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 UNITED STATES DEPARTMENT OF ENERGY 

ENERGY EFFICIENCY AND RENEWABLE ENERGY 

ENERGY CONSERVATION PROGRAM 

FOR CONSUMER PRODUCTS 

TEST PROCEDURE FOR MICROWAVE OVENS 

PUBLIC MEETING 

THURSDAY 

SEPTEMBER 16, 2010 

The Public Meeting convened in Room 8E089 in the Forrestal Building, 1000

Independence Avenue, S.W., Washington, D.C.,

at 9:00 a.m., Douglas Brookman, Facilitator,

presiding.

PRESENT 

DOUGLAS BROOKMAN, Facilitator 

JENNIFER AMANN, American Council for an 

Energy-Efficient Economy

WES ANDERSON, Department of Energy

JAMES BATTAGLIA, Navigant Consulting

JENNIFER CLEARY, Association of Home Appliance

Manufacturers (AHAM)

CAMILLA DUNHAM WHITEHEAD, Lawrence Berkeley

National Laboratory

LUKE HARMS, Whirlpool Corporation

BETSY KOHL, Department of Energy

TIM LONG, Lawrence Berkeley National

Laboratory

JOANNA MAUER, Appliance Standards Awareness

Project

KEVIN MESSNER, AHAM 

WAYNE E. MORRIS, AHAM 

CRAIG NOLD, General Electric 

KENNETH NSOFOR, Navigant Consulting

JUDITH REICH, Navigant Consulting

MEG WALTNER, Natural Resources Defense Council 

TROY WATSON, Navigant Consulting 

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 T-A-B-L-E O-F C-O-N-T-E-N-T-S 

Welcome, Wes Anderson . . . . . . . . . . . . .3 

Opening Remarks, Introductions, & Agenda

Review, Doug Brookman . . . . . . . . . . . . .3 

Introduction, Background, & Legal Authority,

Wes Anderson. . . . . . . . . . . . . . . . . 11

Standby & Off Mode Power Test Procedure,

Judith Reich: 

Covered Products, Effective Date, & 

Measures of Energy Consumption. . . . . 18 

Incorporation by Reference of IEC

Standard 62301. . . . . . . . . . . . . 62

 Definitions of "Active Mode", "Standby

Mode", & "Off Mode" . . . . . . . . . . 67 

Measurements for Standby & Off Mode

Testing . . . . . . . . . . . . . . . . 86 

Specifications for Test Methods & 

Compliance with Other EPCA

Requirements. . . . . . . . . . . . . . 98 

Active Mode Test Procedure, Judith Reich: 

Introduction. . . . . . . . . . . . . .105 

Previous Active Mode Provisions . . . .107 

Potential Methodology . . . . . . . . .114 

Conclusions & Closing Remarks, Wes Anderson .126 

Adjourn . . . . . . . . . . . . . . . . . . .127
	

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 P-R-O-C-E-E-D-I-N-G-S 

9:10 a.m. 

MR. ANDERSON: Good morning, everyone. 

I'm Wes Anderson. I'm with the Department of 

Energy. I'm the Project Manager responsible for 

the test procedures that we're going to talk about 

today. 

It should be, hopefully, a pretty 

straightforward and quick meeting. We have it 

scheduled for 2:00 but maybe we can get through it 

a lot quicker than that. 

FACILITATOR BROOKMAN: Okay. 

start. 

to just g

 MR. ANDERSON: That's it. 

FACILITATOR BROOKMAN: 

o around the table now? 

Do you want 

Let me just 

Good morning, everybody. Welcome. My 

name is Doug Brookman from Public Solutions in 

Baltimore. 

This is the US Department of Energy's 

Public Meeting on Energy Conservation Program for 

Consumer Products: Test Procedure for Microwaves. 

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This is a supplemental NOPR. 

It's our tradition to do introductions 

around the room. We'll start and go this way. 

Please say your name and organizational 

affiliation. 

This may not all be on the record. We 

can hear each other, there are few enough of us. 

So you can just say your name and organizational 

affiliation. 

MR. HARMS: My name is Luke Harms. 

I'm with Whirlpool Corporation. 

FACILITATOR BROOKMAN: Thank you. 

MS. CLEARY: Jennifer Cleary with the 

Association of Home Appliance Manufacturers. 

MR. MESSNER: Kevin Messner with AHAM. 

MR. NOLD: Craig Nold with General 

Electric. 

MS. WALTNER: Meg Waltner, Natural 

Resources Defense Council. 

MS. MAUER: Joanna Mauer, Appliance 

Standards Awareness Project. 

FACILITATOR BROOKMAN: Betsy? 

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 MS. KOHL: Betsy Kohl, DOE General 

Counsel's Office. 

MR. BATTAGLIA: James Battaglia, 

Navigant Consulting. 

MR. WATSON: Troy Watson, Navigant 

Consulting. 

MS. DUNHAM WHITEHEAD: Camilla Dunham 

Whitehead, Lawrence Berkeley National Laboratory. 

MS. REICH: Judith Reich with Navigant 

Consulting. 

MR. LONG: Tim Long from Lawrence 

Berkeley National Laboratory. 

MR. SHARP: Mark Sharp, Panasonic. 

MR. MORRIS: Wayne Morris with AHAM. 

FACILITATOR BROOKMAN: I think many of 

you, perhaps almost all of you, have participated 

in these meetings previously. 

I'm going to do a very quick agenda 

review and then we're going to launch into the 

content. 

Immediately following this agenda 

review, there is an opportunity for anybody that 

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wishes to do so to make opening remarks to 

emphasize key issues/concerns that you might have 

here at the outset. 

Following that we'll have an 

introduction, background, and legal authority from 

Wes Anderson. 

Then we'll launch into the more 

detailed substantive content, standby off mode 

power test procedure: covered products, effective 

date, and measures of energy consumption. 

Then standby and off mode power test 

procedure: incorporation by reference of IEC 

Standard 62301. 

We'll take a break mid-morning around 

10:45 or so. 

Then proceeding on, definitions of 

active mode, standby mode, and off mode. 

All of you have this material, I 

believe. It's in your packet. 

Then immediately following from there, 

compliance with other EPCA requirements. 

Then standby and off mode power test 

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procedure conclusions and closing remarks. 

We'll break around noon for lunch. If 

we're close to concluding this and it's close to 

lunch, maybe we'll just press on and keep going. 

We'll see how it works out. 

If we break for lunch, when we return 

it'll be the active mode test procedure 

introduction. 

Then moving directly to previous 

active mode provisions, potential methodology, and 

then finally active mode test procedure 

conclusions and closing remarks. 

As Wes said, we'll just try and be 

expeditious today, not wanting to diminish your 

opportunity for comment. That's what you're here 

for. That's what we want to make sure happens. 

Questions and comments about the 

agenda? 

I think most of you are familiar with 

the way we do this. 

The slides will be on the screen. All 

of you have a copy of them in your packet. 

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There's also a copy of the Federal Register notice 

for you to refer to. 

I'd ask for your consideration if you 

would, please, speak one at a time. Please say 

your name for the record. 

There will be a complete transcript of 

this meeting available. 

You can hear me okay, right? 

I'm going to be queuing people as best 

I can by name to speak. 

I also wish to encourage follow-on 

comments as best we can accommodate them. 

Please keep the focus here. If you'd 

turn your cell phones on silent mode, limit the 

sidebar conversations, and make sure to turn on 

your microphone as you speak, that will make it 

easier. 

Finally, if you could try to make sure 

your comments are focused and concise, share the 

air time, then we'll be even more efficient today. 

That's the overview. 

I'm hearing an echo. 

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MR. ANDERSON: What if we turned off 

all of the microphones that are not being used. 

Would that help? 

FACILITATOR BROOKMAN: That's a good 

idea. 

MS. LAM: Okay. Do you want to turn -

-

this one off? The volume off? 

FACILITATOR BROOKMAN: Ben needs to 

hear. That one needs to be off and these need to 

be active. 

MS. LAM: Okay. I just turned that 

off. 

FACILITATOR BROOKMAN: You just turned 

that off? 

MS. LAM: Yes. I muted that, I mean. 

FACILITATOR BROOKMAN: Which one did 

you turn off? 

MS. LAM: I muted it so they can't 

hear us on the Webcam. 

FACILITATOR BROOKMAN: What did you 

mute? 

MS. LAM: I muted the organizer's so 

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that they can't hear the microphone. 

FACILITATOR BROOKMAN: This is 

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an 

opportunity for you to look at your slides. 

I read through these yesterday. I 

thought these were pretty good. I thought these 

were pretty well described. 

Maybe while we're waiting, maybe we 

could -- well, we should wait for our substantive 

element. We really should. 

MR. ANDERSON: Should we get started? 

FACILITATOR BROOKMAN: They can't hear 

us on the Web yet. Right? 

Can you send a message to someone and 

ask if they can hear? 

She promised me she had tested this 

yesterday. 

MS. LAM: I had. I had done it. I'm 

so sorry. 

FACILITATOR BROOKMAN: Okay. Let's do 

this. I've concluded the agenda review. You can 

see in your agenda there's space for brief 

introductory remarks and comments/issues of key 

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concern to those that would wish to comment. 

So let's do that round. Then we'll 

launch into the substance with Wes. 

Comments here at the outset; anybody 

wishing to raise any issues that are either in the 

scope here or not included? 

Nothing additional. Okay. 

Then Wes, let's begin. 

MR. ANDERSON: Good morning. Again, 

my name is Wes Anderson with the Department of 

Energy. 

This is just an overview of what we're 

going to talk about today. We're going to talk 

about standby and off mode test procedures for 

microwave ovens. 

We'll seek comments from you, the 

participants, on the proposed test procedure, 

discuss the issues, and answer some of your 

questions related to our proposal. 

We'll also discuss the next steps for 

the standby power rulemaking. And at the end of 

that discussion, we'll discuss steps to initiate 

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the new active mode test procedure rulemaking for 

microwave ovens. 

This is an SNOPR. As Doug mentioned, 

we are doing the SNOPR. NOPR preceded this. I'll 

explain why we're doing SNOPR. 

The NOPR was issued in October 1, 

2008. We issued the SNOPR on July 22 of this year 

for the public meeting today. 

The comment period ended October 4. 

Transcripts and oral comments will be available 

online. DOE will consider all comments, however. 

The final rule publication with the 

EPCA, as amended by the EISA 2007, DOE is required 

to publish final rule addressing standby and off 

mode energy consumption with the test procedure 

for microwave ovens by March 31, 2011. That's the 

reason we are here today, to talk about that. 

Overview and issues. Products covered 

by the test procedure changes, effective dates. 

We'll talk about the measures and metrics. We'll 

incorporate reference of IEC Standard 62301, and 

we'll explain that for measuring standby and off 

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mode power. 

We will go over definitions for 

active, standby, and off mode for microwaves, and 

go over specifications for the test procedure and 

measurements for off mode and standby, and talk 

about compliance with other EPCA requirements. 

The regulatory history; I'll go 

through this pretty quickly. It's in your packet 

and it was printed in the Federal Register. 

The whole purpose was started when 

EPCA set forth the criteria and procedures for DOE 

adoption and amendments for test procedures of the 

covered products. 

Historically, it's been placed in 

Appendix I subpart B of Title 10 of the Code of 

Federal Regulations. 

The test procedure was a part of an 

October 3, 1997 final rule. It also revised the 

test procedure for other cooking products to 

measure their efficiency and energy use more 

accurately. 

It also incorporated reference of IEC 

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Standard 705-1998 Amendment 2-1993. But it did 

not address standby and off mode. 

Thus EISA 2007, where it directs to 

incorporate measures of standby and off mode 

energy consumption into the microwave test 

procedure by March of next year. 

The microwave oven test procedure 

Notice of Proposed Rulemaking was issued, as I 

said earlier, in October 2008, referred to as the 

October 2008 Test Procedure NOPR, where DOE 

proposed incorporated provisions from IEC 62301 

into the active mode test procedure, as well as 

the language to clarify any application of these 

provisions for the measurement of standby and off 

mode. 

Interested parties commented on, among 

other things, the harmonization of mode 

definitions and testing procedures with the rest 

of the world, in particular considering IEC 62301 

Second Edition. 

