Energy Conservation Program: Test Procedures for Residential Clothes Dryers
Federal RegisterAug 14, 2013
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[Docket No. EERE-2011-BT-TP-0054]
RIN 1904-AC63
Energy Conservation Program: Test Procedures for Residential Clothes Dryers
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Final rule.
SUMMARY:
On January 2, 2013, the U.S. Department of Energy (DOE) issued a notice of proposed rulemaking (NOPR) to amend the test procedures for residential clothes dryers. DOE also published a supplemental NOPR (SNOPR) on February 7, 2013, to propose additional amendments to the clothes dryer test procedure. Those proposed rulemakings serve as the basis for today's action. This final rule updates the reference to the latest edition of the International Electrotechnical Commission (IEC) Standard 62301, “Household electrical appliances—Measurement of standby power,” Edition 2.0 2011-01. For the test procedures at both appendix D and appendix D1 to the same subpart, DOE is adopting amendments to clarify the cycle settings used for the test cycle, the requirements for the gas supply for gas clothes dryers, the installation conditions for console lights, the method for measuring the drum capacity, the maximum allowable weighing scale range, and the allowable use of a relative humidity meter. This final rule also amends the DOE clothes dryer test procedure to create a new appendix D2 that includes the amendments discussed above and testing methods for more accurately measuring the effects of automatic cycle termination.
DATES:
Effective date:
The effective date of this rule is September 13, 2013.
Compliance date:
Compliance with the amended test procedure in appendix D for the purposes of compliance with current energy conservation standards, as well as representations, is required beginning February 10, 2014 until January 1, 2015. Compliance with the amended test procedure in appendix D1 for the purpose of compliance with the January 1, 2015 energy conservation standards, as well as representations, is required beginning January 1, 2015. Appendix D2 may be used for informational purposes and compliance with the provisions in appendix D2 may be required at a later date. Voluntary early compliance with appendix D1 or appendix D2 is permitted.
Incorporation by reference:
The incorporation by reference of certain publications listed in this rule was approved by the Director of the
Federal Register
September 13, 2013.
ADDRESSES:
The docket, which includes
Federal Register
notices, public meeting attendee lists and transcripts, comments, and other supporting documents/materials, is available for review at regulations.gov. All documents in the docket are listed in the regulations.gov index. However, some documents listed in the index, such as those containing information that is exempt from public disclosure, may not be publicly available.
A link to the docket Web page can be found at:
http://www.regulations.gov/#!docketDetail;dct=FR%252BPR%252BN%252BO%252BSR;rpp=10;po=0;D=EERE-2011-BT-TP-0054.
This Web page will contain a link to the docket for this notice on the regulations.gov site. The regulations.gov Web page will contain simple instructions on how to access all documents, including public comments, in the docket.
For further information on how to review the docket, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT:
Mr. Stephen Witkowski, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue SW., Washington, DC 20585-0121. Email:
clothes_dryers@ee.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Authority and Background
A. General Test Procedure Rulemaking Process
B. DOE Clothes Dryer Test Procedure
1. January 2011 Final Rule
2. August 2011 RFI
3. January 2013 NOPR
4. February 2013 SNOPR
II. Summary of the Final Rule
A. Automatic Termination Control Procedures.
B. Incorporation of IEC Standard 62301 (Second Edition).
C. Clarifications to Test Conditions.
III. Discussion
A. Products Covered by This Test Procedure Rulemaking
B. Automatic Cycle Termination
1. Joint Petition to Amend the Clothes Dryer Test Procedure
2. January 2013 NOPR Analysis
3. January 2013 NOPR Proposed Amendments and Today's Final Rule
a. Definitions
b. Test Load
c. Automatic Termination Control Dryer Test Cycle
d. Automatic Termination Control Dryer Field Use Factor
e. Wrinkle Prevention Mode and the Determination of the Completion of the Test Cycle
f. New Appendix D2
C. Timed Dry Test Method
D. Incorporating by Reference IEC Standard 62301 Second Edition for Measuring Standby Mode and Off Mode Power
E. Technical Correction to the Calculation of the Per-cycle Combined Total Energy Consumption
F. Clarifications to Test Conditions
1. Cycle Settings
2. Gas Supply Requirements
3. Console Lights
4. Drum Capacity Measurements
5. Maximum Allowable Scale Range
6. Relative Humidity Meter
G. Additional Test Procedure Issues
1. Consumer Usage Patterns and Capabilities
a. Annual Clothes Dryer Use Cycles
b. Initial Remaining Moisture Content and Moisture Removed During Test Cycle
c. Test Load Weight
d. Exhaust Conditions
2. Test Load Bone-Dry Weight Measurement
3. Ventless Clothes Dryer Preconditioning
4. Room Ambient Humidity Requirements
5. Measurement of Drying Cycle Time
6. Clothes Dryer Energy Conservation Standards
H. Effects of Proposed Test Procedure Revisions on Compliance with Standards
1. Active Mode
2. Standby Mode and Off Mode
I. Compliance with Other EPCA Requirements
1. Test Burden
2. Certification Requirements
3. Compliance date of final amended test procedures
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 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
M. Congressional Notification
N. Approval of the Office of the Secretary
Authority and Background
Title III of the Energy Policy and Conservation Act of 1975 (42 U.S.C. 6291,
et seq.;
“EPCA” or, “the Act”) sets forth a variety of provisions designed to
improve energy efficiency. (All references to EPCA refer to the statute as amended through the American Energy Manufacturing Technical Corrections Act (AEMTCA), Public Law 112-210 (Dec. 18, 2012)). Part B of title III, which for editorial reasons was redesignated as Part A upon incorporation into the U.S. Code (42 U.S.C. 6291-6309, as codified), establishes the “Energy Conservation Program for Consumer Products Other Than Automobiles.” These include residential clothes dryers, the subject of today's notice. (42 U.S.C. 6292(a)(8))
Under EPCA, the energy conservation program consists essentially of four parts: (1) Testing, (2) labeling, (3) Federal energy conservation standards, and (4) certification and enforcement procedures. The testing requirements consist of test procedures that manufacturers of covered products must use as the basis for (1) certifying to the U.S. Department of Energy (DOE) that their products comply with the applicable energy conservation standards adopted under EPCA, and (2) making representations about the efficiency of those products. Similarly, DOE must use these test procedures to determine whether the products comply with any relevant standards promulgated under EPCA.
A. General Test Procedure Rulemaking Process
Under 42 U.S.C. 6293, EPCA sets forth the criteria and procedures DOE must follow when prescribing or amending test procedures for covered products. EPCA provides that any test procedures prescribed or amended under this section shall be reasonably designed to produce test results which measure energy efficiency, energy use or estimated annual operating cost of a covered product during a representative average use cycle or period of use and shall not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(3))
In addition, if DOE determines that a test procedure amendment is warranted, it must publish proposed test procedures and offer the public an opportunity to present oral and written comments on them. (42 U.S.C. 6293(b)(2)) Finally, in any rulemaking to amend a test procedure, DOE must determine to what extent, if any, the proposed test procedure would alter the measured energy efficiency of any covered product as determined under the existing test procedure. (42 U.S.C. 6293(e)(1)) If DOE determines that the amended test procedure would alter the measured efficiency of a covered product, DOE must amend the applicable energy conservation standard accordingly. (42 U.S.C. 6293(e)(2))
EPCA also requires DOE to amend the test procedures for all residential covered products to include measures of standby mode and off mode energy consumption. Specifically, EPCA provides definitions of “standby mode” and “off mode” (42 U.S.C. 6295(gg)(1)(A)) and permits DOE to amend these definitions in the context of a given product (42 U.S.C. 6295(gg)(1)(B)). The statute requires integration of such energy consumption into the overall energy efficiency, energy consumption, or other energy descriptor for each covered product, unless DOE determines that—
(i) the current test procedures for a covered product already fully account for and incorporate the standby mode and off mode energy consumption of the covered product; or
(ii) such an integrated test procedure is technically infeasible for a particular covered product, in which case the Secretary shall prescribe a separate standby mode and off mode energy use test procedure for the covered product, if technically feasible. (42 U.S.C. 6295(gg)(2)(A))
In any test procedure amendment, DOE must consider the most current versions of International Electrotechnical Commission (IEC) Standard 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.
B. DOE Clothes Dryer Test Procedure
DOE's test procedures for clothes dryers are codified in appendix D and appendix D1 to subpart B of Title 10 of the Code of Federal Regulations (CFR). DOE established its test procedure for clothes dryers at appendix D in a final rule published in the
Federal Register
on September 14, 1977 (the September 1977 Final Rule). 42 FR 46145. On May 19, 1981, DOE published a final rule to amend the test procedure by establishing a field-use factor for clothes dryers with automatic termination controls, clarifying the test cloth specifications and clothes dryer preconditioning, and making editorial and minor technical changes. 46 FR 27324. The test procedure includes provisions for determining the energy factor (EF) for clothes dryers, which is a measure of the total energy required to dry a standard test load of laundry to a “bone dry”
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state.
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“Bone dry” is defined in the DOE clothes dryer test procedure as a condition of a load of test clothes which has been dried in a dryer at maximum temperature for a minimum of 10 minutes, removed and weighed before cool down, and then dried again for 10-minute periods until the final weight change of the load is 1 percent or less. (10 CFR subpart B, appendix D, section 1.2)
1. January 2011 Final Rule
On January 6, 2011, DOE published in the
Federal Register
a final rule for the residential clothes dryer and room air conditioner test procedure rulemaking (76 FR 972) (January 2011 Final Rule), in which it (1) adopted the provisions for the measurement of standby mode and off mode energy use for those products; and (2) adopted several amendments to the clothes dryer and room air conditioner test procedures concerning the active mode for these products. 76 FR 972 (Jan. 6, 2011). DOE created a new appendix D1 in 10 CFR part 430 subpart B that contained the amended test procedure for clothes dryers. Manufacturers must use the test procedures in appendix D1 to demonstrate compliance with energy conservation standards for clothes dryers as of January 1, 2015. (76 FR 52852 (Aug. 24, 2011), 76 FR 52854 (Aug. 24, 2011))
For clothes dryer standby mode and off mode, the January 2011 Final Rule amended the DOE clothes dryer test procedure to incorporate by reference specific clauses from the IEC Standard 62301, “Household electrical appliances—Measurement of standby power,” (first edition June 2005) (IEC Standard 62301 First Edition) regarding test conditions and test procedures for measuring standby mode and off mode power consumption, as well as language to clarify application of these provisions for measuring standby mode and off mode power consumption in clothes dryers. In addition, DOE adopted definitions of modes based on the relevant provisions from IEC Standard 62301 Second Edition Committee Draft for Vote (IEC Standard 62301 CDV). DOE established the Combined Energy Factor (CEF) for clothes dryers to integrate energy use in the standby mode and off mode with the energy use of the main functions of the product.
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76 FR 972, 975-6 (Jan. 6, 2011).
2
The CEF is defined as the clothes dryer test load weight in pounds divided by the sum of the per-cycle standby and off mode energy consumption and either the total per-cycle electric dryer energy consumption or the total per-cycle gas dryer energy consumption expressed in kilowatt hours (kWh).
For clothes dryer active mode, in the January 2011 Final Rule, DOE adopted testing methods for ventless clothes dryers, test cloth preconditioning requirements for clothes dryer energy tests, test conditions for gas clothes dryers, test conditions for clothes dryer
drum capacity measurement, and amendments to reflect current clothes dryer usage patterns and capabilities and to update the references to the relevant industry test standard (Association of Home Appliance Manufacturers (AHAM) Standard HLD-1-2009). 76 FR 972, 976-8 (Jan. 6, 2011).
In the January 2011 Final Rule, DOE did not adopt amendments to more accurately measure automatic cycle termination that were proposed earlier in the rulemaking
3
because DOE concluded that they did not adequately measure the energy consumption of clothes dryers equipped with such systems using the test load specified in the DOE test procedure. DOE stated that clothes dryers with automatic termination sensing control systems, which infer the RMC
4
of the load from the properties of the exhaust air such as temperature and humidity, may be designed to stop the cycle when a load of varying weights, composition, and size has a higher RMC than the RMC obtained using the proposed automatic cycle termination test procedure in conjunction with the existing DOE test load.
5
In considering whether other test loads would be appropriate to incorporate into the DOE test procedure to produce both representative and repeatable test results, however, DOE noted that manufacturers indicated that test load types and test cloth materials different than those specified in the DOE test procedure do not produce results as repeatable as those obtained using the test load as currently specified. 76 FR 977 (Jan. 6, 2011).
3
The test method proposed in a supplemental notice of proposed rulemaking involved testing clothes dryers with automatic termination controls using the “normal” setting (and where the temperature setting can be chosen independently of the program, DOE proposed to use the highest temperature level) and a test load with a starting moisture content of 57.5 ± 0.33 percent, allowing the dryer to run until the heater switches off for the final time at the end of the drying cycle to achieve a final remaining moisture content of no more than 5 percent. 75 FR 37594, 37612-20 (June 29, 2010).
4
RMC is the ratio of the weight of water contained by the test load to the bone-dry weight of the test load, expressed as a percent.
5
The DOE test load is composed of cotton momie test cloths that are each 24 inches by 36 inches in dimensions and are a blend of 50-percent cotton and 50-percent polyester.
2. August 2011 RFI
On August 12, 2011, DOE published a Request for Information (RFI) to further investigate the effects of automatic cycle termination on clothes dryer energy efficiency (August 2011 RFI). 76 FR 50145. DOE sought information, data, and comments regarding methods for more accurately measuring the effects of automatic cycle termination in the clothes dryer test procedure. In particular, DOE sought comment on the following: (1) The characteristics of loads of varying weights, composition, and size, (2) the accuracy of different automatic cycle termination sensors and controls, (3) the target final RMC used by manufacturers to maintain consumer satisfaction, (4) the effects of the characteristics of water (
i.e.,
hardness and conductivity) used for wetting the test load prior to testing, and (5) the cycle settings selected by consumers for automatic termination cycles. In response to the August 2011 RFI, interested parties commented that DOE should amend the clothes dryer test procedure to include provisions to account for the effectiveness of automatic cycle termination and amend the relevant energy conservation standards based on the effects of the test procedure changes according to EPCA.
3. January 2013 NOPR
On January 2, 2013, DOE published a notice of proposed rulemaking (NOPR) (January 2013 NOPR) (78 FR 152) to propose amendments to the DOE clothes dryer test procedure in 10 CFR part 430, subpart B, appendix D1, to include methods for more accurately measuring the effects of automatic cycle termination. DOE also proposed to update the reference to the latest edition of the IEC Standard 62301, “Household electrical appliances—Measurement of standby power,” Edition 2.0 2011-01 (IEC Standard 62301 (Second Edition) or “Second Edition”) for measuring standby mode and off mode energy consumption, along with additional clarifying language. For the test procedures at both appendix D and appendix D1, DOE proposed in the January 2013 NOPR to clarify the cycle settings used for the test cycle and the requirements for the gas supply for gas clothes dryers. 78 FR 152, 154-155 (Jan. 2, 2013). DOE also held a public meeting on February 6, 2013 (hereafter referred to as the February 2013 public meeting) to hear oral comments on and solicit information relevant to the January 2013 NOPR.
4. February 2013 SNOPR
On February 7, 2013, DOE published a supplemental notice of proposed rulemaking (SNOPR) to consider inquiries regarding specific provisions in the current clothes dryer test procedures (February 2013 SNOPR). DOE proposed amendments to clarify the installation conditions for console lights, the method for measuring the drum capacity, the maximum allowable scale range, and the allowable use of a relative humidity meter. 78 FR 8992 (Feb. 7, 2013).
II. Summary of the Final Rule
A. Automatic Termination Control Procedures.
In this final rule, DOE amends the test procedures for clothes dryers in 10 CFR part 430, subpart B to create a new appendix D2 to include methods for more accurately measuring the effects of automatic cycle termination. As discussed in section III.I.3, DOE determined that the amended automatic cycle termination test procedure for clothes dryers represents a significantly different testing methodology that may impact the energy consumption of some clothes dryers more than others and would potentially require additional product re-design to meet the January 1, 2015 standards. As a result, to maintain the same basic test procedure that is required for use to determine compliance with the January 1, 2015 clothes dryer standards, DOE is not amending appendix D1 in today's final rule to include provisions for more accurately measuring the effects of automatic cycle termination. The newly created appendix D2 with such amendments will not be required for use to determine compliance with either the current or the January 1, 2015 energy conservation standards for clothes dryers. DOE will continue to evaluate products on the market and collect data on clothes dryer automatic cycle termination to evaluate when the compliance date for the amended test procedure in appendix D2 will be required.
