Energy Conservation Program for Consumer Products: Test Procedures for Residential Dishwashers, Dehumidifiers, and Conventional Cooking Products (Standby Mode and Off Mode)
Federal RegisterDec 2, 2010
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket No. EERE-2010-BT-TP-0039]
RIN: 1904-AC27
Energy Conservation Program for Consumer Products: Test Procedures for Residential Dishwashers, Dehumidifiers, and Conventional Cooking Products (Standby Mode and Off Mode)
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Notice of proposed rulemaking and announcement of public meeting.
SUMMARY:
In order to implement recent amendments to the Energy Policy and Conservation Act of 1975 (EPCA), the U.S. Department of Energy (DOE) proposes to amend its test procedures for residential dishwashers, dehumidifiers, and conventional cooking products (which include cooktops, ovens, and ranges) to provide for measurement of standby mode and off mode energy use by these products. The proposed amendments would incorporate into the DOE test procedures relevant provisions from the International Electrotechnical Commission's (IEC) Standard 62301, “Household electrical appliances—Measurement of standby power,” First Edition 2005-06 (IEC Standard 62301 (First Edition)). DOE also proposes to adopt definitions of various modes of operation based on the relevant provisions from the IEC Standard 62301 “Household electrical appliances—Measurement of standby power,” Second Edition Final Draft International Standard (IEC Standard 62301 (FDIS)). In addition, DOE proposes to adopt language to clarify application of these test procedure provisions for measuring standby mode and off mode power consumption in dishwashers, dehumidifiers, and conventional cooking products. Furthermore, the proposed amendments would add new calculations to determine annual energy consumption associated with the standby mode and off mode measured power. Finally, the amendments would modify existing energy consumption equations to integrate standby mode and off mode energy consumption into the calculation of overall annual energy consumption and annual operating cost of those products which already have definitions for such measures (dishwashers and conventional cooking products). DOE is also announcing a public meeting to discuss and receive comments on the issues presented in this notice.
DATES:
Meeting:
DOE will hold a public meeting on Friday, December 17, 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., Friday, December 3, 2010. DOE must receive a signed original and an electronic copy of statements to be given at the public meeting before 4 p.m., Friday, December 10, 2010.
Comments:
DOE will accept comments, data, and information regarding the notice of proposed rulemaking (NOPR) before and after the public meeting, but no later than February 15, 2011. 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 8E-089, 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 Dishwashers, Dehumidifiers, and Conventional Cooking Products, and provide the docket number EERE-2010-BT-TP-0039 and/or Regulatory Information Number (RIN) 1904-AC27. 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-DW-Dehumid-CookingProd-2010-TP-0039@ee.doe.gov
. Include docket number EERE-2010-BT-TP-0039 and/or RIN 1904-AC27 in the subject line of the message.
3.
Postal 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 paper original.
4.
Hand Delivery/Courier:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 950 L'Enfant Plaza, SW., Suite 600, Washington, DC 20024. Telephone: (202) 586-2945. Please submit one signed paper original.
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, 950 L'Enfant Plaza, SW., Suite 600, 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. Wesley Anderson, Jr., U.S. Department of Energy, Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone: (202) 586-7335. E-mail:
Wes.Anderson@ee.doe.gov
.
Mr. Eric Stas, U.S. Department of Energy, Office of the General Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone: (202) 586-9507. E-mail:
Eric.Stas@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 Authority
II. Summary of the Proposal
III. Discussion
A. Products Covered by the Proposed Test Procedure Amendments
B. Incorporation by Reference of IEC Standard 62301 (First Edition) for Measuring Standby Mode and Off Mode Power Consumption
C. Determination and Classification of Operational Modes
D. Specifications for the Test Methods and Measurements for Standby Mode and Off Mode Testing
1. Dishwashers
2. Dehumidifiers
3. Conventional Cooking Products
E. Calculation of Energy Use Associated With Standby Mode and Off Mode
1. Dishwashers
2. Dehumidifiers
3. Conventional Cooking Products
a. Conventional Ovens
b. Conventional Cooktops
c. Conventional Ranges
F. Measures of Energy Consumption
1. Dishwashers
2. Dehumidifiers
3. Conventional Cooking Products
G. Compliance With Other EPCA Requirements
1. Test Burden
2. Potential Incorporation of IEC Standard 62087
3. Integration of Standby Mode and Off Mode Energy Consumption Into Existing Efficiency Metrics
H. Impact of the Proposed Amendments on EnergyGuide and ENERGY STAR
IV. Procedural Issues and Regulatory Review
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 Act of 1974
V. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Requests To Speak
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
1. Incorporation of IEC Standard 62301 (First Edition)
2. Operational Mode Definitions
3. Dishwasher Standby and Off Modes
4. Dehumidifier Standby and Off Modes
5. Conventional Cooking Products Standby and Off Modes
6. Network Mode
7. Default Settings
8. Test Room Ambient Temperature
9. Test Period
10. Energy Use Calculation for Standby Mode and Off Mode
11. New Integrated Measures of Energy Consumption and Energy Efficiency
VI. Approval of the Office of the Secretary
I. Background and Authority
Title III, Part B of the Energy Policy and Conservation Act of 1975 (EPCA), Public Law 94-163 (42 U.S.C. 6291-6309, as codified), established the “Energy Conservation Program for Consumer Products Other Than Automobiles,” a program covering most major household appliances, including residential dishwashers, conventional cooking products, and dehumidifiers,
1
the subjects of today's notice.
2
(42 U.S.C. 6292(a)(6) and (10); 6295(cc)) Under the Act,
3
this program consists essentially of three parts: (1) Testing; (2) labeling; and (3) Federal energy conservation standards.
1
The term “conventional cooking products,” as used in this notice, refers to residential electric and gas kitchen ovens, ranges, and cooktops (other than microwave ovens).
2
For editorial reasons, upon codification in the U.S. Code, Part B was re-designated as Part A.
3
All references to EPCA refer to the statute as amended, including through the Energy Independence and Security Act of 2007, Public Law 110-140.
Manufacturers of covered products must use DOE test procedures, prescribed under EPCA, to certify that their products comply with the energy conservation standards adopted under EPCA and to represent the energy consumption or energy efficiency of their products. (42 U.S.C. 6293(c); 42 U.S.C. 6295(s)) DOE must also use DOE test procedures in any enforcement action to determine whether covered products comply with these energy conservation standards. (42 U.S.C. 6295(s)) Criteria and procedures for DOE's adoption and amendment of such test procedures, as set forth in EPCA, require that test procedures 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. Test procedures must also not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(3))
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)) 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. (42 U.S.C. 6293(e)(2))
Dishwashers
DOE's test procedure for dishwashers is found in the Code of Federal Regulations (CFR) at 10 CFR part 430, subpart B, appendix C. DOE originally established its test procedure for dishwashers in 1977. 42 FR 39964 (August 8, 1977). Since that time, the dishwasher test procedure has undergone a number of amendments, as discussed below. In 1983, DOE amended the test procedure to revise the representative average-use cycles to more accurately reflect consumer use and to address dishwashers that use 120 °F inlet water. 48 FR 9202 (March 3, 1983). DOE amended the test procedure again in 1984 to redefine the term “water heating dishwasher.” 49 FR 46533 (Nov. 27, 1984). In 1987, DOE amended the test procedure to address models that use 50 °F inlet water. 52 FR 47549 (Dec. 15, 1987). In 2001, DOE revised the test procedure's testing specifications to improve testing repeatability, changed the definitions of “compact dishwasher” and “standard dishwasher,” and reduced the average number of use cycles per year from 322 to 264. 66 FR 65091, 65095-97 (Dec. 18, 2001). In 2003, DOE again revised the test procedure to more accurately measure dishwasher efficiency, energy use, and water use. The 2003 dishwasher test procedure amendments included the following revisions: (1) The addition of a method to rate the efficiency of soil-sensing products; (2) the addition of a method to measure standby power; and (3) a reduction in the average-use cycles per year from 264 to 215. 68 FR 51887, 51899-903 (August 29, 2003). The current version of the test procedure includes provisions for determining estimated annual energy use (EAEU), estimated annual operating cost (EAOC), energy factor (EF) expressed in cycles per kilowatt-hour (kWh), and water consumption expressed in gallons per cycle. (10 CFR 430.23(c))
The National Appliance Energy Conservation Act of 1987 (NAECA), Public Law 100-12, amended EPCA to establish prescriptive standards for dishwashers, requiring that dishwashers manufactured on or after January 1, 1988, be equipped with an option to dry without heat. (42 U.S.C. 6295(g)(1)) These EPCA amendments also mandated that DOE must conduct two rounds of rulemaking to determine whether the energy conservation standards for dishwashers should be amended. (42 U.S.C. 6295(g)(4)) On May 14, 1991, DOE issued a final rule establishing the first set of performance standards for dishwashers. 56 FR 22250. The final rule required that dishwashers manufactured on or after May 14, 1994, must have a minimum EF of 0.46 cycles per kWh for standard size, and 0.62 cycles per kWh for compact size.
Id.
at 22279; 10 CFR 430.32(f)(1).
The Energy Independence and Security Act of 2007
4
(EISA 2007) further amended EPCA, in relevant part by establishing the following energy conservation standards for residential dishwashers manufactured on or after January 1, 2010: (1) For standard size
dishwashers, a maximum annual energy use of 355 kWh per year, and a maximum water consumption of 6.5 gallons per cycle; and (2) for compact dishwashers, a maximum annual energy use of 260 kWh per year, and a maximum water consumption of 4.5 gallons per cycle. (42 U.S.C. 6295(g)(10)(A); 10 CFR 430.32(f)(2)) The amendments also specify that not later than January 1, 2015, the Secretary shall publish a final rule determining whether to amend the standards for dishwashers manufactured on or after January 1, 2018. (42 U.S.C. 6295(g)(10)(B))
4
Public Law. 110-140 (enacted Dec. 19, 2007).
Dehumidifiers
The DOE test procedure for dehumidifiers is found at 10 CFR 430, subpart B, appendix X. The Energy Policy Act of 2005 (EPACT 2005), Public Law 109-58, amended EPCA to specify that the U.S. Environmental Protection Agency's (EPA) test criteria used under the ENERGY STAR
®
5
program must serve as the basis for the test procedure for dehumidifiers. (EPACT 2005, section 135(b); 42 U.S.C. 6293(b)(13)) The ENERGY STAR test criteria require that American National Standards Institute (ANSI)/Association of Home Appliance Manufacturers (AHAM) Standard DH-1-2003, “Dehumidifiers,” be used to measure energy use and that the Canadian Standards Association (CAN/CSA) standard CAN/CSA-C749-1994 (R2005), “Performance of Dehumidifiers,” be used to calculate EF. DOE has adopted these test criteria, along with related definitions and tolerances, as its test procedure for dehumidifiers. 71 FR 71340, 71347, 71366-68 (Dec. 8, 2006). The DOE test procedure provides methods for determining the EF for dehumidifiers, which is expressed in liters (l) of water condensed per kWh.
5
For more information on the ENERGY STAR program,
see: http://www.energystar.gov
.
Section 135(c)(4) of EPACT 2005 added dehumidifiers as products covered under EPCA and established standards effective for dehumidifiers manufactured on or after October 1, 2007. (42 U.S.C. 6295(cc)(1)) Section 311 of EISA 2007 further amended EPCA to revise the energy conservation standards for dehumidifiers, establishing the following minimum EFs based on product capacity for dehumidifiers manufactured on or after October 1, 2012:
Table I.1—October 2012 Dehumidifier Energy Conservation Standards *
Product capacity
(pints/day)
Minimum EF
(liters/kWh)
Up to 35.00
1.35
35.01-45.00
1.50
45.01-54.00
1.60
54.01-75.00
1.70
75.00 or more
2.5
* (42 U.S.C. 6295(cc)(2)).
Conventional Cooking Products
DOE's test procedures for conventional ranges, cooktops, and ovens (including microwave ovens) are found at 10 CFR 430, subpart B, appendix I. DOE first established the test procedures included in appendix I in a final rule published in the
Federal Register
on May 10, 1978. 43 FR 20108, 20120-28. DOE revised its test procedure for cooking products to more accurately measure their efficiency and energy use, and published the revisions as a final rule in 1997. 62 FR 51976 (Oct. 3, 1997). These test procedure amendments included: (1) A reduction in the annual useful cooking energy; (2) a reduction in the number of self-cleaning oven cycles per year; and (3) incorporation of portions of IEC Standard 705-1988, “Methods for measuring the performance of microwave ovens for household and similar purposes,” and Amendment 2-1993 for the testing of microwave ovens.
Id.
The test procedure for conventional cooking products establishes provisions for determining EAOC, cooking efficiency (defined as the ratio of cooking energy output to cooking energy input), and EF (defined as the ratio of annual useful cooking energy output to total annual energy input). (10 CFR 430.23(i); 10 CFR part 430 subpart B, appendix I) These provisions for conventional cooking products are not currently used for compliance with any energy conservation standards (because those standards currently involve design requirements), nor is there an EnergyGuide
6
labeling program for cooking products.
6
For more information on the EnergyGuide labeling program,
see: http://www.access.gpo.gov/nara/cfr/waisidx_00/16cfr305_00.html.
DOE has initiated a separate test procedure rulemaking to address standby mode and off mode power consumption for microwave ovens. This rulemaking was initiated separately in response to comments from interested parties on the advance notice of proposed rulemaking (ANOPR) for an earlier rulemaking concerning energy conservation standards for dishwashers, dehumidifiers, cooking products, and commercial clothes washers published on November 15, 2007 (hereafter referred to as the November 2007 ANOPR) (72 FR 64432), prior to the enactment of EISA 2007. As discussed in the October 2008 test procedure NOPR, interested parties stated generally that DOE should amend the test procedures for all types of cooking products to allow for measurement of standby mode energy use in order to implement a standby power energy conservation standard. 73 FR 62034, 62043-44 (Oct. 17, 2008). However, DOE did not receive any specific data or inputs on standby power consumption in conventional cooking products. Also, at that time, interested parties did not submit any comments regarding DOE addressing new measures of standby mode and off mode energy use in the test procedures or energy conservation standards for the other products that were the subject of the November 2007 ANOPR (
i.e.,
dishwashers and dehumidifiers.) Because DOE agreed with the comments supporting new measures of standby mode and off mode energy use for microwave ovens and the potential for early adoption of an energy conservation standard for microwave ovens addressing standby mode and off mode energy consumption, DOE published a NOPR proposing amendments to just the microwave oven test procedure for standby mode and off mode in the
Federal Register
on October 17, 2008. 73 FR 62134. DOE subsequently published a supplemental notice of proposed rulemaking (SNOPR) in the
Federal Register
on this topic on July 22, 2010. 75 FR 42612. Consequently, DOE is proposing amendments to its cooking products test procedure for only conventional cooking products in today's NOPR.
