5

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- i APPENDIX 5

- C. ENGINEERING QUESTION NAIRES

TABLE OF CO NTENTS

5

- C.1 DESIGN FOR ENERGY IM PROVEMENT INFORMATIO N REQUEST

FOR RESIDENTIAL CLOT HES WASHERS

................................ ........................... 1

5

- C.2 QUESTIONNAIRE TO EVA LUATE THE PRODUCT CL ASSES AND

STANDARDS PROPOSED I N THE CONSENSUS AGRE EMENT

....................... 14

5

- C.3 INFORMAT ION REQUEST FOR COMP ACT

- SIZE PRODUCT CLASSES

FOR RESIDENTIAL CLOT HES WASHERS

................................ ......................... 225

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- 1 APPENDIX 5

- C. ENGINEERING QUESTION NAIRE S

5

- C.1 DESIGN FOR ENERGY IM PROVEMENT INFORMATIO N

REQUEST FOR RESIDENT IAL CLOTHES WASHERS

The United States Department of Energy (DOE) is currently reviewing energy

conservation standards for residential clothes washers. DOE would like to confirm information on the incremental costs of increasing product efficiency by understanding the design o ptions involved in the efficiency improvement.

1. Market Share of Products You Sell

To help DOE discover manufacturer sub

- groups and the relative importance of various product classes to specific manufacturers, please disaggregate your annual unit shipment s for each product category as shown below. Please also indicate whether you purchase these products from other manufacturers ( i.e. private label), and whether the factory that supplies the product is located in the United States.

Product Class % Private

Label % Made in US 2008 Unit Shipments

Top

- Loading, Compact

Top

- Loading, Standard

Top

- Loading, Semi

- automatic

Front

- Loading

Suds

- Saving

**•** Are you aware of any top

- loading semi

- automatic or suds

- saving units on the

market?

2. Product Design Features

The following series of exhibits and questions address technical characteristics of key residential clothes washer components for both baseline and improved

- efficiency products.

Baseline Clothes Washers Which design features impacting ener gy use are generally incorporated into a “baseline” clothes washer ( i.e. one that just meets existing modified energy factor (MEF) and water factor (WF) standards, if any) in the following product classes?

**•** Top

- loading, Compact

- size

**•** Top

- loading, Standard

- si ze5

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- 2 **•** Top

- loading, Semi

- automatic

**•** Front

- loading

**•** Subs

- Saving

Incremental Efficiency Levels DOE proposed in the framework document to use efficiency levels based on the MEF and WF specifications prescribed by ENERGY STAR and the Consortium for Energy

Efficienc y (CEE)’s Super

- Efficient Home Appliances Initiative, along with the maximum levels that are currently available in the market. For top

- loading clothes washers, DOE did not include CEE Tier 3 as an efficiency level because the difference between the Tier

3 criteria (2.20 MEF/4.50 WF) and the maximum available level (2.26 MEF/4.48 WF) was so small. For top

- loading standard

- size clothes washers, DOE proposed to add a level to fill the gap between the baseline and the ENERGY STAR criteria. For front

loading cl othes washers, DOE proposes to add a level to fill the gap between the CEE Tier 3 criteria and the maximum available level. It will set these gap

- fill levels at combinations of MEF and WF that are strongly represented in the California Energy Commission (C EC) appliance product directory.

For both top

- and front

- loading clothes washers, DOE recognizes that MEF and WF pairings may not simultaneously achieve max

- tech levels. That is, a clothes washer with the highest possible MEF may not achieve the lowest po ssible WF. Similarly, a clothes washer with the lowest WF may not achieve the highest MEF. DOE considered several models in each product class to determine max

- tech values that best represent optimal performance for products on the market. DOE did not sugg est max

- tech levels that represent a “hybrid” of the highest possible MEF and the lowest possible WF for each product class.

For top

- loading compact

- size clothes washers, DOE did not establish efficiency levels for analysis in previous rulemakings. Based on a review of the top

- loading compact

- size clothes washers in the CEC directory, which revealed little difference between the maximum available efficiency and the baseline DOE standard, DOE proposed to analyze one efficiency level above the baseline repre sented by the currently available maximum technology.

Table 1 through Table 3 shows the proposed efficiency levels for each product class.

**•** Are the proposed efficiency levels appropriate?

**•** Can you suggest an appropriate “max

- tech” efficiency level?

**•** Do you believe that the gap

- fill efficiency levels defined by DOE for top

- loading

standard

- sized and front

- loading clothes washers are representative? If not, can you suggest appropriate gap

- fill values?

**•** If you believe the top

- loading semiautomatic and su ds

- saving clothes washer product classes should be analyzed, can you suggest baseline, gap

- fill, and max

tech efficiency levels for those product classes?5

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- 3 Table 1 : Efficiency Levels for Top

- Loading Standard

- Size Residential Clothes

Washers

Level Efficiency Level Source Efficiency Level

MEF WF

Baseline DOE Standard 1.26 9.50

1 Gap Fill 1.40 9.50

2 ENERGY STAR 1.72 8.00

3 CEE Tier 1 1.80 7.50

4 CEE Tier 2 2.00 6.00

5 Max Available 2.26 4.48

Table 2 : Efficiency Levels for Top

- Loading Compact

- Size Residential Clothes

Washers

Level Efficiency Level Source Efficiency Level

MEF WF

Baseline DOE Standard 0.65 18.40

1 Max Available 0.78 13.90

Table 3 : Efficiency Levels for Front

- Loading Residential Clothes Washers

Level Efficiency Level Source Efficiency Level

MEF WF

Baseline ENERGY STAR 1.72 8.00

1 CEE Tier 1 1.80 7.50

2 CEE Tier 2 2.00 6.00

3 CEE Tier 3 2.20 4.50

4 Gap Fill 2.40 4.20

5 Max Available 2.89 3.36

**•** What design changes are generally required to convert a typical baseline top

loading standard

- sized clothes washer (1.26 MEF, 9.50 WF) to each incremental efficiency level up to the max available level (2.26 MEF, 4.48 WF)?

o What are the costs of the individual design options selected?

