of the warmest or coldest 
202-234-4433

Neal R. Gross & Co., Inc.

Page 108

1 temperature control settings for mechanical 

2 controls. 

3 These are controls that typically 

4 might have some type of indicator or 

5 triangle, an arrow and some symbols or some 

6 numbers, 1-2-3-4-5 or, in the case of Spinal 

7 Tap, up to 11. 

8 You know, in some cases you would 

9 say okay, align the arrow with the furthest 

10 symbol. But then you might ask okay, well if 

11 the dial actually moves past that symbol, 

12 like another ten degrees or 20 degrees or 30 

13 degrees, is that really the coldest or the 

14 warmest setting. 

15 DOE proposes to clarify its 

16 alignment with the symbols that is the 

17 appropriate setting for coldest or warmest. 

18 So DOE requests comment on that proposal. 

19 MR. BROOKMAN: Bill. 

20 MR. BROWN: So is it DOE's 

21 opinion that today's test procedure specifies 

22 to set it at the symbol instead of the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 109

1 physical extremes? 

2 MR. ADIN: Lucas Adin, DOE. I 

3 think, at least in part, this proposal 

4 reflects that the test procedure is a bit 

5 ambiguous about that. So it's likely that 

6 it's been done either way, depending on the 

7 product. 

8 I don't know that I personally 

9 could characterize which way it's definitely 

10 supposed to be under the existing language. 

11 But we're aware that the language is somewhat 

12 ambiguous. It could be interpreted either 

13 way, and it probably has been done in either 

14 of those ways. So I don't know if that 

15 answers your question, but -- 

16 MR. BROWN: I'm well aware that 

17 test labs do it both ways. In fact, I had 

18 one supplier that asked me, after having 

19 asked two separate task labs, one test lab 

20 giving the physical extreme answer, the other 

21 test lab giving the marks on the knob. 

22 So and it does make a difference. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 110

1 I mean the energy associated with temperature 

2 is not exactly linear. So if you can go 

3 beyond the extremes, you're in the non-linear 

4 portion. So the energy will be affected. 

5 So if you're saying today, then, 

6 that either way is correct, okay, I would 

7 understand that. If you say there is no 

8 correct way, but you intend to make one way 

9 correct, that's what I'd like to understand. 

10 MR. ADIN: I think it's probably 

11 the latter of those two, that it could be 

12 done either way, and we're trying to specify 

13 the appropriate way to do it, so that it's 

14 done consistently across the board. 

15 I don't know that honestly we'd 

16 really thought previously about which of 

17 those two was better, and frankly until these 

18 issues started coming up, whether we had 

19 thought about there even being a difference, 

20 that labs might be doing it one of two 

21 different ways. But now that we're 

22 pretty well aware of that, it seems 
202-234-4433

Neal R. Gross & Co., Inc.

Page 111

1 appropriate to specify that one should be 

2 done consistently, and this proposal reflects 

3 which one we think is the most appropriate. 

4 MR. WESTPHALEN: Moving on to 

5 ambient temperature conditions. The current 

6 test procedures, including the HRF-1 '79 

7 and/or 2008 standards that are incorporated 

8 by reference have various requirements for 

9 ambient temperature and ambient temperature 

10 gradients that are not fully consistent 

11 throughout all those documents. 

12 DOE proposes certain 

13 clarifications and requirements for measuring 

14 ambient temperature, and for demonstrating 

15 that the temperature gradient is maintained 

16 during the tests. 

17 First of all, the clarifications 

18 indicate that shielding is allowed, but that 

19 the relocation of sensors that is discussed 

20 in the test procedures is not allowed. The 

21 test procedure language that is proposed 

22 addresses heat from adjacent test units, not 
202-234-4433

Neal R. Gross & Co., Inc.

Page 112

1 just from the condensing unit of the unit 

2 under test. 

3 The proposal also requires that 

4 temperature gradients must be verified during 

5 testing, based on sensors on both sides of 

6 the test unit, at heights of two inches, 36 

7 inches above the floor and then 12 inches 

8 above the test unit. 

9 DOE requests comment on all of 

10 these proposals in regard to the ambient 

11 temperature and the temperature gradients. 

12 (No response.) 

13 MR. BROOKMAN: No comments here? 

14 No. Okay. No. 

15 MR. WESTPHALEN: DOE proposes 

16 certain definitions associated with defrost 

17 cycles. Many of these definitions are 

18 already in the existing test procedures. I 

19 should say that these terms are already in 

20 the existing test procedures, but they are 

21 just not defined formally. 

22 DOE proposes to adopt 
202-234-4433

Neal R. Gross & Co., Inc.

Page 113

1 definitions. Stable operation is defined to 

2 exclude any events associated with the 

3 defrost cycles, and otherwise to be 

4 consistent with the requirements for 

5 evaluating stability prior to testing the 

6 0.042 degree Fahrenheit per hour requirement 

7 that is in Appendix A, Section 29. 

8 A stable period of compressor 

9 operation means a period of stable operation 

10 of a refrigeration system that has a 

11 compressor, and there are also definitions 

12 for pre-cooling and recovery that are very 

13 consistent with the existing use of those 

14 terms currently in the test procedure. DOE 

15 requests comment on these definitions. 

16 (No response.) 

17 MR. BROOKMAN: No comments. 

18 MR. WESTPHALEN: I think at this 

19 stage, we had planned to hand it back over to 

20 Lucas. 

21 Other Issues Under Consideration 

22 MR. ADIN: All right. So a few 
202-234-4433

Neal R. Gross & Co., Inc.

Page 114

1 more items to cover in this area. I'm 

2 jumping in here, not necessarily because this 

3 is particularly one of my favorite items, but 

4 I'm familiar with it. 

5 So this is a requirement that is 

6 in both AHAM, HRF-1 1979 procedure and by 

7 reference the DOE procedure. Freezers have 

8 to be loaded with spinach packages, frozen 

9 spinach packages for the testing, and there 

10 is a specific set of criteria in the AHAM 

11 procedure about how they're to be arranged, 

12 and how many are supposed to be in there. 

13 In many respects, it should seem 

14 relatively straightforward as to how you 

15 accomplish that. But believe it or not, 

16 we've received questions about how that was 

17 actually accomplished. So we thought it 

18 prudent at this point to provide a little bit 

19 more specificity as to how that should be 

20 done and to specifically require that those, 

21 the number of packages in the freezer for the 

22 test be recorded. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 115

1 So we do request comment on those 

2 clarifications, and whether those are 

3 consistent with the requirements of the AHAM 

4 procedure. 

5 MR. BROOKMAN: Bill. 

6 MR. BROWN: I hate to be the only 

7 one making comments. 

8 MR. BROOKMAN: We love for you to 

9 have comments. 

10 MR. BROWN: GE Appliances agrees 

11 with the DOE clarifications. In fact, as 

12 Lucas said, we believe that it's clear that 

13 this is the way that it should be done to 

14 begin with, and yet we have seen test labs 

15 around the world do this differently. 

16 Some of them will calculate the 

17 volume of the compartment, calculate the 

18 volume of a package, and then determine okay, 

19 this is how many packages can be filled. 

20 That would only work if you to reduce those 

21 packages down to dust and try to pour them 

22 in. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 116

1 You may not be able to fit that 

2 many packages into a compartment. So yes, 

3 you fit -- this is a lengthy procedure, and I 

4 think the folks that make test procedures 

5 will realize this is not a fun thing to do. 

6 When you have a 25 cubic foot 

7 chest freezer, you may be putting a 1,000 

8 spinach packages in there. Then you take 

9 them all out and put back in 75 percent with 

10 the appropriate spacing, and to get them to 

11 the point where the thermocouples should be 

12 placed. 

13 So we agree that this should be 

14 clear, and your efforts here in making this 

15 explicitly clear we support. 

16 MR. BROOKMAN: Okay, thank you. 

17 MR. BROWN: Thank you. 

18 MR. BROOKMAN: Additional 

19 comments here? 

20 (No response.) 

21 MR. BROOKMAN: Okay. 

22 MR. ADIN: All right. So the 
202-234-4433

Neal R. Gross & Co., Inc.

Page 117

1 next item here is regarding the minimum 

2 compressor run time between defrosts. 

3 For products that have variable 

4 defrost, the test procedure has some 

5 specifications for the values that should be 

6 used to represent the minimum compressor time 

7 between defrosts and the maximum. 

8 For the shortest, it's supposed 

9 to be the shortest compressor run time 

10 between defrosts that is greater or equal to 

11 six hours, but less than or equal to 12 

12 hours. 

13 Products operating with shorter 

14 CT(L) values could be expected to have more 

15 frequent defrost than does consumer energy, 

16 and so the current procedure sets a minimum 

17 at six, and in some cases -- well actually, I 

18 should clarify. 

19 DOE currently requires in 

20 certification reports that manufacturers 

21 report what their CT(L) and CT(M) values 

22 actually are, and those values are then used 
202-234-4433

Neal R. Gross & Co., Inc.

Page 118

1 in the calculation to determine the product's 

2 energy use. 

3 In some cases, DOE has observed 

4 products where the actual CT(L) value 

5 observed during the test was less than what 

6 was certified. 

7 So this is, at least in part, to 

8 account for products where either that value 

9 may have been in error or the product, for 

10 whatever reason, is operating differently 

11 than the value that was certified to reflect 

12 how the unit actually operated during the 

13 test and what its true energy use is. 

14 Because if the CT(L) value is in 

15 actuality shorter than what was certified, 

16 the energy use might be more, and thus not 

17 necessarily representative of what the 

18 certified value might imply. So are there 

19 any comments on that item? 

20 MR. BROOKMAN: Yes, Rob. 

21 MR. McARVER: I'm going to step 

22 in for Bill, since he's sorry that he has to 
202-234-4433

Neal R. Gross & Co., Inc.

Page 119

1 do all the commenting. But I'm not going to 

2 be terribly specific. I just want to mention 

3 a couple of things that have come up in our 

4 discussion with members. 

5 We have some concerns about this 

6 particular proposal, which we think might 

7 make it impossible to test products, that 

8 will have an impact on the repeatability of 

9 the tests of third party laboratories. So I 

10 will cryptically say we'll provide more 

11 detail in our written comments, but this is 

12 one I wanted to flag. 

13 MR. BROOKMAN: Okay, thanks. 

14 Other comments here? 

15 (No response.) 

16 MR. BROOKMAN: Okay. 

17 MR. ADIN: Thank you. Treatment 

18 of connected products. As I'm sure many or 

19 all of you are aware, there are new products 

20 coming online now or relatively soon that 

21 have the capability to provide connection to 

22 utilities and demand response capability, and 
202-234-4433

Neal R. Gross & Co., Inc.

Page 120

1 this was addressed fairly recently through 

2 some efforts through the EnergyStar program, 

3 to come up with a test procedure for those, 

4 and to encourage the adoption of features 

5 like that. 

6 During that process, it was 

7 recognized that the DOE test procedure does 

8 not specifically address how these products 

9 should be treated during the test. It 

10 requires that a baseline test be performed 

11 for the purposes of comparison with connected 

12 operation, which is just the DOE test. 

13 So there does need to be a 

14 provision in the DOE test that addresses how 

15 that connective component should be treated 

16 for the purpose of connecting that baseline 

17 test. 

18 So DOE proposes that for the 

19 purpose of the test, the connected component 

20 be installed, energized and connected to a 

21 communications network, but that no active 

22 communications be ongoing during the test. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 121

1 So we welcome any comments about 

2 that proposed provision. 

3 (No response.) 

4 MR. BROOKMAN: No comments. 

5 Okay. 

6 MR. ADIN: All right. The next 

7 one is product clearances to the wall during 

8 testing. 

9 So this is an item that was 

10 addressed in part in the last test procedure 

11 rulemaking. There was a little bit more 

12 specificity added in Appendix A to address 

13 this. But DOE has since recognized that a 

14 little bit more specificity might be 

15 appropriate. 

16 This proposal is based at least 

17 in part on some language that was used in the 

18 IEC procedure, and it's intended to address a 

19 wider range of potential configurations and 

20 product characteristics where there might be 

21 components on the rear of the cabinet that 

22 extend beyond that rear plane. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 122

1 So we wanted to more specifically 

2 define what constitutes that rear plane, and 

3 then how you address some of those things 

4 that might extend behind it. So these points 

5 summarize what DOE is proposing to use to 

6 specify those items, and we welcome any 

7 comments you have on that particular 

8 proposal. 

9 (No response.) 

10 MR. BROOKMAN: No comments. 

11 MR. ADIN: Okay. Relocation of 

12 shelving. So this item addresses the 

13 relationship between the placement of the 

14 thermocouples within the cabinet and 

15 components such as shelves. It's not 

16 necessarily just shelves, but really any 

17 component inside the refrigerated space that 

18 can be adjusted in position. 

19 It's to essentially specify that 

20 where there's a conflict between adjustable 

21 components and the location of the 

22 thermocouple, the thermocouple essentially 
202-234-4433

Neal R. Gross & Co., Inc.

Page 123

1 takes precedence. So shelves should be 

2 adjusted as necessary to achieve the 

3 thermocouple locations that are specified in 

4 the test procedure. 

5 Then we also specified, 

6 essentially for consistency of placement 

7 between different tests or test facilities, 

8 that where those components are relocated, 

9 that they adhere as closely as possible to 

10 the other requirements of the AHAM test that 

11 addresses that, which is even spacing of 

12 shelves. 

13 So shelves should be repositioned 

14 if necessary, but they should be still as 

15 evenly spaced as possible. Any comments on 

16 that one? 

17 (No response.) 

18 MR. ADIN: Relatively 

19 straightforward. So this slide addresses a 

20 few corrections that we identified in the 

21 language of the test procedure that might be 

22 appropriate. One is the temperature-setting 
202-234-4433

Neal R. Gross & Co., Inc.

Page 124

1 logic tables in Appendix A. This is 

2 essentially just correcting some aesthetic 

3 elements, to make sure that it's clear which 

4 items correspond to which. 

5 So it's really not a change in 

6 the language at all, just correcting the 

7 appearance of the table. We made some 

8 proposed corrections to references to the 

9 Value E in the equations. Again, that's 

10 another clarifying item. 

11 For the 7.75 cubic feet cutoff 

12 for compact refrigeration products, this is 

13 actually in the product definition in Section 

14 430.2. Just making a clarification that that 

15 refers to total refrigerated volume and not 

16 adjusted volume. 

17 The definition of defrost cycle 

18 type, that's actually in the Appendix A test 

19 procedure, that definition, and we're just 

20 clarifying that off cycle defrost is in fact 

21 a form of automatic defrost for the purposes 

22 of the test procedure and for product 
202-234-4433

Neal R. Gross & Co., Inc.

Page 125

1 classification under DOE's product classes. 

2 Any questions about those or comments? 

3 (No response.) 

4 MR. ADIN: No. Another item 

5 regarding product certification. DOE is 

6 proposing to eliminate the requirement to 

7 report product height in certification 

8 reports that is currently found in the 

9 refrigerator and freezer reporting 

10 requirements in Section 429.14. 

11 This is to reflect that DOE, in 

12 its last test procedure rule, eliminated the 

13 product height cutoff for classification of a 

14 product as compact, as it would apply to 

15 products that are designed to comply with the 

16 September 15, 2014 energy conservation 

17 standards. 

18 So essentially the height would 

19 have nothing to do with its classification as 

20 compact, for products that are designed to 

21 comply with those standards. So there's no 

22 need to report the height. Any questions or 
202-234-4433

Neal R. Gross & Co., Inc.

Page 126

1 comments on that one? 

2 MR. BROOKMAN: Bill. 

3 MR. BROWN: This is Bill. I did 

4 have one question. I can't find any place 

5 where I've had to report the product height. 

6 If I look at the CCMS template, that's not 

7 one of the -- that's not one of the items it 

8 asks for, and even prior to that, I don't 

9 recall seeing the product type. 

10 So I was kind of confused then to 

11 see that you had to stop reporting it, when I 

12 haven't seen where I've had to on any of the 

13 DOE templates. 

14 MR. ADIN: It's technically a 

15 requirement. I do understand it's not in the 

16 template. But so I don't know if I can 

17 necessarily get into why it is or isn't in 

18 the template itself. But it is in the regs, 

19 so we're just reflecting that it doesn't need 

20 to be, essentially. 

21 So I don't know if that helps 

22 answer your question at all, but there's no 
202-234-4433

Neal R. Gross & Co., Inc.

Page 127

1 need for it to be in the regulations at all. 

2 We're going to go ahead and remove it, and 

3 that's essentially all that this was really 

4 meant to address. 

5 MR. BROOKMAN: We have a comment 

6 online. Paul Griffin has a comment. Paul, 

7 take yourself off mute. 

8 MR. GRIFFIN: Hi, this is Paul 

9 Griffin. Sorry, I have no way of typing in 

10 the comment box. It just was regarding the 

11 item on the rear wall clearance. 

12 I was just going to note that 

13 although I think we appreciate the need for 

14 guidance and clarity in how to make that 

15 determination, I think that we had made, we 

16 believed that when there are externally 

17 mounted condensers, that that might 

18 reasonably be interpreted as the rear wall of 

19 the unit for determining the clearance. 

20 We may issue further written 

21 comments. Obviously, if you measure it from 

22 the externally-mounted condenser, to the wall 
202-234-4433

Neal R. Gross & Co., Inc.

Page 128

1 versus, you know, to the back frame, there's 

2 some difference in measured energy. 

3 MR. BROOKMAN: Okay, thank you. 

4 MR. ADIN: All right. So the 

5 next, if there wasn't anything further on the 

6 previous item, the next one is measurement of 

7 product volume, and this is another item that 

8 has come up since the test procedure 

9 rulemaking. DOE has learned a little bit 

10 more about how manufacturers actually measure 

11 volume and what certifications are often 

12 based upon. 

13 This is in part an effort to 

14 allow an approach that DOE deems technically 

15 acceptable, and in many cases more 

16 appropriate than physical measurement. This 

17 is in part due to the physical, or I should 

18 say the practical difficulties in measuring 

19 some products. 

20 Obviously, some products have 

21 very complicated interior dimensions and 

22 features and things that are just inherently 
202-234-4433

Neal R. Gross & Co., Inc.

Page 129

1 difficult to measure. 

2 So other than something onerous 

3 and difficult like filling it with water, 

4 there has to be a method that can properly 

5 account for all of those unusual volumes 

6 accurately. 