The amended test method in appendix D2 requires that clothes dryers with automatic cycle termination controls be tested using the “Normal” automatic termination cycle setting. Where the drying temperature setting can be chosen independently, it shall be set to the maximum. Where the dryness level setting can be chosen independently, it shall be set to the “normal” or “medium” dryness level setting.
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The amendments also specify that the clothes dryer be allowed to run until the completion of the drying cycle, including the cool-down period, to achieve a final RMC of no more than 2 percent. If the final measured RMC is above 2 percent, the test shall be considered invalid and a new test cycle shall be run using the highest dryness
level setting. DOE notes that a final RMC of 2 percent using the DOE test load is more representative of clothes dryers currently on the market than the 5-percent final RMC specified in the existing test procedure and the new requirement is representative of the maximum consumer-accepted final RMC. DOE is including an additional clarification that the cycle shall be considered complete when the clothes dryer indicates to the user that the cycle has finished (by means of a display, indicator light, audible signal, or other signal) and the heater and drum/fan motor shuts off for the final time. If the clothes dryer is equipped with a wrinkle prevention feature (
i.e.,
that continuously or intermittently tumbles the clothes dryer drum after the clothes dryer indicates to the user that the cycle has finished) that is activated by default in the condition as shipped by the manufacturer, the wrinkle prevention mode would be included in the test measurement cycle unless it precluded the necessary automatic termination cycle program, temperature setting, or dryness setting. In addition, if a manufacturer's user manual specifies that the wrinkle prevention mode is recommended to be activated for normal use even if it is not done so in the as-shipped condition, the product would be tested with the wrinkle prevention mode activated per manufacturer's instructions.
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Most clothes dryers available on the market provide separate settings for the “temperature level” and “dryness level.” The temperature level refers to the temperature of the hot air used to dry the load in the drum. The dryness level refers to the desired remaining moisture content of the load at the completion of the drying cycle.
In the January 2013 NOPR, DOE proposed to apply a field use factor of 0.80 for clothes dryers with automatic cycle termination to account for the measured energy consumption at the end of the automatic termination cycle drying the DOE test load below 2-percent RMC. 78 FR 152, 170 (Jan. 2, 2013). Based on comments from interested parties and review of available field use data, DOE determined that eliminating the field use factor for automatic termination control dryers will produce test results that are more representative of consumer use. As a result, in today's final rule, DOE is eliminating the field use factor in appendix D2 for clothes dryers with automatic termination controls because the test method directly measures any over-drying energy consumption.
For clothes dryers with only timed dry control settings, the amendments adopted in the new appendix D2 require that the existing timed dry test cycle be used, but change the allowable final RMC range from 2.5-5 percent to 1-2.5 percent. DOE is also amending the test procedure in appendix D2 to change the normalization in the calculation of the per-cycle energy consumption to represent the energy consumption required to dry the test load to 2-percent RMC. These changes provide consistency with the test method for automatic cycle termination and are representative of the final RMC of clothes dryers currently on the market using the DOE test load.
Appendix D2 may be used for informational purposes, but will not be required for use to determine compliance with either the current or the January 1, 2015 energy conservation standards for clothes dryers. DOE is not amending appendix D1 in today's final rule to include the amendments for more accurately measuring the effects of automatic cycle termination discussed above.
B. Incorporation of IEC Standard 62301 (Second Edition).
The IEC published IEC Standard 62301 (Second Edition) on January 27, 2011. Consistent with EPCA requirements for amending test procedures to include standby and off mode procedures (42 U.S.C. 6295(gg)(2)(A)), DOE analyzed this latest version of the IEC standard and determined that it provides for improvement for some measurements of standby mode and off mode energy use. Accordingly, DOE adopts amendments in today's final rule to incorporate certain provisions of the IEC Standard 62301 (Second Edition), along with clarifying language, into the DOE clothes dryer test procedures in both appendix D1 and appendix D2.
C. Clarifications to Test Conditions.
DOE is amending 10 CFR part 430, subpart B, appendices D, D1, and D2 to clarify: (1) The cycle settings used for the test cycle, (2) the requirements for the gas supply for gas clothes dryers, (3) the installation conditions for console lights, (4) the method for measuring the drum capacity, (5) the maximum allowable weighing scale range for drum capacity and test cloth measurements, and (6) the allowable use of a relative humidity meter.
D. Summary of Test Provisions.
Table II.1 presents the key test procedure provisions in appendix D, D1, and D2.
Table II.1—Test Procedure Provisions
Test provisions
Appendix D
Appendix D1
Appendix D2
Standby/Off Mode Test Methods
None
Incorporates by reference IEC Standard 62301 (Second Edition) with additional clarifications
Incorporates by reference IEC Standard 62301 (Second Edition) with additional clarifications.
Ventless Dryer Test Methods
No
Yes
Yes.
Number of Cycles Per Year
416
283
283.
Referenced AHAM Standard
HLD-1-1974
HLD-1-2009
HLD-1-2009.
Test Load Weight
Standard Size Dryers: 7.00 ± .07 pounds
Standard Size Dryers: 8.45 ± .085 pounds
Standard Size Dryers: 8.45 ± .085 pounds.
Compact Size Dryers: 3.00 ± .03 pounds
Compact Size Dryers: 3.00 ± .03 pounds
Compact Size Dryers: 3.00 ± .03 pounds.
Detergent Specifications for Test Cloth Preconditioning
AHAM Standard Test Detergent IIA
AHAM Standard Test Detergent Formula 3
AHAM Standard Test Detergent Formula 3.
Water Temperature for Test Load Preparation
100 °F ± 5 °F
60 °F ± 5 °F
60 °F ± 5 °F.
Starting RMC of Test Load
70 ± 3.5 percent
57.5 ± 3.5 percent
57.5 ± 0.33 percent.
Cycle and Settings Used for Test
Timed Dry Cycle, Maximum Temperature
Timed Dry Cycle, Maximum Temperature
Automatic Termination Control Dryers: “Normal” Automatic Dry Cycle; Maximum Temperature (if separately selectable); “Normal” or “Medium” Dryness (or, if no such designations, at mid-point between min. and max. settings).
Timer Dryers: Timed Dry Cycle, Maximum Temperature.
RMC of Test Load at Which Test is Stopped
Stopped manually at 2.5-5 percent RMC
Stopped manually at 2.5-5 percent RMC
Automatic Termination Control Dryers: Allowed to run until completion of automatic cycle. Must be below 2-percent RMC or additional test with highest dryness level setting must be run.
Timer Dryers: Stopped manually at 1-2.5 percent RMC.
Cool Down
Clothes dryer not permitted to advance into cool down
Clothes dryer not permitted to advance into cool down
Cool down period included in automatic cycle test.
Field Use Factor (multiplied by per-cycle energy consumption to account for over drying)
= 1.04 for automatic termination control dryers
= 1.04 for automatic termination control dryers
No field use factor for automatic termination control dryers.
= 1.18 for timer dryers
= 1.18 for timer dryers
= 1.18 for timer dryers.
Clarifications:
• Cycle settings used for the test cycle
Yes
Yes
Yes.
• Requirements for the gas supply for gas clothes dryers
• Installation conditions for console lights
• Method for measuring the drum capacity
• Maximum allowable scale range
• Allowable use of a relative humidity meter
III. Discussion
A. Products Covered by This Test Procedure Rulemaking
Today's amendments to DOE's clothes dryer test procedure cover both electric and gas clothes dryers. DOE defines a clothes dryer to mean a cabinet-like appliance designed to dry fabrics in a tumble-type drum with forced air circulation, with blower(s) driven by an electric motor(s) and either gas or electricity as the heat source. 10 CFR 430.2. DOE is not amending the definition for clothes dryers in DOE's regulations.
Hydromatic Technologies Corporation (Hydromatic) commented that its “hybrid electric” clothes dryer should be a covered product and should be considered before setting any standards or test procedures. (Hydromatic, Public Meeting Transcript, No. 10 at pp. 24-27, 116-118)
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DOE notes that the Hydromatic's clothes dryer would be considered a covered product under the definition of an electric clothes dryer in 10 CFR 430.2 because the heat source is electricity. The definition does not limit electric clothes dryers to any specific method or technology by which the heat is generated from the electrical supply, such as an electric resistance heater or heat pump technology.
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A notation in the form “Hydromatic, Public Meeting Transcript, No. 10 at pp. 24-27, 116-118” identifies an oral comment that DOE received during the February 6, 2013, NOPR public meeting, was recorded in the public meeting transcript in the docket for the residential clothes dryer test procedure rulemaking (Docket No. EERE-2011-BT-TP-0054), and is available for review at
www.regulations.gov.
This particular notation refers to a comment (1) made by the Hydromatic Technologies Corporation during the public meeting; (2) recorded in document number 10, which is the public meeting transcript that is filed in the docket of the residential clothes dryer test procedure rulemaking; and (3) which appears on pages 24-27 and 116-118 of document number 10.
B. Automatic Cycle Termination
In today's final rule, DOE is adopting amendments to the clothes dryer test procedure in 10 CFR part 430, subpart B to create a new appendix D2 that includes methods to more accurately measure the effects of automatic cycle termination. DOE is not including these methods for automatic cycle termination in appendix D1 for the reasons discussed in section III.I.3.
The DOE test procedures for clothes dryers in 10 CFR part 430, subpart B, appendices D and D1 require manufacturers to apply a field use factor to the per-cycle drying energy consumption to determine the performance of clothes dryers equipped with both automatic cycle termination and timers. For clothes dryers with automatic termination control, the test procedures do not distinguish between the types of sensing control system (
e.g.,
temperature-sensing or moisture-sensing controls) nor consider the sophistication and accuracy of the control system. Gas or electric clothes dryers with time termination control (
i.e.,
those clothes dryers equipped with a timer to determine the end of a drying cycle) are assigned a field use factor of 1.18, while clothes dryers with automatic
termination are assigned a field use factor of 1.04. Because the test procedure requires the measurement of a timed drying cycle in which the tester manually stops the drying cycle when the test load reaches 2.5-5 percent RMC, the field use factors are intended to account for consumers that may dry loads beyond the 2.5-5 percent RMC specified in the test procedure. The field use factor for timer dryers was derived from a field study conducted by the Oklahoma Gas and Electric Company in 1971, consisting of 64 households and 33,000 loads of clothing, as well as data reported by AHAM representing the energy consumption in 1972 of 2,983,200 production units of clothes dryers. 42 FR 46145, 46146 (Sept. 14, 1977). For automatic termination control dryers, the field use factor was derived from a field study conducted by AHAM in 1977 involving 72 households. 45 FR 46762-63 (July 10, 1980); 46 FR 27324 (May 19, 1981).
In an SNOPR published on June 29, 2010 (75 FR 37594) (June 2010 SNOPR) in advance of the January 2011 Final Rule, DOE proposed to revise its clothes dryer test procedure to include definitions of, and provisions for, testing both timer dryers and automatic termination control dryers based on the methodology provided in Australia/New Zealand (AS/NZS) Standard 2442.1: 1996, “Performance of household electrical appliances—Rotary clothes dryers, Part 1: Energy consumption and performance” (AS/NZS Standard 2442.1) and AS/NZS Standard 2442.2: 2000, “Performance of household electrical appliances—Rotary clothes dryers, Part 2: Energy labeling requirements” (AS/NZS Standard 2442.2). 75 FR 37594, 37598 (June 29, 2010). DOE proposed to incorporate the testing methods from these international test standards, along with a number of clarifications, to measure the energy consumption for both timer dryers and automatic termination control dryers. The measurement would account for the energy consumed by the clothes dryer after the load reaches an RMC of 5 percent. 75 FR 37594, 37599 (June 29, 2010). The proposed test method in the June 2010 SNOPR specified that a clothes dryer with automatic cycle termination controls be tested using the “normal” cycle setting, and where the temperature setting can be chosen independently of the program, it would be set to the highest level. The clothes dryer would then be allowed to run until the heater switched off for the final time at the end of the drying cycle. If the final RMC was higher than 5 percent, the test would be re-run using the highest dryness level setting.
Id.
In addition to the provisions for automatic termination control dryers, DOE also proposed testing methods in the June 2010 SNOPR for timer dryers based on AS/NZS Standard 2442.1. The proposed test method specified that the clothes dryer be operated at the maximum temperature setting until the final RMC of the load was between 5 and 6 percent. The procedure would then be repeated to dry the load until the final RMC was between 4 and 5 percent, with the results from these two tests used to interpolate the value of the per-cycle energy consumption required to dry the test load to exactly 5-percent RMC. 75 FR 37594, 37617 (June 29, 2010).
As discussed in the January 2011 Final Rule, DOE conducted testing of representative residential clothes dryers using the automatic cycle termination test procedure proposed in the June 2010 SNOPR. The results of the testing revealed that all of the clothes dryers tested significantly over-dried the DOE test load to near bone dry and, as a result, the measured EF values were significantly lower than EF values obtained using the existing DOE test procedure in appendix D. 76 FR 972, 977 (Jan. 6, 2011). In the January 2011 Final Rule, DOE concluded that the test procedure amendments for automatic cycle termination proposed in the June 2010 SNOPR do not adequately measure the energy consumption of clothes dryers equipped with such systems using the test load specified in the DOE test procedure. Clothes dryers with automatic termination sensing control systems may infer the RMC of the load from the properties of the exhaust air such as temperature and humidity or by using conductivity sensor bars to determine the amount of moisture in the load when the load comes in contact with the sensors. DOE noted in the January 2011 Final Rule that these automatic termination sensing control systems may be designed for consumer use to dry loads of varying weights, composition, and size, which may have different moisture retention properties than the existing DOE test load, and therefore, may result in a higher measured RMC than the RMC obtained using the existing DOE test load with the proposed automatic cycle termination test procedure. In considering whether other test loads would be appropriate to incorporate into the DOE test procedure to produce both representative and repeatable test results, however, DOE noted that manufacturers indicated that test load types and test cloth materials different than those specified in the DOE test procedure do not produce results as repeatable as those obtained using the test load as currently specified. As a result, in the January 2011 Final Rule, DOE did not adopt the amendments to more accurately measure automatic cycle termination that were originally proposed in the June 2010 TP SNOPR. 76 FR 972, 977-78 (Jan. 6, 2011).
1. Joint Petition To Amend the Clothes Dryer Test Procedure
As discussed in section I of this notice, DOE published the August 2011 RFI to further investigate the effects of automatic cycle termination on clothes dryer energy efficiency. 76 FR 50145 (Aug. 12, 2011). DOE sought information, data, and comments regarding methods for more accurately measuring the effects of automatic cycle termination in the residential clothes dryer test procedure. In particular, DOE sought comment on the following: (1) The characteristics of loads of varying weights, composition, and size, (2) the accuracy of different automatic cycle termination sensors and controls, (3) the target final RMC used by manufacturers to maintain consumer satisfaction, (4) the effects of the characteristics of water (
i.e.,
hardness and conductivity) used for wetting the test load prior to testing, and (5) the cycle settings selected by consumers for automatic termination cycles.
In response to the August 2011 RFI, DOE received the “Joint Petition to Amend the Test Procedure for Residential Clothes Dryers to Include Provisions Related to Automatic Termination Controls” (the “Joint Petition”), a comment submitted by groups representing manufacturers (AHAM, Whirlpool Corporation (Whirlpool), General Electric Company (GE), Electrolux, LG Electronics, Inc. (LG), BSH Home Appliances (BSH), Alliance Laundry Systems (ALS), Viking Range, Sub-Zero Wolf, Friedrich A/C, U-Line, Samsung, Sharp Electronics, Miele, Heat Controller, AGA Marvel, Brown Stove, Haier, Fagor America, Airwell Group, Arcelik, Fisher & Paykel, Scotsman Ice, Indesit, Kuppersbusch, Kelon, and DeLonghi); energy and environmental advocates (American Council for an Energy Efficient Economy (ACEEE), Appliance Standards Awareness Project (ASAP), Natural Resources Defense Council (NRDC), Alliance to Save Energy (ASE), Alliance for Water Efficiency (AWE), Northwest Power and Conservation Council (NPCC), and Northeast Energy Efficiency Partnerships (NEEP)); and consumer groups (Consumer Federation of America (CFA) and the National
Consumer Law Center (NCLC)) (collectively, the “Joint Petitioners”). The Joint Petitioners commented that DOE should amend the clothes dryer test procedure to include provisions to account for the effectiveness of automatic cycle termination. (Joint Petition, No. 3 at pp. 1, 4-5)
8
8
A notation in the form “Joint Petition, No. 3 at pp. 1, 4-5” identifies a written comment: (1) Made by the Joint Petition; (2) recorded in document number 2 that is filed in the docket of the residential clothes dryer test procedure rulemaking (Docket No. EERE-2011-BT-TP-0054) and available for review at
www.regulations.gov;
and (3) that appears on pages 1 and 4-5 of document number 2.