As with dishwashers, NAECA amended EPCA to establish prescriptive standards for cooking products. The NAECA amendments required gas ranges and ovens with an electrical supply cord manufactured on or after January 1, 1990, not to be equipped with a constant-burning pilot light. (42 U.S.C. 6295(h)(1)) Subsequently, DOE published a final rule in the
Federal Register
on April 8, 2009, amending the energy conservation standard for cooking products to require for products manufactured on or after April 9, 2012, that gas cooking products without an electrical supply cord shall not be equipped with a constant burning pilot light. 74 FR 16040, 16094.
Standby Mode and Off Mode
Section 310 of EISA 2007 amended EPCA to require DOE to amend the test procedures for covered products to address standby mode and off mode energy consumption. Specifically, the amendments also require DOE to integrate standby mode and off mode energy consumption into the overall energy efficiency, energy consumption, or other energy descriptor for that product unless the current test procedures already fully account for such consumption. If integration is technically infeasible, DOE must prescribe a separate standby mode and off mode energy use test procedure, if technically feasible. (42 U.S.C. 6295(gg)(2)(A)) Any such amendment must consider the most current versions of IEC Standards 62301, “Household electrical appliances—Measurement of standby power,” and IEC Standard 62087, “Methods of measurement for the power consumption of audio, video, and related equipment.”
Id.
For residential dishwashers, dehumidifiers, and conventional cooking products (and microwave ovens), DOE must prescribe any such amendment to the test procedures by final rule no later than March 31, 2011. (42 U.S.C. 6295(gg)(2)(B)(vi)) Furthermore, EISA 2007 also amended EPCA to direct DOE to incorporate standby mode and off mode energy use into any final rule establishing or revising an energy conservation standard for a covered product adopted after July 1, 2010. If it is not feasible to incorporate standby mode and off mode into a single amended or new standard, then the statute requires DOE to prescribe a separate standard to address standby mode and off mode energy consumption. (42 U.S.C. 6295(gg)(3))
DOE notes that the IEC is in the process of developing a revised version of IEC Standard 62301, which was expected to be released by July 2009. This revision is expected to be significantly delayed until late 2010 at the earliest. In order to publish a final rule by March 31, 2011, DOE is proceeding with an amended test procedure based on the current version of IEC Standard 62301 (First Edition). However, DOE is also considering the updated mode of operation definitions in the latest draft version of IEC Standard 62301, IEC Standard 62301 (FDIS). Although not formally adopted, DOE is evaluating the substance of those definitions, which are expected to be included in the final revised IEC Standard 62301 (Second Edition).
DOE acknowledges that the current dishwasher test procedure already includes definitions and testing methods for measuring standby mode power consumption similar to the IEC Standard 62301 (First Edition) provisions, but it does not include definitions and testing methods for measuring multiple standby modes and off mode power consumption. However, in today's NOPR, for the reasons discussed in section III.B, DOE proposes amendments to the current dishwasher test procedure in order to fully account for standby mode and off mode power consumption. These amendments would take into consideration the most current versions of IEC Standards 62301 and 62087.
The current DOE dehumidifier test procedure does not address energy use when the product is in standby mode and off mode. For this reason, in today's NOPR, DOE is proposing amendments to its dehumidifier test procedure to provide for the measurement of standby mode and off mode energy consumption.
The current DOE conventional cooking products test procedure does not fully account for standby mode and off mode energy consumption. However, DOE notes that the test procedures, as currently drafted, do account for standby energy use in narrow cases. The DOE conventional cooking products test procedures include provisions for determining the annual energy consumption of a continuously-operating clock, as well as the standby energy use associated with a continuously-burning pilot light for gas cooking products. Otherwise, the test procedure does not address energy use in standby mode or off mode. For this reason, in today's NOPR, DOE proposes amendments to the conventional cooking products test procedures to fully account for standby mode and off mode power consumption.
II. Summary of the Proposal
In today's NOPR, DOE proposes to amend the test procedures for dishwashers, dehumidifiers, and conventional cooking products in order to:
(1) Provide a foundation for DOE to develop and implement standards that address use of standby mode and off mode power by these products; and
(2) Address the statutory requirement to expand test procedures to incorporate measures of standby mode and off mode power consumption.
In general, DOE proposes to incorporate by reference into the test procedures for these products specific provisions from IEC Standard 62301 (First Edition) regarding test conditions and test procedures for measuring standby mode and off mode power consumption, and to include language that would clarify the application of such provisions. DOE also proposes to incorporate into each test procedure the definitions of “active mode,” “standby mode,” and “off mode” that are based on the definitions for those terms provided in IEC Standard 62301 (FDIS). Further, DOE proposes to include in each test procedure additional language that would clarify the application of clauses from IEC Standard 62301 (First Edition) for measuring standby mode and off mode power consumption.
7
7
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). However, IEC Standard 62087 addresses the methods of measuring the power consumption of audio, video, and related equipment. As explained subsequently in this notice, the narrow scope of this particular IEC standard reduces its relevance to today's proposal.
As an initial matter, DOE had to analyze a number of product-specific modes in order to determine whether they should be characterized as active mode, standby mode, or off mode functions. As discussed in further detail below, this rulemaking is limited to addressing standby mode and off mode. Based upon the results of its analyses, DOE is proposing the following product-specific amendments to the applicable DOE test procedures. For dishwashers, DOE is proposing definitions for the following different standby modes: (1) A general “inactive” mode; and (2) a “cycle finished” mode. For dehumidifiers, DOE is proposing definitions for the following different standby modes: (1) a general “inactive” mode; (2) an “off-cycle” mode; and (3) a “bucket full/removed” mode. For conventional cooking products, DOE is also proposing definitions for the following different standby modes: (1) A general “inactive” mode; and (2) a “cycle finished” mode. For each product, energy use in each standby mode, as well as energy use in the off mode, would be separately tested under the appropriate procedure and incorporated into an integrated energy efficiency metric for that product.
The current DOE dishwasher test procedure already includes provisions for measuring standby power and includes it in the EAEU and EAOC calculations. However, as discussed earlier, DOE is proposing amendments to the dishwasher test procedure, pursuant to EPCA, to fully and more accurately account for standby mode and off mode power consumption based on provisions in IEC Standard 62301. As a result, DOE is proposing revisions to the EAEU and EAOC calculations to
incorporate the revised measurements of standby mode and off mode power consumption into the combined metrics for dishwashers.
For dehumidifiers, DOE is proposing in today's NOPR to:
(1) Establish a new measure of energy use to calculate the annual standby mode and off mode energy use in dehumidifiers, based on the typical hours dehumidifiers spend in these modes; and
(2) Adopt a new measure of energy efficiency (integrated energy factor (IEF)) that includes energy used in standby, off, and active modes for dehumidifiers.
For conventional cooking products, the current DOE test procedure accounts for energy used by a constant clock display (if present), which is considered as part of standby mode under the proposed definition of “standby mode.” The current test procedure also accounts for standby mode energy use of a continuously-burning pilot light for gas conventional cooking products.
8
However, DOE proposes in today's NOPR to amend the test procedure for conventional cooking products to fully account for all additional standby mode and off mode power consumption, as specified by provisions in IEC Standard 62301. DOE proposes in today's NOPR to: (1) Establish a new measure of energy use to calculate the annual standby mode and off mode energy consumption in conventional cooking products, and (2) adopt new measures of energy efficiency (IEF), annual energy consumption, and annual operating cost that include the energy used in all standby mode and off mode operations of conventional cooking products. In addition, DOE proposes additional clarifications to the testing methods for conventional cooking products to define the test duration for cases in which the measured power is not stable (
i.e.,
varies over a cycle). DOE acknowledges that the power consumption of conventional cooking product displays can vary based on the clock time being displayed, so today's proposal is drafted in a way to account for this fact, while still generating representative results.
8
DOE notes that it published a final rule in the
Federal Register
on April 8, 2009, establishing standards that prohibit continuously-burning pilot lights for gas cooking products manufactured on or after April 9, 2012. 74 FR 16040, 16094.
The statute also has other provisions regarding the inclusion of standby mode and off mode energy use in any energy conservation standard which have bearing on the current test procedure rulemaking. EPCA provides that amendments to the test procedures to include standby mode and off mode energy consumption shall not be used to determine compliance with product standards established prior to the adoption of the amended test procedures. (42 U.S.C. 6295(gg)(2)(C)) However, EPCA requires that DOE must determine to what extent, if any, the proposed test procedure would alter the measured energy efficiency, measured energy use, or measured water use 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 or measured energy use of a covered product, DOE must amend the applicable energy conservation standard during the rulemaking carried out with respect to the amended test procedure. 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. (42 U.S.C. 6293(e)(2)) Although DOE remains obligated under 42 U.S.C. 6293(e)(1) to conduct an analysis of the impact of the test procedure amendments, amendments to the existing energy conservation standards are not required, because the statute already explicitly provides that the test procedure amendments for standby mode and off mode shall not apply to the energy conservation standards currently in place. The following discussion assesses these anticipated impacts, as well as the pathway for regulated entities to continue to be able to ascertain, certify, and report compliance with the existing standards until such time as amended standards are established which comprehensively address standby mode and off mode energy consumption.
For dishwashers, the current energy conservation standards (10 CFR 430.32(f)) are based on EAEU, which includes a simplified measure of standby mode power consumption. Because today's proposed amendments would revise the calculations for EAEU and EAOC, both of which currently incorporate standby mode power, DOE investigated how the proposed amendments would affect the measured efficiency. As discussed in section III.G, DOE has tentatively determined that the proposed amendments in today's NOPR would not measurably alter the measured efficiency of dishwashers. In addition, the proposed amendments would clarify that the amended calculations for EAEU need not be performed to demonstrate compliance with the existing energy conservation standards until the compliance date of amended energy conservation standards for dishwashers which take into account standby mode and off mode energy use. The proposed amendments would also require that any representations as to standby mode and off mode energy use must use the amended calculations for EAEU and EAOC on or after a date 180 days after publication of the test procedure final rule. The amended test procedure, therefore, would still be able to be used by manufacturers to certify compliance of existing dishwashers with the current energy conservation standards.
The current Federal energy conservation standards for dehumidifiers (10 CFR 430.32(v)), which are based on EF, do not currently account for standby mode or off mode power consumption. DOE proposes to establish a new integrated efficiency metric (integrated annual energy use) to account for standby mode and off mode power consumption. For this reason, the proposed amended test procedure would not alter the existing energy efficiency descriptor and, therefore, would not affect a manufacturer's ability to demonstrate compliance with previously established standards for dehumidifiers.
As noted earlier, the current energy conservation standards for cooking products (10 CFR 430.32(j)) require only that gas cooking products with an electrical supply cord not be equipped with a constant-burning pilot light. The same requirement applies to gas cooking products without an electrical supply cord, beginning on April 9, 2012. There are currently no performance-based Federal energy conservation standards for conventional cooking products (including energy use in standby mode and off mode). Thus, given the design standard currently in place, the proposed test procedure amendments would not alter one's ability to comply with the existing energy conservation standard for cooking products.
These amended test procedures would become effective in terms of adoption into the CFR, 30 days after the test procedure final rule is published in the
Federal Register
. However, DOE is proposing added language to the regulations codified in the CFR that would state that any added procedures and calculations for standby mode and off mode energy consumption resulting from implementation of the relevant provisions of EISA 2007 need not be performed at this time to determine compliance with the current energy conservation standards. Subsequently, manufacturers would be required to use
the amended test procedures' standby mode and off mode provisions to demonstrate compliance with DOE's energy conservation standards on the mandatory compliance date of a final rule establishing amended energy conservation standards for dishwasher, dehumidifier, and conventional cooking products that address standby mode and off mode energy consumption, at which time the limiting statements in the DOE test procedures would be removed. Further clarification would also be provided that as of 180 days after publication of a test procedure final rule, any representations related to the standby mode and off mode energy consumption of these products must be based upon results generated under the applicable provision of these test procedures. (42 U.S.C. 6293(c)(2))
As noted above, pursuant to its statutory mandate under 42 U.S.C. 6295(gg)(2), DOE is only addressing issues related to standby mode and off mode energy use in the current test procedure rulemaking for residential dishwashers, dehumidifiers, and conventional cooking products. For issues that are determined to relate to active mode energy use for any of these products, DOE will consider such amendments in a future test procedure rulemaking under section 302 of EISA 2007. Specifically, under that provision, DOE is required to review test procedures for covered products not later than every 7 years and to determine whether the test procedures accurately and fully comply with the requirement that they produce test results which are representative and not unduly burdensome to conduct. (42 U.S.C. 6293(b)(1))
III. Discussion
A. Products Covered by the Proposed Test Procedure Amendments
Today's proposed amendments to the DOE test procedures cover dishwashers, which DOE defines as follows:
“
Dishwasher
means a cabinet-like appliance which with the aid of water and detergent, washes, rinses, and dries (when a drying process is included) dishware, glassware, eating utensils, and most cooking utensils by chemical, mechanical and/or electrical means and discharges to the plumbing drainage system.” 10 CFR 430.2.
Today's proposed amendments to the DOE test procedures also cover dehumidifiers, which DOE defines as follows:
“
Dehumidifier
means a self-contained, electrically operated, and mechanically refrigerated encased assembly consisting of—
(1) A refrigerated surface (evaporator) that condenses moisture from the atmosphere;
(2) A refrigerating system, including an electric motor;
(3) An air-circulating fan; and
(4) Means for collecting or disposing of the condensate.”
Id.
Today's proposed amendments to the DOE test procedures also cover cooking products, specifically conventional cooking products, which are defined as:
“
Cooking products
means consumer products that are used as the major household cooking appliances. They are designed to cook or heat different types of food by one or more of the following sources of heat: Gas, electricity, or microwave energy. Each product may consist of a horizontal cooking top containing one or more surface units and/or one or more heating compartments. They must be one of the following classes: Conventional ranges, conventional cooking tops, conventional ovens, microwave ovens, microwave/conventional ranges and other cooking products.”
“
Conventional cooking top
means a class of kitchen ranges and ovens which is a household cooking appliance consisting of a horizontal surface containing one or more surface units which include either a gas flame or electric resistance heating.”
“
Conventional oven
means a class of kitchen ranges and ovens which is a household cooking appliance consisting of one or more compartments intended for the cooking or heating of food by means of either a gas flame or electric resistance heating. It does not include portable or countertop ovens which use electric resistance heating for the cooking or heating of food and are designed for an electrical supply of approximately 120 volts.”
“
Conventional range
means a class of kitchen ranges and ovens which is a household cooking appliance consisting of a conventional cooking top and one or more conventional ovens.”
Id.
DOE is not proposing any amendments to these definitions in today's notice.
