U.S. DEPARTMENT OF ENERGY

OFFICE OF ENERGY EFFICIENCY AND RENEWABLE ENERGY

TEST PROCEDURES FOR WATER HEATERS, RANGES, OVENS,

COOKTOPS AND MICROWAVE OVENS AND CLOTHES WASHERS

JULY 12 & 13, 1995

VOLUME II

JULY 13, 1995

EE-RM-94-230 COMMENT 0D
INDEX

P

Welcome and Opening Remarks - Marc LaFrance 

Manufacturer site visit - Marc LaFrance 

LBL Analysis Explanation - Peter Biermeyer 

Clorox Company 

Questions and Answers 

Load Size/Use 

Reduced Remaining Moisture Content 1

TUFs 1

Horizontal-Axis Market Acceptance 1

General Discussion 1

EE-RM-94-230 COMMENT 0D
3

1 PRO C E E D I N G S

2 (9:40 a.m.)

3 MR. LaFRANCE: Good morning. I'm

4 Marc LaFrance, the laundry rulemaking program manager

5 in the Office of Codes and Standards.

6 On behalf of the Department of Energy, I

7 thank you for taking the time to participate in this

8 public workshop, concerning the Department's second

9 round of rulemaking for minimum energy conservation

10 standards for clothes washers.

11 We will begin with introductions around the

12 room. Please state your name and the company

13 organization you represent.

14 I'm Marc LaFrance from DOE.

15 I guess we can progress to the right here.

16 MR. BIERMEYER: I'm Peter Biermeyer from

17 LB&L.

18 MR. ROSENQUIST: I'm Greg Rosenquist from

19 Lawrence Berkeley National Laboratories.

20 MS. RANDSE: I'm Jane Randse from General

21 Electric Company.

22 MR. JONES: Earl Jones, GE.

23 MR. HAWKINS: I'm Larry Hawkins from GE.

EE-RM-94-230 COMMENT 0D
4

1 MS. LaCLERIC: Beth LaCleric, GE.

2 MS. PRIOLEAU: Patton, Boggs, Clorox

3 Company.

4 MS. SEMMELMEYER: Florence Semmelmeyer,

5 Clorox Company.

6 MR. ZEIGHAMI: Ali Zeighami, Frigidaire.

7 MR. FOLLETT: Jeff Follett, Frigidaire.

8 MS. GRIENER: Linda Griener, with

9 Frigidaire Company, Washington office.

10 MS. RIGGETT:- Cheryl Riggett, Frigidaire.

11 MR. THIELE: Terry Thiele, Frigidaire.

12 MR. STILWELL: Dick Stilwell, Maytag.

13 MR. WASSON: Michael Wasson, Ashville (ph)

14 Incorporated.

15 MR. JACOBSON: Ron Jacobson, Proctor &

16 Gamble Company.

17 MR. MANTHEI: Bill Manthei, Speed Queen

18 Company.

19 MR. FREESMAN: Mark Freesman, Speed Queen

20 Company.

21 MR. ADAMS: Carl Adams, Department of

22 Energy.

23 MR. MILLER: Peter Miller. ......

.....

~ ..NRDC.

EE-RM-94-230 COMMENT 0D
5

1 MS. SMOZZO: Margaret Smozzo, ACEEE.

2 MR. STEPHENS: Charlie Stephens, Oregon

3 Department of Energy Policy Staff.

4 CURT RIECHMAN: Whirlpool Corporation.

5 MR. ANDERSON: Vince Anderson with

6 Whirlpool.

7 MR. STILES: Rich Stiles, Whirlpool

8 Corporation.

9 MR. MORRIS: Wayne Morris with AHAM staff,

10 Washington.

11 MR. WEIZEORICK: Jack Weizeorick, AHAM.

12 MR. OLDING: Bob Olding, AHAM.

13 MR. McCABE: Michael McCabe, Department of

14 Energy.

15 MR. KOMAR: BJ Komar, Energetics.

16 MR. KAO: Jim Kao, NIST.

17 MR. MARGOLIS: Eugene Margolis, Department

18 of Energy, general counsel's office.

19 MR. LEVY: Ed Levy, the same.

20 MR. LaFRANCE: Thank you. If you have not

21 already done so, please fill out the information

22 requested on the sign-in sheet, with Sandy Cooper.

23 The purpose of today's meeting is to

EE-RM-94-230 COMMENT 0D
6

1 discuss issues and gather information related to

2 energy efficiency standards for clothes washers.

3 Statements and information submitted here today, or

4 within 30 days, will be added to the public record,

5 and will assist the Department in developing a notice

6 of proposed rulemaking.

7 All statements submitted under issues to be

8 discussed and will be considered before the

9 Department publishes a notice of propose rulemaking.

10 As the presiding official, I will set the

11 guidelines or conducting the meeting and provide

12 other pertinent information. In order to obtain as

13 much relevant information as possible and to enable

14 interested persons to express their views, the

15 meeting will be conducted informally.

16 The focus of this meeting is on technical

17 information related to the energy efficiency of

18 clothes washers. There shall be no discussion of

19 proprietary information or other commercial matters

20 regulated by antitrust law.

21 Please keep side conversations to a minimum

22 to avoid interrupting a presenter. If a lengthy

23 private discussion is needed, please move outside the

EE-RM-94-230 COMMENT 0D
7

1 room.

2 It may be necessary to cut off discussion

3 on some topics to maintain the schedule. We will try

4 to allow some time at the end of the meeting to

5 complete discussion of these topics.

6 I encourage all persons present to

7 participate as much as possible to that the

8 Department may get a full spectrum of opinions on

9 these issues.

10 Please let me mention a few general items:

11 In keeping with the regulations of this

12 building, there is no smoking allowed in this room.

13 We will take a one-hour lunch break at a

14 convenient time, near twelve noon, as the schedule

15 permits.

16 This meeting is scheduled to end by four

17 p.m., or sooner, if all items have been completely

18 discussed. Items that have not been completely

19 discussed by four p.m., may be addressed in the

20 written statements.

21 Follow up or additional written statements

22 maybe submitted but not later than August 14th, 1995.

23 In approximately two weeks, the written

EE-RM-94-230 COMMENT 0D
8

1 transcripts of this meeting will be available for

2 inspection at the Department of Energy's Freedom of

3 Information reading room, located in room 1E190, down

4 this main hallway here.

5 Anyone wishing to purchase a copy of the

6 transcript may make arrangements with the court

7 reporter.

8 All written statements will be available

9 for public inspection in the Department of Energy's

10 Freedom of Information reading room. Their telephone

11 number is 202-586-6020.

12 Written statements should be provided to

13 the Department of Energy, as noted in the Federal

14 Register advance notice, November 14th, 1994.

15 We appreciate the time and effort you have

16 taken in preparing for this meeting and are pleased

17 to receive your comments and opinions.

18 Thank you for attending today's workshop.

19

20

21

22

23

EE-RM-94-230 COMMENT 0D
9

1 MANUFACTURER SITE VISIT

2 MR. LaFRANCE: First, the agenda item is to

3 give a little bit of a presentation on the feedback

4 from the manufacturer's site visit.

5 We're here today for the clothes washer

6 rulemaking public workshop. It's the Department's

7 first workshop during an official rulemaking, and

8 it's a process to improve our communications with our

9 stakeholders and customers.

10 This is the second round of rulemaking for

11 clothes washers. It was initiated by the Advance

12 Notice that was published last November. We received

13 considerable amount of comments in response to that

14 notice.

15 Today, we have a listing of all of the

16 comments on record at the information table.

17 We also have a few additional comments that

18 have not been added but will be added shortly.

19 We conducted an initial engineering

20 analysis, which we made available to the

21 manufacturers approximately over a month ago.

22 Then we conducted manufacturer site visits.

23 We visited the top five U.S. laundry manufacturers,

EE-RM-94-230 COMMENT 0D
10

1 which represented approximately 98 percent of the

2 market share. This entire effort, the manufacturer's

3 site visits and today's workshop, is a new, improved

4 method of exchange of information with industry to

5 get the best data that's possible so we can do a

6 thorough analysis.

7 Presently, we will develop a final

8 rulemaking schedule at the conclusion of this

9 workshop in the next few weeks, dependent upon what

10 happens today.

11 We're encouraging as much participation as

12 possible so that we can address the issues that are

13 remaining before we can go ahead with the additional

14 analyses and get to a point of Proposed Rule.

15 We also understand that this rulemaking is

16 causing uncertainty within the industry, as far as

17 what standard level will be imposed and what impact

18 it will have on various companies. We're aware of

19 that, and we're doing the best we can to minimize

20 that uncertainty problem, but obviously we have to do

21 a thorough job in the analysis to make sure it's

22 accurate.

23 Here's some of the matters that we're

EE-RM-94-230 COMMENT 0D
1 considering from result of the site visits:

2 The first element deals with, virtually all

3 the companies are developing significant improvements

4 in energy efficiency on some type of model.

5 Most companies have invested a significant

6 amount of capital, or will be, in the production

7 process, and they have, and that's the way they've

8 been able to maintain their productivity and maintain

9 costs as well.

10 The other part of the cost situation, which

11 we have to be careful today with proprietary

12 information, deals with the large distributors which

13 have been expressed to us. Over the last 10 or 15

14 years, the move from smaller distributors to larger

15 distributors has really made it a difference to the

16 industry, where now the distributor can control the

17 price a lot better than they could in the past.

18 So when people think about pricing, it

19 might not necessarily be controlled by the consumer

20 but more by the distributor to the consumer. So it's

21 a little bit of a concern to us, obviously, and we

22 need to investigate that more.

23 MR. FREESMAN: Marc, when you say

EE-RM-94-230 COMMENT 0D
12

1 "distributor," do you mean retailer?

2 MR. LaFRANCE: Well, retailer, right. The

3 large retailers that everybody is familiar with, I

4 would imagine.

5 Here's some of the feedback on the analysis

6 and assumptions that we presented on the initial

7 analyses, which are available on the docket. For the

8 people that haven't received them, the non9 manufacturers.

10 The first specific feedback we had was

11 dealing with the design option of reduced clearance

12 or the annulus in between the tub and the basket. We

13 had added this design option with reduced remaining

14 moisture content, the design option, and that is,

15 from what we've learned, technically not feasible, so

16 we've separated that in today's analysis, and Peter

17 will explain more about that.

18 We also got feedback that the 62 percent

19 baseline case of RMC is valid, and there is also a

20 little bit of concern from some companies that they

21 believe it's higher than that; but there's also a

22 question of whether or not they tested with larger

23 test loads versus smaller test loads, so, at this

EE-RM-94-230 COMMENT 0D
13

1 point, we still believe that 62 percent is valid.

2 We were told that the analysis did not

3 include gas dryers. When you consider the savings

4 for RMC in the dryer, we were only looking at the

5 electric dryers, so the analysis today, that Peter is

6 going to present, includes the gas dryers.

7 We also made an assumption that there would

8 be zero savings for any reduction in detergent.

9 There have been presentations that have said that the

10 detergent costs will decrease because of using less

11 detergent, and from everything we've learned, we

12 believe that the assumption should be that there will

13 be zero impact to detergent regardless of the level

14 of the wash water.

15 We also got feedback that the base case for

16 the manufacturer's cost is low, and we were able to

17 get a hold of some public data that generated a

18 higher manufacturer cost which, for the analysis

19 point, has resulted in a reduced markup rate.

20 That reduced markup rate will make the

21 engineering analyses look more cost-effective, or the

22 design options look more cost-effective. However, on

23 a manufacturer's impact analysis, it'll make things

EE-RM-94-230 COMMENT 0D
14

1 won't look as promising because of the impact to the

2 manufacturer.

3 There's also some sensitivity analysis

4 that's included in the analyses today for higher and

5 lower markups. I realize we can't really talk about

6 markups today with the situation of the companies,

7 but we can always discuss that in confidential

8 meetings or in confidential statements if need be.

9 There was also talk about the payback and

10 why we use the simple payback, and that was something

11 that was provided in the legislation to us about the

12 presumption of economic justification, so that's why

13 we used that.

14 Some feedback on consumer impact issues:

15 We believe there will not be an impact to

16 the wash performance or fabric care for horizontal

17 access to clothes washers.

18 This was not a unanimous opinion, but from

19 what we've learned, we believe, at this point in

20 time, there will not be an impact to the current

21 level of performance with the.traditional clothes

22 washers.

23 We also believe that the loadingEE-RM-94-230 COMMENT 0D
15

1 accessibility problems can be overcome by unique

2 design characteristics that any particular

3 manufacturer chooses to implement in their new

4 designs.

5 One of the concerns we have is the initial

6 purchase price for horizontal axis clothes washers.

7 We believe it will be considerably higher than the

8 existing retail price on a percentage basis. This is

9 somewhat of a concern to us, and we're looking for

10 information or opinions on- how to assess that

11 potential impact to a consumer.

12 Presently, we do manufacturing analysis and

13 consumer analysis, which takes into account increased

14 price results and reduced sales, and that type of

15 thing. I'm sure you're all familiar with our past

16 work in that area, and the previous TSF.

17 But we're looking for any new information

18 that you might have that could help us in addressing

19 that potential problem.

20 We are also looking for additional

21 information for the potential energy savings of

22 vertical-axis clothes washers.

23 We've also received, which is not reflected

EE-RM-94-230 COMMENT 0D
16

1 in the analysis that you have today, additional data

2 from AHAM regarding some of these design options, and

3 we can talk about that a little bit in today's

4 meeting when we discuss some of the issues, but I

5 guess there's still a concern.

6 Right now, we'd like to learn what are the

7 potential savings with automatic fill control,

8 adaptive fill control, and is there any other

9 technology that is available that could save

10 significant amounts of energy in a vertical-axis

11 machine.

12 My last slide deals with request for

13 additional manufacturer impact. We need to conduct a

14 manufacturer analysis, and it's dependent upon

15 primarily proprietary and confidential information

16 from manufacturers.

17 LBL has distributed a survey request with a

18 confidentiality agreement. At this point, we have

19 not received any responses. We have received a few

20 number of questions regarding the survey, but it is

21 really imperative that we obtain feedback from the

22 industry to do a thorough analysis. We believe this

23 is very important.

EE-RM-94-230 COMMENT 0D
17

1 There is also, depending on what standard

2 level we were to impose, we have a concern about the

3 lead time for manufacturers would be a possible point

4 that we could change from what's been established for

5 other products that's been longer than three years,

6 to justify for the manufacturer analysis for a

7 particular standard level.

8 So there's quite a few things that we need

9 to look at, so we really encourage people to

10 providing that confidential information to LBL, and

11 the Department does not get that information, so will

12 not become part of a FOIA request because it's

13 specifically set up with just LBL and not us.

14 That's all, and we'll move into the next

15 part.

16 MR. JONES: Marc, let me ask you. How are

17 you looking for feedback from the comments you just

18 made, or are you looking for feedback?

19 MR. LaFRANCE: We definitely are looking

20 for feedback. I think, at this point, if we talk

21 about every issue, it could take probably quite some

22 time.

23 Once Peter finishes his presentation and

EE-RM-94-230 COMMENT 0D
18

1 any individual presentations from organizations, at

2 this point, I'm only aware of one presentation from

3 the Clorox Corporation. If anybody else wants to

4 make presentations, though, there's plenty of time

5 available on the agenda. After those presentations,

6 then we'll open it up towards specific questions.

7 Obviously, you can ask questions right now

8 if you have a quick question, but if it's a lengthy

9 question, maybe we should just hold off until the

10 latter part of the agenda.

11 We know that the presentation part of this

12 agenda is rather large, and that's going to be

13 significantly reduced.

14 For time constraints, this whole workshop

15 may be significantly speeded up, where we might not

16 take a lunch break, if people agree and depending on

17 how things are going.

18

19

20

21

22

23

EE-RM-94-230 COMMENT 0D
19

1 PETER BIERMEYER

2 LAWRENCE BERKELEY LABORATORIES

3 MR. BIERMEYER: I'm Peter Biermeyer from

4 Lawrence Berkeley Laboratory. You notice we just

5 changed our mind.

6 MR. LaFRANCE: Excuse me, real quick,

7 Peter. I forgot to mention one thing.

8 Also, today, when you speak, you need to

9 say your name and the organization that you

10 -represent, just for the court reporter.

11 The previously discussion was from

12 Earl Jones, General Electric Corporation.

13 MR. BIERMEYER: I'll start with just a

14 quick overview.

15 Oh, by the way, you have, or most of you

16 have, copies of this, and some of the print will be

17 very small. I'm expecting people to kind of follow

18 along.

19 MR. LaFRANCE: Actually, they don't. We

20 need to pass it out. Sorry.

21 MR. BIERMEYER: .They don't. Okay. Well,

22 pass that out.

23 The first part is sort of a general list.

EE-RM-94-230 COMMENT 0D
20

1 Basically, I'm just like to say where we've been.

2 The first thing at LBL what we do is we try to gather

3 some data from manufacturers. This usually takes

4 place through AHAM. We send out questionnaires, they

5 send back information.

6 Then what I did is, I did an initial

7 engineering analysis, where I take AHAM data and I

8 combine it. As Marc mentioned, that's been sent out

9 to people. It's publicly available.

10 After looking at that, we have some more

11 questions, so we asked for some more data.

12 While waiting for that, Marc, myself, and

13 some other people from DOE, made all plant visits, as

14 he talked about.

15 After that, what I did is, we revised the

16 analysis. We were going to incorporate the new

17 information from AHAM. I just got it last Friday

18 because I didn't have time to do that. But what I

19 did is, we made some adjustments to the analysis.

20 The new data, as I said, has been sent to

21 us, and that will be used in future analysis, and

22 here we are at the workshop today.

23 Again, this is a little more detail,

EE-RM-94-230 COMMENT 0D
21

1 nothing new, really. When we sent out a

2 questionnaire to AHAM, they responded by giving us

3 information based on two different test procedures:

4 The existing DOE state procedure and a test

5 procedure based on something the AHAM came up with.

6 At the time it was Revision 6; they since then made

7 some changes.

8 So I took those two sets of data, and I

9 analyzed it four different ways. Basically, as they

10 came directly from AHAM, basically, without a

11 modified energy factor, and then I used the same data

12 and added in the energy used to dry the clothes after

13 it comes out of the washer, and came up with AHAM,

14 with a modified energy factor, and a DOE test

15 procedure with a modified energy factor.

16 Let me go over the changes that were made.

17 I'll call this the Revised Analysis.

18 The first four were sent, as Marc said, to

19 all the manufacturers. This is called the Initial

20 Engineering Analysis. Just to keep everything

21 separated, I'll call this the Preliminary Analysis.

22 If you're not familiar with it, it'll be

23 explained a little bit further on.

EE-RM-94-230 COMMENT 0D
22

1 But we have a dryer use factor. For the

2 initial analysis, it was .8. AHAM had used .83. My

3 preliminary analysis is .844, and that's just the

4 ratio of washer cycles per year compared to dryer

5 cycles per year.

6 We also made a change in the water inlet

7 temperature. In the DOE test procedure, it's 140

8 degrees. The AHAM data that I received from AHAM it

9 was 130 degrees. We adjusted that to 105, using

10 calculations.

11 There was also some comment that tighter

12 tub tolerance would be better called tighter tub

13 clearance. I think everyone, when they answered the

14 questions concerning tighter tub tolerance design

15 option, they had in mind tighter tub clearances, just

16 a better description I think of what we were all

17 doing.

18 As Marc mentioned, in the initial analysis,

19 I had tighter tub clearance combined with lower

20 remaining moisture content, and we got a lot of

21 comments that these aren't very compatible because

22 one way to get lower remaining moisture content is to

23 use higher spin speed.

EE-RM-94-230 COMMENT 0D
23

1 To use higher spin speed, the annulus can't

2 be any smaller because you have problems with the

3 dryer drum. So that seems to be pretty universal

4 among all the manufacturers.

5 We added payback and life cycle costs,

6 assuming gas dryers as well as electric dryers. We

7 were asked to do that.

8 We changed the manufacturer retail price

9 markup to 1.7, and we also did some analysis assuming

10 different markups. Then, also, there were some minor

11 math corrections from the initial analysis.

12 MR. JONES: Peter, what was the basis for

13 the change in the assumptions on markup?

14 MR. BIERMEYER: Well, what we did is --

15 actually, I was going to get into that.

16 We got some information on manufacturer

17 costs, and we had some information previously from

18 retail costs for baseline, and we basically just

19 divided one into the other to come up with the

20 markup.

21 There's probably some difference of opinion

22 as to how that should be done.

23 The information that I just actually have

EE-RM-94-230 COMMENT 0D
24

1 received from AHAM last Friday includes some

2 additional data on the following design options.

3 Originally, what AHAM does normally is they

4 send us energy costs and energy savings of different

5 design options with respect to the baseline. What

6 LBL does is they combine them.

7 Sometimes when you do that, it can be made

8 more accurate by assuming it's combined already and

9 then getting information from the manufacturers.

10 There was also some disagreement as to what

11 improved fill control meant. Some people considered

12 it one design option, some people considered it be

13 something else, so that had to be clarified and split

14 into different design options.

15 To get into a little bit of the detail

16 where some of the numbers came from in the

17 engineering analysis:

18 The cost data is from the response to the

19 questionnaire we sent out, and AHAM compiles those

20 using shipment weighted averages and sends those to

21 us. That's where the costs came from.

22 There's where we got the markup, 1.7. We

23 used the retail price of $383, which was submitted

EE-RM-94-230 COMMENT 0D
25

1 with the initial engineering analysis that we got

2 from AHAM. We got some marketing costs information

3 based on AHAM average sales and gross margin from ADL

4 report. That turned out to actually be 1.66. I

5 rounded it to 1.7.

6 Then working backwards, or dividing 383 by

7 1.87, you get $225.

8 Cycles per year, DOE, was 416. DOE

9 proposed is 392 cycles per year.

10 Fuel prices are based on the annual energy

11 outlook. Those are 1994 dollars projected into Year

12 2000. This was based on the 1994 projections.

13 There's probably new numbers out now, so it may be

14 revised slightly.

15 Water and sewage cost is based on Ernst &

16 Young data base. Al Diderman of Seattle water

17 department weighted it for population to get a more

18 accurate number. That's where we got that from.

19 Clothes washer life is 14.1 years. That

20 was used in the previous TSD and, reading that, it

21 said it got it from AHAM, so I have to believe it.

22 Water efficiencies: Also from DOE test

23 procedure.

EE-RM-94-230 COMMENT 0D
26

1 Water heater type: This was supplied along

2 with the other data from AHAM before the initial

3 engineering analysis.

4 Clothes dryer type: This is something you

5 haven't seen before. We've been asked to look at

6 both gas and electric dryers. I got the fraction of

7 clothes dryers that are electric and gas from just

8 recently submitted, beginning this month, and results

9 from the dryer questionnaire. They had the sales of

10 gas dryers and-the sales of electric dryers.

11 MR. JONES: Peter, what did you do by way

12 of -- what does that say about installed base? What

13 information do you have about that?

14 MR. BIERMEYER: I don't have that

15 information. I just have the -- well, I just did

16 this as a quick number. If you have information on

17 the installed base --

18 MR. JONES: Yes, but your assumption here

19 is that --

20 MR. BIERMEYER: This is just based on

21 sales.

