Department of Energy

Washington, DC 20585

MEMORANDUM TO DOCKET EE-RM-93-801

ENERGY EFFICIENCY STANDARDS FOR REFRIGERATORS,

REFRIGERATOR-FREEZERS, AND FREEZERS

FROM: DOUG SMITH

DEPUTY GENERAL OUNSEL FOR ENERGY POLICY

DATE: OCTOBER 4, 1996

SUBJECT: MEETING WITH OFFICIALS FROM WHIRLPOOL CORPORATION

On September 30, 1996, Secretary O'Leary, Deputy Secretary Curtis, Chief of Staff Dan

Reicher, Deputy Assistant Secretary for Energy Efficiency and Renewable Energy Joseph

Romm, and I met with the following officials from Whirlpool Corporation: Ralph Hake,

Executive Vice President, North American Appliance Group; Andy Takacs, Vice President

Government Relations; Ed Wendholt, Director, Laundry Technology; Robert W. Johnson,

Director, Product Technology, Refrigerator Group; and Michael Thompson, Director,

Government Relations. Whirlpool made a presentation on the subject of energy efficiency

standards for washing machines and refrigerators. The briefing materials are attached.

Attachment

' Printed with soy ink on recycled paper

 EE-RM-94-403 COMMENT 50

, . 

Department of Energy 

Washington, DC 20585 

MEMORANDUM TO DOCKET EE-RM-93-801 

ENERGY EFFICIENCY STANDARDS FOR REFRIGERATORS, 

REFRIGERATOR-FREEZERS, AND FREEZERS 

FROM: DOUG SMITHVJ-'7 . . 

DEPUTY GE~El{AL fuUNSEL FOR ENERGY POLICY 

DATE: OCTOBER 4, 1996 

SUBJECT: MEETING WITH OFFICIALS FROM WHIRLPOOL COR,eORATION 

On September 30, 1996, Secretary O'Leary, Deputy Secretary Curtis, Chief of Staff Dan 

Reicher, Deputy Assistant Secretary for Energy Efficiency and Renewable Energy Joseph 

Romm, and I met with the following officials from Whirlpool Corporation: Ralph Hake, 

Executive Vice President, North American Appliance Group; Andy Takacs. Vice President 

Government Relations; Ed Wendholt, Director, Laundry Technology; Robert W. Johnson. 

Director, Product Technology, Refrigerator Group; and Michael Thompson, Director, 

Government Relations. Whirlpool made a presentation on the subject of energy efficiency 

standards for washing machines and refrigerators. The briefing materials are attached. 

Attachment 

.' ,® Printed wtth say ink on recycled paper 
DOE BRIEFING:

APPLIANCE ENERGY

EFFICIENCY STANDARDS

September 30, 1996

 EE-RM-94-403 COMMENT 50

DOE BRIEFING: 

APPLIANCE ENERGY 

EFFICIENCY STANDARDS 

'-. September 30, 1996 
AGENDA

* Introductions

* Why are we here?

* Background: Whirlpool has spent millions based on high

efficiency appliances

* Justification for early effective dates

* Justification for stringent efficiency levelsX

* Other comments (time permitting)

- Cumulative burden

- Consumer perspectives on energy & water savings

| Whirlpool's plans to build energy efficiency appliances

I Our request

// ~~~:- / /~~~~~~~//~~~- / 

9~~~~~~

 EE-RM-94-403 COMMENT 50

AGENDA 

• Introductions 

• Why are we here? 

• Background: Whirlpool has spent millions based on hig,h 

, efficiency appliances , 

• Justification for early effective dates 

• Justification for stringent efficiency levels '. 

• Other comments (time permitting) 

- Cumulative burden 

- Consumer perspectives on energy & water'savings 

• Whirlpool's plans to build energy efficiency appliances 

., Our request 
Overview of

Whirlpool Corporation

Founded: 1911

Products: All major home appliances

plus some portables

Number of Brand Names: 11

Number of Countries:

· where we manufacture: 12

* where we market: 140

Number of Employees: 45,000

Annual Revenues: $8.3 Billion

_ _ ·.... ' _ · _ '. ' ..-. ". 

 EE-RM-94-403 COMMENT 50

Overview of 

. Whirlpool Corporation 

Founded: 

Products: 

Number of Brand Names: 

Number of Countries: 

. • where we manufacture: 

• where we market: 

Number of Employees: 

Annual Revenues: 

1911 .. . . 

All major home appliances 

plus some portables 

11 

12 

140 

45,000 

$8.3 Billion 
-NAWIECA Language

Section 325

"(g) Standards for Dishwashers; Clothes Washers; Clothes

Dryers.

"(4)(A) The Secretary shall publish final rules no later than

January 1, 1990

"(B) After January 1, 1990, the Secretary shall publish a

final rule no later than five years after the date of

publication of the previous final rule. (May 14, 1996)

"(C) Any such amendment shall apply to products

manufactured after a date which is five years after-

"(i) the effective date of the previous amendment;

-..,,..... ,,~.~.~~~~:;.,~~ -,~~.... ~~..i~~~~~i~~~~!! !::'" ~-!i; ii; i: ~i ,.~ ........,.,..~7 ..................... Oi:lz¢. ·........... .,.',, .. ~":

 EE-RM-94-403 COMMENT 50

NAECA Language . . 

Section 325 

"(g) Standards for Dishwashers; Clothes Washers; Clothes 

Dryers. 

"(4) (A) The Secretary shall publish final rules no later than 

January 1, 1990 

"(8) After January 1, 1990, the Secretary shall publish a 

final rule no later than five years after the date of 

publication of the previous final rule. (May 14, 1996) 

"(C) Any such amendment shall apply to products 

manufactured after a date which is five years after-

"(i) the effective date of the previous amendment; 
DOE Clothes WNasher Energy

Standards Rule - May 14, 1991

DOE said

"Because of the great energy savings potential of this

design (ie. horizontal-axis), DOE is evaluating this

technology as soon as possible" (FR22269, 5/14/91)

"Since DOE has decided to consider the horizontal axis

technology with its associated fixed costs as soon as

possible, the Department issues a Final Rule today

that imposes minimal impact on manufacturer's

retooling costs" (FR22270, 5/14/91)

 EE-RM-94-403 COMMENT 50

DOE Clothes Washer Energy 

Standards Rule - May 14, 1991 . . 

. DOE said 

"Because of the great energy savings potential of this 

design (ie. horizontal-axis), DOE is evaluating this 

technology as soon as possible" (FR22269, 5/14/91) 

. . 

"Since DOE has decided to consider the horizontal axis 

technology with its associated fixed costs as soon as 

. possible, the Department issues a Final Rule today 

that imposes minimal impa,ct on manufacturer's 

retooling costs" (FR22270, 5/14/91) 
NAECA Language

Section 325

"(b) Standards for refrigerator-freezers, and freezers

"(3)(A)(i)...The Secretary shall publish a final rule no later

than July 1, 1989...which shall apply to products

manufactured after January 1, 1993"

"(B) After the publication of a final rule under

subparagraph (A), the Secretary shall publish a final

rule no later than five years after the date of

publication of the previous final rule." (111/95)

.Cfl~~~~~~~.. .*.n,.,. . . .*, ~~~~~~~~~~~~~~~~~~~~~. ~ ~ ~ ~. A' ~~~~~~g

 EE-RM-94-403 COMMENT 50

-NAECA Language 

Section 325 

"(b) Standards for refrigerator-freezers, and freezers 

"(3)(A)(i) ... The Secretary shall publish a final rule no later 

than July 1, 1989 ... which shall apply to products 

manufactured after January 1, 1993" 

~ "(8) After th'e publication of a final rule under 

subparagraph (A), the Secretary shall publish a- final 

rule no later than five years after the date of 

publication of the previous final rule." (1/1/95) 
High Efficiency Clothes Washer Technology

Company Activity Other Comments

Purchased commercial H-axis plant 2 Division of Raytheon

AMANA year ago. (approx. $11-12 billion annual sales)

Has marketed H-axis for years; new Part of Swedish parent -ElectroluxFRIGIDAIRE H-axis promised for the last year. (approx. $11-12 billion annual sales)

"Plans to market H-axis washers in Approx. $70 billion in annual sales.

GENERAL the U.S. for those consumers who (One of the world's top companies with

ELECTRIC choose to buy them." (Appliance Mfgr., $137.3 billion in assets, USA Today p.28

8/95) 7/1/96)

Is committed to building H-axis Final stages of a $50-M investment to

MAYTAG products. Expected introduction is develop H-axis and companion dryer ... we

1997. are "stronger financially" and have "choices

-9~~ ~~..~ ~for growth that we have not had for

sometime." (CEO Hadley-PR Newswire

9/16/96)

WHIRLPOOL Has more than one high efficiency Has largest clothes washer production in the

clothes washer design. U.S.

_ B H _ _

 EE-RM-94-403 COMMENT 50

Company 

AMANA 

FRIGIDAIRE 

GENERAL 

ELECTRIC 

MAYTAG 

WHIRLPOOL 

High Efficiency Clothes Washer Technology 

Activity 

Purchased commercial H-axis plant 2 

. year ago. 

Has marketed H-axis for years; new 

H-axis promised for the last year. 

"Plans to market H-axis washers in 

the U. S. for those consumers who 

choose to buy them." (Appliance Mfgr., 

8/95) 

Is committed to building H-axis 

products .. Expected introduction is 

1997. 

Has more than one high efficiency 

clothes washer design. 

Other Comments 

Division of Raytheon 

(approx. $11-12 billion annual sales) 

Part of Swedish parent -Electrolux-

(approx. $11-12 billion annual sales) 

Approx. $70 billion in annual sales. 

(One of the world's top companies with 

$137.3 billion in assets, USA Today p.28 

7/1/96) 

Final stages of a $50-M investment to 

develop H-axis and companion dryer ... we 

are "stronger financially" and have "choices 

for growth that we have not had for 

sometime." (CEO Hadley-PR Newswire 

9/16/96) 

Has largest clothes washer production in the 

U.S. 
CL OTHES W\.ASHER ENEPRGY STAnDARDS

IMPACT OF EACH YEAR'S DELAY ON

CLOTHES WASHER ENERGY USE

(over the life of the roduct at 3.0enegy factor)

Total: =' l0. miio barel ofi oi e quiva l en t=

Consumerr Cost Impactl.

4_ ilo nt. $ .6 Iyr x 14_years 1 bilio

p ~ ~ ~ ~ ~ ~~~~~~~~.... .:i ei

 EE-RM-94-403 COMMENT 50

r,LOTHES \A1ASHER ENERGY ST,L~\f'JD,L\RDS 

IMPACT OF EACH YEAR'S DELAY ON 

CLOTHES WASHER ENERGY USE -
CLOTHES WASHER ENERGY STANDARDS

IMPACT OF EACH YEAR'S DELAY ON

DRYER ENERGY USE

(over the life of the product at 50% RMC)

... " cz2>'- ~ .1 2.7 mliion..barrels of oil equivalent

I ilion uitsx56 hrs/rx1 years ;7sr8.4 iP~ion therms itl~i

Elcti Dryers

>::::::::::::I :_:::::: ~ ~ ~ ~ ~ O .:e ~

. Gas.Dryer~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~....!Ils

m iiouits $14 yers $ 4 mdniion i 

5li:~ii~i-i~i 6807" million 9 1 y.: ...... -!Haiti : C~v::n: 2~::.... . . institutional::~~~~~~~~~~~~~~~~~~~~~~~~~~r:! iiii:·iiiiijiaail~~~~~~~~~~~~~~~~~~~~~~~~~~~ijjiiiiia

~~ ~ I ~~~~~~~~: ~ ~ ::::i~~~~~~~~~~i!:::::i,~~~~~

x:::::::g::::~~~~~~~~~~~~

....... li::::::::iI3 hi i f b Iva:::·iiiiijai iii~~~~~~i i~~~~~~~~~'i:~~~~~iiiiiiiilisjiiiii:~~~~~~~~~~~~~~~~~~~~Xiiiii~~~~~~~~ii...... a·:I::::i~ii~l~i~~:i::i ::::::;:::::::::::i ... .... .... .:::::4: 1 ::::: I. ..... I y b::i 77= 77777 = ........... ::::

I:I~~l~i~i~i~ia::si~~ilil:~:iiii~~iii~ l ~ ::: I :·:·' · ·:::::li:·:-l-::i~ .........

b ~~~~h a .. .......... :::::::i:::::::I:il:

::I:::I::: II: ~ .. .......

iiliiiiiii ~1~ii01 . . .. ....

~i~iili ·~ln::-::;*r I~:~:_::: ::I-': 1III:i i xL::: 11 P -: liN ii I i iiii 1:.:i-3 6 Jk 1_-4 i~'.::::: ::: ':::::::: ::: :::l~l13iii~iii~ii~$ 7-6 2:i:X~li~:`!ji!-i 0ni · ,li li:,~~~~~:~ -::·:::::::::-:::·:::::::::-::,:·::::::,:.::.:: il,_,:~~~~,:e:::.::::::::-: ,:::::::,:::: . ....I. . ::::::::1:::::::::4~~~~~~

...... ..... .h fii ,li i ilingsii li lilii: ciiiili

.0 Ve:~~~~~~~~~iiii~i:l:S~ii~i~iiliii

:::::I:::::+r?~~iii~~iZ:·i~i·~::::ii~MET,:~ilii:-:::::::::

 EE-RM-94-403 COMMENT 50

CLOTHES WASHER ENERGY STANDARDS 

IMPACT OF EACH YEAR'S DELAY ON_ 

DRYER ENERGY USE 

(over the life of the product at 500/0 RMC) 
A ~~~~4 ~ ---- -- - ----- ------

CLOTHES WASHER ENERGYSTANDARDS

IMPACT OF EACH YEAR'S DELAY ON WATER USE

' ' (over the life of the product)

W ateri m ct. ... .. .......... .... .

I~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

7 mili~~i:i:iii::lion :: units 6240gallon/yearx 14 yars =612 biliop allon

Consumerlij~j Cost mpac

I: ili i i ~ : .......

/ 6240 gallons/year.x.$2.84/.O allnr=$772ui gi.y 

A'. <... .. . ' .......... .... ..... .. 

.

::~~~:·....... ........

i~i~~i~~i~~~i~::i~r::..... ...... liii l-j:- .iii:Iiiiibi iumi: iii w :: : : . : : : : : : : : : : : : : : ·:······ iil: ...

......... ... ,:::,: ~ ~i~jji:~~:-i:;;:::::i·:::4 4 Ve :: a : ::,.: .

: :: : :: :- : 1. ........i:t

~~ib .:::~I .:I:::::r::::::: ilii (i :~~~il ~iiliilillllii~~i - I i-ii l-...... ...... ........

 EE-RM-94-403 COMMENT 50

CLOTHES WASHER ENERGY STANDARDS 

IMPACT OF EACH YEAR'S DELAY ON WATER USE 

(over the life of the product) 
-4,

CLOTHES WASHER ENERGY STANDARDS

TOTAL IMPACT OF EACH YEAR'S DELAY

(over the life of the product)

d Clothes W,,a sh! P ere'!" | 60.0t0 w milion ibarrel ofsoiil eqialn

A.... -~~~~~~~~~ 0 equialeT tl 74l mlionsinwSc barres of oilx

___________ 

612 illion gallonslri~

iii Drye·r $ . bilio

i~~~~~i :.:::::::::::I:I::··:·:·i: · :~~~~~~~~~~~~~~~~~~~~~~~~~~

i~~~~~~~~~~~~~~l:P-i:Ji ~ ~ ~ ~ ~ ~ .::...... .W 4~s's~'. / ~ *r* ' / /

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~isiiri:i_ii::-::::::

 EE-RM-94-403 COMMENT 50

CLOTHES WASHER ENERGY STANDARDS 

TOTAL IMPACT OF EACH YEAR'S DELAY 

(over the life of the product) 
i Energy Levels Available - Refrigerators

Top Freezer Produds

Product inufacturer

Size Arana Frigidaire GE Maytag V poo

15/16 _100/ 20%/ -0%0/ 15%

17/18 20% 10%* 25% 15% 20%

19/20 15% 0%0/* 25% 15% 20%

21/22 20%0/ 0/* 20% 15% 25%

23+ 25% 0/0%* 100/o 00/a00/ 

* Better efficiency levels were available in 1995.

'_______~ -Side-by-Side Productds

Product IManufraurer

Size Anrrna Frigi dare GE Maytg

19/20 20% 10%/ 0.% 15%

21/22 - 25% 20%/ 20% 15% 400o/

23/24 20%/o 20%/o 15% .

25/26 25% 15% 35%

27+ 20%/ 15% 20% 0/0 35%

Nurb ers represent amount better than '93 Federal Standard (rounded doaM to nearest 5%),

based on data from the June, 1996 AHAM Drecory of Certified Rerierators and Freezers.

::~-.".',~?...'/..-~.~.~.~,,~.~ _~ .! .z.~. . - .........." ........................

 EE-RM-94-403 COMMENT 50

Energy Levels Available -- Refrigerators 

~I reezer s 

AOOtd l\A3nt.Jfcdurer 

Size ArrEna Frigidaire GE rvl3ytaJ WlinJXd 

15'16 10010 2QO/o -0010 15% 

17/18 2QO/o 100/0* 25% 15% 2QO/o 

19120 15% 00/0* 25% 15% . 2QO/o 

21/22 2QO/o 0010* 2Q01o 15% 250/0 

23+ 25% ' 00/0* 100/0 00/0 00/0 

* Better €ffiden,y levels 'Aere availalle in 1995. 

Side-Of-Side PnxJLds 

PrOOLd rv'tanufocturer 

Size Arrena Frigidaire GE rvl3ytaJ Wlinp:n 

19120 2QO/o 100/0 0.% 15% 

21/22 .. 25% 2QO/o .2QO/o 15%, 40'10 

23124 2QO/o 2QO/o 15% ,. 

25/26 25% 15% 350/0 

27+ 2QO/o 15% 2QO/o 0010 ·35% 

N.Jrrtas rep-esent arrount tetter than '93 Federal Stardard (rc:x.Jr"daj cbMl to nearest 50/0), 

tmro CX1 data frem the Jure, .1900 AI-Wv1 [)rEdory ci Certifioo Refrieratcrs ard Freezers. 
REFRIGERATOR ENERGY STANDARDS

IMPACT OF EACH YEAR'S DELAY (TIER 2)

(Over the life of the product)

, ffi Energy - ,,,, Imverath ,~~~~~~~~~~~~~~~~~~~~~~~~~~..... .... ........... ., ,.., ....

::i:,:I: I:i !6 S X1 = 

8 .5.EE~~E..FE m -.0-..~.E iion!E uEflf -it i S~#E .145 ~ kw /y 17 yearsid- =. 20. bdin w

er- > 28,,4 m l b r o::...nili: fvtl .. . .. ~~~~~~~~~~~~~~~~~~~~~~.. ... 'n'

a:31111 n.,?: ro. .. :g . . ... ii tP. .. E...-.i.-...i...;..... -p C P P. I z qell . ... ..... 

i es t:

/:::li,:r~i:^i~i:·::_:i::: I~i8 :i~ii~l-:r::::i:::::::::::::::::::: i:::::::::: i~i:.:l:::i::l::::: -·li~l~i i~i~i~iiiiiiili~i-i~i~l~.......... ...... .......

/ 4.... - $250 million per yr~~~~~~~al

... (produ..t. cost) tiiiwlilirisiijiiijii:i1 5 biMlio lo........ ss. .......... iii l -i jjiiiiiii r y r d e ...... iii. iiiliipe la y ~ :::-7 :::T: ::::::::: -:: iii~j ~~i -:li I: ::: ~i jii.::::i~i:::: ::(:I:: : i i::i~i -............ ::: i~: .:

:·::·:::::-::·::::::::::::::::::::::::::~~~~~~

a l~~~i : : ::iil: : : ~~i ~ ::·i: : : i~~i ::·: : , i ~~~i : : ::::::::::::::::::::·:-~~.......

......... ii,:.:::::::::-::::::::::::::li~ssa iii'liiiiiiir·::::::::::-::::::::I::........... : ...........

......... .. :::i-:::jl .............. i~i~~ii~~ii~:II-

:i-i~i::i~i;_iiiilif l-7i uo n lil e iir

.. .~ ......... ......... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~~~ ~~~~::::::::;. .......- :.·.·· · .·-::.:.:::::::-:::::-

....... . ..~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~'.''.':IR:::~j:j::

..........~ ~ ~ ~ ~~~:: ::

.. . . . .. . . . .. . ...

 EE-RM-94-403 COMMENT 50

REFRIGERATOR ENERGY STANDARDS 

IMPACT OF EACH YEAR'S DELAY (TIER 2) 

(Over the life of the product) 
Trends in Refrigerator Energy Consumption

87 CEC Std.

1;400 - : , 90 DOE Std.

93 DOE

1200

. 1 '000

>1 00 - Predicted

-600- - -,IHstnical

a, .. ..

I I~~~~~~~~~~~~~~~~~~~~irs

 EE-RM-94-403 COMMENT 50

Trends in Refrigerator Energy Consumption 

1400 

13lO 

200 

I· 

I 

87 CEC Std. 

90 DOE Std. 

93 DOE 

Predicted 

I 

I 

I . 

I 

O~~~~~-r~~~~~~~~~~~~ 

1~1~1~ 1~ 1~ 1~1m1~1~ 1~~~~ 

... ~~0I12 

~q1iori4 

-41-H~c3I 
Quotes from "Joint Comments Relating to Energy

Conservation Standards for Refrigerator/Freezers"

(November 15, 1994)

Isection , "yThe agreed to standards comport fully with the standards

criteria in NAECA"

S(page23) * "The energy savings.. .are very significant."

[ "These standards were chosen at a level that provides for

no significant lessening of utility or performance."

* "None of the parties to these agreements believe that the

standards will lead to a likelihood of reduced competition."

(g 2 * "The non-HCFC standard avoids the possibility that some or

all manufacturers would have to drastically reduce product

offerings because of their inability initially to meet the 1998

standards without HCFC-141b."

-- * siniiant le s nn of utS:.::>:~ilfit or.... peform nc .".....5

 EE-RM-94-403 COMMENT 50

Section VI 

(page 22) 

Section VI 

(page 23) 

Quotes from "Joint Comments Relating to Energy 

Conservation Standards for Refrigerator/Freezers" 

(November 15, 1994) 

. 

• "The agreed to standards comport fully with the standards 

. criteria in NAECA" 

• "The energy savings ... are very significant." 

• "These standards were'chosen at a level that provides for 

no significant lessening of utility or performance." 

• "None of the parties to these agreements believe that the 

standards will lead to a likelihood of reduced competition." '. 

• "The non-HCFC standard avoids the possibility that some or 

all manufacturers would hav~ to drastically reduce product 

offerings because of their inability initially to meet the 1998 

standards without HCFC-141 b." 
WON= ---- -

Appliance Market Pull & Utility Incentive Programs

Program Activity Location Timetable

Energy Star (DOE)* Pre-pilot D.C. only 1995

Pilot 4 Cities Late 1996

Implement Nationwide Mid 1997

Federal Energy Appliance purchasing 1997

Management Program guidelines are being

(DOE) developed

SERP Super efficient refrigerators 23 Utility Ends

Districts Mid 1997

Consortium on Energy High efficiency clothes Mostly Ongoing

Efficiency washers West Coast

* Clothes washers are not part of the pilot program.

/~~~~~~~~~~~~~~~~~~~~~iii

 EE-RM-94-403 COMMENT 50

· . 

Appliance Market Pull & Utility Incentive Programs 

Program Activity Location Timetable 

Energ~ Star (DOEt Pre-pilot. D.C. only 1995 

Pilot 4 CiHes Late 1996 

Implement Nationwide Mid 1997 

Federal Energy Appliance purchasing 1997 

Management Program guidelines are being 

(DOE) developed 

SERP Super efficient refrigerators 23 Utility Ends 

Districts· - Mid 1997 

Consortium on Energy High efficiency clothes Mostly Ongoing 

-Efficiency -washers West Coast 

.. Clothes washers are not part of the pilot program. 
Importance of Features on

Consumer Purchase Decision

Clothes Washer

Load Position

Wash Time

Ease of Opening

Price

Axis .

Agitator

Noise Level

Water Savings

Spin Speed

Energy Savings i

0 10 20 30 40 50 60 70 80

Utility Value of Feature on Purchase Decision

Base: 200 female washer owners

,rce: WhirlpoolCorp., WasherConjoinoAnalysis, Mar., 1992 (BasesCorp.) 8

 EE-RM-94-403 COMMENT 50

Importa'nce of Features on 

Consumer Purchase Decision 

Clothes Washer 

Load Position 

Wash Time 

Ease of Opening 

Price 

Axis .. 

Agitator 

Noise Level 

Water Savings 

Spin Speed 

Energy Savings 

'. 

o 10 20· 30 40 50 ' 60 70 80 

Utility Value of Feature on Purchase Decision 

, 

Base: 200 fem~le washer owners 

"nur,r:p.." OWhirlpoolCorp" WasherConjoinJAnalysis, Mar., 1992 (Bases Corp.) 
Importance of Features on

Consumer Purchase Decision

Dishwasher

Cleaning

Reliability

Durability

Capacity

Price

Quiet

Water Usage

Energy Usage - Rack Loading

Controls mm

0% 20% : 40% 60% 80% 100%

s; % of Consumers Rating Extremely or Very Important

Base: 1930 Nationally Representative Households

Source: WhirlpoolCorp., DisirnasherPurchase Process, I 992;MarelFoacs, Inc.

 EE-RM-94-403 COMMENT 50

. Importance of Features on 

Consumer Purchase -Decision 

Dishwasher 

Cleanln'g 

ReUabllity 

Durability 

Qual. of Construction 

Safety 

Ease of Service 

Capacity 

Price 

Quiet 

Water Usage 

Energy Usage 

Ra~k Loading 

.. Controls 

0% 20% 40% 60% 80% 100% > 

~_ % of Consumers Rating Extremely or Very Important 

Base: 1930 Nationally Representative Households 

Dishwasher Purchase Process, 1992; MamlFacls, Inc. 
Standardized Appliance Measurement of Satisfaction

Importance of Factors

Washers 1995/96 Refrigerators

Cleaning Clothes Quality

Clothes Care Shelf Access OEM=

Capacity Performance

Appearance Capacity

Durability _ _ Appearance

Energy ESf. Energy Eff.

Balance Adjustability

Operation _ Quietness

0 20 40 60 s0 0 20 40 60

Correlation with Satisfaction Correlation with Satisfaction

Base: 2498 Washer owners Base: 6535 Top Mount & Side x Side owners

Dishwashers Dryers

Cleaning _i~b~-~Fasx~ Drying Clothes

Capacity Clothes Care _

Appearance __ Appearance

Drying I Capacity

Durability Balance

Convenience ' Energy Eff.

Energy Eff. Durability

operation __ ______ Operation . .

0 20 40 60 80 0 20 40 60 80

Correlation with Satisfaction Correlation with Satisfaction

Base: 3970 DW owners , Base: 2262 Dryer owners

____ ...... , , n X s w rim Inn X no. Isr~n Do SOL r ..... 20

 EE-RM-94-403 COMMENT 50

.§.tandardized Appliance ,Measurement of §atisfaction' ~ 

Importance of Factors 

Washers 1995/96 Refrigerators 

Cleaning Clothes 

Clothes Care 

capacity 

Appearance 

Durability 

Energy Eff. 

Balance 

Operation 

o 20 010 60 

Correia lion with Satisraction 

Base: 2498 Washer owners 

Cleaning 

Capacity 

Appearance 

Drying 

Durabfllty . 

Convenience 

Energy Elf. 

Operation 

o 

Dishwashers 

20 40 60 

Correlation with Satisfaction 

80 

80. 

• 

Quality 

Shelf Access 

Performance 

Capacity 

Appearance 

Energy Eff. 

Adjustability 

Quietness 

o 20 40 60 

Correia lion with Satisfaction 

Base: 6535 Top Mount aSide)( Side owners 

Dryers 

Drying Clothes 

Clothes Care 

Appearance 

Capacity 

. Balance 

EnergyEff. 

Durability 

Operation 

o 2Q 40 60 

Correlation with Satisfaction 

,Base: 2262 Dryer owners 

80 
Request

* Clothes Washers

- Continue the clothes washer rule where it left off

- Place maximum resources on the clothes washer rule

- Have a final rule at 3.0 energy factor that will become

effective no later than 1/1/2001

* Refrigerators

- Publish the final rule quickly

- Establish Tier 2 levels (16-23% more efficient than

current standard) that will become effective no later

than 1/1/2000

 EE-RM-94-403 COMMENT 50

Request 

II Clothes Washers 

- Continue the clothes washer rule where it left off 

- Place maximum resources on the clothes washer rule 

- Have a final rule at 3.0 'energy factor that will become 

effective no later than 1/1/2001 

II Refrigerators 

- Publish the final rule quickly 

- Establish Tier 2 levels (16-23% more efficient than 

current standard) that will become effective no later . 

than 1/1/2000 

, . 
Request (cont.)

It is our opinion that everyone in the

industry is capable of meeting

tough new standards.

* _'''..:..;:.::::' 

 EE-RM-94-403 COMMENT 50

Request (cant.) 

It is our opinion that everyone in the 

industry is· capable of meeting 

tough new standards. 
I+*Pfa~ rr~Department of Energy

Washington, DC 20585

October 15, 1996

DRAFT REPORTS ON THE DESIGN OPTIONS AND PRELIMINARY

ENGINEERING ANALYSIS FOR CLOTHES WASHERS,

AND NOTICE OF PUBLIC WORKSHOP

The Department of Energy has initiated an extensive standards rulemaking process improvement

effort which includes priority setting for various products. The Department has determined that

the clothes washers standards rulemaking be assigned a "High Priority." Therefore, the

Department is initiating the first phase of the new process which is to consider design options for

efficiency improvements. The procedures of the new process can be found in the July 15, 1996,

Federal Register notice which outlines the planning and prioritization process, data collection and

analysis, and decision making criteria.

The Department has recently drafted the following documents: "Draft Report on Design Options

for Clothes Washers," and "Draft Report on the Preliminary Engineering Analysis for Clothes

Washers." The design option report identifies product categories and narrows the range of design

options being considered for the development of technically feasible designs. The preliminary

engineering analysis is being provided because the Department had previously received extensive

data from the Association of Home Appliance Manufacturers and is providing it for informational

purposes. The engineering analysis, selection of candidate standard levels, and draft

consumer/forecasting (energy and water) analyses will be completed before the Department

publishes an Supplemental Advance Notice of Proposed Rulemaking (ANOPR) for clothes

washers planned for April 1997.

The Department seeks information from stakeholders and interested parties relative to the validity

of the design option report, and on how to conduct and complete the engineering analysis. These

reports are currently being peer reviewed by Oak Ridge National Laboratory, Author D. Little,

and an independent consultant.

A screening workshop for clothes washer standards will be held on November 15, 1996, at the

U.S. Department of Energy. 1000 independence Avenue, SW., Washington. DC. 20585-0121 in

room IE-245 from 9:00 a.m. to 4:00 p.m. The objective of the workshop will be to discuss the

enclosed reports, comments received, the peer review, and other relevant topics pertaining to the

standards. I have enclosed a preliminary draft agenda for the workshop.

Printed with soy ink on recycled paper

 EE-RM-94-403 COMMENT 50

Department of Energy 

Washington, DC 20585 

October 15,. 1996 

DRAFT REPORTS ON THE DESIGN OPTIONS AND PRELIMINARY 

ENGINEERING ANALYSIS FOR CLOTHES WASHERS. 

AND NOTICE OF PUBLIC WORKSHOP 

The Department of Energy has initiated an extensive standards rulemaking process improvement 

effort which includes priority setting for various products. The Department has determined that 

the clothes washers standards rulemaking be assigned a "High Priority." Therefore, the 

Department is initiating the first phase of the new process which is to consider design options for 

efficiency improvements. The procedures of the new process can be found in the July 15, 1996, 

Federal Register notice which outlines the planning and prioritization process, data collection and 

analysis, and decision making criteria. 

