U.S. DEPARTMENT OF ENERGY

OFFICE OF ENERGY EFFICIENCY AND RENEWABLE ENERGY.

TEST PROCEDURES FOR WATER HEATERS, RANGES, OVENS,

COOKTOPS AND MICROWAVE OVENS AND CLOTHES WASHERS

JULY 12 & 13, 1995

VOLUME I

JULY 12, 1995

a'

EE-RM-94-230 COMMENT 0C
PANEL MEMBERS:

Ingrid M. Watson, Presiding Official

Office of Codes and Standards

U.S. Department of Energy

Program Manager

Kitchen Products

Marc LaFrance, Program Manager

Office of Codes and Standards

U.S. Department of Energy

Program Manager

Clothes Washers

Bryan Berringer

Office of Codes and Standards

U.S. Department of Energy

Program Manager.

Water Heaters

Eugene Margolis

Attorney

Office of Codes and Standards

U.S. Department of Energy

Steve Nabinger

National Institute of Standards and Technology

Test Engineer

Kitchen Products

Brian Dougherty

National Institute of Standards and Technology

Test Engineer

Water Heaters

Jim Kao

National Institute of Standards and Technology

Test Engineer

Clothes Washers

EE-RM-94-230 COMMENT 0C
INDEX

Welcome and Opening Remarks - Ingrid Watson 

PRESENTATIONS:

WATER HEATERS:

Frank Stanonik

Gas Appliance Manufacturers Association 

Questions and Answers 

Matt Chwalowski

Manager, Electrotechnology Policy

Edison Electric Institute 

Questions and Answers 

RANGES:

Charles Samuels 

Jack Weizeorick 

Association of Home Appliance Manufacturers

Questions and Answers 

MICROWAVE OVENS:

Jack Weizeorick

Association of Home Appliance Manufacturers 

Questions and Answers 

Joy W. Daniel

Association of Home Appliance Manufacturers 

Questions and Answers 

EE-RM-94-230 COMMENT 0C
INDEX

CLOTHES WASHERS:

Charles Samuels, AHAM 

Dick Stilwell, AHAM 

Questions and Answers 

Curt Reichman, AHAM 

Questions and Answers 

Earl Jones

General Counsel, General Electric 

Questions and Answers 

Larry Hawkins

Senior Engineer, General Electric 

Questions and Answers

EE-RM-94-230 COMMENT 0C
1 PRO C E ED NG

2 MS. WATSON: Good morning and welcome. 

3 Ingrid Watson, program manager for kitchen products

4 and today's presiding official.

5 On behalf of the Department of Energy, I

6 would like to thank you for taking the time to

7 participate in this public hearing concerning the

8 Department's test procedures concerning the energy

9 conservation program for consumer products.

10 The purpose of today's public hearing is 

11 receive oral testimony on the notice of proposed

12 rulemaking regarding the Department's test procedure

13 for water heaters, kitchen ranges, ovens and

14 microwave ovens, and clothes washers, as discussed 

15 the proposed rule, published in the Federal Register

16 on March 23rd, 1995.

17 The comments received today and those

18 submitted during the written comment period will

19 assist us in developing the final rule.

20 The comment period for this rulemaking en

21 August 31st, 1995.

22 All comments submitted on this proposed

23 rulemaking will be considered before DOE establishes

EE-RM-94-230 COMMENT 0C
1 the Final Rule.

2 Comments received after the comment peri

3 will be considered to the fullest extent.

4 Hearing Guidelines:

5 As DOE's presiding official for this

6 hearing, I will set forth the guidelines for

7 conducting the hearing and provide other pertinent

8 information. A complete transcript of this hearing

9 will be available at the Department of Energy's

10 Freedom on Information Reading Room, as described i

11 the notice. Anyone wishing to purchase a copy of t

12 transcript, may make arranges with the court

13 reporter.

14 This will not be an evidentiary or judic

15 type of hearing. It will be conducted in accordanc

16 with Section 553, title 5, United States Code, in

17 Section 336 of the Act.

18 To provide the Department of Energy with 

19 much pertinent information and as many views as can

20 reasonably be obtained and to enable interested

21 persons.to express their views, the hearing will be

22 conducted in accordance with the following

23 procedures:

EE-RM-94-230 COMMENT 0C
1 Speakers will be called to testify based 

2 a schedule of those people who responded to the

3 notice of this hearing;

4 Speakers have been allotted 10 to 30

5 minutes for their oral presentations. Some people

6 will be shorter than 10 minutes;

7 Anyone may make an unscheduled oral

8 statement of all scheduled speakers have delivered

9 their statements; and,

10 At the conclusion of all presentations,

11 each speaker will be given the opportunity to make 

12 rebuttal statement, subject to time limits, and will

13 be called in the order in which the initial

14 statements were made.

15 Questions may be asked only by the panel

16 members conducting the hearing, however, the

17 presiding official will allow any interested person

18 an opportunity to question speakers who have made

19 oral presentations.

20 This opportunity will be allowed after an

21 rebuttal statements, to the extent that the presidin

22 official determines that such question is likely to

23 result in a more timely and effective resolution of

EE-RM-94-230 COMMENT 0C
1 the issue.

