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Neal R. Gross and Co., Inc.

 U.S. DEPARTMENT OF ENERGY

 + + + + +

 NOTICE OF PROPOSED RULEMAKING FOR

 REFRIGERATED BEVERAGE VENDING MACHINES

 TEST PROCEDURE

 + + + + +

 PUBLIC MEETING

 + + + + +

 TUESDAY

 SEPTEMBER 16, 2014

 + + + + +

 The Public Meeting met in Room GH019, 1000 Independence Avenue, S.W.,

Washington, D.C., at 9:20 a.m., Doug Brookman, 

Meeting Facilitator, presiding.

PRESENT

DOUG BROOKMAN, Public Solutions, Inc., 

Moderator

ASHLEY ARMSTRONG, Department of Energy

SARAH BUTLER, Department of Energy

DAVE CASE, Department of Energy

JIM COLLINS, Automated Merchandising 

 Systems, Inc.

DOUGLAS DRENTEN, Crane Merchandising 

 Systems*

DAVID EDWARDS, Navigant Consulting

JEREMY GREEN, The Glover Park Group

LARRY HIEB, SandenVendo America, Inc.

CHRISTOPHER LAU, Navigant Consulting

RONALD MAJETTE, Department of Energy

SUBARNA MALAKAR, Crane Merchandising 

 Systems*

MICHAEL MAU*, Royal Vendors, Inc.
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JOANNA MAUER*, Appliance Standards Awareness

Project (ASAP)

SCOTT MITCHELL, Southern California Edison

MICHELLE NIEMEYER, Pacific Northwest 

 National Laboratory

ELIZABETH NOLL, Natural Resources Defense 

 Council

ELAINA PRESENT, Navigant Consulting

CATHARINE CYR RANSOM, The Glover Park Group

GREGORY ROSENQUIST, Lawrence Berkeley 

 National Laboratory

LOUIS STARR, Northwest Energy Efficiency 

 Alliance

MVUALA SUAMI, Natural Resources Canada 

COLLIN WEBER, Navigant Consulting

SARAH WIDDER, Pacific Northwest National 

 Laboratory

ROLANDO WILLIAMS, SandenVendo America, Inc.

SCOTT YOUNG, Lawrence Berkeley National 

 Laboratory

* = Participating telephonically
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 TABLE OF CONTENTS

 Page

Welcome, Introductions and

Opening Statements

Doug Brookman & Ashley Armstrong . . . . . . . 4

Regulatory History & Scope

Elaina Present . . . . . . . . . . . . . . . .11

Test Procedure Amendments: Appendix A

Sarah Widder . . . . . . . . . . . . . . . . .15

Test Procedure Amendments: Appendix B

Sarah Widder . . . . . . . . . . . . . . . . 121
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1 P-R-O-C-E-E-D-I-N-G-S

2 (9:19 a.m.)

3 MR. BROOKMAN: Okay, let's begin.

4 Good morning, everyone, and

5 welcome. Are we connected to the internet? 

6 Yes?

7 COURT REPORTER: Yes.

8 FACILITATOR BROOKMAN: Okay. Good

9 morning, everyone. Welcome. This is the

10 public meeting on the test procedure Notice of

11 Proposed Rulemaking for Refrigerated Beverage

12 Vending Machines. Today is September the

13 16th, 2014 here at the Forrestal Building in

14 Washington, D.C..

15 My name is Doug Brookman from

16 Public Solutions. It is so nice to see you

17 this morning.

18 Ashley will have welcoming

19 remarks, Ashley Armstrong.

20 MS. ARMSTRONG: Hi, everybody. My

21 name is Ashley and I work for the Department

22 of Energy. I oversee the test procedure
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1 development. 

2 I would like to welcome you. We

3 are running a little bit behind. So, we are

4 going to skip some of the intro type stuff but

5 you have in your packets. But I encourage you

6 to participate. This is what this meeting is

7 all about. Ask questions. Give us feedback. 

8 We are here to explain to you what

9 we did, our proposals and why. And we are

10 really looking forward to your data and

11 feedback and your analysis.

12 So, welcome and Doug will begin

13 the meeting.

14 MR. BROOKMAN: Than you. We

15 always start with introductions. And I will

16 start to my immediate left and just say your

17 name and organizational affiliation.

18 We do have microphones working in

19 the room. I'm told they work fairly well but

20 I would ask everyone to speak up.

21 MR. STARR: I'm Louis Starr,

22 Northwest Energy Efficiency Alliance.
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1 MS. NOLL: Elizabeth Noll,

2 National Resources Defense Council.

3 MR. SUAMI: Mvuala Suami, Natural

4 Resources Canada.

5 MR. MITCHELL: Scott Mitchell,

6 Southern California Edison, representing the

7 California IOUs and also the Chair of ASHRAE

8 Committee SPC 32.1

9 MR. HIEB: Larry Hieb, SandenVendo

10 America.

11 MR. WILLIAMS: Rolando Williams,

12 SandenVendo America.

13 MR. COLLINS: Jim Collins,

14 Automated Merchandising Systems.

15 MR. CASE: Dave Case, DOE.

16 MS. BUTLER: Sarah Butler, DOE.

17 MR. MAJETTE: Ron Majette, Project

18 Lead, DOE.

19 MS. ARMSTRONG: Ashley Armstrong,

20 DOE.

21 MR. WEBER: Collin Weber, Navigant

22 Consulting.
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1 MR. EDWARDS: David Edwards,

2 Navigant Consulting.

3 MR. LAU: Chris Lau, Navigant

4 Consulting.

5 MS. PRESENT: Elaina Present,

6 Navigant Consulting.

7 MS. WIDDER: Sara Widder, Pacific

8 Northwest National Lab.

9 MR. YOUNG: Michelle Niemeyer,

10 Pacific Northwest National Laboratory.

11 DR. COLLER: Scott Young, Lawrence

12 Berkeley National Laboratory.

13 FACILITATOR BROOKMAN: And over

14 here?

15 MS. SIACA: Siobhan Siaca, Senator

16 Whitehouse.

17 MS. ARMSTRONG: Thank you.

18 MR. ROSENQUIST: Gregory

19 Rosenquist, Lawrence Berkeley National

20 Laboratory.

21 FACILITATOR BROOKMAN: All of you

22 received a packet of information, I hope. 
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1 There are more copies here if you need them. 

2 The agenda is on page two, if you will take a

3 peek at that, actually page three. 

4 Immediately following

5 this agenda review, there is an opportunity

6 for brief opening statements by anyone who

7 wishes to do so. Issues of concerns, thins

8 you wish to raise here at the outset.

9 Following that, a Regulatory

10 History and Scope. Immediately following

11 that, Test Procedure Amendments, Appendix A. 

12 We will take a break mid-morning, around about

13 10:45, 10:30, something like that.

14 Following the return from the

15 break, Test Procedure Amendments, Appendix B. 

16 And then discussion or presentation plus

17 discussion on Small Business Impacts. An

18 opportunity for closing remarks. Any issues

19 that you wish to raise at that point, around

20 about 11:55 A.M.

21 Today's meeting on test

22 procedures, is really the first half of a two-
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1 meeting day that is proposed. 

2 And then after lunch, the

3 Department is also going to host the Energy

4 Conservation Standards Preliminary Analysis

5 for Beverage Vending Machines, the standard

6 setting portion of that. So, that will

7 happen. We have two meetings running

8 concurrently and we have a lot of material

9 that we hope to get through this morning

10 before that commences.

11 So, that is the general plan.

12 Questions or comments on the general plan? I

13 see none.

14 I would ask for your

15 considerations. Please speak one at a time. 

16 Please say your name for the record each time

17 you speak. There will be a complete

18 transcript of this meeting. If you could be

19 concise and share the air time, there is lots

20 to be said I am certain. 

21 Please keep the focus here. If

22 you haven't turned your cell phone on silent
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1 mode, please do that at this point. Limit the

2 sidebar conversations.

3 Webinar participants, we welcome

4 you. The Department of Energy is trying hard

5 to make these meetings totally accessible to

6 all.

7 Webinar participants, please turn

8 your phone on mute. Please raise your hand to

9 be recognized to speak and we will see if we

10 can hear you in the room. And if not, we will

11 find some way to get your comments written and

12 included in the conversation here.

13 That is the preliminary stuff. If

14 you will take a peek in your packet, just take

15 a peek at slide five. Those listening via the

16 webcast, I have covered that material.

17 The purpose of the public meeting,

18 I think is well-understood.

19 MS. ARMSTRONG: Yes, we are just

20 going to actually skip right ahead to slide

21 13, only because the ones we had before, just

22 talk about generally our time line and that
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1 kind of stuff.

2 Elaina, are you going to start?

3 MS. PRESENT: Okay, so regulatory

4 history and authority. The regulatory history

5 for this rulemaking starts with the Energy

6 Policy and Conversation Act of 1975, which set

7 forth a variety of provisions to improve the

8 energy efficiency of various products and

9 equipment.

10 Part B of Title III provides for

11 the "Energy Conservation Program for Consumer

12 Products Other than Automobiles." And the

13 part of that program directed DOE to establish

14 energy conservation standards for beverage

15 vending machines.

16 Manufacturers of covered equipment

17 must use the prescribed DOE test procedure as

18 the basis for certifying to DOE that their

19 equipment complies with the applicable energy

20 conservation standards adopted under EPCA, and

21 when making representations about the

22 efficiency of the equipment.
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1 DOE also must use this test

2 procedure to determine whether the equipment

3 complies with any relevant standards

4 promulgated under EPCA.

5 EPCA additionally requires that

6 any test procedures prescribed or amended

7 shall be reasonably designed to produce test

8 results which measure energy efficiency,

9 energy use, or estimated annual operating cost

10 of a covered unit of equipment during a

11 representative average use cycle or period of

12 use and shall not be unduly burdensome to

13 conduct.

14 Additionally, EPCA requires that

15 at least once every seven years, DOE review

16 its test procedures for all covered products

17 and either amend the test procedures or

18 publish a determination in the Federal

19 Register not to amend them. This requirement

20 is the reason DOE is undertaking the current

21 rulemaking.

22 EPCA further provides a definition
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1 for refrigerated bottled or canned beverage

2 vending machine. The provided definition is: 

3 "The term 'refrigerated bottled or canned

4 beverage vending machine means a commercial

5 refrigerator that cools bottled or canned

6 beverages and dispenses the bottled or canned

7 beverages on payment."

8 The BVM 2009 Final Rule further

9 defines equipment classes within beverage

10 vending machines. The defined classes are

11 Class A, is a refrigerated bottled or canned

12 beverage vending machine that is fully cooled

13 and is not a combination vending machine. 

14 Class B is any beverage vending

15 machine not considered to be Class A and also

16 not a combination vending machine.

17 And combination vending machines

18 are beverage vending machines that also have

19 separate non-refrigerated volumes for vending

20 other non-"sealed beverage" merchandise.

21 The current DOE test procedure was

22 established by a final rule on December 8,
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1 2006, which we will refer to as the 2006 BVM

2 test procedure final rule. It incorporated by

3 reference two standards, the ANSI -- it should

4 be ANSI/ASHRAE Standard 32.1-2004, "Methods of

5 Testing for Rating Vending Machines for

6 Bottled, Canned, or Other Sealed Beverages,"

7 as the primary method of test, with a few

8 minor modifications.

9 It also adopted ANSI/AHAM HRF-1-

10 2004 to calculate the refrigerated volume of

11 beverage vending machines.

12 In this Notice of Proposed

13 Rulemaking, DOE is proposing to reorganize the

14 BVM test procedure into a new Appendix A and

15 Appendix B.

16 Appendix A would be effective 30

17 days after publication of any test procedure

18 Final Rule in the Federal Register and would

19 contain several clarifications and amendments

20 to the DOE test procedure.

21 Appendix B would be effective with

22 the compliance of any amended standards
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1 promulgated as a result of the current Energy

2 Conservation Standards rulemaking. And it

3 would contain all of the clarifications and

4 amendments incorporated in Appendix A, as well

5 as provisions to account for the impact of low

6 power modes.

7 And now, Sarah.

8 MS. WIDDER: Thanks, Elaina.

9 FACILITATOR BROOKMAN: And just to

10 be clear, we will take questions and comments

11 as we are going along here. There are

12 specific comment boxes but if you are moved to

13 ask a question during the course of

14 presentations, feel free to do so.

15 Sarah.

16 MS. WIDDER: Thank you, Doug and

17 thank you, Elaina. So, Elaina gave a good

18 overview of the type of equipment that we are

19 going to be talking about today. And a

20 general overview of the appendices, how DOE

21 has split the appendices into Appendix A,

22 which is intended to be used immediately with
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1 existing energy conservation standards and

2 then Appendix B that contains a few additional

3 provisions that won't be required until any

4 energy conservation standards are promulgated

5 as a result of the rulemaking we would like to

6 get to this afternoon.

7 So, in light of that, I am going

8 to move fairly quickly but feel free to

9 provide comments, obviously, on anything that

10 we are presenting. There will be issue boxes

11 throughout the presentation and then you are

12 also -- and those correspond to the issue

13 boxes in the NOPR.

14 So, to get started, Appendix A

15 includes several clarifications. DOE believes

16 that all of these clarifications do not affect

17 the measured energy consumption of covered

18 beverage vending machines, which is a Class A,

19 Class B and combination machines that Elaina

20 presented earlier. I have this list of 11

21 clarifications we will go through in detail in

22 the subsequent slides but this is just a
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1 summary of the general type of clarifications

2 and amendment.

3 Because DOE believes that these

4 clarifications do not affect the measured

5 energy use of covered beverage vending

6 machines, manufacturers would use this

7 Appendix A, as Elaina noted, effective 30 days

8 after publication in the Federal Register to

9 certify compliance with existing energy

10 conservation standards and they would also be

11 included in Appendix B.

12 So, the first amendment in this

13 case that DOE is proposing as part of the NOPR

14 is to update the referenced method of test. 

15 Since the 2006 test procedure Final Rule

16 adopted ASHRAE 32.1 2004 and the AHRAM HRF-1

17 for refrigerated volume, both those standards

18 have been updated by their relevant industry

19 groups and are actually currently under

20 revision at this time. But there is a 32.1

21 2010 version available from ASHRAE and an AHAM

22 2008 version available from AHAM.
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1 DOE reviewed both these methods. 

2 The ASHRAE method was only minorly updated to

3 incorporate some of the changes that made the

4 test procedure, the ASHRAE test method more

5 consistent with DOE's adopted test procedure

6 Final Rule. And the equipment classification

7 that DOE adopted was part of the Energy

8 Conservation Standard Final Rule in 2009. So,

9 it essentially aligned that ASHRAE test

10 procedure with what DOE had done.

11 It also incorporated in specific a

12 section of the AHAM HRF-1-2004 standard as an

13 Appendix C for the measurement of volume,

14 which is what DOE had done in their 2006 en

15 masse test procedure Final Rule. DOE found

16 that method to be more appropriate than the

17 method contained within the ASHRAE standard. 

18 And so referencing the AHAM method, ASHRAE has

19 done the same now. So, that is consistent

20 with DOE's existing test procedure for

21 beverage vending machines.

22 The AHAM method simplifies the
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1 previous AHAM 2004 version. It combines

2 Sections 4, 5, and 6 for measuring

3 refrigerated volume of refrigerators,

4 freezers, and refrigerator/freezers into one

5 section. AHAM used to be very complicated and

6 have a lot of specific requirements about what

7 was included, what was excluded. And it is a

8 lot more simple and straightforward of a

9 method now.

10 However, because those changes and

11 specific inclusions or exclusions might change

12 the refrigerated volume of specific beverage

13 vending machines, DOE is electing or is

14 proposing in this NOPR to update the reference

15 method of test to ASHRAE 32.1-2010, including

16 the reference of Appendix C for measurement of

17 refrigerated volume, which would then remove

18 the incorporation by reference of AHAM HRF-1-

19 2004 for the measurement of refrigerated

20 volume.

21 So, this is the first request for

22 comment from interested parties. DOE is
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1 requesting comment on updating the referenced

2 method of test, specifically on updating the

3 reference method of test for measurement of

4 refrigerated volume to Appendix C contained in

5 ASHRAE, rather than the HRF-1 test procedure

6 and also any differences or comparison between

7 the HRF-1-2008 method and Appendix C. DOE, in

8 review, believes that the Appendix C contained

9 in 32.1-2010 is more appropriate and more

10 consistent with the method that is currently

11 used to establish measurement of refrigerated

12 volume for BVMs and requests comments on these

13 items.

14 FACILITATOR BROOKMAN: Comments

15 here, particularly on measurement of

16 refrigerated volume.

17 MS. WIDDER: Now, we're in written

18 comments. DOE also appreciate just

19 affirmative comments in agreeing with DOE's

20 proposed method. But in light of time, we can

21 sort of move forward.

22 The second amendment that DOE is
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1 considering as part of Appendix A is

2 eliminating the requirement to test beverage

3 vending machines at 90 degrees Fahrenheit and

4 65 percent plus or minus 5 relative humidity. 

5 And both of these ambient test conditions are

6 contained within ASHRAE 32.1 standard.

7 And there is no specific exclusion

8 in DOE's test procedure of either of these

9 ambient conditions. So, both of them are

10 inherently required in the DOE test procedure. 

11 However, in the 2009 DOE energy conservation

12 standards final rule, only the 75 degree

13 Fahrenheit and 45 percent relative humidity

14 ambient condition, and I am going to refer to

15 that as just the 75 degree Fahrenheit ambient

16 condition; the relative humidity requirements

17 sort of goes with it, only that ambient

18 condition was referenced in the rule and only

19 testing at the 75 degree ambient condition is

20 used for compliance with DOE's existing Energy

21 Conservation Standard. The 90 degree

22 Fahrenheit condition is not used. And,
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1 therefore, DOE is considering removing the

2 requirement to test beverage vending machines

3 at 90 degree Fahrenheit from the DOE test

4 procedure and requests comment on that

5 proposal.

6 FACILITATOR BROOKMAN: Louis

7 Starr.

8 MR. STARR: Louis Starr from NEEA. 

9 I have a question. Are most manufacturers

10 just going to test to 32.1 anyway, and that

11 information they would gather? Would that

12 information also be available to when they do

13 the DOE test procedure or would they be doing

14 those tests at separate times, specifically?

15 MS. WIDDER: So, I will let

16 manufacturers add to this. My understanding

17 is that it would be half, just logically how

18 you would test a beverage vending machine, it

19 would be incremental, another incrementally

20 like 50 percent additional burden or 100

21 percent additional burden, because you would

22 have to condition the chamber and stabilize
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1 the equipment the same way that you would for

2 the 75 degree ambient conditions. So, it is

3 not -- it is a significant incremental burden. 

4 Manufacturers may do that for voluntary

5 programs like utility incentives, if that

6 information was of interest or of interest to

7 their customer. But it would no longer be

8 required from a DOE perspective and I don't

9 believe that that information is currently

10 reported. It may be in their manufacturing

11 literature but certainly not to DOE.

12 FACILITATOR BROOKMAN: Yes,

13 please.

14 MR. SUAMI: Mvuala Suami from

15 Natural Resources Canada. I have a question. 

16 The reason not considering 90 degree, I don't

17 want to jump to a combination machine but for

18 Class A, some of them can be converted to a

19 combination machine and divide the room to

20 unrefrigerated and refrigerated. But DOE

21 methodology is to test the worst case.

22 My question is for Class B and
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1 some of them are used outside. And the

2 temperature of 90 was designed for those. And

3 the worst case would be to test them at high

4 temperature.

5 So, why for Class A that can

6 become converted into combination we test

7 according to the worst case but for these

8 Class B that are used outside, we don't test

9 according to the worst case?

10 MS. WIDDER: So, EPCA's

11 requirement of DOE in creating test procedures

12 is that they not necessarily be worst case but

13 they are representative of the performance of

14 the equipment under an average cycle of use.

15 And so 75 degrees ambient was

16 selected by DOE because although some Class B

17 equipment can be installed outside, the

18 majority, based on DOE's research, the

19 majority of equipment, 85 percent, I think of

20 Class B machines based on the information we

21 have are installed outside and that 75 degree

22 ambient condition --
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1 MS. ARMSTRONG: Inside.

2 MS. WIDDER: Inside, sorry. Thank

3 you for that. Are installed inside. So, only

4 a small percentage are outside.

5 And that 75 degree ambient

6 condition is representative of that inside

7 environment that a lot of equipment are

8 exposed to and is also, I mean it allows for

9 a comparison between all equipment, a

10 consistent test result that can be compared

11 across equipment, which is the intent of the

12 metric to determine which equipment are more

13 or less efficient.

14 I don't know if that answers your

15 question.

16 FACILITATOR BROOKMAN: We do have

17 additional comments. The proposal to

18 eliminate the requirement to conduct testing

19 at 90 degrees Fahrenheit.

