# Energy Conservation Program for Consumer Products: Test Procedure for Residential Clothes Washers

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URL: https://www.frixlaw.com/law-library/documents/fr%3A2010-22225

## Record

- **Collection:** Federal Register
- **Document type:** Proposed Rule
- **Published:** September 21, 2010
- **Citation:** 75 FR 57556

## Text

DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket No. EERE-2010-BT-TP-0021]
RIN 1904-AC08
Energy Conservation Program for Consumer Products: Test Procedure for Residential Clothes Washers

AGENCY:

Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION:

Notice of proposed rulemaking (NOPR) and public meeting.

SUMMARY:

The U.S. Department of Energy (DOE) proposes amending its test procedure for residential clothes washers under the Energy Policy and Conservation Act to provide for measuring standby mode and off mode energy consumption, and to update the active mode test procedure. DOE is also proposing to eliminate an obsolete clothes washer test procedure currently codified in the Code of Federal Regulations, and is announcing a public meeting to discuss and receive comments on the issues presented in this NOPR.

DATES:

DOE will hold a public meeting on Thursday, October 28, 2010, from 9 a.m. to 4 p.m., in Washington, DC. DOE must receive requests to speak at the public meeting before 4 p.m., Thursday, October 14, 2010. DOE must receive a signed original and an electronic copy of statements to be given at the public meeting before 4 p.m., Thursday, October 21, 2010.

DOE will accept comments, data, and information regarding the NOPR before and after the public meeting, but no later than December 6, 2010. For details, see section V, “Public Participation,” of this NOPR.

ADDRESSES:

The public meeting will be held at the U.S. Department of Energy, Forrestal Building, Room 1E-245, 1000 Independence Avenue, SW., Washington, DC 20585-0121. To attend the public meeting, please notify Ms. Brenda Edwards at (202) 586-2945. Please note that foreign nationals visiting DOE Headquarters are subject to advance security screening procedures. Any foreign national wishing to participate in the meeting should advise DOE as soon as possible by contacting Ms. Edwards to initiate the necessary procedures.

Any comments submitted must identify the NOPR on Test Procedures for Residential Clothes Washers, and provide the docket number EERE-2010-BT-TP-0021 and/or regulatory information number (RIN) 1904-AC08. Comments may be submitted using any of the following methods:

1.
Federal eRulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting comments.

2.
E-mail: RES-CW-2010-TP-0021@ee.doe.gov.
Include docket number EERE-2010-BT-TP-0021 and/or RIN 1904-AC08 in the subject line of the message.

3.
Mail:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Please submit one signed original paper copy.

4.
Hand Delivery/Courier:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 6th Floor, 950 L'Enfant Plaza, SW., Washington, DC 20024.
Telephone:
(202) 586-2945. Please submit one signed original paper copy.

For detailed instructions on submitting comments and additional information on the rulemaking process, see Section V, “Public Participation,” of this document.

Docket:
For access to the docket to read background documents or comments received, visit the U.S. Department of Energy, Resource Room of the Building Technologies Program, 6th Floor, 950 L'Enfant Plaza, SW., Washington, DC 20024, (202) 586-2945, between 9 a.m. and 4 p.m., Monday through Friday, except Federal holidays. Please call Ms. Brenda Edwards at the above telephone number for additional information about visiting the Resource Room.

FOR FURTHER INFORMATION CONTACT:

Mr. Stephen L. Witkowski, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone: (202) 586-7463. E-mail:
mailto:Stephen.Witkowski@ee.doe.gov.

Ms. Jennifer Tiedeman, U.S. Department of Energy, Office of the General Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone: (202) 287-6111. E-mail:
mailto:Jennifer.Tiedeman@hq.doe.gov.

For information on how to submit or review public comments and on how to participate in the public meeting, contact Ms. Brenda Edwards, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone: (202) 586-2945. E-mail:
Brenda.Edwards@ee.doe.gov.

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Background and Legal Authority

II. Summary of the Proposal

III. Discussion

A. Products Covered by This Test Procedure Change

B. Compliance Date of Proposed Test Procedure

C. Standby Mode, Off Mode, and Additional Active Mode Test Procedures

1. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power Consumption

2. Determination of Modes To Be Incorporated

3. Adding Specifications for the Test Methods and Measurements for Standby Mode, Off Mode, and Additional Active Mode Testing

4. Calculation of Energy Use Associated With Each Operating Mode

5. Measures of Energy Consumption

D. Clothes Washer Active Mode Test Procedure

1. Technologies Not Covered by the Current Clothes Washer Test Procedure

a. Steam Wash Cycles

b. Self-Clean Cycles

c. Adaptive Control Technologies

d. Demand Response Technology

2. Changes to Reflect Current Usage Patterns and Capabilities

a. Representative Annual Cycles

b. Test Load Size Specifications

c. Use Factors

3. Test Cloth

4. Other Revisions and Clarifications

a. Clothes Washer Capacity Measurement Method

b. New Measure of Water Consumption

c. Energy Test Cycle

d. Detergent Specifications for Test Cloth Preconditioning

e. Clothes Washer for Test Cloth Preconditioning

f. Water Supply Pressure

g. Additional Revisions and Clarifications

5. Test Procedure Performance Specifications

E. Compliance With Other EPCA Requirements

1. Test Burden

2. Integration of Standby Mode and Off Mode Energy Consumption Into the Efficiency Metrics

3. Commercial Clothes Washers

F. Impact of the Proposed Amendments on EnergyGuide and ENERGY STAR

G. Elimination of the Obsolete Clothes Washer Test Procedure

IV. Procedural Requirements

A. Review Under Executive Order 12866

B. Review Under the Regulatory Flexibility Act

C. Review Under the Paperwork Reduction Act of 1995

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under the Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Review Under Section 32 of the Federal Energy Administration (FEA) Act of 1974

V. Public Participation

A. Attendance at Public Meeting

B. Procedure for Submitting Requests to Speak

C. Conduct of Public Meeting

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

1. Incorporation of IEC Standard 62301

2. Clothes Washer Modes

3. Default Settings

4. Delay Start Mode

5. Test Room Ambient Temperature

6. Energy Use Calculation

7. New Integrated Measures of Energy Consumption and Energy Efficiency

8. Annual Energy Cost Calculation

9. Steam Wash Cycles

10. Self-Clean Cycles

11. Adaptive Control and Demand Response Technologies

12. Representative Number of Annual Cycles

13. Test Load Size Specifications

14. Use Factors

15. Test Cloth

16. Capacity Measurement Method

17. New Integrated Measure of Water Consumption

18. Energy Test Cycle Definition

19. Detergent Specifications

20. Clothes Washer for Preconditioning

21. Water Supply Pressure

22. Impact on Commercial Clothes Washers

VI. Approval of the Office of the Secretary

I. Background and Legal Authority

Title III of the Energy Policy and Conservation Act (42 U.S.C. 6291
et seq.
) (EPCA or the Act) sets forth a variety of provisions designed to improve energy efficiency. Part A of Title III (42 U.S.C. 6291-6309) establishes the “Energy Conservation Program for Consumer Products Other Than Automobiles,” which covers consumer products and certain commercial products (all of which are referred to below as “covered products”). These include residential clothes washers, the subject of today's notice. (42 U.S.C. 6292(a)(7))

Under the Act, this program consists essentially of three parts: (1) Testing, (2) labeling, and (3) Federal energy conservation standards. The testing requirements consist of test procedures that, pursuant to EPCA, manufacturers of covered products must use as the basis for certifying to DOE that their products comply with the applicable energy conservation standards adopted under EPCA and for representations about the efficiency of those products. DOE also must use these test requirements to determine whether the products comply with EPCA standards. Section 323 of EPCA (42 U.S.C. 6293) sets forth criteria and procedures for DOE's adoption and amendment of such test procedures. EPCA provides that “[a]ny test procedures prescribed or amended under this section shall be reasonably designed to produce test results which measure energy efficiency, energy use * * * or estimated annual operating cost of a covered product during a representative average use cycle or period of use, as determined by the Secretary [of Energy], and shall not be unduly burdensome to conduct.” (42 U.S.C. 6293(b)(3)) In addition, if DOE determines that a test procedure amendment is warranted, it must publish proposed test procedures and offer the public an opportunity to present oral and written comments on them. (42 U.S.C. 6293(b)(2))

Finally, in any rulemaking to amend a test procedure, DOE must determine “to what extent, if any, the proposed test procedure would alter the measured energy efficiency * * * of any covered product as determined under the existing test procedure.” (42 U.S.C. 6293(e)(1)) If DOE determines that the amended test procedure would alter the measured efficiency of a covered product, DOE must amend the applicable energy conservation standard accordingly. In determining the amended energy conservation standard, the Secretary shall measure, pursuant to the amended test procedure, the energy efficiency, energy use, or water use of a representative sample of covered products that minimally comply with the existing standard. The average of such energy efficiency, energy use, or water use levels determined under the amended test procedure shall constitute the amended energy conservation standard for the applicable covered products. (42 U.S.C. 6293(e)(2)) EPCA also states that “models of covered products in use before the date on which the amended energy conservation standard becomes effective (or revisions of such models that come into use after such date and have the same energy efficiency, energy use, or water use characteristics) that comply with the energy conservation standard applicable to such covered products on the day before such date shall be deemed to comply with the amended energy conservation standard.” (42 U.S.C. 6293(e)(2))

The DOE test procedure for clothes washers currently being manufactured is found at 10 CFR part 430, subpart B, appendix J1. DOE adopted appendix J1 in 1997 to correct for changes in consumer habits that resulted in an overstatement of average annual energy consumption when using the methods specified in appendix J. 62 FR 45508 (Aug. 27, 1997). DOE added appendix J1, rather than amending appendix J, to accommodate continued use of appendix J until DOE amended the residential clothes washer conservation standards to reference the new appendix J1. On January 12, 2001, DOE published a final rule (hereinafter referred to as the January 2001 final rule), to amend the energy conservation standards for residential clothes washers to reference the efficiency metrics as defined in appendix J1. 66 FR 3314. Use of the amended J1 test procedure was required to demonstrate compliance with these amended energy conservation standards as of January 1, 2004. Since 1997, DOE has amended the test procedure in appendix J1 three times, twice substantively to address test cloth correlation procedures, and once to correct the introductory note. 63 FR 16669 (Apr. 6, 1998); 66 FR 3330 (Jan. 12, 2001); 68 FR 62204 (Oct. 31, 2003). One of these amendments also included an amendment to Appendix J. 66 FR 3330 (Jan. 12, 2001). Because appendix J applies only to clothes washers manufactured before January 1, 2004, however, appendix J is now obsolete. 10 CFR 430 appendix J1.

The current applicable test procedure includes provisions for determining the modified energy factor (MEF) for clothes washers, which is a function of the total energy used for each cubic foot (ft
3
) of clothes washer capacity. The test procedure measures the total energy consumption of the clothes washer. It also accounts for the amount of energy required to heat the water and subsequently dry the load based on the remaining moisture content (RMC) of the clothes at the completion of the machine's full cycle. The test procedure does not currently address energy use in the standby or off modes.

Clothes washer energy conservation standards were originally established by the National Appliance Energy Conservation Act of 1987, which amended EPCA to prescribe that clothes washers manufactured on or after January 1, 1988, have an unheated rinse option. (42 U.S.C. 6295 (g)) The amendments to EPCA also required DOE to conduct a rulemaking by January 1, 1990, to determine if the above mentioned standards should be amended. A final rule was issued on May 14, 1991, (hereinafter referred to as the May 1991 final rule) establishing the first set of performance standards for residential clothes washers. Compliance with these standards was required for products manufactured on or after May 14, 1994. 56 FR 22279. EPCA also

required DOE to conduct a subsequent rulemaking no later than 5 years after the date of publication of the previous final rule to determine whether to amend those standards. A final rule establishing revised standards for residential clothes washers was published in the January 2001 final rule. 66 FR 3313. The January 2001 final rule required all new residential clothes washers manufactured after January 1, 2007 to be 35 percent more efficient than clothes washers minimally compliant with the efficiency standards established in the May 1991 final rule.