**•** What design changes are associated with converting a baseline top

- loading
compact

- sized clothes washer (0.65 MEF, 18.40 WF) to the maximum available level (0.78 MEF, 13.90 WF)?

o Are these design changes comparable for top

- loading standard

- sized

clothes washers?

o What are the costs of the individual design options selected?5

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- 4 **•** What design changes are associated with converting a baseline front

- loading clothes washer (1.72 MEF, 8.00 WF) to each incremental efficiency level up to the maximum available level (2.89 MEF, 3.36 WF)?

o Are these design changes comparable for other produc t classes?

o What are the costs of the individual design options selected?

**•** Are the aggregated industry costs for each product class (highlighted in red in the Tables below) representative of your firm’s costs? Please indicate your firm’s

costs for achievin g the proposed efficiency levels in the Tables below.

**•** Are there fundamental differences between required design changes that make the cost increment much higher for some product classes than others?

**•** Would you help DOE understand and estimate the conve rsion capital investments that would be necessary at each candidate standard level? What is the nature of the capital investments?

**•** What depreciation method would your company use to depreciate the conversion capital expenditures?

**•** Are installation costs a f unction of efficiency? Maintenance costs? Repair costs? If yes, would you please characterize this relationship by providing incremental installation, maintenance, and/or repair cost data?

**•** Is there a relationship between MEF and WF? If yes, please charact erize this relationship.5

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- 5 Table 4 : Manufacturer Cost Data: Top

- Loading

– Compact and Standard

Product Class  Top

Loading

– Compact Top

- Loading

– Standard

Efficiency Level 1 1 2 3 4 5

MEF 0.78 1.40 1.72 1.80 2.00 2.25

WF 13.90 9.50 8.00 7.50 6.00 4.45 Average Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#
Minimum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Maximum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#
Conversion Capital Expenditures ($, Millions)

Building CAPX
Tooling/ Equipment

CAPX

One

- Time Product Conversion Expenses ($, Millions)

R&D
Marketing

# Depreciation on the conversion capital expenditure should NOT be included in the incremental overhead.
* Incremental costs per unit should be reported relative to the baseline unit’s cost. The baseline unit complies with the feder al standard for residential clothes washers and is equal to an MEF of 1.26 and WF of 9.50 for Top

- Loading

– Standard and an MEF of 0.65 for Top

- Loading

- Compact. The baseline WF of 18.40 for Top

- Loading

– Compact was selected based on a survey of clothes washers listed in the NRCan product database.

Direct material

– Costs of raw materials including scrap that can be traced to final or end products. Direct material costs do not include indi rect material costs which are attributed to supplies that may be used in the production process but are not assigned to final pr oducts ( e.g. , lubricating oil for production machinery).

Direct labor

– The earnings of workers who assemble parts into a finished good for operate machines in the production process. Direct labor includes the fringe benefits of direct laborers such as gro up health care, as well as overtime pay. Direct labor does not include indirect labor which is defined as the earnings of employ ees who do not work directly in assembling a product, such as supervisors, janitors, stockroom personnel, inspectors, and forkli ft operators.

Overhead

– Factory overhead excluding depreciation. Factory overhead includes indirect labor, downtime, set

- up costs, indirect material, expendable tools, maintenance, property taxes, insurance on assets, and utility costs. Factory overhead d oes not include selling, general, and administrative costs (SG&A); R&D; interest; or profit (accounted for by DOE separately)

. Full Production Cost = Direct Material + Direct Labor + Overhead (factory) + Depreciation

Full Cost of Product = Full Production Cost + Non

- production Costs (SG&A, R&D, interest, and profit)5

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- 6 Table 5 : Manufacturer Cost Data: Front

- Loading

Product Class  Front

- Loading

Efficiency Level 1 2 3 4 5

MEF 1.80 2.00 2.20 2.40 2.89

WF 7.50 6.00 4.50 4.20 3.36
Average Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#
Minimum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#
Maximum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead# Conversion Capital Expenditures ($, Millions)

Building CAPX
Tooling/ Equipment CAPX

One

- Time Product Conversion Expenses ($, Millions)

R&D
Marketing

# Depreciation on the conversion capital expenditure should NOT be included in the incremental overhead.
* Incremental costs per unit should be reported relative to the baseline unit’s cost. The baseline unit for the front

- loading product class complies w ith the current ENERGY STAR level for residential clothes washers and is equal to an MEF of 1.72 and WF of 8.00.

Direct material

– Costs of raw materials including scrap that can be traced to final or end products. Direct material costs do not include ind irect material costs which are attributed to supplies that may be used in the production process but are not assigned to final products ( e.g. , lubricating oil for production machinery).

Direct labor

– The earnings of workers who assemble parts into a finis hed good for operate machines in the production process. Direct labor includes the fringe benefits of direct laborers such as group health care, as well as overtime pay. Direct labor does not include indirect labor which is defined as the earnings of emplo yees who do not work directly in assembling a product, such as supervisors, janitors, stockroom personnel, inspectors, and forklift operators.