20 Let me know, I would hope to hear

21 from industry here, but if you think this is

22 a sensible proposal.
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1 Yes.

2 MR. MITCHELL: Scott Mitchell from

3 Southern California Edison. So, I am chairing

4 the ASHRAE Committee that is in the process of

5 revising the test method as well. And that

6 group has kind of decided the same thing, that

7 we would get rid of this test condition as

8 well.

9 So, as a consensus, and there

10 hasn't been any push back on that at all,

11 frankly, we are just waiting for the process.

12 FACILITATOR BROOKMAN: Thank you,

13 Scott. That is helpful. Do you wish to

14 comment? No?

15 Louis.

16 MR. STARR: I have a question

17 about it. I was kind of curious. So, if

18 ASHRAE eliminates that, basically, they

19 maintain it at 32.1 but it is not a DOE test

20 procedure. It would seem that, I mean people

21 would skip testing it for the ASHRAE 32.1, you

22 would just do the DOE test procedure.
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1 So, it seems like by not aligning

2 those two, it potentially would create more

3 people going towards the DOE test procedure

4 and skipping the 32.1. So, I am kind of

5 curious why ASHRAE was -- kind of what their

6 thought process was there.

7 MR. MITCHELL: I think it is very

8 close to what Sarah was just sharing in that

9 it was a test that was required by the test

10 method but the information was not actually

11 being used for anything. And there is also

12 concerns that that condition doesn't

13 necessarily represent the average energy use

14 that is required. That is kind of an outlier

15 condition and yes, it is good to know that

16 information but, as far as using that for an

17 annual energy consumption or something like

18 that, that information really isn't used.

19 FACILITATOR BROOKMAN: Thank you,

20 Scott.

21 Additional comments here before I

22 move on? Moving on.
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1 MS. WIDDER: Okay, the third

2 clarification in this case that DOE wanted to

3 make more explicit or proposes to make more

4 explicit in the DOE test procedure is the

5 application of the DOE test procedure to

6 combination beverage vending machines and

7 specifically how to configure combination

8 beverage vending machines for testing.

9 DOE believes that the current test

10 procedures and the amended test procedure as

11 proposed in this NOPR are both appropriate for

12 the evaluation of refrigerated volume,

13 vendible capacity, and energy use of

14 combination beverage vending machines, with a

15 few clarifications about how to configure the

16 machine.

17 Specifically, the refrigerated

18 compartment of the combination beverage

19 vending machine would be the compartment that

20 we are most concerned with, since that is the

21 compartment that is performing both of the BVM

22 functions, vending and refrigerating. So,
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1 only that compartment would be considered in

2 the determination of refrigerated volume,

3 while the vendible capacity would still be

4 representative of the entire vendible volume

5 of the combination beverage vending machine,

6 both the cooled compartment and the non7 refrigerated compartment.

8 Only the refrigerated compartment

9 of the combination vending machine would be

10 fully loaded with standard test packages and

11 standard products during the energy

12 consumption test. And thus, only those

13 temperatures from within the refrigerated

14 compartment would be considered but any

15 lighting or other energy-consuming features in

16 the non-refrigerated compartment would still

17 be fully energized to best represent the

18 energy use of the equipment as installed in

19 the field, in a representative manner.

20 One thing I will note that the

21 gentleman from Natural Resources Canada

22 commented on earlier is a combination beverage
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1 vending machine is explicitly a beverage

2 vending machine that cannot be configured as

3 a Class A or a Class B. And so to the extent

4 that a specific beverage vending machine model

5 can be configured as a Class A and fully

6 cooled, that will be a Class A equipment. And

7 a combination beverage vending machine would

8 only be a beverage vending machine that has in

9 its configuration both refrigerated and non10 refrigerated volumes.

11 So, DOE requests comment on the

12 application of the DOE, the existing and

13 proposed DOE test procedure to combination

14 beverage vending machine.

15 FACILITATOR BROOKMAN: So, we will

16 take comments. Okay.

17 MS. WIDDER: Great. So, the next

18 clarification that DOE is proposing to make

19 more explicit in the DOE test procedure is

20 specific requirements around the loading of

21 test packages. The current BVM test procedure

22 requires equipment to be loaded with the
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1 maximum quantity of standard product, with

2 standard test packages in each next-to-be3 vended position. And these figures at the

4 bottom show specifically where that would be

5 for typical Class A and typical Class B

6 machines. 

7 A typical Class A machine will

8 have a glass front and will be fully cooled

9 such that all of the products along this

10 vertical axis can be purchased by the customer

11 or the consumer, in this case. And thus, all

12 of these front, the products in the front

13 would be standard test packages with

14 thermocouples and these would be standard

15 products.

16 A Class B machine is typically a

17 vertical style stack machine and the standard

18 test packages would go at the bottom of the

19 stack.

20 Refrigerated beverage vending

21 machines may be available in a variety of

22 configurations and may be configured to vend
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1 other refrigerated merchandise. DOE is

2 proposing that the members clarify the DOE

3 test procedure that is for equipment that is

4 available for a variety of product storage

5 configurations should be configured like we

6 were talking about earlier with the difference

7 between combination Class A equipment with the

8 max -- to hold the maximum of sealed beverages

9 that it is capable of accommodating. 

10 So, to the extent that beverage

11 vending machines can be configured with a

12 number of different types of spirals or

13 horizontal rows, depending on what your

14 customer wishes to vend, that you would

15 configure the beverage vending machine to vend

16 the maximum number of sealed beverages that it

17 is capable of accommodating per manufacturer 

18 specifications and that the performance of

19 beverage vending machines that differ only in 

20 placement and type of shelving may be

21 represented as a single basic model for the

22 purposes of compliance with DOE's energy
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1 conservation standards.

2 And just to add on to that, if

3 manufacturers wish to make representations

4 about the differences in energy consumption

5 that might be associated with differences in

6 shelving, the manufacturers could elect to

7 certify those different shelving

8 configurations as different basic models but

9 that is not required.

10 Further, DOE is proposing to

11 clarify the standard product that would be

12 loaded into these machines to make it more

13 consistent across industry and test labs. 

14 Based on some testing that DOE has had done,

15 it is DOE's experience that there is a little

16 bit of variability among test labs in what

17 they fill machines with to determine the

18 energy consumption of covered beverage vending

19 machines. 

20 Section 5 of ASHRAE, as

21 incorporated by reference currently requires

22 that the standard product shall be a 12-ounce
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1 can for machines that are capable of

2 dispensing 12-ounce cans and a standard

3 product for machines that can't. You know

4 whatever is specified by the manufacturer for

5 equipment that can't vend cans. And it has no

6 requirements around what that can should be

7 filled with.

8 DOE is proposing to clarify in two

9 ways the construction of standard products. 

10 First, machines that are capable of vending

11 20-ounce bottles are becoming more and more

12 common. So, DOE is proposing to adopt a

13 requirement that machines capable of vending

14 20-ounce bottles be configured with 20-ounce

15 bottles. That is retaining the ASHRAE

16 requirement that beverage vending machines

17 capable of vending 12-ounce cans vend 12-ounce

18 cans and then also retaining the flexibility

19 that DOE or that ASHRAE had previously had for

20 machines that are not capable of holding 12-

21 ounce cans or 20-ounce bottles to be the

22 product specified by the manufacturer because
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1 there is a lot of milk cartons or other things

2 that beverage vending machines could be

3 configured to vend. And it is important that

4 we provide direct -- that we cover all of

5 those options.

6 The other requirement or

7 specification that DOE is proposing here is

8 the density of the liquid that is used to fill

9 the cans. This can affect the thermal mass

10 within the space and so DOE, as opposed to

11 selecting a specific liquid which would be

12 more restrictive on manufacturers, DOE is just

13 electing to specify a density and a tolerance

14 around that density that can be established

15 really easily with a scale and a beaker or a

16 volume measurement of some sort.

17 DOE selected this density range

18 because based on looking out at literature

19 about density of liquids, it covers most test

20 fluids currently in use. This includes DO

21 water 50-50, glycol/water mixture, most

22 liquids that would already be vended so, Coke,
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1 juice. I'm not sure about dairy products but

2 a lot of liquids that could currently be used

3 to test beverage vending machines would fit in

4 this density requirement.

5 DOE is requesting comments on

6 these clarifications around the

7 characteristics of the standard product and

8 the loading of beverage vending machines to

9 hold the maximum number of sealed beverages,

10 and specifically those standard products that

11 DOE is proposing.

12 FACILITATOR BROOKMAN: Comments

13 here? No comments here.

14 MS. WIDDER: Okay. This third

15 clarification goes with the two previous

16 clarifications. With analyzing and proposing

17 clarifications to the specification of the

18 standard product, DOE also looked at the

19 specifications of standard test packages that

20 are standard products that have been modified

21 to contain a thermocouple in the center of

22 mass.
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1 Currently, Section 3 of the ASHRAE

2 32.1 test method that is incorporated by

3 reference, and this language is retained in

4 the 2010 version, defines the standard test

5 package, as I mentioned, a standard product

6 that has been altered to include a

7 temperature-measuring instrument at its center

8 of mass. There is also tolerance requirements

9 around that temperature measuring instrument.

10 After clarifying the

11 specifications for the standard product, DOE

12 finds that there is no additional

13 clarification necessary to the standard test

14 package but requests comment on that finding.

15 FACILITATOR BROOKMAN: Are

16 clarifications necessary or are these

17 sufficient? I see some heads nodding but that

18 doesn't show up on the record.

19 It would be useful to get a

20 comment or two, I think. Okay, proceed.

21 MS. WIDDER: Written comments are

22 also appreciated.
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1 The next clarification in this

2 case, and I have tried to be clear throughout

3 which of these are clarifications to the

4 existing test procedure or accommodating more

5 explicit language into the DOE test procedure

6 and which of those are actually amendments

7 that just don't change the energy consumption

8 of covered equipment.

9 In this case, it is another

10 clarification. The test procedure currently

11 does not provide specific instructions about

12 how to determine the next-to-vend beverage

13 temperature. In ASRAE 32.1, the specific

14 language as listed here on the screen, there

15 is a table in the standard that basically says

16 that throughout tests, that 36 plus or minus

17 1 should maintained throughout the test. And

18 there has been some ambiguity in the field

19 about what that throughout test really refers

20 to, about whether it is a condition in which

21 the average next-to-vend temperature in each

22 standard test package is etween 37 and 35
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1 degrees Fahrenheit temporally throughout the

2 test and in each package or averaged across

3 the packages throughout the test or is an

4 average across space and time. Throughout the

5 test means taking temperatures maintained in

6 those standard test packages, each standard

7 test package throughout the test and averaging

8 all of the data that is collected during the

9 test. And then that value has to lie between

10 36 plus or minus 1, between 35 and 37 but

11 variations during the test procedure can

12 exceed those tolerances in that second option.

13 DOE discussed these options in the

14 Framework document and received several

15 comments from interested parties about how

16 testing is currently done in industry and how

17 it is interpreted in the field today. A lot

18 of -- many interested parties noted that it

19 was impractical and unnecessarily rigorous and

20 really burdensome to think that a plus or

21 minus 1 degree Fahrenheit tolerance could be

22 maintained in each test package throughout the
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1 test temporally, just due to current equipment

2 designs, how the products are refrigerated. 

3 There is just variations that would occur

4 within the machine naturally, as the equipment

5 was designed to operate that would make the

6 standard test package exceed those balances.

7 DOE agrees with commenters that

8 the average next-to-vend temperature should be

9 both a spatial and a temporal average. This

10 is consistent with the way other commercial

11 refrigeration equipment is treated in the

12 Department's test procedures and regulations

13 to clarify that DOE is proposing to adopt this

14 additional definition, which is also

15 consistent with the term and definition that

16 is used for other commercial refrigeration

17 equipment.

18 Integrated average temperature

19 means the average temperature of all standard

20 test package measurements in the next-to-vend

21 beverage position take during the test,

22 expressed in degrees Fahrenheit.
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1 DOE requests comment on the

2 proposed definition and on whether the

3 proposed definition aligns with the standard

4 practice in industry or if any manufacturers

5 have been maintaining their standard test

6 package, temperature requirements to other

7 specifications.

8 FACILITATOR BROOKMAN: Jim?

9 MR. COLLINS: Jim Collins,

10 Automated Merchandising Systems.

11 Has DOE made any consideration of

12 the rate of sampling of those temperatures

13 throughout the test?

14 MS. WIDDER: The rate of -- like

15 how frequently temperature --

16 MR. COLLINS: How frequently do

17 you sample?

18 MS. WIDDER: -- measurements are

19 taken? I believe that there are

20 specifications in 32.1 that are 

21 MS. ARMSTRONG: Once every three

22 minutes.
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1 MS. WIDDER: Yes, I believe.

2 FACILITATOR BROOKMAN: I didn't

3 hear what was said.

4 MS. ARMSTRONG: If memory serves,

5 it is once every three minutes.

6 MS. WIDDER: I should have a copy

7 of it with me.

8 MS. ARMSTRONG: It's okay, we can

9 look it up.

10 MS. WIDDER: But anyway should we. 

11 I guess that is my question to you. Our

12 assumption right now is that the current

13 standard requires once every three minutes,

14 roughly. That is off the top of our head. We

15 can check it for you. But should we? Should

16 we require something more often or less or

17 more frequent?

18 MR. MITCHELL: Scott Mitchell,

19 California Edison. I don't think the current

20 one has it specified.

21 MS. WIDDER: Okay.

22 MR. MITCHELL: We are talking
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1 about that and I think we have agreed on one

2 minute as being easily achievable.

3 MS. WIDDER: Okay.

4 MR. MITCHELL: But one of the

5 other issues, the definition says it would

6 have to be measured in each next-to-be-vended

7 positions. For the glass-front machines that

8 have many, many products, that can get quite

9 burdensome. So, we were investigating the use

10 of the sampling mechanism to maybe get half or

11 40 percent or something of the visible

12 products and substitute that for measuring all

13 of the individual products.

14 And that may also help with one of

15 the other issues we are going to talk about

16 next, which is feeding the cables, the

17 rotation cable to the refrigerated space.

18 MS. WIDDER: Well, so DOE would

19 appreciate written comments on those specific

20 amendments that ASHRAE is considering for

21 their testing criteria.

22 MS. ARMSTRONG: So this is Ashley
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1 from DOE. What is your timetable? I have a

2 feeling you have finished your --

3 MR. MITCHELL: Man, that would

4 have been nice if DOE finished.

5 (Laughter.)

6 MR. MITCHELL: We were initially

7 trying to finish by January. I don't think

8 that is likely anymore and it looks like it

9 would be at least June maybe through October

10 of next year before we are able to even have

11 something done.

12 MS. ARMSTRONG: So, that is

13 comparable to our time line. I think my

14 request at this point would be if there are

15 specific provisions that you guys have done a

16 lot of work and make a lot of progress that

17 you would like DOE to consider as part of this

18 rulemaking, if actually you would consider

19 just submitting comments. They had done that

20 previously where they hadn't been able to

21 finish their process.

22 MR. MITCHELL: Okay.
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1 FACILITATOR BROOKMAN: Okay,

2 additional comments? No additional comments.

3 MS. WIDDER: Okay. The next

4 clarification that DOE is considering in this

5 NOPR is a definition for "fully cooled." As

6 Elaina presented earlier, the main

7 distinguishing criterion between Class A and

8 Class B equipment is whether the equipment is

9 fully cooled. However, fully cooled is not

10 currently defined.

11 Based on previous discussion

12 around the equipment class definitions, the

13 intent is that fully cooled equipment would be

14 actively maintaining 36 plus or minus 1

15 throughout the refrigerated space; whereas, a

16 not fully cooled equipment or zone-cooled

17 equipment would be directing that refrigerated

18 air at a portion of refrigerated space. This

19 is typical in the Class B stack machines,

20 where only those selections at the bottom of

21 the stack are going to be purchased by

22 customers and are actively cooled and the rest
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1 of the stack is not actively cooled. However,

2 some heat transfer will obviously occur within

3 the refrigerated space.

4 In the BVM Framework document, DOE

5 considered a definition of fully cooled that

6 required each item in the machine or each

7 standard test package to be maintained at an

8 average temperature within two degrees of the

9 average next-to-vend beverage temperature.

10 So, that is a very strict

11 requirement and interested parties commented

12 as such. That there is Class A equipment that

13 cannot, similar to the discussion we just had,

14 cannot maintain that tight of a temperature

15 tolerance throughout the machine, either

16 vertically or horizontally within the spiral.

17 Based on the comments received,

18 DOE is proposing the following definition for

19 fully cooled. I will just read it aloud.

20 Fully cooled means a condition in

21 which the refrigerated system of a beverage

22 vending machine cools products throughout the
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1 entire refrigerated volume of a machine,

2 instead of being directed at a fraction or a

3 zone of the refrigerated volume, as measured

4 by the average temperature of the standard

5 test packages and the furthest from the next6 to-vend positions being no more than 10

7 degrees Fahrenheit above the integrated

8 average temperature of the standard test

9 packages.

10 So, breaking that into pieces,

11 this first part of fully cooled refers to the

12 intent of fully cooled, which is whether or

13 not the equipment is intended to cool the

14 entire refrigerated volume or a fraction or a

15 zone. However, that is not quantifiable

16 language. And so from an enforcement

17 perspective and so that there can be

18 consistency and like a line in the sand so DOE

19 can determine Class A or Class B equipment

20 where there might be some confusion, there

21 needs to be a test in a clear, unambiguous

22 determination criteria to figure out if you
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1 are a Class A or a Class B.

2 So, that is where the second part

3 comes from. The idea is, and I think I have

4 some diagrams here -- oh, this is just -- yes,

5 we need a clear unambiguous criteria to

6 determine the appropriate equipment class.

7 So, here are some pictures that

8 gave us a sense of what that bottom part is

9 getting at. DOE is proposing that standard

10 test packages would also be placed at the

11 furthest from next-to-vend beverage positions,

12 which in this shelf-style machine would be at

13 the back four corners of the equipment and

14 that the average of the spatial and temporal

15 average of these yellow furthest from next-to16 vend standard test packages would be compared

17 to the integrated average temperature, which

18 we just defined, of the traditional standard

19 test packages in the machine. And if those

20 temperatures were more than 10 degrees apart,

21 then this would be a zone-cooled machine and

22 if they are less than 10 degrees apart, this
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1 is a fully cooled machine.

2 Similar for a stack-style machine,

3 the furthest from next-to-vend standard test

4 package positions would go at the top of the

5 stack, furthest away from the standard test

6 packages at the bottom of the stack. And if

7 the difference between those two averages is

8 less than or equal to 10 degrees, then that

9 equipment is fully cooled.

10 DOE requests comment on the

11 definition of "fully cooled." Oh, the one

12 other thing that is worth noting, on this

13 side, I don't know about the other side, but

14 this is an option verification test. So, DOE

15 is not proposing to require these yellow

16 furthest from next-to-vend standard test

17 package positions be done in every DOE test. 

18 That data does not need to be submitted to

19 DOE. This is a test that manufacturers and

20 DOE can do to verify equipment classification. 

21 But it will not be required for a full and

22 complete test, conduct of the DOE test
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1 procedure.

2 So, this is an option test. It is

3 not required but it is what DOE will use to

4 establish equipment classifications from an

5 enforcement testing perspective. That is one

6 other thing that is worth noting.

7 So, with that, DOE requests

8 comment on the definition of "fully cooled"

9 and the optional verification test procedure,

10 both the requirements in it and the fact that

11 it is optional.

12 FACILITATOR BROOKMAN: Comments?

13 MR. HIEB: Yes, Larry Hieb,

14 SandenVendo America.

15 FACILITATOR BROOKMAN: Larry,

16 please say your name for the record.

17 MR. HIEB: Larry Hieb.

18 FACILITATOR BROOKMAN: Thank you.

19 MR. HIEB: My concern with this

20 proposal would be that it does allow for the 

21 manufacturers, I guess, to reconfigure what

22 would normally be a glass-front vending
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1 machine with fully cooled definition to be a

2 zone cooled unit, if we were able to more

3 target the cooled air at the next-to-vend

4 packages and, therefore, allow a higher than

5 10 degree differential between the last-to6 vend products and, therefore, take advantage

7 of a higher energy allotment or allowance for 

8 the Class B machines in what would normally be

9 a Class A machine.

10 MS. WIDDER: That is correct. The

11 standards are currently under verbiage. So,

12 that is just something to keep in mind.

13 MS. ARMSTRONG: This is Ashley

14 from DOE. That comment is great.

15 Our intention with this is that we

16 want to come up with a way. We have had

17 manufacturers come to us and say you have

18 distinctions for Class A and Class B machines

19 but we have noticed some products kind of

20 doing just what you discussed, perhaps being

21 implemented in the field as Class A machines

22 when they are tested and certified as Class 
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1 B machines.