The Energy Independence and Security Act of 2007 (EISA 2007), Public Law 110-140, amended EPCA and, in relevant part, revised the energy conservation standards for residential clothes washers. The revised standards established a maximum water consumption factor (WF) of 9.5, effective January 1, 2011. EISA 2007 further required that DOE publish a final rule no later than December 31, 2011 determining whether to amend the standards in effect for clothes washers manufactured on or after January 1, 2015. (42 U.S.C. 6295(g)(9)) Consequently, DOE is conducting a separate standards rulemaking for these products.

The EISA 2007 amendments to EPCA also direct DOE to amend its test procedures to integrate measures of standby mode and off mode energy consumption into the overall energy efficiency, energy consumption, or other energy descriptor for each covered product unless the current test procedure already fully accounts for and incorporates standby and off mode energy consumption or such integration is technically infeasible. If an integrated test procedure is technically infeasible, DOE must prescribe a separate standby mode and off mode energy use test procedure for the covered product, if technically feasible. (42 U.S.C. 6295(gg)(2)(A))

Any such amendment must consider the most current versions of the International Electrotechnical Commission (IEC) Standard 62301, “Household electrical appliances—measurement of standby power,” First Edition 2005-06, and IEC Standard 62087, “Methods of measurement for the power consumption of audio, video, and related equipment,” Second Edition, 2008-09.
1 2

In developing these test procedure amendments for clothes washers, DOE initially determined that it would consider a revised IEC Standard 62301 expected to be released in July 2009. DOE subsequently found that this revision is expected to be delayed until late-2010, so DOE determined it appropriate to proceed with an amended test procedure based on the current version of IEC Standard 62301, First Edition 2005-06. DOE is also considering a draft version of IEC Standard 62301, Final Draft International Standard (IEC Standard 62301 FDIS), for updated mode definitions, which are expected to be included in the final revised IEC Standard 62301, Second Edition.

1
IEC standards are available online at
http://www.iec.ch.

2
Multiple editions of this standard are referenced in this notice. Unless otherwise indicated, the terms “IEC Standard 62301” or “IEC Standard 62301 First Edition” refer to “Household electrical appliances-measurement of standby power,” First Edition 2005-06.

On August 28, 2009, DOE published a notice in the
Federal Register
announcing the availability of a framework document to initiate a rulemaking to consider amended energy conservation standards for residential clothes washers (hereafter the August 2009 framework document). 74 FR 44306. In the August 2009 framework document, DOE requested comments on the merits of revising the clothes washer test procedure, and sought input regarding how the test procedure could be improved. DOE held a public meeting on September 21, 2009 (September 2009 public meeting). In addition, DOE requested written comments, data, and information on the August 2009 framework document, which it accepted through September 28, 2009.

DOE received comments in response to the August 2009 framework document stating that it should consider changes to the active mode test procedure. As a result, in addition to amending its test procedure for clothes washers to include measures for standby and off mode power consumption, DOE proposes to address issues regarding the active mode provisions of the test procedure.

II. Summary of the Proposal

In today's NOPR, DOE proposes amending the test procedure for clothes washers to assist DOE in the concurrent development and implementation of standards that address use of standby mode and off mode power by these products. Specifically, DOE proposes to integrate measures of standby mode and off mode power consumption, as well as measures of power consumption in certain additional modes determined to be part of active mode, into the test procedure. DOE also proposes, for the measurement of energy use in active mode, to: (1) Adopt technical changes and procedures for accurately measuring the energy consumption of clothes washers with technologies not covered by the current procedure; (2) more accurately reflect current consumer behavior and clothes washer capabilities; (3) address issues related to the test cloth, detergent, and certain test equipment; (4) revise and clarify the existing methods and calculations; and (5) delete obsolete appendix J to subpart B of CFR part 430 and references thereto. The following paragraphs summarize these proposed changes.

To integrate measures of standby mode and off mode power consumption into the test procedure, DOE proposes to incorporate by reference into the clothes washer test procedure specific provisions from IEC Standard 62301 regarding test conditions and test procedures for measuring standby mode and off mode power consumption. DOE also proposes to incorporate into the test procedure the definitions of “active mode,” “standby mode,” and “off mode” that are based on the definitions provided in IEC Standard 62301 FDIS. Further, DOE proposes to include in the test procedure additional language that would clarify the application of clauses from IEC Standard 62301 for measuring standby mode and off mode power consumption.
3

In addition, DOE proposes to incorporate energy consumption associated with delay start and cycle finished modes. Although these modes would be considered part of active mode, the measurements and calculations proposed for them are similar to those proposed for standby and off modes. DOE also proposes to: (1) Establish a new measure of energy use to calculate the per-cycle standby mode, off mode, delay start mode, and cycle finished mode energy consumption; and (2) adopt a new measure of energy efficiency (integrated modified energy factor (IMEF)) that includes the energy used in the active, standby, and off modes. As indicated above, DOE energy conservation standards currently do not address the energy use of clothes washers in the standby or off modes. Section 325(gg)(2)(C) of EPCA provides that amendments to the test procedures to include standby and off mode energy

consumption will not be used to determine compliance with previously established standards. (42 U.S.C. 6295(gg)(2(C)).

3
EISA 2007 directs DOE to also consider IEC Standard 62087 when amending its test procedure to include standby mode and off mode energy consumption.
See
42 U.S.C. 6295(gg)(2)(A). DOE considered IEC Standard 62087 and concluded that because IEC Standard 62087 addresses the methods of measuring the power consumption of audio, video, and related equipment, the narrow scope of this particular IEC Standard reduces its relevance to today's proposal. Further details are provided later in this notice.

For the measurement of active mode energy use other than in delay start and cycle finished modes, DOE proposes to:

(1) Update the test procedure to address technologies not covered by the current procedure, based upon comments from interested parties in response to the August 2009 framework document and further review by DOE. These technologies include steam wash and self-cleaning cycles. Steam wash cycles inject steam into the wash basket, and claim to offer more effective cleaning. Self-clean cycles enable consumers to intermittently, typically once per month, run a self-clean cycle to prevent odor, bacteria, and mildew from building up in the clothes washer. DOE proposes to amend the test procedure to measure energy use in steam and self-clean cycles. DOE also received comments regarding demand response technologies, and investigated adaptive controls other than adaptive fill control. Demand response features enable an appliance to shift its activity based on interaction with the electric grid, utilities, or user programming. Adaptive controls enable a clothes washer to adjust parameters such as agitation speed, number of rinses, wash time, and wash and rinse temperatures based on the size, fabric mix, and soil level of a wash load. However, for reasons discussed in sections III.D.1.c and III.D.1.d, DOE is not proposing to update the test procedure to include provisions for measuring the energy consumption of clothes washers offering demand response technologies or adaptive controls other than adaptive fill control.

(2) Amend the test procedure for clothes washers to reflect current usage patterns and capabilities. DOE received multiple comments on this issue in response to the August 2009 framework document, and reviewed current consumer data from surveys conducted in 2004 and 2005 to determine whether such updates are appropriate. The proposed amendments address the following specific issues: Representative average-use cycles per year for a clothes washer, test load size specifications, and consumer use factors. The proposed amendments are based on recent data that more accurately describe current consumer behavior and updated clothes washer capabilities.

(3) Amend the test procedure to update the procedure and specifications for determining test cloth correlations, change the tolerances regarding the size and weight of the test cloth, and revise the detergent and preconditioning clothes washer specifications due to obsolescence or anticipated obsolescence of the existing test materials and equipment specified in the test procedure. These proposed amendments are based on multiple comments received in response to the August 2009 framework document and at the September 2009 public meeting regarding the test cloth used in the current test procedure.

(4) Update the test procedure to clarify or revise the existing methods and calculations for measuring clothes container capacity, calculating water consumption factor, determining the energy test cycle, and setting the supply water test conditions. The current capacity measurement provisions can be interpreted in multiple ways. Different allowable interpretations of the maximum water fill level used for the measurement can produce inconsistent results that may not accurately reflect the actual usable volume of a clothes washer. The proposed revisions revise the capacity measurement specifications so that interpretations are more likely to be uniform, repeatable, and representative, thereby ensuring the data is reported consistently. DOE proposes to adopt a new measure of water consumption, integrated water consumption factor (IWF) that would include water used in self-clean cycles. The IWF would also include water consumption from all energy test cycles, rather than only from the cold wash/cold rinse cycle as the test procedure currently requires. DOE also proposes to clarify the energy test cycle definition and the supply water test conditions specification.

DOE has also investigated how each of the proposed amendments to the active mode provisions for clothes washers, discussed above would affect the measured efficiency of products. See section III.D for further details. Because of the potential for significant impacts to the measured efficiency of products, DOE proposes to codify the amended clothes washer test procedure as appendix J2 in 10 CFR part 430 subpart B. Manufacturers would not be required to use appendix J2 to demonstrate compliance with clothes washer energy conservation standards until the compliance date of new standards, which would take into account any test procedure amendments. Until that time, manufacturers would be required to use existing appendix J1.

Finally, DOE proposes to delete appendix J to subpart B of CFR part 430, along with all references to appendix J in 10 CFR part 430.23. Appendix J only applies to clothes washers manufactured before January 1, 2004, and is now obsolete. Appendix J1 would retain its current designation and not be re-designated as Appendix J.

III. Discussion

A. Products Covered by This Test Procedure Change

Today's proposed amendments to the DOE test procedure cover residential clothes washers, which DOE's regulations define as follows:

Clothes washer
means a consumer product designed to clean clothes, utilizing a water solution of soap and/or detergent and mechanical agitation or other movement, and must be one of the following classes: automatic clothes washers, semi-automatic clothes washers, and other clothes washers.

Automatic clothes washer
means a class of clothes washer which has a control system which is capable of scheduling a preselected combination of operations, such as regulation of water temperature, regulation of the water fill level, and performance of wash, rinse, drain, and spin functions without the need for user intervention subsequent to the initiation of machine operation. Some models may require user intervention to initiate these different segments of the cycle after the machine has begun operation, but they do not require the user to intervene to regulate the water temperature by adjusting the external water faucet valves.

Semi-automatic clothes washer
means a class of clothes washer that is the same as an automatic clothes washer except that user intervention is required to regulate the water temperature by adjusting the external water faucet valves.

Other clothes washer
means a class of clothes washer which is not an automatic or semi-automatic clothes washer. 10 CFR 430.2.

DOE is not proposing any amendments to these definitions in today's NOPR. The clothes washers covered by these definitions, and by today's proposed amendments, include top-loading compact (less than 1.6 ft
3
capacity); top-loading standard size (1.6 ft
3
or greater capacity); top-loading, semi-automatic; front-loading; and suds-saving clothes washers.

B. Compliance Date of Proposed Test Procedure

As stated previously, DOE originally considered reviewing a revised IEC Standard 62301, expected to be released in July 2009, in the development of these test procedure amendments. DOE received comments in response to the August 2009 framework document

jointly from the Appliance Standards Awareness Project (ASAP), the Natural Resources Defense Council (NRDC) and the National Consumer Law Center (NCLC) (Joint Comment); and the Alliance to Save Energy (ASE), stating that the IEC 62301 revision process may take longer than previously thought and that DOE should proceed with updating the clothes washer test procedure. (Joint Comment, No. 14 at p. 1
4

; ASE, No. 22 at p. 1) Additionally, Northeast Energy Efficiency Partnerships (NEEP) commented that waiting for the IEC process to finalize could be detrimental to the standards rulemaking, and that DOE should consider quickly revising the test procedure independently after the IEC procedure is finalized. (NEEP, No. 20 at p. 1)

4
A notation in the form “Joint Comment, No. 14 at p. 1” identifies a written comment (1) made by ASAP, NRDC, and NCLC jointly; (2) recorded in document number 14 that is filed in the docket of the clothes washer energy conservation standards rulemaking (Docket No. EERE-2008-BT-STD-0019) and maintained in the Resource Room of the Building Technologies Program; and (3) which appears on page 1 of document number 14.

