1 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov The Parker Ranch installation in Hawaii Test Procedure for Clothes Dryers and Room Air Conditioners



## Supplemental Notice of Proposed Rulemaking Public Meeting Margaret Sullivan

July 14, 2010 Department of Energy Energy Efficiency & Renewable Energy Email. AHAM2 -2008 -TP - 0010@hq.doe.gov2 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Agenda

9:00 – 9:20 am 9:20 – 9:45 am 9:45 – 10:10 am 10:10 – 10:45 am
10:45 – 11:00 am 11:00 – 11:30 am Welcome , Attendee Introductions and Agenda Overview Introduction and Regulatory History Covered Products; Standby/Off Mode: Incorporating by Reference IEC 62301 Standby/Off Mode: Determination of Modes to be Incorporated, Added Specifications to the Test Method and Measurements Break Standby/Off Mode: Calculation of Energy Use, Measures of Energy Consumption3 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Agenda (Continued)

11:30 – 12:00 pm 12:00 – 1:00 pm 1:00 – 1:30 am 1:30 – 2:00 pm 2:00 – 2:30 pm
2:30 – 3:00 pm 3:00 pm Active Mode: Dryer Automatic Cycle Termination Lunch Active Mode: Vent- less Dryers, Detergent Specifications for Dryer Test Cloth Preconditioning Active Mode: Changes to Reflect Consumer Usage Patterns and Capabilities Active Mode: Room Air Conditioner and Dryer Referenced Test Procedures, Technical Correction for Gas Dryers, Clarification to Dryer Gas Supply Conditions Compliance with EPCA; Requirements; Effects of Test Procedure Revisions on Compliance with Standards Closing Remarks and Adjourn4 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

###  Introductions  Role of the Facilitator  Ground Rules (norms)



## – Listen as an ally



## – Use short, succinct statements/keep to the point



## – Hold any sidebar conversations outside of the room



## – Focus on issues, not personalities



## – Speak one at a time (raise hand to be recognized; state your name for the record)



## – Set cell phones to silent/vibrate 

###  Housekeeping Items 

## Welcome and Introduction5 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Introduction Purpose of the Test Procedure SNOPR Public Meeting
 Present the Department’s proposed test procedures for clothes dryers and room air conditioners  Seek comment from participants on the proposed test procedures  Discuss specific issues or questions related to the proposal  Discuss the next steps for the rulemaking6 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Procedure Rulemaking Process

NOPR SNOPR
 NOPR published on December 9, 2008 (NOPR Public Meeting on December 17, 2008)  SNOPR published on June 29, 2010 (SNOPR Public Meeting today, July 14, 2010)  Comments on SNOPR from interested parties 

## • Transcript records oral comments from today’s public meeting 

## • Written comments (comment period closes August 30, 2010)  DOE reviews and considers all comments Final Rule7 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Introduction Regulatory History  Clothes Dryer Test Procedure Final Rule. 46 FR 27324, May 19, 1981. 

## • Established test procedure with provisions for measuring the energy factor (EF)  Room Air Conditioner Test Procedure Final Rules. 42 FR 27898, June 1, 1977; 44 FR 37938, June 29, 1979.



## • Established and amended test procedure with provisions for measuring the energy efficiency ratio (EER). 

## • Incorporated by reference:

– ANSI Z234.1 - 1972, “Room Air Conditioners”

– ASHRAE Standard 16 - 69, “Method of Testing for Rating Room Air Conditioners”8 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Introduction Regulatory History – Continued  Energy Independence and Security Act of 2007 (EISA 2007) Amendments to the Energy Policy and Conservation Act (42 U.S.C. 6291 **et seq** .)



## • Directs DOE to incorporate a measure of standby and off mode energy consumption into its test procedures for residential clothes dryers and room air conditioners.  Clothes Dryer and Room Air Conditioner Test Procedure Notice of Proposed Rulemaking (Issued on December 9, 2008, referred to as the December 2008 TP NOPR)



## • DOE proposed amendments to address the statutory requirement to incorporate a measure of standby and off mode energy consumption into the test procedures. 

## • DOE received comments on the harmonization of mode definitions and testing procedures with the international standards, in particular the consideration of IEC Standard 62301 Second Edition Committee Draft 2 (IEC Standard 62301 CD2).9 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Introduction Consideration of IEC Standard 62301  After the December 2008 TP NOPR, DOE decided to allow for the consideration of a revised version of IEC Standard 62301, which was expected to be published in July 2009.



## • Based on review of drafts of the updated IEC Standard 62301, the revisions could include different mode definitions.  More recently, DOE received information that IEC Standard 62301 Second Edition is not expected to be published until late 2010.



## • Would not be in time for the consideration of standby and off mode power consumption in the concurrent energy conservation standards rulemaking.  DOE decided to publish the SNOPR to consider the new mode definitions from the most recent draft version of IEC Standard 62301 Second Edition.



## • Designated as IEC Standard 62301 Committee Draft for Vote (IEC Standard 62301 CDV). 

## • DOE believes that such new mode definitions represent the best definitions available for the analysis in support of the SNOPR.10 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Introduction Consideration of Active Mode Test Procedures  Framework Document to consider amended energy conservation standards for residential clothes dryers and room air conditioners (October 2007 Framework Document).



## • Published on October 9, 2007. 72 FR 57254. 

## • DOE identified potential revisions to the active mode test procedures for the covered products. 

## • Received comments from interested parties on potential amendments.  DOE decided after the December 2008 TP NOPR to conduct a rulemaking to address active mode test procedure issues for clothes dryer and room air conditioners



## • DOE decided to address the balance of the active mode test procedure issues in the test procedure SNOPR.11 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 1. Products Covered by the Test Procedure Changes 2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures a. Incorporating by Reference IEC Standard 62301 (First Edition, 2005 -06) for Measuring Standby Mode and Off Mode Power in Clothes Dryers and Room Air Conditioners b. Determination of Modes to be Incorporated c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Testing d. Calculation of Energy Use Associated with Standby Modes and Off Mode e. Measures of Energy Consumption12 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Covered Products Products Covered by the Test Procedure Changes – Clothes Dryers  The proposed test procedure amendments for clothes dryers cover both gas and electric clothes dryers. 10 CFR 430.2 provides the following definitions: 

## • “Electric clothes dryer means a cabinet- like appliance designed to dry fabrics in a tumble -type drum with forced air circulation. The heat source is electricity and the drum and blower(s) are driven by an electric motor(s).” 

## • “Gas clothes dryer means a cabinet- like appliance designed to dry fabrics in a tumble -type drum with forced air circulation. The heat source is gas and the drum and blower(s) are driven by an electric motor(s).”  The proposed amendments cover: 

## • Vented gas and electric clothes dryers. 

## • Vent- less clothes dryers, including combination washer/dryers.13 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Covered Products Products Covered by the Test Procedure Changes – Room Air Conditioners  10 CFR 430.2 defines “room air conditioner” as “a consumer product, other than a ‘packaged terminal air conditioner,’ which is powered by a single - phase electric current and which is an encased assembly designed as a unit for mounting in a window or through the wall for the purpose of providing delivery of conditioned air to an enclosed space. It includes a prime source of refrigeration and may include a means for ventilating and heating.”  Proposed amendments cover: 

## • Room air conditioners designed for single - or double - hung windows

– With or without louvered sides

– With or without reverse cycle 

## • Casement- slider and casement- only window-type room air conditioners.14 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 1. Products Covered by the Test Procedure Changes 2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures a. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power in Clothes Dryers and Room Air Conditioners b. Determination of Modes to be Incorporated c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Testing d. Calculation of Energy Use Associated with Standby Modes and Off Mode e. Measures of Energy Consumption15 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Incorporating IEC Standard 62301 IEC Standard 62301 – Testing Methods and Procedures  DOE proposed in the December 2008 TP NOPR to incorporate the same clauses from IEC Standard 62301 First Edition for measuring both standby and off mode power consumption.  Section 4 clauses – provide conditions for: 

## • Supply voltage, frequency, and waveform 

## • Ambient room air temperature 

## • Power measurement meter tolerances  Section 5 clauses: 

## • Clarify the measurement of standby mode for units with a short- duration higher power state before a lower power state 

## • Provide methods for measuring standby mode and off mode power when the power measurement is either stable or unstable (i.e., varies over a representative cycle).16 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Incorporating IEC Standard 62301 Updated IEC Standard 62301  IEC is developing an updated test standard, IEC Standard 62301 Second Edition.



## • DOE anticipated, based on reviews of draft versions of IEC Standard 62301 Second Edition, that revisions could include different mode definitions.  DOE decided to consider the new standby, off, and active mode definitions from the draft version IEC Standard 62301 CDV for the SNOPR.



## • New mode definitions expand upon EPCA mode definitions. 

## • Provide additional guidance as to which functions are associated with each mode.  For the SNOPR, DOE is proposing standby, off, and active mode definitions based on IEC Standard 62301 CDV.17 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Incorporating IEC Standard 62301 IEC Standard 62301 – Testing Methods and Procedures  DOE did not receive any comments opposed to the proposed testing methods and procedures referenced in IEC Standard 62301 First Edition.  The SNOPR does not affect DOE’s proposal in the December 2008 TP NOPR to incorporate by reference the presented clauses from IEC Standard 62301 First Edition. **DOE invites comment on the adequacy of IEC Standard 62301 to measure standby**  **power for clothes dryers and room air conditioners**  **in general, and on the suitability of incorporating into DOE regulations the**  **following specific provisions from IEC Standard 62301: section 4 (“General conditions for measurements”), paragraph**  **4.2, “Test room,” , paragraph 4.3 “Power supply” (for room air conditioners only), paragraph 4.4, “Supply voltage waveform,” and**  **paragraph 4.5, “Power measurement accuracy,” and section 5 (“Measurements”), paragraph 5.1, “General” and paragraph 5.3,**  **“Procedure.” (Issue**  **#1)**18 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 1. Products Covered by the Test Procedure Changes 2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures a. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power in Clothes Dryers and Room Air Conditioners b. Determination of Modes to be Incorporated c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Testing d. Calculation of Energy Use Associated with Standby Modes and Off Mode e. Measures of Energy Consumption19 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Modes to be Incorporated

 DOE proposed in the December 2008 TP NOPR to use the EPCA definitions of “active mode,” “standby mode,” and “off mode.”