22 MR. JONES: In 1990 what?

23 MR. BIERMEYER: This is the most recent

EE-RM-94-230 COMMENT 0D
27

data that AHAM sent me, so I guess it's 1994.

Wayne Morris could probably answer that better than I

could.

MR. JACOBSON: In studies that I have done,

just taking the AHAM data, if you go back and look at

the last 10 years, that ratio has not changed more

than maybe 1 or 2 percentage points over the entire

time frame, analyses that I have done. It probably

represents installed base, in other words.

MR. BIERMEYER: Remaining moisture content:

We used a baseline reference, as Marc said, of 62

percent. That's also from AHAM.

Now, in the initial engineering analysis

and subsequent analyses, a couple of general

assumptions were made:

There weren't any differences load handling

capacity of the different -- small differences in

drum sizes. It was about 2.9 cubic feet; for a

vertical-axis was 2.7 something; for horizontal, I

assume they were comparable. I didn't adjust the

energy numbers for those differences.

The next paragraph there-had some other

changes, just basically common sense type things.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

EE-RM-94-230 COMMENT 0D
28

1 If there was an option that had improved

2 motor efficiency but it showed the water changed by a

3 lot or something, said, well, this doesn't seem

4 right; that's just the statistical reason for that,

5 and so I adjusted it just so things could make sense

6 on a common sense basis. That's what those are.

7 There were some design options that I kind

8 of separated out and looked at individually.

9 These usually had either very high paybacks

10 -or long paybacks, or they had very little effect or

11 some manufacturers said they didn't have any effect.

12 The reason for this is usually we would

13 include those in, but we wanted to get some numbers

14 very quickly, wanted to simplify it, so we take the

15 major, basically, design options. That would really

16 have an effect on the analysis and concentrated on

17 those.

18 I also put sud savers out at the bottom of

19 my table, and there is a table in there and I'll get

20 to that later.

21 Again, with the.preliminary analysis now,

22 which is a revised version of the initial analysis, I

23 only did that for the combination of AHAM, including

EE-RM-94-230 COMMENT 0D
29

1 lower remaining moisture content. Another way of

2 saying that is with modified energy factor.

3 The reason for that was also a time

4 constraint, basically, and also because, in talking

5 to manufacturers, that's the one they were

6 concentrating at, because we initially did this four

7 different ways, and that's a lot to look at and

8 concentrate on, so we've sort of picked one that

9 would probably be most likely closer what the final

10 version would look like and concentrated on that.

11 Typically, when we do the analysis, we sort

12 things by payback and cumulative payback. There were

13 a few exceptions for other reasons, such as, in some

14 cases -- well, in this case, actually -- I separated

15 things into different paths: A vertical path, into a

16 horizontal path, because some of the costs could be

17 different for the same design option, depending if

18 you're starting out with a vertical base or a

19 horizontal base.

20 The baseline numbers are originated from

21 Wayne Morris of AHAM, an energy factor of the same

22 class.

23 I'll kind of ao over this sort of auicklv

EE-RM-94-230 COMMENT 0D
30

1 because I'll be here forever if I don't.

2 Basically, what I have on the next couple

3 of overheads is how I went through the design

4 analysis, step by step, for each design option. The

5 basic idea is you don't want to count the same energy

6 twice, so you make adjustments as you go along. Most

7 of the time it's taking certain ratios and

8 multiplying it by the last design option to get some

9 adjusted numbers.

10 So, as I was saying before, basically, I

11 split this latest revision into three different

12 sections, really.

13 The first one is vertical-axis; the second

14 one is horizontal-axis. In this case, the lower

15 remaining moisture content was actually a faster

16 payback than the horizontal-axis design. Since the

17 baseline was a vertical-axis, I'd be adding lower

18 remaining moisture content to vertical, and then

19 going to horizontal.

20 To solve that problem, I just put the

21 horizontal first and then added remaining moisture

22 content on this path.

23 So on the last two paths of design options,

EE-RM-94-230 COMMENT 0D
31

1 you'll notice I didn't include tighter tub clearance

2 because I didn't want to combine that with lower

3 remaining moisture content because of some problems

4 that could happen with higher spin speed.

5 So I still wanted to include that design

6 option, so I started a separate path, using these

7 three design options that don't have any lower

8 remaining moisture content.

9 That brings me to calculations. I don't

10 think this is anything really new.

11 Energy factor is a combination of hot water

12 energy and mechanical energy. To get a modified

13 energy factor, you included the dryer energy required

14 after the clothes are through being washed.

15 Moisture removal energy, I've mentioned,

16 was based on 62 percent remaining moisture content,

17 and I've got some more equations on that later.

18 What you see here is the equation I

19 actually used for the preliminary analysis in

20 determining the amount of energy needed to completely

21 dry the clothes after they've been washed.

22 We have something called the dryer

23 utilization factor. It's the ratio of dryer cycles

EE-RM-94-230 COMMENT 0D
32

1 to clothes washer cycles per year.

2 We used the maximum clothes load for 2.9 to

3 3 cubic foot washer; maximum load is 12.1 pounds.

4 That's from the AHAM proposed test procedure.

5 We used an average load fraction of .52,

6 and that originated from some P&G data.

7 Basically, I have the equation there. We

8 used .5 kilowatt hours per pound of moisture. I

9 think most of the manufacturers have seen this.

10 Here again, we changed the dryer use factor

11 from what I initially had used, .8 to .844. There

12 are some examples there.

13 In the initial analysis, I didn't look at

14 gas dryers at all, and I had someone ask me to also

15 look at gas dryers to see what the savings would be

16 in the real world.

17 So I didn't want to make the assumption

18 that gas dryers have exactly the same efficiency as

19 electric dryers, because I didn't know that to be

20 true. So I thought I'd come up with an adjustment

21 factor.

22 The way I did that is, I have just recently

23 gotten, a couple weeks go, again from AHAM, dryer

EE-RM-94-230 COMMENT 0D
33

1 information from the questionnaires that we sent out.

2 These are just some numbers that they sent me. These

3 are based on 70 percent remaining moisture content,

4 as the starting point.

5 I just took the ratio of the energy, and

6 converted everything.to kilowatt hours; took the

7 ratio of gas to electric and made that the correction

8 factor. Multiplied that by the kilowatt hours per

9 pound for an electric dryer to come up with kilowatt

10 hours per pound for a gas dryer.

11 It was also interesting to notice on this,

12 after I divided the total energy by 7 pounds, which

13 is the test load for a dryer, it's .32, .35, it

14 wasn't .5 kilowatt hours per pound, and that's what

15 we're using. So maybe someone can answer that.

16 Hot water inlet temperature adjustments:

17 As I had mentioned at the beginning, we wanted to go

18 from 130 degree hot water inlet to 135 degree hot

19 water inlet, and we wanted to make that adjustment

20 with the data we had without having to go back and

21 retest everything.

22 There are several ways of doing this.

23 There's one equation. Basically, if you

EE-RM-94-230 COMMENT 0D
34

1 multiply it by the initial value, the AHAM value

2 received before any kind of additions or

3 combinations, multiply that by 75 over 70. It is

4 equivalent to what you see there. That will give you

5 a new hot water energy.

6 So, basically, I just made adjustments to

7 the hot water energy, adjusted that upward.

8 MR. LaFRANCE: Basically, it increases the

9 energy consumption by 7.14 percent.

10 MR. BIERMEYER: I also did this from a

11 completely different perspective, and I got basically

12 the same numbers, so I did that several different

13 ways. I did those calculations several different

14 ways.

15 For the thermostatic mixing valve, at the

16 bottom of the overhead here, basically I said the hot

17 water energy use for a thermostatic mixing valve at

18 135 was the same as it was at 130 degree inlet, so

19 I'm basically saying whatever you tempered the water

20 temperature down to, stayed the same, so this option

21 should show increased energy savings because of that,

22 because you're starting with higher water

23 temnerature. --- r--

EE-RM-94-230 COMMENT 0D
35

1 That brings me to the engineering analysis

2 tables. Since we keep adding more information to

3 these tables, they got a little bit longer. Now

4 they're four pages long. These are also on the back

5 of your handout.

6 The first page, basically, is information

7 on costs, energy, dryer energy and water.

8 The second page contains cumulative payback

9 calculations.

10. The third page is the intermediate step

11 that I used to get payback and life cycle costs. On

12 that page, I calculate all of the annual operating

13 costs.

14 Then the fourth page is life cycle cost

15 calculations.

16 By the way, don't pay any attention to

17 where it says View 12 or View 8. There were some

18 last minute changes, and that number doesn't

19 necessarily correspond to my overhead, so you're not

20 missing any pages.

21 I have examples here for dryer energy

22 required and some examples for annual operating

23 costs. I sort of talked about those. If there are

EE-RM-94-230 COMMENT 0D
36

1 further questions, I can go into further details

2 later.

3 MR. MORRIS: Could you explain the use of

4 the fuel price multiplier?

5 MR. BIERMEYER: Sure. What that is, that's

6 the number that was invented by Lawrence Berkeley

7 Lab. One of its first uses was to make some

8 adjustments in fuel price for water heater analysis.

9 The reasoning behind those numbers are, in

10 places where there are electric water heaters, or the

11 electricity price is lower than say the national

12 average, and that's why people have more electric

13 water heaters in a certain area than gas water

14 heaters.

15 So this was an attempt, and I don't have

16 all the details but analysis was made of this, and so

17 that adjusts the price closer to what it really is

18 out in the real world for whatever appliance you're

19 looking at.

20 So like for an electric water heater,

21 people would more likely have an electric water

22 heater where electricity prices are low and that's

23 why that multiplied, for example, is .9.

EE-RM-94-230 COMMENT 0D
37

1 The gas was -- fuel price multiplier was

2 1.01. It didn't seem to make much difference.

3 The way I used them here, to simplify

4 things, was just to multiply all of the gas prices by

5 the gas fuel price multiplier, all the electricity

6 prices by the electric fuel price multiplier.

7 MR. LaFRANCE: Also, if you look at the

8 footnotes in the analysis, you can see that we used

9 like .09, you just said, Peter.

10 MR. BIERMEYER: Right.

11 MR. LaFRANCE: And that actually drops your

12 price so it makes things less cost-effective for

13 electricity, so it's more conservative analysis is

14 what it comes down to.

15 MR. BIERMEYER: Here's the first page of

16 the preliminary engineering analysis. What you

17 basically see is this area over here. This is all

18 vertical-axis, with different design options, which

19 is why it's called the vertical-axis path.

20 This row here, this is all based on

21 horizontal design.

22 Baseline at vertical; this is horizontal.

23 It's all horizontal design after that.

EE-RM-94-230 COMMENT 0D
38

1 This over here is where I look at all of

2 the design options, without remaining moisture

3 content, so I could get tighter tub tolerance.

4 Over here are other ones that they either

5 had very high payback, or there's two here -- auto

6 fill and adaptive control, which I just got some

7 information on that. I didn't have it at the time I

8 made this chart.

9 I think all of the other headings are

10 fairly explanatory.

11 The energy factor you see next to clothes

12 container doesn't include dryer energy. The modified

13 energy factor does.

14 The second page of the analysis has all of

15 the paybacks. This time, we looked at more

16 combinations.

17 We have electric dryer with electric water

18 heater, electric dryer gas water heater, and then we

19 took proportions of electric and gas water heaters

20 and combined them with electric dryer to get numbers

21 and all these different combinations.

22 So it's just taking proportions of what's

23 out into the field, and we talked about that before.

EE-RM-94-230 COMMENT 0D
39

1 This page, I don't believe I had these

2 numbers on the initial analysis. This is sort of the

3 intermediate step, where I calculate the dollars per

4 year for different energy use.

5 That includes the hot water energy, the

6 machine energy, the dollars per year for water use

7 and disposal; dollars per year for electric dryer,

8 gas dryer, combined dryer, and all the different

9 combinations of dryers with either gas or electric

10 water heaters.

11 MR. POPE: Excuse me, Peter.

12 MR. BIERMEYER: Yes.

13 MR. POPE: Are the water costs figured into

14 the payback numbers?

15 MR. BIERMEYER: In the payback? Yes, they

16 are. The way that works is, I do page one, then I do

17 page three, where I calculate all the dollars, annual

18 operating costs, and that goes into both payback and

19 life cycle costs.

20 The next page I have here is the life cycle

21 cost page. They do all the combinations here.

22 Basically, the same thing as payback, except for life

23 cycle cost, and I believe I showed you that equation.

EE-RM-94-230 COMMENT 0D
40

1 The 2 percent, 6 percent, and 15 percent

2 you see at the top are the three different discount

3 rates. Basically, the one to concentrate on is

4 probably the six percent one, and the two percent and

5 the fifteen percent are sort of a sensitivity

6 analysis.

7 I'll skip over the footnotes.

8 I didn't plot all the different

9 combinations that you see on the tables, but here's

10 an example of the electric water heater with electric

11 dryer. What we have here is three curves. This is

12 the six percent discount rate curve, or sets of

13 curves. This is both two percent and fifteen

14 percent.

15 The numbers you see here refer to the

16 design options that correspond to the numbers on your

17 table.

18 So, basically, here this smaller curve that

19 goes to six has the vertical axis path. The longer

20 curve you would see down here is the horizontal-axis

21 path.

22 I didn't include the one with tub tolerance

23 without remaining moisture content, but the points

EE-RM-94-230 COMMENT 0D
41

1 tend to be up in this area, very tightly packed, and

2 I thought it would just confuse the chart, so I left

3 it off.

4 Here's the same type of chart, life cycle

5 cost versus modified energy factor. This was for

6 electric water heaters and gas dryer, so slightly

7 different but in some ways similar.

8 This chart here shows combined water

9 heaters and combined dryers. So these numbers come

10 basically right off the chart. We're looking at

11 combinations of both electric water heaters, gas

12 water heaters, gas dryers, and electric dryers, and I

13 took the proportion of each and all the combinations

14 and came up with this chart here. So this probably

15 reflects what is sort of an average of what's out in

16 the field.

17 This chart here shows payback versus

18 modified energy factor with the clothes washer

19 lifetime represented by a dotted line at the top.

20 This is cumulative payback. That's also

21 data straight from the tables.

22 MR. STILWELL: This was based again on

23 combined?

EE-RM-94-230 COMMENT 0D
42

1 MR. BIERMEYER: The last chart I showed

2 you, that was a combination water heater and dryer.

3 Yes. So it takes into account both gas and electric

4 dryers, gas and electric water heaters. Using those

5 fractions of each that I showed you earlier, a

6 certain percentage of gas, a certain percentage of

7 electric.

8 This chart, the last chart, is the summary

9 of some analyses with different markups, and so you

10 can see how -- I wanted to get it all one page, so I

11 don't have all of the different combinations here,

12 but it gives you an idea of what effect the different

13 markups have on life cycle costs and payback.

14 Whether or not you think they're large or

15 not, there's probably a large difference of opinion

16 there.

17 That's all I have. Thank you.

18 MR. LaFRANCE: Thank you, Peter.

19

20

21

22

23

EE-RM-94-230 COMMENT 0D
43

1 MR. LaFRANCE: At this time, we'll ask the

2 Clorox Company to present their presentation.

3 CLOROX COMPANY

4 MS. SEMMELMEYER: I'm Mary Semmelmeyer, and

5 I'm with the Clorox Company. I would like to thank

6 you for having the opportunity to expand a little bit

7 on the comments that we submitted, and some good

8 news. On the agenda, there is an hour and a half

9 slotted for this. I will not take that long.

10 We'll be reviewing some facts about bleach

11 and the energy design options;

12 One option that we're promoting that we

13 believe is a potential energy saver;

14 A few comments on utility to the consumer;

15 and,

16 Recommendations.

17 First, some facts about bleach: Sodium

18 hypochlorite is the active ingredient in Clorox

19 liquid bleach. The chemical composition is one

20 sodium molecule, one oxygen molecule, and one

21 chlorine molecule, NaOCl.

22 Common names for Clorox liquid bleach

23 include regular household bleach, and then also

EE-RM-94-230 COMMENT 0D
44

1 chlorine bleach.

2 Because of this last one, chlorine bleach

3 is often confused with raw chlorine, and that's not

4 the case. Similar to table salt, which is sodium

5 chloride, 1 sodium and 1 chlorine molecule, sodium

6 hypochlorite bleach has the chlorine in the formula

7 but it is not chlorine.

8 47 percent of all U.S. households use

9 bleach in their laundry, and this is because

10 consumers recognize its benefits: stain removal,

11 cleaning and whitening and also disinfectancy.

12 Clorox liquid bleach is one of the most

13 cost-effective and fast working disinfectants

14 available worldwide. It kills a variety of

15 microorganisms, including E. coli, Salmonella, the

16 organisms that cause cholera, and it also disinfects

17 common cold and flu germs in the home.

18 Very well known for being able to kill

19 microorganisms in the home.

20 It is also safe for the environment. We'll

21 go into that a little bit more.

22 Sodium hypochlorite bleach is derived from

23 saltwater and breaks down into saltwater during use.

EE-RM-94-230 COMMENT 0D
45

1 This is a little known fact. Starting out with

2 saltwater, you run a current of electricity through

3 it, and this generates chlorine, and then also sodium

4 hydroxide for caustic.

5 These two are separated, and then the

6 chlorine is bubbled through the sodium hydroxide in a

7 solution with water and then, through a chemical

8 reaction, this produces sodium hydroxide bleach.

9 By controlling the level of sodium

10 hydroxide and the amount of chlorine that is bubbled

11 through it, you can produce a 5.25 percent, which is

12 what we sell for regular household bleach, and

13 there's a hundred percent reaction to chlorine, goes

14 to completion.

15 This 5.25 percent solution is then used in

16 the home laundry where it reacts with soils, water

17 harness, stains in the wash, and has very, very rapid

18 degradation -- 95 to 98 percent of the bleach does

19 degrade back into salt water in the wash, and then

20 any remaining products are removed during waste water

21 treatment. So it's back to salt water again.

22 It's a very environmentally friendly

23 process. It's a very environmentally friendly

EE-RM-94-230 COMMENT 0D
46

1 product.

2 It's the first product that the American

3 Red Cross will call for if there's a disaster, like

4 Hurricane Hugo is one; the Loma Creator earthquake in

5 California; North Ridge earthquake at Southern

6 California, and they need the bleach because they use

7 it to purify the drinking water for people.

8 If boiling water is not an option, this

9 gets water out to people that's safe for consumption.

10 One other thing to add: During the

11 circular process, no dioxins are formed;

12 No by-products that have the ability to

13 bioaccumulate to form; and,

14 It is not nontoxic to aquatic life.

15 I just want to point out real quick -- I

16 know you're all familiar with this already -- the

17 design option section. This is what I reviewed in

18 coming up with the idea for a new design option that

19 can save energy.

20 The list for clothes washers includes a

21 variety of options that you're familiar with.

22 We believe that a sodium hydroxide bleach

23 dispenser should be added to that list. Dispensers

EE-RM-94-230 COMMENT 0D
47

1 are already an option on many of today's washers.

2 Some models will carry it.

3 It can potentially provide energy savings

4 because it's viable in cold water -- bleach usage is

5 viable in cold water -- or unheated water, is another

6 term.

7 Basically, your stain removal performance

8 doesn't decrease as the water temperature declines.

9 A second option for saving energy would be

10 that rewashing is less likely. This is not

11 necessarily an issue in today's machines, but in new

12 machines where performance might drop with the new

13 energy factor, this could become an issue.

14 So you would use less energy by only

15 washing your clothes once, and you would use less

16 energy by having a situation where you wouldn't need

17 to heat the water.

18 Another benefit is that soil removal is

19 high with bleach in very cold water.

20 I'm going to present three charts from a

21 study that I did comparing two products: a liquid

22 detergent and then the same liquid detergent with

23 Clorox liquid bleach.

EE-RM-94-230 COMMENT 0D
48

1 I used a liquid detergent because of the

2 wash temperatures that I was looking at. I didn't

3 want any problem with solubility in colder water that

4 you might experience with a powder.

5 So on this particular chart I'm looking at

6 oxidant sensitive stain, which includes red wine,

7 ink, berry, grape juice, coffee, tea, and the like;

8 an average of those stains, looking at the percent

9 stain removed, and 4 different water temperatures,

10 which I have up here in Celsius. I'll tell you the

11 Fahrenheit conversion also.

12 The first is 10 degrees, which is very cold

13 water, about 50 degrees Fahrenheit.

14 20 degrees Celsius is 68 degrees

15 Fahrenheit, which is about your average cold water

16 temperature.

17 30 degrees is 86 Fahrenheit, which

18 depending on the climate where you live, a cold water

19 incoming temperature, if you live in a warm climate

20 or, in a colder climate, this might be your warm

21 water.

22 Then 40 degrees Celsius, is about 104, 105

23 degrees Fahrenheit, which is your general hot water

EE-RM-94-230 COMMENT 0D
49

1 temperature, but in a colder climate might be your

2 hot water might get down that low.

3 The green line is liquid detergent plus

4 Clorox liquid bleach, and consistently across all the

5 temperatures, it offers significant performance

6 benefits for stain removal for oxidant sensitive

7 stains.

8 Even in 10 degree Celsius water, 50 degree

9 Fahrenheit, 94 percent of the stains are removed.

10 Liquid detergent gives a nice description

11 of the effect of temperature on performance.

12 As you increase the water temperature, you

13 consistently increase the performance. It is very

14 low in the colder water.

15 This next slide shows enzyme sensitive

16 stain, which are grass, gravy, and spaghetti. Again,

17 the same pattern. With Clorox liquid bleach and

18 detergent, you consistently get good performance. It

19 is a little bit lower in the cold, cold water, but it

20 still is around 91 percent, very high stain removal.

21 The liquid detergent again shows how increasing the

22 water temperature improves performance but it is very

23 low in the cold water because the enzymes do perform

EE-RM-94-230 COMMENT 0D
50

1 better in warmer temperatures.

2 This last graph shows bandy black clay

3 removal, which is a research clay. Again,

4 performance is very high with Clorox liquid bleach

5 compared to detergent alone. It is stressed at the

6 lower water temperature, but your stain removal is

7 close to 90 percent, at around 89 percent here.

8 It does provide a significant benefit over

9 the liquid detergent in all temperatures.

10 One other thing to add here is I did this

11 testing in a vertical-axis washer, and it does show

12 at a higher temperature of 40 degrees, when you drop

13 to 30 degrees, you do not see a drop in performance

14 with the soil removal, which is important when you're

15 thinking about a machine that might be coming in the

16 future where the water temperature will drop during

17 the load.

18 Vertical-axis washers hold their

19 temperature throughout the cycle. You might see a

20 1 degree drop, but in a horizontal-axis washer, with

21 less water, and the clothing, bringing down the water

22 temperature, your water temperature will fall off

23 during the cycle, and this will not affect the

EE-RM-94-230 COMMENT 0D
51

1 performance with Clorox bleach.

2 Now, for bleach usage in lower water wash

3 systems, we know that consumers will want to adjust

4 the amount of bleach.that they're using for the load

5 size and the soil level, just like they do today.

6 Dispensers that control the amount in the

7 addition of bleach will maximize the cleaning and the

8 soil removal benefits that the consumer can get, and

9 to also synergize with the detergents, allowing

10 better whitening and brightening. They can prevent

11 fabric damage and also prevent dye damage.

