Date: February 5, 2015

Case: Notice of Proposed Rulemaking (NOPR) For Residential 

Dishwashers

Ace-Federal Reporters, Inc.

Phone: 202-347-3700

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Notice of Proposed Rulemaking (NOPR) For Residential Dishwashers

February 5, 2015

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 DEPARTMENT OF ENERGY MEETING

 ENERGY CONSERVATION STANDARDS:

NOTICE OF PROPOSED RULEMAKING (NOPR) FOR

 RESIDENTIAL DISHWASHERS

 United States Department of Energy

 Forrestal Building

 1000 Independence Avenue, SW

 Room No. 8E-089

 Washington, DC

 Thursday, February 5, 2015

 9:00 A.M.
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1 Appearances for Department of Energy Meeting

2 Doug Brookman, Public Solutions, -- Moderator

3 Bryan Berringer, Department of Energy

4 Ashley Armstrong, Department of Energy

5 Johanna Hariharan, Department of Energy, Office of

6 the General Counsel

7 Nicole Buccitelli, Navigant

8 Camilla Dunham, Lawrence Berkeley National Laboratory

9 Mike Edwards, BSH Home Appliances Corporation

10 Charles R. Foster, IV, Independent Attorney

11 Sriram Gopal, Association of 

12 Home Appliances Manufacturers

13 Kyran Hoff, General Electric Appliances

14 Bijit Kundy, Energy Solutions

15 Robert D. McArver, Association of 

16 Home Appliances Manufacturers

17 Paul Newsome, GE Appliances

18 Ed Osann, National Resources Defense Council

19 Judith Reich, Navigant

20 Michael C. Rivest, Navigant

21 Manfred Staebler, BSH Home Appliances Corporation

22 Troy Watson, Navigant
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1 Appearances for Department of Energy Meeting

2

3 Chuck Foster, Edison Electric Institute

4 Chun Chun Ni, Lawrence Berkeley National Laboratory

5 Steve Leybourn, Association of 

6 Home Appliances Manufacturers

7

8

9

10 Webinar Participants for Department of Energy Meeting

11

12 Julian Blomley, Blomley International 

13 Environmental & Associates

14 Emily Clark, Efficiency Vermont

15 Jennifer Cleary, Association of 

16 Home Appliance Manufacturers

17 Rob Cloward

18 Eileen Eaton, CEE

19 Melissa Fiffer, U.S. EPA Energy Star

20 Nick Gillespie, Whirlpool Corporation

21 Kyle Gluesenkamp

22 Mary Kennedy, UL
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1 Webinar Participants for Department of Energy Meeting

2

3 Kelley Kline, General Electric Appliances

4 Wayne Klug, Whirlpool Corporation

5 Jessica Lyman, ICF International

6 Eva Milakowski, Ministry of Ontario

7 Renata Mortazavi, Natural Resources Canada

8 Elizabeth Noll, Natural Resources Defense Council

9 Paul Richter, Electrolux

10 Steve Rolinski, Miele Inc.

11 Michael Woodford, AHRI

12 Angela Langley, DOJ-Antitrust

13 Linda Wilson

14 Brenda Ryan

15

16

17

18

19

20

21

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

2 (9:00 A.M.)

3 MR. BROOKMAN: Good morning everyone. 

4 This is the Energy Conservation Standards Notice of

5 Proposed Rulemaking for Residential Dishwashers. 

6 Today is February 5, 2015 here in the Forrestal

7 Building in Washington, D.C.

8 My name is Doug Brookman, Public

9 Solutions, Baltimore. Nice to see you here this

10 morning. We're going to start with welcoming remarks

11 from Bryan Berringer.

12 MR. BERRINGER: Good morning. Bryan

13 Berringer from the Department of Energy. Thank you

14 all for the people here present here today and those

15 on the Webinar. We have about I think 18 people on

16 the line, as far as the Webinar, so I do expect a

17 good discussion today, and again we thank you those

18 that are here present. And as I said, we just want

19 to hear from you and get your input.

20 We're just going to basically go over the

21 analysis we have to date, and we'll go over that in

22 detail. And as you have questions, please feel free
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1 to ask them.

2 MR. BROOKMAN: Okay, why don't we start

3 with introductions? You can get used to turning

4 these microphones both on and off, and they need to

5 be kind of close to your face to work properly, but

6 your name and organizational affiliation, please.

7 MR. STAEBLER: So, my name is Manfred

8 Staebler, and I'm working for Bosch Siemen Home

9 Appliances located in New Bern, North Carolina, and

10 I'm heading Government Affairs for our company.

11 MR. BROOKMAN: Thank you.

12 MR. EDWARDS: I'm Mike Edwards with BSH

13 Home Appliances, and I work on program structure

14 development for dishwashers.

15 MR. BROOKMAN: Thank you.

16 MR. MCARVER: I'm Rod McArver with the

17 Association of Home Appliance Manufacturers.

18 MR. KUNDU: Bijit Kundu with Energy

19 Solutions on behalf of Pacific Gas and Electric

20 Company.

21 MR. OSANN: Ed Osann with the Natural

22 Resources Defense Council.
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1 MS. HOFF: I'm Kyran Hoff with GE

2 Appliances, and I'm the technology manager for

3 dishwasher.

4 MR. NEWSOME: Paul Newsome, GE Appliances,

5 platform leader for dishwasher.

6 MR. GOPAL: Sriram Gopal from the

7 Association of Home Appliance Manufacturers.

8 MS. HARIHARAN: Johanna Hariharan,

9 Department of Energy, from the General Counsel's

10 Office.

11 MR. WATSON: Troy Watson with Navigant.

12 MS. NI: I'm Chun Chun Ni with LBL.

13 MS. RICH: Judith Rich from Navigant.

14 MS. BUCCITELLI: Nicole Buccitelli from

15 Navigant.

16 MR. FOSTER: Chuck Foster representing

17 Edison Electric Institute.

18 MR. FOSTER: Charles Foster, independent

19 attorney.

20 MR. BROOKMAN: Thank you. Thanks to all

21 of you. Glad to see you all this morning. Thanks

22 for being here on time. We get an early start on the
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1 day.

2 All of you received a packet of

3 information I think as you came in the door. This

4 will be the bulk of the material we'll be going

5 through in detail today. On Slide 3, you'll see an

6 agenda -- actually, Slide 4.

7 Immediately following this agenda review

8 and overview, there's an opportunity for anybody that

9 wishes to, to make brief opening statements, issues

10 that you wish to bring to the floor here at the

11 outset. Did everybody get a copy? Yes? We're all

12 set -- on the materials? Okay.

13 And then, following on from those opening

14 statements, we'll have a review of the overview,

15 scope, and proposed standard and moving on from there

16 market assessment and screening, then engineering

17 analysis. We'll take a break mid-morning around

18 10:40, 10:45 or so. Returning from the break, or

19 whenever we get there, energy use and markup

20 analysis, life-cycle costs and payback period

21 analysis, lunch round about noon-ish, and then

22 shipment, national impact analysis, MIA and NOPR
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1 analyses, and proposed standards and closing remarks

2 at the end of the day whenever we arrive at that

3 point.

4 This is a standard framework for this

5 meeting. Questions and comments on the agenda? Yes,

6 Ed Osann.

7 MR. OSANN: Ed Osann. Doug, will we get

8 introductions from the people who are on the phone?

9 MR. BROOKMAN: I think we could ask our

10 Webmaster to read the names of those individuals

11 who've signed on, okay. We'll do that in a moment. 

12 I'd ask for your consideration, on page 2

13 of the slides are some suggested ground rules. If

14 you would please speak one at a time, please say your

15 name for the record each time you speak. There will

16 be a complete transcript of this meeting made

17 available, if you could be concise, share the

18 airtime, and keep the focus here.

19 If you haven't put your cell phone on

20 silent mode, please do so and limit sidebar

21 conversations. You've already gotten used to turning

22 the microphone on and off.
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1 Webinar participants we welcome you. The

2 Department of Energy is trying hard to make certain

3 that these meetings are totally accessible via the

4 Web. If you would please keep your telephone on mute

5 and raise your hand in the software provided to you

6 recognized to speak, and then we should be able to

7 hear you here in the room once we unmute you via the

8 software.

9 So, that is the bulk of the overview that

10 I wanted to do, except to say that those joining via

11 the Web, the Department encourages your participation

12 in all aspects of this meeting today and wants to

13 especially encourage Web participants to submit

14 written comments. The fact that you're not in the

15 room should not diminish your ability to provide all

16 the comments you wish to provide for this meeting.

17 So, then I'm going to turn it back to

18 Bryan Berringer -- let's let Alex -- can you read

19 who's joining via the web?

20 MR. KROWKA: Alex Krowka from Energetics. 

21 On the Web we have Angela Langley, Eileen Eaton,

22 Elizabeth Noll, Jessica Lyman, Julian Blomley, Kelly
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1 Kline, Linda Wilson, Mary Kennedy, Michael Woodford,

2 Nick Gillespie, Paul Richter, Renata Mortazvi, and

3 Steve Rolinski.

4 MR. BROOKMAN: Thank you. And one more

5 person, this gentleman, you didn't get a chance to

6 introduce yourself.

7 MR. LEYBOURN: Steve Leybourn AHAM.

8 MR. BROOKMAN: Thank you. And Camilla,

9 good morning.

10 MS. DUNHAM: Camilla Dunham, Berkeley

11 Laboratory.

12 MR. BROOKMAN: Thank you. 

13 MR. BERRINGER: Again, thank you all for

14 coming and being available here in person and on the

15 Webinar.

16 Basically, today the purpose of the

17 meeting, obviously, is we're here to talk about

18 dishwashers and the proposed standard. So, today

19 we're going to present procedural and analytical

20 approaches to evaluate the potential energy

21 conservation standards for dishwashers. We invite

22 comments on the Notice of Proposed Rulemaking for the
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1 dishwasher proposal, including DOE's proposed

2 standard levels.

3 So, again, we're here. We invite

4 participation, for you guys to provide comment,

5 either written or orally today. And Doug went over

6 the agenda with you. If there are any other issues

7 that we don't talk about today, please bring them up

8 and we will make sure that we discuss them today.

9 And speaking of discussion, basically, as

10 we go through the presentation today you'll see some

11 note boxes, and these are typically the issues that

12 DOE specifically want to see comment on. A lot of

13 them are addressed in the Notice of Proposed

14 Rulemaking. The list of issues is also available at

15 the website indicated on the slide. And again, the

16 note boxes or issue boxes is just an area where DOE

17 welcomes comment, data, information concerning the

18 standards concerning the dishwashers.

19 And again, we are going to have an open

20 comment period and for written comments after the

21 meeting, so you'll have until February 17 to provide

22 written comments.
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1 So, at this time I'm going to turn it back

2 to the participants. If anybody wants to have any

3 opening remarks, you're invited to do that at this

4 time.

5 MR. BROOKMAN: Yes, please. Rob.

6 MR. MCARVER: If there's no particular

7 order, maybe we'll go alphabetically, right.

8 Good morning and thank you for the

9 opportunity to be here today. I'm Rob McArver, Vice

10 President of Policy and Government Relations with the

11 Association of Home Appliance Manufacturers.

12 We appreciate that this public meeting

13 represents an opportunity to address the proposed

14 rule and highlight some of the issues identified by

15 our members, many of whom are represented around the

16 table and on the phone today.

17 I'd like to highlight a few concerns that

18 we have up front, and then AHAM staff and the member

19 companies represented here will raise additional

20 points during the day's discussion.

21 First of all, I'd like to address

22 circumvention of the process improvement rule. AHAM
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1 objects to DOE's short circuiting of the process

2 improvement rule by foregoing such critical

3 pre-proposal steps as public data availability,

4 stakeholder input, and company interviews.

5 Following these standard procedures

6 would've resulted in a much improved proposal from

7 DOE we feel. They provide DOE with a better

8 understanding of the realities of the current market

9 and product mix and could've prevented many of the

10 analytical errors that appear to be strewn throughout

11 this proposal.

12 In addition, the pre-proposal steps allow

13 stakeholders time to prepare much more useful

14 comments for DOE's consideration. Indeed, the

15 process improvement rule was developed in large part

16 because DOE was conducting nontransparent analyses

17 and in isolation from what was happening in the real

18 world, which resulted in the need for much more

19 engagement among government, DOE, contractors, and

20 industry stakeholders.

21 It was because of the development of the

22 process improvement rule that AHAM supported removing
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1 the previous requirement for an advanced notice of

2 proposed rulemaking. The process improvement rule

3 was developed through extensive stakeholder

4 involvement and notice and comment.

5 Here, by contrast, DOE first unilaterally

6 authorized itself to waive portions of the process

7 improvement rule and then submitted a proposed rule

8 directly to OMB without any notice to the regulating

9 community. This is an abuse of proper procedure and

10 has resulted in what we think is a defective product. 

11 The proposal can be fixed, but it will take more time

12 to do so now than it would have had DOE adhered to

13 the steps laid out in the rule.