2 So, we are asking, I guess this

3 was our proposal for a definitive way to test. 

4 And I agree, it has its own faults and merits. 

5 So, maybe to turn the question around to you,

6 how would you do it better?

7 MR. HIEB: Well, I would think the

8 physical, that stacking method of product

9 would be more appropriate or more in line with

10 the differentiation between the product class

11 in the industry. Horizontal shelf-style

12 vending machines versus a vertical stacked

13 products.

14 MS. WIDDER: Okay.

15 MS. ARMSTRONG: Anybody else have

16 any thoughts on that one?

17 MR. HIEB: And I guess the only

18 other thought I would have is there really a

19 need to classify A and B distinctively

20 different, since we now have a 75 degree

21 common test specification.

22 MS. ARMSTRONG: So, I think that
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1 is a great topic of conversation for this

2 afternoon. Obviously, since we have standards

3 for A and B now, there is a need in the near4 term. And so we have amended standards later

5 but we will probably discuss whether there is

6 a continuing need for a distinction between A

7 and B machines in the standards, especially

8 this afternoon in our product classes.

9 FACILITATOR BROOKMAN: Thank you. 

10 Louis.

11 MR. STARR: Louis Starr, NEEA. 

12 So, the 10 degrees that you ended

13 up coming up with, what was the basis for

14 that?

15 MS. WIDDER: The basis for that

16 was comments submitted by interested parties,

17 specifically, AMS suggested 10 degrees

18 Fahrenheit.

19 MR. STARR: A follow-on question.

20 MS. WIDDER: Okay.

21 MR. STARR: Maybe I am asking you

22 to provide some background on how we maybe we
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1 could get ideas. It seems the conflict may be

2 with some concerns the other manufacturer had.

3 MR. COLLINS: Okay, Jim Collins,

4 AMS. And I will just say during the last

5 meeting in June of 2013, that was a number

6 that I just threw out out of my head. I have

7 no empirical data. It was just a number that

8 I guessed.

9 FACILITATOR BROOKMAN: And Jim,

10 since then, has there been any additional

11 thing that causes you to think that is a good

12 number?

13 MR. COLLINS: I have not

14 researched that number by test or other means

15 to decide whether that is a good number or

16 not.

17 FACILITATOR BROOKMAN: Okay, thank

18 you.

19 MS. WIDDER: I will add on to that

20 DOE would appreciate that kind of data, such

21 that it is available, if DOE were to continue

22 to use a temperature-based criteria to
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1 establish equipment classifications. That

2 kind of data would be very valuable.

3 FACILITATOR BROOKMAN: We have a

4 question. Arshak Zakarian, he asks, how would

5 they like to see them classified instead?

6 MS. WIDDER: Them, meaning the

7 manufacturers?

8 FACILITATOR BROOKMAN: I think so,

9 yes.

10 MR. HIEB: Beverage vending

11 machine.

12 FACILITATOR BROOKMAN: Just a

13 single --

14 MR. HIEB: Yes.

15 FACILITATOR BROOKMAN: --

16 designation, no two classes.

17 MR. HIEB: Yes.

18 FACILITATOR BROOKMAN: Okay. 

19 Okay. And as Ashley said, we will get into

20 this in-depth this afternoon.

21 Any additional questions you have

22 at this point, Sarah?
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1 MS. WIDDER: No.

2 FACILITATOR BROOKMAN: Okay, we

3 are moving on.

4 MS. WIDDER: Okay. The next

5 clarification that DOE is proposing as part of

6 this test procedure NOPR is specifically how

7 the thermocouples that are contained within

8 the standard test packages, how that

9 thermocouple wire should be run through the

10 beverage vending machine. DOE has encountered

11 some instances where the thermocouple wire is

12 run through the door, the dispensing door of

13 the beverage vending machine, which comprises

14 the thermal integrity of the unit and is not

15 representative of how the equipment is

16 designed to operate in a field. As such, DOE

17 is considering specific language that would

18 propose that the thermocouple wire be run

19 through the door gasket and not through the

20 dispensing door, in an attempt to limit the

21 air exchange between the interior refrigerated

22 air and the exterior ambient.
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1 MS. ARMSTRONG: So, just to

2 clarify, the current DOE specification is

3 silent on this.

4 MS. WIDDER: Yes.

5 MS. ARMSTRONG: So, currently, we

6 understand that different methods are used,

7 one being feeding through the door, one being 

8 feeding through the front, one

9 being actually drilling a hole through the

10 side of the vending machine.

11 So, you know all those methods,

12 under the current procedure because it is

13 silent, are seemingly allowable ways.

14 DOE has gotten some feedback that

15 there may be a one method is better than the

16 other. If we go down the pathway, which we

17 have, and we are proposing a specific method,

18 or at least limiting a specific method, that

19 would just cut any other methods that are

20 currently being used. Just so you are aware.

21 But currently there are a variety

22 of different methods all allowable under the
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1 current standard.

2 FACILITATOR BROOKMAN: So, if you

3 have comments here, that would be helpful if

4 you think that forecloses options for you or

5 whether it doesn't matter much, that would be

6 helpful to know.

7 Scott.

8 MR. MITCHELL: Scott Mitchell,

9 Southern California Edison.

10 The current revision we have had a

11 language that it is not specific as to how it

12 should be accomplished but it says that it

13 should be accomplished in a way that doesn't

14 hurt the thermal performance of the machine.

15 MS. ARMSTRONG: So, I will

16 challenge you on that and say for DOE's

17 purposes, how would you write that?

18 MR. MITCHELL: Yes. I don't have

19 an answer to that one.

20 MS. ARMSTRONG: So, I mean that's

21 what we are going for, though, is something

22 that is some type of mutually understandable
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1 method that we all can agree this is either

2 the way or the ways collectively that should

3 be that wouldn't, I guess, intrude upon the

4 thermal or compromise the thermal envelope.

5 MS. WIDDER: It is the same

6 intent. It is just DOE needs a method that

7 you can identify a test that is not done,

8 mostly that is not done in accordance with

9 that requirement.

10 FACILITATOR BROOKMAN: So,

11 additional written comments here would be

12 helpful, perhaps. 

13 Okay, yes, Jim.

14 MR. COLLINS: Jim Collins, AMS. 

15 My suggestion might be that with the

16 information provided to DOE, this particular

17 setup be provided as well. I think it is in

18 the manufacturer's best interest when he is

19 doing his own internal testing or having a

20 third-party do it, that he arrange the

21 thermocouples to be the least disruptive

22 possible and make the equipment perform to the
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1 best.

2 Because there is such a wide

3 variety of different machines, I think it is

4 going to be very difficult to create a

5 standard that will effectively address all the

6 different means that might be used to get

7 those thermocouples out.

8 FACILITATOR BROOKMAN: And so the

9 manufacturer or the testing facility will

10 simply cite how they did it.

11 MS. WIDDER: But so to that point,

12 how would DOE go about determining whether or

13 not what the manufacturer submitted was

14 acceptable or not?

15 MS. ARMSTRONG: I think what you

16 are asking though is basically that DOE allow

17 whatever the manufacturer would like to use

18 such that it meets the intent of the language

19 so that the manufacturer is willing to tell

20 DOE what that is.

21 I see one issue, a couple of

22 issues. One is if DOE were to pull your
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1 machine and test it, would DOE then have to

2 use the same or would anything work for DOE?

3 MR. COLLINS: Again, I would

4 suggest that they would use the test method as

5 used by the manufacturer.

6 MS. ARMSTRONG: And so in certain

7 cases, DOE has found that manufacturers are

8 using destructive is not the right word, but

9 they will drill holes. They will use those

10 methods. And that is something that DOE

11 typically does not do. We try not to

12 compromise the machine, the equipment itself,

13 just to instrument.

14 So, I would ask, in those cases,

15 what would you like DOE to do?

16 MR. COLLINS: I guess to do a fair

17 test, destroy it if you need to. In other

18 words, as a manufacturer, we wouldn't take a

19 machine and run the bundle of thermocouples

20 through the vend door and leave that exposed

21 to ambient air because it would increase our

22 ambient appreciably. So, we are going to do
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1 it in the most energy efficient manner to do

2 so. Since everything we add to do this

3 degrades from the actual performance in the

4 field, this is additional measurement

5 equipment that isn't normally there. Why not

6 allow us to do it in a means we determine is

7 best for the particular design involved?

8 FACILITATOR BROOKMAN: Okay, thank

9 you. 

10 Sir, do you have a comment?

11 MR. WILLIAMS: Rolando Williams,

12 SandenVendo.

13 I think with the way Jim put it,

14 just like with our glass front, we have 50

15 shelves, 50 trays on it. You run 50

16 thermocouples. During my tests, the best

17 performance if I route thermocouples certain

18 locations under these to not interfere with

19 the air flow. And then I had to do a hole

20 through the kick panel to route it out. But

21 it has to be done that way to get the intent

22 of the machine for the energy consumption
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1 without influences from the thermocouples.

2 FACILITATOR BROOKMAN: Thank you. 

3 We have a couple of individuals joining us

4 online that wish to comment. Let's see if

5 this works. Mike Mau is the first person who

6 has requested to speak.

7 Mike, if you will unmute your

8 phone and speak clearly, we will, hopefully,

9 hear you in the room.

10 MR. MAU: Hello, Mike Mau from

11 Royal Vendors.

12 FACILITATOR BROOKMAN: You sound

13 good. Keep going.

14 MR. MAU: I believe having this is

15 probably one of the worst ways possible. Most

16 machines are going to have vandal panels,

17 which will cover up any access to the back of

18 the machine and we won't be able to cover up

19 major air leaks there. It won't be possible.

20 So, we need to, we haven't

21 reviewed this. This is a giant air leak and

22 that will be a negative to the operation of
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1 the machine.

2 MS. WIDDER: How do you test your

3 equipment, Mike? How do you run the

4 thermocouples?

5 MR. MAU: On our stack machine,

6 there are refrigeration lines run up through

7 the base bottom. And so there is actually a

8 cutout there with thermocouples, where we run

9 up through there and let it cool. Then there

10 is a panel on the bottom, which can be removed

11 and run through there and that is normally

12 placed back and placed over that gasket.

13 I think the most important thing

14 for testing these is that all the tests need

15 to seal off any exchange of air between the

16 interior of the machine and the exterior of

17 the machine. And that can be done. That is

18 the way that we -- that is how we do it here.

19 FACILITATOR BROOKMAN: Okay, thank

20 you, Mike.

21 We also have a question or a

22 comment from Subarna Malakar. Please un-mute
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1 your phone and let's hope to hear you in the

2 room.

3 MR. MALAKAR: Okay. We are here

4 at Crane Merchandising Systems. The thing is

5 that we should be able to decide which method

6 is best for us. And on page 44 of your

7 presentation, I think that bullet one and two

8 are sufficient. I don't think we need the

9 third bullet.

10 FACILITATOR BROOKMAN: Okay, thank

11 you Subarna.

12 FACILITATOR BROOKMAN: Thank you

13 for that.

14 MS. WIDDER: I have two follow-up

15 questions that don't need to be responded to

16 now. I think in response to the suggestion,

17 again, DOE needs a method to confirm whether

18 or not those first two bullets have been met. 

19 So, that is just something to consider. 

20 Perhaps photo documentation or instructions

21 that accompany any certification would be

22 sufficient in this case. And there would be
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1 some amount of interpretation left but then,

2 in any enforcement testing, DOE would be able

3 to use the same method as the manufacturer to

4 ensure the thermal integrity of their machine.

5 The second question that I would

6 really appreciate comments from on

7 manufacturers is whether or not submitting

8 that additional documentation would be

9 burdensome. That is something we will get to

10 it later on that we also have to account for

11 in the test procedure is the burden associated

12 with additional test procedure amendments or

13 reporting requirements. And so that would be

14 something we would want to consider and

15 specific numbers, actually, would be really

16 comfortable, how long it would take you to

17 prepare such documentation.

18 FACILITATOR BROOKMAN: Do we have

19 final comments here on placement of

20 thermocouples? These comments have been very

21 helpful. Additional written comments would be

22 even more helpful. Additional comments before
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1 we move on?

2 MS. WIDDER: Okay. The next

3 amendment in this case that DOE is considering

4 or is proposing in this NOPR is a definition

5 and test requirements for equipment that

6 cannot currently meet the specified 36 plus or

7 minus 1 degree Fahrenheit interior temperature

8 requirement so that integrated average

9 temperature of 36 plus or minus 1, there may

10 be some equipment that cannot operate that

11 low. And for those models, those beverage

12 vending machine are currently still covered by

13 the beverage vending machine test procedure

14 and standards, such that they meet the

15 definition of refrigerated bottled or canned

16 beverage machine but they cannot be tested by

17 the DOE test procedure. And as such, must

18 currently request a waiver.

19 DOE is proposing to accommodate

20 such equipment that cannot be tested by

21 testing the equipment at the lowest

22 application product temperature and that is
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1 the lowest temperature setting the equipment

2 is capable of maintaining consistently

3 throughout the test. This is often the lowest

4 temperature setting on the thermostat. I mean

5 when DOE is testing this for enforcement, it

6 will just turn down the thermostat all the

7 way. So, if that is not the best way to

8 determine the lowest application product

9 temperature, DOE would also appreciate

10 comments on that.

11 DOE is proposing this lowest

12 application product temperature definition: 

13 the lowest integrated average temperature

14 means -- or the lowest application product

15 temperature means the lowest integrated

16 average temperature a basic model is capable

17 of maintaining so as to comply with the

18 temperature stabilization requirements

19 specified in ASHRAE Section 7.2.2.2, which is

20 currently how temperatures have to be

21 maintained and how stabilization is determined

22 in ASHRAE 32.1.
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1 This is, in general, an intent

2 consistent with the lowest application product

3 temperature definition that is adopted for

4 commercial refrigeration equipment except for

5 in that case the stabilization requirements of

6 ASHRAE 72 are referenced.

7 These are just a few

8 clarifications on this provision. All other

9 temperature -- all other requirements of the

10 DOE test procedure would still have to be met

11 and maintained, except for maintenance of the

12 interior -- the integrated average temperature

13 of 36 plus or minus 1. In this case, it would

14 be the lowest application product temperature

15 plus or minus one.

16 Equipment tested and certified

17 would be required to meet the applicable

18 standard for that equipment. And I already

19 mentioned this is similar to CRE.

20 DOE is requesting comment from

21 interested parties on the proposed definition,

22 on the proposed test procedure for such
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1 equipment that cannot be tested at 36 plus or

2 minus 1, not intended to operate there.

3 Also, I will note this middle one,

4 specifically how that lowest application

5 product temperature might be best determined. 

6 I mentioned that, based on the equipment

7 designs we have seen, the most consistent way,

8 especially for DOE who is not a manufacturer,

9 would be to just turn the thermostat down all

10 the way. DOE is interested if there is any

11 machines that aren't equipped with thermostats

12 or for which that might not be the most

13 appropriate method.

14 I think that is it.

15 FACILITATOR BROOKMAN: Yes, Jim?

16 MR. COLLINS: Jim Collins, AMS. 

17 What considerations, then, would be made for

18 the MDEC machines that run like my machines

19 would run warmer than 36 degrees?

20 MS. WIDDER: None. As referenced

21 on this slide, that equipment would still be

22 required to meet the applicable conservation
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1 standard without modification. So, the same

2 standard would apply to that equipment. 

3 Thermodynamically, you would expect that

4 equipment to use slightly less energy, have a

5 lower MDEC than a similar piece of equipment

6 that can be maintained at 36. And DOE is not

7 familiar with these machines being incredibly

8 common. So, there is some equipment that

9 can't meet 36 but it is a small niche market. 

10 And as such, DOE is proposing in this test

11 procedure that they would just meet the same

12 standard.

13 FACILITATOR BROOKMAN: And DOE has

14 specified that they intend to just crank it

15 down all the way. And I hope that is still

16 working here.

17 MR. COLLINS: Jim Collins, AMS. 

18 Yes, there are machines where the lowest

19 temperature setting is 40 degrees. So, to

20 make the test today, we have to fit special

21 software to allow you to set it that cold.

22 FACILITATOR BROOKMAN: Uh-huh. 
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1 Okay.

2 MS. WIDDER: I have a follow-up

3 question on that, actually. Is that specific

4 to AMS or is that common for other

5 manufacturers that they are as intended in a

6 field not able to meet 36?

7 MR. HIEB: Larry Hieb from

8 SandenVendo. And no, all of our equipment is

9 designed for 36 average product temperature.

10 MS. WIDDER: Okay, thank you.

11 FACILITATOR BROOKMAN: Louis.

12 MR. STARR: Louis Starr, NEEA. 

13 So, it does kind of sort of what you are

14 alluding to as the thermodynamic, since you

15 are not having to go as far as delta t in

16 parenthesis 36 to 40, that is roughly about

17 ten percent less just in thermodynamic energy. 

18 I'm not sure how it translates into actual

19 refrigeration energy but there could be a

20 point at which it actually does start to use

21 -- in other words, you could have an energy

22 hog but it appears to use the same energy as
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1 the compliant. 

2 Is there a thought of maybe

3 adjusting that or have you considered that

4 approach?

5 MS. WIDDER: So, that is certainly

6 something that DOE has considered. I think

7 the justification for establishing, in that

8 case, either a standard that is a function of

9 integrated average temperature or a separate

10 equipment class for different temperature

11 classifications of equipment.

12 The justification for that would

13 be the extent to which equipment are

14 certifying with this lowest application

15 product temperature provision.

16 So, to the extent that there is a

17 large number of models that are -- it is not

18 DOE's understanding that a large number of

19 models would submit with the lowest

20 application product temperature. As part of

21 this provision, manufacturers, when they are

22 submitting their MDEC, would be required to --
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1 or their certification reports to DOE would

2 also be required to submit the integrated

3 average product temperature or, if they use

4 the lowest application product temperature,

5 what that lowest application product

6 temperature would be.

7 And so then, we will be able to --

8 and this is effective 30 days after

9 publication in the Federal Register. So, we

10 will be able to right away after certification 

11 is required for BVMs, figure out how common it

12 is that equipment need to use this provision

13 and maybe consider something like that if it

14 is, in fact, more prevalent than DOE currently

15 understands.

16 MR. STARR: So it sounds like,

17 essentially, you are not sure there is a lot

18 of equipment that is really going to be using,

19 I don't want to say waivers, but this

20 procedure to do it so you are not concerned

21 about it.

22 If you get an update of that and
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1 you see that there is a problem or you see

2 that kind of the balance we just talked about

3 in terms of energy, you start seeing

4 inconsistency, then there may be a thought of

5 reviewing that to see if one -- but you don't

6 know that until you collect the data. Right?

7 MS. WIDDER: Right, exactly.

8 FACILITATOR BROOKMAN: Subarna

9 Malakar has a question or comment. Subarna,

10 please go ahead.

11 MR. MALAKAR: Okay, we just want

12 to make a comment, we here at Crane

13 Merchandising Systems again.

14 FACILITATOR BROOKMAN: Yes.

15 MR. MALAKAR: We just want to make

16 comment that our machines are capable of going

17 well below 36. And the question that we have

18 here is if you are allowed to just dispense

19 temperature other than 36 and allowed to use

20 the same formula, what good does it do? 

21 What is the benefit of doing

22 testing if you have a 35 in same category?
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1 MS. WIDDER: So first I will

2 clarify that this lowest application product

3 temperature provision is only applicable to

4 machines that cannot meet 36. So, for

5 example, if DOE were to test one of your

6 equipment that can be turned to 36 or well

7 below it and you submitted a certification

8 energy measurement at other than 36, that

9 equipment would not be in compliance. So, if

10 you can test at 36, you have to test at 36. 

11 This is only for equipment that

12 cannot meet the 36 plus or minus 1 temperature

13 requirement. And as previously mentioned, DOE

14 is not aware that that is a significant number

15 of models but will continue to collect data

16 and monitor that. This is based on just

17 looking at manufacturer literature and what is

18 advertised as an operating range for equipment

19 that is available on the market today.

20 And actually, DOE would accept

21 comment from manufacturers, if you are aware

22 of a significant number of models or
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1 manufacturers or machines that are available

2 but can't meet 36, it might be something that

3 is worth considering in the associated energy

4 conservation standard rulemaking.

5 So, the reason we are not

6 considering an amended standard or a different

7 standard is not being considered for lowest

8 application product temperature certified

9 equipment is just because DOE is really not

10 anticipating very many equipment using such

11 provision. It is really just a mechanism to

12 get away from having to do a waiver for these

13 small number of equipment.

14 MR. MALAKAR: So, the thing is

15 like if that is the case, I think there should

16 be another classification maybe like Class C

17 or so and you can clearly state that that

18 formulas used for Class A equipment that

19 cannot meet 36 degrees requirement. That will

20 distinguish that product from the remaining

21 other products.