2 Persons interested in making use of this

3 opportunity must submit their request shortly after

4 the completion of any rebuttal statement to the

5 registration desk. I ask that you please write you

6 name and who you represent on the card provided and

7 leave it at the registration desk.

8 As mentioned earlier, the close of the

9 comment period is August 31st, 1995. All comments

10 received will be available for public inspection at

11 the DOE Freedom of Information Act. Such comments

12 should be addressed to the Department of Energy, as

13 noted in the Proposed Rule for today's hearing.

14 Ten copies of the written comments are

15 requested. In addition, the Department would

16 appreciate an electronic copy in Word Perfect 5.1 o

17 the comments. No faxed comments will be accepted.

18 Any persons submitted information which 

19 or she believes to be confidential and exempt by la

20 from public disclosure, should submit to the same

21 address one complete copy and nine copies from which

22 information claimed to be confidential has been

23 deleted.

EE-RM-94-230 COMMENT 0C
1 In accordance with the procedures

2 established in 10 CFR 1004.11, the Department of

3 Energy shall make its own determination as to wheth

4 or not the information shall be exempt from public

5 disclosure.

6 We appreciate the time and effort you hav

7 taken in preparing your statements and are pleased 

8 receive your comments and opinions.

9 I would like to introduce the members of

10 the panel.

11 Joining me this morning is Steve Nabinger

12 test engineer at the National Institute of Standards

13 and Technology;

14 Brian Dougherty, test engineer for water

15 heaters at NIST;

16 Bryan Berringer, program manager for wate

17 heaters at Department of Energy;

18 Jim Kao, test engineer at NIST, for cloth

19 washers;

20 Marc LaFrance, program manager of clothes

21 washers at the Department of Energy; and,

22 Eugene Margolis, attorney at the Office o

23 General Counsel.

EE-RM-94-230 COMMENT 0C
1 At this time, I would like to call the

2 first speaker, Frank Stanonik. Could you state your

3 name and who you represent.

4 FRANK STANONIX

5 GAS APPLIANCE MANUFACTURERS ASSOCIATION

6 MR. STANONIK: Good morning, I'm Frank

7 Stanonik with the Gas Appliance Manufacturers

8 Association.

9 Gas Appliance Manufacturers Association 

10 a national trade association whose membership

11 includes almost all U.S. manufacturers of residentia

12 gas, oil and electric water heaters.

13 We appreciate the opportunity to comment 

14 DOE's Proposed Rule, published in the March 23rd

15 Federal Register, to revise the efficiency test

16 procedures for residential water heaters.

17 As noted in the discussion section of tha

18 notice, GAMA had previously indicated the need to

19 amend the water heater efficiency test procedures to

20 correct the calculation for the first hour rating an

21 to add covering for models of less than 30 gallons

22 storage capacity. We are pleased that DOE has

23 initiated this process.

EE-RM-94-230 COMMENT 0C
1 In the March 23rd Federal Register notice

2 DOE listed several issues on which it was

3 specifically seeking comments. To the extent that w

4 can, at this time, we will address those issues. I

5 say "at this time," because in many cases we are

6 working on doing tests, comparative tests or tests 

7 some of the proposals, and until we have that data w

8 really can't provide full comments on how we see the

9 proposed revisions.

10 It should also be noted that, to our

11 knowledge, all models of storage water heaters havin

12 less than 20 gallons capacity are electric water

13 heaters.

14 Our comments on that issue, for those

15 models, will be within that context. We'll be

16 talking only about electric.

17 With that introduction, I will get into 

18 issues that DOE identified.

19 The first one was adding electric and oil

20 instantaneous water heaters:

21 We agree with the concept that residentia

22 electric and oil instantaneous water heaters should

23 be covered by the test procedures. However, we are

EE-RM-94-230 COMMENT 0C
1 not aware presently of the existence of any models o

2 oil-fired instantaneous water heaters. You may be

3 putting coverage in that will not ever be used.

4 Also, with regard to electric instantaneo

5 water heater, DOE may wish to distinguish models tha

6 could serve multiple points of use as opposed to

7 small models intended for a single point of use, su

8 as a sink, or whatever. They are very different

9 units.

10 The next issue that was listed was the dr

11 rate for less than 20 gallon models:

12 The draw schedule and draw rate for model

13 with less than 20 gallons of storage capacity needs

14 to be corrected. The proposed 1 gallon per minute

15 rate for withdrawing water from the unit is too high

16 for models with values of only 5 gallons or so.

17 Consider that the first measurement in th

18 test procedures of the outlet temperature occurs at

19 15 seconds after the start of the test. Subsequent

20 measurements are at 5 second intervals.

21 At a 1 gallon per minute flow rate, that 

22 seconds is a 1/4 of a gallon. Compared to the total

23 1.5 gallons of the draw; that 1/4 gallon represents

EE-RM-94-230 COMMENT 0C
1 over 16 percent of the total draw. We believe that

2 is too large a relative volume of water to draw

3 without any measurement of its temperature.

4 GAMA members are currently conducting so

5 comparative tests at 1 and 1/2 gallon per minute fl

6 rates, and we will provide that data to DOE when th

7 tests are completed. Our solution would be to go

8 with the smaller flow rate.

