Atkinson-Baker, Inc

Atkinson-Baker, Inc.www.depo.com

June 20, 2019Audio Transcription

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1

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3 AUDIO TRANSCRIPTION OF

4

5 2019 NFPA TECHNICAL MEETING

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8 THURSDAY, JUNE 20, 2019

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19ATKINSON-BAKER, INC.

20 (800) 288-3376www.depo.com

21

22 TRANSCRIBED BY: MARY HARLOW FILE NO. AD067FA

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abohland

Certified Copy



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1 A P P E A R A N C E S

2

3 DAWN MICHELLE BELLIS

4 SECRETARY OF THE STANDARDS COUNCIL

5 UNIDENTIFIED SPEAKERS

6

7 KERRY BELL PRESIDING OFFICER

8

9 LINDA FULLER STAFF COORDINATOR

10 RECORDING SECRETARY FOR THE STANDARDS COUNCIL

11 SUZANNE GALLAGHER

12 NFPA COUNSEL

13 MARK ODE

14 AWARD RECIPIENT

15 CATHERINE STASHAK

16 AWARD RECIPIENT

17 FREDERIC HARTWELL

18 AWARD RECIPIENT

19 HOWARD HOPPER

20 AWARD RECIPIENT

21 ROLAND HUGGINS

22 AWARD RECIPIENT

23 ALAN MANCHE

24 AWARD RECIPIENT

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3

1 SUSAN MCLAUGHLIN AWARD RECIPIENT

2

3 JAMES MUNDY AWARD RECIPIENT

4

5 VINCENT SAPORITA AWARD RECIPIENT

6

7 FRED WALKER AWARD RECIPIENT

8

9 DAN O'CONNOR PRESIDING OFFICER

10

11 WILLIAM KOFFEL

12 MARK HOPKINS

13

14 GEORGE STANLEY

15 KEITH HATTLER (PHONETIC)

16

17 BOB CAPUTO

18 JAMES PETERKIN

19

20 TERRY VICTOR

21 DAVE DEGENAIS (PHONETIC)

22

23 TIM CROUSHORE

24 JONATHAN FLANNERY

25



4

1 TOP MYERS

2 JOHN MCDEVITT

3

4 MARCELO HIRSCHLER

5 WILLIAM FISKE

6

7 MARK RUNYON

8 JOHN CHOLAN (PHONETIC)

9

10 KENNETH BUSH PRESIDING OFFICER

11

12 JARROD ALSTON

13 ANTONINO MARINO

14

15 JAMES CONRAD

16 DAVE SHAPIRO

17

18 ANDREW ELLISON

19 TIM TOMLINSON

20

21 DAVE BURNS (PHONETIC)

22 ANDY OLIVER

23

24 JAY TORLEY (PHONETIC)

25



5

1 JIM REEDY (PHONETIC)

2 KAREN LETONEN (PHONETIC)

3

4 RICHARD HOFFMANN

5 TED LEMOFF

6

7 BRUCE SWIECICKI

8 JOHN PUSKAR

9

10 JAMES QUITER PRESIDING OFFICER

11

12 WILLIAM TILL

13 DAN FINNEGAN

14

15 HOWARD HOPPER

16 JAMES BIGGINS

17

18 JAMES HOUSTON

19 MIKE GURNEE (PHONETIC)

20

21 PAUL HAYES

22 MATT PACE (PHONETIC)

23

24 TIM MYERS

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6

1 MICHAEL BUCKLEY

2 ROBERT DAVIDSON

3

4 DOUG BERKER (PHONETIC)

5 ANTHONY NATALE

6

7 ROBERT HARRIS

8 CHRIS CIONI

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10 THOMAS BRIDER (PHONETIC)

11 CHRIS SEARLES

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13 WILLIAM CANTOR

14 JUSTIN PERRY

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16 JOHN ALLAGER (PHONETIC)

17 JACK LYONS

18 NICK WARNER

19

20 NED WEST

21 BEN DITCHA (PHONETIC)

22

23 EDDIE GEDRY (PHONETIC)

24 CURTIS ASHTON

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7

1 RYAN MCMORROW

2 JOEL HAYES

3

4 MICHAEL JOHNSTON

5 DANIEL MIKAT

6

7 KENNETH BOYCE

8 JIM TARCHINSKI

9

10 JOHN KOVACHIC (PHONETIC)

11 SCOTT CLINE

12

13 HOWARD HERNDON

14 JULIAN BURNS

15

16 JIM DOLLARD

17 CHRIS HUNTER

18

19 BARRY RODGERS

20 MIKE STONE

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22 ROBERT OSBORNE

23 LARRY AYER (PHONETIC)

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25 DAVID HUMPHREY



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1 THOMAS BISHOP

2 RICHARD HOLUB

3

4 BRIAN HOLLAND

5 THOMAS DOMITROVICH

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7 SKIP GREGORY

8 KEITH LAUGHLIN (PHONETIC)

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10 BILL NOLTEE (PHONETIC)

11 DAN BUUCK

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13 MARK HILBERT

14 MARK GOODSON

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16 JOHN MCHAMMISH (PHONETIC)

17 PALMER HICKMAN (PHONETIC)

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19 KEITH WATERS

20 RANDY DOLLAR

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22 BILL TIMMONS (PHONETIC)

23 LORI KELLY (PHONETIC)

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25 BRETT LARSON



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1 MIKE BENNETT

2 ANDY BARBER

3

4 JEFF TERRY (PHONETIC)

5 DALE BRADINSKI (PHONETIC)

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7 RYAN MCCLARNEN (PHONETIC)

8 MARK ODIE (PHONETIC)

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10 RANDY HUNTER

11 JOHN MCKENZIE

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13 PAUL HARRAH (PHONETIC)

14 STEVE LUBSTER (PHONETIC)

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16 ALAN MANCHE

17 BOB TORBIN

18

19 NATHAN PHILLIPS

20 CHRISTINE PORTER

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22 MITCHELL GETHRIE (PHONETIC)

23 PAUL CABOT

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25 RICHARD JONES



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1 CRAIG ROAKS (PHONETIC)

2 JAMES GOLINVEAUX

3 PRESIDING OFFICER

4 PETER GRASER

5

6 KEITH LOFLAND

7 RODRIGO BURN (PHONETIC)

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9 CHARLES MELLOW (PHONETIC)

10 PHIL SIMMONS (PHONETIC)

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12 DALE CRAWFORD

13 GEORGE STRANIERO

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15 JOE ANDRE

16 TOM WARREM (PHONETIC)

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18 BOBBY GRAY

19 DAVID HUMPHREY

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21 PAUL ABERNATHY

22 RICHARD GARBUCK (PHONETIC)

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24 MIKE SMITH

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1 DOUG MULVANEY

2 SCOTT SCHMIDT

3

4 JOEL GORGON (PHONETIC)

5 LINDA LITTLE

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7 JIM ROGERS

8 JASON FISHER

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10 LEO ZIEMAN (PHONETIC)

11 DYAN ALECUMEN (PHONETIC)

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13 TOM MOORE

14 JIM WIESE

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16 ERNIE GALLO (PHONETIC)

17 KURT SEELIGER

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19 GEORGE ZIMMERMAN

20 STANLEY COPPIN (PHONETIC)

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22 BILL MCCOY

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4 PART 1

5

6 (MUSIC)

7 DAWN BELLIS: Good morning, ladies and

8 gentlemen, and welcome to the 2019 NFPA Technical

9 Meeting in San Antonio, Texas. Please take a moment

10 to familiarize yourself with the room, noting exits in

11 the unlikely event of the need to evacuate. Allow me

12 to remind you, being a safety organization, NFPA is

13 always concerned for your safety. Please look around

14 for the marked emergency exits. Keep in mind that the

15 nearest emergency exit may be behind you. In the

16 event of an emergency in the Convention Center, dial

17 9-1-1 from any phone, and notify the operator that you

18 are a guest or employee at the Henry B. Gonzalez

19 Convention Center, at 900 East Market Street. If

20 there's an emergency requiring evacuation, please

21 follow the direction provided by the voice

22 announcement from the fire alarm after the horns and

23 strobe lights go off. Evacuate following the exit

24 sign, NFPA staff, and the Convention Center Emergency

25 Management Team staff. In the event of a fire



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1 incident, the fire alarm signal is a loud beeping

2 sound along with flashing strobe lights, followed by a

3 voice announcement. If you hear the alarm, please

4 quietly leave the room using the exit nearest you.

5 Again, be mindful, and remember that the nearest exit

6 may be behind you.

7 If you are a person with disabilities who has

8 not already made arrangements with NFPA staff for

9 emergency evacuation, please do so at the registration

10 desk at this time. More details regarding evacuation

11 may be found under the General Info tab on the mobile

12 app.

13 During the Technical Meeting, the use of

14 recording devices of any type is prohibited. The

15 regulations governing the development of NFPA

16 Standards, or the Regs, primarily govern the NFPA

17 Standards Development Process, including processing of

18 Certified Amending Motions at Technical Meetings. The

19 complete Regs are available on NFPA's website, within

20 the NFPA 2019 Standards Directory.

21 As a participant in the process, and attendee,

22 you should familiarize yourself with the Guide for the

23 Conduct of Participants in the NFPA Standards

24 Development Process prior to the start of

25 consideration of today's Certified Amending Motions.



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1 Additionally of importance to be familiar with are the

2 NFPA Convention Rules. The Convention Rules establish

3 the process for today's session. Both documents are

4 included in the 2019 NFPA Standards Directory,

5 available on NFPA's website.

6 The Certified Amending Motion of today's

7 session will be taken in the published order of the

8 NFPA Technical Meeting Agenda. For viewing, please

9 see the NFPA website for the NFPA CNE (phonetic)

10 mobile app. The Agenda combines all Certified

11 Amending Motions from the fall of 2018, and annual

12 2019 Motions Committee Report, and identifies which

13 motions will be considered during the Technical

14 Meeting. Only Certified Amending Motions and

15 subsequent allowable follow-up motions, as determined

16 by the Presiding Officer, will be entertained at this

17 meeting. An authorized person must sign in, as per

18 Convention Rules, to indicate presence and intention

19 to pursue each Certified Amending Motion. By

20 obtaining your credentials at registration, you have

21 electronically signed in for these purposes.

22 Statements for the record, statements for which no

23 certified Amending Motions or allowable follow-up

24 motion is available, shall not be permitted. All

25 Certified Amending Motions were reviewed by the



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1 Motions Committee for determination of certification,

2 following submission of Notices of Intent to Make a

3 Motion.

4 Quorum - for the NFPA Technical Meeting, a

5 Quorum is to be established prior to conducting

6 business in consideration of Certified Amending

7 Motions. Should the quorum be lost during

8 proceedings, the session will terminate without

9 further action by the Membership. Any Certified

10 Amending Motions not acted upon prior to the loss of

11 quorum shall be forwarded directly to the Standards

12 Council without recommendation of this meeting, for

13 action related to issuance, in accordance with Section

14 4.7 of the regulations. Any motions to amend or

15 return that passed prior to the loss of quorum shall

16 be processed and forwarded to the Standards Council in

17 accordance with the regs, Sections 4.5.3, 4.6, and

18 4.7.

19 Appeals - any appeals based upon NFPA Technical

20 Meeting actions must be filed with the Standards

21 Council within 20 days following adjournment. Per

22 Section 1.6.2 of the regs, an appeal for any amendment

23 passed at this meeting which fails Committee ballot

24 shall be filed no later than five days after

25 publication of the amendment ballot results.



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1 Typically, results of amendment ballots are published

2 within 20 days of the Technical Meeting's adjournment.

3 Voting - the votes cast at the Technical

4 Meeting, in conjunction with the debate prior to

5 voting, are an integral and important contribution to

6 NFPA's consensus process. Through motions, debate,

7 and voting, you, our NFPA Membership, make

8 recommendations to the Standards Council. The

9 majority vote results today are for the sole purpose

10 of providing recommendations to the Standards Council

11 prior to the issuance of Standards. The Standards

12 Council's decision on issuance is based upon the

13 entire record, including the discussion and resulting

14 votes at the Technical Meeting. Voting at NFPA

15 Technical Meetings is a privilege granted to voting

16 members of the Association who are physically present.

17 Voting members are identified as such on a

18 registration badge, may utilize a voting device, and

19 should be seated in the areas of the room designated

20 for voting members. Presiding Officers, regardless of

21 membership status, do not vote on matters before the

22 Membership. Voting will be recorded and entered

23 through the electronic devices issued at today's

24 registration. In the event of a tie vote, the issue

25 fails.



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1 Presentation and Debate of Certified Amending

2 Motions - once the session begins today, a Presiding

3 Officer will recognize each authorized maker of a

4 motion, or designee, in the published Agenda Order.

5 At that time, to proceed, the maker must approach a

6 microphone to present the motion. Following

7 presentation, the Chair of the responsible Technical

8 Committee shall report.

9 The floor is then opened for discussion.

10 Anyone in attendance has the privilege of

11 participating, speaking either in support of, or

12 opposition to, the motion. Please preface all remarks

13 with your name, company or organizational affiliation,

14 and whether you are speaking in favor of, or against,

15 the presented motion. Again, identify yourself by

16 name, company or organizational affiliation, and your

17 position each time you address the Membership. Should

18 you forget to do so, the Presiding Officer will remind

19 you of this, as the information assists the

20 stenographer of the session. Green signs indicate

21 microphones for supporters of the motion. Red signs

22 indicate microphones for opponents of the motion.

23 Per the regulations governing NFPA Sections, a

24 Section may present a position on a motion at the

25 Technical Meeting. The position of a Section does not



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1 necessarily reflect the views of all Section members,

2 but minimally must have been established by a majority

3 of members, with 25 or more votes cast. The position

4 of a Section is awarded no special status in the NFPA

5 Standards Development Process, and may be weighed and

6 assessed as you, the Membership, deem appropriate.

7 To officially conduct this meeting, the

8 Presiding Officer will allow each speaker three

9 minutes to speak. However, the Presiding Officer may

10 limit speaking time afforded in the event that this

11 becomes necessary. With one minute remaining, a bell

12 will sound, and a timer will appear on the center

13 screen. Once your time has ended, please conclude

14 your remarks.

15 Following close of debate, the Membership will

16 be asked to vote on the motion. Once the vote is

17 final, the Presiding Officer will announce the results

18 of the Membership's vote. If the motion was

19 successful, the Presiding Officer shall entertain

20 follow-up motions, if any. The maker of a follow-up

21 motion shall explain why the motion is in order,

22 before the Presiding Officer makes determination as to

23 whether the motion is proper as a follow-up motion.

24 If determined proper, debate on the floor follows the

25 same order as Certified Amending Motions.



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1 As presentations and debate of each motion

2 continues, five screens will display the text of the

3 motion. Screen One will show the recommended text if

4 the motion passes, or, should the motion's text be

5 lengthy, refer the audience to the electronic Agenda.

6 Screen Two will show the recommended text of the

7 Technical Committee, and if the motion fails. The

8 center screen will show the actual motion, and action

9 on the floor that the iMac camera captures during

10 debate. Following close of a motion's debate and

11 Membership vote, the center screen will display the

12 total number of votes, in support, and in opposition

13 of the motion.

14 Together, we will make the 2019 NFPA Technical

15 Meeting a success. We thank you in advance for your

16 participation, and welcome any comments you may share,

17 and suggested improvements for future events.

18 At this time, I invite you to please take your

19 seats. The 2019 NFPA Technical Meeting will begin

20 shortly. Your efforts to assist us in starting timely

21 are graciously appreciated.

22 UNIDENTIFIED SPEAKER: (unintelligible) into

23 some sort of (unintelligible). We're all set. Thank

24 you.

25 KERRY BELL: Good morning, ladies and



20

1 gentlemen, and welcome to the 2019 NFPA Technical

2 Meeting. My name's Kerry Bell, and it's my distinct

3 pleasure to serve as Chair of your Standards Council,

4 and to take part in this year's meeting. Now, before

5 we go any further, I want to introduce a few

6 individuals here with me on stage. To my immediate

7 left is Linda Fuller, who's the Recording Secretary of

8 the Standards Council.

9 (applause)

10 KERRY BELL: Sitting in the middle of the stage

11 is Dawn Michelle Bellis, Secretary of the Standards

12 Council.

13 (applause)

14 KERRY BELL: Sitting to the left of Dawn is

15 Suzanne Gallagher, NFPA Counsel.

16 (applause)

17 KERRY BELL: As you know, the NFPA Standards

18 Development Process is a consensus process that

19 encourages anyone to participate who is interested in

20 improving safety and reducing loss from fire. We just

21 have countless volunteers who freely share their time

22 and expertise to develop NFPA Standards to address

23 safety concerns, as well as new technologies. It's my

24 pleasure here this morning to recognize some

25 outstanding participants in the NFPA Standards



21

1 Development Process who have made substantial

2 contributions toward advancing NFPA's mission. Please

3 join me in thanking each of these award recipients for

4 their stellar contributions toward advancing, and of

5 developing the NFPA Standards.

6 Now, the first awards that we have to give out

7 here this morning are the Special Achievement Awards.

8 The Special Achievement Award is presented to an

9 individual for their significant contribution to a

10 single project that has advanced the development of

11 NFPA Standards. We have two of these awards to give

12 out here this morning. And the first award goes to

13 Mark Ode, from Peoria, Arizona. Mark, please join me

14 on stage.

15 (applause)

16 DAWN BELLIS: Mark is being recognized today

17 for his active role with the National Electrical Code

18 project. Mark has been a consistent and strong

19 advocate in promoting the NEC. He has presented for

20 NFPA and UL across the United States, and around the

21 world. As a member of the NEC Quarter Century Club,

22 Mark is one of a group recognized for participation as

23 a panel member for 45 years or more. As a well-

24 established panel member of NFPA 70, the National

25 Electrical Code, Mark has served on numerous code-



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1 making panels, including 1, 3, 4, 7, 13 and most

2 notably, the NEC Correlating Committee.

3 Having been involved in the revisions of the

4 NEC since the 1999 cycle as a volunteer, Mark has gone

5 above and beyond to ensure that the NEC is the

6 standard for electrical installations. To have a

7 positive and notable impact in the NEC revision

8 process, panel members must devote a significant

9 amount of time reviewing public inputs, public

10 comments, participating in panel meetings, task

11 groups, and much more. Mark is truly one of the

12 hardest working volunteers involved with the NEC

13 revision process. The level of preparation and

14 attention to detail that Mark brings to every meeting

15 is unsurpassed. His preparation helped each panel to

16 efficiently work through respective Agendas, resulting

17 in numerous panels finishing ahead of schedule.

18 Although all NFPA volunteers spend hours

19 preparing and participating in the NEC revision

20 process, the NEC Correlating Committee is additionally

21 called upon to review the work of all code-making

22 panels for compliance with the NEC style manual, and

23 to ensure the correlating of all revisions. This is

24 an incredibly time consuming and arduous task. Yet,

25 Mark came to every Correlating Committee meeting with



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1 a completed, comprehensive review of each code-making

2 panel's work. This was only achievable through Mark's

3 tireless efforts and steadfast dedication to produce

4 the best possible edition of the NEC. Simply, Mark's

5 participation in the NEC spanning decades is

6 exemplary; his unwavering dedication is truly

7 deserving of this NFPA Special Achievement Award.

8 KERRY BELL: Please join me in congratulating

9 Mark on his Special Achievement Award.

10 (applause)

11 KERRY BELL: Our second Special Achievement

12 Award here this morning goes to Catherine Stashak of

13 the Office of the Illinois Fire Marshal. Catherine,

14 please join me on stage.

15 DAWN BELLIS: Catherine is being recognized

16 today for her active role with the Fire Code project.

17 Cathy joined the NFPA 1 Fire Code Technical Committee

18 in 2016, and has remained an active member of the

19 Committee since that appointment. NFPA 1 is a unique

20 document that relies heavily on the work of task

21 groups to address the extensive variety of topics

22 covered. For recent cycles, Cathy volunteered to

23 serve as the Chair of one of the two main task groups

24 responsible for reviewing proposed changes to the

25 code, as well as other miscellaneous tasks. Serving



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1 in this role required Cathy to actively and

2 attentively be involved in the entire meeting,

3 chairing the task group and reporting the task group's

4 many recommendations to the full Committee. This took

5 place all while volunteering her expertise on

6 hazardous materials, and other processes.

7 In addition to the two primary task groups,

8 there are always a number of task groups that work to

9 address emerging technical topics, or to review

10 updates to hundreds of extracted code sections. Cathy

11 never hesitates to volunteer for one, or all, and is

12 often called upon to serve as Chair.

13 Cathy's portfolio of experience on NFPA

14 Technical Committees, especially through her

15 dedication to the development of NFPA 1 shows her

16 unmatched knowledge of the NFPA Standards Development

17 Process; and in turn, she brings an invaluable opinion

18 to the table by representing code enforcers in her job

19 at the Illinois Office of the State Fire Marshal.

20 When a Technical Committee is debating an issue, Cathy

21 always provides a vital perspective for how code

22 changes and proposed revisions could impact the AHJ

23 community.

24 In addition to serving on the Fire Code

25 Technical Committee, Cathy also serves on the



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1 Technical Committee on Educational and Daycare

2 Occupancy, where she formerly served as Chair; the

3 Technical Committee on Fire Protection Features; and

4 the Technical Committee on Hazardous Waste, where she

5 currently serves as Chair.

6 KERRY BELL: Please join me in congratulating

7 Catherine for her Special Achievement Award.

8 (applause)

9 KERRY BELL: Well, that concludes the Special

10 Achievement Awards. We're going to move on to the

11 Committee Service Awards.

12 The Committee Service Award is given to a

13 committee member for their continuous and exemplary

14 service on one or more committees over a substantial

15 period of time, and in recognition and appreciation of

16 distinguished service in the development of NFPA Codes

17 and Standards. I'm pleased to present this award to

18 the following very worthy individuals.

19 The first award goes to Frederic Hartwell.

20 Frederic, please join me onstage.

21 DAWN BELLIS: Frederic Hartwell, of Hartwell

22 Electrical Services, Incorporated in Amherst,

23 Massachusetts, serves on the National Electrical Code

24 Panel 9, from 1990 to the present.

25 (applause)



26

1 KERRY BELL: Thank you, Frederic, for your many

2 years of service to NFPA and the Standards Development

3 Process.

4 Now let's welcome our next Committee Service

5 Award winner, Howard Hopper. Howard, please join me

6 on the stage.

7 (applause)

8 DAWN BELLIS: Howard Hopper of UL LLC in

9 Fremont, California, serves on the Correlating

10 Committees on Building Code, from 2000 to present;

11 Safety to Life, from 1999 to present; and these

12 associated Technical Committees on Educational and

13 Daycare Occupancies, from 2015 to the present; Fire

14 Protection Features, from 2010 to the present; and

15 Fundamentals, from 1996 through 2004. Howard

16 additionally serves on the Technical Committees for

17 Energy Storage Systems, from 2016 to today; and the

18 Fire Code, from two - excuse me - 1996 through 2007.

19 KERRY BELL: Thank you, Howard, for your many

20 years of service to NFPA, and the Standards

21 Development Process.

22 Now, the next Committee Service Award goes to

23 Roland Huggins. Roland, please join me on stage here.

24 (applause)

25 DAWN BELLIS: Roland Huggins of American Fire



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1 Sprinkler Association in Dallas, Texas, serve on: The

2 Correlating Committees on Building Code, from 2000 to

3 present; Safety to Life, 2000 to present; the

4 Automatic Sprinkler Systems, 1997 to present. He also

5 serves on the Building Code and Safety to Life

6 Technical Committees on: Assemblies - Assembly

7 Occupancies and Membrane Structures, 2003 to 2007;

8 Industrial, Storage, and Miscellaneous Occupancies,

9 2000 to present. Technical Committees on:

10 Inspection, Testing, and Maintenance of Water Based

11 Systems, from 2001 to 2016; Commissioning and

12 Integrated Testing, 2001 to 2013; Rack Storage, from

13 1997 to 1999; the Fire Prevention Code, from 1997 to

14 1999; General Storage, from 1997 to 2003; Water Tanks,

15 from 1996 to 2005. Additionally, he has served on the

16 Automatic Sprinkler Systems Technical Committees on:

17 Sprinkler Systems Discharge Criteria, 1997 to present;

18 and finally, the Private Water Supply Piping Systems,

19 from 1996 to 2001.

20 KERRY BELL: Thank you, Roland, for your may


22 Process.

23 Now, the next award goes to Alan Manche. Alan,

24 please join me on stage here.

25 (applause)



28

1 DAWN BELLIS: Alan Manche of Schneider Electric

2 in Lexington, Kentucky, serves on: The Correlating

3 Committee on the National Electrical Code, from 2012

4 to present; and these associated panels and

5 committees: Code-Making Panel 2, from 2014 to

6 present; Code-Making Panel 20, from 2006 to 2007;

7 Code-Making Panel 10, 2005 to present; Emergency Power

8 Supplies, 2003 to present. Electrical Equipment

9 Maintenance, 2000 to present, being the Chair since

10 2011; Electrical Systems Maintenance from 1999 to

11 present; and finally, Code-Making Panel 8, 1999 to

12 2005.

13 KERRY BELL: Thank you, Alan, for your many


15 Process.

16 Now, the next recipient of the Committee

17 Service Award goes to Susan McLaughlin. Susan, please

18 join me on the stage.

19 (applause)

20 DAWN BELLIS: Susan McLaughlin of MSL Health

21 Care Partners in Barrington, Illinois serves on: The

22 Correlating Committee on Health Care Facilities, from

23 2012 to present; and these associated Technical

24 Committees: Health Care Emergency Management and

25 Security, from 1999 to the present. She's been Chair



29

1 since 2012. Health Care Emergency Preparedness and

2 Disaster Planning, 1999 to 2000; and Laboratories,

3 from 1997 to 2007, serving as Chair from 2000 to 2007.

4 She has also served on the Technical Committees on:

5 Emergency Management and Business Continuity, serving

6 from 2005 to 2009; and Incinerators and Waste Handling

7 Systems, from 1999 until 2002.

8 KERRY BELL: Thank you, Susan, for your many


10 Process.

11 Now, the next award goes to James Mundy.

12 James, please join me on stage.

13 (applause

14 DAWN BELLIS: James Mundy of Asset Protection

15 Associates, Ltd. In Wantagh, New York serves on: The

16 Correlating Committee on Signaling Systems for the

17 Protection of Life and Property, from 1996 to the

18 present; and these associated Technical Committees:

19 Fundamentals of Fire Alarm and Signaling Systems, from

20 1992 until the present; and Carbon Monoxide Detection,

21 1996 through 2004; and again, serving in 2008 through

22 2018. He's also served on the Technical Committees

23 on: Commissioning and Integrated Testing, from 2018

24 to present; Cultural Resources, from 2003 to 2004;

25 Fire Safety and Emergency Symbols, from 1996 to the



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1 present, being Chair since 2015 on that Technical

2 Committee; Building Code and Safety to Life Technical

3 Committees on: Fundamentals, from 2017 until the

4 present; as well as Building Service and Fire

5 Protection Equipment, 2003 to 2004; and the

6 Correlating Committee on the Building Code, from 2003

7 until 2004.

8 KERRY BELL: Thank you, James, for your many


10 Process.

11 Now, let's bring up our next award winner,

12 Vincent Saporita.

13 (applause)

14 DAWN BELLIS: Vincent Saporita of Eaton's

15 Bussmann Business in Villa Ridge, Missouri, serves on:

16 The Correlating Committee on the National Electrical

17 Code, from 2012 to 2019; and these associated panels

18 and committees: Code-Making Panel 11, from 1993 until

19 the present; Electrical Safety in the Workplace, from

20 1997 until 2016; and Code-Making Panel 10, 1993 'til

21 the present.

22 KERRY BELL: Great. Thank you, Vincent, for

23 your many years of service to NFPA and the Standards

24 Development Process.

25 Now, the next award we have is for Fred Walker.



31

1 Fred, please join me on stage.

2 (applause)

3 DAWN BELLIS: Fred Walker of the US Department

4 of the Air Force in Panama City, Florida serves on:

5 The NEC's Code-Making Panel 14, from 1991 until the

6 present; Building Code & Safety to Life Technical

7 Committees on: Educational and Daycare Occupancies,

8 2001 to 2005; and Residential Occupancies, 2001 to

9 2005. Fred has also served in Technical Committees

10 on: Gaseous Fire Extinguishing Systems, from 2005 to

11 the present; Emergency Medical Services, from 2000 to

12 2009; Fire and Emergency Services Technical Committees

13 on Special Operations Protective Clothing and

14 Equipment, 1998 through 2000; Airport Facilities from

15 1987 until today; and Halogenated Fire Extinguishing

16 Systems, from 1987 to 2005. His remaining work was,

17 was done on the Automatic Sprinkler Systems Technical

18 Committee on Foam-Water Sprinklers, from 1987 until

19 2014.

20 KERRY BELL: Thank you, Fred, for your many


22 Process.

23 Now, we have six other Committee Service Award

24 recipients who are not with us here today. But we'd

25 like to acknowledge them and thank them for their



32

1 service, despite their absence.

2 DAWN BELLIS: The remaining NFPA Technical

3 Committee members receiving awards today are: David

4 Burkhart, Code Consultants, Incorporated, in St.

5 Louis, Missouri. David serves on: Automatic

6 Sprinkler Systems Technical Committees on: Sprinkler

7 System Installation Criteria, from 2013 until the

8 present; and Foam-Water Sprinklers in 1997. He's also

9 served on the Technical Committees on: Aircraft

10 Maintenance Operations, from 2010 as Chair, to the

11 present; Portable Fire Extinguishers, from 2000 to the

12 present, being Chair from 2000 until 2010; Signaling

13 Systems - Protective Premises Fire Alarm and Signaling

14 Systems, from 1999 to the present; Cleanrooms, 1997 to

15 1999; and Airport Facilities, from 1991 to the

16 present.

17 Our next recipient is Jonathan Humble, of

18 American Iron and Steel Institute in West Hartford

19 Connecticut. Jonathan serves on: The Building Code

20 and Safety to Life Technical Committees on:

21 Fundamentals, from 2003 to 2006, and again from 2012

22 to the present; Industrial, Storage, and Miscellaneous

23 Occupancies, 2000 to the present; Assembly

24 Occupancies, 2000 to the present; Fire Protection

25 Features, 1996 to the present; Mercantile and Business



33

1 Occupancies, 1996 to the present. He also served on

2 the Technical Committees on: Garages and Parking

3 Structures, from 2015 to the present; Building Code

4 Technical Committee on Building Construction, 2008 to

5 the present; Safety to Life Technical Committee on

6 Alternative Approaches to Life Safety, 1996 to the

7 present; and the Correlating Committee on Building

8 Code, 2008 to the present.

9 Next, we'd like to recognize Peter Larrimer of

10 the US Department of Veteran Affairs in Valencia,

11 Pennsylvania. Peter serves on: The Correlating

12 Committee on Signaling Systems for the Protection of

13 Life and Property, from 1999 until the present; the

14 associated Technical Committees for signaling systems,

15 including: Testing and Maintenance of Fire Alarm and

16 Signaling Systems, from 1994 until the present; and

17 Protected Business - excuse me - Protected Premises

18 Fire Alarm and Signaling Systems, 1994 to the present.

19 The Building Code and Safety to Life Technical

20 Committees on: Board and Care Facilities, 2013 to the

21 present; Health Care Occupancies, 2006 to the present;

22 Building Service and Fire Protection Equipment, 1994

23 to the present. He also serves on the Technical

24 Committees on: Inspection, Testing, and Maintenance

25 of Water-Based Systems, 1997 to the present; Safety to



34

1 Life - Alternative Approaches to Life Safety, 2005 to

2 the present, serving as Chair since 2019; as well as

3 The Correlating Committee on Safety to Life, from 2019

4 to present.

5 Next, we would like to recognize Glenn

6 McGinley, II, Ohio Public Employment Risk Reduction

7 Program, in Maumee, Ohio. Glenn serves on: The

8 Technical Committees on: Confined Space Safe Work

9 Practices, from 2019 to present - excuse me, 2009 to

10 the present; Wastewater Treatment Plants, 2003 to the

11 present, being Chair since 2008.

12 Next, Andrew Minister of Kennewick, Washington.

13 Andrew serves on: The Technical Committee on

14 Laboratories Using Chemicals, from 1995 to the

15 present, being Chair since 2007.

16 And finally, David Wallis, a Consultant from

17 Parkville, Maryland. David serves on the Technical

18 Committee on Electrical Safety in the Workplace. He's

19 served on this committee since 1998, and now,

20 currently still participates in that Committee work.

21 KERRY BELL: Again, let's show our thanks and

22 appreciation for all these award recipients.

23 (applause)

24 KERRY BELL: Now, with that, I'm going to turn

25 the floor over to Presiding Officer Dan O'Connor, who



35

1 is going to move forward and proceed with the order of

2 business for the 2019 Technical Meeting. Dan?

3 DAN O'CONNOR: Thank you, Kerry. Good morning,

4 everybody. As introduced, I am Dan O'Connor, and as

5 Presiding Officer, I declare that a quorum is present

6 for purposes of conducting business.

7 Let me remind you, being a safety organization,

8 NFPA is always concerned for your safety. Please look

9 around for the marked exits. In the event of an

10 emergency in the convention center, dial 9-1-1 from

11 your phone, and notify the operator that you are a

12 guest or employee at the Henry B. Gonzalez Convention

13 Center, 900 East Market Street. If there is an

14 emergency requiring evacuation, please follow the

15 direction provided by the voice announcement from the

16 fire alarm after the horns and strobe lights go off.

17 Evacuate following the exit signs, NFPA staff, and the

18 Convention Center Emergency Management Team staff. In

19 the event of a fire incident, the fire alarm signal is

20 a loud beeping sound, along with flashing strobe

21 lights, followed by a voice announcement. If you hear

22 the alarm, please quietly leave the room using the

23 exit nearest you. Again, be mindful, and remember

24 that the nearest exit may be behind you.

25 If you are a person with disabilities who has



36

1 not already made arrangements with NFPA staff for

2 emergency evacuation, please do so at the registration

3 desk at this time. More details regarding evacuation

4 may be found under General Info on the mobile app.

5 During the Technical Meeting, we'd like to

6 remind you that the use of recording devices of any

7 type is prohibited.

8 The votes cast today at the Technical Meeting,

9 in conjunction with the debate prior to voting, are an

10 integral and important contribution to the NFPA's

11 consensus process. Through motions, debate, and

12 voting, you, our NFPA Membership, make recommendations

13 to the Standards Council. The majority vote results

14 today are for the sole purpose of providing

15 recommendations to the Standards Council prior to the

16 issuance of standards.

17 Any appeal based upon Technical Meeting actions

18 must be filed with the Standards Council by July 10,

19 2019 - that is, 20 days following the adjournment of

20 this meeting. An appeal for any amendment passed at

21 this meeting which fails Technical Committee or

22 Correlating Committee ballot, shall be filed no later

23 than five (5) days after publication of the Technical

24 Committee ballot results, in accordance with Section

25 1.6.2(b) of the Regs. Typically, results of amendment



37

1 ballots are published within 20 days of the Technical

2 Meeting adjournment.

3 The Standards Council decision on issuance is

4 based upon the entire record before it, including the

5 debate and resulting votes at this Technical Meeting.

6 The Standards Council will meet on August 5th, 6th, and

7 7th, 2019 to hear appeals and make the final

8 determinations on issuing standards.

9 Today's session will include Certified Amending

10 Motions related to the following NFPA Standards: NFPA

11 25, 58, 70, 130, 302, 502, 654, 801, 855, 1851, and

12 1961.

13 Before we move on to the business of the day,

14 let's confirm that your voting devices are

15 operational. The sample motion you see on the screens

16 - or you will soon see on your screens - are ready for

17 your preview. I will call for a 'test' vote after you

18 have time to read the text presented.

19 The motion on the floor is to Accept Public

20 Comment No. 16. Is there further discussion on Motion

21 2019-1 to Accept Public Comment No. 16? Seeing none,

22 we will move to vote on Motion 2019-1.

23 So on your voting device, you will see the

24 motion number that is being balloted. Touch the

25 'vote' button for that identified motion. This will



38

1 initiate the screen for voting. If you wish to vote

2 in support of the motion, touch 'Yes', associated with

3 the green background. If you wish to vote against the

4 motion, touch 'No', associated with the red

5 background. You may change your vote at any time,

6 until my announcement that voting is closed. Please

7 record your vote now.

8 Voting will close in five seconds.

9 Voting is now closed.

10 The results of the 'test' vote are - should we

11 coming up - we'll have it for you in a second.

12 UNIDENTIFIED SPEAKER: (unintelligible)

13 DAN O'CONNOR: Technical glitch.


15 DAN O'CONNOR: Yeah. Be patient. We'll have,

16 have the test and make sure it's, everything's working

17 fine here in a second.


19 DAN O'CONNOR: Okay. Here we go. So the

20 results of the 'test' vote are: 468 in support of the

21 motion, recommend the test on Screen One; and 272

22 against the motion, and recommend the text on Screen

23 Two. The motion has passed.

24 Okay. It's - keep changing, though.

25 UNIDENTIFIED SPEAKER: Okay.



39

1 DAN O'CONNOR: Okay. I think what we - what we

2 want to - what we want to do here, folks, we want to

3 make sure everything's working well today, before we

4 get into the actual document votes. So we're going to

5 try this again. So let's just go, let's just go

6 through this one more time, and make sure everything

7 is working right. So --

8 UNIDENTIFIED SPEAKER: Hold on one second.

9 DAN O'CONNOR: Hold on. We'll hold on.

10 UNIDENTIFIED SPEAKER: Thank you.

11 DAN O'CONNOR: Those (unintelligible) always

12 cause me problems, anyways.

13 (laughter)

14 UNIDENTIFIED SPEAKER: (unintelligible) the

15 results back up? (unintelligible) bring those results

16 back up. (unintelligible)

17 DAN O'CONNOR: Forty-eight, 282, okay.


19 DAN O'CONNOR: Sure. Are we going to go ahead

20 and (unintelligible) --

21 UNIDENTIFIED SPEAKER: (unintelligible) go

22 ahead and --

23 DAN O'CONNOR: We'll test again --

24 UNIDENTIFIED SPEAKER: -- doing the test again?

25 UNIDENTIFIED SPEAKER: Yeah.



40


2 UNIDENTIFIED SPEAKER: Run it through one more

3 time. Okay.

4 DAN O'CONNOR: Okay. Okay, folks. Thanks for

5 your patience this morning on this. We, we do want to

6 make sure the voting works correctly here. So I'm

7 going to take it from the top again.

8 The motion on the floor is to accept - I would

9 - are you guys ready? Yeah. Okay. The motion on the

10 floor is to Accept Public Comment No. 16. Is there

11 any further discussion on Motion 2019-1, to Accept

12 Public Comment, No. 16? Seeing none, we will move to

13 vote on Motion 2019-1.

14 On your voting device, you will see the motion

15 number that is being balloted. Touch the 'vote'

16 button for that identified motion. This will initiate

17 the screen for voting. If you wish to vote in support

18 of the motion, touch 'Yes', associated with the green

19 button. And if you wish to vote against the motion,

20 touch 'No', associated with the red background. You

21 may change your vote at any time, until my

22 announcement that voting is closed. Please record

23 your vote now.


25 Voting is now closed.



41

1 The results of the 'test' vote are: 431 in

2 support of the motion, and recommend the text on

3 Screen One; and 348 against the motion, and recommend

4 the text on Screen Two. The motion has passed.

5 Okay. Thank you for your patience on that.

6 Okay. The tablet will automatically return to

7 the home page after recording your vote for each

8 motion. If there is a follow-up motion, or a call-

9 the-question motion today, the voting button for those

10 motions will be found at the bottom of the list of

11 motions, meaning you'll have to scroll all the way

12 down to the bottom to find that. The Presiding

13 Officer will remind you of the location if either of

14 these motions is made.

15 If for any reason you leave the Tech Session

16 and turn in your tablet, upon your return the NFPA

17 staff will re-scan your badge, and assign you another

18 tablet. Because your voting is linked to your NFPA

19 badge ID, a newly assigned tablet will recall your

20 votes from earlier, and record any new votes.

21 Following the conclusion of today's session, all

22 recorded votes will be purged. NFPA will not maintain

23 anyone's voting record.

24 Let me reiterate that the tablet is assigned by

25 the NFPA badge ID, and you are responsible for



42

1 returning the tablet at the end of today's session.

2 However, a Help Desk is available throughout

3 the duration of the Tech Session, should you have any

4 questions, concerns, or experience difficulties.

5 Now, I have two announcements today regarding

6 our Agenda. We will be changing the order of some

7 NFPA 70 Motions in the Agenda. Motion 70-2 will be

8 discussed following Motion 70-36; and Motion 70-3 will

9 be discussed following Motion 70-40.

10 Additionally, the submitter of Motions 70-20

11 through 24 has requested that we reorder these

12 motions. The Motions Committee will accommodate this

13 request, and those motions will be heard as follows:

14 70-21, 70-22, 70-23, 70-24, and 70-20.

15 There is one more change to the Agenda I'd like

16 to note for you. NFPA and the submitter of Motion

17 130-1 have clarified his intentions regarding Motion

18 130-1. Based on those conversations, Motion 130-1 has

19 been reflectively amended to Reject an Identifiable

20 Part of Second Revision No. 23. Please note that this

21 amendment - the text will appear on the screens when

22 this motion is made, will reflect the changes.

23 Now that, we hope, you are all comfortable with

24 the process and your voting device, we will begin.

25 The first report under consideration this



43

1 morning is that of the Technical Committee on

2 Inspection, Testing, and Maintenance of Water-Based

3 Systems. Here to present the Committee Report is

4 Committee Chair, William Koffel of Koffel Associates,

5 Columbia, Maryland. The Committee Report, that is the

6 First and Second Draft Reports, is located on the

7 Document Information Page for NFPA 25 on the NFPA

8 website. All Certified Amending Motions are contained

9 in the NFPA Technical Meeting (Tech Session) Agenda,

10 and will be displayed behind me, on the screen, as

11 they are under debate.

12 Mr. Koffel will be stepping down as Chair due

13 to the tenure policy, and I would like to express our

14 thanks to Bill for his leadership. Thank you, Bill.

15 (applause)

16 DAN O'CONNOR: Mr. Koffel, will you present the

17 Chair Report?

18 BILL KOFFEL: Mr. Chair, ladies and gentlemen,

19 the Report of the Technical Committee on Inspection,

20 Testing, and Maintenance of Water-Based Systems is

21 presented as found in the First Draft Report, and the

22 Second Draft Report for the 2019 annual revision

23 cycle. The Technical Committee has published a First

24 and Second Draft Report consisting of revisions to

25 NFPA 25, the Standard for the Inspection, Testing, and



44

1 Maintenance of Water-Based Fire Protection Systems.

2 The revisions were submitted to letter ballot of the

3 responsible Technical Committee. The reports and

4 ballot results can be found on the Next Edition tab of

5 the Document Information Page for NFPA 25, at

6 www.nfpa.org/25next. Mr. Chair, I move, for Standards

7 Council issuance, the Committee's Report on NFPA 25.

8 DAN O'CONNOR: Thank you, Mr. Koffel. Let's

9 now proceed with the discussion on Certified Amending

10 Motions on NFPA 25-1. Microphone? Anybody at the

11 microphone? Was --

12 UNIDENTIFIED SPEAKER: Right here.

13 DAN O'CONNOR: Microphone number four, please.

14 MARK HOPKINS: Yes. Thank you, Mr. Chair. My

15 name is Mark Hopkins. I'm with the National Fire

16 Sprinkler Association, representing our Engineering

17 and Standards Committee. We're looking to remove the

18 text that requires inspection of the General

19 Information sign. This is believed --

20 DAN O'CONNOR: Mr. Hopkins?

21 MARK HOPKINS: Yes, Sir.

22 DAN O'CONNOR: I'd like - get you to the -

23 please make the motion.

24 MARK HOPKINS: I'm sorry, Sir. I would like to

25 make the motion to accept 25-1.



45

1 DAN O'CONNOR: So your motion is - to be clear

2 - there's a motion on the floor to Accept Public

3 Comment No. 49?

4 MARK HOPKINS: To accept the motion for 25-1.

5 DAN O'CONNOR: Okay. The motion - that motion

6 is to Accept Public Comment No. 49. Is there a

7 second?

8 UNIDENTIFIED SPEAKER: Second.


10 MARK HOPKINS: Thank you.

11 DAN O'CONNOR: Okay. We do have a second. Mr.

12 Hopkins, would you - just for clarity, would you just

13 please describe your, your position, and your company

14 again, please.

15 MARK HOPKINS: Yes, Sir. Thank you. My name

16 is Mark Hopkins. I represent the National Fire

17 Sprinklers Association's Engineering and Standards

18 Committee. And we're looking to remove the text in

19 Section 528 regarding the General Information sign.

20 This is part of the requirements for NFPA 13 that had

21 been added in the 2007 edition, and subsequently, text

22 had been added into NFPA 25 in the 2011 edition,

23 regarding an Information Sign to cover sprinkler

24 systems that had been in place prior to the adoption

25 of the 2007 edition of NFPA 13. In the 2014 cycle,



46

1 this text was added, now requiring retroactive

2 compliance with the General Information resign - sign

3 requirement of NFPA 13. It already exists in NFPA 13,

4 so there's no need to have this in NFPA 25. Thank

5 you.

6 DAN O'CONNOR: Thank you, Mr. Hopkins. Mr.

7 Koffel, would you like to offer the Committee's

8 position?

9 BILL KOFFEL: Yes. Mr. Hopkins is correct that

10 this is a relatively new requirement in NFPA 13, new

11 to the 2007 edition of NFPA 13. And as he noted, this

12 inspection requirement has now been in several

13 editions of NFPA 25. The Committee believes that the

14 General Information sign provides valuable information

15 regarding the system, and therefore, should be an item

16 that is inspected when required by the, the Standard

17 NFPA 13. We have added an Annex Note in Chapter Four,

18 where there is a requirement for another information

19 sign that is less restrictive, or it contains less

20 detail than what the General Information sign does,

21 that notes that systems installed prior to the 2007

22 edition of NFPA 13 should be inspected per the

23 information sign required in Chapter Four, and not the

24 General Information sign required in Chapter Five.

25 DAN O'CONNOR: Thank you, Gentlemen. With



47

1 that, we will open up debate on the motion. And I'd

2 ask you, when you start, please provide your name,

3 affiliation, and whether you are speaking in support

4 of, or against the motion. Microphone number four,

5 please.

6 GEORGE STANLEY: Hi. Thank you, Mr. Chairman.

7 My name is George Stanley. I'm with Wiginton Fire

8 Protection Engineering, and I'm in - speaking in favor

9 of the motion. I must be crazy to be speaking in

10 favor of this motion, because my company does

11 inspection. And why would I not want to inspect this

12 information sign? Why would I want to save the

13 customer money when this sign is missing? Just to

14 determine if the sign is required could cost the owner

15 hundreds of dollars. To replace the sign, it could

16 cost the owner thousands of dollars.

17 This information sign, as was stated, is not

18 required 'til the 2007 edition of NFPA 13. Well,

19 think about that. There's probably only, maybe 5% of

20 the systems out there that require this sign. But

21 yet, we have to go to every property, and try to

22 inspect this sign, and then determine if it was

23 required, if the system was installed, the 2007

24 edition or later. So that costs the owner money.

25 If the sign was required, and is now missing,



48

1 what does it take to replace that sign? And let's

2 look at what's on the sign. Occupancy classification,

3 commodity classification, so - presence of high piled

4 storage, maximum height of the storage. So some type

5 of engineering evaluation would have to take place.

6 This could cost the owner again, thousands of dollars.

7 The original main drain test - well, if I have the as-

8 built drawings, the original test papers, I might be

9 able to get - basically, you'd have to do a total

10 engineering evaluation.

11 Some municipalities are now having the fire

12 inspectors go in, and they're writing up the property

13 owners. So now we have to determine whether that sign

14 was ever required. We're not losing buildings because

15 of a missing sign. So I would urge you to vote in

16 favor of this motion. Thank you.

17 DAN O'CONNOR: Okay. Thank you, Sir. I will

18 move to microphone - the gentleman at microphone

19 number six.

20 KEITH HATTLER (phonetic): Thank you, Dan. My

21 name is Keith Hattler, representing myself - against

22 the motion. As an authority having jurisdiction, this

23 requirement adds value - value to the sprinkler

24 system. It's been successful in the jurisdictions

25 that I've been in. It gives us the reference for the



49

1 owner to be successful in decision making at that

2 point. It is a positive. If we remove this, it will

3 be a negative.

4 When authorities having jurisdiction are asked

5 about their system, it - and we cannot answer, and we

6 ask them, or tell them to go and find more

7 information, we're labelled as obstructionists. This

8 sign is long term business friendly. It saves time.

9 It's a quick reference source. Where's that original

10 main drain test? That inspector that's doing the main

11 drain test right then and there will know if there's a

12 possible obstruction if the numbers go down. Please,

13 set the - if, if you vote for this motion, you are

14 setting the owner up for failure. Thank you. Vote

15 against.

16 DAN O'CONNOR: Okay. Is there - is - gentleman

17 at microphone number six? Yes.

18 BOB CAPUTO: Thank you, Sir. My name is Bob

19 Caputo. I represent Fire and Life Safety America. I

20 move - I am speaking against the motion on the floor.

21 This information sign is required by NFPA 13, and

22 provides all of the relevant data for the design

23 criteria of the system, along with the original flow

24 test data, as well as the arrangement of storage,

25 commodities stored.



50

1 The one thing we're guaranteed in so many

2 buildings, is change - whether it's change in

3 occupant, ownership, methods of storage, packaging

4 materials, and so on. This information on this sign

5 is critical from the onset, because we are not very

6 likely to find the original as-built drawings or

7 design criteria years later. While I agree that there

8 might be some difficulty in determining if this system

9 was installed prior or after to the 2007 edition, 50

10 years from now, that minimal percentage of newer

11 systems certainly will be more pervasive, and 50 years

12 from now, there'll be someone else using that data to

13 the benefit of the owner, the benefit of the AHJ, and

14 the benefit of good fire and life safety.

15 I urge you to vote against this requirement.

16 This sign - this requirement, if you will, is no

17 different than the requirement to verify that the

18 hydraulic data nameplate is present. But there is no

19 retrofit requirement for this, and there's no

20 requirement in 25 that says if the sign is not

21 present, I have to go back and conduct a design

22 evaluation to reestablish the data, as we do now

23 require for the hydraulic data nameplate. So there is

24 not a retrofit cost to the owner. It's valuable

25 information. It's invaluable for AHJs, as occupancies



51

1 change. There's no other or better way to find this

2 information. It's a benefit to the owner, not a

3 hindrance. I encourage you to vote negative. Thank

4 you.

5 DAN O'CONNOR: Thank you, Sir. I will move to

6 the gentleman at microphone number four.

7 MARK HOPKINS: Thank you, Mr. Chair. Again,

8 Mark Hopkins, NFSA. I just wanted to bring up a

9 couple of points. Part of the challenge is that this

10 is --

11 DAN O'CONNOR: Mr. Hopkins --

12 MARK HOPKINS: Yes, Sir.

13 DAN O'CONNOR: -- you are --

14 MARK HOPKINS: I'm in favor of the motion.

15 DAN O'CONNOR: Thank you.

16 MARK HOPKINS: Okay. Part of the challenge is

17 that there are many jurisdictions that are looking at

18 this as a retrofit requirement. So although we

19 completely agree that there is value to having this,

20 and its place is in NFPA 13 which provides the basic

21 requirement, so the information sign would be provided

22 with the original system installation; for any system

23 in accordance with NFPA 2007 edition of two thousand -

24 oh, I'm sorry, NFPA 2007 edition or later. So we

25 aren't arguing that that has merit, has value. All,



52

1 all that we're trying to make the point is that we

2 have an issue with trying to achieve 100% compliance

3 of inspection, testing, and maintenance. This is one

4 situation where it's placing AHJs against contractors

5 for no apparent reason, because it's being interpreted

6 as a retrofit requirement, which acts completely

7 against this move to get 100% compliance.

8 So we have reference to big data and

9 collection, but we also have an attempt to try to

10 achieve better compliance. This helps to work against

11 that cause. So we urge you to vote in favor of this

12 motion. Thank you.

13 DAN O'CONNOR: Thank you. Is there any further

14 discussion on Motion 25-1 to Accept Public Comment No.

15 49? Okay. Mr. Chair, do you have any final comments?

16 MR. KOFFEL: No, Sir.

17 DAN O'CONNOR: Okay. Seeing there's no other

18 further comments, we will move to a vote. Thank you,

19 Mr. Chair.

20 Before we - we - but before we vote, let me

21 restate the motion. The motion on the floor is to

22 Accept Public Comment No. 49. To vote, touch the

23 'vote' button. If you wish to vote in support of the

24 motion, and recommend the text on Screen One, touch

25 'Yes'. If you wish to vote against the motion, and



53

1 recommend the text on Screen Two, touch 'No'. Please

2 record your vote.

3 The voting will close in five seconds.

4 The voting is closed.

5 The results of the vote are: 211 in support of

6 the motion and recommend the text on Screen One; and

7 408 against the motion, and recommend the text on

8 Screen Two. The motion has failed.

9 Okay. We'll now proceed with the discussion on

10 Certified Amending Motion 25-2. Microphone number

11 one, please.

12 JAMES PETERKIN: Yes. James Peterkin, TLC

13 Engineering Solutions, and I'd like to move to Accept

14 Certified Amended Motion 25-2, which is to Reject

15 Second Revision 42.

16 DAN O'CONNOR: Thank you, Sir. There is a

17 motion on the floor to Reject Second Revision No. 42.

18 Is there a second? Okay, I heard a second there. We

19 do have a second. Please proceed with the discussion

20 on the motion.

21 JAMES PETERKIN: Yes. So we, we understand

22 what the Committee is trying to do here and, and don't

23 necessarily have issue with the concept, but I think

24 some words that they're using are incorrect, or, or

25 have some consequences that go too far.



54

1 In the First Revision, they added some language

2 to try to define deficiencies when doing fire pump

3 tests, that the fire pump performance has degraded.

4 But in the Second Revision, they went a little too far

5 and called a pump that still meets the, the system

6 demand, a deficiency. And if the system demand is

7 met, how is that a deficiency.

8 The second thing, which is more important, is

9 that they called a - when a system maximum demand is

10 not met, it is an impairment. An impairments - words

11 having meaning. And an, an impairment is a system is

12 out of service. We all know that, like 95% of fires

13 are controlled by five sprinklers. A fire pump that

14 is deficient but still in service can still provide

15 protection. An impairment means that a facility has

16 to be either evacuated, or a fire service, or I mean a

17 fire watch has to be implemented. What's the fire

18 watch going to do? We have sprinklers in service. We

19 are going to get water flow. We are going to get

20 notification. It's not an impairment. It's a

21 deficiency. It does have to be addressed. It has to

22 be corrected. But impairment's the wrong word, and

23 that has consequences that are a little far reaching.

24 So I'd urge you to support the motion.

25 DAN O'CONNOR: Thank you. Mr. Koffel, would



55

1 you like to give the Committee's position?

2 BILL KOFFEL: Thank you, Mr. Chair. While I

3 suspect most of the discussion will focus on parens

4 (3), there probably are two technical changes related

5 to this motion. You will note in parens (4) that if

6 the motion passes, excessive vibration is identified

7 as a deficiency only if the pump performance has

8 degraded. The Committee made a change to say that

9 excessive vibration discovered during the test of a

10 pump is a deficiency, even if it did not adversely

11 affect the performance of the pump.

12 However, again, I think the real focus is on

13 parens (3), and as was stated by the maker of the

14 motion, the issue is, do we call this a deficiency, or

15 do we call this an impairment?

16 So currently the Standard indicates that we

17 permit some degradation of the pump, 5% degradation,

18 provided it still meets system demand, and if I exceed

19 that 5% but still meet system demand, an investigation

20 needs to be performed as to why your pump degradation

21 has occurred. With this language, at any point in

22 time if I go below the system demand, it will be

23 classified as an impairment.

24 And then finally, I would just note for the

25 record - and I don't think this should influence



56

1 anybody's vote - that if this motion passes, there

2 most likely needs to be some editorial correlation

3 between this language and the language in 8.3.7.2.3,

4 because we made some changes in that section. The

5 references identified in the motion are no longer

6 correct, but there's also some editorial language

7 change that would probably be needed. Again, I don't

8 think that should influence anybody's vote. I just

9 want to make sure that's on the record.

10 DAN O'CONNOR: Thank you, gentlemen. With

11 that, we will open up debate on the motion. Again,

12 please provide your name, affiliation, and whether you

13 are speaking in support of, or against the motion.

14 Microphone number six, please.

15 BOB CAPUTO: Thank you. Bob Caputo, Fire and

16 Life Safety America, speaking against the motion. The

17 problem with the motion is that, while I agree that a

18 degraded pump performance above the 5% mark isn't a

19 problem, when we have a pump that doesn't meet system

20 demand, that is our water supply. If we do not meet

21 system demand, this is a serious situation, especially

22 in hospital or healthcare occupancies. Because this

23 proposed motion doesn't quantify or qualify what the

24 degraded performance could be, if my performance of my

25 pump is 5% below system demand, 10%, 40% - it's all



57

1 lumped together to say this is just a deficiency, and

2 not a, an impairment.

3 If my water supply is not robust enough in flow

4 or pressure to meet my system demand, that is clearly

5 and absolutely a condition that rises to immediate

6 concern - perhaps not in your warehouse, protecting

7 boxes; but certainly in healthcare facilities, office

8 buildings, residential occupancies - this is a bridge

9 too far for me.

10 If the proponent had put a qualified percentage

11 of degradation below system demand, I perhaps could

12 have supported this. But this is just too broad.

13 This needs to remain an impairment. Thank you.

14 DAN O'CONNOR: Thank you, Sir. Microphone

15 number three.

16 TERRY VICTOR: Thank you, Mr. Chair. Terry

17 Victor with Johnson Controls Fire Protection. I'm

18 speaking against the motion. As Mr. Caputo has, has

19 said, the fact that a fire pump can't meet system

20 demand is, is a real problem. That's a water supply

21 that, that cannot supply the, the calculated demand

22 for the sprinkler system. But it doesn't just apply

23 to healthcare. The entire section on fire pumps

24 applies to all water based fire protection systems.

25 So while we have some ability to have sprinklers that



58

1 open up, you know, one or two usually control a fire,

2 we, we calculate for more than that in the system

3 demand, we also have systems such as water spray

4 systems, and foam systems that are protecting high

5 hazards that depend on that water supply to be exactly

6 as the system demand requires it - water spray,

7 especially. Every drop of water that's coming out of

8 that fire pump is needed to control that fire. High

9 rise - or high hazard warehousing, same situation. We

10 need that water supply to meet system demand to

11 control that fire in that warehouse.

12 And yes, calling it an impairment means that

13 you have some - something to do. Chapter 14 in NFPA

14 25 requires you to have either a fire watch, or to

15 take some other action in order to correct that

16 impairment. Unfortunately, by calling it a

17 deficiency, there's no urgency built into NFPA 25 to

18 have that deficiency corrected in any timely manner.

19 There's no benchmark, no 30 days, no two weeks.

20 Deficiencies can be corrected, you know, at any pace

21 in accordance with the building owner and the AHJ. So

22 there just isn't an urgency to take care of that, that

23 situation.

24 And a pump that's not meeting system demand

25 doesn't just happen overnight. That pump has been



59

1 degrading over time. If the annual tests are done in

2 accordance with NFPA 25, you would be seeing a gradual

3 decline in the ability of that pump to meet the system

4 demand, and actions should have been taken long before

5 it reached that threshold. So there's ample time to

6 correct a pump that's becoming deficient toward that

7 system demand line, and it, it needs to be at that

8 point, to make sure that it can provide the water

9 supply necessary for the systems. So I urge you to

10 vote opposed to this motion. Thank you.

11 DAN O'CONNOR: Thank you. Gentleman at

12 microphone number one.

13 DAVE DEGENAIS (phonetic): Yes, good morning.

14 Dave Degenais, speaking on behalf of the Healthcare

15 Section, in favor of the motion.

16 Yesterday at the Healthcare Section Membership

17 Meeting, the Membership voted to support this motion.

18 Healthcare believes this is, in fact, a problem that

19 needs to be addressed. We also believe there are

20 situations that exist, whether it's called a

21 deficiency or an impairment, that give expectations

22 around how this type of an issue would be addressed.

23 The true question to the Membership is, is this

24 a deficiency, or is it an impairment? So that's

25 easily answered by simply going to the definitions



60

1 that we have within NFPA 25. NFPA 25 says under

2 Deficiency, 3.3.8, and I will paraphrase - the - a

3 condition that has the potential to adversely in fact

4 the - affect the performance of the system.

5 Everything we're talking about - look at the,

6 what's on the screen. You see the word 'performance'

7 through all of the elements there. This is a

8 performance issue. And the definition says that if it

9 affects the performance, it is, in fact, a deficiency.

10 Furthermore, if you go down to the definition

11 of impairment, 3.3.22 - it says a condition - and I'm

12 paraphrasing - a condition with a system or a portion

13 of a system is out of order, and may not operate in

14 the event of a fire. This is not an out of order

15 item. It is in service. It has some deficiencies

16 that need to be corrected. For decades, we've been

17 working with the AHJ to work through all those,

18 through those deficiencies. The bottom line is that

19 this does not elevate to the level of an impairment.

20 So we've heard terms about the, the owners have

21 whatever time they want to fix it. That is not

22 factually true. We know that if we have a deficiency,

23 we must coordinate and, and, and work with the AHJ to

24 determine how that deficiency is going to be

25 corrected.



61

1 So I want to be clear. The Healthcare Section

2 does not think this should not be addressed. We fully

3 agree it should be addressed. What we're suggesting

4 is based on the definition, and based on the entire

5 premise of how items are addressed within NFPA 25, and

6 per the definition that exists in the document, this

7 is clearly a deficiency, and doesn't warrant the level

8 of an impairment. We request, and we urge you to vote

9 in favor of this motion. Thank you.

10 DAN O'CONNOR: Okay. I'll move to microphone

11 number two.

12 MARK HOPKINS: Yes. Thank you, Mr. Chair. I'm

13 in opposition of the motion. My name's Mark Hopkins.

14 I'm with NFSA. And I just wanted to add that this

15 issue of, of deficiencies versus impairments was

16 discussed at the NFPA 25 meetings in, in some detail,

17 and the information that Mr. Victor had provided was

18 considered to be imperative to the Committee as part

19 of the rationale to move this from a deficiency to an

20 impairment, since the pump was inadequate to provide

21 the system demand. So I thought it was important for

22 people to know that the Committee did have much debate

23 on this issue, and felt that this should raise to the

24 level of an impairment. Thank you, Sir.

25 DAN O'CONNOR: Thank you. I will move to



62

1 microphone number four, and then I will come back to

2 six after number four.

3 TIM CROUSHORE: My name's Tim Croushore, just

4 representing myself. I have a question on

5 Parliamentary procedure. When we get to vote, how to

6 we register an official abstention to the vote? Do we

7 just not vote? Because when I pressed the voting

8 button, I didn't have the option to register an

9 official abstention. We've heard a lot of good techs

10 back and forth, but I'm an electrical guy, and I don't

11 know which way to vote. So how do we record an

12 abstention? Just not vote? Or is, is that the way we

13 should do this?

14 DAN O'CONNOR: Well, choices are to vote for

15 the - 'Yes' on the green, green side, in favor; or

16 vote 'No' on the red side, against; or not vote.

17 TIM CROUSHORE: So an abstention would be no

18 vote.

19 DAN O'CONNOR: Yes.

20 UNIDENTIFIED SPEAKERS: (unintelligible)

21 TIM CROUSHORE: Thank you.

22 UNIDENTIFIED SPEAKERS: No.

23 UNIDENTIFIED SPEAKER: No, you would not vote.

24 UNIDENTIFIED SPEAKER: It's a --

25 UNIDENTIFIED SPEAKER: It's a (unintelligible)



63

1 vote, though.

2 DAN O'CONNOR: No, you're just not - you're

3 just not voting, Sir.

4 UNIDENTIFIED SPEAKER: There is no abstention.

5 DAN O'CONNOR: There's no absten-- a 'No' is

6 against the motion. Let me be clear. A 'No' is

7 against the motion. There is not an abstention; you

8 just do not vote. So if people do not wish to vote on

9 the issue, you do, do not press, press One or Two. Is

10 that clear?

11 UNIDENTIFIED SPEAKER: I think that should be

12 clear.

13 DAN O'CONNOR: Okay. Okay. With that, we will

14 move back to microphone number six.

15 BOB CAPUTO: Thank you. Bob Caputo, Fire and

16 Life Safety America, speaking against the motion on

17 the floor.

18 Our firm performs in excess of 40,000

19 inspections per year, in about 46 states last year.

20 We do not report non-critical, or critical

21 deficiencies to AHJs unless they specifically require

22 us to do so. However, impairments are definitely

23 reported and immediately acted upon. In this case, we

24 are talking about the water supply to the system.

25 We're not really talking about a fire pump; we're



64

1 talking about the water supply. NFPA 13 defines the

2 fire pump as being the water supply. When the water

3 supply is not adequate in flow or pressure to meet

4 system demand, we do not have a situation that doesn't

5 need absolute immediate attention. So for that

6 reason, I encourage you to vote against this motion.

7 Thank you.

8 DAN O'CONNOR: Thank you, Sir. I am going to

9 move to microphone number one.

10 JONATHAN FLANNERY: Thank you. Jonathan

11 Flannery with the American Society for Healthcare

12 Engineering, in favor of the motion. What we'd like

13 to point out is the fact that the word 'deficiency'

14 has been in this requirement for a significantly long

15 time, and there's no documentation, or no issues that

16 we are aware of from the previous years where this has

17 been an issue, and has been dealt with in a regular

18 manner through working with the AHJs. So we believe

19 that it should remain as 'deficiency' and encourage

20 your vote for this. Thank you.

21 DAN O'CONNOR: Okay. Is there any further

22 discussion on Motion 25-2 to Reject Second Revision

23 No. 42? Mr. Chair, do you have any other comments?

24 BILL KOFFEL: I think the technical issues have

25 all been addressed by the discussion from the floor.



65

1 I would just note, the ballot results of 34 eligible

2 voters, 27 members of the Committee voted affirmative;

3 seven voted negative.

4 DAN O'CONNOR: Thank you, Mr. Chair. Before we

5 vote, let me restate the motion. The motion on the

6 floor is to Reject Second Revision No. 42. To vote,

7 touch the 'vote' button. If you wish to vote in

8 support of the motion and recommend the text on Screen

9 One, touch 'Yes'. If you wish to vote against the

10 motion, and recommend the text on Screen Two, touch

11 'No'. Please record your vote.



14 Thank you. The results of the vote are: 170

15 in support of the motion, and recommend the text on

16 Screen One; and 374 against the motion, and recommend

17 the text on Screen Two. The motion has failed.

18 Okay. The next motion on NFPA 25-3 appeared in

19 our Agenda. Mr. Hopkins?

20 MARK HOPKINS: Yes. Yeah.

21 DAN O'CONNOR: Will you take --

22 MARK HOPKINS: As the submitter of this motion,

23 I look to withdraw.

24 DAN O'CONNOR: Okay, thank you. I was going to

25 save you the time of coming to the mic, but that's



66

1 fine.


3 DAN O'CONNOR: The next motion, again, on NFPA

4 25-3, as appeared in our Agenda --

5 UNIDENTIFIED SPEAKER: Wait.

6 UNIDENTIFIED SPEAKER: What?


8 DAN O'CONNOR: Yeah. Appeared in our Agenda.

9 However, the authorized maker of the motion, the

10 designated representative, has notified NFPA that he

11 or she no longer wishes to pursue this motion.

12 Therefore, in accordance with NFPA rules, Convention

13 Rules at Section 2.7, the motion may not be considered

14 by the assembly, and is removed from the Agenda. We

15 will now move on to the next motion.

16 So now, let's proceed with the discussion on -

17 excuse me. Now, let's proceed with discussion on

18 Certified Amending Motion - microphone number four.

19 Mr. Hopkins again.

20 MARK HOPKINS: Yes, Sir. Thank you. I look to

21 make a motion to Accept an Identifiable Part of Public

22 Comment 40. And my name is Mark Hopkins, with the

23 NFSA.

24 DAN O'CONNOR: Thank you. There is a motion on

25 the floor to Accept an Identifiable Part of Public



67

1 Comment No. 40. Is there a second?


3 DAN O'CONNOR: Thank you. We do have a second.

4 Let's proceed with the discussion on the motion. Mr.

5 Hopkins.

6 MARK HOPKINS: Yes. Thank you, Sir. This

7 motion looks to remove text that was added as part of

8 the Second Revision, I believe it was 63, and add in

9 the text that was proposed as part of the Public

10 Comment 40. And the real intent here is to align the

11 requirements of NFPA 25 with the initial design

12 requirements of NFPA 13, and NFPA 72, to allow for an

13 identifiable pass/fail criteria for testing of flow

14 switches.

15 That's what we're trying to do here. We think

16 that the text provided in public comment better aligns

17 with those initial design requirements. Thank you.

18 DAN O'CONNOR: Thank you. Mr. Koffel, would

19 you like to offer the Committee position?

20 BILL KOFFEL: Thank you. The Committee's

21 action on Public Comment No. 40 was to reject but see,

22 and created a Second Revision, which is the text that

23 you see on the screen, that would be the, the outcome

24 if the motion fails.

25 As the maker of the motion just indicated, the



68

1 primary issue here is the, the extent of specificity

2 that's provided in NFPA 25. The first paragraph is

3 fairly similar, although the new - the motion would

4 add the text 'until such flow stops'.

5 The second paragraph is really where the, the

6 more substantive change occurs. It references a 90-

7 second performance requirement. It indicates what the

8 flow should be; that it's the smallest orifice

9 sprinkler on the system. And that text is extracted

10 from NFPA 72. So absolutely, the motion would

11 correlate with NFPA 72.

12 However, throughout the Standard, where NFPA 72

13 is referenced, the Committee added text to refer to

14 the locally adopted Fire Alarm Code. This was

15 intended to allow for codes other than NFPA 72 in

16 jurisdictions around the world, that might be

17 applicable; or even if one does adopt NFPA 72 - and

18 I'm aware of some jurisdictions that do this - they

19 modify 72 to decrease that time period. So the

20 Committee felt the language proposed by the Committee

21 better addresses the universe of applications of NFPA

22 25.


24 that, we will open up debate on the motion. Again,

25 please provide your name, affiliation, and whether you



69

1 are speaking in support of, or against the motion.

2 Microphone number one, please.

3 TERRY VICTOR: Thank you. Terry Victor,

4 Johnson Controls Fire Protection. I'm speaking in

5 favor of the motion. You're not seeing the text on

6 the board here that was part of the Second Revision,

7 and that text did, in fact, refer you to NFPA 72. All

8 we're trying to do here is to kind of simplify the

9 text that goes into NFPA 25.

10 Referring someone to 72, you have to go to that

11 additional document; where it's really simple - let's

12 just extract what 72 says, as far as the performance

13 of the water flow switch, and let's put it in NFPA 72.

14 And I understand that, you know, internationally,

15 they're, they're trying to gain acceptance for the

16 NFPA documents. This really helps that effort.

17 Instead of, again, a, a local fire code may have some

18 variances with this. But the 90 seconds is what we're

19 looking for, in reality, for these - the performance

20 of the flow switches. We want to have that signal

21 getting to the panel within 90 seconds. So it's, it's

22 a matter of trying to simplify some criteria that was

23 added. Again, this acceptance criteria wasn't in

24 previous editions of NFPA 25. So we're looking to

25 include this new criteria, the five seconds - or the



70

1 five minutes for, you know, water - just electric bell

2 or water gong, and then the 90 seconds when tied into

3 a fire alarm panel. So again, just trying to simplify

4 it. I urge you to vote in favor of the motion.


6 discussion on Motion 25-4, to Accept an Identifiable

7 Part of Public Comment No. 40? Okay. Seeing none, we

8 will move to a vote - except, Mr. Chair, do you have

9 any final comments?

10 BILL KOFFEL: No, Sir.

11 DAN O'CONNOR: Thank you. Before we vote, let

12 me restate the motion.

13 The motion on the floor is to Accept an

14 Identifiable Part of Public Comment No. 40. To vote,

15 touch the 'vote' button. Then if you wish to vote in


17 Screen One, touch 'Yes'. If you wish to vote against

18 the motion, and recommend the text on Screen Two,

19 touch 'No'. Please record your vote.

20 The voting will be closed in five seconds.

21 MULTIPLE UNIDENTIFIED SPEAKERS: No.

22 UNIDENTIFIED SPEAKERS: No.

23 UNIDENTIFIED SPEAKER: No.


25 MULTIPLE UNIDENTIFIED SPEAKERS: No.



71



3 UNIDENTIFIED SPEAKER: We're offline.

4 UNIDENTIFIED SPEAKER: We're offline.

5 UNIDENTIFIED SPEAKER: Offline.


7 UNIDENTIFIED SPEAKER: (unintelligible).

8 DAN O'CONNOR: Offline? Okay. I understand.

9 I'm hearing comments from the audience that they're

10 offline.


12 DAN O'CONNOR: Is that correct?

13 UNIDENTIFIED SPEAKER: Yes.

14 DAN O'CONNOR: Thank you. We heard you

15 clearly. (laughter) Let us get back here and see if

16 we can get back online here shortly, and proceed with

17 the vote.




21 UNIDENTIFIED SPEAKER: (unintelligible) on the

22 table.

23 (background voices)

24 DAN O'CONNOR: Thank you for your patience.




72

1 DAN O'CONNOR: Okay. Thank you for your

2 patience, again, ladies and gentlemen. They are

3 working on resetting the system. We think we're going

4 to be back up and running very shortly here. So bear

5 with us. Thank you.


7 DAN O'CONNOR: Okay. I've just been informed

8 that the process of resetting the system is going to

9 take another one to two minutes, and then we should be

10 back in business here. Okay. So thanks again for

11 your patience.


13 DAN O'CONNOR: And, and one more, one more

14 comment. There was a gentleman who had asked the

15 question about abstention earlier. I do want to make

16 it clear for all those of you voting today, that you

17 have basically just two options. You have the option

18 to vote 'Yes' on, and accept the, the motion. Or you

19 have the motion to vote 'No', and vote against the

20 motion. Those are your only two options for voting.

21 There is not a, an abstention option. Thank you.



24 DAN O'CONNOR: Ready to go? Okay. It looks

25 like we're ready to go here, folks.



73


2 DAN O'CONNOR: I'll give you a, a second to, to

3 take your seats, get back to your devices --


5 DAN O'CONNOR: -- if you're standing up,

6 floating around.


8 UNIDENTIFIED SPEAKER: Hit refresh. Try

9 refresh.

10 UNIDENTIFIED SPEAKER: Hit refresh.

11 DAN O'CONNOR: Okay.

12 UNIDENTIFIED SPEAKER: Refresh work for --

13 UNIDENTIFIED SPEAKER: Mine came up.


15 DAN O'CONNOR: Okay. I'm going to back up to

16 the point where I had asked earlier if there was any

17 further discussion. I, I, we had moved to the vote,

18 but I wanted to make sure we didn't miss something,

19 didn't get confused there. Was there any further

20 discussion on the motion?


22 UNIDENTIFIED SPEAKER: No, device is not

23 working.

24 UNIDENTIFIED SPEAKER: We can't vote.




74

1 DAN O'CONNOR: You - still devices not working?

2 UNIDENTIFIED SPEAKER: Ours are not.


4 DAN O'CONNOR: Okay. Green screens?

5 UNIDENTIFIED SPEAKER: Yellow.


7 DAN O'CONNOR: Okay, we still have some - we --

8 UNIDENTIFIED SPEAKER: No, we don't

9 (unintelligible)

10 UNIDENTIFIED SPEAKER: Right.

11 DAN O'CONNOR: Yeah.

12 UNIDENTIFIED SPEAKER: We're aware.

13 DAN O'CONNOR: We are aware, and working on

14 that issue.


16 DAN O'CONNOR: Okay. In order to not delay any

17 further, I would like all the NFPA staff that are hand

18 counters to come to the front of the room. We are

19 going to proceed with a hand count procedure --


21 DAN O'CONNOR: -- as - so not to delay this

22 while the technical difficulties are resolved. So

23 NFPA staff that are hand counters, please come -

24 please come to the front.




75

1 UNIDENTIFIED SPEAKER: How many are there?




5 UNIDENTIFIED SPEAKER: Go get 'em, Jeff.



8 UNIDENTIFIED SPEAKER: What is the problem?



11 UNIDENTIFIED SPEAKER: Anybody with yellow

12 screens. (unintelligible) yellow screen, please raise

13 your hand.

14 UNIDENTIFIED SPEAKER: Yeah, so

15 (unintelligible)


17 UNIDENTIFIED SPEAKER: All right. Okay.

18 DAN O'CONNOR: Okay. Let me outline what's

19 going to happen next here. We are going to proceed

20 with a count, a standing count of, of, of voting

21 members. So we also understand that there might be

22 some of you seated at the tables in the voting area

23 that in fact, are not voting members. We are going to

24 trust you on your honor not to stand as I ask for the

25 vote today, okay, if you're, if you're seated at these



76

1 tables in the voting area. So please just stay

2 seated. But we will proceed with a standing vote.

3 I will first ask for a vote for those in favor,

4 and then a vote - and, and then I will ask you to sit

5 down, and then I will ask for a vote against. So.

6 Okay.

7 So before we, we vote, let me restate the

8 motion. The motion on the floor is to Accept an

9 Identifiable Part of Public Comment No. 40. So to

10 vote - if you wish to vote in support of the motion,

11 that's the green screen, I would ask you to now stand.

12 We will need a, a minute or two for staff to go

13 through the aisles and get a count.


15 UNIDENTIFIED SPEAKER: Okay. Okay.

16 DAN O'CONNOR: Oh.

17 UNIDENTIFIED SPEAKER: Just a couple things

18 here.




22 DAN O'CONNOR: Yeah. Yeah. All of those who,

23 you've voted in favor of the motion, you may be

24 seated. And we will now ask for all of those who wish

25 to vote against the motion, and recommend the text on



77

1 Screen Two, to now stand.


3 UNIDENTIFIED SPEAKER: Does anybody else have a

4 yellow screen here?


6 DAN O'CONNOR: You got everybody, right? Thank

7 you for that vote. You may be seated.


9 UNIDENTIFIED SPEAKER: Anyone else with a

10 yellow --

11 UNIDENTIFIED SPEAKER: Right over here.

12 UNIDENTIFIED SPEAKER: Yellow?




16 UNIDENTIFIED SPEAKER: 180.

17 UNIDENTIFIED SPEAKER: 180. We have the - any

18 yellows? Any yellow screens here?


20 UNIDENTIFIED SPEAKER: Everybody okay with

21 their application?



24 UNIDENTIFIED SPEAKER: We need anybody with a

25 yellow --



78

1 DAN O'CONNOR: Okay. Okay. Everybody in the

2 room, thank you very much for assisting us with that

3 process. The results of the vote are: 251 in support

4 of the motion, and recommend the text on Screen One;

5 and 142 against the motion, and recommend the text on

6 Screen Two. The motion has passed.

7 Okay. So because we have some technical

8 difficulties, I, I just want to outline for you what's

9 going to happen here, and then - for the short term.

10 UNIDENTIFIED SPEAKER: Can you announce that if

11 it's a yellow screen to please raise their hand,

12 because staff is going to come reset their screens for

13 them.


15 DAN O'CONNOR: Right now?

16 UNIDENTIFIED SPEAKER: So if they're --

17 UNIDENTIFIED SPEAKER: (unintelligible) yellow.

18 DAN O'CONNOR: Okay. Okay. If you have a

19 yellow screen, would you please raise your hand?

20 Anybody who has a yellow screen, please raise your

21 hand. Staff is going to come, and reset your screen

22 for you right now. Okay? Or raise your hand, or

23 maybe even - maybe you should stand up, because I

24 can't see the hands from - see it through the crowd

25 here.



79


2 DAN O'CONNOR: Okay. So what we're, what we -

3 what we want to do here - we're going to - we want to

4 keep moving forward here. And what we're going to do

5 is we're going to proceed to the legacy approach we've

6 used in NFPA conferences in the past, and we will be

7 asking for - what?


9 DAN O'CONNOR: We're not going to do that?



12 DAN O'CONNOR: Okay. Okay. My confusion -

13 thing. So we, we've been here, talking about a number

14 of different approaches. We want to - we do want to

15 make progress here this morning, so --

16 UNIDENTIFIED SPEAKER: It appears that --

17 DAN O'CONNOR: -- we --

18 UNIDENTIFIED SPEAKER: -- everyone's back up

19 and running.


21 UNIDENTIFIED SPEAKER: So (unintelligible).

22 Just letting you know - sorry.

23 DAN O'CONNOR: Okay. I've been informed

24 (laughter) that everything is back up and running, as

25 --



80

1 (applause)

2 DAN O'CONNOR: Okay. So --


4 DAN O'CONNOR: Okay. We're going to proceed

5 now with the discussion on Certified Amending Motion

6 25-5. And I see a gentleman at microphone number

7 four. Please give us - identify yourself, your

8 affiliation, and for or against the motion, Sir.

9 TOP MYERS: My name is Top Myers. I'm with

10 Myers Risk Services. I'm here Myers Risk Services.

11 I'm here in behalf of Tony Apfelbeck, who made the

12 motion, and the motion is that I'm - he - and I'm

13 following forward, is - we --

14 UNIDENTIFIED SPEAKER: You've got to talk into

15 the microphone.

16 TOP MYERS: -- say yes.

17 UNIDENTIFIED SPEAKER: Use the microphone.

18 UNIDENTIFIED SPEAKER: Microphone.


20 DAN O'CONNOR: Excuse me. You, you are - Mr.

21 Myers, you are the maker of the motion, and for Mr.

22 Apfelbeck?

23 TOP MYERS: Yes.


25 TOP MYERS: And what we are is asking to - the



81

1 motion is to Accept the Original PC 60 from the last

2 cycle.

3 DAN O'CONNOR: Okay. Very good. Is there a

4 second?


6 DAN O'CONNOR: Okay, we have a second. Please

7 proceed with the discussion on the motion - Mr. Myers.

8 TOP MYERS: This is a pretty straightforward

9 request. It's not overly technical, not really

10 technical at all. What we have currently is Appendix

11 G, as in George, and we, in that appendix, talk about

12 if somebody wanted to do a tagging system, how would

13 they go about it, and different parts and pieces from

14 the type of things you're covering, where you place

15 tags, the size of the tags - all kinds of information

16 that would be important in the process of creating and

17 developing a tagging system for a system - for

18 sprinkler systems, that's where you would go.

19 What Tony says is that in the code community,

20 he's had a number of people approach him because what

21 they've done, and asked if he could modify Appendix G,

22 changing the language to reflect how code language

23 should appear. And that's basically what Tony did.

24 He took the - all the same materials, and just put it

25 in the type of language that would be required for



82

1 endorsement.

2 This would allow any local AHJ, or community,

3 or state, or anybody else, to follow a pattern that

4 was - make their process far easier, using the

5 language that would be now the new language in Annex

6 G.

7 This also would have the benefit that over

8 time, there would - could be more uniformity

9 throughout the country, which would be beneficial to

10 owners, as well as national contractors - anybody

11 that's involved on a multiple jurisdiction space.

12 It's that simple, and we would ask you to

13 accept the motion. Thank you.

14 DAN O'CONNOR: Okay. Mr. Koffel, would you

15 like to offer the Committee's position?

16 BILL KOFFEL: Thank you, Mr. Chair. Let me

17 first clarify that this motion does not change

18 anything related to the existing text in Annex G. It

19 adds a new section. Annex G was originally added to

20 the Standard to provide guidance on what a tagging

21 system might be. It was not written in mandatory

22 language. This then takes the critical aspects of

23 other Annex G language, and puts it into mandatory

24 format.

25 However, the Committee felt that this was a



83

1 jurisdictional issue, and needed to be handled in

2 local ordinance, and amendments to locally adopted

3 codes and standards. As written, G3 really is not a

4 complete ordinance. I don't think it would meet the

5 legal requirements in most jurisdictions to simply

6 adopt that; it merely takes 'should' language, and

7 changes it to 'shall'. So the jurisdiction most

8 likely would still need to create a separate

9 ordinance, or modify their fire code to adopt this

10 language. So we felt this was a jurisdictional issue.

11 DAN O'CONNOR: Okay. Thank you, gentlemen.

12 With that, we will open debate on the motion. Again,

13 please provide your name, your affiliation, and

14 whether you're speaking in support of, or against the

15 motion. Nobody?

16 UNIDENTIFIED SPEAKER: Nobody.

17 DAN O'CONNOR: I don't see any - oh. The

18 gentleman at microphone number four.

19 GEORGE STANLEY: Thank you, Mr. Chairman,

20 George Stanley, Wiginton Fire Protection Engineering,

21 speaking in favor of the motion. I'm a contractor in

22 Florida. We have a tagging system. And just changing

23 some of this language to make it more adoptable is a

24 good thing. The AHJs really appreciate this tagging,

25 that they can quickly see if there's any deficiencies



84

1 on the system, and how the system's doing. So I urge

2 you to vote in favor of it. Thank you.

3 DAN O'CONNOR: Thank you. I'm not seeing

4 anybody at the microphones. I - no. So, Mr. Chair,

5 do you have any final comments?

6 BILL KOFFEL: No, Sir.

7 DAN O'CONNOR: Thank you. Okay. Before we


9 floor is to Accept Public Comment No. 60. So we're

10 back to using the 'vote' button. So to vote, touch

11 the 'vote' button. If you wish to vote in support of

12 the motion, and recommend the text on Screen One,

13 touch 'Yes'. If you wish to vote against the motion,

14 and recommend the text on Screen Two, touch 'No'.

15 Please record your vote.


17 The voting is closed. Thank you.


19 the motion, and recommend the text on Screen One; and


21 Screen Two. The motion has passed.

22 Is there any further discussion on NFPA 25?

23 Seeing none, we will move on to the next document.

24 And thank you, Mr. Koffel.

25 BILL KOFFEL: Thank you.



85

1 (applause)

2 DAN O'CONNOR: The next report under

3 consideration is that of the Technical Committee on

4 Motor Craft. Here to present the Committee's report

5 is Technical Committee Chair John McDevitt of Drexel

6 Hill, Pennsylvania.

7 The Committee Report, that is the First and

8 Second - Second Draft Reports is located on the

9 Document Information Page for NFPA 302 on the NFPA


11 in the NFPA Technical Meeting Agenda, and will be

12 displayed behind me on the screen as they are under

13 debate. Mr. McDevitt, will you present the Chair

14 Report.

15 JOHN MCDEVITT: Good morning, Mr. Chair, ladies

16 and gentleman. The Report of the Technical Committee

17 on Motor Craft is presented as found in the First

18 Draft Report, and Second Draft Report for the 2019

19 annual revision cycle.

20 The Technical Committee has published the First

21 and Second Draft Report consisting of these revisions

22 - Fire Protection Standard for Pleasure and Water and

23 Commercial Motor Craft, NFPA 302. The revisions were

24 submitted to letter ballot of the responsible

25 Technical Committee. The reports and ballot results



86

1 can be found in the Next Edition tab of the Document

2 Information Page, NFPA 302, at www.nfpa.org/302next.

3 Mr. Chairman, I move the Standards Council issuance of

4 the Committee's Report on NFPA 302.

5 DAN O'CONNOR: Thank you, Mr. McDevitt. Let's


7 Motion 302-1. Microphone number four, please.

8 MARCELO HIRSCHLER: Marcelo Hirschler, GBH

9 International, and I move to Accept Public Comment No.

10 3.


12 the floor to Accept Public Comment No. 3. Is there a

13 second?


15 DAN O'CONNOR: Okay. Yes, we have a second.

16 Please proceed with the discussion on the motion.


18 International, speaking for NAFRA, and maker of the

19 motion.

20 First of all, let me apologize to the audience,

21 because I have a whole bunch of Certified Amending

22 Motions, that they all, most of them come now, one

23 after the other, so you're going to have to listen to

24 me for a while. But anyway - dealing with this

25 particular CAM - in every single transportation



87

1 environment, we have a requirement that we measure

2 smoke; we have some requirement for smoke obscuration.

3 We - if we're dealing with aircraft, it's the FAA. If

4 we're dealing with ships, it's NFPA 301, the

5 International Maritime Organization, the Coast Guard.

6 DAN O'CONNOR: Mr. Hirschler, could you just

7 stay closer to the mic, please?

8 MARCELO HIRSCHLER: If we - if we're dealing

9 with NFPA - with trains, it's the NFPA, and the

10 Federal Railroad Administration. If we're dealing

11 with subways underground, it's NFPA 130, and the

12 individual requirements of the authorities having

13 jurisdiction. Dealing with busses, it's the FTA

14 guidelines.

15 NFPA 302 deals with small craft, but it does

16 not deal with personal watercraft. I am reading from

17 the scope, or application, actually. NFPA 302 deals

18 with the following - boats of less than 300 gross tons

19 used for pleasure or commercial purposes; boats that

20 use energy for propulsion; they use engines for

21 generating power; they use cooking, heating, or

22 auxiliary appliances, permanently installed ignition

23 sources, permanently installed electrical systems.

24 The motion recommends that when you conduct an

25 ASTM 84 test - that's the Standard (unintelligible)



88

1 for some of you who may not be as familiar as I am -

2 you also - you also get smoke measurements. You

3 always get them when you run the test, so it doesn't

4 mean that you have to do any additional tests. You

5 just do the same test over. This doesn't require any

6 additional test; you get the smoke values.

7 Class - Section 4.1.6.1 says you need an FSI of

8 25, but it doesn't require smoke. So I'm recommending

9 that you add smoke, the Standard Class A smoke of SDI

10 under 450. Thank you.

11 DAN O'CONNOR: Thank you, Sir. Mr. McDevitt,

12 would you like to offer the Committee's position?

13 JOHN MCDEVITT: Yes, Sir. The majority of

14 vessels covered in NFPA 302 are pleasure craft -

15 pleasure crafts or small boats used for pleasure,

16 family, or sportsmen recreation. Generally, pleasure

17 craft is understood to be small to moderate sized boat

18 under 26 feet. The Technical Committee on Motor Craft

19 includes surveyors, retired US Coast Guard inspectors,

20 and these members have experience in the investigation

21 of incidents, including fires, and review of claims

22 and fire losses aboard small pleasure boats. No one

23 can recall an issue where smoke from insulating

24 materials ever being a concern, or contributor to loss

25 of life, additional property damage, or a hindrance in



89

1 firefighting efforts on a small pleasure craft.

2 In the First Draft, the Committee requested the

3 submitter to provide documentation or other

4 information to verify that smoke obscuration was a

5 factor or an important consideration in the size and

6 type of vessels covered by 302. Instead, the

7 submitter's public comments stated that other NFPA

8 Standards use smoke developed index of 450 or less.

9 Among those listed was NFPA 301, which is a Standard

10 for merchant vessels or larger ships where egress

11 could be confused by smoke saturation.

12 It is important to note that marine vessels

13 over the - greater than 300 gross tons were different

14 from, very different from small pleasure craft. NFPA

15 301 was created to address hazards on larger passenger

16 vessels and commercial ships. Larger passenger

17 vessels are vessels with multiple desks, numerous

18 passageways, and carrying passengers who are

19 unfamiliar with the vessel layout. Small pleasure

20 craft, fitted with cabin, typically have a single

21 below deck space that is accessed by a central

22 passageway, with egress forward and aft. Persons are

23 boat owners, and are very familiar with the layout of

24 the vessel.

25 The Committee knows no static - no statistic



90

1 that is available to the public through the United

2 States Coast Guard database, fire losses during the

3 past 20 years when smoke was a contributory factor to

4 increasing the fire hazard on any small vessel covered

5 by NFPA 302.

6 ASTM 84 is a Standard for surface burning

7 materials, and as described in the title and scope,

8 for building materials.

9 The revision that the submitter is presenting

10 in this Certified Motion simply does not apply to

11 vessels that are covered by NFPA 302.


13 that, we will open debate on the motion. If you come

14 to the mic, please provide your name, affiliation,

15 whether you are speaking in support of, or against the

16 motion. Microphone number four.


18 International, for - speaking for NAFRA in favor of

19 the motion.

20 It's very interesting that the Chairman says

21 that ASTM E84 is not applicable, and yet 4161 tells

22 you have to test the materials to ASTM E84. Every

23 material used for thermal and acoustical insulation

24 sold in this country - every material used for thermal

25 and acoustical insulation sold in this country, is



91

1 required to have a flame spread index of 75 or less,

2 and a smoke develop index of 450 or less. And I am

3 absolutely convinced that the materials that are used

4 for 302 are not magically coming from outer space into

5 these vessels. They are - they are materials sold in

6 this country.

7 So it's - second point - we, we are dealing

8 with commercial craft. Yes, they're much smaller

9 than, than ships. They, they are small craft. But

10 when you are in the water, you have no egress

11 capability, which is what happens with all

12 transportation environments, and disorientation as a

13 result of lack of smoke is an important consideration

14 everywhere in transportation environments. Please

15 support the motion, and add this requirement for

16 measuring smoke. Thank you.


18 discussion on Motion 302-1 to Accept Public Comment

19 No. 3? Mr. Chair, do you have any final comments?

20 JOHN MCDEVITT: No, Sir.

21 DAN O'CONNOR: Thank you, Mr. Chair. Before we


23 floor is to Accept Public Comment No. 3. To vote,

24 touch the 'vote' button, and if you wish to vote in




92





5 Voting will end in five seconds.



8 the motion, and recommend the text on Screen One; 233



11 Let's now proceed with the discussion on


13 four, please.


15 International, and I move to Accept Public Comment No.

16 4.

17 DAN O'CONNOR: Thank you. Is there, a, a

18 motion - there is a motion on the floor to Accept

19 Public Comment No. 4. Is there a second?


21 DAN O'CONNOR: We have a second. Thank you.

22 Please proceed with the discussion.


24 International, speaking for NAFRA in support of the

25 motion.



93

1 This is very simple, and actually, I think this

2 is essential, because right now the way it says is

3 materials shall be listed and labeled to meet the

4 requirements of E84. E84 does not have requirements.

5 I'm the Task Group Chairman for ASTM E84. ASTM E84 is

6 a test method. It tells you how to test, period.

7 Doesn't tell you what you do when you finish testing.

8 You report the results, that's all it tells you.

9 So with the wording exactly as is now, what you

10 would have is - I can get a (unintelligible) 10,000.

11 I met the requirements, because there are no

12 requirements. Please support the motion. Thank you.

13 DAN O'CONNOR: Mr. McDevitt, do you have a -

14 offer the Committee's position?

15 JOHN MCDEVITT: The Committee felt that the

16 revision as presented by the submitter is an editorial

17 change that is unnecessary, in the opinion of the

18 Technical Committee on Motor Craft.


20 that, we will open up debate on the motion. Please

21 provide your name, affiliation, and whether you are

22 speaking in support of, or against the motion.

23 Microphone number six, back of the room, please.

24 WILLIAM FISKE: Thank you, Chair - thank you,

25 Chairman. I am William Fiske, and I'm speaking for



94

1 myself, in opposition to the motion.

2 Listed and labeled are both defined terms

3 within NFPA. And the definition of labeled

4 automatically includes listing. So to say 'listed and

5 labelled' is redundant there.



8 International, speaking for NAFRA, and in support.

9 That - this is just editorial, listed and labelled, or

10 labelled or listed. Both terms were there originally.

11 So that doesn't make any change. The real change is

12 the other one.

13 At, at present, this section does not send you

14 to 4.1.6.1. So if it doesn't send you to 4.1.6.1, it

15 doesn't tell you what the requirements are, what

16 criteria you need to meet. So because ASTM E84 does

17 not have criteria, if you leave this here, you have no

18 way of knowing what you need to meet. Thank you.

19 DAN O'CONNOR: Thank you, Sir. Is there any

20 further discussion on Motion 302-2 to Accept Public

21 Comment No. 4? Mr. Chair, do you have any further

22 comments?


24 DAN O'CONNOR: Okay. Thank you, Mr. Chair.

25 Before we vote, let me restate the motion. The motion



95

1 on the floor is to Accept Public Comment No. 4. To

2 vote, touch the 'vote' button. If you wish to vote in











13 Okay. Moving on, we will now proceed with the

14 discussion on Certified Amending Motion 302-3.

15 Microphone number four, please.


17 International, and I move to Accept an Identifiable

18 Part of Public Comment No. 5.





23 DAN O'CONNOR: Okay, we have a second. Please

24 proceed with the discussion on the motion.




96

1 International, speaking for NAFRA and in support of

2 the motion.

3 This is the same issue that we discussed in -

4 two motions ago, 302-1. We're dealing with ducts

5 instead of dealing with insulation. And again,

6 because this is a transportation environment, I urge

7 you to support the motion and add smoked developed

8 requirements. Thank you.

9 DAN O'CONNOR: Mr. McDevitt, would you like to

10 offer the Committee's position.

11 JOHN MCDEVITT: Our response will be similar.

12 The majority of the vessels covered in 302 are

13 pleasure craft. Pleasure craft are boats that are

14 used for personal family and sportsmen recreation.

15 Generally pleasure craft are understood to be small

16 vessels under 26 feet. Once again, our Committee has

17 no experience with incidents where smoke generation

18 was a complication of an already complicated

19 situation.

20 I, I will add that the Coast Guard has

21 developed some recent standards, which - known as Sub-

22 Chapter M, where - they were detailed developments for

23 - or require, requirements for commercial craft, and

24 these did not have any kind of reference to smoke

25 generation at all. So.



97

1 DAN O'CONNOR: Thank you. With that, we will

2 open up the debate on the motion. Name, affiliation,

3 whether you're speaking for or against. Microphone

4 number four, please.


6 International, speaking for NAFRA, in support of the

7 motion. The, the Coast Guard requirements always use

8 ASTM E84, and use - include smoke. Thank you.

9 DAN O'CONNOR: Thank you. Is there any further


11 Part of Public Comment No. 5? Mr. Chair, any further

12 comments?

13 JOHN MCDEVITT: Only that the Coast Guard Sub-

14 Chapter M recent release does not reference E84.

15 DAN O'CONNOR: Thank you, Mr. Chair. Okay,

16 before we vote, I will restate the motion. That

17 motion on the floor is to Accept an Identifiable Part

18 of Public Comment No. 5. To vote, touch the 'vote'

19 button. If you wish to vote in support of the motion,

20 and recommend the text on Screen One, touch 'Yes'. If

21 you wish to vote against the motion, and recommend the

22 text on Screen Two, touch 'No'. Please record your

23 vote.





98

1 And the results of the vote are: 283 in


3 Screen One; 180 against the motion, and recommend the

4 text on Screen Two. The motion has passed.

5 Okay. Moving on, we will now proceed with the




9 International, speaking for NAFRA, and I move to

10 Accept an Identifiable Part of Public Comment No. 5.

11 DAN O'CONNOR: Okay. There is a motion on the

12 floor to Accept an Identifiable Part of Public Comment

13 No. 5. Is there a second?




17 Please proceed with discussion on the motion.


19 International, speaking for NAFRA, and in support of

20 the motion. This is identical to what you did in 302-

21 2. It's just simply pointing out where the

22 requirements are. Otherwise, there's, there's nothing

23 to meet there. Thank you.

24 DAN O'CONNOR: Okay. Mr. McDevitt, would you

25 like to offer the Committee's position on this?



99

1 JOHN MCDEVITT: Yes, Sir. The revision that is

2 presented by the submitter is an editorial change that

3 is unnecessary, in the opinion of the Technical

4 Committee.


6 that, we will open it up for debate. Name,

7 affiliation, whether you are speaking in support of,

8 or against the motion, please. Seeing no one at the

9 mics, I will ask if there is any further discussion on

10 Motion 302-4, to Accept an Identifiable Part of Public

11 Comment No. 5. Nothing further? Mr. Chair, do you

12 have any final comments?

13 MR. MCDEVITT: No, Sir.

14 DAN O'CONNOR: Thank you. Before we vote, let

15 me restate the motion. The motion on the floor is to


17 And to vote, touch the 'vote' button. If you wish to

18 vote in support of the motion, and recommend the text

19 on Screen One, touch 'Yes'. And if you wish to vote

20 against this motion, recommend the text on Screen Two,


22 The vote will close in five seconds.






100





5 four, please.



8 Accept Public Comment No. 6.



11 second?



14 And please proceed with the discussion.



17 motion. This is identical to what you have done in

18 two cases before. This deals with exposed materials,

19 and finishes within 24 inches of heat generation

20 surfaces. Other than that, it's the same thing, just

21 adding the smoke requirements. Thank you.

22 DAN O'CONNOR: Mr. McDevitt, the Committee's

23 position?

24 MR. MCDEVITT: The Committee's response is the

25 same. The Standard is for small craft, and we don't



101

1 feel the application is appropriate.

2 DAN O'CONNOR: Thank you, gentlemen. With that,

3 we'll open up debate on the motion. Again, name,

4 affiliation, and whether you're speaking in support of,

5 or against the motion. Okay. I see no one at the

6 microphone. So is there any - let me ask, is there any

7 further discussion on Motion 302-5, to Accept Public

8 Comment No. 6? Seeing none, we can move to vote,

9 unless, Mr. Chair, any final comment. No?

10 JOHN MCDEVITT: No, thank you.

11 DAN O'CONNOR: Thank you. Okay. The motion on

12 the floor is to Accept Public Comment No. 6. To vote,

13 touch the 'vote' button. If you wish to vote in support

14 of the motion, and recommend the text on Screen One,





19 The vote is closed. Thank you.



22 141 against the motion, and recommend the text on Screen


24 We will now proceed with the discussion on




102

1 four.


3 International, speaking for NAFRA, and I move to Accept

4 an Identifiable Part of Public Comment No. 7.



7 Comment No. 7. Do I hear a second?


9 DAN O'CONNOR: Okay. Thank you. We do have a

10 second. Let's proceed with a discussion on the motion.



13 motion. This is a purely editorial issue. I am the

14 Chairman of the Task Group dealing with ASTM E84. The

15 term for ASTM E84 is flame spread index, not flame

16 spread rating. In fact, that is consistent, what was in

17 previous sections of this Standard. Please support

18 that. Thank you.

19 DAN O'CONNOR: Mr. McDevitt?

20 JOHN MCDEVITT: The Committee, at our meeting in

21 April, discussed this change, and at the time, we did

22 not object to the editorial change that is proposed by

23 the submitter in 302-6.


25 we will open up debate on the motion. Name,



103

1 affiliation, and in support of, or against the motion.

2 Okay. Is there any further discussion on Motion 302-6,

3 to Accept an Identifiable Part of Public Comment No. 7?

4 Mr. McDevitt, anything further?

5 JOHN MCDEVITT: No, thank you.

6 DAN O'CONNOR: Okay. Thank you, Sir. Before we


8 floor is to Accept an Identifiable Part of Public

9 Comment No. 7. To vote, touch the 'vote' button. If

10 you wish to vote in support of the motion, and recommend

11 the text on Screen One, touch 'Yes'. If you wish to

12 vote against the motion, and recommend the text on

13 Screen Two, touch 'No'. Please record your vote now.




17 the motion, recommending the text on Screen One; and 31

18 against the motion, recommending the text on Screen Two.

19 The motion has passed.

20 We'll now proceed with the discussion on


22 four, please.


24 International, for NAFRA, and I move to Accept an

25 Identifiable Part of Public Comment No. 7.



104

1 DAN O'CONNOR: There is a motion on the floor to

2 Accept an Identifiable Part of Public Comment No. 7. Is

3 there a second?





8 International, for NAFRA, in support of the motion.

9 This is the same that you've already voted on three

10 times. It's just to add the smoke develop index. Thank

11 you.

12 DAN O'CONNOR: Thank you, Sir. Mr. McDevitt, any

13 on Committee's position?

14 JOHN MCDEVITT: Our response is the same - that

15 the 302 Standard covers small craft, and not so much

16 applicable to the smoke conditions.

17 DAN O'CONNOR: Once again, thank you, gentlemen.

18 With that, we - again, we will open debate. Anybody

19 wishes to debate on this, your name, affiliation,

20 whether you're speaking in support, or against the

21 motion? No further - is there no further discussion on

22 Motion 302-7, to Accept --


24 DAN O'CONNOR: Is there somebody - oh.

25 UNIDENTIFIED SPEAKER: Yeah, number six.



105

1 DAN O'CONNOR: Microphone number six.

2 WILLIAM FISKE: Thank you, Mr. Chairman. I'm

3 sorry - I don't walk quite fast enough for you. I'm

4 William Fisk. I'm representing myself, but I am a

5 member of the National Electrical Code Committee -

6 again, not speaking for the Electrical Section. But

7 this is --

8 DAN O'CONNOR: I could - Sir, could you - are you

9 in support of, or against the motion?

10 WILLIAM FISKE: I'm sorry. I am speaking

11 against.


13 WILLIAM FISKE: What we're looking at in this

14 section is basically an electrical enclosure. And the

15 smoke developed ratings for indexes, for electrical

16 enclosures are thoroughly irrelevant, although the flame

17 spread rating is very important. Thank you.



20 Part of Public Comment No. 7? Microphone four.


22 International, for NAFRA, and - in support. What we're

23 talking about is that we - we have products in there,

24 inside the vessels, that have to meet flame spread.

25 They also should meet smoke, just like we've talked



106

1 about other things. Please support the motion. Thank

2 you.

3 DAN O'CONNOR: Mr. McDevitt, anything further?


5 DAN O'CONNOR: Thank you. Okay. Before we vote,

6 let me restate the motion. The motion on the floor is

7 to Accept an Identifiable Part of Public Comment No. 7.

8 To vote, touch the 'vote' button. If you wish to vote

9 in support of the motion, and recommend text on Screen



12 'No'. Please record your vote now.








20 Microphone number four?

21 MARCELO HIRSCHLER: No - not on 302.

22 DAN O'CONNOR: Oh, okay.

23 MARCELO HIRSCHLER: Sorry.

24 DAN O'CONNOR: Don't confuse me. Okay. Seeing

25 none, we will move on to the next document. Thank you,



107

1 Mr. McDevitt.

2 JOHN MCDEVITT: Thank you.

3 (applause)

4 DAN O'CONNOR: Okay. The next report under


6 Handling and Conveying of Dusts, Vapors, and Gasses.

7 Here to present the Committee Report is Technical

8 Committee Chair, Mark Runyon, of Marsh Risk Consulting

9 of Portland, Oregon.

10 The Committee Report that is the First and Second

11 Draft Reports is located on the Document Information

12 Page from NFPA 654, on the NFPA website. All Certified

13 Amending Motions are contained in the NFPA Technical

14 Meeting Agenda, and will be displayed behind me on the

15 screen as they are under debate. Mr. Runyon, will you

16 present the Chair Report?

17 MARK RUNYON: Mr. Chair, ladies and gentlemen,

18 the Report of the Technical Committee on Handling and

19 Conveying of Dusts, Papers, and Gasses is presented as

20 found in the First Draft Report, and the Second Draft

21 Report for the 2019 annual revision cycle.


23 and Second Draft Report consisting of revisions to NFPA

24 654, Standard for the Prevention of Fire and Dust

25 Explosions from the Manufacturing, Processing, and



108

1 Handling of Combustible Particulate Solids. The

2 revisions were submitted to letter ballot of the

3 responsible Technical Committee. Their reports and


5 the Document Information Page for NFPA 654 at

6 www.NFPA.org/654next. Mr. Chair, I move for the

7 Standards Council issuance, the Committee's Report on

8 NFPA 654.

9 DAN O'CONNOR: Thank you, Mr. Runyon. Let's now

10 proceed with the discussion on the Certified Amending

11 Motion on NFPA 654-1, microphone number four, please.


13 International, speaking for NAFRA, and I move to Accept

14 an Identifiable Part of Public Comment No. 10, and

15 Accept Public Comment Nos. 11 and 9.



18 Comment No. 10, and Accept Public Comment Nos. 11 and 9.

19 Is there a second.


21 DAN O'CONNOR: I hear a second, and please


23 MARCELO HIRSCHLER: Thank you. Marcelo

24 Hirschler, GBH International, for NAFRA, and in support

25 of the motion. Let - this is completely different from



109

1 what we were talking about before. This is proposed for

2 various reasons. One, for compliance with the Manual of

3 Style. Manual of Style says there should be no

4 requirements in definitions. Consistent with accepted

5 NFPA terminology of what we do for noncombustible

6 material, and consistent with what happens in many, if

7 not most, major NFPA documents, including NFPA 1, 101,

8 5000, 98, 130, and so on, and so on.

9 This also recognizes that in the US - and

10 unfortunately, you don't have the entire definition

11 there, but just - in the US we use materials that pass

12 ASTM E136 as noncombustible materials. The, the text

13 today says that material in the former, which is used

14 (unintelligible) dissipated will not ignite support,

15 combustion, and yet, materials that have passed ASTM

16 E136 can ignite. The criteria is just that the flame

17 should be a short duration. So materials - that is too

18 restrictive, is not in compliance with what we use for

19 noncombustible materials.

20 In fact, the pass/fail criteria of ASTM E136,

21 which are in Items 2 and 3 of the - of my proposed

22 wording, allows burning and flame, and still declares

23 material noncombustible.

24 What the CAM does is move the definition away

25 from Chapter Three, provide a link to Chapter Four, the



110

1 requirements, (unintelligible) options are placed. Note

2 that in 654, in 7.1.4.1, a noncombustible dust is

3 rendered noncombustible by, by dilution with a

4 noncombustible dust. So you have something that's

5 combustible, and with dilution it becomes

6 noncombustible, which means there must be a criterion

7 for deciding when there's not enough noncombustible

8 component for the mixture to be noncombustible.

9 The needs is based on the test method, and the

10 proposed language as is in the Committee does not

11 provide it. The Annex of 654 does provide the language

12 - says, ASTM E136 is the text - the test that you need

13 to do that. So it is inconsistent, because the

14 definition says you shall not have ignition, and yet the

15 Annex associated with that definition says do it in

16 accordance with E136, which allows you to, to have some

17 flaming.

18 So this is inconsistent, and it's inconsistent

19 with the majority of the NFPA documents, such as 1, 101,

20 5000, etc. The rationale used to reject the comments is

21 the criteria proposed apply to building materials. Yes,

22 the Annex uses that definition with the same criteria.

23 So again, it's inconsistent. Please support. Thank

24 you.

25 DAN O'CONNOR: Mr. Runyon, would you like to



111


2 MARK RUNYON: Thank you. The Committee rejected

3 this public input during the First Draft, and the public

4 comment during the Second Draft, as they felt the

5 current definition provided sufficient clarity of the

6 intent that would be considered a noncombustible

7 substance. The Committee wants to keep the simplicity

8 of the definition for the user, to help them make the

9 determination of combustible/noncombustible. Adding to

10 - the additional testing to the ASTM Standards was seen

11 as unnecessary. The existing definition does not

12 include any requirements, and accurately conveys the

13 definition that applies to the use of noncombustible

14 materials in the Standard. Existing Annex material

15 further clarifies the intent of this decision.


17 we will open up debate on the motion. Again, I ask you

18 for your name, affiliation, and whether you are speaking

19 in support of, or against the motion. Microphone number

20 six, please.

21 JOHN CHOLAN (phonetic): Good morning. My name

22 is John Cholan, and I rise to speak against the motion.

23 I'm not supporting any particular client in my actions

24 today.

25 The Technical Committee has used the term



112

1 noncombustible primarily in relation to the construction

2 materials used for process equipment, including

3 ductwork, bins, bunkers, silos, air material separators,

4 cyclones, those kinds of equipment. These kinds of

5 equipment don't have the same kind of fire

6 characteristics and fire concerns that you have for

7 construction materials for occupied spaces.

8 The Technical Committee defined the term

9 noncombustible in that particular context to help the

10 user make the distinction between materials that were

11 suitable for ductwork, bins, and bunkers, as opposed to

12 those that were unsuitable - those that would lose their

13 physical integrity, or contribute to the fire load.

14 Consequently, the Committee defined the term, put

15 the definition where it belongs, and then addresses a

16 relevant test method as one method that might be used to

17 establish the distinction between combustible and

18 noncombustible, and that was put in the Annex for the

19 definition, as it should be, consistent with the Manual

20 of Style.

21 Consequently, I urge the membership to support

22 the actions of the Technical Committee, and reject this

23 proposal. Thank you.

24 DAN O'CONNOR: Mr. Cholan, could you just clarify

25 what is your company affiliation?



113

1 JOHN CHOLAN: My company affiliation is J.M.

2 Cholan Consultants. I'm an independent consultant, and

3 I'm not supporting the objectives of any particular

4 client.

5 DAN O'CONNOR: Thank you, Sir. Okay. Microphone

6 number six.

7 TIM MYERS: I'm Tim Myers from Exponent

8 Incorporated. I'm also speaking against the motion. I

9 agree, we - with - Mr. - what, with, with most of what

10 Mr. Cholan stated. I think one thing the, the mover of

11 the motion explained, that confused things, is that in

12 this Standard, as Mr. Cholan referred, we use

13 noncombustible to talk about materials of construction

14 of process equipment. And then we also have an issue of

15 whether the dust is combustible or noncombustible, which

16 we don't use the standards that have been added to the

17 Standard; we use the standards that are shown there -

18 ASTM E1226, and E2019. So you, you shouldn't be

19 confusing using this term of noncombustible with

20 noncombustible dust. Thank you.



23 International, speaking for NAFRA, and in support of the

24 motion. I note that both the opponents said that this

25 doesn't apply to noncombustible dust. I, I'm not sure



114

1 that I agree with that, but that's not the point. They

2 both said that they use the term 'noncombustible

3 material' for materials of construction, which is

4 exactly what ASTM E136 has done, and is used for, and

5 that's what they put in their Annex, as well. The Annex

6 says you shall use - well, no, it doesn't say you shall

7 use. You - materials that pass ASTM E136 are consistent

8 - are considered noncombustible.

9 So the, the way they put in the Annex - sorry,

10 not they - the way the Committee puts in the Annex, how

11 you determine if a material is noncombustible, is

12 inconsistent with the definition, because you pass E136,

13 and you can ignite support combustion burn. So this is

14 - the proposed text that I have, which is from - same

15 in, as I said, in a whole bunch of other NFPA documents,

16 includes this as one option. This is one of the options

17 to declare something noncombustible. The other options,

18 which are used, as both Mr. Cholan and Mr. Myers said,

19 for building materials - the, the other options are test

20 to ASTM E136, with the pass/fail criteria of ASTM E136.

21 Making this change would make this document

22 consistent with most other documents in the NFPA system,

23 and would prevent this inconsistency, this confusion

24 between what's in the body in Sections - in Chapter

25 Three, and what is in the corresponding Annex, which



115

1 don't tally with one another. Thank you.

2 DAN O'CONNOR: Okay. We'll move back to

3 microphone number six, please.

4 TIM MYERS: This is Tim Myers from Exponent,

5 speaking against the motion. I think one thing that

6 needs to be clarified - when we're talking about

7 materials of construction and process equipment, it's

8 typically steel. There's not a need to do a test to

9 determine if it's noncombustible. It's obvious. And

10 that's part of the reason why we don't have a specific

11 test required in the definition. Thank you.

12 DAN O'CONNOR: And again, at microphone six.

13 JOHN CHOLAN: Yes, this is John Cholan of JM

14 Cholan Consultants, Incorporated, and I can't agree with

15 my colleague, Tim Myers, more.

16 DAN O'CONNOR: For or against the motion, Mr.

17 Cholan.

18 JOHN CHOLAN: I'm speaking against the motion.


20 JOHN CHOLAN: Also, if you look at the text as

21 submitted, it's unclear as to whether the three items

22 listed under the proposed text for the new section in

23 Chapter Four, are an 'or' or an 'and' - so that

24 consequently, a user could be in a position where he has

25 to comply with all three of those criteria. And here,



116

1 we're talking about a piece of 12-gauge steel. And why

2 add the cost to installations for getting tested on

3 materials of construction that are well known not to

4 burn, which is exactly what Mr. Myers brought up.

5 Furthermore, because NFPA 654 is used in a wide

6 array of countries, many of which are not the United

7 States, many times you've got to use a different test

8 method. Consequently, the Technical Committee

9 referenced the ASTM Standard in the Annex, because the

10 Annex is advisory, non-mandatory text. By putting the

11 reference to ASTM in the body of the Standard, it

12 becomes mandatory, and therefore deprives the owner the

13 - of the option of utilizing another test method that is

14 recognized in the jurisdiction where the facility is

15 actually being constructed.

16 So I urge the membership to vote against this




20 International, for NAFRA, and in support of the motion.

21 Let me just - because it's not on the screen, I'm - I

22 want to read what it says in the proposed text. 'A

23 material that complies with any of the following shall

24 be considered noncombustible.' And the first one of

25 those is the same wording that is there today - 'any of



117

1 the following' - which means that you can do one, two,

2 or three; one, two, or three. You clearly, when it says

3 'any of the following' you don't have to do all three.

4 And the first one, which is the most restrictive - which

5 is fine; that is one of the options. Thank you.

6 DAN O'CONNOR: Thank you, Sir. Is there any

7 further discussion on Motion 654-1, to Accept an

8 Identifiable Part of Public Comment No. 10, and Accept

9 Public Comment Nos. 11 and 9.


11 DAN O'CONNOR: Mr. Chair, do you have any further

12 --

13 MARK RUNYON: No. We - the Committee has been

14 well represented, and well spoken. Thank you.

15 DAN O'CONNOR: Thank you, Mr. Chair. Okay.


17 on the floor is to Accept an Identifiable Part of Public

18 Comment No. 10, and Accept Public Comment Nos. 11 and 9.




22 the motion, and recommend the text on Screen No. Two,

23 touch 'No'. Please record your vote now.





118




4 Two. The motion has failed.


6 Seeing none, we will move on to the next document, and I

7 thank you, Mr. Runyon.

8 (applause)

9 DAN O'CONNOR: Okay. I would like to make a, an

10 announcement. We will only be taking 15 minute breaks

11 throughout the session today. We will not be breaking

12 for lunch. We encourage you to leave to get snacks or

13 lunch at our convenience. There is a food court that is

14 open at the bottom of the escalators, and a food cart

15 immediately outside this ballroom.

16 Before we could - begin debate on the next

17 Standard, though, I would like to introduce Kenneth

18 Bush, member of the Standards Council, who will be the

19 Presiding Officer for motions before the membership on

20 the next five Standards.

21 KENNETH BUSH: Thank you, Dan. It's my privilege

22 to announce that the next order of business will be a 10

23 minute break.

24 UNIDENTIFIED SPEAKERS: Yeah.

25 KENNETH BUSH: So please return in 10 minutes.



119

1 (applause)

2 (MUSIC)

3 (END OF PART ONE)

4

5


7


9


11

12 PART 2

13

14

15 (MUSIC)

16 UNIDENTIFIED SPEAKER: Ladies and gentlemen,

17 please take your seats. Please take your seats. This

18 session is about to resume.


20 KENNETH BUSH: Ladies and gentlemen, the next

21 report under consideration is that of the Technical

22 Committee on Fixed Guideway Transit and Passenger Rail

23 Systems. Here to present the Committee Report is

24 Technical Committee Chair Jarrod Alston of Arup,

25 Cambridge, Massachusetts. The Committee Report, that



120

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

is the First and Second Draft Reports, is located on

the Document Information Page for NFPA 130 on the NFPA

website. All Certified Amending Motions are contained

in the NFPA Technical Meeting (Tech Session) Agenda,

and will be displayed behind me on the screen as they

are under debate. Mr. Alston, will you present the

Chair Report.

JARROD ALSTON: Mr. Chair, ladies and

gentlemen, the Report of the Technical Committee on

Fixed Guideway Transit and Passenger Rail Systems is

presented as found in the First Draft Report, and

Second Draft Report for the 2019 annual revision

cycle. The Technical Committee has published a First

and Second Draft Report consisting of revisions to

NFPA 130, Standard for Fixed Guideway Transit and

Passenger Rail Systems. The revisions were submitted

to letter ballot of the responsible Technical

Committee. The reports and ballot results can be

found on the Next Edition tab of the Document

Information Page for NFPA 130 at www.nfpa.org/130next.

Mr. Chair, I move for Standards Council issuance the

Committee's Report on NFPA 130.

KENNETH BUSH: Thank you, Mr. Alston. Let's

now with the discussion of the Certifying Amending

Motions on NFPA 130. Microphone four, please.



121

1 MARCELO HIRSCHLER: I - Marcelo Hirschler, GBH

2 International, for the Vinyl Institute, and I move to

3 Reject an Identifiable Part of Second Revision No. 23.

4 KENNETH BUSH: Thank you, Sir. As a reminder,

5 Motion 130-1 has been changed to Reject an

6 Identifiable Part of Second Revision 23. The text

7 shown on the screens behind me reflects the proposed

8 action for the Membership's consideration.

9 There is a motion on the floor to Reject an

10 Identifiable Part of Second Revision No. 23. Is there

11 a second?


13 KENNETH BUSH: We do have a second. Please

14 proceed with the discussion on the motion. Microphone

15 four.


17 International, for the Vinyl Institute, and in support

18 of the motion. This is a fairly simple issue, but

19 just changing a definition.

20 The concept is that something critical, such in

21 this case a critical velocity, is an absolute term,

22 not a relative term. The existing definition, as

23 accepted by the Committee, says that a critical

24 velocity, one that controls back-layering, such a

25 tenable environment is maintained. That's not



122

1 critical, because it depends on concept obtainable, on

2 the environment, on the point of safety.

3 Critical velocity has to be a critical thing -

4 one that prevents back-layering. It's not necessary

5 to reach your critical velocity of a safe passage.

6 That's just the ultimate goal. It's an

7 (unintelligible). The same when we're talking about

8 critical flux for ignition. It's not the flux at

9 which it will ignite; it's the minimum flux that will,

10 which will ignite. Critical temperature is not the

11 critical, any temperature will ignite - critical,

12 minimum temperature will ignite. So critical is an

13 absolute term. Thank you.

14 KENNETH BUSH: Thank you. Mr. Alston, would

15 you like to offer the Committee's position.

16 JARROD ALSTON: Thank you. It was the

17 Committee's position that the qualifier on the

18 definition of 'critical velocity' was required to

19 provide clarification on its intent, and application

20 to real tunnels. This came in response largely to

21 changes in the formulation of the critical velocity

22 expression adopted in Annex D of the 2017 Edition of

23 NFPA 502. That reformulation was the result of work

24 of Lee (phonetic) and Engison (phonetic) of the

25 Research Institutes of Sweden. The practical outcome



123

1 of their work was to effectively change the definition

2 of critical velocity, to one of an absolute

3 theoretical, or mathematical zero back-layering

4 distance, from one of finite back-layering, based on

5 the outcomes of the Memorial Tunnel Fire Ventilation

6 Test Program.

7 The results of that testing had served for

8 decades as the basis for assessment, and then

9 establish an acceptable degree of back-layering.

10 According from a report on the, on the tests,

11 generally when back-layering was prevented, smoke was

12 contained within 40 feet upgrade of the fire.

13 Therefore, the objective of the modification to

14 the definition in NFPA 130 was to realign with, with

15 this previously accepted practical definition.

16 It is notable that NFPA 502 similarly clarifies

17 the definition, albeit it in Annex material, as

18 achieving the limitation of back-layering such that it

19 does not extend beyond the untenable zone, should be

20 accepted as effectively preventing back-layering.

21 While it is acknowledged that the Committee action

22 creates a minor departure in definition of the similar

23 term in NFPA 102, the intent is the same.

24 Therefore, the Committee viewed it as wholly

25 appropriate to elaborate on, and clarify the intent



124

1 for use in tunnel ventilation of real tunnels.

2 KENNETH BUSH: Thank you, gentlemen. With


4 provide your name, affiliation, and whether you're

5 speaking in support or against the motion. Microphone

6 four, please.


8 International, for the Vinyl Institute, in support of

9 the motion. I think Jarrod Alston explained that what

10 you have in 502 talks about an effective critical

11 velocity. And that's fine; that's what we're talking

12 about. The effective critical velocity is one that

13 will control back-layering. But if you want to

14 prevent back-layering, the absolute term, that is what

15 is critical. Thank you.

16 KENNETH BUSH: Thank you. Is there any further

17 discussion on Motion 130-1, to Reject an Identifiable

18 Part of Section Revision No. 23? Seeing none, we will

19 move on to a vote. Mr. Chair, do you have any final

20 comments?

21 JARROD ALSTON: No further comments. Thank

22 you.

23 KENNETH BUSH: Seeing no further comments, we

24 will move to a vote. Before we vote, let me restate

25 the motion. The motion on the floor is to Reject an



125

1 Identifiable Part of Second Revision No. 23. To vote,







8 KENNETH BUSH: The voting will close in five

9 seconds.


11 The results of the vote are: Two hundred and -

12 I'm sorry, 111 in favor of the motion; 208 against the

13 motion, and the recommended text on Screen Two. The

14 motion has failed.

15 Let's now proceed with the discussion on the

16 Certified Amending Motion 130-2. Microphone four,

17 please.


19 International, speaking for the Vinyl Institute, and

20 I, I move to Reject an Identifiable Part of Second

21 Revision No. 19.

22 KENNETH BUSH: Thank you. There is a motion on

23 the floor to Reject an Identifiable Part of Second

24 Revision No. 19. Is there a second?




126

1 KENNETH BUSH: There is a second. We do have a

2 second. Please proceed with a discussion on the

3 motion. Microphone four, please.


5 International, for the Vinyl Institute, and in

6 support of the motion.

7 It's unfortunate that the, at least the

8 beginning of the, of the table is not shown. What,

9 what we're talking about is that there is a table in

10 the Annex that shows what a number of tests that were

11 conducted with various rail cars. The first column of

12 the table shows what the tests were, with the

13 reference and all that. The next table shows the peak

14 heat release. The next - sorry, not the - next column

15 shows the peak heat release rate, and the third one

16 shows the time for the peak heat release rate.

17 Then there's a fourth column, that I hope you

18 can look at your Agendas, because there are the

19 details in there. The - that describes, to some

20 extent, what the materials are. But this can be very

21 misleading because it's not detailed enough.

22 The table itself is very valuable, and needs to

23 remain, and the references to each test will give all

24 the details you need about materials or products used,

25 as opposed to the scanty detail shown.



127

1 For example, if one of the columns says,

2 'Legacy Interior Materials' - I'm not sure what the

3 hell that means. One of --

4 (laughter)

5 MARCELO HIRSCHLER: -- it could be wood,

6 leather, horsehair - I don't know what a legacy

7 material is. And some legacy materials behave better

8 than others.

9 Another table - another column says, '90% of

10 interior materials were considered to be combustible'

11 - okay, probably most of them were combustible. But

12 what does that tell you about what the materials were?

13 In other cases it said, 'Seek materials of latest

14 design at the time of test.' What does that tell you?

15 That is confusing, potentially misleading.

16 I'm not sure that does help the user at all.

17 In the contrary, it confuses. The key information is

18 what's found in columns one, two, and three - the

19 reference; the type of train; peak heat release; the

20 time to peak heat release rate. Anything else, much

21 more information is needed, if you really want details

22 and want to reproduce to some extent, the test method.

23 That will be found in the reference, and not in some

24 sketchy statements in a misleading column.

25 So again, what this does, and again, I, I urge



128

1 you to look at the Agenda, because this won't show

2 you. The table is an excellent table, and needs to

3 remain. And the table is a summary of measured and

4 estimated heat release rates, and associated context.

5 And the, the context is what's in the first column -

6 heat release rate, and time to peak heat release rate

7 is in the second and third column. The fourth, the

8 fourth column is just some - some sketchy information

9 that you really need to look at in the actual text.

10 Thank you.

11 KENNETH BUSH: Thank you. Mr. Alston, would

12 you like to offer the Committee's position?

13 JARROD ALSTON: Sure. The incorporation of

14 Table B924 in NFPA 130 was part of the much larger and

15 more extensive effort by the Committee to reorganize

16 the rather sprawling of the Annex material in 130.

17 That table in particular builds upon

18 information that had previously been touched on in

19 general terms within the prior Annex H, specifically

20 around, quote, 'Modern trains that are fire hardened

21 have not been readily tested. Research has been on

22 older model trains, where the degree of fire hardening

23 has not been quantified.'

24 It was the view of the Committee that it was

25 appropriate, and a service to the industry to provide



129

1 additional information against each test within the

2 fourth column, rather than discussing in general

3 terms, as had been previously done in Annex H, in

4 order to provide appropriate context to the values

5 documented in the second and third columns of the

6 table.

7 The reason behind the rather generic language

8 utilized in, in column four is actually in response to

9 Mr. Hirschler's comments at our Second Draft meeting,

10 where he had raised concerns about commercial or

11 trademarked material names utilized within, within the

12 table. So that naming, and that nomenclature had been

13 stripped out, in favor of the more generic, legacy, or

14 modern material designation.

15 It's the view of the Committee that that

16 information is essential to provide the desired

17 context to the experimental results, in order to avoid

18 adoption of inappropriate fire sizes for design

19 purposes based solely on conservative, and ill

20 informed selection of numerical values.

21 While it's acknowledged that the, the

22 information is, is limited, it does provide a jumping

23 off point for additional research.





130



3 Microphone four, please.


5 International, for the Vinyl Institute, in support of

6 the motion. I'm going to read a couple of things in

7 this. German IC train with steel body, with legacy

8 interior materials. German ICE train with modern

9 materials at the time of test. Seat materials of

10 latest design at time of test. Other interior

11 materials of former design. Train approximately 30

12 years old, with 90% interior materials estimated re-

13 combustible. Train dating to 1970s, with original

14 combustible interior lining, and an additional fire

15 load. Refurbished X1 train. And so on, and so forth.

16 I mean, I - you - again, if you, if you look at the

17 Agenda, you'll, you'll see the details. That

18 information doesn't help the user, and it potentially

19 confuses, because it will give you inadequate

20 information.

21 I agree that what was - the first time this

22 was, was put forward in front of the Committee - I'm

23 not a member of the Committee, but I, I'm a regular

24 attendee. I've been attending those meetings for

25 probably 25 years or so. The - what was put first in



131

1 front of the Committee was even worse, because some of

2 the materials were identified, without identifying in

3 detail what the material was. This is very vague, and

4 it really just serves to confuse, confuse.

5 There is no debate that Annex B is fabulous.

6 I'm 100% in favor of Annex B. There's no debate that

7 Table B924 is a very important table. I'm fully in

8 favor of that table remaining. I'm strongly opposed

9 to this information about materials, which is vague

10 and misleading. Thank you.


12 discussion on Motion 130-2 to Reject an Identifiable

13 Part of Second Revision No. 19? Mr. Chair, any

14 (unintelligible)?

15 JARROD ALSTON: I just wanted to raise one

16 other point - that there is additional information

17 within the fourth column, particularly around the

18 ignition source, and ventilation conditions, if that

19 was reported on in the testing - both of which are

20 important to understand the outcomes of those tests.

21 KENNETH BUSH: Seeing no further discussion, we







132






6 The voting is closed. The results of the vote

7 are: 129 in support of the motion; 228 against the

8 motion. The motion has failed.



11 Thank you, Mr. Alston.

12 JARROD ALSTON: Thank you, Mr. Chair.

13 (applause)

14 KENNETH BUSH: The next report under


16 Road Tunnel and Highway Fire Protection. Here to

17 present the Committee Report is Technical Committee

18 Chair, Antonio Marino, of the Port Authority of New

19 York and New Jersey, New York, New York.


21 Second Draft Reports, is located on the Document

22 Information Page for NFPA 502 on the NFPA website.

23 All Certified Amending Motions are contained in the

24 NFPA Technical Committee - Technical Meeting (Tech

25 Session) Agenda, and will be displayed behind me on



133

1 the screen as they are under debate.

2 Mr. Marino, will you present the Chair Report.

3 ANTONINO MARINO: Mr. Chair, ladies and

4 gentlemen - the Report of the Technical Committee on

5 Road Tunnel and Highway Fire Protection is presented

6 as found in the First Draft Report, and Second Draft

7 Report for the 2019 annual revision cycle.



10 NFPA 502, Standard for Road Tunnels, Bridges, and

11 Other Limited Access Highways. The revisions were

12 submitted to letter ballot of the responsible

13 Technical Committee. The reports and ballot results

14 can be found on the Next Edition of the Document

15 Information Page for NFPA 502, at

16 www.nfpa.org/502next.

17 Mr. Chair, I move for Standard Council

18 issuance, the Committee's Report on NFPA 502. -

19 KENNETH BUSH: Thank you, Mr. Marino. Let's


21 Motion 502-1. Microphone four, please.


23 International, for the Vinyl Institute. And I move to

24 Accept Public Comment No. 1.




134


2 second?


4 KENNETH BUSH: Yes, we do have a second.




8 of the motion.

9 Again, it's unfortunate not the entire thing is

10 on there. But let me clarify. You - if you look at

11 your Agenda, you will notice what this says is a

12 material is noncombustible if it complies with any of

13 the three things that we discussed in, in other

14 committees, which is if, if, if it doesn't burn, if it

15 meets E136, if it meets E2650 with the criteria of, of

16 E136. And the Committee added this one, which is

17 from, from Europe.

18 And the reason that I'm opposed to this is

19 because the ISO 1192 standard does not have

20 thermocouples by the material itself, because it has

21 no thermocouples by the material itself, can't measure

22 that increase in temperature. Consequently, materials

23 that pass the requirements in here are a - will fail

24 the material - the requirements that we use in the

25 United States for E136. So what this will do is



135

1 allow, as noncombustible, a number of additional

2 materials than the ones we, we normally accept in the

3 United States.

4 I happened to be the Task Group Chairman in

5 ASTM for the ASTM E136 Test Method. We took the

6 apparatus of ISO 1182, and added the thermocouples in

7 here. And that's how we developed our, our test

8 method here. Adding the thermocouples means that you

9 can, you can determine how the material itself

10 behaves, and that will be a pass/fail criterion. And

11 the - that is a much more severe pass/fail criterion

12 than the pass/fail criterion in the European Union,

13 the EN-13501.

14 So I urge you to not approve this, and allow

15 noncombustible materials to be consistent with what is

16 in all of the - our other NFPA Codes and Standards.

17 Thank you.

18 KENNETH BUSH: Mr. Marino, would you like to


20 ANTONINO MARINO: Yes. The Committee reviewed

21 and evaluated the amended motion. The position of the

22 Committee is that the amended motion does not provide

23 adequate substantiation, or compelling evidence of the

24 differences of the two testing criteria methods.

25 The statement of problem in the public comment



136

1 clearly identified the thermocouples, but no

2 information was provided in terms of case studies, or

3 documented reports, indicating the differences of the

4 results of those tests, indicating that one was sub-

5 par to the other, or the percentage of the results,

6 and how they're impacted.

7 Furthermore, the purpose of Item No. 4, which

8 provided the additional testing method which is used

9 in Europe, was brought in. It is because the NFPA 502

10 has been adopted by many countries outside of the

11 United States. In particular, NFPA 502, 42% of the

12 voting Committee members within the Committee are

13 outside of the United States.








21 of the motion.

22 I can't provide actual numbers because as you

23 well know, all test results are shown, and are

24 proprietary test. Labs will not provide that

25 information. But as, again as I said, I am the Task



137

1 Group Chairman for the ASTM E136 and ASTM E2652.

2 What we did in ASTM was write to ISO, request

3 permission to copyright their equipment, the ISO 1192,

4 make it into ISO - ASTM E2652, and add the

5 thermocouples, because that was the, the criterion

6 that we all understood. It was completely understood

7 by everyone in the ASTM Fire Standards Committee that

8 without those, the tests, the, the results are

9 different, and materials that pass this criterion here

10 on the screen will not pass the criteria of E136.

11 There is no visa-versa. Everything that passes,

12 passes this will - sorry - everything that, that

13 passes E136 will pass these criteria, but a lot of

14 materials that pass this will not pass the E136

15 criteria.

16 What, what - this is particularly important

17 when we're dealing with some materials, such as some

18 insulations, depending on the amount of binder in the

19 insulation, it can become noncombustible to ISO 1182,

20 and yet combustible to ASTM E136. Thank you.



23 No. 1? Mr. Chair, any final comments on behalf of the

24 Committee?

25 ANTONINO MARINO: No, Sir.



138

1 KENNETH BUSH: Seeing none, we will move to a

2 vote. Before we vote, let me restate the motion. The

3 motion on the floor is to Accept Public Comment No. 1.






9 Voting will be closed in five seconds.



12 the motion; 199 against the motion. The motion has

13 failed.



16 please.

17 MARCELO HIRSCHLER: Marcelo Hirschler - sorry.

18 Marcelo Hirschler, GBH International, speaking for

19 Vinyl Institute, and move to Reject an Identifiable

20 Part of Second Revision No. 6.



23 Revision No. 6.


25 KENNETH BUSH: We do have a second. Please



139

1 proceed with a discussion on the motion. Microphone

2 four, please.



5 of the motion.

6 This must - is very simple. It - the -

7 eliminates ambiguity. What this has is adding the

8 term, 'or other approved, recognized standards'.

9 Approved by whom? Approved typically here in the

10 United States, means approved by the building

11 official, or the authority having jurisdiction. How

12 does the building official, or authority having

13 jurisdiction know whether the other test that someone

14 conjured is equivalent to UL 2196? UL 2196 has been,

15 for many years, the appropriate tests use for, for

16 that application. It's - it remains the appropriate

17 test. There is no other standard. No one has been

18 able to standardize anything different. And the -

19 adding other approved, recognized standard is - opens

20 the, the floor to something that someone may put in

21 without understanding exactly what it is that is being

22 tested. We, we have no guarantee of equivalence.

23 Thank you.

24 KENNETH BUSH: Thank you. Mr. Marino, would




140

1 ANTONINO MARINO: Yes. NFPA 502, it's a

2 Standard, Road Tunnels, Bridges, and Other Limited

3 Access Highways, which has been adopted globally by

4 many countries outside of the United States, as

5 indicated previously on the previous amending motion.

6 Twelve out of the 29 voting members within the

7 Committee are outside of the United States. This

8 provides a, a method for which other municipalities,

9 countries are able to adopt a testing method that's

10 acceptable within, and recognized within their

11 municipality.

12 KENNETH BUSH: Thank you. With that, we will

13 open up debate on the motion. Please provide you

14 name, affiliation, and whether you are speaking in

15 support of, or against the motion. Microphone six.

16 JAMES CONRAD: Yes. James Conrad, with Marmon

17 I & T, and I speak against the motion on the floor. I

18 am a voting member, a principal member of 502, and I

19 was actually the submitter of this wording.

20 The reason we added that is, like the Chair

21 said, is it is an international standard. UL 2196,

22 although it is a, a very good standard, it still has

23 its shortcomings; and additionally, it's not accepted

24 around the world. And a lot of different test

25 facilities do not do that test. They have their own



141

1 versions.

2 And we additionally added - really, what we're

3 looking for in this Standard, and additional wording

4 in the Annex, is to provide guidance for the users at

5 AHJs what to look for, such as - you know, how to test

6 it vertically, horizontally, used in a totally

7 enclosed furnace; and, and also a list of all the

8 components.

9 Circuit integrity is very important. It can be

10 achieved through different labs all over the world.

11 I've been doing this testing for over 25 years. And

12 yes, UL is, is one of the higher standards. We still

13 need to allow other approved methods meeting the

14 guidelines in 502, in the additional suggestions in

15 the Annexes. Thank you. And I support you - I would

16 ask you to reject this motion.

17 KENNETH BUSH: Thank you. Microphone four.



20 of the motion.

21 You just heard Jim Conrad say other methods are

22 not quite as, as robust, where he - sorry, he didn't

23 use the 'robust' - he said UL 2196, the best method.

24 And he said there is some guidance in the Annex as to

25 how you can develop other standards.



142

1 The - NFPA 502 does have other standards

2 referenced - international standards. For example,

3 there's a standard for the fire resistance inside the,

4 the tunnel, that's a Dutch standard, that's perfectly

5 fine. We - you just approved adding ISO 1182, which

6 is a, an ISO standard primarily used in Europe and in

7 IMO.

8 So if another standard exists, wherever it, it

9 exists, bring it in. But this doesn't bring another

10 standard. It just says 'other approved' - whatever

11 that means. And as you just heard, it is probably not

12 as good as UL 2196, as explained by the supporter.

13 Please, delete this vague language which will produce

14 nothing more than reduced safety. Thank you.



17 Part of Second Revision Number Six? Microphone six,

18 please.

19 DAVE SHAPIRO: Dave Shapiro, representing

20 myself, speaking in favor of the motion. My concern

21 is this - when, when you have an AHJ and somebody

22 comes to him and says, 'I have an equivalent safe

23 method,' the AHJ generally has a mechanism for

24 accepting it. When you have something in the Standard

25 that says, 'other approved methods' - that's - can



143

1 look like an invitation for people to go to the AHJ

2 and say 'Look, I have, I have other good things.

3 Listen to me.' The, the - this is obviously

4 acceptable that, that, that people should come up with

5 a bunch of other possibilities. I don't know if this

6 will happen, but I would think that there is an

7 existing mechanism already that makes this

8 unnecessary. That's all I have to say. Thank you.



11 part of Second Revision No. 6? Mr. Chair, any final

12 comments from the Committee?

13 ANTONINO MARINO: No, Sir.












25 The results of the vote are: 163 in favor of



144

1 the motion; 219 opposed to the motion. The motion has

2 failed.



5 Thank you, Mr. Marino.

6 (applause)

7 KENNETH BUSH: The next Committee, or next

8 report under consideration is that of the Technical

9 Committee on Fire Hose. Here to present the Committee

10 Report is Technical Committee Chair, Andrew Ellison of

11 EFI Global, Incorporated, South Hamilton,

12 Massachusetts.





17 NFPA Technical Meeting (Tech Session) Agenda, and will

18 be displayed behind me on the screen as they are under

19 debate. Mr. Ellison, will you present the Chair

20 Report.

21 ANDREW ELLISON: Mr. Chair, ladies and

22 gentlemen, the Report of the Technical Committee on

23 Fire Hose is presented as found in the First Draft

24 Report, and the Second Draft Report for the 2019

25 annual revision cycle.



145



3 NFPA 1961, Standard on Fire Hose. The revisions were

4 submitted to letter ballot of responsible Technical

5 Committee. The reports and the ballot results can be

6 found in the Next Edition tab of the Document

7 Information Page of 1961.

8 Mr. Chair, I move for the Standards Council

9 issuance adoption Committee's Report from NFPA 1961.

10 KENNETH BUSH: Thank you, Mr. Ellison. Let's

11 now proceed with discussion on Certifying Amending

12 Motion 1961-1.


14 KENNETH BUSH: Okay. Okay. NFPA 1961 appeared

15 on our Agenda. However, no one has signed in to make

16 a Certified Amending Motion on this standard.

17 Therefore, in accordance with the NFPA Rules,

18 Regulations, Regulations at 4 - 4.5.3.7, and the

19 Convention Rules at 2.7, this standard will not be

20 considered this meeting - excuse me, and - and instead

21 becomes a Consent Standard that will be forwarded

22 directly to the Standards Council for issuance on

23 other action - or other action.

24 We would like to thank the Committee for their

25 work on the Standard. We will now, now move on to the



146

1 next Standard.

2 ANDREW ALLISON: Thank you.

3 (applause)



6 Structural and Proximity Fire Fighting Protective

7 Clothing and Equipment. Here to present the Committee

8 Report is Committee Chair, Tom - I'm sorry - Tim

9 Tomlinson of Addison Fire Department, Dallas, Texas.

10 The Committee Report, that is the First and the




14 NFPA Technical Meeting Agenda, and will be displayed

15 behind me on the screen as they are under debate.

16 Mr. Tomlinson, will you present the Chair

17 Report.

18 TIM TOMLINSON: Mr. Chairman, ladies and

19 gentlemen, the Report of the Technical Committee on

20 Structural and Proximity Fire Fighting Protective

21 Clothing and Equipment is presented as found in the

22 First Draft Report, and Second Draft Report for the

23 2019 annual revision cycle.