14 The action is particularly egregious in

15 light of the fact that the last dishwasher standard

16 was presented to DOE through stakeholder agreement. 

17 And in that instance, we actually supported the

18 earliest possible effective date.

19 Given the constructive manner in which our

20 industry has operated in the past with respect to

21 dishwashers and a number of other products, it's

22 troubling that we have been subjected to this covert
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1 and non-inclusive regulatory action. And we have a

2 number of substantive concerns and criticisms

3 regarding the proposed rule, but we are crippled in

4 our ability to provide the necessary substantive

5 comments because of the extremely limited time we've

6 been given before this hearing and the comment

7 period.

8 This has been exacerbated by the fact that

9 vital technical information is buried, if available

10 at all, in various technical support documents. We

11 urge the Department, therefore, to provide us with an

12 opportunity for individual companies to understand

13 how models that have been selected by DOE as

14 exemplars for the proposed rule were analyzed and

15 evaluated from an engineering, performance, and cost

16 point of view. Without this information, it is

17 extremely difficult for us to provide in depth

18 comments; thereby, making it that much more difficult

19 for DOE to make decisions on the appropriate content

20 of the final rule.

21 As an example of what bothers us about the

22 process followed, I would note that this proposal was
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1 issued on December 9, right before the start of the

2 holiday season and the public was granted only a

3 60-day comment period. The holiday season

4 effectively shortened the comment period by at least

5 two weeks.

6 By comparison, the proposal of the

7 commercial clothes washer test procedure was

8 published last February with a 75-day comment period. 

9 Likewise, the proposal accompanying the joint

10 petition for the 2012 dishwasher standard had

11 110-day comment period.

12 In light of this, we are reiterating today

13 our request for a 60-day extension of the comment

14 period, which we believe is very reasonable and would

15 allow us the time needed to discuss the proposal in

16 greater depth with DOE and its contractors as well as

17 amongst ourselves.

18 Based on the information that we've been

19 able to evaluate to date, our initial analysis of the

20 proposed standard levels suggest that they're

21 extremely stringent and would force the vast majority

22 of well-performing and energy-efficient products out
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1 of the market. The standard levels chosen appear to

2 have significant performance and cost implications,

3 and it appears that the existing dishwasher model

4 platform would be destroyed by this action.

5 Even by DOE's estimate, very few current

6 products meet the proposed standard. And we do not

7 believe that the models on which the standard is

8 based are representative of what American consumers

9 should expect as the only available choices.

10 From what we can tell only about 10

11 percent of the standard size current Energy Star

12 models would meet the proposed standard even though

13 approximately 90 percent of the models currently on

14 the market meet Energy Star's specifications. Far

15 fewer compact dishwashers are certified under Energy

16 Star and only about 10 percent of those would meet

17 the proposed standard as well.

18 The heart of the justification for the

19 proposed standard is the Navigant engineering

20 analysis of products minimally complying with the

21 proposed standard in the associated trial standard

22 level. We believe that certain characteristics of
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1 this type of product, including their price would be

2 totally unacceptable to many consumers. Likewise,

3 the drastic reduction in energy and water use

4 proposed would necessitate a significant increase in

5 cycle times, which also would be unacceptable.

6 It is not clear how Navigant went about

7 choosing the representative products it used in its

8 baseline and tiered analysis. The market analysis

9 was based on information used in support of the

10 direct final rule published in 2012, much of which

11 was gathered in 2010 and 2011, and therefore is

12 likely out of date. Had proper procedures been

13 followed this could have easily been avoided.

14 The dishwasher technical support document

15 states that DOE considered technology options from

16 the 2012 direct final rule for dishwashers, the

17 information provided by trade publications, and

18 design data identified in manufacturer product

19 offerings. They did not use current information

20 obtained directly from manufacturers, which should be

21 the most obvious information to consider.

22 By granting more time to our members to
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1 engage Navigant directly, this analysis could be

2 better understood by affected companies and could be

3 improved and strengthened by Navigant. This is a key

4 reason behind our request for a 60-day extension of

5 the comment period.

6 On a related point, it appears that this

7 needs to be explored on an individual model and

8 company basis that Navigant's assurance that there

9 has been no impairment of product performance for

10 products that already attain the proposed efficiency

11 levels is based on the Energy Star dishwasher

12 performance standard. But, and DOE has been briefed

13 on this several times, AHAM undertook an in depth

14 evaluation of the repeatability and reproducibility

15 of that test procedure and showed that it is badly

16 wanting.

17 How then could DOE apparently adopt this

18 flawed test procedure as the basis of such a radical

19 standard? This is more than a little troubling and

20 it suggests a rushed effort to get the proposal out

21 rather than to develop a reasonable rule based on

22 current data and valid test methods.
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1 In closing, we're concerned that DOE's

2 analysis underestimates the cumulative regulatory

3 burden on manufacturers of major appliances. 

4 Furthermore, the unnecessarily expedited regulatory

5 pace has led to degradation in DOE's own regulatory

6 processes. There are numerous apparent deficiencies

7 in the analyses that we will explore in our written

8 comments, including the extraordinary payback period

9 and the adverse impact on company finances.

10 We look for the opportunity to work with

11 DOE and with Navigant to take a much deeper dive into

12 the facts behind this proposed standard to the

13 ultimate benefit, a much more justified and

14 acceptable and consumer-friendly final rule.

15 Thank you for the opportunity to present

16 our brief views, and we look forward to today's

17 dialogue.

18 MR. BROOKMAN: Okay. Thank you. Other

19 comments here at the outset?

20 MR. BERRINGER: This is Bryan Berringer. 

21 Point of clarification, so your comment extension

22 you're looking for 60 days from February 17; is that
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1 what you're looking for?

2 MR. MCARVER: Right.

3 MR. BERRINGER: Okay. Thank you.

4 MR. STAEBLER: Manfred Staebler from BSH. 

5 I can echo what Rob said, especially for BSH where we

6 have our colleagues in Germany to consult. And as

7 many of you may know, they are a little bit luckier

8 than we with the holiday, so they will be back you

9 know probably 6 of January. We have no chance to

10 contact them and get input. So, we appreciate if we

11 get that extension.

12 MR. BROOKMAN: Got you.

13 MR. STAEBLER: And the other thing is I

14 think the discussion with Navigant to understand what

15 was tested, how it was tested will also help us to

16 understand the outcome.

17 MR. BROOKMAN: That information was not in

18 the TSD? Rob?

19 MR. MCAVER: To my understanding, Navigant

20 hasn't had any direct engagement with the

21 manufacturers, so what they based their

22 recommendations or the analysis on which the
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1 proposal is based doesn't include current information

2 on what's on the market and how those products

3 perform.

4 MR. BROOKMAN: I understand. Ed Osann.

5 MR. OSANN: Ed Osann with NRDC. AHAM has

6 raised quite a range of concerns that the

7 manufacturers believe to be serious and we also would

8 like to have the opportunity to explore these issues

9 further, including the opportunity to discuss them

10 with AHAM and member companies, so we don't object to

11 the extension of the comment period.

12 MR. BROOKMAN: Okay. Thanks Ed. 

13 Additional thoughts at the outset here before we go

14 into detail and the content in the packet?

15 MS. HARIHARAN: This is Johanna Hariharan,

16 Department of Energy, General Counsel's Office.

17 I would just like to clarify something

18 about the process rule before we get started, and I

19 think right now is probably the best time to do it.

20 The process rule is not a legal

21 requirement, first of all. It is a guidance

22 document. And in 2010, we did issue additional
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1 guidance, saying that when we found it appropriate we

2 would go straight to the proposed rule. And so, I

3 believe I everyone is aware of that and there is

4 nothing illegal about the process that we did follow

5 here, so I would just like to clarify that.

6 Also, the 60-day comment period is

7 typical of a standard rulemaking. We'll definitely

8 consider your comment extension, but I do want to say

9 that we're not doing anything out of the ordinary

10 with the 60-day standards comment period.

11 MR. BROOKMAN: Okay, thanks for the

12 clarification. Are we ready to dive into this detail

13 here? Okay, let's go then. Bryan Berringer is going

14 to start us off.

15 MR. BERRINGER: I'm just going to give a

16 brief overview and then we'll get into the various

17 analyses. Again, thank you for your opening remarks

18 and thank you for your participation. I hope we can

19 move forward from here and get everything on the

20 right track. So, again, thank you for that.

21 Okay, so basically, the Energy Policy Act,

22 most of you who've been around know this. Just a
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1 little history of the Energy Policy Act of 1975 is

2 sort of the basis that authorizes DOE to establish

3 energy conservation standards for covered products,

4 which include dishwashers.

5 Basically, the dishwasher energy

6 conservation standards that were mentioned in the

7 past were -- we had one effective in 1994, 2010, and

8 more recently, as was mentioned, on May 30, 2013 was

9 the most recent, effective standards rulemaking.

10 Here's just the definition of dishwasher

11 that's found in 10 C.F.R. 430.2. I'm not going to

12 read that to you. I think the more important thing

13 that was mentioned that we're looking at two product

14 classes, both compact and standard, and that's

15 basically what the proposals are looking at that

16 we're looking at today. So, DOE proposes to maintain

17 the existing definition of product classes for

18 residential dishwashers in the compact and standard

19 class.

20 Again, here, EPCA just directs us to have

21 seven factors to look at. The seven factors are

22 listed here. And as a result of those seven factors,
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1 the analysis that we're presenting today and

2 throughout the rulemaking process we look at the

3 lifecycle cost analysis, the manufacturer impact

4 analysis, national impacts, engineering analysis, the

5 screening analysis, and emissions and also utility,

6 employment and regulatory impact analyses.

7 So, we're going to discuss all these in

8 detail today, and we'll give people an opportunity to

9 go through those.

10 And again, the next slide is where now

11 we're in the proposed rulemaking stage. This is all

12 the analysis that we're going to, again, step in

13 detail, starting off with the engineering analysis. 

14 And basically, what we want to do in this meeting, as

15 mentioned by AHAM, is we want to make sure that we're

16 on the right track. We got the right information

17 and the right analysis. We'll refine that analysis

18 before we make a decision on any final rule, so

19 there's plenty of opportunity in the process to do

20 that.

21 And as Johanna mentioned, we'll definitely

22 consider the extension of comment, and we'll get back
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1 to you on that. So, we want to make sure that this

2 is an open process and that we do get your feedback

3 and your input.

4 That being said, this is what we've got

5 for the analysis to date. For standard rulemaking

6 we're looking at trial standard level number two,

7 which is efficiency level number three. So, for the

8 standard product class of dishwashers, we're looking

9 at annual energy use of 234 kilowatt hours per year

10 and water consumption of 3.1.

11 For the compact class, we're looking at

12 efficiency level number one and we're looking at

13 annual energy use of 203 with a water consumption

14 rate of 3.1 gallons per cycle.

15 Again, as was mentioned, what we're basing

16 this on, obviously, we're listing here the benefits

17 and the burdens of looking at these proposed levels. 

18 The analysis to date shows approximately one quad of

19 energy savings from 2019 to 2048, net benefits of .23

20 billion in net present value at a 7 percent discount

21 rate and 2.14 billion at a 3 percent discount rate. 

22 We also have emission reductions in both classes for
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1 the LCC energy savings are positive.

2 As mentioned, there is a burden with a

3 decrease in industry net present value as much as

4 34.7 percent or almost $204 million for the

5 residential dishwasher industry. So, we have

6 recognized that.

7 Okay, with that being said -- are there

8 any other questions before we start -- we're going to

9 start and step through the analysis at this point and

10 give people a chance for discussion.

11 Do we have any other general comments,

12 anything about the agenda or any other items that

13 need to be addressed, other than what you see on

14 these topics today? Anybody on the phone, any issues

15 from the Webinar?

16 Okay, hearing none, I'm going to turn it

17 over to Troy Watson to talk about the market

18 technology and screening.

19 MR. WATSON: Like Bryan said, I'm Troy

20 Watson and I'm with Navigant, and I'll be taking us

21 through the first three stages of DOE's NOPR

22 analysis.
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1 (Slide shown)

2 MR. WATSON: So, you can see the first

3 step here is the market and technology assessment. 

4 So, the purpose of a market and technology assessment

5 is to gather all the relevant information that could

6 be used in the downstream analyses of DOE's NOPR

7 analysis.

8 So, the key things that DOE does at this

9 stage are define product classes, characterize the

10 industry, identify existing regulatory and voluntary

11 efficiency programs, gather market data, and identify

12 the technology options that could be used to improve

13 dishwasher efficiencies.

14 And as has been pointed out, most of the

15 information in chapter 3 of the TSD, which covers the

16 market and technology assessment, a lot of that

17 information was pulled from information that was

18 gathered in support of the 2012 direct final rule. 

19 But DOE did go through and update that information

20 with more recent data, as it was available.

21 So, for product classes, as Bryan said,

22 DOE is continuing to propose standards based on the
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1 existing product classes, and these are compact and

2 standard. The differentiation is based on the

3 product capacity in terms of place settings, and

4 that's based on the ANSI/AHAM DW-1 standard, and

5 that's the 2010 version.

