Part I: Manufacturers Speak Their Mind About New Efficiency Rules: EXCLUSIVE

“Do we need to carve our request into your forehead?”
“YOUR BLOODY JOB IS TO BLOODY WELL FIGURE HOW TO GET OVER IT!”
“you can just fix the bullet hole and go about your day………..have you considered that?”

Did manufacturers actually say this during the December 10, 2009 "Public Meeting on the Preliminary Analysis for Residential Refrigerators, Refrigerator - Freezers and Freezers"?  Nope!  They did not. 
We've attempted to reduce the 244 page transcript to a manageable 4 pages, and may have taken one or two liberties to condense both what they were saying, and must have been feeling and wish that they had said.  Shockingly, at least some of what follows is actually Verbatim.


ApplianceAdvisor.com's
Digest of the Public Meeting on the Preliminary Analysis for Residential Refrigerators, Refrigerator-Freezers and Freezers
(or the Digest of PMPARRRFF)

Subject:  Ice Making Energy Excluded from Current and Future Testing
Pg 28 - 62

Consultant: Mr. W
Of course the energy for ice making is not included in the new testing because no one explicitly asked for it in the new testing using the Golden Rod test change request form.
 
Appliance Standards: Mr. D
What glue are you sniffing? In the joint comments filed by ASAP, ACEEE, NRDC, PG&E, and the Power and Conservation Council, as well as others, we wrote, “Where is the Department’s updated test procedure to explicitly address the energy consumption for ice–making functions and to address the associated heat losses?”
So, your second bullet on that slide is complete bull-(deleted). Do we need to carve our request into your forehead?
 
Sub Zero: Mr. T
Oh ice making energy testing is sooooo hard! This is NOT easy. Hard....that's what is.  Not easy at all.
 
Consultants: Mr. W
I mean are there even any technologies to reduce the energy used to make ice? So why include ice making energy in the testing at all? Really, it’s just ice, a mere phase change. Ice has been around for, what, 5 billion years. I don’t think we need to test ice making energy usage.
 
AHAM: Ms. B
Really really hard. We’re looking at 2 years minimum to figure out how to test ice maker energy. And what do you do, just add this energy to the entire unit?  I mean who really uses the ice maker anyway?  I hate ice.
 
Consultants: Mr. W
So for now we are still not including ice making energy in the new rule because we never received a correctly formatted Golden Rod test change form.
 
AHAM: Ms. B
Halleluiah, praise the lord above. Who’s the man? THESE ARE THE BENEFITS OF MEMBERSHIP BABY!
 
Consultant: Mr. W
Will someone help AHAM down from the table? 
 
Subject:  Measuring Freezer and Fridge Volumes
Pg 59
Whirlpool: Mr. C
See I don’t get it. The new test should have reduced fridge volumes by excluding the ice maker volume and the dispenser volumes from the total. Can someone tell me how come these volumes are all higher?
 
DOE: Mr. L
Don’t look at me pal. This comes from AHAM
 
AHAM: Ms. B
Oh, look at that. Hmm, how could that have happened? I am just so bad with numbers. With my liberal arts degree I can hardly handle a stapler.  I'll check them over again, but let's just use these numbers for now.
(AHAM writes note self:  have transcript amended)
 
Subject:  Efficiency Targets Based on Existing Technology
Pg 72
 
Consultant: Mr. W
So we started analyzing how low we could get using the "max tech", the maximum available technology, to develop these efficiency targets.
 
Sub Zero: Mr. T.
In the analysis, did you use technology provided by a species of alien super beings, because this is fantasy?

AHAM:  Ms B
How the hell do you expect our dues paying members to jam all that difficult-to-spell-technology into the fridge box and still leave room for food? Don’t blame me if Americans start to wither away for lack of food.
 
Consultants: Mr. W
WE'RE FREAKING CONSULTANTS.  WE SET THE FREAKING BAR. THAT’S OUR JOB.
YOU, YOU, ARE THE MANUFACTURERS, AND YOUR BLOODY JOB IS TO BLOODY WELL FIGURE HOW TO GET OVER THE BAR.  CLEAR?
 
Group: (inaudible, difficult to understand exactly who said what, many voices, at least one broken glass)
Did you consider the availability of compressors, trionic heat exchangers, or subterfugian lamenters? Did you find suppliers and seek pricing for all of the new components we need? What the hell did you consider in your definition of max tech? You make me want to vomit. (inaudible, glass breaking, inaudible)

Subject:  Vacuum Insulated Panels (basically fridges made with really efficient Thermos type walls)
Pg 93
AHAM: Ms B.
DOE requirements are going to require VIPs. Are you whack? Who can make these things? You know India already requires VIPs? You CANNOT expect us to keep up with India? Have you fully thought this out?

Appliance Standards: Mr. D
Not to be dick, but AHAM you are an idiot. The rules require a level of performance, NOT a solution to reach the performance. Your pansy-ass clients can solve the performance issue in anyway they see fit.
 
Sub Zero: Mr. T
(thinking to himself......really wanting to say VIPs are bad.....but then how to explain that SZ is already using them?)
This is very very hard. You want so so so so so many VIPs. Sure we use them now, but we question how the laws of supply and demand will ever ramp up to meet the demand. How are they going to make all of these VIPs. So so many VIPs. And, and, and you shoot a bullet into a VIP and it’s ruined, the whole fridge. Can’t be fixed. DO YOU HEAR ME? IT CAN'T BE FIXED!!! You can empty a machine gun into a regular fridge, and you can just fix the bullet holes and go about your day…….have you considered that, I bet you haven’t considered that, I bet.
 
