Energy Conservation Program: Test Procedures for Residential and Commercial Clothes Washers

Federal RegisterSep 1, 2021

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DEPARTMENT OF ENERGY

10 CFR Parts 429, 430 and 431

[EERE-2016-BT-TP-0011]

RIN 1904-AD95

Energy Conservation Program: Test Procedures for Residential and Commercial Clothes Washers

AGENCY:

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

ACTION:

Notice of proposed rulemaking, request for comment, and announcement of webinar.

SUMMARY:

The U.S. Department of Energy (“DOE”) proposes to amend the test procedures for residential and commercial clothes washers to specify test conditions, instrument specifications, and test settings; address large clothes container capacities; add product-specific enforcement provisions; delete obsolete provisions; and consolidate all test cloth-related provisions and codify additional test cloth material verification procedures used by industry. DOE also proposes to create a new test procedure for residential and commercial clothes washers with additional modifications for certain test conditions, measurement of average cycle time, required test cycles, tested load sizes, semi-automatic clothes washer provisions, new performance metrics, and updated usage factors. The proposed new test procedure would be used for the evaluation and issuance of updated efficiency standards, as well as to determine compliance with the updated standards. As part of this proposal, DOE is announcing a webinar to collect comments and data on this proposal. DOE is seeking comment from interested parties on the proposal.

DATES:

DOE will accept comments, data, and information regarding this proposal no later than November 1, 2021. See section V, “Public Participation,” for details. DOE will hold a webinar on Tuesday, September 14, 2021, from 10:00 a.m. to 3:00 p.m. See section V, “Public Participation,” for webinar registration information, participant instructions, and information about the capabilities available to webinar participants.

ADDRESSES:

Interested persons are encouraged to submit comments using the Federal eRulemaking Portal at

www.regulations.gov.

Follow the instructions for submitting comments. Alternatively, interested persons may submit comments, by email to the following address:

ResClothesWasher2016TP0011@ee.doe.gov.

Include “Energy Conservation Program: Test Procedures for Residential and Commercial Clothes Washers” and docket number EERE-2016-BT-TP-0011 and/or RIN number 1904-AD95 in the subject line of the message. Submit electronic comments in WordPerfect, Microsoft Word, PDF, or ASCII file format, and avoid the use of special characters or any form of encryption.

Although DOE has routinely accepted public comment submissions through a variety of mechanisms, including postal mail and hand delivery/courier, the Department has found it necessary to make temporary modifications to the comment submission process in light of the ongoing corona virus 2019 (“COVID-19”) pandemic. DOE is currently accepting only electronic submissions at this time. If a commenter finds that this change poses an undue hardship, please contact Appliance Standards Program staff at (202) 586-1445 to discuss the need for alternative arrangements. Once the COVID-19 pandemic health emergency is resolved, DOE anticipates resuming all of its regular options for public comment submission, including postal mail and hand delivery/courier.

No telefacsimilies (“faxes”) will be accepted. For detailed instructions on submitting comments and additional information on the rulemaking process, see section V of this document.

Docket:

The docket, which includes

Federal Register

notices, public meeting attendee lists and transcripts (if a public meeting is held), comments, and other supporting documents/materials, is available for review at

www.regulations.gov.

All documents in the docket are listed in the

www.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.

The docket web page can be found at

www.regulations.gov/docket/EERE-2016-BT-TP-0011.

The docket web page contains instructions on how to access all documents, including public comments, in the docket. See section V for information on how to submit comments through

www.regulations.gov.

FOR FURTHER INFORMATION CONTACT:

Mr. Bryan Berringer, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-5B, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 586-0371. Email:

ApplianceStandardsQuestions@ee.doe.gov.

Ms. Kathryn McIntosh, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 586-2002. Email:

Kathryn.McIntosh@hq.doe.gov.

For further information on how to submit a comment, review other public comments and the docket, or participate in the webinar, contact the Appliance and Equipment Standards Program staff at (202) 287-1445 or by email:

ApplianceStandardsQuestions@ee.doe.gov.

SUPPLEMENTARY INFORMATION:

DOE proposes to incorporate by reference the following standards into part 430.

American Association of Textile Chemists and Colorists (“AATCC”) Test Method 79-2010, “Absorbency of Textiles,” Revised 2010.

AATCC Test Method 118-2007, “Oil Repellency: Hydrocarbon Resistance Test,” Revised 2007.

AATCC Test Method 135-2010, “Dimensional Changes of Fabrics after Home Laundering,” Revised 2010.

Copies of AATCC test methods can be obtained from AATC, P.O. Box 12215, Research Triangle Park, NC 27709, (919) 549-3526, or by going to

www.aatcc.org.

International Electrotechnical Commission (“IEC”) 62301, “Household electrical appliances—Measurement of standby power,” (Edition 2.0, 2011-01).

Copies of IEC 62301 are available from the American National Standards Institute, 25 W 43rd Street, 4th Floor, New York, NY 10036, (212) 642-4900, or by going to

webstore.ansi.org.

For a further discussion of these standards, see section IV.M of this document.

Table of Contents

I. Authority and Background

A. Authority

B. Background

II. Synopsis of the Notice of Proposed Rulemaking

III. Discussion

A. General Comments

B. Scope of Coverage

C. Testing Conditions and Instrumentation

1. Water Meter Resolution

2. Installation of Single-Inlet Machines

3. Water Supply Temperatures

4. Wash Water Temperature Measurement

5. Pre-Conditioning Requirements

D. Cycle Selection and Test Conduct

1. Tested Load Sizes

2. Water Fill Setting Selections for the Proposed Load Sizes

3. Determination of Warm Wash Tested Settings

4. Remaining Moisture Content

5. Cycle Time Measurement

6. Capacity Measurement

7. Anomalous Cycles

8. Semi-Automatic Clothes Washers

9. Optional Cycle Modifiers

10. Clothes Washers With Connected Functionality

E. Metrics

1. Replacing Capacity With Weighted-Average Load Size

2. Inverting the Water Metric

3. Annual Energy Use

4. Representation Requirements

F. Cleaning Performance

G. Consumer Usage Assumptions

1. Annual Number of Wash Cycles

2. Drying Energy Assumptions

3. Low-Power Mode Assumptions

4. Temperature Usage Factors

5. Load Usage Factors

6. Water Heater Assumptions

7. Commercial Clothes Washer Usage

H. Clarifications

1. Water Inlet Hose Length

2. Water Fill Selection Availability

3. Water Fill Control Systems

4. Energy Test Cycle Flowcharts

5. Wash Time Setting

6. Annual Operating Cost Calculation

7. Structure of the Proposed New Appendix J

8. Proposed Deletions and Simplifications

9. Typographical Errors

I. Test Cloth Provisions

1. Test Cloth Specification

2. Consolidation to Appendix J3

J. Product-Specific RMC Enforcement Provisions

K. Test Procedure Costs, Harmonization, and Other Topics

1. Test Procedure Costs and Impact

2. Harmonization With Industry Standards

3. Other Test Procedure Topics

L. Compliance Date and Waivers

IV. Procedural Issues and Regulatory Review

A. Review Under Executive Order 12866

B. Review Under the Regulatory Flexibility Act

1. Description of Reasons Why Action Is Being Considered

2. Objective of, and Legal Basis for, Rule

3. Description and Estimate of Small Entities Regulated

4. Description and Estimate of Compliance Requirements

5. Duplication, Overlap, and Conflict With Other Rules and Regulations

6. Significant Alternatives to the Rule

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. Description of Materials Incorporated by Reference

V. Public Participation

A. Participation in the Webinar

B. Procedure for Submitting Prepared General Statements for Distribution

C. Conduct of the Webinar

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

VI. Approval of the Office of the Secretary

I. Authority and Background

Consumer (residential) clothes washers (“RCWs”) are included in the list of “covered products” for which DOE is authorized to establish and amend energy conservation standards and test procedures. (42 U.S.C. 6292(a)(7)) DOE's energy conservation standards and test procedures for RCWs are currently prescribed at title 10 of the Code of Federal Regulations (“CFR”), part 430 section 23(j), and subpart B appendices J1 (“Appendix J1”) and J2 (“Appendix J2”). DOE also prescribes a test method for measuring the moisture absorption and retention characteristics of new lots of energy test cloth, which is used in testing clothes washers, at appendix J3 to subpart B (“Appendix J3”). Commercial clothes washers (“CCWs”) are included in the list of “covered equipment” for which DOE is authorized to establish and amend energy conservation standards and test procedures. (42 U.S.C. 6311(1)(H)) The test procedures for CCWs must be the same as those established for RCWs. (42 U.S.C. 6314(a)(8)) The following sections discuss DOE's authority to establish test procedures for RCWs and CCWs and relevant background information regarding DOE's consideration of test procedures for these products and equipment.

A. Authority

The Energy Policy and Conservation Act, as amended (“EPCA”),

authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. (42 U.S.C. 6291-6317) Title III, Part B

of EPCA established the Energy Conservation Program for Consumer Products Other Than Automobiles, which sets forth a variety of provisions designed to improve energy efficiency. These products include RCWs. (42 U.S.C. 6292(a)(7)) Title III, Part C

of EPCA, added by Public Law 95-619, Title IV, section 441(a), established the Energy Conservation Program for Certain Industrial Equipment. This equipment includes CCWs. (42 U.S.C. 6311(1)(H)) Both RCWs and CCWs are the subject of this document.

All references to EPCA in this document refer to the statute as amended through the Energy Act of 2020, Public Law 116-260 (Dec. 27, 2020).

For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.

For editorial reasons, upon codification in the U.S. Code, Part C was redesignated Part A-1.

The energy conservation program under EPCA consists essentially of four parts: (1) Testing, (2) labeling, (3) Federal energy conservation standards, and (4) certification and enforcement procedures. Relevant provisions of EPCA specifically include definitions (42 U.S.C. 6291; 42 U.S.C. 6311), test procedures (42 U.S.C. 6293; 42 U.S.C. 6314), labeling provisions (42 U.S.C. 6294; 42 U.S.C. 6315), energy conservation standards (42 U.S.C. 6295; 42 U.S.C. 6313), and the authority to require information and reports from manufacturers (42 U.S.C. 6296; 42 U.S.C. 6316).

The Federal testing requirements consist of test procedures that manufacturers of covered products must use as the basis for: (1) Certifying to DOE that their products comply with the applicable energy conservation standards adopted pursuant to EPCA (42 U.S.C. 6295(s); 42 U.S.C. 6316(a)), and (2) making representations about the efficiency of those consumer products (42 U.S.C. 6293(c); 42 U.S.C. 6314(d)). Similarly, DOE must use these test procedures to determine whether the products and equipment comply with relevant standards promulgated under EPCA. (42 U.S.C. 6295(s); 42 U.S.C. 6316(a))

Federal energy efficiency requirements for covered products and equipment established under EPCA generally supersede State laws and regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297; 42 U.S.C. 6316(a) and (b)) DOE may, however, grant waivers of Federal preemption for particular State laws or regulations, in accordance with the procedures and other provisions of EPCA. (42 U.S.C. 6297(d); 42 U.S.C. 6316(b)(2)(D))

Under 42 U.S.C. 6293 and 42 U.S.C. 6314, EPCA sets forth the criteria and procedures DOE must follow when prescribing or amending test procedures for covered products and equipment, respectively. EPCA requires that any test procedures prescribed or amended under this section be reasonably designed to produce test results which measure energy efficiency, energy use or estimated annual operating cost of a covered product or equipment during a representative average use cycle or period of use and not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(3); 42 U.S.C. 6314(a)(2))

In addition, EPCA requires that DOE amend its test procedures for all covered products to integrate measures of standby mode and off mode energy consumption. (42 U.S.C. 6295(gg)(2)(A))

Standby mode and off mode energy consumption must be incorporated into the overall energy efficiency, energy consumption, or other energy descriptor for each covered product unless the current test procedures already account for and incorporate standby and off mode energy consumption or such integration is technically infeasible. If an integrated test procedure is technically infeasible, DOE must prescribe a separate standby mode and off mode energy use test procedure for the covered product, if technically feasible. (42 U.S.C. 6295(gg)(2)(A)(ii))

Any such amendment must consider the most current versions of the IEC Standard 62301

and IEC Standard 62087

as applicable. (42 U.S.C. 6295(gg)(2)(A))

EPCA does not contain an analogous provision for commercial equipment.

IEC 62301,

Household electrical appliances—Measurement of standby power

(Edition 2.0, 2011-01).

IEC 62087,

Methods of measurement for the power consumption of audio, video, and related equipment

(Edition 3.0, 2011-04).

EPCA also requires that, at least once every 7 years, DOE evaluate test procedures for each type of covered product, including RCWs, to determine whether amended test procedures would more accurately or fully comply with the requirements for the test procedures to not be unduly burdensome to conduct and be reasonably designed to produce test results that reflect energy efficiency, energy use, and estimated operating costs during a representative average use cycle or period of use. (42 U.S.C. 6293(b)(1)(A))

If the Secretary determines, on his own behalf or in response to a petition by any interested person, that a test procedure should be prescribed or amended, the Secretary shall promptly publish in the

Federal Register

proposed test procedures and afford interested persons an opportunity to present oral and written data, views, and arguments with respect to such procedures. (42 U.S.C. 6293(b)(2)) The comment period on a proposed rule to amend a test procedure shall be at least 60 days and may not exceed 270 days.

Id.

In prescribing or amending a test procedure, the Secretary shall take into account such information as the Secretary determines relevant to such procedure, including technological developments relating to energy use or energy efficiency of the type (or class) of covered products involved.

Id.

If DOE determines that test procedure revisions are not appropriate, DOE must publish its determination not to amend the test procedures.

DOE has historically provided a 75-day comment period for test procedure NOPRs, consistent with the comment period requirement for technical regulations in the North American Free Trade Agreement, U.S.-Canada-Mexico (“NAFTA”), Dec. 17, 1992, 32 I.L.M. 289 (1993); the North American Free Trade Agreement Implementation Act, Public Law 103-182, 107 Stat. 2057 (1993) (codified as amended at 10 U.S.C.A. § 2576) (1993) (“NAFTA Implementation Act”); and Executive Order 12889, “Implementation of the North American Free Trade Agreement,” 58 FR 69681 (Dec. 30, 1993). However, Congress repealed the NAFTA Implementation Act and has replaced NAFTA with the Agreement between the United States of America, the United Mexican States, and the United Canadian States (“USMCA”), Nov. 30, 2018, 134 Stat. 11, thereby rendering E.O. 12889 inoperable. Consequently, since the USMCA is consistent with EPCA's public comment period requirements and normally requires only a minimum comment period of 60 days for technical regulations, DOE now provides a 60-day public comment period for test procedure NOPRs.

EPCA requires the test procedures for CCWs to be the same as the test procedures established for RCWs. (42 U.S.C. 6314(a)(8)) As with the test procedures for RCWs, EPCA requires that DOE evaluate, at least once every 7 years, the test procedures for CCWs to determine whether amended test procedures would more accurately or fully comply with the requirements for the test procedures to not be unduly burdensome to conduct and be reasonably designed to produce test results that reflect energy efficiency, energy use, and estimated operating costs during a representative average use cycle. (42 U.S.C. 6314(a)(1))

DOE is publishing this notice of proposed rulemaking (“NOPR”) in satisfaction of the 7-year review requirement specified in EPCA. (42 U.S.C. 6293(b)(1)(A); 42 U.S.C.6314(a)(1))

B. Background

As discussed, DOE's existing test procedures for clothes washers appear in Appendix J1, Appendix J2, and Appendix J3.

DOE originally established its clothes washer test procedure, codified at 10 CFR part 430, subpart B, appendix J (“Appendix J”),

in a final rule published Sept. 28, 1977. 42 FR 49802 (“September 1977 Final Rule”). Since that time, the test procedure has undergone several amendments that are relevant to this rulemaking, summarized as follows and described in additional detail in a request for information (“RFI”) that DOE published on May 22, 2020. 85 FR 31065 (“May 2020 RFI”).