6 Now, for the technology assessment, this

7 is where DOE develops the list of technology options

8 that can improve the efficiency of dishwashers. And

9 this list of technology options, it feeds into the

10 downstream analyses, so anything DOE identifies in

11 the market and tech assessment is considered further

12 in the later analyses.

13 And again, most, if not all, of the

14 technology options identified in the market and

15 technology assessment were also identified in the

16 2012 direct final rule; but DOE did also conduct

17 literature review and conducted product teardowns

18 since the 2012 direct final rule to determine whether

19 those technology options are still valid or if there

20 are certain new components that DOE might have missed

21 out on since the direct final rule. And that's how

22 DOE developed a list that's included in chapter 3 of
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1 the TSD.

2 And I know I don't have too many comment

3 boxes mixed in here, so if there's a particular spot

4 where you'd like to jump in. I know it sounds like

5 manufacturers might have input here on the list of

6 technology options, so DOE would definitely welcome

7 any comment.

8 MR. BROOKMAN: Ed Osann.

9 MR. OSANN: Ed Osann with NRDC. In terms

10 of assessing sort of the base case against which

11 standards would be compared, what is the most recent

12 year of production and shipments that you had

13 incorporated into the analysis for the base case?

14 MR. WATSON: For the shipments, I'd have

15 to turn to my LBNL colleagues. In terms of

16 engineering, the information is based on -- the most

17 recent data, I think, was May 2014, so for things

18 like market information DOE pulled information from

19 the certification database. So, any products that

20 were certified in May 2014 were considered in this

21 analysis.

22 MR. BROOKMAN: Bijit.
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1 MR. KUNDU: Bijit Kundu, Energy Solutions. 

2 Ed asked the question -- the first question I was

3 going to ask. I guess the second question I had was

4 what was the latest or the most recent year for your

5 teardowns? What year models were they?

6 MR. WATSON: Well, teardowns were

7 conducted around that May timeframe, I believe. I

8 think what you're getting at is had the previous

9 standards kicked in by the time we did this

10 analysis.

11 MR. KUNDU: No, I was just actually

12 looking for like how recent is the models, were they

13 2014 models, were some mixture?

14 MR. WATSON: So, I believe the teardowns

15 were in 2014. I can't say off the top of my head if

16 they were manufactured in 2014. I know there's

17 usually a lag period of maybe 10 months to a year, so

18 these were probably manufactured in 2013.

19 MR. KUNDU: Is that data typically

20 available or does DOE typically make that data

21 available?

22 MR. WATSON: I don't think we provide
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1 detailed information on the models we tore down.

2 MR. BROOKMAN: Can you provide the dates,

3 the model years of the models?

4 MR. WATSON: We can see if we can get that

5 information. I mean the models are torn down.

6 MR. BROOKMAN: Let him finish his comment.

7 MR. KUNDU: Yes, I mean you've got the

8 model numbers, right, and the models, right?

9 MR. WATSON: We could probably provide a

10 range of dates, but we wouldn't provide specifics.

11 MR. KUNDU: Thank you.

12 MR. BROOKMAN: Additional thoughts on

13 these technology options, specifically? That's our

14 point of departure here.

15 Okay, we're going to move on.

16 MR. WATSON: And like I said, a lot of the

17 information from the market and technology assessment

18 feeds into the other analyses, and one of these is

19 the screening analysis. And this is where the list

20 of technology options identified in the market and

21 tech assessment, those are all considered. DOE

22 determines whether they're appropriate for
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1 consideration in the downstream analysis. And DOE

2 does this based on four criteria.

3 Technologies would be screened out if they

4 are not technologically feasible, not practicable to

5 manufacture, instal or service, if they have adverse

6 impacts on product utility or availability to

7 consumers, or if they have adverse impacts on health

8 or safety.

9 So, in the screening analysis, DOE

10 screened out three technology options. And again, I

11 think this is consistent with the 2012 direct final

12 rule, and these are the reduced inlet water

13 temperatures, super critical carbon dioxide washing,

14 and ultrasonic washing.

15 And for the second two, those are not

16 currently available on the market. They're pretty

17 much at the conceptual stage, so DOE determined it

18 wouldn't be practicable to manufacture those

19 technologies on a scale necessary to reach the market

20 by the time of the effective date of any proposed

21 standards.

22 For the first technology option, the
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1 reduced inlet water, DOE screened that out because it

2 would not be practicable to install on the market and

3 this is because typical homes in the U.S. have only a

4 hot water line that's running to the dishwasher

5 location in the kitchen. So, in order for a reduced

6 inlet water temperature to be incorporated on the

7 market, consumers would have to reconfigure their

8 kitchens across the country to get that cold water

9 feed line there.

10 So, after screening out those three

11 technology options, the remaining technology options

12 were considered further in the engineering analysis.

13 MR. STAEBLER: This is Manfred Staebler

14 from BHS. I have one question to the reduced inlet

15 water temperature. That means you assume you have

16 warm water to the dishwater; is that correct? 

17 Because if I just look at my house, you know, I have

18 the hot water heater is somewhere downstream with

19 this little water, you have actually cold water to

20 the dishwater, even if you are hooked up to the warm

21 water line.

22 MR. BROOKMAN: Thank you.
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1 (Slide shown)

2 MR. WATSON: Now, we'll move on to the

3 engineering analysis. And this, again, shows how it

4 feeds into the later downstream analysis at the NOPR

5 stage.

6 So, in the engineering analysis, DOE

7 evaluates the design options that can improve

8 efficiencies of dishwashers. And the main output of

9 the engineering analysis is shown by this chart down

10 at the bottom left. So, DOE develops a relationship

11 between manufacturer production costs and improved

12 efficiency levels. And typically, as you go to the

13 improved efficiency levels the manufacturer costs

14 increase. And then this is the information that

15 feeds into the downstream analyses.

16 This gives an overview of how DOE

17 approached this engineering analysis. The first step

18 is developing baseline and higher efficiency levels

19 for both of the product classes. DOE then selected

20 representative units for testing and teardowns. 

21 After conducting the teardowns and testing, DOE

22 identified the design options that were included in
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1 these units and DOE determined the typical mix of

2 design options that could be incorporated at each

3 higher efficiency level.

4 And then, from that teardown information

5 DOE developed a cost model to estimate the

6 manufacturing costs of these different products. And

7 when those costs were assigned to the different

8 efficiency levels that's how you generate the cost

9 efficiency curves.

10 So, the first step is establishing the

11 efficiency levels. At the baseline, DOE selected the

12 current efficiency level -- I'm sorry -- the current

13 existing energy conservation standards as the

14 baseline efficiency level for both product classes,

15 and they're shown here in the table. And DOE is

16 aware of dishwashers that are available on the

17 market that are currently at both baseline efficiency

18 levels.

19 For standard dishwashers, DOE analyzed

20 four possible efficiency levels beyond the baseline. 

21 The first is based on the current Energy Star levels. 

22 The next two are representative efficiency levels
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1 based on the distribution of models available on the

2 market, and efficiency level four is based on the

3 maximum available efficiency at the time of the

4 analysis, and here you can see that was the May 2014

5 timeframe.

6 So, as Bryan said, efficiency level three

7 is the proposed level in this NOPR. So, we'll give a

8 little more detail on how DOE selected that level.

9 So, I mentioned the DOE certification

10 database in May. This plot shows the distribution of

11 models that were available on the market at that

12 time. And one thing to note here is that any models

13 that were certified as having a cold water inlet were

14 removed from this database because DOE screened out

15 that technology option.

16 So, you can see here efficiency level

17 three is kind of the most efficient point in the big

18 cluster of products, so it kind of represents a most

19 efficient point out of the typical distribution of

20 products available on the market at that time. And

21 there are very few units available on the market

22 between efficiency level three and maximum available.
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1 MR. KUNDU: Bijit Kundu with Energy

2 Solutions. I'm just curious. Did DOE kind of

3 qualitatively look at more recent data between May of

4 2014 and you know whenever this was published, maybe

5 the end of 2014, just to kind of see where newer

6 models kind of fell along this?

7 MR. WATSON: Not that I'm aware of, but

8 that's definitely something DOE would consider going

9 forward as part of this. And if anyone has input as

10 to where models have dropped off or were introduced

11 --

12 MR. BROOKMAN: That's the point.

13 MR. WATSON: -- that's information we

14 would welcome.

15 MR. BROOKMAN: That is new models that

16 might demonstrate different performance

17 characteristics. If you have information about that,

18 that would especially useful to the Department.

19 Yes, Ed Osann.

20 MR. OSANN: Yes, Ed Osann with NRDC. Can

21 you repeat that observation you made about this

22 cluster diagram here in connection with TSL3.
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1 MR. WATSON: Yes. So, DOE was selecting

2 the efficiency levels and it looks at the maximum

3 available, so that efficiency level four or whatever

4 the highest efficiency level is, and moving back from

5 that point there's a couple of units scattered in

6 there, but they're not really representative of --

7 they're just single units and DOE tries to avoid

8 analyzing a single unit as the efficiency level.

9 So, by moving back to where there are more

10 products available, DOE thought that was a more

11 representative efficiency level to consider for its

12 analysis.

13 MR. BROOKMAN: That's 234 kilowatts.

14 MR. WATSON: Yes. 

15 MR. BROOKMAN: Additional thoughts,

16 comments here? Okay.

17 MR. WATSON: Okay. For compact

18 dishwashers, DOE analyzed two efficiency levels

19 beyond the baseline, and these are based on the

20 proposed Energy Star criteria and the maximum

21 available based again on the certified dishwashers

22 in the DOE database.
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1 One thing to point out here is that DOE is

2 not aware of any dishwasher models -- compact

3 dishwasher models currently available on the market

4 at EL1; however, in developing its proposal Energy

5 Star had conversations with manufacturers and

6 discussed the changes that would be necessary to

7 increase efficiency to EL1. So, DOE based its

8 analysis at EL1 on the information gathered by Energy

9 Star.

10 So, we've gotten into this a little bit,

11 but DOE requests comment on the efficiency levels

12 selected. And specifically, DOE is interested in

13 knowing if cleaning performance or any other consumer

14 utility is affected at any of the analyzed efficiency

15 levels.

16 MR. BROOKMAN: No additional comments

17 here. Let me remind those joining us via the Web, if

18 you wish to comment we probably can hear you here in

19 the room. Okay.

20 MR. WATSON: Okay. So, after selecting

21 the efficiency levels, DOE conducted testing. And

22 DOE conducted testing both specifically for this NOPR
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1 and DOE also relied on a lot of the data that was

2 gathered in developing the Energy Star cleaning

3 performance test method. And DOE was particularly

4 interested in cleaning performance to determine

5 whether consumer utility could be affected at any of

6 the analyzed efficiency levels.

7 And from this testing, DOE observed that

8 cleaning performance does decrease at a certain

9 point, but based on the available test data that

10 looks like this occurs when products use less than

11 .4 kilowatt hours per cycle of machine electric

12 energy consumption, or below three gallons per cycle

13 of water consumption. After that point, it looks

14 like things start to drop off a little bit.

15 And an important thing to point out is

16 that this really only occurred on the heavy and

17 medium soil loads under the DOE test procedure. And

18 this is likely because when you test the according to

19 the light cycle there's so little soil being

20 introduced to the machine that the opportunity to

21 really get a low score is not there as much as for

22 the medium and heavy cycles.
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1 MR. EDWARDS: Troy, Mark Edwards from DSH. 

2 So, what attributes were evaluated? Was it just the

3 cleaning for DOE and Energy? Were there other

4 attributes like drying or time or something like that

5 involved in the analysis?

6 MR. WATSON: In this, DOE looked at

7 cleaning performance, energy performance, and water

8 performance. It didn't look at drying performance. 

9 And DOE would have data on the cycle times, but I

10 don't think that fed into the engineering analysis,

11 and I don't know that information off the top of my

12 head.

13 MR. BROOKMAN: Yes, please. Steve.

14 MR. LEYBOURN: This is Steve Leybourn with

15 AHAM. I saw in a footnote in the TSD that -- and I'm

16 paraphrasing a little bit, that in order to present

17 the largest set of data for the cleaning performance

18 was that they presented -- you presented the IEC's

19 scoring results. It suggests that there are also the

20 AHAM scoring results. Would that be something you

21 guys would be willing to share?

22 MR. WATSON: So, the reason DOE used the
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1 IEC scoring results is because there was more data in

2 support of the Energy Star test method. I know at

3 least one of the rounds of testing only looked at IEC

4 scoring because at that point it looked like that was

5 the way the test method was going, and that round of

6 testing covered a lot of units. So, the AHAM

7 information isn't available there, so that's why we

8 used the IEC data.

9 But as we found out during the Energy Star

10 test method development, both of the scoring methods

11 convey similar information. It's just a matter of

12 what scale the final number's on. And I think some

13 of the testing AHAM did with the round robin showed

14 that point, which is why we switched back to the AHAM

15 scoring method for that test method. So, even though

16 the numbers are a little different than they would

17 currently come out under the test method for Energy

18 Star, the information is the same. You'd see a

19 similar drop off in cleaning performance at the lower

20 water consumptions. It's just a matter of what are

21 the numbers on the scale.