After October 2008, the test procedure 

NOPR decided to allow for consideration of the IEC 

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62301, which was expected to publish about a year 

ago. Based on review of drafts of the updated IEC 

Standard, the revisions could include different 

mode definitions. 

DOE later received information that 

IEC Standard 62301 Second Edition is not expected 

to publish until late 2010. But EPCA requires DOE 

to establish test procedures for standby and off 

mode by March 31, 2011. 

DOE is conducting current energy 

conservation standard rulemaking for standby and 

off mode energy use. 

As a result, we're going to consider 

in this SNOPR the IEC Standard 62301 Committee 

Draft Vote -- we're going to call it the IEC 

Standard 62301 CDV for short -- since the Final 

Draft International Standard was issued. 

At the end of the discussion, we will 

also talk -- well, we did repeal the regulatory 

provision for the microwave oven cooking 

efficiency. We repealed the regulatory provision 

for the active mode on July 22, 2010. 

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 We determined that the microwave oven 

test procedure provisions to measure cooking 

efficiency did not produce accurate and repeatable 

test results, unaware of any test procedures that 

have been developed that address these concerns 

with DOE microwave oven cooking efficiency test 

procedure. 

DOE will publish a notice for the 

workshop today, and discuss at the end of the 

active mode and standby discussion a separate 

rulemaking process to establish new provisions for 

microwave oven energy efficiency active mode. 

Now I will hand over the mic to Judith 

Reich. 

FACILITATOR BROOKMAN: Let's just 

pause right there. 

How are we doing with this? 

MS. LAM: We're still getting very 

loud feedback. 

Can we turn this down? 

If we could put a speaker right up 

here like a conference call so they can hear 

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everything that's going on? 

FACILITATOR BROOKMAN: Kevin, please 

say your name for the record? 

MR. MESSNER: Kevin Messner with AHAM. 

talking 

today, 

Just on that last slide when you were 

about published notice of a workshop 

a notice came out today about a new 

workshop on active mode or you're talking about it 

was published that today's meeting would happen? 

MR. ANDERSON: It was published that 

we will discuss the active mode. We repealed the 

active mode prior. 

MR. MESSNER: Right. Okay. So 

nothing new happened today, nothing was published 

today? 

MR. ANDERSON: No. Nothing was 

published today. I misspoke. I'm sorry. 

FACILITATOR BROOKMAN: Thank you. 

MR. ANDERSON: Do you want to take a 

coffee break or something? 

FACILITATOR BROOKMAN: How many of you 

would like to go get coffee? 

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 Not enough. 

MR. ANDERSON: Or tea? 

FACILITATOR BROOKMAN: Let's proceed. 

Judy Reich? 

MS. REICH: Judy Reich from Navigant. 

Since I have a bad habit of stepping away from the 

microphone anyway, it won't matter whether that's 

on or not. So I'll try and speak loudly. 

I'll be going through the topics that 

we've seen already. I want to reiterate that 

these are the subject of the test procedure SNOPR, 

Supplemental Notice of Proposed Rulemaking, 

related specifically to standby and off mode 

power. There will be a few slides at the end that 

talk about active mode. 

Each of these topics were included in 

the SNOPR because they were the subject of 

comments that DOE received on the NOPR. 

Therefore, the SNOPR has focused on these topics. 

The first one is what exactly are the 

products that are covered by this test procedure 

rulemaking. 

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 To start out with, the Code of Federal 

Regulations at Section 430.2 provides a definition 

of microwave oven that's very simple. It states 

that it's a class of kitchen ranges and ovens 

which is a household cooking appliance consisting 

of a compartment designed to cook or heat food by 

means of microwave energy. 

Back in the October test procedure 

NOPR, it was proposed that the amendments for 

standby power should cover all microwave ovens 

which had microwave energy as the primary source 

of the heating function. 

That included microwave ovens by 

themselves, and microwave ovens that potentially 

had thermal elements that would be used for a 

secondary function of grilling or surface browning 

of the food. 

It specifically excluded combination 

ovens, which are ovens that within a single 

compartment include the capability for cooking 

with microwave energy and other technologies, 

particularly convection cooking and possibly 

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thermal or halogen elements to heat the food. 

The other product that was excluded 

were microwave/conventional ranges. These are 

products that have a separate compartment for 

cooking by means of microwave energy and a more 

conventional oven and cooktop. 

Those, by the way, are defined 

separately in DOE's regulations. This particular 

test procedure focused on the regulatory 

definition of just microwave ovens. 

As a side note, here down at the end, 

DOE had requested in a previous Energy 

Conservation Standards Rulemaking that covered 

microwave ovens, data on what the efficiency 

characteristics of combination ovens are. This 

was back in November 2007. But DOE did not 

receive any such information. 

There were questions raised about 

those particular products that were included or 

excluded. In particular, that it was not very 

clear about whether certain products should or 

shouldn't be included. 

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 So specifically, clarity was sought on 

the definition of what a microwave oven and 

combination oven are. And secondly, whether 

combination ovens would then be covered by this 

test procedure. 

To address this, the first thing that 

DOE did was to take a look at products that are 

currently available on the market, looking at all 

available configurations. That would include 

countertop and over-the-range units. Also, 

built-in microwave ovens. 

Noted that there was only one model 

out of 129 that were surveyed that only had the 

thermal elements for grilling, and did not have 

any convection capability associated with any 

additional thermal elements. 

However, a fairly significant number, 

16 percent of the units surveyed, were classified 

or considered as combination units, defining that 

as a microwave plus a convection system. And 

secondarily, it could also have additional types 

of heating systems such as thermal elements. 

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 On the question first there were some 

concerns about if there's a thermal element only, 

is that only for surface browning or is that also 

a primary function. 

DOE doesn't believe that being very 

inclusive and saying all microwave ovens that have 

thermal elements, regardless of what their 

function are, is going to change the scope of 

these covered products very much. There's only 

one such unit out there. 

Therefore, DOE believes that no 

further specification about what the function of 

those thermal elements should be would be 

necessary to consider that to be a covered 

product. So with or without thermal elements, a 

microwave oven would be considered a covered 

product in this rulemaking. 

For microwave ovens the proposal is to 

include them because, on further reading of the 

regulatory definition, DOE believes that if a 

microwave oven is capable of cooking or heating 

the food via the use of microwave energy that it 

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falls under the regulatory definition. And that 

it does not matter whether there is an additional 

capability for convection cooking. 

Additionally, our preliminary analysis 

has shown that the standby and off modes look the 

same for combination microwave ovens as compared 

to just conventional microwave only units. So no 

additional or different amendments to the test 

procedure to address combination ovens would be 

necessary. 

At this point, we would invite comment 

on that proposal to clarify the definition in the 

CFR to cover microwave ovens with or without 

thermal elements designed for surface browning, as 

well as combination microwave ovens; that is, 

microwave ovens that incorporate convection 

features and possibly other cooking means. 

We also welcome comment on the 

proposal that the same test procedures, methods, 

and calculations be applied to all of these 

microwave ovens. 

And also, input whether in fact there 

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are additional standby and off modes or other 

features for any of these types of microwave ovens 

that would require separate test procedures. 

FACILITATOR BROOKMAN: That's the one 

right there. That seems especially salient should 

you have comments, should you disagree with the 

Department's preliminary conclusions. 

Kevin? 

MR. MESSNER: Kevin Messner with AHAM. 

We have strong issues, serious issues with this 

proposal and do not support it. 

It's overly broad in what it's taking 

in. It's bringing in other components, thermal or 

convection, which there's no test procedure for. 

And how you could deal with it on a repeatable 

basis, there's questions there. 

It also has implications -- and this 

is not dealing with active mode directly here but 

we'll get to that later today. It has 

implications on active mode, as well. 

In that area we have to understand the 

different product classes or product types that 

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Page 25 

are going to have to be addressed. For example, 

there needs to be an understanding or a 

differentiation between the countertop and the 

over-the-range microwaves. That's without 

bringing in these other issues. 

So going down this path we would not 

be supportive of. 

FACILITATOR BROOKMAN: You would say 

that the convection element contributes to the 

energy consumption in a way that distinguishes 

that activity, and therefore it would need to be 

addressed in the test procedure? 

MR. MESSNER: Well, we're not even 

clear exactly what the definition -- a clear 

definition of what these are, a combination 

microwave. 

And what the test procedure would be 

to deal with that, how you would incorporate it, 

and then how you compare that to one without. I 

mean, these are a lot different. 

FACILITATOR BROOKMAN: At this point 

AHAM does not have a counter proposal or a remedy 

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for the problem you're noting? 

MR. MESSNER: Yes. Just stick with 

microwaves and deal with microwaves. 

Then we have to also, within just that 

group of just microwaves, have to understand 

there's differences between the countertop and the 

over-the-range. That alone will take some --

FACILITATOR BROOKMAN: What about the 

convection feature? 

MR. MESSNER: No. That's a completely 

-- that's a different --

FACILITATOR BROOKMAN: Do you have a 

remedy for that one? 

MR. MESSNER: No. There's no test 

procedure, as we'll get into later on, on the 

active mode issues. 

FACILITATOR BROOKMAN: I'm way out of 

my depth here. 

Do you want to respond to any of this, 

Judy? 

MS. REICH: Maybe a question. 

Do your comments apply equally to if 

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that covered product definition for standby and 

off mode power -- if it were limited to that; is 

it in the context of both standby and active mode 

or active mode only? 

MR. MESSNER: I'm not sure. I guess, 

yes. If I'm understanding you, the answer is yes. 

Are you asking whether we think an 

active mode definition should not include these 

other capabilities as well? 

MS. REICH: Let me rephrase that a 

little. Would you object to this definition if it 

were limited to a standby power test procedure; 

the definition of a covered product for just 

standby power purposes, would you still object to 

that? 

MR. MESSNER: Yes. 

MS. REICH: That it should not include 

combination ovens? 

MR. MESSNER: Yes. We oppose it for 

the standby power. 

For the reasons I've stated, there's 

issues there. And then these issues will cascade 

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into the active mode problems, as well. So 

starting here and then doing something different 

in active mode, I'm having trouble envisioning how 

that would work. 

FACILITATOR BROOKMAN: As a layperson, 

I'm having a hard time following what the pathways 

to the solution are here. 

Jennifer, go ahead. 

MS. AMANN: Jennifer Amann, ACEEE. 

We'd be interested to learn a little 

bit more, Kevin, maybe about some of the technical 

reasons why, particularly for standby and off 

mode, there would be significant differences 

between the combination/convection products and 

the regular microwaves. 

Our position is typically -- and it 

would apply to this product category, as well --

that we want to have test procedures that can 

cover a broad range of products. 

So we're able to test them adequately 

then make decisions about where we should have 

coverage when we get to the standards phase, and 

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how products might be differentiated in product 

classes at the standards rulemaking phase. 

But to not limit coverage of test 

procedures that really help us determine what the 

impact of the products are and overall energy 

consumption. 

FACILITATOR BROOKMAN: Before you 

respond, if you wish to, let me just clarify. 

Did you say the convection feature 

doesn't contribute significantly to the energy 

consumption, and therefore it should be all rolled 

together as one? 

MS. REICH: No. 

FACILITATOR BROOKMAN: Okay. 

MS. REICH: That's not what I stated. 

The available modes -- at least our preliminary 

analysis has shown that there are no different 

modes, not at all addressing what the power levels 

are in those modes. 

But that would not require different 

methodology in the test procedure for combination 

ovens. 

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 FACILITATOR BROOKMAN: Thank you. 

That was clear. 

Do 

Jennifer? 

Even I got that one. Okay. 

you want to respond, Kevin, to 

MR. MESSNER: Maybe I'll let some 

other folks get into more of the technicalities of 

it. But I guess I would just say overall, just 

because there's a microwave component of a range 

with a microwave in it, that doesn't make that a 

microwave. 

So there's a lot of innovation in this 

space and there's a lot of differences that are 

going on here. 

FACILITATOR BROOKMAN: You've also 

noted the different kinds of models; you have 

raised issues surrounding that. 

MR. MESSNER: But others may have more 

technical insights. 

FACILITATOR BROOKMAN: Craig, go ahead 

and say your name. 

MR. NOLD: Craig Nold, General 

Electric. I'd like to add to the technical 

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discussion requested. 