7 DOE recognizes that this is a 

8 common practice. It's something that could 

9 work perfectly well for DOE's purposes, but 

10 there are certain considerations that have to 

11 be made to reflect that independent 

12 verification of that volume may be difficult 

13 or impossible, depending on the information 

14 that's available to whomever is doing that 

15 verification. 

16 So DOE proposed some verification 

17 requirements, and these were intended to be 

18 consistent with the verification process for 

19 volume that was included in the AHAM 

20 verification program. 

21 DOE did some analysis of volume 

22 measurements and deemed that threshold 
202-234-4433

Neal R. Gross & Co., Inc.

Page 130

1 tolerance to be appropriate. So that's what 

2 was included. It's essentially a two percent 

3 tolerance between the volume that is 

4 certified to DOE using CAD and an independent 

5 measurement. 

6 So there are some specific 

7 verification procedures that are included in 

8 the proposal in Part 429, and an 

9 accommodation in the test procedures for the 

10 use of CAD for certification purposes. Any 

11 questions or comments on this item at this 

12 time? 

13 (No response.) 

14 MR. BROOKMAN: No comments here. 

15 Nope. 

16 MR. ADIN: This slide actually 

17 just covers a few more of the details 

18 regarding the product volume item. Actually, 

19 I should clarify. This is product volume, 

20 but a few items beyond just the CAD item. 

21 DOE has received some questions 

22 regarding how certain components should be 
202-234-4433

Neal R. Gross & Co., Inc.

Page 131

1 treated for the purpose of the volume 

2 measurement, and this is in part because the 

3 HRF-1 2008 language is a little bit broader, 

4 actually quite a bit broader than the 

5 previous HRF-1 1979 language that went almost 

6 component by component, had a lot of diagrams 

7 and things like that. 

8 So the new language is somewhat 

9 more categorical, and so there were some 

10 questions that arose as to which categories 

11 or exceptions within that language certain 

12 components fell, and how they should be 

13 treated. 

14 So DOE has issued some guidance 

15 on how to treat those components. One of 

16 them is air ducts. That's the first one 

17 that's mentioned. Another was water tanks 

18 that are used for chilling of water, for the 

19 water dispenser. 

20 So DOE proposed to add some 

21 language to Appendices A and B that would 

22 more specifically, ideally more specifically 
202-234-4433

Neal R. Gross & Co., Inc.

Page 132

1 address things like that, so that it's clear 

2 which categories within the HRF-1 language 

3 those would fall. 

4 That included the incorporation 

5 of a definition for a through the door ice 

6 water dispenser, which DOE didn't previously 

7 have. So that might provide a little bit 

8 more clarification in this area and others 

9 potentially. 

10 So we welcome any comments on 

11 these specific clarifications. 

12 MR. BROOKMAN: Yes, Nathan. 

13 MR. MOUW: Yes. Nathan Mouw from 

14 Whirlpool. I guess more of a clarifying 

15 question to ask. You just mentioned the idea 

16 of air ducts and water assemblies, and I 

17 recognize that water assembly or water 

18 reservoirs are treated differently, whether 

19 they're integral to the dispenser or not. 

20 My question is are those the only 

21 two clarifications that are being made in 

22 this proposal? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 133

1 MR. ADIN: So I don't know that I 

2 want to say that it's limited specifically to 

3 those two types of components. I think the 

4 intent really was to provide some more 

5 clarification about the general categories of 

6 components that would be excluded or included 

7 in the volume, and when I say that, I mean as 

8 far as which components are technically part 

9 of the ice water dispenser or within the 

10 refrigerated space, and thus must be 

11 included. So it's more of a 

12 clarification about what those exemptions are 

13 supposed to apply to. These are just two 

14 examples that happened to come up, and that 

15 prompted the DOE to propose some specifying 

16 language. 

17 But I don't know that it's 

18 necessarily limited to those two. I don't 

19 know of any other components offhand that 

20 might be affected by this. But those are the 

21 two that prompted DOE to propose some 

22 amendment. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 134

1 MR. BROOKMAN: Nathan, do others 

2 come to mind? 

3 MR. MOUW: So I'll just read a 

4 comment in the NOPR. I'm looking at the pre5 release. It's on page 163. 

6 The comment is "However, since 

7 the volume measurement method generally 

8 excludes volumes occupied by components that 

9 are not intended to be removed by the user, 

10 and that occupy space that cannot be used for 

11 storage," and then it goes on to talk about 

12 air ducts. 

13 This is a specific commentary in 

14 the discussion about air ducts. But that 

15 comment is perhaps different than an 

16 interpretation that we've had in the AHAM 

17 HRF-1. So I was just hoping to get some 

18 feedback on what is meant by that. So 

19 hopefully you can help us with that. 

20 MR. ADIN: I don't know that I 

21 could comment specifically on that, without 

22 knowing how the interpretations on AHAM's 
202-234-4433

Neal R. Gross & Co., Inc.

Page 135

1 side or its member side differ from DOE's. 

2 Maybe I just misunderstood what you meant by 

3 the last question. 

4 MR. BROOKMAN: Nathan. 

5 MR. MOUW: Sure. This is Nathan 

6 from Whirlpool again. As I read that 

7 statement, it seems maybe a bit contrasting 

8 to the third bullet point on the slide, which 

9 says the measured volume -- it's pretty clear 

10 on the slide that it says "The measured 

11 volume shall include all spaces within the 

12 insulated volume of each compartment, except 

13 for the volumes that must be deducted in 

14 accordance with Section 4.2 of HRF-1." 

15 And of course then if you review 

16 HRF-1, it's pretty specific. So reading that 

17 bullet point it seems clear, but then reading 

18 this commentary in the NOPR, it just puts 

19 some uncertainty into what would be included 

20 and excluded from the volume calculation. 

21 MR. ADIN: I mean I think in 

22 general what we were trying to do is really 
202-234-4433

Neal R. Gross & Co., Inc.

Page 136

1 to try and simplify the way that people think 

2 about what's supposed to be included and what 

3 isn't, and this was an effort to try and do 

4 that. 

5 So it's everything within that 

6 insulated boundary, where you treat the 

7 insulating hump of the through the door ice 

8 dispenser as part of that, and so everything 

9 inside that is not removable and it is part 

10 of the refrigerated space that's included, 

11 unless HRF-1, Section 4.2.2 says specifically 

12 to exclude it. 

13 So I think we were hoping that it 

14 would be simpler to think about it that way, 

15 you know. To the extent we were wrong about 

16 that and there's still ambiguity or any kind 

17 of conflict between the HRF-1 language or 

18 people's general understanding of what that 

19 means, I mean we'd like to know that. 

20 MR. BROOKMAN: Or if they need 

21 more specificity. 

22 MR. ADIN: Right, yes. It seemed 
202-234-4433

Neal R. Gross & Co., Inc.

Page 137

1 relatively clear to us at the time, but I 

2 understand that potentially there's some 

3 nuances in the language that made this a 

4 little bit more confusing than we intended it 

5 to be. So to the extent that's the case, we 

6 want to be able to correct it. 

7 MR. BROWN: This is Bill from GE. 

8 Specifically, then, I want to address this 

9 question of the water tank. Let's say there 

10 is a water tank within the refrigerated 

11 space. It does feed the dispenser, but 

12 they're not integrally tied to one another. 

13 MR. ADIN: Right. 

14 MR. BROWN: Would this say to 

15 include that space or to not? I'm having 

16 difficulty, even with your last sentence 

17 here. I kind of read it one way. Again, I 

18 would say that the way that the HRF-1 

19 Committee looked at this is like you said, 

20 it's inside the refrigerated space. 

21 It's not one of the three 

22 bulleted items that you're talking about. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 138

1 Therefore, it should be included. So I just 

2 wanted to just clarify from DOE's standpoint 

3 whether that type of device would be 

4 included. 

5 MR. ADIN: So our interpretation 

6 is that the water tank that is not integral 

7 to the icemaker or through the door ice water 

8 dispenser and within the refrigerated space 

9 should be included. Is that what you're 

10 asking? Okay. 

11 MR. BROOKMAN: So all this 

12 discussion is a precursor to the comment box 

13 of Issue 16, and maybe we've covered it now. 

14 Just push that up there and ask additional 

15 comments, because the preceding discussion 

16 was useful. 

17 (No response.) 

18 MR. BROOKMAN: No additional 

19 comments here? Okay. 

20 MR. ADIN: All right. This slide 

21 addresses another item regarding 

22 certification data in Section 429.14(b), 
202-234-4433

Neal R. Gross & Co., Inc.

Page 139

1 which is the part of the sampling and 

2 certification requirements for refrigerators, 

3 that specifies the data that manufacturers 

4 have to report to DOE. 

5 There are two separate 

6 paragraphs. One is data that is explicitly 

7 made publicly available and the other that is 

8 not. 

9 So DOE is making some amendments 

10 or proposing to make some amendments to that 

11 section, to specify that certain items are in 

12 fact to be treated as public, and that is 

13 whether a product has variable defrost, 

14 whether it has an anti -- actually, it should 

15 be whether it has variable anti-sweat heater 

16 control, and whether alternate temperature 

17 sensor locations were used during testing. 

18 So the specific values associated 

19 with variable defrost control the CT(L) and 

20 CT(M) values, and the variable anti-sweat 

21 heater control wattages would still remain in 

22 the non-public section. This would just be 
202-234-4433

Neal R. Gross & Co., Inc.

Page 140

1 whether the product has those features. Any 

2 questions or comments about that item before 

3 we move on? 

4 MR. BROOKMAN: Bill. 

5 MR. BROWN: So same thing then 

6 with the variable defrost. The CT(L)s and 

7 CT(M) would still be confidential; is that 

8 correct? 

9 MR. ADIN: Correct. DOE would 

10 not be making those values public, or the 

11 variable anti-sweat heater control wattages. 

12 MR. BROOKMAN: Additional 

13 questions or comments? 

14 (No response.) 

15 MR. ADIN: All right. So the 

16 next several items are some additional issues 

17 that DOE is raising for consideration. 

18 I don't necessarily have test 

19 procedure amendments proposed for them, but 

20 DOE is raising these issues at least while 

21 either in part because of questions that 

22 DOE's received, or because of observations 
202-234-4433

Neal R. Gross & Co., Inc.

Page 141

1 about certain product performance. 

2 The first deals with products 

3 that are designed to be built in. There are 

4 a number of product classes that the DOE 

5 standards address that are for products 

6 specifically designed for use in a built-in 

7 condition, where they're integral to 

8 cabinetry, fastened to the walls or floor. 

9 Obviously, products like that are 

10 configured differently than a conventional 

11 free-standing refrigerator or freezer. Their 

12 heat dissipation characteristics may very 

13 likely be quite a bit different, and in fact 

14 the energy conservation standards do reflect 

15 that they are likely to be different. 

16 But that does potentially raise 

17 some questions about testing, and so DOE is 

18 interested in comments or data regarding the 

19 potential difference in how products like 

20 this might perform if they were to be tested 

21 in a built-in configuration, where they 

22 actually have a physical enclosure around 
202-234-4433

Neal R. Gross & Co., Inc.

Page 142

1 them for the test. 

2 DOE did do a small amount of 

3 investigation of this issue with a few 

4 different products, which as we pointed out 

5 have slightly different configurations as far 

6 as how the heat is rejected from the 

7 condenser, and the impact that that may have 

8 had on their measured energy use. 

9 So and as we've pointed out, the 

10 enclosures that were used for these tests 

11 were consistent with the UL Standard 250 

12 provisions, that specify how to do that. So 

13 conceivably there is a consistent way that 

14 you could apply these provisions and build an 

15 enclosure like that. 

16 So as I mentioned, there isn't a 

17 specific proposal to require this. This is 

18 just an issue that DOE is investigating and 

19 is interested in receiving any comments or 

20 data on, both the extent to which this may 

21 affect the energy use of particular products 

22 just generally or based on their design, and 
202-234-4433

Neal R. Gross & Co., Inc.

Page 143

1 the test burden that may be associated with 

2 doing tests like this. 

3 MR. BROOKMAN: Jennifer. 

4 MS. AMANN: Jennifer Amann, 

5 ACEEE. We would be supportive of DOE 

6 incorporating testing in a built-in 

7 condition, particularly for built-in products 

8 that are only going to be used in that built9 in configuration in the field by their 

10 design, given that there is a specific design 

11 element that leads to differences in the 

12 product's performance. 

13 We think that should be reflected 

14 in the product's ability to meet the 

15 standard, as well as in the information 

16 that's provided to consumers on energy 

17 consumption. I believe that this is 

18 something that has also been looked at in 

19 testing done by Consumers Union, and that 

20 they have found similar findings, and they 

21 may have additional data that would be useful 

22 for you. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 144

1 MR. BROOKMAN: Thank you. 

2 MR. ADIN: Thank you. 

3 MR. BROOKMAN: So there you see 

4 the comment box. Additional thoughts at this 

5 time, and noting that the Department would 

6 also like to receive your comments in writing 

7 on this one. Yes, Nathan. 

8 MR. MOUW: This is Nathan from 

9 Whirlpool. So as I look at the information 

10 that's been presented on Slide 77, we do 

11 recognize that the heat rejection technology 

12 can have an impact on measured energy, if 

13 measured in a built-in condition. 

14 So perhaps we could have some 

15 insight on if a decision is made to move 

16 forward with this testing technique, what 

17 would be the process in moving forward for 

18 that, and perhaps some idea of schedules 

19 associated with that. 

20 MR. ADIN: So I think 

21 realistically it's probably too early for us 

22 to make any kind of specific statements about 
202-234-4433

Neal R. Gross & Co., Inc.

Page 145

1 how we would address this if we were to 

2 address it. It's something that we've 

3 observed in a few tests. 

4 Admittedly, our sample is 

5 relatively small. We're really only at an 

6 initial stage of evaluating the potential 

7 impacts of a change to the test like this. 

8 So the most I can probably say at this point 

9 is that it's too early for us to say. 

10 But how we decide to proceed will 

11 be based in large part on the comments that 

12 we receive on this item, and the burden that 

13 it is likely to impose as a result of the 

14 differences in testing, the extent to which 

15 it's likely to affect the measurement of 

16 energy use for a lot of these products. 

17 As you can see, for a couple 

18 anyway, in the sample that we tested, there 

19 probably is very little or no impact on that, 

20 on the measurement, at least as far as we 

21 understand, because of the way that they're 

22 configured. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 146

1 But for others it might, and so 

2 we're interested in knowing the proportion of 

3 the market that might likely be affected, and 

4 the extent to which those products might 

5 likely be affected, because that will help us 

6 determine how appropriate it might be to 

7 pursue a change to the test procedure that 

8 addresses this item, and the burden is 

9 obviously also a big part of that 

10 consideration. So it's not something that we 

11 can say right now, but -- 

12 MR. BROOKMAN: Additional 

13 thoughts or comments before I move on? 

14 (No response.) 

15 MR. BROOKMAN: Okay. 

16 MR. ADIN: All right. So the 

17 next issues deal with compliance with some of 

18 the other EPCA requirements associated with 

19 test procedure amendments, and for that, I'm 

20 going to turn back over to Detlef Westphalen. 

21 Thanks. 

22 Compliance With Other EPCA Requirements 
202-234-4433

Neal R. Gross & Co., Inc.

Page 147

1 MR. WESTPHALEN: Doug, I was 

2 going to ask, I would assume at this point we 

3 might just push on and try to get through 

4 before lunch? 

5 MR. BROOKMAN: Correct, yes. 

6 MR. WESTPHALEN: Yes. So 

7 compliance and other EPCA requirements. Some 

8 of these issues, if you've read a certain 

9 number of test procedure notices, some of the 

10 issues involved are familiar. Test burden, 

11 changes in measured energy use and stand-by 

12 and off mode energy use. 

13 First of all, test burden. DOE 

14 tentatively concludes that other than the 

15 icemaking test, none of the proposed changes 

16 have a significant impact on test burden. 

17 Many of the proposed test 

18 procedure amendments are clarifications, 

19 small changes, different view of test 

20 periods, things of that nature that DOE feels 

21 would not alter the amount of effort required 

22 to conduct the test. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 148

1 The new icemaking test procedure 

2 would increase the test burden. First of 

3 all, some upgrade of the facilities, not 

4 major upgrade providing a water supply, and 

5 DOE has provided an initial estimate of an 

6 additional $800 per testing facility. 

7 Stakeholders are welcome to comment on that. 

8 Additional instrumentation, for 

9 instance, a scale to measure the ice mass. 

10 Again, a modest cost, and also additional 

11 test time. DOE feels that the additional 

12 test time is really the major test burden 

13 impact of the proposal. 

14 DOE estimates that that would 

15 represent perhaps a 50 percent increase in 

16 the test time and, as provided, a cost 

17 estimate per test and per certified product, 

18 assuming three units tested per product. 

19 So DOE seeks comment on its 

20 preliminary assessment of the test burden, 

21 and welcomes any information regarding 

22 potential variations that manufacturers might 
202-234-4433

Neal R. Gross & Co., Inc.

Page 149

1 expect from the initial estimates. 

2 MR. BROOKMAN: Comments here? 

3 (No response.) 

4 MR. BROOKMAN: Okay. 

5 MR. WESTPHALEN: The regulatory 

6 flexibility review. DOE must determine 

7 whether a modification to the proposed test 

8 procedures would result in a significant 

9 impact on a substantial number of small 

10 entities. 

11 We just talked about the test 

12 burden associated primarily with the testing 

13 for certification for the icemaking test. 

14 The cutoff for small entities for 

15 refrigeration products has increased to 1,000 

16 employees. 

17 DOE identified a few small 

18 businesses, but only one that manufactures 

19 products that are sold with automatic 

20 icemakers, and hence that would be subject to 

21 the additional testing requirements or the 

22 additional requirements that would impose 
202-234-4433

Neal R. Gross & Co., Inc.

Page 150

1 additional test burden. 

2 DOE determined that the proposed 

3 test procedure would not have a significant 

4 economic impact on a substantial number of 

5 small entities. 

6 DOE reviewed industry average 

7 figures for research and development 

8 expenditures, provided some calculations that 

9 are detailed in the Notice of the impact, 

10 which was then approximated to be five 

11 percent of the annual research and 

12 development budget, a one-time cost for 

13 certification for that one small business 

14 manufacturer. 

15 These conclusion are based on 

16 available data, and DOE welcomes additional 

17 data that it might use to refine its 

18 estimates. So DOE requests comment on these 

19 preliminary findings regarding the impacts on 

20 small businesses. 

21 (No response.) 