22 MR. BROOKMAN: If AHAM thought these
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1 numbers were discrepant, then you should definitely

2 note that in your comments. Okay, Ed Osann.

3 MR. OSANN: Ed Osann with NRDC. Three

4 questions about this.

5 First of all, what is the universe of the

6 tested machines there?

7 MR. WATSON: I believe there's probably

8 around a dozen machines, but I'd have to go back to

9 the data to come up with a number for sure.

10 MR. OSANN: A dozen for compact and a

11 dozen for --

12 MR. WATSON: Sorry, this is just standard

13 dishwashers.

14 MR. OSANN: Standard.

15 MR. WATSON: Yes. I don't know that there

16 are a dozen compact units available on the market.

17 MR. OSANN: And you're testing it medium

18 and heavy; is this multiple tests of the same machine

19 or this was way more than two dozen?

20 MR. WATSON: Yes. So, each machine would

21 get light, medium, and heavy soil loads. And I

22 believe there's some repeatability in there, so there
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1 could be a few data points that could be multiple

2 mediums for a single unit or multiple heavies for a

3 single unit.

4 MR. OSANN: Okay, so these are multiple

5 tests on 12 machines?

6 MR. WATSON: Correct.

7 MR. OSANN: Okay, were the tests conducted

8 by DOE or your contractor?

9 MR. WATSON: I believe DOE conducted some

10 of these tests internally, and others were conducted

11 at third-party test labs.

12 MR. OSANN: At third-party test labs?

13 MR. WATSON: Third-party test labs.

14 MR. OSANN: Okay, but at DOE's request.

15 MR. WATSON: Yes.

16 MR. OSANN: And the slide above has a

17 reference to cleaning performance typically

18 decreasing at lower energy as well as water

19 consumption with a reference of .4 KWH per cycle. Is

20 there a similar plot for the energy consumption per

21 cycle versus the cleaning performance?

22 MR. WATSON: Yes, chapter 5 of the TSD --
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1 MR. OSANN: It's in the TSD.

2 MR. WATSON: -- separates out the plots. 

3 That separates it out by heavy, medium, and light

4 soil load, and it also separates it out by energy and

5 water consumption.

6 MR. OSANN: Thank you.

7 MR. WATSON: The reason this one is

8 included here is because the trend seemed most clear

9 with the water consumption.

10 MR. BROOKMAN: Additional questions,

11 comments before we move on? Yes, Mike.

12 MR. EDWARDS: Yes, Mike Edwards, BSH. I

13 just wanted to make the comment that in the DOE round

14 -- or the AHAM round robin we saw up to a 30 point

15 range in performance of a single unit with the DOE

16 test procedure, so there's quite a variation.

17 MR. BROOKMAN: Running the same

18 prescriptive cycle?

19 MR. EDWARDS: Sending the unit to

20 different manufacturers and running the tests the

21 evaluation came out quite a bit different.

22 MR. BROOKMAN: Different for manufacturing
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1 or different from labs?

2 MR. EDWARDS: Different labs.

3 MR. BROOKMAN: Different labs, okay.

4 MR. EDWARDS: Yes, single unit.

5 MR. BROOKMAN: Interesting. Okay. Thank

6 you.

7 MR. WATSON: One point on that is that DOE

8 recognized that same sort of variability in its

9 testing. And when there were big jumps in the score

10 like that it was usually because the unit was using

11 different amounts of water. So, I think this helps

12 to show that if you're in a certain range you're

13 probably ending up with a certain cleaning

14 performance. It's when you get a unit that's

15 triggering different cycle responses where you get

16 the wide variation of cleaning performance.

17 MR. BROOKMAN: Mike.

18 MR. EDWARDS: What we found internally is

19 that the tests seem to be repeatable within the same

20 lab, but when you go outside that lab you see much

21 larger variations.

22 MR. BROOKMAN: Okay. Additional comments
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1 here? I said this before for those of us joining in

2 via the Web, you need to send a signal to our

3 Webmaster and he will unmute your phone if you wish

4 to comment.

5 Okay, we're going to move on.

6 MR. WATSON: So, after testing, DOE

7 conducted reverse engineering on its test units and

8 so DOE tore down each unit tested in support of this

9 NOPR and also relied on some of the teardown

10 information that was conducted in support of the May

11 2012 direct final rule. But one thing that's

12 important to note here is that if DOE pulled any of

13 that information, it confirmed that the teardowns

14 were conducted on units that are either still

15 currently available on the market or that are

16 representative of units that are still currently

17 available on the market.

18 So, during these teardowns, DOE observed

19 the typical design options that manufacturers

20 incorporated into products at the different

21 efficiency levels, and chapter 5 of the TSD includes

22 a detailed list of the technology options that
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1 seemed typical of construction at the different

2 efficiency levels.

3 So, the main output from teardown is a

4 bill of materials. DOE then feeds that bill of

5 materials into its manufacturing cost model. And

6 it's a pretty detailed cost model that looks at

7 whether parts are purchased by the manufacturer,

8 whether they're manufactured in house directly from

9 raw materials. It considers all the assembly

10 processes necessary to bring the product together,

11 and the main output is the manufacturing production

12 cost; and this includes things like material, labor,

13 overhead.

14 (Slide shown)

15 MR. WATSON: This shows how that ties into

16 other manufacturing costs, so on the left over there

17 is the manufacturing production cost. That's the key

18 output of engineering analysis, but manufacturers

19 also incur non-production costs and these kind of

20 feed into the manufacturer markup, which Camilla will

21 go into a bit more. And when you apply the

22 manufacturer markup to the manufacturer production
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1 costs, that's how you arrive at the manufacturer

2 selling price.

3 (Slide shown)

4 MR. WATSON: So, after conducting all the

5 teardowns and analysis, DOE developed a manufacturing

6 production cost at each efficiency level based on the

7 mix of design options as included in chapter 5 of the

8 TSD. DOE arrived at these incremental numbers. So,

9 it compares the manufacturer production cost at each

10 higher efficiency level to the baseline manufacturer

11 production costs.

12 And one thing that's important to point

13 out here is that the MPCs are equivalent at EL3 and

14 EL4, and that's because DOE expects manufacturers to

15 incorporate the similar types of design options at

16 both of these efficiency levels. The way DOE expects

17 manufacturers to reach EL4 from EL3 is to implement a

18 control scheme that would limit water and energy use,

19 but it wouldn't necessarily require additional

20 physical features. So, since that's just a control

21 tweak there's no associated increase in MPC at that

22 level.
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1 And so that pretty much takes me to the

2 end of the engineering analysis. I know there were

3 some concerns with these numbers, so at this point

4 I'm happy to answer any questions on DOE's analysis.

5 MR. BROOKMAN: I would note that I noticed

6 that many of you are taking notes in the margin of

7 the slides, which I assume will be in your written

8 comments, but perhaps you wish to provide some

9 comments now as well. Rob.

10 MR. MCARVER: I don't have a specific

11 comment based on what's just been presented, but I

12 will reiterate what I said before. We and our

13 members haven't had sufficient time to look through

14 the documentation. And while I mean there has been

15 some opportunity, of course, and questions may arise

16 directly from the presentation, we'd ask for an

17 extension in the date of this hearing as well in the

18 hopes that we'd have more robust discussions. So,

19 hopefully, there will be some more input today, but I

20 can't promise that.

21 MR. BROOKMAN: Okay. Thanks.

22 MR. WATSON: So, if I could just request
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1 one comment. It seemed like there were some concerns

2 about the market changing significantly from 2012 to

3 this new set of standards. I think DOE would be

4 interested in learning more about those particular

5 concerns to see where this analysis might not match

6 up or might not be appropriate at this point because

7 based on all the information DOE had available in

8 conducting this analysis it seems to reflect the

9 current market. Rob.

10 MR. MCAVER: I'll again reiterate a point

11 that I made earlier. Had there been an opportunity

12 for direct dialogue between manufacturers and

13 DOE/Navigant I think a lot more information would've

14 been made available that would help answer that

15 question. So, I don't know the answer off the top of

16 my head, but we'd be happy to sit down with everybody

17 and go into that in much more detail. So, thanks.

18 MR. BROOKMAN: Thank you. Thanks Rob. 

19 Manfred.

20 MR. STAEBLER: This is Manfred from BSH. 

21 And this is really a remark on top of my head when it

22 comes to performance. Looking at cleaning
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1 performance and water consumption leaving drying

2 away, you know, if you look at energy you have to

3 pump water. You have to heat water and that's the

4 energy what you have. And if you want to dry the

5 dishes properly probably you need the water hotter,

6 you know, that the dishes are hotter that they dry by

7 themselves afterwards. So, the drying performance

8 somehow, you know, plays into the cleaning

9 performance. So, you know, if you look at the energy

10 available and what you can do with the energy I think

11 we have to look at the full spectrum, and this is

12 kind of missing here. But like I said, that's not a

13 technical answer. It's just an observation.

14 MR. BROOKMAN: Okay. Thank you.

15 MR. STAEBLER: And we will look deeper

16 into that, you know, when we have the time to.

17 MR. BROOKMAN: Okay. Thank you.

18 MR. EDWARDS: I'll add something to that. 

19 If you want to reduce energy in the dishwasher,

20 you're going to have to compensate somehow. It's

21 going to have to wash longer. You're going to have

22 to reduce temperatures in some phase of it. I mean
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1 if you actually take energy out of it you have to

2 compensate.

3 MR. BROOKMAN: Okay.

4 MR. EDWARDS: And it can be done with a

5 reduction in dry performance, longer wash time, and

6 things like that.

7 MR. BROOKMAN: Thank you Mike. Okay. 

8 Yes, please, Kyran.

9 MS. HOFF: Yes, Kyran Hoff from GE. The

10 teardown analysis, is that data available to us in

11 terms of models and the cost assumptions because I

12 think it's quite challenging without engaging with

13 industry to understand whether we're sourcing a part

14 or producing it in house and different labor costs,

15 and so there's a lot of assumptions that are built

16 into that. So, will that data be made available to

17 us?

18 MR. WATSON: DOE doesn't make the specific

19 data available, but during manufacturing interviews,

20 DOE tries to refine the model and determine which

21 sort of parts are purchased out-of-house, which are

22 made in house, and to determine cost premiums and
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1 things like that. So, no, the specifics aren't. I

2 think sometimes if there's big assumptions to be made

3 DOE will provide that information, but typically, no,

4 the details aren't provided.

5 MS. HOFF: Okay. And on a similar vein, I

6 think some of the technology options presented in

7 chapter 5 regarding the path for manufacturers to

8 meet these new levels, and there are some fundamental

9 flaws in those assumptions. So, I think that in the

10 teardown it appears to us that you perhaps looked at

11 higher efficiency models and made assumptions that

12 the design elements on that model was there because

13 of energy when, in fact, that is not what the

14 manufacturer -- that's not a technology that you use

15 to get there. So, as we read that chapter, there

16 were several examples of that that stood out to us,

17 so we'll provide that in our written comments; but

18 we'd be interested to know how you made the

19 assessment of what was a design option for energy

20 versus what was just simply a feature that was on a

21 higher efficiency model.

22 MR. WATSON: Sure. In the analysis, DOE
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1 definitely tried to sort those things out. So, one

2 example off the top of my head is something like a

3 stainless steel tub. I know during the 2012

4 rulemaking we also learned that that was probably

5 just a feature and not necessarily a design option

6 to improve efficiency. So, in the cost modeling

7 analysis, DOE would replace that with a plastic tub

8 for the purpose of coming up with the MPCs, so those

9 classes don't reflect the efficient models available

10 on the market now. They reflect the build up with

11 the design options. And if any of those are

12 inappropriate, that would definitely be helpful.

13 MS. HOFF: Okay. Thank you.

14 MS. HARIHARAN: This is Johanna Hariharan,

15 General Counsel. I just want to make a point here,

16 and this is just for the record, that when we talk

17 about features usually it means they separate product

18 costs. And I just really want to be careful that

19 we're not talking about features as in features that

20 would separate product classes, but simply just

21 things that are different like stainless steel tubs.

22 MR. WATSON: Thank you.
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1 MR. BROOKMAN: Okay, additional thoughts

2 here? Okay. Good.

3 (Slide shown)

4 MR. WATSON: I should've switched this

5 slide, but this is what we just went through, so I'll

6 turn it over to Camilla now.

7 MS. DUNHAM: Good morning. My name is

8 Camilla Dunham. I work at Lawrence Berkeley

9 Laboratory. I'm going to be talking about -- we're

10 turning now in the presentation to the economic

11 analyses. I'm going to be talking about the life

12 cycle cost analysis and my colleague will be talking

13 about the national impact analysis.

14 Before getting into the life cycle cost

15 analysis itself, I'm going to discuss two of the

16 inputs that would need greater explanation. The

17 first of those is the markup analysis.