Subject:  Different Product Classes
Pg 101
Explanation: More classes makes it easier for less efficient applances (like Side by Sides) to continue to be made since they only compete in pools of appliances just like themselves. Each additional class is just another team in the appliance Special Olympics.
 
Sub Zero: Mr. T
Sub Zero wants built-in fridges to be in a separate class. Of course built-in’s are less efficient. That’s just thermodynamics, and it’s the law. Look we convinced the money-bags to buy wide shallow fridges. Let’s not punish the wealthy cause they want something contrary to the current laws of the universe.
Look at your own damn rules. DOE’s criteria for separate product classes include in the statute, and I quote, “Capacity or other performance–related features such as those that provide utility to the consumer,”
 
Our bloody fridges provide "utility" like it's nobody's business. How else will the rich differentiate themselves from the mouth breathing mucus swallowing masses? Are we to ask folks with 9 digit bank statements to store their food in a GE Profile top mount with finger print hiding texturing? They would sooner set themselves on fire with a fine brandy.
 
And we are already using every technology so far discussed……..though we may not be using every technology in every model…….really we might only be using one technology in each model, and not every one as I implied……..actually I wonder if we put all the technologies together in one unit if we could actually hit the efficiency requirements……..but we really don’t want to have that in the record. Please strike my last mumblings.
 
If you require us to meet these new numbers;
built-in refrigerators
made FOR rich people
BY poor people
could perish from the earth.

Did I mention that we hire Americans? We’re in Wisconsin, and Mexicans haven’t figured out how to get there yet. Did I mention that we are a small company with a paltry $1 billion in annual sales.
Whispered: Oh my god, I shouldn’t have said that, what was I thinking, can you please, please delete that last financial bit from the transcript, I have a wife……they’ll kill me, kill me. (inaudible, quiet weeping)
How can we build the fridges required by our sexually perverse self-centered super rich clientele AND, quote unquote, save the planet? (speaker smirks) See my point? It cannot be done.
 
AHAM: Ms B.
That was a great speech from Sub Zero. We completely agree with those guys. We sooo support Sub Zero in their desire for a separate class, so much that we will write it down on paper and send it to you again.   WITH A STAMP!!
 
Subject:  Collecting Actual Energy Usage from Real People’s Fridges in the Field
Pg 119
AHAM: Ms B.
Do not collect field energy usage.
 
Pg 127
AHAM: Ms B.
Do not collect field energy usage
 
Pg 150
AHAM: Ms B.
Please, please, please, dear God, do not collect field energy usage.
 
Subject:  Side Effects of New Regulation
Pg 203
Consultant: Mr. W.
We surveyed manufacturers and they said:
These requirements are going to cost millions, requiring factories to be completely updated and therefore to close, starvation will sweep the land. Factories will then open in Mexico, because they’ll allow bloody anything in Mexico; the wankers. Add to that the Climate bill coming any day now, regulating CO2 emissions.
 
And all the changes in Canadian and European regulation, we can’t possibly meet all of these regulations at the same time. And what if the only answer is a thicker walled fridge to reach these standards? Where are you going to put the bloody insulation? That’s right you need to take it away from food storage volume to keep the fixed exterior volume.
 
Appliance Standards: Mr D.
What! Manufacturers have to make upgrades ALL the time. When we finally launch this standard it will be 14 years since the last standard. It’s about time.
 
Consultant: Mr. W
Really if you need to make thicker insulated refrigerator walls you will completely destroy the industry forcing it to rebuild in Mexico. We Americans will be forced to return to caves, and create a new cave language, and wear skimpy animal skins that make us look fat. Fat and unattractive.  Cave shagging of domesticated guinea pigs will be the only joy left to us. Is guinea shagging in unlit caves worth thicker walled refrigerators? I think not.
 
Appliance Standards: Mr. D
Really? Guinea shagging will be all the “rage”? You sir are a sorry piece of consulting garbage. None of these regulations have passed, and yet for well over 10 years there has been an exodus of manufacturers to Mexico.  They load up the trucks, program the old GPS for "South", and BANG, they are gone. Didn't you learn anything in your online consulting academy such as the difference between a "Proximate Cause", a "Coincidental Unrelated Event", and "Bull-(deleted)"?
These things are going to bloody well happen whether the standards change or not, you arse.
 
Subject:  Smart Grid
Pg 235
AHAM
Look we are already 235 pages into the transcript and I hope I’m not too late to get this in here, but have we considered just going home and doing nothing? While we sit in the room for hours babbling on and on, the guys down the hall are getting ready to launch the Smart Grid which will make the powerplants more efficient. Man that just trumps us cause using more efficiently made energy just wipes out our plan to use energy more efficiently. We can’t beat that whole powerplant efficiency thing. (whispering) But, but, you guys will love this, we can credit those powerplant efficiencies towards our own efficiency goals. It’s a, hmmm, it's a holistic approach, YAH, holistic approach to energy efficiency, cause we all......all of us.....are in this together………if you know what I mean.
(Manufacturers all nod heads up and down vigorously biting lips)