22 MR. BROOKMAN: No comments here. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 151

1 Okay. 

2 MR. WESTPHALEN: Changes in 

3 measured energy use. This has been 

4 discussed, as we have been discussing the 

5 individual items. DOE concludes that changes 

6 in the energy use measurement associated with 

7 the proposed test procedure are associated 

8 primarily with the icemaking test procedure, 

9 and otherwise are minimal. 

10 DOE is proposing to require use 

11 of the icemaking test procedure when the next 

12 round of energy conservation standards after 

13 2014 take effect, and DOE requests comments 

14 on its preliminary assessment, that aside 

15 from the icemaking test procedure that the 

16 changes in the measured energy would be 

17 minimal. 

18 MR. BROOKMAN: Yes, Rob. 

19 MR. McARVER: This is Rob McArver 

20 with AHAM. I'll just reiterate a point we 

21 made earlier. But AHAM believes that some of 

22 the proposal, the changes in the proposal 
202-234-4433

Neal R. Gross & Co., Inc.

Page 152

1 could impact measured energy, and we're 

2 investigating this, discussing it with 

3 members and we'll propose, we'll provide DOE 

4 with data and comments as appropriate. 

5 MR. BROOKMAN: Thank you, okay. 

6 Yes, Nathan. 

7 MR. MOUW: This is Nathan from 

8 Whirlpool. To just add to what Rob said, as 

9 discussed we're -- I think some of these test 

10 procedure amendments are trying to do one of 

11 three things. 

12 Those three things are improve 

13 accuracy, improve repeatability or improve 

14 reproducibility. One could argue that if two 

15 of those three are trying to be done, that 

16 there is a real impact on measured energy. 

17 As an example, when I think of 

18 accuracy, I think of it as trying to better 

19 represent use in the home. That's kind of 

20 our gauge for accuracy for these test 

21 procedures. That would mean that on average, 

22 let's say the test procedure increases 
202-234-4433

Neal R. Gross & Co., Inc.

Page 153

1 measured energy by two percent, just as an 

2 example. 

3 An example of reproducibility I 

4 think is the example that was brought up by 

5 the gentleman regarding fixed condensers and 

6 its placement to the wall. 

7 You know, that is an example 

8 where if a laboratory, whether it be an 

9 enforcement laboratory or a manufacturer, is 

10 interpreting it as that condenser is not 

11 essentially placed up against the wall. 

12 Although we can call it a 

13 clarification, really for that lab, for that 

14 manufacturer, that enforcement lab, that is a 

15 real change is how energy is being measured. 

16 So a little clarity and clarification is 

17 good. In the context of 

18 reproducibility, that is a change in measured 

19 energy for those products in that 

20 manufacturer, that enforcement lab. Thanks. 

21 MR. BROOKMAN: Thank you. 

22 Additional comments? 
202-234-4433

Neal R. Gross & Co., Inc.

Page 154

1 (No response.) 

2 MR. BROOKMAN: Okay. 

3 MR. WESTPHALEN: The last topic 

4 is standby and offload energy use. As a lot 

5 of you are aware, EPCA requires DOE to 

6 consider whether its test procedures for 

7 residential products include measurement of 

8 standby off mode energy use and, if not, to 

9 make modifications so that these energy use 

10 modes are addressed. 

11 The existing test procedures and 

12 the test procedures amended as proposed do 

13 already consider the energy use associated 

14 with standby and off modes, and hence DOE 

15 concludes that it's consistent with the EPCA 

16 requirement for the standby and off modes. 

17 MR. BROOKMAN: Comments on 

18 standby and energy off mode? 

19 (No response.) 

20 MR. BROOKMAN: No, no comments. 

21 Okay. So then now is an opportunity for 

22 anybody that wishes to make concluding 
202-234-4433

Neal R. Gross & Co., Inc.

Page 155

1 remarks, summary statements of other issues 

2 you wish to raise that haven't been covered 

3 sufficiently in the course of today's 

4 meeting? 

5 (No response.) 

6 MR. BROOKMAN: Okay. Then for my 

7 part, I'll thank you. We covered a lot of 

8 ground today, and I'll turn it back to Lucas 

9 Adin for closing remarks. 

10 Oh and finally, each of you 

11 received a copy of an evaluation form. It's 

12 the last page in your packet. If you'll take 

13 just a few seconds or a minute and fill it 

14 out, that would be helpful. 

15 Conclusions and Closing Remarks 

16 MR. ADIN: All right, thanks 

17 Doug. Just a few last closing items. These 

18 are just some of the standard things that we 

19 cover at the end of each meeting. 

20 This public meeting was recorded, 

21 and there will be a transcript available 

22 relatively shortly, that we'll make available 
202-234-4433

Neal R. Gross & Co., Inc.

Page 156

1 on DOE's website, and will become part of the 

2 docket for this rulemaking, part of the 

3 public record. 

4 For written comments, the comment 

5 period closes September 23rd. Comments may 

6 be submitted as shown below. There is a 

7 rulemaking email inbox. That's probably the 

8 most expeditious way to get comments to us. 

9 You can submit them by mail, although keep in 

10 mind that they go through a very rigorous 

11 physical screening process. 

12 So they may get here quite a bit 

13 later and not necessarily completely 

14 physically intact, and interestingly enough, 

15 we still offer the opportunity for a courier 

16 delivery. 

17 If you have any questions about 

18 the issues raised in this rulemaking or 

19 really anything else related to DOE test 

20 procedures for these products, the standards, 

21 certification and compliance, anything to 

22 that effect, you can email the address shown 
202-234-4433

Neal R. Gross & Co., Inc.

Page 157

1 on the screen. 

2 They all come to me, so I'll deal 

3 with them, and we offered a couple of other 

4 links for information on DOE's standards and 

5 test procedures for these products, this 

6 rulemaking. So those are good places for 

7 more information if you need it. 

8 I'll just close by thanking you 

9 again for coming today, for those on the 

10 webinar, for your participation. We do 

11 understand that this is a busy month for a 

12 lot of you. So we very much appreciate your 

13 willingness to participate today, and we also 

14 appreciate that it's been a relatively short 

15 time since the publication of the Notice. 

16 So you may need more time to 

17 fully digest all the things that we've 

18 proposed. So certainly to the extent you 

19 need additional clarification on any of the 

20 items we've discussed today, please let us 

21 know. I think that's about it. Thanks very 

22 much. 
202-234-4433

Neal R. Gross & Co., Inc.

Page 158

1 MR. BROOKMAN: Thank you. Safe 

2 travels. 

3 (Whereupon, at 12:23 p.m., the 

4 meeting was adjourned.) 

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22
202-234-4433

Neal R. Gross & Co., Inc.

Page 159

A

ability 8:20 37:3

143:14

able 9:17 20:17

31:21 37:10 41:19

42:9 60:9 100:6

116:1 137:6

above-entitled

71:17

absence 64:9

acceptable 38:9

53:19 54:13

105:15 128:15

accessible 9:13

accommodation

130:9

accompanied 68:7

accomplish 19:5

114:15

accomplished

114:17

account 68:6

101:14 118:8

129:5

accounted 74:14

accuracy 13:16

17:21 36:21 53:20

152:13,18,20

accurate 47:9

53:18 59:6 96:5

accurately 129:6

ACEEE 2:1 20:14

64:9 66:18 143:5

achieve 46:7 85:14

123:2

acknowledge 18:4

acquisition 36:13

36:14,20 37:6

38:19

Act 16:7

acting 98:11

action 51:13

activated 30:11

50:5

activation 28:9

32:7

active 50:8 51:7

120:21

activities 36:19

actual 118:4

actuality 118:15

add 23:1 37:4

83:18 131:20

152:8

added 121:12

addition 35:17 40:1

69:3

additional 15:17

21:17,17 38:15,17

40:4 43:16 48:20

48:21 51:14 55:9

61:12,13 65:7

68:18 81:9 82:5

89:9 100:8 101:13

102:16 104:7

116:18 138:14,18

140:12,16 143:21

144:4 146:12

148:6,8,10,11

149:21,22 150:1

150:16 153:22

157:19

address 23:14

25:21 34:7 53:11

64:4 67:9 72:3

95:1 120:8 121:12

121:18 122:3

127:4 132:1 137:8

141:5 145:1,2

156:22

addressed 23:17

26:18 75:15

106:16 120:1

121:10 154:10

addresses 111:22

120:14 122:12

123:11,19 138:21

146:8

addressing 66:22

adds 100:22

adequately 14:20

adhere 123:9

Adin 1:16 4:16,18

4:19 5:18 7:1,1

10:20 11:5,7,10

21:21 22:1 25:12

33:19,19 69:14,15

69:15 71:22 74:4

74:4 87:3,3

107:10,10 109:2,2

110:10 113:22

116:22 119:17

121:6 122:11

123:18 125:4

126:14 128:4

130:16 133:1

134:20 135:21

136:22 137:13

138:5,20 140:9,15

144:2,20 146:16

155:9,16

adjacent 111:22

adjourned 158:4

adjust 101:22

adjustable 122:20

adjusted 45:13

122:18 123:2

124:16

adjusting 47:15

adjustment 66:21

adjustments 55:13

Admittedly 145:4

adopt 58:7 92:5

112:22

adopted 92:4 101:5

adoption 62:8 69:6

101:17 120:4

adopts 75:18

adverse 15:10

advocate 96:17

advocates 20:19

53:13

aesthetic 124:2

affect 34:1,12,19

35:3 61:2 142:21

145:15

affiliation 6:2

afforded 32:8

agency 68:14

agency's 68:3

agenda 3:4 4:17

7:15,16 8:14,15

11:10

agree 18:7 50:16

107:6 116:13

agreement 20:18

21:1,7

agrees 115:10

AHAM 2:3,4 13:9

13:14,19 16:5

17:9 18:6,12

19:14 22:19 25:16

29:6 36:5 46:10

47:6,8,10,13

51:21 53:11,13

54:5,9 55:2 59:13

63:20 114:6,10

115:3 123:10

129:19 134:16

151:20,21

AHAM's 15:2 54:4

55:13 134:22

ahead 40:13 43:17

127:2

aims 101:19

air 9:6 131:16

132:16 134:12,14

align 103:5 108:9

alignment 108:16

Alliance 52:20

allow 15:16 32:18

35:21 58:13 60:12

65:15 76:18 78:3

128:14

allowance 103:15

allowed 19:12 40:5

75:16 82:11 99:7

111:18,20

allowing 32:20

84:10 99:13

allows 77:10 83:20

98:9 99:2

alter 75:20 90:9

147:21

altering 104:19

alternate 139:16

alternative 32:5

40:3,5 53:7 76:20

Alternatively 77:22

83:19

Amanda 2:5 6:16

Amann 2:1 6:18,18

20:13,14 64:8,8

66:17,17 143:4,4

ambient 29:18 31:6

35:12,14,22 36:8

102:11 111:5,9,9

111:14 112:10

ambiguity 136:16

ambiguous 109:5

109:12

amended 16:21

23:9 154:12

amendment 13:12

133:22

amendments 3:8,9

8:5,8,10,12 12:1

19:15 24:16 25:4

71:1 72:13 75:3,6

95:1 104:14 139:9

139:10 140:19

146:19 147:18

152:10

American 2:1 6:19

amount 49:7,11

97:15 142:2

147:21

analysis 35:8 42:2

55:1 129:21

Andrew 1:17 2:2

6:8 7:5 25:1,6

26:20 33:3,4 38:7

and/or 111:7

angled 94:4

annual 14:12

150:11

answer 43:12

109:20 126:22

answers 109:15

anti 101:1,13

139:14

anticipate 8:14

anti-circumventi...

100:14,15,19

101:18 102:20
202-234-4433

Neal R. Gross & Co., Inc.

Page 160

anti-sweat 28:7,10

28:13,17 29:13

30:2,11 31:10,22

139:15,20 140:11

anybody 13:6

154:22

anyway 24:2 67:14

145:18

apart 97:22 98:5

apologies 7:10

appearance 124:7

Appendices 131:21

Appendix 23:6

32:15 52:4 55:15

78:17 89:5 92:11

94:17,22 113:7

121:12 124:1,18

appliance 2:3,4

4:20 6:11,14 14:9

Appliances 2:2,2

6:7,9 30:18 46:4

59:12 79:4 85:10

90:13 115:10

applicable 86:21

applied 16:21

applies 92:8

apply 17:4 26:12

29:22 125:14

133:13 142:14

applying 59:4

appreciate 5:2,15

107:11 127:13

157:12,14

appreciates 13:19

approach 16:11,20

26:2 53:7 68:15

81:2 96:18 98:9

98:13 107:7

128:14

approaches 32:5

64:15,16

approaching 57:16

appropriate 14:21

53:19 66:4 81:15

82:6 87:8 108:17

110:13 111:1,3

116:10 121:15

123:22 128:16

130:1 146:6 152:4

approximated

150:10

area 32:22 114:1

132:8

areas 52:14

argue 152:14

arguments 48:5

arose 131:10

arranged 114:11

arrow 108:5,9

ascertain 26:11

aside 151:14

asked 109:18,19

asking 12:6 41:19

99:14 138:10

asks 126:8

aspect 34:7 68:15

aspects 84:8 96:8

assemblies 132:16

assembly 39:5

132:17

assess 70:14

assessment 95:3,16

148:20 151:14

associated 32:6

54:19 73:4 77:7

89:12,17 96:1,11

103:13,20 104:2

104:11,15 110:1

112:16 113:2

139:18 143:1

144:19 146:18

149:12 151:6,7

154:13

Association 2:3,4

6:11,14

assume 72:18

79:21 147:2

assumes 79:6

assuming 52:21

62:9 148:18

assumption 29:11

31:16 52:7 53:5

73:2

assumptions 47:8

53:5 73:14

assure 32:6

August 14:16

Australia 97:6,8

98:13

Australian-New

94:8,14

Australia-New

96:19 97:5 99:2

authority 16:6

automatic 26:5,7

54:19 81:17 104:3

124:21 149:19

automatically 50:7

51:6

available 66:5,9

70:2,19 129:14

139:7 150:16

155:21,22

Avenue 1:12

average 16:14 42:7

56:19 60:17 62:4

64:19 150:6

152:21

avoid 77:19

aware 11:17 12:2

31:9 39:4 71:12

74:15 91:16

109:11,16 110:22

119:19 154:5

axis 44:20

a.m 1:12 4:2 71:18

71:19

B

B 131:21

back 26:21 41:15

42:20 51:21 71:16

71:21 72:1 73:21

76:8 113:19 116:9

128:1 146:20

155:8

Background 3:5

10:19

badge 71:10

balance 53:20

Baltimore 4:14

based 19:18 22:19

23:7 29:17 30:19

31:1,16 40:6 42:7

52:2,6 54:10

56:12 57:9 59:1

64:19 66:5 70:1

70:18 76:21 77:9

81:19 83:1,4

84:20 87:5 92:12

93:19 94:2 100:15

112:5 121:16

128:12 142:22

145:11 150:15

baseline 44:8,16

45:10,16 46:8

55:12,14 58:8,14

59:21 60:13 61:7

120:10,16

basic 10:21 11:2

12:13 16:13 20:10

23:3 29:12

basically 89:15

92:8 97:16

basis 84:11

beginning 61:1

believe 14:3 16:20

31:20 48:1,11

49:3 53:17 61:4

98:12 114:15

115:12 143:17

believed 47:11

127:16

believes 37:1 73:7

151:21

benefits 18:9

Berkeley 2:6 7:8

best 15:14 70:3,18

better 5:11 21:11

64:14 66:18 70:14

73:11,15 80:12

81:3,4 110:17

152:18

beyond 59:20

110:3 121:22

130:20

big 146:9

Bill 2:2 6:6 30:16

30:17 46:2,3 49:1

50:10,11 59:10,11

62:4 74:2 79:2,3

81:19 85:8,9 87:6

87:18 90:12 96:15

96:16 104:22

105:1 108:19

115:5 118:22

126:2,3 137:7

140:4

bin 27:15 32:21

53:1,3 56:2 62:9

64:12

bit 7:16 8:17 30:8

31:3,19 52:7 60:5

109:4 114:18

121:11,14 128:9

131:3,4 132:7

135:7 137:4

141:13 156:12

board 110:14

bottom 23:13 57:6

93:17

boundary 136:6

box 57:3,4 84:7

89:14,16 100:8,9

127:10 138:12

144:4

boxes 22:6

break 8:6,11 71:4,9

74:9

brief 7:14,16,19

20:14

briefly 24:3

bring 5:9 7:21

broad 16:12

broader 131:3,4

Brookman 1:12,15

4:4,13 5:17,20 7:2

7:9 9:22 10:8

11:4,6,9 13:3

17:13 20:11 21:16

26:20 27:1 28:2

28:22 29:3,21

30:3,16 32:9 33:3

33:18 35:9 37:7

37:16 38:2,15
202-234-4433

Neal R. Gross & Co., Inc.