18 So, the LCC is a sum of the total

19 installed cost and the lifetime operating costs. 

20 From the engineering analysis we have the engineering

21 costs -- I'm sorry -- the manufacturing costs and we

22 need to transform those manufacturing costs into
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1 consumer product prices. Markups are the multipliers

2 that make that adjustment. So, from manufacturer to

3 consumer, markups reflect each step along the

4 distribution channel.

5 For dishwashers, the distribution chain is

6 pretty straightforward. Manufacturers sell to

7 retailers who then sell to consumers. The

8 manufacturer markup we get from the Securities and

9 Exchange Commission 10-K reports for publicly-traded

10 companies. The retailer markup comes from the annual

11 retail survey. And then the consumer markup is the

12 sales tax, and we get that from the Sales Tax

13 Clearinghouse.

14 We also have baseline and incremental

15 markups. Baseline markups relate costs to price

16 prior to efficiency and include direct costs such as

17 salaries, rent, and payroll. The incremental markups

18 are applied to each efficiency level above the

19 baseline, and they include costs such as goods and

20 services that vary with efficiency, but do not

21 include direct costs.

22 (Slide shown)
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1 MS. DUNHAM: These are the markups that

2 were developed for both the standard and compact

3 product classes. So, just to back up a second here,

4 DOE welcome comment on anything presented, whether or

5 not there's a comment box requesting comment.

6 (Slide shown)

7 So, now we're going to move on to another

8 major input into the life cycle cost analysis, and

9 that is the energy and water use analysis. So, the

10 energy and water use you can see here on the slide is

11 an input into the lifetime operating costs. So, DOE

12 needs to know how much energy and water dishwashers

13 use so that they can estimate possible savings as a

14 difference between the baseline and the higher

15 efficiency levels.

16 From the engineering analysis, we get

17 energy use by efficiency level for different

18 operations, including machine energy, water heating

19 energy, and drying energy. The per cycle water

20 volume also comes from the engineering analysis. 

21 RECS and publicly available studies are other

22 sources of data that contribute to the determination
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1 of energy and water use. This slide shows the per

2 cycle energy and water use by efficiency level.

3 (Slide shown)

4 MS. DUNHAM: And the next slide provides

5 the same information. Those per cycle energy and

6 water use values were multiplied by 215, which is the

7 estimate for cycles per year.

8 Okay, I'm going to move on to the general

9 LCC discussion.

10 MR. BROOKMAN: Let's pause for just a

11 moment to see if there's any comments on all of the

12 data presented on 47 and 48. Any thoughts; what

13 about 215 cycles per year? Bijit.

14 MR. KUNDU: Bijit Kundu with Energy

15 Solutions. I know there was some discussion in the

16 NOPR document about how DOE came up with 215 cycles

17 per year, but can you briefly let us know how you

18 came to that?

19 MS. DUNHAM: Sure. There was an extensive

20 study performed by A.D. Little, which reviewed tens

21 of thousands of instances of dishwasher use, and 215

22 represents an average from the extensive work that
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1 A.D. Little did. Variability, DOE doesn't assume

2 that 215 is the one number that each household uses,

3 and so variability is introduced through the RECS

4 survey, and I'll discuss that later in another slide.

5 MR. BROOKMAN: Additional thoughts on all

6 of these energy use levels and characterizations? 

7 Okay.

8 MS. DUNHAM: Okay, so this shows all of

9 the inputs into the LCC and payback period

10 calculation. I'm going to talk about the purpose and

11 calculation method before I go into detail into the

12 other inputs.

13 So, in this analysis we look at both the

14 life cycle costs, the LCC and the payback period. 

15 The LCC is the total cost to the consumer over the

16 life of the product. The payback period is the

17 period of time needed to recover the increased

18 purchase price of the more efficient equipment.

19 The purpose of the LCC is to compare the

20 lifetime impacts between baseline efficiency levels

21 and higher efficiency products. Using a consumer

22 sample from RECS, that's EIA's Residential Energy
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1 Consumption Survey, we determined the total installed

2 cost for each efficiency level. We determine both

3 first year and lifetime operating costs.

4 The payback period divides the average

5 increase in installed cost by the average decrease

6 in first year operating costs. We calculate the LCC

7 savings by subtracting the LCC of each efficiency

8 level from the LCC of what the customer would've

9 purchased in the absence of standards.

10 DOE conducts the LCC using a Monte Carlo

11 simulation. A Monte Carlo simulation and probability

12 distributions model both the uncertainties and the

13 variabilities of the inputs, enabling DOE to identify

14 percentages of consumers who either benefit from or

15 who are negatively impacted by a proposed standard. 

16 Each Monte Carlo simulation represents 10,000 LCC

17 calculations to reduce the error brought by

18 uncertainty and variability. As mentioned before,

19 the RECS household sample forms the basis for energy

20 use and each product class is separately analyzed.

21 So, we've talked about markups. We've

22 talked about both total installed costs and lifetime
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1 operating costs. There's another input into total

2 installed cost and that is installation costs. We

3 get installation costs -- so, consumer product price

4 was discussed in the markups discussion. For

5 installation costs we get data from the RS Means

6 Residential Costs data.

7 DOE assumed that installation costs would

8 not vary by efficiency level, and so that input drops

9 away from the calculation.

10 Now, we're going to turn to operating cost

11 inputs. There are, if you remember, or you can look

12 in your handout at that flowchart. There are a

13 number of interim calculation steps. So, we need to

14 get to annual energy and water costs. So, we already

15 have the use, energy and water use, and to that we

16 multiply energy and water prices that we get from

17 EIA's Form 861 and the Raftelis/American Waterworks

18 Association Water and Wastewater Rates.

19 Energy trends come from EIA's Annual

20 Energy Outlook and the water price trends come from

21 the water and sewage rates produced by the Bureau of

22 Labor Statistics CPI or in their CPI.
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1 Repair and maintenance costs is another

2 operating cost input. And these, like installation

3 costs, are assumed to not vary with efficiency

4 level, and so these also drop away from the

5 calculation. So, here is a comment request.

6 MR. BROOKMAN: Ed Osann.

7 MR. OSANN: Yes, I'm sorry to have to take

8 you back.

9 MR. BROOKMAN: It's okay.

10 MR. OSANN: I wanted to drop back to

11 slides 47 and 48.

12 MS. DUNHAM: Can you tell me what it is?

13 MR. OSANN: The energy and water use

14 analysis.

15 MS. DUNHAM: Yes.

16 MR. OSANN: The graphics could you --

17 MS. DUNHAM: This one?

18 MR. OSANN: The charts.

19 MS. DUNHAM: Okay.

20 MR. OSANN: Yes. Could you comment a

21 little bit on the development of the origin of the

22 standby power data, the baseline?
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1 MS. DUNHAM: It's described in the fine

2 print at the bottom. So, it's assumed that each

3 cycle lasts an hour. And then on the basis of that

4 we subtract that figure from total number of hours to

5 get the standby power.

6 MR. OSANN: And what's your thinking about

7 the assignment of zero for the base case?

8 MS. DUNHAM: I'm going to let Troy handle

9 that.

10 MR. WATSON: Yes, this is Troy Watson from

11 Navigant. In our engineering analysis, we observed

12 that the baseline standard unit used

13 electromechanical controls, and the associated off

14 mode power for that unit was zero watts, so there was

15 no standby for that. And then when you switch to

16 the electronic controls at the higher efficiency

17 levels that's where you always have some sort of

18 standby power draw, and that's where the 0.5 watts

19 comes from.

20 MR. OSANN: Okay. Thank you.

21 MS. DUNHAM: Okay, I'm going to move

22 forward, with no objections.
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1 Okay, we're back to lifetime. So, to move

2 from annual energy and water costs to lifetime

3 operating costs, DOE uses a Weibull probability

4 distribution that has inputs from historical

5 shipments data and product saturation from RECS and

6 the American Housing Survey. DOE's estimated the

7 average lifetime for both product classes to be 15.4

8 years. Yes.

9 MR. BROOKMAN: Sriram.

10 MR. GOPAL: Sriram Gopal from AHAM. One

11 thing I couldn't tease out when I was going through

12 the technical support document is the relationship

13 between average lifetime and your average number of

14 cycles per year. Is there a tie-in there? You know,

15 are you saying that the average product is run for

16 whatever, 215 cycles per year for 15 years, or were

17 these calculations kind of done independent of each

18 other?

19 MS. DUNHAM: I don't believe that we

20 connected the degree of use and the lifetime of the

21 product.

22 MR. BROOKMAN: Would you suggest that?
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1 MR. GOPAL: I'm not prepared to suggest

2 anything.

3 MR. BROOKMAN: Okay. Thank you.

4 MR. GOPAL: Okay.

5 MS. DUNHAM: Okay, so now we have the

6 lifetime, so we're considering future costs. And to

7 do that we need to use a discount rate to establish

8 those costs' present value. DOE uses publicly

9 available data from the Federal Reserve for its

10 Survey of Consumer Finances to estimate consumers'

11 opportunity costs of funds related to appliance cost

12 savings and maintenance costs.

13 The discount rate value is applied in the

14 LCC to future year energy costs savings and

15 maintenance costs yielding a net LCC and LCC savings. 

16 DOE notes that the discount rate used in the LCC

17 analysis is distinct from an implicit discount rate. 

18 Basically, this is not a discount rate that we're

19 using to model consumer purchase decisions.

20 So, DOE doesn't assume that all machines

21 in use or to be purchased are at the baseline

22 efficiency level. Consumers already use and purchase
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1 products with efficiencies greater than or equal to a

2 prospective standard level and so then wouldn't be

3 affected in terms of the savings by the standard. 

4 So, a base case efficiency distribution allows a more

5 accurate estimation of consumer impacts by

6 representing different efficiency levels either

7 currently in use or to be purchased.

8 So, there's a graph in front of you where

9 you see, and on the screen they're yellow diamonds. 

10 Those are historical product annual energy use data

11 based on a mix of product efficiencies. The green

12 diamond is DOE's forecast for annual energy use for

13 the date the prospective standard would take effect,

14 which is 2019. And the blue curve shows that the mix

15 of efficiencies would level off at 280 kilowatt

16 hours 

17 a year.

18 MR. BROOKMAN: Yes, Ed.

19 MR. OSANN: Ed Osann with NRDC. What's

20 the origin of the yellow diamond sort of labeled

21 "historic data"?

22 MS. DUNHAM: AHAM's fact book, shipment
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1 information that's been provided.

2 MR. OSANN: So, those are the shipment

3 weighted performance of new products in each of those

4 years?

5 MS. DUHHAM: Shipment weighted

6 efficiencies. Correct.

7 So, here are market shares currently, or

8 when this was done last year at the different

9 efficiency levels for both standard-size dishwashers

10 and for the compact size.

11 MR. BROOKMAN: It says distribution in

12 2019.

13 MS. DUNHAM: Yes, we developed that and

14 then that is assumed to take effect in 2019.

15 There's a comment box based or directed to

16 the base case efficiency distribution.

17 (Slide shown)

18 MS. DUNHAM: And here are the LCC results. 

19 The blue rectangle shows the proposed standard, the

20 top for standard size and the bottom for compact

21 size.

22 MR. BROOKMAN: Let's just linger there on
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1 these two tables for just a moment. Questions? 

2 There's another comment box coming up here. Looking

3 at these two tables, questions, comments here?

4 (Pause.)

5 MR. BROOKMAN: Nothing additional here? 

6 Okay. I think we're probably -- yes, Ed.

7 MR. OSANN: So, just to be clear, for

8 purposes of the life cycle cost analysis and the

9 payback analysis the assumed base case shipment

10 weighted efficiency in 2019 is in the vicinity of the

11 high 280s? Am I reading your graph right on Slide

12 60?

13 MS. DUNHAM: I'm sorry. Could you repeat

14 your question?

15 MR. BROOKMAN: Going back to Slide 60?

16 MR. OSANN: The one with the graph with

17 the diamonds on it. So, for purposes of the life

18 cycle cost analysis and the payback analysis the

19 assumption is that the base case shipment weighted

20 efficiency in first compliance year, 2019, would be

21 in the high 280s?

22 MS. DUNHAM: That's correct.
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1 MR. OSANN: What is that number actually?

2 MS. DUNHAM: I don't have it off the top

3 of my head.

4 MR. OSANN: Okay. Is it in the TSD; do

5 you know?

6 MS. DUNHAM: It's in the TSD.

7 MR. OSANN: Okay. Thanks.

8 MR. BROOKMAN: And then you would do what? 

9 You had a follow-on comment, I thought.

10 MS. DUNHAM: I always get myself in

11 trouble when I do that, so I'll keep my counsel here.

12 MR. BROOKMAN: Okay. Additional thoughts

13 here, a lot of data there on Slide 63. The

14 Department has shown its intentions here. Okay,

15 nothing additional. Let's take a break. We're due

16 for a break. It's 10:25. And we'll take a 15-minute

17 break. I think most of you are familiar with the

18 procedures around here. Please wear your visitor's

19 badge or some identifier as you walk around in the

20 hallways here.