The Joint Petitioners recognized DOE's concerns that the amendments for automatic cycle termination proposed in the June 2010 SNOPR may not properly measure the effectiveness of automatic termination controls, particularly in light of data that suggested that automatic termination control dryers may in fact be drying clothes to approximately 5-percent RMC rather than the less than 2-percent RMC resulting from testing using the DOE test cloth. The Joint Petitioners noted that the DOE test cloth is uniform, for purposes of repeatability and reproducibility, but likely dries faster and more uniformly than a load of varying weights, composition, and size. (Joint Petition, No. 3 at p. 5)
As part of the Joint Petition, AHAM members provided test data on clothes dryers with automatic termination controls representing 60 percent of shipments, measuring the final RMC at the completion of a “normal” automatic cycle, including cool down, using the DOE test load. The data showed that all tested models had a final RMC below 2 percent. The Joint Petitioners stated that because there are few consumer complaints that automatic termination control dryers do not dry clothes, this market-representative final RMC from testing using the DOE test cloth best approximates the maximum consumer-accepted final RMC. (Joint Petition, No. 3 at pp. 5-6)
Based on this data, the Joint Petitioners stated that DOE should amend the clothes dryer test procedure to include the full automatic termination cycle, including cool down. The Joint Petitioners stated that testing the entire cycle is more representative of actual consumer use and is less of a test burden for manufacturers than DOE's proposal in the June 2010 SNOPR to stop the clothes dryer when the heater switches off for the final time at the end of the drying cycle. In addition, the Joint Petitioners commented that the test procedure should be amended to state that the final RMC when testing units with automatic termination controls shall be no more than 2 percent when testing with the DOE test load to be representative of clothes dryers currently on the market. Any test in which the final RMC is 2 percent or less should be considered valid. If the final RMC is greater than 2 percent, the test would be invalid and a new test run would be conducted using the highest dryness level setting. (Joint Petition, No. 3 at p. 6)
AHAM withdrew its support for the petition in a letter to DOE dated May 29, 2012, stating that the petition was predicated on DOE's adoption of test procedure provisions to account for automatic termination controls by December 31, 2011. (AHAM, No. 5 at pp. 1-2) DOE acknowledged AHAM's withdrawal but continued to consider the substantive provisions to account for such controls.
2. January 2013 NOPR Analysis
For the January 2013 NOPR, DOE selected a representative sample of 20 clothes dryers encompassing all clothes dryer product classes to evaluate potential amendments for automatic cycle termination. DOE considered features such as rated energy factor, rated capacity, control type (
i.e.,
electromechanical versus electronic), and automatic cycle termination sensor technology (if advertised) when selecting units to be most representative of products currently available on the U.S. market. DOE initially conducted testing for all test units according to the DOE clothes dryer test procedure in 10 CFR part 430, subpart B, appendix D1. Appendix D1 requires that the DOE test load, initially soaked with an RMC of 57.5 ± 3.5 percent, be dried using the timed dry and maximum temperature settings until the test load has reached a final RMC of 2.5 to 5 percent without allowing the clothes dryer to advance into a cool-down phase. A field use factor is then applied to the measured per-cycle energy consumption to account for the over-drying energy consumption associated with the use of either timer dryers or automatic termination control dryers. DOE then conducted testing of these units using automatic cycle termination test methodologies with different test loads to evaluate the effects of these potential test procedure amendments on the measured efficiency as compared to the existing DOE test procedure in 10 CFR part 430, subpart B, appendix D1. DOE also conducted additional testing to evaluate repeatability and reproducibility of the test results. 78 FR 152, 157-158 (Jan. 2, 2013).
In conducting the testing for the January 2013 NOPR, DOE used the DOE test load and the test load specified in both the AHAM clothes dryer test standard HLD-1-2009, “Household Tumble Type Clothes Dryers,” and the IEC test standard 61121, “Tumble dryers for household use—Methods for measuring the performance,” Edition 3 (2005), which consists of cotton bed sheets, towels, and pillowcases. DOE concluded in the August 2011 RFI that clothes dryers with automatic termination sensing control systems may be designed to stop the cycle when a load of varying weights, composition, and size has a higher RMC than the RMC obtained using the automatic termination drying cycle in conjunction with the existing DOE test load. 76 FR 50145, 50146 (Aug. 12, 2011).
As part of the January 2013 NOPR, DOE conducted the testing for the proposed automatic cycle termination test methodology according to the DOE test procedure in appendix D1, with the following modifications. The test load was prepared with a starting RMC of 57.5 percent ± 0.33 percent. The controls were set as follows:
• Instead of using the timed dry cycle setting, the “normal” automatic termination cycle setting was selected. If a “normal” cycle setting was not provided, then the test cycle recommended by manufacturers for drying cotton or linen clothes was used.
• Where the temperature setting could be chosen independently of the program, the highest level was selected.
• Where the dryness level setting could be chosen independently of the program, it was set to the “normal” or “medium” level. If such designation was not provided, then the dryness level was set at the mid-point between the minimum and maximum settings. 78 FR 152, 158 (Jan. 2, 2013).
The clothes dryer was then allowed to run until the completion of the cycle, including the cool-down period. At the completion of the cycle, the clothes were weighed to determine the final RMC. If the final RMC was below 2 percent for the DOE test load, the test was considered valid. If the RMC was higher than 2 percent (
i.e.,
the test load contained more moisture than would be acceptable to consumers), the test was considered invalid and was re-run using the highest dryness level setting. DOE selected the 2-percent RMC threshold based on data presented in the Joint Petitioners' comment regarding RMC levels acceptable to consumers, discussed above. For the IEC/AHAM test load, similar test conditions were applied except that the threshold value for the final RMC was changed from 2
percent to 5 percent because of the more varied composition of the IEC/AHAM test load.
Id.
For each specific testing methodology, DOE conducted a series of three identical tests for each model to evaluate the repeatability of test results.
9
DOE presented the test results in the January 2013 NOPR, which are summarized in Table III.1. DOE noted in the January 2013 NOPR that for the automatic cycle termination tests using the DOE test load, all of the tests resulted in a lower measured CEF (
i.e.,
higher per-cycle energy use) compared to the DOE test procedure, ranging from a 3.5 percent to 41.9 percent decrease in CEF. Similarly, for the automatic cycle termination tests using the IEC/AHAM test load, DOE noted that all of the tests resulted in a lower measured CEF compared to the DOE test procedure, ranging from a 6.1 percent to 40.3 percent decrease. In addition, the majority of tested units had a lower CEF for the automatic cycle termination test with the IEC/AHAM test load than with the DOE test load. 78 FR 152, 159-160 (Jan. 2, 2013).
9
For this series of tests, DOE did not make any modifications to the water used to wet the test loads.
Table III.1—January 2013 NOPR DOE Test Procedure and Automatic Cycle Termination Test Results
Product class
DOE test
procedure
(Appendix D1)
CEF (
lb/kWh
)
Automatic cycle
termination—DOE test load
CEF
1
(
lb/kWh
)
% Change
Automatic cycle
termination—IEC/AHAM test load
CEF
1
(
lb/kWh
)
% Change
Vented Electric Standard
3.79
3.16
−16.6
3.03
−20.0
Vented Electric Compact (240V)
3.54
2.79
−21.1
2.68
−24.4
Vented Electric Compact (120V)
3.75
2.18
−41.9
2.42
−35.6
Vented Gas
3.39
2.92
−13.9
2.79
−17.7
Ventless Electric Compact (240V)
2.98
2.73
−8.4
2.63
−11.9
Ventless Electric Combination Washer/Dryer
2.54
2.45
−3.9
2.29
−9.7
1
No field use factor for automatic cycle termination applied to results.
In the January 2013 NOPR, DOE also presented the average final RMC from the automatic cycle termination tests with both the DOE and IEC/AHAM test loads, as well as the cycle settings used for each test unit. The test data showed that the final RMC ranged from 0.4 percent to 2.0 percent for the DOE test load and 1.3 to 4.7 percent for the IEC/AHAM test load. DOE also noted that for nearly all of the test units, the average final RMC was higher for the tests using the IEC/AHAM test load. The higher measured per-cycle energy use and final RMC for the IEC/AHAM test load compared to the DOE test load is likely due to the ability of the IEC/AHAM test load to retain more water during the drying process than the DOE test load, which gives off moisture more readily and terminates the drying cycle sooner. In addition, as discussed above, clothes dryers with automatic termination sensing control systems may be designed to stop the cycle when a load of varying weights, composition, and size has a higher RMC than the RMC obtained using the DOE test load. 78 FR 152, 160 (Jan. 2, 2013).
DOE noted in the January 2013 NOPR that manufacturers have indicated that test load types and test cloth materials different than those specified in the DOE test procedure do not produce results as repeatable as those obtained using the DOE test load. Therefore, for each test unit, DOE examined the test-to-test variation in CEF among the three tests conducted using the DOE test procedure and among the three tests using the automatic cycle termination test methodology. DOE presented the test-to-test variation results in the January 2013 NOPR, which are summarized in Table III.2. The analysis showed that the test-to-test variation for the automatic cycle termination tests with the DOE test load is slightly lower than the test-to-test variation with the IEC/AHAM test load, and that both are higher than the test-to-test variation for the DOE test procedure. DOE noted that the more consistent results for the current DOE test procedure are likely due to the use of the timed dry cycle rather than the automatic termination cycles, which may have additional variation in results due to the performance of temperature and moisture sensors and the automatic termination control strategies. 78 FR 152, 160-161 (Jan. 2, 2013).
Table III.2—January 2013 NOPR CEF Test-to-Test Variation
CEF Test-to-test variation (
%
)
DOE test
procedure
(Appendix D1)
Automatic cycle termination—DOE test load
Automatic cycle termination—IEC/AHAM test load
Minimum
0.18
0.16
0.16
Maximum
2.08
5.7
6.44
Average
0.87
1.87
2.07
In the January 2013 NOPR, to evaluate the effect of test load composition on repeatability, DOE then ran appendix D1 again for a subset of 10 of the clothes dryers in its test sample, using the IEC/AHAM test cloth instead of the DOE test cloth. For each of these units, DOE conducted three repeat tests. DOE stated that it believes that using the timed dry cycle and requiring that the clothes dryer be stopped manually allow for better evaluation of the effect of the test
load composition alone on repeatability by limiting other factors, such as automatic termination sensor performance, that may contribute to variability of results from test to test. The results from this testing were presented in the January 2013 NOPR and are summarized in Table III.3. The results showed a test-to-test variation in CEF (expressed in terms of standard error) of 1.02 percent for the IEC/AHAM test load as compared to the 0.87 percent test-to-test variation for the DOE timed dry test procedure with the DOE test load. 78 FR 152, 161 (Jan. 2, 2013).
Table III.3—January 2013 NOPR CEF Test-to-Test Variation for Appendix D1 with IEC/AHAM Test Loads
Timed Dry-IEC/AHAM test load—
CEF test-to-test
standard error
(
%
)
Minimum
0.31
Maximum
1.42
Average
1.02
DOE noted in the January 2013 NOPR that in addition to the use of the IEC/AHAM test load producing less repeatable results from test to test, the reproducibility of test results from lab to lab must also be considered because different test laboratories may be using different lots of test cloth. To evaluate the reproducibility of test results from lab to lab, DOE conducted testing of 9 units at an independent test laboratory with different lots of the DOE and IEC/AHAM test loads using the automatic cycle termination test method. The results showed that the lab-to-lab reproducibility of test results was, on average, 3.0 percent for the existing DOE test load and 4.7 percent for the IEC/AHAM test load. 78 FR 152, 161-162 (Jan. 2, 2013).
As part of the automatic cycle termination testing for the January 2013 NOPR, DOE tested a number of units in the test sample at an independent test laboratory that measured and recorded the energy consumption and an estimated instantaneous RMC of the test load throughout the test cycle. The estimated RMC was determined based on the weight of the test load, measured in place during the test cycle, and the rotation of the drum. Based on this testing, DOE decided to develop a field use factor to account for the over-drying energy consumption using the automatic cycle termination test method with the DOE test load at the end of the cycle when the load is dried below 2-percent RMC. 78 FR 152, 162 (Jan. 2, 2013).
Using the independent test laboratory's data, DOE evaluated the measured energy consumption at different times during the cycle—when the test load initially reached 5-percent RMC, when it reached 2-percent RMC, and at the end of the cycle (including after cool down). The test data showed that the energy consumption measured over a full automatic termination dry cycle is 11-72 percent greater than the energy consumption during the test cycle when the test load initially reaches 5-percent RMC, and 4-62 percent greater than the energy consumption when the test load initially reaches 2-percent RMC (before any moisture regain during cool down/tumbling). DOE also noted that while the final RMC of the DOE test load using the automatic cycle termination test method was between 0.4 percent and 2.0 percent at the completion of the test cycle for all of the clothes dryers in DOE's test sample, this RMC was achieved either after the end of a cool-down period, during which the clothes dryer tumbles with no added heat after the conclusion of the heated drying, or after an extended period of operation at nearly 0-percent RMC when the heater is cycled off and on. The independent test laboratory's data showed that during cool down or non-heated tumbling, the test load regains moisture from the room air. As a result, the final RMC of the test load at the completion of the cycle after the cool-down/tumbling period is higher than the RMC of the load when the heater turns off for the final time. 78 FR 152, 162 (Jan. 2, 2013).
Table III.4—January 2013 NOPR—Measured Automatic Cycle Termination Energy Consumption at Specific RMC Levels
Product class
Test unit
Automatic cycle termination sensor technology
Energy consumption
(
kWh
)
5% RMC
2% RMC
End of cycle (measured RMC
(
%
))
1
Vented Electric Standard
1
Moisture + Temp
1.945
2.070
2.624 (1.2)
2
Temperature
2.068
2.233
3.119 (0.9)
4
Moisture + Temp
2.160
2.318
2.405 (0.7)
6
Moisture + Temp
2.091
2.280
3.141 (1.9)
Vented Electric Compact (240V)
10
Temperature
0.823
0.875
1.418 (2.0)
Vented Gas
13
Moisture + Temp
2.375
2.569
2.905 (0.8)
15
Moisture + Temp
2.347
2.532
3.161 (1.2)
17
Moisture + Temp
2.300
2.482
2.843 (1.2)
1
As noted above, the test load regained moisture during the cool-down/tumbling period.
Based on the test data, DOE noted that for all of the clothes dryers tested at the independent test laboratory, the DOE test load reached 2-percent RMC before the clothes dryer initially began cycling the heater on and off. The test data also showed that the cool-down/tumbling period can contribute a significant amount of energy consumption associated with over-drying and moisture regain when using the DOE test load. DOE observed that two test units, both of which used the same moisture sensor technology and dried the test load to final RMCs of close to 1 percent at the end of the cycle, had significantly different total measured energy consumption. One of these test units achieved this final RMC with only a brief cool-down period, while the other test unit repeatedly heated, tumbled, and regained moisture before the final cool down. DOE stated in the January 2013 NOPR that it believes that the difference in energy consumption between these two units is most likely a function of the control strategy rather
than the accuracy of the sensors. 78 FR 152, 163-166 (Jan. 2, 2013).
As part of the January 2013 NOPR, DOE conducted further analysis to develop an appropriate field use factor to account for the measured energy consumption at the end of the automatic termination cycle below 2-percent RMC using the DOE test load (including any cool-down/tumbling period). DOE calculated a field use factor of 0.80 for automatic termination control dryers by taking the average of the difference between the measured energy consumption to initially reach 2-percent RMC and the measured energy consumption at the end of the test cycle. 78 FR 152, 166 (Jan. 2, 2013). The results of this analysis showing the application of the 0.8 field use factor are presented in Table III.5.