Overhead

– Factory overhead excluding depreciation. Factory overhead includes indirect labor, downtime, set

- up co sts, indirect material, expendable tools, maintenance, property taxes, insurance on assets, and utility costs. Factory overhead does not include selling, general, and administrative costs (SG&A); research and development (R&D); interest; or profit (account ed for by DOE separately).

Full Production Cost = Direct Material + Direct Labor + Overhead (factory) + Depreciation

Full Cost of Product = Full Production Cost + Non

- production Costs (SG&A, R&D, interest, and profit)5

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- 7 DOE is requesting data on efficiency improvements and manufacturing costs associated with specific technology options. When providing data on efficiency improvements please indicate the improvements with respect to MEF and WF.

Control Systems

Adaptive Control Systems

**•** Is there any room for further, significant energy efficiency improvement via adaptive control systems that adjust washer operation or conditions ( i.e. , wash temperature, cycle time, number of rinse cycles, spin speed, and other parameters) based on

characteristics of the clothes load? If so, how much improvement can be achieved? What is the incremental manufacturing cost associated with adaptive control systems? What adaptive control sensor technologies do you use in your washers ( e.g. , sensors to measure the soil l oad, turbidity sensors to detect water quality, etc)?

**•** Do any of your clothes washers use a fuzzy logic to weigh laundry loads and regulate the length of the wash cycle, water level, number of rinses, and drying time? If so, how much efficiency improvement can be achieved? What would be the incremental manufacturing cost?

Automatic Fill Controls

**•** What types of automatic fill control technologies do you incorporate in your front

load clothes washers? Top

- load clothes washers? What are the incremental costs

a ssociated with these automatic fill control technologies? How much energy can be saved using this technology option?

**•** Are there fundamental differences in the implementation of this technology option that make the cost increment much higher for some product classes than others? If so, please elaborate on these differences.

Improved Fill Control

**•** Is there any room for further significant energy efficiency improvement via improved fill control? For example, improving tolerances on existing wash

- water fi ll sensing (pressure sensors or improving switch design) to avoid overfilling the wash tub? What would be the incremental manufacturing cost?

Other Control Issues

**•** Are you aware of any intellectual property or patent infringement issues that might

affect your choice of adaptive control, automatic fill, or improved fill control technology?

**•** What is the incremental manufacturing cost of switching from electromechanical controls to electronic controls? Which technology options require electronic controls?

**•** Have you considered requiring a cold rinse and offering more warm or cold wash programs while reducing the number of hot wash cycle options in order to increase the MEF without affecting the WF per the DOE test procedure?5

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- 8 Advanced Agitation Concepts for Ver tical

- Axis Machines

**•** What types of advanced agitation technologies do you incorporate in your top

- loading clothes washers ( e.g. , nutating plates, rotating disks, side

- mount agitators)? How much efficiency improvement can be achieved with each type of advan ced agitation technology? What is the incremental manufacturing cost compared to the standard agitator found in traditional top

- loading machines?

Drum/Tub Upgrades

Added Insulation

**•** Have you considered increased insulation as a design option? If so, what thicknesses and insulation materials have you considered? How much efficiency improvement can be achieved? What would be the incremental manufacturing cost?

Horizontal

- Axis Design

**•** DOE’s review of research and literature shows that horizontal

- axis mac hines use on average 40 percent less energy and 25 percent less water than traditional vertical

- axis washers. Would you consider this accurate? If not, please suggest a more appropriate

value.

**•** Are performance or consumer utilities limited by horizontal

- axi s designs?

Horizontal

- Axis Design with Recirculation

**•** Have you considered horizontal

- axis design with recirculation as a design option ( i.e.

, using a pump to recirculate water and spray it into the drum)? How much efficiency improvement can be achieved wit h this design option? What would be the associated incremental manufacturing cost?

**•** Would this design option limit consumer utilities or performance?

Horizontal

- Axis Design with Top

- Loading Configuration

**•** Have you considered a horizontal

- axis drum design th at can be loaded from the top? Would you consider this to be a viable design option? Would a top

- loading

horizontal

- axis washer have any inherent differences in performance compared to a

traditional front

- loading horizontal

- axis washer? What would be the a ssociated incremental manufacturing cost for this feature?

Improved Horizontal

- Axis Drum Design

**•** Is there any room for further significant energy efficiency improvements via

horizontal

- axis drum design ( i.e. , to improve wash performance, reduce mass, and increase spin speeds)? Have you considered drums featuring special paddles, drum

wall textures, or similar enhancements? If so, how much efficiency improvement can be achieved? What would be the incremental manufacturing cost?5

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- 9 Reduced Thermal Mass

**•** Have you considered using a plastic wash tub specially designed to minimize the thermal mass that is heated by the water? If so, what specific materials have you considered? How much efficiency improvement can be achieved? Are there any advanced materials (pla stics, composites, or others) that could be used to lower the thermal mass of the tub beyond the current practice? What would be the incremental manufacturing cost?

Tighter Tub Tolerance

**•** Have you considered tighter tub tolerances ( i.e. , reducing the annul ar volume between the inner wash basket and outer tub) as a means for improving efficiency? If so, how much efficiency improvement can be achieved? What is the incremental manufacturing cost?

**•** Are there other design considerations that are important in dete rmining an appropriate clearance between basket and tub? If so, please elaborate.

Improved Water Extraction to Lower Remaining Moisture Content (RMC)

**•** Have you considered increasing the spin speed of the wash basket for the final spin cycle? What design changes would be required for this and what would be the incremental manufacturing cost? What would be the associated improvement in efficiency?

**•** Have you considered changing the direction of rotation to more evenly distribute clothes? If so, how much effic iency improvement can be achieved? What would be the incremental manufacturing cost?

