3

- i CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION

................................ ................................ ................................ ........... 3

- 1
3.2 PRODUCT DEFINITIONS

................................ ................................ ............................. 3

- 1
3.3 PRODUCT CLASSES

................................ ................................ ................................ ..... 3

- 1
3.4 PROD UCT TEST PROCEDURES

................................ ................................ ................. 3

- 2
3.5 MANUFACTURER TRADE G ROUPS

................................ ................................ ......... 3

- 3
3.5.1 Association of Home Appliance Manufacturers

................................ .............................. 3

- 3
3.5.2 Coin Laundry Association

................................ ................................ ............................... 3

- 3
3.5.3 Multi

- housing Laundry Association

................................ ................................ ................ 3

- 3
3.6 MANUFACTURER INFORMA TION

................................ ................................ ........... 3

- 4
3.6.1 Manufacturers and Market Shares

................................ ................................ ................... 3

- 4
3.6.2 Mergers and Acquisitions

................................ ................................ ................................ 3

- 4
3.6.3 Small Business Impacts

................................ ................................ ................................ ... 3

- 4
3.6.4 Distribution Channels

................................ ................................ ................................ ...... 3

- 5
3.7 REGULATORY PROGRAMS

................................ ................................ ....................... 3

- 6
3.7.1 Energy Policy Act of 2005

................................ ................................ ............................... 3

- 7
3.7.2 Energy Independence and Security Act of 2007

................................ .............................. 3

- 7
3.7.3 State Energy Conservation Standards

................................ ................................ .............. 3

- 8
3.7.4 Canadian Energy Conservation Standards

................................ ................................ ....... 3

- 8
3.7.5 International Standby Power Regulatory Programs

................................ ......................... 3

- 9
3.8 VOLUNTARY PROGRAMS

................................ ................................ ........................ 3

- 10
3.8.1 ENERGY STAR

................................ ................................ ................................ ............ 3

- 10
3.8.2 Consortium for Energy Efficiency

................................ ................................ ................. 3

- 11
3.8.3 Federal Energy Management Program

................................ ................................ .......... 3

- 11
3.8.4 Manufacturer Tax Credits for Energy

- Efficient Appliances

................................ ......... 3

- 11
3.8.5 Rebates for Highly Energy

- Efficient Products

................................ .............................. 3

- 12
3.9 HISTORICAL SHIPMENTS

................................ ................................ ......................... 3

- 13
3.9.1 New Multi

- Family Unit Starts

................................ ................................ ....................... 3

- 13
3.9.2 Unit Shipments

................................ ................................ ................................ ............... 3

- 14
3.9.3 AHAM Data

................................ ................................ ................................ ................... 3

- 15
3. 9.4 Imports and Exports

................................ ................................ ................................ ....... 3

- 17
3.10 HISTORICAL EFFICIENC IES

................................ ................................ ..................... 3

- 17
3.11 PRODUCT RETAIL PRICE S

................................ ................................ ....................... 3

- 18
3.12 INDUSTRY COST STRUCT URE

................................ ................................ ................ 3

- 20
3.13 TECHNOLOGY ASSESSMEN T

................................ ................................ .................. 3

- 20
3.13.1 Product Operations and Components

................................ ................................ ............. 3

- 20
3.13.2 Technology Options

................................ ................................ ................................ ....... 3

- 22
3.13.2.1 Adaptive water fill

................................ ................................ ....................... 3

- 23
3.13.2.2 Advanced agitation concepts for top

- loading machines

.............................. 3

- 23
3.13.2.3 Capacity increase

................................ ................................ ......................... 3

- 24
3.13.2.4 Direct

- drive motor

................................ ................................ ....................... 3

- 243

- ii

3.13.2.5 Higher spin speeds to reduce remaining moisture content

.......................... 3

- 25
3.13.2.6 Increased motor efficiency

................................ ................................ ........... 3

- 26
3.13.2.7 Ozonated laundering

................................ ................................ .................... 3

- 26
3.13.2.8 Polymer bead cleaning

................................ ................................ ................. 3

- 26
3.13.2.9 Spray rinse

................................ ................................ ................................ ... 3

- 27
3.13.2.10 Temperature

- differentiated pricing controls

................................ ................ 3

- 27
3.13.2.11 Thermostatically controlled mixing valves

................................ .................. 3

- 27
3.13.2.12 Water circulation loop

................................ ................................ .................. 3

- 28
3.13.3 Energy Efficiency

................................ ................................ ................................ .......... 3

- 28

LIST OF TABLES

Table 3.6.1 Major and Other Commercial Clothes Washer Manufacturers

................................ 3

- 4 Table 3.7.1 Energy Conservation Standards for Commercial Clothes Washers Established

by EPACT 2005

................................ ................................ ................................ ... 3

- 7 Table 3.7.2 Energy Conservation Standards for Commercial Clothes Washers Established

by January 2010 Final Rule

................................ ................................ ................. 3

- 7 Table 3.7.3 Current Canadian Energy Conse rvation Standards for Household

- Style

Commercial Clothes Washers

................................ ................................ .............. 3

- 9 Table 3.7.4 Current Canadian Standard Levels for High

- Efficiency Household

- Style

Commercial C lothes Washers

................................ ................................ .............. 3

- 9 Table 3.7.5 EU Ecodesign Requirements for Standby and Off Mode

................................ ....... 3

- 10
Table 3.8.1 ENERGY STAR Criteria for Commercial Clothes Washers

................................ . 3

- 11 Table 3.8.2 Manufacturer Tax Credits for Energy

- Efficient Clothes Washers, 2011

- 2013

...... 3

- 12
Table 3.9.1 New Multi

- Family Housing Unit Starts in the United States from 2000

- 2013

...... 3

- 14
Table 3 .9.2 Industry Shipments of Commercial Clothes Washers 2002

– 2011

......................... 3

- 15 Table 3.9.3 AHAM Commercial Clothes Washer Shipment

- Weighted Average Efficiency

Data Submitta l

................................ ................................ ................................ ... 3

- 15 Table 3.9.4 AHAM Top

- Loading Commercial Clothes Washer Market Share Efficiency

Data, 2010

- 2013

................................ ................................ ................................ . 3

- 16
Table 3.9.5 AHAM Front

- Loading Commercial Clothes Washer Market Share Efficiency

Data, 2010

- 2013

................................ ................................ ................................ . 3

- 16 Table 3.9.6 Import an d Export Data for Commercial Clothes Washers, 2003

- 2013

................. 3

- 17 Table 3.10.1 Energy Efficiency Trends for Commercial Clothes Washers, 2002

- 2011

........... 3

- 18
Table 3.11.1 Commercial Clothes Washer Retail Prices

................................ ........................... 3

- 19 Table 3.13.1 Design Options Removed fro m Consideration

................................ ..................... 3

- 22 Table 3.13.2 Technology Options for Residential Clothes Washers

................................ ......... 3

- 23

LIST OF FIGURES

Figure 3.6.1 Distribution Channel for Commercial Clothes Washers

................................ ......... 3

- 6 Figure 3.9.1 Multi

- Family Housing Unit Starts, 2000

– 2013

................................ ..................... 3

- 14 Figure 3.9.2 Annual CCW Shipments 2 002

- 2011

................................ ................................ ..... 3

- 153

- iii

Figure 3.9.3 Import and Export Trends for Commercial Clothes Washers, 2003

- 2013

............ 3

- 17 Figure 3.10.1 Energy Efficiency Trends for Commercial Clothes Washers, 2002

- 2011

.......... 3

- 18 Figure 3.13.1 Distribution of Commercial Clothe s Washers by MEF

................................ ...... 3

- 29 Figure 3.13.2 Distribution of Commercial Clothes Washers by WF

................................ ......... 3

- 293

- 1 CHAPTER 3. MARKET AND TECHNOLOG Y ASSESSMENT

3.1 INTRODUCTION

This chapter provides a profile of the commercial clothes washer (CCW) industr y in the United States. The U.S. Department of Energy (DOE) developed the market and technology assessment presented in this chapter primarily from publicly available information. This assessment is helpful in identifying the major manufacturers and their p roduct characteristics, which form the basis for the engineering and the life

- cycle cost (LCC) analyses. Present and past industry structure and industry financial information help DOE in the process of conducting the manufacturer impact analysis.