B. Incorporation by Reference of IEC Standard 62301 (First Edition) 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 test procedures. (42 U.S.C. 6295(gg)(2)(A)) DOE notes that IEC Standard 62301 includes provisions for measuring standby power in electrical appliances, and, thus, is relevant to this rulemaking. 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 dishwashers, dehumidifiers, or conventional cooking products. Therefore, DOE has tentatively determined that IEC Standard 62087 is unsuitable to this rulemaking and has not included any of its provisions in today's proposed test procedure amendments.
DOE proposes to incorporate by reference into these test procedures specific clauses from IEC Standard 62301 (First Edition) for measuring standby mode and off mode power. Specifically, two clauses provide test conditions and test procedures for measuring the average standby mode and average off mode power consumption. Section 4 of IEC Standard 62301 (First Edition) specifies test room conditions, supply voltage waveform, and power measurement meter tolerances, thereby ensuring repeatable and precise measurements of standby mode and off mode power consumption. Section 5 of IEC Standard 62301 (First Edition), regarding test procedures, specifies methods for measuring power consumption when it is stable and unstable (
i.e.,
varies over a representative cycle).
Specifically, DOE proposes to incorporate by reference into the DOE test procedures for dishwashers, dehumidifiers, and conventional cooking products the following provisions from IEC Standard 62301 (First Edition):
Table I.2—Provisions From IEC Standard 62301 (First Edition) Proposed to be Incorporated by Reference
Section
Paragraph
4. General conditions for measurements
4.2 Test room.
4.4 Supply voltage waveform.
4.5 Power measurement accuracy.
5. Measurements
5.1 General, Note 1.
5.2 Selection and preparation of appliance or equipment.
5.3 Procedure.
DOE notes that the current dishwasher test procedure already includes testing methods for measuring standby power consumption that are very similar to the provisions in IEC Standard 62301 (First Edition). However, DOE also notes that the current dishwasher test procedure does not contain provisions for measuring multiple standby modes or an off mode. EPCA, as amended by EISA 2007, requires DOE to amend its test procedures for all covered products to fully account for and incorporate standby mode and off mode energy consumption, and to consider the most current version of IEC Standard 62301 as it does so. (42 U.S.C. 6295(gg)(2)(A)) As discussed below, DOE proposes to amend the dishwasher test procedure to include new definitions of “standby mode,” “off mode,” and “active mode” based on the provisions in IEC Standard 62301 (FDIS). DOE also analyzed the current DOE dishwasher test procedure to determine if any other amendments would be necessary. The analysis has led DOE to tentatively conclude that the proposed clauses from IEC Standard 62301 (First Edition) presented earlier would clarify the dishwasher testing procedure, as well as produce representative and repeatable test results.
As discussed in Section I, the current DOE conventional cooking products test procedure does not fully account for standby mode and off mode energy consumption. The test procedure accounts only for the annual energy consumption of a continuously-operating clock, and the standby energy use associated with a continuously-burning pilot light for gas cooking products. Otherwise, this test procedure does not address energy use in standby mode or off mode. For this reason, DOE has tentatively concluded that adopting the clauses from IEC Standard 62301 (First Edition) as proposed would provide for a test procedure that would produce representative and repeatable test results that would fully account for standby mode and off mode energy consumption.
As also discussed in section I, the current DOE dehumidifier test procedure does not contain any provisions for measuring energy use in standby mode or off mode. DOE has tentatively concluded that adopting the clauses from IEC Standard 62301 (First Edition) as proposed would provide for a test procedure that would produce representative and repeatable test results that would fully account for the standby mode and off mode energy consumption of dehumidifiers.
DOE invites comment on whether IEC Standard 62301 (First Edition) can adequately measure standby mode and off mode power consumption for dishwashers, dehumidifiers, and conventional cooking products, and whether these specific provisions should be incorporated into the test procedures.
DOE is aware that the EPCA requirement to consider IEC Standard 62301 in developing amended test procedures to include standby mode and off mode power consumption results in a potential conflict between the EPCA and IEC Standard 62301 (FDIS) definitions of “standby mode.” EPCA defines “standby mode” as the condition in which a product is connected to a main power source and offers one or more of the following user-oriented or protective functions: (1) To facilitate the activation or deactivation of other functions (including active mode) by remote switch (including remote control), internal sensor, or timer; and/or (2) to provide continuous functions, including information or status displays (including clocks) or sensor-based functions. (42 U.S.C. 6295(gg)(1)(A)(iii)) However, paragraph 3.1 of the IEC Standard 62301 (First Edition) 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.” Finally, DOE adopted a third definition prior to EISA 2007 for “standby mode” nearly identical to that of IEC Standard 62301 (First Edition) in the dishwasher test procedure, in which “standby mode” “means the lowest power consumption mode which cannot be switched off or influenced by the user and that may persist for an indefinite time when the dishwasher is connected to the main electricity supply and used in accordance with the manufacturer's instructions.” (10 CFR part 430, subpart B, appendix C, section 1.14) However, DOE is free to resolve any such conflict, because EISA 2007 specifically grants authority to amend the statutory definitions of “active mode,” “off mode,” and “standby mode.” (42 U.S.C. 6295(gg)(1)(B)) DOE notes that the statute requires consideration of the most current version of IEC Standard 62301, but it does not require its adoption if DOE determines that another definition(s) would be more appropriate.
Although 42 U.S.C. 6295(gg)(2)(A) requires that DOE consider the most current version of IEC Standard 62301, DOE notes that the IEC is developing an updated version of this standard, IEC Standard 62301 (Second Edition). This updated version of IEC Standard 62301 is expected to include definitions of “off mode,” “network mode,” and “disconnected mode,” and it would also revise the current IEC Standard 62301 (First Edition) definition of “standby mode.” However, the IEC anticipates that the final version of IEC Standard 62301 (Second Edition) will likely be published only in late 2010 at the earliest. Therefore, for this proposed rule, the second edition is not available for DOE's consideration or incorporation by reference. Thus, IEC Standard 62301 (First Edition) is the “current version” for purposes of 42 U.S.C. 6295(gg)(2)(A).
DOE is aware that there are significant differences between IEC Standard 62301 (First Edition) and IEC Standard 62301 (FDIS), which is the latest draft version of IEC Standard 62301 (Second Edition). For example, IEC Standard 62301 (FDIS) clarifies certain provisions, such as clarifying the definition of “standby mode” and “off mode” to allow for the measurement of multiple standby power modes.
DOE has reviewed IEC Standard 62301 (FDIS) and anticipates that, once finalized, it will ultimately define the
various modes differently than IEC Standard 62301 (First Edition). IEC Standard 62301 (FDIS) incorporates responses to comments from multiple national committees from member countries on several previous draft versions, and thus, DOE believes, it provides the best available mode definitions. Although the revised IEC Standard 62301 (Second Edition) has not yet been officially released, DOE has decided to consider the substance of the new operational mode definitions from the draft version IEC Standard 62301 (FDIS). DOE notes that the mode definitions in IEC Standard 62301 (FDIS) are substantively similar to those in the previous draft version (IEC Standard 62301 (CDV)), which were the subject of extensive comments from interested parties during recent DOE test procedure rulemakings addressing standby mode and off mode energy use in other products (
i.e.,
microwave ovens, clothes dryers, and room air conditioners). In those instances, interested parties indicated general support for adopting the mode definitions provided in IEC Standard 62301 (CDV). Due to the effective equivalence of the mode definitions in IEC Standard 62301 (CDV) and IEC Standard 62301 (FDIS), DOE believes the public comment support expressed for the mode definitions in IEC Standard 62301 (CDV) would extend to those in IEC Standard 62301 (FDIS).
DOE notes that other significant changes in the methodology were first introduced only at the IEC Standard 62301 (FDIS) stage. These changes have not been the subject of significant public comment from interested parties, nor has DOE had the opportunity to conduct a thorough analysis of those provisions. Consequently, the merits of these latest changes have not been fully vetted, as would demonstrate that they are preferable to the existing methodological provisions in the current version of the IEC standard. Thus, DOE is not able to determine whether the updated methodology represents the best available means to measure standby mode and off mode energy use, so DOE has tentatively decided to base the proposed test procedure amendments (other than the mode definitions previously discussed) on the provisions of IEC Standard 62301 (First Edition).
After considering the most current version of IEC Standard 62301 (
i.e.,
the First Edition) and the draft version of IEC Standard 62301 (
i.e.,
FDIS), DOE has tentatively concluded that the definitions of “standby mode,” “off mode,” and “active mode” provided in IEC Standard 62301 (FDIS) are the most useful, in that they expand upon the EPCA mode definitions and provide additional guidance as to which functions are associated with each mode. Therefore, DOE is proposing definitions of “standby mode,” “off mode,” and “active mode” based on the definitions provided in IEC Standard 62301 (FDIS). These definitions are discussed in detail immediately below in section III.C.
C. Determination and Classification of Operational Modes
As stated earlier, without further clarification, regulated parties' attempts to reconcile differences between the mode definitions specified by EPCA and IEC Standard 62301 (First Edition) could lead to multiple interpretations. Therefore, DOE is proposing regulatory definitions for these key terms in order to ensure consistent application of the test procedure provisions related to standby mode and off mode. This section first discusses these overarching definitional changes and then follows with a product-specific analysis of different operational modes in order to determine whether they are active mode, standby mode, or off mode functions. DOE's proposed approach is set forth below.
EPCA defines “active mode” as the condition in which an energy-using product:
(1) Is connected to a main power source;
(2) Has been activated; and
(3) Provides one or more main functions.
(42 U.S.C. 6295(gg)(1)(A)(i))
EPCA defines “standby mode” as the condition in which an energy-using product:
(1) Is connected to a main power source; and
(2) Offers one or more of the following user-oriented or protective functions:
(a) To facilitate the activation or deactivation of other functions (including active mode) by remote switch (including remote control), internal sensor, or timer;
(b) Continuous functions, including information or status displays (including clocks) or sensor-based functions.
(42 U.S.C. 6295(gg)(1)(A)(iii))
This definition of “standby mode” differs from the one provided in IEC Standard 62301 (First Edition) by permitting the inclusion of multiple standby modes.
EPCA defines “off mode” as the condition in which an energy-using product:
(1) Is connected to a main power source; and
(2) Is not providing any standby mode or active mode function.
(42 U.S.C. 6295(gg)(1)(A)(ii))
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. For specific products with multiple functions, these broad definitions could lead to multiple interpretations. Therefore, DOE proposes to amend the test procedures to include definitions for these modes based on the definitions provided in IEC Standard 62301 (FDIS), with added provisions specific to dishwashers, dehumidifiers, and conventional cooking products. DOE's proposed approach is discussed below.
DOE proposes to define “active mode” for dishwashers, dehumidifiers, and conventional cooking products as the condition in which the energy-using product is connected to a mains power source, has been activated, and provides one or more main functions. DOE notes that section 3.8 of IEC Standard 62301 (Second Edition 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)) removed this clarification based on a comment from a member committee on IEC Standard 62301 (CD2) that the clarification conflicted with the proposed definition of “standby mode,” which would include “activation of * * * active mode by * * * timer.” However, in its response to that comment, the IEC reiterated that delay start mode is a one-off function of limited duration, even though it took action to delete the clarification in IEC Standard 62301 (CDV).
9
DOE infers this to mean that delay start mode should, therefore, be considered part of active mode. However, DOE notes that IEC Standard 62301 (FDIS) classifies delay start as a secondary function and 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, it should be considered part of active mode. Additional discussion of delay start mode is provided later in this section.
9
Compilation of comments on 59/523/CD: IEC 62301 Ed 2.0 “Household electrical appliances—Measurement of standby power” (August 7, 2009) p. 6. IEC Standards are available online at
http://www.iec.ch.
DOE also proposes the following clarifications for the range of main
functions that would be classified as active mode for each product:
Dishwashers
—“Active mode” means a mode in which the dishwasher is performing the main function of washing, rinsing, or drying (when a drying process is included) dishware, glassware, eating utensils, and most cooking utensils by chemical, mechanical and/or electrical means, or is involved in functions necessary for these main functions, such as admitting water into the dishwasher or pumping water out of the dishwasher.
Conventional Cooking Products
—“Active mode” means a mode in which a conventional cooking top, conventional oven, or conventional range is performing the main function of cooking, heating, proofing, or holding the cooking load by means of either a gas flame or electric resistance heating.
Dehumidifiers
—“Active mode” means a mode in which a dehumidifier is performing the main functions of removing moisture from ambient air by drawing moist air over a refrigerated coil using a fan, circulating air through activation of the fan without activation of the refrigeration system, or defrosting the refrigerant coil.
DOE proposes to define “standby mode” for dishwashers, dehumidifiers, and conventional cooking products as any mode in which the product 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:
10
10
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.
• To facilitate the activation of other modes (including activation or deactivation of active mode) by remote switch (including remote control), internal sensor, or timer;
• Continuous functions, including information or status displays (including clocks) or sensor-based functions.
DOE proposes the additional clarification 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 in section III.B, this definition of “standby mode” is based on the definitions provided in IEC Standard 62301 (FDIS), and expands upon the EPCA mode definitions to provide additional clarifications as to which functions are associated with each mode.
As noted earlier, the current DOE dishwasher test procedure defines “standby mode” as the lowest power consumption mode that cannot be switched off or influenced by the user and that may persist for an indefinite time when the dishwasher is connected to the main electricity supply and used in accordance with manufacturer's instructions. That definition is comparable to the definition in IEC Standard 62301 (First Edition). DOE believes that the proposed “standby mode” definition based on IEC Standard 62301 (FDIS) is preferable in that it expands upon the definition in IEC Standard 62301 (First Edition) and provides additional guidance as to what functions are associated with standby mode. For this reason, DOE proposes in today's NOPR to amend the “standby mode” definition in the dishwasher test procedure based on the definition provided in IEC Standard 62301 (FDIS). Furthermore, DOE proposes to redesignate the current DOE definition as a “simplified standby mode” in order to allow manufacturers to continue to use the existing standby mode provisions to determine compliance with the current dishwasher energy conservation standards until such time as these standards are amended to address standby mode and off mode energy use.
DOE proposes to define “inactive mode” for dishwashers, dehumidifiers, and conventional cooking products 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.
The following discussion analyzes various product-specific modes for dishwashers, dehumidifiers, and conventional cooking products to determine whether they would be properly characterized as active mode, standby mode, or off mode functions.
