On November 2, 2010, Nobuko Horii of SANYO North America Corp., Kaz Fukukura and Paul Ramsbottom of SANYO E&E Corp, and Alan Fishel and Adam Bowser of Arent Fox LLP met with Timothy Lynch, Stephanie Weiner, Michael Kido and Laura Barhydt of the Office of the General Counsel and Ashley Armstrong of the Building Technologies Program to discuss ongoing energy-efficiency compliance and certification under Parts 430 and 431 of the Department’s rules and regulations with respect to certain Sanyo refrigeration products and forthcoming guidance on such products. Specifically, Sanyo requested that interested parties be permitted to comment on the forthcoming guidance in advance of the release of such guidance, and if DOE believed an expedited comment cycle was appropriate, Sanyo would not oppose a shortened period for comment. Sanyo also sought guidance on the Department’s
interpretation of the term “basic model” in relation to certain commercial refrigeration products that differed in size but were otherwise comparable in terms of energy consumption and, more generally, the Department’s interpretation of the term “commercial refrigerator” under Part 431.62. Sanyo further sought clarification on the Department’s view on the necessary protocol for submitting certification reports for commercial products.