24 The Technical Committee has published a First

25 Draft, and Second Draft Report consisting of revisions



147

1 to NFPA 1851, Standard on Selection, Care,

2 Maintenance, of Proximity - of Protective Ensembles

3 for Structural Firefighting and Proximity

4 Firefighting. The revisions were submitted to letter

5 ballot of the responsible Technical Committee. The

6 reports and ballot results can be found on the Next

7 Edition tab of the Document Information Page for NFPA

8 1851 at www.nfpa.org/1851next.

9 Mr. Chair, I move for Standards Council

10 issuance of the Committee's Report on NFPA 1851.

11 KENNETH BUSH: Thank you, Mr. Tomlinson. Let's

12 now proceed with the discussion on the Certified

13 Amending Motion on NFPA 1851-1. Microphone four,

14 please.

15 DAVE BURNS (phonetic): Dave Burns,

16 (unintelligible) Association of Professional

17 Firefighters. I speak for the motion to reject Second

18 Revision No. 37.

19 One of the largest emerging concerns for the

20 Fire Service --

21 KENNETH BUSH: Sir, we need to - we need to

22 have a motion on the floor.


24 KENNETH BUSH: I'll, I'll, I'll take that as a

25 motion and a second on the floor.



148

1 (laughter)

2 KENNETH BUSH: Now we can proceed with

3 discussion. Thank you.

4 DAVE BURNS: Thank you. One of the largest

5 emerging concerns for the Fire Service is the

6 increased rate of cancer among firefighters. These

7 rates are at alarming levels, and many departments are

8 feeling the premature and rapidly escalating loss of

9 its members due to cancer related deaths.

10 Unfortunately, the personal protective

11 equipment that we depend on to protect us from flame,

12 heat, and physical hazards does an adequate, but

13 imperfect job of protecting us from the frequent

14 exposure of soot, and fire gasses, which include known

15 and suspected carcinogens.

16 Advances are being made through the work of

17 NFPA committees to, to make needed improvements in

18 personal protection. However, protective clothing and

19 equipment, once contaminated, create the threat of

20 continued exposure until properly cleaned. Yet, many

21 research studies have consistently shown that cleaning

22 processes are only partially effective. In some

23 cases, conventional cleaning may remove only 10 to 20%

24 of certain dangerous contaminants, and average

25 cleaning efficiencies across the range of contaminants



149

1 are reported around 50%.

2 In the most recent revision of NFPA 1851,

3 extensive work undertaken by the Fire Protection

4 Research Foundation was used to provide the basis for

5 developing cleaning verification requirements to show

6 exactly how effective cleaning of gear can be.

7 Specific requirements were developed that will be

8 applied to both manufacturers and companies that

9 routinely clean firefighting - firefighter clothing.

10 The requirements include procedures intended to

11 standardize how claims of cleaning effectiveness are

12 made, and include modest criteria to incentivize the

13 industry for creating improved cleaning - methods of

14 cleaning.

15 As part of the 1851 revision, a caveat was

16 inserted to extend the mandatory compliance of these

17 requirements to two years, rather than the one year

18 period associated with all other parts of the

19 standard. This means the cleaning verification will

20 not be mandated until 2021. One year is an

21 appropriate and reasonable period of time for those

22 organizations providing gear cleaning services to be

23 held accountable for the effectiveness of their

24 cleaning process.

25 Accepting this NITMAM means applying the same



150

1 grace period that is applied in other standards for

2 new requirements involving personal protective

3 equipment. There are laboratories that are ready to

4 provide the necessary test services in order to carry

5 out the verification of cleaning. Delaying the

6 implementation of this requirement for an additional

7 year would only - would, would cause further harm to

8 the Fire Service.

9 This NITMAM therefore corrects a concession

10 that needlessly delays specific benefits that should

11 be provided to firefighters by the promotion of a

12 process for better cleaned gear, and reducing yet

13 another avenue of contamination exposure.

14 It is essential that this body vote in favor of

15 this NITMAM to address the significant aspect of

16 contamination control affecting firefighter health and

17 safety. Thank you.

18 KENNETH BUSH: Thank you. Mr. Tomlinson, would

19 you like to offer the Committee's position.

20 TIM TOMLINSON: Yes, Mr. Chairman. Mr.

21 Chairman, the position of the Committee is to oppose

22 the motion, and uphold the Second Draft final ballot

23 results, which provided consensus amongst the

24 Committee to allow the 21 - 24 month period for

25 organizations to verify to the new criteria.



151

1 The agreement of the Committee was to allow

2 this concession for the reasons of allowing the labs

3 enough time to prepare for verification of these new

4 criteria, and additionally, allow the industry ample

5 time to become ready, and educated to verify to these

6 new requirements, as well.





11 Microphone six, please.

12 ANDY OLIVER: Thank you, Mr. Chairman. My

13 name's Andy Oliver, with Verified Independent Service

14 Providers Association. I'm speaking against the

15 motion.

16 We are for the new cleaning validation for

17 heavy metals and biological contaminants, but we are

18 against accelerating the phase-in period to 12 months,

19 versus the stated 24 months. We believe that's going

20 to rush the labs too much. They're still doing

21 testing. They're still trying to do run-throughs, so

22 it's not ready. So we think if, if we rush this, it's

23 going to be negative for the Fire Service. So the

24 original purpose of the 24 month period was to enable

25 the industry to digest the information, and develop a



152

1 commercially viable process. Again, this is very

2 complex.

3 So again, we think if it's a 12 month period,

4 it's going to be - we're going to have negative

5 outcomes for the Fire Service.

6 In addition, voting against this motion does

7 not mean ISPs are not going to get verified in the

8 first 12 months. Some companies will be able to do

9 that. But there's a greater majority that still need

10 to, again, digest the information, upgrade their

11 facilities and their equipment, and we don't want to

12 see this rushed, because we do want good quality

13 outcomes for the Fire Service. Thank you, Mr.

14 Chairman.

15 KENNETH BUSH: Thank you. Microphone five,

16 please.

17 MARCELO HIRSCHLER: Marcelo - Marcelo

18 Hirschler, GBH International, speaking for NAFRA, and

19 in support of the motion.

20 It's been demonstrated that one of the critical

21 things to maintain the health of the firefighters is

22 to clean the uniforms, and have uniforms that are as -

23 most up to date as possible. The more gap we allow,

24 the less safe it will be for firefighters. Please

25 support the motion. Thank you.



153

1 KENNETH BUSH: Thank you. Microphone five,

2 please.

3 JAY TORLEY (phonetic): Jay Torley, National

4 Institute for Occupational Safety and Health, and I'm

5 in support of the NITMAM.

6 The process for developing the requirements was

7 open and transparent. Specific information used in

8 support of the requirements arose from an extensive,

9 three-year Department of Homeland Security effort that

10 funded the Fire Protection Research Foundation.

11 The Foundation, in turn, worked with the

12 National Personal Protective Technology Laboratory,

13 which is part of the National Institute for

14 Occupational Safety and Health, which conducted the

15 principle research that led to the proposed adopted

16 test methods and suggested criteria. Throughout this

17 process, the industry, and the ISPs were kept informed

18 of the progress, and provided periodic reviews of the

19 project direction.

20 In the course of the project, the proposed

21 procedures and criteria were repeatedly applied to

22 multiple independent service providers. When the

23 requirements were first proposed, some believed that

24 these procedures were not workable, or could not be

25 implemented. These objections were raised before the



154

1 requirements could be fully described during the

2 initial Second Draft meeting for the Committee. And I

3 would like to remind this group that other, more

4 intense test requirements for like the SCBAs are

5 completed in the one-year grace period.

6 So I believe that this is an important issue

7 for the Fire Service, to get ahead of, of

8 contamination control, and its implementation should

9 be undertaken as soon as practicably possible. Thank

10 you.

11 KENNETH BUSH: Thank you. Microphone number

12 four.

13 JIM REEDY: Morning. My name is Jim Reedy. I

14 represent the Texas State Association of Firefighters.

15 I rise in support of the, the motion. We - I sit on

16 this Committee, and originally I voted for the 24

17 month implementation. But in the State of Texas since

18 that, that Committee meeting, we've had an incident

19 where a supposed verified cleaner sent back gear to a

20 fire department, and the firefighters were injured,

21 based on the improper cleaning procedures.

22 We need to have these cleaners and ISPs

23 verified in a timely manner. Two years is not a

24 timely manner. Now that the - some of the labs can

25 already be up and running and, and do the verification



155

1 that needs to be done, I, I would recommend that we go

2 back to the one-year period, just like everything else

3 is done one year on that standard - we should go to

4 one year. Thank you.


6 discussion on Motion 1851-1 to Reject --

7 KAREN LETONEN (phonetic): Microphone number

8 six.

9 KENNETH BUSH: -- Revision No., No. 37?


11 KAREN LETONEN: Thank you. I'm Karen Letonen

12 from Lion (phonetic), and I'm speaking against the

13 motion. I, I'm not here to speak against the

14 verification and the cleaning process. It is

15 extremely critical that that move forward for the

16 health and safety of the firefighter, for them to have

17 clean gear.

18 What I am opposed to at this time is the

19 changing from two years to one year. During the

20 revision process, the Technical Committee discussed at

21 length, and supported the need for the additional time

22 for this verification. These procedures and testing

23 is very complex, and somewhat new to this industry. I

24 agree that there were several studies; the ISPs were

25 kept informed of these test procedures. However, even



156

1 though the labs are stating they are ready, there's

2 still some question about the text that's in the

3 standard. So that concerns me, in terms of not being

4 able to be verified within one year. If that happens,

5 it does further damage to the Fire Service, because

6 there will be no ISPs who are verified to this

7 requirement. And then that leaves you in a position

8 of a gap. So we are speaking against this.

9 The TC recently approved five TIAs to be

10 concurrently published with this Standard. This issue

11 could have been easily submitted as a TIA along with

12 those, so the Committee could have decided if the two

13 year was no longer necessary and we needed to go to a

14 12 month grace period.

15 So if the verification can't be realized, it

16 could put the Fire Service in jeopardy. So again,

17 Lion supports the need for this validation. We are

18 ready to submit it as soon as possible, and so are

19 other organizations. But there - it could be a risk;

20 that we need to understand the challenges for both the

21 testing laboratories, and other ISPs, which is why we

22 are supporting the original direction of the Technical

23 Committee, and speaking against this motion. Thank

24 you.




157


2 No. 37? Mr. Chair, any further comments from

3 Committee?

4 TIM TOMLINSON: Yeah, Mr. Chair. We just - one

5 final comment to give everybody a perspective on the

6 timeline. This document does issue in August. So

7 that's what the timeline we're looking at, as far as

8 the 12 or 24 months. That's all I have, Mr. Chairman.



11 the motion. The motion on the floor is to Reject

12 Second Revision No. 37. To touch - to vote, touch the





17 record your vote.





22 passed.



25 Thank you, Mr. Tomlinson.



158

1 TIM TOMLINSON: Thank you, Mr. Chairman.

2 (applause)


4 consideration is that of the Committee on Liquefied

5 Petroleum Gases. Here to present the Committee Report

6 is Committee Chair Richard Hoffmann of Hoffmann,

7 Feige, Brewster, New York. The Committee Report, that

8 is the First and Second Draft Reports, is located on

9 the Document Information Page for NFPA 58 on the NFPA


11 in the NFPA Technical Committee meeting, that is the

12 Tech Session Agenda, and will be displayed behind me

13 on the screen as they are under debate.

14 Mr. Hoffmann, will you present the Chair

15 Report.

16 RICHARD HOFFMANN: Thank you, Sir. Mr. Chair,

17 ladies and gentlemen, the Report of the Technical

18 Committee on Liquefied Petroleum Gases is presented as

19 found in the First Draft Report, and the Second Draft

20 Report of the 2019 annual revision cycle.

21 The Technical Committee has published a First

22 and Second Draft Report, consisting of revisions of -

23 to NFPA 58, Liquefied Petroleum Gas Code. The


25 responsible Technical Committees. The reports and



159

1 ballot result can be found in the Next Edition tab of




5 issuance, the Committee's Report on NFPA 58.

6 KENNETH BUSH: Thank you, Mr. Hoffmann. Let's


8 Amending Motion on NFPA 58-1. Microphone one, please.

9 TED LEMOFF: My name's Ted Lemoff, and I move

10 to Reject Second Revision 9.

11 KENNETH BUSH: Thank you. Is there - there is

12 a motion on the floor to Reject Second Revision No.

13 69. Is there a second?


15 KENNETH BUSH: We have a second. Please

16 proceed with the discussion on the motion. Microphone

17 --

18 TED LEMOFF: Thank you.

19 KENNETH BUSH: -- one.

20 TED LEMOFF: Thank you, Mr. Chair. I've been a

21 member of the NFPA 58 Committee since 1985. I served

22 as the Staff Liaison, and I'm the author of - or the

23 editor, of eight editions of the Liquefied Petroleum

24 Gases Handbook. I now represent myself, my own

25 company, on the Committee.



160

1 This is all about purging of flammable gases.

2 Purging of flammable gases is very important, which

3 was highlighted by the Clean Energy explosion in

4 Connecticut in 2010, with six fatalities. Today,

5 there are minimal requirements in NFPA 58 for purging

6 propane, mostly covering purging of cylinders and

7 tanks. I submitted a proposal to add purging

8 requirements for piping systems in the 2020 edition,

9 which was accepted. Proposal required purging for

10 propane lines, with a pressure of up to 125 PSIG in

11 accordance with NFPA 54, and higher pressures in

12 accordance with NFPA 56, which is the standard for

13 fire and explosion during cleaning and purging of

14 flammable gas and piping systems. And just so you

15 understand, the scope of NFPA 54 goes up to, but stops

16 at 125, so that's the reason for that break. And when

17 I say purging, we're talking about replacing of one

18 gas with another - so either air with air, or propane

19 with air, as piping is taken into or out of service.

20 The substantiation for the comment stated that

21 this revision contains references to NFPA 54, which

22 excludes propane over 50 PSIG, and NFPA 56, which

23 excludes propane. Well, these - these statements are

24 true. However, 54 excludes propane systems over 50

25 PSI because above 50 PSI, the propane will condense



161

1 back to a liquid, and if you're feeding this as a fuel

2 to an appliance, you don't want liquid coming in,

3 because the liquid will expand about 260 volumes to

4 one, and if it's a range, you're talking about getting

5 pretty high flames on the top of the range.

6 56 excludes propane because when it developed,

7 the Committee apparently never, never bothered to see

8 what 58 said about purging. In fact, it really only

9 covers purging of tanks and cylinders.

10 The - propane is stored as a liquid, and most

11 propane storage plants can have very long runs of

12 piping, especially rail terminals, pipeline terminals,

13 and marine terminals. And purging of these is very

14 important, and requires specific safety procedures to

15 prevent accidental addition - ignition, which just

16 aren't in NFPA 54. So it's for these higher pressure,

17 and liquid containing lines that we need NFPA 56. I

18 encourage you to vote for the motion. Thank you.

19 KENNETH BUSH: Thank you. Mr. Hoffmann, would


21 RICHARD HOFFMANN: Pardon me?

22 KENNETH BUSH: I'm sorry - Mr. --

23 RICHARD HOFFMAN: I didn't hear your question.

24 KENNETH BUSH: Would you like to offer the

25 Committee's position?



162

1 RICHARD HOFFMANN: Yeah. The Committee's

2 position is we are against this motion. The Committee

3 addressed it fully during its meetings. We have 33

4 members; the 24 voted in, in favor of rejecting the

5 motion that was proposed by Mr. Lemoff, and it - there

6 were, there were four negatives against it, and only

7 two discussed the addition of NFPA 56.

8 The NFPA 56 excludes the propane code

9 requirements, and they both require written

10 procedures. The Committee felt that it was best that

11 these purging issues remain in 58, and it referenced

12 54. And that represents our position.





17 Microphone three, please.

18 BRUCE SWIECICKI: Thank you. Bruce Swiecicki

19 with National Propane Gas Association. I'm speaking

20 against the motion on the floor.

21 I'm also a member of all three of the Technical

22 Committees that we are discussing here - 58, 54, and

23 56. And as was pointed out already, the, the scopes

24 don't quite match up in either 56 or 54, with what's

25 in 58. But based on the, the, the motion on the



163

1 floor, we're talking about piping systems designed

2 with pressures greater than 125 PSIG. Those will

3 predominantly be liquid piping systems, to be found at

4 bulk plants, some vaporizer applications.

5 But if you look at the, the actual purging

6 requirements between the two standards, 56 and 54,

7 you'll see that they are very similar, if not

8 identical. They both require written procedures.

9 Chapter 15 in NFPA 58 requires written procedures for

10 operations and maintenance. They both require

11 calibrated detection equipment. The point of

12 discharge is controlled, with respect to sources of

13 ignition, building openings, and the general public.

14 They both require purging with inert gas first,

15 whether in or out of service.

16 But the most important reason to, to vote

17 against this motion is really a safety concern. The

18 propane industry personnel that will be conducting

19 these purging operations are trained according to

20 materials that are provided by the Propane Education

21 and Research Council. And the Council relies heavily

22 on NFPA 58, and NFPA 54 to develop those materials.

23 So you're talking about service personnel in the field

24 that are being trained right now to the requirements

25 of NFPA 54. They are not familiar with 56; 56 is not



164

1 referenced currently in NFPA 58, so you'd be

2 introducing a whole new document, and disrupting

3 potentially the, the training and the effectiveness of

4 these individuals to perform the purging operations

5 safely. So I urge you to support the Technical

6 Committee on this particular one, and vote against the


8 KENNETH BUSH: Thank you. Microphone five.

9 JOHN PUSKAR: Hello. My name is John Puskar.

10 I'm here to support the motion. I'm also a member of

11 NFPA 54 and of 56. I'm not representing those

12 committees officially. I'm speaking on behalf of

13 myself, and my company, Prescient Technical Services

14 in Cleveland, Ohio.

15 The reason I support the motion is really two-

16 fold. Excuse me, I don't know if - getting an

17 interruption there, and how I'm sounding. But the

18 first is that it makes no sense to me at all that we

19 would be providing the same guidance to a plumber

20 installing a residential hot water heating system as

21 we would to a team of people installing a industrial

22 tank farm system with 200-pound pressure propane. It

23 just makes no sense at all.

24 I would believe that most of you in this room

25 commonsensically would agree that as the pressure of a



165

1 piping system increases, so does the hazard. You just

2 can't treat them the same way. In fact, this was

3 recognized, and this was one of the primary reasons

4 why NFPA 56 was created. After a couple of horrible

5 accidents with high pressure gas piping systems, US

6 Chemical Safety Board asked NFPA to create such a

7 document. We now have such a document.

8 The second reason I support this is that

9 document is a great tool, and it provides the proper

10 guidance for this situation. It provides, for

11 example, the need to do a plan. Yes, 54 says do a

12 plan. But 56 actually provides more than 40 specific

13 criteria that you should include in your plan. There

14 are questions that guide you through the creation of

15 the plan - like, where is the cloud going to go when

16 you depressurize a piping system; have you considered

17 the specific chemical properties of what you're

18 releasing; have you considered contacting people in

19 the Fire Service, and the community to let them know

20 that you might be doing this kind of hazardous event.

21 I'm sure you folks in the audience here in the fire

22 community would appreciate that.

23 The second issue is that we asked that a safety

24 validation be created for that plan. So we asked that

25 people who didn't create the plan review that plan,



166

1 and challenge it. We also asked that inert substances

2 be used to move residual gasses out. There's specific

3 criteria about isolating piping systems, and it

4 requires the use of meters. And yes, there could be a

5 training deficiency. But 56 requires people to be

6 trained - how to use meters, the hazards of nitrogen.

7 If that training deficiency exists, I'd rather fix the

8 training deficiency than use an inappropriate

9 standard.

10 So I hope you'll join me in supporting, moving

11 with Mr. Lemoff's motion here. We don't need to have

12 more people not coming home from work before we decide

13 to address this. Thank you very much.

14 KENNETH BUSH: Thank you, Sir. Is there any

15 further discussion on Motion 58-1 to Reject Second

16 Revision No. 69?


18 KENNETH BUSH: Microphone one, please.

19 TED LEMOFF: Ted Lemoff, speaking for myself.

20 I want to just give a little perspective --

21 KENNETH BUSH: Excuse me, Sir. In support or

22 against the motion?

23 TED LEMOFF: I'm in support of my motion.

24 KENNETH BUSH: Thank you.

25 TED LEMOFF: A little perspective - NFPA's 54



167

1 requirements were developed first, following a, a

2 couple of, of incidents. I mean, it's a very real

3 thing. And it was thought to be an - sufficient and

4 adequate for mostly smaller systems. And I'm not

5 commenting on that.

6 Fifty-six was developed later, and it is

7 clearly more rigorous. And it's my opinion that for

8 the higher pressure, liquid systems, we need a more

9 rigorous system. Thank you very much.



12 No. 69? Mr. Chair, any final comments from the

13 Committee?

14 RICHARD HOFFMANN: My final comments are that

15 NFPA 58 requires written procedures for all of these

16 operations that are performed in these plants, and

17 it's applicable, and it's - references to 54, and -

18 which is the low pressure propane code, propane vapor

19 code, appliances, and it's - I recommend that we vote

20 No on this recommendation.

21 KENNETH BUSH: Thank you. Before we vote, let


23 Reject Second Revision No. 69. To vote, touch the





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3 record your vote.




7 the motion; 102 oppose the motion. The motion has

8 passed.


10 Seeing none, we will like - we'll move to the next

11 document.

12 I would like to make an announcement. We will

13 only be taking 15 minute breaks throughout the session

14 today. We will not be breaking for lunch. We

15 encourage you to leave to get snacks or lunch at your

16 convenience. There is a food court that is open at

17 the bottom of the escalators, and a food cart

18 immediately outside the ballroom.

19 Before we begin debate on the next standard, I

20 would like to introduce James Quiter, member of the

21 Standards Council, who will be the Presiding Officer

22 for motions before the Membership on the next three

23 standards.

24 JAMES QUITER: Thank you, Mr. Bush. We have a

25 lot of work to do, so we're going to dive right in.



169

1 The next report under consideration is that of

2 the Technical Committee on Fire Protection for Nuclear

3 Facilities. Here to present the Committee Report is

4 Committee Chair William Till of Bernie Till &

5 Associates, Orangeburg, South Carolina.



8 Information Page for NFPA 801, on the NFPA website.




12 debate.

13 Mr. Till, will you present the Chair Report.

14 WILLIAM TILL: Thank you, Mr. Chair. Mr.

15 Chair, ladies and gentlemen, the Report of the

16 Technical Committee on Fire Protection for Nuclear

17 Facilities is presented as found in the First Draft

18 Report, and Second Draft Report, for the 2019 annual

19 revision cycle. The Technical Committee has published

20 a First and Second Draft Report consisting of

21 revisions to NFPA 801, Standard for Fire Protection

22 for Facilities Handling Radioactive Materials. The


24 responsible Technical Committee. The reports and




170





5 JAMES QUITER: Thank you, Mr. Till. Let's now

6 proceed with the discussion on the Certified Amending

7 Motion on NFPA 801-1. Microphone four, please.

8 JAMES PETERKIN: Yes, this is James Peterkin

9 with TLC Engineering Solutions, and I move to accept

10 Certified Amending Motion 801-1 to Reject Second

11 Revision 1.

12 JAMES QUITER: Thank you. There is a motion on

13 the floor to Reject Second Revision No. 1. Is there a

14 second?


16 JAMES QUITER: I hear a second. So please


18 JAMES PETERKIN: Yes, thank you. Yeah, this

19 again is not necessarily opposed to the - what the

20 code - the Technical Committee is trying to do here.

21 I just think it's bad code language. There - the, the

22 proposed code language requires fire protection

23 systems shall be tested in their entirety, end to end

24 - which is not really defined; it's kind of vague.

25 They further put Annex material, and it says, 'should



171

1 be tested in accordance with NFPA 4' - which is the

2 standard for integrated testing.

3 What they should have done was just put in,

4 'tested in accordance with NFPA 4'. I just think the

5 language is a little too vague, and should be cleaned

6 up. So - look forward for your support. Thanks.

7 JAMES QUITER: Thank you. Mr. Till, would you

8 like to offer the Committee's position?

9 WILLIAM TILL: Thank you, Mr. Chair. The

10 Technical Committee provided the language presented in

11 recognition of the need for a thorough and complete

12 verification of the operability of integrated fire

13 protection systems. Given the complexity of

14 facilities which handle radioactive materials, and the

15 unique hazards associated with those materials, the

16 reliability of fire protection systems performing as

17 intended is paramount to reducing the potential

18 consequences of fires.

19 The - with regard to the submitter's comments

20 on the non-mandatory language in the Annex, that is by

21 design, in accordance with the NFPA Guidelines for

22 Recommended Guidance in the Annex; and what we - what

23 the intent of the Committee was, was to drive the

24 integrated testing, but without being overly specific

25 with regard to how that is done, but yet still



172

1 recognize the best available guidance on that subject.

2 JAMES QUITER: Thank you, gentlemen. With





7 DAN FINNEGAN: Hi. Good morning. My name is -

8 I'll be speaking against the motion. My name is Dan

9 Finnegan with Siemens Smart Infrastructure. And I'm a

10 member of various NFPA Technical Committees including

11 72, but I'm not speaking on their behalf.

12 The proponent's statement that maybe the code

13 language could have been better - that's debatable.

14 But I'm really against the idea of eliminating this

15 entirely.

16 The - it's important that we do end to end

17 testing on these systems, because as the codes and

18 standards stand today - for example, 72 and 25, there

19 is a gap. We are directed in NFPA 72 to only test up

20 to the point of interface. We do not test end to end,

21 or follow through the whole sequence of life safety

22 measures. So it's important that this language be

23 there.

24 The reference to NFPA 4 is rock solid - that is

25 the standard for integrated testing. And maybe next



173

1 time around, if we want to tune that language up a

2 little bit - but the industry understands what end to

3 end testing means, and I think this is appropriate to

4 stay in, and it will be a significant life safety

5 issue if it should be removed by accepting this

6 motion. So I ask everyone to please vote against this


8 JAMES QUITER: Thank you. Microphone one,

9 please.

10 DAVE DEGENAIS: Dave Degenais, speaking on

11 behalf of the Healthcare Section, in favor of the

12 motion. The Healthcare Section met yesterday at their

13 annual business meeting, and voted to speak and

14 support this motion. Again, we are not against the

15 expectation around testing or integrative testing.

16 What we are against is the terminology of end to end.

17 It is unclear. It gives - lacks clarity. The

18 reference to NFPA 4 is really all that should have

19 existed. As an owner, at the end of the day, it, it -

20 you, you don't understand, and will not know what that

21 end to end testing is.

22 Also, the other thing I want to emphasize is

23 that this is for facilities that handle radioactive

24 material. There's a variety of facilities that do

25 have access to radioactive materials - not necessarily



174

1 nuclear power plants, but the radioactive material

2 exists within many industries. So the Healthcare

3 Section urge you to support this motion. We believe

4 that the integrative testing expectation requirements

5 already exist within NFPA 4, and that will be

6 addressed there, and then clean this up and get it

7 back on the next cycle. I urge you to support.

8 JAMES QUITER: Thank you. Microphone three,

9 please.

10 HOWARD HOPPER: Howard Hopper, UL. Just a

11 point of order. You know, I was - I was familiar with

12 the term end to end testing. And I looked into the

13 NFPA 4, and this is a defined term - end to end

14 integrated system testing. So I'm not sure if there's

15 really that much confusion about what that entails.

16 Thank you.

17 JAMES QUITER: Thank you. Is there any further

18 discussion? Microphone three.

19 DAN FINNEGAN: Yes. Hi. Good afternoon. Dan

20 Finnegan, Siemens Smart Industry. Just really one

21 more time - expressing the caution, if this motion

22 goes forward --

23 JAMES QUITER: Sorry - for or against?

24 DAN FINNEGAN: Excuse me. I am against the

25 motion, Sir. And just wanted to reiterate, as Mr.



175

1 Hopper said, that end to end testing is defined, and

2 that if we eliminate this by accepting this motion, we

3 will have no direction or guidance towards end to end

4 testing, and referring to NFPA 4. I'm in agreement

5 that next cycle around, we could improve the language.

6 But this needs to stay where it's at for now. Please

7 vote against this motion. Thank you.


9 discussion. Microphone six - you're not discussing?

10 No. Okay. Is there any further discussion to - on

11 Motion 801-1 to Reject Second Revision No. 1? If not,

12 Mr. Chair, do you have - would you like an opportunity

13 to - for final comments?

14 WILLIAM TILL: I do, Mr. Chair, thank you. The

15 Committee voted unanimously in support of the

16 requirements for integrated testing for facilities

17 handling radioactive materials because of the critical

18 importance of fire protection systems and protection

19 of both on site personnel, and the general public.

20 Thank you, Mr. Chair.

21 JAMES QUITER: Thank you. Before we vote, let







176



3 record your vote.



6 The results of the vote are: 51 in favor; 346

7 voted no. Therefore, the motion fails.



10 Thank you, Mr. Till.

11 (applause)

12 JAMES QUITER: The next report under


14 Energy Storage Systems. Here to present the Committee

15 Report is Committee Chair James Biggins of TUV SUD

16 America Inc., Manhattan, Illinois.







23 debate.

24 Mr. Biggins, will you present the Chair Report.

25 JAMES BIGGINS: Thank you. Mr. Chair, ladies



177

1 and gentlemen, the Report of the Technical Committee

2 on Energy Storage Systems is presented as found in the

3 First Draft Report, and the Second Draft Report for

4 the 2019 annual revision cycle. The Technical

5 Committee has published a First and Second Draft

6 Report consisting of revisions to NFPA 855, Standard

7 for the Installation of Stationary Energy Storage

8 Systems. The revisions were submitted to letter

9 ballot of the responsible Technical Committee. The

10 reports and ballot results can be found on the Next

11 Edition tab of the Document Information Page for NFPA

12 855, at www.nfpa.org/855next. Mr. Chair, I move for

13 the Standards Council issuance, the Committee's Report

14 on 855.

15 JAMES QUITER: Thank you, Mr. Biggins. Let's


17 Amending Motion on NFPA 855-1. There you are.

18 Microphone one, please.

19 JAMES HOUSTON: Okay. My name is James

20 Houston. I'm with Southern Company, and Chair of the

21 National Electric Safety Code Committee, Subcommittee

22 Three for Supply Stations. I am Sue Vogel's

23 designated representative, and speaking on her behalf.

24 Ms. Vogel is the IEEE - was with - is with IEEE as the

25 Senior Manager responsible for the NESC. I move to



178

1 Accept Public Comments 912 and 454.

2 JAMES QUITER: There is a motion on the floor

3 to Accept Public Comment 912 and 454. Is there a

4 second?



7 JAMES QUITER: We do have a second. Please

8 proceed with the discussion on the floor. Microphone

9 one.

10 JAMES HOUSTON: Okay. The electric utility

11 industry encourages the NFPA members to continue to

12 recognize the boundaries between the NFPA codes, and

13 the National Electric Safety Code. Both organizations

14 are highly committed to safety. The electric utility

15 environment is a hazardous one for those not familiar

16 with it. It is therefore important that utilities be

17 allowed to continue to develop codes where their

18 expertise in complex electrical systems and energy

19 storage is essential.

20 The National Electric Safety Code is the

21 established consensus standard that is used in whole

22 or in part by statute, regulation, or consent, as the

23 standard of safe practices for public and private

24 utilities in the US. The National Electric Safety

25 Code is voluntary, adopted by the federal government,



179

1 and as large - majority of the US states, giving the

2 effect of law. It is also used in various

3 jurisdictions and industries in other countries, and

4 has been in existence for over 100 years.

5 The purpose of the National Electric Safety

6 Code is the practical safeguarding of persons and

7 facilities on the utilities side of the service point,

8 whereas the NFPA 70 applies to facilities behind the

9 service point.

10 NFPA 855 does not allow - does not allow for

11 this historical delineation. The NESC 2022 revision

12 is addressing energy storage, and change proposals to

13 the NESC have already been submitted to support the

14 Department of Energy's coordination of ESS code

15 changes. These changed proposals are extensive and

16 comprehensive. Many 855 provisions should not be

17 applicable to installations constructed under the

18 NESC. Thus, similar to the structure of the NEC,

19 there should be two subsections to the scope of 855 -

20 covered, and not covered.

21 The - this course of action is strongly

22 recommended by the National Electric Safety Code

23 Executive Committee.

24 Additionally, the National Electric Safety Code

25 welcomes the submission of public comments from all



180

1 stakeholders and entities for the revision of the 2022

2 National Electric Safety Code, and the pre

3 (unintelligible) opens to public comment July 1st,

4 2019. That will be in a couple weeks.

5 I would also like to encourage that the

6 National Electric Safety Code and NFPA leaders who

7 work closely together to prevent code conflicts such

8 as this one, as outlined in the white paper developed

9 by both the NESC and NEC leaderships. This paper is

10 the NEC and NESC Partners for a Safer Tomorrow, dated

11 October 2016, and the recommendation be adopted from

12 this paper for a Cross Code Correlation Committee to

13 apply to all code development matters. This will help

14 lay out a clear roadmap for future code development,

15 and prevent conflicts.

16 I respectfully ask that the NFPA members vote

17 for Certified Amending Motion 855-1. Thank you.


19 please.

20 HOWARD HOPPER: Howard Hopper, UL, also a

21 member of the - TC member; but for this motion and the

22 other 855 motions, I will not be speaking on behalf of

23 the Committee. I'm speaking against the motion.

24 Now, the issue of electric utility ESS

25 installations was debated extensively at the



181

1 Committee, at the number of - large number of

2 Committee meetings we had. And we have a number of

3 specific requirements in 855 that apply to electric

4 utilities. There's specifically some carveouts for

5 lead acid systems at their facilities.

6 Now, the real safety concern you have here is

7 ESS systems under the exclusive control of electric

8 utilizes are no longer limited to those at a remote

9 power plant, or those at a remote switch gear area

10 location. These, these ESS installations - you may

11 have a floor of a building in an urban area that's

12 under the exclusive control of the electric utility.

13 And what we'd say here is that with these requirements

14 in place in this building, if the electric utility

15 owned that floor, we'd say - you don't have any ESS

16 requirements. We're going to exempt them to some

17 other utility requirements that are, I guess, due to

18 be developed in 2022.

19 So the hazard's the same. It doesn't depend if

20 the electric utility owns the ESS, or they're under

21 private ownership - the hazard's the same.

22 We also did accommodate the electric utilities

23 in, in 855, because we specifically developed

24 requirements for ESS at dedicated, remote facilities,

25 such as indoor installations, such as those at a power



182

1 plant, or for remote outdoor locations, such as -

2 outdoor ESS locations, such as those at a, at a

3 switchyard.

4 So vote - I'm urging you to vote against this,

5 because you're introducing - with this exception,

6 you're introducing exposure hazards to occupants,

7 occupancies, and emergency responders. Thank you.

8 JAMES QUITER: Thank you. Mr. Biggins, my

9 apologies. I forgot to give you an opportunity to

10 talk on behalf of the Committee.

11 JAMES BIGGINS: Thank you, Mr. Chairman.

12 Howard just mentioned a couple of points. First, this

13 is the first of a number of motions that'll be made to

14 try to exempt electric utilities from the NFPA 55

15 Standard. And as Howard mentioned, the Technical

16 Committee, for the large scale, grid type systems

17 created two categories - dedicated use buildings, and

18 remote locations, in order to exempt these

19 installations that are under the direct control and

20 supervision of utilities and the power companies from

21 being covered by 855.

22 Also, a great deal of concern is from

23 utilities, there's a misconception that this standard

24 would impose new, cumbersome requirements on lead acid

25 or nickel cadmium battery systems and substations, and



183

1 power plants. When these issues were brought to the

2 attention of the Technical Committee by the industry,

3 the Committee carefully considered the comments, and

4 provided exemptions from these requirements in various

5 sections of Chapter Four, in the Second Revision of

6 the draft. These requirements, they are provided in

7 exemptions; it's very similar to the wording within

8 NFPA 70, and state that if the installations aren't

9 installed in accordance with IEEE-C2, then they do not

10 fall under the requirements of NFPA 855.

11 The one thing that NFPA 855 Technical Committee

12 did not exempt the utilities or anybody from, are the

13 requirements that directly affect the public safety,

14 or the safety of first responders. This includes

15 means of egress requirements; developing commissioning

16 and decommissioning requirements and plans for

17 installations; develop, developing a - performing a

18 hazards analysis when the scope of the installation

19 goes beyond what's required by 855, or - or is of, of

20 a technology that 855 does not cover yet.

21 With respect to this motion, the proposed

22 wording would exclude utilities from 855, and also

23 within the substantiation of the submitter, it was

24 made quite clear that these requirements are not yet

25 in C2. They're being proposed, and they will not be



184

1 within the C2 document until 2022, and the Committee

2 does not feel that any installation should be not -

3 essentially, not covered by any requirements until

4 that point.

5 JAMES QUITER: Thank you, Mr. Biggins. To

6 microphone four please.

7 SHARON BONESTEEL: Sharon Bonesteel, Salt River

8 Project, speaking in support of the motion on the

9 floor, and seeking your support.

10 When I utilize a code or a standard, the more

11 exemptions it has scattered throughout the document

12 makes it more difficult to use. NFPA has

13 traditionally honored the line of demarcation. They

14 have understood that utilities require a different

15 approach. We have NFPA 801 for nuclear plants; 850

16 for electric generating plans; 851 for hydro-plants.

17 And potentially, we need another NFPA standard. But I

18 like the idea of sticking with the National Electric

19 Safety Code, because it is - it is well set up to

20 coordinate the standards with those other authorities

21 having jurisdiction on us, which include the federal

22 government.

23 One of the things we dealt with between the

24 First and Second Draft, is helping the Committee

25 understand the different situations we operate under.



185

1 We have to deal with the security of the grid.

2 There's a lot of things we can't do in the normal

3 format. What we learned in Arizona, is what we need

4 is training, and cooperation, and discussions. And

5 we're moving forward, pursuing some of those

6 conversations.

7 But to sit there and say that the battery

8 doesn't know who it's working for, in some ways is

9 just like saying - let's take a Formula One race car,

10 and let's see how Lewis Hamilton drives it, versus

11 your teenage son.

12 And I think when you're dealing with utilities,

13 you are dealing with a lot of different conditions.

14 We had a tough time explaining that under certain

15 conditions - don't go in there. Let it burn. We

16 don't - we don't worry about that, because it's more

17 important to us to keep the power flowing on the grid;

18 to keep those services being provided. We're looking

19 at much bigger pictures. Life safety is important.

20 Respecting tradition, and the reasons for those

21 separations is highly important. We urge your support

22 of this motion on the floor. Thank you.

23 JAMES QUITER: Thank you. Microphone six,

24 please.

25 MIKE GURNEE (phonetic): Thank you. Mike



186

1 Gurnee, speaking on behalf of myself, and I'm opposing

2 the amendment. Working for an AHJ, not having the

3 ability to review and look at the safety features puts

4 our first responders, and potentially the public, at

5 risk. Now, the utility companies do a fantastic job

6 handling power plants, and generation. But these ESS

7 systems are being placed within neighborhoods.

8 They're not a traditional power plant. And when

9 people call the Fire Department, we have a duty to

10 respond, and a duty of care, and we need to be able to

11 make sure that our first responders are safe, and that

12 we can keep an eye on what's going on. It's just part

13 of the check and balance in the system. We don't want

14 to put the grid at risk or anything, but we do have to

15 protect our responding personnel. Thank you.


17 please.

18 PAUL HAYES: Thank you, Mr. Chair. My name is

19 Paul Hayes. I'm in favor of 85-0-1. I am a FPE, Fire

20 Protection Engineer, with American Fire Technologies.

21 I represent my own company. I've got 35 years'

22 experience in special hazards protection.

23 And I'm going to start off by saying that an

24 asset is not worth a life. I think that's very

25 important for us to recognize, no matter what we do,



187

1 and what we say. I have been intimately involved with

2 the code process, which basically means I've been

3 irritating the hell out of the Committee throughout

4 this whole process. So --

5 JAMES QUITER: It'd be better if you were a

6 little closer to the mic.

7 PAUL HAYES: Okay. So I'm an integrator. At

8 the end of the day, I take to take the code and make

9 it work. What is the equipment that's applied, how is

10 it applied, what does it look like. I am an SME for

11 New York City to help them solve this problem. I am

12 on the 95-40A Task Group. But I represent myself.

13 Actually, as Sharon mentioned, one of the best

14 strategies is to let it burn. It does two things.

15 It, it sounds strange, but it removes stranded energy,

16 so we don't have to deal with it, as we've seen in

17 Arizona. And secondly, what burns doesn't explode.

18 So this is not, obviously, a good approach for high

19 hazard areas. I don't believe in that approach for

20 high risk and urban environments. And honestly,

21 between the code right now, I don't believe it goes

22 far enough for adequate protection of life and safety

23 in high hazard environments. I'll address that a

24 little bit later in some further NITMAMs.

25 But I would recommend that this be passed,



188

1 because it allows the opportunity for the, the

2 utilities to operate under IFC. This exemption

3 already exists under the IFC codes, so you're getting

4 into some conflicts on where do you apply the code.

5 Utilities allow for secure, remote facilities -

6 let it burn; do not enter; do not jeopardize first

7 responders, and the public. A life is not worth an

8 asset. So since the Arizona incident, I've seen a

9 real big change in the industry. They have picked up

10 the mantle. They are diagnosing the inherent hazards.

11 They are making sure that safety truly is first.

12 This, this has been a shift in the industry.

13 To be fair, we are learning every single day.

14 There's new insights into this hazard, and what it

15 means. Today, we are vastly superior on what we know,

16 than we knew several months ago, eight months ago when

17 this code was being developed. Keep in mind, energy

18 is not the same as risk. We can fire a shotgun in New

19 York, or West Virginia, and my apologies to New York

20 and West Virginia. But in New York, you run the risk

21 of life and safety. In West Virginia, you're gonna be

22 lucky to hit a squirrel. So energy is not the same

23 thing as risk.

24 We have not found the silver bullet yet, but we

25 are working on it. Allow the utilities to work under



189

1 a hundred years of power operation. Do not jeopardize

2 life and safety. An asset is not worth the risk.

3 Please support this motion. Thank you.


5 please.

6 MATT PACE (phonetic): Thank you, Mr. Chair.

7 My name is Matt Pace. I am a retired Fire Captain

8 from San Jose Fire Department, and I represent the

9 International Association of Firefighters on both the

10 National Electrical Code, and 855.

11 I'm requesting the Committee's vote against

12 this motion. A number of the justifications that we

13 have heard speak about acknowledging the risks of some

14 of these technologies, and letting it burn. The

15 problem right now with 855 - has been acknowledged by

16 a lot of people - is it paints with a very broad

17 brush, all energy storage technologies. We've made

18 some attempts to separate them by technology, without

19 being too prescriptive. But there are many

20 technologies that include that family of energy

21 storage. Lithium ion is just one, and it's a very,

22 very energetic technology.

23 This particular motion, seeking a broad

24 exemption from all energy storage, is just simply too

25 broad to allow the kind of safety that's needed for



190

1 some of these technologies, like some of the lithium

2 ion chemistries. Recently in Arizona there was an

3 explosion at a utility power plant, a substation.

4 There was not enough knowledge in both the personnel

5 that responded, representing the battery, as well as

6 the firefighters that responded. Two firefighters

7 were blown over 70 feet away. They were standing

8 outside. The metal door was bent in two. It's proof

9 that it's a very, very significantly dangerous

10 technology when not managed properly. There's a lot

11 of us - there's a lot that needs to be learned to

12 protect these systems.

13 This week at the conference, we heard some very

14 valuable data from FM Global that shows the difficulty

15 in providing adequate fire protection to lithium ion

16 battery systems. Again, to provide a broad exemption

17 to the utility industry - and no disparagement at all

18 against the utility industry; they manage lead acid,

19 and nicad battery technologies very safely. But to

20 just say because they're managing a lithium ion

21 battery it's going to perform safely, when this

22 installation could be very close, or inside occupied

23 structures - it just goes too far for the technology

24 right now.

25 We request disapproval of this motion. Thank



191

1 you very much.

2 JAMES QUITER: Thank you. I'm going to go to

3 microphone four, but I'll assure you folks in the back

4 that I'm getting to you. Microphone four.

5 TIM MYERS: This is Tim, Tim Myers for

6 Exponent, Incorporated, speaking in favor of the

7 motion. First off, I'd like to thank the Technical

8 Committee for all their hard work on this standard.

9 I've been on an NFPA Committee writing a new standard,

10 and I realize it's, it's a lot of work. You have to

11 deal with a lot of public input, public comment, and,

12 and write the standard. So I appreciate all of your,

13 your effort.

14 I'd like to talk a little bit about the scope.

15 The scope is really one of the most important parts of

16 an NFPA document because it controls who falls under a

17 standard.

18 In the Second Revision, there were 40 public

19 comments addressing the scope. They were all rejected

20 by the Committee. I think as you heard earlier, this

21 standard is intended to be very broad, and to apply to

22 a lot of energy storage systems of different types -

23 from flywheels, compressed air, hydraulic, to

24 batteries. But really, most of the requirements in

25 this standard are geared towards protecting a energy



192

1 storage system with a lot of lithium ion batteries in

2 a very small area.

3 Unfortunately, this, this applies to a lot of

4 different applications. I'll give you one example

5 right here that that makes sense. All of you have one

6 of these iPads. I counted the number of people that

7 voted on the first vote this morning, the example of

8 one. The total energy quantity of the iPads that

9 voted exceeded the threshold quantity for NFPA 855.

10 So maybe this room falls under this standard. Some of

11 you would argue, 'Well, these aren't connected;

12 they're not plugged in.' Well, I would argue that we

13 probably have enough laptops plug in, in these

14 thousand seats here, that they would be considered a

15 mobile and portable ESS installed in a stationary

16 configuration.

17 So I think one of the problems we really need

18 to think about with this standard is what other types

19 of things that it's going to apply to and impact, that

20 really wasn't the intention.

21 There are other standards that cover energy

22 storage - NFPA 1; the IFC. NFPA 1 actually includes a

23 specific exemption that says that you don't have to

24 distribute, or you don't have to aggregate distributed

25 pieces of the equipment in a large room. Thank you.



193


2 please.


4 International, speaking for NAFRA, and in opposition.

5 Just want to point out a couple of things. Number

6 one, the last speaker just was --

7 JAMES QUITER: Are you for, or against?

8 MARCELO HIRSCHLER: Sorry - against the motion.

9 I thought I'd said so. I apologize. Against the

10 motion.

11 The last speaker was just talking about NFPA 1.

12 NFPA 1 as - is very well correlated with 855. So the

13 people who wrote, a lot - a number of the members of

14 the Committee of NFPA 855 are also on the committee,

15 the - that works with the Fire Code Action Committee

16 for the IFC, and the RRC, and that's very well

17 correlated.

18 On the other hand, the NESC does not have

19 details for dealing with ESS. One of the speakers

20 before talked about that we have multiple types of

21 technologies, and yet the only thing we know so far is

22 what has been - what's, what has occurred in the past.

23 The 855 has addition information about emerging

24 technologies, which are not covered by other things.

25 It would be a mistake to exclude all utilities,



194

1 when the details for those emerging technologies, and

2 detail for some of the existing technology, are not

3 covered by NESC yet. Please oppose the motion. Thank

4 you.

5 JAMES QUITER: Thank you. Microphone five,

6 please.

7 MICHAEL BUCKLEY: Hi. My name is Michael

8 Buckley, representing the Edison Electric Institute.

9 I am here in support of this motion. EEI is the

10 representation - is the organization that represents

11 all investor owned electric utilities in the United

12 States. Our members provide electricity for 220

13 million Americans, and our members unanimously agree

14 that electric utilities should not be included under

15 the scope of, of, of this standard.

16 Safety and reliability are of paramount concern

17 to electric utilities. Electric utilities, under the

18 scope of NFPA 855, will lead to conflicts among

19 regulators, and create confusion for AHJs.

20 Including our industry under this standard

21 could be dangerous for first responders. Energy

22 storage systems are not the primary hazard in electric

23 utility operations. So please allow me to emphasize

24 that point again. Energy storage systems are not the

25 primary hazard for electric utilities.



195

1 EEI and our member companies adamantly believe

2 that NFPA should honor the traditional demarcation

3 between NFPA and the NESC. EEI therefore asks for

4 your support of this motion. As the EEI

5 representative here, I will withdraw the other motions

6 we have for NFPA 855, if CAM 855-1 passes. Thank you.


8 please.

9 ROBERT DAVIDSON: Robert Davidson, Davidson

10 Concepts. I am a member of the 855 Technical

11 Committee. I'm also a member of the International

12 Code Council's Fire Code Action Committee, Energy Work

13 Group that did all the work in that code to correlate.

14 But I'm not speaking for those groups. I'm speaking

15 for myself, and against the motion.

16 So they, they want to use this term

17 'exclusively under the control of the utility

18 companies' when today, that does-- that's not the

19 world today. Yes, there's sites they exclusively

20 control. But we have large utility scale

21 installations going in with partnerships. They're

22 going on private property, but they're being managed

23 by the utility company. They're going on private

24 property by somebody else's investor. They're going

25 to be on utility property by private investors, but



196

1 then managed by the utility company. Right. The

2 lines are blurred. They're not all remote. All

3 right? They're in urban, urban environments. Or they

4 may have started out at a remote location, but because

5 of the massive growth in some communities, they

6 quickly are no longer remote. In all cases, the Fire

7 Service has to respond, and deal with the incidents,

8 and the safety of these systems is extremely

9 important.

10 I heard a - I heard testimony that the IFC has,

11 already has its exemption in there. That is not

12 correct. The International Fire Code has an exemption

13 for distribution transmission equipment that matches

14 the 2014 National Electrical Code exemption. When the

15 2017 National Electric Code was updated to include ESS

16 in that exemption, that was not added to the IFC, so

17 that they would still be regulated, and by the 1206

18 Energy Storage Systems.

19 I heard that they're updating the NESC. That's

20 good, because currently the NESC has a page - less

21 than a page and a quarter applying to lead acid

22 batteries. That's it. All right. I also heard one

23 of the proponents mention the Arizona incident. If

24 they were to build that installation today, there's

25 absolutely no guidance in the NESC for that lithium



197

1 ion installation. Think of that. That's what they

2 want us to point to; there's absolutely no guidance.

3 You could build it that way again.

4 I urge your Membership to support the

5 Committee, and vote against the motion.

6 JAMES QUITER: Thank you. Microphone number

7 five, please.

8 DOUG BERKER (phonetic): Doug Berker,

9 (unintelligible). I want to speak in favor - I'm

10 sorry, I'm getting feedback from the microphone. I

11 want to speak in favor of the motion. I think any

12 time that you can clarify definitions by covering

13 what's covered and what's not covered, it only adds to

14 the standard.

15 I would like to reinforce what a previous

16 speaker said - that if you feel that the energy

17 storage system under the control of utilities, should

18 be specified, then we need to develop a separate

19 regulation for it.

20 Final point of order that I wanted to clarify

21 when we first started, is that the motion of what was

22 made, and what was on the screen are in conflict. The

23 maker of the motion was speaking in favor of 454. And

24 the screen says 654. So if we could please clarify

25 which we're voting for. That's all I have.



198

1 JAMES QUITER: Okay. Let us check on that for

2 a moment.


4 JAMES QUITER: Okay. You are correct. It's

5 Public Comment 454. The screen is incorrect.


7 JAMES QUITER: Okay. Microphone three, please.

8 HOWARD HOPPER: Howard Hopper, UL. Just a

9 couple of quick points. There's some testimony

10 provided that the industry has NFPA 850 to rely on.

11 But we discussed that at the Committee. That's a, a

12 recommended practice. It's not enforceable.

13 UNIDENTIFIED SPEAKER: For or against?

14 HOWARD HOPPER: Speaking against the motion.


16 JAMES QUITER: Thank you.

17 HOWARD HOPPER: Yeah. Also, there's discussion

18 about the ESS associated with laptops and, and

19 computers. That's not defined as ESS. ESS is defined

20 as energy storage that provides electric power as an

21 output of it - not just that utilizes that. So that

22 was incorrect - or incorrect testimony.

23 The other thing is, if I had an exemption like

24 this, it's appropriate for the National Electrical

25 Code, because the requirements are very similar - the



199

1 electrical installation either at a utility or a non-

2 utility based installation. But they really, as Mr.

3 Davidson pointed out, there's no ESS protection

4 requirements in that document today. And so if this

5 motion passes, we'll have nothing to protect those

6 installations in jurisdictions that enforce the 855.

7 The - I think the one other thing I saw was I,

8 I heard someone from the electric utilities say that

9 ESS is not really the safety consideration you're

10 going to see at electric utility. I, I was kind of

11 dumbfounded by that, because it, it, it - it really

12 provides a very hazardous exposure to - again, to

13 occupants and emergency responders. And it's

14 especially of concern if you have a utility owned

15 facility in a urban area, possibly a mixed use

16 building. Urge you to vote against the motion. Thank

17 you.

18 JAMES QUITER: Thank you. Just for

19 clarification, the text in the Agenda was correct

20 originally. The screen has now been updated to

21 reference 454 instead of 654. Okay. I'll go to

22 microphone number four, please.

23 ANTHONY NATALE: Good afternoon. Anthony

24 Natale, speaking in support of the motion,

25 representing Consolidated Edison of New York. I'm



200

1 responsible for risk and industrial fire. My

2 expertise is high voltage firefighting. The APS

3 incident --

4 JAMES QUITER: You're speaking --

5 ANTHONY NATALE: -- is not --

6 JAMES QUITER: -- for or against?

7 ANTHONY NATALE: Speaking in support.


9 ANTHONY NATALE: The APS incident is not the

10 norm; it's the anomaly. We manage much greater

11 hazards on a daily basis without incident. In our

12 current ESS system designs, we consider flammable gas

13 accumulation in an enclosed space. We are able to

14 manage this risk without being governed by 855.

15 Managing this risk is nothing new to the utility

16 industry. We manage thousand PSI gas mains in our

17 generating stations on a daily basis, without

18 incident.

19 In the matter of APS, they learned a valuable

20 lesson which has been widely shared in the utility

21 industry to ensure there will be no future

22 reoccurrence.

23 The constraints of 855 will hinder large scale

24 grid projects. For example, to further limit risk,

25 the Committee wants to cap battery size. Folks, the



201

1 smallest breaker in your house is 15 amps. Ours is

2 63,000 amps in stations with open air, 500,000 volt

3 conductors. Based on the hazards found in the utility

4 locations, energy storage systems don't make the top

5 10 list. However, we manage these facilities every

6 day without incident, without safety issues.

7 We are heavily regulated by a number of

8 different groups that impose rigorous inspection,

9 testing, and maintenance programs that come with

10 significant penalty mechanisms.

11 I think 855 will play a valuable role in

12 providing guidance on residential and commercial

13 installations to folks not familiar with energy

14 hazards. This is our job. We do this every day, and

15 we are seeking your support in this exemption. At the

16 end of the day, is there really a value in trying to

17 tell the watchmaker what time it is? Thank you.

18 JAMES QUITER: Okay, thank you. I'm going to

19 stay at microphone number four. There's a lot of

20 people lined up in the four column, so make sure

21 you're presenting new information. Microphone four.

22 ROBERT HARRIS: Yes. My name is Robert Harris.

23 I'm here to represent the National Rural

24 Electrification - Association of Rural Electric Co-

25 Ops, speaking in favor of the motion.



202

1 NRECA is a service organization for

2 approximately 900 electric cooperatives in the United

3 States. We serve power to approximately 42 million

4 people in 47 states, and cover well over half the

5 country's land mass. Some of our cooperatives are in

6 suburban service areas, but this estimated average is

7 about eight customers per mile of distribution line,

8 and we do have some members that are down as low as

9 one customer per mile. So we are in some very rural

10 parts of the country in some cases.

11 Providing safe, reliable, and affordable

12 electricity is the primary mission of America's

13 electric cooperatives. We feel that this motion

14 supports that mission, and ask for your support in

15 favor of the motion. Thank you.


17 please.

18 CHRIS CIONI: Speaking in support of the

19 motion. My name is Chris Cioni with Calpine

20 Corporation. Just wanting to start with an analogy

21 from what was discussed our with the propane, and the

22 differences between NFPA 54 and 56. And that's very

23 much the case here, where the National Electric Safety

24 Code and the NEC, NFPA 70 are the right codes for the

25 right applications, but they're two different



203

1 documents.

2 And to speak to some of the concerns of the

3 firefighters and first responders in this room - we

4 are currently, today, developing a project that's

5 going to begin construction shortly in Southern

6 California, and we're going about this the way

7 utilities go about doing business every day. We're

8 sitting down with the system original equipment

9 manufacturer, and we're sitting down with all of the

10 fire and safety organizations in that area. They want

11 to understand what their people are going to be

12 exposed to. They want to know how to respond. But

13 they point to us as the experts. They want us to

14 teach them what to do to keep their people safe, and

15 that's what we intend to do, and we are doing.

16 Again, this is a facility in a very dense urban

17 area, Southern California. It also happens to be

18 located about a hundred yards from one of their fire

19 stations that houses their HAZMAT team. So these

20 people have a very keen interest in understanding what

21 they're exposed to, and what they're going to be asked

22 to do. And our first thing that we do in every

23 activity is safety - safety for our own people, safety

24 for the public, safety for the first responders. So

25 we are looking at that as our primary mission. We are



204

1 going to sit down together. We will work through all

2 of these issues, their questions. We will take every

3 consideration into account. The OEM is going to be

4 able to respond, in, in terms of making them

5 completely knowledgeable and comfortable with what's

6 out there, what to do, what not to do, when to do it.

7 So again, just to reiterate, there are reasons

8 why the electric utility is operating the most

9 hazardous electrical systems in the country, and the

10 NEC 70 code is typically for lower hazard, more common

11 occupancies. Thank you.

12 JAMES QUITER: Thank you. Microphone four,

13 please.

14 PAUL HAYES: Thank you, Mr. Chair. Paul Hayes,

15 in favor. A point of clarification. I did --

16 JAMES QUITER: Who are you representing?

17 PAUL HAYES: Myself; no other company. Point

18 of clarification. I do have an Amending Motion No. 6,

19 which asks for the scope change under utilizing the

20 IFC. I will withdraw that if this is approved.

21 But I wanted to clarify what's in 2018 IFC. It

22 says it shall not apply to equipment associated with

23 the generation, control, transformation, transmission,

24 or distribution of the energy installation that is

25 under the exclusive control of an electric utility, or



205

1 lawfully designated agency. That is already existing

2 in 2018; I took that language directly from. So

3 there, there is a precedent for the IFC to reflect

4 these separation. Thank you.

5 JAMES QUITER: Thank you. Again, to microphone

6 four.

7 JAMES HOUSTON: This is James Houston, with

8 Southern Company. Yeah, I'm making a, a comment for

9 the motion. Yeah, it - we're getting down to - it

10 looks like we're trying to out-code one another. You

11 know, we - you know, who - 'My dad can beat your dad

12 up.' 'My code is better than your code,' kind of

13 situation. But I can't emphasize, you know, the

14 dangers associated with the - working in the electric

15 industry. And we understand it, I think better than

16 most. And our code is not going to go into effect for

17 the National Electric Safety Code revisions that

18 include ESS, until 2022. But I will extend my hand to

19 NFPA members to participate in that code revision.

20 And also, there's going to be opportunities, if we

21 choose to, to issue Tentative Interim Agreements. And

22 I could - in the interest of public safety, I could

23 see that happening. Thank you.


25 please.



206


2 Concepts, speaking for myself. So two items. One,

3 one, one of those issues comes down to how they're

4 regulated - how they're regulated. How they're

5 regulated is determined by the state, county, local -

6 the authority having jurisdiction; the commissions

7 they set up; the public - water public utilities they

8 set up. And they decide what the utilities have to

9 comply with.

10 JAMES QUITER: Just to clarify - for or

11 against?

12 ROBERT DAVIDSON: Against - sorry. They decide

13 that. Why would we put a blanket exemption in there,

14 when the AHJ may decide that, guess what, you need

15 building fire permits for this, for this installation.

16 And then we go and we look for the standard, and well,

17 the standard says it doesn't apply. And we had a full

18 discussion of that at the Committee over and over,

19 that depending on the jurisdiction you're in, the

20 states you're in, is how - the rules were different.

21 In some, they didn't have to comply with any of the

22 Building Fire Code requirements. In others, they did.

23 Right? The jurisdiction I was in for 22 years - fixed

24 facilities, which would include ESS, would - was

25 required to comply to Building Fire Code.



207

1 Now, I heard a lot of testimony about

2 California. I was recently involved in a number of

3 projects out there. And those regulations actually

4 say they need the appropriate permits from the local

5 building and fire departments - under their building

6 and fire codes. All right? So that decision about

7 how it's going to apply, when, will be made by the

8 jurisdictions, based on the body of codes that they've

9 grabbed hold of to apply in their special cases.

10 That's a routine occurrence. All right?

11 It's not that we ignored the industry in the

12 work. We created dedicated use buildings based on

13 the, their input. We created remote use buildings

14 based on their input. And we put a bunch of

15 exemptions in there for the legacy lead acid storage

16 buildings, based on their input. So this went on from

17 - from beginning to end. So it wasn't that we're just

18 ignoring and saying, 'You're captured by this.'

19 And the last thing is, the gentleman who read

20 the language of the 2018 IFC, I'm glad he read it,

21 because those of you familiar with the NEC recognize

22 what he read is what was in the 2014 NEC. The

23 industry added energy storage systems to the 2017 NEC.

24 We did not pick that up and add that to the

25 International Fire Code, because we wanted ESS to be



208

1 captured. Thank you.


3 please.

4 FRED HARTWELL: Thank you, Mr. Chairman. Fred

5 Hartwell, speaking for myself. I'm --

6 JAMES QUITER: For or --

7 FRED HARTWELL: Well, I'm in a bit of a --

8 JAMES QUITER: For or against?

9 FRED HARTWELL: -- unique --

10 JAMES QUITER: For or against the motion?

11 FRED HARTWELL: I'm in - speaking in favor of

12 the motion. I have a bit of a unique take on this,

13 from an electrical background, and 30 years on the

14 National Electrical Code Committee, and 35 years on

15 the Massachusetts Code Committee, most of that time as

16 the Secretary of that Committee. And what keeps me

17 awake at night from time to time is when proposals are

18 generated from whatever source, for whatever reason,

19 that I think will attract the attention of the

20 Legislature, or of the legal community, and interfere

21 with the orderly adoption and promulgation of the

22 National Electrical Code in my state. I think a lot

23 about this.

24 There's an old proverb that 'fences make good

25 neighbors' and I think it applies here. I think that



209

1 without this, I think we very much could impede the

2 orderly adoption of this standard. We will certainly

3 attract the attention of the investor owned utilities,

4 who have the resources to resist this. And I think we

5 have to just be very careful about invading the scope

6 of the National Electrical Safety Code on this. I, I

7 don't know where this ends, but I think there's a real

8 issue here very likely in terms of the adoptability of

9 this standard, without this provision. Thank you.

10 JAMES QUITER: Thank you. Microphone two,

11 please.

12 THOMAS BRIDER (phonetic). Hopefully I do this

13 right. Thomas Brider, International Association of

14 Firefighters. I'd like to call the question.

15 UNIDENTIFIED SPEAKER: Yay.

16 (applause)

17 JAMES QUITER: There is a motion from the floor

18 to call the question. I notice that there are a

19 number of people remaining at the microphones waiting

20 to speak, but we'll proceed with the vote on the call

21 of the question. Do we have a second?

22 UNIDENTIFIED SPEAKERS: Second.

23 JAMES QUITER: We do have a second. In order

24 to vote on this motion, please scroll down to the

25 bottom of the tablet to vote. If you wish to vote in



210

1 support of the motion, touch 'Yes'. If you wish to

2 vote against the motion, touch 'No'. Please record

3 your vote.

4 UNIDENTIFIED SPEAKER: It's not working.

5 UNIDENTIFIED SPEAKER: It's frozen.

6 UNIDENTIFIED SPEAKER: It's frozen.

7 UNIDENTIFIED SPEAKER: Clear to the bottom - to

8 call the question.

9 JAMES QUITER: Okay. I'm hearing a 'frozen' -

10 are there several?


12 UNIDENTIFIED SPEAKER: That's not the motion.

13 Call the --

14 UNIDENTIFIED SPEAKER: Call the question

15 (unintelligible).



18 JAMES QUITER: This is a - this is a call the

19 question motion. So you should not be voting on this

20 specific item. You should be scrolling down to the

21 bottom to find the 'call the question' vote.


23 JAMES QUITER: Okay. We'll give you five more

24 seconds.




211

1 (laughter)

2 JAMES QUITER: Okay, voting is closed.


4 (laughter)

5 (applause)

6 JAMES QUITER: The results of the vote are:

7 548 in support; and 87 against. The motion has

8 passed.

9 UNIDENTIFIED SPEAKER: (unintelligible) call

10 the question.

11 JAMES QUITER: Yes, the - yes, it had - the

12 motion was to call the question. That motion has

13 passed. That means we will proceed to the vote on the

14 main motion.

15 The motion on the floor is to Accept Public

16 Comment Nos. 912 and 454. To vote, touch the 'vote'



19 you wish to vote against the motion and recommend the


21 vote.

22 Five seconds.



25 the motion --



212

1 (applause) -

2 JAMES QUITER: -- recommending the text on

3 Screen One; and 280 oppose the motion, and recommend

4 this text on Screen Two. The motion has passed.


6 Certified Amending Motion 855-2. Microphone one,

7 please.

8 CHRIS SEARLES: Yes. Chris Searles, BAE

9 Batteries, USA; past Chair of the IEEE Energy Storage

10 and Stationary Battery Committee; and member of the

11 ESSB Safety Codes Working Group. And I would like to

12 move forward and make a motion to Adopt or Accept the

13 Identifiable Part - Identifiable Part, I'm sorry - of

14 Public Comment 410.

15 JAMES QUITER: Thank you. There's a motion on






21 CHRIS SEARLES: The IEEE Energy Storage and --

22 JAMES QUITER: Go ahead and introduce yourself

23 again - your - your --

24 CHRIS SEARLES: Chris Searles, BAE Batteries.

25 JAMES QUITER: And for or against?



213

1 CHRIS SEARLES: I am for the motion.


3 CHRIS SEARLES: The IEEE Energy Storage and

4 Stationary Battery Committee and the Safety Codes

5 Working Group represent the stationary battery

6 industry with the development and publication of over

7 27 industry standards. We propose that the scope as

8 outlined in Section 1.1 be changed to add the words,

9 'This scope includes - excludes' - I'm sorry - '...lead

10 acid and nickel cadmium batteries used in stationary,

11 standby power applications in the commercial and

12 industrial sector.'

13 Our reasoning is four-fold. First, we

14 understood the original intent of NFPA 855 was to

15 address safety issues with newer, emerging

16 technologies not previously used in a stationary

17 environment, especially lithium ion. Traditional lead

18 acid and nickel cadmium batteries have been included,

19 even though they are governed by other excellent codes

20 and standards.

21 Second, stationary lead acid batteries have

22 been in existence for over 100 years, with significant

23 improvements in their safety. IEEE Standards, NFPA 1,

24 IFC 2018, and other agency codes currently provide

25 updated safety guidelines for lead acid and nickel



214

1 cadmium batteries when used in traditional, standby

2 power applications.

3 Third, there are over 750,000

4 telecommunications, electric utility, and

5 uninterruptible power system sites installed in the

6 United States alone that have been operating safely

7 with lead acid and nickel cadmium batteries for

8 decades.

9 Finally, placing lead acid and nickel cadmium

10 batteries for standby applications in the same boat

11 with those of emerging technologies would be like

12 grounding all propeller aircraft when safety concerns

13 were identified with the 737 Max. There is some risk

14 associated with propeller aircraft, and sometimes an

15 accident occurs. But lumping them in with similar

16 requirements imposed upon newer, emerging passenger

17 jet technologies would be considered out of place.

18 At several of the sessions this week, efforts

19 were made to justify placing lead acid and nickel

20 cadmium batteries under 855, while admitting the

21 standard was developed in reasonable haste, and many

22 requirements were not backed up by actual experience

23 or data.

24 I would respectfully encourage the Membership

25 to carefully and realistically consider the proposed



215

1 amendment, and vote in favor of adopting it. It

2 directs the standard to the real problem at hand,

3 which is emerging energy storage technologies,

4 especially lithium ion. Thank you.

5 JAMES QUITER: Thank you. Mr. Biggins, would


7 JAMES BIGGINS: Yes. First, Chris, I was in

8 most of those sessions, and I don't remember any of

9 those things that you said about, you know, being

10 directed at that - it's hastily crafted and all this.

11 The development of 855 was began in 2016, when

12 the Standards Council approved a request by NFPA - for

13 NFPA to develop a standard on stationary energy

14 storage systems. The Tech Committee worked diligently

15 to craft a standard that was built upon the

16 information both currently in NFPA 1 and NFPA 70, as

17 well as other standards, to develop a comprehensive

18 document to fill those gaps.

19 With respect to this motion, the Technical

20 Committee strongly believes that no energy storage

21 system, including lead acid and nickel cadmium

22 batteries installations should be exempt from the

23 requirements of 855 that directly affect the safety of

24 the public or first responders.

25 What the Technical Committee did to address the



216

1 concerns of the submitter was to provide exemptions in

2 Chapter Four of NFPA 855 for these systems installed

3 as UPS systems, switch gear and generating plant

4 control batteries for utilities, and as backup power

5 supplies for the telecom industry. This was done for

6 requirements pertaining to listing of the

7 installations to UL 95-40; revision of energy storage

8 management systems; identification of disconnecting

9 means; limitations of below grade or above grade

10 installations and structures; size and separation

11 requirements; fire protection system requirements; and

12 fire protection water supply requirements.

13 You know, the Committee was very diligent in

14 making sure that when these issues were brought to our

15 attention, that we did not do anything that would

16 require additional and potentially difficult

17 requirements on these systems. We do recognize they

18 are - have operated well for a number of years, but

19 they still do, do present a hazard, and 855 attempts

20 to address these issues.

21 JAMES QUITER: Thank you, gentlemen. We have a

22 side discussion going on here. Give us a moment. All

23 right. With that, we will open up debate on the

24 motion. Please provide your name and affiliation, and

25 whether you are speaking in favor, or against the



217

1 motion. Microphone one, please.

2 WILLIAM CANTOR: Thank you, Mr. Chair. My name

3 is William Cantor. I work for TPI, but I'm

4 representing the IEEE Energy Storage and Stationary

5 Battery Committee. I'm in support of the motion.

6 As was mentioned, there's approximately 750,000

7 lead acid and nicad sites, energy storage sites,

8 throughout the United States, that have been operating

9 for years under the current requirements in documents

10 such as the National Electric Code, and the Fire

11 Codes. The current scope would include the vast

12 majority of these sites. In fact, these type of sites

13 would be the majority of sites covered by this

14 document.

15 The current scope would, would add additional,

16 unneeded requirements, potentially tens of millions of

17 dollars' worth of cost, especially to the lead acid

18 industry. As the Chair mentioned, there - we did get

19 some exemptions in there, but they don't cover all the

20 requirements. And you know, doing some calculations,

21 we think there's probably about 100,000 sites that

22 still won't be exempt with those narrow exemptions.

23 And then there's a number of requirements that will

24 apply to all these sites that have no exemptions. And

25 that's a big concern for the industry - just for the



218

1 cost, with no reason that we think that are needed,

2 because these sites, as, as mentioned, have been

3 operating for a long time under current regulations.

4 Thank you.


6 please.

7 JUSTIN PERRY: Justin Perry, from Dominion

8 Energy, speaking for the motion. I think the Chair

9 summed it up very well when he discussed that lead

10 acid and nicad batteries have been operating well for

11 a number of years. There are legacy requirements in

12 both NFPA 1, and the IFC, that cover lead acid and

13 nicad batteries. And I would recommend that we revert

14 back to those regulations instead of NFPA 855, and

15 urge you to support this motion. Thank you.


17 please.

18 HOWARD HOPPER: Howard Hopper, UL, speaking

19 against the motion on the floor. As Mr. Biggins

20 pointed out, this Committee has debated this

21 extensively, and we did specifically address lead acid

22 batteries at electric utility installations, at UPS,

23 and at telecom facilities. And so we all - we have a

24 number of requirements that specifically address lead

25 acid throughout the code. They're under requirements



219

1 for the installations, the technology specific

2 requirements, and a variety of different locations.

3 If you - if this motion is successful, you're

4 going to have lead acid excluded from the scope of the

5 standard, and yet you're going to have dozens of

6 references to lead acid throughout the, throughout the

7 code. So it's being done incorrectly. If what

8 they're trying to accomplish is to get those out, it's

9 being done incorrectly, and you're going to have

10 requirements that kind of make - break the code a

11 little bit there.

12 Every - the other concern we've had is that

13 historically, lead acid batteries have been used in

14 standby power, emergency power, and UPS applications,

15 okay. They - we, we know those applications. There's

16 a very acceptable level of safety for those. But now

17 they're starting to be used in energy storage system

18 applications, where now you're, you know, they have

19 different cycling, different periods of how they're

20 used. And the requirements in 855 and the

21 International Fire Code specifically address those new

22 uses of the - of, of these battery technologies.

23 Also, when you're talking about existing

24 installations, there's requirements. I mean, codes

25 apply as, as appropriate, as adopted to either new



220

1 installations, or existing installations. So I don't

2 think we're, you know, causing an undue burden and

3 hardship on this. So speaking against the motion on

4 the floor. Thank you.


6 please.

7 TIM MYERS: Tim Myers from Exponent, speaking

8 for the motion. I just wanted to reply to a comment

9 the Chair made about whether or not this was, this was

10 - standard was developed hastily. I - again, as I

11 stated earlier, I certainly appreciate all of the hard

12 work the Committee did. And, and they had a tall task

13 in front of them. But I just wanted to give you a few

14 statistics, or a few points to, to look at the

15 development of this standard.

16 I mentioned earlier, though, that this Scope

17 Statement received 40 public comments - four, zero.

18 All of those were rejected by the Committee. You can

19 look at the Second Draft Report, or the Public Comment

20 Report, and you'll see that a lot of those comments

21 were lumped together, and the Committee statements

22 about why they were rejected really have no relation

23 to the, the, the public comments.

24 Looking more generally at the, at this standard

25 - it received 534 public inputs; 875 public comments -



221

1 which doesn't show you that we're, we're converging on

2 consensus on this standard. Of, of those 875 public

3 comments, 844 were rejected. If you look at how many

4 revisions were made in the First Draft, it was 144;

5 166 in the Second. If you look - if you compare the

6 schedule of meetings for this committee, relative to

7 the published schedule for the committee, a number of

8 the meetings, particularly in the Second Draft, were

9 held after the deadline for having Second Draft

10 meetings. So you know, I think in a lot of cases, the

11 committee just didn't have the time to adequately

12 address a lot of the public input and public comments.

13 I'd welcome any of you to look at the Second Draft

14 Report, and I think you'll see that in many cases the

15 Committee statements don't really address the public

16 comments. Thank you.


18 please. And I would like to keep comments related to

19 this particular item, rather than the overall process.

20 Microphone --

21 JOHN ALLEGER (phonetic): Sure.

22 JAMES QUITER: -- five.

23 JOHN ALLEGER: That's John Alleger. I'm the

24 Battery and Fire Protection SME for Pico Energy. I'm

25 speaking for the motion.



222

1 So this came up as a situation to try to fix

2 the difference between energy storage systems, and

3 standby systems that the utilities use - two very

4 different systems, two very different purposes. In

5 the current document it refers to control of the

6 substations. It actually should be protection and

7 control, but it only had control. It would have been

8 nice for the code folks to have more folks having

9 utility background on the Committee - it would have

10 helped.

11 Now, this situation, you either - you were

12 given three options. You fix the scope; you add all

13 sorts of exclusions throughout the document; or you

14 change Table 1.3 under lead acid. Instead of 70 kw

15 hours, make it a hundred, make it 120 kw hours. If

16 you wanted a note saying that that was strictly for

17 standby, and not for ESS applications, none of this

18 would have been an issue. That was rejected by the

19 Committee as a recommendation I have made. It would

20 have been so much easier.

21 So to answer the gentleman with the hat - why

22 are we looking for exclusions, general exclusions?

23 Because of the possibility that standard lead acid

24 batteries, slightly larger than what's represented in

25 Table 1.3 would be requiring fire testing, and also -



223

1 yes, the gentleman from the - ha-- - there he is. All

2 sorts of requirements and, and costs required, because

3 a number wouldn't be changed in Table 1.3.

4 JAMES QUITER: Thank you. Microphone two, the

5 gentleman with the hat.

6 (laughter)

7 (applause)


9 Concepts, speaking against, for myself. So speaking

10 to there was just not enough time to do this, kind of

11 ignores the fact that a lot of baseline work had

12 already done and, and was pulled into the - during the

13 First Draft and the Second Draft, because in that

14 other code organization, there was a, a group of 40 to

15 50 people that wrote a bunch of requirements that went

16 into the 2018 International Fire Code, and went into

17 the 2018 NFPA 1. So we already had two fire documents

18 that already had extensive coverage of this topic.

19 And that's - and so that was helped, along with the

20 draft. So that work started in 2015. And many of the

21 people in part of that work ended up on 855, and

22 continue with that work, and more people got involved.

23 So to say it was all rushed and everything, and

24 just not enough time - no, there's a longer history

25 here, and there was a built up set of requirements



224

1 already in two fire codes, that were built upon. All

2 right. And many of the comments that, the changes

3 that came in, were responded to, and we did make those

4 changes. We responded to the industry for that.

5 Where is this threshold issue came up that was

6 just addressed to me - came out of the fire codes

7 already. That threshold already existed. How did the

8 threshold came up - they looked at the threshold in

9 the, in the fire codes - it's previously 50 gallons

10 for lead acid batteries. And they looked at that, and

11 what was the equivalent energy amount. That's what,

12 that's where that came from. All right? So I'm not

13 going to dispute the gentleman, as far as he'd rather

14 see it go up to a higher level, but there was a basis

15 on, in it, and that is already in both fire codes as

16 the threshold. And one of the things we attempted to

17 do with 855 is not write a document that was less, had

18 less coverage than both fire codes are already

19 requiring at this time. I urge you to vote against

20 the motion.


22 one.

23 CHRIS SEARLES: Chris Searles, BAE Batteries,

24 and the Energy Storage Safety Codes Working Group,

25 voting - or recommend voting in favor of the motion.



225

1 It's important that the distinction be

2 clarified, that we're not saying that lead acid

3 batteries just totally be exempted cart blanche

4 through the whole standard. What we are saying, or

5 asking, is that the lead acid and nickel cadmium

6 batteries be exempted in the scope for standby, the

7 traditional standby power applications, which have

8 been addressed, which cover the almost one million

9 installations that exist across the country.

10 And the impacts within the standard, there are

11 unique things within the standard that are very good,

12 and will apply to the new, emerging technologies, and

13 perhaps even the so called, quote, unquote, "advanced

14 lead acid batteries". But all the document has

15 certain issues within it that really impact, very

16 negatively in our opinion, the existing standby

17 application market.


19 discussion on Motion 855-2 to Accept an Identifiable

20 Part of Public Comment No. 410? Seeing none, Mr.

21 Chair, do you have any further comment?

22 JAMES BIGGINS: Yes, I do. First of all, with

23 respect to Mr. Searles' comments, the standard is not

24 retroactive. So it will not impact existing

25 recommend-- existing facilities. With respect to Mr.



226

1 Myers' comment about the 534 first public - 534 public

2 inputs, and 875 public comments, and that we somehow

3 out of pocket rejected all of them - the Committee

4 created 144 First Revisions to the draft, based upon

5 the public inputs. The Committee further created 166

6 Second Revisions to the document, based upon the

7 public comments. Everything was reviewed. Everything

8 was considered. The Committee had an - probably an

9 unprecedented amount of guests allowed to come in, and

10 speak, and make - and be able to present their views,

11 including the submitter of this comment.

12 But after all that, the Committee did look at

13 what was presented, as far as the scope, and

14 determined that the scope as written and presented

15 right now for adoption is what is proper. And we ask

16 that the, this motion be rejected.

17 JAMES QUITER: Thank you, Mr. Chair. Before we



20 Comment No. 410. To vote, touch the 'vote' button.

21 If you wish to vote in support of the motion, and

22 recommend the text on Screen One, touch 'Yes'. If you

23 wish to vote against the motion, and recommend the


25 vote.



227






6 Two. Therefore, the motion has failed.



9 please.

10 MICHAEL BUCKLEY: My name Is Michael Buckley,

11 representing EEI. I withdraw this motion.

12 JAMES QUITER: Thank you. Motion 855-3

13 appeared in our Agenda. However, the authorized maker

14 of the motion, or the designated representative has

15 just notified NFPA that he no longer wishes to pursue

16 this motion. Therefore, in accordance with NFPA

17 Rules, Convention Rules at Section 2.7, the motion may

18 not be considered by the assembly, and is removed from

19 the Agenda.

20 We will now move on to the next motion, which

21 is 855-4. So we'll proceed with the discussion on


23 please.

24 MICHAEL BUCKLEY: Michael Buckley with EEI.

25 Withdraw this motion, as well.



228

1 JAMES QUITER: Bear with me. I lost it. I

2 have it. Okay, bear with me. We - for the sake of

3 the record, we need to get things on the record

4 properly.

5 Next motion, 855-4, F-4, appeared in our

6 Agenda. However, the authorized maker of the motion,

7 or the designated representative just notified NFPA

8 that he no longer wishes to pursue this motion.

9 Therefore, in accordance with NFPA Rules, Convention

10 Rules at Section 2.7, the motion may not be considered

11 by the assembly, and is removed from the Agenda.

12 We will move - now move on to the next motion.

13 Let's proceed with the discussion on Certified

14 Amending Motion No. 855-5. Microphone four, please.

15 JAMES HOUSTON: Yes, my name's James Houston.

16 I'm with Southern Company, and maker of this motion,

17 and I withdraw it.


19 appeared in our Agenda. However, the authorized maker


21 just notified NFPA that he no longer wishes to pursue

22 this motion. Therefore, in accordance with NFPA



25 the Agenda.



229

1 We will now move on to the next motion. Let's

2 proceed with the discussion on Certified Amending

3 Motion 855-6. Looks like also microphone four.

4 PAUL HAYES: Thank you. My name is Paul Hayes.

5 I'm with American Fire Technologies, representing

6 myself, and I remove this motion.


8 appeared on our Agenda. However, the authorized maker


10 notified NFPA that he no longer wishes to pursue this

11 motion. Therefore, in accordance with the NFPA Rules,

12 Convention Rules at Section 2.7, the motion may not be

13 considered by the assembly, and is removed from the

14 Agenda.

15 We will now move on to the next motion.

16 UNIDENTIFIED SPEAKER: Fifteen minute break.

17 JAMES QUITER: Okay. We are now going to take

18 a 15 minute break before we finish up 855. My watch

19 shows 1:25, so base it on 1:40. Thank you.


21 UNIDENTIFIED SPEAKER: Very well.

22 (MUSIC)

23 (END OF PART TWO)

24

25



230

1

2


4


6


8

9 PART 3

10

11

12 (MUSIC)

13 UNIDENTIFIED SPEAKER: Ladies and gentlemen,

14 please take your seats. The session is about to

15 resume. Thank you.


17 JAMES QUITER: Let's just go.

18 UNIDENTIFIED SPEAKER: (unintelligible) will

19 you please take your seats.

20 JAMES QUITER: Yeah.

21 UNIDENTIFIED SPEAKER: We're, we're about to

22 call the next motion.

23 JAMES QUITER: Please take your seats. I will

24 be starting in 30 seconds.




231

1 JAMES QUITER: Let's now proceed with the

2 discussion on the Certified Amending Motion 855-7.


4 TIM MYERS: I am Tim Myers of Exponent,

5 Incorporated. I move to Accept Public Comment No.

6 138.


8 the floor to Accept Public Comment No. 138. Is there

9 a second?




13 TIM MYERS: I'm speaking in favor of the

14 motion.

15 JAMES QUITER: And please identify yourself

16 again.

17 TIM MYERS: Tim Myers of Exponent,

18 Incorporated. The public comment I submitted adds a

19 description of the hazards mitigated by NFPA 855, to

20 the Purpose Statement, namely electrical, fire, and

21 explosion hazards. Those are the hazards that this

22 standard currently addresses. Without this change,

23 the standard just says hazards, which includes many

24 hazards not addressed by this standard.

25 Given the wide variety of technologies that



232

1 fall under the broad scope of the standard, it is

2 critical to spell out the types of hazards the

3 standard addresses so that users don't have a false

4 sense of security that other hazards are addressed.

5 For instance, the standard does not address

6 environmental or mechanical hazards posed by energy

7 storage systems. The standard covers flywheels, which

8 has significant mechanical hazards, but there's -

9 there's really no requirements related to that.

10 I also want to raise a procedural issue.

11 Section 448 of the Regulations Governing the

12 Development of NFPA Standards requires that the

13 Technical Committee consider, act, and comment on each

14 public comment during the Second Draft phase. In the

15 Committee's statement in the Second Draft Report,

16 there is no indication that this portion of my public

17 comment was considered; nor did the TC provide any

18 rationale why this portion of the public comment was

19 rejected. The Committee lumped my public comment into

20 a group of five public comments that were all rejected

21 with the same Committee statement.

22 My public comment was different than the other

23 comments with which it was lumped. My public comment

24 was the only comment to add electrical, fire, and

25 explosion hazards to the Purpose Statement. The



233

1 Committee statement justifying the rejection of my

2 comment had nothing to do with my proposed hazard

3 language. It said, 'The term 'mitigating' is more

4 appropriate here, because the term 'minimize' is

5 already used earlier in the sentence. This is mostly

6 a grammatical change.' I, I welcome someone to

7 explain how that addresses adding electrical fire and

8 explosion.

9 I'm interested to hear what the reasoning is

10 that's given for not adding these words today. But as

11 I've described earlier, it's very clear that there are

12 many hazards that the standard does not address for

13 the wide variety of energy storage systems it covers.

14 And there are many hazards that are outside the

15 Technical Committee's scope, as defined by the

16 Standards Council. I urge you to accept this motion

17 that adds a description of the electrical, fire, and

18 explosion hazards mitigated by this standard. Thank

19 you.



22 JAMES BIGGINS: Yes, I would. The purpose of

23 NFPA 855 is to provide the minimum requirements for,

24 for mitigating hazards associated with energy storage

25 systems, irregardless of what the hazard may be, or



234

1 what particular energy storage technology is used.

2 Limiting the hazards sole, solely to electrical, fire,

3 and explosion hazards is too restrictive, and

4 overlooks other hazards associated with energy storage

5 systems, such as flow - the, the chemical hazards

6 associated with flow batteries.

7 Please note that the Committee made a conscious

8 decision not to address all energy storage systems in

9 this initial edition of the document. It would have

10 been far, far too much an overwhelming task. The

11 Committee made a very informed decision to focus on

12 the areas for which we wrote requirements, being

13 electrical - you know, battery systems, capacitors,

14 and fuel cells. The other chapters are there; they're

15 reserved, and they will be added to, once the

16 Committee, you know, re-enters the standards cycle.

17 Again, we did feel that, you know, limiting it

18 to just these three hazards is too restrictive, and

19 for that reason, the Committee did not decide to make

20 the change as proposed in your public comment.

21 JAMES QUITER: Thank you, Mr. Biggins. With




25 Microphone two.



235

1 MATT PACE: Thank you, Mr. Chair. My name is

2 Matt Pace, speaking for the International Association

3 of Firefighters, and against the motion. As we just

4 heard from the Chair, the scope of this initial draft

5 - this is the first publication of 855 - it's a

6 difficult balance to address a emerging technology,

7 and be prescriptive - or be - to provide code that is

8 not too prescriptive.

9 There's a lot of technology that's changing on

10 a, on a continual basis. One perfect example that

11 would just blow this proposal out of the water would

12 be flow batteries. Flow batteries do - they, the

13 biggest - one of the biggest hazards of flow batteries

14 is a spillage of a caustic electrolyte. So some could

15 interpret that in saying that this scope would not be

16 addressing that whole technology.

17 So the intention, I think is fine by Mr. Myers.

18 But I think that narrowing it down does not serve us,

19 or the community we're trying to provide guidance to.

20 I urge everyone to vote against this motion. Thank

21 you.


23 four.

24 TIM MYERS: So I think one of the key issues

25 here - and one of the key issues with the standard, is



236

1 its scope really does cover a wide variety of energy

2 storage systems, but the requirements that are

3 currently in it are really limited to very specific

4 technologies in the electrical, fire, and explosion

5 hazards.

6 JAMES QUITER: Sorry. We missed identifying

7 yourself and your, and your position.

8 TIM MYERS: I'm sorry. I'm Tim Myers from

9 Exponent, and I'm speaking in front - or - in favor of

10 the motion. And so like I said, there's a disconnect

11 in that the scope includes a lot of different

12 technologies, but the requirements are really very

13 specific to a limited number of technologies, and

14 covering the electrical, and fire, and explosion

15 hazards.

16 I think what I'm asking here is something very

17 simple to just provide an accurate description of the

18 hazards that are actually covered by the standard, so

19 that people don't have a false sense of security.

20 Electric - you know, flywheels are still covered by

21 this standard. The chapter that's specific of them

22 has absolutely no requirements. You would have to

23 comply with general requirements in the standard, that

24 really aren't that well related to flywheels, but, but

25 they're part of the standard. As the standard



237

1 progresses and they include additional requirements,

2 and address additional kind of hazards, this Purpose

3 Statement could be expanded to provide an accurate

4 description of what's currently in the standard.

5 Again, I'd, I'd request that you vote in favor of the

6 motion.

7 JAMES QUITER: Thank you. Microphone three.


9 against the motion. As a Committee member, but I'm

10 not speaking on behalf of the Committee, I recall

11 discussing this with the other comments. And the one

12 - the, the discussion I recall is, among other things,

13 we talked about hazardous materials, and we talked

14 about toxics. If I might read Section 4.4.1 there,

15 ESS cannot release toxic, or highly toxic gasses above

16 PEL levels during normal charging, discharging, and

17 operation. Toxic gas is not captured by electric,

18 fire, or explosion, and yet that is within the scope.

19 So if we wish to put a laundry list in the

20 Purpose Statement, we need to make sure it reflects

21 all the items that are addressed in the standard.

22 Thank you.


24 six.

25 MARCELO HERSCHEL: Marcelo Herschel, GBH



238

1 International, speaking for NAFRA, and in opposition

2 to the motion. I'm very concerned about this, this

3 type of limitation in the scope or purpose, because

4 standards - we start in certain direction; things

5 start moving; things start changing as we expand, as

6 we understand more and more. And when we then have to

7 change the scope of a standard because new

8 technologies, new information has come around, that

9 causes a lot of havoc, and we get a lot of opposition.

10 'Oh, no, you don't want to change the scope of the

11 standard. The - your, your standard was specifically

12 to address this, that, and the other.'

13 You just heard from Howard Hopper that the

14 standard addresses things like toxics; that is not in

15 there. You, you heard from one of the other speakers,

16 the standard addresses spillage, which is not on

17 there. So this is extremely limiting, and will

18 prevent the expansion of, and further development of

19 the standard. Please vote against the motion. Thank

20 you.

21 JAMES QUITER: Thank you. Microphone two.

22 Sorry, microphone four.

23 TIM MYERS: Again, this, this is not the scope

24 statement --

25 JAMES QUITER: Wait - again, with your name



239

1 first.

2 TIM MYERS: Oh, sorry. Tim Myers from

3 Exponent, speaking in favor of the motion. This is

4 not the scope statement. This is the Purpose

5 Statement, so some of the comments that were just made

6 aren't really accurate.

7 With every fire, toxicity, you're going to have

8 toxic problems. That's always a hazard - that, that's

9 covered with fire. And you know, again, I, I still

10 haven't heard an explanation of why a public comment,

11 or, or why the Technical Committee didn't provide a

12 comment on my public comment that actually addressed

13 the issues that I brought up. Thank you.

14 JAMES QUITER: Thank you. Is there any other


16 Comment No. 138? Seeing none, Mr. Chairman, would you

17 like to say something?

18 JAMES BIGGINS: Well, yes, I'd like, like to

19 apologize to Mr. Myers if we didn't, you know, explain

20 our reasoning in rejecting the public comment. But

21 with respect to this motion, you know, adding these

22 three terms - electrical, fire, and explosion - would

23 be too limited, and I urge it's rejected. Thank you.

24 JAMES QUITER: And it looks like I missed

25 somebody at microphone three.



240

1 JACK LYONS: Just a - sorry, just a point of

2 order. Just a point of order. Jack Lyons from NEMA.

3 Should both of those say 1.2?

4 JAMES BIGGINS: Yes.

5 (laughter)


7 UNIDENTIFIED SPEAKER: Thanks.

8 (unintelligible)

9 JAMES QUITER: Okay. Thank you, Mr. Chair.


11 on the floor is to Accept Public Comment No. 138. To



14 Screen One, vote 'Yes'. If you wish to vote against

15 the motion, and recommend the text on Screen Two, vote


17 Five seconds.


19 The results of the vote are: 109 in favor, and

20 recommend the text on Screen One; 399 against the

21 motion, and recommend the text on Screen Two.

22 Therefore, the motion has failed.



25 please.



241

1 TIM MYERS: I am Tim Myers of Exponent. I move

2 to Reject an Identifiable Part of Second Revision No.

3 75.





8 JAMES QUITER: I hear a second. Please proceed

9 with a discussion on the motion. And again, start

10 with your name, affiliation, etc.

11 TIM MYERS: Again, I am Tim - Tim Myers of

12 Exponent, and I'm speaking in favor of the motion. I

13 am one of four individuals who each independently made

14 this same motion. I would explain - like to - I would

15 like to explain one of the reasons I have made this

16 motion, and I hope the other submitters will also be

17 given time to explain their reasoning.

18 If you accept this motion, it will return the

19 maximum energy storage system group size to 250

20 kilowatt hours, the value that was contained in the

21 First Revision of NFPA 855. During the Second

22 Revision, the value was reduced by a factor of five,

23 from 250 to 50 kilowatt hours. By my count, that

24 revision passed by a single vote on the ballot.

25 There was no indication in the First Draft



242

1 Report that such a significant change was being

2 considered, and the public has not had the ability to

3 comment on this significant change.

4 The Second Revision received 13 negative votes

5 from Technical Committee members, who provided reasons

6 for the negative votes, including - the change is

7 arbitrary; no valid safety or technical reason has

8 been provided for the change; the change was

9 significant and should be considered new material,

10 which is now allowed during the Second Draft revision

11 period.

12 During the First Draft, only grammatical

13 changes were made to Section 4.6.2. During the First

14 Revision, this section received 11 public inputs, none

15 of which proposed lowering the group size threshold

16 from 250 to 50 kilowatts. Most of the public inputs

17 proposed increasing the threshold above 250 kilowatt

18 hours, or removing it. There was no indication that

19 the Committee was considering decreasing the group

20 size.

21 I want to raise a procedural issue. Section

22 44831(A) of the Regulations Governing the Development

23 of NFPA Standards states that a Second Revision should

24 not be made when it would introduce a new concept that

25 has not had public review by being included in a



243

1 related input, or First Revision as shown in the First

2 Draft.

3 As described by several Technical Committee

4 members who voted against this Second Revision, the

5 revision introduced a material concept that has not

6 been reviewed by the public, and was therefore not

7 consistent with the spirit of the regulations.

8 I expect that some of the other submitters of

9 this CAM will explain how this change may make

10 installations less safe, rather than making them more

11 safe. I urge you to vote in favor of this motion, to

12 return the maximum group size to 250 kilowatt hours.

13 Thank you. And I, I hope the other submitters will

14 now have a chance to provide their reasoning.

15 JAMES QUITER: They will, after Mr. Biggins

16 makes a comment.

17 JAMES BIGGINS: Thank you, Mr. Chair. The

18 Technical Committee revised the maximum stored energy

19 level downward, from 250 kilowatt hours to 50 kilowatt

20 hours, based upon heat release rates exhibited by

21 lower energy amounts when, when subjected to large

22 scale fire testing. This was done in consideration of

23 the size of the fire, the heat release, and also in

24 consideration to the safety of firefighters and first

25 responders. Additionally, the energy level is



244

1 consistent with the current limits contained within

2 NFPA 1, Chapter 52 in the IFC.




6 speaking in support or against the motion. Microphone

7 one.

8 WILLIAM CANTOR: Thank you, Mr. Chair. William

9 Cantor, TPI, representing IEEE Energy Storage and

10 Stationary Battery Committee, in support of the

11 motion.

12 The reduction of group sizes in Second Revision

13 75 from 250 kilowatt hours to 50 kilowatt hours is

14 significant, and is, and is new material that has not

15 been scrutinized by the public. There is no First

16 Revision that addresses a change to this number. The

17 Public Comment referenced in Second Revision 75

18 references First Revision 148. FR 148 did not change

19 this number; thus, this is new material.

20 The reduction of group sizes from 250 to 50 is

21 a significant change, with no justification other than

22 it was in the IFC 2018 edition. While it is in the

23 IFC 2018 edition, the IFC completely - IFC 2018

24 completely exempts lead acid and nicad chemistries for

25 this limitation, while NFPA 855 does not offer this



245

1 complete exemption.

2 The justification for Second Revision 75 states

3 that the impact is negligible, when in fact it will

4 have a major impact on the stationary battery

5 industry. It will limit 48 volt systems to about a

6 thousand amp hours; 125 volt systems to 400 amp hours;

7 and 480 volt UPS systems to 833 watts per cell.

8 It is estimated over 100,000 existing lead acid

9 and nicad stationary battery sites that do not meet

10 the current exemptions, that have strings that will

11 exceed these limits, yet have operated safely for

12 decades. Yes, the standard is not retroactive, but

13 thousands of these sites are replaced every year, and

14 thousands of these sites are added every year.

15 There were very strong objections to the Second

16 Revision within the NFPA 855 Technical Committee,

17 mainly based on these particular reasons. Thank you.


19 six.

20 NICK WARNER: My name is Nick Warner with

21 Warner Energy Storage Solutions, speaking on behalf of

22 myself. However, I am a member of the NFPA 855

23 Committee, as well as the ICC Working Group, and

24 several UL Standards. Having conducted numerous --




246

1 NICK WARNER: -- large scale tests --

2 JAMES QUITER: Excuse me - for or against?

3 NICK WARNER: Sorry, I speak against the

4 motion. Having conducted numerous large scale tests

5 on lithium ion batteries, ranging from several hundred

6 watt hours, which is several thousand times smaller

7 than what we're speaking of here, as well as having

8 conducted explosion modeling, it's my concern that

9 even small systems potentially below 50 kilowatt

10 hours, but certainly above 50 kilowatt hours pose

11 significant risks that should require large scale

12 testing to quantify.

13 In addition to the comments by the gentleman a

14 minute ago, several of the telecom systems and

15 utilities systems have already been exempted by

16 language in the code. So the number of systems that

17 are going to be impacted by this in the future should

18 be drastically reduced.

19 Excuse me - however, there is additional data

20 and information to suggest, from events that have

21 happened in the past few weeks and few months, that

22 systems in this 50 to 250 kilowatt hour gap just pose

23 a significant threat that should not be ignored. And

24 while the Committee has gone back and forth on the

25 number several times, as the industry has continued to



247

1 evolve and the information becomes available, that

2 should be considered in real time. Thank you.


4 four.

5 NED WEST: Thank you. I'm Ned West, with

6 Southern Company, speaking for Motion 855-8. We

7 believe that 855 will become the standard for behind

8 the meter battery storage systems, so we want to get

9 it right. I'll focus on three technical reasons for

10 restoring the group size limit to 250 kilowatt hours -

11 chemistry, complexity, and compliance.

12 NFPA's neutral stance on lithium battery

13 chemistry types has an unintended and unfortunate

14 consequence in the case of this group size limit. The

15 draft 855 Standard makes no distinct between the more

16 volatile NMC chemistry, and the safer LFP chemistry,

17 which has better thermal stability, and is more abuse

18 tolerant. Differences between the heat release rate

19 and burn properties of NMC and LFP are described in

20 this Technical Report by NFPA's Research Foundation

21 on, on Large Scale Fire Testing.

22 The 50 kilowatt hour group size limit works

23 against ESS safety by favoring NMC over LFP, and it's

24 because the NMC has a higher nominal cell voltage of

25 3.7 volts, versus a lower 3.2 volts for LFP cells.



248

1 ESS suppliers will tend to choose the more hazardous

2 NMC batteries over the safer LFP because of that

3 inherent cell voltage difference, in order to get

4 under the 50 kilowatt hour limit.

5 Next, complexity - behind the meter ESS are

6 typically thousand-volt strings that feed an inverter

7 to provide 480 volt AC to the customer premises. So

8 with groups under 50 kilowatt hours, it's going to

9 take two to four groups connected in series to make a

10 thousand volt string. Multiple battery groups in

11 separate enclosures will be managed by a single BMS.

12 You see, the standard doesn't define a group. And the

13 standard doesn't say that each group must have its own

14 BMS. So breaking a string into multiple separate

15 groups adds complexity. Power, control and

16 communications between the groups must be field wired.

17 And field wiring is harder to QA than factory wiring.

18 Last, compliance assurance. NFPA rightly

19 incentivizes large scale fire testing to promote safer

20 ESS designs. However, battery suppliers and ESS

21 integrators should be assured that the time and

22 expense of successful UL 9548 testing will allow a

23 listed, 250 kilowatt hour, ESS product to be

24 consistently employed across many jurisdictions. The

25 standards shouldn't make an AHJ liable for



249

1 interpretation of a large scale fire test report to

2 approve group sizes over 50 kilowatt hour for a UL

3 listed --


5 NED WEST: -- battery storage system. We

6 should restore the 250 kilowatt hour limit for reasons

7 of safer chemistry, less complexity, and compliance

8 assurance by voting yes on this motion. Let's get it

9 right. Thank you.


11 three.


13 against the motion. Also, a Committee member, though

14 it's - but I'm not speaking on behalf of the Committee

15 here.

16 You know, the Committee debated this 50 versus

17 250 all the way through the process. We, we discussed

18 it during the first cycle, the public input cycle. We

19 discussed it during the public comments cycle. One

20 reason it came up is because the 50 kilowatt hours is

21 the value that's gone into the 2021 International Fire

22 Code. It was vetted through that process, and as is

23 mentioned, it's also a referenced in NFPA 1.

24 So the 50 kilowatt hour value that we're

25 discussing does not limit ESS above that energy level.



250

1 What it does is it says those need to be subjected to

2 a large scale fire test. And the whole purpose of

3 this section of both the IFC and 855 is it's - it's

4 the size and separation requirements, because there's

5 uncertainty with the fire propagation properties of

6 all battery chemistries, and, and especially the new

7 battery chemistries. So the concept here is if you go

8 above these limits, and you can get a significant fire

9 event from a 50 kilowatt hour battery unit or string -

10 this just says you have to do large scale fire

11 testing.

12 Also with some of the technologies such as

13 lithium ion systems when they're indoors, you want to

14 do the large scale fire testing because you make get

15 flammable gasses off those if they go into thermal

16 runaway. And then the code and - requires explosion

17 prevention - or pardon me, explosion control. Well,

18 you can't determine the gas flow rates for - to comply

19 with NFPA 68 or 69, without doing large scale fire

20 testing. So if you allow up to a 250 kilowatt hour

21 single unit - and you can have multiple units within a

22 fire area - a single unit, if that goes into thermal

23 runaway and you have not conducted a large scale

24 testing on that, you could have a very catastrophic

25 event. And that's the problem with energy storage



251

1 systems, compared to some other technologies out

2 there, is the potential for a catastrophic event.

3 Thank you.


5 four.

6 TIM MYERS: This is Tim Myers from Exponent,

7 speaking for the motion. I just wanted to comment on,

8 on a few statements that I've heard.

9 One that I've, I've heard a few times today is

10 that this limit was lowered to force people to have to

11 do large scale fire testing on smaller units. I, I

12 find that really interesting, because if you look at

13 the Second Revision report and read the Committee

14 statement, it says, 'The impact is negligible, since

15 large scale fire testing is required for lower levels

16 anyway, to generate date for deflagration prevention,

17 and correct fire protection levels.'

18 So when they - they wrote the Second Revision,

19 they said this was a negligible issue because you

20 would already have to do fire testing. Today what's

21 being communicated to us was, this was actually done

22 to force smaller units to have to do fire testing.

23 Thank you.

24 JAMES QUITER: Microphone three.

25 BEN DITCHA (phonetic): Ben Ditcha from Global.



252

1 I'm a Committee member on 855, although I'm not

2 speaking for that group. I am speaking against the

3 motion. The report the gentleman held up earlier on

4 the Foundation Report - I wrote the Basis Report for

5 that. I conducted those large scale fire tests.

6 In the world of lithium ion batteries, energy

7 storage capacity is fuel. If your system gets larger,

8 you're going to have a bigger fire. And in that

9 report, you'll find that 50 kilowatt hour systems,

10 both iron phosphate, with was the LFP, and nickel

11 manganese cobalt oxide, which is the NMC, both

12 represent significant hazards at 50 kilowatt hours.

13 That's not to say the systems can't be made

14 safe, and they can't be adequately protected. We need

15 the fire test. This criteria here makes you conduct

16 the large scale fire test. It's the only way we can

17 make sure that these systems are going to be safe.

18 So I urge you, with that, to vote against the

19 motion.


21 one.

22 EDDIE GEDRY (phonetic): My name's Eddie Gedry,

23 representing myself, and I would like to call the

24 question, please.

25 JAMES QUITER: Okay. There is a motion from



253

1 the floor to call the question. I noted a person at -

2 remaining at a microphone waiting to speak, but we'll

3 proceed with the vote on the call of the question. Do

4 we have a second?



7 to vote on this motion, please remember to scroll down

8 to the very bottom of the tablet to vote - not to vote

9 on this item. If you wish to vote in support of the

10 motion, touch 'Yes'. If you wish to vote against the

11 motion, touch 'No'. Please record your vote - and

12 remember, this is the vote on calling the question.



15 Results are: 546 in, in support of the motion

16 to call the question; 75 against the vote - the motion

17 to call the question - which returns us to the primary

18 motion.

19 So before we vote, let me restate the motion.

20 The motion on the floor is to Reject an Identifiable

21 Part of Second Revision No. 75. To vote, touch the







254

1 record your vote.


3 working.

4 UNIDENTIFIED SPEAKER: Yeah, it is now.


6 JAMES QUITER: Okay. Did it go back to

7 working?

8 UNIDENTIFIED SPEAKERS: Yeah. Yes.

9 JAMES QUITER: Okay. Thank you. I need to not

10 move so fast.


12 JAMES QUITER: The voting will be closed in

13 five seconds.





18 Screen Two. Therefore, the motion has failed.

19 Well, let's now proceed with the discussion on

20 Certified Amending Motion 855-9. Microphone one.

21 PAUL HAYES: Thank you, Mr. Chair. My name is

22 Paul Hayes. I'm with American Fire Technologies, and

23 I am representing myself. My motion is to Accept 855-

24 9, which is - Accepts Public Comment 283.




255

1 the floor to Accept Public Comment No. 283. Is there

2 a second?



5 proceed with the discussion on the motion - again,

6 starting with --

7 PAUL HAYES: Okay.

8 JAMES QUITER: -- identifying yourself.

9 PAUL HAYES: Thank you very much. The first

10 thing I want to do is acknowledge Jim Biggins, and

11 those that served on this Committee, because it was a

12 --

13 JAMES QUITER: So do - do - do --

14 PAUL HAYES: This is not an easy task

15 (unintelligible)

16 JAMES QUITER: Start with the Paul Hayes, and

17 who you represent --

18 PAUL HAYES: All right.

19 JAMES QUITER: -- first, and --


21 JAMES QUITER: -- your position on the motion.

22 PAUL HAYES: Paul Hayes. I represent myself,

23 and --

24 JAMES QUITER: And you're --

25 PAUL HAYES: -- from American Fire



256

1 Technologies.


3 PAUL HAYES: For the motion.


5 PAUL HAYES: All right. So, to acknowledge Jim

6 and his actions. This was no easy task. I am a Fire

7 Protection Engineer with 35 years. I do not sit on

8 855. I do sit on 850. I am not representing any of

9 those Committees, but I had the honor and the pleasure

10 of sitting through 12 days, and 1200 public comments.

11 What I want to do is reference Arizona. It was

12 a very unfortunate event. We wish those that were

13 injured, the best. As I've said several times, no

14 asset is worth a life, but it does provide an

15 opportunity for us to learn, and we've got to share

16 best practices in this industry. I have seen a big

17 shift. I have seen them working towards best

18 practices, and it is something as a, as a group, we

19 have to share.

20 There is no silver bullet at this point in

21 time, but I am recommending that we provide gas

22 detection as a standard for lithium ion. This

23 language is out of the - the public comment is out of

24 the IFC Gas Detection. As the 855 is currently

25 written, it provides gas detection under normal



257

1 conditions, such as sealed lead acid batteries;

2 directs you to 868 and 869 for explosion and control -

3 neither which specifically address lithium ion

4 batteries. As we've seen, they can and will create an

5 explosive environment. I believe the technology code

6 advances, we will see further guidance, and we need to

7 provide that guidance to the AHJs in the industry.

8 Unfortunately, this PC was written about a year

9 ago. It's not perfect. I recognize that there's some

10 conflicts that this creates. But I believe providing

11 improvement now is better than waiting, because of

12 what we can see, and possibly can happen in the

13 industry.

14 Explosions are very real possibilities with

15 lithium ion batteries. Large scale testing, 9540A,

16 have both shown that lithium batteries gas during

17 thermal runaway and propagation. It can, and has

18 created events, explosive events. So 68 and 69,

19 again, don't specifically address this.

20 Suppression systems can actually make the

21 systems worse. They can reflash, they can continue to

22 cascade in an oxygen starved environment. This motion

23 reflects the 2018 gas --


25 PAUL HAYES: -- detection chapter in IFC. We



258

1 have recognized that it, the - right now as it's

2 written, is missing some information. Again, I want

3 to see this addressed sooner, as opposed to later.

4 But in discussions with the Committee, I believe a TIA

5 may be forthcoming anyway. So if we don't move

6 forward on this one, I believe it needs to be

7 addressed in this publication.

8 So I think outside of that, we will see some

9 changes in this code. So I'm asking that you support

10 this, and it may need some adjustments as we move

11 forward. Thank you, Mr. Chairman.



14 JAMES BIGGINS: Yes, Mr. Chair. The Technical

15 Committee incorporated much of this public comment in

16 Second Revision 79, which combines Sections four - 4.9

17 and 4.12 from the First Revision of NFPA 855, into

18 Section 4.9 of the Second Revision. Specifically,

19 Section 4.9.3.2 addresses requirements for gas

20 detection. The gas - the Committee did not agree on

21 all items proposed in the public comment, but did

22 require in Section 4.9.3 that the gas detection system

23 be designed to activate the mechanical exhaust

24 ventilation system when the level of flammable gas

25 detected in the room, walk-in unit, enclosure,



259

1 container, and cabinet exceeds 25% of the LFL. The

2 mechanical exhaust system shall remain on until the

3 flammable gas detected is less than 25% of the LFL.

4 The gas detection system shall be provided with a

5 minimum of two hours of standby power, and the failure

6 of the gas detection system shall enunciate a trouble

7 signal at an approved central station, proprietary, or

8 remote station service, or one approved at a

9 constantly attended on site location, in accordance

10 with NFPA 72, or at an approved (unintelligible)

11 location.

12 The Technical Committee did not have enough

13 information to determine if de-energizing the battery

14 charger was an appropriate action, at 25% of the LL

15 (phonetic), for all types of energy storage systems.

16 So we did not take action on that.

17 The Technical Committee also did not believe it

18 was appropriate to exclude stationary battery systems

19 less than 50 volts AC/60 volts DC, as these

20 installations are also capable of providing flammable

21 gases.







260


2 ROBERT DAVIDSON: Robert Davidson, Davidson's

3 Concepts; a member of the Committee but not speaking

4 for the Committee, speaking opposed to the language -

5 mainly because it, it just won't work at this time

6 with the standard. The proposed language starts out,

7 'Where required elsewhere in the code,' rooms

8 containing. We actually don't mandate gas detection

9 anywhere. In the case of the mechanical ventilation,

10 it's an option. You can design your space with your

11 exhaust ventilation running continuously, or if you

12 don't want to do it continuously, you have the option

13 to go to gas detection, and then all the safety

14 factors that the Chair just recited would kick in. So

15 there's no trigger there.

16 In the case of toxics, we have a restriction

17 against toxics exceeding PELs. But there's no

18 requirement for mandatory gas detection. How they

19 engineer the system, how they provide for that, is up

20 to them. So it says where required, but once I get

21 into the standard, it doesn't say to do it.

22 So if we were to put it in, and somebody was to

23 try to apply it to the mechanical gas monitoring -

24 well, if the mechanical gas monitoring senses the LEL

25 increase, it puts the exhaust on, and keeps it down to



261

1 the acceptable level. That's - that would be the

2 normal operation for that space. However, this would

3 also require that normal operation to initiate the

4 distinct audio/visual alarms, the transmittal on their

5 approved location, de-energize the battery charger,

6 when actually, it's doing what he wanted - we want it

7 to do, to maintain that space below the LEL.

8 So as drafted and as written, this will not

9 work with the existing language in the code. Some

10 major rewrites would have to occur, which - this isn't

11 the time to do that; the next cycle would be the time.

12 I urge you to vote against the motion.

13 JAMES QUITER: Thank you. Also microphone

14 number three.

15 CURTIS ASHTON: My name's Curtis Ashton, and I

16 am the Chair of the Energy Storage and Stationary

17 Battery Committee of the IEEE; also, the Co-Chair of

18 the IEEE Ashray (phonetic) Working Group for

19 Ventilation and Thermal Management of Stationary

20 Batteries. While I appreciate the intent of --

21 JAMES QUITER: And speaking for, or against the

22 motion?

23 CURTIS ASHTON: I'm speaking for the motion.

24 Thank you.

25 JAMES QUITER: For the motion, or against?



262

1 You're at the --

2 CURTIS ASHTON: Sorry.

3 JAMES QUITER: -- against mic.

4 CURTIS ASHTON: Against the motion.


6 CURTIS ASHTON: Against the motion. Thank you.

7 Nervousness overtook me. So I appreciate the intent

8 of the submitter in trying to handle a problem with

9 lithium ion batteries. However, it's overly broad

10 because it doesn't specifically exclude other

11 technologies. So lead acid batteries, and nickel

12 cadmium batteries, for example, gas small amounts of

13 hydrogen. However, Ashray (phonetic) and the IEEE

14 specifically recommend against using gas detection for

15 those technologies because of - it's maintenance

16 intensive, and causes a lot of false alarms that get

17 ignored. And so the amount of gas produced is

18 incredibly tiny, and so it's overkill to require gas

19 detection.

20 And so in my opinion, this just takes a step

21 too far in, in encompassing all technologies, rather

22 than, than covering the technology that it needs to

23 cover. Thank you.





263

1 No. 283? Mr. Biggins?

2 JAMES BIGGINS: Nothing, Sir.





7 motion, and recommend this text on Screen One, touch




11 Five seconds.








19 please. Scrolling laptop time.

20 PAUL HAYES: Too, too - too many comments, Mr.

21 Chairman. Thank you, Mr. Chairman. My name is Paul

22 Hayes, American Fire Technologies. I represent

23 myself. My motion is for 855-10 to Reject Second

24 Revision 100. My comment, a quick comment, the

25 Committee (unintelligible) --



264

1 JAMES QUITER: Let - let's get a second, and --

2 PAUL HAYES: I, I'm going to withdraw the

3 motion.

4 JAMES QUITER: Oh, okay. The let's not --


6 JAMES QUITER: -- take a second.

7 (laughter)

8 PAUL HAYES: So I don't want to - what I would

9 like to, to acknowledge is that this chapter needs

10 work, but it is being currently addressed through a

11 TIA and a Task Group process. So therefore, I will

12 withdraw this motion.

13 JAMES QUITER: Okay. Thank you, Mr. Hayes.

14 Motion 855-10 appeared on our Agenda. However, the

15 authorized maker of the motion has notified NFPA that

16 he no longer wishes to pursue this motion. Therefore,

17 in accordance with NFPA Rules, Convention Rules at

18 Section 2.7, the motion may not be considered by the

19 assembly, and is removed from the agenda. We will now

20 move on to the next motion.


22 Certified Amending Motion No. 855-11. Microphone

23 four, please.

24 TIM MYERS: I am Tim Myers of Exponent. I move

25 to reject Second Revision No. 173.



265


2 to Reject Second Revision No. 173. Is there a second?



5 proceed with the discussion on the motion - again,

6 starting with your name.

7 TIM MYERS: I am Tim Myers of Exponent,

8 speaking in favor of the motion. This motion would

9 remove Annex F from NFPA 855. The Annex is an

10 approximately 28-word summary of the history of

11 requirements for energy storage systems in a variety

12 of current, historical, and future codes and

13 standards.

14 I am moving to reject this Second Revision,

15 because the public has not had the opportunity to

16 review or comment on this language. There was no

17 indication in public, or Committee inputs, or in the

18 First Revision, that such an annex would be created.

19 It was also not a public comment. It was added as

20 Second Revision - my understanding it was, was

21 actually added at a meeting that was held after the

22 deadline for Second Draft meetings - but it was added

23 as a Second Revision, and was first available for the

24 public to review when it was published in the Second

25 Revision Report on February 28th of this year. The



266

1 only opportunity the public has had to comment on this

2 is during the NITMAM phase.

3 As described by the Technical Committee members

4 who voted against this standard revision, the revision

5 introduced material concept that had not been reviewed

6 by the public, and was therefore not consistent with

7 the spirit of regulations.

8 Section 4.4.9.2 of the regulations governing

9 the development of NFPA Standards stated that Second

10 Revisions must be related to material that has

11 received public review during the input stage, either

12 through the submission of public input, Committee

13 input, correlating input, or through First Revisions.

14 Section 4.4.8.3.1(A) states that a Second

15 Revision should not be made when it would introduce a

16 concept that has not had public review by being

17 included in a related input or First Revision, as

18 shown in this First Draft.

19 As described by Technical Committee members who

20 voted against the Second Revision, the revision of

21 adding a new annex which will be used to - as

22 described by Technical Committee members who voted

23 against this Second Revision, the revision of adding a

24 new annex which will be used to interpret the meaning

25 of draft NFPA 855 was not consistent with the spirit



267

1 of the regulations.

2 Even though this is in the annex material, and

3 not a requirement, it is important for it to go

4 through the standard-making process to ensure that it

5 is accurate. Users, enforcers, and other parties

6 often refer to annex material to understand and

7 interpret the requirements within the body of the

8 standard. If the material is important and needs to

9 be in the standard, it should go through the proper

10 standard making process in the next revision cycle, or

11 be introduced through a TA. I urge you to support

12 this motion to remove Annex F.



15 JAMES BIGGINS: Yes. I would first like to

16 speak to - this is the second time Mr. Myers has said

17 that the Committee met beyond the dates. The

18 Committee worked within the dates on the custom

19 schedule that we were assigned by the Standards

20 Council and Standards Administration. So that is a

21 false statement, and I would appreciate you not

22 misleading the voting members.

23 Secondly, the Technical Committee decided to

24 develop this annex material as an aid to the users of

25 the document, including system developers, owners,



268

1 AHJs, and the Fire Service, in order to provide,

2 provide all parties with an understanding of how the

3 various codes and standards, including NFPA documents,

4 such as NFPA 70, and NFPA 1, the IFC - the IF Codes,

5 and the UL Standards all work together to provide

6 guidance in this area.

7 The development of the annex is a direct result

8 of the approximately 100 public comments on Chapter

9 One of the First Draft of 855 on the scope, purpose,

10 application, and retroactivity sections of the

11 standard, where it became clear to the Technical

12 Committee that many of the submitters did not

13 understand the history of the codes and standards that

14 apply and cover energy storage systems. The annex is

15 informational, does not contain it - or introduce any

16 new requirements for these systems. Thank you.







23 International, speaking for NAFRA, and against the

24 motion. As I've said in, in a different context

25 today, I am the technical contact for ASTM E136, the



269

1 standard for testing for non-combustibility of

2 building products.

3 We have a very extensive appendix - we call it

4 appendix in ASTM, which is the equivalent of Annex

5 here in NFPA - we have an extended appendix on the

6 history of the concept of non-combustibility, and how

7 the test methods have evolved over time. I have found

8 - I resort to looking at that quite frequently. In -

9 a couple of years ago, a proposal went in front of the

10 Committee to see whether we wanted to delete that

11 annex - that appendix, because history's - it doesn't

12 matter. There was overwhelming vote against that.

13 Why? Because the Committee members felt that the

14 history of how you get to a certain thing is a very

15 important background.

16 There is no application of that as a mandatory

17 part of the document. It just brings the, the members

18 up to speed as to how this was developed, and what it

19 means. The requirements are in the body; the

20 appendix, or the annex in this case, is there for

21 information to let people know why we're doing this,

22 why this has been developed. Please vote against the



25 please.



270

1 TIM MYERS: So I just want to clarify a, a

2 statement that I made.

3 JAMES QUITER: Your name first.

4 TIM MYERS: Tim Myers from Exponent, speaking

5 in favor of the motion. I've compared the dates that

6 the meetings were held, to a document that's published

7 on the NFPA website that says - it's Custom 2020, NFPA

8 855 Master Schedule. The last date for the Second

9 Draft meeting listed on that document is before the

10 date of the last two meetings for NFPA 855.

11 And so I want to respond to, to the last

12 comment. I'm not saying that it's not a good idea to

13 have history, a description of history in an annex.

14 What I am opposed to is this being added without the

15 public having any opportunity to comment on it, and to

16 propose edits to it. This literally was - has not

17 shown up in public input, public comment - anywhere.

18 There was nothing that someone could actually look at,

19 and provide feedback on until this Second Draft Report

20 was published. Thank you.


22 three, please.


24 Concepts, also a member of the Technical Committee,

25 but not speaking for the Committee, speaking in



271

1 opposition to the motion.

2 So this actually came out of the First Draft

3 meeting, public meeting. This is - this information

4 is what we used to guide us in the work - to explain

5 why things are already in the Fire Codes, and why

6 we're referring to that language - how they - how we

7 got there, how it developed. It was after all of that

8 work was done going into the First Draft, that it was

9 decided that, you know what, we should take all this

10 language, and put it, put it in an annex so everybody

11 with this document (unintelligible) can understand how

12 the Committee got to where they got. And it was

13 assigned to a Work Group, and a Work Group worked on

14 this, and commented on it, and then it was brought

15 forward with those edits at the Second Draft meeting.

16 So that there wasn't public notice - well, the

17 people participating in the process knew it was

18 happening. But more importantly, this is just

19 extracts out of the codes. These are public

20 documents. Those documents exist, and had public

21 participation. Anybody could have read them. The,

22 the process they went through changes, all posted

23 electronically. People can get at it and read it.

24 This, this is public information. We didn't write

25 code. We just grabbed the reference materials out



272

1 there so people understand that history, and how we

2 got to where we are. I would urge you to vote against

3 the motion.


5 one, please.

6 EDDIE GEDRY: Eddie Gedry, speaking for myself.

7 Call the question, please.


9 UNIDENTIFIED SPEAKER: Second. He's speaking

10 for all of us (unintelligible).


12 to call the question. Do we have a second?



15 to vote on this motion, please scroll down to the very

16 bottom of your tablet to vote. If you wish to vote in


18 vote against the motion, touch 'No'. Remember, this

19 motion is only to call the question. Please record

20 your vote.


22 The voting is closed. The results of the vote

23 are: 560 in support of the motion to call the

24 question; 33 against the motion to call the question.

25 The motion has passed, which returns us to Item 855-



273

1 11.

2 Before we vote, let me restate the motion. The

3 motion on the floor is to Reject Second Revision No.

4 173. To vote, touch the 'vote' button. If you wish

5 to vote in support of the motion, and recommend the

6 text on the screen, on Screen One, touch 'Yes'. If



9 vote.









18 one, please.

19 CHRIS SEARLES: Chris Searles, BAE Batteries

20 USA, past Chair of IEEE Energy Storage and Stationary

21 Battery Safety Codes Working Group. I'm Secretary of

22 the latter. At the consensus request of the ESSB

23 Safety Codes Working Group, I make a motion that NFPA

24 855 as currently proposed be sent back to Committee

25 for revision.



274


2 the floor to Return the Entire NFPA Standard. Is

3 there a second?


5 JAMES QUITER: There is a second. Please

6 proceed with the discussion of the motion.

7 CHRIS SEARLES: Thank you, Mr. Chair. Well --

8 JAMES QUITER: And again, start with your name,

9 and affiliation.

10 CHRIS SEARLES: Chris SEARLES, BAE Batteries,

11 USA.

12 JAMES QUITER: Speaking for the motion --

13 CHRIS SEARLES: While there are many good

14 points - and I am in favor of this motion. While

15 there are many good points contained within NFPA 855,

16 and we appreciate the difficult work of the Committee,

17 and with the number of lithium ion fires in the energy

18 storage space now becoming known, a need for

19 regulation via code compliance is in order for lithium

20 ion batteries.

21 However, 855 as written has several issues that

22 do need to be reexamined and corrected before

23 releasing as a viable standard. 855 should

24 concentrate its focus on lithium ion, and newer

25 commercially available types of emerging technology



275

1 battery systems exclusively, while existing codes and

2 standards continue to address the evolution of lead

3 acid and nickel cadmium batteries.

4 In addition, there are several other major

5 concerns that should be addressed by the 5 - 855

6 Committee members, in our opinion. They've shown

7 earlier, there are Second Draft changes that the

8 public has not had a chance to comment on. Number

9 two, the carve-outs included in the Second Revision

10 are not universal, and address only a portion of the

11 affected markets while perhaps unintentionally

12 providing an unintended license for lithium ion

13 batteries to skirt around some intended requirements.

14 We have already addressed the fact that there

15 were 875 public comments submitted, and 37 were

16 accepted, to our knowledge. So it's obvious that a

17 significant number of relevant issues have not been

18 adequately addressed.

19 Certain thresholds - number four - threshold

20 values for volume, and kilowatt hour calculations are

21 impractical for all technologies.

22 Number five, requiring UL listing for all

23 batteries, especially lead acid and nickel cadmium

24 batteries is not practical, due to the significant

25 number of variations in the chemistries. It would add



276

1 tremendous costs not only to manufacturers, but to

2 users, as well.

3 It is our understanding there are clauses being

4 introduced into NFPA 1, and the IFC Code that would

5 require those codes to retroactively include 855

6 sections verbatim, which could prevent active public

7 comment, or Committee action in these instances.

8 In our opinion, adopting 855 in its present

9 form is a serious disservice to major parts of the

10 industry and public. The exceptions and carve-outs

11 are evidence of an attempt to minimize this damage.

12 The standard really needs to be sent back to

13 Committee for substantial revision, for each of the

14 technologies involved, to bring back a solid and very

15 meaningful standard. Thank you.


17 you like to offer an opinion?

18 JAMES BIGGINS: Yes, Mr. Chair. The

19 development of NFPA 855 began in 2016, when the NFPA

20 Standards Council approved a request to NFPA to

21 develop a standard on stationary ESS. It was

22 submitted on behalf of the California Energy Storage

23 Alliance, in order to address gaps in regulation

24 identified through workshops.

25 In the three years since, the Tech Committee



277

1 was formed, a draft standard was developed. Nine

2 meetings were held in person; various task groups

3 working on teleconferences; acted on 531 public -

4 public inputs on the draft; 875 public comments on the

5 First Revision. As Mr. Searles said, you know, he

6 only saw that 37 were accepted. In NFPA code process,

7 in the process, when you accept a, a public comment,

8 you accept it as-is, as proposed. So yes, we accepted

9 - only accepted 37 public comments as proposed. But

10 we - with - out of the other five hundred and some

11 comments, the Committee created 166 Second Revisions

12 to the document, based upon the - these comments from

13 the - from the public. So to say that, you know - the

14 impression that we didn't, you know, pay attention to

15 what was being told to us is complete incorrect.

16 Irregardless, the Committee worked diligently

17 to craft a standard built upon the information in NFPA

18 1, NFPA 70, the other standards such as the, the I

19 codes, you know - other product standards such as

20 those developed by you all. And we worked to develop

21 a comprehensive document to fill those gaps left by

22 these documents, to provide a comprehensive document

23 which could be looked at by all - not only here in the

24 US, but this document will probably receive a lot of

25 interest in other parts of the world, such as China,



278

1 Korea, and other areas where these installations are

2 going in, and they have no guidance, and they are

3 looking to us for this type of document.

4 The Technical Committee strongly believes that

5 NFPA 855 has accomplished the goals set forth by the

6 Standards Council, and asks you to vote against this


8 JAMES QUITER: Thank you. With that, we will

9 open up debate on the motion. Please provide your


11 support of, or against the motion. Microphone four,

12 please.

13 TIM MYERS: For those of you that haven't heard

14 my name before, I'm Tim Myers from Exponent, and I'm

15 in - speaking in support of the motion. First, I

16 would like to thank the Technical Committee for all of

17 their hard work. I do really appreciate it.

18 Unfortunately, I don't believe there has been adequate

19 time to consider and develop 855. The NFPA Standards

20 process allows a motion and return - to return the

21 first edition of standard to the Committee for further

22 development.

23 With my minimal allotted time, I will focus on

24 some of the key problems with the current draft of

25 855. You have all heard - you have already heard



279

1 disagreement between experts on some issues with the

2 standard. I will highlight additional issues.

3 The current scope of NFPA 855 is overly broad,

4 and there is debate on which industries and types of

5 occupancies should be included. One key difference

6 between 855 and NFPA 1, and the IFC is that in 855,

7 Annex material to the Threshold Quantities Table 1.3

8 states that you should aggregate the energy storage

9 capacity of the - in the entire fire area. This has a

10 consequence of requiring very large rooms, like this

11 room, with many small, distributed batteries to comply

12 with the NFPA 855, and be treated the same as lithium

13 ion energy storage systems with large quantities of

14 batteries concentrated in a small area. As an

15 example, the aggregate capacity of batteries in the

16 voting iPads in this room today has exceeded the

17 threshold quantity in NFPA 855.

18 Consider how many stationary batteries are in

19 large fire areas, like the room we are in, the Expo

20 area downstairs, a warehouse, big box stores, data

21 centers, or large office spaces. In these types of

22 rooms, there are often small backup batteries, and

23 emergency lights, the fire alarm control units, and

24 other appliances. The aggregate energy capacity of

25 these batteries would make these types of large fire



280

1 areas fall under NFPA 855.

2 In contrast, NFPA 1 specific states in the

3 Annex material that it is not intended to regulate

4 equipment with integral standby power systems below

5 the threshold amounts, including these specific

6 examples.

7 These types of large rooms also can contain

8 laptops, appliances, consumer products, and other

9 battery containing devices in a stationary

10 configuration, that would fall under the standard.

11 These types of occupancies have not been involved in

12 the standards making process, and are not the real

13 hazard that needs to be addressed.

14 There are other points that I'd like to make,

15 that maybe I can come back and address later. But I

16 urge you to support this motion to return the standard

17 to Committee. I believe it is important that we get

18 this first edition correct so that it provides valid

19 information to stakeholders. If we get it wrong,

20 incorrect information will propagate to other

21 standards, and it will be difficult to correct in the

22 future. Thank you.


24 six.




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1 International, speaking for NAFRA, in opposition to

2 the motion. I urge you to disapprove the motion.

3 The, the previous two speakers said the, the NFPA 855

4 is not perfect. Well, hallelujah - what standard,

5 what code is perfect -

6 (laughter)

7 MARCELO HIRSCHLER: -- particularly the first

8 edition. When is ever a code perfect?

9 (applause)

10 MARCELO HIRSCHLER: That's why we're here, all

11 the time, to keep revising them and improving them.

12 But if we're going to start throwing away every time

13 we have something that's not perfect, we'll never get

14 anything through.

15 This is a really important exercise to get a

16 problem that we know exists, and is being highlighted

17 by some serious accidents that happened all over the

18 world. Please allow this document to come to

19 publication so we can start having a method to address

20 these problems. Oppose the motion. Thank you.


22 one.

23 CURTIS ASHTON: Curtis Ashton, Chair of the

24 IEEE Energy Storage and Stationary Battery Committee,

25 in favor of the motion. Just to follow on a little



282

1 bit about the aggregate capacity. A lot of people

2 talk about - have talked about laptops, and the

3 aggregate capacity of laptops. I'd like to bring a

4 more real world example of a stationary battery. Both

5 Google and Facebook have large data centers with

6 distributed power. And about every 19 inches, there's

7 a very tiny battery about the size of a laptop

8 battery. It's a lead acid battery, and it would be

9 covered under this standard, under its existing

10 language. And so I think there's unintended

11 consequences. And I - I'm amazed that this Committee

12 kicked out a standard in three years. It was an

13 incredible amount of work. I've written standards

14 that take over 10 years to provide, to come out with

15 a, a large group of people, and a large interested

16 audience. So the work they did is amazing, but I just

17 think it's not quite ready for prime time.

18 One other example of how it's not quite ready

19 for prime time - and I agree with Marcelo's comment

20 that it, it's not going to be perfect the first time

21 out. But I don't think you can have unintended

22 economic consequences that are large, when you already

23 know the answer and you can easily avoid them.

24 Everyone knows that not all lithium ion chemistries

25 are created equal. Some are safer than others.



283

1 Lithium titanite, as far as I am aware, there's never

2 been a documented fire with lithium titanite. Lithium

3 phosphate is a relatively safer lithium ion chemistry.

4 And so basically, I guess the point I'm trying

5 to make is the standard is overly broad in certain

6 areas, and it will cause burdensome economic

7 consequences a battery technology that is very safe,

8 such as the Google data center that I talked about, or

9 the lithium titanite chemistries that are out there.

10 So I urge acceptance of this recommendation that this

11 be returned to Committee for further work to further

12 refine the standard.


14 please.

15 RYAN MCMORROW: Ryan McMorrow with NextEra

16 Energy, speaking in favor of the amendment. I, too,

17 would like to commend the work of the 855 Committee.

18 This was an incredible amount of work. And I also

19 would like to comment that I can personally attest to

20 this Committee's commitment to reaching out to and

21 understanding as much as they possibly could, and

22 gaining information from the industry as they could.

23 And so certainly appreciated those efforts, and the

24 opportunities I've had to speak with you guys.

25 However, this - 855 as it reads now does not



284

1 add a lot of value, or add, add a lot of additional

2 information relative to the NFPA 1 that's already been

3 passed, nor from the International Fire Code. It also

4 doesn't take away a lot. As far as what it adds, and

5 what it takes away to the existing standards, here is

6 not really a lot of actionable changes to how we would

7 go and design an energy storage system based on 855,

8 versus the NFPA 1, or the International Fire Code.

9 One of the areas where it does expand on those

10 requirements is on ventilation. And as information is

11 continuing to come out at a, a more and more rapid

12 pace after some of the events that have happened

13 around the world, we don't have good information

14 detailing what the appropriate rate of ventilation

15 should be for these energy storage systems, and

16 specifically the concern being that we may actually

17 make things worse by adding ventilation. And I think

18 it's that engineering detail, and those engineering

19 studies that need to be allowed to conclude, and

20 allowed to be incorporated into this standard in order

21 to add a significant amount of value, and become the

22 global standard for energy storage systems.

23 If I look at the design of substations for, you

24 know, independent power producers, understanding

25 utilities are now exempted; but as an independent



285

1 power producer, if I build a substation, I'm now going

2 to be designing my substation to make sure that the

3 backup battery systems that provide protection and

4 control, are less than 50 gallons. That requirement

5 is completely arbitrary. There's no guidance for it.

6 But if that 50 gallon requirement is necessary in

7 order to meet an exemption, then I have to put fire

8 sprinklers in the middle of the desert, in a solar

9 facility.

10 So I would urge you to accept the motion to

11 send this back to the Committee. I think the

12 Committee is very talented, and with an additional

13 time, they'd be able to incorporate detailed

14 engineering information, and make this a much, much

15 better standard. Thank you.


17 please.

18 HOWARD HOPPER: Howard Hopper, UL, speaking in

19 opposition to the motion to turn, return this to

20 Committee. I've got to admit, what I'm hearing is

21 kind of what I'd term as a lot of red herrings. We

22 already discussed that laptop ESS is not considered -

23 or laptops lithium ion batteries are not considered

24 ESS by the definition of energy storage systems. So

25 they're not going to contribute to any sort of



286

1 quantity of ESS you'd have to consider in an area.

2 Also, there was discussion about, 'Well, we may

3 not have really looked at a lot of different battery

4 technologies, and these are...' - you know, I heard that

5 one technology is safe. Well, we've - we set up the

6 855, which is very similar to the 2021 IFC, to have

7 technology specific criteria. If you can come to the

8 Committee and show your, your technology has a good

9 safety performance area, then we'll address that in

10 the code. And we did that for a nickel technology

11 right during the process. They brought forward some

12 data that they, they performed acceptably. So with

13 855 in place, we had a vehicle to be able to evaluate

14 that, and determine what protection criteria you need

15 for that technology, versus not having it.

16 So - and, and 855 is almost identical to the

17 protection concepts that are in the 2021 edition of

18 the International Fire Code which will eventually be

19 adopted probably in over 40 states in the country. So

20 saying these requirements aren't correct, you're going

21 to have the same requirements being enforced. And we

22 know of certain - I've heard of certain jurisdictions

23 that are looking at adopting those before the 2021

24 effective date.

25 So I think what you have is anyone saying this



287

1 is not ready for prime time, that it's incomplete,

2 it's not well thought out - we've been working on this

3 - the various working groups covering ESS, both on the

4 ICC side, and NFPA, we've been building on each

5 other's work since, since 2015. And right now we have

6 a platform in place that has good, enforceable

7 criteria. It has technology specific requirements,

8 and it addresses issues like not having water supply

9 out in the desert. That's a specific exemption for

10 dedicated use facilities in a remote location. We

11 specifically recognize that you're not going to have

12 water supply out there. So it's addressed. So I

13 would urge you to keep the - keep the - not return

14 this to Committee; allow it to go forward, so that

15 then we can start from this point forward. If

16 revisions are needed, we have a good basis to work on

17 those. Thank you.


19 please.

20 JOEL HAYES: Yes. Joel Hayes, in support of

21 the motion, from NantEnergy. Just like to make a

22 couple of points.

23 So comments that this, this NFPA 855 is not

24 perfect, and I appreciate all the effort that's gone

25 in in NFPA 855. And I agree it's not perfect, and it



288

1 can, it could use improvement. I think a lot of the

2 pushbacks comes because of the, the implications and

3 impact to the industry, and the expense, and

4 disruption that it will cause. It's one thing to put

5 forward an imperfect standard, saying we'll improve

6 it. It's another to put forward an imperfect standard

7 that's going to have major impact, and disruption

8 until it can be improved. I think we need to keep

9 that in mind.

10 A lot of reference has been made to the IFC

11 2020, saying that it's just a simple adoption of their

12 standards. It has been very clear that there's call-

13 outs in the IFC, like with some of the safer

14 chemistries, like lead acid and nickel cadmium, that

15 are not in 855, that are at least not adequately in

16 855, especially in relation to the size of the system.

17 It, it's very clear from the discussion that

18 855 has been written substantially towards lithium

19 ion. If that's the intention, then it should be more

20 clearly stated what applies to lithium ion, and what

21 does or not apply to the aqueous chemistries, such as

22 nickel cadmium, lead acid, etc. You, you're using a

23 one size fits all to apply this standard to

24 substantially lithium ion installations. And when you

25 discuss the dangers and the safeties, everybody says



289

1 lithium ion.

2 I think the other thing that's been obvious

3 from the contentious comments and discussion is that

4 there doesn't seem to be an adequate input from the

5 broader industry - the utilities, the users, some of

6 the, the energy storage systems used in buildings. So

7 I am for the motion that this should go back to the

8 Committee to be reconsidered, and come up with a more

9 perfect product sooner, that could be used in the

10 industry.


12 please.

13 MATT PACE: Thank you, Mr. Chair. I'm Matt

14 Pace, representing the International Association of

15 Firefighters, speaking against the motion.

16 It's, it's not very common that Marcelo and the

17 Fire Service are standing at the same mic.

18 (laughter)

19 (applause)

20 MATT PACE: This is a critical standard to get

21 published. We are planning on getting right back

22 together to work out some of these, these bumps. But

23 if you notice the screen that was being displayed

24 during our breaks, one of the images up there was a

25 very large scale, utility sized energy storage, with



290

1 the statement, 'We make the world safer together.' If

2 this is not published, we'll be going backyards years

3 in providing a level of safety for the most common

4 electrical chemical battery being installed today -

5 lithium ion.

6 I agree, we have a lot of work to do to make it

7 as perfect as possible. But it is an excellent

8 standard, as it stands right now, to provide a very

9 high level of safety that does not exist. I urge you

10 to vote no. Thank you.


12 please.

13 EDDIE GEDRY: Eddie Gedry, representing myself.

14 Motion to call the question.


16 (applause)



19 number of people remaining at microphones, waiting to

20 speak. But we'll proceed with the vote on the call of

21 the question. Do we have --

22 UNIDENTIFIED SPEAKER: I, I --

23 JAMES QUITER: -- a second?

24 UNIDENTIFIED SPEAKER: I rise to a point of

25 order. Given the number of people that are standing



291

1 in line to speak, can we continue?

2 JAMES QUITER: No. This is a non-debatable

3 issue. We take the vote, and then we find out what

4 happens.




8 JAMES QUITER: Do we have a second?






14 support of the motion, which is to call the question,





19 The results of the vote are: 548 yes, in

20 support of the motion to call the question; and 112

21 against the motion to call the question. The motion

22 to call the question has passed, which brings us back

23 to 855-12.


25 motion on the floor is to Return the Entire NFPA



292

1 Standard. To vote, touch the 'vote' button. If you

2 wish to vote in support of the motion, and recommend



5 Screen Two, touch 'No'. Please record your vote.



8 (applause)






14 Seeing none, we will move on to the next documents.

15 Thank you, Mr. Biggins.

16 JAMES BIGGINS: Thank you, Mr. Chair.

17 (applause)

18 JAMES QUITER: Only 53 left.

19 (laughter)

20 JAMES QUITER: The last report under

21 consideration is that of the Correlating Committee for

22 the National Electrical Code. Here to present the

23 Report is Correlating Committee Chair, Michael

24 Johnstons of NECA, Bethesda, Maryland. The Report,

25 that is the First and Second Draft Reports, is located



293

1 on the Document Information Page for NFPA 70 on the

2 NFPA website. All Certified Amending Motions are

3 contained in the NFPA Technical Meeting (Tech Session)

4 Agenda, and will be displayed behind me on the screen

5 as they are under debate.

6 We have several National Electrical Code Chairs

7 that will be stepping down due to the tenure policy.

8 They are: Michael Johnston, NEC Correlating Committee

9 Chair; Mark Hilbert, Panel 2; Nathan Phillips, Panel

10 5; Larry Cogburn, Panel 8; Dave Humphrey, Panel 9;

11 Julian Burns, Panel 10; Larry Todd, Panel 15; Tom

12 Moore, Panel 16; Donny Cook, Panel 17; and Bobby Gray,

13 Panel 18. Please join me in thanking all of these

14 Chairs for their leadership.

15 (applause)

16 JAMES QUITER: Mr. Johnston, will you present

17 the Chair Report.

18 MICHAEL JOHNSTON: Thank you, Mr. Chair. Mr.

19 Chair, ladies and gentlemen, the Report of the

20 Correlating Committee on the National Electrical Code

21 is presented as found in the NEC First Draft Report,

22 and the NEC Second Draft Report for the 2019 annual

23 revision cycle. The Correlating Committee and panels

24 have published a First Draft, and Second Draft Report

25 consisting of revisions to NFPA 70, the National



294

1 Electrical Code. The revisions were submitted by

2 letter ballot of the responsible panels. The reports

3 and ballot results can be found on the Next Edition

4 tab of the Document Information Page for NFPA 70, at

5 www.nfpa.org/70Next.