9 The next issue was the efficiency

10 requirement for less than 20 gallon models:-

11 It is not appropriate, in our opinion, t

12 extend the current minimum efficiency standard, the

13 .93-.00132 times the volume, to apply to models with

14 less than 20 gallons storage capacity.

15 The current federal minimum efficiency

16 requirements for residential storage water heaters

17 were developed based on data and information

18 involving the models covered by the existing DOE

19 efficiency test procedure; that is, models with

20 volumes between 100 and 120 gallons.

21 Furthermore, the minimum efficiency

22 requirement for electric residential storage water

23 heaters was selected to be a slight improvement over

EE-RM-94-230 COMMENT 0C
1 the 4 watts per square foot of tank surface area,

2 maximum standby loss criterion that was specified i

3 ASHRAE Standard 90A-1980 for those size water

4 heaters.

5 The complete requirement in ASHRAE 90A-1

6 was an hourly standby loss not greater than 4 watts

7 per square foot of tank surface area, or 43 watts,

8 whichever was greater.

9 That requirement properly recognized tha

10 as the tank surface area became smaller, the four

11 watts per square foot criteria became too stringent

12 because fitting losses became too large a portion o

13 the total standby loss.

14 The small volume models, less than 20

15 gallons, have the same fittings and connection loss

16 as the larger volume models, yet their tank surface

17 area if significantly smaller. It is exactly these

18 models to which the 43 watts per hour maximum stand

19 loss specification applies.

20 These smaller volume models were not

21 considered when the federal minimum efficiency

22 standards were established, and a separate minimum

23 efficiency requirement for those models must be

EE-RM-94-230 COMMENT 0C
1 established.

2 The results of our testing which we will

3 provide to DOE, when it's available, should be

4 helpful in determining an appropriate comparable

5 minimum efficiency requirement.

6 As further evidence of the inapplicabilit

7 of the current federal minimum efficiency requiremen

8 to small volume models, I have attached a calculati

9 which shows the maximum hourly standard loss that

10 would be allowed for a 15-gallon water and a 6-gall

11 water heater, if the .93-00132 times the volume

12 minimum energy factor were applied to those two

13 models.

14 You can look at the calculations, but you

15 will see that the resultant hourly standby loss is

16 significantly less than 43 watts. It's a very low

17 number. I'm not sure, but I suspect practically

18 unacceptable.

19 The next issue was the definitions:

20 We have no specify comments on the propos

21 definition of heat pump water heaters. However, we

22 do not understand the purpose of this expanded

23 definition.

EE-RM-94-230 COMMENT 0C
1 We just bring that to your attention

2 because the definition has been significantly

3 expanded and, at this point, it's not clear what th

4 intent of that was, and it may be something we can

5 discuss further.

6 We also do not understand why a definiti

7 for solar water heater is being added. The

8 definition that is proposed is imprecise.

9 The percentage of water heating done by

10 solar energy is dependent on the specific

11 installation and geographic location.

12 The proposed specification that a solar

13 water heater is a water heater designed to obtain 5

14 percent of the annual water heating energy from the

15 sun does not seem to be an essential defining

16 characteristic of that type of water heater, the

17 point being, what if it's 40, what if it's one-thir

18 it's still a solar water heater.

19 The last one, we have a comment or an is

20 the DOE identified, was the test procedure for heat

21 pump water heaters:.

22 We recommend that the test procedure for

23 heat pump water heaters be revised to properly

EE-RM-94-230 COMMENT 0C
1 recognize that a significant percentage of the wate

2 heating they do is still being done by the backup

3 electric resistance elements. This could be done b

4 either changing the draw schedule to be more

5 representative of a typical usage schedule in a

6 residence or by adding a separate test to estimate

7 what percentage of the total water heating is done 

8 an electric resistance element.

9 We are running some different draw sched

10 tests on a heat pump water heater at ETL Testing

11 Laboratories, and will provide that information to

12 DOE once the work is completed.

13 One issue not listed in the Federal

14 Register notice on which we have a comment, is the

15 piping connections for under the counter and counte

16 top water heaters.

17 Section 4 should be modified to separate

18 address the under the counter water heaters and

19 counter top water heaters. While these two types o

20 water heaters may appear somewhat similar, they are

21 intended for different installations.

22 Specifically, the water connections for 

23 counter top model will be within the water heater

EE-RM-94-230 COMMENT 0C
1 jacket so that the model can be installed flush to

2 the back wall. This is not the case for an under t

3 counter model.

4 Also, separate piping arrangements should

5 be provided for the models less than 20 gallons,

6 which are floor mounted.

7 Attached to my statement are suggested

8 revisions to Section 4.1, 4.3, revised figures 4a a

9 4b, and new figures 5 and 6, which reflect our

10 comments.

11 We appreciate this opportunity to presen

12 our comments and intend to provide additional data 

13 the result of ETL's testing becomes available.