12 This is very important for providing the

13 consumer with a safe and effective way to add bleach

14 to a low water wash system.

15 I want to make some quick comments on

16 utility to the consumer. Right now, it includes your

17 cost benefit analysis, your efficiencies, energy

18 consumption, all of these issues. It doesn't

19 actually look at how well these washers clean

20 consumers' clothes. It's not part of the baseline

21 equation.

22 We feel very strongly that increased

23 utility that's provided by energy savings should not

EE-RM-94-230 COMMENT 0D
52

1 be diminished or negated by poor performance for the

2 consumer.

3 We believe that in incorporating actual

4 cleaning performance into the assessment of the

5 machine is critical to ensure that regulating the

6 energy does not translate to poor performance for the

7 consumer.

8 Recommendations are to add bleach

9 dispensers for sodium hypochlorite bleach to that

10 design option list. This would make this Option P

11 and include actual cleaning performance in the

12 assessment of utility to the consumer.

13 Now I can take questions.

14 QUESTIONS AND ANSWERS

15 MR. LaFRANCE: Mary, your proposal to add

16 the dispenser as a design option, are you referring

17 to like a design criteria, or a specific requirement

18 to have that type of design feature be regulated, or

19 are you proposing that some type of credit be

20 established for a clothes washer that has a bleach

21 dispenser, something like that?

22 In other words, right now, the test

23 procedure does not cover the bleach dispenser

EE-RM-94-230 COMMENT 0D
53

1 provision.

2 MS. SEMMELMEYER: We like the idea of an

3 option with an energy credit, because we realize that

4 this does increase the manufacturer's cost in

5 producing the machine, but it is a very good option.

6 It does improve the performance, it will be

7 meaningful for the consumer, and we like the idea of

8 it as an option with a credit.

9 MR. LaFRANCE: Okay. So some type of

10 credit in the test procedure will be provided in the

11 energy rating.

12 MS. SEMMELMEYER: Yes.

13 MR. LaFRANCE: Are you aware or are the

14 manufacturers aware of what percentage of clothes

15 washers today have bleach dispensers?

16 MS. SEMMELMEYER: We have that information

17 about the Clorox. I don't know the number off the

18 top of my head.

19 MR. LaFRANCE: If you could provide that,

20 that would help.

21 MS. SEMMELMEYER: Okay.

22 MR. LaFRANCE: Thank you.

23 MR. WASSON: Over the years, the machines

EE-RM-94-230 COMMENT 0D
54

1 with bleach dispensers have declined. Do you have

2 any comment as to why the trend has gone from taking

3 that design option off the machines?

4 MS. SEMMELMEYER: Since I'm not an

5 appliance manufacturer, I don't know. I would

6 imagine it might be cost. I know they offer a range

7 of machines with higher end models carrying

8 dispensers and lower end models without, which is

9 more typical.

10 I don't know of any other appliance

11 manufacturers. That's my best guess.

12 MR. ADAMS: I would assume that the

13 assumption here is that there would be energy savings

14 from having the bleach dispenser because consumers

15 would choose to use more cold water washing and lower

16 temperatures.

17 Does Clorox or anyone else have any data as

18 to the differences between consumer usage of hot

19 water with machines that do and do not have bleach

20 dispensers?

21 We would need something like that in order

22 to assess what sort of credit or benefit would accrue

23 from such a desian ontion. ---- - - 1- -

EE-RM-94-230 COMMENT 0D
55

1 MS. SEMMELMEYER: We have information on

2 consumer habits, and cold water usage, warm water

3 usage, and hot water usage, and we can correlate that

4 to usage. This is predictive of what might be

5 happening in the new machines. Also, where

6 performance is lower, they will want to use something

7 to bring it up, and bleach can definitely offer that.

8 MR. ADAMS: This is information you can

9 provide to us?

10 MS. SEMMELMEYER: That would be predictive,

11 but we can provide current usage information. We

12 will.

13 MR. STEPHENS: That also, I presume,

14 includes a way to get at the different -- the usage

15 of bleach by people who have the option and who

16 don't. Obviously, people who don't have the option

17 may figure out a way to use bleach anyway.

18 I don't know whether you can tell us that,

19 but perhaps you can tell us what fraction of the

20 people who have the option in their machine actually

21 use bleach?

22 MS. SEMMELMEYER: Okay. I don't know the

23 numbers to your question, but I do know that

EE-RM-94-230 COMMENT 0D
56

1 consumers -- since many machines don't have bleach

2 dispensers right now and consumers are using the

3 bleach, they typically either add it at the beginning

4 as the washer is filling and allow it to dilute, or,

5 for best results, they will dilute it into a quart of

6 water and add it five minutes into the wash cycle.

7 So they can use it right now easily because

8 they have access to the washer during the cycle when

9 there's a large amount of water in there, and it is

10 very easy for them to use with or without a

11 dispenser.

12 In new machines, where there might be a

13 lockout situation, there might be less water. It

14 might be more difficult for them to safely add the

15 product, and a bleach dispenser would make that

16 easier for them.

17 As a result, then, they could use cold

18 water more easily and get better results.

19 MR. ZARGHAMI: In your presentation, you

20 indicated that usage of bleach would prevent fabric

21 damage.. Would you elaborate on that?

22 MS. SEMMELMEYER: Okay. Because you have a

23 situation with less water and you still need to use

EE-RM-94-230 COMMENT 0D
57

1 the amount of bleach because, like detergent, bleach

2 is geared toward the soil and you have the same soil

3 because you're going to be washing the 6 pounds of

4 clothes, still. You do have less water so you need a

5 more controlled addition. Dispensers can promote

6 that and prevent fabric damage.

7 MR. FREESMAN: So you're saying that the

8 dispenser will control the damage not the bleach?

9 MS. SEMMELMEYER: The dispenser will

10 prevent the damage.

11 MR. FREESMAN: But the bleach itself will

12 not mitigate damage. I think what is Ali's comment,

13 with represented, you're saying bleach -- bleach

14 usage in lower water wash systems, and you're talking

15 about prevent dye damage, prevent fabric damage,

16 which also goes to the question of colored clothes,

17 and so forth.

18 How effective and how useful is this bleach

19 with dyed materials?

20 MS. SEMMELMEYER: It's actually more

21 effective that many people realize. We have done

22 work, going out into the stores and buying garments

23 and testing them for safety, and many garments that

EE-RM-94-230 COMMENT 0D
58

are colored are bleachable, and we encourage

consumers to test the hidden parts of the garment

with one tablespoon of bleach and a quarter cup of

water, to determine if it can safely be bleached.

If you have a blue Oxford cloth shirt and

you have a pen that leaked all over the pocket, and

the shirt will not fade because it's safe for bleach,

many consumers are very happy that they can restore

their garments that way.

46 percent of the color garments that are

purchases in the survey were actually safe for

bleach, the internal work that we've done.

MR. JACOBSON: I've got a couple of

questions. The test data that you showed, did you

run that, and what procedure did you use? Did you

add the bleach at the beginning of the wash cycle or

did you add it halfway through?

MS. SEMMELMEYER: I did a 5-minute addition

on the 14-minute wash.

MR. JACOBSON: Okay. Thank you.

In response to the question that was asked

a minute ago, we do have some data, as well, as to

the number of loads that are typically bleached. I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

EE-RM-94-230 COMMENT 0D
59

1 think you mentioned that about 47 percent of

2 households use bleach. I believe our data would

3 confirm that.

4 In terms of the number of loads that are

5 chlorine bleach, the number is down around 15, 17

6 percent, if I recall.

7 MS. SEMMELMEYER: That's correct.

8 MR. JACOBSON: That's because of mostly

9 white loads, and so on.

10 MS. SEMMELMEYER: We get about 16 percent

11 in our data.

12 MR. JACOBSON: Okay.

13 MR. LaFRANCE: You just mentioned about 15,

14 16 percent of the clothes loads bleach are being used

15 in them. Do you have any historical information at

16 all on that? There's a concern about the temperature

17 use factors. You know, the use of cold water has

18 been decreasing over time-- I'm increased over time,

19 and the use of hot water has decreased.

20 Is the use of bleach a fact that's

21 affecting the way consumers are using the clothes

22 washer or has the use for bleach been pretty much

23 constant or has it been declining or increasing, I

EE-RM-94-230 COMMENT 0D
60

1 should say?

2 MS. SEMMELMEYER: It has been pretty

3 constant, and I don't know that you could correlate

4 it today to the increase in cold water usage because

5 people are using more bleach.

6 Traditionally, bleach users do wash in hot

7 water because that's an association that consumers

8 have. However, we do know that it does offer

9 benefits in cold water, and there's an application

10 here.

11 MR. LaFRANCE: I guess the concern, so you

12 just -- did you want to make?

13 MR. JACOBSON: I was going to say that I

14 think our data would show that chlorine bleach usage

15 has probably been coming down slightly over the

16 years, and I think it'd be hard pressed to say that

17 the increase in cold water has lead to an increase in

18 chlorine bleach as an offsetting factor. I don't

19 believe that's the case.

20 MR. LaFRANCE: I guess the concern I have

21 is if people that use bleach are still using hot

22 water, then obviously you've explained the potential

23 for savings. Obviously, it's rapidly picked you very

EE-RM-94-230 COMMENT 0D
61

1 well.

2 I guess the concern is how can that

3 translate into real world savings in the consumer's

4 home? That's the concern that I have.

5 It goes back to Carl's question about

6 getting data that would show that people who have

7 dispensers that are using bleach are using colder

8 temperatures than the people that don't use bleach.

9 If that doesn't correlate, then I don't

10 think it -- it wouldn't justify a credit, but

11 obviously we've just been getting that data so we can

12 analyze that, because obviously the potential is very

13 great.

14 MS. SEMMELMEYER: I'm not sure I understand

15 your question.

16 MR. LaFRANCE: My question goes back to, I

17 guess, basically supporting Carl's request for data

18 that would justify a credit, because you just

19 indicated that people that are using bleach tend to

20 use hot water, and you've shown that there's a

21 potential for savings, but if it's not really

22 happening, then it really wouldn't justify a credit.

23 That's my concern.

EE-RM-94-230 COMMENT 0D
62

1 MS. SEMMELMEYER: Okay.

2 MR. LaFRANCE: If you or P&G could provide

3 any data at all relative to this concern, it would be

4 helpful.

5 MS. SEMMELMEYER: This is a situation where

6 we will need to do consumer education, as we are

7 already doing now, because we are always trying to

8 increase consumer usage.

9 Obviously; in the new washing machines,

10 there's a whole new situation, and there's an

11 opportunity there to get consumers to understand that

12 they can use the product in cold water.

13 Currently, the push is for hot water

14 because the best cleaning performance you can get is

15 in hot water and we recommended for our consumers the

16 best performance possible, which is hot water, and so

17 that's why you have a higher percentage now of

18 consumers using hot water.

19 But, again, education with the new machines

20 and the new situation will provide the opportunity

21 for increased cold water usage.

22 MR. LEVY: I understood you to indicate

23 that approximately half of colored fabrics could be

EE-RM-94-230 COMMENT 0D
6

1 washed with bleach or bleach safe. Doesn't that

2 present a real practical problem with using the

3 product as a way of producing water temperature on a

4 widespread basis?

5 MS. SEMMELMEYER: We wouldn't recommend it

6 on the widespread basis. We would continue to

7 recommend testing, because you can't look at a

8 colored garment and know that's bleachable, that's

9 not bleachable, unless you're looking at fiber

10 content. Obviously, silk is not bleachable.

11 Consumers have to test for color garments,

12 but it is something that can be done that many people

13 aren't aware of, and that's another point of

14 education that we work on.

15 MR. POPE: Mary, I have two questions for

16 you.

17 The first question is, in a scenario where

18 you have a dispenser, do you foresee using less

19 liquid detergent because you were adding the bleach?

20 The second question is: I wasn't aware

21 that the more efficient washers had a lower

22 performance as far as cleaning goes. I guess if that

23 were the case, my understanding and the biggest

EE-RM-94-230 COMMENT 0D
64

1 concern might be on not so much stain removal but

2 more on whiteness retention.

3 I guess by question is: The results

4 presented sound like they had mostly to do with stain

5 removal. What would be the impact on bleach on

6 redeposition of soil and overall whiteness retention?

7 MS. SEMMELMEYER: It improves it. Let me

8 make sure I get your questions right and in the right

9 order.

10 To whitening, bleach is a fabric whitener,

11 and it works best in synergy with the detergent. You

12 wouldn't need to reduce detergent usage. You would

13 still want to use the same amount.

14 Bleach is a complement to that. It should

15 be added after the detergent to allow fluorescent

16 whitening agents and enzymes in the detergent to do

17 their job in a wash and then bleach would come in and

18 complement that and take soils that are in the water

19 and decolorize them as well as soils and stains be a

20 part of the soil, it double bonds, it solubilizes

21 them, and improves the soil and stain removal and

22 does improve redeposition, which is the prevention of

23 soil going back onto the clothing.

EE-RM-94-230 COMMENT 0D
65

1 With whitening, when it is added later in

2 the wash, it provides indefinite benefit because it

3 allows the fluorescent whitening agents to work,

4 which is a major part of detergents.

5 Does that answer your question?

6 MR. POPE: Yes. Thank you.

7 MR. FREESMAN: When you said that 46

8 percent of the garments that you bought were

9 bleachable, have you done any shipment weighted

10 averages? Because I think you'd see a tendency to

11 say that the stuff that moves in volume in the stores

12 would not be bleachable. Maybe some of the things

13 that don't sell in high volumes are bleachable, and

14 what does that do for actual garments sold in stores?

15 How would that number come out relative to

16 46 percent of the garments that you purchased?

17 MS. SEMMELMEYER: I can try and find that

18 out. I think that's an interesting question, the

19 idea being, did we buy a garment that maybe only two

20 consumers in the whole country happened to own that's

21 bleachable, or is it something that's mainstream.

22 MR. FREESMAN: If you walk into Wal-Mart

23 and buy some of the products in there, chances are --

EE-RM-94-230 COMMENT 0D
66

1 MS. SEMMELMEYER: Most denim and blue jeans

2 are bleachable, so that's one item that I know has a

3 pretty high market permeation.

4 MR. FREESMAN: Indigo doesn't need much to

5 help it run.

6 MS. SEMMELMEYER: A variety of denim,

7 though -- light colored denim, dark colored denim,

8 depending on -- I wouldn't necessarily bleach it the

9 first time I bought it, but after a series of time

10 where most of the dye is going to bleed off has bled

11 off, you can definitely get stains off your jeans.

12 Let me make a note of that.

13 MR. JACOBSON: Getting back to the issue of

14 fabric damage, I think it's the concern for fabric

15 damage that reduces the number of loads and number of

16 fabrics that get bleached in the first place. That,

17 along with just odor concerns, I think are probably

18 the two limiters to wider-spread chlorine bleaching.

19 Certainly, I think your points are well

20 made that a well designed bleach dispenser would help

21 to mitigate fabric damage, but the fact of the matter

22 is chlorine bleach is aggressive to two fabrics, and

23 you do get a weakening of the fabric, and that is a

EE-RM-94-230 COMMENT 0D
67

1 concern, and that does blend with the use of chlorine

2 bleach, as I think we're all aware.

3 MS. SEMMELMEYER: To a point. Consumers

4 take into account the usable life of the garment, and

5 something that has a stain on it that other products

6 are not going to get out, they will want to use and

7 they want to be able to use it.

8 MR. JACOBSON: That's right.

9 MS. SEMMELMEYER: There's tradeoffs, too.

10 MR. JACOBSON: There are definitely

11 tradeoffs, and I think that leads to why we see 15,

12 17 percent of loads getting bleach as opposed to 100

13 percent of loads.

14 MS. SEMMELMEYER: We see, also, because of

15 consumer miseducation. Most consumers do their

16 laundry the way their mother did the laundry.

17 MR. JACOBSON: Right.

18 MS. SEMMELMEYER: In all of our surveys,

19 how did you learn; that's the number one reason. If

20 mom was afraid of bleach or didn't use bleach, then

21 the adult child won't use it.

22 MR. JACOBSON: I think there's also

23 appointed in that the advancements that have been

EE-RM-94-230 COMMENT 0D
68

1 made with activated oxygen bleaches have certainly

2 provided an alternative to consumers for going after

3 bleach sensitive stains, and those products have been

4 very effective in the marketplace.

5 MS. SEMMELMEYER: Yes, to a point. Again,

6 certain stains you might find compared to performance

7 and certain stains you won't be able to beat

8 hypochlorite bleach.

9 I also don't believe -- you can correct me

10 if I'm wrong -- perhaps to just accomplish

11 disinfectancy in a variety of wash temperatures, so

12 there are --

13 MR. JACOBSON: The disinfectancy of

14 chlorine bleach is clearly one of its strengths.

15 MR. MILLER: Peter Miller with NRDC, to

16 pick up on that. There are nonchlorine bleaches in

17 the market which have different characteristics. How

18 would you propose taking that into account in this

19 analysis, given that consumers are using both types

20 of bleach at different times?

21 MS. SEMMELMEYER: I see that as a separate

22 issue than the bleach dispenser, for sodium

23 hypochlorite bleach, because they are different

EE-RM-94-230 COMMENT 0D
69

1 products, and they do have different uses.

2 MR. MILLER: So are you proposing that this

3 would be a dispenser solely for chlorine bleach?

4 MS. SEMMELMEYER: Correct.

5 MR. JACOBSON: The oxygen bleach products

6 and the activated oxygen bleach products on the

7 market today are designed to go in, either in the

8 main detergent or as a supplement to the main

9 detergent at the start of the wash and are compatible

10 with the different components of the detergent, so

11 there's not an issue there in terms of the use, and

12 they tend to be milder to the fabric.

13 They're not as aggressive to fabric, and

14 they tend to be virtually across the board with very,

15 very few exceptions to dyes.

16 MS. SEMMELMEYER: Yes. Basically, if you

17 can wash it with detergent, you can wash it with

18 color-safe mix.

19 MR. JACOBSON: Right.

20 MR. MILLER: So this dispenser would not be

21 appropriate for alternate bleaches? Is that what I'm

22 hearing?

23 MR. ---  JACOBSON: ---------  Correct. ------- 

EE-RM-94-230 COMMENT 0D
70

I MS. SEMMELMEYER: Correct.

2 MR. JACOBSON: You wouldn't need it for an

3 alternate bleach.

4 MS. SEMMELMEYER: Any more questions?

5 [No response.]

6 MS. SEMMELMEYER: Okay. Thank you very

7 much.

8 MR. LaFRANCE: Thank you, Mary.

9 Would anybody else like to make a

10 presentation at all this morning or go into general

11 discussion?

12 [No response.]

13 MR. LaFRANCE: I propose we take a five14 minute break. We'll come back in five minutes.

15 [Recess]

16 MR. LaFRANCE: I thought we were moving

17 rather well here. We started late, but there weren't

18 that many presentations. We'll go all day if you

19 want to, but we felt that maybe the discussion will

20 only take approximately two hours. In that case, we

21 won't take a lunch break. We'll just keep working.

22 If people feel as if we want to take a

23 lunch break and go on for the entire afternoon,

EE-RM-94-230 COMMENT 0D
71

1 that's fine, we're here for as long as you guys want

2 to discuss the issues.

.3 We'll probably wait until 12:30; give it a

4 full hour, and then we'll see if we want to take a

5 break or keep going on.

6 This morning I presented some slides and

7 Peter from LBL presented the analysis. We also have

8 some topics we'd like to discuss specifically, but,

9 at this point, we can bring up the particular issues

10 that people want and discuss them.

11 Also, the analysis that we've completed, at

12 this point, is our best assessment on the engineering

13 analysis, which provides the basis for all of the

14 other analysis -- being manufacturer, residential,

15 energy impact to the nation, environmental -- all of

16 the other analyses that we've explained in the

17 advanced notice.

18 So if there are issues that you have with

19 particular analysis that we've presented today, it's

20 very important that you provide those issues to us so

21 that we can try to consider them again before, before

22 we finalize the engineering analysis and use it for

23 the analysis.

EE-RM-94-230 COMMENT 0D
72

1 For example, there has been a little bit of

2 concern on the temperature use factors on the AHAM

3 proposed test procedure, and the AHAM test procedure

4 that was submitted, dated July 5th, had exact same

5 Tufs (ph) that the data was submitted on.

6 If we adjust those Tufs at all, then we

7 will need to readjust the energy consumption for the

8 analyses, so that's one example of something that we

9 plan on doing if we need to. But it's important that

10 people provide feedback on the analysis, but it's

11 going to provide the basis for all of the other

12 analyses.

13 So I'll just start. The first issue that

14 we have on the agenda deals with the load size for

15 vertical-axis versus horizontal axis.

16 The concern that we have here is we've

17 heard various concerns. One position is that the

18 variation in load size, quote, a fixed capacity drum,

19 would be based on consumer habits. This concern

20 about the European models would be used, larger loads

21 for the same amount of drum size.

22 There is also concern that the existing

23 test procedure and even proposed test procedure,

EE-RM-94-230 COMMENT 0D
73

1 might have a credit but not by design, just by

2 accident, and that is, we measured the capacity of

3 the basket to the uppermost portion, where you have

4 the basket ring, which some models are very small and

5 other models could be rather large, and that doesn't

6 appear that that is actually occupied during the wash

7 cycle, but yet it's used in the calculations, so it

8 may be giving a large credit to the vertical-axis.

9 So that's another side.

10 We'd like to discuss that and get feedback

11 as to what your thoughts are on that particular

12 issue, between the load sizes and the vertical-axis

13 and the horizontal-axis, for a particular fixed

14 capacity.

15 MR. STILWELL: Are you asking for comments

16 now on that, Marc?

17 MR. LaFRANCE: Yes. It's an open forum,

18 anybody can speak.

19 MR. STILWELL: We talked a little bit about

20 this also, and I think there's an Australian test

21 procedure for washers that takes that factor into

22 account, and I believe they multiply their

23 horizontal-axis washer volume by 1.2, to account for

EE-RM-94-230 COMMENT 0D
74

1 that difference.

2 I think what they're saying is that for any

3 given advertised volume, the wash baskets, the

4 horizontal washer can handle about 1.2 times what a

5 vertical axis can in terms of actual load size.

6 MR. LaFRANCE: What's the fundamental basis

7 behind that 1.2? Is it based on consumer habits or

8 is it based on the method of test or the inherent

9 design characteristics of each?

10 MR. STILWELL: I think it's just based on

11 the fact that all of the interior volume of a

12 horizontal axis washer is usable space, where it is

13 not on a vertical axis washer.

14 MR. JACOBSON: I would assume that that

15 analysis, with all due respect to the Australians, is

16 like much materials based on horizontal-axis, theory,

17 as opposed to what actually happens.

18 Everything we know says that consumers make

19 these decisions based upon their perceptions.

20 I think it's clear that consumers perceive

21 the capacity of these machines to be smaller.

22 Therefore, any kind of factor which would assume that

23 they would act counter to that perception, is

EE-RM-94-230 COMMENT 0D
75

1 probably wrong and certainly shouldn't be accepted by

2 DOE without some very extensive analysis or basis to

3 support it, aside from one which is based purely on

4 the assumptions that there is more usable capacity,

5 because of the way the washer actually works.