22 MS. WIDDER: Okay. So, thank you
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1 for that comment. If you have any information

2 about what the energy consumption of, you

3 know, what a representative energy consumption

4 of such lowest application product temperature

5 applicable equipment would be and what their

6 lowest application product temperature is, DOE

7 needs that kind of data in order to support

8 setting the standard for that equipment

9 specifically, if that makes sense.

10 So, we would need information. 

11 You know if all that equipment can get down to

12 45, maybe establishing a separate integrated

13 average product temperature, as opposed to

14 this more variable provision. And then we

15 would need energy data from some

16 representative set of those equipment.

17 And so setting a standard is a

18 fairly rigorous process and establishing

19 separate equipment class is a fairly rigorous

20 process, which is why DOE has elected not to

21 pursue it in this NOPR anyways.

22 But if it is warranted, then DOE
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1 certainly would accept and will probably

2 actively solicit relevant data.

3 MR. DRENTEN: So, this is Doug

4 Drenten at Crane Merchandising. I am in the

5 room here with Subarna.

6 MS. WIDDER: Great.

7 MR. DRENTEN: Here is my question. 

8 If we have classifications that are already

9 established and we have certain protocol

10 around the testing, the methods, the

11 temperature ranges for that testing at 36

12 degrees, how does DOE expect the consumer or

13 somebody looking at the data to distinguish

14 between a better performing product and one

15 that is just not operating at 36 degrees,

16 using the same formulas?

17 If I have my machine so that it

18 will only go down to 50 degrees, intuitively,

19 I am going to use less energy.

20 MS. WIDDER: Right, intuitively

21 you will. That is a valid comment. I think

22 DOE was not anticipating that that comparison
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1 -- that consumers would be making that

2 comparison very often due to the lower number

3 of equipment that DOE anticipates will be

4 using this lowest application product

5 temperature provision.

6 MR. DRENTEN: But it is really not

7 how often a consumer makes it. It is if a

8 consumer has to make that determination or

9 that comparison, how do that do that, whether

10 it is one or whether it is one million

11 consumers?

12 MS. WIDDER: So they would -- so,

13 there is two things that that would be

14 relevant.

15 So, one is from DOE's

16 understanding, manufacturers typically publish

17 a temp operating temperature range in their

18 manufacturer literatures. And that is,

19 potentially, a criterion that that consumer is

20 using to select a piece of equipment. And so

21 the consumer would notice when they were

22 reviewing the operating range that it did not
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1 include 36 and did not go down that low. And

2 they would notice it had a higher operating

3 range. If that is acceptable for their

4 application, that is fine. But that would be

5 one hint or idea that the energy information

6 that they were seeing was not representative

7 of 36 because that equipment operates higher,

8 at a higher temperature.

9 The second would be that DOE, as I

10 mentioned, DOE is requiring that if equipment

11 is certified using the lowest application

12 product temperature provision, then they must

13 certify as such in their certification report. 

14 And those data will be available, publicly

15 available in the certification database, once

16 certification is required for BVM. So,

17 customers, anyone can go and look at that

18 certification information online.

19 And Elaina from Navigant also had

20 something to add.

21 MS. PRESENT: I just wanted to add

22 --
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1 FACILITATOR BROOKMAN: Stand up,

2 Elaina.

3 MS. PRESENT: Sorry -- that

4 customers may also be using the energy use

5 information to gauge the energies to expect

6 from the machine. If the machine cannot go

7 down to 36, it is not going to use the same

8 energy consumption as it would as it was

9 tested at 36. So, it is actually more

10 representative, as is required by DOE to use

11 the field -- what would be a reasonable field

12 energy use for the equipment.

13 FACILITATOR BROOKMAN: Louis

14 Starr.

15 MR. STARR: So, just a thought.

16 MS. WIDDER: Yes.

17 MR. STARR: It seems like maybe

18 just scale, thermodynamically scale the

19 relative -- in other words, if you are at 40

20 instead of 36, just scale up that energy

21 proportional as your MDEC, what is the word,

22 your allowable amount.
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1 MS. WIDDER: Based on the delta t.

2 MR. STARR: Right. Maybe the

3 ASHRAE chair has a thought about whether that

4 would be a pretty good way to do it.

5 But I mean straight up, if you are

6 doing 90 percent of the delta, it seems like

7 you would get only 90 percent of the energy

8 budget, too.

9 MS. WIDDER: Yes, there is also

10 fixed energy consuming components, like lights

11 and things. And that proportion will vary

12 from equipment to equipment, depending on how

13 big the box is.

14 So, while thermodynamically for

15 the same piece of equipment operating at one

16 level or another, it is a fixed proportion, 

17 applying that to all equipment and using the

18 methods DOE uses to set standards may not be

19 one to one but that is something, it is a

20 proposal on the table that manufacturers or

21 others can respond to.

22 MR. MITCHELL: So, not being a
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1 manufacturer myself, I don't have a lot of

2 information, a lot of test data to show how

3 the performance varies as that temperature

4 changes. But I don't know if the

5 manufacturers even have that.

6 FACILITATOR BROOKMAN: Stand up,

7 Rolando.

8 MR. WILLIAMS: Rolando

9 SandenVendo.

10 If a unit cannot be pulled down to

11 36, the machine is designed differently. 

12 Insulation is designed, it is not as much as

13 one that can go down to 36. So, the energy

14 would be much different.

15 MS. WIDDER: Yes, I think it would

16 be a little more complex of a process. When

17 I was thinking about it, part of the reason we

18 didn't go down that road is it really would be

19 setting us, establishing a separate equipment

20 class and doing all of the rigorous analysis

21 we are going to talk about hopefully this

22 afternoon on a whole different set of
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1 equipment. And there is requirements that

2 EPCA establishes for DOE when considering

3 setting the standards and we would have to

4 jump through all those hoops for this

5 particular type of equipment.

6 And so I think we could consider

7 scaling it by temperature but we would want to

8 make sure that that was representative and

9 fair for all of those equipment.

10 So, it would be a complex thing. 

11 And if the interest parties around this room

12 or on the webinar feel that that is something

13 DOE should pursue, they can certainly comment

14 as such. Or, if they have data about how

15 prevalent the lowest application product

16 temperature equipment are, that would

17 certainly be an important piece of

18 information.

19 FACILITATOR BROOKMAN: Louis,

20 follow on.

21 MR. STARR: In general, how much

22 equipment are we talking about on a percentage
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1 basis?

2 MS. WIDDER: I don't know. 

3 Elaina, do you have a guess?

4 MS. PRESENT: I could guess the

5 number of models but I'm not sure.

6 MS. WIDDER: Yes, a very single

7 digit percentage. 

8 The other thing I will note that

9 DOE also considers when they are setting

10 standards is the potential for energy savings. 

11 And since the lowest application product

12 temperature equipment will already be

13 inherently using less energy than the rest of

14 the models, and it is a small number of models

15 based on our research, there is not a lot of

16 theoretical potential for energy savings via

17 available, via setting a separate standard for

18 those equipment.

19 So, I am going to move on, unless

20 there is any other burning comments. But I

21 encourage interested parties to consider

22 thinking about this.
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1 FACILITATOR BROOKMAN: Subarna has

2 an additional comment.

3 MS. WIDDER: Okay.

4 FACILITATOR BROOKMAN: Subarna?

5 MR. MALAKAR: Yes, the one comment

6 I have is you know, again, just to separate

7 those machines. I think we should have a

8 different classification and list those

9 machines with a temperature they are tested

10 at.

11 MS. WIDDER: So, I have a --

12 MR. MALAKAR: -- come up with

13 another formula or anything like that. Just

14 create another classification, say Class C or

15 so and list those machines with the

16 temperature they are tested at.

17 MS. WIDDER: So, you are

18 suggesting establishing a labeling requirement

19 for beverage vending machines.

20 MR. MALAKAR: Something like that,

21 exactly.

22 MS. WIDDER: Okay, thank you for
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1 that comment. I would encourage other

2 interested parties to respond to that

3 proposal, whether they believe a labeling

4 requirement for equipment testing at the

5 lowest application product temperature would

6 be a good thing, is justified.

7 FACILITATOR BROOKMAN: Okay, let's

8 move on.

9 MS. WIDDER: Okay, moving on.

10 So, this is a slide that we are

11 going to spend a lot of time on. This is a

12 large part of the NOPR, if you happened to

13 read it. If not, I encourage you to do so

14 because I am going to stay pretty high level

15 here but I am going to discuss in general

16 DOE's proposal for these accessories and one

17 other that is on the following slide.

18 DOE, in testing and discussions

19 with manufacturers has determined that there

20 is a lot of variability in the accessories

21 that might be -- a BVM might come equipped

22 with. It might be money-processing, lighting
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1 on the inside, the outside, heaters for winter

2 cooling, anti-sweat heaters, security covers,

3 they are all listed here. And none of these

4 equipment has explicit specifications within

5 the existing test procedure as to how they are

6 to be configured for the purposes of

7 conducting the DOE test procedure, which could

8 lead to variability in the measure of energy

9 consumption, if one lab were to do it one way

10 and another lab a different way.

11 So, DOE is considering clarifying

12 the test procedure and specifically, the

13 configuration for each of these accessories to

14 ensure consistency of results among equipment

15 and among labs.

16 I'm just going to read through

17 these. Money-processing devices, and that

18 would be what is used to swipe the credit card

19 or accept money, would be in place and

20 functional in the most energy consuming

21 combination that is available with that model

22 because there can be a variety of money-
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1 processing equipment configured on the

2 machine.

3 Internal lighting. This is the

4 one that is probably the most clear in the

5 current ASHRAE standard. The internal

6 lighting should be at the maximum energy7 consuming state.

8 Anti-sweat and other electric

9 resistance heaters should be set to automatic,

10 if available. So, if there is a humidistat

11 associated with the anti-sweat heater, that

12 can be used. Otherwise, set to the maximum

13 energy-consuming state.

14 Condensate pan heaters and pumps

15 in place and operational. So, that would --

16 and not messed with during the DOE test

17 procedure. You know you can't manually remove

18 condensate during the test.

19 Illuminated temperature displays,

20 that is already specified in ASHRAE by the

21 way. Illuminated temperature displays would

22 be energized and operated normally, as
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1 intended.

2 Condenser filters should be

3 removed for the test, such that it would

4 affect air flow.

5 Security covers that might be in

6 place on the front of the machine to protect

7 the machine from vandalism aren't expected to

8 affect the energy performance of equipment but

9 would be removed for the test, just to ensure

10 consistency, if it would hold in some of the

11 air or something.

12 General purpose outlets that may

13 be on the outside of the equipment for cell

14 phone charging or that people are starting to

15 do all manner of things with beverage vending

16 machines. It will be energized. It is

17 difficult to de-energize those but nothing

18 should be plugged into them.

19 Crankcase heaters and other

20 electric resistance heaters for cold weather

21 should be operational and operated with any

22 control systems activated. So, hopefully,
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1 such a machine would have like a thermostat

2 associated with it that measured the outdoor

3 ambient. If it didn't, I guess it should be

4 on all the time. But hopefully, the

5 thermostat would be operated and should be

6 operated, if it exists.

7 And then I wrote out this one

8 accessory which DOE is calling -- is it on

9 here -- yes, external customer display signs,

10 lighting and digital screens. I wrote this

11 out separately because this is sort of like

12 the "everything else" accessory pile.

13 So, DOE has become aware that

14 there are BVMs that are being developed that

15 have interactive screens and gaming consoles

16 and all sorts of things associated with them. 

17 So, the variety of this equipment is

18 increasing rapidly.

19 DOE looked out at the availability

20 of this equipment and believes that a lot of

21 this equipment or noticed that a lot of this

22 equipment is already covered by another DOE
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1 energy conservation standard, like TVs are

2 already covered to the extent that someone

3 were to put like a -- what are those called --

4 like a TV -- yes, a lot of this is already

5 covered by existing DOE energy conservation

6 standards. But DOE will note that just by

7 quick back of the envelope calculations, it is

8 going to vary based on what the BVM is and

9 what the equipment is. But it is about

10 equivalent to the energy use of the BVM,

11 itself. So, it can be significant in some

12 cases.

13 However, due to the variability of

14 that equipment and the difficulty of trying to

15 accommodate all those different configurations

16 and still meet a consistent standard, DOE

17 believes that the energy use of such external

18 customer display signs, lighting, and digital

19 screens are virtually not associated with the

20 primary function of the refrigerated beverage

21 vending machine, which is to refrigerate

22 products and vend them to a customer. And so
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1 any of these external features that are

2 associated with other functions that are not

3 refrigerating or vending are not necessarily

4 representative of the energy consumption of

5 just the refrigeration, the refrigerated

6 beverage vending machine in its fundamental

7 use.

8 Therefore, DOE is proposing in

9 this NOPR in general that such equipment

10 should be de-energized. There is a little bit

11 of nuance that is characterized in this table. 

12 So, if the operation of the customer display

13 side lighting or digital screen is not used

14 for refrigerating or vending, such that de15 energizing will not affect the performance of

16 the refrigerated beverage vending machine in

17 meeting the intent of a refrigerated beverage

18 vending machine, it should be in Appendix A,

19 de-energized or in its lowest energy-consuming

20 state and in Appendix B, which is to be used

21 with future energy conservation standards, de22 energized or in standby mode.
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1 So, DOE is proposing a definition

2 for standby mode, that is on the next slide

3 that is, in general, is consistent with the

4 terminology in Appendix A but to the extent

5 that it is different, DOE is accommodating

6 this definition in Appendix B, proposing that

7 definition in Appendix B, and placing it in

8 Appendix B because it may affect the energy

9 consumption of covered equipment.

10 And then if that display sign,

11 lighting, and digital screen is necessary for

12 vending, so like you have to touch the screen

13 to make your selection or something like that,

14 it must be placed in its lowest energy

15 consuming state that does not interfere with

16 the vending function. So, you have to be able

17 to still select the product but maybe there is

18 another part of the screen that can be de19 energized or something like that.

20 FACILITATOR BROOKMAN: We have a

21 couple of comments here.

22 MS. WIDDER: Yes, okay.
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1 FACILITATOR BROOKMAN: Louis

2 first.

3 MR. STARR: So, a question. In

4 the machines you are looking at that have the

5 external outlet, was signage being plugged

6 into that or could it be a range of things

7 that are being plugged in?

8 MS. WIDDER: So, it is a variety. 

9 And actually, typically, Elaina can correct me

10 if I am wrong, but my understanding is that

11 equipment that is being manufactured to have

12 this kind of auxiliary stuff on it, it is

13 actually directly wired. And so that is why

14 we have all these different energy-consuming

15 states because it is not something you could

16 just like unplug in many or all -- in most

17 cases. If it is, then that is what you should

18 do. If you can directly plug it in, unplug

19 it. That would meet this de-energized thing. 

20 It would also meet the general purpose outlet

21 provision.

22 But otherwise, there is a lot that
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1 is directly wired.

2 MR. STARR: Well, I didn't say I

3 was suggesting the opposite. If it is like an

4 electrical outlet in your house, it is

5 designed for a certain amount of wattage and

6 it is kind of then National Electrical Code

7 that determines how much equipment.

8 So, one option instead of de9 energizing is energizing to the full amount

10 that that circuit is able to handle in the

11 test procedure. So, if you have something set

12 up for 10 amps or 15 amps, we power that much.

13 The fact that the size of the --

14 you were mentioning the percentage of use of

15 these auxiliary devices are meeting the amount

16 of the machines, starts to make me think it is

17 really just essentially part of the machine.

18 MS. WIDDER: Right.

19 MR. STARR: So, that is kind of a

20 little bit of my thought process. But it is

21 just another option to think about. Instead

22 of not having things plugged in, plug it in to
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1 the amount that there is a circuit breaker for

2 that switch. Someone plugs in a 20 amp

3 circuit into a 10, it will cook the circuit. 

4 So, you, therefore, couldn't load it up to its

5 maximum available and do the test procedure

6 that way.

7 MS. WIDDER: Right. Thank you for

8 that comment. Just to follow up, something

9 that goes through my mind is whether or not

10 that maximum energy consumption would be

11 representative of what is that BVM is in the

12 field.

13 There are sometimes general

14 purpose outlets and whatever I have seen them

15 on a BVM, nothing is plugged in, for what it

16 is worth. It is not that -- that is an

17 anecdotal piece of information. But if

18 manufacturers have or others have information

19 about the extent to which they are used, we

20 would want to at least account for that to be

21 as representative as possible but that is

22 certainly one approach. Thank you for that
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1 comment.

2 FACILITATOR BROOKMAN: Subarna,

3 you are next.

4 MS. WIDDER: Subarna?

5 FACILITATOR BROOKMAN: We cannot

6 hear you Subarna. Unmute the phone.

7 MR. MALAKAR: Yes, just a

8 question. What is the reason behind the

9 reason where you remove the condenser filter

10 and the security covers?

11 MS. WIDDER: What is the reasoning

12 behind it?

13 MR. MALAKAR: Yes.

14 MS. WIDDER: Just to consistently

15 configure. Those two provisions, actually, in

16 specific, DOE doesn't anticipate being very

17 common or prevalent or affecting the energy

18 consumption very dramatically but --

19 MR. MALAKAR: It will affect the

20 energy consumption. Like if you have a filter

21 that increases pressure drop across and the

22 coil, it can increase the condensing
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1 temperature and it can increase the energy

2 consumption.

3 MS. WIDDER: Right. And so if you

4 were in an outdoor application, you might want

5 to incorporate a condenser filter. However,

6 DOE wants all of the equipment to be tested

7 consistently. So, if you think it would be

8 more representative to test it with condenser

9 filters in place, we certainly welcome those

10 types of comments.

11 MR. MALAKAR: Yes.

12 MS. WIDDER: DOE selected these

13 specifications because they thought they were

14 most representative of how equipment would be

15 installed in the field. That was the intent

16 -- and being consistent.

17 MR. MALAKAR: But the thing is

18 like you have to test and it will be years,

19 right? That is the thing. If it is going to

20 be used with the condenser filter, then it

21 will have to be tested with condenser filter.

22 MS. WIDDER: So, just to follow-up
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1 on that, for a specific BVM model, would you

2 ship all those models with the same filter or

3 is there some models that go with the filter,

4 some without, and is there any variability in

5 the type of filter that could be applied?

6 MR. MALAKAR: Then you will have

7 to have that as two different models.

8 MS. WIDDER: That is one option. 

9 I would request feedback or comments from

10 other manufacturers about whether they think

11 that those equipment should be listed as

12 separate models and we should revise this

13 specification.

14 FACILITATOR BROOKMAN: Additional

15 comments? Sarah, I think we are due for a

16 break.

17 MS. WIDDER: Okay. Can we -- we

18 are really close to the end of Appendix A.

19 FACILITATOR BROOKMAN: Okay.

20 MS. WIDDER: Yes, I think we are

21 really close to the end of Appendix A, if I

22 remember properly. So, let's get there.
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1 This is the last thing, but there

2 is a lot of questions -- we are sort of

3 getting the comments out now but there is a

4 lot of pages of comments.

5 We could also maybe let people

6 think about it on the break and take some

7 comments but let me get through my slides at

8 least.

9 FACILITATOR BROOKMAN: Okay.

10 MS. WIDDER: I think this actually

11 might be the last content slide.

12 This is the definition of standby

13 mode that DOE is proposing for inclusion in

14 Appendix B. Standby mode means the mode of

15 operation in which any external integral

16 consumer display sign, lighting or digital

17 screen are connected to main power, do not

18 produce the intended illumination display or

19 interaction functionality, and can be switched

20 into another mode automatically with only a

21 remote user-generated or internal signal.

22 So, this definition was developed
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1 based on the definition of standby mode that

2 is included for TVs because DOE thought that

3 is the type of equipment it might be most

4 applicable for.

5 The idea is here that if it is in

6 a mode that like you could power it on but it

7 is not completely de-energized if there is any

8 background sort of -- like maintaining a

9 timestamp or something like that, a Wi-Fi

10 signal, that would be included in the standby

11 mode but the primary energy consumption would

12 be off.

13 So, that is what this definition

14 was intended to encompass. And then to the

15 extent that a standby mode energy consumption

16 state exists for any of this auxiliary

17 equipment or user accessories that is

18 different from de-energizing the equipment,

19 that state would be used for Appendix B but

20 the equipment would be de-energized in

21 Appendix A, to be to not modify the energy

22 consumption of that equipment, as it needs to
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1 meet the existing standard.

2 So, here is all the -- I will just

3 run through the comments and we can talk about

4 them. This is our request for comment on

5 internal lighting, that it would reach its

6 maximum energy-consuming state and whether

7 that is consistent with normal operation or if

8 there is a wide variety of lighting levels, if

9 there is something that might be more

10 representative.