14 MS. WATSON: Thank you.

15 QUESTIONS AND ANSWERS

16 MS. WATSON: Are there any questions?

17 Steve?

18 MR. NABINGER: No.

19 Brian?

20 MR. DOUGHERTY: Right.- As far as the

21 instantaneous water heaters, the electric, I'm aware

22 that they have a 9 watt. Do you know the other

23 intervals that they have, as far as under 12 watt --

EE-RM-94-230 COMMENT 0C
1 KW -- 12KW?

2 MR. STANONIK: No, I'm not aware. I mean

3 I'd say sporadically I have heard comments or had

4 people call me and say they are working on or they

5 have an electric instantaneous water heater that th

6 intend would be comparable to what I'm going to cal

7 a whole house water heater, a unit that could satis

8 the demands of the whole house.

9 But I'll tell you, in most of the cases 

10 -do not see any follow up that actually tells me wha

11 this model is, what it's input is. I think from a

12 realistic standpoint and the limitations of

13 housewaring, probably 9KW, in fact, is pretty high.

14 MR. DOUGHERTY: Right.

15 How about on the electric storage tank

16 water heaters? Do they.go as low as 1 gallon and

17 then maybe to 2 gallons, or how do they jump around

18 MR. STANONIK: The typical sizes, in

19 talking to our members, are something around 15.

20 They either have perhaps a 10 or a 12, and then it

21 appears to be 9, 6, either a 4 or a 5 and then a 2.

22 I think in terms of what they offer for

23 that kind of unit, 2 is probably the smallest.

EE-RM-94-230 COMMENT 0C
1 Something less, you're now looking at, for lack of 

2 better description, what I'm going to call the

3 Insinkerator or the instant heater that attaches to

4 the incoming hot water line at your sink or

5 something, which those I don't think hold -- I'm no

6 sure how much volume they hold.

7 MR. DOUGHERTY: Okay.

8 MS. WATSON: Marc?

9 MR. LaFRANCE: No questions.

10 MS. WATSON: Eugene?

11 MR. MARGOLIS: No questions.

12 MS. WATSON: Jim?

13 MR. KAO: No questions, thank you.

14 MR. STANONIK: Thank you.

15 MS. WATSON: All right.

16

17

18

19

20

21

22

23

EE-RM-94-230 COMMENT 0C
1 MS. WATSON: I would like to call the nex

2 speaker, Dr. Matt Chwalowski. Would you state your

3 name and who you represent.

4 MATT CHWALOWSKI

5 MANAGER OF ELECTROTECHNOLOGY POLICY

6 EDISON ELECTRIC INSTITUTE

7 DR. CHWALOWSKI: Good morning. I am

8 Matt Chwalowski. I am with Edison Electric

9 Institute. We are a trade association of investor10 owned electric utilities.

11 Our members provide about three-quarters 

12 electric energy nationwide.

13 My comments this morning will be limited 

14 issues related exclusively to water heating testing

15 procedures. Our comments are based on an extensive

16 analysis, which was done by Dr. Carl Hiller, at

17 Electric Power Research Institute, EPRI.

18 Our industry has identified several

19 critical aspects of the Depart's proposal that, in

20 our view, are technically incorrect or fail to

21 reflect the reality of hot water usage.

22 While some elements of the proposal are a

23 improvement over previous DOE rulings in this area,

EE-RM-94-230 COMMENT 0C
1 we are still very concerned with several issues, an

2 we urge the Department to take our views into

3 consideration.

4 Today, I will summarize our principal

5 concerns, focusing, in particular, on the first-hou

6 rating procedure. We will provide additional

7 comments to the Department on all aspects of the

8 proposal in our written comments.

9 Here are our preliminary conclusions:

10 First-hour testing and rating procedure:

11 The proposed first-hour testing and ratin

12 procedure, while an improvement over the method

13 currently in use, and over the 1991 procedure, is

14 still flawed and should not be implemented.

15 These are very harsh words, however, we

16 believe that they are justified.

17 In particular, the proposed first-hour

18 rating procedure is based on an unrealistic water

19 consumption behavior patterns and, as a result, the

20 first-hour concept, an arbitrarily defined time

21 period, means little in relation to how hot water is

22 actually used and not useful in sizing water heating

23 svstems. - - - r - - -

EE-RM-94-230 COMMENT 0C
1 Today, we would like to propose an

2 alternative to the proposed hot water delivery

3 testing and rating system but eliminate the

4 shortcoming of past and current DOE approaches whil

5 being much faster, easier, and more reliable to use

6 Let me first highlight the shortcomings 

7 a currently proposed DOE first-hour rating procedur

8 EPRI is conducting extensive research.

9 It's an 18-month study to show how unimportant the

10 first-hour rating period is for the performance and

11 operation of water heaters.

12 We notice that in the DOE notice, there 

13 no justification offered why the hot water delivery

14 capability should be evaluated over such an arbitra

15 period, such as one hour.

16 Secondly: Large tanks in these procedure

17 are penalized relative to smaller tanks because the

18 test procedures uses a fixed flow rate for

19 withdrawing water from tanks. As a result, the

20 procedure assumes that large tanks will be in a

21 drawdown mode for greater portion of the first hour

22 thereby delaying and shortening useful recovery tim

23 Moreover, and better significance, the

EE-RM-94-230 COMMENT 0C
1 currently proposed procedure allows draws to continu

2 past the end of the one-hour period, if water at

3 useful temperature is available, so it allows for

4 arbitrary times.