The modes by definition, the 

terminology used such as standby between the two 

models could be defined as words (standby). But 

technically, the two units could have -- of 

course, we don't have clear definition on all the 

units that are out there today or in the future, 

which is more important. 

But there are requirements by the FCC 

for noise suppression going back into the home 

lines as the current draw by the unit, being the 

microwave, increases that technology changes as 

well. And heating elements are known to draw more 

current than any of the other technologies in 

there when they're turned on. 

So technically, you would have to 

design your product for calrod implementation. 

Which would then change other circuitry in the 

design. 

I'm not sure if the analysis that was 

taken included these other requirements by other 

agencies. 

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 FACILITATOR BROOKMAN: Okay. That was 

helpful. 

Do you want to follow on, Jennifer? 

MS. AMANN: Jennifer Amann again. I 

would just reiterate, we're just interested in 

developing test procedures where we can determine 

and understand what the energy consumption is of 

the products. 

I think these other issues can be 

handled in determining coverage, scope, or product 

classes within a standards rulemaking. 

We're very interested in trying to 

develop the test procedures that let us understand 

how the products are performing and what the 

differences might be between the product types. 

FACILITATOR BROOKMAN: Wes Anderson? 

MR. ANDERSON: Wes Anderson with DOE. 

Is it a product class, what the 

different products are or the definition of the 

product class is where your concern is, and then 

the test procedure that is associated with that? 

Is that what I'm hearing? 

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 MR. MESSNER: We'll have to get into a 

little more detail in our written comments. But 

if you look at some of the other products, these 

types of -- some of these, going back to the 

on-the-counter or over-the-range, it would seem 

maybe a product class. 

We're going to have to get into 

exactly what is there. But would that be in the 

definition? 

So those are the things that we're 

trying to look at, too, with microwaves. Is it a 

definitional distinction or is it a product class 

distinction? I don't know. 

FACILITATOR BROOKMAN: Jennifer? 

MS. CLEARY: Jennifer, also from AHAM. 

I think one of the main concerns we 

have here is that this definition will not only 

apply to standby and off mode. It will also be 

applicable in the future if an active mode test 

procedure and standard is developed. 

So we need to make sure that it's able 

to cut across both of those, and that we're not 

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shortsighted right now in applying the definition 

only with standby considerations in mind. 

I think that's why we're seeking a 

little bit more clarity about exactly what 

products are or not included. 

And that one that is overbroad may 

incorporate too many that will have far- reaching 

consequences when that active mode is later 

addressed. 

MR. ANDERSON: This is Wes with DOE. 

Sometimes DOE's collective hands may 

be tied because of what we can address. And if 

it's future products that are not available, that 

draws some kind of limitation to where we can go. 

So is the concern that our definition 

as it would go forth would impact products that 

are not on the market yet or expectation of where 

the technology is going? Is that what you're 

saying? 

MS. CLEARY: I think that's part of 

the concern but it's not the whole concern. I 

think more the concern is where the standard and 

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the test procedure will go. 

As I understand it, this definition is 

the overall definition in the CFR which will apply 

to the active mode later. So the concern is 

there, there are significant differences when you 

measure active mode in particular but also, as 

Craig was discussing, standby issues. 

I think we just need to keep in mind 

that later this will apply to active mode. It 

could be a slippery slope what products are 

included, the products that are on the market 

today that were being discussed; that there will 

be real differences there. 

Having everything lumped under one 

definition may become a problem in the future. 

MS. REICH: I'd also like to add that 

FACILITATOR BROOKMAN: Judy Reich. 

MS. REICH: Judy Reich. I'm sure 

everybody's aware there is a concurrent standards 

rulemaking for these products. And the issue of 

product class is addressed in the standards 

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rulemaking. 

DOE examines each defined class 

individually and may determine that different 

standards for each class are warranted, or may 

even determine that certain class standards are 

not warranted and therefore they would be 

excluded. 

So maybe some of those issues would be 

addressed in the standards context rather than the 

test procedure context. 

FACILITATOR BROOKMAN: Luke? 

MR. HARMS: I would echo Jen's 

comments. But I also want to add that an example 

of the broadness of the definition is a product 

that uses primarily radiant heat -- a built-in 

oven, for example -- that also has supplemental 

microwave technology. 

We do not believe that should be 

included in the definition of combination oven. 

FACILITATOR BROOKMAN: Is that in the 

current definition? 

MR. HARMS: This says combination 

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microwave ovens capable of cooking or heating food 

by means of microwave energy. So we believe it 

could be. 

MS. REICH: We would certainly, DOE 

would certainly appreciate any information on how 

to clarify what determines whether it's primarily 

a microwave oven versus primarily a radiant unit. 

FACILITATOR BROOKMAN: You were 

thinking that radiant could be included in that 

definition, Luke? 

MR. HARMS: We want clarification that 

it is not. 

FACILITATOR BROOKMAN: Okay. I think 

we're working toward it. 

Any final comments? 

Kevin, go ahead. 

MR. MESSNER: Was it your intent that 

those would not be included; is that the intent in 

the SNOPR? 

MS. REICH: No. I'm not drawing any 

conclusion about that. Just if there is 

information available, we're --

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 MR. MESSNER: Was the intent that what 

Luke was talking about would be included or not 

included; is the SNOPR assuming that those are 

included or not included in this definition? 

MS. REICH: The SNOPR assumes that if 

it is capable of cooking the food by means of 

microwave energy that it would be a covered 

product. 

MR. MESSNER: So it would be included, 

what you're describing? 

FACILITATOR BROOKMAN: If there was 

both microwave and radiant? 

MR. MESSNER: Which is what he was 

saying. That would be included in this under this 

assumption? 

MS. REICH: There was no attempt to 

qualify whether the microwave was the primary 

energy or the secondary. 

MR. MESSNER: Okay. 

FACILITATOR BROOKMAN: Okay. More to 

be done on this. 

I'm going to ask Judy to proceed and 

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keep going. 

MS. REICH: Okay. The next topic is 

when does the test procedure become effective. 

The EISA amendments to EPCA, as Wes 

mentioned, require that the test procedure 

amendments, if warranted, to incorporate standby 

and off mode power would occur by March 31, 2011. 

Back in 2008 when DOE was considering 

standards for microwave ovens, it subsequently 

published a final rule that just covered active 

mode for microwave ovens. 

DOE determined, based on input from 

various interested parties, that it was 

appropriate to wait and consider the fact that the 

IEC International Standard for Standby Power 62301 

was in the process of being updated. There was a 

second edition that was anticipated in July 2009 

at that time. 

So DOE decided to separate microwave 

oven standby power standards in order to consider 

this newly revised version. That, of course, 

would require an update to the test procedure to 

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also consider the revised 62301. 

However, shortly after that decision 

was made it became clear that the IEC process was 

going to take a little longer than anticipated. 

The information on the second edition was not 

going to be available until late 2010. Let me be 

more clear; the second edition would not issue 

until late 2010. 

What DOE decided was to consider 

language from the most current drafts of that 

second edition in the context of the test 

procedure. 

And therefore, publish the 

supplemental NOPR considering very narrowly just 

mode definitions from what, at the time the SNOPR 

was prepared, was the most recent draft version, 

the Committee Draft Vote for CDV. 

FACILITATOR BROOKMAN: Do we have any 

questions or comments? 

I've been asked -- apparently the Web 

link is working. However, it's going to be easier 

for them to hear you with us not having an echo if 

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you get close to the microphone. 

Wayne, please? 

MR. MORRIS: Thank you. Wayne Morris 

with AHAM. I serve in one of my capacities as the 

Chairman of the US Technical Advisory Committee to 

the IEC 62301. 

Sort of like a broken record, Judy, 

I'm sorry. But again, I'm here apologizing for 

how long this is taking to get the Final Draft 

International Standard out. 

We have had some problems with some 

editorial issues that really are not substantive, 

but unfortunately they have caused us a delay in 

getting that out of the central office at the IEC. 

I'm sending emails now every day asking when this 

is going to be coming out. 

The differences between the CDV and 

the FDIS -- as it is presently written and has 

been turned in to the central office for its 

editorial nature for sort of aligning paragraphs. 

And for also doing the French translation, which 

is necessary in order to actually come out with an 

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actual FDIS. 

They ran into some problems because 

apparently there were some French words that don't 

match up with English words in some of the 

technical language. We've been back and forth 

with some email traffic on that one, but I think 

that's all settled now. 

The modes and the definitions, as you 

probably know, in the CDV and in the FDIS are 

essentially the same. The real primary difference 

in the FDIS and what has taken a lot longer than 

we thought are in the actual testing mechanisms. 

In particular, there were concerns 

expressed by a number of governmental bodies with 

the CDV as it originally stood that as you're 

beginning now to get down into very, very small 

numbers of watts, microwatts or milliwatts of 

energy, that may make the difference between 

somebody passing and failing when you begin to 

write a standard along that line. 

The other situation is now we have 

enforcement and other activities going on by both 

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ENERGY STAR and by the Department of Energy. It's 

very critical that the measurements taken in one 

laboratory and the measurements taken in another 

are absolutely the same. 

The feeling, though, of the Committee 

was that in the CDV it was not clear in terms of 

some of the test equipment that was being used. 

Particularly, some of the 

methodologies that were in there were not spelled 

out in a clear enough manner to make sure that all 

the testing would be done absolutely the same. 

There was the possibility of some 

tolerance differences that, as you now get down 

into very, very small numbers of milliwatts of 

energy, these tolerance differences would overlap 

and create problems. That's what has led to a 

real significant rewrite in the FDIS. 

In fact, the CDV, which is the 

Committee Draft Vote on the second edition that 

was taken last autumn of 2009 -- if it actually 

passed. There were sufficient numbers of votes 

that approved it that it could have gone forward. 

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 However, the Committee pulled back and 

said, "We see the points that are being raised. 

We want to be able to address those and put in 

language that will help with the measurement." 

So that's the section that really has 

been rewritten. The mode definitions don't cause 

a problem, I don't think, if you use them out of 

the CDV as the Department has suggested. 

I do think that the FDIS version is 

going to be out, I believe really seriously, 

within 30 days. Because they're really down to 

now just dotting I's and crossing T's, and putting 

paragraph numbers in alignment to get this out, 

but understanding that the Department has to move 

on forward and you have a date to be able to do 

this. 

The FDIS will have to go out for a 

vote. It will be a vote. But having passed at 

the CDV stage, I certainly don't believe there's 

any concern that the FDIS will fail to garner its 

necessary number of votes. 

The concern I think, and I know Jen 

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will address this, is in terms of the effective 

date of the standard. I'll let her speak to that 

situation. 

I agree with you, Judy, that the mode 

definitions that are in the section of the CDV and 

in the FDIS are not going to vary. 

I mean, there's a couple references in 

there. There are some references to the annexes 

and that kind of thing. I don't think it's going 

to make any difference really at all. 

I think that it can move forward using 

the definitions that are in the CDV. Particularly 

for the modes of operation which are, I think, 

really the crux of the issue in terms of defining 

this as we go forward in 62301. 

Thank you. 

FACILITATOR BROOKMAN: The Committee 

Draft you expect unless something really odd 

happens will be very, very similar to the final? 

MR. MORRIS: Yes. 

FACILITATOR BROOKMAN: Okay. Judy, do 

you want to follow on? 

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 MS. REICH: Yes. We certainly 

acknowledge the different methodologies. I 

understand from a technical standpoint the 

rational for making those changes. This is an 

issue that was recognized early in the rulemaking 

process. 

The determination was that DOE has a 

statutory obligation under EPCA to consider the 

most recent version of 62301. And until such time 

as it is actually a final version, if it was going 

to incorporate sections it had to incorporate them 

from the first edition. It's a case of close 

timing. 

And that specifically, because of the 

objections raised very narrowly on the mode 

definitions, DOE could consider the language from 

the draft versions but not incorporating those by 

reference. 

Maybe that's more of a little bit of 

background on why, as we go through this, we'll 

see that the clauses that are proposed to be 

incorporated are coming from the first edition. 

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 FACILITATOR BROOKMAN: Wayne? 

MR. MORRIS: Wayne Morris again, AHAM. 

We understand the Department's need in that 

situation. 

But in every other governmental body 

I've seen having to do with IEC standards, once a 

standard reaches an FDIS, all the other 

governments that we've ever been involved with 

have been able to reference an FDIS. That's 

considered standard practice to reference an FDIS 

version while you're waiting for it move through 

the last phases. 