11 These are comments on the

12 specifications for these auxiliary

13 accessories, the external customer display

14 signs, lighting and digital screens. This DOE

15 would appreciate the most comment on. The

16 range of equipment that should be addressed in

17 this category; if the language is sufficient

18 to capture all of that equipment; if the

19 provision itself is representative of the BVM

20 energy consumption.

21 If there might be any issue de22 energizing such equipment in Appendix A, DOE
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1 would like comment on that or setting the

2 equipment in standby mode. So, the

3 implementation of such a provision. I think

4 that is -- you guys can read these comments. 

5 There is more.

6 And then especially this last one

7 I will bring up and the rest of you can read. 

8 For digital screens that also perform the

9 vending or money-processing function, DOE

10 would appreciate comment to the extent that

11 exists, if that means that equipment has to be

12 fully energized and if so, if it would be

13 difficult for that equipment to meet a

14 standard or it needs a separate standard, or

15 if there is a lower energy-consuming state

16 that would still allow the money processing

17 feature to function.

18 And then we are on to Appendix B.

19 So, maybe, Doug, unless there is

20 burning comments now, we could take a break

21 and then will accept any additional comments

22 that might occur to people on these items and
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1 then move on to Appendix B.

2 FACILITATOR BROOKMAN: Yes, I

3 think there is quite a bit of a list here. 

4 Let's take a short break. 

5 Arshak, when we return, you are

6 the first one in the queue. Let's try and do

7 this in ten minutes. We really close to the

8 coffee shop. Please wear your badge so it is

9 visible to walk around the Forrestal building. 

10 And the coffee shop is right around the corner

11 here. The restrooms are on both ends of the

12 hall also.

13 MR. STARR: And vending machines.

14 FACILITATOR BROOKMAN: And vending

15 machines. But it is now 11:00, which means we

16 will resume at ten minutes after 11:00. There

17 is a fair amount of substantive material

18 before we break for lunch. So, let's get back

19 here and get right at it.

20 (Whereupon, the above-entitled

21 matter went off the record at 11:00 a.m. and

22 resumed at 11:12 a.m.)
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1 FACILITATOR BROOKMAN: Okay, let's

2 start back. So, let's finish our brief

3 overview of slides up to slide 54. So, that

4 included definition of standby mode, treatment

5 of accessories -- treatment of accessories,

6 several slides there.

7 So, Arshak, you were next in the

8 queue. Please comment.

9 MR. ZAKARIAN: Hi, can you hear

10 me?

11 FACILITATOR BROOKMAN: Yes, speak

12 up.

13 MR. ZAKARIAN: I am just wondering

14 when you say DOE doesn't do standby or

15 vending-only, what does this mean exactly?

16 MS. WIDDER: Okay. So, that means

17 exactly -- how come I can't go backwards? Oh,

18 okay.

19 FACILITATOR BROOKMAN: We've got

20 some feedback in the room, which typically

21 means that someone has their phone un-muted

22 and is not speaking. So, if everyone who
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1 joined us on line can mute their phone, maybe

2 that will stop the feedback.

3 PARTICIPANT: It is Arshak's

4 phone.

5 FACILITATOR BROOKMAN: Sarah, keep

6 going.

7 MS. WIDDER: So, standby -- to

8 answer the question, exactly that means that

9 if there is a mode that meets this definition,

10 and so the best thing to think about is a

11 television - which is where this definition

12 was developed - that can be turned on with a

13 remote control or pressing the power button on

14 the screen, but to the extent that this other

15 standby power use isn't the case, another

16 example that has nothing to do with BVMs is

17 like a coffee maker or a microwave that has

18 internal clock or might have other functions

19 that are always energized and then a primary

20 function that is disabled in the standby mode.

21 So, that is what this definition

22 is intended to represent. Exactly -- the
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1 reason this is included in Appendix B or what

2 it means to be included in Appendix B is that

3 if there is TVs or lighting or other signs

4 that would meet this definition, that would

5 have a mode that they can be turned off but

6 there is other peripheral functions that are

7 always energized like clocks, temperature

8 displays, something that is part of it, then

9 those -- then the standby mode would have to

10 be met.

11 In Appendix B, that equipment

12 would be de-energized completely -- or in

13 Appendix A. I'm sorry. In Appendix A, that

14 equipment would be de-energized completely or

15 in its lowest energy-consuming state, whatever

16 that is. In Appendix B, it would be de17 energized or in standby mode.

18 So, if its lowest energy-consuming

19 state is standby mode, then that means

20 nothing. If it can be de-energized, it is

21 always de-energized in Appendix A or Appendix

22 B. So, if you can turn it off completely, if
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1 you can disconnect it, if you can unplug it,

2 that is what you should do. If you cannot

3 unplug it or de-energize it without de4 energizing the entire machine, you would put

5 it in its lowest energy-consuming state in

6 Appendix A, which is however you can configure

7 the machine or in standby mode. And the

8 reason that that is adopted here is the lowest

9 energy-consuming state is a little bit

10 ambiguous. I think that we can all appreciate

11 that that is not a specific -- that doesn't

12 have specific requirements around how the

13 equipment, what functionality is available

14 versus not, what lowest energy-consuming state

15 means. So, this describes what type of

16 functions should be available and is

17 representative in DOE's view of the percentage

18 of the energy consumption associated with

19 these peripheral devices that is appropriate

20 to accommodate in the measurement of daily

21 energy consumption for the beverage vending

22 machine. Because that would be present, just
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1 like lighting, 24/7 in the beverage vending

2 machine when it was plugged in. Whereas, a

3 television may be turned off, may be turned

4 on, may be operating differently in the field. 

5 There is just such a wide variety of

6 mechanisms or ways that this equipment could

7 be operated. There are so many different

8 energy consumption profiles. That is what

9 this means.

10 Does that help at all?

11 MR. ZAKARIAN: I keep on wondering

12 what it means to be in Appendix A, to be in

13 Appendix B and what is required.

14 MS. WIDDER: Okay, so I will try

15 to answer that specifically. And then if that

16 is still not clear, I think any suggestions or

17 further questions DOE would appreciate written

18 comments on that and we can continue to

19 consider them to be more explicit, to make

20 sure it is clear when we do the final rule.

21 So, to reiterate, in Appendix A,

22 which would be effective 30 days after
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1 publication of this test procedure -- any test

2 procedure final rule in the Federal Register

3 and would be able to be used with existing

4 standards if you can de-energize an external

5 customer display sign, external lighting, or

6 digital screen, it should be de-energized.

7 If you can't de-energize it

8 without affecting the vending function or

9 affecting the refrigeration, or affecting the

10 energy consumption of the beverage vending

11 machine as performing the refrigeration and

12 vending functions that make it a BVM, then it

13 should be in its lowest energy-consuming

14 state. So, turned down to the extent it can

15 turn down.

16 It is difficult to specify more

17 than that. So, things that come to mind are

18 if it is a TV monitor and the TV can be on

19 like a sleep mode or something and that is

20 available without de-energizing it, then it

21 should be in the sleep mode. If it always has

22 to be illuminated but there is like a dimmer
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1 setting on the lights, it should be in the

2 dimmer setting on the lights.

3 Those are some examples but as I

4 mentioned previously, there is a lot of

5 variability in this equipment.

6 In Appendix B, which would be

7 required with compliance with any amended

8 energy conservation standards, that same BVM

9 would -- what's that?

10 Yes, that would be after the

11 publication of any amended standards and also

12 after compliance with those standards as

13 required. There are some provisions for DOE

14 allowing for early use of amended test

15 procedures but I am not going to go there

16 right now.

17 So, the point is, Appendix B is

18 intended to be used with those amended

19 standards. What you would do in that case is

20 still, if you can de-energize the equipment,

21 if you can unplug it without affecting the

22 refrigeration or vending functions, that is
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1 what should happen. It should be de2 energized. And if you can't de-energize it,

3 then it should be in a mode that meets this

4 definition of standby mode.

5 And in general, based on DOE's

6 review, the lowest energy-consuming state will

7 probably meet this standby mode definition. 

8 But the standby mode definition was proposed

9 to provide more explicit instructions about

10 what features should be energized or de11 energized -- well since it can't be de12 energized, it should be available to represent

13 the energy consumption of that equipment in a

14 minimally energized state.

15 So, some questions that might --

16 that we thought about, that DOE thought about,

17 you know to respond to your question about

18 what is the difference between Appendix A and

19 Appendix B, one question would be, is the

20 lowest energy consuming state different than

21 standby mode for any equipment that

22 manufacturers or other interested parties are
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1 aware of?

2 If standby mode were included in

3 Appendix A, would that be problematic for any

4 equipment?

5 Would it be more representative in

6 Appendix B to have standby mode specified for

7 all of these external customer display signs

8 and de-energization -- that is not a word --

9 de-energizing those accessories not available? 

10 So, you just have to put it in standby for

11 Appendix B and then it can be de-energized as

12 low as you can go in Appendix A.

13 I mean these are questions that we

14 thought about, what is representative for this

15 equipment. And in Appendix B, we can

16 consider, we have more flexibility to consider

17 what is representative for this equipment

18 because amended standards are also being

19 considered that can accommodate any changes in

20 energy consumption that would change -- that

21 would result from changing the specification

22 of the accessories.
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1 In Appendix A, we would have to

2 stick with what is the DOE test procedure and

3 what was considered in the existing standards.

4 FACILITATOR BROOKMAN: And we are

5 going to move on to Appendix B shortly but

6 let's take additional comments here.

7 MR. SUAMI: Mvuala from Natural

8 Resources Canada.

9 FACILITATOR BROOKMAN: Yes.

10 MR. SUAMI: Why not call the

11 standby mode external accessory standby mode? 

12 Because in Appendix B it is more, if I

13 understand, is internal accessory standby than

14 refrigeration standby mode.

15 MS. WIDDER: Right.

16 MR. SUAMI: Because for the

17 Appendix B, when you say standby mode,

18 somebody will think about internal standby

19 mode because there is no qualification of what

20 is standby mode. That term may bring some

21 confusion. 

22 So, if you qualify this standby
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1 mode as external accessory standby mode,

2 people will understand it is something that

3 was not perhaps for vending machine for the

4 cold beverage vending machine.

5 MS. WIDDER: Right. That is a

6 good comment and actually a perfect transition

7 to Appendix B, if we don't have any other

8 comments.

9 FACILITATOR BROOKMAN: Final

10 comments here before we move on.

11 Okay. Yes, please, Jim.

12 MR. COLLINS: Jim Collins, AMS. 

13 The topic on the previous slide regarding

14 money devices, that seems to me to be opening

15 up a huge can of worms. We discussed it a

16 little bit in the ASHRAE committee. We are

17 unsure what you are planning to do there. 

18 There is a wide variety of different equipment

19 available, numerous permutations of equipment

20 that can be fitted on any of these machines

21 and, certainly, at this stage, they will work

22 to the detriment of our allowed MDEC. Any
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1 consideration for adjustments then to the

2 MDEC, due to the additional requirement for

3 money processing devices.

4 MS. WIDDER: So, thank you for

5 that comment. DOE's intent -- so, that -- how

6 do I address this? DOE's intention with the

7 specification for money processing devices for

8 them to be in place and functional and the

9 most energy-consuming combination is to

10 respond to the first part of your statement or

11 comment, which is there is a wide variety of

12 money processing configurations that are

13 available for a given model. DOE doesn't

14 necessarily see the need for all of those

15 configurations to be differentiated as

16 different basic models. And so a way to

17 represent the energy consumption of that model

18 in a consistent fashion is with a

19 conservative, or the maximum, most consumptive

20 rating. That is where this thinking came

21 from. That is consistent with DOE's basic

22 model grouping provisions, which allow basic
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1 models to be in the same equipment class to be

2 grouped, provided they all use the same most

3 consumptive energy rating. 

4 So, DOE wanted first to be more

5 specific about what energy, what money

6 processing equipment should be in place. And

7 I think we all agree on that. That should

8 probably occur. What that combination is that

9 is representative for that model and how that

10 can be consistently applied to the equipment

11 or a different basic model for each

12 combination of money processing equipment are

13 necessary or what is currently done in the

14 field, what are industry today, all of that

15 would be useful information.

16 DOE in Appendix A would, as you

17 know, like to account for what was considered

18 in existing standards. So, DOE is actually

19 accounting for that in its specifications that

20 are effective 30 days after publication of

21 final rules. So, these Appendix A

22 clarifications, DOE is accounting for how
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1 those equipment were treated in the

2 promulgation of the 2009 energy conservation

3 standards. So, we are thinking about that. 

4 We wanted to have the test procedure that

5 comes out of this rulemaking be consistent

6 with what DOE was assuming when they set those

7 2009 standards.

8 And if those, whatever

9 specifications we are considering here, are

10 inconsistent with what was considered during

11 the 2009 rulemaking for energy conservation

12 standards, then those are the type of changes

13 that would go in Appendix B.

14 So, comments about what is

15 currently done for money processing equipment

16 or what should be done, potentially, in the

17 future, to be representative and consistent

18 are appreciated.

19 Does that help?

20 MR. COLLINS: Well, I guess the

21 main point is that right now there is no

22 specificity in the ASHRAE test standard.
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1 MS. WIDDER: I agree with that.

2 MR. COLLINS: And, therefore, and

3 I will be the first to raise my hand, all my

4 equipment is tested with no money devices. 

5 Right or wrong, it is not mentioned, so it

6 wasn't included. And I would be willing to

7 guess that many of my colleagues would say

8 that is how theirs were tested.

9 So, this would be a "changing

10 horse in the middle of the stream" type of an

11 issue.

12 MS. WIDDER: Okay. Well, thank

13 you. That is exactly the kind of information

14 that we need. I mean, while we want to be

15 consistent with the DOE test procedure, we

16 need to know what manufacturers are doing now

17 to comply.

18 MR. HIEB: Yes, Larry Hieb with

19 SandenVendo America. I concur with Jim. It

20 has never been in our process to include money

21 handling devices in our energy consumption

22 testing. We consider that a separate
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1 accessory that is, again, variable to our

2 customer. Many of our and most of our

3 equipment goes out without money handling

4 systems. And it is at the discretion of the

5 consumer/customer to install those in many

6 cases and to try to determine which systems to

7 install because there are a wide variety of

8 systems and combinations.

9 We would consider that to be

10 burdensome and should anything be put off to

11 the Appendix B later because if it is not

12 accounted for in the current figures.

13 MS. WIDDER: Okay, thank you for

14 that comment.

15 FACILITATOR BROOKMAN: Louis.

16 MR. STARR: Louis Starr. So, it

17 sounds like the crux of the thing is whether

18 it goes in Appendix A or Appendix B. It seems

19 everybody agrees that eventually it should go

20 on Appendix B. But is it just a -- not

21 necessarily.

22 So, Sarah, in your experience, are
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1 these money-processing devices, and I assume

2 that is with all of these things that you

3 chose to leave in or out are kind of

4 representative of the typical machine. Is

5 that the purpose for including them or not

6 including them?

7 In other words, like the condenser

8 filters you are leaving off because they are

9 only put in harsh conditions but money

10 machines you are putting on because that is

11 what you have seen in the field a lot as far

12 as the equipment?

13 MS. WIDDER: Two things, I think. 

14 Yes, this list is meant to be representative

15 of what is typically available on the widely

16 available models. So, when we look out there,

17 I mean I think you can't vend if you can't

18 process money. So, it is difficult for a BVM

19 to meet the definition of a beverage vending

20 machine without some type of coin acceptor in

21 place to accept money from the customer.

22 And then the other criteria that I
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1 mentioned that DOE used is whether or not

2 these accessories were accounted for in the

3 setting of the 2009 energy conservation

4 standard.

5 FACILITATOR BROOKMAN: Are we

6 ready to move on? Let's move on.

7 MS. WIDDER: Okay. Okay, so

8 Appendix B, and just a reminder, although I

9 think we are all clear on that by now, oh,

10 it's not on this slide, but Appendix B is

11 intended to be used with any amended energy

12 conservation standards that come on the

13 rulemaking we will be discussing this

14 afternoon.

15 In general, Appendix B contains

16 all of the clarifications that we just

17 discussed that are proposed to be included in

18 Appendix A. And in addition, provisions for

19 accounting for a low power mode or a machine

20 standby mode, a low power mode test method

21 that would account for the reduced energy

22 consumption associated with that type of
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1 energy management control.

2 DOE, in reviewing equipment, has

3 found that equipment with a low power mode is

4 widely available. It is an ENERGY STAR

5 requirement and a large percentage of the BVM

6 market is ENERGY STAR qualified certified. 

7 However, there is no current test or energy

8 consumption representations around what that

9 low power mode achieves. DOE believes that it

10 would be more representative to have a test

11 that accounts for the availability of that low

12 power mode and gives customers information

13 about some type of estimated energy savings

14 they might achieve. That is pretty much what

15 this --

16 Oh, and then DOE is also aware

17 that there are specifications around when

18 equipment turns on and off. There is a

19 variety of low power modes available, both

20 modes that address lighting and accessories,

21 I will call them, than refrigeration systems

22 that can also be modulated during this low
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1 power mode. And so there is a variety of

2 different low power modes that might be

3 available for equipment.

4 DOE is proposing in the subsequent

5 slides a specific test method that can be

6 consistently applied across equipment equipped

7 with any lower power modes, but it wouldn't

8 capture the variability in all of those

9 different -- if there is different like

10 lighting levels that could be selected.

11 All right, so the current DOE BVM

12 test procedure specifies that equipment should

13 be operated with normal lighting and control

14 settings, using only those energy management

15 controls that are permanently operational and

16 not capable of being adjusted by the machine

17 operator. And since most low power modes are

18 capable of being adjusted by the machine

19 operator, they cannot be currently employed

20 during the DOE test procedure.

21 So, we are going to get into some

22 definitions and then the specific test
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1 provisions. There is quite a few slides and

2 all the requests for comment are saved until

3 the end. But I would encourage people to

4 interrupt me if there is things you want to

5 discuss on a specific slide.

6 So, the first definition DOE is

7 proposing to define in Appendix B, "low power

8 mode," which is a state in which a beverage

9 vending machine's lighting, refrigeration,

10 and/or other energy-using systems are

11 automatically adjusted without user

12 intervention, such that they consume less

13 energy than they consume in an active vending

14 environment.

15 And DOE intended "without user

16 intervention" to be treated differently than

17 the previous "not capable of being adjusted". 

18 It just means that you don't have to go and

19 manually move -- engage the low power mode,

20 that it is automatically, based on a schedule

21 that the operator may have set, or some sort

22 of occupancy sensor, that you could set the
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1 time interval when occupancy sensor employs.

2 So, that is without user

3 intervention, a little bit different than

4 without manual intervention at all.

5 Two more proposed definitions. I

6 mentioned that there is two types of low power

7 modes and DOE is proposing to define those

8 explicitly and treat them differently in the

9 test procedure. And accessory low power mode,

10 which is a state in which a beverage vending

11 machine's lighting and/or other energy-using

12 systems, except the refrigeration system are

13 in low power mode. So, this could include

14 dimming lights, turning off the illuminated

15 temperature displays.

16 Some of the specifications that we

17 saw before in Appendix A, those equipment,

18 those accessories that were listed out on the

19 previous slide, to the extent that they can be

20 controlled by a low power mode, they would be

21 able to be controlled by this low power mode.

22 So, that is accessory low power mode.
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1 Refrigeration low power mode is a

2 state in which a beverage vending machine's

3 refrigeration system is in low power mode. 

4 And then we have in the definition contained

5 there, don't worry about the words right now,

6 it is a verification test procedure similar to

7 the optional test procedure about fully cooled

8 and not fully cooled. DOE wanted an explicit

9 quantifiable method to determine whether or

10 not manufacturers had this refrigeration low

11 power mode. So, that is contained within the

12 definition here. We will get into it in a few

13 more details in more detail.

14 But the point of this slide is we

15 are just going to define these two little

16 types of low power mode differently because

17 they are proposed to be treated differently in

18 the DOE test procedure.

19 FACILITATOR BROOKMAN: Let's just

20 see if we have any comments here. Comments on

21 these three definitions, low power mode,

22 accessory low power mode, and refrigeration
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1 low power mode?

2 MS. WIDDER: You know I think it

3 will become more clear once say why we

4 separated them. So, let's keep going and then

5 we will come back. Okay.

6 So, test methods. DOE considered

7 several different options for how to account

8 for low power mode in the DOE test procedure. 

9 This blue one on the bottom is DOE's proposal. 

10 DOE considered separate physical tests, where

11 you would test the beverage vending machine in

12 full active mode, in accordance with the

13 current DOE test procedure, and then a

14 separate test, that may or may not be the same

15 length of time, with all systems that are

16 controlled by a low power mode, de-energized

17 or being controlled by that energy management

18 system in a consistent fashion and somehow

19 adding those together with the algorithm.

20 The nice thing about it, it is

21 clean, it is quantitative and unambiguous. 

