May 22, 2013

Via E

- Mail

Ms. Ashley Armstrong U.S. Department of Energy

Office of the Building Technologies Program, Mailstop EE-2J 1000 Independence Avenue, SW Washington, DC 20585-0121

EERE_ACES@ee.doe.gov

Re: AHAM Request for Guidance on Several Refrigerator/Freezer Test Procedure Issues

The Association of Home Appliance Manufacturers (AHAM) respectfully submits the following

request s for guidance on several questions regarding the refrigerator/freezer test procedures, as specified below

.

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

costs.

I. What Surface Is Used to Set the Rear Clearance of the Unit During Testing When

the Back of the Unit Is Not All One Plane?

DOE’s recent amendments to the refrigerator test procedure recogni zed ambiguity regarding Appendix A1’s rear clearance requirements by clarifying the set

- up requirements for rear clearance. Specifically, DOE added language to the test procedure in Appendix A indicating that the “clearance shall not be greater than 2 inches (51 mm) from the plane of the cabinet’s back panel to the vertical surface. If permanent rear spacers extend further than this distance, the appliance shall be located with the spacers in contact with the vertical surface.” See 10 C.F.R. 430, Appendix A, § 2.8.p 2 Although this language does clarify the requirements as compared to Appendix A1, it does still leave ambiguity regarding what surface is to be used to set the rear clearance when the back of the unit is not all on one plane. Thus, AHAM asks D OE to clarify that, in that situation, testers

should refer to the Committee Draft for Vote (CDV) version of Part 1 of IEC 62552.2 Household refrigerating appliances – Characteristics and test methods

. 1 Annex B, section B.2.3.1 is consistent with Appendix A, § 2.8, but also provides more detail regarding the surface to be used to set the rear clearance. For example, it indicates that the rear plane of the appliance is the largest flat surface at the rear of the cabinet shell excluding any local features ( e.g., protrusions associated with brackets or the compressor). It also provides a number of diagrams that are helpful in determining how to set up the unit under test ( see Figure B1). AHAM understands that DOE may not be able to simply reference IEC 62552.2 in guidance, but we request that DOE issue guidance that exactly harmonizes with that draft standard. Not only does section B.2.3.1 match the intent of Appendix A, § 2.8, but harmonization with international standards is the best way to provide consistency and clarity to regulated parties and reduce burden on

manufacturers.

II. Is the Volume of All Air Ducts Deducted From the Determination of Volume?

10 C.F.R. 430, Appendix A, section 5.3 requires electric refrigerator and electric refrigeratorfreezer total refrigerated volume to be measured in accordance with AHAM/ANSI HRF -1-2008. That standard indicates that, among other things, the “volume of air ducts required for proper cooling and operation of the unit” “shall be considered as being in place and their volumes

deducted.” Does DOE interpret “the volume of air ducts required for proper cooling and operation of the unit” to include only the air ducts that feed the fresh food and freezer

compartments or all air ducts in the unit ?

III. How Are Product Classes Determined Without a Defrost Cycle Type?

Appendix A, section 1.9 states:

“Defrost cycle type” means a distinct sequence of control whose function is to remove

frost and/or ice from a refrigerated surface. There may be variations in the defrost control sequence such as the number of defrost heaters energized. Each such variation establishes a separate distinct defrost cycle type. However, defrost achieved regularly during the compressor off-cycles by warming of the evaporator without active heat addition is not a defrost cycle type

. (emphasis added)

The last sentence, in italics above, is confusing. It seems to imply that off

- cycle def rosts are not
automatic defrost units ; how ever, the only alternative is for off

- cycle defrosts to be considered

manual defrost units and that certainly cannot be the case since the customer would not interact with the defrost in such a product. The ambiguity in the sentence could also indicate th at if a product does not use a heater, then there is not a defrost cycle type. If that is the case, then, because product classes for refrigerator/freezers are based, in part, on defrost type, it would be impossible to determine what product class the product is in and the energy use of the product.

1 We understand that the CDV was circulated for vote on May 10, 2013, and that voting will close on August 16, 2013. Given that the standard is in the CDV stage, we do not expect substantive changes.p 3 Accordingly, due to the extensive confusion that sentence creates, AHAM r espectfully requests

that DOE clarify the intent behind the italicized language , including how product class is to be determined when a product does not use a heater.

IV. Compartment Temperature Measurements

DOE made the following amendments from Appendix A1 to Appendix A for section 5.1.2 (redlines indicate changes to Appendix A1):

Compartment Temperature. The compartment temperature for each test period shall be an average of the measured temperature s taken in a compartment during the test period as

defined in section 4. one or more complete compressor cycles. One compressor cycle is one complete motor “on” and one c omplete “off” period. For long- time automatic defrost models, compartment temperatures shall be those measured in the first part of the test period specified in section 4.2.1. For models with variable defrost controls, compartment temperatures shall be tho se measured in the first part of the test per iod specified in

section 4.2.2.

The amended language indicates that the averages of the compartment temperatures are to be taken during the test period defined in Section 4. This test period is from defrost to defrost and

includ es defrost recovery. AHAM would like to know what the reasons were behind this change

, especially considering the language in Appendix A1 , which specifically indicates that defrost recovery shall not be included. Our understanding is t hat it was not DOE’s intent to include defrost recovery, and we thus request that DOE clarify its intent so that regulated parties understand the compartment temperature requirements.

V. The Stabilization Period Duration is Unclear.

In the current test procedure, Appendix A1, the steady state condition is described, in section 2.9, to be measured over a stabilization period constrained by a two hour minimum:

2.9 Steady State Condition. Steady state conditions exist if the temperature

measurements in all measured compartments taken at four minute intervals or less during a stabilization period are not changing at a rate greater than 0.042 °F. (0.023 °C.) per hour as determined by the applicable condition of A or B.

A. The average of the measurements during a two hour period if no cycling occurs or during a number of complete repetitive compressor cycles through a period of no less than two hours is compared to the average over an equivalent time period with three hours elapsed between the two measurement periods.

B. If A above cannot be used, the average of the measurements during a number of complete repetitive compressor cycles through a period of no less than two hours and including the last complete cycle prior to a defrost period, or if no cycling occurs, the average of the measurements during the last two hours prior to a defrost period; arep 4 compared to the same averaging period prior to the following defrost period. (emphasis added)

The language above does not indicate a maximum constraint for the stabilization period. AHAM requests that DOE issue guidance clarifying whether no maximum constraint is intended or if the maximum constraint for the stabilization period is the first cycle that ends beyond the two hour minimum (i.e., a cycle could start b efore two hours but end after two hours and that would be considered the first cycle that ends beyond the two hour minimum). The stabilization period for

the latter would be determined by the number of completed cycles necessary to satisfy the two
hour mi nimum.

AHAM appreciates the opportunity to seek guidance clarifying these many questions on the refrigerator/freezer test procedures , and would be glad to further discuss these issues should you

so request.

Respectfully Submitted,

Jennifer Cleary

Direct or, Regulatory Affairs

cc: Lucas A di n, DOE