The only reason anyone can object to 

an FDIS version is if somebody feels that the 

translation between English and French is not 

acceptable, or if they feel that there's a 

typographical error. 

They cannot vote no on substance. 

That is only done in the CDV vote stage. 

All that means is if they vote no, 

they have to just clean it up. And then they go 

right back out again. 

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 So I'm understanding what you're 

saying. But unfortunately, there are huge 

differences between the first edition and the 

second edition in terms of the definitions and the 

modes. 

I think in order to be up to date, 

it's very important that the Department use the 

second edition even if it's only in an FDIS stage. 

I think it's extremely important that we stay with 

that because those are the most important. 

There's also more harmonization 

between what is being done in Europe with their 

definitions. They're considering standards on 

microwave ovens. So are other governmental bodies 

in Asia and other places. 

A microwave oven is probably the 

closest thing you will come to in major appliances 

to a universal product. It is not built for one 

continent or one country. 

Manufacturers of microwave ovens 

essentially build them for worldwide distribution. 

They become almost ubiquitous and generic. So 

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it's extremely important that the manufacturers 

have the ability to build one microwave for 

distribution everywhere. 

In terms of standby, they're going to 

use 62301, the FDIS, until such time as the final 

version comes out. 

In begging the indulgence of the 

Department and their policy, I think it's 

important that we recognize it is acceptable to 

use an FDIS. Hopefully, that will be out soon 

enough that it can be incorporated into the 

language of the test procedure. 

Thanks. 

MS. KOHL: Judy, I'm sorry. I don't 

want to belabor this. This is Betsy Kohl from 

DOE. 

The mode definitions in this SNOPR 

were using the ones from the CDV? 

MS. REICH: Yes. 

MS. KOHL: But the things that we're 

incorporating by reference, they're not implicated 

by the SNOPR that we're talking about today, those 

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first edition? 

MS. REICH: There are a few clauses 

that are newly proposed for the SNOPR. 

MS. KOHL: Okay. The one problem that 

we have with it, the FDIS as I understand it is 

not yet publicly available. Which is a problem 

for the public to be able to see what we're using 

to regulate them. 

FACILITATOR BROOKMAN: Might we say 

that -- these details are important. The 

Department and others have statutory and process 

obligations to follow. 

Might the Department say that they 

have an intention to do the best they can given 

their limitations in working to adopt what the 

Committee Draft -- can you make a representation 

that doesn't get you in trouble? 

MS. KOHL: We'll do our best. 

FACILITATOR BROOKMAN: Use the 

microphone. 

MR. ANDERSON: Yes. The Department 

will try to use the most legally available. 

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Because like I said before, we have certain 

statutory requirements that we have to live by. 

There's also the public availability 

of certain documents that need to be reviewed if 

we choose to go in that direction. If we don't 

have that as a reference, it's problematic. 

So we urge you to speed along whatever 

process you have to do and get those French guys 

in order. 

FACILITATOR BROOKMAN: Okay. I don't 

think you were finished with this segment. 

MS. REICH: Yes. 

FACILITATOR BROOKMAN: Judy Reich. 

MS. REICH: Judy Reich, quickly going 

through some of the nuts and bolts of the 

procedural issues. 

An amended test procedure would be 

considered effective 30 days after the final rule 

is published in the Federal Register, at which 

point it becomes codified in the CFR. 

But in terms of when manufacturers 

actually need to use it, i.e. the compliance date, 

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manufacturers would not be required to use the 

standby and off mode provisions to demonstrate 

compliance with any standby power standards for 

microwave ovens until such time that the standards 

-- the compliance date of the standards, which is 

usually 3 years after the publication of that 

final rule. 

However, 180 days after the test 

procedure is published, if a manufacturer makes 

any representations about the standby power off 

mode energy use of the product, it would need to 

be based upon those provisions in the amended test 

procedure. 

Actually, this slide provides some 

information about what was touched on previously 

about international harmonization. 

A number of comments were received in 

response to the test procedure NOPR that the 

effective date of the test procedure and standards 

should harmonize with the 2013 effective date for 

multiple countries that are implementing a one 

watt standard. 

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 That was taken into consideration when 

DOE decided to go ahead and look at the language 

in the draft version of the second edition, so 

that both the methodology and the effective date 

are harmonized, to the extent that DOE is able to 

under these statutory limitations, with some of 

these international standby power standards. 

FACILITATOR BROOKMAN: Let's see if 

there are additional comments on the effective 

date. 

Jennifer, did you have an additional 

issue related to effective date? Wayne said you 

did. 

MS. CLEARY: I guess I was just 

wondering if you had any indication when that 

effective date would be. I'm guessing no. But 

it's worth the question. 

MS. REICH: Again, it's typically 3 

years from the date that the final rule of the 

standards publish. It's an ongoing rulemaking. 

MS. CLEARY: Thank you. 

FACILITATOR BROOKMAN: Other comments 

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before we move on to the next section? 

MS. REICH: Okay. Measures of energy 

consumption. 

FACILITATOR BROOKMAN: Are they able 

to hear us? 

Okay. I guess it's working. Good. 

Thank you. 

MS. REICH: As Wes noted, the active 

mode provisions have been repealed from the test 

procedure. But I'm going to step back and talk 

about initially what was done. 

Historically, there have been several 

measures of active mode energy use for microwave 

ovens. Namely cooking efficiency and energy 

factor, which were defined actually for all 

cooking products. For some those are different. 

It turns out for microwave ovens those were the 

equivalent. And in annual energy consumption. 

In the previous rulemakings looking at 

microwave oven standards, it was energy factor 

that was metric which was used for the analysis. 

The test procedure right now does not include 

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measures of standby and off mode energy use that 

would be required under EISA. 

So the October 2008 NOPR was looking 

at specifically for the test procedure whether 

standby and off mode energy use could be rolled 

into a combined metric using the energy factor. 

DOE determined that it was technically 

infeasible to combine those two because of 

inherent problems with the energy factor 

measurement. Specifically, the variability in 

measurements from test to test. 

And that by either putting those into 

energy factor or into an annual energy 

consumption, which would rely upon the same 

measurement methodology, you are combining 

something that wasn't meaningful with your standby 

power measurement. 

The result, the combined metric, would 

not be meaningful itself. Therefore it would not 

be technically feasible. 

I guess it's worthwhile at this point 

to state specifically what the language in the 

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EISA amendments to EPCA are about, integrating 

these metrics in the test procedure. 

It states that they must be integrated 

unless it's determined that either the current 

test procedure fully accounts for standby and off 

mode energy use, or it's technically infeasible to 

come up with a test procedure that integrates 

them. 

In which case, if it's technically 

feasible to define a separate standby and off mode 

metric, that would be required as well. 

At this point, because the active mode 

repeal final rule has already published, the test 

procedure doesn't currently address that active 

mode energy use. Therefore, the requirement for 

an integrated metric doesn't apply. 

As new active mode methodology is 

potentially developed, DOE would consider the 

statutory requirement and see if it would be 

feasible to define an integrated metric. 

Here is a little bit of the background 

and reasoning on why the active mode provisions 

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were repealed. 

In analysis that was performed for the 

standards rulemaking, testing and evaluation 

showed specific limitations of the existing 

methodology. In particular, it was based upon 

heating a water load for a short period of time. 

That was found to be not 

representative of actual food loads. So DOE 

considered whether methodology could be revised to 

be based upon a more representative food load. 

DOE believes that's not feasible at 

this time because it's not clear what a 

representative food load would be. And would 

require some significant additional analysis and 

input to understand how to define that, and how to 

ensure that that load is going to produce 

representative and consistent results from test to 

test and from laboratory to laboratory. 

DOE isn't aware of any other test 

procedures that have been developed that address 

these concerns. Nor is it aware of any research 

or data on consumer usage to know what a 

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representative food load would be, and how that 

could be used to determine an energy factor or 

some other energy use metric. 

For those reasons, at this time in the 

SNOPR the amendments are focusing only on standby 

mode and off mode energies. 

We'll talk about this, I guess, in 

more detail when we get to the end of the 

presentation where we're talking about the 

initiation of an active mode rulemaking. 

But at this point we'd also invite 

comments on any test procedures or methods that do 

address the active mode in microwave ovens. And 

on some of the issues I mentioned: repeatability 

and consistency, what a representative food load 

actually would be, and how that could be 

incorporated into an energy efficiency metric. 

FACILITATOR BROOKMAN: Kevin Messner? 

MR. MESSNER: This is Kevin with AHAM. 

We're not aware either of any test procedure or 

food load that could be used. As always, we'll 

work with DOE to try to work that out. But we're 

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not aware of any right now. 

FACILITATOR BROOKMAN: Would this be a 

new effort for you all? 

MR. MESSNER: Yes. We're not aware of 

any test procedures out there at all that gets at 

the repeatability and the representative food 

loads. 

FACILITATOR BROOKMAN: Okay. Other 

comments? 

Wayne? 

MR. MORRIS: I just have a question, 

actually. This relates back then to the comments 

that you had, Judy, on the effective date. 

It says in there on that slide 

previously that 180 days from the time that it 

becomes effective, any manufacturer would have to 

make representations based on this particular test 

procedure? 

MS. REICH: If they made 

representations they would need to be based on the 

test procedure. Yes. 

MR. MORRIS: Okay. So a manufacturer 

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places on its retail carton the wattage of the 

microwave oven, that's a representation of energy. 

It would not be in keeping with this particular 

test procedure. 

MS. REICH: Representations as to 

standby power and off mode energy use. 

MR. MORRIS: Will it be stated just 

that in the final rule? 

MS. REICH: I believe it is. Yes. 

MR. MORRIS: That's the only --

MS. REICH: I think in the proposed 

regulatory text it specifically qualifies it as 

standby. 

MR. MORRIS: Standby or standby and 

off mode? 

MS. REICH: Standby and off mode. 

Yes. 

MR. MORRIS: So any representation of 

standby or off mode would have to be according to 

this test procedure within 180 days? 

MS. REICH: Yes. 

MR. MORRIS: But it would not apply to 

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a wattage rating of a microwave oven, the energy 

consumed in active mode, or anything along that 

line? 

MS. REICH: No. 

MR. MORRIS: Okay. We would urge the 

Department to make that very, very clear in the 

final rule. 

Thank you. 

FACILITATOR BROOKMAN: Thanks, Wayne. 

Other comments on this section? 

Craig? 

MR. NOLD: Craig Nold, General 

Electric. I'd like to add as we're talking about 

trying to determine a representative food load for 

the microwave, earlier we had discussed the 

possibility of inclusion of alternative 

technologies. 

To talk a little bit further about 

representative food loads, with the inclusion of 

those, this becomes even more difficult, more 

challenging, and possibly impossible. Something 

to consider. 

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 FACILITATOR BROOKMAN: We're going to 

press on, then. 

MS. REICH: Okay. The next topic is 

incorporation by reference of certain clauses from 

IEC 62301 First Edition for measuring standby mode 

and off mode power in microwave ovens. 

In the December 2008 NOPR -- I think 

that was the October 2008 NOPR -- DOE proposed to 

incorporate certain clauses from the first edition 

for measuring both standby mode and off mode 

power. 

In particular, Section 4 which applies 

to various test conditions, certain specifications 

for the supply voltage, frequency, and waveform 

were proposed to be incorporated. 

In particular, the voltage and 

frequency are 120 volts and 60 hertz, plus or 

minus 1 percent. That's the proposal. 

There is a tolerance on the waveform. 

The harmonic content must be less than 2 percent. 

In terms of the ambient room 

temperature, it's actually a fairly broad range 

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that's allowable. It's 23.5 degrees C, plus or 

minus 5 C, I think. 

Then there are also certain tolerances 

on accuracies of resolutions associated with the 

power measurement equipment that would be used for 

measuring standby and off mode power. 

In the NOPR it was also proposed to 

incorporate certain clauses that relate to the 

measurement procedure itself. 

In particular, one of the paragraphs 

in Section 5 clarifies, for units that have a 

short duration higher power state before it drops 

down to a lower power state, sufficient time 

should be allowed for the product to drop to the 

lower power state before making the measurement. 

It also provides instructions for how 

to measure the standby power and off mode power. 