**•** Have you considered longer spin cycles to lower the RMC? How much efficiency improvement can be achieved?

**•** How much efficiency improvement can be achieved through increasin g the size or number of drainage holes in the washer drum? What would be the associated manufacturing cost?

**•** Based on DOE’s review of the CEC product database, front

- loading washer RMC values range from 30 to 53 percent and top

- loading washers RMC values ra nge from 35 to 61 percent. What RMC levels can be achieved with the above mentioned improved water extraction design changes? What RMC levels are achieved by your currently offered top

- load clothes washers? Front

- load clothes washers?

**•** Does the size of the test load affect the RMC that can be achieved? If so, are you aware of any data showing this relationship?

Drum Motor Upgrades and Improvements

**•** What types of drum motors do you currently employ in your clothes washers?5

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- 10 Increased Motor Efficiency

**•** Have you considered improved motor efficiency as a design option? If so, how much improvement can be achieved? What is the incremental manufacturing cost associated with improved motor efficiency?

**•** DOE’s review of literature and research indicates that rep lacing a split

- phase motor with a capacitor

- start motor may increase the efficiency of the motor by 10 percent. Would you consider this accurate?

**•** How much efficiency improvement can be achieved with permanent magnet motors?

**•** What percentage of the overall energy consumption in a wash cycle is associated with

the drum motor?

Direct

- Drive Motors

**•** Do any of your top

- loading or front

- loading washers use a direct

- drive motor? How much efficiency improvement can be achieved with this design option as compared to the conventional motor/transmission system? Are the efficiency improvements different for each product class?

**•** What type of motor would be used for this technology option ( e.g. , brushless direct

current (BLDC) motor)?

**•** How would a direct

- drive system af fect cleaning performance, cycle times, or spin speeds?

**•** Are there larger standby power requirements for a direct

- drive motor system? If so,

how much?

**•** What is the incremental manufacturing cost associated with a direct

- drive motor?

Spray Rinse or Si milar Water

- Reducing Rinse Technology

**•** Do your clothes washers currently incorporate spray rinse? How much efficiency improvement can be achieved through this design option? What is the incremental manufacturing cost?

**•** Do any of your clothes washers incorporate steam washing? How much efficiency improvement can be achieved through this design option? What is the incremental manufacturing cost?

**•** Do spray rinse and steam washing raise performance issues ( e.g. , reducing soil removal)?

Thermostatically C ontrolled Mixing Valves

**•** Have you considered thermostatically controlled water valves (TCWVs) as a design option to achieve energy savings by more accurately controlling inlet water temperature? How much efficiency improvement can be achieved? What is the incremental manufacturing cost?

**•** Do adjustments to the water inlet temperatures raise performance issues ( i.e.

, reducing soil removal with lower wash temperatures)?5

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- 11 **•** DOE believes that TCWV technology option has the potential to overstate the real

world ene rgy savings, depending on the proximity of the water heater to the installed clothes washer and unheated water temperatures in different geographic locations and time of year. Are the benefits of TCWVs accurately captured by the test procedure?

**•** Can e fficiency improvements be achieved with non

- thermostatically controlled water inlet systems, i.e. , reducing the hot water energy use by reducing the warm water temperature using different hot and cold water ratios (40 percent hot and 60 percent cold as opp osed to 50

- 50)? How much efficiency improvement can be achieved? Are there concerns with performance and consumer utility when adjusting the hot and

cold water ratios?

Hot Water Circulation Loop

**•** Have you considered hot water circulation loop as a design option ( i.e. , using the hot water line running through a heat exchanger to heat cold water for use in a clothes washer)? How much efficiency improvement can be achieved? What is the incremental manufacturing cost associated with this design option?

Alte rnative Cleaning Processes

Plastic Particle Cleaning

**•** Have you considered plastic particle cleaning ( i.e. , tumble clothes with polymer granules which absorb dirt) as a design option? Has there been any attempt to commercialize this technology? DOE’s review of research and literature indicates that this technology would require 2 percent of the water used by a conventional clothes washer. Would you consider this accurate?

Bubble Action

**•** Have you considered an air

- bubble feature as a design option ( i.e. using air bubbles to more effectively deliver detergent to the surface of the clothing, while requiring less water than a typical wash cycle)? If so, what technology are you using to generate the bubbles? How much efficiency improvement can be achieved? What is the incremental manufacturing cost?

Electrolytic Disassociation of Water

**•** Have you considered electrolytic disassociation of water as a design option ( i.e.

, reducing hot water usage by substituting the electrolytic production of bleaching agents for the activation of bleaching chemical reactions in detergents by hot water)? How much efficiency improvement can be achieved? What is the incremental manufacturing cost?5

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- 12 Ozonated Laundering

**•** Would you consider ozonated laundering a viable design option? How much efficiency improvement can be achieved? What is the incremental manufacturing

cost?

Smart Grid Technologies

**•** Have you considered smart grid technologies as a design option? If so, what specific capabilities would be enabled by the smart grid technol ogy? Other than shifting energy usage away from peak power periods, could smart grid technology affect the overall energy efficiency of the clothes washer? How much efficiency improvement can be achieved? What is the incremental manufacturing cost?

Standby Power

**•** What are the consumer utilities associated with each type of display used in clothes washer? (For example, cycle/temperature selection, delay start time, cycle time, etc.)

**•** What types of display technologies do you use in your clothes washer product line? What are the standby power requirements for each display type assuming a comparable display (size and capability)?

**•** Are you aware of consumers demanding specific display types or is it other clothes

washer features that attract them?

**•** What are the manufacturing costs associated with various display technologies?

**•** What drives the costs for each display technology?

**•** What would be the manufacturing costs associated with adding a feature to dim or turn off the displays? How much could this potentially decrease power consumption?

