May 29, 2012

By E

- Mail

Ms. Kathleen Hogan Deputy Assistant Secretary for Energy Efficiency
U.S. Department of Energy 1000 Independence Ave., SW Washington, DC 20585

- 0121

kathleen.hogan@ee.doe.gov

R e: AHAM Withdrawal of Support from Joint Petition

to Amend the Test Procedure for Residential Clothes Dryers
to Include Provisions Related to Automatic Termination Controls

Dear Ms. Hogan :

I am writing on behalf of t he Association of Home Appliance M anufacturers (AHAM) to
withdraw , effective immediately, our support at this time from the Joint Petition to Amend the Test Procedure for Residential Clothes Dryers to Include Provisions Related to Automatic Termination Controls, Docket No. EERE

– 2008

– BT

– TP

– 0010; RIN 1904

– AC02 and Docket No.
EERE

- 2011

- BT

- TP

- 0054 , RIN 1904

- AC63 (Sept. 8, 2011) ( the Petition)

.

AHAM represents manufacturers of major, portable and floor care home appliances, and suppliers to the industry. AHAM’s more than 150 members employ tens of thousands of people in the U.S. and produce more th an 95% of the household appliances shipped for sale within the U.S. The factory shipment value of these products is more than $30 billion annually. The home appliance industry, through its products and innovation, is essential to U.S. consumer lifestyle,
h ealth, safety and convenience. Through its technology, employees and productivity, the industry contributes significantly to U.S. jobs and economic security. Home appliances also are a success story in terms of energy efficiency and environmental protect ion. New appliances often represent the most effective choice a consumer can make to reduce home energy use and

costs.

As part of the agreement between AHAM and energy efficiency advocates on federal minimum energy conservation standards for five produc ts, including residential clothes dryers, and related test procedures, ENERGY STAR, and financial incentive provisions, AHAM and the advocates agreed that DOE should amend the clothes dryer test procedure to address the effectiveness of
automatic terminati on controls such as moisture and temperature sensor controls. In its final test procedure, however, DOE declined to adopt prop osed amendments to address automatic
termination controls. Accordingly, on September 8, 2011, AHAM and the advocates jointlyp 2 pet itioned DOE to amend the clothes dryer test procedure to accoun t for the effectiveness of
automatic termination controls. 1 DOE published the P etition in the Federal Register on October 11, 2011, and sought comments by December 12, 2011. See 76 Fed. Reg. 62644 (Oct. 11, 2011).

The P etition recommended that test procedure and standards revisions adopted in response to the petition take effect on January 1, 2015. The goal was to have a single round of standards and test procedure changes take effect on tha t date , and thus, the P etition requested that the test procedure
and rel ated standards amendments replace the final test procedure issued in January 2011 and the clothes dryer standards contained in the Direct Final Rule issued in April 20 11. Importantly, however, the P etition stated that in “order to give manufacturers adequate time to prepare for a revised test procedure and standards, we urge DOE to complete and finalize the test procedure and standards revisions as soon as possible, but no later than D ecember 31, 2011. . . . The timing suggested in this petition is contingent on DOE providing adequate lead

- in time for manufacturers to develop products that will comply with the revised standard per the revised test procedure that more effectively account s for automatic termination controls. In order to provide adequate lead

- in time, it is necessary that the test procedures and standards are completed and final no later than December 31, 2011 .” (emphasis added).

It is now the end of May 2012, five months after the Petition requested a complete test procedure and standards adjustment. Were a test procedure and accompanying standards adjustment to be published now that addressed automatic termination controls and became effective on January 1, 2015, the le ad

- in time would be significantly less than three years before the new standard would take effect. Thus, manufacturers would not have adequate time to prepare for the revised test procedure and standards. Accordingly, AHAM can no longer support the P etit ion at this time

. We have informed the advocates of this position.

I would be glad to further discuss this matter should you so request.

Best regards

,

Jennifer Cleary Director, Regulatory Affairs

CC: Ashley Armstrong Stephen L. Witkowski
Elizabeth K ohl
Sarah Butler

1 The P etition also served as joint comments in response to DOE’s Request for Information on Test Procedures for Residential Clothes Dryers, Docket No. EERE

- 2011

- BT

- TP

- 0054, RIN 1904

- AC63, 76 Fed Reg. 50145 (Aug. 12, 2011).