6 I have no idea how to get at that

7 information, but it would seem to be, again, that

8 until we can figure that out, that DOE would have to

9 act, or rather would not take that fact into

10 consideration with coming up with any kind of

11 standard or as the basis for any action at all.

12 I suppose we could all do some research on

13 that, and maybe that's not a bad idea, but I'm not

14 aware of any which actually would confirm that these

15 machines are necessarily more efficient or even as

16 efficient based on the actual ability of each, use

17 more of its capacity.

18 MR. STEPHENS: Are you suggesting, then,

19 that the P&G load factor of .52 is essentially

20 properly applied from you standpoint, to whatever

21 machine is being considered, no matter what it's

22 supposed manufacturer's suggested capacity?

23 MR. JACOBSON: Well, no, I'm not suggesting

EE-RM-94-230 COMMENT 0D
76

1 that because we are supporting the AHAM test

2 procedure. I don't think that would be in line with

3 that. If I recollect, the AHAM test procedure is not

4 based on that 1.5 percent. It's a half-pound load,

5 is our [inaudible].

6 MR. STEPHENS: Well, yes. The average load

7 fraction, I presume, is defined as the fraction of

8 the maximum load capable that a consumer actually

9 tend to wash with. Is that wrong?

10 MR. LaFRANCE: The load fraction represents

11 the max load to average load ratio, based on the test

12 procedure, which should be close to consumer's

13 habits. Now, that could be a point of contention on

14 the test procedure hearing rulemaking.

15 All the .52 says is that the P&G data,

16 let's say for a 2.8 cubic foot machine and the 2.4

17 cubic foot machine, they come up with average and

18 maximum loads, and it's just a ratio of one to the

19 other. So the test procedure tests the RMC using max

20 loads, and then calculates the energy savings based

21 on average load, so it's almost half.

22 MR. STEPHENS: Right. That's kind of what

23 I'm getting at. The point is, given that the vast

EE-RM-94-230 COMMENT 0D
77

1 majority of machines out there today are vertical2 axis machines, then that suggests to me that

3 consumers perceive that the vertical-axis machine can

4 wash, or they just choose to wash, half of the

5 clothes that the machine is actually capable of

6 washing. Is that a bad presumption?

7 MR. FREESMAN: I think that's a very unsafe

8 presumption because I think what you find is

9 different users use their products differently.

10 At one point in time, they may have a full

11 load, they put in a full load. They might put in 12,

12 13, 14 pounds, maybe even stuff that is more than the

13 washer can handle, and at other times they just have

14 a couple of things but they need something cleaned,

15 and they'll put in two or three pounds of clothes.

16 You average that out, you're getting 7 pounds.

17 So you're using two variables in creating a

18 number from those two variables, which is .52 and

19 just represents those two variables which you've

20 chosen.

21 MR. STEPHENS: Yes, I think you're right.

22 I guess what we have to come up with is some

23 rationale to suggest that no matter what kind of

EE-RM-94-230 COMMENT 0D
7

1 machine in question we have, that that same procedure

2 is what we go through, or that consumers are picking

3 their load based on what they have to wash, rather

4 than what the machine will hold. I mean, that's kind

5 of what you're sort of leaning towards there, but I

6 don't know that that's true.

7 MR. JONES: They choose what they wash by:

8 (A) the capacity of the machine; and,

9 (B) What they have to wash.

10 If what they have to wash is morethan what

11 the capacity of the machine is, when they have to do

12 two loads or more.

13 MR. STEPHENS: Except that you just

14 suggested that in some cases they'll overload the

15 machine, horizontal or vertical axis.

16 MR. JONES: Yes.

17 MR. JACOBSON: There's a technical

18 difference here, though. In a vertical-axis machine,

19 if you stuff the machine full while it is still in

20 the water and the clothes absorb some water and so

21 on, you can get to the point where you have so many

22 clothes in there that you cannot get effective

23 washing.

EE-RM-94-230 COMMENT 0D
79

1 I mean, you will not get the turnover,

2 you'll get the rollover, you'll not get effective

3 washing.

4 In a horizontal-axis machine, since you are

5 putting the clothes in before the water starts to

6 come into the machine, typically, that's the

7 operation, you can almost stuff that thing full.

8 Once water comes in, the clothes tend to collapse

9 because of the wetness of the clothes, and you can

10 still get effective tumbling-and action.

11 So there's a different functionality that

12 occurs between the two types of machines. I think a

13 lot of consumers with vertical-axis machines today

14 certainly know that if they put too many clothes in,

15 overload it, they just don't gt the clothes clean.

16 I mean, the thing sits there and doesn't do

17 much, and they're very conscious of needing to not

18 overstuff the machine, at least the conscientious

19 housewife will do that.

20 MR. MILLER: I think more specifically, the

21 point, too, it appears that DOE is now measuring up

22 to the very top of the basket in the vertical-axis

23 machines. In my experience, at least, that's

EE-RM-94-230 COMMENT 0D
80

1 certainly a point at which you're not going to get

2 effective cleaning. I believe that's an overestimate

3 of the affected capacity, and so that there is

4 clearly, in my mind, a credit to be given to the

5 vertical-axis on that basis alone.

6 MR. POPE: I'd like to mildly challenge the

7 assumption that consumers automatically assume the

8 capacity is smaller in the horizontal-axis. I think

9 if you look at the average load size in Europe, with

10 a much smaller typical drum size, you see a typical

11 load that's almost as large as that represented here

12 in the states.

13 I realize they're different consumers, but

14 I'm wondering how much data there is here in the

15 state, with such a small market share, that really

16 tells us that consumers will not perceive the full

17 capacity of horizontal-axis design.

18 MR. JACOBSON: The horizontal-axis

19 machines, at least that are sold today in the U.S.,

20 do look smaller capacity, and the perception is real,

21 they do look smaller. But I do support the numbers

22 that you stated, that our data shows the average load

23 size in Europe and in the U.S. is virtually

EE-RM-94-230 COMMENT 0D
81

1 identical, about 3 kilograms in Europe, which is 6.6

2 pounds, very close to the average load size that we

3 find in the U.S.

4 The machines over there are typically rated

5 for smaller capacities, and you'll typically see like

6 a 5 kilogram machine, which would be an 11-pound

7 rated capacity. They will still do about 6 pounds of

8 laundry in that machine.

9 I suppose we have distributional data in

10 Europe for load size distribution, just as we have it

11 here in the U.S., and I could certainly find that

12 information if that would be helpful.

13 MR. LaFRANCE: Yes, it would be.

14 MR. WASSON: We have no actual data that's

15 been collected for load size, however, we do have

16 customer testimonial letters that we could copy and

17 send.in to DOE, stating the fact that they get as

18 much or more in their new machine compared to a

19 vertical axis, and we have not actually done, like I

20 said, data collection, because of the small numbers,

21 but, if need be, those letters, the testimonials, can

22 be sent in.

23 MR. T.a RANCE T think it won ii1 ho h1 -,-i 1 ---- ---- -- - - - .. -- - -- L- -

EE-RM-94-230 COMMENT 0D
82

1 if you could provide those to give some basis.

2 MR. POPE: Not only does Australia, I

3 think, utilize that correction factor that Dick

4 mentioned, but I think the international European

5 electro-techno commission also utilizes maybe 1.15

6 factor, so it's being acknowledged in more places

7 than just Australia.

8 MR. LaFRANCE: Getting back to the concern

9 about the test procedure and possibly providing a

10 credit for the method of measuring the volume,

11 yesterday at the hearing, the test procedures, I

12 requested AHAM to provide some input on that, and I

13 would also request anybody today to provide input in

14 regards to that rulemaking, so we can use it.

15 Also, maybe a proposed change in the test

16 method that they would recommended adopting to change

17 the method of testing.

18 We also learned yesterday that by just

19 measuring it with the machine's ability to fill the

20 basket would not be fair to the machines that might

21 not fill up the entire basket, and we mentioned

22 something on the record about that'yesterday.

23 So there's a concern that you just can't

EE-RM-94-230 COMMENT 0D
83

1 use the machine's ability to fill it up, so it would

2 need to be done probably manually, but some type of

3 language that would explain what height in the basket

4 would be allowable.

5 So maybe once we find information on that,

6 in regards to yesterday's rulemaking, we would

7 appreciate it.

8 The next point I have here deals with the

9 potential energy savings for automatic fill control.

10 - We have just recently received data from AHAM, I

11 believe, on Friday of last week, which Peter

12 explained is not in the analysis.

13 That information, we can make that

14 available to you at the end of the workshop. We

15 didn't have it in time. I should have made copies

16 for everybody but it's something that I didn't even

17 have a chance to review myself.

18 But it shows virtually zero or very, very

19 low increase in efficiency for adaptive control.

20 Now, a lot of that has to do with the number of

21 copies responding. I believe we had four companies

22 respond to that design option, and the base case we

23 had five.

EE-RM-94-230 COMMENT 0D
84

1 The stated deviation is relatively low, and

2 I: guess this is a concern to me, because we've seen

3 slides from AHAM in the past the depicted a large

4 potential that was not quantifiable, but from a

5 graphical standpoint it appeared to be a large amount

6 of potential savings, with automatic water fill

7 capability.

8 Also, the proposed load use factors that

9 AHAM has presented in regards to the test procedure

10 rulemaking show approximately use of max fill, I

11 believe something on the order of 14 percent. I

12 don't have it in front of me, but it's 14 to 12 max,

13 and the same for minimum, 14 to 12, and in the middle

14 it was like 64, or something like that, the relative

15 range. We can talk about the exact numbers.

16 It showed that the vast majority of people

17 are using average load sizes, and there's also a

18 graph from P&G that shows the actual data points of

19 people using load size. Very few people in the small

20 size and very few people in the max size.

21 If the average load size is roughly half,

22 we'll say, of the capability of that machine, and I

23 don't know what ball park, but let's say two-thirds

EE-RM-94-230 COMMENT 0D
85

1 of the water use -- and that's a ball park because I

2 think everybody knows that the minimum fill is about

3 one-third of the water, in that range.

4 Believe me, please jump right in if you

5 have better numbers, because I'm just going on a

6 guesstimate of the industry, and obviously everybody

7 has their own settings, but roughly about a third is

8 used for minimum, and approximately maybe two-thirds

9 for medium, and full for maximum.

10 So if the vast majority of the people are

11 using average load sizes, with only two-thirds of the

12 water savings, then I guess I have a major concern

13 about the data that was submitted. It only shows a

14 minimum amount of energy savings.

15 If people could provide information here as

16 to what's happening here, why does it only show a

17 minimum amount of savings when it was depicted at

18 some times of being a rather large potential energy19 saving option.

20 MS. RANSDE: One point that I'd like to

21 make on reviewing this data is that baseline is based

22 on five companies all the time. When one of the

23 design options is based on less than the five

EE-RM-94-230 COMMENT 0D
86

1 companies, four or three companies, the data can be

2 skewed, depending on which company dropped out. If

3 that was a lowball figure or a highball figured

4 compared to the average, the data can be skewed in

5 making these comparisons.

6 In fact, when looking at the data that was

7 submitted by AHAM, some of these energy saving

8 options actually showed increases in energy use.

9 One of the suggestions that came out of

10 some of our AHAM meetings was that Wayne Morris from

11 AHAM was going to help us by providing recalculated

12 baseline data for these options.

13 So I'd like LBL and DOE to take into

14 consideration that we might want to recalculate some

15 of these options with a baseline that only included

16 the same companies in the baseline that included data

17 for those options.

18 MR. STEPHENS: Which data were they that

19 you think are affected by that?

20 MS. RANSDE: Any data option that fewer

21 than the five companies submitted data on.

22 MR. STEPHENS: I mean, is it water use or

23 dollars or is it the whole analysis, everything about

EE-RM-94-230 COMMENT 0D
87

it?

MS. RANSDE: Dollars and basically

everything, needs to be compared to the same four

baseline companies. If you have an option where four

companies submitted data on that option, you need to

compare the results with a baseline that includes

those same four.

MR. STEPHENS: Thank you.

MR. LaFRANCE: Have the AHAM members agreed

to provide that to us?

MR. ANDERSON: It's in the submittal.

MR. LaFRANCE: Okay.

MR. RIECHMAN: It's been done for all that

MR. MORRIS: It's not done for all design

options, it can be done. It was done with this

latest round of data submission.

MR. JONES: What's the product of the

latest? Do we know?

MR. LaFRANCE: Let me explain for people

that might not understand what's going on here.

On the record, we have comments from

various organizations, and AHAM has submitted data in

the past, and that is on the public record. That is

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

__

EE-RM-94-230 COMMENT 0D
88

1 the data that Peter uses for the analysis.

2 This last round of data came in, I believe

3 it was last Friday, and actually, because I've been

4 rather busy, I reviewed it last night, so right now

5 we don't have it on the record at this point but we

6 will make it available at the end of this meeting.

7 Everybody is referring to the last

8 submission of data from AHAM. We did not analyze the

9 data yet and it's not part of the analysis. I'm glad

10 that Jane explained this, and Wayne already explained

11 the problem with the base case have been at least

12 resolved for this particular data submission.

13 I think, even in the base case sense, the

14 standard deviation is still relatively low and the

15 energy savings are very, very low. I guess I just

16 don't understand that.

17 I don't understand how, in one case, people

18 can talk about this being a rather large potential

19 energy savings because most consumers use average

20 load the vast majority of the time. I think it's in

21 the. 64 percent range.

22 But, yet, the test procedure tests the max

23 load 72 percent of the time, because when you have a

EE-RM-94-230 COMMENT 0D
89

1 manual setting, the consumers set max fill 72 percent

2 of the time, based on historical P&G data, or maybe

3 somebody can explain the 72.

4 I guess we can go back and look at it, but

5 it's something that everybody at this point, all of

6 the manufacturers and everybody that's provided

7 comment, believes is valid.

8 It was in the existence of that procedure

9 for over 20 years and we're not changing.

10 So if 72 percent of the time we're using

11 max fill but, in reality -- and this is, I think,

12 based on P&G data -- 64 percent number, people are

13 only using average size loads, then that, to me, is a

14 significant amount of energy savings or hot water

15 savings.

16 MR. LEVY: You mean it's a significant

17 amount of savings if you had automatic fill control?

18 MR. LaFRANCE: Right. Right. But automatic

19 fill control, by design concept, you obviously have

20 to have enough water to saturate the clothing, so if

21 you have an average size.load in the 67-pound range,

22 you have to saturate the clothing.

23 Then, depending on the design type, you may

EE-RM-94-230 COMMENT 0D
90

1 have some fixed amount of additional water, or you

2 might have a percentage of additional water,

3 depending on how you design your clothes washer.

4 You may have various methods to control

5 that water fill; you know, all proprietary.

6 But, in any case, it seems to me you would

7 still save some considerable amount of water, and it

8 just seems as if the data that's been submitted,

9 basically, do the manufacturers believe that

10 automatic fill control has minimal savings? I guess

11 I'd like to hear some comment as to where are the

12 potential savings for an automatic fill control

13 machine?

14 MR. STILWELL: I don't think we know,

15 frankly, and I think the formula that we arrived at

16 was the best we could do with what we have to work

17 at.

18 In other words, I'd have to defer to Larry

19 Hawkins at GE, who developed this formula, but I

20 think it was basically a comparison based on average

21 load sizes versus the old test procedure ratio of

22 minimum size to maximum -- or minimum fill to maximum

23 fill, and that's really all we had to work with.

EE-RM-94-230 COMMENT 0D
91

1 Until these controls are developed and we

2 get them out in the field and actually see what the

3 savings are, I think it's just anybody's guess.

4 MR. HAWKINS: I understand what you're

5 saying, Dick. I guess in some regards I share marc's

6 comments. But if you went through, all of us, if we

7 all did it, and we went through it on a purely

8 theoretical basis, which would be the only basis that

9 maybe some of us have right now, I don't understand

10 why the savings wouldn't reflect, as Marc indicated,

11 it should reflect, based upon the work done in the

12 test procedures and based upon the assumptions made

13 and based upon the data we have available, it would

14 appear that unless someone was discounting the

15 capabilities of the systems, it ought to come out in

16 the numbers to show the energy savings better there.

17 MR. LaFRANCE: I think also, from a

18 technical standpoint, the average size load on a ship

19 to weighted average capacity is a fixed amount. I

20 could pull it out, but it's in the 67-pound range.

21 That clothing only saturates a certain amount of

22 gallons of water.

23 You can look at it from several design

EE-RM-94-230 COMMENT 0D
92

1 points saying that there might be three or four ways

2 to look at it for the design capability of the

3 machine, saying okay, you have a fixed amount of

4 water for the clothing.

5 Then you have, let's say, one design option

6 would be 5 percent of additional free water, 10

7 percent of additional free water, 15 percent, 20

8 percent load.

9 So, at some point in time, you have a fixed

10 amount of water for the clothing, and then varying

11 design options of, let's say, how crude the adaptive

12 control may be.

13 So you could actually submit data based on

14 certain percentages of additional free water in the

15 basket or in the tub, and then, with that, provide

16 potential energy savings.

17 So if you design a high-tech unit that only

18 uses 5 percent or 2 percent additional free water,

19 then it provides the maximum savings.

20 But if it's crude and it's 25 percent

21 additional free water, then it's not as good. Maybe

22 there's some way to look at this from a technical

23 standpoint to give us the numbers, I don't know. I

EE-RM-94-230 COMMENT 0D
93

1 guess I'd like to hear comments.

2 MR. MILLER: To follow up on that, I'm

3 wondering if there's information on the

4 characteristics of the adaptive control was assumed,

5 whether it was an additional percentage, or an

6 additional number of gallons.

7 MR. LaFRANCE: We do not have that. The

8 data that came from AHAM, checked their members, is

9 lumped together on a ship weighted average, and a lot

10 of the specific proprietary information like that,

11 what it was based on, is not provided to us.

12 We encourage that people write to us on a

13 confidential basis just as much as possible to help

14 us assess this. But, from what I've seen -- and,

15 like I said, I've only reviewed this for a short

16 period of time -- relatively speaking, it's a minimal

17 improvement in efficiency, and it doesn't seem to be

18 representative of what was showing in the test

19 procedure, but potential savings.

20 In one case, we're supposed to accept that

21 test procedure that shows a potential large savings

22 for adaptive fill and in the other case, when we get

23 the data submitted, it shows minimal savings, it

EE-RM-94-230 COMMENT 0D
94

1 doesn't match, and it's a concern.

2 Possibly the manufacturers would be willing

3 to explain a little bit more as to how they submitted

4 it, if they can. I don't know what's proprietary and

5 what's not.

6 MR. STEPHENS: Marc, I think this is a

7 larger issue that's going to rear its head in other

8 appliance rulemaking procedures when we start getting.

9 into adaptive controls and fuzzy logic and the other

10 systems that will, in theory, help the consumer to

11 make better choices.

12 One issue that came up when we were looking

13 at water heaters that were purporting to do some of

14 the same thing, was that we also ended up wanting to

15 know how a consumer knew, how anybody knew, for that

16 matter, that this matter was or was not working; in

17 other words, with absent data that says this thing

18 has a lifetime that's longer than the machine or

19 least as long as the entire machine, how does the

20 consumer know when this adaptive control has failed,

21 and, if it fails, what does it do? What does the

22 machine do if it fails?

23 If the consumer knows right away that

EE-RM-94-230 COMMENT 0D
95

1 something's not working and can get it fixed, it has

2 minimal impact, but if the consumer has very little

3 way to know if this thing is still functioning on the

4 machine, and the machine's default is fill it to the

5 top every time, then it would potentially have an

6 effect on the savings that we could assume from such

7 features.

8 So I'm just adding that in now as something

9 that if you want to try to get at information for

10 manufacturers to assess the potential savings, you

11 might consider trying to get at some of those notions

12 as well.

13 MR. LaFRANCE: Well, that's a good point.

14 but, in something like that case, you know we could

15 analyze this to the nth degree, where if you're

16 talking about a liability of a new adaptive system,

17 let's say the reliability is less than the life of

18 the machine itself, you have a problem with the

19 machine not be adaptive control.

20 The adaptive control could not provide any

21 water. In that case, the consumer would have to get

22 it fixed.

23 Aln i+ alwavs efault-s t-n -ho "mv f ; I 1 - -- -- -11- 1 - -- - - - -- ,

EE-RM-94-230 COMMENT 0D
9

1 you know, consumers are energy conscious, at least

2 some of them are, and quite a few people are. If

3 they see it's going to max fill all the time,

4 occasionally picking up and putting another

5 [inaudible] and they say, wow, this thing's full,

6 then I think the manufacturers would get feedback on

7 that and the market itself would help to prevent that

8 type of default function.

9 It's a good point and it's a valid point,

10 but I mean, at this point in time, we're just trying

11 to quantify the base case when the model leaves the

12 factory and do the best we can and leave the

13 reliability up to the manufacturers, so that's a good

14 point.

15 MR. MORRIS: Marc, I don't know what you

16 mean by not a significant amount of reduction, but

17 the reduction that I calculated was 11.5 percent

18 reduction of the hot water energy, versus the

19 recalculated baseline.

20 The overall total energy was reduced by 10

21 percent, and the energy factor went up by about 12

22 percent, so this is based on the data that was

23 submitted last week on automatic fill control.

EE-RM-94-230 COMMENT 0D
97

1 So I don't know what you mean by not a

2 significant amount or significant amount, or what; I

3 can't comment on that, but those are the numbers that

4 were submitted.

5 MR. LaFRANCE: Thank you, Wayne. I guess,

6 obviously, I didn't look at the recalculated baseline

7 because I wasn't aware. Like I said, didn't look at

8 this recently.

9 I guess 11 percent, which is better than

10 what I thought it was originally. So I think 11

11 percent actually moves in the right direction and

12 maybe it is valid. I'm glad you made that available

13 to us, and maybe we could have some feedback as to

14 whether people think 11 percent is in the range.

15 Obviously, we need to go back and do some

16 ball park calculations. Based on, let's say, if you

17 assume two-thirds for the average load, I don't even

18 know if that's valid, if two-thirds think is

19 reasonable, though, for an average load with that

20 setting, and we'll say the medium load size.

21 If we could get some feedback as to whether

22 two-thirds is high or low, then we might be able to

23 do some assessment as to how valid the 11 percent.

EE-RM-94-230 COMMENT 0D
98

1 MS. RANSDE: What is the two-thirds of?

2 MR. LaFRANCE: I mean, this is like a ball

3 park number. That's.like a subjective ball park

4 number that I've learned.

5 In a conventional clothes washer, when you

6 select the minimum fill, you get roughly one-third.

7 That might be high or it might be low, but if you can

8 say percentage basis of number of gallons versus

9 total gallons for max fill, and then when you set it

10 to medium fill, I'm saying, ball park, we're talking

11 two-thirds.

12 Some people say, well, I'm setting it to

13 medium fill and the consumer might think okay, I'm

14 getting like the middle of the basket being filled

15 with water, but in reality they might be getting two16 thirds. I'm not sure if that's right or not, but

17 it's a ball park number.

18 I don't have anything to back that up, and

19 I'm looking for something from you, from all of you

20 in industry, to say okay, what are the percentages of

21 max fill from a gallon standpoint.