## • Also proposed to clarify the range of main functions that would be classified as active mode functions and to define multiple standby modes for both clothes dryers and room air conditioners.  DOE proposed in the December 2008 TP NOPR to define multiple standby modes.



## • Clothes Dryers:

– Inactive Mode

– Cycle Finished Mode

– Delay Start Mode 

## • Room Air Conditioners

– Inactive Mode

– Delay Start Mode

– Off- cycle Mode 

### December 2008 TP NOPR Proposed Definition of Modes20 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Modes to be Incorporated

 DOE is proposing revised active, standby, and off mode definitions based on the definitions provided in IEC Standard 62301 CDV.  DOE is proposing the following definition of active mode. 

## • “Active mode” means a mode which includes product modes where the energy using product is connected to a mains power source, has been activated and provides one or more main functions. 

### Definition of Modes21 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Modes to be Incorporated

 IEC Standard 62301 CD2 provided additional clarification that “delay start mode is a one off user initiated short duration function that is associated with an active mode.”  IEC Standard 62301 CDV removed this clarification. 

## • In response to comments on IEC Standard 62301 CD2 that led to IEC Standard 62301 CDV, IEC states that delay start mode is a one off function of limited duration. 

## • DOE infers this to mean that delay start mode would not be considered a standby mode and that no conclusion is made as to whether delay start mode would be considered part of active mode.  DOE is continuing to propose the additional clarifications for the range of main functions that would be classified as active mode functions, as proposed in the December 2008 TP NOPR. 

### Definition of Modes – Active Mode22 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Modes to be Incorporated Definition of Modes – Standby Mode  Based on the definition provided in IEC Standard 62301 CDV, DOE is proposing the following definition of standby mode.



## • “Standby mode” means any product modes where the energy using product is connected to a mains power source and offers one or more of the following user oriented or protective functions which may persist for an indefinite time:

– To facilitate the activation of other modes (including activation or deactivation of active mode) by remote switch (including remote control), internal sensor, or timer;

– Continuous functions, including information or status displays (including clocks) or sensor- based functions. 

## • Additional clarification that a timer is a continuous clock function (which may or may not be associated with a display) that provides regular scheduled tasks (e.g., switching) and that operates on a continuous basis.23 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Modes to be Incorporated Definition of Modes – Standby Mode  Delay start and cycle finished modes for clothes dryers and delay start and off-cycle modes for room air-conditioners would not be considered part of a standby mode.



## • Not modes that persist for an indefinite time.  These modes each represent a negligible portion (0.1 percent or less) of the annual energy use for each product.



## • An integrated energy efficiency metric would not be measurably affected by either the inclusion or exclusion of the energy use in any of these modes. 

## • Benefit of incorporating these modes is outweighed by the burden on manufacturers to measure power consumption in each of these modes.  DOE is not proposing to define delay start, cycle finished, and offcycle modes or to measure power consumption in these modes.



## • DOE is only proposing provisions for measuring energy consumption in the inactive and off mode.24 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Modes to be Incorporated Definition of Modes – Standby Mode **DOE invites comment on the proposed definition of “standby mode,” which is based on the**  **definition in IEC Standard 62301 CDV. (Issue**  **#2) DOE invites comment on the establishment of inactive mode as the**  **only standby mode for clothes dryers and room air conditioners and the determination that delay start mode, cycle finished mode, and off** **** **cycle mode would not be considered standby modes. DOE further invites comment on the proposed mode definitions and on the**  **question of whether there are any modes consistent with the “active mode,” “standby mode,” or “off mode” definitions under the**  **proposed definitions that have not been identified and that can represent significant energy use. (Issue**  **#3 and**  **#4)**25 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Modes to be Incorporated Network Mode  DOE received comments in response to the December 2008 TP NOPR to consider network mode.  IEC Standard 62301 CDV defines network mode as follows. 

## • Network mode is a mode category which “includes any product modes where the energy using product is connected to a mains power source and at least one network function is activated (such as reactivation via network command or network integrity communication) but where the primary function is not active.”  DOE is unaware of any clothes dryers or room air conditioners currently available on the market that incorporate a networking function. 

## • Unaware of any data regarding network mode in these products to determine appropriate testing procedures for incorporation into the DOE test procedures for the these products.  For these reasons, the proposed amendments do not include network mode.26 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Modes to be Incorporated Network Mode – Request for Comment **DOE welcomes comment on whether clothes dryers and room air conditioners are currently available that incorporate a networking**  **function and whether definitions and testing procedures for a network mode should be incorporated into the DOE test procedure.**  **DOE also requests comment on appropriate methodologies for measuring energy consumption in a network mode, and data on the**  **results and repeatability of such testing methodology. (Issue #5)** 27 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Modes to be Incorporated Definition of Modes – Off Mode  DOE is proposing the following definition of off mode based upon the definition in IEC Standard 62301 CDV. 

## • “Off mode” means a mode which includes any product modes where the energy using product is connected to a mains power source and is not providing any standby mode or active mode function and where the mode may persist for an indefinite time. An indicator that only shows the user that the product is in the off position is included within the classification of off mode.28 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 1. Products Covered by the Test Procedure Changes 2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures a. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power in Clothes Dryers and Room Air Conditioners b. Determination of Modes to be Incorporated c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Testing d. Calculation of Energy Use Associated with Standby Modes and Off Mode e. Measures of Energy Consumption29 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Methods and Measurements Specifications for Test Methods and Measurements – Clothes Dryer Test Period  Dryers may reduce power consumption by automatically dimming or powering down their displays after a period of user inactivity.



## • Proposed in the December 2008 TP NOPR that the test be conducted after the power level has dropped to its low level.  Section 5.3 of IEC Standard 62301 First Edition: 

## • Stable power - requires waiting at least 5 minutes for the product to stabilize and then measuring the power at the end of an additional time period of not less than 5 minutes. 

## • Unstable power - requires a measurement period of no less than 5 minutes, or one or more complete operating cycles of several minutes or hours.30 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Methods and Measurements Specifications for Test Methods and Measurements – Clothes Dryer Test Period  DOE received comments that the test procedures should specify a 30 - minute stabilization period and a measurement period at least 10 minutes.  Dryers may remain in the higher- power state for the duration of a 5 - minute stabilization period and 5 - minute measurement period, then drop to the lower- power state more representative of inactive mode.  IEC Standard 62301 CDV specifies a stabilization period of at least 30 minutes prior to a measurement period of not less than 10 minutes.



## • Sufficient time for displays that automatically dim or power down to reach the lower- power state prior to measurement. 

## • Would allow for representative measurements among products that may have varying time periods before the power drops to a low level.31 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Methods and Measurements Specifications for Test Methods and Measurements – Clothes Dryer Test Period  A test period of “not less than” or “at least” a specified amount of time may result in different test technicians testing the same product for different periods of time.  To ensure that testing procedures for standby and off mode are clear and consistent, DOE is proposing to require that the stabilization period be 30 to 40 minutes, and the test period be 10 minutes.32 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov  Interested parties commented that the appliance should be configured at the factory or “default” settings prior to the initiation of the test measurements.  DOE believes provisions for setting up the appliance should be specified in the test procedure.



## • Setting up the appliance in accordance with manufacturer’s instructions or in the factory or “default” settings would allow manufacturers to ship appliances set in a low power mode that consumers may switch out of during typical standby or off mode use.  DOE proposes that the appliance be set up in the settings that produce the highest power consumption level, consistent with the particular standby of off mode definition under test.



## • Provides a clear and consistent testing method. 

## Test Methods and Measurements Specifications for Test Methods and Measurements – Clothes Dryer Setup33 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Methods and Measurements Specifications for Test Methods and Measurements – Room Air Conditioner Test Room Temperature  DOE proposed in the December 2008 TP NOPR to require that test room temperature be maintained at 74 ± 2 ° F, and that the temperature control setting be 79 ° F.  DOE received comments that the proposed room temperature would represent a testing burden.  The test chamber ambient conditions proposed in the December 2008 TP NOPR would be relevant only for off-cycle mode.



## • If the test procedure is limited to measurement of a single standby mode and an off mode, the proposed close tolerance on ambient temperature would not be required.34 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Methods and Measurements

 Because DOE is not proposing in the SNOPR to measure off-cycle mode, DOE is revising its proposal in the December 2008 TP NOPR to provide flexibility for the test room temperature for standby and off mode testing:



## • Testing may be conducted in test facilities used for testing cooling performance. 

## • If testing is not conducted in such a facility, the test facility shall comply with the test conditions in section 4.2 of IEC Standard 62301.  Indoor temperature conditions required by the cooling performance test fall within the temperature range allowed by IEC Standard 62301. 

### Specifications for Test Methods and Measurements – Room Air Conditioner Test Room Temperature

**DOE requests comment on the proposed room ambient temperature range for standby mode and off mode power measurements for room**  **air conditioners and clothes dryers. (Issue #6)** 35 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Methods and Measurements

 DOE received comments that the standby and off mode test procedures should specify a 30 - minute stabilization period and a measurement period at least 10 minutes.



## • DOE does not have any information/data suggesting that these stabilization and measurement periods would produce more representative or consistent measurements than the December 2008 TP NOPR proposed time periods.  To ensure testing procedures for standby and off mode are clear and consistent, DOE proposes to require that the stabilization period be 5 to 10 minutes, and the test period be 5 minutes. 