22 The main problem with that is it is
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1 additionally burdensome because you have two

2 tests and it does not capture pull-down energy

3 use. So, if the refrigeration system is

4 allowed to increase the temperature setting or

5 float during the low power mode, with two

6 separate tests you are not capturing the

7 energy consumption of pulling that machine

8 back down to 36 degrees to the vending

9 temperature again.

10 So, another method DOE considered

11 is a single test where you would start with 18

12 hours in vending state, which would be that

13 active mode; 6 hours in low power mode, as was

14 previously defined. And that is your 24 hour

15 test period. And then you would have a pull16 down that would occur after that and get you

17 to capture the energy consumption associated

18 with getting back to vending temperature.

19 And then an algorithm could be

20 developed whereby that energy consumption,

21 which is now more than 24 hours, could be

22 scaled back to 24 hours, since that is the
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1 metric: energy consumption in a 24-hour

2 period.

3 But one could consider how

4 temporally you can scale that back. And DOE,

5 I think, discussed in a little more detail or

6 method in the NOPR, which I can discuss but I

7 am not going to now, but if folks are

8 interested.

9 So, the difficulty with this

10 method -- it is nice because it is

11 quantitative, unambiguous and it captures the

12 variation among low power modes. So, if one

13 manufacturer is different than another

14 manufacturer, you are getting all that. The

15 problem is manufacturers have a lot of

16 different lengths of pull-down, ways of

17 pulling down, temperatures they get to. And

18 that variability around how low power mode is

19 implemented through refrigeration low power

20 mode makes it very difficult to specify when

21 a machine should start pulling down and when

22 you are done and how to get that back into the
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1 test procedure in a consistent way without

2 really like input from the manufacturer.

3 So just for example, DOE tried to

4 implement these different low power mode test

5 methods on some equipment and there is some

6 equipment that pulled down very quickly, some

7 that take in excess of six hours to pull down.

8 So, there is a lot of variability

9 there. And because of that variability and

10 potential input from manufacturers that would

11 be necessary to conduct consistent tests and

12 lack of data really in how this would go, DOE

13 is proposing this third method, which is a

14 single 18-hour vending state test, a 6-hour

15 accessory-only low power mode test. So the

16 accessory-only low power mode test won't have,

17 you don't have that pull-down issue. You just

18 turn things off and turn things on. It is a

19 lot easier to do for manufacturers and DOE in

20 a consistent way.

21 And then we still want to give

22 manufacturers credit for accommodating
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1 refrigeration low power mode. So, based on

2 DOE's testing, a representative number was

3 developed, a credit that could be given to

4 manufacturers if they have refrigeration low

5 power mode.

6 So, the measured daily energy

7 consumption would be the 24-hour energy

8 consumption measured during the test, during

9 the 18-hour vending state and the 6-hour

10 accessory-only low power mode times this

11 refrigeration low power mode credit.

12 So the benefit is quantitative,

13 easy to implement. The main thing about this

14 test procedure is it does not capture the

15 variation among refrigeration low power modes. 

16 So, one manufacturer may do it better than the

17 other one. This one gives everybody the same

18 amount of credit.

19 So, this is just a rundown of how

20 the physical test would be conducted. So,

21 there is still a 12-hour stabilization period

22 that is required for ASHRAE. Zero to 18 hours
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1 a vending state test period occurs, where all

2 equipment and accessories are energized as

3 specified in Appendix A. We went through that

4 list. Adjustable energy management controls,

5 however, would be set to the highest or

6 maximum energy consuming space. And this is

7 now changing from the way beverage vending

8 machines are currently tested. Right now, you

9 are not allowed to interact with the beverage

10 vending machine during testing. It is

11 specified specifically in the test procedure

12 that no stimulation, no interaction should

13 occur.

14 In this vending state test period,

15 it is meant to represent an active vending

16 environment. And so manufacturers or testing

17 lab personnel would provide whatever

18 stimulation is necessary, pushing buttons or

19 just walking by the machine that would prevent

20 the engagement of low power modes during this

21 18 hours.

22 And then from 18 to 24 hours, the
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1 operation of accessary low power modes would

2 be allowed. So, if for example, lighting was

3 on an occupancy sensor, then that stimulation

4 would no longer be required. The low power

5 mode could be initiated for the remainder of

6 the 24-hour test for those six hours. 

7 FACILITATOR BROOKMAN: Subarna has

8 a question or a comment.

9 MS. WIDDER: Okay, sure. Great.

10 FACILITATOR BROOKMAN: Subarna,

11 you are on.

12 MR. MALAKAR: Yes, the question we

13 had was for the procedure for the vending

14 test. We were just wondering like when you --

15 vending meaning like we have to do the vending

16 itself?

17 MS. WIDDER: No.

18 MR. MALAKAR: I just want to make

19 sure like -- just running that -- 

20 MR. DRENTEN: Where is that

21 described in any detailed procedure anywhere?

22 MS. WIDDER: So, the vending state
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1 test is you do not have to vend anything. You

2 have to operate the beverage vending machine

3 so that it meets, in general, this

4 requirement. It is specified more exclusively

5 in the regulatory text that is at the back of

6 the notice and also in the preamble.

7 But, in general, it would be

8 similar to the existing DOE test procedure,

9 except that even energy management systems

10 that cannot be adjusted by the manufacturer,

11 which are allowed to be initiated right now,

12 so for example, if you had a default occupancy

13 sensor that no one could operate, that would

14 be allowed in the current DOE test procedure. 

15 And in this proposed test procedure or during

16 the vending state, all energy management

17 systems would be disabled. The intent is, you

18 don't have to vend but you do want to capture

19 the energy consumption of the beverage vending

20 machine in an active state for those 18 hours.

21 MR. MALAKAR: So, this is

22 significantly different than how we have been
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1 doing. Right?

2 MS. WIDDER: Yes.

3 MR. MALAKAR: So, will it be

4 permanently updated?

5 MS. WIDDER: No. I mean -- you

6 mean the standard? The standard is --

7 So, these proposals that we are

8 discussing right now are all to be included in

9 Appendix B, which is only required for use

10 with amended energy conservation standards. 

11 So, you don't have to do this to meet existing

12 standards.

13 So, this afternoon, we are going

14 to talk about amended standards that are

15 accounting for all of these new proposed test

16 methods.

17 MR. MALAKAR: So what incentive do

18 we have to go to this test, this amended --

19 what is the reason? I mean it looks like you

20 are creating two test procedure methods for

21 standards.

22 MS. ARMSTRONG: So, this is Ashley
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1 from DOE. So, two things. One is you

2 wouldn't be allowed to use Appendix B to show

3 compliance with the current standards. The

4 current standards were not built upon Appendix

5 B. You would have to use the current test

6 procedure or to the extent that the proposal

7 for clarifications get adopted here in

8 Appendix A. Use that to show compliance with

9 Appendix A.

10 Now, as you know, DOE, which is

11 the topic of this afternoon's meeting, DOE has

12 been triggered to review the energy

13 conservation standards for beverage vending

14 machines to see whether more stringent

15 standards may meet our statutory criteria.

16 Part of that would also trigger to

17 review the test procedure. One of the points

18 of feedback that we have gotten from a variety

19 of interested parties was there are these

20 presence of low power modes. There is a low

21 power mode and then there is like the

22 refrigeration accessory low power mode, which
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1 we call a refrigeration low power mode.

2 So, some people argue that they

3 would like some type of -- incentivize that

4 type of behavior that control strategy that is

5 being implemented in the field. Our current

6 test procedure does not adopt for it at all. 

7 The current standards do not reflect it.

8 In the future, if DOE were to

9 accomplish amended standards and require the

10 use of an Appendix B, it would be required to

11 then use also Appendix A. We would transition

12 wholesale to Appendix B with these amended

13 standards. That may reflect low power mode.

14 So, really the question becomes

15 does industry and other stakeholders,

16 utilities, advocates as well, believe that

17 inclusion of low power mode in the test method

18 is the right way to go. And then, if the

19 answer is yes, this is our proposal on how we

20 propose to do it and we welcome your views on

21 that, obviously.

22 MR. DRENTEN: So Ashley, this is
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1 Doug Drenten. So, if I am understanding what

2 you have said, if we, as participants, agree,

3 and other interested parties with the idea of

4 having a low power state, what you are

5 specifying at the moment is the test method

6 that you are proposing to be used. Correct?

7 MS. ARMSTRONG: Correct.

8 MR. DRENTEN: So, how do we -- and

9 Ashley, maybe we are going to discuss this in

10 a lot more detail this afternoon, but how did

11 you come up with the 18 hours?

12 MS. WIDDER: We are not going to

13 discuss that this afternoon but there is in a

14 few minutes and right now because I am going

15 to say it, we request comment on if 18 hours

16 is the right amount and if 6 hours is the

17 right amount for low power mode.

18 MS. ARMSTRONG: So, the honest

19 answer, Sarah is going to toe the line here

20 but the honest answer is we struggled quite a

21 bit with this procedure, this proposal. And

22 we went back and forth. 
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1 We did quite a bit of testing on

2 our own and it was hard. And each person,

3 each manufacturer in different models employ

4 low power mode in different manners. So, it

5 is hard to write a uniform applicable test

6 that can be done both by the manufacturer and

7 can be done by a third party that will react

8 and put a BVM or at least verify that a BVM

9 goes into low power mode either through its

10 accessories or through its refrigeration

11 system or both for some significant duration

12 to show that it actually when put in the

13 field, will operate in a low power state. It

14 will save energy. And the reason why that is

15 important here for verification purposes is

16 because on the next couple slides you will see

17 is we are propose to give credit for that. 

18 And so with that credit, comes in

19 the incentive to do it but we want to make

20 sure that that is actually being realized in

21 the field.

22 That is where we are coming from. 
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1 If you have a better way to do it, we are all

2 ears. Because like I said, we struggled with

3 this for a while.

4 MR. DRENTEN: I was just more

5 curious as to how you got the particular 18

6 hours, 6 hours, and 12 hours.

7 MS. ARMSTRONG: I think some of it

8 was testing. Some of it was based on the

9 testing that we had seen and what we feel

10 comfortable was long enough to say something

11 has actually been put in low power mode versus

12 something was just put there for a test

13 condition versus a variety of different

14 methods.

15 MS. WIDDER: And so, I mean,

16 essentially what the 18 hours and the 6 hours

17 is doing is establishing a usage profile for

18 the BVM. That is what it is. And the usage

19 profile for BVM can be anything from zero

20 hours for the BVMs that are on every floor of

21 a hotel to 24 hours. You know you could

22 imagine scenarios where there is a BVM in a
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1 place that sees a lot of traffic, in an

2 airport, all day long, and is interacted with

3 or people are walking in front of it all the

4 time.

5 And so, there is a lot of

6 variability in usage profiles out there for

7 BVMs. And so this was what we selected as

8 potentially representative and consistent

9 across equipment. It won't be representative

10 of everything, obviously, but you have got to

11 pick something and then implement it for all

12 models.

13 So, if there is a reason that it

14 should be different than six hours and a

15 better number, a better number of hours to

16 employ a low power mode that DOE would welcome

17 feedback on that but this is our proposal

18 based on the information and data that is

19 available.

20 So this was, in specific,

21 developed on a typical operating hours of like

22 stores. If a store is going to close or have
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1 periods of low use, it is typically at night,

2 you know a gas station might be closed or like

3 have people not going into the store and

4 purchasing beverages for some amount of time.

5 FACILITATOR BROOKMAN: Larry, do

6 you have a comment?

7 MR. HIEB: Yes, Larry Hieb,

8 SandenVendo.

9 Just for clarification, if a

10 vending machine has an automatic feature that

11 shuts the lights off, for example, after two

12 hours of inactivity, would there be stimuli

13 put into the test during that 18 hours to turn

14 those lights back on through that period?

15 MS. WIDDER: Correct. That is

16 what is proposed here, so that you have a

17 period that -- so, DOE currently if that

18 energy management system can't be operated or

19 controlled by the machine operator, and can't

20 be adjusted by the machine operator, that

21 occupancy sensor could turn off the lights,

22 essentially, for the duration of the test,
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1 which may or may not be representative of a

2 field use. In this proposal we are proposing

3 that it may not represent the field use of

4 typical equipment and so that that equipment

5 should be on for 18 hours and off for --

6 lighting would be off for 6 hours.

7 MR. HIEB: So, is it understood

8 then that the DEC data or the DEC allowance

9 would need to be increased because current

10 test methods allow for the lights to be turned

11 off for the duration of the tests?

12 MS. WIDDER: Well, there are two

13 factors here. One is the energy use may

14 increase during the ending stage test period

15 but would also decrease because of the

16 refrigeration low power mode credit, which I

17 have not gotten to yet.

18 But the answer is yes. The answer

19 is we are going to talk about that this

20 afternoon. And the energy conservation

21 standard numbers and analysis was all done

22 using these proposals as the basis. So,
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1 assuming this.

2 MS. ARMSTRONG: The real answer is

3 whatever the impacts are from the proposals

4 that we are going to make and that we did make

5 and meet will be carried through to the

6 numbers you see this afternoon.

7 MR. HIEB: So, it may be at an

8 increase not just a decrease.

9 MS. ARMSTRONG: Not necessarily. 

10 I mean it just depends. We will do our

11 analysis and you will see this afternoon where

12 our analysis shows. It may not necessarily be

13 an increase. For your unit, it may be. But

14 our analysis may not show an increase.

15 FACILITATOR BROOKMAN: Louis.

16 MR. STARR: So, this is Louis

17 Starr, Northwest Energy Efficiency Alliance. 

18 We are definitely supporting the

19 Department of Energy including these in their

20 test procedure, because we feel that it will

21 encourage the use of the refrigeration low

22 power mode and accessory low power mode.
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1 The one thing I would say, it

2 sounds like we will talk about this low power

3 refrigeration mode, I sort of looked in the

4 PTSD about that. And it looks very

5 conservative now but there may actually be

6 more energy savings that are shown there and

7 a manufacturer can comment on that.

8 The other thing I would say is

9 that in your definition of refrigeration low

10 power mode, you would probably want to include

11 something about how that is activated because

12 I might -- let's say I am a manufacturer that

13 doesn't really have a low power mode in there,

14 I could claim that credit by maybe putting a

15 button on the side of the machine that you

16 would press. It would go into that but it

17 would not really be activated otherwise.

18 So, I would be concerned about

19 people talking credit, the three percent

20 credit doesn't allow an energy savings by

21 having that but that it be a real one that is

22 actually activated by some external source.
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1 MS. WIDDER: So, that is a great

2 segue into the refrigeration lower power mode

3 credit and then the verification procedures. 

4 So, for that very reason, and then also

5 because it is -- so for that very reason, yes. 

6 To verify the existence of low power mode, DOE

7 is also considering a verification test, which

8 is also optional but it is how DOE will

9 confirm that that low power mode credit was

10 taken accurately.

11 So, first the number. The low

12 power mode credit based on DOE's limited

13 testing, I will admit, is three percent of an

14 estimated amount of savings on the measured

15 daily energy consumption that would come from

16 a 6-hour refrigeration low power mode, also,

17 accounting for pull down.

18 So, DOE requests comment on that

19 number. It is somewhat conservative and there

20 is certainly variability within that but that

21 is DOE's, based on our testing, a reasonable

22 number to incentivize use of refrigeration low
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1 power modes.

2 I will also note that DOE would --

3 as DOE becomes more comfortable or as

4 refrigeration low power modes are more widely

5 used, there is potential to develop a test

6 method that could quantifiably determine what

7 the refrigeration low power mode was for

8 specific models. But because of the issues we

9 talked about before, that is not being

10 considered here or proposed here.

11 So, the verification test that you

12 were getting to. So, since taking the credit

13 won't verify the existence of this

14 refrigeration low power mode, you want it to

15 accommodate some sort of check that could be

16 done to verify existence of a low power mode. 

17 And essentially what it is, is at the end of

18 the BVM test procedure, you would allow the

19 equipment to continue to operate and initiate

20 the refrigeration low power mode.

21 The requirements are that over the

22 course of this 2-hour period, the
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1 instantaneous average next-to-vend beverage

2 temperature must increase above 40 degrees

3 Fahrenheit and remain above 40 degrees

4 Fahrenheit for at least one hour. So, in an

5 hour, you have to get from 36 to 40 and then

6 be maintained above 40.

7 And Louis, it is not written on

8 this slide, but in the reg text and in the

9 NOPR, that refrigeration low power mode has to

10 be activated without user -- has to be

11 activated automatically I think is the word

12 that is used.

13 I mean it could be something that

14 refrigeration low power modes could be timer

15 based. So, you know if a facility is closed,

16 you are going to turn the refrigeration system

17 off at 10:00 p.m. or something like that. And

18 that is allowed but you would have to pre19 program that and it would automatically

20 initiate.

21 And then at the conclusion, to be

22 sure that the equipment can in fact bring it
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1 down, we don't care about the energy

2 consumption at this point, but at the

3 conclusion of the 2-hour period, the BVM must

4 automatically return to 36 plus or minus 2

5 without operator intervention.

6 The validation test, as I

7 mentioned, would not be required to certify

8 performance and DOE will use it for

9 enforcement purposes only.

10 So, here is the request for

11 comment. I think that is all that is left. 

12 Yes, okay.

13 So, on the definitions, as Doug

14 mentioned previously, we can go backwards, the

15 vending state. DOE requests comment on its

16 proposal to run units in the vending state for

17 18 hours and to specify whatever stimuli is

18 necessary to prevent automatic activation of

19 low power modes, now that they have been

20 defined in Appendix B.

21 The refrigeration low power mode,

22 DOE requests comment on the credit, the amount
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1 of the credit, and the verification test

2 method that we just discussed. Particularly,

3 if a one-hour time period in which the

4 instantaneous average of all test packages was

5 maintained above 40 degrees, that is the

6 appropriate amount of time, if that is

7 possible, to get from 36 to 40 based on our

8 thermodynamic calculations seems reasonable

9 but is a lot of different insulation levels,

10 infiltration, things that will affect how

11 quickly the temperature changes in the box.

12 So, input from manufacturers on

13 what that time frame should be. Forty degrees

14 seemed reasonable because we need to be far

15 enough away from the specified temperature

16 that we know we are really getting something. 

17 But that also requests comment on the 40

18 degrees.

19 And then these are some general

20 comments, general requests for comments on low

21 power mode, whether it is representative of

22 equipment, that user profile that we were
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1 discussing, whether six hours is the right

2 amount.

3 There is also a specific request

4 for a comment in here on the prevalence of

5 non-cycling compressors in the BVM industry. 

6 And also a request for comment on we discussed

7 different test methods. We proposed -- this

8 test method is the most appropriate, at least

9 brings a good compromise for what we can do

10 today, most manufacturers and DOE. But if a

11 physical test method would be more

12 representative and if so, how to implement

13 that consistently.

14 FACILITATOR BROOKMAN: Several

15 requests for comment. Louis Starr.

16 MR. STARR: So, mine is on the low

17 power mode. So, just thermodynamically if you

18 looked at a test period, you have six hours

19 where you increase the temperature four

20 degrees, from 75 to 36 is 39 degrees; 75 to 40

21 is 35 degrees. So, essentially, you are

22 adjusting it by ten percent. So during that
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1 six hours, you get ten percent savings. And

2 then it is only one-fourth of the period. So,

3 10 percent times one-fourth is 2.4 percent,

4 which is kind of looks like where the 3

5 percent comes from.

6 Have the manufacturers, would they

7 publish for that particular mode? Would they

8 sell that as a product to customers? Is it in

9 that range? Is it a higher number or what did

10 you typically see as the savings from having

11 the refrigeration power mode increase?

12 MS. WIDDER: I have not, myself,

13 seen estimates of savings from low power

14 modes, only words that say it is available. 

15 So, only representations that such a mode is

16 available, not estimates of the energy savings

17 from it. And I think part of that is because

18 there is really no representative way to

19 estimate the savings yet. That is part of

20 what this proposal is about.

21 FACILITATOR BROOKMAN: Jim.

22 MR. COLLINS: Jim Collins, AMS. 
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1 Just a comment on that. Our customer base

2 typically never would compare this data and

3 the reason is that the people that buy our

4 equipment and operate it don't pay for

5 electricity. So, it is not a market factor.

6 The second question is, on slide

7 64 you specified the test period. And as I

8 understood it, this is how you would confirm

9 at DOE that we are following this rule to get

10 our credits.

11 MS. WIDDER: Correct.

12 MR. COLLINS: How will this

13 procedure be implemented? Are you intending

14 to impose upon us some automatic mode that

15 will operate the machine in this manner or do

16 you intend to actually go into the test

17 chamber, reset the equipment temperatures --

18 MS. WIDDER: No, no. So, what

19 would happen is so if you certified your

20 equipment with a refrigeration low power mode,

21 which you would tell us as part of the

22 proposal is you have to say that I am taking
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1 the refrigeration low power mode credit. So,

2 if DOE were then testing that equipment, we

3 would test it with the vending state and

4 accessory low power mode test procedure that

5 goes 24 hours. And then if there was like a

6 schedule, it depends, I mean all

7 manufacturers, how they initiate low power

8 mode is different. For it to take this

9 credit, it has to be automatically actuated.