6 Mr. Chair, I move for Standards Council


8 JAMES QUITER: Thank you, Mr. Johnston. Let's


10 Amending Motion on NFPA 70-1. Microphone four,

11 please.

12 DANIEL MIKAT: Good afternoon. I am Daniel

13 Mikat. I represent Toyota Motor North America, and 23

14 other automotive manufacturers, the Alliance of

15 Automakers, Global Automakers, and Society of

16 Automotive Engineers. I move to Reject an

17 Identifiable Part of Second Revision No. 7891.






23 proceed with the discussion on the motion. And again,

24 repeat your name, and affiliation first.

25 DANIEL MIKAT: Thank you. I am Daniel Mikat,



295

1 from Toyota Motor North America, and again I represent

2 23 other automotive manufacturers, the Alliance of

3 Automakers, Global Automakers, and Society of

4 Automotive Engineers. And I'm speaking in favor of

5 the text revision indicated in 70-1.

6 So this text was made in order to protect

7 premises electrical systems from reverse energy flow

8 from a vehicle, through an electrical vehicle supply

9 equipment. However, the text under 90-2, line 6, has

10 the potential of creating confusion in the automotive

11 industry, and whether the scope includes onboard power

12 outlets as power export equipment.

13 An onboard power outlet in the vehicle can't

14 connect to the premises, and therefore present no

15 safety concern to premises or infrastructure. The

16 automotive manufacturers are deeply committed to high

17 quality and safe function of the power outlets on the

18 vehicles. The concerns with the text on line 6 is

19 that interpretation might include outlets that will

20 never be connected to premises or infrastructure.

21 Further, the following section, in 625.60

22 specifically lists requirements for on vehicle power

23 sources that can't be connected to infrastructure.

24 Including requirements for automotive applications is

25 in direct conflict with the Scope Statement in 90-2,



296

1 which indicate that automotive vehicles are excluded

2 from this scope. It's not sensible to include

3 conflicting language in this document, where

4 automotive applications for exporting power are

5 included in line 6, but excluded in 90-2.

6 This interpretation is not in keeping with the

7 real intention of the code-making panel, and as such,

8 should be stricken as indicated in the motion on the

9 screen. Thank you.

10 JAMES QUITER: Thank you. Mr. Johnston, would

11 you like to offer the panel's position?

12 MICHAEL JOHNSTON: Thank you, Mr. Chair. Under

13 its responsibilities for scopes within the NEC, the

14 Correlating Committee reviewed revisions to the scope

15 of 90.2(A). The Correlating Committee found no

16 conflicts or correlation issues in either revision

17 that resulted in the 2020 NEC development process.

18 And I'd like to defer to microphone two, to the Chair

19 of Code Panel 1, who handles Article 90 in the code -

20 Kenneth Boyce.

21 KENNETH BOYCE: Thank you, Mr. Chair. I'm Ken

22 Boyce, Principal Engineer Director at UL LLC, and I

23 have the privilege of serving as the Chairman of NEC

24 Code-Making Panel 1. I speak in opposition to the

25 motion.



297

1 CMP 1 took action to add a new phrase to the

2 scope of the NEC in Section 90.2(A) to clearly

3 indicate that V2X (phonetic) installations used to

4 export electric power from vehicles to premises

5 wiring, or for bidirectional current flow, are indeed

6 covered under the scope of the NEC.

7 In the First Draft stage, the panel supported

8 this concept, but deemed that there was no need to add

9 the statement, because these installations are already

10 under the scope of the NEC, based on 90.(A)(3)

11 regarding the supply of electricity.

12 In the Second Draft stage, the panel

13 reconsidered the need for enhanced clarity, based on

14 the public comment, and added the new phrase, as

15 90.2(A)(6). All returned votes were in the

16 affirmative, reflecting the panel's strong alignment

17 on this issue.

18 The explicit inclusion of these installations

19 in the scope of the NEC correlates to the actions

20 taken by CMP 12 for Article 625. It also correlates

21 to the longstanding position of CMP 1 that these types

22 of electrical applications are covered by the NEC.

23 The purpose of the NEC, as clearly stated in Section

24 90.1(A) is, quote, 'The practical safeguarding of

25 persons and property from hazards arising from the use



298

1 of electricity.' End quote.

2 The inclusion of these types of interconnected

3 electrical applications in the purview of the NEC was

4 overwhelmingly reinforced by CMP 1 several cycles ago,

5 in affirming that the use of portable generators to

6 provide power to electrical systems and equipment is

7 covered under the scope of the NEC. As electricity

8 export technologies are increasingly being deployed in

9 vehicles for various uses by the public, the vehicles

10 essentially function as portable generators.

11 The NEC comprises a carefully coordinated

12 system for safety of electrical supply and usage,

13 including consideration for topics such as overcurrent

14 protection, ground fall protection, and receptacle

15 requirements. Electrical devices and utilization

16 equipment are designed and certified, based on the

17 expectation of that type of coordinated protection

18 being provided.

19 Code-Making Panel 1 clearly supports that the

20 safety of these vehicle electrical power export

21 applications is under the scope of the NEC, and acted

22 decisively to specifically clarify that - again, to

23 provide the practical safeguarding of persons and

24 property from hazards arising from the use of

25 electricity. Thank you.



299


2 five.

3 JIM TARCHINSKI: Good afternoon. My name is

4 Jim Tarchinski. I represent SAE International, and I

5 would like to speak for the motion on the floor.

6 First, let me say that I also work for General

7 Motors, and I am part of Code-Making Panel 12 for the

8 NEC. I, I think we should vote for this motion on two

9 primary grounds. First, the second part of the phrase

10 for bidirectional current flow - that already covers

11 equipment that's unidirectional, so I think that would

12 already be covered, as long as it's connected to the

13 grid.

14 The second main issue I have is the use to

15 export electric power is overly broad. It would

16 include five volt outputs, or 12 volt outputs, which

17 is not in the interest of safety. There is no known

18 need to cover low power devices like that. And

19 therefore, you should reject - I'm sorry. You should

20 vote for this motion, to remove Item Six from this

21 list. Thank you.


23 two.

24 JOHN KOVACHIC (phonetic): Thank you, Mr.

25 Chairman. I'm John Kovachic, with Underwriters



300

1 Laboratories, and I speak representing UL, and I'm

2 speaking against the motion.

3 This issue resides in the electric vehicle

4 acting and serving as a branch circuit, but - but

5 without being held to the same NEC rules as other

6 branch circuits. There is a concern with any

7 certified equipment, UL or any third party

8 certification, when such equipment is connected to an

9 electric vehicle, and what effect this has on the

10 certification of that equipment. For example, an

11 appliance is protected by the overcurrent devices in

12 the electrical infrastructure of the building where

13 installed, when certain fault conditions occur. When

14 connected to an electric vehicle, that same appliance

15 may not be provided with the same or equivalent

16 protection, when those same fault conditions which can

17 occur, do occur.

18 During the Code Panel 12 Second Draft meeting,

19 the automobile industry representatives specifically

20 stated that the vehicle cannot protect the equipment

21 connected to it, and it is the responsibility of the

22 equipment to protect itself when it is connected to

23 the vehicle. As a result, this will have a negative

24 effect on all products that have traditionally relied

25 upon overcurrent protection in the electrical



301

1 infrastructure of a building, to meet the electrical

2 safety requirements of the NEC.

3 Ignoring the consequences of connecting a

4 product to an electric vehicle, and using the vehicle

5 as a source of supply, would be a mistake. Going

6 forward, UL supports working with the automotive

7 industry to develop requirements necessary to ensure

8 adequate protection of products when connected to, and

9 supplied by electric vehicles. Thank you.


11 four, please.

12 WILLIAM FISKE: Thank you, Chairman. I am

13 William Fiske. I am employed by Intertek, and I am a

14 former member of NEC Panel 1, which we're covering

15 here. But I am speaking for myself. The gentleman

16 from GM who --

17 JAMES QUITER: For or against --

18 WILLIAM FISKE: -- talked --

19 JAMES QUITER: -- the motion?

20 WILLIAM FISKE: I'm - and I am in, in, in the


22 JAMES QUITER: Opposition to the motion?

23 You're at the wrong mic. But go ahead.

24 WILLIAM FISKE: Okay. The, the gentleman from

25 GM mentioned the power outlets in the, in the



302

1 automobile, and - but he conveniently overlooked where

2 it says 'export electric power from vehicles to

3 premises wiring systems'. None of those things that

4 are in the vehicle export power to the premises wiring

5 system, except for the charging port itself.


7 two.

8 SCOTT CLINE: I'm Scott Cline, representing

9 NECA, and I'm Chair of the NEC Code-Making Panel 12,

10 which is responsible for Article 625, Electric

11 Vehicles. I speak against this motion.

12 Although 90.2 is not a section within the

13 purview of my panel, the subject at hand directly

14 affects my panel's Article 625 responsibilities.

15 Because this motion, and then several more regarding

16 Article 625 are to follow later, and have the same

17 general concept in common, please hear me now. Much

18 of what I will bring up will also apply to these

19 upcoming 625 motions.

20 The NEC does not want to regulate the use of

21 electricity within a vehicle used for the purposes of

22 transportation. However, we do need to include

23 regulations for electrical power receptacles intended

24 to be used while the vehicle is stationary. To be

25 clear, we are talking about providing power which is



303

1 equivalent to many household circuits and portable

2 generators; indeed, many could easily provide a 120-

3 250 volt, 50 amp circuit. The electricity provided

4 does not know where it comes from, nor does it care

5 what it goes through to complete the circuit. If it

6 goes through a human body to do so, it will be a

7 killer without remorse. The automotive people are

8 asking us to trust them that their own internal

9 systems will provide the necessary levels of

10 protection. The aircraft manufacturers of the 737 Max

11 also determined that it was safe, but it wasn't.

12 The vehicle manufacturers choose to offer

13 options which turn the vehicle into a non-

14 transportation power supply system. The options need

15 to comply with the NEC. The scope is not a one line

16 declaration of coverage which may never be changed.

17 When available technology comes into being which

18 presents electrical hazards, then the NFPA has a

19 responsibility to consider if regulations for public

20 safety are needed.

21 The regulations which Code-Making Panel 12

22 required after comprehensive discussions do not impede

23 the safe use of vehicles for transportation. They do

24 not impede the safe use of vehicles for providing

25 power to a dwelling. They do not impede the safe use



304

1 of vehicles for stationary use as a power generator.

2 We only want it done safely. Please vote no on this

3 motion.



6 Part of Second Revision No. 7891. Mr. Johnston, do

7 you have any further comment?

8 MICHAEL JOHNSTON: Nothing further, Mr. Chair.










18 Voting is closed.





23 As we announced earlier, far earlier, we have

24 reordered the next two motions so that they will be

25 discussed in paragraph or section order. Discussions



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1 on Motions 70-2 will be heard after Motion 70-36.

2 Discussions on Motions 70-3 will be heard after Motion

3 70-40.

4 Therefore, let's now proceed with the

5 discussion on Certified Amending Motion 70-4. Given

6 we just jumped some, I'll give it a moment.

7 HOWARD HERNDON: Dealing with the scrolling

8 here.

9 JAMES QUITER: I'm glad you said that, because

10 I didn't even see you.

11 HOWARD HERNDON: Oh.

12 JAMES QUITER: Okay. Microphone four, when

13 you're ready.

14 HOWARD HERNDON: I'm Howard Herndon,

15 representing the 75 PEARL dealers in the United States

16 and Canada, and would like to move to accept Motion 70

17 - 70.4.

18 JAMES QUITER: Which --

19 HOWARD HERNDON: 8072.

20 JAMES QUITER: So if you read the second screen

21 here, the middle screen, go on to say what that motion

22 is.

23 HOWARD HERNDON: That motion is to Reject the

24 Information Given in Article 100 Concerning a

25 Reconditioning.



306

1 JAMES QUITER: Okay. So what you're doing is

2 making a motion to Reject Second Revision No. 8072.

3 HOWARD HERNDON: That's correct.

4 JAMES QUITER: Thank you. Is there a second?


6 JAMES QUITER: I - we do have a second. So

7 please proceed with the discussion on the motion,

8 again, beginning with your name and affiliation.

9 HOWARD HERNDON: I'm Howard Herndon,

10 representing PEARL, and I am in - for the motion. The

11 definition for reconditioning here was obviously not -

12 it's not consistent with other ANSI and industry

13 standards, and would like to see consistency between

14 the industry and ANSI standards, as well as make it

15 enforceable language. If you look at the terms of

16 rebuilt, refurbished, or remanufacturing, they have

17 many different meanings in many different industries,

18 and especially the electrical industry, and these are

19 not consistent with the word 'reconditioning'.


21 you like to add the Committee comment?

22 MICHAEL JOHNSTON: Thank you, Mr. Chair.

23 Certified Amending Motion 70-4 seeks to delete the

24 definition of reconditioned. At the completion of the

25 Second Draft ballot, the NEC Correlating Committee was



307

1 faced with three definitions of the same term. These

2 three definitions came from three different code-

3 making panels that were dealing with this in the

4 process.

5 Under its responsibility to correlate and

6 resolve conflict in the NEC, the Correlating Committee

7 chose a definition that was supported through

8 consensus of three code-making panels. The NEC

9 Correlating Committee also reviewed the complete

10 record of both associated public inputs, and comments

11 to insure that there was no new material being

12 introduced. The Correlating Committee that there was

13 no new material introduced. And just as a side note,

14 Public Input 2935 had global impact throughout the

15 entire NEC, and could not be handled by a single rule

16 in Chapter One.

17 I'd like to defer to the Chair of Code-Making

18 Panel 10 to add some technical explanation to this.

19 I'm not sure which mic he's at, because it's difficult

20 to see.

21 JULIAN BURNS: I could actually be at two

22 different mics, Mike. This is Julian Burns, Chairman

23 of Panel 10. I'm at mic five.

24 MICHAEL JOHNSTON: Okay. I see you now.

25 (laughter)



308

1 MICHAEL JOHNSTON: This noise was coming from

2 back here. Pay no attention that person behind here.

3 JULIAN BURNS: CMP 10 has purview of this,

4 believe it or not. We have technical people that

5 serve on CMP 10 that work in the industry, that also

6 reconditions equipment. We spent laborious time

7 working on a definition that would comply with many

8 different avenues. You're going to hear from me again

9 about other reconditioned equipment.

10 However, this is done in the environment of

11 electrical industry on a daily basis. However, there

12 is only certain types of equipment that can be

13 reconditioned - i.e., you cannot recondition a molded

14 case circuit breaker. However, there are larger frame

15 breakers that can be reconditioned. So during this

16 process, we developed the definition that is on the

17 screen at this point in time.

18 However, we think we have purview of it; it

19 better fits in the definitions of 100. So this is

20 done every day. This is not something new. Thank

21 you.




25 support of, or against the motion. Microphone two,



309

1 please.

2 JIM DOLLARD: Thank you, Mr. Chairman. My name

3 is Jim Dollard, representing the International

4 Brotherhood of Electrical Workers, and I rise in

5 opposition to the motion on the floor.

6 This is a significant issue that has a

7 significant impact on safety. And for that reason,

8 part of my comments will be read from a written

9 statement.

10 I would like to take this opportunity to

11 explain to this body, and to document in the

12 transcript for Standards Council, that this public

13 comment and all other associated public comments do

14 not contain new material. Public Input 2935 was

15 resolved by CMP 1 in the First Draft stage. Public

16 Input 2935 was in play for all related public

17 comments, as per the regulations governing the

18 development of NFPA Standards. Public Input 2935 was

19 submitted to Section 110.21 located in Chapter One,

20 Section 90.3 details code arrangement in the NEC, and

21 very clearly explains that requirements in Chapter One

22 have a global impact over all electrical products, and

23 installations in the NEC, in Chapters One through

24 Seven. Public Input 2935 would have - would have

25 required all reconditioned equipment to be listed.



310

1 That is extremely significant, and could have had a

2 major impact on the entire NEC. There are products

3 that can be reconditioned, and there are products that

4 cannot be reconditioned. This was recognized by the

5 NEC Correlating Committee as an extremely significant

6 issue that needed correlation. Therefore, a

7 Correlating Committee Task Group was formed to submit

8 global comments to instruct each code-making panel to

9 make this determination on a case by case basis,

10 because a single general requirement in Chapter One

11 could have a significantly negative impact.

12 Public comments addressing reconditioned

13 equipment through Public Input 2935 do not represent

14 new material. This public input would have required

15 all reconditioned equipment to be listed. This would

16 mean that a field evaluation of all reconditioned

17 electrical equipment would be necessary in all cases,

18 which is extremely significant. This public input

19 addressed requirements in Chapter One, and had a

20 global impact. This public input was available for

21 public review in the NFPA consensus process, as were

22 the comments. The proponents of these CAMs had the

23 opportunity to review that public input, and to review

24 the comments. Lack of involvement in the - in the

25 NFPA consensus process does not constitute new



311

1 material. Thank you.


3 three - or number four, please.

4 CHRIS HUNTER: Thank you. Chris Hunter with

5 Serra (phonetic) Wire, speaking in support of the

6 motion. I was involved in the process - oh, was

7 involved in the process, and did submit public inputs,

8 and public comments.

9 Unfortunately, I think the definition that came

10 out of the process is confusing. If you look at the

11 very first sentence - electromechanical systems,

12 equipment, apparatus, or components that are restored

13 to operating conditions. If I switch on a light, I

14 have restored a luminaire to operating conditions. If

15 I start up a motor, I've restored it to operating

16 conditions. It doesn't really tell us anything about

17 the substance of reconditioning electrical equipment,

18 unlike many more descriptive definitions that are in

19 published industry standards that specifically address

20 reconditioned and remanufactured equipment.

21 The second sentence of the definition is also

22 confusing. The NEC Style Manual states that the NEC

23 shall not contain references or requirements that are

24 unenforceable, or vague. In that list of possibly

25 vague or unenforceable terms is the word 'normal'



312

1 which is used in this definition. The definition says

2 that reconditioning differs from normal servicing

3 equipment, of equipment that remains within a

4 facility. But what is normal servicing? Well, if we

5 look back at the 2017 NEC cycle, the code-making panel

6 said that they considered that replacing a fuse, or

7 circuit breaker, or similar work as normal servicing.

8 So the implication is that anything beyond that is now

9 not normal servicing, but instead, reconditioning.

10 And that's true even if it occurs within the facility

11 where the equipment is located.

12 The last part of the sentence - again,

13 puzzling. It says that reconditioning does not

14 include the replacement of listed equipment on a one

15 to one basis. If - and that makes sense, because you

16 would never have thought that replacing, say, a listed

17 receptacle with another listed receptacle would be

18 reconditioning. But what if you have a control panel,

19 and you replace a recognized component with another

20 recognized component. Is that reconditioning? Is

21 that normal servicing? What if you replace a part

22 that's not even required to be listed. Is that

23 equipment now reconditioned? If it is, 110.21 will

24 require the removal of the original listing mark, and

25 application of a reconditioning label. I see no



313

1 justification for that.

2 We can have a good definition. This just

3 doesn't meet the needs of the code at this point.

4 Thank you for your time. I support the motion on the

5 floor.


7 three, please.

8 EDDIE GEDRY: Eddie Gedry, representing

9 Associated Builders and Contractors. Mr. Dollard - I,

10 I'm sorry. I'm speaking against the motion. And Mr.

11 Dollard, and Ms. Hunter brought up some very valid

12 points. I, I don't really - I'm not in love with the,

13 the words that were used here, that came out of the

14 process. But having been on Code Panel 11 for the

15 last 20 years, I also know that it has - it goes

16 through the process where - of public review and

17 everything else, and, and lots of thought and hours

18 are put into the process, and everybody probably in

19 this room is aware of that.

20 Having said that, there's lots of other

21 Certified Amending Motions that are going to be

22 considered in the next, hopefully just a few hours,

23 but --

24 (laughter)

25 EDDIE GEDRY: -- related to this reconditioning



314

1 topic. And the, the, the thing is, most of the work

2 that I have done for the last 40 years has been in

3 industrial environments. And there's a need to

4 recognize the fact that some of this gear is 30, 40,

5 50, or - years or older, and it has to be

6 reconditioned, as you can't buy replacement parts.

7 The only other option is to go out and buy all new,

8 and that gets cost prohibitive at times, if you had to

9 go out and replace a whole lineup of medium switch

10 gear, for instance, instead of reconditioning it.

11 So when we're talking about these other topics

12 related to the reconditioning, I would like to just

13 remind everybody that yes, in a perfect world it would

14 be great if, instead of reconditioning equipment, to

15 replace everything with all new, but it's just not

16 possible. So keep that in mind when, when these other

17 topics come up.

18 And yes, I agree with Ms. Hunter that, that I

19 do not love this wording. But in three years - yeah,

20 I don't think it does any harm the way it is now. And

21 in three years, we get another shot to, to, to massage

22 it a little bit more. Thank you.


24 one, please.

25 DAVE DEGENAIS: Dave Degenais, speaking on



315

1 behalf of the Healthcare Section, in favor of this

2 motion. The Healthcare Section met at their annual

3 Board meeting yesterday, and decided to speak in favor

4 of this motion. We do believe there's a need for a

5 definition with reconditioning, and let's - let's just

6 say it the way it is. This sets the foundation for

7 20-plus additional motions that are going to take

8 place this evening, or late into this evening, I

9 should probably say. So it's important that this be

10 right. We think there's a need for a definition. We

11 support a definition, but this is not it. This

12 definition provides confusion. It is inconsistent

13 with the other industry definitions. It's just going

14 to confuse, and it's going to set a poor foundation

15 for the concept for reconditioning.

16 The previous speaker spoke about the need for

17 reconditioning. I think everyone acknowledges there

18 are certain components that can be reconditioned, and

19 certain components that can't. But if we're going to

20 base the premise on what applies to reconditioning

21 with a definition, this is not the one. We urge you

22 to vote in favor of this motion.


24 please.

25 BARRY RODGERS: I'm Barry Rodgers. I represent



316

1 Schneider Electric. Schneider Electric is against

2 this motion. Schneider Electric supports the action

3 taken by the Code Panel to include this language.

4 Safety is the major reason to adopt these changes.

5 Schneider Electric states that reconditioning without

6 in depth knowledge of the technology, and product

7 standards used to the manufacturer - to design and

8 manufacture the product can pose a safety risk to

9 people. Reconditioning standards alone are not

10 sufficient to understand all the different aspects of

11 the design of the product.

12 Schneider Electric provides services for

13 reconditioning, rework, repair, maintenance, and

14 normal service. Schneider Electric opposes this CAM,

15 and supports the language as proposed in the 2020 NEC.

16 Schneider Electric believes the information as

17 proposed in the 2020 NEC is clear, and provides the

18 necessary information. My safety concern includes

19 safety of workers, as well as safety of occupants in

20 facilities. I urge you to vote against this motion.


22 three, please.

23 MIKE STONE: Mike Stone, representing the

24 National Electrical Manufacturers Association, and I

25 also represent NEMA on Code-Making Panel 1. And NEMA



317

1 is opposed to this motion to reject - excuse me - to

2 Reject this Second Revision 8072. Thank you.


4 please.

5 ROBERT OSBORNE: Robert Osborne, Principal

6 Engineer, representing UL, and I am speaking in


8 One comment that I have heard twice since I've

9 been up here is this idea that there's confusion

10 behind, and there's concerns with this definition.

11 One thing I would like to point out is that this was

12 the definition that was - that was developed and

13 submitted by three different code panels.

14 So one of the tasks of the Correlating

15 Committee, which I sit on, was to determine which of

16 the definitions, as there was a fourth definition from

17 Code Panel 1 that was also submitted. So there was

18 this task of determining which of the definitions

19 would be used, and, and the definition chosen, if, if

20 it is confusing, it is one that came from there

21 different code-making panels. So it has a lot of, of

22 input from technical experts.

23 Reconditioned equipment was a term introduced

24 in the 2017 code. And regardless of actions taken on

25 other CAMs related to reconditioning, and we know



318

1 there's quite a few of them coming up, this is a new

2 definition that needs to remain, as reconditioning is

3 part of the NEC; it has been since 2017. The term is

4 needed to help an AHJ identify what is reconditioned

5 equipment, including other terms noted in the

6 Informational Note, as there's other terms such as

7 rebuilt, refurbished, remanufactured.

8 The definition also incorporates concepts of

9 servicing equipment that remains within a facility.

10 And an earlier speaker pointed to that particular

11 statement in this definition. But keep in mind, this

12 has its origins from Section 1.10.21(A)(2)

13 Informational Note No. 1. So the idea of normal

14 servicing of equipment that remains within a facility

15 has already been established, and been accepted from

16 the 2017 code.

17 So as reconditioned equipment gains more

18 prominence in the code, it is important that an, an

19 Article 100 definition is adopted. Thank you.


21 please.

22 LARRY AYER (phonetic) Yes. My name is Larry

23 Ayer. I am Chair of IEC Codes and Standards, and I am

24 here speaking against the motion.

25 Certain - as has been mentioned before, certain



319

1 electrical products cannot be reconditioned, and other

2 products can. For those products that can be

3 reconditioned, for safety reasons, they, they must be

4 reconditioned according to consensus, or manufacturing

5 standards to make sure they function as intended. The

6 NEC has been silent on this issue in the past. For -

7 we have made numerous revisions during this cycle, and

8 they have been accepted into the 2020 cycle to define

9 what reconditioning is, and what it is not, and what

10 products can and cannot be reconditioned. It is

11 important that this definition, and all other

12 revisions on this topic, be accepted into this

13 document. We urge you to vote against this motion.

14 JAMES QUITER: Okay. I'm going to go to three

15 one more time.

16 DAVID HUMPHREY: Yes. I'm David Humphrey, I am

17 representing myself, and I rise in opposition to the

18 motion. As an AHJ, we have desperately needed a

19 definition for reconditioned equipment for some time.

20 This definition will help enormously with the process

21 of being able to identify accurately reconditioned

22 equipment. It's very important. Kicking the can down

23 the road for three more years in order to tweak a few

24 words will not help the industry; it will not help the

25 AHJs around the country, or the people who wish to use



320

1 reconditioned equipment. Thank you.


3 please.


5 International, and I call the question.



8 UNIDENTIFIED SPEAKER: Dad-gum-it. I knew it.

9 (laughter)

10 UNIDENTIFIED SPEAKER: I knew it.


12 to call the question.

13 (laughter)

14 JAMES QUITER: I notice that there were a


16 to speak --


18 JAMES QUITER: -- but we'll proceed with the

19 vote on the call of the question. Do we have a

20 second?

21 UNIDENTIFIED SPEAKERS: Second. Second.



24 bottom of your tablet to vote. If you wish to vote in




321

1 vote against the motion, touch 'No'. Please remember,

2 this is voting only on the motion to call the

3 question. Please record your vote.




7 the motion to call the question; and 33 against the

8 motion to call the question. The motion has passed -

9 which brings us back to Motion 70-4, to Reject Second

10 Revision No. 8072.

11 If you wish to vote in support of the motion,




15 vote.







22 Let us now proceed with the discussion on


24 four, please.

25 HOWARD HERNDON: Again, I'm Howard Herndon,



322

1 representing the Professional Electrical Apparatus

2 Reconditioners League, OR PEARL, and I make a motion

3 (unintelligible) --

4 JAMES QUITER: Well, hold, hold on just a

5 minute.

6 UNIDENTIFIED SPEAKER: (unintelligible) five.

7 JAMES QUITER: This was 70-5. Is that what you

8 were on?

9 UNIDENTIFIED SPEAKER: 70

10 UNIDENTIFIED SPEAKER: (unintelligible) 75.


12 JAMES QUITER: I'm looking for Thomas Bishop,

13 as --

14 THOMAS BISHOP: That's me.

15 JAMES QUITER: Okay. Thank you.

16 THOMAS BISHOP. Okay.

17 JAMES QUITER: Go ahead.

18 THOMAS BISHOP: We have very similar

19 submittals, so I think that's the reason for the, the

20 confusion.

21 Okay. My name is Thomas Bishop with the

22 Electrical Apparatus Service Association, and I'm in

23 favor of this motion to --

24 JAMES QUITER: First, you've got to make the

25 motion.



323

1 THOMAS BISHOP: Oh. Sorry. I make a motion

2 that we Reject an Identifiable Part of the Second

3 Correlating Revision No. 71.



6 Correlating Revision No. 71. Is there a second?


8 JAMES QUITER: Say it louder.


10 JAMES QUITER: Thank you. We do have a second.

11 Please proceed with the discussion on the motion. And

12 again, start by - with your name and affiliation.

13 THOMAS BISHOP: Thomas Bishop, Electrical

14 Apparatus Service Association, and I'm in favor of

15 this motion. And what this relates to, it, it - one

16 of the primary things is the, the requiring of the

17 listing mark removal that's been added to this

18 section. And if, if we do that, you know, it brings

19 up a number of implications. But one of the things

20 that, when I look back through the records of, of how

21 this came about, in the First Draft Revision, Public

22 Input 2935, anyway, the statement was made that the

23 presence of the original certification mark on

24 reconditioned equipment suggests to the installer and

25 the AHJ that the equipment is compliant with the



324

1 product safety standard related to that equipment.

2 In reality, the actual compliance with the

3 related safety standard is unknown. To me the - you

4 know, the above statement is fundamentally flawed, in

5 that it applies to all installed equipment. Well,

6 once you put a piece of equipment in, the listing mark

7 - the way I would read this - the listing mark is no

8 longer applicable. Maybe there should be, you know,

9 like a tear-off tab on it. There - it just - it, it

10 just, like I say, it defies my imagination, but -

11 compliance to the original manufactured state. You,

12 you don't know what that original manufactured state,

13 whether that's been preserved, once that piece of

14 equipment's been installed.

15 So the, the listing mark, the manufacturer's

16 mark, you don't know what that's about. And if you

17 try and take that listing mark off, basically you're

18 going to have to deface that labeling that's on that

19 machine. And now you have, you know, a potential

20 legal issue, as I see it, between an end user and the

21 person who's doing that service work, or that

22 reconditioning - because they're going to say, 'You've

23 defaced this nameplate. You've destroyed -

24 especially, you've destroyed historical information.'

25 Now we can't trace back to, you know, information



325

1 about the original listing mark. So you know, that,

2 that's part of the issue here.

3 The main paragraph of the exception in this

4 statement ends with a statement that is, that, that is

5 reconditioned by the owner or operator as part of a

6 regular equipment maintenance program. That the

7 exception allows someone who's working for the owner,

8 who works for the owner of the equipment, to do work

9 on that machine, essentially reconditioning. But if

10 it's someone who's a professional in reconditioning

11 electrical apparatus, they're not allowed to work on

12 it.

13 And, and then it brings up, to me, a gray area

14 of, well, what about when you are the owner of the

15 equipment, and you hire someone out, you embed

16 material from another organization to be your in-house

17 maintenance work. But where does that fall? Does

18 that fall within, or without, you know, outside of the

19 scope of this.

20 So - and my just - one last thing is

21 Informational Note No. Two is new text that wasn't

22 identified as new text. It wasn't new text - it

23 didn't exist in the 2017 edition, but now it's shown

24 here as though it did. So - thank you.




326

1 you like to offer the Panel's position?


3 Second Correlating Revision 71 did effect this, so I

4 will address the Correlating Committee's activity.

5 The text was revised by the Correlating

6 Committee in, in Second Correlating Revision 71. Note

7 that their action deleted the second sentence of

8 Informational Note No. 1 because it contained a

9 recommendation. That's in violation of the NEC Style

10 Manual, which the Correlating Committee is responsible

11 for. This text had been already included in the 2017

12 edition of the NEC. However, with the new definition

13 being placed in Article 100, and new Informational

14 Note, this sentence, in this - and this Informational

15 Note is now extraneous.

16 And I'd like to defer to the Chair of Code

17 Panel One, Ken Boyce.

18 JAMES QUITER: I believe he's at mic two.

19 KEN BOYCE: Thank you, Mr. Chair. Ken Boyce,

20 ULC - UL LLC, Chairman of Code-Making Panel One. I

21 speak in opposition to the motion.

22 As Mike Johnston stated, the Correlating

23 Committee removed the last sentence of Informational

24 Note One in concert with the addition of a new

25 definition in Article 100.



327

1 CMP 1 added the requirement that the original

2 listing mark of the equipment is to be removed when

3 reconditioned. This is consistent with the conceptual

4 approach that has been in Section 110.21(A), that the

5 approval of the reconditioned equipment shall not be

6 solely based on the equipment's original listing.

7 Once the equipment is reconditioned, the party

8 performing the reconditioning is responsible for

9 addressing necessary actions related to approval

10 associated with the reconditioning. The original

11 listing which applied to the product as it left its

12 original point of manufacture, is no longer applicable

13 after reconditioning. The continued compliance of the

14 product with the applicable requirements, which is the

15 basis for the original listing, is no longer known.

16 Therefore, CMP 1 introduced the new requirement

17 to remove the original listing mark associated with

18 the reconditioning to promote clarity relative to the

19 approval process for the equipment. This approach was

20 overwhelming supported by CMP 1. We believe it marks

21 a significant progression in addressing the safety and

22 approval of reconditioned equipment. Thank you.






328

1 support of, or against the motion. Microphone one,

2 please.

3 CHRIS HUNTER: Thank you. I'm Chris Hunter

4 with Serra (phonetic) Wire, speaking in support of the

5 motion. Removing the original listing mark - it has

6 no value to the user of the code. The requirement in

7 110.21 already requires that reconditioned equipment

8 be identified as reconditioned; that - and then it

9 instructs the AHJ not to depend on the original

10 listing mark for approval. The listing mark on

11 switchboards, transformers, and other electrical

12 equipment is most often an integral part of the label

13 on the equipment that contains other necessary,

14 critical information about the characteristics of the

15 equipment. Quite often, these labels are permanently

16 applied, and the removal is time consuming, and it's

17 pointless. It, it provides no value. It can be

18 difficult or impossible to actually remove that

19 listing mark without destroying that critical

20 electrical characteristic information from the

21 equipment, and that can actually lead to a greater

22 hazard to anyone who has to work on that equipment in

23 the future and depends on that information to

24 determine what they're working on. I support the

25 motion on the floor. Thank you.



329


2 two, please.


4 Schneider Electric. We are against this motion. We

5 support the action taken by the Code Panel to include

6 this language. The listing mark notes that the

7 product meets appropriate standards, and found

8 suitable for its purpose. The removal of the mark

9 helps inform the user, and Code Enforcement, that the

10 equipment has been reconditioned, and may not meet the

11 requirements of the industry product safety standard.

12 I urge you to vote against this motion.


14 four.

15 RICHARD HOLUB: Richard Holub with DuPont,

16 representing the American Chemistry Council, and I'm

17 speaking for the proposal.

18 OSHA 29 CFR 1910.303 requires all electrical

19 equipment used in the workplace be approved. So by

20 taking this action to remove a listing mark, you're

21 actually shutting down a whole industry of motor

22 repair, unless you get all of your motors' repairs,

23 you know, third party listed. I don't see that

24 happening.

25 Fundamentally, we're creating a problem here



330

1 because we want to insulate, I guess, the NRTL

2 (phonetic) from, from any potential legal action down

3 the road. If you want to require, you know, that

4 third party reconditioners apply a new label to

5 indicate that this equipment has been reconditioned,

6 that's fine. But removing a listing mark creates a

7 problem with the OSHA language that we have today.

8 Thank you. I'd urge you --


10 RICHARD HOLUB: -- to vote against this.


12 RICHARD HOLUB: Or - I'm sorry - vote for this.


14 three, please.

15 BRIAN HOLLAND: Thank you. My name is Brian

16 Holland, and I'm with NEMA Codes and Standards,

17 speaking in opposition for CAM 70-5 - NEMA is opposed

18 to the Motion to Reject the Identifiable Part of

19 Second Correlation Revision No. 71. We ask you to

20 vote no on this motion, and keep the recommended text

21 that's identified in Screen Number Two. Thank you.

22 JAMES QUITER: Thank you. And again, to

23 microphone number three.





331



3 I'd like to make a couple of brief comments.

4 First, there was a - a - somebody mentioned that

5 Informational Note No. 2 was new material in the

6 Second Draft stage. That's not true. That was put in

7 with First Revision 8560. Comments to the fact that

8 you can't remove the listing mark without completely

9 damaging the equipment are not valid, not by any

10 stretch of the imagination. It's 2019. And it's easy

11 to obscure the listing mark. This is extremely

12 important. We're talking about equipment, like a

13 transfer switch, that may be necessary to transfer to

14 emergency power, okay. And you - we've got language

15 in there now that says you can't do that. We have

16 (unintelligible, inaudible).

17 UNIDENTIFIED SPEAKER: We've got a mic problem.





22 UNIDENTIFIED SPEAKER: Gotta stop the clock.

23 (laughter)

24 UNIDENTIFIED SPEAKER: Stop the clock.

25 (applause)



332


2 UNIDENTIFIED SPEAKER: Good stuff.


4 JAMES QUITER: Okay. Where are we?

5 UNIDENTIFIED SPEAKER: I think --

6 JAMES QUITER: I think the referee said you

7 gotta go back to three minutes.

8 (laughter)

9 UNIDENTIFIED SPEAKER: I think the referee

10 probably did not.

11 (laughter)


13 UNIDENTIFIED SPEAKER: It's an electrical

14 battery (unintelligible) --


16 JAMES QUITER: Thank you, Sir.

17 UNIDENTIFIED SPEAKER: Hey, we got Cisco in

18 here.



21 JIM DOLLARD: All right. Well, you know what,

22 I'm probably working with a reconditioned microphone.

23 (laughter)

24 (applause)

25 JIM DOLLARD: But we've got requirements that



333

1 are specifically - that specifically point out types

2 of equipment that we'll - we're going to be dealing

3 with CAMS on those later today. But we've got many

4 pieces of equipment that are addressed by the National

5 Electrical Code, that - we don't say that you can, and

6 we don't say that you can't. So the only requirement

7 would be if - is if somebody reconditions them, they

8 must remove the listing mark.

9 If you are the research and testing

10 organization, and the manufacturer, and you built that

11 product to the applicable standard, if somebody else

12 gets their hands in there after that equipment was

13 under water six months ago, and just puts it back into

14 service, the research and testing laboratory and the

15 manufacturer still own liability. If they want to do

16 that, if they want to recondition that equipment, let

17 them put their name on it, and take the listing mark

18 off. Thank you. I urge everybody to oppose the

19 motion on the floor.

20 JAMES QUITER: See, you didn't need three more

21 minutes. Microphone number three, please.

22 THOMAS DOMITROVICH: Oh.

23 JAMES QUITER: Yeah, that's you.


25 (laughter)



334

1 THOMAS DOMITROVICH: I thought - Robert's been

2 standing up there. I was just like, okay. So my name

3 is Thomas Domitrovich. I am with Eaton, and I am

4 speaking in opposition to the motion on the floor.

5 What - the, the, the motion on the floor and

6 the item that we're talking about right now has to

7 deal with transparency. And when you look at this,

8 this section of the Code, 110.21 and the marking

9 requirements, you have to also consider that there are

10 other requirements within the National Electrical

11 Code, including the definition, which we just

12 addressed, and they all work together.

13 So the marking requirement for removing the

14 reconditioned - removing the, the listing labelling -

15 the listing of the equipment, the marking, and

16 identifying the person, and the individual, or the

17 organization that is doing the refurbishing, which in

18 - in - as, as Eaton, we both manufacture new

19 equipment, and we do consider remanufacturing, or

20 reconditioning equipment, as well. So we do both of

21 these, these operations on equipment. And we ensure

22 that the transparency for the end user, who's going to

23 be purchasing and installing that equipment

24 understands exactly what they're receiving.

25 Remember that we're talking about electrical



335

1 safety equipment, including GFCIs, AFCIs, and other

2 technologies that are there to save lives and protect

3 property, which is the fundamental reason behind the

4 National Electrical Code. I urge everybody to support

5 - or to not support this 70-5. Thank you.

6 JAMES QUITER: Thank you. Microphone two.

7 ROBERT OSBORNE: Thank you. Robert Osborne,

8 representing UL, and speaking in opposition to the

9 motion.

10 The application of the listing mark is the

11 OEM's attestation that the product complied with

12 listing requirements at the time of manufacture. For

13 equipment that has been installed, possibly worn,

14 possibly damage, then taken out of service, sent to an

15 off-site facility for reconditioning, compliance with

16 the listing requirements can only be determined if

17 then reevaluated by a NRTL (phonetic) that is

18 qualified to apply the latest edition of the end

19 product standard, and then apply a new certification

20 mark, indicating that it has been certified as

21 reconditioned.

22 UL supports reconditioning, and has well over

23 100 listing programs to facilitate evaluation of

24 reconditioned equipment. When those products are

25 validated as being in compliance with the latest



336

1 edition of the standard, our policy is the original

2 listing remark is removed, and a new listing mark is

3 applied, identifying listing with an appropriate

4 identifier, such as, 'Rebuilt Electric Sign'.

5 Without a code requirement to remove the

6 listing mark, the end user, the AHJ, they see the mark

7 and assume that the product complies with the

8 applicable end product safety standard. This promotes

9 a false sense of security, as without recertification,

10 compliance is an unknown, and may lead to the use of

11 unsafe equipment. Thank you.

12 JAMES QUITER: Thank you. And microphone

13 number three, please.

14 DAVID HUMPHREY: Yes. David Humphrey,

15 representing myself, and I speak in opposition to the

16 motion. First of all, a statement was made earlier

17 about all products having to be approved. Approved is

18 acceptable to the authority having jurisdiction, and

19 has absolutely nothing to do with a listing mark.

20 Secondly, as an enforcer, when you go in the field to

21 do inspections, and you see a listing mark, generally

22 a lot of guys stop there. But if this is

23 reconditioned equipment, that's the mark that counts.

24 And there should be but one mark - that's the

25 refurbished or reconditioned mark. And then the



337

1 inspector may enforce his or her decision based on

2 that mark, and that mark alone.



5 Part of Second Correlating Revision No. 71? Mr.

6 Johnston, do you want to add anything?

7 MICHAEL JOHNSTON: I have no further comments,

8 Mr. Chair.


10 THOMAS BISHOP: Can I make one more comment?

11 It's Thomas Bishop from Electrical Apparatus Service

12 Association?

13 JAMES QUITER: Yes.

14 THOMAS BISHOP: But the rationale here --

15 JAMES QUITER: Say --

16 THOMAS BISHOP: -- that --

17 JAMES QUITER: -- say - you'd said that part,

18 but for or against --

19 THOMAS BISHOP: Okay. I'm for the motion,

20 okay. And, and the, the remark that was made from,

21 like the fellow from UL, that this applies to the

22 equipment at the time it was manufactured, and then

23 later on, we hear this statement about, well, it's

24 been reconditioned, then it needs to have a

25 recondition mark, and take off the label that says it



338

1 was built to the standard that it was built to, and it

2 was certified to that. That applies to every piece of

3 equipment. Once that machine, if it's five years old,

4 or three months old, or 10 years old - someone spoke

5 about a flood. Well, what if the machine was in a

6 flood, the equipment, and nothing was done, and they

7 turned it back on? That label is still there, and it

8 doesn't fall under reconditioning. If you're going to

9 say remove the label, then you better remove the label

10 when you install the equipment. Thank you.

11 JAMES QUITER: Okay. Thank you. I will make a

12 comment. I may have missed you, because it's hard to

13 see out there, but if not, please be at the mics and

14 ready when we're, when we're doing this. Mike, do you

15 want to respond to any of that?

16 MICHAEL JOHNSTON: I have no additional

17 comments --

18 JAMES QUITER: Okay.

19 MICHAEL JOHNSTON: -- Mr. Chair.

20 JAMES QUITER: So before we vote, let me


22 Reject an Identifiable Part of Second Correlating

23 Revision No. 71. To vote, touch the 'vote' button.

24 If you wish to vote in support of the motion, and

25 recommend the text on Screen One, touch 'Yes'. If you



339

1 wish to vote against the motion, and recommend the


3 vote.

4 Five seconds.






10 Before we progress with item 70-6, I have a

11 couple of announcements. One is we will be taking -

12 assuming we're still going, we'll be optimistic and

13 just say that - but assuming we're still going at six

14 o'clock, we will take a 30 minute break. That is

15 partially because concessions will close at 7 o'clock,

16 so if you need to get something to eat for the

17 remainder of the session, please do so during that 30

18 minute break. Also at this point, we will take a 15

19 minute break, and reconvene at 4:20. Thank you.

20 UNIDENTIFIED SPEAKER: Yeah, thank you.

21 (BREAK) (MUSIC)


23 JAMES QUITER: Okay. Let's now proceed with

24 the discussion on Certified Amending Motion 70-6.




340

1 HOWARD HERNDON: In light of the decision on

2 70.5, I withdraw this motion.


4 (applause)

5 JAMES QUITER: The motion on 70-6, which

6 appeared in our Agenda; however, the authorized maker

7 of the motion has notified NFPA that he no longer

8 wishes to pursue this motion. Therefore, in

9 accordance with NFPA Rules, Convention Rules at


11 assembly, and is removed from the Agenda.

12 We will now move on to the next motion, which

13 is 70-7. So let's proceed with the discussion on


15 please.

16 RICHARD HOLUB: My name is Richard Holub.

17 Represent DuPont, and the America Chemistry Council,

18 and I am here to speak in support of CAM 70-7 to

19 Reject an Identifiable Part of Second Revision 8104.

20 JAMES QUITER: Okay. I will take that as a

21 motion. Is there a second?


23 JAMES QUITER: Okay. We do have a second. The

24 motion is to Reject an Identifiable Part of Second

25 Revision No. 8104. Please proceed with the discussion



341

1 on the motion. And again, start with identifying

2 yourself again.

3 RICHARD HOLUB: Once again, Richard Holub with

4 DuPont, representing the American Chemistry Council,

5 speaking in support of this motion to Reject an

6 Identifiable Part of 8104.

7 The public comment that put this language in

8 the code was well intentioned, but while well

9 intentioned, it's had some unintended consequences.

10 The, the specific sentence that we want to reject is,

11 'Open equipment doors shall not impede the entry to,

12 or egress from the working space.' It's just that

13 single sentence.

14 And fundamentally, we're talking about large

15 equipment, and when large equipment - we're talking

16 about 1200 amps or greater, and over six feet wide.

17 And basically, when we have that condition,

18 110.26(C)(2) is going to require you to have two

19 entrances or methods to enter and egress that

20 workspace.

21 And the, the language here that was inserted

22 was intended to attack conditions where you have

23 equipment that has two doors, where they open in

24 opposite directions, and you could be working between

25 the two doors. And that's, that's great. But the



342

1 language that they inserted didn't state that.

2 So basically, what the consequence is, is now

3 on the back of your switch gear, when you have a

4 single door that opens, and that door might three feet

5 wide - when that door opens, and you only have three

6 and a half feet from, from the back of that switch

7 gear to the wall, you know, you've only got a half a

8 foot between that, that one door and the wall, so I've

9 limited means of egress in one direction. Well, I

10 still have a means of egress in the other direction;

11 that should be acceptable. And the proposal that put

12 this in didn't address that.

13 So I'm asking you to reject it, and to take

14 this language out, and then in the next cycle we can

15 get the language correct at the First Draft stage, not

16 put a change in like this at the Second Draft stage,

17 where it didn't get public review.

18 JAMES QUITER: Okay. Thank you.

19 RICHARD HOLUB: Thank you.

20 JAMES QUITER: Mr. Johnston, would you like to

21 offer the Panel's position?

22 MICHAEL JOHNSTON: Thank you, Mr. Chair. There

23 were no correlating issues or conflicts identified by

24 the NEC Correlating Committee. I'd like to defer to

25 microphone two and the Chair of Code Panel 1, Kenneth



343

1 Boyce.

2 KENNETH BOYCE: Thank you, Mr. Chair. Ken

3 Boyce, UL, LLC, Chairman of Code-Making Panel 1. I

4 speak in opposition to the motion. CMP 1 added

5 requirements to Section 110.26(C)(2) to prevent open

6 equipment doors from impeding the entry to, or egress

7 from the working space associated with large

8 equipment. This was done for an important reason - to

9 minimize the change of entrapment of a person between

10 open equipment doors and an obstruction, such as a

11 wall, facing the equipment.

12 CMP took this important action to provide

13 additional safety for workers who need access to, and

14 egress from large equipment containing over current

15 devices, switching devices, or control devices.

16 Ensuring that workers can have unimpeded access

17 to, and egress from the working space is an important

18 safety issue, and the requirement to ensure that

19 equipment doors will not impede that access or egress

20 is an important advancement for worker safety.

21 All return votes were in the affirmative,

22 reflecting the Panel's alignment on this issue. Code-

23 Making Panel 1 believes that this safety advancement

24 is critical and achievable, and strongly supports this

25 critical requirement. Thank you.



344





5 please.


7 Serra Wire, speaking in support of the motion. This

8 is - it's an overreaching requirement. It doesn't

9 really solve the problem that it was intended to

10 solve, but it does add significant confusion to the

11 application of the working space requirements in

12 110.26. My company operates four manufacturing

13 facilities in the US. In every one of those

14 facilities, we have multiple installations that

15 qualify as large equipment, under this code provision.

16 None of that equipment has two doors that will impede

17 egress, and yet this language will apply to that

18 equipment. But the way this requirement is worded

19 will make it impossible to replace that existing

20 equipment and still comply with the working space

21 requirements.

22 The intent of the requirement's good, but the

23 actual language goes far beyond the original intent.

24 It creates an impractical requirements that will

25 significantly delay the replacement of aged equipment.



345

1 The language as written will require - could require

2 walls to be removed, existing large equipment to be

3 relocated, and it creates an unjustified burden on

4 commercial and industrial facilities, while failing to

5 increase safety in nearly every case. I urge you to

6 support this motion. Thank you.


8 three, please.

9 JIM DOLLARD: Thank you, Mr. Chairman. My

10 name is Jim Dollard, and I'm representing the

11 International Brotherhood of Electrical Workers. I

12 represent the International Brotherhood of Electrical

13 Workers on multiple committees - the NEC Correlating

14 Committee, Code-Making Panel 10, Code-Making Panel 13,

15 and NFPA 70E. NFPA 70E is electrical safety in the

16 workplace. I would remind everyone that this section

17 --

18 JAMES QUITER: I think I forgot to ask you to

19 say whether you are for or against.

20 JIM DOLLARD: Oh, I'm obviously against.

21 JAMES QUITER: Obviously, but you need to say

22 it.

23 JIM DOLLARD: Obviously against. I would like

24 to let everybody know this section is dealing with

25 large equipment. So we're starting at 1200 amps. And



346

1 this is about working space. When we need to do

2 justified energized work, and we, and when we need to

3 get into large equipment, when we need to get into

4 systems that are Y connected secondaries at 480 volts,

5 there are significant arc flash hazards. We have to

6 have the capability to get out.

7 Pictures are worth a thousand words. Imagine

8 you're standing with me, working on equipment. Behind

9 our back is a block wall. To our right we've got a

10 door that opens 90 degrees, and blocks it, and to our

11 left we have a door that opens 90 degrees, and blocks

12 it. If there is an arc flash incident, we cannot get

13 out. It's 2019. We can design equipment so that we

14 are not exposed to those types of hazards. This is

15 practical. It doesn't make any sense at all to lock

16 the men and women that work on these systems into an

17 area, and allow them to continuously be exposed to

18 temperatures in 15 to 30,000 degrees Fahrenheit,

19 breathing super-heated, toxic gasses. I urge you to

20 reject the motion on the floor. Thank you.


22 one, please.

23 SKIP GREGORY: Skip Gregory, Health Facility

24 Consulting, speaking in favor of the motion. When I -

25 we took a vote yesterday in the Healthcare Section at



347

1 the business meeting in support of this motion.

2 I've been working on codes and standards for 25

3 years, and when I see language like 'impede the entry'

4 - the word 'impede' I refer to as liquid language,

5 because it can mean anything that the person in,

6 involved in enforcing this wants it to mean. As a

7 former authority having jurisdiction, my - my eyes

8 light up when I see something like 'impede the entry'

9 - because I can easily make any kind of deficiency

10 statement I want to, based on that language.

11 It's unfortunate that this sentence was so

12 vaguely written that it will be vaguely enforced. I

13 support - I would urge you to support returning this

14 back to the Committee, and let's get something we can

15 actually enforce. Thank you.

16 JAMES QUITER: Thank you. Back to microphone

17 three.

18 KEITH LAUGHLIN (phonetic): Yes, Keith Laughlin

19 with, with the International Association of Electrical

20 Inspectors, and I stand in opposition of this motion.

21 Not only is this a needed requirement for the

22 installers, it's a needed requirement for the

23 electrical inspectors, as well. Thank you, Mr. Chair.

24 JAMES QUITER: And microphone number four.

25 RICHARD HOLUB: Richard Holub with DuPont, once



348

1 again speaking in favor of this. I don't think

2 there's any of us that would disagree with Mr.

3 Dollard's depiction. If we had - were standing

4 between two doors that were open and impeding, you

5 know, egress, I think we could all agree that that's

6 not a safe condition.

7 But now picture one door's open, it's clear all

8 access in the other direction, and we're saying that

9 that's unsafe and we can't have that condition.

10 Basically, what you're doing is, is stopping all

11 replacement of equipment. We, we won't replace it.

12 Because I can't replace it in its current location,

13 that project's not going to go forward. There's no

14 way you're going to, you're going to get the money to

15 relocate it, and extend those cables, or reroute the

16 cables to a new location. So this is a huge problem

17 that you're putting on the industry, with, with no

18 benefit.

19 When it's two doors, I fully agree, that's a

20 condition we need to fix. And that's what the comment

21 was there to address. But you know, the comment went

22 in at the, the Second Draft. It didn't go in at the

23 proposal stage, when we could have fixed it; it went

24 in at the Second Draft. And to say there's no

25 correlation problems, it really is a correlation



349

1 problem when you look at, you know, behind that

2 equipment, depending on how that equipment's designed,

3 you know, three and a half feet is no longer the case.

4 It's now five feet required behind the equipment,

5 because the door is three feet. So it does create a

6 problem in applying the table that we have today, a

7 longstanding table, for separation of equipment. So

8 I, I'd urge you to support this. Thank you.

9 JAMES QUITER: Thank you. Back to microphone

10 three.




14 opposition to the motion on the floor. I would remind

15 everybody that this requirement that you see on the

16 screen, 110.26(E)(2) large equipment - we're talking

17 about where two doors are required. We're not talking

18 about the load center in your basement at a hundred

19 amps at 240 volts. We're talking about extremely

20 large systems, with an extreme amount of energy - and

21 we're there.

22 So one of the things that we heard was there's

23 no benefit. Let's do it this way. Think of a young

24 man or a young man or a young woman that's related to

25 you, and they're working with me. And we're going to



350

1 limit the access for us to get out of the way of that

2 arcing event. We're going to ensure that we're

3 standing there breathing superheated air, exposed to

4 all that arc flash energy. And what you heard was

5 there's no benefit. I've been representing Labor in

6 this process since 1999 cycle, and I can tell you

7 there's tremendous benefit to the change that we see

8 in 110.26(C)(2) for large equipment. I urge you to

9 vote in opposition to the motion on the floor. Thank

10 you.

11 JAMES QUITER: Okay. Also at microphone three.

12 BILL NOLTEE (phonetic): My name is Bill

13 Noltee. I am also IBEW, but I do not speak for IBEW.

14 I would - actually, I want to speak in opposition to

15 this amendment, because I have been in the situations,

16 and the argument that there's no benefit just doesn't

17 hold water.

18 In a perfect world, if you only had one door

19 blocking and the event wasn't between you and the

20 other exit, then this wouldn't be a problem. But the

21 situation can occur where you do not have an exit

22 because one door blocks your exit, and the other one,

23 you've got an arc flash event blocking your exit, your

24 opposite exit. So again, I, I - I firmly reject this

25 motion.



351

1 JAMES QUITER: And back to microphone number

2 four.


4 Serra Wire, speaking in support of the motion. I, I

5 just want to take issue with the, the statement that

6 there are always two doors required. We're talking

7 about the doors on the equipment. And I can tell you,

8 we have a lot of large equipment that does not have

9 two doors that have to be open at the same time. So

10 to put this in, in those cases when that is not the

11 situation is - it is a burden, and it does not provide

12 the benefit that it is purported to provide.

13 We do want to increase safety. No one is

14 saying that we don't. We just want language that is

15 actually practical, and does what it is intended to

16 do. Thank you.



19 Part of Second Revision No. 8104? Are you coming to

20 the mic, Sir? Okay.

21 BILL NOLTEE: Again, my name's Bill Noltee. I

22 am rejecting - or in opposition to the motion. One of

23 the things - there are simple mechanical solutions to

24 this. If you put a bi-fold door in, you don't block

25 the, the egress. So there, there are simple, easy



352

1 ways to get around this. The, the comments that it

2 creates a burden on the industry is just false. Thank

3 you.

4 JAMES QUITER: Thank you. Mr. Johnston, do you

5 have anything further to add?

6 MICHAEL JOHNSTON: I have nothing further, Mr.

7 Chair.



10 Reject an Identifiable Part of Second Revision No.



13 text on Screen One, touch 'Yes'. If you wish to vote


15 Two, touch 'No'. Please record your vote.

16 You have five seconds.






22 With that, let's proceed with the discussion on

23 Certified Amending Motion No. 70-8. Thank you.

24 Microphone one, please.

25 DAN BUUCK: Thank you, Mr. Chair. My name is



353

1 Dan Buuck, and I represent the National Association of

2 Homebuilders. And I make a motion to Reject an

3 Identifiable Part of Second Revision No. 7697,

4 Including any Related Portions of First Revision Nos.

5 8119 and 7705.

6 JAMES QUITER: Thank you. I think that's the

7 most complicated motion today. There is a motion on


9 Revision No. 7697, Including any Related Portions of

10 First Revisions Nos. 8119 and 7705. Is there a

11 second?



14 Please proceed with the discussion of the motion.

15 DAN BUUCK: Thank you, Mr. Chair. Again, Dan

16 Buuck with the National Association of Homebuilders;

17 also a voting member of Panel 2, not representing

18 Panel 2. And that is a complicated motion, but it's

19 fairly --

20 JAMES QUITER: And speaking for the motion,

21 correct?

22 DAN BUUCK: Speaking for the motion - thank

23 you. It basically maintains the language of the 2017

24 edition, as shown on the screen, and does not expand

25 GFCI requirements to 240 volt receptacles that are



354

1 within six feet of a sink or similar source of water.

2 This - the - and this is the first of three

3 motions opposing the expansion of GFCI coverage that

4 are not technically supported. And in this particular

5 one, the voting member from NECA, as well as EEI,

6 agree with the fact that there was no technical

7 substantiation to make this change, as shown in their

8 ballot responses on their negative votes that were

9 published.

10 The proponents of the change cited an

11 installation hazard, which is already addressed in the

12 NEC. And according to the, the article that they

13 cited, the appliance in question was, and I quote, 'an

14 older installation, one predating today's requirement

15 to install an equipment grounding conductor in the

16 branch circuit to the range.' End quote.

17 240 volt receptacles serving large appliances

18 which are rarely moved do not present similar hazards

19 as 120 volt receptacles serving smaller, corded

20 appliances such as hair dryers, toasters, blenders.

21 So I ask that you please support this motion, and

22 thank you very much.

23 JAMES QUITER: Thank you. Mr. Johnston, do you

24 have anything to say for the Panel?

25 MICHAEL JOHNSTON:: Thank you, Mr. Chair.



355

1 There were no correlation issues or conflicts

2 identified by the NEC Correlating Committee. I would

3 like to defer to the Chair of Code-Making Panel Two,

4 Mark Hilbert, and I believe he's at microphone three.

5 MARK HILBERT: Thank you, Mr. Chairman. If it

6 pleases the Presiding Officer - my name's Mark Hilbert

7 from - and I do represent the International

8 Association of Electric Inspectors on Code-Making

9 Panel 2, and I have had the pleasure of being Chair

10 for the last three cycles.

11 I speak in opposition to the motion on behalf

12 of CMP 2. And this actually - there was a fatality

13 that was associated with this change. This is the

14 second cycle now that this was attempted, and the - it

15 did result from a plumbing contractor who came in

16 contact with an energized out enclosure of a, of a

17 range, which was actually a new electric range. And

18 he was working underneath the sink, and it resulted in

19 a fatality from a fault that occurred to the - and

20 energized the outer jacket of the, of the range. So

21 there was substantiation to increase to the 250 volts.

22 I'd also like to make a note that it should say

23 125 volt, single 50, and 20 amp, which was the

24 previous language in the 2017 NEC.

25 So as I said, the - I stand in support of the



356

1 Panel's work on this. There was substantiation for

2 it. Mr. Chairman, all sides of the, of the issue were

3 heard and had ample time at the Panel. It resulted in

4 a 10 to 4 vote, with 10 in favor, and four - four

5 against. Excuse me - 11 for, and three against - my

6 bad.

7 JAMES QUITER: Okay.

8 MARK HILBERT: Thank you, Mr. Chairman.




12 support of, or against the motion. Let's go to mic

13 three first.

14 MIKE STONE: Mike Stone, representing the

15 National Electrical Manufacturers Association. NEMA

16 is opposed to this motion to Reject an Identifiable

17 Part of Second Revision 7697, Including any Related

18 Portions of First Revision 8119 and 7705. Thank you.

19 JAMES QUITER: Thank you. Microphone one.

20 DAN BUUCK: Thank you. Dan Buuck, National

21 Association of Homebuilders, speaking in support of

22 the motion. Again, I point to the, the article that

23 was cited, that it was an older installation.

24 Another point to be made about this is that it

25 only applies to receptacles. Many of those larger



357

1 appliances are also hardwired, and this will increase

2 the, the - that practice that they become hardwired,

3 to get around this, this requirement for GFCI.

4 This is only putting it back to what we

5 currently have. We believe that that is safe. And

6 maybe you've seen a report that came out recently from

7 the NFPA Policy Institute that mentions that adoptions

8 of the NEC are becoming more difficult. The -

9 editions are getting skipped; the process is taking

10 longer; there are more amendments; and most of all,

11 it's becoming more politicized. If you want to avoid

12 that that continues down that road, please vote for

13 this motion. It's exactly issues like this that

14 brings politicians into the process, and we don't want

15 to see that continue unnecessarily.

16 There are so many things that are improvements

17 to the NEC - we're talking about safety at marinas.

18 We're talking about EE - ESS technology. We're also

19 talking about emergency disconnects. That is

20 something that's new, that will be in this code, that

21 the homebuilders, NHB, specifically, has supported.

22 The longer that it takes to get the NEC adopted, the

23 more homes will not have this improved safety, and the

24 less that there will be these emergency disconnects

25 that will protect the Fire Service and others who need



358

1 to quickly shut off the power to the home. So I ask

2 you to support the motion. Thank you.


4 three, please.

5 MARK GOODSON: Yes. My name is Mark Goodson.

6 I am a consulting engineer, representing myself on

7 this particular matter - against the motion.

8 I had the luxury of doing graduate school at

9 the medical examiner's office in medical school in

10 Dallas. I consult for three medical examiners offices

11 in the Dallas area. This - this is addressing a real

12 problem. And there - there are people being hurt and

13 killed because of the lack of ground fault

14 interrupters. Since 1982 when I started this

15 business, ground fault interrupters have come a long

16 way. The death rate has dropped. There is no reason

17 we can't do even better with our 240 volt appliances.

18 Thank you.

19 JAMES QUITER: Microphone number one, please.

20 FRED HARTWELL: Fred Hartwell, speaking for

21 myself. I realize that speaking against - or seeming

22 to speak against GFCI is a - it's a little like

23 farting in church.

24 (laughter)

25 FRED HARTWELL: But I have to say that the



359

1 substantiation for this one is some of the most

2 incomplete that I have seen in 30 years on the

3 National Electrical Code Committee.

4 We had a stove that was not installed in

5 accordance with existing code requirements. It was

6 installed in a hazardous manner by an unqualified

7 person. And the result was an extreme hazard that

8 unfortunately, took a life. But this is a very

9 isolated incident. I think the most relevant thing

10 here is that these appliances simply aren't moved, or

11 unplugged and plugged in. There's just - it just

12 doesn't happen very much. And where - you know, this

13 is just - we need better substantiation to impose

14 these kind of costs. And I just - I have a problem

15 with that. I, I, I just do.


17 please.

18 JOHN MCHAMMISH (phonetic): Thank you, Mr.

19 Chair. This is John McHammish. I serve on Code-

20 Making Panel 2, where I represent the IBEW. Just to

21 answer the - a few of the points that were made

22 earlier - today's installations become tomorrow's old

23 installations. And so to cite the reason as these are

24 older installations, and that is why accidents happen

25 - tomorrow, these installations that this code would



360

1 apply to, will need GFCI protection, as been - as has

2 been proven.

3 To round out additional substantiation - there

4 were three deaths - a four-year-old girl, and two 10-

5 year-old boys who were electrocuted, killed, when they

6 went to retrieve either a pet, or a stuffed animal

7 behind a dryer.

8 So my question is, at what point do these

9 deaths become relevant, as far as substantiation is

10 concerned. I don't know how many it takes. I prefer

11 a proactive approach. I don't see why in today's

12 world with the technology we have, that electrocutions

13 occur in our home. Furthermore, these are

14 electrocutions. These are not shocks, that largely go

15 unreported, which could be, under slightly different

16 conditions, an electrocution.

17 So for this reason, for this reason I speak in

18 opposition to this motion.


20 four, please.

21 PALMER HICKMAN (phonetic): Thank you. Palmer

22 Hickman with the IBEW. I'd like to call the question.






361









9 vote against the motion, touch 'No'. Remember, this

10 is only on calling the question. Please record your

11 vote.





16 motion to call the question. The motion has passed.

17 That means we will return to the motion of 70-

18 8, to Reject an Identifiable Part of Second Revision

19 No. 7697, Including any Related Portions of First

20 Revisions Nos. 78 - excuse me - Nos. 8119 and 7705.








362








8 Certified Amendment No. 70-9. Microphone one, please.

9 DAN BUUCK: Thank you. Dan Buuck, representing

10 the National Association of Homebuilders, and I move


12 7697, Including any Related Portions of First Revision

13 Nos. 8120 and 7705.



16 Revision No. 7697, Including any Related Portions of

17 First Revisions Nos. 8120 and 7705. Is there a

18 second?







25 the motion. I appreciate Mr. Hartwell's comments on



363

1 the last one, but he maybe didn't see this one because

2 this has even less substantiation.

3 This is a motion - this motion here would

4 maintain the language of the 2017 edition, and does

5 not expand GFCI protection to receptacles in finished

6 portions of basements.

7 There was no technical substantiation to show

8 that people are at a higher risk in finished portions

9 of basements, compared to other finished areas of a

10 house. Flooding was brought up, but this is not your

11 - or your grandmother's basement, cinder block, plain

12 concrete, and possibly in a flood plain. FEMA and the

13 building codes have taken care of the issue with

14 building in a flood plain. You'll see houses now on

15 stilts, and those don't have flooding in the basement.

16 Damp-proofing was used previously. Now we use

17 waterproofing, and the, the moisture isn't getting

18 into the basements like it used to.

19 GFCI receptacles expanded into the unfinished

20 areas of basements 30 years ago. And this change came

21 along, and there was not a reason for it. If it's

22 been 30 years and we needed them, why haven't we heard

23 of it before. And where were the incidents shown that

24 we need it now?

25 One thing you may not have considered is in



364

1 this room, as you're voting, what happens here goes on

2 to become the law of the land, because this language

3 is adopted by states across the country. So we are

4 working as de facto legislators. I want my

5 legislators, both federal and state, to take both the

6 cost and the benefit into consideration. We don't

7 have the information to make that decision wisely.

8 So again, it will be up to the politicians at

9 the state level, when they see this, and across the

10 board at all levels of government, they are talking

11 about affordable housing. They will be asking,

12 'Where's the benefit?' and it just isn't there in the

13 documentation that is along with the code. So I ask

14 that you support the motion. Thank you.


16 you like to offer the Panel's position.


18 There were no correlation issues, or conflicts

19 identified by the NEC Correlating Committee, but I

20 would like to defer to the Chair of Code Panel 2, Mark

21 Hilbert, at microphone three, please.

22 MARK HILBERT: Thank you, Mr. Chairman. As he

23 said, my name's Mark Hilbert, representing

24 International Association of Electrical Inspectors,

25 Chair of Panel 2. And I would just like to speak



365

1 against the motion, and offer to support the Panel's

2 work.

3 There was debate. All sides were heard -

4 whether you were for or against this - the discussion,

5 there was discussion both at the First Draft and the

6 Second Draft stage. It also helped clarify - part of

7 the substantiation at the Panel discussion was that it

8 would help to clarify what was habitable and not

9 habitable, dealing with that language, and also trying

10 to address damp and wet conditions, as Mr. Buuck

11 mentioned in his discussion.

12 So as I say, I speak in favor of the Panel's

13 work on this, and that all people were heard. The

14 vote was, again, 11 to three, so the majority of the

15 Panel voted in favor of the text as it was shown at

16 the Second Draft.


18 MARK HILBERT: Thanks, Jim.

19 JAMES QUITER: With that, we will open up

20 debate on the motion. Please provide your name,


22 of, or against the motion. Microphone three, please.

23 JOHN MCHAMMISH: Thank you, Mr. Chair. John

24 McHammish. I serve on Code-Making Panel 2. I

25 represent the IBEW. I'm speaking against the motion.



366

1 Part of the issue that was - that caused this

2 to come to be was initial public input about basements

3 that are indeed finished, but the ground surface is

4 finished concrete, or some other finished material

5 that provides a adequate ground path where a shock

6 hazard would exist, as with any concrete floor

7 basement - which, as Mr. Buuck pointed out, GFCIs have

8 been a requirement for basements in these

9 circumstances for decades. And as a result of that

10 requirement, there haven't been any incidents. Bravo

11 to the GFCIs.

12 So at what point does unfinished versus

13 finished come into play? This actually adds clarity,

14 removes ambiguity from the code, such that a $12.00

15 GFCI can now provide protection for basements. Thank

16 you.

17 JAMES QUITER: Also microphone number three.

18 BRIAN HOLLAND: Thank you. Brian Holland,

19 representing the National Electrical Manufacturers

20 Association. NEMA is opposed to the motion on 70-9.

21 We ask you to vote no, and keep the language in

22 210.8(A)(5) as approved by the Panel. Thank you.


24 one.




367


2 the motion. Again, it wasn't just myself who spoke,

3 or voted in opposition. There were published ballot,

4 negative ballot responses, talking about lack of

5 substantiation from this, both from members of IAEI,

6 and the electrical contractors - not necessarily

7 supporting, with support from their organizations, but

8 that's where they were coming from. They did not

9 support this.

10 I - my understanding that originally, these

11 were required in the older basements because of the

12 damp problem. Water and electricity - electricity

13 don't mix. But just because there is a concrete

14 floor, that happens everywhere, in many places - it -

15 not necessarily just in the basement. Many commercial

16 occupancies have that, many commercial buildings are

17 there, GFCI's everywhere in those buildings. We're

18 not seeing that as an issue. So please support the

19 motion.

20 JAMES QUITER: Thank you. Microphone three.

21 ALAN MANCHE: Alan Manche with Schneider

22 Electric. I rise against the motion. Water doesn't -

23 water doesn't understand the difference between a

24 finished and an unfinished basement. So it's not

25 going to stop at the door, moving across from an



368

1 unfinished space to a finished space. So when someone

2 walks into that area, the same hazard exists. It's

3 also not going to know when the water rises above the

4 receptacles, and energizes that space. So most anyone

5 can get on Google at this point in time, and, and, and

6 Google for those electrocutions, and you'll find them

7 in the basement. And, and whether it's finished or

8 unfinished - those sump pumps reside in finished and

9 unfinished spaces, and I would encourage everyone to

10 vote no.

11 JAMES QUITER: Thank you. Mic number two.

12 THOMAS DOMITROVICH: Yes. My name is

13 Domitrovich with Eaton, and I'm speaking against the


15 We're talking about ground fault circuit

16 interrupter protection for personnel, due to shock,

17 electrocution. I would not like to see

18 substantiation, because most of the substantiation, as

19 a Code-Making Panel 2 member, that I see, has death

20 associated with it.

21 In our discussions at Code-Making Panel 2, and

22 our continued debates on this topic, we talked about

23 the hazards in these locations in basements - standing

24 on concrete, damp areas, wet locations, things of that

25 nature. And the - in, in these unfinished and



369

1 finished basements, which our discussion revolved

2 around how do you determine what is finished, and what

3 is unfinished, especially in today's world where

4 construction look and feel is a design aspect of the

5 area.

6 The hazards exist. We are electrical

7 professionals that understand the hazards associated

8 with electricity. And I would hope that our homes are

9 safe because of this technology, and we can save lives

10 in the future, and hopefully not have substantiation

11 for further expansion of GFCIs, if we do the right

12 thing today. Thank you.


14 THOMAS DOMITROVICH: Yeah.

15 JAMES QUITER: Mic six.

16 DAVE SHAPIRO: Dave Shapiro, myself, speaking

17 against. Personal experience - I live in a 1950s

18 house. I gutted it, and rewired it; put down tile,

19 beautiful tile on the concrete floors in the

20 downstairs. But enough moisture gets in that I want

21 GFCI protection there, and I want that for people I

22 inspect, people I might wire - because I think they're

23 in the same situation, even though it's a newly redone

24 house. And so - well, it's not completely

25 waterproofed as the NAHB might arrange for a new



370

1 house, in the best of worlds. But it's something that

2 I'm taking responsibility for. So, so think about

3 that.

4 JAMES QUITER: Thank you. Mic one.


6 I'd like to call the question.



9 to call the question. I noted there was a person

10 remaining at the microphones, waiting to speak, but

11 we'll proceed with a vote on the call of the question.

12 Do we have a second?







19 your vote, remembering that this is only for the call

20 of the question.



23 Results of the vote are: 499 in support of the

24 motion to call the question; and 13 against the motion

25 to call the question - which moves us back to Motion



371

1 No. 70-9.


3 motion on the floor is to Reject an Identifiable Part

4 of Second Revision No. 7697, Including any Related

5 Portions of First Revision Nos. 8120 and 7705. To












17 Let us now proceed with discussion on Certified

18 Amending Motion No. 70-10. Microphone one, please.

19 DAN BUUCK: Dan Buuck, representing National

20 Association of Homebuilders, and I move to Reject

21 Second Revision No. 7676.


23 the floor to Reject Second Revision No. 7676. Is

24 there a second?




372





5 the motion. This motion also maintains the language

6 of the - of the 2017 edition; does not expand GFCI

7 requirements to outdoor outlets, with - and these

8 would be outlets other than the receptacles that are

9 already covered by code. And you'll see that it would

10 be for 150 volts to ground, or less; 50 amperes, or

11 less. And so this would include your air conditioning

12 condenser unit, and this has the potential of shutting

13 off air conditioning units, putting people's lives at

14 risk in hot weather, and their property at risk due to

15 high humidity and mold. Homeowners and renters will

16 yet again be the guinea pigs for these untested

17 installations.

18 It's typically, in new construction, the

19 builder who gets called when there are problems. So

20 this is something that our members will be dealing

21 with when the air conditioning goes off in the middle

22 of a humid summer day. And so I'm asking that you

23 support this motion. Again, there was very limited

24 substantiation to make this change.




373




4 identified by the NEC Correlating Committee, but I

5 would like to refer to the Chair of Code Panel 2, Mark

6 Hilbert. I believe he's at mic three.

7 MARK HILBERT: Thank you, Mr. Chairman. As he

8 said, Mark Hilbert, representing the International

9 Association of Electrical Inspectors, Chairman of

10 Panel Two. And again, I speak against the motion, and

11 in favor of the work done by the Panel.

12 This did also involve a fatality, and it

13 actually did involve a condensing unit. It was an

14 interesting one. There, there was a problem with the

15 wiring in the system to the air conditioning, as I

16 understood the substantiation, to the condenser. A

17 gentleman had come over a chain link fence, came in

18 contact with the enclosure of the condenser, which had

19 a fault, a ground fault to it, and as a result, there

20 was a fatality when he came in contact with the

21 enclosure and the, and the metal fence.

22 So again, all parts were heard. All parties

23 had ample time to discuss this at the Panel. There

24 were not issues there at, at the meetings. And this

25 one cast - it was a vote of 10 to four. Thank, Mr.



374

1 Chairman.




5 support of, or against the motion. Microphone three,

6 please.

7 JACK LYONS: Speaking against the motion. I'm

8 Jack Lyons, from the National Electrical Manufacturing

9 Association, speaking on behalf of the Codes and

10 Standards Committee to state their opposition to the

11 motion to Reject SR 7676 related to outdoor outlets,

12 and GFCI protection.

13 JAMES QUITER: Thank you. Also microphone

14 number three.

15 KEITH WATERS: Yes, thank you, Mr. Chair. My

16 name is Keith Waters. I'm with Schneider Electric,

17 and I stand in opposition to the motion.

18 As Mr. Hilbert said, there was a fatality that

19 was a direct result of this change being made. Since

20 the, the ballot time, we have actually went out and

21 done field trials and field testing on these exact

22 applications. And what we have found is that the

23 concerns, and what happened in - at this fatality in,

24 in the Chicago area, is not a single incident. We

25 found applications were ground wires weren't run, and



375

1 we found applications that were shorted to the

2 condenser. So if someone had been - in the same

3 application - had touched the AC condenser and grabbed

4 a fence, a, a metal fence, they would have been the

5 path to ground; or if they just walked up and put

6 their hand on it, they would have been the path to

7 ground. So I ask the Membership to stand in

8 opposition.

9 JAMES QUITER: Thank you. And also, microphone

10 number three.

11 JOHN MCHAMMISH: Thank you, Mr. Chair. Joh

12 McHammish. I - I serve on Code-Making Panel 2, where

13 I represent the IBEW, speaking against the motion.

14 The limited substantiation of one fatality has

15 already been mentioned, and the - as Mr. Domitrovich

16 said, that's how we define substantiation, it seems.

17 But there's also other fatalities, or shocks that have

18 happened - HVAC technicians, with operations as simple

19 as changing out air filters on HVAC units. So for

20 these and the previous reasons, I speak against the

21 motion.

22 JAMES QUITER: Thank you. And microphone

23 number one.

24 DAN BUUCK: Dan Buuck, National Association of

25 Homebuilders, speaking in support of the motion. The



376

1 tragic incident that's being cited was an existing

2 home, an older home, I believe, and it was an improper

3 installation. This is not going to end, if the - you

4 know, if these - these installations are still around,

5 this isn't going to end those problems, because these

6 older homes are more of the problem.

7 If somebody is going to do an improper

8 installation, they're not going to first run the GFCI

9 protection, and then do the improper installation;

10 they're going to leave that off, as well. So we're

11 penalizing new construction, which is done to the

12 code, and the, there's no exception in this language

13 for new construction, although I believe it applies

14 more to the existing housing stock than the new

15 construction. So I ask your support.


17 two.

18 THOMAS DOMITROVICH: Yes. My name is Thomas

19 Domitrovich, speaking in opposition to the motion on

20 the floor. I'm with Eaton, and I'm also a Code-Making

21 Panel Two member.

22 GFCIs are not there for when things go right

23 GFCIs are there for when things go wrong. And when

24 things go wrong, unfortunately with electricity,

25 people die. In my home, I have an HVAC system, a



377

1 geothermal system. And not too long ago, I had a

2 wiring issue within my, my assembly, where my two

3 pumps were energized because of a conductor that was

4 accidentally touching the enclosure. I touched those

5 two, and I received a shock. I did not die, thank

6 God. But I called my HVAC person who showed up to fix

7 the issue, and they found the wiring problem that had

8 been there for quite some time. Anybody in my house

9 could have touched those, and some of my friends

10 admire the - thank you, Larry - my cleanliness of my,

11 of my HVAC system, because we take care of it.

12 But there was a hazard there. And had I had

13 GFCI protection, the leakage current itself would have

14 found that problem, and isolated the problem, so that

15 nobody would have - so I would have been able to

16 identify the issue and, and resolve that issue.

17 GFCI protection saves lives. There is no

18 reason that we should die in our own home from

19 electricity, with the technology we have today.

20 Please vote against this motion that is on the floor.


22 one.

23 EDDIE GEDRY: Eddie Gedry speaking for myself

24 as a - one of many electrical professionals in this

25 room. I want to call the question, please.



378


2 JAMES QUITER: That was almost testifying

3 before calling the question. So be careful about

4 that.

5 (laughter)

6 JAMES QUITER: There was a motion from the

7 floor to call the question. I noticed there were a

8 couple of people remaining at the microphones waiting




12 JAMES QUITER: We, we do have a second. In

13 order to vote on this motion, please scroll down to

14 the bottom of the tablet to vote. If you wish to vote

15 in support of the motion, touch 'Yes'. If you wish to


17 your vote. And again, this is only on the call of the

18 question.

19 And our voting time is shortening, with a -

20 voting will be closed in five seconds.

21 (laughter)

22 JAMES QUITER: The voting is closed.

23 Results of the vote: 497 in the support of the

24 motion to call the question; and 7 against the motion

25 to call the question. The motion has passed, which



379

1 returns us to Motion 70-10.

2 So let me restate the motion. The motion on

3 the floor is to Reject Second Revision No. 7676. To


5 support, and recommend the text on Screen One, touch



8 record your vote.

9 Five seconds.

10 And the voting is closed.







17 Certified Amending Motion No. 70-11. Okay, back at

18 microphone number five.

19 RANDY DOLLAR: My name is Randy Dollar. I'm

20 representing the American Circuit Breaker

21 Manufacturers Association. And I make a motion to

22 Accept an Identifiable Part of Public Comment No.

23 1381.





380





5 RANDY DOLLAR: Okay. Again, my name is Randy

6 Dollar, representing American Circuit Breaker

7 Manufacturers Association.

8 I speak in support of the motion. AFCI

9 expansion to cover all, 120 volt, single phase, 15 and

10 20 amp circuits in dwelling units has been over 20

11 years in the making. This was, and is a safety driven

12 effort that originally began as a result of findings

13 by the CPSC. This CAM simply extends AFCI protection

14 to, to the few areas of dwelling units not covered

15 under the 2017 NEC.

16 The most recent USFA fire statistics covers the

17 range of 2007 to 2016. That report shows residential

18 building electrical malfunction fire trends. The

19 report summarizes these trends as a 22% decrease in

20 fires, a 3% decrease in deaths, 32% decrease in

21 injuries, and a 39% decrease in dollar loss. The

22 AFCI, along with other safety features built in by the

23 NEC, have certainly contributed to those reductions.

24 And I ask for your support for this motion.




381




4 identified by the NEC Correlating Committee. I would

5 like to defer to the Chair of Code Panel 2, Mark

6 Hilbert. I believe he's at mic, microphone three.

7 MARK HILBERT: Thank you, Mr. Chairman. As you

8 said, Mark Hilbert, representing International

9 Association of Electrical Inspectors, Code-Making

10 Panel 2 Chair.

11 Again, I support the work of the code-making

12 panel, and speak against the motion. This was

13 debated, both in the First Draft and Second Draft

14 stages. It passed the meeting with a simple majority

15 at the First Draft, and failed at the ballot vote

16 stage, with a vote of nine to five, and one not

17 returned; we had one additional member in the First

18 Draft stage.

19 The comment, 1381, was undertaken during the

20 Second Draft stage, and failed to obtain the simple

21 majority by a very narrow margin at the Second Draft.

22 Both sides were heard, positions were well stated

23 throughout both the First and Second Drafts. And so I

24 support the Panel's work on this. Thank you, Mr.

25 Chairman.



382


2 open up the debate on the motion. Please provide your


4 support of, or against the motion. I see lots of

5 people standing. Let's make sure we don't have any

6 'me, too's' unless you just say, 'Me, too.'

7 Microphone number two.

8 BILL TIMMONS (phonetic): Thank you. My name

9 is Bill Timmons. I'm from La Grande (phonetic), and I

10 am speaking in opposition of the motion.

11 We at La Grande are committed to the

12 development of electrical products aimed at making

13 homes safer. However, we - we believe that decisions

14 on mandates for use of these safety products should be

15 based on facts. No data was presented that supports

16 the idea that AFCIs have reduced the number of

17 residential electrical fires.

18 The leadership of Panel 2 asked the Fire

19 Protection Research Foundation to collect data to

20 determine the best methods of protecting branch

21 circuit wiring in dwelling units, against electrical

22 arcing. The project revealed, quote, "There is

23 uncertainty regarding the residential electrical fire

24 problem, and the effectiveness of branch circuit

25 protection devices such as AFCIs."



383

1 The Research Foundation Project further

2 acknowledged, again quote, "The most significant

3 problem with residential electrical fire data is that

4 nearly all the currently available public data is

5 lacking in quality and accuracy, and is relatively

6 unusable for data analytics in its current state."

7 The same Research Foundation is planning a

8 workshop in the fall to determine the best way to

9 collect data to provide answers on AFCI effectiveness.

10 Why should we expand the AFCI requirement before this

11 data is known? The Panel should take into

12 consideration upcoming Research Foundation findings

13 before proceeding with any expansion of AFCI

14 requirements. I urge you to vote against this motion.


16 three.

17 LORI KELLY (phonetic): Thank you, Mr. Chair.

18 I'm Lori Kelly from La Grand, and I am speaking in

19 opposition to the proposal. I'm reading comments

20 submitted by Jane Allred, the Chief Electrical

21 Inspector for the state of Wyoming. Jane has over 15

22 years' experience as an electrical inspector; has been

23 a Master Electrician in Wyoming; and a Journeyman in

24 Idaho. She holds ICC certifications as an electrical

25 and building inspector, and holds a Master Electrical



384

1 Inspector certification from IAEI; and serves as the

2 Secretary and Treasurer of the Eastern Idaho Division

3 of the IAEI.

4 Jane was not able to attend today, but asked

5 that her testimony be read, given her strong feelings

6 against the AFCI expansion.

7 'Since the introduction of the AFCI breaker

8 into the NEC, there have been numerous issues. Some

9 of those were addressed with the introduction of the

10 combination of AFCI breaker. But overall, the

11 technology has proven to measure up to the complicated

12 ways of the - the ways that electricity is being used

13 in modern homes. Due to harmonics, motor inrush

14 current, heating elements, LED lighting, and other

15 energy saving advances, these devices have cost the

16 consumer, the electrical contractor, and the general

17 contractor massive amounts of money and nuisance -

18 with nuisance tripping, and callbacks.

19 Some claim that appliances are the problem, but

20 I feel that the AFCI technology needs to be improved,

21 and proven to be effective before we use code

22 requirements to force contractors to install them.

23 They are costly, and damage the reputation of

24 contractors as a result of their constant nuisance

25 tripping. The intended protection is not being



385

1 provided because homeowners, when confronted with

2 nuisance tripping, simply remove their $35.00 breaker,

3 and replace it with a $3.00 non-GF - AFCI breaker.

4 GFCI protection has been around for decades, is very

5 well vetted, and has proven time and again to be a

6 true safety measure for a user of electricity.

7 However, this proposal will further push installers to

8 use the dual AFCI/GFCI breaker in order to save time

9 and money, and when - when wiring an - residential

10 residence. So as a result, when the AFCI causes

11 nuisance tripping, the homeowner will simply remove

12 the dual breaker, and replace it with the standard

13 breaker, and now not only have they lost AFCI

14 protection, they've lost the valuable GFCI protection,

15 as well. The expansion of these breakers will not

16 alleviate any safety hazard, but will in fact, create

17 a safety hazard that's very serious." So thank you,

18 again, for your consideration against this motion.


20 one, please.

21 BRETT LARSON: My name is Brett Larson. I

22 represent Schneider Electric, and I stand in support

23 of this motion.

24 There has been a, as discussed earlier, a

25 significant decrease in the fires due to electrical



386

1 malfunction, and the AFCIs are a key contributor to

2 that reduction in fires.

3 This motion supports the protection of

4 electrical circuits by AFCI in garages. AFCI - or

5 FEMA published a report on residential building fires

6 that started in the garage. And so let me share a few

7 highlights from that report.

8 An estimated 6,600 residential building garage

9 fires were reported in United States Fire Departments

10 each year, and cause an estimated 30 deaths, 400

11 injuries, and $457 million in property loss. Garage

12 fires result in substantially more injuries per 1,000

13 fires, and greater dollar loss per fire than non-

14 garage fires. Fires in the garage take longer to

15 detect, become larger in size, and cause more

16 widespread damage. The leading cause of residential

17 building fires, or garage fires, was electric -

18 electrical malfunction. Electrical arcing was the

19 most common heat source in residential building garage

20 fires.

21 This motion seeks to place AFCI protection on

22 garage electrical circuits in order to eliminate these

23 FEMA statistics. I encourage you to vote in support

24 of this motion. Thank you.




387

1 six, please.

2 MIKE BENNETT: Mr. Chairman, my name is Mike

3 Bennett. I'm the CEO of the Arc of San Antonio, so

4 welcome, all of you to our fair city.

5 I'm here today to speak on behalf of special

6 needs individuals. These are folks that we serve

7 across the United States.

8 JAMES QUITER: And are you for, or against the

9 motion?

10 MIKE BENNETT: Sorry - I'm against the motion,

11 and I'm against the motion for the very simple reason

12 of accessibility. The folks that we serve have a

13 number of issues in trying to deal with the simple

14 tasks of everyday life. One of those would be

15 responding to a power outage at a, an electrical

16 socket, whether that's used for personal hygiene,

17 cooking, or very often for medical equipment.

18 Our position is that moving the accessibility

19 of this reset from the point of use to out in the

20 garage or down in the basement puts a significant

21 number of folks at risk, in terms of being able to

22 handle that. And our goal is to help special needs

23 individuals be as independent, and able to live a life

24 just like the rest of us, as they wish.

25 So we ask you all to deal with that issue on



388

1 the basis of accessibility, because it will be a

2 significant problem for the folks that we serve.

3 As just a personal point, I look across this

4 audience today, and I keep in mind that for the

5 special needs individuals we serve, their

6 accessibility issues go on for their entire life. But

7 there are many folks in the room who look just like

8 me. They're getting towards that part of their life

9 where accessibility may also become an issue. And so

10 I would suggest that as important as it is to us in

11 the special needs community, we all think about the

12 days when it might not be too simple for us to get out

13 there and deal with that button. Thank you for your

14 consideration.


16 three, please.

17 ANDY BARBER: Good eve - good evening. My name

18 is Andy Barber. I'm with Generation Homes out of

19 Charleston, South Carolina. I am representing myself

20 in here, speaking against this motion.

21 I think I'm looking around the room - I'm the

22 only one of my kind in here. I'm the contractor. I'm

23 the, I'm the guy on the front lines that's taking the

24 heat for all of this. And, and I'm, I'm here to tell

25 you, there's a lot of heat.



389

1 The - I'm not - you, you know, I look around,

2 and I appreciate what's being done. But I'm not an

3 engineer, a manufacturer and inspector, or anybody

4 like that. I'm the guy that's standing toe to toe

5 with the homeowner at the end of the day, that has to

6 explain why their breakers keep tripping, and why

7 their breakers can't be tested, and why we're having

8 these issues. While I appreciate the intent - we're

9 all here - I serve on a lot of different code

10 committees. We're all here to save lives and

11 property. But I think we're going about it the wrong

12 way with, with the AFCI, particularly with this

13 expansion.

14 I appreciate the intent, and the engineering,

15 and the testing. This technology is just not ready

16 for this type of use. I just - I just can't get

17 behind it, in all that I do in codes. We've heard the

18 words 'nuisance tripping', 'annoyance trips'. I've

19 even heard 'em called 'safety checks'. I call it a

20 product defect. I just - this product just does not

21 perform as advertised, in the real world. When you

22 get similar things, similar items out there that cause

23 wave forms that match these arcs that they're supposed

24 to detect, you wind up with these nuisance trippings -

25 things such as televisions, computer equipment, small



390

1 motors, small devices, and even, as the previous

2 gentleman stated, medical equipment. I mean, these -

3 you're just dealing with unreliable technology.

4 And the outcome is, as the lady before me at

5 this podium said, homeowners are going in and digging

6 these things out. I've seen it firsthand. I've been

7 in my clients' houses who have electrical problems,

8 who have come back after my electrician left, and

9 pulled the panel apart, and changed these outlets

10 because they're so aggravated with 'em. And our

11 standard answer is, 'Well, there's nothing we can do

12 about it. It's code. We can't test it. We can't

13 make it right.'

14 So that's, that's my outlook on this. I really

15 can't support any, any expansion of AFCI circuitry at

16 this point in time, and I urge everyone to vote

17 against this motion. Thank you.


19 one.


21 Hartwell, speaking for myself. But I think, you know

22 - first of all, I, I think it's important to note that

23 Code Panel 2 voted for this almost overwhelmingly.

24 They (unintelligible) --

25 JAMES QUITER: For or against - before you get



391

1 there. Speaking for, or against the motion?

2 FRED HARTWELL: I'm, I'm speaking in favor of

3 the motion. Thank you. It - the, this change failed

4 by a single vote of obtaining a two-thirds vote in

5 Panel 2 - a single vote. And I think that the - we

6 should, we should move towards completing what was

7 started that - well, almost 20 years ago.

8 And I will say that in Massachusetts, you, you

9 know, we - because we try to be in place, enforcing

10 the code on January 1 of a named code year, which

11 means we are very actively now in the process of

12 looking at the Second Draft Reports and so forth, and

13 preparing whether we should amend various code

14 provisions, or not. And one of the things that we

15 have now, the Massachusetts Committee has overwhelming

16 voted, is to in effect, execute this change. The - we

17 will be - we are assuming that the change will fail

18 ballot again, by failing two-thirds here, and it will

19 not go into the Massachusetts Code.

20 However, the Massachusetts Code, in the, the,

21 the 2020 Massachusetts Code, enforceable January 1 -

22 we'll, we'll see; the - we have yet to go through a

23 public comment period, but it is likely, based on the

24 overwhelming vote already taken, that that edition of

25 the code will apply AFCI to all dwelling outlets, as



392

1 anticipated in this particular motion. I support it.


3 please.

4 JEFF TERRY (phonetic): Hi. My name is Jeff

5 Terry from Raske (phonetic) Partners, and I'm here on

6 behalf of the La Grande. And I actually appreciate

7 the previous speaker's mention of state activity.

8 (unintelligible)

9 JAMES QUITER: Are you for, or against.

10 JEFF TERRY: I am against. Apologies. When

11 the panel members draft the code, they're not

12 expecting to have the NEC altered during state

13 adoptions. When the NEC is modified by states, they

14 may not understand the full picture of the

15 requirements, and it may not lead to a decrease in

16 safety - or may lead to a decrease in safety in those

17 states. There are 17 states that have modified the

18 NEC to lessen the areas where AFCIs are required.

19 That's 17 separate opportunities to somehow create

20 unintentional situations as they're modifying the code

21 to push back against expansions.

22 Inconsistencies between states introduce

23 confusion. They trust that the electrical

24 professionals developing the NEC have used data, and

25 known solutions as central to the development of the



393

1 code. When states move to modify the NEC, it causes

2 an erosion of this trust with the public.

3 The expansion of AFCI has been politicized to

4 such an extent that it has undermined NFPA's and

5 stated objectives for advocacy and support of uniform

6 adoption nationwide of the NEC as the best way to

7 increase safety. This is because the evidence based

8 data to support this position does not exist, and

9 cannot be delivered. Stakeholders at the state level

10 eventually see this, and push back the only way that

11 they can, which is by amending out the requirements

12 that they are sold to them as being for their own

13 good.

14 If one-third of state's experts and electrical

15 professionals are reversing the work of panels, it's

16 time to listen to them. Let's make sure the states

17 don't have to edit out mistakes. Panel 2 had it

18 right. Do not expand problematic AFCIs. I urge you

19 to vote against this motion. Thank you.


21 please.

22 MARK GOODSON: Yes. My name is Mark Goodson.

23 I'm a Consulting Engineer. I appear here today on

24 behalf of La Grande. I sit on 1033, which is

25 requirements for fire investigators, and also sit on a



394

1 NFPA panel that doesn't have a number yet, for fire

2 investigation units. I am against what is being

3 proposed.

4 First off, reference has been made to the FEMA

5 report. All those reports have to rely on what's

6 called an NFIRS Report - National Fire Incident

7 Reporting System. Sadly, those things were a

8 disaster. It depends on who's on duty that day at the

9 fire house. We've all seen the reports - unspecified

10 electrical short; carelessly discarded smoking

11 material. The truth is, unless somebody gets hurt, or

12 killed, or there's an indication of arson, the fires

13 are not investigated the right way; the data is

14 meaningless. You, you can't work off that.

15 Number one - number two, I, I have mentioned -

16 you know, I, I spent three years in grad school at a,

17 at a medical examiner's office, part of the medical

18 school. I do tons of work in electrical deaths. What

19 we're seeing is people are going to pull the AFCIs out

20 because they nuisance trip. They'll replace it with a

21 cheap thermomagnetic breaker. Then all of a sudden,

22 they have zero ground fault protection. This is -

23 this is not theory. I don't have to - this is, this

24 has already happened.

25 If you really want to do something about the



395

1 electrical fire prevention and you make circuit

2 breakers, why not make the circuit breaker, the

3 thermomagnetic portion, work at the same temperature

4 requirement as you have for the arc fault in the

5 ground fault interrupter? Why, why stop 'em, you

6 know, at some high temperature. What happens when a

7 breaker panel's outside, and it gets cold outside, and

8 you overload the circuit? The breaker doesn't

9 respond. It, it's just, just not good business.

10 In terms of this 20 year technology, the 20

11 year technology has not kept up with what's happening

12 in the house. What happens when you have a variable

13 frequency drive running your refrigerator, or has an

14 inverter on there, that - you have a compressor that

15 runs all the time. Have these been tested for? I can

16 tell you, in my own house, I had to throw out 10

17 pounds of trout, and you know, many pounds of venison

18 because the AFCI tripped for no reason. Anyway --

19 UNIDENTIFIED MALE SPEAKERS: (unintelligible)

20 MARK GOODSON: Yeah. That's - you talk about

21 getting somebody's --

22 (laughter)

23 MARK GOODSON: -- getting somebody's dander up

24 --




396

1 MARK GOODSON: -- that, that results of a good

2 fishing trip.


4 MARK GOODSON: But yeah, the - the - I went in

5 and retrofitted the AFCIs, and it was a mistake. The

6 things aren't ready. I urge rejection of this. Thank

7 you.


9 the motion.

10 JAMES QUITER: Okay. So I'm, I'm sensing that

11 we're getting a lot of repetition, so let's try to

12 avoid the repetition, and the side stories, and move

13 on with the, with the technical matters. Microphone


15 DALE BADINSKI: Thank you, Mr. Chairman. My

16 name is Dale Badinksi. I'm speaking on behalf of

17 myself. I'm a retired IBEW, NECA trained journeyman

18 electrician, as well as hold a electrical, master

19 electrical contractor's license in New Orleans,

20 Louisiana, for the last 41 years. And I don't want to

21 be a 'me, too'.

22 JAMES QUITER: And you're for, or against?

23 DALE BADINSKI: I'm against. Yeah. I don't

24 want to be a 'me, too', but a lot of the things that I

25 wanted to cover were covered. However, I, I think



397

1 that the, the electrical contractor's really taking

2 the brunt of this, and I think that the, the key word

3 here with the exchanging of the AFCI breaker with a

4 regular breaker is, is dual, dual protection. When we

5 lose the GFI protection, which is a proven technology

6 - and it's been talked about here for the, for the

7 last hour or so - it, it's terrible. It puts

8 everybody at risk in the house.

9 The other thing I, I wanted to bring up is that

10 the incompatibility of these breakers with common

11 household products. You know, the nuisance tripping

12 can really be serious. And nuisance tripping can be a

13 major issue for senior citizens and the disabled.

14 AFCI breakers are often located outside, in the

15 basement, in the garage. Resetting a breaker can be a

16 very difficult task for them. And, and what if that

17 circuit has respirators or, or other type of critical

18 loads that these people need? You know, not only -

19 not only does this inconvenience them, but it actually

20 impacts their quality of life.

21 Nuisance tripping can cause property damage.

22 The, the gentleman he indicated he lost 50 pounds of

23 trout - can be, can be very devastating and, and

24 costly for the homeowner. Being a, an amateur radio

25 operator, we have experienced AFCI tripping not only



398

1 in our own homes, but at our neighbor's homes, as

2 well, indicating that not only do we have an EMI

3 problem, but we've got an RFI problem. And when we

4 piggyback proven technology with GFIC, that's not

5 good.

6 Electrical arcs are serious threats to both

7 life and property. And I comment the industry for

8 trying to address that. But until the industry can

9 create a device that is totally immune to EMI and RFI,

10 can be compatible with all home electrical products,

11 and can effectively differentiate between normal

12 electrical arcs, and those that can cause a fire, we

13 should not move forward with this motion at this point

14 in time, to add additional circuits.

15 And just as a footnote - I've got nine seconds

16 - this issue, and the things we talked about affect

17 everybody in this room that lives in a dwelling.

18 Thank you very much for your time, and your

19 consideration.

20 JAMES QUITER: Thank you. Microphone -

21 microphone number four, please.


23 International. I call the question.

24 UNIDENTIFIED MALE SPEAKERS: Yeah.

25 UNIDENTIFIED MALE SPEAKERS: Second.



399

1 UNIDENTIFIED MALE SPEAKERS: Yeah.


3 (applause)




7 to speak, but we'll proceed with a vote on the call of

8 the question. Do we have a second?




12 to move - vote on this motion, please scroll down to




16 your vote.

17 Five seconds.




21 motion to call the question. The motion has carried.

22 We will return to Motion 70-11.


24 motion on the floor is to Accept an Identifiable Part

25 of Public Comment No. 1381. To vote, touch the 'vote'



400


2 and recommend the text on Screen One, touch yes. If



5 vote.


7 The voting's closed.




11 Two. The motion has carried.

12 As mentioned earlier, we have a hard stop at

13 six o'clock. I'm going to see whether we get the next

14 one in, or not. If we don't, we will make our hard

15 stop, and pick it up again when we reconvene at 6:30.

16 So let's proceed with the discussion on

17 Certifying - Certified Amending Motion 70-12.

18 Microphone four, I think, please.

19 HOWARD HERNDON: This is Howard Herndon with

20 Professional Electrical Apparatus Reconditioners

21 League. I'd like to make a motion on 70.12 to Reject

22 an Identifiable Part of the Second Revision 7656.

23 JAMES QUITER: 56 or 57?

24 HOWARD HERNDON: 57 - I'm sorry.

25 JAMES QUITER: Okay. Thank you. There's a



401

1 motion on the floor to Reject an Identifiable Part of

2 the Second Revision 7657. Is there a second?




6 HOWARD HERNDON: Item 3 of the text as it is in

7 the proposed NEC would seem to be fairly easy, because

8 it seems like we're looking at ground fault

9 protection. And we've kind of beat ground fault

10 protection up all afternoon.

11 But realize, this is branch circuit ground

12 fault protection --


14 HOWARD HERNDON: -- which could include larger

15 feeder devices, such as 1200 amps and above. So

16 consequently, if I have a bolted pressure switch, or

17 some type of large feeder breaker, I cannot work on

18 that ground fault protection system, and it cannot be

19 reconditioned. We would agree that a arc fault

20 circuit interrupter, such as a 20 amp single pole,

21 should not be reconditioned, and neither should a 20

22 amp single pole ground fault circuit interrupter be

23 reconditioned.

24 So Item 3 is the real item in question, and we

25 would like to move to strike that from the 2020



402

1 edition.




5 were no correlation issues or conflicts identified by

6 the NEC Correlating Committee. I would like to defer

7 to the Chair of Code-Making Panel 2, Mark Hilbert, I

8 believe at microphone three.

9 MARK HILBERT: Thank you, Mr. Chairman. Again,

10 Mark Hilbert, representing International Association

11 of Electrical Inspectors, Chair of Panel 2. And

12 again, I speak against the motion, and in favor of the

13 Panel's work on this. We have a number of

14 manufacturers on the panel that dealt with the global

15 request to look at which equipment could be

16 reconditioned, and which couldn't. And like I said,

17 there was sufficient debate on it, on both sides. And

18 actually, it was a unanimous vote in favor of the text

19 on the right side, in Screen Two. Thank you, Mr.

20 Chairman.




24 support of, or against the motion. We'll start with

25 microphone one.



403


2 Serra Wire, speaking in support of the motion.

3 Prohibiting the reconditioning of any equipment with

4 ground fault protection of equipment is overreaching.

5 And it's going to have unintended consequences.

6 While the first two list items prohibit

7 reconditioning of small devices, like AFCIs and GFCIs,

8 GFPE is considerably different. This prohibition

9 applies to equipment that supplies branch circuits of

10 a thousand amps or more, on solidly grounded, Y

11 systems between 150 volts to ground, and 600, 600

12 volts to - phase to phase.

13 There was no substantiation provided as to why

14 reconditioning equipment that contains GFP would be

15 unsafe in any way, but that's what the language

16 prohibits. It not only prohibits reconditioning of

17 the ground fault protection of equipment components,

18 but any equipment that provides ground fault

19 protection of equipment. If that protection is

20 provided in a type of equipment that would otherwise

21 be considered suitable for reconditioning, this

22 language will now prohibit it.

23 I support the motion on the floor. Thank you.


25 two.



404


2 is Jim Dollard. I represent the International



5 The maker of the motion referred to feeders,

6 and you know, potentially services, saying that this

7 language would, would impact that equipment. It would

8 not. It would not. The scope of Article 210 is

9 limited to branch circuits. And as the previous

10 speaker mentioned, it would be limited to disconnects

11 for those branch circuits rated at a thousand amps or

12 more, and essentially, Y connected secondaries at 480,

13 277.

14 Those are complicated systems. It's not a

15 single device. They're listed systems, and this will

16 prohibit them from being reconditioned.

17 I speak in opposition to the motion on the

18 floor. This is the, the same thing that we went

19 through before. It's reconditioned equipment. The

20 Correlating Committee submitted global public comments

21 to each code-making panel, and each code-making panel

22 went on a case by case basis through all of the

23 equipment under their purview. And I support the

24 actions of Code-Making Panel 2. I urge this body to

25 reject the motion on the floor. Thank you.



405


2 five, please.

3 RYAN MCCLARNEN (phonetic): Hi. I'm Ryan

4 McClarnen, and with Utility Relay Company. We are for

5 the motion. So similar to one of the other

6 commenters, we're in support of the general intent.

7 We believe we understand the general intent. But the

8 wording - equipment, provides ground fault protection

9 of equipment, can refer to many different types of

10 equipment. So we believe it's intended for riveted,

11 molded case circuit breakers. We do not believe it's

12 intended for power circuit breakers. Power circuit

13 breakers can feed branch circuits - so not feeders,

14 but branch circuits.

15 Power circuit breakers are permitted elsewhere

16 in this document to be reconditioned. So right there,

17 we have a conflict.

18 So basically, if - if you look at it the way

19 it's worded, any power circuit breaker that, that

20 feeds a branch circuit, that has ground fault

21 protection integral to it, cannot be reconditioned.

22 And that, that - I don't think that's the intent.

23 Again, we're for the intent, but we believe

24 that the wording is just not specific enough. We

25 think this wording will result in facilities



406

1 neglecting to recondition equipment, where that might

2 be the only safe option. So we encourage you, and

3 urge you to vote for this motion.

4 JAMES QUITER: Okay. Microphone number three,

5 please.


7 Domitrovich. I'm with Eaton, also a Code-Making Panel 2

8 member. And I speak in opposition to the motion that's

9 on the floor.

10 As a manufacturer, I - we manufacturer, Eaton

11 manufactures many different types of devices that

12 provide ground fault protection of equipment, and they

13 do include the thousand amp and above devices. But they

14 also include those 30 million amp devices that you see

15 on de-icing and, and those outdoor circuits that require

16 GFPE. We also see GFPE multi-case type of solutions

17 used in marinas, where we have requirements for ground

18 fault protection of equipment up to 100 million amps.

19 This technology is not limited to large, over

20 current protection devices, but it extends well beyond

21 that. And we're talking about equipment that is there

22 for life safety, and to protect property. And these are

23 digital, electronic type of devices that should not be

24 taken apart and reconditioned in the field without

25 proper supervision, on - at all.



407

1 So that is why Code-Making Panel 2, and we had

2 unanimous support to prohibit the ground fault

3 protection of equipment from being reconditioned. And I

4 fully support what the Code-Making Panel did. And

5 again, I urge everyone to vote against this motion

6 that's on the floor. Thank you.

7 JAMES QUITER: Thank you. Is anyone who's

8 currently seated planning on speaking to this? If not,

9 we'll go through the rest of the speakers. If you are,

10 please let me know so that we can figure out when we're

11 going to call our break. But before we do that, I'm

12 going to go to microphone four first. I'm going to go

13 there twice in a row, and let the gentleman with the

14 cane speak first.

15 MARK ODIE (phonetic): Mark Odie with Pearson

16 Engineering, and I'm in support of this motion. A

17 thirty million ampere GFPE is not what we're talking

18 about here. When I go to 210.15, similar to what I do

19 in 215.10, and 230.95, this is larger equipment, starts

20 at a thousand amps or greater. I'm not going to have

21 GFPE on, on a branch circuit, unless it's part of, for

22 example, in, in 517.17, where I have to have a second

23 level of GFPE. This very easily can be done as

24 reconditioned equipment. And there are requirements for

25 reconditioning this type of equipment. You're not



408

1 talking about a 30 million ampere device here. You're

2 talking about something that's going to be basically

3 adjustable up to 1200 amperes, and, and one second.

4 And, and this certainly can be reconditioned. I don't

5 see any restriction for this.

6 And, and for somebody to think that GFPE is

7 protection of personnel, it's not. GFCI is protection

8 of personnel. So I, I, I believe that this is something

9 that we should get behind, and pass this recommended

10 text. Thank you.

11 JAMES QUITER: Thank you. And also at microphone

12 number four.

13 RANDY HUNTER: I'm Randy Hunter, representing

14 Hunter Technical Services, and I'm in favor of the

15 motion.

16 I've been following this remanufactured topic

17 throughout the code, and I'm very concerned - I'm not

18 going to speak toward any technical issues. I want to

19 talk about the fact that this material was added during

20 the second phase, the comment phase, this language you

21 see up - is - it was added during that phase. It is

22 actually new material.

23 They've referenced - and some of the people today

24 have spoke about new material. I respect them very

25 well. But this material that you see up in front of us



409

1 now appeared from public - or from no public comment, no

2 public input, no First Revision. It was created as a

3 Second Revision only. And the original public input

4 they're trying to relate everything to regarding

5 rebuilt, remanufactured, only dealt with listing, and

6 the labeling. It had no prohibition, and did not name

7 any type of equipment that cannot be reconditioned.

8 So as such, I feel that all of this is new

9 material, and therefore should be held until the 2023

10 cycle, as per the regulations of NFPA. Thank you.

11 JAMES QUITER: Thank you. Microphone number two.

12 FRED HARTWELL: Fred Hartwell, speaking for

13 myself. I beg to differ. I think the intended, at

14 least for sure, the intended application of Item 3 here

15 is your typical 30 million amp, molded case circuit

16 breaker with GFPE in it, as is mandated for like, de-

17 icing protection on a roof, or there are a number of

18 places where the - also on a number of kinds of pipe

19 tracing, that - for freeze protection. I have several

20 of these breakers on my - at my own house, for that

21 exact purpose. These are not suitable for

22 reconditioning.

23 I - and I think the application of this for, for

24 - yeah - I understand - for very large circuits there,

25 there - we get back into this kind of residual current



410

1 protection. But I think that is not where this is going

2 to be applied. This is - I think clearly, this is about

3 the, the molded case circuit breaker, and small sizes.

4 I think we should support this. It, it, it can be

5 straightened out if necessary, but I think we should

6 support this.

7 JAMES QUITER: Microphone three, please.

8 BRIAN HOLLAND: Thank you, Sir. Brian Holland

9 with the National Electrical Manufacturers Association.

10 NEMA is opposed to the motion made on CAM 70-12. We ask

11 you to vote no, and keep the recommended text that you

12 see up on Screen Number Two. Thank you.

13 JAMES QUITER: Thank you. We're at microphone

14 two, please.


16 Schneider Electric. We're against this action. We

17 support the action taken by the Code Panel to include

18 this language.

19 As industry, we recognize ground fault systems

20 are safety critical, and must operate as designed. And

21 as Mr. Domitrovich has said, these systems are very

22 complex, and we believe that reconditioning, without the

23 in depth knowledge of the technology and product

24 standards can pose a safety risk to people, and - can

25 pose a safety risk to people. Therefore, my safety



411

1 concern includes safety of workers, as well as safety of

2 occupants and facilities. I urge you to vote against

3 this motion.



6 Part or Second Revision to number six - 7657? Mr.

7 Johnston.


9 JAMES QUITER: Thank you. Before we vote, let me


11 Reject an Identifiable Part of Second Revision No. 7657.




15 the motion, and recommend the text on Screen Two, touch

16 'No'. Please record your votes.







23 At this point, we will take a break for 30

24 minutes. And a, a reminder that the concessions close

25 at 7 p.m., so if you're planning on getting food for the



412

1 latter sessions of this, this event, please do it now.


3 JAMES QUITER: Thirty minutes, please.

4 (BREAK)

5 (MUSIC)

6 (END OF PART THREE)


8


10


12

13 PART 4

14

15

16 (MUSIC)

17 JAMES QUITER: I do have a couple things I want

18 to say. Under no circumstances do we want to curtail

19 what people are offering in terms of testimony, or

20 curtail any facts. But we do want to curtail much of

21 the 'me, too' testimony. If some - if you have

22 something you want to say that somebody has already

23 said, please state your position, but please don't

24 repeat it all. We have many items left to get through

25 yet tonight, and I'm sure the people at the very end



413

1 of the session would like somebody to still be in the

2 room when we get there. So please consider everyone

3 who is involved in the process, and limit your

4 comments to those that need to be said in order for

5 people to have the correct hearing.

6 With that, let us now proceed with the

7 discussion on Certified Amending Motion No. 70-13.

8 Microphone four.


10 with Serra Wire. I'd like to make a Motion to Reject

11 Second Revision No. 7657.


13 the floor to Reject Second Revision No. 7657. Is

14 there a second?


16 JAMES QUITER: I heard a second.


18 with Serra Wire, speaking in support of the motion.

19 This language appeared for the first time in the

20 Second Draft. It was not based on any similar

21 language or requirement that was considered in the

22 First Draft. There was no public input, no First

23 Revision, nor any other appearance of any language

24 like this in the First Draft. This conflicts with the

25 requirements in the NFPA Regulations governing the



414

1 development of NFPA Standards. 4.4.4.2 says public

2 comments must be related to material that has received

3 public review, either through the submission of public

4 input, committee input, or correlating input, or

5 through the First Revisions.

6 Related to this, the Regulations also state, in

7 4.4.4.8.3.1, Criteria for Hold - The Technical

8 Committee shall reject, but hold for processing as

9 public input for the next revision cycle, in

10 accordance with 4.4.8.1(D), a public comment that

11 meets any of the following criteria: a) it would

12 introduce a concept that has not had public review by

13 being included in a related input or a First

14 Revisions, as shown in the First Draft.

15 The code-making panel should have held the

16 public comments that suggested this new language, but

17 they did not. Requirements prohibiting or restricting

18 remanufactured equipment appeared in over a dozen

19 places in the NEC, without public review; without an

20 opportunity for all of the stakeholders who will be

21 affected by these requirements to contribute their

22 expertise, their concerns, their objections, or their

23 support.

24 This conflicts with the NFPA Regulations, and

25 we should take this opportunity to correct this



415

1 failure of the process, and require all of these

2 changes to follow the established, fair process with

3 adequate public review. Thank you. Please support

4 the motion.



7 MICHAEL JOHNSTON: Thank you, Mr. Chair. The,

8 the issue of new material - I know there's several

9 that are going to speak to that, that issue. The -

10 there were multiple code panels that received public

11 comments. The majority of the code panels did. And

12 it was outlined very nicely in the public comments

13 what public input this was tied to. And the fact that

14 PI 2935 had to be acted on in a way to move things

15 beyond just Chapter One, because it had global

16 implications across the entire NEC. And we explained

17 this when we covered the definition of recondition.

18 So the Correlating Committee reviewed the

19 complete record of both public input and comments, in

20 addition to the work of the panels, which is a

21 responsibility to police for new material. And the

22 Correlating Committee found no new material. So I'm

23 going to defer to the Chair of Code Panel 2, Mark

24 Hilbert, to respond to the technical side of it. I

25 think he's at mic three.



416

1 MARK HILBERT: Yes, Sir. Yes, Mr. Chairman,

2 for the last time tonight, I think. So again, as the

3 Chairman said, Mark Hilbert, International Association

4 of Electrical Inspectors; CMP 2 Chair. And again, I

5 speak against the motion, and in favor of the Panel's

6 work.

7 As was stated earlier in the, in the 70-11,

8 basically we had manufacturers on the panel that are

9 involved with this type of equipment. It was taken on

10 a case by case basis. Each one was reviewed

11 individually. And again, it was a unanimous vote.

12 There were no negative votes. Thank you, Mr.

13 Chairman.

14 JAMES QUITER: With that, we will open up

15 debate on the motion. Please provide your name,


17 of, or against the motion. Microphone number two.





22 I would like to apologize to this body for

23 having to repeat everything that I said when I first

24 took the mic. The maker of this motion just told you

25 that this is new material. It is not new material.



417

1 The Correlating Committee looked at Public Input 2935,

2 which would have required all reconditioned equipment

3 be listed - which means a field evaluation. That is a

4 significant requirement; an extreme burden on the

5 users of the National Electrical Code. It was

6 submitted to 110.21. The Correlating Committee looked

7 at that, saw that that would be a general requirement,

8 would impact every piece of electrical equipment in

9 the National Electrical Code. So the Correlating

10 Committee did the right thing. They correlate it.

11 They formed a task group, and that task group

12 submitted public comments to each committee, and told

13 them to make a decision, case by case - each committee

14 made a decision, case by case, on what to do with

15 reconditioned equipment.

16 Public Input 2935 was available for public

17 review. The proponents of reconditioning knew it was

18 there. The public comments were available for public

19 review. The proponents are long time members in this

20 process. They know the game. They didn't approach

21 any of the Chairs. Their goal is to try to set up an

22 appeal, and tell Standards Council they were wronged

23 by the process. They were not wronged by the process.

24 The process is correct.

25 We're going to go through this all night long,



418

1 and we should not have to do this. Thank you very

2 much. I urge you to reject the motion on the floor.


4 three.

5 (applause)

6 JACK LYONS: Speaking against the motion, Jack

7 Lyons from NEMA, representing NEMA Codes and

8 Standards. We agree with him.

9 (laughter)

10 (applause)


12 JOHN MCKENZIE: John McKenzie, with Schneider

13 Electric, and we oppose this motion. Several of our

14 points have been made, so I will just say that Schneider

15 is committed to engaging across the industry, to

16 reinforce our position on the safe use of electrical

17 products, and the reuse of electrical equipment.

18 We believe that the language included by the

19 Code-Making Panel supports this goal. We oppose this

20 motion, and we urge the Membership to oppose it, as

21 well. Thank you.


23 four.





419

1 This language did not appear in any form or

2 fashion in any public input. It did not appear in the

3 First Draft. It was in no way included in any of the

4 provisions or requests in the language in - that was

5 proposed for 110.21. A request to list equipment in no

6 way equates to a prohibition against reconditioning.

7 There was no request in the first part of the cycle to

8 prohibit reconditioning of any of this equipment. So to

9 say that somebody asking for listing is exactly the same

10 thing as putting in dozens of requirements prohibiting

11 something that's been happening for - forever in our

12 industry, with no other substantiation, is wrong. This

13 is new material. And I understand that, you know, maybe

14 you don't want to talk about this, but it should not be

15 in the code because it did not follow the process.

16 Thank you. Please support the motion.

17 JAMES QUITER: Thank you. Microphone number six.

18 PAUL HARRAH (phonetic): Yes. I'm Paul Harrah,

19 the - I'm a spec writer, electrical engineer with Delta

20 Gavitro (phonetic) writing master spec. I'm speaking

21 for myself in opposition to the motion.

22 I believe the whole problem with this is the

23 words 'equipment that provides'. The definition of

24 equipment is so broad. And so I believe what we really

25 need to do is to let this text go through, but



420

1 immediately put in a TIA to change this to say 'all

2 reconditioned equipment shall replace devices providing

3 ground fault circuit interruption, arc fault circuit

4 interruption, or ground fault protection of equipment

5 with new listed devices'. And I think that would solve

6 everybody's problems, in opposition to this language.

7 JAMES QUITER: Thank you. Microphone number one.

8 STEVE LUBSTER (phonetic): I'm Steve Lubster,

9 speaking for myself, and I call the question.


11 (applause)

12 UNIDENTIFIED SPEAKER: Thank you.

13 JAMES QUITER: There's a motion from the floor to

14 call the question. There were some people still

15 remaining at the microphones waiting to speak, but we'll

16 proceed with the vote on the call of the question. Do

17 we have a second?


19 UNIDENTIFIED SPEAKERS: Second. (unintelligible)

20 JAMES QUITER: We do have a second. In order to

21 vote on this motion, please scroll down to the bottom of

22 the tablet to vote. If you wish to vote in support of

23 the motion, touch 'Yes'. If you wish to vote against

24 the motion, touch 'No'. Please record your vote, and

25 again, this is for calling the question.



421





5 motion to call the question.

6 With that, we will return to Motion 70-13. Let





11 'Yes'. If you wish to vote against het motion, and





16 The results of the vote are: 26 in favor of the

17 motion, and recommend the text on Screen One; and 353





22 please.

23 ALAN MANCHE: My name's Alan Manche with

24 Schneider Electric, and I wish to make a Motion to

25 Reject Second Revision 8074.



422


2 the floor to reject Second Revision No. 8074. Is there

3 a second?


5 JAMES QUITER: Hearing a second, please proceed

6 with discussion on the motion.

7 ALAN MANCHE: My name's Alan Manche with

8 Schneider Electric, and I support this motion. This,

9 this particular motion is to address duplication of the

10 definition of reconditioned. So what we, what we

11 ultimately have here is this definition was created by

12 Code Panel 10, accepted by Code Panel 1 or, or moved by

13 the Correlating Committee to Code Panel 1. So this is a

14 duplicate that's also located in Panel 1, that we

15 addressed, so what we don't want to do is have this in

16 two places to create confusion.

17 So this is simply removing the duplicate in

18 240.2, and Article 240 will rely on the definition that

19 is - now resides, it's identical to this in, in Article

20 - in 100, and Code Panel 10 that has responsibility,

21 too, for 240.2, also has responsibility for that

22 particular definition in 100. I urge you to support

23 this.


25 ALAN MANCHE: (unintelligible)



423



3 MICHAEL JOHNSTON: Thank you, Mr. Chair. The NEC

4 Correlating Committee supports the motion on the floor,

5 as it removes a duplication. I echo the sentiments from

6 Mr. Manche.


8 open debate on the motion. Please provide your name,

9 affiliation, and whether you are speaking in support of,

10 or against the motion. Microphone four.

11 MIKE STONE: Mike Stone, representing NEMA, and I

12 also represent NEMA on Code-Making Panel 1, which is

13 where this definition now resides. We support this

14 Motion to Reject Second Revision 8074, and remove the

15 proposed text. Thank you.


17 discussion on Motion 70-14, to Reject Second Revision

18 No. 8074? Microphone six, are you waiting for the next

19 one?

20 UNIDENTIFIED SPEAKER: I was going to call the

21 question if there were any others, but it doesn't like

22 it.

23 (laughter)

24 JAMES QUITER: Chairman Johnston, do you have any

25 further comment?



424

1 MICHAEL JOHNSTON: I have no further comments,

2 Mr. Chair.

3 JAMES QUITER: Okay. Before we vote, let me


5 Reject Second Revision No. 8074. To vote - vote, touch


7 the motion, and recommend the text on Screen One, touch


9 recommend the text on Screen Two, vote 'No'. Please


11 Five seconds.



14 the motion, and recommend the text on Screen One; and 25


16 Two. Therefore, the motion has passed.

17 Let's now proceed with Certified Amending Motion

18 70-15. Microphone four, please.

19 HOWARD HERNDON: This is Howard Herndon,

20 representing the Professional Apparatus Reconditioners

21 League. Motion 70.14, Reject the Second Revision 7974.


23 the floor to Reject Second Revision No. 7974. Is there

24 a second?




425



3 HOWARD HERNDON: The intent here, I think, is to

4 allow the other apparatus that has fuse holders in it to

5 be reconditioned, but not necessarily fuses - because I

6 think it's pretty ludicrous to say that we're going to

7 recondition a fuse - that's not renewable, and which

8 RENS (phonetic) are no longer even legal in most

9 circumstances.

10 So I vote - I would like to see us reject this,

11 get it reworded properly, because if I have a motor

12 control center bucket, a fuse switch that I can

13 recondition under the NEMA guidelines, I have to touch

14 the fuse clips.




18 were no correlation issues or conflicts created by this

19 action, and I'll just repeat, the NEC Correlating

20 Committee did review the complete record, and had

21 determined that there was no new material being

22 introduced on this particular item.

23 For the technical, I will defer to the Chair of

24 Co-Panel 10, Mr. Julian Burns. I think he's at mic

25 three.



426

1 JULIAN BURNS: Thank you, Mr. Chairman. My name

2 is Julian Burns. I represent the Independent Electrical

3 Contractors Association, and I am Chairman of Panel 10.

4 Panel 10 looked at this rather extensively, and

5 knowing you cannot refurbish, recondition a fuse or the

6 holder. So I stand in opposition of this motion. I

7 would appreciate everyone else standing in appreciation

8 of it, because think of it - if you take a fuse apart,

9 you've destroyed it. If the fuse holder - you cannot

10 replace 'em. So if you reach in there, most of the time

11 they have irreversible screws, so you'd have to drill it

12 out. That is not a portion of reconditioning. Thank

13 you.


15 open up debate on the motion. Please provide your name,


17 or against the motion. Microphone two.





22 We're just going through all the motions, the

23 arguments are all the same - it's reconditioned

24 equipment. I urge you to reject the motion on the

25 floor. Again, we're going to do this all night, so I'd



427

1 like to quote Yogi Berra and say, 'It's déjà vu all over

2 again.'

3 (laughter)

4 JAMES QUITER: Thank you. Is there --

5 (applause)

6 JAMES QUITER: Microphone two.


8 Schneider Electric, and I recommend that we, the

9 Membership vote against this motion.


11 discussion on Motion 70-15, to Reject Second Revision

12 No. 7974? Microphone four.

13 CHRIS HUNTER: Thank you. Chris Hunter, with

14 Serra Wire, speaking in support of the motion. Just a

15 reiteration, I believe this is also new material. And

16 the, the comment that, that we're going through the

17 motions I think is disrespectful to this process. There

18 was actually a different technical point that was

19 brought up on this, and it's worthy of this body to

20 listen to the submitters of these motions. Thank you.

21 JAMES QUITER: Thank you. Mr. Chair, any further

22 comment?


24 Chair.




428







7 record your vote.



10 Results of the vote are: 26 in support of the






16 please.

17 HOWARD HERNDON: Motion 70-16. This is Howard

18 Herndon, Professional Electrical Apparatus Recyclers

19 League, or Reconditioners League, rather - Reject the

20 Second Revision 8048.


22 the floor to reject Second Revision No. 8048. Is there

23 a second?





429



3 HOWARD HERNDON: The text of the wording here

4 allows, allows us that we cannot recondition a fuse

5 clip; nor would we want to recondition a medium voltage

6 fuse. We all know that once a fuse blows, it's in the

7 trash can. That's fine. But the fuse clip is part of a

8 metal, enclosed piece of switch gear, or a medium

9 voltage starter, needs to be able to be renewed if we're

10 going to be able to work on that piece of equipment.

11 And technically, I think that's a good issue that we

12 need to get - we don't have an issue with the medium

13 voltage fuses. It's the fuse holder.



16 MICHAEL JOHNSTON: Thank you, Mr. Chair. The

17 Correlating Committee found no correlation issues or

18 conflicts with this. And I'd like to defer to the Chair

19 of Code Panel 10, Julian Burns, at microphone number

20 three, please.

21 JULIAN BURNS: Thank you, Mr. Chairman. I am

22 Julian Burns, representing the Independent Electrical

23 Contractors Association, and I am Chairman of Panel 10.

24 As before, we discussed this. We understand that

25 you cannot replace or recondition a medium voltage fuse.



430

1 Also, you should not recondition a fuse clip. The same

2 story, twice again. Thank you.




6 or against the motion. Seeing no one rising, is there

7 any further - is there anything else you would like to

8 add, Mr. Chair?

















25 Certified Amending Motion 70-17. Microphone one.



431

1 BOB TORBIN: My name is Bob Torbin. I am the

2 originator of this public input, and I would move to

3 accept Amending Motion 7-17 to Accept Public Comment

4 808.



7 second?





12 BOB TORBIN: Again, my name is Bob Torbin. I am

13 the Director of Codes and Standards for Omega Flex,

14 manufacturer of corrugated tubing products. And I would

15 move - I would support the Motion to Accept Public

16 Comment 808.

17 The National Fire Protection Association

18 Standards Council previously affirmed that NFPA 54

19 Technical Committee, and not NFPA 70 Technical

20 Committee, would be responsible for setting requirements

21 for the bonding of gas piping. All of the editions of

22 NFPA 54 from 2009 to the - actually, the appending, the

23 currently pending 2021, have requirements for extra

24 bonding of CSST, which is corrugated stainless steel

25 tubing.



432

1 In the 2011 National Electrical Code, an

2 Informational Note was added to alert both electrical

3 contractors and electrical inspectors that additional

4 information for gas piping bonding could be found in the

5 current edition of NFPA 54. However, most electrical

6 contractors and inspectors don't have copies of the

7 National Fuel Gas Code available, or in their truck.

8 Also, according to the National Association of

9 State Fire Marshals, a majority of CSST fires are

10 attributable to a lack of this bonding, in accordance

11 with the code, and the lack of enforcement of the code,

12 due to a lack of coverage in the code.

13 And so this proposal is an attempt to rectify

14 that situation. The proposed change, Public Comment

15 808, to the National Electrical Code, would simply and

16 only include the additional information from NFPA 54, on

17 bonding of gas piping in an Informational Annex, in the

18 National Electrical Code. That is all we're asking

19 here, is to take the information from one code, and

20 provide it to users of another.

21 The benefit of this proposal would be to provide

22 contractors and inspectors a clear and easy access to

23 this critical code requirement on the bonding of gas

24 piping, as it is already stipulated in the National

25 Electrical Code.



433





5 the NEC Correlating Committee. I would like to defer to

6 the Chair of Code-Making Panel 5, Nathan Phillips, at

7 microphone three.

8 NATHAN PHILIPS: Thank you. My name is Nathan

9 Phillips. I'm Chair of Panel 5. I'm representing NECA,

10 and I'm speaking against the motion.

11 Proposals to require additional bonding of CSST

12 in the NEC to protect against lightning events have been

13 brought to Code-Making Panel 5 every cycle since at

14 least 2008. The Committee has voted each time in

15 opposition to these proposals.

16 The failures of CSST reported to CMP 5 have been

17 due to lightning events, not as the result of the use of

18 electricity. Protection of CSST from the effects of

19 lightning is more properly found in NFPA 780, the

20 Standard for the Installation of Lightning Protection

21 Systems.

22 In response to previous Certifying Amending

23 Motions and appeals, the Correlating Committee and the

24 Standards Council have found that this issue is outside

25 the scope of the NEC. The Standards Council assigned



434

1 responsibility for installation requirements for CSST to

2 NFPA 54, the National Field Gas Code. CMP 5 has

3 repeatedly affirmed that the requirements for the

4 bonding of metal piping systems, other than water

5 piping, were likely to become energized, found in

6 250.104(B) are appropriate and adequate for addressing

7 issues within the scope of the NEC. The Committee has

8 received no technical substantiation to suggest

9 otherwise, with respect to CSST.

10 The Committee considered Comment 808, that added

11 an Informational Annex restating the installation

12 requirements for CSST found in NFPA 54. The Committee

13 concluded that adding the proposed Informative Annex

14 would not add value, and would cause correlation issues

15 between the NEC and NFPA 54 when revisions are made to

16 NFPA 54. The installation requirements for CSST are

17 readily available to the public at the NFPA website,

18 where they can be reviewed by installers and AHJs.

19 UNIDENTIFIED SPEAKER: Oh.

20 NATHAN PHILLIPS: In this cycle, the Committee

21 did approve simplifying the existing Informational Note

22 to avoid conflicting section numbers when revisions are

23 made to NFPA 54, and a reference to NFPA 780 was added

24 to provide further guidance on the protection of the

25 CSST systems. The Committee vote was unanimous in



435

1 support of these actions. Thank you.

2 JAMES QUITER: Thank you With that, we will open

3 up debate on the motion. Please provide your name,


5 or against the motion. Microphone two, please.

6 CHRISTINE PORTER: My name is Christine Porter.

7 I'm from Intertek, and I am also the Chair of 780. We

8 are aware that the --


10 CHRISTINE PORTER: I am speaking against the

11 motion. It has been upheld that this is a lightning

12 issue, and not through the use of electricity. The

13 Omega Flex group actually had a rep come to our Second

14 Draft meeting, and together we did create an Annex

15 material discussing how and where to bond the CSST,

16 because we as a Committee disagree with the quantity of

17 bonding, and the lengths of bonding that is recommended

18 in NFPA 54. And for that reason, we urge you to reject

19 this motion.


21 three.



24 Brotherhood of Electrical Workers, and I urge the - I'm

25 speaking in opposition. I urge the body to oppose the



436

1 motion on the floor, for a couple of extremely important

2 reasons.

3 Standards Council Final Decision D Number 10-2

4 very clearly states that bonding of CSST is not within

5 the scope of the National Electrical Code. This does

6 not belong in the NEC. This is a lightning issue. It's

7 a product issue. We never had this issue when we used

8 black iron. Lightning is an extremely powerful and

9 destructive force. When lightning hits any building or

10 structure, there will be differences of potential

11 throughout the building. CSST is an extremely thin wall

12 product; an arc is formed, and you get a pinhole. Then

13 you have a flame thrower.

14 Requirements to bond CSST with a Number Six are

15 ridiculous. There is no way that that would make any

16 difference at all. You can't stop a freight train with

17 a 2 x 4. That's what they're trying to do here, telling

18 you to take a Number Six to the gas manifold. I urge

19 you to reject the motion on the floor.


21 JOHN KOVACHIC: Thank you, Mr. Chairman. John

22 Kovachic, UL LLC, speaking on behalf of the Electrical

23 Section of NFPA as their official representative, and


25 The Electrical Section met on Tuesday of this



437

1 week. During its business meeting, the members voted to

2 not support the motion on the floor. Ladies and

3 gentlemen, I urge you to vote against this motion.

4 Thank you very much.

5 JAMES QUITER: Thank you. And also microphone

6 number two.

7 MITCHELL GETHRIE (phonetic): Thank you.

8 Mitchell Gethrie, representing myself. I've served 10

9 years as the Chair of NFPA 780, and the IEC Committee on

10 Lightning Protection, and selected to be a member of NFP

11 - excuse me, the NFPA Standards Council CSST Task Group.

12 I'm speaking in opposition to the proposal.

13 It removes a reference to NFPA 780, in 250, 104,

14 even though the proposed Annex text clearly states that

15 it's a lightning related threat. I won't repeat some of

16 the other things, but I think it's already been well

17 said that this is certainly a lightning protection

18 problem, and, and really doesn't belong in the NEC. We

19 totally agree with those statements.

20 These - National Association of State Fire

21 Marshals has conducted and posted on their website,

22 fault current testing on several types of CSST, and the

23 results indicate that the grounding and bonding

24 indicated in the proposed Annex text will not be

25 effective for all types of CSST.



438

1 The proposed Annex K contains many errors, and

2 can't appear as listed. There's reference text that -

3 with asterisks that's not included there. And it would

4 reference the version of NFPA 780 that is four revisions

5 old - 12 years old reference.

6 The current edition of NFPA 780, as mentioned by

7 the Chair earlier, contains Annex text that addresses

8 various aspects of the mitigation of the threat

9 presented by lightning, in the presence of CSST. These

10 do not include the maximum values from an analysis using

11 optimistic parameters against a limited threat scenario

12 that's given in NFPA 54. Instead, it identifies

13 measures that could be taken to reduce the susceptible

14 to reaches of CSST resulting from lightning threats.

15 The Annex discusses the use of multiple grounding

16 and bonding points with preferred locations. It

17 discusses minimizing the length of the bonding cable to

18 minimize the voltage differences. And it discusses the

19 benefit of separation distance to increase the level of

20 voltage that, that may develop between CSST and

21 conductive objects, without any hazardous arcing.

22 The - I urge you to vote no on this motion.

23 Thank you.

24 JAMES QUITER: Thank you. Any further discussion

25 on Motion 70-17, to Accept Public Comment No. 808? Mr.



439

1 Johnston?


3 Chair.

4 JAMES QUITER: Thank you. Before we vote, let me




8 motion, and recommend the text on Screen One, vote






14 The results of the vote are: 6 in support of the





19 Certified Amending Motion No. 70-18. Microphone number

20 one.

21 PAUL CABOT: I'm Paul Cabot with the American Gas

22 Association, and I move to Accept an Identifiable Part

23 of Public Comment No. 444.

24 JAMES QUITER: There is a motion on the floor to




440

1 Is there a second?

2 UNIDENTIFIED SPEAKERS: Second that. Second.



5 PAUL CABOT: Paul Cabot, the American Gas

6 Association. I'm in favor of this motion. AGA is

7 seeking to require that the internal sealing of

8 electrical conduits and raceways, where they enter a

9 building or structure. AGA's public input, and our

10 public comment to revise Section 305, this section we're

11 dealing with today, right now, and 350F, which we'll be

12 dealing with in our next motion, both failed the Panel -

13 at the Panel meetings.

14 Section 305 is for underground conduit

15 installations. It's part of the general requirements

16 for wiring methods for installations that have 1,000

17 volts or less.

18 Now, the code currently provides an Information

19 Note that states that where hazardous gasses or vapors

20 may be present, that sealing should be considered. So

21 clearly, the code currently recognizes that this is a

22 hazard.

23 We are - we are - we are seeking to require that

24 - the sealing of all such conduits and raceways, without

25 local installer determination, since installers are



441

1 often unaware that gas service may be near the building.

2 These conduit penetrations are a potential avenue to

3 carry natural gas into a building from an underground

4 gas leak, or other natural sources of methane.

5 Our Association members, which are natural gas

6 utilities that provide gas service to over 95% of all

7 meters in the United States, are committed to help

8 ensuring that our gas distribution systems are leak-

9 free. All have programs to replace aging pipelines, and

10 many are undertaking accelerated pipe replacement

11 programs to further reduce the risk.

12 However, this is a two - we need a two-fold

13 approach. One is what our members are doing, is to

14 minimize underground leaks. And the second one, which

15 is what we're asking the Membership to do, is to provide

16 the seal to make - that may - might - reduce the

17 migration of, of gas leaks into buildings.

18 This change that we had proposed has the support

19 of many organizations, including our membership, the

20 National Propane Gas Association, American Poly Water

21 Company, and the National Utility Contractors

22 Association, NUCA. They, they have sent us a letter in

23 supporting of our members. They couldn't be here today,

24 but they wanted to know, let you know that sealing, that

25 this sealing requirement would, if adopted,



442

1 substantially reduce the risk of injury.

2 Section 305 as I - as I previously stated,

3 recognized the hazard with an Informational Note. So

4 all we're asking is for it to be mandated, not to rely

5 upon a local installer to make a determination. This is

6 a low cost practice that will provide an overall safety

7 benefit to the build environment. Thank you.





12 the Correlating Committee. I would like to defer to the

13 Chair of Code Panel 3, Robert Jones. I believe he's at

14 microphone three.

15 ROBERT JONES: Thank you, Mr. Chairman. My name

16 is Robert Jones. I represent Independent Electrical

17 Contractors, and I am Chair of Panel 3. I speak on

18 behalf of Panel 3 in opposition to the motion.

19 Panel 3 resolved Public Input 3330, which sought

20 to require sealing of all underground conduits and

21 raceways entering a building, with an internal seal, and

22 an outer seal to prevent the entrance of water and

23 gasses. At the First Draft meeting, before the Panel

24 discussed the public input, the submitter gave a

25 presentation, and the Panel members were allowed to



443

1 address the presenter. Panel 3 gave a very lengthy

2 Panel Statement which is public record, that some of the

3 concerns of Panel 3 are: Many installations and

4 buildings do not have the presence of natural gas or

5 fuel gas. A seal can minimize the passage of gas, but

6 cannot prevent it. The entrance of the underground

7 electrical raceways into the building must comply with

8 building codes, which require keeping moisture and other

9 elements out of the building. The proposed revision for

10 Informational Notice 1 and 2 were written in mandatory

11 language, and would not be in accordance with 3.1.3 of

12 the NEC Style Manual.

13 During the Second Draft meeting, Public Comment

14 1126 was rejected, and before the Panel discussed the

15 public comment, the submitters gave a presentation, and

16 Panel members were allowed to address the presenters.

17 Panel 3 gave another lengthy Panel Statement, which is

18 public record.

19 Panel 3 does acknowledge that this issue requires

20 further study, and it is recommended that the

21 Correlating Committee appoint a Task Group composed of

22 the members of Panel 3, 14, and 16 to study the issue.

23 In addition, Panel 3 has requested sending this issue to

24 the Fire Protection Research Foundation for additional

25 study. I ask all voting members to support Panel 3, and



444

1 vote against this motion.




5 or against the motion. Microphone one, please.

6 CRAIG ROAKS (phonetic): Craig Roaks, Southwest

7 Gas Corporation, in support of the motion.

8 This CAM would harmonize this code with the

9 National Electrical Safety Code, where their

10 requirements have existed for over a hundred years.

11 This CAM will reduce the number of moisture incursions

12 into buildings that are currently permitted by this

13 section's vague and permissive text. This section's

14 core requirements are in its first sentence. Introduced

15 in the 1975 edition as part of a code reorganization, it

16 appeared without any explanation or support. It

17 requires seals to be installed in conduits, quote,

18 '...through which moisture may contact live parts.'

19 That's vague and ambiguous, which might make it

20 unenforceable, and dangerous. It would violate the NEC

21 Style Manual, if it applied.

22 And that ambiguity is compounded by the

23 Informational Note. Among other problems, that note

24 doesn't provide information, but instead makes a vague

25 recommendation. It also would violate the Style Manual.



445

1 Now, when the section does mandate seals, it

2 allows only one end to be sealed. So if the conduit

3 enters a building, it can be sealed on the opposite end,

4 but that's ineffective, and dangerous if the underground

5 conduit is subsequently damaged, because it leaves the

6 building unprotected from any moisture that enters the

7 damaged conduit.

8 This CAM eliminates the ambiguities and the risks

9 where it matters the most, requires seals to be

10 installed at the end within the building. It doesn't

11 require additional study.

12 If the text looks familiar, that's not an

13 accident. For example, it replicates the requirement

14 that already exists for sealing all conduits for outside

15 branch circuits and feeders where they enter buildings,

16 in Section 22.27. And it borrows text from the existing

17 requirements for underground conduits that are over a

18 thousand volts.

19 Another benefit of the CAM is that it will reduce

20 the number of preventable explosions, fires, and

21 injuries that have occurred since this section was

22 adopted. That's why I'm here. Moisture isn't the only

23 hazard that exists beneath the underground, and it can

24 enter conduits, and travel into buildings. There's

25 smoke from underground cable fires; small animals that



446

1 can damage live parts; and flammable liquids, gasses,

2 and vapors from a variety of sources, including sewer

3 gas.