Table III.5—January 2013 NOPR—Automatic Cycle Termination Test Results With Adjusted Field Use Factor
Product class
Test unit
Per-cycle energy consumption
(
kWh
)
2% RMC
End of test—measured
End of test—field adjusted
Vented Electric Standard
1
2.070
2.624
2.099
2
2.233
3.119
2.495
4
2.318
2.405
1.924
6
2.280
3.141
2.513
Vented Electric Compact (240V)
10
0.875
1.418
1.134
Vented Gas
13
2.569
2.905
2.324
15
2.532
3.161
2.528
17
2.482
2.843
2.274
DOE noted in the January 2013 NOPR that the IEC recently revised its test standard for clothes dryers, IEC Standard 61121. 78 FR 152, 166 (Jan. 2, 2013). IEC Standard 61121 Fourth Edition, which published in February 2012, notes that the characteristics of the water used for wetting the test load prior to the test, particularly the conductivity, can influence the test results when testing automatic termination control dryers with moisture sensors. Clothes dryers with moisture sensors use conductivity sensor bars to determine the amount of moisture in the load when the load comes in contact with the sensors. Table III.6 provides the characteristics of either soft or hard water to be used for appliance testing under IEC Standard 61121.
Table III.6—IEC Standard 61121 Requirements for Composition of Soft and Hard Water for Clothes Dryer Testing
Property
Unit
Water type
Standard soft water
Standard hard water
Total hardness
Millimols per liter (mmol/l) (Ca
2+
/Mg
2+
)
0.50 ± 0.20
2.50 ± 0.20
Conductivity (at 20°C)
Microsiemens per centimeter (μS/cm)
150 ± 50
750 ± 150
In the August 2011 RFI, DOE requested information and data on these effects of the characteristics of the water used to wet the test load on the measured efficiency, as well as any potential testing burden associated with the requirements for modifying the water supply used for wetting the test load. DOE did not receive any comments or information on this issue. DOE conducted testing for the January 2013 NOPR to evaluate the effects of using supply water modified to meet the specifications in the IEC Standard 61121 on the measured efficiency compared to using supply water according to the requirements of appendix D1. For this series of tests, DOE conducted tests on 16 units using the same automatic cycle termination methodology discussed above, except that the water used to wet the test load prior to the test met the conditions presented in Table III.6 for standard soft water. 78 FR 152, 167 (Jan. 2, 2013). DOE selected the soft water requirements from IEC Standard 61121 rather than the hard water requirements to more closely match the existing DOE clothes dryer test procedure, which also requires the use of soft water.
10
For each test method, DOE again conducted three identical tests for each test unit. The test results did not show a correlation between the average measured CEF and water supply specifications for the automatic cycle termination tests with either the DOE or IEC/AHAM test loads. Similar to the measured CEF discussed above, there was no definitive correlation between the average measured final RMC or the test-to-test variation and the water supply specifications. Based on the test results, DOE determined that the modifications to the water supply specified in IEC Standard 61121 did not have a definitive effect on the measured CEF as compared to the water requirements specified in the existing DOE test procedure. In addition, the repeatability testing showed that the IEC water hardness specifications did not improve overall the test-to-test repeatability. 78 FR 152, 167-169 (Jan. 2, 2013).
10
10 CFR part 430, subpart B, appendix D1, section 2.6.3 requires the use of soft water with 17 parts per million hardness or less.
DOE conducted additional testing on two clothes dryers to evaluate the lab-to-lab reproducibility using both supply water specifications in automatic cycle termination tests with the IEC/AHAM test load. These tests showed that the IEC supply water may produce more reproducible results from lab to lab with the IEC/AHAM test load. DOE noted, however, that the percentage difference in test results from lab to lab was within the test-to-test variation for a given lab using the IEC/AHAM test load. For
these reasons, DOE did not propose amendments in the January 2013 NOPR to include in the amendments to appendix D1 the supply water specifications from IEC Standard 61121. DOE noted that if additional test results are made available showing that IEC supply water characteristics produce more repeatable and reproducible test results than the requirements in appendix D1, DOE may consider such amendments in a future test procedure rulemaking. 78 FR 152, 166 (Jan. 2, 2013).
3. January 2013 NOPR Proposed Amendments and Today's Final Rule
Based on the testing and analysis discussed above, DOE proposed amendments to the clothes dryer test procedure in 10 CFR part 430, subpart B, appendix D1 in the January 2013 NOPR to more accurately measure the energy consumption of automatic termination control dryers. 78 FR 152, 169 (Jan. 2, 2013).
a. Definitions
DOE proposed in the January 2013 NOPR to amend the clothes dryer test procedure in appendix D1 to add definitions for both automatic termination control dryers and timer dryers. DOE proposed to define “automatic termination control dryer” as a clothes dryer that can be preset to carry out at least one sequence of operations to be terminated by means of a system assessing, directly or indirectly, the moisture content of the load. An automatic termination control dryer with a supplementary timer or that may also be manually controlled would be tested as an automatic termination control dryer. DOE proposed to define “timer dryer” as a clothes dryer that can be preset to carry out at least one operation to be terminated by a timer, but may also be manually controlled, and does not include any automatic termination function. 78 FR 152, 169-170 (Jan. 2, 2013).
AHAM and ALS commented that they did not oppose the proposed definitions for automatic termination control dryer and timer dryer. (AHAM, No. 17 at p. 12; ALS, No. 16 at p. 3) Based on these comments and the discussion above, DOE is adopting these definitions for automatic termination control dryer and timer dryer in today's final rule.
b. Test Load
The existing DOE test procedure in 10 CFR part 430, subpart B, appendix D1, section 2.6 specifies that the test load be composed of 50-percent cotton and 50-percent polyester momie weave cloth. Section 2.7 in appendix D1 requires that test loads be prepared with a starting RMC of 57.5 percent ± 3.5 percent. DOE proposed amendments in January 2013 NOPR to change the starting RMC from 57.5 percent ± 3.5 percent to 57.5 percent ± 0.33 percent. DOE stated in the January 2013 NOPR that it believes that the starting RMC of 57.5 percent ± 0.33 percent, which was used for the testing presented above, and originally proposed in the June 2010 SNOPR, would produce the most repeatable results, particularly for automatic termination control dryers. DOE noted that allowing a wide range in the starting RMC, such as the ± 3.5 percent specified in the current DOE test procedure, would result in significantly different results using the proposed automatic cycle termination test procedure because a test load with a starting RMC of 61 percent would contain approximately 0.6 pounds (lb) of water more than a test load with a starting RMC of 54 percent for standard-size loads. 78 FR 152, 170 (Jan. 2, 2013). As a result, DOE specifically proposed to amend 10 CFR part 430, subpart B, appendix D1, section 2.7.1, “Compact size dryer load,” and section 2.7.2, “Standard size dryer load,” to require that water be extracted from the wet test loads by spinning the load until the moisture content of the load is 52.5-57.5 percent of the bone-dry weight of the test load. Final mass adjustments would be made, such that the moisture content is 57.5 percent ± 0.33 percent by adding water uniformly to the load in a very fine spray. DOE noted that requiring water to be extracted to achieve an RMC between 52.5 percent and 57.5 percent would serve as an initial preparation step prior to the final mass adjustments to obtain a test load with an RMC of 57.5 ± 0.33 percent proposed above. 78 FR 152, 170 (Jan. 2, 2013).
Test Load Composition
In response to the January 2013 NOPR, The Northwest Energy Efficiency Alliance (NEEA) and NPCC jointly commented (hereafter “NEEA & NPCC”) that the DOE test load is not representative of the laundry loads being dried in a representative average use cycle. NEEA & NPCC stated that the data from the NEEA residential laundry field use study, which included 50 households in the Pacific Northwest United States metered from January 2012 to March 2012, show that the fabrics in the loads being washed and dried are much heavier than those in the DOE test load. NEEA & NPCC added that the outcomes for the field data, in terms of RMC from the clothes washer, drying cycle time, and clothes dryer energy use, are all substantially different than those produced using the test procedure proposed in the January 2013 NOPR. (NEEA & NPCC, No. 21 at pp. 3-4, 10; NPCC, Public Meeting Transcript, No. 10 at p. 114; NEEA, Public Meeting Transcript, No. 10 at p. 17) NEEA added that: (1) The current DOE test load is consistent and the ply is fairly thin, (2) the IEC Standard 61121 mixed load has thinner fabric but more cotton than the DOE load, (3) the IEC Standard 61121 cotton load is also fairly thin and not substantively different than the DOE ply, (4) the AS/NZS Standard 2442 load is mostly cotton and has a large range of ply thicknesses and resembles loads that are seen in the field, and (5) the AHAM HLD-1-1992 test load is cotton and has a large range of ply thicknesses. Pacific Gas and Electric Company, San Diego Gas and Electric Company, and Southern California Edison (hereafter “California Investor Owned Utilities (IOUs)”) and NEEA commented that the test-to-test and lab-to-lab variation based on DOE's testing is slightly higher for the IEC cotton load as compared to the DOE test load, but, given that the amount of energy that it takes to dry the IEC cotton load is greater, the results as a percentage of per-cycle energy use are not significantly different. The California IOUs added that, given the far greater differences observed between the actual clothes dryer energy use per load in the field and what is measured using the DOE test procedure, this minimal increase in testing variability is justifiable to provide an accurate representation of energy use. (NEEA, Public Meeting Transcript, No. 10 at pp. 17, 19-21, 22; California IOUs, Public Meeting Transcript, No. 10 at p. 64)
NEEA & NPCC and the California IOUs noted that when DOE tested the IEC/AHAM test load and allowed the clothes dryers to shut off at 5-percent RMC or less (rather than 2-percent RMC with the DOE test load), all of the clothes dryers used more energy per load but left the clothes less dry than the tests with the DOE test load. The California IOUs added that the average efficiency drop from the existing appendix D1 results was 3.9 percent for automatic termination with the DOE test load and 9.7 percent with the IEC/AHAM test load and that the choice of a test load affects the final test outcome more than the choice of final RMC or most of the other factors being considered in the test procedure. NEEA & NPCC and the California IOUs commented that this difference would increase with an even more realistic test load, such as the AHAM HLD-1-1992
test load. The California IOUs added that removing the last few percent RMC from the load is an inefficient process, and that if the test procedure required the IEC/AHAM test load to be dried 2-percent RMC, the difference in efficiency compared to the existing appendix D1 test procedure would widen further. (NEEA & NPCC, No. 21 at p. 5; California IOUs, No. 22 at p. 14; California IOUs, Public Meeting Transcript, No. 10 at pp. 60-61, 64)
NEEA & NPCC and the California IOUs presented test data for 5 different clothes dryer models
11
comparing the drying time, measured per-cycle energy consumption, and CEF using the automatic termination test cycle with the DOE test load versus with a test load they considered more representative of real-world laundry loads. NEEA & NPCC noted that the drying times for the automatic termination test cycle with the real-world loads are quite similar from model to model, except for the clothes dryer with the moisture sensor bars that rotate with the drum and the heat pump clothes dryer. NEEA & NPCC and the California IOUs also noted that the CEF is lower for the tests with real world load as compared to the DOE test load in all cases, but the difference varies depending on the technology type. Based on this data, NEEA & NPCC and the California IOUs believe that it is inappropriate for DOE to adopt a single field use factor to adjust the per-cycle energy use from testing using the current DOE test load to represent how various technologies would perform with real-world laundry loads. NEEA & NPCC and the California IOUs commented that DOE should specify testing with a more realistic test load, such as the IEC cotton load or AHAM HLD-1-1992 test load, so that manufacturers would have an incentive to optimize their sensors and drying technology for real-world conditions. (NEEA & NPCC, No. 21 at pp. 10-12; California IOUs, No. 22 at pp. 21-22) NEEA & NPCC commented that a test load that is more reflective of real-world clothing, such as the IEC cotton test load or the AHAM HLD-1-1992 test load, would provide additional agreement between tested energy use and typical field energy use. NEEA & NPCC urged DOE to address this issue as soon as possible for both clothes washers and clothes dryers in a new rulemaking. (NEEA & NPCC, No. 21 at pp. 12-13)
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The 5 tested clothes dryers included: (1) A dryer with temperature sensing, (2) a dryer with stationary moisture sensing bars, (3) a dryer with moisture sensing bars that rotate with the drum, (4) a dryer with an exhaust air-to-air heat exchanger, and (5) a heat pump clothes dryer.
NRDC, ASAP, ACEEE, and the California IOUs similarly commented that the current test load is not representative of real-world loads and results in significant underreporting of energy use. The California IOUs added that, as a result, the test procedure does not appropriately balance representativeness and repeatability. NRDC, ASAP, and the California IOUs requested DOE to address this issue as soon as possible in a new rulemaking. NRDC and ASAP commented that clothes dryers are likely the single largest opportunity for energy savings in home appliances, and modifying the test procedure so that it more accurately represents field energy use is critical to being able to capture these additional opportunities. (NRDC, No. 20 at p. 2; ASAP, Public Meeting Transcript, No. 10 at pp. 119-120; ACEEE, Public Meeting Transcript, No. 10 at pp. 114-115; California IOUs, No. 22 at pp. 14, 17)
Earthjustice commented that DOE's use of 5 percent as the target RMC using the AHAM test load recognizes that the AHAM load is more representative of the loads encountered in the field. Earthjustice stated that the NEEA field study data, which shows that heavier fabrics (such as the towels represented in the AHAM test load) make up a significant portion of household laundry loads, supports this conclusion. (Earthjustice, No. 15 at pp. 1-2)
The California IOUs stated that designs that reduce over-drying can, based on DOE's test data in January 2011 Final Rule, save about 0.3 to 0.6 kilowatt hours (kWh) of over-drying energy use per load relative to designs that inefficiently terminate the cycle. The California IOUs stated that, based on recent testing by Ecos, Consumer Reports, DOE, and Ecova, certain automatic termination test methods can actually result in a higher measured energy use relative to DOE's current timed dry test procedure because the DOE test cloths are already quite dry by the time many clothes dryers detect high exhaust temperatures and low humidity levels that indicate there is no water left in the load to evaporate. The California IOUs stated that it is difficult for these clothes dryers to prevent over-drying because the condition they are designed to detect occurs when the DOE test load has been over-dried. (California IOUs, No. 22 at p. 13)
The California IOUs commented that DOE should use the AHAM HLD-1-1992 bone-dry load weight (7.4 lb), which according to the NEEA field data more accurately represents field laundry loads than the DOE test load or the IEC/AHAM cotton load because it contains a much wider range of fabric thicknesses and weights. The California IOUs stated that common items such as shirts, pants, socks, and other articles of clothing are three-dimensional, and therefore contain interior sides that are more difficult to dry than the two-dimensional DOE test cloths. The California IOUs added that these items vary quite widely in their moisture retention capability because of differences in thickness and synthetic content but, on average, retain more moisture per pound than the uniform DOE test cloth and require more energy to dry. The California IOUs stated that these items present automatic termination controls with greater difficulty than DOE's test cloths in determining when the load is dry. (California IOUs, No. 22 at pp. 17-18; California IOUs, Public Meeting Transcript, No. 10 at pp. 112-113) The Super Efficient Dryer Initiative (SEDI) also cited the Ecova testing in stating that the AHAM HLD-1-1992 test load is the most similar to typical laundry because it uses items of actual clothing with different fabrics and varying thicknesses. SEDI stated that the test results showed that drying test cloths that more closely resemble real-world clothing increased drying time and energy consumption, and that DOE should specify the use of the AHAM HLD-1-1992 test load in the clothes dryer test procedure. (SEDI, No. 14 at pp. 2-3)
The California IOUs commented that manufacturers are likely already using AHAM HLD-1 to evaluate drying performance. The California IOUs commented that if there is already a representative load that industry is using to determine drying performance, measuring energy at the same time as that test would reduce test burden. (California IOUs, Public Meeting Transcript, No. 10 at pp. 179-180) AHAM stated that the test burden associated with using the IEC/AHAM test load for energy and water testing would not be lower than the burden associated with using the DOE test load. AHAM stated that manufacturers use the IEC/AHAM test load for non-energy purposes, but use of the AHAM test procedure is voluntary and, thus, use of the IEC/AHAM test load for other purposes is outside of the regulatory context. AHAM also stated that it is not simple to measure the energy using the IEC/AHAM test load given the increased variability in test results, which will in turn increase the burden on manufacturers. AHAM added that it is critical that the DOE test procedure be as repeatable and reproducible as
possible, especially given the more stringent standards. (AHAM, No. 17 at p. 15)
AHAM stated that the DOE test load, because it is comprised of uniform test cloth, produces more repeatable and reproducible results. AHAM, therefore, agreed with DOE's proposal to continue using the DOE test load at this time. AHAM stated that should such a change in the test load be considered in the future, extensive testing would be required to determine the appropriate test load and the impact of such a change on measured energy efficiency. AHAM indicated that it would be impossible to complete this work prior to the January 1, 2015 compliance date of the amended standards, even were it appropriate to make such a change during the 3-year lead time before the amended standards. (AHAM, No. 17 at p. 14) Samsung also supported using the DOE test load to minimize measurement system uncertainty, based on DOE's data and internal experience that the IEC/AHAM loads could result in higher variation. Samsung stated that even though the DOE load is different from real-world loads, it is expected that the DOE load will identify relative differences between the test units with higher precision. (Samsung, No. 13 at p. 2)
Hydromatic stated that there is no definition of a real-world test load. (Hydromatic, Public Meeting Transcript, No. 10 at pp. 40-55)
DOE recognizes interested parties concerns regarding the test load composition and the available field study data that show a variety of weights, composition, and size of consumer laundry loads. DOE did not receive any data or information from interested parties that would alter its determination that the test-to-test and lab-to-lab variation using the current IEC/AHAM test load is sufficiently higher than with the DOE test load to warrant the continued use of the DOE test load. Further, DOE concludes that specifying any alternative load with more variation in weights, composition, and size than the DOE test load would increase the test-to-test and lab-to-lab variation. Repeatable and reproducible test procedures are necessary to ensure that testing results are consistent from test to test and lab to lab especially for compliance and verification testing. In addition, although certain manufacturers may use AHAM HLD-1 for measuring clothes dryer performance and these manufacturers may experience reduced testing burden if DOE specified the IEC/AHAM load in its test procedure, the use of AHAM HLD-1 is voluntary and thus this benefit may not apply to all manufacturers. For these reasons, DOE is not adopting amendments to the DOE test load in today's final rule. In addition, due to a lack of sufficient information at this time, DOE is not adopting a definition of a real-world load in today's final rule. DOE may continue collecting data on clothes dryer test loads and may consider amendments to the test load in a future rulemaking if data is made available showing that the variation from test to test and lab to lab can be reduced, particularly for different batches and lots of test loads.