3.2 PRODUCT DEFINITIONS

The Energy Policy and Conservation Act of 1975, as amended, defines commercial
clothes washer s as follows:

The term “ commercial clothes washer ” means a soft

- mount, front

- loading or soft

- mount, top

- loading clothes washer that: A) has a clothes compartment that: i) for horizontal

- axis clothes washers, is not more than 3.5 cubic feet; and ii) for vertical

- axis clothes washers, is not more than 4.0 cubic feet; and B) is defined for use in: i) applications in which the occupants of more than 1 h ousehold will be using the clothes washer, such as multi

- family housing common areas and coin laundries;

o r ii) other commercial applications.

( 42 U.S.C. 6311(21))

3.3 PRODUCT CLASSES

DOE separate d commercial clothes washers into product classes and has for mulated separate energy conservation standard s for each class . The criteria for separation into different product classes are: (1) type of energy used; (2) capacity; or (3) other performance

- related features such as those that provide utility to the consum er, or others deemed appropriate by the Secretary that would justify the establishment of a separate energy conservation standard. (42 U.S.C. 6295 (q) and 6316(a) )

For the existing energy conservation standards, DOE defines two product classes for

commer cial clothes washers based on location of access:3

- 2

 Top

- loading

 Front

- loading

DOE maintains this product class distinction for the amended energy conservation standards adopted i n the final rule

.

3.4 PRODUCT TEST PROCEDU RES

The Energy Policy and Conservation Act (EPCA), Pub. L. 94

- 163, 42 U.S.C. 6291 et seq

, as amended, mandate s that the test procedures for commercial clothes washers shall be the same as the test procedures established by DOE for residential clothes washers (RCW) . (42 U.S.C. 6314(a)(8)). The DOE test procedure s for commercial clothes washers currently being
manufactured is codified at title 10 of the Code of Federal Regulations (CFR) pa rt 430, subpart B, appendix J1 (hereafter, “appendix J1”). On March 7, 2012, D OE published a final rule amending its test procedures for residential clothes washers ( “March 2012 final rule”)

. (77 FR
13888 ) The March 2012 final rule included minor amendments to appendix J1 and also established a new test procedure at appendix J2 (her eafter, “appendix J2”).

Beginning March 7, 2015, manufacturers of commercial clothes washers may use either appendix J1 or appendix J2 to demonstrate compliance with the current standards established by the January 2010 final rule . Manufacturers using ap pendix J2 would be required to use the conversion equations established in a separate test procedure rulemaking to translate the measured efficiency metrics into equivalent appendix J1 values. a The use of appendix J2 will be required to demonstrate complia nce with the amended energy conservation standards established by this final rule, and the conversion equations will no longer be used at that time

.

As described further in chapter 5 of this TSD, DOE also considered t he Association of Home Appliance Manufacturers (AHAM) test method HLW

- 1

- 2010, “Performance Evaluation Procedures for Household Clothes Washers” (referre d to here as “AHAM HLW

- 1

- 2010”), in order to evaluate potential impacts on cleaning and rinsing performance as a result of more stringent standard levels. AHAM HLW

- 1

- 2010 is typically used to measure the performance of residential clothes washers; however, given the similarity of CCWs covered in this rulemaking to RCWs, and through consultation with CCW manufacturers, DOE determined that AH AM HLW

1

- 2010 would be appropriate to use for comparison testing of CCWs. Specifically, DOE performed the soil/stain removal, rinsing effectiveness, and sand removal tests provided in

HLW

- 1

- 2010.

a Additional details regarding DOE’s test procedure rulemaking for commercial clothes washers are available at DOE’s rulemaking webpage: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=86 . All rulemaking documents
are also available at www.regulations.gov , under Docket # EERE

- 2013

- BT

- TP

- 00 0 2

.3

- 3

3.5 MANUFACTURER TRADE G ROUPS

DOE recognizes the importance of trade groups in disseminating information and promoting the interests of the industry that they support. To gain insight into the commercial
clothes washer industr y , DOE researched various associations available to manufacturers, supplier s, and users of su ch equipment.

DOE identified several trade groups that support, or have an interest in, the residential cooking product and/or CCW industries, including the Association of Home Appliance Manufacturers (AHAM), the Coin Laundry Association (CLA), and the M ulti

- housing Laundry Association (MLA).

3.5.1 Association of Home Appliance Manufacturers

AHAM, 1 formed in 1967, aims to enhance the value of the home appliance industry through leadership, public education and advocacy. AHAM provides services to its members
i ncluding government relations; certification programs; an active communications program; and technical services and research. In addition, AHAM conducts other market and consumer research studies and publishes periodic industry reports . AHAM also develops and maintains technical standards for various appliances to provide uniform, repeatable procedures for measuring specific product characteristics and performance features.

3.5.2 Coin Laundry Association

The CLA 2 is a trade association representing the 30,000 coin laundry owners in the United States and around the world. Since 1960, the CLA has provided education and service to the entrepreneurs of the coin laundry industry, promoted their business interests, and promoted the industry to the general public.

3.5.3 Multi

- housing Laundry Association

The MLA, 3 founded in 1959, is a trade association of operator and supplier companies providing professional laundry services for the multi

- housing industry. The MLA works for a favorable legislative and regulatory climate for the industry, facilitates the exchange of technical and business information among members, and demonstrates the value of the industry to target
markets.3

- 4

3.6 MANUFACTURER INFORMA TION

3.6.1 Manufacturers and Market S hares

DOE estimates that there are five domestic and two foreign manufacturers of the types of commercial clothes washers covered by this rulemaking. DOE estimates that two major manufacturers hold over 90 percent of the market share of commercial clothes washers covered by DOE standards: Alliance Laundry Systems LLC b and Whirlpool Corporation c

. Other
manufacturers include AB Electrolux, d Continental Girbau, Inc.

, General Electric, and LG

. Table
3.6

. 1 lists these manufacturers.

Table 3.6

. 1 Major and Other Commercial Clothes Washer Manufacturers

Major Manufacturers Other Manufacturers
Alliance Laundry Systems AB Electrolux
Whirlpool Continental Girbau

General Electric

LG

3.6.2 Mergers and Acquisitions

DOE described the merger between Whirlpool and Maytag, which was completed on March 31, 2006 , i n chapter 3 of the TSD accompanying the January 2010 final rule

. 4

On September 8, 2014, GE announced that it had signed an agreement to sell its appliance business to Electrolux for $3.3 billion. As part of the transaction, GE entered into a long

- term agreement with Electrolux to continue use of the GE Appliances brand. As of the date of the announcement, the transaction r emains subject to regulatory approvals, and is targeted to
close in 2015. 5

3.6.3 Small Business Impacts

DOE considers the possibility of small businesses being impacted by the promulgation o f energy conservation standards

. Based on the size standards published by the Small Business
Association (SBA) (65 FR 30840, May 15, 2000, as amended at 67 FR 52602, Aug. 13, 2002; 74 FR 46313, Sept. 9, 2009), to be categorized as a small business manufacturer of commercial
clothes washe rs under North American Industry Classification System (NAICS) 333318, “Other commercial and service industry machinery manufacturing,” a commercial laundry equipment

b Alliance Laundry Systems markets the following brands: Speed Queen, UniMac, Huebsch, and IPSO.

c Whirlpool also markets the Maytag brand. Whirlpool merged with Maytag on March 31, 2006.

d AB Electrolux also markets the Wascomat brand.3

- 5

manufacturer and its affiliates may employ a maximum of 1000 employees. The 1000

- employee threshold includes all employees in a business’s parent company and any other subsidiaries. Using this classification in conjunction with a search of industry databases and the SBA member directory, DOE did not identify any manufacturers of commercial clo thes washers that qualify as
small businesses.

DOE identified one low

- volume manufacturer (LVM) of commercial clothes washers. Unlike small business manufacturers, there is no employment limit associated with LVMs. Instead, LVMs are characterized by th eir low overall production volumes relative to their competitors, often associated with specialization within a singular industry. In 2012, the LVM derived 98 percent of its revenues from the sale of laundry equipment and service parts, while,
for its main competitor, this percentage was 30 percent. Within the clothes washer segment,
DOE estimates that the LVM derived 8 8 percent of its clothes washer equipment revenues from the sale of commercial clothes washers covered by this rulemaking. Because the comme rcial clothes washer industry itself is characterized by low total shipments, with less than 200,000 units sold annually in the U.S., the concentration of this manufacturer’s business in this industry qualifies them as an LVM. Where the LVM operates at a much smaller scale and does not manufacture products across a broad range of industries, this rulemaking could have disproportionate impacts on the LVM compared to its large, diversified competitors. Accordingly, DOE performed an in

- depth analysis of the i ssues relating to the commercial clothes washer LVM. The manufacturer subgroup analysis is discussed in greater detail in the final rule and in chapter 12 of this TSD.