The Department has recently drafted the following documents: "Draft Report on Design Options 

for Clothes Washers," and "Draft Report on the Preliminary Engineering Analysis for Clothes 

Washers." The design option report identifies product categories and narrows the range of design 

options being considered for the development of technically feasible designs. The preliminary 

engineering analysis is being provided because the Department had previously received extensive 

data from the Association of Home Appliance Manufacturers and is providing it for informational 

purposes. The engineering analysis, selection of candidate standard levels. and draft 

consumer/forecasting(energy and water) analyses will be completed before the Department 

publishes an Supplemental Advance Notice of Proposed Rulemaking (ANOPR) for clothes 

washers planned for April 1997. 

The Department seeks information from stakeholders and interested parties relative to the validity 

of the design option report, and on how to conduct and complete the engineering analysis. These 

reports are currently being peer reviewed by Oak Ridge National Laboratory, Author D. Little, 

and an independent consultant. 

A screening workshop for clothes washer standards will be held on November 15, 1996, at the 

U:S. Department of Energy. 1000 Independence Avenue, S\\', Washington, DC. 20585-0121 in 

room lE-245 from 9:00 a.m. to 4:00 p.m. The objective of the workshop will be to discuss the 

enclosed reports, comments received, the peer review, and other relevant topics pertaining to the 

standards. I have enclosed a preliminary draft agenda for the workshop. 

* Printed with soy ink on recycled paper 
If you have any comments, please send them to: Ms. Sandy Beall, Office of Energy Effciency

and Renewable Energy, Mail Station EE-431, U.S. Department of Energy, 1000 Independence

Avenue, SW., Washington, DC. 20585-0121. Telephone: (202) 586-7574; FAX:

(202) 586-4617. In order to ensure full consideration, comments must be received by the

Department of Energy no later than November 8, 1996. If you have any questions or plan to

attend the workshop, please contact Marc LaFrance at (202) 586- 8423 or Bryan Berringer at

(202) 586-0371.

Sincerely,

Mi hael J. Mcabe, Di ctor

OfficEof Codes and Standards

Building Technology, State and

Community Programs

Energy Efficiency and Renewable Energy

Enclosures

 EE-RM-94-403 COMMENT 50

If you have any comments, please send them to: Ms. Sandy Beall, Office of Energy Efficiency 

and Renewable Energy, Mail Statton EE-431, U.S. Department of Energy, 1000 Independence 

Avenue, SW., Washington, DC. 20585-0121. Telephone: (202) 586-7574; FAX: 

(202) 586-4617. In order to ensure full consideration, comments must be received by the 

Department of Energy no later than November 8, 1996. If you have any questions or plan to 

attend the workshop, please contact Marc Lafrance at (202) 586- 8423 or Bryan Berringer at 

(202) 586-0371. 

Enclosures 

abe, Di ector 

Offic of Coaes and Standards 

Building Technology, State and 

Community Programs 

Energy Efficiency and Renewable Energy 
DEPARTMENT OF ENERGY

CLOTHES WASHER WORKSHOP

November 15, 1996

U.S. Department of Energy

1000 Independence Avenue, S.W.

Room 1E-245

Purpose of Workshop: To review and comment on the "Draft Report on Design Options

for Clothes Washers," and "Draft Report on the Preliminary

Engineering Analysis for Clothes Washers."

Outcomes of Workshop: Determination on how to conduct and complete the engineering

analysis. Based on this work and additional stakeholder input, the

Department plans to issue a Supplemental Advance Notice of

Proposed Rulemaking (ANOPR) for clothes washers in April 1997.

Preliminary Draft Agenda

Opening Remarks, Introductions, Agenda Review

Overview of Clothes Washer Rulemaking Schedule

Discussion on Design Options

Discussion on Preliminary Engineering Analysis

Discussion on How to Improve Future Workshops

Closing - Next Steps

 EE-RM-94-403 COMMENT 50

~ -, 

DEPARTMENT OF ENERGY 

CWTHES WASHER WORKSHOP 

November 15, 1996 

u.S. Department of Energy 

1000 Independence Avenue, S. W. 

Room lE-245 

Purpose of Workshop: . To review and comment on the "Draft Report on Design Options 

for Clothes Washers," and "Draft Report on the Preliminary 

Engineering Analysis for Clothes Washers." 

Outcomes of Workshop: Determination on how to conduct and complete the engineering 

analysis. Based on this work and additional stakeholder input, the 

Department plans to issue a Supplemental Advance Notice of 

Proposed Rulemaking (ANOPR) for clothes washers in April 1997. 

Preliminary Draft Agenda 

Opening Remarks, Introductions, Agenda Review 

Overview of Clothes Washer Rulemaking Schedule 

Discussion on Design Options 

Discussion on Preliminary Engineering Analysis 

Discussion on How to Improve Future Workshops 

Closing - Next Steps 

....... -

. f 
DRAFT REPORT ON DESIGN OPTIONS FOR CLOTHES WASHERS

October 1996

LAWRENCE BERKELEY NATIONAL LABORATORY

Energy & Environment Division

Technology and Market Assessment Group

Berkeley, CA 94720

Prepared for

U.S. DEPARTMENT OF ENERGY

Office of Codes and Standards

 EE-RM-94-403 COMMENT 50

DRAFT REPORT ON DESIGN OPTIONS FOR CLOTHES WASHERS 

October 1996 

LAWRENCE BERKELEY NATIONAL LABORATORY 

Energy & Environment Division 

Technology and Market Assessment Group 

Berkeley, CA 94720 

Prepared for 

u.s. DEPARTMENT OF ENERGY 

Office of Codes and Standards 
TABLE OF CONTENTS

DRAFT REPORT ON DESIGN OPTIONS FOR CLOTHES WASHERS

1. INTRODUCTION ............. 1

2. PRODUCT CLASSES ............. ........ . . . 1. 1

3. DESIGN OPTIONS ......... ..... .... ... 2

4. CONCLUSIONS ............................... . 15

LIST OF TABLES

Table 1 Current Product Classes & Efficiency Standards ........................ 2

Table 2 Proposed Product Classes ............ ........ .............. 2

Table 3 Design Options ........... ........... 3

Table 4 Design Options Eliminated from Further Analysis ..... ................. 15

Table 5 Remaining Design Options ................................ 15

1

 EE-RM-94-403 COMMENT 50

TABLE OF CONTENTS 

DRAFT REPORT ON DESIGN OPTIONS FOR CLOTHES WASHERS 

1. INTRODUCTION .. , .. '.' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1 

2. PRODUCT CLASSES ........................... : . . . . . . . . . . . . . . . . . . . 1 

3. DESIGN OPTIONS ......... , .. '.' ................................... 2 

4. CONCLUSIONS .................................................. 15 

LIST OF TABLES 

Table 1 Current Product Classes & Efficiency Standards ........................ 2 

Table 2 Proposed Product Classes .............. : ......................... 2 

Table 3 Design Options ................................................ 3 

Table 4 Design Options Eliminated from Further Analysis . . . . . . . . . . . . . . . . . . . . .. 15 

Table 5 Remaining Design Options . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 15 
Draft Report On Design Options for Clothes Washers

1. INTRODUCTION

This report discusses possible design options for improving the energy efficiency of standard

capacity, residential clothes washers.

The procedure used in this design option analysis is based on a Department of Energy (DOE)

interpretive ruling outlining process improvement measures [1]. After the different appliances subject

to possible regulation are ranked, potential design options are identified as the next step in the process

of promulgating appliance efficiency standards. Screening factors are then used to determine if any

design options should be eliminated from further consideration. Much of the input used for screening

design options was provided by clothes washer manufacturers. Other sources include trade

publications and the Association of Home Appliance Manufacturers (AHAM).

Although (under the new process) the design option stage of the analysis now precedes an

Advance Notice of Proposed Rulemaking (ANOPR), responses to the original ANOPR [2], data

previously collected from manufacturers, and existing input from AHAM and other stakeholders will

still be considered in this report. The DOE intends to issue a Supplemental Advance Notice of

Proposed Rulemaking in the future.

2. PRODUCT CLASSES

Appliance features that provide utility to the consumer are incorporated into the analysis

through the creation of product classes. Classes are a subset of appliance types. For example, clothes

washers are an appliance type, but a compact clothes washer is a product class. Appliance types are

segregated into separate classes to which different energy-efficiency standards apply. DOE

differentiates classes by capacity or other performance-related features that provide utility to the

consumer and affect efficiency. In general, classes are defined using data collected in discussions with

appliance manufacturers, trade associations, and other interested parties. Those classes for which no

DOE test procedure has been specified are omitted from further analysis.

Currently, clothes washers are separated into the product classes shown in Table 1. The

corresponding minimum efficiency requirements which became effective May 14, 1994 are also

provided [3].

1

 EE-RM-94-403 COMMENT 50

Draft Report On Design Options for Clothes Washers 

1. INTRODUCTION 

This report discusses possible design options for improving the energy efficiency of standard 

capacity, residential clothes washers. 

The procedure used in this design option analysis is based on a Department of Energy (DOE) 

interpretive ruling outlining process improvement measures [1]. After the different appliances subject 

to possible regulation are ranked, potential design options are identified as the next step in the process 

of promulgating appliance efficiency standards. Screening factors are then used to determine if any 

design options should be eliminated from further consideration. Much of the input used for screening 

design options was provided by clothes washer manufacturers. Other sources include trade 

publications and the Association of Home Appliance Manufacturers (AHAM). 

Although (under the new process) the design option stage of the analysis now precedes an 

Advance Notice of Proposed Rulemaking (ANOPR), responses to the original ANOPR [2], data 

previously collected from manufacturers, and existing input from AHAM and other stakeholders will 

still be considered in this report. The DOE intends to issue a Supplemental Advance Notice of 

Proposed Rulemaking in the future. 

2. PRODUCT CLASSES 

Appliance features that provide utility to the consumer are incorporated into the analysis 

through the creation of product classes. Classes are a subset of appliance types. For example, clothes 

washers are an applianc.e type, but a compact clothes washer is a product class. Appliance types are 

segregated into separate classes to which different· energy-efficiency standards apply. DOE 

differentiates classes by capacity or other performance-related features that provide utility to the 

consumer and affect efficiency. In general, classes are defined using data collected in discussions with 

appliance manufacturers, trade associations, and other interested parties. Those classes for which no 

DOE test procedure has been specified are omitted from further analysis. 

Currently, clothes washers are separated into the product classes shown in Table 1. The 

corresponding minimum efficiency requirements which became effective May 14, 1994 are also 

provided [3]. 

1 
Table 1. Current Product Classes & Efficiency Standards

Product Class Efficiency Standard

Compact top loading . EF 2 0.90 ft'/(kWh/cycle)

Standard top loading EF 21:18 ft'/(kWh/cycle)

Semi-automatic top loading Must have unheated rinse option

Front loading Must have unheated rinse option

Suds saving Must have unheated rinse option

In a previous rulemaking [4], the terms top loading and front loading were used to refer to

vertical and horizontal axis clothes washers, respectively. Since horizontal axis machines can be

manufactured in a top loading configuration, product class distinction-based on how clothes are

loaded-is no longer made. Instead, vertical and horizontal axis washers are considered as design

strategies that manufacturers can use to achieve different efficiency levels. For the present analysis,

the product classes in Table 2 were considered.

Table2. Proposed Product Classes

Product Class Definition

-Compact less than 1.6 ft' capacity

Standard 1.6 ft' or greater capacity

In this report, since data were not available for the compact class, only standard capacity

clothes washers will be discussed.

3. DESIGN OPTIONS

Design options are changes in clothes washer design that may have the potential to save.

energy.

The DOE issued an ANOPR on November 14, 1994, that proposed design options for

increasing clothes washer efficiency [5]. A questionnaire based on these design options was sent to

AHAM for distribution to its clothes washer manufacturer members. The questionnaire requested

data on the energy use and cost of design options. After the initial questionnaire was distributed,

workshops were held between stakeholders including AHAM, manufacturers, and DOE. These

interactions resulted in modifications and additions to the initial design option list.

Several of the original ANOPR design options were renamed to better define their technology.

Microprocessor controls & fuzzy logic was renamed advanced controls/sensor.

Configuration/tolerance of inner and outer tubs was changed to tighter tub tolerance. Higher spin

speed was redefined as improved water extraction and was separated into four different values for

2

i ' * * ' * * . * * '~~~~~~~~~~~~~~

 EE-RM-94-403 COMMENT 50

Table 1. Current Product Classes & Efficiency Standards 

Product Class 

Compact top loa~ing 

Standard top loading 

Semi-autom~tic top loading 

Front loading 

Suds saving 

Efficiency Standard 

EF ~ 0.90 ft'!(kWhlcycle) 

EF~ 1.18 ft'/(kWhlcycle) 

Must have unhel!-ted rinse option 

Must have unheated rinse option 

Must have unheated rinse option 

, In a previous ruleniaking [4], the terms top loading, and fron.t loading were used to refer to 

vertical and horizontal axis clothes washers, (espectively. , Since horizontal axis machines can be 

manufactured in a top loading corifiguration, product class distinction-based on how clothes are 

'. loaded-is BO longer made. Instead, vertical and horiZontal axis washers are considered as design 

strategies that manufacturers can use to achieve different efficiency levels. For the present analysis, 

the proquct Classes in Table 2 were considered. 

Table 2. Proposed\Product Classes 

Product Class 

Compact 

Standard 

Definition 

less than 1.6 ft· capacity 

. 1.6 ft' or greater capacity 

. In this report, since data were not avail~ble for the compact class, only staiidard capacity 

clothes washers will be discussed. 

3. DESIGN OPTIONS 

Design options are changes in clothes washer design that may have the potential to' save, 

energy. 

The DOE issued art ANOPR on'November 14, 1994, that proposed design options for 

increasing clothes washer efficiency [5]. A questionnaire based on these design 'options was sent to 

AHAM for distribution to ,its clothes washer manufacturer members. The questionnaire requested 

data on the, energy use and cost of design' options. After the initial questionnaire was distributed, 

workshops were held, between stakeholders including AHAM, manufacturers, and' DOE. These 

interactions resulted in modifications and additions to the initial design option list. ' 

Several of the original ANOPR design options were renanied to better define their technology. 

Microprocessor controls & fuzzy logic was renamed advanced controlS/sensor. 

,Configuration/tolerance of inner and outer tubs was changed to tighter tub tolerance. Higher spin 

speed was redefined as improved water extraction and ~as separated into four different values for 

.. 

! 2 
remaining moisture content (RMC); 50%, 40%, 35%, and 30%. The RMC design option is the same

in all four cases but it varies in the amount of final moisture content of the cloth. Different costs and

energy usages are required to achieve the different levels of RMC.

Several design options were split into two or more options. Improved fill control was

originally interpreted differently by individual manufacturers (with large differences in cost and energy

savings) and was therefore split into two options: improved fill control and automatic fill control.

The horizontal axis design option was separated into two design options: horizontal axis and

horizontal axis with recirculation.

Table 3 shows the final design options considered in this analysis.

Table 3. Design Options

Improved fill control

Tighter tub tolerance

Added insulation

Increased motor efficiency

Thermostatically controlled mixing valves (TCMV)

Improved water extraction

(remaining moisture content; RMC = 50%,40%,35%, 30%)

Horizontal axis design

Horizontal axis with recirculation

Advanced controls/sensor (soil load sensor)

Suds saving

Direct drive motor

Automatic fill control

Reduced thermal mass

Electrolytic disassociation of water

Ultrasonic washing

Bubble action

Ozonated laundering

Some of the design options in Table 3 are eliminated from further consideration (later in this

report) if one of the following criteria are not met [6]:

3

 EE-RM-94-403 COMMENT 50

remaining moisture content (RMC); 500/0, 40%, 35%, and 30%. The RMC design option is the same 

in all four cases but it varies in the amount of final moisture content of the cloth. Different costs and 

energy usages are required to achieve the different levels ofRMC. 

Several design options were split into two or more options. Improved fill control was 

originally interpreted differently by individual manufacturers (with large differences in cost and energy 

savings) and was therefore split into two options: improved fill control and automatic fill control. 

The horizontal axis design option was separated into two \design options: horizontal axis and 

horizontal axis with recirculation. 

Table 3 shows the final design options considered in this analysis. 

Table 3. Design Options 

Improved fill control 

Tighter tub tolerance 

Added insulation 

Increased motor efficiency 

Thermostatically controlled mixing valves (TCMV) 

Improved water extraction 

(remaining moisture content; RMC = 50%,40%,35%, 30%) 

. Horizontal axis design 

Horizontal axis with recirculation 

Advanced controls/sensor (soil load sensor) 

Suds saving 

Direct drive motor 

Automatic fill control 

Reduced thermal mass 

Electrolytic disassociation of water 

Ultrasonic washing 

Bubble action 

Ozonated laundering 

Some of the design options in Table 3 are eliminated from further consideration (later in this 

report) if one of the following criteria are not met [6]: 

3 
1) Technological Feasibility. Technologies incorporated in commercial products or in

working prototypes will be considered technologically feasible.

2) Practicability to Manufacture, Install and Service. If mass production of a technology in

commercial products and reliable installation and servicing of technology could be

achieved on the scale necessary to serve the relevant market at the time of the effective

date of the standard, then that technology will be considered practicable to manufacture,

install and service.

3) No adverse Impacts on Product Utility or Product Availability.

4) No adverse Impacts on Health or Safety.

The reasons for eliminating a design option shown in Table 3 (or keeping for further

consideration) are discussed in the individual descriptions of the design options outlined below. The

design options that are not recommended for elimination in this report will be analyzed further in a

later report. In this later report, the efficiency and cost of design options and combinations of design

options will be analyzed.

Included in the discussion of design options are limiting performance factors (if the same

factor was submitted by-two or more manufacturers). These limiting performance factors describe

parameters affected by a design option. Typically, these factors affect the utility of the clothes

washer. A limiting performance factor does not necessarily exclude a design option from further

analysis but describes performance factors that are affected by a design option and should be taken

into consideration.

Baseline Model

A clothes washer baseline model is used as a reference for evaluating the energy saving

potential and increased manufacturing costs of various design options. The potential for energy

savings is based on a proposed future DOE test procedure (Appendix JI) [7]. This test procedure

will take effect only when a new clothes washer standard is enacted.

The baseline represents the typical vertical axis washer with an energy efficiency just above

the minimum allowable, as specified by updates to the National Appliance Energy Conservation Act

(NAECA). Currently, all standard size washers must achieve the minimum allowed energy factor of

1.18 ftV/kWh, as rated according to the existing DOE test procedure. The baseline model will'be

assumed to have a plastic tub, non-thermally controlled mixing valves, an unheated rinse and the

capability to achieve a 62% remaining moisture content on the normal spin cycle.

4

 EE-RM-94-403 COMMENT 50

1) Technological Feasibility. Technolo~es incorporated in commerCial products or in 

working prototypes will be considered technologically feasible.' . 

2) Practicability to Manufactur~, Install and Service. If mass production of a technology in 

commercial products and reliable installation ,and servicing ~of technology could be 

achieved on the scale necessary to serve the relevant market at the time of the effective, 

'date of the standard, then that technology will be considered practicable to manufacture, 

install and service. ': 

3) No adverse Impacts on Product Utility or Product Availability. , ' 

4) No adverse Impacts on Health ~r Safety: 

The reasons for eliminating a design option shown in Table 3{ or keeping fot furthe~ 

consideration)are discussed in the individual descriptions of the design options outlined below. The 

design ()ptions that are. not recommended for elimination in this report will be analyzed further'in a 

later report. In this later report, the efficiency and cQst of design options and combinations of design 

options will be analyzed. 

Included in the discussion, of design options are ,limiting perfoimance factors' (if the same 

factor was submitted by two ~r more manufacturers). These'limiting performance factors describe 

parameters affected by a design option. Typically, these factors affect the utility ·of the clothes 

washer. A limiting performance factor does 'not necessarily exclude a design option from further 

analysis but describes performance factors that are affected by a design option and should be taken 

,into consideration. 

Baseline Model 

. A clothes ~ashei baseline model is ~sed as a reference for'evaluating the energy saving 

potential and increased manufacturing costs of various design options. The potential for energy 

. ,s,avings is based on a proposed future DOE test procedure (Appendix 11) [7]. This test procedure 

will take effect only when a new clothes washer. standard is enacted. 

, The baseline represents the typical vertical axis 'washer with an' energy efficiency just above 

the nlinimum allowable, as specified by updates to the National Appliance Energy .Conservation Act 

(NAECA). Currently, all'standard size washers must achieve, the minimum allowed energy factor of 

1.18 fiHkWh, as rated according to the existing DOE test procedure. The baseline model will 'be 

assumed to.have a plastic tub, non-thermally controlled miXingvalves,an unheated rinse and the ' 

capability to achieve a 62% remaining moisture content on the normal spin cycle. " 

4 
Improved fill control

This design option is defined as improving the tolerance on existing wash water fill sensing.

This can be accomplished by reducing tolerances of presently used pressure sensors or improving

switch design. This design option relates primarily to vertical axis design washers, although it is

sometimes applicable to horizontal axis washers depending on the specific fill control design. In a

typical vertical axis washer, one end of an air hose is connected near the bottom of the washer tub

and the other end is connected to a pressure switch. As water fills the tub, air in the hose is forced

into a smaller volume, thereby increasing the air pressure. The air pressure increases until it activates

a pressure switch, which in turn shuts off the water inlet valve. A more accurate water level setting

system would avoid overfilling the wash tub, thereby reducing the amount of water and energy used.

Limiting performance factors mentioned by manufacturers include: 1) soil removal, 2) gentleness of

action, and 3) wear.

One manufacturer said it was not aware of any opportunity to reduce tolerances of presently

used pressure sensors. But because several manufacturers provided cost and efficiency data for

improving the fill control, it was analyzed as a method to improve clothes washer efficiency.

Tighter tub tolerance

This design option reduces the space (the annulus) between the inner wash basket and the

outer tub. This annulus fills with water, but does not add to the clothes washer capacity. Having less

space between the inner wash basket and the outer tub reduces the amount of water required for a

fill, thereby saving the energy required to heat it. This option applies primarily to vertical axis

washers. In a horizontal axis washer, water only occupies the lower portion of the annulus. Since

most of the annulus in a horizontal axis washer is filled with air, a smaller annulus does not yield

significant energy savings.

Other considerations are also important in determining an appropriate clearance between

basket and tub. Manufacturers state that if the annulus is too small there may be problems with "suds

lock", where suds from the wash water remain between the inner wash basket and outer tub.

Clearance is also needed to drain water during the spin dry cycle. Also, enough space must be

retained to allow for deflection of baskets with out-of-balance loads. Increasing the spin speed of the

washer basket during the spin dry cycle may also require a larger space between tub and basket to

allow for greater deflection at higher spin speeds. For this reason, tighter tub tolerance was not

combined with the improved water extraction design options. Other limiting performance factors

mentioned by manufacturers include: 1) noise, 2) vibration, and 3) sand removal.

One manufacturer stated that the space between inner and outer tubs is already at the

minimum. However, tub tolerances vary among manufacturers. Therefore, manufacturer supplied

cost and efficiency data were used to estimate the benefit of tightening the tub tolerance.

5

 EE-RM-94-403 COMMENT 50

Improved fill control 

This design option is defined as improving the tolerance on existjng wash water fill sensing. 

This can be accomplished by reducing tolerances of presently used pressure sensors or improving 

switch design. This design option relates primarily to vertical axis design washers, although it is 

sometimes applicable to horizontal axis washers depending on the specific fill control design. In a 

typical vertical axis washer, one end of an air hose is connected near the bottom of the washer tub 

and the other end is connected to a pressure switch. As water fills the tub, air in the hose is forced 

into a smaller volume, thereby increasing the air pressure. The air pressure increases until it activates 

a pressure switch, which in tum shuts off the water inlet valve. A more accurate water level setting 

system would avoid overfilling the washtub, thereby reducing the amount of water and energy used. 

Limiting performance factors mentioned by manufacturers include: 1) soil removal, 2) gentleness of 

action, and 3) wear. 

One manufacturer said it was not aware of any opportunity to reduce tolerances of presently 

used pressure sensors. But because several maimfacturers provided cost and efficiency' data for 

improving the fill control, it was analyzed as a method to improve clothes washer efficiency. 

Tighter tub tolerance 

This design option reduces the space (the annulus) between the inner wash basket and the 

outer tub. This annulus fills with water, but does not add to the clothes washer capacity .. Having less 

space between the inner wash basket and the outer tub reduces the amount of water required for a 

fill, thereby saving the energy required to heat it. This option applies primarily to vertical axis 

washers. In a horizontal axis washer, water only occupies the lower portion of the annulus. Since 

most of the annulus in a horizontal axis washer is filled with air, a smaller annulus does not yield 

significant energy savings. 

Other considerations are also important in determining an appropriate clearance between 

basket and tub. Manufacturers state that if the annulus is too small there may be problems with "suds 

. lock", where suds from the wash water remain between the inner wash basket and outer tub. 

Clearance is also needed to drain water during the spin dry cycle. Also, enough space must be 

retained to allow for deflection of baskets with out,.of-balance loads. Increasing the spin speed of the 

washer basket during the spin dry cycle may also require a larger space between tub and basket to 

allow for greater deflection at higher spin speeds. For this reason, tighter tub tolerance was not 

combined with the improved water extraction design options. Other limiting performance factors 

mentioned by manufacturers include: 1) noise, 2) vibration, and 3) sand removaL 

One manufacturer stated that the space between inner and outer tubs is already at the 

minimum. However, tub tolerances vary among manufacturers. Therefore, manufacturer supplied 

cost and efficiency data were used to estimate the benefit of tightening the tub tolerance. 

5 
Added insulation

This design option adds insulation around the outer wash tub. Because some heat energy is

lost through the shell of the clothes washer, adding insulation around the outer tub slightly reduces

the water temperature needed for a hot wash. However, since the wash cycle is short, the thermal

mass of the water is very high, and the temperature of the tub is relatively low there is very little

change in water temperature from adding insulation. Computer simulations performed for a 20-

minute wash cycle at 140°F showed that adding one inch of fiberglass insulation relative to no

insulation resulted in only a 1 - 2°F increase in water temperature during parts of the wash [8].

Some manufacturers stated that this design option would produce little savings and should

be eliminated. Since several manufacturers supplied cost and efficiency data for this design option,

it was analyzed as a method to improve clothes washer efficiency.

Increased motor efficiency

About 10% of the total electrical energy consumed by a typical clothes washer is used by the

electric motor. The typical washing machine has a y2-% horsepower motor. One manufacturer states

that replacing a split-phase motor with a capacitor start motor may increase the efficiency of the'

motor by 1P% [9]. Limiting performance factors mentioned by manufacturers include: 1) physical

size and 2) servicing/installation.

Manufacturers supplied data for this option but suggested that since the motor energy is a

small part of the total energy, even.a 10% reduction in motor energy would result in only a 1%

reduction in overall energy consumption. Although only small energy savings would be realized by

improving the motor efficiency, it was still considered as a method to improve clothes washer

efficiency.

Thermostatically controlled nixing valves (TCMVs)l

This design option achieves energy savings by more accurately controlling inlet water

temperature for hot or warm fills. In a typical non-thermostatically controlled water inlet system, two

solenoid valves are used; one valve controls hot water fills while the other controls cold water fills.

Both solenoid valves are opened if a warm water setting is selected. In the warm wash mode, a fixed

fraction of hot and cold water are controlled' by flow control devices. For example, a manufacturer

may decide to let warm water be 50% hot and 50% cold. To reduce hot water energy use, some

manufacturers have reduced the warm water temperature by using other ratios such as 40% hot and

60% cold.

A thermostatically controlled mixing valve (TCMV) refers to a set of clothes washer valves

which sense water temperature and adjust the supply of hot and cold water to maintain a desired

1Also referred to as "Thermostatically Controlled Water Valves".

6

 EE-RM-94-403 COMMENT 50

Added insulation 

. . . 

This design option adds insulation around the outer wash tub. Because some heat energy is 

lost through the shell of the clothes'washer, adding insulation around the outer tub slightly reduces 

. the water temperature needed for a hot wash. However, since the wash cycle is short, the thermal 

mass of the water is very high, and the temperature of the tub is relatively low there is very little 

change in water temperature from adding insulation. Computer simulations performed for a 20-

minute wash cycle at 140°F showed that adding one inch of fib~rglass insulation relative.to no 

insulation resulted in only a 1. - 2 OF increase in water temperature during parts of the w,ash [8]. I 

. , 

, Some manufacturers stated that this design option would produce little savings and should 

be' eliminated. Sinces~veral manufacturers supplied' cost and efficiency data for this design option, 

it was analyzed as a method to improve clothes washer efficiency. . 

.' Increased moto~ efficiency , 

About 10% of the total electrical energy consumed by a typical clothes washer is used by th~ 

electric motor. The typical washing machine has a %-2fs horsepower motor. One manufacturer states i 

that .replacing a split-phase motor with a capacitor start motor may increase the effic~ency of the ( 

motor by 1,0% [9]. Limiting performance factors mentioned by manufacturers include: 1) physical 

size and 2) servicinglinstallation. 

Manufacturers supplied data for this option but suggested that since the motor energy is a 

small part of the total energy, even.a 10% reduction in motor en~rgywould result in only a 1% 

reduction in overall energy consumption. Although only small energy savings would be realized by , 

improving the motor efficiency, it was still considered as a method to improve clothes washer 

efficiency. 

, Th~rm~statically controlled mixing valves rrCMVs)l . ' 

Thisde~ign option achieves ~nergy savings. by more accurately controlling' inlet wa~er temperature for hot or warm fills. In a typical non-thermostatically controlled water inlet system, two' 

solenoid valves are used; one valve controls hot water fills while the other controls cold water fills. 

Both solenoid valves are opened if a warm water setting is selected. In thewarm wash mode, afixed 

fraction of hot and cold water are controlled by flow control devices. For example, a manufacturer 

may decide to let warm water be 50% hot and 50% cold. To reduce hot water energy use, some 

manufacturers have reduced the warm waterteinperature by using other ratios such as 40% hot and 

60% cold. ' 

A thermostatically controlled miXiIig valve (TCMV) refers to a set of clothes wa~her valves 

which sense water temperature and adjust the supply of hot and cold water to maintain a desired , -

1 AlS? referred to as "Thennostatically. Controlled Water Valves;'. 

6 
warm water temperature [10]. In the June 1996 comments to the DOE test procedure, AHAM

commented that it is not necessary to define thermostatically controlled water valves but to define

clothes washers with thermostatically controlled water valves. It is likely that DOE will revise the

aforementioned definition to that recommended by AHAM: "Clothes washers with thermostatically

controlled water valves refer to clothes washers which sense water temperature and adjust the hot

water and cold water supplies appropriately to maintain a mixed water temperature" [11].

Energy can be saved with a TCMV by either reducing the hot water temperature or reducing

the warm water temperature. For example, the TCMV could be used to lower the hot wash

temperature from 135°F to 130°F by mixing hot water (at 135°F test inlet conditions) with cold

water. Warm water temperature could be similarly reduced. The energy savings can vary widely

depending on the test standard's specified inlet hot water temperature and the selected temperature

of the tempered water.

A TCMV design option has the potential to overstate the actual in-home energy savings when

tested under laboratory conditions. The magnitude of the discrepancy depends on the proximity of

the water heater to the clothes washer. When tested under laboratory conditions, the clothes washer

is next to the hot water source, whereas this is generally not the case in the home. As a result of the

distance between the hot water source and the clothes washer, there is a temperature drop due to line

losses. As a result of the line losses, a clothes washer with a TCMV may use more hot water than

predicted under the laboratory testing. Similarly, in a real world application savings will also vary

with the temperature of incoming cold water (i.e. ground water). The unheated water temperature

will vary with both geographic location and time of year. More energy would likely be saved in cases

of warmer inlet water as a TCMV would then reduce the amount of time a hot water valve is open.

The amount of savings is also dependent on the set point of the TCMV, the water heater set point,

the temperature selection of the wash (hot or warm cycle), and the location of the sensing thermostat

controlling the inlet water valves. A limiting performance factor mentioned by more than one

manufacturer was soil removal.

Because TCMV's are commercially available on high end machines they were considered as

a way to increase clothes washer efficiency. Manufacturers supplied cost and efficiency data for this

design option.

