December 07, 2011 The Honorable CatherineZoi Assistant Secretary, Energy Efficiency and Renewable Energy U.S. Departmentof Energy Mail Station EE-10 1000 IndependenceAvenue, SW Washington, DC 20585 Via e-mail (cathy

.zoi@ee

.doe.gov) and overnight mail

Re: Petition forWaiver and Application for Interim Waiver concerning the measurement ofwater and energy used in the watersoftening regeneration process of Dishwasher having an Integrated Water Softener DearAssistant SecretaryZoi: BSH Home Appliance Corporation ("BSH") hereby submits this Petition for Waiver and Application for Interim Waiver pursuant to 10 CFR 430.27, concerning the test procedure for measuring energy consumption of Dishwashers. BSH is the manufacturer of household appliances bearing the brand names of Bosch, Thermador, and Gaggenau. Its appliances include dishwashers, washing machines, clothes dryers, refrigerator-freezers, ovens, and microwave ovens, and are sold worldwide, including in the United States. BSH's United States operations are headquartered in Irvine, California. BSH's appliances are produced in the United States and Germany.

10 CFR 430.27(a)(1) providesthat any interested person may submit a petition to waive for a particular basic model any requirement of Section 430.23, or of any appendix to this subpart, upon grounds that the basic model contains one or more design characteristics which either prevent testing of the basic model according to the prescribed test procedures, or the prescribed test procedures may evaluate the basic model in a manner so unrepresentative of its true energy consumption characteristics, or water consumption characteristics as to provide materially inaccurate comparative data

.Additionally, 10 CFR 430.27 (b)(2) allows any applicant ofa Petition ofWaiverto also request an Interim Waiver if it can be demonstrated the likely success of the Petition for Waiver, while addressing the economic hardship and/or competitive disadvantage that is likely to result absent afavorable determination on theApplication for Interim Waiver. This request for Waiver is directed to Dishwashers containing a built-in or integrated water softener, specifically addressing the energy and water used inthe regeneration process of the integrated water softener. This request is identical to Waiver Case Number DW-005 previously granted to BSH Home Appliance Corporation with the only modification being to add additional model numbers. Further, the water softening technology used in these models is identicaltothe modelsthat were previously approved. Based on the reasoning indicated herein, BSH submits that the testing of Dishwashers equipped with a water softener under the current DOE test procedure may lead to information that could be considered misleading to consumers.
1. Identification ofBasic Models. The Dishwasher models manufactured by BSH which contain an integrated water softener and were not included in Waiver case No

. DW-005 is as follows: Bosch brand: • Basic Model
- SHE7ER5#UC • SHE7ER5#UC • SHV7ER5#UC • SHX7ER5#UC • SGE63E1#UC • SHE9ER5#UC • SHV9ER5#UC • SHX9ER5#UC • SHE8ER5#UC • SHX8ER5#UC • Basic Model
- SPE5ES5#UC • SPE5ES5#UC • SPV5ES5#UC • SPX5ES5#UC Thermador brand: • Basic Model
- DWHD650G## • DWHD650G## • DWHD651GFP • Basic Model
- DWHD640J## • DWHD640J## • Basic Model- DWHD651J## • DWHD650J## • DWHD651J##

2

. BackgroundThe design characteristic that is unique among the above listed models is an integrated water softener. The primaryfunction ofa water softener is to reduce the high mineral content of "hard" water. Hard water reduces the effectiveness of detergents leading to additional detergent usage. Hard water also causes increased water spots on dishware, resulting in the need to use more rinse aid to counterbalance this effect. "Hard" water can reduce customer satisfaction with Dishwasher performance resulting in increased pre-rinsing and/or hand washing as well as increased detergent and rinse agent usage. The water softening process requires water usage for both the regeneration process and to flush the system. For purposes ofthis Waiver request, the term "regeneration" will include the water and energy used in both the flushing and regeneration process of the water softener. The water used in the regeneration process is in addition to the water used in the dish washing process. The water used in the regeneration process does not occur with each use of the Dishwasher. The frequency of the r egeneration process is dependant upon an adjustable water softener setting that is controlled by the end user, and based on the home water hardness

. Regeneration frequency will vary greatly depending upon the customer setting of the water softener

. Data from the U.S. Geological Survey shows considerable variation in the water hardness within the U.S. and for many locations the use ofa water softener is not necessary. Water hardness varies throughout the U.S. with the mean hardness of 217 mg/liter or 12.6 grains/gallon (based on information provided by the U.S. Geological Survey located at http://water.usgs

.gov/owg/hardnessalkalinitv

.html). 