1. Dishwashers
DOE is aware of two additional relevant modes for dishwashers: (1) delay start mode; and (2) cycle finished mode. “Delay start mode” is defined as a mode in which activation of an active mode is facilitated by a timer. “Cycle finished mode” is defined as a mode that provides continuous status display following operation in active mode. As discussed earlier, because delay start mode is not a mode that may persist for an indefinite time, DOE believes that delay start mode would not be considered part of standby mode, but instead would be a form of active mode. DOE is not proposing amendments to the dishwasher test procedure to define “delay start mode” or to measure power consumption in this mode. DOE may consider amendments addressing delay start mode issues in a future dishwasher test procedure rulemaking conducted under the 7-year schedule requirements of the EISA 2007 amendments to EPCA. (42 U.S.C. 6293(b)(1))
Based on the proposed “standby mode” definition, cycle finished mode, a mode that provides a continuous status display and may persist for an indefinite time, would be considered as part of a standby mode. Therefore, DOE proposes in today's NOPR to define cycle finished mode for dishwashers as “a mode which provides continuous status display following operation in active mode.” Proposed provisions to measure energy use in delay start mode and cycle finished mode are discussed in section III.E.1.
2. Dehumidifiers
DOE is aware of three additional relevant modes for dehumidifiers: (1) Delay start mode; (2) off-cycle mode; and (3) bucket full/removed mode. The definition for “delay start mode” for dehumidifiers is the same as that for dishwashers. “Off-cycle mode” is defined as a mode in which a dehumidifier has cycled off its main function by humidistat or humidity sensor, does not have its fan or blower operating, and will reactivate the main function according to the humidistat or humidity sensor signal. “Bucket full/removed mode” is defined as a mode in which the dehumidifier has automatically powered off its main function by detecting when the water collection bucket is full or has been removed. For the same reasons discussed earlier for dishwashers, DOE believes that delay start mode would not be considered a standby mode, but instead would be a form of active mode. Therefore, DOE is not proposing amendments to define or to measure power consumption in “delay start mode.” DOE may consider amendments addressing delay start mode issues in a future dehumidifier test procedure rulemaking conducted under the 7-year schedule requirements of the EISA 2007 amendments to EPCA. (42 U.S.C. 6293(b)(1))
DOE believes that off-cycle mode and bucket full/removed mode are modes that may persist for an indefinite time and, under the proposed definition, would be considered as part of standby mode. Therefore, DOE proposes amending its dehumidifier test procedure to include definitions of “off-
cycle mode” and “bucket full/removed mode.” Proposed provisions to measure energy use in delay start mode, off-cycle mode, and bucket full/removed mode are discussed in section III.E.2.
3. Conventional Cooking Products
DOE is aware of three additional relevant modes for conventional cooking products: (1) Delay start mode; (2) cycle finished mode; and (3) Sabbath mode. “Delay start mode” and “cycle finished mode” are defined as for dishwashers. “Sabbath mode” is defined as a mode in which the automatic shutoff is overridden to allow for warming of pre-cooked foods during such periods as the Jewish Sabbath. For the same reasons as discussed for dishwashers and dehumidifiers, DOE believes that delay start mode would not be considered a standby mode, but instead would be a form of active mode. Therefore, DOE is not proposing amendments to define or to measure power consumption in “delay start mode.” In addition, DOE believes that the Sabbath mode function of warming food would also be considered part of the active mode. Therefore, DOE is not proposing amendments to define or to measure power consumption in “Sabbath mode.” DOE may consider amendments addressing delay start mode and Sabbath mode issues in a future cooking products test procedure rulemaking conducted under the 7-year schedule requirements of the EISA 2007 amendments to EPCA. (42 U.S.C. 6293(b)(1))
DOE believes that cycle finished mode is a mode that may persist for an indefinite time and, under the proposed definition, would be considered as part of standby mode. Therefore, DOE proposes to amend its conventional cooking products test procedure to include a definition of “cycle finished mode.” Proposed provisions to measure energy use in delay start mode and cycle finished mode are discussed in section III.E.3.
As discussed in section III.B, DOE proposes to amend the test procedures for residential dishwashers, dehumidifiers, and conventional cooking products to define “off mode” as a mode in which the product is connected to a mains power source and is not providing any active mode or standby mode function, and where the mode may persist for an indefinite time. An indicator that shows the user only that the product is in the off positions is included within the classification of off mode. As noted in section III.B, this definition of “off mode” is based on the definitions provided in IEC Standard 62301 (FDIS) and is useful in terms of expanding the scope of the EPCA mode definitions to clarify which functions are associated with off mode.
Under the proposed definitions, a dishwasher, dehumidifier, or conventional cooking product 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 mode or active mode functions are energized. An energized light-emitting diode (LED) or other indication that shows the user only 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 mode or active mode functions are energized. However, if any energy is consumed by the appliance in the presence of a one-way remote control, the unit would be considered to be operating in standby mode because the remote control would be used to activate or deactivate other mode(s). Electrical leakage and any energy consumed for electrical noise reduction, which are not specifically categorized as standby power functions, would be indicative of off mode and would be measured by the proposed amended test procedures.
Section 3.7 of IEC Standard 62301 (FDIS) also 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.” Section 3.7 of 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 separately 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.”
DOE acknowledges that in the future, products that are the subject of this rulemaking could incorporate a network mode for either communication with technicians for repair and performance monitoring, or for interaction with the electric grid. At this time, however, DOE is unaware of any data that would enable it to determine appropriate testing procedures and mode definitions for incorporation into test procedures for network mode in dishwashers, dehumidifiers, and conventional cooking products. This makes it extremely difficult to consider evaluation of a networked unit, even in terms of categorizing it as a standby mode or off mode function. In particular, DOE is unaware of methods for appropriately configuring networks or methods for collecting data about the energy use of appropriately configured networks. DOE also has no information as to whether network connection speed or the number and type of network connections affect power consumption for these products. DOE also has no information as to whether wireless network devices in such products would have different levels of power consumption when a device is looking for a connection versus when the network connection is established. DOE is also unaware of how the energy consumption for dishwashers, dehumidifiers, and conventional cooking products in a network environment may be affected by their product design and user interaction, as well as network interaction. These effects would need to be measured both if the network function could become active intermittently according to a fixed schedule or in response to a network requirement. For these reasons, the amendments proposed in today's NOPR do not include provisions for testing network mode energy consumption in dishwashers, dehumidifiers, and conventional cooking products. 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 dishwashers, dehumidifiers, or conventional cooking products 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 procedures. DOE also requests comment on appropriate testing methodologies for measuring energy consumption in a network mode for dishwashers, dehumidifiers, and conventional cooking products, and data on the repeatability of those testing methodologies.
DOE also notes that section 3.9 of IEC Standard 62301 (FDIS) provides a definition for “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 off mode, standby mode, or network mode. DOE believes that there would be no energy use in a disconnected mode and agrees that it would not be part of off mode, standby mode, or network mode. Therefore, DOE is not proposing a definition or testing method for disconnected mode in the test procedures for residential dishwashers, dehumidifiers, or conventional cooking products.
D. Specifications for the Test Methods and Measurements for Standby Mode and Off Mode Testing
DOE proposes amending its test procedures to include provisions for measuring the power consumption of dishwashers, dehumidifiers, and conventional cooking products in all standby and off modes. This section first discusses issues relevant to all three types of products subject to this rulemaking, and then, it subsequently addresses issues specific to each product type. As an initial matter, DOE would clarify the provisions it proposes to include in the test procedures to clarify the IEC Standard 62301 (First Edition) methods when used to measure standby mode and off mode energy use in dishwashers, dehumidifiers, and conventional cooking products. These proposed amendments also include provisions for measuring energy use in cycle finished mode for dishwashers, off-cycle mode and bucket full/removed mode for dehumidifiers, and cycle finished mode for conventional cooking products.
For all three products, DOE is proposing a test method based on the provisions from IEC Standard 62301 (First Edition). Paragraph 5.3.1 of IEC Standard 62301 (First Edition) specifies the following test method for products in which the power varies by not more than 5 percent from a maximum level during a period of 5 minutes: (1) Wait at least 5 minutes after selecting the mode to be measured for the product to stabilize; and (2) measure the power consumption at the end of an additional time period of not less than 5 minutes.
IEC Standard 62301 (First Edition), paragraph 5.3.2, contains provisions for measuring average power in cases where the power is not stable (
i.e.,
the measured power varies by more than 5 percent from a maximum level during a period of 5 minutes). Such instances can include, for example, a clock display whose power consumption varies as a function of the time displayed or internal electronic components which are cycled on and off regularly. In such cases, IEC Standard 62301 (First Edition) requires a measurement period of no less than 5 minutes, or, if there is an operating cycle (defined as a regular sequence of power states that occur over several minutes or hours), one or more complete cycles. DOE notes these provisions do not preclude manufacturers from testing products with a longer stabilization period, or a longer measurement period, as long as the power does not vary by more than 5 percent or the stabilization period represents one or more complete cycles. DOE expects results obtained under such conditions would be comparable to those obtained using the minimum allowable stabilization and measurement periods.
DOE is aware that residential dishwashers and conventional cooking products with displays may reduce power consumption by dimming after a period of user inactivity (known as “automatic power-down”). For products whose power consumption in inactive mode 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 (First Edition), section 5, paragraph 5.1, Note 1. DOE believes that products with automatic power-down spend more time in this low-power state than in the higher-power state. Thus, the energy consumption at the low-power level is most representative of inactive mode power range.
DOE is aware that IEC Standard 62301 (First Edition) does not provide guidance on how long to wait for the appliance to drop to the lower-power state. DOE tested 14 dishwashers, 13 dehumidifiers, and 41 conventional cooking products and observed that units with an automatic power-down feature persisted in the higher-power state for less than 10 minutes of user inactivity after the display has initially been energized. However, the test sample was small and may not be sufficiently representative. It is possible that some dishwashers, dehumidifiers, and conventional cooking products may remain in the higher-power state for the duration of a 5-minute stabilization period and subsequent 5-minute measurement period, and then drop to the lower-power state that is more representative of inactive mode. In contrast, IEC Standard 62301 (CDV) specifies for each testing method that the product shall be allowed to stabilize for at least 30 minutes prior to a measurement period of not less than 10 minutes. DOE believes this specification would allow sufficient time for all displays that automatically dim or power down after a period of user inactivity to reach the lower-power state prior to measurement. 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 (First Edition). 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 mode, off mode, 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 are 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. After careful consideration, DOE has tentatively concluded 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 dishwashers, dehumidifiers, and conventional cooking products be allowed to stabilize for at least 30 minutes prior to a power measurement period of not less than 10 minutes. (For the reasons discussed in section III.D.3, DOE is proposing a choice between different methodologies for the specific case in which conventional cooking product energy use in standby mode varies as a function of the time displayed on a clock. In such case, DOE proposes to specify setting the clock to a particular start time at the
end of a 10-minute stabilization period, waiting another 10 minutes for the product again to stabilize, and then measuring standby power over a period of 10 minutes. Alternatively, DOE proposes that manufacturers, at their own discretion, may choose to measure standby power over a 12-hour period that captures all possible variations of power consumption as a function of the time displayed.) Although DOE did not observe any dehumidifiers with displays that automatically powered down, DOE is proposing the 30-minute stabilization and 10-minute power measurement periods for those products as well in order to account for currently available or future models that may have such a feature.
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 products 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. However, DOE believes the typical consumer will not alter the standard or default settings. Therefore, 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 mode energy consumption. It also welcomes comment on any testing methodologies that can account for consumer actions that might increase energy use, and requests data on the repeatability of those testing methodologies.
The following sections describe the proposed test method that is specific to each of the three products that are the subject of this rulemaking.
1. Dishwashers
DOE proposes that test room ambient temperatures for standby mode and off mode testing be specified for all dishwashers according to section 4, paragraph 4.2 of IEC Standard 62301 (First Edition). The IEC standard specifies a temperature range of 73.4 ± 9 °F. The current DOE test procedure for dishwashers includes a test room ambient air temperature requirement of 75 ± 5 °F. The narrower range of allowable ambient temperature in the DOE test procedure helps ensure consistent and repeatable test results for active mode measurements in which heat losses could affect energy consumption, but energy use in standby mode or off mode are less affected by ambient temperature. Today's proposed test procedure would allow manufacturers of dishwashers to use the more stringent ambient temperature range in the current DOE test procedure if tests of active mode efficiency performance and standby mode and off mode power consumption are conducted simultaneously in the same room on multiple dishwashers. Alternatively, the proposed temperature specifications taken from IEC Standard 62301 (First Edition) would allow a manufacturer that opts to conduct standby mode and off mode testing separately from active mode testing more latitude in maintaining ambient conditions. DOE requests comment on the appropriateness of this proposed modified test room ambient temperature range.
2. Dehumidifiers
DOE proposes that test room ambient temperatures for standby mode and off mode testing be specified for all dehumidifiers according to section 4, paragraph 4.2 of IEC Standard 62301 (First Edition). The IEC standard specifies a temperature range of 73.4 ± 9 °F. The current DOE test procedure for dehumidifiers references the ENERGY STAR test criteria for dehumidifiers. The ENERGY STAR test criteria are based on ANSI/AHAM Standard DH-1-2003, “Dehumidifiers,” which specifies a test room ambient temperature of 80 ± 2 °F for testing. Today's proposed test procedure would allow manufacturers of dehumidifiers to conduct active mode efficiency performance testing and standby mode and off mode power consumption testing simultaneously in the same room on multiple dehumidifiers, as long as the temperature requirements for both tests are met. Alternatively, the proposed temperature specifications taken from IEC Standard 62301 (First Edition) would allow a manufacturer that opts to conduct standby mode and off mode testing separately from performance testing to use the ambient temperature requirement of 73.4 ± 9 °F. DOE requests comment on the appropriateness of this proposed modified test room ambient temperature range.
DOE also proposes additional clarifications to the power supply requirements for standby mode and off mode testing for dehumidifiers to require that the power supply frequency be the rated frequency ± 1 percent. The current DOE dehumidifier test procedure requires that the power supply for the active mode test have a supply voltage of 115/230 volts (V) ± 2 percent (depending on the voltage specified on the name plate), and be at the rated frequency (no allowable range is specified for the latter). DOE notes that section 4, paragraph 4.3 of IEC Standard 62301 (First Edition) states that when IEC Standard 62301 is referenced by an external standard, the test voltage and frequency defined by the external standard shall be used. When the test voltage and frequency are not defined by the external standard, IEC Standard 62301 (First Edition) requires that the supply voltage and frequency be 115 V ± 1 percent and 60 Hertz (Hz) ± 1 percent, respectively. Because the current DOE dehumidifier test procedure specifies that the rated frequency be used for testing but does not provide an allowable range, DOE proposes that the range of ± 1 percent specified by IEC Standard 62301 (First Edition) be used for standby mode and off mode testing. DOE requests comments on its proposed amendments related to frequency.