DOE agrees that the revision to IEC Standard 62301 is expected to be delayed; the revision is currently expected in late 2010. Therefore, DOE proposes basing the amendments to the clothes washer test on the first edition of IEC Standard 62301, as well as draft versions of the second edition, in the issuance of this NOPR. Such action is necessary to permit manufacturers to certify that their products comply with any newly established energy conservation standards that take into account standby and off mode energy use.

The amended test procedure would become effective 30 days after the date of publication in the
Federal Register
of the final rule in this test procedure rulemaking. However, DOE would clarify in the published amended test procedure in 10 CFR part 430 subpart B appendix J2 that it need not be used to determine compliance with current energy conservation standards. Instead, manufacturers would be required to begin using the test procedures in appendix J2 on the compliance date of any final rule establishing amended energy conservation standards that would, in part, address standby and off mode power consumption for these products. 42 U.S.C. 6295(gg)(2)(C).

C. Standby Mode, Off Mode, and Additional Active Mode Test Procedures

1. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power Consumption

As required by EPCA, as amended by EISA 2007, DOE considered the most current versions of IEC Standard 62301 and IEC Standard 62087 for measuring power consumption in standby mode and off mode when developing today's proposed amendments to the clothes washer test procedure. (42 U.S.C. 6295(gg)(2)(A)) DOE noted that IEC Standard 62301 provides for measuring standby power in electrical appliances, including clothes washers, and thus is relevant here. DOE also reviewed IEC Standard 62087, which specifies methods of measuring the power consumption of TV receivers, video cassette recorders (VCRs), set top boxes, audio equipment, and multi-function equipment for consumer use. IEC Standard 62087 does not, however, include methods for measuring the power consumption of electrical appliances such as clothes washers. Therefore, DOE has determined that IEC Standard 62087 is inapplicable to this rulemaking, and has not included any of its provisions in today's proposed test procedure.

DOE proposes to incorporate by reference into this test procedure all applicable provisions from Sections 4 and 5 of IEC Standard 62301. Specifically, DOE proposes to incorporate, from section 4, (“General conditions for measurements”), paragraph 4.2, “Test room;” paragraph 4.4, “Supply voltage waveform;” paragraph 4.5, “Power measurement accuracy;” and from section 5, (“Measurements”), paragraph 5.1, “General,” Note 1; and paragraph 5.3, “Procedure.” These clauses provide test conditions and test procedures for measuring average standby mode and average off mode power consumption. With respect to test conditions, section 4 of IEC Standard 62301 provides specifications for the test room conditions, supply voltage waveform, and power measurement meter tolerances to ensure repeatable and precise measurements of standby mode and off mode power consumption. With respect to test procedures, section 5 of IEC Standard 62301 provides methods for measuring power consumption when the power measurement is stable and when it is unstable.

DOE invites comment on whether IEC Standard 62301 measures standby and off mode power consumption for clothes washers adequately, and whether incorporating these specific provisions into the DOE test procedure is appropriate.

2. Determination of Modes To Be Incorporated

EPCA provides the following mode definitions:

“Active mode” is defined as the condition in which an energy-using product is connected to a main power source, has been activated, and provides one or more main functions. (42 U.S.C. 6295(gg)(1)(A)(i))

“Standby mode” is defined as the condition in which an energy-using product is connected to a main power source and offers one or more of the following user-oriented or protective functions: to facilitate the activation or deactivation of other functions (including active mode) by remote switch (including remote control), internal sensor, or timer; or continuous functions, including information or status displays (including clocks) or sensor-based functions. (42 U.S.C. 6295(gg)(1)(A)(iii))

“Off mode” is defined as the condition in which an energy-using product is connected to a main power source and is not providing any standby mode or active mode function. (42 U.S.C. 6295(gg)(1)(A)(ii))

During the September 2009 Public Meeting, ASAP commented that the definitions provided in IEC Standard 62301 do not conform to the statutory definitions provided by EPCA, so ASAP believed it was not entirely clear that DOE should adopt the IEC definitions word-for-word. (ASAP, Public Meeting Transcript, No. 7 at p. 19)
5

5
A notation in the form “ASAP, Public Meeting Transcript, No. 7 at p. 19” identifies an oral comment that DOE received during the September 21, 2009, Framework public meeting, was recorded in the public meeting transcript in the docket for the clothes washer energy conservation standards rulemaking (Docket No. EERE-2008-BT-STD-0019), and is maintained in the Resource Room of the Building Technologies Program. This particular notation refers to a comment (1) made by ASAP during the public meeting; (2) recorded in document number 7, which is the public meeting transcript that is filed in the docket of the clothes washer energy conservation standards rulemaking; and (3) which appears on page 19 of document number 7.

DOE notes that the EPCA definition of standby mode differs from the one provided in IEC Standard 62301, which defines standby mode as the “lowest power consumption mode which cannot be switched off (influenced) by the user and that may persist for an indefinite time when an appliance is connected to the main electricity supply and used in accordance with the manufacturer's instructions.” However, DOE expects significant changes to the mode

definitions included in IEC Standard 62301, based on review of IEC Standard 62301 FDIS. The definitions provided in IEC Standard 62301 FDIS are likely to be included in the final revised IEC Standard 62301, Second Edition. DOE considered the definitions provided by IEC Standard 62301 FDIS as the most current when determining the mode definitions proposed to be included in the test procedure.

EPCA authorizes DOE to amend mode definitions, as appropriate, considering the most current versions of IEC Standards 62301 and 62087. (42 U.S.C. 6295(gg)(1)(B)) DOE recognizes that the EPCA definitions for active mode, standby mode, and off mode were developed to be broadly applicable for many energy-using products. However, for specific products with multiple functions, these broad definitions could be interpreted in different ways. For these reasons, DOE proposes amending the test procedure to include definitions for these modes based on the definitions provided in IEC Standard 62301 FDIS, with added clarifications specific to clothes washers.

Active Mode

DOE proposes to define active mode as a mode in which the clothes washer is connected to a mains power source; has been activated; and is performing one or more of the main functions of washing, soaking, tumbling, agitating, rinsing, and/or removing water from the clothing, or is involved in functions necessary for these main functions, such as admitting water into the washer or pumping water out of the washer. DOE is proposing to refer to the typical clothes washing operation (
i.e.,
a complete wash cycle intended for washing a clothing load, including washing, rinsing, and spinning) as the active washing mode. DOE is aware of three additional relevant modes that it proposes to define as a part of active mode: delay start mode, cycle finished mode, and self-clean mode. DOE is proposing to include these modes in the measures of clothes washer energy consumption, as discussed in section III.C.4.

i. Delay Start Mode

DOE proposes to define delay start mode as a mode in which activation of the active washing mode is facilitated by a timer. Because delay start mode is not a mode that may persist for an indefinite time, DOE believes it would not be considered as part of a standby mode based on the proposed definition discussed below. DOE also notes that IEC Standard 62301 Committee Draft 2 (IEC Standard 62301 CD2) provides the additional clarification that “delay start mode is a one off user initiated short duration function that is associated with an active mode.” The subsequent IEC Standard 62301 Committee Draft for Vote (IEC Standard 62301 CDV) removes this clarification; however, in response to comments on IEC Standard 62301 CD2 that led to IEC Standard 62301 CDV, IEC states that delay start mode is a one off function of limited duration. DOE infers that delay start mode should therefore be considered part of active mode. DOE notes that IEC 62301 FDIS classifies delay start as a secondary function and therefore not part of active mode. DOE continues to believe, however, that because delay start is of limited duration and is uniquely associated with the initiation of a main function (
i.e.,
washing cycle), it should be considered part of active mode. The proposed methods for measuring energy consumption in delay start mode are discussed in III.C.3.

ii. Cycle Finished Mode

DOE proposes to define cycle finished mode as a mode that provides continuous status display following operation in the active washing mode. However, as with delay start mode, cycle finished mode is not a mode that may persist for an indefinite time, and would therefore not be considered as a part of standby mode. Additionally, operation in cycle finished mode occurs only after operation in the active washing mode. DOE believes cycle finished mode, similar to delay start mode, would be considered a one off short duration function that is associated with an active mode. DOE is therefore proposing to define cycle finished mode as a part of active mode. The proposed methods for measuring energy consumption in cycle finished mode are discussed in III.C.3.

DOE is aware that some clothes washers currently available offer energy-consuming features in cycle finished mode other than a continuous status display. For example, certain models may employ a low-power fan to circulate air around the damp clothes to prevent odors. These models may also periodically tumble the clothes to prevent wrinkles for up to 10 hours after the completion of the wash cycle. These functions, while enabled, would use more energy than the continuous display normally associated with cycle finished mode. However, DOE does not propose amending the test procedure to address these specific cycle finished mode functions, because DOE believes measuring the energy use from these functions would significantly increase the test cycle duration to capture a negligible contributor to annual energy consumption. In addition, DOE research indicates that only eight out of the 94 residential clothes washer models currently produced by manufacturers representing more than 92 percent of the residential clothes washer market incorporate such a circulation or tumbling function. Because these models are also higher priced and recently introduced, DOE believes that the shipment-weighted percentage of residential clothes washers with a circulation or tumbling function in cycle finished mode is less than 5 percent. Therefore, DOE believes the energy consumed by these features in cycle finished mode represents a negligible portion of the overall energy consumption of clothes washers.

iii. Self-Clean Mode

DOE proposes to define self-clean mode as a clothes washer operating mode that:

• Is dedicated to cleaning, deodorizing, or sanitizing the clothes washer by eliminating sources of odor, bacteria, mold, and mildew;

• Is recommended to be run intermittently by the manufacturer; and

• Is separate from clothes washing cycles.

Self-clean mode is considered a part of the active mode because it is a function necessary for the main functions associated with washing clothes. A clothes washer with excessive bacteria, mildew, or odor cannot effectively wash clothes. A further discussion of self-clean mode, including its incorporation in the clothes washer test procedure, is included in section III.D.1.b.

Standby Mode

DOE proposes to define standby mode as any mode in which the clothes washer is connected to a mains power source and offers one or more of the following user-oriented or protective functions which may persist for an indefinite time:
6

6
The actual language for the standby mode definition in IEC Standard 62301 FDIS describes “* * *user oriented or protective functions which usually persist” rather than “* * * user oriented or protective functions which may persist for an indefinite time.” DOE notes, however, that section 5.1 of IEC Standard 62301 FDIS states that “a mode is considered to be persistent where the power level is constant or where there are several power levels that occur in a regular sequence for an indefinite period of time.” DOE believes that the proposed language, which was originally included in IEC Standard 62301 CD2, encompasses the possible scenarios foreseen by section 5.1 of IEC Standard 62301 FDIS without unnecessary specificity.

• Facilitation of the activation of other modes (including activation or deactivation of active mode) by remote

switch (including remote control), internal sensor, or timer;

• Continuous function: Information or status displays including clocks; and

• Continuous function: Sensor-based functions.

DOE proposes adding a clarification of what would be considered a timer under this definition of standby mode. DOE would clarify that a timer is a continuous clock function (which may or may not be associated with a display) that provides regular scheduled tasks (
e.g.,
switching) and that operates on a continuous basis. As noted earlier in this section, this proposed definition was developed based on the definition provided in IEC Standard 62301 FDIS. It expands on the EPCA mode definition to provide additional clarifications as to which functions are associated with standby mode.

The proposed definition of standby mode based on IEC Standard 62301 FDIS allows for multiple modes to be considered a standby mode. DOE has identified only one mode that would be considered a standby mode under the proposed definition. DOE proposes to define this “inactive mode” as a standby mode that facilitates the activation of active mode by remote switch (including remote control), internal sensor, or timer, or that provides continuous status display. DOE proposes amending the test procedure for clothes washers to include provisions for measuring energy use in inactive mode as the measurement of standby energy use. Although it identified only this one particular standby mode, DOE remains open to consideration of additional standby modes.

Off Mode

As discussed in section III.C.1, DOE proposes in today's NOPR to amend the DOE test procedure for clothes washers to define “off mode” as any mode in which the clothes washer is connected to a mains power source and is not providing any standby mode or active mode function and the mode may persist for an indefinite time. An indicator that only shows the user that the product is in the off position is included within the off mode classification. As noted in section III.C.1, this definition was developed based on the definitions provided in IEC Standard 62301 FDIS. It expands on the EPCA mode definitions to provide additional clarifications as to which functions are associated with off mode.