In this NOPR, to distinguish different versions of each test method, DOE uses the following nomenclature: Appendix [letter]-[year of amendment]. For example, the original version of Appendix J is referred to as Appendix J-1977. The version as amended by the August 1997 Final Rule is referred to as Appendix J-1997, and so forth.

DOE amended Appendix J in August 1997 (62 FR 45484 (Aug. 27, 1997); “August 1997 Final Rule”) and January 2001 (66 FR 3313 (Jan. 12, 2001); “January 2001 Final Rule”). The August 1997 Final Rule also established an Appendix J1. 62 FR 45484. DOE amended Appendix J1 in the January 2001 Final Rule (66 FR 3313) and in March 2012. 77 FR 13887 (Mar. 7, 2012) (“March 2012 Final Rule”). The March 2012 Final Rule also established a new test procedure at Appendix J2 and removed the obsolete Appendix J-2001.

Id.

In that rulemaking, DOE also adopted procedures to measure standby mode and off mode energy consumption into the energy efficiency metrics in the then-newly created Appendix J2. Manufacturers were not required to incorporate those changes until the compliance date of an amended standard. 77 FR 13887, 13932. Amended standards were then adopted through a direct final rule that required the use of Appendix J2 for RCWs manufactured on or after the 2015 compliance date. 77 FR 32308, 32313 (May 31, 2012). The newly proposed Appendix J in this NOPR follows a similar approach because manufacturers would not be required to incorporate the amendments proposed in Appendix J until the compliance date of an amended standard.

DOE most recently amended both Appendix J1 and Appendix J2 in a final rule published on August 5, 2015. 80 FR 46729 (“August 2015 Final Rule”). The August 2015 Final Rule also moved the test cloth qualification procedures from Appendix J1 and Appendix J2 to the newly created Appendix J3. 80 FR 46729, 46735.

The current version of the test procedure at Appendix J2 includes provisions for determining modified energy factor (“MEF”) and integrated modified energy factor (“IMEF”) in cubic feet per kilowatt-hour per cycle (“ft

/kWh/cycle”); and water factor (“WF”) and integrated water factor (“IWF”) in gallons per cycle per cubic feet (“gal/cycle/ft

”). RCWs manufactured on or after January 1, 2018, must meet current energy conservation standards, which are based on IMEF and IWF, determined using Appendix J2. 10 CFR 430.32(g)(4); 10 CFR 430.23(j)(2)(ii) and (4)(ii). CCWs manufactured after January 1, 2018 must meet current energy conservation standards, which are based on MEF and IWF, determined using Appendix J2. 10 CFR 431.154 and 10 CFR 431.156(b).

DOE published the May 2020 RFI to initiate an effort to determine whether to amend the current test procedures for clothes washers. 85 FR 31065. DOE requested comment on specific aspects of the current test procedure, including product definitions and configurations, testing conditions and instrumentation,

measurement methods, representative usage and efficiency factors, and metric definitions. 85 FR 31065, 31067-31082 (May 22, 2020). In response to stakeholder requests, DOE re-opened the comment period for the May 2020 RFI. 85 FR 38106 (June 25, 2020).

On December 16, 2020, DOE established separate product classes for top-loading RCWs with a cycle time of less than 30 minutes and for front-loading RCWs with a cycle time of less than 45 minutes. 85 FR 81359 (“December 2020 Final Rule”). DOE is re-evaluating the new short-cycle product classes in response to Executive Order 13900, “Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis.” 86 FR 7037 (Jan. 25, 2021). In addition, stakeholders and interested parties filed multiple lawsuits challenging the December 2020 Final Rule, and DOE has received several petitions for reconsideration of the December 2020 Final Rule.

DOE received comments in response to the May 2020 RFI from the interested parties listed in Table I.1.

Table I.1—Written Comments Received in Response to May 2020 RFI

Commenter(s)

Reference in this NOPR

Commenter type

Appliance Standards Awareness Project, American Council for an Energy-Efficient Economy, Consumer Federation of America, National Consumer Law Center, Natural Resources Defense Council

Joint Commenters

Efficiency Organizations.

Association of Home Appliance Manufacturers

AHAM

Trade Association.

Electrolux Home Products

Electrolux

Manufacturer.

GE Appliances

GEA

Manufacturer.

Northwest Energy Efficiency Alliance

NEEA

Efficiency Organization.

Pacific Gas and Electric Company, Southern California Edison, San Diego Gas & Electric Company

California Investor-Owned Utilities (“CA IOUs”)

Utilities.

Samsung Electronics America

Samsung

Manufacturer.

Underwriters Laboratories

Third-Party Test Laboratory.

Whirlpool Corporation

Whirlpool

Manufacturer.

A parenthetical reference at the end of a comment quotation or paraphrase provides the location of the item in the public record.

The parenthetical reference provides a reference for information located in the docket of DOE's rulemaking to develop test procedures for clothes washers. (Docket No. EERE-2016-BT-TP-0011, which is maintained at

www.regulations.gov/docket/EERE-2016-BT-TP-0011

). The references are arranged as follows: (Commenter name, comment docket ID number, page of that document).

II. Synopsis of the Notice of Proposed Rulemaking

In this NOPR, DOE proposes to update Appendix J2 as follows:

(1) Further specify supply water temperature test conditions and water meter resolution requirements;

(2) Add specifications for measuring wash water temperature using submersible data loggers;

(3) Expand the load size table to accommodate clothes container capacities up to 8.0 cubic feet (“ft

”);

(4) Define “user-adjustable automatic water fill control;”

(5) Specify the applicability of the wash time setting for clothes washers with a range of wash time settings;

(6) Specify how the energy test cycle flow charts apply to clothes washers that internally generate hot water;

(7) Specify that the energy test cycle flow charts are to be evaluated using the Maximum load size;

(8) Specify that testing is to be conducted with any network settings disabled if instructions are available to the user to disable these functions;

(9) Further specify the conditions under which data from a test cycle would be discarded;

(10) Add product-specific enforcement provisions to accommodate the potential for test cloth lot-to-lot variation in remaining moisture content (“RMC”);

(11) Delete obsolete definitions, metrics, and the clothes washer-specific waiver section; and

(12) Move additional test cloth related specifications to Appendix J3.

In this NOPR, DOE is also proposing to update 10 CFR part 430, subpart B, appendix J3, “Uniform Test Method for Measuring the Moisture Absorption and Retention Characteristics,” as follows:

(1) Consolidate all test cloth-related provisions, including those proposed to be moved from Appendix J2;

(2) Reorganize sections for improved readability; and

(3) Codify the test cloth material verification procedure as used by industry.

In this NOPR, DOE is also proposing to create a new appendix J to 10 CFR part 430, subpart B, “Uniform Test Method for Measuring the Energy Consumption of Automatic and Semi-Automatic Clothes Washers,” which would be used for the evaluation and issuance of any updated efficiency standards, as well as to determine compliance with the updated standards, should DOE determine that amended standards are warranted based on the criteria established by EPCA.

The proposed new Appendix J would include the following additional provisions beyond those proposed as amendments to Appendix J2:

Information regarding the ongoing RCW and CCW energy conservation standards rulemakings can be found at docket numbers EERE-2017-BT-STD-0014 and EERE-2019-BT-STD-0044, respectively.

(1) Modify the hot water supply target temperature and clothes washer pre-conditioning requirements;

(2) Modify the Extra-Hot Wash threshold temperature;

(3) Add measurement and calculation of average cycle time;

(4) Reduce the number of required test cycles by requiring the use of no more than two Warm Wash/Cold Rinse cycles, and no more than two Warm Wash/Warm Rinse cycles;

(5) Reduce the number of required test cycles by removing the need for one or more cycles used for measuring RMC;

(6) Reduce the number of load sizes from three to two for units with automatic water fill controls;

(7) Modify the load size definitions consistent with two, rather than three, load sizes;

(8) Update the water fill levels to be used for testing to reflect the modified load size definitions;

(9) Specify the installation of single-inlet clothes washers, and simplify the test procedure for semi-automatic clothes washers;

(10) Define new performance metrics that are functions of the weighted-average load size rather than clothes

container capacity: “energy efficiency ratio,” “active-mode energy efficiency ratio,” and “water efficiency ratio;”

(11) Update the number of annual clothes washer cycles from 295 to 234; and

(12) Update the number of hours assigned to low-power mode to be based on the clothes washer's measured cycle time rather than an assumed fixed value.

Finally, in this NOPR, DOE is proposing to remove Appendix J1 and to update the relevant sections of 10 CFR parts 429, 430 and 431 in accordance with the edits discussed previously, and to modify the product-specific enforcement provisions regarding the determination of RMC.

DOE's proposed actions are summarized in Table II.1 compared to the current test procedures as well as the reason for the proposed change.

Table II.1—Summary of Changes in Proposed Test Procedures Relative to Current Test Procedures

Current DOE test procedure

Proposed test procedure

Attribution

Specifies a water meter resolution of no larger than 0.1 gallons

Requires a water meter with a resolution no larger than 0.01 gallons if the hot water use is less than 0.1 gallons, in Appendices J and J2

Improve representativeness of test results.

Does not specify how to install clothes washers with a single inlet

Specifies installing clothes washers with a single inlet to the cold water inlet, in Appendix J

Provide further direction for unaddressed feature.

Specifies a hot water supply temperature of 130-135 °F

Specifies a hot water supply temperature of 120-125 °F, in Appendix J

Improve representativeness of test results.

Defines the Extra-Hot Wash threshold as 135 °F

Specifies an Extra-Hot Wash threshold of 140 °F, in Appendix J

Improve representativeness of test results.

Specifies a target water supply temperature at the high end of the water supply temperature range

Removes the target water temperature specification, in Appendices J and J2

Reduce test burden.

Specifically allows the use of temperature indicating labels for measuring wash water temperature

Adds specification for using a submersible temperature logger to measure wash water temperature, in Appendices J and J2

Reduce test burden.

Specifies different pre-conditioning requirements for water-heating and non-water-heating clothes washers

Requires the same pre-conditioning requirements for all clothes washers, in Appendix J

Improve reproducibility of test results.

Specifies the test load sizes for clothes container capacities up to 6.0 ft

Specifies the test load sizes for clothes container capacities up to 8.0 ft

, in Appendices J and J2

Response to waiver.

Requires 3 tested load sizes on clothes washers with automatic water fill control systems

Reduces the number of load sizes to test to 2, and specifies new load sizes, in Appendix J

Reduce test burden.

Defines load sizes for each 0.1 ft

increment in clothes container capacity

Redefines load sizes for each increment in clothes container capacity, consistent with reduction from 3 to 2 load sizes, in Appendix J

Maintain representativeness.

Defines water fill levels to use with each tested load sizes on clothes washers with manual water fill control systems

Changes the water fill levels consistent with the updated load sizes, in Appendix J

Maintain representativeness.

Requires testing up to 3 Warm Wash temperature selections

Requires testing a maximum of 2 Warm Wash temperature selections, in Appendix J

Reduce test burden.

Specifies that the RMC is to be measured on separate cycle(s) from the energy test cycle

Specifies that the RMC is to be measured on all energy test cycles, in Appendix J

Reduce test burden, improve representativeness of test results.

Provides product-specific enforcement provisions to address anomalous RMC results that are not representative of a basic model's performance

Provides additional product-specific enforcement provisions to accommodate differences in RMC values that may result from DOE using a different test cloth lot than was used by the manufacturer for testing and certifying the basic model, for Appendices J and J2

Accommodate potential source of variation in enforcement testing.

Specifies that the starting weight of the test cloth may be up to 104 percent of bone-dry

Requires that the test cloth be bone-dry at the start of every test cycle, in Appendix J

Improve reproducibility of test results.

Does not specify a measure of cycle time

Specifies provisions for measuring cycle time, in Appendix J

Improve representativeness of test results.

Specifies discarding data from a wash cycle that provides a visual or audio indicator to alert the user that an out-of-balance condition has been detected, or that terminates prematurely if an out-of-balance condition is detected

Specifies discarding the test data if during a wash cycle the clothes washer signals the user by means of a visual or audio alert that an out-of-balance condition has been detected or terminates prematurely, in Appendices J and J2

Response to test laboratory question.

Does not explicitly state how to test semi-automatic clothes washers

Provides explicit test provisions for testing semi-automatic clothes washers, in Appendix J

Provide further direction for unaddressed feature.

Does not explicitly address the required configuration for network-connected functionality

Specifies that clothes washers with connected functionality shall be tested with the network-connected functions disabled if such settings can be disabled by the end-user, and the product's user manual provides instructions on how to do so, in Appendices J and J2

Improve reproducibility of test results.

Defines metrics that are dependent on capacity (IMEF, MEF, IWF)

Specifies new metrics that are dependent on the weighted-average load size, in Appendix J

Improve representativeness of test results.

Estimates the number of annual use cycles for clothes washers as 295, based on the 2005 Residential Energy Consumption Survey (“RECS”) data

Updates the estimate to 234 cycles per year, based on the latest available 2015 RECS data, in Appendix J

Update with more recent consumer usage data.

Estimates the number of hours spent in low-power mode as 8,465, based on 295 cycles per year and an assumed 1-hour cycle time

Calculates the number of hours spent in low-power mode for each clothes washer based on 234 cycles per year and measured cycle time, in Appendix J

Improve representativeness of test results.

Does not specify how to test a clothes washer that does not provide water inlet hoses

Specifies using a water inlet hose length of no more than 72 inches, in Appendix J

Response to test laboratory question.

Does not provide an explicit definition for “user-adjustable automatic water fill controls” or “wash time”

Provides a definition for “user-adjustable automatic water fill controls,” in Appendix J and for “wash time,” in Appendices J and J2

Improve readability.

Specifies that user-adjustable automatic clothes washers must be tested with the water fill setting in the most or least energy-intensive setting without defining energy-intensive

Changes the wording to specify selecting the setting based on the most, or least, amount of water used, in Appendices J and J2

Response to test laboratory question.

Does not specify on which load size to evaluate the energy test cycle flow charts

Specifies evaluating the flow charts using the maximum load size for Appendix J2 and the large load size for Appendix J

Response to test laboratory question, improve reproducibility of test results.

Does not explicitly address how to evaluate the Cold/Cold energy test cycle flow chart for clothes washers that internally generate hot water

Explicitly addresses clothes washers that internally generate hot water, in Appendices J and J2

Response to test laboratory question.

Does not provide direction for all control panel styles on clothes washers that offer a range of wash time settings

Clarifies how to test cycles with a range of wash time settings, in Appendices J and J2

Improve readability.

Includes test cloth verification specifications in Appendix J2

Moves all test cloth related provisions to Appendix J3

Improve readability.

Does not include all aspects of test cloth verification procedures performed by industry

Codifies additional test cloth verification procedures performed by industry, in Appendix J3

Codify industry practice.

Contains obsolete provisions

Updates or deletes obsolete provisions, including Appendix J1 in its entirety

Improve readability.

DOE has tentatively determined that the proposed amendments to Appendix J2 and Appendix J3 described in section III of this document would not alter the measured efficiency of clothes washers, and that the proposed test procedures would not be unduly burdensome to conduct.

DOE has tentatively determined that the proposed amendments in the new Appendix J would alter the measured efficiency of clothes washers, in part because the amended test procedures would adopt a different energy efficiency metric and water efficiency metric than in the current test procedure. Because the proposed new Appendix J would be used for the evaluation and issuance of updated efficiency standards, DOE is proposing that use of new Appendix J, if finalized, would not be required until the compliance date of any updated standards. Discussion of DOE's proposed actions are addressed in detail in section III of this document.

III. Discussion

In the following sections, DOE describes the proposed amendments to the test procedures for residential and commercial clothes washers. This NOPR includes issues identified in previous rulemakings and discusses additional issues that DOE has become aware of since the completion of the August 2015 Final Rule. DOE seeks input from the public to assist with its consideration of the proposed amendments presented in this document. In addition, DOE welcomes comments on other relevant issues that may not specifically be identified in this document.

A. General Comments

DOE received a number of general comments from stakeholders, as summarized below.