### Specifications for Test Methods and Measurements – Room Air Conditioner Test Period36 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 1. Products Covered by the Test Procedure Changes 2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures a. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power in Clothes Dryers and Room Air Conditioners b. Determination of Modes to be Incorporated c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Testing d. Calculation of Energy Use Associated with Standby Modes and Off Mode e. Measures of Energy Consumption37 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Calculation of Energy Use

 Active mode energy use for clothes dryers is expressed in terms of total energy use per drying cycle.  DOE determined that it is technically feasible to incorporate measures of standby and off mode energy use into the overall energy - use metric.  DOE examined standby and off mode energy consumption in terms of annual energy use apportioned on a per-cycle basis. 

### Calculation of Energy Use – Clothes Dryers38 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Calculation of Energy Use

 DOE proposed estimates of annual hours and approximate annual energy use for different modes in the December 2008 TP NOPR . 

### December 2008 TP NOPR Estimate of Annual Energy Use of Clothes Dryer Modes if All Modes are Possible

Mode Hours Typical (W) Annual Energy Use (kWh) Active 140 6,907 967 Delay Start 34 3 0.1 Cycle Finished 429 3 1 Off and Inactive 8,157 0.5 to 3 4 to 24  Based upon comments, DOE believes, under the proposed definitions of standby and off mode, this allocation of annual hours to inactive and off modes is appropriate.  This SNOPR does not affect DOE’s proposal in the December 2008 TP NOPR for this allocation of hours.39 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Calculation of Energy Use

 DOE is not proposing amendments to measure delay start and cycle finished modes for clothes dryers. 

## • These modes each represent a negligible portion (0.1 percent or less) of the annual energy use. 

## • More appropriate under a simplified approach to allocate the hours associated with delay start and cycle finished modes to off/inactive modes.  DOE proposes to maintain the estimate of 8,620 non -active hours that would be allocated to inactive and off modes.  SNOPR does not affect the December 2008 TP NOPR proposal for the allocation of hours between inactive and off mode. 

## • Allocate the hours entirely to either off mode or standby mode, as appropriate, if only one of these modes is possible. 

## • Allocate the hours equally if both modes are possible. 

### Calculation of Energy Use Associated with Standby Modes and Off Mode – Clothes Dryers40 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Calculation of Energy Use Calculation of Energy Use Associated with Standby Modes and Off Mode – Clothes Dryers  DOE proposes to calculate clothes dryer energy use per cycle associated with standby and off modes by: 1. Calculating the product of wattage and allocated hours for all possible standby and off modes 2. Summing the results 3. Dividing the sum by 1,000 to convert from Wh to kWh 4. Dividing by 283* cycles per year *Revised number of dryer cycles per year part of the proposed amendments to active mode test procedure. **DOE seeks comment on the approach for determining total energy use for standby mode and off mode for clothes dryers, including its**  **accuracy and test burden. DOE also invites comment and requests data on the estimates for annual hours associated with each mode,**  **including the 140 hours specified by the current test procedure for active mode (drying). (Issue**  **#7)**41 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Calculation of Energy Use

 For the December 2008 TP NOPR, DOE estimated the annual hours for standby and off modes and the relative magnitudes of annual energy use in standby and off modes in an example for a representative 8,000 Btu/hour, 9 EER unit. Mode Hours Typical (W) Annual Energy Use (kWh) Active Cooling 750 889 667 Delay Start 90 2 0.2 Off- Cycle 440 2 0.9 Off/Inactive 4,850 0.5 to 4 2.5 to 10



### December 2008 TP NOPR Estimate of Annual Hours for Off/Inactive Modes – Room Air Conditioners42 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Calculation of Energy Use

 DOE is not proposing amendments to the room air conditioner test procedure to measure delay start and off-cycle power consumption.



## • These modes each represent a negligible portion (0.1 percent or less) of the annual energy use. 

## • More appropriate under a simplified approach to allocate the hours associated with delay start and off - cycle modes to off/inactive modes.  DOE proposes the estimate of 5,115 hours as the non -active hours that would be allocated to inactive and off modes for room air conditioners.  SNOPR does not affect the December 2008 TP NOPR proposal for the allocation of hours between inactive mode and off mode. 

## • Allocate the hours entirely to either off mode or standby mode, as appropriate, if only one of these modes is possible. 

## • Allocate the hours equally if both modes are possible. 

### Calculation of Energy Use Associated with Standby Modes and Off Mode – Room Air Conditioners43 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Calculation of Energy Use Calculation of Energy Use Associated with Standby Modes and Off Mode – Room Air Conditioners  DOE continues to propose to calculate room air conditioner annual energy use associated with standby and off modes by: 1. Calculating the products of wattage and allocated hours for all possible standby and off modes 2. Summing the results 3. Dividing the sum by 1,000 to convert from Wh to kWh **DOE seeks comment on the approach for determining total energy use for standby mode and off mode for room air conditioners,**  **including its accuracy and test burden. DOE also invites comment and requests data on the estimates for annual hours associated with**  **each mode, including the estimate of “unplugged” time. (Issue #8)** 44 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 1. Products Covered by the Test Procedure Changes 2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures a. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power in Clothes Dryers and Room Air Conditioners b. Determination of Modes to be Incorporated c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Testing d. Calculation of Energy Use Associated with Standby Modes and Off Mode e. Measures of Energy Consumption45 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Measures of Energy Consumption Measures of Energy Consumption  DOE proposed the following combined metrics addressing active, standby, and off modes for clothes dryers and room air conditioners in the December 2008 TP NOPR.  Clothes Dryers: 

## • “Per- cycle integrated total energy consumption expressed in kWh” 

## • “Integrated energy factor” (IEF)  Room Air Conditioners: 

## • “Integrated annual energy consumption” 

## • “Integrated energy efficiency ratio” (IEER)  This proposal from the December 2008 TP NOPR for the integrated metrics is not affected by the SNOPR.46 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures a. Automatic Cycle Termination for Clothes Dryers b. Test Procedure for Vent - less Clothes Dryers c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning d. Changes to Reflect Current Usage Patterns and Capabilities e. Room Air Conditioner Referenced Test Procedures f. Clothes Dryer Referenced Test Procedure g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy Consumption h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers 4. Compliance with Other EPCA Requirements 5. Effects of Test Procedure Revisions on Compliance with Standards47 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination for Clothes Dryers  The current DOE clothes dryer test procedure may not adequately measure the benefits of automatic cycle termination.  Current DOE test procedure provides a single credit for enhanced performance of clothes dryers equipped with automatic termination.



## • Defined by a Field Use (FU) scaling factor applied to the per- cycle drying energy consumption. 

## • Time termination control dryer FU factor equals 1.18, while automatic termination control dryer FU factor equals 1.04 (12 percent credit). 

## • Does not distinguish between the type of sensing control system and the sophistication and accuracy of the control system.48 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Industry and International Clothes Dryers Test Standards  DOE reviewed industry and international clothes dryer test standards for testing procedures for evaluating automatic termination control clothes dryers. 

## • AHAM HLD - 1 - 2009, “Household Tumble Type Clothes Dryers” 

## • European Standard EN 61121, “Tumble dryers for household use
– Methods for measuring the performance” (Edition 3 2005) 

## • Australia/New Zealand Standard 2442

– AS/NZS Standard 2442.1: 1996, “Performance of household electrical appliances
– Rotary clothes dryers, Part 1: Energy consumption and performance”

– AS/NZS Standard 2442.2: 2000, “Performance of household electrical appliances
– Rotary clothes dryers, Part 2: Energy labelling requirements”  AHAM HLD - 1 -2009 and EN Standard 61121 do not provide representative comparisons of energy consumption between timer dryers and automatic cycle termination dryers.49 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination for Clothes Dryers - AS/NZS Standard 2442  AS/NZS Standard 2442 Testing Procedures: 

## • Accounts for the amount of over- drying associated with automatic termination control dryers beyond a specified RMC.

– Effectively takes into consideration the accuracy of different automatic termination sensor technologies. 

## • Provides an accurate and representative method for comparing the energy consumption between timer dryers and automatic termination control dryers.  DOE proposes to incorporate the test procedures for timer dryers and automatic termination control dryers based on provisions in AS/NZS Standard 2442 with modifications as appropriate for the DOE test procedure.50 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination – Dryer Type Definitions  DOE proposes the following definitions based on the definitions provided in AS/NZS Standard 2442.1.



## • “Timer dryer” is a dryer which can be preset to carry out at least one sequence of operations to be terminated by a timer, but may also be manually controlled. 

## • “Automatic termination control dryer” is a dryer which can be preset to carry out at least one sequence of operations to be terminated by means of a system assessing, directly or indirectly, the moisture content of the load. An automatic termination control dryer with supplementary timer shall be tested as an automatic termination control dryer.  Definitions are very similar to the definitions in EN Standard 61121.51 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination – Test Load Preparation  DOE proposes to add the following test load preparation requirements based on the methods in AS/NZS 2442.1:



## • Require that the moisture content of the test load be between 42 and 47* percent of the bone - dry weight of the test load, serving as an initial preparation step prior to the final mass adjustments. 

## • Make a final mass adjustments, such that the moisture content is 47 percent ± 0.33 percent by adding water uniformly to the load in a very fine spray.

– The ± 0.33 percent allowable RMC range was determined based upon the allowable range specified in AS/NZS Standard 2442.1 (190 percent ± 0.02 kg of the bone dry weight). *As discussed later, proposing to change the initial RMC from 70 percent to 47 percent  Improves the repeatability and helps to reduce the variation from test to test.  Allows for a more representative comparison between timer dryers and automatic cycle termination dryers.52 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Water Temperature for Dryer Test Load Preparation  Section 2.7 of the current DOE test procedure (test load preparation) requires that the test load be agitated in 100 ° ± 5 ° F water.  DOE recognizes that some clothes washers may use a default cold rinse cycle at the end of the wash cycle.