22 So, with that, another way to get to the

23 potential savings is basically assuming that your

EE-RM-94-230 COMMENT 0D
99

1 automatic fill control, no matter how you design it,

2 will achieve the appropriate amount of water.

3 Actually, it could even be possibly less water than

4 that, and it could even be additional savings.

5 So just by going at the two-thirds, you're

6 going to save energy in the test procedure

7 standpoint, but in reality you're probably saving

8 additional energy as well. Maybe not. But that will

9 at least help us, to some extent.

10 The next thing is, how much water is

11 displaced by the average size load clothing, and what

12 are reasonable amounts of free water for an adaptive

13 control machine?

14 Do they range from 5 to 20, 2 to 50? Some

15 type of information that would help us calculate

16 adaptive fill capability, in addition to this mission

17 from AHAM, so we can validate that 11 percent,

18 whether it's reasonable or whether it should be

19 higher or lower.

20 MR. FREESMAN: If you're looking for bigger

21 numbers, don't forget, you've got temperature use

22 factors that come into play, so you're talking about

23 cutting down the hot water. You mentioned hot water

EE-RM-94-230 COMMENT 0D
100

1 saving.

2 MR. LaFRANCE: Right.

3 MR. FREESMAN: The temperature use factor

4 you're saving, but only a percentage of that is going

5 to be hot water, significant temperature use factors.

6 MR. LaFRANCE: But there's also water

7 savings. That's a good point. There are also water

8 savings --

9 MR. FREESMAN: You were focused on this hot

10 water, I think, before.

11 MR. LaFRANCE: Yes.

12 MR. STILWELL: I believe that was factored

13 in.

14 MR. FREESMAN: Oh, it was, and that's why

15 the numbers were lower than I think Marc was looking

16 for.

17 MR. LaFRANCE: Maybe that's why. Like I

18 said, we just recently received the data, and I'm

19 glad that Wayne pointed that out, that it's 11

20 percent, because when I first looked at it, it looked

21 like minimal.

22 I couldn't understand what was happening,

23 especially when I looked at the combined options with

EE-RM-94-230 COMMENT 0D
101

1 vertical-axis, automatic fill control,

2 thermostatically controlled mixing, and then RMC.

3 Again, I didn't look at the recalculated

4 baseline, and I need to do that, and I'm glad it was

5 pointed out to me.

6 MR. STILWELL: I think the formula that was

7 arrived at is a pretty fair estimate of the potential

8 savings. As I said earlier, until we actually get

9 units out in the field and get field test results on

10 them, we won't really be able to confirm that or deny

11 that.

12 Based on everything that we know at this

13 point in time, we think that's a very fair estimate

14 of the savings that are available.

15 MR. LaFRANCE: Okay.

16 DR. HAWKINS: And going through the math of

17 it, it ought to follow out, to show the savings. It

18 ought to show that there.

19

20

21

22

23

EE-RM-94-230 COMMENT 0D
102

1 REDUCED REMAINING MOISTURE CONTENT

2 MR. LaFRANCE: Okay. The next point I hav

3 on the agenda deals with reduced remaining moisture

4 content.

5 The first topic deals with the potential

6 consumer use. I'd like to get some feedback.

7 Do people believe that consumers want lower

8 RMC in their clothes washer? And, if so, if it's an

9 option to them, I need a time or speed or both of the

10 spin cycle.

11 Do you have any feedback as to whether

12 consumers will actually use it; and, if so, to what

13 percentage they'll use it? And should this be part

14 of the calculations for MEF?

15 I know that AHAM his proposed not to

16 include anything like that. They've mentioned that

17 it should be based on the energy test cycle for

18 cottons and linens. I guess that a manufacturer

19 would provide literature to the consumer, which would

20 indicate a recommended spin speed for that cotton and

21 linen load.

22 But we're just looking for any feedback as

23 to do consumers really want to produce RMC or what's

EE-RM-94-230 COMMENT 0D
103

1 the feedback on that?

2 MR. STEPHENS: I can offer one comment.

3 The consumers we've begun to talk to about

4 our program recently haven't so much zeroed in on

5 remaining moisture, but they've zeroed in on the

6 concept that it might shorten the dryer cycle and

7 make the dryer cycle closer to the length of the

8 washing machine cycle, and that for people who do a

9 lot of successive loads or like to get their laundry

10 done in a short period.of time, they like that idea.

11 So, to that extent, it's kind of an

12 indirect effect but that's what they seem to zero in

13 on.

14 MR. WASSON: In showing higher spin, it's

15 been mentioned about showing the consumer what speed

16 to spin at, and most of the European style washing

17 machines, it does give a high-spin speed for cottons

18 and linens, and then it does show a reduction in spin

19 speed when you're using perma press type fabric or

20 even wool and even some silks, it'll actually show no

21 spin; have the machine stop with just a draining,

22 again, for wrinkling in the machine.

23 So vour European -- Z __- style. Z--I vour _ ___ hori7nnta_

EE-RM-94-230 COMMENT 0D
104

1 machines with higher spin speeds, do give a selection

2 availability of either a very high to a medium to

3 either a no-spin.

4 We find that, again, no test data

5 available, just consumer comments to us that they're

6 drying time is cut down in the cotton cycle by using

7 the higher spin.

8 That's got to inevitably cut down the

9 energy for the dryer.

10 MR. LaFRANCE: Are there any comments?

11 [No response.]

12 The next point is fabric care with reduced

13 RMC levels. That's the wrinkling or polka dying, or

14 whatever you want to call it, and trying to get some

15 feedback as to what people have to say about fabric

16 care with lower RMC.

17 MR. WASSON: Again, I keep referring back,

18 because there's no actual test data for the

19 United States. However, there is test data available

20 from Europe, and if that is needed, as far as the

21 type of fabric, the amount of wrinkling, the amount

22 of spin speed that is needed, that can be gotten from

23 our laboratory over at the factory, and also from

EE-RM-94-230 COMMENT 0D
105

1 SAMCO, which is an independent testing company for

2 safety and also performance on the machine. That

3 information can be gotten.

4 We find that there are some complaints as

5 far as wrinkling where they use the higher spin speed

6 on certain fabrics but on, again, the cotton and

7 linens, we do not get the complaints of the wrinkling

8 from the high spin of taking the moisture out.

9 Our feeling is it's the fabric that's going

10 to cause.the dryer to run the longest time anyway.

11 It's generally not the perma press of the

12 other fabrics that cause it to run excessive length

13 of time because the remaining moisture content will

14 be lower on those fabrics than it will be in the

15 cotton.

16 MS. RANSDE: Our experience is we haven't

17 been able to find a lot of data regarding the effect

18 on clothes care from reduced moisture content.

19 One concern that we have, though, is the

20 increased use of irons to press clothing if the

21 wrinkled clothing were in the washers.

22 MR. JACOBSON: I support that same kind of

23 thought that there's no data. We do know that

EE-RM-94-230 COMMENT 0D
106

1 ironing in Europe is a far wider practice, household

2 function --

3 VOICE: Art.

4 MR. JACOBSON: -- art -- function, than it

5 is in the U.S. There is already many consumers in

6 the U.S. who have absolutely given up on ironing, and

7 the kids and so on just say I don't have time for

8 this anymore, and they don't.

9 The extent to which you encourage more

10 irony, you're going to disenchant consumers on the

11 one hand and, to the extent that you do encourage or

12 achieve greater ironing, you've got an energy factor

13 for ironing that ought to be added into the equation

14 somewhere.

15 MR. POPE: I have a question for Ron.

16 Is there a correlation between, was there

17 increase in ironing over in Europe in response to, I

18 think it was only a very recent increase on the spin

19 speed on the European washers, or is that just a

20 cultural thing over there?

21 MR. JACOBSON: I do not have the answer to

22 that directly. It may well be cultural as much as

23 anything. We'd have to look and see. I just don't

EE-RM-94-230 COMMENT 0D
107

1 have the data. I can look at it.

2 MR. FREESMAN: Michael made a point before

3 about the spin speeds going up, but he also made a

4 point about varying the capability of spin speeds

5 that consumers have access to.

6 If we're going to somehow analyze the

7 payback on this type of option and we're going to

8 recognize that we cannot bring everything to the

9 level of 50 percent or 40 percent or 30 percent, or

10 how ever low you want to get the RMC to, we recognize

11 that the consumer needs to have options.

12 If you're going to look at the payback of

13 this option, you've got to recognize that you're

14 going to have spin speed usage factors. How often

15 will they take it down to maximum and how often will

16 they leave it at another variable?

17 I mean, today we have variation in terms of

18 spin speed. You have the high and low spin speeds.

19 To assume that they're going to take it to the max on

20 every load would be false, and to calculate the

21 payback on that would also be false.

22 I think if we're going to look at that as a

23 viable option, there needs to be a lot of work done

EE-RM-94-230 COMMENT 0D
108

1 on RMC usage factors, whatever you want to call it.

2 MR. JONES: Marc, that was in testimony

3 yesterday, that I guess Michael wants his comments

4 supported. It's apparently in existing machines

5 where high-spin speed is something which is promoted

6 and gets marketed. There is the provision made for

7 the ability to select it out.

8 Therefore, if you're going to rely upon RMC

9 levels, if you're going to analyze that as a design

10 option, you've got to have some kind of a discounting

11 factor which, again, I suppose could be determined

12 based upon analysis, whether it's field studies or

13 whether it's some kind of just presumed factor, which

14 automatically would be applied. I believe that's a

15 valid point.

16 Similarly -- and I hadn't thought about

17 that -- but your point is well taken, I think, as

18 well, in terms of the analysis. Our concern has

19 always been that DOE has looked at that as kind of a

20 panacea, and in fact it might not be.

21 To the extent that it sort of push folks

22 and rely upon RMC, we need to look at that possibly

23 differently, both in.terms of payback and consumer

EE-RM-94-230 COMMENT 0D
109

1 problems.

2 MR. HAWKINS: I'd also like to add to

3 Earl's comments that, as we mentioned yesterday, our

4 search for information has not revealed any of the

5 high-speed washers that are, in fact, demonstrating

6 low RMCs through the way the designs are executed.

7 Maybe they're getting the high spin speeds

8 but not at a time length effective enough to get the

9 water out.

10 We'd like to see data from anywhere that

11 says, in fact, they are being used effectively for

12 driving down RMC if it's there.

13 MR. WASSON: If Larry doesn't mind that

14 data being more European information than U.S., that

15 is available showing time to RMC and actually even,

16 one thing that I'll even state, you get to a certain

17 point where there's no more moisture taken out,

18 unless you go well beyond the realm of financial

19 capability.

20 But there is information that says from

21 here, at this length of time, you'll take out this

22 moisture; this length of time this. moisture, and that

23 data can be aiven. __ _ __ -- - --

EE-RM-94-230 COMMENT 0D
110

1 MR. HAWKINS: Don't dispute that that is

2 not a relationship, Michael. The question is, is

3 that really being executed in designs in the market

4 when you run it through the cycles, provide it to

5 consumers. In fact, it does run at those speeds for

6 a long enough time to go down to those lower RMC

7 values?

8 Not that there is not a relationship that

9 exists, but is that relationship being executed for

10 product design, and so being used by customers in the

11 field?

12 MR. JACOBSON: Such as, does it spin at

13 1500 rpm for 30 seconds.

14 MR. JONES: I am curious. What levels are

15 we talking about are European products that are

16 achieved? What RMC levels are actually being

17 achieved? Do you have any sense of that?

18 MR. WASSON: I can get that information for

19 you, Mr. Jones.

20 MR. JONES: So when you speak about high

21 spin speeds in our discussions here today, we're not

22 sure whether that's 60 percent or 55?

23 MR. WASSON: We've got numbers on it, I

EE-RM-94-230 COMMENT 0D
111

1 just don't have it or I can quote it to you right

2 now.

3 MR. POPE: We have some limited data on

4 that with testing mostly European products, and there

5 is a definite correlation, at least as tested in the

6 AHAM test procedure.

7 It's definitely apparent in the graphing of

8 the data, with 50-50 column cotton-poly, you get RMCs

9 correlating with the spin Gs.

10 I have -- I guess that's not going to be

11 helpful.

12 MR. LaFRANCE: I guess also getting back to

13 Mark Freesman's question or concern about the various

14 fabrics and the potential use of lower RMC option on

15 the machine, the test procedure right now, as

16 proposed by AHAM, only uses the cotton linen for the

17 entire test. It doesn't use other types of fabric.

18 I'm not saying that's valid or not valid.

19 It pretty much maintains what was in the existing

20 test procedure already.

21 If you're talking about a particular fabric

22 that is very delicate, let's say silk, whatever a

23 consumer does with that particular fabric is not even

EE-RM-94-230 COMMENT 0D
112

1 representative in the test procedure. So I think I

2 would be more inclined to learn about how people

3 would select RMC with a cotton-linen test load,

4 because that's what's being used for the measurement

5 of the energy factor or the modified energy factor.

6 Or, if you don't agree with the cotton7 linen fabric being used for the test cycle, then that

8 should be used for everything else.

9 So it just seems as if we can't really talk

10 about other fabrics for RMC options and then keep the

11 test procedure for cotton and linen for the entire

12 energy test to begin with.

13 I think it's doubted that consumers may use

14 other spin speeds but different fabrics, but we're

15 assuming that the entire testing is going to be done

16 on cotton and linen.

17 I think we should try to keep it toward

18 that or explain why using something else.

19 MR. FREESMAN: I don't have a problem with

20 that, because that's the test procedure to measure

21 its capability. But if you want to bring the reality

22 with it, if you're going to offer a consumer

23 something other than RMC, you have to recognize that

EE-RM-94-230 COMMENT 0D
113

1 in the payback you won't get the same kind of -- the

2 consumer will not be realizing the same paybacks as

3 the analysis indicates, because the analysis assumes

4 100 percent.

5 If you want to get into -- I mean, like you

6 say, you can get into the nth degree and look at all

7 of the possible things that it will wash, and get

8 down there and do that analysis, but the test

9 procedure is there to measure effectiveness and

10 understand where it stands relative to other things.

11 MR. POPE: But, Mark, doesn't the RMC or

12 calculations refer to 50-50 cotton poly, whereas I

13 assume the savings to be bigger with cotton and

14 linens that are a much higher proportion of the

15 cotton, so wouldn't that tend to balance the

16 equation?

17 MR. FREESMAN: Unfortunately, I'm a

18 marketing guy not an engineering guy. I'm not in a

19 position to answer that question.

20 [Laughter]

21 MR. LaFRANCE: Is any company in the

22 position to answer that question about the impact

23 with cotton? How much is the consumption for cotton

EE-RM-94-230 COMMENT 0D
114

versus -- I mean --

MR. STILWELL: That is a valid point, yes,

because with the mix, the load, the polyester cotton

load, you're starting at a lower moisture level to

begin with, and even though you reduce both of them

from the same percentage, obviously, you're working

with less moisture to begin with in that mix load

than you are with a cotton load. So, yes, it does

tend to kind of balance out.

MR. NANTHEIL: The cotton load may not get

down to the level of the cotton poly.

MR. STILWELL: No, but I mean percentage

wise, they'll both be reduced by about the same

amount.

MR. POPE: Yes. You start out with a

higher RMC with cotton coming out of the clothes

washer and you get down to its loads of 50-50, but I

think the spread is probably bigger.

MR. LaFRANCE: I guess on this particular

issue, I've heard several companies indicate that

there possibly should be some type of usage factor.

I guess for us to even consider that, we

need to get some information, a rationale, as to what

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

EE-RM-94-230 COMMENT 0D
115

1 it would be and how it would be applied and the basis

2 for it.

3 So if you could provide that, we'll

4 consider it, and we may or may not accept it,

5 depending on some of the issues that have been

6 brought up, and depending on what it is and how it

7 looks.

8 MR. FREESMAN: I'm not so sure that that

9 data is really going to exist in the North American

10 framework. My concern is that to assume that 100

11 percent usage is a bit false, and I think it would be

12 erroneous to do that.

13 I think it behooves all of us to go out and

14 find, or come up with something, that's appropriate,

15 rather than assume 100 percent until someone proves

16 otherwise.

17 MR. JACOBSON: I would presume that from

18 the composition data that we have and that kind of

19 thing, that we probably could go through and make a

20 pretty reasonable estimate of the percentage of

21 cotton loads and cotton linen loads, and so on.

22 You could make a pretty reasonable first

23 stab, but I do believe you'll have to have market

EE-RM-94-230 COMMENT 0D
116

1 experience before you find out what's really going on

2 here to get it fine tuned.

3 That becomes a question of how does the

4 test procedure want to deal with something like that.

5 Do you want to go in with reasonable

6 estimates, to begin with, or do you really want to

7 figure out some other way of tackling it?

8 MR. LaFRANCE: The considerable load type,

9 fabric type and load type, would be like a

10 sensitivity analysis.on real use. Obviously, our

11 goal is to establish a test procedure that matches or

12 that represents the consumer usage as close as

13 possible with reducing test burden.

14 Through that, we've established a cotton15 linen type of test load for energy consumption.

16 Now, the entire energy consumption is based

17 on that type of load, everything involved.

18 Now we're looking at one particular design

19 option for a portion of the energy that's being used

20 on the MEF calculation.

21 So I guess it's still a fundamental

22 concern. If we're going to start worrying about

23 sensitivity for load type, for that one particular

EE-RM-94-230 COMMENT 0D
117

1 design option, which is one element of the energy

2 consumption, then we should be concerned about it for

3 the entire energy consumption overall.

4 Now, I'm not saying we should adopt or we

5 shouldn't. What I'm saying is that if the industry,

6 which they have, reached consensus that the entire

7 energy testing should be done on a cotton linen

8 basis, then it seems to me that for this one

9 particular design option, to assess the potential

10 energy savings for it in the future, which we all

11 know we don't have the data today, then it would be

12 reasonable to assume the same type of fabric load.

13 Now, if you're saying that within the use

14 of the cotton linen load type, some people may not

15 choose to go the higher or the reduced RMC, and if so

16 what would that percentage be?

17 If we stop messing around with the variable

18 of low type for one design option, then it seems as

19 if we would have to bring it up for the entire

20 analysis and the entire test procedure.

21 Now, at this point in time, the industry

22 does not support that because that's not what they've

23 provided, so we just can't have it both ways.

EE-RM-94-230 COMMENT 0D
118

1 MR. HAWKINS: I would like to comment just

2 a little bit on that. First of all, the new test

3 procedure that we developed steps off of a test

4 procedure for vertical-axis washers that uses no

5 load -- no clothes, article in the machine at all --

6 which has everything to say that load or not, whether

7 it's cottons, whether it's polys, whether it's silks,

8 is not a factor in measuring the energy use of that

9 water.

10 That's primarily, I believe, true of our

11 designs. They're insensitive to the kind of articles

12 that's in there when they go to fill, amount, not

13 necessarily, type of fabric.

14 We used as a test load in our new test

15 procedures the same load that is currently specified

16 in dryers.

17 That was convenient, it was there, we all

18 have them; we have data with them. Again, the belief

19 that whether we had 100 percent cotton swatches or

20 50-50 blend swatches on the fill part of the washer,

21 would have negligible to no impact up on the

22 measurement.

23 It's different when vou talk about the ---

EE-RM-94-230 COMMENT 0D
119

1 extraction process. The water, the mechanics of the

2 way the water comes out of the clothes, is different

3 between polyesters, blends, and 100 percent, and it

4 becomes more germane in that discussion of extraction

5 than ever was in the discussion of water consumption,

6 hot water, cold water, or whatever temperature water.

7 We all know, I believe, in the industry,

8 that it's much more difficult to get water out of

9 cottons than it is off the blends and synthetics.

10 I think that's really what you're talking

11 about there when you're talking about extraction.

12 So, to say that we've accepted cottons and lines,

13 historically, the base energy of washers is a valid

14 reason for ignoring fabric type, fabric type load

15 size, speed, time, factors I talked about yesterday,

16 and even the amount of surfactant that's left in the

17 clothes, I think can completely change the resulting

18 outcome statement of the energy benefit.

19 So I guess I would say that it's an

20 oversimplification, say, that we've ignored it

21 previously, so we should be able to ignore it now.

22 MR. LaFRANCE: I guess I understand your

23 comment and, in considering that, you have a cycle

EE-RM-94-230 COMMENT 0D
120

1 type. So, in the past, historically, we have always

2 used the normal cycle which is based on cotton and

3 linen. So when we look at fabric type, which you

4 have merit, obviously, you would look for the type of

5 cycle and fabrics that are used in that type of

6 cycle.

7 This might be going a little bit ahead of

8 myself here, but if you have a delicate cycle with

9 silk, for example, I don't think that would be really

10 representative, but if you have an energy test cycle

11 that you're using for cotton and linens, and it

12 happens to be named in Regular, and you put in there

13 permanent press and you put in there cotton and

14 linen, and you have different ratio values for both

15 of those, how you would use them, then maybe that has

16 some merit, because now you have different fabric

17 type by the same type of load size, the same type of

18 cycle that's selected.

19 I guess if you're going to start factoring

20 in a delicate cycle with a delicate fabric that's

21 only used less than 10 percent of the time, then

22 maybe that doesn't have as much merit as it would if

23 it was different types of fabric but on the same type

EE-RM-94-230 COMMENT 0D
121

1 of cycle, and that would come in with the historical

2 part of it.

3 MR. THIEL: I think, though, that the one

4 distinction that we may be missing in this

5 decision -- and anyone can correct me if I' wrong --

6 but on all of the design options, we are looking at

7 for washers, the assumption with the design

8 assumption is that the manufacturer will apply the

9 design option so that it washes clothes. That is,

10 the performance of the design option is a given.

11 The only thing the test procedure measures

12 when it evaluates that design option is the

13 consumption of energy.

14 When you're talking about RMC, however, you

15 are talking about the performance of a particular

16 function that you are measuring, which is the

17 extraction of water, and so, qualitatively, when you

18 look at RMC as opposed to all of the other design

19 options on the table, it is qualitatively a different

20 analysis because you are measuring performance as the

21 necessary outcome.

22 You don't measure performance of any of the

23 other design options.

EE-RM-94-230 COMMENT 0D
122

1 Isn't that right?

2 MR. STILWELL: Yes.

3 MR. THIEL: This is the only place we are

4 measuring performance quality of the machine, with a

5 nexus to energy. In all other cases, the performance

6 of the machine is a given, that it will wash clothes.

7 MR. MILLER: The performance of the options

8 is not a given relative to their energy performance.

9 This is measured for all options.

10 MR. THIELE: No, that's absolutely right.

11 That's the point I'm making. The test procedure

12 measures energy and assumes washing performance.

13 RMC, however, measures the water extraction, which is

14 the quality that you are attempting to receive.

15 So this is the only case where you're

16 measuring the performance issue as part of the test

17 procedure.

18 MR. MILLER: I guess I'm not clear on why

19 that's --

20 MR. THIEL: Because in all the other cases,

21 it's assumed that the machine washes clothes, and we

22 could care less what the clothes are, at least as far

23 as the test procedure is concerned, because the

EE-RM-94-230 COMMENT 0D
123

1 assumption is that clothes are getting washed, while

2 whatever here is happening is happening, and all

3 we're going to do is measure the energy it takes to

4 achieve that outcome: Clean clothes.

5 Whereas, in this case, the outcome is

6 reduced moisture, and you're measuring it, and then

7 you're also measuring the energy that goes along to

8 achieve that performance.