Page 161

40:10,18 41:3

42:12 43:4,15

46:2 48:19 49:21

50:10 51:2,14

53:9 55:5 59:10

61:12 62:16 63:13

64:7 65:6,9 66:16

68:17,20 69:14

70:21 71:4,7,20

73:18 74:19 76:15

78:7,14 79:2 81:9

81:12 82:3,17

84:16 85:8 87:1

88:13 89:19,22

96:15 97:3 100:7

100:11 103:1

104:21 107:9

108:19 112:13

113:17 115:5,8

116:16,18,21

118:20 119:13,16

121:4 122:10

126:2 127:5 128:3

130:14 132:12

134:1 135:4

136:20 138:11,18

140:4,12 143:3

144:1,3 146:12,15

147:5 149:2,4

150:22 151:18

152:5 153:21

154:2,17,20 155:6

158:1

brought 153:4

Brown 2:2 6:6,6

30:17,17 46:3,3

48:22 49:1 50:11

51:1 59:11,11

79:3,3 85:9 87:18

90:12,12 96:16,16

97:4,10 105:1

108:20 109:16

115:6,10 116:17

126:3 137:7,14

140:5

budget 150:12

build 142:14

Building 1:11 4:12

71:10

built 141:3 143:8

built-in 141:6,21

143:6,7 144:13

bullet 135:8,17

bulleted 137:22

burden 37:4 46:6

48:14 53:20,22

54:13 60:5 73:4,9

81:8 103:13 143:1

145:12 146:8

147:10,13,16

148:2,12,20

149:12 150:1

burden-wise 47:1

business 150:13

businesses 149:18

150:20

busy 19:17 157:11

C

cabinet 52:8

121:21 122:14

cabinetry 141:8

CAD 130:4,10,20

calculate 115:16,17

calculated 59:3

93:5 94:17

calculating 59:14

63:4

calculation 56:14

57:6 58:5 86:14

92:15 118:1

135:20

calculations 15:3

150:8

call 28:12 153:12

calling 97:5

calls 89:2 92:11

94:19 103:7

capability 119:21

119:22

capacity 34:20

careful 65:15

carefully 55:2

case 15:14 24:6

108:6 137:5

cases 72:18 83:2

91:2,3 108:8

117:17 118:3

128:15

categorical 131:9

categories 131:10

132:2 133:5

CCMS 126:6

cell 9:8

Cerrito 10:4

certain 13:22 32:16

94:22 111:12

112:16 129:10

130:22 131:11

139:11 141:1

147:8

certainly 5:15

11:17 12:7 73:13

73:22 76:8 80:21

107:15,17 157:18

certification 30:13

95:1,6,10,19

96:13 100:5

117:20 125:5,7

130:10 138:22

139:2 149:13

150:13 156:21

certifications

128:11

certified 118:6,11

118:15,18 130:4

148:17

CFR 100:21

challenging 14:9

chamber 28:15

36:1

chance 20:9 67:9

change 16:17 33:22

35:4 44:20 46:7

48:3,6,8,12,16

67:16 68:6 72:16

84:21 90:2,11,15

105:16 124:5

145:7 146:7

153:15,18

changed 30:7 33:10

changes 3:7 8:4

14:5,22 15:18

16:4,9 18:4,8,13

19:3,7,8,11,20

20:8,8,15 21:8

24:5 33:8 53:21

65:16 69:4 75:19

91:5,11 103:21,22

147:11,15,19

151:2,5,16,22

changing 46:21

characteristics

121:20 141:12

characterize 109:9

chart 92:19 93:9

chest 116:7

chilling 131:18

chose 86:1 88:11

Chowdhury 10:5

circumvention

101:2,14

claimed 69:4

clarification 5:4

37:18 72:14 87:4

100:22 102:4

106:21 107:8

124:14 132:8

133:5,12 153:13

153:16 157:19

clarifications

111:13,17 115:2

115:11 132:11,21

147:18

clarify 40:3 102:16

104:8 108:15

117:18 130:19

138:2

clarifying 124:10

124:20 132:14

clarity 13:22 19:10

100:20 127:14

153:16

classes 125:1 141:4

classification 125:1

125:13,19

clear 24:6 50:22

62:20 67:2 72:7

73:17 81:5 115:12

116:14,15 124:3

132:1 135:9,17

137:1

clearance 127:11

127:19

clearances 121:7

clearly 37:10 41:5

close 157:8

closely 123:9

closes 156:5

closing 3:13 155:9

155:15,17

coffee 71:13

cold 98:3,3,7,8

coldest 107:22

108:13,17

colleagues 10:11

collect 46:13

105:21

collected 60:7

collection 78:8

colorful 8:1

combination 94:2

combinations

93:22

combined 83:11,18

come 23:2 27:5

30:22 32:1 74:8

79:14 83:21 119:3

120:3 128:8

133:14 134:2

157:2

comes 60:21

coming 40:16

79:14 110:18

119:20 157:9

comment 8:20 9:16

13:11 15:11 17:10

18:1 20:14 22:4,8

26:2,6,10 27:22

28:19 29:2,6 33:1

36:7 37:5,8 39:17

39:19 40:2,16

42:13 44:3 45:5

46:5 47:20 49:1

52:14,15,16 53:4
202-234-4433

Neal R. Gross & Co., Inc.

Page 162

58:7,13,20 61:18

61:19 62:4,7,11

63:10,19,21 66:8

68:22 69:5,18

84:7,8 85:6 87:5

89:14,16,16 90:8

91:17 99:15 100:1

100:8,9 101:9

102:18 105:18

107:11 108:18

112:9 113:15

115:1 127:5,6,10

134:4,6,15,21

138:12 144:4

148:7,19 150:18

156:4

commentary

134:13 135:18

commented 54:5

commenting 119:1

comments 5:7,13

7:19 12:3,6,8,20

13:1,5 17:10,14

20:6 21:17 27:4,5

28:2 29:9,10,15

30:18 32:3,10

35:10 36:11 38:16

40:9,11 43:16,19

47:6,10 48:1

51:15 55:4,6 59:9

61:13,16 62:16

63:14 65:7 68:18

69:3,12 74:1,7

76:13,15,18 78:2

78:7,12,22 81:10

82:1,3,14 84:16

86:4 89:19 96:7

100:16 103:1

104:13,18,21

105:17 112:13

113:17 115:7,9

116:19 118:19

119:11,14 121:1,4

122:7,10 123:15

125:2 126:1

127:21 130:11,14

132:10 138:15,19

140:2,13 141:18

142:19 144:6

145:11 146:13

149:2 150:22

151:13 152:4

153:22 154:17,20

156:4,5,8

commercial 17:5

committee 98:20

137:19

common 129:8

communications

120:21,22

compact 124:12

125:14,20

companies 18:6

79:9

company 14:17

compared 54:15

75:21 76:3 90:3

comparison 120:11

compartment

44:14,16 45:6,8

45:11 61:22 62:3

64:12 84:20 89:3

92:10,10 93:12,13

93:22 96:2 97:21

115:17 116:2

135:12

compartments

44:10 46:19 92:9

92:14 93:5

complete 46:14

103:10 104:17

completely 70:7

156:13

completion 15:6

complexities 67:19

compliance 3:11

15:20 19:12 23:9

65:13 146:17,22

147:7 156:21

compliant 15:22

complicated

128:21

comply 15:17

125:15,21

component 34:2

120:15,19 122:17

131:6,6

components 101:15

121:21 122:15,21

123:8 130:22

131:12,15 133:3,6

133:8,19 134:8

comprehensive

68:12

compressor 42:4,8

55:20 56:4,12,16

57:5,9,20 59:2

60:17,22 62:1,14

75:7,8,14 76:11

76:12,20,22 77:1

77:3,5 79:13,21

80:3,6,15 82:11

83:2,3,5,6,9 84:12

85:11,13 86:17,20

86:22 87:7,9,12

88:19 103:5,10,15

103:17 104:18

105:6,12,14,20

106:7 107:4,4

113:8,11 117:2,6

117:9

compressors 55:21

56:7,11,22 58:19

79:12 82:7 85:18

90:6 91:15

comprised 83:8

comprising 82:10

conceivably 142:13

concept 60:11

concepts 59:12

concern 18:11

19:14

concerned 103:12

concerning 41:8,9

concerns 13:21

33:7 66:19 67:8

67:10,12 119:5

concise 9:6

concluded 44:13

concludes 147:14

151:5 154:15

concluding 154:22

conclusion 150:15

Conclusions 3:13

155:15

condenser 102:9

127:22 142:7

153:10

condensers 127:17

153:5

condensing 112:1

condition 29:18

141:7 143:7

144:13

conditions 30:10

32:16 35:19

101:20 102:6

111:5

conduct 42:16

147:22

conducted 30:10

80:15,17 88:19

90:22 95:20

conducting 73:4

confidential 140:7

configuration

141:21 143:9

configurations

64:2 121:19 142:5

configured 141:10

145:22

conflict 122:20

136:17

confused 126:10

confusing 137:4

connected 119:18

120:11,19,20

connecting 93:20

120:16

connection 32:19

38:10 119:21

connective 120:15

consecutive 52:11

consensus 20:18

21:1

conservation 1:3

4:7 16:7 23:10

65:19,22 69:8

125:16 141:14

151:12

consider 12:22

64:3,15 73:12

85:17 101:12

102:15 154:6,13

consideration 3:10

9:1 32:4 113:21

140:17 146:10

considerations

129:10

considered 38:7

52:20 80:19

considering 34:6

53:14

consist 85:4

consistency 100:21

123:6

consistent 35:15

36:5 52:2 55:15

89:5 94:20 107:6

111:10 113:4,13

115:3 129:18

142:11,13 154:15

consistently 54:5

72:22 87:16

110:14 111:2

consisting 55:19

58:11

constitutes 122:2

Consulting 1:17,17

7:4,6

consumer 1:3 4:7

117:15

consumers 18:10

21:14 51:10

143:16,19

consumption 18:11

21:12 143:17

contained 34:10

content 7:17 8:1,13

10:15 21:20

context 68:11

153:17

continue 8:13

17:21 18:21 65:22

75:5
202-234-4433

Neal R. Gross & Co., Inc.

Page 163

continued 8:9,10

continuing 8:9

continuous 84:14

continuously 17:18

contrasting 135:7

contribution 66:4

control 35:21 40:15

44:7 45:21 46:21

48:4 49:2,5,15,17

52:5 101:22 102:5

102:9,13,13

107:21 108:1

139:16,19,21

140:11

controlled 45:17

controls 46:7 48:6

48:13 85:19 108:2

108:3

convened 1:11

conventional

141:10

conversations 9:9

convey 51:4

cooler 35:2

coordinate 19:11

copy 11:11 155:11

Corporation 2:5

6:5

correct 38:14 50:19

50:21 110:6,8,9

137:6 140:8,9

147:5

corrected 55:8

correcting 124:2,6

corrections 103:22

123:20 124:8

correctly 30:6

41:18

correlation 62:20

correspond 124:4

cost 148:10,16

150:12

Council 2:1 6:19

Counsel 6:22

couple 31:7 46:4

72:3 97:10 105:17

119:3 145:17

157:3

courier 156:15

course 10:9 135:15

155:3

cover 26:8 71:15

114:1 155:19

covered 3:7 8:3

21:22 24:4 71:2

72:4 74:10 90:7

138:13 155:2,7

covers 130:17

create 59:20

criteria 61:10 86:5

86:6 87:6 88:8

114:10

cryptically 119:10

CT(L) 117:14,21

118:4,14 139:19

CT(L)s 140:6

CT(M) 117:21

139:20 140:7

cube 27:17

cubic 116:6 124:11

current 32:14

35:15 36:16 52:3

54:14,16 78:21

79:4,17 89:5 93:7

94:21 97:11 101:1

103:7 105:3 111:5

117:16

currently 15:7 79:9

92:11 113:14

117:19 125:8

curve 88:3

curves 88:3

customers 47:14,17

49:8,14,18,19

cut 76:17

cutoff 124:11

125:13 149:14

cycle 37:22 38:22

39:8,14,18 40:6

52:11 56:8,11,16

56:17,21 58:18

60:17,22 61:1,2

62:1,1,9,21 63:4,5

78:18,20 79:21

103:17 104:18

105:6,14,20 106:8

107:4,5 124:17,20

cycles 39:2,20 53:2

55:20 56:10,12,13

57:4,6,16,21 58:2

59:2,2 60:15 63:3

63:6,9 76:19,20

76:22 77:3,9,9,11

77:14 78:1,3,4

82:10 83:3,9

84:12 103:6,11,16

105:12,15,22

106:10,20 112:17

113:3

cycling 55:21 57:2

57:19 82:7,10

103:4,6,9,20

104:14,22

D

D 3:1

daily 52:15

data 29:16 37:3

41:13 42:17 44:22

46:13 52:2 54:4

54:10 60:8,9,13

60:13 64:9,13,14

66:5,8,12 69:3,12

70:2 78:8 80:21

88:9 89:7 105:21

138:22 139:3,6

141:18 142:20

143:21 150:16,17

152:4

date 15:19 16:1

65:13

day 52:17 54:1,4,9

71:15

days 106:5

DC 1:12

de 16:7

deactivated 51:8

deadline 14:15

15:11

deal 28:20 107:18

146:17 157:2

deals 141:2

dealt 23:19,22

decide 145:10

decided 70:18

decision 70:17

144:15

decisions 91:6

decrease 91:4

deducted 135:13

deemed 129:22

deems 128:14

define 76:11 77:11

122:2

defined 24:8,8

76:19 77:15 83:1

83:5 85:5 94:10

112:21 113:1

defining 77:8

definitely 73:6

109:9

definition 27:14,20

77:13 79:5 104:15

105:13 124:13,17

124:19 132:5

definitions 27:8,12

28:1 112:16,17

113:1,11,15

defrost 26:1,4

55:16 56:2,5

58:10 62:9,14

79:14,15 80:2

81:17 88:20,22

89:1,11 91:17

104:3,4,12 112:16

113:3 117:4,15

124:17,20,21

139:13,19 140:6

defrosts 83:21

117:2,7,10

degree 29:17 31:6

31:17 35:14 44:15

45:1,10,15 46:8

46:22 48:3 62:2

77:17 89:3 113:6

degrees 31:2,2,19

31:22 35:19 56:18

60:16 85:15 86:3

86:19 97:22 98:5

108:12,12,13

delay 21:10 69:6

delayed 21:10

delineation 40:6

delivery 156:16

demand 14:16

119:22

demonstrating

111:14

Department 1:1,16

1:16 4:6,19 9:12

13:10 144:5

Department's 14:8

depend 91:5

depending 34:12

46:20 102:10

109:6 129:13

depends 60:20

depiction 57:13

depicts 57:1

describe 93:21

described 78:5

89:8 90:4 94:21

description 53:7

77:14 81:19

design 15:6 33:11

80:19 142:22

143:10,10

designed 15:5

125:15,20 141:3,6

designing 19:17

designs 39:5

detail 11:13 14:19

17:9 29:9,14

119:11

detailed 20:5 55:4

83:12 150:9

details 75:22 78:4

96:11 102:13

130:17

determination

54:12 127:15

determinations

16:8

determine 44:22

54:7 57:21 63:7
202-234-4433

Neal R. Gross & Co., Inc.

Page 164

101:21 115:18

118:1 146:6 149:6

determined 94:2

94:15 150:2

determines 57:7

determining 63:2,5

127:19

Detlef 1:17 7:3 30:4

30:5 32:10 38:3,4

43:5,6 49:22 50:1

71:2 75:1 146:20

develop 68:1

development 150:7

150:12

deviation 52:8,13

device 138:3

diagrams 131:6

dial 45:19 108:11

dictated 57:4,5

63:8,17

differ 95:20 96:3

135:1

difference 16:18

90:19 109:22

110:19 128:2

141:19

differences 65:1

76:3 91:1,1

143:11 145:14

different 31:3,19

33:15 64:5 68:5

69:13 87:9,22

93:21 99:12

102:10 106:9

107:5 110:21

123:7 134:15

141:13,15 142:4,5

147:19

differently 101:15

115:15 118:10

132:18 141:10

difficult 77:4 129:1

129:3,12

difficulties 128:18

difficulty 137:16

digest 157:17

dimensions 128:21

diminish 8:19

directed 18:14

disabling 45:22

disadvantage 17:5

discernible 80:5

discuss 12:9

discussed 92:2

111:19 151:4

152:9 157:20

discussing 24:18

75:5 151:4 152:2

discussion 5:3 8:13

14:7 24:20,22

32:4 50:2 51:17

72:1 74:8 83:13

119:4 134:14

138:12,15

discussions 77:7

dispenser 27:21

131:19 132:6,19

133:9 136:8

137:11 138:8

dissipation 141:12

distraction 19:4

docket 156:2

documents 111:11

DOE 6:21 7:1

12:21 13:14 14:10

14:14 16:3,6,10

17:17 18:1 19:10

19:18 20:4,16

21:4 22:13 23:5,9

23:14 24:8 25:15

25:20 26:2,6,9

27:7 28:6 31:8

32:3,18 33:19

35:13,17 36:14

37:1 39:4,16 40:1

44:9,13,22 45:4

47:5,8,10,20 48:1

50:6 51:17,19,21

52:4,15,21 53:4

53:15 54:1,6,13

54:18 56:19 58:6

58:19 59:16 61:18

62:7,11,19 63:10

63:16 64:3,13

65:10 66:11 67:2

67:11 68:22 69:5

69:15,19 74:4

76:10,12,18 77:6

78:2,11,15,22

79:5,17 80:9,14

81:22 82:14,20

84:4,5,18 85:6

86:6 87:3 90:1,5,8

90:14 91:16 92:4

92:5 94:5,12,19

94:22 95:15 96:7

97:11 100:14

101:8,12 102:12

102:15,18 103:4

103:12,19 104:13

105:4 106:21

107:2,10,21

108:15,18 109:2

111:12 112:9,15

112:22 113:14

114:7 115:11

117:19 118:3

120:7,12,14,18

121:13 122:5

125:5,11 126:13

128:9,14 129:7,16

129:21 130:4,21

131:14,20 132:6

133:15,21 139:4,9

140:9,17,20 141:4

141:17 142:2,18

143:5 147:13,20

148:5,11,14,19

149:6,17 150:2,6

150:16,18 151:5

151:10,13 152:3

154:5,14 156:19

DOE's 11:20 13:12

13:19 16:11,20

30:18 32:12 39:1

40:14 53:5,21

54:12 55:3,11

66:2,18 67:8

88:15 105:9,13

107:7 108:20

125:1 129:9 135:1

138:2 140:22

156:1 157:4

doing 35:7 64:18

70:8 110:20

129:14 143:2

door 27:21 63:18

64:10 132:5 136:7

138:7

dot 89:19

dots 93:16

Doug 1:12,15 4:13

75:5 147:1 155:17

draft 36:6 55:14

63:21

drafted 29:20

Drake 10:4

drawn 92:22

drifted 44:12

driving 57:10

dry 76:17

dual 57:14,22 58:4

ducts 131:16

132:16 134:12,14

due 85:15 128:17

duration 55:19

62:7 82:18 83:16

83:20 84:10

durations 42:9

84:2

dust 115:21

D.C 4:13

E

E 3:1 124:9

earlier 8:17 22:2

66:20 70:8 151:21

early 15:20 19:1,12

144:21 145:9

easy 43:2,10

echo 18:11 19:14

economic 150:4

economically 31:21

Economy 2:1 6:20

effect 23:12 66:2

67:5 69:8 151:13

156:22

effective 8:19 14:6

15:13 18:20 19:9

41:4

effects 69:11

efficiency 14:13

52:19 65:13

efficient 6:19 8:19

effort 17:17 128:13

136:3 147:21

efforts 13:15,18

116:14 120:2

either 42:10 44:16

73:3,8 74:13

89:10 95:18 98:2

109:6,12,13 110:6

110:12 118:8

140:21

electric 24:11,12

element 143:11

elements 124:3

eliminate 23:16

125:6

eliminated 125:12

email 156:7,22

Emily 1:18 9:18

emphasize 20:7

employees 149:16

empty 32:21

enable 46:12

enclosure 141:22

142:15

enclosures 142:10

encourage 5:8

64:13 120:4

ends 71:11

Energetics 1:18

energies 59:3

energize 43:11

energized 120:20

energy 1:1,3,16,16

4:7 6:19 9:12

13:10,15 14:13

15:3 16:6,9 17:18

18:10,18 19:16,21

20:2,10 21:12,15

23:10 33:12 34:3

34:12,19,22 35:3

35:16 41:15 42:18
202-234-4433

Neal R. Gross & Co., Inc.

