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

Re: 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 the Association of Home Appliance Manufacturers (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 than 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, 

health, 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 protection. 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 products, 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 termination controls such as moisture and temperature sensor controls. In its final test 

procedure, however, DOE declined to adopt proposed amendments to address automatic 

termination controls. Accordingly, on September 8, 2011, AHAM and the advocates jointly 
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petitioned DOE to amend the clothes dryer test procedure to account for the effectiveness of 

automatic termination controls.1 DOE published the Petition in the Federal Register on October 

11, 2011, and sought comments by December 12, 2011. See 76 Fed. Reg. 62644 (Oct. 11, 2011).

The Petition 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 that date, and thus, the Petition requested that the test procedure 

and related 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 2011. Importantly,

however, the Petition 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 December 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 accounts 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 lead-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 Petition 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 Kohl

Sarah Butler

 1 The Petition 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).