Test Load Preparation
AHAM requested that DOE provide further definition of what is considered a “very fine spray” and what is meant by “uniform” when adding water to make the final mass adjustments. AHAM questioned whether testers should use a spray bottle, a detergent bottle with holes in it, or some other method, and that without clarity on these points, variation could be introduced into the test procedure. AHAM stated that the method for application of the water could impact the measured energy use. AHAM suggested that DOE further investigate the impact this method could have on measured energy use, including contacting manufacturers for input. AHAM stated that it cannot provide data on the impact on measured energy efficiency, if any, until DOE clarifies “very fine spray.” (AHAM, No. 17 at p. 12) ALS opposed tightening the allowable range for the initial RMC to ± 0.33 percent because it claimed manufacturers and test labs will aim to be at the low end of this tolerance, and then try to utilize the proposed technique of “uniformly” misting with a “very fine spray” the outside of the test load to achieve the initial RMC. ALS believes that the sprayed moisture on the outside of the test load is the easiest to evaporate during the energy test and can skew the test result. (ALS, No. 16 at pp. 3-4)
DOE does not believe that the method for wetting the test load, which requires water to be initially extracted to achieve an RMC between 52.5 percent and 57.5 percent then making final mass adjustments to obtain a test load with an RMC of 57.5 ± 0.33 percent by adding water uniformly to the load in a very fine spray, would significantly affect the measured efficiency at the extremes for the RMC conditions. Because the DOE test cloths are uniform and relatively thin, the water absorbed when making the final mass adjustments by adding water uniformly in a very fine spray would be absorbed relatively equivalently to the water absorbed when initially dampening the test load. In addition, DOE notes that the allowable range for the initial RMC of 57.5 ± 0.33 percent would result in a difference in the amount of water contained in the test load of only approximately 0.06 lb at the minimum and maximum values. As a result, DOE does not believe this allowable range for the initial RMC would measurably affect the efficiency and that further tightening the tolerances would add testing burden to achieve the initial RMC. DOE also notes that for the testing conducted for the January 2013 NOPR, the test technicians did not attempt to control the tolerances for wetting the test load tighter than the ranges specified in the test method (
i.e.,
the initial extraction achieve an RMC between 52.5 percent and 57.5 and the final mass adjustments to obtain a test load with an RMC of 57.5 ± 0.33 percent). As a result, any effects in the measured efficiency would have been captured in the test-to-test variation for the automatic termination tests with the DOE test load (which was on average 1.87 percent). For these reasons, DOE is adopting the test load requirements proposed in the January 2013 NOPR and discussed above, with the following clarification. To provide a clear and consistent method, the amendments adopted in today's final rule specify in 10 CFR part 430, subpart B, appendix D2, section 2.7, that water added to make the final mass adjustments shall be uniformly distributed among all of the test cloths in a very fine spray using a spray bottle.
Automatic Termination Control Dryer Test Cycle
DOE proposed in the January 2013 NOPR to change the clothes dryer test cycle specified in 10 CFR part 430, subpart B, appendix D1, section 3.3 to require separate test methods for automatic termination control dryers and timer dryers. 78 FR 152, 170 (Jan. 2, 2013).
For automatic termination control dryers, DOE proposed to amend the clothes dryer test procedure to require the use of the control settings discussed in section III.B.2 of this notice. Specifically, DOE proposed to require that the “normal” automatic termination cycle program be selected for the test cycle, and that for clothes dryers that do not have a “normal” program, the cycle recommended by the manufacturer for drying cotton or linen clothes would be selected. 78 FR 152, 170 (Jan. 2, 2013). Where the drying temperature can be chosen independently of the program, it would be set to the maximum
temperature setting.
Id.
In addition, the proposed amendments would require that where the dryness level setting can be chosen independently of the program, the dryness level would be set to the “normal” or “medium” setting.
Id.
If such designation is not provided, then the dryness level would be set at the mid-point between the minimum and maximum settings. DOE also proposed to require that the cycle settings used for the test cycle be recorded.
Id.
For the reasons explained below, DOE proposed that the clothes dryer would then be allowed to run until the completion of the cycle, including any cool-down period. After the cycle is complete, the test load would be weighed to determine the final RMC. If the final RMC is below 2 percent, the test would be considered valid. If the RMC is higher than 2 percent, the test would be considered invalid and would be re-run using the highest dryness level setting.
Id.
DOE proposed in the January 2013 NOPR to measure the full automatic termination cycle, including any cool-down period, to be more representative of actual consumer use. DOE determined in the January 2013 NOPR that the proposed provision to include a cool-down period would result in less testing burden than the January 2011 Final Rule proposal to stop the test cycle when the heater switches off for the final time immediately before the cool-down period begins (76 FR 972, 998 (Jan. 6, 2011)), which would require the tester to monitor the clothes dryer and possibly run multiple test cycles to determine when the heater has switched off for the final time. 78 FR 152, 170 (Jan. 2, 2013).
As discussed above, DOE also proposed in the January 2013 NOPR to base the calculations for automatic termination control dryers on a nominal final RMC of 2 percent. This is a change from the existing test procedure, which requires that the clothes dryer test cycle be stopped when the final RMC is between 2.5 percent and 5 percent. Based on the data submitted in the Joint Petition and DOE's analysis, DOE tentatively concluded in the January 2013 NOPR that a final RMC of 2 percent using the DOE test load would be more representative of clothes dryers currently on the market and representative of the maximum consumer-accepted final RMC.
Id.
NEEA stated that, based on its field study data, consumers select the medium temperature setting 52 percent of the time. (NEEA, Public Meeting Transcript, No. 10 at p. 21) The California IOUs commented that DOE should update the required temperature settings in the test procedure to reflect consumer preferences, based on recent field measurements. The California IOUs stated that DOE should make these revisions in a new test procedure rulemaking. The California IOUs noted that the NEEA field data also show that consumers select the high and low temperature settings 35 percent and 13 percent of the time, respectively. (California IOUs, No. 22 at pp. 17, 20)
DOE does not have information to determine for the clothes dryer models included in the field study whether the temperature setting can be selected independently of the cycle program and whether the sample of clothes dryers in the field study is representative of the optional temperature settings for all clothes dryer shipments. As a result, DOE notes that there is uncertainty as to whether the temperature settings selected by participants in the NEEA field study, which included only 50 households in the Pacific Northwest, are representative of the selections of the nation as a whole. For these reasons, DOE is not considering changing the temperature settings for the automatic termination test cycle proposed in the January 2013 NOPR at this time. However, DOE notes that according to the provisions for the cycle settings proposed in the January 2013 NOPR, which specify that the highest temperature setting be used if the temperature setting can be chosen independently of the cycle program setting, six of the 14 units in DOE's test sample that had a temperature setting indicator on the control panel were unable to select the temperature setting separately from the cycle program and automatically used the medium temperature setting for the test cycle. In addition, DOE may continue to collect and consider available data and information on the temperature settings to consider whether changes to the temperature settings would be warranted in a future test procedure rulemaking.
NEEA stated that, based on its field study data, consumers select the normal dryness setting 57 percent of the time and the very dry setting 42 percent of the time. (NEEA, Public Meeting Transcript, No. 10 at p. 21) The California IOUs commented that many people use the very dry setting, and that it is not true that all consumers are satisfied with the dryness of their clothing when using the normal dryness setting, based on the study conducted by NRDC in 2011 that found that real clothing would have to be dried to approximately 2-percent final RMC in order to feel uniformly dry to the touch. The California IOUs commented that, since the DOE test cloths are much easier to dry than real-world loads, the test cloths would need to be significantly lower than 2-percent final RMC to approximate a 2-percent final RMC in real clothing. The California IOUs stated that with a test load that more closely approximates real-world clothing, such as the AHAM HLD-1-1992 test load, a 2-percent final RMC would be appropriate. (California IOUs, No. 22 at pp. 20-21)
DOE notes that the NRDC report prepared by Ecova and referenced by the California IOUs states that the 2-percent RMC threshold for what consumers would consider “dry” for real-world clothing is an assertion made by NRDC and Ecova without any empirical basis.
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As a result, DOE is not considering changing the dryness level settings for the automatic termination test cycle proposed in the January 2013 NOPR. In addition, for the reasons discussed above, DOE is not considering changing the DOE test load at this time.
12
Denkenberger, Serena Mau, Chris Calwell, and Eric Wanless. 2011. Residential Clothes Dryers: A Closer Look at Energy Efficiency Test Procedures and Savings Opportunities. Ecova and NRDC. p. 7.
NEEA & NPCC and the California IOUs commented that the NEEA field study showed that participants used timed drying 29 percent of the time, and the auto-termination cycle 71 percent of the time. NEEA & NPCC and the California IOUs considered 29 percent to be a significant fraction of total clothes dryer cycles, and therefore stated that the test procedure should require clothes dryers with automatic cycle termination to be tested both in the timed drying and auto cycle termination modes. (NEEA & NPCC, No. 21 at pp. 13-14; California IOUs, No. 22 at p. 11)
Because the field study sample was limited, DOE does not have sufficient information at this time to determine how frequently all consumers in the nation use the timed dry function versus the automatic cycle termination function and, thus, properly weight or apportion the energy consumption between the two drying modes in the clothes dryer test procedure. DOE also notes that Whirlpool submitted a comment in the last test procedure rulemaking asserting that, although the majority of consumers want timed dry cycle capability, they use it only 10 percent of the time. 76 FR 972, 995 (Jan. 6, 2011). In addition, requiring the measurement of both the automatic termination cycle and the timed dry cycle for automatic termination control
dryers would significantly increase testing burden. As a result, DOE is not considering amendments in today's final rule to require the measurement of both the automatic termination cycle and the timed dry cycle for automatic termination control dryers.
d. Automatic Termination Control Dryer Field Use Factor
DOE proposed in the January 2013 NOPR that the measured test cycle energy consumption be multiplied by a field use factor of 0.80 to calculate the per-cycle energy consumption for automatic termination control dryers based on the data presented above in section III.B.2. DOE noted in the January 2013 NOPR that this field use factor would account for the measured energy consumption at the end of the automatic termination cycle drying the DOE test load below 2-percent RMC, which DOE determines to be representative of consumer-acceptable drying levels with loads of varying weights, composition, and size. 78 FR 152, 170 (Jan. 2, 2013).
AHAM and ALS opposed the proposed 0.80 field use factor, asserting that it is without technical or empirical justification. AHAM added that the Joint Petition did not include such a factor because it is not necessary under the proposed test procedure. AHAM and ALS stated that based on testing, DOE must rely on the proposed field use factor to justify the determination of a
de minimus
impact on the measured efficiency according to DOE's criteria (
e.g.,
less than a 5-percent impact on measured efficiency). AHAM commented that it is inappropriate for DOE to include the 0.80 field use factor to avoid adjusting the standard, and that DOE should either provide a “crosswalk” or not make such significant test procedure changes except as part of a future standards rulemaking. (AHAM, No. 17 at p. 4; ALS, No. 16 at p. 3)
Samsung agreed with DOE's proposed field use factor. Samsung alternatively recommended that the 0.80 field use factor not be included in the test procedure and that the standard levels be adjusted to account for the energy increase due to the test procedure change according to 42 U.S.C. 6293(e)(2). (Samsung, No. 13 at p. 3)
NEEA & NPCC, ASAP, ACEEE, SEDI, and the California IOUs commented that the 0.80 field use factor for automatic termination cycles inappropriately adjusts per-cycle energy use, significantly underestimating the annual clothes dryer energy use measured in the field. (NEEA & NPCC, No. 21 at pp. 3-4; ASAP, Public Meeting Transcript, No. 10 at pp. 28, 85-86; ACEEE, Public Meeting Transcript, No. 10 at pp. 200-201; SEDI, No. 14 at p. 3; California IOUs, No. 22 at p. 3) NEEA & NPCC stated that, based on its analysis and testing, the proposed test procedure estimates annual energy use that is approximately 30 percent lower than what is observed in the field. NEEA & NPCC commented that their testing demonstrates reasonably close agreement in energy use between DOE's proposed test procedure, but without the field use factor, and testing with a more real-world procedure. NEEA & NPCC stated that average annual clothes dryer energy use estimated from NEEA's 2012 field study is 920 kWh, and suggests that the field use factor should be closer to 1.1 or 1.2, assuming all other test procedure factors are unchanged. (NEEA & NPCC, No. 21 at p. 6) NEEA & NPCC strongly recommended that DOE not use a field use factor less than 1.0 to adjust the actual measured energy use from testing. (NEEA & NPCC, No. 21 at pp. 2-3, 12; NEEA, Public Meeting Transcript, No. 10 at pp. 87-92) NPCC added that the proposed field use factor is not consistent with the original proposal in the Joint Petition. (NPCC, Public Meeting Transcript, No. 10 at p. 104) The California IOUs commented that the NEEA field study data supports a field use adjustment factor of 1.0, or it should be removed entirely, since the field data consistently point to clothes dryers using more energy than they do under the DOE test procedure. (California IOUs, No. 22 at p. 6, 17; California IOUs, Public Meeting Transcript, No. 10 at pp. 170-171) SEDI added that CLASP-funded laboratory testing suggests that clothes dryers in the field consume more energy than would be measured by the proposed test procedure even without the field use factor. (SEDI, No. 14 at p. 3)
NEEA & NPCC and the California IOUs commented that DOE's data show that the average clothes dryer operating on an automatic termination cycle uses on the order of 25 percent more energy than it would if it terminated the cycle at optimum load dryness. NEEA & NPCC and the California IOUs commented that the difference between the end-of-cycle energy use and the energy use upon initially reaching 2-percent RMC represent an energy savings opportunity that manufacturers should be encouraged to pursue through modifications to automatic termination controls. NEEA & NPCC and the California IOUs stated that the proposed field use factor would revise the measured energy use for automatic termination control dryers that don't terminate at an initial 2-percent RMC down to a value that might have been achieved if the clothes dryer terminated properly. (NEEA & NPCC, No. 21 at p. 6; California IOUs, No. 22 at p. 5; California IOUs, Public Meeting Transcript, No. 10 at pp. 76-77, 101-102)
The California IOUs noted that in two cases (DOE test units 4 and 17), the adjusted energy consumption is lower than the measured energy consumption at both 5-percent and 2-percent RMC, and likely represents the energy consumption at points in the cycle when the test load would have been damp to the touch. The California IOUs stated that the field-adjusted values that DOE presented, therefore, are not representative of field clothes dryer performance. The California IOUs also stated that DOE's sample of 8 clothes dryer models is not sufficiently large to provide statistically meaningful information on the field use factor. (California IOUs, No. 22 at pp. 5-6; California IOUs, Public Meeting Transcript, No. 10 at pp. 94-97)
NEEA & NPCC commented that DOE's testing showed, with one exception, that the final RMC values for the IEC/AHAM test load are higher than with the DOE test load but the increase in the final RMC was not consistent from model to model. NEEA & NPCC stated that, as a result, any single field use factor is problematic. (NEEA & NPCC, No. 21 at p. 5) NEEA & NPCC also noted that the proposed automatic termination test procedure significantly increases the range of tested efficiencies, but that this increase is not predictable for a given clothes dryer. NEEA & NPCC stated that the most and least efficient models using the current DOE test procedure are not the most and least efficient models using the proposed automatic termination test procedure but with a more realistic test load. NEEA & NPCC stated that the proposed field use factor will simply reduce the calculated per cycle energy use, thereby reducing the differentiation among models. (NEEA & NPCC, No. 21 at p. 6)
The Joint Efficiency Advocates commented that DOE should adjust the January 1, 2015 standards to account for the proposed test procedure amendments without the proposed field use factor. However, the Joint Efficiency Advocates stated that if DOE concludes that it cannot adjust the standard levels, DOE should proceed with the proposal in the January 2013 NOPR. (Joint Efficiency Advocates, No. 19 at pp. 2-3)
SEDI objected to the proposed 0.80 field use factor, but commented that if DOE chooses to retain the field use
factor, manufacturers should be required to report clothes dryer energy consumption both with and without the field use factor applied. SEDI stated that accurate energy consumption information is critical for energy efficiency programs to be able to evaluate potential for incentives for more efficient products. (SEDI, No. 14 at p. 3)
Earthjustice commented that DOE should revise the proposed field use factor for automatic termination control dryers. Earthjustice stated that DOE's test data show that the load composition has much less of an impact on the effectiveness of automatic termination controls than DOE's proposed field use factor assumes. Earthjustice commented that for nearly all of the 20 clothes dryers that DOE tested, the difference in CEF between the AHAM and DOE test loads was less than 10 percent, with an average reduction in CEF of about 4 percent. Earthjustice stated that the adjustment needed for the CEF ratings to better reflect real world conditions is not only much smaller than DOE has proposed, it is in the opposite direction, and that DOE's proposal would lead to CEFs that significantly overstate the energy efficiency of many automatic termination control dryers. (Earthjustice, No. 15 at pp. 1-2)
Earthjustice stated that DOE's analysis shows that drying the DOE test load to 2-percent RMC at the end of the cycle reasonably approximates drying a test load that is more representative of the varied composition and heavier fabrics encountered in real world laundry loads to 5-percent RMC. Earthjustice stated that based on the test data in the January 2013 NOPR, the only field use factor that should be applied is a small correction to reflect that drying the AHAM test load to the end of a cycle achieving 5-percent RMC results in CEF levels about 4 percent below those measured drying the DOE test cloth as proposed in the January 2013 NOPR. (Earthjustice, No. 15 at p. 2)
Based on these comments and DOE's review of available data, DOE agrees that eliminating the field use factor for automatic termination control dryers will produce test results that are more representative of consumer use. As a result, in today's final rule, DOE is not adopting the 0.80 field use factor proposed in the January 2013 NOPR, but is instead removing the field use factor for automatic termination control dryers in appendix D2 because the test method directly measures the over-drying energy consumption. Because DOE is not amending appendix D or appendix D1 to include the methods for more accurately measuring the effects of automatic cycle termination, as discussed in section III.B.3.f, DOE is not amending the current field use factors specified in section 4.1 in 10 CFR part 430, subpart B, appendix D and appendix D1.