Under the proposed definitions, a clothes washer equipped with a mechanical on/off switch that can disconnect power to the display and/or control components would be considered as operating in the off mode when the switch is in the “off” position, provided that no other standby or active mode functions are energized. An energized light-emitting diode (LED) or other indicator that only shows the user that the product is in the off position would be considered part of off mode under the proposed definition, again provided that no other standby or active mode functions are energized. As stated above, however, if any energy is consumed by the appliance in the presence of a one-way remote control, the unit would be operating in standby mode under the proposed definition. That definition would include remote controls that facilitate the activation or deactivation of other functions (including active mode) as a feature of standby mode.

IEC Standard 62301 FDIS also provides definitions for additional modes that DOE determined are not applicable to the clothes washer test procedure. Section 3.7 of IEC Standard 62301 FDIS defines network mode as a mode category that includes “any product modes where the energy using product is connected to a mains power source and at least one network function is activated (such as reactivation via network command or network integrity communication) but where the primary function is not active.” IEC Standard 62301 FDIS also provides a note, stating that “[w]here a network function is provided but is not active and/or not connected to a network, then this mode is not applicable. A network function could become active intermittently according to a fixed schedule or in response to a network requirement. A `network' in this context includes communication between two or more separate independently powered devices or products. A network does not include one or more controls which are dedicated to a single product. Network mode may include one or more standby functions.” As discussed further in section III.D.1.c, DOE is not proposing any amendments to include provisions for testing network mode energy consumption in clothes washers.

DOE also notes that section 3.9 of IEC Standard 62301 FDIS provides a definition of “disconnected mode”, which is “the state where all connections to mains power sources of the energy using product are removed or interrupted.” IEC Standard 62301 FDIS also adds a note that common terms such as “unplugged” or “cut off from mains” also describe this mode and that this mode is not part of the lower power mode category. DOE believes that there would be no energy use in a disconnected mode, and therefore, is not proposing a definition or testing methods for such a mode in the DOE test procedure for clothes washers.

DOE welcomes comment on the proposed establishment of the modes as discussed above, including inactive mode as the only standby mode for clothes washers. DOE also invites comment on the determination that delay start mode and cycle finished mode would be considered part of active mode. DOE further invites comment on the proposed mode definitions, including the definition of self-clean mode, and whether there are any modes that have not been identified in this NOPR that represent significant energy use and are consistent with the proposed active mode, standby mode, or off mode definitions.

3. Adding Specifications for the Test Methods and Measurements for Standby Mode, Off Mode, and Additional Active Mode Testing

This section discusses the provisions DOE proposes to include in the test procedure to clarify the IEC Standard 62301 methods when used to measure standby mode and off mode energy use in clothes washers. These proposed procedures also include provisions for measuring energy use in delay start mode and cycle finished mode. Although these modes are considered a part of active mode under the proposed definitions, the methods for measuring their associated energy consumptions are similar to those used for standby mode and off mode.

Paragraph 5.3.1 of section 5.3 of IEC Standard 62301 contains provisions for measuring power. It specifies, for products in which the power is stable (
i.e.,
power varies by not more than 5 percent from a maximum level during a period of 5 minutes), waiting at least 5 minutes for the product to stabilize and then measuring the power at the end of an additional time period of not less than 5 minutes. Paragraph 5.3.2 contains provisions for measuring average power in cases where the power is not stable (
i.e.,
power varies by more than 5 percent from a maximum level during a period of 5 minutes). In such cases, IEC Standard 62301 requires a measurement period of no less than 5 minutes, or one or more complete operating cycles of several minutes or hours. DOE notes these provisions do not preclude manufacturers from testing products with a longer stabilization period, or a longer measurement period (if the power varies by not more than 5 percent or if that period represents one or more complete cycles).

Displays on residential clothes washers may reduce power consumption by dimming or turning off after a certain period of user inactivity (“automatic power-down”). For clothes washers whose power input in standby, off, and cycle finished modes varies in this manner during testing, DOE proposes that the test be conducted after the power level has dropped to its lowest level, as discussed in IEC Standard 62301, section 5, (“Measurements”), paragraph 5.1, “General,” Note 1. DOE is aware that IEC Standard 62301 does not provide guidance on how long to wait for the appliance to drop to the lower-power state. DOE observed during tests of 17 residential clothes washers that in units with an automatic power-down feature the higher-power state persists for less than 10 minutes of inactivity after the display has been energized. Thus, the energy consumption at the low-power level is most representative of standby mode, off mode, and cycle finished mode power. However, DOE notes the test sample of 17 clothes washers was relatively small. It is possible that some clothes washers may remain in the higher-power state for the duration of a 5-minute stabilization period and 5-minute measurement period, and then drop to the lower-power state that is more representative of standby mode, off mode, or cycle finished mode. In contrast, IEC Standard 62301 CDV specifies for each testing method that the product be allowed to stabilize for at least 30 minutes prior to a measurement period of not less than 10 minutes. DOE believes this method would allow sufficient time for displays that automatically dim or power down after a period of user inactivity to reach the lower-power state prior to measurement. Based on the automatic power-down time periods observed in its own testing, DOE believes that the IEC Standard 62301 CDV 30-minute stabilization and 10-minute measurement periods provide a clearer and more consistent testing procedure than the corresponding time periods specified in IEC Standard 62301. Those periods allow for representative measurements to be made among products that may have varying time periods before the power drops to a lower level more representative of standby, off, or cycle finished mode. DOE notes that IEC Standard 62301 FDIS establishes an overall test period of not less than 15 minutes for products in which power consumption in the mode being tested is not cyclic. Data collected during the first third of the total period is discarded (and thus this time could be inferred to be a stabilization period), and data from the remaining two-thirds of the total period are used to determine whether the power is stable. If stability is not achieved, the total period is extended continuously until the stability criteria are achieved, to a maximum of 3 hours. Modes that are known to be non-cyclic and of varying power consumption shall follow this same procedure, but with a total test period not less than 60 minutes. If power consumption in a mode is cyclic, measurements must be conducted with an initial operation period (analogous to a stabilization period) of at least 10 minutes, and the average power measured over at least four complete cycles. The measurement period must be at least 20 minutes. DOE believes that the specifications provided in IEC Standard 62301 FDIS would not produce power consumption measurements as accurate, repeatable, and enforceable as the specifications provided in IEC Standard 62301 CDV. Therefore, DOE proposes to require that: (1) the product be allowed to stabilize for at least 30 minutes, then (2) the power measurement be made for a period not less than 10 minutes for inactive, off, and cycle finished modes.

DOE's test procedures are developed to measure representative energy use for the typical consumer, and cannot capture all possible consumer actions and appliance usage patterns that might increase energy use. For example, certain residential clothes washer models featuring a display power-down may allow consumers to alter the display settings to increase the amount of time in the high-power state, or to make the high-power state permanent. Because DOE does not have information regarding the likelihood consumer will alter the default display settings, DOE has not proposed additional provisions in today's NOPR to address the possibility of increased energy use as a result of consumers adjusting the display power-down settings or other features. DOE welcomes comment on the suitability of using the default settings in testing standby energy consumption. It also welcomes comment on any methodologies that can account for consumer actions that might increase energy use, and requests data on the repeatability of such testing procedures.

DOE understands that clothes washers with a delay start capability may use varying amounts of power during delay start mode, depending on the delay time entered, the amount of remaining delay time displayed, and/or display indication of mode status. To ensure comparable and valid results, DOE proposes to include in its clothes washer test procedure a specification for the delay start time to be set at 5 hours, and for power to be monitored for 60 minutes after waiting at least 5 minutes for power input to stabilize. In determining the specification for delay start parameters, DOE considered the possibility that display power input would depend on the time displayed, which is typically the time in hours remaining before the start. Displays may be one or two digits. Some two-digit displays may show whole numbers for remaining delay hours of 10 or more and both the ones and tenths digits for the remaining delay hours of 9.9 or less. DOE analyzed the number of LEDs activated in LED displays of the remaining hours over a range of delay times. It concluded that the average number of LEDs lit for the range of all possible delay times would be best approximated by determining the average number of LEDs lit for either single-digit or two-digit displays in a 60-minute test if the delay time is set at 5 hours. DOE welcomes comment on this approach to measuring delay start mode.

DOE is also proposing that test room ambient temperatures for standby mode and off mode testing, as well as delay start mode and cycle finished mode testing, be specified for all clothes washers according to section 4, paragraph 4.2 of IEC Standard 62301. The current DOE test procedure includes a test room ambient air temperature specification only for water-heating clothes washers, for which the requirement is 75 ± 5 degrees Fahrenheit (°F). This falls within the range specified by IEC Standard 62301 of 73.4 ± 9 °F. Today's proposed test procedure would allow manufacturers of water-heating clothes washers to use the more stringent ambient temperature range in the current DOE test procedure if tests of active washing mode performance and standby, off, delay start, and cycle finished mode power are conducted simultaneously in the same room on multiple clothes washers. Alternatively, the proposed temperature specifications taken from IEC Standard 62301 would allow a manufacturer that opts to conduct standby, off, delay start, and cycle finished mode testing separately from active washing mode testing more latitude in maintaining ambient conditions. DOE requests comment on the appropriateness of this proposed modified test room ambient temperature range.

4. Calculation of Energy Use Associated With Each Operating Mode

To combine active washing mode energy consumption with energy

consumption from inactive, off, and additional active modes (delay start, cycle finished, and self-clean modes), DOE estimated the representative energy use for each of these modes. The total energy consumption in each of these modes depends on both the power level of that mode and the time spent in that mode. This section discusses the approach DOE proposes for calculating energy use associated with each operating mode for clothes washers and the numbers of hours proposed to be associated with each mode.

Energy use for clothes washers is expressed in terms of ft
3
of wash load capacity per total energy use per wash cycle.
7

As discussed further in section III.E.2, DOE has tentatively determined that it is technically feasible to integrate measures of standby mode and off mode energy use into the overall energy use metric, as required by the EISA 2007 amendments to EPCA. (42 U.S.C. 6295(gg)(2)(A)) Therefore, DOE has examined standby mode and off mode power consumption in terms of annual energy use apportioned on a per-cycle basis. DOE has also examined energy consumption from delay start, cycle finished, and self-clean modes on a per-cycle basis. Energy used during an active washing mode test cycle is directly measured in the current DOE test procedure, and a weighted average is calculated under different load sizes, fill levels, and wash temperature conditions according to the specific machine's capacity and features. (
See
section 4.1 of appendix J1 of subpart B of 10 CFR 430 for details.) The calculation of MEF also includes nominal energy used by a water heater to heat the water supplied to the clothes washer, and by a dryer to remove the remaining moisture after the clothes washer completes its full cycle (weighted by a dryer usage factor (DUF) to account for loads not dried in a clothes dryer).

7

See
section III.C.5 for a detailed description of how the efficiency metric is calculated.

Average cycle times can vary significantly based on the axis of basket rotation and type of load. One 1997 study compared a 37-minute normal cycle for a vertical-axis, top-loading clothes washer with 40 to 110-minute cycles for eight different front-loading, horizontal-axis machines.
8

The U.S. Environmental Protection Agency (EPA) reported in 2005 on three studies in the magazine “Consumer Reports”
9

that determined top-loading clothes washers have “normal” cycle times of 37-55 minutes, and front-loading washers have “normal” cycle times of 51-105 minutes.
10

Therefore, DOE proposes to adopt the estimate of 1 hour per cycle associated with a residential clothes washer's typical active washing mode (
i.e.,
a complete wash cycle including washing, rinsing, and spinning). DOE is proposing a single cycle duration for both top-loading and front-loading clothes washers rather than more accurate cycle times specific to each product class to simplify the test procedure and calculations. Additionally, proposing cycle times for each product class would have an insignificant effect on the calculations proposed in the test procedure because it is used only to allocate the number of annual hours associated with inactive/off mode. For example, using cycle times of 45 minutes for top-loaders and 75 minutes for front-loaders would change the number of hours allocated to inactive/off mode (the only modes affected by the number of active mode hours) by less than 1 percent.