4 Now, for comparison, the code mandates fire

5 stopping of electrical conduit penetrations through fire

6 resistance rated walls, because those installations

7 shouldn't substantially increase the spread of an

8 accidental fire. The same can be said of underground

9 conduit penetrations through exterior walls. They

10 shouldn't substantially increase the spread of

11 accidental hazards from the underground environment,

12 that are just as lethal as fire.

13 The National Electrical Safety Code addresses

14 this by requiring inexpensive seals. This code should

15 do that, too. I support this motion because I'm tired

16 of responding to preventable explosions. Please vote

17 yes.


19 MARK ODIE: Mark Odie, from Pearson Engineering,

20 and I'm speaking in opposition to this. I'm a member of

21 Panel 3, and have been for a long time. I'm

22 representing Pearson Engineering, and speaking not on

23 behalf of the Code Panel.

24 The proposed change in 300.5(G) would require all

25 electrical conduits and raceways entering any building



447

1 from an underground installation to be sealed around all

2 raceways. In addition to sealing around the raceway as

3 it enters a building, the proposed change would require

4 an external underground vault, or enclosure with a

5 sealant at grade at the point of entry of any

6 underground raceway into the building. An alternative

7 to the underground vault would be a box or enclosure

8 immediately inside the building, with a sealant to

9 prevent the passage of gas between two nonhazardous,

10 unclassified locations. And that's the - those words

11 are directly from the proposal, and the comment.

12 This would apply to any size or type of

13 electrical raceway, from a half inch, to a six-inch

14 raceway. And I quote from the proposed comment.

15 'Internal seals are warranted whenever an underground

16 conduit enters a building, including used, unused, and

17 spare conduits.' There wasn't any limitation on the

18 application, since the proposed text would apply to

19 branch circuit raceways, feeder raceways, and service

20 raceways. The proposed text would apply to any

21 building, from residential, commercial, to industrial

22 buildings. This proposed text would apply to any

23 building, even those buildings without any natural gas

24 on or near the property.

25 The intent is to establish a seal that will



448

1 separate nonhazardous, unclassified areas from another

2 nonhazardous, unclassified area. The comment stated

3 that installing an underground vault or above ground

4 enclosure with seals would reduce risk of sewer gas,

5 industrial waste gas, cable installation, paralysis,

6 smoke, and the loss of containment from fuel lines or

7 tanks, or other recognized hazards.

8 This public input and comment does not have any

9 technical substantiation to back up those supposedly

10 dire consequences, and stated that the proposed text

11 requires absolutely no study by any task group or

12 foundation, as we had originally intended them to

13 submit. The comment stated that when these sealants

14 are, are absent, preventable building evacuations and

15 explosions with industry - I, I'm sorry, with injuries,

16 have occurred for decades. I have reason to doubt that.

17 And again, the motion should be rejected, and thank you

18 very much for your time.


20 four, please.


22 International, for NAFRA, in support. Beyond the

23 expectation of doom and gloom given by Mr. Odie, I

24 haven't really heard any reason not to, to seal the end

25 of a, of a conduit or raceway entering a building.



449

1 Conduits entering a building - there clearly is the

2 potential for gasses coming through for whatever things

3 coming through. A cheap seal on the other end of a

4 conduit or raceway seems a very reasonable and

5 inexpensive way. Please support the motion.


7 three, please.


9 I move to call the question.


11 to call the question. I notice that there are a couple

12 people remaining at the microphones waiting to speak,

13 but we'll proceed with the vote on the call of the

14 question. Do we have a second?


16 JAMES QUITER: We do have a second. In order to

17 vote on this motion, please scroll down to the bottom of

18 the tablet to vote. If you wish to vote in support of

19 the motion, touch 'Yes'. If you wish to vote against

20 the motion, touch 'No'. Please record your vote





25 motion to call the question. The motion has passed.



450

1 Therefore, we are back to the main motion, which

2 is Motion 70-18. The motion on the floor is to Accept

3 an Identifiable Part of Public Comment No. 444. To


5 support of the motion, and recommend the text on Screen












17 please.

18 PAUL CABOT: I'm Paul Cabot with the American Gas

19 Association. I move to Accept Public Comment Nos. 1470

20 and 1445.

21 JAMES QUITER: 1445 or 445?

22 PAUL CABOT: I mean 445. Sorry.


24 PAUL CABOT: Thank you.

25 JAMES QUITER: There is a motion on the floor to



451

1 Accept Public Comment Nos. 1470 and 445. Is there a

2 second?




6 proceed with a discussion of the motion.

7 PAUL CABOT: Paul Cabot, American Gas

8 Association, in favor of this motion. This motion

9 actually can stand alone. It doesn't - it doesn't

10 depend upon what this Membership just did with the

11 previous one. We think it's a good idea to refer back

12 to one section that covers the sealing of conduits, just

13 to make sure that there's consistency within the code.

14 So I urge the Membership to approve this, this motion.

15 JAMES QUITER: Thank you. Mr. Johnston, any

16 comments for the Panel?



19 the Correlating Committee. I would like to defer to the

20 Chair of Code Panel 3, Robert Jones, at microphone

21 three, please.

22 ROBERT JONES: Thank you, Mr. Chairman. Again,

23 my name is Robert Jones. I'm with the Independent

24 Electrical Contractors, also Chair of Panel 3. I speak

25 in opposition to this motion, on behalf of Panel 3.



452

1 And Panel 3 did see this as exactly the same

2 issue as the one that we just discussed. The only

3 difference is, it's coming out of Section 300.50(F),

4 which is for installations over a thousand votes.

5 Again, I would appreciate you all voting in opposition

6 to this motion.



9 affiliation, and whether you're speaking in support of,

10 or against the motion. Microphone two, please.

11 MARK ODIE: Mark Odie, with Pearson Engineering,

12 and I'm speaking in opposition, and I reiterate what I

13 said before. Panel 3 looked at this and decided that it

14 was the same issue. What they wanted to do in 300.5(G),

15 they were going to just refer from 300.50(F), back to

16 300.5(G). But in, in opposition to that, we voted that

17 down. So again, I suggest that we vote this one down,

18 also.


20 discussion on Motion 70-19 to Accept Public Comment Nos.

21 1470 and 445? Mr. Johnston?


23 JAMES QUITER: Before we vote, let me restate the

24 motion. The motion on the floor is to Accept Public

25 Comment Nos. 1470 and 445. To vote, touch the 'vote'



453





5 vote.







12 Before we continue the debate on NFPA 70, I would

13 like to introduce James Golinveaux, Member of the

14 Standards Council, who will be the Presiding Officer for

15 the remaining motions before the Membership. Mr.

16 Golinveaux.

17 (applause)

18 JAMES GOLINVEAUX: As we announced earlier, we

19 have reordered the next five motions - motions.

20 Discussions on the motions will be held in the following

21 order: 70-21, 22, 23, and 24; and then we will follow

22 up with 70-20.

23 So moving on, let's now proceed with the





454

1 PETER GRASER: Good evening. Yes, my name is

2 Peter Graser. I represent Copperweld Bimetallics, and

3 the American Bimetallics Association. I move to Accept

4 an Identifiable Part of Public Comment No. 1406.

5 JAMES GOLINVEAUX: Thank you. There is a motion

6 on the floor to Accept an Identifiable Part of Public

7 Comment No. 1406. Is there a second? Did I get a

8 second?


10 JAMES GOLINVEAUX: Ah, thank you. Please

11 proceed.

12 PETER GRASER: Again, my name is Peter Graser. I

13 represent Copperweld Bimetallics, as well as the

14 American Bimetallics Association. I would like to - I

15 would like your support for my, my CAM, and it deals

16 with enumerating the text for the requirements of the

17 CAM 721, as well as correcting certain grammatical

18 errors in the text, for the usability - to improve the

19 usability of the CAM, or of the article.

20 JAMES GOLINVEAUX: Okay. Thank you. Mr.

21 Johnston, would you like to offer the Panel's position?


23 were no correlation issues, or conflicts identified by

24 the Correlating Committee on this issue. Because the

25 Chair of Code Panel 6 is not with us, I would like to



455

1 defer to the Chair of Code Panel 7, who has agreed to

2 talk on behalf of Code Panel 6, to this issue. That's

3 Keith Lofland. He is at microphone number three,

4 please.

5 KEITH LOFLAND: Thank you, Mr. Chair. The - I

6 wish to speak against the motion, and on Code-Making

7 Panel 6, they had rejected this at the comment stage,

8 and the, the following Panel Statement - the test data

9 provided in support of the public input and, and comment

10 addresses temperature corrections only. A fact finding

11 investigation is needed that specifically develops a

12 test pattern, and develops test data that supports the

13 proposed changes in the NEC, based on specific code

14 language that's being proposed. This would include

15 overcurrent protection, compatibility with wiring

16 devices, equipment, and other correlation with the code,

17 where 14 American wire gauge, copper clad aluminum would

18 be used.

19 So I stand in opposition of the motion. Thank

20 you, Mr. Chair.

21 JAMES GOLINVEAUX: Thank you. With that, we'll


23 affiliation, and whether you are speaking in support, or

24 against the motion. Microphone four, please.




456

1 Serra Wire. I'm speaking in support of the motion.

2 I'm on Code-Making Panel 6, and of course, I'm

3 not representing Code-Making Panel 6 here today. But I

4 was very involved in the conversations. And, and Mr.

5 Lofland read the, the statement in opposition to this.

6 But this is only to accept an identifiable part. The,

7 the part that we're being asked to accept does not

8 request that we accept the 14 gauge, copper clad

9 aluminum that was the basis of the, the negative from

10 the Code-Making Panel. What we're being asked to accept

11 is, is actually an, an improvement to the usability and

12 readability of this section, and it improves this code

13 section. So I, I would urge you to, to support this


15 JAMES GOLINVEAUX: Thank you. Microphone four.

16 PETER GRASER: Peter Graser, Copperweld

17 Bimetallics, and the American Bimetallics Association.

18 I am in favor of this, this motion.

19 Basically, we're, we're essentially enumerating,

20 and creating logic for this article. We're enumerating

21 the requirements, and we're correcting the grammatical

22 errors that are in the text. And we, we seek your,

23 your, your, your yes vote for this motion. Thank you.

24 JAMES GOLINVEAUX: Thank you. Microphone four,

25 please.



457


2 International, speaking for myself. This seems to be

3 simply editorial reorganization - no technical change.

4 JAMES GOLINVEAUX: Marcelo, are you speaking for

5 or against the motion?

6 MARCELO HIRSCHLER: I'm sorry - speaking for the


8 JAMES GOLINVEAUX: And thank you. Is there any

9 further discussion on Motion 70-21 to Amend an

10 Identifiable Part of Public Comment No. 1406? Mr.

11 Johnston, do you have any final comments?


13 Thank you.

14 JAMES GOLINVEAUX: Thank you, Mr. Chair. Before

15 we vote, let me restate the motion. The motion on the




19 this text on Screen One, touch 'Yes'. If you wish to



22 Five seconds, the voting will be closed.

23 The vote is closed.

24 There are 167 votes in favor of the motion; 230

25 against the motion. The motion has failed.



458

1 Now, let's proceed with the discussion on


3 please.

4 PETER GRASER: Peter Graser of Copperweld


6 I move to Accept an Identifiable Part of Public Comment

7 No. 1406.

8 JAMES GOLINVEAUX: Thank you. There's a motion

9 on the floor to an accept - to Accept an Identifiable

10 Part of Public Comment No. 1406. Is there a second?


12 JAMES GOLINVEAUX: I do have a second, so please

13 proceed with the discussion.



16 I urge this Membership to vote yes for this motion. The

17 aim of this motion is to seek a listing requirement for

18 the bimetallic material. It is absolutely essential

19 that this listing requirement be part of this code. It

20 is virtually impossible to know, by looking, if a piece

21 of bimetallic copper clad aluminum meets the

22 requirements of ASTM, and of this code, by not having it

23 tested. You - it is absolutely essential that this

24 listing requirement be in, in, in place so that the user

25 knows that it's a true bimetal with a true metallurgical



459

1 bond. Thank you.

2 JAMES GOLINVEAUX: Thank you. Mr. Johnston,

3 would you like to offer the Panel's position, please?



6 the Correlating Committee. I would like to defer once

7 again to the Chair of Code Panel 7, Keith Lofland, at

8 microphone three, on behalf of Code Panel 6.

9 KEITH LOFLAND: Thank you, Mr. Chair. Keith

10 Lofland, representing the International Association of

11 Electrical Inspectors, and I stand in opposition to this

12 motion. The sitting Chair of Panel 6 asked me to read

13 the following statement: The motion is seeking to add

14 copper clad aluminum conductors shall be listed. While

15 the NEC does require listing of equipment at Section

16 110.3, I cannot find a separate article or section that

17 clearly states copper clad or aluminum conductors shall

18 be listed. Therefore, why would we arbitrarily add

19 copper clad aluminum conductors to be listed at this

20 location. There are already standards in place which

21 will abide the manufacturer of these conductors. The

22 finished product is listed, such as covered in the

23 wording at 110.3(a) through (c). Thank you, Mr. Chair.





460


2 support, or against the motion. Microphone number four,

3 please.


5 International, for the Vinyl Institute, in support.

6 I don't see any reason why, to oppose this.

7 Within this section, copper clad aluminum conductors are

8 already included. So what the proponent is asking for

9 is to make it tougher for themselves by requiring that

10 they be listed. That doesn't decrease safety. In fact,

11 it will increase safety. He is not adding copper clad

12 aluminum conductors to the, to this section. They are

13 already in this section; already permitted. He is

14 making it more difficult, safer for them to be included

15 here. Please support the motion. Thank you.

16 JAMES GOLINVEAUX: Thank you. Microphone five,

17 please.

18 RODRIGO BURN (phonetic): My name is Rodrigo

19 Burn. I'm with Condocell (phonetic) from El Salvador,

20 and I am also with the American Bimetallics Association.

21 I support the motion on the floor.

22 We, as copper clad aluminum manufacturers, we

23 think it's important to have a listing on the product.

24 We are trying to protect the final consumer in the

25 markets from substandard product. And actually, copper



461

1 clad aluminum in - wire and electrical conductor up to

2 200 volts is already being used in Latin American and

3 the Caribbean since probably eight, 10 years ago, and

4 we're started to see an increase in substandard product,

5 not complying with the code requirements already stated

6 for copper clad aluminum, and the ASTM standards. So I

7 urge you to, to support our motion. Thank you.

8 JAMES GOLINVEAUX: Thank you. Microphone three,

9 please.


11 Jack Lyons, represent NEMA Codes and Standards

12 Committee. And they are - I'm just stating their

13 opposition to the Motion to Accept the Identifiable Part

14 in PC 1406, related to listing of copper clad aluminum.

15 Thank you.

16 JAMES GOLINVEAUX: Thank you. Microphone number

17 four, please.

18 CHARLES MELLOW (phonetic): My name is Charles

19 Mellow. I am CDC Mellow Consulting, speaking on the

20 behalf of copper clad aluminum - Copper - or Copperweld

21 Bimetallics.

22 Copper clad aluminum is a manufactured product.

23 It's very critical that it be --

24 JAMES GOLINVEAUX: Are you for or against the

25 motion?



462

1 CHARLES MELLOW: I am for the motion. It is very

2 critical that the metallurgical bonding be verified.

3 This can only be done by a testing a laboratory, through

4 a listing process. It cannot be done in the field; you

5 don't know that it's (unintelligible), as previously

6 just stated - not to repeat a 'me, too' - but there is

7 substandard material where it's a copper plated

8 aluminum, not a copper clad aluminum being put on the

9 market, and being stated as copper clad aluminum.

10 It's very critical for the safety in the

11 installation for the installers and inspectors to have

12 the knowledge that this is a suitable conductor. Thank

13 you.


15 four, please.


17 Domitrovich with Eaton. Two things --

18 JAMES GOLINVEAUX: Are you speaking for, or

19 against?

20 THOMAS DOMITROVICH: Oh, I'm sorry - speaking for

21 the motion that's on, on the floor - on the table.

22 First of all, the - it should be copper, not

23 Copper Clad Aluminum, I believe. But this, this

24 proposal - this, this change - as, as well as the

25 previous one, they're both not major changes. The



463

1 previous one was just a wording issue, and this is a, a

2 listing requirement, which we should be for listed

3 solutions being used in the field. So I speak in

4 support of the motion on the table. Thank you.


6 one, please.

7 FRED HARTWELL: Thank you, Mr. Chairman. This is

8 Fred Hartwell, and I have to say, in listening to the --



11 FRED HARTWELL: I'm speaking in favor of the

12 motion. I, I have to say, in listening to the statement

13 from Panel 6, I find it absolutely preposterous. By

14 that language, we should not have listing requirements

15 anywhere in the code, you know, by that line of

16 reasoning. This is a perfectly reasonable requirement.

17 I don't know how in the world any AHJ is going to be

18 able to figure out, in the field, what the percentage of

19 copper is on a piece of wire. This is - this absolutely

20 should be listed.

21 JAMES GOLINVEAUX: Is there any further

22 discussion on Motion 70-22 to Accept an Identifiable

23 Part of Public Comment No. 1406? Mr. Johnston, do you

24 have any final comments?

25 MICHAEL JOHNSTON: I have nothing further to add,



464

1 Mr. Chair.

2 JAMES GOLINVEAUX: Thank you. Before we vote,


4 to Accept an Identifiable Part of Comment No. 1406. To


6 support of the motion, and recommend the text on Screen






12 There are 327 votes in favor of the motion; 71

13 against. The motion has passed.

14 Now let's proceed with the, the discussion on


16 please.

17 PETER GRASER: Mr. Chair, I request to discuss

18 Certified Amending Motion 70-24 before 70-23, if that's

19 possible.

20 JAMES GOLINVEAUX: I'll be with you in one

21 second.

22 UNIDENTIFIED SPEAKER: Do you want me to

23 (unintelligible)?


25 JAMES GOLINVEAUX: We are going to move, at your



465

1 request, to 70-24, unless I get any dramatic response on

2 this. I don't think it's going to affect too much here.

3 So I will, I will do that. I will move to 70-24, and

4 then I'll come back to 70-23, and then we'll follow up

5 with 70-20, as I originally stated.

6 So let's now proceed with the discussion on


8 please.

9 PETER GRASER: Yes. Peter Graser, Copperweld

10 Bimetallics; also the American Bimetallics Association.

11 I move to Accept an Identifiable Part of Public Comment

12 No. 1382.


14 on the floor to, to Accept an Identifiable Part of

15 Public Comment No. 1382. Is there a second?

16 UNIDENTIFIED SPEAKER: Second. Second.

17 JAMES GOLINVEAUX: We do have a second. Please


19 PETER GRASER: Yes. Peter Graser, from

20 Copperweld Bimetallics; the American Bimetallics

21 Association. I urge you to, to vote in favor of this

22 Certified Amending Motion.

23 Essentially, it's important for the Membership to

24 know that copper clad aluminum, aluminum, and copper,

25 are different metals altogether. They have their own



466

1 voltage potentials; they have their own rates of

2 corrosion; they have their own weights. They also have

3 their, their own resistance, and as well, their own ASTM

4 material certification numbers. So by, by all measures,

5 they're, they're different metals.

6 Essentially, the way that 310.16 and 310.17 read

7 currently, which are quite possibly the most referenced

8 tables in all of wiring methods - the reader only sees

9 two metals - aluminum, and copper. If they see aluminum

10 - if they see copper clad aluminum at all, they feel

11 like it's, it's aluminum. So this, this motion attempts

12 to create improved usability for the reader by

13 separating out the three metals. In, in this Certified

14 Amending Motion, there, there would be three columns,

15 each with its unique metal, and each with its unique

16 temperature, temperature columns - 60 degrees, 75

17 degree, and 90 degrees.

18 So this is important, because in the Second

19 Revision, 7736 and 7739, 14 gauge copper, copper clad

20 aluminum is, is a viable conductor for TC and MC cable

21 for control, remote control, and signal wire. It's -

22 that, that's significant because those are Class 1

23 wires. So those wires require a, a - they can carry up

24 to 600 volts. At 600 volts, that's the same voltage

25 that, say, residential branch service wire would have.



467

1 So it's, it's important that that be protected. And in

2 fact, in 725-34, there's a requirement for 14 gauge

3 overprotection. And so obviously, there has to be some

4 values set, set place.

5 So this chart, the new sets of, sets of tables

6 allow for that.

7 JAMES GOLINVEAUX: I'm sorry. Your time has

8 expired. Mr. Johnston, would you like to offer the

9 Panel's position?



12 the Correlating Committee on this issue. I'd like to

13 deer to the Chair of Code Panel 7, Keith Lofland, on

14 behalf of Code Panel 6. He's at mic three, I believe.

15 KEITH LOFLAND: I'm here. Thank you, Mr. Chair.

16 Keith Lofland, the International Association of

17 Electrical Inspectors, speaking on behalf of Code-Making

18 Panel 6.

19 And what this motion is seeking is to add

20 additional columns to the most widely used table in the

21 entire code book. And the Chair of Panel 6, anyway -

22 I'm not sure about the whole Panel, but the Chair of

23 Panel 6 feels like this would just add complexity to an

24 already semi-complex table; and, and the, the values,

25 the ampacity values in the added columns would be



468

1 identical to the ones for aluminum, once you get past 14

2 American wire, wire gauge. So I stand in opposition of

3 the motion. Thank you very much.


5 open up the debate on this motion. Please - please


7 speaking in support, or against the motion. Microphone

8 three, please.

9 JACK LYONS: I'm Jack Lyons, represent NEMA Codes

10 and Standards Committee, that state their opposition to

11 the Motion to Accept the Identifiable Part in 1382

12 related - I'm sorry, for 13 - yeah, 1382, related to the

13 ampacity table, 16 and 17.

14 JAMES GOLINVEAUX: Okay. Microphone two, please.


16 Serra Wire, opposing the motion. As, as Mr. Lofland

17 read on one of the earlier, the earlier motions, the

18 Code-Making Panel, Code-Making Panel 6 did consider a

19 tremendous amount of data around the issue of adding 14

20 gauge copper clad aluminum. In this case particularly,

21 adding 14 gauge copper clad aluminum will result in

22 conflicts within the NEC. Unlike 14 gauge copper, and

23 other smaller conductors, 14 gauge copper clad aluminum

24 is not addressed in 240.4(D) for overcurrent protection

25 of small conductors. The result is that a 14 gauge



469

1 rated at 10 amps will be permitted on a 15 amp circuit

2 breaker. This creates a serious safety concern that

3 needs to be addressed before we add 14 gauge copper clad

4 aluminum.

5 Right now, none of our switches, receptacles, or

6 other equipment are tested with 14 gauge copper clad

7 aluminum conductors. There are 10 amp breakers on the

8 market, but they have not been tested with 14 gauge

9 copper clad aluminum conductors. Traditionally, the

10 minimum standard size, standard ampere rating in Table

11 240.6(A) is 15 amps. And while there may be opportunity

12 to add this conductor size in the future, we're going to

13 have to do a lot more work in the NEC to make sure that

14 installations are done safely.

15 As I mentioned, I'm a member of Code-Making Panel

16 6. Information was submitted to the panel that proves

17 that copper clad aluminum runs hotter than 14 gauge

18 copper, as we expected. If you support this motion, you

19 would be supporting the substation of 14 gauge copper

20 clad aluminum in place of 14 gauge copper, on 15 amp

21 breakers, which will run hotter than what is currently

22 allowed.

23 And as in the - as previously discussed by one of

24 the other, the other speakers, this will significantly

25 reduce the usability and readability of this table by



470

1 adding all of those extra columns. We'll go from six

2 columns of ampacity values, to nine columns of ampacity

3 values. And in every - in almost - in every case except

4 for the one that, that is being requested be added to

5 the table, the values are exactly the same for aluminum,

6 and for copper clad aluminum. So I'd request that you

7 please oppose this motion. Thank you.


9 please.

10 CHARLES MELLOW: Charles Mellow, CDC Mellow

11 Consulting, speaking on the behalf of Copper clad -

12 Copperweld. I am speaking in favor of the motion.

13 We have a chicken and egg problem here, you know,

14 where a number of public inputs and public comments

15 submitted to the panels, including for Panel 10, for

16 240.4(D). Panel 10 decided not to act on it because

17 Panel 6 did not set up the ampacity.

18 To do the testing as was stated here on the

19 circuit breakers on the devices, one has to have an

20 ampacity for the conductor. And I want to bring up what

21 the definition of ampacity is, from Article 100. The

22 maximum current in amperes that a conductor can carry

23 continuously under the conditions of use, without

24 exceeding its temperature rating.

25 If you look at the conditions of use, as stated



471

1 by Panel 6 in 310.16, the conditions are: Conductors

2 are rated 0 to 2000 volts; conductors are rated 60

3 degrees c; 75 degrees c; or 90 degrees c, which is the

4 insulation classes. Wiring is installed in a 30 degree

5 c ambient, and there are not more than three current

6 carrying conductors.

7 310.17 is similar requirements, except you don't

8 have the - it's air, it doesn't have the three conductor

9 limit.

10 The issue here is, the ampacity needs to be set

11 for the conductor. Credible testing was done by a

12 recognized testing laboratory, and additional testing

13 was done by a different credible lab, recognized testing

14 laboratory, between the stages, and submitted with the

15 public comment. So we need to get the ampacity set, so

16 that we can go on and do future testing. We realize

17 that you're going to have some correlation issues as we

18 go down the road with this.

19 But I encourage the panel here, the Membership,

20 to accept this ampacity, get it in the table so that we

21 can move forward. Thank you.

22 JAMES GOLINVEAUX: Thank you. Microphone six,

23 please.

24 PHIL SIMMONS: Thank you, Mr. Chairman. My name

25 is Phil Simmons, and I'm speaking on behalf of myself.



472

1 And I urge the body here --



4 PHIL SIMMONS: Ooh, well, I'm standing behind the

5 against --

6 JAMES GOLINVEAUX: Oh, don't start with that.

7 (laughter)

8 PHIL SIMMONS: Yes, I'm against.

9 JAMES GOLINVEAUX: We, we - we need a verbal. We

10 need a verbal on your description for the record,

11 please.

12 PHIL SIMMONS: Oh, okay. Well --

13 JAMES GOLINVEAUX: It's not about the color.

14 PHIL SIMMONS: I'm speaking against.

15 JAMES GOLINVEAUX: Thank you.

16 PHIL SIMMONS: Okay. I urge the body to, to

17 reject this motion, 70-24. Accepting it would introduce

18 a serious conflict in the, in the code, because they're

19 proposing an ampacity for 14 gauge copper clad aluminum.

20 And if you look at 310.3, it says the minimum size

21 conductor is No. 12 copper clad aluminum. And 310.3(A)

22 doesn't even allow No. 14 copper clad aluminum.

23 So 70-20, excuse me, the motion, intends to fix

24 that. But when you read through that motion, it, it, it

25 would read - the minimum size of conductors for voltage



473

1 ratings up to and including 2,000 volts shall be 14 AWG

2 copper, and copper clad aluminum; or 12 AWG - nothing -

3 because it's all struck out - except it's permitted

4 elsewhere in the code. You couldn't even use aluminum,

5 if 70-20 is accepted. So it seems like we have to

6 delete, or not accept 70-24.


8 five, please.

9 RODRIGO BURN: Rodrigo Burn with Condocell

10 (phonetic), and the American Bimetallics Association. I

11 support the motion, and I'll try to break it down, my

12 two arguments.

13 As an ABA member, our, part of our mission is to

14 educate the public about what's a bimetallic, what's

15 copper clad aluminum, or copper clad steel. It

16 certainly - it's not copper; it's not aluminum. It's a

17 different metal, and one of the three legitimate metals

18 that are already recognized in code for our

19 applications.

20 So I think it's - it gets kind of confusing if

21 you get the aluminum and the copper clad aluminum on the

22 same columns. And trust me, in Latin America, and

23 Central America, and the Caribbean, the people often

24 think that copper clad aluminum, it's aluminum. So

25 copper clad aluminum terminates just like copper, and



474

1 it's a dissimilar metal than the aluminum. So it poses

2 a safety issue, that you have people thinking that

3 copper clad aluminum, and aluminum are the same thing;

4 they could intermix the two metals in a connector, or,

5 or what - it imposes a, a, a, a threat from that stand -

6 point of view.

7 And in regards of 14 AGW, the - I think the CAM

8 70-20 intends to include on the article already

9 mentioned, 14 AGW, copper clad aluminum. And enough

10 fact finding testing was presented to the Code-Making

11 Panel 6 from three different nationally recognized

12 testing labs that supports that 10 amps for 60 degrees

13 c, copper clad aluminum 14 AGW is safe, and it's really

14 viable, and it's not even close to the limit of the, the

15 temperature for that column.

16 So I urge, urge you to support the motion. Thank

17 you very much.

18 JAMES GOLINVEAUX: Thank you. Microphone one.

19 EDDIE GEDRY: Eddie Gedry, speaking for myself,

20 and thank you, Mr. Chair for clarifying that the color

21 of the sign, and the text does not indicate viewpoints.

22 With that, I call the question.


24 JAMES GOLINVEAUX: All right. I'm going to give

25 you that one. You're not supposed to state a, any part



475

1 of a comment, but I'll give it to you because you're

2 giving me a compliment.

3 (laughter)

4 JAMES GOLINVEAUX: There's a motion on the floor

5 to call the question. I notice there are a number of

6 people remaining at the microphones waiting to speak,

7 but I'll proceed on the vote on the call on the



10 JAMES GOLINVEAUX: We do have a second. In order

11 to vote on this motion, please scroll down to the bottom

12 of the tablet to vote. If you wish to vote in support

13 of the motion, touch 'Yes'. If you wish to vote against

14 the motion, press - touch 'No'. Please record your

15 vote.

16 Five seconds.


18 The results are 387 in favor of calling the

19 question; 10 against. So the, the motion is passed to

20 call the question.

21 Therefore, before we vote, let me restate the

22 motion. The motion on the floor is to Accept an

23 Identifiable Part of Public Comment No. 1382. To vote,





476






6 The results are: 68 in favor of the motion; 349


8 Returning now as requested from the submitter,

9 we're going to go to Motion 70-23.


11 JAMES GOLINVEAUX: So on 70-23, microphone four,

12 please.

13 PETER GRASER: Yes. Peter Graser, Copperweld

14 Bimetallics; the American Bimetallics Association. I

15 move to Accept an Identifiable Part of Public Comment

16 No. 1382.



19 Comment No. 1382. Is there a second? Is, is there a

20 second?


22 JAMES GOLINVEAUX: Okay. I got to - I need to

23 hear something. Thank you. We do have a second.

24 Please just continue with the discussion on the motion.

25 PETER GRASER: Mr. Chair, I would like to



477


2 JAMES GOLINVEAUX: You - I'm sorry - you would

3 have had to do that before you made the motion --

4 PETER GRASER: Okay. I'm sorry.

5 JAMES GOLINVEAUX: -- and I had a second. So --

6 PETER GRASER: Yeah, sorry about that.

7 JAMES GOLINVEAUX: If you want to put a bad

8 argument, that's your choice.

9 (laughter)

10 JAMES GOLINVEAUX: I - yeah, I have to proceed

11 with the motion, since it was made, and seconded.

12 PETER GRASER: Great.

13 UNIDENTIFIED SPEAKER: All - you had your

14 (unintelligible).

15 UNIDENTIFIED SPEAKER: Call the question.

16 JAMES GOLINVEAUX: So you --

17 PETER GRASER: So - I call for question.


19 PETER GRASER: Call for question.

20 JAMES GOLINVEAUX: Oh, God, I can't.

21 UNIDENTIFIED SPEAKER: You can. Come on.


23 JAMES GOLINVEAUX: I - if you want to finish; if

24 that's your statement - I can't call the question --

25 UNIDENTIFIED SPEAKER: Right.



478

1 JAMES GOLINVEAUX: -- based on you had a, a, a

2 positive response to make the motion. So I will go

3 ahead and go with the Chair's position.

4 PETER GRASER: Okay.

5 JAMES GOLINVEAUX: And if you want to speak

6 against your own motion, please feel free to do so, but

7 I believe I have to proceed with the motion.

8 PETER GRASER: Okay.

9 JAMES GOLINVEAUX: Okay. So I'll, I'll accept --

10 UNIDENTIFIED SPEAKER: Well --

11 JAMES GOLINVEAUX: -- that you're done. Mr.

12 Johnston, do you have any comment from the Panel?

13 MICHAEL JOHNSTON: Nothing from the Correlating -

14 -

15 JAMES GOLINVEAUX: From the Chair?

16 MICHAEL JOHNSTON: -- Committee, Mr. Chair. But

17 I would like to defer to the Chair of Code Panel 7, who

18 is speaking on behalf of Code Panel 6, Keith Lofland, at

19 microphone 3, please.


21 Lofland, representing IAEI; Chairman of Code-Making

22 Panel 7, speaking on behalf of Code Panel 6, and stand

23 in opposition to the motion. And I've got to admit, you

24 guys have me so confused, that I, I was arguing this one

25 the last time I was up here, so I've already said what I



479

1 needed to say --

2 (laughter)

3 KEITH LOFLAND: -- that adding these extra

4 columns would just confuse the matter and, and I think

5 we've already hashed and discussed all that pretty

6 thoroughly.

7 JAMES GOLINVEAUX: Perfect. Thank you. Is there

8 any other comments - now I've got to flip my page. Are

9 there any further discussion on Motion 70-23 to Accept

10 an Identifiable Part of Public Comment No. 1382? Seeing

11 none - Mr. Chair, do you have any final comments?

12 MICHAEL JOHNSTON: Thank you, Mr. Chair. I have

13 nothing further. Thank you.

14 JAMES GOLINVEAUX: Thank - thank you. Before we



17 Comment 1382. To vote, touch the 'vote' button. If you

18 wish to vote in support of the motion, and recommend the






24 There were 55 in favor of the motion; and 356

25 votes against the motion. The motion has failed.



480

1 Now, proceeding to the discussion on Certified

2 Amending Motion 70-20. Microphone four, please.

3 PETER GRASER: Mr. Chair, we would like to


5 (laughter)

6 JAMES GOLINVEAUX: Thank you. You have to

7 identify yourself, please.

8 (applause)


10 Bimetallics.


12 PETER GRASER: And the American Bimetallics

13 Association. Thank you.

14 JAMES GOLINVEAUX: The next motion, 70- - NFPA

15 70-20 appeared on our Agenda. However, the authorized

16 maker of the motion, or the designated representative

17 has notified NFPA that he no longer wishes to pursue

18 this motion. Therefore, in accordance with the NFPA



21 the Agenda. We'll now move to the next motion.

22 The next motion of NFPA 70, 70-25, appeared on

23 our Agenda. However, the authorized maker of the motion

24 has notified NFPA that he no longer wishes to pursue

25 this motion. Therefore, in accordance with the NFPA



481



3 the Agenda. We'll now move to the next motion. I told

4 you I'd move this along.

5 (laughter)

6 JAMES GOLINVEAUX: Now let's proceed with the


8 Microphone four.

9 CHRIS HUNTER: Thank you. Christel Hunter with

10 Serra Wire. I make a Motion to Accept Public Comment

11 No. 1502.


13 on the floor to Accept Public Comment No. 1502. Is

14 there a second?


16 JAMES GOLINVEAUX: I heard a second. Before we

17 begin on this, the phrase, in parentheses, (that there

18 are four stories or fewer), that appears in No. 2 of

19 both the recommend text for passes or fails, was

20 included in the - in the Agenda in error. The text

21 which appears on the screens behind me reflect the

22 correct text. Please proceed.



25 The language that's being requested mirrors



482

1 allowances that have been in place in Massachusetts and

2 Michigan for decades. In the 1975 NEC, a three story

3 limitation for the use of nonmetallic sheath cable was

4 put in place. The states of Massachusetts and Michigan

5 amended the NEC to permit the use of NM cable in

6 buildings above three stories, and has been widely used

7 in mid-rise and high-rise buildings over the last four

8 decades. During this time, the use of nonmetallic

9 sheath cable in these buildings has been proven to be a

10 safe and reliable wiring method.

11 In the 2002 NEC, the three story limitation was

12 removed, and the use NM cable was tied to the building

13 construction type. Right now across the country, NM

14 cable is being used in multifamily dwellings,

15 warehouses, offices, retail buildings, and other

16 applications.

17 To give you an idea of the prevalence of NM

18 cable, the EPA reported that over eight billion feet of

19 NM cable was installed in 2007. Billions of feet are

20 installed every year, and most of us live in homes that

21 are wired with NM cable. There's no reason to believe

22 that NM cable would behave differently on the first

23 floor, the fourth floor, or the tenth floor of a

24 building. There are already code requirements for

25 physical protection of the cable - steel plates to



483

1 protect from nail penetrations; grommets to protect it

2 when pulled through steel framing; and other code

3 requirements that limit the potential for physical

4 damage. All the provisions are in place to use this

5 cable safely. So why change the code now?

6 We now have an additional 20 years of experience

7 in multiple areas where NM cable has been permitted, and

8 extensively used in these exact installations, with no

9 indications to support any safety concerns. In fact,

10 we've seen just the opposite. In the 2011 NEC code

11 cycle, the representative from the Massachusetts

12 Electrical Advisory Board put on the record that they

13 had no incidents tied to the use of these - this cable

14 in those applications. I had the opportunity to, to

15 speak with that representative again this week - you

16 know, it's been nine years - to see if there were any

17 changes, and the answer was no - no issues with using NM

18 cable in the applications that are being requested.

19 Thank you. Please support the motion on the floor.



22 MICHAEL JOHNSTON: There were no correlation

23 issues, or conflicts identified by the Correlating

24 Committee. And I'd like to defer to the Chair of Code

25 Panel 7, talking on behalf of Code Panel 6, at



484

1 microphone three, please.


3 Lofland, International Association of Electrical

4 Inspectors, speaking on behalf of Code-Making Panel 6.

5 This issue was addressed during the 2002 code

6 cycle, and a Task Group was formed at that time to look

7 at this, and the end result of that was that they

8 determined that the National Electric Code didn't need

9 to be in the business of dealing with the construction

10 types, and that that was better suited for the Building

11 Code. And so that's where we came to - where we had the

12 types of constructions that we have today that's

13 discussed.

14 So on behalf of the Chair of Code-Making Panel 7,

15 I stand in opposition of this motion. Thank you very

16 much.



19 name, affiliation, and whether you're speaking in

20 support, or against the motion. Microphone three,

21 please.


23 Jack Lyons, represent NEMA Codes and Standards

24 Committee, to state their opposition to the Motion to

25 Accept Public Comment 1502 related to building types and



485

1 uses permitted. Thank you.


3 please.


5 International, speaking for, for the Vinyl Institute.

6 The opposition by --



9 MARCELO HIRSCHLER: So I'm speaking in favor of

10 the motion. I apologize. Thank you.

11 JAMES GOLINVEAUX: No - no worries.

12 MARCELO HIRSCHLER: I'm speaking in favor of the

13 motion. The opposition expressed by the Chair of Panel

14 6, stating that types of construction should not be in

15 the NEC, makes no sense when you look at Item 2, which

16 talks of Types 3, 4, 5, construction; Item 4 talks about

17 Types 3, 4, 5 construction. Item 5 talks about Types 3,

18 4, 5 construction. So why - what's wrong with adding

19 Type 1 and 2 construction, which is what this - is

20 proposed to be added. And ask - Ms. Hunter just said

21 this has been in, in two state codes for many years

22 without any unsuccessful use. Please support the


24 JAMES GOLINVEAUX: Thank you. Microphone 3,

25 please.



486

1 DALE CRAWFORD: Dale Crawford, Steel Tube

2 Institute, speaking against the motion.

3 This motion would permit NM cable to be used in

4 Type 1 and Type 2 building type constructions. These

5 building types are, by definition, constructed of

6 noncombustible building materials, and they cannot have

7 combustible materials, and have very stringent smoke

8 development and flame spread indexes. NM cable does not

9 meet any of these standards. Because of this, soft-

10 jacketed NM cable is a wiring method that is not fully

11 compatible with Type 1 and Type 2 construction,

12 regardless of the occupancy, or the use of the building.

13 It is simply not an appropriate cable and building

14 material for these type of buildings. These buildings

15 tend to be very large, and very tall buildings, with

16 very high levels of occupancy, having shared

17 environmental air conditions - conditioning systems.

18 Combustible wiring methods and materials could result in

19 significant hazards under fire conditions, or if faults

20 on the electrical system were to occur.

21 Type 1 and 2 construction are those types of

22 construction in which the building elements listed in

23 Table 601 are of noncombustible materials, except as

24 permitted in Section 603 and elsewhere in this code.

25 Section 603 consists of criteria dealing with the flame



487

1 and smoke spread limitations, or some other testing

2 standard.

3 603.1.3 enforces this by saying the use of

4 electrical wiring methods with combustible insulation,

5 tubing, raceways, and related components shall be

6 permitted where installed in accordance with the

7 limitations of this code.

8 Some of these limitations are - tell us - are

9 outlined in Chapter 7 and Chapter 9 - for example, 703.2

10 tells us the fire resistive rating of building elements,

11 components, or assembly shall be determined in

12 accordance with the test procedures set forth in ASTM

13 E111, or UL 263, or in accordance with 703.3.

14 It should also be noted that just because this is

15 allowed in one or two states, that this is not a

16 sufficient reason to push this change through for all 50

17 states. This may be allowed in one jurisdiction, but it

18 does not mean that it is a standard or advisable

19 construction practice in those areas. Reference to

20 local codes is inappropriate, since they are not

21 nationally recognized. Installation practices vary

22 throughout the country. If we wanted to use local

23 jurisdiction for substantiation to change the national

24 code, then I would point to the use of Chicago as an

25 example, to require all branch circuits be done in steel



488

1 conduit.

2 No technical substantiation has been provided to

3 support the expansion of the use of soft-jacketed cable

4 for use in these building types. NM is a combustible

5 building material, and should not be allowed in a

6 noncombustible building type. Please vote against this

7 motion.

8 JAMES GOLINVEAUX: Thank you. Microphone three

9 again, please.

10 GEORGE STRANIERO: I'm George Straniero with AFC,


12 The level of mechanical production of fire

13 resistance currently provided by the NEC for multifamily

14 occupancy in Type 1 and 2 buildings, is represented by

15 conduit type wiring methods, and by metallic sheath

16 cables. These wiring methods provide a high level of

17 mechanical protection, and possess an inherent ability

18 to resist flame ignition, propagation, and smoke.

19 Permitting NM cable for multifamily occupancies

20 in Type 1 and Type 2 buildings is simply extreme

21 reduction in the level of mechanical protection and fire

22 resistance of the wiring method.

23 The public comment does not provide any

24 substantiation as to why a lower level of performance is

25 warranted, or that the construction of NM has been



489

1 increased so as to provide a higher level of

2 performance. I request that you vote against the, the

3 motion on the floor. Thank you.

4 JAMES GOLINVEAUX: Thank you. I'm going to go

5 with microphone four, please.



8 There was a comment about noncombustible wiring

9 types being required in Type 1 and Type 2 buildings.

10 What's interesting is that the National Electrical Code

11 right now allows electrical nonmetallic tubing, commonly

12 known as smurf tube, in Type 1 and Type 2 buildings, of

13 unlimited height. The Building Code does not restrict

14 these writing types. The Building Code does have

15 requirements, but it refers to the National Electrical

16 Code for those wiring types.

17 And the, there was a, a comment that the public

18 comment didn't give substantiation for why a lower bar

19 should be set, essentially - because we're not setting a

20 lower bar. We've already seen that this cable can be

21 successfully used in Type 1 and Type 2 buildings. As a

22 matter of fact, it is already used in Type 1 and Type 2

23 buildings. The reason that Item 2 says multifamily

24 dwellings permitted to be of Types 3, 4, and 5 - and

25 the, the reason that term and that phraseology is used,



490

1 is there are already buildings that are Type 1 and Type

2 2, but that could have been designated Type 3, 4, and 5.

3 So it is appropriate for Type 1 and Type 2 buildings.

4 Thank you.

5 JAMES GOLINVEAUX: Thank you. I have three

6 gentlemen over here that were in line at the same time.

7 Microphone three.

8 JOE ANDRE: Thank you. Joe Andre, from the Steel

9 Tube Institute, rising in opposition.

10 I'll address the comment that was just made about

11 ENT. And it's true that it is allowed. But there are

12 restrictions about where you can use that. It has to be

13 behind a 15-minute finish rating. Those words don't

14 appear here - not that people would do it very often,

15 but adopting this would allow an M cable to be run

16 exposed in Type - in noncombustible buildings. That's

17 pretty scary.

18 The other thing that I just want to mention is, I

19 just want to refer back to the Panel's statement when

20 they rejected this. And it, it said this was

21 extensively reviewed by the Code-Making Panel, and by a

22 Task Force back in the 2002 edition of the NEC, and it

23 referred to extensive documentation. We couldn't read

24 all it and finish in this week the amount of document in

25 opposition.



491

1 I'll refer also to those days when there was an

2 ICC electrical code that had very similar language, and

3 the entire electrical industry rose up in opposition to

4 that. And I think it's notable to remember that not a

5 single manufacturer of NM cable supported the ICC

6 expansion, very similar to what we're doing here. So I

7 urge you to reject this proposal.

8 JAMES GOLINVEAUX: Thank you. Microphone two.

9 FRED HARTWELL: Thank you. Fred Hartwell, and I

10 imagine there are some people --

11 JAMES GOLINVEAUX: Are you - are you speaking

12 for, or against?

13 FRED HARTWELL: So I'm speaking against the

14 motion. And I imagine there are a number of people in

15 here that are kind of expecting, as the Secretary of the

16 Massachusetts Committee, that I might be speaking in

17 favor of it. I'm not.

18 And the reason is that the - and, and we do

19 address this in Massachusetts, and we do allow it, but

20 only behind a fire finish. And we take the requirement

21 for smurf tube, and allow this in a, an application

22 that's the same as the National Electrical Code does

23 allow for smurf tube. And so that is a fundamentally

24 different situation than is presented in this motion.

25 And although I have some - I, I'm fascinated by the



492

1 motion, and I have some sympathy for it, but I cannot

2 support it.

3 JAMES GOLINVEAUX: Thank you. Microphone three,

4 please.

5 TOM WARREM (phonetic): Thank you. I'm Tom

6 Warrem, speaking on my own behalf, in opposition of the


8 Some of the confusion I see is if, if we look at

9 Item No. 2 for multifamily dwellings, we're not

10 permitted to use NM cable in a Type 3, 4, or 5

11 construction. We're not permitted to use it - or - so

12 when you look at a dwelling unit, can we use on a Type 1

13 or 2 construction, NM cable within a multifamily

14 dwelling, when it's not permitted in a multifamily

15 dwelling.

16 JAMES GOLINVEAUX: Thank you. Is there any


18 Comment No. 1502? Microphone number four.

19 CHRIS HUNTER: Thank you. Just a quick

20 clarification. Chris Hunter with Serra Wire, in support

21 of the motion. I, I didn't quite understand the last

22 comment, because No. 2 does allow NM cable in

23 multifamily dwellings permitted to be of Types 3, 4, and

24 5 construction. That's the whole purpose of that part

25 of the code. So it definitely does allow it. Thank



493

1 you.



4 Comment No. 1502? Mr. Johnston, do you have any final

5 comments?


7 nothing further.

8 JAMES GOLINVEAUX: Before we vote, let me restate

9 the motion. The motion on the floor is to Accept Public










19 Now let's proceed with the discussion on


21 please.

22 HOWARD HERNDON: This is Howard Herndon,

23 representing the Professional Electrical Apparatus

24 Reconditioners League. I'd like to make a Motion to




494


2 on the floor to Reject Second Revision No. 8187. Is

3 there a second? Is there a second?



6 JAMES GOLINVEAUX: Thank you. Thank you. We do

7 have a second. Please proceed with the discussion on

8 the motion.

9 HOWARD HERNDON: This is a very interesting

10 motion. But receptacles come in many different sizes,

11 and types. For instance, I'm sure the intent of the

12 Code Committee as to keep a 20 amp duplex receptacle, or

13 a 15 amp duplex receptacle from being reconditioned,

14 which - nobody wants that reconditioned.

15 But it does not allow us to recondition a 60,

16 100, or a 200 amp pin and sleeve receptacle. So I would

17 like to see this struck so that we can get back into

18 some further attention to detailed, and get it clarified

19 further.


21 would you like to offer the Panel's position?


23 were no correlation issues or conflicts that were

24 identified by the Correlating Committee, but I will like

25 to defer to the Chair of Code Panel 18, Bobby Gray, and



495

1 I think he's at microphone three.

2 BOBBY GRAY: Thank you, Mr. Chair. My name is

3 Bobby Gray, with Hoytabuck (phonetic) Electric. I

4 represent the National Electrical Contractors

5 Association; Chair of Code-Making Panel 18. I'd like to

6 speak in opposition of the motion, and in support of the

7 action taken by the Committee.

8 The Committee discussed this in detail, and were

9 unified in their opinion that receptacles should not be

10 reconditioned. They also reinforced the fact that some

11 receptacles, as was pointed out by the, by the

12 submitter, are - do have serviceable parts, and those

13 would not be considered reconditioned, as explained back

14 in 110.21.

15 So again, we're in opposition of the motion.

16 Thank you, Mr. Chair.

17 JAMES GOLINVEAUX: Thank you. And I'm going to

18 go in order here. Microphone three again.

19 MIKE STONE: Mike Stone, representing NEMA. NEMA

20 opposes this Motion to Reject Second Revision 8187.

21 Thank you.


23 four, please.

24 RANDY HUNTER: Randy Hunter, Hunter Technical

25 Services, representing myself. And as you can see,



496

1 we've had a little bit of discussion here that there are

2 applications --

3 JAMES GOLINVEAUX: Are you for, or against the

4 motion?

5 RANDY HUNTER: I am for the motion - sorry.


7 RANDY HUNTER: There are applications. There are

8 applications that could be rebuilt. And the obvious

9 thing here is this language was not vetted properly. It

10 wasn't open for public review because it was new

11 language brought in during the comments stage. They're

12 trying to attach it again to the rebuilt subject that

13 was brought in in 110, which was only talking about

14 listing, and the labeling part, and taking off the

15 listing. This language of - put in here, stating that -

16 what cannot be rebuilt, is totally new during the

17 comments stage.

18 I have a hard time understanding how we can add

19 language in various places within the code, that have a

20 list of prohibited items, and say that that is not new

21 language, when the original public input they're

22 relating it to only talked about listing and labeling of

23 remanufactured.

24 So to me, it's an issue. If it had had public

25 comment, some of these little details that we're talking



497

1 about, of the pin and sleeve items that are serviceable,

2 could have been addressed, and we could have wrote

3 cleaner language here than we have.

4 It's my opinion that this should be held, so that

5 we can get input from everybody. Thank you.

6 JAMES GOLINVEAUX: Thank you. Microphone two,

7 please.

8 JOHN MCKENZIE: John McKenzie, representing

9 Schneider Electric. We believe that while pin and

10 sleeve receptacles are --


12 against the --

13 JOHN MCKENZIE: I --

14 JAMES GOLINVEAUX: -- the motion?

15 JOHN MCKENZIE: I apologize. I'm speaking

16 against the resolution.


18 JOHN MCKENZIE: We believe that while pin and

19 sleeve receptacle types are serviceable, there are times

20 when they are not reconditionable. We stand in

21 opposition.


23 please.





498



3 We just heard that this motion should be accepted

4 because it's new material. I want to point out to the

5 body on this floor that we're belaboring this. We're

6 going over, and over - and, and they're, they're going

7 to go to every one. But I want to get it in the record,

8 for Standards Council, and for this body, that they're

9 just cherry picking.

10 I wanted to wait until we got out of Article 240,

11 because there's a new Section 240.88, which gets into

12 reconditioned equipment dealing with circuit breakers.

13 And it specifically permits low voltage, and medium

14 voltage power circuit breakers, and high voltage circuit

15 breakers to be reconditioned.

16 So the individuals that are telling you that this

17 is new material left that there because they like it.

18 Let's, let's oppose this motion, and every other one

19 that hits the floor.


21 please.

22 (applause)

23 BILL FISKE: Thank you, Mr. Chairman. I am Bill

24 Fiske with Intertek, and I am speaking against this

25 motion.



499

1 The maker of the motion stated that there are

2 larger pin and sleeve receptacles which are amenable to

3 reconditioning. However, this is very sweeping

4 language, and it doesn't exclude anything. To remove

5 that last sentence permits any receptacle to be

6 reconditioned.


8 please.


10 Serra Wire, in support of the motion.

11 The statement that the, the submitters of some of

12 these motions were cherry picking is incorrect.

13 Unfortunately, the submitters of some of these motions

14 just missed one.

15 The language in 240.88 is new material, and

16 dearly wish that it would have been submitted as a

17 motion, as well. It showed up for the very first time

18 in the Second Draft, with no public review. And it's

19 just unfortunate that it was missed. It was simply an

20 oversight, and at - like the others, it should have

21 public review. Thank you.

22 JAMES GOLINVEAUX: Thank you. Are there any

23 further discussion on Motion - microphone two.

24 FRED HARTWELL: Yeah. Fred Hartwell. When I

25 first looked at this --



500

1 JAMES GOLINVEAUX: Are you speaking --

2 FRED HARTWELL: -- I immediately thought --

3 JAMES GOLINVEAUX: Your name, affiliation --

4 FRED HARTWELL: Yeah. I, I'm speaking for

5 myself, and I'm speaking against the motion.


7 FRED HARTWELL: When I first looked at this, I

8 thought, 'You know, I could support this,' thinking of

9 pin and sleeve receptacles. But no, there's a reason

10 why the definition excludes one to one replacements of

11 these parts. Yes, there are parts in a pin and sleeve

12 receptacle that are field serviceable. You can take a,

13 a contact tube out, and replace it with a, a, a, a new

14 one from the manufacturer that meets current

15 requirements. And that can, that can be done, and it is

16 not reconditioning. It is, you know, it is a, a one for

17 one replacement of a component. And that's different

18 than reconditioning. It's not covered in the definition

19 of reconditioning.



22 Revision No. 8187? Mr. Johnston, do you have any final

23 comments?


25 nothing further to add.



501

1 JAMES GOLINVEAUX: Before we vote, let me restate

2 the motion. The motion on the floor is to Reject Second

3 Revision No. 8187. Touch - to vote, touch the 'vote'





8 vote.







15 please.

16 HOWARD HERNDON: Motion 70.28 - Howard Herndon,

17 Professional Electrical Apparatus Reconditioners League,

18 Rejecting the Revision 8189.


20 on the floor to Reject Second Revision No. 80 - 8189.

21 Is there a second?







502

1 HOWARD HERNDON: Our discussion with this is very

2 similar to the discussion with the receptacles. A cord

3 attachment plug could be a 60, hundred, a hundred, or

4 200 amp pin and sleeve connector. And the only thing I

5 would add to this is - is taking the manufacturer's part

6 out of a package, is that reconditioning, refurbishing?

7 I'm not really sure, based on our new definition.





12 the Correlating Committee, with this issue. I would

13 like to defer to the Chair of Code Panel 18, Bobby Gray,

14 at microphone three, please.

15 BOBBY GRAY: Thank you, Mr. Chair. Bobby Tray,

16 Hoytabuck (phonetic) Electric, representing the National

17 Electrical Contractors Association; chair of Code-Making

18 Panel 18. I stand in opposition of the motion, and in

19 support of the action taken by the Committee.

20 Again, it was a total alignment of all Committee

21 members in supporting this opinion that these devices,

22 these wiring devices, should not be allowed to be

23 reconditioned. Once again, in several ballot statements

24 it was made clear by Committee members that replacement

25 of serviceable parts do not constitute reconditioning of



503

1 electrical equipment. Thank you, Mr. Chair.

2 JAMES GOLINVEAUX: Thank you. Microphone - well,

3 with, with that, we'll open up the debate on the motion.

4 Please provide your name, affiliation, and whether you

5 are speaking in support, or against the motion.


7 BRIAN HOLLAND: Brian Holland, NEMA Codes and

8 Standards, call the question, please.


10 (applause)


12 JAMES GOLINVEAUX: Okay.

13 (laughter)

14 JAMES GOLINVEAUX: Seeing that there was no one

15 else at a microphone, I notice there's a motion to call






21 of the motion to call the question, touch 'Yes'. If you

22 wish to vote against the motion to call the question,






504

1 And the - the results of the call the question

2 are 370 in favor; and 10 opposed. So the vote was in

3 favor of calling the question.


5 motion on the floor is to Reject Second Revision No.

6 8189. To vote, touch the 'vote' button. If you wish to

7 vote in support of the motion, and recommend the text on


9 the motion, and recommend the text on Screen Two, touch







16 Certified Amending Motion 70-29. Microphone four?

17 DAVID SHAPIRO: I'm David Shapiro. I move to

18 Accept Public Comment No. 1123, Motion 70-29.



21 there a second?




25 DAVID SHAPIRO: David Shapiro, representing



505

1 myself, and in favor of the motion.

2 So I get a, a service call. Somebody has

3 something going wrong with their wiring. They're

4 worried. What do I do? I say, 'Hey, can you kill the

5 circuit?' Maybe yes, maybe no. It is a problem that's

6 been seen in the field, and I've heard about it from

7 across the country. And it's a problem that ironically

8 is because the person who's responsible for installing

9 the equipment and labeling the circuit, tends to be a

10 qualified professional. And the person inspecting and

11 approving it. And if that sounds odd - let me tell you

12 what I heard from Nick Sazza (phonetic), the man who

13 came up with the original proposal.

14 He said that when he had a chance on inspection,

15 he'd take the occupant, the, the facility manager, or

16 the homeowner, whoever it was, and he'd stand in front

17 of the load center. And said, 'Hey, if those lights

18 down there were flickering, and you thought maybe there

19 was a crackling sound from that switch, you'd probably

20 want to kill the circuit. Right?' 'Yeah.' 'Okay.

21 Which of these would you flip?' He said nine times out

22 of ten - I'm shaking my head, because they wouldn't have

23 a clue.

24 And the point is, this was - even when Nick could

25 look at it, and it was clear and evident to him, as a



506

1 qualified professional - it's circuit seven.

2 Now, the reason for this is something that comes

3 up in a lot of fields, where an expert is trying to

4 communicate - the - it's been studied, and the

5 scientists call it the curse of knowledge. The idea

6 being that I've been doing this stuff so long, that

7 jargon, and abbreviations, and odd little terms that -

8 and even symbols that I may put on the panel - well, I'd

9 come there, inspect, I recognize that. It's plain

10 English to me. But it isn't, necessarily, to the end

11 user. So I asked some of these scientists, 'What do you

12 do?' And the best answer they came up with is you warn

13 - not the ding-a-ling - you warn the end user that, you

14 know, you warn the, the qualified professional to think

15 of the end user. Think of somebody other than me,

16 somebody different who doesn't have my background.

17 And checked this wording out with Dr. Birch

18 (phonetic), who's done some of the latest research, and

19 just was told, 'Yeah, that's the sort of thing you say.

20 Think about somebody other than you.' Just like we

21 don't say high voltage, because an electrician knows

22 what that means. Watch it. We say danger, high voltage

23 keep out so that anybody who might be in a position,

24 they might need to use it - not a little kid, not

25 somebody who can't see, but somebody who might



507

1 realistically be on the site, can use it. And also, the

2 electrician who didn't have our same background, because

3 there are electricians in this country who use

4 abbreviations that I don't know. And if I'm traveling

5 to that jurisdiction, I might be lost, too. Simplest,

6 plainest English.

7 JAMES GOLINVEAUX: I'm sorry, I have to interrupt

8 you. Your time has expired. Mr. Johnston, would you

9 like to offer the Panel's position?


11 were no correlation or - issues or conflicts identified

12 by the Correlating Committee. However, I'd like to

13 defer to the Chair of Code Panel 9, David Humphrey, and

14 I believe he's at microphone three, please.

15 DAVID HUMPHREY: I'm David Humphrey, Chair of

16 Code-Making Panel 9, and I represent the International

17 Association of Electrical Inspectors, and I stand in


19 The current language is both clear, direct, and

20 concise. We specifically are required to identify each

21 circuit, for its specific purpose, in a manner that's

22 clear and evident. You can't get too much more concise

23 than that.

24 Part of this substantiation that the Panel noted

25 in the submitter's substantiation, was that alternate



508

1 languages may be required. And this poses a tremendous

2 burden on installer, and inspector. So we encourage

3 that you defeat this motion. And it should also be

4 noted that even by unqualified persons - the code is not

5 intended to be written for unqualified persons. Thank

6 you.




10 support, or against the motion. Microphone four,

11 please.

12 DAVE SHAPIRO: Dave Shapiro, for myself, in favor

13 of the motion. I apologize to Mr. Humphrey, if I gave

14 the impression my substantiation as talking about using

15 alternate languages. That is not my intent.

16 But let me give you an example. There's a, a

17 well known electrical instructor who told me he came

18 across a clear, evident marking, where it said 'MBR' and

19 then a circle with two lines down it. And that's clear

20 and evident to me. It means the receptacles. But it

21 doesn't mean that to the people who may be on the site.

22 There are electricians who write 'D + D' in many

23 jurisdictions. Until I started researching this, I

24 never knew that this was a common abbreviation, and

25 initials, and it meant, 'dishwasher and disposal'. So



509

1 if I'd been in that jurisdiction, I wouldn't have had a

2 clue.

3 Now, I'm not saying everything has to be in the

4 simplest English that any moron is gonna get it, and

5 that it has to be Spanish, and Tagalog and, and

6 whatever. But you know, if you're in a, a jurisdiction

7 where you're inspecting a hall like this - there are

8 people who've written 'poke-through'. Well, I'm an

9 electrician. I figure they must mean the floor

10 receptacles in this room. But if the facility manager's

11 there, and his maintenance guy looks at that - it's

12 clear to me. It's not clear to him. That's, that's the

13 - that's my concern here.


15 please.

16 PAUL ABERNATHY (phonetic). Hi. My name is Paul

17 Abernathy, and I represent Encore Wire, and I speak in


19 As an electrician for over 30 years, and

20 instructor, when I read this it says it has to be clear,

21 evident, and specific purpose. I think we do that. I

22 think the, the efforts by the electricians in there is

23 to try to achieve that. But when we get down to where

24 it says each circuit's got to be distinguished from, all

25 others - when I list something and say 'master bedroom',



510

1 and I expect somebody that's unqualified - is the intent

2 here for me to actually write 'love shack' on that

3 breaker's label --

4 (laughter)

5 PAUL ABERNATHY: -- on that breaker's label? Is

6 that distinguished enough for the unqualified person?

7 I'm not sure. I think it's very clear when we label it.

8 Thank you.

9 (laughter)

10 (applause)


12 UNIDENTIFIED SPEAKER: Just go straight to the

13 (unintelligible)

14 (laughter)

15 JAMES GOLINVEAUX: Even I get lectured. Okay.

16 (laughter)

17 JAMES GOLINVEAUX: I'm not seeing anybody at a

18 microphone, so is there any further discussion on Motion

19 70-29 to Accept Public Comment 1123? Mr. Johnston, do

20 you have any final comments?

21 MICHAEL JOHNSTON: I have nothing further,

22 especially on a love shack.

23 (laughter)

24 MICHAEL JOHNSTON: Just, just, just took me back

25 a little bit, that's all.



511

1 (laughter)


3 JAMES GOLINVEAUX: Okay. I'm turning red.


5 on the floor is to Accept Public Comment 1123. To vote,








13 The vote is 46 in favor of the motion; 381


15 Now, let's proceed to the discussion on Certified

16 Amending Motion 70-30. Microphone four, I believe.

17 HOWARD HERNDON: Yes, Sir.


19 HOWARD HERNDON: Howard Herndon, Professional

20 Electrical Apparatus. We're - Motion 70.30 - 70-30




24 there a second?




512



3 HOWARD HERNDON: In general, we do not have a

4 problem with this entire statement, except for the

5 conflicting remarks at - on Item B - switchboards and

6 switch gear, or sections of switchboard and switch gear

7 shall be permitted to be reconditioned. Reconditioned

8 switch gear shall be listed. And notice that it said

9 'reconditioned switch gear'. Shouldn't it say

10 'switchboards and switch gear' shall be listed and field

11 labeled as reconditioned? Previously applied listed

12 marks - if any within the previous portions of the

13 reconditions shall be removed.

14 So we think there's some issues here with

15 wording, and we would like to have this sent back to

16 have it reworded and cleaned up a little bit, so it's

17 nice and clear.



20 MICHAEL JOHNSTON: Yes. Thank you, Mr. Chair.

21 There were no Correlating Committee issues identified,

22 and I would like to defer to the Chair of Code Panel 9,

23 David Humphrey, at microphone three, please.

24 DAVID HUMPHREY: Yes, I'm David Humphrey, Chair

25 of Code-Making Panel 9, and I represent the



513

1 International Association of Electrical Inspectors. I

2 stand in opposition to the motion.

3 Code-Making Panel 9 takes the position that

4 switchboards and switch gear lend themselves to

5 reconditioning, as they are generally constructed on

6 site, due to the practical concerns with removal and

7 replacement. When coupled with a field evaluation, will

8 provide a safe and cost effective solution.

9 Panel boards are, are the bussing that is

10 generally installed in cabinets, and is easily

11 replaceable, as field evaluation is not practical.

12 Panel boards in dwelling units are often replaced due to

13 contact with smoke, and other products of combustion

14 that will likely have a damaging effect on the metal

15 bussing, and as such does reconditioning would be

16 effective, or safe. Thank you.






22 please.






514


2 You need to take a look at SR 8172. Throughout

3 the evening, there has been several issues with some of

4 the language on the screen. We have to keep in mind

5 that each committee took a look at all of the equipment

6 under their purview, and this revision was done by the

7 Code-Making Panel members on Panel 9.

8 I wish this would not be belabored all night

9 long. But this is sound. It's not new material. And I

10 urge this body to oppose this motion - reject the motion

11 on the floor. We've got three more coming right after

12 it.


14 please.



17 As a manufacturing facility operator, there are

18 concerns that the language in this revision will result

19 in the premature replacement of equipment, and extended

20 down time.

21 During the Second Revision balloting, the IEEE

22 voted - voted against adding this language to the NEC,

23 and submitted a comment that said, quote, 'The language

24 in this Second Revision has not had sufficient public

25 review. Users of the NEC have not been able to review



515

1 the proposed language, evaluate the impact on their

2 facility, and have a chance to respond and comment on

3 the proposed wording. Due to the large amount of

4 installed electrical equipment of varying ages,

5 reconditioning of equipment occurs regularly in

6 industrial facilities to maintain or improve safety and

7 integrity of equipment. Those users need a sufficient

8 opportunity to review and comment on the proposed

9 language.' Unquote.

10 As an organization of 400,000 members, and

11 representing the user interest on this Code Panel, the

12 IEEE objections should be given serious consideration.

13 They also pointed out that, quote, 'The proposed wording

14 requires the use of design qualified parts verified

15 under applicable standards. The term 'design qualified

16 parts' is not defined in the NEC. There is no clear

17 understanding on what parts can be classified per this

18 term. For example, it can be interpreted that design

19 qualified parts can refer to only the exact parts used

20 in the original design of the equipment. That

21 interpretation is extremely problematic for older

22 equipment where original parts are no longer available,

23 and the manufacturer is no longer in business. Using

24 the term 'design qualified parts' creates confusion, and

25 the inability to meet the proposed requirement.'



516

1 Unquote.

2 As in earlier motions, this language appeared in

3 the Second Draft, and it was not based on any similar

4 language or requirement that was considered in the First

5 Draft. That lack of public review has resulted in a

6 confusing set of rules that have the potential to create

7 an extremely negative impact on American manufacturers.

8 Thank you. Please support the motion.


10 please.

11 BILL FISKE: Thank you, Mr. Chairman. I am Bill

12 Fiske of Intertek, speaking against this motion. When

13 Mr. Herndon introduced it, he noted some deficiencies,

14 with a few words missing from Subsection B. That does

15 not strike me as any reason to delete the entire

16 section, which is what the motion purports to do. This

17 strikes me as a stealth approach to removing all rules

18 regarding reconditioning of switchboards and panel

19 boards.


21 please.


23 Hartwell, a member of Code Panel 9, speaking against the

24 motion.

25 The - it is possible to excessively enforce any



517

1 section of the code. And to apply the term 'design

2 qualified parts' in a way that effectively removes the

3 possibility is a clear over-enforcement, if you will,

4 and it - that is on that particular jurisdiction. It is

5 not on the code.

6 Now, I'm speaking as the Chairman of Task Group 2

7 in Code Panel 9. And Task Group 2 was responsible for

8 this language. And I want to say a little something

9 about the absence of the word 'switchboards' in B, where

10 it says 'reconditioned switch gear'. That is an error.

11 I will take responsibility for that error.

12 What happened was, we had to develop language,

13 both here and for Article 490, because the comment we

14 got that asked us to deal with medium voltage, and

15 medium voltage equipment is out of the scope of Article

16 408. In, in the process - in 490, it's only switch

17 gear. And in the process of moving material between

18 those two Articles, it got lost. And as I said, that is

19 on me.

20 There are some discussions taking place right now

21 as to whether we need a TIA on this, or whether we can

22 rely on the Standards Authority's - the - and the test

23 labs to apply this to switchboards, as well as switch

24 gear, which it plainly should apply to.

25 I don't know where that's going to come out.



518

1 It's a small thing to fix. But basically, the wording

2 here is sound.


4 please.

5 JOHN MCKENZIE: Thank you, Mr. Chairman. My name

6 is John McKenzie. I represent Schneider Electric, and

7 we oppose this motion.

8 As mentioned before, Schneider Electric is not

9 only a manufacturer. We also are reconditioners. As a

10 designer of products, we know that there can be

11 proprietary and patented methods and procedures used in

12 the design and manufacturing process. This includes the

13 concept of design qualified parts, which is well

14 understood in the industry. Reconditioning without

15 knowledge of these methods and procedures can result in

16 an unsafe product. Knowledge of these methods and

17 procedures can also inform us when it is not safe to

18 recondition a product at all - not even by the original

19 manufacturer. We oppose this motion.

20 JAMES GOLINVEAUX: Thank you. Microphone six, I

21 believe.

22 DAVID SHAPIRO: David Shapiro, speaking for

23 myself, against the motion.

24 I want to speak to one small piece of it, which

25 is the panel boards, and the concern that Ms. Hunter



519

1 mentioned about the excessive down time. I don't know

2 if that applied to panel boards per se. But just in

3 case it did - you are not reconditioning a panel board

4 if you leave the cabinet there, leave the conductors in

5 it, and remove the guts, and replace them with OEM

6 product. And you've saved the time.


8 THOMAS DOMITROVICH: My name is Thomas

9 Domitrovich, with Eaton, and I speak in opposition to

10 the motion on the, on the floor.

11 I will make myself brief. I'm a - we are a

12 manufacturer of electrical equipment. Reconditioning

13 this equipment is not a simple matter, and what the,

14 what the Panel has constructed in code language is very

15 sound, and any minor issues can be resolved, I'm sure,

16 as time progresses. So thank you, and I support the -

17 and again, urge everyone to - to not support this motion

18 on the table.



21 Revision 8172? Mr. Johnston, do you have any final

22 comment?

23 MICHAEL JOHNSTON: I have nothing further to add,

24 Mr. Chair. Thank you.




520


2 to reject Second Revision 8172. To vote, touch the





7 record your vote.







14 HOWARD HERNDON: Yes, Sir. Motion 70-31 --

15 JAMES GOLINVEAUX: And can you please get a

16 little closer --

17 HOWARD HERNDON: Oh.

18 JAMES GOLINVEAUX: -- to the microphone, please.

19 I'm sorry.

20 HOWARD HERNDON: Howard Herndon with PEARL

21 Professional Electrical Apparatus - it's getting late.

22 Professional Electrical Apparatus Reconditioners League.

23 We would respectfully withdraw this motion.

24 (applause)

25 JAMES GOLINVEAUX: Thank you. So the Motion 70-



521

1 31 appeared on our Agenda. However, the authorized

2 maker of the motion has notified NFPA that he no longer

3 wishes to pursue this motion. Therefore, in accordance

4 with the NFPA Rules, Convention Rules at Section 2.7,

5 the motion may not be considered by the assembly, and

6 its removed from the Agenda. We will now move on to the

7 next motion.



10 please.

11 HOWARD HERNDON: Howard Herndon, representing

12 PEARL, on Motion 70.32 to Reject 8164. We are going to


14 (applause)

15 JAMES GOLINVEAUX: Thank you. Motion 70-32

16 appeared on our Agenda. However, the authorized maker

17 of the motion has notified NFPA that he no longer wishes

18 to pursue this motion. Therefore, in accordance with

19 the NFPA Rules, Convention Rules at Section 2.7, the

20 motion may not be considered by the assembly, and its

21 removed from the Agenda. We'll now move on to the next

22 motion.



25 please.



522


2 PEARL. Motion 70.33, Reject Second Revision 8222.



5 there a second?



8 proceed with a discussion on the motion.

9 HOWARD HERNDON: The question we have here - what

10 is a design qualified part? Sometimes that would seem

11 apparent to me. If I was reconditioning a ITE circuit

12 breaker, air circuit breaker, who would I get a design

13 qualified part? We feel like that this section needs to

14 be reworded, and re-brought back to the assembly for

15 reconsideration, because many of the products that we

16 are reconditioning, a design qualified parts are no

17 longer available. If they are available, you're going

18 to have to buy them from the manufacturer who made them.

19 And do you think they're going to sell them to you?

20 Probably not.




24 are no apparent conflicts, or correlation issues. The

25 NEC Correlating Committee reviewed the complete record



523

1 of both the public input, and comments to ensure there

2 was no new material being introduced. The Correlating

3 Committee concluded that there was no new material

4 related to the definition of reconditioned, and the new

5 rules related to it. And that's consistent with all of

6 the code-making panels that had the charge of policing

7 their own material and this issue for new material. So

8 it's not just the Correlating Committee doing this.

9 Each code-making panel that dealt with it had the new

10 material policing effort as one of their charges, and

11 the issue never came up. The public record will show

12 that it started at the beginning, and this is how it

13 ended.

14 I'd like to defer to the Chair of Code Panel 9,

15 David Humphrey, who's at microphone three, please.

16 DAVID HUMPHREY: I'm David Humphrey, Chair of

17 Code-Making Panel 9. I represent the International

18 Association of Electrical Inspectors, and I stand in

19 opposition of the motion.

20 It is the determination of Panel 9 that switch

21 gear can be reconditioned. And this work is typically

22 done in place because of the difficulty of removal and

23 reinstallation. Panel 9 has reviewed the current status

24 of listing coverage and conclude that - concludes that

25 field labeling is a viable approach. If the gear has



524

1 been water or products of combustion, a field evaluation

2 by a testing lab is warranted. Thank you.



5 affiliation, and whether you are speaking in support, or

6 against the motion. Microphone four, please.


8 Serra Wire, in support of the motion. Besides being new

9 material, there is a question on the second paragraph on

10 here. This is medium voltage switch gear. The

11 requirements is that it shall be listed or field

12 labelled as reconditioned. Some of this equipment never

13 had to be listed in the first place. How are you going

14 to list it as reconditioned in that case. So it's a -

15 it's a, it's a question that I, I think deserves an

16 answer. Thank you.


18 please.

19 BARRY RODGERS: I am Barry Rodgers. I represent

20 Schneider Electric. Schneider Electric is against this

21 motion. We support the action taken by the Code Panel

22 to include this language. For design qualified parts,

23 it's necessary to discuss with the manufacturer about

24 the part in question, in order to have a thorough

25 understanding of the part in question. Design qualified



525

1 clearly points to product standards, and manufactured

2 defined qualifications during the design process. The

3 product standards and manufacturer knowledge include

4 qualifications that deeply involve the technology and

5 sciences involved for the product. This includes

6 proprietary and patented parts, and/or processes.

7 The listing mark notes that the product - product

8 meets appropriate standards, and found suitable for its

9 purpose. The removal of the listing mark helps to

10 inform the user, and code enforcement that the equipment

11 has been reconditioned, excuse me - and may not be

12 suitable - and may not meet the requirements of the

13 industry product safety standard. I urge you to vote

14 against this motion.


16 please.

17 RICHARD GARBUCK (phonetic): Richard Garbuck. I

18 speak for myself. I'd like to call the question.

19 JAMES GOLINVEAUX: There is a motion from the

20 floor to call the question. I notice there are a number

21 of people remaining at the microphone waiting to speak,

22 but we'll proceed with the vote on the call of the






526


2 of your tablet to vote. If you wish to vote in support


4 the motion, touch 'No'. Please record your vote.



7 There are 342 votes in favor of calling the

8 question; there are 19 opposed to it. The - we - the

9 vote is in favor of calling the question. Therefore,

10 we'll move straight to the motion.


12 motion on the floor is to Reject Second Revision 8222.

13 The vote - to vote, touch the 'vote' button. If you

14 wish to vote in support of the motion, and recommend the






20 The results are 19 in favor of the motion; 387


22 We are going to take a 10 minute break, which is

23 going to be the last break for the evening, because we

24 will come back and finish this. So enjoy this break,

25 and we will see you in 10 minutes.



527

1 (laughter)

2 (break)

3 (MUSIC)

4 (END OF PART FOUR)

5

6


8


10


12

13 PART 5

14

15

16 (MUSIC)

17 JAMES GOLINVEAUX: All right. I hate to

18 interrupt Love Shack, so --

19 (laughter)

20 JAMES GOLINVEAUX: We're - let's proceed with

21 the discussion on Certified Amending Motion 75-34.

22 I've got a whole bunch of people around microphones,

23 so I've got to - if you could raise your hand. So it

24 looks like five? Microphone five, please.

25 GEORGE STRANIERO: George Straniero from AFC



528

1 Cable Systems, and I move to Reject Identifiable Part

2 of Second Revision 7979.


4 on the floor to Reject an Identifiable Part of Second







11 GEORGE STRANIERO: George Straniero from AFC

12 Cable Systems, speaking in favor of the motion.

13 Panel 14 accepted interlocked armored MC HL

14 cable for the First Revision for the 2020 NEC. They

15 then rejected it for the Second Revision. The reason

16 given for the rejection do not technically just

17 justify excluding its use as a wiring method for Class

18 1, Division 1 locations.

19 First reason given was, for the rejection, was

20 that the addition of interlocked armored MC cable does

21 not satisfy any current need for Division 1 locations.

22 This is not true. Continuous sheath MC HL is stiff,

23 difficult to install, and reposition. Interlocked

24 armor type MC provides additional flexibility.

25 The next reason given was that the need for



529

1 flexibility can be met by other accepted cable types.

2 The availability of other wiring methods is not a

3 technical reason to allow - disallow other acceptable

4 cables.

5 Another reason given was that MC cable, with

6 the continuous metallic sheet, provides a second vapor

7 barrier. There are no requirements for multiple vapor

8 barriers. Other permitted cable constructions do not

9 have a multiple vapor barrier. The absence of the

10 multiple vapor barrier should not be a reason for

11 exclusion of MC HL with interlocked armor.

12 Finally, the Panel expressed concern that

13 arcing ground faults in interlocked armored cable

14 provides potential ignition source in Division 1

15 areas. Arcing ground faults with interlocked armored

16 are no more a concern than for arcing ground faults

17 with continuous MC. In fact, it's less a concern,

18 considering the - the ability of interlocked armored

19 cable to be flexed without damaging the armor.

20 Deletion in the First Revision that permitted

21 MC HL with interlocked armor unduly restricts the use

22 of a suitable alternative wiring method. There is no

23 valid reason that MC HL with interlocked armor should

24 be excluded. I ask that you vote to accept the motion

25 to Reject Second Revision 7979. Thank you.



530




4 were no correlation issues, or conflicts identified by

5 the NEC Correlating Committee, and I'd like to defer

6 to the Chair of Code-Making Panel 14, Mike Smith, at

7 microphone number two, please.

8 MIKE SMITH: Thank you, Mr. Chairman. I am

9 Michael Smith. I am from St. Louis, Missouri in

10 representation of NECA, and also home of the 2019

11 Stanley Cub Champion, St. Louis Blues. Thank you very

12 much.

13 (applause)

14 JAMES GOLINVEAUX: With that, are you for, or


16 MIKE SMITH: I am for - or against the motion.

17 I'm sorry.

18 (laughter)

19 MIKE SMITH: Got all excited there.

20 JAMES GOLINVEAUX: Right.

21 MIKE SMITH: It's been a long day. Panel 14

22 did review, and during the First Draft meeting, create

23 an FR 7609, based on the submission of PI 3314 and

24 3318. The Panel saw at that time, no problem with the

25 addition of this cable type being used in a Class 1



531

1 location. Yet, the Panel also noted that if this -

2 that this cable type was not currently manufactured.

3 And if it was going to be manufactured, it needed to

4 have the same crush rating impact - impact

5 requirements to ensure robust construction that would

6 compare to other cables used in this location.

7 We then received, after - during the comments

8 stage, two comments for this FR, to review in the

9 Second Draft meeting. PC 888 came to us from the

10 Correlating Committee, basically instructing us to

11 review the actions that we took on FR 76 - 7609, for

12 clarity and usability, with respects to the Item 1 and

13 2, those possible confusions between the two types of

14 cables.

15 After further review, Panel 14 then reversed

16 its original action allowing the MC HL cable with

17 interlocking metallic sheath, to be omitted as Item

18 No. 2, since the cable was not in existence at the

19 time.

20 Additional, Code Panel 14 noted that their

21 concern was with the arcing could occur under ground

22 fault conditions in the interlock armor, which could

23 provide ignition sources in a Class 1, Div 1 location.

24 And finally, just to make a note that this

25 paren (3) is for only industrial establishments, with



532

1 restrictions to public access, and where conditions of

2 maintenance and supervision ensure that only qualified

3 persons service the installation.

4 Thank you very much, Mr. Chairman.




8 support, or against the motion. Microphone four,

9 please.

10 JOHN KOVACHIC: Thank you, Mr. Chair. John


12 Section of NFPA as their official representative, and


14 The Electrical Section had its business meeting

15 on Tuesday of this week, and the Section voted to

16 support the motion on the floor. Ladies and gentlemen

17 of this body, I ask for your vote in support of this



20 please.

21 GEORGE STRANIERO: George Straniero, AFC Cable,

22 speaking in favor of the motion.

23 In response to the Panel 14 Chair's comments,

24 he indicated that there were no performance

25 requirements for impact and crush. The performance



533

1 requirements for HL constructions, for MC HL, which

2 exists today, and for Type TC HL, which exists today,

3 are contained in UL Standard 2225. So the

4 requirements are already in existence, the cable does

5 exist. Just waiting for the, for the - Article 501 to

6 recognize it.

7 Second comment made was relative to clarity in

8 the, in the, in the types of construction. I can - I

9 can't see it from back here. Hopefully you could see

10 it better; but clearly, it says interlocked armor

11 within the language of the, the proposed code text.

12 And as far as the, the comments made about

13 arcing, I, I think I addressed that earlier. You

14 already have the continuous sheath MC cable. My - an

15 interlocked armored cable is able to flex much more

16 easily, and without damage than, than a continuous

17 sheet. So it's no more a issue for, for arc fault

18 grounding, as, as the existing product that's allowed.

19 Thank you.

20 JAMES GOLINVEAUX: Okay. Thank you.


22 BILL FISKE: Thank you, Chairman. I am Bill

23 Fiske from Intertek, and I am speaking against this

24 motion.

25 Listed MC HL cable with an interlocked metallic



534

1 sheath does not exist. It is not covered by Standard

2 UL 2225. I'm a member of the STP that's responsible

3 for that. And I'm not speaking for Panel 14, but I am

4 a member of it. And in addition, I checked with the

5 primary designated engineer for STP 2225, who is also

6 a member of Panel 14, and he confirmed that it isn't

7 in the scope of the standard, and there are no current

8 proposals to put it into the standard.

9 JAMES GOLINVEAUX: Microphone five, please.

10 GEORGE STRANIERO: In rebuttal, the standard

11 cover and MC cable, both continuous and interlocked,

12 is UL 1569, and the standard exists. The cables

13 exist. The performance requirements are in 2225,

14 which covers the dash -HL suffix. Now we're up to the

15 chicken and egg - I like to call it the, the code

16 sneezes --

17 JAMES GOLINVEAUX: I --

18 GEORGE STRANIERO: -- UL goes, gesundheit.

19 JAMES GOLINVEAUX: Could --

20 GEORGE STRANIERO: The code (unintelligible)

21 JAMES GOLINVEAUX: Could you I'm going to

22 interrupt you just for --

23 GEORGE STRANIERO: I'm sorry --

24 JAMES GOLINVEAUX: -- one second.

25 GEORGE STRANIERO: I'm speaking in favor of the



535

1 motion.

2 JAMES GOLINVEAUX: You didn't state your name,

3 the company --

4 GEORGE STRANIERO: George - I'm sorry. George

5 Straniero, AFC Cable, speaking in favor of the motion.


7 GEORGE STRANIERO: I apologize. As I was

8 starting to say, I like to call it the, the code

9 sneezes and UL goes gesundheit, or the standard goes

10 gesundheit.

11 It's not in 2225 because it's not in the

12 National Electrical Code, which is why we're here

13 discussing it at this point. So the fact that it's

14 not in UL 2225 at this point is not a reason to reject

15 it. Should it make it into Article 501.10, that would

16 then instigate the, the revision to UL 2225. Thank

17 you.


19 Microphone two.

20 (laughter)

21 SCOTT CLINE: Scott Cline, representing NECA;

22 speaking for myself here.

23 JAMES GOLINVEAUX: Are you --

24 SCOTT CLINE: I - I'm --

25 JAMES GOLINVEAUX: -- speaking for or against



536

1 the motion?

2 SCOTT CLINE: I am speaking against the motion,

3 because I look at the long added paragraph there, long

4 sentence, which has no requirement. I don't think

5 it's a complete English sentence. I'm not sure what

6 its point is, in the way it's worded. I think it's

7 written in error. I would suggest voting against this

8 motion.


10 further discussion on Motion 70-34 to Reject an

11 Identifiable Part of Second Revision No. 7979? Mr.



14 Thank you.

15 JAMES GOLINVEAUX: Before we vote, let me










25 The vote is: 199 in favor of the motion; 183



537

1 against the motion. The motion has passed.

2 The next motion, NFPA 70-35, appeared on - on

3 our Agenda. However, the authorized maker of the

4 motion has notified NFPA that he no longer wishes to

5 pursue the motion. Therefore, in accordance with the

6 NFPA Rules, Convention Rules at Section 2.7, the

7 motion may not be considered by the assembly, and is

8 removed from the Agenda. We'll now move on to the

9 next motion.


11 Certified Amending Motions 70-36. Microphone one.

12 Thank you, sorry.


14 KEITH WATERS: Thank you, Mr. Chair. My name

15 is Keith Waters. I'm with Schneider Electric. I'm

16 representing myself here. I make a Motion to Reject

17 an Identifiable Part of the Second Correlating

18 Revision No. 30.



21 Correlating Revision No. 30. Is there a second?




25 KEITH WATERS: So - so the, the - the motion



538

1 itself is pretty straightforward, calling for a

2 deletion on the second part of the requirements that

3 are being removed from the, the code. The original,

4 the original code in 2017 requires GFCI protection for

5 all of the receptacles in an RV pedestal, whether it's

6 a 15 and 20 amp duplex, or the 30 amp, or 50 amp for

7 the RV itself.

8 So the - this motion is to keep that GFCI

9 protection for that outdoor receptacle, both for the

10 30 and 50, which is what's being deleted with this

11 SCR.

12 So what I ask it for the - from the, the

13 audience is a positive vote on my motion, in order to

14 keep GFCI protection on a, on an outdoor receptacle,

15 in case somebody's in the - trying to plug in the

16 rain, standing in water, have a cord laid out across

17 the ground that could be damaged. And it's basically

18 all about keeping that GFCI protection from

19 electrocution in that outdoor environment. Thank you.




23 Second Correlating Revision 30 was intended to align

24 this section with the NEC Style Manual, relative to

25 required driving text in this section, numbering, and



539

1 other alignment; and also with Section 90.3.

2 For the technical response, I'd like to defer

3 to the Chair of Code Panel 7, Keith Lofland, at



6 Lofland, International Association of Electrical

7 Inspectors. And I stand opposed to this motion.

8 Without the text that is being proposed to be

9 struck, this would call for GFCI protection for the

10 supply cord to the RV itself, which by definition of

11 the supply cord at 551.2, and the definition of a

12 feeder is a feeder - it's not a branch circuit.

13 You're - you have your individual branch circuit GFCI

14 protection in the RV itself. This, this language that

15 you see before you was voted upon by Code Making Panel

16 7, with a unanimous vote of 12-0. And so I, I ask you

17 to not support this motion at this time. Thank you

18 very much.

19 JAMES GOLINVEAUX: Thank you. Microphone - oh-

20 with that, we'll open up the debate on the motion.

21 Please provide your name, affiliation, and whether

22 you're speaking in support, or against the motion.

23 Microphone two, please.

24 WADE ELLIOTT: My name is Wade Elliott. I'm

25 the President of Utilities Supply Group. I'm a



540

1 supplier of electrical equipment to the RV industry,

2 and I represent the National Association of RV Parks

3 and Campgrounds, to Code-Making Panel 7; I'm here

4 representing the National Association. I'm here to

5 speak against Certifying Amendment 7036, and to

6 maintain correlating Revision 30.

7 Before I get too far into it, I, I want to

8 mention that the, the supplier that - of the Certified

9 Amending Motion mentioned that, that Current Code 17

10 requires a 30 and 50 amp GFI. It does not require a

11 30 amp - 50 amp GFI.

12 To reiterate what the Chairman said, numerous

13 inputs were made to Panel 7 addressing insulation of

14 GFCI protection on RV side equipment to enhance safety

15 in RV parks, because no recorded, or presented issues

16 regarding electrocutions at, or harm related to RV

17 park site equipment, nor any evidence of improved

18 safety would be provided by a vote in the first draft

19 of 12 to 2. This - the language was approved to not

20 have GFI protection on, on the 30 and 50 amp.

21 During the public comment period, one of the

22 submitters submit - that submitted the Certified

23 Amending Motion and, and a public comment sought to

24 reinstitute the 30 and 50 amp protection requirement.

25 In his comment, the Submitter quoted an industry



541

1 safety expert, Mike Sokol (phonetic), as justification

2 for the proposed revision. In fact, Mike Sokol

3 denounces the submitter's position as exactly opposite

4 of his thoughts - Mike is a friend of mine - for 30

5 and 50 amp on RV parts and, and side equipment GFCI.

6 It would actually reduce safety, as users would devise

7 methods, such as removing the ground pin from the

8 plug, to circumvent the GFCI protection, which would

9 lead to the actual hot skin condition that Mr. Sokol

10 warns against.

11 Second Revision, and the correlating inputs, as

12 the Chairman mentioned - we came to the conclusion

13 that 551.2 definition of power supply assembly, and,

14 and NFPA 100, definition of a feeder, the 30 and 50

15 amp are feeder circuits, and the 20 amp is a branch

16 circuit. And in our, in our proposal, or in our

17 Second Revision, we have the 20 amp GFI protection, UL

18 Standard 231, which I am a member of the Standard

19 Technical Panel, does not require GFCI protection on

20 only but the, the 15 and 20 amp in Table 8.1.


22 please.

23 RANDY DOLLAR: Randy Dollar with Siemens, but

24 I'm speaking on behalf of American Circuit Breaker

25 Manufacturers Association. We support this motion,



542

1 and we ask you to. We believe it would improve

2 safety, and you will not be able to avoid the GFCI

3 protection simply by removing the ground pin.


5 Microphone five again.

6 JACK LYONS: Thank you. I'm speaking for the

7 motion, and I'm --

8 JAMES GOLINVEAUX: And who are you, please?

9 JACK LYONS: -- Jack Lyons, represent NEMA

10 Codes and Standards, state their support for the

11 motion to Reject an Identifiable Part (unintelligible)

12 Revision No. 3 related to GFCI protection in Article

13 551.


15 please.

16 DOUG MULVANY: Thank you, Mr. Chair. Doug

17 Mulvany, Kampgrounds of America, speaking against.

18 Appreciate the time. Thank you.

19 I would just reiterate the points that Mr.

20 Elliot made, as well as our Chair, that after very

21 thorough discussions that dove deep into the

22 definition of the branch circuit versus the feeders,

23 the entire group, the entire Committee, voted

24 unanimously to remove this requirement for the GFCI on

25 the 50 and 30.



543

1 In addition to that, if you do remove

2 Informational Note 2, it will cause confusion, and

3 reduce the clarity of the code as it applies to the

4 current design standards that are laid out in 551.

5 Thank you.


7 please.

8 PHIL SIMMONS: Yes. Thank you, Mr. Chairman.

9 My name's Phil Simmons, speaking for myself, and


11 I have to admit that I learned something

12 tonight. The Informational Note No. 2 says that the

13 supply to the RV is indeed a feeder. And I would have

14 argued before that it's a branch circuit. So it meets

15 the definition of a feeder in Article 100, it's

16 misplaced to try to force the requirements of 210.8(B)

17 on the feeder to an RV.

18 In addition, RVs are supplied with all the

19 GFCIs that are needed - like in bathrooms, and

20 kitchens, and outdoor. So all the protection is there

21 that's needed, in the RV itself. So it seems like the

22 Code Panel has really implemented Section 90.3

23 correctly. Thank you.


25 KEITH WATERS: Yes. My name's Keith Waters.



544

1 I'm with Schneider Electric. I'm speaking for myself,

2 and I'm speaking for the motion.

3 So the first thing to note is in the

4 Correlating Committee comment, they reference 210.8(B)

5 directly. So the Correlating Committee recognizes

6 that it is a branch circuit, directly with their

7 statement in their Second Revision.

8 So - and also in reference to - this is about

9 safety. So we, we're not talking about issues within

10 the RV itself. We're talking about the cord that -

11 that's external to the RV, that could be damaged on

12 the ground; because someone could be holding it and

13 trying to plug during the rain - during rain, or, or

14 you have standing water. So it's a public safety

15 issue on terms of electrocution. And that's why I

16 would ask you to support the motion, to keep that

17 protection, because it is - it's in within the 2017,

18 because up through 50 amps in 201.8(B), do - does

19 exist in 2017.

20 JAMES GOLINVEAUX: Thank you. Microphone one,

21 again.


23 Call the question, please.


25 JAMES GOLINVEAUX: There's a motion from the



545

1 floor to call the question. I notice that there are a

2 few people still remaining at the microphone waiting




6 JAMES GOLINVEAUX: We do have a second. And in

7 order to vote on the motion, please scroll down to the

8 bottom of the table to vote. If you wish to vote in



11 your vote.



14 There are 364 in favor of calling the question;

15 and 19 against the motion to call the question. So

16 with - the vote is in favor of calling the question.

17 Before we move - we're moving to the main

18 motion. Before we vote, let me restate the motion.

19 The motion on the floor is to Reject an Identifiable

20 Part of Second Correlating Revision No. 30. To vote,








546



3 There are 274 in favor of the motion; 154

4 against the motion. The motion passes.

5 As we announced earlier, we have reordered the

6 next motion, so that it will be discussed in paragraph

7 section order. Discussions on Motion 70-2 will be

8 heard next. And I'll give you a second to catch up on

9 70-2.


11 Certified Amending Motion 70-2. And who's going to be

12 my maker of the motion? Microphone four, please.

13 DANIEL MIKAT: Thank you. My name is Daniel

14 Mikat. I represent Toyota Motor North America, and 23

15 other OEMs, including the Automotive Alliance, and

16 Global Automakers, and Society of Automotive

17 Engineers.

18 I move to Reject an Identifiable Part of Second

19 Revision No. 7776, Including - and Related Portions of

20 First Revision No. 8385.



23 Revision No. 7776, Including the Related Portions of

24 First Revision No. 8385. Is there a second?

25 UNIDENTIFIED SPEAKER: I second.



547



3 DANIEL MIKAT: Thank you. I am Daniel Mikat.

4 I represent Toyota Motor North America, and 23 other

5 automotive manufacturers, the Automotive Alliance,

6 Global Auto Makers, and SAE.

7 The auto - and I'm speaking in favor of this

8 motion. The automotive community recognizes that the

9 intention of this NEC code is to protect building,

10 premises, and infrastructure, electrical grid from

11 reverse energy flow from an electric vehicle to a home

12 wiring system.

13 The Scope Statement in previous section,

14 Section 90.1, excludes automotive vehicles, and

15 rightly so. This allows federal agencies, namely

16 NHTSA, with purview over automotive applications to do

17 their job, unfettered by conflicting rules from other

18 organizations.

19 NHTSA is recognized by automotive manufacturers

20 as the sole authority for creating automotive

21 regulations and requirements. They have the

22 resources, the procedures, and Congressional authority

23 to enact regulations, investigate incidents, and

24 produce and enforce regulations - and above all, to

25 broadly address any safety defects. Among those are



548

1 the recall process, and creating new FMVSS

2 regulations.

3 Conflicting rules from various organizations,

4 including the NFPA, would create confusion within the

5 automotive community, and ultimately would require

6 expensive and unnecessary procedures to comply. Now,

7 note that there are no known safety defects regarding

8 on board power outlets. L

9 Subsequent Section 625.60 includes specific

10 requirements for on board vehicle power outlets, such

11 as the 120 volt power outlet - which cannot connect to

12 a building infrastructure, and so should be excluded.

13 The language proposed allows management of

14 safety of electric vehicle supply equipment, which

15 supplies sufficient and necessary conditions, without

16 interfering with NHTSA's authority.

17 Discussions between the Automotive Alliance and

18 NHTSA have already begun with regard to this code

19 language, and NHTSA has agreed to produce an

20 interpretation letter; and we believe that NHTSA

21 preemption is likely, with regard to this code

22 language.

23 Based on these facts and conditions, the motion

24 is offered to maintain the scope of NEC, without

25 creating a conflicting requirement from that which



549

1 NHTSA has developed under FMVSS 305 GTR 13. And

2 hence, I am - I urge this constituency to accept the

3 language change proposed, and apply the scope to

4 include electrical vehicle - electric equipment

5 external to a vehicle. Thank you.



8 MICHAEL JOHNSTON: Thank you, Mr. Chair. Under

9 its responsibilities to review revisions to scopes,

10 the NEC Correlating Committee reviewed, and did not

11 identify any correlation or conflicts with regard to

12 the revisions made.

13 For the rest of it, I'd like to defer to the

14 Chair of Code Panel 12, Scott Cline, and I think he's

15 at microphone two, please.

16 SCOTT CLINE: I'm Scott Cline, representing

17 NECA. I am the Chair of NEC Code-Making Panel 12,

18 which is responsible for Article 625; and I speak


20 I hope you remember from what is now so very

21 long ago, my statements about the necessity of having

22 rules in the NEC to cover the hazards arising from the

23 decision by vehicle manufacturers, to turn a vehicle

24 into a non-transportation power supply system.

25 We need more than just the manufacturing



550

1 evaluating systems safety. Panel 12 gave all these

2 many issues very serious consideration. We started

3 discussions of the 625.1 and 625-60 issues by spending

4 an hour on two presentations, each followed by a Q and

5 A session, presenting the concerns of the automotive

6 industry. The Panel then spent six hours discussing

7 and acting on the issues specific to this general

8 topic. An hour of this time was spent on this

9 specific Second Revision.

10 Again, the Panel does not want to govern the

11 manufacturing of vehicles for transportation. But we

12 do insist that electrical power for our users to be

13 provided safely, to the same standards as elsewhere in

14 the NEC. If vehicle manufacturers choose to offer

15 options which turn the vehicle into a non-

16 transportation power supply system, the options need

17 to comply with the NEC. The scope is not a one time



20 presents electrical hazards, then the NFPA has the

21 responsibility to consider if regulations for public

22 safety are needed.

23 All 18 Panel votes for Second Revision 7776

24 were affirmative. Please vote no on this motion.




551



3 support, or against the motion. I'm going to go in

4 order that you are standing. Microphone two, please.


6 Kovachic, UL LLC, speaking on behalf of UL, and


8 I spoke earlier today on this issue as it

9 related to the scope of the code, and my remarks would

10 remain the same, so I won't repeat all of them. But

11 I'll summarize in two quick statements. The issue

12 resides in the electric vehicle acting, and serving as

13 a branch circuit, but without being held to the same

14 NEC rules as other branch circuits.

15 Ignoring the consequences of connecting a

16 product to an electric vehicle, and using the vehicle

17 as a source of supply would be a mistake. I urge this

18 body to reject the motion on the floor. Thank you.

19 JAMES GOLINVEAUX: Thank you. I'm going to go

20 with microphone five.

21 JIM TARCHINSKI: Good evening. My name's Jim

22 Tarchinski, and I'm representing SAE International,

23 speaking for the motion the floor.

24 SAE International, formerly known as the

25 Society of Automotive Engineers, is a lot like NFPA.



552

1 They are primarily focused on safety. They have

2 decades of experience, and they are globalized -

3 globally recognized leaders in their field. But the

4 fields are very different. SAE International is very

5 focused on the automotive environment, including the

6 different use cases that exist, including crash

7 worthiness issues.

8 SAE International has the J-1766 document that

9 does cover high voltage safety in the automotive

10 space. It deals with impacts. The federal government

11 has incorporated the basics of J-1766 into FMVSS 305

12 regulations, which all vehicle manufacturers must

13 meet, to sell in the United States.

14 NFPA putting requirements in the automotive

15 space will lead to confusion at best, but more likely,

16 ultimately to conflicts between the documents.

17 Last, different states are allowed to adopt

18 different versions of the code, and it does - code does

19 change over times. It is not clear if people will need

20 to comply with a version of the NEC in effect in the

21 state where they live, or in the state where the

22 purchased the vehicle. There is no enforcement activity

23 available to AHJs. As we as explained by Mr. Mikat, the

24 NHTSA organization does have processes and procedures in

25 place to deal with all these.



553

1 Instead of duplicating efforts between NFPA and

2 the government, I strongly recommend you vote for this

3 motion. And basically, if you have any issues and think

4 additional safety requirements are needed, we should

5 bring that to NHTSA, since they are responsible for

6 vehicle safety in the United States. Thank you.


8 please.


10 International, speaking for NAFRA, and against the

11 motion.

12 I want to remind some of you who probably don't

13 quite remember that 400 hours ago, we rejected --

14 (laughter)

15 MARCELO HIRSCHLER: -- NFPA 71. The makers of

16 this motion moved 72 far away so that you probably don't

17 remember that it is exactly the same issue. It is - we

18 have rejected in 90A what is covered, so 90.2-A, what

19 the code covers. The code covers installations where

20 the electric power is exported from the vehicle to the

21 house - has nothing to do with how the vehicle moves,

22 which is what NHTSA covers. NHTSA covers the movement

23 of the vehicle, the vehicle as a transportation

24 equipment. That's not what this is. This is the

25 vehicle as a source of electrical power to the house.



554

1 Please reject the motion. Thank you.


3 please.

4 DAN MIKAT: Hello. This is Dan Mikat again. I -

5 from Toyota Motor North America, and I'm speaking in

6 favor of the motion.

7 The past few comments were in opposition, and

8 they referenced the EV as a power supply should be

9 governed by NEC, and I agree with this. If you read

10 this text statement under the Scope Statement, this

11 proposed language, you'll see that the connection as an

12 EV as a power source is still included, per their

13 revised Scope Statement. The only thing that we're

14 trying to exclude here is on board power supplies.

15 And also the, the point about the amount of time

16 that the Committees spend discussing this matter is

17 irrelevant.

18 Now, regarding the question about the difference

19 between this proposal and 70.1 - this is different from

20 70.1. 70.1 requested to eliminate this from the scope

21 altogether. But this statement allows the connection or

22 the, the purview of the EV as a power supply to be

23 governed by the NEC, as long as this is for equipment

24 external to the electric vehicle. Thank you.




555

1 please.

2 EDDY GEDRY: Eddy Gedry, representing myself.

3 Call the question.


5 floor to call the question. I notice that there are a

6 number of people remaining at the microphones waiting to

7 speak, but we'll proceed with the vote on call of the




11 to vote on the motion, please scroll down to the bottom



14 the motion, touch 'No'. Please record your vote on

15 calling the question.



18 The results are: 373 in favor of calling the

19 question; 13 against calling the question. So it is

20 passed, the motion to call the question.

21 Moving to the main motion. Before we vote, let


23 Reject an Identifiable Part of the Second Revision No.

24 7776, Including Related Portions of the First Revision

25 No. 8385. To vote, touch the 'vote' button. If you



556







7 The results are: 32 in favor of the motion;

8 372 against the motion. The motion has failed.


10 Certified Amending Motion 70-37. Microphone - runner.

11 Microphone - I was just waiting to see where you

12 stopped - four.

13 SCOTT SCHMIDT: Thank you, Sir.

14 JAMES GOLINVEAUX: No worries. Catch your

15 breath.

16 SCOTT SCHMIDT: I'm Scott Schmidt with the

17 Alliance of Automobile Manufacturing, speaking for

18 Nancy Stone, 23 OEMs, their trade associations, and

19 SAE. I make the Motion to Reject SR No. 7783,

20 Including Part of FR No. 8597.

21 JAMES GOLINVEAUX: Thank you. There is a

22 motion on the floor to Reject Second Revision No.

23 7783, Including Any Related Portions of First Revision





557

1 JAMES GOLINVEAUX: Before we begin discussion

2 on this motion, I wanted to point out that there are -

3 some of the text on the Second Revision 7783, was not

4 included in the Agenda. The text which appears on the

5 screens behind me reflects the additional text.

6 Please proceed with the motion.

7 SCOTT SCHMIDT: Yes. Scott Schmidt with the

8 Auto Alliance. I support the motion.

9 The proposed definition of EVP seeks to

10 regulate on board equipment that provide power to

11 external loads using the vehicle as a source of

12 supply. These requirements do not appropriately

13 contemplate that automotive electrical architecture

14 significantly differs from other installations.

15 The definition of EVP conflicts with existing

16 safety oversight, namely federal preemptive authority

17 and the National Highway Traffic Safety

18 Administrations.

19 As indicated before, we have been in

20 discussions with the agency and are very interested in

21 examining where these conflicts would cause them to

22 consider preemption.

23 NHTSA has continuously evolved FMVSS 305 to

24 address safety needs as they emerged. Therefore,

25 NHTSA's enforcement authority replies regardless of



558

1 the presence of even an FMVSS. And as was said, if

2 there should be an issue in the field, NHTSA has the

3 authority to force the manufacturer to recall and

4 remedy its products.

5 There's use - various usage conditions and

6 receptacles are not appropriately addressed, either.

7 The proposed definition of EVPE lacks clarity on the

8 significantly wide variety uses and equipment it may

9 be intended to address. The proposed definition is

10 also overly broad, and may be interpreted to include

11 the inverter, regardless of on board or off board; the

12 EVSC that works for reversed power from the vehicle;

13 AC outlets regardless of on board or off board; EV

14 charging receptacles when used as an outlet, again,

15 regardless of AC or DC; wires or cables for the

16 devices above.

17 There is also inconsistency with the other NEC

18 sections. Section 625.60 and 625.2 both clearly

19 specify requirements for on board outlets installed in

20 electric vehicles. However, 625.1 and 90.2 can be

21 interpreted otherwise.

22 The Code-Making Committee attempted to address

23 these inconsistencies, but with the definition, such

24 interfaces remains unclear.

25 In summary, the petitioners of this motion



559

1 firmly believe that the proposal to add the definition

2 of EVPE would create a significant conflict with the

3 (unintelligible) authority, will not address

4 automotive usage conditions, and is not consistent

5 with the scope of other NEC sections. The proposal

6 will not provide any safety benefit, and we strongly

7 urge the NFPA to remove the definition of EVPE from

8 the 2020 NEC Second Draft Revisions. Thank you.


10 would you like to offer the Panel's position, please.



13 the NEC Correlating Committee. However, I would like

14 to defer the technical response to the Chair of Code

15 Panel 12, Scott Cline, and I believe he's at

16 microphone two, please.

17 SCOTT CLINE: I am Scott Cline, representing

18 NECA. I am Chair of NEC Code-Making Panel 12, which

19 is responsible for Article 625, and I speak against

20 this motion.

21 You have again just heard my opinion about the

22 necessity of having rules in the NEC to cover hazards

23 arising from the decision of vehicle manufacturers to

24 provide electrical power supply having nothing to do

25 with transportation. I still insist that the



560

1 electricity provided does not know where it comes

2 from, nor does it care what it goes through. It can

3 be an, an adult or a child's body; it will still be a

4 killer.

5 Neither the National Electric Code Article 90

6 scope, nor the scope of Article 625 is a one time



9 presents these hazards, then we have the

10 responsibility to consider them, and make rules where

11 required.

12 The vehicle manufacturers are sometimes

13 choosing to offer these options, turning the vehicle

14 into a non-transportation power supply system. When

15 they do this, they need to accept NEC standards, which

16 will integrate systems safely with loads that can be

17 connected to the vehicle now by simply plugging in a

18 cord, having nothing to do, necessarily, with

19 bidirectional vehicle charging equipment.

20 The Panel voting on Second Revision 7783 was 17

21 to 1. Please continue to provide protection to the

22 public, and vote no on this motion.






561

1 support, or against the motion. Microphone number

2 four, please.

3 SCOTT SCHMIDT: Yes. This I Scott Schmidt, the

4 Alliance, just providing some supplemental. I would

5 like to make note that we have examined, and talked to

6 NHTSA. There is absolutely no injuries that have been

7 documented due to these outlets. For - and in

8 addition, these outlets are not new. They've been on

9 the market for quite a while, as part of ICE, internal

10 combustion engine vehicle.

11 So the safety record of the industry is

12 sterling. We have no issues that need to be resolved

13 immediately.

14 Now, because of that, when we went to the

15 Panel, we were saying, 'Okay. You have this issue.

16 Let's work on maybe a joint SAE/NFPA work group that

17 can find a way of putting some standard language

18 together that is compatible with how our systems are

19 designed, especially when they are designed to provide

20 fault tolerance to FMVSS 305, and therefore, will not

21 conflict.'

22 So the whole idea of this was to say, 'We don't

23 have a safety problem that needs to be handled in this

24 code cycle. But we're not going to ignore it. We are

25 going to find a way of making something that gives you



562

1 the safety assurance you want, and be flexible for

2 industry.' And that's what we want, and that's what

3 we've been trying to do. Unfortunately, that did not

4 move forward, but I would like to see that happen.

5 And if this does carry, we will still be willing to

6 work on such a joint issue.


8 please.

9 KEN BOYCE: Thank you, Mr. Chair. Ken Boyce,

10 UL LLC, and the Chairman of Co-Panel 1, speaking in


12 You already heard me speak earlier, relative to

13 70-1, on, on - Panel 1's views on this, as it pertains

14 to the scope in Article 90.

15 I just wanted a few new comments. People have

16 heard the term NHTSA, and I just want to make sure

17 everyone understands. NHTSA is an acronym for the

18 National Highway Traffic Safety Administration. And

19 they say that they're responsible for keeping people

20 safe on America's roadways - a very important role.

21 But they also go on to say their mission is to save

22 lives, prevent injuries, and reduce economic costs due

23 to road traffic crashes, through education, research,

24 safety, safety standards, and enforcement activity.

25 So that's a very different purview than what we're



563

1 talking about here.

2 As Chairman Cline has pointed out in his

3 comments about CMP 12's view, of the nature of this

4 mode of operation of an electrical source, and the

5 NEC's clear purview over it, that we've already

6 established, that means we need requirements in the

7 NEC. Code Panel 12 has given us those requirements

8 through diligent deliberation.

9 I ask that you oppose this motion, and support

10 electrical safety.

11 JAMES GOLINVEAUX: Thank you. Microphone five.

12 JIM TARCHINSKI: Good evening. Jim Tarchinski,

13 representing SAE International, speaking for the

14 motion on the table. I would like to talk about two

15 of the previous comments that were made.

16 First, Mr. Cline mentioned safety. NHTSA - the

17 National Highway Traffic Safety Administration - uses

18 a method of protection called isolation resistance.

19 And the goal of that method is to make certain

20 touching high voltage, there are no hazards. But it's

21 different than the method in the NEC. And therefore,

22 the two are not compatible, and that's why it's very

23 important what was mentioned about the need for NFPA

24 and SAE International to work together.

25 The second comment was made relative to



564

1 National Highway Traffic Safety Administration only

2 covering vehicles when they're on the roadways.

3 That's not quite correct. NHTSA has stated that they

4 are responsible for vehicle safety in normal usage

5 conditions; and for an electric vehicle, that would

6 include charging. So NHTSA has vehicles' coverage

7 stationary, as well as in motion. Thank you.

8 JAMES GOLINVEAUX: Thank you. Microphone

9 three.

10 JOEL GORGON (phonetic): Mr. Chairman, I'm Joel

11 Gorgon with Cisco Systems, and I am speaking against

12 the motion. I'm a CMP 12 principal member. I do not

13 speak for CMP 12. Scott Cline has already done that.

14 I'd like to make a couple clarifications on

15 what we've been talking about here. Specifically, if

16 I look at the scope defined in 625.1, and I quote, 'It

17 covers the electrical conductors and equipment

18 connecting an electric vehicle to premise wiring.'

19 Now, I understand that a car is supposed to be on the

20 road. But when it's not on the road, and it's pulled

21 in the garage, and it's plugged into the garage and

22 it's charging, or delivering power into the home, it

23 now has, since it's delivering power into the home or

24 residence, it is now specifically powering that, and

25 has become part of the home power source system.



565

1 Further, with electric outlets that are inside

2 the vehicle, if I choose to clean my car while it's in

3 the garage, I can take my wet/dry shop vac and plug it

4 into said electrical outlet.

5 Now, there has to be some type of protection,

6 because now the car is no longer on the road. I'm not

7 driving 90 miles an hour down the road - I like to

8 drive fast, by the way - so I'm no longer driving

9 that. I'm actually parked in the garage, driving the

10 home.

11 This is, this is part of the National

12 Electrical Code. This text needs to be here. And

13 again, I speak against this motion, and I urge you all

14 to vote against this.

15 JAMES GOLINVEAUX: Thank you very much.

16 Microphone one.

17 EDDY GEDRIE: Me again, Eddy Gedrie, speaking

18 for myself. Call the question.

19 JAMES GOLINVEAUX: There's a motion on the

20 floor to call the question. I notice there are a


22 to speak, but we'll proceed with the motion on call



25 JAMES GOLINVEAUX: We do have a second. In



566

1 order to vote on this motion, please scroll down to




5 your vote.

6 Five seconds, the voting will be closed.



9 questions; 11 against calling the question. So the

10 vote is in favor of calling the question.

11 This will move us to the - restate the motion.

12 The motion on the floor is to Reject the Second

13 Revision 7783, Including Any Related Portions of the

14 First Revision No. 8597. To vote, touch the 'vote'





19 vote.




23 and 382 against the motion. The motion has failed.





567

1 please.

2 DOUG BURKETT: Hello. My name is Doug Burkett,

3 Ford Motor Company, and I'm here today representing 23

4 OEM companies, as well as the organizations of

5 Alliance of Automobile Manufacturers, Global

6 Automakers, and SAE International.

7 We request that the NFPA Accept Public Comment

8 1590, and only require the listing of any equipment

9 external --

10 JAMES GOLINVEAUX: Sir, Sir --

11 DOUG BURKETT: -- to the vehicle.

12 JAMES GOLINVEAUX: Let's, let's, let's stop on

13 - you've requested the Motion to Accept Public Comment

14 No. 1590. Correct?

15 DOUG BURKETT: Yes.

16 JAMES GOLINVEAUX: So there's a motion on the

17 floor to Accept Public Comment No. 1590. Is there a

18 second?


20 JAMES GOLINVEAUX: Did I get that second? All

21 right. Got a second. We do have a second. Please


23 DOUG BURKETT: Thank you. Again, my name is

24 Doug Burkett with Ford Motor Company, and I'm speaking

25 for the motion.



568

1 The Public Comment 1590 has not been adequately

2 considered. The current changes to the code creates

3 ambiguity. An attempt to clarify the code has instead

4 caused additional confusion.

5 It's our position that the requirement for

6 listing of any on vehicle components is improperly

7 directed. The requirement for listing any on vehicle

8 components creates at least six significant,

9 unresolved issues.

10 One, current automotive industry requirements

11 for on vehicle components have more stringent

12 specifications than similar current, off the shelf,

13 premises wiring type of components. Two, the NRTL

14 listing process is not consistent with NHTSA's legally

15 established self-certification process. Three,

16 listing of on vehicle components it not pragmatic, due

17 to the complexities of fully testing component

18 requirements outside of an actual vehicle. Four, a

19 listing requirement will delay service part

20 availability. Five, states typically adopt a code as

21 a legislative action. Individual state adoption of

22 different versions could raise issues of unique state

23 by state requirements for motor vehicles. Six,

24 assuming that listed components were required on

25 vehicles, there could be potential safety hazard for



569

1 AHJ inspectors performing on site inspections.

2 It must also be highlighted that as written,

3 the Second Draft version of 625.5 gives a blanket

4 listing requirement for any equipment that might be

5 added to this article of the code in the future.

6 Therefore, the items discussed above should also be

7 evaluated in terms of the negative impact they might

8 impart on the development of future technology in this

9 area.

10 It's appreciated that NFPA's goal is to

11 proactively update the code with well defined and

12 consistent standards. However, an on vehicle

13 requirement should be consistent with existing roles

14 within industry standard developments. There should

15 be separate infrastructure requirements addressed by

16 NFPA, and on vehicle requirements addressed through

17 SAE International. SAE standards are a recognized

18 source for automobile standards, and are often

19 referenced, adopted by NHTSA in federal regulations

20 such as FMVSS 305. Thank you.


22 would you like to state the Panel's position, please.

23 MICHAEL JOHNSTON: Thank you, Mr. Chair. I'd

24 like to defer to the Chair of Code Panel 12, Scott

25 Cline, for a technical response.



570

1 SCOTT CLINE: I am Scott Cline, representing

2 NECA. I am the Chair of NECA Code-Making Panel 12,

3 which is responsible for Article 625. I speak against

4 this motion.

5 Again, we hear from the vehicle manufacturing

6 industry that they should be able to offer options

7 which turn the vehicle into a non-transportation power

8 supply system, without conforming to NEC standards.

9 Despite hearing that the time spent by the Panel is

10 irrelevant, it actually proves the well-considered

11 actions which the Panel has taken.

12 I will again insist that the protections which

13 the Code-Making Panel was very careful to require, do

14 not impede the safe use of vehicles for

15 transportation; do not impede the safe use of vehicles

16 for providing power to a dwelling; do not impede the

17 safe use of vehicles for stationary use as a power

18 generator. Providing this option is exactly that.

19 It's an option not relevant to transportation.

20 We only insist that it be done safely, to the

21 same standards as elsewhere in the NEC. Please vote

22 no on this motion.






571

1 support, or against the motion. Microphone five,

2 please.

3 JIM TARCHINSKI: Good evening. Again, my

4 name's Jim Tarchinski, representing SAE International,

5 speaking for the motion at hand.

6 As Mr. Burkett already mentioned, the listing

7 process would be very difficult to set up and operate.

8 Let me explain why, though.

9 Automobiles use a distributed computing system,

10 where the software to drive a particular component

11 generally does not reside in that component. It could

12 reside across the vehicle. This would make it

13 different - this would make it difficult to set up a

14 particular device in a listing lab.

15 Also, the listing requirements do not cover the

16 automotive environment, including crash worthiness

17 requirements. As Doug mentioned, the AHJ would have

18 no way to enforce this requirement. They cannot

19 safely disassemble a vehicle in the field to make

20 certain it complies with the NEC code.

21 And as previously mentioned, the National

22 Highway Traffic Safety Administration has this area

23 covered. They have regulations on the book. NHTSA

24 obviously has not seen any safety issues in this

25 field, or they would have started an investigation,



572

1 started regulations.

2 For these reasons, I strongly recommend a vote

3 in favor of these motions - or this motion. Thank

4 you.


6 please.




10 floor to call the question. I notice there are a


12 to speak, but I will proceed with the vote on the call

13 of the question Do we have a second?


15 JAMES GOLINVEAUX: We do have a second. And in

16 order to vote on the motion, please scroll down to the




20 your vote.

21 The voting will end in five seconds.



24 question; 14 against calling the question. Therefore,

25 the motion is passed to call the question.



573

1 I'll move to the main motion. Before we vote,


3 to Accept Public Comment No. 1590. To vote, touch the





8 record your vote.




12 and 346 against the motion. The motion has failed.



15 No. Okay. I'm not seeing the maker of the motion at

16 a microphone. Last call for 70-39. Seeing that the

17 maker of the motion, nor an identified designated

18 representative has approached the - to make the

19 motion, 70-39, in accordance with the NFPA Convention

20 Rules, Section 2.7, the motion may not be considered

21 by the assembly, and is removed from the Agenda. We

22 will now move on to the next motion included in the

23 Agenda.





574

1 please.

2 SCOTT SCHMIDT: Yes. This is Scott Schmidt

3 with the Alliance of Automobile Manufacturers. I'd

4 like to move to withdraw this motion.


6 (applause)

7 JAMES GOLINVEAUX: The Motion 70-40 appeared on

8 the Agenda. However, the authorized maker of the

9 motion has notified NFPA that he is no - no - no

10 longer wishes to pursue this motion. Therefore, in

11 accordance with the NFPA Rules, Convention Rules at


13 assembly, and is removed from the agenda. We will now

14 move to the next motion.

15 As we discussed earlier, we have reordered the

16 next motion so that it will be discussed in paragraph

17 section order. The discussion on Motion 70-3 will be

18 heard next.

19 SCOTT SCHMIDT: Thank you. This is Scott

20 Schmidt of the Alliance of Automobile Manufacturers.

21 JAMES GOLINVEAUX: Let - let me, let me --

22 SCOTT SCHMIDT: I'm sorry.

23 JAMES GOLINVEAUX: Just give me one - now let's

24 proceed with the discussion on Certified Amending

25 Motion 70-3. Microphone four, please.



575

1 SCOTT SCHMIDT: Thank you, Chairman. Scott

2 Schmidt with the Alliance of Automobile Manufacturers,

3 for Nancy Stone, the Auto Makers Trade Association,

4 and SAE. I'd like to make a motion to Accept PC

5 Comment 1482.


7 on the floor to Accept Public Comment 1482. Is there

8 a second?

9 UNIDENTIFIED SPEAKER: I second.



12 SCOTT SCHMIDT: Thank you. This is Scott

13 Schmidt with the Alliance of Automobile Manufacturers,

14 and I support the motion.

15 625.60 seeks to regulate all on board AC

16 receptacle outlets that provide power to external

17 loads using the vehicle as a source of supply.

18 Again, we've mentioned that there requirements

19 really do not contemplate that automobile electric's

20 architecture, that's significantly different from the

21 installations. And 6025.60 - conflicts with existing

22 safety oversight. And as I've repeated before, and

23 I'll be very brief - that it basically conflicts with

24 federal preemptive authority. It also conflicts with

25 some of the requirements in the FMVSS standards.



576

1 There also is no real safety need that's been

2 identified, and we've looked to try to have a way to

3 set up a joint kind of SAE/NFPA type of approval, or a

4 - I'm sorry, I'm getting tired - approach to try to

5 come up with something that's fairly reasonable.

6 However, what is a little different about this

7 is that there are a lack of safety benefits with

8 regards to the automotive applications. And 6025.60

9 seeks to improve safety by requiring GFCI protection.

10 That's just it. However, a ground really doesn't

11 exist in automotive applications, and it's therefore

12 not really appropriate to apply the ground fault logic

13 to those installations. If installed, the ground

14 effect GFCI may not even trip in fault conditions.

15 One of the things about FMVSS 305 and SAE standards is

16 they require isolation resistance that limits fault

17 currents to no more than two milliamps. Meanwhile,

18 the NFPA Class A GFCI says it shall not trip unless

19 the fault current, you know, is less than four

20 milliamps. So there's a bit of a disconnection there

21 that I think (unintelligible) going to be

22 (unintelligible) attention to.

23 There's also various use conditions, and

24 receptacles are not appropriately addressed. 625.60

25 lacks clarity on the significantly wide variety of



577

1 usages and equipment it may be intended to address.

2 For example, AC receptacle outlets in the cabin are

3 not electrically grounded, and the on board wires

4 conductively connected to the AC receptacle are

5 electrically insulated. If a ground fault were to

6 occur, the current return path that might cause

7 electrocution would not be formed, rendering GFCI

8 protection unnecessary.

9 There also is inconsistency with other NEC

10 Sections - 625.60, 625.2, both clearly specify

11 requirements for on board outlets. However, 625.1 and

12 90.2 can be interpreted otherwise.

13 Code-Making Committee attempted to address

14 these inconsistencies, but the definition of such

15 interfaces remain. Thank you.





20 the NEC Correlating Committee. I'd once again like to

21 defer to the Chair of Code Panel 12, Scott Cline, at

22 microphone two, please.

23 SCOTT CLINE: One last time - I'm Scott Cline,

24 representing NECA. I am the Chair of NECA - of NEC

25 Code-Making Panel 12, which is responsible for Article



578

1 625, and I speak against this motion.

2 You have heard my statements about the decision

3 by vehicle manufacturers to provide electrical supply

4 power having nothing to do with transportation.

5 During the many hours the Panel spent on these issues,

6 we did thoroughly consider the many requirements

7 brought in during the First Revision process. We

8 carefully listened to the concerns brought up in

9 discussion, and made compromises, with a target to

10 keep all necessary, basic regulations, and still

11 remove some regulations which were not written in as

12 efficient a manner for manufacturing.

13 Among the Committee actions on 625.60 was SR

14 7796 that removed the paren, (a) grounding requirement

15 - changed to listed receptacle. That was voted 17 to

16 1. SR 7798 allowed paren, (c) overcurrent protection

17 to be anywhere in the supply, instead of at the

18 receptacle. Panel voting was 18 to 0. SR 7799,

19 allowed paren, (d) GFCI protection anywhere in the

20 system, as long as reset was readily accessible.

21 Panel voting was 17 to 1. SR 7800 deleted (e), the

22 inverter listing requirement, due to the added

23 requirements of (a) through (d). That vote was 18 to

24 nothing. SR 7801 deleted paren, (f) marking

25 requirements as not required as a redundant issue.



579

1 Panel voting was 18 to zero.

2 We have already carefully compromised on this

3 solution.

4 (laughter)

5 SCOTT CLINE: Is what we've done perfect?

6 Nothing I know of in the NEC is perfect, but future

7 editing is the way to strive for better, not

8 abandoning hundreds of hours spent on the work done to

9 date. The NFPA has the responsibility to consider

10 these regulations. I say to please vote no on this

11 motion.



14 name and affiliation, and whether you're speaking in

15 support, or against the motion. Microphone two,

16 please. Oh - I, I apologize. Microphone five.

17 JIM TARCHINSKI: Good evening. Jim Tarchinski,

18 representing SAE International, speaking for the

19 motion.

20 I would just like to elaborate on the comments

21 that Mr. Schmidt made, relative to the existing

22 disconnects between FMVSS 305 and what's in the draft

23 version of the National Electric Code.

24 The FMVSS is very specific that vehicles must

25 shut down if there's an isolation fault equivalent to



580

1 two milliamps. But in the GFCI requirements we need

2 to be able to keep operating in that condition.

3 That's a very significant disconnect.

4 The other thing that was pointed out to me is I

5 realized a lot of you are thinking about vehicles

6 powering the home. And that's not really the use case

7 that is being the considered here. The outlets are

8 provided in vehicles for convenience so customers can

9 charge their cell phone, can go ahead and use their

10 laptop for the folks in the backseat. They will not

11 draw significant power. They will not allow inductive

12 loads. They will not be able to power your home.

13 They are intended for small loads. Read your owner's

14 manual. That's generally in there; it's very well

15 defined. The system will shut down if it detects too

16 much current being taken. Again, it's not intended

17 for powering the home. It's convenience only. Thank

18 you.




22 UNIDENTIFIED SPEAKER: Ah.

23 (applause)


25 floor to call the question.



581

1 UNIDENTIFIED SPEAKER: Mr. Chairman, I object,

2 from the point of view that I was at this microphone

3 before he stood up out of his chair, and got to that

4 stand.

5 JAMES GOLINVEAUX: I have my own notes of when

6 I saw people at microphones, and I apologize if I

7 didn't see you, but the motion has been called. So I

8 will have to go with the motion. I, I --

9 UNIDENTIFIED SPEAKER: I still object.

10 JAMES GOLINVEAUX: I do the best I can to keep

11 up with who's at a microphone.

12 EDDIE GEDRY: Mr. Chair, I don't know if this

13 is out of order, but this gentleman was correct. He

14 was there first.

15 JAMES GOLINVEAUX: I have a motion. I don't

16 have a second yet. Can he withdraw his motion before

17 I get a second?





22 UNIDENTIFIED SPEAKER: That's it.

23 (laughter)

24 JAMES GOLINVEAUX: That's it?




582

1 EDDIE GEDRY: May I withdraw my motion?

2 JAMES GOLINVEAUX: I'm looking for my hired

3 help here.

4 (laughter)

5 JAMES GOLINVEAUX: They told me I was ir-

6 reasonable to think of things like this, so I'm going

7 to pause.



10 UNIDENTIFIED SPEAKER: Second the motion.


12 UNIDENTIFIED SPEAKER: Third.

13 JAMES GOLINVEAUX: And, and I do apologize.

14 It's, it's touch to be a Chair, and, and see, and --

15 UNIDENTIFIED SPEAKER: I'm good, Mr. Chair.

16 I'm, I'm good.


18 UNIDENTIFIED SPEAKER: Seriously, it's cool.

19 JAMES GOLINVEAUX: Okay. I, I apologize. I

20 really do.


22 JAMES GOLINVEAUX: I, I do the best I can to

23 keep track of who's at which microphone. And then I

24 also try to balance for and against so we don't get a

25 whole bunch of one side. So it - trying to do the



583

1 best that we can.

2 So I have a motion on, on the floor to call the

3 question. There were a number of people remaining at

4 the microphone waiting to speak. If you vote the

5 motion down, those people will have a chance to speak.

6 It's your, it's your call. Do I have a second?


8 JAMES GOLINVEAUX: I have a second. In order


10 bottom of the table to vote. If you wish to vote in



13 your vote.


15 The vote is closed.

16 And 317 in favor of calling the question; there

17 are 70 against the motion to call the question. So

18 the motion has passed to call the question.

19 And before we vote, let me restate the motion.

20 The motion on the floor is to Accept Public Comment

21 No. 1482. To vote, touch the 'vote' button. If you







584





5 failed.


7 Certified Amending Motion 70-41. Microphone four.

8 HOWARD HERNDON: Howard Herndon with PEARL;

9 Motion 70-41 to Reject Second Revision 7522.



12 there a second?




16 HOWARD HERNDON: Real quick on this. There's

17 two issues. One is, we feel that this is new material

18 because this has not been covered with any review.

19 And fire pump controllers are made up of many

20 different components. They could include circuit

21 breakers, contactors, relays, starters - all types of

22 components within those systems. And we feel that not

23 permitting them can be - to be reconditioned could

24 actually do undue hardship in existing facilities.




585


2 MICHAEL JOHNSTON: Thank you, Mr. Chair. As a

3 reminder, one of the responsibilities of the

4 Correlating Committee is to call balls and strikes

5 when it comes to judgment on new material. The NEC

6 Correlating Committee reviewed the complete record of

7 both public input and comments to ensure there was no

8 new material being introduced. The Correlating

9 Committee concluded that no new material was related

10 to the definition of reconditioned, and the rules

11 related to it. There were no apparent conflicts, or

12 correlation issues identified by the Correlating

13 Committee, and I'd like to defer to the Chair of Code

14 Panel 13, Linda Little, and I think she's at


16 LINDA LITTLE: Thank you. My name is Linda

17 Little. I'm Chairman of Code Panel 13, and I

18 represent the IBEW. I stand in opposition to the

19 motion on the floor, and I support the Panel action.

20 Multiple manufacturers are represented on Code

21 Panel 13, and all sides of the issue had an

22 opportunity to speak. I encourage this body to oppose

23 the motion on the floor. Thank you.





586

1 name and affiliation, and whether you are speaking in

2 support, or against the motion. I'll go to microphone

3 two.

4 JOHN KOVACHIC: Thank you, Mr. Chairman. I'm

5 John Kovachic, UL LLC, and I'm speaking on behalf of

6 UL, against the motion. I'm also a member of the NFPA

7 20 Committee on Stationary Fire Pumps. I'm not

8 speaking on behalf of the Committee, but as a 30 year

9 member of the Committee, I'd like to address primarily

10 fire pump controllers. But transfer switches can be

11 provided as a combination unit with a fire pump

12 controller, so they factor into my comments, as well.

13 Fire pump controllers are life safety

14 equipment, and no doubt about it. Just ask any member

15 of the 20 Committee, or other committees associated

16 with fire protection and fire suppression. A fire

17 pump controller controls a motor, which is a prime

18 mover for a pump that delivers water into a sprinkler

19 system in the event of a fire. Besides controlling

20 the motor, the fire pump controller performs other

21 function. It is monitoring the pressure in that

22 sprinkler system, which is the parameter that

23 determines whether a pump needs to start to deliver

24 water - for example, when a sprinkler opens. The

25 controller is also monitoring conductors going out to



587

1 remote start stations - looking at those conductors to

2 make sure that they're continuous. If there's any

3 breakage or any disconnection, they're required then

4 to send a signal back to the controller, which then

5 starts the pump. So it's definitely life safety

6 equipment.

7 And reconditioning a fire pump controller would

8 be tantamount to playing with the lives of people in a

9 building that are depending on fire suppression

10 equipment to protect them.

11 Ladies and gentlemen of this body, I urge you

12 to vote against this motion. Thank you.


14 three, please.

15 MIKE STONE: Mike Stone, representing NEMA.

16 NEMA opposes this Motion to Reject Second Revision

17 7522 related to the reconditioning of fire pump

18 controllers and transfer switches. Thank you.


20 please.

21 BARRY RODGERS: I am Barry Rodgers. I

22 represent Schneider Electric. We are against this


24 to include this language.

25 Safety is the major reason to adopt this



588

1 change. My concern - my safety concern includes

2 safety of workers, as well as safety of occupants and



5 please.

6 THOMAS DOMITROVICH: Thank you. My name is

7 Thomas Domitrovich, with Eaton. Transfer switch and

8 fire pump controllers - both of those components are

9 very technically complicated devices. As a

10 manufacturer of both of those devices, I do not

11 support the CAM that's on the, on the motion. I'm

12 speaking in opposition.

13 JAMES GOLINVEAUX: Yes.

14 THOMAS DOMITROVICH: Yes.


16 THOMAS DOMITROVICH: Sorry about that.

17 Speaking in opposition. These - this equipment is

18 very technical, and it should not be reconditioned in

19 the field, nor any time after installation or

20 manufacture. It is a life saving equipment, and very

21 important that it functions correctly. Please vote

22 against this motion on the floor. Thank you.



25 Revision No. 7522? Just waiting to see if they're



589

1 going to a microphone. No? Okay. Mr. Johnston, any

2 final comment?


4 Chair. Thank you.

5 JAMES GOLINVEAUX: All right. Before we vote,


7 to reject Second Revision 7522. To vote, touch the










17 Now let's proceed to the discussion on

18 Certified Amending Motion 70-42. Microphone four.

19 HOWARD HERNDON: Howard Herndon with PEARL.

20 Reject - Motion 70-42 to Reject the Second Revision

21 7584.



24 there a second?




590



3 HOWARD HERNDON: We feel this is the same case

4 as the previous discussion - that it is in fact, new

5 material, and that in fact, they are made of many

6 different components, which many of these components

7 can be reconditioned to assemble a complete automatic

8 transfer switch. And in fact, I've done it myself.


10 JAMES GOLINVEAUX: Not going to say it.






16 of both public input and comments to ensure that there

17 was no new material being introduced. The conclusion

18 was that there were - was no new material introduced

19 related to the definition of recondition, and the

20 rules related to it. There are no apparent conflicts

21 or correlation issues related to this CAM. I would

22 like to defer of Code-Making Panel 13, Linda Little,

23 at microphone three for some technical comments.


25 Little. I'm Chairman of Code Panel 13. I represent



591

1 IBEW. I stand in opposition to the motion on the

2 floor, in support of Panel action.

3 Multiple manufacturers are represented on Code

4 Panel 13, including transfer switch manufacturers.

5 And all of them had the opportunity to present their

6 sides of this issue. I encourage this body to oppose

7 the motion on the floor. Thank you.





12 please.



15 Brotherhood of Electrical Workers. I rise in


17 We have heard all the arguments. This - there

18 is no new material. These are transfer switches for

19 emergency systems. We're going to get to do this

20 again in 701, 702, and 708. I urge that this body,

21 very quickly, oppose the motion on the floor. Thank

22 you.


24 three, please.

25 THOMAS DOMITROVICH: My name is Thomas



592

1 Domitrovich with Eaton. We are a manufacturer - Eaton

2 is a manufacturer of automatic transfer switches, and

3 we do not support the reconditioning of this

4 equipment. It is life safety. This is Article 700.

5 We do not support, and we would hope that others in

6 this room will continue to not support the

7 reconditioning of this equipment. I speak in

8 opposition to this motion. Thank you.




12 motion. We support the action take by the Code Panel

13 to include this language.

14 Safety is the major reason to adopt these

15 changes. My safety concern includes the safety of

16 workers, as well as safety of occupants and



19 further discussion on Motion 70-42 to reject Second

20 Revision 7584? Mr. Johnston, do you have any final

21 comments?


23 Thank you.





593

1 to Reject Second Revision 7584. To vote, touch the





6 record your vote.







13 please.

14 HOWARD HERNDON: Again, this is Howard Herndon,

15 representing PEARL, and we would have the same

16 argument, that this is a new material, number one.

17 JAMES GOLINVEAUX: Excuse me.

18 HOWARD HERNDON: Number two --

19 JAMES GOLINVEAUX: You need to make the motion.

20 HOWARD HERNDON: Oh, I'm sorry. Rejecting -

21 Motion 70.43, Rejecting Second Revision 7586.







594



3 HOWARD HERNDON: Our discussion would go to the

4 same line that it's gone with the other issues. On

5 transfer switches, we feel that these can be

6 reconditioned, and this is new material to this

7 section.




11 Correlating Committee reviewed the complete record of

12 both public input and comments to ensure there was no

13 new material being introduced. The conclusion was

14 that no new material was being introduced related to

15 the definition of reconditioned, or any of the rules

16 related to it, including the new rules. There are no

17 apparent conflicts or correlation issues, and I'd like

18 to defer to the Chair of Code Panel 13, Linda Little,

19 for a technical response, at microphone three.


21 Little. I'm the Chairman of Panel 13, and I represent

22 the IBEW. I stand in opposition to the motion. All

23 sides of this issue had an opportunity to speak at the

24 Panel meetings. I encourage you to reject this




595



3 name and affiliation, and whether you're speaking in


5 please.

6 THOMAS DOMITROVICH: Thank you. My name is

7 Thomas Domitrovich, with Eaton. I speak in opposition

8 to the motion on the floor.

9 This is not new material. We've heard this

10 over and over again. I agree with that. And I agree

11 with the, the actions of the Panel. We should

12 continue to support the Panel. Please vote in -

13 against this motion. Thank you.



16 represent Schneider Electric. We're against this


18 to, to include this language. Safety is the major

19 reason to adopt these changes. I urge you to vote




23 Revision No. 7586? Mr. Johnston, any final comments?





596

1 MICHAEL JOHNSTON: Thank you.



4 to Reject Second Revision No. 7586. To vote, touch












16 please.

17 HOWARD HERNDON: Howard - Howard Herndon,

18 representing PEARL. Motion 70-44 to Reject an

19 Identifiable Part of Second Revision 7588.









597

1 HOWARD HERNDON: Article 702.5 - transfer

2 switches can be found in many, many different pieces

3 of equipment, including UPSes and, and in separate

4 components, being both breaker based, and contactor

5 based. We feel like that this article paints it with

6 a very broad brush, and is new material.


8 would you like to offer the Panel's position.

9 MICHAEL JOHNSTON: Thank you, Mr. Chair. Since

10 the new material issue was brought again, I'll

11 reemphasize that the NEC Correlating Committee,

12 fulfilling its responsibilities, did review the

13 complete record of both public input and comments to

14 ensure that no new material was being introduced.

15 Conclusion was that no new material related to the

16 definition of recondition, and the rules that relate

17 to it, were introduced into the process. There are no

18 apparent conflicts or correlation issues. And I'd

19 like to defer to the Chair of Code Panel 13, Linda

20 Little, at microphone three, please.


22 Little. I'm the Chairman, Code Panel 13. I represent

23 the IBEW, and I speak in opposition to this motion.

24 All the Panel members had ample time to discuss

25 this issue. Many manufacturers are represented on our



598

1 Panel. I encourage you to vote against the motion on



4 JOHN MCKENZIE: Thank you, Mr. Chairman. John

5 McKenzie. I represent Schneider Electric. We support

6 the actions of the Code-Making Panel, and oppose this

7 motion.

8 I don't wish to subject the Membership to a

9 complete restatement of our argument against Motion

10 70-30, but the premise is the same.

11 I will, however, restate that engaging in

12 reconditioning without knowledge of the methods and

13 procedures used by the manufacturer can result in an

14 unsafe product; or the attempt to recondition a

15 product that cannot and should not be reconditioned.

16 We urge the Membership to oppose this motion. Thank

17 you.


19 three, please.

20 THOMAS DOMITROVICH: Thomas Domitrovich with

21 Eaton, speaking in opposition to the motion on the

22 floor. Eaton is a manufacturer of transfer switches.

23 These are safety related devices. I agree with my

24 colleague from Schneider that explained these - that

25 modifying this equipment can be dangerous, and result



599

1 in tragedy. So please, continue to not support this


3 JAMES GOLINVEAUX: All right. Thank you. Is

4 there any further discussion on Motion 70-44 to Reject

5 an Identifiable Part of Second Revision No. 7588? Mr.

6 Johnston, any final comment?



9 MICHAEL JOHNSTON: Thank you.

10 JAMES GOLINVEAUX: Before we vote, let me














24 please.

25 TIM CROUSHORE: Yes. My name is Tim Croushore.



600

1 I represent the electric utility industry as a

2 consultant for the Edison Electric Institute. And I

3 move to Reject Second Revision No. 8159, Including Any

4 Related Portions of First Revision No. 8608.


6 on the floor to Reject Second Revision No. 8159,

7 Including Any Related Portions of the First Revision





12 TIM CROUSHORE: Thank you. My name is Timothy

13 Croushore. I represent the electric utility industry

14 as a consultant for the Edison Electric Institute. I

15 stand for the motion.

16 What this deals with, in Article 705 is

17 interconnected electric power production sources that

18 are interconnected with the electric utilities. These

19 sources are solar, energy storage, fuel cells, wind,

20 and as we've heard, vehicles.

21 The three options to interconnect premises

22 wiring systems - and I'll really emphasis premises

23 wiring, because we really need to look at this is the

24 - what's covered by the NEC is premises wiring.

25 There are three options to interconnect



601

1 premises wiring - with generation, premises wiring

2 generation to the utility. One would be after the

3 service disconnecting means. Two would be a separate

4 service, permitted - already permitted by 230.2(A)(5),

5 or 230.40. Or option number three, and this is what

6 this is about - is ahead of the disconnecting means,

7 is already permitted in 230.82, specifically Item No.

8 6.

9 Now, since this CAM deals with option number

10 three, ahead of the service disconnecting means, there

11 was a lot of moving parts during both the First

12 Revision, and Second Revision process on the 2020 code

13 making process. This involved three different panels

14 - Code-Making Panel 4, in which I'm a principal

15 member; Code-Making Panel 5; and Code-Making Panel 10.

16 Okay. Now, this deals with how to ground and bond

17 these connections.

18 Now, during the same time, Code-Making Panel 5

19 already has worked on these requirements to bond this

20 in Article - bond and ground this in Article 250.

21 They are covered in new Section 250.25 for system

22 grounding, and our traditional Section 250.92 for the

23 bonding of services.