### Calculations 

### Water Use • Based on the DOE Energy Test for Dishwashers, the BSH Dishwashers listed in this waiverwith an internal water softener use an average of6.65 liters ofwater per dish cleaning cycle. • Based on an average U.S. water hardness of 12.6 grains/gallon, the internal BSH Dishwasher water softener system would be set on "4". • Based on a BSH Dishwasher internal water softening system setting of "4" and the dishwasher using 6.65 liters ofwater per run, the water regeneration processwould occurevery 6th cycle. • When using the Dishwasher 215 times per year (per DOE test procedure), the regeneration process would occur 35

.8times (36). • The internal BSH water softening system uses 4

.97 liters (5

.0) per regeneration cycle

. • Water usage calculation based on above data

. o 36 x 5 = 180 liters per year (47

.6 gallons) or
.84 liters (.22 gallons) each timethe dishwasher is used.

### Energy Used in kWh • Formula W= V x T x K o V =Weighted Average Water Usage per DOE o T = Nominal water heatertemperature rise of39° C o K = Specific heat ofwater 0.00115 • Calculated Energy use - 180x 39 x
.00115 = 8.0 kWh/yr 

### Summary

• A Dishwasher built by BSH with an integrated water softener in a home with a 12

.6 grain per gallon water hardness would be cycled through the water softening regeneration process approximately every 6 dish cleaning cycles

. When the water used in the water softener regeneration process is apportioned evenly over all dishwasher runs, the amount of energy and water usage per cycle is very low. Based on the assumptions provided, BSH estimates the typical water used in the internal Dishwasher water softener r egeneration process at

.84 liters (.22 gallons) per use; furthermore, using about 8.0 kWh per year to heat this water in the home hot water heater. Note: Contrary to current DOE direction, in BSH's opinion the water used in the Water Softening regeneration process has the separate and distinct purpose of softening water and we do notfeel that this water and energy should be included in the energy usage figures for washing dishes

. EN 50242 does not include the water or energy used in the water softening process in the dishwasher energy consumption calculation and BSH would suggest adopting a similar approach as used in EN50242 when the test procedure is updated. 3. Requirements soughtto be waived Dishwashers are subjected to test methods outlined in 10 CFR Part 430, Subpart B, App. C, Section 4

.3, which specifies the method for the water energy calculation.

• To stay consistent with the recently approved Whirlpool waiver, BSH is requesting approval to estimate the water and energy used in the water softening process based on the design of the BSH Dishwasher and the calculations and assumptions outlined above

.
4. Grounds for WaiverandInterim Waiver10 CFR 430.27 (a) (1) provides that a Petition to waive a requirement of 430.23 may be submitted upon grounds thatthe basic model contains one or more design characteristics which either prevent testing of the basic model according to the prescribed test procedures, or the prescribed test procedures may evaluate the basic model in a manner so unrepresentative of its true energy consumption characteristics as to provide materially inaccurate comparative data. If a water softener regeneration process was to occur while running an energy test, the water usage would be overstated. In this case, the water energy usage would be unrepresentative of the product providing inaccurate data resulting in a competitive disadvantageto BSH

. Granting of an Interim Waiver in this case is justified since the prescribed test procedureswould potentially evaluate the basic model in a manner so unrepresentative of its true energy consumption characteristics as to provide materially inaccurate comparative data. In addition, a similar Interim Waiver and Waiver has previously been granted to BSH

. 

### 5

. Manufacturers ofSimilarProducts andAffectedManufacturers Web based research shows that at least two other manufacturers are currently selling dishwashers with an integrated water softener, Miele Inc. and Whirlpool Corporation (Waiver Granted). Manufacturers selling dishwashers in the United States include AGA Marvel, Arcelik A.S., ASKO Appliances, Inc., Electrolux North America, Inc., FagorAmerica, Inc., Fisher & Paykel Appliances, GE Appliances and Lighting, Haier America, Indesit Company Sa, Kuppersbusch USA, LG Electronics USA, Miele, Inc., Samsung Electronics Co., Viking Range Corporation and Whirlpool Corporation. BSH will notify all companies listed above (as well as AHAM), as required by the Department's rules, providing them with a copy ofthis Petition for Waiver and Interim Waiver. 

### 6. Conclusion BSH Home Appliances Corporation hereby requests approval of the Waiver petition and Interim Waiver. By granting said Waivers the Department of Energy will further ensure that water energy is measured in the same way by all Dishwasher Manufacturer's that have a integrated water softener. Further, BSH would request that theseWaivers be in good standing until such time thatthetest procedure can beformally modified to accountfor integrated watersofteners.BSH Home Appliances certifies that all manufacturers of domestic Dishwashers as listed above have been notified by letter. Copies ofthese notifications are attached. With Best Regards, Mike Edwards

# f\A-CZ2~

# nior Engineer, Performance and Consumption

# ~~H HomeAppliances Corporation (FNbG) 100 Bosch Blvd

., Building 102 New Bern, NC 28562-6924 mike

.edwards@bshg.com www.boschappliances.com Phone (252) 636 4334 Fax (252) 636 4450