## • Current DOE clothes washer test procedure specifies a cold rinse temperature of 60 ° ± 5 ° F. 

## • DOE does not have data indicating whether a different water temperature for dryer test load preparation would be more representative of current consumer usage habits.  DOE is not proposing any changes to the water temperature for clothes dryer load preparation at this time.



## • If consumer usage data is made available indicating that a 60 ° ± 5 ° F water temperature is more representative of consumer usage, DOE may adopt an alternate approach specifying this water temperature for test load preparation.53 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Water Temperature for Dryer Test Load Preparation – Request for Comment **DOE invites comment on whether the existing water temperature of 100**  **° ±**  **5 °** **F for test load preparation in the existing test procedure is representative of consumer usage habits, and, if not, what would be a**  **representative value. DOE also requests data quantifying how changes to the water temperature for clothes dryer test load**  **preparation would affect the measured efficiency as compared to the existing DOE test procedure, in particular for those units that are**  **minimally compliant with current energy conservation standards. (** 

**Issue #10)** 54 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination – Test Cycle  DOE also proposes to include the following testing procedures in section 3.3, “Test cycle,” of the DOE test procedure specific to each type of dryer, based on the test methods provided in AS/NZS 2442.1.  Timer dryers: 

## • The clothes dryer shall be operated at the maximum temperature setting and, if equipped with a timer, at the maximum time setting. 

## • The load shall be dried to 5
–6 percent RMC without the dryer advancing into cool down, resetting the timer if necessary. 

## • The procedure would then be repeated until the RMC of the test load is 4
–5 percent.55 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination – Test Cycle  Automatic Termination Control Dryers: 

## • A “normal” program shall be selected for the test cycle to be most representative of consumer usage. 

## • Where the drying temperature can be chosen independently of the program, it shall be set to the maximum. 

## • When the heater switches off for the final time at the end of the drying cycle (immediately before the cool - down period begins), the dryer shall be stopped. 

## • If the final RMC is greater than 5 percent, the tests shall be invalid and a new run shall be conducted using the highest dryness level setting. Any test cycle in which the final RMC is 5 percent or less shall be considered valid. 

## • The cycle setting selected for the test shall be recorded.56 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination Test Cycle – Cool - Down  At least two ways to terminate the drying cycle during the test: 

## • Termination before cool - down.

– AS/NZS Standard 2442.1

– AHAM HLD - 1 - 2009 

## • Termination at the end of the selected test cycle.

– EN Standard 61121  DOE proposes for the SNOPR that the test cycle for automatic termination control dryers does not include the cool -down phase. 

## • Based on AS/NZS Standard 2442 because it provides a more representative comparison of energy consumption between timer dryers and automatic termination control dryers. 

## • Harmonizes DOE test methods with industry and international test standards.57 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination Test Cycle – Cool - Down  DOE is considering the alternative method of EN Standard 61121 because it may provide incentives for energy -saving improvements.



## • Residual heat during the cool - down period may be used to continue drying clothes while slowly spinning the drum to achieve a desired RMC. 

## • Such potential for energy efficiency improvement would not be captured by the test methods DOE is proposing for the SNOPR.  DOE may adopt an alternate approach to include the measurement of the cool -down period as part of the proposed automatic cycle termination test methodology. **DOE welcomes comment on whether the cool -** **down period should be included as part of the active mode test cycle for automatic**  **termination control dryers. In addition, DOE also welcomes data quantifying how including the cool**  **- down period in the test cycle**  **would affect the measured efficiency of clothes dryers as compared to the existing DOE test procedure, in particular for those units that**  **are minimally compliant with current energy conservation standards. (** 

**Issue #12)** 58 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination – Calculations of Results  DOE proposes the following amendments to the calculations of derived results from test measurements in the DOE test procedure.  For timer dryers, DOE proposes to use the results from the proposed tests cycles to interpolate the per-cycle energy consumption required to dry the test load to exactly 5 - percent RMC.



## • DOE is unaware of any data that would indicate the 1.18 FU factor credit for timer dryers is inaccurate and not currently representative of consumer usage habits. 

## • DOE does not intend to revise the 1.18 FU factor for timer dryers at this time.59 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination – Calculations of Results  For automatic termination control dryers, DOE proposes to revise the FU factor credits to more appropriately account for over-drying energy consumption.



## • Automatic termination control clothes dryer FU factor would equal 1.0. Any over- drying energy consumption would be included in the per- cycle energy consumption, resulting in a reduction in measured EF. 

## • An automatic termination control dryer that is able to dry the test load to exactly 5 - percent RMC (eliminating over- drying) would result in a higher measured efficiency than if it over- dried the test load to an RMC less than 5 percent.  DOE estimated, based on limited testing, that baseline dryers would possibly over-dry the test load to below 5 - percent RMC such that the energy consumption and measured EF would be equivalent to that measured by the existing DOE test procedure. 

## • No changes to the current energy conservation standards would be warranted.60 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination – Request for Comment **DOE invites comment on the adequacy of AS/NZS Standard 2442, along with proposed definitions and clarifications, to measure energy**  **consumption for timer and automatic termination control clothes dryers to account for over**  **- drying energy consumption.**  **DOE invites comments on whether the proposed FU factor credits for timer and automatic termination control dryers, along with the**  **revised calculations for per -** **cycle energy consumption, are appropriate.**  **DOE welcomes comment on whether a final RMC of 5 percent is appropriate, and, if not, what a representative final RMC would be.**  **DOE also welcomes data from dryers tested according to the proposed test procedure, in particular for units which minimally**  **comply with current energy conservation standards, as well as data showing whether one sensor technology is more accurate, and**  **reduces over -** **drying, than another. (Issue #9)** 61 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Cycles and Settings for Timer Dryer and Automatic Termination Control Dryer Testing – Request for Comment

**DOE invites comment on whether using the maximum temperature setting for timer dryers is representative of current consumer usage**  **habits. DOE also invites comment on whether the proposed cycles and**  **settings for the automatic termination control dryer tests are representative of current consumer usage habits.**  **DOE requests comment on whether multiple cycles and settings should be tested and how the results from those multiple tests**  **should be evaluated, and if so, how testing multiple cycles and settings would affect the measured efficiency as compared to the**  **existing DOE clothes dryer test procedure.. (Issue**  **#11)**62 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures a. Automatic Cycle Termination for Clothes Dryers b. Test Procedure for Vent - less Clothes Dryers c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning d. Changes to Reflect Current Usage Patterns and Capabilities e. Room Air Conditioner Referenced Test Procedures f. Clothes Dryer Referenced Test Procedure g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy Consumption h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers 4. Compliance with Other EPCA Requirements 5. Effects of Test Procedure Revisions on Compliance with Standards63 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Procedure for Vent- less Clothes Dryers Vent - less Clothes Dryers  Manufacturers of vent - less clothes dryers commented that the current DOE test procedure is unable to test this type of dryer.



## • Current DOE test procedure requires an exhaust restrictor to simulate backpressure effects of a vent tube in an installed condition.  Vent - less clothes dryers do not vent exhaust air to the outside as a conventional dryer does.64 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Procedure for Vent- less Clothes Dryers Alternate Test Procedure for Vent - less Clothes Dryers Presented in LG Petition for Waiver  DOE presented an alternate test procedure for vent - less dryers in the Petition for Waiver and Denial of the Application for Interim Waiver of LG Electronics from the DOE Clothes Dryer Test Procedure. 71 FR 49437 (August 23, 2006).



## • Added separate definitions for a “conventional clothes dryer” and a “condensing clothes dryer.” 

## • Qualified the requirement for an exhaust simulator for only conventional clothes dryers.  DOE conducted limited tests of vent - less clothes dryers according to the alternate test procedure. 

## • Results show less than 2 percent variation in measured EF from test to test. 

## • Based on this limited testing, the alternate testing procedures appear to produce repeatable results.65 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Procedure for Vent- less Clothes Dryers Vent - less Clothes Dryer Test Standards  DOE investigated test standards used internationally. 

## • EN Standard 61121 

## • AS/NZS Standard 2442  Whirlpool submitted comments providing amendments to the DOE test procedure to include methods for testing condensing dryers. 

## • Largely based on EN Standard 61121.  EN Standard 61121 includes relevant test procedures for condensing (vent - less) clothes dryers.66 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Procedure for Vent- less Clothes Dryers Test Procedure for Vent - less Clothes Dryers – Dryer Type Definitions  Based on the definitions in the LG Petition for Waiver, EN Standard 61121, AS/NZS Standard 2442, and Whirlpool’s proposed amendments, DOE proposes the following definitions:



## • “Conventional clothes dryer” is “a clothes dryer that exhausts the evaporated moisture from the cabinet.” 

## • “Vent- less clothes dryer” is “a clothes dryer that uses a closed - loop system with an internal condenser to remove the evaporated moisture from the heated air. The moist air is not discharged from the cabinet.”67 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Procedure for Vent- less Clothes Dryers Test Procedure for Vent - less Clothes Dryers – Installation Conditions  Based on the LG Petition for Waiver, the test standards, and Whirlpool’s proposed amendments, DOE proposes to amend the installation conditions in its test procedure to qualify the requirement for an exhaust simulator to only apply to conventional clothes dryers.



## • Additional proposed clarifications:

– Vent- less dryers shall be tested without the exhaust simulator installed.