3.6.4 Distribution Channels

Understanding the distribution channels of products covered by th is rulemaking is an important facet of the market assessment. DOE gathered information regarding the distribution
channels for commercial clothes washers from publicly available sources and through
discussions with manufacturers. Figure 3.6

. 1 illustrates the major CCW distribution channels

, which were originally described in a 1998 Consortium for Energy Efficiency (CEE) report describing their Commercial, Family

- Sized Clothes Washer Initiative

. 6 Through discussions with CCW manufacturers, DOE has determined that these distribution channels remain relevant for
the current CCW market.3

- 6 Figure 3.6

. 1 Distribution Channel for Commercial Clothes Washers

The 1998 CEE report state s that the CCW market can be divided into three areas, including: (1) laundromats; (2) private multi

- family housing; and (3) large institutions (e.g., military barracks, universities, and housing authorities.) Most large instit utions and a majority of private multifamily housing (between 50 and 90 percent) do not purchase clothes washers directly. Rather, these organizations lease their laundry space to a third party known as a route operator. Route operators supply laundry equi pment and maintain facilities in exchange for a percentage of the laundry revenue. Laundromats and some private building managers, conversely, will purchase clothes washers directly from distributors. The main difference between route operators and distrib utors is the length of service provided to their clients. Route operators provide on

- going support

, while distributor support ends at the point of sale

.

3.7 REGULATORY PROGRAMS

The following section details current regulatory programs mandating energy conserv ation
standards for CCWs

.3

- 7

3.7.1 Energy Policy Act of 2005

The Energy Policy Act of 2005 (EPACT 2005) , P.L. 109

- 58, amended EPCA to expand DOE’s energy conservation program to include commercial clothes

. This legislation established the first energy conservation standards for CCWs, shown in Table 3.7

. 1 , without consideration of separate product classes. These standards became effective January 1, 2007.

Table 3.7

. 1 Energy Conservati on Standards for Commercial Clothes Washers Established by EPACT 2005

Metric Standard Effective January 1, 2007

Modified Energy Factor (MEF), ft 3 /kwh/cycle 1.26 (minimum)

Water Factor (WF), gal/cycle/ft 3 9.5 (maximum)

EPACT 2005 further directed DOE to conduct two rulemaking cycles to determine whether to amend these standards: the first final rule was required by January 1, 2010, which was fulfilled by the January 2010 final rule. Table 3.7

. 2 show s the amended standard levels from the January 2010 final rule, which became effective January 8, 2013.

Table 3.7

. 2 Energy Conservation Standards for Commercial Clothes Washers Established by January 2010 Fin al Rule

Standard s Effective January 8, 2013

Equipment Class Modified Energy Factor (cu.ft./kWh/cycle) Water Factor (gal/cycle/cu.ft)
Top

- Loading ≥ 1.60 ≤ 8.5

Front

- Loading ≥ 2.00 ≤ 5.5

The s econd final rule is required by January 1, 2015 , which is fulfilled by the current rulemaking . ( 42 U.S.C. 6313 (e))

3.7.2 Energy Independence and Security Act of 2007

The Energy Independence and Security Act of 2007 (EISA 2007), Pub. L. No. 110

- 142

, amended EPCA to require any final rule for new or amended energy conservation standards for consumer products promulgated after July 1, 2010 to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) This requirement applies to residential clothes washers but does not apply to commercial clothes washers, which are covered under DOE’s energy conservation program for certain industrial equipment (42 U.S.C. 6311

- 6317). Specifically, when DOE adopts a standard for a covered consumer product after July 1, 2010 , it must, if justified by the criteria for adoption of standards under EPCA (42 U.S.C. 6295(o)), incorporate standby mode and off mode energy use into the standard, or, if that is not feasible, adopt a separate standard for such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)

- (B)) In the March 2012 final rule, DOE incorporated standby and off mode energy use with active mode energy use into an3

- 8

integrated metric, integrated modified energy factor (IMEF)

, contained in the new appendix J2 test procedure. Appendix J2 also retains provisions for calculating modified energy factor (MEF J2 ). The amended energy standard s for CCWs are based on MEF J2 , which does not incorporate standby and off mode power.

3.7.3 State Energy Conservation Standards

Prior to the passage of EPACT 200 5, several States proposed and adopted State

- level efficiency regulations for commercial clothes washers that are identical, or very similar, to EPACT 2005 regulations. Complete details of these State

- level regulations are available in chapter 3 of the TSD accompanying the January 2010 final rule. 7 The EPACT 2005 energy and water use standards for CCWs preempt any State efficiency standards since they became effective January 1, 2007. DOE is not aware of any State

- level energy conservation programs for

comm ercial clothes washers since the standards from EPACT 2005 became effective

.

3.7.4 Canadian Energy Conservation Standards

The Canadian government regulates the efficiency of household

- style commercial clothes
washers

. The standard levels are contained in Table 11 of the Canadian S tandard Association (CSA) C360

- 13 test method (“CSA C360

- 1 3”), Energy performance, water consumption and capacity of household clothes washers

. 8 CSA C360

- 1 3 defines household

- style commercial
clothes washers as follows:

Household style commercial clothes washer means a soft

- mounted front

- loading or soft

mounted top

- loading clothes washer that is designed for use in

— (i) Applications in which the occupants of more than one household will be using the clothes washer, such
as multi

- fam ily housing common areas and coin laundries; or (ii) other commercial applications

.

Table 3.7

. 3 shows t he currently applicable regulations for household

- style commercial
clothes washers from Table 1 1 of CSA C360

- 1 3. These standards are harmonized with the U.S.
standards that became effective January 8, 2013.3

- 9

Table 3.7

. 3 Current Canadian Energy Conservation Standards for Household

- Style
Commercial Clothes Washers

Standard s Effective J anuary 8, 2013

Equipment Class Modified Energy Factor, L/kWh/cycle (cu.ft./kWh/cycle) Water Factor, L/cycle/L (gal/cycle/cu.ft)

Vertical

- axis ≥ 45.31 ( ≥ 1.6) ≤ 1.13

(≤ 8.5)

Horizontal

- axis ≥ 56.63 (≥ 2.0) ≤ 0.73

(≤ 5.5)

Canada also defines voluntary standard levels for high

- efficiency household

- style
commercial clothes washers in Table 13 of CSA C360

- 1 3 . These standards , shown in Table
3.7

. 4 , are consistent with the U.S. ENERGY STAR version 6.0 standards as described later in
th is chapter. These high

- efficiency standard levels are not defined by product class.

Table 3.7

. 4 Current Canadian Standard Levels for High

- Efficiency Household

- Style
Commercial Clothes Washers

Standard s Effective February 1 , 2013

Equipment Class Modified Energy Factor, L/kWh/cycle (cu.ft./kWh/cycle) Water Factor, L/cycle/L (gal/cycle/cu.ft)

Household

- style commercial
clothes washers ≥ 62.3 ( ≥ 2.2 ) ≤ 0.6

(≤ 4 .5)

CSA C360

- 13 does not yet contain updated standards for household

- style commercial clothes washers based on appendix J2. DOE believes that such standards may be harmonized with the final standards promulgated as a result of this rulemaking, and would be incorp orated
into CSA C360

- 13 shortly thereafter.