**•** What clothes washer features other than displays contribute to standby power, and what is the standby power requirement associated with each of them?

**•** Do any of your clothes washers incorporate switching power supplies? Is this a viable technology for reducing standby power in clothes washers? What is the incremental manufacturing cost of a switching power supply compared to a conventional linear power supply?

**•** Would you consider the following a viable design option for reducing s tandby power, and if so what would be the incremental manufacturing cost: a transformer

- less power supply design, incorporated with a “soft” power pushbutton and triac to control power through the transformer, providing just enough power through the transf ormer

- less power supply to maintain the microcontroller chip while the clothes washer is not powered on. When the power button is pressed, current would then be allowed to pass through the transformer of the conventional power supply to power the remainder of

the control board.

**•** What other design options are available for reducing standby power consumption? What is the associated incremental manufacturing cost?5

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- 13 3. Test Procedure Issues

**•** How do you currently measure the capacity of your clothes washers? More specifically, at what level do you fill the washer with water for the DOE capacity measurement for top

- loaders? What level do you fill the washer with water for front

loaders? Is the c apacity measurement for the DOE energy test the same capacity used for marketing purposes? Would you suggest any changes to the current language for measuring capacity in the DOE energy test procedure?

**•** Do you have any data showing the effects on RMC resul ts using test cloth from different lots for a given clothes washer unit? Have you observed significant test

- to

test variation in MEF and WF measurements and RMC results as the test cloth ages (from 0 to 60 runs) for a given clothes washer unit? If so, how much is this variation? Do you have any test data showing this variation? Are there other test cloth issues that affect the measured test results that you are aware of? Would you recommend any changes to the test cloth specifications currently included in the DOE test procedure?

**•** Since the AHAM

- 2A detergent is no longer available, what detergent do you currently use to precondition the test cloths according to the DOE test procedure?

**•** The current DOE test procedure does not require the use of detergent during the energy test wash cycles. Do you believe the test procedure should be amended to require the use of detergent during the energy test wash cycles? If so, would you suggest using a powder or liquid detergent? Should DOE specify a specific brand of deterg ent to use to help ensure repeatability of test results? Would there be any concerns with the repeatability of test results using a liquid detergent?

**•** Do you have any consumer usage data showing the percentage of consumers that use powder detergent versus l iquid detergent?

**•** The current DOE test procedure does not provide specifications for the test load size for clothes washer capacities greater than 3.8 ft 3 . Would a linear extrapolation of test load sizes for capacities greater than 3.8 ft 3 be appropriate ? If not, can you suggest appropriate test load sizes (minimum, average, and maximum) for capacities greater

than 3.8 ft 3 ?

**•** Are you aware of any test procedures which account for adaptive controls (other than adaptive water fill control)?

**•** Are the temperatu re use factors specified by the current test procedure, which provide a weighted

- average measurement of energy and water performance under the range of typical wash and rinse cycle temperature selections, representative of current consumer patterns and ava ilable wash cycles?

**•** Are there any clothes washer features currently available in the market that you believe should be incorporated into the test procedure? For example, should the test procedure incorporate steam cycles? Should the test procedure incorpor ate self

cleaning, deodorizing, or sanitizing cycles? Are there any other features that may impact the energy usage compared to a traditional wash and rinse cycle?

**•** Do you have any consumer usage data showing the percentage of consumers that use each type o f wash cycle or advanced feature currently available in the market?5

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- 14 5

- C.2 QUESTIONNAIRE TO EVA LUATE THE PRODUCT CL ASSES AND

STANDARDS PROPOSED I N THE CONSENSUS AGRE EMENT

The Association of Home Appliance Manufacturers (AHAM) and the American Council

for an E nergy Efficient Economy (ACEEE) recently released a multi

- product standards agreement (Consensus Agreement) that addressed negotiated standards for refrigerators/freezers, clothes washers, clothes dryers, room air conditioners, and

dishwashers. For clothes washers, the Consensus Agreement proposes updated standards for top

- loading standard and top

- loading product classes, as well as splitting the existing

front

- loading product class into front

- loading standard and front

- loading compact clothes

washers. DOE’ s rulemaking process allows for a direct publication of a final rule if DOE concludes that standards proposed in the Consensus Agreement meet certain statutory criteria. In order to evaluate the product classes and standards proposed in the Consensus Agree ment for residential clothes washers, DOE is requesting information on the topics in this questionnaire.

DOE is requesting information on the product classes in the table below.

Baseline Efficiencies for Considered Product Classes

Product Class Product Class Description Baseline MEF (ft 3 /kWh/cycle) Baseline Standby Power (W) Top

- Loading,

Standard Top

- loading with capacity greater than 1.6 ft 3 1.26 0

Top

- Loading, Compact Top

- loading with capacity

less than 1.6 ft 3 0.65 0

Front

- Loading,

Standard Front

- loading with capacity greater than 1.6 ft 3 1.72 2.3

Front

- Loading, Compact* Front

- loading with capacity

less than 1.6 ft 3 N/A N/A

*DOE is not aware of any compact front

- loading clothes washers available on the market, and is especially

interested in information on this product class to evaluate the proposed standard in the Consensus Agreement.

Any amended standards for clothes washers would be expressed in terms of the integrated modified energy factor (IMEF), as proposed in the test procedure NOP R published on September 21, 2010. 75 FR 57556. Based on the current definition, DOE expects IMEF to vary significantly from the current MEF metric. IMEF will account for standby and off mode energy consumption, as well as energy use from steam and self

cl eaning cycles. The proposed test procedure also includes changes to the capacity measurement for top

- loading washers, which will affect IMEF. The discussion below references efficiency levels in terms of MEF to avoid metrics unfamiliar to

manufacturers.