3. Conventional Cooking Products
DOE proposes that test room ambient temperatures for standby mode and off mode testing be specified for all conventional cooking products, including cooktops, ovens, and ranges, according to section 4, paragraph 4.2 of IEC Standard 62301 (First Edition). The IEC standard specifies a temperature range of 73.4 ± 9 °F. The current DOE test procedure for conventional cooking products includes a test room ambient air temperature specification of 77 ± 9 °F. This varies slightly from the range specified by IEC Standard 62301 of 73.4 ± 9 °F. DOE believes that the higher temperatures allowed for active mode energy testing could be representative of ambient temperatures during a cooking process, but that it would be appropriate to maintain lower allowable temperatures for standby mode and off mode power consumption measurements as to be more representative of ambient conditions during those operating modes. The proposed test procedure would allow manufacturers of conventional cooking products to measure active mode performance and standby and off mode power simultaneously in the same room on multiple units, provided that the room ambient temperature falls within the range allowed by both ambient temperature requirements (
i.e.,
any temperature between 68 and 82.4 °F). Alternatively, the proposed temperature specifications from IEC Standard 62301 (First Edition) would allow a manufacturer to conduct standby mode and off mode testing separately from
performance testing within an ambient temperature range of 73.4 ± 9 °F. DOE requests comment on the appropriateness of this proposed modified test room ambient temperature range.
DOE also proposes additional clarifications to the power supply requirements for standby mode and off mode testing for conventional cooking products to require that the power supply frequency be 60 Hz ± 1 percent. The current DOE conventional cooking products test procedure requires that the power supply for the active mode test be 240/120 V ± 2 percent or 208/120 ± 2 percent (for basic models rated only at that rating), but the test procedure does not specify any power supply frequency requirements. As discussed earlier for dehumidifiers, section 4, paragraph 4.3 of IEC Standard 62301 (First Edition) states that when the test voltage and frequency are not defined, the supply voltage and frequency shall be 115 V ± 1 percent and 60 Hz ± 1 percent, respectively. Because the current DOE conventional cooking products test procedure does not specify a power supply frequency, DOE proposes that the 60 Hz ± 1 percent specified by IEC Standard 62301 (First Edition) be used for standby mode and off mode testing. DOE requests comments on its proposed amendments related to frequency.
IEC Standard 62301 (First Edition) is written to provide some flexibility so that the test standard can be used to measure standby mode and off mode power for most household electrical appliances (including conventional cooking products). For that reason, it does not specify closely the test method for measuring the power consumption in cases in which the measured power is not stable. Section 5.3.2 of IEC Standard 62301 (First Edition) states that “[i]f the power varies over a cycle (
i.e.,
a regular sequence of power states that occur over several minutes or hours), the period selected to average power or accumulate energy shall be one or more complete cycles in order to get a representative average value.” DOE investigated the possible regular sequences of power states for conventional cooking products in order to propose clarifying language to IEC Standard 62301 (First Edition) that would provide accurate and repeatable test measurements.
DOE's tests of standby power measurement in conventional cooking products indicate that a given unit or model with a clock display may use varying amounts of standby power depending on the clock time being displayed. DOE tested a small number (7) of conventional cooking products from its test sample to determine the amount of variation in power consumption that is possible due to variations in the clock time being displayed. More specifically, DOE tested the products with clock settings of 1:11 and 12:08, which represent the minimum and maximum amount of numerical display segments.
11
Table III.1 shows the test results for the products that showed significant variation in power consumption depending upon the clock's time display. According to DOE tests of conventional cooking products equipped with a 12-hour clock display, standby power use at different times during a 12-hour cycle could vary by as much as 44 percent.
11
Each clock time was tested three times to confirm that the results were repeatable. The table shows the average power of the three tests.
Table III.1—Conventional Cooking Product Clock Time Variation Standby Testing Results
Product type
Test unit No.
Average power (W)
1:11 Clock time
12:08 Clock time
Percent
variation (%)
Oven
1
1.06
1.44
26.4
Oven
2
1.05
1.5
30.0
Oven
3
1.25
1.60
21.7
Oven
4
1.06
1.44
26.4
Range
5
2.73
3.69
26.1
Range
6
0.65
1.15
43.8
Range
7
1.29
1.63
21.0
DOE believes that the lack of specificity in IEC Standard 62301 (First Edition) about the test period could produce test results obtained during one time period that are not comparable to those obtained using other time periods. Such results would not necessarily represent the standby power consumption of conventional cooking products during all hours associated with standby mode. In addition, different testing laboratories could take different approaches in selecting cycles for testing. To assess alternatives to the test cycle specified in IEC Standard 62301 (First Edition), DOE investigated alternative time periods and averaging methods for calculating representative standby power use, using data that DOE collected from microwave oven clock displays during its analyses for energy conservation standards for those products. DOE believes that those displays have cyclic variation in power consumption as a function of displayed time comparable to those in conventional cooking products.
For a typical microwave oven display with a 12-hour clock feature, DOE measured average standby power over the full 12-hour period. This measurement provides the most accurate and repeatable results. However, because a 12-hour test could substantially add to manufacturer test burden, DOE sought to identify other, more-abbreviated testing options, all the while keeping the 12-hour test in mind as an appropriate frame of reference in terms of generating representative results. DOE then evaluated a method using 18 different clock display times to produce an average standby power measurement representative of a 12-hour cycle. (This is referred to as the “18-point method.”) This method was discussed in appendix 5B of the technical support document (TSD) for the November 2007 ANOPR. When this method is used, the standby power consumption and line voltage are measured as the clock is cycled through all the possible digit combinations (in terms of active elements).
12
A regression
analysis is then performed to quantify the effect of the number of lit elements (by digit) and voltage on power consumption. The results were integrated across the number of minutes that each active element combination was “on” through the course of the 12-hour test period. As noted in chapter 5 of the November 2007 ANOPR TSD, this methodology produced results for average standby power consumption that were within 1 to 2 percent of the 12-hour test results.
12
The term “active elements” refers to the number of display segments energized in a seven-segment clock display for a given time. Different digit combinations associated with different times displayed may have the same number of active elements.
DOE also investigated whether a single 10-minute measurement period with a starting clock time of 3:33 would be a reasonable proxy for the 12-hour standby power measurement in the event that power consumption is not stable. DOE's analysis indicates that the proportion of time that each possible number of segments in a 7-segment LED display that are lit over the 10-minute time period from 3:33 to 3:42 is representative of the distribution of lit segments over a 12-hour period with an arbitrary starting time.
13
This suggests that the 10-minute test period starting at 3:33 would produce average standby power measurements comparable to average standby power measured over 12 hours. Table III.2 shows the average standby power measured for 11 units in DOE's microwave oven test sample using the 18-point and 10-minute methodologies as compared to the 12-hour test.
13
See
“10-Minute vs. 12-Hour Analysis.pdf,” included as entry No. 2 in the docket for this rulemaking.
Table III.2—Comparison of Methodologies for Measuring Standby Power in Cooking Products With Clock Displays
Test unit
Display type
12-Hour method
Standby
watts *
18-Point method
Standby
watts
*
Percent
difference
10-Minute method
Standby
Watts
*
Percent
difference
1
LCD
1.567
1.552
−0.99
1.592
1.60
2
LCD
1.571
1.560
−0.70
1.554
−1.08
3
LCD
1.812
1.812
0.03
1.801
−0.61
4
LCD
1.490
1.475
−0.96
1.492
0.17
5
LCD
1.859
1.847
−0.60
1.874
0.84
6
LCD
3.788
3.798
0.26
3.818
0.81
7
LCD
3.641
3.642
0.04
3.606
−0.95
8
LED
1.802
1.796
−0.35
1.797
−0.32
9
LED
1.825
1.820
−0.25
1.816
−0.47
10
LED
3.185
3.177
−0.27
3.290
** 3.28
11
VFD
5.600
5.611
0.20
5.607
0.13
* Standby power measurements are scaled to normalize the supply power to 120.0 volts.
** For this test, the supply power was significantly different than 120.0 volts. Therefore, DOE believes the scaling of the measured standby power and, thus, the percentage differences from the 12-hour standby power measurements are not valid for this test unit.
Within DOE's limited test sample, the average standby power measured over the specified 10-minute test period agrees within ± 2 percent of the average standby power measured over 12 hours. Therefore, DOE tentatively concludes that a 10-minute measurement period with a starting time of 3:33 would provide a valid measure of standby energy use for conventional cooking products, with power consumption varying according to the time displayed on the clock. DOE requests comment on the validity and comparability of the various tests examined, as well as which test(s) DOE should adopt for measuring standby mode and off mode energy use.
As a related matter, DOE is aware that certain clock displays enter a higher-power state when one manually sets the time, and then after a prescribed interval, the clock enters a lower-power state (
e.g.,
by dimming the display) that is representative of the power levels that would be associated with the display running without consumer interaction. Therefore, DOE has tentatively concluded that it would be appropriate to provide a second stabilization period after the clock display is set prior to the start of the measurement period. DOE testing of combination microwave ovens, which have similar clock displays as conventional cooking products, suggest that a second stabilization period of 10 minutes would be sufficient to ensure that the clock display has reached its more representative power state after setting the time. This approach would require setting the clock time to 3:23 in order to start the measurement period at 3:33 after the 10-minute second stabilization period. Therefore, DOE has tentatively decided to specify that, for conventional cooking products for which standby power consumption is not stable, the clock display shall be set at 3:23 at the conclusion of the stabilization period specified in section 5.3 of IEC Standard 62301 (First Edition), after which a second 10-minute stabilization period shall be provided, and the subsequent test period shall be 10 minutes. Alternatively, DOE believes that appropriate stabilization may be achieved by requiring only the 10-minute stabilization period after setting the clock time to 3:23. DOE seeks comment on whether this alternative method in which the clock time is set to 3:23 prior to a 10-minute stabilization period, followed by a 10-minute measurement period commencing at 3:33 would be appropriate.
DOE acknowledges, however, that both the 18-point and 10-minute approaches for accelerated standby testing do not exclude the possibility that a product could be programmed to alter its behavior during such a test in order to minimize measured standby power consumption. For example, a conventional cooking product could be programmed to dim or alter its display only during the display times associated with the 18 measurement points or between display times 3:33 and 3:42.
In light of the above, DOE is proposing to provide manufacturers of conventional cooking products the option to conduct either the full 12-hour test, the 10-minute test, or both (with the expectation that any test records will make clear which type of test(s) was (were) performed). If a manufacturer elects to perform both
tests on a unit, the manufacturer may only use the results from one of the tests (
i.e.,
the 12-hour test or the 10-minute test) as the test results for that unit. For purposes of enforcement testing, DOE reserves the right to use either test or both tests. Given that the 10-minute test, like the 12-hour test, is intended to represent standby mode and off mode energy use and based upon the research data discussed above, DOE proposes to clarify that the test results conducted under the two different tests must be within
±
2 percent of each other; otherwise, DOE will use the 12-hour test to determine compliance. DOE requests comment on its proposed approach requiring results under the 12-hour test and the 10-minute test to be within
±
2 percent of each other and welcomes data which would show that some other range is more appropriate.
DOE notes that the conventional cooking products test procedure is designed to provide an energy efficiency measurement consistent with representative average consumer use of these products, even if the test conditions and/or procedures may not themselves all be representative of average consumer use (
e.g.,
testing with a display of only 3:33 to 3:42). DOE's proposal reflects the statutory requirement, and the Department's longstanding view, that the overall objective of the test procedure is to measure the product's energy consumption during a representative average use cycle or period of use. 42 U.S.C. 6293(b)(3). Further, the test procedure requires specific conditions during testing that are designed to ensure repeatability while avoiding excessive testing burdens. Although certain test conditions specified in the test procedure may deviate from representative use, such deviations are carefully designed and circumscribed in order to attain an overall calculated measurement of the energy consumption during representative use. Thus, it is—and has always been—DOE's view that products should not be designed such that the energy consumption drops during test condition settings in ways that would bias the overall measurement, thereby making it unrepresentative of average consumer use. If a manufacturer incorporates a power-saving mode as part of the appliance's routine operation, DOE's test procedure would produce a representative measure of average consumer use if the unit powered down during the 10-minute test period for the same percentage of time that such powering down would be expected to occur during a typical 12-hour period, and, thus, such operation would be permissible. Although DOE believes that its proposed 10-minute test would be adequate for standby mode and off mode testing purposes, if it becomes aware of product design strategies which render the 10-minute test results unrepresentative, DOE reserves the right to perform a full 12-hour test in the context of enforcement testing. It has been the Department's long-held interpretation that the purpose of the test procedure is to measure representative use. Ultimately, if DOE identifies a broad pattern of behavior which has the effect of circumventing its test procedure provisions, the Department may consider reopening the conventional cooking products test procedure for further rulemaking.
DOE proposes to clarify in the conventional cooking products test procedure codified in 10 CFR 430.23(i)(17) that the energy test procedure is designed to provide a measurement consistent with representative average consumer use of the product, even if the test conditions and/or procedures may not themselves all be representative of average consumer use (
e.g.
specified display times). However, in a proposed rule on certification, compliance, and enforcement published in the
Federal Register
on September 16, 2010, DOE proposed that it would be a prohibited act to either fail to test a covered product in conformance with applicable test procedure requirements or to engage in “deliberate use of controls or features in a covered product or covered equipment to circumvent the requirements of a test procedure and produce test results that are unrepresentative of a product's energy or water consumption if measured pursuant to DOE's required test procedure.” 75 FR 56796, 56825 (Sept. 16, 2010) (citing proposed amendments to 10 CFR 429.31(a)(2)). Examples of products exhibiting such behavior are those products that can exhibit operating parameters (
e.g.
display wattage) for any energy using component that are not predictably varying functions of operating conditions or control inputs—such as when a display is automatically dimmed when test conditions or test settings are reached. DOE believes that retention of the ability to conduct enforcement testing using the 12-hour test will deter product designs that would not be representative under the 10-minute test of the DOE test procedure.
DOE seeks comment on the proposed approach above to address products equipped with controls or other features that modify the operation of energy-using components during testing. DOE's proposed approach does not identify specific product characteristics that could render results generated under the test procedure unrepresentative when testing certain products (
e.g.
modification of operation based on display time). Rather, it clarifies the need to address any features that could potentially yield measurements unrepresentative of the product's energy consumption during a representative use cycle.
As discussed in section III.B, the current DOE conventional cooking products test procedure provides testing methods and calculations to account for energy use of a continuously-operating clock. The current test procedure requires that any electrical clock that uses energy continuously be disconnected, except for those that are an integral part of the timing or temperature-controlling circuit of the product. In cases where the continuously-operating clock is an integral part of the timing or temperature-control circuit and cannot be disconnected during the test, the test procedure requires that such clock energy use be subtracted from the oven, cooktop, or range test energy consumption. The test procedure also provides methods for measuring the power consumption of a clock, which is then multiplied by 8,760 hours (total hours per year) to determine the annual clock energy consumption. The annual clock energy consumption is included in the calculation of total annual energy consumption and EF.