3.7.5 International Standby Power Regulatory Programs

The International Energy Agency (IEA) has raised awareness of standby power through publications, international conferences, and policy advice to governments. In 1999, the IEA developed the “1

- Watt Plan,” which proposed reducing standby power internationally in electronic devices and which advocates that all countries harmonize energy policies and adopt the same definition and test procedure. The IEA has advocated a 1 watt (W) requirement for all consumer electrical products (unless specifically excluded) in standby mode. The IEA also stated that IEC 62301 provides an internationally sanctioned definition and test procedure for standby power which is now widely spec ified and used. 93

- 10

The European Union passed the Ecodesign Directive in 2005 which calls for an implementing measure to reduce standby power for a specified list of energy using products,
which include household clothes washers. DOE does not believe that th ese regulations would apply to commercial clothes washers. On December 18, 2008, the Commission of the European Communities published Commission Regulation (EC) No 1275/2008 containing Ecodesign requirements for standby and off mode electric power consumpt ion of electrical and electronic household and office equipment

. Table 3.7

. 5 presents the requirements for energy consumption in standby and off mode power

. 10

Table 3.7

. 5 EU Ecodesign Requirements for Standby and Off M ode

Mode Maximum Power ( Watts )
Tier 1 ( effective January 07, 2010 )

Off (no function) 1.0 W
Standby (only reactivation function) 1.0 W
Standby (information or status display plus reactivation function ) 2.0 W
Tier 2 ( effective January 07, 2013 )
Off (no function) 0.5 W
Standby (only reactivation function) 0.5 W
Standby (information or status display plus reactivation function ) 1.0 W

3.8 VOLUNTARY PROGRAMS

DOE reviewed several voluntary programs promoting commercial clothes washers in the United States. Many programs, including ENERGY STAR, CEE, and the Federal Energy Management Program ( FEMP ) , establish voluntary energy conservation stan dards for these products.

3.8.1 ENERGY STAR

ENERGY STAR, a voluntary labeling program backed by the U.S. Environmental Protection Agency (EPA) and DOE, identifies energy efficient products through a qualification

process. To qualify, a product must exceed Federa l minimum standards by a specified amount, or if no Federal standard exists, exhibit selected energy saving features. The ENERGY STAR program works to recognize the top quartile of products on the market, meaning that approximately 25 percent of products o n the market meet or exceed the ENERGY STAR levels. ENERGY STAR specifications exist for several products, including commercial clothes washers.

ENERGY STAR criteria exist for commercial clothes washers with capacities greater
than 1.6 cubic feet. 11 New criteria for CCWs became effective on February 1, 2013, shown
below in Table 3.8

. 1

. The ENERGY STAR program does not distinguish between product

c lasses for CCWs.3

- 11

Table 3.8

. 1 ENERGY STAR Criteria for Commercial Clothes Washers

Standard s Effective February 1, 2013

Equipment Type Modified Energy Factor (cu.ft./kWh/cycle) Water Factor (gal/cycle/cu.ft)

Commercial Clothes Washers ≥ 2.2 ≤ 4 .5

3.8.2 Consortium for Energy Efficiency

The CEE 12 develops initiatives for its North American members to promote the manufacture and purchase of energy efficient products and services. The goal of the organization
is to induce lasting structural and behavioral changes in the marketplace, resulting in the increased adoption of energy efficient technologies. CEE has historically maintained a Commercial Clothes Washer Initiative that encourages the purchase and use of energy and water
efficient commercial clothes washers. Given recent changes to federal minimum efficiency standards and ENERGY STAR criteria for commercial clothes washers, the CEE Commercial Clothes Washer Specif

ication is not currently active. As a result, pub lication of the associated qualifying product list is also temporarily suspended. According to information on the CEE website, the specification will be reinstated once the revised levels are finalized through the CEE specification revision process. CEE an ticipates that this will be completed by the end of 2014

.

3.8.3 Federal Energy Management Program

DOE’s FEMP 13 works to reduce the cost and environmental impact of the Federal government by advancing energy efficiency and water conservation, promoting the use o f distributed and renewable energy, and improving utility management decisions at Federal sites. FEMP helps Federal buyers identify and purchase energy efficient equipment, including
commercial clothes washers.

The National Energy Conservation Act (P.L. 95

- 619), Executive Order 13423

, and Federal Acquisition Regulations Subpart 23.2 and 53.223 require that Federal agencies purchase
ENERGY STAR

- qualified products. Currently, the FEMP recommendations for commercial clothes washers are equivalent to the ENER GY STAR standard levels described above.

3.8.4 Manufacturer Tax Credits for Energy

- Efficient Appliances

EPACT 2005 amended the Internal Revenue Code of 1986 (26 U.S.C. 1 et seq. ) to establish a tax credit to manufacturers for the production in the United States of energy efficient CCWs. (26 U.S.C. 45M(b)(1)(B)) A credit of $100 was established for CCWs manufactured in the calendar year 2006 or 2007 which met the ENERGY STAR qualifying criteria in effect in 2007. The total credit for CCWs was equal to an applicabl e credit amount multiplied by the eligible production, subject to a $75 million limit, reduced by the amount of credit taken in previous years. The eligible production for CCWs equaled the number of appliances produced in3

- 12

a year divided by the average numb er of appliances produced during the preceding 3

- calendar

year period.

The Energy Improvement an d Extension Act of 2008 (Pub. L. 110

- 343; Oct. 3, 2008) further amended the Internal Revenue Code of 1986 to modify and extend the manufacturer tax
credits for CCWs to apply to equipment produced in calendar years 2008, 2009, or 2010. (26 U.S.C. 45M(b)(2)) Eligible production wa s calculated over a 2

- calendar

- year period and the total credit limit calculation was reduced by the amount of credit taken in prior yea rs beginning after December 31, 2007. Further, the aggregate credit amount did not apply to CCWs meeting or exceeding 2.2 MEF/4.5 WF. (26 U.S.C. 45M(c)(2) and (e))

The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (Pub. L. 111

- 312) and the American Taxpayer Relief Act of 2012 (Pub. L. 112

- 240) further extended the manufacturing tax credits for all clothes washers, including CCWs, through 2013. ( 26 U.S.C. 45M(b)(2 )(B Table 3.8

. 2 shows the applicable tax credit amounts based on MEF and

WF. Although CCWs are eligible to receive these tax credits, DOE’s market survey conducted for this rulemaking indicates that no top

- loading or front

- loading CCWs on the market achieve
the MEF and W F levels required to receive the tax credits.

Table 3.8

. 2 Manufacturer Tax Credits for Energy

- Efficient Clothes Washers, 2011

- 2013

Equipment Type Modified Energy Factor (cu.ft./kWh/cycle) Water Factor (gal/c ycle/cu.ft) Credit

Amount
Top

- Loading Clothes Washers 1 ≥ 2.2 ≤ 4 .5 $175

Top

- Loading Clothes Washers ≥ 2.4 ≤ 4

. 2 $225

Front

- Loading Clothes Washer ≥ 2.8 ≤ 3.5 $225

1. Effective only in 2011

3.8.5 Rebates for Highly Energy

- Efficient Products

States, e lectric utilities , municipalities, and other organizations promote the purchase of highly energy

- efficient commercial clothes washers through consumer rebates. Typically, these programs offer rebates for products meeting existing ENERGY STAR efficiency levels . DOE jointly manages the Database of State Incentives for Renewables & Efficiency (DSIRE), which lists the financial incentives available in each state for purchasing energy

- efficient products, including CCWs. 143

- 13

3.9 HISTORICAL SHIPMENTS

Awareness of annual product shipment trends is an important aspect of the market assessment and in the development of the standards rulemaking. DOE reviewed data collected by
the U.S. Census Bureau and AHAM to evaluate commercial clothes washer product shipment
trends and the value o f these shipments, which were used during the shipments a nalysis (chapter 9 of this TSD).

3.9.1 New Multi

- Family Unit Starts

Trends in multi

- family unit starts can affect shipments of commercial clothes washers.
Table 3.9

. 1 an d Figure 3.9

. 1 show the number of new multi

- family housing units (with 5 units or more)
started in the United States from 2000

- 201 3

. 15 Over the 5

- year period from 2000

– 2005, multi

family unit starts remained stable at around 300,000 units annually. B etween 2005 and 200 9

, multi

- family unit starts decreased significantly to around 100,000 units annually. Since 2009,
multi

- family unit starts have increased steadily, reaching almost 30 0,000 in 201 3

.3

- 14

Table 3.9

. 1 New Multi

- Family Housing Unit Starts in the United States from 2000

- 201 3

Year Multi

- Unit Housing Starts (000’s)

Figure 3.9

. 1 Multi

- Family Housing Unit S tarts, 2000

– 201 3 2000 299

2001 293

2002 308

2003 315

2004 303

2005 311

2006 293

2007 277

2008 266

2009 98

2010 104

2011 167

2012 234

2013 294

3.9.2 Unit Shipments

AHAM provided shipment estimates during the last rulemaking for the period 2002

- 2005, and during the current rulemaking for the period 201 0

- 201 3 , as presented in Table 3.9

. 2
and Figure 3.9

. 2 below

. 16 After steadily declining from 191,000 total shipm ents in 2003 to 161,000 in 2011, total shipments increased to 206,000 in 2013. This increase was largely driven by an increase in top

- loading sales.3

- 15

Table 3.9

. 2 Industry Shipments of Commercial Clothes Washers 2002

– 201 1

Shipments (000’s)

Figure 3.9

. 2 Annual CCW Shipments 2002

- 2011 Year Total Top

Load Front

Load

2002 175 n/a n/a

2003 191 n/a n/a

2004 178 n/a n/a

2005 177 n/a n/a

2006 n/a n/a n/a

2007 n/a n/a n/a

2008 n/a n/a n/a

2009 n/a n/a n/a

2010 164 104 60

2011 161 107 54

2012 173 120 53

2013 206 151 55

3.9.3 AHAM Data

AHAM also provide shipment

- weighted average efficiency levels disaggregated by product class for 2010 through 2013 , as shown in Table 3.9

. 3

. During this period, weighted MEF has steadily increased for both top

- loading and front

- loading CCWs. A HAM stated in its data submission that the increase in weighted WF for top

- loading CCWs in 2012 and 2013 is due to
sell

- through of older models. Weighted WF for front

- loading CCWs has steadily decreased during the period 2010

- 2013.