1 K EY ISSUES

1.1 You previously indicated the following key issues in this rulemaking: [LIST KEY ISSUES] Do these remain key issues for your company in this rulemaking, and are there any additional key issues you believe DOE should consider in this5

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- 15 rulemaking?

2 ENGINEERING AND LIFE

- CYCLE COST

2.1 Are the AHAM

- supplied average incremental manufacturing costs at each efficiency level representative of costs your company incurs at each of these efficiency levels? Also, please indicate if the design options you pr eviously stated for the given efficiency levels are still valid.

AHAM

- Supplied Standard Top

- Loading Incremental Costs

MEF (ft 3 /kWh/cycle) AHAM Average

Incremental Cost (materials, labor, OH) Actual

Incremental Cost (if different) Description of Design Options

1.40 $3.08

1.72 $8.39 Electronics, load sensors, spray rinse, temperature sensors, modified agitators/baskets

1.80 $13.02 Same as above

2.00 $23.99 Impeller, stainless baskets (higher spin speeds), better electronic controls/sensors, hung suspension, lower water temperatures, longer cycles, variable motor drives

2.26 $59.25 Higher spin speeds, better load detection/flow meters, sophisticated drives, accelerometers, better suspension, longer cycles

AHAM

- Supplied Standard Front

- Loading Incremental Costs

MEF (ft 3 /kWh/cycle) AHAM Average
Incremental Cost (materials, labor, OH) Actual
Incremental Cost (if different) Description of Design Options

1.80 $2.13

2.00 $6.09 Electronic UI

2.20 $15.73 Better damping/sensing systems, water level sensors paired with flow meters

2.40 $38.89

2.89 $72.13

2.2 At the time the Framework Document was published, the max

- tech units had MEF ratings of 2.26 and 2.89 for top

- loading and front

- loading clothes washers respectively. DOE is now aware of top

- loading clothes washers with a MEF of 2.57, and

front

- loading clothes washers with a MEF of 3.35. What design features and associated costs would be necessary to reach these efficiencies?

2.3 Do the design options and associated costs in the table s above also apply to the compact front

- and top

- loading product classes?

2.4 Please comment on any issues related to the following proposed changes to the DOE clothes washer test procedure and how they may impact the design options used to reach higher efficiencies for each product class, as appropriate:5

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- 16 2.4.1 Standby and Off Mode Power How would accounting for standby and off mode power impact the measured efficiencies of clothes washers? Would the inclusion of standby and off mode power affect the

d esign options currently used to reach higher efficiencies?

2.4.2 Steam Wash Cycles How would accounting for steam wash cycles affect the measured efficiency of clothes washers with this feature compared to the efficiency as measured using the existing tes t procedure? Is it appropriate to account for steam wash cycles in the measured efficiency of clothes washers? What percentage of your total shipments do clothes washers offering a steam wash cycle account for?

2.4.3 Self

- Clean Cycles

How would includin g self

- clean cycles affect the measured efficiency as compared to the current test procedure? What fraction of your total clothes washer shipments includes a

pre

- set self

- clean cycle, and how frequently do you recommend consumers use such a cycle?

2.4.4 Use Factors Will the proposed amendments to the use factors in the DOE test procedure significantly affect the measured efficiencies of any clothes washers? Are the proposed values consistent with actual consumer use? Can you provide any non

- proprietary d ata related to consumer use of different cycles?

2.4.5 Capacity Measurement Method Will the proposed capacity measurement method affect the design options you use to reach higher efficiencies?

2.4.6 Energy Test Cycle Definition How will the changes to th e energy test cycle definition change how your clothes washers are tested? Will this revised definition limit the design options available for reaching higher efficiencies?

3 CONVERSION COSTS

The MIA considers two types of conversion costs:

**•** Capital conversion costs are one

- time investments in plant, property, and equipment (PPE) necessitated by an amended energy conservation standard. These may be incremental changes to existing PPE or the replacement of existing PPE. Included are expenditures on bui ldings, equipment, and tooling.

**•** Product conversion costs are costs related research, product development, testing, marketing and other costs for redesigning products necessitated by an amended energy conservation standard.5

- C

- 17 3. 1 The tables below show the A HAM

- submitted average capital conversion costs for

a number of efficiency levels. Please indicate if your expected capital conversion costs vary from the AHAM

- submitted estimate. In the description column, DOE is intereste d in understanding the kinds of ch anges that would need to be implemented to production lines and production facilities at each efficiency level. Where applicable, please quantify the number and cost of new production equipment, molds, etc. that would be required to implement the specified design changes.

AHAM

- Supplied Standard Top

- Loading Capital Conversion Costs

MEF (ft 3 /kWh/cycle) AHAM Average Capital Conversion Costs ($mm) Actual Capital

Conversion Cost (if different) Description

1.40 $1.51

1.72 $34.98

1.80 $37.84

2.00 $41.76

2.26 $60.88

AHAM

- Supplied Standard Front

- Loading Capital Conversion Costs

MEF (ft 3 /kWh/cycle) AHAM Average Capital Conversion Costs ($mm) Actual Capital

Conversion Cost (if different) Description

1.80 $0.85

2.00 $0.86

2.20 $13.32

2.40 $19.46

2.89 $25.78

3.2 The tables below show the AHAM

- submitted average product conversion costs for a number of efficiency levels. Please indicate if your expected product conversion costs vary from the AHAM

- submitted estimate. In the description column, DOE is

interested in un derstanding such expenses as product development, prototyping, testing, certification, and marketing. In the description column, please describe the assumptions behind the estimates provided.