10 So, that could be a schedule-based

11 control or that could be an occupancy sensor12 based control for some other like interaction13 based control. So, like if it hadn't seen you

14 touching the screen for a while, it would

15 start to float.

16 So, what would happen is at the

17 end of the test procedure, the equipment would

18 be allowed to operate and for a scheduled base

19 control, that temperature would change -- the

20 thermostat within the equipment would change

21 at the end of the test procedure.

22 For things that had a significant
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1 occupancy lapse period, we would have to wait

2 for the thermostat for whatever that period

3 is. And then that would initiate the

4 refrigeration low power mode state. Does that

5 make sense?

6 MR. COLLINS: Well again, the way

7 this is stated, it looks like a multiple step

8 process, where you do in and raise the

9 temperature to 40 and then two hours' later go

10 in and reset the temperature back to 36.

11 MS. WIDDER: No, if that is

12 necessary, you don't get a refrigeration low

13 power mode credit. If in order to change the

14 temperature of the equipment, you have go to

15 set the thermostat, that is not a

16 refrigeration low power mode.

17 FACILITATOR BROOKMAN: Louis.

18 MR. STARR: I think maybe I can

19 clarify. You essentially just get three

20 percent credit but you have to have a mode

21 that really works.

22 FACILITATOR BROOKMAN: It is
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1 automatic.

2 MS. WIDDER: Right.

3 MR. STARR: Right. So, they are

4 just giving you a three percent credit to

5 encourage you to put these in your machines. 

6 And if it is there and it really works like it

7 is supposed to work --

8 MR. COLLINS: Well you keep

9 specifying that this is how it is supposed to

10 work. I would maintain I have a better

11 program in place right now and it doesn't work

12 this way at all.

13 MS. WIDDER: Well, then that kind

14 of information -- so all we are trying to

15 achieve with the refrigeration verification

16 test procedure is that it exists and

17 automatically will work. And so, if this

18 isn't the right way to verify that, then we

19 would like suggestions on what the way to

20 verify it is.

21 We just don't want people taking

22 three percent credits and having to do what
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1 you said, which is go in and change. That is

2 not the credit.

3 MS. ARMSTRONG: Just to be clear

4 here, we are not trying to tell you how your

5 refrigeration should work. That is obviously

6 up to you and you guys should know that way

7 better than we would ever.

8 But like Sarah said, you would

9 need a way to, on the back end, verify that

10 you actually had employed one without -- an

11 automatic, a confirmed one that you have set

12 up.

13 And so that is what we are looking

14 to do. And if this test isn't the right one,

15 we need to know one that is.

16 FACILITATOR BROOKMAN: Scott, do

17 you have a comment?

18 MR. MITCHELL: Yes, Scott

19 Mitchell, Southern California Edison.

20 I think these comments might have

21 taken care of it but the way that this is

22 written right now looks to me like it would
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1 require some sort of software modifications

2 from what was originally included in the

3 machine, in order to do this test method as it

4 is written.

5 So, I would just encourage the

6 manufacturers, who have much better knowledge

7 of it, to make comments on it.

8 MR. WILLIAMS: Rolando Williams,

9 SandenVendo. 

10 Our machine is programmable by the

11 consumer. So, they can put it in whatever

12 time they need to do with when they go and

13 shut off something and it raises the

14 temperature. Everything is programmable.

15 FACILITATOR BROOKMAN: So, does

16 that mean that this is workable from your

17 perspective? 

18 MR. HIEB: It's workable.

19 MS. WIDDER: So that was the kind

20 of control that DOE had in mind when they

21 developed this verification test. And there

22 are dynamic options and schedule options. But
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1 if you can automatically schedule, the

2 temperature will rise at the end of the test

3 -- at the end of the vending and accessory

4 mode low power mode testing, you wouldn't have

5 to verify the existence of a dynamic mode in

6 addition. That scheduling-based function is

7 fine. That meets the intent of the low power

8 mode.

9 This is just a verification test. 

10 Manufacturers don't have to do it. This is

11 just a QA method to ensure that we are

12 actually going to see these savings in the

13 field. That is really what it is for.

14 FACILITATOR BROOKMAN: And Linda

15 Wilson and Mike Mau, I guess. Mike, I guess

16 I pronounced your name incorrectly previously. 

17 You are next. Please go ahead.

18 Un-mute your phone. We can't hear

19 you.

20 MR. MAU: Hi, Mike Mau. Was there

21 testing done in order to verify periods to

22 raise the ambient temperature to 40 degrees
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1 from 36 and then also for the 2-hour period

2 that automatically occurred for 36 degrees.

3 I'm just curious about that. I

4 haven't ever done this kind of test to verify

5 how fast the products warm up. I kind of take

6 DOE at your word.

7 MS. WIDDER: So, I'll be honest. 

8 No. Those numbers weren't developed based on

9 testing. They were developed based on just

10 some thermodynamic calculations that I --

11 MS. ARMSTRONG: That's not true. 

12 We did do some testing.

13 MS. WIDDER: Okay.

14 MS. ARMSTRONG: We did do some --

15 MS. WIDDER: But did we do this

16 teat?

17 MS. ARMSTRONG: Uh-huh. The two18 hour rise definitely was seen in testing from

19 products commercially available today.

20 MS. WIDDER: That being said --

21 MR. MAU: This is Mike. I

22 couldn't hear you.
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1 MS. ARMSTRONG: Sorry. The answer

2 is yes. We did do testing from products that

3 are commercial available today for the two4 hour rise.

5 FACILITATOR BROOKMAN: Louis.

6 MR. STARR: This is Louis Starr. 

7 The concern I have with the schedule of the

8 low power refrigeration mode is that it is

9 pretty easy to change or put in something to

10 a schedule and have it changed. It is also

11 likely that it might not actually be

12 implemented. 

13 So, one that actually goes ahead

14 and is either through occupancy sensors or

15 some other way, if nothing else, seems like it 

16 should be credited at a different rate than

17 one that potentially could be but most likely

18 wouldn't be.

19 And I would say the other thing is

20 if you do do it that way, it seems like we

21 should later on look to see if people are

22 actually using the schedules or not. Because
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1 as you know, these machines can maybe do a lot

2 of things but if the consumers don't configure

3 them that way, then you don't really get the

4 savings. But if it is something programmed in

5 the hardware, then it goes into this mode,

6 then it is more likely for it to actually be

7 implemented in the field and actually see

8 those savings. That is one of the concerns

9 that we might have.

10 MS. WIDDER: Okay, thank you.

11 FACILITATOR BROOKMAN: Linda

12 Wilson has a question. Linda asks, will the

13 EPA proposed SNAP rule have any impact on the

14 testing methods (i.e., eliminating of HFC

15 refrigerants)?

16 MS. WIDDER: I do not believe that

17 it will have any impact on the test procedure.

18 MS. ARMSTRONG: Right. So, I

19 think the answer is -- so, I think that is

20 true, that the test is going to be

21 refrigerant. The test is the test.

22 Now, that being said, I think the
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1 answer is that we don't know exactly how it

2 will impact the number coming out of the test. 

3 And really we are going to ask you guys a

4 question and I think we are going to hit on

5 this maybe a little bit this afternoon. But

6 whether it will impact the number coming out

7 of the test and whether the value levels that

8 you see currently on the market today will

9 change, if the upper limits are used and

10 certain ones are phased out.

11 And so, I think the answer from

12 the Department is we are not sure. From the

13 test procedure point of view, we believe the

14 test is a valid method of test and is

15 refrigerant useful.

16 But for the standards, it is a

17 different issue.

18 FACILITATOR BROOKMAN: I would

19 like to see if we have additional comments on

20 these other comment boxes here. I don't

21 believe we have hit all of you yet.

22 I do believe that the final two
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1 slides, 67 and 68. So, state additional and

2 perhaps final comments because it is just

3 about time to go to lunch.

4 MS. WIDDER: So hearing none, the

5 last section of this slide deck is a request

6 for any closing remarks that any interested

7 parties would like to make about the test

8 procedure and how to submit comments. You can

9 refer to those details in your packet.

10 And then as Doug noted, we will be

11 starting up the energy conservation standard

12 after lunch.

13 FACILITATOR BROOKMAN: Let me know

14 and reiterate what someone said early on. 

15 Some of this, it seems that it is new enough

16 and complicated enough that your detailed

17 written comments would be very helpful to the

18 Department. Very, very helpful. So, please,

19 if you walk away from this morning's session

20 and think about how to put that together in a

21 way that you can really amplify your concerns

22 better.
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1 So, let's break for lunch. It is

2 now 12:15. It takes pretty much an hour to

3 have lunch here in the Forrestal Building and

4 that is if you stay on campus. Please don't

5 leave. There is big cafeteria about 100 yards

6 down the hallway that a way.

7 For those of you, does anybody not

8 know where they are going? Most everyone

9 does. There will be a bunch of folks trooping

10 in that direction. Please make sure you have

11 your badge visible.

12 If you go to the big cafeteria,

13 which is where most of us will be going, you

14 might need, you will probably need an ID to

15 get back through the security portal. 

16 This room will be secured. You

17 can leave your stuff here.

18 And you know where the restrooms

19 are.

20 We covered a lot of ground this

21 morning. We are going to cover even more this

22 afternoon. We will see you back here at 1:15. 
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1 And thanks those of you joining us

2 online. Hang with us. We are going to start

3 again at 1:15.

4 (Whereupon, the above-entitled

5 matter went off the record at 12:17 p.m.)

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A

a.m 1:11 4:2 8:20

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able 44:10,20 51:2

63:18 65:5 66:2

72:6 74:7,10

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128:21

above-entitled

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accept 76:20 79:1

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acceptable 60:14

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acceptor 123:20

access 63:17

accessary 136:1

accessible 10:5

accessories 88:16

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107:5,5 115:9,22

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accessory 92:8,12

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122:1 128:9,22

129:22 139:22

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accessory-only

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accommodate

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accommodating

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accompany 65:21

accomplish 140:9

accomplished

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account 15:5 66:10

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accounted 122:12

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accounting 119:19

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accounts 125:11

accurately 149:10

achievable 43:2

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activation 152:18

active 127:13

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actively 45:14,22

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actual 62:3 72:18

actuated 157:9

add 22:16 33:2

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addition 124:18

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additional 16:2

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address 60:5 118:6

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addressed 104:16

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adjusting 73:3

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adjustments 118:1

admit 149:13

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advantage 51:6

advertised 76:18

advocates 140:16

affect 16:16 17:4

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affiliation 5:17

affirmative 20:19

afternoon 16:6

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afternoon's 139:11

agenda 8:2,5

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agreed 43:1

agreeing 20:19

agrees 40:7 122:19

AHAM 17:21,22

18:12,18,22 19:1

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ahead 10:20 75:10

162:17 164:13

AHRAM 17:16

air 9:19 45:18 51:3

56:21,22 61:21

62:19 63:19,21

64:15 91:4,11

airport 144:2

algorithm 130:19

131:19

aligned 18:9

aligning 27:1

aligns 41:3

Alliance 2:12 5:22

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allotment 51:7

allow 50:20 51:4

60:16 62:6 71:21

105:16 118:22

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ambiguity 38:18

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amendments 3:16

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America 1:20 2:17

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amount 66:1 82:22

97:5,9,15 98:1

106:17 134:18

141:16,17 145:4

149:14 152:22

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amp 98:2

amplify 167:21

amps 97:12,12

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59:14 70:16 71:17

72:4 117:12

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analysis 5:11 9:4

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analyzing 36:16

and/or 127:10

128:11

anecdotal 98:17

annual 12:9 27:17

ANSI 14:3

ANSI/AHAM 14:9

ANSI/ASHRAE

14:4

answer 58:19 108:8

111:15 140:19

141:19,20 146:18

146:18 147:2

164:1 165:19

166:1,11

answers 25:14

anti-sweat 89:2

90:8,11

anticipate 99:16

anticipates 80:3

anticipating 77:10

79:22

anybody 52:15

168:7

anymore 44:8

anyway 22:10

42:10

anyways 78:21

apart 48:20,22

appears 72:22

appendices 15:20

15:21
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 171

Appendix 3:16,19

8:11,15 14:14,15

14:16,21 15:4,21

16:2,14 17:7,11

18:13 19:16 20:4

20:7,8 21:1 94:18

94:20 95:4,6,7,8

101:18,21 102:14

103:19,21 104:22

105:18 106:1

109:1,2,11,13,13

109:16,21,21

110:6 111:12,13

111:21 113:6,17

114:18,19 115:3,6

115:11,12,15

116:1,5,12,17

117:7 119:16,21

120:13 122:11,18

122:18,20 124:8

124:10,15,18

127:7 128:17

135:3 138:9 139:2

139:4,8,9 140:10

140:11,12 152:20

Appliance 2:1

applicable 11:19

69:17 70:22 76:3

78:5 103:4 142:5

application 28:5

30:12 67:22 68:8

68:12,14 69:2,14

70:4 73:14,20

74:4,5 76:2 77:8

78:4,6 80:4 81:4

81:11 85:15 86:11

88:5 100:4

applied 101:5

119:10 126:6

apply 71:2

applying 83:17

appreciably 61:22

appreciate 20:18

43:19 54:20 66:6

68:9 104:15

105:10 110:10

111:17

appreciated 37:22

120:18

approach 73:4

98:22

appropriate 18:16

20:9 28:11 48:6

52:9 70:13 110:19

153:6 154:8

argue 140:2

Armstrong 1:15

3:11 4:19,20 6:19

6:19 7:17 10:19

25:1 41:21 42:4,8

43:22 44:12 51:13

52:15,22 57:1,5

58:15,20 60:15

61:6 138:22 141:7

141:18 143:7

147:2,9 160:3

163:11,14,17

164:1 165:18

arrange 59:20

Arshak 55:4 106:5

107:7

Arshak's 108:3

ASAP 2:1

Ashley 1:15 3:11

4:18,19,21 6:19

43:22 51:13 55:19

138:22 140:22

141:9

ASHRAE 6:7

17:16,21 18:2,4,9

18:17,18 19:15

20:5 21:6 26:4,18

26:21 27:5 33:20

34:15,19 37:1

43:20 68:19,22

69:6 83:3 90:5,20

117:16 120:22

134:22

asking 52:2 53:21

60:16

asks 55:4 165:12

ASRAE 38:13

associated 33:5

66:11 77:3 90:11

92:2,16 93:19

94:2 110:18

124:22 131:17

assume 123:1

assuming 120:6

147:1

assumption 42:12

attempt 56:20

authority 11:4

Automated 1:17

6:14 41:10

automatic 90:9

145:10 152:18

156:14 159:1

160:11

automatically

102:20 127:11,20

151:11,19 152:4

157:9 159:17

162:1 163:2

Automobiles 11:12

auxiliary 96:12

97:15 103:16

104:12

availability 92:19

125:11

available 17:21,22

22:12 31:21 32:4

54:21 76:19 77:1

81:14,15 86:17

89:21 90:10 98:5

110:13,16 112:20

114:12 115:9

117:19 118:13

123:15,16 125:4

125:19 126:3

144:19 155:14,16

163:19 164:3

Avenue 1:11

average 12:11

24:14 27:13 38:21

39:4 40:8,9,18,19

46:8,9 47:4,8

48:14,15,17 67:8

68:13,16 69:12

72:9 73:9 74:3

78:13 151:1 153:4

averaged 39:2

averages 49:7

averaging 39:7

aware 57:20 76:14

76:21 92:13 115:1

125:16

Awareness 2:1

axis 31:10

B

B 3:19 8:15 11:10

13:14 14:15,21

16:2,19 17:11

23:22 24:8,16,20

30:3 31:5,16 45:8

45:19 47:19 48:1

51:8,18 52:1,19

53:3,7 94:20 95:6

95:7,8 102:14

103:19 105:18

106:1 109:1,2,11

109:16,22 111:13

113:6,17 114:19

115:6,11,15 116:5

116:12,17 117:7

120:13 122:11,18

122:20 124:8,10

124:15 127:7

138:9 139:2,5

140:10,12 152:20

back 26:10 48:13

63:17 64:12 93:7

106:18 107:2

130:5 131:8,18,22

132:4,22 137:5

141:22 145:14

158:10 160:9

168:15,22

background 53:22

103:8

backwards 107:17

152:14

badge 106:8 168:11

balance 75:2

balances 40:6

base 64:7 156:1

157:18

based 24:18,20

33:14 35:18 45:11

46:17 70:6 76:16

83:1 86:15 93:8

103:1 114:5

127:20 134:1

143:8 144:18

149:12,21 151:15

153:7 157:12,13

163:8,9

basic 32:21 33:8

68:16 118:16,21

118:22 119:11

basically 26:18

38:15 60:16

basis 11:18 53:13

53:15 86:1 146:22

beaker 35:15

becoming 34:11

behavior 140:4

believe 23:9 41:19

42:1 63:14 88:3

140:16 165:16

166:13,21,22

believes 16:15 17:3

20:8 28:9 92:20

93:17 125:9

benefit 75:21

134:12

Berkeley 2:9,18

7:12,19

best 29:17 59:18

60:1 62:7,16 65:6

68:7 70:5 108:10

better 52:6 57:15

79:14 134:16

143:1 144:15,15

159:10 160:7

161:6 167:22

beverage 1:3 4:11

9:5 11:14 13:1,4,9

13:12,14,18,20

14:11 16:18 17:5

18:21 19:12 21:2

22:2,18 28:6,8,14

28:18 29:5,22

30:1,4,7,8,14

31:20 32:10,15,19
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Neal R. Gross and Co., Inc.

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33:18 34:16 35:2

36:3,8 38:12

40:21 46:9,21

48:11 55:10 56:10

56:13 67:11,13,16

87:19 91:15 93:20

94:6,16,17 110:21

111:1 112:10

117:4 123:19

127:8 128:10

129:2 130:11

135:7,9 137:2,19

139:13 151:1

beverages 13:6,7

14:6 32:8,16 36:9

145:4

big 83:13 168:5,12

bit 5:3 33:16 94:10

97:20 106:3 110:9

117:16 128:3

141:21 142:1

166:5

blue 130:9

bottled 13:1,3,5,6

13:11 14:6 67:15

bottles 34:11,14,15

34:21

bottom 31:4,18

45:20 48:8 49:6

64:7,10 130:9

box 83:13 153:11

boxes 15:12 16:10

16:13 166:20

break 8:12,15

101:16 102:6

105:20 106:4,18

168:1

breaker 98:1

breaking 47:10

brief 8:6 107:2

bring 105:7 116:20

151:22

brings 154:9

Brookman 1:11,14

3:11 4:3,8,15 5:14

7:13,21 15:9

20:14 22:6 23:12

25:16 26:12 27:19

30:15 36:12 37:15

41:8 42:2 45:1

50:12,15,18 53:9

54:9,17 55:3,8,12

55:15,18 56:2

58:2 59:10 60:8

62:8 63:2,12

64:19 65:10,12

66:18 70:15 71:13

71:22 72:11 75:8

75:14 82:1,13

84:6 85:19 87:1,4

88:7 95:20 96:1

99:2,5 101:14,19

102:9 106:2,14

107:1,11,19 108:5

116:4,9 117:9

122:15 124:5

129:19 136:7,10

145:5 147:15

154:14 155:21

158:17,22 160:16

161:15 162:14

164:5 165:11

166:18 167:13

budget 83:8

building 4:13 106:9

168:3

built 139:4

bullet 65:7,9

bullets 65:18

bunch 168:9

bundle 61:19

burden 22:20,21

23:3 66:11

burdensome 12:12

39:20 43:9 66:9

122:10 131:1

burning 86:20

105:20

Business 8:17

Butler 1:16 6:16,16

button 108:13

148:15

buttons 135:18

buy 156:3

BVM 13:8 14:1,14

28:21 30:21 46:4

81:16 88:21 93:8

93:10 98:11,15

101:1 104:19

112:12 113:8

123:18 125:5

126:11 142:8,8

143:18,19,22

150:18 152:3

154:5

BVMs 20:12 74:11

92:14 108:16

143:20 144:7

C

C 18:13 19:16 20:4

20:7,8 77:16

87:14

cable 43:17

cables 43:16

cafeteria 168:5,12

calculate 14:10

calculations 93:7

153:8 163:10

California 2:2 6:6

6:7 26:3 42:19

58:9 160:19

call 116:10 125:21

140:1

called 93:3

calling 92:8

campus 168:4

Canada 2:13 6:4

23:15 29:21 116:8

canned 13:1,3,5,6

13:11 14:6 67:15

cans 34:2,5,17,18

34:21 35:9

capable 32:9,17

34:1,10,13,17,20

68:2,16 75:16

126:16,18 127:17

capacity 28:13 29:3

capture 104:18

126:8 131:2,17

134:14 137:18

captures 132:11

capturing 131:6

card 89:18

care 152:1 160:21

carried 147:5

cartons 35:1

case 1:16 6:15,15

17:13 23:21 24:3

24:7,9,12 28:2

31:11 38:2,9

65:22 67:3 69:5

69:13 73:8 77:15

108:15 113:19

cases 61:7,14 93:12

96:17 122:6

category 75:22

104:17

CATHARINE 2:8

causes 54:11

cell 9:22 91:13

center 36:21 37:7

certain 9:20 61:6

62:17 79:9 97:5

166:10

certainly 23:11

73:5 79:1 85:13

85:17 98:22 100:9

117:21 149:20

certification 65:21

74:1,10 76:7

81:13,15,16,18

certified 51:22

69:16 77:8 81:11

125:6 156:19

certify 17:9 33:7

81:13 152:7

certifying 11:18

73:14

chair 6:7 83:3

chairing 26:3

challenge 58:16

chamber 22:22

156:17

change 19:11 38:7

115:20 157:19,20

158:13 160:1

164:9 166:9

changed 164:10

changes 18:3 19:10

84:4 115:19

120:12 153:11

changing 115:21

121:9 135:7

characteristics

36:7

characterized

94:11

charging 91:14

check 42:15 150:15

chose 123:3

Chris 7:3

CHRISTOPHER

1:20

circuit 97:10 98:1,3

98:3

cite 60:10

claim 148:14

clarification 28:2

30:18 36:15 37:13

38:1,10 45:4 56:5

145:9

clarifications 14:19

15:3 16:15,16,21

17:1,4 28:15 36:6

36:16,17 37:16

38:3 69:8 119:22

124:16 139:7

clarify 32:2 33:11

34:8 40:13 57:2

76:2 158:19

clarifying 37:10

89:11

class 13:11,14,15

16:18,19 23:18,22

24:5,8,16,20 30:3

30:3,5,6 31:5,5,7

31:16 32:7 45:7,8

45:12,19 46:12

47:19,19 48:1,1,6

51:8,9,18,18,21

51:22 52:10 73:10

77:16,18 78:19

84:20 87:14 119:1

classes 13:9,10 53:8

55:16
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Neal R. Gross and Co., Inc.