AHAM commented generally that no test can be considered “reasonably designed” under EPCA if the test is not accurate, repeatable, and reproducible. AHAM stated that test procedures with significant variation do not allow consumers to make informed purchase decisions based on energy use/efficiency and do not adequately serve the purpose of demonstrating compliance with energy conservation standards. (AHAM, No. 5 at p. 2) AHAM also claimed that as energy conservation standards become more stringent, minimizing variation in test procedure results becomes more important because of the need for manufacturers to conservatively rate their products. AHAM asserted that lack of uniform test results requires manufacturers to rate more conservatively, which effectively makes the standard more stringent in practice.

Id.

AHAM commented that the clothes washer test procedure is one of the most burdensome DOE test procedures for consumer appliances. AHAM provided an example that a full-featured clothes washer (one that includes manual and user-adjustable automatic water fill control systems (“WFCS”), a heater, four warm wash temperatures, warm rinse, and selectable spin speeds) could require more than 70 test cycles per unit under Appendix J2. (AHAM, No. 5 at pp. 4-5) GEA similarly commented that DOE should work to reduce test burden for full-featured clothes washers, stating that requiring 70 individual cycles for a single test of certain clothes washers demonstrates that the clothes washer test procedure has become overly complicated and fails to fulfill the representativeness requirement under the EPCA. (GEA, No. 13 at p. 2)

AHAM requested that if DOE implements any changes that will significantly impact measured energy, DOE should require compliance with the revised test procedure on the same date as the next amended energy conservation standards for clothes washers. (AHAM, No. 5 at p. 16)

Electrolux, GEA, and Whirlpool support AHAM's comments to the RFI. (Electrolux, No. 11 at p. 1; GEA, No. 13 at p. 1; Whirlpool, No. 7 at p. 1) GEA incorporates them into its own comments by reference. (GEA, No. 13 at

p. 1) Whirlpool further supports a reasonable balancing of the DOE test procedure, considering repeatability, reproducibility, representativeness, and testing burden. (Whirlpool, No. 7 at p. 1)

As stated, EPCA requires that any test procedures be reasonably designed to produce test results which measure energy efficiency, energy use or estimated annual operating cost of a covered product or equipment during a representative average use cycle or period of use and not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(3); 42 U.S.C. 6314(a)(2)) As described in this NOPR, DOE is proposing a number of changes to be implemented in a proposed new Appendix J that DOE has tentatively concluded would significantly reduce test burden while maintaining or improving the representativeness of test results. In addition, both the amendments to Appendix J2 and the proposed new Appendix J are intended to further improve the repeatability and reproducibility of test results, as described in the relevant sections of this document.

DOE is proposing to establish a new test procedure at a new Appendix J at 10 CFR part 430 subpart B. Any changes to the test procedure that would impact measured efficiency would be provided in this proposed new Appendix J, which DOE would use for the evaluation and issuance of updated efficiency standards. Therefore, DOE is proposing that use of new Appendix J would not be required until the compliance date of any updated standards that are based on new Appendix J. (42 U.S.C. 6295(gg)(2)(C)). DOE also proposes to state in the introductory text to both Appendix J2 and the proposed new Appendix J that Appendix J2 is required to determine compliance with energy conservation standards until any such amended standards are adopted.

B. Scope of Coverage

This NOPR covers those consumer products that meet the definition of “clothes washer,” as codified at 10 CFR 430.2.

EPCA does not define the term “clothes washer.” DOE has defined a “clothes washer” as a consumer product designed to clean clothes, utilizing a water solution of soap and/or detergent and mechanical agitation or other movement, that must be one of the following classes: Automatic clothes washers, semi-automatic clothes washers, and other clothes washers. 10 CFR 430.2.

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

Id.

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

Id.

“Other clothes washer” means a class of clothes washer that is not an automatic or semi-automatic clothes washer.

Id.

This NOPR also covers commercial equipment that meets the definition of “commercial clothes washer.” “Commercial clothes washer” is defined as a soft-mount front-loading or soft-mount top-loading clothes washer that—

(A) Has a clothes container compartment that—

(i) For horizontal-axis clothes washers, is not more than 3.5 cubic feet; and

(ii) For vertical-axis clothes washers, is not more than 4.0 cubic feet; and

(B) Is designed for use in—

(i) Applications in which the occupants of more than one household will be using the clothes washer, such as multi-family housing common areas and coin laundries; or

(ii) Other commercial applications.

(42 U.S.C. 6311(21); 10 CFR 431.452)

DOE is not proposing any changes to the scope of products and equipment covered by its clothes washer test procedures, or to the relevant definitions.

C. Testing Conditions and Instrumentation

1. Water Meter Resolution

Section 2.5.5 of Appendix J2 requires the use of water meters (in the hot and cold water lines) with a resolution no larger than 0.1 gallons and a maximum error no greater than 2 percent of the measured flow rate. DOE has observed that some clothes washers use very small amounts of hot water on some temperature selections, on the order of 0.1 gallons or less. 85 FR 31065, 31069. For example, some clothes washers have both Cold and Tap Cold temperature selections, and the Cold selection may use a fraction of a gallon of hot water. 85 FR 31065, 31070. DOE believes that Appendix J2 may not provide the necessary resolution to accurately and precisely measure the hot water usage of such temperature selections.

Id.

In the May 2020 RFI, DOE requested input on whether to amend section 2.5.5 of Appendix J2 to require that water meters must have a resolution more precise than 0.1 gallons.

Id.

The Joint Commenters encouraged DOE to require a water meter with greater precision than that of the current specification to ensure that the test procedures are accurately representing energy use. (Joint Commenters, No. 10 at p. 3)

AHAM commented that requiring more precise water meters could provide a benefit by increasing the accuracy of the measurements but could also increase the burden due to the cost of obtaining these meters that could become overly burdensome. (AHAM, No. 5 at p. 7)

GEA supported moving to a 0.01-gallon resolution for water meters. GEA stated that it uses water meters with this resolution and has encountered reproducibility issues when using a water meter with only 0.1-gallon resolution. (GEA, No. 13 at p. 2)

Whirlpool commented that requiring a more precise water meter is not justified. Whirlpool estimates that a manufacturer without these meters installed could face a cost of over $100,000 to purchase and install them, and cautioned that the need for a more precise water meter needs to be balanced with the cost burden. (Whirlpool, No. 7 at p. 1)

DOE has identified clothes washers on the market that use less than 0.1 gallons of hot water on certain temperature selections or load sizes required for testing. In DOE's experience with such clothes washers, the maximum load size typically uses more than 0.1 gallons of hot water on each of the available temperature selections (providing indication of which temperature selections use hot water), whereas the average and minimum load sizes may use a quantity less than 0.1 gallons. For these clothes washers, the existing water meter resolution of 0.1 gallons is insufficient to provide an accurate measurement of hot water consumption,

i.e.,

the volume of hot water measured is less than the resolution of the water meter. To improve the representativeness of the water measurement, DOE is proposing a requirement to use a water meter with greater precision for clothes washers that use less than 0.1 gallons of hot water. DOE's testing suggests that

clothes washers that use such low volumes of heated water represent a minority of units on the market. Requiring greater water meter precision for all clothes washers would represent an undue burden for those clothes washer models for which water meters with the currently required level of precision provide representative results. DOE is therefore proposing that the hot water meter must have a resolution no larger than 0.01 gallons only for clothes washers with hot water usage less than 0.1 gallons in any of the individual cycles within the energy test cycle. All other clothes washers may continue to be tested using a water meter with a resolution no larger than 0.1 gallons. As noted by GEA's comment, some manufacturers may already be using water meters with this greater resolution, and DOE's experience working with third-party laboratories indicates that at least some third-party laboratories already use water meters with this greater resolution.

DOE is proposing to include in section 2.5.5 of both the proposed new Appendix J and Appendix J2 the following specification: “If the volume of hot water for any individual cycle within the energy test cycle is less than 0.1 gallons (0.4 liters), the hot water meter must have a resolution no larger than 0.01 gallons (0.04 liters).”

DOE requests comment on its proposal to require a hot water meter resolution no larger than 0.01 gallons for clothes washers that use less than 0.1 gallons in any of the individual cycles within the energy test cycle. DOE requests comment on the extent to which manufacturers and test laboratories already use water meters with this greater resolution. DOE also requests comment on whether proposing this requirement for Appendix J2 would require manufacturers to retest any basic models that have already been certified under the existing water meter resolution requirements.

2. Installation of Single-Inlet Machines

Section 2.10 of Appendix J2 provides specifications for installing a clothes washer, referencing both the hot water and cold water inlets. Additionally, section 2.5.5 of Appendix J2 specifies that a water meter must be installed in both the hot and cold water lines. DOE is aware of RCWs on the market that have a single water inlet rather than separate hot and cold water inlets. 85 FR 31065, 31070. DOE has observed two types of single-inlet RCWs: (1) Semi-automatic clothes washers, which are generally intended to be connected to a kitchen or bathroom faucet and which require user intervention to regulate the water temperature by adjusting the external water faucet valves; and (2) automatic clothes washers intended to be connected only to a cold water inlet, and which regulate the water temperature through the use of an internal heating element to generate any hot water used during the cycle.

Id.

DOE stated in the May 2020 RFI that it understood that a “Y”-shaped hose or other similar device may be provided by the manufacturer on some automatic models to allow separate cold and hot water supply lines to be connected to the single inlet on the unit; however, other models may not include such a connector.

Id.

In the May 2020 RFI, DOE inadvertently attributed the use of a Y-shaped hose to

automatic

single-inlet clothes washers (

emphasis added

)—rather, DOE intended to describe that

semi-automatic

single-inlet clothes washers may provide or accommodate the use of a Y-shaped hose, based on its experience with testing semi-automatic clothes washers.

For single-inlet semi-automatic clothes washers (

i.e.,

the first example described previously), DOE has observed that these clothes washers are most often designed to be connected to a kitchen or bathroom faucet, with a single hose connecting the faucet to the single inlet on the clothes washer (

i.e.,

both cold and hot water are supplied to the clothes washer through a single hose).

The user regulates the water temperature externally by adjusting the faucet(s) to provide cold, warm, or hot water temperatures for the wash and rinse portions of the cycle.

As noted, some models may provide or accommodate a Y-shaped hose to connect the separate cold and hot water faucets or supply lines.

Section 3.2.3.2 of Appendix J2 provides setup instructions for semi-automatic clothes washers regarding the configuration of both cold and hot water faucets during testing. Specifically, the test procedure specifies that to obtain a hot inlet water temperature, open the hot water faucet completely and close the cold water faucet; for a warm inlet water temperature, open both hot and cold water faucets completely; and for a cold inlet water temperature, close the hot water faucet and open the cold water faucet completely. In the laboratory setup defined by section 2.2 of Appendix J2, the cold and hot water supplies are provided as separate hookups, in contrast to most faucets in residential settings, in which the cold and hot water supply lines combine internally within the faucet into a single output. Thus, the instructions in section 3.2.3.2 of Appendix J2 can be conducted only for either a semi-automatic clothes washer with both hot and cold water inlets (of which no such models are currently on the market, according to DOE research), or a single-inlet semi-automatic clothes washer installed with a Y-shaped hose or other similar device that combines the cold and hot water supply lines to connect to the single inlet on the unit (simulating most residential faucets, which combine the cold and hot water supply lines internally, as described). Appendix J2 does not, however, explicitly prescribe the use of a Y-shaped hose.

As described in the May 2020 RFI, without the use of a Y-shaped hose, connecting a single-inlet semi-automatic clothes washer to only a single water supply would limit the available water temperature to either 60 degrees Fahrenheit (“°F”) (provided by the cold water supply) or 135 °F (provided by the hot water supply), based on the supply water specifications currently provided in section 2.2 of Appendix J2. 85 FR 31065, 31070. In effect, only Cold Wash/Cold Rinse or Hot Wash/Hot Rinse could be tested with a single-hose installation.

Id.

As noted, Appendix J2 does not provide explicit direction on how to connect a single-inlet semi-automatic clothes washer to enable testing at other wash/rinse temperatures.

Id.

Therefore, DOE requested information on whether and how consumers using this type of clothes washer adjust their water temperature for the wash and rinse portions of the cycle and requested comments, data, and information on the typical connection and representative average use of single-inlet semi-automatic clothes washers. Additionally, DOE requested information on how manufacturers are currently testing single-inlet semi-automatic clothes washers under Appendix J2.

Id.

No comments were received regarding installation or testing of single-inlet semi-automatic clothes washers.

Based on the previous discussion, DOE maintains that additional direction in the test procedure is warranted for single-inlet semi-automatic clothes washers to produce test results that reflect representative consumer usage of cold, warm, and hot wash/rinse temperatures. DOE considered three potential changes to address the installation of single-inlet semi-automatic clothes washers: (1) Require the use of a Y-shaped hose, which would be used to connect the single inlet of the clothes washer to both the cold and hot water supply connections; (2) connect the single inlet of the clothes washer to a single water supply

connection with a non-fixed temperature output that can be nominally set to 60 °F (for cold), 97.5 °F (for warm), or 135 °F (for hot), for example; or (3) require connection to only the cold water supply, enabling testing of only the Cold/Cold wash/rinse temperature, and calculate the energy and water performance at other wash/rinse temperatures formulaically from the Cold/Cold cycle data. As discussed in detail in the following paragraphs, DOE is proposing to adopt option 3 in this NOPR.

Regarding option 1, requiring the use of a Y-shaped hose would provide a simple and low-cost approach for testing of cold, warm, and hot wash/rinse temperatures on single-inlet semi-automatic clothes washers. The Y-shaped hose would mimic the functionality provided by most residential faucets, and thus would provide a representative installation setup. However, by connecting the cold and hot lines to each other, differences in water pressure

between the two sides can result in unequal and unrepeatable water flow rates through the cold and hot sides.

Section 2.3 of Appendix J2 specifies maintaining water pressure of 35 pounds per square inch gauge (“psig”) ± 2.5 psig on both the cold and hot water supply lines. These tolerances could result in a pressure difference of up to 5 psig between the two lines.

Regarding option 2, (requiring a non-fixed temperature supply line that can be set to the specified cold, warm, or hot temperature), DOE tentatively concludes that such a requirement could present undue test burden on laboratories that do not currently implement variable-temperature supply water controls and instrumentation, given the relatively low number of single-inlet semi-automatic models on the market that would be tested each year. In addition, because temperature sensors are typically calibrated around the target temperature being measured, varying the temperature of the supply line between 60 °F and 120 °F could result in less accurate inlet water temperature measurements.

Regarding option 3, (connecting to the cold water inlet only, testing only on the Cold/Cold cycle, and determining performance at other temperatures numerically), as discussed further in section III.D.8.b of this document, energy and water performance at temperatures other than Cold Wash/Cold Rinse can be calculated numerically using test data from the Cold/Cold cycle because the measured characteristics

of a semi-automatic clothes washer cycle do not depend on the inlet water temperature. Therefore, DOE tentatively concludes that representative test results can be obtained with a minimal number of test cycles using this approach, which DOE proposes to incorporate into the proposed new Appendix J.

Measured characteristics of a semi-automatic clothes washer cycle include total water consumption, electrical energy consumption, cycle time, and bone-dry and cycle complete load weights. See section III.D.8.b of this document for more details.

DOE is proposing in this NOPR to make this change only in the proposed new Appendix J because connecting to only the cold water inlet may differ from how such units are currently being tested by manufacturers and laboratories under Appendix J2. DOE seeks information about implementing this change to Appendix J2 as well, specifically regarding how single-inlet semi-automatic clothes washers are being tested and any potential impact on the measured energy use of these clothes washers on the market.

See section III.D.8 of this document for a full discussion of other proposed edits to testing provisions for semi-automatic clothes washers and a list of related issues on which DOE seeks comment.

For a single-inlet

automatic

clothes washer, DOE discussed in the May 2020 RFI the use of a Y-shaped hose to allow both cold and hot water supply lines to be connected to the single inlet on the unit. 85 FR 31065, 31070 (

emphasis added

). DOE requested comments or information on how single-inlet automatic clothes washers are typically installed by consumers.

Id.