Improved water extraction

There are several ways to reduce the remaining moisture content (RMC) in the laundry load

after the final spin cycle. One method is to increase the spin speed of the wash basket for the final

spin cycle. Other ways include: 1) changing the direction of rotation to more evenly distribute

clothes, 2) having a longer spin cycle, and 3) increasing the size or number of drainage holes in the

washer drum. Since mechanical drying is more efficient than using heat to dry, energy consumption

for the combined wash and dry process is reduced.

7

 EE-RM-94-403 COMMENT 50

warm water temperature [10]. In the June 1996 comments to the DOE test procedure, AHAM 

commented that it is not necessary to define thermostatically controlled water valves but to define 

clothes washers with thermostatically controlled water valves. It is likely that DOE will revise the 

aforementioned definition to that recommended by AHAM: "Clothes washers with thermostatically 

controlled water valves refer to clothes washers which sense .water temperature and adjust the hot 

water and cold water supplies appropriately to maintain a mixed water temperature" [11]. 

Energy can be saved with a TCMV by either reducing the hot water temperature or reducing 

the warm water temperature. For example, the TCMV could be used to lower the hot wash 

temperature from 135°F to 130°F by mixing hot water (at 135°F test inlet conditions) with cold 

water. Warm water temperature could be similarly reduced. The energy savings can vary widely 

depending on the test standard~s specified inlet hot water temperature and the selected temperature 

of the tempered water. 

A TCMV design option has the potential to overstate the actual in-home energy savings when 

tested under laboratory conditions. The magnitude of the discrepancy depends on the proximity of 

the water heater to the clothes washer. When tested under laboratory conditions, the clothes washer 

. is next to the hot water source, whereas this is generally not the case in the home. As a result of the 

distance between the hot water source and the clothes washer, there is a temperature drop due to line 

losses. As a result of the line losses, a clothes washer with a TCMV may use more hot water than 

predicted under the laboratory testing. Similarly, in a real world application savings will also vary 

with the temperature ofincomirtg cold water (i.e. ground water). The unheated water temperature 

will vary with both geographic location and time of year. More energy would likely be saved in cases 

of warmer inlet water as a TCMV would then reduce the amount of time a hot water valve is open. 

The amount of savings is also depen~ent on the set point of the TCMV, the water heater set point, 

the temperature selection of the wash (hot or warm cycle), and the location of the sensing thermostat 

controlling the inlet water valves. A limiting performance factor mentioned by more than one 

manufacturer was soil removal. 

Because TCMV's are commercially available on high end machines they were considered as 

a way to increase clothes washer efficiency. Manufacturers supplied cost and efficiency data for this 

design option. 

Improved water extraction 

There are several ways to reduce the remaining moisture content (RMC) in the laundry load 

after the final spin cycle. One method is to increase the spin speed of the wash basket for the final 

spin cycle. Other ways include: 1) changing the direction of rotation to more evenly distribute 

clothes, 2) having a longer spin cycle, and 3) increasing the size or number of drainage holes in the 

washer drum. Since mechanical drying is more efficient than using heat to dry, energy consumption 

for the combined wash and dry process is reduced. 

7 
Limiting performance factors mentioned by manufacturers include: 1) greater wrinkling of

clothes, 2) noise and, 3) vibration. Manufacturers state that the washing machine structure would

have to be redesigned to handle greater dynamic loads, stresses, deflections, and increased braking.

In addition, different spin cycle options would have to be available on a washer to account for the

load type. Different fabrics require different maximum spin speeds to avoid clothes damage. 'The

probable, future test procedure (Appendix J1) will most likely assume that the improved water

extraction feature will not be used for 25% of the time that the clothes washer is in use (based on

AHAM response to the test procedure Supplemental ANOPR) [12]. Since this feature can be

consumer selectable, clothes subject to wrinkling can be washed with a conventional spin cycle option

to avoid a wrinkling problem. Some manufacturers were doubtful that RMCs of35% and 30% could

be practically obtained.

In laboratory testing, RMCs on commercially available horizontal axis washers ranged from

49% to 36% with a 50/50 cotton/polyester cloth load. For the same test load, a vertical axis machine

had a 52% RMC. The washers for the above testing were loaded at 3 pounds per cubic foot of

basket capacity [13]. The future DOE test procedure (Appendix J1), generally based on AHAM

recommendations, specifies the test load as being closer to 4 pounds per cubic foot of basket capacity

[14]. Since the amount of cloth test load has an effect on the RMC achieved, it is unknown whether

the above laboratory tested machines can achieve their stated RMC values under future DOE test

conditions.

Some manufacturers already have models which can achieve 40% RMC levels. For example,

General Electric applied for a test procedure waiver for a vertical axis washing machine that can

achieve RMC levels of less than 40% [15]. Several European horizontal axis models are able to

achieve 40% RMC including: Asko model 20005; Creda model CWA242; and Miele models W1903,

W1918, and W1930 [16].

There do not appear to be any commercially available or known prototype clothes washer that

achieves RMCs of 35% or 30% and, therefore, these two RMC levels will be eliminated from any

further analysis. RMC levels of 50% and 40% are analyzed with manufacturer supplied cost and

efficiency data.

Horizontal axis design

Horizontal axis machines rotate the drum (wash basket) and clothes about a horizontal axis.

With this design, the drum does not have to be filled with water to cover the top of the clothes.

Therefore, horizontal axis machines use much less water than conventional vertical axis machines.

In some designs the washer is first filled to a specified level. As clothes absorb the water, a water

level sensor allows more water to enter to maintain the specified level. In this way the water level

is matched to the laundry load. Washing performance appears to be equal to that of vertical axis

machines. In laboratory testing, horizontal axis machines used on average 40% less energy and 25%

less water when normalized to clothes container volume. The horizontal axis machines also had a

greater soil removal effectiveness [17].

8

 EE-RM-94-403 COMMENT 50

Limiting performance factors mentioned by manufacturers include: 1) greater wrinkling of 

clothes, 2) noise and, 3) vibration. Manufacturers state that the washing machine structure would 

have to be redesigned to handle greater dynamic loads, stresses, deflections, and increased braking. 

In addition, different spin cycle options would have to be available on a washer to account for the 

load type. Different fabrics require different maximum spin speeds to avoid clothes damage .. The 

probable, future test procedure (Appendix 11) will most likely assume that the improved water 

extraction feature will not be used for 25% of the time that the clothes washer is in use (based on 

AllAM response to the test procedure Supplemental ANOPR) [12]. Since this feature can be 

consumer selectable, clothes subject to wrinkling can be washed with a conventional spin cycle option 

to avoid a wrinkling problem. Some manufacturers were doubtful that RMCs of35% and 30% could 

be practically obtained. 

In laboratory testing, RMCs on cOIllIilercially available horizontal axis washers ranged from 

49% to 36% with a 50/50 cotton/polyester cloth load. For the same test load, a vertical axis machine 

had a 52% RMC. The washers for the above testing were loaded at 3 pounds per cubic foot of 

basket capacity [13]. The future DOE test procedure (Appendix 11), generally based on AHAM 

recommendations, specifies the test load as being closer to 4 pounds per cubic foot of basket capacity 

[14]. Since the amount of cloth test load has an effect on the RMC achieved, it is unknown whether 

the above laboratory tested machines can achi'eve their stated RMC values under future DOE test 

conditions. 

Some manufacturers already have models which can achieve 40% RMC levels. For example, 

General Electric' applied for a test procedure waiver for a vertical axis washing machine that can 

achieve RMC levels of less than 40% [15]. Several European horizontal axis models are able to 

achieve 40% RMC including: Asko model 20005; Creda model CW A242; and Miele models W1903, 

W1918, and W1930 [16]. 

There do not appear to be any commercially available or known prototype clothes washer that 

achieves RMCs of 35% or 30% and, therefore, these two RMC levels will be eliminated from any 

further analysis. RMC levels of 50% and 40% are analyzed with manufacturer supplied cost and 

efficiency data. 

Horizontal axis design 

Horizontal axis machines rotate the drum (wash basket) and clothes about a horizontal axis. 

With this design, the drum does not have to be filled with water to cover the top ofthe.clothes. 

Therefore, horizontal axis machines use much less water than conventional vertical axis machines. 

In some designs the washer is first filled to a specified level. As clothes absorb the water, a water 

level sensor allows more water to enter to maintain the specified level. In this way the water level 

is matched to the laundry load. Washing performance appears to be equal to that of vertical axis 

machines. In laboratory testing, horizontal axis machines used on average 40% less energy and 25% 

less water when normalized to clothes container volume. The horizontal axis machines also had a 

greater soil removal effectiveness [17]. 

8 
In a previous analysis, it was estimated that less detergent would be needed based on some

detergent manufacturers' recommendations [18]. New information now suggests that if a low

sudsing detergent is sold in the U.S., detergent use would remain unchanged [19][20].

In the May 8, 1995 data submittal by AHAM [21], one manufacturer commented that there

will be many consumer utility issues impacted by the use of a horizontal axis design including:

* Clothes washer water bath will still not be at household water heater settings:

A greater portion of the fill water will be affected by thermal losses (since less hot water is

used) due to 1) household supply piping, 2) washing machine structure, and 3) clothes load.

e There will be an increased cycle time to complete the washing process:

This manufacturer states that there is the need to tumble clothes longer as there is less

mechanical action in tumbling than agitation. Multiple rinses will be required to remove

higher detergent concentration versus rinses in horizontal axis washers. More time is required

to heat water if an internal heater is utilized.

* Loading/unloading accessibility is impaired:

There is a need to stoop to load front loader style horizontal axis washers. A small opening

(to load clothes) is required to avoid water.leaks. The door is locked to avoid water spillage

and therefore garments cannot be added after the cycle has been initiated without draining

water. Top-loading horizontal style horizontal axis washers have an "unfriendly" springloaded trap door. In addition, excessive reach is required to retrieve garments at bottom of

cylinder on top loading style horizontal axis machine.

* Rewiring of electrical system may be required:

A financial impact to consumers may result from having to rewire the electrical system of the

home to 240V in the washer area if an internal heater is utilized.

* A new low-sudsing formulated detergent would be required:

Leading detergent manufacturers are still developing detergents for horizontal axis machines.

As compared to horizontal axis designs, the detergent cost per load will increase. The dosage

is the same or slightly less than horizontal axis designs, not one third of vertical axis designs

as claimed by advocates of horizontal axis designs.

Limiting performance factors mentioned by more than one manufacturer include: 1) soil

removal, 2) consumer interface (ergonomics), 3) tangling, 4) cycle time, 5) rinsing and 6) suds

sensitivity.

Horizontal axis machines are currently commercially available in the United States, and

although manufacturers have several concerns over this design, it is analyzed as a method to improve

clothes washer efficiency.

9

 EE-RM-94-403 COMMENT 50

Ina previous analysis, it was estimated that less de:tergent would be needed based on some 

detergent manufacturers' recommendations [18]. New information now suggests that if a low 

sudsing detergent is sold in the U.S., detergent use would remain unchanged [19][20]. 

In the May 8, 1995 data submittal by AHAM [21], one manufacturer commented that there 

will be many consumer utility issues impacted by the use of a horizontal axis design including: 

• 

• 

• 

• 

• 

Clothes washer water bath will' still not be at household water heater settings: 

A greater portion of the fill water will be affected by thermal losses (since less hot water is 

used) due to 1) household supply p~ping? 2) washing machine structure, and 3) clothes load. 

There will be an increased cycle time to complete the washing process: 

This manufacturer states that there is the need to tumble clothes longer as there is less 

mechanical action in tumbling than agitation. Mu.ltiple rinses will be required to remove 

higher detergent concentration versus rinses in horizorital axis washers. More time is required 

to heat water if an internal heater is utilized. 

Loading/unloading accessibility is impaired: 

There is a need to stoop to load front loader style horizontal axis washers. A small opening 

(to load clothes) is required to avoid water·leaks. The door is locked to avoid water spillage 

and therefore garments cannot be added after the c:ycle has been initiated without draining 

water. Top-loading horizontal style horizontal axis washers have an "unfriendly" springloaded trap door. In addition, excessive reach is required to retrieve garments at bottom of 

cylinder on top loading style horizontal axis machine. 

Rewiring of electrical system may be required:. . 

A financial impact to consumers may result from having to rewire'the electrical system of the 

home to 240V in the washer area if an internal heater is utilized. 

A new low-sudsing formulated detergent would be required: 

Leading detergent manufacturers are still developing detergents for horizontal axis machines. 

As compared to horizontal axis designs; the detergent cost per load will increase. The dosage 

is the same or slightly less than horizontal axis designs, not one third of vertical axis designs 

as claimed by advocates of horizontal axis designs. 

Limiting performance factors mentioned by more than one manufacturer include: 1) soil 

removal, 2) consumer interface (ergonomics), 3) tangling, 4) cycle time, 5) rinsing and 6) suds 

sensitivity. 

Horizontal axis machines are currently, commercially available in the United States, and 

although manufacturers have several concerns over this design, it is analyzed as a method to improve 

clothes washer efficiency. 

9 
Horizontal axis with recirculation

This design option is a variation on the horizontal axis design option. It differs in that this

design uses a pump to circulate water from a sump underneath the rotating drum through a spray

nozzle into the interior of the rotating drum. The small amount of water in the bottom of the drum

of a standard horizontal axis washer is not required. Less hot water is needed per wash cycle, thereby

saving energy.

In the May 8, 1995 data submittal by AHAM, one company commented that they have not

been able to verify that a savings exists with recirculation. Limiting factors mentioned by more than

one manufacturer include: 1) soil removal, 2) tangling, 3) cycle time, 4) rinsing, and 5) suds

sensitivity.

Manufacturers submitted data on cost and energy use for this design option. Electrolux

models EW 1550, EW1450, and EW 1250 use direct spray (eight liters per minute of water/detergent

solution is sprayed into the drum by means of a supply valve above the porthole) [22].

Advanced controls/sensor (soil load sensor)

According to the future DOE test procedure (Appendix J1), "an adaptive control system

refers to a clothes washer control system which is capable of automatically adjusting washer operation

or washing conditions based on characteristics of the clothes load placed in the clothes container,

without allowing or requiring consumer intervention and/or actions." This design option would use

sensors to measure the soil load to adjust the wash temperature, agitation and/or tumble cycle time,

number of rinse cycles, spin speed, and other parameters. Water and energy use can then be tailored

to the load, thereby avoiding washing the clothes more than necessary. The future DOE test

procedure (Appendix J1) would account for energy savings due to this design option, and in some

cases would allow for specific field test procedures to measure energy consumption [23].

The Electrolux Intuition and Zanussi Dialog washing machines use fuzzy logic to weigh

laundry loads and regulate the length of the cycle, water level, number of rinses, and drying time

[24].AEG unveiled the Oko-Lavamat 6953 in mid-1993. This washing machine incorporates fuzzy

logic to optimize the washing process while conserving water usage. The fuzzy logic control

determines the absorbency of the items being washed at the earliest stage possible after the start of

the washing cycle. The system determines the correct water quantity for clear-water washing and the

subsequent rinsing (the phase of washing that uses a majority of the water) [25]. Manufacturers

submitted cost and energy data for this design option, therefore, this option will be included in further

analysis.

Suds saving

A suds saving feature allows water from one wash cycle to be reused in the next wash cycle.

After agitation, sudsy wash water is pumped into a separate storage tub, remaining there until the

10

 EE-RM-94-403 COMMENT 50

Horizontal axis with recirculation 

This design option is a variation on the horizon~al axis design option, It differs in that this 

design uses a pump to circulate water from a sump underneath the rotating drum through a spray 

nozzle into the interior of the rotating drum. The small amount of water in the bottom of the drum 

of a standard horizontal axis washer is not required. Less hot water is needed per wash cycle, thereby 

saving energy. 

In the May 8, 1995 data submittal by AHAM, one company commented that they have not 

been able to verify that a savings exists with recirculation. Limiting factors mentioned by more than 

one manufacturer include: 1) soil removal, 2) tangling, 3) cycle time, 4) rinsing, and 5) suds 

sensitivity. 

Manufacturers submitted data on cost and energy use for this design option. Electrolux 

models EW 1550, EW1450, and EW 1250 use direct spray (eight liters per minute ofwater/detergent 

solution is sprayed into the drum by means ofa supply valve above the porthole) [22]. 

Advanced controls/sensor (soil load sensor) 

According to the future DOE test procedure (Appendix 11), "an adaptive control system 

refers to a clothes washer control system which is capable of automatically adjusting washer operation 

or washing conditions based on characteristics of the clothes load placed in the clothes container, 

without allowing or requiring consumer intervention and/or actions." This design option would use 

sensors to measure the soil load to adjust the wash temperature, agitation and/or tumble cycle time, 

number of rinse cycles, spin speed, and other parameters. \Vater and energy use can then be tailored 

to the load, thereby avoiding washing the clothes more than necessary. The future DOE test 

procedure (Appendix 11) would account for energy savings due to this design option, and in some 

cases would allow for specific field test procedures to measure energy consumption [23]. 

The Electrolux Intuition and Zanussi Dialog washing machines use fuzzy logic to weigh 

laundry loads and regulate the length of the cycle, water level, number of rinses, and drying time 

[24].AEG unveiled the Oko-Lavamat 6953 in mid-1993. This washing machine incorporates fuzzy 

logic to optimize the washing process while conserving water usage. The fuzzy logic control 

determines the absorbency of the items being washed at the earliest stage possible after the start of 

the washing cycle. The system determines the correct water quantity for clear-water washing and the 

subsequent rinsing (the phase of washing that uses a majority of the water) [25]. Manufacturers 

submitted cost and energy data for this design option, therefore, this option will be'included in further 

analysis. 

Suds saving 

A suds saving feature allows water from one wash cycle to be reused in the next wash cycle. 

After agitation, sudsy wash water is pumped into a separate storage tub, remaining there until the 

10 

t. 
next wash cycle. While the water is stored, soil settles to the bottom of the tub. During the next

wash cycle, all but an inch of the water is pumped back into the washer tub for use again [26].

Manufacturers have commented that this option saves water but not energy. They also believe that

there is low consumer demand for this option and would, therefore, not be used often. In addition,

this option cannot be used for all loads or soil conditions. This option is useful only when there is

more than one wash cycle per load of laundry, e.g., a pre-wash (which is not typically the case), or

if the consumer washed more than one wash load at a time. Subsequent washes could receive

diminishing benefits, since the water in the holding tub would cool if left standing too long. A limiting

performance factor mentioned by more than one manufacturer for this design option was soil removal.

This design option is currently commercially available. An example is AB Electrolux's

Recycle 40. It uses water from the final rinse of one load to use again as the prewash of the next

cycle [27]. Maytag features this option as a water saving option on one of its washers.

The future (Appendix J1) DOE test procedure will no longer provide an energy saving benefit

for this design option. The two interested parties that commented on this provision during the

comment period for the test procedures, were not in favor of retaining credit for this design option

[28][29]. In addition, because this option requires an external wash tub, consumer utility is affected.

This option is eliminated from further consideration for the above stated reasons.

Direct drive motor

This design option is primarily intended for use in vertical axis machines. A conventional

vertical axis clothes washer uses an induction motor, a mechanical transmission, and sometimes a

pulley belt. A direct drive motor can replace a conventional motor/transmission system. Rather than

using a belt and/or transmission, a motor could be directly connected to the agitator, thereby avoiding

transmission (gearbox) losses. Eaton, a motor manufacturer, claims that this will result in less

mechanical energy required, i.e., less energy needed to run the agitator motor. This is accomplished

by using a Brushless DC (BLDC) motor with electronic controls. Cleanability was not measured by

Eaton. In addition, other parameters such as cycle time or spin speed were not kept constant in a

comparison test with a conventional washer. For the machines tested, Eaton found savings of about

140 W-hr per cycle or 64% of motor energy use. When adjusted for the direct drive standby power,

this difference drops to about 35 W-hr per cycle or 16%. The direct drive standby power is the

energy consumption when the machine is "off'. In the "off" mode, the direct drive motor system has

a power drain of 4.78 watts. The current DOE test procedure does not account for standby power

use. Energy savings could be improved if the standby power loss was decreased [30].

One company submitted a comment that energy losses in the drive system are a very small

percent of total energy use. Therefore, savings from a direct drive motor would be minimal. A

limiting performance factor mentioned by more than one manufacturer for this design option was

physical size.

11

 EE-RM-94-403 COMMENT 50

• 

next wash cycle. While the water is stored, soil settles to the bottom of the tub. During the next 

wash cycle, all but an inch of the water is pumped back into the washer tub for use again [26]. 

Manufacturers have commented that this option saves water but not energy. They also believe that 

there is low consumer demand for this option and would, therefore, not be used often. In addition, 

this option cannot be used for all loads or soil conditions. This option is useful only when there is 

more than one wash cycle per load oflaundry, e.g., a pre-wash (which is not typically the case), or 

if the consumer washed more than one wash load at a time. Subsequent washes could receive 

diminishing benefits, since the water in the holding tub would cool ifleft standing too long. A limiting 

performance factor mentioned by more than one manufacturer for this design option was soil removal. 

This design option is currently commeJ;'cially available. An example is AB Electrolux's 

Recycle 40. It uses water from the final rinse of one load to use again as the prewash of the next 

cycle [27]. Maytag features this option as a water saving option on one of its washers. 

The future (Appendix 11) DOE test procedure will no longer provide an energy saving benefit 

for this design option. The two interested parties that eorrimented on this provision during the 

comment period for the test procedures, were not in favor of retaining credit for this design option 

[28][29]. In addition, because this option requires an external wash tub, consumer utility is affected. 

This option is eliminated from further consideration for the above stated reasons. 

Direct drive motor 

This design option is primarily intended for use in vertical axis machines. A conventionai 

vertical axis clothes washer uses an induction motor, a mechanical transmission, and sometimes a 

pulley belt. A direct drive motor can replace a conventional motor/transmission system. Rather than 

using a belt and/or transmission, a motor could be directly connected to the agitator, thereby avoiding 

transmission (gearbox) losses. Eaton, a motor manufacturer, claims that this will result in less 

mechanical energy required, i.e., less energy needed to run the agitator motor. This is accomplished 

by using a Brushless DC (BLDC) motor with electronic controls. Cleanability was not measured by 

Eaton. In addition, other parameters such as cycle time or spin speed were not kept constant in a 

comparison test with a conventional washer. For the machines tested, Eaton found savings of about 

140 W-hr per cycle or 64% of motor energy use. When adjusted for the direct drive standby power, 

this difference drops to about 35 W-hr per cycle or 16%. The direct drive standby power is the 

energy consumption when the machine is "off'. In the "off' mode, the direct drive motor system has 

a power drain of 4. 78 watts. The current DOE test procedure does not account for standby power 

use. Energy savings could be improved if the standby power loss was decreased [30]. 

One company submitted a comment that energy losses in the drive system are a very small 

percent of total energy use. Therefore, savings from a direct drive motor would be minimal. A 

limiting performance factor mentioned by more than one manufac~rer for this design option was 

physical size. 

11 
In Japan, Australia, and Asia, vertical axis direct drive washers are currently available. Some

horizontal axis machines also use a direct drive motor. Thus, using manufacturer supplied cost and

efficiency data, this design option is analyzed as a method to improve the clothes washer efficiency.

Automaticfill control2

This design option incorporates advanced control technologies to sense the clothes load and

adjust the water level accordingly. For a vertical axis machine, this may mean setting the water level

to just submerge the clothes load. This design option would overcome the tendency of consumers

to manually select a water level greater than required.

Energy is saved in either the vertical or horizontal axis designs by reducing the amount of hot

water used in the wash cycle. The future (Appendix J1) DOE test procedure (unlike the existing

DOE test procedure) uses an actual clothes load and, therefore, possible savings due to this design

option can be measured. Limiting performance factors mentioned by more than one manufacturer

for this design option were: 1) gentleness of action and 2) wear.

Washing machines with automatic fill control are available. Test procedure waivers for this

design option have been applied for, and in some cases a decision or order has been issued by the

DOE. Using manufacturer supplied cost and efficiency data, this design option is analyzed as a

method to improve clothes washer efficiency.

Reduced thermal mass

This design option uses a plastic tub to reduce the thermal mass that would be heated by the

water. Tests by manufacturers indicate that very little energy can be saved this way because the bulk

of the thermal mass is contained in the hot water. One manufacturer compared the impact of both

porcelain enameled steel and polypropylene outer tubs on water temperature. Both machines were

filled with 16 gallons of 140°F water and agitated for ten minutes. After ten minutes, there was no

significant difference in water temperature between the two machines. Calculations show that if there

were no heat losses through the outer tub, the equilibrium temperature for the tested steel tub

described above would be 138.9°F. Therefore, there is little to be gained by decreasing the thermal

mass of the outer tub [31 ].

Plastic outer tubs are commonly used by manufacturers and can be considered as part of the

baseline model. There is no practicable way to manufacture washing machines with a lower thermal

mass beyond the current practice. Therefore, this design option is eliminated from further analysis.

2In the test procedure the terminology used is "adaptive water fill control".

12

 EE-RM-94-403 COMMENT 50

In Japan, Australia, and Asia, vertical axis direct drive washers are currently available. Some 

horizontal axis machines also use a dire~t drive motor. Thus, using manufacturer supplied cost and 

efficiency data, this design option is analyzed as a method to improve the clothes washer efficiency. 

Automatic fill controz2 

This design option incorporates advanced control technologies to sense the clothes load and 

adjust the water level accordingly. For a vertical axis machine, this may mean setting the water level 

to just submerge the clothes load. This design option would overcome the tendency of consumers 

to manually select a water level greater than required. 

Energy is saved in either the vertical or horizontal axis designs by reducing the amount of hot 

water used in the wash cycle. The future (Appendix 11) DOE test procedure (unlike the existing 

DOE test procedure) uses an· actual clothes load and, therefore, possible savings due to this design 

option can be measured. Limiting performance factors mentioned by more than one manufacturer 

for this design option were: 1) gentleness of action and 2) wear. 

Washing machines with automatic fill control are available. Test procedure waivers for this 

design option have been applied for, and .in some cases a decision or order has been issued by the 

DOE. Using manufacturer supplied cost and efficiency data, this design option is analyzed as a 

method to improve clothes washer efficiency. 

Reduced thermal mass 

This design option uses a plastic tub to reduce the thermal mass that would be heated by the 

water. Tests by manufacturers indicate that very little energy can be saved this way because the bulk 

of the thermal mass is contained in the hot water. One manufacturer compared the impact of both 

porcelain enameled steel and polypropylene outer tubs on water temperature. Both machines were 

filled with 16 gallons of 140°F water and agitated for ten minutes. After ten minutes, there was no 

significant difference in water temperature between the tWo machines. Calculations show that if there 

were no heat losses through the outer tub, the equilibrium temperature for the tested steel tub 

described above would be 138.9°F. Therefore, there is little to be gained by decreasing the thermal 

mass of the outer tub [3 1]. 

Plastic outer tubs are commonly used by manufacturers and can be considered as part of the 

baseline modeL There is no practicable way to manufacture washing machines with a lower thermal 

mass beyond the current practice. Therefore, this design option is eliminated from further analysis. 

2In the test procedure the terminology used is "adaptive water fill control". 

12 
Electrolytic disassociation of water

The goal of electrolytic dissociation of water is to reduce hot water usage by substituting the

electrolytic production of bleaching agents for the water heating process. A prototype clothes washer

with electrolytic dissociation of water has been successfully tested [32]. Although commercial

detergents perform better at high temperatures, the same: hypochlorite concentration obtained by

adding bleaching agents to water can be achieved at low temperatures, if the agents are produced by

electrolytic disassociation within the machine. The bleaching action is due to the chemical reaction

of the oxygen (derived from the chemical decomposition of the hypochlorite) with the insoluble

organic compounds that constitute the soil in the clothes. Together they make soluble compounds

that are dissolved in the water.

Electrolytic dissociation was tested in a laboratory electrochemical cell. Medium soiled

clothes and white materials were used in the test. The washing cycle test was conducted in two steps.

The first was with electrolytic action, which was performed by adding 4 gm/liter of salt to the room

temperature water. The second stage was with a commercial detergent at a temperature of 95°F to

113°F. The usual rinses, spinning, and drainage followed. Initial tests showed that energy use

dropped from about 2.65 kWh/cycle for a typical washing machine to 1.35 kWh/cycle for the new

electrochemical method. The costs of such a system are not available.

Manufacturers do not feel that electrolytic dissociation is a workable approach. Primary

concerns are negative effects on garments resulting from the bleaching process and poor consumer

acceptance due to their inability to control the chemistry and temperature in the wash part of the cycle

[33]. Since there are no commercially available or working prototypes for residential use, this design

option is eliminated from further consideration.

Ultrasonic washing

The addition of mechanical energy can reduce the need for hot water (or chemical energy) in

the cleaning action of clothes washers. One potential method of delivering the mechanical energy is

through ultrasonic vibrations that loosen and remove some of the dirt on the soiled clothes. Such

washing machines have been produced by a Japanese firm and were to be marketed in the U.S. One

U.S. manufacturer of clothes washers investigated the Japanese product and found that it did not

successfully clean clothes. The U.S. firm stated that the Japanese company is an excellent

manufacturer of ultrasonic transducers, but does not have experience with clothes washing.

One of the problems with ultrasonic vibration is that clothes are not uniformly exposed to the

vibrations generated by the transducers, which means that some areas remain soiled. Additionally,

the wash solution and the submerged clothes appear to dissipate much of the energy without being

cleaned. Although ultrasonic vibration may be technically feasible, a design producing adequate

cleaning action does not appear to have been developed [34].

13

 EE-RM-94-403 COMMENT 50

• 

Electrolytic disassociation of water 

The goal of electrolytic dissociation of water is to reduce hot water usage by substituting the 

electrolytic production of bleaching agents for the water heating process. A prototype clothes washer 

with electrolytic dissociation of water has been succesSlfully tested [32]. Although commercial 

detergents perform better at high temperatures, the same: hypochlorite concentration obtained by 

adding bleaching agents to water can be achieved at low temperatures, if the agents are produced by 

electrolytic disassociation within the machine.. The bleaching action is due to the chemical reaction 

of the oxygen (derive~ from the chemical decomposition of the hypochlorite) with the insoluble 

organic compounds that constitute the soil in the clothes. Together they make soluble compounds 

that are dissolved in the water. 

Electrolytic dissociation was tested in a laboratOJ[Y electrochemical cell. Medium soiled 

clothes and white materials were used in the test. The washing cycle test was conducted in two steps. 

The first was with electrolytic action, which was performed by adding 4 gmIliter of salt to the room 

temperature water. The second stage was with a commercial detergent at a temperature of 95 OF to 

113 ° F. The usual rinses, spinning, and drainage followed. Initial tests showed that energy use 

dropped from about 2.65 kWh/cycle for a typical washing machine to l.35 kWh/cycle for the new 

electrochemical method. The costs of such a system are not available. 

Manufacturers do not feel that electrolytic dissociation is a workable approach. Primary 

concerns are negative effects on garments resulting from the bleaching process and poor consumer 

acceptance due to their inability to control the chemistry and temperature in the wash part of the cycle 

[33]. Since there are no commercially available or working prototypes for residentiai use, this design 

option is eliminated from further consideration. 

Ultrasonic washing 

The addition of mechanical energy can reduce the need for hot water (or chemical energy) in 

the cleaning action of clothes washers. One potential method of delivering the mechanical energy is 

through ultrasonic vibrations that loosen and remove s~me of the dirt on the soiled clothes. Such 

washing machines have been produced by a Japanese firm and were to be marketed in the U.S. One 

U. S. manufacturer of clothes washers investigated the Japanese product and found that it did not 

successfully clean clothes. The U.S. firm stated that the Japanese company is an excellent 

manufacturer of ultrasonic transducers, but does not have experience with clothes washing. 

One of the problems with ultrasonic vibration is that dothes are not uniformly exposed to the 

vibrations generated by the transducers, which means that some areas remain soiled. Additionally, 

the wash solution and the submerged clothes appear to dissipate much of the energy without being· 

cleaned. Although ultrasonic vibration may be technically feasible, a design producing adequate 

cleaning action does not appear to have been developed [34]. 

13 
Since there does not appear to be a commercially available product or a working prototype

(that successfully cleans clothes), this design option is eliminated from further analysis.