– If a dryer is designed to operate with an optional exhaust duct, the dryer shall be tested without the duct installed.  Provides additional clarity and covers all possible clothes dryer configurations  Provides harmonization with international test standards.68 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Procedure for Vent- less Clothes Dryers

 DOE proposes the following requirements regarding a condensation box based on provisions in EN Standard 61121 to provide additional clarity to cover all possible configurations:



## • Section 2.1, “Installation”
– “If a manufacturer gives the option to use a ventless dryer with or without a condensation box, the dryer shall be tested with the condensation box installed.” 

## • Section 3.3, “Test cycle”
– “If the dryer automatically stops during a cycle and the reason is that the condensation box is full of water, the test is stopped, and the test run is invalid” to ensure consistency of the measured efficiency.  Based on Whirlpool’s proposal, DOE proposes to add the requirement that “the condenser unit of the dryer must remain in place and not be taken out of the dryer for any reason between tests.” 

## • Provides additional clarification and ensures that all manufacturers are testing products under the same conditions. 

### Test Procedure for Vent - less Clothes Dryers – Installation Conditions69 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Procedure for Vent- less Clothes Dryers

Test Procedure for Vent - less Clothes Dryers – Preconditioning  Section 2.8 of the current DOE test procedure, “Clothes dryer preconditioning,” states:



## • Before any test cycle is initiated, the dryer must be operated without a test load in non - heat mode for 15 minutes or until the discharge air temperature varies less than 1 ° F during a period of 10 minutes, whichever is longer.  Vent - less clothes dryers do not have discharge air.  Based on EN Standard 61121, DOE proposes the following for vent less dryer preconditioning:



## • The steady- state temperature must be equal to ambient room temperature before the start of all test runs with an additional note that this can be done by leaving the machine at ambient room conditions for at least 12 hours but not more than 36 hours between tests.  DOE proposes to add a qualification to the existing pre -conditioning procedure that it applies only to vented clothes dryers.70 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Procedure for Vent- less Clothes Dryers Test Procedure for Vent - less Clothes Dryers – Test Cycle  DOE proposes, based on EN Standard 61121 and Whirlpool’s proposal, to specify in section 3.3, “Test cycle,” of the DOE test procedure the following for vent - less dryers:



## • The first cycle after a period of non - operation longer than 36 hours shall not be used for evaluation, and that, between test cycles, the door of the tumble dryer shall be closed except for loading (and unloading).  These provisions will maintain a clear and repeatable testing procedure and produce accurate and representative results.  EN Standard 61121 requires that at least five valid test cycles be performed and the results averaged.



## • DOE clothes dryer test procedure does not specify multiple test cycles to obtain the representative EF. 

## • DOE is not aware of data suggesting that test-to -test variation is sufficient to warrant a requirement for more than one test cycle. 

## • DOE is not proposing amendments to the number of valid test cycles.71 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Procedure for Vent- less Clothes Dryers Test Procedure for Vent - less Clothes Dryers – Request for Comment **DOE invites comment on the adequacy of proposed definitions and installation conditions for vent**  **- less clothes dryers, which are based**  **upon the alternate test procedure presented in**  **the LG Petition for Waiver. DOE further invites comment on the proposed additional**  **clarifications to the installation conditions, condensation boxes, dryer preconditioning, and testing conditions based on EN Standard**  **61121 and Whirlpool’s proposed amendments. (Issue # 13)**  **DOE also invites comment and data suggesting that test -**  **to -**  **test variation is sufficient to warrant a requirement for more than one**  **clothes dryer test cycle. (Issue #14)**72 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Test Procedure for Vent- less Clothes Dryers Test Procedure for Vent - less Clothes Dryers – Water Consumption  DOE investigated water consumption of vent - less clothes dryers . 

## • Only vent- less combo washer/dryers use water to condense moisture in the air exiting the drum for products on the U.S. market.  DOE measured the water consumed by a vent - less combo washer/dryer. 

## • Combination washer/dryer consumed on average 3.25 gallons of cold water. 

## • Combo washer/dryers represent a very small niche of the U.S. dryer market. 

## • DOE believes that the benefit of measuring water use for vent- less dryers is outweighed by the burden on manufacturers.  DOE is not proposing to include a requirement to measure the water consumption for vent - less condensing clothes dryers. **DOE requests comment and data on the water consumption of vent****** **less clothes dryers and whether measurement of water consumption should be included in the DOE**  **test procedure. (Issue #**  **13)**73 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures a. Automatic Cycle Termination for Clothes Dryers b. Test Procedure for Vent - less Clothes Dryers c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning d. Changes to Reflect Current Usage Patterns and Capabilities e. Room Air Conditioner Referenced Test Procedures f. Clothes Dryer Referenced Test Procedure g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy Consumption h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers 4. Compliance with Other EPCA Requirements 5. Effects of Test Procedure Revisions on Compliance with Standards74 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Clothes Dryer Test Cloth Preconditioning Detergent Specifications for Clothes Dryer Test Cloth Preconditioning  The DOE test procedure specifies that the test cloth be preconditioned using AHAM Standard Test Detergent IIA.



## • This detergent is obsolete and no longer supplied by AHAM or other suppliers. 

## • The current AHAM standard detergent is AHAM standard test detergent Formula 3.  DOE proposes to amend the test procedure to specify the use of AHAM detergent Formula 3 for preconditioning.  AHAM’s clothes dryer test standard, AHAM HLD - 1 -2009, specifies a standard test detergent Formula 3 dosage of 27 g + 4.0 g/lb of base test load for test cloth pre -treatment. 

## • DOE is proposing to amend the test load size for standard - size clothes dryers to 8.45 lb ± .085 lb.

– Detergent dosage for AHAM standard test detergent Formula 3 of 60.8 g.75 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Clothes Dryer Test Cloth Preconditioning Detergent Dosage  DOE believes the detergent concentration should be set by the pounds of test cloth in this standard -size test load.



## • This load is more closely matched to the maximum water fill level than is the compact- size test load.  DOE is proposing to require 60.8 g of AHAM standard test detergent Formula 3 for test cloth preconditioning. **DOE invites comment on the proposed revisions to the detergent formulation and dosage specifications, requiring 60.8g of AHAM**  **standard test detergent Formula 3 for clothes dryer test cloth preconditioning. DOE also welcomes data showing the effects of**  **changing the detergent specifications for test cloth preconditioning on the measured EF for clothes dryers. (Issue #15)** 76 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures a. Automatic Cycle Termination for Clothes Dryers b. Test Procedure for Vent - less Clothes Dryers c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning d. Changes to Reflect Current Usage Patterns and Capabilities e. Room Air Conditioner Referenced Test Procedures f. Clothes Dryer Referenced Test Procedure g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy Consumption h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers 4. Compliance with Other EPCA Requirements 5. Effects of Test Procedure Revisions on Compliance with Standards77 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Number of Annual Cycles  The average number of dryer use cycles assumed in the revised DOE clothes washer test procedure is inconsistent with the use cycles in the clothes dryer test procedure .



## • Clothes washer test procedure specifies 392 annual washer use cycles and assumes that 84 percent of all washer loads are dried in dryers (329 dryer cycles per year). 

## • Current clothes dryer test procedure assumes 416 dryer cycles per year.  2004 California Statewide Residential Appliance Saturation Study (RASS) surveyed clothes dryer usage patterns.



## • For the 6,790 households that said they owned a clothes dryer, average usage was 4.69 loads per week, or approximately 244 loads per year. 

## • Study provides only a limited dataset.78 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Number of Annual Cycles – 2005 RECS  DOE reviewed data from the Energy Information Administration (EIA)’s 2005 Residential Energy Consumption Survey (RECS).



## • National sample survey of housing units. 

## • For each sample home, RECS provides data on the number of laundry loads (washer cycles) washed per week and the frequency of clothes dryer use. 

## • Using the RECS data, DOE estimated the average usage to be 283 cycles per year.  Based on 2005 RECS data, DOE proposes to amend the number of annual use cycles in its test procedure to 283 cycles per year. **DOE seeks comment on the proposed amendment to change the number of clothes dryer annual use cycles to 283 cycles for all**  **product classes of clothes dryers based upon data from the 2005 RECS.**  **(Issue # 16)** 79 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Initial Remaining Moisture Content  RMC is the ratio of the weight of water contained by the test load at the completion of the clothes washer energy test cycle to the bone dry weight of the test load, expressed as a percent.



## • The current DOE clothes dryer test procedure specifies an initial RMC of 70 ± 3.5 percent.  Since the clothes dryer test procedure was established in 1981, average clothes washer RMC has decreased due to the introduction of higher efficiency models with higher final spin speeds.



## • For the residential clothes washer standard which became effective January 1, 2007 (1.26 MEF), DOE estimated a weighted - average RMC of 56 percent.80 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Initial Remaining Moisture Content  DOE estimated the RMC of clothes washers using a distribution of values for models listed in the December 2008 CEC product database.



## • RMC values ranged from 30 percent to 61 percent, with an average of 46 percent.  AHAM provided data showing the shipments of residential clothes washers for which RMC was reported, along with shipment weighted RMC81 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities AHAM Data Submittal – Shipment -Weighted Average RMC for Residential Clothes Washers

* Data contains only shipments for which the RMC was reported. 46 47 48 49 50 51 52 53 54 55

2000 2001 2002 2003 2004 2005 2006 2007 2008Shipment-Weighted RMC (%)

Year82 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Initial Remaining Moisture Content  Based on review of the CEC product database and AHAM data, DOE believes that an initial RMC of 47 percent is representative of current residential clothes dryer initial test load characteristics.  DOE proposes to amend the clothes dryer test procedure to require that the initial RMC be changed from 70 percent to 47 percent.  DOE estimated, based on internal testing, a 41 - percent increase in EF from switching from 70 - percent to 47 - percent initial RMC.