Page 165

44:21 52:4,19

53:17 54:17,18,21

56:14 57:7,10,12

57:17,17 59:7,20

63:17 65:1,12,17

65:18,21 66:4,8

66:13 67:15,16

68:7 69:1,7,11,12

69:21,22 70:12

73:3 75:17,20

90:2,19 92:7,15

92:20,21 93:2,5

93:14,15,21 94:15

94:16 96:6 97:15

98:10 101:20,21

102:2,14 104:6

110:1,4 117:15

118:2,13,16

125:16 128:2

141:14 142:8,21

143:16 144:12

145:16 147:11,12

151:3,6,12,16

152:1,16 153:1,15

153:19 154:4,8,9

154:13,18

EnergyStar 2:5

6:17 120:2

Energy's 4:6,19

Energy-Efficient

2:1

enforcement 95:2

95:16 153:9,14,20

engineering 18:15

engineers 18:21

19:16

ensure 36:21

entire 42:18 79:22

entirely 35:7

entities 149:10,14

150:5

envisioned 60:3

EPA 2:5

EPCA 3:11 17:3

146:18,22 147:7

154:5,15

equal 117:10,11

equation 57:12

equations 124:9

equilibrate 35:22

Equipment 4:20

equivalence 46:8

equivalent 58:9

Eric 10:4

error 83:15 84:4

89:12 118:9

especially 17:2

20:8

essence 106:3

Essential 4:21

essentially 22:17

23:19 75:18 92:18

104:2 122:19,22

123:6 124:2

125:18 126:20

127:3 130:2

153:11

establish 23:9 27:8

58:21

established 22:14

22:16 23:4,6

estimate 54:9 148:5

148:17

estimates 52:1

148:14 149:1

150:18

evaluated 84:20

evaluating 113:5

145:6

evaluation 56:20

65:16 89:7 155:11

evenly 123:15

event 19:7 80:2

events 61:9 113:2

evidence 83:14

EX 94:15

exactly 47:9 91:7,8

98:11 110:2

example 95:9 97:18

99:6 102:5 105:20

152:17 153:2,3,4

153:7

examples 133:14

exceed 45:9

exceptions 131:11

excessive 53:2

exclude 113:2

136:12

excluded 133:6

135:20

excludes 134:8

exemption 19:12

exemptions 133:12

exist 63:22 81:21

82:7 91:18

existing 58:9 75:12

76:21 81:2 109:10

112:18,20 113:13

154:11

expect 5:2 49:13

74:13 76:17 91:2

106:22 149:1

expectation 91:11

93:19

expected 75:20

93:2 117:14

expects 90:1,15

expeditious 156:8

expenditures 150:8

experience 47:18

90:19

explain 25:2

explicitly 116:15

139:6

extend 88:21

121:22 122:4

extended 52:11

extending 89:9

extent 5:6 33:22

34:4 69:17 73:6

73:14 103:21

107:14,17 136:15

137:5 142:20

145:14 146:4

157:18

externally 127:16

externally-moun...

127:22

extra 59:19

extreme 109:20

extremely 14:9

extremes 109:1

110:3

F

Fabian 10:4

Facilitator 1:12,15

facilities 37:2 123:7

148:3

facility 41:10 148:6

fact 48:16 73:7

109:17 115:11

124:20 139:12

141:13

factory 31:13

Fahrenheit 29:18

35:19 44:15 45:1

45:10,15 56:18

62:3 84:22 85:6

89:3 113:6

fairly 120:1

fall 132:3

falling 16:18

falls 36:2

familiar 9:1 11:1

27:10 114:4

147:10

familiarity 67:22

fans 102:10

far 17:21 31:15

47:5 79:18 86:5

90:19 99:15 133:8

142:5 145:20

fastened 141:8

favorable 47:2

102:1

favorite 114:3

feasible 31:20

feasibly 70:15

feature 24:1 45:22

49:5,12 51:8

features 23:1

102:13 120:4

128:22 140:1

federal 18:3 19:18

20:2 22:14

feed 137:11

feedback 26:15

134:18

feel 59:19 60:18

61:11 105:13

106:15

feels 84:4 147:20

148:11

feet 124:11

fell 131:12

field 47:12,15,17

47:21 48:7,14,18

51:10,13,19 52:9

52:22 53:8 102:2

102:8 143:9

figure 56:22 92:17

107:16

figures 44:19 150:7

fill 62:10 155:13

filled 115:19

filling 53:1 56:2

129:3

filter 33:6,11 34:1

34:9,16,21

filters 33:9,13

final 12:15 13:2

15:15 22:13,16

23:5 73:12

finalize 20:4

finally 16:5 26:9

40:6 155:10

find 36:3 88:10

126:4

findings 143:20

150:19

finish 8:16

firmly 14:3

first 22:13 24:21

46:5,17 53:11

55:17 69:11 76:10

82:13,19,20 83:7

84:9,13,19 85:3

94:20 95:4,20,22

96:9 105:19

111:17 131:16

141:2 147:13

148:2

fit 33:14 116:1,3

five 95:21 96:3
202-234-4433

Neal R. Gross & Co., Inc.

Page 166

150:10

five-six 58:1

fixed 78:20 153:5

flag 119:12

flavor 74:1

flaw 31:8

flaws 29:7

flexibility 102:21

149:6

floor 112:7 141:8

flow 38:13 40:7

flowing 38:13

focus 9:7 18:16,22

Fogle 10:7

folks 5:13 10:22

11:16 72:10 97:6

116:4

follow 33:20

following 7:15 8:7

27:11

follow-up 69:16

87:4

food 46:18 79:13

85:20,22 87:21

88:1 92:10,20

93:13 96:1 98:3,8

foot 116:6

forces 97:14

forcing 100:2

fore 7:21

form 87:13 124:21

155:11

formally 112:21

format 9:2

Forrestal 1:11 4:12

71:9

forward 18:8 20:3

20:20 74:12

144:16,17

found 36:3 125:8

143:20

foundation 22:18

23:3

four 36:17 106:5

fours 96:22

Fourteen 9:19

frame 67:6 128:1

frames 87:22

frankly 110:17

free 12:7

freeze 45:21 49:2,5

49:15,17 50:3,5,8

50:13,15,17,18

51:7

freezer 15:1 18:18

46:18 47:22 48:7

48:10,15 64:12,12

79:13 83:3,4

85:22 87:20,22

92:9,21 93:12

96:2 98:4,8,11

114:21 116:7

125:9 141:11

freezers 1:4 4:10

11:22 23:18,20

24:1,12 26:5,13

47:21 101:8 114:7

freezer's 85:20

freezing 61:22

free-standing

141:11

frequency 36:19

frequent 117:15

frequently 83:21

fresh 46:18 79:13

85:20,22 87:21

88:1 92:10,20

93:13 96:1 98:3,8

friends 10:11

frozen 114:8

FTC 14:14 15:19

19:13

fully 111:10 157:17

fun 116:5

function 70:11 93:2

further 40:3 43:17

85:21 127:20

128:5

Furthermore 15:11

furthest 108:9

future 65:13 69:7

G

G 3:1

gauge 152:20

GE 6:6,8 30:17

33:5 46:3 49:2

50:12 59:12 79:3

85:9 87:19 90:13

96:16 105:2,2

115:10 137:7

general 6:22 22:11

27:17 35:16 67:22

72:2,8 133:5

135:22 136:18

generally 11:2,11

12:10 23:14 72:12

134:7 142:22

gentleman 153:5

getting 21:8 63:20

given 67:3,18,18

95:7 99:4 107:2

143:10

giving 109:20,21

globally 98:18

go 6:2 10:20 11:12

22:9 25:17 26:20

29:14 31:15 40:13

40:18 41:14 42:20

43:18 59:19 76:1

76:8 77:21 78:1

97:22 98:6 105:11

106:7 110:2 127:2

156:10

goes 51:6 134:11

going 4:15 7:14

8:16 10:1 21:20

24:18 25:2,17

37:18,19 74:3,12

74:22 75:1,5 76:4

77:15 85:21

107:12 118:21

119:1 127:2,12

143:8 146:20

147:2

good 4:4 5:3,12

13:9 17:15 33:20

46:21 58:4 64:6

69:10 71:8,14

74:17,19 153:17

157:6

gradient 111:15

gradients 111:10

112:4,11

grandfathering

17:3

granted 75:16

grave 17:5

great 26:15 40:9

greater 105:15

117:10

greatly 47:3 53:22

61:2

green 57:4,15

Griffin 10:6 127:6

127:8,9

ground 10:21 11:2

155:8

growing 103:13

guess 26:9,14 27:16

27:21 32:2 33:20

38:18 39:4,13

40:1,8,16 42:1,7

44:2 50:21 52:10

55:7,7 64:5 65:18

68:21 69:9 71:2

89:22 132:14

guidance 107:14

127:14 131:14

guys 37:18

G.E 2:2,2

H

half 77:17 89:2

hall 71:11

hand 9:15 81:6

113:19

happened 133:14

happening 61:10

79:15

happens 48:18

51:10 88:10

happy 9:11

hard 9:12

harmonized 98:18

harvest 27:13 39:3

40:20,21 41:9,11

41:21 43:8

hate 115:6

haven’t 76:7

hear 8:2 9:17 26:15

37:11 40:9 59:8

64:6 69:10 74:22

heat 34:13 111:22

141:12 142:6

144:11

heater 28:7,10,17

29:13 30:2,11

31:10 39:6 40:20

40:21 41:9,11,22

42:5,9,21 139:15

139:21 140:11

heaters 28:13

30:22 32:1,7 39:3

43:8

heating 28:21

height 125:7,13,18

125:22 126:5

heights 112:6

Hello 4:18

help 36:21 134:19

146:5

helped 79:8

helpful 72:9 73:19

73:19 155:14

helps 126:21

Hi 20:13 64:8 127:8

high 88:1

higher 52:1 92:16

93:6

highlight 29:9

highlighted 39:9

history 3:6 8:3

21:22

holds 44:17

home 2:3,4 6:11,14

152:19

honestly 110:15

hopefully 5:4,10

134:19

hoping 134:17

136:13

hour 66:1 78:21

79:18,19,19 80:8

83:22 84:6,10,22
202-234-4433

Neal R. Gross & Co., Inc.

Page 167

85:6,15 86:3,12

86:19 88:16 103:8

103:14 105:5,20

105:22 106:1,7,9

107:3 113:6

hours 55:18 56:1

58:12 59:15,18,22

60:5 62:9 66:3

78:18,19,19 80:12

81:3 82:9 83:18

83:20 84:2,11

86:7,8,8 89:11

103:11,16 104:17

105:10,15 106:2,5

117:11,12

hour-three 106:1

hour-two 106:1

how's 25:10

HRF-1 22:19

100:19 111:6

114:6 131:3,5

132:2 134:17

135:14,16 136:11

136:17 137:18

HRF-1-2008 23:7

humidity 28:15

30:13,14,21 31:6

31:15

hump 136:7

I

ice 27:13,14,14,16

27:17,21 32:20

39:6,11 42:6 49:7

49:11 51:11,20

52:15 53:3,12,17

54:2,7,22 57:2

60:20 62:19,21

63:2,4,4,7,11

66:14 132:5 133:9

136:7 138:7 148:9

icemaker 34:2 35:3

39:5,14 40:7

60:21 63:18 64:10

64:11,11,17 138:7

icemakers 26:5,8

26:13,17 27:11

36:4 63:16,22

65:3,18 66:10

149:20

icemaking 3:8 8:5

8:8 24:20 25:4,8

25:16 26:1,17

27:9 28:5,8 32:17

32:19,21 35:13

36:18 38:22 39:2

39:8,18,20 40:6

44:8,18 45:12,15

45:21 46:12,19

47:16,19 48:13

49:3 50:6,8,18

51:7,9,18 52:3,6,9

52:22 53:2,8

54:17,19 55:12,22

56:1,3,6,8,10,11

56:13,17,20,22

57:4,16,17,20

58:16,19,21 59:1

59:5,7 60:15 61:5

61:9,21 62:1,6,12

62:21 63:3,6,6,9

63:17 65:11 66:5

66:8,13,19 69:2

69:21 78:11

147:15 148:1

149:13 151:8,11

151:15

idea 132:15 144:18

ideally 131:22

ideas 34:8

identical 23:19

100:18

identification

39:17

identified 43:22

123:20 149:17

identify 39:14

41:19 42:10 43:11

44:10 87:17

identifying 39:2,8

39:20 42:4 77:2

IEC 98:17 121:18

ignores 16:12

illustrate 80:22

illustrated 92:17

92:19 93:9,15

immediately 7:15

16:2

impact 15:3 16:8

19:16,20 34:5

44:21 67:15 73:3

73:8 74:11,13,15

119:8 142:7

144:12 145:19

147:16 148:13

149:9 150:4,9

152:1,16

impacting 20:9

impacts 16:13,16

54:22 69:1 70:4

70:14 145:7

150:19

implement 94:5

implementation

96:12

implemented 94:7

implications 17:6

imply 38:12 118:18

important 8:21

13:17 17:20 57:11

importantly 14:21

impose 145:13

149:22

impossible 14:18

119:7 129:13

improve 17:18

36:20 66:12

152:12,13,13

improvements 20:5

inbox 156:7

inches 112:6,7,7

include 39:9 56:9

61:19 64:16 81:22

96:10 104:10

135:11 137:15

154:7

included 103:14

129:19 130:2,7

132:4 133:6,11

135:19 136:2,10

138:1,4,9

includes 12:1 81:14

including 96:9,12

111:6

inclusion 57:11

incomplete 103:4,6

103:9,20 104:14

104:22

inconsistency 85:1

incorporate 98:21

incorporated 21:1

98:16,17 111:7

incorporating

66:19 94:8 143:6

incorporation 68:8

69:22 132:4

incorrect 53:6

73:14 96:21

increase 45:12 47:4

53:22 54:14 91:3

148:2,15

increased 149:15

increases 152:22

increasing 36:19

incremental 53:16

Independence 1:12

independent

129:11 130:4

independently 79:7

indicate 111:18

indicated 54:1

67:21 84:1

indicates 101:2

indication 96:4

indicative 48:17

49:18

indicator 108:4

individual 83:10

87:14 151:5

individually 64:17

individuals 10:2,10

industry 150:6

influence 73:22

inform 54:12

information 7:12

21:14 31:17,18

53:6 70:10,19

90:5 129:13

143:15 144:9

148:21 157:4,7

inherently 128:22

initial 46:10 47:10

53:1 54:4 145:6

148:5 149:1

initially 51:20

95:19

initiated 56:4 62:13

65:20

inlet 35:18,21 36:9

36:10

innovation 18:16

input 17:8

inside 34:10,17,21

35:1 122:17 136:9

137:20

insight 144:15

installation 32:14

33:2

installed 120:20

instance 33:10

81:15 82:12 148:9

instances 16:11

instructions 62:20

instrumentation

148:8

insulated 135:12

136:6

insulating 136:7

intact 156:14

integral 132:19

138:6 141:7

integrally 137:12

integrating 67:20

intend 72:16 110:8

intended 38:12

72:14 121:18

129:17 134:9

137:4

intent 50:4,14 51:5

72:8 133:4

intention 51:3

96:10

interested 21:3

80:9 141:18

142:19 146:2
202-234-4433

Neal R. Gross & Co., Inc.

Page 168

interestingly

156:14

interior 128:21

interpolate 99:10

interpolation 92:8

92:12 93:18 97:13

interpolations

92:16 96:1

interpretation 33:7

33:16 93:8 134:16

138:5

interpretations

134:22

interpreted 109:12

127:18

interpreting

153:10

interrupt 80:1

interrupted 56:2

intersect 94:3

Introducing 19:2

Introduction 3:5

10:19

introductions 3:4

5:21 11:14

Intros 4:17

investigating

142:18 152:2

investigation 142:3

invite 12:3

invoke 86:3

involve 63:1

involved 67:19

147:10

involves 36:18 44:6

69:17 93:9

involving 78:18,19

issue 22:5 26:10

32:10 40:9 43:20

53:12 55:6 105:2

106:21 127:20

138:13 142:3,18

issued 15:15

131:14

issues 3:10 7:20,20

17:9,11 59:9

67:22 75:12 81:1

105:4 110:18

113:21 140:16,20

146:17 147:8,10

155:1 156:18

item 24:21 29:16

49:1 74:10 117:1

118:19 121:9

122:12 124:10

125:4 127:11

128:6,7 130:11,18

130:20 138:21

140:2 145:12

146:8

items 5:8 10:21

12:4,7 22:5,9

24:17 72:2 74:12

114:1,3 122:6

124:4 126:7

130:20 137:22

139:11 140:16

151:5 155:17

157:20

iteration 46:16

J

J 55:6,8

January 15:19 19:1

Jean 7:5 25:1,6

JEAN-LOUIS 1:17

7:5 25:5,13 26:22

27:7 28:4 32:12

35:11 36:12 38:18

40:14 41:1,12,17

42:1 44:5 51:16

55:11 61:15 62:18

63:15 65:10 68:21

70:22 71:6

Jennifer 2:1 6:18

20:12,13 64:7,8

66:16,17 143:3,4

jibe 32:16

job 8:18

join 9:11

joining 9:18

July 1:8 4:11 12:18

12:18 18:3

jumping 114:2

K

keep 9:7,14 48:2

60:6 74:3 85:21

97:20 98:5 156:9

key 25:14 89:17

Kido 1:16 6:21,21

67:11,11

kilowatt 66:1,3

kind 21:4 42:22

44:19 60:1 64:18

68:13 73:8 74:22

79:5 107:14

126:10 136:16

137:17 144:22

152:19

knob 109:21

knobs 45:18

know 10:11 11:12

11:17 12:2 21:6

21:11 30:7 31:4

31:13 32:3 34:15

35:7 40:20 41:10

41:20,21 42:19,22

51:12 60:1 64:19

70:9 73:9,13,15

74:10 77:20 79:18

80:9,22 81:7 86:7

86:20 87:13,15

88:2 91:5 106:20

107:12 108:8

109:8,14 110:15

126:16,21 128:1

133:1,17,19

134:20 136:15,19

153:7 157:21

knowing 134:22

146:2

known 27:16 74:13

Krause 2:2 6:8,8

33:4,5 34:8

L

lab 40:19 41:21

91:6 105:10

109:19,21 153:13

153:14,20

labeling 15:20

laboratories 119:9

laboratory 2:6 7:8

37:13,19 69:7

153:8,9

laboratory's 42:16

labs 47:3 105:8

106:19 109:17,19

110:20 115:14

laid 39:19

language 50:22

72:20 100:14,15

101:2,14,18

102:20 109:10,11

111:21 121:17

123:21 124:6

131:3,5,8,11,21

132:2 133:16

136:17 137:3

large 18:14 49:6,11

49:20 70:1 145:11

Lastly 27:20 36:5

45:20 56:15

late 7:11 16:3

Laughter 97:9

launch 7:22 15:16

15:22 18:22 72:1

law 17:2

Lawrence 2:6 7:7

lays 22:10

lead 84:3 102:14

leads 143:11

lead-in 17:1

learn 21:4 72:10

learned 128:9

leave 5:10 27:2

left 75:2 92:19

lengthy 116:3

let's 21:19 27:6

46:5 71:4,8,20

100:11 137:9

152:22

level 12:13 28:16

43:8

levels 31:15,22 42:4

42:8,9

Leybourn 2:3 6:13

6:13

light 64:9

likes 79:17

Likewise 34:20

Limit 9:8

limitation 84:6

limitations 21:4

limited 54:10 70:8

133:2,18

limits 45:5 52:13

line 18:18 20:16,17

22:11 45:18 57:15

92:22 98:1

linear 97:13 110:2

lines 32:19 38:10

68:22

linger 11:18

links 157:4

list 9:21 24:17

25:14 76:9

listed 8:15

listening 10:12

74:21

lists 76:2

literature 36:4 38:8

little 8:17 30:7

43:16 52:7 60:4

114:18 121:11,14

128:9 131:3 132:7

137:4 145:19

153:16

loaded 47:21 48:7

48:15 52:12 114:8

location 34:9

122:21

locations 123:3

139:17

logic 124:1

long 15:21 58:3

67:6 81:17 82:9

86:11,12 88:12

89:14 96:17

103:16

longer 68:14 86:2

105:5

long-time 104:4

look 18:8 20:3 22:6

41:15 44:9 76:9
202-234-4433

Neal R. Gross & Co., Inc.