8
J. Dieckmann, D. Westphalen. 1997. “Laboratory Testing of Clothes Washers.”
The High-Efficiency Laundry Metering and Market Analysis (THELMA).
Volume 2. Final Report to the Electric Power Research Institute (EPRI). Report No. TR-109147-V2. December 29, 1997. Available for purchase at
http://www.epri.com.

9
These studies appeared in the July 1998, July 1999, and August 2000 issues of
Consumer Reports.

10
C. Wilkes
et al.
2005. “Quantification of Exposure-Related Water Uses for Various U.S. Subpopulations.” U.S. Environmental Protection Agency, Office of Research and Development. Report No. EPA/600/R-06/003. Washington, DC. December 2005. Available at
http://www.wilkestech.com/205edrb06_Final_Water_Use_Report.pdf.

In the January 2001 final rule, 66 FR 3314, DOE estimated the representative number of annual wash cycles per clothes washer as 392. DOE is proposing to update the number of wash cycles per year from 392 to 295 to reflect more current consumer behavior, which is discussed in detail in section III.D.2.a. One hour per cycle would result in a total of 295 hours per year associated with active mode. DOE is proposing to associate the remaining 8,465 (8,760 minus 295) hours of the year with all modes other than the active washing mode.

DOE is aware of five modes other than active washing mode in which residential clothes washers use energy: (1) Inactive mode, (2) cycle finished mode, (3) delay start mode, (4) off mode, and (5) self-clean mode. DOE is aware of only limited studies of the time clothes washers spend in these different modes. One household survey conducted by the National Appliance and Equipment Energy Efficiency Committee (NAEEEC) in Australia in 2000, for example, measured the time associated with different modes for 61 clothes washers with an average age of 9 years. The daily time spent in each mode in this study averaged 1 hour for washing (active washing mode), zero time for delay start and “active standby” modes, and the remaining time split 20 percent for “end of program” mode and 80 percent for off mode.
11

Self-clean mode was not explicitly addressed. The active standby mode of the washers in this study is equivalent to the inactive mode defined in section III.C.2 of this notice, and the end of program mode is equivalent to cycle finished mode.

11
Australia's National Appliance and Equipment Energy Efficiency Committee (NAEEEC).
Standby Product Profile—Clothes Washers.
October 2003. Available at
http://www.energyrating.gov.au/library/pubs/sb200308-washers.pdf.

The average age of the clothes washers in the study suggests that many of them have electromechanical rather than electronic controls, and thus would not likely have been capable of inactive mode. Hence, DOE does not infer from those results that more modern clothes washers spend negligible time in inactive mode. DOE believes that because current clothes washer models offer both mechanical and electronic controls, the time apportioned to off mode in this study would actually be split between off mode and inactive mode. Clothes washers with electromechanical controllers can have a delayed start feature, although its implementation appears to be market-specific. Markets with a long history of residential time-of-day electricity pricing are more likely to have appliances with delayed start features than in markets where household electricity prices are constant. The clothes washers in the NAEEEC study would have been less likely to have a delay start mode because differential power pricing is a relatively recent development in the Australian residential power market. Thus, the findings in the Australian clothes washer study regarding delayed start are inconclusive regarding the time current models of clothes washers spend in delay start mode.

To help address this uncertainty, DOE examined a more recent 2005 Australian study that noted a small number of usage hours associated with delay start mode. This study used dataloggers to monitor time clothes washers spent in different modes in Australia and New Zealand. The study showed that the average amount of time spent in delay start mode per wash cycle was approximately 5 minutes.
12

DOE

expects similar low usage patterns of delayed start functionality for clothes washers in U.S. households because DOE research suggests that most U.S. residential electricity customers have fixed-rate electricity pricing (
i.e.,
the cost of electricity does not change with time of day, day of week, or time of year). However, delayed start functionality usage could increase in the United States as more electric utilities offer residential customers variable-rate pricing plans that encourage shifting electricity consumption to off-peak hours.

12
Australian Electrical and Electronic Manufacturer's Association.

A Submission to NAEEEC on Mode Times for Use When Determining Standby Energy Consumption of Clothes Washers,

Dishwashers, and Dryers.

Appendix B. March 11, 2005. Available at
http://www.aeema.asn.au/ArticleDocuments/258/standby.pdf.

DOE welcomes comment on whether the sources cited provide a reasonable indication of residential clothes washer mode usage patterns, and also welcomes any additional information about such usage patterns.

Based on these two studies, DOE concludes that a typical modern residential clothes washer spends a small amount of time in delay start mode. Using an estimated 5 minutes per cycle, the total annual amount of time spent in delay start mode, using the proposed representative 295 cycles per year, is 25 hours.

The NAEEEC study suggests that 20 percent of the total use cycle time not allocated to active washing or delay start mode would be associated with cycle finished mode. However, DOE testing of multiple residential clothes washers showed that the time spent in a cycle finished mode per use cycle is very short. Several models tested had no cycle finished mode, and immediately reverted to off/inactive mode after the wash cycle completed. All of the tested units with cycle finished mode remained in that state for less than 5 minutes before switching back to off/inactive mode. Based on these results, DOE is proposing to allocate 3 minutes per average use cycle to cycle finished mode, for a total of 15 hours per year.

In addition, DOE is aware that some residential clothes washers offer a self-clean mode, as further discussed in section III.D.1.b. These self-clean cycles are not accounted for in the proposed 295 active mode washing hours per year. DOE tested seven machines that had these cycles, and found an average self-clean cycle time of 1.3 hours. DOE proposes to account for the time spent in self-cleaning cycles, if applicable, based on an estimated average manufacturer recommendation of 12 self-clean cycles per year, resulting in 16 hours per year. Therefore, machines offering a self-cleaning cycle will spend 16 fewer hours per year in standby mode or off mode.

In summary, DOE is proposing to allocate 295 hours per year to the active washing mode, 16 hours to self-clean mode (if applicable), 25 hours to delay start mode, 15 hours to cycle finished mode, and the remainder (8,409 hours for clothes washers offering other modes) to off and/or inactive mode.

Table III.1 presents DOE's estimate of the annual energy use associated with all modes for a clothes washer that is capable of each of these functions. The approximate ranges of power associated with the different modes are based on DOE testing of residential clothes washers with the exception of active washing mode, as noted below. Where ranges of average power are listed, the highest and lowest average measured values for both top- and front-loading clothes washers are provided. Active washing mode annual energy use is calculated based on the proposed 295 cycles per year in a standard-size, top-loading or front-loading clothes washer. Active washing mode per-cycle energy use is determined from a 2006 study that referenced data provided in 2005 by the Association of Home Appliance Manufacturers (AHAM) and Whirlpool Corporation (Whirlpool).
13

This study estimated that, in 2005, average per-cycle energy use was 2.23 kWh for a typical residential clothes washer in the United States with an average MEF of 1.37 and a capacity of 3.06 ft
3
.

13
R. Bole.
Life-Cycle Optimization of Residential Clothes Washer Replacement.
Center for Sustainable Systems, University of Michigan. Report. No. CSS06-03. Appendix C. April 21, 2006. Available at
css.snre.umich.edu/css_doc/CSS06-03.pdf.

Table III.1—Estimate of Annual Energy Use of Residential Clothes Washer Modes

Mode
Hours

Typical average power
W

Annual energy use
kWh

Active Washing
295
2,230

**
657.9.

Self-Clean
16
75 to 2,081
† 1.2 to 33.3

Delay Start
25
1.4 to 8.9
0.04 to 0.2.

Cycle Finished
15
0 to 5.2
0 to 0.08.

Off and Inactive

*
8,409

0 to 1.7
0 to 14.3.

*
Remaining time = 8,760 − 295 − 16 − 25 − 15 = 8409.

**
Includes energy consumption for water heating and moisture removal in the dryer as well as machine electrical energy consumption.

† Based on DOE testing of seven units with self-clean cycles, and 12 cycles per year. Values include energy consumption for water heating and machine electrical energy consumption.

To determine the annual hours per mode for clothes washers that do not utilize all possible modes, DOE estimated values based upon reallocating the hours for modes that are not present to off/inactive modes. Table III.2 summarizes the allocation of hours to different possible modes under each scenario.

Table III.2—Estimate of Annual Hours of Possible Clothes Washer Modes

Mode

All modes
possible

No delay start mode
No cycle finished mode
No delay start or cycle finished modes

No Self-Clean Available

Active Washing
295
295
295
295

Delay Start
25
0
25
0

Cycle Finished
15
15
0
0

Off and Inactive
8,425
8,450
8,440
8,465

Self-Clean Available

Active Washing
295
295
295
295

Self-Clean
16
16
16
16

Delay Start
25
0
25
0

Cycle Finished
15
15
0
0

Off and Inactive
8,409
8,434
8,424
8,449

DOE believes the proposed definition of off mode as applied to residential clothes washers refers to units with mechanical rather than electronic controls, or units with electronic controls combined with a mechanical switch with which the user can de-energize the electronic controls. Reactivation of the clothes washer with a pushbutton sensor, touch sensor, or other similar device that consumes power is considered to be a standby mode feature under the proposed definition. DOE believes there are few clothes washers with electronic controls that have an additional mechanical on/off switch. Therefore, the combined inactive/off hours would most likely be allocated fully either to inactive mode or off mode, depending on the type of controls present on the clothes washer. DOE does not have market share information to determine how many residential clothes washers are currently shipped with electromechanical controls. For clothes washers with electronic controls plus a mechanical on/off switch, DOE is proposing to allocate half of the inactive/off hours each to inactive and off modes. DOE welcomes comment and additional information on this point.

In conclusion, DOE is proposing to calculate residential clothes washer energy use per cycle associated with inactive, off, delay start, and cycle finished modes by (1) Calculating the product of wattage and allocated hours for all possible inactive, off, delay start and cycle finished modes; (2) summing the results; (3) dividing the sum by 1,000 to convert from Wh to kWh; and (4) dividing by the proposed 295 use cycles per year. DOE is also proposing to calculate energy use per cycle associated with self-clean mode, if available, by (1) multiplying the energy use per self-clean cycle in kWh by 12 (the number of self-clean cycles estimated per year); and (2) dividing by the proposed 295 use cycles per year.

DOE invites comments on this proposed methodology and associated factors, including accuracy, allocation of annual hours, and test burden. DOE may also consider the following alternative methodology based on comments received:

The comparison of annual energy use of different clothes washer modes shows that delay start and cycle finished modes represent a relatively small number of hours at low power consumption levels. For clothes washers currently on the market, these levels are distinct from, but comparable to, those for off/inactive modes. Thus, DOE could adopt an approach that would be limited to specifying hours for only off and inactive modes when calculating energy use. In that case, all of the hours not associated with active washing mode or self-clean mode (8,465 hours total) would be allocated to the inactive and off modes. DOE invites comment on whether such an alternative would be representative of the power consumption of clothes washers currently on the market.

5. Measures of Energy Consumption

The DOE test procedure for clothes washers currently incorporates various measures of per-cycle energy consumption including total weighted per-cycle hot water energy consumption (for electric-, gas-, or oil-heated water), total weighted per-cycle machine electrical energy consumption, and per-cycle energy consumption for removing moisture from a test load in a dryer. (
See
sections 4.1 and 4.3 of appendix J1 of subpart B of 10 CFR 430 for details.) The test procedure also provides a calculation for MEF, which is equal to the clothes container capacity in ft
3
divided by the sum, expressed in kWh, of the total weighted per-cycle hot water energy consumption, the total weighted per-cycle machine electrical energy consumption, and the per-cycle energy consumption for removing moisture from a test load. (See section 4.4 of appendix J1 of subpart B of 10 CFR 430 for details.) The current Federal energy conservation standards for clothes washers are expressed in MEF. (10 CFR 430.32(g)(3)).