## • DOE will consider addressing this change in the concurrent standards rulemaking for residential clothes dryers.83 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Initial Remaining Moisture Content – Request for Comment **DOE seeks comment on the proposed amendments to the DOE clothes dryer test procedure to change the initial RMC to 47 percent to reflect**  **current consumer usage habits, based on the trends of the shipment****** **weighted average RMC of clothes washers shown in data submitted by AHAM. DOE further welcomes comment and data indicating an**  **appropriate initial RMC and how that initial RMC would affect the measured EF of clothes dryers, in particular units that are minimally**  **compliant with current energy conservation standards. (Issue #**  **17)**84 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Test Load Weight  Section 2.7, “Test loads,” of the current DOE clothes dryer test procedure requires:



## • 7.00 lb ± .07 lb test load for standard - size dryers. 

## • 3.00 lb ± .03 lb test load for compact- size dryers.  In response to comments on the October 2007 Framework Document, DOE investigated whether the average test load weight for standard -capacity dryers is consistent with the current generation of washer capacities.85 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Test Load Weight  Procter and Gamble conducted an internal study (2003) on household laundry habits on a representative set of the U.S. population.



## • The clothes washer load weight data:

– Sample size of 3367 loads of laundry from a total of 510 respondents,

– Average load size for top - and front- loading clothes washers was 7.2 lb and 8.4 lb, respectively. 

## • DOE estimated, using AHAM data, the shipment-weighted average load size for all clothes washers to be approximately 7.5 lbs. 

## • Clothes washer capacities were likely to have increased since the survey was conducted in 2003.86 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities AHAM **Trends in Energy Efficiency 2008** Data on Tub Volume for Residential Clothes Washers

2 2.2 2.4 2.6 2.8 3 3.2 3.4

1980 1985 1990 1995 2000 2005 2010Shipment-Weighted Average TubVolume (cu. ft.)

Year  The shipment -weighted average tub volume increased from 2.52 ft 3 in 1981 to 3.22 ft 3 in 2008 (22.4% increase).87 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities DOE Clothes Washer Test Load Size Requirements (Table 5.1 of 10 CFR 430 Subpart B, Appendix J1)

 Average load size in the washer test procedure increases by 21 percent based on the increase in capacity shown in the AHAM Data.



## • DOE believes this proportionally impacts clothes dryer load sizes.  Applying this ratio to the clothes dryer test load size would result in an increase from 7.00 lb to 8.45 lb for standard -size dryers. Container Volume (ft3 ) Minimum Load (lb) Maximum Load (lb) Average Load (lb) ≥2.50 to <2.60 3.00 10.50 6.75 ≥3.20 to <3.30 3.00 13.30 8.1588 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Test Load Weight  Based on this data, DOE proposes to amend the clothes dryer test load size to 8.45 lb ± .085 lb for standard -size dryers.  DOE believes most compact -size dryers are used in conjunction with compact -size washers. 

## • DOE does not have any information to suggest that the tub volume of such clothes washers has changed significantly. 

## • DOE is not proposing to change the 3 - lb test load size currently specified in the test procedure for compact clothes dryers.89 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Test Load Weight – Effects on Measured EF  Based on testing results in a National Institute of Standards and Technology (NIST) report, DOE estimated the percentage change in EF for an 8.45 - lb test load by linearly interpolating the results for 7 - lb and 9 - lb tests.  Using this method, the EF would increase by about 3.8 percent when increasing the test load size from 7 lb to 8.45 lb. **DOE seeks comment on the proposed amendments to the DOE clothes dryer test procedure to change the clothes dryer test load**  **size to 8.45**  **lb ±**  **. 085**  **lb for standard -** **size dryers. DOE also welcomes data on clothes washer and clothes dryer test load sizes**  **representative of current consumer usage habits for both compact****** **size and standard -** **size units. DOE further requests data on how any changes in test load size would affect the measured EF of clothes**  **dryers, in particular units that are minimally compliant with current energy conservation standards. (Issue #**  **18)**90 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Room Air Conditioner Annual Operating Hours  DOE test procedure currently assumes room air conditioners have an average annual use of 750 hours.



## • DOE’s technical support document from September 1997 (most recent room air conditioner standards rulemaking) showed closer to 500 hours for the average annual operational hours.  DOE’s investigation of usage pattern data revealed a lack of metered and survey data for the operating hours of individual room air conditioners.  DOE found two sources of survey data: 

## • The CEC California Statewide RASS survey contained only aggregated residential data, which limited any analysis pertaining to the annual operating hours. Its regional scope also limited the relevance of the data. 

## • EIA’s 2005 RECS provides extensive data on individual residences and a more expansive and representative sample of households.91 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Room Air Conditioner Annual Operating Hours – EIA’s 2005 RECS  Using 2005 RECS data, DOE developed a household sample for the annual hours of use of a room air conditioner, which was used to calculate a weighted national average of usage hours.



## • The data in the 2005 RECS indicates that the estimated average annual usage is 810 hours.  DOE does not consider the increase of 60 hours to be significant. 

## • Does not exceed the uncertainty level associated with the RECS - based approach for estimation of this value.  DOE is not proposing a change at this time in the annual operating hours used in the test procedure. **DOE seeks comment on the determination that the 750 annual operating hours specified by the current DOE test procedure for**  **room air conditioners is still representative based upon data from the 2005 RECS. (Issue #**  **19)**92 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Room Air Conditioner Part - Load Performance  DOE room air conditioner test procedure measures full - load performance.



## • Not able to assess energy savings associated with technologies which improve part- load performance.  DOE does not plan to consider amendments to measure part - load performance.



## • Widespread use of part- load technology in room air conditioners would probably not occur because of the development of a part- load metric. 

## • The significant effort of development of an accurate part- load metric is not likely to be warranted by the expected minimal energy savings .93 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Room Air Conditioner Ambient Test Conditions  DOE considered whether the ambient test conditions in its room air conditioner test procedure are representative of typical installations.



## • DOE received comments that the ambient temperature should be increased from 95 ° F to 115 ° F. 

## • DOE did not receive further information to support the specification of the higher temperature.  DOE is not considering amendments to the ambient test conditions at this time. **DOE invites comment and data indicating representative ambient test conditions for the DOE room air conditioner test procedure. DOE**  **further requests data showing how any changes to the ambient conditions would affect the measured EER of room air conditioners,**  **in particular units that are minimally compliant with current energy conservation standards. (Issue**  **#20)**94 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures a. Automatic Cycle Termination for Clothes Dryers b. Test Procedure for Vent - less Clothes Dryers c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning d. Changes to Reflect Current Usage Patterns and Capabilities e. Room Air Conditioner Referenced Test Procedures f. Clothes Dryer Referenced Test Procedure g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy Consumption h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers 4. Compliance with Other EPCA Requirements 5. Effects of Test Procedure Revisions on Compliance with Standards95 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Referenced Test Procedures Room Air Conditioner Referenced Test Procedures  The room air conditioner test procedure cites two test standards: 

## • American National Standard (ANS) (since renamed American National Standards Institute (ANSI)) Z234.1 - 1972, “Room Air Conditioners;” and 

## • American Society of Heating, Refrigerating, and Air- Conditioning Engineers (ASHRAE) Standard 16 - 69, “Method of Testing for Rating Room Air Conditioners.”  Both the ANSI and ASHRAE standards have been updated since DOE last revised its room air conditioner test procedure.  Current standards: 

## • ANSI/AHAM RAC - 1 - R2008, “Room Air Conditioners”; and 

## • ANSI/ASHRAE Standard 16 - 1983 (RA 2009) “Method of Testing for Rating Room Air Conditioners and Packaged Terminal Air Conditioners .”96 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Referenced Test Procedures Room Air Conditioner Referenced Test Procedures  DOE suggested in the October 2007 Framework Document to consider updating its test procedure to incorporate by reference the most recent test standards.



## • Interested parties commented in support of referencing the most recent ANSI and ASHRAE test standards. 

## • Sections that would be referenced in ANSI/AHAM RAC - 1 - R2008 do not introduce any new changes in the measurement of cooling capacity or power input. 

## • Sections that would be referenced in ANSI/ASHRAE Standard 16 - 1983 (RA 2009) would introduce changes to the determination of capacity, four new temperature measurements, and changes to the test tolerances.97 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Referenced Test Procedures Room Air Conditioner Referenced Test Procedures  DOE proposes to amend the DOE test procedure to reference the relevant sections ANSI/AHAM RAC - 1 - R2008 and ANSI/ASHRAE Standard 16 - 1983 (RA 2009).



## • Provides more accurate and repeatable measurements of capacity. 

## • Provides greater flexibility to manufacturers in selecting equipment and facilities . 

## • Does not add any significant testing burden. **DOE invites comment on the proposed amendments to update the references in the DOE room air conditioner test procedure to**  **reference the latest ANSI and ASHRAE test standards, ANSI/AHAM RAC** **- 1**  **- R2008 and ANSI/ASHRAE Standard 16** **- 1983 (RA 2009). (**  **Issue #21)** 98 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures a. Automatic Cycle Termination for Clothes Dryers b. Test Procedure for Vent - less Clothes Dryers c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning d. Changes to Reflect Current Usage Patterns and Capabilities e. Room Air Conditioner Referenced Test Procedures f. Clothes Dryer Referenced Test Procedure g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy Consumption h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers 4. Compliance with Other EPCA Requirements 5. Effects of Test Procedure Revisions on Compliance with Standards99 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Clothes Dryer Referenced Test Procedure AHAM Standard HLD - 1  DOE clothes dryer test procedure currently references AHAM Standard HLD - 1 - 1974, “AHAM Performance Evaluation Procedure for Household Tumble Type Clothes Dryers.” 

## • Section 3.3.5 of AHAM Standard HLD - 1 - 1974 provides specifications for the exhaust simulator.  AHAM HLD - 1 has been updated since DOE established its clothes dryer test procedure. The current standard is AHAM Standard HLD 1 -2009.