9 Here, there is a correlation between energy

10 and performance, whereas, that correlation is not

11 established in the test procedure for any of the

12 other design options. That's why the load becomes so

13 important in this case.

14 MR. STEPHENS: I think you've actually

15 wandered off the, it washes clothes path a little

16 already, as soon as you start to use any kind of

17 technology that automatically adjusts fill level or

18 even, for that matter, provides some level of fill,

19 based on what you're washing and how much of what

20 you're washing you're washing.

21 MR. THIEL: But the assumption is still

22 built in, that the manufacturer is going to adjust

23 his adaptive control in such a way that the

EE-RM-94-230 COMMENT 0D
124

1 manufacturer is getting the requisite performance he

2 needs to sell that in the marketplace.

3 MR. MILLER: I guess the point to me would

4 be that you're saying for RMC the type of fabric

5 affects the performance, and therefore you need to

6 take into account, and that's not true for any other

7 option, and I don't necessarily agree.

8 For example --

9 MR. THIEL: No, no, you're absolutely

10 right. The type of fabric will affect the

11 performance, but in all other cases we don't measure

12 it in the energy context.

13 MR. MILLER: But that is, I think, Marc's

14 case, is that we're not taking it into account for

15 evaluating these other options, why should we only

16 take it into account for evaluating RMC?

17 MR. THIEL: Because in all other cases it's

18 irrelevant.

19 MR. MILLER: That's not necessarily true.

20 For example, adaptive control, poly fabrics or

21 fabrics that absorb less water may actually show

22 better savings, better performance of the adaptive

23 control feature because since they absorb less water,

EE-RM-94-230 COMMENT 0D
125

1 the adaptive control will need to add less water, and

2 therefore the adaptive control wouldn't show any

3 better performance with the synthetic loads.

4 MR. THIEL: I'll defer to the engineers on

5 that. You may be right on that point, but it's my

6 understanding that, by and large, all of the design

7 options would go to wash and performance, the

8 assumption built in, but we don't have a washing

9 standard. We don't have a performance standard for

10 the washing process. All we're doing is measuring

11 energy consumption.

12 MR. RIECHMAN: One of the things we don't

13 measure in RMC is fabric care. We're measuring the

14 remaining moisture content but we aren't measuring,

15 saying that it has to meet a standard on wrinkling or

16 fabric care, whatever that may be.

17 So I kind of look at it that we are

18 measuring the same types of things in both and not

19 setting performance measures through it.

20 MR. JONES: Do I understand, Terry, that

21 your point, then, is that somehow that it's invalid

22 to focus on RMC because it's performance oriented?

23 MR. THIEL: No. I was simply commenting on

EE-RM-94-230 COMMENT 0D
126

1 the fact that the load of the wash load makes a

2 qualitative difference in the consumer-related

3 performance RMC, whereas the wash load has no impact

4 whatsoever in the test procedure when you're looking

5 at all the other design options, because the

6 assumption is that when you wash the clothes, the

7 clothes get clean.

8 MR. JONES: What should follow from that?

9 MR. THIEL: I was simply responding to the

10 discussion that said that the analysis of the types

11 of clothes that consumers wash, whether they're all

12 cottons and linens, or whether there's some mix,

13 whether you need a tough effort for this, that that

14 difference in clothing had a direct relationship to

15 RMC that you didn't see in any of the other design

16 options.

17 MR. STILWELL: I thank that in most of

18 these cases we're trying to make the best estimate we

19 can of energy consumption. In this case, by using a

20 cotton poly mixture in the RMC test, we're probably

21 understating a little bit, the total amount of water

22 that's carried over on average and actual use.

23 But, by assuming 100 percent usage of that,

EE-RM-94-230 COMMENT 0D
127

1 we're probably overstating it on that side. So I

2 think, all in all, it probably tends to average out

3 somewhat.

4 MR. FREESMAN: I think the issue isn't what

5 happens inside the washer so much as what happens

6 inside the consumer's head. You get 100 percent

7 cottons, but they're not going to want to spin it at

8 full speed because they're wrinkle, and there's

9 certain things they don't want to wrinkle.

10 Now you're going to take cottons and divide

11 them into two different loads, those that I don't

12 want wrinkled and those that really won't wrinkle, so

13 towels versus shirts.

14 I don't want to iron these hundred percent

15 cotton shirts, and if I spin them at a lower speed, I

16 don't have to iron them. I can put them in the dryer

17 a little bit, or whatever method that I use.

18 The issue is that if you've got choices for

19 the consumer, you're going to have usage factors that

20 need to be taken into account. You can design that

21 test procedure. Terry's point is us need, perhaps, a

22 different test procedure to measure RMCs than you do

23 to measure enervg consumption.

EE-RM-94-230 COMMENT 0D
128

1 Is that what you were saying, Terry?

2 MR. THIEL: Well, I didn't have a

3 conclusion to offer. I was simply making an

4 observation that they're factually different

5 explorations that you are undertaking.

6 MR. STILWELL: I think ultimately what

7 you're going to find -- and it happens in Europe, and

8 I think Michael gave testimony to that -- is that you

9 get different usage factors.

10 Therefore, you will not -- and even if you

11 assume that cottons hold a little bit more water and

12 it's a little bit more difficult to get out, I think

13 the percentage of the use factors will be

14 substantially greater than the difference in

15 performance between one type of material and the

16 other.

17 To assume that it's 100 percent, using a

18 different test methodology and extrapolating that out

19 to here, would just be false and erroneous.

20 MR. POPE: I'd like to comment on that

21 Marc. I have some limited data in front of me here

22 that suggests that cottons compared to 50-50 poly,

23 just looking at a highball average of some numbers,

EE-RM-94-230 COMMENT 0D
129

1 it looks like it's about high 80 kilowatt hours per

2 pound for a mixed cotton load versus about .57

3 kilowatt hours per pound of water, or 50-50.

4 So it's quite a substantial increase in the

5 energy required to try cotton versus poly, so I

6 suspect that, in fact, the opposite would happen, if

7 you take your RMC and weight them by energy use or

8 savings to dry those different types of fabrics that

9 are associated with those different TUFs.

10 Obviously, that would get very complicated

11 trying to break out all those.

12 MR. NANTHIEL: Maybe we're getting a little

13 too hung up on this fabric issue. The real point of

14 the matter is, as was pointed out yesterday, we're

15 going into some uncharted territory here. Really,

16 consumers are going to expect satisfaction in their

17 laundry process until we know more about it.

18 Each manufacturer is going to probably

19 address that in some way, and whether they elect to

20 put a switch on to override the high-speed option or

21 high-speed design, is yet to be seen.

22 We're going to have to probably account for

23 that, and that's why we're suggesting that that may

EE-RM-94-230 COMMENT 0D
130

1 be a usage factor if there is an option switch to be

2 taken into account.

3 It is a risk that each manufacturing may be

4 accepting.

5 MS. RANSDE: All these comments bring me

6 back to one comment about the LBL data. It concerns

7 us that the number one and two options listed in the

8 data are the 50 percent RMC and the 40 percent RMC,

9 and perhaps those aren't located in the most

10 appropriate place due to comments we made yesterday,

11 in addition to all of the uncertainties regarding

12 those two options.

13 These would be the first two options and

14 all the others options are built.

15 MR. LaFRANCE: Jane, as you know, the

16 reason for the first two is they're the most cost17 effective the way we're analyzing it, and that is

18 based on the AHAM proposed test procedure, which now

19 we're debating the question of whether there should

20 be some type of factor for it, the option; if there's

21 an option on the machine, or whatever.

22 I've also heard other things that are

23 interesting, about the types of fabric being actually

EE-RM-94-230 COMMENT 0D
131

1 tested for the remaining moisture.

2 I believe that the AHAM test procedure was

3 also trying to minimize test burden, which we

4 certainly support.

5 For example, they're running a test with

6 the maximum load, and yesterday General Electric

7 provided a chart that showed that the actual RMC

8 level is reduced with a larger load or increases with

9 a smaller load.

10 So, basically, we're testing at a max load

11 condition and corrating it down to an average load

12 for consumption.

13 I had asked the question about what is the

14 slope of that line that they provided or how much of

15 a difference is it, and possibly -- I mean, this is

16 just an I dare suggestion; the test procedure could

17 be changed to a certain size load, which would be

18 closer to average, with a certain type of

19 composition, if need be. That would be one type of

20 scenario, or it could have some factors.

21 All I'm requesting is that companies go

22 back and look at it from their perspective and

23 provide information as to show they think we should

EE-RM-94-230 COMMENT 0D
132

1 analyze it.

2 Saying something subjectively they should

3 have a credit, that's fine, but tell us what the

4 credit should be and why it should be that and how we

5 should apply it, or if you think there should be a

6 different type of test load used, which would require

7 additional test, in that case, it would probably be

8 the average size not the maximum side, we would need

9 that as well.

10 There are many possibilities, and I request

11 from the industry to come back to us their positions

12 on what should we do. In other words, not

13 subjectively but what we should do, apply X

14 percentage or we should do a certain thing. If you

15 could provide that, it would be very helpful.

16 MR. FREESMAN: I want to ask you a

17 question. The way we're measuring -- and I'm not

18 directly involved with the test procedure

19 development, this is an open question -- we're then

20 measuring the moisture extraction on the 12-pound

21 load and relating that to 392 loads of 7-pound usage.

22 So we're actually trying to determine the payback

23 determined on 392 loads of 12-pound extraction when,

EE-RM-94-230 COMMENT 0D
133

1 in fact, the market is only use 392 loads of 7-pound

2 of washing?

3 VOICES: No, no.

4 MR. STILWELL: We're not that dumb.

5 [Laughter]

6 MR. JONES: This raises another issue

7 again. One of the points that we made was we believe

8 that if you all come up with a standard, which is

9 predicated upon achieving a certain RMC level. Do I

10 understand that your Design Options 1 and 2, of

11 course, are so predicated? Is that not correct?

12 Then to the extent there's a build up from

13 that, 5 and 6, I guess it is, and then additional

14 ones beyond that on the horizontal axis as well.

15 MR. BIERMEYER: All the time options are

16 cumulative here, so you start with 1 and then the

17 other options are added on to that.

18 So then our position would be if you, for

19 example, found yourself setting a standard based on

20 Design Option No. 6, or Design Option No. 12, that

21 that would an unlawful standard.

22 We'll continue to pursue that issue

23 otherwise, of course, but I just wanted to make sure

EE-RM-94-230 COMMENT 0D
134

1 that I was not misunderstanding the way this is laid

2 out.

3 MR. LaFRANCE: As you know, these are laid

4 out in the order of most cost-effective, and it so

5 happens the way we analyze the data, these two are on

6 the top of the list.

7 As you know, if we were to impose a level,

8 let's say, in this case, Level 2 on the design

9 options, then we analyze it, the standard level

10 process would be based on the justification for that

11 type of type of cost and efficiency savings, but the

12 companies would be flexible to how they implemented

13 that.

14 The same as in the past rulemakings; you

15 can implement that in many ways. You can go ahead

16 and do the improved fill control and control valve

17 and something else, and not do the higher RMC, or you

18 could go to a horizontal axis and not do anything.

19 So, in other words, this is what we're

20 using to base the standard on, the standard levels.

21 But what a manufacturer does would be up to them and

22 it would leave it up to the manufacturer's marketing

23 and development decision as to how they would

EE-RM-94-230 COMMENT 0D
135

' 1actually build a product to meet a certain standard.

2 I believe that you are concerned that we

3 establish that -- you opposed the possibility of

4 establishing this data that would require RMC?

5 MR. JONES: That's correct. So I guess I

6 don't understand how you can -- you're suggesting

7 that we could be in a position where we don't have to

8 do that because we can do something that's more

9 expensive, for example. Spend more money.

10 [Laughter]

11 MR. LaFRANCE: Or say it different, Earl,

12 we could do some design options that's not identified

13 yet and not on this list.

14 MR. JONES: Right. Right.

15 MR. LaFRANCE: Provide flexibility to the

16 manufacturer.

17 MR. JONES: Okay. I guess that raises a

18 question in my mind, again, and that is if the basis

19 of the conclusion is something which may not be able

20 to be -- if the data.with which you build your

21 determination at the appropriate level can't, in

22 fact, be mandated, I guess I don't understand how

23 that would not be equally as unlawful, to say, well,

EE-RM-94-230 COMMENT 0D
136

1 we think you can do this -- the only way we know if

2 this can be done is by focusing on RMC, but of course

3 we don't have to do that, we could do it some other

4 way.

5 MR. LaFRANCE: No, no, I don't think we

6 would say that the only way this could be done is

7 RMC. We'd say, from our analysis, we've determined

8 that the most cost-effective way to do that is with

9 RMC, however, leave the option to the manufacturer to

10 do whatever they want to, anything that they want to

11 meet that standard.

12 MR. MARGOLIS: What are the reasons that

13 you say we cannot base a standard on RMC?

14 MR. JONES: Because RMC, getting minimal

15 levels of RMC, requires the expenditure of more

16 energy. You either have to do that by running the

17 machine longer, in the spin cycle, or by increasing

18 the spin, both of which require the consumption of

19 increased energy.

20 MR. MARGOLIS: But the overall energy would

21 be saved.

22 MR. JONES: Well, by that point, our view

23 is, that the statute-requires you to set a standard

EE-RM-94-230 COMMENT 0D
137

1 by product, and to the extent that -- I mean, there's

2 no basis in the statute that I'm aware of, that says

3 the product is the washing and drying cycle.

4 Your numbers look to the dryer, so the

5 savings which you're projecting here are based upon

6 savings in the dryer, and it seems to me that that is

7 not -- you cannot do that.

8 You can't say, we're going to require you

9 to spend more money on the washer and expend more

10 energy in the washer, because we know that'll save

11 energy over the entire cycle; i.e., in the dryer.

12 You make your analysis on what's effective

13 or cost-effective and technically feasible in the

14 dryer and you come up with a standard or you don't.

15 We think the data doesn't support a

16 standard on the dryer, but that's a different story.

17 MR. LEVY: Are you saying that we have to

18 disregard what happens in the dryer?

19 MR. JONES: Yes. You do, if your standard

20 level depends upon that being accomplished in the

21 dryer.

22 MR. LEVY: The answer is yes.

23 MR. JONES: Well, I mean, I can't -- you'll

EE-RM-94-230 COMMENT 0D
138

1 have to answer that. But I'm only saying as far

2 as --

3 MR. LEVY: I'm just asking you what you're

4 saying.

5 MR. JONES: I think what I'm saying is

6 pretty clear.

7 MR. ADAMS: I think we have somewhat of a

8 similar situation between clothes washers and water

9 heaters and dishwashers, and water heaters, where

10 there's an interaction between two different

11 appliances and what you do in one may affect the

12 energy consumption of the other product.

13 MR. JONES: That's a valid point. Perhaps

14 we ought to resolve this entire question by focusing

15 on savings in the water heater and exempt washers

16 altogether.

17 [Laughter]

18 MR. JONES: We would endorse that.

19 MR. ADAMS: Without addressing that --

20 [Laughter]

21 MR. ADAMS: -- let me also say something

22 about the moisture content. The types of standards

23 that DOE has set in the past have been performance

EE-RM-94-230 COMMENT 0D
139

1 standards, and they have not required any particular

2 design option to be incorporated or not, but the

3 level that we set the standard at was at a particular

4 scenario, a way -- a possible way -- of getting to a

5 particular performance level at some particular cost.

6 These products are complicated products,

7 and there's many aspects to them, and there's

8 obviously many ways to skin the cat, so to speak, to

9 get to a certain performance level.

10 Depending upon where a particular

11 manufacturer is starting from their base case, every

12 manufacturer's base case is going to be somewhat

13 different than everybody else's and certain different

14 from the average base case that we use in the

15 analysis.

16 For some manufacturers, it may make more

17 sense economically to achieve performance

18 improvements down this pathway rather than down some

19 other pathway, that might make sense for some other

20 manufacturer.

21 So we're trying to come up with, based on

22 an average base case, a scenario that could be

23 followed to get to a certain performance level, but I

EE-RM-94-230 COMMENT 0D
140

1 don't think we would have any intention of saying you

2 would have to get to some particular residual

3 moisture content. You would have to have a clothes

4 washer that achieved 40 percent moisture retention

5 rate.

6 It would be some energy factor, and

7 whatever makes the most sense, depending upon where

8 you are starting from, to achieve that, would be your

9 option to do.

10 MR. JONES: Right. Again, we appreciate

11 that, and I don't want to carry this too far. But I

12 guess, at the end, wherever you all wound up, could

13 only be achieved, could most cost-effectively be

14 achieved that way, through RMC. We think there where

15 some legal issues there.

16 MR. MILLER: I guess I, first of all, want

17 to thank GE for what I think I heard was their offer

18 of support for a water heater standards and levels of

19 cost-effectiveness. So we'll be contacting you to

20 work on that.

21 [Laughter]

22 MR. JONES: We'll be glad to help you

23 there. We have no technological expertise, as we

EE-RM-94-230 COMMENT 0D
141

1 don't make them.

2 MR. LaFRANCE: We do look forward to your

3 support on that. I think the history of the

4 standards and the legislation itself makes it clear

5 that energy that is saved through improvements in the

6 product can be counted even if they're not saved

7 directly within that product the same way that the

8 hot water is not heated into the clothes washer or

9 the dishwasher. The saved energy in the dryer is

10 energy that's saved from improvements in the clothes

11 washer, and that's the real energy that's saved.

12 The electricity that the washing machine

13 uses is being saved in the power plant not in the

14 washer too. So we would take a different position.

15 Of course, this will be argued in comments, and I

16 don't know if we need to spend much time on it here.

17 At this point in time, I would like get a

18 feeling from the audience as to what their thoughts

19 are of going to a lunch break, whether they would

20 like to stop for lunch now or they feel that most of

21 the remaining issues -- and we have only a couple

22 more on our agenda.

23 Like we said before, we're looking forward

EE-RM-94-230 COMMENT 0D
142

to any comments you have on our presentations from

DOE or LBL this morning and the analysis.

If people.feel they want to discuss things

for a significant amount of time, I think we should

take a break now for lunch.

If people feel that this will only go on

for so much, let's say 45 minutes to an hour longer,

then maybe you want to just continue and finish it.

I would like to get a little feedback from

people on that.

MR. STILWELL: I'd prefer finishing early;

as early as possible.

MR. LaFRANCE: Okay. Sounds good.

MR. ADAMS: Marc, is the only agenda item

left that's written down here, the horizontal-axis

market acceptance?

MR. LaFRANCE: We have also adaptive

control, which I guess we've kind of touched on that

a little bit, about automatic fill control, and I

guess from an adaptive control, looking at soiled

conditions, and we have the AHAM data. I guess we

need to look at that further to analyze it.

We're also requesting that people provide

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

EE-RM-94-230 COMMENT 0D
143

1 any additional information that they might have for

2 soil types. Are consumers presently using more hot

3 water than is needed?

4 I guess we had a big presentation from

5 Clorox as to ways to improve performance and reduce

6 temperature. I don't know that you would have an

7 automatic control bleach dispenser as a possibility.

8 There's a lot of things out there.

9 If anybody could provide any input at all

10 relative to this design option, we'd welcome it.

11 MR. POPE: Marc, what about the discussion

12 on TUFs? Can we cover that quickly today?

13 MR. LaFRANCE: Sure. Did you want to just

14 talk about that right now? The last bullet I have

15 here is horizontal-axis market acceptance, and we can

16 talk about that after.

17 Go ahead.

18 MR. POPE: I just want to get some

19 clarification on what the TUF consumptions were in

20 the calculations.

21

22

23

EE-RM-94-230 COMMENT 0D
144

1 TUFs

2 MR. LaFRANCE: What has happened, to give

3 everybody a little history on it, AHAM had developed

4 a test procedure. They've been working on this for

5 well over a year now. We support them in their

6 development effort and we're very appreciative of

7 that, that they have taken this task.

8 When they presented the Rev 6 version, it

9 had particular TUFs in it, and that's the version

10 they used for the submission of the data. The first

11 data submission to us was the Rev 6 version.

12 Then they had a Rev 8 version, which

13 rejected the TUFs forward with the regression to the

14 year 1999 or 2000.

15 Then, when they sent in their final version

16 on July 5, it had the identical TUFs of the Rev 6 --

17 revision -- which means what we thought to be the

18 final test procedure, had the exact same TUFs as the

19 submitted data.

20 But at yesterday's hearing for the test

21 procedure rulemaking, we learned that they had

22 inadvertently put the wrong TUFs into their final

23 submission to us, and there was a presentation made

EE-RM-94-230 COMMENT 0D
145

1 as to what the TUFs should be from the AHAM

2 perspective, and that that were based on several

3 regressions and projects to the year 1999 versus

4 2000.

5 So a few things remain:

6 One is: We need to work on what should the

7 final TUFs be from the Department's perspective, and

8 get comment on that; whether the regression should

9 just go to the current year or they should be

10 projected to the year 2000, or somewhere between.

11 We'd be interested in learning about the

12 factors that affect reduction in hot water use in

13 laundry relative to warm and hot, whether they deal

14 with soil conditions or types of fabrics, or whatever

15 else is involved.

16 So that we want to do an analytical

17 analysis of this, and also subjective analysis as to

18 whether we expect the trend to continue at the same

19 rate or whether it would be somewhere in between.

20 Then once we get that information, and then

21 we can solidify what the tests should be, then we

22 need to look at the submission of the data to us, and

23 if there's a difference between the submitted data

EE-RM-94-230 COMMENT 0D
146

1 and the final TUFs, then we will need to make a

2 change, which will probably reduce the energy

3 consumption if we change the TUFs from the Rev 6

4 version.

5 So that's just a little history on the

6 TUFs.

7 Go ahead, Ted.

8 MR. POPE: Okay. Now, just a couple of

9 numbers might clarify. What TUFs were used for the

10 three setting machine, were used in this version we

11 have now, the final version of these numbers versus

12 what seems to be currently accepted?

13 MR. HAWKINS: What version do you have?

14 MR. POPE: Okay. I assume I have the same

15 I got faxed yesterday the materials for the

16 engineering analysis.

17 MR. HAWKINS: Is this the engineering

18 analysis that was handed out here? The copy I have

19 is dated 7-7-95.

20 MR. LaFRANCE: Actually, there was a

21 version this morning 7-9-95.

22 MR. HAWKINS: 7-9-95.

23 MR. LaFRANCE: Ted, the analysis you have,

EE-RM-94-230 COMMENT 0D
147

1 the analysis we presented today, is representative of

2 the Rev 6 AHAM TUF data.

3 MR. POPE: Okay. That's the 14 by 50 by

4 36?

5 MR. LaFRANCE: It's 14 for hot, 50 for warm

6 and 36 for cold.

7 MR. POPE: Okay. So that's what's in the

8 numbers here.

9 MR. LaFRANCE: That's in the analysis. But

10 the test procedure that was presented from AHAM

11 yesterday have different numbers.

12 I don't have it in front of me, Larry. Do

13 you have those?

14 MR. HAWKINS: Yes. It's 14 for hot, 47 for

15 warm wash, and 39 -- let me confirm those.