When the power measurement is either stable or 

unstable -- and I want to be very clear that 

that's not relating to the input power to the 

device, the supply power. It is the power 

consumed by the unit, for example, as a clock 

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display is cycling. 

In the case of it being unstable, it 

varies by a certain amount over the measurement 

period by more than that amount. 

If there is some sort of cyclic 

operating cycle, the methodology requires that at 

least one full cycle is measured. It can be more 

complete cycles than that but at least one full 

cycle. 

I think we've sort of talked about 

this extensively. But just to reiterate, because 

the second edition has not been finalized, for the 

purposes of EISA the first edition clauses are 

what DOE is considering. 

What is proposed now in the SNOPR does 

not change those clauses that were proposed in the 

NOPR. Those proposals are being retained. 

What is being done is some additional 

paragraphs are proposed in the SNOPR to be 

included. This was based on comments that DOE 

received in response to the NOPR. 

For example, DOE received some 

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comments that it was unclear what the test setup 

-- how the product should be initially configured 

at the start of the test. 

Paragraph 5.2 provides some 

clarification on how the microwave oven should be 

set up prior to the start of the test. In 

particular, it states that it should be tested at 

the factory or default settings. And that where 

there are no such indications, it would be tested 

as supplied. 

DOE believes that doing so provides 

some guidance on how to conduct the test that 

would be most representative of how consumers use 

it. They may typically use it as it comes 

straight out of the box. It would also ensure 

consistency from test to test. 

For those reasons, DOE is proposing to 

incorporate by reference these instructions. 

Additional comments were received 

regarding the accuracy of the equipment supplying 

the power to the unit and that DOE should 

incorporate those. DOE agrees and believes that 

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IEC 62301 is pretty good methodology. It's robust 

and it's recognized broadly as being suitable for 

making these kinds of measurements. 

Therefore Paragraph 4.3, which relates 

to the accuracy of the test equipment, would be 

proposed to be incorporated by reference as well. 

Any comments would be appreciated on 

the adequacy of 62301 First Edition to measure 

standby power and off mode power in general, and 

on the suitability of incorporating those specific 

provisions. 

FACILITATOR BROOKMAN: Jennifer? 

MS. CLEARY: This is Jennifer. I 

think we would reiterate the comments that --

FACILITATOR BROOKMAN: Can you get a 

little closer to the mic? 

MS. CLEARY: Sure. 

We'd reiterate the comments that Wayne 

made a little bit earlier in our previous 

discussion regarding the FDIS version and 

etcetera. But we do support the adoption of these 

additional clauses. 

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Page 67

 FACILITATOR BROOKMAN: Thank you. 

That's helpful. 

Other comments on this subject? 

Okay. 

MS. REICH: Judy Reich again. 

Definitions of active mode, standby mode, and off 

mode. Here is where we deviate from incorporating 

provisions from First Edition 62301. 

I'll give you some background. For 

the October 2008 Test Procedure NOPR, DOE had 

proposed to use the statutory definitions provided 

by EISA that are now incorporated into EPCA, the 

definitions for active mode, standby mode, and off 

mode. 

EISA does provide the ability for DOE 

to consider other definitions. 

For the reasons that we've already 

talked about, namely that comments were received 

about wanting to harmonize these mode definitions 

and that there were new definitions becoming 

available with the second edition, DOE decided to 

consider those definitions from what at the time 

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was the most recent draft version, the CDV. 

These don't really change the EPCA 

definitions, but they expand upon them. They 

provide some extra guidance as to what functions 

are associated with each mode. 

Therefore, DOE is proposing mode 

definitions based on the CDV. 

As Wayne commented, the FDIS does not 

substantively change those definitions. We are 

aware that this is coming out shortly and there 

are editorial type differences in wording, but 

they are substantively the same definitions. 

Let me talk about specifically what 

those definitions are. For standby mode, it's any 

product mode where it's connected to the power 

source and offers one or more of the following 

functions. 

What is key that is different from the 

EPCA definition is it adds that these functions 

may persist for an indefinite time. 

You see that one is to facilitate 

activating other modes. Examples include a remote 

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Page 69 

switch, an internal sensor, a timer. 

Or they may be continuous functions 

that include information or status displays, which 

may include clocks or sensor-based functions. 

Additionally, a clarification that was 

provided in the CDV is a timer is a continuous 

clock function that doesn't have to be associated 

with a display. It may be an internal one that 

provides regular scheduled tasks and operates on a 

continuous basis. 

DOE did receive a comment that the 

definition should also include that standby power 

would be measured at the lowest power state 

selectable by the user. 

It did not propose to include this 

statement because it would potentially conflict 

with the provisions of Paragraph 5.2 that it has 

to be tested in the factory or default settings. 

FACILITATOR BROOKMAN: Wayne Morris? 

MR. MORRIS: Wayne Morris with AHAM. 

It seems, Judy, as if the Department 

is sort of lifting certain definitions out, and 

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then sort of leaving some other things out as it 

does. 

One of them is that in the CDV and in 

the FDIS version of the second edition, there's an 

extensive amount of work done in there on network 

mode. 

And network mode then translates to a 

lot of the activities that are going on by both 

the Department and other people in regard to smart 

grid, smart appliances, and all of that, which is 

therefore missing from any reference to this. 

So it becomes important -- and I think 

Kevin can speak much better to this than I can --

that the situation being if you use as your 

definition that standby is not off mode, and it's 

not active mode, then that leaves in the grey area 

network mode. What is it? 

I think that's one of the elements 

that ends up being missing if you go back to First 

Edition 62301. 

The other side of this is that the 

second edition also deals with the function 

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activities and is a super-definition, if you will, 

before you get into the mode definitions. 

Paragraph 3.1 deals with function and 

explain functions. And if you don't do that, the 

definitions of modes that are lifted out then 

don't have a context. 

So that's where I think -- I think we 

appreciate the fact that the Department is willing 

to lift out the definitions. But unfortunately, 

you miss a lot of the section when you just lift a 

few and not the whole thing. 

I think that's where we begin to see a 

problem in developing between the first edition 

and second edition. 

I'll let Kevin talk about smart grids. 

MR. MESSNER: Actually, Wayne, did you 

want to clarify that last bullet point, too, while 

you're up there? 

FACILITATOR BROOKMAN: Are you talking 

about on page 34 or 33? 

MR. MORRIS: I don't know quite where 

that comes from. Because I thought that our 

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position at AHAM had always been that we were 

agreeing with what the Department has actually 

ended up at. 

That is, the standby and off modes 

should be measured in the factory or default 

settings. 

I guess I wasn't aware that at any 

point AHAM had ever stated that it wanted to use 

the lowest power state selected by the user. 

That goes with First Edition. When 

you change to Second Edition 62301, that becomes a 

nonstarter. 

We've had as our position consistently 

that we want to move to this factory or default 

setting, which is where the Department is. We're 

in agreement with you all. I don't think that we 

want to set up any disagreement by this last 

bullet. 

That may have been at the point in 

time when the first edition was out. But at any 

time since the second edition has been considered, 

we certainly have been more in line with where the 

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Department is. 

Thanks. 

FACILITATOR BROOKMAN: Okay. Thank 

you. 

Judy? 

MS. REICH: I do want to mention 

network mode. That was a mode that was considered 

by DOE. 

It was determined that it would not be 

addressed in the test procedure, at least at this 

time, because there are no products available for 

DOE to determine an appropriate test procedure 

for. 

So it wasn't that we neglected it. It 

was considered. It is not proposed to be 

addressed because of the fact that there aren't 

any products available to evaluate. 

FACILITATOR BROOKMAN: Wayne Morris, 

go ahead. 

MR. MORRIS: That doesn't matter in 

terms of the definition. I think the issue of the 

definition -- of having a definition for network 

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mode doesn't relay it back to whether you can 

measure it or not. 

It's in the basic definition. It says 

that if you want to know what standby is, standby 

is when it's not in off mode, it's not in network 

mode, and it's not in active mode. 

If you leave out that other element of 

network mode, then you're precluding the 

development in the future of having that situation 

by virtue of the fact that you can't -- you are 

penalizing manufacturers from going through the 

technology development in there. 

Because by the way that you've set up 

the definition, as soon as somebody comes up with 

a network mode, if it uses any energy whatsoever 

then it's captured under this situation. And it 

isn't excluded. 

The purpose of smart appliances and 

smart grid is to save energy. So really, in fact, 

you would be penalizing manufacturers from having 

products that would save energy for the country. 

I think what we're -- it's not 

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dependent upon being able to be measured at this 

point. It's a definition. 

FACILITATOR BROOKMAN: Wes Anderson? 

MR. ANDERSON: This is Wes Anderson. 

I understand where you're coming from and what 

you're trying to do here. But we have to react to 

what is. 

That doesn't mean that DOE cannot 

change in its direction. The whole purpose of --

we're driven by legislation, statute. 

We will address that issue when it 

becomes available. But right now DOE doesn't have 

enough information to make broad-reaching 

requirements right now. We don't have enough to 

-- we couldn't defend our position. That's one of 

the problems here. 

FACILITATOR BROOKMAN: Kevin? 

MR. MESSNER: Kevin Messner with AHAM. 

Maybe we'll look at this for our 

written comments, too, to make sure that -- I 

mean, our key point is the network mode should not 

be included given that we're talking about smart 

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appliances, smart grid, and we're talking a little 

bit about the innovations that are going to come. 

But we also don't want to be in a 

position where the definition of standby down the 

road is seen to be, oh, here's something that 

could -- it's a network issue to help make the 

grid more efficient and save consumers' money --

is somehow then thrust into the standby mode. 

We will take a closer look to make 

sure the definition is tight enough. 

FACILITATOR BROOKMAN: In your written 

comments you'll find a way through those 

definitions to differentiate these functions? 

MR. MESSNER: Yes. We'll try to see 

what we can do to see if there's any areas in 

there that we can help out on. 

FACILITATOR BROOKMAN: Wayne, do you 

have something else to say? No? 

Okay. Judy? 

MS. REICH: Okay. The off mode 

definition that DOE is proposing in the SNOPR. 

Again, very similar to what's in EPCA, with a 

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little additional clarification. 

It means a mode where the product is 

connected to the main power source and is not 

providing any standby or active mode function. 

The additional clarification is that 

it may persist for an indefinite time. 

Another clarification is an indicator 

that only shows the user that the product is in 

the off position would still classify it as 

operating in off mode. 

I think this had been an area of 

question before because it could conceivably be 

considered a status display. That would have put 

it back under the classification of standby mode. 

So I think the idea is that if it is, 

in fact, in off mode but gives some indication 

that it's there, it would still be considered 

operating in off mode. 

Another question that was raised was 

what happens if the unit is plugged in, but it is 

not consuming energy because an on/off switch is 

there and the switch is in the off position? 

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Would that be considered disconnected mode or 

would that be considered off mode? 

In considering this topic, DOE looked 

at what was provided for informational purposes 

within the draft version, CDV of 62301. 

It first notes that -- this particular 

appendix states that disconnected mode is included 

as a mode definition because users remove the 

product from the main power source for substantial 

periods of time. 

In reading that, DOE interpreted that 

to mean that the condition they're referring to as 

removed means unplugging from the power source. 

That same appendix goes on to state 

that a product can have several off modes, or it 

may have no off mode. And regardless of how the 

switch is labeled on the unit, it really depends 

on what's happening internally as to how that mode 

would be classified. 

So although it's not definitive in 

saying how the presence of the on/off switch 

should be treated, DOE takes that language to 

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infer that, having a switch, the unit can operate 

in either off or standby mode depending on what 

components remain energized, if any, when the 

switch is in the off position. 

In thinking about all of these 

statements in total, DOE is proposing in the SNOPR 

that disconnected mode be assumed only when the 

power cord is unplugged. 

And if you have an on/off switch and 

when it's in the off position you have zero energy 

consumption. That puts it in an off mode rather 

than a disconnected mode. 

I want to emphasize, this is different 

than what was determined in the previous test 

procedure NOPR. At that time DOE proposed that it 

be considered disconnected mode. 

But by classifying this as an off 

mode, it would encourage manufacturers to 

incorporate that kind of feature and provide it as 

an energy savings means. 

Finally, DOE proposes to define active 

mode as a state in which it is connected to the 

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main power source, has been activated, and 

provides one or more main functions. 