21 There's a restroom at both ends of the

22 hall. There's a coffee shop on the ground floor. 
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1 Many of you have already found it. Please go quickly

2 to get coffee, if you're going to go, and we'll

3 resume at 10:40. And those of you joining us on the

4 line, please feel free to join the conversation when

5 we resume at 10:40.

6 (Whereupon, a short recess was taken at

7 10:25 a.m.)

8 MR. BROOKMAN: So, we're going to pick up

9 where we left off with the shipments, and we're going

10 to hear from Chun Chun.

11 MS. NI: My name Chun Chun Ni. I'm with

12 LBNL. In this session, I will talk about DOE's

13 shipments and the national impact analysis.

14 (Slide shown)

15 MS. NI: The purpose of the shipment

16 analysis is to estimate shipments for dishwashers

17 during a 30-year analysis period for both base case

18 and standards case.

19 The shipments are the inputs to national

20 impact analysis and the manufacturer impact analysis. 

21 The shipment analysis relies on a range of data

22 sources, including historical shipments data and the
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1 RECS data. The shipments model considers dishwashers

2 are installed either for replacement purposes or

3 installed in new housing starts.

4 (Slide shown)

5 MS. NI: This is a flowchart of the

6 shipment analysis. DOE first estimated shipments for

7 each product class that accounts for replacement and

8 new installations. DOE then estimated shipments by

9 aggregating shipments of each product class. As

10 mentioned, the shipment analysis relies on a range of

11 data sources. For this rulemaking, DOE mostly

12 relied on the data that was submitted with previous

13 rulemaking.

14 So, for the historical shipments data, DOE

15 added 2011 and 2012 data points by using Appliance

16 Designed data report. As for the product class

17 segment, DOE used NPD data. DOE estimated that

18 standard dishwashers account for about 99 percent and

19 compact dishwashers account for about 1 percent of

20 the total market. For the replacement, DOE used the

21 dishwasher lifetime retirement function that was

22 developed in the life cycle cost analysis. DOE also
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1 used AEO 2014 to estimate installations in new

2 housing starts and dishwasher energy operating costs.

3 As for dishwasher water operating costs,

4 DOE used CPI national water price index trend. For

5 the product prices, those prices were derived from

6 LCC analysis. So, DOE's shipment analysis includes

7 two components, that is base case shipments

8 projection and the standards case shipment

9 projection.

10 After developing base case shipment

11 projection, DOE developed a standards case shipment. 

12 In other words, the shipments projected after a

13 standard is adopted. The standards case shipments is

14 developed by using the same data sources as the base

15 case shipments projection. In addition, the

16 standards case shipments account for purchase price

17 increases and operating cost savings due to a

18 standard to estimate any shipments change to the base

19 case shipments projection.

20 This table summarizes the total projected

21 shipments in selected years in the base case and in

22 each trial standard level. As you can see, DOE
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1 didn't find that any significant standards impacts on

2 dishwashers' annual shipments.

3 Here is a comment box. DOE requests

4 comments and information related to 2011 and 2012

5 data points and the market segments between standard

6 and compact dishwashers. DOE also welcomes comments

7 related to standards case shipments projection.

8 I will stop here for a while.

9 MR. BROOKMAN: Thank you. Any thoughts,

10 as requested by the comment box particularly on

11 shipments?

12 (Pause.)

13 MR. BROOKMAN: Nothing at this time. 

14 Okay.

15 MS. NI: So, I will move onto the national

16 impact analysis. The purpose of the national impact

17 analysis is to determine the national energy and

18 water savings and the national net present value over

19 a 30-year analysis period from 2019 to 2048.

20 DOE conducted this analysis by developing

21 annual series of energy, water, and economic impacts. 

22 The analysis also used shipment model, as discussed
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1 before, to estimate the total stock of residential

2 dishwashers. DOE then aggregated the costs, energy,

3 and water used in any given year and reported

4 estimates for economic impacts as changes in consumer

5 net present value in constant year dollars. DOE also

6 used the discount rates to account for the time value

7 of money. 

8 (Slide shown)

9 MS. NI: This is a flowchart of the

10 national impact analysis. The analysis relies on the

11 LCC and the shipments model to get the numbers. It's

12 basically gather all outputs from LCC and shipments

13 and those numbers feeds into the economic impacts. 

14 The analysis outputs of energy and water savings and

15 the national present value.

16 The analysis period is 30 years of

17 shipments; however, DOE did account for energy and

18 water savings and economic impacts of all those

19 shipments in the 30 years as far as their lifespan

20 lasts; therefore, the results go beyond 2048.

21 (Slide shown)

22 MS. NI: This is a summary table of the
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1 inputs used for the national impact analysis. A lot

2 of these inputs are the same as what we have

3 discussed in the LCC section. So, in addition to

4 those inputs, DOE also accounts for full-fuel cycle

5 energy using certain multipliers per OMB's guideline. 

6 DOE also used 7 percent and 3 percent discount rates

7 to discount all future expenses to the Year 2014.

8 Based on LCC and the payback period

9 analysis results, DOE then developed a trial standard

10 level for each product class. As we can see, TSL1

11 represents EL1 for standard and a baseline for

12 compact, and TSL2 represents EL3 for standard and EL1

13 for compact. TSL3 is the max tech level for both

14 product classes. For this rulemaking DOE is

15 proposing TSL2 for residential dishwashers.

16 (Slide shown)

17 MS. NI: So, this table summarizes the

18 national energy and water saving for each trial

19 standard level. As we can see, at the proposed TSL2,

20 the national full-fuel cycle savings is about 1.1

21 quads. And the national water savings is about .2

22 trillion gallons. And this slide summarizes the
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1 consumer net present value by discount rate. At the

2 proposed TSL2, consumers will save about .2 billion

3 at 7 percent discount rate and about 2 billion at 3

4 percent discount rate.

5 Here is a comment box. DOE requests

6 whether or not DOE should review the sensitivity

7 analysis for the analysis period. That's all for the

8 shipments and national impact analysis.

9 MR. BROOKMAN: Comments on all of the

10 foregoing? Yes, Bijit.

11 MR. KUNDU: Bijit Kundu with Energy

12 Solutions. I just have a question, going back to

13 Slide 77, how were the efficiency -- you know, I

14 noticed the efficiency levels for standard it goes

15 from one, three to four. How were the TSLs mapped to

16 the efficiency level, at least for standard? What

17 happened to efficiency level 2?

18 MS. NI: The TSL2 is the max net present

19 value.

20 MR. KUNDU: I guess my question was, was

21 efficiency level 2 considered like --

22 MS. NI: Okay, EL2, I think in LCC
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1 analysis the El2 tends negative savings; therefore,

2 DOE cannot take the EL2 as the trial standard level.

3 MR. KUNDU: So, an analysis was done.

4 MS. NI: I think in the LCC section. We

5 can go back, take a look at that slide. So, you can

6 see the EL2 for standard the life cycle cost saving

7 is minus two. So, there's no saving for consumers.

8 MR. KUNDU: Okay, I see. I understand.

9 MS. ARMSTRONG: Can I chime in here for a

10 second?

11 MR. KUNDU: Yes.

12 MS. ARMSTRONG: I mean, basically, what we

13 do is we mix efficiency levels for different product

14 classes and we evaluate different policy scenarios,

15 which we deem with our special term "trial standard

16 level." We do analyze each efficiency level, so you

17 could look at the national impact results of the

18 efficiency level you're seeking in the TSD. And if

19 it's something that you think DOE should -- you know,

20 if there is a policy scenario that we didn't analyze

21 in the NOPR that's a different combination of

22 efficiency levels that you think we should, you're
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1 welcomed to comment on that.

2 MR. KUNDU: Okay. I just wanted some

3 insights and that's helpful. Thank you.

4 MR. BROOKMAN: So, that was Ashley

5 Armstrong. Thank you Ashley. Additional thoughts

6 here, comments here before we go back to where we

7 left off? Lots of results. Comments on these

8 slides.

9 (Pause.) 

10 MR. BROOKMAN: Okay.

11 MS. NI: Okay, I will turn to Nicole from

12 Navigant.

13 MR. BROOKMAN: Thank you.

14 MS. BUCCITELLI: Hi, I'm Nicole Buccitelli

15 from Navigant. I'll be presenting on the

16 manufacturing impact analysis.

17 The purpose of the manufacturing impact

18 analysis or MIA is to assess the impacts of potential

19 energy standards on manufacturers, and in doing this

20 also estimate impacts on manufacturer subgroups such

21 as small businesses that may be disproportionately

22 burdened. And the MIA also examines cumulative
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1 regulatory impacts, impacts to direct employment,

2 competition, and manufacturing capacity in the

3 industry.

4 In terms of methodology, the Government

5 Regulatory Impact Model or GRIM is used to analyze

6 industry cash flows and estimate industry net present

7 value at the base case and at each possible standard

8 level. Interviews with manufacturers are used to

9 refine inputs to the GRIM and develop subgroup

10 analyses and also in order to address qualitative

11 issues that are covered in the MIA.

12 In a little bit more detail, the MIA can

13 be broken down into three phases of analysis. In

14 phase one, DOE builds from the information developed

15 in the market and tech assessment, supplementing this

16 information with additional market research in order

17 to create a profile for the industry. During the

18 phase, DOE also identifies important issues that

19 require further investigation.

20 In phase two, DOE develops a preliminary

21 industry cash flow model using the information

22 compiled in phase one and initial inputs from the
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1 engineering and shipments analyses. DOE also

2 prepares an interview questionnaire which will serve

3 as the basis for discussions with manufacturers.

4 In phase three, DOE interviews

5 manufacturers and uses information obtained from the

6 interviews to refine the GRIM and to quantitatively

7 assess impacts on employment, competition, and

8 manufacturing capacity, and cumulative regulatory

9 burden.

10 Just to point out, DOE did attempt to

11 contact manufacturers as a part of the MIA, and was

12 not able to schedule interviews. So, for this NOPR,

13 DOE relied on information gathered from manufacturer

14 interviews conducted in support of the May 2012

15 direct final rule.

16 For the 2012 direct final rule, DOE

17 interviewed manufacturers representing approximately

18 80 percent of residential dishwasher sales. At the

19 time, key issues included impact of potential

20 standards on wash performance, drying performance,

21 cycle time, and noise levels. Manufacturers felt

22 that these impacts could, in turn, lead to higher
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1 rates of service calls, rejection of poorly

2 performing products in the marketplace and changes in

3 usage behavior.

4 Manufacturers also raised concerns over

5 test procedures, citing such issues as the multitude

6 of test procedures currently in the field and the

7 lack of performance matrix in the DOE test procedure. 

8 Manufacturers of both baseline and higher efficiency

9 products anticipated an increase in competition in

10 the industry following amended standards. 

11 Manufacturers whose market shares was largely

12 attributed to baseline products expected to see

13 either the removal of features from higher efficiency

14 units as a means to cut costs, to maintain a low cost

15 minimally compliant product offering or the

16 disappearance of entry level models as they're forced

17 to add other features and costs in line with current

18 higher efficiency products.

19 Finally, manufacturers expressed concern

20 about cumulative regulatory burdens they face as

21 dishwashers are only one of a suite of products they

22 produce.
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1 MR. BROOKMAN: I believe there are key

2 issues that you would wish to note here. Yes, Ed.

3 Osann?

4 MR. OSANN: Yes, I just want to come back

5 to the comment that DOE was unable to -- sought to

6 schedule interviews with manufacturers, but was

7 unable to I think that was your word. Does that mean

8 that -- what does that mean? Does that mean that the

9 manufacturers wouldn't take the appointments or that

10 window of -- the time window was too narrow to

11 arrangement those, or what does it mean?

12 MS. BUCCITELLI: DOE contacted

13 manufacturers and did not receive any comments about

14 wanting to participate in interviews on the part of

15 manufacturers.

16 MR. OSANN: So, DOE contacted

17 manufacturers to seek an interview.

18 MS. BUCCITELLI: Mm-hmm.

19 MR. OSANN: Okay. And the time period for

20 that, just broadly speaking in terms of was that

21 early 2014?

22 MS. BUCCITELLI: The contacting began
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1 probably in August and I think the last attempt was

2 made in October.

3 MR. OSANN: Thank you.

4 MS. BUCCITELLI: During interviews

5 conducted for the 2012 direct final rule, DOE

6 received feedback supporting the calculated 1.24

7 baseline markup for residential dishwashers. For the

8 current rulemaking, DOE continued to use the 1.24 as

9 the baseline markup. DOE modeled two markup

10 scenarios, the preservation of gross margin as a

11 percent of revenue scenario and the preservation of

12 operating profit scenario.

13 The preservation of gross margin as a

14 percent of revenue markup scenario assumes that the

15 baseline markup of 1.24 is maintained for all

16 products in the standards case. This scenario

17 represents the upper bound of industry profitability

18 as manufacturers are able to fully pass on

19 additional costs due to the standards to their

20 customers.