Table 3.9

. 3 AHAM Commercial Clothes Washer Shipment

- Weighted Average Efficiency
Data Submittal

Top

- Loading Front

- Loading

Year Weighted MEF Weighted WF Weighted MEF Weighted WF

2010 1.36 9.10 2.19 4.68

2011 1.32 9.33 2.31 4.43

2012 1.28 9.77 2.34 4.36

2013 1.46 9.63 2.38 4.053

- 16

AHAM also provided market share efficiency data for top

- loading and front

- loading
commercial clothes washers for 2010 through 201 3 , as shown in Table 3.9

. 4 and Table 3.9

. 5

. The submitted values represent the market shares for clothes washers up to the listed efficiency
levels.

Table 3.9

. 4 AHAM Top

- Loading Commercial Clothes Washer Market Share Efficiency
Data , 2010

- 2013

Top

- Loading
Efficiency Bins Market Share (%)

MEF WF 2010 2011 2012 2013

1.26 9.5 82% 80% 77% 43%

1.42 9.5 18% 20% 22% 0%

1.60 8.5 0% 0% 1% 57%

Notes:
1. Models with MEF/WF data not meeting the criteria for both MEF and WF for any of the Efficiency Bins in the table above were included in the Efficiency Bin for which the value of the lesser efficient, MEF or WF, is satisfied. For example, a model with a MEF = 1.60 and WF = 9.0 would have been included in the
1. 42/9.5 Efficiency Bin.
2. The 2013 data for the 1.60/8.5 Efficiency Bin includes products with higher efficiency levels up to and including the maximum efficiency level available on the market.

Table 3.9

. 5 AHAM Front

- Loading Commercial Clothes Washer Market Share Efficiency
Data , 2010

- 2013

Front

- Loading
Efficiency Bins Market Share (%)

MEF WF 2010 2011 2012 2013

< 1.72 > 8.0 2% 0% 0% 0%

1.72 8.0 1% 0% 0% 0%

1.80 7.5 1% 0% 0% 0%

2.00 5.5 28% 28% 30% 0%

2.20 5.1 68% 34% 20% 31%

2.40 4.0 0% 38% 50% 69%

2.60 3.7 0% 0% 0% 0%

Notes:
1. Models with MEF/WF data not meeting the criteria for both MEF and WF for any of the Efficiency Bins in the table above were included in the Efficiency Bin for which the value of the lesser efficient, MEF or WF, is satisfied. For example, a model with a MEF = 2.01 and WF = 5.6 would have been included in the
1. 80/7.5 Efficiency Bin.3

- 17

3.9.4 Import s and Exports

DOE obtained import and export data from the U.S. International Trade Commission’s
DataWeb database. 17 Table 3.9

. 6 and Figure 3.9

. 3 sho w the number of coin

- operated commercial clothes washer imports and exports for the period 2003

- 2013. The quantity of exports is substantially greater than imports. Exports have generally decreased from a peak of aroun d 120,000 units in 2005 to around 56,000 units in 2013. Imports have generally increased from around 3,800 units in 2003 to around 6,500 units in 2013.

Table 3.9

. 6 Import and Export Data for Commercial Clothe s Washers, 2003

- 2013

Unit Shipments

Figure 3.9

. 3 Import and Export Trends for Commercial Clothes Washers, 2003

- 2013 Year Imports Exports

2003 3,780 112,110

2004 3,793 109,307

2005 3,499 120,856

2006 2,113 94,841

2007 4,581 88,382

2008 3,543 77,195

2009 2,858 54,513

2010 6,264 46,006

2011 5,701 52,391

2012 12,037 56,409

2013 6,543 56,227

3.10 HISTORICAL EFFICIENC IES

Table 3.10

. 1 and Figure 3.10

. 1 sho w the shipment

- weighted trend in MEF from 2002

- 201 3

. This data was provided by AHAM during the last rulemaking for the period 2002

- 2005, and during the current rulemaking for the period 201 0

- 201 3

. The increase in weighted efficiency in 2013 is due to the amended energy conservation standards that became effective January 8,
2013. 0 20 40 60 80 100 120 140 Shipments (thousands)

Year Exports

Imports3

- 18

Table 3.10

. 1 Energy Efficiency Trends for Commercial Clothes Washers, 2002

- 2011

Shipment

- Weighted
MEF

Figure 3.10

. 1 Energy Efficiency Trends for Commercial Clothes Washers, 2002

- 2011 Year Total Top

Load Front

Load

2002 1.30 n/a n/a

2003 1.33 n/a n/a

2004 1.33 n/a n/a

2005 1.41 n/a n/a

2006 n/a n/a n/a

2007 n/a n/a n/a

2008 n/a n/a n/a

2009 n/a n/a n/a

2010 1.66 n/a n/a

2011 1.65 1.36 2.19

2012 1.60 1.28 2.34

2013 1.71 1.46 2.38

3.11 PRODUCT RETAIL PRICE S

DOE conducted a search of retail prices for CCWs by contacting several CCW distributors by phone and by gathering pricing data for CCW models available for sale on the Internet. Table
3.11

. 1 summarizes the data collected by DOE. Where DOE obtained multiple prices for the same model, the average price is shown in the table.3

- 19

Table 3.11

. 1 Commercial Clothes Washer Retail Prices

Manufacturer Model Product Class Control Panel Type Payment System

Type Vendor Price

GE WNRD2050G Top

- Loading No Vend Display None AppliancesDirect.com $682

Alliance Laundry Systems SWNSX2PP112TW01 Top

- Loading No Vend Display Coin Box Appliances Direct $909

Alliance Laundry Systems SWNBC2PP112TW01 Top

- Loading Vend Price Display Coin Box Appliances Direct $1,052

Alliance Laundry Systems SWNLC2PP112TW01 Top

- Loading Vend Price Display Coin Box Appliances Direct $1,086

Whirlpool CAE2743BQ Top

- Loading No Vend Display Coin Slide Home Depot $764

Whirlpool MHN30PDBWW Front

- Loading Vend Price Display Coin Box Appliances Connection $1,579

Whirlpool CHW8990AW Front

- Loading Vend Price Display Coin Box Whirlsource.com $1,225

Alliance Laundry Systems SFNLCFSP* Front

- Loading Vend Price Display Coin Box Yankee Equipment $1,900

Alliance Laundry Systems SFNNCFSP* Front

- Loading Vend Price Display Coin Box Yankee Equipment $1,900

LG GCW1069* Front

- Loading No Vend Display None Daniels Equipment $1,695

GE WNRD2050G Top

- Loading No Vend Display None AppliancesDirect.com $682

Alliance Laundry Systems SWNSX2PP112TW01 Top

- Loading No Vend Display Coin Box Appliances Direct $9093

- 20

Based on its market survey, DOE determined that retail price is largely a function of the type of loading (i.e., top

- loading or front

- loading) as well as whether the unit offers a control panel that displays vend price. Vend price display units would be pr imarily sold to Laundromats
and multi

- family housing laundries; whereas units with no vend price display would be used mostly in other commercial applications where fare is not charged.

As discussed further in c hapter 8 of the TSD, DOE used manufacturing costs developed for specific standard levels in combination with manufacturer and distributor markups, sales taxes, and installation costs to establish the total installed cost differences between baseline and

mo re efficient commercial clothes washers. DOE used the above range in current retail price differences between top

- loading and front

- loading clothes washers as an indication of the reasonableness of the total installed cost estimates that it developed for r esidential clothes
washers.