And it is clarifying that because 

delay start mode is a one-off, user-initiated 

function -- it is short duration; it does not 

persist for an indefinite time -- it would be 

associated with the active mode. 

In coming up with this, this is a 

topic that DOE considered thoroughly. In the 

draft version of Second Edition 62301 that 

preceded the Committee Draft Vote -- it was 

entitled Committee Draft 2 -- there was language 

that clarified that delay start mode is this oneoff, user-initiated, short duration function 

associated with active mode. 

When the Committee Draft Vote was 

issued, it removed that clarification. And it did 

so on the basis of comments that it received from 

various parties on the Committee Draft 2. 

But in the summary of its responses to 

those comments, the IEC did acknowledge that delay 

start mode is a one-off function of limited 

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duration. 

Based on that response, DOE concluded 

that the suggestion was IEC does not consider it 

part of standby mode, even though the CDV doesn't 

state conclusively whether it would be part of 

active mode. 

In sum, based on those and in further 

review, DOE is proposing to consider delay start 

as part of active mode because of the reasons 

we've already mentioned. 

Obviously, the functions that you 

would normally associate with a microwave oven, 

cooking or warming of the food -- those would be 

considered active mode functions also. 

This is certainly an area that DOE 

would like to hear comments on, these definitions 

of the three modes based on the language, again, 

of what was current at the time that the SNOPR was 

prepared, the CDV recognizing that they have not 

substantially changed in the FDIS. 

Also, it seeks comment on specific 

functions that would be associated with each of 

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those modes. 

FACILITATOR BROOKMAN: Wayne Morris? 

MR. MORRIS: Wayne Morris with AHAM. 

The Committee did consider this issue of delay 

start. 

What was decided is that this is more 

of a regulatory issue than a testing issue. 

Therefore it was decided to leave out any 

particular direction on this, and allow individual 

regulatory agencies to see it as they choose. 

I think the Department has chosen to 

see delay start as part of the active mode, and 

that's the direction that you've taken. I'll let 

my colleagues discuss it. 

But I want to let you know that it was 

discussed. Particularly, this became relevant 

with the standby regulatory action in the EU under 

the EUP directives. There they have viewed it in 

the same manner that the Department is proposing, 

to see it as an active mode. 

FACILITATOR BROOKMAN: Thank you. 

Other comments on delay start and 

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other issues related to active mode? 

Craig? 

MR. NOLD: Craig Nold, General 

Electric. In the definition of modes under on/off 

switch, if I read the recommendations here I would 

look at them in the context of a product that's on 

a 120-volt system. 

I was wondering if there were any 

studies or conversations in the past around a 

system that might be a 240-volt system where you 

have multiple energy feeds but one switch in the 

circuitry? 

MS. REICH: You know, we're aware that 

there are some combination ovens that are 

240-volt. 

This gets back to our initial 

considerations that we didn't identify any other 

standby modes or any other means that needed to be 

measured for combination ovens, but would like 

information if there are modes like that that we 

aren't aware of. 

MR. NOLD: Was there discussion around 

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Page 84 

that, though, that I could review? Or are you 

saying there was no discussion around that in the 

past? 

MS. REICH: Not in the past. This is 

a newly considered product for the SNOPR. 

In the context of the standards 

rulemaking, this is a product that's being 

investigated currently. 

MR. MESSNER: Thank you. 

FACILITATOR BROOKMAN: At the time you 

did this work on the test procedure, you didn't 

have any products that met that definition? 

MS. REICH: Right. Prior to the 

publication of the SNOPR. 

FACILITATOR BROOKMAN: Okay. Thank 

you. 

MR. ANDERSON: This is Wes with DOE. 

However, it would be nice if you have 

any information to supply that to help us in going 

forward. 

MR. MESSNER: At this moment I do not 

or I would share it. 

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Page 85

 MR. ANDERSON: All right. 

FACILITATOR BROOKMAN: Thank you. 

Other comments on this segment? 

MS. REICH: The section may get into 

some depth. I might recommend a break. 

FACILITATOR BROOKMAN: Yes. Let's 

take a break. We've made really good progress and 

it's now 10:45. 

For those of you that are listening in 

on the Webinar, we are pleased to have you. I 

think it's been stop and start and echo-y. 

Hopefully you can still hear us. 

Let's take a 15-minute break. We'll 

resume at 11:00. 

Thanks to all of you, we have a really 

good start on the day. We'll see you back here at 

11:00. 

(Whereupon, at 10:46 a.m. off the 

record until 11:02 a.m.) 

FACILITATOR BROOKMAN: We're going to 

resume. Welcome back. We are ahead of schedule. 

If we keep going at our current pace, we should 

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Page 86 

finish maybe not by noon but maybe by, say, 12:30 

or before 1:00 would be my guess. So unless we 

hit a snag, we'll probably just keep pressing on 

now until we're finished. We'll see how this 

develops. 

Judy? 

MS. REICH: Okay. Topic 6 is next, 

which are specifications for test methods and 

measurements for conducting the standby and off 

mode testing. 

Back in the test procedure NOPR, it 

was noted that IEC 62301 doesn't closely specify 

how the measurement should be made in cases where 

the power is not stable. This is the measured 

power again, not the line power. 

Section 5.3.2 states if the power 

varies over a cycle -- and it defines cycle as a 

regular sequence of power states that occur over 

several minutes or hours -- the period selected to 

average power or accumulate energy shall be one or 

more complete cycles. That's so the average is 

representative. 

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Page 87

 In the NOPR, DOE investigated language 

that could provide a means to make that more 

clear, and so that it would be an accurate and 

repeatable measurement. 

It was recognized that for microwave 

ovens, an unstable power measurement was most 

likely to be associated with a clock display in 

which, depending on the time display, a different 

number of segments would be energized; and 

therefore, potentially the power consumption would 

change. 

In the US, at least, these are 12-hour 

clocks. So DOE's testing led it to propose that 

the measurement could be made with an arbitrary 

starting time as long as it was conducted over a 

12-hour period. It's specified as 12 hours plus 

or minus 30 seconds. 

Recognizing that 12 hours may 

represent a fairly significant test burden, DOE 

also investigated methods that could produce a 

representative average power measurement in 

something less than 12 hours. 

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 Two approaches were considered. The 

first was a method that was actually looked at 

first in the standards rulemaking, back when an 

advanced notice of proposed rulemaking was under 

way. 

This was a technique in which 18 

separate measurements were taken. At each data 

point a different clock time would be set. 

The idea was that first you have to 

understand how power consumption and voltage would 

vary as the clock was cycled through all possible 

combinations of the segments that would be lit for 

any time that occurred in that 12-hour window. 

Then a regression analysis 

performed to quantify what the impact of 

number of lit elements were and the effect of 

was 

the 

variation in voltage on the power consumption. 

The results are then integrated across 

the number of minutes that each active element 

combination -- that is, the number of the lit 

elements -- is on over the course of all possible 

times that would be displayed over the 12 hours. 

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Page 89

 It was determined that the results 

from this methodology came to within 2 percent of 

the 12-hour test results. 

In response to the test procedure 

NOPR, DOE also received comments that an 

alternative methodology could be considered in 

which a single 10-minute window of power 

consumption is measured. Specifically, with a 

starting clock time of 3:33. 

It was based upon the fact that the 

combination of digits for the times displayed in 

that 10-minute window just so happened to have the 

same proportion of time that different segments of 

numbers are lit as they do during a full 12-hour 

cycle. 

I just want to clarify, this is 

assuming a typical seven-segment typical LED digit 

display. 

FACILITATOR BROOKMAN: This sounds 

like a brainteaser for physicists or something. 

MS. REICH: So based on the fact that 

these different combinations of lit segments occur 

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Page 90 

under the same proportion that they do over a 

12-hour period, the suggestion is that measuring 

this average power during the 10- minute period 

would be comparable to a 12-hour power 

measurement. 

To compare those three methodologies, 

DOE conducted some limited testing. There was a 

sample of 11 microwave ovens that have different 

types of displays. 

Since the variation in power 

consumption is different whether it's a liquid 

crystal display LED or a vacuum fluorescent 

display, different models were selected that have 

those different types of displays. 

The first column shows what the 

average standby power was, measured using the full 

12- hour method. 

The two sections to the right, the 

18-point method and the 10-minute method, compare 

the results back to the 12-hour technique, 

assuming that 12 hours is kind of the gold 

standard of the measurement. 

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Page 91

 What was found was that the 10-minute 

method, which DOE believes represents the minimal 

test burden to manufacturers, produces results 

that agree with the 12-hour data within 2 percent. 

So the idea is that it's a pretty darn good proxy. 

DOE is proposing that for those units 

where power consumption varies as a function of 

the clock display, the methodology would be to set 

the clock time to 3:33 at the end of the 5- minute 

stabilization period, and then measure over a 

period of 10 minutes. 

FACILITATOR BROOKMAN: Kevin? 

MR. MESSNER: Kevin Messner with AHAM. 

You just mentioned the 5-minute stabilization 

period. I understand the 10 minutes and certainly 

see what you're doing there. 

The 5-minute stabilization, you're 

assuming that sometimes a display could -- if 

you're doing something with the machine, the 

display would then change after it hits the 

stabilization period, so you'd want to test that 

10 minutes when it hits that stabilization period? 

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 Is that what with the 5 minutes you 

were talking about prior to that? 

MS. REICH: The stabilization period 

may be for other components --

MR. MESSNER: Right. 

MS. REICH: -- as well as the display. 

So there needs to be a period upfront for other 

things to stabilize. 

I recognize the issue you're talking 

about with your action of changing the display 

time might in fact then, you know, maybe require 

an additional stabilization period. 

And if so, maybe the clock could be 

set to an earlier time, say 10 minutes earlier or 

5 minutes earlier, and wait until it hits 3:33. 

That might be something that we would 

appreciate comment on if you would advocate that 

kind of approach. 

MR. MESSNER: Yes. Definitely. 

Do you want to add to that? 

MS. CLEARY: We would advocate that 

approach. We think it would be more 

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representative of actual consumer use. 

Where when you touch the display the 

clock gets brighter, for example, that's not the 

state that it's sitting in normally in the 

consumer's home. It's sitting when the clock 

maybe is dimmer, for example. 

So if you set the clock for 3:33 minus 

the number of minutes it takes to go back into its 

low power state, we think that would be more 

representative. 

I think exactly what you were saying, 

we would agree with. 

MS. REICH: Okay. We would certainly 

appreciate information on what that secondary 

stabilization period should be, the length of it. 

FACILITATOR BROOKMAN: Thank you. 

Kevin? 

MR. MESSNER: We'll provide more in 

written comments. 

I'm not sure whether you could pick a 

number for every product. It may have to be 

whatever time it takes for that product to reach 

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that stabilization period. 

FACILITATOR BROOKMAN: Wes Anderson? 

MR. ANDERSON: Yes, with DOE. 

Would it then make sense to have a 

condition instead of a time frame; is that what 

you're saying? 

MR. MESSNER: Yes. We'll provide more 

detail, but yes. The impression of our initial 

read on that is it would probably have to be a 

conditions-based thing. For example, the 3:33 

minus whatever time it takes for that product to 

reach its stabilization period. 

FACILITATOR BROOKMAN: Wayne Morris? 

MR. MORRIS: Wayne Morris with AHAM. 

I'd just point out, Judy, that some of 

that is covered in the FDIS version of 62301 with 

5.3.1 on sampling methods. That specifically is 

meant to deal, that section, with this whole issue 

of noncyclical loads or activities where the power 

is not stable over a period of time. 

The Committee dealt with this in a 

similar manner. 

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 That's not to say that the methodology 

you're now proposing is not in keeping with this. 

But there's finer points to this than just what 

the digits are on the display, especially in terms 

of power distribution within the unit and other 

features that may come on or come off during that 

time situation. 

Jennifer mentioned one, which is the 

display dimming kind of situation. That's going 

to be covered in this section. 

So hopefully, we could use the more 

up-to-date method. 

Thanks. 

FACILITATOR BROOKMAN: Yet one more 

reason why we eagerly await the completion of that 

work. 

Okay. 

MS. REICH: Were there other comments? 

Okay. Well, a key consideration is of 

course whether the measurement that is being 

proposed for unstable power situations is in fact 

representative. 