AHAM

- Supplied Standard Top

- Loading Product Conversion Costs

MEF (ft 3 /kWh/cycle) AHAM Average

Product Conversion

Costs Actual Product

Conversion Cost

(if different) Description

1.40 $0.93

1.72 $1.43

1.80 $3.62

2.00 $7.95

2.26 $12.845

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- 18 AHAM

- Supplied Standard Front

- Loading Product Conversion Costs

MEF (ft 3 /kWh/cycle) AHAM Average
Product Conversion

Costs Actual Product
Conversion Cost

(if different) Description

1.80 $0.53

2.00 $0.53

2.20 $3.10

2.40 $5.91

2.89 $11.48

3.3 Are the capital and product conversion costs described above applicable to the compact product classes as well? Would the magnitude and nature of the conversion costs differ for the compact product classes?

3.4 Please provide additional qualitative information to help DOE understand the types and nature of your inv estments, including the plant and tooling changes and the product development effort required at different efficiency levels.

4 MARKUPS AND PROFITABILITY

DOE estimated the manufacturer production costs for the two standard product classes of residential clothes washers. DOE assumed the other two compact product classes would have similar baseline markup values. DOE defines manufacturer production cost as al l direct costs associated with manufacturing a product: direct labor, direct materials, and overhead (which includes depreciation). The manufacturer markup is a multiplier applied to manufacturer production cost to cover non

- production costs, such as SG&A and R&D, as well as profit. It does not reflect a “profit margin.”

The manufacturer production cost multiplied by the manufacturer markup equals the manufacturer selling price. Manufacturer selling price is the price manufacturers charge

their first cust omers, but does not include additional costs along the distribution channels.

4.1 Please comment on the baseline markups DOE calculated as compared to your company’s baseline markups for the clothes washer product classes.

Residential Clothes Washer Baseline Manufacturer Markups by Product Class

Product Class Product Class Description Estimated

Baseline Markup Manufacturer Comments

or Revised Estimates

Top

- Loading, Compact Top

- loading with capacity less than

1.6 ft 3 1.22

Top

- Loading,

Standard Top

- loading with capacity greater

than 1.6 ft 3 1.22

Front

- Loading, Compact Front

- loading with capacity less than

1.6 ft 3 1.30

Front

- Loading,

Standard Front

- loading with capacity greater

than 1.6 ft 3 1.305

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- 19 4.2 One of the possible scenarios DOE uses to model impacts on industry profitability is the impact of commoditization of premium products. Because the market disruption caused by standards can alter the pricing of premium products, DOE is interested in understanding if efficiency is a feature that earns a premium. Within each product class, do markups vary by efficiency level? If yes, please provide information about the markups at efficiencies above the baseline in the tables below. Would these markups also vary for com pact product classes?

Estimated Standard Top

- Loading Markups by Efficiency Level

MEF (ft 3 /kWh/cycle) Estimated Markup Manufacturer Comments

1.40

1.72

1.80

2.00

2.26

Estimated Standard Front

- Loading Markups by Efficiency Level

MEF (ft

3 /kWh/cycle) Estimated Markup Manufacturer Comments

1.80

2.00

2.20

2.40

2.89

4.3 Would you expect changes in your estimated profitability following an amended energy conservation standard? If so, please explain why. Can you suggest any scenarios that would model these expected changes?

5 FINANCIAL PARAMETERS

5.1 In order to accurately collect information about clothes washer manufacturing, please compare your financial parameters to the GRIM parameters tabulated below.5

- C

- 20 Financial Parameters for Residential Clothes Washer Manufacturing
GRIM Input Definition Industry
Estimated

Value (%) Your Actual (If

Different from

DOE’s Estimate)

Income Tax

Rate Corporate effective income tax paid (percentage of earnings before taxes, EBT) 34.3

Discount Rate Weighted average cost of capital (inflation

adjusted weighted average of corporate cost of debt and return on equity) 8.0

Working Capital Current assets less current liabilities (percentage of revenues) 6.5

Net PPE Net plant property and equipment (percentage of revenues) 17.7

SG&A Selling, general, and administrative expenses (percentage of revenues) 11.3

R&D Research and development expenses (percentage of revenues) 2.2

Depreciation Amortization of fixed assets (percentage of revenues) 4.7

Capital Expenditures Outlay of cash to acquire or improve capital assets (percentage of revenues, not including acquisition or sale of business units) 2.7

Cost of Goods

Sold Includes material, labor, overhead, and depreciation (percentage of revenues) 83.0

6 ADDITIONAL IMPACTS

6.1 You previously indicated the following regulatory burdens: changes in refrigerants, outcome of Copenhagen, building codes (green building programs and LEED), management over product life (take

- back legislation), and RoHS regulations in California, Minnesota, and Canada. You additionally listed the DOE’s regulation of commercial clothes washers, clothes dryers, refrigerators and room air conditioners. Do these still represent regulatory burdens, and a re there any additional regulatory burdens at this time? What costs do you anticipate incurring to meet these regulations?

6.2 The impact of amended energy conservation standards on employment is an important consideration in the rulemaking process. Where are your residential clothes washer facilities that produce products for the United States located? Please also provide employment levels and total washer shipments at each of these facilities.

6.3 At what efficiency levels would you consider relocating current domestic production abroad?

6.4 Are you aware of any small businesses, niche manufacturers, or component manufacturers for which amended energy conservation standards would have a severe impact? If so, why?