24 Basically, the requirements in 705-11(D) are

25 not required. Furthermore, this is a safety issue,



602

1 with - when you have a grounded service. The

2 conductor is not bonded through the main bonding

3 jumper, through the enclosure of the disconnecting

4 means, as required by 250-24(C), and also by 250-28.

5 My CAM eliminates this complete section in its

6 entirety, and the requirements of Article 250 can

7 apply safely. The issue was thoroughly discussed at

8 length in the Electrical Section meeting, and the

9 members voted to support this CAM. I request the

10 Membership of the Association to vote in favor of this

11 Certified Amending Motion. Thank you.




15 were no apparent correlating issues, or conflicts

16 identified by the NEC Correlating Committee. And I'd

17 like to defer to the Chair of Code-Making Panel 4, Jim

18 Rogers. And Jim is at microphone two.

19 JIM ROGERS: Good evening - oh, good morning,

20 pretty soon.

21 (laughter)

22 JIM ROGERS: My name's Jim Rogers. I represent

23 IAEI as the Chair on Code-Making Panel 4. I speak

24 against the motion.

25 Code-Making Panel 4 deals with alternative



603

1 energy sources, and their interconnection with the

2 utility companies in 705. We had multiple public

3 inputs, and public comments on this issue. And we

4 soon discovered that there was rampant confusion all

5 across the country on how this could be done safely

6 and uniformly. And we had, like I say, multiple

7 public inputs and comments on that.

8 The Panel spent several hours - multiply - this

9 was probably the most heavily discussed item in both

10 the First Revision and the Second Revision process.

11 As a result, we - the Panel constructed language

12 totally in the First Revision, that was totally

13 rewritten in the Second Revision, to simplify and

14 clarify the portions of Article 250 that should be

15 utilized when making the connection to one of these

16 disconnects that's required ahead - when you make a

17 connection ahead of the service main.

18 The Panel never wanted to circumvent the

19 requirements of, of Article 250, but simply clarify

20 them. And, and that was the language that they put in

21 place to do that. Sorry, I'm a little tired. I'm

22 getting - I'm losing my train of thought here a little

23 bit.

24 So the, the - it was an overwhelming majority.

25 17 to 1 was the Panel vote to accept this language.



604

1 And the one dissenting vote was the EEI vote. And

2 part of the rationale for that dissenting vote was

3 250.92 not being complied with. But the language does

4 reference 250.92. And I respectfully request, because

5 of that clarity and uniformity in application of these

6 rules, I respectfully request that you support the

7 Panel on this, and reject this motion.





12 please.

13 JASON FISHER: Hello. I am Jason Fisher. I am

14 representing the Solar Energy Industries Association

15 here, and I'm speaking against this motion. I was one

16 of the voting members of the Code-Making Panel Four,

17 and I'm a licensed electrician who has applied the

18 code to my daily work for over 25 years. I'm not

19 speaking on behalf of the Technical Committee, though.

20 The first thing I'd note about this motion is

21 that the report of the motion's Committee that's

22 currently posted on NFPA 70 Next Edition web page as

23 of today, shows different language than that is what's

24 up on the screen. According to that report, it states

25 that - that is stated as the final report on the



605

1 Certified Amended Motion, that this motion, based on

2 NITMAM Log 108 was a motion to reject a Second

3 Revision. What I see here, though, is completely

4 different, since now this motion seems to want to

5 strike the entire section, including the First

6 Revision language.

7 This concerns me a bit, since I don't really

8 understand how a motion can keep changing up to the

9 last minute, but - and personally, I am not clear that

10 this motion's in order. But since it's up there, I'll

11 go ahead and address it, with my apologies to the

12 members in the room for the time it takes me, but I

13 must go on the record to oppose this.

14 It, it's not true I do not agree that there is

15 a safety concern with this language. I agree with our

16 Chair that this language, which the Committee worked

17 very hard to create with lots of debate, adds a lot of

18 clarity - that's important. It was significantly

19 debated, with dozens of task group meetings, and many

20 hours spent on it, and it was based on multiple inputs

21 and comments.

22 To delete this section would, in fact, remove

23 requirements for these installations, which are

24 becoming increasingly common every year. The removal

25 of a set of requirements that were written to ensure



606

1 safety, does not improve safety. By removing this

2 section, electricians like myself, and enforcers of

3 the code would be left without clear requirements, and

4 thus would have to go back to hunting for, and

5 debating over what the code actually requires for

6 these installations. I didn't hear that there were

7 any real conflicts. There was a suggestion that this

8 was just duplicative. I don't think it's going to be

9 the only language in the code that helps aid the users

10 of the code to follow requirements correctly, and

11 that's why it's important to remain. I urge the

12 membership to reject this motion, and to support the

13 Committee.


15 please.



18 Section of the National Fire Protection Association,

19 and speaking for the motion.




23 of this body, I ask for your support in voting for

24 this motion. Thank you.




607

1 please.

2 TIM CROUSHORE: Thank you very much. Timothy

3 Croushore. I represent the electric utility industry

4 as a consultant through the Edison Electric Institute.

5 I stand for the motion.

6 A couple different things. Jim Rogers,

7 excellent Panel Chairman. As you know, it's Panel

8 Chairman's responsibility to stand up and support the

9 Panel Chair, and every good panel chairman does that.

10 The issue here is not necessarily supporting the

11 panel; the issue here is one of safety. If you

12 notice, the, the disconnecting means that we've been

13 talking about, and we'll be covering that on the next

14 Certified Amending Motion, should be a service

15 disconnecting means. And as you know, every inspector

16 knows on the service disconnecting means, it's not the

17 supply side bonding jumper; it's the main bonding

18 jumper. And if you look at about the middle of the

19 paragraph, it's incorrect.

20 What we're concerned with is confusion between

21 the requirements of Panel 5, and these requirements in

22 the field. We respectfully request that all of these

23 be removed, and new Section 250.25, which for a

24 grounded service, talk about 250.24, and that is about

25 a page and a half. You cannot cover all the



608

1 requirements of 250.24 in just one few - in just a few

2 sentences.

3 So therefore, I recommend to the, the

4 Association that we support this Certified Amending

5 Motion, and leave the grounding to the grounding

6 experts in Article 250. Thank you.


8 LEO ZIEMAN (phonetic): Thank you. My name is

9 Leo Zieman. I am with Florida Power and Light, and

10 also with the Edison Electric Institute, and am voting

11 alternate for Panel No. 4. And I speak in favor of

12 this motion, for the exact same reasons that they have

13 been stating all along - and that is that the language

14 in their proposed revision, which is shown up there in

15 red, would constitute a problem with the availability

16 of fault return back to the source to the utility.

17 And that is really what's at crux here.

18 I also believe that, along with my colleague,

19 that when we're talking about grounding and bonding,

20 it does belong with Code-Making Panel 5. Thank you.


22 CHARLES MELLOW: Charles Mellow, with CDC

23 Mellows Consulting, respect - representing myself

24 here. The statement here that this (unintelligible)




609


2 CHARLES MELLOW: I'm speaking for the motion.

3 Thank you. There are some technical errors, actually,

4 in this. I am a long time member of Code Panel 5,

5 just recently off of that. But the use of the term

6 supply side (unintelligible) is actually technically

7 incorrect. What is actually needed in this location

8 is bringing the grounded circuit conductor from the

9 utility to this disconnect. That is a fault return

10 path.

11 This is about taking care of ground fault

12 current, wherever it happens in the system, and it

13 needs to be treated essentially just like a service.

14 Whether you call it a service or not doesn't matter,

15 but from a fault current standpoint, it needs to be

16 treated, and grounded, and bonded exactly like a

17 service disconnect would be. Please vote for this

18 motion.



21 Hartwell - faintly in favor of the motion.

22 At the Electrical Section, I voted against

23 this. I've now reconsidered that position. But I do

24 have a problem with describing this as a service. To

25 my way of thinking, a service supplies load. These do



610

1 not supply load.

2 However, the reason that I have changed my

3 position is that the existing text that is presented

4 in 705.11(D) can frequently undersize the conductor

5 that will accomplish the fault current return. I use

6 that kind of tortured construction to avoid the

7 question of whether it is a supply side bonding

8 jumper, or the main bonding jumper. In order to get

9 there, you have to settle the question, is it a

10 service, or not.

11 So I have a suggestion. I believe that this

12 motion is going to pass. And I suggest to Code Panel

13 4 that the way to get around this is to immediately

14 come back with a Tentative Interim Amendment that

15 restores 705.11(D), essentially the way it - they

16 wrote it, except at the end of the second sentence,

17 where it relates to the size of this fault return

18 conductor - maybe it's a main bonding jumper, and

19 maybe it's a supply side bonding jumper - we could

20 have a very interesting discussion about that. But

21 the point is, and the safety is - to make darned sure

22 that it is the right size. And whether you think it's

23 a service or not, we can establish if, if the Panel

24 comes back with a TIA, they can change this, the, the

25 back end of that sentence, and instead of relating the



611

1 size, basing the size on the size of the 705.11(B)

2 conductors, just simply say that it is to be sized on

3 - in reference to the size of the service conductors

4 to which the 705.11(B) conductors are connected.

5 And in that way, you sidestep the entire

6 semantic issue of whether it's a service or not, and

7 you accomplish the required safety by making sure that

8 that conductor is properly sized.



11 Revision No. 81-59, Including Any Related Portions of

12 First Revision 8608? Mr. Johnston, do you have any

13 final comment?


15 comments, Mr. Chair. Thank you.



18 to Reject Second Revision 8159, Including Any Related

19 Portions of the First Revision 8608. To vote, touch









612




4 passed.



7 please.

8 TIM CROUSHORE: My name is Tim Croushore. I

9 represent the electric utility industry as a

10 consultant through the Edison Electric Institute. I

11 move to Accept an Identifiable Part of Public Comment

12 No. 315.







19 TIM CROUSHORE: My name is Tim Croushore. I

20 represent the electric utility industry as a

21 consultant through the Edison Electric Institute.

22 This issue is relatively the same issue that we

23 talked about of Option 3 of 705.11. As Chairman

24 Rogers had said, there was confusion in this industry,

25 and we're trying to basically clarify this.



613

1 But one of the things that the Panel wanted to

2 do was to completely not name this disconnecting means

3 a service disconnecting means. So what they chose to

4 do, and the difference between what you see on the

5 left and what you see on the right, is just a deletion

6 of the word 'not'. Okay. Now, as we all know - or

7 maybe you don't know - Panel 10 did change the

8 definition of service during this 2020 cycle, is these

9 conductors that connect the utility to the premises

10 wiring. It no longer is for the transfer of energy

11 from the utility to the premises wiring. It can flow

12 both ways, per the definition of service. So that's

13 one thing that Panel 10 did.

14 Panel 10 also initiated 230.85, which they

15 wanted to, wanted for, wanted to family dwellings,

16 limit the number of disconnecting means for emergency

17 response personnel.

18 What the, what the interconnected generation

19 folks wanted to do was - 'If we don't call this a

20 service disconnecting means, then I can get away from

21 the six disconnect rule of 230.71.' As we know, there

22 are only four disconnects that can be in this case

23 that's not considered a service disconnecting means.

24 Now, Panel 10 did look at this, and there were

25 requests to Panel 10. They rejected them all. My



614

1 suggestion is that we reject these, as well.

2 So in addition, 237.70 - basically, the general

3 requirement is means shall be provided to disconnect

4 all ungrounded conductors in a building or other

5 structure from the service conductors. That's one of

6 the main requirements, that we want to be able to

7 separate the utility from the premises wiring system.

8 237.70 also has location, readily accessible

9 locations - these things can't be in a bathroom, okay.

10 If, if you have a remote control, how that has to

11 work. These disconnecting means have to be marked as

12 a service disconnecting means in such a way that it's

13 understand that this will disconnect from the utility.

14 And there's a requirement for the suitability of use,

15 so use suitable for use of service of equipment.

16 So this device disconnects the power between

17 the utility and the interconnected generation. It has

18 overcurrent protection. It's in an enclosure, and

19 it's listed as - for use as service equipment. It's

20 like the old saying - if it flies like a duck, it

21 walks like a duck, swims like a duck, and looks like a

22 duck, it's a duck. This is a service disconnecting

23 means.

24 I recommend the Association vote in favor of

25 this Certified Amending Motion. Thank you.



615



3 MICHAEL JOHNSTON: Sure. Thank you, Mr. Chair.

4 There were no apparent correlating issues or conflicts

5 that were identified by the NEC Correlating Committee.

6 And I would like to defer to the Chair of Code Panel

7 Four, Jim Rogers, at microphone two, for a technical

8 response, please.

9 JIM ROGERS: Jim Rogers, IEI, Chair of Code-

10 Making Panel 4. So I, I mostly want to talk about

11 what the Panel did. But it was very interesting,

12 watching the Back to the Future talk about the

13 National Electrical Code that I watched yesterday And

14 part of the rationale for that was looking at how we

15 deal with alternative energy systems, how we keep

16 moving forward with things like alternative energy

17 systems, and, and how does the NEC work in conjunction

18 with that.

19 Well, here's a perfect example, and why the

20 Panel was so adamant on not calling it one of the

21 service disconnects, as required in 230.70. If you

22 had an existing building that had a service, and you

23 were at the limit - let's say they were in - because

24 even under the new requirements, if they're in

25 separate enclosures, you could still have six



616

1 disconnects - so let's say you're at that limit. And

2 you use the permissive language that you find in 230,

3 to either have - use another set of service entrance

4 conductors, or you could have another service for our

5 alternative energy system to tie into. And if you did

6 that, and you called that a service disconnect along

7 with the other ones, then you could be forced to

8 replace the entire service on the building, which

9 could in essence, in some instances, make the

10 installation of an alternative energy system cost

11 prohibitive.

12 You've got to weigh safety, with the ability to

13 accomplish what you're trying to accomplish. And, and

14 that's one of the main concerns for calling that one

15 of the service disconnects in 230-70, because it -

16 there's other requirements in 705 for placarding, and,

17 and, and making sure you disconnect the, all of the

18 conductors at that interconnection point.

19 So the Panel was very adamant that they felt

20 they had covered safety, but they wanted to have - not

21 include that as one of the service disconnects, to

22 that they wouldn't be - so that the end user wouldn't

23 be forced in that instance to, like I say, change out

24 the entire service just because they wanted to add an

25 alternative energy system - without compromising



617

1 safety, like I said. Thank you.





6 please.

7 JASON FISHER: Thank you. Jason Fisher, again

8 representing SEIA, speaking against this motion. As

9 with the previous proposed motion, I again have

10 procedural concerns with regards to this motion, since

11 the 2019 Motions Committee Report shows different

12 language than that which is displayed on the screen,

13 and it's different than the original motion - because

14 according to that report, there was a, a effort to

15 strike an entire sentence, and now it - we have

16 something where we're just striking a single word.

17 So again, I, I have concerns, personal, that

18 this motion is out of order, but since it is there,

19 again, with my apologies, I have to speak against it.

20 This proposed motion presents some major

21 technical problems for users of the code. This motion

22 is to change language that the Technical Committee

23 deliberated for many hours, through both First and

24 Second Revision meetings, as well as in multiple Task

25 Group meetings. This was not language that was added



618

1 in the Second Revision. It started in the First

2 Revision, from many public inputs and comments.

3 It's also worth noting that this motion if

4 passed would impact any source interconnection that is

5 interconnected with the primary source. It's not just

6 solar, but it's any parallel connected source, such as

7 a energy storage system generator, etc. The language

8 as the Committee wrote it, that these are not service

9 disconnects is true, consistent with how the code has

10 been discussed, and taught for decades. If this

11 sentence was revised as the submitter's request, this

12 section would create a code conflict for many users of

13 the code, since it seems to indicate that other

14 sections that have been referred to would not apply.

15 So something that many folks in this room might

16 not know about, because it was all new, is because of

17 the hard work of my fellow Committee members, and

18 those on other committees such as CMP 13, concerns

19 over the ability to have indication of the presence

20 of, ready access to, and the control of on site power

21 sources has been addressed substantially in the 2020

22 Second Draft. Regardless of the type of on site power

23 source, there are now specific requirements for

24 identification of those sources, disconnection of

25 those sources, and ready access to those disconnects,



619

1 etc. This - I commend all the committees who worked

2 hard to look forward into the requirements that were

3 the new challenges that we're going to be faced with

4 the interconnection of all these new sources; and that

5 has been done in the relevant articles for those

6 sources.

7 So again, I'd ask the NFPA Membership to reject

8 this motion. It's better with it.

9 JAMES GOLINVEAUX: Thank you very much.


11 JOHN KOVACICH: Thank you, Mr. Chair. John

12 Kovacich, UL LLC, speaking on behalf of the Electrical

13 Section of NFPA as its official representative, and





18 of this body, I ask for your support in voting for

19 this motion. Thank you.

20 JAMES GOLINVEAUX: Thank you. And I'm going to

21 go in order of the microphone here. I'm going to go

22 back to four one more time.

23 LEO ZIEMAN: That's all right. If they want to

24 go ahead first, they can.

25 JAMES GOLINVEAUX: Microphone four.



620

1 LEO ZIEMAN: Oh, I'm sorry. Leo Zieman, with

2 Florida Power and Light, and Edison Electric

3 Institute, and also an alternative voting member for

4 Panel 4, and I speak in favor of this motion.

5 There were people that came up to these

6 microphones, both in for and against motions, and

7 other amendments. And they spoke about how electrons,

8 electricity doesn't care where it comes from, or where

9 it goes to. The direction if it doesn't matter. It's

10 gonna flow. So here we go - we have a point of

11 connection with a utility, and that is called a

12 disconnecting means. When you have that point there,

13 regardless of whether the premise is using load, or

14 it's actually generating back onto the grid. So

15 therefore, these disconnect means that we were talking

16 about, applies for both load and source.

17 Again, I will plead to the body to vote in

18 favor of this motion. Thank you.


20 MATT PACE: Thank you, Mr. Chair. My name is

21 Matt Pace, representing the IAFF. I'm also a primary

22 representative on Code Panel 4, and I'm speaking

23 against the measure.

24 I'm going to make two very brief, short

25 comments. The first one is that in very simple terms,



621

1 which is how I have to represent this to the Fire

2 Service - is that what this could do is roll ack

3 successes that we've had in trying to put disconnects

4 at a readily accessible location.

5 We have had great success in recently getting

6 the emergency disconnect for the utility on the

7 outside of one and two family homes. This could

8 eliminate the possibility of putting that disconnect

9 on the outside. That's going backwards.

10 The other comment that I'm going to make is

11 that on the Panel, this passed by a 17 to 1 vote. The

12 fact that we are even here discussing this almost

13 means why do we spend our time on code-making panels,

14 when one person can bring us to a vote of hundreds of

15 people that are not even involved the code-making

16 panel, and the hundreds of hours of discussions. I

17 urge you to vote no on this. Thank you.

18 JAMES GOLINVEAUX: Thank you. And standing in

19 order at the microphone - microphone two again.


21 Hartwell, speaking for myself, and speaking against

22 the motion.

23 In this case, I'm, I'm sorry - I disagree with

24 the motion's submitter on this one. I don't think

25 this quacks like a duck, swims like a duck, or does



622

1 anything else like a duck. I don't think it's a

2 service disconnect. It's not necessary to call it a

3 service disconnect, in order to meet the safety

4 objectives; and we are in Chapter 7 of the code. I

5 think that Panel 4 is well within its rights, and

6 within the, the commonly understood function of these,

7 to create this requirement.

8 As I said, I, I, I do have a serious technical

9 quibble with the outcome of the prior action that we

10 took - well, the - and which is why I changed my vote

11 on it from this Electrical Section until - to tonight.

12 But in this case, it's, it's not necessary to do that.

13 I think that we should support Panel 4 on this one.



16 TIM CROUSHORE: Thank you, Mr. Chairman. Tim

17 Croushore, representative of the electric utility

18 industry, as a consultant to the Edison Electric

19 Institute. Call your attention to the second to the

20 last sentence --

21 JAMES GOLINVEAUX: Are you speaking for or

22 against the motion, please?

23 TIM CROUSHORE: My apologies. Speaking for the

24 motion.




623

1 TIM CROUSHORE: Pay particular attention to the

2 second to the last sentence. You have service

3 conductors. You have service. This disconnect is

4 connected to the service conductors, with nothing in

5 between. This is a service disconnecting means.

6 Okay? By the definition that they're putting in the

7 next to the last sentence, that's exactly what this

8 is. So - and I appreciate Mr. Pace's requirements;

9 vehemently all through the process, we have been

10 against not calling this a service disconnecting

11 means. We have been trying to push all the

12 requirements of Part 6 of Article 230, which covers

13 Article 230-70, 71, 72, all the way through 86 - which

14 is the firefighter disconnect map.

15 So everything that you see is all included.

16 All we're saying is this is a service disconnecting

17 means. If you don't call this a service disconnecting

18 means, the firefighters can't deal with that section

19 in 230-86. So to have a single disconnecting means

20 for one and two family dwellings, this has to be

21 considered as a service disconnecting means. Thank

22 you.


24 further discussion on Motion 70-46 to Accept an

25 Identifiable Part of Public Comment 315? Mr.



624

1 Johnston, do you have any final comment?


3 Chair.


5 let we restate the motion. The motion on the floor is

6 to Accept an Identifiable Part of Public Comment No.








14 The results of the ballot is: 246 in favor of

15 the motion; 132 opposed to the motion. The motion has

16 passed.



19 please.


21 PEARL for Motion 70-47, Reject Second Revision 7517.



24 there a second?




625



3 HOWARD HERNDON: Quickly, we feel this is new

4 material, and we feel this is a broad brush, sweeping

5 requirement that is not necessary; and some of this

6 equipment is reconditionable.


8 would you like to offer the Panel's position.



11 of both public input and comments to ensure there was

12 no new material being introduced. The conclusion was

13 that no new material related to either the definition,

14 or the rules related to it, was introduced. There are

15 no apparent conflicts or correlation issues. I would

16 like to defer to the Chair of Code Panel 13, Linda

17 Little, at microphone three for some technical

18 response


20 Little. I'm the Chairman of Code Panel 3. I

21 represent IBEW, and I speak in opposition to the

22 motion. We - anybody on the panel had ample

23 opportunity to discuss this issue. Several

24 manufacturers are represented on the Panel. I ask you

25 to reject this - I - and support the Panel action.



626

1 Thank you.





6 please.



9 motion.

10 We support the action by the Code Panel to

11 include this language. Safety is the major reason to

12 adopt these changes. For the reasons already been

13 noted, these devices should not be reconditioned. I

14 urge you to vote against this motion.


16 please.


18 Domitrovich. I am with Eaton, and I'm speaking

19 against this position - or the motion on the table. I

20 think my little run back here gave me a - a - my

21 second breath.

22 These changes identify those devices that are

23 not designed, nor expected to be taken apart in the

24 field and put back together, should they reach a state

25 that they need to be restored to an operating



627

1 condition. If they no longer function, they cannot be

2 reconditioned, or refurbished. They should be

3 replaced. These are safety items.

4 We should continue to support the actions of

5 the Panels, and continue to reject these motions that

6 seek to remove the - the, the ability to - remove the,

7 the allowance of reconditioning this equipment. Thank

8 you.



11 Revision No. 7517? Mr. Johnston, do you have any

12 final comments?


14 Thank you.



17 to Reject Second Revision No. 7517. To vote, touch


19 the motion, and recommend the text on the screen,

20 touch 'One' - or touch 'Yes'. Let me reread that.

21 If you wish to vote in support of the motion,




25 vote. Sorry about that.



628



3 The results of the ballot are: 12 in favor of


5 failed.



8 please.



11 Accept Public Comment 501.



14 there a second?


16 JAMES GOLINVEAUX: I believe I got my second

17 there. Correct? Okay. We do have a second. Please


19 MARCELO HIRSCHLER: First of all, we're moving

20 into something completely different, nothing to do

21 with anything that we've been dealing with. We're

22 moving basically to fire testing to plenum cables.

23 This motion is intended to help in the

24 usability of the code for most users. We all know

25 that the requirements for wiring in ducts and plenums



629

1 is the same in Articles 725, 760, 770, 800, which now

2 becomes 805, 820, 830, and 40.

3 Therefore, using the same terms is what's most

4 helpful to the user, and will improve the usability of

5 the code.

6 Panel 3's responsible for Articles 725 and 760,

7 which are some of the articles dealing plenums and

8 ducts. Panel 16's responsible Article 770, and the -

9 all Articles in Chapter Eight, the remaining Articles

10 deal with plenums and ducts.

11 Many years ago, Standards Council stated that

12 NFPA 90A was the committee with jurisdiction over

13 requirements for materials, including wires and cables

14 in ducts and plenums, and that the NEC has to be

15 consistent with 90A. I'm a member of 90 - of course,

16 I'm not speaking for the Committee.

17 Article 770 and 800 from Chapter Eight, where

18 800 combined, combined the previous 800, now 805, 820,

19 830, 840, have tables in Section 154, with the same

20 information as the, as the table that we're

21 discussing. The discrepancies in the lines addressing

22 exposed to the airflow, instead of noting the actual

23 location - fabricated ducts or plenums, which in the

24 NEC we call spaces used for environmental air.

25 Article 725 and 760 talk about exposed to the



630

1 air flow, instead of stating the actual location, like

2 every other line in the table, and like the tables in

3 other relevant (unintelligible) tables. You can't see

4 on the screen, but if you look at the Agenda, you can

5 see it.

6 This is an inconsistency. It means the user

7 may be confused as to whether tables in the various

8 articles mean the same. Cables are exposed to air

9 flow in all other locations, including risers, trays,

10 shaft, and so on. NFPA 90A, which is where we should

11 really look for, does not use the term exposed to the

12 air flow, other than when dealing with removal of

13 abandoned cable; does not use the phrase for

14 (unintelligible) for cable fire test requirements.

15 You will hear that this is not - it is not

16 essential that terms in 735 and 60 be aligned with the

17 Articles from Ballot 16. It's true. But having

18 alignment is helpful to the user, and not alignment is

19 not helpful. You will hear the terms fabricated

20 ducts, and other space (unintelligible) air, already

21 in the first (unintelligible) column. But the issue

22 is that the language should be consistent within

23 articles. Column in the table talk about where the

24 cables are.

25 There is no argument, adding consistency will



631

1 create more usability to the code, and not cause any

2 problem. It is important that we make the code more

3 user friendly. Thank you.





8 the Correlating Committee, and I'd like to defer to

9 the Chair of Code Panel 3, Robert Jones, at microphone

10 three, please.

11 ROBERT JONES: Thank you, Mr. Chairman. My

12 name is Robert Jones. I represent Independent

13 Electrical Contractors. I am Chairman of Panel 3.

14 And on behalf of Panel 3, I am speaking against this

15 motion.

16 Public Comment 501 was rejected by Panel 3

17 because the phrase 'exposed to air flow' is

18 explanatory, as well as descriptive. The definition

19 is not necessary to understand that cables installed

20 in fabricated ducts will be exposed to air flow.

21 I ask all voting members to vote against this,

22 this motion, in support of Panel 3.

23 JAMES GOLINVEAUX: Thank you. With that, we

24 will open up the debate on the motion. Please provide

25 your name, affiliation, and whether you are speaking



632

1 in support, or against the motion. Microphone five,

2 please.

3 GEORGE STRANIERO: George Straniero, AFC Cable

4 Systems, speaking in favor of the motion; member of

5 Panel 398 but speaking on the behalf of myself.

6 If you look at all the application tables in

7 725, 760, 770 and 800, they're - they're all

8 consistent, in terms of the application and the

9 headings. Exposed to the air flow that was put in for

10 725 and 760 is out of context with the other

11 application tables, and out of context with the

12 applications stated in those tables themselves. And

13 those tables, it's - the applications are listed as -

14 in a raceway, in a fireproof shaft, in a cable tray.

15 The application that's being described is actually in

16 a fabricated duct, and that's the language that should

17 be included in the table - not exposed to airflow.

18 Thank you.


20 please.


22 International for NAFRA, and in support.

23 Again, the - you did not hear from the Chairman

24 of the, of the Panel, anything that is wrong with

25 making the change to improve the usability of the



633

1 code. You just heard that the Committee didn't like

2 it, but for no apparent reason. The - that - you

3 heard from George Straniero that consistency is to

4 make the change, please. Thank you.




8 comment?


10 Thank you.











21 The results are 192 in favor of the motion; 123

22 against the motion. The motion has passed.



25 please.



634


2 International, speaking for NAFRA, and in support of

3 the motion.

4 This is identical to what (unintelligible)

5 JAMES GOLINVEAUX: I'm sorry, Marcelo. You

6 have to make the motion first.

7 MARCELO HIRSCHLER: Excuse me. I move - Accept

8 Public Comment 500. I apologize.

9 JAMES GOLINVEAUX: I can't pick on you. My

10 daughter would kill me.

11 (laughter)

12 JAMES GOLINVEAUX: So there is a motion on the

13 floor to Accept Public Comment No. 500. Is there a

14 second?




18 MARCELO HIRSCHLER: I apologize one more time.

19 Marcelo Hirschler, GBH International, speaking for

20 NAFRA, in support of the motion.

21 This motion is identical to the one we just

22 voted on. This is on Article 60. The other one was

23 Article 725. No other difference. Thank you.





635

1 MICHAEL JOHNSTON: Thank you, Mr. Chair. No

2 correlating issues or conflicts were identified by the

3 Correlating Committee. And I'd like to defer to the

4 Chair of Code Panel 3, Robert Jones, at microphone


6 ROBERT JONES: Thank you, Mr. Chairman. My

7 name is Robert Jones. I'm representing Independent

8 Electrical Contractors. I am Chairman of Panel 3.

9 And I speak on behalf of Panel 3, in opposition to

10 this, this motion.

11 But I also agree this is the same as the

12 previous motion. The Panel acted the same way, with

13 the same Panel Statement.




17 support of, or against the motion. Microphone five,

18 please.

19 GEORGE STRANIERO: George Straniero, ARC Cable

20 Systems, speaking in support. My same comments I

21 mentioned previously apply here, as well. Thanks.


23 further discussion on Motion 70-49 to Accept a Public

24 Comment No. 500? Microphone five.

25 DYAN ALECUMEN (phonetic): Dyan Alecumen,



636

1 speaking in favor of the motion. I just wanted to

2 bring to the attention that the number on the board up

3 there says 725, and we're discussing 760.


5 MARCELO HIRSCHLER: Mr. Chairman, yeah - it, it

6 should state 760 on all four --

7 JAMES GOLINVEAUX: You are correct.

8 MARCELO HIRSCHLER: -- screens.

9 JAMES GOLINVEAUX: You are correct. Okay?

10 Noted. Is there any further discussion on Motion 70-

11 49 to Accept a - Public Comment No. 500? Mr.

12 Johnston, any final comment?

13 MICHAEL JOHNSTON: No further comments, Mr.

14 Chair. Thank you.














637

1 90 against the motion. Therefore, the motion has

2 passed.



5 please.


7 with Serra Wire. Id make a - like to make a Motion to

8 Reject Section Revision 7509.







15 CHRIS HUNTER: Thank you. I'm Chris Hunter,

16 with Serra Wire, in support of the motion.

17 Like in earlier motions, this language appeared

18 in the Second Draft. It was not based on any similar

19 language, or requirement that was considered in the

20 First Draft.

21 Communications equipment is frequently

22 reconditioned, and a new label is added. However,

23 this requirement would require the removal of the

24 original listing mark, which is unnecessary, and may

25 result to damage to the equipment. Thank you.



638



3 MICHAEL JOHNSTON: Thank you, Mr. Chair. Since

4 the new material issue was brought up again, the same

5 statement is in order.

6 The NEC Correlating Committee did review the

7 complete record of public comments and inputs to

8 ensure that no new material was being introduced.

9 Nothing was identified; no holds were place. The

10 Correlating Committee concluded that there was no new

11 material related to either the definition of

12 reconditioned, or any new rules related to it. There

13 were no apparent conflicts or correlation issue. I'd

14 like to defer to the Chair of Code Panel 16, Thomas

15 Moore. He's at microphone three, please.

16 TOM MOORE: Thank you, Mr. Chairman. My name

17 is Tom Moore, representing the International

18 Association of Electrical Inspectors, as Chair of CMP

19 16, speaking in opposition of the motion on the floor.

20 CMP 16 acted on Global Public Comment 979,

21 thereby creating Second Revision 7509. CMP 16

22 reviewed, and affirmed with the Correlating Committee

23 that this was not new material.

24 As indicated in the Panel's Committee

25 Statement, there are certain types of communication



639

1 equipment covered in Chapter 8 that may be

2 reconditioned. Furthermore, during the discussions,

3 it is clear that reconditioning of certain types of

4 communications equipment has been performed under

5 recognized product standards for many years. By

6 virtue of NEC 90.3, Chapter 8 is a standalone chapter,

7 and 110.21(A)(2) would not be applicable if not

8 referenced in new 800.3(G), other articles. Thank

9 you.




13 support, and/or against the motion. Microphone three.

14 THOMAS DOMITROVICH: Thomas Domitrovich with

15 Eaton. I continue to speak against the motion that's

16 on the floor. I would ask everyone else to do the

17 same. Thank you.

18 JAMES GOLINVEAUX: Okay. Thank you. I'm not

19 seeing anyone at a microphone. Is there any further

20 discussion of Motion 70-50 to Reject a Second Revision

21 7509? Mr. Johnston, do you have any final comment?


23 comments, Mr. Chair. Thank you.





640

1 to Reject Second Revision 7509. To vote, touch the





6 record your vote.




10 the motion: 337 against the motion. The motion has

11 failed.



14 please.


16 International for NAFRA, and I move to Accept Public

17 Comment No. 516, please.

18 JAMES GOLINVEAUX: Thank you. There, there is

19 a motion on the floor to Accept Public Comment No.





24 MARCELO HIRSCHLER: Thank you. Marcelo

25 Hirschler, GBH International, speaking for NAFRA, and



641

1 in support of the motion.

2 This is a very simple motion. I don't know if

3 it was because of the, of the Panel, or because of

4 staff or whatever. The date of the ASTM E84 Standard

5 was not updated to (unintelligible) in the comment.

6 So all this is doing is just simply update the date of

7 the ASTM E84 Standard to the one that was at the time

8 that the comment was submitted. Thank you.


10 would you like to state the Panel's position, please.

11 MICHAEL JOHNSTON: Thank you, Mr. Chair. No

12 correlation issues or conflicts were identified by the

13 NEC Correlating Committee. And I would defer to the

14 Chair of Code Panel 16, Thomas Moore, for an

15 additional response.

16 TOM MOORE: Thank you, Mr. Chairman. My name's

17 Tom Moore, representing the International Association

18 of Electric Inspectors, a Chair of CMP 16, speaking in

19 favor of the motion on the floor.

20 It gets a little bit confusing, but First

21 Revision 8014 was created at the First Draft meeting

22 by updating ASTM E8(4), 15(A) to 17(A), and

23 Informational Note No. 1 to 800.182(A).

24 Additionally, during the First Draft Meeting,

25 Article 800 became General Requirements to



642

1 Communication Systems, and the existing Article 800

2 Communication Circuits become new Article 805.

3 During the Second Draft meeting, CMP 16 took

4 action based on Public Comment 516, also by the

5 submitter of this related NITMAM, to update ASTM E84

6 17(A) to 18(A), and 805.182(A), Information Note One.

7 Second Revision 7746 encompassed said revision

8 along with relocating all of Article 805-182 to the

9 General Requirements Article under 800-182.

10 As part of the relocation, the updated

11 reference did not appear in the Second Draft Report.

12 As indicated in the actions taken, it was the intent

13 of CMP 16 that Information Note Number One to 182,

14 800-182(A) reference ASTM E18(A).


16 open up the debate on this motion. Please provide

17 your name, affiliation, whether you are speaking in


19 please.

20 JOHN KOVACHIC: Thank you, Mr. Chair. John



23 speaking for the motion. The Electrical Section had

24 its business meeting on Tuesday of this week, and the

25 Section voted to support this motion.



643

1 I ask the members of this body to vote in favor

2 of this motion. Thank you.


4 further discussion on Motion 70-51 to Accept a Public


6 comments?


8 Chair. Thank you.







15 recommend the text on Screen Two, text - touch 'No'.




19 The results of the motion is 328 in favor of


21 passed.

22 And before I read the last ballot, I know there

23 may be a reaction from you. So I'm going to have a

24 few more things to tell you what to do with your iPad,

25 and how to turn it in. So please, let, let's get



644

1 through the motion, then just bear with me for two

2 minutes, I promise. I just need to give you some

3 direction before you head towards the back of the

4 room.

5 So now let's proceed with the discussion of

6 Certified Amending Motion 70-52. Microphone five?

7 JIM WIESE: Yes, Sir.


9 JIM WIESE: Yes, Sir. Good evening. My name

10 is Jim Wiese with ADTRAN, Incorporated. I'm here to

11 make a Motion to Accept Public Comment 2147.


13 motion on the floor to Accept an Identifiable Part of

14 Public Comment 2147. Is there a second?




18 JIM WIESE: My name is Jim Wiese with ADTRAN,

19 and I'm requesting support to accept this minor

20 clarification, so that there is not multiple,

21 conflicting interpretations.

22 This clarification is only intended to reduce

23 interpretative confusion. It is extremely important

24 to convey that there's no request to change anything

25 technically from the status quo that has been in place



645

1 as long as Chapter 8 has existed, and for well over a

2 hundred years of telecommunication service deployment

3 and practices.

4 I would like to note that this proposal is

5 identical to PC 128 from Bill McCoy, who I worked

6 with, along with representatives from Telcordia, AT&T,

7 Verizon, Century Link, Addis, and IEEE TSTC Committee.

8 Unfortunately, the rejection of the public comments on

9 this subject was based on the belief that service

10 providers were asking to do something new with utility

11 outside plant entrance cables. However, that was

12 never the issue. What we really were trying to

13 clarify is that no technical change was actually made

14 in the First Revision. The stated rationale for

15 adding listed in accordance with 805-179 was for a

16 totally different reason of reinforcing the existing

17 listing requirements on premises communications

18 cables, particularly on listed land cables - not

19 removing communications powering on entrance cables,

20 as that was not the purpose.

21 The common and historical accurate

22 interpretation of this has no problem, as 805, 804-48,

23 utility entrance cables are not required to be listed

24 up to 50 feet into the building. They are exempted

25 from the 805-179 listing requirements. So the



646

1 sentence in 841-60 is not even applicable to those

2 cables that are in 841 - 4 - 548.

3 However, another valid but unintended

4 interpretation was raised, and resulted in the public

5 comment. That interpretation is that the code for the

6 first time is removing, for some unknown reason, the

7 ability of these cables to have powering aspect. But

8 this only applies if the signals are broadband and the

9 electrons flow from the customer's listed device,

10 rather than from the network. However, this would be

11 inconsistent with precedent, and other articles in

12 800.

13 Even if the motion fails, the service providers

14 will just continue to use the first interpretation as

15 the historical precedent, and a legitimate

16 interpretation. The proposal just eliminates

17 potential confusion and difficulties for the service

18 providers and AHJ. Putting all else aside, from a

19 practical standpoint, there's no way an AHJ is going

20 to figure out if a - if 200 pair, unlisted 840.48

21 utilities outside by (unintelligible) cable has pairs

22 with powering communications circuits, and then

23 determine which way the electrons are flowing, and

24 then determine if the signal is broadband.

25 Accepting this proposal removes the unclarity -



647

1 no more, and no less. So I respectfully ask the

2 positive vote for this proposal, as it creates nothing

3 new, in no way changes anything in terms of electrical

4 safety, provides clarification, reduces confusion, and

5 as a result improves the usability and consistent

6 application of the code.

7 JAMES GOLINVEAUX: Thank you. Your time has

8 expired, but thank you. Mr. Johnston, do you have any

9 comments from the Panel?



12 the Correlating Committee, and I'd like to defer to

13 the Chair of Code Panel 16, Tom Moore, and I believe

14 he's at microphone three, please.

15 TOM MOORE: Thank you. My name is Tom Moore.

16 I represent the International Association of

17 Electrical Inspectors, as Chair of CMP 16. We're

18 speaking in opposition of the motion on the floor.

19 During the Second Draft meeting, CMP 16 heard

20 two public comments - 128 and 169, recommending that

21 the phrase, covered in 800 - 840.48, and those. CMP

22 16 rejected both of the public comments, as the use of

23 unlisted outside plant cables for providing power is a

24 new concept to 840.160, and had no benefit - or no

25 benefit of public review.



648

1 This language may be in other Chapter 8

2 articles, but it is new material for 840.160. Thank

3 you.


5 open the debate on the motion. Please provide your


7 support of, or against the motion. Microphone five,

8 please.

9 JOEL GORGAN (phonetic): My name is Joel

10 Gorgan, and I'm a Fellow with Cisco Systems. I speak

11 in favor of this motion.

12 The 840.48 reference to unlisted outside plant

13 cable has been in place since broadband copper was

14 added in this section definition. This was and is

15 accepted practice. Outside plant wiring has different

16 requirements for extreme outdoor use than, than inside

17 listed wiring does.

18 And I feel to see in the change of this

19 sectional draft, because the, the sections were, were

20 renumbered, so it was really difficult to follow and

21 add additional comment. There's a huge insulation

22 base, without any known issues recorded. And I'd like

23 to reiterate that. There is a huge insulation base

24 without any known issues recorded. There's no reason

25 to burden installers and owners to change this. The



649

1 common interpretation is that 840.160, listed in

2 accordance with the 805.179, does not apply at all to

3 entrance cables, as they are not listed, in accordance

4 with 805.179, and thus exempt 804 - can't talk -

5 805.48.

6 So again, understanding all of this, and

7 looking at all this information, please support this



10 please.






16 on Tuesday of this week, and at that meeting, the

17 Section voted not - not to support this motion. I ask

18 the members of this body to vote against the motion on



21 please.

22 ERNIE GALLO (phonetic): Hello. My name is

23 Ernie Gallo. I sit on the National Electrical Code

24 Correlating Code, Code-Making Panels 1, 5, and I also

25 sit on the National Electrical Safety Code, although



650

1 I'm not here representing those groups. I am

2 representing the Alliance of Telecommunications

3 Solutions, and I support the motion.

4 The revision proposed will assist --

5 JAMES GOLINVEAUX: Excuse me. Are you speaking

6 in --

7 ERNIE GALLO: I am - I support the motion.


9 ERNIE GALLO: The, the revision will assist in

10 correlation, clarity, and usability of the code.

11 There's a hundred year history to support this CAM.

12 The original customer premise power was a hand cranked

13 phone, way back in the 1800s, with a magneto. So the

14 customer premise power is nothing new. I remember

15 when the electric power in my house went out when I

16 was a child, the phone would still work because there

17 was network power. So there's been power over those

18 cables, the, the drop cables that, that we're talking

19 about here. And electrons really don't worry which

20 way they flow.

21 The cables in question are drop cables that

22 come from either a pole, or aerial, or buried cables.

23 They are 300 volts. They have a, a fuse link on them.

24 So there's many safety brought into them. The signal

25 and power over these cables are what they call SELV,



651

1 or extra safety low voltage. So they're basically

2 touch safe, with very low voltage and current levels.

3 The cables are also covered the National Electrical

4 Safety Code. So there's a lot of things looking at

5 these cables.

6 The terminal equipment is listed by a

7 nationally recognized test lab. The terminal

8 equipment historically has also been covered by FCC

9 Part 68, as a result of the Carterfone Decision. And

10 what that was - at one time, you could only get your

11 telephones and other equipment from Ma Bell. The FCC

12 said that other people can connect their equipment, as

13 long as they meet certain criteria, and the criteria

14 was that the terminal equipment not cause harm to the

15 network. So terminal equipment is regulated, as well.

16 There have been no safety issues raised, no

17 documentation, no report to indicate any safety issues

18 that would not support this motion. Acceptance of

19 this motion will assist in bringing high speed,

20 broadband services to underserved areas in the United

21 States, which is very important. Thank you. Please

22 support this motion.


24 please.

25 KURT SEELIGER: Thank you. I'd like to



652

1 officially welcome everyone to Friday morning.

2 (laughter)

3 KURT SEELIGER: I am --

4 JAMES GOLINVEAUX: I'd rather have your name,

5 and your motion, or your statement on it, please.

6 (laughter)

7 KURT SEELIGER: Yeah. I'm Kurt Seeliger of

8 AT&T, representing AT&T, speaking in support of the

9 motion.


11 KURT SEELIGER: Communications power has been

12 safely sourced from premises over unlisted cables for

13 decades by communications utilities. Examples include

14 off premise extensions, and T carrier systems, where

15 the requirements of 2017 NEC Section 800.48 and 840.48

16 are followed. Please vote in favor of the motion.

17 Thank you.

18 JAMES GOLINVEAUX: Thank you. I'm going to -

19 I'm going to go one more time at microphone five,

20 because you had a - you had a line of about four

21 people, and then I'll come over to you.

22 GEORGE ZIMMERMAN: Thank you. I'm George

23 Zimmerman with CME Consulting, and I'm speaking in

24 favor of the motion. I'm a member of Code-Making

25 Panel 3, and a Technical Committee Chair for the



653

1 Ethernet Alliance, but I'm speaking for myself.

2 Many of the points have already been made, so

3 I, I'm going to be very, very brief. I don't really

4 have a dog in this fight, but I do not want someone

5 else's dog to become roadkill because of things I'm

6 interested in.

7 The genesis of this listed language in 841.60

8 came out of the POE Task Group after the 2017 code was

9 put together. We put it in there because we were

10 thinking about unlisted land cables. We forgot about

11 the unlisted cables that come in from the service

12 provider. As you have heard, and actually as my

13 personal experience has been, these are not new in

14 carrying power. The confusion that's been generated

15 by the new language there makes one think that power

16 isn't allowed over those cables. And this CAM simply

17 seeks to correct that confusion.

18 I, I urge you to support this CAM, as well as,

19 in this case, it's supporting the really good work

20 that the Panel did to clean up 841.60, and prevent

21 this unintended consequence from causing confusion and

22 tarnishing that.

23 JAMES GOLINVEAUX: Thank you. Microphone five.

24 STANLEY COPPIN (phonetic): This is six.

25 UNIDENTIFIED SPEAKER: Oh, I'm - I thought you



654

1 were taking a negative.

2 JAMES GOLINVEAUX: I - They've been standing

3 there, for - you just walked up.

4 STANLEY COPPIN: I'm taking a negative. I'm at

5 six.

6 JAMES GOLINVEAUX: I called five.


8 JAMES GOLINVEAUX: Microphone five.

9 JOEL GORGAN: Mr. Chairman, I'm Joel Gorgan

10 with Cisco Systems, and I speak again in favor of this

11 motion. I'd like to point out that there has been a

12 considerable amount of work that's done here. And as

13 Jim pointed out when he introduced the, the CAM, the

14 material isn't new. It's always been there. It was

15 added in two code cycles back in, in 840 -

16 unintentionally, intentionally, it doesn't matter;

17 it's in there.

18 And in terms of that reference, I'd just like

19 to point out that, that we've been powering over these

20 communication cables for some time. And again,

21 they're unlisted; they're coming in from the outside.

22 They're only coming in a little - as - by definition,

23 in 15 meters, right. And we've been doing this

24 successfully, as you heard from my past colleagues,

25 for a number of years. So again, I speak in favor of



655

1 the motion. Thank you.

2 JAMES GOLINVEAUX: Thank you. Now microphone

3 six, please.

4 STANLEY COPPIN: My name is Stanley Coppin.

5 I'm a member of Panel 16; have been for a long time.

6 I'm speaking in opposition to the motion.

7 I'd like to clarify that Article 840 is

8 premises powered broadband. It was first introduced

9 into the 2011 code. And why is it premises powered?

10 Because it had no power coming in on a cable. It was

11 an optical fiber cable, cables I'd like to call a no

12 voltage cable. But the next cycle, we stayed only

13 with optical fiber cable. And only in the last cycle,

14 broadened how the signals can come in. But the, the

15 whole concept is, the power is not coming in on the

16 cable. I'm not suggesting that they're wrong about

17 powering over cables, but they're in the wrong

18 article. This article does not bring in power on the

19 cable; it provides it on the premises.

20 In addition, the, the articles that have

21 traditionally, have provided power, have provided very

22 low power. Panel 16 has an Article 830, where they

23 provide for a higher level of network powering, and

24 frankly, the Panel requires a listed cable there. So

25 at some point of powering, we require a listed cable.



656


2 please.

3 BILL MCCOY: Yes. I'm Bill McCoy. I'm an

4 independent telecommunications consultant, and a

5 member of Panel 16. I speak in favor of this motion.

6 Mention was made that we should be using

7 Article 830. 830, if you look at the title and the

8 scope of it, it is network powered broadband

9 communications systems. That means the power is

10 coming from the network, rather than the premises.

11 Article 840 is power that could come from the

12 premises.

13 All this CAM is trying to do is provide

14 clarification on an established procedure for

15 installing outside plant communications cable. I'd

16 ask that you vote in favor of this motion.


18 further discussion on Motion 70-52 to Accept an

19 Identifiable Part of a Public Comment No. 2147? Mr.



22 Chair. Thank you.



25 to Accept an Identifiable Part of Public Comment No.



657






6 UNIDENTIFIED SPEAKER: (unintelligible) vote

7 (unintelligible).

8 UNIDENTIFIED SPEAKER: It's not working.

9 UNIDENTIFIED SPEAKER: It's not registering.



12 UNIDENTIFIED SPEAKER: It doesn't work.


14 JAMES GOLINVEAUX: It expired at midnight.

15 (laughter)

16 JAMES GOLINVEAUX: Hang on.


18 JAMES GOLINVEAUX: What?


20 JAMES GOLINVEAUX: All right. Let's just - let

21 - I'm going to do a hand vote.


23 JAMES GOLINVEAUX: So I have a feeling I know

24 where this is going to go. So if you are in favor of

25 the motion - and I'll restate the motion, since I'm



658

1 going to do a hand vote.

2 The motion before you is to Accept an

3 Identifiable Part of the Public Comment No. 2147. And

4 if you are in favor of that motion, please raise your

5 hand.

6 UNIDENTIFIED SPEAKER: (unintelligible) should

7 stand.

8 JAMES GOLINVEAUX: If you are opposed to that

9 motion, please raise your hand. Oh, God.

10 (laughter)

11 JAMES GOLINVEAUX: I think it - it think it's

12 opposed, but I've got to get a count. Sorry.


14 JAMES GOLINVEAUX: It's, it's, it's not as

15 clean --

16 (laughter)

17 JAMES GOLINVEAUX: Ya let me down.

18 (laughter)


20 JAMES GOLINVEAUX: You want to do it as a --


22 UNIDENTIFIED SPEAKER: Yeah, (unintelligible).

23 JAMES GOLINVEAUX: Okay. We're going to try

24 Round Two. We're going to pretend this is a call the

25 question, and see if this works.



659

1 So we're going to change the application of the

2 motion to the call the question on your iPad. So if

3 you scroll down to the bottom - if you want to vote in

4 favor of the motion, which would be Screen One for the

5 call the question vote, I want you to touch 'Yes'. If

6 you want to oppose the motion, which would be Screen

7 Two, I want you to touch 'No'. Please record your

8 vote.


10 JAMES GOLINVEAUX: Voting will close in five

11 seconds. This is working.

12 (laughter)

13 JAMES GOLINVEAUX: The voting is closed.

14 (applause)

15 UNIDENTIFIED SPEAKER: Woo-hoo.

16 JAMES GOLINVEAUX: The results of - the results

17 of the motion is that 100 were in favor if the motion;

18 21 to - of Motion 70-52; 233 against. The motion has

19 failed.


21 Seeing none, we will move on. Thank you, Mr.

22 Johnston.

23 (applause)

24 JAMES GOLINVEAUX: Before I close, if you can

25 pull out your voting tablet. To log out, I'm going to



660

1 give you some instructions. It's going to save us a

2 whole bunch of time in getting you out of this hall.

3 To log out of the iPads, press the On-Off icon

4 near the name at the top left. The Log-Off prompt

5 should appear. In the Log-Off code, enter 1218. I'll

6 repeat it. In the Log-Off code, enter 1218, then

7 press Log-Off. Good.


9 (laughter)

10 UNIDENTIFIED SPEAKER: Yeah, really

11 (unintelligible)

12 JAMES GOLINVEAUX: This officially concludes

13 the 2019 NFPA Technical Meeting. I want to thank you

14 for your participation, interest and support. I now

15 declare the 2019 Technical Meeting officially

16 adjourned.

17 (applause)

18 (MUSIC)

19 (END OF MEETING)

20

21

22

23

24

25





Page 1

AABA 473:13abandoned 630:13abandoning 579:8abbreviation 508:24abbreviations 506:7507:4

Abernathy 10:21 509:16509:17 510:5

abide 459:21ability 57:25 59:3 186:3242:2 488:17 529:18616:12 618:19 627:6646:7 661:7

able 48:9 139:18 140:9152:8 156:4 186:10200:13 204:4 226:10285:13 286:13 319:21377:15 384:4 387:21387:23 429:9,10463:18 514:25 533:15542:2 570:6 580:2,12614:6

aboard 88:22absence 32:1 517:9529:9

absent 448:14absolute 64:5 121:21122:13 123:2 124:14

absolutely 57:5 68:1091:3 196:25 197:2236:22 336:19 448:11458:18,23 463:13,19561:6

absten-- 63:5abstention 62:6,9,12,1763:4,7 72:15,21

abuse 247:17AC 248:7 375:3 558:13558:15 575:15 577:2,4

AC/60 259:19accelerated 441:10accelerating 151:18accept 37:19,21 40:8,1040:11 44:25 45:2,4,652:14,22 53:13 66:2166:25 70:6,13 72:1876:8 81:1 82:13 84:986:9,12 91:18,2392:15,18 94:20 95:195:17,20 97:10,1798:10,12 99:10,16100:8,10 101:7,12102:3,6 103:3,8,24104:2,22 105:19 106:7108:13,15,17,18 117:7117:8,17,18 133:24134:1 135:2 137:22138:3 170:9 178:1,3211:15 212:12,16225:19 226:19 231:5,8233:16 239:15 240:11241:18 254:23 255:1262:25 263:5 277:7,8285:10 305:16 379:22379:25 399:24 431:3,3431:6,15 438:25 439:6439:22,25 450:2,19

451:1 452:20,24 454:3454:6 456:6,7,8,10457:16 458:6,9,9461:13 463:22 464:4465:11,14 468:11471:20 473:6 475:22476:15,18 478:9 479:9479:16 481:10,13484:25 492:17 493:3,9504:18,20 510:19511:5 529:24 549:2560:15 567:7,13,17573:3 575:4,7 583:20603:25 612:11,14623:24 624:6 628:11628:13 633:6,13 634:7634:13 635:23 636:11636:17 640:16,19643:4,11 644:11,13,19656:18,25 658:2

acceptable 123:9 140:10143:4 219:16 261:1336:18 342:11 529:3

acceptably 286:12acceptance 69:15,23283:10 651:18

accepted 109:4 121:23123:15,20 140:23160:9 275:16 277:6,8277:9 318:15 319:8,12422:12 473:5 498:3528:13 529:1 648:15

accepting 142:24 149:25173:5 175:2 472:17646:25

Accepts 254:24access 133:11 140:3173:25 343:13,16,19348:8 350:1 432:22532:1 618:20,25

accessed 89:21accessibility 387:12,18388:1,6,9

accessible 578:20 614:8621:4

accident 214:15 445:13accidental 161:15 446:8446:11

accidentally 377:4accidents 165:5 281:17359:24

accommodate 42:12181:22

accomplish 219:8 610:5611:7 616:13,13

accomplished 278:5account 204:3accountable 149:23accumulation 200:13accuracy 383:5accurate 236:17 237:3239:6 267:5 645:21

accurately 111:12319:21

achievable 23:2 343:24achieve 52:2,10 509:23achieved 141:10Achievement 21:7,8

23:7,9,11 25:7,10achieving 123:18acid 181:5 182:24190:18 196:21 207:15213:10,18,21,25 214:7214:9,19 215:21 217:7217:17 218:10,12,21218:25 219:4,6,13222:14,23 224:10225:2,5,14 244:24245:8 257:1 262:11275:3,23 282:8 288:14288:22

ack 621:2acknowledge 31:25255:10 256:5 264:9443:19

acknowledged 123:21129:21 189:15 383:2

acknowledges 315:17acknowledging 189:13acoustical 90:23,25acronym 562:17act 232:13 470:16acted 15:10 63:23 277:3298:21 415:14 635:12638:20

acting 300:4 550:7551:12

action 15:9,13 19:858:15 67:21 121:8123:21 145:23,23179:21 193:15 195:12259:14,16 276:7 297:1316:2 326:7 329:5,20330:2 343:12 410:16410:17 425:19 495:7502:19 524:21 531:16568:21 585:19 587:23591:2 592:12 595:17622:9 625:25 626:10642:4 661:10

actionable 284:6actions 15:20 36:17 59:4111:23 112:22 256:6297:19 317:24 327:9404:24 435:1 531:11570:11 578:13 595:11598:6 627:4 642:12

activate 258:23active 21:17 23:16,18276:6

actively 24:1 391:11activity 203:23 326:4392:7 552:22 562:24

acts 52:6actual 19:8 39:4 128:9136:22 163:5 214:22324:2 344:23 541:9568:18 629:22 630:1

AD067FA 1:22adamant 615:20 616:19adamantly 195:1add 61:14 67:8 68:4 88:991:15 96:7,20 104:10116:2 137:4 160:7207:24 213:8 217:15222:12 232:24 275:25

284:1,1,1,21 297:1,8306:21 307:18 337:6344:10 352:5 398:14430:8 434:14 459:13459:18 463:25 467:19467:23 469:3,12496:18 500:25 502:5519:23 559:1 616:24648:21

added 45:21,22 46:1,1754:1 67:7 68:13 69:2382:19 113:16 134:16135:6 140:20 141:2196:16 207:23 234:15245:14 265:19,21,22270:14 297:14 323:17327:1 343:4 408:19,21432:2 434:10,23467:25 470:4 485:20536:3 569:5 578:22617:25 637:22 648:14654:15

adding 100:21 111:9135:8 139:7,19 142:5233:7,10 239:21266:21,23 284:17434:13 460:11 468:19468:21 470:1 479:3485:18 514:22 630:25645:15

Addis 645:7Addison 146:9addition 24:7,24 152:6161:15 162:7 193:23246:13 275:4 326:24415:20 443:23 447:2528:20 530:25 534:4543:1,18 561:8 614:2655:20

additional 69:11 88:4,688:25 111:10 129:1,23130:14 131:16 135:1136:8 141:3,14 150:6155:21 216:16 217:15237:1,2 246:19 279:2284:1 285:12 315:7338:16 343:13 360:3381:17 398:14 432:3432:16 433:11 443:24445:11 467:20 471:12483:6 528:24 531:20553:4 557:5 568:4611:14 639:22 641:15648:21

additionally 14:1 22:2026:16 27:15 42:10140:23 141:2 151:4179:24 243:25 641:24

address 17:17 20:2223:21 24:9 89:15150:15 166:13 187:23213:15 215:25 216:20218:21,24 219:21221:12,15 232:5233:12 234:8 235:6237:2 238:12 257:3,19275:2,10 276:23280:15 281:19 286:9

311:19 326:4 342:12348:21 365:10 398:8422:9 443:1,16 490:10491:19 547:25 557:24558:9,22 559:3 577:1577:13 586:9 605:11

addressed 54:21 59:1959:22 61:2,3,5 64:25162:3 174:6 224:6225:8 231:24 232:4237:21 239:12 258:3,7264:10 275:5,14,18280:13 287:12 310:19333:4 334:12 354:11384:9 422:15 468:24469:3 484:5 497:2533:13 558:6 569:15569:16 576:24 618:21

addresses 68:21 112:15231:22 232:3 233:7238:14,16 244:16258:19 287:8 438:7446:13 455:10

addressing 179:12191:19 235:16 310:12327:9,21 358:11 434:6540:13 629:21

adds 48:23 82:19 197:13231:18 233:17 248:15284:4 366:13 605:17

adequate 64:3 135:23148:12 167:4 187:22190:15 278:18 289:4301:8 366:5 415:3434:6

adequately 221:11252:14 275:18 288:15568:1

adjourned 660:16adjournment 15:21 16:236:19 37:2

adjustable 408:3adjustments 258:10Administration 87:10267:20 562:18 563:17564:1 571:22

Administrations 557:18admire 377:10admit 285:20 478:23543:11

admitting 214:20adopt 68:17 83:6,9 140:9212:12 316:4 552:17568:20 587:25 592:14595:19 626:12

adoptability 209:8adoptable 83:23adopted 68:14 83:2122:22 136:10 140:3153:15 178:25 180:11219:25 286:19 318:19357:22 364:3 441:25445:22 569:19

adopting 215:1 276:8286:23 490:15

adoption 45:24 129:18145:9 208:21 209:2226:15 288:11 393:6



Page 2

568:21adoptions 357:7 392:13ADTRAN 644:10,18adult 560:3advance 19:15advanced 21:10 225:13advancement 343:20,23advances 148:16 257:6384:15

advancing 21:2,4adversely 55:10 60:3advertised 389:21advisable 487:18advisory 116:10 483:12advocacy 393:5advocate 21:19aerial 650:22AFC 488:10 527:25528:11 532:21 535:5632:3

AFCI 380:8,13,22 383:9383:10,13 384:6,7,10384:20 385:3,10,13386:4,4,21 389:12390:15 391:25 393:3395:18 397:3,14,25

AFCI/GFCI 385:8AFCIs 335:1 382:16,25386:1 392:18 393:18394:19 396:5 403:7

Affairs 33:10affect 55:11 60:4 183:13215:23 398:16 465:2

affiliation 17:13,16 47:356:12 68:25 80:883:13 90:14 93:2197:2 99:7 101:4 103:1104:19 111:18 112:25113:1 124:4 130:1136:16 140:14 151:9162:15 172:4 216:24234:23 241:10 244:5259:24 268:19 274:9278:10 294:24 306:8308:24 323:12 327:25344:3 356:11 365:21374:4 382:3 402:23416:16 423:9 426:16430:5 435:4 444:4452:9 455:23 460:1468:6 484:19 500:3503:4 508:9 513:20524:5 532:7 539:21551:2 560:25 570:25579:14 586:1 591:10595:3 604:10 617:4626:4 631:25 635:16639:12 642:17 648:6

affirmative 65:2 297:16343:21 550:24

affirmed 431:18 434:3638:22

affirming 298:5affordable 202:11364:11

afforded 18:10aft 89:22afternoon 174:19 199:23

294:12 299:3 401:10AGA 440:6AGA's 440:9again.' 427:2aged 344:25agencies 547:15agency 205:1 213:24557:20

agenda 14:8,10 17:419:5 42:6,7,15 43:965:19 66:4,8,14 85:11107:14 120:4 128:1130:17 132:25 134:11144:17 145:15 146:14158:12 169:10 176:21199:19 227:13,19228:6,11,19,25 229:8229:14 264:14,19293:4 340:6,11 480:15480:21,23 481:3,20521:1,6,16,21 537:3,8557:4 573:21,23 574:8574:13 630:4

Agendas 22:16 126:18ages 515:4aggravated 390:10aggregate 192:24 279:8279:15,24 282:1,3

aging 441:9ago 96:4 188:16,16246:14 257:9 269:9298:4 333:13 363:20377:1 391:7 461:3549:21 553:13 629:11

agree 50:7 51:19 56:1761:3 113:9 114:1115:14 130:21 155:24164:25 194:13 258:20282:19 287:25 290:6314:18 348:5,19 354:6401:19 418:8 437:19554:9 595:10,10598:23 605:14,15635:11

agreed 455:1 548:19agreement 151:1 175:4Agreements 205:21AGW 474:7,9,13Ah 454:10 580:22ahead 22:17 39:19,22154:7 212:22 301:23322:17 478:3 580:9601:6,10 603:16,17605:11 619:24

AHJ 24:22 50:13 58:2160:17,23 82:2 142:21142:23 143:1 186:2206:14 248:25 318:4319:18 323:25 328:9336:6 463:17 569:1571:17 646:18,19

AHJs 50:25 52:4 63:2164:18 83:24 141:5194:19 257:7 268:1319:25 434:18 552:23

aid 267:24 606:9aim 458:17aimed 382:12

air 31:4 112:3 160:18,18160:19 191:23 201:2350:3 372:11,13,21373:15 375:19 471:8486:17 522:12 629:24630:1,8,12,20 631:17631:20 632:9

aircraft 32:9 87:3 214:12214:14 303:10

airflow 629:22 632:17Airport 31:14 32:15aisles 76:13Alan 2:23 9:16 27:23,2328:1,13 367:21,21421:23,23 422:7,7,25

alarm 12:22 13:1,3 29:1932:13 33:15,18 35:1635:19,22 68:14 70:3279:23

alarming 148:7alarms 261:4 262:16albeit 123:17Alecumen 11:11 635:25635:25

alert 432:2align 67:10 538:23aligned 630:16alignment 297:16343:22 502:20 539:1630:18,18

aligns 67:16ALLAGER 6:16Alleger 221:21,23,23alleviate 385:16Alliance 276:23 294:14295:2 546:15 547:5548:17 556:17 557:8561:4 567:5 574:3,20575:2,13 650:2 653:1

ALLISON 146:2allotted 278:23allow 12:11 18:8 67:1268:15 82:2 135:1,14141:13 150:24 151:1,4152:23 179:10,10188:5,25 189:25194:23 248:22 250:20281:18 287:14 346:17425:4 467:6 472:22490:15 491:19,21,23492:22,25 494:15529:3 580:11

allowable 14:15,23allowance 627:7allowances 482:1allowed 178:17 226:9242:10 284:19,20325:11 442:25 443:16469:22 487:15,17488:5 490:11 502:22533:18 552:17 578:16578:19 653:16

allowing 151:2 531:16allows 109:22 110:16188:1 278:20 325:7429:4,4 445:2 489:11547:15 548:13 554:21

Allred 383:20

Alston 4:12 119:24120:6,8,23 122:14,16124:9,21 128:11,13131:15 132:11,12

altered 392:12alternate 507:25 508:15608:11

alternative 33:6 34:1447:6 529:22 602:25615:15,16 616:5,10,25620:3

altogether 465:25554:21

aluminum 455:17 456:9458:21 459:14,17,19460:7,12,22 461:1,6461:14,20,22 462:8,8462:9,23 465:24,24466:9,9,10,11,20468:1,20,21,23 469:4469:7,9,17,20 470:5,6472:19,21,22 473:2,4473:15,16,21,21,24,24473:25 474:1,3,3,9,13

amateur 397:24amazed 282:11amazing 282:16ambient 471:5ambiguities 445:8ambiguity 139:7 366:14444:22 568:3

ambiguous 444:19amenable 499:2amend 15:14 391:13457:9

amended 42:19 53:14135:21,22 482:5 605:1

amending 13:18,25 14:614:11,14,19,23,2515:6,10 17:1 18:2537:9 43:8 44:9 53:1066:18 80:5 85:10 86:686:21 92:12 95:1498:6 100:4 101:25103:21 107:13 108:10120:3,24 125:16132:23 133:20 138:15140:5 144:16 145:11145:16 146:13 147:13158:10 159:8 169:9170:6,10 176:20177:17 180:17 204:18212:6 227:8,22 228:14229:2 231:2 240:24254:20 263:18 264:22273:17 293:2 294:10305:5 306:23 313:21321:23 339:24 340:14352:23 371:18 379:17393:11 400:17 413:7421:21 424:17 428:15430:25 431:3 433:22439:19 450:16 453:24458:2 464:15,18 465:7465:22 466:14 480:2481:7 493:20 501:14504:16 511:16 520:13521:9,24 527:21

537:11 540:9,23546:11 556:10 566:25573:14,25 574:24584:7 589:18 593:12596:15 599:23 602:11607:14 608:4 612:6614:25 624:18 628:7633:24 637:4 640:13644:6

amendment 15:22,2516:1 36:20,25 42:21186:2 215:1 283:16350:15 362:8 540:5610:14

amendments 83:2357:10 620:7

America 49:19 56:1663:16 176:16 294:13295:1 340:17 473:22473:23 542:17 546:14547:4 554:5

America's 202:12562:20

American 26:25 32:1864:11 186:20 229:5254:22 255:25 263:22329:16 341:4 379:20380:6 439:21 440:5441:20 450:18 451:7454:3,14 455:17456:17 458:5,15460:20 461:2 465:10465:20 468:2 473:10476:14 480:12 516:7541:24

Americans 194:13Amherst 25:22amount 22:9 137:18224:11 226:9 262:17282:13 283:18 284:21349:20 468:19 490:24515:3 554:15 654:12

amounts 243:21 262:12280:5 384:17

amp 245:6,6 303:3355:23 380:10 401:20401:22 406:13,14409:15 469:1,7,20494:12,13,16 502:4538:6,6,6 540:10,11540:11,20,24 541:5,15541:15,17,20

ampacity 467:25 468:13470:2,2,17,20,21471:10,15,20 472:19

ampere 407:17 408:1469:10

amperes 372:10 408:3470:22

ample 59:5 151:4 356:3373:23 597:24 625:22

amps 201:1,2 341:16345:25 349:19 401:15403:10 404:11 406:18407:20 469:1,11474:12 544:18

analogy 202:20analysis 183:18 438:10



Page 3

analytics 383:6and' 115:23and/or 525:6 639:13Andre 10:15 490:8,8Andrew 4:18 34:12,13144:10,21 146:2

Andy 4:22 9:2 151:12,13388:17,18

animal 360:6animals 445:25annex 46:17 82:5,18,1982:23 110:11,15,22111:14 112:18 114:5,5114:9,10,25 116:9,10122:22 123:17 126:10128:16,19 129:3 131:5131:6 141:4,24 170:25171:20,22 265:9,9,18266:21,24 267:2,6,12267:24 268:7,14 269:4269:11,20 270:13271:10 279:7 280:3432:17 434:11,13435:14 437:14,24438:1,7,15

Annexes 141:15announce 18:17 78:10118:22

announced 304:23453:18 546:5

announcement 12:2213:3 35:15,21 38:640:22 118:10 168:12

announcements 42:5339:11

annoyance 389:18annual 14:11 43:22 59:185:19 107:21 120:12133:7 144:25 146:23158:20 169:18 173:13177:4 293:22 315:2

anomaly 200:10ANSI 306:12,14answer 49:5 222:21282:23 359:21 390:11483:17 506:12 524:16

answered 59:25answers 383:9Anthony 6:5 199:23,23200:5,7,9

anticipated 392:1ANTONINO 4:13 133:3135:20 137:25 140:1143:13

Antonio 12:9 132:18387:3

anybody 44:10 75:1177:3,24 78:20 82:3,1084:4 104:18 183:12271:21 377:8 389:3506:23 510:17 625:22

anybody's 56:1,8anyone's 41:23anyway 86:24 251:16258:5 323:22 395:18467:21

anyways 39:12apart 390:9 406:24 426:8

626:23Apfelbeck 80:11,22apologies 182:9 188:19392:10 605:11 617:19622:23

apologize 86:20 193:9239:19 416:22 485:10497:15 508:13 535:7579:16 581:6 582:13582:19 634:8,18

app 13:12 14:10 36:4apparatus 135:6 311:12322:1,22 323:14325:11 337:11 400:20424:20 425:4 428:18493:23 501:17 511:20520:21,22

apparent 52:5 522:11,24585:11 590:20 594:17597:18 602:15 615:4625:15 633:2 638:13

apparently 161:7appeal 15:22 36:17,20417:22

appeals 15:19,19 37:7433:23

appear 18:12 42:2181:23 393:23 419:1,2438:2 490:14 642:11660:5

appearance 413:23appeared 65:18 66:4,8145:14 227:13 228:5228:19 229:8 264:14340:6 409:1 413:19414:18 444:16 480:15480:22 516:2 521:1,16537:2 574:7 637:17

appears 79:16 481:18,21557:4

appending 431:22appendix 81:10,11,21269:3,4,5,11,20

applause 20:9,13,1621:15 23:10 25:8,2526:7,24 27:25 28:1929:13 30:13 31:234:23 43:15 80:1 85:1107:3 118:8 119:1132:13 144:6 146:3158:2 176:11 209:16211:5 212:1 223:7281:9 289:19 290:16292:8,17 293:15331:25 332:24 340:4399:3 418:5,10 420:11427:5 453:17 480:8498:22 503:10 510:10520:24 521:14 530:13574:6 580:23 659:14659:23 660:17

appliance 161:2 300:11300:14 354:13

appliances 87:22 167:19279:24 280:8 354:17354:20 357:1 358:17359:10 384:19

applicable 68:17 90:21

104:16 167:17 179:17324:8 327:12,14333:11 336:8 515:15639:7 646:1

application 77:21 87:17101:1 122:19 139:16225:17 268:10 269:16312:25 335:10 344:11375:3 409:14,23447:18 491:21 604:5632:6,8,11,15 647:6659:1

applications 68:21163:4 192:4 202:25213:11 214:2,10219:14,15,18 222:17225:7 295:24 296:4297:22 298:3,21374:22,25 375:1473:19 482:16 483:14483:18 496:2,7,8547:16 576:8,11632:12,13

applied 149:8 150:1153:21 187:9,10327:11 328:16 336:3410:2 444:21 512:11519:2 604:17

applies 57:24 111:13179:8 192:3 208:25288:20 315:20 324:5337:21 338:2 356:25376:13 403:9 543:3620:16 646:8

apply 57:22 90:10110:21 113:25 180:13181:3 188:4 191:21192:19 204:22 206:17207:7,9 217:24 219:25225:12 260:23 268:14288:21,23 302:18330:4 335:18,19344:17 360:1 391:25447:12,18,20,22 517:1517:23,24 549:3576:12 602:7 618:14635:21 649:2

applying 149:25 196:21349:6

appoint 443:21appointment 23:19appreciate 83:24 165:22191:12 220:11 261:20262:7 267:21 274:16278:17 287:24 362:25389:2,8,14 392:6426:7 452:5 542:18623:8

appreciated 19:21283:23 569:10

appreciation 25:1534:22 426:7

approach 17:5 79:581:20 184:15 187:18187:19 327:4,19360:11 417:20 441:13516:17 523:25 576:4

approached 573:18

approaches 33:6 34:179:14

appropriate 18:6 101:1123:25 128:25 129:4139:15,16 149:21173:3 198:24 207:4219:25 233:4 259:14259:18 284:14 329:7336:3 434:6 486:13490:3 525:8 576:12

appropriately 557:12558:6 576:24

approval 327:5,9,19,22328:10 576:3

approve 135:14 249:2434:21 451:14

approved 139:8,9,9,10139:19 141:13 142:5142:25 156:9 204:20215:12 259:7,8,10261:5 276:20 329:19336:17,17 366:22540:19

approved' 142:10approving 505:11approximately 130:11202:2,3 217:6 265:10268:8

April 102:21APS 200:2,9,19aqueous 288:21arbitrarily 459:18arbitrary 242:7 285:5arc 346:5,12 350:4,23387:3 395:4 401:19420:3 436:12 533:17635:19

architecture 557:13575:20

arcing 350:2 382:22386:18 438:21 529:13529:15,16 531:21533:13

arcs 389:23 398:6,12arduous 22:24area 75:22 76:1 181:9,11192:2 199:15 203:10203:17 250:22 268:6279:9,14,20 286:1,9325:13 346:17 358:11368:2 369:5 374:24448:2 569:9 571:22

areas 16:19 187:19202:6 234:12 278:1279:19 280:1 283:6284:9 363:9,20 368:24380:14 392:18 448:1483:7 487:19 529:15651:20

argue 192:11,12argued 543:14arguing 51:25 478:24argument 350:16 477:8593:16 598:9 630:25

arguments 426:23473:12 591:17

arising 297:25 298:24549:22 559:23

Arizona 21:13 185:3187:17 188:8 190:2196:23 256:11

armor 528:24 529:11,19529:21,23 531:22533:10

armored 528:13,20529:13,15,18 533:15

arose 153:8arrange 369:25arrangement 49:24309:20

arrangements 13:8 36:1array 116:6arson 394:12article 296:19 297:20302:10,14,16 305:24318:19 326:13,25354:12 356:22 404:8422:18,19 454:19456:20 459:16 470:21474:8 498:10 517:13517:15 533:5 535:15542:12 543:15 549:18559:19 560:5,6 562:14569:5 570:3 577:25592:4 597:1,5 600:16601:20,20 602:6603:14,19 608:6623:12,13 629:8,17,25634:22,23 641:25642:1,2,8,9 655:7,18655:18,22 656:7,11

articles 517:18 619:5629:1,6,7,9,9 630:8,17630:23 639:8 646:11648:2 655:20

Arup 119:24as- 48:7as-built 50:6as-is 277:8Ashray 261:18 262:13Ashton 6:24 261:15,15261:23 262:2,4,6281:23,23

aside 646:18asked 18:16 49:4 72:1473:16 81:21 165:6,23165:24 166:1 203:21382:18 384:4 456:7,10459:12 506:11 517:14

asking 79:7 80:25 225:5236:16 258:9 303:8342:13 364:11 372:22419:9 432:18 441:15442:4 460:8 645:10

asks 195:3 204:19 278:6aspect 150:15 369:4646:7

aspects 82:22 316:10438:8

assemble 590:7Assemblies 27:6assembly 27:6 32:2366:14 227:18 228:11228:24 229:13 264:19340:11 377:2 480:20481:2 487:11 521:5,20



Page 4

522:14 537:7 541:13573:21 574:13

assessed 18:6assessment 123:8asset 29:14 186:24188:8 189:2 256:14

assign 41:17assigned 41:19,24267:19 271:13 433:25

assist 19:20 650:4,9651:19

assisting 78:2assists 17:19associated 26:12 28:428:23 29:18 30:1733:14 38:2,4 40:18,20110:15 128:4 149:18171:15 198:18 204:22205:14 214:14 233:24234:4,6 307:10 309:13313:9 327:10,17 343:7355:13 368:20 369:7586:15

Associates 29:15 43:4169:5

Association 16:16 27:144:16 147:16 151:14154:14 162:19 189:9201:24 209:13 235:2289:14 316:24 322:22323:14 337:12 347:19353:1,16 355:8 356:15356:21 362:10,24364:24 366:20 367:1371:20 372:4 373:9374:9 375:24 379:21380:7 381:9 402:10410:9 416:3 426:3429:23 431:17 432:8437:20 439:22 440:6441:5,20,22 450:19451:8 454:3,14 456:17458:5,15 459:10460:20 465:10,21467:16 473:10 476:14480:13 484:3 495:5502:17 507:17 513:1523:18 539:6 540:2,4541:25 575:3 602:10604:14 606:18 608:4614:24 638:18 641:17647:16

Association's 45:17associations 556:18assume 336:7assuming 339:12,13391:17 568:24

assurance 248:18 249:8562:1

assure 191:3assured 248:21asterisks 438:3ASTM 87:25 90:6,21,2293:5,5 94:16 97:8102:14,15 109:12,15109:20 110:12 111:10113:18 114:4,7,20,20116:9,11 135:5,5

137:1,1,2,4,7,20268:25 269:4 458:22461:6 466:3 487:12641:4,7,22 642:5,14

AT&T 645:6 652:8,8ATKINSON-BAKER 1:19attach 496:12attachment 502:3attack 341:22attempt 52:9 276:11432:13 568:3 598:14

attempted 224:16355:14 558:22 577:13

attempts 189:18 216:19466:11

attend 384:4attendance 17:10attended 259:9attendee 13:21 130:24attending 130:24attention 22:14 64:5183:2 208:19 209:3216:15 277:14 308:2494:18 576:22 622:19623:1 636:2

attentively 24:2attest 283:19 661:5,8attestation 335:11attorney 661:9attract 208:19 209:3attributable 432:10audience 19:5 71:986:20 165:21 282:16388:4 538:13

audio 1:3 12:1 119:6230:3 412:7 527:7661:6

audio/visual 261:4August 37:6 157:6author 159:22authorities 49:4 87:12184:20

authority 48:22 132:18139:11,12 206:6336:18 347:7 547:20547:22 548:16 557:16557:25 558:3 559:3575:24

Authority's 517:22authorized 14:17 17:366:9 227:13 228:6,19229:8 264:15 340:6480:15,23 521:1,16537:3 574:8

auto 547:6,7 557:8 575:3Automakers 294:15,15295:3,3 546:16 567:6

automatic 27:4,16 31:1732:5 590:7 592:2

automatically 41:6 94:4automobile 300:19302:1 556:17 567:5569:18 574:3,20 575:2575:13,19

Automobiles 571:9automotive 294:14,16295:2,4,10,16,24296:1,4 301:6 303:7

546:15,16 547:5,5,8547:14,16,19,20 548:5548:17 550:5 551:25552:5,9,14 557:13559:4 568:10 571:16576:8,11

auxiliary 87:22availability 529:2 568:20608:15

available 13:19 14:5,2442:2 90:1 172:1 247:1265:23 274:25 303:17310:20 383:4 417:16417:18 432:7 434:17515:22 522:17,17550:19 552:23 560:8

avenue 150:13 441:2avenues 308:8average 148:24 202:6avoid 129:17 282:23357:11 396:12 434:22542:2 610:6

awake 208:17award 2:14,16,18,20,222:24 3:1,3,5,7 21:3,821:12 23:7,9,12 25:725:12,17,19 26:5,2227:23 28:17 29:1130:11,25 31:23 34:22

awarded 18:4awards 21:6,7,11 25:1025:11 32:3

aware 64:16 68:18 74:1274:13 283:1 313:19435:8

AWG 473:1,2Ayer 7:23 318:22,23

BB 12:18 35:12 131:5,6512:5 516:14 517:9

B924 128:14 131:7back 39:15,16 50:2162:1,10 63:14 71:1571:16 72:4,10 73:3,1579:18,24 84:10 93:23115:2 154:19 155:2161:1 174:7 191:3218:14 246:24 254:6273:24 276:12,14280:15 285:11 289:7289:21 291:22 308:2312:5 321:9 323:20324:25 332:7 333:13338:7 342:3,6 346:9347:14,16 349:9 351:1357:4 370:25 379:17390:8 392:21 393:10409:25 448:9 450:1451:11 452:15 465:4490:19,22 494:17495:13 510:24 512:15522:14 526:24 533:9587:4 606:4 608:16610:14,24,25 615:12619:22 620:14 626:20626:24 644:3 650:13654:15

back-layering 121:24122:4 123:3,4,9,11,18123:20 124:13,14

backed 214:22background 38:3,540:20 71:23,25 72:672:12,22 73:7,14,2173:25 74:3,15 75:2,4,675:10,16 76:14,1977:2,5,8,15,19,22 79:179:11 80:19 119:19208:13 222:9 230:16230:25 269:15 339:22506:16 507:2

backseat 580:10backup 216:4 279:22285:3

backwards 621:9backyards 290:2bad 170:21 356:6 477:7badge 16:18 41:17,19,25Badinksi 396:16BADINSKI 396:15,23BAE 212:8,24 224:23273:19 274:10

balance 186:13 235:6582:24

ballot 15:23,25 36:22,2444:2,4 65:1 85:24,25108:2,4 120:17,18133:12,13 145:4,5147:5,6 150:22 158:24159:1 169:23,25 177:9177:10 241:24 294:2,3306:25 354:8 367:3,4374:20 381:15 391:18502:23 624:14 628:3630:17 643:22

balloted 37:24 40:15balloting 514:21ballots 16:1 37:1ballroom 118:15 168:18balls 585:4bar 489:18,20Barber 9:2 388:17,18barrier 529:7,9,10barriers 529:8Barrington 28:21Barry 7:19 315:25,25329:3,3 410:15,15427:7,7 524:19,19587:21,21 592:10,10595:15,15 626:7,7

base 229:19 315:20648:22,23

based 15:19 16:12 27:1036:17 37:4 42:1857:24 61:4,4 110:9123:4 129:19 154:21162:25 199:2 201:3207:8,12,14,16 226:4226:6 243:20 245:17277:12 284:7 297:10297:13 298:16 327:6337:1 347:10 382:15391:23 393:7 413:20455:13 478:1 502:7516:3 530:23 548:23

597:4,5 605:1,20637:18 642:4 645:9

baseline 223:11basement 349:18 363:11363:15 366:7 367:15367:24 368:7 387:20397:15

basements 363:6,9,18363:20 366:2,8,15367:11 368:23 369:1

basic 51:20 578:10basically 48:9 72:1781:23 105:14 187:2283:4 324:17 341:17342:2 348:10 353:23405:18 408:2 416:8456:19 518:1 531:10538:17 553:3 575:23601:24 612:25 614:2628:22 651:1

basics 552:11basing 611:1basis 123:8 149:4200:11,17 224:14235:10 252:4 287:16308:11 310:9 312:15327:15 388:1 404:22416:10 456:9

bathroom 614:9bathrooms 543:19batteries 191:24 192:1196:22 212:9,24213:10,18,21 214:1,7214:10,20 215:22216:4 218:10,13,22219:13 222:24 224:10224:23 225:3,6,14234:6 235:12,12,13246:5 248:2 252:6257:1,4,15,16 261:20262:9,11,12 273:19274:10,20 275:3,13,23275:24 279:11,14,15279:18,22,25 285:23

battery 182:25 185:7190:5,16,19,21 200:25212:10 213:4,5 217:5219:22 221:24 234:13244:10 245:4,9 247:8247:12 248:10,20249:5 250:6,7,9259:13,18 261:5,17273:21 275:1 280:9281:24 282:4,7,8,8283:7 285:3 286:3290:4 332:14

bear 72:4 228:1,2 644:1beat 205:11 401:9beautiful 369:19becoming 59:6 274:18357:8,11 605:24

bedroom' 509:25beeping 13:1 35:20beg 409:13began 215:11 276:19380:12

beginning 126:8 207:17306:8 523:12



Page 5

begins 17:2begun 548:18behalf 59:14 80:11137:23 164:12 172:11173:11 177:23 180:22182:10 186:1 237:10245:21 249:14 276:22315:1 355:11 374:9387:5 392:6 393:24396:16 436:22 442:18446:23 451:25 455:2459:8 461:20 467:14467:17 470:11 471:25478:18,22 483:25484:4,14 492:6 532:11541:24 551:6 586:5,8604:19 606:17 619:12631:14 632:5 635:9642:21 649:12

behave 127:7 482:22behaves 135:10belabored 514:8belaboring 498:5belief 645:9believe 59:19 64:18 67:8151:19 154:6 164:24174:3 187:19,21 195:1247:7 257:5,10 258:4258:6 259:17 278:18280:17 308:4 315:4326:18 327:20 355:4357:5 373:6 376:2,13381:6 382:13 402:8405:7,10,11,23 408:8410:22 418:18 419:22419:24 427:15 442:13462:23 467:14 478:7482:21 497:9,18507:14 511:16 518:21542:1 548:20 559:1,15608:18 610:11 628:16647:13

believed 44:19 153:23believes 46:13 59:18215:20 278:4 316:16343:23

bell 2:7 18:11 19:25 20:220:10,14,17 23:8,1125:6,9 26:1,19 27:2028:13 29:8 30:8,2231:20 34:21,24 70:1651:11

Bellis 2:3 12:7 20:1121:16 23:15 25:2126:8,25 28:1,20 29:1430:14 31:3 32:2

belong 436:6 437:18608:20

belongs 112:15Ben 6:21 251:25,25benchmark 58:19beneath 445:23beneficial 82:9benefit 50:13,13,14 51:282:7 348:18 349:23350:5,7,16 351:12364:6 432:21 438:19442:7 445:19 559:6

647:24,25benefit?' 364:12benefits 150:10 576:7Bennett 9:1 387:2,3,10bent 190:8Berker 6:4 197:8,8Bernie 169:4Berra 427:1best 23:4 141:23 162:10172:1 187:13 256:13256:16,17 370:1382:20 383:8 393:6506:12 552:15 581:10582:22 583:1 661:7

Bethesda 292:24better 51:1 52:10 67:1668:21 127:7 150:12172:13 187:5 205:12205:15 247:17 257:11285:15 308:19 338:9358:17 359:13 484:10533:10 579:7 619:8

beyond 22:5 123:19183:19 267:17 312:8344:23 406:20 415:15448:22

bi-fold 351:24bidirectional 297:5299:10 560:19

big 52:8 188:9 217:25256:16 279:20

bigger 185:19 252:8biggest 235:13,13Biggins 5:16 176:15,24176:25 177:15 182:8182:11 184:5 215:5,7218:19 225:22 233:20233:22 234:21 239:18240:4 243:15,17 244:3255:10 258:12,14259:22 263:1,2 267:13267:15 268:17 276:16276:18 292:15,16

Bill 8:10,22 11:22 43:1443:14,18 46:9 55:264:24 67:20 70:1082:16 84:6,25 350:12350:12 351:21,21382:8,9 498:23,23516:11,11 533:22,22645:5 656:3,3

billion 482:18Billions 482:19bimetal 458:25bimetallic 458:18,21473:14

Bimetallics 454:2,3,13454:14 456:17,17458:5,5,15,15 460:20461:21 465:10,10,20465:20 473:10 476:14476:14 480:10,12

binder 137:18bins 112:3,11biological 151:17Birch 506:17Bishop 8:1 322:12,14,16322:18,21 323:1,13,13

337:10,11,14,16,19bit 173:2 187:24 191:14208:7,12 219:11 282:1314:22 496:1 510:25512:16 576:20 603:23605:7 641:20

black 436:8blanche 225:3blanket 206:13 569:3blenders 354:20block 346:9 351:24363:11

blocking 350:19,23blocks 346:10,11 350:22blow 235:11blown 190:7blows 429:6Blues 530:11blurred 196:2BMS 248:11,14board 33:20 69:6 165:6315:3 364:10 483:12519:3 548:8,10 554:14557:10 558:11,11,13558:13,19 575:15577:3,11 636:2

boards 513:9,12 516:19518:25 519:2

boat 88:17 89:23 214:10boats 87:18,19 88:15,2296:13

Bob 3:17 9:17 49:18,1856:15,15 63:15,15431:1,1,12,12

Bobby 10:18 293:12494:25 495:2,3 502:13502:15,15

body 114:24 116:11130:7 150:14 207:8267:7 269:19 303:6309:11 404:24 416:22427:19 435:25 472:1472:16 498:5,8 514:10532:17 551:18 560:3585:22 587:11 591:6591:20 606:23 619:18620:17 643:1 649:18

bolted 401:16bond 435:15 436:14459:1 601:16,19,20

bonded 602:2 609:16bonding 431:21,24432:4,10,17,23 433:11434:4 435:17,17 436:4437:23 438:16,17462:2 601:23 602:2607:17,17 608:19610:7,8,18,19

Bonesteel 184:7,7book 467:21 571:23borrows 445:16bothered 161:7bottom 41:10,12 60:18118:14 168:17 209:25210:7,21 253:8 272:16291:13 320:24 361:7370:16 378:14 399:13420:21 449:17 475:11

503:19 526:1 545:8555:11 566:2 572:17583:10 659:3

boundaries 178:12box 279:20 447:7boxes 57:7Boyce 7:7 296:20,21,22326:17,19,19 343:1,2343:3 562:9,9

boys 360:5BRADINSKI 9:5branch 300:4,6 354:16382:20,24 401:11403:9 404:9,11 405:13405:14,20 407:21445:15 447:19 466:25487:25 539:12,13541:15 542:22 543:14544:6 551:13,14

Bravo 366:10break 118:23 160:16219:10 229:16,18339:14,18,19,21407:11 411:23 412:4473:11 526:22,23,24527:2

breakage 587:3breaker 201:1 308:14312:7 379:20 380:6384:7,10 385:2,3,8,12385:13 394:21 395:2,7395:8 397:3,4,15401:17 405:19 409:16410:3 469:2 522:12,12541:24 597:4

breaker's 510:3,5breakers 308:15 385:15389:6,7 395:2 397:10397:14 405:11,12,13405:15 409:20 469:7469:21 470:19 498:12498:14,15 584:21

breaking 118:11 168:14248:14

breaks 118:10 168:13289:24

breath 556:15 626:21breathing 346:19 350:3Brett 8:25 385:21,21Brewster 158:7Brian 8:4 330:15,15366:18,18 410:8,8503:7,7

Brider 6:10 209:12,13bridge 57:8Bridges 133:10 140:2brief 331:3 519:11575:23 620:24 653:3

bring 30:11 39:15 51:8142:9,9 276:14 282:3302:18 397:9 470:20553:5 621:14 636:2655:18

bringing 609:8 651:19brings 22:14 24:17269:17 291:22 321:9323:18 325:13 357:14

broad 57:12 189:16,23

189:25 190:16 191:21232:1 262:9 279:3283:5 299:15 419:24558:10 597:6 625:4

broadband 646:8,24648:13 651:20 655:8656:8

broadened 655:14broader 289:5broadly 547:25Brotherhood 309:4331:1 345:11,12349:13 404:3 416:20426:20 435:24 498:1513:25 591:15

brought 116:4 136:9183:1 216:14 239:13271:14 286:11 313:11363:10 427:19 433:13496:11,13 578:7,8597:10 638:4 650:24

Bruce 5:7 162:18,18brunt 397:2brush 189:17 597:6625:4

bucket 425:12Buckley 6:1 194:7,8227:10,10,24,24

build 196:24 197:3 285:1442:7

builder 372:19Builders 313:9building 26:10 27:2,530:2,4,6 31:6 32:1933:3,4,7,19,22 58:2190:8 110:21 114:19139:10,12 163:13181:11,14 199:16206:15,22,25 207:5,5269:2 287:4 300:12301:1 363:13,14380:18 383:25 386:5,8386:17,19 436:9,11440:9 441:1,3 442:21443:7,8,9 445:3,6,10446:25 447:3,6,8,16447:21,23 448:14,25449:1 482:12,24484:10,25 486:4,5,6486:12,13,22 487:10488:4,5,6 489:13,14547:9 548:12 587:9614:4 615:22 616:8645:24

buildings 48:14 50:257:8 182:17 207:12,13207:16 289:6 367:16367:17 441:17 443:4444:12 445:15,24447:22,23 482:6,7,9482:15 486:14,14,15488:14,20 489:9,12,21489:23 490:1,3,16

builds 128:17built 48:8 58:17 215:15223:25 224:1 277:17333:10 338:1,1 380:22

bulk 163:4



Page 6

bullet 188:24 256:20bumps 289:22bunch 86:21 114:15143:5 207:14 223:15527:22 582:25 660:2

bunkers 112:3,11burden 220:2 345:3351:11 352:2 417:4508:2 648:25

burdensome 283:6buried 650:22Burkett 567:2,2,11,15,23567:24 571:6

Burkhart 32:4burn 10:7 114:13 116:4134:14 185:15 187:14188:6 189:14 247:19460:18,19 473:9,9

burning 90:6 109:22burns 4:21 7:14 147:15147:15 148:4 187:17293:11 307:21,22308:3 425:24 426:1,2429:19,21,22

Bush 4:10 118:18,21,25119:20 120:23 121:4121:13 122:14 124:2124:16,23 125:8,22126:1 128:11 129:24131:11,21 132:14133:19,25 134:4135:18 136:14 137:21138:1,21,25 139:24140:12 141:17 142:15143:9,14 144:7 145:10145:14 146:4 147:11147:21,24 148:2150:18 151:7 152:15153:1 154:11 155:5,9156:25 157:9 158:3159:6,11,15,19 161:19161:22,24 162:13164:8 166:14,18,21,24167:10,21 168:24

business 15:6 29:530:15 32:25 33:1735:2,6 37:13 49:872:10 118:22 173:13203:7 347:1 358:15395:9 437:1 484:9515:23 532:14 606:20619:15 642:24 649:15

busses 87:13bussing 513:9,15Bussmann 30:15button 37:25 40:16,1941:9 52:23 62:8 65:770:15 84:10,11 91:2495:2 97:19 99:17101:13 103:9 106:8117:19 125:2 131:25138:4 143:18 157:13167:24 175:24 211:17226:20 240:12 253:22263:6 273:4 292:1304:12 338:23 352:11361:21 371:6 379:4388:13 400:1 411:12

421:9 424:6 428:3430:13 439:7 450:4453:1 457:17 464:5475:24 479:17 493:10501:4 504:6 511:6520:3 526:13 536:18545:21 555:25 566:15573:4 583:21 589:8593:2 596:5 599:13611:20 624:7 627:18633:14 636:18 640:2643:12 657:1

Buuck 8:11 352:25353:1,15,16,22 356:20356:20 362:9,9,23,23365:10 366:7,25,25371:19,19 372:3,3375:24,24

buy 314:6,7 522:18

Cc 2:1 459:23 471:3,3,3,5474:13 578:16

C2 183:25 184:1cabin 89:20 577:2cabinet 259:1 519:4cabinets 513:10cable 438:17 445:25448:5 466:20 482:3,5482:9,12,14,18,19,21482:22,25 483:5,7,13483:18 486:3,8,10,13488:3,19 489:20490:15 491:5 492:10492:13,22 528:1,12,14528:20 529:1,5,8,13529:19 530:25 531:2531:16,18 532:21533:4,14,15,25 534:11535:5 630:13,14 632:3632:14 635:19 646:21648:13 655:10,11,12655:13,16,19,24,25656:15

cables 348:15,16 488:16529:4 531:6,14 534:12558:15 628:22 629:13630:8,24 631:19645:11,18,18,19,23646:2,7 647:23 649:3650:18,18,21,21,22,25651:3,5 652:12 653:10653:11,16 654:20655:11,17

Cabot 9:23 439:21,21440:5,5 450:18,18,22450:24 451:7,7

cadmium 182:25 213:10213:18 214:1,7,9,20215:21 225:5 262:12275:3,23 288:14,22

calculate 58:2calculated 57:21calculations 217:20275:20

calibrated 163:11California 26:9 203:6,17207:2 276:22

call 37:17 55:14,15186:9 209:14,18,20210:8,13,14,18,21211:9,12 230:22252:23 253:1,3,16,17269:3 272:7,12,19,23272:24 290:14,18,20291:14,20,21,22 320:5320:12,19 321:2,7,8360:22,25 361:2,15,16370:6,9,11,19,24,25377:25 378:7,9,17,24378:25 389:19 398:23399:5,7,20,21 407:11420:9,14,16 421:4,5423:20 449:9,11,13,24449:25 474:22 475:5,7475:20 477:15,17,19477:24 503:8,15,21,22504:1 505:2 506:5525:18,20,22 534:15535:8 539:9 544:23545:1,3,15 555:3,5,7555:20 565:18,20,22572:8,10,12,25 573:16580:21,25 581:19583:2,6,17,18 585:4609:14 613:19 622:2622:19 623:17 629:24650:25 655:11 658:21658:24 659:2,5

call- 41:8 288:12callbacks 384:18called 22:21 24:12 54:554:9 59:20 225:13372:19 377:6 389:19394:6 563:18 581:7616:6 620:11 654:6

calling 58:12,16 253:12361:10 378:3 420:25475:18 504:3 526:7,9538:1 545:14,16555:15,18,19 566:8,9566:10 572:23,24583:16 615:20 616:14623:10

Calpine 202:19CAM 86:25 109:24 195:6243:9 316:14 330:17340:18 380:13 410:10444:8,11 445:8,19454:15,17,19 474:7588:11 590:21 601:9602:5,9 650:11 653:16653:18 654:13 656:13

Cambridge 119:25camera 19:9Campgrounds 540:3CAMs 310:22 317:25333:3

Canada 305:16cancer 148:6,9cane 407:14Cantor 6:13 217:2,3244:8,9

cap 200:25capability 91:11 346:6capable 259:20

capacitors 234:13capacity 252:7 279:9,15279:24 282:1,3

Captain 189:7captured 207:18 208:1237:17

captures 19:9Caputo 3:17 49:18,1956:15,15 57:18 63:1563:15

car 185:9 564:19 565:2,6Carbon 29:20carcinogens 148:15care 28:21,22,24 29:133:20,21 58:22 147:1186:10 303:4 363:13377:11 560:2 609:11620:8

careful 209:5 378:3570:13

carefully 183:3 214:25298:11 578:8 579:2

carelessly 394:10Caribbean 461:3 473:23Carolina 169:5 388:19carried 399:21 400:11carrier 652:14carry 150:4 441:3 466:23470:22 562:5

carrying 89:18 471:6653:14

cars 126:11cart 118:14 168:17 225:3Carterfone 651:9carve-outs 275:9 276:10carveouts 181:4cascade 257:22case 63:23 121:21 136:2202:23 247:14 260:9260:16 269:20 308:14310:9,9 345:5 349:3404:22,22 405:11409:15 410:3 416:10416:10 417:13,13,14417:14 468:20 470:3519:3 524:14 538:15580:6 590:3 613:22621:23 622:12 653:19

cases 100:18 127:13148:23 196:6 202:10207:9 221:10,14310:17 351:10 552:6

cast 16:3 18:3 36:8373:25

catastrophic 250:24251:2

catch 546:8 556:14categories 182:17Catherine 2:15 23:12,1323:15 25:7

Cathy 23:17,22 24:1,1024:20,25

Cathy's 24:13cause 39:12 52:11 150:7283:6 288:4 386:10,15386:16 389:22 397:21398:12 434:14 543:2557:21 577:6 631:1

651:14caused 366:1 568:4causes 238:9 262:16385:10 393:1

causing 220:2 653:21caustic 235:14caution 174:21caveat 149:15CDC 461:19 470:10608:22

cell 245:7 247:24 248:3580:9

cells 234:14 247:25600:19

center 12:16,19,24 18:1219:8,11 35:10,13,18283:8 349:18 425:12505:17

centers 279:21 282:5central 89:21 259:7392:25 473:23

Century 21:21 645:7CEO 387:3certain 148:24 185:14225:15 238:4 269:14275:19 283:5 286:22286:22 300:13 308:12315:18,19 318:25,25454:17 563:19 571:20638:25 639:3 651:13

certainly 50:11 57:7209:2 220:11 246:10283:23 380:23 408:4437:17 473:16

CERTIFICATE 661:1certification 15:1 300:8300:10 323:23 335:19384:1 466:4

certifications 383:24certified 13:18,25 14:614:10,14,19,23,2515:6,9 17:1 18:25 37:943:8 44:9 53:10,1466:18 80:5 85:10 86:686:21 90:10 92:1295:14 98:6 100:4101:25 103:21 107:12108:10 120:3 125:16132:23 133:20 138:15144:16 145:16 146:13147:12 158:10 159:7169:9 170:6,10 176:20177:16 180:17 212:6227:8,22 228:13 229:2231:2 240:24 254:20263:18 264:22 273:17293:2 294:9 298:16300:7 305:5 306:23313:21 321:23 335:20338:2 339:24 340:14352:23 362:8 371:17379:17 400:17 413:7421:21 424:17 428:15430:25 439:19 450:16453:24 458:2 464:15464:18 465:7,22466:13 480:1 481:7493:20 501:14 504:16



Page 7

511:15 520:13 521:9521:24 527:21 537:11540:8,22 546:11556:10 566:25 573:14573:25 574:24 584:7589:18 593:12 596:15599:23 602:11 605:1607:14 608:4 612:6614:25 624:18 628:7633:24 637:4 640:13644:6

Certifying 120:24 145:11400:17 433:22 540:5

CFR 329:18chain 373:17chair 17:7 20:3 23:2324:12 25:2,5 28:9,2529:3 30:1 32:10,1234:2,11,15 43:4,12,1743:18 44:6,14 51:752:15,19 55:2 57:1661:12 64:23 65:4 70:882:16 84:4 85:5,13,1591:19,21 93:24 94:2194:24 97:11,15 99:11101:9 107:8,16,17108:6 117:11,15119:24 120:7,8,21124:19 131:13 132:12132:18 133:2,3,17137:23 140:20 143:11144:10,19,21 145:8146:8,16 147:9 157:2157:4 158:6,14,16159:4,20 167:12 169:4169:13,14,15 170:3171:9 175:12,14,20176:15,24,25 177:12177:20 186:18 189:6204:14 212:9 217:2,18218:8 220:9 225:21226:17 235:1,4 240:9243:17 244:8 254:21258:14 260:14 261:16273:20 274:7 276:18281:23 289:13 292:16292:23 293:9,17,18,19294:6 296:12,18,21302:9 304:8 306:22307:17 318:23 326:2326:16,19 337:8338:19 342:22,25343:2 347:23 352:7,25353:15 354:25 355:3,9359:19 364:17,20,25365:23 373:2,5 374:15375:11 381:2,5,10383:17 402:4,7,11411:8 415:7,23 416:4423:3 424:2 425:17,23427:21,24 429:16,18430:8,9 433:3,6,9435:7 437:9 438:7439:3 442:10,13,17451:17,20,24 452:22454:22,25 455:1,5,20457:12,14 459:4,7,9459:12,23 464:1,17

467:10,13,15,21,22474:20 476:25 478:15478:16,17,20 479:11479:12 480:3 483:24484:2,14 485:13 493:6494:22,25 495:2,5,16500:24 502:10,13,15502:17 503:1 507:10507:13,15 511:2512:20,22,24 519:24522:23 523:14,16530:3,6 532:10 536:13537:14 538:22 539:3,5542:16,20 549:8,14,17559:11,14,18 562:9569:23,24 570:2577:18,21,24 581:3,12582:14,15 585:2,13589:4 590:14 592:22594:10,18 595:24597:9,19 599:7 602:14602:17,23 605:16607:9 611:15 615:3,6615:9 619:11 620:20624:3 625:9,16 627:13631:6,9 633:9 635:1,4636:14 638:3,14,18639:23 641:11,14,18642:20 643:8 647:10647:13,17 652:25656:22

Chair's 478:3 532:23chairing 24:3chairman 47:6 83:1986:3 90:20 93:5,25102:14 105:2 135:4137:1 146:18 150:20150:21 151:12 152:14157:8 158:1 182:11208:4 239:16 258:11263:21,21 296:23299:25 301:12 307:22309:2 326:20 330:24343:3 345:9 349:11355:5 356:2,8 364:22373:7,9 374:1 381:7381:25 387:2 390:20396:15 402:9,20 404:1416:1,3,13,18 423:24426:1,3,18 429:21,23435:22 436:21 442:15451:22 463:7 471:24478:21 497:24 498:23513:23 516:11,22517:6 518:5 530:8532:4 533:22 540:12541:12 543:8 551:5562:10 563:2 564:10575:1 581:1 585:17586:4 590:25 591:13594:21 597:22 598:4606:16 607:7,9 609:20612:23 621:20 622:16625:20 631:11,13632:23 635:6,8 636:5638:16 641:16 649:11654:9

Chairman's 607:8

Chairs 293:6,14 417:21challenge 51:9,16 166:1challenges 156:20 619:3Champion 530:11chance 243:14 275:8505:14 515:2 583:5

change 38:5 40:21 42:1550:2,2 51:1 55:8 56:768:6 82:17 93:1794:11,11 99:2 102:21102:22 114:21 123:1179:12 188:9 204:19222:14 231:22 234:20238:7,10 242:1,3,6,8,8243:9 244:16,18,21342:16 343:9 350:7354:7,10 355:13363:20 372:24 374:19391:3,16,17 420:1432:14 441:18 446:24447:3 457:3 462:24483:5 487:16,23 549:3552:19 588:1 610:24613:7 616:23 617:22632:25 633:4 644:24645:13 648:18,25659:1

change.' 233:6changed 121:5 179:15213:8 223:3 303:16390:9 550:18 560:7578:15 610:2 622:10

changes 23:24 24:2242:22 55:4 56:4 83:7122:21 179:15 224:2,4242:13 258:9 271:22275:7 284:6 316:4415:2 455:13 462:25483:17 568:2 592:15595:19 626:12,22647:3

changing 38:24 42:681:22 83:22 121:19155:19 235:9 238:5375:19 605:8

chapter 46:17,23,2458:13 96:22 97:14109:25,25 114:24115:23 163:9 183:5216:2 236:21 244:2257:25 264:9 268:8307:16 309:19,21310:10,19 415:15487:9,9 622:4 629:9629:17 639:1,6,6645:1 648:1

chapters 234:14 309:23characteristic 328:20characteristics 112:6328:14

charge 523:6 580:9charger 259:14 261:5charges 523:10charging 237:16 302:5558:14 560:19 564:6564:22

Charles 10:9 461:18,18462:1 470:10,10

608:22,22 609:2Charleston 388:19chart 467:5cheap 394:21 449:3check 186:13 198:1checked 506:17 534:4checks' 389:19chemical 165:6,17 234:5290:4

Chemicals 34:14chemistries 190:2244:24 250:6,7 275:25282:24 283:9 288:14288:21

chemistry 247:11,13,16247:16 249:7 283:3329:16 340:17 341:4

cherry 498:9 499:12Chicago 374:24 487:24chicken 470:13 534:15Chief 383:20child 650:16child's 560:3China 277:25choice 477:8choices 62:14Cholan 4:8 111:21,22112:24 113:1,2,10,12114:18 115:13,13,14115:17,18,20

choose 205:21 248:1303:12 550:14 565:2

choosing 560:13chose 307:7 613:3chosen 317:19Chris 6:8,11 7:17 202:18202:19 212:8,8,21,24212:24 213:1,3 215:7224:23,23 273:19,19274:7,10,10,13 311:4311:4 328:3,3 344:6,6351:3,3 403:1,1 413:9413:9,17,17 418:24,24427:13,13 455:25,25468:15,15 481:9,23,23489:6,6 492:19,20499:9,9 514:15,15524:7,7 637:6,6,15,15

Christel 481:9Christine 9:20 435:6,6435:10

church 358:23cinder 363:11Cioni 6:8 202:18,19circle 508:19circuit 141:9 300:4 303:3303:5 308:14 312:7354:16 368:15 379:20380:6 382:21,24 395:1395:2,8 397:17 401:11401:20,22 405:11,12405:12,15,19,20407:21 409:15 410:3420:3,3 447:19 469:1470:19 498:12,14,14505:9,20 506:1 507:21522:11,12 539:12,13541:16,24 542:22

543:14 544:6 551:13584:20 609:8

circuit's 509:24circuit?' 505:5circuitry 390:15circuits 300:6 303:1380:10 386:4,22398:14 403:9 404:9,11405:13,14 406:15409:24 445:15 487:25541:15 551:14 642:2646:22

circumstances 366:9412:18 425:9

circumvent 541:8603:18

Cisco 332:17 564:11648:10 654:10

cite 359:23cited 354:10,13 356:23376:1

citizens 397:13city 31:4 187:11 387:4clad 455:17 456:8458:21 459:14,17,19460:7,11,22 461:1,6461:14,20,22 462:8,9462:23 465:24 466:10466:19 468:20,21,23469:3,6,9,17,20 470:6470:11 472:19,21,22473:2,15,15,21,24,25474:3,9,13

claim 384:19claims 88:21 149:11clarification 122:19199:19 204:15,18492:20 644:20,22647:4 656:14

clarifications 564:14clarified 42:17 115:6225:2 494:18

clarifies 111:15 123:16clarify 82:17 112:24123:25 134:10 197:12197:20,24 204:21206:10 270:1 298:22365:6,8 568:3 603:14603:19 612:25 645:13655:7

clarifying 474:20clarity 45:12 111:5173:17 297:13 327:18366:13 531:12 533:7543:3 558:7 576:25604:5 605:18 650:10

Class 88:7,9 466:22528:17 530:25 531:23576:18

classes 471:4classification 48:2,3classified 55:23 515:17clauses 276:3clean 149:9 152:22155:17 160:3 174:6565:2 653:20 658:15

cleaned 148:20 150:12171:5 512:16



Page 8

cleaner 154:19 497:3cleaners 154:22cleaning 148:21,23,25149:5,6,11,13,14,19149:22,24 150:5151:16 154:21 155:14160:13

cleanliness 377:10Cleanrooms 32:14clear 45:1 61:1 63:6,1063:12 72:16 180:14183:24 210:7 233:11268:11 288:12,17302:25 316:17 348:7432:22 502:24 505:25507:19,22 508:18,19509:12,12,20 510:7512:17 515:16 517:3552:19 563:5 605:9606:3 639:3

clearly 57:4 61:7 71:15117:2 136:1 167:7288:20 297:2,23298:19 309:21 410:2436:4 437:14 440:21449:1 459:17 525:1533:10 558:18 577:10

Cleveland 164:14client 111:23 113:4clients' 390:7Cline 7:11 302:8,8535:21,21,24 536:2549:14,16,16 559:15559:17,17 563:2,16564:13 569:25 570:1,1577:21,23,23 579:5

clip 429:5,7 430:1clips 425:14clock 331:22,24close 18:15 19:10 38:840:24 53:3 65:12 92:495:7 97:24 99:22101:18 103:14 106:13117:24 125:8 132:5143:23 157:18 190:22227:1 292:6 339:15371:11 400:6 411:24428:8 464:10 474:14479:22 503:24 526:5536:23 545:12 546:1555:16 556:5 566:20573:9 583:14 584:1589:13 593:7 596:10599:18 611:25 624:12628:1 633:19 636:23640:7 643:17 659:10659:24

closed 38:6,9 40:22,2553:4 65:13 70:2084:16,17 92:6 95:897:25 99:23 101:19103:15 106:14 117:25125:10 132:6 138:9,10143:24 157:19 168:4,5176:4,5 211:2,23227:2 240:18 253:13253:14 254:12,14263:12 272:21,22

273:10,11 291:17,18292:7 304:17,18 321:4321:5,16,17 339:5352:17 361:12,13362:1,2 370:21,22371:12 378:20,22379:10 399:18 400:7411:17,18 421:1,2,14421:15 424:12 428:9430:18,19 439:12,13449:21,22 450:9,10453:6,7 457:22,23464:11 475:17 476:4,5479:23 493:15,16501:9,10 503:25504:11,12 511:11,12520:8,9 526:6,18,19536:24 545:13 546:2555:17 556:6 566:6,7566:21 572:22 573:10583:15 584:2 589:14593:8 596:11 599:19612:1 624:13 628:2633:20 636:24 640:8643:18 659:13

closely 180:7closer 87:7 187:6 520:16clothing 31:13 146:7,21148:18 149:9

cloud 165:15Club 21:21clue 505:23 509:2CME 652:23CMP 297:1,20,21 298:4308:3,5 309:15 327:1327:16,20 343:4,12355:12 416:4 433:16434:2 563:3 564:12,13618:18 638:18,20,21641:18 642:3,13647:17,19,21

CNE 14:9Co- 201:24Co-Chair 261:17Co-Panel 425:24 562:10Coast 87:5 88:19 90:296:20 97:7,13

cobalt 252:11code 21:17,25 23:16,1723:25 24:10,18,21,2425:23 26:10,18 27:2,527:13 28:3 30:2,6,1731:6 32:4,19 33:3,8,1968:14 69:17 81:19,2283:9 105:5 158:23162:8 167:18,19170:20,21,22 172:12177:21 178:13,20,25179:6,14,22,24 180:2180:6,7,12,13,14184:10,19 187:2,8,21188:4,17 189:10193:15 195:12,12,13196:12,14,15 198:25202:24 204:10 205:12205:16,17,19 206:22206:25 207:25 208:14208:15,22 209:6

217:10 218:25 219:7219:10,21 222:8223:14,16 235:7246:16 249:22 250:16257:5 258:9 261:9271:25 274:19 276:4277:6 281:5,8 284:3,8286:10,18 292:22293:6,20 294:1 296:19296:19 300:18 309:20313:3,14 316:3 317:13317:17,24 318:16,18326:16 328:6 329:5,9333:5 334:8,11 335:4336:5 341:8 342:25344:15 357:20 359:3,5359:25 364:13,20366:14 372:9 373:5376:12 381:5 384:21389:9 390:12,23391:10,10,13,19,20,21391:25 392:11,20393:1 408:17 410:17415:10,11,23 417:5,9419:15 422:12,12,13422:20 429:19 432:1,7432:11,11,12,15,18,19432:23,25 434:2 436:5440:18,21 442:13444:8,9,15 446:4,13446:14,23 451:13,20454:25 455:1,2,13,16456:12 458:19,22459:7,8 461:5 463:15467:13,14,21 472:18473:4,18 478:17,18,22482:24 483:2,5,10,24483:25 484:5,8,11486:24 487:7,24489:10,13,14,16 491:2491:22 492:25 494:12494:25 496:19 502:13507:13 508:4 512:22515:11 516:23 517:1,5517:7 519:14 523:14524:21 525:10 531:20533:11 534:15,20535:8,12 538:3,4539:3,15 540:9 543:3543:22 547:9 548:18548:21 549:14 551:9552:18,18 553:19,19559:14 560:5 561:24563:7 565:12 568:2,3568:20 569:5,11,24571:20 577:21 579:23585:13,17,20 587:23590:25 591:3 592:12594:18 595:17 597:19597:22 601:12 604:18606:3,5,9,10 609:4610:12 615:6,13617:21 618:9,12,13620:22 622:4 625:16625:20 626:10 628:24629:5 631:1,2,9 633:1635:4 638:14 641:14646:5 647:6,13 649:23

649:24,25 650:10651:4 653:8 654:15655:9 660:5,6

code- 21:25 307:2343:22 359:19 615:9

code-making 22:21 23:128:5,6,7,11 30:18,2031:5 296:7,24 298:19299:7 302:9 303:21307:8,17 310:8 312:5316:25 317:21 326:20343:3 345:14,14 355:3355:8 365:24 368:19368:21 375:12 376:20381:9,11 402:7 404:21404:21,24 406:7 407:1407:4 414:15 418:19423:12 433:6,13 455:6456:2,3,10 467:17468:18,18 469:15474:10 478:21 484:4484:14 490:21 495:5502:17 507:16 512:25513:3 514:7 523:6,9523:17 530:6 540:3549:17 558:22 559:18570:2,13 577:13,25590:22 598:6 601:14601:15,15,18 602:17602:23,25 604:16608:20 621:13,15649:24 652:24

code,' 205:12 260:7codes 25:16 68:15 83:3135:16 172:17 178:12178:17 188:3 202:24207:6,8 212:11 213:4213:19,24 217:11219:24 224:1,6,9,15224:18,24 265:12268:3,4,13 271:5,19273:21,23 275:1 276:5277:19 318:23 330:16347:2 363:13 374:9389:17 418:7 431:13443:8 461:11 468:9484:23 485:21 487:20503:7 542:10

Cogburn 293:10cold 395:7colleague 115:15 598:24608:18

colleagues 654:24collect 382:19 383:9collection 52:9color 472:13 474:20Columbia 43:5column 126:11,14,17127:9,24 128:5,7,8129:2,8 131:17 201:20474:15 630:21,23

columns 127:1,18 129:5466:14,16 467:20,25470:1,2,2 473:22479:4

combination 384:10586:11

combined 629:18,18

combines 14:10 258:16combustible 108:1110:5 112:17 113:15127:11 130:13,14137:20 486:7,18 487:4488:4

combustible' 127:10combustible/noncom...111:9

combustion 109:15114:13 513:13 524:1561:10

come 62:1 74:18,23,2478:12,21 86:22 90:13143:4 201:9 226:9238:8 280:15 281:18282:14 284:11 286:7289:8 314:17 358:15366:2,13 373:17 390:8435:13 465:4 477:21494:10 506:9 517:25526:24 576:5 610:14650:22 652:21 653:11655:14 656:11

comes 142:22 206:3288:2 303:4,17 506:2550:19 560:1,8 585:5610:24 620:8

comfortable 42:23 204:5coming 38:11 58:7 65:2591:4 161:2 166:12308:1 318:1 351:19367:8 449:2,3 452:3514:11 654:21,22655:10,15 656:10

commend 283:17 619:1comment 37:20,2140:10,12 45:3,6 52:1452:22 66:22 67:1,1067:16,21 70:7,1472:14 76:9 84:9 86:986:12 91:18,23 92:1592:19 94:21 95:1,1895:21 97:11,18 98:1098:12 99:11,16 100:8100:10 101:8,9,12102:4,7 103:3,9,25104:2 105:20 106:7108:14,15,18,18 111:4117:8,9,18,18 133:24134:1 135:25 137:22138:3 157:5 160:20178:3 180:3 191:11198:5 205:8 211:16212:14,17 220:8,19225:20,21 226:1,11,20231:5,8,18 232:13,14232:17,18,19,22,23,24233:2 234:20 239:10239:12,12,16,20240:11 242:3 243:16244:17 251:7 254:24255:1 256:23 258:15258:21 262:25 263:5263:24,24 265:16,19266:1 270:12,15,17275:8 276:7 277:7282:19 283:19 297:14



Page 9

304:7 306:21 309:13317:8 337:10 338:12341:7 348:20,21379:22 380:1 381:19391:23 398:7 399:25408:20 409:1 414:10423:25 427:16,22431:3,6,16 432:14434:10 438:25 439:6439:23,25 440:10443:13,15 447:11,14448:2,8,13 450:3,19451:1 452:20,25 454:4454:7 455:7,9 457:10457:17 458:6,10463:23 464:4 465:11465:15 471:15 475:1475:23 476:15,19478:12 479:10,17481:10,13 484:25488:23 489:8,17,18490:10 492:18,22493:4,10 496:25504:18,20 510:19511:5 514:23 515:2,8517:13 519:22 533:7540:21,23,25 544:4563:25 567:7,13,17568:1 573:3 575:5,7583:20 589:2 599:6611:13 612:11,15621:10 623:25 624:1,6628:11,13 631:16633:7,8,13 634:8,13635:24 636:11,12,17638:20 639:21 640:17640:19 641:5,8 642:4643:5,11 644:11,14646:5 648:21 656:19656:25 658:3

commented 271:14commenters 405:6commenting 167:5comments 19:16 22:1052:15,18 64:23 70:971:9 84:5 89:7 91:1994:22 97:12 99:12110:20 124:20,21,23129:9 137:23 143:12143:14 157:2,9 167:12167:14 171:19 175:13178:1 179:25 183:3191:19 220:17,20,23220:25 221:3,12,16,18224:2 225:23 226:2,7232:20,23 237:11239:5 246:13 249:19256:10 263:20 268:8275:15 277:4,9,11,12287:23 289:3 307:10309:8,13,17 310:8,12310:22,24 311:8 331:3331:7 337:7 338:17352:1 362:25 383:19404:20 413:4 414:2,16415:11,12,19 417:12417:18 424:1 451:16457:11 463:24 470:14

479:8,11 493:5 496:11496:17 500:23 510:20523:1 531:7,8 532:23533:12 536:12 554:7562:15 563:3,15579:20 585:7 586:12590:16,23 592:21594:12 595:23 597:13603:3,7 605:21 611:15618:2 620:25 625:11627:12 635:20 636:13638:7 639:23 643:6645:8 647:9,20,22656:20

commercial 85:23 87:1989:16 91:8 96:23129:10 201:12 213:11345:4 367:15,16447:21

commercially 152:1274:25

commissioning 27:1129:23 183:15

commissions 206:6commitment 283:20committed 178:14295:16 382:11 418:15441:7

committee 14:12 15:115:23 17:8 19:7 22:222:20,25 23:17,1924:4,20,25 25:1,3,4,1125:12,13 26:4,22 28:328:16,22 29:16 30:2,630:16 31:18,23 32:333:4,5,7,12 34:3,13,1834:19,20 36:21,22,2442:12 43:1,3,4,5,19,2344:3,17 45:18 46:1353:22 55:8 61:18,2265:2 67:19 68:13,2068:20 82:25 85:3,5,785:16,20,25 88:1889:2,25 93:15,1896:16 99:4 102:20105:5 107:5,7,8,10,18107:22 108:3 110:10111:2,7,25 112:8,14112:22 114:10 116:8117:13 119:22,23,24119:25 120:9,13,18121:23 123:21,24128:15,24 129:15130:22,23 131:1132:15,17,17,20,24133:4,8,13 134:16135:20,22 136:12,12137:7,24 140:7 143:12144:7,9,9,10,13,22145:1,5,24 146:5,7,8146:10,19,24 147:5150:21,24 151:1 154:2154:16,18 155:20156:12,23 157:3 158:4158:5,6,7,11,18,21159:21,25 161:7 162:2162:10 164:6 167:13169:2,3,4,6,16,19,24

170:20 171:10,23175:15 176:13,14,15176:17 177:1,5,9,21179:23 180:12,23181:1,2 182:10,16183:2,3,11 184:1,24187:3 191:8,9,20193:14,14,15 195:11195:12 197:5 198:11200:25 206:18 208:14208:15,16 212:10213:4 215:14,20,25216:13 217:5 218:20220:12,18,21 221:6,7221:11,15 222:9,19226:3,5,8,12 232:13232:19,21 233:1 234:7234:11,16,19 237:9,10239:11 242:5,19 243:3243:18 244:10 245:16245:23 246:24 249:13249:14,16 251:13252:1 255:11 258:4,15258:20 259:12,17260:3,4 261:17 263:25265:17 266:3,12,19,22267:17,18,23 268:12269:10,13 270:24,25271:12 273:24 274:16275:6 276:7,13,25277:11,16 278:4,16,21280:17 281:24 282:11283:11,17 285:11,12285:20 286:8 287:14289:8 292:21,23 293:8293:20,23 296:14,15306:21,25 307:6,9,12310:5,7 317:15 326:6326:10,23 342:24345:14 347:14 355:2359:3 364:19 373:4374:10 381:4 391:15402:6 404:20 414:4,8415:18,22 417:1,6,10417:12,13 422:13423:4 425:20 429:17431:19,20 433:5,14,23434:7,10,12,20,25435:16 437:9 442:12443:21 451:19 454:24459:6 461:12 467:12468:10 478:16 483:24484:24 491:16 494:12494:24 495:7,8 502:12502:19,20,24 507:12512:21 514:5 522:25523:3,8 530:5 531:10542:23 544:4,5 549:10558:22 559:13 577:13577:20 578:13 585:4,6585:9,13 586:7,8,9,15590:15 594:11 597:11602:16 604:19,21605:16 606:13 615:5617:11,22 618:8,17625:10 629:12,16631:8 633:1 635:3638:6,10,22,24 641:13

645:7 647:12 652:25Committee's 44:7 46:755:1 67:20 82:15 85:486:4 88:12 93:1496:10 98:25 100:22,24104:13 108:7 111:1120:22 122:15,17128:12 133:18 135:19139:25 145:9 147:10150:19 159:5 161:20161:25 162:1 170:4171:8 177:13 189:11215:6 232:15 233:15233:21 258:13 267:14283:20 294:7 326:4

committees 24:14 25:1426:10,12,16 27:2,6,927:16 28:5,24 29:4,1829:22 30:3,18 31:7,931:12 32:6,9,20 33:233:14,20,24 34:8134:14 148:17 158:25162:22 164:12 172:10256:9 345:13 389:10554:16 586:15 618:18619:1

commodities 49:25commodity 48:3common 204:10 289:16290:3 302:17 386:19397:10 508:24 605:24645:21 649:1

commonly 489:11 622:6commonsensically164:25

communicate 506:4communicated 251:21communication 638:25642:1,2 654:20

communications 248:16637:21 639:4 645:17645:19 646:22 652:11652:13 656:9,15

communities 196:5community 24:23 81:1982:2 165:19,22 208:20235:19 388:11 547:8548:5

companies 149:8 152:8182:20 186:5 195:1567:4 603:2

companies' 195:18company 17:13,16 45:1347:10 112:25 113:1159:25 164:13 177:20186:21 195:23 196:1204:17 205:8 228:16247:6 344:12 405:4441:21 535:3 567:3,24

compare 221:5 531:6compared 251:1 270:5363:9

comparison 446:4compatibility 455:15compatible 398:10486:11 561:18 563:22

compelling 135:23complete 13:19 83:4

171:11 245:1 277:15303:5 307:9 415:19425:20 522:25 536:5585:6 590:7,15 594:11597:13 598:9 602:5625:10 638:7

completed 23:1 154:5completely 51:19 52:6108:25 137:6 204:5244:23,24 285:5 331:8369:24 605:3 613:2628:20

completing 391:6completion 306:24complex 152:2 155:23178:18 410:22

complexities 568:17complexity 171:13247:11 248:5,15 249:7467:23

compliance 22:22 46:252:2,7,10 109:2,18149:16 247:11 248:18249:7 274:19 324:2,11327:13 335:15,25336:10

compliant 323:25complicated 96:18353:7,18 384:11404:14 588:9

complication 96:18complied 335:11 604:3complies 116:23 134:12336:7 571:20

compliment 475:2comply 115:25 206:9,21206:25 236:23 250:18279:11 303:15 308:7344:20 443:7 548:6550:17 552:20

complying 461:5component 110:8312:19,20 500:17568:17 571:10,11

components 141:8311:12 315:18,19403:17 487:5,11 568:6568:8,11,13,16,24584:20,22 588:8 590:6590:6 597:4

composed 443:21compounded 444:22comprehensive 23:1179:16 215:17 277:21277:22 303:22

compressed 191:23compressor 395:14comprises 298:11compromised 579:2compromises 578:9compromising 616:25computer 389:25computers 198:19computing 571:9concentrate 274:24concentrated 279:14concept 53:23 121:20122:1 242:24 243:5



Page 10

250:7 266:5,16 269:6297:8 302:17 315:15414:12 518:13 647:24655:15

concepts 195:10 206:2223:9 260:3 270:24286:17 318:8

conceptual 327:3concern 57:6 88:24142:20 163:17 181:6182:22 194:16 199:14217:25 219:12 246:8284:16 295:15 300:6316:18 411:1 469:2509:13 518:25 529:12529:16,17 531:21588:1,1 592:15 605:15

concerned 12:13 35:8238:2 360:10 408:17607:20

Concerning 305:24concerns 20:23 42:4112:6 129:10 147:19148:5 156:3 203:2214:12 216:1 275:5295:18 317:10 374:23414:22 443:3 483:9513:6 514:18 550:5578:8 605:7 616:14617:10,17 618:18

concert 326:24concession 150:9 151:2concessions 339:15411:24

concise 507:20,22conclude 18:13 284:19523:24

concluded 434:13 523:3585:9 638:10

concludes 25:9 523:24660:12

conclusion 41:21541:12 590:17 594:13597:15 625:12

concrete 363:12 366:4,6367:13 368:24 369:19

concurrently 156:10condense 160:25condenser 372:12373:16,18 375:2,3

condensing 373:13condition 57:5 60:3,1160:12 341:17 348:6,9348:20 541:9 580:2627:1

conditioning 372:11,13372:21 373:15 486:17

conditions 104:16131:18 185:13,15257:1 300:13,16311:13,14,16 341:22360:16 365:10 470:23470:25 471:1 486:17486:19 531:22 532:1548:15,23 558:5 559:4564:5 576:14,23

Condocell 460:19 473:9conduct 13:23 18:7

50:21 87:24 252:15conducted 126:11153:14 245:24 246:4,8250:23 252:5 437:21

conducting 15:5 35:6163:18

conductive 438:21conductively 577:4conductor 354:15 377:3461:1 462:12 466:20469:12 470:20,22471:8,11 472:21 602:2609:8 610:4,18 611:8

conductors 201:3459:14,17,19,21 460:7460:12 468:23,25469:7,9 471:1,2,6472:25 519:4 564:17586:25 587:1 611:2,3611:4 613:9 614:4,5616:4,18 623:3,4

conduit 440:14 441:2445:2,5,7 446:5,9447:16 448:25 449:4488:1,15

conduits 440:8,24442:20 444:17 445:14445:17,24 446:25449:1 451:12

conduits.' 447:17conference 190:13conferences 79:6configuration 192:16280:10

Confined 34:8confirm 37:14confirmed 534:6conflict 197:22 295:25307:6 405:17 472:18559:2 618:12

conflict.' 561:21conflicting 296:3 434:22512:5 547:17 548:3,25644:21

conflicts 180:7,15 188:4194:18 257:10 296:16342:23 355:1 364:18373:3 381:3 402:5413:24 414:24 425:18429:18 433:4 442:11451:18 454:23 459:5467:11 468:22 483:23494:23 502:11 507:11522:24 530:4 549:11552:16 557:15,21559:12 575:21,23,24577:19 585:11 590:20594:17 597:18 602:15606:7 615:4 625:15631:7 635:2 638:13641:12 647:11

conforming 570:8confronted 385:1confuse 106:24 131:4,4315:14 479:4

confused 73:19 89:11113:11 478:24 630:7

confuses 127:17 130:19

confusing 113:19127:15 311:10,22317:20 473:20 516:6641:20

confusion 79:12 114:23174:15 194:19 295:10315:12 317:9 322:20344:10 392:23 422:16492:8 515:24 543:2548:4 552:15 568:4603:4 607:20 612:24644:23 646:17 647:4653:14,17,21

confusions 531:13congratulating 23:8 25:6Congressional 547:22conjunction 16:4 36:9615:17

conjured 139:14connect 295:14 548:11613:9 651:12

connected 192:11 248:9295:20,23 299:12300:8,14,21,22 301:8346:4 404:12 560:17577:4 611:4 618:6623:4

Connecticut 32:19 160:4connecting 301:3551:15 564:18

connection 554:11,21603:15,17 620:11

connections 601:17connector 474:4 502:4Conrad 4:15 140:16,16141:21

conscious 234:7consensus 16:6 20:1836:11 150:23 178:21221:2 273:22 307:8310:21,25 319:4

consent 145:21 178:22consequence 247:14279:10 342:2 653:21

consequences 53:2554:23 171:18 282:11282:22 283:7 301:3341:9 403:5 448:10551:15

consequently 112:14,21115:24 116:8 134:22401:16

conservative 129:19consider 200:12 214:25232:13 278:19 279:18286:1 303:19 334:9,19413:2 468:18 550:21557:22 560:10 578:6579:9

considerable 654:12considerably 403:8consideration 13:2515:6 42:25 85:3 89:591:13 107:5 119:21121:8 132:15 144:8146:5 158:4 169:1176:13 199:9 204:3243:22,24 292:21

298:13 364:6 383:12385:18 388:14 398:19515:12 550:2

considered 14:13 61:1866:13 111:6 114:8116:24 127:10 145:20165:16,18 183:3192:14 214:17 226:8227:18 228:10,24229:13 232:17 242:2,9247:2 264:18 285:22285:23 312:6 313:22340:10 363:25 403:21413:21 434:10 440:20480:20 481:2 495:13516:4 521:5,20 537:7568:2 573:20 574:12580:7 613:23 623:21637:19

considering 242:19529:18

consistency 306:13451:13 630:25 633:3

consistent 21:18 102:16109:4,6 112:19 114:7114:22 135:15 243:7244:1 266:6,25 306:12306:19 327:3 523:5559:4 568:14 569:12569:13 618:9 629:15630:22 632:8 647:5

consistently 148:21248:24

consisting 43:24 85:21107:23 120:14 133:9145:2 146:25 158:22169:20 177:6 293:25

consists 486:25Consolidated 199:25constant 384:24constantly 259:9constituency 549:2constitute 310:25502:25 608:15

constraints 200:23constructed 116:15179:17 486:5 513:5519:14 603:11

construction 33:4 112:1112:7 113:13 114:3115:7 116:3 203:5369:4 372:18 376:11376:13,15 482:13484:9 485:14,16,17,18485:19 486:11,21,22487:19 488:25 492:11492:13,24 531:5 533:8610:6

constructions 484:12486:4 529:8 533:1

consult 358:10consultant 34:16 113:2600:2,14 607:4 612:10612:21 622:18 656:4

Consultants 32:4 113:2115:14

consulting 107:8 346:24358:6 393:23 461:19

470:11 608:23 652:23consumer 280:8 384:16460:24

consuming 22:24328:16

contact 268:25 355:16373:18,20 444:18500:13 513:13

contacting 165:18contactor 597:4contactors 584:21contain 268:15 280:7309:14 311:23

contained 43:8 85:10107:13 120:3 123:12132:23 144:16 146:13158:10 169:9 176:20241:20 244:1 274:15293:3 326:8 533:3

container 259:1containing 161:17 260:8280:9 343:14

containment 448:6contains 46:19 160:21328:13 403:14 438:1,7

contaminants 148:24,25151:17

contaminated 148:19contamination 150:13150:16 154:8

contemplate 557:13575:19

contentious 289:3context 112:9 128:4,5129:4,17 268:24632:10,11

continual 235:10continue 178:11,17223:22 257:21 275:2291:1 357:15 453:12476:24 560:21 592:6595:12 599:1 627:4,5639:15 646:14

continued 148:20246:25 327:13 368:22

continues 19:2 357:12continuing 284:11Continuity 29:5continuous 25:13528:22 529:6,17533:14,16 534:11587:2

continuously 260:11,12346:17 470:23 557:23

contractor 83:21 355:15384:16,17 388:22

contractor's 396:19397:1

contractors 52:4 82:10313:9 367:6 384:22,24426:3 429:23 432:3,6432:22 441:21 442:17451:24 495:4 502:17631:13 635:8

contrary 127:17contrast 280:2contribute 112:13285:25 414:21



Page 11

contributed 380:23contribution 16:5 21:936:10

contributions 21:2,4contributor 88:24 386:1contributory 90:3control 58:1,8,11 124:13150:16 154:8 181:7,12182:19 195:17,20197:17 204:23,25216:4 222:5,7,7248:15 250:17 257:2279:23 285:4 312:18343:15 425:12 466:21466:21 614:10 618:20

controlled 54:13 163:12controller 586:12,17,20586:25 587:4,7

controllers 584:19586:10,13 587:18588:8

controlling 586:19controls 57:17 69:4121:24 191:16 586:17

convenience 118:13168:16 580:8,17

conveniently 302:1convention 12:16,19,2414:2,2,18 35:10,12,1866:12 145:19 227:17228:9,23 229:12264:17 340:9 480:19481:1 521:4,19 537:6573:19 574:11

conventional 148:23converging 221:1conversations 42:18185:6 456:4

convey 644:24Conveying 107:6,19conveys 111:12convinced 91:3Cook 293:12cooking 87:21 387:17cool 582:18cooperation 185:4cooperatives 202:2,5,13coordinate 60:23 184:20coordinated 298:11,17coordination 179:14COORDINATOR 2:9copies 432:6copper 455:17 456:8458:21 459:14,17,19460:7,11,22,25 461:6461:14,20,20,22 462:7462:8,9,22,23 463:19465:24,24 466:9,10,19466:19 468:20,21,22468:23 469:3,6,9,17469:18,19,20 470:6,11472:19,21,22 473:2,2473:15,15,16,21,24,25473:25 474:3,9,13648:13

Copperweld 454:2,13456:16 458:4,14461:20 465:9,20

470:12 476:13 480:9Coppin 11:20 653:24654:4 655:4,4

copyright 137:3cord 502:2 538:16539:10,11 544:10560:18

corded 354:19core 444:14Corporation 202:20444:7

correct 46:9 56:6 58:1559:6 71:12 196:12198:4 199:19 251:17280:18,21 286:20306:3 342:15 353:21413:5 414:25 417:24481:22 564:3 567:14581:13 628:17 636:7,9653:17 661:13

corrected 54:22 58:1858:20 60:16,25 274:22

correcting 454:17456:21

corrections 455:10correctly 40:6 543:23588:21 606:10

corrects 150:9correlate 68:11 195:13307:5 417:10

correlated 193:12,17correlates 297:19,20correlating 22:2,20,2322:25 26:9 27:2 28:228:22 29:16 30:6,1633:7,11 34:3 36:22266:13 292:21,23293:8,20,23 296:14,15306:25 307:6,9,12310:5,7 317:14 323:3323:6 326:3,4,5,6,10326:22 337:5 338:22342:23,24 345:13355:2 364:19 373:4381:4 402:6 404:20414:4 415:18,22 417:1417:6,9 422:13 423:4425:19 429:17 433:5433:23 442:12 443:21451:19 454:24 459:6467:12 478:13 483:23494:24 502:12 507:12512:21 522:25 523:2,8530:5 531:10 537:17537:21 538:23 540:6541:11 544:4,5 545:20549:10 559:13 577:20585:4,6,8,12 590:15594:11 597:11 602:15602:16 615:4,5 625:10631:7,8 635:2,3 638:6638:10,22 641:13647:11,12 649:24

correlation 56:2 180:12296:16 310:6 330:19348:25,25 355:1364:18 373:3 381:3402:5 425:18 429:17

433:4 434:14 442:11451:18 454:23 455:16459:5 467:11 471:17483:22 494:23 502:11507:11 522:24 530:4549:11 559:12 577:19585:12 590:21 594:17597:18 625:15 638:13641:12 650:10

corresponding 114:25corrosion 466:2corrugated 431:14,24cost 47:14,16 48:6 50:24116:2 217:17 218:1314:8 364:6 384:15442:6 513:8 616:10

costly 384:23 397:24costs 47:24 223:2 276:1359:14 562:22

Council 2:4,10 15:12,1615:21 16:8,10 20:3,820:12 36:13,15,1837:3,6 44:7 86:3 108:7118:18 120:21 133:17145:8,22 147:9 159:4163:21,21 168:21170:3 177:13 215:12233:16 267:20 276:20278:6 294:6 309:12329:16 340:17 341:4417:22 431:18 433:24433:25 436:3 437:11453:14 498:8 629:11

Council's 16:12 195:12Counsel 2:12 20:15count 74:19 75:20,2076:13 241:23 658:12

counted 192:6counters 74:18,23countless 20:21countries 116:6 136:10140:4,9 179:3

country 82:9 90:24,2591:6 202:10 204:9225:9 286:19 319:25364:3 482:13 487:22505:7 507:3 603:5

country's 202:5counts 336:23county 206:5couple 51:9 76:17 130:6165:4 167:2 180:4182:12 193:5 198:9269:9 287:22 331:3339:11 378:8 412:17436:1 449:11 564:14607:6

coupled 513:7course 153:20 179:21456:2 629:15

court 118:13 168:16cover 45:23 183:20192:21 202:4 217:19218:12 225:8 236:1262:23 268:14 299:18380:9 396:25 534:11549:22 552:9 559:22571:15 607:25

coverage 223:18 224:18303:16 354:3 432:12523:24 550:18 560:7564:6

covered 23:22 88:1489:6 90:4,11 96:12179:20,20 182:21184:3 193:24 194:3197:13,13 217:13236:18,20 239:9 282:9297:6,22 298:7 299:12372:9 380:14 396:25415:17 459:22 500:18534:1 553:18 571:23584:18 600:24 601:21616:20 639:1 647:21651:3,8

covering 81:14 160:6197:12 236:14 262:22287:3 301:14 564:2607:13

covers 104:15 161:9232:7 233:13 299:10380:16 451:12 534:14553:19,19,22,22564:17 623:12

CPSC 380:13crackling 505:19craft 85:4,17,23 87:1588:14,17,18 89:1,1489:20 91:8,9 93:1896:13,13,15,23 100:25104:15 215:15 277:17

crafted 215:10crafts 88:15Craig 10:1 444:6,6cranked 650:12crash 552:6 571:16crashes 562:23Crawford 10:12 486:1,1crazy 47:9create 83:8 148:19 165:6165:25 194:19 257:4349:5 385:16 392:19398:9 422:16 435:14466:12 516:6 530:22548:4 559:2 605:17618:12 622:7 631:1

created 67:22 89:15165:4,24 182:17207:12,13 226:4,5257:18 265:18 277:11282:25 409:2 422:11425:18 641:21

creates 123:22 257:10330:6 344:24 345:3352:2 469:2 515:24568:2,8 647:2

creating 81:16 149:13295:10 329:25 456:20547:20 548:1,25638:21

creation 165:14credentials 14:20credible 471:11,13criteria 27:17 32:7 49:2350:7 67:13 69:22,2369:25 94:16,17 109:16

109:20 110:21,22114:20 115:25 134:15135:24 137:10,13,15149:12 150:25 151:4153:16,21 165:13166:3 252:15 286:7,14287:7 414:7,11 486:25651:13,13

criterion 110:6 135:10135:11,12 137:5,9

critical 50:5 63:20 82:22121:20,21,23 122:1,3122:3,5,8,10,11,11,12122:18,21 123:2124:10,12,15 152:20155:15 175:17 232:2289:20 328:14,19343:24,25 397:17410:20 432:23 461:23462:2,10

Cross 180:12Croushore 3:23 62:3,362:17,21 599:25,25600:12,13 607:2,3612:8,8,19,19 622:16622:17,23 623:1

crowd 78:24crush 531:4 532:25crux 608:17CSST 431:24 432:9433:11,16,18 434:1,9434:12,16,25 435:15436:4,11,14 437:11,22437:25 438:9,14,20