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 DOE concluded that both the 18-point 

and 10- minute approaches do offer the possibility 

that the microwave oven could be designed to alter 

its power consumption when it detects conditions 

that are uniquely associated with the standby 

power measurement. 

In other words, for example, the 

microwave oven could conceivably be programmed to 

turn off certain power-consuming components such 

as the cooking sensor, or it could dim the 

display, only during the times that are known to 

be associated with the test procedure. 

For example, during the 18 times that 

are set for the 18-point measurement or the 

display period between 3:33 and 3:42. 

In general, DOE's test procedures are 

designed to produce a measurement that is 

consistent with what is deemed to be the average 

consumer use. 

Even though the specific conditions 

that are specified for the test procedure aren't 

necessarily representative of how the consumers 

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use it, the end result is intended to represent 

the way an average consumer uses it. 

The proposed language in the SNOPR is 

intended to make explicit that DOE has long held 

that this is the purpose of the test procedure. 

And that there is a specific 

mechanism, namely a waiver process, that is 

mandatory for products for which the test 

procedure doesn't properly capture the energy use 

during what would be the typical consumer's usage 

of it. 

Looking for comments on that 

particular point, specifically requiring a 

petition for waiver to address products that 

modify their behavior during the specific 

conditions of the energy test. 

And seeks comment on whether more 

specificity should be provided in the test 

procedure. 

FACILITATOR BROOKMAN: Jennifer? 

MS. CLEARY: We certainly agree that 

circumvention should be avoided and addressed by 

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the Department. 

However, I think we would state that 

the waiver process, at least as it currently 

functions, may not be the best way to do it. It's 

very lengthy and it delays time to market. 

We would request that if that process 

is used, it's streamlined so that it can be more 

efficiently dealt with. 

FACILITATOR BROOKMAN: Specifics about 

ideas on ways it could be streamlined, if you all 

have ideas on that? 

MS. CLEARY: At this time we don't. 

We can consider those for our written comments. 

FACILITATOR BROOKMAN: Thank you. 

Okay. Other comments? 

Okay. 

MS. REICH: Test burden. This is an 

important consideration. Actually, the following 

section addresses the EPCA requirement to address 

it, as well. 

I want to comment here that the 

proposed test procedure is not believed to add 

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significantly to manufacturer test burden. 

The number of units that have to be 

tested to satisfy the regulatory requirements are 

defined under 10 CFR 430.24(i). DOE believes 

these are reasonable. 

Secondly, it believes that the test 

period, stabilization period, and measurement 

period that are now being proposed are now very 

reasonable. The 5-minute stabilization in either 

a 5- or 10-minute period for measuring standby 

power is reasonable. 

And because of this time frame being 

significantly smaller than the 12 hours, DOE 

believes that this would allow manufacturers to 

conduct testing on the production line. 

Manufacturers that are currently doing 

that on the production line for quality control 

purposes would still be able to continue to do 

that. They would not be required to conduct 

separate off-line testing. 

Actually, I'm going to segue directly 

into the same topic that is a regulatory 

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requirement. Statutory, maybe, is the more 

appropriate word. 

Section 323(b)(3) requires that any 

prescribed or amended test procedure shall be 

reasonably designed to produce test results which 

measure energy efficiency, energy use, or 

estimated annual energy cost during a 

representative average use cycle or period of use. 

The last part is really the key part 

that we're talking about now. It shall not be 

unduly burdensome to conduct. 

Back in the test procedure NOPR, DOE 

had tentatively concluded that the proposed 

amendments would meet this requirement because the 

standby power and off mode measurements are 

representative for products where the power 

consumption is both stable and unstable. 

Secondly, it would be based upon an 

international test standard that's widely used and 

accepted, the IEC 62301. 

And the test equipment and test 

conditions specifications that were added would 

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not require manufacturers, DOE believes, to make 

major investments in new facilities or equipment 

to perform that testing, and would not represent 

an undue burden to actually perform the tests. 

Because the amendments are similar for 

the SNOPR, the proposed amendments and in fact the 

methodology being proposed for the unstable 

measurement significantly cuts down on test time, 

DOE continues to believe that the proposed 

amendments in the SNOPR satisfy this EPCA 

requirement. 

That concludes the section on the 

standby power SNOPR. 

Any comments that people had today at 

the meeting will captured in a transcript. It 

will be part of the public record and, as Wes 

mentioned, will be available on the DOE Web site. 

We certainly invite additional written 

comments through the end of the comment period, 

which is October 4. This provides instructions on 

how these can be submitted either by email or by 

hard copy. 

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Page 102

 FACILITATOR BROOKMAN: Additional 

comments on the proceeding before we move on? 

MS. REICH: Okay. Moving then into --

FACILITATOR BROOKMAN: Wes Anderson? 

MR. ANDERSON: I want to make -- it's 

very effective if we stay with that process. I do 

get personal emails sent to me directly because my 

name and address are on the Web page. But I also 

get like 150 emails a day. 

So I just want to make it plain that 

it would be very helpful to go through this 

process. It keeps everything in its proper mail 

slot. I just want to emphasize that. 

FACILITATOR BROOKMAN: Thank you. 

Okay. Yes, please? 

MS. WALTNER: Just a question about 

sending in comments. Do you want comments on 

active mode separate? 

I noticed they have a different docket 

number. 

MS. REICH: Yes. 

MS. WALTNER: Okay. So they should be 

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completely separate? 

MS. REICH: Yes. 

FACILITATOR BROOKMAN: Thank you, Meg. 

Jennifer? 

MS. AMANN: Just a general process 

question. Is it possible to set up a system where 

when we email in our comments, we can get an 

automatic reply that they've been received? 

Because on a couple of the dockets, 

there have been some problems and we've been 

contacted later that the comments weren't 

received. We'd been talking so they knew we had 

sent them in. We had to resend them. 

So if we could get some kind of 

automatic response to let us know that they were 

received, that could really ease our minds to make 

sure we have documentation to show that our 

comments were in fact received. 

FACILITATOR BROOKMAN: Have you ever 

added that to your written comments? 

MS. AMANN: I've asked to get a --

I've said, you know, "Can you please respond that 

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you received this?" But I don't usually get a 

response. 

FACILITATOR BROOKMAN: Okay. Wes? 

MR. ANDERSON: I can't speak for IT 

right now. But I really don't know how to respond 

to that. We'll try. 

I mean, that's not the normal 

procedure because sometimes we could get -- some 

rules get 5,000 emails. And they're sort of the 

automatically generated same comment kind of 

thing. 

That would be impractical for us to 

respond to each one of those. So that's probably 

one of the reasons. 

I would say that if you're concerned 

it had been not received, I would make a call. 

Phone calls I can deal with. I don't have that 

many coming in. 

FACILITATOR BROOKMAN: Yet. 

MR. ANDERSON: Yet. Right. I have 

gotten some very -- anyway, I have gotten some 

interesting calls. But if you have a real 

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concern, just call when you send your email for 

this situation. 

FACILITATOR BROOKMAN: Why don't you 

include it in your written comments? 

MR. ANDERSON: Yes. Include that in 

your written comments. 

FACILITATOR BROOKMAN: Say it upfront 

where they can't miss it. 

MS. AMANN: There might even be a way 

to just have it on that email that goes out 

anytime something is, you know -- you send out a 

reply. 

MR. ANDERSON: We're actually changing 

this process. It will be more web-based, which 

would have that kind of capability. 

FACILITATOR BROOKMAN: Thank you. 

Okay. We're moving on to active mode. 

MS. REICH: Okay. Judith Reich again. 

For the active mode, as everybody's 

aware, there was a final rule published at the 

same time as the standby power microwave oven test 

procedure SNOPR. 

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 This final rule repealed the active 

mode provisions within Appendix I for microwave 

ovens specifically relating to cooking efficiency 

and energy factor, which had been the previous 

active mode metrics that have been defined. 

The reason that was done, again, was 

that DOE had determined the provisions that had 

been in place were producing results that were not 

accurate and repeatable. 

And because at that time DOE was not 

aware of other test procedures that could be 

evaluated for potential amendments to the active 

mode provisions. 

Therefore, DOE has repealed them. 

In that final rule DOE stated it would 

be considering initiating a new rulemaking to 

consider whether other active mode measurements 

could be incorporated into the test procedure. 

The steps that would be taken for such 

a rulemaking were, as a result of this public 

meeting and comments that would be submitted 

subsequent to this, DOE would consider initiating 

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a Notice of Proposed Rulemaking that would respond 

to those comments; culminating, of course, in a 

final rule. 

Let me discuss what specifically those 

previous provisions were based on. They had 

incorporated portions of what was -- at the time 

the DOE test procedure was first developed back in 

1997. 

It incorporated portions of what was 

then the current version of the IEC test standard 

for measuring performance of microwave ovens. 

That was IEC Standard 705. That's a typo there. 

That should be 1988. And Amendment 2 in 1993. 

Since that time, IEC has declared that 

standard to be obsolete and has issued a new 

version, Standard 60705-2006, which also measures 

the active mode performance of microwave ovens. 

Previously during the energy 

conservation standards rulemaking, both DOE and 

AHAM had evaluated microwave ovens using both the 

705 and 60705 methodology. 

DOE's test sample consisted of 32 

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microwave ovens. All of those, I believe, were 

countertop units. 

AHAM had tested 21 microwave ovens. 

What was noted from the results of 

those tests is that indeed there were significant 

variability in all of the cooking efficiency test 

measurements. 

And it was difficult, if not 

impossible, to ascertain what was contributing to 

the efficiency of any given unit. There were no 

correlations between measured efficiency and 

certain design features or construction designs. 

So DOE was unable to consider how an 

analysis of standards could be based on either of 

those methodologies. 

Specifically, the results from running 

tests according to IEC 705 and IEC 60705 were 

compared. Fundamentally, they are very similar. 

They both involve cooling down a 

sample of water to 10 degrees C below room 

temperature, and then operating the microwave oven 

at full power until the sample comes back to room 

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Page 109 

temperature. You record the time that's required 

and, of course, the power consumption that's 

required. 

A specific difference, though, for 

what was in the DOE test procedure at the time, 

which was the IEC 705, was that test period and 

power consumption did not include heating the 

filament during the magnetron heat-up. 

It also was noted that it held the 

tolerances for the ambient temperature and the 

final temperature that the water had to come to 

tighter tolerances than what 60705 allows. 

You can see what the ranges are. 

They're several degrees C. 

It's very critical to note that these 

tolerances are a large percentage, a significant 

percentage of the temperature difference that 

you're trying to capture. It's only 10 degrees C 

temperature rise and it's happening in a period of 

10s of second. 

So very small allowable tolerances and 

resolutions in your time measurements can create 

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very substantial differences/variations in your 

measurement of the energy factor. 

Then looking at what has now become 

the current IEC methodology, 60705, just noting 

that that energy measurement now does include the 

power that's being consumed by the magnetron 

during warm-up. 

That has a 1 or 2 percent efficiency 

point effect, which doesn't sound like a lot. But 

considering that the range of microwave oven 

efficiencies is very small to begin with -- a low 

efficiency unit might be 55 percent and a high 

efficiency one might be only 65 percent - - a 

variation of a couple of percent in there is 

significant. 

The second feature that we noted had 

great impact for 60705 was that the calculations 

require rounding off the measured power to the 

nearest 50 watts and efficiency to the nearest 

whole number. 

So when you perform the efficiency 

energy factor calculations, those have a 

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tremendous impact. They can really cause multiple 

percentage point swings in the measured 

efficiency. 

There are some uncertainties also left 

unclear in 60705. It doesn't provide specific 

methodology in how to determine the filament 

heat-up time in the magnetron. 

There is some additional uncertainty 

in it doesn't specify what the accuracy should be 

for your temperature and time measurements. 

All of these things combined add up to 

produce a highly variable measurement. 

This is a little tough, maybe, to 

interpret because there are two different things 

that are going on here. 

This table is looking at the 

difference between what was measured for IEC 705 

and then two calculations based on running 60705. 

This is running the test methodology 

exactly as it's required to, which means rounding 

of the power measurement. 

Then this is if you don't perform that 

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rounding, what sort of change occurs test to test. 

I believe these are all percentage 

points on efficiency, not percentage of 

efficiency. Again, a couple of percentage points 

is very significant. 

