2012-06-01 Comment response to issues as requested by DOE.

Regarding Docket EERE-2011-BT-TP-0024 IV. Public Participation B. Issues on Which DOE Seeks Comment (p49-50): 1. Pre-approval process for AEDMs - No comment 2. Expand use or AEDMs - Agree that use of AEDMs should be expanded to other products, specifically WICF refrigeration systems. 3. Number of basic models, simulation tool development - Recommend one random sample per product family provided models retain linear relationship regarding performance. Simulation tools are typically developed based on input of variable data acquired and shown to historically impact performance (door use, ambient temperature, product load, etc.) 4. Overall and individual tolerance levels - Agree with proposed +/- 5% provided testing is conducted under regulated utility supply to match (typical electric utility tolerance is +/- 10% which will impact performance). 5. Selection and number of basic models - Recommend that basic models be grouped based on linear performance relationship, with a minimum of one each / maximum three each samples for validation if necessary. 6.Course of action and time to complete for failure to meet certified rating - Will DOE be conducting audit/tests and will they be random or only when prompted by non-compliance? Recommend quarantine of identified non-complying product but allowance for production of like models in compliance to continue contingent upon verification of corrective actions. 7. Disallowance of AEDM for willful mis-rating or multiple non-compliance issues - Agree that AEDM be disallowed for willful mis-use but only to the extent of the manufacturer in question. 8. Necessity of re-substantiation - Agree that re-substantiation be required only if such change directly impacts collection or calculation methods and/or modeling of energy consumption data.