In response to the August 2009 framework document, Whirlpool commented that DOE should incorporate standby power into the MEF calculation, and that standby power should not be accounted for separately. (Whirlpool, No. 21 at p. 2) Additionally, the Joint Comment and ASE commented that DOE should integrate standby and no-load mode power into a single energy metric based on the revisions to IEC Standard 62301. (Joint Comment, No. 14 at p. 1; ASE, No. 22 at p. 1).

Under 42 U.S.C. 6295(gg)(2)(A), EPCA directs that the “[t]est procedures for all covered products shall be amended pursuant to section 323 to include standby mode and off mode energy consumption * * * with such energy consumption integrated into the overall energy efficiency, energy consumption, or other energy descriptor for each covered product, unless the Secretary determines that—(i) the current test procedures for a covered product already fully account for and incorporate the standby mode and off mode energy consumption of the covered product; or (ii) such an integrated test procedure is technically infeasible for a particular covered product, in which case the Secretary shall prescribe a separate standby mode and off mode energy use test procedure for the covered product, if technically feasible.”

DOE proposes to establish the following measure of energy consumption for clothes washers. It integrates energy use of standby mode and off, modes with the energy use of the product's main functions, including delay start and cycle finished modes as well as any self-clean function available. DOE would define a “per-cycle standby, off, delay start and cycle finished mode energy consumption,” and a “per-cycle self-clean mode energy consumption” measure, as applicable, expressed in kWh. DOE would also define integrated modified energy factor (IMEF) as the clothes container capacity in ft
3
divided by the sum, expressed in kWh, of:

• The total weighted per-cycle hot water energy consumption;

• The total weighted per-cycle machine electrical energy consumption;

• The per-cycle energy consumption for removing moisture from a test load;

• The per-cycle standby, off, delay start and cycle finished mode energy consumption; and

• The per-cycle self-clean mode energy consumption, as applicable (discussed in III.D.1.b).

DOE proposes an amended clothes washer test procedure, appendix J2 to subpart B of 10 CFR part 430, to include the measurement of the energy consumption in these additional modes and the calculation of IMEF.

DOE does not propose to amend the estimated annual operating cost calculation in 10 CFR 430.23 to include the cost of energy consumed in the non-active washing modes because:

• DOE believes that the cost of energy consumed in self-clean, standby, off, delay start, and cycle finished modes is small relative to the total annual energy cost for clothes washers and, therefore, would make little difference in the estimated annual operating cost calculation; and

• The Federal Trade Commission's (FTC's) EnergyGuide Label for clothes washers includes as its primary indicator of product energy efficiency the estimated annual operating cost, compared to a range of annual operating costs of similar products. Appendix F1 to 16 CFR part 305. An estimated annual operating cost incorporating self-clean, standby, off, delay start, and cycle finished mode energy use would no longer be directly comparable to the minimum and maximum energy costs prescribed for the EnergyGuide Label.

D. Clothes Washer Active Mode Test Procedure

1. Technologies Not Covered by the Current Clothes Washer Test Procedure

a. Steam Wash Cycles

Multiple clothes washer models currently available on the market offer a steam function via pre-set cycles or as an optional addition to conventional wash cycles. During these cycles, steam is injected into the basket, which manufacturers claim provides enhanced cleaning and/or sterilization. The steam is produced in a generator that requires a significant amount of energy to heat and vaporize the water. The current clothes washer test procedure does not account for energy or water consumption during this type of wash cycle.

In response to the August 2009 framework document, DOE received comments from the Joint Comment and ASE supporting revisions to the test procedure to measure energy and water consumption during steam wash cycles. (Joint Comment, No. 14 at p. 3; ASE, No. 22 at p. 1).

The current clothes washer test procedure specifies methods for measuring energy and water consumption over a range of wash temperatures based on the temperature selections available on a clothes washer, as specified in Table 3.2 of the test procedure, Test Section Reference. DOE proposes amending the test procedure to include an additional measurement of energy and water consumption during a steam wash cycle for clothes washers offering this feature, included in section 3.9. In the proposed amendments, Table 3.2 of the test procedure is updated to include a column that specifies the test sections to be followed for clothes washers offering a steam wash cycle, to update the footnotes, and to correct an error in the current organization of the table. The test sections required for clothes washers without a steam wash cycle would remain unchanged. The proposed updated Table 3.2 from the test procedure is shown below as table III.3.

Table III.3—Test Section Reference

Max. wash temp. available
Number of wash temp. selections
≤135 °F (57.2 °C)
1
2
>2
** >135 °F (57.2 °C)
3
>3
3
>3

Test Sections Required to be Followed

3.3
3.3

3.4
3.4

3.4

3.5
3.5
3.5

3.6
3.6
3.6
3.6
3.6

* 3.7
* 3.7
* 3.7

3.8
3.8
3.8
3.8
3.8

† 3.9
† 3.9

** Only applicable to machines with a warm wash/warm rinse cycle.
** Only applicable to water heating clothes washers on which the maximum wash temperature available exceeds 135 °F (57.2 °C)
† Only applicable to machines equipped with a steam wash cycle.

DOE also proposes to include the energy and water consumption from steam wash cycles in the final calculations for the energy and water use metrics. For clothes washers capable of steam wash cycles, the measurements of energy and water consumption from the steam wash cycle with the hottest wash temperature would be included in the overall energy and water use calculations based on the temperature use factor (TUF) for steam wash. Table 4.1.1 of the test procedure specifies the current weight given to the consumption measurements for the different wash cycles. DOE believes extra hot and steam cycles would be reserved for the most heavily soiled loads, and would have similar use factors. However, DOE has tentatively assumed that the steam wash cycles would be selected somewhat fewer times than the extra hot cycle because on some models steam is available only as an option on certain settings. DOE is proposing to update Table 4.1.1 to include 0.02 as the TUF of a steam wash cycle, when available. Although DOE lacks data on consumer use of steam wash cycles, DOE believes these cycles would decrease the use of extra hot cycles, but would leave the use of hot, warm, and cold cycles unchanged. DOE therefore believes the 0.02 TUF associated with steam washes would correspond to a 0.02 decrease in the current TUFs associated with extra hot cycles, from 0.05 to 0.03 or 0.14 to 0.12, for a steam-capable clothes washer Table III.4 below shows the proposed Table 4.1.1, including specifications for a steam wash cycle, and updated warm rinse TUFs, as discussed below in section III.D.2.c.

Table III.4—Temperature Use Factors

Max wash temp available

≤135 °F
(57.2 °C)

≤135 °F
(57.2 °C)

≤135 °F
(57.2 °C)

>135 °F
(57.2 °C)

>135 °F
(57.2 °C)

Steam
Steam

Number wash temp selections
Single
2 Temps
> 2 Temps
3 Temps
> 3 Temps
3 Temps
> 3 Temps

TUF
s
(steam)

NA
NA
NA
NA
NA
0.02
0.02

TUF
m
(extra hot)

NA
NA
NA
0.14
0.05
0.12
0.03

TUF
h
(hot)

NA
0.63
0.14
NA
0.09
NA
0.09

TUF
ww
(warm/warm)

NA
NA
* 0.27
* 0.27
* 0.27
* 0.27
* 0.27

TUF
w
(warm)

NA
NA
0.22
0.22
0.22
0.22
0.22

TUF
c
(cold)

1.00
0.37
0.37
0.37
0.37
0.37
0.37

* Only applicable to machines offering a warm/warm cycle. For machines with no warm/warm cycle, this value would be zero and the warm/cold TUF should be increased by 0.27.

DOE requests comment on the following issues: Whether the energy and water consumption of a steam wash cycle should be included in the test procedure; whether the proposed TUF associated with steam wash cycles is appropriate; and whether any data are available regarding consumer usage patterns of such cycles.

b. Self-Clean Cycles

Many residential clothes washers currently on the market offer a self-clean cycle. These cycles are used periodically with bleach and/or detergent but no clothes load to clean, deodorize, or sanitize the components that come into contact with water by preventing or eliminating mold, bacteria, and mildew. Self-clean cycles may require higher water temperatures and greater volumes of water than a normal cycle, and therefore potentially consume a substantial amount of energy. The current test procedure does not account for energy or water consumption attributable to self-clean cycles.

In response to the August 2009 framework document, DOE received comments from the Joint Comment and ASE recommending that DOE amend the test procedure to account for energy and water consumption from these periodic cleansing or sanitizing cycles. According to both commenters, the test procedure should also be amended to credit clothes washer designs that address mold and odor issues without the use of periodic sanitizing cycles. (Joint Comment, No. 14 at p. 3; ASE, No. 22 at p. 1).

In its research, DOE noted that many clothes washer user manuals include a recommendation for how frequently the consumer should run a self-clean cycle. DOE observed that the manufacturer-recommended frequency typically is once a month. Some manufacturers also recommend a cleaning cycle every certain number of wash cycles. DOE believes that these self-clean cycles are not accounted for in the proposed 295 wash cycles per year. Because these cycles may consume a significant amount of energy and water, DOE is proposing to include them in the calculation of the efficiency metric.

DOE is proposing to define a “self-clean mode” as a clothes washer operating mode that:

• Is dedicated to cleaning, deodorizing, or sanitizing the clothes washer by eliminating sources of odor, bacteria, mold, and mildew;

• Is recommended to be run intermittently by the manufacturer; and

• Is separate from clothes washing cycles.

DOE also proposes to integrate energy and water consumption in self-clean cycles into the overall energy efficiency metric, under the assumption that these cycles are typically run once per month. As discussed in section III.C.5, DOE proposes to define IMEF as the clothes container capacity in ft
3
divided by the sum, expressed in kWh, of:

• The total weighted per-cycle hot water energy consumption,

• The total weighted per-cycle machine electrical energy consumption,

• The per-cycle energy consumption for removing moisture from a test load,

• The per-cycle standby mode and off mode energy consumption, and

• The per-cycle energy consumption from any self-clean cycles.

DOE proposes to calculate the per-cycle energy consumption from self-clean cycles by:

• Measuring the hot and cold water consumption and the electrical energy consumption for a self-clean cycle,

• Calculating the per-cycle hot water energy consumption and summing with the per-cycle machine electrical energy consumption for the self-clean cycle, and

• Multiplying by the number of self-clean cycles per year (12) divided by 295 annual active washing mode cycles.

This approach apportions the annual energy use in self-clean mode to each annual active washing mode cycle. DOE notes that it only proposes to account for self-clean cycles in the IMEF calculation for clothes washers for which the manufacturer provides and/or recommends such cycles. If a clothes washer is designed to address mold and odor problems without the need for separate dedicated cleaning cycles, the per-cycle self-clean energy consumption will be zero.

DOE proposes to use a similar approach for including self-clean water consumption in the calculation of IWF (
see
section III.D.4.b). The total measured hot and cold water consumption for a self-clean cycle would be multiplied by 12 self-clean cycles per year divided by 295 annual active washing mode cycles. This per-cycle self-clean water consumption would be summed with the total weighted per-cycle water consumption in the active washing mode, then divided by clothes container capacity to obtain IWF.

DOE requests comment on self-clean cycles, including the proposed definition, the inclusion of self-clean cycle energy and water use into the overall energy efficiency metrics, and on whether any relevant data are available regarding self-clean cycles.

c. Adaptive Control Technologies

Adaptive control technologies can adjust parameters such as agitation speed, number of rinses, wash time, and wash and rinse temperatures based on the size, fabric mix, and soil level of a wash load. The current test procedure accounts for adaptive fill technologies, but no other types of adaptive controls.

AHAM, BSH Home Appliances Corporation (BSH), and Whirlpool commented in response to the August 2009 framework document that adaptive controls are already widely used in residential clothes washers. DOE agrees that multiple models are available on the market that use adaptive control technologies to respond to measured or inferred load size and fabric mix. However, DOE lacks data on the distribution of load size and fabric

content representative of actual consumer usage. DOE is also not aware of any residential clothes washers that currently incorporate soil sensing systems. According to multiple manufacturers that DOE interviewed, implementing soil sensing systems requires overcoming several technical challenges. For example, typical soil sensors have difficulty identifying a single soiled clothing item. Also, detergent foaming can interfere with control systems using turbidity sensors to monitor the clarity of the wash water.