AHAM commented that it is not aware of a Y-shaped hose connecter being used for typical installation of single-inlet automatic clothes washers. (AHAM, No. 5 at p. 7)

As described previously, DOE inadvertently attributed the use of a Y-shaped hose to

automatic,

rather than

semi-automatic,

single-inlet clothes washers. DOE is not aware of any single-inlet automatic clothes washers that require the use of a Y-shaped hose connector because such clothes washers internally generate any hot water needed for the cycle. Based on a review of models currently certified in DOE's compliance certification database, DOE is aware of three models of single-inlet automatic clothes washers currently available on the market.

DOE's examination of user manuals for each of these single-inlet automatic clothes washers indicates that the instructions accompanying these products direct that they be connected to the cold water supply.

DOE's certification compliance database is available at

www.regulations.doe.gov/certification-data/CCMS-4-Clothes_Washers.html.

DOE identified the following single-inlet automatic models: WFW3090J**, WFW5090J**, WFC8090G**. Analysis conducted in March 2021.

Therefore, DOE is proposing in this NOPR to specify that all single-inlet automatic clothes washers be installed to the cold water supply only. As discussed above, DOE is proposing to include this provision in the proposed new Appendix J only. The proposed edit would specify in section 2.10.1 of the proposed new Appendix J that if the clothes washer has only one water inlet, connect the inlet to the cold water supply in accordance with the manufacturer's instructions.

DOE requests comment on its proposal to require all single-inlet clothes washers to be installed to the cold water supply only. DOE also requests comment on whether this requirement should be included in only the proposed new Appendix J, or whether, if adopted, it should be included as an amendment to Appendix J2.

3. Water Supply Temperatures

a. Hot Water Supply Temperature

Section 2.2 of Appendix J2 requires maintaining the hot water supply temperature between 130 °F (54.4 degrees Celsius (“°C”)) and 135 °F (57.2 °C), using 135 °F as the target temperature.

DOE has revised the hot water supply temperature requirements several times throughout the history of the clothes washer test procedures to remain representative of household water temperatures at the time of each analysis. When establishing the original clothes washer test procedure at Appendix J in 1977, DOE specified a hot water supply temperature of 140 °F ± 5 °F for clothes washers equipped with thermostatically controlled inlet water valves. 42 FR 49802, 49808. In the August 1997 Final Rule, DOE specified in Appendix J1 that for clothes washers in which electrical energy consumption or water energy consumption is affected by the inlet water temperatures,

the hot water supply temperature cannot exceed 135 °F (57.2 °C); and for other clothes washers, the hot water supply temperature is to be maintained at 135 °F ±5 °F (57.2 °C ± 2.8 °C). 62 FR 45484, 45497. DOE maintained these same requirements in the original version of Appendix J2. In the August 2015 Final Rule, DOE adjusted the allowable tolerance of the hot water

supply temperature in section 2.2 of Appendix J2 to between 130 °F (54.4 °C) and 135 °F (57.2 °C) for all clothes washers, but maintained 135 °F as the target temperature. 80 FR 46729, 46734-46735.

For example, water-heating clothes washers or clothes washers with thermostatically controlled water valves.

DOE analyzed household water temperatures as part of the test procedure final rule for residential and commercial water heaters published July 11, 2014. 79 FR 40541 (“July 2014 Water Heater Final Rule”). In the July 2014 Water Heater Final Rule, DOE revised the hot water delivery temperature from 135 °F to 125 °F based on an analysis of data showing that the average set point temperature for consumer water heaters in the field is 124.2 °F (51.2 °C), which was rounded to the nearest 5 °F, resulting in a test set point temperature of 125 °F. 79 FR 40541, 40554. Additionally, a 2011 compilation of field data across the United States and southern Ontario by Lawrence Berkeley National Laboratory (“LBNL”)

found a median daily outlet water temperature of 122.7 °F (50.4 °C).

Id.

Further, DOE noted in the July 2014 Water Heater Final Rule that water heaters are commonly set with temperatures in the range of 120 °F to 125 °F.

Id.

Lutz, JD, Renaldi, Lekov A, Qin Y, and Melody M, “Hot Water Draw Patterns in Single Family Houses: Findings from Field Studies,” LBNL Report number LBNL-4830E (May 2011). Available at

www.escholarship.org/uc/item/2k24v1kj.

Additionally, DOE's consumer dishwasher test procedure, codified at 10 CFR part 430 subpart B, appendix C1 (“Appendix C1”), specifies a hot water supply temperature of 120 °F ± 2 °F for water-heating dishwashers designed for heating water with a nominal inlet temperature of 120 °F, which includes nearly all consumer dishwashers currently on the U.S. market. Section 2.3.2 of Appendix C1. This water supply temperature is intended to be representative of household hot water temperatures.

Table III.1 summarizes the various hot water temperature data considered for the present rulemaking.

Table III.1—Summary of Field Surveys of Water Heater Temperature

Source

Description

Temperature

(°F)

May 2011 LBNL Report

Median daily outlet water temperature

122.7

July 2014 Water Heater Final Rule

Average set point temperature for consumer water heaters in the field

124.2

July 2014 Water Heater Final Rule

Common water heater setpoints

120-125

Appendix C1

Dishwasher test procedure supply temperature

120

In the May 2020 RFI, DOE requested comments on whether DOE should consider updating the hot water supply temperature specification for the clothes washer test procedures to be within the range of 120 °F to 125 °F, providing better consistency with DOE's test procedures for dishwashers and consumer water heaters. 85 FR 31065, 31069.

AHAM suggested that product design changes may be required if DOE amends the clothes washer test procedures to harmonize the hot water supply temperature with the dishwasher test procedure. AHAM stated that changing the hot water supply temperature specification would impact measured efficiency, and DOE would thus need to address that change in the accompanying standards rulemaking. (AHAM, No. 5 at p. 6)

GEA stated that there is little benefit to consumers by moving the target temperature to 120 °F. If DOE does change the target temperature, GEA is concerned about the change in measured hot water energy usage. (GEA, No. 13 at p. 2)

The CA IOUs recommended keeping the target temperature at 135 °F to prevent the growth of

Legionella

bacteria. The CA IOUs referenced the American Society of Sanitary Engineering (“ASSE”) Scald Awareness Task Group and Unified Plumbing Code (“UPC”) recommendations that hot water temperature should be 130-140 °F to eliminate the risk of

Legionella

growth. (CA IOUs, No. 8 at pp. 14-15)

The Joint Commenters stated that DOE should consider changing the target temperature to 120 °F, because 120 °F is the hot water supply temperature for the consumer dishwasher test procedure and is a common water heater set point. (Joint Commenters, No. 10 at p. 3) However, the Joint Commenters also stated that the 135 °F target temperature may be appropriate to maintain as average set points increase in the field due to

Legionella

concerns. The Joint Commenters encouraged DOE to investigate which hot water supply temperature would be most representative.

Id.

UL supports specifying the hot water supply temperature to be consistent with hot water heater outlet temperatures, as supported by field data. (UL, No. 9 at p. 1)

Samsung recommended that DOE specify a hot water supply temperature of 120 ± 2 °F, consistent with the temperature specified in the consumer dishwasher test procedure. Samsung also commented that the U.S. Consumer Product Safety Commission recommends this temperature to consumers as the safest set point for water heaters to avoid scalds. (Samsung, No. 6 at p. 3)

NEEA encouraged DOE to investigate the hot water supply temperature that would be most representative of field use. NEEA added that water heater set points may increase closer to the Appendix J2-specified 135 °F in the future, due to concerns about

Legionella

bacteria growth. (NEEA, No. 12 at p. 26) NEEA also recommended that DOE consider heat losses in the pipes and static water in the supply line in the field, which are likely to lower clothes washer inlet hot temperatures relative to water heater set points.

Id.

Based on the analysis of recent water temperature data summarized in Table III.1, DOE is proposing to update the hot water supply temperature in the proposed new Appendix J from 130-135 °F to 120-125 °F. DOE preliminarily concludes that an inlet temperature of 120-125 °F is more representative of consumer hot water temperatures than the range of 130-135 °F currently specified in Appendix J2.

In addition, section 4.1.2 of Appendix J2 calculates the hot water energy consumption for each tested load size, by multiplying the hot water consumption for each tested load size, by “T,” the temperature rise, and by “K,” the specific heat of water. In Appendix J2, T is defined as 75 °F, which represents the nominal difference between the hot and cold water inlet temperatures. In this NOPR, DOE is proposing to use a value for T of 65 °F in the proposed new Appendix J, consistent with the differential between the nominal values for the proposed hot

water supply temperature (120-125 °F) and the cold water supply temperature (55-60 °F).

DOE agrees with AHAM and GEA that changing the hot water supply temperature would likely impact measured efficiency because hot water energy consumption is a significant component in the calculation of the IMEF metric. As a result, DOE is proposing to update the hot water supply temperature only in the proposed new Appendix J and not in existing Appendix J2. Therefore, DOE's proposal would not affect the measured efficiency of clothes washers currently tested using Appendix J2. The ongoing RCW and CCW energy conservation standards rulemakings would consider the impact of this proposed modification to the hot water supply temperature on measured efficiency.

DOE requests comment on its proposal to update the hot water supply temperature for the proposed new Appendix J from 130-135 °F to 120-125 °F. DOE seeks more recent data on hot water supply temperatures in consumer clothes washer installations. DOE also requests comment on any potential impact to testing costs that may occur by harmonizing temperatures between the clothes washer and dishwasher test procedures, and the impacts on manufacturer burden associated with any changes to the hot water supply temperature.

In the NOPR preceding the July 2014 Water Heater Final Rule, DOE cited a comment from Applied Energy Technology,

which stated that water temperatures in the range of 120 °F are adequate to prevent

Legionella

growth as long as the water is maintained at a temperature “high enough, long enough, and often enough.” 78 FR 66202, 66219 (Nov. 4, 2013). In that NOPR, DOE also cited the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (“ASHRAE”) guideline

which states that hot water should be stored above 140 °F only for high-risk applications (such as health-care facilities and nursing homes). 78 FR 66202, 66218 (Nov. 4, 2013). Moreover, the specification of hot water supply temperature in the clothes washer test procedure is intended to be representative of consumer clothes washer installations, as supported by the data described previously. The target temperature defined in the clothes washer test procedure does not and would not introduce any regulatory requirement on water heater manufacturers, installers, or consumers regarding the set point temperature that can be chosen for any individual water heater installation.

See comment number 22 in Docket number EERE-2011-BT-TP-0042. Available at

www.regulations.gov/docket/EERE-2011-BT-TP-0042.

ASHRAE Guideline 12, “Minimizing the Risk of Legionellosis Associated with Building Water Systems,” states that the temperature range most favorable for amplification of legionellae bacteria is 77−108 °F (25−42 °C) and recommends that when practical, hot water should be stored at temperatures of 120 °F (49 °C) or above. The guideline states that hot water should be stored above 140 °F (60 °C) for high-risk settings such as in health care facilities and nursing homes. For more information visit:

www.ashrae.org.

b. Extra-Hot Wash Determination

Clothes washers are tested using an energy test cycle that is comprised of certain cycles taking into consideration all cycle settings available to the end user. Section 2.12 of Appendix J2. Figure 2.12.5 of Appendix J2 specifies that for the energy test cycle to include an Extra-Hot Wash/Cold Rinse, the clothes washer must have an internal heater and the Normal cycle

must, in part, contain a wash/rinse temperature selection that has a wash temperature greater than 135 °F. The 135 °F threshold matches the current hot water inlet target temperature, as specified in section 2.2 of Appendix J2.

Section 1.25 of Appendix J2 defines the Normal cycle as the cycle recommended by the manufacturer (considering manufacturer instructions, control panel labeling, and other markings on the clothes washer) for normal, regular, or typical use for washing up to a full load of normally-soiled cotton clothing. For machines where multiple cycle settings are recommended by the manufacturer for normal, regular, or typical use for washing up to a full load of normally-soiled cotton clothing, then the Normal cycle is the cycle selection that results in the lowest IMEF or MEF value.

DOE has revised the Extra-Hot wash temperature parameters previously. In the August 1997 Final Rule, DOE changed the minimum hot water supply temperature from 140 °F in Appendix J-1977 to 135 °F in Appendix J1-1997, and also revised the threshold temperature for Extra-Hot Wash from 140 °F to 135 °F accordingly. 62 FR 45484, 45497. As noted, Appendix J2 retains this threshold temperature of 135 °F for Extra-Hot Wash.

As described previously, DOE is proposing to update the hot water inlet temperature from 135 °F to 125 °F (see section III.C.3.a of this document). This proposed change to the hot water inlet temperature prompted DOE to reassess the threshold temperature for the Extra-Hot wash temperature. Because the inclusion of an Extra-Hot Wash/Cold Rinse in the energy test cycle requires the clothes washer to have an internal heater, the threshold temperature is not limited to the input temperature.

DOE testing of a broad range of clothes washers

indicates that over 70 percent of Extra-Hot cycles have a wash water temperature that exceeds 140 °F, despite the threshold temperature for Extra-Hot Wash changing to 135 °F in the August 1997 Final Rule. Furthermore, DOE research indicates that 140 °F is widely cited as a threshold for achieving sanitization by organizations including the World Health Organization and the United Kingdom's National Health Service.

Based on DOE's data indicating that a majority of existing Extra-Hot cycles have wash water temperatures that exceed 140 °F, and based on the cited reports finding that washing textiles at 140 °F is an accepted sanitation threshold, DOE proposes specifying the Extra-Hot Wash threshold as 140 °F. Based on the research described above, DOE preliminarily concludes that a temperature threshold of 140 °F would align with 140 °F as an accepted temperature threshold for sanitization, and therefore may be more representative of consumer expectations and usage of the Extra-Hot Wash cycle, than the current 135 °F threshold.

DOE analyzed test data from 2 top-loading and 15 front-loading models representing 7 different manufacturers and 9 different brands.

World Health Organization. “Boil Water.” Available at:

www.who.int/water_sanitation_health/dwq/Boiling_water_01_15.pdf.

National Health Service. “Can clothes and towels spread germs?” Available at:

www.nhs.uk/common-health-questions/infections/can-clothes-and-towels-spread-germs/.

In addition to improving representativeness, changing the Extra-Hot Wash temperature threshold to 140 °F could potentially reduce test burden. As discussed more fully in section III.C.4 of this document, a threshold of 140 °F would enable easier confirmation that an Extra-Hot temperature has been achieved when measuring wash temperature with non-reversible temperature indicator labels, as permitted by section 3.3 of Appendix J2. Temperature indicator labels are widely available with a 140 °F indicator, whereas DOE is not aware of any commercially available temperature indicator labels that provide a 135 °F indicator.

In summary, DOE is proposing to specify in the proposed new Appendix J that the minimum temperature threshold for the Extra-Hot Wash/Cold Rinse is 140 °F. This change would be reflected in the proposed Extra Hot Wash/Cold Rinse flowchart in section 2.12 of the proposed new Appendix J as well as any references to this temperature threshold elsewhere

throughout the proposed new Appendix J.

DOE recognizes that for the 30 percent of units with Extra-Hot Wash temperatures that do not exceed 140 °F, DOE's proposal to change the Extra-Hot Wash definition may impact measured efficiency. Therefore, in this NOPR, DOE is proposing to include the amended Extra-Hot Wash temperature parameter only in the proposed new Appendix J and not in existing Appendix J2. The ongoing RCW and CCW energy conservation standards rulemakings would consider the impact of any modifications to the Extra-Hot Wash definition on measured efficiency.

DOE requests comment on its proposal to specify in the proposed new Appendix J that the Extra-Hot Wash/Cold Rinse designation would apply to a wash temperature greater than or equal to 140 °F. DOE requests any additional data on the wash temperature of cycles that meet the Appendix J2 definition of Extra-Hot Wash/Cold Rinse. DOE is also interested in data and information on any potential impact to testing costs that may occur by changing the Extra-Hot Wash temperature threshold, and the impacts on manufacturer burden associated with any changes to the Extra-Hot Wash/Cold Rinse definition.

c. Target Water Supply Temperature

Section 2.2 of Appendix J2 specifies that the hot water supply temperature must be maintained between 130 °F (54.4 °C) and 135 °F (57.2 °C), using 135 °F as the target temperature. Based on experience working with third-party test laboratories, as well as its own testing experience, DOE recognizes that maintaining 135 °F as the target temperature for the hot water supply may be difficult given that the target temperature of 135 °F lies at the edge, rather than the midpoint, of the allowable temperature range of 130 °F to 135 °F. 85 FR 31065, 31069. On electronic temperature-mixing valves commonly used by test laboratories, the output water temperature is maintained within an approximately two-degree tolerance above or below a target temperature programmed by the user (

e.g.,

if the target temperature is set at 135 °F, the controller may provide water temperatures ranging from 133 °F to 137 °F).