Bubble action

Daewoo Electronics, Ltd. has developed an air bubble washing machine. This machine uses

a low-profile bottom-hugging impeller typical in Asian-style vertical axis washers and combines it

with a six-winged, rotating pulsator shaped to direct water in four directions. This pulsator also

distributes air bubbles in different directions. The bubbles are generated by a vibrating bellows which

is driven by an electromagnet. Bubbles are reported to increase the cleaning power of the washer in

several ways: 1) by inducing a high-frequency pressure fluctuation near the clothes, 2) by increasing

the dissolution of detergent, 3) by increasing the amount of dissolved oxygen which increases the

activity of the detergent, and 4) by lowering the viscosity of the wash water [35][36].

The Sharp Corporation also makes a bubble washer in which the bubble-generating device

uses neuro-fuzzy logic controls. From a nozzle located at the bottom of the washer, air bubbles are

generated by a computer-controlled pulsator and circulated upward in vertical and horizontal swirling

motions. The controls adjust the amount of water use by using a single-tub design that washes the

same amount of laundry as a typical dual-tub (inner and outer) configuration. Water and detergent

use are only 70% of that used in conventional dual-tub designs. Although sold in Japan, this machine

is not yet marketed in the United States [37]. Standardized and independent tests have yet to be

conducted on the performance of the bubble-action system, therefore the energy saving potential and

performance of a bubble action design option is unknown.

This design option was proposed because of reports that such a machine was being

manufactured in Korea and Japan. However, since there do not appear to be any energy savings

studies from this design option, this design option is eliminated from further analysis.

Ozonated laundering

Currently, three manufacturers make ozonated laundering systems for commercial/institutional

washers. The ozone, manufactured from ambient air, is injected into the water. There is some debate

as to how the process of the ozonated cleaning exactly works. Some claim the ozone reacts with

soluble soils, making them insoluble, after which the mechanical action of the washing separates the

soils from the fabric. One manufacturer proposed that the energy inherent in ozone reduces water

tension, making the water a better solvent. Energy is saved with this system because the water is not

heated for light'to moderately soiled laundry; in fact colder water retains a higher concentration of

ozone for a longer time. For heavily soiled laundry, temperatures of 100-110°F are used. Also, since

less chemicals are used, the rinse time is minimized thereby reducing the total wash time. Economical

ozone production is critical to the potential energy savings. One manufacturer estimates savings of

25% on "utility expenses" with installation of its system. The expected cost and energy consumption

for a residential ozonated wash system are unknown [38].

14

 EE-RM-94-403 COMMENT 50

Since there does not appear to be a cOmrriercially available product or a working prototype 

(that successfully cleans clothes), this. design option is eliminated from further analysis. 

Bubble action 

Daewoo Electronics, Ltd. has developed an air bubble washing machine. This machine uses 

a low-profile bottom-hugging impeller typical in Asian-style vertical axis washers and combines it 

with a six-winged, rotating pulsator shaped to direct water in four directions. This pulsator also 

distributes air bubbles in different directions. The bubbles are generated by a vibrating bellows which 

is driven by an electromagnet. Bubbles are reported to increase the cleaning power of the washer in 

several ways: 1) by inducing a high-freq1:lency pressure fluctuation near the clothes, 2) by increasing 

the dissolution of detergent, 3) by increasing the amount of dissolved oxygen which increases the 

activity of the detergent, and 4) by lowering the viscosity of the wash water [35][36]. 

The Sharp Corporation also makes a bubble washer in which the bubble-generating device 

uses neuro-fuzzy logic controls. From a nozzle located at the bottom ofthe washer, air bubbles are 

generated by a computer-controlled pulsator and circulated upward in vertical and horizontal swirling 

motions. The controls adjust the amount of water use by using a single-tub design that washes the 

same amount oflaundry as a typical dual-tub (inner and outer) configuration. Water and detergent 

use are only 70% ofthat used in conventional dual-tub designs. Although sold in. Japan, this machine 

is not yet marketed in the United States [37]. Standardized and independent tests have yet to be 

conducted on the performance of the bubble-action system, therefore the energy saving potential and 

performance of a bubble action design option is unknown. 

This design option was proposed because of reports that such a machine was being 

manufactured in Korea and Japan. However, since there do not appear to be any energy savings 

studies from this design option, this desig~ option is eliminated .from further analysis. 

Ozonated laundering 

Currently, three manufacturers make ozonated laundering systems for commerciaVinstitutional 

washers. The ozone, manufactured from ambient air, is injected into the water. There is some debate 

as to how the process of the ozonated cleaning exactly works. Some claim the ozone reacts with 

soluble soils, making them insoluble, after which the mechanical action of the washing separates the 

soils from the fabric. One manufacturer proposed that the energy inherent in ozone reduces water 

tension, making the water a better solvent. Energy is saved with this system because the water is not 

heated for IIght·to moderately soiled laundry; in fact colder water retains a higher concentration of 

ozone for a longer time. For heavily soiled laundry, temperatures of 100-11 O°F are used. Also, since 

less chemicals are used, the rinse time is minimized thereby reducing the total wash time. Economical 

ozone production is critical to the potential energy savings. One manufacturer estimates savings of 

25% on "utility expenses" with installation of its system. The expected cost and energy consumption 

for a residential ozonated wash system are unknown [38]. 

14 
There does not appear to be any commercially available or working prototype residential

clothes washer using this design option. Therefore, this design option is eliminated from further

analysis.

4. CONCLUSIONS

For previously stated reasons, the design options in Table 4 were eliminated from further

consideration.

Table 4. Design Options Eliminated from Further Analysis

Improved Water Extraction for RMC's of 35% & 30%

Suds Saving

Reduced Thermal Mass

Electric Disassociation of Water

Ultrasonic Washing

Bubble Action

Ozonated Laundering

Table 5 shows the design options remaining for further analysis.

Table 5. Remaining Design Options

Improved Fill Control

Tighter tub tolerance

Thermostatically controlled mixing valves (TCMV)

Improved Water Extraction for RMC's of 50% &40%

Horizontal axis design

Horizontal axis design with recirculation

Automatic Fill Control

Increased Motor Efficiency

Direct Drive Motor

Advanced Controls / Sensors

Added Insulation

15

 EE-RM-94-403 COMMENT 50

• 

There does not appear to be any commercially available or working prototype residential 

clothes washer using this design option. Therefore, this design option is eliminated from further 

analysis. 

4. CONCLUSIONS 

For previously stated reasons, the design options in Table 4 were eliminated from further 

consideration. 

Table 4. Design Options Eliminated from Further Ap,alysis 

Improved Water Extraction for RMC's of 35% & 30% 

Suds Saving 

Reduced Thermal Mass 

Electric Disassociation of Water 

Ultrasonic Washing 

Bubble Action 

Ozonated Laundering 

Table 5 shows the design options remaining for fun:her analysis. 

Table 5. Remaining Design Options 

Improved Fill Controi 

Tighter tub tolerance 

Thermostatically controlled mixing valves (TCMV) 

Improved Water Extraction for RMC's of 50% &40% 

Horizontal axis design 

Horizontal axis design with recirculation 

Automatic Fill Control 

Increased Motor Efficiency 

Direct Drive Motor 

Advanced Controls / Sensors 

Added Insulation 

15 
REFERENCES

1. U.S. Department of Energy (DOE). 1996a. Procedures, Interpretations and Policies for

Consideration of New or Revised Energy Conservation Standards for Consumer Products;

Final Rule. Federal Register Vol. 61 No. 136, Appendix A to Subpart C of Part 430 --

July 15, 1996.

2. U.S. Department of Energy (DOE). 1994. Advance Notice of Proposed Rulemaking,

Federal Register, Vol. 59, No. 218, 10 CFR Part 430, Docket No. EE-RM-94-403,

November 14, 1994.

3. U.S. Department of Energy (DOE). 1991. Energy Conservation Program for Consumer

Products: Final Rule Regarding Energy Conservation Standards for Three Types of

Consumer Products. Code of Federal Regulations, Title 10 Part 430, Vol. 56, No. 93, May

14, 1991. Docket No. CE-RM-88-101.

4. Ibid.

5. U.S. DOE. 1994. Op cit.

6. U.S. DOE. 1996a. Op. cit.

7. U.S. DOE. 1996b. Energy Conservation Program for Consumer Products: Test Procedure

for Clothes Washers and Reporting Requirementfor Clothes Washers, Clothes Dryers, and

Dishwasher. (61 Federal Register 17589, April 22, 1996.), 10CFR, Part 430, Docket No. EERM-94-230A.

8. Science Applications Inc., 1977. Energy Efficiency Program for Clothes Washers, Clothes

Dryers and Dishwashers, SAI-77-839, La Jolla, CA. p.4-45.

9. Association of Home Appliance Manufacturers (AHAM). 1995. Comments on the Advance

Notice of ProposedRulemaking. DOE Docket No. EE RM-94-403. comment #27, May 8,

1995.

10. U.S. DOE. 1996b. Op cit.

11. AHAM. 1996. Comments on the Supplemental Notice of Proposed Rulemaking, Energy

Conservation Program for Consumer Products: Test Procedure for Clothes Washers Test

Procedure, DOE Docket No. EE-RM-94-230A, comment #7, June 6, 1996.

12. Ibid.

13. Arthur D. Little, Inc. (ADL). 1995. Laboratory Testing of Clothes Washers, p.3-8, December,

1995, EPRI Report No. TR-105098.

16

 EE-RM-94-403 COMMENT 50

REFERENCES 

1. U. S. Department of Energy (DOE). 1996a. Procedures, Interpretations and Policies for 

Consitieration-of New or Revised Energy Conservation Standards for Consumer Products; 

. Final Rule. Federal Register Vol. 61 No. 136, Appendix A to Subpart C of Part 430 --

July 15, 1996. 

2. U.S. Department of Energy (DOE). 1994. Advance Notice of Proposed Rulemaking, 

Federal Register, Vol. 59, No. 218, 10 CFR Part 430, Docket No. EE-RM-94-403, 

November 14, 1994. 

3. U.S. Department of Energy (DOE). 1991. Energy Conservation Program for Consumer 

Products: Final Rule Regarding Energy ConsenJation Standards for Three Types of 

Consumer Products. Code of Federal Regulations, Title 10 Part 430, Vol. 56, No. 93, May 

14, 1991. Docket No. CE-RM-88-10l: 

4. Ibid 

5. U.S. DOE. 1994. Op cit. 

6. U.S. DOE. 1996a. Op. cit. 

·7. U.S. DOE. 1996b. Energy Conservation Programfor Consumer Products: Test Procedure 

for Clothes Washers and Reporting Requirement for Clothes Washers, Clothes Dryers, and 

Dishwasher. (61 Federal Register 17589, April 22, 1996.), lOCFR, Part 430, Docket No. EERM-94-230A. -

8. Science Applications Inc., 1977. Energy Efficiency Program for Clothes Washers, Cloihes 

Dryers and Dishwashers, SAI-77-839, LaJolla, CA. p.4-45. 

9. Association of Home Appliance Manufacturers (AHAM). 1995. Comments on the Advance 

Notice of Proposed Rulemaking. DOE Docket No. EE RM-94-403, comment #27, May 8, 

1995. 

10. U.S. DOE. 1996b. Op cit. 

11. AHAM. 1996. Comments on the Supplemental Notice of Proposed Rulemaking, Energy 

Conservation Program for Consumer Products: Test Procedure for Clothes Washers Test 

Procedure, DOE Docket No. EE-RM-94-230A, comment #7, June 6, 1996. 

12. Ibid 

13. ArthurD. Little, Inc: (ADL). 1995. Laboratory Testing of Clothes Washers, p.3-8, December, 

1995, EPRI Report No. TR-I05098. 

16 
14. U.S. DOE. 1996b. Op. cit.

15. U.S. DOE. 1996c. Federal Register, April 24, 1996, Volume 61, Number 80, Office of Energy

Efficiency and Renewable Energy [Case No. CW-004]. Energy Conservation Programfor

Consumer Products: Granting of the Applicationfor Interim Waiver and Publishing of the

Petition for Waiver of General Electric Appliances from the DOE Clothes Washer Test

Procedure.

16. Consortium for Energy Efficiency (CEE). High Efficiency Clothes Washer Initiative,

Qualifying Products as of 7/9/96.

17. ADL. 1995. Op. cit.

18. B. Lebot, I. Turiel, G. Rosenquist. 1990. "Horizontal Axis Domestic Clothes Washers: An'

Alternative Technology that Can Reduce Residential Energy and Water Use". Proceedings

of the ACEEE 1990 Summer Study on Energy Efficiency in Buildings, Volume 1, Building

Equipment and Appliances, p.1.147-1.156.

19. A. Cahn. 1994. The Laundering Process, handout presented at the Workshop on Home

Laundry Energy Standards Regulatory Issues, Washington, D.C., November 11, 1994.

20. Procter & Gamble, Comments on the Advance Notice of Proposed Rulemaking, DOE Docket

No. EE RM-94-403, comment #9, January 20, 1995.

21. AHAM. 1995. Op. cit.

22. Electrolux product literature. New for '93, Domotechnica.

23. U.S. DOE. 1996b. Op. cit.

24. Appliance Manufacturer, April 1995, p.27.

25. Appliance Manufacturer, February 1995, p.E-58

26. Appliance, "New Ways of Washing", September 1992, Vol. 49, No. 9, p.75.

27. Appliance, September 1995, p.51.

28. Maytag 1996. Comments on the Supplemental Notice of Proposed Rulemaking, Energy

Conservation Program for Consumer Products: Test Procedure for Clothes Washers Test

Procedure, DOE Docket No. EE-RM-94-230A, comment #8, June 6, 1996.

29. Raytheon 1996. Comments on the Supplemental Notice of Proposed Rulemaking, Energy

Conservation Program for Consumer Products: Test Procedure for Clothes Washers Test

Procedure, DOE Docket No. EE-RM-94-230A, comment #9, June 6, 1996.

17

 EE-RM-94-403 COMMENT 50

14. US. DOE. 1996b. Gp. cit. 

15. US. DOE. 1996c. Federal Register, April 24, 1996, Volume 61, Number 80, Office of Energy 

Efficiency and Renewable Energy [Case No. CW-004]. Energy Conservation Programfor 

Consumer Products: Granting of the Application for Interim Waiver and Publishing of the 

Petition for Waiver of General Electric Appliances from the DGE Clothes Washer Test 

Procedure. 

16. Consortium for Energy Efficiency (CEE). High Efficiency Clothes Washer Initiative, 

Qualifying Products as of 7/9/96. 

17. ADL. 1995. Gp. cit. 

18. B. Lebot, I. Turiel, G. Rosenquist. 1990. "Horizontal Axis Domestic Clothes Washers: An' 

Alternative Technology that Can Reduce Residential.Energy and Water Use". Proceedings 

of the ACEEE 1990 Summer Study on Energy Efficiency in Buildings, Volume 1, Building 

Equipment a~d Appliances, p.l.14 7 -1.156. 

19. A. Cahn. 1994. The Laundering Process, handout presented at the Workshop on Home 

Laundry Energy Standards Regulatory Issues, Washington, D.C., November 11, 1994. 

20. Procter & Gamble, Comments on the Advance Notice of Proposed Rulemaking. DOE Docket 

No. EE RM-94-403, comment #9, JB:nuary 20, 1995. 

21. AHAM. 1995. Gp. cit 

22. Electrolux product literature. New for '93, Domolechnica. 

23. US. DOE. 1996b. Gp. cit. 

24. Appliance Manufacturer, April 1995, p.27. 

25. Appliance Manufacturer, February 1995, p.E-58. 

26. Appliance, "New Ways of Washing", September 1992, Vol. 49, No.9, p.75. 

27. Appliance, September 1995, p.5l. 

28. Maytag 1996. Comments.on the Supplemental Notice of Proposed Rulempking, Energy 

Conservation Program for Consumer Products: Test Procedure for Clothes Washers Test 

Procedure, DOE Docket No. EE-RM-94-230A, comment #8, June 6, 1996. 

29. Raytheon 1996. Comments on the Supplemental Notice of Proposed Rulemaking, Energy 

Conservation Program for Consumer Products: Test Procedure for Clothes Washers Test 

Procedure, DOE Docket No. EE-RM-94-230A, comment #9, June 6, 1996. 

17 
30. S. Kristic, J. Pardee, "Direct" Comparison Assessing the Energy Efficiency Impact of a

Transmission-Less Motor-Drive System for Conventional Clothes Washers, Proceedings of

the 44th Annual International Appliance Technical Conference, p. 101, May 1993.

31. U.S. DOE. 1990. Technical Support Document: Energy Conservation Standards for

Consumer Products: Dishwashers, Clothes Washers, and Clothes Dryers, p.3-14, DOE/CE0299P, December 1990.

32. Ibid p.3-15.

33. Ibid. p.3-15.

34. Ibid. p.3-15.

35. Appliance Manufacturer, "Big Plans for Tiny Bubbles", p.32, December 1994.

36. Appliance, "Sorting Through Laundry", p.35, September 1994.

37. I. Turiel, et al., Evaluation of Advanced Technologies for Residential Appliances and

Residential and Commercial Lighting, January 1995, Lawrence Berkeley National

Laboratory, LBL-35982.

38. Electric Power Research Institute (EPRI). 1996. Ozone Laundering: A Better Wash Process

for Commercial Laundries, Technical BriefRP2890, March 1996.

18

 EE-RM-94-403 COMMENT 50

30. S. Kristic, J. Pardee, "Direct" Comparison Assessing the Energy Efficiency Impact of a 

Transmission-Less Motor-Drive System for Conventional Clothes Washers, Proceedings of 

the 44th Annual International Appliance Technical Conference, p.1 0 1, May 1993. 

31. U.S. DOE. 1990. Technical Support Document: Energy Conservation Standards jor 

Consumer Products: Dishwashers, Clothes Washers, and Clothes Dryers, p.3-14, DOE/CE0299P, December 1990. 

32. Ibid p.3-15. 

33. Ibid p.3-15. 

34. Ibid p.3-15. 

35. Appliance Manufacturer, "Big Plans for Tiny Bubbles", p.32, December 1994. 

36. Appliance, "Sorting Through Laundry", p.35, September 1994. 

37. I. Turiel, et al., Evaluation of Advanced Technologies for Residential Appliances and 

Residential and Commercial Lighting January 1995, Lawrence Berkeley National 

Laboratory, LBL-35982. 

38. Electric Power Research Institute (EPRI). 1996. Ozone Laundering: A Better Wash Process 

for Commercial Laundries, Technical Brief RP2890, March 1996. 

18 
DRAFT REPORT ON THE PRELIMINARY ENGINEERING ANALYSIS

FOR CLOTHES WASHERS

October 1996

LAWRENCE BERKELEY NATIONAL LABORATORY

Energy & Environment Division

Technology and Market Assessment Group

Berkeley, CA 94720

Prepared for

U.S. DEPARTMENT OF ENERGY

Office of Codes and Standards

 EE-RM-94-403 COMMENT 50

DRAFT REPORT ON THE PRELIMINARY ENGINEERING ANALYSIS 

FOR CLOTHES WASHERS 

October 1996 

LAWRENCE BERKELEY NATIONAL LABORATORY 

Energy & Environment Division 

Technology and Market Assessment Group 

Berkeley, CA 94720 

Prepared for 

u.s, DEPARTMENT OF ENERGY 

Office of Codes and Standards 
TABLE OF CONTENTS

DRAFT REPORT ON THE PRELIMINARY ENGINEERING ANALYSIS FOR

CLOTHES WASHERS

1. O V E R V IE W ...................................................... 1

2. TEST PROCEDURE .............................. ........... . .... .. 2

3. ENERGY-USE AND COST ANALYSIS ............................... 4

3.1 Introduction ..................... .......................... 4

3.2 Variability and Uncertainty Analysis .............................. 4

3.3 E nergy U se .......................... .............. ...... 5

3.4 Costing Data ................ ......... ........... 7

3.5 Energy-Use and Cost Results ................................. 8

4. MAXIMUM TECHNOLOGICALLY FEASIBLE DESIGN ................. 12

APPENDIX A. DISAGGREGATED MANUFACTURER COST DATA ........ A-I

APPENDIX B. ADJUSTMENTS TO AHAM DATA ....................... B-1

B. I Adjustments due to Statistical Variations .................... B-1

B.2 Adjustments due to Normalization ........................... B-l

B.3 Adjustments due to Test Procedure Changes ........ ...... . B-2

APPENDIX C RAW DATA PROVIDED BY AHAM ................. CAPPENDIX D DRYER EFFICIENCY FUEL CORRECTION DERIVATION .... D-l

APPENDIX E CALCULATIONS FOR IMPROVED WATER EXTRACTION

DESIGN OPTION I....... .................. . E-l

APPENDIX F. CLOTHES CONTAINER CAPACITY ... ... FLIST OF TABLES

Table 1.. General Assumptions ......... ........... 7

Table 2. Standard Clothes Washer: Cost, Energy-Use, and Water-Use Data ....... 9

Table A. I Disaggregated Cost of Efficiency Improvements for Standard

C lothes W ashers ............. ........... ............ .... A -2

Table B. 1 Temperature Use Factors for Proposed AHAM and Future DOE

Test Procedures .... ......... ................. B-3

Table C. 1 Raw Data Provided by AHAM and Used in the Engineering Analysis ... C-2

Table C.2 AHAM Confidence Level and Limiting Performance Factor Data ....... C-4

Table D. 1 Dryer Energy at 70% Initial Moisture Content ..................... DLIST OF FIGURES

Figure 1 Manufacturer Cost vs. Modified Energy Factor ..... 10

 EE-RM-94-403 COMMENT 50

TABLE OF CONTENTS 

DRAFT REPORT ON THE PRElLIMINARY ENGINEERING ANALYSIS FOR 

CLOTHES WASHERS 

1. OVERVIEW ...................................................... 1 

2. TEST PROCEDURE ................................................ 2 

3 . ENERGY-USE AND COST ANALYSIS ................................ 4 

3. 1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 

3.2 Variability and Uncertainty Analysis .............................. 4 

3.3 Energy Use. . . . . . . . . . . . . . . . . . . . . . . . . . . .............. , .... 5 

3.4 Costing Data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . 7 

3.5 Energy-Use and Cost Results . '.' . . . . . . . . . . . . . . . . . . . .. . ........ 8 

4. MAXIMUM TECHNOLOGICALLY FEASIBLE DESIGN. . . . . . . . . . . .. 12 

APPENDIX A. DIS AGGREGATED MANUFACTURER COST DATA ......... A-I 

APPENDIX B. ADJUSTMENTS TO AHAM DATA ....................... B-1 

B.l Adjustments due to Statistical Variations ........................ B-1 

B.2 Adjustments due to Normalization ...... . . . . . . . . .. . ...... B-1 

B.3 Adjustments due to Test Procedure Changes. . ................. B-2 

APPENDIX C RAW DATA PROVIDED BY AHAM . C-1 

APPENDIX D DRYER EFFICIENCY FUEL CORRECTION DERIVATION. '. 0-1 

APPENDIX E. CALCULATIONS FOR IMPROVED WATER EXTRACTION 

DESIGN OPTION. . . . . . . . . . . . . . . . . . . . . .. ...... E-1 

APPENDIX F. CLOTHES CONTAINER CAPACITY . . . . . . . . . . F-l 

LIST OF TABLES 

Table 1 .. 

Table 2. 

Table A.l 

General Assumptions . . . . . . . . . . . . .. . ........ . 

Standard Clothes Washer: Cost, Energy-Use, and Water-Use Data. 

Oisaggregated Cost of Efficiency Improvements for Standard 

Clothes Washers. . . . . . . . . . . . . . . . . ......... . 

Table B.l Temperature Use Factors for Proposed AHAM and Future DOE· 

. 7 

9 

A-2 

Test Procedures . . . . . . . . . . . . . . . . . . . . . . . . . B-3 

Table C 1 Raw Data Provided by AHAM and Used in the Engineering Analysis C-2 

Table C.2 AHAM Confidence Level and Limiting Performance Factor Data ....... C-4 

Table D.l Dryer Energy at 70% Initial Moisture Content ..................... D-l 

LIST OF FIGURES 

Figure 1 Manufacturer Cost vs. Modified Energy Factor 10 

i 
Clothes Washer Preliminary Engineering Analysis

1. OVERVIEW

The Engineering Analysis provides information on efficiencies, manufacturer costs, and other

characteristics of the appliance class being analyzed. For clothes washers, there are two classes:

standard and compact. Since data were not available to analyze the compact class, only standard

clothes washers were analyzed in this report.-- For this analysis, individual design options were

combined and ordered in a manner that resulted in the lowest cumulative cost/savings ratio. The

cost/savings ratiois the increase in manufacturer cost for a design option divided by the reduction in

operating costs due to fuel and water savings.

A significant amount of information gathering and analysis was conducted before the new

interpretive rule process approach was implemented, therefore, some preliminary results are presented

here as a point for discussion. The methodologies used in the final engineering analysis report will

be addressed after consultation with stakeholders. Uncertainty and variability of data must also be

addressed before the engineering analysis is completed. Other input from stakeholders is also

encouraged for the final engineering analysis report. Alternative approaches can be explored or

present approaches can be modified and refined. Also open for discussion is what variables or

uncertainties need to be analyzed.

Baseline Units

A baseline unit is the starting point for analyzing design options for improving energy

efficiency. In this repor.' the baseline unit represents a typical model with an energy efficiency no

lower than the minimum required by the amended National Appliance Energy Conservation Act

(NAECA) (Energy Factor > 1.18 ft3/kWh). The baseline energy use is based on the shipmentweighted average of major American manufacturers' models.

Design Options

Design options that are presently commercially available or that are in prototypes were

established in Draft Report on Desigtn Optionsfor Clothes Washers [1]. This report also discussed

design options which were screened out from further analysis based on provisions detailed in the

Department of Energy's Interpretive Rule [2]. Analysis of economic criteria will be found in a future

report.

Maximum Technologically Feasible Designs

A maximum technologically feasible design option consisting of a combination of individual

design options was identified. This option, or combination of options, results in the highest energy

 EE-RM-94-403 COMMENT 50

Clothes Washer Preliminary Engineering Analysis· 

1. OVERVIEW 

The Engineering Analysis provides information on efficiencies, manufacturer costs,and other 

characteristics of the appliance class being analyzed. For clothes washers, there are two classes: 

standard and compact. Since data were not available to analyze the compact class, only standard 

clothes washers were analyzed in this report.· For this analysis, individual design options were 

combined and ordered in a manner that resulted in the lowest cumulative cost/savings ratio. The 

cost/savings ratio is the increase in manufacturer cost for a design option divided by the reduction in 

operating costs due to fuel and water savings. 

A significant amount of information gathering and analysis was conducted before the new 

interpretive rule process approach was implemented, therefore, some preliminary results are presented 

here as a point for discussion. The methodologies used in the final engineering analysis report will 

be addressed after consultation with stakeholders. Uncertainty and variability of data must also be 

addressed before the engineering analysis is completed. Other input from stakeholders is also 

encouraged for the final engineering analysis report. Alternative approaches can be explored or 

present approaches can be modified and refined. Also open for discussion is what variables or 

uncertainties need to be c.nalyzed. 

Baseline Units 

A baseline unit is the starting point for analyzing design options for improving energy 

efficiency In this repon. the baseline unit represents a typical model with an energy efficiency no 

lower than the minimum required by the amended National Appliance Energy Conservation Act 

(NAECA) (Energy Factor::> 1.18 ft 3/kWh) The baseline energy use is based on the shipmentweighted average of major American manufacturers' models. 

Design Options 

Design options that are presently commercially available or that are in prototypes were 

established in Draft RepOrT Oil Design Options for Clothes Washers [I]. This report also discussed 

design options which were screened out from further analysis based on provisions detailed in the 

Department of Energy's Interpretive Rule [2]. Analysis of economic criteria will be found in a future 

report. 

Maximum Technologically Feasible Designs 

A maximum technologically feasible design option consisting of a combination of individual 

design options was identified. This option, or combination of options, results in the highest energy 
efficiency. The maximum technologically feasible efficiency level must be either commercially feasible

or available as a working prototype.

Efficiency Calculation

The efficiency levels corresponding to various design options were determined from

manufacturer data and from engineering calculations.

Cost Estimates

Estimates of manufacturer cost were received in response to a questionnaire sent out by

Lawrence Berkeley National Laboratory (LBNL) to the Association of Home Appliance

Manufacturers (AHAM). Appendix A contains detailed incremental cost data disaggregated into

labor, purchased parts and materials, shipping/packaging, and investment. The sum of individual

design option costs were used for design options combined in this analysis (i.e., those not previously

combined by AHAM or manufacturers).

Cost-Efficiency Relationships

The results of the Engineering Analysis are summarized in cost-efficiency relationships which

show the efficiency and manufacturer cost of the design options.

Outputs from the Engineering Analysis

For each combination of design options considered in the analysis, the following are provided:

* energy efficiency (expressed as a Modified Energy Factor' and unit energy consumption);

* increased variable and fixed costs for manufacturers;

* annual energy consumption per unit (based on DOE test procedures);

* the relationship between cost and efficiency: and

* change in water consumption.

2. TEST PROCEDURE

Since this analysis is based on a future Department of Energy (DOE) test procedure, it is

important to discuss proposed changes to the test procedure. The Department has proposed two new

' The Modified Energy Factor is a measure of energy efficiency derived fiom the future DOE test procedure tor each

product type.

2 /

 EE-RM-94-403 COMMENT 50

efficiency. The maximum technologically feasible efficiency level must be either commercially feasible 

or available as a working prototype. 

Efficiency Calculation 

The ~fficiency levels corresponding to various design options were determined from 

manufacturer data and from engineering calculations. 

Cost Estimates 

Estimates of manufacturer cost were received in response to a questionnaire sent out by 

Lawrence Berkeley National Laboratory (LBNL) to the Association of Home Appliance 

Manufacturers (AHAM). Appendix A contains detailed incremental cost data disaggregated into 

labor, purchased parts and materials, shipping/packaging, and investment. The sum of individual 

design option costs were used for design options combined in this analysis (i.e., those not previously 

combined by AHAM or manufacturers). 

Cost-Efficiency Relationships 

The results of the Engineering Analysis are summarized in cost-efficiency relationships which 

show the efficiency and manufacturer cost of the design options. 

Outputs from the Engineering Analysis 

For each combination of design options considered in the analysis, the following are provided' 

• energy efficiency (expressed as a Modified Energy Factorl and unit energy consumption)~ 

• increased variable and fixed costs for manufacturers; 

. • annual energy consumption per unit (based on DOE test procedures); 

• the relationship between cost and efficiency: and 

• change in water consumption. 

2. TEST PROCEDURE 

Since this analysis is based on a future Department of Energy (DOE) test procedure, it is 

important to discuss proposed changes to the test procedure. The Department has proposed two new 

I The Modified Energy Factor is a measure of energy efficiency derived from the future DOE test procedure for each 

product type. 

2 
clothes washer test procedures in a Supplemental Notice of Proposed Rulemaking; Appendices "J"

and "J1" [3]. In this report, the two new versions of the test procedure "'' and "J1" will be referred

to as the "proposed" and "future" test procedure, respectively. The proposed (Appendix J) test

procedure will take effect shortly after being completed and published in the Federal Register as a

final rule. The "future" (Appendix J1) test procedure will take effect only when a new clothes washer

standard is enacted. The Engineering Analysis presented in this report is based on the future

(Appendix Jl) test procedure.

The test procedure used in analyzing design options is important not only because of

differences in the magnitude of energy savings predicted but also because it has the potential to

change the ranking of design options. For example, the energy savings due to a thermostatically

controlled mixing valve (TCMV) are dependent on the hot water temperature set point of the water

heater.

Existing test procedure

The existing test procedure specifies 140°F inlet water and 416 clothes washer cycles per year [4]. The existing test procedure is carried out without a cloth test load for vertical axis clothes

washers.

Proposed test procedure (Appendix J)

The Appendix J test procedure will not alter the existing energy factor of any clothes washer

that is required to meet the current efficiency standard, except for.clothes washers with temperature

selections which are locked out of the normal cycles [5]. Test procedure changes include 1) a clothes

washer use of 392 cycles per year, 2) clarification of wash/rinse temperatures to avoid ambiguity, 3)

specification of agitation and spin speed settings, 4) addition of water heating clothes washer

capability, and 5) new provisions to account for an automatic fill control feature. In addition, the

following informational quantities are defined: 1) total (both hot and cold) water consumption, 2)

remaining moisture content (RMC) in the test load after the final spin cycle, and 3) a calculated

modified energy factor (MEF). The MEF will include the energy needed to dry clothes in a dryer after a final washer spin cycle . Determining the MEF will not be mandatory.