e. Wrinkle Prevention Mode and the Determination of the Completion of the Test Cycle
In the January 2013 NOPR, DOE proposed for the automatic cycle termination test method that the clothes dryer shall be operated until the completion of the programmed cycle, including the cool-down period. 78 FR 152, 170 (Jan. 2, 2013).
NRDC commented that DOE should clarify the definition of “completion of test cycle” for clothes dryers with automatic termination controls. NRDC noted that many clothes dryers have post-cycle features, such as additional tumbling designed to prevent wrinkling, that may run after the clothes dryer has terminated the main drying cycle. NRDC stated that these features can sometimes be enabled by the user and sometimes are the default operational mode. NRDC recommended that DOE modify the proposed test procedure to clarify that the cycle is complete when the main cycle terminates and the clothes dryer indicates to the consumer that the load is finished. (NRDC, No. 20 at pp. 1-2; NRDC, Public Meeting Transcript, No. 10 at pp. 129-131) NRDC also urged DOE to conduct a new rulemaking as soon as possible to further revise the clothes dryer test procedure to address post-cycle energy use to better represent real world energy use. (NRDC, No. 20 at p. 2)
NEEA & NPCC commented that it is unclear whether the current test procedure is designed to capture the energy use associated with the wrinkle prevention mode, which is part of the default cycle in some clothes dryer models. NEEA & NPCC stated that the wrinkle prevention mode meets DOE's definition of an active mode, and yet DOE's testing stopped the test at the completion of the cool-down phase. NEEA & NPCC stated clothes dryers typically use 150-250 watts of power when rotating the drum (and by default in most models, the fan) and that over a few hours, the wrinkle prevention mode could use as much as 0.5 kWh depending on how often the feature is activated and for how long at the end of each cycle. NEEA & NPCC stated that this clothes dryer feature should be accounted for accurately in the test procedure, regardless of any increase in the test burden associated with the measurement. According to NEEA & NPCC, the potential energy use of this function may be large enough to make the difference as to whether or not a clothes dryer complies with the standard, and so is not insignificant. (NEEA & NPCC, No. 21 at p. 14) NEEA added that if a cyclical wrinkle prevention period goes on indefinitely, it may cause issues with determining when to measure standby and off mode if the end of the cycle is not clearly defined. (NEEA, Public Meeting Transcript, No. 10 at pp. 154-155)
The California IOUs, Hydromatic, and the U.S. Environmental Protection Agency (EPA) also questioned how the wrinkle prevention mode would be tested and how the end of the cycle would be determined. The California IOUs stated that it is a relatively new feature, but it is becoming more prevalent. (California IOUs, Public Meeting Transcript, No. 10 at pp. 153, 154; Hydromatic, Public Meeting Transcript, No. 10 at pp. 124-128, 132-133; EPA, Public Meeting Transcript, No. 10 at pp. 122-123)
AHAM stated that the cycle ends when the clothes dryer signals to the consumer that the cycle is complete, and that wrinkle prevention or similar functions are selected by the user and should not be included in the DOE test unless they are activated by default in the condition as shipped. AHAM stated that this approach will minimize ambiguity for testers, thus resulting in less variation in the test procedure. (AHAM, No. 17 at p. 13) ALS similarly recommended testing with the default settings and not with other optional settings such as a wrinkle prevention extended cycle. (ALS, No. 16 at p. 4)
DOE conducted a market survey and testing to evaluate the wrinkle prevention mode. DOE noted that products operate in wrinkle prevention mode either intermittently or by continuously tumbling for a fixed period of time or until the user opens the clothes dryer door. Based on DOE's review of products currently available on the market, approximately 95 percent of products that are equipped with a wrinkle prevention feature offer it as a mode that must be manually selected by the user (
i.e.,
wrinkle prevention is turned off by default). Approximately 63 percent of products that are equipped with a wrinkle prevention feature operate in this mode by intermittently tumbling. For the products in DOE's test sample, the intermittent tumbling consisted of 3 to 5 seconds of tumbling every 5 to 10 minutes for a fixed period of time. Such intermittent tumbling was observed for all products on the market that operated in wrinkle prevention mode automatically by default after the end of the programmed cycle, with the
maximum duration among the sample units being 5 hours. DOE estimates that products that intermittently tumble for 5 hours would consume approximately 8.3 Wh in the wrinkle prevention mode. In the worst-case scenario for clothes dryers on the market for which the wrinkle prevention mode must be selected manually by the user, continuous tumbling was observed with a duration of up to 45 minutes and a corresponding energy consumption as much as approximately 188 Wh.
DOE is unaware of consumer usage data on how often consumers select the wrinkle prevention mode when this feature must be manually selected or data on the typical elapsed time between the end of the programmed cycle and when the consumer opens the clothes dryer door to remove the laundry load. As a result, DOE is not amending the test procedure to include the measurement of the wrinkle prevention mode when this feature must be manually selected by the consumer. As discussed in section III.F.1, DOE is adopting amendments to clarify for automatic termination control dryers that the test procedures specify requirements only for the automatic termination cycle program, temperature setting, and dryness setting, and do not specify modifications to any other optional settings that do not affect the automatic termination cycle program, temperature setting, or dryness setting. As a result, if a product is equipped with a wrinkle prevention feature that is activated by default in the condition as shipped by the manufacturer, the wrinkle prevention mode would be included in the test measurement cycle unless it precluded the necessary automatic termination cycle program, temperature setting, or dryness setting. DOE also notes that, based on the requirements that products be installed in accordance with manufacturers' instructions, if a manufacturers' user manual specifies that the wrinkle prevention mode is recommended to be activated for normal use even if it not done so in the as-shipped condition, the products would be tested with the wrinkle prevention mode activated as per manufacturer's instructions.
DOE is adopting amendments in today's final rule to clarify in 10 CFR part 430, subpart B, appendix D2, section 3.3.2, that the drying cycle is complete when the clothes dryer indicates to the user that the cycle has finished (by means of a display, indicator light, audible signal, or other signal) and the heater and drum/fan motor shuts off for the final time. If the clothes dryer is equipped with a wrinkle prevention mode (
i.e.,
that continuously or intermittently tumbles the clothes dryer drum after the clothes dryer indicates to the user that the cycle has finished) that is activated by default in the as-shipped position or if manufacturers' instructions specify that the feature is recommended to be activated for normal use, the cycle shall be considered complete after the end of the wrinkle prevention mode.
f. New Appendix D2
With the exception of the field use factor and the compliance date, AHAM and ALS supported the proposed test procedure for automatic termination control dryers. In light of its objection to the proposed field use factor and compliance date, however, AHAM stated that it cannot support these changes at this time and DOE should instead defer the changes until compliance with a future standard, subsequent to the January 1, 2015 standards change. (AHAM, No. 17 at p. 13; ALS, No. 16 at p. 4)
Samsung supported the proposed automatic termination test method, including the maximum allowable RMC of 2 percent. Samsung stated that the proposed test procedure is representative of consumer usage because it measures the energy use of the most commonly selected cycle (Normal/Cottons and Linens) and includes the cool-down period. Samsung stated that the proposed test procedure would encourage manufacturers to refine their automatic termination feature to terminate drying very close to the target 2-percent RMC using the DOE test load, without the over-drying evidenced on some clothes dryer models during DOE testing, thus reducing real-world energy consumption. (Samsung, No. 13 at pp. 2-3)
ASAP, ASE, ACEEE, CFA, NCLC jointly commented (hereafter “the Joint Efficiency Advocates”) and SEDI, NRDC, NEEA & NPCC, and the California IOUs commented that they generally support the proposed automatic termination test procedure amendments. The Joint Efficiency Advocates, NRDC, NEEA & NPCC, and the California IOUs noted that DOE's test data presented in the January 2013 NOPR show that there is wide variability among clothes dryers in the effectiveness of automatic termination controls, and that many clothes dryers waste a significant amount of energy at the end of the automatic termination cycle (up to 38 percent of energy use). NRDC and SEDI added that the proposed test procedure will capture this energy use at the end of the cycle and will result in differentiation of the measured efficiency of individual clothes dryers. The Joint Efficiency Advocates stated that based on DOE's test data, the current test procedure in appendix D1 is not a good predictor of the efficiency of the complete automatic termination cycle. The Joint Efficiency Advocates, NEEA & NPCC, and the California IOUs stated that the proposed automatic cycle termination test procedure will encourage manufacturers to adopt improved automatic termination controls and will provide a significant national energy savings opportunity. The California IOUs added that DOE's sample is too small to conclusively estimate this savings opportunity, but a study conducted by NRDC on 15 clothes dryers concluded that a variety of energy-saving technologies, including automatic termination, could save 20 percent to 30 percent of overall energy consumption by preventing over-drying. (Joint Efficiency Advocates, No. 19 at pp. 1-2; SEDI, No. 14 at p. 2; NRDC, No. 20 at p. 1; NEEA & NPCC, No. 21 at pp. 2, 4-5; California IOUs, No. 22 at pp. 3-5)
Based on the comments from interested parties and for the reasons discussed above, DOE is adopting the automatic termination test method proposed in the January 2013 NOPR with modification as further discussed above. With regards to AHAM's comments concerning the compliance date, as discussed in section III.B.3.f and section III.I.3, DOE is amending the clothes dryer test procedure in 10 CFR part 430, subpart B to create a new appendix D2 that includes the testing methods for more accurately measuring the effects of automatic cycle termination. As discussed in section III.I.3, the newly created appendix D2 will not be required for use to determine compliance with the January 1, 2015 energy conservation standards for clothes dryers. DOE is not amending appendix D1 in today's final rule to include the amendments associated with automatic termination controls. Appendix D2 is for informational purposes only.
Timed Dry Test Method
For timer dryers, DOE proposed in the January 2013 NOPR to use the test method currently specified in 10 CFR part 430, subpart B, appendix D1, section 3.3, but with a revised final RMC requirement. The proposed test method would require that the clothes dryer be operated using the highest temperature setting and maximum time setting. The clothes dryer would then be allowed to run until the final RMC of the load is between 1.0 percent and 2.5
percent, at which point the test cycle would be stopped without permitting the clothes dryer to advance into the cool-down period and the test load would be weighed. DOE also proposed to add a clarification that the clothes dryer should not be stopped intermittently in the middle of the test cycle for any reason. DOE stated that this clarification would ensure that test technicians are not stopping the clothes dryer intermittently to weigh the test load to check whether the RMC is within the target range. Such a practice would alter the measured results because of the heat loss from the clothes dryer when the cycle is stopped. 78 FR 152, 171 (Jan. 2, 2013).
DOE proposed in the January 2013 NOPR to include separate calculations for the per-cycle energy consumption for timer dryers. The calculations would be similar to the calculations provided in the current DOE test procedure in 10 CFR part 430, subpart B, appendix D1, sections 4.1-4.3, except that the normalization of the per-cycle energy consumption to represent the energy consumption required to dry the test load to 4-percent RMC would be changed to represent the new target RMC of 2 percent. The per-cycle energy consumption calculation in the current test procedure applies a scaling factor of 53.5, which represents the RMC percentage point change from the nominal initial RMC of 57.5 percent to the nominal final RMC of 4 percent. The proposed amendments would change this scaling factor to 55.5 to reflect the new final RMC of 2 percent. DOE proposed a range of 1.0 percent to 2.5 percent for the allowable final RMC during the test cycle to reduce testing burden. DOE tentatively concluded in the January 2013 NOPR that requiring the tester to dry the test load to an exact RMC during the test cycle would be unduly burdensome because it could require the test to be repeated a significant number of times until the exact RMC is achieved. For the test procedure to produce repeatable results, the measured test cycle energy consumption is normalized to calculate the energy consumption required to dry the test load from exactly 57.5-percent RMC to 2-percent RMC, which is representative of clothes dryers currently on the market and of the maximum consumer-accepted final RMC. 78 FR 152, 171 (Jan. 2, 2013).
DOE proposed in the January 2013 NOPR that manufacturers continue to apply the field use factor needed to account for the energy consumption of timed drying beyond the 2-percent RMC specified in the test procedure. DOE did not propose any changes to the 1.18 field use factor for timer dryers because DOE stated that it is not aware of any data or studies more recent than the studies on which it was originally based that would indicate that this value is not currently representative of consumer use.
DOE did not propose in the January 2013 NOPR to include the cool-down period as part of the timed dry test cycle because the proposed test method requires drying the load to a specified RMC, at which point the test cycle is stopped by the test technician. DOE determined that specifying a timed dry cycle that includes the cool-down period to achieve a target final RMC would add significant testing burden on test technicians to determine and preset the appropriate time setting. DOE also noted that it would be difficult to ensure that testing results are repeatable and reproducible because different combinations of timed dry cycle length and cool-down period may be selected to dry a test load to the same final RMC.