Id.

To ensure that the hot water inlet temperature remains within the allowable range of 130 °F to 135 °F, such a temperature controller would need to be set to around the midpoint of the range, which conflicts with the test procedure requirement to use 135 °F as the target temperature.

Id.

An analogous difficulty exists for the cold water supply temperature. Section 2.2 of Appendix J2 specifies maintaining a cold water temperature between 55 °F and 60 °F, using 60 °F as the target.

In the May 2020 NOPR, DOE requested comments on whether it should consider changes to the target temperature or allowable range of temperature specified for the hot and cold water inlets, and if so, what alternate specifications should be considered.

Id.

UL commented that it supports the change to an equal sided tolerance for the hot and cold water inlet temperature requirements. (UL, No. 9 at p. 1)

AHAM also supported DOE updating the target water temperature to have a tolerance and nominal value (rather than any temperature within the range) specified as the target,

i.e.,

X ± Y, with nominal (X) as the target. (AHAM, No. 5 at p. 6)

The CA IOUs supported a change in the water supply temperature tolerance to ± 2.5 °F around the target temperature, claiming that it may create a more repeatable test procedure and decrease the number of failed test runs. (CA IOUs, No. 8 at p. 15)

GEA supported a hot water target temperature adjustment to 132.5 ± 2.5 °F, stating that doing so would align the test procedure with engineering best practices. (GEA, No. 13 at p. 2)

DOE recognizes the widespread support for defining a temperature range centered around a target midpoint of the range. Although this would appear to reflect current test laboratory practice, DOE is concerned that specifying a cold water target temperature of 57.5 °F in Appendix J2 and the proposed new Appendix J, or specifying a hot water target temperature of 132.5 °F for Appendix J2 or 122.5 °F for the proposed new Appendix J, could imply that the test procedure requires a precision of 0.5 °F in temperature control, which could create undue test burden. Furthermore, DOE is concerned that defining a “target” temperature, whether as currently defined or defined as the midpoint of the range, could unintentionally imply that a test would be invalid if the water temperature remains within the allowable range, but not centered exactly around the target.

For these reasons, DOE is proposing to remove the “target” temperature associated with each water supply temperature range, and to instead define only the allowable temperature range. Specifically, the cold water supply temperature range would be defined as 55 °F to 60 °F in both Appendix J2 and the proposed new Appendix J; the hot water supply temperature range in Appendix J2 would be defined as 130 °F to 135 °F; and the hot water supply temperature range in the proposed new Appendix J would be defined as 120 °F to 125 °F. Defining allowable water supply temperature ranges instead of specific target temperatures at the upper end of the allowable ranges would reduce the difficulty of maintaining water supply temperatures within the desired ranges.

DOE requests comment on its proposal to remove the target temperatures and instead specify water supply temperature ranges as 55 °F to 60 °F for cold water in both Appendix J2 and the proposed new Appendix J, 130 °F to 135 °F for hot water in Appendix J2, and 120 °F to 125 °F for hot water in the proposed new Appendix J.

4. Wash Water Temperature Measurement

In the August 2015 Final Rule, DOE amended section 3.3 of Appendix J2, “Extra-Hot Wash/Cold Rinse,” to allow the use of non-reversible temperature indicator labels to confirm that a wash temperature greater than 135 °F had been achieved. 80 FR 46729, 46753. Since the publication of the August 2015 Final Rule, DOE has become aware that some third-party laboratories measure wash temperature using self-contained temperature sensors in a waterproof capsule placed inside the clothes washer drum during testing. 85 FR 31065, 31069. In the May 2020 RFI, DOE requested comments on manufacturers' or test laboratories' experience with these or any other methods for determining the temperature during a wash cycle that may reduce manufacturer burden, including the reliability and accuracy of those methods.

Id.

UL commented that it has not found any temperature labels that read exactly 135 °F, but rather only labels that provide 10 °F increments between 130 °F and 140 °F. (UL, No 9 at p. 2) UL added that if a label does not change at 140 °F but does change at 130 °F, there is no way of knowing if the water temperature reached 135 °F without running an additional test run with a data logger.

Id.

UL also commented that if DOE requires temperature loggers for measuring the internal water temperature, DOE should prescribe a specific method, for increased lab-to-lab reproducibility.

Id.

AHAM similarly commented that the non-reversible temperature indicator labels currently specified in the test procedure do not work well because the labels available on the market do not easily identify when 135 °F is reached, as they typically provide 10 °F

increments, and none are available in increments of 125 °F to 135 °F. (AHAM, No. 5 at pp. 6-7) According to AHAM, testers must estimate when 135 °F is reached on labels that are currently available. Thus, AHAM suggests that DOE consider permitting the use of submersible temperature loggers.

Id.

As discussed by UL and AHAM, DOE is aware that none of the temperature indicator labels available on the market provide an indicator at 135 °F, the current Extra-Hot Wash water temperature threshold. Because of this, temperature indicator labels can be used to confirm that the water temperature reached 135 °F only if the water temperature exceeds 140 °F. The temperature indicator labels are unable to identify an Extra-Hot Wash/Cold Rinse cycle if the temperature of the cycle is greater than 135 °F but less than 140 °F. DOE recognizes the potential benefit of other methods of measurement to supplement or replace the temperature indicator labels.

DOE investigated submersible temperature loggers as suggested by AHAM. DOE found submersible temperature loggers available for less than $175 and available with a resolution of 0.5 °C (0.9 °F) or better and an accuracy of ±0.5 °C (0.9 °F) for water temperatures between -10 °C (14 °F) and +65 °C (149 °F).

In testing with such temperature loggers, DOE found them small enough in size to be able to embed within the test load during testing. However, DOE testing indicated a 5 to 10-minute time lag in measuring dynamically changing temperatures, which is likely due to the thermal mass of the waterproof capsule. As a result of this time lag, if a clothes washer's wash water temperature were to reach 135 °F only briefly, then a submersible temperature logger may not record that 135 °F had been reached. DOE concludes that, similar to temperature indicator labels, a submersible temperature logger indicating a temperature higher than 135 °F can provide confirmation that the water temperature reached 135 °F, but failure to record a temperature of 135 °F does not necessarily determine that the temperature threshold for the Extra-Hot Wash cycle has not been achieved. For clothes washers with sustained water temperatures greater than 135 °F but less than 140 °F, submersible temperature loggers may provide potentially reduced test burden, compared to using temperature indicator labels.

See

e.g., www.maximintegrated.com/en/products/ibutton-one-wire/data-loggers/DS1923.html/product-details/tabs-3, www.maximintegrated.com/en/products/ibutton-one-wire/ibutton/DS9107.html,

and

www.maximintegrated.com/en/products/interface/universal-serial-bus/DS9490.html.

For Appendix J2, DOE is proposing to allow the use of a submersible temperature logger as an additional temperature measurement option to confirm that an Extra-Hot Wash temperature greater than 135 °F has been achieved during the wash cycle. DOE is proposing that the submersible temperature logger must have a time resolution of at least 1 data point every 5 seconds and a temperature measurement accuracy of ±1 °F. As described currently for temperature indicator labels, DOE would include a note that failure to measure a temperature of 135 °F would not necessarily indicate of the lack of an Extra-Hot Wash temperature. However, such a result would not be conclusive due to the lack of verification of that the required water temperature was achieved, in which case an alternative method must be used to confirm that an extra-hot wash temperature greater than 135 °F has been achieved during the wash cycle.

Because DOE is proposing to change the Extra-Hot Wash water temperature threshold to 140 °F for the proposed new Appendix J, commercially available temperature indicator labels with indications at 140 °F would be able to be used more readily to determine whether the water temperature reached the Extra-Hot Wash temperature threshold. DOE is also proposing to allow the usage of a submersible temperature logger in the proposed new Appendix J as an option to confirm that an Extra-Hot Wash temperature greater than 140 °F has been achieved during the wash cycle. Like the temperature threshold of 135 °F in Appendix J2, failure to measure a temperature of 140 °F would not necessarily indicate the lack of an Extra-Hot Wash temperature. However, such a result would not be conclusive due to the lack of verification of that the required water temperature was achieved, in which case an alternative method must be used to confirm that an extra-hot wash temperature greater than 140 °F has been achieved during the wash cycle.

Lastly, DOE is proposing to move the description of allowable temperature measuring devices from section 3.3 of Appendix J2 to section 2.5.4 of both Appendix J2 and the proposed new Appendix J (“Water and air temperature measuring devices”), specifying the use of non-reversible temperature indicator labels in new section 2.5.4.1, and adding specifications for the use of submersible temperature loggers to new section 2.5.4.2 of both Appendix J2 and the proposed new Appendix J.

DOE requests comment on its proposal to allow the use of a submersible temperature logger in Appendix J2 and the proposed new Appendix J as an option to confirm that an Extra-Hot Wash temperature greater than the Extra-Hot Wash threshold has been achieved during the wash cycle. DOE requests data and information confirming (or disputing) DOE's discussion of the benefits and limitations of using a submersible temperature logger, including DOE's determination that a submersible logger's failure to measure a temperature greater than the Extra-Hot Wash threshold does not necessarily indicate that the cycle under test does not meet the definition of an Extra-Hot Wash/Cold Rinse cycle.

5. Pre-Conditioning Requirements

Section 2.11 of Appendix J2 specifies the procedure for clothes washer pre-conditioning. The current pre-conditioning procedure requires that any clothes washer that has not been filled with water in the preceding 96 hours, or any water-heating clothes washer that has not been in the test room at the specified ambient conditions for 8 hours, must be pre-conditioned by running it through a Cold Rinse cycle and then draining it to ensure that the hose, pump, and sump are filled with water. The purpose of pre-conditioning is to promote repeatability and reproducibility of test results by ensuring a consistent starting state for each test, as well as to promote the representativeness of test results by ensuring that the clothes washer is operated consistent with the defined ambient conditions. In particular, the additional specification for water-heating clothes washers was first suggested in a supplemental NOPR published on April 22, 1996, (“April 1996 SNOPR”), in which DOE expressed concern about the testing of water-heating clothes washers that may have been stored at a temperature outside of the specified ambient temperature range (75 °F ± 5 °F) prior to testing. 61 FR 17589, 17594-17595. DOE stated that the energy consumed in a water-heating clothes washer may be affected by the ambient temperature.

Id.

Thus, if the ambient temperature prior to and during testing is relatively hot, then less energy will be consumed than under typical operating conditions,

i.e.,

the test will understate the clothes washer's energy consumption.

Id.

Conversely, if the ambient temperature prior to and during the test is relatively cold, then the energy consumption will be overstated.

Id.

In the subsequent August 1997 Final Rule, DOE added the

pre-conditioning requirement for water-heating clothes washers, which requires water-heating units to be pre-conditioned if they had not been in the test room at ambient conditions for 8 hours. 62 FR 45484, 45002, 45009, 45010.

DOE is concerned that the energy use of non-water-heating clothes washers could also be affected by the starting temperature of the clothes washer, particularly those that implement temperature control by measuring internal water temperatures during the wash cycle. For example, if the ambient temperature prior to testing is relatively hot, causing the internal components of the clothes washer to be at a higher temperature than the specified ambient temperature range, less hot water may be consumed during the test than otherwise would be if the starting temperature of the clothes washer is within the specified ambient temperature range. Noting that third-party test laboratories cannot necessarily identify whether a unit is a water-heating clothes washer or not, DOE is proposing to require the same pre-conditioning procedure for both water-heating and non-water-heating clothes washers, which would minimize the influence of ambient temperature on energy use and alleviate the need for third-party test laboratories to determine whether a clothes washer is water-heating or not. If adopted, this proposed change may impact the measured energy use of non-water-heating clothes washers that implement temperature control by measuring internal water temperatures during the wash cycle. Due to the potential impact on the measured energy use, DOE is proposing this change only for the proposed new Appendix J, which would be used for the evaluation and issuance of updated efficiency standards, and to determine compliance with those standards. DOE is therefore proposing that use of the proposed new Appendix J, if finalized, would not be required until the compliance date of any updated standards.

In addition, the proposed amendments to the pre-conditioning requirements would eliminate the differentiation between “water-heating clothes washer” and “non-water heating clothes washer,” which are defined terms in the test procedure. Therefore, DOE is also proposing to remove the definitions of “water-heating clothes washer” and “non-water-heating clothes washer” from section 1 of the proposed new Appendix J.

DOE requests comment on its proposal to specify the same pre-conditioning requirements for all clothes washers and to remove the “water-heating clothes washer” and “non-water-heating clothes washer” definitions in the proposed new Appendix J. DOE also requests information regarding whether test laboratories typically pre-condition water-heating and non-water-heating clothes washers using the same procedure.

D. Cycle Selection and Test Conduct

1. Tested Load Sizes

Table 5.1 of Appendix J2 provides the minimum, average, and maximum load sizes to be used for testing based on the measured capacity of the clothes washer. The table defines capacity “bins” in 0.1 ft

increments. The load sizes for each capacity bin are determined as follows:

□ Minimum load is 3 pounds (“lb”) for all capacity bins;

□ Maximum load (in lb) is equal to 4.1 times the mean clothes washer capacity of each capacity bin (in ft3); and

□ Average load is the arithmetic mean of the minimum load and maximum load.

These three load sizes are used for testing clothes washers with automatic WFCS. Clothes washers with manual WFCS are tested with only the minimum and maximum load sizes.

a. Expanding the Load Size Table

DOE originally introduced the load size table in Appendix J1-1997, which accommodated clothes container capacities up to 3.8 ft

. 62 FR 45484, 45513. In the March 2012 Final Rule, DOE expanded Table 5.1 in both Appendix J1 and Appendix J2 to accommodate clothes container capacities up to 6.0 ft

. 77 FR 13887, 13910. DOE extrapolated the load sizes to 6.0 ft

using the same equations to define the maximum and average load sizes as described above.

On May 2, 2016 and April 10, 2017, DOE granted waivers to Whirlpool and Samsung, respectively, for testing RCWs

with capacities between 6.0 and 8.0 ft

, by further extrapolating Table 5.1 using the same equations to define the maximum and average load sizes as described. 81 FR 26215; 82 FR 17229. DOE's regulations in 10 CFR 430.27 contain provisions allowing any interested person to seek a waiver from the test procedure requirements if certain conditions are met. A waiver allows manufacturers to use an alternate test procedure in situations where the DOE test procedure cannot be used to test the product or equipment, or where use of the DOE test procedure would generate unrepresentative results. 10 CFR 430.27(a)(1) DOE's regulations at 10 CFR 430.27(l) require that as soon as practicable after the granting of any waiver, DOE will publish in the

Federal Register

a NOPR to amend its regulations so as to eliminate any need for the continuation of such waiver. As soon thereafter as practicable, DOE will publish in the

Federal Register

a final rule. 10 CFR 430.27(l).

As noted, CCWs are limited under the statutory definition to a maximum capacity of 3.5 cubic feet for horizontal-axis CCWs and 4.0 cubic feet for vertical-axis CCWs. (42 U.S.C. 6311(21))

In the May 2020 RFI, DOE requested comment on whether to extrapolate Table 5.1 of Appendix J2 to accommodate RCW capacities up to 8.0 ft

, and if so, appropriate methods for extrapolation. 85 FR 31065, 31077. DOE received comments from multiple interested parties regarding the definition of load sizes more generally, which DOE addresses in section III.D.1.b of this document. DOE received no comments regarding the expansion of the load size table itself.