Future test procedure (Appendix J1)

This DOE clothes washer test procedure has been proposed in order to more accurately

reflect actual energy usage and adapt to the continuing changes in clothes washer design. This test

procedure will make some of the informational changes in the Appendix J test procedure mandatory

[6]. Among the changes in the test procedure will be 1) new temperature use factors (TUFs), 2)

lowering of the inlet hot water temperature from the existing 140°F to 135 °F, 3) a water temperature rise change from 90 °F to 75 °F and 4) provisions to account for adaptive control and automatic fill

control. In addition, clothes washer test loads will depend on washer capacity, remaining moisture

content after a final spin cycle will be taken into account, and the MEF will replace the current energy

3

 EE-RM-94-403 COMMENT 50

clothes washer test procedures in a Supplemental Notice of Proposed Rulemaking; Appendices 'T' 

and "J}" [3]. In this report, the two new versions of the test procedure 'T' and "]1" will be referred 

to as the "proposed" and "future" test procedure, respectively. The proposed (Appendix J) test 

procedure will take effect shortly after being completed and published in the Federal Register as a 

final rule. The "future" (Appendix 11) test procedure will take effect only when a new clothes wa~her 

standard is enacted. The Engineering Analysis presented in this report is based on the future 

(Appendix ]1) test procedure. 

The test procedure used in analyzing design options is important not only because of 

differences in the magnitude of energy savings predicted but also because it .has the potential to 

change the ranking of design options. For example, the energy savings due to a thermostatically 

controlled mixing valve (TCMV) are dependent on the hot water temperature set point of the water 

heater. . 

Existing test procedure 

The existing test procedure specifies 140°F inlet water and 416 clothes washer cycles per year 

[4]. The existing test procedure is carried out without a cloth test load for vertical axis clothes 

washers. 

Proposed test procedure (Appendix J) 

The Appendix J test procedure will not alter the existing energy factor of any clothes washer 

that is required to meet the current efficiency standard, except for clothes washers with temperature 

selections which are locked out of the nonnal cycles [5]. Test procedure changes include 1) a clothes 

washer use of392 cycles per year, 2) clarification ofwashlrinse temperatures to avoid ambiguity, 3) 

specification of agitation and spin speed settings, 4) addition of water heating clothes washer 

capability, and 5) new provisions to account for an automatic fill controi feature In addition, the 

following informational quantities are defined. 1) total (both hot and cold) water consumption, 2) 

remaining moisture content (RMC) in the test load after the final spin cycle, and 3) a calculated 

modified energy factor (MEF). The MEF will include the energy needed to dry clothes in a dryer 

after a final washer spin cycle. Determining theMEF will not be mandatory. 

Future test procedure (Appendix JJ) 

This DOE clothes washer test procedure has been proposed in order to more accurately 

reflect actual energy usage and adapt to the continuing changes in clothes washer design. This test 

procedure will make some of the informational changes in the Appendix J test procedure mandatory 

[6]. Among the changes in the test procedure will be 1) new temperature use factors (TUFs), 2) 

lowering of the inlet hot water temperature from the existing 140°F to 135 OF, 3) a water temperature 

rise change from 90 OF to 75 OF and 4) provisions to account for adaptive control and automatic fili 

control. In addition, clothes washer test loads will depend on washer capacity, remaining moisture 

content after a final spin cycle will be taken into account, and the MEF will replace the current energy 

3 
factor (EF) for standard compliance. (Reporting of the energy factor (EF) will be kept for voluntary

programs.) The above changes should result in a more accurate prediction of actual clothes washer

and clothes dryer energy use.

3. ENERGY-USE AND COST ANALYSIS

3.1 Introduction

A cost and efficiency questionnaire sent to AHAM was responded to by five AHAM member

manufacturers, however not every manufacturer provided energy-use and cost data for each design

option considered. AHAM submitted energy usage data based on both the existing DOE test

procedure and a proposed2 AHAM test procedure. Differences between the proposed AHAM and

future DOE test procedures are discussed in Appendix B.

After LBNL performed an initial engineering analysis, additional information was requested

on combinations of design options, particularly for design options that could be used on both vertical

and horizontal axis washers. Additional data were desired because inherent design differences

between vertical and horizontal axis washers could result in different incremental costs and energy

savings for a given design option. Certain synergies in cost and efficiencies could also result from

combining some design options. The analysis performed was divided into two basic stages; Phase I

and Phase II. Phase I is the analysis of the responses from the initial questionnaire and Phase II

includes responses from additional data requests (e.g., combined design options and further

disaggregated design options). Data from both Phase I and Phase II were used in the final analysis.

Where possible, data submitted from Phase II were used. Data from Phase I were used when needed

to analyze design options not covered in the Phase II data submittal. The raw data supplied by

AHAM are provided in Appendix C:

3.2 Variability and Uncertainty Analysis

Because of large differences (in some instances) in cost and energy use data provided by

manufacturers it is important to analyze the effect of variability and uncertainty in the data used in the

engineering analysis.

Variability refers to differences in input values, for example, costs for a design option. Even

if in some cases the manufacturers know how much a design option would cost them to implement.

these costs may be different among manufacturers. Similarly for fuel costs, although current costs

for fuel are known, fuel prices vary among electric or gas utilities. Uncertainty is a measure of how

a data value may vary if the exact value is unknown. For example, although all manufacturers might

agree on the probable cost of a design option, the exact cost may be unknown. Parameters with

21n this report proposed AHAM test procedure" refers to an early version of the AHAM test procedure which

was used by manufacturers to submit data.

4

 EE-RM-94-403 COMMENT 50

factor (EF) for standard compliance. (Reporting of the energy factor (EF) will be kept for voluntary 

programs.) I The above changes should result in a more accurate prediction of actual clothes washer' 

and clothes dryer energy use. .' 

3. ENERGY-USE AND COST ANALYSIS , . , . 

'3.1 Introduction 

A cost and efficiency questionnaire sent to AHAM was responded to by five' AHAM member 

manufacturers, however not every manufacturer.provided'energy-use and cost data for each ,design 

option. considered. AHAM submitted energy usage data based on both the existing DOE test 

procedure and a proposed2 AHAM test procedure. Differences between the proposed AHAM and 

future DOE test procedures'are discussed in Appendix B: 

. 

After LBNL performed· an initial engineering analysis, additional information was requested 

on combinations of design options, particularly for design options that could be used on both verticiil 

and horizontal axis washers. Additional data were desired because inherent design differences 

,between vertical and horizontal axis washers could result in different incremental costs and energy 

savings for a given design option. Certain synergies in cost and, efficiencies, could also result from 

'combiningsoQ'le design options.' The analysis performed was divided into two basic stages;' Phase I 

,and Phase II. Phase I is the analysis of the re~ponses from the initial questionnaire and Phase II 

includes responses from additional ~ata requests (e.g., cOl:nbined design options and further 

disaggregated design options); Data from both Phase I and Phase II were used in the final analysis. 

Where possible, data submitted from Phase II were used. Data from Phase I were used when needed· 

to analyze design options not covered in the Phase II data submittal.' The raw data supplied by 

AHAM are provided in Appendix C; 

3.2 Variability and Uncertainty Analysis 

B.ecause of large differences (in some instances) in cost and energy use data provided by 

manufacturers it is important to analyze the effect of variability and uncertainty in the data used in the . , 

engineering analysis .. 

Variability refers to differences in input values, for example, costs for a design optioft. Even 

if in some cases the manufacturers know how much a design option would cost them to implement, 

these costs may be different among manufacturers. Similarly for fuel costs,aIthough current costs 

, for fuel are known, fuel prices vary among electric or gas utilities.' Uncertainty;is a measure of how 

a data value may vary if the exact value is unknown. For example, although all manufacturers plight 

agree' on the probable cost of a design optiOri, the exaCt cost may be unknown. Parameters with, 

2In this repoI1 "proposed AHAM test pro~edure" refers to an early version of the AHAM test procedure which 

was used by manufacturers to submit data, 

4 

" 
variability and uncertainty applicable to the engineering analysis include manufacturer cost, fuel price,

usage in cycles per year, predicted energy savings, and water price.

To avoid releasing confidential information, AHAM submitted manufacturing costs and

energy usage data as shipment weighted averages. Along with the actual values, information on the

standard deviation of the datawas also provided (see Appendix C). How these data should be used

and whether or not an alternative metric (such as a range of submitted values) can be provided is open for discussion. Differences in how fixed and variable costs were submitted by AHAM may also be

discussed (see Appendix A).

Data were also provided on confidence factors for: cost and investment data, mass production

success, and marketing success. Of these, cost and investment data are directly applicable to the

engineering analysis. Stakeholder input is requested in how to explictly utilize these confidence

factors in the analyses.

One approach to account for variability and uncertainty would be to statistically determine

which input variables have a significant impact on the output of the engineering analysis. This

approach could similarly be used to measure the effect of input paramenter variability on the metrics

used in determining what the appliance standard should be, if one is promulgated. This statistical

approach could also be used to determine the frequency of occurrence of life-cycle cost reduction or

of payback being greater than a specific value. Methods such as the one mentioned above have been

used on other products to determine the affect of variability and uncertainty on consumer impacts (i.e., payback and life-cycle cost). However, these metrics are currently not the subject of the

engineering analysis. In previous rulemakings, sensitivity analyses have been performed by assuming

a high and low value for various data inputs (e.g., electricity price). Sensitivity analyses may be

discussed in the future when doing consumer and national impact analyses.

3.3 Energy-Use

Adjustments had to be made to the data submitted by AHAM because 1) not all manufacturers

provided data for all design options and 2) differences in the proposed AHAM and future (Appendix Jl) DOE test procedures. Test procedure changes included adjustments in: 1) inlet hot water

temperature, 2) TUFs, and 3) dryer usage factor (DUFs). Appendix B details the adjustments made

to the AHAM data.

Cost/savings ratios were calculated for all individual design options (referenced to the

baseline). As depicted in Eq. 1, the cost/savings ratio is the increase in manufacturer cost for a design option divided by the reduction in operating costs due to fuel and water savings.

5

 EE-RM-94-403 COMMENT 50

variability and uncertainty applicable to the engineering analysis include manufacturer cost, fuel price, 

usage in cycles per year, predicted energy savings, and water price. 

To avoid releasing confidential infon:nation, AHAM submitted manufacturing costs and 

energy usage data as shipment weighted averages. Along with the actual values, information on the 

standard deviation of the data/was also provided (see Appendix C). How these data should be used 

and whether or not an alternative metric (such as a range of submitted values) can be provided is open 

for discussion. Differences in how fixed and variable costs were submitted by AHAM may also be 

discussed (see Appendix A). 

Data were also provided on confidence factors for: cost and investment data, mass production 

success, and marketing success. Of these, cost and investment data are directly applicable to the 

engineering analysis. Stakeholder input is requested in how to explictly utilize these confidence 

factors in the analyses. 

One approach to account for variability and uncertainty would be to statistically determine 

which input variables have a significant impact on the output of the engineering analysis. This 

approach could similarly be used to measure the effect of input paramehter variability on the metrics 

used in determining what the appliance standard should be, if one is promulgated. This statistical 

approach could also be used to detennitle the frequency of occurrence of life-cycle cost reduction or 

of payback being greater than a specific value. Methods such as the one mentioned above have been 

used on other products to determine the affect of variability and uncertainty on consumer impacts 

(i.e., payback and life-cy<;le cost). However, these metrics are currently not the subject of the 

engineering analysis. In previous rulemakings, sensitivity analyses have been performed by assuming 

a high and low value for various data inputs (e.g., electricity price). Sensitivity analyses may be 

discussed in the future when doing consumer and national impact analyses 

3.3 Energy-Use 

Adjustments had to be made to the data submitted by AHAM because 1) not all manufacturers 

provided data for all design options and 2) differences in the proposed AHAM and future (Appendix 

]I) DOE test procedures. Test procedure changes included adjustments in: 1) inlet hot water 

temperature, 2) TUFs, and 3) dryer usage factor (DUFs). Appendix Bdetails the adjustments made 

to the AHAM data. ' 

Cost/savings ratios were calculated for all individual design options (referenced to the 

baseline). As depicted in Eq. 1, the cost/savings ratio is the increase in manufacturer cost for a design 

option divided by the reduction in operating costs due to fuel and water savings. 

5 
Cost/Savings Ratio = ACOStmfg ACost ( operating

where ACostmf = Increase in manufacturer cost

ACostowrag = Reduction in annual operating cost

Those design options with very high cost/savings ratios were identified and not combined with

other design options in order to reduce the total number of combinations. Thosenot combined were:

1) added insulation, 2) increased motor efficiency, 3) direct drive motor, and 4) advanced controls.

Individual design options were also combined where possible to determine if greater possible

energy savings were feasible. However, in some instances design options were not considered

compatible with each other. For example, tighter tub tolerance was not combined with lower RMC

options or horizontal axis designs because of greater possible tub deflection at higher spin speeds

(which is one method of achieving lower RMCs). Improved fill control and automatic fill control

were considered two distinct methods of achieving the same goal and were, therefore, not combined

with each other.

Cost/savings ratios were calculated for various combinations of gas and electric water heaters

and clothes dryers. Generally, design options were ranked and combined by lowest cumulative

cost/savings ratio. Operating costs used in determining the savings portion of the cost/savings ratio

were based on a weighted average of both gas and electric water heaters and dryers. The weighted

average operating costs were derived by first calculating the cost in dollars per year required for

heating water and drying clothes for each fuel type separately. Then average dollars per year were

calculated for pairings of gas and electric water heaters, with similar averages calculated for

combinations of gas and electric dryers. An average cost in dollars per year for water heating and

clothes drying is then the sum of the water heater average and the clothes dryer average.

In some instances, other considerations took precedence when ranking design options. An

example involves the horizontal axis and lower RMC designs where the RMC design option should

precede the horizontal axis design option because it has a lower cost/savings ratio. However, since

a horizontal axis machine may affect the cost and performance of adding on a RMC feature.

horizontal axis was placed ahead of it. With regard to combined design options submitted by AHAM

(some were submitted precombined in Phase II), if they had a lower cost/savings ratio than one of

its single design option components, then the single (uncombined) design option was not used.

For some cases, it was not technically correct to simply add individual energy or water savings

to determine the energy and water saved due to combined options. The following procedure was

used in determining hot water energy for the improved fill control, automatic fill control (auto-fill),

and TCMV design options. First, the energy for the individual design option was determined. Next,

6

 EE-RM-94-403 COMMENT 50

Cost/Savings Ratio = 

{)'Cost ,r; mJg 

(),Costoperatlng 

where LlCostmfr 

LlCostoperating 

Increase in manufacturer cost 

Reduction in annual operating cost 

(1) 

Those design options with very high cost/savings ratios were identified and not combined with 

other design options in order to reduce the total number of combinations. Thosenot combined were: 

1) added insulation, 2) increased motor efficiency, 3) direct drive motor, and 4) advanced controls. 

Individual design options were also combined where possible to determine if greater possible 

energy savings were feasible. However, in some instances design options were not considered 

compatible with each other. For example, tighter tub tolerance was not combined with lower RMC 

options or horizontal axis designs because of greater possible tub deflection at higher spin speeds 

(which is one method of achieving lower RMCs). Improved fill control and automatic fill control 

were considered two distinct methods of achieving the same goal and were, therefore, not combined 

with each other. 

Cost/savings ratios were calculated tor various combinations of gas and electric water heaters 

- and clothes dryers. Generally, design options were ranked and combi~ed by lowest cumulative 

cost/savings ratio. Operating costs used in. determining the savings portion of the cost/savings ratio 

were based on a weighted average of both gas and electric water heaters and dryers. The weighted 

average operating costs were derived by first calculating the cost in dollars per year required for 

heating water and drying clothes for each fuel type separately. Then average dollars per year were 

calculated for pairings of gas and electric water heaters, with similar averages calculated for 

combina!ions of gas and electric dryers. An average cost in dollars per year for water heating and 

clothes drying is then the sum of the water heater average and the clothes dryer average. 

In some instances, other considerations took precedence when ranking design options. An 

example involves the horizontal axis and lower RMC designs where the RMC design option should 

precede the horizontal axis design option because it has a lower cost/savings ratio. However, since 

a horizontal axis machine may affect the cost and performance of adding on a RMC feature, 

horizontal axis was placed ahead of it. With regard to combined design options submitted by AHAM 

(some were submitted precombined in Phase- II), if they had a lower cost/savings ratio than one of 

its single design option components, then the single (uncombined) design option was not used. 

. For some cases, it was not technically correct to simply add individual energy or water savings 

to determine the energy and water saved due to combined options. The following procedure was 

used in determining hot water energy for the improved fill cOt;ltrol, automatic fill control (auto-fill), 

and TCMV design options. First, the enerbYJ' for the individual design option was determined. Next, 

6 
the ratio of the individual design option's energy use to the baseline's energy use was calculated. This

ratio was then used to multiply the energy use of the immediately preceding design option to arrive

at the lower energy use for the combined design option. Similarly the above method was used to

determine the reduced water use for improved fill control and auto-fill control design options.

General Assumptions

Table 1 shows the assumptions made in order to carry out the energy-use and energy cost

calculations.

Table 1. General Assumptions

Parameter Value Source

Baseline Clothes Container Volur.e 2.9 cubic feet AHAM [7]

Cycles per Year 392 Future DOE test procedure [8]

Electricity Price 0.083594 $/kWh AEO.1996 [9]

Natural Gas Price 6.075 $/MBtu AEO 1996 [10]

Electricity Price Multiplier 0.90 LBNL

Natural Gas Price Multiplier 1.01 LBNL

Water and Sewage Cost 2.84 $/kgal. Seattle Water 11]

Water Heater Efficiency, Electric:-. 100% Existing DOE Test Procedure 112]

Water Heater Efficiency, Gas 75% Existing DOE Test Procedure [13]

Fraction Electric Water Heaters 0.45 AHAM [ 14

Fraction Gas Water Heaters 0.55 AHAM [15]

Fraction Electric Clothes Drers 0.75 AHAM [16]

Fraction Gas Clothes Dryers 0.25 AHAM [171

Initial Remaining Moisture Conte.: RMC) 62% AHAM [18]

Dryer Usage Factor (DUF) 0.84 Future DOE Test Procedure [19]

Drying Efficiency of Clothes D1re: 0.5 kWh/lb. Future DOE Test Procedure [20]

Gas Dryer Correction Factor (GCF 1.12 See Appendix D

Percentage of Time RMC Option L-sed 75% See Appendix E

It was assumed for this analysis that the clothes load was not a function of clothes container volume.

Appendix F discusses this assumption.

3.4 Costing Data

All incremental manufacturer cost data are based on AHAM-supplied data. Disaggregated

costs are shown in Appendices A and C.

7

 EE-RM-94-403 COMMENT 50

the ratio of the individual design option's energy use to the baseline's energy use was calculated. This 

ratio was then used to multiply the energy use ofthe immediately preceding design option to arrive' 

at the lower energy use for the combined design option. Similarly the above method was used to 

determine the reduced water use for improved fill control and auto-fill control design options. 

General Assumptions 

Table 1 shows the assumptions made in order to carry out the energy-use and energy cost 

calculations. 

Table 1. General Assumptions 

Parameter 

Baseline Clothes Container Volu!.'.;: 

Cycles per Year 

Electricity Price 

Natural Gas Price 

Electricity Price Multiplier 

Natural Gas Price Multiplier 

Water and Sewage Cost 

Water Heatei' EfTiciency. Electncl:~ 

Water Healer EtTiclency, Gas 

FractIOn Electric Water Heaters 

. Fraction Gas Water Heaters 

Fraction Electric Clothes Dryers 

Fraction Gas Clothes Dryers 

Imtial Remaming Moisture Conter.:RMC) 

Dryer Usage Factor (DUF) 

Drying EfTiclency of ClotbesDry,,: 

Gas Drye,' Correction Factor (GCF 

Percentage of Time RMC Option \..' sed 

Value 

2.9 cubic feet 

392 

0.083594 $/kWb 

6.075 $IMBtu 

0.90 

101 

2.84 $/kgal. 

100% 

75% 

0.45 

0.55 

0.75 

0.25 

62% 

0.84 

0.5 kWbllb. 

112 

75% 

Source 

AHAM [7] 

Future DOE test procedure [8] 

AEO .1996 [9] 

AEO 1996 [10] 

LBNL 

LBNL 

Seattle Water [11 J 

Existing DOE Test Procedure [12] 

Existing DOE Test Procedure [13] 

AHAM [14] 

AHAM [IS] 

AHAM [16] 

AHAM [17J 

APu\M [18] 

Future DOE Test Procedure (19J 

Future DOE Test Procedure [20] 

See Appendix D 

See Appendix E 

It was assumed for this analysis that the clothes load was not a function of clothes container volume 

Appendix F discusses this assumption. 

3.4 Costing Data 

AIl incremental manufacturer cost data are based on AHAM-supplied data. Disaggregated 

costs are shown in Appendices A and C. . 

7 
3.5 Energy-Use and Cost Results

The energy use and cost of design options are shown in Table 2.

The analysis was organized to allow maximum flexibility in selecting alternative efficiency

levels for further study. Typically, an engineering analysis is based on arranging combinations of

design options by lowest cumulative cost/savings ratio. Although this was the basic approach used,

where this would limit choices of design options, additional design paths were created. For example,

horizontal axis with recirculation was branched off of the basic horizontal axis path (itself a branch)

to enable analysis of the different RMC options with horizontal axis without recirculation. Table 2

separates the design options into five categories (a,b,c,d,e). They are:

* Category a: Vertical axis with RMC design options;

* Category b: Horizontal axis;

* Category c: Horizontal axis with recirculation;

* Category d: Vertical axis with tighter tub tolerance. This was separated from "category a" on

the assumption that tighter tub tolerance is not compatible with lower RMC achieved by

increasing the spin speed; and

* Category e: Options not analyzed in combination with other design options.

The cost/efficiency relationship of the design options in Table 2 is shown graphically in Figure 1.

8

 EE-RM-94-403 COMMENT 50

3.5 Energy-Use and Cost Results 

The energy use and cost of design options are shown in Table 2. 

The analysis was organized to allow maximum flexibility in selecting alternative efficiency 

levels for further study. Typically, an engineering analysis is based on arranging combinations of 

design options by lowest cumulative cost/savings ratio. Although this was the basic approach used, 

where this would limit choices of design options, additional design paths were created. For example, 

horizontal axis with recirculation was branched off of the basic horizontal axis path (itself a branch) 

to enable analysis of the different RMC options with horizontal axis without recirculation. Table 2 

separates the design options into five categories (a,b,c,d,e). They are: 

• Category a: Vertical axis with RMC design options; 

• Category b: Horizontal axis; 

• Category c: Horizontal axis with recirculation; 

• Category d: Vertical axis with tighter tub tolerance. This was separated from "category a" on 

the assumption that tighter tub tolerance is not compatible with lower RMG achieved by 

increasing the spin speed; and 

• Category e: Options not analyzed in combination witn other design options. 

The cost/efficiency relationship of the design options in Table 2 is shown graphically in Figure 1. , . 

8 
Table 2. Standard Clothes Washer: Cost, Energy-Use, and Water-Use Data

Incr. Total Energy-Use Water Use Annual Annul Anal Cost/

Mfr. NMfr. I Io Total Total w/ I'ercenll Total Energy Water Operating Savings

Cost Cost' Water Mahl.' Washer D)rver' I)Drer Improv.' MIEFs allons WCFI'' Consumption' Consumption' Expense' Ratio'

No. Design Option 1994$ 1994$S klh/cwc kWI'hc'c kWl'h,'cvc k7ll'lcc klf'trX'cv % ftkf'f1h sgal/cvc .l/ft' klWh/r eallons/vr 1994S vears

0) laseline (vertical axis) - 225 1.554 0.220 771 1 53.1 3.306 0.885 38.92 13.3 1296 15257 117

la 0 1 50%oRMC 9.60 235 1 554 0.226 1 780 1.295 3.074 7.0 0.952 38.92 13.3 1205 15257 112 1.7

2a la Auto Fill 4 TCMV 39.78 275 1.339 0.226 1.565 1.295 2.860 13.5 1.024 35.23 12.0 1121 13810 103 3.6

3a la 4Improved Fill 11.58 246 1.436 0.226 1.662 1.295 2.957 10.6 (.990 36.77 12.6 1159 14415 107 2.1

4 la4 a 0%RMC 8.52 243 1.554 0.234 1.788 1.097 2.884 12.8 1.015 38.92 13.3 1131 15257 107 1.8

5a 4a + Auto Fill -TCMV 40.21 284 ' 1.339 0.232 1.571 1.097 2.667 19.3 1.097 35.23 12.0 1046 13810 99 3.1

6a 4a+ .mprovedFill ... 11.58 255 1.436 0.232 1.668 1.097 2.765 16.4 1.059 36.77 12.6 1084 14415 102 2.0

lb Horizontal Axis 1 101.57 327 0.461 0.193 0.654 1.533 2.187 33.9 1.265 25.73 9.3 857 10086 i 81 2.8

2b 11) 4 Auto Fill 34.15 361 0.423 0.193 0.616 1.533 2.149 35.0 1.287 25.00 9.0 842 9800 79 3.6

3b lb + 50% RMC 8.66 336 0.461 0.204 .0.665 1.295 1.960 40.7 1.411 25.73 9.3 768 10086 75 2.6

4b 3b+TCMV . 8.16 344 0450 0.204 0.654 1.295 1.949 41.1 1.419 25.73 9.3 764 10086 75 2.8

51) 4b+ Auto Fill 31.62 375 0.397 0.204 0.601 1.295 1.896 42.7 1.459 25.01 9.0 743 9804 73 3.4

6b 3b 40%RMC 7.49- 343 0.461 0.209 0.670 1.097 1.767 46.6 1.566' 25.73 9.3 693 10086 70 2.5

7b 6b t TCMV 8.16 351 0.450 0.209 0.659 1.097 1.756 46.9 1.575 25.73 9.3 688 10086 70 2.7

8b 7b + Auto Fill _ 32.05 383 0.397 0.209 0.606 1.097 1.703 48.5 1.624 25.01 9.0 668 9804 68 3.2

Ic Horizontal Axis 101.57 327 0.461 0.193 0.654 1.533 2.187 33 9 1.265 25.73 93 857 10086 81 2.8

2c lc + Horz. Axis w/recirc. 3.28 330 0.371 0 202 0.573 1.533 2.106 36.3 1299 21.78 8.0 825 8539 75 2.5

3c 2c - 50% RMC 8.66 339 0 371 0.213 0.584 1.295 1.879 43.2 1.456 21.78 8.0 736 8539 69 2.4

4c 3c t 40/oRMC 7.49 346 . 0.371 0.218 0.589 1.097 1.685 49.0 1.623 21.78 8.0 661 8539 65 2.3

Id 0 + TighterTub 7.09 232 1.461 0.220 1.681 1.533 3214 28 0911 36.05 12.3 1260 14131 112 1.4

2d Id4 Improved Fill 11.58 244 ' 1.350 0.220 1.570 1.533 3.103 6.1 0.943 34.07 11.6 1216 13354 108 2.0

3d 2d i TCMV 8.16 252 1.318 0.220 1.538 1.533. 3.071 7.1 0.953 34.07 11.6 1204 13354 107 2.7

4d Id t TCMV 8.16 241 1.426 0.220 1.646 1.533 3.179 3.9 0.921 36.05 12.3 1246 14131 112 2.7

5d 4d t Auto Fill 31.62 272 1.259 0.220 1.479 1.533 3.012 8.9 0.972 32.63 11.1 1181 12791 104 3.7

6d ld+ Auto Fill .34.15 267 1.293 0.220 1.513 1.533 3.046 7.9 0.961 32.63 11.1 1194 12791 105 3.4

le 0 + Incr MotorEfficiency 9.51 235 1.554 0.200 1.754 1.533 3.286 0.6 0.891 38.92 13.3 1288 15257 117 16.1

2e 0 + Direct Drive Motor 70.88 296 1 554 0.086 1.64(1 1.533 3.172 4.1 0.923 38.92 13.3 1244 15257 113 17.9

3e 0 + Advanced Controls 60.75 286 1541 0.220 1.761 1.533 3.294 0.4 0.889 38.92 13.3 1291 15257 117 254.0

4e 0 + Added Insulation 48.77 274 1.554 0.220 1.774 1.533 3.306 0.0 0.885 38.92 13.3 1296 15257 117 N/A

Dollar values are shown in rounded dollars; actual values as provided by AH-AM are used in all calculations.

Machine Energy tUse.

Dryer Energy Use (D,) based on 62% initial moisture content I)1 IF (the ratio ofdryer cyclcs to clothes washer cvcles per vear) 0.84 (See Appendix E).

Percent Improvemlent over tle baseline total with dryer energy use.

Clothes Container Volume: Vertical Axis Designs = 2.927 t'. Ilorizontal Axis Designs - 2.766 i. I lorz. with Rccirculation Designs 2.736 fl'; same clothes load capacity is assumed for all design

options for purposes of calculating energy use..

W CF - Water Consumption Factor.

Annual IEnergy Consumption is equal to the total (with dryer) energy per cycle multiplied 1v .192 cycles / vr

Annual Water Consumption is equal to the total gallons per cycle multiplied b! 392 cycles / yr

Cumulative annual operating cost (based on combined electric. gas water heaters and drvers).

0 Cost/Savings Ratio - (Change in manufacturer cost relative to baselinc) - (Change in alnnuall energy & waltr c.,sl rclalivc o baseline): (based on combined electric/ga ater .s eat and drers).

9

 EE-RM-94-403 COMMENT 50

Table 2. Standard Clothes Washer: Cost, Energy-Use, and Water:Use Data 

Incr. 

Mfr. 

Cost 

1994$ 

Total 

Mf,·. 

Cos" 

199-1$ 

II", 

Wa'cr-

. Enc'·~~'·Use 

To'al To.alwi I'",..-"nl 

No. 

o 

I a 

2a 

3a 

4a 

5a 

6a 

Ib 

2h 

3h 

4b 

5h 

6b 

7b 

8b 

Ic 

2c 

3c 

4c 

ld 

2d 

3d 

4d 

Sd 

Design Option 

Ilasdirw (vertical axis) 

0'1 500 ;, RMC 

I a , Auto Fill" TCMV 

I a " Improved Fi II 

la + 40% I~MC 

4a + Auto Fill + TCMV 

~a+ ImprovedFill 

Horizontal A'(is 

Ih \ Auto Fill 

Ih + 50%RMC 

3b + TCMV 

4b + Auto Fill 

3b t 40%RMC 

6b f TCMV 

7b + Auto Fill 

Horizontal Axis 

1c t Horz. Axis w/recirc. 