DOE believes that the testing provisions for clock energy consumption currently in the cooking products test procedure are no longer necessary because DOE proposes to amend the conventional cooking products test procedure to fully account for standby mode and off mode energy consumption, which include clock energy consumption. DOE proposes to incorporate standby mode and off mode energy consumption into the total annual energy consumption and EF calculations. Therefore, DOE proposes to remove the provisions for clock energy consumption from the conventional cooking products test procedure and to replace them with the provisions for measuring all standby mode and off mode energy consumption. (
See
section III.E.)
E. Calculation of Energy Use Associated With Standby Mode and Off Mode
Measurements of power associated with standby mode and off mode for
dishwashers, dehumidifiers, and conventional cooking products are expressed in watts (W). The annual energy consumption in each of these modes is the product of the power consumption and the time spent in that particular mode per year. The following sections describe how the annual energy use associated with each operating mode is calculated for the products that are the subject of this rulemaking.
1. Dishwashers
Energy use for dishwashers is expressed in terms of average annual energy use and total energy used per dishwasher cycle. (10 CFR 430.23(c)) As discussed in section III.F, DOE has tentatively determined that it is technically feasible to incorporate measures of standby mode and off mode energy use into the overall energy use metric (
i.e.,
average annual energy use) 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 energy consumption in terms of annual energy use, expressed in kWh per year.
In the current DOE dishwasher test procedure, the annual standby mode energy consumption is calculated by multiplying the average standby power use by the number of standby hours per year. The number of standby hours per year is equal to the number of total hours per year minus the product of the representative average dishwasher use of 215 cycles per year times the average wash cycle time. The average wash cycle time is derived from test measurements of the duration of the various cycles available on a dishwasher, such as normal, truncated normal, and sensor cycles. The average standby energy consumption is then added to the annual machine energy use (which includes any water heating within the dishwasher) and annual water energy use (energy used by the residence's water heater to heat the water prior to being supplied to the dishwasher during the cycle) to calculate the EAEU. DOE is proposing in today's NOPR that the active mode hours be determined using the approach specified in the current DOE dishwasher test procedure. That procedure uses test measurements of the duration of the various cycles available on a dishwasher to determine its average wash cycle time and then multiplies that average wash cycle time by 215 cycles per year. DOE proposes that the remaining non-active hours be distributed between the appropriate standby and off modes. DOE investigated the annual hours and energy consumption associated with each possible dishwasher operating mode, including inactive, delay start, cycle finished, off, and active modes, in order to propose methods for calculating the total annual energy use.
As part of the November 2007 ANOPR, DOE estimated the length of a dishwasher cycle to be one hour. 72 FR 64432, 64471 (Nov. 15, 2007). The DOE test procedure assumes 215 dishwasher cycles per year. (10 CFR part 430 subpart B, appendix C, section 5.6) Therefore, DOE estimates that 215 hours per year are dedicated to active mode.
Data regarding the amount of time dishwashers spend in the remaining non-active modes is very limited. A study conducted in Australia, “2005 Intrusive Residential Standby Survey Report,” surveyed 120 households and provided information regarding delay start for dishwashers. The report stated that about 25 percent of dishwashers were found to have delay start capabilities. Twenty percent of those surveyed who had dishwashers with delay start capabilities indicated they used this function. The study also reported an average power consumption for delay start mode of 3.8 W.
14
DOE notes the study reported data on dishwashers installed in the households at the time of the survey. Thus, the data may not be representative of dishwashers currently on the market. Because this study provided only limited information on consumer usage patterns for a limited number of modes, DOE investigated other sources of consumer usage data for dishwashers regarding the amount of time dishwashers spend in each possible non-active mode.
14
“2005 Intrusive Residential Standby Survey Report,” Energy Efficient Strategies (February 2006), p. 40.
One IEC report
15
surveyed dishwasher usage patterns in Germany, Italy, and the United Kingdom households. Dishwashers in these households averaged 213 cycles per year, which is close to the value specified by the current DOE dishwasher test procedure of 215 cycles per year. DOE believes the results of this survey are consistent with consumer behavior in the United States. DOE notes that the sample size of this survey was only 79 households. Regarding delay start, called “time delay function” in the survey, data showed 44 percent of dishwashers had a delay start function. Thirty-four percent of the respondents who owned a dishwasher with a delay start function used the function. Respondents who did use delay start used it for 16 percent of all cycles, with an average delay setting of 5.1 hours. If the results for delay start are applied to all dishwashers and cycles, the average delay start per cycle is just under 8 minutes, or 26 hours per year. For cycle finished mode, called “program end” in the survey, data from all households showed the average time after program end and before switching the machine off was 1.1 hours. If results for cycle finished mode are applied to all dishwashers and cycles, the average total cycle finished mode hours is 237 hours per year.
15
R. Stamminger, “Stand-by and other lower power modes on dishwashers,”
IEC
Report No. 59A/122/INF (March 24, 2006).
DOE is using data from this IEC survey in its estimates of the energy consumption associated with the different dishwasher modes. Of a total 8,760 hours per year,
16
the hours not associated with active, delay start, or cycle finished mode are allocated to off and inactive modes. To determine the approximate wattages associated with standby modes and off mode, DOE conducted internal testing on 14 dishwashers.
17
Average power levels in watts are multiplied by the estimated number of hours allocated per year to each mode to calculate the annual energy use for each mode. For example, the active mode power and annual energy use were calculated based on 215 cycles per year for a standard-size dishwasher with a minimum standard EF of 0.65. The typical average per-cycle energy use for such a dishwasher is calculated to be 1.54 kWh per cycle. The product of these inputs yields annual energy use in active mode of 331.1 kWh per year. In summary, Table III.3 presents the comparison of the average wattages and annual energy use associated with all dishwasher modes.
16
DOE used a value of 8760 total hours per year in all of its analyses in today's notice, based on 24 hours/day × 365 days/year. The current dishwasher test procedure includes a value of 8766 hours, which results from 24 hours/day × 365.25 days/year. Although the latter equation is more accurate, DOE has retained the value of 8760 in all its proposed test procedure amendments in today's notice, and notes that the two values vary by a negligible 0.07 percent.
17
See “Standby and Off Mode Power Measurements,” included as entry No. 3 in the docket for this rulemaking.
Table III.3—DOE Estimate of Annual Energy Use of Dishwasher Modes
Mode
Hours
Typical power
(W)
Annual energy use
(kWh)
Active
215
1,540
331.10.
Delay Start
* 26
1.91
0.05.
Cycle Finished
237
1.56
0.37.
Off and Inactive
** 8,282
0 to 0.69
0 to 5.71.
* Based on IEC 59A/122/INF.
** (8,760 hours per year—215 active mode hours—26 delay start hours—237 cycle finished hours) = 8,282 hours.
As discussed in section III.C, DOE believes that delay start would not be considered part of standby mode, but instead, it would be an active mode. For the reasons discussed earlier, DOE is not proposing amendments to the dishwasher test procedure to define “delay start mode” or to measure power consumption in this mode. The comparison of annual energy consumption of different dishwasher modes presented in Table III.3 shows that energy use associated with delay start mode is relatively insignificant because of the small number of annual hours associated with this mode. In addition, the power levels in this mode are similar to those for off/inactive modes for dishwashers currently on the market. Therefore, DOE proposes to allocate delay start mode hours (which total 26 for this example case) to the inactive and off modes (which would then total 8,308 for this example case). DOE also proposes that 237 hours be associated with cycle finished mode for dishwashers capable of functioning in such a mode, as presented in Table III.3.
To determine the annual hours per mode for dishwashers for which not all standby modes are possible, DOE proposes to reallocate the hours for modes that are not part of the dishwasher's design. For example, if cycle finished mode is not part of a dishwasher's design, the off/inactive mode hours would be the total hours per year minus the active mode hours per year. If cycle finished mode is part of the design, the off/inactive mode hours would be the total hours per year minus the active mode hours per year minus the 237 cycle finished mode hours.
DOE believes that the proposed definition of “off mode” as applied to dishwashers 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 dishwasher with a push-button sensor, touch sensor, or other similar device that consumes power is considered to be a standby mode feature under the proposed definition. The proposed definition states that standby mode facilitates the activation of other modes (including activation or deactivation of active mode) by remote switch (including remote control), internal sensor, or timer. DOE believes there are few dishwashers with electronic controls that have an additional mechanical on/off switch. Therefore, the combined inactive/off mode hours would most likely be allocated fully either to inactive or off mode, depending on the type of controls present on the dishwasher. DOE does not have market share information to determine how many dishwashers are currently shipped with electromechanical controls or the proportion of time spent in off mode for units equipped with a mechanical on/off switch. For dishwashers with electronic controls plus a mechanical on/off switch, DOE is proposing to allocate half of the non-active hours to inactive and half to off modes. DOE welcomes comment and additional information on this point, and on the proposed approach for calculating energy use for standby mode and off mode.
In conclusion, DOE proposes to determine dishwasher standby mode and off mode energy use by: (1) Calculating the product of wattage and allocated hours for all possible standby and off modes; (2) summing the results; and (3) dividing the sum by 1,000 to convert from watt-hours (Wh) to kWh. DOE invites comments on this proposed methodology and associated factors, including accuracy, allocation of annual hours, and test burden for manufacturers. DOE may also consider adoption in the final rule of the following alternative methodology based on comments received.
The comparison of annual energy use of different dishwasher product modes shows that cycle finished mode represents a relatively small number of hours per year at a low power consumption level. For dishwashers currently on the market, these levels are distinct from but comparable to those for off/inactive modes. Thus, DOE could adopt a test procedure for dishwashers that would specify that only hours spent in off and inactive modes would be considered when calculating energy use associated with standby mode and off mode. In that case, all of the non-active hours would be allocated to the inactive and off modes. DOE invites comment on whether such an alternative would be representative of the standby mode and off mode power consumption of dishwashers currently on the market.
2. Dehumidifiers
Energy use for dehumidifiers is expressed as EF, which is the ratio of liters of water removed from the air per kWh. As discussed in section III.F, DOE has determined it is technically feasible to incorporate measures of standby mode and off mode energy use into the overall energy use metric, and accordingly, DOE is making a proposal consistent with that determination, as required by the EISA 2007 amendments to EPCA. (42 U.S.C. 6295(gg)(2)(A)) Thus, DOE proposes that a dehumidifier's total annual energy use be estimated by combining standby mode and off mode energy consumption with active mode consumption based on the number of hours a dehumidifier spends in each mode.
In order to establish the number of hours per year a dehumidifier spends in different operating modes, DOE investigated studies of dehumidifier usage patterns. Table III.4 shows estimates of monthly dehumidifier usage obtained from a variety of sources, including a 1998 Arthur D. Little (ADL) report,
18
a 2005 Lawrence Berkeley National Laboratory (LBNL) report,
19
and estimates provided by ENERGY
STAR
20
and AHAM in 2006
21
in consultation with manufacturers and others familiar with the product. Most of these estimates demonstrate heavy dehumidifier usage during the summer months and none between the months of November and March. DOE proposes to use AHAM's mid-level estimate of active mode hours for the purpose of this analysis. The AHAM data were developed based on manufacturer experience. DOE believes, therefore, that the data represent a reasonable assessment of the average usage patterns for dehumidifiers. As shown in Table III.4, AHAM's mid-level estimate of annual hourly operation is 1,095 active mode hours, while other estimates range from 875 to 4,320 active mode hours. For the purposes of this analysis, DOE proposes that 1,095 hours be associated with active mode.
18
R. Zogg, and D. Alberino, “Electricity Consumption by Small End Uses in Residential Buildings,” Arthur D. Little (August 20, 1998).
19
M. McWhinney,
et al.,
“ENERGY STAR product specification development framework: using data and analysis to make program decisions.”
Energy Policy,
33 (2005) pp. 1613-25.
20
U.S. Environmental Protection Agency and U.S. Department of Energy, ENERGY STAR, “Savings Calculator—Dehumidifiers (Assumptions) (2006) (Last accessed August 10, 2010). Available online at:
http://www.energystar.gov/index.cfm?c=dehumid.pr_dehumidifiers.
21
AHAM,
AHAM Data on Dehumidifiers for Efficiency Standards Rulemaking
(August 23, 2006) (Docket No. EE-2006-STD-0127, Comment Number 17).
Table III.4—Estimates of Active Mode Operating Hours for Dehumidifiers
Source
Nov-Mar
Apr
May
June
July
Aug
Sep
Oct
Annual
AHAM-Low
0
0
70
210
245
245
70
35
875
AHAM-Mid
0
14
86
231
288
288
130
58
1,095
AHAM-High
0
37
110
256
329
329
183
73
1,315
ADL
0
0
180
360
360
360
180
180
1,620
ENERGY STAR
0
0
475
475
475
475
475
475
2,851
LBNL-High
1,800
360
360
360
360
360
360
360
4,320
DOE is aware that a dehumidifier may be unplugged for a certain percentage of time, and, therefore, will not be in either standby mode or off mode. DOE does not have data regarding the amount of time a typical dehumidifier is unplugged. However, in its comment on the framework document for the residential dishwasher, dehumidifier, cooking products, and commercial clothes washer energy conservation standards rulemaking, AHAM stated that dehumidifiers are normally used on a regional basis in basements during humid summer hours in northern climates. Reviewing the survey data presented in Table III.4, which show no active mode hours of operation for the months from November to March and minimal active mode hours in April, in the context of AHAM's comment has led DOE to tentatively conclude that dehumidifiers would likely be unplugged during the period from November to March and for half of April (5.5 months). Therefore, DOE estimates the time dehumidifiers spend unplugged as 3,984 hours.
Next, DOE investigated how the remaining 3,681 non-active hours (8,760−1,095—3,984) would be allocated to the other operating modes. DOE is not aware of any reliable consumer usage data on the number of hours per year dehumidifiers spend in delay start and bucket full/removed modes. In the absence of such data, DOE estimated the time spent in these modes in the manner described below.
To estimate a representative number of annual hours for bucket full/removed mode, DOE estimated the number of times a dehumidifier bucket would be expected to fill with water and the number of hours the bucket would be expected to remain full before being emptied. As discussed in the November 2007 ANOPR, DOE estimated that the predominant dehumidifier product class, which has 25.01-35 pints per day capacity and operates at the existing energy conservation standard level (EF of 1.35 liters per kWh), would have an annual energy use of about 480 kWh per year. 72 FR 64432, 64473 (Nov. 15, 2007). DOE estimates that such a dehumidifier would remove 648 liters of water from the air per year (480 kWh per year × 1.35 liters per kWh = 648 liters per year). Based on the units in DOE's test sample with a capacity between 25.01-35 pints per day, DOE estimates that the average condensate collection bucket size for this product class would be 18.7 pints, or 8.9 liters.