In this NOPR, DOE is proposing to expand Table 5.1 in both Appendix J2 and the proposed new Appendix J to accommodate clothes washers with capacities up to 8.0 ft

. In Appendix J2, DOE proposes to expand Table 5.1 using the same equations as the current table, as described above, and consistent with the load size tables provided in the two granted waivers. For the proposed new Appendix J, DOE proposes a revised methodology for defining the load sizes in each capacity bin in Table 5.1, as further discussed in section III.D.1.b of this document.

DOE requests comment on its proposal to expand the load size table in both Appendix J2 and the proposed new Appendix J to accommodate RCWs with capacities up to 8.0 ft

b. Defining New Load Sizes

As discussed in the previous section, Appendix J2 currently defines three load sizes for automatic clothes washers (minimum, average, and maximum) for each capacity bin in Table 5.1 of the appendix. In this NOPR, DOE is proposing for the proposed new Appendix J to define two load sizes for automatic clothes washers (small and large) for each capacity bin, which are intended to represent the same load size distribution underlying the existing three load sizes. DOE has tentatively concluded that this would substantially reduce test burden while maintaining or improving representativeness. The following paragraphs describe the development of the current load size definitions to provide context and

justification for DOE's proposed changes.

The current load size definitions (

i.e.,

the defining of three load sizes, and the equations used to determine each of the three load sizes) are based on consumer usage data analyzed during the test procedure rulemaking that culminated in the August 1997 Final Rule. As part of that rulemaking, AHAM presented to DOE data from the Procter & Gamble Company (“P&G”) showing the distribution of consumer load sizes for 2.4 ft

and 2.8 ft

clothes washers, which represented typical clothes washer capacities at the time (1995).

The 1995 P&G data indicated that the distribution of consumer load sizes followed an approximate normal distribution slightly skewed towards the lower end of the size range. Figure III.1 shows the summarized data presented by AHAM.

The full data set presented by AHAM is available at

www.regulations.gov/document/EERE-2006-TP-0065-0027.

BILLING CODE 6450-01-P

EP01SE21.001

In the August 1997 Final Rule, DOE defined three load sizes—minimum, average, and maximum—to represent this normal distribution. 62 FR 45484, 45490. The minimum load size represented approximately the 14th percentile of the distribution (

i.e.,

the lower 14 percent of the cumulative distribution); the average load size represented approximately the 14th through 88th percentile (

i.e.,

the middle 74 percent of the cumulative distribution); and the maximum load size represented approximately the 88th through 100th percentile (

i.e.,

the upper 12 percent of the cumulative distribution).

Figure III.2 illustrates the boundaries representing the three defined load sizes overlaid with the P&G load distribution data.

See the table titled “Relationship of Water Fill Factors to Cumulative Load Size Distribution” on page 22 of the data presented by AHAM as part of the rulemaking that culminated in the August 1997 Final Rule, available at

www.regulations.gov/document/EERE-2006-TP-0065-0027.

EP01SE21.002

BILLING CODE 6450-01-C

In the August 1997 Final Rule, these load size relationships were scaled across the range of 0.8 ft

to 3.8 ft

capacities

using the equations described above: Minimum load size fixed at 3 lb for all capacity bins; maximum load size calculated as 4.1 times the mean clothes washer capacity of each capacity bin; and average load size calculated as the mean of the minimum and maximum load sizes. 62 FR 45484, 45504, 45513. Within each capacity bin, the three defined load sizes were intended to approximate a normal distribution of consumer load sizes. As noted, the load size table in Appendix J1-1997 was extrapolated to 6.0 ft

in the March 2012 Final Rule, applicable to both Appendix J1 and Appendix J2.

For capacities in the range of 0.0 to 0.8 ft

, a fixed load size of 3 lb was defined for all three test load sizes.

In the May 2020 RFI, DOE requested data and information on whether the minimum, average, and maximum load size definitions in Table 5.1 are representative of the range of load sizes used by consumers for each capacity bin in the table, particularly for larger-capacity RCWs. 85 FR 31065, 31078.

UL commented that in order to make load sizes more equitable for the widening range of clothes washer capacities, all three load sizes should be proportional to capacity, similar to the current definition of maximum load. UL suggested that minimum and average load sizes could be proportional to the maximum load size (

e.g.,

minimum and average load sizes could be 25 percent and 50 percent of maximum load size, respectively). (UL, No. 9 at p. 4)

Fixing the minimum load size at 3 lb represents the need for consumers to wash a small load of laundry (for example, a single outfit of clothing) regardless of the capacity of the clothes washer. The “average” load size as constructed in Appendix J2 represents the middle of the range of load sizes

washed by consumers (

i.e.,

the approximate peak of the roughly normal distribution of load sizes). As described below, DOE is proposing in the proposed new Appendix J to define two, rather than three, load sizes, and each of the two load sizes would be defined as a function of capacity.

In effect, the “average” load size is intended to represent the median load size washed by consumers.

The CA IOUs recommended that DOE amend the average and maximum load sizes in Table 5.1 of Appendix J2 to use

a logarithmic relationship between capacity and load size. (CA IOUs, No. 8 at pp. 1-4) The CA IOUs presented data from a 2016 Pacific Gas and Electric Company (“PG&E”) field survey (“2016 PG&E survey”) that recorded load size and capacity data, and showed a logarithmic relationship between load size and capacity for clothes washers with capacities from 2-5 ft

. In the range of 2 ft

to approximately 5 ft

capacity, the 2016 PG&E survey showed slightly higher average consumer load sizes than would be defined by Table 5.1 in Appendix J2 for a clothes washer of the same capacity. The CA IOUs commented that extrapolating this relationship to smaller and larger-capacity clothes washers, however, would result in a smaller consumer load sizes than would be defined by Table 5.1 of the current Appendix J2.

Id.

The CA IOUs also commented that a similar logarithmic trend was found in an Australian clothes dryer study.

Although the Australian study relates to residential clothes dryers, the CA IOUs asserted that the operation of clothes washers and clothes dryers are closely linked.

Id.

The CA IOUs commented that the 2016 PG&E survey excludes households outside of the “hot-dry” Southwestern region of the United States, as well as households that rely on CCWs to wash their clothes, and requested that DOE conduct a larger national survey or study existing surveys to explore the relationship between capacity and average load size before making any changes to Table 5.1 of Appendix J2 to ensure that the test procedure produces results that most represent an average use cycle.

Id.

Lloyd Harrington of Energy Efficient Strategies, Australia. Supporting data and corresponding presentations:

eedal2017.uci.edu/wp-content/uploads/Thursday-17-Harrington.pdf.

DOE appreciates the CA IOUs providing consumer usage data from the 2016 PG&E field survey. While the conclusions from this data may be instructive as a point of comparison, these data are limited in that they represent usage in a single season (summer), in a single state (California), and only around three wash cycles per participating household.

Notwithstanding these limitations, the results indicate that within the range of 2 to approximately 5 ft

, which encompasses the large majority of units on the market, the load sizes defined by Appendix J2 are reasonably close to the load sizes observed in the 2016 PG&E field study. Regarding the Australian clothes dryer study, while these data provide a point of comparison, usage patterns of Australian consumers do not necessarily represent the usage patterns of U.S. consumers. DOE is not aware of, and the CA IOUs have not provided, any data or information that would suggest that Australian usage patterns are the same as U.S. usage patterns. Further, clothes dryer load sizes may differ from clothes washer loads for reasons which may depend on region or localized customs (for example, line drying clothing may be more common in hot, dry climates). DOE is not aware of, nor have the CA IOUs provided, any data to suggest how Australian dryer load sizes relate to Australian clothes washer load sizes. DOE also observes that a logarithmic trend may not represent the best characterization of the Australian data.

According to CA IOUs, the data represent 310 wash cycles across 105 California households. (CA IOUs, No. 8 at p. 7)

NEEA recommended that, if DOE were to adopt an efficiency metric that is a function of capacity, DOE should eliminate the current average load calculation method and replace it with a fixed 7.6 lb load, which it believes would be more representative. NEEA cited its 2014 laundry field study that found an average clothes washer load size of 7.6 lb, which NEEA characterized as being close to the average load size of 8.5 lb that corresponds with the 2010 market-weighted average capacity of 3.5 ft

. NEEA stated, however, that the market-weighted average capacity as of 2019 has increased to 4.4 ft

, for which Appendix J2 defines an average load size of 10.4 lb.

(NEEA, No. 12 at pp. 22-24) NEEA compared this 10.4 lb average load size to three Australian field studies that found an average load size of approximately 6.6 lb. NEEA further referenced another Australian research study conducted by Choice

in which consumers were instructed to fully fill the clothes container. The resulting average load size measured during the study was 8 lb, which NEEA described as significantly less than an amount that the clothes container could hold.

Id.

NEEA asserted that using a fixed average load size of 7.6 lb would increase representativeness, stating that the growing inconsistency between field-measured average load size and Appendix J2-calculated average load size indicates that average load size is independent of clothes washer capacity and is relatively small.

Id.

NEEA also stated that using a fixed average load size would reduce test burden, since less work would be required by the laboratory to build an inventory of custom Appendix J2-defined average loads for each clothes washer capacity. NEEA recommended that if DOE were to determine a field average load size for the United States, DOE could conduct a study similar to the referenced Choice study but with a representative group of consumers in the United States.

Id.

NEEA's estimate of 4.4 ft

average capacity in 2019 is based on NEEA's 2019 ENERGY STAR Retail Products Platform data.

“Washing machine user habits: A report on wash temperature and load size habits among CHOICE Members.” 2011. Prepared for the Australian Department of Climate Change and Energy. Not publicly published, but can be made available upon request to Simon Newman, Residential Energy Efficiency Branch, Energy Security and Efficiency Division, Department of Industry, Science, Energy and Resources, PO Box 2013, Canberra, ACT 2601. 39 Personal Communication. Lloyd Harington, Energy Efficient Strategies. 17 June 2020.

DOE appreciates NEEA providing the consumer usage data from the 2014 laundry study. DOE does not agree with NEEA's conclusion that the 2014 laundry study confirms that the field average load size is independent of clothes container size and is relatively small. In support of its assertion, NEEA presented data indicating that current (2019) average capacity has increased to 4.4 ft

, for which Appendix J2 defines an average load size of 10.4 lb. However, NEEA did not present any field data demonstrating average consumer load sizes for a sample of clothes washers with an average capacity of 4.4 ft

. Therefore, no conclusions can be drawn from the 2014 laundry study regarding how consumer load sizes may have changed as average clothes washer capacity has increased from around 3.5 ft

in 2010 to 4.4 ft

in 2019. Regarding NEEA's summary of the three Australian field studies, DOE reiterates that the usage patterns of Australian consumers do not necessarily represent the usage patterns of U.S. consumers. DOE notes that the summaries of the Electrolux and Fisher & Paykel surveys provided by NEEA do not identify the average capacity of the clothes washers in the survey samples. Therefore, no conclusions can be drawn regarding how the average consumer load size of 6.6 lb from the surveys compares to the load size that Appendix J2 would prescribe for a U.S. clothes washer of the same size. While DOE agrees that using a fixed average load size could decrease test burden by avoiding the need to inventory different average load sizes for each possible capacity, for the reasons described above, DOE preliminarily concludes that the data provided by NEEA do not justify using a fixed average load size across all clothes container capacities.

The Joint Commenters also encouraged DOE to consider specifying an average load size that is a constant value independent of capacity. (Joint

Commenters, No. 10 at pp. 4-5) According to the Joint Commenters, the introduction of large-capacity clothes washers to the market, combined with the structure of Table 5.1 in Appendix J2, has led to the weighted-average load size for the largest clothes washers being significantly greater than that for small clothes washers. For example, the Joint Commenters stated that the weighted-average load size for a 6.0 ft

clothes washer (13.68 lb) is around 60 percent larger than the weighted-average load size for a 3.5 ft

clothes washer (8.68 lb).

Id.

The Joint Commenters also referenced NEEA's laundry field study, which the Joint Commenters characterized as finding no clear correlation between clothes washer capacity and load size. The Joint Commenters expressed concern that the current test procedure may not be representative of an average cycle use for large-capacity clothes washers.

Id.

As noted previously, DOE preliminary concludes that the data provided by NEEA, as referenced by the Joint Commenters, do not demonstrate that using a fixed average load size would be representative of U.S. consumer usage. DOE also notes that the assertion made by NEEA and the Joint Commenters—that consumer average load sizes are

smaller

than DOE's Appendix J2 load sizes—conflicts with the data summarized above from the CA IOUs, which suggest consumer average load sizes for clothes washers in the range of 2 to 5 ft

capacity that are

larger

than the Appendix J2 load sizes. These conflicting conclusions, combined with the noted limitations of each data set, do not provide justification for DOE to change the average load sizes in Table 5.1 of Appendix J2.

As noted, DOE is proposing to replace the minimum, maximum, and average load sizes with two new load sizes in the proposed new Appendix J, designated as “small” and “large.” In the paragraphs that follow, DOE explains its rationale for (1) reducing the number of load sizes from three to two, and (2) defining the two load sizes for each capacity bin.

As discussed in section III.A of this document, AHAM and GEA commented on the current test burden associated with conducting the Appendix J2 test procedure. While DOE acknowledges the theoretical possibility of Appendix J2 requiring up to 70 test cycles, DOE is not aware of any products currently or historically on the market that would require this maximum number of test cycles. In DOE's experience, in practice the number of test cycles is around 6 cycles for clothes washers with very few and basic features; around 15-20 cycles for the most typical configurations on the market; and around 35 cycles for the most feature-rich models that would trigger the greatest number of required test cycles in Appendix J2. Nevertheless, DOE seeks to find opportunities for reducing the test burden associated with its test procedures, while maintaining representative, repeatable, and reproducible test results.

One of the key contributors to the total number of required cycles is the requirement to test three load sizes for each wash/rinse temperature selection required for testing on clothes washers with automatic WFCS (which represent the majority of the market). As described previously, the three load sizes were devised to approximate a normal distribution of consumer load sizes. At the time of the August 1997 Final Rule, clothes washer control panels were not as feature-rich as current models available on the market, and DOE had not contemplated that future clothes washer models could require testing up to 35 cycles.

Given the increasing prevalence of more feature-rich clothes washer models that require a higher number of test cycles under Appendix J2, DOE is proposing to reduce test burden by reducing the number of defined load sizes for the proposed new Appendix J from three to two for clothes washers with automatic WFCS. The following paragraphs discuss how DOE proposes to define the two load sizes for each capacity bin.

The new proposed small and large load sizes would continue to represent the same roughly normal distribution presented in the 1995 P&G data described above. The weighted-average load size using the proposed small and large load sizes would match the weighted-average load size using the current minimum, average, and maximum load sizes. As proposed, the small and large load sizes would have equal load usage factors (“LUFs”)

of 0.5. The small and large load sizes would represent approximately the 25th and 75th percentiles of the normal distribution, respectively. Each of these points is discussed in greater detail in the paragraphs that follow.

LUFs are weighting factors that represent the percentage of wash cycles that consumers run with a given load size.

BILLING CODE 6450-01-P

Figure III.3 illustrates how the proposed new small and large load sizes would overlay with the P&G load distribution data.

EP01SE21.003

BILLING CODE 6450-01-C

As noted, DOE defined the proposed new load sizes and LUFs such that the weighted-average load size equals the weighted-average load size of the current minimum, average, and maximum load definitions for clothes washers with automatic WFCS, and thus will produce test results with equivalent representativeness. As noted in DOE's responses to comments above, DOE is not aware of any more recent, nationally representative field data indicating that the consumer load size distribution in relation to clothes washer capacity has changed since the introduction of the three load sizes in the August 1997 Final Rule.

Further, defining the small and large loads to represent approximately the 25th and 75th percentiles of the normal distribution balances the need to capture as large of a load size range as possible while remaining representative of the “peak” of the load distribution curve, which represents the most frequently used load sizes.

Specifically, DOE is proposing that the small and large load sizes be calculated using Equation III.1 and Equation III.2, respectively.