3.12 INDUSTRY COST STRUCT URE

Chapter 12 of this TSD provides a detailed financial analysis of the industry cost
structure for commercial clothes washers. This analysis identifies key financial inputs including cost of capital, working capital, depreciation, and capital expenditures.

3.13 TECHNOLOGY ASSESSMEN T

The purpose of the technology assessment is to understand how the product uses energy and potential changes that could reduce energy consumption. DOE typically uses information about “technology options”

— existing technologies and prototype designs and concepts

— to identify technologies product manufacturers could use to attain higher energy efficiency levels.

3.13.1 Product Operations and Components

In preparation for the screening and engineering analyses, DOE prepared a brief description of the characteristics and operation of commercial clothes washers

. These descriptions provide a basis for understanding the technologies used to improve product efficiency.

Commercial clothes washers are appliances designed to clean clothes by using a solution of soap and/or detergent and water with mechanical agitation. Clothes washers use electricity to operate one or more pumps and to power an electric motor that agitates and spins the clothes.
Clo thes are washed, rinsed, and spun within a tub that is inside a cabinet. Because clothes washers require heated water for hot and warm water cycles, a separate water heater is typically needed to supply hot water. Most of the energy used by clothes washers is for water heating. Water is fed into the clothes washer through electrically operated water valves, one connected to a hot water supply line and a second connected to a cold water supply line.3

- 21

Traditional top

- loading clothes washers have an opening on the top of the cabinet, covered by a door, which gives access to the inner basket where the load to be washed is placed. The inner basket is typically perforated and is surrounded by a larger outer tub which holds the water when the machine is running. Th e inner basket typically contains an agitator along a vertical axis, which undergoes a reversing circular motion. The motion of the agitator, which is powered by an electric motor, circulates the clothes vertically from the bottom to the top of the
basket. The spinning action of the inner basket and the drain pump are also powered by the motor. Traditional top

- loading clothes washers use more water than other types of washers, and therefore, consume more energy during heated wash cycles. They also typically extract less water from laundry during the spin cycle, which results in longer drying time and greater overall energy consumption.

Non

- agitator top

- loading clothes washers may have a “wash plate” rather than an agitator
to move the clothes within the bas ket. These top

- loading clothes washers function by partially filling the tub with water for wash and rinse cycles and using very high spin speeds to extract rinse water from the clothes during the spin cycle. These top

- loading clothes washers are more
effi cient in terms of water and energy than traditional top

- loaders, but their high spin speeds that reduce drying time (and thus dryer energy consumption) may wrinkle clothing more than traditional top

- loader spin speeds. These machines work best with low

- foa ming, high efficiency detergent.

Front

- loading clothes washers utilize a cylindrical tub or drum rotating on a horizontal or nearly

- horizontal axis to wash clothes. Clothes are usually loaded along the axis of the cylindrical drum, which has led to this t ype of clothes washer to be called a front

- loader. The clothes are cleaned by tumbling them in the water (i.e., clothes are lifted to the top of the drum by the rotation of the cylinder and then dropped into the water below.) The cylindrical drum is only p artially filled with water for wash and rinse cycles. High spin speeds are used to extract the water from the clothes during the spin cycles. These clothes washers are typically more efficient in terms of water and energy than traditional top

- loaders, but as with non

- agitator top

- loading clothes washers, their high spin speeds may wrinkle clothing.

Manufacturers typically base CCWs on existing RCW platforms. This simplifies fabrication and assembly ( e.g . commercial and residential clothes washers can be as sembled on the same assembly line), and helps reduce the fixed costs associated with tooling, overhead etc. for the (typically) much lower CCW manufacturing volumes. However, some CCW components are selectively upgraded to make them more rugged, reliable, and vandal

- resistant. Furthermore,
the user i nterface is usually simplified ( presenting the commercial user with fewer wash choices than a residential user) and the control system is designed to interface with various payment systems (ranging from coin slides to magnetic card readers). Lastly, the wash cycles may be redesigned to a llow satisfactory operation in an approximately 30

- minute wash cycle

.3

- 22

3.13.2 Technology Options

In order to gain a deeper understanding of the technological improvements used to increase the efficiency of commercial clothes washers, DOE identified several possibl e technologies and examined the most common improvements used in today’s market.

For the technology assessment for this rulemaking, DOE considered a subset of the design options considered during the previous CCW s tandards rulemaking. Based on informatio n published in recent trade publications, technical reports, manufacturer literature, and through product teardowns, DOE has observed that the results of the technology screening analysis performed during the previous rulemaking remain largely relevant for this rulemaking. After further analysis of the both the CCW and RCW market s an d discussions with manufacturers of
both CCWs and RCWs

, DOE concluded that some of the technologies previously included in the analysis are not considered “technology options” f or improving efficiency because they have negligible or no impact on the energy efficiency of a commercial clothes washer. Table 3.13

. 1 lists the specific technologies DOE eliminated from consideration and provides a brief justification for each.

Table 3.13

. 1 Design Options Removed from Consideration

Design Option Removed
from Consideration Justification for Removal

Adaptive control systems (not including adaptive water fill controls) DOE is not aware of any adaptive control systems for commercial clothes washers other than adaptive water fill controls, which are considered a separate design option. In addition, DOE h as not found any indications of adaptive control systems being used to achieve energy savings in clothes washers.

Horizontal

- axis design This would be considered a design option only if DOE were to eliminate the product class distinction based on axis of loading. However, DOE has retain ed two separate product classes, top

- loading and front

- loading. Improved horizontal

- axis washer drum design DOE does not have any data to suggest that changes to a horizontal

- axis drum design could provide improvements in efficiency (e.g. drum shape or hole patterns). Low standby power controls DOE is proposing amended energy standards based on the MEF J2 metric, which would exclude measurement of standby and off mode power.

Reduced thermal mass DOE has not found any data indicating potential energy savings due to reduced thermal mass of the wash basket or outer wash tub. DOE believes any such energy savings would be negligible. Silver ion injection DOE has determined that silver ion injection technology is no longer avail able
on the market for residential clothes washers and has not been considered as a technology option for commercial clothes washers. Tighter tub tolerance DOE’s engineering analyses for prior rulemakings have indicated that manufacturers have already ach ieved the maximum feasible reduction in spacing between the wash basket and outer was tub, leaving little, if any, room for improvement.

Based on comments received from interested parties in response to the framework document, DOE added temperature

- dif ferentiated pricing controls as a technology option for
consideration. Table 3.13

. 2 shows the complete list of technology options considered by DOE in3

- 23

the technology assessment. Detailed descriptions of each technology option are prov ided after
the table.

Table 3.13

. 2 Technology Options for Residential Clothes Washers

1. Adaptive water fill

2. Advanced agitation concepts for top

- loading machines

3. Capacity increase

4. Direct

- drive motor

5. Higher spin speeds to reduce remaining moisture content

6. M otor efficiency improvements

7. Ozonated laundering

8. Polymer bead cleaning

9. Spray rinse or similar water

- reducing rinse technology

10. Temperature

- differentiated pricing controls

11. Thermostatically controlled mixing valves

12. W ater re circulation loop

3.13.2.1 Adaptive water fill

Adaptive water fill controls incorporate advanced control technologies to sense the size
of the clothing load and adjust the water level accordingly. This technology option can overcome the tendency of consumers to manually select a water level greater than required for a given load. The most common implementation is a water level pressure sensor, which meas ures the pressure of the pooled water at the bottom of the tub. During the water fill portion of the cycle, dry clothing absorbs most of the incoming water. As the clothes become saturated, water begins pooling in the bottom of the wash tub. Once the poole d water reaches a predetermined height, the pressure will trigger the sen sor to shut off the water flow.

This technology is used primarily to save water; however, energy is also saved by reducing the amount of hot water used in the wash cycle. DOE testi ng indicates that for top

loading clothes washers, adaptive water fill controls can provide to up 50% energy and water savings compared to clothes washers with manual water fill controls. Nearly all front

- load clothes washers already implement adaptive wat er fill controls, but higher efficiency can be achieved by implementing more sensitive water level pressure sensors. DOE estimates that such sensors can provide around 10% additional energy and water savings for those machines that already have adaptive water fill control.