21 The preservation of operating profit

22 scenario is similar to the flat markup scenario with
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1 the exception that in the standards case minimally

2 compliant products lose a fraction of the baseline

3 markup. This scenario represents the lower bound of

4 industry profitability as manufacturers accept a

5 lower margin as a percent of revenues in attempts to

6 maintain a price competitive entry level product.

7 In addition to the two markup scenarios,

8 DOE modeled two conversion cost scenarios for this

9 NOPR. First, DOE scaled the product and capital

10 conversion cost estimates divulged for the May 2012

11 direct final rule to reflect the new efficiency

12 levels for each product costs. Additionally, DOE

13 developed a separate capital conversion cost scenario

14 using the engineering cost model developed for this

15 NOPR.

16 For this estimate, DOE identified the

17 design pathways considered in the engineering

18 analysis, estimated the cost of the changes in

19 production, equipment to implement each design option

20 and aggregated these costs to reflect the

21 industry-wide investment using an estimate of the

22 number and efficiency level of product platforms or
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1 families currently marketed by each manufacturer.

2 Given that the DOE modeled two markup

3 scenarios and two conversion cost scenarios, there

4 was a total of four different scenarios analyzed in

5 the GRIM. The results of the four scenarios are on

6 this slide and in the next slide. The two tables on

7 this slide represent INPV results using the estimates

8 of product and capital conversion costs scaled from

9 the 2012 direct final rule with the preservation of

10 gross margin percent markup scenario in the top table

11 and the preservation of operating profit markup

12 scenario in the bottom table.

13 Because standard dishwashers represent

14 over 90 percent of product shipments, changes to this

15 product class contribute to the majority of the

16 impacts to INPV across all TSLS.

17 And I'll show the next and then I'll talk

18 about the results for that.

19 (Slide shown)

20 MS. BUCCITELLI: The two tables on this

21 slide use estimates of capital conversion costs based

22 on the engineering cost model, again with the
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1 preservation of gross margin percent markup scenario

2 on the top and the preservation of operating profit

3 markup scenario on the bottom.

4 At TSL1, DOE estimates impacts on INPV to

5 range from a change of negative 7.4 percent to

6 negative 13.7 percent. In all scenarios, the impact

7 on INPV stems largely from the conversion costs

8 required to switch production lines from

9 manufacturing baseline units to those meeting EL1 for

10 standard dishwashers.

11 The design options proposed to meet TSL1

12 relate primarily to minimizing the amount of wash

13 water through spray arm optimization, filter

14 improvement, and enabling greater control over the

15 wash water temperature. Total conversion costs are

16 estimated to range from 73.7 million to 118 million.

17 At TSL2, DOE estimates impacts on INPV to

18 range from negative 17.7 percent to negative 34.7

19 percent. For standard dishwashers, the improvements

20 required to meet TSL2 included exchanging a heated

21 drying system for a condensation drying system

22 further optimizing the hydraulic system and
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1 incorporating a flow meter, temperature sensor and

2 soil sensor to finely tune water consumption,

3 temperature, and the drying cycle.

4 For standard dishwashers only 3.7 percent

5 of shipments currently meet standards specified by

6 TSL2. Total conversion costs are estimated to range

7 from 233.7 million to 281.4 million.

8 Finally, at TSL3, the max tech level for

9 both product classes, DOE estimates INPV to range

10 from a change of negative 24 percent to negative 40.9

11 percent, the impact of INPV is most severe at TSL3

12 because less than 1 percent of shipments meet this

13 level. Because so few products exist at this level,

14 nearly all manufacturers would face complete redesign

15 for products to meet the standard.

16 DOE expects manufacturers of standard

17 dishwashers would incorporate similar design options

18 at TSL3 as at TSL2 extended to include more highly

19 optimized control strategies that would further

20 reduce the wash and rinse water temperatures. 

21 Additionally, DOE expects that manufacturers of

22 baseline compact dishwashers in countertop
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1 configuration would exit the market for these

2 products at TSL3.

3 DOE requests comments on the industry

4 product and capital conversion costs estimated in

5 this NOPR. DOE also requests comments on any impacts

6 to direct employment and also estimates of cumulative

7 regulatory burden.

8 MR. BROOKMAN: And it's worth noting that

9 manufacturers have access to nondisclosure agreements

10 with Navigant, so they send -- make sure that you're

11 aware that they can send information to Navigant that

12 will never see the light of day, so if you wish to

13 contribute that to the analysis here. Additional

14 thoughts, comments here?

15 (Pause.)

16 MR. BROOKMAN: Okay.

17 MS. DUNHAM: Okay, we're coming into the

18 home stretch here.

19 (Slide shown)

20 MS. DUNHAM: So, these are referred to as

21 downstream analyses, and I'm going to step through

22 these very quickly or at a reasonable pace. And
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1 again, any comments or information provided would be

2 appreciated.

3 So, the consumer subgroup analysis is to

4 look at parts of the consumer population that may be

5 adversely affected by a standard for dishwashers. We

6 looked at senior-only households and low-income

7 households. I thought there was a chart here, but

8 there's not. You can see a chart in the TSD in

9 chapter 11, showing that the impacts are not

10 noticeably different for the subgroup populations as

11 compared to the total population.

12 So, moving on to the emissions analysis,

13 DOE looks at emission reductions from the proposed

14 energy conservation standards. This includes both

15 power plant emissions and upstream emissions called

16 the full-fuel cycle. We've produced results using a

17 time series of energy savings and employ EIA's NEMS,

18 the National Energy Modeling System.

19 (Slide shown)

20 MS. DUNHAM: These are results for the

21 proposed trial standard level two. The emissions

22 monetization analysis uses the most current social
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1 cost of carbon values that were developed by

2 interagency process, and they're used in all of the

3 rules that DOE performs for the appliance standards. 

4 You can see that 2013 values here. We also monetize

5 the NOx emissions using average values from the

6 literature.

7 (Slide shown)

8 MS. DUNHAM: Here's a request for comment

9 on the social cost of carbon values used. 

10 For the utility impact analysis, DOE

11 estimates the changes in electric installed capacity

12 and generation resulting from amended standards. 

13 This is the same method used in the emissions

14 analysis. It's based on a time series of energy

15 savings and uses the NEMS model. The TSD -- I

16 believe it's chapter 14 -- has these results.

17 The employment impact analysis looks at

18 indirect employment impacts. The manufacturer impact

19 analysis looked at direct employment impacts. For

20 the employment impact analysis, we used ImSET, that's

21 the Impact of Sector Energy Technologies, and it

22 shows the net labor or market impacts resulting from
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1 a standard.

2 The last analysis is the regulatory impact

3 analysis. It addresses the potential for

4 non-regulatory approaches to supplant or augment

5 energy conservation standards to improve the energy

6 efficiency or reduce energy consumption of

7 dishwashers covered under this rulemaking.

8 MR. BROOKMAN: Let's proceed to the final

9 slide.

10 (Slide shown)

11 MR. BROOKMAN: I think we said this

12 morning that we would entertain any final comments as

13 we moved towards closure here in the meeting today. 

14 And now we've gone through all the material. Any

15 additional thoughts, any final comments here before I

16 turn it over to Bryan for his concluding remarks? 

17 Yes, Rob.

18 MR. MCARVER: I just had one quick

19 question. Johanna, you mentioned earlier regarding

20 the process improvement rule that it's DOE's

21 interpretation that it's guidance and the

22 particulars of the rule don't necessarily have to be
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1 followed when appropriate. Correct?

2 MS. HARIHARAN: Yes, that's correct. We

3 put out guidance in 2010 saying which parts of the

4 process improvement rule we would not follow, and one

5 of them is in order to make rulemakings go faster,

6 that we would, when appropriate, go straight to the

7 proposed rulemaking, which is what we did this time.

8 MR. MCARVER: Okay. Thanks. So, I guess

9 my question is what makes it appropriate in this

10 circumstance, if we could better understand that that

11 would be helpful.

12 MS. HARIHARAN: Well, I don't know the

13 particulars of the exact decision, but it's up to us,

14 so I can't really comment on that further.

15 MR. MCARVER: Okay.

16 MR. BROOKMAN: Additional comments here,

17 closing remarks, other issues that anybody wishes to

18 bring to the floor.

19 MR. STAEBLER: This is Manfred Staebler

20 from BSH. Just made a note, you know, when it came

21 there was no response from manufacturers when asked,

22 you know, shocked me a little bit because that's
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1 normally not the case. And I would like, you know,

2 to understand, first of all, internally what

3 happened. Was it forgotten? Did it go to the wrong

4 person, or sometimes it can come in -- I mean I was

5 working a long time in engineering. And if you're in

6 the middle of a project and have to deliver results

7 to meet your production date then the last thing you

8 want to think about is answer a questionnaire from

9 DOE.

10 So, I'd like to understand personally what

11 happened internally, but I think that's normally not

12 or should not be the case that you don't get a

13 response from the manufacturers. So thank you.

14 MR. BROOKMAN: Okay. Thank you.

15 MS. ARMSTRONG: This is Ashley Armstrong

16 from DOE. And I think we would agree. We do

17 typically get a very good response from the AHAM

18 manufacturers. And just generally speaking, DOE has

19 a very good relationship working with AHAM and its

20 members, and even those appliance manufacturers that

21 are not members of AHAM also impacted by our rules.

22 Good news is, yes, Rob we went straight to
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1 NOPR, but there's still plenty of opportunity here

2 for us to engage and work together. So, I apologize

3 for being late to the meeting. I've heard we've

4 gotten a good deal of feedback today. And we may

5 not have gotten it right with our proposal. Really

6 what's driving our analysis that you see so far is

7 data and so a key to that is engaging with

8 manufacturers and other interested parties about

9 getting data that maybe the Department did not have

10 its first time, or getting different data, if you do

11 have it, that will help us inform our decisions as we

12 set up for the next stage of this rulemaking going

13 forward.

14 So, we hope that you will take this

15 opportunity, and as you work through your internal --

16 I'm not sure, from the DOE perspective, we care why

17 you weren't able to engage, but we hope that you will

18 use this opportunity to engage now. We're open to

19 setting up those manufacturing interviews now. We

20 are open to having those conversations, and we hope

21 you will be receptive to that.

22 MR. BROOKMAN: Yes, Rob.
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1 MR. MCARVER: I'll second that motion. 

2 Yes, generally, AHAM and our members and DOE have a

3 very good working relationship and we're certainly

4 willing to participate in those discussions now and

5 look forward to providing more information than has

6 been made available in the past to help with moving

7 forward in the rulemaking process.

8 MR. BROOKMAN: Thank you. Other

9 concluding remarks? Ed Osann.

10 MR. OSANN: Actually, this is a question

11 as opposed to a concluding remark. And it was during

12 the discussion of the MIA analysis. And as working

13 through the description of the impacts at each TSL

14 there was also mention made of features and

15 components that were assumed to be employed by

16 manufacturers to meet those TSLs. Those didn't

17 appear in the slides and I just wondered if the

18 speaker can kind of cross-walk us back to the TSD as

19 to where the delineation of those specific design

20 features.

21 MR. WATSON: This is Troy Watson from

22 Navigant. Each of the design options we considered
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1 at the different efficiency levels those are all

2 outlined in chapter 5 of the TSD.

3 MR. OSANN: Five? Okay.

4 MR. WATSON: And then I think it ties into

5 the MIA, chapter 12 of the TSD. So, there are

6 discussions of the design options in both chapters. 

7 The engineering one will give the technical side of

8 it, and the MIA will focus on the conversion cost

9 impacts.

10 MR. OSANN: Thank you.

11 MR. BROOKMAN: Bijit.

12 MR. KUNDU: Bijit Kundu, Energy Solutions. 

13 Just a point of clarification with the last dialogue

14 that was going on, if DOE's analysis changes

15 significantly or changes even insignificantly based

16 upon manufacturer input and discussions with

17 interested parties what would be the next step of

18 this rulemaking. I know, typically, it goes from

19 NOPR to a final rule.

20 MS. HARIHARAN: This is Johanna Hariharan. 

21 It depends, but if the results do change

22 significantly, we can issue a supplemental as a
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1 proposed rulemaking.

2 MS. ARMSTRONG: But we also have other

3 ways of issuing revised analysis without an

4 additional proposal too, so it really just depends on

5 -- we've done that before like issuing a note of "For

6 comment." There are a variety of ways we can do it. 

7 If we have significant difference in analysis, we

8 typically put it out for comment again.

9 MR. KUNDU: Okay.

10 MS. ARMSTRONG: It just depends.

11 MR. KUNDU: So, there other ways it would

12 be open to public comment.

13 MS. ARMSTRONG: Yes.

14 MR. KUNDU: Great. Thank you.

15 MR. BROOKMAN: Yes, Steve.

16 MR. LEYBOURN: Steve Leybourn from AHAM. 

17 Circling back to the question I asked earlier, but

18 also building on that, would it be possible to, as

19 DOE's done before and Navigant's done before, to

20 provide, you know, the tests results in more of a

21 side-by-side fashion. Make it a table fashion rather

22 than presenting them spliced out, you know, comparing
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1 two at a time because, you know, there's the water

2 consumption, the energy consumption, and clean

3 performance. If you're looking at two of the three

4 at a time, you're not necessarily getting the full

5 picture.