6.5 Have any of your US facilities qual ified for grants available through the American Recovery and Reinvestment Act? Has your company reached the $75 million limit for efficient appliances under the Energy Improvement and Extension Act of 2008? How5

- C

- 21 many shipments of washers qualifying for a $2 50 production tax credit under the Energy Improvement and Extension Act do you anticipate manufacturing in 2010?5

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- 22 5

- C.3 INFORMATION REQUEST FOR COMPACT

- SIZE PRODUCT

CLASSES FOR RESIDENT IAL CLOTHES WASHERS

The United States Department of Energy (DOE) is current ly reviewing energy conservation standards for residential clothes washers, including the standards proposed

in the AHAM

- ACEEE Multi

- Product Standards Agreement (“Consensus Agreement”). In particular, DOE would like to understand the rationale for the prop osed efficiency standards for the top

- loading compact and front

- loading compact product classes.

1. Consensus Agreement Standard Levels

Table 1 shows the proposed standards in the Consensus Agreement.

Table 6 . AHAM

- ACEEE Multi

- Product Standards Agreement for Residential

Clothes Washers

Product Description New Standard Jan. 1, 2015 (MEF/WF) New Standard Jan. 1, 2018 (MEF/WF) Top

- Loading, Compact (less than 1.6 cubic feet capacity) 1.26 / 14.0 1.81 / 11.6

Top

- Loading, Standard 1.72 / 8.0 2.0 / 6.0

Front

- Loading, Compact (less than 1.6 cubic feet capacity) 1.72 / 8.0

Front

- Loading, Standard 2.2 / 4.5

Table 2 compares the Consensus Agreement standards for the compact product classes to the current DOE standard, as well as the efficiency levels of compact top

- loaders currently on the market.

Table 7 . Efficiency Levels for Compact

- Size R esidential Clothes Washers

Efficiency Level Source Efficiency Level

MEF WF
Top

- Loading, Compact

DOE Standard 0.65 none
Level 1 (currently on the market) 0.78 13.9

Level 2 (currently on the market) 1.00 12.7

Consensus Agreement, 2015 1.26 14.0

Consensus Agreement, 2018 1.81 11.6

Front

- Loading, Compact

DOE Standard 1.26 none
Consensus Agreement, 2015 1.72 8.05

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- 23 Questions:

**•** Top

- loading compact

o How were the standards for the top

- loading compact product class

established?

o What was the rationale for the tiered standards?

o Are you aware of any products on the market that meet the 2015

standards? 2018 standards?

o Within the top

- loading compact product class, what percentage market share do your company’s shipments represent?

o Do you foresee any potenti al changes in the competitive landscape for compact clothes washers due to the proposed standards?

**•** Front

- loading compact

o How were the proposed standards for the front

- loading compact product

class established?

o Are you aware of any compact front

- loaders on the market that meet the proposed standards? If not, do you foresee any entrants into this market in

the future?5

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- 24 2. Design Options and Costs for Achieving Proposed Standard Levels The inclusion of more stringent standards for top

- loading compact and front

- loading compact product classes in the Consensus Agreement implies that these standards are technologically achievable and economically justifiable. Because the proposed standards for the top

- loading product class represent a significant improvement over current standards, DOE would like to better understand how these higher standard levels can be

achieved. Table 3 shows the design options considered for standa rd

- size top

- loading

clothes washers.

Table 8 . Design Options for Standard

- Size Top

- Loading Clothes Washers

Design Options Applicable to Compact

Product Class?

More Advanced Controls Adaptive fill control (more accurate pressure switches) Temperature control (more accurate sensors) Water inlet valves (more accurate flow control)

Electronic controls

Accelerometers

Motor Improvements

More efficient motor Variable speed drive Higher spin speeds

Basket/Drum Modifications Basket shape modification

Stainless steel basket Larger capacity Stronger basket Agitator modification

Reduced Water Consumption Spray rinse Recirculation pumps Gray

- water rinse

Structural Improvements

Better suspension system

Out

- of

- balance detection

Operational Design Options Longer cycle times Lower water temperatures5

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- 25 Questions:

**•** What design options are available for the compact product classes to meet the higher standard levels?

**•** What design options are most likely to be used to reach the proposed 2015

standards? The 2018 standards?

**•** What are the average costs associated with meeting each incremental standard level? (See Table 4 )

Table 9 . Cost Associated with Meeting Each Incremental Efficiency Level

Efficiency Level Source Efficiency Level Incremental Cost ($/Unit) MEF WF

Top

- Loading, Compact

DOE Standard 0.65 none

Level 1 (currently on the market) 0.78 13.9

Level 2 (currently on the market) 1.00 12.7

Consensus Agreement, 2015 1.26 14.0

Consensus Agreement, 2018 1.81 11.6

Front

- Loading, Compact

DOE Standard 1.26 none

Consensus Agreement, 2015 1.72 8.0

**•** Are there any significant differences between product types or platforms ( e.g. stacked washer/dryer vs. portable top

- loading washer) that could affect the ability for a particular product type to achieve the proposed standard levels?

**•** Can the front

- loading compact efficiency standards be achieved assuming similar desig n options as “nearly compact” front

- loaders ranging from 1.6

- 2.4 cubic feet?5

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- 26 3. Consumer Utility DOE would like to better understand the unique consumer utility offered by compact

- size

clothes washers.

Questions:

**•** Does the market continue to demand clothes washers with capacity less than 1.6

cubic feet?

**•** Are the disparate compact top

- loading products considered substitutes for each other? Or does each distinct product type satisfy a unique niche within the market? ( e.g. stacked washer/dryer vs. portable top

- l oading washer)

**•** Would the proposed standards have any negative impacts on consumer utility of
compact

- size clothes washers?