Cub 530:11Cultural 29:24cumbersome 182:24current 111:5 200:12217:9,11,15 218:3222:5 244:1 245:10265:12 278:24 279:3297:5 299:10 343:14348:12 377:13 383:6384:14 406:20 409:25432:5 437:22 438:6470:22 471:5 500:14507:19 523:23 528:21534:7 540:9 543:4568:2,10,12 576:19577:6 580:16 609:12609:15 610:5 651:2

currently 25:5 34:2055:16 81:10 164:1196:20 203:4 213:24215:16 231:22 236:3237:4 256:24 264:10273:24 357:5 383:4407:8 431:23 440:18440:21 444:12 466:7469:21 488:13 531:2604:22

currents 576:17curse 506:5curtail 412:18,20,20Curtis 6:24 261:15,15,23262:2,4,6 281:23,23

custom 267:18 270:7customer 47:13 202:9



Page 12

248:7 650:12,14customer's 646:9customers 202:7 580:8cycle 22:4 43:23 45:2581:2 85:19 107:21120:13 133:7 144:25146:23 158:20 169:19174:7 175:5 177:4234:16 249:18,18,19261:11 267:10 293:23312:5 319:7,8 342:14350:6 355:14 409:10414:9 419:7 433:13434:20 483:11 484:6561:24 613:8 655:12655:13

cycles 23:22 298:4355:10 654:15

cycling 219:19cyclones 112:4cylinders 160:6 161:9

Dd 122:22 436:3 508:22578:19,23

D' 508:22dad 205:11,11Dad-gum-it 320:8daily 200:11,17 308:11604:18

Dale 9:5 10:12 396:15,16396:23 486:1,1

Dallas 27:1 146:9 358:10358:11

damage 88:25 156:5276:11 335:14 384:23386:16 397:21 446:1483:4 533:16 637:25

damaged 445:5,7 538:17544:11

damaging 331:9 513:14529:19

damp 365:10 367:12368:24

Damp-proofing 363:16Dan 3:9 5:13 8:11 34:2535:2,3,4 38:13,15,1939:1,9,11,17,19,2340:4 43:16 44:8,13,2044:22 45:1,5,11 46:646:25 48:17,20 49:1651:5,11,13,15 52:1352:17 53:16 54:2556:10 57:14 59:1161:10,25 62:14,1963:2,5,13 64:8,21 65:465:21,24 66:3,8,2467:3,18 68:23 70:5,1171:8,12,14,24 72:1,772:13,24 73:2,5,11,1574:1,4,7,11,13,16,2175:18 76:16,20,2277:6,23 78:1,15,1879:2,9,12,17,20,2380:2,4,20,24 81:3,682:14 83:11,17 84:3,785:2 86:5,11,15 87:688:11 90:12 91:17,21

92:17,21 93:13,1994:6,19,24 95:19,2396:9 97:1,9,15 98:1198:16,24 99:5,14100:9,13,22 101:2,11102:5,9,19,24 103:6104:1,5,12,17,24105:1,8,12,18 106:3,5106:22,24 107:4 108:9108:16,21 110:25111:16 112:24 113:5113:21 115:2,12,16,19116:18 117:6,11,15118:9,21 172:7,8174:19,19,24 352:25353:1,15,15,22 356:20356:20 362:9,9,23,23366:25,25 371:19,19372:3,3 375:24,24554:4,4

dander 395:23danger 506:22dangerous 148:24 190:9194:21 444:20 445:4598:25

dangers 205:14 288:25Daniel 7:5 294:12,12,25294:25 546:13,13547:3,3

darned 610:21dash 534:14data 49:22,24 50:12,1850:22,23 52:8 190:14214:23 246:19 279:20282:5 283:8 286:12382:15,19 383:3,4,6,9383:11 392:24 393:8394:13 455:8,12468:19

database 90:2date 152:23 251:16270:8,10 286:24 579:9641:4,6

dated 180:10 661:14dates 267:17,18 270:5dating 130:13daughter 634:10Dave 3:21 4:16,21 59:1359:14 142:19,19147:15,15 148:4173:10,10 293:10314:25,25 369:16,16508:12,12

David 7:25 10:19 32:3,534:16,17 319:16,16336:14,14 504:17,17504:25,25 507:13,15507:15 512:23,24,24518:22,22 523:15,16523:16

Davidson 6:2 195:9,9,9199:3 206:1,1,1,12223:8,8,8 260:2,2270:23,23,23

Davidson's 260:2Dawn 2:3 12:7 20:11,1421:16 23:15 25:2126:8,25 28:1,20 29:14

30:14 31:3 32:2day 37:13 173:19 187:8188:13 201:6,14,16203:7 308:20 372:22389:5 394:8 530:21661:14

Daycare 25:1 26:13 31:7days 15:21,24 16:236:19,23 37:1 58:19256:10 388:12 491:1

DC 259:19 558:15de 364:4de- 409:16de-energize 261:5de-energizing 259:13de-icing 406:15deadline 221:9 265:22deal 87:16 182:22 185:1187:16 191:11 196:7334:7 387:13,25388:13 517:14 552:25615:15 623:18 629:10

dealers 305:15dealing 86:24 87:3,4,887:10,13 91:7 96:4,5102:14 137:17 185:12185:13 193:19 305:7307:3 333:2 345:24365:9 372:20 390:3440:11,12 484:9486:25 498:12 628:21629:7 630:12

deals 87:15,17 100:18454:15 552:10 600:16601:9,16 602:25

dealt 64:17 184:23402:14 409:5 523:9

dearly 499:16death 358:16 368:19deaths 148:9 360:4,9380:20 386:10 394:18

debatable 172:13debate 16:4,6 17:1 18:1518:24 19:1,10,10 36:936:11 37:5 43:11 47:156:11 61:22 68:2483:12 85:13 90:1393:20 97:2 99:6 101:3102:25 104:18,19107:15 111:17 118:16120:6 124:3 129:25131:5,6 133:1 136:15140:13 144:19 146:15151:8 158:13 162:14168:19 169:12 172:3176:23 216:23 234:22244:4 259:23 268:18278:9 279:4 293:5308:23 327:24 344:2356:10 365:3,20 374:3382:2 402:17,22416:15 423:8 426:15430:4 435:3 444:3452:8 453:12 455:22459:25 468:5 484:18503:3 508:8 513:19524:4 532:6 539:20551:1 560:24 570:24

579:13 585:25 591:9595:2 604:9 605:17617:3 626:3 631:24635:15 639:11 642:16648:5

debated 180:25 218:20249:16 381:13 605:19

debates 368:22debating 24:20 606:5decades 23:5 60:16123:8 214:8 245:12366:9 385:4 448:16482:2,8 552:2 618:10652:13

decide 166:12 206:8,12206:14 234:19

decided 156:12 267:23271:9 315:3 452:13470:16

deciding 110:7decision 16:12 37:3 49:1111:15 207:6 234:8,11337:1 340:1 364:7417:13,14 436:3549:23 559:23 578:2651:9

decisions 382:13decisively 298:22deck 89:21declaration 303:16550:18 560:7

declare 35:5 114:17660:15 661:11

declares 109:22decline 59:3decommissioning183:16

decrease 68:19 380:19380:20,20,21 385:25392:15,16 460:10

decreasing 242:19dedicated 181:24 182:17207:12 287:10

dedication 23:3,6 24:15deem 18:6deemed 297:8deep 542:21deeply 295:16 525:4deer 467:13deface 324:18defaced 324:23defeat 508:3defect 389:20defects 547:25 548:7defer 296:18 307:17326:16 342:24 355:3364:20 381:5 402:6415:23 425:23 429:18433:5 442:12 451:19455:1 459:6 478:17483:24 494:25 502:13507:13 512:22 523:14530:5 539:2 549:13559:14 569:24 577:21585:13 590:22 594:18597:19 602:17 615:6625:16 631:8 635:3638:14 641:13 647:12

deficiencies 54:2 58:2060:15,18 61:15 63:2183:25 516:13

deficiency 54:6,7,2155:7,10,14 57:1 58:1758:18 59:21,24 60:2,960:22,24 61:7,19166:5,7,8 347:9

deficiency' 64:13,19deficient 54:14 59:6defies 324:10define 54:2 248:12 319:8375:16

defined 94:2 112:8,14170:24 174:13 175:1198:19,19 233:15515:16 525:2 564:16569:11 580:15

defines 64:1definitely 63:22 492:25587:5

definition 60:8,10 61:4,694:3 109:10,24 110:14110:15,22 111:5,8,11111:13 112:15,19114:12 115:11 121:19121:22 122:18 123:1123:14,15,17,22285:24 306:11,24307:7 308:7,16 311:9311:21 312:1,1 313:2315:5,10,11,12,21317:10,12,16,19 318:2318:8,11,19 319:11,19319:20 326:12,25334:11 415:17 419:23422:10,11,18,22423:13 470:21 486:5500:10,18 502:7 523:4539:10,11 541:13,14542:22 543:15 557:9557:15 558:7,9,23559:1,7 577:14 585:10590:19 594:15 597:16613:8,12 623:6 625:13631:18 638:11 648:14654:22

definitions 59:25 109:4197:12 307:1,2 308:19311:18 315:13 317:16317:18

deflagration 251:16Degenais 3:21 59:13,14173:10,10 314:25,25

degradation 55:17,17,2057:11

degraded 54:3 55:856:18,24

degrading 59:1degree 123:9 128:22466:17 471:4

degrees 346:10,11,18466:16,17 471:3,3,3474:12

déjà 427:1delay 74:16,21 344:25568:19

Delaying 150:5



Page 13

delays 150:10delete 142:13 269:10306:23 473:6 516:15605:22

deleted 326:7 538:10578:21,24

deletion 529:20 538:2613:5

deliberated 617:23deliberation 563:8delineation 179:11deliver 586:23delivered 393:9delivering 564:22,23delivers 586:18Delta 419:19demand 54:6,6,9 55:1855:19,22 56:20,21,2557:4,11,20,21 58:3,658:10,24 59:4,7 61:2164:4

demarcation 184:13195:2

demonstrated 152:20denounces 541:3dense 203:16department 31:3 33:10146:9 153:9 154:20179:14 186:9 189:8

departments 148:7207:5 386:9

departure 123:22depend 58:5 148:11181:19 328:9 451:10

depending 137:18206:19 349:2 587:9

depends 122:1 328:23394:8

depiction 348:3deployed 298:8deployment 645:2depressurize 165:16deprives 116:12depth 316:6 410:23describe 45:13described 90:7 154:1233:11 243:3 247:19266:3,19,22 632:15

describes 126:19describing 609:24description 231:19233:17 236:17 237:4270:13 472:10

descriptive 311:18631:18

desert 285:8 287:9deserves 524:15deserving 23:7design 49:22 50:7,2167:11,17 127:14129:18 130:10,11171:21 260:10 284:7284:23 316:7,11346:13 369:4 515:14515:15,18,20,24 517:1518:12,13 522:10,12522:16 524:22,25525:2 543:4

designated 16:19 66:10177:23 205:1 227:14228:7,20 229:9 480:16490:2 534:5 573:17

designation 129:14designed 163:1 258:23298:16 349:2 410:20561:19,19 626:23

designee 17:4designer 518:10designing 285:2designs 200:12 248:20desired 129:16desk 13:10 36:3 42:2desks 89:17desperately 319:18despite 32:1 570:9destroyed 324:23,24426:9

destroying 328:19destructive 436:9detail 22:14 46:20 61:16126:25 131:3 194:2284:18 495:8

detailed 96:22 126:21285:13 494:18

detailing 284:14details 13:10 36:3126:19,24 127:21130:17 193:19 194:1309:20 496:25

detect 386:15 389:24detected 258:25 259:3detection 29:20 163:11256:22,24,25 257:25258:20,22 259:4,6260:8,13,18 262:14,19

detects 580:15determination 15:118:22 111:9 310:9440:25 442:5 523:20

determinations 37:8determine 47:14,2248:13 60:24 114:11115:9 135:9 250:18259:13 286:14 317:15328:24 369:2 382:20383:8 646:23,24

determined 14:15 18:24206:5 226:14 303:11335:16 425:21 484:8487:11

determines 586:23determining 50:8 317:18devastating 397:23develop 20:22 91:2104:10 141:25 151:25163:22 178:17 183:17197:18 215:13,17267:24 276:21 277:20278:19 301:7 438:20517:12

developed 89:8 96:7,21105:15 135:7 149:7161:6 167:1,6 180:8181:18,23 188:17214:21 220:10 269:18269:22 271:7 277:1,20

308:16 317:12 549:1developers 267:25developing 21:5 81:17149:5 153:6 183:15,17203:4 392:24

development 13:15,1713:24 18:5 20:18 21:121:10 24:15,16 25:1626:2,21 27:21 28:1429:9 30:9,24 31:21180:13,14 213:6215:11 220:15 232:12238:18 242:22 266:9268:7 276:19 278:22296:17 309:18 382:12392:25 414:1 486:8569:8

developments 96:22569:14

develops 455:11,12device 16:18 37:2340:14 42:24 73:22398:9 404:15 408:1571:14 614:16 646:9

devices 13:14 16:2336:6 37:14 73:3 74:1280:9 298:15 299:18300:11 343:15,15,15382:25 384:15 390:1401:15 403:7 406:11406:13,14,20,23 420:2455:16 470:19 502:21502:22 558:16 588:9588:10 598:23 626:13626:22

devices' 420:5devise 541:6devote 22:8diagnosing 188:10dial 12:16 35:10die 376:25 377:5,18differ 409:13difference 222:2 248:3279:5 367:23 436:16452:3 554:18 613:4634:23

differences 135:24136:3 202:22 247:18436:10 438:18

different 50:17 79:1481:13 89:13,14 108:25116:7 137:9 139:18140:24 141:10 184:14184:25 185:13 191:22192:4 201:8 202:25206:20 219:2,19,19222:4,4 232:22 236:11268:24 286:3 306:17306:17 307:2,22 308:8316:10 317:13,21360:15 389:9 403:8405:9 406:11 427:18465:25 466:5 471:13473:17 474:11 491:24494:10 500:17 506:16552:4,6,17,18 554:19562:25 563:21 568:22571:13 575:20 576:6

584:20 590:6 597:2601:13 604:23 605:4607:6 617:11,13628:20 645:16 648:15

differentiate 398:11differently 482:22differs 312:2 557:14difficult 184:12 216:16235:6 274:16 280:21307:19 328:18 357:8397:16 460:14 528:23571:7,13 648:20

difficulties 42:4 74:2278:8 646:17

difficulty 50:8 190:14523:22

digest 151:25 152:10digging 390:5digital 406:23diligent 216:13 563:8diligently 215:14 277:16dilution 110:3,5ding-a-ling 506:13dire 448:10direct 182:19 268:7295:25 374:19 507:19

directed 172:19 215:10568:7

direction 12:21 35:15153:19 156:22 175:3238:4 342:9,10 348:8620:9 644:3

directions 341:24directly 15:11 145:22183:13 205:2 215:23302:13 447:11 544:5,6

Director 296:22 431:13Directory 13:20 14:4directs 215:2 257:2disabilities 13:7 35:25disabled 397:13disagree 348:2 435:16621:23

disagreement 279:1disallow 529:3disapproval 190:25disapprove 281:2disassemble 571:19disaster 29:2 394:8discarded 394:10discharge 27:17 163:12discharging 237:16disconnect 236:10580:3 609:9,17 613:21614:3,13 616:6,17620:15 621:6,8 622:2622:3 623:3,14

disconnecting 216:8601:3,6,10 602:3607:12,15,16 613:2,3613:16,20,23 614:11614:12,22 620:12623:5,10,16,17,19,21

disconnection 576:20587:3 618:24

disconnects 357:19,24404:10 579:22 603:16613:22 614:16 615:21

616:1,15,21 618:9,25621:3

discovered 55:9 603:4discrepancies 629:21discuss 288:25 373:23464:17 524:23 597:24625:23

discussed 42:8,9 61:1696:3 102:21 134:13155:20 162:7 198:11202:21 218:9 249:17249:19 285:22 304:25385:24 429:24 442:24443:14 452:2 469:23479:5 484:13 495:8546:6 569:6 574:15,16602:7 603:9 618:10

discusses 438:15,17,18discussing 129:2 162:22175:9 237:11 249:25435:15 535:13 550:6554:16 621:12 629:21636:3

discussion 16:13 17:937:20 40:11 44:952:14 53:9,19 55:364:22,25 66:16,1767:4 70:6 73:17,2080:5 81:7 84:22 86:686:16 91:18 92:11,2294:20 95:14,24 97:1098:6,17 99:9 100:3,14101:7,24 102:10 103:2103:20 104:6,21105:19 106:19 108:10108:22 117:7 118:5120:24 121:14 124:17125:15 126:2 131:12131:21 132:9 133:20134:5 137:22 138:14139:1 142:16 143:10144:3 145:11 147:12148:3 155:6 157:1,23159:7,16 166:15167:11 168:9 170:6,17174:18 175:9,10 176:8177:16 178:8 198:17206:18 212:5,20216:22 225:19 227:7227:21 228:13 229:2231:2,12 237:12239:15 240:23 241:9254:19 255:5 262:25263:17 264:21 265:5273:16 274:6 286:2288:17 289:3 292:13294:9,23 304:5 305:5306:7 321:22 323:11337:4 339:24 340:13340:25 351:18 352:22353:14 362:7,22 365:4365:5,7,11 369:1371:17 372:2 379:16380:4 400:16 401:5411:5 413:7 421:20422:6 423:17 425:2427:11 428:14 429:2430:24 431:11 438:24



Page 14

439:18 440:4 450:15451:6 452:20 453:24457:9 458:1,13 463:22464:14 465:6,18476:24 479:9 480:1481:7 492:17 493:3,19494:7 496:1 499:23500:21 501:13,25502:1,2 504:15,24510:18 511:15 512:2519:20 520:12 521:8521:23 522:8 527:21528:10 536:10 537:10537:24 546:10 547:2556:9 557:1 566:24567:22 573:13,24574:17,24 575:11578:9 584:6,15 588:24589:17 590:2,4 592:19593:11 594:2,3 595:22596:14,25 599:4,22600:11 610:20 611:10612:5,18 623:24624:17 625:2 627:10628:6,18 633:6,23634:17 635:23 636:10637:3,14 639:20640:12,23 643:4 644:5644:17 656:18 659:20

discussions 185:4 258:4303:22 304:25 305:2368:21 453:20 517:20542:21 546:7 548:17550:3 557:20 621:16639:2

dishwasher 508:25disorientation 91:12disparagement 190:17display 19:2,11displayed 43:10 85:12107:14 120:5 132:25144:18 146:14 158:12169:11 176:22 289:23293:4 617:12

disposal' 508:25dispute 224:13disrespectful 427:17disrupting 164:2disruption 288:4,7dissenting 604:1,2disservice 276:9dissimilar 474:1dissipated 109:14distance 123:4 438:19distinct 20:2 247:15261:4

distinction 112:10,17225:1

distinguished 25:16509:24 510:6

distribute 192:24distributed 192:24279:11 282:6 571:9

distribution 196:13202:7 204:24 441:8

Ditcha 6:21 251:25,25Div 531:23dive 168:25

Division 384:2 528:18,21529:14

do?' 506:12document 23:20 39:443:7 44:5 61:6 69:1184:23 85:9 86:1106:25 107:11 108:5114:21 118:6 120:2,19132:10,21 133:14144:4,14 145:6 146:11147:7 157:6,24 158:9159:2 164:2 165:7,7,9168:11 169:7 170:1176:9,18 177:11 184:1184:11 191:16 199:4215:18 217:14 222:5222:13 224:17 225:14226:6 234:9 267:25269:17 270:6,9 271:11277:12,21,22,24 278:3281:18 293:1 294:4296:3 309:11 319:13405:16 490:24 552:8

documentation 64:1589:3 364:13 490:23651:17

documented 129:5136:3 283:2 561:7

documents 14:3 69:16109:7 110:19 114:15114:22 203:1 217:9223:17 268:3 271:20271:20 277:22 292:14552:16

does-- 195:18dog 653:4,5doing 39:24 49:10 54:284:1 141:11 151:20165:20 203:7,15217:20 250:19 261:6269:21 306:1 324:21334:17 338:14 348:10358:8 441:13 491:6506:6 523:8 641:6654:23

dollar 8:20 379:19,19380:5,6,21 386:13541:23,23

Dollard 7:16 309:2,3313:9,11 330:24,25332:21,25 345:9,10,20345:23 349:11,12404:1,2 416:18,19426:18,19 435:22,23497:24,25 513:23,24591:13,14

Dollard's 348:3dollars 47:15,16 48:6dollars' 217:17Dominion 218:7Domitrovich 8:5 333:22334:1,3 368:12,13369:14 375:15 376:18376:19 406:6,7 410:21462:16,17,20 519:8,9588:6,7,14,16 591:25592:1 595:6,7 598:20598:20 626:17,18

639:14,14Donny 293:12doom 448:23door 190:8 342:4,4,5,8346:10,11 349:5350:18,22 351:24367:25

door's 348:7doors 341:11,23,25343:6,10,19 344:16348:4,19 349:17 351:6351:7,9

doubt 448:16 586:14Doug 6:4 11:1 197:8,8542:16,16 567:2,2,11567:15,23,24 571:17

dove 542:21downstairs 279:20369:20

downward 243:19dozen 414:18dozens 219:5 419:10605:19

Dr 506:17draft 43:6,21,22,24 85:885:18,18,21 89:2107:11,20,20,23 111:3111:4 120:1,11,12,14129:9 132:21 133:6,6133:9 144:14,23,24145:2 146:11,22,22,25146:25 150:22 154:2158:8,19,19,22 169:7169:17,18,20 176:18177:3,3,5 183:6184:24 220:19 221:4,8221:9,13 223:13,13,20226:4 232:14,15 235:4241:25 242:10,12243:2 247:15 265:22266:18,25 268:9 270:9270:19 271:2,8,15275:7 277:1,4 278:24292:25 293:21,22,24293:24 297:7,12300:18 306:25 309:15323:21 331:6 342:15342:16 348:22,24365:5,6,16 381:13,13381:15,18,20,21391:12 392:11 413:20413:22,24 414:14419:3 435:14 442:23443:13 499:18 516:3,5530:22 531:9 540:18559:8 569:3 579:22618:22 637:18,20641:21,24 642:3,11647:19 648:19

drafted 261:8Drafts 381:23drain 48:7 49:10,11dramatic 465:1drastically 246:18draw 580:11drawings 48:8 50:6Drexel 85:5drill 426:11

drive 171:23 395:13565:8 571:10

driven 380:11drives 185:10driving 538:25 565:7,8,9drop 58:7 650:18,21dropped 358:16dryer 360:7dryers 354:20dual 385:8,12 397:4,4duck 614:20,21,21,22,22621:25,25 622:1

duct 632:16ducts 96:4 628:25 629:8629:10,14,23 630:20631:20

ductwork 112:3,11due 43:12 148:9 181:17275:24 293:7 368:16372:14 384:13 385:25432:12 433:17 513:6513:12 515:3 561:7562:22 568:16 578:22

dumbfounded 199:11duplex 494:12,13 538:6duplicate 422:14,17duplicating 553:1duplication 422:9 423:5duplicative 606:8DuPont 329:15 340:17341:4 347:25

duration 42:3 109:17dust 107:24 110:2,4113:15,20,25

Dusts 107:6,19Dutch 142:4duty 186:9,10 394:8dwelling 303:25 380:10380:14 382:21 391:25398:17 492:12,14,15513:12 570:16

dwellings 482:14 489:24492:9,23 613:15623:20

Dyan 11:11 635:25,25

Ee 2:1,1 578:21E111 487:13E1226 113:18E136 109:12,16,20110:12,16 114:4,7,12114:20,20 134:15,16134:25 135:5 137:1,10137:13,14,20 268:25

E18(A) 642:14E2019 113:18E2650 134:15E2652 137:1,4E8(4) 641:22E84 90:21,22 93:4,4,5,594:16 97:8,14 102:14102:15 641:4,7 642:5

earlier 41:20 72:15 73:16191:20 220:11,16233:5,11 252:3 275:7304:23,23 318:10336:16 359:22 385:24

400:12 416:7 438:7453:18 468:17,17516:2 533:13 546:5551:8 562:12 574:15637:17

easier 82:4 222:20easily 59:25 156:11282:23 303:2 347:9407:23 513:10 533:16

East 12:19 35:13Eastern 384:2easy 255:14 256:6331:10 351:25 401:7432:22

eat 339:16Eaton 334:3,18 368:13376:20 406:7,10462:17 519:9 588:7592:1,1 595:7 598:21598:22 626:18 639:15

Eaton's 30:14echo 423:5economic 282:22 283:6562:22

Eddie 6:23 252:22,22272:6,6 290:13,13313:8,8,25 370:5,5377:23,23 449:8,8474:19,19 544:22,22572:7,7 580:20,20581:12 582:1

Eddy 555:2,2 565:17,17Edison 194:8 199:25600:2,14 607:4 608:10612:10,21 620:2622:18

edit 393:17editing 579:7edition 23:4 44:4 45:2145:22,25 46:11,2247:18,24 50:9 51:2351:24 86:1 108:4120:19 122:22 133:14145:6 147:7 159:1160:8 169:25 177:11234:9 244:22,23278:21 280:18 281:8286:17 294:3 325:23326:12 335:18 336:1353:24 363:4 372:6391:24 402:1 432:5438:6 444:15 490:22604:22

editions 46:13 69:24159:23 357:9 431:21

editor 159:23editorial 56:2,6 93:1694:9 99:2 102:13,22457:3

edits 270:16 271:15educate 473:14educated 151:5education 163:20562:23

Educational 25:1 26:1231:7

EE 357:18EEI 194:9 195:1,3,4



Page 15

227:11,24 354:5 604:1effect 179:2 205:16300:9,24 326:3 391:16513:14 552:20 576:14

effective 124:10,12148:22 149:6 286:24384:21 437:25 513:8513:16

effectively 123:1,20398:11 517:2

effectiveness 149:11,23164:3 382:24 383:9

effects 433:18efficiencies 148:25efficient 578:12efficiently 22:16effort 69:16 128:15153:9 191:13 287:24380:12 523:10 617:14

efforts 19:20 23:3 89:1214:18 283:23 509:22553:1

EFI 144:11egg 470:13 534:15egress 89:10,22 91:10183:15 341:12,19342:9,10 343:6,14,17343:19 344:17 348:5351:25

eight 159:23 188:16202:7 461:3 482:18629:9,17

either 17:11 41:13 54:1658:14 160:18 162:24199:1 219:25 222:11266:11 296:16 360:6414:3 558:6 616:3625:13 638:11 650:22

El 460:19elaborate 123:25 579:20electric 28:1 70:1 177:21178:10,13,14,20,24179:5,22,24 180:2,6180:24 181:3,7,12,14181:20,22 182:14184:16,18 194:8,11,14194:17,17,22,25196:15 198:20 199:8199:10 201:24 202:2202:13,23 204:8,25205:14,17 214:4217:10 218:22 236:20237:17 297:4 299:15300:3,9,14 301:4,9302:2,10 316:1,1,2,5316:12,14,16 329:4336:4 355:8,17 367:22374:16 385:22 386:17410:16 418:13 421:24422:8 427:8 484:8495:3 497:9 502:16518:6,8 524:20,20537:15 544:1 547:11548:14 549:4 551:12551:16 553:20 554:24558:20 560:5 564:5,18565:1 579:23 587:22592:11 595:16 598:5

600:1,2,13,14,17,18607:3,4 608:10 612:9612:10,20,21 620:2622:17,18 626:8641:18 650:15

electric's 575:19electrical 21:17,25 22:625:22,23 28:3,8,1030:16,19 34:18 62:1087:23 105:5,6,14,15178:18 189:10 196:14198:24 199:1 204:9208:13,14,22 209:6231:20 232:24 233:7233:17 234:2,13 236:4236:14 239:22 290:4292:22 293:6,20 294:1295:7,8 297:22 298:3298:6,12,15,20 300:12300:25 301:1 302:23303:18 306:18 308:11309:4,22 310:17311:17 316:24 319:1322:1,22 323:13325:11 328:11,20329:18 331:1 332:13333:5 334:10,25 335:4337:11 345:11,12,15347:19,23 349:13356:15 359:3 364:24366:19 367:6 369:6373:9 374:8 377:24380:18 381:9 382:12382:17,21,23 383:3,20383:22,24,25 384:16385:25 386:4,18,18,22387:15 390:7 392:23393:14 394:10,18395:1 396:18,19 397:1398:6,10,12 400:20402:11 404:3 410:9416:4,20 417:5,8,9418:16,17 419:19426:2,20 428:18429:22 432:1,2,3,5,15432:18,25 435:24436:5,22,25 440:8442:16 443:7 444:9446:5,13,25 447:13451:24 459:11 461:1467:17 483:12 484:3486:20 487:4 489:10489:11,15 491:2,3,22493:23 495:4 498:1501:17 502:17 503:1507:17 508:17 511:20513:1,25 515:4 519:12520:21,22 523:18532:11,14 535:12539:6 540:1 547:10549:4 550:12,20553:25 557:13 559:24563:4,10 564:17 565:4565:12 578:3 591:15602:8 606:17,20609:22 615:13 619:12619:15 622:11 631:13635:8 638:18 642:21

642:23 647:3,17649:12,15,23,25 651:3

electrically 577:3,5electrician 383:23 390:8396:18 506:21 507:2509:9,19 604:17

electricians 507:3508:22 509:22 606:2

electricity 194:12 202:12297:11 298:7,25302:21 303:3 367:12367:12 369:8 376:24377:19 384:12 385:6433:18 435:12 560:1620:8

electricity.' 298:1Electrification 201:24electrocuted 360:5electrocution 360:16368:17 538:19 544:15577:7

electrocutions 360:12360:14 368:6 540:16

electrolyte 235:14electromechanical311:11

electronic 16:23 19:5406:23

electronically 14:21271:23

electrons 620:7 646:9646:23 650:19

elements 60:7 384:14443:9 486:22 487:10

elevate 60:19eligible 65:1eliminate 175:2 386:22554:20 621:8

eliminates 139:7 445:8602:5 646:16

eliminating 172:14Elliot 542:20Elliott 539:24,24Ellison 4:18 144:10,19144:21 145:10

else's 195:24 653:5em 75:5 389:19 390:10395:5 426:10

embed 325:15emerged 557:24emergency 12:14,15,1612:20,24 13:9 28:7,2429:1,5,25 31:11,1235:10,14,18 36:2182:7 199:13 219:14279:23 331:14 357:19357:24 591:19 613:16621:6

emerging 24:9 147:19148:5 193:23 194:1213:15 214:11,16215:3 225:12 235:6274:25

EMI 398:2,9emphasis 600:22emphasize 173:22194:23 205:13

employed 248:24 301:13

employee 12:18 35:12661:8

Employment 34:6EN-13501 135:13enable 151:24enact 547:23enclosed 141:7 200:13429:8

enclosure 105:14258:25 355:16 373:18373:21 377:4 447:4,7448:4 602:3 614:18

enclosures 105:16248:11 615:25

encompassed 642:7encompassing 262:21Encore 509:17encourage 51:3 64:6,19118:12 161:18 168:15180:5 214:24 368:9386:23 406:2 471:19508:2 585:22 591:6594:24 598:1

encourages 20:19178:11

ended 18:13 223:21523:13

endorsement 82:1ends 209:7 325:4energetic 189:22energized 346:2 355:16355:20 377:3 434:5

energizes 368:4energy 26:17 87:20160:3 176:14 177:2,7178:18 179:12 187:15188:17,22 189:17,20189:24 191:22,25192:8,21 194:21,24195:12 196:18 197:16198:20 201:4,13204:24 207:23 212:9212:21 213:3 215:3,13215:20 216:7 217:4,7218:8 219:17 221:24222:2 224:11,24 232:6233:13,24 234:1,4,8236:1 241:19 243:18243:21,25 244:9245:21 249:25 250:25252:6 259:15 261:16265:11 268:14 273:20274:17 276:22 279:8279:13,24 281:24283:16 284:7,15,22285:24 289:6,25 295:7349:20 350:4 384:15547:11 600:19 603:1604:14 613:10 615:15615:16 616:5,10,25618:7

Energy's 179:14enforce 199:6 337:1347:15 516:25 547:24571:18

enforceable 198:12287:6 306:15 391:21

enforced 286:21 347:12

enforcement 329:9432:11 525:10 552:22557:25 562:24

enforcer 336:20enforcers 24:18 267:5606:2

enforces 487:3enforcing 347:6 391:9engaging 418:15 598:11engine 561:10engineer 186:20 256:7260:19 296:22 317:6358:6 389:3 393:23419:19 534:5

engineering 44:16 45:1747:8 48:5,10 53:1364:12 83:20 170:9284:18,18 285:14389:14 407:16 446:19446:22 452:11

Engineers 294:16 295:4546:17 551:25

engines 87:20Engison 122:24English 506:10 507:6509:4 536:5

enhance 540:14enhanced 297:13enjoy 526:24enormously 319:20Ensembles 147:2ensure 22:5,23 200:21267:4 301:7 334:21343:18 350:2 523:1531:5 532:2 585:7590:16 594:12 597:14605:25 625:11 638:8

ensuring 343:16 441:8ENT 490:11entails 174:15enter 188:6 341:19 440:8445:15,24 660:5,6

entered 16:22entering 442:21 446:25448:25 449:1

enters 445:3,6 447:3,16entertain 18:19entertained 14:16entire 16:13 24:2 37:457:23 61:4 109:10134:9 274:2 279:9291:25 307:15 310:2388:6 415:16 467:21491:3 512:4 516:15542:23,23 605:5 611:5616:8,24 617:15

entirely 172:15entirety 170:23 602:6entities 180:1entrance 442:22 443:6616:3 645:11,19,23649:3

entrances 341:19entrapment 343:9entry 341:11 343:6 447:5entry' 347:3,8enumerating 454:16456:19,20



Page 16

enunciate 259:6environment 87:1 96:6121:25 122:2 178:15213:17 257:5,22308:10 442:7 446:11538:19 552:5 571:16

environmental 232:6486:17 629:24

environments 91:12,14187:20,23 196:3 314:3

EPA 482:18equal 282:25equates 419:6equipment 28:8 30:531:14 33:22 112:2,4,5113:14 115:7 137:3146:7,21 148:11,19150:3 152:11 163:11187:9 192:25 196:13203:8 204:22 280:4295:9,12 298:6,16299:11 300:7,8,10,20300:22 308:6,9,12309:25 310:13,15,17311:12,17,20 312:3,3312:11,14,23 314:14317:23 318:5,9,14,17319:19,22 320:1323:24,25 324:1,5,6325:6,8,15 327:2,5,7327:19,22 328:7,12,13328:15,21,22 329:10329:19 330:5 331:9,12333:2,4,12,16 334:15334:19,20,21,23 335:1335:13,24 336:11,23337:22 338:3,6,10341:11,15,15,23 343:6343:8,10,11,14,19344:15,16,18,20,25345:2,25 346:3,8,13348:11 349:2,4,7,16350:8 351:7,8 354:15387:17 389:25 390:2402:15 403:3,4,9,14403:17,18,19,20 404:7404:19,23 405:8,9,10406:1,12,18,21 407:3407:19,24,25 409:7414:18 416:9 417:2,8417:15 418:17 419:5,8419:23,24 420:2,4426:24 429:10 455:16459:15 469:6 498:12503:1 505:9 514:5,19515:4,5,7,20,22517:15 519:12,13524:12 525:10 540:1540:14,17 541:5548:14 549:4 553:24554:23 557:10 558:8560:19 564:17 567:8569:4 577:1 586:14587:6,10 588:17,20592:4,7 597:3 598:25614:15,19 625:6 627:7637:21,25 639:1,4651:6,8,11,12,14,15

equipment's 324:14327:6 349:2

equivalence 139:22equivalent 139:14142:22 224:11 269:4300:15 303:1 579:25

Ernie 11:16 649:22,23650:7,9

erosion 393:2error 481:20 517:10,11536:7

errors 438:1 454:18456:22 609:3

escalating 148:8escalators 118:14168:17

especially 24:14 56:2158:7 161:12 199:14213:17 215:4 217:17250:6 275:23 288:16306:18 324:24 369:3510:22 561:19

ESS 179:14 180:24181:7,10,15,20,24182:2 186:6 192:15193:19 196:15 198:18198:19,19 199:3,9200:12 205:18 206:24207:25 222:17 237:15247:23 248:1,5,20,20248:23 249:25 276:21285:22,24 286:1 287:3357:18

ESSB 212:11 273:22essence 616:9essential 93:2 129:16150:14 178:19 458:18458:23 630:16

essentially 184:3 298:10325:9 404:12 456:19465:23 466:6 489:19609:13 610:15

establish 14:2 112:17123:9 447:25 610:23

established 15:5 18:221:24 178:21 318:15415:2 563:6 568:15656:14

establishments 531:25estimated 128:4 130:12202:6 245:8 386:8,10

Ethernet 653:1Europe 134:17 136:9142:6

European 135:12EV 554:8,12,22 558:13evacuate 12:11,23 35:17evacuated 54:16evacuation 12:20 13:913:10 35:14 36:2,3

evacuations 448:14evaluate 286:13 515:1evaluated 135:21 569:7evaluating 550:1evaluation 48:5,10 50:22310:16 335:23 417:3513:7,11 524:1

eve 388:17

evening 315:8,8 388:17454:1 514:3 526:23551:21 563:12 571:3579:17 602:19 644:9

event 12:11,16,25 16:2418:10 35:9,19 60:14165:20 250:9,25 251:2256:12 350:2,19,23412:1 586:19

events 19:17 246:20257:18,18 284:12433:12,17

eventually 286:18393:10

everybody 35:4 77:6,2078:1 157:5 271:10288:25 313:18 314:13333:18 335:4 345:24349:15 397:8 398:17497:5

everybody's 420:6everyday 387:14everyone's 79:18everything's 38:16 39:3evidence 135:23 276:11393:7 540:17

evident 505:25 507:22508:18,20 509:21

evolution 275:2evolve 247:1evolved 269:7 557:23EVP 557:9,15EVPE 558:7 559:2,7EVSC 558:12exact 374:21 409:21483:8 515:19 608:12

exactly 58:5 93:9 114:4116:4 139:21 149:6334:24 357:13 419:9452:1 470:5 541:3553:17 570:18 609:16623:7

examined 561:5examiner's 358:9 394:17examiners 358:10examining 557:21example 127:1 142:2165:11 172:18 192:4,7200:24 235:10 262:12279:15 282:4,18300:10 407:22 445:13487:9,25 508:16515:18 577:2 586:24615:19

examples 280:6 652:13exceed 55:18 245:11exceeded 192:9 279:16exceeding 260:17470:24

exceeds 259:1excellent 128:2 213:19290:7 607:7

exception 182:5 325:3,7376:12

exceptions 276:10excess 63:18excessive 55:6,9 519:1excessively 516:25

exchanging 397:3excited 530:19exclude 183:22 193:25259:18 262:10 499:4554:14

excluded 219:4 296:1,5529:24 548:12

excludes 160:22,23,24161:6 162:8 500:10547:14

excludes' 213:9excluding 528:17exclusion 529:11exclusions 222:13,22,22exclusive 181:7,12204:25

exclusively 195:17,19275:1

excuse 26:18 33:17 34:966:17 80:20 145:20164:16 166:21 174:24246:2,19 317:1 356:5361:20 437:11 472:23525:11 593:17 634:7650:5

execute 391:16Executive 179:23exemplary 23:6 25:13exempt 181:16 182:14182:18 183:12 215:22217:22 649:4

exempted 225:3,6246:15 284:25 645:24

exemption 188:2 189:24190:16 192:23 196:11196:12,14,16 198:23201:15 206:13 245:1285:7 287:9

exemptions 183:4,7184:11 207:15 216:1217:19,22,24 245:10

exempts 244:24exercise 281:15exhaust 258:23 259:2260:11,25

exhibited 243:20exist 59:20 174:5 225:9271:20 290:9 325:23366:6 369:6 393:8533:5 534:1,13 544:19552:6 576:11

existed 173:19 224:7444:10 645:1

existence 179:4 213:22531:18 533:4

existing 82:18 111:11,14121:22 143:7 194:2205:1 219:23 220:1225:16,24,25 245:8261:9 275:1 282:9284:5 344:19 345:2359:5 376:1,14 434:21445:16 533:18 557:15569:13 575:21 579:21584:24 610:3 615:22642:1 645:16

exists 46:3 61:6 142:8,9166:7 174:2 188:3

281:16 368:2 445:14445:23 533:2,2 534:12

exit 12:15,23 13:4,535:17,23,24 350:20,21350:22,23,24

exits 12:10,14 35:9expand 161:3 238:5284:9 353:24 363:5372:6 383:10 393:18

expanded 237:3 363:19expansion 238:18 354:3369:11 380:9 383:13384:6 385:15 389:13390:15 393:3 488:3491:6

expansions 392:21expect 243:8 510:1expectation 173:15174:4 298:17 448:23

expectations 59:21expected 469:18 626:23expecting 392:12 491:15expense 248:22 288:3expensive 548:6experience 24:13 42:488:20 96:17 186:22214:22 369:17 383:22483:6 552:2 653:13

experienced 397:25experimental 129:17expert 506:3 541:1expertise 20:22 24:5178:18 200:2 414:22

experts 203:13 279:1317:22 393:14 608:6

expired 467:8 507:8647:8 657:14

explain 18:21 233:7239:19 241:14,15,17243:9 271:4 309:11389:6 571:8

explained 113:11 124:9142:12 415:16 495:13552:23 598:24

explaining 185:14explains 309:21explanation 239:10307:18 444:16

explanatory 631:18explicit 297:18explode 187:17explosion 160:3,13190:3 231:21 232:25233:8,18 234:3 236:4236:14 237:18 239:22246:8 250:16,17 257:2

explosions 107:25257:14 445:20 446:16448:15

explosive 257:5,18Expo 279:19Exponent 113:7 115:4191:6 220:7 231:4,17236:9 239:3 241:1,12251:6 264:24 265:7270:4 278:14

export 295:12 297:4298:8,20 299:15 302:2



Page 17

302:4exported 553:20exporting 296:4exposed 100:18 203:12203:21 346:14,17350:3 490:16 629:22629:25 630:8,11631:17,20 632:9,17

exposure 148:14,20150:13 182:6 199:12

express 43:13expressed 485:13529:12

expressing 174:21expression 122:22extend 123:19 149:16205:18 348:15

extended 269:5 514:19extends 380:13 406:20extensions 652:14extensive 23:21 128:15149:3 153:8 179:15223:18 269:3 490:23

extensively 180:25218:21 426:4 483:8490:21

extent 68:1 126:20127:22 393:4

exterior 446:9external 447:4 544:11549:5 554:24 557:11567:9 575:16

Extinguishers 32:11Extinguishing 31:10,15extra 431:23 470:1 479:3651:1

extract 69:12extracted 24:10 68:9extracts 271:19extraneous 326:15extreme 349:20 359:7417:4 488:20 648:16

extremely 155:15 196:8238:17 310:1,5,18331:11 349:19 436:1,8436:11 515:21 516:7644:23

eye 186:12eyes 347:7

Ff 265:9 267:12 578:24F-4 228:5FAA 87:3fabricated 629:23630:19 631:20 632:16

fabulous 131:5Facebook 282:5faced 307:1 619:3facilitate 335:23facilities 28:22 31:1432:15 33:20 57:7140:25 152:11 169:3169:17,22 171:14173:23,24 175:16179:7,8 181:5,24188:5 201:5 206:24218:23 225:25 287:10

316:20 344:13,14345:4 405:25 411:2515:6 584:24 588:3592:17

facility 54:15 116:14199:15 203:16 285:9312:4,10 318:9,14335:15 346:23 505:15509:10 514:17 515:2

facing 343:11fact 57:19 59:18 60:3,964:13 69:7 75:23102:16 109:20 161:8165:2 217:12 223:11245:3 275:14 314:4331:7 354:6 385:16408:19 415:13 455:10460:10 467:2 474:10483:9 489:22 495:10529:17 535:13 541:2590:4,5,8 605:22621:12

facto 364:4factor 89:5 90:3 241:22586:12

factors 260:14factory 248:17facts 382:15 412:20548:23

factually 60:22Fahrenheit 346:18fail 134:23 391:17failed 53:8 65:17 118:4125:14 132:8 138:13144:2 227:6 240:22254:18 263:16 273:15292:12 304:22 321:21339:9 352:21 362:6371:16 379:15 381:15381:20 391:3 411:22421:19 428:13 430:23439:17 440:12 450:14453:11 457:25 476:7479:25 493:18 501:12504:14 511:14 520:11526:21 556:8 566:23573:12 584:5 589:16593:10 596:13 599:21628:5 640:11 659:19

failing 345:4 391:18fails 15:23 16:25 19:736:21 67:24 176:7481:19 646:13

failure 49:14 259:5 415:1failures 433:16faintly 609:21fair 188:13 387:4 415:2fairly 68:3 121:18 353:19401:7 576:5

fall 14:11 183:10 232:1280:1,10 298:14325:17,18 338:8 383:8

falls 191:16 192:10false 232:3 236:19262:16 267:21 336:9352:2

familiar 14:1 88:1 89:23163:25 174:11 178:15

201:13 207:21 445:12familiarize 12:10 13:22family 88:16 96:14189:20 613:15 621:7623:20

fantastic 186:5far 53:25 54:4,23 57:969:12 82:4 157:7187:22 190:23 193:21224:13 226:13 234:10234:10 262:21 283:1284:4 304:23 344:23360:9 533:12 540:7553:16

farm 164:22farting 358:23fascinated 491:25fashion 419:2fast 105:3 254:10 565:8fatalities 160:4 375:17fatality 355:12,19 373:12373:20 374:18,23375:14

fault 300:13,16 355:19358:13,15 368:15373:19,19 394:22395:4,5 401:8,9,12,18401:19,22 403:4,17,18405:8,20 406:12,18407:2 410:19 420:3,3420:4 437:22 531:22533:17 561:20 576:12576:14,16,19 577:5579:25 608:16 609:9609:11,15 610:5,17

faults 486:19 529:13,15529:16

favor 17:14 47:8,1048:16 51:14 52:1159:15 61:9 62:1564:12 69:5 70:4 76:376:23 83:21 84:290:18 125:12 129:13131:6,8 142:20 143:25150:14 162:4 168:6173:11 176:6 186:19191:6 197:9,11,23201:25 202:15 204:15208:11 215:1 216:25224:25 231:13 236:9237:5 239:3 240:19241:12 243:11 263:13265:8 270:5 274:14281:25 283:16 295:4315:1,3,22 322:23323:14 346:24 348:1356:4 365:12,15373:11 391:2 402:12402:18 408:14 416:5421:16 440:6 451:8456:18 457:24 463:11464:12 465:21 470:12475:18 476:6 479:24485:9,12 491:17493:17 501:11 504:2,3504:13 505:1 508:12511:13 520:10 526:7,9526:20 528:12 532:22

534:25 535:5 536:25545:14,16 546:3 547:7554:6 555:18 556:7566:8,10,22 572:3,23573:11 583:16 584:3589:15 593:9 596:12599:20 602:10 608:11609:21 612:2 614:24620:4,18 624:14 628:3632:4 633:21 636:1,25640:9 641:19 643:1,19648:11 652:16,24654:10,25 656:5,16657:24 658:4 659:4,17

favoring 247:23FCC 651:8,11features 25:3 26:1432:25 186:3 380:22

February 265:25federal 87:10 178:25184:21 364:5 547:15552:10 557:16 569:19575:24

feed 248:6 405:13feedback 197:10 270:19feeder 401:15,17 447:19539:12,12 541:14,15543:13,15,17

feeders 404:5 405:13445:15 542:22

feeding 161:1feeds 405:20feel 101:1 184:2 197:16202:13 234:17 369:4384:20 409:8 466:10478:6 522:13 584:17584:22 590:3 594:5597:5 625:3,4 648:18

feeling 148:8 657:23feelings 384:5feels 467:23feet 88:18 96:16 123:12190:7 341:16 342:4,6349:3,4,5 354:1482:18,19 645:24

Feige 158:7fellow 337:21 618:17648:10

felt 61:23 68:20 82:2583:10 93:15 111:4162:10 269:13 616:19

FEMA 363:12 386:5,23394:4

fence 373:17,21 375:4,4fences 208:24fewer 481:18fiber 655:11,13field 163:23 248:16,17310:16 336:20 374:21374:21 406:24 417:3434:2 462:4 463:3,18500:12 505:6 512:10513:7,11 523:25 524:1524:11 552:3 558:2571:19,25 588:19607:22 626:24

fields 506:3 552:4Fifteen 229:16

Fifty-six 167:6fight 653:4Fighting 146:6,20figure 407:10 463:18509:9 646:20

FILE 1:22filed 15:20,24 36:18,22fill 215:18 277:21filters 375:19final 18:17 37:7 52:1570:9 84:5 91:19 99:12101:9 124:19 137:23143:11 150:22 157:5167:12,14 175:13197:20 436:3 457:11460:24 463:24 479:11493:4 500:22 510:20519:21 536:12 589:2592:20 595:23 599:6604:25 611:13 624:1627:12 633:7 636:12639:21 643:5 656:20

finally 27:18 28:11 34:1655:24 214:9 529:12531:24

financially 661:9find 41:12 49:6 50:6 51:1210:21 251:12 252:9291:3 368:6 459:16463:13 561:17,25616:2

finding 455:10 474:10findings 380:12 383:12fine 38:17 66:1 117:5124:11 142:5 235:17330:6 429:7

finish 93:7 229:18477:23 490:13,24491:20 526:24

finished 363:5,8,9 366:3366:4,4,13 367:24368:1,7,8 369:1,2459:22

finishes 100:19finishing 22:17finite 123:4Finnegan 5:13 172:7,9174:19,20,24

fire 12:22,25 13:1 20:2023:13,16,17 24:19,2425:3 26:13,18,2527:13 29:19,25 30:431:10,12,15 32:11,1332:24 33:15,18,2235:16,19,19 44:1,1545:16 47:7 48:1149:19 50:14 54:2,3,1354:16,17,17 56:1557:17,19,23,24 58:1,858:8,11,14 60:1463:15,25 64:2 68:1469:4,17 70:3 83:9,2085:22 88:22 90:2,4107:24 112:5,6,13123:5,12 128:20,22129:18 130:14 132:16133:5 137:7 142:3144:9,23 145:3 146:6



Page 18

146:9,20 147:20 148:5148:14 149:3 150:8151:23 152:5,13153:10 154:7,20 156:5156:16 160:13 165:19165:21 169:2,16,21170:22 171:12,16175:18 186:9,19,20188:18 189:7,8 190:15193:15 195:12 196:6196:12 200:1 203:10203:18 206:15,22,25207:5,6,25 216:11,12217:10 219:21 221:24222:25 223:16,17224:1,6,9,15,18 229:5231:20 232:24 233:7233:17 234:2 236:4,14237:18 239:7,9,22243:22,23 247:21248:19 249:1,21 250:2250:5,8,10,14,19,22251:11,15,17,20,22252:5,8,15,16 254:22255:25 256:6 263:22268:1 271:5 279:9,19279:23,25 283:2 284:3284:8 285:7 286:18289:17 357:25 380:16380:18 382:18,23383:3 386:9,13 393:25394:1,6,9 395:1398:12 431:17 432:9437:20 443:24 446:4,5446:8,12 486:19487:10 488:12,21491:20 584:19 586:7586:10,11,13,16,16,16586:19,20 587:7,9,17588:8 606:18 621:1628:22 630:14

firefighter 149:9 150:16155:16 623:14

firefighters 147:17 148:6150:11 152:21,24154:14,20 189:9 190:6190:6 203:3 209:14235:3 243:24 289:15623:18

firefighting 89:1 147:3,4149:9 200:2

fireproof 632:14fires 54:12 88:21 171:18274:17 380:20 382:17385:25 386:2,5,9,12386:13,14,14,17,17,20394:12 432:9 445:20445:25

firm 63:18firmly 350:24 559:1first 21:6,12 25:19 42:2543:6,21,23 54:1 68:276:3 82:17 85:7,17,2086:20 89:2 107:10,20107:22 111:3 116:24117:4 120:1,11,13126:11 128:5 130:21130:25 132:20 133:6,8

144:13,23 145:1146:10,22,24 152:8153:23 158:8,19,21163:14 164:18 167:1169:6,17,20 176:17177:3,5 182:12,13183:14 184:24 186:4186:11 188:6,11 191:7192:7 194:21 197:21203:3,22,24 213:13215:7,24 221:4 223:13225:22 226:1,4 235:5239:1 241:21,25242:12,13 243:1,1,24244:15,18 249:18255:9,19 258:17265:18,23 266:13,17266:18 267:15 268:9270:3 271:2,8 277:5278:15,21 280:18281:7 282:20 292:25293:21,24 294:24297:7 299:6,9 309:15311:11 322:24 323:21331:4,7 336:16 342:15353:4,10 354:2 356:13356:18 361:19 362:12362:17 365:5 371:5376:8 381:13,15,17,23390:22 394:4 403:6407:12,14 409:2413:19,22,22,24 414:5414:13,14 416:23419:3,7 442:23 444:14462:22 482:22 499:17499:25 500:7 516:4524:13 528:14,19529:20 530:22 540:18544:3 546:20,24555:24 556:23 563:16566:14 578:7 581:14600:4,7 601:11 603:10603:12 604:20 605:5611:12,19 617:23618:1 619:24 620:25628:19 630:21 634:6637:20 641:20,21,24645:14 646:6,14 655:8

firsthand 390:6Fisher 11:8 604:13,13617:7,7

fishing 396:2Fisk 105:4Fiske 4:5 93:24,25 105:2105:10,13 301:12,13301:18,20,24 498:23498:24 516:11,12533:22,23

fits 288:23 308:19fitted 89:20five 15:24 19:2 36:2338:8 40:24 46:24 53:354:13 65:12 69:2570:1,20 84:16 92:4,595:7 97:24 99:22101:18 103:14 106:13117:24 118:20 125:8132:5 138:9 143:23

152:15 153:1 156:9157:18 164:8 168:4176:4 194:5 197:7202:16 210:23 211:22221:17,22 227:1232:20 240:17 241:22253:13 254:13 263:11272:21 273:10 275:22277:10 287:18 291:17292:6 299:2,16 304:17307:23 321:4,16 322:6338:3 339:4 349:4352:16 361:12 362:1370:21 371:11 378:20379:9,18 381:16399:17 400:6 405:2411:17 421:1,14424:11 428:8 430:18439:12 449:21 450:9453:6,19 457:22460:16 464:10 473:8475:16 476:4 479:22493:15 501:9 503:24504:11 511:11 520:8526:5,18 527:24,24532:19 534:9 536:23541:21 542:5 545:12546:1 551:20 555:16556:5 563:11 566:6,20568:20 571:1 572:21573:9 579:16 583:14584:1 589:13 593:7596:10 599:18 611:25624:12 628:1 632:1633:19 635:17,24636:23 640:7 643:17644:6 648:7 649:20651:23 652:19 653:23654:6,8 656:1 659:10

fix 60:21 166:7 222:1,12348:20 377:6 472:23518:1

fixed 119:22 120:10,15206:23 348:23

flame 91:1 102:15,15105:16,24 109:16,22148:11 436:13 486:8486:25 488:18

flames 161:5flaming 110:17flammable 160:1,2,14200:12 250:15 258:24259:3,20 446:1

Flannery 3:24 64:10,11flash 346:5,12 350:4,23flashing 13:2 35:20flawed 324:4flex 431:13 435:13533:15

flexed 529:19flexibility 528:24 529:1flexible 562:1flickering 505:18flies 614:20flip 479:8flip?' 505:21floating 73:6flood 338:5,6 363:12,14

flooding 363:10,15floor 17:9 18:24 19:934:25 37:19 40:8,1045:2 49:20 52:2153:17 63:17 64:2565:6 66:25 70:13 76:884:9 86:12 91:2392:18 95:1,20 97:1798:12 99:15 100:10101:12 102:6 103:8104:1 106:6 108:17117:17 121:9 124:25125:23 131:23 134:1138:3,22 139:20140:17 143:16 147:22147:25 157:11 159:12162:20 163:1 167:22170:13 175:22 178:2,8181:11,15 184:9185:22 209:17 211:15212:16 218:19 220:4226:19 231:8 240:11241:4 253:1,20 255:1263:4 265:1 272:11273:3 274:2 290:17291:25 294:19 299:5304:10 309:5 313:5320:11 323:5 328:25331:2 333:19 334:4,5338:21 346:20 349:14350:9 352:9 353:8360:24 362:15 366:6367:14 368:14 370:8371:3,23 376:20377:20 378:7 379:3,25399:4,24 401:1 403:23404:4,18,25 406:9407:6 411:10 413:13416:21 418:2 420:13421:7 422:2 423:4424:4,23 426:25 428:1428:22 430:11 431:6436:1,19 437:2 439:5439:24 449:10 450:2450:25 452:24 454:6457:16 458:9 460:21462:21 464:3 465:14475:4,22 476:18479:16 481:13 482:23482:23,23 483:19489:3 492:7 493:9494:2 498:2,5,19501:2,20 504:5,20509:9 511:5,23 514:11519:10 520:1 522:4525:20 526:12 528:4532:16 536:16 537:20545:1,19 546:22551:18,23 555:5,22556:22 565:20 566:12567:17 572:10 573:2575:7 580:25 583:2,20584:11 585:19,23588:22 589:6,23 591:2591:7,16,21 592:25593:23 595:8 596:3,21598:2,22 599:11 600:6606:22 611:17 612:14

619:17 624:5,23627:16 628:13 633:12634:13 636:16 637:10638:19 639:16,25640:19 641:19 643:10644:13 647:18 649:19656:24

floors 369:19Florida 31:4 83:22 608:9620:2

flow 49:23 54:19 57:364:3 67:13 68:4,869:13,20 234:5,6235:12,12,13 250:18295:7 297:5 299:10547:11 613:11 620:10630:1,9,12 631:20632:9 646:9 650:20

flow' 631:17flowing 185:17 646:23flux 122:8,8,9flywheels 191:23 232:7236:20,24

FM 190:14FMVSS 548:1 549:1552:11 557:23 558:1561:20 569:20 575:25576:15 579:22,24

foam 58:4Foam-Water 31:18 32:8focus 55:3,12 234:11247:9 274:24 278:23

focused 552:1,5fold 164:16folks 39:2 40:4 72:25165:21 191:3 200:25201:13 222:8,8 387:6387:12,21 388:2,7580:10 613:19 618:15

follow 12:21 35:14 82:3172:21 281:25 302:16415:2 419:15 453:21465:4 606:10 648:20

follow-up 14:15,2318:20,20,23 41:8

followed 13:2 35:21550:4 652:16

following 12:23 15:2,2117:6 18:15 19:1025:18 35:17 36:1937:10 41:21 42:8,980:13 87:18 116:23167:1 295:21 408:16414:11 453:20 455:8459:13

following' 117:1,3follows 18:24 42:13food 118:13,14 168:16168:17 411:25

foot 342:8footnote 398:15force 31:4 251:10,22384:22 436:9 490:22543:16 558:3

forced 616:7,23Ford 567:3,24foregoing 661:5,12forever 419:11



Page 19

forget 17:18forgot 182:9 345:18653:10

form 276:9 419:1format 82:24 185:3formed 277:1 310:7417:11 436:12 484:6577:7

former 109:13 130:11301:14 347:7

formerly 25:2 551:24forms 389:23Formula 185:9formulation 122:21forth 62:10 130:15246:24 278:5 391:12487:12

forthcoming 258:5Forty-eight 39:17forward 35:1 79:4 80:1389:22 130:22 155:15171:6 174:22 185:5212:12 258:6,11271:15 286:11 287:14287:15 288:5,6 301:6348:13 398:13 471:21562:4 615:16 619:2

forwarded 15:11,16145:21

found 13:11 36:4 41:1043:21 44:4 85:17 86:1107:20 108:4 120:11120:19 127:18,23133:6,14 144:23 145:6146:21 147:6 158:19159:1 163:3 169:17,25177:2,10 188:24 201:3269:7 293:21 294:3296:15 329:7 374:22374:25 375:1 377:7,14415:22 429:17 432:4433:19,24 434:5,12525:8 597:2

foundation 149:4 153:10153:11 247:20 252:4315:6,14 382:19 383:1383:7,12 443:24448:12

four 44:13 46:17,23 47:451:6 62:1,2 66:18 80:783:18 86:7 90:1692:13 94:6 95:15 97:498:7 100:5 102:1103:22 105:20 106:20108:11 109:25 113:21115:23 116:18 120:25121:15 124:6 125:16126:3 129:8 130:3133:21 136:18 138:15139:2 141:17 147:13154:12 162:6 170:7183:5 184:6 191:3,4199:22 201:19,20,21204:12 205:6 216:2218:5 220:5,17 227:8227:22 228:14 229:3231:3 235:23 238:22240:24 241:13 247:4

248:9 251:5 258:16264:23 269:24 275:19278:11 283:13 294:10301:11 305:12 311:3320:2 321:24 329:14339:25 340:14 344:4344:12 347:24 351:2356:4,4 360:20 373:25398:21 400:18 407:12408:12 413:8 418:23423:10 424:18 427:12428:15 438:4 448:20453:25 455:24 456:15456:24 458:2 460:2461:17 462:15 464:15465:7 470:8 476:11480:2 481:8,18 482:7485:2 489:5 492:18493:20 495:23 499:7501:14 504:16 508:10511:16 514:13 520:13521:9,24 524:6 525:15527:4 532:8 546:12554:2 556:12 561:2566:25 568:18 573:14573:25 574:25 576:19584:7 589:18 593:12596:15 599:23 604:16606:14,25 608:7,21609:19 612:6 613:22615:7 619:10,22,25622:15 624:18 628:7632:19 633:24 636:6637:4 640:13 642:18652:20

four-fold 213:13four-year-old 360:4fourth 126:17 128:7,8129:2 131:17 317:16482:23

FPE 186:19FR 244:18 530:23 531:8531:11 556:20

frame 308:14framing 483:2frankly 655:24Fred 3:7 30:25 31:1,3,931:20 208:4,4,7,9,11358:20,20,25 390:20390:20 391:2 409:12409:12 463:7,8,11491:9,9,13 499:24,24500:2,4,7 516:22,22609:20,20 621:20,20

Frederic 2:17 25:19,2025:21 26:1

free 441:9 478:6freely 20:21freeze 409:19freight 436:16Fremont 26:9frequency 395:13frequent 148:13frequently 269:8 610:4637:21

Friday 652:1friend 541:4friendly 49:8 631:3

friends 377:9front 74:18,24 130:22131:1 220:13 236:9269:9 388:23 408:25505:16

frozen 210:5,6frozen' 210:9FSI 88:7FTA 87:13fuel 161:1 234:14 252:7432:7 443:5 448:6600:19

fulfilling 597:12full 24:4 206:17 392:14Fuller 2:9 20:7fully 61:2 131:7 154:1162:3 348:19 407:4486:10 568:17

function 295:17 298:10319:5 586:21 622:6627:1

functions 588:21fundamental 335:3fundamentally 324:4329:25 341:14 491:23

Fundamentals 26:1529:19 30:3 32:21

funded 153:10furnace 141:7further 15:9 20:5 37:2040:11 52:13,18 64:2170:5 73:17,19 74:1784:22 91:17 94:20,2197:9,11 99:9,11 101:7103:2,4 104:21,21105:18 106:3,19111:15 117:7,11 118:5124:16,21,23 131:11131:21 132:9 137:21142:15 143:9,14 144:3150:7 155:5 156:5,25157:2,9,23 166:15167:10 168:9 170:25174:17 175:8,10 176:8187:24 200:24 225:18225:21 226:5 238:18239:15 257:6 262:24278:21 283:11,11292:13 295:21 304:4,7304:8 337:3,7 351:17352:5,6 369:11 383:1385:7 411:4,8 423:16423:25 424:1 427:10427:21,23 430:7,9434:24 438:24 439:2441:11 443:20 452:19452:22 457:9,12463:21,25 479:9,13492:17 493:3,7 494:18494:19 499:23 500:21500:25 510:18,21519:20,23 531:15536:10,13 565:1588:24 589:3 592:19592:22 595:22,24599:4,7 611:10 623:24624:2 627:10,13 633:6633:9 635:23 636:10

636:13 639:19 643:4,7656:18,21 659:20661:8

Furthermore 60:10116:5 136:7 360:13601:25 639:2

fuse 312:6 425:4,7,12,14426:5,8,9 429:4,6,6,7429:13,25 430:1650:23

fuses 425:5 429:13future 19:17 180:14200:21 246:17 265:12280:22 328:23 369:10469:12 471:16 569:5,8579:6 615:12

GG 81:11,21 82:6,18,19,23G3 83:3gain 69:15gaining 283:22gains 318:17Gallagher 2:11 20:15Gallo 11:16 649:22,23650:7,9

gallon 285:6gallons 224:9 285:4game 417:20gap 152:23 156:8 172:19246:22

gaps 215:18 276:23277:21

garage 386:6,8,11,14,14386:17,19,22 387:20397:15 564:21,21565:3,9

garages 33:2 386:4Garbuck 10:22 525:17525:17

gas 158:23 160:14,18162:19 163:14 165:5200:12,16 237:17250:18 256:21,24,25257:16,23 258:19,20258:22,24 259:3,4,6260:8,13,18,23,24262:12,14,17,18431:21 432:4,7,17,23434:2 436:18 439:21440:5 441:1,3,4,5,6,8441:17,20 443:4,5,5444:7 446:3 447:9,23448:4,5 450:18 451:7

Gaseous 31:10gases 158:5,18 159:24160:1,2 259:21

gasses 107:6,19 148:14166:2 237:15 250:15346:19 440:19 442:23446:1 449:2

gauge 455:17 456:8466:19 467:2 468:2,20468:21,22,23,25 469:3469:6,8,17,19,20472:19

Gavitro 419:20GBH 86:8,17 90:17

92:14,23 94:7 95:1695:25 97:5 98:8,18100:6,15 102:2,11103:23 104:7 105:21108:12,24 113:22116:19 121:1,16 124:7125:18 126:4 130:4133:22 134:6 136:19138:18 139:3 141:18152:18 193:3 237:25268:22 280:25 320:4398:22 448:21 457:1460:4 485:4 553:9628:9 632:21 634:1,19640:15,25

gear 149:6,22 150:12154:19 155:17 181:9216:3 314:4,10 342:3342:7 429:8 512:6,6,8513:4 517:17,24523:21,25 524:10

gear' 512:9,10 517:10geared 191:25Gedrie 565:17,17Gedry 6:23 252:22,22272:6,6 290:13,13313:8,8,25 370:5,5377:23,23 449:8,8474:19,19 544:22,22555:2,2 572:7,7580:20,20 581:12582:1

general 13:11 27:14 36:444:18 45:19 46:2,1446:20,24 128:19 129:2163:13 175:19 222:22236:23 299:6 302:17310:10 384:16 405:6,7417:7 440:15 512:3550:7 614:2 641:25642:9

generally 88:16 96:15123:11 142:23 220:24336:21 513:5,10571:11 580:14

generate 251:16generated 208:18653:14

generating 87:21 184:16200:17 216:3 620:14

generation 96:17,25100:19 186:6 204:23388:18 601:1,2 613:18614:17

generator 304:1 570:18618:7

generators 298:5,10303:2

generic 129:7,13genesis 653:7gentleman 48:18 49:1651:6 59:11 72:14 80:683:18 85:16 207:19222:21 223:1,5 224:13246:13 252:3 301:15301:24 373:17 390:2397:22 407:13 581:13

gentlemen 12:8 20:1



Page 20

43:18 46:25 56:1068:23 72:2 83:1190:12 93:19 99:5101:2 102:24 104:17107:17 111:16 119:16119:20 120:9 124:2129:24 133:4 136:14144:22 146:19 151:7158:17 162:13 169:15172:2 177:1 216:21230:13 293:19 437:3490:6 532:16 587:11606:22 619:17

George 3:14 10:13 11:1947:6,7 81:11 83:19,20488:10,10 527:25,25528:11,11 532:21,21534:10,18,20,23,25535:4,4,4,7 632:3,3633:3 635:19,19652:22,22

geothermal 377:1German 130:7,8gesundheit 534:18535:9,10

Gethrie 9:22 437:7,8getting 69:21 116:2161:4 164:16 188:3191:4 197:10 205:9289:21 357:9 363:17388:8 395:21,23396:11 411:25 520:21576:4 603:22 621:5660:2

GFCI 353:25 354:3 357:3358:22 360:1 363:5,19366:15 369:21 372:6374:12 376:8 377:13377:17 385:4,14 408:7538:4,8,14,18 539:9539:13 540:14 541:5,8541:19 542:2,12,24576:9,14,18 577:7578:19 580:1

GFCI's 367:17GFCIs 335:1 366:7,11369:11 376:22,23403:7 543:19

GFI 397:5 540:10,11,20541:17

GFIC 398:4GFP 403:14GFPE 403:8 406:16,16407:17,21,23 408:6409:16

girl 360:4give 21:6,11 55:1 59:2173:2 80:7 126:23130:19 157:5 166:20182:9 192:4 210:23216:22 220:13 305:6474:24 475:1 482:17489:18 508:16 546:8574:23 644:2 660:1

given 25:12 171:13222:12 231:25 233:10241:17 290:25 305:5305:24 384:5 438:12

448:23 515:12 528:16528:19,25 529:5 563:7

gives 48:25 173:17561:25 569:3

giving 179:1 475:2glad 207:20 305:9Glenn 34:5,7glitch 38:13global 144:11 190:14251:25 284:22 294:15295:3 307:14 309:22310:8,20 402:14404:20 415:15 546:16547:6 567:5 638:20

globalized 552:2globally 140:3 552:3gloom 448:23GM 301:16,25go 12:23 20:5 35:1638:19 39:5,5,19,2147:21 48:12 49:6,1250:21 53:25 55:2260:10 69:10 72:24,2575:5 76:12 81:13,18143:1 155:1,3 156:13165:15 185:15 191:2199:21 203:7 205:16206:16 212:22 224:14230:17 250:7,15 254:6260:13 267:3,9 284:7287:14 289:7 301:23305:21 314:7,9 319:14322:17 332:7 336:20348:13,22 356:12360:14 376:22,23,24388:6 391:19,22 407:9407:12,12,18 417:25419:25 470:1 471:16471:18 476:9 478:2,3489:4 495:18 498:7510:12 551:3,19562:21 580:9 581:8586:2 594:3 605:11,13606:4 619:21,21,24620:10 652:19 657:24

goal 122:6 387:22417:21 418:19 563:19569:10

goals 278:5God 377:6 477:20 658:9goes 21:12 23:12 25:1926:22 27:23 28:1729:11 69:9 160:15174:22 183:19 187:21190:23 250:22 303:5,6313:15 344:23 364:1372:21 534:18 535:9,9560:2 620:9

going 25:10 34:24 35:139:4,19 40:7 54:18,1954:19 59:25 60:2464:8 65:24 72:3,873:15 74:19 75:19,1975:23 78:9,12,21 79:379:4,5,9 80:4 86:23130:6 151:19,23 152:4152:4,7 165:15 168:25181:16 186:12,23

190:21 191:2 192:19195:21,22,23,24199:10 201:18 203:5,6203:11,21 204:1,3205:16,20 207:7216:22 219:4,5,9224:13 229:17 239:7246:17 248:8 252:8,17264:2 271:8 278:2281:12 282:20 285:1285:25 286:20 287:11288:7 290:2 301:5308:8 313:21 315:7,13315:14,19 319:14324:18,22 333:2334:22 338:8 339:12339:13 341:18 348:13348:14,14 349:25350:2 367:25 368:3376:3,5,7,8,10 389:11390:5 394:19 400:13403:5 407:11,12,12,20408:2,18 410:1 415:9415:23 417:25 423:20425:6 426:22,25427:16 429:10 452:15463:17 464:25 465:2469:12 471:17 474:24476:9 489:4 495:17498:6,6 505:3 517:25521:12 522:17,19524:13 526:22,23531:3 534:21 546:11551:3,19 561:24,25576:21 582:6 586:25589:1 590:10 591:19606:8 610:12 619:3,20619:21 620:24 621:9621:10 643:23 646:19652:18,19 653:3657:21,24 658:1,23,24659:1,25 660:1

Golinveaux 10:2 453:13453:16,18 454:5,10,20455:21 456:15,24457:4,8,14 458:8,12459:2,24 460:16 461:8461:16,24 462:14,18463:5,9,21 464:2,20464:25 465:13,17467:7 468:4,14 470:8471:22 472:2,6,9,13472:15 473:7 474:18474:24 475:4,10476:11,17,22 477:2,5477:7,10,16,20,23478:1,5,9,11,15 479:7479:14 480:6,11,14481:6,12,16 483:20484:17 485:2,7,11,24488:8 489:4 490:5491:8,11 492:3,16493:2,8 494:1,6,20495:17,22 496:3 497:6497:11,14,17,22498:20 499:7,22 500:1500:3,6,20 501:1,19501:24 502:8 503:2,12

503:14,18 504:19,23507:7 508:7 509:14510:15,17 511:3,18,22512:1,18 513:18514:13 516:9,20 518:3518:20 519:7,19,25520:15,18,25 521:15522:3,7,21 524:3,17525:15,19,25 527:17527:20 528:3,9 530:1530:14,20 532:5,19533:20 534:9,17,19,21534:24 535:2,6,18,23535:25 536:9,15537:19,23 538:20539:19 541:21 542:4,8542:14 543:6,24544:20,25 545:6546:21 547:1 549:6550:25 551:19 553:7554:2,25 555:4,10556:14,21 557:1 559:9560:23 562:7 563:11564:8 565:15,19,25567:10,12,16,20569:21 570:23 572:5,9572:15 574:7,21,23575:6,10 577:16579:12 580:19,24581:5,10,15,24 582:2582:5,13,17,19,22583:8 584:10,14,25585:24 587:13,19588:4,13,15,23 589:5589:22 590:1,10,12591:8,23 592:9,18,24593:17,19,22 594:1,8595:1,14,21,25 596:2596:20,24 597:7 598:3598:18 599:3,8,10600:5,10 602:12 604:8606:14,25 608:7,21,25609:19 611:9,16612:13,17 615:1 617:2619:9,20,25 620:19621:18 622:14,21,25623:23 624:4,22 625:1625:7 626:2,15 627:9627:15 628:12,16631:4,23 632:19 633:5633:11 634:5,9,12,16634:24 635:14,22636:4,7,9,15 637:9,13638:1 639:10,18,24640:18,22 641:9642:15 643:3,9 644:8644:12,16 647:7 648:4649:9,20 650:5,8651:23 652:4,10,18653:23 654:2,6,8655:2 656:1,17,23657:14,16,18,20,23658:8,11,14,17,20,23659:10,13,16,24660:12

gong 70:2gonna 188:21 509:4620:10

Gonzalez 12:18 35:12good 12:7 19:25 35:350:14 59:13 62:9 81:383:24 85:15 111:21140:22 142:12 143:2152:12 172:7 174:19187:18 196:20 199:23208:24 225:11 270:12274:13,15 284:13286:8 287:6,16 294:12299:3 313:2 332:2344:22 388:17,17393:13 395:9 396:1398:5 429:11 451:11454:1 551:21 563:12571:3 579:17 582:15582:16 602:19,19607:9 644:9 653:19660:7

Goodson 8:14 358:5,5393:22,22 395:20,23396:1,4

Google 282:5 283:8368:5,6

Gorgan 648:9,10 654:9,9Gorgon 11:4 564:10,11gotta 331:22 332:7govern 13:16 550:10governed 200:14 213:19554:9,23

governing 13:15 17:23232:11 242:22 266:8309:17 413:25

government 178:25184:22 364:10 552:10553:2

grabbed 207:9 271:25375:3

grace 150:1 154:5156:14

graciously 19:21grad 394:16grade 216:9,9 447:5gradual 59:2graduate 358:8grammatical 233:6242:12 454:17 456:21

Grand 383:18Grande 382:9,11 392:6393:24

grandmother's 363:11granted 16:15Graser 10:4 454:1,2,12454:12 456:16,16458:4,4,14,14 464:17465:9,9,19,19 476:13476:13,25 477:4,6,12477:17,19 478:4,8480:3,9,9,12

gray 10:18 293:12325:13 494:25 495:2,3502:13,15

great 30:22 165:9 182:22314:14 341:25 477:12621:5

greater 89:13 152:9163:2 200:10 328:21341:16 386:13 407:20



Page 21

green 17:20 38:3 40:1862:15,15 74:4 76:11

Gregory 8:7 346:23,23grid 182:16 185:1,17186:14 200:24 299:13547:10 620:14

grommets 483:1gross 87:18 89:13ground 298:14 358:13358:15 366:3,5 368:15372:10 373:19 374:25375:5,7 394:22 395:5401:8,9,11,18,22403:4,11,17,18 405:8405:20 406:12,17407:2 410:19 420:3,4448:3 529:13,15,16531:21 538:17 541:7542:3 544:12 576:10576:12,13 577:5601:16,20 609:11

grounded 403:10 577:3602:1 607:24 609:8,16

grounding 214:12354:15 437:23 438:15533:18 578:14 601:22608:5,5,19

grounds 299:9group 21:22 24:3 93:5102:14 135:4 137:1154:3 187:12 195:13212:11 213:5 223:14224:24 232:20 241:19242:15,19 243:12244:12,20 245:23247:10,14,22 248:12248:13 249:2 252:2256:18 261:18 264:11271:13,13 273:21,23282:15 310:7 417:11417:11 435:13 437:11443:21 448:11 484:6517:6,7 539:25 542:23561:16 605:19 617:25653:8

group's 24:3groups 22:11 23:21,2324:7,8 195:14 201:8248:8,9,10,15,16277:2 287:3 650:1

growth 196:5GTR 549:1guarantee 139:22guaranteed 50:1Guard 87:5 88:19 90:296:20 97:7,13

guess 181:17 206:14283:4 330:1

guest 12:18 35:12guests 226:9guidance 82:20 141:4,24164:19 165:10 171:22172:1 175:3 196:25197:2 201:12 235:19257:6,7 268:6 278:2285:5 434:24

guide 13:22 165:14271:4

guidelines 87:14 141:14171:21 213:25 425:13

Guideway 119:22120:10,15

guinea 372:16Gurnee 5:19 185:25186:1

guts 519:5gutted 369:18guy 62:10 388:23 389:4509:11

guys 40:9 283:24 336:22478:24

HH 128:19 129:3ha-- 223:1habitable 365:8,9hair 354:20half 202:4 342:6,7 349:3447:13 607:25

hall 509:7 660:2hallelujah 281:4Halogenated 31:15Hamilton 144:11 185:10hand 74:17,19,23 75:1378:11,19,21,22 193:18205:18 215:2 302:13375:6 527:23 571:5650:12 657:21 658:1,5658:9

Handbook 159:24handle 171:14 173:23262:8 387:22

handled 83:1 307:15561:23

handles 296:19handling 29:6 107:6,18108:1 169:22 175:17186:6

hands 78:24 333:12Hang 657:16happen 58:25 75:19 78:9143:6 257:12 359:12359:24 562:4

happened 135:4 246:21281:17 284:12 374:23375:18 394:24 517:12

happening 205:23271:18 329:24 395:11419:11

happens 91:11 109:6156:4 203:17 291:4364:1 367:14 395:6,12609:12

hard 191:8 220:11278:17 338:12 400:12400:14 496:18 605:17618:17 619:2

hardened 128:20hardening 128:22harder 248:17hardest 22:12hardship 220:3 584:24hardwired 357:1,2HARLOW 1:22 661:5,18harm 150:7 314:20540:16 651:14

harmonics 384:13harmonize 444:8Harrah 9:13 419:18,18Harris 6:7 201:22,22Hartford 32:18Hartwell 2:17 25:19,2125:21 208:4,5,7,9,11358:20,20,25 390:20390:21 391:2 409:12409:12 463:7,8,11491:9,9,13 499:24,24500:2,4,7 516:22,23609:20,21 621:20,21

Hartwell's 362:25hashed 479:5haste 214:21hastily 215:10 220:10hat 222:21 223:5hate 527:17Hattler 3:15 48:20,21havoc 238:9Hayes 5:21 7:2 186:18186:19 187:7 204:14204:14,17 229:4,4254:21,22 255:7,9,14255:16,18,20,22,22,25256:3,5 257:25 263:20263:22 264:2,5,8,13287:20,20

hazard 58:9 90:4 165:1187:19,23 188:14194:22,25 204:10216:19 233:2,25 239:8280:13 328:22 354:11359:7 366:6 368:2377:12 385:16,17440:22 442:3 445:23568:25

hazard's 181:19,21hazardous 24:6 25:4165:20 178:15 199:12204:9 237:13 248:1359:6 438:21 440:19

hazards 58:5 89:15148:12 166:6 171:15182:6 183:18 186:22188:10 200:11 201:3201:14 231:19,21,21231:23,24 232:2,4,6,8232:25 233:12,14,18233:24 234:2,3,4,5,18235:13 236:5,15,18237:2 252:12 297:25298:24 303:18 346:5346:14 354:18 368:23369:6,7 446:11 448:7486:19 549:22 550:20559:22 560:9 563:20

HAZMAT 203:19head 505:22 644:3headings 632:9health 28:20,22,24 29:133:21 150:16 152:21153:4,14 155:16346:23

healthcare 56:22 57:757:23 59:14,16,1861:1 64:11 173:11,12

174:2 315:1,2 346:25hear 13:3 35:21 37:7102:7 108:21 161:23170:16 233:9 241:8302:17 308:8 337:23476:23 570:5 606:6630:15,19 632:23

heard 42:13 53:18 60:2062:9 71:14 141:21142:11 189:13 190:13191:20 196:10,10,19196:22 199:8 207:1235:4 238:13,15239:10 251:8,9 278:13278:25,25 286:4,22305:1,2 317:8 349:22350:4 356:3 363:22365:3,13 373:22381:22 389:17,19413:16 448:24 481:16498:3 505:6,12 546:8559:21 562:12,16574:18 578:2 591:17595:9 600:20 633:1,3647:19 653:12 654:24

hearing 71:9 210:9285:20 413:5 422:5570:9

heat 100:19 126:14,15126:16 127:19,20128:4,6,6 148:12243:20,23 247:18386:19 388:24,25

heating 87:21 164:20384:14

heavily 23:20 163:21201:7 603:9

heavy 151:17height 48:4 489:13held 149:23 221:9 252:3265:21 270:6 277:2300:5 409:9 414:15453:20 497:4 551:13

hell 127:3 187:3Hello 164:9 554:4 567:2604:13 649:22

help 42:2 111:8 112:9127:16 130:18 180:13187:11 318:4 319:20319:24,24 365:8387:22 441:7 582:3628:23

helped 22:15 222:10223:19 365:6

helpful 629:4 630:18,19helping 184:24helps 52:10 69:16 329:9525:9 606:9

Henry 12:18 35:12Herndon 7:13 305:7,11305:14,14,19,23 306:3306:9,9 321:25,25340:1 400:19,19,24401:6,14 424:19,19425:3 428:17,18 429:3493:22,22 494:9501:16,16 502:1511:17,19,19 512:3

516:13 520:14,17,20520:20 521:11,11522:1,1,9 584:8,8,16589:19,19 590:3593:14,14,18,20 594:3596:17,17 597:1624:20,20 625:3

herrings 285:21Herschel 237:25,25hesitates 24:11het 421:11Hey 332:17 505:4,17Hi 47:6 172:7 174:19194:7 392:4 405:3509:16

Hickman 8:17 360:21,22high 48:3 58:4,8,9 161:5165:5 187:18,20,23200:2 290:9 295:16372:15 395:6 486:16488:16 498:14 506:21506:22 552:9 563:20651:19

high-rise 482:7higher 141:12 160:11161:16 167:8 224:14247:24 363:8 489:1655:23

highlight 279:2highlighted 160:3281:16 569:2

highlights 386:7highly 178:14 185:21237:15

Highway 132:16 133:5557:17 562:18 563:17564:1 571:22

Highways 133:11 140:3Hilbert 8:13 293:9 355:4355:5,6 356:8 364:21364:22,23 365:18373:6,7,8 374:18381:6,7,8 402:7,9,10415:24 416:1,3

Hill 85:6hinder 200:23hindrance 51:3 88:25hire 325:15hired 582:2Hirschler 4:4 86:8,8,1786:17 87:6,8 90:17,1792:14,14,23,23 94:7,795:16,16,25,25 97:5,598:8,8,18,18 100:6,6100:15,15 102:2,2,11102:11 103:23,23104:7,7 105:21,21106:21,23 108:12,12108:23,24 113:22,22116:19,19 121:1,1,16121:16 124:7,7 125:18125:18 126:4,4 127:5130:4,4 133:22,22134:6,6 136:19,19138:17,17,18 139:3,3141:18,18 152:17,18193:3,3,8 268:22,22280:25,25 281:7,10



Page 22

320:4,4 398:22,22448:21,21 457:1,1,6460:4,4 485:4,4,9,12553:9,9,15 628:9,9,19632:21,21 634:1,1,7634:18,19 636:5,8640:15,15,24,25

Hirschler's 129:9historical 179:11 265:12324:24 645:21 646:15

historically 219:13 651:8history 223:24 265:10268:13 269:6,14270:13,13 272:1650:11

history's 269:11hit 73:8,10 188:22hits 436:9 498:19HL 528:13,22 529:11,21529:23 531:16 533:1,1533:2,25 534:14

HOFFMAN 161:23Hoffmann 5:4 158:6,6,14158:16 159:6 161:19161:21 162:1 167:14

hold 39:8,9,9 207:9322:4,4 350:17 396:18414:7,8

holder 426:6,9 429:13holders 425:4holding 544:12holds 383:24,25 638:9Holland 8:4 330:15,16366:18,18 410:8,8503:7,7

Holub 8:2 329:15,15330:10,12 340:16,16341:3,3 342:19 347:25347:25

home 41:7 166:12 358:1360:13 376:2,2,25377:18 398:10 530:10547:11 564:22,23,25565:10 580:6,12,17

homebuilders 353:2,16356:21 357:21 362:10362:24 367:1 371:20372:4 375:25

Homeland 153:9homeowner 385:11389:5 397:24 505:16

homeowners 372:15385:1 390:5

homes 357:23 369:8376:6 382:13 384:13388:18 398:1,1 482:20621:7

honestly 187:20honor 75:24 195:2 256:9honored 184:13hope 42:23 126:17166:10 241:16 243:13369:8 549:20 592:5

hopefully 209:12 313:22369:10 533:9

Hopkins 3:12 44:14,1544:20,21,24 45:4,1045:12,15,16 46:6,9

51:7,8,11,12,14,1661:12,13 65:19,20,2266:19,20,22 67:5,6

Hopper 2:19 5:15 26:5,8174:10,10 175:1180:20,20 198:8,8,14198:17 218:18,18237:8,8 238:13 249:12249:12 285:18,18

horizontally 141:6horns 12:22 35:16horrible 165:4horsehair 127:6Hose 144:9,23 145:3hospital 56:22hot 164:20 372:14 541:9hotter 469:17,21hour 246:22 247:22248:4,23 249:2,6,24250:9,20 252:9 275:20397:7 550:4,8 565:7

hours 22:18 222:15,15241:20,23 242:18243:12,19,20 244:13244:13 245:6,6 246:6246:10,10 247:10248:8 249:20 252:12259:5 313:17,22 550:6553:13 578:5 579:8603:8 605:20 617:23621:16

house 201:1 363:10369:18,24 370:1 377:8394:9 395:12,16 397:8409:20 553:21,25650:15

household 303:1 397:11houses 203:19 363:14390:7

housing 364:11 376:14Houston 5:18 177:19,20178:10 205:7,7 228:15228:15

Howard 2:19 5:15 7:1326:5,5,8,15,19 174:10174:10 180:20,20182:12,15 198:8,8,14198:17 218:18,18237:8,8 238:13 249:12249:12 285:18,18305:7,11,14,14,19,23306:3,9,9 321:25,25340:1 400:19,19,24401:6,14 424:19,19425:3 428:17,17 429:3493:22,22 494:9501:16,16 502:1511:17,19,19 512:3520:14,17,20,20521:11,11 522:1,1,9584:8,8,16 589:19,19590:3 593:14,14,18,20594:3 596:17,17,17597:1 624:20,20 625:3

Hoytabuck 495:3 502:16huge 348:16 648:21,23Huggins 2:21 26:23,25human 303:6

Humble 32:17humid 372:22humidity 372:15Humphrey 7:25 10:19293:10 319:16,16336:14,14 507:13,15507:15 508:13 512:23512:24,24 523:15,16523:16

hundred 125:11 189:1203:18 222:15 246:5277:10 349:18 444:10502:3,3 645:2 650:11

hundreds 24:10 47:15579:8 621:14,16

Hunter 7:17 9:10 311:4,4313:11 314:18 328:3,3344:6,6 351:3,3 403:1403:1 408:13,13,14413:9,9,17,17 418:24418:24 427:13,13455:25,25 468:15,15481:9,9,23,23 485:20489:6,6 492:19,20495:24,24,24 496:5,7499:9,9 514:15,15518:25 524:7,7 637:6637:6,15,15

hunting 606:4hurt 358:12 394:11HVAC 375:18,19 376:25377:6,11

hydraulic 50:18,23191:23

hydro-plants 184:16hydrogen 262:13hygiene 387:16

Ii.e 308:13IAEI 367:5 384:1,3478:21 602:23

IAFF 620:21IBEW 350:13,13 359:20360:22 365:25 375:13396:17 585:18 591:1594:22 597:23 625:21

IC 130:7ICC 245:23 287:4 383:24491:2,5

ICE 130:8 561:9icing 409:17icon 660:3Id 41:19,25 637:7Idaho 383:24 384:2idea 172:14 184:18270:12 317:9 318:13382:16 451:11 482:17506:5 561:22

identical 98:20 100:17163:8 286:16 422:19468:1 634:4,21 645:5

identifiable 42:19 66:2166:25 67:13 70:6,1476:9 95:17,20 97:1097:17 98:10,12 99:1099:16 102:4,6 103:3,8103:25 104:2 105:19

106:7 108:14,17 117:8117:17 121:3,6,10124:17 125:1,20,23131:12,24 138:19,22142:16 143:10,17212:13,13,16 225:19226:19 241:2,5 253:20294:17,19 304:5 323:2323:5 330:18 337:4338:22 340:19,24341:6 351:18 352:10353:3,8 356:16 361:18362:11,15 371:3379:22,25 399:24400:22 401:1 411:5,11439:22,25 450:3 454:4454:6 456:6 457:10,16458:6,9 461:13 463:22464:4 465:11,14468:11 475:23 476:15476:18 479:10,16528:1,4 536:11,17537:17,20 542:11545:19 546:18,22555:23 596:19,21599:5,12 612:11,14623:25 624:6 644:13656:19,25 658:3

identification 216:8618:24

identified 16:17 37:2540:16 55:6 56:5 131:2136:1 214:13 276:24325:22 328:8 330:21342:23 355:2 364:19373:4 381:4 402:5433:4 442:11 451:18454:23 459:5 467:11483:23 494:24 502:11507:11 512:21 530:4559:12 573:17 576:2577:19 585:12 602:16615:5 631:7 635:2638:9 641:12 647:11

identifier 336:4identifies 14:12 438:12identify 17:15 80:7231:15 318:4 319:21377:16 480:7 507:20549:11 626:22

identifying 131:2 236:6255:8 334:16 336:3341:1

IEC 318:23 437:9IEEE 177:24,24 212:9,21213:3,23 217:4 244:9261:17,18 262:13273:20 281:24 514:21515:12 645:7

IEEE-C2 183:9IEI 615:9IFC 188:2,3 192:22193:16 196:10,16204:20,21 205:3207:20 213:24 218:12244:2,22,23,23,23250:3 256:24 257:25268:4 276:4 279:6

286:6 288:10,13ignite 109:14,16 114:13122:9,10,11,12

ignition 87:22 110:14122:8 131:18 161:15163:13 488:18 529:14531:23

ignore 561:24ignored 207:11 246:23262:17

ignores 223:11ignoring 207:18 301:3551:15

II 34:6ill 129:19Illinois 23:13 24:1928:21 176:16

iMac 19:9images 289:24imagination 324:10331:10

imagine 346:7 491:10,14immediate 20:6 57:564:5

immediately 63:23118:15 168:18 420:1447:8 500:2 561:13610:13

immune 398:9IMO 142:7impact 22:7 24:22192:19 225:15,24245:3,4 251:14 288:3288:7 307:14 309:7,22310:2,11,20 404:7417:8 515:1 516:7531:4,4 532:25 569:7618:4

impacted 136:6 246:17impacts 225:10 397:20552:10

impairment 54:10,11,1554:20 55:15,23 57:257:13 58:12,16 59:2159:24 60:11,19 61:861:20,24

impairment's 54:22impairments 54:1061:15 63:22

impart 569:8impede 209:1 303:22,24303:25 341:11 343:19344:16 347:3,8 570:14570:15,16

impede' 347:4impeding 343:6 348:4imperative 61:18imperfect 148:13 288:5288:6

implementation 150:6154:8,17

implemented 54:17153:25 543:22

implication 312:8implications 288:2323:19 415:16

importance 14:1 175:18important 16:5 36:10



Page 23

54:8 61:21 81:16 89:589:12 91:13 105:17131:7,20 137:16 141:9154:6 160:2 161:14163:16 172:16,22178:16 185:17,19,21186:25 191:15 196:9225:1 267:3,8 269:15280:17 281:15 315:9318:18 319:11,22331:12 343:8,12,17,20388:10 390:22 436:1460:23 465:23 466:18467:1 562:20 563:23588:21 605:18 606:11631:2 644:23 651:21

importantly 271:18impose 182:24 201:8359:13

imposed 214:16imposes 474:5impossible 328:18344:19 458:20

impractical 275:21344:24

impression 277:14508:14

improper 154:21 376:2,7376:9

improperly 568:6improve 175:5 288:5454:18 515:6 542:1576:9 606:1 629:4632:25

improved 149:13 288:8357:23 384:20 466:12540:17

improvement 257:11288:1 456:11

improvements 19:17148:17 213:23 357:16

improves 456:12 647:5improving 20:20 281:11in-house 325:16in.' 192:12inability 515:25inadequate 61:20130:19

inappropriate 129:18166:8 487:20

inaudible 331:16incentivize 149:12incentivizes 248:19inch 447:13inches 100:19 282:6incident 13:1 35:19154:18 188:8 196:23200:3,9,11,18 201:6346:12 359:9 374:24376:1 394:6

incidents 88:21 96:17167:2 196:7 363:23366:10 483:13 547:23

Incinerators 29:6include 37:9 69:25 97:8111:12 148:14 149:10149:12 165:13 184:21189:20 196:15 205:18

206:24 217:11 237:1276:5 295:19 296:2299:16 302:22 312:14316:3 329:5 372:11401:14 406:13,14410:17 432:16 438:10455:14 474:8 524:22525:3 549:4 558:10564:6 584:20 587:24592:13 595:18 616:21626:11 652:13

included 14:4 194:14213:18 242:25 266:17275:9 279:5 296:5326:11 414:13 418:18419:3 438:3 460:8,14481:20 554:12 557:4573:22 623:15 632:17

includes 88:19 94:4114:16 183:14 192:22213:9 231:23 236:11295:11 316:18 411:1518:12 525:5 548:9588:1 592:15

including 13:17 16:1322:1 33:15 37:4 88:21109:7 112:2 172:10194:20 215:21 226:11242:6 267:25 268:3280:5 295:24 298:13318:5 334:11 335:1353:4,9 356:17 361:19362:12,16 371:4441:19 446:2 447:16470:15 473:1 546:15546:19,23 548:4 552:5552:6 555:24 556:20556:23 566:13 571:16591:4 594:16 597:3600:3,7 605:5 611:11611:18 629:13 630:9

inclusion 297:18 298:2incompatibility 397:10incomplete 287:1 359:2inconsistencies 392:22558:23 577:14

inconsistency 114:23558:17 577:9 630:6

inconsistent 110:13,18110:18,23 114:12315:12 646:11

inconvenience 397:19incorporate 285:13incorporated 25:22 32:4113:8 115:14 144:11191:6 231:5,18 258:15284:20 552:11 644:10

incorporates 318:8incorporation 128:13incorrect 53:24 198:5,22198:22 277:15 280:20499:12 607:19 609:7

incorrectly 219:7,9increase 134:22 260:25345:5 351:13 355:21357:1 393:7 438:19446:7,10 460:11 461:4

increased 148:6 489:1

increases 165:1increasing 90:4 242:17increasingly 298:8605:24

incredible 282:13283:18

incredibly 22:24 262:18incursions 444:11independent 113:2151:13 153:22 284:24284:25 387:23 426:2429:22 442:16 451:23631:12 635:7 656:4

independently 241:13index 89:8 91:1,2 102:15104:10

indexes 105:15 486:8indicate 14:18 17:20,22296:1 297:3 330:5437:23 474:21 618:13651:17

indicated 67:25 140:5295:5 296:8 397:22437:24 532:24 557:19638:24 642:12

indicates 55:16 68:7indicating 136:3,4335:20 398:2

indication 232:16241:25 242:18 265:17394:12 618:19

indications 483:9individual 21:9 87:12334:16 539:13 568:21

individually 416:11individuals 20:6 25:18164:4 241:13 387:6,23388:5 498:16

indoor 181:25indoors 250:13inductive 580:11industrial 27:8 32:22164:21 200:1 213:12314:3 345:4 447:21448:5 515:6 531:25

industries 174:2 179:3279:4 306:17 604:14

industry 128:25 149:13151:4,25 153:17155:23 163:18 173:2174:20 178:11 183:2188:9,12 190:17,18194:20 198:10 200:16200:21 205:15 207:11207:23 213:6,7 216:5217:18,25 224:4 245:5246:25 256:16 257:7257:13 276:10 283:22288:3 289:5,10 295:11300:19 301:7 306:12306:14,18 308:5,11311:19 315:13 319:24329:11,21 348:17352:2 398:7,8 410:19418:15 419:12 448:15491:3 518:14 525:13540:1,25 550:6 561:11568:10 569:14 570:6

600:1,13 607:3 612:9612:20,24 622:18

industry.' 562:2ineffective 445:4inert 163:14 166:1inexpensive 446:14449:5

influence 55:25 56:8Info 13:11 36:4inform 329:9 518:17525:10

information 17:19 43:744:5,19 45:19,23 46:246:14,14,18,20,23,2447:12,17 49:7,21 50:450:25 51:2,21 61:1781:15 85:9 86:2 89:4107:11 108:5 120:2,20127:17,21 128:8,18129:1,16,22 130:18,20131:9,16 132:22133:15 136:2,25144:15 145:7 146:12147:7 151:25 152:10153:7 158:9 159:2169:8 170:1 176:19177:11 193:23 201:21215:16 238:8 246:20247:1 258:2 259:13269:21 271:3,24277:17 280:19,20283:22 284:2,10,13285:14 293:1 294:4305:24 316:16,18324:25 328:14,20,23364:7 432:4,16,19440:18 444:24 469:16629:20 642:6,13 649:7

information.' 324:24informational 268:15318:6,13 325:21 326:8326:13,14,23 331:5432:2,17 434:11,21442:3 443:10 444:23543:2,12 641:23

Informative 434:13informed 72:7 79:23129:20 153:17 155:25234:11

infrastructure 172:9295:15,20,23 300:12301:1 547:10 548:12569:15

inherent 188:10 248:3488:17

initial 67:11,17 154:2234:9 235:4 366:2

initials 508:25initiate 38:1 40:16 261:3initiated 613:14injured 154:20 256:13injuries 380:21 386:11386:12 445:21 448:15561:6 562:22

injury 442:1input 111:3 191:11207:13,14,16 221:12243:1 249:18 266:11

266:12,13,13,17270:17 289:4 307:14309:14,16,18,24310:13,14,18,20,23317:22 323:22 366:2409:2,3 413:22 414:4414:4,4,9,13 415:13415:19 417:1,16 419:2431:2 440:9 442:19,24448:8 455:9 496:21497:5 523:1 585:7590:16 594:12 597:13625:11

inputs 22:9 220:25 226:2226:5 242:14,16265:17 277:4 307:10311:7 470:14 540:13541:11 603:3,7 605:20618:2 638:7

inrush 384:13inserted 149:16 341:21342:1

inside 105:24 142:3190:22 447:8 565:1648:16

insights 188:14insist 550:12 559:25570:12,20

inspect 47:11,22 369:22506:9

inspected 46:16,22inspecting 505:10 509:7inspection 27:10 33:2443:2,19,25 44:1846:12 47:11 52:3201:8 505:14

inspections 63:19336:21 569:1

inspector 49:10 337:1383:21,22,25 384:1389:3 508:2 607:15

inspectors 48:12 88:19347:20,23 355:8364:24 373:9 381:9402:11 416:4 432:3,6432:22 459:11 462:11467:17 484:4 507:17513:1 523:18 539:7569:1 638:18 641:18647:17

install 338:10 354:15384:22 528:23

installation 32:7 51:22177:7 183:18 184:2190:22 196:24 197:1199:1,2 204:24 206:15354:11,14 356:23376:3,8,9 433:20434:1,11,16 447:1448:5 462:11 487:21532:3 588:19 616:10

installations 22:6 116:2179:17 180:25 181:10181:25 182:19 183:8183:17 195:21 199:6201:13 215:22 216:7216:10 218:22 219:1219:24 220:1,1 225:9



Page 24

243:10 259:20 278:1288:24 297:3,9,18309:23 344:14 359:22359:23,24,25 372:17376:4 440:15,16 443:3446:6 452:4 469:14483:8 553:19 557:14575:21 576:13 605:23606:6

installed 46:21 47:2350:9 87:22,23 183:9192:15 214:5 216:2290:4 300:13 324:5,14335:13 359:4,6 444:17445:10 471:4 482:19482:20 487:6 513:10515:4 558:19 576:13631:19

installer 323:24 440:25442:5 508:2

installers 347:22 385:7434:18 440:25 462:11648:25

installing 164:20,21334:23 448:3 505:8656:15

instance 232:5 314:10494:11 616:23

instances 276:7 616:9instigate 535:16Institute 32:18 121:2,17124:8 125:19 126:5130:5 133:23 134:7136:20 138:19 139:4141:19 153:4,13 194:8357:7 460:5 485:5486:2 490:9 600:2,14607:4 608:10 612:10612:21 620:3 622:19

Institutes 122:25instruct 310:8instructing 531:10instructions 660:1instructor 508:17 509:20instructs 328:9insulate 330:1insulated 577:5insulating 88:23insulation 90:23,25 96:5137:19 471:4 487:4540:13 648:21,23

insulations 137:18insure 307:11integral 16:5 36:10280:4 328:12 405:21

integrate 560:16integrated 27:12 29:23171:2,12,24 172:25174:14 175:16

integrative 173:15 174:4integrator 187:7integrators 248:21integrity 112:13 141:9515:7

intend 203:15intended 68:15 149:10171:17 191:21 275:13280:3 302:23 319:5

341:22 344:9 351:15384:25 405:10,12409:13,14 448:12508:5 538:23 558:9577:1 580:13,16628:23 644:22

intends 472:23 474:8intense 154:4intensive 262:16intent 15:2 67:10 111:6111:15 122:19 123:23123:25 171:23 213:14261:20 262:7 344:22344:23 389:8,14 405:6405:7,22,23 425:3447:25 494:11 508:15510:1 642:12

intention 14:18 192:20235:17 288:19 296:7547:9

intentionally 654:16intentioned 341:8,9intentions 42:17interconnect 600:21,25interconnected 298:2600:17,18 613:18614:17 618:5

interconnection 603:1616:18 618:4 619:4

interest 203:20 205:22277:25 299:17 515:11660:14

interested 20:19 233:9282:15 557:20 653:6661:9

interesting 90:20 251:12373:14 489:10 494:9610:20 615:11

interface 172:20interfaces 558:24577:15

interfere 208:20interfering 548:16Interim 205:21 610:14interior 127:2,10 130:8130:10,12,14

interlock 531:22interlocked 528:13,20528:23 529:11,13,15529:18,21,23 533:10533:15,25 534:11

interlocking 531:17intermix 474:4internal 303:8 440:7442:21 447:15 561:9

international 86:9,1887:5 90:18 92:15,2494:8 95:17 96:1 97:698:9,19 100:7,16102:3,12 103:24 104:8105:22 108:13,24113:23 116:20 121:2121:17 124:8 125:19126:5 130:5 133:23134:7 136:20 138:18139:4 140:21 141:19142:2 152:18 189:9193:4 195:11 196:12

207:25 209:13 219:21223:16 235:2 238:1249:21 268:23 281:1284:3,8 286:18 289:14299:4 309:3 320:5330:25 345:11,12347:19 349:12 355:7364:24 373:8 381:8398:23 402:10 404:2416:3,19 426:19435:23 448:22 457:2459:10 460:5 467:16484:3 485:5 497:25507:16 513:1,24523:17 539:6 551:22551:24 552:4,8 553:10563:13,24 567:6569:17 571:4 579:18591:14 628:10 632:22634:2,19 638:17640:16,25 641:17647:16

internationally 69:14interpret 235:15 266:24267:7

interpretation 249:1295:19 296:6 515:21548:20 645:22 646:4,5646:14,16 649:1

interpretations 644:21interpretative 644:23interpreted 52:5 515:18558:10,21 577:12

interrupt 507:7 527:18534:22

interrupter 368:16 395:5401:20,22

interrupters 358:14,15interruption 164:17420:3,4

Intertek 301:13 435:7498:24 516:12 533:23

intimately 187:1introduce 20:5 118:17168:20 212:22 242:24266:15 268:15 392:22414:12 453:13 472:17

introduced 35:4 243:5266:5 267:11 276:4307:12,13 317:23327:16 425:22 444:14516:13 523:2 585:8590:17,18 594:13,14597:14,17 625:12,14638:8 654:13 655:8

introducing 164:2 182:5182:6

introduction 384:7,9invading 209:5invaluable 24:17 50:25inverter 248:6 395:14558:11 578:22

investigate 547:23investigated 394:13investigation 55:1988:20 394:2 455:11571:25

investigators 393:25

investor 194:11 195:24209:3

investors 195:25invitation 143:1invite 19:18involve 373:12,13 525:4involved 22:3,12 24:282:11 187:1 207:2223:22 276:14 280:11311:6,7 347:6 413:3416:9 456:4 525:5601:13 621:15

involvement 310:24involving 150:2ion 189:21 190:2,15,20192:1 197:1 213:17215:4 246:5 250:13252:6 256:22 257:3,15262:9 274:17,20,24275:12 279:13 282:24283:3 285:23 288:19288:20,24 289:1 290:5

iPad 643:24 659:2iPads 192:6,8 279:16660:3

ir- 582:5iron 32:18 252:10 436:8ironically 505:7irregardless 233:25277:16

irrelevant 105:16 554:17570:10

irreversible 426:11irritating 187:3ISO 134:19 135:6 137:2137:3,4,19 142:5,6

isolated 359:9 377:14isolating 166:3isolation 563:18 576:16579:25

ISPs 152:7 153:17154:22 155:24 156:6156:21

issuance 15:13 16:11,1236:16 37:3 44:7 86:3108:7 120:22 133:18145:9,22 147:10 159:5170:4 177:13 294:7

issue 16:24 24:20 52:253:23 55:14 59:2260:8 61:15,23 63:964:17 68:1 74:14 83:183:10 88:23 96:3102:13 113:14 121:18154:6 156:10 157:6165:23 173:5 180:24205:21 209:8 222:18224:5 232:10 242:21251:19 291:3 297:17299:14 300:3 309:6310:6 319:6 324:20325:2 343:18,22 351:5356:2 363:13 366:1367:18 377:2,7,16,16387:25 388:9 397:13398:16 415:8,9 429:11429:12 433:24 435:12436:6,7,7 443:19,22

443:23 452:2,14454:24 455:2 463:1467:12 468:19 471:10474:2 484:5 496:24502:12 523:7,11533:17 544:15 551:8551:11 553:17 558:2561:15 562:6 578:25585:21 591:6 594:23597:10,25 601:25602:7 603:3 607:10,11611:6 612:22,22625:23 630:21 638:4638:13 645:12

issued 16:23issues 64:15,24 162:11183:1 201:6 204:2206:3 213:15 216:14216:20 225:15 235:24235:25 239:13 274:21275:17 279:1,2 287:8296:16 342:23 355:1357:13 364:18 373:3373:24 381:3 384:8387:13 388:6 389:8402:5 408:18 425:18429:17 433:4 434:7,14442:11 451:18 454:23459:5 467:11 471:17483:17,23 494:23502:11 507:11 512:14512:21 514:3 519:15522:24 530:4 540:15544:9 550:2,3,7 552:7553:3 559:12 561:12568:9,22 571:24577:19 578:5 584:17585:12 590:21 594:4594:17 597:18 602:15615:4 625:15 631:7635:2 641:12 647:11648:22,24 651:16,17

issuing 37:8It'd 187:5ITE 522:11item 46:15 60:15 136:7210:20 221:19 253:9272:25 299:20 334:6339:10 401:6,24,24409:14 425:22 485:15485:16,17 489:23492:9 512:5 531:12,17601:7 603:9

items 61:5 109:21115:21 206:2 237:21258:21 389:22 403:6412:24 496:20 497:1569:6 627:3

JJ-1766 552:8,11J.M 113:1Jack 6:17 240:1,2 374:7374:8 418:6,6 461:10461:11 468:9,9 484:22484:23 542:6,9,9

jacket 355:20jacketed 486:10



Page 25

James 3:3,18 4:15 5:105:16,18 10:2 29:11,1229:14 30:8 53:12,1253:21 140:16,16168:20,24 170:5,8,8170:12,16,18 171:7172:2 173:8 174:8,17174:23 175:8,21176:12,15,25 177:15177:19,19 178:2,7,10180:18 182:8,11 184:5185:23 186:16 187:5189:4 191:2 193:1,7194:5 195:7 197:6198:1,4,7,16 199:18200:4,6,8 201:18202:16 204:12,16205:5,7,7,24 206:10208:2,6,8,10 209:10209:17,23 210:9,18,23211:2,6,11 212:2,15212:19,22,25 213:2215:5,7 216:21 218:5218:16 220:5 221:17221:22 223:4 224:21225:18,22 226:17227:12 228:1,15,15,18229:7,17 230:17,20,23231:1,7,11,15 233:20233:22 234:21 235:22236:6 237:7,23 238:21238:25 239:14,18,24240:4,9 241:4,8243:15,17 244:3245:18,25 246:2 247:3249:10 251:4,24252:20,25 253:6 254:6254:9,12,25 255:4,8255:13,16,19,21,24256:2,4 258:12,14259:22 261:13,21,25262:3,5,24 263:2,3264:1,4,6,13 265:1,4267:13,15 268:17269:24 270:3,21 272:4272:11,14 274:1,5,8274:12 276:16,18278:8 280:23 281:21283:13 285:16 287:18289:11 290:11,17,23291:2,8,11 292:16,18292:20 293:16 294:8294:18,22 296:10299:1,22 301:10,17,19301:22 302:6 304:4,9305:9,12,18,20 306:1306:4,6,20 308:22311:2 313:6 314:23315:23 316:21 317:3318:20 319:14 320:2320:11,14,18,22 322:4322:7,12,15,17,24323:4,8,10 325:25326:18 327:23 329:1329:13 330:9,11,13,22331:19,21 332:4,6,16333:20,23 335:6336:12 337:3,9,13,15

337:17 338:11,18,20339:23 340:5,20,23342:18,20 344:1 345:7345:18,21 346:21347:16,24 349:9350:11 351:1,17 352:4352:8 353:6,13,20354:23 356:7,9,19358:3,19 359:16360:19,24 361:5362:14,21 364:15365:17,19 366:17,23367:20 368:11 369:13369:15 370:4,8,14371:22 372:1,25 374:2374:13 375:9,22376:16 377:21 378:2,6378:12,22 379:24380:3,25 382:1 383:15385:19 386:25 387:8388:15 390:18,25392:2,9 393:20 396:10396:22 398:20 399:4399:11 400:23,25401:4 402:2,21 403:24405:1 406:4 407:7408:11 409:11 410:7410:13 411:4,9 412:3412:17 413:12,16415:5 416:14 418:3,11418:22 419:17 420:7420:13,20 422:1,5,24423:1,7,16,24 424:3424:22 425:1,15426:14 427:4,6,10,21427:25 428:21 429:1429:14 430:3,10 431:5431:10 433:1 435:2,9435:20 436:20 437:5438:24 439:4,24 440:3442:8 444:2 446:18448:19 449:6,10,16450:21,23,25 451:5,15452:7,19,23 453:13,18454:5,10,20 455:21456:15,24 457:4,8,14458:8,12 459:2,24460:16 461:8,16,24462:14,18 463:5,9,21464:2,20,25 465:13,17467:7 468:4,14 470:8471:22 472:2,6,9,13472:15 473:7 474:18474:24 475:4,10476:11,17,22 477:2,5477:7,10,16,20,23478:1,5,9,11,15 479:7479:14 480:6,11,14481:6,12,16 483:20484:17 485:2,7,11,24488:8 489:4 490:5491:8,11 492:3,16493:2,8 494:1,6,20495:17,22 496:3 497:6497:11,14,17,22498:20 499:7,22 500:1500:3,6,20 501:1,19501:24 502:8 503:2,12

503:14,18 504:19,23507:7 508:7 509:14510:15,17 511:3,18,22512:1,18 513:18514:13 516:9,20 518:3518:20 519:7,19,25520:15,18,25 521:15522:3,7,21 524:3,17525:15,19,25 527:17527:20 528:3,9 530:1530:14,20 532:5,19533:20 534:9,17,19,21534:24 535:2,6,18,23535:25 536:9,15537:19,23 538:20539:19 541:21 542:4,8542:14 543:6,24544:20,25 545:6546:21 547:1 549:6550:25 551:19 553:7554:2,25 555:4,10556:14,21 557:1 559:9560:23 562:7 563:11564:8 565:15,19,25567:10,12,16,20569:21 570:23 572:5,9572:15 574:7,21,23575:6,10 577:16579:12 580:19,24581:5,10,15,24 582:2582:5,13,17,19,22583:8 584:10,14,25585:24 587:13,19588:4,13,15,23 589:5589:22 590:1,10,12591:8,23 592:9,18,24593:17,19,22 594:1,8595:1,14,21,25 596:2596:20,24 597:7 598:3598:18 599:3,8,10600:5,10 602:12 604:8606:14,25 608:7,21,25609:19 611:9,16612:13,17 615:1 617:2619:9,20,25 620:19621:18 622:14,21,25623:23 624:4,22 625:1625:7 626:2,15 627:9627:15 628:12,16631:4,23 632:19 633:5633:11 634:5,9,12,16634:24 635:14,22636:4,7,9,15 637:9,13638:1 639:10,18,24640:18,22 641:9642:15 643:3,9 644:8644:12,16 647:7 648:4649:9,20 650:5,8651:23 652:4,10,18653:23 654:2,6,8655:2 656:1,17,23657:14,16,18,20,23658:8,11,14,17,20,23659:10,13,16,24660:12

Jane 383:20,21 384:4January 391:10,21jargon 506:7

Jarrod 4:12 119:24120:8 122:16 124:9,21128:13 131:15 132:12

Jason 11:8 604:13,13617:7,7

Jay 4:24 153:3,3Jeff 9:4 75:5 392:4,4,10jeopardize 188:6 189:1jeopardy 156:16Jersey 132:19jet 214:17Jim 5:1 7:8,16 11:7,14141:21 154:13,13255:10 256:5 299:3,4309:2,3 330:24,25332:21,25 345:9,10,20345:23 349:11,12365:18 404:1,2 416:18416:19 426:18,19435:22,23 497:24,25513:23,24 551:21,21563:12,12 571:3,4579:17,17 591:13,14602:17,18,19,22,22607:6 615:7,9,9 644:7644:9,10,18,18 654:13

JM 115:13job 24:18 148:13 186:5201:14 547:17

Joe 10:15 490:8,8Joel 7:2 11:4 287:20,20564:10,10 648:9,9654:9,9

Joh 375:11John 4:2,8 5:8 6:16 7:108:16 9:11 85:5,1588:13 91:20 93:1594:23 96:11 97:1399:1 101:10 102:20103:5 104:14 106:4107:2 111:21,22 113:1115:13,13,18,20 164:9164:9 221:21,23,23299:24,25 359:18,19365:23,23 375:11418:12,12 436:21,21497:8,8,13,15,18518:5,6 532:10,10551:5,5 586:4,5 598:4598:4 606:16,16619:11,11 642:20,20649:11,11

Johnson 57:17 69:4Johnston 7:4 293:8,16293:18 294:8 296:10296:12 304:6,8 306:20306:22 307:24 308:1325:25 326:2,22 337:6337:7 338:16,19342:20,22 352:4,6354:23,25 364:15,17372:25 373:2 380:25381:2 402:2,4 411:7,8415:5,7 423:1,3,24424:1 425:15,17427:23 429:14,16430:9 433:1,3 439:1,2442:8,10 451:15,17

452:21,22 454:21,22457:11,12 459:2,4463:23,25 467:8,10478:12,13,16 479:12483:20,22 493:4,6494:20,22 500:22,24502:8,10 507:8,10510:19,21,24 511:2512:18,20 519:21,23522:21,23 530:1,3536:12,13 538:20,22549:6,8 559:9,11569:21,23 577:16,18584:25 585:2 589:1,3590:12,14 592:20,22594:8,10 595:23,24596:1 597:7,9 599:6,7599:9 602:12,14611:12,14 615:1,3624:1,2 625:7,9627:11,13 631:4,6633:7,9 634:24 635:1636:12,13 638:1,3639:21,22 641:9,11643:5,7 647:8,10656:20,21 659:22

Johnstons 292:24join 21:3,13 23:8,14 25:625:20 26:5,23 27:2428:18 29:12 31:1166:10 293:13

joined 23:17joint 561:16 562:6 576:3Jonathan 3:24 32:17,1964:10,10

Jones 9:25 442:13,15,16451:20,22,23 631:9,11631:12 635:4,6,7

Jose 189:8journeyman 383:23396:17

judgment 585:5Julian 7:14 293:11307:21,22 308:3425:24 426:1,2 429:19429:21,22

July 36:18 180:3 661:14jumped 305:6jumper 602:3 607:17,18610:8,8,18,19

jumping 129:22JUNE 1:8 12:3 119:10230:7 412:11 527:11

jurisdiction 48:22 49:482:11 83:7 87:13116:14 139:11,13184:21 206:6,19,23336:18 347:7 487:17487:23 507:5 509:1,6517:4 629:12

jurisdictional 83:1,10jurisdictions 48:2451:17 68:16,18 83:5179:3 199:6 207:8248:24 286:22 508:23

justification 244:21245:2 313:1 541:1

justifications 189:12



Page 26

justified 346:2justify 214:19 528:17justifying 233:1Justin 6:14 218:7,7

KK 438:1Kampgrounds 542:17Karen 5:2 155:7,11,11keen 203:20keep 12:14 38:24 79:4111:7 185:17,18186:12 188:17 203:14221:18 281:11 287:13287:13 288:8 314:16318:11 330:20 366:21388:4 389:6 410:11494:12 506:23 514:4538:8,14 544:16578:10 580:2 581:10582:23 605:8 615:15

keeping 296:6 443:8538:18 562:19

keeps 208:16 260:25Keith 3:15 8:8,19 10:648:20,21 347:18,18374:15,16 455:3,5459:7,9,9 467:13,15467:16 478:18,20,20479:3 484:2,2 537:14537:15,25 539:3,5,5543:25,25

Kelly 8:23 383:17,18Ken 296:21 326:17,19,19343:2 562:9,9

Kenneth 4:10 7:7 118:17118:21,25 119:20120:23 121:4,13122:14 124:2,16,23125:8,22 126:1 128:11129:24 131:11,21132:14 133:19,25134:4 135:18 136:14137:21 138:1,21,25139:24 140:12 141:17142:15 143:9,14 144:7145:10,14 146:4147:11,21,24 148:2150:18 151:7 152:15153:1 154:11 155:5,9156:25 157:9 158:3159:6,11,15,19 161:19161:22,24 162:13164:8 166:14,18,21,24167:10,21 296:20,21342:25 343:2

Kennewick 34:12Kentucky 28:2kept 153:17 155:25395:11

Kerry 2:7 19:25 20:2,1020:14,17 23:8,11 25:625:9 26:1,19 27:2028:13 29:8 30:8,2231:20 34:21,24 35:3

key 127:17 235:24,25278:24 279:5 386:1397:2

kick 260:14kicked 282:12Kicking 319:22kid 506:24kill 505:4,20 634:10killed 358:13 360:5394:12

killer 303:7 560:4kilowatt 241:20,23242:17 243:12,19,19244:13,13 246:9,10,22247:10,22 248:4,8,23249:2,6,20,24 250:9250:20 252:9,12275:20

kilowatts 242:16kind 69:8 96:24 112:5165:20 170:24 189:25199:10 205:12 219:10223:10 237:2 285:21347:9 359:14 388:22401:9 409:25 473:20491:15 576:3 610:6

kinds 81:15 112:4,4409:18

kitchens 543:20knew 188:16 271:17320:8,10 417:17508:24

know 20:17 49:11 54:1258:1,20 60:22 61:2262:11 69:14 70:179:22 127:6 136:23139:13 141:5 143:5164:16 165:19 173:20174:11 185:8 188:15193:21 203:12 205:11205:11,13 209:7 215:9216:13 217:20 219:15219:18 220:2 221:10234:13,16,17 236:20239:9,19,21 249:16269:21 271:9 277:5,13277:14,19 281:16282:23 284:24 286:4286:22 303:4 313:15317:25 323:18 324:4,8324:12,16,19,25 325:1325:18 329:23 330:3332:21 342:7 345:24348:5,21 349:1,3359:12 360:10 368:3376:4 389:1 390:21391:9 394:16 395:6,17397:11,18 404:6407:10 415:8 417:20419:13 429:6 441:24441:24 458:20 462:5463:15,17 465:24470:13 483:16 500:8500:16 506:14 507:4509:6 517:25 518:10519:1 560:1 576:19579:6 581:12 607:7,15613:6,7,21 618:16628:24 641:2 643:22657:23

knowing 94:18 426:5

knowledge 24:16 190:4275:16 316:6 410:23462:12 506:5 518:15518:16 525:3 598:12

knowledgeable 204:5known 96:21 116:3148:14 274:18 299:17327:15 383:11 392:25489:12 508:17 548:7551:24 648:22,24

knows 89:25 282:24458:25 506:21 607:16

Koffel 3:11 43:4,4,12,1643:18 44:8 46:7,952:16 54:25 55:264:24 67:18,20 70:1082:14,16 84:6,24,25

Korea 278:1Kovachic 7:10 299:24,25436:21,22 532:10,11551:5,6 586:4,5606:16,17 642:20,21649:11,12

Kovacich 619:11,12Kurt 11:17 651:25 652:3652:7,7,11

kw 222:14,15

LL 548:8La 382:9,11 383:18392:6 393:24

lab 471:13 524:2 571:14651:7

label 312:25 328:12330:4 337:25 338:7,9338:9 510:3,5,7637:22

labeled 93:3 94:2,3512:11

labeling 324:18 409:6496:14,22 505:9523:25

labelled 49:7 94:9,10524:12

labelled' 94:5labelling 334:14labels 328:15Labor 350:5laboratories 29:2 34:14150:3 156:21 300:1

laboratory 153:12333:14 462:3 471:12471:14

laborious 308:6labs 136:24 141:10151:2,20 154:24 156:1474:12 517:23

lack 91:13 310:24358:13 367:4 432:10432:11,12 516:5 576:7

lacking 383:5lacks 173:17 558:7576:25

ladies 12:7 19:25 43:1872:2 85:15 107:17119:16,20 120:8 133:3144:21 146:18 158:17

169:15 176:25 230:13293:19 437:2 532:16587:11 606:22 619:17

lady 390:4laid 538:16 543:4land 202:5 364:2 645:18653:10

language 54:1 55:2156:3,3,6 68:20 81:2281:22,25 82:5,5,22,2383:6,10,23 110:10,11129:7 142:13 170:21170:22 171:5,10,20172:13,22 173:1 175:5205:2 207:20 233:3246:16 256:23 260:4,6261:9 265:16 271:6,10282:10 296:3 306:15316:3,15 329:6 330:7331:14 341:7,21 342:1342:14,15 344:17,23345:1 347:3,4,10351:14 353:23 355:24363:4 364:2 365:9366:21 372:5 376:12403:15,22 404:7408:20 410:18 413:19413:21,23 414:16418:18 419:1,4 420:6443:11 455:14 463:14481:25 491:2 496:9,11496:15,19,21 497:3499:4,15 507:19 514:4514:18,22,23 515:1516:2,4 517:8,12519:14 524:22 533:11539:14 540:19 548:13548:19,22 549:3554:11 561:17 587:24592:13 595:18 603:11603:20,25 604:3,23605:6,15,16 606:9608:13 616:2 617:12617:22,25 618:7626:11 630:22 632:16637:17,19 648:1 653:7653:15

language.' 515:9languages 508:1,15laptop 263:19 282:7285:22 580:10

laptops 192:13 198:18280:8 282:2,3 285:23

large 179:1 181:1 182:16192:25 195:20 200:23243:21 246:1,4,11247:21 248:19 249:1250:2,10,14,19,23251:11,15 252:5,16257:15 279:10,13,19279:21,25 280:7 282:5282:15,15,22 289:25341:14,15 343:7,14344:15 345:2,25 346:3349:16,20 350:8 351:8354:17 401:17 406:19409:24 486:15 515:3

largely 122:20 360:14

larger 89:10,15,16128:14 222:24 252:7308:14 356:25 386:15401:14 407:19 499:2

largest 147:19 148:4Larrimer 33:9Larry 7:23 293:10,11318:22,22 377:10

Larson 8:25 385:21,21late 315:8 520:21latest 127:13 130:10335:18,25 506:18

Latin 461:2 473:22Laughlin 8:8 347:18,18laughter 39:13 71:1579:24 127:4 148:1211:1,4 223:6 240:5264:7 281:6 289:18292:19 307:25 313:24320:9,13 331:23 332:8332:11,23 333:25358:24 378:5,21395:22 418:9 423:23427:3 472:7 475:3477:9 479:2 480:5481:5 503:13 510:4,9510:14,16,23 511:1527:1,19 530:18535:20 553:14 579:4581:23 582:4 602:21634:11 652:2,6 657:15658:10,16,18 659:12660:9

laundry 237:19law 179:2 364:2lawfully 205:1laws 661:11lay 180:14layout 89:19,23lead 181:5 182:24190:18 194:18 196:21207:15 213:9,17,21,25214:7,9,19 215:21217:7,17 218:9,12,21218:24 219:4,6,13222:14,23 224:10225:2,5,14 244:24245:8 257:1 262:11275:2,23 282:8 288:14288:22 328:21 336:10392:15,16 541:9552:15

leaders 180:6 552:3leadership 43:14 293:14382:18

leaderships 180:9leading 386:16League 322:2 400:21424:21 428:19,19493:24 501:17 520:22

leak 441:4leak- 441:8leakage 377:13leaks 441:14,17learn 256:15learned 185:3 190:11200:19 543:11

learning 188:13



Page 27

leather 127:6leave 13:4 35:22 41:1594:17 118:12 168:15376:10 519:4,4 608:5

leaves 156:7 445:5lectured 510:15led 153:15 384:14Lee 122:24left 20:7,14 277:21292:18 327:11 346:11390:8 412:24 498:17606:3 613:5 660:4

legacy 79:5 127:2,6,7129:13 130:7 207:15218:11

legal 83:5 208:20 324:20330:2 425:8

legally 568:14legislative 568:21legislators 364:4,5Legislature 208:20legitimate 473:17 646:15LEL 260:24 261:7Lemoff 5:5 159:9,9,18159:20 162:5 166:19166:19,23,25

Lemoff's 166:11lend 513:4length 155:21 438:17602:8

lengths 435:17lengthy 19:5 443:1,17Leo 11:10 608:8,9619:23 620:1,1

lessen 392:18lesson 200:20let's 26:4 30:11 34:2137:14 39:5,5 44:8 48:166:16,17 67:4 69:1169:13 86:5 92:11100:3 102:10 108:9120:23 125:15 133:19138:14 145:10 147:11159:6 170:5 177:15185:9,10 212:5 227:7228:13 229:1 230:17231:1 240:23 249:8254:19 263:17 264:1,4264:21 273:16 294:8305:4 315:5,5 339:23340:13 347:14 349:23352:22 356:12 379:16382:5 393:16 396:11400:16 421:20 424:17428:14 430:24 439:18453:23 458:1 464:14465:6 481:6 493:19498:18,18 501:13504:15 511:15 520:12521:8,23 527:20537:10 546:10 556:9561:16 566:24 567:12567:12,12 573:13,24574:23 584:6 589:17593:11 596:14 599:22612:5 615:23 616:1624:17 628:6 633:23637:3 640:12 643:25

644:5 657:20lethal 446:12Letonen 5:2 155:7,11,11letter 44:2 85:24 108:2120:17 133:12 145:4147:4 158:24 169:23177:8 294:2 441:22548:20

letting 79:22 189:14level 22:13 60:19 61:7,24219:16 224:14 243:19243:25 249:25 258:24261:1 290:3,9 364:9393:9 407:23 438:19488:12,16,21,24 489:1655:23

levels 148:7 237:16251:15 303:9 364:10486:16 651:2

levels.' 251:17Lewis 185:10Lexington 28:2LFL 259:1,3LFP 247:16,19,23,25248:2 252:10

liability 333:15liable 248:25Liaison 159:22license 275:12 396:19licensed 604:17life 26:11 27:3,5 29:1730:2 31:6 32:20 33:5,633:13,19 34:1,1,349:19 50:14 56:1663:16 88:25 172:21173:4 185:19 186:24187:22 188:7,21 189:2256:14 359:8 387:14387:23 388:6,8 397:20398:7 406:22 586:13587:5 588:20 592:4

light 311:13 340:1 347:8608:9 620:2

lighting 384:14lightning 433:12,17,19433:20 435:11 436:6,8436:9 437:10,15,17438:9,14

lights 12:23 13:2 35:1635:21 279:23 505:17

limit 18:10 200:24 245:5247:10,14,22 248:4249:6,25 251:10 350:1413:3 471:9 474:14483:3 613:16 615:23616:1

limitation 123:18 238:3244:25 447:17 482:3482:11

limitations 216:9 487:1487:7,8

limited 129:22 133:11140:2 181:8 236:3,13239:23 342:9 372:23375:14 404:9,10406:19 438:11

limiting 234:2,17 238:17limits 244:1 245:11

250:8 576:16Linda 2:9 11:5 20:7585:14,16,16 590:22590:24,24 594:18,20594:20 597:19,21,21625:16,19,19

line 59:7 60:18 184:13202:7 291:1 295:9,18296:5 303:15 463:15490:6 594:4 630:2652:20

lined 201:20lines 160:10 161:17196:2 388:23 448:6508:19 629:21

lineup 314:9lining 130:14link 109:25 373:17 645:7650:23

linked 41:18Lion 155:12 156:17Liquefied 158:4,18,23159:23

liquid 161:1,2,3,10,17163:3 167:8 347:4

liquids 446:1list 41:10 141:7 201:5237:19 299:21 311:24403:6 419:5 496:20509:25 524:14

listed 89:9 93:3 94:2,4,994:10 115:22 248:23249:3 270:9 309:25310:15 312:14,16,17312:22 329:23 404:15417:3 420:5 438:2459:14,18,19,22460:10 463:2,20486:22 512:8,10,11524:11,13 533:25568:24 578:15 614:19632:13 645:15,18,23646:9 648:17 649:1,3651:6 653:7 655:24,25

listen 86:23 143:3393:16 427:20

listened 578:8listening 463:8,12listing 94:4 216:6 275:22312:24 323:17 324:6,7324:15,17 325:1 327:2327:6,11,15,17 328:5328:10,10,19 329:6,20330:6 331:8,11 333:8333:17 334:14,15335:10,12,16,23 336:2336:2,3,6,19,21 409:5419:9 458:17,19,24459:15 460:23 461:14462:4 463:2,14 496:14496:15,22 523:24525:7,9 567:8 568:6,7568:14,16,19 569:4571:6,14,15 578:22637:24 645:17,25

lists 295:22literally 270:16lithium 189:21 190:1,15

190:20 192:1 196:25213:17 215:4 246:5247:12 250:13 252:6256:22 257:3,15,16262:9 274:17,19,24275:12 279:12 282:24283:1,2,2,3,9 285:23288:18,20,24 289:1290:5

little 11:5 54:4,23 166:20166:25 171:5 173:2187:6,24 191:14219:11 281:25 314:22358:22 496:1,25 506:7506:24 510:25 512:16517:8 520:16 576:6585:14,16,17 590:22590:24,25 594:18,20594:21 597:20,21,22603:21,22 625:17,19625:20 626:20 641:20654:22

live 369:17 387:23444:18 446:1 482:20552:21

lives 335:2 369:9 372:13377:17 389:10 398:17562:22 587:8

LLC 26:8 296:22 326:20343:3 436:22 532:11551:6 562:10 586:5606:17 619:12 642:21649:12

load 112:13 130:15349:18 505:17 609:25610:1 620:13,16

loads 397:18 557:11560:16 575:17 580:12580:13

local 69:17 82:2 83:2206:5 207:4 440:25442:5 487:20,22

locally 68:14 83:2located 43:6 85:8 107:11120:1 132:21 144:14146:11 158:8 169:7176:18 203:18 292:25309:19 312:11 397:14422:14

location 41:13 181:10196:4 259:9,11 261:5287:10 348:12,16459:20 531:1,6,23609:7 614:8 621:4629:23 630:1

locations 182:1,2,18201:4 219:2 368:23,24438:16 447:10 528:18528:21 614:9 630:9

lock 346:15Lofland 10:6 455:3,5456:5 459:7,9,10467:13,15,16 468:16478:18,20,21 479:3484:2,3 539:3,5,6

log 605:2 659:25 660:3Log-Off 660:4,5,6,7logic 456:20 576:12

long 49:8 59:4 64:14161:11 218:3 299:12358:15 377:1 417:19417:25 446:21 506:6514:9 530:21 536:3,3549:21 554:23 578:20609:4 645:1 651:13655:5

longer 56:5 66:11156:13 181:8 196:6223:24 227:15 228:8228:21 229:10 264:16324:8 327:12,15 340:7349:3 357:10,22386:14 425:8 480:17480:24 515:22,23521:2,17 522:17 537:4565:6,8 574:10 613:10627:1

longstanding 297:21349:7

look 12:13 35:8 48:260:5 65:23 66:20115:20 126:18 128:1,9130:16 134:10 141:5143:1,2 163:5 171:6186:3 187:10 206:16220:14,19 221:3,5,13226:12 251:12 270:18284:23 306:15 311:10312:5 323:20 334:7349:1 369:4 388:3,7389:1 402:15 405:18470:25 472:20 484:6485:15 492:8,12505:25 514:2,5 536:3564:16 600:23 607:18613:24 619:2 630:4,11632:6 656:7

looked 174:12 224:8,10277:23 286:3 417:1,6426:4 452:13 499:25500:7 576:2

looking 44:17 45:1851:17 69:19,24 105:13141:3 157:7 185:18203:25 220:24 222:22269:8 278:3 286:23322:12 388:21 391:12401:8 458:20 582:2587:1 615:14 649:7651:4

looks 67:7 72:24 205:10229:3 239:24 445:12509:11 527:24 614:21

Lori 8:23 383:17,18lose 112:12 397:5losing 48:14 603:22loss 15:10,15 20:2088:24 148:8 380:21386:11,13 448:6

losses 88:22 90:2lost 15:7 228:1 385:13385:14 397:22 507:5517:18

lot 62:9 137:13 140:24168:25 185:2,13189:16 190:10,11



Page 28

191:10,11,22 192:1,3193:13 201:19 207:1208:22 220:20 221:10221:12 223:11 235:9236:11 238:9,9 262:16277:24 282:1 284:1,1284:4,6 285:21 286:3288:1,10 290:6 317:21336:22 351:8 388:25389:9 396:11,24469:13 506:3 551:25580:5 601:11 605:17651:4

lots 313:17,20 382:4605:17

loud 13:1 35:20louder 323:8Louis 32:5 530:9,11Louisiana 396:20love 313:12 314:19510:2,22 527:18

low 167:18 202:8 299:18442:6 498:13 651:1,2655:22

lower 204:10 243:21247:25 251:15 488:24489:18,20

lowered 251:10lowering 242:15Lubster 9:14 420:8,8lucky 188:22ludicrous 425:6luminaire 311:14lumped 57:1 220:21232:19,23

lumping 214:15lunch 118:12,13 168:14168:15

luxury 358:8Lyons 6:17 240:1,2374:7,8 418:6,7461:10,11 468:9,9484:22,23 542:6,9,9

MM 96:22 97:14 490:15Ma 651:11machine 324:19 325:9338:3,5

magically 91:4magneto 650:13main 23:23 48:7 49:1049:10 211:14 299:14325:3 450:1 545:17555:21 573:1 602:2603:17 607:17 610:8610:18 614:6 616:14

mains 200:16maintain 41:22 152:21261:7 363:4 515:6540:6 548:24

maintained 121:25maintains 353:23 372:5maintenance 27:10 28:928:10 32:10 33:15,2443:2,20 44:1 52:3147:2 163:10 201:9262:15 316:13 325:6

325:17 509:11 532:2major 109:7 245:4261:10 275:4 276:9288:7 310:2 316:4397:13 462:25 587:25592:14 595:18 617:20626:11

majority 16:9 18:2 36:1388:13 96:12 110:19152:9 179:1 217:12,13365:14 381:14,21415:11 432:9 603:24

maker 17:3,5 18:2055:13 66:9 67:2580:21 86:18 197:23227:13 228:6,16,19229:8 264:15 340:6404:5 416:24 480:16480:23 499:1 521:2,16537:3 546:12 573:15573:17 574:8

makers 547:6 553:15575:3

making 22:1 49:1 114:21188:11 204:4 205:8216:14 243:10 267:10280:12 306:2 307:3343:23 359:20 380:11382:12 460:14 539:15561:25 601:13 603:15611:7 615:10 616:17632:25

MALE 395:19,25 396:3,8398:24,25 399:1,9,10401:3,13 412:2

malfunction 380:18386:1,18

man 349:24,24 505:12manage 190:18 200:10200:14,16 201:5

managed 190:10 195:22196:1 248:11

management 12:2528:24 29:5 35:18216:8 261:19 548:13

manager 177:25 505:15manager's 509:10managing 190:20200:15

Manche 2:23 9:16 27:2328:1 367:21,21 421:23421:23 422:7,7,25423:6

mandate 260:8 445:1mandated 149:20409:16 442:4

mandates 382:14 446:4mandatory 82:21,23116:12 149:16 260:18269:16 443:10

manganese 252:11Manhattan 176:16manifold 436:18manner 58:18 64:18154:23,24 359:6507:21 578:12

mantle 188:10manual 22:22 109:2,3

112:19 311:22 326:10443:12 444:21,25538:24 580:14

manufacture 316:8327:12 334:18 335:12588:20

manufactured 324:11,12337:22 461:22 525:1531:2,3

manufacturer 203:9316:7 333:10,15 389:3406:10,10 431:14459:21 491:5 500:14515:23 518:9,19519:12 522:18 524:23525:3 558:3 588:10592:1,2 598:13,22

manufacturer's 324:15502:5

manufacturers 149:8276:1 294:14 295:2,16303:10,12 316:24356:15 366:19 379:21380:7 402:14 410:9416:8 460:22 516:7541:25 547:5,19549:23 550:14 552:12559:23 560:12 567:5574:3,20 575:2,13578:3 585:20 591:3,4597:25 625:24

manufactures 406:11manufacturing 107:25319:4 344:12 374:8514:17 518:12 549:25550:11 556:17 570:5578:12

map 623:14Marcelo 4:4 86:8,8,17,1787:8 90:17,17 92:1492:14,23,23 94:7,795:16,16,25,25 97:5,598:8,8,18,18 100:6,6100:15,15 102:2,2,11102:11 103:23,23104:7,7 105:21,21106:21,23 108:12,12108:23,23 113:22,22116:19,19 121:1,1,16121:16 124:7,7 125:18125:18 126:4,4 127:5130:4,4 133:22,22134:6,6 136:19,19138:17,17,18 139:3,3141:18,18 152:17,17152:17 193:3,3,8237:25,25 268:22,22280:25,25 281:7,10289:16 320:4,4 398:22398:22 448:21,21457:1,1,4,6 460:4,4485:4,4,9,12 553:9,9553:15 628:9,9,19632:21,21 634:1,1,5,7634:18,19 636:5,8640:15,15,24,24

Marcelo's 282:19margin 381:21

marinas 357:17 406:17marine 89:12 161:13Marino 4:13 132:18133:2,3,19 135:18,20137:25 139:24 140:1143:13 144:5

Maritime 87:5mark 2:13 3:12 4:7 8:138:14 9:8 21:13,13,1621:18,22,25 22:4,1122:14,25 23:9 44:1444:15,21,24 45:4,1045:15,16 51:7,8,12,1451:16 56:18 61:12,1365:20,22 66:20,2267:6 107:8,17 111:2117:13 293:9 312:24323:17,23 324:6,7,15324:16,17 325:1 327:2327:17 328:5,10,10,19329:6,8,20 330:6331:8,11 333:8,17335:10,20 336:2,6,6336:19,21,23,24,25337:2,2,25 355:4,5,6356:8 358:5,5 364:20364:22,23 365:18373:5,7,8 381:5,7,8393:22,22 395:20,23396:1,4 402:7,9,10407:15,15 415:23416:1,3 446:19,19452:11,11 525:7,9637:24

Mark's 23:2,4marked 12:14 35:9614:11

market 12:19 35:13225:17 462:9 469:8561:9

markets 275:11 460:25marking 334:8,13,15508:18 578:24

marks 327:20 512:12Marmon 140:16Marsh 107:8Marshal 23:13 24:19Marshals 432:9 437:21MARY 1:22 661:5,18Maryland 34:17 43:5292:24

mass 202:5Massachusetts 25:23119:25 144:12 208:15391:8,15,19,20,21482:1,4 483:11 491:16491:19 661:12

massage 314:21massive 196:5 384:17master 270:8 383:23,25396:18 419:20 509:25

match 162:24 389:23matches 196:13material 90:23,24 109:6109:13,23 111:14112:3 114:11 116:23123:17 127:7 128:16129:11,14 131:3

134:12,20,21,24 135:9170:25 173:24 174:1242:9 243:5 244:14,19266:5,10 267:2,6,8,24279:7 280:3 307:11,13309:14 310:14 311:1325:16 331:5 366:4394:11 408:19,22,24408:25 409:9 414:2415:8,21,22 416:25,25419:13 425:21 427:15435:15 458:18 462:7466:4 486:14 488:5498:4,17 499:15 514:9517:17 523:2,3,7,7,10524:9 584:17 585:5,8585:9 590:5,17,18591:18 593:16 594:6594:13,14 595:9 597:6597:10,14,15 625:4,12625:13 638:4,8,11,23648:2 654:14

material' 114:3materials 24:6 50:481:24 88:24 90:7,8,2291:3,5 93:3 100:18109:11,12,15,17,19110:21 111:14 112:2,7112:10 113:13 114:3,7114:19 115:7 116:3126:20,24 127:7,10,12127:13 130:8,9,9,11130:12 131:2,9 134:22135:2,15 137:9,14,17163:20,22 169:22171:14,15 173:25175:17 237:13 271:25486:6,7,18,23 629:13

Materials' 127:2mathematical 123:3Matt 5:22 189:6,7 235:1235:2 289:13,13,20620:20,21

matter 69:22 186:25200:19 269:12 358:7479:4 489:22 519:13554:16 609:14 620:9654:16

matters 16:21 180:13396:13 445:9

Maumee 34:7Max 214:13 303:10maximum 48:4 54:9241:19 243:12,18438:10 470:22

MBR' 508:18MC 466:20 528:13,20,22528:24 529:5,11,17,21529:23 531:16 533:1533:14,25 534:11

McClarnen 9:7 405:3,4McCoy 11:22 645:5656:3,3

McDevitt 4:2 85:5,13,1586:5 88:11,13 91:2093:13,15 94:23 96:996:11 97:13 98:2499:1,13 100:22,24