5 Water heater may be operating for the nex

6 30 seconds, but one may be drawing water for the nex

7 perhaps 45 minutes.

8 Due to this, the actual period of a test

9 can be dramatically different for different sizes an

10 types of water heaters because of the allowance to

11 continue draining water after the one-hour period i

12 over.

13 Allowing each tank to be tested over a

14 different time period in an unregulated manner gives

15 an unfair advantage to some systems and reduces the

16 comparability of ratings based on the proposed

17 procedure.

18 Thirdly: The proposed first-hour rating

19 procedures gives artificially high first-hour rating

20 for systems having high heat input rates, relative t

21 some having lower heat input rates, by virtue of the

22 draw behavior patterns imposed.

23 The draw behavioral patterns imposed ofte

EE-RM-94-230 COMMENT 0C
1 cause draw/no draw decisions to be made but are

2 dramatically different in one system compared to

3 another, even though in reality the system are

4 behaving very similarly.

5 Let me give you a brief example.

6 If you have two tanks and you are

7 conducting a test, making a draw, and then waiting

8 until the uppermost reaches 110 -- let's say we hav

9 two tanks, and one tank reaches 109, which is short

10 just one degree of 110; the procedure says that you

11 can impose a draw at the end of one-hour period, but

12 then you have to stop after 30 seconds.

13 Let's say that the other tank reaches the

14 temperature of 112. Let's say it's a large tank.

15 You can go and make your draws every three minutes

16 for the next hour.

17 From the point of view of a customer,

18 there's two minutes differential in time, but

19 involves perhaps going from 109 to 112, is

20 immaterial, irrelevant.

21 The danger of using this procedure is tha

22 it allows for a lot of gaining to occur. From a

23 mathematical, physical point of view, it is clearly

EE-RM-94-230 COMMENT 0C
1 something wrong where such a huge function is allowe

2 where the time delay involved is so small.

3 So we very strongly feel that, here, the

4 procedure simply breaks down, and this is what we

5 consider one of the major flaws, because what's goi

6 to happen-is you have those two tanks and you can

7 just manipulate with burn rates, with thermostats

8 maybe slightly different.

9 In one case say you have 40 gallon ratin

10 in another case, if you go to 112, you can get 60-

11 hour rating, and we would rather not see a situatio

12 where such gaining is allowed.

13 Will gaining occur? Sure, it will, and 

14 some advantage to somebody.

15 Fourth: The proposed first-hour rating

16 procedure fails to account for the differences in

17 energy content of water delivered at different

18 temperatures during the first-hour testing and rati

19 procedures.,

20 In other words, the way the procedure is

21 written right now, water at temperature 130 and 110

22 has the same energy content. DOE states that there

23 are no manufacturers that currently induce mixing o

EE-RM-94-230 COMMENT 0C
1 hot and cold water to deliver a large amount of not

2 quite so hot water, before there is a need to adjus

3 hot water delivery ratings.

4 In fact, we know that there is at least 

5 U.S. manufacturer who has recently purchased the

6 right to manufacture and sell the equivalent of such

7 an internal mixing product and intends to bring the

8 technology to market in the not-so-distant future.

9 From the perspective of this industry, yo

10 may know that we are going through a possible

11 restructuring, and it's more and more likely that

12 energy use at off-peak would be more significant in

13 the competitive situation. That's why we urge the

14 Department to make sure that it considers such

15 situations as they become more prevalent.

16 Fifth: The DOE proposed first-hour ratin

17 procedure as applied to instantaneous water heater 

18 inappropriate because consumers may mistakenly

19 compare instantaneous and storage type water heaters

20 as being equivalent if similarly first-hour rated.

21 The first-hour rating for instantaneous

22 water heaters should be abandoned in favor of a

23 maximum gallons per minute capability rating at 50

EE-RM-94-230 COMMENT 0C
1 degree Fahrenheit temperature rise. This will reduc

2 application mistakes.

3 Basically, we do not want a situation whe

4 a customer sees first our rating and goes and

5 purchases an instantaneous water heater. We want hi

6 to choose storage type water heater if that's the

7 proper application for him.

8 Before I briefly propose our first-hour

9 rating procedure, let me make additional comments to

10 other aspects of DOE proposal.

11 Similarly to GAMA, we have concerns about

12 requirements for tanks less than 20 gallons; the

13 requirements of same energy factor as for larger

14 water heater is not correct, because energy factor

15 was developed at a flow rate of -- data consumption

16 of 64.3 gallons, and that exists at only one

17 consumption level.

18 In other words, DOE has to develop new

19 curves for tanks less than 20 gallons.

20 The reasons for that are explained in my

21 testimony.

22 We also have a concern about very small

23 tanks. There are some applications where there are

EE-RM-94-230 COMMENT 0C
1 one and two-gallon water heaters -- gourmet kitchens

2 and applications like that. These tanks simply

3 cannot meet the draw schedule, which is required,

4 without severely depleting the tank.

5 So a much less severe draw schedule shoul

6 be used for such tanks but recognizes the nature of

7 use of his equipment or perhaps such tanks should be

8 eliminated from considerations.