Page 169

126:6 144:9

lookback 65:20

looked 44:22

137:19 143:18

looking 25:19

39:13 42:3,22

43:10 52:10 57:15

57:18,19 86:18

106:4 134:4

looks 42:5 70:12

lot 20:10 33:15

72:12,14 131:6

145:16 154:4

155:7 157:12

loudly 25:12 37:10

41:5

Louis 7:6 25:2,7

love 115:8

low 31:22 88:2

lower 52:18

Lucas 1:16 4:16,19

7:1 21:20 25:6

33:18,19 69:14,15

71:21 74:3,4 87:2

87:3 107:9,10

109:2 113:20

115:12 155:8

luck 85:15

lunch 8:11 147:4

M

machine 38:1

magnitude 90:10

mail 156:9

maintain 20:17

37:22

maintained 111:15

major 148:4,12

making 39:9 48:2

51:11 60:20 66:20

115:7 116:14

124:14 139:9

140:10

manager 4:21

mandating 49:16

manner 72:16

manual 25:22

58:10 91:17

manufacturer

97:14 99:3,16

100:2 150:14

153:9,14,20

manufacturers 2:3

2:4 6:12,15 14:10

14:12,18 15:4,16

15:21 16:15 17:4

20:19 21:6 29:17

30:19 31:12,17

38:12 47:2 68:1

74:20 80:17,20

95:4 101:19 102:3

106:22 117:20

128:10 139:3

148:22

manufactures

149:18

MARCHETTI

1:18 9:20 10:3

Mark 10:4

market 146:3

marketplace

106:18

marks 109:21

mass 35:4 48:8

52:12 57:7,12,18

62:19,21 63:4,5

63:11 148:9

mathematically

86:13

matter 7:20 14:2

71:18 99:19

maximum 45:2

78:1,1 117:7

McARVER 2:4

6:10,10 13:8,8

29:1,5,5 30:1

53:10,10 118:21

151:19,19

mean 34:4 97:13

110:1 133:7

135:21 136:19

152:21

meaning 107:22

means 33:17 73:21

113:9 136:19

meant 48:17 127:4

134:18 135:2

measure 37:19,19

54:16 59:6 69:21

127:21 128:10

129:1 148:9

measured 15:3

16:9 19:16,21

20:9 61:22 67:15

67:16 68:7 70:13

73:3 75:20 90:2

92:13 128:2 135:9

135:10 142:8

144:12,13 147:11

151:3,16 152:1,16

153:1,15,18

measurement

36:22 63:17 65:11

65:17 69:4,7 73:9

91:3,4,12 93:11

93:13,14 104:6,8

104:20 128:6,16

130:5 131:2 134:7

145:15,20 151:6

154:7

measurements

39:10,11 69:1

74:12 90:10 93:15

102:15 129:22

measuring 39:7,12

53:16 63:2,11

64:17 111:13

128:18

mechanical 45:17

107:21 108:1

mechanism 66:22

mechanisms 64:20

meet 18:18 19:17

143:14

meeting 1:6,11 4:6

9:2 11:2,15,19

12:18 14:11,20

16:18 17:8,12

20:1 88:7 155:4

155:19,20 158:4

meetings 9:13

member 18:6 135:1

members 119:4

152:3

mention 24:3 74:18

119:2

mentioned 22:1

38:7 60:14 74:6

77:10 97:7 131:17

132:15 142:16

mentions 38:8

merit 18:7

met 83:22

metering 75:13

method 59:16 60:2

63:1 90:18 92:2

94:21 95:8 96:5

99:11 129:4 134:7

methodical 90:22

methods 39:19,22

40:5 43:21 44:1

Michael 1:16 6:21

10:5 67:11

Michael's 69:16

microphone 9:4

29:4

microphones 5:22

mid-morning 8:6

mind 134:2 156:10

minimal 151:9,17

minimis 16:7

minimize 21:10

minimum 62:8

77:16,17,18,21

86:7,7,8 117:1,6

117:16

mini-dips 77:20

minus 37:20

minute 36:15 37:3

37:6 71:9 78:10

155:13

minutes 7:11 36:17

misunderstanding

50:4

misunderstood

135:2

Mizanur 10:5

mode 9:8 147:12

154:8,18

model 20:10 95:7

95:11

models 16:13 29:12

modes 154:10,14

154:16

modest 148:10

modification 102:9

104:16 149:7

modifications

22:22 25:8,10,15

33:2 101:10,13

102:16 154:9

modified 101:17

modifies 102:6

modify 32:13

100:15

modifying 64:3

mold 27:14 39:6,11

42:6

moment 36:7

monitoring 42:17

75:16

month 157:11

months 18:16 19:2

morning 4:4 7:13

13:9 17:15

mounted 127:17

Mouw 2:5 6:4,4

17:15,16 132:13

132:13 134:3

135:5 144:8 152:7

move 5:18 24:15,19

38:21 44:6 91:21

100:12 103:3

140:3 144:15

146:13

moves 108:11

moving 78:14

100:13 111:4

144:17

multiple 33:13

63:16,22 75:7,8

76:11 77:1,4

79:12 80:3,15

83:10,17 85:11

86:17,22 87:7,12
202-234-4433

Neal R. Gross & Co., Inc.

Page 170

90:6 91:15

mute 9:15 127:7

N

N 3:1

name 4:13 6:1 9:5

names 9:21 10:1

Nathan 2:5 6:4

17:14,16 132:12

132:13 134:1

135:4,5 144:7,8

152:6,7

national 2:6 7:8

54:6

nature 147:20

Navigant 1:17,17

7:4,6 25:7 30:6

38:5 43:7 50:2

navigate 19:5

near 16:14

nearing 15:6

nearly 15:7 100:18

necessarily 86:14

114:2 118:17

122:16 126:17

133:18 140:18

156:13

necessary 59:19

66:21 99:17 123:2

123:14

NEEA 52:2

need 11:12,18

13:22 19:4 23:16

50:21 60:11,12

61:3,8 68:1 73:9

73:11 79:14,15

85:4 101:3 102:4

105:19 106:13

120:13 125:22

126:19 127:1,13

136:20 157:7,16

157:19

needed 102:17

needs 84:14 106:16

neither 81:17

Nestor 10:5

network 120:21

never 88:5,6

Nevertheless 75:11

new 15:9 18:19,22

19:17,22 23:6,9

67:4 97:6 98:14

98:17 119:19

131:8 148:1

Nice 4:14

NIST 53:14 98:19

non-automatic

55:16

non-linear 110:3

non-public 139:22

non-representative

101:4 102:14

Nope 130:15

NOPR 134:4

135:18

normal 82:7

Northwest 52:19

note 30:19 53:22

79:4 96:20 105:3

127:12

notes 40:10 107:2

notice 5:6 12:14,17

14:10,19 15:12

17:12 64:1 66:11

69:20 70:3 72:13

83:13 84:1 89:8

150:9 157:15

notices 147:9

noting 144:5

nuances 137:3

number 12:1,3

19:3 22:2 46:20

56:9 57:16 63:3,5

105:12 106:20

114:21 141:4

147:9 149:9 150:4

numbers 108:6

O

observations

140:22

observed 50:6

118:3,5 145:3

obtain 64:13 102:1

obviously 31:1

127:21 128:20

141:9 146:9

occupied 134:8

occupy 134:10

occurred 22:21

occurring 11:15

occurs 52:22 88:11

offer 107:14 156:15

offered 157:3

offhand 133:19

Office 6:22

offload 154:4

oh 11:7 26:22 39:3

48:22 155:10

okay 10:8 13:3

21:16,19 25:13

27:6,7 28:4 30:3,3

30:16 32:2,9,11

35:9 36:11 38:17

38:18,21 42:11

43:4,15 44:3,3

48:19,21 49:21

50:11 51:1,14,15

55:5,10 62:17

63:14 66:7 68:20

70:21 71:7,20

73:18 74:2,22

75:4 81:12 82:4

84:17 87:1 88:13

97:3 100:11,11

103:2 108:9,10

110:6 112:14

115:18 116:16,21

119:13,16 121:5

122:11 128:3

138:10,19 146:15

149:4 151:1 152:5

154:2,21 155:6

once 36:15 37:3,6

47:16,18 48:13

70:13 78:10 80:1

onerous 129:2

one-time 150:12

ongoing 120:22

online 27:6 119:20

127:6

opening 3:4 4:17

10:16 13:4 18:12

22:10

operate 87:8

101:15

operated 118:12

operating 42:3

85:18 117:13

118:10

operation 27:13

28:17,21 32:17

34:2 36:18 52:11

53:8 80:6 82:8

83:11 85:5 87:20

88:21 89:1,10

102:8 104:10

113:1,9,9 120:12

operations 52:9

56:4

opinion 108:21

opportunity 7:18

12:22 13:11 17:7

18:1 154:21

156:15

optimum 97:15

option 50:17 99:4

optional 91:22 94:7

order 46:7 54:16

59:5 66:12 77:19

101:22 107:6

organizational 6:2

ought 9:16

outset 7:20 13:6

17:14 72:5

outside 34:16

overall 24:17 25:18

65:17 91:10

overlap 58:13

60:12

overview 7:17

o'clock 8:17

P

package 115:18

packages 114:8,9

114:21 115:19,21

116:2,8

packet 7:12 8:2

155:12

page 134:5 155:12

paragraphs 139:6

parallel 23:20

part 13:17 23:7

25:2 26:10 49:4

49:12 50:9 51:11

55:17 58:8,15,17

58:21 60:9,10

61:6,7 70:1 74:6

81:16 82:13,19,20

83:7 84:9,13,19

85:3 88:15,18

89:6,12,15,17

92:4 94:17 106:13

109:3 118:7

121:10,17 128:13

128:17 130:8

131:2 133:8 136:8

136:9 139:1

140:21 145:11

146:9 155:7 156:1

156:2

participants 9:10

37:8 77:7

participate 157:13

participating 5:14

10:12

participation 5:2

5:15 157:10

particular 12:6

29:8 61:17 67:13

68:8 95:6 119:6

122:7 142:21

particularly 43:20

114:3 143:7

parties 13:21

parts 44:8 45:6

72:15

party 49:10 96:13

119:9

pass 99:18,22

Patrick 10:6 37:8,9

37:13 40:19 41:3

42:12

pattern 80:5
202-234-4433

Neal R. Gross & Co., Inc.

Page 171

Paul 10:6 127:6,6,8

people 136:1

people's 136:18

percent 30:21 31:5

31:16 44:21 54:15

54:20 95:21 96:3

116:9 130:2

148:15 150:11

153:1

perfectly 129:9

perform 141:20

performance 14:13

141:1 143:12

performed 90:17

120:10

period 17:1 49:7

55:22 56:3,9,19

57:3,5,10,14,15

57:19,21 58:1,2,4

58:8,9,11,14 59:5

59:21 60:4 62:2,7

62:8,22 63:7,8

78:16,21 79:19,19

79:20 80:8,11

81:14 82:5,9,19

83:1,4,16 84:2,11

84:14 85:4 86:2

86:11 88:12,17,20

88:21,22 89:5,9

91:8,9 103:8,17

104:9,16,19 106:4

113:8,9 156:5

periods 56:21 57:8

58:21 59:4 76:18

77:12 86:9,10,12

103:5,14 104:5

147:20

permit 83:10

permitted 15:19

personally 109:8

perspective 44:2

petitions 102:5

phase 15:6 88:4

phone 37:9

phones 9:8

physical 109:1,20

128:16,17 141:22

156:11

physically 156:14

pick 41:16 42:20

43:2,3 75:2

picture 88:2

piece 27:16 99:14

place 79:9 88:10

97:12 126:4

placed 116:12

153:11

placeholder 52:3

66:1

placement 122:13

123:6 153:6

places 14:17 22:2

73:1 157:6

placing 39:10

plan 19:11

plane 93:17,19 94:4

121:22 122:2

planned 113:19

planning 15:22

plans 106:21

platforms 19:17

20:1

please 6:1 7:2 9:3,4

13:7 29:3 37:16

71:21 157:20

plot 92:19,21

plus 37:20

point 12:8 27:22

28:18 42:16 46:14

61:11 68:4 88:6,6

98:6 99:5,8,11,22

114:18 116:11

135:8,17 145:8

147:2 151:20

pointed 142:4,9

points 12:4 39:1

89:17 93:1,20

99:9,10,18 122:4

Policy 16:6

Polinski 10:3

portion 18:14 25:8

28:6,8 46:20 53:2

55:17 110:4

position 68:3 69:19

122:18

possibilities 21:5

possibility 70:7

possible 46:16

80:17 81:20 91:15

123:9,15

possibly 19:22

potential 32:5 33:8

68:5 74:11 77:20

81:8 84:3 102:19

121:19 141:19

145:6 148:22

potentially 38:11

66:20 67:9 103:13

132:9 137:2

141:16

pound 66:14

pounds 52:17 54:1

54:4,8

pour 115:21

Powell 10:6 37:8,12

37:13,17 38:14

40:19 41:7,14,20

42:11,15 43:13

power 42:2,3,8,9

PowerPoint 8:2

practical 128:18

practice 129:8

pre 134:4

precedence 123:1

preceding 26:21

138:15

precludes 70:7

precursor 138:12

preferred 98:13

preliminary 10:14

148:20 150:19

151:14

prepare 14:19

preparing 14:12

present 1:14,21

10:2 11:20 24:1

74:21

presentation 8:2

12:5,9 22:3

presented 144:10

presiding 1:13

pressure 36:2,10

37:15 38:9

pretty 5:3 11:1

27:15 110:22

135:9,16

prevent 28:9

101:19

previous 37:14

69:16 77:18 92:3

100:17 106:9

128:6 131:5

previously 85:2

110:16 132:6

pre-cooling 113:12

primarily 76:21

149:12 151:8

primary 83:2,6,8

84:12

prior 56:5 113:5

126:8

probably 8:15 24:5

67:21 72:4,9

80:16 81:3 86:17

109:13 110:10

144:21 145:8,19

156:7

problems 68:5

procedure 3:7,8,9

8:4,5,8,10,12

12:12 16:9 17:19

19:9,19,20 22:14

22:17,18,20 23:6

23:8,15 24:5,16

24:21 25:4,16

26:1,18 27:9,11

28:5,11 36:16

46:11,15 47:2,7

47:13 53:16 59:13

61:16 64:4,22

65:16,21 66:10

67:13,19 68:9,16

69:2 71:1 72:15

75:3,6,8,9,12,19

75:22 76:21 78:11

78:22 79:17 89:6

90:3,9 91:22 92:1

92:3 93:7 94:9,18

97:12 100:17

101:3 103:7 104:1

105:3,9 108:21

109:4 111:21

113:14 114:6,7,11

115:4 116:3 117:4

117:16 120:3,7

121:10,18 123:4

123:21 124:19,22

125:12 128:8

140:19 146:7,19

147:9,18 148:1

150:3 151:7,8,11

151:15 152:10,22

procedures 1:3 4:8

11:21 13:13,17

14:1,5 15:1,10,18

16:17 21:2,9,12

22:12 26:7 32:15

61:21 66:6,20

76:4 79:20 94:6

111:6,20 112:18

112:20 116:4

130:7,9 149:8

152:21 154:6,11

154:12 156:20

157:5

proceed 11:14

12:15 13:2,4

21:19 27:6 73:22

145:10

process 93:6 120:6

129:18 144:17

156:11

produce 15:10

produced 63:2,7

producing 57:2

product 4:21 16:2

31:14 36:4 38:8

49:19 51:6 59:15

60:19 75:17 76:11

81:21 85:11,13,16

86:15,20,22 87:14

95:6 96:6 101:21

105:5 107:1 109:7

118:9 121:7,20

124:13,22 125:1,5
202-234-4433

Neal R. Gross & Co., Inc.