Small load size [

] = 0.90 × Capacity [

] + 2.34

Equation III.1 Proposed Determination of the Small Test Load Size

Large load size [

] = 3.12 × Capacity [

] + 0.72

Equation III.2 Proposed Determination of the Large Test Load Size

As noted, clothes washers with manual WFCS are tested only with the minimum and maximum load sizes, in contrast to clothes washers with automatic WFCS, which are tested with all three load sizes. Given DOE's proposal to define only two load sizes in the proposed new Appendix J, the same two load sizes could be used for all clothes washers, regardless of whether a clothes washer's WFCS is automatic or manual.

DOE's proposal would reduce test burden under the proposed new Appendix J by requiring only two load sizes to be tested instead of three for clothes washers with automatic WFCS. Specifically, the number of cycles tested would be reduced by 33 percent for clothes washers with automatic WFCS, which represent a large majority of clothes washers on the market.

DOE's proposed water fill selections corresponding to the new small and large load sizes are further discussed in section III.D.2 of this document.

DOE requests comment on its proposal to replace the minimum, maximum, and average load sizes with the small and large load sizes in the proposed new Appendix J. DOE seeks comment on how reducing the number of load sizes tested would impact the

representativeness of test results. DOE also requests data and information to quantify the reduction in test burden that would result from reducing the number of load sizes from three to two for clothes washers with automatic WFCS.

2. Water Fill Setting Selections for the Proposed Load Sizes

Section 3.2.6 of Appendix J2 prescribes the water fill setting selections to use with each load size based on the type of WFCS on the clothes washer. As discussed in section III.D.1.b of this document, DOE is proposing that the proposed new Appendix J test newly-defined small and large load sizes, rather than the minimum, maximum, and average load sizes used in Appendix J2. To test clothes washers using these new small and large load sizes, the appropriate water fill setting selections would also need to be provided in the proposed new Appendix J for each load size for each type of WFCS.

Appendix J2 defines two main types of WFCS: manual WFCS, which “requires the user to determine or select the water fill level,” and automatic WFCS, which “does not allow or require the user to determine or select the water fill level, and includes adaptive WFCS and fixed WFCS.” Sections 1.22 and 1.5 of Appendix J2, respectively. Section 3.2.6.2 of Appendix J2 further distinguishes between user-adjustable and not-user-adjustable automatic WFCS. Additionally, section 3.2.6.3 of Appendix J2 accommodates clothes washers that have both an automatic WFCS and an alternate manual WFCS. Proposed amendments to the definitions of fixed WFCS and user-adjustable automatic WFCS are further discussed in section III.H.3.a of this document.

Section 3.2.6.1 of the current Appendix J2 specifies that clothes washers with a manual WFCS are set to the maximum water level available for the wash cycle under test for the maximum test load size and the minimum water level available for the wash cycle under test for the minimum test load size.

Section 3.2.6.2.1 of Appendix J2 specifies that clothes washers with non-user-adjustable automatic WFCS are tested using the specified maximum, minimum, and average test load sizes, and that the maximum, minimum, and average water levels are selected by the control system when the respective test loads are used (

i.e.,

no selection of water fill level is required by the user).

Section 3.2.6.2.2 of Appendix J2 specifies that clothes washers with user-adjustable automatic WFCS undergo four tests. The first test is conducted using the maximum test load and with the automatic WFCS set in the setting that will give the most energy intensive result. The second test is conducted with the minimum test load and with the automatic WFCS set in the setting that will give the least energy intensive result. The third test is conducted with the average test load and with the automatic WFCS set in the setting that will give the most energy intensive result for the given test load. The fourth test is conducted with the average test load and with the automatic WFCS set in the setting that will give the least energy intensive result for the given test load. The energy and water consumption for the average test load and water level are calculated as the average of the third and fourth tests.

As discussed in section III.D.1.b of this document, DOE is proposing that the proposed new Appendix J test newly-defined small and large load sizes, rather than the minimum, maximum, and average load sizes used in Appendix J2. To test clothes washers using these new small and large load sizes, the appropriate water fill setting selections would also need to be provided in the proposed new Appendix J for each load size for each type of WFCS.

For manual WFCS clothes washers, DOE first considered maintaining the current water fill level settings as specified in Appendix J2 (

i.e.,

testing the proposed small load with the minimum water level setting available and testing the proposed large load with the maximum water level setting available). However, the proposed small load is larger than the current minimum load, and using the minimum water fill setting for the larger-sized “small” load may not be representative of consumer use. In other words, while the minimum water fill level setting may provide an appropriate amount of water for washing the “minimum” load size, it may not provide sufficient water for washing the “small” load size as proposed. Further, the 1995 P&G data showed that when using a clothes washer with manual WFCS, consumers tend to select more water than is minimally necessary for the size of the load being washed.

See p. 20 of the AHAM document at

www.regulations.gov/document/EERE-2006-TP-0065-0027;

specifically, the conclusions that “consumers are not good judges of clothes load size” and “consumers overuse maximum fill level.”

Based on these considerations, DOE is instead proposing to specify the use of the second-lowest water fill level setting for the proposed small load size. Although DOE is not aware of any clothes washers with manual WFCS currently on the market with only two water fill level settings available, DOE proposes to accommodate such a design by specifying that if the water fill level selector has two settings available for the wash cycle under test, the minimum water fill level setting would be selected for the small load size, consistent with the current specification in Appendix J2. In all cases, the water fill level selector would be set for the large load size to the maximum water fill level setting available for the wash cycle under test, consistent with the current specification in Appendix J2 for testing the maximum load size.

For clothes washers with non-user-adjustable automatic WFCS, no changes would be required because the water fill levels are determined automatically by the WFCS.

As discussed, section 3.2.6.2.2 of Appendix J2 specifies that clothes washers with user-adjustable automatic WFCS require four test cycles: one test at the most energy-intensive setting

using the maximum load size, one test at the least energy-intensive setting using the minimum load size, one test at the least energy-intensive setting using the average load size, and one test at the most energy-intensive setting using the average load size. As described in section III.D.1.b of this document, DOE's proposal would reduce the number of test load sizes from three to two, which would necessitate a change to these instructions for clothes washers with user-adjustable WFCS. To accommodate the proposed “small” and “large” load sizes in the proposed new Appendix J, DOE is proposing to require testing clothes washers with user-adjustable WFCS using the large test load size at the setting that provides the most energy-intensive result, and the small test load size at the setting that provides the least energy-intensive result. This proposal would capture the same range of water fill performance as the current test procedure (

i.e.,

capturing the range of least-intensive to most-intensive results). Additional tests could be considered, for example: Testing the small test load size at the setting that provides the most energy-intensive result and the large test load size at the setting that provides the least energy-intensive result. However, DOE has tentatively concluded that requiring

these two additional cycles beyond the two proposed cycles would create additional test burden with little, if any, improvement to representativeness compared to the proposal.

As described in section III.H.3.b of this document, DOE is proposing to update the phrase “the setting that will give the most energy-intensive result” to “the setting that uses the most water” (and likewise for the setting that will give the least energy-intensive result) to reflect the original intent of this provision.

In summary, DOE tentatively concludes that the proposed changes to the water fill level settings, in conjunction with the proposed changes to the load sizes and the applicable LUFs, would continue to produce representative test results for each type of WFCS. Collectively, this combination of amendments would continue to approximate the same consumer usage patterns that provide the foundation for the current Appendix J2 test procedure.

DOE recognizes that for some models, these proposed amendments could change the measured efficiency. As noted, DOE is proposing to include the changes to the water fill level specifications only in the proposed new Appendix J, which DOE would use for the evaluation and issuance of updated efficiency standards. Thus, DOE is proposing that use of the proposed new Appendix J, if finalized, would not be required until such time as the energy conservation standards are amended using the measured efficiency as determined under Appendix J.

DOE requests comment on its proposal to change the water fill level selections in the proposed new Appendix J for clothes washers with manual and user-adjustable automatic WFCS to reflect the proposed small and large test load sizes. DOE seeks data and information on how the proposed changes to the water fill level selection for clothes washers with manual and user-adjustable automatic WFCS would impact test procedure representativeness.

3. Determination of Warm Wash Tested Settings

Section 3.5 of Appendix J2 states that if a clothes washer has four or more Warm Wash/Cold Rinse temperature selections, either all discrete selections shall be tested, or the clothes washer shall be tested at the 25-percent, 50-percent, and 75-percent positions of the temperature selection device between the hottest hot (≤135 °F (57.2 °C)) wash and the coldest cold wash. If a selection is not available at the 25, 50 or 75-percent position, in place of each such unavailable selection, the next warmer temperature selection shall be used. DOE refers to the latter provision as the “25/50/75 test.” Section 3.6 of Appendix J2 states that the 25/50/75 test provision also applies to the Warm Wash/Warm Rinse temperature selection.

DOE first established the 25/50/75 test in Appendix J1-1997 to address the test burden for clothes washers that offer a large number of warm wash temperature selections, if the test procedure were to require testing all warm temperature selections. 62 FR 45484, 45497. DOE had originally proposed a similar method

in the April 1996 SNOPR for clothes washers having infinite warm wash selections that are nonuniformly distributed. 61 FR 17589, 17599. In the August 1997 Final Rule, DOE considered clothes washers with more than three warm wash temperatures to be clothes washers with infinite warm wash temperature selections, therefore allowing them to also use the 25/50/75 test. 62 FR 45484, 45498. DOE concluded at that time that testing at the various test points of the temperature range, with a requirement to test to the next higher selection if a temperature selection is not available at a specified test point, would provide data representative of the warm wash temperature selection offerings.

Id.

The originally proposed test would have required testing at the 20/40/60/80 percent positions.

DOE notes that the 25/50/75 test was adopted before the widespread use of electronic controls, which now allow for the assignment of wash water temperatures that may not reflect the physical spacing between temperature selections on the control panel. For example, with electronic controls, the 25-percent, 50-percent, and 75-percent positions on the dial may not necessarily correspond to 25-percent, 50-percent, and 75-percent temperature differences between the hottest and coldest selections. DOE is aware of clothes washers on the market with four or more warm wash temperature selections, in which the temperature selections located at the 25, 50, and 75-percent positions are low-temperature cycles that have wash temperatures only a few degrees higher than the coldest wash temperature; whereas the temperature selection labeled “Warm” is located beyond the 75-percent position on the temperature selection dial and is therefore not included for testing under the 25/50/75 test. 85 FR 31065, 31073.

In the May 2020 RFI, DOE requested feedback on the representativeness of using the 25/50/75 test on clothes washers with electronic controls, particularly for clothes washers in which the 25-percent, 50-percent, and 75-percent positions on the dial do not correspond to 25-percent, 50-percent, and 75-percent temperature increments between the hottest and coldest selections.

Id.

DOE also requested comment on whether there is a less burdensome means for the test procedure to be reasonably designed to measure energy use or efficiency of the clothes washer during a representative average use cycle.

AHAM opposed any changes to the 25/50/75 test for clothes washers with four or more warm/cold temperature selections, stating that changes are not necessary. AHAM asserted that introducing any change could lead to increased test burden with no evident benefit to consumers or energy savings. (AHAM, No. 5 at p. 13)

The CA IOUs supported DOE amending the 25/50/75 test to define positions along the temperature range instead of positions along the temperature selection device. The CA IOUs expressed concern that the current 25/50/75 test significantly underestimates energy usage of clothes washers in situations where positions along the temperature selection device do not match positions along the temperature range. (CA IOUs, No. 8 at p. 16)

The Joint Commenters expressed concern that the 25/50/75 test for clothes washers with four or more Warm Wash/Cold Rinse temperature selections is not representative because, for some clothes washers, the 25-percent, 50-percent, and 75-percent positions on the temperature dial may not accurately represent the 25-percent, 50-percent, and 75-percent temperature differences between the coldest and hottest selections. The Joint Commenters encouraged DOE to amend the 25/50/75 test so that it adequately represents the energy use of all clothes washers' Warm Wash/Cold Rinse temperature selections. (Joint Commenters, No. 10 at p. 3)

NEEA recommended that DOE characterize the Warm Wash/Cold Rinse temperature selections using a single test run on the wash temperature setting labeled “Warm” in order to increase representativeness of real-world use. NEEA expressed concern that the current test procedure likely underestimates hot water use and adds unnecessary test burden. (NEEA, No. 12 at pp. 18-20) NEEA added that its recommended change would eliminate up to six test runs from the test procedure (three load sizes at two wash/rinse temperatures). NEEA expects that this benefit would affect a sizeable percentage of the market, given NEEA's estimate that more than 75 percent of clothes washers sold in the Northwest have three or more discrete Warm Wash/Cold Rinse temperature selections.

Id.

DOE is proposing to require testing of both the hottest Warm Wash/Cold Rinse setting and the coldest Warm Wash/Cold Rinse setting for all clothes washers in the proposed new Appendix J instead of the 25/50/75 test. Water consumption, electrical energy consumption, and all other measured values

would be averaged between the two tested cycles to represent the Warm Wash/Cold Rinse cycle. DOE is proposing to make the same changes to the Warm Wash/Warm Rinse cycle in the proposed new Appendix J.

As discussed in sections III.D.4.a and III.D.5 of this document, DOE is proposing to require measurements of RMC and cycle time for each tested cycle.

DOE's proposal would decrease the test burden under the proposed new Appendix J for clothes washers that offer more than two Warm Wash/Cold Rinse or Warm Wash/Warm Rinse temperature settings, which DOE estimates represent around half of the market, by reducing the number of Warm Wash/Cold Rinse and Warm Wash/Warm Rinse tested cycles from three to two. Because this proposed approach may, however, change the measured energy use of clothes washers that offer more than two Warm Wash/Cold Rinse or Warm Wash/Warm Rinse settings, the proposed edits would not apply to Appendix J2 and therefore would not affect the measured efficiency of existing clothes washers. The ongoing RCW and CCW energy conservation standards rulemakings would consider the impact of any modifications to the measured efficiency using the proposed new Appendix J.

DOE tentatively concludes that the proposed approach in the proposed new Appendix J would maintain representativeness by continuing to capture the complete range of Warm Wash temperatures available for selection (

i.e.,

by relying on an average of the hottest Warm Wash/Cold Rinse setting and the coldest Warm Wash/Cold Rinse setting). For models that are currently tested using the 25/50/75 test and for which certain “Warm” settings are located beyond the 75-percent position on the temperature selection dial and therefore not included for testing, DOE's proposal would capture entire range of available Warm Wash temperatures available to the consumer, and therefore would improve representativeness.

DOE acknowledges that NEEA's suggestion to characterize the Warm Wash/Cold Rinse temperature selections using a single test run on the wash temperature setting labeled “Warm” would reduce test burden even further by requiring just a single test cycle. However, DOE tentatively concludes that testing a single Warm Wash temperature on a clothes washer that offers multiple Warm Wash selections to the user may not provide as accurate a representation of consumer usage as DOE's proposal, which captures the full range of available Warm Wash temperatures. In addition, DOE is concerned that defining the tested temperature as the setting labeled “Warm” would create ambiguity for clothes washers that offer multiple Warm Wash temperatures but for which no setting is expressly labeled “Warm.” For example, DOE is aware of clothes washers that use descriptors such as “Colors,” “Brights,” and “Whites” to describe the different wash temperature selections available to the user.

DOE requests comment on the proposal to require in the proposed new Appendix J testing only the hottest and the coldest Warm Wash/Cold Rinse settings. DOE seeks data and information on how this proposed change to the Warm Wash temperature settings required for testing would impact representativeness, testing costs, and manufacturer burden.

As noted, based on its market research, DOE estimates that roughly half of all clothes washer models on the U.S. market offer more than two Warm Wash/Cold Rinse temperature settings. For these units, DOE's proposal to simplify the Warm Wash/Cold Rinse settings required for testing may impact measured efficiency. Therefore, in this NOPR, DOE is proposing to change the Warm Wash tested settings only in the proposed new Appendix J and not in the existing Appendix J2. The ongoing RCW and CCW energy conservation standards rulemakings would consider the impact of these modifications to the Warm Wash/Cold Rinse tested cycles on measured efficiency.