9 We also have concerns about some of the

10 definitions and wording and specifically about add-o

11 heat pump water heater definition and heat pump wate

12 heater storage tank.

13 My suspicion is that these definitions co

14 from last year's hearing when DOE wanted to eliminat

15 electric resistance water heaters, but the problem

16 that is occurring is that you attempt to create new

17 definitions, but essentially you have two almost

18 identical tanks. One you label electric resistance

19 and the other one the add-on heat pump water heater.

20 Simply, common sense would indicate that 

21 would increase the cost to consumers and

22 unnecessarily create additional barriers. This is

23 ill advised. These new tanks are essentially of

EE-RM-94-230 COMMENT 0C
1 identical construction. They will meet two separate

2 definitions. They will create confusion and

3 potentially increase the cost of heat pump water

4 heaters.

5 Regarding our proposed first-hour or

6 alternative to hot water delivery rating test, I hav

7 outlined it in my proposal, where we will provide

8 specify information with examples and with equations

9 by August 31st to the DOE.

10 I just want to highlight that in our

11 proposed procedure we eliminate the drawbacks that

12 DOE procedures suffer from right now. What we do is

13 we impose draws up front and times zero is at the T14 25 degrees.

15 Then the only thing that is done is we

16 measure the time required for temperature in the tan

17 of upper thermal couple to reach 110 and do simple

18 mathematical calculation, thereby reaching very

19 quickly the rating for the tank.

20 This is simple, this is reproducible, it

21 provides useful information. It eliminates the

22 potential for gaming and eliminates what is importan

23 for our industry bias, based on tank size, draw

EE-RM-94-230 COMMENT 0C
1 patterns, and tank type.

2 Regarding instantaneous water heaters, we

3 are opposed to allowing instantaneous water heaters

4 to be tested under different draw flow rates and the

5 be given a first-hour rating similar to tank-type

6 water heaters. This could cause a lot of

7 misapplication of water heaters.

8 Again, I want to stress that we would lik

9 to see that instantaneous water heaters be listed in

10 different sections and be rated in terms of maximum

11 gallons per minute delivered at 50 degree temperatur

12 rise.

13 In summary, the Department has raised

14 several important issues regarding testing procedure

15 for water heaters.

16 Our industry believes there are serious

17 implications for the marketplace if the currently

18 proposed procedures are allowed to go forward. Thes

19 proposals have significant and burdensome

20 consequences that they raise and numerous technical

21 concerns and, if unaltered, may actually create a ne

22 barrier to high efficiency water heating

23 technologies.

EE-RM-94-230 COMMENT 0C
1 We request that the Department consider 

2 comments and conduct a thorough reconsideration of

3 water heater test proposals.

4 Thank you.

5 MS. WATSON: Thank you.

6 QUESTIONS AND ANSWERS

7 MS. WATSON: Do you have any questions o

8 comments, Steve?

9 MR. NABINGER: I have no questions.

10 MS. WATSON: Brian.

11 MR. DOUGHERTY: Yes.

12 Will the proposed first-hour rating that 

13 being developed be able to differentiate single

14 element versus two-element electric water heaters?

15 DR. CHWALOWSKI: The answer is yes.

16 MR. DOUGHERTY: Okay.

17 DR. CHWALOWSKI: But I want to stress tha

18 we are primarily, as the industry, focused on two19 tank elements -- excuse me -- two-element tank

20 because of significant disadvantages for consumers

21 with single element tank. But the answer is yes.

22 MR. DOUGHERTY: Okay. That was one of th

23 driving factors behind the change in the '79 version

EE-RM-94-230 COMMENT 0C
1 to the --

2 DR. CHWALOWSKI: I understand that. I

3 understand that.

4 MR. DOUGHERTY: Okay. The second thing

5 was, would you be able to provide data showing the

6 proposed method as far as the discontinuity problem

7 That was, in fact, the problem with the 

8 version, and there was an attempt this time to try 

9 minimize the discontinuity problem.

10 Can you provide examples where that is

11 shown to be excessive now?

12 DR. CHWALOWSKI: What we will do is by

13 August 31st we will provide a number of examples,

14 including the test data that we are collecting from

15 an 18-month old study. The studies, right now, is 

16 the 10-month, so by next month we should have some

17 data that we can draw some conclusions from, and we

18 will be able to share that with the Department.

19 MR. DOUGHERTY: At that time, too, will y

20 have a better feel on what may be a -- I agree, ther

21 is nothing magical about one hour. Whether or not

22 there's a better interval to say. the sizing should

23 be based on an hour-and-a-half. Would that be

EE-RM-94-230 COMMENT 0C
1 available at this time or does that have to wait

2 maybe until the study is completely finished?

3 DR. CHWALOWSKI: What we have done is,

4 Dr. Hiller from EPRI has conducted literally hundred

5 of rounds on watts, and that will be available.

6 We are in the process of getting some tes

7 done by ETL Labs, to verify those computer runs, and

8 I don't know whether that will be available by Augus

9 31st, frankly.

10 MR. DOUGHERTY: Okay. The last I wanted 

11 say, I just wanted to thank you and Frank both for

12 making very constructive comments. I appreciate

13 that.