2c'\ 50% RMC 

3c t 40%RMC 

o + Tighter Tub 

I d + Improved Fill 

2dl TCMV 

Id + TCMV 

4d \ Alrto Fill 

9.60 

39.78 

11.58 

8.52 

40.21 

11.58 

101.57 

34.15 

8.66 

8.16 

31.62 

7.49 

8.16 

32.05 

101.57 

3.28 

8.66 

7.49 

7.09 

11.58 

8.16 

8.16 

31.62 

225 

215 

275 

. klrh1c\'c 

1'i5~ 

I 554 

I.D9 

246 1.436 

243 1.554 

284 I 1.339 

255 

327 

361 

1.436 

0.461 

0.423 

336 0.461 

344 0.450 

375 OJ97 

343 0.461 

351 0.450 

383 0.397 

327 0.461 

330 (U7I 

339 0371 

346 0.]71 

232 1.461 

244 ' usa 

252 1318 

241 1.426 

272 1.259 

Mal'll.' \Yashu 

kWh-GTC kHn/c\'c 

, 

0.220 • I 77·1 

0.226 1 7XO 

0.226 1.5(,) 

0.226 

0.234 

0.232 

0.232 

0.193 

0.193 

0.204 

0.204 

0.204 

0.209 

0.209 

0.209 

0193 

0202 

0.213 

0.7.[ X 

0.220 

0.220 

0.220 

0220 

0.220 

1.662 

1.788 

1.57 1 

1.668 

0.654 

0.61(; 

0.665 

0.654 

0.601 

0.670 

0.65'} 

'0606 

0.65·1 

0.573 

0.584 

(U89 

1.68] 

1.570 

1.538 

1.646 

1.479 

D .. y .... ' DI)'('" 

kWh'erc kil'n!GTc 

I. '1 ~ 3.306 

1.295 1.074 

1.295 2.860 

1.295 2.957 

1.097 2.884 

1.097 2.667 

1.097 

1.533 

1.533 

1.295 

1.295 

1.295 

1.097 

1.097 

1.097 

1.513 

1513 

1.295 

1.097 

1.'iT1 

1.5:13 

I5D 

1.533 

1.533 

2.765 

2.187 

2.149 

1.960 

1.949 

1.8% 

1.767 

1.756 

1.703 

2.)87 

2.)06 

1.879 

1.685 

3.214 

3.)03 

3.071 

3.)79 

3.012 

6d Id + Auto Fill 34.15 267 1.293 0.220 15 J3 1533 ~.046 

Ie 0 + Iner Motor Efficiency 9.51 235 1.554 0.200 ) .754 1.533 3.286 

2c 0 + Direct Drive Motor 70.88 296 I 554 0.086 1.640 1.533 3. I 72 

3e 0 t Advanced Controls 60.75 286 I 541 0.220 1. 761 1.533 3.294 

4e 0 + Added Insulation 48.77 274 I.S54 0.220 1.774 1.533 3.306 

I Dollar values are ShO\\11 in rounded dollars; actual values as provided by AJiAM are us<~d in all calculations. 

1 Machine Energy Usc. 

Imp""" .• 

% 

70 

1'-5 

10.6 

12.8 

19.3 

16.4 

33.9 

35.0 

40.7 

4L1 

42.7 

46.6 

46.9 

4R.5 

.13.9 

:1(,.3 

4:\.2 

~9.0 

]X 

6.1 

7.1 

3.9 

8.9 

7.9 

0.6 

4.1 

0.4 

0.0 

I\/EF' 

(i',kWh 

0.885 

0.952 

1.024 

0.990 

1015 

1.097 

1.059 

1.265 

1.287 

1.411 

1.419 

1.459 

1566 

1.575 

1.624 

1.265 

1299 

1.456 

1.623 

0'>11 

0.943 

0.953 

0.921 

0.972 

0.961 

0.891 

0.923 

0.889 

0.885 

Water US(' 

To.al 

Gallons 

gallc\'c 

38.92 

.18.92 

35.23 

36.77 

38.92 

35.23 

36.77 

25.73 

25.00 

25.73 

25.73 

25.01 

25.73 

25.73 

25.01 

25.73 

21.7R 

21.78 

21.7R 

36.05 

34.07 

34.07 

36.05 

32.63 

32.63 

38.92 

38.92 

38.92 

38.92 

WCF' 

.gllf.'(i' 

LLl 

LI.l 

12.0 

12.6 

13.3 

12.0 

12.6 

9.3 

9.0 

9.3 

9.3 

9.0 

9.3 

9.3 

9.0 

9.3 

8.0 

8.0 

8.0 

123 

11.6 

11.6 

12.3 

IJ.J 

IJ.J 

13.3 

13.3 

13.3 

13.3 

) Dryer Energy Use (D,) based on 62% initial moisture content DIll' (the ratio of dryer cycks to cIotlh:s waslll:r cvdes per war) ~ 0.84 (Sec Appcndix E). 

J Percent Improvcrllcnt ovcr the baseline total with dryer cncrgy Usc. . 

Annual 

Energ~' 

Annual 

\VlIter 

Annual Cost! 

Operating Savings 

Consump.lon' ! ConslUnption' Expense' 

1994$ 

Ratio" 

kWhlvr gal/ons/vr vears 

)296 15257 117 

112 

103 

1205 

1121 

1159 

1131 

1046 

15257 

13810 

14415 

15257 

13810 

107 

107 

99 

1.7 

3.6 

2.1 

1.8 

3.1 

1084 .. __ ...... 1-,14_15 __ . ___ 10_2 ___ ... __ 2_.Q_ .. . 

857 

842 

7~8 

764 

743 

693 

688 

668 

857 

825 

736 

661 

1260 

1216 

1204 

1246 

1181 

1194 

1288 

1244 

1291 

1296 

10086 

9800 

81 

79 

2.8 

3.6 

10086 75 2.6 

10086 75 2.8 

9804 73 3.4 

10086 70 2.5 

10086 70 2.7 

9804 68 3.2 .. _------ - ------_ ... _- - .. "-

10086 81 2.8 

8539 75 2.5 

8539 69 2.4 

8539 65 2.3 

14131 112 1.4 

13354 108 2.0 

13354 107 2.7 

14131 112 2.7 

12791 104 3.7 

12791 __ , __ .!Q1._ 

15257 

15257 

15257 

15257 

117 

113 

117 

117 

3.4 

16.1 

17.9 

254.0 

N/A 

5 Clothes Container Volume: Vertical Axis Designs = 2.927 fl', Horizontal Axi~, Designs' 2.766 W, 11017. with Recirculation Dcsigns ~ 2.73611'-, same clothes load capacity is assumed for all design 

options for purposes of calculating energy use .. 

6 \VCF - Water Consumption Factor. 

Annual Energy Consumption is equal to the total (with dryer) l'nerg) per cycle Illultiplied hv .1<)2 cycles / \T 

S Annual Water Consumption is equal to the total gallons per cYCle Illultiplied In 392 cycles / yr 

o Cumulative annual operating cost (based on combined electric.gas wafer hcakrs and drwrs). 

10 Cost/Savings Ratio' (Change in manufacturer cost relative to I""dine) " (Chang<: 111 annual energy & wakr <",,' r:dalrw III haseline): (hased on comhineci ~Iedric/gas water heaters and dryers). 

9 
Headings used in Table 2 are described below.

Incremental Manufacturer Cost. This is the cost that would be incurred if the design option were

required to meet a minimum efficiency standard and would therefore be mass-produced approximately

at the same level as current production levels. For this reason some prices for models, such as

horizontal axis washers, would be substantially lower than those currently on the market due to

economies of scale. These values are based on data provided by AHAM.

TotalManufacturer Cost. This cost is determined by adding a design option incremental cost to the

total manufacturer cost of the previous design option.

Hot Water Energy Use. This is the energy content of the hot water supplied by the water heater

external to the washing machine.

Machine Energy Use. This is the electrical energy input to the washer during a washer test cycle.

Total Washer Energy Use. This is the sum of the hot water and machine energy use.

Dryer Energy Use. This is the amount of energy needed to complete the drying of the test load in

a clothes dryer after the final spin cycle.

Total Energy Use with Dlyer. This is the sum of hot water energy, machine energy, and dryer energy

use.

Percent Improvement. This is the percent reduction in washer energy use (including dryer energy)

over the baseline case.

Modified Energy Factor (MFF). This is the ratio of washer volume in cubic feet to total energy

where the total energy includes the dryer (moisture removal) energy. MEF differs from EF in that

the energy needed to dry clothes, after a spin cycle, is added to the total energy use. MEF is given

in units of cubic feet per kWh per cycle The following equation demonstrates how MEF is

calculated.

MEF-=~MEF -r= Clothes Container VolWume

Hot Water Energy + Mechanical ergyrgy + Dyer Energy ()

Total Gallons. This is the total amount of water used per cycle, both hot and cold.

Water Consumption Factor (WCF). This is the total gallons of water used in a test cycle divided by

the clothes container volume in cubic feet.

10

 EE-RM-94-403 COMMENT 50

" 

Headings used in Table 2 are described below. 

Incremental Manufacturer Cost. This is the cost tnat would be incurred if the design option were 

required to meet a minimum efficiency standard and w~>uld therefore be mass-produced approximately 

at the same level as current production levels. For this reason some prices formodels,such as 

horizontal axis washers, would be slibstantiallylower than those curr~ntIy on the market due to . 

. economies of scale. These v(ilues are based on data provided by AHAM. 

Total Manufacturer Cost. This cost is determined by adding a design option incremental cost to the 

" total manufacturer cost of the prevIOus ~esign option. . 

, '. ',' 

Hot Water Energy Use. This is the energy con~ent of the hot water supplied by the water· heater 

external to the washing machine. . 

Machine Energy Use. This isthe electrical energy input to the 'washer during a washer test cycle. 

Total Washer Energy Use. This is the sum of the hot water and machine energy use. 

" Dryer Energy Use . . This is the a~ountof energy needed to complete the drying ofthetest load in 

a clothes dryer after the final spin cycle. 

Total Energy Use ~tJilhDlyer. 'This is the sum of hot water energy, machine energy, and dryer energy 

use. 

Percent ImprolJemel11. This is the percent reduction in washer energy use (including dryer energy) 

over the baseline case. 

Modified Energy FaCIOI' (M~r). This is the ratio of washer volume in cubic feet to total energy 

where the total energy includes the dryer (moisture removal) energy. MEF differs fromEF in that 

the energy needed to dry clothes, after a spin cycle, is added to the total energy use. MEF is given 

in units' of cubic feet per kWh per cycle. The following equation demonstrates how MEFis 

calculated. .... 

MEF" = . Clothes Contafner Volume. 

. Hot Water Energy + ,Mechanical Energy + DJyer Energy (2) 

Total Galions. This is the total amount of water used per cycle, both hot and cold. 

Water ConsumptionFactor (WCF). This is the total gallons of water used in a test cycle divided by 

the clothes container volume in cubic feet. . . 

10 

"; ," 
Annual Energy Consumption. This is total washer and dryer energy usage in kWh for an entire year

based on 392 clothes washer cycles per year.

Annual Water Consumption. This is the total water consumption in gallons (both hot and cold) in

an entire year based on 392 clothes washer cycles per year.

Annual OperatingExpense. This is cost in fuel and water to run a washing machine for one year plus

the cost to dry the clothes as well. The dollar amount is reported in 1994 dollars.

Cost/Savings Ratio. This ratio describes the increase in manufacturer cost for one or more design

options relative to the savings in annual operating expense.

S400

S380 1

5b

,2b ,

4b - o

N l

Ib - 3b' 

S320 -

id

L S26 -

2 S40 -

S220 -

S200 -_ _:______ __ __

(L8 09 1.0 1.1 1.2 13 1.4 1.5 1.6 1.7

Modified Energy Factor (cubic feet / kWh)

Figure 1. Manufacturer Cost vs. Modified Energy Factor

11

\~~~~~~6

 EE-RM-94-403 COMMENT 50

Annual Energy Consumption. This is total washer and dryer energy usage in kWh for an entire year 

based on 392 clothes washer cycles per year. 

Annual Water Consumption. This is the total water consumption in gallons (both hot and cold) in 

an entire year based on 392 clothes washer cycles per year. 

Annual Operating Expense. This is cost in fuel and water to run a washing machine for one year plus 

the cost to dry the clothes as well. The dollar amount is reported in 1994 dollars. 

Cost/Savings Ratio. This ratio describes the increase in manufacturer cost for one or more design 

options relative to the savings in annual operating expense. 

$-1001 

i 

S3ffi i 

I 

2b 0 

5bp 

7b Cl' 

-- 5320 -

= .~ 

:; S260 c 

$110 - o 

$200 

0.8 0.9 1.0 1.1 1.2 \.3 1.4 1.5 1.6 1.7 

'fodified Energy Factor (cubic feet / kWh) 

Figure 1. :\lanufacturer Cost vs. Modified Energy Factor 

11 
4. MAXIMUM TECHNOLOGICALLY FEASIBLE DESIGN

The maximum technological feasible design based on energy use per cycle is a horizontal axis

washer with recirculation and a RMC of 40%. This design would reduce total laundry energy

consumption (for both washing and drying) by 49.0% and washing energy alone by 66.8%. The MEF

for this design is 1.62.

12

 EE-RM-94-403 COMMENT 50

4. MAXIMUM TECHNOLOGICALLY FEASmLE DESIGN 

The maximum technological feasible design based on energy use per cycle is a horizontal axis 

washer with recirculation and a RMC of 40%. This design would reduce total laundry energy 

consumption (for both washing and drying) by 49.0% and washing energy alone by 66.8%. The MEF 

for this design is 1.62. . 

12 
REFERENCES

1. U.S. Department of Energy (DOE). 1996a. Draft Report on Design Options for Clothes

Washers, October 1996.

2. U.S. DOE. 1996b. Procedures, Interpretations and Policies for Consideration of New or

Revised Energy Conservation Standards for Consumer Products; Final Rule. Federal

Register Vol. 61, No. 136, Appendix A to Subpart C of Part 430 -- July 15, 1996.

3. U.S. DOE. 1996c. Energy Conservation Program for Consumer Products: Test Procedure

for Clothes Washers tld Reporting Requirement for Clothes Washers, Clothes Dryers, and

Dishwashers. (61 Federal Register 17589, April 22, 1996.), 10CFR, Part 430, Appendices

J & J1, Docket No. EE-RM-94-230A.

4. U.S. Office of the Federal Register. 1994. Code of Federal Regulations, Title 10, Appendix

J to Subpart B or Pan 430 -- Uniform Test Methodfor Measuring the Energy Consumption

of Automatic and Semi-automatic Clothes Washers, January 1, 1994.

5. U.S. Office of the Federal Register. 1995. Code of Federal Regulations, Title 10, Part 430,

Vol. 60, No. 56, p. 15335, Proposed Rules. -March 23, 1995.

6. U.S. DOE. 1996c. Op. cit.

7. Association of Home Appliance Manufacturers (AHAM). 1995a. Comments on the Advance

Notice of Proposed Rlulenaking. DOE Docket No. EE RM-94-403. comment #27, May 8.

1995.

8. U.S. DOE. 1996c. (Op. cit.

9. U.S. DOE, Energy Information Administration 1996. Annual Energy Outlook 1996 with

Projections to 2015 Washington, D.C., DOE/EIA-0383(96), January.

10. Ibid.

11. Seattle Water, Commentls on the Aahdance Notice of Proposed Rulemaking, DOE Docket No

EE RM-94-403, comment #29, May 8, 1995

12. U.S. Office of the Federal Register. 1994. Op. cit.

13. Ibid.

14. AHAM. 1995a. Op. cit.

15. Ibid.

13

 EE-RM-94-403 COMMENT 50

REFERENCES 

1. U.S. Department of Energy (DOE). 1996a. Draft Report on Design Optionsfor Clothes 

Washers, October 1996. 

2. U.S. DOE. 1996b. Procedures, Interpretations and Policies for Consideration of New or 

Revised Energy Conservation Standards for Consumer Products; Final Rule. Federal 

Register Vol. 61, No. l36, Appendix A to Subpart C of Part 430 -- July 15,1996. 

3. US. DOE. 1996c. Energy Conservation Programfor Consumer Products: Test Procedure 

for Clothes Washersand Reporting Requirementfor Clothes Washers, Clothes Dlyers, and 

Dishwashers. (61 Federal Register 17589, April 22, 1996.), 10CFR, Part 430, Appendices 

J & 11, Docket No EE-RM-94-230A 

4. US. Office of the Federal Register. 1994. Code of Federal Regulations, Title 10, Appendix 

J to Subpart B or Pan 430 -- Uniform Test Method for Measuring the Energy Consumption 

of Automatic and St?mi-automatic Clothes WasIJers, January 1, 1994. 

5. US. Office of the Federal Register. 1995. Code of Federal Regulations, Title 10, Part 430, 

Vol. 60, No. 56, p. 15335, Proposed Rules, March 23, 1995. 

6. U.S. DOE. 1996c. ()p. cit. 

7. Association of Home .--\ppliance Manufacturers (AHAM). 1995a. Comments on/he Advance 

Notice of Proposed Rulemaking. DOE Docket No. EE RM-94-403, comment #27, May 8, 

1995. 

8 U.S DOE. 1996c. OD. cit. 

9. U.S. DOE, Energy Information Administration 1996. Annual Energy OUllook 1996 )t'ith 

Projections 10 2015 Washington, D.C, DOEIEIA-0383(96), January 

10. IbId. 

11. Seattle Water, Commt!J1ls 011 the Advance Notice qf Proposed Rulemaking. DOE Docket No 

EE RM-94-403, cornment #29, May 8, 1995 

12. US. Office of the F edefal Register. 1994. Op. ci I. 

13 Ibid. 

14. AHAM. 1995a. Op. cil. 

15. Ibid. 

13 
16. AHAM. 1995b. Comments on the Advance Notice of Proposed Rulemaking. DOE Docket

No. EE RM-94-403, comment #37, June 27, 1995.

17. Ibid.

18. AHAM. 1995a. Op. cit.

19. U.S. DOE. 1996c. Op. cit.

20. Ibid.

14

'*~ ~ ~ . . ! * ' - * * „ - * ! 1

^ . . : ' ' ' .

 EE-RM-94-403 COMMENT 50

, . 

16. '. AHAM. 1995b .. Comments on the Advance Noticeo! Proposed Rulemaking. DOE Docket 

No. EE RM-94-403, comment #37, June 27, 1995. 

17. Ibid 

18. AHAM. 1995a. Op. cit . 

. 19. 'U.S. DOE. 1996c; Op. cit. 

20. Ibid 

14 
APPENDIX A. DISAGGREGATED MANUFACTURER COST DATA

Table A. 1 shows the manufacturer costs for standard clothes washers by design option. The

cost data provided by AHAM are disaggregated into variable and fixed costs. The AHAM variable

cost data were supplied as per unit costs and were disaggregated into the following three categories: material/parts, labor, and shipping. The AHAM fixed cost data, not supplied on a.per unit basis',

were disaggregated into the following three categories: tooling, capital costs, and other. AHAM also

provided a total per unit incremental manufacturer cost for each design option.

The columns labeled "Total Variable" and "Total Fixed" in Table A. 1 were derived by LBNL

and represent the per unit cost for each design option. The total per unit fixed cost was determined

by subtracting the total per unit variable cost from the total incremental manufacturer cost.

This was due to AHAM's need to keep the data confidential and also from complications arising fiom how the

data was collected.

A-1

 EE-RM-94-403 COMMENT 50

APPENDIX A. DISAGGREGATED MANUFACTURER COST DATA 

Table Al shows the manufacturer costs for standard clothes washers by design option. The 

cost data provided by AHAM are disaggregated into variable and fixed costs. The AHAM variable 

cost data were supplied as per unit costs and were disaggregated into the following three categories: 

material/parts, labor, and shipping. The AHAM fixed cost data, not supplied on a per unit basisl, 

were disaggregated into the following three categories: tooling, capital costs, and other. AHAM also 

provided a total per unit incremental manufacturer cost for each design option. 

The columns labeled "Total Variable" and "Total Fixed" in Table Al were derived by LBNL 

and represent the per unit cost for. each design option. The total per unit fixed cost was determined 

by subtracting the total per unit variable cost from the total incremental manufacturer cost. 

IThis was due to AHAM's need to keep the data confidential and also from complications arising from how the 

data \\·as collected. 

A-I 
Table A.1 Disaggregated Cost of Efficiency Improvements for Standard Clothes Washers

Design Design Option Variable Costs Fixed Costs ' Incremn. Total

No. Costs per Unit _ Costs (in Thousands) Per Unit per Unit Mfg.

Material/Parts Labor Shipping Total Tooling Capital Other Total Mfg. Cost

Variable Costs ' Fixed ' Costs

1994$ 1994$ 1994$ 1994$ 1994S 1994S 1994$ 1994$ 1994$ 1994S

0 Baseline (Vert. Axis) 225

la RMC = 50% 4.50 0.31 0.00 4.81 35843 14950 2474 4.79 9.60 235

2a la + Auto Fil, TCMV 34.93 1L49 0.00 36.42 69009 .27745 14581 3.36 39.78 275

3a a + Improved Fill Control 10.98 0.55 0.00 11.53 139 0 124 0.05 11.58 246

4a la, RMC=40% 7.82. 0.01 0.00 7.83 41437 17618 '3658 0.69 8.52 243

5a 4a - Auto Fill, TCMV 35.28 1.49 0.00 36.77 75170 30744 15824 3.44 40.21 284

6a 4a - Improved Fill Control 10.98 0.55 0.00 11.53 139 0 124 005 11.58 25-

lb Horizontal Axis Design 67.98 8.24 056 7678 86852 125690 15717 2479 10157 32

2b lb* AutoFill 3012 1.24 0.00 31 36 97957 143847 17038 279 34 15 361

3b lb- 50% RMC 7.70 0.!7 06 7.93 97089 143588 16626 0.73 866 336

4b 3b -TC4MV 7.70 0.33 0.00 803 0.13 816 344

5b 4b- Auto Fill 27.23 085 0 00 28.08 3.54 31.62 375

6b 3b 40% RMC 6.90 0.00 0.00 6 90 103056 146564 19619 0.59 7.49 343

7b 6b- TCMV 7.70 0.33 0.00 8.03 0.13 816 351

8b 7b - Auto Fill 2758 1.15 000 28 73 3.32 32 05 383

Ic Horizontal Axis Design 67.98 8.24 056 i 7678 86852 125690 15717 24.79 101.57 327 2c Ic- Horz Axis w'recirc 328 0o.0 I 0.00 32 95728 134844 21727 000 32S 330

3c 2c - 50(, RMC 7.70 0.17 0.06 793 97089 14358S 16626 0.7. 8 66 339

4c 3c - 40% RM.C 6.90 000 0.00 6.90 103056 146564 19619 0.59 7.49 346

Id 0- Tighter Tub Tolerance 4.61 0.22 000 4 83 15239 17137 836 2 2 7 -9 232

2d id - Improved Fill Control 10.9S 055 000 : 53 139 0 i24 00 It 5 24a

3d '2d- TCXi!V 77 03 03 0 S0 i Si ;5

4d id - TCMV . 7.70 033 | 00 5 03 013 8 i(- 24

5d 4d-AutoFili .27.23 116 000 2839 8 323 316- 272

6a 1id- Auto Fill _3012 1!.2 0. O1O.36 29719| 11769 6061 2 79 34 i 267

le 0-Increase Motor Efficiency 8.78 007 j 0.0 0 8. 3043 2678 1373 066 o9. 2

2e 0-Direct Drive Motor 68.87 0.74 0 0.0 i 9.61 617 8528 4353 i27 70 8S 296

3e 10-Advanced Controls 5498 1 .24 000 ' 522 45668 15131 16068 453 60 7 286

4e |0-Added insulation 43.22 0[9. :9 00 -4.1 2 58226 45 8662 465 4877 274

Assumes a five-year regulatolr life.

Includes production machinery, plant upgrade, and/or expansion

Includes R&D, product certification, and administrative overhead

Fixed costs = total costs - variable costs.

A-2

 EE-RM-94-403 COMMENT 50

Table A.I Disaggregated Cost of Efficiency Improvements for Standard Clothes Washers 

Design 

No. 

0 

la 

2a 

3a 

4a 

Sa 

6a 

lb 

2b 

3b 

4b 

5b 

6b 

7b 

8b 

1 c 

2c 

3c 

4( 

Id 

2d 

30 

4d 

50 

6c 

1 t 

2e 

3e 

4(-

Design 0 plion Variable Costs Fixed Costs I 

Costs per Unit Costs (in Thousands) 

MateriallParts Labor Shipping Total Tooling 

Variable 

1994$ 1994$ 1994$ 1994$ 1994$ 

Baseline (Vert. Axis) 

RMC = 50% 4.50 0.31 0.00 4.81 35843 

la '+- Auto Fiil, TCMV 34.93 lA9 0.00 36.42 69009 

1 a + Improved Fill Control 10.98 0.55 0.00 11.53 139 

18'" RMC = 40% 7.82 . 0.01 0.00 7,83 41437 

4a + Auto Fill, TCMV 35.28 1.49 0.00 36.1'7 75170 

4a + Improved Fill Control 10.98 . 0.55 0.00 11.53 139 

Horizontal Axis Design 67.98 8.24 0.56 7678 86852 

Ib ... Auto Fill 30.12 /.24 0.00 I 31 3"6 97957 

Ib + 50% RMC 7.70 0.17 0.06 I 7.93 97089 

3b -TCMV 7.70 {)33 0.00 I 803 

4b- Auto Fill 27.23 085 000 I 28.08 1 

I 

3b'" 40% RMC 6.90 0.00 0.00 690 103056 

6b + TCMV 7.70 0.33 0.00 803 

7b'" Auto Fill 2758 1.15 0.00 28 73 

Horizontal Axis Design 67.98 8.24 I 056 I 76.78 86852 

lc ~ Horz AXIS \\.'/recirc. 3 28 () 0(, I O.no I ) ~8 957~8 

2e + SO' 0 Rl\·fC 7.70 O. !7 I 0.06 I 793 97089 

3e - 40~o RMC 6.90 O.(Hj 0.00 6.90 103056 

0- Tighter Tub Tolerance 4.61 n ,- \ .-~ 0.00 .j 83 15239 

1d - Impro"cd F ill Control 10.% 0« 000 ~ 1 53 j 39 

l~d - TC\<\' 770 :').3 : (1")(; ~.(Jj 

lid - TCd\'. 7.70 I C.33 OOG S.03 

I"d + Auto Fill ~7.:!:; I 1 16 000 28.39 

! id - .'-uto Fill 3012 I !.:~ 0.00 i :.) .36 29719 

I ~J-1ncrease Motor Eflielenc," 8.78 

I 

0.07 0.0(, : ;; 8~ 30 .. .1.3 

I I)-Direct DrIve t>.1otor 68.87 0.74 0.00 :59.6J S6I7 

I:J-.".d\'anced Control, 549S ' " U 00 i 56.22 45668 1. __ 

O-Added Insulation 43.2: I :) 9(; (100 ~.!2 58226 

, A~sume,; a five-year regulatory life. 

, Includes production machinery, plant upgrade, and/or expansion 

) Includes R&D, product certification, and administrative overhead. 

" Fixed costs = total costs - variable cosis. 

Capital Other' 

Costs , 

1994$ 1994$ 

14950 2474 

27745 14581 

0 124 

17618 . 3658 

30744 15824 

0 124 

125690 15717 

143847 17038 

143588 16626 

146564 19619 

125690 15717 

134844 21727 

14358~ 16626 

146564 19619 

17137 836 

(i i24 

1 

I 

I 11769 6061 

I 2678 1373 

852S ,,353 

I J 51 31 1606S 

I 4' 8662 

Increm. 

Per Unit per Unit 

Total Mfg. 

Fixed' Costs 

1994$ 1994$ 

4.79 9.60 

3.36 39.78 

0.05 11.58 

0.69 8.52 

3.44 40.21 

0.05 11.58 

2479 101.57 

:: 79 34 1< 

073 8.66 

0.13 8.16 

3.54 31.62 

0.59 749 

0.13 8.16 

3.32 32.05 

24.79 101.57 

(100 3 ~~ 

0.7'0 86,; 

0.S9 7.49 

:.:;~ 7 (10 

f) 05 1 1 5, 

() i ~~ ~ ! t: 

0.13 S 1(-

3.23 31.6: 

:< 79 34. i 5 

I 

0.66 9.51 

i.27 70 ~S 

I 453 607' 1 4.65 ,,877 

Total 

Mfg. 

Cost 

1994$ 

225 

235 

275 

246 

243 

284 

255 

3~i' 

361 

336 

344 

375 

343 

351 

383 

327 

330 

33c 

346 

23: 

I 2.:lJ. 