Page 29

101:10 102:19,20103:4,5 104:12,14106:3,4 107:1,2

McGinley 34:6McHammish 8:16359:18,19 365:23,24375:11,12

McKenzie 9:11 418:12418:12 497:8,8,13,15497:18 518:5,6 598:4598:5

McLaughlin 3:1 28:1728:20

McMorrow 7:1 283:15283:15

me.' 143:3mean 54:16 88:4 130:16152:7 167:2 219:24310:16 347:5,6 390:2450:22 487:18 508:21509:9 630:8

meaning 41:11 54:11266:24

meaningful 276:15meaningless 394:14meanings 306:17means 54:15 58:12110:6 117:1 127:3135:8 139:10 142:11149:19,25 173:3183:15 187:2 188:15211:13 216:9 269:19342:9,10 361:17391:11 417:3 506:22508:20 563:6 601:3,6601:10 602:4 607:12607:15,16 613:2,3,16613:20,23 614:3,11,12614:23 620:12,15621:13 623:5,11,17,18623:19,21 630:6 656:9

meant 508:25measure 87:1 134:21384:11 385:6 620:23

measured 128:3measurements 88:2measures 172:22 438:13466:4

measuring 91:16mechanical 232:6,8258:23 259:2 260:9,23260:24 351:23 488:12488:17,21

mechanism 142:23143:7

mechanisms 201:10medical 31:11 358:9,9358:10 387:17 390:2394:17,17

medium 314:9 429:5,8429:12,25 498:13517:14,15 524:10

meet 37:6 55:19 56:1956:20 57:4,19 58:1059:3 64:3 83:4 93:394:16,18 98:23 105:24105:25 245:9 285:7301:1 313:3 329:10

486:9 515:25 525:12552:13 622:3 651:13

meeting 1:5 12:2,9 13:1314:8,14,17 15:4,12,2015:23 16:4,14 17:2518:7 19:15,19 20:2,422:14,25 24:2 35:236:5,8,17,20,21 37:2,543:9 58:24 59:1785:11 102:20 107:14119:8 120:4 129:9132:24 141:13 144:17145:20 146:14 154:2154:18 158:11 169:10173:13 176:21 230:5265:21 270:9 271:3,3271:15 293:3 300:18315:3 347:1 381:14412:9 435:14 437:1442:23 443:13 527:9530:22 531:9 532:14602:8 606:20 619:15641:21,24 642:3,24647:19 649:15,16660:13,15,19

Meeting's 16:2meetings 13:18 16:1522:10 61:16 130:24162:3 181:2 221:6,8221:10 265:22 270:6270:10 277:2 373:24440:13 594:24 605:19617:24,25

meets 54:5 55:18 134:15134:15 329:7 414:11458:21 500:14 525:8543:14

Mellow 10:9 461:18,19461:19 462:1 470:10470:10,10 608:22,22609:2

Mellows 608:23member 21:21,23,2423:18 25:13 105:5118:18 130:23 140:18140:18 159:21 162:21164:10 168:20 172:10180:21,21 195:1,10,11212:10 237:9 245:22249:13 252:1 260:3270:24 301:14 353:17354:5 368:19 376:21381:17 406:8 437:10446:20 453:13 469:15473:13 516:23 534:2,4534:6 541:18 564:12586:6,9,14 601:15609:4 620:3 629:15632:4 652:24 655:5656:5

members 16:16,17,2018:1,3 22:8 32:3 65:275:21,23 88:20 136:12140:6 148:9 162:4178:11 180:16 193:13194:12,13 202:8205:19 242:5 243:4266:3,19,22 267:22

269:13,17 275:6 367:5372:20 392:11 417:19437:1 441:5,13,23442:25 443:16,22,25502:21,24 514:7515:10 597:24 602:9604:16 605:12 618:17631:21 643:1 649:18

membership 15:9 16:716:21,22 17:17 18:618:15 19:11 36:1259:16,17,23 112:21116:16 118:19 168:22197:4 214:24 375:7418:20 427:9 441:15441:19 451:10,14453:15 458:16 465:23471:19 598:8,16602:10 606:12 619:7

Membership's 18:18121:8

Membrane 27:7Memorial 123:5men 346:16mention 196:23 392:7490:18 540:8 656:6

mentioned 182:12,15187:13 217:6,18 218:2220:16 249:23 301:25318:25 331:4 365:11375:15 394:15 400:12404:10 438:6 469:15474:9 518:8 519:1540:9 541:12 563:16563:23 571:6,17,21575:18 635:21

mentions 357:7Mercantile 32:25merchant 89:10merely 83:6merit 51:25met 54:7,10 93:11173:12 267:17 315:2436:25 529:1

metal 190:8 373:21375:4 429:8 434:4466:15 473:17 474:1513:14

metallic 488:15 529:6531:17 533:25

metallurgical 458:25462:2

metals 151:17 465:25466:5,9,13 473:17474:4

meter 247:8 248:5meters 166:4,6 441:7654:23

methane 441:4method 93:6 110:9112:16,16 116:8,13127:22 135:5,8 136:8140:8,9 141:23 281:19482:10 486:10 488:22528:17 529:22 563:18563:19,21

method,' 142:23methods 50:3 135:24

141:13,21 149:13153:16 269:7 341:19382:20 440:16 466:8486:18 487:4 488:15488:16 518:11,15,16529:2 541:7 598:12

methods' 142:25mic 65:25 87:7 90:14187:6 262:3 289:17301:23 307:19,23326:18 331:17 351:20356:12 368:11 369:15370:4 373:6 381:6415:25 416:24 425:24467:14

Michael 6:1 7:4 194:7,7227:10,10,24,24292:23 293:8,18296:12 304:8 306:22307:24 308:1 326:2337:7 338:16,19342:22 352:6 354:25364:17 373:2 381:2402:4 411:8 415:7423:3 424:1 425:17427:23 429:16 430:9433:3 439:2 442:10451:17 452:22 454:22457:12 459:4 463:25467:10 478:13,16479:12 483:22 493:6494:22 500:24 502:10507:10 510:21,24511:2 512:20 519:23522:23 530:3,9 536:13538:22 549:8 559:11569:23 577:18 585:2589:3 590:14 592:22594:10 595:24 596:1597:9 599:7,9 602:14611:14 615:3 624:2625:9 627:13 631:6633:9 635:1 636:13638:3 639:22 641:11643:7 647:10 656:21

Michelle 2:3 20:11Michigan 482:2,4microphone 17:6 44:1044:11,13 47:4 48:1848:18 49:17 51:653:10 56:14 57:1459:12 61:10 62:163:14 64:9 66:18 69:280:6,15,17,18 83:1886:7 90:16 92:1293:23 94:6 95:15 97:398:7 100:4 101:6,25103:21 105:1,20106:20 108:11 111:19113:5,21 115:3,12116:18 120:25 121:14124:5 125:16 126:3130:3 133:21 136:18138:15 139:1 140:15141:17 142:17 147:13151:11 152:15 153:1154:11 155:7,10 159:8159:16 162:17 164:8

166:18 170:7 172:6173:8 174:8,18 175:9177:18 178:8 180:18184:6 185:23 186:16189:4 191:3,4 193:1194:5 195:7 197:6,10198:7 199:22 201:19201:21 202:16 204:12205:5,24 208:2 209:10212:6 217:1 218:5,16220:5 221:17,20 223:4224:21 227:8,22228:14 229:3 231:3234:25 235:22 237:7237:23 238:21,22239:25 240:24 244:6245:18 247:3 249:10251:4,24 252:20 253:2254:20 260:1 261:13263:18 264:22 268:21269:24 270:21 272:4273:17 278:11 280:23281:21 283:13 285:16287:18 289:11 290:11294:10 296:18 299:1299:22 301:10 302:6305:12 308:25 311:2313:6 314:23 315:23316:21 317:3 318:20320:2 321:23 328:1329:1,13 330:13,23332:22 333:21 335:6336:12 339:25 340:14342:25 344:4 345:7346:21 347:16,24349:9 350:11 351:1352:24 355:4 356:19358:3,19 359:16360:19 362:8 364:21365:22 366:17,23367:20 371:18 374:5374:13 375:9,22376:16 377:21 379:18381:6 382:7 383:15385:19 386:25 388:15390:18 392:2 393:20396:13 398:20,21400:18 402:8,25403:24 405:1 406:4407:12 408:11 409:11410:7,13 413:8 416:17418:3,11,22 419:17420:7 421:21 423:10423:18 424:18 426:17427:6,12 428:15429:19 430:25 433:7435:5,20 436:20 437:5439:19 442:14 444:5446:18 448:19 449:6450:16 451:20 452:10453:25 455:3,24456:15,24 458:2 459:8460:2,16 461:8,16462:14 463:5 464:15465:7 468:7,14 470:8471:22 473:7 474:18476:11 478:19 480:2481:8 484:1,20 485:2



Page 30

485:24 488:8 489:5490:7 491:8 492:3,18493:20 495:1,18,22497:6,22 498:20 499:7499:23 501:14 502:14503:2,6,15 504:16507:14 508:10 509:14510:18 511:16 512:23513:21 514:13 516:9516:20 518:3,20 519:7520:13,18 521:9,24523:15 524:6,17525:15,21 527:24530:7 532:8,19 533:21534:9 535:19 537:11539:4,19,23 541:21542:5,14 543:6,24544:20 545:2 546:12549:15 551:4,20 553:7554:2,25 556:10,11559:16 561:1 562:7563:11 564:8 565:16566:25 571:1 572:5573:14,16,25 574:25577:22 579:15,16580:19 581:2,11582:23 583:4 584:7585:15 586:2 587:13587:19 588:4 589:1,18590:23 591:11,23592:9 593:12 594:19595:4,14 596:15597:20 598:3,18599:23 602:18 604:11606:14,25 608:7,21609:19 612:6 615:7617:5 619:10,21,25620:19 621:19,19622:15 624:18 625:17626:5,15 628:7 631:9632:1,19 633:24 635:4635:17,24 637:4638:15 639:13,19640:13 642:18 644:6647:14 648:7 649:9,20651:23 652:19 653:23654:8 655:2 656:1

microphones 17:21,2284:4 209:19 290:19320:15 361:1 370:10378:8 399:6 420:15449:12 475:6 527:22555:6 565:21 572:11581:6 620:6

mics 99:9 307:22 338:13mid-rise 482:7middle 20:10 285:8305:21 372:21 607:18

midnight 657:14migration 441:17Mikat 7:5 294:12,13,25294:25 546:13,14547:3,3 552:23 554:4554:4

Mike 5:19 7:20 9:1 10:24185:25,25 307:22316:23,23 326:22338:14 356:14,14

387:2,2,10 423:11,11495:19,19 530:6,8,16530:19,21 541:1,2,4587:15,15

mile 202:7,9miles 565:7milliamps 576:17,20580:1

million 194:13 202:3225:8 386:11 406:14406:18 407:17 408:1409:15

millions 217:16mind 12:14 188:17 288:9314:16 318:11 388:4514:4

mindful 13:5 35:23mine 73:13 541:4minimal 50:10 160:5278:23

minimally 18:2minimize 276:11 343:9438:18 441:14 443:5

minimize' 233:4minimizing 438:17minimum 122:9,12233:23 259:5 469:10472:20,25

Minister 34:12minor 123:22 519:15644:19

minute 18:11 76:12118:10,23 168:13229:16,18 246:14322:5 339:14,18,19526:22 605:9

minutes 18:9 70:1 72:9118:25 332:7 333:21411:24 412:3 526:25644:2

mirrors 481:25miscellaneous 23:2527:8 32:22

misconception 182:23misleading 126:21127:15,24 131:10267:22

misplaced 543:16missed 236:6 239:24338:12 499:14,19

missing 47:13,25 48:15258:2 516:14

mission 21:2 202:12,14203:25 473:13 562:21

Missouri 30:15 32:5530:9

mistake 193:25 301:5396:5 551:17

mistakes 393:17Mitchell 9:22 437:7,8mitigated 231:19 233:18mitigating 233:24mitigating' 233:3mitigation 438:8mix 367:13mixed 199:15mixture 110:8mobile 13:11 14:10 36:4

192:15mode 563:4model 128:22modeling 246:8moderate 88:17modern 128:20 129:14130:8 384:13

modest 149:12modification 123:13modified 392:13,17modify 68:19 81:21 83:9393:1

modifying 392:20598:25

moisture 363:17 369:20443:8 444:11,18 445:6445:22

mold 372:15molded 308:13 405:11409:15 410:3

moment 12:9 198:2216:22 305:6

money 47:13,24 348:14384:17 385:9

monitoring 260:23,24586:21,25

Monoxide 29:20month 150:24 151:24152:3 154:17 156:14

months 151:18,19 152:8157:8 188:16,16246:21 333:13 338:4

Moore 11:13 293:12638:15,16,17 641:14641:16,17 647:13,15647:15

morning 12:7 19:2520:24 21:7,12 23:1235:3 40:5 43:1 59:1379:15 85:15 111:21154:13 172:7 192:7602:19 652:1

moron 509:4motion 14:6,19,24 15:317:4,6,12,15,21,22,2418:16,18,21,21,23,2319:1,3,4,7,8,13 37:1537:19,20,22,24,2538:2,4,21,22,23 40:8,940:11,13,14,16,18,1941:2,3,4,8,8,9 42:7,8,842:9,16,17,18,2244:23,25 45:1,2,4,5,547:1,4,9,10 48:16,2249:13,20 51:14 52:1252:14,21,21,24,2553:6,7,8,10,14,17,2054:24 55:5,6,14 56:1,556:11,13,16,17,2357:18 59:10,15,1761:9,13 63:6,7,16 64:664:12,22 65:5,5,8,1065:15,16,17,18,2266:3,9,11,13,15,18,2166:24 67:4,7,24,2568:3,10,24 69:1,5 70:470:6,12,13,16,1872:18,19,20 73:20

76:8,8,10,23,25 78:4,578:6 80:5,8,12,12,2181:1,7 82:13,17 83:1283:15,21 84:8,8,12,1384:19,20,21 86:7,1186:16,19 87:24 90:1090:13,16,19 91:15,1891:22,22,25 92:2,8,992:10,12,18,18,2593:12,20,22 94:1,2094:25,25 95:3,5,10,1195:12,14,19,24 96:2,797:2,7,10,16,17,19,2198:2,3,4,6,11,17,2099:8,10,15,15,18,2099:25 100:1,2,4,9,17101:3,5,7,11,14,15,21101:22,23,25 102:5,10102:13,25 103:1,2,7,7103:10,12,17,18,19,21104:1,6,8,21,22 105:9105:19 106:1,6,6,9,11106:16,17,18 108:11108:16,22,25 111:17111:19,22 113:8,11,24115:5,16,18 116:17,20117:7,16,16,20,22118:2,3,4 121:5,9,14121:18 124:3,5,9,17124:25,25 125:3,5,12125:13,14,16,22 126:3126:6 129:25 130:2,6131:12,23,23 132:1,3132:7,8,8 133:21,25134:5,8 135:21,22136:15,17,21 137:22138:2,3,5,7,12,12,12138:15,21 139:1,5140:5,13,15,17 141:16141:20 142:16,20143:10,16,16,19,21144:1,1,1 145:12,16147:13,17,22,25150:22 151:8,10,15152:6,19,25 154:15155:6,13 156:23 157:1157:11,11,14,15,21,21157:21 159:8,12,16161:18 162:2,5,14,16162:20,25 163:17164:7,10,15 166:11,15166:22,23 167:11,22167:22,25 168:1,7,7,7170:7,10,12,17 172:3172:5,8 173:6,7,12,14174:3,21,25 175:2,7175:11,22,22,25 176:1176:7 177:17 178:2180:17,21,23 183:21184:8 185:22 189:3,12189:23 190:25 191:7193:8,10 194:3,9195:4,15 197:5,11,21197:23 198:14 199:5199:16,24 201:25202:13,15,19 204:18205:9 208:10,12209:17,24 210:1,2,12

210:19 211:7,12,12,14211:15,17,19,25 212:3212:4,6,12,15,20213:1 215:19 216:24217:1,5 218:8,15,19219:3 220:3,8 221:25224:20,25 225:19226:16,18,18,21,23227:4,5,6,8,11,12,14227:16,17,20,22,25228:5,6,8,10,12,14,16228:18,20,22,23 229:1229:3,6,7,9,11,12,15230:22 231:2,7,12,14233:16 234:22,24235:3,20 236:10 237:6237:9 238:2,19 239:3239:15,21 240:10,10240:13,15,21,22,24241:4,9,12,14,16,18243:11 244:4,6,11245:25 246:4 247:6249:8,13 251:7 252:3252:19,25 253:7,10,11253:15,16,18,19,20,23253:24 254:16,17,18254:20,23,25 255:5,21256:2,3 257:22 259:23259:25 261:12,22,23261:25 262:4,6,25263:4,4,7,8,14,15,16263:18,23 264:3,12,14264:15,16,18,20,22265:1,5,8,8 267:12268:18,20,24 269:23270:5 271:1 272:3,11272:15,17,18,19,23,24272:25 273:2,3,5,7,13273:14,15,17,23 274:1274:6,12,14 278:7,9278:11,15,20 280:16281:2,2,20,25 285:10285:19 287:21 289:7289:15 290:14,17291:12,14,15,20,21,21291:24,25 292:2,4,10292:11,12 294:10,18294:23 296:8,25 299:5299:8,20 300:2 301:19301:21,22 302:11,15304:3,5,10,10,13,14304:20,21,22 305:1,2305:5,16,21,23 306:2306:7,10,23 308:23,25309:5 311:6 313:4,10315:2,4,22 316:2,20317:1,7 318:24 319:13319:18 320:11,23,25321:1,2,7,8,8,9,11,13321:19,20,21,23 322:2322:23,25 323:1,4,11323:15 326:21 327:24328:1,5,25 329:4,12330:18,20 331:2333:19 334:4,5 335:9336:16 337:4,19338:21,21,24 339:1,7339:8,9,24 340:2,5,7,8



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340:10,12,14,21,24341:1,5 343:4 344:2,4344:7 345:6 346:20,24347:1,20 349:14 350:9350:25 351:4,18,22352:9,9,12,14,19,20352:21,23 353:2,7,7353:14,18,20,22354:21 355:11 356:10356:12,16,22 357:13358:2,7 360:18,24361:6,8,9,15,16,16,17361:22,24 362:4,5,6362:14,22,25 363:3,3364:14 365:1,20,22,25366:20 367:2,19,22368:14 370:8,15,17,18370:24,24,25 371:2,3371:7,9,14,15,16,18371:22 372:2,5,5,23373:10 374:3,5,7,11374:17 375:13,21,25376:19 377:20 378:6378:13,15,16,24,24,25379:1,2,2,6,13,14,15379:17,21,24 380:4,8380:24 381:12 382:2,4382:10 383:14 385:18385:23 386:3,21,24387:9,10,11 388:20390:17 391:1,3 392:1393:19 396:9 398:13399:4,12,14,15,20,21399:21,22,23,24 400:1400:3,9,10,11,17,21401:1,5 402:12,22,24403:2,23 404:4,5,17404:25 405:5 406:3,8407:5,16 408:15410:10 411:3,5,10,10411:13,15,20,21,22413:7,10,12,18 415:4416:5,15,17,21,24418:2,6,13,20,25419:16,21 420:13,21420:23,24 421:4,5,6,7421:7,10,11,17,18,19421:21,24 422:1,6,8,9423:4,8,10,14,17424:4,4,7,8,14,15,16424:17,21,22 425:2426:6,15,17,21,24427:9,11,14 428:1,1,4428:5,11,12,13,15,17428:21 429:2 430:4,6430:11,11,14,15,21,22430:23,25 431:3,5,11431:15 433:10 435:3,5435:9,11,19 436:1,19436:24 437:2,3 438:22438:25 439:5,5,8,9,15439:16,17,19,24 440:4440:6,12 442:18 444:1444:3,5,7 446:15448:17 449:5,10,17,19449:20,24,25,25 450:1450:2,2,5,7,12,13,14450:16,25 451:6,8,8

451:14,25 452:6,8,10452:20,24,24 453:1,3453:9,10,11,24 454:5455:6,19,22,24 456:1456:14,18,23 457:5,7457:9,15,15,18,20,24457:25,25 458:2,8,16458:17 459:12,13,25460:2,15,21 461:7,10461:13,25 462:1,21463:4,10,12,22 464:3464:3,6,8,12,13,15,18465:7,13,18,22 466:11466:14 467:19 468:3,5468:7,11,16 469:18470:7,12 472:3,17,23472:24 473:11 474:16475:4,11,13,14,19,22475:22,25 476:1,6,7,7476:9,17,24 477:1,3477:11 478:2,6,7,23479:9,15,15,18,20,24479:25,25 480:2,4,14480:16,18,19,21,22,23480:25 481:1,3,7,10481:12,24 483:19484:15,18,20,22,24485:8,10,13,23 486:2486:3 488:7,11 489:3489:7 491:14,24 492:1492:7,17,21 493:3,9,9493:11,13,17,18,18,20493:24 494:1,8,10495:6,15,20 496:4,5497:14 498:2,3,18,25499:1,10,17,23 500:5500:21 501:2,2,4,6,11501:12,12,14,16,19,25502:18 503:3,5,15,19503:21,22 504:4,5,7,9504:13,14,14,16,18,19504:24 505:1 507:18508:3,8,10,13 509:18510:18 511:4,4,7,8,13511:14,14,16,20,22512:2 513:2,19,21514:1,10,10,16 516:8516:12,16,24 518:7,19518:23 519:10,17,20520:1,1,4,5,10,11,11520:13,14,23,25 521:2521:3,5,7,9,12,13,15521:17,18,20,22,24522:2,3,8 523:19524:4,6,8,21 525:14525:19 526:1,3,4,10526:11,12,14,16,20,21526:21 527:21 528:3528:10,12 529:24530:15,16 532:6,8,13532:16,18,22 533:24535:1,5 536:1,2,8,10536:16,16,19,21,25537:1,1,2,4,5,7,9,16537:19,24,25 538:8,13539:7,17,20,22 540:9540:23 541:25 542:7542:11 543:10 544:2

544:16,25 545:7,9,10545:15,18,18,19,22,24546:3,4,4,6,7,11,12,21547:2,8 548:23 549:19550:24 551:1,3,7,18551:23 553:3,11,16554:1,6 555:4,11,13555:14,20,21,22,22556:1,3,7,8,8,10,19,22557:2,6,8 558:25559:20 560:22,24561:1 562:11 563:9,14564:7,12 565:13,19,22566:1,3,4,11,12,15,17566:22,23,23,25567:13,16,22,25 570:4570:22,24 571:1,5572:3,9,16,18,19,25573:1,2,2,5,6,11,12,12573:14,15,17,19,20,22573:25 574:4,7,9,10574:12,14,16,17,25575:4,6,11,14 578:1579:11,13,15,19580:24 581:7,8,15,16582:1,10 583:2,5,9,11583:12,17,18,19,20,22583:24 584:4,4,4,7,9584:10,15 585:19,23585:25 586:2,6 587:12587:16,23 588:3,11,22588:24 589:6,6,9,10589:15,16,16,18,20,22590:2 591:1,7,9,11,16591:21 592:8,12,17,19592:25,25 593:3,4,9593:10,10,12,19,21,23594:2,22,25 595:2,4,8595:13,17,20,22 596:3596:3,6,7,12,13,13,15596:18,20,25 597:23598:1,7,9,16,21 599:2599:4,11,11,14,16,20599:21,21,23 600:5,11600:15 602:11,24604:7,9,11,15,20605:1,1,2,4,8 606:12606:19,22,24 607:5,14608:5,12 609:1,2,18609:21 610:12 611:10611:17,17,21,22 612:3612:3,3,6,13,18614:25 617:3,5,8,9,10617:13,18,20,21 618:3619:8,14,17,19 620:4620:18 621:22 622:22622:24 623:24 624:5,5624:8,10,15,15,15,18624:21,22 625:2,22626:3,5,9,14,19627:10,16,16,19,21,23628:4,4,4,7,12,18,23631:15,22,24 632:1,4633:6,12,12,15,16,21633:22,22,24 634:3,6634:12,17,20,21635:10,12,15,17,23636:1,10,16,16,19,20

636:25 637:1,1,4,7,10637:14,16 638:19639:11,13,15,20,25,25640:3,4,10,10,10,13640:19,23 641:1,2,19642:16,18,23,25 643:2643:4,10,10,13,14,19643:20,20,20 644:1,6644:11,13,17 646:13647:18 648:5,7,11649:8,14,17,18 650:3650:7 651:18,19,22652:5,9,16,24 654:11655:1,6 656:5,16,18656:24,24 657:2,4,25657:25 658:2,4,9659:2,4,6,17,17,18,18

motion's 19:4,10 604:21605:10 621:24

motions 13:18,25 14:1114:12,13,14,15,23,2515:1,7,10,14 16:6 17:218:20,25 36:11 37:1041:10,11,14 42:7,1042:12,12,13 43:844:10 85:10 86:2296:4 107:13 118:19120:3,25 132:23144:16 146:13 158:10168:22 169:9 176:20180:22 182:13 195:5293:2 302:19 304:24305:1,2 313:21 315:7354:3 426:22 427:17427:20 433:23 453:15453:19,19,20 468:17499:12,13 516:2537:11 572:3 617:11620:6 627:5 637:17

motor 85:4,17,23 88:1893:18 294:13 295:1311:15 329:21 384:13425:11 546:14 547:4554:5 567:3,24 568:23586:17,20

motors 299:7 390:1motors' 329:22move 25:10 35:1 37:1337:22 40:12 44:648:18 49:20 51:5 52:752:18 53:13 61:10,1961:25 63:14 64:966:15 70:8 84:23 86:386:9 92:15 95:17 98:9100:7 101:8 102:3103:24 106:25 108:6108:13 109:24 115:2118:6 120:21 121:2124:19,24 125:20131:22 132:10 133:17133:23 138:1,19143:15 144:4 145:8,25147:9 155:15 157:10157:24 159:4,9 166:2168:10 170:3,9 176:9177:12,25 212:12227:20 228:12,12229:1,15 231:5 241:1

254:10 258:5,10264:20,24 292:14294:6,16 305:16340:12 362:10 371:20391:6 393:1 396:12398:13 399:12 401:25415:14 431:2,15439:22 449:9 450:19454:3 458:6 464:25465:3,11 471:21476:15 480:21 481:3,4504:17 521:6,21526:10 528:1 537:8545:17 546:18 562:4566:11 573:1,22 574:4574:14 600:3 612:11628:10 634:7 640:16659:21

moved 73:17 354:18359:10 422:12 553:16

movement 553:22mover 113:10 586:18moves 370:25 553:21moving 79:4 95:13 98:5166:10 185:5 238:5265:14 367:25 387:18453:23 517:17 545:17555:21 601:11 615:16628:19,22

MSL 28:20multi-case 406:16multifamily 482:14488:13,19 489:23492:9,13,14,23

multiple 70:21,25 82:1189:17 153:22 193:20248:10,14 250:21344:14 345:13 415:10438:15 483:7 529:7,9529:10 585:20 591:3603:2,6 605:20 617:24644:20

multiply 603:8MULVANEY 11:1Mulvany 542:16,17Mundy 3:3 29:11,14municipalities 48:11140:8

municipality 140:11MUSIC 12:6 119:2,15229:22 230:12 339:21412:5,16 527:3,16660:18

Myers 4:1 5:24 80:9,9,1080:10,16,21,23,2581:7,8 113:7,7 114:18115:4,4,15 116:4191:5,5 220:7,7 231:4231:4,13,17,17 235:17235:24 236:8,8 238:23239:2,2,19 241:1,1,11241:11 251:6,6 264:24264:24 265:7,7 267:16270:1,4,4 278:13,14

Myers' 226:1

NN 2:1



Page 32

NAFRA 86:18 90:1892:24 94:8 96:1 97:698:9,19 100:7,16102:3,12 103:24 104:8105:22 108:13,24113:23 116:20 152:18193:4 238:1 268:23281:1 448:22 553:10628:10 632:22 634:2634:20 640:16,25

NAHB 369:25nail 483:1name 17:13,16 44:1545:15 47:2,7 48:2149:18 56:12 66:2268:25 80:9 83:1390:14 93:21 97:2 99:6101:3 102:25 104:19111:18,21 124:4 130:1136:16 140:14 151:9154:13 162:15 164:9172:4,7,8 177:19186:18 189:7 194:7201:22 202:19 216:24217:2 227:10 229:4234:23 235:1 238:25241:10 244:5 245:20254:21 259:24 263:21265:6 268:19 270:3274:8 278:10,14294:24 299:3 306:8308:24 309:2 318:22322:21 323:12 327:25330:15,24 333:17334:2 340:16 344:3345:10 349:11 350:12352:25 356:11 358:5365:20 368:12 374:4374:16 376:18 379:19380:5 382:3,8 385:21387:2 388:17 392:4393:22 396:16 402:23404:1 406:6 409:6416:15,18 423:8 426:1426:15,18 430:4 431:1431:12 433:8 435:3,6435:22 442:15 444:3451:23 452:8 454:1,12455:22 460:1,18461:18 462:16 468:6471:24 484:19 495:2497:24 500:3 503:4508:9 509:16 513:20513:23 518:5 519:8524:4 532:7 535:2537:14 539:21,24546:13 551:2 560:25567:2,23 570:25579:14 585:16 586:1588:6 590:24 591:10591:13,25 594:20595:3,6 597:21 599:25600:12 604:10 608:8612:8,19 613:2 617:4620:20 625:19 626:4626:17 631:12,25635:7,16 638:16639:12 642:17 644:9

644:18 647:15 648:6,9649:22 652:4 655:4660:4

name's 20:2 61:13 62:3151:13 159:9 228:15252:22 261:15 351:21355:6 364:23 421:23422:7 543:9,25 551:21571:4 602:22 641:16

named 391:10nameplate 50:18,23324:23

names 129:11naming 129:12Nancy 556:18 575:3NantEnergy 287:21narrow 217:22 381:21narrowing 235:18Natale 6:5 199:23,24200:5,7,9

Nathan 9:19 293:9 433:6433:8,8 434:20

national 21:17,24 25:2328:3 30:16 44:1545:16 82:10 105:5153:3,12,13 162:19177:21 178:13,20,24179:5,22,24 180:2,6184:18 189:10 196:14196:15 198:24 201:23202:23 205:17 208:14208:22 209:6 217:10292:22 293:6,20,25316:24 333:4 334:10335:4 353:1,16 356:15356:20 359:3 362:10362:23 366:19,25371:19 372:3 374:8375:24 394:6 410:9417:5,9 431:17 432:1432:7,8,15,18,24434:2 436:5 437:20441:20,21 444:9446:13 484:8 487:23489:10,15 491:22495:4 502:16 535:12540:2,4 557:17 560:5562:18 563:17 564:1565:11 571:21 579:23606:18 615:13 649:23649:25 651:3

nationally 474:11 487:21651:7

nationwide 393:6natural 441:3,4,5 443:4447:23

nature 368:25 563:3near 441:1 447:24 660:4nearest 12:15 13:4,535:23,24

nearly 345:5 383:4NEC 21:19,21 22:2,4,5,722:12,19,20,22 23:4,5179:18 180:9,10202:24 204:10 207:21207:22,23 293:8,21,22296:13,17,23 297:2,6297:10,19,22,23 298:3

298:7,11,21 299:8300:5 301:2,14 302:9302:20 303:15 306:25307:6,8,15 309:20,23310:2,5 311:22,22312:5 316:15,17 318:3319:6 326:9,12 342:24345:13 354:12 355:2355:24 357:8,17,22364:19 373:4 380:15380:23 381:4 384:8392:12,13,18,24 393:1393:6 401:7 402:6414:19 415:16 423:3425:19 433:5,12,25434:7,15 436:6 437:18443:12 444:20 455:13459:15 468:22 469:13482:2,5,11 483:10485:15 488:13 490:22514:22,25 515:16522:25 528:14 530:5538:24 547:9 548:24549:10,17,22 550:14550:17 551:14 552:20554:9,23 558:17 559:5559:8,13,18,22 560:15563:7,21 570:8,21571:20 577:9,20,24579:6 585:5 590:15597:11 600:24 602:16615:5,17 625:10629:14,24 638:6 639:6641:13 652:15

NEC's 31:5 563:5NECA 292:24 302:9354:5 396:17 433:9530:10 535:21 549:17559:18 570:2,2 577:24577:24

necessarily 18:1 53:23170:19 173:25 367:6367:15 425:5 506:10560:18 607:10

necessary 18:11 59:9122:4 150:4 156:13285:6 301:7 303:9310:17 316:18 327:9328:13 331:13 410:5524:23 548:15 578:10622:2,12 625:5 631:19

necessity 549:21 559:22Ned 6:20 247:5,5 249:5need 12:11 46:4 58:1060:16 64:5 76:1277:24 83:8 88:7 94:1694:18 110:12 115:8126:24 128:9 141:13147:21,21 152:9154:22 155:21 156:17156:20 161:17 165:11166:11 167:8 171:11184:17 185:3 186:10192:17 197:18 206:14207:4 228:3 237:20250:1 252:14 254:9257:6 258:10 274:18274:22 284:19 286:14

288:8 297:8,13 299:18302:22 303:14 314:3315:4,10,16 333:20339:16 343:13 345:21346:1,2,3 348:20357:25 359:13 360:1363:24 397:18 413:4419:25 429:12 441:12471:15 472:9,10476:22 484:8 506:24514:2 515:7 517:21528:21,25 549:25550:16 552:19 560:15561:12 563:6,23 576:1580:1 593:19 600:23626:25 644:2

needed 56:7 58:8 83:1127:21 148:17 156:13189:25 218:1 287:16303:20 310:6 318:4319:18 347:21,22363:22 455:11 479:1531:3 543:19,21550:22 553:4 609:7

needlessly 150:10needs 55:20 56:2 57:1359:7,19 110:9 115:6126:22 128:2 155:1175:6 190:11 258:6262:22 264:9 267:8276:12 280:13 313:3318:2 337:24 384:20387:6,22 388:5,11429:9 469:3 471:10522:13 557:24 561:23565:12 586:23 609:13609:15

negative 49:3 51:3 65:3151:23 152:4 242:4,6300:23 310:11 354:8367:4 416:12 456:9516:7 569:7 654:1,4

negatively 225:16negatives 162:6neglecting 406:1negligible 245:3 251:14251:19

neighbor's 398:1neighborhoods 186:7neighbors' 208:25neither 257:3 401:21560:5

NEMA 240:2 316:25,25330:16,17 356:15366:20 410:10 418:7,7423:11,12 425:13461:11 468:9 484:23495:19,19 503:7 542:9587:15,16

Nervousness 262:7NESC 177:25 179:11,13179:18 180:9,10193:18 194:3 195:3196:19,20,25

network 646:10 650:17651:15 655:23 656:8656:10

neutral 247:12

never 24:11 161:7,7281:13 283:1 295:20303:16 312:16 436:7508:24 523:11 524:12550:18 560:7 603:18645:12

new 20:23 29:15 41:2046:10,10 68:3 69:2582:5,19 115:22 132:18132:19,19,19 150:2,25151:3,6,16 155:23158:7 164:2 182:24187:11 188:14,18,19188:20 191:9 199:25200:15 201:21 219:21219:25 225:12 238:7,8242:9,24 244:14,19250:6 266:21,24268:16 297:1,14307:11,13 308:20309:14 310:14,25314:7,15 318:1 325:21325:22,22 326:12,13326:24 327:16 330:4331:5 334:18 335:19336:2 348:16 355:17357:20 369:25 372:18376:11,13,14 396:19408:22,24 409:8414:16 415:8,21,22416:25,25 419:13420:5 425:21 427:15467:5 496:10,16,20498:4,11,17 499:15500:13 502:7 514:9523:2,3,4,7,9 524:8548:1 561:8 562:15584:17 585:5,8,9590:4,17,18 591:18593:16 594:6,13,14,16595:9 597:6,10,14,15601:21 607:23 615:24618:16 619:3,4 625:3625:12,13 637:22638:4,8,10,12,23639:8 642:2 645:10647:3,24 648:2 650:14653:13,15 654:14

newer 50:10 213:15214:16 274:24

newly 41:19 369:23NextEra 283:15NFIRS 394:6NFP 437:10NFPA 1:5 2:12 12:2,8,1212:24 13:8,15,16,2013:23 14:2,4,8,9,915:4,19 16:7,14 17:2318:4 19:14,19 20:1,1520:17,22,25 21:5,1121:20,24 22:18 23:723:17,19 24:13,15,1625:16 26:2,20 27:2128:14 29:9 30:9,2331:21 32:2 35:8,1736:1,12 37:10,1041:16,18,22,25 42:742:16 43:7,7,9,25 44:5



Page 33

44:7,10 45:20,22,2546:3,3,4,10,11,13,1746:22 47:18 49:2151:20,23,24 58:13,1759:2 60:1,1 61:5,1664:1 65:18 66:3,10,1267:11,12,12 68:2,1068:11,12,15,17,2169:7,9,13,16,24 74:1774:23 79:6 84:22 85:985:9,11,23 86:2,4 87:487:9,9,11,15,17 88:1489:7,9,14 90:5,11 94:3106:19 107:12,12,13107:23 108:5,8,11109:5,7,7 110:19114:15,22 116:5 118:5119:8 120:2,2,4,15,20120:22,25 122:23123:14,16,23 128:14132:9,22,22,24 133:10133:15,18 135:16136:9,11 140:1 142:1144:3,15,15,17 145:3145:9,14,17 146:12,12146:14 147:1,7,10,13148:17 149:2 157:23158:9,9,11,23 159:2,5159:8,21 160:5,11,12160:15,21,22 161:16161:17 162:7,8 163:9163:22,22,25 164:1,11165:4,6 167:15 168:9169:8,8,10,21 170:1,4170:7 171:1,4,21172:10,19,24 173:18174:5,13 175:4 176:8176:19,19,21 177:6,11177:17 178:11,12179:8,10 180:6,16182:14 183:8,10,11184:12,15,17 191:9,16192:9,22,22 193:11,12193:14 194:18 195:2,3195:6 198:10 202:22202:24 205:19 213:14213:23 215:12,13,16215:16 216:2 218:12218:14 223:17 227:15227:16 228:7,9,21,22229:10,11 230:5231:19 232:12 233:23241:21 242:23 244:2244:25 245:16,22248:18 249:23 250:19258:17 259:10 264:15264:17 265:9 266:9,25268:3,4,4 269:5 270:7270:7,10 273:23 274:2274:15 276:4,19,19,20277:6,17,18 278:5,19279:3,6,12,17 280:1,2281:3 284:2,8 287:4287:23,25 291:25292:13 293:1,2,3,25294:4,7,10 303:18309:18 310:21,25340:7,9 345:15,15

357:7 394:1 409:10412:9 413:25 414:1,24431:18,19,22 432:5,16433:19 434:2,12,15,16434:17,23,23 435:18436:23 437:9,11,13438:4,6,12 453:12480:14,17,18,22,24,25521:2,4,17,19 527:9532:12 537:2,4,6541:14 548:4 550:20551:25 552:14 553:1553:15 559:7 563:23567:7 569:16 573:19574:9,11 576:18 579:9586:6 604:22 619:7,13629:12 630:10 642:22649:13 659:20 660:13

NFPA's 13:19 14:5 16:621:2 36:10 166:25247:12,20 393:4569:10

NFSA 51:8 61:14 66:23NHB 357:21NHTSA 547:16,19548:18,19,20 549:1552:24 553:5,22,22557:23 558:2 561:6562:16,17 563:16564:3,6 569:19 571:23

NHTSA's 548:16 557:25568:14

nicad 190:19 217:7218:10,13 244:24245:9

nice 222:8 512:17nicely 415:12Nick 6:18 245:20,20246:1,3 505:12,24

nickel 182:25 213:10,18213:25 214:7,9,19215:21 225:5 252:10262:11 275:3,23286:10 288:14,22

night 208:17 417:25426:25 514:8

nine 277:1 381:16398:15 470:2 483:16505:21

NITMAM 149:25 150:9150:15 153:5 266:2605:2 642:5

NITMAMs 187:24nitrogen 166:6NM 482:5,12,13,17,19,21482:22 483:7,17 486:3486:8,10 488:4,19,25491:5 492:10,13,22

NMC 247:16,19,23,24248:2 252:11

No' 38:4 40:20 53:162:16 63:5,6 65:1170:19 72:19 84:1492:3 95:6 97:22 99:21101:16 103:13 106:12117:23 125:6 132:4138:8 143:22 157:16168:2 176:2 210:2

211:20 226:24 240:16253:11,25 263:9272:18 273:8 291:16292:5 304:15 321:1,14339:2 352:15 361:9,25370:18 371:10 378:16379:7 399:15 400:4411:16 420:24 421:12424:9 428:6 430:16439:10 449:20 450:8453:4 457:21 464:9475:14 476:2 479:21493:14 501:7 503:23504:10 511:9 520:6526:4,17 536:22545:10,25 555:14556:4 566:4,18 572:19573:7 583:12,25589:11 593:5 596:8599:17 611:23 624:11627:24 633:17 636:21640:5 643:15 657:5659:7

noise 308:1Noltee 8:10 350:12,13351:21,21

nomenclature 129:12nominal 247:24non- 199:1 303:13386:13 550:15

non-combustibility269:1,6

non-critical 63:20non-debatable 291:2non-GF 385:3non-mandatory 116:10171:20

non-transportation549:24 560:14 570:7

noncombustible 109:5109:12,19,23 110:2,3110:4,6,7,8 111:6,13112:1,9,18 113:13,15113:19,20,25 114:2,8114:11,17 115:9134:12 135:1,15137:19 486:6,23 488:6489:8 490:16

noncombustible.'116:24

nonhazardous 447:9448:1,2

nonmetallic 482:3,8489:11

norm 200:10normal 185:2 237:16256:25 261:2,3 312:2312:4,7,9,21 316:14318:13 398:11 564:4

normal' 311:25normally 135:2North 294:13 295:1546:14 547:4 554:5

Nos 108:15,18 117:9,18211:16 353:4,10361:20,20 362:13,17371:5 450:19 451:1452:20,25

not' 613:6notable 22:7 123:16491:4

notably 22:2note 42:16,20 46:17 55:555:24 65:1 89:12110:1 113:24 222:16234:7 307:13 318:6,13325:21 326:6,8,14,15326:24 331:5 355:22390:22 432:2 434:21440:19 442:3 444:23444:23 531:24 543:2543:12 544:3 548:7561:5 604:20 641:23642:6,13 645:4

noted 46:11 253:1 318:5370:9 487:14 507:24508:4 516:13 531:1,20626:13 636:10

notes 46:21 329:6 525:7581:5

notice 134:11 209:18271:16 289:23 290:18320:14 360:25 399:5443:10 449:11 475:5503:15 512:8 525:20545:1 555:5 565:20572:10 607:12

noticed 378:7Notices 15:2notification 54:20notified 66:10 227:15228:7,21 229:10264:15 340:7 480:17480:24 521:2,17 537:4574:9

notify 12:17 35:11noting 12:10 618:3629:22

NRECA 202:1NRTL 330:1 335:17568:13

NUCA 441:22nuclear 169:2,16 174:1184:15

nuisance 384:17,18,24385:2,11 389:18,24394:20 397:11,12,21

number 19:12 24:837:24 40:15 44:1347:4 48:19 49:17 51:653:10 56:14 57:1559:12 61:11 62:1,263:14 64:9 66:18 69:279:13 80:6 81:2083:18 86:7 90:1692:12 93:23 94:695:15 97:4 98:7 100:4101:25 103:21 104:25105:1 106:20 108:11111:19 113:6,21 115:3116:18 126:10 135:1142:17 154:11 155:7181:1,1,2 182:13189:12 192:6 193:5,13197:6 199:22 201:7,19207:2 209:19 216:18

217:23 218:11,24221:7 223:3 224:21235:22 236:13 237:23244:16,19 245:18246:16,25 247:3249:10 251:4 252:20261:14 270:21 272:4273:17 274:17 275:8275:17,19,22,25280:23 281:21 290:19290:25 299:1,22301:10 302:6 311:2,3313:6 314:23 316:21320:15 321:23 323:19329:1,13 330:13,21,23333:21 336:13 345:7346:21 347:24 351:1358:3,19 360:19 361:1366:17,23 368:11374:14 375:10,23376:16 377:21 379:18382:7,16 383:15385:19 386:25 387:13387:21 388:15 390:18394:1,15,15 396:14398:21 399:6 402:13403:24 405:1 406:4408:12 409:11,17,18410:12 411:6 416:17418:3,11,22 419:17420:7 429:19 435:20436:3,14,18,20 437:6439:19 444:11 445:20446:18 448:19 449:6455:3 460:2 461:16462:14 463:5 470:14473:7 475:5 491:14492:18 495:22 525:20530:7 555:6 561:1565:21 572:11 583:3593:16,18 601:5,9613:16 622:15 635:5636:2 642:13 654:25

numbering 538:25numbers 49:12 136:22434:22 466:4

numerical 129:20numerous 21:25 22:1789:17 245:24 246:4319:7 384:8 540:12

Oo'clock 339:14,15400:13

O'Connor 3:9 34:25 35:335:4 38:13,15,19 39:139:9,11,17,19,23 40:443:16 44:8,13,20,2245:1,5,11 46:6,2548:17 49:16 51:5,1151:13,15 52:13,1753:16 54:25 56:1057:14 59:11 61:10,2562:14,19 63:2,5,1364:8,21 65:4,21,2466:3,8,24 67:3,1868:23 70:5,11 71:8,1271:14,24 72:1,7,13,24



Page 34

73:2,5,11,15 74:1,4,774:11,13,16,21 75:1876:16,20,22 77:6,2378:1,15,18 79:2,9,1279:17,20,23 80:2,4,2080:24 81:3,6 82:1483:11,17 84:3,7 85:286:5,11,15 87:6 88:1190:12 91:17,21 92:1792:21 93:13,19 94:694:19,24 95:19,2396:9 97:1,9,15 98:1198:16,24 99:5,14100:9,13,22 101:2,11102:5,9,19,24 103:6104:1,5,12,17,24105:1,8,12,18 106:3,5106:22,24 107:4 108:9108:16,21 110:25111:16 112:24 113:5113:21 115:2,12,16,19116:18 117:6,11,15118:9

object 102:22 581:1,9objections 153:25245:15 414:22 515:12

objective 123:13objectives 113:3 393:5622:4

objects 438:21obscuration 87:2 89:4obscure 331:11obstruction 49:12343:10

obstructionists 49:7obtain 381:20obtainable 122:1obtaining 14:20 391:4obvious 115:9 275:16289:2 496:8

obviously 143:3 187:18306:11 345:20,21,23467:3 571:24

occupancies 26:13 27:727:8 31:7,8 32:23,2433:1,21 50:25 56:2257:8 182:7 204:11279:5 280:11 367:16488:19

occupancy 25:2 48:2486:12,16 488:14

occupant 50:3 505:15occupants 182:6 199:13316:19 411:2 588:2592:16

Occupational 153:4,14occupied 112:7 190:22occur 261:10 300:13,17300:17 350:21 360:13486:20 531:21 577:6

occurred 55:21 193:22355:19 445:21 448:16

occurrence 207:10occurs 68:6 214:15312:10 515:5

October 180:11odd 505:11 506:7Ode 2:13 21:13

Odie 9:8 407:15,15446:19,19 448:23452:11,11

OEM 204:3 519:5 567:4OEM's 335:11OEMs 546:15 556:18off-site 335:15offer 46:7 67:19 82:1588:12 93:14 96:1098:25 111:1 122:15128:12 135:19 139:25150:19 161:20,24171:8 215:6 233:21244:25 258:13 267:14276:17 296:11 303:12326:1 342:21 364:16365:1 373:1 381:1402:3 415:6 423:2425:16 429:15 433:2442:9 454:21 459:3467:8 483:21 494:21502:9 507:9 512:19522:22 530:2 538:21549:7 550:14 559:10560:13 570:6 577:17585:1 590:13 594:9597:8 602:13 615:2625:8 631:5 634:25638:2

offered 548:24offering 412:19office 23:13 24:19 57:7279:21 358:9 394:17

Officer 2:7 3:9 4:10 5:1010:3 14:16 17:3,1818:8,9,17,19,22 34:2535:5 41:13 118:19168:21 355:6 453:14

Officers 16:20offices 358:10 482:15official 62:6,9 139:11,12436:23 532:12 619:13642:22 649:13

officially 18:7 164:12652:1 660:12,15

offline 71:3,4,5,8,10oh 51:24 76:16 83:17104:24 106:22 238:10239:2 264:4 305:11311:6 323:1 333:22345:20 434:19 462:20472:6,12 477:20520:17 579:16 593:20602:19 620:1 653:25658:9

oh- 539:19Ohio 34:6,7 164:14okay 38:19,24,25 39:139:17,18 40:3,4,4,941:5,6 45:5,11 48:1749:16 51:16 52:15,1753:9,18 61:10 63:1363:13 64:21 65:18,2470:5,7 71:8 72:1,7,1072:24 73:11,15 74:4,774:16 75:17,18,2576:6,15,15,20 77:2077:23 78:1,1,7,18,18

78:22 79:2,12,12,2079:23 80:2,4,24 81:3,682:14 83:11 84:786:15 91:17 94:2495:13,23 97:15 98:598:11,24 101:5,11102:9 103:2,6 105:18106:5,22,24 107:4113:5 115:2 117:15118:9 127:11 145:14145:14 175:10 177:19178:10 187:7 198:1,4198:6,7 199:21 201:18210:9,23 211:2 219:15228:2 229:17 240:6,9252:25 254:6,9 255:7264:4,13 301:24305:12 306:1 307:24319:14 322:15,16,21331:14 332:4 334:2337:19,20 338:11,18339:23 340:20,23342:18 350:11 351:20356:7 379:17 380:5396:10 400:25 406:4424:3 427:25 430:10454:20 468:14 472:12472:16 476:22 477:4478:4,8,9 503:12505:20 510:15 511:3511:18 533:20 535:18542:4 561:15 573:15582:17,19 589:1601:16 613:6 614:9622:14 623:6 628:17636:4,9 639:18 644:8658:23

old 130:12 208:24 338:3338:4,4 359:22 438:5438:5 614:20

older 128:22 314:5354:14 356:23 359:24367:11 376:2,6 515:21

Oliver 4:22 151:12,13Omega 431:13 435:13omitted 531:17On-Off 660:3onboard 295:11,13once 17:2 18:13,1696:16 104:17 148:19234:15 260:20 324:6324:13 327:7 338:3341:3 347:25 429:6459:6 468:1 502:23577:20

One' 627:20one-third 393:14one-year 154:5 155:2ones 135:2 468:1 616:7online 71:16onset 50:5onstage 25:20Ooh 472:4open 47:1 56:11 58:168:24 83:12 90:1393:20 97:2 99:6 101:3102:25 104:18 111:17118:14 124:3 129:25

136:15 140:13 151:8153:7 162:14 168:16172:3 201:2 216:23234:22 244:4 259:23268:18 278:9 308:23327:24 341:11,23343:5,10 344:2 348:4348:7 351:9 356:10365:19 374:3 382:2402:22 416:14 423:8426:15 430:4 435:2444:3 452:8 455:22459:25 468:5 484:18496:10 503:3 508:8513:19 524:4 532:6539:20 551:1 560:24570:24 579:13 585:25591:9 595:2 604:9617:3 626:3 631:24635:15 639:11 642:16648:5

opened 17:9openings 163:13opens 139:19 180:3342:4,5 346:10,11586:24

operability 171:12operate 60:13 184:25188:2 410:20 571:7

operated 216:18 245:11operates 344:12operating 204:8 214:6217:8 218:3,10 311:13311:14,15 580:2626:25

operation 189:1 237:17261:2,3 563:4

operational 37:15operations 31:13 32:10163:10,19 164:4167:16 194:23 334:21375:18

operator 12:17 35:11325:5 397:25 514:17

opinion 24:17 93:1799:3 167:7 225:16262:20 275:6 276:8,17495:9 497:4 502:21559:21

opponents 17:22 113:24opportunities 205:20283:24 392:19

opportunity 175:12182:9 188:1 256:15265:15 266:1 270:15309:10 310:23 414:20414:25 469:11 483:14515:8 585:22 591:5594:23 625:23

oppose 150:21 168:7194:3 212:3 281:20333:18 418:13,19,20435:25 460:6 470:7498:18 514:10 518:7518:19 563:9 585:22591:6,21 598:6,16605:13 659:6

opposed 59:10 112:11

126:25 131:8 134:18144:1 155:18 170:19258:3 260:4 270:14317:1 330:17 356:16366:20 410:10 504:2526:8 539:7 624:15658:8,12

opposes 316:14 495:20587:16

opposing 186:1 354:3468:16

opposite 341:24 350:24445:3 483:10 541:3

opposition 17:12 19:1261:13 94:1 193:4238:1,9 271:1 281:1285:19 296:24 301:21301:22 309:5 317:7319:17 326:21 330:17331:2 334:4 335:8336:15 343:4 347:20349:14 350:9,14351:22 355:11 360:18367:3 374:10,17 375:8376:19 382:10 383:19404:4,17 406:8 416:21419:21 420:6 426:6,21433:15 435:25 437:12442:18 446:20 451:25452:5,12,16 455:19456:5 459:11 461:13468:2,10 478:23484:15,24 485:6,13490:9,25 491:3 492:6495:6,15 497:21 498:2502:18 507:18 509:18513:2 514:1 519:9523:19 554:7 562:11585:18 588:12,17591:1,16 592:8 594:22595:7 597:23 598:21625:21 635:9 638:19647:18 655:6

Ops 201:25optical 655:11,13optimistic 339:12438:11

option 62:8 72:17,21114:16 116:13 260:10260:12 314:7 406:2570:18,19 601:5,9612:23

options 72:17,20 110:1114:16,17,19 117:5222:12 303:13,14550:15,16 560:13570:6 600:21,25

or' 115:23Orangeburg 169:5order 14:7 17:4 18:21,2535:1 42:6 58:15 60:1360:14 74:16 118:22129:4,17 150:4 174:11182:18 197:20 209:23240:2,2 248:3 253:6268:1 272:14 274:19276:23 284:20 285:7290:25 291:11 295:6



Page 35

304:25 319:23 320:22361:5 370:14 378:13385:8 386:22 399:11413:4 420:20 449:16453:21 475:10 495:18503:18 524:24 525:25538:13 545:7 546:7551:4 555:10 566:1572:16 574:17 581:13583:8 605:10 610:8617:18 619:21 621:19622:3 638:5

orderly 208:21 209:2ordinance 83:2,4,9Oregon 107:9organization 12:12 35:787:5 194:10 202:1223:14 325:16 333:10334:17 515:10 552:24

organizational 17:13,16organizations 149:22150:25 156:19 178:13203:10 367:7 441:19547:18 548:3 567:4

orifice 68:8original 48:7,8 49:9,2350:6 51:22 81:1130:13 151:24 156:22203:8 213:14 312:24323:23 324:11,12325:1 327:1,6,10,12327:15,17 328:5,9336:1 344:23 409:3496:21 505:13 515:20515:22 518:18 531:16538:3,4 617:13 637:24650:12

originally 82:19 94:10154:16 199:20 367:10380:12 448:12 465:5

originator 431:2origins 318:12Orleans 396:19Osborne 7:22 317:5,5335:7,7

OSHA 329:18 330:7other's 287:5other.' 238:12out-code 205:10outage 387:15outcome 67:23 122:25390:4 622:9

outcomes 123:5 131:20152:5,13

outdoor 182:1,2 372:7374:11 406:15 538:9538:14,19 543:20648:16

outer 91:4 355:20442:22

outlet 295:13 548:11558:14 565:4

outlets 295:12,17,19301:25 372:7,8 374:11390:9 391:25 548:8,10558:13,19 561:7,8565:1 575:16 577:2,11580:7

outline 75:18 78:8outlined 180:8 213:8415:12 487:9

outlook 390:14output 198:21outputs 299:16,16outs 288:13outside 118:15 136:10136:13 140:4,7 168:18190:8 233:14 258:8325:18 395:7,7 397:14433:24 445:14 568:18621:7,9 645:11 646:21647:23 648:12,15654:21 656:15

outstanding 20:25over-enforcement 517:3overall 221:19 384:10442:6

overcurrent 298:13300:11,25 455:15468:24 578:16 614:18

overkill 262:18overload 395:8overlooked 302:1overlooks 234:4overly 81:9 171:24 262:9279:3 283:5 299:15558:10

overnight 58:25overprotection 467:3overreaching 344:8403:4

oversight 499:20 557:16575:22

overtook 262:7overwhelming 234:10269:12 327:20 391:15391:24 603:24

overwhelmingly 298:4390:23

owned 181:15 194:11199:14 209:3

owner 47:14,16,24 48:649:1,14 50:13,24 51:258:21 116:12 173:19325:5,7,8,14

owner's 580:13owners 48:13 60:2082:10 89:23 267:25648:25

ownership 50:3 181:21owns 181:20oxide 252:11oxygen 257:22

PP 2:1,1p.m 411:25pace 5:22 58:20 189:6,7235:1,2 284:12 289:13289:14,20 620:20,21

Pace's 623:8package 502:6packaging 50:3page 41:7 43:7 44:5 85:986:2 107:12 108:5120:2,20 132:22

133:15 144:15 145:7146:12 147:7 158:9159:2 169:8 170:1176:19 177:11 196:20196:21 293:1 294:4479:8 604:22 607:25

paints 189:16 597:5pair 646:20pairs 646:21Palmer 8:17 360:21,21Panama 31:4panel 21:23,24 22:8,1022:15 25:24 28:5,6,728:11 30:18,20 31:569:21 70:3 293:9,9,10293:10,11,11,12,12,13296:7,19,24 297:7,12298:19 299:7 300:18301:14 302:9,13303:21 307:18,23310:8 312:5,18 313:14316:3,25 317:17326:17,20 329:5342:25 343:3,23345:14,14 353:17,18354:24 355:3,9 356:3359:20 364:20,25365:7,15,24 366:22368:19,21 373:5,10,11373:23 375:12 376:21381:5,10,12 382:18383:11 390:9,23 391:5392:11 393:17 394:1402:7,11,14 404:21,21404:24 406:7 407:1,4410:17 414:15 415:23416:8 418:19 422:12422:12,13,14,20423:12 426:3,4 429:19429:23 433:6,9,13440:12,13 442:13,17442:18,19,23,25 443:1443:2,3,14,16,17,17443:19,22,23,25446:21,23 451:16,20451:24,25 452:1,13454:25 455:1,2,7,8456:2,3,10 459:7,8,12463:13 467:13,14,18467:21,22,23 468:18468:18 469:15,16470:15,16,17 471:1,19474:11 478:12,17,18478:22,22 483:25,25484:4,14 485:13490:21 494:25 495:5502:13,18 506:8507:13,16,24 512:22512:25 513:3,9,12514:7,7 515:11 516:18516:23 517:7 518:25519:2,3,14 523:9,14523:17,20,23 524:21528:13 529:12 530:6530:21,24 531:1,15,20532:23 534:3,6 539:3539:15 540:3,13541:19 543:22 549:14

549:17 550:1,6,10,23559:15,18 560:20561:15 562:13 563:7569:24 570:2,9,11,13577:21,25 578:5,18,21579:1 585:14,17,19,21587:23 590:22,25591:2,4 592:12 594:18594:21,24 595:11,12595:17 597:19,22,24598:1,6 601:14,15,15601:18 602:17,23,25603:8,11,18,25 604:7604:16 607:7,7,9,9,11607:21 608:11,20609:4 610:12,23 613:1613:7,13,14,24,25615:6,10,11,20 616:19620:4,22 621:11,16622:5,13 625:16,20,22625:24,25 626:10629:6,8 631:9,13,14631:16,22 632:5,24635:4,8,9,12,13638:14 641:3,14 647:9647:13 652:25 653:20655:5,22,24 656:5

panel's 23:2 296:11297:16 302:14 326:1342:21 343:22 356:1364:16 365:1,12 373:1381:1,24 395:7 402:3402:13 415:6 416:5423:2 425:16 429:15433:2 442:9 454:21459:3 467:9 483:21490:19 494:21 502:9507:9 512:19 522:22530:2 538:21 549:7559:10 569:22 577:17585:1 590:13 594:9597:8 602:13 615:2625:8 631:5 634:25638:2,24 641:10

panels 22:1,17,22 28:430:17 293:23 294:2307:3,8 317:13,21393:15 415:10,11,20470:15 523:6 601:13621:13 627:5 649:24

paper 180:8,9,12papers 48:8 107:19par 136:5paragraph 68:2,5 304:25325:3 524:9 536:3546:6 574:16 607:19

parallel 618:6paralysis 448:5parameter 586:22parameters 438:11paramount 171:17194:16

paraphrase 60:2paraphrasing 60:12pardon 161:21 250:17paren 531:25 578:14,16578:19,24

parens 55:3,5,13

parentheses 481:17park 540:17parked 565:9Parking 33:2parks 540:2,15Parkville 34:17Parliamentary 62:5part 12:4 20:4 42:2045:20 51:9,16 61:1866:21,25 67:7,9 69:670:7,14 76:9 95:18,2097:11,17 98:10,1299:10,16 102:4,6103:3,8,25 104:2105:20 106:7 108:14108:17 115:10 117:8117:17 119:3,12 121:3121:6,10 124:18 125:1125:20,23 128:14131:13,24 138:20,22142:17 143:11,17149:15 153:13 178:22186:12 212:13,13,16223:21 225:20 226:19229:23 230:9 236:25241:2,5 253:21 269:17294:17,19 299:7,9304:6 309:8 312:12,21318:3 323:2,5 325:2,5328:12 330:18 337:5337:17 338:22 340:19340:24 341:6 351:19352:10 353:3,8 356:17361:18 362:11,15365:6 366:1 371:3379:22,25 388:8394:17 399:24 400:22401:1 407:21 411:6,11412:6,13 419:7 429:7439:22,25 440:15444:15 450:3 454:4,6456:6,7 457:10,16458:6,10,19 461:13463:23 464:4 465:11465:14 468:11 473:13474:25 475:23 476:15476:18 479:10,16492:24 496:14 502:5507:24 522:10,13524:24,25 527:4,13528:1,4 536:11,17537:17,20 538:2542:11 545:20 546:18546:22 555:23 556:20561:9 564:25 565:11568:19 596:19,21599:5,12 604:2 612:11612:14 615:14 623:12623:25 624:6 642:10644:13 651:9 656:19656:25 658:3

partially 148:22 339:15participant 13:21participants 13:23 20:25participate 20:19 205:19participates 34:20participating 17:1122:10,19 271:17



Page 36

participation 19:1621:22 23:5 271:21660:14

particular 86:25 111:23112:9 113:3 128:17136:11 164:6 189:23221:19 234:1 245:17318:10 354:4 358:7392:1 422:9,22 425:22517:4 571:10,14 623:1

particularly 131:17137:16 221:8 281:7389:12 468:20 645:18

Particulate 108:1parties 267:5 268:2373:22

Partners 28:21 180:10392:5

partnerships 195:21parts 81:13 149:18191:15 202:10 276:9277:25 314:6 373:22446:1 495:12 500:11500:11 502:25 515:14515:17,19,19,22518:13 522:16 524:22525:6 541:5 601:11

parts' 515:16,24 517:2parts.' 444:18party 300:7 327:7 329:23330:4 661:9

pass 109:11 114:7,12134:23 137:9,10,13,14137:14 408:9 610:12

pass/fail 67:13 109:20114:20 135:10,11,12

passage 122:5 443:5447:9

passageway 89:22passageways 89:18passed 15:15,23 36:2038:23 41:4 78:6 84:2192:10 95:12 98:4100:2 101:23 103:19106:18 109:15 157:22168:8 187:25 211:8,13212:4 241:24 272:25284:3 291:22 321:8361:16 378:25 381:14424:16 449:25 464:13475:19 537:1 555:20572:25 583:18 612:4618:4 621:11 624:16633:22 637:2 643:21

passenger 89:15,16119:22 120:10,16214:16

passengers 89:18passes 19:4 55:6 56:1137:11,12,13 195:6199:5 481:19 546:4

patented 518:11 525:6path 366:5 375:5,6 577:6609:10

patience 40:5 41:5 71:2472:2,11

patient 38:15pattern 82:3 455:12

Paul 5:21 9:13,23 10:21186:18,19 187:7204:14,14,17 229:4,4254:21,22 255:7,9,14255:16,18,20,22,22,25256:3,5 257:25 263:20263:21 264:2,5,8419:18,18 439:21,21440:5,5 450:18,18,22450:24 451:7,7 509:16509:16 510:5

pause 582:7pay 277:14 308:2 623:1PC 81:1 257:8 461:14531:9 575:4 645:5

peak 126:13,15,16127:19,20 128:6

PEARL 305:15 306:10322:2 520:20 521:12522:2 584:8 589:19593:15 596:18 624:21

Pearson 407:15 446:19446:22 452:11

pedestal 538:5PEL 237:16PELs 260:17penalizing 376:11penalty 201:10 661:11pending 431:23penetrations 441:2446:5,9 483:1

Pennsylvania 33:11 85:6people 61:22 63:8 81:20143:1,4 164:21 165:18165:25 166:5,12 186:9189:16 192:6 193:13201:20 202:4 203:11203:14,20,23 209:19223:15,21,22 236:19251:10 269:21 271:17271:23 272:1 282:1,15290:19,25 303:7 308:4316:9 319:25 320:15358:12 361:1 363:8365:13 369:21,22376:25 378:8 382:5394:19 397:18 399:6408:23 410:24,25412:19,25 413:5420:14 449:12 473:23474:2 475:6 490:14491:10,14 508:21509:8 525:21 527:22545:2 552:19 555:6562:15,19 565:21572:11 581:6 583:3,5587:8 620:5 621:15651:12 652:21

people's 372:13Peoria 21:13percentage 50:10 57:10136:5 463:18

perfect 235:10 257:9281:4,5,8,13 282:20287:24,25 289:9 290:7314:13 350:18 479:7579:5,6 615:19

perfectly 142:4 463:16

perform 164:4 190:21389:21

performance 54:3 55:755:11 56:18,24,2460:4,8,9 68:7 69:12,19286:9 488:24 489:2532:24,25 534:13

performance' 60:6performed 55:20 167:16286:12 639:4

performing 171:16183:17 327:8 569:1

performs 63:18 586:20period 25:15 68:19 93:6149:18,21 150:1,24151:18,24 152:3 154:5155:2 156:14 242:11391:23 540:21

periodic 153:18periods 219:19perjury 661:11permanently 87:22,23328:15

permission 137:3permissive 444:13 616:2permit 55:17 482:5486:3

permits 206:15 207:4498:13 499:5

permitted 14:24 405:15444:12 460:13 469:1473:3 483:7 485:1486:24 487:6 489:24492:10,11,14,23 512:7529:8,20 601:4,4,7

permitting 488:19584:23

Perry 6:14 218:7,7person 13:7 14:17 35:25253:1 277:2 308:2324:21 334:16 343:9347:5 359:7 370:9377:6 505:8,10 510:6621:14

personal 87:16 96:14148:10,18 150:2153:12 369:17 387:16388:3 617:17 653:13

personally 283:19 605:9personnel 163:18,23175:19 186:15 190:4368:16 408:7,8 613:17

persons 89:22 179:6297:25 298:23 508:4,5532:3

perspective 24:21 157:5166:20,25

pertaining 216:6pertains 562:13pervasive 50:11pet 360:6Peter 10:4 33:9,11 454:1454:2,12,12 456:16,16458:4,4,14,14 464:17465:9,9,19,19 476:13476:13,25 477:4,6,12477:17,19 478:4,8480:3,9,9,12

Peterkin 3:18 53:12,1253:21 170:8,8,18

petitioners 558:25Petroleum 158:5,18,23159:23

phase 232:14 266:2380:9 403:12,12408:20,20,21

phase-in 151:18Phil 10:10 471:24,25472:4,8,12,14,16543:8,9

PHILIPS 433:8Phillips 9:19 293:9 433:6433:9 434:20

phone 12:17 35:11 580:9650:13,16

phonetic 3:15,21 4:8,214:24 5:1,2,19,22 6:46:10,16,21,23 7:10,238:8,10,16,17,22,23 9:49:5,7,8,13,14,22 10:110:7,9,10,16,22 11:411:10,11,16,20 14:948:20 59:13 111:21122:24,24 147:15153:3 155:7,12 185:25189:6 197:8 209:12221:21 251:25 252:22259:15 261:18 262:13297:3 299:24 311:5318:22 328:4 330:2335:17 347:18 350:12359:18 360:21 382:8,9383:17 392:4,5 405:3407:15 419:18,20420:8 425:8 437:7444:6 460:18,19461:18 473:10 492:5495:3 502:16 505:12506:18 509:16 525:17541:1 564:10 608:8635:25 648:9 649:22653:24

phosphate 252:10 283:3phrase 297:1,14 299:9481:17 630:13 631:17647:21

phraseology 489:25physical 112:13 148:12482:25 483:3

physically 16:16PI 415:14 530:23pick 207:24 400:15634:9

picked 188:9picking 498:9 499:12Pico 221:24picture 348:7 392:14pictures 185:19 346:7piece 116:1 324:6,13338:2 417:8 429:8,10458:20 463:19 518:24

pieces 81:13 192:25333:4 597:2

piggyback 398:4pigs 372:16piled 48:3

pin 494:16 497:1,9,18499:2 500:9,11 502:4541:7 542:3

pinhole 436:12pipe 409:18 441:10pipeline 161:12pipelines 441:9piping 27:18 160:8,14,19161:12 163:1,3 165:1165:5,16 166:3 431:21432:4,17,24 434:4,5

placarding 616:16place 24:5 45:24 48:551:20 81:14 181:14214:17 286:13 287:6315:8 386:21 391:9458:24 459:20 467:4469:20 482:1,4 483:4517:20 523:22 524:13552:25 603:21 638:9644:25 648:13

placed 110:1 186:7326:13

places 367:14 409:18414:19 422:16 496:19

placing 52:4 214:9,19plain 363:11,12,14 506:9plainest 507:6plainly 517:24plan 165:11,12,13,15,24165:25,25

planning 29:2 289:21383:7 407:8 411:25

plans 183:16 184:16plant 181:9 182:1 186:8190:3 216:3 645:11647:23 648:12,15656:15

plants 34:10 161:11163:4 167:16 174:1183:1 184:15 186:6

plated 462:7plates 482:25platform 287:6play 201:11 309:16366:13

playing 587:8plead 620:17please 12:9,13,20 13:3,914:8 17:12 18:1319:18 21:2,13 23:8,1425:6,20 26:5,23 27:2428:17 29:12 31:1 35:835:14,22 36:2 38:640:22 42:20 44:13,2345:13,14 47:2,5 49:1253:1,11,19 56:12,1465:11 68:25 69:270:19 74:23,24 75:1276:1 78:11,19,20 80:781:6 83:13 84:15 86:786:16 87:7 90:1491:14 92:3,13,2293:12,20,23 94:6 95:695:15,23 97:4,22 98:798:17 99:8,21 100:5100:14 101:17 102:17103:13,22 104:6 106:1



Page 37

106:12 108:11,21110:23 111:20 113:21115:3 116:18 117:23118:25 119:17,17120:25 121:13 124:3,6125:6,17 126:2,3129:25 130:3 132:4133:21 134:5 136:15136:18 138:8,16,25139:2 140:13 142:13142:18 143:22 147:14151:8,11 152:16,24153:2 155:10 157:16159:8,15 162:14,17166:18 168:2 170:7,16172:3,6 173:6,9 174:9175:6 176:2 177:18178:7 180:19 184:6185:24 186:17 189:3,5193:2 194:3,6,23195:8 197:7,24 198:7199:22 202:17 204:13205:25 208:3 209:11209:24 210:2 211:20212:7,19 216:24 217:1218:6,17 220:6 221:18226:24 227:9,23228:14 230:14,19,23231:3,11,15 234:7,22238:19 240:16,25241:8 244:4 252:24253:7,11,25 255:4259:23 260:1 263:9,19264:23 265:4 268:18268:21 269:22,25270:22 272:5,7,15,19273:8,18 274:5 278:9278:12 281:18 283:14285:17 287:19 289:12290:12 291:12,16292:5 293:13 294:11294:22 301:11 302:17304:2,15 306:7 308:23309:1 311:3 313:7314:24 315:24 316:22317:4 318:21 320:3,23321:1,3,14,24 323:11327:24 328:2 329:2330:14 333:21 336:13338:13 339:2,17,25340:15,25 344:2,5345:8 346:22 352:15352:24 353:14 354:21356:10 357:12 358:4358:19 359:17 360:20361:6,10,25 362:8,21364:21 365:20,22367:18 370:15,18371:10,18 372:1 374:3374:6 377:20,25378:13,16 379:7 380:3382:2 385:20 387:1388:16 392:3 393:21396:14 398:21 399:12399:15 400:4,18 401:5402:22 405:2 406:5407:10 410:7,14411:16 412:1,3,23,23

413:2 415:3 416:15419:16 420:21,24421:12,22 422:5 423:8424:9,18 425:1 426:15428:6,16 429:1,20430:4,16 431:10 435:3435:5 439:10 440:3444:3,5 446:16 448:20449:5,7,17,20 450:8450:17 451:5,21 452:8452:10 453:4,25454:10 455:4,22,24456:25 457:21 458:3458:12 459:3,25 460:3460:15,17 461:9,17462:15 463:6 464:9,16465:8,17 468:5,5,8,14470:7,9 471:23 472:11473:8 475:11,14 476:3476:12,24 478:6,19479:21 480:2,7 481:22483:19,21 484:1,18,21485:3,22,25 488:6,9489:5 492:4 493:14,21494:7 495:23 497:7,23498:21 499:8 501:7,15501:24 502:14 503:4,6503:8,19,23 504:10,23507:14 508:8,11509:15 511:10 512:1512:23 513:19,22514:14 516:8,10,21518:4 520:6,15,18521:10,25 522:7523:15 524:4,6,18525:16 526:1,4,17527:24 528:9 530:2,7532:6,9,20 533:21534:9 536:22 537:23539:4,21,23 541:22542:8,15 543:7 544:23545:7,10,25 546:12547:1 549:7,15 550:24551:1,4 553:8 554:1,3555:1,11,14 556:4557:6 559:10,16560:21,24 561:2 562:8566:1,4,18 567:1,21569:22 570:21,24571:2 572:6,16,19573:7 574:1,25 575:10577:17,22 579:10,13579:16 583:9,12,25584:14 585:15,25587:14,20 588:5,21589:11 590:1 591:9,12591:24 593:5,13 594:1595:2,5,12 596:9,16596:24 597:20 598:19599:1,17,24 600:10604:9,12 606:15 607:1609:17 611:24 612:7612:17 615:8 617:3,6619:10 622:15,22624:11,19 625:1 626:3626:6,16 627:24 628:8628:17 631:10,24632:2,20 633:4,17,25

634:16,25 635:5,15,18636:21 637:5,13 638:2638:15 639:11 640:5640:14,17,22 641:10642:16,19 643:16,25644:16 647:14 648:5,8649:7,10,21 651:21,24652:5,16 655:3 656:2657:5 658:4,9 659:7

pleased 25:17pleases 355:6pleasure 20:3,24 85:2287:19 88:14,15,15,1688:22 89:1,14,1996:13,13,15 256:9355:9

plenum 628:22plenums 628:25 629:7629:10,14,23

plug 192:13 502:3538:15 541:8 544:13565:3

plugged 192:12 359:11564:21

plugging 560:17plumber 164:19plumbing 355:15pocket 226:3podium 390:5POE 653:8point 49:2 52:1 55:2159:8 64:13 73:16 91:7114:1 122:2 129:23131:16 163:11 172:20174:11 179:7,9 184:4193:5 194:24 197:2,20203:13 204:15,17240:1,2 256:20 283:4287:15 290:24 308:17313:3 317:11 327:12333:1 339:18 356:22356:24 360:8 366:12368:5 387:19 388:3390:16 398:13 411:23427:18 447:5 474:6487:24 498:4 505:24535:13,14 536:6554:15 557:2 581:2610:21 616:18 620:10620:12 654:11,19655:25

pointed 162:23 199:3218:20 318:10 366:7495:11 515:13 563:2580:4 654:13

pointing 98:21pointless 328:17points 51:9 182:12 198:9220:14 274:14,15280:14 287:22 313:12359:21 418:14 438:16525:1 542:19 653:2

poke-through' 509:8pole 401:20,22 650:22police 415:21policing 523:6,10policy 43:13 293:7 336:1357:7

politicians 357:14 364:8politicized 357:11 393:3Poly 441:20poor 315:14port 132:18 302:5portable 32:11 192:15298:5,10 303:1

Porter 9:20 435:6,6,10portfolio 24:13portion 60:12 232:16,18275:10 395:3 426:12

portions 353:4,9 356:18361:19 362:12,16363:6,8 371:5 512:12546:19,23 555:24556:23 566:13 600:4,7603:14 611:11,19

Portland 107:9pose 246:10,22 316:8410:24,25

posed 232:6poses 474:1 508:1position 17:17,24,2518:3 45:13 46:8 55:167:19 82:15 88:1293:14 96:10 98:25100:23 104:13 111:1115:24 122:15,17128:12 135:19,21139:25 150:19,21156:7 161:20,25 162:2162:12 171:8 215:6233:21 236:7 255:21258:13 267:14 296:11297:21 326:1 342:21364:16 373:1 381:1387:18 393:8 402:3412:23 415:6 418:16423:2 425:16 429:15433:2 442:9 454:21459:3 467:9 478:3483:21 494:21 502:9506:23 507:9 512:19513:3 522:22 530:2538:21 541:3 549:7559:10 568:5 569:22577:17 585:1 590:13594:9 597:8 602:13609:23 610:3 615:2625:8 626:19 631:5634:25 638:2 641:10

positions 381:22positive 22:7 49:2 478:2538:13 647:2

possess 488:17possibilities 143:5257:14

possibility 222:23 517:3621:8

possible 23:4 49:12152:23 154:9 156:18290:7 314:16 464:19516:25 531:13

possibly 199:15 257:12283:21 311:24 335:13335:14 363:12 466:7

posted 271:22 437:21604:22

potential 60:3 171:17251:2 295:10 324:19330:2 372:12 436:10441:2 449:2 483:3516:6 529:14 568:25646:17

potentially 127:15130:18 164:3 184:17186:4 216:16 217:16246:9 404:6

potentials 466:1pounds 395:17,17397:22

power 28:7 87:21 174:1181:9,25 182:20 183:1185:17 186:6,8 189:1190:3 198:20 202:3213:11 214:2,5 216:4219:14,14 225:7248:15 259:5 280:4282:6 284:24 285:1295:11,12,13,17,22296:4 297:4 298:6,20299:15,18 301:25302:2,4,23,25 303:14303:25 304:1 331:14358:1 387:15 405:12405:12,15,19 498:14541:13 548:8,10,11549:24 550:12,16553:20,25 554:8,12,14554:22 557:10 558:12559:24 560:14 564:22564:23,25 570:7,16,17575:16 578:4 580:11580:12 600:17 608:9614:16 618:20,22620:2 647:23 650:12650:14,15,17,17,25652:11 653:14,15655:10,15,18,21,22656:9,11

powered 655:8,9 656:8powerful 436:8powering 564:24 580:6580:17 645:19 646:7646:22 654:19 655:17655:23,25

practicably 154:9practical 122:25 123:15179:6 275:24 297:24298:23 346:15 351:15513:6,11 646:19

practice 198:12 357:2442:6 487:19 648:15

practices 34:9 178:23256:16,18 487:21645:3

pragmatic 568:16pre 180:2precedent 205:3 646:11646:15

predating 354:14predominantly 163:3preemption 548:21557:22

preemptive 557:16575:24



Page 38

preface 17:12prefer 360:10preferred 438:16premature 148:8 514:19premise 61:5 315:20564:18 598:10 620:13650:12,14 652:14

premises 32:13 33:17248:7 295:7,14,15,20297:4 302:3,4 547:10568:13 600:21,22,24601:1,1 613:9,11614:7 645:17 652:12655:8,9,19 656:10,12

preparation 22:13,15prepare 151:3Preparedness 29:1preparing 22:19 391:13preposterous 463:13Prescient 164:13prescriptive 189:19235:7,8

presence 14:18 48:3323:23 438:9 443:4558:1 618:19

present 16:16 17:6,2425:17,24 26:10,11,1326:14 27:3,3,4,9,1728:4,6,7,8,9,11,23,2529:18,20,24 30:1,4,1930:21 31:6,11 32:8,1132:12,14,16,22,23,2432:25 33:1,3,5,7,8,1333:16,18,21,21,23,2534:2,4,9,10,11,15 35:543:3,16 50:18,21 85:485:13 94:13 107:7,16119:23 120:6 132:17133:2 144:9,19 146:7146:16 158:5,14 169:3169:13 176:14,24216:19 226:10 276:8292:22 293:16 295:14354:18 440:20 591:5

presentation 17:1,7442:25 443:15

presentations 19:1550:4

presented 17:15 21:8,1937:18 43:21 85:1793:16 99:2 107:19120:11 133:5 144:23146:21 158:18 169:17171:10 177:2 226:13226:14 293:21 382:15438:9 474:10 491:24540:15 610:3

presenter 443:1presenters 443:16presenting 90:9 201:21550:5

presents 303:18 550:20560:9 617:20

preserved 324:13President 539:25Presiding 2:7 3:9 4:105:10 10:3 14:16 16:2017:2,18 18:8,9,17,19

18:22 34:25 35:541:12 118:19 168:21355:6 453:14

press 63:9,9 475:14660:3,7

pressed 62:7pressure 57:4 64:3160:10 161:16 164:22164:25 165:5 167:8,18401:16 586:21

pressures 160:11 163:2pretend 658:24pretty 81:8 161:5 425:6479:5 490:17 538:1602:20

prevalence 482:17prevent 114:23 124:14161:15 180:7,15238:18 276:6 343:5442:22 443:6 447:9562:22 653:20

preventable 445:20446:16 448:14

prevented 123:11preventing 123:20prevention 27:13 107:24250:17 251:16 395:1

prevents 122:4preview 37:17previous 64:16 69:24102:17 140:5 197:15281:3 315:16 355:24375:20 390:1 392:7404:9 433:22 451:11462:25 463:1 512:12547:13 563:15 590:4617:9 629:18 635:12

previously 123:15128:18 129:3 140:5213:16 224:9 363:16431:18 442:2 462:5469:23 512:11 571:21635:21

primarily 13:16 112:1142:6 552:1 586:9

primary 24:7 68:1 165:3194:22,25 202:12203:25 253:17 299:9323:16 534:5 618:5620:21

prime 282:17,19 287:1586:17

principal 140:18 296:22317:5 564:12 601:14

principle 153:15prior 13:24 15:5,10,1516:4,11 36:9,15 45:2446:21 50:9 128:19622:9

private 27:18 178:23181:21 195:22,23,25

privilege 16:15 17:10118:21 296:23

proactive 360:11proactively 569:11probably 47:19 55:456:7 127:11 130:25142:11 192:13 217:21

226:8 277:24 286:19313:18 315:9 332:10332:22 461:3 505:19522:20 553:12,16603:9

problem 56:17,19 57:2059:18 75:8 135:25187:11 189:15 215:2250:25 262:8 281:16329:25 330:7 331:17344:9 348:16 349:1,6350:20 358:12 359:14367:12 373:14 376:6377:7,14,14 382:24383:3 384:19 388:2398:3,3 419:22 437:18470:13 505:5,7 512:4530:24 561:23 608:15609:24 631:2 645:22

problematic 393:18515:21

problems 39:12 192:17239:8 278:24 281:20348:25 372:19 376:5390:7 420:6 444:23617:21

procedural 232:10242:21 617:10

procedure 62:5 74:19656:14

procedures 149:10153:21,24 154:21155:22,25 161:14162:10 163:8,9 167:15487:12 518:11,15,17547:22 548:6 552:24598:13

proceed 17:5 35:1 44:953:9,19 66:16,17 67:471:16 74:19 75:1976:2 79:5 80:4 81:786:6,16 92:11,2295:13,24 98:5,17100:3,14 101:24102:10 103:20 104:6108:10,22 121:14125:15 126:2 133:20134:5 138:14 139:1145:11 147:12 148:2159:7,16 170:6,17177:16 178:8 209:20211:13 212:5,20 227:7227:21 228:13 229:2231:1,12 240:23 241:8253:3 254:19 255:5263:17 264:21 265:5273:16 274:6 290:20294:9,23 305:4 306:7320:18 321:22 323:11339:23 340:13,25352:22 353:14 361:2362:7,22 370:11371:17 372:2 378:9379:16 380:4 399:7400:16 401:5 413:6420:16 421:20 422:5424:17 425:2 428:14429:2 430:24 431:11

439:18 440:4 449:13450:15 451:6 453:23454:11 458:1,13464:14 465:6,18 475:7477:10 478:7 481:6,22493:19 494:7 501:13501:25 504:15,24511:15 512:2 520:12521:8,23 522:8 525:22527:20 528:10 537:10537:24 545:3 546:10547:2 555:7 556:9557:6 565:22 566:24567:22 572:12 573:13573:24 574:24 575:11584:6,15 589:17 590:2593:11 594:2 596:14596:25 599:22 600:11612:5,18 624:17 625:2628:6,18 633:23634:17 637:3,14640:12,23 644:5,17

proceeding 383:13480:1

proceedings 15:8 661:5process 13:17,21,2414:3 16:6 18:5 20:1820:18 21:1 22:8,13,2024:17 26:3,21 27:2228:15 29:10 30:10,2431:22 36:11 42:2472:8 78:3 81:16 82:4112:2 113:14 115:7149:24 150:12 152:1153:6,17 155:14,20187:2,4 221:19 249:17249:22 264:11 267:4267:10 271:17,22277:6,7 278:20 280:12286:11 296:17 307:4308:16 310:21,25311:6,7,10 313:14,16313:18 319:20 327:19350:6 357:9,14 391:11413:3 415:1,2 417:20417:23,23,24 419:15427:17 462:4 517:16517:17 518:12 525:2548:1 568:14,15 571:7578:7 597:17 601:12601:13 603:10 623:9

processed 15:16processes 24:6 148:22525:6 552:24

processing 13:17107:25 414:8

produce 23:3 142:13547:24 548:19

produced 262:17producer 285:1producers 284:24product 248:23 277:19289:9 301:4 316:6,8316:11 324:1 327:11327:14 329:7,11333:11 335:11,19336:7,8 389:20,20410:23 436:7,12

459:22 460:23,25461:4,22 518:16,18519:6 525:1,3,5,7,7,13533:18 551:16 598:14598:15 639:5

production 488:12600:17

products 105:23 126:24269:2 280:8 300:24301:8 309:22 310:2,3319:1,2,2,10 335:24336:17 382:12,14397:11 398:10 418:17431:14 513:13 518:10522:15 524:1 558:4

professional 147:16322:1 325:10 400:20424:20 428:18 493:23501:17 505:10 506:1506:14 511:19 520:21520:22

professionals 369:7377:24 392:24 393:15

program 34:7 123:6325:6

programs 201:9 335:23441:9,11

progress 79:15 153:18339:10

progresses 237:1519:16

progression 327:21prohibit 403:6,22 404:16407:2 419:8

prohibited 13:14 36:7496:20

prohibiting 403:3 414:17419:10

prohibition 403:8 409:6419:6

prohibitive 314:8 616:11prohibits 403:16,16project 21:10,18 23:16153:19,20 184:8 203:4382:22 383:1

project's 348:13projects 200:24 207:3prominence 318:18promise 644:2promote 248:19 327:18promotes 336:8promoting 21:19promotion 150:11prompt 660:4promulgation 208:21proof 190:8propagate 280:20propagation 250:5257:17 488:18

propane 160:6,10,18,22160:23,24,25 161:6,10161:11 162:8,19163:18,20 164:22167:18,18 202:21441:20

propeller 214:12,14proper 18:23,24 165:9226:15 267:9 406:25



Page 39

properly 148:20 190:10228:4 425:11 433:19496:9 611:8

properties 165:17247:19 250:5

property 29:17 33:1347:21 48:12 88:25195:22,24,25 297:25298:24 335:3 372:14386:11 389:11 397:21398:7 406:22 447:24

proponent 57:10 460:8proponent's 172:12proponents 196:23310:22 354:10 417:17417:19

proposal 112:23 160:7,9235:11 269:9 329:17342:11 348:23 383:19385:7 432:13,21437:12 447:11 462:24491:7 505:13 541:16554:19 559:1,5 645:4646:16,25 647:2

proposals 179:12,15208:17 433:11,15534:8

propose 213:7 270:16proposed 23:24 24:2256:23 67:9 68:20102:22 109:1,21110:10,21 114:14115:22 116:22 121:7153:15,20,23 162:5170:22 183:21,25214:25 233:2 234:20242:15,17 258:21260:6 273:24 277:8,9316:15,17 394:3 401:7419:5 423:15 432:14434:13 437:14,24438:1 441:18 443:9446:24 447:3,14,18,20447:22 448:10 455:13455:14 485:20 515:1,3515:8,13,25 533:11539:8 541:2 548:13549:3 554:11 557:9558:7,9 608:14 617:9617:20 650:4

proposing 472:19proprietary 136:24 259:7518:11 525:6

propulsion 87:20protect 148:11 186:15190:12 199:5 295:6300:20,22 335:2357:25 406:22 433:12460:24 483:1,1 547:9587:10

protected 33:17,17252:14 300:11 467:1

protecting 57:6 58:4148:13 191:25 382:20

protection 25:3 26:1429:14,17 30:5 32:2433:12,22 44:1 47:854:15 57:17,24 69:4

83:20 85:22 132:16133:5 148:18 149:3153:10 169:2,16,21170:22 171:13,16175:18,18 186:20,22187:22 190:15 199:3216:11,12 221:24222:6 251:17 256:7285:3 286:14,17298:14,14,17 300:16300:25 301:8 303:10360:1 363:5 366:15368:16 369:21 374:12376:9 377:13,17380:13 382:19,25384:25 385:4,14,14386:3,21 394:22 397:4397:5 401:9,10,12,18403:4,17,19,19 405:8405:21 406:12,18,20407:3 408:7,7 409:17409:19 410:1 420:4431:17 433:18,20434:24 437:10,17443:24 455:15 468:24482:25 488:17,21538:4,9,14,18 539:9539:14 540:14,20,24541:8,17,19 542:3,12543:20 544:17 560:21563:18 565:5 576:9577:8 578:16,19586:16 606:18 614:18

protections 570:12protective 31:13 32:13146:6,20 147:2 148:10148:18 150:2 153:12

proven 360:2 384:11,21385:5 397:5 398:4482:9

proverb 208:24proves 469:16 570:10provide 47:2 54:14 56:1259:8 61:20 68:2582:20 83:13 89:390:14 93:21 109:25110:11,11 122:19124:4 128:25 129:4,16129:22 130:1 135:22136:16,22,24 140:13141:4 149:4 150:4151:9 162:15 172:4190:16 194:12 213:24216:1,24 232:17233:23 234:23 235:7235:19 236:17 237:3239:11 243:14 244:5248:7 256:14,21 257:7259:24 260:19 268:1,2268:5,19 270:19277:22 278:9 282:14285:3 290:8 298:6,23303:2,9 308:23 327:24343:12 344:2 351:11351:12 356:10 365:20366:15 374:3 382:2383:9 402:22 406:12416:15 423:8 426:15

430:4 432:20,21434:24 435:3 441:6,15442:6 444:3,24 452:8455:22 459:25 468:6484:18 488:16,23489:1 503:4 508:8513:8,19 524:4 531:23532:6 539:21 551:1557:10 559:6,24560:21,24 561:19570:24 575:16 578:3579:13 585:25 591:9595:2 604:9 617:3626:3 631:24 635:15639:11 642:16 648:5655:23 656:13

provided 12:21 35:1551:21 55:18 61:1767:16 68:2 111:5136:2,8 150:11,23153:18 163:20 171:10183:4,6 185:18 198:10242:5,8 259:4 298:18300:15 303:3 385:1403:13,20 455:9 488:2488:13 540:18 550:13560:1 580:8 586:11614:3 655:21,21 661:6

provider 653:12providers 151:14 153:22645:10 646:13,18

provides 24:21 46:1449:22 51:20 140:8165:9,10,12 198:20199:12 256:25 280:18315:12 316:12,17328:17 366:5 403:18405:8 440:18 528:24529:6,14 647:4 655:19

provides' 419:23providing 16:10 36:14149:22 164:19 190:15201:12 202:11 257:10259:20 275:12 290:3302:25 303:24 420:2561:4 570:16,18647:23

provision 209:9 344:15provisions 179:16391:14 419:4 483:4

Proximity 146:6,20147:2,3

PSI 160:25,25 200:16PSIG 160:10,22 163:2public 22:9,9 34:6 37:1937:21 40:10,12 45:2,652:14,22 66:21,2567:9,16,21 70:7,1476:9 84:9 86:9,12 89:790:1 91:18,23 92:1592:19 94:20 95:1,1895:20 97:11,18 98:1098:12 99:10,16 100:8100:10 101:7,12 102:4102:6 103:3,8,25104:2 105:20 106:7108:14,15,17,18 111:3111:3 117:8,9,17,18

133:24 134:1 135:25137:22 138:3 163:13175:19 178:1,3,23179:25 180:3 183:13186:4 188:7 191:11,11191:18 198:5 203:24205:22 206:7,7 211:15212:14,16 215:24220:17,19,23,25,25221:2,12,12,15 225:20226:1,1,2,5,7,19 231:5231:8,18 232:14,16,18232:19,20,22,23234:20 239:10,12,15239:20 240:11 242:2242:14,16,25 243:6244:15,17 249:18,19254:24 255:1 256:10256:23 258:15,21262:25 263:5 265:15265:17,19,24 266:1,6266:11,12,16 268:8270:15,17,17 271:3,16271:19,20,24 275:8,15276:6,10 277:3,4,4,7,9277:13 297:14 298:9303:19 307:10,14309:12,13,14,15,16,18309:24 310:12,13,14310:18,20,21,23 311:7311:8 313:16 323:21341:7 342:17 366:2379:22,25 383:4391:23 393:2 399:25404:20 409:1,1,2,3413:22 414:1,3,3,9,10414:12,16,19 415:3,10415:12,13,19 417:1,12417:16,16,18,18 419:2431:2,3,6,15 432:14434:17 438:25 439:6439:23,25 440:9,10442:19,24 443:2,13,15443:18 448:8 450:3,19451:1 452:20,24 454:4454:6 455:9 457:10,16458:6,10 463:23465:11,15 470:14,14471:15 473:14 475:23476:15,18 479:10,16481:10,13 484:25488:23 489:17 492:17493:3,9 496:10,21,24499:18,21 504:18,20510:19 511:5 514:24516:5 523:1,11 532:1540:21,23 544:14550:21 560:22 567:7567:13,17 568:1 573:3575:7 583:20 585:7590:16 594:12 597:13603:2,3,7 612:11,14618:2 623:25 624:6625:11 628:11,13631:16 633:6,13 634:8634:13 635:23 636:11636:17 638:7,20640:16,19 642:4 643:4

643:11 644:11,14645:8 646:4 647:20,22647:25 656:19,25658:3

publication 15:25 36:23213:6 235:5 258:7281:19

published 14:7 16:117:4 37:1 43:23 85:20107:22 120:13 133:8145:1 146:24 156:10158:21 169:19 177:5221:7 265:24 270:6,20289:21 290:2 293:24311:19 354:9 367:3386:5

pull 394:19 659:25pulled 223:12 390:9483:2 564:20

pump 54:2,3,5,13 55:755:10,11,17,20 56:1856:19,25 57:19 58:858:24,25 59:3,6 61:2063:25 64:2 584:19586:10,11,13,17,18,20586:23 587:5,7,17588:8

pumps 57:23 368:8377:3 586:7

purchased 552:22purchasing 334:23purely 102:13purged 41:22purging 160:1,2,5,6,7,9160:13,17 161:8,9,13162:11 163:5,14,19164:4

purported 351:12purports 516:16purpose 16:9 36:14136:7 151:24 179:5231:20 232:25 233:22237:2,20 238:3 239:4250:2 268:9 297:23329:8 409:21 492:24507:21 509:21 525:9645:20

purposes 14:21 35:687:19 129:19 222:4302:21

pursue 14:19 66:11227:15 228:8,21229:10 264:16 340:8480:17,24 521:3,18537:5 574:10

pursuing 185:5purview 298:3 302:13308:3,18 404:23 514:6547:16 554:22 562:25563:5

push 385:7 392:21393:10 487:16 623:11

pushbacks 288:2Puskar 5:8 164:9,9put 57:10 69:13 81:24112:14,18 114:5,9130:22,25 139:20156:16 170:25 171:3



Page 40

186:14 206:13 207:14237:19 260:22 271:10271:10 285:7 288:4,6313:18 324:6 331:6333:17 341:7 342:11342:16 351:10,24369:18 375:5 420:1462:8 477:7 482:4483:12 496:15 506:8534:8 603:20 621:3626:24 632:9 653:9,9

puts 82:23 114:10 186:3260:25 333:13 387:20397:7

putting 116:10 348:17357:4 372:13 419:10552:14 561:17 621:8623:6 646:18

puzzling 312:13

QQA 248:17quacks 621:25qualifications 525:2,4qualified 57:10 335:18505:10 506:1,14515:14,15,19,24 517:2518:13 522:10,13,16524:22,25 532:2

qualifier 122:17qualify 56:23 344:15quality 152:12 295:17383:5 397:20

quantified.' 128:23quantify 56:23 246:12quantities 279:7,13quantity 192:8,9 279:17286:1 435:16

quarter 21:21 196:21question 59:23 62:472:15 156:2 161:23209:14,18,21 210:8,14210:19 211:10,12252:24 253:1,3,12,16253:17 272:7,12,19,24272:24 290:14,18,21291:14,20,21,22 320:5320:12,19 321:3,7,8354:13 360:8,22,25361:3,10,15,16 370:6370:9,11,20,24,25377:25 378:3,7,10,18378:24,25 398:23399:5,8,20,21 401:24420:9,14,16,25 421:4421:5 423:21 449:9,11449:14,24,25 474:22475:5,8,19,20 477:15477:17,19,24 503:8,16503:21,22 504:1,3522:9 524:9,15,24,25525:18,20,23 526:8,9544:23 545:1,4,14,15545:16 554:18 555:3,5555:8,15,19,19,20565:18,20,23 566:9,10572:8,10,13,24,24,25580:21,25 581:19

583:3,16,17,18 610:7610:9 650:21 658:21658:25 659:2,5

question' 210:21questions 42:4 165:14204:2 566:9

quibble 622:9quick 49:9 198:9 263:24492:19 551:11 584:16

quickly 83:25 196:6358:1 591:21 625:3

quietly 13:4 35:22quite 105:3 141:22162:24 183:24 269:8282:17,18 318:1328:15 377:8 466:7492:21 553:13 561:9564:3

Quiter 5:10 168:20,24170:5,12,16 171:7172:2 173:8 174:8,17174:23 175:8,21176:12 177:15 178:2,7180:18 182:8 184:5185:23 186:16 187:5189:4 191:2 193:1,7194:5 195:7 197:6198:1,4,7,16 199:18200:4,6,8 201:18202:16 204:12,16205:5,24 206:10 208:2208:6,8,10 209:10,17209:23 210:9,18,23211:2,6,11 212:2,15212:19,22,25 213:2215:5 216:21 218:5,16220:5 221:17,22 223:4224:21 225:18 226:17227:12 228:1,18 229:7229:17 230:17,20,23231:1,7,11,15 233:20234:21 235:22 236:6237:7,23 238:21,25239:14,24 240:9 241:4241:8 243:15 244:3245:18,25 246:2 247:3249:10 251:4,24252:20,25 253:6 254:6254:9,12,25 255:4,8255:13,16,19,21,24256:2,4 258:12 259:22261:13,21,25 262:3,5262:24 263:3 264:1,4264:6,13 265:1,4267:13 268:17 269:24270:3,21 272:4,11,14274:1,5,8,12 276:16278:8 280:23 281:21283:13 285:16 287:18289:11 290:11,17,23291:2,8,11 292:18,20293:16 294:8,18,22296:10 299:1,22301:10,17,19,22 302:6304:4,9 305:9,12,18305:20 306:1,4,6,20308:22 311:2 313:6314:23 315:23 316:21

317:3 318:20 319:14320:2,11,14,18,22322:4,7,12,15,17,24323:4,8,10 325:25326:18 327:23 329:1329:13 330:9,11,13,22331:19,21 332:4,6,16333:20,23 335:6336:12 337:3,9,13,15337:17 338:11,18,20339:23 340:5,20,23342:18,20 344:1 345:7345:18,21 346:21347:16,24 349:9350:11 351:1,17 352:4352:8 353:6,13,20354:23 356:7,9,19358:3,19 359:16360:19,24 361:5362:14,21 364:15365:17,19 366:17,23367:20 368:11 369:13369:15 370:4,8,14371:22 372:1,25 374:2374:13 375:9,22376:16 377:21 378:2,6378:12,22 379:24380:3,25 382:1 383:15385:19 386:25 387:8388:15 390:18,25392:2,9 393:20 396:10396:22 398:20 399:4399:11 400:23,25401:4 402:2,21 403:24405:1 406:4 407:7408:11 409:11 410:7410:13 411:4,9 412:3412:17 413:12,16415:5 416:14 418:3,11418:22 419:17 420:7420:13,20 422:1,5,24423:1,7,16,24 424:3424:22 425:1,15426:14 427:4,6,10,21427:25 428:21 429:1429:14 430:3,10 431:5431:10 433:1 435:2,9435:20 436:20 437:5438:24 439:4,24 440:3442:8 444:2 446:18448:19 449:6,10,16450:21,23,25 451:5,15452:7,19,23

quo 644:25quorum 15:4,5,7,11,1535:5

quote 128:20 225:13297:24 298:1 354:13354:16 382:22 383:2427:1 444:17 447:14514:23 515:13 564:16

quoted 540:25

RR 2:1race 185:9raceway 447:2,6,13,14448:25 449:4 632:14

raceways 440:8,24442:21 443:7 446:25447:2,19,19,20 487:5

Rack 27:12radio 397:24radioactive 169:22171:14 173:23,25174:1 175:17

rail 119:22 120:10,16126:11 161:12

Railroad 87:10rain 538:16 544:13,13raise 61:23 75:12 78:1178:19,20,22 131:15232:10 242:21 527:23568:22 658:4,9

raised 129:10 153:25646:4 651:16

rampant 603:4Randy 8:20 9:10 379:19379:19 380:5,5 408:13408:13 495:24,24496:5,7 541:23,23

range 148:25 161:4,5355:17,17,20 380:17

range.' 354:16ranging 246:5rapid 284:11rapidly 148:8rarely 354:18Raske 392:5rate 126:15,16 127:20128:6,6 148:6 247:18284:14 358:16

rated 404:11 446:6 469:1471:2,2

rates 128:4 148:7 243:20250:18 466:1

rating 102:16 105:17469:10 470:24 487:10490:13 531:4

ratings 105:15 473:1rationale 61:19 110:20232:18 337:14 604:2615:14 645:14

re- 130:12re-brought 522:14re-enters 234:16re-scan 41:17reach 122:5 426:10626:24

reached 59:5reaches 438:14reaching 54:23 283:20reaction 643:23read 37:18 116:22 130:6207:19,20,22 237:14251:13 271:21,23305:20 309:8 324:7384:5 456:5 459:12466:6 468:17 472:24472:25 490:23 509:20554:9 580:13 643:22

readability 456:12469:25

reader 466:8,12readily 128:21 434:17578:20 614:8 621:4

reading 87:16 383:19reads 283:25ready 37:16 40:9 72:2472:25 150:3 151:5,22156:1,18 282:17,18287:1 305:13 338:14389:15 396:6 618:20618:25

real 55:12 57:20 67:1094:11 122:20 124:1167:2 181:6 188:9209:7 215:2 247:2257:14 280:12 282:4296:7 358:11 389:21401:24 576:1 584:16606:7

realign 123:14realistically 214:25507:1

reality 69:19 324:2realize 191:10 358:21401:11 471:16

realized 156:15 580:5really 63:25 68:5 69:1169:16 81:9 83:3,24127:21 128:9 131:4141:2 161:8 163:17164:15 170:24 172:14173:18 174:15,20191:15,24 192:17,20199:2,9,11 201:16220:22 221:15 225:15232:9 236:1,3,12,24239:6 251:12 276:12278:17 281:15 284:6286:3 311:16 313:12344:9 348:25 390:14394:25 397:1,12419:24 437:18 448:24474:13 502:7 543:22575:19 576:10,12580:6 582:20 600:22600:23 605:7 608:17630:11 645:12 648:20650:19 653:3,19660:10

reason 41:15 52:5 64:6115:10 129:7 134:18140:20 160:16 163:16164:15 165:8 208:18218:1 234:19 242:7249:20 309:7 316:4322:19 335:3 343:8358:16 359:23 360:17360:17 363:21 377:18387:11 395:18 435:18448:16,24 460:6482:21 487:16 489:23489:25 491:18 500:9506:2 516:15 528:15528:19,25 529:3,5,10529:23 535:14 587:25592:14 595:19 610:2626:11 633:2 645:16646:6 648:24

reasonable 149:21214:21 449:4 463:16576:5 582:6



Page 41

reasoning 213:13 233:9239:20 241:17 243:14463:16

reasons 109:2 151:2165:3 185:20 204:7241:15 242:5 245:17247:9 249:6 319:3375:20 436:2 572:2608:12 626:12

rebuilt 306:16 318:7336:4 409:5 496:8,12496:16

rebuttal 534:10recall 41:19 88:23237:10,12 548:1 558:3

receive 277:24received 220:17,25242:4,14 266:11 377:5414:2 415:10 434:8531:7

receiving 32:3 334:24receptacle 298:14312:17,17 494:12,13494:16 497:19 499:5500:12 538:9,14575:16 577:2,4 578:15578:18

receptacles 302:23353:25 354:17,19356:25 363:5,19 368:4372:8 469:5 494:10495:9,11 497:10 499:2500:9 502:2 508:20509:10 538:5 558:6,14576:24

recertification 336:9recipient 2:14,16,18,202:22,24 3:1,3,5,728:16 32:17

recipients 21:3 31:2434:22

recited 260:14recognition 25:15171:11

recognize 17:3 20:2433:9 34:5 172:1178:12 186:25 207:21216:17 257:9 287:11314:4 410:19 506:9533:6

recognized 21:16,2223:15 116:14 139:8,19140:10 165:3 258:1310:4 312:19,20 442:3448:7 471:12,13473:18 474:11 487:21547:19 552:3 569:17639:5 651:7

recognizes 109:9 440:21544:5 547:8

recommend 38:21,2241:2,3 52:24 53:1,6,765:8,10,15,16 70:1670:18 76:25 78:4,584:12,14,19,20 91:2592:2,8,9 95:3,5,10,1197:20,21 98:2,3 99:1899:20,25 100:1 101:14

101:16,21,22 103:10103:12 106:9,11,16,17117:20,22 118:2,3125:3,5 132:1,3 138:5138:7 143:19,21 155:1157:14,16 167:19,25168:2 175:25 176:2187:25 211:18,19212:3 218:13 224:25226:22,23 227:4,5240:13,15,20,21253:23,25 254:16,17262:14 263:7,9,14,15273:5,7,13,14 292:2,4292:10,11 304:13,15304:20,21 321:12,13321:19,20 338:25339:1,7,8 352:12,14352:19,20 361:22,24362:4,5 371:7,9,14,15379:5,7,13,14 400:2,3400:9,10 411:13,15,20411:21 421:10,12,17421:18 424:7,9,14,15427:8 428:4,6,11,12430:14,16,21,22 439:8439:10,15,16 450:5,7450:12,13 453:2,3,9453:10 457:18,20464:6,8 475:25 476:2479:18,20 481:19493:11,13 501:5,6504:7,9 511:7,9 520:4520:6 526:14,16536:19,21 545:22,24553:2 556:1,3 566:16566:17 572:2 573:5,7583:22,24 589:9,11593:3,5 596:6,8599:14,16 608:3611:21,23 614:24624:8,10 627:19,22,23633:15,17 636:19,21640:3,5 643:13,15657:2,4

recommend-- 225:25recommendation 15:12167:20 180:11 222:19283:10 326:9 444:25

recommendations 16:816:10 24:4 36:12,15

recommended 19:3,6125:13 171:22 179:22198:12 330:20 408:9410:11 435:17 443:20

recommending 88:8103:17,18 212:2256:21 647:20

recommends 87:24recondition 308:13333:16 337:25 406:1415:17 425:7,13 426:5429:4,5,25 430:1494:15 518:18 590:19597:16 598:14

reconditionable 497:20625:6

reconditioned 306:24

308:9,13,15 309:25310:3,4,12,15,16311:20 312:23 314:6315:18 317:23 318:4318:17 319:1,3,4,10319:19,21 320:1323:24 325:5 327:3,5327:7,22 328:7,8329:10 330:5 332:22334:14 335:21,24336:23,25 337:24401:19,21,23 402:16404:16,19 405:16,21406:24 407:3,24 408:4409:7 417:2,15 420:2422:10 425:5 426:23494:13,14 495:10,13498:12,15 499:6502:23 512:7,7,9,11517:10 523:4,21524:12,14 525:11584:23 585:10 588:18590:7 594:6,15 598:15626:13 627:2 637:22638:12 639:2

reconditioners 322:2330:4 400:20 424:20428:19 493:24 501:17518:9 520:22

reconditioning 305:25306:11 311:17 312:2,9312:13,18,20,25313:25 314:10,12,14315:5,15,17,20 316:5316:9,13 317:25 318:2319:9 324:22 325:9,10327:8,10,13,18 334:20335:15,22 338:8 403:3403:7,14,16,21 407:25409:22 410:22 417:17419:6,8 426:12 499:3500:16,18,19 502:6,25513:5,15 515:5 516:18518:14 519:3,12522:11,16 587:7,17592:3,7 598:12 627:7639:3

reconditioning' 306:19reconditions 308:6333:7 512:13

reconsideration 522:15reconsidered 289:8297:13 609:23

reconvene 339:19400:15

record 14:22 16:13 37:438:7 40:22 41:20,2353:2 55:25 56:9 62:1165:11 70:19 84:1592:3 95:6 97:22 99:21101:17 103:13 106:12117:23 125:6 132:4138:8 143:22 157:17168:3 176:3 210:2211:20 226:24 228:3,3240:16 253:11 254:1263:10 272:19 273:8291:16 292:5 304:16

307:10 321:3,14 339:2352:15 361:10,25370:18 371:10 378:16379:8 399:15 400:4411:16 415:19 420:24421:13 424:10 425:20428:7 430:17 439:11443:2,18 449:20 450:8453:4 457:21 464:9472:10 475:14 476:3479:21 483:12 493:14498:7 501:7 503:23504:10 511:10 520:7522:25 523:11 526:4526:17 536:22 545:10545:25 555:14 556:4561:11 566:4,18572:19 573:8 583:12583:25 585:6 589:12590:15 593:6 594:11596:9 597:13 599:17605:13 611:24 624:11625:10 627:24 633:18636:22 638:7 640:6643:16 657:5 659:7

recorded 16:22 41:22540:15 648:22,24

recording 2:10 13:1420:7 36:6 41:7

records 323:20recreation 88:16 96:14rectify 432:13Recyclers 428:18red 17:21 38:4 40:2062:16 285:21 511:3608:15

redone 369:23reduce 438:13 441:11,16442:1 444:11 445:19448:4 469:25 541:6543:3 562:22 644:22

reduced 142:14 241:22246:18 382:16

reduces 647:4reducing 20:20 150:12171:17

reduction 34:6 244:12244:20 386:2 488:21

reductions 380:23redundant 94:5 578:25Reedy 5:1 154:13,13reemphasize 597:11reestablish 50:22reevaluated 335:17reexamined 274:22refer 19:5 68:13 69:7267:6 347:4 373:5405:9 451:11 452:15490:19 491:1 515:19

referee 332:6,9reference 48:25 49:952:8 96:24 97:14116:11 126:13 127:19127:23 172:24 173:18199:21 256:11 271:25288:10 394:4 434:23437:13 438:2,4,5487:19 544:4,8 604:4

611:3 642:11,14648:12 654:18

referenced 68:13 116:9142:2 162:11 164:1244:17 249:23 408:23466:7 554:8 569:19639:8

references 56:5 68:6126:23 160:21 167:17219:6 244:18 311:23

referred 113:12 404:5490:23 618:14

referring 69:10 175:4271:6

refers 222:5 489:15refine 283:12reflash 257:21reflect 18:1 42:22 81:22205:3 481:21

reflecting 297:16 343:22reflectively 42:19reflects 121:7 237:20257:23 557:5

reformulation 122:23refresh 73:8,9,10,12refrigerator 395:13refurbish 426:5refurbished 130:15306:16 318:7 336:25627:2

refurbishing 334:17502:6

regard 171:19,25 548:18548:21 549:11

regarding 13:10 36:342:5,17 45:19,2346:15 297:11 302:15382:23 409:4 516:18540:16 548:7 554:18

regardless 16:20 317:24486:12 557:25 558:11558:13,15 618:22620:13

regards 474:7 576:8617:10

register 62:6,8registering 657:9registration 13:9 14:2016:18,24 36:2

regs 13:16,19 15:17,2236:25

regular 64:17 130:23325:6 397:4

regularly 515:5regulate 280:3 302:20557:10 575:15

regulated 196:17 201:7206:4,4,5 651:15

regulation 178:22197:19 274:19 276:23

regulations 13:15 15:1417:23 145:18,18 207:3218:3,14 232:11242:22 243:7 266:7,8267:1 302:23 303:19303:21 309:17 409:10413:25 414:6,24547:21,23,24 548:2



Page 42

550:21 552:12 569:19571:23 572:1 578:10578:11 579:10

regulators 194:19reinforce 197:15 418:16reinforced 298:4 495:10reinforcing 645:16reinstallation 523:23reinstitute 540:24reiterate 41:24 174:25204:7 452:12 540:12542:19 648:23

reiteration 427:15reject 42:19 53:14,1764:22 65:6 67:21110:20 112:22 121:3,5121:9 124:17,25125:20,23 131:12,23138:19,22 141:16142:16 143:10,16147:17 155:6 157:1,11159:10,12 166:15167:11,23 170:10,13175:11,23 241:2,5253:20 263:23 264:25265:2,14 273:3 294:16294:19 299:19 304:5304:11 305:23 306:2317:1,2 321:9 323:2,5330:18 337:4 338:22340:19,24 341:5,10342:13 346:20 350:24351:18 352:10 353:2,8356:16 361:18 362:11362:15 371:3,20,23374:11 379:3 400:21401:1 404:25 411:5,11413:10,13 414:8 418:2421:8,25 422:2 423:14423:17 424:5,21,23425:10 426:24 427:11428:2,19,22 430:12435:18 436:19 472:17491:7 493:25 494:2495:20 500:21 501:2501:20 504:5 511:21511:23 514:10 519:20520:2 521:12 522:2,4526:12 528:1,4 529:25535:14 536:10,17537:16,20 542:11545:19 546:18,22551:18 554:1 555:23556:19,22 566:12584:9,11 587:16588:24 589:7,20,20,23592:19 593:1,23594:24 595:22 596:4596:18,21 599:4,12600:3,6 604:7 605:2606:12 611:10,18614:1 619:7 624:21,23625:25 627:5,10,17637:8,10 639:20 640:1

rejected 111:2 191:19220:18,22 221:3222:18 226:3,16232:19,20 239:23

443:14 448:17 455:7490:20 528:15 553:13553:18 613:25 631:16647:22

rejecting 162:4 239:20351:22 501:18 593:20593:21

rejection 233:1 396:6528:16,19 645:8

relate 409:4 597:16related 15:13 37:10 55:482:18 148:9 221:18232:9 236:24 243:1266:10,17 309:16313:25 314:12 317:25324:1,3 327:9 349:24353:4,9 356:17 361:19362:12,16 371:4374:11 414:2,6,13437:15 461:14 468:12468:12 484:25 487:5523:4,5 540:16 542:12546:19,23 551:9555:24 556:23 566:13585:9,11 587:17590:19,20,21 594:14594:16 597:15 598:23600:4,7 611:11,18625:13,14 638:11,12642:5

relates 323:15 610:17relating 496:22 610:25relation 112:1 220:22288:16

relative 121:22 221:6284:2 327:18 533:7538:24 562:12 563:25579:21 661:8

relatively 46:10 283:3383:5 612:22

Relay 405:4relays 584:21release 97:14 126:14,15126:16 127:19,20128:4,6,6 237:15243:20,23 247:18

releasing 165:18 274:23relevant 49:22 112:16275:17 359:9 360:9570:19 619:5 630:3

reliability 171:16 194:16reliable 202:11 482:10relied 300:24relies 23:20 163:21relocate 348:15relocated 345:3relocating 642:8relocation 642:10rely 198:10 394:5 422:18442:4 517:22

remain 57:13 64:19126:23 128:3 162:11259:2 318:2 551:10577:15 606:11

remainder 339:17remained 23:18remaining 18:11 31:1632:2 131:8 209:19

253:2 290:19 320:15361:1 370:10 378:8399:6 420:15 449:12453:15 475:6 525:21545:2 555:6 565:21572:11 583:3 629:9

remains 139:16 312:3318:9,14 558:24

remanufactured 311:20318:7 408:16 409:5414:18 496:23

remanufacturing 306:16334:19

remark 336:2 337:20remarks 17:12 18:14512:5 551:9

remedy 558:4remember 13:5 35:23215:8 253:7,12 272:18321:1 334:25 361:9491:4 549:20 553:13553:17 650:14

remembering 370:19remind 12:12 17:18 35:736:6 41:13 154:3314:13 345:16 349:14553:12

reminder 121:4 411:24585:3

remorse 303:7remote 181:8,9,24 182:1182:18 188:5 196:2,4196:6 207:13 259:8287:10 466:21 587:1614:10

removal 312:24 323:17328:16 329:8 513:6523:22 525:9 605:24630:12 637:23

remove 44:17 45:18 49:267:7 148:23 229:6265:9 267:12 299:20327:17 328:18 329:20331:8 333:8 336:5338:9,9 385:2,11423:14 499:4 519:5542:24 543:1 559:7578:11 605:22 627:6,6

removed 66:14 173:5227:18 228:11,24229:13 264:19 326:23327:2 336:2 340:11345:2 480:20 481:2482:12 512:13 521:6521:21 537:8 538:3573:21 574:13 578:14607:23

removes 187:15 366:14423:5 437:13 517:2646:25

removing 242:18 328:5330:6 334:13,14422:17 516:17 541:7542:3 606:1 645:19646:6

rendered 110:3rendering 577:7renewable 425:7

renewed 429:9RENS 425:8renters 372:15renumbered 648:20reoccurrence 200:22reorder 42:11reordered 304:24 453:19546:5 574:15

reorganization 444:15457:3

reorganize 128:15rep 435:13repair 316:13 329:22repairs 329:22repeat 294:24 412:24416:23 425:19 437:15462:6 551:10 660:6

repeated 575:22repeatedly 153:21 434:3repetition 396:11,12replace 47:15 48:1312:19,21 314:9,15344:19 348:11,12385:3,12 394:20 420:2426:10 429:25 441:9500:13 519:5 616:8

replaceable 513:11replaced 245:13 513:12627:3

replacement 312:14314:6 344:25 348:11441:10 500:17 502:24513:7 514:19

replacements 500:10replacing 160:17 312:6312:16

replicates 445:13replies 557:25reply 220:8report 14:12 17:8 42:2543:3,5,17,19,21,22,2444:7 63:20 85:2,4,7,1485:16,18,18,21 86:493:8 107:4,7,10,16,18107:20,21,23 108:7119:21,23,25 120:7,9120:11,12,14,22123:10 132:14,17,20133:2,4,6,7,9,18 144:8144:10,13,20,22,24,24145:2,9 146:4,8,10,17146:19,22,22,25147:10 158:3,5,7,15158:17,19,20,22 159:5169:1,3,6,13,15,18,18169:20 170:4 176:12176:15,17,24 177:1,3177:3,6,13 220:19,20221:14 232:15 242:1247:20 249:1 251:13252:3,4,4,9 265:25270:19 292:20,23,24293:17,19,21,22,24294:7 357:6 380:17,19386:5,7 394:5,6604:21,24,25 617:11617:14 642:11 651:17

reported 63:23 131:19

149:1 386:9 433:16482:18

reporting 24:3 394:7reports 43:6 44:3 85:885:25 107:11 108:3120:1,18 132:21133:13 136:3 144:14145:5 146:11 147:6158:8,25 169:7,24176:18 177:10 292:25294:2 391:12 394:5,9

reposition 528:23represent 45:16 49:19154:14 159:24 186:21187:12 189:8 201:23213:5 252:12 255:17255:22 263:22 294:13295:1 299:4 310:13315:25 316:25 329:3340:17 345:12 353:1355:7 359:20 365:25375:13 385:22 404:2410:15 423:12 426:2427:7 442:16 454:2,13461:11 468:9 484:23495:4 507:16 509:17512:25 518:6 523:17524:19 540:2 542:9546:14 547:4 585:18587:22 590:25 592:11594:21 595:16 597:22598:5 600:1,13 602:22607:3 612:9,20 621:1625:21 626:8 631:12647:16

representation 194:10530:10

representative 66:10177:23 195:5 227:14228:7,20 229:9 436:23480:16 483:11,15532:12 573:18 619:13620:22 622:17 642:22649:13

representatives 300:19645:6

represented 117:14222:24 488:14 585:20591:3 597:25 625:24

representing 24:1844:16 48:21 62:4105:4 142:19 164:11190:5 194:8 199:25204:16 217:4 227:11229:5 244:9 252:23254:23 256:8 289:14290:13 300:1 302:8305:15 306:10 309:3313:8 316:23 317:6319:17 322:1 329:16330:25 335:8 336:15341:4 345:10 349:12350:5 353:17 356:14358:6 362:9 364:23366:19 371:19 373:8379:20 380:6 381:8388:19 402:10 408:13416:19 418:7 423:11



Page 43

424:20 426:19 429:22433:9 435:23 437:8446:22 449:8 456:3459:10 478:21 493:23495:19,25 497:8,25502:16 504:25 513:24515:11 521:11 522:1535:21 537:16 540:4549:16 551:22 555:2559:17 563:13 567:3570:1 571:4 572:7577:24 579:18 580:20587:15 591:14 593:15596:18 604:14 608:23617:8 620:21 624:20635:7 638:17 641:17650:1,2 652:8

represents 162:12194:10

reproduce 127:22reputation 384:23request 42:13 61:8 81:9137:2 190:25 215:12237:5 273:22 276:20402:15 419:5,7 456:8464:17 465:1 470:6489:2 567:7 602:9604:4,6 607:22 618:11644:24

requested 42:11 89:2443:23 470:4 476:8481:25 483:18 554:20567:13

requesting 189:11644:19

requests 419:4 613:25require 47:20 50:2363:21 88:5,8 96:23162:9 163:8,10,14184:14 216:16 246:11258:22 261:3 262:18276:5 312:24 330:3341:18 345:1,1 406:15415:1 433:11 440:7,23442:20 443:8 445:11446:24 447:3 459:15466:23 487:25 540:10541:19 548:5 567:8570:13 576:16 637:23655:25

required 24:1 46:16,2346:24 47:14,18,23,2548:14 49:21 81:2591:1 115:11 122:18160:9 183:19 206:25223:2 251:15 260:7,20303:22 309:25 310:14312:22 349:4,17 351:6367:11 392:18 417:2489:9 507:20 508:1538:25 560:11 568:24578:25 587:3 601:25602:4 603:16 611:7615:21 645:23

requirement 46:3,10,1246:18 48:23 50:15,1650:17,19,20 51:18,2152:6 64:14 68:7 87:1,2

91:15 150:6 156:7260:18 267:3 285:4,6310:10 327:1,16 328:6333:6 334:13 336:5343:18,25 344:8,18347:21,22 349:15354:14 357:3 366:8,10383:10 395:4 413:21417:4,7 432:23 441:25445:13 458:17,19,24463:2,16 467:2 491:20516:4 536:4 540:24542:24 548:25 568:5,7568:19 569:4,13571:18 578:14,22614:3,14 622:7 625:5637:19,23

requirement's 344:22requirement.' 515:25requirements 45:2067:11,12,17 83:587:12 93:4,4,11,1294:15 96:8,23 97:798:22 100:21 109:4110:1 111:12 134:23134:24 149:5,7,10,17150:2 151:6 153:6,8153:23 154:1,4 160:5160:8 162:9 163:6,24167:1 174:4 175:16181:3,13,16,17,24182:24 183:4,6,10,13183:15,16,24 184:3191:24 198:25 199:4206:22 214:16,22215:23 216:6,11,11,12216:17 217:9,16,20,23218:11,24,25 219:2,10219:20,24 223:2,15,25232:9 233:23 234:12236:2,12,22,23 237:1250:4 258:19 265:11267:7 268:16 269:19275:13 284:10 286:20286:21 287:7 295:22295:24 298:15 301:2,7309:21 310:19 311:23327:14 329:11 332:25334:9,10 335:12,16343:5 344:11,21,24353:25 359:5 372:7383:14 384:22 392:15393:11,25 406:17407:24 413:25 414:17414:21 419:10 431:20431:23 434:1,3,12,16436:14 440:15 444:10444:14 445:17 454:16456:21 458:22 461:5463:14 471:7 482:24483:3 489:15 500:15524:11 525:12 529:7531:5 532:25 533:1,4534:13 538:2 543:16547:21 548:10 552:14553:4 557:12 558:19563:6,7 568:10,18,23569:15,16 571:15,17

575:18,25 577:11578:6,23,25 580:1601:19,24 602:6603:19 605:23,25606:3,10 607:21,21608:1 614:6 615:24616:16 618:23 619:2623:8,12 628:25629:13 630:14 641:25642:9 645:17,25648:16 652:15

requires 44:18 58:6,14161:14 163:9 166:4,5167:15 170:22 232:12250:16 328:7 329:18443:19 444:17 445:9448:11 515:14 538:4540:10 606:5 655:24

requiring 12:20 35:1446:1 222:25 224:19275:22 279:10 323:16446:14 460:9 576:9

reread 627:20reroute 348:15research 122:25 128:21129:23 148:21 149:4153:10,15 163:21247:20 333:9,14382:19 383:1,7,12443:24 506:18 562:23

researching 508:23reserved 234:15reset 78:12,21 387:19578:20

resetting 72:3,8 397:15reside 368:8 571:11,12residence 385:10 564:24residential 31:8 57:8164:20 201:12 380:17382:17,23 383:3 385:9386:5,8,16,19 447:21466:25

resides 300:3 422:19423:13 551:12

residual 166:2 409:25resign 46:2resist 209:4 488:18resistance 142:3 446:6466:3 488:13,22563:18 576:16

resistive 487:10resolution 497:16resolve 307:6 377:16resolved 74:22 309:15442:19 519:15 561:12

resort 269:8resources 29:24 209:4547:22

respect 163:12 183:21215:19 225:23,25239:21 408:24 434:9608:23

respectfully 180:16214:24 520:23 604:4,6607:22 647:1

Respecting 185:20respective 22:16respects 531:12

respirators 397:17respond 186:10 196:7203:12 204:4 270:11338:15 395:9 415:24515:2

responded 190:5,6224:3,4

responders 182:7183:14 186:4,11 188:7194:21 199:13 203:3203:24 215:24 243:25

responding 186:15387:15 446:16

response 96:11 100:24104:14 122:20 129:8433:22 465:1 478:2532:23 539:2 559:14569:25 594:19 613:17615:8 625:18 641:15

responses 354:8 367:4responsibilities 296:13302:14 549:9 585:3597:12

responsibility 300:21303:19 307:5 370:2415:21 422:20,21434:1 517:11 550:21560:10 579:9 607:8

responsible 17:7 23:2441:25 44:3 85:24108:3 120:17 133:12145:4 147:5 158:25169:24 177:9,25 200:1294:2 302:10 326:10327:8 431:20 505:8517:7 534:2 549:18553:5 559:19 562:19564:4 570:3 577:25629:6,8

rest 387:24 407:9 549:13restate 52:21 65:5 70:1276:7 84:8 91:22 94:2597:16 99:15 103:7106:6 117:16 124:24131:22 138:2 143:15157:10 167:22 175:22226:18 240:10 253:19263:4 273:2 291:24304:10 338:21 352:9371:2 379:2 399:23411:10 421:7 424:4428:1 430:11 439:5452:23 457:15 464:3475:21 479:15 493:8501:1 504:4 511:4520:1 526:11 536:16545:18 555:22 566:11573:2 583:19 589:6592:25 596:3 598:11599:11 611:17 624:5627:16 633:12 636:16639:25 643:10 656:24657:25

restatement 598:9restating 434:11restore 249:6restored 311:12,14,15626:25

restores 610:15restoring 247:10restrict 489:13restricting 414:17restriction 260:16 408:5restrictions 490:12532:1

restrictive 46:19 109:18117:4 234:3,18

restricts 529:21result 91:13 122:23159:1 268:7 300:23355:15 359:7 366:9373:19 374:19 380:12384:24 385:10 386:12405:25 433:17 468:21468:25 484:7 486:18514:18 518:15 598:13598:25 603:11 637:25647:5 651:9

resulted 296:17 355:18356:3 516:5 646:4

resulting 16:13 22:1637:5 438:14

results 15:25 16:1,918:17 36:13,24,2538:10,20 39:15,1541:1 44:4 53:5 65:1,1478:3 84:18 85:25 92:793:8 95:9 98:1 99:24101:20 103:16 106:15108:4 118:1 120:18123:7 125:11 129:17132:6 133:13 136:4,5136:23 137:8 138:11143:25 145:5 147:6150:23 157:20 168:6169:25 176:6 177:10211:6,24 227:3 240:19253:15 254:15 263:13272:22 273:12 291:19292:9 294:3 304:19321:6,18 339:6 352:18361:14 362:3 370:23371:13 378:23 379:12396:1 399:19 400:8411:19 421:3,16424:13 428:10 430:20437:23 439:14 449:23450:11 453:8 475:18476:6 493:17 501:11504:1,13 520:10526:20 555:18 556:7566:8,22 572:23573:11 584:3 589:15593:9 596:12 599:20612:2 624:14 628:3633:21 636:25 640:9643:19 659:16,16

resume 119:18 230:15retail 482:15retired 88:19 189:7396:17

retrieve 360:6retroactive 46:1 225:24245:12

retroactively 276:5retroactivity 268:10



Page 44

retrofit 50:19,24 51:1852:6

retrofitted 396:5return 15:15 41:6,16118:25 241:18 243:12274:2 278:20,20280:16 285:19 287:13291:25 343:21 361:17399:22 421:6 577:6608:16 609:9 610:5,17

returned 283:11 297:15381:17

returning 42:1 347:13476:8

returns 253:17 272:25379:1

reuse 418:17revealed 382:22reverse 295:7 547:11reversed 531:15 558:12reversing 393:15revert 218:13review 22:21 23:1 24:988:21 165:25 186:3242:25 265:16,24266:11,16 310:21,23310:23 313:16 342:17414:3,12,19 415:3417:17,19 425:20496:10 499:18,21514:25,25 515:8 516:5530:22 531:8,11,15549:9 584:18 597:12638:6 647:25

reviewed 14:25 135:20226:7 243:6 266:5296:14 307:9 415:18416:10 434:18 490:21522:25 523:23 549:10585:6 590:15 594:11625:10 638:22

reviewing 22:9 23:24reviews 153:18revise 440:10revised 243:18 326:5554:13 618:11

revising 281:11revision 22:7,13,1942:20 43:22 53:15,1754:1,4 64:22 65:6 67:867:22 69:6 85:19 90:993:16 99:1 107:21120:12 121:3,6,10124:18 125:1,21,24131:13,24 133:7138:20,23 142:17143:11,17 144:25146:23 147:18 149:2149:15 155:9,20 157:1157:12 158:20 159:10159:12 160:21 166:16167:11,23 169:19170:11,13 175:11,23177:4 179:11 180:1183:5 191:18 205:19216:7 241:2,5,21,22241:24 242:4,10,14,23243:1,4,5 244:12,16

244:17,18 245:2,16251:13,18 253:21258:16,17,18 263:24264:25 265:2,14,18,20265:23,25 266:4,4,15266:17,20,20,23,23267:10 273:3,25 275:9276:13 277:5 293:23294:17,20 295:5296:16 304:6,11 306:2317:2 321:10 323:3,6323:21 326:3,6 330:19331:7 337:5 338:23340:19,25 351:19352:10 353:3,4,9356:17,18 361:18362:11,12,16 371:4,5371:21,23 379:3400:22 401:2 409:2,3411:6,11 413:11,13,23414:9 421:8,25 422:2423:14,17 424:5,21,23427:11 428:2,20,22430:12 443:9 466:19493:25 494:2 495:20500:22 501:3,18,20504:5 511:21,23 514:6514:18,21,24 519:21520:2 522:2,4 526:12528:2,5,14,15 529:20529:25 535:16 536:11536:17 537:18,21538:23 540:6 541:2,11541:17 542:12 544:7545:20 546:19,20,23546:24 550:9,23555:23,24 556:22,23557:3 560:20 566:13566:14 578:7 584:9,11587:16 588:25 589:7589:20,23 592:20593:1,21,23 595:23596:4,19,22 599:5,12600:3,4,6,7 601:12,12603:10,10,12,13 605:3605:6 608:14 611:11611:12,18,19 617:24618:1,2 624:21,23627:11,17 637:8,10638:21 639:20 640:1641:21 642:7,7 645:14650:4,9

revisions 22:3,23 24:2243:24 44:2 85:21,23107:23 108:2 120:14120:16 133:9,11 145:2145:3 146:25 147:4158:22,24 169:21,23177:6,8 205:17 221:4226:4,6 266:10,13277:11 287:16 293:25294:1 296:14 319:7,12353:10 361:20 362:17414:5,14 434:15,22438:4 549:9,12 559:8

revolved 369:1rewired 369:18reworded 425:11 512:16

522:14rework 316:13rewrites 261:10rewritten 603:13RFI 398:3,9Richard 5:4 8:2 9:2510:22 158:6,16 161:21161:23 162:1 167:14329:15,15 330:10,12340:16,16 341:3,3342:19 347:25,25525:17,17

Ridge 30:15ridiculous 436:15right 39:7 44:12 49:1174:10 75:17 77:6,1177:13,14 78:15,2293:2 163:24 166:17168:25 187:21 189:15190:24 192:5 196:1,3196:22 202:24,25206:23 207:6,10209:13 216:23 224:2224:12 226:15 247:9249:9 255:18,20 256:5258:1 264:5 286:11287:5 289:21 290:8315:10 332:21 334:6346:9 369:11 376:22393:18 394:13 402:19405:16 417:10 440:11469:5 474:24 477:25482:13 489:11 514:11517:20 527:17 530:20567:21 589:5 599:3610:22 613:5 619:23654:23 657:20

right.' 390:13Right?' 505:20rightly 248:18 547:15rights 622:5rigorous 167:7,9 201:8rise 58:9 111:22 154:15290:24 309:4 319:17331:1 349:13 367:22404:3 416:20 426:20498:1 513:25 591:15

risers 630:9rises 57:5 368:3rising 430:6 490:9risk 34:6 80:10,10 107:8156:19 186:5,14187:20 188:18,20,23189:2 200:1,14,15,24214:13 316:8 363:8372:14,14 387:21397:8 410:24,25441:11 442:1 448:4

risks 189:13 246:11445:8

River 184:7riveted 405:10road 132:16 133:5,10140:2 319:23 330:3357:12 471:18 562:23564:20,20 565:6,7

roadkill 653:5roadmap 180:14

roadways 562:20 564:2Roaks 10:1 444:6,6Robert 6:2,7 7:22 195:9195:9 201:22,22 206:1206:1,12 223:8,8260:2,2 270:23,23317:5,5 335:7,7442:13,15,16 451:20451:22,23 631:9,11,12635:4,6,7

Robert's 334:1robust 57:3 141:22531:5

robust' 141:23rock 172:24Rodgers 7:19 315:25,25329:3,3 410:15,15427:7,7 524:19,19587:21,21 592:10,10595:15,15 626:7,7

Rodrigo 10:7 460:18,18473:9,9

Rogers 11:7 602:18,19602:22,22 607:6612:24 615:7,9,9

Roland 2:21 26:23,23,2527:20

role 21:17 23:16 24:1201:11 562:20

roles 569:13roll 621:2roof 409:17room 12:10 13:4 16:1935:22 74:18 78:293:23 164:24 192:10192:25 203:3 258:25279:11,16,19 313:19364:1 377:25 388:7,21398:17 413:2 509:10592:6 605:12 618:15644:4

rooms 260:7 279:10,22280:7

rose 491:3round 360:3 658:24routine 207:10routinely 149:9row 407:13RRC 193:16rule 307:15 613:21rules 14:2,2,18 66:12,13145:17,19 206:20227:17,17 228:9,10,23228:23 229:11,12264:17,17 300:5 340:9340:9 480:19,19 481:1481:1 516:6,17 521:4521:4,19,19 523:5537:6,6 547:17 548:3549:22 551:14 559:22560:10 573:20 574:11574:11 585:10 590:20594:15,16 597:16604:6 625:14 638:12

run 40:2 88:3 188:20374:25 376:8 469:21490:15 626:20

run-throughs 151:21

runaway 250:16,23257:17

runner 556:10running 72:4 79:19,24154:25 260:11 395:13

runs 161:11 395:15469:17

Runyon 4:7 107:8,15,17108:9 110:25 111:2117:13 118:7

rural 201:23,24 202:9rush 151:20,22rushed 152:12 223:23RV 538:5,7 539:10,14540:1,2,14,15,16541:5 543:13,17,21544:10,11

RVs 543:18Ryan 7:1 9:7 283:15,15405:3,3

SS 2:1Sadly 394:7SAE 299:4 547:6 551:22551:24 552:4,8 556:19563:13,24 567:6569:17,17 571:4 575:4576:15 579:18

SAE/NFPA 561:16 576:3safe 34:8 122:5 142:22152:24 178:23 186:11202:11 203:14 243:10243:11 252:14,17283:7 286:5 295:17303:11,23,24,25 348:6357:5 369:9 406:2418:16 474:13 482:10513:8,16 518:17562:20 570:14,15,17651:2

safeguarding 179:6297:24 298:23

safely 164:5 190:19,21214:6 245:11 304:2469:14 483:5 550:13560:16 570:20 571:19602:7 603:5 652:12

safer 180:10 247:16248:2,19 249:7 282:25283:3 288:13 290:1382:13 460:14

safeties 288:25safety 12:12,13 20:20,2326:11 27:3,5 29:2530:2,19 31:6 32:2033:5,6,19,25 34:1,3,1835:7,8 49:19 50:1456:16 63:16 122:2142:14 150:17 153:4153:14 155:16 161:14163:17 165:6,23172:21 173:4 177:21178:13,14,20,24 179:5179:22,24 180:2,6181:6 183:13,14184:19 185:19 186:3187:22 188:11,21



Page 45

189:2,25 194:16 196:8199:9 201:6 202:23203:10,23,23,23,24205:17,22 209:6212:11 213:4,15,23,25214:12 215:23 219:16224:24 242:7 243:24247:23 260:13 273:21273:23 286:9 290:3,9295:15 298:12,20299:17 301:2 303:20309:7 316:4,8,18,19316:19 319:3 324:1,3327:21 329:11 335:1336:8 343:13,18,20,23345:5,15 351:13357:17,23 380:11,22382:14 385:6,16,17389:19 392:16,16393:7 406:22 410:20410:24,25,25 411:1,1442:6 444:9 446:13460:10,11 462:10469:2 474:2 483:9515:6 525:13 540:14540:18 541:1,6 542:2544:9,14 547:25 548:7548:14 550:1,22 552:1552:9 553:4,6 557:16557:17,24 559:6561:11,23 562:1,18,24562:24 563:10,16,17564:1,4 568:25 571:22571:24 575:22 576:1,7576:9 586:13 587:5,25588:1,2,2 592:4,14,15592:15,16 595:18598:23 601:25 605:15606:1,1 607:11 610:21611:7 616:12,20 617:1622:3 626:11 627:3647:4 649:25 650:24651:1,4,16,17

sake 228:2Salt 184:7Salvador 460:19sample 37:15San 12:9 189:8 387:3Saporita 3:5 30:12,14satisfy 528:21saturation 89:11save 47:12 65:25 335:2369:9 385:8 389:10562:21 660:1

saved 519:6saves 49:8 377:17saving 384:15 588:20saw 199:7 277:6 417:7530:24 581:6

saying 185:9 186:23207:18 222:16 225:2,4235:15 270:12 286:20286:25 288:5,11 348:8351:14 404:6 487:3509:3 561:15 614:20623:16

says 50:20 60:1,8,1169:12 81:19 88:7

90:20 93:2 109:3,13110:12,14,15 114:6116:22 117:2 121:23127:1,9 134:11 142:10142:22,25 165:11170:25 192:23 197:24204:22 206:17 231:23250:1,10 251:14260:20 270:7 288:25302:2 312:1,13 331:15337:25 414:1 472:20489:23 509:20,24517:10 533:10 543:12576:18 636:3

Sazza 505:12scale 182:16 195:20200:23 243:22 246:1,4246:11 247:21 248:19249:1 250:2,10,14,19250:23 251:11,15252:5,16 257:15289:25

scanty 126:25scary 490:17scattered 184:11SCBAs 154:4scenario 438:11schedule 22:17 221:6,7267:19 270:8

Schmidt 11:2 556:13,16556:16 557:7,7 561:3561:3 574:2,2,19,20574:22 575:1,2,12,13579:21

Schneider 28:1 316:1,1316:2,5,12,14,16329:4 367:21 374:16385:22 410:16 418:12418:14 421:24 422:8427:8 497:9 518:6,8524:20,20 537:15544:1 587:22 592:11595:16 598:5,24 626:8

school 358:8,9 394:16394:18

sciences 525:5scientists 506:5,11scope 87:17 90:7 160:15179:19 183:18 191:14191:15,19 194:15,18204:19 209:5 213:7,9217:11,15 219:4220:16 222:12 225:6226:13,14 232:1233:15 235:4,15 236:1236:11 237:18 238:3,7238:10,23 239:4 268:9279:3 295:11,25 296:2296:14 297:2,6,10,19298:7,21 303:15325:19 404:8 433:25434:7 436:5 517:15534:7 547:13 548:24549:3 550:17 551:9554:10,13,20 559:5560:6,6 562:14 564:16656:8

scopes 162:23 296:13

549:9Scott 7:11 11:2 302:8,8535:21,21,24 536:2549:14,16,16 556:13556:16,16 557:7,7559:15,17,17 561:3,3564:13 569:24 570:1,1574:2,2,19,19,22575:1,1,12,12 577:21577:23,23 579:5

SCR 538:11screen 18:13 19:3,6,8,1138:1,21,22 40:17 41:341:4 43:10 52:24 53:153:6,8 60:6 65:8,10,1665:17 67:23 70:17,1875:12 76:11 77:1,478:4,6,11,19,20,2184:12,14,19,21 85:1292:1,2,8,9 95:4,5,1095:11 97:20,22 98:3,499:19,20,25 100:1101:14,16,21,22103:11,13,17,18 106:9106:11,16,17 107:15116:21 117:21,22118:2,3 120:5 125:4,5125:13 132:2,3 133:1137:10 138:6,7 143:20143:21 144:18 146:15157:14,16 158:13167:25 168:2 169:11175:25 176:2,22197:22,24 198:5199:20 211:18,20212:3,4 226:22,24227:4,5 240:14,15,20240:21 253:23,25254:16,18 263:7,9,14263:16 273:6,6,8,13273:15 289:23 292:3,5292:10,12 293:4 296:9304:13,15,20,21305:20,21 308:17321:12,14,19,20330:21 338:25 339:2,7339:9 349:16 352:13352:14,19,21 353:24361:23,24 362:4,6371:8,9,14,16 379:5,7379:13,15 400:2,4,9400:10 402:19 410:12411:14,15,20,21421:10,12,17,18 424:7424:9,14,15 428:4,6428:11,12 430:14,16430:21,22 439:8,10,15439:16 450:5,7,12,13453:2,4,9,10 457:19457:21 464:6,8 475:25476:2 479:19,20493:12,14 501:5,7504:8,9 511:7,9 514:4520:4,6 526:15,16536:20,21 545:23,24556:2,4 566:16,18573:5,7 583:23,25589:9,11 593:3,5