14 DR. CHWALOWSKI: Thank you.

15 MS. WATSON: Do you have any questions,

16 Marc?

17 MR. LaFRANCE: No questions. Thank you.

18 MS. WATSON: Jim?

19 MR. KAO: No questions.

20 MS. WATSON: Gene.

21 MR. MARGOLIS: Yes. Am I correct in

22 stating that you will be submitting changes to the

23 first-hour rating procedure, not that you wish that

EE-RM-94-230 COMMENT 0C
1 the first-hour rating procedure be eliminated?

2 DR. CHWALOWSKI: We do not wish that to 

3 eliminated. We think that customers should be

4 provided that additional information, in addition t

5 the energy factor.

6 What we will be providing is a significan

7 revision to the proposal.

8 MR. MARGOLIS: It still would be consider

9 a first-hour rating. The reason why I am saying th

10 is that the FTC labeling program for water heaters

11 uses the first hour rating.

12 DR. CHWALOWSKI: Yes. What you will see 

13 our equation as we provide them, it can still be

14 called a first-hour rating. Just like currently we

15 have a first-hour rating, even though in reality it

16 is not a first-hour rating.

17 Basically, the difference is that our tim

18 zero starts after T -25 degrees, so we are still

19 within that same 60-minute concept. We are just

20 doing things in reversed order.

21 MR. MARGOLIS: Thank you very much.

22 DR. CHWALOWSKI: Thank you.

23 MS. WATSON: Thank you.

EE-RM-94-230 COMMENT 0C
1 DR. CHWALOWSKI: Thank you.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

EE-RM-94-230 COMMENT 0C
1 MS. WATSON: Going to ranges, the next

'2 speaker, Charles Samuels.

3 CHARLES SAMUELS

4 AHAM

5 MR. SAMUELS: Thank you.

6 I'm Charles Samuels, and I'm government

7 relations counsel for the Association of Home

8 Appliance Manufacturers.

9 We appreciate the opportunity to testify

10 today. We particularly appreciate your accommodatin

11 us by organizing the testimony by products.

12 I'm going to make some brief comments abo

13 ranges and microwave oven test procedures now, and

14 then later I'll make somebrief comments about

15 clothes washer test procedures.

16 We believe that as compared with where yo

17 stood about a year ago or so when you proposed the

18 range and the microwave energy conservation

19 standards, that you have made great strides forward

20 in the range or microwave oven test procedures and

21 you're getting closer and closer to what we think is

22 a good representation of the energy consumption.

23 You're going to hear some technical

EE-RM-94-230 COMMENT 0C
1 comments about some changes that still need to be

2 made on ranges and microwaves.

3 Then you're going to hear some comments

4 that aren't really technical but are very important

5 and very substantive, which will show you that you

6 still are significantly overstating the annual energ

7 use of these products.

8 You still don't have an empirical basis f

9 the numbers that you're using in the proposed test

10 procedures. We are going to, again, provide you wit

11 some better data and analysis, and we urge you to

12 adopt it.

13 This is significant, not only because it

14 will mean that your test procedure will comply with

15 the legal requirements in NECA but also because it

16 will be very compelling evidence that the energy use

17 of ranges and microwave ovens is a lot less than you

18 have thought it is over the last few years, and it

19 undermines, really, the substantive and legal case

20 for energy standards, because you're simply not goin

21 to get the energy benefits that you thought you were

22 going to get in the Proposed Rule.

23 So this is important not only for test

EE-RM-94-230 COMMENT 0C
1 procedure purposes but also for the justification of

2 the pending proposed standards.

3 For example, if you take a take a look at 

4 comparison of range and microwave oven use to

5 television sets, you have just essentially withdrawn

6 your proposed product standards for television sets

7 yet, even using your own inflated numbers for

8 microwave oven and range use, your proposed

9 television standard rule would have saved

10 significantly more energy than what you believe

11 you're going to save in your proposed microwave oven

12 and range standard.

13 In terms of energy use, by your own prese

14 account, televisions use more energy than microwave

15 ovens.

16 So I think once you are able to relate in

17 the test procedure to what the actual range or

18 microwave oven use is more likely to be in the

19 United States, you're not only going to have a bette

20 test procedure, but you'll see significant diminutio

21 in the justification for standards.

22 That's basically what my comments are on

23 ranges and microwave ovens.

EE-RM-94-230 COMMENT 0C
1 Jack Weizeorick is going to testify on,

2 first, ranges, and then he'll be happy to take

3 questions on the range test procedure; then he'll

4 move into the microwave oven test procedure, and the

5 we'll have some further comment on microwave ovens,

6 as well.

7 Thank you.

8 MS. WATSON: Thank you.

9 MR. SAMUELS: Any questions?

10 MR. NABINGER: I don't have any questions

11 MR. DOUGHERTY: No questions.

12 MR. BERRINGER: No questions.

13 MS. WATSON: I have a comment.

14 MR. SAMUELS: Sure.

15 MS. WATSON: The numbers that were used 

16 the test procedure were based on metered studies

17 between 1988 and 1994?

18 MR. SAMUELS: You're talking about

19 microwave ovens?