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classification 18:6

49:20 77:16 87:8

87:14

classifications 50:4

55:1 73:11 79:8

classified 55:5

classify 52:19

clean 130:21

clear 15:10 38:2

47:21 48:5 90:4

111:16,20 124:9

130:3 160:3

clearly 63:8 77:17

clock 108:18

clocks 109:7

close 27:8 101:18

101:21 106:7

144:22

closed 145:2

151:15

closing 8:18 167:6

Code 97:6

coffee 106:8,10

108:17

coil 99:22

coin 123:20

Coke 35:22

cold 71:21 91:20

117:4

colleagues 121:7

collect 75:6 76:15

collected 39:8

collectively 59:2

COLLER 7:11

Collin 2:14 6:21

Collins 1:17 6:13

6:13 41:9,9,16

54:3,3,13 59:14

59:14 61:3,16

70:16,16 71:17,17

117:12,12 120:20

121:2 155:22,22

156:12 158:6

159:8

combination 13:13

13:16,17 16:19

23:17,19 24:6

28:6,7,14,18 29:5

29:9,22 30:7,13

32:7 89:21 118:9

119:8,12

combinations

122:8

combines 19:1

come 51:16,17

87:12 88:21

107:17 112:17

124:12 130:5

141:11 149:15

comes 48:3 120:5

142:18 155:5

comfortable 66:16

143:10 150:3

coming 53:13

142:22 166:2,6

commences 9:10

comment 15:12

19:22 20:1 22:4

26:14 30:11 37:14

37:20 41:1 49:10

50:8 51:14 62:10

63:4 64:22 69:20

75:9,12,16 76:21

78:1 79:21 85:13

87:2,5 88:1 98:8

99:1 104:4,15

105:1,10 107:8

117:6 118:5,11

122:14 127:2

136:8 141:15

145:6 148:7

149:18 152:11,15

152:22 153:17

154:4,6,15 156:1

160:17 166:20

commented 29:22

46:11

commenters 40:7

comments 9:12

10:11 15:10 16:9

20:12,14,18,19

25:17 27:21 30:16

36:5,12,13 37:21

39:15 43:19 44:19

45:2,2 46:17

50:12 53:16 58:3

59:11 66:6,19,20

66:21,22 68:10

86:20 95:21

100:10 101:9,15

102:3,4,7 104:3

104:11 105:4,20

105:21 111:18

116:6 117:8,10

120:14 129:20,20

153:20,20 160:20

161:7 166:19

167:2,8,17

commercial 13:4

40:10,16 69:4

164:3

commercially

163:19

committee 6:8 26:4

117:16

common 34:12

52:21 71:8 72:4

74:11 99:17

comparable 44:13

compare 156:2

compared 25:10

48:16

comparison 20:6

25:9 79:22 80:2,9

compartment

28:18,19,21 29:1

29:6,7,8,14,16

complete 9:17

49:22

completely 103:7

109:12,14,22

complex 84:16

85:10

compliance 14:22

17:9 21:20 32:22

76:9 113:7,12

139:3,8

compliant 73:1

complicated 19:5

167:16

complies 11:19

12:3

comply 68:17

121:17

components 83:10

compressors 154:5

comprises 56:13

compromise 59:4

61:12 154:9

concern 50:19

164:7

concerned 28:20

74:20 148:18

concerns 8:7 27:12

54:2 165:8 167:21

concise 9:19

conclusion 151:21

152:3

concur 121:19

concurrently 9:8

condensate 90:14

90:18

condenser 91:2

99:9 100:5,8,20

100:21 123:7

condensing 99:22

condition 21:14,16

21:18,19,22 22:22

24:22 25:6 26:7

27:12,15 38:20

46:20 143:13

conditions 21:5,9

23:2 123:9

conduct 12:13

25:18 49:22

133:11

conducted 134:20

conducting 89:7

configuration 30:9

89:13

configurations

31:22 32:5 33:8

93:15 118:12,15

configure 28:7,15

32:15 99:15 110:6

165:2

configured 30:2,5

31:22 32:5,11

34:14 35:3 89:6

90:1

confirm 65:17

149:9 156:8

confirmed 160:11

conflict 54:1

confusion 47:20

116:21

connected 4:5

102:17

consensus 26:9

conservation 9:4

11:11,14,20 15:2

16:1,4 17:10 18:8

21:11,21 33:1

70:22 77:4 93:1,5

94:21 113:8 120:2

120:11 124:3,12

138:10 139:13

146:20 167:11

conservative

118:19 148:5

149:19

consider 44:17,18

65:19 66:14 74:13

85:6 86:21 111:19

115:16,16 121:22

122:9 132:3

consideration

41:11 118:1

considerations

9:15 70:17

considered 13:15

29:1,14 46:5 73:3

73:6 77:7 115:19

116:3 119:17

120:10 130:6,10

131:10 150:10

considering 21:1

22:1 23:16 43:20

45:4 56:17 67:3

77:3,6 85:2 89:11

120:9 149:7

considers 86:9

consistency 47:18

89:14 91:10

consistent 18:5,19
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20:10 25:10 33:13

40:10,15 69:2

70:7 93:16 95:3

100:16 104:7

118:18,21 120:5

120:17 121:15

130:18 133:1,11

133:20 144:8

consistently 68:2

99:14 100:7

119:10 126:6

154:13

consoles 92:15

construction 34:9

Consulting 1:19,20

2:7,14 6:22 7:2,4

7:6

consume 127:12,13

consumer 11:11

31:11 79:12 80:7

80:8,19,21 102:16

161:11

consumer/custo...

122:5

consumers 80:1,11

165:2

consuming 83:10

89:20 90:7 95:15

114:20 135:6

consumption 16:17

27:17 29:12 33:4

33:18 38:7 62:22

78:2,3 82:8 89:9

94:4 95:9 98:10

99:18,20 100:2

103:11,15,22

104:20 110:18,21

111:8 112:10

114:13 115:20

118:17 121:21

124:22 125:8

131:7,17,20 132:1

134:7,8 137:19

149:15 152:2

consumptive

118:19 119:3

contain 14:19 15:3

36:21

contained 18:17

20:4,8 21:6 56:7

129:4,11

contains 16:2

124:15

content 102:11

CONTENTS 3:6

continue 54:21

76:15 111:18

150:19

continuing 53:6

control 91:22

108:13 125:1

126:13 140:4

157:11,12,13,19

161:20

controlled 128:20

128:21 130:16,17

145:19

controls 126:15

135:4

conversation 10:12

11:6 53:1

conversations 10:2

converted 23:18

24:6

cook 98:3

cool 47:13 64:9

cooled 13:12 29:6

30:6 31:8 45:5,9,9

45:13,16,22 46:1

46:5,19,20 47:11

47:12 49:1,9,11

50:8 51:1,2,3

129:7,8

cooling 89:2

cools 13:5 46:22

copies 8:1

copy 42:6

corner 106:10

corners 48:13

correct 51:10 96:9

141:6,7 145:15

156:11

correspond 16:12

cost 12:9

Council 2:6 6:2

couple 60:21 63:3

95:21 142:16

course 15:13

150:22

COURT 4:7

cover 35:4 63:17,18

168:21

covered 10:16

11:16 12:10,16

16:17 17:5 33:18

38:8 67:12 92:22

93:2,5 95:9

168:20

covers 35:19 89:2

91:5 99:10

Crane 1:18,21 65:4

75:12 79:4

crank 71:14

Crankcase 91:19

CRE 69:19

create 27:2 60:4

87:14

creating 24:11

138:20

credit 89:18 133:22

134:3,11,18

142:17,18 146:16

148:14,19,20

149:3,9,12 150:12

152:22 153:1

157:1,9 158:13,20

159:4 160:2

credited 164:16

credits 156:10

159:22

criteria 43:21

47:22 48:5 54:22

123:22 139:15

criterion 45:7

80:19

crux 122:17

curious 26:17 27:5

143:5 163:3

current 12:20

13:21 15:1 28:9

30:21 40:1 42:12

42:19 57:2,12

58:1,10 90:5

122:12 125:7

126:11 130:13

137:14 139:3,4,5

140:5,7 146:9

currently 17:19

20:10 23:9 33:21

35:20 36:2 37:1

38:10 39:16 45:10

51:11 57:5,20,21

67:6,12,18 68:20

74:14 119:13

120:15 126:19

135:8 145:17

166:8

customer 23:7

31:10 32:14 92:9

93:18,22 94:12

104:13 112:5

115:7 122:2

123:21 156:1

customers 45:22

81:17 82:4 125:12

155:8

cut 57:19

cutout 64:8

cycle 12:11 24:14

CYR 2:8

D

D.C 1:11 4:14

daily 110:20 134:6

149:15

dairy 36:1

data 5:10 39:8

49:18 54:7,20

55:2 75:6 76:15

78:7,15 79:2,13

81:14 84:2 85:14

133:12 144:18

146:8 156:2

database 81:15

Dave 1:16 6:15

David 1:19 7:1

day 9:1 144:2

days 14:17 17:7

74:8 111:22

119:20

de 94:14,21 95:18

97:8 104:21

109:16 110:3

114:1,10,11

de-energization

115:8

de-energize 91:17

110:3 112:4,7

113:20 114:2

de-energized 94:10

94:19 96:19 103:7

103:20 109:12,14

109:20,21 112:6

115:11 130:16

de-energizing

103:18 112:20

115:9

DEC 146:8,8

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107:20 168:16

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rotation 43:17

roughly 42:14

72:16

route 62:17,20

rows 32:13

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rule 13:8,22 14:2

14:18 17:15 18:6

18:8,15 21:12,18

111:20 112:2

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120:11 124:13

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stakeholders

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Stand 82:1 84:6

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Starr 2:11 5:21,21

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53:11,11,19,21

72:12,12 74:16

82:14,15,17 83:2

85:21 96:3 97:2

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147:17 154:15,16

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164:6,6

start 5:15,16 11:2

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131:11 132:21

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started 16:14

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state 77:17 90:7,13

94:20 95:15

103:16,19 104:6

105:15 109:15,19

110:5,9,14 112:14

114:6,14,20 127:8

128:10 129:2

131:12 133:14

134:9 135:1,14

136:22 137:16,20

141:4 142:13

152:15,16 157:3

158:4 167:1

stated 158:7

statement 118:10

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states 96:15

station 145:2

statutory 139:15

stay 88:14 168:4

step 158:7

stick 116:2

stimulation 135:12

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stimuli 145:12

152:17

stop 108:2

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stores 144:22

straight 83:5

straightforward

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struggled 141:20

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stuff 5:4 10:13 11:1

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style 31:17

Suami 2:13 6:3,3

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116:16

Subarna 1:21

64:22 65:11 75:8

75:9 79:5 87:1,4

99:2,4,6 136:7,10

submit 73:19 74:2

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submitted 49:18

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submitting 44:19

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subsequent 16:22

126:4

substantive 106:17

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sufficient 37:17

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suggest 61:4

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suggestion 59:15

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159:19

summary 17:1

support 78:7

supporting 147:18

supposed 159:7,9

sure 36:1 72:18

74:17 85:8 86:5

111:20 136:9,19

142:20 151:22

166:12 168:10

swipe 89:18

switch 98:2

switched 102:19

system 46:21

128:12 129:3

130:18 131:3

142:11 145:18

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systems 1:17,18,22

6:14 41:10 65:4

75:13 91:22 122:4

122:6,8 125:21

127:10 128:12

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t 72:15 83:1

table 3:6 38:15

83:20 94:11

take 8:2,12 10:14

10:14 15:10 30:16

40:21 51:6 61:18

66:16 102:6

105:20 106:4

116:6 133:7 157:8

163:5

taken 41:19 149:10

160:21

takes 168:2

talk 10:22 43:15

84:21 104:3

138:14 146:19

148:2

talked 75:2 150:9

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48:19 49:3,5,14

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113:14 116:2

120:4,22 121:15

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138:20 139:5,17

140:6,17 141:5

142:5 143:12

145:13,22 146:10

146:14 147:20

149:7 150:5,11,18

152:6 153:1,4

154:7,8,11,18

156:7,16 157:3,4

157:17,21 159:16

160:14 161:3,21

162:2,9 163:4

165:17,20,21,21

166:2,7,13,14,14

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67:20 69:16 70:1

82:9 87:9,16

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64:14 66:2 67:21

68:5 75:22 79:10

79:11 88:4,18

121:22 134:2

135:10,16 142:1

143:8,9 149:13,21

157:2 162:4,21

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tests 22:14 38:16

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text 137:5 151:8

thank 7:17 15:16

15:17 25:2 26:12

27:19 50:18 53:9

54:17 62:8 63:2

64:19 65:10,12

72:10 77:22 87:22

98:7,22 118:4

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thanks 15:8 169:1

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thing 26:6 29:20

49:12 50:6 54:11

64:13 65:4 77:14

85:10 86:8 88:6

96:19 100:17,19

102:1 108:10

122:17 130:20

134:13 148:1,8

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things 35:1 80:13

83:11 91:15 92:16

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123:2,13 127:4

133:18,18 139:1

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think 10:18 24:19

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123:13,17 124:9

130:2 132:5 143:7

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160:20 165:19,19

165:22 166:4,11

167:20

thinking 84:17

86:22 118:20

120:3

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65:9 133:13 142:7

third-party 59:20

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73:2 75:4 82:15

83:3 97:20 100:13

103:2 114:16,16

115:14

thoughts 52:16

three 8:3 41:21

42:5,13 129:21

148:19 149:13

158:19 159:4,22

threw 54:6

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time 9:15,16,19

10:22 17:20 20:20

39:4 44:13 88:11

92:4 128:1 130:15

144:4 145:4 153:3

153:6,13 161:12

167:3

timer 151:14

times 22:14 134:10

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timestamp 103:9

timetable 44:1

Title 11:10
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type 5:4 15:18 17:1

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un-mute 64:22

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understood 146:7

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undertaking 12:20

unduly 12:12

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unit 12:10 51:2

56:14 84:10

147:13

units 152:16

unmute 63:7 99:6

unnecessarily

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110:1,3 113:21

unrefrigerated

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unsure 117:17

update 17:14 19:14

74:22

updated 17:18 18:2

138:4

updating 20:1,2

upper 166:9

usage 143:17,18

144:6

use 11:17 12:1,9,11

12:12 17:5,6

24:14 27:13 28:13

29:18 35:20 43:9

50:3 54:22 60:17

61:2,4,9 66:3 71:4

72:20,22 74:3,12

75:19 79:19 82:4

82:7,10,12 93:10

93:17 94:7 97:14

108:15 113:14

119:2 131:3 138:9

139:2,5,8 140:10

140:11 145:1

146:2,3,13 147:21

149:22 152:8

useful 37:19 119:15

166:15

user 103:17 127:11

127:15 128:2

151:10 153:22

user-generated

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uses 83:18

utilities 140:16

utility 23:5

V

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validation 152:6

valuable 55:2

value 39:9 166:7

vandal 63:16

vandalism 91:7

variability 33:16

88:20 89:8 93:13

101:4 113:5 126:8

132:18 133:8,9

144:6 149:20

variable 78:14

122:1

variation 132:12

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variations 39:11

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varies 84:3

variety 11:7 31:21

32:4 57:21 60:3

89:22 92:17 96:8

104:8 111:5

117:18 118:11

122:7 125:19

126:1 139:18

143:13

various 11:8

vary 83:11 93:8

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32:15 34:5,17

35:3 48:16 51:6

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87:19 91:15 93:21

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106:13,14 110:21

111:1 112:8,10,12

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123:19 127:9,13

128:10 129:2

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134:9 135:1,7,10

135:14,15 136:13

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137:2,16,19

139:13 145:10

152:15,16 157:3

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vending-only

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Vendors 1:22

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verbiage 51:11

verification 49:14

50:9 129:6 142:15

149:3,7 150:11

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wanted 28:2 81:21

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111:5 117:18

118:11 122:7

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155:3

10:00 151:17

10:30 8:13

10:45 8:13

100 22:20 168:5

1000 1:11

11 3:14 16:20

11:00 106:15,16,21

11:12 106:22

11:55 8:20

12 34:20 143:6

12-hour 134:21

12-ounce 33:22

34:2,17,17

12:15 168:2

12:17 169:5

121 3:20

13 10:21

15 3:17 97:12

16 1:8

16th 4:13

18 131:11 134:22

135:21,22 137:20

141:11,15 143:5

143:16 145:13

146:5 152:17

18-hour 133:14

134:9

1975 11:6

2

2 152:4

2-hour 150:22

152:3 163:1

2.4 155:3
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 191

20 98:2

20-ounce 34:11,14

34:14,21

2004 14:10 17:16

19:1,19

2006 14:1,1 17:15

18:14

2008 17:22

2009 13:8 18:8

21:11 120:2,7,11

124:3

2010 17:21 37:4

2013 54:5

2014 1:8 4:13

24 131:14,21,22

135:22 143:21

157:5

24-hour 132:1

134:7 136:6

24/7 111:1

3

3 37:1 155:4

30 14:16 17:7 74:8

111:22 119:20

32.1 6:8 17:16,20

21:6 22:10 26:19

26:21 27:4 37:2

38:13 41:20 68:22

32.1-2004 14:4

32.1-2010 19:15

20:9

35 38:22 39:10

75:22 154:21

36 38:16 39:10

45:14 67:6,9

69:13 70:1,19

71:6,9 72:6,9,16

75:17,19 76:4,6,8

76:10,10,12 77:2

77:19 79:11,15

81:1,7 82:7,9,20

84:11,13 131:8

151:5 152:4 153:7

154:20 158:10

163:1,2

37 38:22 39:10

39 154:20

4

4 3:11 19:2

40 43:11 71:19

72:16 82:19 151:2

151:3,5,6 153:5,7

153:17 154:20

158:9 162:22

44 65:6

45 21:13 78:12

5

5 19:2 21:4 33:20

50 22:20 62:14,15

62:15 79:18

50-50 35:21

54 107:3

6

6 19:2 131:13

141:16 143:6,16

146:6

6-hour 133:14

134:9 149:16

64 156:7

65 21:4

67 167:1

68 167:1

7

7.2.2.2 68:19

72 69:6

75 21:12,15,19 23:2

24:15,21 25:5

52:20 154:20,20

8

8 13:22

85 24:19

9
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

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

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

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

192

Refrigerated Beverage Vending

Notice of Proposed Rulemaking

US DOE

09-16-14

Washington, DC