DOE is aware that other consumer products employ adaptive controls, and that these are addressed in their respective test procedures. For example, many dishwashers incorporate adaptive controls by means of a turbidity sensor which adjusts the number and duration of wash and rinse cycles. The dishwasher test procedure accounts for these models through the use of soiled dishware loads. (10 CFR part 430, subpart B, appendix C)

If clothes washers become available that offer adaptive controls using a turbidity sensor, DOE could consider amending the clothes washer test procedure to measure energy and water consumption with a soiled wash load. DOE is aware of other industry and international clothes washer test procedures that use a soiled wash load to determine wash performance, including AHAM HLW-1, “Performance Evaluation Procedures for Household Clothes Washers,” IEC 60456, “Clothes washing machines for household use—Methods for measuring the performance,” and Standards Australia/Standards New Zealand (AS/NZS) 2040.1, “Performance of household electrical appliances—Clothes washing machines—Methods for measuring performance, energy and water consumption.”
14

DOE could, for example, incorporate the test cloth soiling method from one of these test procedures into the DOE clothes washer test procedure to capture the energy and water consumption effects of adaptive controls.

14
AHAM and AS/NZS standards are available online at
http://webstore.ansi.org/.

DOE welcomes comment on whether there are any clothes washers available on the market offering soil-sensing adaptive controls, and on its tentative decision to account for only adaptive fill controls in the test procedure. DOE further invites information on the size distribution and fabric content of wash loads typical of consumer use, and comment on using a soiled test load to determine energy and water consumption in the presence of adaptive controls.

d. Demand Response Technology

Demand response technology enables an appliance to shift its activity based on interaction with the electric grid, utilities, or user programming. Appliances that can communicate with the electric grid or any other network would be considered to have a network mode as defined by IEC Standard 62301 FDIS. This standard defines network mode as a mode category that includes “any product modes where the energy using product is connected to a mains power source and at least one network function is activated (such as reactivation via network command or network integrity communication) but where the primary function is not active.” IEC Standard 62301 FDIS also provides a note stating, “[w]here a network function is provided but is not active and/or not connected to a network, then this mode is not applicable. A network function could become active intermittently according to a fixed schedule or in response to a network requirement. A `network' in this context includes communication between two or more separate independently powered devices or products. A network does not include one or more controls which are dedicated to a single product. Network mode may include one or more standby functions.”

In response to the August 2009 framework document, DOE received multiple comments regarding demand response technologies in clothes washers. Energy Solutions, Pacific Gas and Electric Company (PG&E), Southern California Gas Company (SoCal Gas), San Diego Gas and Electric Company (SDG&E), and Southern California Edison Design & Engineering Services (SoCal Edison) (jointly, the California Utilities) commented that it is important for DOE standards to give credit not only to energy conservation, but to the reduction of peak demand from demand responsive controls. (California Utilities, No. 18 at p. 6) AHAM commented that DOE should evaluate the capability of residential clothes washers to provide peak load shedding capabilities through a “smart grid” infrastructure. (AHAM, No. 15 at p. 4) General Electric (GE) also commented in support of DOE considering demand responsiveness as a technology associated with residential clothes washers. (GE, No. 19 at p. 3) Samsung Electronics America (Samsung) commented that DOE should consider smart grid or grid-enabled appliance technologies for their effect on energy use as it drafts DOE's clothes washer test procedure. (Samsung, No. 22 at p. 4)

However, as mentioned in section III.C.2, DOE does not propose amending the test procedure to include any provisions for measuring energy consumption in network mode because it is unaware of any clothes washers currently available on the market that incorporate a networking function. At this time, DOE is unaware of any data regarding network mode in clothes washers that would enable it to determine appropriate testing procedures and mode definitions for incorporation into the test procedure. In particular, DOE is unaware of:

• Data and methods for the appropriate configuration of networks;

• Whether network connection speed or the number and type of network connections affect power consumption;

• Whether wireless network devices may have different power consumptions when the device is looking for a connection and when the network connection is actually established;

• How the energy consumption for clothes washers in a network environment may be affected by their product design and user interaction as well as network interaction; and

• Whether the network function could become active intermittently according to a fixed schedule or in response to a network requirement.

For these reasons, the proposed amendments in today's NOPR do not include the measurement of energy use in network mode. Provisions for testing power consumption in network mode could be incorporated into the test procedure through future amendments, once the appropriate data and testing methodologies become available. DOE welcomes comment on whether clothes washers that incorporate a networking function are currently available, and whether definitions and testing procedures for a network mode should be incorporated into the DOE test procedure. DOE also requests comment on appropriate methodologies for measuring energy consumption in a network mode, and data on the repeatability of such testing methodology.

2. Changes To Reflect Current Usage Patterns and Capabilities

a. Representative Annual Cycles

In the January 2001 final rule, DOE estimated the representative number of annual wash cycles per clothes washer as 392. 66 FR 3314. This number is not used in the calculations for the current energy efficiency metric, because MEF is calculated on a per cycle basis. In this

NOPR, DOE is proposing to include power consumption from modes other than active washing mode in the energy efficiency metric. As discussed above, doing so requires an estimate of the time a typical clothes washer spends in active washing, inactive, off, delay start, cycle finished, and self-clean modes. The number of annual wash cycles is used to determine the time spent in the active washing mode, and determines the remaining time to be allocated to the other possible modes.

DOE received comments in response to the August 2009 framework document on the number of average clothes washer cycles per year. Alliance Laundry Systems, LLC (ALS) commented that the annual cycles value should be revised to approximately 300 cycles per year, referring to Procter & Gamble (P&G) consumer studies which have been used by DOE in prior test procedure rulemakings. (ALS, No. 12 at p. 1) The Joint Comment and ASE stated that DOE should acquire data for an updated annual number of wash cycles because the current value in the test procedure is based on outdated consumer usage patterns and machine characteristics. (Joint Comment, No. 14 at p. 1; ASE, No. 22 at p. 1) AHAM stated that it supported the use of data from the 2005 “Residential Energy Consumption Survey” (RECS) in determining the annual energy and water consumption of residential clothes washers. (AHAM, No. 15 at p. 6) Additionally, Whirlpool commented that the RECS data has limitations, but that it was unaware of any more robust alternatives to determine annual energy and water consumption of residential clothes washers. (Whirlpool, No. 21 at p. 7)

The 2005 RECS compiles data on energy use in residential buildings from households across the United States. The survey has a section devoted to appliance usage, including residential clothes washer usage. The survey asked respondents to identify the average number of loads per week that they wash, with response options of 1 or fewer, 2 to 4, 5 to 9, 10 to 15, and more than 15 loads per week. DOE assigned a representative average number of wash cycles per year to each of these response categories, and calculated the weighted average. Using this method, DOE determined that the data show an average of 295 wash cycles per year.

DOE is aware that the “California Residential Appliance Saturation Survey” (California RASS) from 2004 also provides data on the use of residential appliances. For clothes washer use, the survey asks for the number of loads washed in the household during a typical week using hot, warm, and cold wash water temperature settings. There are 11 response options, ranging from zero to 10+ per week. DOE summed the average number of wash loads per week for each water temperature and scaled this weekly value to an annual value to determine the average number of wash cycles per year. Using this method, the California RASS data show an average of 283 wash cycles per year.

P&G also supplied DOE with data on typical consumer use of clothes washers. The P&G data show an average of 308 wash cycles per year. DOE review determined that the P&G data set contains fewer single-person households and more multiple-person households than the 2005 RECS data, which more closely approximates the household sizes shown in the latest sampling performed by the U.S. Census Bureau and the American Housing Survey in 2007.
15

DOE believes that the larger average household size in the P&G study could lead to the higher average annual wash cycles value found in the P&G data.

15
Information on the American Housing Survey can be found on the U.S. Census Bureau Web site at
http://www.census.gov/hhes/www/housing/ahs/ahs.html
.

In today's notice, DOE is proposing 295 as the representative number of wash cycles per year based on the 2005 RECS data. DOE believes this is a more representative value than the results of the California RASS because the survey is nationwide rather than limited to a single State. DOE also believes the 2005 RECS value is more representative of average use than the value based on the P&G study due to the household size distribution of the data sets. Overall, however, the relatively small variation among the three estimates of annual clothes washer cycles supports DOE's tentative conclusion that 295 cycles per year is a reasonable value to include in its clothes washer test procedure.

DOE welcomes comment on whether 295 wash cycles per year is representative of typical consumer use, and whether the 2005 RECS is an appropriate source of data for this issue. DOE also seeks any additional data relevant to the representative number of annual clothes washer cycles.

b. Test Load Size Specifications

The current DOE clothes washer test procedure specifies the test load size for the active washing mode energy tests based on the clothes washer's container volume. The table specifying the test load sizes in the test procedure, Table 5.1, currently only covers clothes washer container volumes up to 3.8 ft
3
. DOE is aware that multiple clothes washers available on the market have container volumes exceeding 3.8 ft
3
.

ALS commented in response to the August 2009 framework document that it supports revising Table 5.1 to account for larger capacities because larger capacity clothes washers exist in the marketplace, for which Whirlpool filed a petition for waiver on November 21, 2005. 71 FR 48913. ALS also stated that it supports Whirlpool's petition. (ALS, No. 12 at p. 1) AHAM and Whirlpool commented that DOE should expand Table 5.1 to include washer capacities up to 6 ft
3
. AHAM stated that the larger capacities should be addressed by continuing the linear relationship used in the current table. (AHAM, No. 15 at p. 2; Whirlpool, No. 21 at p. 1)

DOE also received comments from the Joint Comment and ASE opposing the expansion of the test load size specifications to cover container volumes up to 6 ft
3
unless DOE verifies the validity of the calculations used in Table 5.1 with current consumer data. Specifically, these commenters request that DOE verify the average load calculations across machines of different capacities. These commenters also stated that DOE should ensure that the calculations do not introduce a bias favoring clothes washers with larger capacities. (Joint Comment, No. 14 at pp. 1-2; ASE, No. 22 at p. 1)

In response to Whirlpool's November 2005 request for waiver, DOE granted an interim test procedure waiver to Whirlpool for three of Whirlpool's clothes washer models with container capacities greater than 3.8 ft
3
. 71 FR 48913 (August 22, 2006). This notice contained an alternate test procedure, which extended the linear relationship between maximum test load size and clothes washer container volume in Table 5.1 to include a maximum test load size of 15.4 pounds (lbs) for clothes washer container volumes of 3.8 to 3.9 ft
3
.

DOE is aware of limited data regarding typical clothes washer load sizes. In 2003, P&G conducted a survey on load size with 510 respondents, comprising 3367 loads of laundry. The data from this survey show an average load size of 7.2 lbs for top-loading machines, and 8.4 lbs for front-loading machines. These load sizes correspond to the average test loads for the 2.7-2.8 ft
3
and 3.3-3.4 ft
3
clothes washer capacity bins, respectively, in Table 5.1. These results are consistent with the shipment-weighted average tub volume of 3.05 ft
3
from the 2005 AHAM
Factbook.

P&G has also noted that increases in average load size tend to correlate with increases in clothes washer capacities. DOE has found that from 1993 to 2005, tub capacities have increased by 14 percent, based on AHAM data, while the number of cycles per year has decreased by 17 percent, based on RECS data. Assuming that households continued to wash the same volume of clothes each year, the data imply that, on average, the wash loads were larger.

The limited data on this subject suggest that the current values in the test load size chart are appropriate, and extending the linear relationship between test load size and container capacity to larger capacities is valid. Thus, DOE proposes amending the clothes washer test procedure to establish test load size specifications for clothes washer container volumes up to 6.0 ft
3
. The amendment would be based on a continuation of the linear relationship between test load size and clothes washer container volume currently in the DOE clothes washer test procedure. DOE welcomes comment on the proposed test load sizes, including whether the linear relationship between test load size and clothes washer container volume is representative of actual consumer use, and additional consumer use data relevant to this topic.

c. Use Factors

The clothes washer test procedure relies on use factors to weight different consumer behaviors in the overall energy and water consumption calculations. The factors are based on consumer use data and represent the fraction of all cycles that are run with certain settings or characteristics. The use factors in the test procedure cover wash and rinse temperatures, load sizes, and dryer use.