16 MR. JACOBSON: That's correct.

17 MR. HAWKINS: That's correct. Sorry.

18 Numbers are going through my mind.

19 For the warm rinse option, we are not in a

20 consensus decision at AHAM. It's a range of 21 to 33

21 percent.

22 MR. POPE: Is there a precedence for

23 projecting future rates for this kind of standard

EE-RM-94-230 COMMENT 0D
148

1 setting process?

2 MR. JONES: We had a big debate on this

3 yesterday. You don't project rates, you project

4 rates.

5 MR. HAWKINS: If you fix it at the '94, '95

6 level, you're essentially projecting no change at all

7 in the rate, so you can't say because we didn't

8 project, we didn't project. You're projecting

9 something. It's a question of what you're

10 projecting.

11 MR. STEPHENS: I would suggest that you

12 need to know why you're projecting something, too,

13 and do we know that? Do we understand why the rate

14 has been what it is, and we can explain why we think

15 that rate will continue in the future?

16 MR. HAWKINS: I can answer that. The data

17 that we used was P&G data survey. Going back to the

18 year 1975, there were some blanks in the early years,

19 but we used the best data we had, that we obtained

20 from P&G. That's the data that went into the

21 original TUFs, only followed through the years.

22 We analyzed the trend in that data over

23 time. We said that since we were working on a test

EE-RM-94-230 COMMENT 0D
149

1 procedure that was intended to be applicable with the

2 rulemaking that was most likely going to be

3 forthcoming in 1999, then TUFs at that time would

4 either be out of date and need to be updated or else

5 we could look at ahead to project what they would be,

6 based upon the long-term trend that has existed over

7 that long period of time, and project them out.

8 That was the approach we took. We weren't

9 talking about TUFs that would be applied this year on

10 energy measure this year, we were talking about TUFs

11 that would be applicable in the year which the

12 rulemaking took effect, out in 1999, and our concern

13 was what would the TUFs be, given the trend didn't

14 change.

15 We made the assumption that the trend that

16 prevailed through that long period of time would be

17 consistent carrying out the next 4 to 5 years.

18 Again, we also looked at it and said, well

19 if we didn't do that, if we just shut it off in 1995,

20 what you end up is, you have a hockey stick if you

21 look at the trend curve.

22 It says that starting in 1995, consumers

23 didn't change their practices at all, and it really

EE-RM-94-230 COMMENT 0D
150

1 challenges any belief in the analysis of the data

2 that that's what would happen.

3 The reality is that it may be somewhere in

4 between, but in standard forecasting techniques, you

5 take the trend and project it, extrapolate. There is

6 always -- anyone will tell you doing forecasting

7 analysis, there is risk that something could change

8 that's a trend and modify it, but we have no

9 information to say that it would or wouldn't.

10 Given no major change in the detergent

11 formulations, I would assume that line is asatotic

12 (ph) at some point, and I guess I don't know where

13 that is, but I think you can assume it flattens out

14 at some point down the road.

15 MR. STEPHENS: I would also suggest that

16 the price of oil in 1973 kind of took that hockey

17 stick like bend in itself, and a lot of people,

18 including companies like Arco, were taking that

19 handle on the hockey stick and just projecting it out

20 into the future, and about every two years over the

21 last six years, that handle has been coming down

22 flatter and flatter until, at some point, if you had

23 been sitting in 1972, you might have actually reached

EE-RM-94-230 COMMENT 0D
151

1 the 1999 projection for the price of oil if you

2 assumed that there was no hockey stick, it was flat.

3 So there is a reason, actually, I think,

4 given that some of this stuff is actually

5 interrelated to actually analyze why you think

6 yesterday's trends can be projected into the future.

7 There's a lot of them right now,

8 especially, that aren't the same as they were a year

9 ago or even twos or six months ago. People are

10 changing a lot of these trends and prices and

11 people's habits.

12 A lot of other things affecting people's

13 choices are changing right now, too, and I don't

14 argue that you're wrong, I argue that we better

15 understand why we're picking the path we pick.

16 MR. HAWKINS: I don't disagree. It's

17 interesting you pick the price of oil. I would like

18 to point out that the analysis underlying the design

19 options is also forecasting energy cost out in time.

20 We could argue the same points that we're

21 talking about in TUFs. Is that the appropriate thing

22 to do? Why not fix it at the current level.

23 MR. JONES: Yes. Our point is you need to

EE-RM-94-230 COMMENT 0D
152

1 be consistent, and there is no reason why we should

2 presume that what we're working on here is so complex

3 that it is not susceptible to some reasonable

4 statistical analysis as we deal with other things.

5 An alternative approach, and it might be

6 one which is actually more suitable, except that this

7 process that we're working on just seems to get hung

8 up. I would use the word "bureaucracy," but I don't

9 want to insult anybody so I won't say that.

10 But if we could agree on a process by -whic

11 the DOE commits on an X basis every two years to

12 readjust these numbers or to take a look at the data,

13 that's perfectly fine.

14 Nobody's out to get to the point that's

15 unrealistic, but what we are not prepared for is to

16 accept assumptions which put us at a disadvantage

17 when there's data, when there are two ways of

18 understanding where you could be, either by recent

19 projections or by relooking at the data.

20 Certainly sort of standing pat and assuming

21 that you were going to be there on the [inaudible],

22 is not realistic, and that's something that is

23 unacceptable.

EE-RM-94-230 COMMENT 0D
153

1 MS. SMOZZO: What are the explanatory

2 variables that are used in predicting?

3 MR. HAWKINS: The raw data from P&G was

4 analyzed over the time period that were the

5 variables.

6 MS. SMOZZO: I don't have that data.

7 MR. HAWKINS: It was presented yesterday,

8 and it's P&G's consumer survey data that says how

9 often the consumers select the water cycles available

10 or hot wash or warm wash, cold wash, warm rinse or a

11 cold rinse.

12 They tracked that data religiously over a

13 long period of time. It does not describe the data

14 itself what are the underlying deriving factors of

15 why consumers have been moving towards cold water,

16 but it's evident in the data that consumers are

17 moving towards cold water, and all we did was took

18 that data and used standard statistical techniques to

19 say, can we look at it.

20 I'll back up.

21 We originally made a proposal at TUFs based

22 on the latest P&G data. We were asked and commented

23 that that was probably not appropriate to do that, we

EE-RM-94-230 COMMENT 0D
154

1 needed to look at more years of data in order to

2 adjust to temperature usage factors.

3 We agreed that, yes, that would certainly

4 be the more technically precise process to follow and

5 that we would try to do that.

6 So we moved from a point in Rev 6, which

7 was what Marc talked about, that was in the earlier

8 data analysis, we had TUFs in there that was based

9 upon the latest P&G data, and I think that was the

10 year 1993, which is when we set those TUFs in place

11 at that time.

12 We were asked to go back to look at --

13 let's take more than one year to base what we believe

14 is going to be the best estimate of the temperature

15 usage factors that should be applied. We did that

16 and with faith.

17 We asked P&G to send us the best data that

18 they had over a long period of time and just analyzed

19 it.

20 MS. SMOZZO: I'm sorry, just one more

21 point.

22 How many data points are there? This is

23 like 1982 or 1980 to 1994?

EE-RM-94-230 COMMENT 0D
155

1 MR. HAWKINS: It goes 1975, 1978, 1981,

2 yearly through 1994.

3 MS. SMOZZO: Okay.

4 MR. MILLER: Just to make sure I'm

5 understanding, it sounds like what you're doing is

6 just extending a time trend and not trying to put in

7 other explanatory variables.

8 MR. HAWKINS: Exactly. Yes, sir.

9 We did find, in analyzing the data, as is

10 inherent in a lot of time series data, but the data

11 itself was exhibited at auto correlation. If you go

12 to auto correlation, it says that there is an

13 inherent relationship between this year's temperature

14 usage number and last year's and the one preceding.

15 To eliminate that as a variable, one

16 standard technique used is to take and subtract year

17 to year and just get the changes; average those and

18 assume that those changes on the average, through

19 that time period, will be the same level of changes

20 that will go forward in the future.

21 That's the way we did it, because it also

22 allowed us to establish a confidence interval around

23 the data, but we looked at the data using the

EE-RM-94-230 COMMENT 0D
156

1 difference in technique; we looked at it using linear

2 and nonlinear techniques.

3 And while, as there are some differences in

4 the numbers that you project, there was not a huge

5 disagreement in those numbers.

6 I present a curve showing the linear and

7 nonlinear regression and presented a table so I

8 calculate the differences approach at yesterday's

9 session.

10 MR. LaFRANCE: They're presentation from

11 yesterday is available at the information table, so

12 you can get that after. I'm sorry, we might have run

13 out of those, but we'll get some more of them.

14 Also, I'd just like to clarify that the

15 data submitted -- and Larry just explained this but

16 to clarify it a little bit more -- AHAM data

17 submitted was on the Rev 6 version, which was of the

18 recent year, 1992-93, so those numbers we mentioned

19 before, like 14, 50, and 36, those are not from the

20 regression that would go to the year 1994 and 1995.

21 Those numbers are different.

22 NIST has calculated those numbers, one for

23 a series of -- the data for 10 years and data for 16

EE-RM-94-230 COMMENT 0D
157

1 years. So that would be a difference in the TUFs.

2 So are the AHAM final version TUFs.

3 So, depending on what we decide to do for

4 the test procedure, the analysis will need to be

5 revised slightly to account for the new TUFs,

6 whatever they may be. Even if they're somewhere in

7 between, they still probably will have to be

8 adjusted.

9 HORIZONTAL-AXIS MARKET ACCEPTANCE

10 The last item on our-agenda is the

11 horizontal-axis market acceptance. We'll try to get

12 some feedback on that.

13 The point I made in this morning's

14 presentation about the estimated or potential price

15 increase, based on a percentage of the retail cost, I

16 think today's analysis is showing, oh, I believe

17 about a $170 increase to a 383.

18 We're looking at from 383 to increase to

19 555. We're looking for some feedback as to how to

20 analyze the impact to the consumer, you know, to the

21 marketplace and something nontraditional than what we

22 do already, which involves impact to manufacturer

23 sales and net revenue and profit to corporations and

EE-RM-94-230 COMMENT 0D
158

1 everything else.

2 MR. FREESMAN: There's two issues that I

3 would like to get to -- before we get too deep into

4 the horizontal-axis -- two issues that I still want

5 to bring up.

6 One will follow up with comments and that

7 relates to your markup of 1.7; I know I've mentioned

8 this to you before.

9 In calculating that 1.7 and looking at

10 where the average is today, I still think it's

11 appropriate to look at that as an incremental markup.

12 In fact, as you add cost to product, we obviously

13 can't get too deep into that discussion here, but

14 perhaps that markup will vary, probably increase.

15 So that when you look at retail cost of

16 these products, they be substantially higher than

17 what you've represented here. Because, as companies

18 make investments to assist new businesses, they look

19 for greater returns and better paybacks, and they

20 impact on retail pricing will vary by company, but

21 will probably be higher than it is for the average of

22 the business.

23 The other thina that I wanted to add is. i:n __ - - __ - - - - - - - F ---

EE-RM-94-230 COMMENT 0D
159

1 the analysis of payback, there is no identification

2 here of increase in servicing cost of the products.

3 There is no question that as we increase complexity

4 of the product to achieve greater results, there are

5 additional risks related to maintaining these

6 products, both to the manufacturer during the

7 warranty period, as well as post-warranty to the

8 consumer.

9 The analysis is going to assume that the

10 performance -- .I don't want to say the quality, the

11 quality is measuring two different animals -- but as

12 the beast gets more complex, a potential for

13 breakdown is going to increase and that will cost

14 people money in another warranty.

15 That's got to be reflected certainly in the

16 life costs analysis if not between the payback.

17 There's going to be warranty expense and if there's

18 warranty expense, it's going to be reflected in the

19 cost of the product as well.

20 That's a hole that I think is missing in

21 this whole analysis as well.

22 MR. LaFRANCE: I would request that, to the

23 extent possible, if we could receive data relative to

EE-RM-94-230 COMMENT 0D
160

1 that concern about the serviceability of more complex

2 products, they will be helpful.

3 MR. FREESMAN: It's not just

4 serviceability, it's frequently of service.

5 MR. LaFRANCE: I should say service costs,

6 maintenance cost.

7 Also, possibly, maybe Asko might have some

8 information because I believe you have a horizontal9 axis machine that's probably more complex than the

10 traditional machine, and that maybe they have some

11 information on that. So if anybody has any

12 information at all, we welcome it so we can analyze

13 it and possibly add it to the analysis.

14 MR. LEVY: Including any savings that might

15 be achieved. I mean, that's not outside the realm of

16 possibility either.

17 MR. JONES: Savings and?

18 MR. LEVY: Servicing costs. Repair.

19 MR. JACOBSON: Certainly one of us just

20 came out with a new product that talked about being

21 much simpler, fewer component, and that will improve

22 serviceability. If you want to go the other way in

23 making the product more complex, logic would continue

EE-RM-94-230 COMMENT 0D
161

1 in the other direction.

2 MR. LaFRANCE: Your point is well taken

3 that we should look at the serviceability, and if we

4 have data we will look at the impact to maintenance,

5 I should say.

6 MR. JACOBSON: We're going out in that

7 black hole, though again, Marc.

8 MR. LaFRANCE: We're trying to do the best

9 we can with the information we have, obviously, and

10 we're willing to look at anything else that's

11 reasonable as long as we have information to look at.

12 Your point about being more complex more

13 automatically relates to less reliable. I guess some

14 people would have a concern about that, because

15 obviously when you develop a new product you develop

16 it for obsolescence, for reduced parts.

17 I mean, I know you can't correlate it to

18 the electronic world, but when they develop new

19 products with electronics, they have significantly

20 less components, higher reliability.

21 That may be true., that may not be true.

22 All we're saying is anything you have that would

23 justify an indication that it will be such a

EE-RM-94-230 COMMENT 0D
162

1 products, horizontal-axis will be less reliable, and

2 therefore the service rate will increase. What is

3 the existing service rate now, and what is the cost

4 to consumer of the existing baseline service?

5 So we don't have that either, so if you

6 give us the baseline and then some type of rationale

7 as to the reliability either goes up or goes down.

8 But just because it's a more complex

9 machine, doesn't always relate to less reliable. It

10 may, but it may not, depending on how they design -it.

11 MR. JONES: Doesn't that defy logic? I

12 mean, that sounds nice, Marc, but is there any basis

13 in fact for that statement?

14 MR. LaFRANCE: Certainly in other products

15 there are. I mean, for the -- and I really shouldn't

16 be getting involved in this right now, about

17 components, but for electronic industry it's a

18 totally different issue. So I'll just use that as an

19 example.

20 MR. JONES: Yes, but that's simplification.

21 That's not going to make it more complex.

22 MR. LaFRANCE: Well, no. More capability,

23 I should say, instead of complex. Maybe it's the

EE-RM-94-230 COMMENT 0D
163

1 wrong word, complex for capability.

2 So improved capability. Okay? Which we're

3 talking about a horizontal-axis machine. Now,

4 whether or not you can build it with more or less

5 parts, I don't have a clue. I'm not going to say I

6 do.

7 I'm just saying, in theory, when you

8 develop a new technology, some types of products can

9 be made to be more reliable.

10 MR. JONES: Of course.

11 MR. LaFRANCE: Of course. Right.

12 All I'm saying is, that may be true, it may

13 not be true. I'm saying we need information that

14 would prove that, in the case of horizontal-axis,

15 that they are less reliable.

16 Just because it's a new technology and it's

17 different from what you're doing now, I'm saying it

18 doesn't necessarily mean it's always going to be less

19 reliable.

20 You have always the start-up costs of a new

21 development project. When it's new, you have bugs to

22 work out and all that. We all know that's part of

23 it, but the analysis is based so many years into the

EE-RM-94-230 COMMENT 0D
164

1 life of the product, after it's been on the product.

2 MR. JONES: It's perhaps a point which is

3 very difficult to make, because, again, we have

4 building experience.

5 MR. STILWELL: It's all conjecture, at this

6 point.

7 MR. JONES: Exactly. It's all conjecture.

8 MR. STILWELL: There's not even any point

9 in talking about it.

10 MR. JONES: For DOE somehow to assume that

11 this is transition is as simple as adding a

12 component, portrays such an unfamiliarity with what's

13 involved in making these kind of changes, has to defy

14 the comment on it.

15 MR. LEVY: We're not assuming anything.

16 We're just responding to Marc's comment.

17 MR. JONES: No. No, you are assuming. You

18 are assuming something when you say that horizontal19 axis is a design option on which you can simply take

20 what you've got today and flip it on its side or do

21 something else, which sort of makes it an add on.

22 MR. LaFRANCE: Earl, I was responding to

23 Mark's concern about reliability. I'm not saying

EE-RM-94-230 COMMENT 0D
165

1 that they're going to be more or less reliable. I'm

2 just saying provide some rationale for that.

3 As far as the design option concept, we

4 visited all of the plants. We know what's required

5 to manufacture horizontal-axis machine.

6 We realize that requires massive capital

7 investment, completely new tooling for the most part,

8 and it's expensive investment.

9 We also realize that many companies retool

10 occasionally just to change the type of product they

11 have, the type of platform they have.

12 So we realize that it's a major change, and

13 we want to analyze it, and the concern about whether

14 or not it has a higher service rate is a good point,

15 but all I'm saying is, for us to analyze it, we need

16 information.

17 MR. JONES: I understand.

18 MR. LaFRANCE: He brought up the point,

19 maybe it's more reliable, maybe it's less. If you

20 can give us information that justifies that it's less

21 reliable, taking out the initial start-up bugs,

22 because every new design has that, then we have valid

23 data.

EE-RM-94-230 COMMENT 0D
166

1 MR. JONES: No, I don't want to argue with

2 you on that point, I agree with you. I really do.

3 Marc, my question was: What are your

4 assumptions. What are the assumptions in here about

5 service?

6 MR. MORRIS: I'm not trying to take away

7 from the suggestion made by Mark Freesman or what

8 you're saying, Earl, at all, but in response to your

9 request for data on this subject, Marc, one small

10 element of this might be found in the data submission

11 that was made by AHAM to you in the confidence

12 factors.

13 Confidence factors on both the

14 manufacturability and the marketing ability of these

15 design options and/or changes to the product are

16 found in the data that was sent to you and, in fact,

17 I don't find reflected in the analysis that Peter has

18 done so far.

19 It may be a case where you would want to

20 suggest some way of looking at that as one element,

21 one element, of getting at the issue of

22 serviceability or dependability or costs associated

23 with or complexity of design of some of these other

EE-RM-94-230 COMMENT 0D
167

1 situations that are mentioned as design options.

2 MR. LaFRANCE: Thank you for the

3 suggestion, and I think we certainly are willing to

4 do that if somebody could provide us a basis with how

5 we should do it.

6 Just to get back to Earl's question about

7 what's the assumption, at this point in time, Mark

8 was correct that we have not made any adjustment for

9 serviceability, so the basically the underlying

10 assumption that was done -- I don't think really

11 anything. We didn't have any information so we

12 didn't analyze it, so basically the resulting

13 assumption is that it maintained the same.

14 But we didn't really sit down and think

15 about this, to be honest with you. He brought up the

16 issue just now. It's an interesting issue. We would

17 be more than glad to analyze it, if possible.

18 If the confidence factors can be used in

19 any way at all, we would be more than glad to use

20 them. I think, at this point, we probably would need

21 a little assistance from the industry or non-industry

22 members to give us a means to do that, and we are

23 willing to do it if there is a means to do it.

EE-RM-94-230 COMMENT 0D
168

1 MR. JONES: Surely some notion of the chaos

2 theory or some other way of doing this, can come up

3 with a number that might be -- I don't know that you

4 have to look to the industry for this answer.

5 Surely, you all have access to information, which

6 talks about what happens when people or industry make

7 significant changes. Maybe look auto or look

8 someplace else, I have no idea.

9 MR. STEPHENS: I would not suggest looking

10 at auto. You won't get the answer you're looking for

11 at the automobile industry.

12 MR. JONES: Well, it depends on what kind

13 of change you're talking about.

14 MR. STEPHENS: Complete product change.

15 MR. JONES: Like the electric car?

16 MR. STEPHENS: No, to Chrysler, for

17 instance, starting out completely with an entirely

18 new platform that has no basis in their previous

19 automobiles -- the LH, the Neon. There's three

20 product lines.

21 MR. JONES: They've still got gasoline

22 engines, as far as I understand.

23 MR. STEPHENS: Yes, but that wasn't really

EE-RM-94-230 COMMENT 0D
169

1 their reliability problem in history. I mean, their

2 are maintenance problems, their warranty problems,

3 their reliability problems didn't really come from

4 the power plant.

5 The point is, they have done some rather

6 complete technology changes in the automobile, and

7 you would be hard pressed to argue that the

8 automobile is less complicated today than it was 10

9 years ago.

10 MR. JONES: I disagree with you. I think

11 it is much less complicated.

12 MR. STEPHENS: To you, maybe.

13 MR. JONES: Oh, absolutely.

14 MR. STEPHENS: Not to the person who

15 designed it and the person who has to put it

16 together. It does a lot more things that you don't

17 have to worry about, but the way it does it is far

18 more complicated than it used to be, but it's

19 manufactured to a much higher standard, it's much

20 more reliable. We now have vehicles professing

21 100,000 mile maintenance intervals.

22 So it's not clear, based on a number of

23 examples, that complexity breeds maintenance costs or

EE-RM-94-230 COMMENT 0D
170

1 unreliability, but it can.

2 MR. JONES: Your definition of complexity

3 is not an engineer's definition of complexity.

4 That's the only part I leave you with.

5 MR. MARGOLIS: This issue has been raised

6 by Speed Queen, and the department will analyze it,

7 will then go out with its results, looking at the

8 data that we have, or coming up with other data, and

9 we'll present it to you for comments, just like we do

10 with any other part of a Proposed Rule before we go

11 final with it.

12 If industry doesn't have the data, that

13 doesn't mean that DOE will not come up with some

14 numbers, based on certain assumptions that it makes,

15 which it puts out with its numbers.

16 MR. LaFRANCE: Okay. Are there any other

17 topics that people would like to discuss relative to

18 the entire workshop today, the analysis, the

19 presentation, new technologies?

20

21

22

23

EE-RM-94-230 COMMENT 0D
171

1 GENERAL DISCUSSION

2 MR. THIEL: I would just simply like to

3 repeat for the record, in the workshop, a point or

4 two which we had already made to you directly. It

5 relates back to your presentation at the beginning.

6 The first point we'd like to state is that

7 Frigidaire will not be providing any additional data

8 of any manner whatsoever on this rulemaking, and the

9 reason for that is the design option, which will

10 probably affect over 50 percent of the marketplace is

11 not on the table for consideration, and without the

12 ability to do a technical feasibility and economic

13 justification analysis of whatever that design option

14 or combination of options may be, we don't believe

15 that any of the work-you have done to date will be

16 valid or defensible.

17 When that design option and the surrounding

18 data eventually becomes available, everybody is going

19 to have to resubmit their data anyway.

20 We will not, by providing data, give anyone

21 the inference that we think that this process is

22 defensible.

23 The second noint I would like to make fnr ---- ml------ -- -

EE-RM-94-230 COMMENT 0D
172

1 the record is that; in this marketplace, in this

2 industry, we do not believe it is defensible for the

3 Department of Energy to use an average manufacturer

4 analysis, because there clearly is no such thing as

5 an average manufacturer.