22
If it is assumed the typical consumer will run a dehumidifier until the bucket is full before emptying it, DOE estimates that dehumidifiers will reach bucket full/removed mode 73 times per year (648 liters of water removed from the air per year/8.9 liter bucket capacity = 73). Thus, the 1095 active mode hours divided by 73 bucket full mode events results in an estimate of 15 hours that the dehumidifier spends in active mode per bucket fill. DOE believes that consumers will not empty the collection bucket more than once per day, so the dehumidifier is likely to remain full an average of 9 hours per bucket-full event (24 hours per day − 15 hours per bucket fill = 9 hours). Based on these assumptions, DOE estimates the number of bucket full/removed annual hours to be 657 hours (73 bucket fills per year × 9 hours bucket remains full before being emptied and replaced).
22
See
“Dehumidifier Bucket Size.pdf,” included as entry No. 4 in the docket for this rulemaking
To determine the number of annual hours associated with delay start mode, DOE surveyed dehumidifier models available on the market. DOE determined that about 19 percent of dehumidifiers have a delay start mode function and that the delay start function can be set for up to 24 hours. DOE estimates that the delay start function will only be used on 50 percent of these 19 percent of dehumidifiers that have the function. DOE also estimates that consumers that do use the delay start function will use it once a day for 10 percent of the 199 dehumidifying days per year. (The dehumidifying days are the 6.5 months of the year during which the dehumidifier may be operated in active mode, as shown in the AHAM's mid-level estimate in Table III.4.) DOE also estimates that consumers will use an average delay setting of 12 hours (which is half of the maximum delay start time available on dehumidifiers.) Based on these assumptions, DOE estimates that the average time a dehumidifier is operating in delay start mode per active mode day is 6.8 minutes, or 23 hours per year.
The estimates of annual hours and energy consumption associated with the active, delay start, and bucket full/removed modes are displayed in Table III.5. To determine the approximate wattages associated with standby modes and off mode, DOE conducted internal testing on 13 dehumidifiers.
23
Average power levels in watts are multiplied by
the estimated number of hours allocated per year to each mode to calculate the annual energy use for each mode. For the purpose of this analysis, DOE estimated that the remaining 3,001 annual hours (3,681 non-active mode hours − 23 delay start mode hours − 657 bucket/full removed mode hours = 3,001 hours) would be split between off-cycle mode, inactive mode, and off mode. The split between these three modes is discussed later in this section.
23
See
“Standby and Off Mode Power Measurements,” included as entry No. 3 in the docket for this rulemaking.
Table III.5—DOE Estimate of Annual Energy Use of Dehumidifier Modes
Mode
Hours
Typical power (
W
)
Annual energy use (
kWh
)
Active
1,095
493
540.
Delay Start *
23
1.54
0.04.
Bucket Full/Removed **
** 657
1.63
1.07.
Off-Cycle/Inactive/Off
3,001
0 to 1.04
0 to 3.12.
* 19 percent (percentage of dehumidifiers with delay start function) × 50 percent (percentage of machines for which the delay start function is used) × 10 percent (for consumers that use the delay start function, the percentage of dehumidifying days that a consumer will use this function per day) × 12 hours (average programmed duration of delay start period) × 199 days (number of dehumidifying days per year) = 23 hours.
** 73 (bucket fills per year) × 9 hours (hours the bucket remains full before being emptied and replaced) = 657 hours.
As discussed in section III.C, DOE believes that delay start mode would not be considered part of standby mode, but instead would be a form of active mode. Therefore, DOE is not proposing amendments to the dehumidifier test procedure to define “delay start mode” or to measure power consumption in this mode. The comparison of the annual energy consumption of different dehumidifier modes presented in Table III.5 shows that energy use associated with delay start mode is relatively insignificant because dehumidifiers spend only a small number of hours in this mode. In addition, the power levels in delay start mode are similar to those for off/inactive modes for dehumidifiers currently on the market. Therefore, DOE proposes to allocate delay start mode hours (which total 23 hours for this example case) to the off-cycle, inactive, and off modes (which would then total 3,024 hours in this example case).
To determine the annual hours per mode for dehumidifiers for which not all standby modes are possible, DOE estimated values by reallocating the hours associated with various standby modes that are not present using the ratios discussed previously. DOE's logic for this distribution of hours follows.
For example, if bucket full/removed mode is not possible for dehumidifiers with a continuous drain and no condensate collection bucket, off-cycle/inactive/off modes would equal 3,024 off-cycle/inactive/off mode hours + 657 bucket full/removed hours = 3,681 hours. DOE believes the proposed definition of “off mode” as applied to dehumidifiers is similar to that for dishwashers. Off mode, as applied to dehumidifiers, refers to units with mechanical rather than electronic controls, or units with electronic controls combined with a mechanical switch that the user can use to de-energize the electronic controls. DOE observed during testing that dehumidifiers with electronic controls require that a humidity level be set when the unit is powered on; if the room humidity level is above the level set, the unit begins operating in active mode. Therefore, DOE believes that when a dehumidifier with electronic controls is powered on, the majority of the non-active mode hours (
i.e.,
when the relative humidity level in the room is below the dehumidifier humidity set point) would be associated with off-cycle mode. If a dehumidifier is equipped with electronic controls and a push-button sensor to power on the controls, it operates in the inactive mode when the unit is not powered on. DOE believes that a dehumidifier with a remote control can be controlled whenever it is plugged in. Thus, these units do not have an off mode and instead operate in the inactive mode when the unit is not powered on, and operate in off-cycle or active mode when the unit is powered on. However, if a dehumidifier allows the user to switch off remote control operation, it would be capable of off, inactive, and off-cycle modes. DOE does not have consumer usage data on the distribution of annual mode hours for dehumidifiers among the different combinations of off-cycle, inactive, and off modes. DOE proposes that the annual hours be split evenly between the off-cycle, inactive, and off modes depending on which modes are present on the dehumidifier under test. Otherwise, for units which are capable of operating in only off-cycle, inactive, or off mode, DOE proposes that all of the hours be allocated to the appropriate mode. DOE welcomes any data available on this issue.
In summary, DOE proposes to amend the dehumidifier test procedure to determine energy use associated with standby mode and off mode by: (1) Calculating the products of wattage and allocated hours for all possible standby and off modes; (2) summing the results; and (3) dividing the sum by 1,000 to convert from Wh to kWh. DOE invites comments on this proposed methodology for dehumidifiers and associated factors, including accuracy, allocation of annual hours, and test burden. DOE may also consider adoption in the final rule of the following alternative methodology based on comments received.
The comparison of annual energy use of different dehumidifier modes shows that, for dehumidifiers currently on the market, power consumption levels in bucket full/removed mode are distinct from but comparable to those for off-cycle/inactive/off modes. Thus, DOE could adopt an approach for dehumidifiers limited to specifying the hours for only off-cycle, inactive, and off modes when calculating energy use associated with standby mode and off mode. In that case, all of the non-active hours (3,681 hours total), including bucket full/removed mode, would be allocated to the off-cycle, inactive, and off modes. DOE invites comment on whether this alternative would be representative of the standby mode and off mode power consumption of dehumidifiers currently on the market.
3. Conventional Cooking Products
Energy use for conventional cooking products is expressed as EF, which is the ratio of annual cooking energy output to the annual energy input. As discussed in section III.F, DOE has determined it is technically feasible to incorporate measures of standby mode and off mode energy use into the overall energy use metric, and accordingly, DOE is making a proposal consistent with that determination, as required by the EISA 2007 amendments to EPCA. (42 U.S.C. 6295(gg)(2)(A)) In order to incorporate standby mode and off mode power consumption into the overall energy consumption for conventional
cooking products, DOE analyzed data on the usage patterns and power consumption in these modes on an annual basis for each product class of conventional cooking products, as discussed below.
a. Conventional Ovens
DOE investigated the hours and energy consumption associated with each possible operating mode for conventional ovens, including inactive, Sabbath, delay start, cycle finished, off, and active modes.
DOE is unaware of reliable consumer usage data for the number of hours spent in active mode for conventional ovens. To estimate the number of annual active mode hours, DOE reviewed data from the Energy Information Administration (EIA)'s 2005 “Residential Energy Consumption Survey” (RECS).
24
RECS is a national sample survey of housing units that collects statistical information on the consumption of and expenditures for energy in housing units, along with data on energy-related characteristics of the housing units and occupants. RECS provides survey data on the frequency of conventional oven use per week. Based on its analysis of RECS data, DOE estimates that the number of active mode cooking cycles per year is 211. Assuming that a conventional oven active mode cycle is on average 1 hour long, DOE estimates that the number of active mode hours per year for a conventional oven is 211. DOE welcomes information and data on such average cycle times, as well as the number of annual conventional oven usage cycles. For the purposes of this analysis, DOE proposes that 211 hours be associated with active mode and the remaining 8,549 hours of the year be associated with the remaining possible modes, including inactive, delay start, cycle finished, Sabbath, and off mode. RECS also provides consumer usage data on how many conventional ovens are used per household. Based on its analysis of RECS data, DOE estimates that 1.04 conventional ovens are used per household.
24
U.S. Department of Energy-Energy Information Administration, “Residential Energy Consumption Survey,” 2005 Public Use Data Files (2005). Available online at:
http://www.eia.doe.gov/emeu/recs/.
It is noted that EIA's 2005 RECS is the latest available version of this survey.
Similarly, DOE is not aware of reliable consumer usage data for the number of hours conventional ovens spend in various non-active modes. DOE estimated the time associated with Sabbath mode in conventional ovens based on the percentage of Jewish households in the United States that observe kosher practices at home (the households most likely to use Sabbath mode), the number of annual work-free days, and the number of conventional ovens used per household. DOE believes this represents the population of consumers which uses Sabbath mode features in a conventional oven. DOE estimates the percentage of Jewish consumers observing kosher practices at home to be about 0.54 percent of the total U.S. population, based on data from a 2000-01 population survey by the United Jewish Communities,
25
which reported that 21 percent of 2.9 million Jewish households (which equals 609,000 households) in the United States keep a kosher home, compared to 112,386,298 total households in the United States as of 2008.
26
DOE also estimates 1,584 hours of annual work-free hours, which would comprise the weekly Sabbath and the annual non-working Jewish holidays.
27
Using these estimates as well as the number of ovens per household as determined earlier in this section, DOE estimates that 8.9 hours per year would be associated with Sabbath mode for conventional ovens. The calculation is: 0.54 percent (percent of U.S. households that observe kosher practices) × 1,584 hours (annual work-free hours per year) × 1.04 (conventional ovens per household) = 8.9 hours per year.
25
United Jewish Communities, “The National Jewish Population Survey 2000-01—Strength, Challenge and Diversity in the American Jewish Population,” (Sept. 2003) (Last accessed August 10, 2010). Available online at:
http://www.jewishfederations.org/local_includes/downloads/4606.pdf
.
26
U.S. Census Bureau. “2006 American Community Survey 3-Year Estimates. S1101. Households and Families” (2006) (Last accessed August 10, 2010). Information available online at:
http://factfinder.census.gov/servlet/STTable?_bm=y&-qr_name=ACS_2008_3YR_G00_S1101&-geo_id=01000US&-ds_name=ACS_2008_3YR_G00_&-_lang=en&-format=&-CONTEXT=st.
27
These Jewish holidays included Rosh Hashanah, Yom Kippur, Sukkot, Shemini Atzeret, Simchat Torah, Shavu'ot, and Passover.
DOE also estimated the annual hours associated with delay start mode. DOE analyzed data from a DOE survey of ovens currently available on the market and estimated that 96 percent of conventional ovens are equipped with a delay start function. DOE notes that conventional ovens may offer a delay start function of up to 24 hours. However, DOE is unaware of any reliable usage data for the delay start function. In the absence of data, DOE has estimated that, given the prevalence of delay start-equipped ovens, approximately 50 percent of consumers will use this feature for at least some cooking cycles. DOE further estimates that consumers that use the delay start function will use it for 5 percent of cooking cycles and will program a 12-hour delay start period. (The 12-hour delay is half of the maximum delay start time available on conventional ovens, which is also approximately the time between preparation in the morning and initiating a cooking cycle in the evening.) Applying these estimates to all conventional ovens and cooking cycles (211 cycles per year as determined earlier), DOE estimates that the average time a conventional oven is operating in delay start mode per cycle is 17 minutes, or 61 hours per year.
To estimate the annual time associated with cycle finished mode, DOE assumed that conventional ovens on average remain in cycle finished mode for 5 minutes after every cycle. Calculations based on that assumptions result in an estimate of 18 annual hours associated with cycle finished mode.
The remaining 8,461.1 annual hours not associated with active, Sabbath, delay start, or cycle finished mode are allocated to off and inactive modes (8,760 annual hours − 211 active mode hours − 8.9 Sabbath mode hours − 61 delay start mode hours − 18 cycle finished mode hours). The hours for the relevant modes and estimates of power input and energy use for conventional ovens are summarized in Table III.6. The approximate wattages associated with each mode, other than active mode, were determined from internal testing conducted by DOE on 12 conventional ovens.
28
For active mode, the typical average power level is calculated by dividing the annual energy consumption of a baseline efficiency model electric self-cleaning oven (EF of 0.1099 and annual energy consumption of 171.0 kWh per year) by 211 active hours, which equals 810 W. Electric self-cleaning ovens were determined to be the predominant conventional electric oven product class as part of the November 2007 ANOPR. 72 FR 64432, 64474 (Nov. 15, 2007). Although the hours per mode presented in Table III.6 are estimates based on limited study data, DOE believes the energy patterns illustrated in this table are representative for most conventional ovens.
28
See
“Standby and Off Mode Power Measurements, pdf,” included as entry No. 3 in the docket for this rulemaking.
Table III.6—Estimate of Annual Energy Use of Conventional Oven Modes
Mode
Hours
Typical power
(W)
Annual energy use
(kWh)
Active
211
810
171.0.
Sabbath
* 8.9
7.59
.068.
Delay Start
** 61
5.35
0.33.
Cycle Finished
†
18
1.75
0.032.
Off/Inactive
8,461.1
0 to 3.80
0 to 32.15.
* 1,584 (yearly work-free hours) × 1.04 (conventional ovens per household) × 0.54 percent (percent of U.S. households that observe kosher practices) = 8.9 hours.
** 96 percent (percentage of conventional ovens with delay start function) × 50 percent (percentage of machines for which the delay start function is used) × 5 percent (for consumers that use the delay start function, the percentage of cycles that the consumer would use this function) × 12 hours (average programmed duration of delay start period) × 211 (annual cooking cycles) = 61 hours.
†
211 (annual cycles) × 5 minutes (estimated cycle finished minutes per cycle) = 18 hours.