AHAM commented that it did not oppose the proposed timed dry test method on a technical basis. AHAM stated, however, because it considers these changes to be part of the proposed amendments regarding automatic cycle termination controls, it cannot support these changes at this time. AHAM commented that DOE should defer the changes until compliance with future energy conservation standards, subsequent to the January 1, 2015 standards. (AHAM, No. 17 at p. 13) ALS also opposed the proposed timed drying test method because it opposed any test procedure change with an effective date concurrent with the January 1, 2015 standards. (ALS, No. 16 at p. 4) As discussed in section III.I.3, DOE is adopting the amendments to more accurately measure the effects of automatic cycle termination in a new appendix D2 that will not be required for use to determine compliance with the January 1, 2015 energy conservation standards for clothes dryers. As a result, in today's final rule, DOE is also adopting the timer dryer test methods presented above in 10 CFR part 430, subpart B, appendix D2, section 3.3.2. DOE is not amending appendix D1 in today's final rule to include these amendments.
Incorporating by Reference IEC Standard 62301 Second Edition for Measuring Standby Mode and Off Mode Power
As discussed in section I of today's final rule, EPCA, as amended by EISA 2007, requires that test procedures be amended to include standby mode and off mode energy consumption, taking into consideration the most current versions of IEC Standards 62301 and 62087. (42 U.S.C. 6295(gg)(2)(A)) The January 2011 Final Rule incorporated in the test procedures for clothes dryers relevant provisions from IEC Standard 62301 (First Edition) for measuring standby mode and off mode power. 76 FR 972, 979-80 (Jan. 6, 2011). DOE reviewed the IEC Standard 62301 (First Edition) and concluded that it would be generally applicable to clothes dryers, although some clarification would be needed. Specifically, DOE adopted amendments for standby mode and off mode power measurements to provide a stabilization period of 30 to 40 minutes followed by an energy use measurement period of 10 minutes. 76 FR 986 (Jan.6, 2011). With these clarifications in place, the January 2011 Final Rule referenced IEC Standard 62301 (First Edition) for the standby mode and off mode wattage measurements. DOE also incorporated into the clothes dryer test procedure definitions of “active mode,” “standby mode,” and “off mode” based on the definitions provided in IEC Standard 62301 CDV. 76 FR 76 FR 981-85 (Jan. 6, 2011).
IEC Standard 62301 (Second Edition) published on January 27, 2011. Consistent with EPCA requirements for amending test procedures to include standby and off mode procedures, DOE considered IEC Standard 62301 (Second Edition) for amendments to the standby mode and off mode test procedures for clothes dryers in the January 2013 NOPR. (42 U.S.C. 6295(gg)(2)(A)) DOE determined that IEC Standard 62301 (Second Edition) is an internationally-accepted test procedure for measuring standby power in residential appliances, and it provides clarification to certain sections as compared to the First Edition. In the January 2013 NOPR, DOE proposed to update its reference to IEC Standard 62301 by incorporating certain provisions of IEC Standard 62301 (Second Edition), along with clarifying language, into the DOE test procedures for clothes dryers. 78 FR 152, 171 (Jan. 2, 2013).
AHAM and ALS commented that they support the incorporation by reference of IEC Standard 62301 (Second Edition). AHAM stated that the Second Edition contains a number of important clarifications not present in the First Edition and that adopting the Second Edition will allow for optimum international harmonization, which gives clarity and consistency to the regulated community. (AHAM, No. 17 at pp. 13-14; ALS, No. 16 at p. 4)
The suitability of specific clauses from IEC Standard 62301 (Second Edition) regarding testing conditions
and methodology for use in DOE's clothes dryer test procedure are discussed in the following paragraphs.
Section 4, paragraph 4.4 of the Second Edition revises the power measurement accuracy provisions of the First Edition. A more comprehensive specification of required accuracy is provided in the Second Edition, which depends upon the characteristics of the power being measured. Testers using the Second Edition are required to measure the crest factor and power factor of the input power, and to calculate a maximum current ratio (MCR) (paragraph 4.4.1 of the Second Edition). The Second Edition then specifies calculations to determine permitted uncertainty in MCR. DOE noted in the January 2013 NOPR, however, that the allowable uncertainty is the same or less stringent than the allowable uncertainty specified in the First Edition, depending on the value of MCR and the power level being measured. DOE determined that this change in the allowable uncertainty, however, maintains sufficient accuracy of measurements under a full range of possible measured power levels without placing undue demands on the instrumentation. These power measurement accuracy requirements were based upon detailed technical submissions to the IEC in the development of IEC Standard 62301 Final Draft International Standard (FDIS), which showed that commonly-used power measurement instruments were unable to meet the original requirements for certain types of loads. DOE concluded in the January 2013 NOPR that the incremental testing burden associated with the additional measurements and calculations is offset by the more reasonable requirements for testing equipment, while maintaining measurement accuracy deemed acceptable and practical by voting members for IEC Standard 62301 (Second Edition). For these reasons, DOE proposed in the January 2013 NOPR to incorporate by reference in 10 CFR part 430, subpart B, appendix D1, section 2.4.7 the power equipment specifications in section 4, paragraph 4.4 of IEC Standard 62301 (Second Edition). 78 FR 152, 171-172 (Jan. 2, 2013). AHAM commented that it supports incorporating by reference these provisions. (AHAM, No. 17 at p. 14) For the reasons discussed above, DOE adopts in today's final rule these amendments to its clothes dryer test procedure.
In the January 2013 NOPR, DOE noted that Section 5, paragraph 5.2 of IEC Standard 62301 (Second Edition) maintains the installation and setup procedures incorporated by reference in the clothes dryer test procedure in the January 2011 Final Rule from the First Edition. These provisions require that the appliance be prepared and set up in accordance with manufacturer's instructions, and that if no instructions are given, then the factory or default settings shall be used, or where there are no indications for such settings, the appliance is tested as supplied. Additionally, IEC Standard 62301 (Second Edition) adds certain clarifications to the installation and setup procedures in section 5, paragraph 5.2 of the First Edition regarding products equipped with a battery recharging circuit for an internal battery, as well as instructions for testing each relevant configuration option identified in the product's instructions for use. DOE stated in the January 2013 NOPR that it is not aware of any clothes dryer with an internal battery, or with a recharging circuit for such a battery. DOE also determined that a requirement to separately test each configuration option could substantially increase test burden and potentially conflicts with the requirement within the same section to set up the product in accordance with the instructions for use or, if no such instructions are available, to use the factory or default settings. Therefore, DOE tentatively concluded in the January 2013 NOPR that the portions of the installation instructions in section 5, paragraph 5.2 of IEC Standard 62301 (Second Edition) pertaining to batteries and the requirement for the determination, classification, and testing of all modes associated with every combination of available product configuration options (which may be more numerous than the modes associated with operation at the default settings) are not appropriate for the clothes dryer test procedures. Accordingly, DOE proposed qualifying language in the test procedure amendments in 10 CFR part 430, subpart B, appendix D1, section 2.1 to disregard those portions of the installation instructions. 78 FR 152, 172 (Jan. 2, 2013). AHAM commented that it does not oppose this proposal because it is also not aware of any clothes dryer with an internal battery or recharging circuit for such a battery. (AHAM, No. 17 at p. 14) Therefore, for the reasons discussed, DOE is amending the clothes dryer test procedure in today's final rule to incorporate by reference the installation instructions in section 5, paragraph 5.2 of IEC Standard 62301 (Second Edition) and to include qualifying language to disregard the portions pertaining to batteries and the requirement for the determination, classification, and testing of all modes associated with every combination of available product configuration options.
The Second Edition also contains provisions for the power supply (section 4.3) and power-measuring instruments (section 4.4). Paragraph 4.3.2 requires that the value of the harmonic content of the voltage supply be recorded during the test and reported. As described previously, paragraph 4.4.1 requires the instrument to measure the crest factor and maximum current ratio. Paragraph 4.4.3 requires the instrument to be capable of measuring the average power or integrated total energy consumption over any operator-selected time interval. In the January 2013 NOPR, DOE stated that it is aware of commercially available power measurement instruments that can perform each of these required measurements individually. However, DOE is also aware that certain industry-standard instruments, such as the Yokogawa WT210/WT230 digital power meter and possibly others, are unable to measure harmonic content or crest factor while measuring average power or total integrated energy consumption. DOE is concerned that laboratories currently using power-measuring instruments without this capability would be required to purchase, at potentially significant expense, additional power-measuring instruments that are able to perform all these measurements simultaneously. Therefore, DOE proposed in the January 2013 NOPR for 10 CFR part 430, subpart B, appendix D1, sections 2.3.1.1 and 2.4.7 that if the power-measuring instrument is unable to perform these measurements during the actual test measurement, it would be acceptable to measure the total harmonic content, crest factor, and maximum current ratio immediately before and immediately after the actual test measurement to determine whether the requirements for the power supply and power measurement have been met. 78 FR 152, 172 (Jan. 2, 2013). AHAM commented that it supports this proposal. (AHAM, No. 17 at p. 14) For the reasons discussed, DOE adopts these amendments to its clothes dryer test procedure in today's final rule.
The other major changes in the Second Edition related to the measurement of standby mode and off mode power consumption in covered products involve measurement techniques and specification of the stability criteria required to measure that power. The Second Edition contains more detailed techniques to evaluate the stability of the power consumption and to measure the power consumption for loads with different
stability characteristics. According to the Second Edition, the user is given a choice of measurement procedures, including sampling methods, average reading methods, and a direct meter reading method. For the January 2013 NOPR, DOE evaluated these new methods in terms of test burden and improvement in results as compared to the methods adopted in the January 2011 Final Rule, which were based on IEC Standard 62301 (First Edition).
In the January 2011 Final Rule, DOE adopted provisions requiring that clothes dryer standby mode and off mode power be measured using section 5, paragraph 5.3 of IEC Standard 62301 (First Edition), clarified by requiring the product to stabilize for 30 to 40 minutes and using an energy use measurement period of 10 minutes. Further, for any clothes dryer in which the power varies over a cycle, as described in section 5, paragraph 5.3.2 of the First Edition, the January 2011 Final Rule adopted amendments to require the use of the average power approach in section 5, paragraph 5.3.2(a), with a 30- to 40-minute stabilization period and a 10-minute minimum measurement period, as long as the measurement period comprises one or more complete cycles. 76 FR 972, 979-980, 985-986 (Jan. 6, 2011).
For the January 2013 NOPR, DOE analyzed the potential impacts of referencing methodology from IEC Standard 62301 (Second Edition) rather than from the First Edition by comparing the provisions allowed by each under different scenarios of power consumption stability. Based on its analysis, DOE concluded that the use of the Second Edition would improve the accuracy and representativeness of power consumption measurements and would not be unduly burdensome to conduct. As a result, DOE proposed in the January 2013 NOPR to incorporate by reference the relevant paragraphs of section 5.3 of IEC Standard 62301 (Second Edition) in the clothes dryer test procedure in 10 CFR part 430, subpart B, appendix D1, section 3.6. 78 FR 152, 172-174 (Jan. 2, 2013).
AHAM commented that it does not oppose the proposed requirement to use the sampling method in section 5.3.2 of the Second Edition. (AHAM, No. 17 at p. 14) For the reasons discussed above, DOE amends the clothes dryer test procedure in today's final rule to require in 10 CFR part 430, subpart B, appendix D1, section 3.6 the use of the sampling method in section 5.3.2 of the Second Edition for all standby mode and off mode power measurements.
DOE also amends the reference in 10 CFR 430.3 to add IEC Standard 62301 (Second Edition). DOE is not replacing the reference to the First Edition in 10 CFR 430.3, because several test procedures for other covered products not addressed in today's notice incorporate provisions from it. In addition, there are a number of editorial changes necessary in appendix D1 to allow for the correct referencing to the Second Edition. For example, the definition section in appendix D1 must define the IEC Standard 62301 as the Second Edition instead of the First Edition. Also, there are certain section numbering differences in the Second Edition that impact the text of the measurement provisions of the relevant test procedures in appendix D1. In addition, the definition and section references discussed above are incorporated in appendix D2.
E. Technical Correction to the Calculation of the Per-cycle Combined Total Energy Consumption
In the January 2013 NOPR, DOE noted that 10 CFR part 430, subpart B, appendix D1, section 4.6, regarding the calculation of the per-cycle combined total energy consumption contains a reference to an incorrect section number. The per-cycle standby mode and off mode energy consumption, E
TSO
, which is contained in section 4.5, is incorrectly referenced in the per-cycle combined total energy consumption as section 4.7. DOE proposed in the January 2013 NOPR to correct this section number reference. 78 FR 152, 174 (Jan. 2, 2013). DOE did not receive any comments on this topic in response to the January 2013 NOPR. In today's final rule, DOE adopts this amendment to its clothes dryer test procedure in appendix D1, and includes the correct calculation in newly adopted appendix D2.
F. Clarifications to Test Conditions
DOE noted in both the January 2013 NOPR and the February 2013 SNOPR that it had received a number of inquiries requesting clarification on testing according to the DOE clothes dryer test procedure in 10 CFR part 430, subpart B, appendix D. 78 FR 152, 174 (Jan. 2, 2013); 78 FR 8992 (Feb. 7, 2013). As discussed in the following sections, based on these inquiries, DOE is adopting amendments in today's final rule to clarify certain provisions in the DOE clothes dryer test procedure.
1. Cycle Settings
Section 3.3 in 10 CFR part 430, subpart B, appendix D specifies that the maximum temperature setting and, if a tested unit is equipped with a timer, the maximum time setting must be used for the drying test cycle. DOE noted in the January 2013 NOPR that it received an inquiry regarding how to test a clothes dryer that has timed dry cycle length settings, but no temperature settings on the control panel. DOE proposed in the January 2013 NOPR to clarify in 10 CFR part 430, subpart B, appendix D, section 3.3, that if the clothes dryer does not have a separate temperature setting selection on the control panel, the maximum time setting should be used for the drying test cycle. DOE also proposed in the January 2013 NOPR to include the clarification discussed above in section 3.3.1 of 10 CFR part 430, subpart B, appendix D1, for the timer dryer test method. 78 FR 152, 174 (Jan. 2, 2013).
AHAM commented that it does not oppose these clarifications for the cycle settings, nor does it oppose these changes becoming effective prior to the January 1, 2015 standards compliance date. (AHAM, No. 17 at p. 17) Because DOE did not receive any comments objecting to this proposal in response to the January 2013 NOPR and for the reasons discussed above, DOE adopts this clarification to its clothes dryer test procedure in appendix D and appendix D1 in today's final rule. Because DOE is amending the clothes dryer test procedure in today's final rule to create a new appendix D2 for informational purposes only that includes the methods for more accurately measuring the effects of automatic cycle termination, which includes a separate method for timer dryers, DOE is also including the same cycle settings clarification in section 3.3.1 of 10 CFR part 430, subpart B, appendix D2, for the timer dryer test method.
In the January 2013 NOPR, DOE noted that it also received an inquiry regarding how to test a clothes dryer that has an optional cycle setting, other than the temperature and time settings, that is activated by default in the condition as shipped by the manufacturer. DOE proposed to clarify in both 10 CFR part 430, subpart B, appendix D, section 3.3, and appendix D1, section 3.3.1, that the test procedures specify requirements only for the temperature setting and time setting, and do not specify modifications to any other optional settings that do not alter the temperature setting and time setting. Similarly, in 10 CFR part 430, subpart B, appendix D1, section 3.3.2, DOE proposed to clarify for automatic termination control dryers that any other optional cycle settings that do not affect the automatic termination cycle program, temperature setting, or dryness setting shall be tested in the as-shipped position. 78 FR 152, 174 (Jan. 2, 2013).
AHAM commented that it does not oppose the clarifications for the optional cycle settings because they are consistent with its position that units should be tested in the as-shipped condition. AHAM stated that if other settings are activated by default when the appropriate temperature and time settings are selected, the unit should be tested with those settings activated. AHAM noted, however, that because it opposes the amendments related to automatic termination controls at this time, it supports incorporating these clarifications in the current appendix D and appendix D1. Should DOE finalize the automatic termination control methodology and related amendments, but make them mandatory for compliance with some future standard (beyond 2015), AHAM stated it would support these clarifications in that test procedure as well. (AHAM, No. 17 at pp. 17-18)
For the reasons discussed above, DOE amends section 3.3 in 10 CFR part 430, subpart B, appendix D and D1 and section 3.3.1 in 10 CFR part 430 subpart B, appendix D2, to clarify that any other optional cycle settings that do not affect the temperature or time settings shall be tested in the as-shipped position. In addition, DOE amends section 3.3.2 of 10 CFR part 430, subpart B, appendix D2, which will not be required to demonstrate compliance with the 2015 standards, to clarify for automatic termination control dryers that any other optional cycle settings that do not affect the automatic termination cycle program, temperature setting, or dryness setting shall be tested in the as-shipped position.