3.13.2.2 Advanced agitation concepts for top

- loading machines

Advanced agitation designs replace the standard agitator found in traditional top

- loading clothes washers. The most common implementation of this technology is a rotating “impeller” wash plate at the bottom of the drum. A traditional agitator requires clothing to be fully suspended in water; as the agi tator rotates, the agitator vanes catch the clothing and move the garments through the wate a r. A rotating wash plate, however, requires a much lower water level3

- 24

inside the wash tub to clean the clothing properly. The wet clothing load sits on top of the wa sh plate, and as the wash plate rotates, raised fins catch the clothing along the bottom of the wash tub to rotate the garments. If the wash tub contains too much water and the clothing becomes suspended in water, the wash plate is unable to r otate the clo thing effectively. DOE believes that the lack of a standard agitator may encourage machine overloading in a coin laundry environment, and that this technology is more susceptible to producing poorer wash performance when overloaded compared to a traditiona l agitator design.

As with adaptive water fill controls, impeller wash plates are used primarily to save water; however, energy is also saved by reducing the amount of hot water used in the wash cycle. In addition, the absence of the agitator increases t he available capacity for the same size wash tub. Advanced agitation systems add considerable complexity to the control strategies for
top

- loading clothes washer s.

DOE has identified only one top

- loading commercial clothes washer, manufactured by Whirlpo ol, that uses an advanced agitation concept. This clothes washer uses a rotating wash plate in combination with a vane

- less agitator column, which is intended primarily to prevent

over

- loading of the machine by the end user.

DOE testing indicates that th e use of impeller wash plates can directly contribute around 10% energy and water savings in top

- loading clothes washers.

3.13.2.3 Capacity increase

Implementing a larger tub capacity can contribute to improved efficiency because a larger amount of clothing can be washed using an incremental increase in the quantity of water that is less than the incremental increase in capacity, therefore reducing the amount of water an d energy per pound of clothing. DOE estimates that increased capacity can contribute around 10

- 1 5% energy and water savings.

End

- users typically value larger capacity clothes washers, so increases in tub capacity provide increased end

- user utility. However, a larger clothes container capacity may be
considered a detriment to coin

- operated laundry o wners and route operators because a larger capacity tub may result in fewer wash cycles performed by the end

- user customer. In competitive markets, coin

- operated laundries may not be able to sustain higher vend fares to compensate for
the lower number of “ turns” per day. In addition, based on discussions with manufacturers, larger tub capacities may encourage the over

- loading of machines by end

- user customers. Because of these perceived negative impacts on utility, unlike the residential clothes washer
mark et, manufacturers may not be willing to aggressively increase tub volumes in order to achieve higher efficiency levels.

3.13.2.4 Direct

- drive motor

A baseline clothes washer typically uses a relatively simple and inexpensive single

- speed
or dual

- speed capacitor

- st art induction motor, in combination with a mechanical transmission,3

- 25

and sometimes a pulley belt. A direct

- drive motor can replace this conventional motor/transmission system. Rather than using a belt and/or transmission, a direct

- drive motor is mounted directly to the wash tub along the axis of rotation, thus directly driving the rotation of the wash tub and eliminating transmission and/or g earbox losses. A direct drive motor for a clothes washer is typically a variable

- sp eed, electronically

- controlled permanent magnet motor.

DOE has observed increasingly widespread use of direct

- drive motors in the residential clothes washer market, particularly for front

- loading clothes washers and high

- efficiency top

loading clothes wa shers. DOE has identified only one front

- loading commercial clothes washer, manufactured by LG, that uses a direct drive motor.

DOE testing indicates that direct

- drive permanent magnet motors can reduce a clothes washer’s motor energy consumption by up t o 50 percent ; however, because motor energy represents such a small porti on of overall clothes washer ene rgy, tota l energy is reduced by roughly five percent.

3.13.2.5 Higher spin speeds to reduce remaining moisture content

The clothes washer test procedure requi res measuring the remaining moisture content of the clothing load, which is calculated as:

where W c is the weight of the test cloth immediately after completion of the washer spin cycle,
and W i is the “bone dry” weight of the test cloth. The RMC measurement is used to determine the estimated drying energy that would be needed to dry the clothes in a n electric clothes dryer after the wash cycle is complete. The drying energy is included in the ME F equation to encourage manufacturers to reduce the remaining moisture content of the clothing coming out of the clothes washer, since that will subsequently result i n clothes dryer energy savings.

The most common ways to reduce the RMC include increasin g the spin speed of the wash basket for the final spin cycle, or using a longer spin cycle. Since increas ing the duration of the spin cycle would result in a longer total cycle time, which w ould negatively impact consumer utility, manufacturers focus mainl y on increasing the spin speed of the final spin cycle. Implementing faster spin speeds requires more advanced motor technologies, including electronic feedback sensing; stronger tub materials such as stainless steel; more robust bearings;
and consumer saf

ety protections such as locking lids.

Since mechanical water removal is more energy efficient than using heat to evaporate it

, overall energy consumption for the combined wash and dry process is reduced. DOE testing indicates that faster spin speeds can reduce the calculated drying energy by 30% or more. Because drying energy constitutes a majority of the total energy captured in the MEF metric, this
translates to 15

- 20% total energy savings.3

- 26

3.13.2.6 Increased motor efficiency

Around 10 percent of the total ener gy factored into the MEF metric is used by the electric

motor. The typical clothes washer has a 1⁄2

– 2⁄3 horsepower single

- speed or dual

- speed capacitor

start induction motor

. Drive system efficiency can be increased by using a buck

- boost power
factor correct ion circuit (PFC). This reduces inverter complexity and cost by controlling inverter output voltage through changing DC bus voltage without affecting performance. Using a PFC circuit can improve efficiency by more than 1.5 times from that of a single

- phase induction

motor. 18 Three

- phase induction motors have also been shown to consume 50 percent less power than universal commutator motors through better control of motor slip. 19

3.13.2.7 Ozonated l

aundering

Ozonated laundering systems are available for large

- scale com mercial or institutional
multi

- load clothes washers. An ozone laundry system consists of a separate wall

- mounted unit that pumps ambient air through an ozone generator, which is then directly injected into the wash water. The ozone may be injected into the cold water line or directly into the clothes washer through a port located in the clothes washer sump. Once in the water, the ozone reacts with
in soluble soils, making them soluble, after which the mechanical action of the washing separates
the soils from the fabric. Ozone also acts as a natural disinfectant, providing sanitizatio n in colder water temperatures.

Ozone laundry technology saves energy because the water is not heated for lightly to moderately soiled laundry. For heavily soiled laundry, temperatures of 100

– 110 °F are used, which are lower than the temperatures required in a conventional washer. The reduced water temperature results in energy savings of up to 89 percent. Also, since fewer chemicals are used,
the rinse time is minimized, thereby reducing the total cycle time and water consumption. 20

3.13.2.8 P

olymer bead c leaning

Polymer bead cleaning u ses the absorbent properties of nylon polymer beads to clean clothes. The nylon beads are added to the wash drum with a sm all amount of water and detergent to loosen the dirt or stains on the clothing. The clothes are tumbled with the polymer beads for around 45 minutes. The polarity of the nylon polymer attracts stains from the clothing. Under humid conditions, the polymer b ecomes absorbent. Dirt is attracted to the surface and then
absorbed into the center of the bead. At the end of the cycle, the polymer beads are separated from the clothing through an inner drum/outer drum rotation process.

This technology was developed b y Xeros Ltd. in the United Kingdom, and the company has recently introduced this technology to the U.S. market. Research conducted by Xeros in the United Kingdom has shown that this technology could reduce water consumption by up to 90
percent compared to a traditional clothes washer. Including lower temperature cleaning and reduced detergent consumption, total laundry energy consumption could be reduced by up to 40
percent. 213

- 27

3.13.2.9 Spray rinse

Traditional vertical

- axis clothes washers immerse the clothing comple tely in water during the wash and rinse phases of the cleaning cycle. Spray

- rinse systems eliminate the immersion requirement by spraying rinse water into the drum while the wash basket is rotating. The centrifugal force of the rotating basket pins the clo thes against the outer walls and subsequently forces the rinse liquid through the clothes. In the process, the rinsing liquid picks up remaining suds and transports them into the sump, from which they are drained. Since immersion or partial
immersion is no longer necessary, less rinse water is required.