596:6,8 599:15,16604:24 611:21,23617:12 624:9,10627:19,22,24 630:4633:15,17 636:19,21640:3,5 643:13,15657:3,4 659:4,6

screens 19:2 37:15,1642:21 74:4 75:1277:18 78:12 121:7481:21 557:5 636:8

screws 426:11scroll 41:11 209:24253:7 272:15 291:12320:23 361:6 370:15378:13 399:12 420:21449:17 475:11 503:19526:1 545:7 555:11566:1 572:16 583:9659:3

scrolling 210:20 263:19305:7

scrutinized 244:15SDI 88:9se 519:2seal 441:16 442:21,22443:5 447:25 448:24449:3

sealant 447:5,8sealants 448:13sealed 257:1 445:2,3447:1

sealing 440:7,20,24441:24,25 442:20445:14 447:2 451:12

seals 444:17 445:1,9446:14 447:15 448:4

Searles 6:11 212:8,8,21212:24,24 213:1,3224:23,23 273:19,19274:7,10,10,13 277:5

Searles' 225:23Seat 130:9seated 16:19 75:22,2576:2,24 77:7 407:8

seats 19:19 73:3 119:17119:17 192:14 230:14230:19,23

second 23:11 38:11,1739:8 42:20 43:6,22,2445:7,8,9,11 53:15,1753:18,18,19 54:4,864:22 65:6 67:1,3,8,2268:5,7 69:6 73:2 81:481:5,6 85:8,8,18,2186:13,14,15 91:792:19,20,21 95:21,2295:23 98:13,14,16100:11,12,13 102:7,8102:10 104:3,4,5107:10,20,23 108:19108:20,21 111:4 120:1120:12,14 121:3,6,10121:11,12,13 125:1,20125:23,24,25 126:1,2128:7 129:5,9 131:13131:24 132:21 133:6,9134:2,3,4 138:20,22

138:24,25 142:17143:11,17 144:14,24145:2 146:11,22,25147:17,23,25 150:22154:2 157:1,12 158:8158:19,22 159:10,12159:13,14,15 165:8,23166:15 167:11,23169:7,18,20 170:10,13170:14,15,16 175:11175:23 176:18 177:3,5178:4,5,6,7 183:5184:24 191:18 209:21209:22,23 212:17,18212:19 213:21 220:19221:5,8,9,13 223:13226:6 231:9,11 232:14232:15 241:2,5,6,7,8241:21 242:4,10,23243:4 244:12,17 245:2245:15 251:13,18253:4,5,6,21 255:2,3,4258:16,18 263:23264:1,6,25 265:2,2,3,4265:14,20,22,23,24266:9,14,20,23 267:16270:8,19 271:15 272:9272:12,13,14 273:3274:3,4,5 275:7,9277:11 290:23 291:5,6291:7,8,9,10,11292:25 293:22,24294:17,19,20,21,22297:12 299:9,14300:18 304:6,11305:20 306:2,4,5,6,25311:21 317:2 320:17320:20,21,21,22 321:9323:2,5,6,7,9,10 326:3326:6,7 330:19 331:6337:5 338:22 340:19340:21,22,23,24342:16 348:22,24351:19 352:10 353:3,8353:11,12,13 355:14356:17 360:23 361:3,4361:5,18 362:11,15,18362:19,20,21 365:6,16370:12,13,14 371:4,21371:23,24,25 372:1378:10,11,12 379:3380:1,2,3 381:13,20381:21,23 391:12398:25 399:8,9,10,11400:22 401:2,2,3,4407:22 408:3,20 409:3411:6,11 413:11,13,14413:15,16,20 420:17420:18,19,20 421:8,25422:2,3,4,5 423:14,17424:5,21,23,24,25425:1 427:11 428:2,20428:22,23,24,25 429:1430:12 431:7,8,9,10435:13 440:1,2,2,3441:14 443:13 449:14449:15,16 451:2,3,4,5454:7,8,9 458:10,11



Page 46

458:12 464:21 465:15465:16,16,17 466:18475:8,9,10 476:19,20476:21,23 477:5481:14,15,16 493:25494:2,3,3,4,5,7 495:20499:18 500:21 501:2501:20,21,22,23,24503:16,17,18 504:5,21504:22,23 511:21,23511:24,25,25 512:1514:21,24 516:3519:20 520:2 522:2,4522:5,6,7 524:9525:23,24,24,25526:12 528:2,4,5,6,7,8528:9,15 529:6,25531:9 533:7 534:24536:11,17 537:17,20537:21,22,23 538:2,23541:11,17 544:7 545:4545:5,6,20 546:8,18546:22,24,25 547:1550:9,23 555:8,9,10555:23 556:22,24,25557:3 559:8 560:20563:25 565:23,24,25566:12 567:18,19,20567:21,21 569:3572:13,14,15 575:8,9575:10 581:16,17582:9,10 583:6,7,8584:9,11,12,13,14587:16 588:24 589:7589:20,23,24,25 590:1592:19 593:1,21,23,24593:25 594:1 595:22596:4,19,21,22,23,24599:5,12 600:3,6,8,9600:10 601:12 603:10603:13 605:2 610:16611:10,18 612:15,16612:17 617:24 618:1618:22 622:19 623:2624:21,23,24,25 625:1626:21 627:10,17628:14,15,16,17634:14,15,16 637:10637:11,12,13,18638:21 639:20 640:1640:20,21,22 642:3,7642:11 644:14,15,16647:19

secondaries 346:4404:12

seconded 477:11secondly 187:17 267:23336:20

seconds 38:8 40:24 53:365:12 69:18,21,2570:2,20 84:16 92:4,595:7 97:24 99:22101:18 103:14 106:13117:24 125:9 132:5138:9 143:23 157:18168:4 176:4 210:24211:22 227:1 230:24240:17 253:13 254:13

263:11 272:21 273:10291:17 292:6 304:17321:4,16 339:4 352:16361:12 362:1 370:21371:11 378:20 379:9398:15 399:17 400:6411:17 421:1,14424:11 428:8 430:18439:12 449:21 450:9453:6 457:22 464:10475:16 476:4 479:22493:15 501:9 503:24504:11 511:11 520:8526:5,18 536:23545:12 546:1 555:16556:5 566:6,20 572:21573:9 583:14 584:1589:13 593:7 596:10599:18 611:25 624:12628:1 633:19 636:23640:7 643:17 659:11

Secretary 2:4,10 20:7,11208:16 273:21 384:2491:15

section 15:13,22 17:2417:25 18:1,4 36:2445:19 56:4 57:2359:15,16 61:1 66:1382:19 88:7 94:13105:6,14 115:22124:18 173:11,12174:3 213:8 227:17228:10,23 229:12232:11 237:14 242:13242:14,21 250:3258:18,19,22 264:18266:8,14 295:21 297:2297:23 302:12 304:25309:19,20 315:1,2318:12 323:18 327:4334:8 340:10 343:5345:16,24 346:25434:22 436:23,25440:10,10,14 442:2445:1,16,21 451:12452:3 456:12,13459:15,16 460:7,12,13480:19 481:1 486:24486:25 498:11 516:16517:1 521:4,19 522:13532:12,14,15 537:6538:24,25 539:1543:22 546:7 547:13547:14 548:9 558:18573:20 574:12,17594:7 601:21,22 602:5602:8 605:5,22 606:2606:18,20,21 607:23609:22 618:12 619:13619:15,16 622:11623:18 629:19 637:8642:22,23,25 648:14649:13,15,17 652:15

section's 444:13,13sectional 648:19sections 15:17 17:2324:10 102:17 114:24183:5 258:16 268:10

276:6 512:6 558:18559:5 577:10 618:14648:19

sector.' 213:12secure 188:5security 28:25 153:9185:1 232:4 236:19336:9

see 14:9 37:15,16,2340:14 60:6 67:21,2371:15 78:24,24 80:683:17,25 101:5 130:17152:12 161:7 163:7185:10 199:10 205:23220:20 221:14 224:14248:12 257:6,12 258:3258:8 269:10 305:10306:13 307:20,24312:25 324:20 329:23333:20 336:6,21338:13 347:3,8 349:15350:7 357:15 360:11363:1,14 364:9 368:17368:19 372:9 382:4391:22 393:10 400:13406:14,16 408:5,21,25410:12 425:10 452:1460:6 461:4 466:9,10483:16 492:8 494:17495:25 506:25 526:25533:9,9 539:15 554:11556:11 562:4 581:7582:14 588:25 605:3613:4,5 623:15 630:3630:5 648:18 658:25

seeing 37:21 40:1252:17 59:2 69:5 70:784:3,23 99:8 101:8106:24 118:6 124:18124:23 131:21 132:10138:1 143:14 144:4157:9,24 168:10 176:9225:20 239:16 292:14367:18 394:19 430:6479:10 503:14 510:17573:15,16 639:19659:21

seek 127:13 456:22458:17 627:6

seeking 184:9 189:23201:15 440:7,23459:13 467:19

seeks 306:23 386:21557:9 575:15 576:9653:17

Seeliger 11:17 651:25652:3,7,7,11

seen 111:10 187:16188:8 256:16,17 257:4357:6 359:2 390:6394:9 483:10 489:20505:6 571:24

sees 466:8SEIA 617:8selected 437:10selection 129:20 147:1self-certification 568:15sell 522:19 552:13

SELV 650:25semantic 611:6semi-complex 467:24send 94:13,14 285:11587:4

sending 443:23senior 177:25 397:13sense 164:18,23 192:5232:4 236:19 312:15336:9 346:15 485:15

senses 260:24sensible 296:2sensing 396:10sent 154:19 273:24276:12 335:14 441:22512:15

sentence 233:5 311:11311:21 312:12 326:7326:14,23 341:10,13347:11 444:14 499:5536:4,5 610:16,25617:15 618:11 622:20623:2,7 646:1

sentences 608:2sentiments 423:5separate 83:8 189:18197:18 248:11,14392:19 448:1 459:16569:15 597:3 601:3614:7 615:25

separating 466:13separation 205:4 216:10250:4 349:7 438:19

separations 185:21separators 112:3sequence 172:21series 248:9serious 56:21 276:9281:17 385:17 397:12398:6 469:2 472:18515:12 550:2 622:8

Seriously 582:18Serra 311:5 328:4 344:7351:4 403:2 413:10,18418:25 427:14 456:1468:16 481:10,24489:7 492:20 499:10514:16 524:8 637:7,16

serve 20:3 23:23 24:1227:1 202:3 235:18308:5 359:19 365:24375:12 387:6,12 388:2388:5 389:9

served 21:25 25:2 27:1529:4,22 31:9 32:9 33:134:19 123:7 159:21255:11 437:8

serves 24:25 25:5,2326:9,16 27:5 28:2,2129:15 30:15 31:4 32:532:19 33:11,23 34:734:13,17 131:4 384:1

service 25:11,12,14,1626:2,4,20,22 27:2128:14,17 29:9 30:4,930:23 31:21,23 32:133:22 54:12,14,16,1860:15 128:25 147:20

148:5 150:8 151:13,23152:5,13 153:22 154:7156:5,16 160:19163:15,23 165:19179:7,9 196:7 202:1,6259:8 268:1 289:17316:14 322:22 323:14324:21 333:14 335:14337:11 357:25 441:1,6447:19 466:25 505:2532:3 568:19 601:3,4601:10 602:1 603:17607:14,16,24 609:13609:14,17,24,25610:10,23 611:3,6613:3,8,12,20,23614:5,12,15,19,22615:21,22 616:3,4,6,8616:15,21,24 618:8621:2 622:2,3 623:2,3623:4,5,10,16,17,21645:2,9 646:13,17653:11

serviceable 495:12497:1,19 500:12502:25

services 25:22 31:11,1280:10,10 149:22 150:4164:13 185:18 316:12404:6 408:14 495:25601:23 651:20

servicing 312:2,4,7,9,21318:9,14

serving 23:25 24:24 29:329:5,21 34:2 296:23300:4 354:17,19551:12

session 14:3,7 15:8 17:217:20 37:9 41:15,2142:1,3 43:9 118:11119:18 120:4 132:25144:17 158:12 168:13169:10 176:21 230:14293:3 339:17 413:1550:5

sessions 214:18 215:8412:1

set 19:23 49:13 184:19206:7,8 223:25 278:5286:5 315:14 417:21467:4,4 470:17 471:10471:15 487:12 489:19516:6 571:7,13 576:3605:25 616:3

sets 315:6 467:5,5setting 49:14 431:20489:19

settle 610:9seven 65:3 309:24 506:1severe 135:11sewer 446:2 448:4shack 510:22 527:18shack' 510:2shaft 630:10 632:14shaking 505:22shall' 83:7Shapiro 4:16 142:19,19369:16,16 504:17,17



Page 47

504:25,25 508:12,12518:22,22

share 19:16 20:21256:15,19 386:6

shared 200:20 486:16Sharon 184:7,7 187:13sheath 482:3,9 488:15528:22 531:17 533:14534:1

sheet 529:6 533:17shelf 568:12shift 188:12 256:17ships 87:4 89:10,16 91:9shock 366:5 368:16377:5

shocks 360:14 375:17shop 565:3short 78:9 109:17394:10 620:24

shortcomings 140:23shorted 375:1shortening 378:19shortly 19:20 71:16 72:4203:5

shot 314:21shotgun 188:18should' 83:6show 19:3,6,8 34:21128:1 149:5 221:1286:8 363:7 523:11

showed 377:6 499:17shown 113:17 121:7126:8,25 136:23148:21 243:1 257:16266:18 270:17 275:6325:23 353:24 354:7363:23 365:15 414:14608:14

shows 24:15 126:10,12126:13,15,16 190:14229:19 380:17 604:23617:11

shut 358:1 579:25580:15

shutting 329:21 372:12side 62:15,16 179:7216:22 287:4 307:13396:12 402:19 415:24540:14 541:5 582:25607:17 609:6 610:7,19

sides 356:2 365:3381:22 402:17 585:21591:6 594:23

sidestep 611:5Siemens 172:9 174:20541:23

sign 12:24 14:17 44:1945:19,23 46:2,14,1946:20,23,24 47:12,1347:14,15,17,20,22,2548:1,2,13,15 49:8,2150:4,16,20 51:21474:21

Sign' 336:4signal 13:1 35:19 69:20259:7 466:21 587:4646:24 650:24

signaling 29:16,19 32:12

32:13 33:12,14,16,18signals 646:8 655:14signed 14:21 145:15significant 21:9 22:8150:15 173:4 201:10213:22 232:8 242:1,3242:9 244:14,21246:11,23 250:8252:12 275:17,24284:21 309:6,7 310:1310:5,18 327:21344:10 346:5 383:2385:25 387:20 388:2417:4 466:22 486:19559:2 568:8 580:3,11

significantly 64:14 190:9310:11 344:25 469:24557:14 558:8 575:20576:25 605:18

signs 17:20,21 35:17silent 319:6silos 112:3silver 188:24 256:20similar 68:3 96:11123:22 163:7 179:18183:7 198:25 214:15286:6 312:7 322:18354:1,18 389:22,22405:5 407:18 413:20471:7 491:2,6 502:2516:3 568:12 637:18

similarly 123:16Simmons 10:10 471:24471:25 472:4,8,12,14472:16 543:8,9

simple 69:11 82:12 93:1121:18 139:6 236:17288:11 351:23,25375:18 381:14,20387:11,13 388:12519:13 620:25 641:2

simplest 507:5 509:4simplicity 111:7simplify 69:8,22 70:3603:13

simplifying 434:21simply 23:4 59:25 83:590:10 98:21 189:24359:10 380:13 385:2385:11 422:17 432:15457:3 486:13 488:20499:19 542:3 560:17603:19 611:2 641:6653:16

single 21:10 86:25 89:20188:13 241:24 248:11250:21,22 307:15310:10 341:13 342:4355:23 374:24 380:9391:4,5 401:20,22404:15 491:5 617:16623:19

sink 354:1 355:18Sir 44:21,24 45:15 48:1749:18 51:5,12 52:1653:16 57:14 61:2463:3 64:8 66:20 67:670:10 80:8 84:6 88:11

88:13 91:20 94:19,2399:1,13 103:6 104:12105:8 106:4 113:5117:6 121:4 137:25143:13 147:21 158:16166:14,21 174:25263:2 332:16 351:20410:8 416:1 511:17520:14 556:13 567:10567:10 644:7,9

sit 76:4 154:15 185:7204:1 256:7,8 317:15393:24,25 649:23,25

site 175:19 259:9 507:1508:21 513:6 540:17569:1 618:20,22

sites 195:19 214:5 217:7217:7,12,12,13,21,24218:2 245:9,13,14

sitting 20:10,14 203:8,9256:10 459:12

situation 52:4 56:2158:9,23 64:4 96:19165:10 205:13 222:1222:11 350:21 351:11369:23 432:14 491:24

situations 59:20 184:25350:15 392:20

six 31:23 48:19 49:1756:14 62:2 63:1493:23 104:25 105:1111:20 113:6 115:3,12140:15 142:17,17151:11 155:8,10 160:4175:9 185:23 193:1237:24 245:19 268:21280:24 299:20 333:13339:13 341:16 354:1369:15 387:1 392:2400:13 411:6 419:17423:18 436:14,18470:1 471:22 497:22498:20 509:14 516:9518:20 533:21 543:6550:6 553:7 568:8,23613:21 615:25 626:15653:24 654:5 655:3

six-inch 447:13size 81:15 89:5 200:25216:10 241:19 242:15242:20 243:12,23247:10,14,22 250:4282:7 288:16,23386:15 447:12 469:10469:12 472:20,25610:17,22 611:1,1,1,3

sized 88:17 289:25611:2,8

sizes 129:18 244:12,20249:2 410:3 494:10

sketchy 127:24 128:8skin 541:9Skip 8:7 346:23,23skipped 357:9skirt 275:13sleeve 494:16 497:1,10497:19 499:2 500:9,11502:4

slightly 222:24 360:15small 87:15 88:15,17,2289:1,14,19 90:4 91:996:15 100:25 104:15192:2 246:9 262:12279:11,14,22 389:25390:1 403:7 410:3445:25 468:25 518:1518:24 580:13

smaller 91:8 167:4 246:6251:11,22 354:19468:23

smallest 68:8 201:1Smart 172:9 174:20SME 187:10 221:24Smith 10:24 530:6,8,9530:16,19,21

smoke 87:2,2 88:2,6,8,988:9,23 89:4,8,11 90:391:2,13,16 96:17,2497:8 100:21 104:10,16105:15,25 123:11445:25 448:6 486:7487:1 488:18 513:13

smoked 96:7smoking 394:10smurf 489:12 491:21,23snacks 118:12 168:15sneezes 534:16 535:9Society 64:11 294:15295:3 546:16 551:25

socket 387:16soft- 486:9soft-jacketed 488:3software 571:10Sokol 541:1,2,9solar 285:8 600:19604:14 618:6

sold 90:24,25 91:5393:12

sole 16:9 36:14 234:2547:20

solely 129:19 234:2327:6

solid 172:24 276:14solidly 403:10Solids 108:1solution 513:8 579:3solutions 53:13 170:9245:21 351:23 392:25406:16 463:3 650:3

solve 187:11 344:9,10420:5

somebody 81:12 104:24142:21 195:24 239:25260:22 331:4 333:7,11376:7 394:11 408:6412:22 413:1 419:9505:2 506:15,16,20,25506:25 510:1

somebody's 395:21,23538:15

somewhat 155:23son 185:11soon 37:16 154:9 156:18602:20 603:4

sooner 258:3 289:9soot 148:14

sorry 44:24 51:24 79:22105:3,10 106:23 114:9125:12 126:14 137:12138:17 141:22 146:8161:22 174:23 193:8197:10 206:12 212:13213:9 236:6,8 238:22239:2 240:1 246:3262:2 299:19 313:10323:1 330:12 387:10400:24 448:15 450:22457:6 462:20 467:7468:12 477:2,4,6496:5 507:7 520:19530:17 534:23 535:4537:12 574:22 576:4588:16 593:20 603:21620:1 621:23 627:25634:5 658:12

sort 19:23 285:25 506:19sorts 222:13 223:2sought 442:19 540:23sound 13:2 18:12 35:20505:19 514:9 518:2519:15

sounding 164:17sounds 187:15 505:11source 49:9 131:18208:18 301:5 354:1386:19 529:14 551:17553:25 554:12 557:11563:4 564:25 569:18575:17 608:16 618:4,5618:6,23 620:16

sourced 652:12sources 87:23 163:12295:23 441:4 446:2531:23 600:17,19603:1 618:21,24,25619:4,6

South 144:11 169:5388:19

Southern 177:20 203:5203:17 205:8 228:16247:6

Southwest 444:6space 34:8 82:11 89:2191:4 200:13 260:10261:2,7 274:18 343:7343:17 344:11,20346:1 368:1,1,4552:10,15 630:20

space.' 341:12spaces 112:7 279:21368:9 629:24

Spanish 509:5spanning 23:5spare 447:17speak 18:9 111:22140:17 147:17 155:13173:13 189:13 197:9197:11 203:2 209:20226:10 246:3 253:2267:16 283:24 290:20291:1 296:24 299:5300:1 302:11 315:3320:16 326:21 336:15340:18 343:4 350:13



Page 48

350:14 355:11 358:22360:17 361:2 364:25365:12 370:10 373:10375:20 378:9 380:8381:12 387:5 399:7402:12 404:17 406:8407:14 408:18 415:9416:5 420:15 442:17449:12 451:24 455:6463:3 475:6 478:5483:15 495:6 509:17518:24 519:9 525:18525:21 540:5 545:3549:18 555:7 559:19562:12 564:13 565:13565:22 570:3 572:12578:1 583:4,5 585:22592:7 594:23 595:7597:23 602:23 608:11617:19 620:4 625:21635:9 639:15 648:10654:10,25 656:5

speaker 18:8 19:2238:12,14,18,25 39:839:10,14,18,21,24,2540:1,2 44:12 45:8,962:23,24,25 63:4,1166:2,5,6,7 67:2 70:2370:24 71:1,2,3,4,5,6,771:11,13,18,19,20,2172:23 73:1,4,8,10,1273:13,22,24 74:2,5,6,874:10,12,20,25 75:1,375:5,7,8,9,11,14,1776:15,17,21 77:3,9,1177:12,13,14,16,17,2077:24 78:10,14,16,1779:8,10,16,18,21 80:380:14,17,18 81:583:16 86:14 92:2095:22 98:14,15 100:12102:8 104:4,23,25108:20 117:10 119:16121:12 125:7,25 134:3138:24 145:13 147:23159:14 166:17 170:15178:5,6 193:6,11197:16 198:3,6,13,15209:15 210:4,5,6,7,11210:12,14,16,17,22,25211:3,9 212:18 229:16229:20,21 230:13,18230:21 231:10 240:6,7241:7 249:4 254:2,4255:3 257:24 265:3272:8,9 274:4 290:15290:22,24 291:5,6,7,9291:10 294:21 306:5315:16 318:10 320:6,7320:8,10,17 322:6,9322:10,11 323:7,9331:17,18,20,22,24332:2,3,5,9,12,13,15332:17,19,20 333:24339:20 340:3,22353:12 360:23 362:19362:20 370:7,13371:25 378:11 379:11

380:2 404:10 413:15420:10,12 422:4423:20 424:25 428:24428:25 431:8,9 434:19449:15 451:3,4 454:9458:11 464:22,24465:16 474:23 476:10477:13,15,18,21,25478:10 481:15 494:4,5496:6 501:22,23 503:9503:11 504:22 510:12513:17 522:6 528:6,7528:8 537:13,22544:24 546:25 556:25565:24 567:19 574:5575:9 580:22 581:1,9581:18,19,20,22,25582:8,9,10,12,15,18582:21 589:25 590:9590:11 593:25 596:23600:9 612:16 624:25628:15 634:15 637:12640:21 644:15 653:25654:7 657:6,8,9,10,12657:19 658:6,13,21,22659:9,15 660:8,10

speaker's 392:7speakers 2:5 62:20,2270:21,22,25 118:24193:19 209:22 238:15253:5 254:5,8,11272:13 281:3 320:21332:1 361:4 378:1395:19,25 396:3,8398:24,25 399:1,2,9399:10 401:3,13 407:9412:2 420:18,19 440:2469:24 475:9 476:21477:22 503:17 510:11511:25 525:24 545:5555:9 572:14 581:21582:11 583:7 584:13657:11,13,17,22658:19

speaking 17:11,14 18:1047:3,8,9 49:20 56:1356:16 57:18 59:1463:16 69:1,4 83:14,2186:18 90:15,18 92:2493:22,25 94:8 96:197:3,6 98:9,19 99:7100:7,16 101:4 102:3102:12 104:20 105:6105:10 108:13 111:18113:8,23 115:5,18124:5 125:19 130:2136:17 138:18 140:14142:20 151:10,14152:18 155:12 156:8156:23 162:16,19164:12 166:19 172:5,8172:11 173:10 177:23180:22,23 184:8 186:1191:6 193:4 195:14,14197:23 198:14 199:24200:4,7 201:25 202:18206:2 208:5,11 216:25218:8,18 220:3,7

221:25 223:9,9 231:13234:24 235:2 236:9237:8,10 238:1 239:3241:12 244:6 245:21246:7 247:6 249:12,14251:7 252:2,2 259:25260:3,4 261:21,23265:8 268:20,23 270:4270:25,25 272:6,9274:12 278:10,15281:1 283:16 285:18289:15 295:4 300:2301:15 308:24 311:5313:10 314:25 317:6318:24 327:25 328:4329:17 330:17 334:4335:8 341:5 344:3,7346:24 348:1 351:4353:20,22 356:11,21358:20,21 362:24365:21,25 367:1368:13 369:16 370:5372:4 374:4,7,9375:13,25 376:19377:23 382:3,10383:18 388:20 390:21391:1,2 396:16 402:23403:2 407:8 409:12413:18 416:16 418:6418:25 419:20 420:9423:9 426:16 427:14430:5 433:10 435:4,10435:25 436:22,24437:12 444:4 446:20446:22 452:9,12455:23 456:1 457:2,4457:6 460:1 461:10,19462:18,20 463:9,11467:17 468:7 470:11470:12 471:25 472:2472:14 474:19 478:18478:22 481:24 484:4484:19,22 485:5,7,9485:12 486:2 488:11489:7 491:11,13,16492:6 497:11,15498:24 500:1,4,5503:5 508:9 513:20514:16 516:12,23517:6 518:22 524:5528:12 532:7,11,13,22533:23 534:3,25 535:5535:22,25 536:2539:22 541:24 542:6542:17 543:9,10 544:1544:2,22 547:7 551:2551:6,7,23 553:10554:5 556:17 560:25562:10 563:13 564:11565:17 567:24 570:25571:5 579:14,18 586:1586:5,8 588:12,17591:10 595:3 598:21604:10,15,19 606:17606:19 608:25 609:2617:4,8 619:12,14620:22 621:21,21622:21,23 626:4,18

628:10 629:16 631:14631:25 632:4,5 634:2634:19 635:16,20636:1 638:19 639:12640:25 641:18 642:17642:21,23 647:18648:6 649:12,14 650:5652:8,23 653:1 655:6

spec 419:19,20special 18:4 21:7,8 23:723:9,11 25:7,9 31:13186:22 207:9 387:5,22388:5,11

specific 115:10 149:7150:10 153:7 161:14165:12,17 166:2171:24 181:3 192:23210:20 219:1 236:3,13236:21 280:2,5 286:7287:7,9 341:10 405:24455:13 507:21 509:21548:9 550:7,9 579:24618:23

specifically 63:21128:19 181:4,23218:21,24 219:21238:11 257:3,19258:18 262:10,14284:16 287:11 295:22298:22 300:19 311:19333:1,1 357:21 455:11498:13 507:20 564:15564:24 601:7

specifications 568:12specificity 68:1specified 197:18specify 558:19 577:10speed 269:18 651:19spell 232:2spend 22:18 554:16621:13

spending 550:3spent 308:6 394:16550:6,8 570:9 578:5579:8 603:8 605:20

spillage 235:14 238:16spirit 243:7 266:7,25spoke 315:16 338:4367:2 408:24 551:8620:7

spoken 117:14sportsmen 88:16 96:14sprawling 128:16spray 58:3,6spread 91:1 102:15,16105:17,24 446:7,10486:8 487:1

sprinkler 27:1,4,16,1731:17 32:6,6 44:1645:23 48:23 57:2268:9 81:18 586:18,22586:24

sprinklers 31:18 32:845:17 54:13,18 57:25285:8

squirrel 188:22SR 374:11 514:2 556:19578:13,16,18,21,24

St 32:4 530:9,11stability 247:17staff 2:9 12:24,25 13:835:17,18 36:1 41:1774:17,23 76:12 78:1278:21 159:22 641:4

stage 20:6,10 21:1423:14 26:6,23 27:2428:18 29:12 31:1266:11 297:7,12309:15 331:6 342:15342:16 348:23 365:6381:16,18,20 455:7496:11,17 531:8

stages 381:14 471:14stainless 431:24stakeholders 180:1280:19 393:9 414:20

stance 247:12stand 75:24 76:11 77:178:23 172:18 347:20355:25 374:17 375:7385:22 426:6 451:9455:19 459:11 468:2474:5 478:22 484:15497:20 502:18 505:16507:17 513:2 523:18539:7 581:4 585:18591:1 594:22 600:15607:5,8 658:7

standalone 639:6standard 22:6 43:2546:16 55:16 68:1282:20 85:22 87:2588:9 89:9 90:6 100:25102:17 104:15 107:24111:14 113:12,17116:9,11 118:17120:15 133:10,17134:19 139:17,19140:2,21,22 141:3142:3,4,6,8,10,24145:3,16,19,21,25146:1 147:1 149:19155:3 156:3,10 159:4160:12 166:9 168:19169:21 170:3 171:2172:25 177:6 178:21178:23 182:15,23184:10,17 191:8,9,12191:17,21,25 192:10192:18 194:15,20197:14 206:16,17209:2,9 214:21 215:2215:13,15 219:5220:10,15,24 221:2222:23 225:4,10,11,23231:22,23,24 232:1,3232:5,7 233:12,18235:25 236:18,21,23236:25,25 237:4,21238:7,11,11,14,16,19245:12 247:7,15248:12,13 256:22260:6,21 266:4 267:8267:9,10 268:11 269:1274:2,23 276:12,15,21277:1,17 278:21 279:2



Page 49

280:10,16 281:4 282:9282:12 283:5,12284:20,22 285:15288:5,6,23 289:20290:8 292:1 324:1,3329:11 333:11 335:19336:1,8 338:1 385:12390:11 433:20 469:10469:10 487:2,18525:13 533:3 534:1,7534:8,10,12 535:9541:18,18 561:17569:14 641:4,7

standard-making 267:4standardize 139:18149:11

standards 2:4,10 13:1613:17,20,23 14:415:11,16,20 16:8,1016:11,11 18:5 20:3,820:11,17,22,25 21:521:11 24:16 25:1726:2,20 27:21 28:1429:9 30:9,23 31:2136:13,15,16,18 37:3,637:8,10 44:6,17 45:1783:3 86:3 89:8 96:21108:7 111:10 113:16113:17 118:18,20120:21 135:16 137:7141:12,25 142:1,2145:8,22 147:9 150:1163:6 168:21,23172:18 177:13 184:20192:21 213:7,20,23215:12,17 232:12233:16 234:16 238:4242:23 245:24 248:25265:13 266:9 267:19267:20 268:3,5,13275:2 276:20 277:18277:19 278:6,19280:12,21 282:13284:5 288:12 294:6306:13,14 309:12,18311:19 316:7,9 318:23319:5 329:7 330:16347:2 374:10 410:24414:1 417:22 418:8431:13,18 433:24,25436:3 437:11 453:14459:20 461:6,11468:10 484:23 486:9498:8 503:8 515:15517:22 525:1,3,8542:10 543:4 550:13560:15 562:24 569:12569:17,18 570:8,21575:25 576:15 629:11639:5

standards' 139:8standby 213:11 214:1,10219:14 222:3,17 225:6225:7,16 259:5 280:4

standing 73:5 75:2076:2 190:7 289:17290:25 334:2 346:8348:3 350:3 368:23

382:5 389:4 426:7472:4 538:16 544:14551:4 621:18 654:2

standpoint 609:15646:19

stands 290:8Stanley 3:14 11:20 47:647:7 83:19,20 530:11653:24 654:4 655:4,4

start 13:24 47:2 186:23202:20 238:4,5,5241:9 255:16 274:8281:12,19 287:15311:15 323:12 341:1402:24 472:6 586:23587:1

started 196:4 197:21223:20 358:14 386:6391:7 461:4 508:23523:12 550:2 571:25572:1 618:1

starter 429:9starters 584:21starting 19:20 219:17230:24 255:6 265:6345:25 535:8

starts 260:6 407:19587:5

starved 257:22Stashak 2:15 23:12state 24:19 82:3 154:14154:17 183:8 206:5208:22 324:11,12342:1 364:5,9 374:10383:6,21 392:7,12393:9 412:23 414:6432:9 437:20 468:10474:25 484:24 485:21535:2 542:10 552:21552:21 568:21,22,23569:22 626:24 636:6641:10 661:12

state's 393:14stated 47:17 55:13 89:7113:10 151:19 160:20220:11 266:9 288:20297:23 300:20 326:22381:22 390:2 393:5416:7 442:2 448:2,10448:13 461:5 462:6,9465:5 470:18,25 499:1564:3 604:25 629:11632:12 645:14

statement 135:25172:12 220:17 231:20232:15,21,25 233:1237:3,20 238:24 239:4239:5 251:14 267:21270:2 290:1 295:25297:9 309:9 318:11323:22 324:4 325:4,4336:16 337:23 347:10351:5 443:2,17 455:8456:5 459:13 463:12477:24 490:19 499:11512:4 544:7 547:13554:10,10,13,21608:24 635:13 638:5

638:25 652:5statements 14:22,22127:24 160:23 220:21221:15 251:8 437:19502:23 549:21 551:11578:2

states 21:20 63:19 90:2116:7 134:25 135:3136:11,13 139:10140:4,7 179:1 194:12202:3,4 206:20 214:6217:8 242:23 245:2266:14 279:8 280:2286:19 305:15 311:22316:5 364:3 386:9387:7 392:13,17,17,22393:1,16 436:4 437:14440:19 441:7 459:17482:4 487:15,17552:13,17 553:6568:20 604:24 651:21

static 89:25stating 156:1 461:12485:14 496:15 608:13630:1

station 259:7,8stationary 177:7 192:15212:10 213:4,5,10,16213:21 215:13 217:4244:10 245:4,9 259:18261:16,19 273:20276:21 279:18 280:9281:24 282:4 302:24304:1 564:7 570:17586:7

stations 177:22 200:17201:2 203:19 587:1

statistic 89:25statistics 220:14 380:16386:23

status 16:21 18:4 523:23644:25

statute 178:22stay 76:1 87:7 173:4175:6 201:19

stayed 655:12steadfast 23:3stealth 516:17steel 32:18 115:8 116:1130:7 431:24 473:15482:25 483:2 486:1487:25 490:8

stellar 21:4stenographer 17:20step 262:20stepping 43:12 293:7sterling 561:12Steve 9:14 420:8,8sticking 184:18stiff 528:22stilts 363:15stipulated 432:24stock 376:14Stone 7:20 316:23,23356:14,14 423:11,11495:19,19 556:18575:3 587:15,15

stood 581:3

stop 331:22,24 336:22367:25 395:5 400:12400:15 436:16 567:12

stopped 556:12stopping 348:10 446:5stops 160:15stops' 68:4storage 26:17 27:8,1227:14 32:22 48:4,449:24 50:3 161:11176:14 177:2,7 178:19179:12 189:17,21,24191:22 192:1,22194:22,24 196:18197:17 198:20 201:4207:15,23 212:9,21213:3 215:3,14,20216:7 217:4,7 219:17222:2 224:24 232:7233:13,24 234:1,4,8236:2 241:19 244:9245:21 247:8 249:5250:25 252:7 259:15261:16 265:11 268:14273:20 274:18 276:22279:8,13 281:24 284:7284:15,22 285:24289:6,25 600:19 618:7

stored 49:25 161:10243:18

stores 279:20stories 396:12 481:18482:6

story 430:2 482:2,11stove 359:4STP 534:2,5straight 510:12 526:10straightened 410:5straightforward 81:8538:1

stranded 187:15strange 187:15Straniero 10:13 488:10488:10 527:25,25528:11,11 532:21,21534:10,18,20,23,25535:4,5,7 632:3,3633:3 635:19,19

strategies 187:14Street 12:19 35:13stretch 331:10stricken 296:8strictly 222:16strike 401:25 516:15605:5 617:15

strikes 516:17 585:4striking 617:16string 248:10,14 250:9stringent 486:7 568:11strings 245:10 248:6stripped 129:13strive 579:7strobe 12:23 13:2 35:1635:20

strong 21:18 245:15297:16 384:5

strongly 131:8 179:21215:20 278:4 343:24

553:2 559:6 572:2struck 473:3 494:17539:9

Structural 146:6,20147:3

structure 179:18 436:10440:9 614:5

structures 27:7 33:3190:23 216:10

studied 506:4studies 136:2 148:21155:24 284:19

study 443:20,22,25445:11 448:11

stuff 332:2 506:6stuffed 360:6style 22:22 109:3,3112:20 311:22 326:9443:12 444:21,25538:24

sub- 96:21 97:13 136:4Subcommittee 177:21subject 172:1 302:13496:12 598:8 645:9

subjected 243:21 250:1submission 15:2 179:25266:12 414:3 530:23

submit 156:18 310:7311:7 448:13 540:22

submittals 322:19submitted 44:2 85:24108:2 115:21 120:16133:12 145:4 147:4156:11 158:24 160:7169:23 177:8 179:13231:18 275:15 276:22294:1 309:19 317:13317:17 383:20 404:20417:6,12 469:16470:15 471:14 499:16514:23 540:22 641:8

submitter 42:10,1665:22 89:3 90:9 93:1699:2 102:23 140:19183:23 216:1 226:11262:8 442:24 476:8495:12 540:25 621:24642:5

submitter's 89:7 171:19507:25 541:3 618:11

submitters 241:16 243:8243:13 268:12 427:20443:15 499:11,13540:22

Subsection 516:14subsections 179:19subsequent 14:15 548:9subsequently 45:21445:5

substance 111:7 311:17substances 166:1substandard 460:25461:4 462:7

substantial 21:1 25:14276:13

substantially 288:18,24386:12 442:1 446:7,10618:21



Page 50

substantiation 135:23160:20 183:23 354:7355:21 356:1 359:1,13360:3,9 363:2,7 365:7367:5 368:18,18369:10 372:24 373:16375:14,16 403:13419:12 434:8 448:9487:23 488:2,24489:18 507:24,25508:14

substantive 68:6substation 190:3 285:1285:2 469:19

substations 182:25222:6 284:23

suburban 202:6subways 87:11success 19:15 621:5successes 621:3successful 18:19 48:2449:1 219:3 248:22

successfully 489:21654:24

SUD 176:15sudden 394:21Sue 177:22sufficient 111:5 167:3316:10 402:17 487:16514:24 515:7 548:15

suffix 534:14suggest 246:20 388:10434:8 452:17 536:7610:12

suggested 19:17 153:16414:16

suggesting 61:3 655:16suggestion 606:7610:11 614:1

suggestions 141:14suggests 323:24suitability 614:14suitable 112:11 329:8403:21 409:21 462:12525:8,12 529:22614:15

suited 484:10summarize 551:11summarizes 380:19summary 128:3 265:10558:25

summed 218:9summer 372:22sump 368:8super-heated 346:19superheated 350:3superior 188:15supervision 182:20406:25 532:2

supplemental 561:4supplied 301:9 543:18supplier 540:1,8suppliers 248:1,20supplies 28:8 216:5403:9 548:15 554:14609:25

supply 27:18 56:20 57:357:20,21 58:5,10 59:9

63:24 64:1,2,3 177:22216:12 287:8,12 295:8297:11 298:12 301:5303:14 539:10,11,25541:13 543:13 548:14549:24 550:16 551:17554:8,22 557:12559:24 560:14 570:8575:17 578:3,17607:17 609:6 610:1,7610:19

support 17:11 19:1238:2,20 40:17 41:247:3 52:23 53:5 54:2456:13 59:17 65:8,1569:1 70:16 76:10 78:383:14 84:11,18 90:1591:15,25 92:7,2493:12,22 94:8 95:3,996:1,7 97:6,19 98:2,1999:7,18,24 100:16101:4,13,20 102:12,17103:1,10,16 104:8,20105:9,22 106:1,9,15108:24 109:14 110:23111:19 112:21 113:23114:13 116:20 117:20118:1 121:17 124:5,8125:3 126:6 130:2,5132:1,7 134:7 136:17136:20 138:5,11 139:4140:15 141:15,19143:19 151:10 152:19152:25 153:5,8 154:15157:13,20 162:16164:5,10,15 165:8166:21,23 167:24171:6 172:5 173:14174:3,7 175:15,24179:13 184:8,9 185:21189:3 194:9 195:4197:4 199:24 200:7201:15 202:14,18210:1 211:7,17,24217:5 218:15 226:21227:3 234:24 240:13244:6,10 253:9,15,22254:15 258:9 259:25263:6 267:11 268:20272:17,23 273:5,12278:11,15 280:16287:20 291:14,20292:2,9 304:12,19308:25 311:5 313:4315:11 320:25 321:6321:11,18 328:1,4,24329:5 335:4,5 338:24339:6 340:18 341:5344:4,7 345:6 347:1347:13,13 349:8 351:4352:12,18 354:21355:25 356:12,21358:2 361:8,14,22362:3,24 364:14 365:1365:21 367:1,7,9,18370:17,23 371:7,13372:4,23 374:5 375:25376:15 378:15,23

379:5,12 380:8,24381:11,24 382:4385:22 386:23 390:15392:1 393:5,8 399:14399:19 400:1,8 402:24403:2,23 404:23 405:6407:2,4,16 410:4,6,17411:13,19 413:18414:23 415:3 416:16418:25 419:16 420:22421:3,9 422:8,22423:9,13 424:6,13426:16 427:14 428:3428:10 430:5,13,20431:15 435:1,4 437:2439:7,14 441:18443:25 444:4,7,16446:15 448:22 449:5449:18,23 450:5,11452:9 453:1,8 454:15455:9,23 456:1,13457:18 460:2,5,15,21461:7 463:4 464:6468:7 469:18 473:11474:16 475:12,24479:18 481:24 483:9483:19 484:20 485:22488:3 489:7 492:2,20493:11 495:6 499:10500:8 501:4 502:19503:5,20 504:7 508:10511:6 513:21 514:16516:8 519:16,17 520:3524:5,8,21 526:2,14532:8,16,17 536:19539:17,22 541:25542:10 544:16 545:9545:22 551:3 555:12556:1 557:8 561:1563:9 566:3,15 571:1572:18 573:4 575:14579:15 583:11,22585:19 586:2 587:23588:11 589:8 591:2,11592:3,5,6,12 593:2595:4,12,17 596:5598:5 599:1,14 602:9604:6,11 606:12,22,23607:8 608:4 611:20617:5 619:17,18622:13 624:8 625:25626:5,10 627:4,18,21631:22 632:1,22633:14 634:2,20635:17,20 636:18637:16 639:13 640:2641:1 642:18,25643:12 644:19 648:7649:7,17 650:3,7,11651:18,22 652:8653:18 657:2 660:14

supported 57:12 155:21297:7 307:7 327:20354:4 357:21 491:5

supporter 142:12supporters 17:21supporting 111:23 113:3156:22 166:10 367:7

441:23 469:19 502:21607:10 653:19

supports 156:17 202:14298:19 301:6 316:2,15335:22 343:24 382:15386:3 418:19 423:4455:12 474:12

supposed 154:19389:23 474:25 564:19

supposedly 448:9suppression 257:20586:16 587:9

sure 38:16 39:3,6,1940:6 56:9 59:8 73:18113:25 127:2,16128:13 165:21 174:14186:11 188:11 201:20216:14 221:21 237:20252:17 285:2 307:19319:5 382:5 393:16409:14 412:25 451:13467:22 469:13 494:11502:7 510:7 519:15536:5 562:16 587:2610:21 611:7 615:3616:17

surface 90:6 366:3surfaces 100:20surveyors 88:19Susan 3:1 28:17,17,2029:8

susceptible 438:13suspect 55:3suspected 148:15Suzanne 2:11 20:15Sweden 122:25sweeping 499:3 625:4Swiecicki 5:7 162:18,18swims 614:21 621:25switch 69:13 181:9216:3 311:13 314:9331:13 342:3,6 401:16425:12 429:8 505:19512:6,6,8,9,10 513:4517:10,16,23 523:20524:10 588:7 590:8591:4

switchboard 512:6switchboards 328:11512:5,10 513:4 516:18517:23

switchboards' 517:9switches 67:14 69:20469:5 586:10 587:18591:18 592:2 594:5597:2 598:22

switching 343:15switchyard 182:3symbols 29:25 506:8sympathy 492:1system 32:7 46:15 47:2348:24 49:5,23 50:851:22,22 54:5,6,9,1155:18,19,22 56:19,2156:25 57:4,11,19,2258:2,6,10,24 59:3,760:4,12,13 61:2163:24 64:4 68:9 72:3,8

81:12,17,17 82:2183:22 84:1 114:22164:20,22 165:1,16167:9 174:14 186:13192:1 197:17 200:12203:8 214:5 215:21216:11 219:17 241:19249:5 252:7 258:22,24259:2,4,6 260:19267:25 284:7 288:16298:12 302:5 303:14373:15 376:25 377:1377:11 394:7 401:18486:20 547:12 549:24550:16 560:14 564:25570:8 571:9 578:20580:15 586:19,22601:21 609:12 614:7616:5,10,25 618:7

system's 84:1systems 26:17 27:4,1127:16,17,18 28:1029:7,16,19 31:10,1631:17 32:6,13,1433:12,14,16,18,2543:3,20 44:1 45:2446:21 47:20 50:1157:24 58:3,4,4 59:981:18 87:23 119:23120:10,16 160:8,14,24163:1,3 165:5 166:3167:4,8 170:23 171:13171:16 172:17 175:18176:14 177:2,8 178:18181:5,7 182:16,25186:7 190:12,16191:22 194:22,24196:8,18 201:4 204:9207:23 215:14 216:2,3216:8,17 222:2,3,4232:7 233:13,25 234:5234:8,13 236:2 245:5245:6,7 246:9,14,15246:16,22 247:8250:13 251:1 252:9,13252:17 257:20,21259:15,18 265:11268:14,16 275:1279:13 280:4 284:15284:22 285:3,24 289:6295:7 298:6 303:9311:11 346:4,16349:20 403:11 404:14404:15 410:19,21433:21 434:4,25 441:8486:17 528:1,12 550:1560:16 561:18 564:11584:22 591:19 600:22615:15,17 632:4635:20 642:1 648:10652:14 654:10 656:9

systems' 302:3

TT 140:17 652:14TA 267:11tab 13:11 44:4 86:1108:4 120:19 145:6



Page 51

147:7 159:1 169:25177:11 294:4 324:9

table 24:18 71:22 126:8126:9,12,13,22 127:9128:2,2,3,14,17 129:6129:12 131:7,7,8222:14,25 223:3 279:7349:6,7 462:21 463:4467:20,24 468:13469:10,25 470:5471:20 486:23 519:18541:20 545:8 563:14583:10 626:19 629:20630:2,23 632:17

tables 75:22 76:1 466:8467:5 629:19 630:2,3630:7 632:6,11,12,13

tablet 41:6,16,18,19,2442:1 209:25 253:8272:16 291:13 320:24361:7 370:16 378:14399:13 420:22 449:18475:12 503:20 526:2555:12 566:2 572:17659:25

Tagalog 509:5tagging 81:12,17 82:2083:22,24

tags 81:15,15take 12:9 19:18 20:440:7 48:1,5 58:15,2265:21 72:9 73:3119:17,17 147:24185:9 187:8,8 204:2208:12 229:17 230:14230:19,23 248:9259:16 264:6 271:9282:14 284:4 291:3309:10 315:7 324:17333:17 337:25 339:14339:18 340:20 342:13351:5 364:5 377:11383:11 386:14 411:23414:25 426:8 432:19436:18 491:20 500:12505:15 514:2 517:11526:22 565:3 592:12

taken 14:7 59:4 160:19297:20 316:3 317:24329:5 335:14 363:13391:24 406:24 410:17416:9 438:13 495:7502:19 524:21 570:11580:16 587:23 595:17626:23 642:12

takes 82:22 83:6 262:20284:5 357:22 360:10513:3 605:12

talented 285:12talk 80:14 81:11 113:13182:10 191:14 282:2395:20 408:19 419:14455:2 563:14 607:24615:10,12 629:25630:23 649:4

talked 105:25 193:20237:13,13 282:2 283:8301:18 368:22 397:6

398:16 496:22 561:5612:23

talking 60:5 63:24,2564:1 79:13 105:23109:1 115:6 116:1122:7 124:11 126:9160:17 161:4 163:1,23193:11 219:23 302:25314:11 331:12 334:6334:25 341:14,15349:16,17,19 351:6357:17,18,19 364:10367:4 368:15 406:21407:17 408:1,2 483:25496:13,25 508:14544:9,10 563:1 564:15607:13 608:19 620:15650:18

talks 124:10 485:16,16485:17

tall 220:12 486:15tally 115:1tank 164:22tanks 27:14 160:7 161:9448:7

tantamount 587:8Tarchinski 7:8 299:3,4551:21,22 563:12,12571:3,4 579:17,17

target 578:9tarnishing 653:22task 22:10,24 23:20,2324:3,3,7,8 93:5 102:14135:4 136:25 187:12220:12 234:10 255:14256:6 264:11 277:2310:7 317:18 397:16417:11,11 437:11443:21 448:11 484:6490:22 517:6,7 605:19617:24 653:8

tasks 23:25 317:14387:14

taught 618:10TC 156:9 180:21 232:17466:20 533:2

teach 203:14team 12:25 35:18 164:21203:19

tear-off 324:9Tech 41:15 42:3 43:9120:4 132:24 144:17158:12 169:10 176:21215:14 276:25 293:3

technical 1:5 12:2,813:13,18 14:8,13 15:415:19 16:2,3,14,1517:7,25 19:7,14,1920:1 23:17 24:9,14,2024:25 25:1,3,4 26:1226:16 27:6,9,16 28:2329:4,18,22 30:1,2 31:631:9,12,17 32:2,6,9,2033:2,4,5,14,19,23 34:834:13,17 35:2 36:5,836:17,21,23 37:1,538:13 43:1,9,19,2344:3 55:4 64:24 74:22

78:7 81:9,10 85:3,5,1185:16,20,25 88:1893:18 99:3 107:5,7,13107:18,22 108:3111:25 112:8,22 116:8119:8,21,24 120:4,9120:13,17 132:15,17132:24,24 133:4,8,13144:8,10,17,22 145:1145:4 146:5,14,19,24147:5 155:20 156:22158:11,17,21,25162:21 164:5,13 169:2169:10,16,19,24170:20 171:10 172:10176:13,21 177:1,4,9182:15 183:2,11 191:7195:10 215:19,25230:5 232:13 233:15239:11 242:5,7 243:3243:18 245:16 247:9247:20 258:14 259:12259:17 266:3,19,22267:23 268:11,25270:24 278:4,16 293:3307:18 308:4 317:22354:6 363:7 396:13408:14,18 412:9 414:7415:24 425:23 427:18431:19,19 434:8 448:9457:3 488:2 495:24527:9 529:3 539:2541:19 559:14 569:25588:18 590:23 594:19604:19 609:3 615:7617:21,22 622:8625:17 645:13 652:25660:13,15

technically 354:4 429:11528:16 588:9 609:6644:25

technicians 375:18technologies 20:23186:20 189:14,17,20190:1,19 193:21,24194:1 213:16 214:11214:17 215:3 219:22225:12 229:5 231:25236:4,12,13 238:8250:12 251:1 254:22256:1 262:11,15,21263:22 275:21 276:14286:4 298:8 335:2

technology 153:12183:20 189:18,22190:10,23 194:2 219:1234:1 235:6,9,16257:5 262:22 274:25283:7 286:5,7,8,10,15287:7 303:17 316:6357:18 360:12 369:9377:19 384:11,20389:15 390:3 395:10395:11 397:5 398:4406:19 410:23 525:4550:19 560:8 569:8

techs 62:9Ted 5:5 159:9,9,18,20

166:19,19,23,25teenage 185:11Telcordia 645:6telecom 216:5 218:23246:14

telecommunication645:2

telecommunications214:4 650:2 656:4

teleconferences 277:3telephones 651:11televisions 389:25tell 49:6 93:7 94:15127:12,14 201:17311:16 350:6 351:7388:24 395:16 417:22487:8 505:11 643:24

telling 436:17 498:16tells 90:21 93:6,8 487:10temperature 122:10,11122:12 134:22 395:3,6455:10 466:16,16470:24 474:15

temperatures 346:18ten 505:22tenable 121:25tend 248:1 486:15tends 505:9tens 217:16Tentative 205:21 610:14tenth 482:23tenure 43:13 293:7term 49:8 78:9 102:15111:25 112:8,14113:19 114:2 121:21121:22 122:13 123:23124:14 139:8 174:12174:13 195:16 233:3,4285:21 307:1 317:23318:3 489:25 515:15515:18,24 517:1562:16 609:5 630:11

terminal 651:6,7,14,15terminals 161:12,12,13terminate 15:8terminates 473:25terminology 109:5173:16

terms 60:20 94:2,10128:19 129:3 136:2156:3 204:4 209:8239:22 306:15 311:25318:5,6 387:21 395:10412:19 506:7 544:15569:7 620:25 629:3630:16,19 632:8 647:3654:18

terrible 397:7Terry 3:20 9:4 57:16,1669:3,3 392:4,5,10

test 38:16,21 39:23,2448:7,8 49:10,11,2455:9 87:25 88:3,5,690:22 93:6,6 110:9,12112:16 114:19 115:8115:11 116:7,13 123:6126:23 127:22 129:1130:9,10 135:5,7

136:23,24 139:13,17140:24,25 141:5 150:4153:16 154:4 155:25172:19,20 249:1 250:2252:15,16 269:7390:12 455:8,12,12487:12 517:22 630:14651:7

test' 37:17 38:10,20 41:1test.' 127:14tested 116:2 128:21139:22 170:23 171:1,4389:7 395:15 458:23469:6,8

testifying 378:2testimony 196:10 198:9198:22 207:1 384:5412:19,21

testing 27:10,12 29:2333:15,24 43:2,20,2552:3 67:13 93:7111:10 123:7 131:19135:24 136:8 140:9141:11 151:21 155:22156:21 171:2,24172:17,25 173:3,15,15173:21 174:4,12,14175:1,4,16 201:9222:25 243:22 246:12247:21 248:19,22250:11,14,20,24251:11,15,20,22257:15 269:1 333:9,14374:21 389:15 437:22462:3 470:18 471:11471:12,12,13,16474:10,12 487:1 524:2568:17 628:22

tests 54:3 59:1 88:4123:10 126:10,12131:20 136:4 137:8139:15 246:1,4 252:5

Texas 12:9 27:1 146:9154:14,17

text 19:2,3,4,6 37:1838:22 41:2,4 42:2144:18 45:18,21 46:152:24 53:1,6,7 65:8,1065:15,17 67:7,9,16,2268:4,9,13 69:5,7,970:16,18 76:25 78:4,582:18 84:12,14,19,2091:25 92:2,8,9 95:3,595:10,11 97:20,2298:2,4 99:18,20,25100:1 101:14,16,21,22103:11,12,17,18 106:9106:11,16,17 109:12110:12 114:14 115:20115:22 116:10,22117:20,22 118:2,3121:6 125:3,5,13128:9 132:1,3 138:5,7143:19,21 156:2157:14,16 167:25168:2 175:25 176:2199:19 211:18,20212:2,4 226:22,24



Page 52

227:4,5 240:13,15,20240:21 253:23,25254:16,17 263:7,9,14263:15 273:6,8,13,14292:3,4,10,11 295:5,6295:9,18 304:13,15,20304:21 321:12,14,19321:20 325:21,22,22326:5,11 330:20338:25 339:2,7,8352:13,14,19,20361:22,24 362:4,5365:15 371:7,9,14,15379:5,7,13,14 400:2,4400:9,10 401:6 402:18408:10 410:11 411:13411:15,20,21 419:25421:10,12,17,18423:15 424:7,9,14,15428:4,6,11,12 429:3430:14,16,21,22437:14,24 438:2,7439:8,10,15,16 444:13445:12,16 447:18,20447:22 448:10 450:5,7450:12,13 453:2,4,9453:10 454:16,18456:22 457:19,20464:6,8 474:21 475:25476:2 479:19,20481:19,20,22 493:12493:13 501:5,7 504:7504:9 511:7,9 520:4,6526:15,16 533:11536:20,21 538:25539:8 545:22,24554:10 556:2,3 557:3557:4,5 565:12 566:16566:18 573:5,7 583:23583:24 589:9,11 593:3593:5 596:6,8 599:15599:16 610:3 611:21611:23 624:9,10627:19,22,24 633:15633:17 636:19,21640:3,5 643:13,15,15657:3,4

thank 19:15,23 26:1,1927:20 28:13 29:8 30:830:22 31:20,25 35:339:10 41:5 43:14 44:844:14 45:10,15 46:4,646:25 47:6 48:16,1748:20 49:14,18 51:3,551:7,15 52:12,13,1853:16 54:25 55:256:10,15 57:13,14,1659:10,11 61:9,12,2461:25 62:21 63:1564:7,8,10,20 65:4,1465:24 66:20,24 67:3,667:17,18,20 68:2369:3 70:11 71:14,2472:1,5,21 77:6 78:282:13,16 83:11,1984:2,3,7,17,24,25 86:586:11 88:10,11 90:1291:16,21 92:6,17,21

93:12,19,24,24 94:1894:19,24 95:8,19 96:897:1,8,9,15,25 98:1698:23 99:5,14,23100:9,13,21 101:2,10101:11,19 102:5,9,18102:24 103:5,6,15104:5,10,12,17 105:2105:12,17 106:1,5,14106:25 107:2 108:9,16108:23 110:23 111:2111:16 112:23 113:5113:20 115:1,11,19116:17 117:5,6,14,15117:25 118:7,21120:23 121:4 122:13122:14,16 124:2,15,16124:21 125:22 128:10128:11 129:24 131:10131:11 132:11,12133:19,25 135:17136:14 137:20,21138:21 139:23,24140:12 141:15,17142:14,15 143:8,9,24144:5 145:10,24 146:2147:11 148:3,4 150:17150:18 151:7,12152:13,15,25 153:1154:9,11 155:4,5,11156:23,25 157:19,25158:1,16 159:6,11,18159:20 161:18,19162:13,18 164:7,8166:13,14,24 167:9,10167:21 168:5,24169:14 170:5,12,18171:7,9 172:2 173:7,8174:8,16,17 175:7,8175:14,20,21 176:5,10176:25 177:15 180:17180:18 182:7,8,11184:5 185:22,23,25186:15,16,18 189:3,4189:6 190:25 191:2,7192:25 193:1 194:3,5195:6,7 197:6 198:16199:16,18 200:8201:17,18 202:15,16204:11,12,14 205:4,5205:23,24 208:1,2,4209:9,10 211:23212:15 213:2 215:4,5216:21 217:2 218:4,5218:15,16 220:4,5221:16,17 223:4224:21 225:18 226:17227:12 228:18 229:4,7229:19 230:15 231:7233:18,20 234:21235:1,20,22 237:7,22237:23 238:19,21239:13,14,23 240:9243:13,17 244:3,8245:17,18 247:2,3,5249:9,10 251:3,4,23252:20 254:9,21,25255:9 256:4 258:11,12

259:22 261:13,24262:5,6,23,24 263:3263:21 264:13 267:13268:16,17 269:23,24270:20,21 272:4 274:1274:7 276:15,16 278:7278:8,16 280:22,23281:20,21 283:13285:15,16 287:17,18289:11,13 290:10,11292:15,16 293:18294:8,18,25 296:9,10296:12,21 298:25299:1,21,22,24 301:9301:10,12 302:6 304:4304:9 306:4,20,22308:20,22 309:2 311:1311:2,4 313:4,6314:22,23 315:23316:21 317:2,3 318:19318:20 320:1,2 322:15323:4,10 325:24,25326:2,19 327:22,23328:3,25 329:1,13330:8,9,11,13,15,21330:22,24 332:16333:18 335:5,6,7336:11,12 337:3,9338:10,11 339:19,20342:18,19,22 343:2,25344:1,6 345:6,7,9346:20,21 347:15,16347:23 349:8,9,11350:9 351:3,16,17352:2,4,8,23,25 353:6353:13,15,22 354:22354:23,25 355:5 356:8356:9,18,19,20 358:2358:3,18 359:16,18360:19,21 362:9,14,23364:14,15,17,22365:17,23 366:15,18366:22,23,25 367:20368:11 369:12,13370:4 371:22 372:3,25373:2,7,25 374:2,13374:15 375:9,11,22376:16 377:5,10,21379:24 380:25 381:2,7381:24 382:1,8 383:15383:17 385:17,19386:24,25 388:13,15390:17,18,20 391:3392:2 393:19,20 396:6396:15 398:18,20400:25 401:4 402:2,4402:9,19,21 403:1,23403:24 404:1,25 405:1407:6,7 408:10,11409:10,11 410:8,12,13411:4,9 413:9,12,17415:3,7 416:12,18418:1,3,11,21,22,24419:16,17 420:7,12422:1,24 423:3,7,15423:16 424:22 425:15425:17 426:1,12,14,18427:4,10,13,20,21

428:21 429:14,16,21430:2,3 431:5 433:1,3433:8 435:1,2,20,22436:20,21 437:4,5,7438:23,24 439:4 442:7442:8,10,15 444:2446:18 448:17,19449:6 450:23,24451:15,17,22 452:7,19454:5,10,20,22 455:5455:19,21,25 456:14456:15,23,24 457:7,8457:13,14 458:8 459:1459:2,4,9,23,24460:15,16 461:7,8,15461:16 462:12,14463:4,5,7 464:2465:13 467:10,15468:3,4,15 470:7,8471:21,22,24 472:15473:7 474:16,18,20476:17,23 478:20479:7,12,13,14,14480:6,11,13 481:9,12481:23 483:19,20484:2,15,17 485:1,2485:10,23,24 488:8489:3,4,6 490:4,5,8491:8,9 492:3,5,16,19492:25 493:2,6 494:1494:6,6,20,22 495:2495:16,17,21,22 497:5497:6,17,22,24 498:20498:23 499:7,9,21,22500:6,20,24 501:19502:8,10,15 503:1,2504:19 507:10 508:5,7509:14 510:8 511:2,22512:18,20 513:16,18513:23 514:13,15516:8,9,11,20,22518:3,5,20 519:7,16519:19,24,25 520:25521:15 522:3,21,23524:2,3,7,16,17525:15 528:3 529:25530:1,3,8,11 532:4,5532:10,18,19 533:19533:20,22 535:6,16,18536:9,14 537:12,14,19538:19,20,22 539:5,17539:19 541:21 542:4,6542:14,16,18 543:5,6543:8,23,24 544:20546:13,21 547:3 549:5549:6,8 550:25 551:5551:18,19 553:6,7554:1,2,24,25 556:13556:21 559:8,9,11560:23 562:7,9 563:11564:7,8 565:15 567:23569:20,21,23 570:23572:3,5 574:19 575:1575:6,12 577:15,16,18579:12 580:17,19584:10,25 585:2,16,23585:24 586:4 587:12587:13,18,19 588:4,6

588:15,22,23 589:4,22590:12,14,24 591:7,8591:13,21,23 592:8,9592:18,23,24 593:22594:8,10,20,25 595:1595:6,13,14,21,25596:1,2,20 597:7,9,21598:2,3,4,16,18 599:2599:3,8,9 600:5,12602:11,12,14 604:8606:14,16,24,25 607:2608:6,7,8,20,21 609:3609:19,20 611:9,15,16612:13 614:25 615:1,3617:1,2,7 619:9,11,19619:20 620:18,19,20621:17,18,20 622:14622:16,25 623:21,23624:4,22 625:7,9,19626:1,2,15 627:7,9,14627:15 628:12 631:3,4631:6,11,23 632:18,19633:4,5,10,11 634:23634:24 635:1,6,14,22636:14,15 637:6,9,15637:25 638:1,3,16639:8,10,17,18,23,24640:18,24 641:8,9,11641:16 642:15,20643:2,3,8,9 644:12647:7,8,10,15 648:2,4649:8,9,11,19,20650:8 651:21,23,25652:10,17,18,22653:23 655:1,2 656:1656:17,22,23 659:21660:13

thanking 21:3 293:13thanks 34:21 40:4 43:1472:10 171:6 240:7365:18 635:21

the-question 41:9theoretical 123:3theory 394:23thermal 90:23,24 247:17250:15,22 257:17261:19

thermocouples 134:20134:21 135:6,8 136:1137:5

thermomagnetic 394:21395:3

they'd 285:13thin 436:11thing 50:1 54:8 79:1383:24 100:20 113:10115:5 122:3 134:9167:3 173:22 183:11188:23 193:21 198:23199:7 203:22 207:19255:10 269:14 288:4289:2 314:1 317:11325:20 359:9 363:25369:12 397:9 404:18417:10 419:10 474:3490:18 496:9 502:4506:19 518:1 544:3554:13 580:4 604:20



Page 53

613:13things 76:17 81:14 106:1113:11 130:6 134:13143:2 152:21 184:23185:2 187:14 192:19193:5,24 215:9 224:16225:11 228:3 237:12238:4,5,14 271:5284:17 302:3 323:16323:19 349:22 351:23357:16 368:24 376:22376:23,24 389:22,25390:6 391:14 394:7396:6,24 398:16412:17 415:14 437:16449:2 462:17 576:15582:6 607:6 613:1614:9 615:16 643:24651:4 653:5

think 39:1 47:19 53:2355:12,25 56:8 61:263:11 64:24 67:1572:3 83:4 93:1 113:10115:5 124:9 143:6151:22 152:3 170:21171:4 173:3 185:12186:24 191:20 192:17192:18 197:1,11 199:7201:11 205:15 208:19208:22,25,25 209:1,4209:7 217:21 218:1,8220:2 221:10,14235:17,18,24 236:16258:8 282:10,17,21284:17 285:11 286:25288:1,8 289:2 299:8299:11 308:18 311:9314:20 315:10,17322:19 332:5,6,9345:18 348:1,5 349:23353:6 359:9 369:22370:2 388:11,21389:11 390:21,22391:5 396:25 397:2400:18 405:22,25408:6 409:13,23 410:1410:2,4,5 415:25416:2 420:5 425:3,6425:24 426:8 427:17429:11 437:16 451:11460:23 465:2 473:20473:24 474:7 479:4491:4 495:1 506:14,15506:20 509:21,22510:7 512:14 522:19524:15 533:13 536:4,6549:14 553:3 576:21582:6 585:14 606:8610:22 621:24 622:1,5622:13 626:20 653:15658:11,11

thinking 474:2 500:8580:5 609:25 653:10

third 126:15 128:7 129:5214:3 300:7 329:23330:4 582:12

thirty 407:17 412:3this,' 500:8

this.' 207:18Thomas 6:10 8:1,5209:12,13 322:12,14322:16,18,21 323:1,13323:13 333:22 334:1,3337:10,11,14,16,19368:12 369:14 376:18376:18 406:6,6 462:16462:16,20 519:8,8588:6,7,14,16 591:25591:25 595:6,7 598:20598:20 626:17,17638:14 639:14,14641:14

thorough 171:11 524:24542:21

thoroughly 105:16 479:6578:6 602:7

thought 61:21 167:3193:9 287:2 312:16313:17 334:1 500:2,8505:18 603:22 653:25

thoughts 541:4thousand 51:23 192:14200:16 245:6 246:6248:10 346:7 403:10404:11 406:13 407:20445:18 452:4

thousand-volt 248:6thousands 47:16 48:6245:13,14

threat 148:19 246:23437:15 438:8,11 474:5

threats 398:6 438:14three 18:8 57:15 104:9109:25 114:25 115:21115:25 117:2,2,3127:18 134:13 162:17162:21 168:22 172:6174:8,18 177:22180:18 189:4 195:7198:7 205:24 218:16222:12 234:18 237:7239:22,25 247:9249:11 251:24 260:1261:14 270:22 276:25282:12 285:16 307:1,2307:2,8 311:3 313:7314:19,21 316:22317:13 318:20 319:14319:23 330:14,23332:7 333:20,21336:13 338:4 342:4,5345:8 347:17 349:3,5349:10 350:11 354:2355:4,10 356:5,13358:4,10 359:16 360:4364:21 365:14,22366:17 367:20 373:6374:5,14 375:10 381:6383:16 388:16 394:16396:14 402:8 406:4410:7 412:6 415:25418:4 425:25 429:20433:7 435:21 442:14449:7 451:21 455:3459:8 461:8 466:13,14467:14 468:8 471:5,8

473:17 474:11 482:2,6482:11 484:1,20 488:8490:5,7 492:3 495:1495:18 502:14 503:6507:14 512:23 513:21514:11 523:15 539:4564:9 568:15 585:15587:14 590:23 591:24594:19 595:4 597:20598:19 600:21,25601:5,10,13 604:11617:5 625:17 631:10635:5 638:15 639:13647:14

three-year 153:9threshold 59:5 192:9224:5,7,8,8,16 242:15242:17 275:19 279:7279:17 280:5

thresholds 275:19throw 395:16thrower 436:13throwing 281:12THURSDAY 1:8 12:3119:10 230:7 412:11527:11

TIA 156:11 258:4 264:11420:1 517:21 610:24

TIAs 156:9tie 16:24 616:5tied 70:2 415:13 482:12483:13

tile 369:18,19Till 5:12 169:4,4,13,14170:5 171:7,9 175:14176:10

Tim 3:23 4:19 5:24 62:362:3,17,21 113:7,7115:4,4,15 146:8,18150:20 157:4 158:1191:5,5,5 220:7,7231:4,4,13,17,17235:24 236:8,8 238:23239:2,2 241:1,1,11,11241:11 251:6,6 264:24264:24 265:7,7 270:1270:4,4 278:13,14599:25,25 600:12607:2 612:8,8,19,19622:16,16,23 623:1

time 13:10 17:5,17 18:1018:13 19:18 20:2122:9,24 25:15 36:337:18 38:5 39:6 40:340:21 49:8 55:22 59:159:5 60:21 64:1565:25 68:19 82:8102:21 126:16 127:14127:20 128:6 130:9,10130:21 149:21 151:3,5155:18,21 173:1174:21 185:14 197:12201:17 208:15,17,17218:3 221:11 223:10223:24 224:19 241:17247:2 248:21 256:21260:5 261:11,11263:19 267:16 269:7

278:19,23 281:11,12282:17,19,20 285:13287:1 308:6,17 313:4319:15,19 328:16335:12 337:22 351:9356:3 368:5 373:23374:20 377:8 378:19385:5,8 390:16 393:16395:15 398:14,18413:19 416:2 417:19426:10 433:14 446:21448:18 467:7 478:25482:8 484:6 490:6496:18 499:17 507:8514:20 519:1,6,16530:24 531:19 539:17542:18 550:8,17554:15 560:6 570:9577:23 588:19 597:24601:18 605:12 609:4619:22 621:13 634:18641:7 646:6 647:7651:10 652:19 654:20655:5 660:2

timeline 157:6,7timely 19:20 58:18154:23,24

timer 18:12times 104:10 116:7246:6,25 251:9 256:13314:8 497:19 505:21552:19

Timmons 8:22 382:8,9Timothy 600:12 607:2tiny 262:18 282:7tired 446:15 576:4603:21

tireless 23:3titanite 283:1,2,9title 90:7 656:7TLC 53:12 170:9toasters 354:20today 16:9 17:2 21:1623:16 26:17 31:15,2432:3 36:8,14 39:3 41:942:5 72:16 75:25109:13 111:24 116:25118:11 160:4 168:14172:18 188:15 195:18195:19 196:24 199:4203:4 233:10 251:9,20268:25 279:16 290:4330:7 333:3 349:6353:7 369:12 377:19384:4 387:5 388:4393:23 408:23 440:11441:23 456:3 484:12533:2,2 551:8 567:3604:23

today's 13:25 14:3,616:23 37:9 41:21 42:1354:14 359:22 360:11369:3

Todd 293:11toe 389:4,4together.' 290:1told 277:15 416:24417:12 481:3 506:19

508:17 582:5tolerance 561:20tolerant 247:18Tom 10:16 11:13 146:8293:11 492:5,5 638:16638:17 641:16,17647:13,15,15

Tomlinson 4:19 146:9146:16,18 147:11150:18,20 157:4,25158:1

tomorrow 180:10 359:25tomorrow's 359:22tonight 412:25 416:2543:12 622:11

tons 87:18 89:13 394:18Tony 80:11 81:19,23too' 396:21,24 412:21462:6

too's' 382:6too.' 382:6tool 165:9top 4:1 40:7 80:9,9,16,2380:25 81:8 161:5201:4 660:4

topic 223:18 314:1319:12 368:22 408:16550:8

topics 23:21 24:9 298:13314:11,17

Torbin 9:17 431:1,1,12431:12

Torley 4:24 153:3,3tortured 610:6total 19:12 48:9 192:8502:20

totally 141:6 225:3 398:9437:19 496:16 603:12603:12 645:16

touch 37:24 38:2,4 40:1540:18,20 52:22,2453:1 65:7,9,10 70:1570:17,19 84:10,13,1491:24 92:1,3 95:2,4,697:18,20,22 99:17,1999:21 101:13,15,16103:9,11,13 106:8,10106:11 117:19,21,23125:2,4,6 131:25132:2,4 138:4,6,8143:18,20,22 157:12157:12,14,16 167:23167:25 168:2 175:23175:25 176:2 210:1,2211:16,18,20 226:20226:22,24 240:12253:10,11,21,23,25263:5,7,9 272:17,18273:4,6,8 291:15,16292:1,3,5 304:11,13304:15 320:25 321:1321:12,14 338:23,25339:2 352:11,13,15361:8,9,21,23,25370:17,18 371:6,8,10378:15,16 379:4,5,7399:14,15,25 400:2,4411:12,14,15 420:23



Page 54

420:24 421:8,10,12424:5,7 425:13 428:2428:4,6 430:12,14,16439:6,10 449:19,20450:4,6,7 452:25453:2,4 457:17,19,21464:5,7,8 475:13,14475:24 476:1,2 479:17479:19,21 493:10,12493:14 501:3,3,5,7503:21,23 504:6,8,9511:6,8,9 520:2,4,6526:3,4,13,15,17536:18,20,22 545:9,10545:21,23,25 555:13555:14,25 556:2,4566:3,4,14,16,18572:18,19 573:3,5,7582:14 583:11,12,21583:23,25 589:7,9,11593:1,3,5 596:4,7,8599:13,15,17 611:19611:22,23 624:7,9,11627:17,20,20,22,24633:13,15,17 636:17636:19,21 640:1,3,5643:11,13,15 651:2657:1,3,5 659:5,7

touched 128:18 375:3377:4,9

touching 377:4 563:20tough 185:14tougher 460:9toxic 237:15,15,17 239:8346:19

toxicity 239:7toxics 237:14 238:14260:16,17

Toyota 294:13 295:1546:14 547:4 554:5

TPI 217:3 244:9trace 324:25tracing 409:19track 582:23trade 556:18 575:3trademarked 129:11tradition 185:20traditional 186:8 195:2213:17 214:1 225:7601:22

traditionally 184:13300:24 469:9 655:21

traffic 557:17 562:18,23563:17 564:1 571:22

tragedy 599:1tragic 376:1train 127:19 130:7,8,11130:13,15 436:16603:22

trained 163:19,24 166:6396:17

training 164:3 166:5,7,8185:4

trains 87:9 128:20,22transcribed 1:22 661:6TRANSCRIBER'S 661:1transcript 309:12TRANSCRIPTION 1:3

12:1 119:6 230:3412:7 527:7

transfer 331:13,13586:10 587:18 588:7590:8 591:4,18 592:2594:5 597:1 598:22613:10

transformation 204:23transformers 328:11Transit 119:22 120:10120:15

transmission 196:13204:23

transmittal 261:4transparency 334:7,22transparent 153:7transportation 86:2591:12,14 96:6 302:22303:14,23 550:11,16553:23 559:25 570:15570:19 578:4

trash 429:7travel 445:24traveling 507:4tray 502:15 632:14trays 630:9Treasurer 384:2treat 165:2treated 279:12 609:13609:16

Treatment 34:10tremendous 276:1 350:7468:19 508:1

trends 380:18,19trials 374:21trigger 260:15trip 394:20 396:2 576:14576:18

tripped 395:18tripping 384:18,25 385:2385:11 389:6 397:11397:12,21,25

tripping' 389:18trippings 389:24trips' 389:18trouble 259:6trout 395:17 397:23truck 432:7true 59:23 60:22 160:24312:10 331:6 385:6458:25,25 490:11528:22 605:14 618:9630:17 661:12

truly 22:11 23:6 188:11trust 75:24 303:8 392:23393:2 473:22

truth 394:11try 39:5 47:21 52:9 54:273:8 182:14 222:1260:23 324:17 391:9396:11 417:21 473:11509:23 543:16 576:2,4582:24 658:23

trying 52:1,2 53:22 67:1569:8,15,22 70:3151:21 170:20 201:16205:10 219:8 235:19262:8 283:4 365:9

387:13 398:8 409:4436:17 460:24 496:12506:3 538:15 544:13554:14 562:3 582:25612:25 616:13 621:3623:11 645:12 656:13

TSTC 645:7tube 486:1 489:12 490:9491:21,23 500:13

tubing 431:14,25 487:5489:11

Tuesday 436:25 532:15606:21 619:16 642:24649:16

tune 173:1tunnel 123:5 124:1132:16 133:5 142:4

tunnels 122:20 124:1133:10 140:2

turn 24:17 34:24 41:16153:11 285:19 303:13549:23 550:15 570:7643:25

turned 338:7turning 511:3 560:13TUV 176:15tweak 319:23Twelve 140:6twice 317:8 407:13430:2

two 19:6 21:11 23:2324:7 26:18 38:23 41:442:5 51:23 53:1,8 55:458:1,19 61:11 63:965:10,17 70:18 72:972:17,20 76:12 77:178:6 84:14,21 92:2,1095:5,12 96:4 97:2298:4 99:20 100:2,18101:16,23 103:13,18106:11,18 117:1,2,22118:4 125:5,11,13127:18 132:3 135:24138:7 143:21 149:17154:23 155:19 156:12157:16 162:7 163:6168:2 176:2 179:19182:17 187:14 190:6,8202:25 206:2 209:10211:20 212:4 222:3,4223:4,17 224:1 226:24227:6 229:23 234:25238:21 240:15,21248:9 253:25 254:18259:5 263:9,16 270:10273:8,15 275:9 281:3289:11 292:5,12296:18 299:8,23 302:7304:15,22,24 307:21308:25 315:23 317:3321:14,21 325:21326:18 329:2 330:21335:6 339:2,9 341:18341:23,25 342:25344:16 348:4,19349:17 351:6,9 352:15352:21 355:3 360:4361:24 362:6 368:11

371:9,16 373:10376:17,21 377:2,5379:7,15 382:7 393:20394:15 400:4,11402:19 403:6,25409:11 410:12,14411:15,22 416:17418:11 421:12,19422:16 424:9,16426:17 427:6 428:6,13430:16,23 435:5436:20 437:6 439:10439:17 441:12 446:18447:9 450:7,14 452:10453:4,11 457:21462:17 464:8 466:9468:14 473:12 474:4476:2 479:21 485:21487:15 491:8 493:14497:6 499:23 501:7504:9 508:19 511:9516:20 517:18 518:3519:7 520:6 524:17526:17 530:7 531:8,13535:19 536:22 539:23542:14 545:24 549:15550:4 551:4,11 556:4559:16 562:7 563:14563:22 566:18 568:13573:7 576:17 577:22579:15 580:1 583:25584:17 586:3 587:19588:4 589:11 591:11592:9 593:5,18 595:14596:8 598:3 599:17601:3 602:18 611:23615:7 620:19,24 621:7621:19 623:20 624:11626:5 627:24 633:17636:21 640:5 643:15644:1 647:20 649:9654:15 657:5 658:24659:7

two- 164:15two-fold 441:12two-thirds 391:4,18type 13:14 36:7 48:459:22 81:14,25 89:6127:19 182:16 217:12238:3 278:3 298:17389:16 397:17 401:17403:20 406:16,23407:25 409:7 416:9447:12 482:13 485:19486:4,4,4,11,11,14,21488:6,14,15,20,20489:9,9,12,12,21,21489:22,22 490:1,1,2,3490:3,16 492:10,12528:24 530:25 531:2533:2 565:5 568:13576:3 618:22

types 191:22 192:18193:20 232:2 247:13259:15 274:25 279:4279:21,25 280:7,11297:21 298:2 308:12333:1 346:14 405:9

406:11 437:22,25484:10,12,25 485:14485:16,17,17 486:5,21488:4 489:9,14,16,24492:23 494:11 497:19529:1 531:13 533:8584:21 638:25 639:3

typical 409:15typically 16:1 36:2589:20 115:8 139:9204:10 248:6 372:18523:21 568:20

UUL 21:20 26:8 139:14,14140:21 141:12,23142:12 174:10 180:20198:8 216:7 218:18237:8 245:24 248:22249:2,12 268:5 275:22285:18 296:22 300:1,7301:6 317:6 326:20335:8,22 337:21 343:3436:22 487:13 532:11533:3 534:2,12,18535:9,14,16 541:17551:6,6 562:10 586:5586:6 606:17 619:12642:21 649:12

ULC 326:20ultimate 122:6ultimately 422:11 548:5552:16

unanimous 402:18407:2 416:11 434:25539:16

unanimously 175:15194:13 542:24

unaware 441:1uncertainty 250:5382:23

unclarity 646:25unclassified 447:10448:1,2

unclear 115:21 173:17558:24

underground 87:11440:14 441:3,14442:20 443:6 445:4,17445:23,25 446:8,11447:1,4,6,7,15 448:3

undermined 393:4underneath 355:18underserved 651:20undersize 610:4understand 53:21 69:1471:8 75:21 131:20156:20 160:15 173:20184:25 203:11 205:15238:6 267:6 268:13271:11 272:1 316:10367:23 369:7 392:14405:7 409:24 419:13429:24 492:21 564:19605:8 614:13 631:19

understanding 139:21203:20 265:20 268:2276:3 283:21 284:24



Page 55

367:10 496:18 515:17524:25 649:6

understands 173:2334:24 562:17

understood 88:17 96:15137:6,6 184:14 213:14373:16 518:14 622:6

undertaken 149:3 154:9381:19

undertaking 441:10Underwriters 299:25undue 220:2 584:24unduly 529:21unenforceable 311:24311:25 444:20

unfamiliar 89:19unfettered 547:17unfinished 363:19366:12 367:24 368:1,8368:9,25 369:3

unfortunate 126:7 134:9247:13 256:12 347:11499:19

unfortunately 58:16109:10 148:10 192:3257:8 278:18 311:9359:8 376:24 499:13562:3 645:8

ungrounded 614:4UNIDENTIFIED 2:519:22 38:12,14,18,2539:8,10,14,18,21,2439:25 40:1,2 44:1245:8,9 62:20,22,23,2462:25 63:4,11 66:2,5,666:7 67:2 70:21,22,2370:24,25 71:1,2,3,4,571:6,7,11,13,18,19,2071:21 72:23 73:1,4,873:10,12,13,22,2474:2,5,6,8,10,12,20,2575:1,3,5,7,8,9,11,1475:17 76:15,17,2177:3,9,11,12,13,14,1677:17,20,24 78:10,1478:16,17 79:8,10,1679:18,21 80:3,14,1780:18 81:5 83:1686:14 92:20 95:2298:14,15 100:12 102:8104:4,23,25 108:20117:10 118:24 119:16121:12 125:7,25 134:3138:24 145:13 147:23159:14 166:17 170:15178:5,6 198:3,6,13,15209:15,22 210:4,5,6,7210:11,12,14,16,17,22210:25 211:3,9 212:18229:16,20,21 230:13230:18,21 231:10240:6,7 241:7 249:4253:5 254:2,4,5,8,11255:3 257:24 265:3272:8,9,13 274:4290:15,22,24 291:5,6291:7,9,10 294:21306:5 320:6,7,8,10,17

320:21 322:6,9,10,11323:7,9 331:17,18,20331:22,24 332:1,2,3,5332:9,12,13,15,17,19332:20 333:24 339:20340:3,22 353:12360:23 361:4 362:19362:20 370:7,13371:25 378:1,11379:11 380:2 395:19395:25 396:3,8 398:24398:25 399:1,2,9,10401:3,13 412:2 413:15420:10,12,18,19 422:4423:20 424:25 428:24428:25 431:8,9 434:19440:2 449:15 451:3,4454:9 458:11 464:22464:24 465:16 474:23475:9 476:10,21477:13,15,18,21,22,25478:10 481:15 494:4,5496:6 501:22,23 503:9503:11,17 504:22510:11,12 511:25513:17 522:6 525:24528:6,7,8 537:13,22544:24 545:5 546:25555:9 556:25 565:24567:19 572:14 574:5575:9 580:22 581:1,9581:18,19,20,21,22,25582:8,9,10,11,12,15582:18,21 583:7584:13 589:25 590:9590:11 593:25 596:23600:9 612:16 624:25628:15 634:15 637:12640:21 644:15 653:25654:7 657:6,8,9,10,11657:12,13,17,19,22658:6,13,19,21,22659:9,15 660:8,10

unidirectional 299:11unified 495:9uniform 393:5uniformity 82:8 604:5uniformly 603:6uniforms 152:22,22unimpeded 343:16unintelligible 19:22,2338:12,14,18 39:11,1439:15,16,20,21 62:2062:25 66:7 71:7,18,1971:21 72:23 73:4 74:974:25 75:3,7,9,12,1576:21 78:14,17 79:879:21 80:3 87:2593:10 98:15 104:23109:14 110:1 117:10122:7 131:14 145:13147:16 180:3 197:9198:3,15 210:11,15,16210:17 211:9 229:20230:18 231:10 240:8249:4 254:2,5,11255:15 257:24 259:10263:25 271:11 272:8

272:10 290:15 320:6,7322:3,6,10,11 331:16331:20 332:1,3,12,14332:15,19,20 333:24378:1 379:11 390:24392:8 395:19,25 396:3396:8 399:2 401:13412:2 420:19 422:25462:5 464:23,24477:14,22 496:6 503:9503:11 510:11,13513:17 534:20 542:11559:3 576:21,22581:21,25 582:8,11590:9,11 608:24 609:6630:3,14,20,21 634:4641:5 646:21 657:6,7657:11,13,17,19,22658:6,13,19,22 659:9660:8,11

unintended 247:13275:12 282:10,21341:9 403:5 646:3653:21

unintentional 392:20unintentionally 275:11654:16

uninterruptible 214:5Union 135:12unique 23:19 171:15208:9,12 225:11466:15,15 568:22

unit 250:9,21,22 258:25372:12 373:13 492:12586:11

United 21:20 90:1 116:6134:25 135:3 136:11136:13 139:10 140:4,7194:11 202:2 214:6217:8 305:15 386:9387:7 441:7 552:13553:6 651:20

units 250:21 251:11,22279:23 372:13 375:19380:10,14 382:21394:2 513:12

universal 275:10universe 68:21unjustified 345:3unknown 324:3 336:10646:6

unlimited 489:13unlisted 646:20 647:23648:12 652:12 653:10653:11 654:21

unmatched 24:16unnecessarily 357:15unnecessary 93:17 99:3111:11 143:8 548:6577:8 637:24

unneeded 217:16unplugged 359:11unprecedented 226:9unprotected 445:6unqualified 359:6 508:4508:5 510:1,6

unquote 225:13 515:9516:1

unreliable 390:3unreported 360:15unresolved 568:9unsafe 336:11 348:9403:15 518:16 598:14

unspecified 394:9unsuccessful 485:22unsuitable 112:12unsurpassed 22:15untenable 123:19untested 372:16unusable 383:6unused 447:16unwavering 23:6up.' 205:12upcoming 302:19383:12

update 569:11 641:6642:5

updated 196:15 199:20213:25 641:5 642:10

updates 24:10updating 196:19 641:22upgrade 123:12 152:10upheld 435:11uphold 150:22UPS 216:3 218:22219:14 245:7

UPSes 597:3urban 181:11 187:20196:3,3 199:15 203:16

urge 48:15 50:15 52:1154:24 59:9 61:8 70:484:1 96:6 112:21116:16 127:25 135:14164:5 174:3,7 185:21197:4 199:16 218:15224:19 233:16 235:20239:23 243:11 252:18261:12 267:11 272:2280:16 281:2 283:10285:10 287:13 290:9315:21 316:20 319:13329:12 330:8 333:18335:4 345:5 346:19347:13 349:8 350:8383:14 390:16 393:18396:6 404:24 406:3407:5 411:2 418:2,20422:22 426:24 435:18435:24,25 436:18437:3 438:22 451:14456:13 458:16 461:7465:21 472:1,16474:16,16 491:7514:10 519:17 525:13549:2 551:17 559:7565:13 587:11 588:3591:20 592:17 595:19598:16 606:11 621:17626:14 653:18

urgency 58:17,22urging 182:4USA 212:9 273:20274:11

usability 454:18,19456:11 466:12 469:25531:12 628:24 629:4

631:1 632:25 647:5650:10

usage 298:12 558:5559:4 564:4

usages 577:1use 13:13 36:6 80:1787:20,20,21 89:8 97:797:8 109:11,18 111:13113:12,16,17 114:2,6114:7 116:7 124:1134:24 139:15 141:23166:4,6,8 182:17184:12 195:16 199:15207:12,13 222:3287:10 288:1 297:25298:5,24 299:14302:20 303:23,24,25304:1 319:25 336:10363:16 382:14 384:21385:8 387:19 389:16418:16 433:17 435:12438:15 470:23,25473:4 482:3,5,8,12483:4,13 485:22486:12 487:3,22,24488:3,4 490:12 492:10492:11,12 506:24507:1,3 515:14 528:17529:21 552:6 558:5570:14,15,17,17 571:9576:23 580:6,9 609:5610:5 614:14,15,15,19616:2,3 630:11,13646:14 647:22 648:16

user 111:8 112:10115:24 127:16 130:18324:20 328:6 329:9334:22 336:6 385:6458:24 506:11,13,15515:11 525:10 616:22629:4 630:6,18 631:3

users 141:4 232:3 267:5267:24 276:2 289:5417:5 432:20 514:25515:7 541:6 550:12606:9 617:21 618:12628:24

uses 110:22 219:22298:9 485:1 558:8563:17

USFA 380:16usually 58:1utilities 178:16,24 179:7181:4,22 182:14,20,23183:12,22 184:14185:12 188:2,5,25193:25 194:11,14,17194:17,25 197:17199:8 203:7 206:7,8209:3 216:4 222:3246:15 284:25 289:5441:6 539:25 600:18646:21 652:13

utility 178:10,14 180:24181:12,14,17,20 186:5190:3,17,18 194:23195:17,20,23,25 196:1199:1,2,10,14 200:15



Page 56

200:20 201:3 204:8,25214:4 218:22 222:9289:25 405:4 441:21600:1,13 601:2 603:2607:3 608:16 609:9612:9,20 613:9,11614:7,13,17 620:11621:6 622:17 645:10645:23

utilization 298:15utilize 16:18 184:10utilized 129:8,11 603:15utilizes 181:8 198:21utilizing 116:13 204:19

VV2X 297:3vac 565:3vague 131:3,9 142:13170:24 171:5 311:24311:25 444:13,19,24

vaguely 347:12,12Valencia 33:10valid 242:7 280:18313:11 331:9 529:23646:3

validated 335:25validation 151:16 156:17165:24

valuable 46:14 50:24126:22 190:14 200:19201:11 385:14

value 48:23,23 51:19,25201:16 241:20,22249:21,24 284:1,21328:6,17 434:14

values 88:6 129:4,20275:20 438:10 467:4467:24,25 470:2,3,5

vapor 167:18 529:6,7,9529:10

vaporizer 163:4vapors 107:6 440:19446:2

variable 395:12variances 69:18variations 275:25variety 23:21 173:24219:2 231:25 233:13236:1 265:11 446:2558:8 576:25

various 109:2 126:11172:10 179:2 183:4268:3 277:2 287:3298:9 391:13 438:8496:19 548:3 558:5576:23 630:7

vary 487:21varying 515:4vast 217:11vastly 188:15vault 447:4,7 448:3vehemently 623:9vehicle 286:13 295:8,8295:13,22 298:20300:3,9,14,20,23301:4,4 302:4,21,24303:12,13 547:11

548:10,14 549:4,5,23549:23 550:14,15551:12,16,16 552:12552:22 553:6,20,21,23553:23,25 554:24557:11 558:12 559:23560:12,13,17,19561:10 564:4,5,18565:2 567:11 568:6,7568:11,16,18 569:12569:16 570:5,7 571:12571:19 575:17 578:3

vehicles 295:18 296:1297:4 298:9,9 301:9302:2,11 303:23,24304:1 547:14 550:11558:20 564:2 568:23568:25 570:14,15,17579:24 580:5,8 600:20

vehicles' 564:6velocity 121:21,24 122:3122:5,21 123:2 124:11124:12

velocity' 122:18venison 395:17ventilation 123:5 124:1131:18 258:24 260:9260:11 261:19 284:10284:14,17

verbal 472:9,10verbatim 276:6verification 149:5,19150:5 151:3 154:25155:14,22 156:15171:12

verified 151:13 152:7154:19,23 156:4,6462:2 515:14

verify 50:17 89:4 150:25151:5

Verizon 645:7version 438:4 552:20569:3 579:23

versions 141:1 552:18568:22

versus 61:15 151:19185:10 247:25 249:16284:8 286:15 366:12542:22

vertically 141:6vessel 89:19,24 90:4vessels 88:14 89:6,10,1289:16,17,17 90:1191:5 96:12,16 105:24

Veteran 33:10vetted 249:22 385:5496:9

viable 152:1 274:23466:20 474:14 523:25

vibration 55:6,9Victor 3:20 57:16,1761:17 69:3,3

view 128:24 129:15474:6 563:3 581:2

viewed 123:24viewing 14:8viewpoints 474:21views 18:1 226:10

562:13Villa 30:15Vincent 3:5 30:12,14,22Vinyl 121:2,17 124:8125:19 126:5 130:5133:23 134:7 136:20138:19 139:4 141:19460:5 485:5

violate 444:20,25violation 326:9Virginia 188:19,20,21virtually 458:20virtue 639:6visa-versa 137:11vital 24:21Vogel 177:24Vogel's 177:22voice 12:21 13:3 35:1535:21

voices 71:23,25 72:6,1272:22 73:7,14,21,2574:3,15 75:2,4,6,10,1676:14,19 77:2,5,8,1577:19,22 79:1,1180:19 119:19 230:16230:25 339:22

volatile 247:16volt 201:2 245:5,6,7248:7,10 299:16,16303:3 353:25 354:17354:19 355:23 358:17380:9 548:11

voltage 200:2 247:24248:3 429:5,9,13,25438:18,20 466:1,24472:25 498:13,14,14506:21,22 517:14,15524:10 552:9 563:20651:1,2 655:12

volts 247:25,25 259:19259:19 346:4 349:19355:21 372:10 403:11403:12 440:17 445:18461:2 466:24,24 471:2473:1 650:23

volume 275:20volumes 161:3voluntary 178:25volunteer 22:4 24:11volunteered 23:22volunteering 24:5volunteers 20:21 22:1222:18

vote 16:9,21,24 18:16,1618:18 19:11 36:1337:17,22 38:1,3,5,7,1038:20 40:13,17,19,2140:23 41:1,7 48:1549:13,14 50:15 51:352:11,18,20,22,23,2553:2,5 56:1,8 59:1061:8 62:5,6,7,11,12,1462:16,16,18,23 63:1,863:8 64:6,20 65:5,6,765:9,11,14 70:4,8,1170:14,15,17,19 71:1772:18,19,19 73:17,2475:25 76:2,3,4,5,7,10

76:10,25 77:7 78:384:2,8,10,11,13,15,1891:22,23,24 92:1,3,794:25 95:2,2,4,6,997:16,18,19,21,2398:1 99:14,17,18,1999:21,22,24 101:8,12101:13,15,17,19,20103:7,9,10,12,13,14103:16 106:5,8,8,10106:12,13,15 116:16117:16,19,19,21,23118:1 124:19,24,24125:1,2,4,6,11 131:22131:22,24,25 132:2,4132:6 138:2,2,4,4,6,8138:11 143:15,15,17143:18,20,22,25150:14 157:10,10,12157:13,15,17,20161:18 163:16 164:6167:19,21,23,24 168:1168:3,6 173:6 175:7175:21,23,24 176:1,3176:6 180:16 182:4,4189:11 192:7 197:5199:16 209:20,24,25209:25 210:2,3,21211:6,13,16,17,19,21211:24 215:1 224:19226:18,20,21,23,25227:3 235:20 237:5238:19 240:10,12,12240:14,14,15,16,19241:24 243:11 252:18253:3,7,8,8,9,10,11,12253:16,19,21,22,24254:1,15 261:12 263:3263:5,6,8,10,13269:12,22 272:2,15,16272:16,18,20,22 273:2273:4,5,7,9,12 278:6290:10,20 291:3,12,13291:13,15,16,19,24292:1,2,4,5,9 299:8,20304:2,9,11,12,14,16304:19 315:22 316:20319:13 320:19,23,24320:24 321:1,3,6,11321:13,15,18 329:12330:10,12,20 338:20338:23,24 339:1,3,6346:25 350:9 352:8,11352:12,13,15,18 356:4357:12 361:2,6,7,7,9361:11,14,21,21,23,25362:3 365:14 366:21368:10 370:11,15,16370:16,18,19,23 371:2371:6,6,8,10,13373:25 377:20 378:9378:13,14,14,16,17,23379:4,4,6,8,12 381:15381:16 383:14 386:23390:16 391:4,4,5,24393:19 399:7,12,13,13399:15,16,19,23,25400:1,3,5,8 402:18

406:3 407:5 410:11411:2,9,12,12,14,19416:11 420:16,21,22420:22,23,24 421:3,8421:9,11,13,16 424:3424:5,5,6,8,9,10,13425:10 427:9,25 428:2428:3,5,7,10 430:10430:12,13,15,17,20434:25 437:3 438:22439:4,6,7,8,9,11,14444:1 446:16 449:13449:17,18,18,19,20,23450:4,4,6,8,11 452:17452:23,25 453:1,3,5,8456:23 457:15,17,18457:20,21,23 458:16464:2,5,5,7,9 465:21475:7,11,12,12,13,15475:21,23,24 476:1,3479:15,17,18,19,21488:6 489:2 493:8,10493:11,13,14 501:1,3501:4,6,8 503:19,20503:20,22,23 504:2,4504:6,7,8,10 511:4,5,6511:8,10,13 519:25520:2,3,5,7 525:13,22526:1,2,2,3,4,9,11,13526:13,14,15,17529:24 532:17 536:15536:18,19,20,22,25538:13 539:16 540:18545:3,7,8,8,10,11,16545:18,20,21,23,25550:24 553:2 555:7,11555:12,12,13,14,16,21555:25 556:1,3,4560:22 565:14 566:1,2566:2,4,5,10,14,15,17566:19 570:21 572:2572:12,16,17,17,19,20573:1,3,4,6,8 578:23579:10 583:4,9,10,10583:12,13,15,19,21,22583:24,25 584:3587:12 588:3,21 589:5589:7,8,10,12 592:17592:24 593:1,2,4,6,7595:12,19 596:2,4,5,7596:9 598:1 599:10,13599:14,15,17 602:10603:25 604:1,1,2609:17 611:16,19,20611:22,24 612:2614:24 620:17 621:11621:14,17 622:10624:4,7,8,9,11 626:14627:15,17,18,21,23,25631:21 633:11,13,14633:16,18 636:15,17636:18,20,22 639:24640:1,2,4,6,9 643:1,9643:11,12,14,16 647:2649:18 652:16 656:16656:23 657:1,2,3,5,6657:21 658:1 659:3,5659:8



Page 57

vote' 37:25 40:15 52:2365:7 70:15 84:10,1191:24 95:2 97:1899:17 101:13 103:9106:8 117:19 125:2131:25 138:4 143:18157:13 167:24 175:24211:16 226:20 240:12253:22 263:6 273:4292:1 304:12 338:23352:11 361:21 371:6379:4 399:25 411:12421:9 424:6 428:3430:13 439:7 450:4452:25 457:17 464:5475:24 479:17 493:10501:3 504:6 511:6520:3 526:13 536:18545:21 555:25 566:14573:4 583:21 589:8593:2 596:5 599:13611:20 624:7 627:18633:14 636:18 640:2643:12 657:1

voted 59:17 65:2,3 76:23104:9 154:16 162:4173:13 175:15 176:7192:7,9 243:4 266:4266:20,22 365:15367:3 390:23 391:16433:14 437:1 452:16514:22,22 532:15539:15 542:23 578:15602:9 606:21 609:22619:16 634:22 642:25649:17

voters 65:2votes 16:3,14 18:3 19:1236:8 37:5 39:4 41:2041:20,22 242:4,6297:15 343:21 354:8411:16 416:12 452:4457:24 464:12 479:25526:7 550:23

voting 16:3,5,7,14,15,1716:18,20,22 36:9,1237:14,23 38:1,6,8,940:6,14,17,22,24,2541:9,18,23 42:24 53:353:4 62:7 63:3 65:1265:13 70:20 72:16,2075:20,22,23 76:184:16,17 92:4,5,6 95:795:8 97:24,25 99:23101:18 103:15 106:14117:24,25 125:8,10132:5,6 136:12 138:9138:10 140:6,18143:23,24 152:6157:18,19 168:4,5176:4,5 197:25 210:19211:2,23 224:25,25227:1,2 240:18 249:8253:13,14 254:12,14263:12 267:22 272:21272:22 273:10,11279:16 291:17,18292:6,7 304:17,18

321:2,4,5,16,17 339:5352:17 353:17 354:5361:12,13 362:1,2364:1 370:21,22371:11,12 378:19,20378:22 379:10 399:18400:6 411:17,18 421:1421:2,14,15 424:12428:8,9 430:18,19439:12,13 443:25449:21,22 450:9,10452:5 453:6,7 457:22464:10,11 475:17476:4,5 479:22,23493:15,16 501:9,10503:24,25 504:11,12511:11,12 520:8,9526:5,6,18,19 536:7536:23,24 545:12,13546:1,2 555:17 556:5556:6 560:20 566:6,7566:20,21 572:21,22573:9,10 578:18,21579:1 583:14 584:1,2589:13,14 593:8596:10,11 599:18,19604:16 606:23 608:10611:25 612:1 619:18620:3 624:12,13 628:1628:2 631:21 633:19633:20 636:23,24640:7,8 643:17,18659:10,13,25

voting's 400:7vu 427:1

WWade 539:24,24wait 66:5 238:25 498:10waiting 209:19 253:2257:11 290:19 320:15361:1 370:10 378:8399:6 420:15 423:18449:12 475:6 525:21533:5 545:2 555:6556:11 565:21 572:11583:4 588:25

walk 105:3walk-in 258:25walked 375:5 654:3Walker 3:7 30:25 31:3walks 368:2 614:21wall 342:7,8 343:11346:9 436:11

Wallis 34:16walls 345:2 446:6,9want 20:5 39:2,2,2 40:547:11,12 56:9 60:2161:1 69:20 72:15 78:879:3,3,14,14 116:22124:13 127:21,22152:11,12 161:2166:20 173:1,22186:13 193:5 195:16197:2,9,11 203:10,12203:13 232:10 238:10242:21 247:8 250:13255:10 256:11 258:2

260:12 261:6 264:8270:1,11 302:20 304:2330:1,3 333:15,16337:6 338:15 341:10347:10 350:14 351:5351:13,14 357:11,14364:4 369:20,21377:25 394:25 396:20396:24 408:18 412:17412:18,20,22 419:14422:15 429:5 464:22470:20 477:7,23 478:5490:18,19 498:4,7505:20 517:8 518:24540:7 550:10 553:12562:1,2,16 605:4614:6 615:10 619:23653:4 658:20 659:3,5659:6,7 660:13

Wantagh 29:15wanted 51:8 61:14 73:1881:12 131:15 174:25197:20 204:21 207:25220:8,13 222:16 251:7261:6 269:10 396:25397:9 441:24 452:14487:22 498:10 557:2562:15 603:18 613:1613:15,15,15,19616:20,24 636:1

wanting 202:20wants 111:7 200:25347:6 494:14

warehouse 57:6 58:11279:20

warehouses 482:15warehousing 58:9warn 506:12,13,14Warner 6:18 245:20,20245:21 246:1,3

warns 541:10warrant 61:7warranted 447:15488:25 524:2

Warrem 10:16 492:5,6Washington 34:12wasn't 69:23 192:20207:17 271:16 303:11325:21,22 350:19367:2 447:17 496:10

waste 25:4 29:6 448:5Wastewater 34:10watch 54:17,18 58:14229:18 506:22

watched 615:13watching 615:12watchmaker 201:17water 27:10,14,18 54:1956:20 57:3,20,24 58:358:5,6,7,10 59:8 63:2464:1,2,2 69:13 70:1,285:22 91:10 164:20206:7 216:12 235:11287:8,12 333:13350:17 354:1 367:12367:22,23 368:3 434:4441:20 442:22 524:1538:16 544:14 586:18

586:24Water-Based 33:25 43:243:20 44:1

watercraft 87:16waterproofed 369:25waterproofing 363:17Waters 8:19 374:15,16537:14,15,25 543:25543:25

watt 246:6watts 245:7wave 389:23way 41:11 51:1 62:11,1293:2 94:18 114:9,10165:2 197:3 203:6249:17 252:16 314:20315:6 324:7 344:18348:14 349:23 350:1358:16 383:8 389:12393:6,10 394:13403:15 405:18 415:14419:3,6 436:15 449:5466:6 517:2 536:6561:17,25 565:8571:18 576:2 579:7609:25 610:13,15611:5 614:12 623:13635:12 646:19,23647:3 650:13,20

ways 185:8 352:1 384:12384:12 613:12

we'll 38:11,15 39:9,2353:9 101:3 103:20115:2 168:10 199:5209:20 210:23 227:21253:2 281:13 286:9288:5 290:2,20 320:18333:2 339:12 361:2370:11 378:9 391:22391:22 399:7 402:24407:9 420:15 440:11449:13 455:21 459:24465:4 468:4 470:1480:21 481:3 484:17503:3 508:7 513:18521:21 524:3 525:22526:10 532:5 537:8539:20 545:3 550:25555:7 560:23 565:22570:23 579:12 585:24591:8 595:1 604:8607:13 617:2 626:2635:14 639:10 642:15648:4

we're 19:23 25:10 39:444:17 45:18 48:1449:7 50:1 52:1 60:561:3 63:25,25 67:1569:8,18,24 71:3,4 72:372:25 74:12 79:2,3,4,579:9 80:4 84:9 87:3,487:8,10 96:4 105:13105:22 115:6 116:1122:7 124:11 126:9137:17 141:2 152:4157:7 160:17 163:1168:25 181:16 185:5185:18 197:25 203:6,7

203:9 205:9,10 207:17220:2 221:1,1 225:2230:21,21 235:19246:7 249:24 269:21271:6 281:10,12301:14 314:11 315:19329:25 331:12 333:2334:6,25 338:14,14339:12,13 341:14,15345:25 348:8 349:16349:17,19,21,25 350:2350:2 351:6 357:17,18357:18 367:17 368:15376:10 389:7,8,10,11394:19 396:11 401:8405:6,23 406:21407:10,17 410:13,16417:25 425:6 426:22426:25 427:16 429:9432:18 440:10 441:15442:4 456:7,10,19,19456:20,21 461:4469:12 476:9 489:19491:6 492:9,11 495:15496:25 498:5,5 511:20527:20 534:14 535:12544:9,10 545:17554:13 561:24 562:25591:19 595:16 607:20608:19 612:25 617:16619:3 623:16 628:19628:21 629:20 636:3647:17 650:18 658:23658:24 659:1

we've 60:16,20 62:9 79:579:13 105:25 154:18187:16 189:17 219:12256:15 257:4 286:5287:2,4 331:14,17332:25 333:3 346:9389:17 394:9 398:3401:9 479:5 483:10489:20 496:1 514:11562:3 563:5 564:15575:18 576:2 579:5595:9 600:20 607:12621:3 628:21 654:19654:23

weather 372:14web 604:22website 13:19 14:5,943:8 85:10 107:12120:3 132:22 144:15146:12 158:10 169:8176:19 270:7 293:2434:17 437:21

week 190:13 214:18437:1 483:15 490:24532:15 606:21 619:16642:24 649:16

weeks 58:19 180:4246:21

weigh 616:12weighed 18:5weights 466:2welcome 12:8 19:1620:1 26:4 221:13233:6 387:4 652:1



Page 58

welcomes 179:25well- 21:23well-considered 570:10went 54:4 207:16 223:15223:16 269:9 271:22348:21,23 360:6374:20 396:4 404:18404:22 561:14 650:15

weren't 374:25West 6:20 32:18 188:19188:20,21 247:5,5249:5

wet 365:10 368:24wet/dry 565:3white 180:8who've 509:8wholly 123:24wide 116:5 231:25233:13 236:1 341:16342:5 558:8 576:25

widely 200:20 467:20482:6

widespread 386:16Wiese 11:14 644:7,9,10644:18,18

Wiginton 47:7 83:20William 3:11 4:5 5:126:13 43:4 93:24,25105:2,4,10,13 169:4169:14 171:9 175:14217:2,3 244:8,8301:12,13,18,20,24

willing 562:5wind 389:24 600:19winner 26:5 30:11wire 311:5 328:4 344:7351:4 369:22 403:2413:10,18 418:25427:14 455:17 456:1461:1 463:19 466:21466:25 468:2,2,16481:10,24 489:7492:20 499:10 509:17514:16 524:8 637:7,16

wired 248:16 482:21wires 374:25 466:23,23558:15 577:3 629:13

wiring 248:17,17 297:5302:3,4 373:15 377:2377:7 382:21 385:9440:16 455:15 466:8471:4 482:10 486:10486:18 487:4 488:15488:16,22 489:8,16502:22 505:3 528:17529:2,22 547:12568:13 600:22,23,24601:1,1 613:10,11614:7 628:25 648:15648:17

wiring.' 564:18wisely 364:7wish 38:1,3 40:17,1952:23,25 63:8 65:7,970:15,17 76:10,2484:11,13 91:24 92:195:2,4 97:19,21 99:1799:19 101:13,15

103:10,11 106:8,10117:19,21 125:2,4131:25 132:2 138:4,6143:18,20 157:13,15167:24 168:1 175:24176:1 209:25 210:1211:17,19 226:21,23237:19 240:12,14253:9,10,22,24 256:12263:6,8 272:16,17273:4,7 291:13,15292:2,3 304:12,14319:25 320:24,25321:11,13 338:24339:1 352:11,13 361:7361:8,21,23 370:16,17371:6,8 378:14,15379:4,6 387:24 399:13399:14 400:1,3 411:12411:14 420:22,23421:9,11,24 424:6,8428:3,5 430:13,15439:7,9 449:18,19450:4,6 453:1,3 455:6457:18,19 464:5,7475:12,13,24 476:1479:18,19 493:11,12499:16 501:4,6 503:20503:22 504:6,8 511:6511:8 514:8 520:3,5526:2,3,14,15 536:18536:20 545:8,9,21,23555:12,13 556:1,2566:2,3,15,17 572:17572:18 573:4,6 583:10583:11,22,23 589:8,10593:2,4 596:5,7 598:8599:13,15 611:20,22624:7,9 627:18,21,23633:14,16 636:18,20640:2,4 643:12,14657:1,3

wishes 66:11 104:19227:15 228:8,21229:10 264:16 340:8480:17,24 521:3,17537:4 574:10

withdraw 65:23 195:5204:20 227:11,25228:17 264:2,12 340:2477:1 480:4 520:23521:13 574:4 581:16582:1

woman 349:24women 346:16Woo-hoo 659:15wood 127:5word 54:22 60:6 64:13306:19 311:25 347:4397:2 517:9 613:6617:16

worded 344:18 405:19536:6

wording 93:9 109:22116:25 140:19 141:3183:7,22 314:19 405:8405:24,25 429:3459:23 463:1 506:17

512:15 515:3,13 518:1words 53:24 54:10 213:8233:10 313:13 319:24346:7 389:18 419:23447:10 490:13 516:14

work 22:16,21 23:2,2024:8 31:16 34:8,2052:10 60:17,23 73:12122:23 123:1 145:25148:16 149:3 166:12168:25 180:7 187:9188:25 191:8,10195:12,13 204:1207:12 217:3 220:12223:11,20,21,22 260:5261:9 264:10 268:5271:4,8,13,13 274:16278:17 282:13,16283:11,17,18 287:5,16289:22 290:6 299:6308:5 312:7 314:1324:21 325:8,11,17328:22 334:12 346:2346:16 356:1 365:2,13373:11 381:11,24393:15 394:14,18395:3 401:17 402:13415:20 416:6 429:10469:13 523:21 561:16561:16 562:6 563:24579:8 604:18 614:11615:17 618:17 650:16653:19 654:12 657:12

workable 153:24worked 153:11 215:14267:18 271:13 277:16277:20 601:19 605:16619:1 645:5

worker 343:20workers 309:4 316:19331:1 343:13,16345:11,13 349:13404:3 411:1 416:20426:20 435:24 498:1513:25 588:2 591:15592:16

working 22:12 38:1639:3,7 60:17 64:1872:3 73:23 74:1,13185:8 186:2 188:25205:14 210:4 212:11213:5 224:24 245:23254:3,7 256:17 261:18273:21,23 277:3 287:2287:3 301:6 308:7325:7 328:24 332:22341:12,24 343:7,17344:11,20 346:1,8347:2 349:25 355:18364:4 657:8 659:11

workplace 30:19 34:18329:19 345:16

works 40:6 193:15247:22 325:8 558:12658:25

workshop 383:8workshops 276:24workspace 341:20

world 21:21 68:16140:24 141:10 195:19252:6 277:25 281:18282:4 284:13 290:1314:13 350:18 360:12369:3 389:21 463:17

worlds 370:1worn 335:13worried 505:4worries 485:11 556:14worry 185:16 650:19worse 131:1 257:21284:17

worth 186:24 188:7189:2 217:17 256:14346:7 618:3

worthiness 552:7571:16

worthy 25:18 427:19wouldn't 223:3 350:20505:22 509:1 616:22616:22

write 137:2 191:12224:17 271:24 508:22510:2

writer 419:19writing 48:12 191:9419:20 489:14

written 82:21 83:3 162:9163:8,9 167:15 226:14256:25 257:8 258:2261:8 274:21 282:13288:18 309:8 345:1347:12 443:10 508:5509:8 536:7 569:2578:11 605:25

wrong 54:22 280:19301:23 376:23,24389:11 419:12 485:18505:3 632:24 655:16655:17

wronged 417:22,23wrote 193:13 223:15234:12 251:18 252:4497:2 610:16 618:8

www.depo.com 1:20www.nfpa.org/130next120:20

www.nfpa.org/1851next147:8





www.NFPA.org/654next108:6

www.nfpa.org/70Next294:5



Wyoming 383:21,23

Xx 436:17X1 130:15

YY 346:4 403:10 404:12Ya 658:17yards 203:18Yay 209:15 211:3 340:3544:24 574:5

yeah 38:15 39:25 40:1,965:20 66:2,8 67:271:11,20 74:11,2075:14 76:22,22 104:25118:24 157:4 162:1170:18 198:17 205:8,9210:22,25 230:20254:4,8 314:19 331:18331:19,21 333:23339:20 369:14 370:7395:20 396:4,23398:24 399:1 409:24468:12 474:23 476:10477:6,10,18 499:24500:4 506:19 537:13582:21 636:5 652:7654:7 658:22 660:10

Yeah.' 505:20year 63:19,19 149:17,20150:7 155:3,4,19156:4,13 245:13,14257:8 265:25 386:10391:10 395:10,11482:20 586:8 605:24650:11

year's 20:4year-old 360:5years 21:23 26:2,2027:21 28:14 29:9 30:930:23 31:21 50:7,1050:11 64:16 90:3130:12,25 139:15141:11 149:17 154:23155:19 179:4 189:1206:23 208:13,14213:22 216:18 217:9218:11 256:7 269:9276:25 282:12,14290:2 313:15 314:2,5314:19,21 319:23338:3,4 347:3 359:2363:20,22 380:11391:7 394:16 396:20437:9 438:5 444:10461:3 483:6,16 485:21509:19 604:18 629:11639:5 645:2 654:25

years' 186:21 383:22yellow 74:5 75:11,1277:4,10,12,18,2578:11,17,19,20

yellows 77:18Yes' 38:2 40:18 52:2562:15 65:9 70:1772:18 84:13 92:1 95:497:20 99:19 101:15103:11 106:10 117:21



Page 59

125:4 132:2 138:6143:20 157:15 168:1176:1 210:1 211:18226:22 240:14 253:10253:24 263:8 272:17273:6 291:15 292:3304:14 320:25 321:12338:25 352:13 361:8361:23 370:17 371:8378:15 379:6 399:14411:14 420:23 421:11424:8 428:5 430:15439:9 449:19 450:6453:2 457:19 464:7475:13 476:1 479:19493:12 501:5 503:21504:8 511:8 520:5526:3,15 536:20 545:9545:23 555:13 556:2566:3,16 572:18 573:6583:11,23 589:10593:4 596:7 599:15611:22 624:9 627:20627:22 633:16 636:20640:4 643:14 657:3659:5

yesterday 59:16 173:12315:3 346:25 615:13

Yogi 427:1York 29:15 132:19,19,19158:7 187:11 188:19188:19,20 199:25

you.' 506:20young 349:23,24,24

Zzero 123:3 220:17394:22 579:1

Zieman 11:10 608:8,9619:23 620:1,1

Zimmerman 11:19652:22,23

zone 123:19

00 471:2 578:18

11 12:4 22:1 23:17,1924:15 109:7 110:19133:24 134:1 137:23138:3 170:11,13175:11,23 192:22,22193:11,12 213:23215:16 218:12 223:17244:2 249:23 268:4276:4 277:18 279:6280:2 284:2,8 296:19296:24 297:1,21 298:4298:19 301:14 309:15316:25 317:17 318:13326:8 327:1,16,20342:25 343:3,4,23391:10,21 422:12,13422:14 423:12 443:10466:22 485:19 486:4486:11,21 488:14,20

489:9,12,21,22 490:1490:3 492:12 528:18528:18,21 529:14530:25 531:12,23,23560:21 562:10 578:16578:21 603:25 621:11641:23 649:24

1's 562:131,000 386:12 440:161.1 213:81.10.21(A)(2) 318:121.2 240:31.3 222:14,25 223:3279:7

1.6.2 15:221.6.2(b) 36:251:25 229:191:40 229:1910 28:7 30:20 36:18108:14,18 117:8,18118:22,25 148:23201:5 282:14 293:11307:18,23 308:3,5338:4 345:14 356:4,4373:25 395:16 422:12422:20 425:24 426:3,4429:19,23 437:8 461:3469:1,7 470:15,16474:12 475:19 504:2526:22,25 596:12601:15 613:7,13,14,24613:25

10- 360:410-2 436:310% 56:2510,000 93:10100 179:4 213:22 263:13263:24 268:8 305:24308:19 318:19 326:13326:25 335:23 406:18422:20,22 470:21494:16 541:14 543:15659:17

100% 52:2,7 131:6100,000 217:21 245:8101 109:7 110:19102 123:23 168:7 399:201033 393:24104 437:13105 118:1 273:12107 371:13108 605:2109 240:1911 30:18 108:15,18117:9,18 242:14 273:1313:14 356:5 365:14566:9 589:15 640:9

110 496:13110.21 309:19 312:23328:7 334:8 417:6419:5 495:14

110.21(A) 327:4110.21(A)(2) 639:7110.26 344:12110.26(C)(2) 341:18343:5 350:8

110.26(E)(2) 349:16110.3 459:16

110.3(a) 459:23111 125:12112 291:201123 504:18,20 510:19511:5

1126 443:141182 135:6 137:19 142:51192 134:19 137:312 151:18 152:3,8156:14 157:8 256:10297:20 299:7,16300:18 302:9 303:21438:5 472:21 473:2540:19 549:14,17550:1 559:15,18 563:7564:12,13 569:24570:2 577:21,25 628:3

12's 563:312-0 539:1612-gauge 116:112.00 366:14120 95:10 222:15 354:19380:9 548:11

120- 303:21200 256:10 341:16345:25 401:15 408:3

1206 196:171218 660:5,6122 379:12123 633:21124 99:25125 160:10,16 163:2245:6 355:23

128 645:5 647:20129 132:713 22:1 45:20,25 46:3,346:10,11,17,22 47:1849:21 51:20 64:167:12 242:4 345:14370:24 468:12 549:1555:19 585:14,17,21590:22,25 591:4594:18,21 597:19,22618:18 625:16

130 37:11 87:11 109:8120:2,15,20,22,25123:14 128:14,16132:9

130-1 42:17,18,18 121:5124:17

130-2 125:16 131:12132 624:15135 352:18138 231:6,8 239:16240:11

1381 379:23 380:1381:19 399:25

1382 465:12,15 468:11468:12 475:23 476:16476:19 479:10,17

14 31:5 58:13 421:4443:22 455:17 456:8466:19 467:2 468:1,19468:21,22,23,25 469:3469:6,8,17,19,20472:19,22 473:1 474:7474:9,13 528:13 530:6530:21 531:15,20

532:23 534:3,6 572:241406 454:4,7 457:10,17458:7,10 461:14463:23 464:4

141 101:22142 78:5 292:9 362:3144 221:4 226:41445 450:20,211470 450:19 451:1452:21,25

148 157:21 244:18,181482 575:5,7 583:2115 118:10 163:9 168:13201:1 229:18 293:11339:18 346:18 380:9383:21 469:1,11,20494:13 538:6 541:20566:22 654:23

15-minute 490:1315(A) 641:22150 372:10 403:111502 481:11,13 484:25492:18 493:4,10

152 138:11154 546:3 629:191569 534:121590 567:8,14,17 568:1573:3

16 37:20,21 40:10,12293:12 443:22 468:13520:10 593:9 630:17638:14,19,20,21641:14,18 642:3,13647:13,17,19,22 655:5655:22 656:5

16's 629:8163 143:25166 221:5 226:5 277:11167 457:24169 647:2017 293:12 392:17,19449:24 468:13 504:13540:9 560:20 578:15578:21 603:25 621:11

17(A) 641:22 642:6170 65:14173 264:25 265:2 273:418 293:13 494:25 495:5501:11 502:13,18550:23 578:18,23579:1

18(A) 642:6180 77:16,17 98:31800s 650:13182 642:13183 106:16 536:251851 37:11 146:12 147:1147:8,10 149:2,15157:23

1851-1 147:13 155:6157:1

19 125:21,24 131:13,24282:6 526:8,20 545:15

1910.303 329:18192 633:211950s 369:171961 37:12 144:15 145:3145:7,9,14

1961-1 145:121970s 130:131975 444:15 482:21982 358:141985 159:211987 31:15,16,18199 138:12 536:251990 25:241991 31:5 32:151992 29:201993 30:18,201994 33:16,18,221995 34:141996 26:15,18 27:15,1929:17,21,25 32:2533:1,6

1997 27:4,13,13,14,1729:3 30:20 32:8,1433:25

1998 31:14 34:191999 22:4 26:11 27:1327:14 28:10,11,2529:2,7 32:14,15 33:13350:6

1st 180:3

22 28:5 98:21 109:21119:12 293:9 331:5353:17,18 355:9,12359:20 364:20,25365:24 368:19,21373:5 375:12 381:5,10382:18 390:23 391:5393:17 402:7,11404:24 406:7 407:1415:23 416:4 436:17443:10 481:18 485:15485:19 486:4,11,21488:14,20 489:9,12,21489:22,23 490:2,3492:9,13,22 517:6,7531:13,18 540:19543:2,12

2,000 473:12.7 66:13 145:19 227:17228:10,23 229:12264:18 340:10 480:19481:1 521:4,19 537:6573:20 574:12

20 1:8 12:3 15:21 16:228:6 36:19 37:1 90:3119:10 230:7 313:15355:23 380:10,10391:7 395:10,10401:20,21 412:11483:6 494:12 527:11538:6 541:15,17,20586:7,15

20-plus 315:720% 148:23200 461:2 494:16 502:4646:20

200-pound 164:222000 26:10 27:2,3,9 28:929:2,3 31:11,14 32:1132:12,23,24 471:2

2001 27:11,12,19 31:8,8



Page 60

2002 29:7 482:11 484:5490:22

2003 27:7,14 28:8 29:2430:5,6 32:21 34:10

2004 26:15 29:21,2430:5,7

2005 27:15 28:7,12 29:631:8,9,10,16 34:1

2006 28:6 32:21 33:212007 26:18 27:7 28:629:3,3 34:15 45:21,2546:11,21 47:18,2350:9 51:23,24 380:17482:19

2008 29:21 33:4,8 34:11433:14

2009 29:6 31:12 34:9431:22

201.8(B) 544:182010 26:14 32:10,12160:4

2011 28:10 45:22 432:1483:10 655:9

2012 28:3,23 29:1 30:1732:21

2013 27:12 32:7 33:202014 28:5 31:19 45:25196:14 207:22

2015 26:13 30:1 33:3223:20 287:5

2016 23:18 26:17 27:1130:20 180:11 215:11276:19 380:17

2017 30:3 122:22 196:15207:23 312:5 317:24318:3,16 325:23326:11 353:23 355:24363:4 372:6 380:15538:4 544:17,19652:15 653:8

2018 14:11 29:22,23204:21 205:2 207:20213:24 223:16,17244:22,23,23 257:23

2019 1:5,8 12:2,3,813:20 14:4,12 19:1419:19 20:1 30:17 34:234:3,9 35:2 36:19 37:743:22 85:18 107:21119:8,10 120:12 133:7144:24 146:23 158:20169:18 177:4 180:4230:5,7 293:22 331:10346:13 412:9,11 527:9527:11 530:10 617:11660:13,15 661:14

2019-1 37:21,22 40:1140:13

2020 160:8 270:7 288:11296:17 316:15,17319:8 391:21 401:25528:14 559:8 601:12613:8 618:21

2021 149:20 249:21286:6,17,23 431:23

2022 179:11 180:1181:18 184:1 205:18

2023 409:9

208 125:1221 150:24 659:18210 404:8210.15 407:18210.8(A)(5) 366:22210.8(B) 543:16 544:4211 53:52147 644:11,14 656:19657:1 658:3

215.10 407:19218 400:9219 144:1 636:252196 139:14,14 140:21141:23 142:12

22 206:23 453:2122% 380:1922.27 445:16220 194:122225 533:3 534:2,5,13535:11,14,16

228 132:723 42:20 121:3,6,10124:18 125:1 294:13295:2 453:21 546:14547:4 556:18 567:3

230 457:24 616:2 623:12230-70 616:15 623:13230-86 623:19230.2(A)(5) 601:4230.40 601:5230.70 615:21230.71.' 613:21230.82 601:7230.85 613:14230.95 407:19231 541:18233 92:8 659:18235 92:7237.70 614:2,8239 227:324 42:11 100:19 150:24151:19,24 154:16157:8 162:4 453:21584:3

240 349:19 353:25354:17 358:17 422:18498:10

240.2 422:18,21240.4(D) 468:24 470:16240.6(A) 469:11240.88 498:11 499:15243 84:20246 624:1425 18:3 37:11 43:7,2544:5,7 45:22 46:4,1350:20 58:14,17 59:260:1,1 61:5,16 67:1168:2,22 69:9,24 84:2288:8 130:25 141:11172:18 347:2 424:14604:18

25-1 44:10,25 45:4 52:1425-2 53:10,14 64:2225-3 65:18 66:425-4 70:625-5 80:625% 259:1,3,14250 241:19,23 242:16,17

243:12,19 244:13,20246:22 247:10 248:23249:6,17 250:20 303:3355:21 437:13 601:20602:6 603:14,19 608:6

250-24(C) 602:4250-28 602:4250.104(B) 434:6250.24 607:24 608:1250.25 601:21 607:23250.92 601:22 604:3,4251 78:326 88:18 96:16 421:16428:10

260 161:3262 84:18 157:20263 487:1327 65:2 213:7272 38:21274 106:15 546:3277 404:1328-word 265:10280 212:3282 39:17 227:4283 98:1 254:24 255:1263:1,5

285 612:2287 254:15288 450:13288-3376 1:2028th 265:2529 140:6 329:182935 307:14 309:14,16309:18,24 310:13323:22 415:14 417:1417:16

297 400:8

33 22:1 55:4,13 86:10,1291:19,23 109:21 230:9297:10 401:6,24409:14 442:13,17,18442:19 443:1,3,17,19443:22,23,25 446:21451:20,24,25 452:1,13478:19 485:16,17,17485:24 489:24 490:2492:10,23 531:25542:12 612:23 625:20631:9,13,14,16,22635:4,8,9 652:25

3's 629:63% 380:203.00 385:33.1.3 443:113.2 247:253.3.22 60:113.3.8 60:23.7 247:2530 58:19 130:11 208:13230:24 314:4 339:14339:17 359:2 363:20363:22 386:10 406:14408:1 409:15 411:23471:4 509:19 537:18537:21 538:6,10,23540:6,10,11,20,24

541:4,14 542:25545:20 573:11 586:8599:20

30-70 519:2030,000 346:18300 87:18 89:13 650:23300.5(G) 446:24 452:14452:16

300.50(F) 452:3,15301 87:4 89:9,15302 37:11 85:9,23 86:2,487:15,17 88:14 89:690:5,11 91:4 96:12104:15 106:19,21

302- 98:20302-1 86:7 91:18 96:4302-2 92:12 94:20302-3 95:14 97:10302-4 98:6 99:10302-5 100:4 101:7302-6 101:25 102:23103:2

302-7 103:21 104:22105:19

305 440:10,14 442:2549:1 552:11 557:23561:20 569:20 576:15579:22

307 168:6 493:1731 103:17 521:1310.16 466:6 471:1310.17 466:6 471:7310.3 472:20310.3(A) 472:21315 612:12,15 623:25624:7

316 211:24317 583:1632 304:19 453:8 556:732% 380:20320 101:20326 254:17327 464:12328 643:1933 162:3 272:24 321:73314 530:233318 530:243330 442:19337 640:10338 421:3339 453:1034 65:1342 526:7345 449:23346 176:6 573:12347 99:24348 41:3349 476:635 186:21 208:14 256:735.00 385:2350F 440:11353 421:17355 566:8 584:4356 118:2 479:24 572:23628:4

364 545:14369 430:2237 147:18 155:9 157:2

157:12 275:15 277:6,9370 95:9 504:2372 428:11 556:8373 555:18374 65:16376 424:13380 599:21381 511:13382 566:23385 352:20 439:15386 399:19387 475:18 526:20388 593:1039 361:1539% 380:21391 589:16398 632:5399 240:20

44 22:1 55:5 92:16,1994:21 95:1 136:7145:18 172:24 173:18174:5,13 175:4 356:4412:13 436:17 485:16485:16,17,18 489:24490:2 492:10,23601:14 602:17,23,25608:11 610:13 615:10620:4,22 622:5,13646:2

4' 171:1,44.1.6.1 88:7 94:14,144.12 258:174.4.1 237:144.4.4.2 414:14.4.4.8.3.1 414:74.4.8.1(D) 414:104.4.8.3.1(A) 266:144.4.9.2 266:84.5.3 15:174.5.3.7 145:184.6 15:174.6.2 242:134.7 15:14,184.9 258:16,184.9.3 258:224.9.3.2 258:194:20 339:1940 66:22 67:1,10,21 70:770:14 76:9 123:12165:12 191:18 220:17223:14 286:19 314:2,4629:2

40% 56:2540,000 63:18400 245:6 386:10 553:13596:13

400,000 515:10401 501:11 520:10402 362:5 379:14403 504:13405 273:14408 53:7 517:1641 396:20410 212:14,17 225:20226:20

411 411:20



Page 61

414 371:154161 90:2142 53:15,17 64:23 65:6202:3 430:20

42% 136:11431 41:1439 263:15444 439:23,25 450:3445 450:21,22 451:1452:21,25

446 103:16448 232:1144831(A) 242:2245 21:23450 88:10 89:8 91:2454 178:1,3 197:23198:5 199:21 211:16

457 386:1146 63:19 511:13468 38:20 292:1147 202:4 411:1948 245:5480 245:7 248:7 346:4404:12

482 361:14484 339:849 45:3,6 52:15,22636:11

490 517:13,16497 378:23499 370:23

55 36:23 95:18,21 97:1197:18 98:10,13 99:1199:16 241:6 275:5293:10 433:6,9,13,16434:2 485:16,17,17,18489:24 490:2 492:10492:24 527:13 601:15601:18 607:21 608:20609:4 649:24

5% 47:19 55:17,19 56:1856:25

50 50:9,11 160:22,24,25223:15 224:9 241:23242:16 243:19 244:13244:20 246:9,10,22247:22 248:4,8 249:2249:16,20,24 250:9252:9,12 259:19 285:4285:6 303:3 314:5355:23 372:10 397:22487:16 538:6,10540:10,11,20,24 541:5541:14 542:25 544:18645:24

50% 149:1500 634:8,13 635:24636:11,17

500,000 201:25000 109:8 110:20501 533:5 628:11,13631:16 633:7,13

501.10 535:15502 37:11 122:23 123:16124:10 132:22 133:10133:15,18 136:9,11

140:1,18 141:14 142:1144:3

502-1 133:21 137:22502-2 138:15 142:16143:10

503 321:1951 176:6516 640:17,20 642:4643:5,11

517.17 407:2252 244:2528 45:19529 321:653 292:18531 277:3534 220:25 226:1,154 160:11,15,21,24161:16 162:12,22,24163:6,22,25 164:11165:11 166:25 167:17202:22 431:18,22432:5,16 434:2,12,15434:16,23 435:18438:12

542 304:20546 253:15548 211:7 291:19 646:255 182:14 479:24551 542:13 543:4551.2 539:11 541:1356 160:12,22 161:6,17162:7,8,23,24 163:6163:25,25 164:11165:4,12 166:5 202:22400:23

560 272:2357 400:23,2458 37:11 158:9,23 159:2159:5,21 160:5 161:8162:11,22,25 163:9,22164:1 167:15 168:9

58-1 159:8 166:15167:11

5th 37:6

66 100:8,10 101:8,12138:20,23 143:11,17204:18 295:9,18 296:5439:14 454:25 455:2,7456:2,3 459:8,12463:13 467:14,18,21467:23 468:18 469:16470:17 471:1 474:11478:18,22 483:25484:4 485:14 601:8623:12

6,600 386:86:30 400:1560 81:1 84:9 466:16471:2 474:12 494:15502:3 630:16 634:22

600 403:11,11 466:24,24601 486:236025.60 575:21 576:8603 486:24,25603.1.3 487:3625 297:20 302:10,14,16

302:19 549:18 559:19560:6 570:3 578:1

625-60 550:3625.1 550:3 558:20564:16 577:11

625.2 558:18 577:10625.5 569:3625.60 295:21 548:9558:18 575:15 576:24577:10 578:13

63 67:863,000 201:265 339:6654 37:11 107:12,24108:5,8 110:2,11116:5 118:5 197:24199:21

654-1 108:11 117:768 250:19 257:18 476:6651:9

69 159:13 166:16 167:12167:23 250:19 257:18

6th 37:6

77 22:1 102:4,7 103:3,9103:25 104:2 105:20106:7 339:15 378:24411:25 455:1 459:7467:13 478:17,22483:25 484:14 487:9539:3,16 540:3,13622:4

7-17 431:37.1.4.1 110:270 21:24 37:11 42:7179:8 183:8 190:7202:24 204:10 215:16222:14 268:4 277:18293:1,25 294:4,7305:16 322:9 431:19453:12 480:22 583:17604:22 659:20

70- 361:17 480:14520:25 636:10

70-1 294:10 295:5 304:5351:18 562:13

70-10 371:18 379:170-11 379:17 399:22416:7

70-12 400:17 410:10411:5

70-13 413:7 421:670-14 421:21 423:1770-15 424:18 427:1170-16 428:15,1770-17 430:25 438:2570-18 439:19 450:270-19 450:16 452:2070-2 42:7 305:1 546:7,9546:11

70-20 42:10,14 453:22465:5 472:23 473:5474:8 480:2,15

70-21 42:14 453:21,24457:9

70-22 42:14 458:2463:22

70-23 42:14 464:15,18465:4 476:9,11 479:9

70-24 42:14 464:18465:1,3,7 472:17473:6

70-25 480:2270-26 481:7 492:17493:3

70-27 493:20 500:2170-28 501:1470-29 504:16,18 510:1970-3 42:8 305:2 574:17574:25

70-30 511:16,20 598:1070-31 520:13,1470-32 521:9,1570-33 521:2470-34 536:1070-35 537:270-36 42:8 305:1 537:1170-37 556:1070-38 566:2570-39 573:14,16,1970-4 305:5 306:23 321:970-40 42:9 305:3 573:25574:7

70-41 584:7,9 588:2470-42 589:18,20 592:1970-43 593:12 595:2270-44 596:15,18 599:470-45 599:23 611:1070-46 612:6 623:2470-47 624:18,21 627:1070-48 628:7 633:670-49 633:24 635:2370-5 321:23 322:7330:17 335:5 337:4

70-50 637:4 639:2070-51 640:13 643:470-52 644:6 656:18659:18

70-6 339:10,24 340:570-7 340:13,14,1870-8 352:2370-9 362:8 366:20 371:170.1 554:19,20,2070.12 400:2170.14 424:2170.28 501:1670.30 511:2070.32 521:1270.33 522:270.4 305:1770.43 593:2170.5 340:2700 592:4701 591:20702 591:20702.5 597:1703.2 487:9703.3 487:137036 540:5705 600:16 603:2 616:16705-11(D) 601:24705.11 612:23705.11(B) 611:1,4705.11(D) 610:4,15708 591:20

70E 345:15,1571 321:18 323:3,6 326:3326:6 330:19 337:5338:23 464:12 553:15623:13

72 67:12 68:10,11,12,1568:17,19 69:7,10,1269:13 172:11,18,19259:10 553:16 623:13

721 454:17725 629:1,6,25 632:7,10634:23 636:3

725-34 467:2735 630:16737 214:13 303:1075 91:1 241:3 244:13,17245:2 253:16,21305:15 322:10 466:16471:3

75-34 527:21750,000 214:3 217:67509 637:8,11 638:21639:21 640:1

7517 624:21,23 627:11627:17

7522 584:9,11 587:17588:25 589:7

7584 589:21,23 592:20593:1

7586 593:21,24 595:23596:4

7588 596:19,22 599:5,1376 531:11760 629:1,6,25 632:7,10636:3,6

7609 530:23 531:117656 400:227657 401:2 411:6,11413:11,13 421:8

7676 371:21,23 374:11379:3

7697 353:3,9 356:17361:19 362:12,16371:4

770 629:1,8,17 632:77705 353:5,10 356:18361:20 362:13,17371:5

7736 466:197739 466:197746 642:77776 546:19,23 550:23555:24

7783 556:19,23 557:3560:20 566:13

7796 578:147798 578:167799 578:1878 361:20780 433:19 434:23 435:7437:9,13 438:4,6

7800 578:217801 578:247891 294:17,20 304:6,1179 258:167974 424:21,23 427:12428:2

7979 528:2,5 529:25



Page 62

536:11,187th 37:7

88 28:11 293:10 361:18639:1,6 645:1 648:1

8.1 541:208.3.7.2.3 56:380 501:20800 1:20 629:1,17,18,18632:7 641:25 642:1646:12 647:21

800-182 642:9800-182(A) 642:14800.182(A) 641:23800.3(G) 639:8800.48 652:15801 37:11 169:8,21170:1,4 176:8 184:15

801-1 170:7,10 175:118014 641:21804 649:4804-48 645:228048 428:20,22 430:12805 629:2,18 642:2645:22

805-179 645:15,25805-182 642:8805.179 649:2,4805.182(A) 642:6805.48 649:58072 305:19 306:2 317:2321:10

8074 421:25 422:2423:14,18 424:5

808 431:4,6,16 432:15434:10 438:25 439:6

81-59 611:118104 340:19,25 341:6351:19 352:11

8119 353:5,10 356:18361:20

8120 362:13,17 371:58159 600:3,6 611:188164 521:128172 511:21,23 514:2519:21 520:2

8187 493:25 494:2495:20 500:22 501:3

8189 501:18,20 504:6820 629:2,188222 522:2,4 526:12830 629:2,19 655:22656:7,7

833 245:78385 546:20,24 555:2584 87:25 90:6840 629:19 654:15 655:7656:11

840.160 647:24 648:2649:1

840.48 646:20 647:21648:12 652:15

841 646:2841-60 646:1841.60 653:7,20844 221:385-0-1 186:19

850 184:15 198:10 256:8851 184:16855 37:11 176:19 177:6177:12,14 179:10,16179:19 180:22 181:3181:23 182:21 183:10183:11,19,20,22189:10,15 192:9193:12,14,23 194:18195:6,10 199:6 200:14200:23 201:11 213:14214:20 215:11,23216:2,19 218:14219:20 223:21 224:17229:18 231:19 233:23235:5 241:21 244:25245:16,22 247:7,15250:3 252:1 256:8,24258:17 265:9 266:25268:9 270:8,10 273:24274:15,21,23 275:5276:5,8,19 278:5,19278:25 279:3,6,6,12279:17 280:1 281:3283:17,25 284:7 286:6286:13,16 287:23,25288:15,16,18 292:13

855- 254:23 272:25855-1 177:17 180:17195:6

855-10 263:18,23 264:14855-11 264:22855-12 273:17 291:23855-2 212:6 225:19855-3 227:8,12855-4 227:21,22 228:5855-5 228:14,18855-6 229:3,7855-7 231:2 239:15855-8 240:24 247:6855-9 254:20 262:258560 331:78597 556:20,24 566:1486 623:138608 600:4,8 611:12,19868 257:2869 257:287 211:7875 220:25 221:2 226:2275:15 277:4

888 531:989 493:17

99 25:24 108:15,18 117:9117:18 159:10 254:24293:10 487:9 507:13507:16 512:22,25513:3 514:7 516:23517:7 523:14,17,20,23643:20

9-1-1 12:17 35:1090 69:18,21 70:2 127:9296:19 297:10 346:10346:11 466:17 471:3560:5 562:14 565:7629:15 637:1

90- 68:6

90-2 295:9,25 296:590% 130:1290.1 547:1490.1(A) 297:2490.2 302:12 558:20577:12

90.2-A 553:1890.2(A) 296:15 297:290.2(A)(6) 297:1590.3 309:20 539:1543:22 639:6

900 12:19 35:13 202:290A 553:18 629:12,15630:10

912 178:1,3 211:1695-40 216:795-40A 187:1295% 54:12 441:69540A 257:159548 248:2296 612:3979 638:2098 109:899 450:119th 661:14

Documents

Atkinson-Baker, Inc