Page 172

125:7,13,14 126:5

126:9 128:7

130:18,19 139:13

140:1 141:1,4

148:17,18

production 51:18

51:20 52:16 53:12

54:3,8,22

products 1:3 3:6

4:8,22 8:3 15:5,9

15:17,22 16:16

19:1 20:20 21:13

21:15,22 22:15

23:13 24:4,7

25:22 26:8,13,16

26:19 30:9 31:4

31:10 45:20 49:6

54:21 56:7,10,21

58:10,18 63:15,22

64:5 66:9,15

67:17 70:11 72:17

75:8 77:2 80:16

81:16 82:6 86:17

87:7,10,12 90:6

91:15,16,18 92:8

92:12 103:6,9,10

103:20 104:3,9,17

106:18 107:8

117:3,13 118:4,8

119:7,18,19 120:8

124:12 125:15,20

128:19,20 141:2,5

141:9,19 142:4,21

143:7 145:16

146:4 149:15,19

153:19 154:7

156:20 157:5

product's 118:1

143:12,14

program 1:3 4:7,20

120:2 129:20

progress 71:8

progression 12:11

prompted 133:15

133:21

promulgate 14:4

promulgated 16:22

properly 129:4

proportion 146:2

proposal 5:7 11:20

12:14,16 18:2

25:3 26:11 29:19

30:8 32:13 35:12

36:8,13 38:6,22

39:1,1 40:15 44:6

44:13 45:2 50:9

54:14 55:3,12,14

58:7,13,20 61:19

62:12 72:8 75:18

77:10 78:2,5,10

78:12 79:1 81:13

81:22 82:1,15,22

83:9,19 84:9,13

85:7 88:16 89:2

90:3 94:19 96:8

100:18 101:9

103:15,19 108:18

109:3 111:2 112:3

119:6 121:16

122:8 130:8

132:22 142:17

148:13 151:22,22

proposals 5:5 96:8

96:9 104:7 112:10

propose 14:4

133:15,21 152:3

proposed 5:11

12:14 13:11 14:8

16:17 18:5,8

19:15 33:1 36:6

43:21,22 45:5

46:15 53:21 64:4

66:11 69:2,6,20

72:13 75:6 78:9

90:9 91:22 94:22

104:14 111:21

121:2 124:8

129:16 131:20

140:19 147:15,17

149:7 150:2 151:7

154:12 157:18

proposes 16:10

51:19 54:3 76:10

76:18 78:15 82:20

84:6,18 92:5 94:5

95:15 100:14

103:4,21 107:21

108:15 111:12

112:15,22 120:18

proposing 16:3

25:9,15,20 27:8

28:6 32:18 35:13

35:17,18 36:14

52:5 56:20 62:19

63:16 80:11 122:5

125:6 139:10

151:10

protections 17:3

provide 5:4 17:8,9

18:9 55:3 59:6

62:19 72:14

102:20 114:18

119:10,21 132:7

133:4 152:3

provided 21:14

81:20 143:16

148:5,16 150:8

providing 148:4

provision 29:8

120:14 121:2

provisions 100:19

142:12,14

prudent 114:18

psig 35:20 37:20

public 1:6,11,15

4:6,14 12:18

14:11,20 17:8

139:12 140:10

155:20 156:3

publication 157:15

publicly 139:7

published 12:17

22:15 23:5

pull 31:21

purchases 65:2

purpose 11:19

100:2 120:16,19

131:1

purposes 95:3,17

120:11 124:21

129:9 130:10

pursue 146:7

push 138:14 147:3

put 17:4 19:22

20:19 27:1 34:15

35:2 61:4,10 80:8

116:9

puts 135:18

putting 35:1 116:7

P-R-O-C-E-E-D-...

4:1

p.m 158:3

Q

question 33:5,20,21

38:11 41:6,8,18

43:5,12 69:18

87:4 90:14,16

109:15 126:4,22

132:15,20 135:3

137:9

questions 5:6 12:8

16:5 24:13 33:15

68:18 114:16

125:2,22 130:11

130:21 131:10

140:2,13,21

141:17 156:17

quick 29:2,6 45:21

49:2,5,15,16 50:3

50:4,7,13,15,17

50:17 51:7 69:16

87:4

quickly 38:19 74:5

quite 24:19 31:3,19

58:3 67:6 80:18

97:12 131:4

141:13 156:12

R

raise 9:15 141:16

155:2

raised 17:11 18:12

75:9 156:18

raising 140:17,20

ran 79:6 90:16

98:13 99:5,20

106:10

random 28:9 32:7

range 16:13 36:2

47:18 80:19 102:6

121:19

ranges 38:9

rate 36:13,14 37:6

38:19 51:18,20

52:16,18 53:12

54:3,8,22 78:9

84:21

rated 54:20

read 10:1 41:2

50:12,16 76:4

84:22 134:3 135:6

137:17 147:8

reading 135:16,17

ready 15:7 24:19

real 18:10 19:4

31:18 107:13

152:16 153:15

realistic 54:2

realistically 144:21

realize 116:5

really 39:18 48:5

49:4,17 57:10

60:20 61:3 70:1

70:14 72:13,15

79:11,17,20 83:14

86:11,11 106:4,5

106:8 108:13

110:16 122:16

124:5 127:3 133:4

135:22 145:5

148:12 153:13

156:19

rear 121:21,22

122:2 127:11,18

rearranged 100:20

reason 10:9 74:6,16

83:15 118:10

reasonable 87:11

reasonably 127:18

reasons 48:11

recall 30:6 126:9

receive 12:20 144:6

145:12

received 7:12 13:1

114:16 130:21
202-234-4433

Neal R. Gross & Co., Inc.

Page 173

140:22 155:11

receiving 142:19

recognize 13:15

20:15 132:17

144:11

recognized 79:7

120:7 121:13

recognizes 102:12

105:2 129:7

recommendations

53:15

recommended

20:18

record 9:5,21 10:2

40:12 71:18 156:3

recorded 114:22

155:20

recording 37:2

42:17

recovery 113:12

red 57:3

redesign 18:17

redesigned 20:1

reduce 27:18 60:4

89:11 115:20

reduction 81:8

84:10

reengineer 15:9

reevaluate 33:12

refer 27:3

reference 33:6

79:18 94:8 96:21

97:19 99:6 111:8

114:7

references 124:8

refers 124:15

refine 150:17

reflect 21:13

118:11 125:11

129:11 141:14

reflected 29:19

65:4 143:13

reflecting 126:19

reflects 109:4

111:2

refrigerated

122:17 124:15

133:10 136:10

137:10,20 138:8

refrigeration 4:22

54:21 58:18 66:14

113:10 124:12

149:15

refrigerator 15:1

18:17 26:12 34:17

34:18 35:1 38:10

48:9 52:12 65:2

97:17 98:11 125:9

141:11

refrigerators 1:3

4:9 11:22,22

23:20 24:11 25:22

26:3,4,12 28:21

33:14 67:5 101:6

139:2

refrigerators-fre...

4:9

refrigerator-free...

13:12 57:1 97:20

refrigerator-free...

1:4 24:12 80:4

101:7

regard 38:19

112:10

regarding 13:21

14:7 16:8 18:13

35:12 36:13 46:5

47:6 51:17 54:13

58:16 59:9 61:16

62:20 69:12,20

72:7 91:7,14

104:19 117:1

125:5 127:10

130:18,22 138:21

141:18 148:21

150:19 153:5

regards 34:12,19

38:22 39:16 40:15

81:1

Register 18:3

registered 7:13

regs 126:18

regular 49:14

regulated 13:21

regulations 24:9

127:1

regulatory 3:6 7:17

8:3 21:22 22:11

149:5

reiterate 85:10

86:16 151:20

rejected 142:6

rejection 144:11

related 156:19

relationship 122:13

relative 30:13,14

30:21 31:5

relatively 12:12

114:14 119:20

123:18 137:1

145:5 155:22

157:14

release 134:5

released 14:10 18:2

19:19

relocated 123:8

relocation 111:19

122:11

rely 54:3

remain 139:21

remaining 76:5

remarks 3:4,13

4:16,17 10:16

13:5 155:1,9,15

reminder 22:7

removable 136:9

remove 34:13,22

127:2

removed 134:9

removing 27:13

repeat 87:16

repeatability 17:22

119:8 152:13

repeatable 53:18

repeating 87:19

report 95:5,11

117:21 125:7,22

126:5 139:4

reported 30:13

reporting 96:13

125:9 126:11

reports 14:13,15

117:20 125:8

repositioned

123:13

represent 51:12

53:19 96:6 117:6

148:15 152:19

representative 54:7

54:11 102:2,7

118:17

representativeness

13:16

represented 98:20

representing 93:1

represents 54:20

reproducibility

17:22 152:14

153:3,18

reproducible 53:18

request 18:6 32:4

33:1 36:7 80:21

115:1

requested 102:3

requesting 22:4,8

26:2,6 27:22

28:19 37:5 39:17

39:19 40:2 45:4

52:15 53:4 58:6

58:12,20 61:18,18

62:7 63:10,19,21

66:7 68:22 69:5

89:16

requests 76:13 78:2

78:11,22 81:22

82:14 84:7 85:6

90:5,8 91:17 96:7

101:8 104:13

108:18 112:9

113:15 150:18

151:13

require 28:6,14

32:15 33:12 35:20

44:14 45:7 59:3

61:21 62:12 78:16

82:22 88:16 104:5

114:20 142:17

151:10

required 17:2 23:8

65:12 75:13 78:9

95:5 147:21

requirement 35:15

39:21 43:21 44:17

45:14 60:19 61:4

61:20 67:4 69:21

78:17 83:12,22

113:6 114:5 125:6

126:15 154:16

requirements 3:12

16:19 18:19,19

32:13 95:2 104:20

111:8,13 113:4

115:3 123:10

125:10 129:17

139:2 146:18,22

147:7 149:21,22

requires 46:16

112:3 117:19

120:10 154:5

requiring 65:11

research 31:9 44:9

53:14 150:7,11

reservoirs 132:18

residential 11:21

154:7

resolution 36:20

resolve 37:2

resolved 83:17

resources 14:17

18:15

respect 58:17 62:18

68:15

respects 22:22

114:13

respond 13:20

74:21

response 32:10

33:21 62:15 63:12

65:8 68:19 76:14

78:6,13 81:11

82:2,16 84:15

89:21 91:13,19

101:11 102:22

112:12 113:16

116:20 119:15,22
202-234-4433

Neal R. Gross & Co., Inc.

Page 174

121:3 122:9

123:17 125:3

130:13 138:17

140:14 146:14

149:3 150:21

154:1,19 155:5

restrooms 71:11

result 18:5 44:13

45:4 94:1 102:1

145:13 149:8

results 15:10 35:5

84:4 95:19 107:5

resume 71:14

resumed 71:19

retained 52:18

review 3:4 4:17

7:15,16 12:22

13:20 14:19 38:7

50:21 67:4 68:12

80:22 135:15

149:6

reviewed 150:6

reviewing 55:3

77:3

revised 36:6 46:10

47:6 55:14 59:13

revisions 11:20

101:5 102:19

right 14:11 19:3

25:3,14 28:3

35:10 41:12 42:11

44:4 55:9 61:14

61:15 63:13 65:9

68:20 71:5,14

91:20 92:21 97:22

98:6 113:22

116:22 121:6

128:4 136:22

137:13 138:20

140:15 146:11,16

155:16

rigorous 156:10

rise 44:15 45:2

104:11

risk 20:1

Rob 6:10 13:7,8

17:13 28:22 29:3

29:5 53:9,10

118:20 151:18,19

152:8

ROBERT 2:4

room 1:11 6:3 9:17

10:10 11:1

rooms 31:21

round 151:12

rule 10:21 12:15

13:2 14:8 15:15

22:3,13,16 23:4,5

23:21,22 24:7

33:16 65:20 73:12

125:12

rulemaking 12:11

12:15 16:11,21

23:15 69:20 75:10

92:3,5,6 100:17

104:1 121:11

128:9 156:2,7,18

157:6

rules 11:2 22:21

run 10:15 46:17,19

47:3 50:18 99:3,9

99:10,19,21 106:2

106:3,5 117:2,9

running 60:6 98:15

99:4

runs 102:9

Ryan 10:6

S

Safe 158:1

Salazar 10:6

sample 145:4,18

sampling 139:1

satisfied 98:14

satisfy 83:11

save 13:15

saw 29:7

saying 42:19 48:5

110:5

says 105:9 135:9,10

136:11

scale 148:9

scenario 15:14

schedule 85:18

scheduled 14:11

schedules 144:18

scope 24:3 27:18

SCOTT 2:6

screen 157:1

screening 156:11

search 88:9

second 22:16 29:16

64:11 88:14,18

89:6,15,17

Secondly 47:5

52:21 58:16 60:14

106:15

seconds 155:13

section 24:9 29:22

55:15 71:1 101:7

113:7 124:13

125:10 135:14

136:11 138:22

139:11,22

sections 13:22

101:6

see 4:15 8:18 14:4

20:21 40:10 46:11

57:22 64:21 71:16

79:10 80:10 82:3

85:19 87:19,20,21

105:16 126:11

144:3 145:17

seeing 126:9

seeking 26:10

43:19 52:16 62:11

66:11

seeks 102:18

148:19

seemingly 19:21

seen 12:17 80:18

105:7,10 115:14

126:12

segments 83:10,17

seldomly 49:12

select 33:15

selection 92:14

sensing 101:19

sensor 139:17

sensors 111:19

112:5

sentence 137:16

separate 75:13

109:19 139:5

September 12:21

15:12 125:16

156:5

set 45:8 100:9

108:22 114:10

sets 117:16

setting 40:16 45:9

45:13 46:21

108:14,17

settings 44:7 48:4

49:14 52:5 107:21

108:1

seven 59:15,18,22

severe 17:5

shape 27:19

share 9:6

shelves 122:15,16

123:1,12,13

shelving 122:12

shielding 111:18

shifts 50:7

shop 71:13

short 16:19 157:14

shortcut 60:2

shorter 83:20

117:13 118:15

shortest 117:8,9

shortly 56:5 62:13

155:22

show 16:16 44:20

60:8 86:13 99:18

99:22 106:6,11

showed 106:12

showing 59:17

shown 23:13 156:6

156:22

shows 24:17

side 89:10 135:1,1

sidebar 9:9

sides 112:5

significant 14:5,22

16:4,16 19:3 73:2

74:11,14 84:5

147:16 149:8

150:3

significantly 15:2

72:16

silent 9:8

similar 68:22 78:10

78:17 143:20

simple 12:12

simpler 136:14

simplifications

81:14 82:5

simplify 136:1

simply 15:8 16:3

54:9 72:20 80:12

sine 88:3,3

single 57:14,19

58:2 75:16 81:16

84:14 85:12 86:19

87:6,9 99:5,8,22

100:4 103:17

105:14

situations 16:12

102:21

six 19:2 117:11,17

six-year 65:20 67:3

slide 22:10 24:16

26:21 27:2 37:14

41:8 43:18 76:2

96:20 123:19

130:16 135:8,10

138:20 144:10

slides 10:16 76:5

slight 55:13 91:2,4

slightly 100:20

142:5

small 19:21 49:7

142:2 145:5

147:19 149:9,14

149:17 150:5,13

150:20

sold 26:3,5 66:9

149:19

solenoid 39:13

Solutions 1:15 4:14

somewhat 109:11

131:8

soon 16:1 119:20

sooner 107:18
202-234-4433

Neal R. Gross & Co., Inc.

Page 175

sorry 10:4 11:5,8

22:3 29:5 48:22

74:5 118:22 127:9

sort 68:14

sounds 87:5

so-called 83:14

space 122:17

133:10 134:10

136:10 137:11,15

137:20 138:8

spaced 123:15

spaces 135:11

spacing 116:10

123:11

speak 9:2,6,16

25:12 37:10 39:3

41:4

speaking 23:14

72:12

specific 5:7 12:6

17:11 22:4,9

24:15 27:19 34:5

49:5 73:10 114:10

119:2 130:6

132:11 134:13

135:16 139:18

142:17 143:10

144:22

specifically 4:8

24:9 25:21,21

27:12 114:20

120:8 122:1

131:22,22 133:2

134:21 136:11

137:8 141:6

specifications

117:5

specificity 114:19

121:12,14 136:21

specified 33:7 38:5

64:1 123:3,5

specifies 108:21

139:3

specify 30:12

107:22 110:12

111:1 122:6,19

139:11 142:12

specifying 72:20

133:15

speeds 102:10

spinach 114:8,9

116:8

Spinal 108:6

spirit 20:22 21:7

stability 46:12

56:15 59:14 60:3

61:5,6,10,17,20

79:11,11 80:13

85:11,12 86:5,13

86:18 87:6,13

88:8 105:19

106:12 113:5

stabilization 57:17

58:14 60:13 78:16

80:11 81:2 84:19

stabilizing 58:1

stable 59:18 60:8

60:10 83:11 85:4

85:17,20,22 86:15

88:21 89:1,10

104:10 106:6

113:1,8,9

stage 113:19 145:6

stakeholder 13:5

100:16 101:9

Stakeholders 148:7

stand 7:2 55:8

standard 16:19,22

19:18 20:2 66:21

67:3,4 69:8 70:1

94:9,14,16 96:19

98:17,19,22 99:2

99:12 142:11

143:15 155:18

standardized 44:12

93:3 94:3,11

standards 4:20

15:13 23:10 65:14

65:19,22 66:2

68:13 111:7

125:17,21 141:5

141:14 151:12

156:20 157:4

standby 154:4,8,14

154:16,18

standpoint 138:2

stand-by 147:11

start 4:15 5:21

21:20 46:6 47:19

48:13 56:5 62:13

71:15,20 84:5

89:4 91:7 107:3,3

started 110:18

starting 7:11 19:1

starts 39:15 77:5

state 51:2

stated 47:10 54:13

54:18

statement 18:12

41:8 90:14 135:7

statements 22:10

144:22 155:1

static 38:13

step 118:21

steps 12:10,13

Steve 2:3 6:13 7:7

10:3

Stevens 2:5 6:16,16

stick 21:8

stop 105:9 126:11

stops 77:5

storage 27:15

32:20 134:11

straight 7:22 92:22

straightforward

27:15 114:14

123:19

strategies 39:7

strategy 28:9,12,19

63:11,19

strict 86:18

strongly 5:8

structure 100:21

study 54:6 90:22

stuff 10:15 39:15

subject 149:20

submit 20:5 156:9

submittals 30:20

31:2

submitted 25:17

53:15 54:9 100:16

156:6

substantial 149:9

150:4

successfully 19:6

sufficiently 155:3

suggested 51:21

52:19 63:20

suggestions 28:20

suggests 66:3 89:8

summarize 122:5

summary 7:19 20:3

25:10 155:1

supplier 109:18

supply 39:12 148:4

support 20:6

116:15

supporting 69:3

supportive 143:5

supports 13:14

53:6

suppose 69:17

supposed 98:18

109:10 114:12

117:8 133:13

136:2

sure 26:22 50:22

67:1,8 68:4,10

72:6,21 73:16,20

100:1 119:18

124:3 135:5

SW 1:12

switch 28:7,14

29:13 30:9 31:11

switches 30:2

symbol 45:18

108:10,11,22

symbols 108:5,16

system 31:11 79:6

82:11 83:2 88:19

113:10

systems 55:20

75:14

T

table 72:10 124:7

tables 124:1

take 8:6,11 10:16

66:2 67:5 71:4,8

76:8 106:7 116:8

127:7 151:13

155:12

taken 40:11 68:14

takes 17:17 58:2

69:8 106:5 123:1

talk 25:7 37:14

134:11

talked 149:11

talking 137:22

talks 77:15

tank 137:9,10

138:6

tanks 131:17

Tap 108:7

target 88:22 94:12

task 109:19

technical 72:1

technically 126:14

128:14 133:8

technician 91:6

technique 144:16

technology 144:11

telephone 9:14

temperature 34:11

35:12,14,20 36:8

36:9 39:10,12

40:15 44:7,20

45:2 48:9,12,15

52:5,13 60:20

61:3,20 62:3

76:19 77:9,11,14

77:16,16,18,21,22

78:3,4 84:21 88:1

89:3 92:20,22

93:4,12,14 96:2

99:6 102:11 104:6

104:8,11 108:1

110:1 111:5,9,9

111:14,15 112:4

112:11,11 139:16

temperatures

44:11,12,14 45:6

45:8,12 46:18

47:11,15,18 48:3

52:8 56:16 92:13
202-234-4433

Neal R. Gross & Co., Inc.