4. Remaining Moisture Content

Section 3.8.4 of Appendix J2 requires that for clothes washers that have multiple spin settings

available within the energy test cycle that result in different RMC values, the maximum and minimum extremes of the available spin settings must be tested with the maximum load size on the Cold/Cold temperature selection.

The final RMC is the weighted average of the maximum and minimum spin settings, with the maximum spin setting weighted at 75 percent and the minimum spin setting weighted at 25 percent. The RMC measurement is used to calculate the drying energy component of IMEF. On most clothes washers, the drying energy component represents the largest portion of energy captured in the MEF and IMEF metric.

The term “spin settings” refers to spin times or spin speeds. The maximum spin setting results in a lower (better) RMC.

On clothes washers that provide a Warm Rinse option, RMC must be measured on both Cold Rinse and Warm Rinse, with the final RMC calculated as a weighted average using TUFs of 73 percent for Cold Rinse and 27 percent for Warm Rinse. DOE has observed very few clothes washer models on the market that offer Warm Rinse. For simplicity throughout this discussion, DOE references the testing requirements for clothes washers that offer Cold Rinse only.

DOE is aware of clothes washers on the market that offer multiple spin settings, but which offer only the maximum spin setting on the Cold/Cold temperature selection. 85 FR 31065, 31073. This results in the lower spin setting not being factored into the RMC calculation, despite being available at other temperature selections in the energy test cycle. As defined in the Temperature Use Factor (“TUF”)

Table 4.1.1 in Appendix J2, the Cold/Cold temperature selection represents 37 percent of consumer temperature selections, whereas the other available temperature selections, for which the lower spin settings would be available on such a unit, represent a combined 63 percent of consumer temperature selections.

Id.

DOE has tentatively concluded that the existing RMC measurement procedure may not provide representative test results on certain clothes washer models.

As described in more detail in section III.G.4 of this document, TUFs are weighting factors that represent the percentage of time that consumers choose a particular wash/rinse temperature selection for the wash cycle.

a. Revised Calculation

In the May 2020 RFI, DOE requested comment on testing clothes washers that offer only the maximum spin setting on the Cold/Cold temperature selection but provide lower spin settings on other temperature selections.

Id.

DOE suggested that, RMC could be measured at the default spin setting for each temperature selection and averaged using the TUFs.

Id.

AHAM stated that it is not necessary to address clothes washers with spin settings that are only available on certain temperature selections because the current method of RMC calculation is representative of an average use cycle. (AHAM, No. 5 at p. 13)

Samsung commented that clothes washers with spin settings that are available only on certain temperature selections make the current test procedure unrepresentative of real world use, since customers can select an

un-tested, and potentially more energy-intensive mode, in order to access the spin speed they intend to use. Samsung suggested that for such units, DOE consider requiring an additional test at another temperature setting where the spin speed is selectable. (Samsung, No. 6 at pp. 2-3)

NEEA commented that it was not aware of any units with spin speeds that are available only on certain temperature selections, but asserted that Appendix J2's current RMC test does not represent the range of RMCs expected in the field, even when maximum and minimum speeds are tested as specified in Appendix J2. NEEA presented RMC data from its testing of three top-selling clothes washer models, which demonstrated a difference in RMC of 0.3-1.1 percentage points between maximum and minimum speed.

(NEEA, No. 12 at p. 5) NEEA described laboratory testing it conducted to isolate and measure variables that affect RMC: testing was performed on 12 top-selling RCW models (including six front-loading and five top-loading), representing over five manufacturers, and spanning the range of efficiencies available on the market; two CCWs were tested as well. (NEEA at No. 12, pp. 2-13) NEEA stated its testing was performed according to the DOE Appendix J2 procedure, except that the RMC was calculated for all test runs performed; an encoder non-invasively measured revolutions per minute during test runs; and some tests were performed at different load sizes or using different cycle selections. Based on its data, NEEA stated that the current Appendix J2 RMC test does not represent the RMC of an average clothes washer cycle. NEEA asserted that the RMC test procedure prescribed in Appendix J2 represents a “best-case” scenario for RMC conditions—every other test that NEEA performed at alternate temperatures, load sizes, and cycle types increased the RMC value relative to the Appendix J2-tested value.

Id.

NEEA commented that, according to its testing, the primary difference in RMC for a given clothes washer was due to programmed spin differences such as spin time, and not differences in load size.

Id.

NEEA's stated that its test data show that among all the clothes washers tested, spin time was, on average, 7 minutes longer using the Cold Wash/Cold Rinse temperature selection with the maximum spin selection than when using the Warm Wash/Cold Rinse temperature selection with the default spin selection. These differences resulted in an RMC difference of an average of 10 percentage points.

Id.

NEEA recommended that DOE measure RMC at the default spin setting for each temperature selection and load size, and average those RMC values using TUFs and LUFs. NEEA stated that this approach will reduce test burden by removing the need for a separate test run exclusively for measuring RMC, increase representativeness by capturing RMC for all load sizes and water temperatures, and potentially result in significant energy savings for clothes dryers in the future.

Id.

DOE notes that in NEEA's comment, this range was cited as 0.3-0.9, but the data in the table presented by NEEA displayed a range of 0.3-1.1 percentage points between the RMCs at maximum and minimum speed.

The Joint Commenters and CA IOUs supported NEEA's comments and urged DOE to amend the test procedure to measure RMC for all load sizes and temperature selections, and to weight the measurements using LUFs and TUFs because doing so would improve the representativeness of the test procedure. (Joint Commenters, No. 10 at pp. 1-2; CA IOUs, No. 8 at pp. 6-7) The Joint Commenters stated that the current test procedure is likely significantly underestimating drying energy use and is leading to inaccurate efficiency ratings. (Joint Commenters, No. 10 at p. 1)

DOE is proposing an amended method for measuring RMC in the proposed new Appendix J that would require measuring RMC on each of the energy test cycles using the default spin settings, and determining the final RMC by weighting the individual RMC measurements using the same TUFs and LUFs that apply to the water and energy measurements. DOE notes that this proposal is largely consistent with the approach recommended by NEEA and supported by the Joint Commenters and CA IOUs.

DOE tentatively concludes (based on its test observations as described above and the test results presented by NEEA) that the current method of measuring RMC may no longer produce test results that measure energy and water use during a representative average use cycle or period of use, particularly as the prevalence of clothes washers with complex electronic controls continues to increase in the market. On a clothes washer with basic controls (

e.g.,

in which the available spin settings are the same regardless of what wash/rinse temperature is selected), measuring RMC using only the Cold/Cold cycle would be expected to provide RMC results that are equally representative of the other available wash/rinse temperatures, which as noted comprise the majority of consumer cycle selections. However, on a clothes washers in which the selection of wash/rinse temperature affects which spin settings are available to be selected, measuring RMC using only the Cold/Cold cycle may not necessarily provide results that measure energy and water use during a representative average use cycle or period of use (

i.e.,

across the range of wash/rinse temperature options selected by consumers, as represented by the temperature use factors).

The data presented by NEEA illustrates how, on average, the spin portion of the cycle on the setting used to measure RMC (

i.e.,

the maximum spin setting on the Cold Wash/Cold Rinse temperature setting) may not be representative of the spin characteristics and resulting RMC measurement of other temperature selections comprising the energy test cycle. Specifically, the data presented by NEEA suggest that the specific cycle configuration from which RMC is measured is programed with a longer spin time than other temperature settings available to the consumer, resulting in a significantly better RMC measurement than would be experienced by the consumer on the majority of wash cycles performed.

The proposed update to the RMC measurement would provide a more representative measure of RMC than the current test procedures because RMC would be measured on all of the energy test cycles rather than only the Cold Wash/Cold Rinse cycles, which represent only 37 percent of consumer cycles and may not share the same RMC performance as the other 63 percent of consumer cycles.

37% is the TUF for the Cold Wash/Cold Rinse temperature selection as specified in Table 4.1.1 of Appendix J2.

Regarding Samsung's suggestion to require an additional RMC test at a different temperature setting that would provide the spin speed that is unavailable on the Cold setting, DOE tentatively concludes that its proposed approach would provide a more representative measure of RMC by capturing RMC across all the temperature settings within the energy test cycle.

Because RMC directly affects drying energy, which is a large component in the calculation of IMEF, it is important that the RMC value be representative of all test cycles. DOE's proposal would make the RMC calculation consistent with how hot water energy, electrical energy, and water usage are calculated,

i.e.,

by testing multiple load sizes and temperatures and averaging these values using LUFs and TUFs.

DOE tentatively concludes that this proposal would reduce overall test burden. The proposal would require weighing the cloth before and after each test cycle, but would avoid the need to perform extra cycles for capturing both the maximum and minimum spin settings available on the clothes washer if such spin settings are not activated by default as part of the energy test cycle. In DOE's experience, a majority of clothes washers offer multiple spin settings, thus requiring between one and eight RMC cycles, depending on the specific options available on the clothes washer. Appendix J2 currently requires measuring the test load weight before each cycle in order to verify that the load is bone-dry.

To DOE's knowledge, many laboratories already measure and record the test load weight after each test cycle as a means for identifying potential cycle anomalies or to provide additional data that can be used to verify quality control retrospectively. In cases where a laboratory currently does not measure the weight after completion of the cycle, DOE's proposal would incur a

de minimis

amount of additional time to weigh the load after the cycle, which can be performed using the same scale used to weigh the load at the beginning of the cycle. For these reasons DOE does not expect the additional collection of data to result in additional test burden.

See section III.D.4.b of this document for the definition of the term “bone-dry.”

This proposal would likely impact the measured RMC value and thus would impact a clothes washer's IMEF value. Therefore, in this NOPR, DOE is proposing the revised RMC procedure only in the proposed new Appendix J and not in existing Appendix J2. The ongoing RCW and CCW energy conservation standards rulemakings would consider the impact of any modifications to the RMC calculation on measured efficiency.

DOE requests comment on its proposal to revise the RMC procedure so that RMC would be measured at the default spin setting for each temperature selection and load size, and the individual RMC values would be averaged using TUFs and LUFs to calculate the final RMC. DOE seeks data and information regarding how this change to the RMC calculation would impact testing costs and manufacturer test burden.

DOE further requests comment on whether DOE should implement any changes to the RMC calculation in Appendix J2 to address clothes washers with spin settings that are available only on certain temperature selections.

b. Definition of Bone-Dry

In section 1.6 of Appendix J2, the term “bone-dry” is defined as a condition of a load of test cloth that 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. The bone-dry definition was first established in the September 1977 Final Rule. 42 FR 49801, 49807-49808. In the March 2012 Final Rule, DOE added a specification to section 2.6 of Appendix J2 requiring that the dryer used for drying the cloth to bone-dry must heat the test cloth (and stuffer cloths) above 210 °F (99 °C). 77 FR 13888, 13924.

In response to the May 2020 RFI, NEEA recommended that DOE update its procedure for achieving bone-dry test cloth to harmonize with Annex G of IEC Standard 60456, “Clothes washing machines for household use—Methods for measuring the performance” Edition 5.0 (“IEC 60456”). (NEEA, No. 12 at p. 26) In particular, NEEA recommended that DOE consider the tumble dryer specifications in Section G.2 of IEC 60456, the dryer inlet temperature measurement method, and the requirement that the weight of the bone-dry load change be no more than 1 percent or 0.044 lb (whichever is smaller) between 10-minute drying periods (Section G.3 of IEC 60456).

Id.

DOE is not aware of any problems with the current bone-dry definition that would justify changing the bone-dry definition as NEEA has suggested. DOE has tentatively concluded that specifying a weight change of no more than 1 percent or 0.044 lb (whichever is smaller) would increase the test burden because for a majority of tested loads, the 0.044 lb requirement would apply, which would be more stringent than the existing 1 percent requirement. DOE has not identified, and commenters have not suggested, any problems with the current approach. In the absence of data indicating any problems with the current procedure, DOE is not proposing any changes to the bone-dry definition or associated dryer temperature measurement method in this NOPR.

DOE requests comment on its tentative conclusion not to propose changes to the bone-dry definition and associated dryer temperature measurement method.

c. Starting Moisture Content

Section 2.9.1 of Appendix J2 requires the test load for energy and water consumption measurements to be bone-dry prior to the first cycle of the test, and allows the test load to be dried to a maximum of 104 percent of the bone-dry weight for subsequent testing. This allowance effectively allows for an increase to the starting moisture content of the load from 1 percent moisture (as implied in the definition of “bone-dry” in section 1 of Appendix J2) to 4 percent moisture, which creates two concerns.

First, for the largest clothes washers on the market, which use the largest test load sizes, a 4 percent tolerance can represent up to 1 lb of additional water weight in a starting test load. DOE is concerned that the range of starting water weights that this provision allows could reduce the repeatability and reproducibility of test results, particularly for larger clothes washers.

Second, as described in section III.D.4.a of this document, DOE is proposing to require the measurement of RMC for all tested cycles in the proposed new Appendix J. The RMC of each tested cycle would be calculated based on the bone-dry weight at the start of the cycle. Allowing the bone-dry weight to vary within a range of 1 percent to 4 percent moisture at the beginning of each tested cycle would introduce variability into the RMC calculation.

Therefore, to improve repeatability and reproducibility of test results, DOE is proposing in new Appendix J to remove the provision that allows for a starting test load weight of 104 percent of the bone-dry weight, and instead require that each test cycle use a bone-dry test load. DOE is not proposing to make any changes to section 2.9.1 of Appendix J2, recognizing that such a change could impact measured energy efficiency.

In DOE's experience, most test laboratories use the bone-dry weight as the starting weight of each test load rather than a starting weight up to 104 percent of bone-dry, as allowed by section 2.9.1 of Appendix J2. If a test laboratory does make use of this provision in section 2.9.1 of Appendix J2, the requirement to use the bone-dry weight would add no more than 10 minutes of drying time per cycle to ensure that the test load has reached the bone-dry requirement. In DOE's experience, most test laboratories dry the load from the previous test cycle while the next cycle is being tested on the clothes washer, such that a minor increase in drying time would not affect the overall time required to conduct the test procedure.

DOE requests comment on its proposal to require that each test cycle use a bone-dry test load in the proposed new Appendix J. DOE requests comment on whether test laboratories

start test cycles with the test load at bone-dry or at up to 104 percent of the bone-dry weight. DOE further requests feedback on its assessment that this change would not affect test burden.

5. Cycle Time Measurement

The current test procedure does not specify a measurement for average cycle time. In this NOPR, DOE is proposing to base the allocation of annual combined low-power mode hours on the measured average cycle time rather than a fixed value of 8,465 hours, for the proposed new Appendix J (see section III.G.3 of this document). DOE is therefore proposing to require the measurement of average cycle time for the proposed new Appendix J. Calculating the annual standby mode and off mode hours using the measured average cycle time would provide a more representative basis for determining the energy consumption in the combined low-power modes for the specific clothes washer under test.

DOE is proposing to define the overall average cycle time of a clothes washer model as the weighted average of the individual cycle times for each wash cycle configuration conducted as part of the test procedure, using the TUFs and LUFs for the weighting. Using the weighted-average approach would align the average cycle time calculation with the calculations for determining weighted-average energy and water use. These proposed changes would apply only to the proposed new Appendix J.

DOE does not expect the measurement of cycle time to increase test burden. To DOE's knowledge, test laboratories are either already measuring cycle time for all tested cycles or using data acquisition systems to record electronic logs of each cycle, from which determining the cycle time would require minimal additional work.

DOE requests comment on its proposal to add cycle time measurements and to calculate average cycle time using the weighted-average method in the proposed new Appendix J. DOE also requests comment on its assertion that adding cycle time measurements and a calculation of a weighted-average cycle time would not increase testing costs or overall test burden.

6. Capacity Measurement

Section 3.1 of Appendix J2 provides the procedure for measuring the clothes container capacity, which represents the maximum usable volume for washing clothes. The clothes container capacity is measured by filling the clothes container with water and using the weight of the water to determine the volume of the clothes container. For front-loading clothes washers, this procedure requires positioning the clothes washer on its back surface such that the door opening of the clothes container faces upwards and is leveled horizontally.

a. Computer-Aided Design

DOE is aware that for some front-loading clothes washers, positioning the clothes washer on its back surface may be i

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