6 Until the Department of Energy comes up

7 with some other approach for determining economic

8 feasibility, other than average manufacture analysis,

9 again, we don't think anything coming out of this

10 rulemaking is defensible.

11 MR. MARGOLIS: As to Point 1, could you

12 tell us what design option you're saying is not out

13 on the table?

14 MR. THIEL: Yes. The Whirlpool design

15 option.

16 MR. MARGOLIS: What do you mean by the

17 Whirlpool design option?

18 MR. THIEL: I have no flaming idea, and

19 that's the point. And, frankly, I was disappointed

20 that the Department's presentation did not recognize

21 the fact that that manufacturer, which has over 50

22 percent of the market share, has publicly announced

23 that they will be introducing a high efficiency

EE-RM-94-230 COMMENT 0D
173

1 design option, which they have declined to disclose,

2 which will clearly have an impact on the

3 competitiveness of this industry.

4 MR. JONES: I would just ask a question, a

5 follow up, by way of point of information, to you,

6 Marc, and possibly to Eugene.

7 Exactly how does DOE deal with that issue?

8 Eugene, you indicated how you would deal with the

9 absence of data on serviceability or liability, but

10 how would you deal with the absence of information

11 regarding this design?

12 MR. LaFRANCE: As far as the exact response

13 to that, Earl, I'm going to have to defer to our

14 general counsel, to some extent, but I want to go

15 back, before I do that, to Terry's second point about

16 manufacturer analysis.

17 He said that we conduct an average

18 manufacturer's analysis, ant that is what we have

19 done historically. We do have the capability to

20 conduct an individual manufacturer analysis. The

21 problem is, we can't disclose it.

22 So I'm not saying that we will do that but

23 the capability exists, and possibly we may choose to

EE-RM-94-230 COMMENT 0D
174

1 do that but not disclose it. I don't know how that

2 would work in rulemaking and I don't know what we'd

3 do with it, but I'm just saying the capability

4 exists. What we do with it, we don't know at this

5 point in time.

6 In regards to the Whirlpool announcement,

7 we are certainly going to investigate what we need to

8 do in this rulemaking from a legal standpoint, and it

9 certainly will be considered. We're aware of what's

10 happening, but we can't publicly discuss what they've

11 disclosed to us.

12 MR. MILLER: I have a question for

13 Frigidaire, which were listed to your statement.

14 That is, we have in front of us an analysis

15 with disclosed design options. Does the existence of

16 an undisclosed design option in any way, in your

17 mind, call into question either the technological

18 feasibility or the cost-effective of the design

19 options that are being evaluated?

20 MR. THIEL: Absolutely. Not with

21 technology feasibility, obviously, but there are two

22 aspects of that analysis that we can't address: one

23 is cumulative and the other is comparative. If

EE-RM-94-230 COMMENT 0D
175

1 you'll look on that, you'll see that DOE is ranked

2 and then aggregated design options to try to come up

3 with the optimized design upon which to base the

4 standard.

5 There is a big hole in terms of missing

6 designs to do that accumulation.

7 Secondly, it's comparative.

8 MR. MILLER: Could we do that first point.

9 MR. THIEL: Sure.

10 MR. MILLER: If there were an additional

11 option in here, how would that suddenly make the

12 options which have been evaluated, not cost13 effective? Wouldn't it just show that you could get

14 further faster, for less money?

15 MR. THIEL: Well, you've now gone to the

16 economic side, that was where I was going.

17 MR. MILLER: I'm trying to understand your

18 first point.

19 MR. THIEL: The first point is, I can't

20 give you any sense as to whether I agree with the

21 order of merit of the design options because they're

22 not all out there.

23 MR. MILLER: But the ones that are out

EE-RM-94-230 COMMENT 0D
176

1 there, I don't understand why the ones --

2 MR. THIEL: There may be certain design

3 options there that are much more valuable or much

4 more useful when they are combined with the missing

5 design options.

6 MR. MILLER: But it wouldn't say that you

7 couldn't get -- it would stay but you could still get

8 this level at that cost, so you might be able to get

9 farther at lower costs.

10 MR. THIEL: You might do that.

11 MR. MILLER: Right.

12 MR. THIEL: You're absolutely right. We

13 might do better.

14 MR. MILLER: So that an analysis that said

15 you can get to the levels evaluated in this analysis,

16 and at this cost, that would still be valid, would it

17 not?

18 MR. THIEL: Given the understanding that

19 there would be an overlay of the missing design

20 accumulated with all the various and other options as

21 well, certainly.

22 There's just a whole missing tier of

23 analysis, so from a technical standpoint, which I'm

EE-RM-94-230 COMMENT 0D
177

1 speaking to now, the technical feasibility side of

2 the equation, you may be missing out on the best and

3 the greatest.

4 MR. MILLER: Isn't that always in terms of

5 technological advance, that we can often find things

6 that we didn't expect to find in the future?

7 MR. THIEL: It's a question of degree. In

8 an industry where everybody is in constant process of

9 finding incremental improvements, you're absolutely

10 right. We're not talking about an incremental

11 improvement, we're not talking about climbing the

12 hill, we're talking about leaping a chasm.

13 We're talking about a step function change

14 in efficiency.

15 MR. MILLER: And I'm asking not so much

16 about that future but about the present in terms of

17 looking at disclosed design options, looking at what

18 we have in front of us today. I really have trouble

19 understanding why you believe that this analysis

20 would be somehow invalidated or that this analysis

21 would show --

22 MR. THIEL: It's complete. I'm not saying

23 the numbers would necessarily change on a not design

EE-RM-94-230 COMMENT 0D
178

1 basis.

2 MR. MILLER: But the levels of efficiency

3 at the cost evaluated here would still be achievable

4 and would still be cost-effective even if they

5 were --

6 MR. THIEL: No, no. You see, you've just

7 jumped to the second side of the equation, which is

8 economic justification.

9 I could build you the most technologically

10 feasible washer in the world, and I could do all the

11 calculations and give you what it's going to cost me

12 in terms of material. The question is: Can I recoup

13 that cost in the marketplace, because if I can't sell

14 the product, I can't recoup my cost, and the whole

15 thing is a moot exercise. I've just gone out of

16 business.

17 I've got to be able to produce a product

18 that I can compete with in the marketplace.

19 MR. MILLER: Now you're, in my mind,

20 introducing a third issue.

21 MR. THIEL: No, I'm talking economic

22 feasibility.

23 MR. MILLER: But economically justified. - _ --

EE-RM-94-230 COMMENT 0D
179

1 according to statute, is it cost-effective to the

2 consumer.

3 MR. THIEL: It's also whether or not it's

4 manufacturer impact.

5 MR. MILLER: Manufacturer impact is a

6 separate criteria that the statute discusses.

7 MR. THIEL: But that's part of economic

8 feasibility.

9 MR. MILLER: No, I'm not suggesting that we

10 forget about it, I'm just suggesting that it is a

11 separate criteria in-the statute.

12 MR. THIEL: Okay.

13 MR. MILLER: And that economic

14 justification is a matter of cost-effective to the

15 consumer. I'm asking you whether that criteria,

16 specifically, would in any way be developing.

17 MR. THIEL: The cost-effective to the

18 consumer is one element of economic feasibility. As

19 far as those design options are concerned, obviously,

20 you can go through that cost benefit analysis to the

21 consumer, but you are basing that upon price

22 assumptions.

23 What I'm tellina vou is those nri-c - -- ) . - _ _ ml- ___

EE-RM-94-230 COMMENT 0D
180

1 assumptions are worthless. Because I can go out and

2 sell an apple for a million bucks per, and if I sell

3 one I recoup my costs. The question is whether I can

4 sell the apple.

5 Every single thing we've got in terms of

6 that economic analysis, is predicated upon being able

7 to go to market at some price in order to sell that

8 product.

9 Now, I've got to be able to determine,

10 before I can give you that price, whether I feel I

11 can sell it. I have no way of telling you whether

12 the product I can build, I can sell at a price point

13 which allow me to survive.

14 MR. POPE: Terry, by the same logic, I

15 could tell you that when the h-axis washers come out

16 they are going to be so popular, that people will be

17 pleased to pay $175 or whatever it is; therefore, we

18 should say that the baseline for washers should be

19 higher than it's reflected in the market right now,

20 and therefore the incremental cost is lower.

21 MR. THIEL: I see that, but I don't believe

22 you because, you see, if there is another product on

23 the marketplace that.is just as efficient as that

EE-RM-94-230 COMMENT 0D
181

1 horizontal-axis product, but you don't have to spend

2 170 bucks to get it, then why are they going to by my

3 horizontal-axis machine?

4 MR. POPE: I agree with you there, but --

5 MR. THIEL: Well, there we are. That's it.

6 MR. STEPHENS: Except aren't you

7 presupposing an awful lot?

8 MR. THIEL: Well, if I don't presuppose

9 that, I'm out of business, all right? You're

10 assuming that I can go ahead invest the money,

11 produce a price, walk into the marketplace blind, and

12 hope somebody will buy it.

13 I have got to build that product based upon

14 my best judgment as to whether I can sell it, and

15 you've got to step back and look at this industry.

16 This is not an industry where you have any

17 ability to do an average manufacturer analysis. You

18 have one manufacturer with over 50 percent market

19 share.

20 Now, you're asking me, with what market

21 share we have, which is a quarter, a fifth of that

22 manufacturer; that I can go out into the marketplace

23 and compete not only in terms of features but price,

EE-RM-94-230 COMMENT 0D
182

1 without knowing what that manufacturer is doing.

2 You obviously don't have any experience in

3 the marketplace, with all due respect, if you don't

4 go through that process first.

5 MR. STEPHENS: I guess I'm just wondering

6 what this rulemaking process has to do with that.

7 MR. THIEL: Well, if this rulemaking

8 process obsolesces vertical-axis machines, then there

9 is nothing left to compete with whatever Whirlpool is

10 going to come out with, except horizontal-axis.

11 If the consumer prefers whatever Whirlpool

12 is coming out with to horizontal-axis, then you're

13 not selling any horizontal-axis products either. So

14 the only --

15 MR. STEPHENS: Well, are you going to sell

16 any vertical-axis?

17 MR. THIEL: No, because of efficiencies.

18 Now if Whirlpool has a design that is patented, that

19 no one else can get a hold of, I'd like to ask you

20 how it is with the rest of us in the marketplace are

21 going to compete?

22 MR. STEPHENS: Well, I guess I can't -- if

23 the situation is as drastic as you suggest it is, I

EE-RM-94-230 COMMENT 0D
183

1' don't know how you're going to compete no matter what

2 washing machine you're selling, and we'll know that

3 before 1999.

4 MR. THIEL: Well, I'm going to tell you

5 it's a very difficult marketplace, and you're

6 absolutely right.

7 MR. STEPHENS: And I presume we'll know the

8 answer to that or we'll have a better idea of just

9 how you're going to fare before this standard takes

10 effect, will we not?

11 MR. THIEL: We won't know until we have

12 access to sufficient information to evaluate the

13 cost-effectiveness of the Whirlpool design.

14 MR. STEPHENS: When will that be?

15 MR. THIEL: You'll have to ask Whirlpool.

16 All I'm telling you is that this rulemaking

17 can't go forward until we have that analysis, because

18 we don't have all the design options on the table.

19 MR. STEPHENS: I don't get it. I'm sorry.

20 We could call a halt to progress immediately on that

21 basis.

22 MR. THIEL: You've got to look at this

23 industry and this marketplace. If you don't

EE-RM-94-230 COMMENT 0D
184

1 understand the market dynamics involved, then you're

2 not going to get it.

3 MR. STEPHENS: In my mind -- I mean, I

4 understand, you're in a very competitive industry,

5 and that's true today and will be true tomorrow.

6 If someone comes out with a better product

7 that consumers prefer at lower costs today, with or

8 without a standard, you're going to have trouble

9 competing.

10 MR. THIEL: You're absolutely right. But

11 the market is driving down.

12 [Simultaneous conversation.]

13 MR. LaFRANCE: Excuse me for a second.

14 Please, let's continue to keep our names -- state our

15 names before you make your statement. Thank you.

16 [Laughter].

17 MR. JONES: I just wanted to ask one other

18 question. Again, I'm looking to Gene to help us cut

19 through some of this discussion. It very well be

20 that the concerns that are being expressed are going

21 to be addressed in the rulemaking process, and we

22 just haven't -- we're just not aware of that yet, so

23 why don't we just see what the answer to the question

EE-RM-94-230 COMMENT 0D
185

1 first is from Eugene, if you have one.

2 MR. MARGOLIS: The comments raised by Terry

3 Thiel are such that we have to look at very odd --

4 the issues that he raised, especially the issue, if

5 true, that this design option by Whirlpool was

6 patented.

7 Because if his allegation -- well --

8 MR. STEPHENS: Well, I have no idea. I

9 don't mean it to be an allegation. I just said it's

10 a hypothetical.

11 MR. MARGOLIS: But, I mean, that is

12 something that we would have to consider in our

13 proposing a rule.

14 MR. JONES: Certainly, if you don't, the

15 Department of Justice will.

16 But let me ask you just a follow up again.

17 Am I correct that the statute also requires you to

18 examine all of the designs or technologies which

19 exist in order to come up with which ones make the

20 most sense?

21 MR. MARGOLIS: Well, it's all the ones that

22 we know of.

23 MR. JONES: Well. yes, and vou know of one

EE-RM-94-230 COMMENT 0D
186

1 because you've been told of one, and we've all been

2 told of one. I mean, we're not in the scenario where

3 somebody over here mentioned, where somebody's got

4 something on the shelf somewhere and they're waiting

5 to spring it for competitive reasons because that's

6 the way the market works. We all understand that.

7 We're in a different situation here because

8 this statute requires this department to undertake a

9 certain kind of analysis, to look at certain

10 information.

11 Where we are today in certain information,

12 which they are aware of, which they're all aware of,

13 which is not being made available for that purpose.

14 Therefore, it seems to raise a different set of

15 issues.

16 I don't know what the full implications of

17 that would be, but certainly there's a different set

18 of questions that I've imposed.

19 I think that whether Terry's point is

20 ultimately a valid one or not, it certainly is one

21 which I have a question about, and I think we are

22 looking at some more affirmative guidance from DOE as

23 this process goes ahead, so we clue it in.

EE-RM-94-230 COMMENT 0D
187

1 MR. MARGOLIS: What I would say at this

2 time is that issue has to be resolve before we go out

3 with the proposed rule.

4 That issue is raised and we would have to

5 cover that issue and discuss it in the proposed rule.

6 Whether or not the Secretary would or would

7 not go out with a proposed rule without a discussion

8 of that design option, I cannot answer for her, but

9 it's something that we would have to, in the proposed

10 rule, discuss and either we.put in a design option or

11 the information around it, or would have to say why

12 we're going forward without that design option.

13 But to give you a better answer now, I just

14 cannot.

15 MR. JONES: I understand. I take your

16 answer to be that the point which has been raised is

17 a valid one, the implications of which are not yet

18 fully known.

19 That is, I think, our last point.

20 MR. MILLER: Can I ask one question of the

21 other manufacturers. Can anyone here say that

22 they've disclosed all the options that they're

23 developing for complying?

EE-RM-94-230 COMMENT 0D
188

1 MR. JONES: Say it again, please? Whether

2 we?

3 MR. MILLER: Can any of the manufacturers

4 state that they have disclosed all of the

5 technological options that they are investigating for

6 complying with future standards.

7 MR. JONES: Well, I mean, I, quite frankly

8 am not sure -- I don't know the answer to that

9 question myself, fortunately.

10 I would say to you that the answer to this

11 question is qualitatively different in this

12 particular segment of the industry, given the make

13 dominance of one player. I mean, that's not

14 exactly -- the question, as you put it, is kind of

15 almost -- I won't say irrelevant but it's not

16 completely relevant because there's missing

17 information.

18 If you are the dominant player in a market

19 the answer to that question I think is much more

20 relevant than if you're not.

21 MR. ANDERSON: Excuse me. I would like to

22 at least put this dominance in the market a little

23 bit in prospective, especially for some of folks who

EE-RM-94-230 COMMENT 0D
189

1 might not be as familiar as our industry.

2 We compete in the appliance industry, not

3 just in the clothes washer industry. We happen to

4 have a very healthy market share in clothes washers,

5 but we compete in appliances.

6 When you look at the actual size of the

7 five major companies that are represented here, as

8 far as U.S. production of appliances, especially when

9 we include the total revenue of those companies,

10 we're ranked No. 4 out of those 5.

11 Maytag is smaller than us.

12 Electrolux, General Electric, and Raytheon

13 are all larger than Whirlpool.

14 I think it's important to keep that in

15 perspective, that we are not -- we do not have 50

16 percent of the market share in the appliance

17 industry, nor do we have 50 percent of the revenues

18 of the appliance industry.

19 MR. JONES: You know what they say about

20 figures.

21 [Laughter]

22 MR. LEVY: That statement could have been

23 made much earlier in this meeting.

EE-RM-94-230 COMMENT 0D
190

MS. CLARK: I would like to make a statement

for the record. Because this is a laundry workshop

and we aren't talking about the laundry industry, I

do happen to have the 1994 laundry manufactured share

numbers.

Whirlpool is at 53.8 percent of the laundry

manufactured share.

MR. LEVY: I want to ask Terry a question.

Your statement implies that if any firm

were to come up with a new method of complying with

the standards, some technological advance, that

wasn't previously disclosed for complying with the

standards, that that would somehow invalidate the

standard or the analysis that lead up to it.

I mean, that's what I infer from your

comments. Is that correct or not?

MR. THIEL: I think you have to put it in

the context of, when you say design what you mean.

Okay?

Let me --

MR. LEVY: Did I use the word design? I

said, you know, some technological advance.

MR. THIEL: All right. But I am putting it

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

EE-RM-94-230 COMMENT 0D
191

1 back into DOE's terminology, which is how you

2 evaluate your rules, which are design options.

3 There are two ways of looking at design

4 option analysis, and this is roughly what happened in

5 refrigeration, where you've got a series of design

6 options that may overlap and represent incremental

7 improvements. It's a sliding scale.

8 You can pick any point along that line and

9 put your mark and say that's where my standard is

10 going to be;

11 Now, in that context, people are coming up

12 with new design options all the time -- new

13 condenser, new evaporator, new compressor, new

14 insulation, what have you; some are significant, some

15 are not.

16 But it's part of a melange of design

17 options that all sort of fit together and justify the

18 standard level.

19 What we're looking at here is a step

20 function situation, where you have one basic

21 platform, which is vertical-axis, is going to get you

22 a certain level of efficiency at a certain level of

23 cost.

EE-RM-94-230 COMMENT 0D
192

1 Then you have a discontinuity until you get

2 to the next design option, which has a significant

3 improvement in efficiency, and may or may not have a

4 significant improvement, but here, I'm saying,

5 horizontal-axis gets you a lot more energy and gives

6 you a lot more cost.

7 Depending upon the situation as to whether

8 the design option is available to everyone, which

9 horizontal-axis is, it's a well-known, understood

10 concept.

11 Virtually all manufacturers, I believe,

12 have had it in their product line;

13 Or whether you are talking about design X,

14 which no one knows about, you are going to have a

15 very, very different conclusion. That's the point

16 I'm trying to make.

17 When you're talking about the refrigerator

18 industry, you come up with a different analysis and

19 when you're talking about the home laundry industry.

20 The flip side to that is you've got two

21 average manufacturer scenarios.

22 You've got one. Well, let's say you've got

23 five players. I just pick some numbers. The average

EE-RM-94-230 COMMENT 0D
193

1 is 20 percent, but you're low high variance is 8. In

2 that context, the average manufacturer analysis has

3 some validity for all of the manufacturers. They all

4 look something like that.

5 In this case -- I'm using older numbers,

6 I'm sorry; I have 52 percent for Whirlpool -- but

7 you've got a low high variance of 49 percent. To do

8 any sort of analysis of that number, 4 out of the 5

9 manufacturers aren't accurately represented by the

10 outcome.

11 Now, if you're talking about a step

12 function rulemaking, where you go from here to here

13 and everything that was back on this level is now

14 obsolesced, and everybody has to get to a brand new

15 level with brand new designs.

16 You're talking literally greenfield

17 investment to build whatever that new design is.

18 That has a traumatic impact on the

19 industry. It's going to have a traumatic impact on

20 either of these industries; it's certainly going to

21 make a bigger difference here than it does there.

22 In this case, if we have a new design that

23 nobody else is able to build or is unable to build

EE-RM-94-230 COMMENT 0D
194

1 without paying for it, which puts you at an immediate

2 cost disadvantage, you are inherently giving

3 advantage to the manufacturer with that one design.

4 Now, if it were the three percent

5 manufacturer that had that design, the economic

6 impact of the marketplace certainly would be

7 profound, but I don't think it would be nearly as

8 profound if it's the 600-pound gorilla.

9 That's all I'm saying.

10 I didn't mean that we should resolve this

11 today, I'm just putting it on the record.

12 MR. LaFRANCE: Terry, we also would like to

13 get copies of those two slides so we can add it to

14 the record.

15 [See attached.]

16 MR. THIEL: Sure.

17 MR. LaFRANCE: Thank you.

18 Are there any other comments at all dealing

19 with the laundry rulemaking analysis?

20 [No response.]

21 Okay. We would like to thank everybody for

22 attending today. We encourage you to submit

23 additional data as requested.

EE-RM-94-230 COMMENT 0D
195

1 We appreciate the effort that everybody has

2 taken in coming here. We'll do our best and most

3 objective analysis as possible.

4 Thank you.

5 [Whereupon, the meeting was adjourned.]

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

EE-RM-94-230 COMMENT 0D
DOE DESIGN OPTION ANALYSIS SCENARIOS

"SLIDING-SCALE"

DESIGN OPTION ANALYSIS

"STEP-FUNCTION"

DESIGN OPTION ANALYSIS

60 T

50 +

C

0

S

T

40 +

30 +

20 +

10

0

1% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50%

Energy Consumption Reduction

0% 10% 20% 30% 40%

Energy Consumption Reduction

* Efficiency improvements are

relatively continuous.

* Economic feasibility gradually

diminishes as efficiency improves.

* Efficiency improvements are

relatively discontinuous.

* Economic feasibility abruptly ends

with a quantum leap in efficiency.

"CLIMBING A MOUNTAIN" VS. "LEAPING A CHASM"

T

T. T.Tli 7/795 I -* ,-·

50

45

40

C 35

0 30

25

20

15

10 I

5

0 *

0 50%

. r . . . .- . . --

.

EE-RM-94-230 COMMENT 0D
DOE "AVERAGE" MANUFACTURER ANALYSIS SCEflM1IOS

MANUFACTURERS BY MARKET SHARE

21%

16%

19%

20%

24%

o Average = 20%

* Low/High Variance = 8%

* "Average" Manufacturer

analysis has some validity

for all manufacturers.

MANUFACTURERS BY MARKET SHARE

12%

17%

* Average = 20%

* Low/High Variance = 49%

* "Average" Manufacturer

analysis fails to establish

economic feasibility for

4 out of 5 manufacturers.

T. Thiele 7/7/95.

S O

EE-RM-94-230 COMMENT 0D