## • Section 3.3.5.1 of AHAM Standard HLD - 1 - 2009 provides the same requirements for the exhaust simulator as required by AHAM Standard HLD 1 - 1974.  DOE proposes to amend the DOE test procedure to reference section 3.3.5.1 of AHAM Standard HLD - 1 -2009.100 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Clothes Dryer Referenced Test ProcedureOptional Clothes Dryer Exhaust Simulator  AHAM Standard HLD - 1 -2009 also allows for the optional use of a modified exhaust simulator.



## • Test standard notes that only limited testing has been done to compare results using the two exhaust simulators, and that users are invited to submit results and comments for both options.  DOE will continue to require the standard exhaust simulator currently referenced by the DOE clothes dryer test procedure.  DOE clothes dryer test procedure also references an obsolete AHAM clothes dryer test standard, AHAM Standard HLD -2EC. 

## • No provisions of this test standard are currently used in DOE’s test procedure. 

## • DOE proposes to remove this reference.101 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Clothes Dryer Referenced Test Procedure Clothes Dryer Referenced Test Procedure – Request for Comment **DOE invites comment on the proposed amendments to update the reference in the DOE clothes dryer test procedure to reference the**  **latest AHAM clothes dryer test standard, AHAM Standard HLD -**  **1 -**  **2009, and to eliminate the reference to obsolete AHAM Standard HLD****** **2EC. DOE also invites comment on whether the optional modified exhaust simulator in AHAM Standard HLD** **- 1**  **- 2009 is appropriate for**  **incorporation into the DOE clothes dryer test procedure. DOE seeks data comparing the effects of the two exhaust simulators in AHAM**  **Standard HLD -**  **1 -** **2009 on the measured EF, in particular for units that minimally comply with current energy conservation standards.**  **(Issue #** **22)**102 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures a. Automatic Cycle Termination for Clothes Dryers b. Test Procedure for Vent - less Clothes Dryers c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning d. Changes to Reflect Current Usage Patterns and Capabilities e. Room Air Conditioner Referenced Test Procedures f. Clothes Dryer Referenced Test Procedure g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy Consumption h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers 4. Compliance with Other EPCA Requirements 5. Effects of Test Procedure Revisions on Compliance with Standards103 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Technical Correction Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy Consumption  Current DOE clothes dryer test procedure contains a technical error in the calculation of the per-cycle gas dryer continuously burning pilot light gas energy consumption, E up , in Btu’s per cycle.  DOE proposes to revise this equation as follows: 

## • Should correctly subtract the active mode hours per year from the total hours per year to give the number of non - active mode hours per year the pilot is consuming gas, before dividing by dryer cycles per year. 

## • The equation should read ((8760 - 140)/283), instead of (8760
– 140/283). **DOE seeks comment on its proposed correction to the calculation of the per**  **- cycle gas dryer continuously burning pilot light gas energy**  **consumption. (Issue # 23)** 104 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures a. Automatic Cycle Termination for Clothes Dryers b. Test Procedure for Vent - less Clothes Dryers c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning d. Changes to Reflect Current Usage Patterns and Capabilities e. Room Air Conditioner Referenced Test Procedures f. Clothes Dryer Referenced Test Procedure g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy Consumption h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers 4. Compliance with Other EPCA Requirements 5. Effects of Test Procedure Revisions on Compliance with Standards105 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Gas Clothes Dryer Gas Supply Test Conditions Clarification of the Gas Supply Test Conditions for Gas Dryers  Section 2.3.2.1 and 2.3.2.2 of the DOE test procedure: 

## • Specifies maintaining the gas supply to the clothes dryer at a normal inlet test pressure immediately ahead of all controls at 7 to 10 inches of water column for natural gas or 11 to 13 inches of water column for propane gas. 

## • References to “normal inlet test pressure” may be confusing as to what is meant by the term “normal.” 

## • Such language is not necessary because the gas supply pressure immediately ahead of all controls is explicitly stated.  DOE proposes to revise this language to specify maintaining “the gas supply to the clothes dryer immediately ahead of all controls at a pressure of” 7 to 10 inches of water column for natural gas and 11 to 13 inches of water column for propane gas.106 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Gas Clothes Dryer Gas Supply Test Conditions Clarification of the Gas Supply Test Conditions for Gas Dryers  DOE proposes minor revisions to the specifications for a gas pressure regulator in sections 2.3.2.1 and 2.3.2.2 of the test procedure.



## • Clarify that the outlet pressure for a dryer equipped with a pressure regulator for which the manufacturer specifies an outlet pressure, should be approximately that recommended by the manufacturer. **DOE seeks comment on its proposed clarifying language for specifying the natural gas and propane supply pressure conditions**  **for testing gas clothes dryers. ( Issue #** **24)**107 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures a. Automatic Cycle Termination for Clothes Dryers b. Test Procedure for Vent - less Clothes Dryers c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning d. Changes to Reflect Current Usage Patterns and Capabilities e. Room Air Conditioner Referenced Test Procedures f. Clothes Dryer Referenced Test Procedure g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy Consumption h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers 4. Compliance with Other EPCA Requirements 5. Effects of Test Procedure Revisions on Compliance with Standards108 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Compliance with Other EPCA Requirements Test Burden  Section 323(b)(3) of EPCA requires that any prescribed or amended test procedures shall be reasonably designed to produce test results which measure energy efficiency, energy use or estimated annual operating cost during a representative average use cycle or period of use and shall not be unduly burdensome to conduct.  DOE tentatively concluded in the December 2008 TP NOPR that the proposed amendments for measuring standby and off mode power consumption would satisfy this requirement.109 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Compliance with Other EPCA Requirements Test Burden – Standby/Off Mode  DOE is not proposing amendments to measure delay start and cycle finished modes in the clothes dryer test procedure or delay start and off-cycle modes in the room air conditioner test procedure.  DOE received comments that the December 2008 TP NOPR proposed ambient temperature conditions for measuring room air conditioner standby power would increase testing burden.



## • DOE is proposing to provide manufacturers flexibility in the ambient conditions for standby and off mode testing.  DOE tentatively concludes that the proposed amendments to the clothes dryer and room air conditioner test procedures for measuring standby and off modes are not unduly burdensome.110 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Compliance with Other EPCA Requirements Test Burden – Clothes Dryer Active Mode  The proposed amendments to test automatic termination control dryers and vent - less dryers are based on international testing standards used in Australia and the EU, respectively.



## • A number of manufacturers that sell dryers in the United States also sell clothes dryers in Australia and in the EU. 

## • Likely already test clothes dryers according to these test standards. 

## • Would not require testing methods and equipment substantially different from those in the current DOE test procedure. 

## • Would not require manufacturers to make major investment in test facilities and new equipment.  Proposed amendments to reflect current usage patterns and capabilities do not substantially change the testing procedures and methods such that they would become burdensome to conduct.111 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Compliance with Other EPCA Requirements Test Burden – Room Air Conditioner Active Mode  Proposed amendments to update the references to external standards in the DOE room air conditioner test procedure are based on revised standards representing current industry practices and methods.



## • Would not require manufacturers to make any significant new investment in test facilities and equipment, nor require significant changes in the testing methodology.112 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### Test Procedure Overview 3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures a. Automatic Cycle Termination for Clothes Dryers b. Test Procedure for Vent - less Clothes Dryers c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning d. Changes to Reflect Current Usage Patterns and Capabilities e. Room Air Conditioner Referenced Test Procedures f. Clothes Dryer Referenced Test Procedure g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy Consumption h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers 4. Compliance with Other EPCA Requirements 5. Effects of Test Procedure Revisions on Compliance with Standards113 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Effects of Test Procedure Revisions on Compliance with Standards Effects of Test Procedure Revisions on Compliance with Standards  DOE must determine to what extent, if any, the proposed test procedures would alter the measured energy efficiency of covered products as determined under the existing test procedures. If DOE determines that an amended test procedure would alter the measured efficiency of a covered product, DOE must amend the applicable energy conservation standard during the rulemaking carried out with respect to such test procedure. (42 U.S.C. 6293(e))  EPCA provides that amendments to the test procedures to include standby mode and off mode energy consumption will not determine compliance with previously established standards. (U.S.C. 6295( gg )(2)(C))114 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Effects of Test Procedure Revisions on Compliance with Standards Effects of Test Procedure Revisions on Compliance with Standards – Clothes Dryer Active Mode  DOE believes that only the revisions to the initial RMC and to the standard -size dryer test load sizes would affect the measured EF as compared to the existing test procedure.  Based upon DOE testing and analysis of minimally compliant clothes dryers and review of available research:



## • The proposed amendments to the initial RMC would increase the measured EF of minimally compliant clothes dryers by 41 percent. 

## • The proposed amendments to the test load size for standard - size clothes dryers would increase the measured EF by 3.8 percent.115 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Effects of Test Procedure Revisions on Compliance with Standards Energy Factor of Minimally Compliant Clothes Dryers with the Current and Proposed Amended Test Procedure

 Based on the proposed amendments, the measured EF would increase by about 41 percent for compact -size clothes dryers and about 46 percent for standard -size clothes dryers.  DOE will consider such changes in the concurrent energy conservation standards rulemaking for clothes dryers and room air conditioners. Product Class Energy Factor (lb/kWh) Current Test

Procedure Proposed Amended Test Procedure 1. Electric , Standard (4.4 ft 3 or greater capacity) 3.01 4.39 2. Electric , Compact (120 v) (less than 4.4 ft 3 capacity) 3.13 4.41 3. Electric , Compact (240 v) (less than 4.4 ft 3 capacity) 2.90 4.09 4. Gas 2.67 3.90116 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Effects of Test Procedure Revisions on Compliance with Standards Clothes Dryer Test Procedure Proposed Amendments – Addition of Appendix D1  Proposed clothes dryer test procedure amendments for active mode would substantially change the existing EF metric.  DOE has tentatively decided to create a new appendix D1 in 10 CFR 430 subpart B for the proposed amendments.