MR. ANDERSON: Judy, given that 

there's some people on the Web, when you talk 

about the different columns could you just --

MS. REICH: Describe it a little 

better? 

MR. ANDERSON: -- title the columns so 

they'll know what you're talking about? 

MS. REICH: Okay. Sure. 

The first set I was talking about was 

labeled IEC 705 1988. That's what was in the DOE 

test procedure to begin with. 

The second column under Test-to-Test 

Efficiency Range was labeled Rounded IEC 60705. 

That shows the greatest variation. 

What's entitled Raw IEC 60705 were the 

results that were obtained using the same measured 

data, but not performing the rounding on the power 

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Page 113 

consumption to the nearest 50 watts. 

What it shows you in the chart on the 

right-hand side, that compares the impact of the 

requirements in 60705 to perform the rounding. 

The purple, lighter bars show what 

happens if you don't round it. 

The pinker, higher level bars show 

what happens when you're forced to round it. 

These are in terms, again, of 

percentage points test to test for a given unit. 

The variation at least tripled from 

test to test for any specific unit depending on 

whether you had to perform that rounding 

calculation. 

The intent of this is to show the 

limitations of the existing IEC test procedure. 

In most cases it was found that the 

current, or what was current at the time -- the 

DOE test procedure that was based on the old, 

obsolete methodology was actually producing more 

consistent and repeatable results. 

So that gives some background. 

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 Neither of these it was felt were 

adequate to be measuring active mode energy use. 

Because again, a couple of percentage points are 

still a very significant uncertainty on a 

potential efficiency measurement that would only 

vary in a range of maybe 10 percentage points. 

At this point, those provisions are no 

longer in the DOE microwave oven test procedure. 

What we'd like to do is invite input 

from any party on methodology that's known for 

other means of measuring active mode energy use. 

What I've shown in this slide is we're 

aware that there are other test procedures out 

there. I think a fair number of them are largely 

based on 60705, so it's not known whether any of 

these are going to provide any better techniques. 

The last bullet point is a question 

mark if any party is aware of methodology besides 

what's listed here that could be considered. It's 

really intended at this point to open up the floor 

to any thoughts other parties may have. 

FACILITATOR BROOKMAN: Wayne Morris? 

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Page 115

 MR. MORRIS: Thanks. Wayne Morris 

with AHAM. 

The appropriate IEC committee that's 

in charge of 60705 is IEC Technical Committee 59K 

for Cooking. That's the determiner committee 

that's responsible for this. 

They actually will be meeting in 

Seattle in conjunction with the IEC general 

meeting in 2 weeks, I believe; 3 weeks. 

We certainly have representatives on 

TC 59K. In fact, I believe Tim Brooks from 

Whirlpool is a representative from AHAM to that 

committee. And we can convey some of these 

comments. 

But it would be very helpful if the 

Department could write this down in a way to 

explain what the deficiencies are more than just 

the slides on a PowerPoint. Those could be 

submitted to the committee as a reason to open up 

what's called a new work provision to try and 

inform a subcommittee to deal with this. 

I don't think that if we're finding 

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Page 116 

deficiencies, other people won't find the same 

situation. 

The Department is ahead of some other 

countries because I don't believe there's any 

regulatory actions pending in other countries on 

energy efficiency of microwave ovens other than 

for standby power. 

But that isn't to say that it isn't 

important. We ought to get it right. 

It would be important to feed this 

information back to the Technical Committee and 

ask them to deal with it very soon. Maybe within 

a few months or a year or so, they could come back 

with a revision to this test procedure that would 

be sort of a universal position that would be 

taken by all the countries together through the 

IEC process. 

FACILITATOR BROOKMAN: Wayne, can you 

confirm -- these other countries that apparently 

have enacted test procedures, are they based on 

60705? 

MR. MORRIS: I couldn't tell you. I 

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wouldn't know for sure. I mean, we can ask the 

question, certainly. But I wouldn't know offhand 

if they are or are not. 

I would agree with Judy that it's 

quite likely, considering that countries like 

Australia, Japan, Korea, and Brazil generally 

don't have standards that aren't based on IEC. 

I couldn't speak for China. In some 

cases, China does write its own standards that are 

different than the IEC. That is possible. 

But many of the others up there 

usually base their performance test methods on IEC 

wherever possible. 

The Canadian -- I thought that the 

C388 was actually identical, essentially, to the 

DOE old version. They're not using it for 

anything right now. There are no energy 

efficiency limits, to my knowledge, on microwave 

ovens in Canada. But that's a CSA standard. 

And I would think that if the US were 

to develop an energy test method for active mode 

on microwave ovens, we would encourage that it be 

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done cooperatively with Canada through a joint 

action that would involve CSA and also Natural 

Resources Canada. Because it makes only good 

sense that anything we do here, we would want to 

see similar. 

I think it's important that we feed 

this information back to the appropriate committee 

so that they have all of your particular thoughts 

and responses on this. And give it to them in a 

manner that says, "This is a problem. We need 

your help." 

I doubt seriously if it is something 

unique to just the United States. 

FACILITATOR BROOKMAN: Okay. Thank 

you. 

As Judy said, the Department seeks 

comment, ideas. We're really opening up here. 

Yes, Judy? 

MS. REICH: Before we do that, I also 

would like to state that there has been a report 

DOE has put together internally for the results of 

the analysis that is summarized here. 

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Page 119

 That could be made available to the 

committee you're describing. If you let us know 

what the appropriate means to transmit that is, we 

can certainly do that -- provide it. 

FACILITATOR BROOKMAN: Great. 

Other thoughts? 

Meg? 

MS. WALTNER: Can that report be 

publicly available as well, or just to the 

committee? 

MS. REICH: I believe that would be 

publicly available. Yes. 

FACILITATOR BROOKMAN: I'm looking and 

Wes Anderson is nodding his head yes. 

MR. ANDERSON: Yes. DOE will provide 

that. I'm just trying to figure out what would be 

the media. 

MS. WALTNER: Post it. 

MR. ANDERSON: Post it on the Web? 

Okay. We can post it on the Web. 

FACILITATOR BROOKMAN: Other thoughts, 

other test procedures that are not listed here, or 

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other ideas; anything additional? 

MS. WALTNER: I'm curious -- this is 

Meg from NRDC -- did you just test the two test 

procedures, or did you sort of experiment at all 

with different modifications to the test 

procedures when you were collecting that data to 

see if there were better methods? 

MS. REICH: I don't believe we strayed 

far from the methodology of those two tests. But 

I will also say that we developed techniques to 

more closely specify things than were included in 

the test procedure to, again, limit that 

variability. 

There were certain things that maybe 

hadn't been considered in the test procedure that 

we held more closely, controlled more of the test 

conditions. And were able to reduce that 

variability by doing so. 

But again, one of the fundamental 

problems is that was able to be done on IEC 705. 

That test procedure from IEC is obsolete. They 

don't make it available. It's completely 

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unobtainable. So we did not pursue that further. 

FACILITATOR BROOKMAN: Other thoughts 

on this? 

You're going to leave the Department 

to their own devices? 

No additional comments. Okay. 

MR. NOLD: One comment, please. 

FACILITATOR BROOKMAN: Craig? 

MR. NOLD: Craig Nold, General 

Electric. 

Earlier you mentioned that DOE had 

tested 32 microwave ovens and you believe those 

were all CMOs; then out of those 32, 12 of these 

are CMOs as well for this study that you performed 

here? 

MS. REICH: I think so. I'm not sure 

I understand the question entirely. But I see 

James nodding his head, who actually performed the 

tests. 

MR. BATTAGLIA: These 12 are a subset 

of those 32 countertop microwave ovens. 

MR. NOLD: They were all CMOs as well? 

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Page 122

 MR. BATTAGLIA: I'm sorry. What do 

you mean by CMO? 

MR. NOLD: Countertop units. 

MR. BATTAGLIA: Yes. 

FACILITATOR BROOKMAN: That was James 

Battaglia. 

Navigant. 

MR. BATTAGLIA: James Battaglia, 

FACILITATOR BROOKMAN: Navigant, yes. 

MR. NOLD: I asked the question 

because there also needs to be consideration --

due to cavity sizes and design techniques of the 

cavities, your traditional CMOs do not dump the 

magnetron energy in the same way as an OTR would. 

That needs to be taken into consideration. 

FACILITATOR BROOKMAN: Kevin? 

MR. MESSNER: Just to add to that, as 

we talked about earlier, as you think about active 

mode test procedures you need to -- it has to --

there is a difference between the countertop 

microwave ovens and the over-the-ranges. There 

are differences there, significant differences, 

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one of which Craig was talking about. 

There's just the general things that 

folks think about. There's the venting. There's 

the lights overhead. They are designed over a 

range with certainly a lot of different 

requirements than on a counter. 

So these two, you can't just think 

microwaves, countertop, over-the-range, same 

thing. They're different and they need to be 

looked at differently. 

MS. REICH: Okay. 

FACILITATOR BROOKMAN: Wes Anderson? 

MR. ANDERSON: This is Wes. We should 

also bring that up in the standards portion of the 

rulemaking. I think that may address the product. 

It just sounds like you're trying to 

get a product distinction and that needs to be 

considered. There are certain legal hurdles 

there, as well. 

FACILITATOR BROOKMAN: The follow-up 

question I had was, then does that mean that the 

test procedure needs to do some sort of structural 

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specification 

differences? 

that talks about all those 

I don't know whether it does or 

doesn't. 

MR. ANDERSON: The measuring, would 

the measuring be different for the countertop 

versus over-the-range; or are you saying the 

energy usage is different, the energy draw is 

different? 

MR. MESSNER: This may not be as much 

detail as you want. 

Jen, if you have more you can add it. 

There's differences overall on the 

appliances. Now, whether or not the measurement 

-- there's differences that need to be understood 

and contemplated. 

You can't just say, "Here's a test 

procedure for microwaves," and walk away assuming 

that it's going to make sense for both of these 

types. There are differences. 

MR. ANDERSON: We'd appreciate it if 

you could give us a little clarity as to how that 

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would affect the test procedure, or how a 

manufacturer would do a test on their product to 

determine if it's doing what it's designed to do. 

I think that would be internal testing 

that the designers would have to be able to 

distinguish between that. 

That kind of information would be 

helpful to DOE, just from a product difference if 

there is one. 

MR. MESSNER: Yes. Certainly we can 

look to if we can expand on that in the written 

comments and that type of thing. 

FACILITATOR BROOKMAN: Thanks, Kevin. 

Craig, do you have something else? 

MR. NOLD: Not at this time. 

FACILITATOR BROOKMAN: Okay. Thank 

you. 

Additional comments on this section? 

I think we're pretty much through it, 

right? 

MS. REICH: I think so. Yes. 

FACILITATOR BROOKMAN: So once again, 

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the how and where to comment slide. 

Do you want to add to the --

MS. REICH: I just again note, this is 

a different rulemaking than the standby power test 

procedure rulemaking. So it does have a unique 

docket number and RIN. There is also a different 

DOE email address to which comments can be sent. 

FACILITATOR BROOKMAN: It's not 

reflected in the agenda. Typically it's the case 

that the Department wants to provide yet another 

comment for any final comments, any additional 

issues that individuals wish to raise. 

I want to provide that opportunity now 

for any final comments as we hand out the 

evaluation form. 

Okay. Back to Wes for closing 

remarks. 

MR. ANDERSON: I'd like to thank you 

guys for coming out and expressing your views. 

It's very important for the Department to 

understand where the community, that being the 

manufacturers as well as the people who are 

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concerned about the environment -- input to help 

us round out our perspective. 

If you have any questions, I have some 

cards here that I will be happy to hand out. 

comments. 

soon. 

We're looking forward 

Thanks for coming out. I'l

to 

l see 

your 

you 

FACILITATOR BROOKMAN: Thank you. 

Safe travels. 

(Whereupon, at 11:53 a.m. the meeting 

was concluded.) 

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C E R T I F I C A T E
 

This is to certify that the foregoing transcript 


In the matter of: Test Procedures for Microwave Ovens 

Public Meeting
 

Before: US Department of Energy
 

Date: 09-16-10
 

Place: Washington, DC
 

was duly recorded and accurately transcribed under 


my direction; further, that said transcript is a 


true and accurate record of the proceedings. 


-----------------------

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com