I 

~~~ 

2 .... 1 

I 27'":. 

I 

267 

235 

290 

2R6 

274 
APPENDIX B. ADJUSTMENTS TO AHAM DATA

Several adjustments were made to the data submitted by AHAM. These adjustments were

made for the following reasons: 1) statistical variations, 2) normalizing, and 3) differences between

the proposed' AHAM and future DOE (Appendix Jl) test procedures.

B.1 Adjustments due to Statistical Variations

The first step in the analysis was to review the AHAM data. In some cases not all

manufacturers responded to a particular design option. Because manufacturers provided different

energy and water use estimates, an energy or water use change due to a design option modification

can arise simply because a different number of responses are being used to calculate the shipment- weighted average. This situation arose in the analysis of several design options and, as a result, the

energy or water use had to be adjusted.

The hot water energy and total water use for all vertical axis RMC design options were set

equal to the baseline values. Hot water and total water use for horizontal axis designs with 50% and

40% RMC were set equal to that reported for the stand-alone horizontal axis design option. Total

water use for the added insulation and direct drive motor design options were set equal to the baseline

value The mechanical energy for the added insulation design option was also set equal to the

baseline value.

The clothes container volume (wash basket capacity) also varied due to statistical reasons.

Where the clothes container volume differed, values were equalized and the MEF was recalculated.

For the engineering analysis, clothes container volume was allowed to vary based on 1) axis

orientation (vertical or horizontal) and 2) whether a recirculation design was incorporated Thus.

only three clothes container volumes were analyzed; one for vertical axis designs, another for

horizontal axis designs. and one for horizontal axis with recirculation designs. Although the volume

was adjusted as described above for the MEF calculation, it was assumed that all design options washed the same amount of clothes for purposes of calculating the clothes dryer energy required to

dry the clothes. The issue of clothes load is discussed further in Appendix F

B.2 Adjustments due to Normalization

In AHAM's Phase II data submittal, not all manufacturers provided data for every design option. However, a separate baseline (except for cost data) was provided for each "Phase II" design option. The energy use data for this separate baseline were based only on those responses from

manufacturers who provided data for that design option. These "separate" baseline data were used

to normalize the "Phase II" design option data to the five-respondent baseline used throughout the

In this report "proposed AHAM test procedure" refers to an early version of the AHAM test procedure which

was used by manufacturers to submit data

B-1

 EE-RM-94-403 COMMENT 50

APPENDIX B. ADJUSTMENTS TO AHAM DATA 

Several adjustments were made to th~ data submitted by AHAM. These adjustments were 

made for the following reasons: 1) statistical variations, 2) normalizing, and 3) differences between 

the proposed! AHAM and future DOE (Appendix II) test procedures. 

B.I Adjustments due to Statistical Variations 

The first step in the analysis was to review the AHAM data. In some cases not all 

manufacturers responded to a particular design option. Because manufacturers provided different 

energy and water use estimates, an energy or water use change due to a design option modification 

can arise simply becau se a different number of responses are being used to calculate the shipmentweighted average. This situation arose in the analysis of several design options and, as a result, the 

energy or water use had to be adjusted. 

The hot water energy and total water use for all vertical axis RMC design options were set 

equal to the baseline values. Hot water and total water use for· horizontal axis designs with 50% and 

40% RMC were set equal to that reported for the stand-alone horizontal axis design option. Total 

water use for the added msulation and direct drive motor design options were set equal to the baseline 

value The mechanic 2.1 energy for the added insulation design option was also set equal to the 

baseline value. 

The clothes container volume (wash basket capacity) also varied due to statistical reasons 

Where the clothes container volume differed, values were equalized and the MEF was recalculated. 

F or the engineering analysis, clothes container volume was allowed to vary based on 1) axis 

orientation (vertical or horizontal) and 2) whether a recirculation design was incorporated Thus. 

only three clothes container volumes were analyzed; one for vertical axis designs, another for 

horizontal axis designs, and one for horizontal axis with recirculation designs. Although the volume 

was adjusted as described above for the MEF calculation, it was assumed that all design options 

washed the same amount of clothes for purposes of calculating the clothes dryer energy required to 

dry the clothes. The issue of clothes load is discussed further in Appendix F 

B.2 Adjustments due to Normalization 

In AHAM's Phase II data submittal, not all manufacturers provided data for every design 

opti.on. However, a separate baseline .(except for cost ?ata) was provided for each "Phase II" Besign 

optIOn. The energy use data for thiS separate baselme were based only on those responseS-from 

manufacturers who pro\ ided data for that design option. These "separate" baseline data were used 

to normalize the "Phase II" design option data to the five-respondent baseline used throughout the 

lIn this report "pro;,osed AHAM test procedure" refers to an early version of the AHAM test procedure which 

\:'as used by manufacturers ;~, submit data. 

B-1 
analysis. The following "Phase II" design option data were normalized: 1) hot water energy use, 2)

clothes container capacity, and 3) total water use. The basic normalization equation is shown below:

Value * ( Baseline (B)

unadjusted

where Valueadsed = Design option hot water energy use, water use, or clothes

container capacity normalized to 5-respondent baseline.

'aluleunadsted = Original, Phase II, AHAM design option hot water energy use,

water use, or clothes container capacity (unadjusted for number

of respondants)..

Baselines.responden, = Baseline hot water energy use, water use, or clothes container

capacity based on data supplied by all five manufacturers,

i.e., the data for the five-respondent baseline.

Baselineuna,,,,, = Baseline hot water energy use, water use, or clothes container

capacity based on data supplied by the number of manufacturers

providing data for Value,,,adsed.

B.3 Adjustments due to Test Procedure Changes

All of the data submitted by AHAM that was used in the analysis was based on a proposed

AHAM test procedure. Thus, adjustments had to be made to the AHAM data so that they were in

accordance with the future DOE test procedure (Appendix J1). This included adjusting the hot water

energy use to reflect changes in both inlet water temperature assumptions and temperature use factors

(TUFs). It also included changing the dryer usage factor (DUF) from 0.83 to 0.84. The hot water

energy use adjustments are detailed below.

The future DOE test procedure assumes a value of 135°F for the hot water inlet temperature.

The proposed AHAM's test procedure used a value of 130°F. Thus, the hot water energy use of all

the AHAM design option data was corrected by using the following equation.

B-2

 EE-RM-94-403 COMMENT 50

analysis. The following "Phase II" design option data were normalized: 1) hot water energy use, 2) 

clothes container capacity, and 3) total water use. The basic normalization equation is shown below: 

Value adjusted 

where Value adjusted 

ValUeunad)lIsted 

Base Ii lle 5-respondent 

Baseline,madillSled 

Baseline 5 -respondent 

= Value unadjusted . ( ) 

Baseline unadjusted 

(B.1) 

Design option hot water energy use, water use, or clothes 

container capacity normalized to 5-respondent baseline. 

Original, Phase II, AHAM design option hot wafer energy use, 

water use, or clothes container capacity (unadjusted for number 

of respondants) .. 

Baseline hot water ,energy use, water use, or clothes container 

capacity based on data supplied by all five manufacturers, 

i.e., the data for the five-respondent baseline. 

Baseline hot water energy use, water use, or clothes container 

capacity based'on data supplied by the number of manufacturers 

provIding data for Value,mad/llSled' 

B.3 Adjustments due to Test Procedure Changes 

All of the data submitted by AHAM that was used in the analysis was based on a proposed 

AHAM test procedure. Thus, adjustments had to be made to the AHAM data so that they were in 

accordance with the future DOE test procedure (Appendix 11). This included adjusting the hot water 

energy use to retlect changes in both inlet water temperature assumptions and temperature use factors 

(TUFs) It also included changing the dryer usage factor (DUF) from 0.83 to 0.84 The hot water 

energy use adjustments are detailed below 

the future DOE test procedure assumes a value of 135 of for the hot water inlet temperature. 

The proposed AHAM's test procedure used a value of 130°F. Thus, the hot water energy use of all 

the AHAM design option data was corrected by using the following equation. 

B-2 
Wadjuted uHWadjusted ( A ) (B.2)

AHAM

where HWated = Adjusted hot water energy use

HWunadsted = Hot water energy use unadjusted for changes in test procedure

TDoE = Temperature difference between hot water inlet and cold water

inlet according to proposed DOE test procedure

= 135F - 60F = 75°F

J TAMH = Temperature difference between hot water inlet and cold water

inlet according to proposed AHAM test procedure

130F - 60°F = 70°F

The above adjustment not only affects total energy consumption but also the cost-effectiveness of

certain design options. For example, in the case ofTCMV. a higher assumed inlet water temperature results in greater energy savings.

The hot water energy use for the AHAM design option data were also multiplied by a

correction factor that accounted for changes in assumptions regarding TUFs. The following table

details the differences in the TUFs between the proposed AHAM and the future DOE test

procedures.

Tablle B.1 Temperature Use Factors for Proposed AHAM and Future DOE Test Procedures

Temperature Use Factors

Wash/Rinse Selection Proposed AHAM' Test Procedure Future DOE Test Procedure

Hot/Cold 14% 14%

Warm/Cold 50% 49%

Cold/Cold 36% 37%

Warm Rinse 21-33% 27%

As noted on page B- 1, in this report "proposed AHAM test procedure" refers to an early version of the AHAM test

procedure which was used by manufacturers to submit data

Based on the TUFs in the future DOE test procedure, a correction factor of 0.987 was derived and

used to adjust the AHAM hot water energy use data. The derivation of this correction factor is

outlined below:

B-3

 EE-RM-94-403 COMMENT 50

where HWadjusted 

HWunadjusted 

..1TooE 

..1TAHAM 

.6TDOE 

HWad;usled = HWunadjusled • ( ) .6TAHAM (B.2) 

= 

= 

= 

= 

Adjusted hot water energy use 

Hot water energy use unadjusted for changes in test procedure 

Temperature difference between hot water inlet and cold water 

inlet according to proposed DOE test procedure 

135 of - 60°F = 75 of 

Temperature difference between hot water inlet and cold water 

inlet according to proposed AHAM test procedure 

130°F - 60°F = 70°F 

The above adjustment not only affects total energy consumption but also the cost-effectiveness of 

certain design options. For example, in the case ofTCMV a higher assumed inlet water temperature 

results in greater energy savings. 

The hot water energy use for the AHAM design option data were also multiplied by a 

corr,ection factor that accounted for changes in assumptions regarding TUFs. The following table 

details the differences in the TUFs between the proposed AHAM and the future DOE test 

procedures. 

Tablle B.l Temperature Use Factors for Proposed AHAM and Future DOE Test Procedures 

Temperature Use Factors 

Wash/Rinse Selection 

Hot/Cold 

Warm/Co]? 

Cold/Cold 

Proposed AHAMl Test Procedure 

14% 

50% 

36% 

Future DOE Test Procedure 

14% 

49% 

37% 

Warm Rinse 21-33% 27% 

I As noted on page B-1, in this repon "proposed AHAM test procedure'" refers to an earl\' versIOn of the AHAM test 

proeedure which was used hy manufacturers to submIt data 

Based on the TUFs in the future DOE test procedure, a correction factor of 0.987 was derived and 

used to adjust the AHAM hot water energy use data. The derivation of this correction factor is 

outlined below: 

B-3 
First, the following assumptions were made:

1) Clothes washer is a three-selection machine, i.e., wash/rinse temperature selections are

hot/cold, warm/cold, and cold/cold.

2) Baseline hot water energy use is 1.574 kWh/cycle (note that this value has already been

corrected for the future DOE test procedure's hot water inlet temperature).

The following equation for the total per-cycle hot water energy consumption is then taken from the

proposed AHAM test procedure [1].

E = Vh 4 * AT K (B.3)

where E = Baseline hot water energy use (kWh/cycle)

V ,AHV = Baseline hot water use based on proposed AHAM test

procedure (gallons)

AT = Temperature rise (135°F - 60°F) = 75°F

K = Water specific heat (kWh/gal° F) = 0.00240

Substituting the appropriate values in Eq. B.3 for E, AT, and K, one can solve for IVT ,,H4.

E. 1.574 kWhIcyc Vh 'A\- 8.74 gallons (B.4) h H w .. AT 7K 75°F ' 0.0024 kWh/gal-° (B4)

The average amount of hot water used is equal to the amount used for both the hot and warm wash

cycles multiplied by their respective TUFs. This is represented by the following equation.

[' (ho TUFho) + (HH T(UFar,,,) (B.5)

where H^, = Hot water use for hot wash cycle (gallons)

TUF^i, = Temperature Use Factor for hot wash cycle

Harm = Hot water use for warm wash cycle (gallons)

TUFr,, '= Temperature Use Factor for warm wash cycle

B-4

 EE-RM-94-403 COMMENT 50

First, the following assumptions ~ere made: 

I} Clothes washer is a three-selection machine, i.e., wash/rinse temperature selections are 

. hot/cold, warm/cold, and cold/cold. 

2} Baseline hot water energy use is 1.574 kWh/cycle (note that this value has already been 

corrected for the future DOE test procedure's hot water inlet temperature). 

The following equation for the total per-cycle hot water energy consumption is then taken from the 

proposed AHAM test procedure [1]. 

E = VhAHAM • !1 T . K (B.3) 

where E Baseline hot water energy use (kWh/cycle) 

V"AH.4M Baseline hot water use based on proposed AHAM test 

procedure (gallons) 

LlT 

K 

Temperature rise (135°F - 60°F) = 75°F 

Water specific heat (kWh/gaIO F) = 0.00240 

Substituting the appropriate values in Eq. B.3 for E, LlT, and K, one can solve for r'''_~H.4M' 

= ___ 1_.5_7_4_k_Wh_/c,,-Yc___ = 8.74 gallo11S 

75°F' 0.0024 kWh/gal' of, (B.4) 

The average amount of hot water used is equal to the amount used for both the hot and warm wash 

cycles multiplied by their respective TUFs. This is represented by the following equation. 

where Hho/ 

TU}~/ 

Hot water use for hot wash cycle (gallons) 

Temperature Use Factor for hot wash cycle 

Bot water lise for warm wash cycle (gallons) 

Temperature Use Factor for warm wash cycle 

B-4 

(B.5) 
The warm wash temperature is assumed to be the average of the cold and hot water inlet

temperatures (i.e., a 50/50 mix of hot and cold water supplies). Thus, the amount of hot water used

for the warm water wash is equal to half of that used for the hot water wash. This can be expressed with the following equation.

Hhot

warm (B.6)

Substituting Eq. B.6 for H,r, in Eq. B.5 we get the following equation:

:.^ (Hho, * TUFo,) + (h * TUFVO,,) (B.7)

Substituting both the proposed AHAM test procedure TUFs and the baseline hot water use in Eq. B.7, we can solve for H,.

,Hho -, VHf _ 8.74 ga = 22.42 gallons

ho + Th UF"., 0.14 0 (B.8) r -Fho, + 0.14

2 2

Since Hw,,r.. is one-half of H,,, H,,,,,, is equal to 11.21 gallons.

Since the amount of water used in a hot wash cycle and a warm wash cycle is independent of the

TUFs, the future DOE test procedure TUFs can be substituted into Eq. B.5 to determine the total hot

water energy use based on the future DOE test procedure.

IhDOE = (22.42 gal 0.14) + (11.21 gal · 0.49) = 8.63 gallons (B.9)

The correction factor (0.987) is simply the ratio of the total hot water use as determined with the

future DOE test procedure TUFs (8.63 gallons) divided by the total hot water use as determined with

the proposed AHAM test procedure TUFs (8.74 gallons).

B-5

 EE-RM-94-403 COMMENT 50

Th(: warm wash temperature is assumed to be the average of the cold and hot water inlet 

temperatures (i.e., a 50/S0 mix of hot and cold water supplies). Thus, the amount of hot water used 

for the warm water wash is equal to half of that used for the hot water wash. This can be expressed 

with the following equation .. 

(B.6) 

SubstitutingEq. B.6 for H"urm in Eq. B.S we get the following equation: 

(B.7) 

Substituting both the proposed AHAM test procedure TUFs and the baseline hot water use in Eq. 

B. T. we can solve for H;,.:. 

V hAHAM 

TUF n F

ha

( + __ "_"01_·/11 

2 

874 gal 

0.14 T· 0.50 

2 

Since H\rarlll is one-half of Hhol' HWCJrlI1 is equal to 11.21 gallons. 

= 22.42gallolls 

(B.8) 

Since the amount of water used in a hot wash cycle and a warm wash cycle is independent of the 

TUJ;s, the future DOE test procedure TUFscan be substituted into Eq. B.S to determine the total hot 

water energy use based on the future DOE test procedure. 

VhDOE = (22.42 gal· 0.14) T (11.21 gal' 0.49) = 8.63 gallolls (B.9) 

The correction factor (0.987) is simply the ratio of the total hot water use as determined with the 

future DOE test procedure TUFs (8.63 gallons) divided by the total hot water use as determined with 

the proposed AHAM test procedure TUFs (8.74 gallons). 

B-S 
REFERENCES

1. Association of Home Appliance Manufacturers (AHAM). 1995. Comments on the Advance

Notice of Proposed Rulemaking. (section 4.1.1.1) DOE Docket No. EE RM-94-403,

comment #36, July 5, 1995.

B-6

 EE-RM-94-403 COMMENT 50

REFERENCES 

1. Association of Home Appliance Manufacturers (AHAM). 1995. Comments on the Advance 

Notice of Proposed Rulemaking. (section 4.1.1.1) DOE Docket No. EE RM-94-403, 

comment #36, July 5, 1995. 

B-6 
APPENDIX C. RAW DATA PROVIDED BY AHAM

Table C. 1 shows cost, energy, and water use data submitted by AHAM; these data were used

in the Engineering Analysis.

C-1

 EE-RM-94-403 COMMENT 50

APPE:\DIX c. RAW DATA PROVIDED BY AHAM 

Table C.l shows. cost, energy, and water use data submitted by AHAM; these data were used 

in the Engineering Analysis. 

C-l 
TABLE C.I Raw Data Provided by AHAM and Used in the Engineering Analysis

Cost Data Washer Energy Use Data - Proposed Test Procedure Water Use Data

Cost per Unit" Investment Data'" Total I lot Clothes Energy Dryer Total Gallons

Mtl/Part Labor" Shipping oolig Capital' Other per Unit'.Water' Machine'' Total' Container Factoi Sourcek Energy' Gallons percu.ft.

Design Option - 1000's 1000 1000's 'y / 0kW h/cy c kW/cvc 'cu.fl. fft/kWh kWh/cvc ' all/cc eal/cu.ft.

Baseline Compm - - - - 5 55 55 5 55 55

SWA" - - 1.469 0.220 1.689 2.927 1.733 C,C,C,T,C 0.000 39.921 13.372

STD - - - - 0.3350 0.038 0.379 0.173 0.000 3.338 2.037

New BaselineP 1.525 0.221 1.747 2.960 1.695 38.304 12.973

Improved Comp 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4.

Fill Control SWA. $10.98 $0.55 $0.00 $139.31 $0,00 $123.55 $11.58 1.409 0.221 1.631 - 2.960 1.816 C,C,C,E 0.000 36.189 12.261

STD. ;10.931 3.943 0.000 139.164 0.000 199.264 14.668 0.278 0.044 0.320 0.095 0.000 1.284 0.727

Config/Tolerance Comp 4 4 4 4 4 4 4 5 5 5 5 5 5 5 5 5

of Inner & Outer SWA : $4.61 $0.22 -$0.00 $15,239.0 $17,137.10 $836.20 $7.09 1.382 0.220 1.602 - 2.927 1.827 C,C,C,TE 0.000 36.049 12.378

.Tubs-reduce water STD 4.008 0.239 0.000 11032.202 14463.192 339.621. 4.567 0.435 0.038 0.463 0.173 0.000 4.079 1.651

Added Comp 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2

Insulation SWA $43.44 $0.90' $0.00 $68,226.0 $44.59 $8,662 04 $48.77 1.599 0.236 1.835 2.941 1.603 C,E 0.000 39.883 13.634

STD .31.537 0.495, 0.000 56568.540 214.253 3428.308' 35.377 0.580 0.021 0.601 0.283 0.000 4.243 3.048

Increased Motor Comp 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5

Efficiency SWA $8.78 $0.07 $0.00' $3.042.74 $2,678.43 $1,37333 ;$951 1.468 0.200 1.668 2.927 1.754 C,C,C,C,E. 0.000 38.921 13.372

STD 9.641 0.230 0.000 2141 152 2230.583 2265 312 . 1.88 .0.353 00035 0.379 0.173 0.000 · 3.338 2.037

'Thermostatically Comp 5 -5 5 5 5 5 5 5 5 5 5 5 5 5

Controlled SWA $7.70 $0.33 $0.00 $75.09 $1.72 $36:3.26 $8.16 1.426 0.220 1.645 2.927 1.780 C,C,C,C,C 0.000 1 38.921 13.372

Mixing Valves STD 6.570 0.454. 0.000 161.222 4.472 1133.239 7.119 0.352 0.038 0.383 0.173 0.000 3.338 2.037

Improved Water Comp 5 5 5 5 5 5 5 5 5 55 5 5 5 5 5

Extraction SWA $4.50 $0.31 $0.00 .$35,843.0 $14,95039 $2.473.88 $960 1.469 0.226 1.694 .2.927 1.728 T,E,E,C,C -0.383 38.921 13.372

RMC = 50% STD 3.677 1.045 0.000 24314.178 10613.869 2695.075 4.677 0.350 0.029 0.372 0.173 0.245 3.338 2.037

RMC =40% Comp 5 5 5 5 5 5 5 5 :5. 5 5 5 5 5 5 5

SWA $12.32 $0.32 $0:00 $41,437.0 $17,618.02 $3.658.27 $18.12 1.469 0.234 1.702 2.927 1.720 T,E,E,C,C -0.677 38.921 13.372

STD ,7.493 2.156 0.000 27468.394 111923.857 2599.578 8.936 0.350 0.026 0.360 0.173 ___ .0.309 . 3.338 2.037

Horizontal Axis Comp 5 5 5 5 5 5 5 5 5 5 5 . 5 5 5 5.

Design SWA $67.98 $8.24 $0.56 $86,852.27 $125,689.6 $15,716.65 $101.57 0.436 0.193 0.599. 2.766 4.618 E,EE,C,C 0.000 25.730 9.325

STD 62.648 30.463 0.487 59228.735 82027.537 5771.343 110:138 0.163 0.276' 0.184 0.067 0.000 6.296 2.378

Assumes a constant production volume at a 1994 level of 6,576,346. Production Sum of hot water and machine energy used in test procedures.

volume applies only to baseline and includes all models in the product class. J Energy factor should be no less than current minimum efficiency standard.

Burdened labor rate. Source of energy use data: test data (T), calculations (C), or estimation (E). For purposes of this analysis, assumes a five-year regulatory life. Based on energy calculated at 0.5 kWh/lb water removed when compared to baseline.

Includes investment in such items as production machinery and plant upgrade and/or expansion. " Number of companies providing data.

Includes research & development, product certification, administrative overhead. Shipment-weighted average value.

Total of material/parts, labor, and shipping, plus per unit allocation of investment costs. ° Standard deviation on shipment-weighted average value.

Includes only extemally applied hot water. P For energy data where less than five companies reported, a new baseline is calculated

Includes internal hot water. based only on those companies providing data for the design option.

(';ablc(: I continues on next page)

C-2

 EE-RM-94-403 COMMENT 50

TABLE C.I . Raw Data Provided by AHAM and Used in the Engineering Analysis 

Cost Dlltll Wllsher Enrl'gy Usc Data - Proposed Test Procedure . Water Usc Data 

Cost per Unit" Invcstmcnt ()atll~" Total Ilot Clothes Energy Dryer Total Gallons 

l\:1tl/Part Labor" Shipping Tooling Capital" Other< pcr Unit'. Water!' Machine" Totali . ContainerFacto~ Sotircek Energy' . Gallons. pe( cu.ft. 

Design Option . 1000's 1000's 1000's kTf7r1i::ve kWlrlcye kWh/eyecl/.n. (flkWh' kWh/eye: galleyc gallcrl.{t; 

Baselinc Compm: 

SWA" . 

STDo 

Nc\vBaselimf 

Improvcd 

j:ill Control 

Comp 

SWA 

STD 

Config/Tolerance '. Comp 

. orInner & Outcr SWA 

Tubs-rcduce Wllter SID 

Added Comp 

I~sulation SWA 

[ncrcllscd Motor . 

Efficicncy 

.:r hcrmostatically 

Controlled 

Mixing Valvcs 

Improved Watcr 

Extraction 

RMC = 50% 

RMC =40%, 

Horizontal Axis 

Dcsign. 

STD 

Comp 

SWA 

STD 

Comp 

'SWA 

STD 

Comp 

SWA 

STD 

Comp 

SWA 

STD 

Comp 

SWA 

. STU 

4 4 

$10.98· $0.55 

10.931 

4 

$4.61 

4.008 

2 

$43.44 

31.537 

5 

.$in8 

9.641 

5 

$7.70 

6.570 

5 

$4.50 

3.677 

5 

. $12.32 

7.493 

5 

. $67.98 

3.943 

4 

$0.22 

0.239 

2 

$0.90 

0.495. 

5 

$0.07 

0~230 

·5· 

$0.33 

0,454. 

5 

$0.31 

1.045 

5 

$0.32 

2.156 

5 

$8.24 

, 62.648 . 30,463 

4 

$0.00 

0.000 . 

4· 

'$0.00 

0.000 

2 

4 

$139.31 

\39.164 

4 

4 

$0.00 

0.000 

4 

4 

$123.55 

199.264 

4 

$15,239.0 $17,13710 $836.20 

11032.202 14463.192 339.621· 

2 . 2_ 2 

4 

$11.58 

14.668 

4 

$7.09 

4.567 

2 

$0.00 $68,226.0 $44.59 $8,66204 $48.77 

0.000, 56568.540 214.253 3428.308 35.377 

5 5 5 5 5 

$0.00 $.1,()42.74 $2,67843 $J,373:n $9 .. 51 

0.000 2141 152 2230.5X3· 22(,5312 10.088 

5 5 is S ~ 

$0.00 $75.09 .$\.72 $363.26 $8.16 

0.000 161.222 4.472 1133.2~9 7.119 

5 5 5 5 5' 

$0.00$35,843,0 SI4,950.39 $2.47388 $9.60 

0.000 24314.178 10613.869 2695.075 . 4.677 

5 5 5 5 5 

$O~OO $41,437.0 $17,618'c)2 $3.658.27 $18.12 

0.000 27468.394 11923.857. 2599.578 8.936 

5 5 5 5 5 

$0.56 $86,852.27 $125,689.6 S15,71665 $101.57 

0,487 59228.735 82027.537 5771.343 110' \38 

. A~sunies a constant production volume at a 1994 level of6,576.346. PrOduction 

volume applies only to baseline and includes ail models in the product class. 

Burdened labor rate. 

For purposes of this analysis, aSsumes a five-year regulatory life. 

Includes investment in such items as production machinery and plant upgrade and/or expansion. 

Includes research & development, product certification, administrative overhead. 

Total of materia lip arts, labor, and shipping, plus per unit allocatio'n ofinvestmcht costs. 

5 5 55 5 5 5 '5 5 

1:469 

(U30 

1.525 

4 

1.409 

0.278 

5 

1.382 

0,435 

2 

1.599 

0.580 

5 

. 1,4(,8 

0.351 . 

5 

1.426 

0.352 

5 

1,469 

0.350 

5 

1.469 

0.350 

5 

0.436 

0.163 

0.220 

0.D38 

0.221 

4 

0.221 

0.044 

5 

0.220 

0.D38 

2 

. 0.236 

0.021 

5 

(J.200 

0035 

5 

0.220 

0038 

5 

0.226 

0.029 

5 

0.234 

0.026 

5 

0.193 

0.276' 

1.689 

0.379 

1.747 

2.927 

0.173 

2.960 

1. 733. C,C,C,T,C 0.000 

0.000 

39.921 13.372 

3.338 2.037 

"38.304--I2.973-; 

4 4 

1.695 . 

4 

1.816 

4 4 4 4 . 

1.631 . 2.960. C,C,C,E 0.000 36.189 12.261 

0.320 

5 

'1.602 

0,463 

2 

1.835 

0.601 

5 

1.668 

0.379 

5 

1.645 

. 0.383 

5 

1.694 

0.372 

5 

1.702 

0.360 

5 

0.599. 

0.184 

0.095 

5 

2.92'Z 

5 

0.000 1.284 0.727 -------------------_._----------_ .. 

5 555 

0.000 i 36.049 12.3.78 

0.173 0.000 4.079 1.651 .. - ---... --~.---- .. - ._---_._---._----------------- 2 2 

2.941 

0.283 

5 

2.927 

0.173 

5 

2.927 

0.173 

5 

2.927 

1.603 

5 

1.754 

. 5 

1.780 

5 

1.728 

2 

C,E 

2 2 2 

0.000 ; 39.883 13.634 

0.000 4.243 3.048 - ..... _- --- --------

5 5 5' 5 

C,C,C,C,E. 0.000 38.921 

3.338 

5 

13:372 . 

2.037 

5 

C,C,C,C,C 

5 

T,E,E,C,C 

0,000 

5 5 

0.000 i 38.921 13.372 

0.000 3.338 2.037 .... -._---_... . .,----- ..... _-_. __ .•. _--

5 5 5' 

-0.3.83 38.921 13.3.72 

0.173 0.245 3.338 2.037 -' .. _- _ .. -.--_. --------.. --... -... _- - - --- ___ • ___ ._. ___ .... _ •• _. __ 0. 

5 5 5 . 5 5 5 

2.927 1.720 T ,E,E,C,C -0.677 38.921 13.372 . 

0.173. ___ .... .. .. ____ .... _. _.0.302. .. ,...1.33.8 _ . .::.1:Q}l.: 

5 

2.766 

0.067 

5 

4.618 

5' 5 5 5 

E,E,E,C,C 0.000 

0.000 

25.730 

6.296 

9.325 

2.378 

Sum of hot water and machine energy used in teSt procedures . 

Energy factor should be no less than current minimum efficiency standard. 

Source of energy use data: teSt data (T), calcula~ions (C), or estimation (E). 

" Based on energy calculated at 0.5 kWh/lb water removed when compared to baseline. 

mNumber of companies providing data. 

Shipment-weighted average vallie. 

Standard deviation on shipment~weighted average value. 

Includes only extemaJly applied hot water. . . 

Includes intemalliot water. 

" P . For energy data where less than five companies reported, a new baseline' is calculated 

based only on those companies providing data for the design option. 

cr ablc C I continlles 011 next pagc) 

C-2 
TABLE C. I Raw Data Provided by AHAM and Used in the Engineering Analysis (cont.)

Cost Data Washer Energy Use Data - Proposed Test Procedure Water Use Data

Cost per Unit' Investment Data)" Total 1lot Clothes Energy Dryer Total Gallons

Mtl/Part Labor b Shipping Tooling Capital" Olthere per Unil' Water" Machine h ' Total' Container Factorj Sourcek Energy' Gallons percu.ft.

Design Option g p' 1000's 1000.10s k._W//cvc kli',/cv kfl,/rrc cry.fi. ftr/k,'U,7, _wv/c ...... ./cvc ... /cu..

New BaselineP 1 520 0 219 1.739 .2.960 1.703 38.299 12.971

Advanced Conmp" 2 2 2 2 2 2 3 3 3 3 3 3 3 3 3

Controls SWA" $54.98 $1.24 $0.00 $45,667.95 S15,13095 $16,068.24 $60.75 1.508 0.219 1.727 2.960 1.714 E,E,E 0.000 38.299 12.971

STD" ,28.991 0.707 0.000 41627.376 14142.136 11419775 26.290 0.321 0.035 0.353 0.115 0.000 1.424 0.822

Direct Drive Comp 2 2 2 2 2 2 2 2 2 2 2 2 2

Motor SWA $68.87 $0.74 $0.00 $8,617.44 .$8,528.26 S4.353.32 $70.88 1618 0.086 1 703 2.941 1.727 C,E 0.000 39.883 13.634

STD 53:457 1.273 0.000 6642.561 7071.068 3107.027 55.451 (0.587 0.021 0.608 0.283 0.000 . 4.243 3.048

Horizontal Axis Comp 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4

with SWA $74.92 $6.00 $0.17 $95,727.83 $134.844.25 $21.727.10 $104.53 0.348 0.260 0.608 2.736 4.503 C,C,E,E 0.000 21.782 8.034

Recirculation STD 31.182 11 644 0.500 63393.182 95407.456 8952979 28.273 0126 0 166 0.185 0.144 0.000 3.389 1.637

New Baseline I 525 0 221 1.747 2.960 1.695 38.304 12.973

Automatic Fill Comp 4 4 · 4 4 4 4 4 4 4 4 4 4 4 4 4 4

Control SWA $30.12 $1.24 $0.00 $29,719.00 1.768.76872 $S6.06081 34.15 I 5( 0.221 1.571 2.995 1.906 E,EE,C . 0.000 : 34.672 11.620

STD 12.807 3.637 0.000 24676.399 9995.003 4775.921 15124 0.255 0.044 0.290 0.165 0.000 1.969 1.004

New Baseline 1.525 0.221 1.747 2.960 1.695 38.304 12.973

tHorizontal Axis Comp 4. 4 4 4 4 4 4 4 4 4 4 4 .4 4

with 50% RMC SWA $75.68 $8.41 $0.62 $97.088.68 $143,588.A49 516.626 00 $110 2? 0.445 0,205 0.621 2.778 4.474 C,C,C,E,E -0.317 27.181 9.808,

SfI) 84.857 34.558 0.515 623376699 88404.374 4867 152 139.390 0.160 0.297 0.161 0.058 0.219 3.392 1.361