## • Such an appendix would contain a clothes dryer test procedure that manufacturers would be required to use on the mandatory compliance date of amended clothes dryer energy conservation standards. 

## • Manufacturers would continue to use appendix D for clothes dryers until the energy conservation standards are amended; at that time, testing would be conducted pursuant to appendix D1.117 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Effects of Test Procedure Revisions on Compliance with Standards Effects of Test Procedure Revisions on Compliance with Standards – Room Air Conditioners  DOE has tentatively concluded that the proposed amendments to the DOE room air conditioner test procedure would not affect the measured EER of room air conditioners. **DOE invites comment on how the proposed amendments to the DOE test procedures for clothes dryers and room air conditioners will**  **affect the measured efficiency of products. In particular, DOE seeks data showing how certain proposed amendments affect the EF or**  **EER of minimally compliant clothes dryers or room air conditioners, respectively. (**  **Issue # 25)** 118 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

### In all correspondence, include all of the following:

– Residential Clothes Dryers and Room Air Conditioners Rulemaking

– Docket Number EERE - 2008 - BT-TP - 0010

– Regulatory Identification Number (RIN) 1904 -AC02 

### Email : AHAM2 - 2008 - TP - 0010@hq.doe.gov

Comment period closes August 30, 2010 Postal Mail : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program Mailstop EE - 2J 1000 Independence Avenue, S.W. Washington, DC 20585 - 0121 Courier : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program 950 L’Enfant Plaza, S.W., 6 th Floor Washington, DC 20024 Telephone: (202) 586 - 2945 

## DOE Seeks Comments on its Proposal119 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

# Additional Information120 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination – Effects on Measured EF  EPCA requires that DOE must determine how the EF of clothes dryers which are minimally compliant would be affected by the amendments to the test procedure, and based on this, amend the energy conservation standards as appropriate. (42 U.S.C. 6293(e))  For the standards rulemaking, DOE conducted a limited number of tests at an independent laboratory to analyze the various automatic termination technologies found in DOE’s sample of dryers. 

## • Over- drying to lower final RMCs requires higher energy consumption, with a slightly exponential trend likely because it becomes more difficult to remove final small amounts of moisture remaining in the test load. 

## • DOE did not observe any apparent relationships between the type of automatic termination sensor technology used and the amount of over- drying. 

## • Testing results may not be representative of the proposed testing methods.

– DOE had not yet developed the proposed test procedure for automatic cycle termination at the time that this testing was conducted.

– Test conditions different than those proposed were used (i.e., various cycle termination settings were applied to achieve low RMCs).121 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers DOE Automatic Cycle Termination Test Results

0 0.5 1 1.5 2 2.5 3 3.5

0 20 40 60 80Energy Consumption (kWh)

Estimated RMC (%)  Vented electric standard dryer single test run showing the cumulative energy consumption as the test load is dried122 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers DOE Automatic Cycle Termination Test Results

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7

0.0 1.0 2.0 3.0 4.0 5.0 6.0Over-drying Energy Consumption(kWh)

Estimate Final RMC (%) Temperature Sensing Moisture Sensing123 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination – Effects on Measured EF  Effect of changing the FU credit from 1.04 to 1.0 for automatic termination control dryers. 

## • An automatic termination control dryer capable of drying the test load to very close to 5 - percent RMC (no over- drying) would receive a 4 percent credit in EF compared to the current DOE test procedure.  Effects of requiring the test load to be dried to a target final RMC of 5 percent (or lower) for automatic cycle termination dryers.



## • Measured energy consumption would decrease and EF increase if the target RMC of 5 percent is achieved (no over- drying), compared to the current DOE test procedure which uses a correction factor to determine the energy consumption required to dry the test load to a final RMC of 4 percent. 

## • Based on the differences in the calculations of per- cycle energy consumption using a starting RMC of 47 percent, if the target final RMC of 5 percent is achieved, DOE believes that the EF would increase by about 2.4 percent using the proposed test procedure as compared to the current DOE test procedure.124 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Automatic Cycle Termination for Clothes Dryers Automatic Cycle Termination – Effects on Measured EF  All clothes dryers currently available on the U.S. market that are covered under the current energy conservation standards are equipped with some form of automatic cycle termination sensing.  DOE believes that a clothes dryer which is minimally compliant with current energy conservation standards would likely use a less accurate automatic termination control system.



## • Such a dryer would possibly over- dry the test load below 5 - percent RMC, such that the energy consumption and measured EF would be equivalent to that measured by the existing DOE clothes dryer test procedure. 

## • No changes to the current energy conservation standards as a result of the proposed amendments for automatic cycle termination would be warranted.125 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Initial Remaining Moisture Content – Effects on Measured EF  DOE investigated how the proposed amendments to change the initial RMC would alter the measured efficiency.



## • AHAM provided data on the change in measured EF that was observed when the initial RMC was reduced from nominally 70 percent to nominally 56 percent.

– Measured EF increased by an average of 22 percent in AHAM’s test sample of 11 baseline clothes dryers. Average EF increased from 3.09 to 3.77 lb/kWh.126 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities AHAM Data Submission on the Effects of Changes to the Initial RMC on Measured EF

- 0.4 - 0.2 0 0.2 0.4 0.6 0.8 1

2.95 3 3.05 3.1 3.15 3.2 3.25 3.3Change in EF at 56% RMC (lb/kWh)

EF at 70% RMC (lb/kWh) Corrected Scaling Factor Existing Scaling Factor127 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Initial Remaining Moisture Content – Effects on Measured EF  DOE conducted similar tests subsequent to the October 2007 Framework Document for representative baseline dryers.



## • One vented electric standard, one vented electric compact (240V), vented gas, and vent- less electric compact (240V). 

## • Tested each unit according to the current DOE dryer test procedure, but changing initial RMC to 56 ± 1 percent and 39 ± 1 percent to evaluate the effects of lowering the initial RMC. 

## • Data shows a non - linear trend in EF as a function of initial RMC. 

## • Using a polynomial trend to fit the datasets, DOE estimated a 47 percent increase EF resulting from changing the initial RMC to 47 percent.  After this analysis was complete, DOE conducted further testing on one maximum -available gas clothes dryer (tested for the standards rulemaking) to evaluate the effects on EF of changing the initial RMC.



## • Tested at reduced initial RMCs of 56 percent ± 3.5 percent and 47 percent ± 3.5 percent.128 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Initial Remaining Moisture Content – Effects on Measured EF (56% and 39% RMC Tests)

2 2.5 3 3.5 4 4.5 5 5.5 6

0 10 20 30 40 50 60 70 80EF (lb/kWh)

Initial RMC (%) Vented Electric Standard Vented Electric Compact (240V) Vented Gas Vent- less Electric Compact (240V)129 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Initial Remaining Moisture Content – Effects on Measured EF (56% and 47% RMC Tests)

2.5 2.7 2.9 3.1 3.3 3.5 3.7 3.9 4.1 4.3

30 40 50 60 70 80EF (lb/kWh)

Initial RMC (%)  Test results for a maximum -available gas dryer showed an average increase in EF of 40.6% when using an initial RMC of 47%.130 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Initial Remaining Moisture Content – Effects on Measured EF  DOE believes that a 41 - percent increase in EF resulting from switching from 70 - percent to 47 - percent initial RMC for a minimally compliant clothes dryer is representative.



## • The current energy conservation standards in terms of EF for vented clothes dryer product classes would need to be increased by 41 percent, based upon this proposed amendment. 

## • DOE would consider addressing this change in the concurrent standards rulemaking for residential clothes dryers, for which a final rule is scheduled for publication by June 30, 2011.131 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Test Load Weight – Effects on Measured EF  EF for clothes dryers is the bone -dry test load weight divided by the clothes dryer energy consumption per cycle.  The proposed amendments to the test load size would increase both the bone -dry test load weight and the energy consumption per cycle.  As lower nominal RMCs are reached at the end of the test cycle, the rate and efficiency of water removal from the load would be higher for the larger test load simply because there would be more water in the load, hence making it easier to remove.132 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities NIST Vented Electric Standard Clothes Dryer Variable Test Load Data  The National Institute of Standards and Technology (NIST) conducted testing to investigate the effects of changing the clothes dryer load size on the measured efficiency for a vented electric standard clothes dryer with a capacity of 6.3 ft 3 .



## • Clothes dryers were tested according to the DOE clothes dryer test procedure, except the test load size was varied from 2 lb to 15 lb. Test Number 1 2 3 4 5 6 7 8 Nominal Bone-Dry Weight, lb 2 3 5 7 9 11 13 15 Initial RMC, % 70.30 70.67 70.52 69.99 70.67 72.81 69.35 70.34 Final RMC, % 2.84 2.48 3.73 2.88 1.28 5.27 4.29 4.67 Per- Cycle Energy Consumption, kWh 0.970 1.167 1.637 2.160 2.638 3.303 4.005 4.582 EF, lb/kWh 2.06 2.56 3.04 3.24 3.41 3.33 3.25 3.27 Percentage Change in EF Compared to 7-lb Test, % - 36.6
- 20.9
- 6.0 0.0 5.2 2.7 0.3 1.1133 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov 

## Changes to Reflect Current Usage Patterns and Capabilities Clothes Dryer Test Load Weight – Effects on Measured EF  DOE estimated the percentage change in EF for an 8.45 - lb test load by linearly interpolating the NIST testing results for the 7 - lb and 9 - lb tests.  Using this method, the EF would increase by about 3.8 percent when increasing the test load size from 7 lb to 8.45 lb. 

## • DOE believes that this percentage change in EF can be applied to all vented standard - size clothes dryer product classes because it believes the moisture removal mechanisms are comparable among them.