2. Gas Supply Requirements
Section 2.3.2 in 10 CFR part 430, subpart B, appendix D and appendix D1, specifies that gas supply to the clothes dryer should be maintained at a normal inlet test pressure at 7 to 10 inches of water column, and that the hourly British thermal unit (Btu) rating of the burner shall be maintained within ± 5 percent of the rating specified by the manufacturer. DOE discussed in the January 2013 NOPR that it received an inquiry noting that during testing of a gas clothes dryer, the unit under test did not meet the requirement to maintain the Btu rating within 5 percent of the rating specified by the manufacturer under the allowable range in gas inlet test pressure. DOE proposed in the January 2013 NOPR to add a clarification in both 10 CFR part 430, subpart B, appendix D and appendix D1 that if the requirement to maintain the hourly Btu rating of the burner within ± 5 percent of the rating specified by the manufacturer cannot be achieved under the allowable range in gas inlet test pressure, the orifice of the gas burner should be modified as necessary to achieve the required Btu rating. 78 FR 152, 174-175 (Jan. 2, 2013).
AHAM and ALS opposed the proposal to change the orifice of the gas burner or any other hardware to meet the ± 5 percent requirement. AHAM added that the burner Btu rating is based on a test gas value intended to ensure product safety and that the average heating value and typical heating value during consumer use may be lower than the heating value of the test gas. AHAM commented that because the intent of the test procedure is to be representative of actual consumer use, DOE should not go forward with this proposal because the consumer would never and should never modify the orifice. (AHAM, No. 17 at p. 18; ALS, No. 16 at pp. 4-5)
DOE notes that the proposed requirement to modify the gas burner orifice if the hourly Btu rating specified by the manufacturer cannot be achieved under the allowable range in gas inlet pressure ensures that the burner output is reproducible from lab to lab for testing purposes. DOE notes that removing the gas supply requirements specified in the test procedure and allowing a wider range in the burner output could affect the measured efficiency and reproducibility of results because of the resulting variation in the heat input into the air entering the clothes dryer drum. In addition, DOE notes that the test procedure for gas water heaters similarly specifies that the burner should be adjusted as necessary to achieve the hourly Btu rating specified by the manufacturer. (10 CFR part 430, subpart B, appendix E, section 5.1.3) To ensure that test results are repeatable and reproducible, in today's final rule, DOE amends the clothes dryer test procedure in section 2.3.2 in 10 CFR part 430, subpart B, appendix D and appendix D1 to include this clarification for the gas supply requirements. In addition, because DOE is also amending the clothes dryer test procedure to include a new appendix D2, DOE is also including this clarification for the gas supply requirements in 10 CFR part 430, subpart B, appendix D2, section 2.3.2.
Section 2.3.2 in 10 CFR part 430, subpart B, appendix D and appendix D1 specifies that if a clothes dryer is equipped with a gas appliance pressure regulator, the regulator outlet pressure at the normal test pressure shall be approximately that recommended by the manufacturer. DOE noted in the January 2013 NOPR that the test procedures for similar gas heating products, such as gas water heaters, specify that the regulator outlet pressure must be within ± 10 percent of the value specified by the manufacturer. DOE proposed to clarify the term “approximately” by specifying that the regulator outlet pressure shall be within ± 10 percent of the value specified by the manufacturer. 78 FR 152, 175 (Jan. 2, 2013).
ALS supported DOE's proposal to clarify the outlet pressure range for the gas regulator. (ALS, No. 16, at p. 5) AHAM commented that the regulator outlet pressure should be as close as possible to that specified by the manufacturer. AHAM stated that this manufacturer recommendation helps ensure the safety of the product and, thus, the outlet pressure should not be altered. (AHAM, No. 17 at p. 18) Because DOE did not receive any comments objecting to this proposal in response to the January 2013 NOPR and for the reasons discussed above, DOE amends section 2.3.2 in 10 CFR part 430, subpart B, appendix D and appendix D1 in today's final rule to include the clarification that the regulator outlet pressure shall be within ± 10 percent of the value recommended by the manufacturer in the installation manual, on the nameplate sticker, or wherever the manufacturer makes such a recommendation for the basic model. In addition, because DOE is also amending the clothes dryer test procedure to include a new appendix D2, DOE is also including this clarification in 10 CFR part 430, subpart B, appendix D2, section 2.3.2.
3. Console Lights
In the February 2013 SNOPR, DOE noted that it received an inquiry requesting clarification on section 2.1 in 10 CFR part 430, subpart B, appendix D and appendix D1, which specifies for the installation conditions that all console lights or other lighting systems that do not consume more than 10 watts shall be disconnected during the clothes dryer active mode test cycle. 78 FR 8992, 8993 (Feb. 7, 2013). DOE noted that this provision was originally adopted in the September 1977 Final Rule. 42 FR 46145, 46146, 46150. DOE intended this provision to apply to an older generation of clothes dryers existing at the time of the September 1977 Final Rule that used task lights to illuminate the area of the clothes dryer for consumers doing the laundry that did not provide any function related to the drying process during the drying cycle. Newer-generation clothes dryers equipped with electronic controls may have control setting indicators such as indicator lights showing the cycle
progression, temperature or dryness settings, or other cycle functions. In contrast to the task lighting of older-generation clothes dryers, these indicator lights associated with cycle settings or the drying operation are fully integrated into the clothes dryer control printed circuit boards (PCBs). Disconnecting such lights would require extracting the control PCB from the clothes dryer and either physically cutting off the indicator lights or destroying their electrical signal traces etched on the PCB.
As a result of these differences, DOE proposed in the February 2013 SNOPR to clarify in section 2.1 in both appendix D and appendix D1 that “console lights or other lighting systems” refers to task lights that do not provide any function during the drying cycle related to the drying process, rather than the control setting indicators in newer-generation clothes dryers with electronic controls. DOE also proposed to clarify that control setting indicators such as indicator lights showing the cycle progression, temperature or dryness settings, or other cycle functions should not be disconnected during the active mode test cycle. 78 FR 8992, 8993 (Feb. 7, 2013).
AHAM and ALS commented that they do not oppose the proposed clarification for the installation conditions of console lights. AHAM added that because this is not different than current industry practice, this proposal would not impact measured efficiency. (AHAM, No. 17 at p. 18; ALS, No. 16 at p. 5) Because DOE did not receive any comments objecting to this proposal and for the reasons discussed above, DOE amends the section 2.1 in 10 CFR part 430, subpart B, appendix D and appendix D1 in today's final rule to include this clarification to the installation requirements for console lights or other lighting systems. In addition, because DOE is also amending the clothes dryer test procedure to include a new appendix D2, DOE is also including this clarification in 10 CFR part 430, subpart B, appendix D2, section 2.1.
4. Drum Capacity Measurements
Section 3.1 in 10 CFR part 430, subpart B, appendix D and appendix D1 specifies that when measuring drum capacity, the drum shall be filled with water to a level determined by the intersection of the door plane and the loading port. In addition, section 3.1 specifies that volume should be added or subtracted as appropriate depending on whether the plastic bag used for the measurement protrudes into the drum interior. DOE noted in the February 2013 SNOPR that it received an inquiry requesting clarification of this requirement. DOE proposed to amend section 3.1 to clarify that, for the measurement of the drum capacity, the intersection of the door plane and the loading port refers to the uppermost edge of the drum that is in contact with the door seal and that volume should be added or subtracted from the measured water fill volume to account for any space in the drum interior not measured by water fill (
e.g.,
space occupied by the door protruding into the drum interior). 78 FR 8992, 8993 (Feb. 7, 2013).
ALS supported DOE's proposal to clarify the drum capacity measurement. (ALS, No. 16 at p. 5) AHAM commented that it opposes the change for the drum capacity measurements in appendix D due to a lack of information and data on the impact, if any, on measured energy efficiency. AHAM stated that it does not have such data. AHAM also commented that the proposed amendments could impact manufacturers' reported capacities and that it would be burdensome to require such a change during the transition to the January 1, 2015 standards. AHAM suggested that DOE make this change only to appendix D1, and only if DOE determines that there would be no impact on measured energy efficiency. Otherwise, AHAM requested that any changes DOE made not be mandatory for compliance with the January 1, 2015 standards. According to AHAM, this would allow any impact on measured energy efficiency to be evaluated in the future. AHAM commented that it is possible that manufacturers have information on whether there is an impact on measured energy efficiency, and, thus, AHAM suggested that DOE contact manufacturers to understand the potential impact. (AHAM, No. 17 at pp. 18-19)
DOE notes that the amendment for the drum capacity measurement proposed in the February 2013 SNOPR would clarify the measurement method (
i.e.,
the level to which water is filled in the drum and the amount of volume added or subtracted from the measurement), but not change the measurement results. Therefore, the amendments to clarify the drum capacity measurement would not affect the measured drum volume or energy efficiency. In today's final rule, DOE amends section 3.1 in 10 CFR part 430, subpart B, appendix D and appendix D1 to include this clarification to the drum capacity measurement. In addition, because DOE is also amending the clothes dryer test procedure to include a new appendix D2, DOE is also including this clarification in 10 CFR part 430, subpart B, appendix D2, section 3.1.
The California IOUs commented that the current method for measuring drum capacity requires a technician to line the clothes dryer drum with a plastic bag and then fill the lined drum with water while the clothes dryer rests on its side on a scale. The California IOUs stated that this procedure is burdensome, presents a risk of very large water spills, and can introduce measurement errors because it is often difficult for technicians to ensure that the plastic bag has completely filled every extrusion inside the drum, particularly those just inside the drum opening. The California IOUs stated that DOE should consider the IEC method for drum volume measurement. (California IOUs, No. 22 at p. 24)
DOE notes that the drum volume measurement method in annex E of IEC Standard 61121 requires that the clothes dryer be placed on its side with the door leveled horizontally. The drum is then filled with specifically-sized table tennis balls without preventing the door closing. In addition, the table tennis balls are stirred occasionally to achieve the closest packing of balls possible and to eliminate void spaces. The number of table tennis balls are then counted and used to calculate the drum volume. DOE notes that this method could result in variation due to test technicians stirring the table tennis balls differently, and thus ending up with a different number of total balls in the drum. DOE also notes that counting the table tennis balls may be burdensome depending on the size of the drum. DOE notes that, if conducted properly, the drum capacity measurement using water is not significantly more burdensome that the drum volume measurement method in IEC Standard 61121. As a result, DOE is not considering such amendments to the drum capacity measurement method in today's final rule.
5. Maximum Allowable Scale Range
Section 2.4.1 in appendix D and appendix D1 specifies that the weighing scale for the test cloth shall have a range of 0 to a maximum of 30 lb with a resolution of at least 0.2 ounces and a maximum error no greater than 0.3 percent of any measured value within the range of 3 to 15 lb. Similarly, section 2.4.1.2 in appendix D and appendix D1 specifies that the weighing scale for drum capacity measurements should have a range of 0 to a maximum of 500 lb with resolution of 0.50 lb and a maximum error no greater than 0.5 percent of the measured value. DOE noted in the February 2013 SNOPR that it received an inquiry requesting clarification of this requirement. DOE recognizes that scales for weighing the
test cloth may have maximum capacity higher than 30 lb, but still meet the requirements for resolution and maximum error within the range of 3 to 15 lb, as specified in the test procedure. DOE also recognizes that a clothes dryer, when filled with water for the drum capacity measurement, could exceed 500 lb. As a result, DOE proposed in February 2013 SNOPR to allow a higher maximum scale range, 60 lb for weighing the test cloth and 600 lb for drum capacity measurements. DOE also noted that the resolution and maximum error requirements would remain unchanged. 78 FR 8992, 8993-8994 (Feb. 7, 2013).
AHAM stated that it did not oppose the proposal to increase the maximum allowable scale range while retaining the resolution and maximum error requirements. (AHAM, No. 17 at p. 19) ALS opposed DOE's proposal for the weighing scales, especially for the 600 lb maximum range for the weighing scale used for drum capacity measurements. ALS commented that a larger maximum range would be acceptable provided that the scale's accuracy in the range where the measurement is being made is calibrated to ISO 17025. (ALS, No. 16 at pp. 5-6) As discussed above, DOE is maintaining the resolution and accuracy requirements in the range where the measurement is being made that are specified in the current test procedure. DOE does not believe it is necessary to require a calibration to a specific standard as long as the resolution and accuracy requirements have been properly certified. For the reasons discussed above, in today's final rule, DOE adopts the amendments to sections 2.4.1 and 2.4.1.2 in 10 CFR part 430, subpart B, appendix D and appendix D1 to allow a higher maximum scale range, 60 lb for weighing the test cloth and 600 lb for drum capacity measurements, while maintaining the current resolution and maximum error requirements. In addition, because DOE is also amending the clothes dryer test procedure to include a new appendix D2, DOE is also incorporating these provisions for the weighing scale in 10 CFR part 430, subpart B, appendix D2, sections 2.4.1 and 2.4.1.2.
6. Relative Humidity Meter
Section 2.4.4 in appendix D and appendix D1 specifies that the dry and wet bulb psychrometer used for measuring the ambient humidity shall have an error no greater than ±1 degree Fahrenheit (°F). DOE noted in the February 2013 SNOPR that it received an inquiry requesting clarification of this provision. DOE recognizes that relative humidity meters may be an acceptable means to measure the ambient humidity. DOE also recognizes that some humidity meters may express error tolerances in terms of the dry and wet bulb temperatures, while others express error tolerances in terms of percent relative humidity. As a result, DOE evaluated how the ±1 °F tolerance for the dry and wet bulb temperatures translates to relative humidity. DOE determined in the February 2013 SNOPR, based on the allowable range in ambient temperature (72 to 78 °F) and ambient humidity (40 to 60 percent relative humidity) specified in the DOE test procedure, that a ±1 °F tolerance for the dry and wet bulb temperatures would translate to a tolerance between ±2 percent and ±4 percent relative humidity. As a result, DOE proposed that a relative humidity meter with a maximum error tolerance expressed in °F equivalent to the requirements for the dry and wet bulb psychrometer or with a maximum error tolerance of ±2 percent relative humidity would be acceptable for testing. 78 FR 8992, 8993-8994 (Feb. 7, 2013).
ALS supported DOE's proposed requirements for the relative humidity meter. (ALS, No. 16 at p. 6) Because DOE did not receive any comments objecting to this proposal in response to the February 2013 SNOPR and for the reasons discussed above, DOE adopts in today's final rule the amendments to section 2.4.4 in 10 CFR part 430, subpart B, appendix D and appendix D1 specifying that a relative humidity meter with a maximum error tolerance expressed in °F equivalent to the requirements for the dry and wet bulb psychrometer or with a maximum error tolerance of ±2 percent relative humidity would be acceptable for testing. In addition, because DOE is also amending the clothes dryer test procedure to include a new appendix D2, DOE is also including this clarification in 10 CFR part 430, subpart B, appendix D2, section 2.4.4.
G. Additional Test Procedure Issues
DOE received comments in response to the January 2013 NOPR and February 2013 SNOPR regarding a number of additional issues related to the clothes dryer test procedure. These issues are discussed in the following sections.
1. Consumer Usage Patterns and Capabilities
DOE received a number of comments regarding changes to reflect current consumer usage patterns and capabilities. NEEA and the California IOUs commented that based on the NEEA field use data, the drying energy consumption per-cycle in the field is different than what is measured in the DOE test procedure. NEEA stated that real-world drying times are longer and the energy used per load is greater. According to NEEA, their field use data indicates that the average annual energy use is 1134 kWh/year, which is nearly double what the DOE test procedure produces. According to the California IOUs, the typical annual energy use using DOE's proposed amendments to appendix D1 is 30 percent lower than values observed in the NEEA field study, which ranged from approximately 830 to 1,100 kWh/year. The California IOUs stated that the estimated clothes dryer energy use is 967 kWh/year when using the appendix D test procedure, which closely approximates the trends observed in the field data. The California IOUs stated that the proposed number of clothes dryer loads per year reduces the estimated annual energy use to 641 kWh/year, which is too low. (NEEA, Public Meeting Transcript, No. 10 at pp. 15-16, 17, 18; California IOUs, No. 22 at pp. 1-2)
The California IOUs commented that in terms of load size, typical drying times, and the measurement of automatic termination, NEEA's field study and the proposed test procedure in the January 2013 NOPR are in fair
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