New Baseline 1525 0.221 1.747 2.960 1.695 38.304 12.973

Horizontal Axis Comp 4 4 4 4 4 4 4 4 4 4 4 44 4 4 4

with 40% RMC SWA $82.58 $8.30 $0.62 $ 103,056.3 $146,564 13 $19,619.04 $117 72 0.445 0.210 0.626 2.778 4.434 C,C,C,E,E -0.595 27.181 9.808

STD 93.164 34.587 0.515 63613.907 90683 111 5107 8.37 148.284 0.160 0.293 0.152 0.058 0.368 3.392 1.361

New Baseline 1.520 0.219 1.739 2.960 1.703 38.299 12.971

Hlorizontal Axis Comp 3 3 3 3 3 - - 3 3 3 3 3 3 3 3

with Aultomatic SWA $67.21 $5.36 $0.65 $97,956.79 $143.847.18 S17,038.09 $9583 0.414 0 169 0.583 2.782 4.771 C,C,EE 0.000 26.430 9.515

Fill Conitrol STD 34.036 13.426 0.520 60563.595 104969.425 3110.307 26.065 0.064 0.021 0.079 0.058 0.000 i 3.023 1.090

New Baselinec 1.525 0.221 1.747 2.960 1.695 38.304 12.973

Vertical Axis. Comp 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4

AutoFill. TCMV, SWA $39.43 $1.80 $0.00 $69,008.50 $27,744.51 $14.580.77 $49.38 1314 0,.227 1.541 2.995 1.944 C,C,E,E -0.361 34.672 11.617

50% RMC STD 17.642 5.277 0.000 47604.864 19080.927 9727.611 22.798 0.278 0.034 0.301 0.165 0.289 1.969 1.004

New Baseline '1.525 0 221 1.747 ' 2.960 1.695 38.304 12.973

Vertical Axis. Comp 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4

Auto Fill, TCMV, SWA $47.60 $1.81 $0.00 $75,17029 S30,744.42 15.823.87 $S58.33 1 314 0.233 1.546 2.995 1.937 C,CE,E -0.666 34.672 11.617

40% RMC STD 20.009 0.583 0 51452.143 21061.697 10556.755 26.893 0.278 0.028 0.294 0.165 0.313 1.969 1.004

Assumes a constant production volume at a 1994 level of'6.576.346 Production ' Sum ofllt water and machine energy used in test procedures.

volume applies only to baseline and includes all models in the product class. l'.'nergy hactor should be no less than current minimum efficiency standard.

Burdened labor rate. Source oflenergy use data: test data (T). calculations (C), or estimation (E).

For purposes of this analysis. assumes a five-year regulatory life Based on energy calculated at 0.5 kWh/lbi water removed when compared to baseline.

Includes investment in such items as production machinery and plail upgrade tldor Numberl companis providing data.

Includes research & dcvcslopicntl. product cerilitication, administl alivc vc rhne l .Slhipilsl cI-weighlld average valuc.

lTolal of 'material/parlts labor, and shipping, plus per unit allocalion of ilmvestmenui, costs. Stalndadllt d eviation on shlipment-weigllhted average value.

Includes only extemaclly applied hot water. I:o, cne-!",v dal; where less thaI live c omopanies reported. a new baseline is calculated

Include's itcln' l hot \aIter. hse'id ollv 11 thlmse comp; a1ies provitdinge d aita lot tlhe design option.

C-3

 EE-RM-94-403 COMMENT 50

TABLE C.I Raw Data Provided by AHAM and Used in the Engineering Analysis (cant.) 

Cost Dntn Wnshcl' Encl'gy Us(' Dntn - Propos('d Tcst Proccdure 

Cost per Unit' Investment Data"'. Total Hot Clothes Energy 

MIl/Part Lahorb Shipping Tooling Capital~ Other' per lJni{ Water Maehineh · Totali Container Faeto~ Soureek 

Dryer 

Energy 

Water Use Data 

Total Gallons 

Gallons per Cll.ft. 

~D:.:::c~si~g.!!n...:O~pl!:t~io~I",-I ____ ,--___________ · ~10()_Q_! 1000's 1000's ,HVh/cvc HVhlcvc HVhlrvr cuf!. (rl.L:W7! J..II.ll./~ .. ~ , ..... ,.' "" r"'" , gaf,!cvc .-.... 11 .... 4. r, 5""\"U.II, 

Advanced 

Controls 

Direct Drive 

Motor 

New l3asclineP 

Compm 

SWA" 

SIDo 

Comp 

SWA 

SrD . 

Horizontal Axis Com I' 

with SWA 

Recirculation STD 

Ncw Baseline 

Automatic Fill (omp 

Control SWA 

SID 

Ncw Basclinc 

Horizontal Axis 

with 50% RMC 

COIllP 

SWA 

SrD 

Ncw Baseline· 

Horizontal Axis Comp 

\\'ith 40% RMC SWA 

SrD 

New Baseline 

1 Iorizontal Axis Comp 

with Automatic SW A 

Fill COIitrol SrD 

Ncw f3aselinc' 

Vertical Axis. Comp 

Auto FilL TCMV. SWA 

50% RMC STD 

Ncw Baseline 

Vertical Axis. Comp 

Auto Fill, TCMV, SWA 

40%RMC STD 

2 

$54.98 

28.991 

2 

S6887 

53457 

4 

S74.92 

31.182 

<1 

S30.12 

12.807 

II. 

. $7568 

84.857 

4 

S82.58 

93.164 

3 

S67.21 

34.036 

4 

$3943 

17.642 

4 

S47.60 

20.009 

2 

Sl.24 

0.707 

2 

SO.74 

1.273 

4 

$6.00 

11.644 

4 

Sl.24 

3.6.37 

,! 

S841 

34.558 

4 

$830 

34.587 

.3 

S5.36 

13426 

4 

$1.80 

5.277 

4 

SI.81 

0.583 

? 

$Cl.OIl 

0000 

2 

SO.OO 

0.000 

4 

SO.17 

D500 

4 

$0.00 

(l.OOO 

4 

SO.Ii:? 

0.515 

4 

SO.62 

0.515 

.3 

$0.65 

0.520 

4 

$0.00 

0.000 

4 

SO.DO 

o 

2 . I 520 

3 

$45.667.95 S 15,13095 $16,068.24 S60.75 !.S08 

41627376 14142.IY, 11419775 26.29() OJ:? 1 

:? 

$8,61744 

6642.561 

4 

2 

S8528.2(' 

70710(,8 

4 

2 

$4.353.32 

.3107.027 

4 

2 

$70.88 

55451 

4 

2 

I (d 8 

0.587 

4 

$95,727.83 $134,844.25 S21 .727.10 $104.53 0 . .348 

63.393.182 ()S40745(, 8()S2 (n9 28.273 0 12(, 

I S2S 

<1 4 '1 ,1 4 

$2<),71 <)00 S 11.7(,87:.' $(,.()(,tUi I S3 11.1 S ~5() 

24('7(>.399 9995()(U 477S.92I 15 12/1 ()2'i5 

1.525 

4 4 4 ,1 4 

$97.088.C>f; SI<13,58x,l9 SI(,.(,2() ()O SIlO 2? 0.445 

62337 (,')9 8~4()4.374 tlX(,7 152 139.V)O ().I(,O 

1.525 

4 4 4 4 4 

$IOH)56.3 SI46,564 I ~ $19/,J904 $117 T2 0.445 

63613.907 ()0683 III 5107 X37 148.284 (J.W) 

1.520 

.3 .3 ? 3 3 

0219 1.739 .2.960 

.3 3 3 

0.219 1.727 2.960 

(U)35 0.353 0.115 

222 

0.086 1.703 2.941 

0.02 J 0.608 0.283 

4 4 4 

0.260 0.608 2.736 

o 1(,(' () IX5 0.144 

() 2:? I 1.7117 2. <)(,() 

444 

0221 1.571 2.995 

0.044 0.290 0.165 

0.221 1.747 2.960 

4 4 4 

0205 0621 2.778 

0297 U.161 0.058 

0221 1.747 2.960 

444 

(J.210 0.626 2.778 

0293 0.152 0.058 

0.219 1.739 2.960 

3 :3 3 

$97.956.79 SI43.X47.18 $17.03809 $95X3 0.414 0 169 0.5X.1 2.782 

60563.595 I 04969.425 .~ I J 0.307 260(,5 

4 4 4 4 

$69.1)08.50 S27.744.51 S 14.580.77 $493X 

47604.864 19080.927 9727.611 22.798 

0.064 0.021 n.079 0.058 

1.525 n.221 1.747 2.960 

4 4 4 4 

1314 0227 1.541 2.995 

0.278 0.034 0.301 0.165 

1.703 

3 

1.714 

2 

1.727 

4 

4.503 

l.m5 

4 

1.906 

1.695 

3 

E,E,E 

3 

0.000 

38.299 

3 

38.299 

12.971 

.3 

12.971 

0.000 1.424 0.822 ._---._---_ .. _._-------_. __ ._-- -------_._ .. _----._--

2 2 2 2 

C,E 

4 

C,C,E,E 

4 

E,E,E,C 

0.000 39.883 13.634 

0.000 

4 

0.000 

0.000 

4 

0.000 

0.000 

4.243 

4 

21.782 

3.389 

3X.304 

4 

34.672 

1.969 

3.048 

4 

8.034 

1.637 

12.973 

4 

11.620 

1.004 

38.304 12.973 

4 4 4 .4 4 

9.808. 

1.361 

4.474 C,C,C,E,E -0.317 27.181 

0.219 3.392 

1.695 38.304 12.973 

4 4 4 4 4 

4.434 C,C,C,E,E -0.595 27.181 9.808 

1.703 

3 

4.771 

1.695 

4 

1.944 

3 

C,C,E,E 

4 

C,C,E,E 

0.368 3.392 1.361 

3 

0.000 

0.000 

4 

-0.361 

38.299 

3 

26.430 

3.023 

38.304 

4 

34.672 

12.971 

3 

9.515 

1.090 

12.973 

4 

11.617 

0.289 1.969 1.004 --_._-- --_ .. _-_._. -._._--

. 1.525 0221 1.747 2.960 1.695 38.304 12.973 

4 4 4 4 4 " 4 4 4 4 4 4 4 

$75,J7()29 $30.744,)2 SJ5.X23.87 S58 .. n 1314 0.233 1.546 2.995 1.937 C,C,E,E -0.666 34.672 11.617 

51452. 143 21061.697 J 0556.:..;. 7..:;5.:::,5--=:2;,:.:6"." 8~9.:::.3-,--.::0:..:.:.2::.c7.::8:....".,___"'0.:.;;. 0:.=2c:::8_~0~.2.:::.94...:....._0:::,;.c.!.1 :::,;65:::.-________ c:::0.:.,::.3:..!,1.:::,3_....!..:1..:::.,96:::,;9::......---!1..;,:.0:.,:;:0:24_ 

/I$Sl1l11CS a constant production volume at a 1994 level 01'6.576.346 Production SUI11 "fhnt lVater and machine cnergy used in test procedures. 

volume applies only to haselineand includes all models in the product class. Fncrg\' lactor should he no less than current minimum et1icicncy standard. 

Burdened labor raic. SOUJW "fenergy lise data: test data (T). calculations (C), or estimation (E). 

F<\r purposes of this analysis. assumes a five-year regulalory life Ilascd on energy calculated at n.5 kWh/lh water removed when compared to baseline. 

Includes in\'estment in slich items as producti("lIl Jllachiilcry alld plalll upgratk al1d/or C\P;IIlSI~11I NUllllh:r l,rcol1lpanics pr()viding (bttt. 

Includcs rL:~carch & dc,·clopIllCIlL product cCf1ilicaliotl, adlllillislla1J'·L: O\·crlH.:ad Shipmcllf-w\;ighkd a "cragl..' vallie. 

Tolal ofmatcrilli/parts.labllr, and shipping. plus per unil all"cation "l'in, .. "tnwlIl cosh. Standard d~viation on shipJ11~nt-\\'"ightcd awrage value. 

Indudc!' ol~ly c\tcfllally applit~d hot watcr FOl \ .. .'ll~rg\' dala whcre kss thall li\'\...· ~·lllllpallic!'i n.:pon.:d." new hasdine is calculated 

Illeludes inkr1lal hot \\'akr. ha:-,\:d olll\' Ull 111lls,,: companies pru\"1dill.g data h.lr the th:sign option. 

C-3 
Table C.2 provides data supplied by AHAM showing confidence levels on the design options listed in Table C. 1. For each design option, the confidence levels provided in Table C.2 indicate how

confident manufacturers are in 1) the accuracy of their cost and investment data and 2) their success

at mass-producing and marketing a clothes washer with the prospective design option. Confidence

levels are expressed as percentages with a higher value indicating increased confidence. Also

included in Table C.2 are limiting performance factors for incorporating the design options in clothes

washer designs.

Table C.2 AHAM Confidence Level and Limiting Performance Factor Data

Confidence Levels Limiting

Cost and Mass Production Marketing Performance

Design Option Investment Data Success Success Factor'

Improved Fill Compb 4 4 4 4

Control SWA' 66.781% 79.579% 47.637% 1,1,4,4.4,7.8,12,

STDd 0.150 0.075 0.210 15,15,16,17

Config/Tolerance Comp' 4 4 4 5

of Inner & Outer SWA' 69.340% 54.540% 87.030% 1,2,4,5,5,5,7,10.O,0

Tubs-Reduce Water STD" 0.075 0.2!7 0.075 11,11,13,14,15,16

Added Comp1 2 2 2 2

Insulation SWA' 53.680% 37.360%/ 39.570% 0.0,2.6,7,9.14

STD'" 0.177 0.354 0.460

Increased Motor Compb 5 5 5 5

Efficielnc SWA' 77.680% 9i.900% 75.690% 0,2,2,2,5,6,6, i. .2

STDV" 0 110 0. i i 0.259

Thermostatically Comp 5 5

Controlled SWA' 62.590% 97 840% 56.430% 1.1.17.13

Mixing Valves STD' 0.084 0.055 0.246

Improved Watel CompL 5: 5 5

Extraction SWA' 71.170% 78.840%'- 76.860% 3,5.,5,91,1 ), 10.15

IRMC = 50% ' STIDd 0.061 0.124 0.190

RMC =40%., Comp" 55 5

SWA' 48.280% 61.260% 64.590% 3.3,3.,5,5,5,10,10.10

STD° 0045 0.199 0.135 12.14,15

Horizontal Axis Compb 5 5 5 5

Design SWA' 62.438% 91.899% 67.942% 1,1.2,56.,77.8,8.9.9.9.1 (

STD 0.15_2 0.292 0.313 10, .14,16,16.16.1-7 Factors that are repeated indicate multiple number of companies listing the factor as a concern. 1. Soil Removal 7. Consumer Interface (Ergonomics) 13. Whiteness Retention

2. Physical Size 8. Tangling 14. Capacity 3. Wrinkling 9. Cycle Time 15. Wear

4. Gentleness of Action 10. Vibration 16. Rinsing 5. Noise 11. Sand Removal 17. Suds Sensitivity 6. Servicing/Installation 12. Safety

Number of companies providing data.

Shipment-weighted average value

d. Standard deviation on shipment-weighted average value.

(Table C.2 continues on next page)

C-4

 EE-RM-94-403 COMMENT 50

Table C.2 provides data supplied by AHAM showing confidence levels on the design options 

listed in Table C.I. For each design option, the confidence levels provided in Table C.2 indicate how 

confident manufacturers are in I) the accuracy of their cost and investment data and 2) their success 

at mass-producing and marketing a clothes washer with the prospective design option. Confidence 

levels are expressed as percentages with a higher value indicating increased confidence. Also 

included in Table C.2 are limiting performance factors for incorporating the design options in clothes 

washer designs. 

Table C.2 AHAM Confidence Level and Limiting Performance Factor Data 

Design Option 

Improved Fill 

Control 

Confi glT olerance 

of hIDer & Outer 

Tubs-Reduce Water 

Added 

Insulation 

Incrcased MOlor 

Efficlcnc\ 

ThermostaticallY 

Controiled 

Mixing Vah'es 

Improved Watel 

ExtraclIon 

RMC = 500/" 

RMC =40% 

Horizontal AXIS 

Design 

Compb 

SWN 

STDd 

Comp" 

SWA' 

STDd 

Compo 

SWN 

SID" 

Compo 

SWA' 

STD" 

Compo 

SWA' 

S'TDd 

Compo 

SWA' 

STDd 

Comp" 

SWA' 

STD" 

Compb 

SWA' 

Cost and 

. Investment Data 

4 

66.781% 

0.150 

4 

69.340% 

0.075 

2 

53.680% 

O. ]77 

5 

77.680% 

() 1 1 () 

.5 

62.590% 

0.084 

5 

7).170% 

0.061 

5 

48.280% 

U.045 

5 

62.438% 

Confidence Levels Limiting 

Mass Production Marketing Performance 

Success Success Factor' 

4 4 4 

79.579% 47.637% 1,1,4,4,4,7,8,12, 

0.075 0.210 15,15,16,17 

4 4 5 

54.540% 87.030% 1,2,4,5,5,5,7, I 0, 1 0, 

0.217 0.075 11,11,13,14,15,16 

2 2 2 

37.360% 39.570% 0,0,2,6,7 ,9,1 4 

0.354 0.460 

5 5 5 

:";1.900%, 75.690% 0,2,2,2,5,6,6,10.12 

v.1HI 0.259 

5 5 .5 

97.840% 56.430% !.I,L7,!3 

(1055 0.246 

.:; 5 5 

78.840% 76.860'Yo 3,5,5,5,9,10, I 0, 1 0, 15 

0.124 0.190 

.5 5 .5 

61260°/.0 64.590% 3.3,3 ,5,5,5, I 0, I O,l 0, 

0.199 0.135 12.14,15 

5 5 5 

Cll.899% 67.942% 1.1,2,5,6.7,7,8,8,9,9,9,1() 

STDe 0.152 0.292 0.313 10,11,14,16.16.16,1'.;7 

Factors that are repeated indicate multiple number of companies listing the factor as a concem . 

1. Soil Removal 7. Consumer Interface (Ergonomics) 13. Whiteness RetentIon 

2. Physicai Size 8. Tanglmg 14. Capacity 

3. WnnklIng 9. Cycle TIme 15. Wear 

4. Gentleness of Action 10. Vibration 16. Rinsing 

'5. Noise 11. Sand Removal 17. Suds Sensitivity 

6. Servicingllnstallation 

Number of companies providing data. 

Shipment-weighted average value 

12. Safety 

d Standard de\'iation on shipment-weighted average value. 

(Table C2 continues on next page) 

C-4 
Table C.2 AHAM Confidence Level and Limiting Performance Factor Data (cont.)

Confidence Levels Limiting

Cost and Mass Production Marketing Performance

Design Option Investment Data Success Success Factore

Advanced Compb 3 3 3 2

Controls SWA' i 38.390% 35.955% 26.217% 1,4,7,9

STDd 0.389 0.318 0.035

Suds Savings Compb : 4 4 4 4

SWA' ! 2.040% 97.860% 19.280% 0,1,1,2,6,7

STDd i 0.050 0.096 0.354

Direct Drive Compb 2 2 2 2

Motor SWAC . 45.150% 55.890% 90.740% 0,2,2,5,6,8

STDd 0.247 0.283 0.035

Horizontal Axis Compb 4 4 4 4

with 40% RMC SWAC 38.797% 64:070% 51.508% 1,3,3,3,5.5,6,7,7,8,8.9.9

STDd 0.111 0.216 0.229 10,10,11,14,15,16,16

Horizontal Axis Compb 3 3 3 3

with Automatic SWA' 64.353% 90.534% 71.289% , 1,6,7,7,8,8,9,10,11,

Fill Control STDd 0.100 0.153 0.150 16,16,17

Vertical Axis, Compb 4 4 4 4

Auto Fill. TCMV, SWA' 3'.851% 35.988% 29.249% 1,1.3,4,5,7,81.1 3.i5.

50% RMC STD' J.247 0.189 0.138 16,16,17

Vertical Axis, Compb 4 4 4 4

Auio Fill, TCMV, SWA' - 8523 3% 0 29.249% 1,1,3.3,4.5,7.8.10.13.! 4.

40% RMC STD 0.125 0.171 0.138 15.16.17 a Factors that are repeated indicate multiple number of companies listing the factor as a concern)

1. Soil Removal 7. Consumer Interface (Ergonomics) 13. Whiteness Retention

2. Physical Size 8. Tangling 14. Capacity

2. Wrinkling 9. Cycle Time 15. Wear

4. Gentleness of Action 10 Vibration 16. Rinsing

5. Noise 11- Sand Removal 17. Suds Sensitivltv

6. Servicing/Installation 12. SafeTx

b Number of companies providing data.

Shipment-weighted average x al;:. d Standard deviation on shipmenm-vweighted average alue.

C-5

 EE-RM-94-403 COMMENT 50

Table C.2 AHAM Confidence Level and Limitin 

Design Option 

Advanced 

Controls 

Suds Savings 

Direct Drive 

Motor 

Horizontal Axis 

with40%RMC 

Horizontal Axis 

with Automatic 

Fill Control 

Vertical Axis, 

Auto Fill. TCMV. 

50%RMC 

Compi. i 

SWN i ... §XI)~~. 

Compb: 

SWN I 

STDd 

Compb 

SWN. 

STDd 

Compb 

SWN 

STDd 

Compb 

SWN 

STDd 

Compb. 

SWN 

STDd 

Vertical AXIS, Compb 

Auto Fill, TCMV, SW N 

Cost and 

InyesUnent Data 

3 

38.390% 

0.389 -~ ---------~----.---

4 

""2.040% 

0.050 

2 

"+5.150% 

0.247 

4 

~S.797% 

0.111 

3 

6..+.353% 

0.100 

4 

~:.851 % 

J.247 

4 

::- 852% 

Confidence Levels 

Mass Production 

Success 

3 

35.955% 

0.318 .- -----------------

4 

97.860% 

0.096 

2 

55.890% 

0.283 

4 

64:070% 

0.216 

3 

90.534% 

0.153 

4 

35.988% 

0.189 

4 

32.203% 

Marketing Performance 

Success Factor" 

3 2 

26.217% 1;4,7,9 

0.035 

4 4, 

19.280% 0,1, 1,2,6,7 

0.354 

2 2 

90.740% 0,2,2,5,6,8 

0.035 

4 4 

51.508% 1,3,3,3,5,5,6,7,7,8,8,9,9 

0.229 10,10,11,14,15,16,16 

3 3 

71.289% 1,6,7,7,8,8,9,10,11, 

0.150 16,16,17 

4 4 

29.249% 1,1.3,4,5,7,8.10,13.15. 

o 138 16,16,17 

4 4 

29.249% 1,1,3.3,4.5,7.8.10. i 3.14. 

40%RMC STD';lI25 0.171 0.138 15.16.17 

Factors that are repeated indie"le multiple number of compames hsting the factor as a concern) 

I. Soil Removal 7. Consumer InteI'face (Ergonomics) 13. Whiteness Retention 

2. Physical Size 8. TrrngliIig 14. Capacity 

3. Wrinkling 9. Cycle Time 15. Wear 

<1. Gentleness of Action 10 Vibration 16. Rinsing 

.; NOIse II· Sand Removal 17 Suds SensitlVit\ 

6. Sel'Vlcinglinstallation 

b Number of companies pro\'idm~ jata 

~,hlpment-\\'elghted average \J:~:': 

12. Safel\ 

Standard deviation on shipmeJ1l-w eighted average \ alue. 

C-5 
APPENDIX D. DRYER EFFICIENCY FUEL CORRECTION

DERIVATION

An adjustment to the Df (the amount of energy required by a dryer to remove moisture) was

required for gas dryers because the value of 0.5 kWh/lb used in the future DOE test procedure

(Appendix J1) was determined based on the use of an electric dryer. A correction factor was derived

from data submitted by AHAM as part of their dryer data submittal [1]. The data is summarized in

the following table.

Table D.1 Dryer Energy at 70% Initial Moisture Content

Clothes Dryer Type Gas Energy Electric Energy Total Energy

kWh/'cvce kJhl.hcycl cce klWh/cvcl

Electric 2.210 2.210

Gas 2.379 0.102 2.481

A simple ratio of the total drying energy can then be used as a correction factor to the D,.

GCF = Gas Dyer Total Energy 2.481 1.12

Electric Dryer Total Energy 2.210

where GCF = Gas Correction Factor

Thus, the energy required to remove moisture in a gas clothes dryer is represented by the following

equation.

De: ., = D e (D.2)

where Defg = gas dryer energy required to remove moisture (kWh/lb)

Df = electric dryer energy required to remove moisture (kWh/lb)

To simplify the calculation of the energy expense of drying clothes in a gas dryer, all the energy used

by a gas dryer is assumed to be priced at the cost of gas (including the small amount of electricity that

is used).

D-l

 EE-RM-94-403 COMMENT 50

APPENDIX D. DRYER EFFICIENCY FUEL CORRECTION 

DERIVATION 

An adjustment to the D ej(the amount of energy required by a dryer to remove moisture) was 

required for gas dryers because the value of 0.5 kWhJlb used in the future DOE test procedure 

(Appendix 11) was determined based on the use of an electric dryer. A correction factor was derived 

from data submitted by AHAM as part of their dryer data submittal [1]. The data is summarized in 

the following table. 

Table D.I Dryer Energy at 70% Initial Moisture Content 

Clothes Dryer Type Gas Energy Electric Energ~· Total Energy 

kWh/cycle kWh/cycle kWllIcvcle 

Electric 2.210 2.210 

Gas 2.379 0.102 2.481 

A simple ratio of the total drying energy can then be used as a correction factor to the D~r 

GCF = Gas Dlyer Total Energy 

Electric Dryer Total Energy = 2.481 

2.210 

where GCF = Gas Correction Factor 

= 1.12 (D.I) 

Thus, the energy required to remove TJ)oisture in a gas clothes dryer is represented by the following 

equation 

where D ef.gas 

De! 

gas dryer energy required to remove moisture (kWhJlb) 

electric dryer energy required to remove moisture (kWhJlb) 

(D.2) 

To simplifY the calculation of the energy expense of drying clothes in a gas dryer, all the energy used 

bya gas dryer is assumed !o be priced at the cost of gas (including the small amount of electricity that 

is used). 

D-l . 
REFERENCES

1. Association of Home Appliance Manufacturers (AHAM). 1995. Comments on the Advance

Notice of Proposed Rulemaking. DOE Docket No. EE RM-94-403, comment #37, June 27,

1995.

D-2

 EE-RM-94-403 COMMENT 50

REFERENCES 

1. ;<, 

Association of Home Appliance Manufacturers (AHAM). 1995;, Comments on the Advance 

, Notice ofProposedRulenuiking. DOE Docket No. EE RM-:94-403, comment #37, June 27, 

'1995. " ' , , 

, f 

D-2 

i 
APPENDIX E. CALCULATIONS FOR IMPROVED WATER

EXTRACTION DESIGN OPTION

In calculating the benefits of improved water extraction, several parameters were taken into

consideration. These include 1) the amount of energy saved in the clothes dryer for every extra

pound of moisture removed in the washer, 2) the fraction of clothes dryer loads per washer load

(some clothes are line-dried), 3) the average load size, 4) the moisture content of the clothes before

entering the clothes dryer, and 5) the fraction of time the lower RMC option is used., These are

described in greater detail below.

The dryer energy (D.) is defined as the amount of energy needed to completely dry the test

load in a clothes dryer after the washer final spin cycle. The amount of energy needed to dry clothes

after they are removed from the clothes washer depends on how much moisture is retained after the

final spin. The remaining moisture is specified as a percentage of the "bone dry" weight of a standard

test load. For this analysis, a baseline RMC of 62% after the final spin cycle was assumed. This is

based on data AHAM submitted on shipment-weighted averages for a baseline washer. A 62% RMC

means that the weight of a wet test load weighs 62% more than a bone dry test load (1.62 x dry test

load). After being dried in a clothes dryer, the test load is assumed to have a residual RMC of 4%

The future DOE test procedure (Appendix J1) provides a table that specifies the maximum

clothes load for a given size clothes washer. For a 2.9 to 3.0 ft3 washer, the maximum load is 12 1

lbs. The average load to maximum load fraction. 0.52, was derived from Procter & Gamble data and

made part of the proposed and future DOE test procedures. The dryer energy is sometimes also

referred to as moisture removal energy. The equation describing the dryer energy is given below

where:

D= LAF * (Max. Load) (RAC - RMC4%) · De DUF (E.1)

LAF = Load Adjustment Factor = 0.52

Max. Load = Maximum clothes load = 12.1 lbs/cycle

RMC = Remaining Moisture Content after final spin cycle, (expressed as a fraction) RMC4% = Remaining Moisture Content with a 4% residual, (expressed as a fraction)

Def = 0.5 kWh/lb of moisture (nominal energy required for clothes dryer to remove

moisture)

DUF = Diyer Usage Factor = 0.84. DUF is the ratio of dryer cycles to clothes

washer cycles per year.

Since it is not expected that consumers would use higher spin speed or other options to reduce the remaining moisture content 100% of the time, the future DOE test procedure

E-l

 EE-RM-94-403 COMMENT 50

APPENDIX E. CALCULATIONS FOR IMPROVED WATER 

EXTRACTION DESIGN OPTION 

In calculating the benefits of improved water extraction, several parameters were taken into 

consideration. These include 1) the amount of energy saved in the clothes dryer for every extra 

pound of moisture removed in the washer, 2) the fraction of clothes dryer loads per washer load 

(some clothes are line-dried), 3) the average load size, 4) the moisture content of the clothes before 

entering the clothes dryer, and 5) the fraction of time the lower RMC option is used., These are 

described in greater detail below. 

The dryer energy (De) is defined as the amount of energy needed to completely dry the test 

load in a clothes dryer after the washer final spin cycle. The amount of energy needed to dry clothes 

after they are removed from the clothes washer depends on how much moisture is retained after the f 

final spin. The remaining moisture is specified as a percentage of the "bone dry" weight of a standard 

test load. For this analysis, a baseline RMC of 62% after the final spin cycle was assumed This is 

based on data AHAM submitted on shipment-weighted averages for a baseline washer. A 62% RMC 

means that the weight ofa wet test load weighs 62% more than a bone dry test load 0.62 x dry test 

load). After being dried in a clothes dryer, the test load is assumed to have a residual RMC of 4% 

The future DOE test procedure (Appendix 11) provides a table that specifies the maximum 

clothes load for a given size clothes washer. For a 2.9 to 3.0 ft3 washer, the maximum load is 12 1 

lbs. The average load to maximum load fraction, 0.52, was derived from Procter & Gamble data and 

made part of the proposed and future DOE test procedures. The dryer energy is sometimes also 

referred to as moisture removal energy. The equation describing the dryer energy is given below 

where~ 

De = LAF . (Max. Load) . (RMC - RMC4%) . Der ' DUF (E.l) 

LAF· = Load Adjustme11l FacIOI' = 0.52 

Max. Load = Maximum clothes load = 12.1 Ibs/cycle 

RMC = Remaining Moisture Content after final spin cycle, (expressed as a fraction) 

RMC4% = Remaining Moisture Contem with a 4% residual, (expressed as a fraction) 

Def = 0.5 kWhllb of moisture (nominal energy required for clothes dryer to remove 

moisture) 

DUF = Dlyer Usage Factor = 0.84. DUF is the ratio of dryer cycles to clothes 

washer cycles per year. 

Since it is not expected that consumers would use higher spin speed or other options to 

reduce the remaining moisture content 100% of the time, the future DOE test procedure 

E-1 
(Appendix J1) assumes that consumers will use the lower remaining moisture content option 75% of

the time and the baseline case of 62% remaining moisture content the remaining 25% of the time.

The adjusted dryer energy is shown in the equation below.

D = 0.75 D + 0.25 (E.2) e,adjusred 75 e,reduced + 25 62% (E.2)

where:

Derced, = the dryer energy required with using a improved moisture

extraction design option (lower RMC option).

De62% = the dryer energy required with the baseline RMC of 62%.

E-2

 EE-RM-94-403 COMMENT 50

(Appendix Jl) assumes that consumers will use the lower remaining moisture content option 75% of 

the time and ~he baseline case of 62% remaining mois~ure content the remaining 25% of the time. 

The adjusted dryer energy is shown in the equation below. 

'Where: 

De,adjuSred= 0.75'· De,reduced + 0:25 . D e,62% . (E.2) 

De. reduced 

De. 62% 

the dryer. energy required' with using a improved moisture 

extraction design option (lower RMC option). 

= the dryer. energy required' with the baseline RMC of 62%. - ' ",' . 

...... : 

E-2 
APPENDIX F. CLOTHES CONTAINER CAPACITY

Although the proposed DOE test procedure specifies different amounts of cloth test loads

varying with clothes container volume, for purposes of this analysis the amount of clothes washed

per cycle was assumed to be the same for all design options. Consideration was given to adjusting the energy use values to account for the slightly smaller horizontal axis clothes container capacity, and therefore, smaller test load size in accordance with the future DOE test procedure (Appendix J1).

However, because of disagreements over clothes container capacity measurement and clothes loading in vertical and horizontal axis washers, adjustments to the horizontal axis clothes container capacity

were not made.

With regard to vertical axis washers, clothes container capacity-as measured according to

the future DOE test procedure-includes volume above the water line. Some argue that including volume above the water line overstates the usable clothes container capacity. But others claim that

this volume should be included since clothes above the water level will be pulled down into the water

as they become wet and compacted. This of course assumes that clothes filled to this level will still

receive an adequate wash. With regard to horizontal axis washers, claims have been made that for

the available clothes container capacity, more clothes can be loaded into a horizontal axis washer than

in a vertical axis machine while still achieving satisfactory wash performance.

Another consideration for assuming a constant load size is to allow for fair comparisons

between different design options. For example, assuming a smaller clothes load for horizontal axis

washers would reduce its calculated wash and drying energy. This would overstate the energy savings of horizontal axis washers relative to that of vertical axis washers. It should be noted.

however, that the MEF normalizes the energy usage to the rated volume by dividing the clothes

container volume by the total energy use

F-i

 EE-RM-94-403 COMMENT 50

APPENDIX F. CLOTHES CONTAINER CAPACITY 

Although the proposed DOE test procedure specifies different amounts of cloth test loads 

varying with clothes container volume, for purposes of this analysis the amount of clothes washed 

per cycle was assumed to be the same for all design options. Consideration was given to adjusting 

the energy use values to account for the slightly smaller horizontal axis clothes container capacity, 

and therefore, smaller test load size in accordance with the future DOE test procedure (Appendix 11) 

However, because of disagreements over clothes container capacity measurement and clothes loading 

in vertical and horizontal axis washers, adjl:lstments to the horizontal axis clothes container capacity 

were not made. 

With regard to vertical axis washers, clothes container capacity-as measured according to 

the future DOE test procedure-includes volume above the water line. Some argue that including 

volume above the water line overstates the usable clothes container capacity. But others claim that 

this volume should be included since clothes above the water level will be pulled down into the water 

as they become wet and compacted. This of course assumes that clothes filled to this level will still 

receive an adequate wash. With regard to horizontal axis washers, claims have been made that for 

the available clothes container capacity, more clothes can be loaded into a horizontal axis washer than 

in a venical axis machine while still achieving satisfactory wash performance. 

Another consideration for assuming a constant load size is to allow for fair comparisons 

between different design options. For example, assuming a smaller clothes load for horizontal aXIs 

washers would reduce its calculated wash and drying energy. This would overstate the energy 

savings of horizontal axis washers relative to that of vertical axis washers. It should be noted. 

however, that the MEF normalizes the energy usage to the rated volume by dividing the clothes 

container volume by the total energy use. 

F-l