DOE received comments from the Joint Comment and ASE regarding usage factors in the current clothes washer test procedure. They stated that DOE should validate the use factors for minimum, average, and maximum loads, TUFs, and the DUF based on current data. They also stated that DOE should verify that the current use factors for load size—12 percent for minimum load size, 74 percent for average load size, and 14 percent for maximum load size—do not introduce a systematic bias favoring large capacity clothes washers. These factors also might not reflect current consumer usage because they were established in the 1990s and because the assumed downward trend in the number of annual wash cycles may indicate that loads are, on average, larger. The Joint Comment and ASE also suggested that DOE should reassess the load adjustment factor (LAF) used in the RMC calculation. This factor is intended to represent the ratio of maximum load size to average load size, but a fixed value of 0.52 is used despite the ratio changing as capacity increases according to the data in Table 5.1. (Joint Comment, No. 14 at pp. 1-3; ASE, No. 22 at p. 1)

DOE's responses to these comments on use factors are discussed separately in the following sections.

i. Load Size Use Factors

The load size use factors in the DOE test procedure represent the fraction of all wash cycles a typical consumer runs for the minimum, average, and maximum load sizes. DOE is not aware of recent data characterizing such usage patterns. Therefore, DOE is not proposing in today's notice to change the load size use factors. DOE welcomes input and data on consumer selection of load sizes.

ii. Temperature Use Factors

As stated in section III.D.1.a, DOE proposes amending the TUFs in its clothes washer test procedure to account for steam wash cycles, and to revise the warm rinse TUF. DOE believes the steam wash cycle TUF only affects the extra hot TUF, leaving the other TUFs unchanged.

Among the limited data on consumer wash and rinse temperature selections, the 2005 RECS and the 2004 California RASS both provide some information on temperature selections. However, each of these surveys only disaggregate temperature use into hot, warm, and cold cycle settings, providing no information on extra hot or steam use. Further, the RECS questionnaire asks respondents only for the water temperature selections usually used for the wash and rinse cycles of a clothes washer, which may not account for the less-frequent use of the hot wash cycle. Hot wash cycles are generally used for the most heavily soiled loads, which DOE believes would not represent the water temperature selection usually used by consumers. As a result, the 2005 RECS data may support a hot wash use factor that is lower than the actual value. The California RASS questionnaire asks for the number of wash loads per week typically washed at hot, warm, and cold temperature settings. While this phrasing captures the use of all three temperature selections, the California RASS only represents one State, and may not reflect consumer use nationwide. Table III.5 compares the TUFs from these two surveys with the current values in the DOE clothes washer test procedure for hot, warm, and cold washes, and for warm rinse.

Table III.5—Temperature Use Factors

Temperature setting
TUF, current test procedure
TUF, 2005 RECS
TUF, 2004 California RASS

Hot Wash
0.14
0.062
0.2

Warm Wash
0.49
0.542
0.41

Cold Wash
0.37
0.397
0.39

Warm Rinse
0.27
0.2
N/A

Because the factors from each source demonstrate general agreement, DOE believes that the TUFs in its test procedure are a reasonable estimate of current consumer use. While DOE is therefore proposing to amend only the TUFs for clothes washers offering a steam wash cycle as discussed in section III.D.1.a and shown in Table III.4, DOE welcomes comment on the proposed TUFs.

DOE also notes that it has recently received consumer usage survey data from a manufacturer which indicate that, for one clothes washer model with no cold rinse option on the cycle recommended for cotton clothes and a default cold rinse on all other cycles, users participating in the survey reported using warm rinse for 1.6 percent of all cycles. Although DOE does not believe that this conclusion necessarily applies to all consumers and residential clothes washer models, it remains open to considering the warm rinse TUF and welcomes further data

regarding consumer usage of warm rinse.

In addition, DOE proposes to revise the methods for measuring warm rinse and incorporating the revised measurement into the test procedure's calculations. The current test procedure addresses warm rinses by applying a TUF of 0.27 to account for the incremental energy consumption of a warm rinse over that of a cold rinse. This indicates that 27 percent of all loads across all temperatures use a warm rinse. Because the test procedure incrementally accounts for warm rinses, the relevant provisions require the measurement of hot water consumption for the warm rinse only and the measurement of the electrical energy consumed by the clothes washer to heat the rinse water only. For some clothes washers, though, it is not entirely clear when water consumption for the wash cycle ends and rinse begins because multiple fill and drain events may occur in various sequences.

To address this uncertainty, DOE believes that it is more appropriate to measure energy and water consumption over an entire cycle that utilizes warm rinse. DOE believes that most clothes washers currently available on the market allow users to select a warm rinse only with a warm wash cycle. DOE is, therefore, proposing to establish a TUF for a full warm wash/warm rinse cycle and to eliminate the incremental use factor currently attributed to warm rinse. DOE believes that the value of this incremental use factor of 0.27 would represent a valid TUF for the warm wash/warm rinse cycle. For those clothes washers with such an option, DOE is also proposing to decrement the warm wash/cold rinse TUF by a corresponding amount, reducing it from 0.49 to 0.22. DOE further proposes that the warm wash/warm rinse TUF would not be applicable for clothes washers with one or two wash temperature settings because these washers would not be capable of warm wash.

DOE is not proposing to amend the TUFs for wash temperature selections other than the warm wash. Additionally, the proposed TUFs for warm/cold and warm/warm sum to the current warm wash TUF. Overall, the warm wash temperature selection would receive the same weight in the energy and water consumption calculations.

DOE recognizes that not all clothes washers offer a warm/warm temperature selection under the normal wash cycle setting recommended for washing cotton or linen clothes (hereafter, the “Normal” setting). For these clothes washers, if a warm/warm cycle is available in any other wash cycle setting that employs agitation/tumble operation, spin speed(s), wash times, and rinse times that are largely similar to the “Normal” cycle, the warm/warm cycle would be tested using the wash cycle setting that would best reflect typical consumer use. Under the current test procedure, only the hot water consumption for the warm rinse and the electrical energy consumed by the clothes washer to heat the rinse water are required to be measured for this cycle. The proposed test procedure would require measuring energy and water consumption over the complete warm wash/warm rinse cycle. As a result, MEF measured under the current test procedure could differ from the MEF measured with under the proposed revisions. During the ongoing energy conservation standards rulemaking, DOE expects to analyze potential effects of the proposed warm rinse methodology on measured MEF and incorporate any such effects, as appropriate, into any amended standards.

As stated above, DOE welcomes comment on these proposed TUFs, including steam wash and warm wash/warm rinse cycles, and on whether any other consumer use data regarding temperature setting selection is available. DOE also requests comment and any relevant data on whether the proposed method of incorporating warm rinse would affect MEF ratings.

iii. Dryer Use Factor

DOE investigated whether the DUF of 0.84 in its clothes washer test procedure reflects current consumer usage. The 2005 RECS includes data on both clothes washer and clothes dryer use. As stated previously in section III.D.2.a, AHAM and Whirlpool both commented in support of using RECS data for representative annual cycles, because they believe no other alternative data set is available. (AHAM, No. 15 at p. 6; Whirlpool, No. 21 at p. 7)

Analysis of the RECS data shows that, for households with both a clothes washer and dryer, the average DUF is 0.96. For all households with a clothes washer, the average DUF is 0.91. This use factor is lower because it includes households with only a clothes washer and no dryer. DOE also analyzed the 2004 California RASS to determine that its data show a DUF of 0.86 for households with both a clothes washer and dryer. This dryer use factor is based on 283 clothes washer cycles per year as supported by the California RASS, not the proposed 295 cycles per year in today's NOPR. Including households without a clothes dryer, the California RASS data show a DUF of 0.76.

DOE proposes amending its clothes washer test procedure to include a DUF of 0.91, based on the 2005 RECS. DOE is proposing 0.91 rather than 0.96 because the clothes washer test procedure aims to estimate the energy use of all clothes washers, regardless of clothes dryer ownership. DOE is proposing to use the value derived from the 2005 RECS rather than the 2004 California RASS to be consistent with the proposed number of wash cycles per year and because, as stated in section III.D.2.a, the RECS data represent the entire country rather than one State. DOE welcomes comment on the proposed value of 0.91 for the DUF and using the RECS data to calculate this value.

iv. Load Adjustment Factor

Load Adjustment Factor (LAF) represents the ratio of maximum load size to average load size. This ratio is used in the calculation of the energy required to remove moisture from the test load. The RMC value used in this calculation is based only on tests using the maximum test load, so the LAF is used to scale this value down to the average load size. DOE lacks information warranting adjusting this value or changing it from a fixed value to one that varies as a function of average load size, and is therefore not proposing to amend the LAF in the test procedure. DOE welcomes comments on appropriate adjustments that could be made to the LAF.

3. Test Cloth

The current clothes washer test procedure requires the use of closely-specified test cloth for the energy test cycles. The test cloth affects the calculated energy consumption largely through the RMC value. RMC is calculated as the ratio of the weight of water absorbed by the test cloth after a complete energy cycle to the initial weight of the “bone dry” test cloth, multiplied by 100 percent. The RMC is then used to calculate the per-cycle energy consumption for removal of moisture from the test load. Because the test cloth plays a central role in determining energy consumption, the test procedure includes provisions to ensure consistent and accurate results. The test cloth characteristics can vary based on production lot, or even within the same lot, so the test procedure includes a calibration procedure to provide consistent results for all test cloth.

DOE received multiple comments in response to the August 2009 framework

document regarding the test cloth used in its clothes washer test procedure. ALS commented that DOE should revise the test procedure to improve test cloth calibration auditing. (ALS, No. 12 at p. 1) AHAM submitted detailed comments on this issue, including a proposal it sent to DOE on September 22, 2008, that addresses energy test cloth tolerances, provides additional detail for determining RMC, and removes redundant sections regarding preconditioning the test cloths. AHAM also commented that DOE should provide guidance and/or support on the annual test cloth correlation work, including a proposal for the creation of a DOE Test Cloth Advisory Panel. (AHAM, No. 15 at pp. 2, 10, 14-18, 34) In a letter to DOE sent March 29, 2010, AHAM confirmed that the AHAM DOE Test Cloth Task Force, which includes AHAM members, BSH, Electrolux Home Products, GE, Samsung, Whirlpool, and SDL Atlas, supported the test cloth-related changes to the test procedure that were proposed in AHAM's comments submitted for the framework document. Whirlpool commented in support of the AHAM test cloth proposal. Whirlpool also commented that DOE should provide guidance and/or support on the test cloth issues not addressed by the current test cloth supplier, which include quality, correlation coefficients, and the availability of new fabric lots. (Whirlpool, No. 21 at pp. 1-2)

DOE believes that the test cloth specifications that AHAM proposed represent the industry's consensus on the available means to limit uncertainty in the test procedure due to variations in the test cloth properties. DOE is therefore proposing to update the sections of the test procedure regarding test cloth to reflect the changes in September 22, 2008, proposal included in the AHAM comment and supported by Whirlpool and the Test Cloth Task Force. The current test procedure does not specify any tolerances for the size and weight of the energy test cloths. DOE is proposing the following tolerances:

• In section 2.6.1, “Energy Test Cloth,” the energy test cloth shall be 24 ±
1/2
inches by 36 ±
1/2
inches (61.0 ± 1.3 cm by 91.4 ± 1.3 cm) and hemmed to 22 ±
1/2
inches by 34 ±
1/2
inches (55.9 ± 1.3 cm by 86.4 ± 1.3 cm) before washing;

• In section 2.6.2, “Energy Stuffer Cloth,” the energy stuffer cloth shall be 12 ±
1/4
inches by 12 ±
1/4
inches (30.5 ± .6 cm by 30.5 ± .6 cm) and hemmed to 10 ±
1/4
inches by 10 ±
1/4
inches (25.4 ± .6 cm by 25.4 ± 0.6 cm) before washing; and

• In section 2.6.4.2, the fabric weight specification shall be 5.60 ± 0.25 ounces per square yard (190.0 ± 8.4 g/m
2

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A2010-22225. Public record. Not legal advice.