6 MR. BROOKMAN: He would like to see one

7 feature, one variable displayed altogether?

8 MR. LEYBOURN: I'm thinking if any you

9 recall like what was done at the last clothes dryer

10 proposal there was a list of task units and then the

11 various energy or whatever measurements displayed for

12 each of those results.

13 MR. BROOKMAN: I just wanting to make sure

14 we follow you.

15 MS. ARMSTRONG: I think we follow him. We

16 understand him.

17 MR. BROOKMAN: Okay.

18 MR. WATSON: Troy Watson again. In terms

19 of splitting out, I guess it's a question of whether

20 the data is split out in more detail in the TSD or

21 the TSD data could be split out even more; is that

22 what you're asking?
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1 MR. LEYBOURN: Yes. Yes, so see testing

2 "A" through whatever, the energy consumption, the

3 water, clean --

4 MS. ARMSTRONG: I think we're going to

5 talk about it. He's asking can we take the data in

6 the TSD that's shown right now in different tables

7 and put it in a aggregated tabulated format so that

8 he can compare all the units we tested in a summary

9 type fashion is what I translate the ask.

10 MR. BROOKMAN: Thank you Ashley.

11 MS. ARMSTRONG: We can talk about it. I

12 don't think there's an issue. The data is already

13 out there. It's just a matter of can someone in

14 Excel.

15 MR. BROOKMAN: Okay. And we have a

16 comment from someone who's joining us online, Nick

17 Gillespie, I believe. Nick, please unmute your phone

18 and let's hear from you.

19 MR. GILLESPIE: Yes, I think -- can you

20 hear me okay?

21 MR. BROOKMAN: Yes, you sound good.

22 MR. GILLESPIE: Okay, good. I haven't
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1 heard that in a long time.

2 MR. BROOKMAN: No, you do sound good.

3 MR. GILLESPIE: Thank you. That's good. 

4 I'm a little bit late because I've had my hand up for

5 a little bit. I know you guys were talking, so it's

6 not going to be easy. I would just add to what Rob

7 had said already about the manufacturer interview.

8 I don't want to beat a dead horse, and

9 kudos to Ashley for what she's put forth on that. I

10 was just, for the record, just stating I don't know

11 what the miscommunication was, but for Whirlpool at

12 least, and I obviously can't speak for other

13 manufacturers, but Ben Barrington and Navigant asked

14 Whirlpool for an interview on August 26. And we

15 indicated a willingness to participate and were ready

16 to go in September.

17 Ben indicated that the NOPR had already

18 been submitted at that point, that the OMB had more

19 questions and then I never heard from Ben again. 

20 And I don't know what happened, and I'm not blaming

21 Ben. I don't think Ben's there anymore, but I was

22 just saying there was some kind of a breakdown there,
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1 so I just wanted to point that out. But again, I

2 guess after hearing Ashley and Rob talk about it and

3 put forth what they have I mean I think that's dead

4 on. I just want to indicate that Whirlpool is ready

5 to take on whatever interviews, visits I mean with

6 commercial clothes washers and other rulemaking then

7 Navigant, if they should come up to the

8 manufacturers' facilities, we welcome that. We've

9 already actually spoken with Judy, so I just want to

10 reiterate how we would welcome it. We look forward

11 to it. And as Ashley said, we're ready to provide

12 data to help with this. So, that's all.

13 MR. BROOKMAN: Thank you, Nick. Okay.

14 MR. GILLESPIE: Thank you.

15 MR. BROOKMAN: Additional thoughts before

16 we close out this meeting?

17 (Pause.)

18 MR. BROOKMAN: So, I'll turn it back to

19 Bryan Berringer for his closing remarks.

20 MR. BERRINGER: Thank you. The slide has

21 been up there so people on the Webinar, the

22 information as far as comments, where to send them
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1 to, the email is there,

2 ResDishwashers2014STD0021@ee.doe.gov, my -- Brenda's

3 information as far as you want to mail something to. 

4 Again, we welcome comments. There was a request

5 from AHAM for a 60-day extension. We will get back

6 with you on that. Actually, Ashley's prepared to

7 answer that now.

8 MS. ARMSTRONG: So, we are going to extend

9 the comment period. I don't know if we're going to

10 do 60 days yet or not. I don't know the exact

11 timeframe, but we are still having discussions about

12 what timeframe it might be, but we are going to

13 extend it. And we're hoping that that extension will

14 be our good faith and your good faith will be

15 scheduling interviews ASAP.

16 MR. McARVER: Absolutely.

17 MS. ARMSTRONG: Thank you.

18 MR. BERRINGER: Okay, then at that point

19 I'd just like to thank everybody participating today

20 and on the Webinar, and look forward to working with

21 everybody. Thank you.

22 MR. BROOKMAN: Thanks. Safe travels
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1 everyone.

2 (Whereupon, the meeting was concluded at

3 11:25 a. m.)

4

5

6

7

8

9

10

11

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13

14

15

16

17

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A

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basically 5:20 11:16
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25:15 26:14 68:18

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94:12,15 95:16

104:22 105:4

commercial 17:7

104:6

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compact 18:15

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complete 9:16 90:14

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57:18 58:19,21,21

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Institute 3:3 7:17
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preservation 86:10

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46:17 56:3 96:17

99:18 100:8

U

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UL 3:22

ultimate 21:13

ultrasonic 34:14

unable 85:5,7

unacceptable 19:2,5

uncertainties 63:12

uncertainty 63:18

underestimates

21:2

understand 16:12

22:14,16 23:4

55:13 80:8 95:10

96:2,10 101:16

understanding 14:8

22:19

understood 20:2

undertook 20:13

unilaterally 15:5

unit 40:8 46:2,3

47:15,19 48:4,10

48:14 49:8 66:12

66:14

United 1:7

units 36:20 37:1

38:21 40:5,7 44:6

45:16 49:7,14,16

84:14 89:9 101:10

102:8

universe 45:5

unmute 10:7 49:3

102:17

unnecessarily 21:4

update 29:19

upper 86:17

upstream 92:15

urge 16:11

usage 84:3

use 8:19 19:3,19

27:9,13 42:10

51:18 56:14 60:9

60:10,13,17 61:1

61:2,6,21 62:6

63:20 64:15,15

65:13 67:20 68:7

68:21,22 69:7,10

69:12 86:8 88:21

97:18

useful 14:13 39:18

uses 62:2 67:3 68:8

83:5 92:22 93:15

usually 32:17 48:10

57:17

utility 26:5 34:6

41:14 42:5 93:10

V

valid 20:22 30:19

value 27:20 28:3

68:8,13 76:18

77:5,6,15 79:1,19

82:7

values 61:6 93:1,4,5

93:9

variabilities 63:13

variability 48:8

62:1,3 63:18

variable 101:7

variation 47:16

48:16

variations 48:21

variety 100:6

various 16:10 24:16

101:11

vary 59:20 64:8

65:3

vast 17:21

vein 56:5

Vermont 3:14

version 30:5

versus 46:21 56:20

Vice 13:9

vicinity 71:10

view 16:16

views 21:16

visitor's 72:18

visits 104:5

vital 16:9

volume 60:20

voluntary 29:10

W

waive 15:6

walk 72:19

want 5:18 12:12

24:8 26:14,15

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96:8 103:8 104:4

104:9 105:3

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wanting 20:16

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wants 10:12 13:2

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wash 54:21 55:5

83:20 89:12,15

90:20

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washers 104:6

washing 34:13,14

Washington 1:11

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water 19:3 27:10,13

34:12 35:1,4,6,8

35:15,16,18,19,19

35:21 38:13 42:13

43:7 44:20 46:18

47:5,9 48:11

51:18 54:1,3,3,5

60:9,10,12,18,19

61:1,2,6 64:14,15

64:16,18,20,21

65:13 67:2 75:3,4

76:18,21 77:3,14

77:18 78:18,21

89:13,15 90:2,20

101:1 102:3

Waterworks 64:17

Watson 2:22 7:11

7:11 28:17,19,20

29:2 31:14 32:6

32:14,22 33:4,9

33:16 36:2 39:7

39:13 40:1,14,17

41:20 43:6,22

45:7,12,15,20

46:6,9,13,15,22

47:2,7 48:7 49:6

50:15 51:4 52:22

55:18 56:22 57:22

58:4 66:10,10

98:21,21 99:4

101:18,18

watts 66:14,18

way 44:5 45:19

51:16

Wayne 4:4

ways 100:3,6,11

we'll 5:21 8:4,14,17

9:11 13:7 24:7,16

26:8,17,21,22
Notice of Proposed Rulemaking (NOPR) For Residential Dishwashers

February 5, 2015

202-347-3700 Ace-Federal Reporters, Inc. 866-928-6509

Page 120

36:2 38:7 56:17

72:16 73:2

we're 5:10,20 8:11

11:17,19 12:3

21:1 24:9 25:13

25:16 26:1,7,11

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28:8 33:15 49:5

55:13 57:19 58:9

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91:17 97:18 98:3

102:4 104:11

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27:4 41:10 63:21

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web 10:4,11,13,19

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Webinar 3:10 4:1

5:15,16 10:1

11:15 28:15

104:21 105:20

Webmaster 9:10

49:3

website 12:15

weeks 17:5

Weibull 67:3

weighted 70:3,5

71:10,19

welcome 10:1 31:6

39:14 60:4 104:8

104:10 105:4

welcomed 81:1

welcomes 12:17

76:6

welcoming 5:10

well-performing

17:22

went 12:5 19:6 58:5

96:22

weren't 97:17

Whirlpool 3:20 4:4

103:11,14 104:4

who've 9:11 24:22

wide 48:16

willing 43:21 98:4

willingness 103:15

Wilson 4:13 11:1

window 85:10,10

wish 8:10 10:16

41:18 49:3 52:8

85:2 91:12

wishes 8:9 95:17

wondered 98:17

Woodford 4:11 11:1

word 85:7

words 75:12

work 6:5,13 21:10

58:8 61:22 97:2

97:15

working 6:8 96:5,19

98:3,12 105:20

world 14:18

worth 91:8

would've 14:6 53:13

63:8

wouldn't 33:10

34:18 51:19 69:2

85:9

written 10:14 12:5

12:20,22 21:7

52:7 56:17

wrong 96:3

X

Y

year 27:9 31:12

32:4,5,17 61:7,13

61:17 63:3,6

67:14,16 68:14

69:17 70:8 71:20

77:3,5 78:7

years 33:3 67:8,16

70:4 75:21 77:16

77:19

yellow 69:9,20

yielding 68:15

Z

zero 66:7,14

0

0.5 66:18

1

1 74:19 90:12

1.1 78:20

1.24 86:6,8,15

10 18:10,16 25:11

32:17

10-K 59:9

10,000 63:16

10:25 72:16 73:7

10:40 8:18 73:3,5

10:45 8:18

1000 1:9

11 92:9

11:25 106:3

110-day 17:11

118 89:16

12 46:5 99:5

13.7 89:6

14 93:16

15 67:16

15-minute 72:16

15.4 67:7

17 12:21 21:22

17.7 89:18

18 5:15

1975 25:1

1994 25:7

2

2 9:12 78:21 79:2,3

79:17,21

2.14 27:21

2010 19:11 23:22

25:7 30:5 95:3

2011 19:11 74:15

76:4

2012 17:10 19:10,16

29:18 30:16,18

34:11 49:11 53:2

57:3 74:15 76:4

83:14,16 86:5

87:10 88:9

2013 25:8 32:18

93:4

2014 31:17,20 32:13

32:15,16 38:4

39:4,5 75:1 78:7

85:21

2015 1:12 5:6

2019 27:19 69:14

70:12,14 71:10,20

76:19

203 27:13

204 28:4

2048 27:19 76:19

77:20

215 61:6,13,16,21

62:2 67:16

23 27:19

233.7 90:7

234 27:9 40:13

24 90:10

26 103:14

280 69:15

280s 71:11,21

281.4 90:7

3

3 8:5 27:21 29:15

30:22 78:6 79:3

3.1 27:10,14

3.7 90:4

30 25:8 47:14 77:16

77:19

30-year 73:17 76:19

34.7 28:4 89:18

4

4 8:6 42:11 46:19

40.9 90:10

430.2 25:11

47 61:12 65:11

48 61:12 65:11

5

5 1:12 5:6 46:22

49:21 51:7 56:7

99:2

6

6 22:9

60 21:22 71:12,15

105:10

60-day 17:3,13 20:4

24:6,10 105:5

63 72:13

7

7 27:20 78:6 79:3

7.4 89:5

73.7 89:16

75-day 17:8

77 79:13

8

80 83:18

861 64:17

8E-089 1:10

9

9 17:1

9:00 1:14 5:2

90 18:13 88:14

99 74:18
1 21 

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