As discussed in section III.C, DOE believes delay start mode would not be considered part of standby mode, but instead, it would be a form of active mode. Therefore, DOE is not proposing amendments to the conventional oven test procedure to define delay start mode or to measure power consumption in this mode. The comparison of annual energy consumption of different conventional oven modes shows that energy use associated with delay start mode is relatively insignificant because only a small number of hours are associated with this mode. In addition, the power levels in this mode are similar to those for off/inactive modes for conventional ovens currently on the market. For this reason, DOE proposes to allocate delay start mode hours (which total 61 hours for this example case) to the inactive and off modes (which would then total 8,522.1 hours in this example case.)
As also discussed in section III.C, DOE believes that Sabbath mode would be considered part of the active mode. Therefore, DOE is not proposing amendments to the conventional cooking products test procedure to define “Sabbath mode” or to measure power consumption in this mode. However, the comparison of annual energy consumption shows that energy use associated with Sabbath mode is insignificant because only a small number of hours are associated with this mode. DOE proposes to allocate the Sabbath mode hours (which total 8.9 hours for this example case) to the active mode (which would then total 219.9 hours in this example case.)
To determine the annual hours per mode for conventional ovens for which not all standby modes are possible, DOE estimated values based upon reallocating the hours for modes that are not present using the ratios discussed previously. If cycle finished mode, which is assumed to be a fixed value of 18 hours per year, is not present, the off/inactive mode hours would be 8,760 total hours − 219.9 active mode hours = 8,540.1 hours. If cycle finished mode is possible, the off/inactive mode hours would be 8,760 total hours − 219.9 active mode hours − 18 cycle finished hours = 8,522.1 hours.
DOE believes the proposed definition of “off mode” as applied to conventional ovens 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. Reactivating a conventional oven with a push-button sensor, touch sensor, or other similar device that consumes power is considered to be a standby mode feature under the proposed definitions. DOE believes there are few conventional ovens with electronic controls that have an additional mechanical off switch. Therefore, the combined inactive/off mode hours would most likely be allocated fully either to inactive or off mode, depending on the type of controls present on the conventional oven. DOE does not have market share information to determine how many conventional ovens are currently shipped with electromechanical controls. For conventional ovens with electronic controls plus a mechanical off switch, DOE proposes to allocate half of the non-active hours to inactive and half to off modes. DOE welcomes comment and additional information on this point, and on the proposed approach for calculating energy use for standby mode and off mode, including the decision to allocate all non-active mode hours to off and inactive modes.
In summary, DOE proposes to determine conventional oven energy use associated with standby mode and off mode by: (1) Calculating the product of wattage and allocated hours for all possible standby and off modes; (2) summing the results; and (3) dividing the sum by 1,000 to convert from Wh to kWh. DOE invites comments on this proposed methodology and associated factors, including accuracy, allocation of annual hours, and test burden. DOE may also consider adoption in the final rule of the following alternative methodology based on comments received.
The comparison of annual energy use of different conventional oven product modes shows that cycle finished mode represents a relatively small number of hours at a low power consumption level. For conventional ovens currently on the market, these levels are distinct from but comparable to those for off/inactive mode. Thus, DOE could adopt an approach that would be limited to specifying the hours for only off/inactive mode when calculating energy use associated with standby and inactive/off modes. In that case, all of the non-active hours (8,540.1 hours total) would be allocated to the inactive/off mode. DOE invites comment on whether such an alternative would be representative of the standby mode and off mode power consumption of conventional ovens currently on the market.
b. Conventional Cooktops
DOE investigated the hours and energy consumption associated with each possible operating mode for conventional cooktops, including inactive, Sabbath, off, and active modes. DOE did not observe any models capable of delay start mode or cycle finished mode, and, therefore DOE did not consider these modes for the purpose of this analysis.
DOE notes that RECS only provides usage data for conventional ovens and does not provide usage data for conventional cooktops. As discussed earlier, DOE estimated based on the 2005 RECS that there are 211 active mode cooking cycles per year for conventional ovens, resulting in 211 active mode hours per year, and that the
balance of the year (8,549 hours) is the established number of hours associated with Sabbath, cycle finished, and off/inactive modes. DOE believes that conventional cooktops would have similar active mode usage patterns as conventional ovens. Therefore, DOE is proposing to use the same 211 active mode cycles per year and annual active mode hours for conventional cooktops, so the remaining 8,549 hours of the year would be associated with standby mode and off mode. DOE welcomes information and data on such average cycle times, as well as annual conventional cooktop usage. DOE also notes that RECS does not provide usage data on how many conventional cooktops are used per household. As a result, DOE is proposing to estimate that the average household uses one conventional cooktop.
DOE is not aware of reliable consumer usage data for hours spent in different standby and off modes in conventional cooktops. As was done for conventional ovens, DOE estimated the time associated with Sabbath mode in conventional cooktops based on the percentage of Jewish households in the United States that observe kosher practices at home (the households most likely to use Sabbath mode), the number of annual work-free days, and the number of conventional cooktops used per household. As it did for conventional ovens, DOE estimates that about 0.54 percent of U.S. households keep kosher homes and that there are approximately 1,584 annual work-free hours (
i.e.,
the weekly Sabbath and the annual Jewish holidays). Applying these estimates to the number of cooktops per household as estimated earlier in this section, and estimating that, based on the relatively few cooktop models certified as Sabbath-compliant
29
and the greater availability of ovens with a dedicated Sabbath mode that DOE estimates would be used in place of cooktops on the Sabbath at least 75 percent of the time, DOE estimates that 2.1 hours per year would be associated with Sabbath mode for conventional cooktops. The calculation is as follows: 0.54 percent (percent of U.S. households that observe kosher practices) × 1,584 hours (annual work-free hours per year) × 1 (conventional cooktops per household) × 25 percent (percent of times that cooktops would be used on the Sabbath in place of or in addition to using an oven) = 2.1 hours per year.
29
For information on requirements for Sabbath-compliant cooktops and a list of cooktops certified as Sabbath-compliant, please visit:
http://www.star-k.com/cons-appl.htm.
The remaining 8,546.9 annual hours not associated with active or Sabbath mode are allocated to off and inactive modes (8,760 annual hours − 211 active mode hours − 2.1 Sabbath mode hours). The hours for the relevant modes and estimates of power input and energy are summarized in Table III.7. The approximate wattage associated with off/inactive mode was determined from internal testing conducted by DOE on eight conventional cooktops.
30
For active mode, the typical average power level is calculated by dividing the annual energy consumption of a baseline efficiency model electric smooth cooktop (EF of 0.742 and annual energy consumption of 128.2 kWh per year) by 211 active hours which equals 608 W. Electric smooth cooktops were determined to be the predominant conventional electric cooktop product class as part of the November 2007 ANOPR. (
See
the ANOPR national impacts analysis (NIA) spreadsheet tool for cooktops and ovens on DOE's Web site at:
http://www1.eere.energy.gov/buildings/appliance_standards/residential/cooking_products_anopr_tools.html
). For Sabbath mode, in which the cooktop burners or heating elements must not be turned on, off, or adjusted during the Sabbath period, DOE estimates that the burners will be set at no more than 25 percent of the heating input associated with active mode, due to safety considerations during such long-duration use. Although the hours per mode presented in this table are estimates based on limited study data, DOE believes that energy patterns illustrated in this table are representative for most conventional cooktops, because Sabbath mode hours would be a small percentage of annual hours and the off/inactive power levels are based on DOE test measurements.
30
See
“Standby and Off Mode Power Measurements.pdf,” included as entry No. 3 in the docket for this rulemaking.
Table III.7—Estimate of Annual Energy Use of Conventional Cooktop Modes
Mode
Hours
Typical power
(W)
Annual energy use
(kWh)
Active
211
608
128.2.
Sabbath
* 2.1
152 **
0.33.
Off/Inactive
8,546.9
0 to 3.13
0 to 26.73.
* 1,584 (yearly work-free hours) × 1 (conventional cooktops per household) × 0.54 percent (percent of U.S. households that observe kosher practices) × 25 percent (percent of times that cooktops would be used on the Sabbath in place of or in addition to using an oven) = 2.1 hours.
** 608 W (power in active mode) × 25 percent (percent of heating input that would be used during the Sabbath).
For the same reasons as discussed for conventional ovens, DOE believes that Sabbath mode would be considered part of the active mode. Therefore, DOE is not proposing amendments to the conventional cooktop test procedure to define “Sabbath mode” or to measure power consumption. However, the comparison of annual energy consumption shows that energy use associated with Sabbath mode is insignificant, because only a small number of hours are associated with this mode. DOE instead proposes to allocate the Sabbath mode hours (which total 2.1 hours for this example case) to the active mode (which would total 213.2 hours in this example case).
As with conventional ovens, DOE believes there are few conventional cooktops with electronic controls that have an additional mechanical off switch. Therefore, DOE proposes that the combined inactive/off mode hours would likely be allocated fully either to inactive or off mode, depending on the type of controls present on the conventional cooktop. For conventional cooktops for which both inactive mode and off mode are present, DOE proposes to allocate half of the non-active hours each to inactive and off modes. DOE welcomes comment and additional information on the proposed approach for calculating energy use for standby and off modes, including the decision to allocate all non-active mode hours to off and inactive modes.
In summary, DOE proposes to determine conventional cooktop energy use associated with standby mode and off mode by: (1) Calculating the product
of wattage and allocated hours for all possible standby and off modes; (2) summing the results; and (3) dividing the sum by 1,000 to convert from Wh to kWh. DOE invites comments on this proposed methodology and associated factors, including accuracy, allocation of annual hours, and test burden.
c. Conventional Ranges
DOE investigated the hours and energy consumption associated with each possible operating mode for conventional ovens, including inactive, Sabbath, delay start, cycle finished, off, and active mode.
DOE notes that RECS only provides usage data for conventional ovens and does not provide usage data for conventional ranges. As discussed previously, DOE estimated based on the 2005 RECS that there are 211 active mode cooking cycles per year for conventional ovens, resulting in 211 active mode hours per year. DOE also estimated that a conventional cooktop is in the active mode for 211 hours per year. DOE believes that the annual hours that a conventional range would be in active mode would be the sum of the annual active mode hours for conventional ovens and cooktops, which equals 422 hours. Since a range is essentially a combination of an oven and a cooktop, DOE's rationale is to combine the average values for these two components individually. Therefore, for conventional ranges, DOE proposes to associate 422 hours with active mode, and the remaining 8,338 hours of the year with the other non-active modes. DOE welcomes information and data on such average cycle times, as well as annual conventional range usage. RECS does provide consumer usage data on how many conventional ranges are used per household. Based on its analysis of the 2005 RECS data, DOE estimates that 1.03 conventional ranges are used per household.
DOE is not aware of reliable consumer usage data for hours spent in different standby and off modes for conventional ranges. DOE estimated the time associated with Sabbath mode in conventional ranges based on the percentage of Jewish households in the United States that observe kosher practices at home (the households expected to use Sabbath mode), the number of annual work-free days, and the number of conventional ranges used per household. DOE believes this represents the population of consumers which uses Sabbath mode features in a conventional range. As was determined earlier for conventional ovens, DOE estimates that about 0.54 percent of U.S. households keep kosher homes. As was estimated for conventional ovens, DOE estimates 1,584 annual work-free hours (
i.e.,
the weekly Sabbath and the annual Jewish holidays). Applying these estimates to the number of ranges per household, as estimated earlier in this section, DOE estimates that 8.8 hours per year would be associated with Sabbath mode for conventional ranges. The calculation is as follows: 0.54 percent (percent of U.S. households that observe kosher practices) × 1,584 hours (annual work-free hours per year) × 1.03 (conventional ranges per household) = 8.8 hours per year.
DOE analyzed a DOE survey of ranges currently available on the market and estimated that 79 percent of conventional ranges are equipped with a delay start function.
31
DOE notes that conventional ranges available on the market may offer a delay start function of up to 24 hours. As it did for conventional ovens, DOE estimates this function will be used on only 50 percent of conventional ranges so equipped. DOE also estimates that consumers who use the delay start function will use it for 5 percent of the cooking cycles associated with the oven portion of the range and set it for a 12-hour delay start period. (The 12-hour period is half of the maximum delay start time available on conventional ranges.) Applying these estimates to all conventional ranges and applying DOE's estimate of 211 oven cooking cycles per year, DOE estimates that the average time a conventional range is operating in delay start mode per cycle is 14.2 minutes, or (14.2 minutes × 211 cycles per year) = 50 hours per year.
31
See
“Range Modes.pdf,” included as entry No. 5 in the docket for this rulemaking.
To estimate the annual time associated with cycle finished mode, DOE assumes that, on average, conventional ranges remain in cycle finished mode for 5 minutes after every cycle, resulting in (5 minutes × 211 cycles per year) = 18 annual hours associated with cycle finished mode.
The remaining 8,261.2 annual hours not associated with active, Sabbath, delay start, or cycle finished mode are allocated to off and inactive modes (8,760 annual hours − 422 active mode hours − 8.8 Sabbath mode hours − 50 delay start mode hours − 18 cycle finished mode hours). The hours for the relevant modes and estimates of power input and energy use are summarized in Table III.8. The approximate wattages associated with each mode, other than active mode, were determined from internal testing conducted by DOE on 21 conventional ranges.
32
For active mode, the typical average power level is based on the sum of the typical power levels for conventional ovens and cooktops, as shown in Table III.6 and Table III.7. While the hours per mode presented in this table are estimates based on limited study data, DOE believes that energy patterns illustrated in Table III.8 are representative for most conventional ranges because Sabbath mode hours would be reasonably a small percentage of annual hours and the non-active power levels are based on DOE test measurements.
32
See
“Standby and Off Mode Power Measurements.pdf,” included as entry No. 3 in the docket for this rulemaking.
Table III.8—Estimate of Annual Energy Use of Conventional Range Modes
Mode
Hours
Typical power
(
W
)
Annual
energy use
(
kWh
)
Active
422
709
††
299.2.
Sabbath
* 8.8
3.72
0.033.
Delay Start
** 50
2.95
0.148.
Cycle Finished
†
18
2.52
0.045.
Off/Inactive
8,261.2
0 to 2.68
0 to 22.14.
* 1,584 (yearly work-free hours) × 1.04 (conventional ranges per household) × 0.54 percent (percent of U.S. households that observe kosher practices) = 8.8 hours.
** 79 percent (percentage of conventional ovens with delay start function) × 50 percent (percentage of machines for which the delay start function is used) × 5 percent (for consumers that use the delay start function, the percentage of cycles that the consumer would use this function) × 12 hours (average programmed duration of delay start period) × 211 (annual oven portion cooking cycles) = 50 hours.
†
211 (annual oven portion cooking cycles) × 5 minutes (estimated cycle finished minutes per cycle) = 18 hours.
††
171 kWh (annual energy use for conventional ovens) + 128.2 kWh (annual energy use for conventional cooktops) = 299.2 kWh.
As discussed for conventional ovens, DOE believes delay start mode
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