On clothes washers that provide only a cold rinse option, spray rinse technology provides water savings but no energy savings. On clothes washers that provide a warm rinse option, spray rinse will provide energy savings by reducing the quantity of hot water consumed during the rinse portion of the cycle. DOE testing indicates that spray rinse technology can provide around 25% water savings.

3.13.2.10 Temperatur e - differentiated pricing c ontrols

T emperature

- differentiated pricing controls offer the potential to incentivize energy savings by providing favorable vend pricing for lower

- temperature settings. End

- users may thus opt for lower

- temperature settings than they might otherwise have select ed under
undiff erentiated pricing. DOE’s market analysis confirmed the availability of this feature on multiple commercial clothes washer models from multiple manufacturers. DOE is not aware of any information regarding the extent to which this feature changes the temper ature selection frequencies of end users.

3.13.2.11 Thermostatically controlled mixing valves

Thermostatically controlled water valves (TCWVs) are clothes washer inlet valves that have the ability to sense and adjust the hot and cold supply water. This technology o ption achieves energy savings by more accurately controlling inlet water temperature for hot and warm fills. In a typical non

- thermostatically

- controlled water inlet system, two solenoid valves are used on a timed basis; one valve opens for hot water fills while the other opens for cold water fills. Both solenoid valves are opened if a warm water setting is selected.

Energy can be saved with a TCWV by either reducing the hot water temperature and/or reducing the warm water temperature. For example, the TC WV 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 stan dard’s specified inlet hot water temperature, the selected temperature of the warm water, and the amount of hot water consumed.

The TCWV technology option has the potential to overstate the real

- world energy savings, depending on the proximity of the water heater to the installed clothes washer. When tested under laboratory conditions, the clothes washer is typically close to the h ot water source,3

- 28

whereas this is generally not the case in a home laundry setting. A large distance between the hot
water source and the clothes washer can create a significant temperature drop due to line losses. Because of these line losses, a clothes wa sher with a TCWV may use more hot water than predicted on the basis of laboratory testing. Similarly, in a real

- world application, savings will also vary with the temperature of incoming cold water. The unheated water temperature will vary with both geogra phic location and time of year. More energy would likely be saved in cases of warmer “cold” supply water, as a TCWV 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 TCWV, the wa ter 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.

3.13.2.12 Water circulation loop

Water recirculation pumps are used in some high

- efficiency clothes washe rs to recirculate water out of the bottom sump and spray it back into the wash drum during certain parts of the cycle. This reduces the amount of unusable standing water in the sump and reduces the amount of new water that must be periodically introduced i nto the clothes washer.

DOE testing indicates that water recirculation pumps can provide water and energy savings of around 5

- 10%.

3.13.3 Energy Efficiency

In preparation for the screening and engineering analyses, DOE gathered data on the energy efficiency of commercial clothes washers available in the marketplace in November
2013

. While this section is not intended to provide a complete characterization of the energy efficiency of all commercial clothes washers currently available and in use, it does provide an overview of the vast majority of units available currently on the market.

DOE used its Compliance Certification Database to identify CCW models on the
market. 22 As of November 2013, DOE’s database contains 253 CCW models. DOE excluded any
models in the database that do not achieve the new standard levels effective January 8, 2013. A large number of these models belong to the same basic model . DOE defines a “basic model” as all units of a given type of covered product (or class thereof) manufactured by on e manufacturer, having the same primary energy source, and which have essentially identical electrical, physical, and functional (or hydraulic) characteristics that affect energy consumption, energy efficiency, water consumption, or water efficienc y. (10 C FR 430.2) After filtering out non

- unique basic models and models that do not achieve the January 8, 2013 standards, DOE identified 8 top

loading basic models and 11 front

- loading basic models available on the market.

Figure 3.13

. 1 displays the distribution of commercial clothes washers as a function of

MEF , as measured using appendix J1

. As shown in the figure, no overlap exists between the MEF rating s of top

- loading and front

- loading CCWs. Top

- loading MEF values range from 1.60 to 1.85, and front

- loading MEF values range from 2.20 to 2.60.3

- 29 Figure 3.13

. 1 Distribution of Commercial Clothes Washers by MEF

Figure 3.13

. 2 displays the distribution of commercial clothes washers as a function of

WF , as measured using appendix J1

. As shown in the figure, no overlap exists between the WF ratings of top

- loading and front

- loading CCWs. Top

- loading WF values range from 6.2 to 8.5,
and front

- loading WF values range from 3.7 to 4.5.

Figure 3.13

. 2 Distribution of Commercial Clothes Washers by WF 0 1 2 3 4 5 6

1.5 1.6 1.7 1.8 1.9 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 Frequency

MEF (based on Appendix J1) Top-Loading

Front-Loading

0 1 2 3 4 5

3.0 3.4 3.8 4.2 4.6 5.0 5.4 5.8 6.2 6.6 7.0 7.4 7.8 8.2 8.6 Frequency

WF (based on Appendix J1) Top-Loading

Front-Loading3

- 30

REFERENCES

1 Association of Home Appliance Manufacturers website: www.aham.org

.

2 Coin Laundry Association website: For more information, visit www.coinlaundry.org

3 Multi

- Housing Laundry Association website: http://www.mla

- online.com/

4 Technical Support Document accompanying the January 8, 2010 final rule is available at http://www.regulations.gov/#!documentDetail;D=EERE

- 2006

- STD

- 0127

- 0118

.

5 GE Appliances. “GE Agrees to Sell Appliances Business to Electrolux for $3.3 B.” September 8, 2014. Available online at: http://pressroom.geappliances.com/news/ge

- agrees

to

- sell

- appliances

- business

- to

- electrolux

- for

- 3

- 3b

6 CEE, Commercial Family

- Sized Washers: An Initiative Description, 1998. No longer
accessible online.

7 Technical Support Document accompanying the January 8, 2010 final rule is available at http://www.regulations.gov/#!documentDetail;D=EERE

- 2006

- STD

- 0127

- 0118

.

8 CSA C360

- 13 available at http://shop.csa.ca/en/canada/energy

- efficiency/c360

- 13/invt/27019792013

. The CSA C360

- 03 test method has been superseded by C360

- 13 and is no longer available online.

9 Internation Energy Agency website: http://www.iea .org/

.

10 Commission of the European Communities. 2008. “Commission Regulation (EC) No. 1275/2008 of 17 December 2008 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for standby and off mode electric power consumption of electrical and electronic household and office equipment.” December 18, 2008. Available online at http://eur

lex.europa .eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:339:0045:0052:EN:PDF (Accessed December 2009)

11 ENERGY STAR criteria for commercial clothes washers: http://www.energyst ar.gov/index.cfm?c=clotheswash.pr_crit_clothes_washers

12 Consortium for Energy Efficiency website: http://www.cee1.org

.

13 Federal Energy Management Program website: ht tp://www.eere.energy.gov/femp

.

14 Database of State Incentives for Renewables & Efficiency website: www.dsireusa.org3

- 31

15 U.S. Census Bureau. “New Residential Construction.” Accessed online at http://www.census.gov/construction/nrc/

.

16 AHAM shipment data submissions.
2006 data submission available at: http://www.regulations.gov/#!documentDetail;D=EERE

2006

- STD

- 0127

- 0031
2012 data submission available at: http://www.regulations.gov/#!documentDetail;D=EERE

2012

- BT

- STD

- 0020

- 0013
2014 data submission available at: http://www.regulations.gov/#!documentDetail;D=EERE

2012

- BT

- STD

- 0020

- 0032

17 U.S. International Trade Commi ssion. “ USITC Interactive Tariff and Trade DataWeb .”
Accessed online at http://dataweb.usitc.gov , Feb. 2014.

18 Hoghani, J.S. and Heidari, M. “High Efficient Low Cost Induction Motor Drive for
Residential Applicati ons.” 2006 International Symposium of Power Electronics, Electrical Drives, Automation and Motion . IEEE. pp. 1399

- 1402. May 26, 2006.

19 Bourgeois, J.

- M. “Energy Saving Motor Controls for Washing Machines.” Electronik . Vol. 50, No. 12, pp. 58

- 61. July 12, 2001.

20 “Cold Facts: Textile/Linen Wear Study of Traditional versus EcoTex Ozone Laundry Wash Practices.” Clearwater Tech, LLC. Available at http://www.cwtozone.com

.

21 Xeros Bead Cleaning website: http://www.xeroscleaning.com/

22 DOE Compliance Certification Database: http://www.regulatio ns.doe.gov/certification

data/CCMS

- 79222370561.html