Page 176

93:3,22 94:3,11

94:13 97:19,21

104:20

temperature-sett...

123:22

template 126:6,16

126:18

templates 126:13

ten 31:5 108:12

tentatively 147:14

terms 21:11 28:5

112:19 113:14

terribly 119:2

test 1:3 3:7,8,9 4:8

8:4,4,8,10,12

11:21 12:12 13:12

13:17 14:1,5 15:1

15:9,18 16:8,17

17:18 19:8,18,20

21:2,9,11 22:12

22:14,17 23:6,15

24:4,16,20 25:4

25:16 26:1,7,18

27:9,11 28:5,8,11

28:14,15 30:9

32:17,20,22 35:13

35:16,16,22 36:16

37:1,4 40:3 41:16

42:17,18,20 44:8

44:11,16,18 45:3

45:7,10,16,16

46:1,6,9,11,13,15

46:17 47:1,2,3,4,6

47:12,13,22 48:14

48:17 49:4 50:6

50:18 51:9,11

53:15,20,22 54:13

54:16 55:14,17,18

55:22 56:6,8,12

56:18,21 57:3,5,8

57:9,14,14,19,21

57:22 58:2,4,7,8

58:15,17,22 59:13

60:2,4,10,16

61:16,21 62:2,6,8

62:21 63:6,8 64:4

64:22 65:5,16,21

66:6,10 68:16

69:2 70:13 71:1

72:15 75:3,6,7,9

75:12,21 76:3,18

76:21 77:11 78:11

78:21 79:20 81:8

81:14,16 82:5,8,8

82:13,14,19,20,21

83:1,4,7,16,20

84:2,9,11,13,20

85:3 88:15,15,16

88:18,20 89:4,6,7

89:9,13,15,18

90:3,9 91:8,9,21

92:1,3 93:5,7 94:1

94:6,7,12,18

95:13 97:16,17

98:14,15,16 99:3

99:5,5,19 100:17

101:3,20,22

102:14 103:5,7,8

103:12,14,17

104:1,5,16,19

105:3,5,8,9,9,10

106:4,6,13,14

107:3 108:21

109:4,17,19,21

111:6,20,21,22

112:2,6,8,18,20

113:14 114:22

115:14 116:4

117:4 118:5,13

119:7 120:3,7,9

120:10,12,14,17

120:19,22 121:10

123:4,7,10,21

124:18,22 125:12

128:8 130:9

140:18 142:1

143:1 145:7 146:7

146:19 147:9,10

147:13,15,16,17

147:19,22 148:1,2

148:11,12,12,16

148:17,20 149:7

149:11,13 150:1,3

151:7,8,11,15

152:9,20,22 154:6

154:11,12 156:19

157:5

tested 45:22 46:11

72:17,19 95:8,10

95:11 100:4

141:20 145:18

148:18

testing 15:8 16:2

23:1 41:10,21

54:15 66:3 80:10

80:15 95:16 96:14

98:2,7 101:16

102:7 106:19

107:1,13 112:5

113:5 114:9 121:8

139:17 141:17

143:6,19 144:16

145:14 148:6

149:12,21

tests 52:6 55:13

73:5 80:16 90:17

90:20 92:11,18

93:10,11 94:20

95:20,22 99:16

111:16 119:9

123:7 142:10

143:2 145:3

thank 5:17,19,20

13:4,10 17:7,13

18:1 20:11 21:16

25:5,6 32:9 35:9

38:1,2,14 43:13

48:19 55:5 65:6

68:17 87:1 88:13

97:2 100:6,7

107:19 116:16,17

119:17 128:3

144:1,2 152:5

153:21 155:7

158:1

thanking 157:8

thanks 5:13 7:9

20:10 21:15 30:4

43:4,15 70:20

73:17,18 74:19

75:4 97:3,4

119:13 146:21

153:20 155:16

157:21

thermal 48:8 52:12

thermocouple

122:22,22 123:3

thermocouples

116:11 122:14

thing 79:10 98:4

99:1 116:5 140:5

things 8:20 10:22

21:9 27:10 31:7

35:6 46:4 72:4

73:11 97:10 119:3

122:3 128:22

131:7 132:1

147:20 152:11,12

155:18 157:17

think 10:14,21

23:21 24:5,13,19

29:11,19 30:8

31:12 42:13 47:7

49:9,18 55:6

60:10 64:21 67:7

67:20,22 68:3

71:12,22 73:20

74:1,5,16 109:3

110:10 111:3

113:18 116:4

119:6 127:13,15

133:3 135:21

136:1,13,14

143:13 144:20

152:9,17,18 153:4

157:21

thinking 27:3

third 96:13 119:9

135:8

thought 74:17 77:8

81:7 110:16,19

114:17

thoughts 48:20

55:4 64:6 100:8

144:4 146:13

three 8:16 24:7

39:19,21 43:21,22

55:18 56:18 58:12

60:5,16 62:2

78:18 79:19 82:9

86:8,9 93:10,10

93:20 94:20 95:9

99:10,19,20,21

105:22 106:9

137:21 148:18

152:11,12,15

three-year 17:1

threshold 14:2

28:16 30:15,20

31:5 129:22

Thursday 1:8 4:11

tied 137:12

time 9:3,6,7 14:3

14:21 15:8,16

19:10 20:7,16,17

22:11 24:2 26:14

37:2 40:8,13 41:2

47:4 49:7,13,17

54:15 58:11 59:8

59:20 64:6 67:6

68:2 70:2,19

74:17 81:17 83:17

86:2,11 87:16,22

88:8,12 97:13

117:2,6,9 130:12

137:1 144:5

148:11,12,16

157:15,16

timeline 23:18

times 46:20 98:14

timing 14:8 18:13

today 4:11 5:1,3,9

5:10 8:16 12:9,18

13:11 17:12 21:3

22:19 23:17 24:18

24:22 25:9,19

72:8 79:20 86:6

97:18 110:5 155:8

157:9,13,20

today's 14:7 17:8

26:11 107:8

108:21 155:3

tolerance 61:17

89:4 130:1,3

topic 51:17 75:9,14
202-234-4433

Neal R. Gross & Co., Inc.

Page 177

154:3

total 63:2 124:15

touch 76:6

touched 69:9 76:7

trace 42:2 43:10

77:4

transcript 155:21

transition 19:5

travels 158:2

treat 131:15 136:6

treated 120:9,15

131:1,13 132:18

139:12

Treatment 119:17

triangle 93:16

108:5

triangular 93:8,18

triangulation 91:21

92:7 94:6 95:5,12

95:14,17,18 96:4

96:10,18 98:9

99:11,15 100:3

tries 23:14

trigger 28:17

triggering 28:10

42:5,6

true 44:17 118:13

truncation 83:15

89:12

try 42:20 107:18

115:21 136:1,3

147:3

trying 9:12 51:3,12

86:3 88:9 110:12

135:22 152:10,15

152:18

tune 97:16

turn 9:7 25:1 29:3

47:16 50:13,17

71:3 146:20 155:8

turned 28:7

turning 5:22 9:3

turns 8:18 41:11,22

42:21 43:3

two 12:13 29:7

45:11 48:11,14

52:14 55:19,19

56:20 59:9 65:1,2

69:11 75:13 78:18

78:19 79:18,19

82:10 86:7,8,12

90:20 92:9,11,15

92:18 93:1 94:20

95:13,20,22 99:9

99:18,20 103:10

105:22 109:19

110:11,17,20

112:6 130:2

132:21 133:3,13

133:18,21 139:5

152:14 153:1

two-part 82:13

88:15 95:13

type 26:16 28:21

31:14 88:7 102:5

107:1 108:4

124:18 126:9

138:3

types 24:7 93:4

133:3

typical 42:8,8

51:18 54:21 66:14

102:8

typically 5:21

10:17,18 49:9

52:22 108:3

typing 127:9

t(XA) 94:13

t(XB) 94:13

U

UL 142:11

uncertainty 135:19

undercuts 17:1

undergoes 88:20

understand 21:6

21:12 41:18 61:7

61:8 64:22 66:18

67:8 110:7,9

126:15 137:2

145:21 157:11

understanding

5:11 18:10 66:13

67:14 70:4 136:18

Underwriters

37:13

Union 143:19

unique 87:13

unit 32:14 37:21

42:3 50:7 100:4

112:1,1,6,8

118:12 127:19

units 45:17 95:7,10

111:22 148:18

unloaded 47:22

48:9,10,17

unmute 37:9 41:5

unnecessary 60:18

61:11

unusual 129:5

unworkable 79:5

update 51:21

upgrade 148:3,4

upset 97:7

usage 41:15 42:18

64:14 67:15,16

use 15:3 21:15 23:8

29:13 34:3 43:22

45:20 49:14,15

51:19 52:4 54:17

54:18,21 56:14

57:7,11 60:9,11

64:10,19 65:1,3

65:12,17,22 66:4

66:8,13 68:7 69:1

69:11,12,22 70:12

73:3 75:17,21,21

78:3 81:15 82:8

86:2 88:12 90:2

92:20,21 93:2,9

93:21 94:15,16

95:17 96:6 97:15

99:8 100:3,3,6

102:2 103:4,8

104:5,6 105:12

113:13 118:2,13

118:16 122:5

130:10 141:6

142:8,21 145:16

147:11,12 150:17

151:3,6,10 152:19

154:4,8,9,13

useful 34:6 107:12

138:16 143:21

user 134:9

utilities 119:22

utilize 39:5

U.S 1:1 2:5 4:5

98:20

V

value 54:2,7,12

93:6 118:4,8,11

118:14,18 124:9

values 17:17 117:5

117:14,21,22

139:18,20 140:10

valve 39:14

variable 28:10,13

31:10 81:18 104:4

117:3 139:13,15

139:19,20 140:6

140:11

variation 44:10

45:5 84:3

variations 32:6

80:18 148:22

various 12:4 23:1

76:2 84:8 96:11

111:8

vary 47:11

vein 97:8

verification 129:12

129:15,16,18,20

130:7

verified 112:4

version 101:1,18

versus 34:17 57:14

64:11 92:20,21

99:12 128:1

view 15:2 25:18

42:16 68:14

147:19

virtually 14:18

visible 71:10

volume 34:10

115:17,18 124:15

124:16 128:7,11

129:12,19,21

130:3,18,19 131:1

133:7 134:7 135:9

135:11,12,20

volumes 129:5

134:8 135:13

W

wait 67:2

waiting 106:17

waiver 75:19,21

76:3 79:8 80:8

88:12 90:17 101:3

102:4

waivers 23:11,15

23:16 75:15 77:8

78:22 90:4,7

102:17 107:1

wall 121:7 127:11

127:18,22 153:6

153:11

walls 141:8

want 4:22 9:20

10:15 42:13 48:2

49:9,11 67:1,7

68:10 72:6,21

73:21 74:2 97:14

100:6 106:20

119:2 133:2 137:6

137:8

wanted 64:13 72:3

73:16 119:12

122:1 138:2

wants 67:2 100:2

warmer 45:15

warmest 45:9,13

107:22 108:14,17

Washington 1:12

4:13

wasn't 128:5

water 32:19 33:6,8

33:11,13 34:10,14

34:16,21 35:2,4

35:18,21,22 36:9

36:10 37:15,21

38:1,10,13 39:12

39:13 40:7 129:3
202-234-4433

Neal R. Gross & Co., Inc.

Page 178

131:17,18,19

132:6,16,17,17

133:9 137:9,10

138:6,7 148:4

wattage 43:8,10

77:3

wattages 139:21

140:11

watts 42:22 43:9

way 64:5 72:19

73:5 86:5 96:5

109:6,9,13 110:6

110:8,8,12,13

115:13 127:9

136:1,14 137:17

137:18 142:13

145:21 156:8

ways 28:20 109:14

109:17 110:21

wear 71:10

web 9:10

webinar 5:14 11:16

11:16 37:7 72:11

157:10

website 156:1

week 14:16

weighted 64:18

welcome 3:3 4:3,5

5:1 121:1 122:6

132:10 148:7

welcomes 148:21

150:16

welcoming 4:16

went 50:14 71:18

131:5

Westphalen 1:17

7:3,4 30:5,6 32:2

38:4,5 43:6,7 50:1

50:2,20 51:5 71:2

75:1,4 76:16 78:8

78:15 80:14 81:13

82:4,18 84:18

88:14 90:1,21

91:14,20 97:2

100:10,13 101:12

103:3 107:20

111:4 112:15

113:18 146:20

147:1,6 149:5

151:2 154:3

we'll 5:3,12,18 6:2

7:22 8:6,10,18

10:20 12:5,20

13:1 24:15 28:12

29:8,14 43:16

71:3,15 75:22

107:15 119:10

152:3,3 155:22

we're 4:15 8:15

10:1 21:3,19 22:4

24:17,19 25:9,19

27:22 28:18 35:17

37:5,22 42:19

43:17,19 66:7

67:2 70:8 72:19

74:15,22 75:1

109:11 110:12,21

124:19 126:19

127:2 145:5 146:2

152:1,9

we've 5:5,11 13:1

22:9 23:19 59:21

71:8,14 73:1 74:9

74:13 98:21 105:7

114:16 134:16

138:13 142:9

145:2 157:17,20

Whirlpool 2:5 6:5

17:16,17 132:14

135:6 144:9 152:8

wide 47:18

wider 121:19

wildly 107:5

willingness 13:20

157:13

wish 7:21 9:16,16

13:7 155:2

wishes 7:18 13:6

154:22

withdrawn 53:3

wondering 85:1

99:17

Woodford 10:5

worded 86:6

wording 30:7

words 58:10

work 18:22 19:4,22

20:6 81:3,4,6

115:20 129:9

workable 42:14

worked 98:21

working 20:4

works 80:12

world 105:8 107:13

115:15

wouldn't 60:11,12

67:5 81:4,6

wrapped 68:11

write 73:12 79:8

writes 40:19

writing 144:6

written 5:12 17:10

20:6 29:10,15

32:3 55:4 119:11

127:20 156:4

wrong 29:12

136:15

wrote 70:3 80:7

X

X 44:20

Y

Y 44:21

Yashar 98:19

yeah 10:1,17,17

25:12 30:1 41:16

43:7

year 14:6 15:12

18:20 19:19 33:11

66:1 79:22

years 98:21

yellow 57:18

Yep 11:9

Young 2:6 7:7,7

Z

Zealand 94:9,14

96:19 97:5,6

98:14 99:2

Zehr 10:4

zero 16:14 98:6

99:7

$

$800 148:6

0

0 98:4,12

0.042 84:21 113:6

0.7 54:1,11

042 85:5,14 86:3,18

1

1 14:16 106:13

1st 15:18

1,000 116:7 149:15

1-2-3-4-5 108:6

1.8 51:19 52:17

54:4,8

10 3:5 54:20

10th 12:18 18:3

10:30 8:7 71:7,18

10:45 71:14

10:49 71:19

100 43:1,9

1000 1:11

11 108:7

112 3:10

12 103:16 105:5,15

112:7 117:11

12:23 158:3

12:30 8:11

144 3:12

15 18:15 37:20

54:20 71:8 125:16

153 3:13

16 138:13

163 134:5

18 83:20 84:2,6,10

105:20,22 106:2,5

106:7,9

1977 22:15

1979 22:20 114:6

131:5

1982 22:16 23:4

2

2 33:11

2(d) 30:2 32:11

2(h) 43:20

2(i) 43:20

2.j 55:6

20 43:1 108:12

2003 23:22

2008 100:20 111:7

131:3

2009 51:22

2012 23:5 25:17

2013 1:8 4:12

2014 15:5,13,22

23:10 125:16

151:13

2020 67:6

21 3:7

23rd 12:21 15:12

156:5

24 3:8 56:1 62:8

78:20 80:8,12

81:3 83:18,22

84:10 88:16 89:11

103:8,11 104:17

105:10 107:3

24-hour 82:20

83:12,16

25 1:8 116:6

25th 4:11 12:19

250 142:11

26 41:9 43:18

27 43:18

29 113:7

3

3 89:19

30 30:21 31:16

108:12

35 30:21 31:16

36 112:6

39 98:4,5,6,12 99:7

4

4 3:3,4 49:1

4.1 55:16

4.2 135:14

4.2.2 136:11

40 97:21

429 130:8

429.14 125:10
202-234-4433

Neal R. Gross & Co., Inc.

Page 179

429.14(b) 138:22

430.2 24:10 124:14

430.23 101:8

44474 97:1

4474 96:22

45 97:18 98:1

48 103:14

5

5 97:19 98:1

50 43:1 54:15

148:15

56 96:20

6

6 94:17

60 35:19 37:20

7

7.75 124:11

72 29:17 31:2,17

73 3:9

75 116:9

77 144:10

79 111:6

8

8E-089 1:11

84 66:1,3

9

9:00 1:12

9:23 4:2

90 31:2,6,18,22

35:13,19
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

180

Test Procedures for Refrigerators,

Refrigerator Freezers and Freezers

US DOE

07-25-13

Washington, DC