20 MS. WATSON: For all of the products.

21 MR. SAMUELS: We're going to specifically

22 address that. We think there are --

23 MS. WATSON: That's just the comment that 

EE-RM-94-230 COMMENT 0C
1 wanted to make.

2 MR. SAMUELS: Sure. And I think there ar

3 serious flaws in the studies. We've pointed them o

4 before. You have adjusted, somewhat, but you haven

5 adjusted appropriately, and we're going to be very

6 specific about that in the next two testimonies.

7 MS. WATSON: Okay.

8 MR. MARGOLIS: That's my question.

9 Who is going to? In your lead in, you s

10 you were to do that, but then when you said who's

11 going to testify, I don't know who is going to be

12 presenting that.

13 MR. SAMUELS: I'm sorry you're confused.

14 Jack Weizeorick is going to talk about

15 ranges next and make some comments, also, about the

16 microwave oven test procedure. He's going to talk

17 about annual energy use for ranges, and then

18 Joy Daniel of Sharp Corporation, on behalf of AHAM,

19 is going to, as she did in the prior hearing, discus

20 annual energy use for microwave ovens.

21 MR. MARGOLIS: Thank you.

22

23

EE-RM-94-230 COMMENT 0C
1 JACK WEIZEORICK

2 AHAM

3 MR. WEIZEORICK: I have copies of my

4 statement and I will give them to you. I was going

5 to put them over at the desk, but I see nobody is

6 there.

7 Thank you very much. My name is Jack

8 Weizeorick. I'm Vice President of Engineer Service

9 for the Association of Home Appliance Manufacturers

10 The testimony that I'm about to give is

11 presented on behalf of AHAM's members that

12 manufacture gas and electric ranges and refers to th

13 DOE range test procedure, published in the Federal

14 Register on March 23rd, 1995, which was Docket No.

15 EE-RM-94-230.

16 The initial comments that I have, as Chuc

17 Samuels has said, addresses the annual useful cookin

18 energy output.

19 You will recall that on June 7th, 1994, 

20 Department held a hearing on proposed appliance

21 energy standards for ranges, in which AHAM commented

22 on this very subject.

23 Specifically, we stated that the

EE-RM-94-230 COMMENT 0C
1 demographics in the United States are changing and,

2 to the extent that there are many smaller families

3 that do less home cooking than in the past and, as 

4 result, the amount of energy used in today's

5 household for cooking purposes has been drastically

6 reduced.

7 AHAM advised -- well, it was supported b

8 both the Gas Research Institute and Arthur D. Littl

9 on research with regard to metered studies for

10 cooking energy. One of these studies noted was a

11 totally metered study and, to our knowledge, the on

12 viable and objective study that's available today.

13 Just so it's perfectly clear, this was n

14 an industry study. It was done by Northern Illinoi

15 Gas Company. The industry was not a part of it, bu

16 it supports that study. The way it was done it was

17 completely metered an independent study.

18 The values that came out of that study,

19 which are endorsed by AHAM, are different from what

20 the DOE has listed -- significantly different.

21 For instance, the gas cook top. That st

22 recommends 429.5 kiloBtu per year for the annual

23 useful cooking energy output instead of the DOE

EE-RM-94-230 COMMENT 0C
1 recommendation of 732.5 kiloBtus per year.

2 Gas ovens is 91.8 in the study, kiloBtu p

3 year, versus 124.2.

4 In the electric cook tops, the NIE gas

5 study was 157 kilowatt hours per year versus DOE's

6 recommendation of 209.4 kilowatt hours per year, and

7 for electric ovens, the NIE gas study was 26.6 versu

8 the 35.5.

9 These are significantly different values,

10 and we urge that.these values be adopted by DOE.

11 In fact, we believe that DOE owes industr

12 a response on why these values were not immediately

13 selected over the more subjective studies and survey

14 used to arrive at the values you presented.

15 While the annual energy usage remains the

16 single biggest disagreement between DOE and industry

17 there are other items of lesser concern that require

18 AHAM to comment.

19 Specifically, in paragraph 2.9.2, we agre

20 with you totally, in the elimination of the use of a

21 standard continuous flow calorimeter for gas cooking

22 products. The measurements should be left to the

23 discretion of the manufacturers and testing

EE-RM-94-230 COMMENT 0C
1 laboratories, as long as accuracy is maintained.

2 Referring to paragraph 2.9.3.5, you have

3 recommended a tolerance of plus or minus 0.45 degre

4 Fahrenheit for surface temperature measurement

5 measuring devices. We think that tolerance is too

6 tight.

7 Your previous test procedure had a plus 

8 minus 1 degree Fahrenheit tolerance over the range 

9 65 degrees to 90 degrees F., for surface temperatur

10 measuring devices.

11 We think that's the correct tolerance an

12 represents good laboratory practice. We would

13 recommend that you continue that.

14 In paragraph 4.1.2.3, that paragraph dea

15 with the number of self-cleaning cycles. DOE has

16 continued to use values that we consider extremely

17 high. 11 annual self-cleaning operations for

18 conventional electric ovens and 7 annual self19 cleaning operations for conventional gas ovens.

20 With the use of ranges declining, we thin

21 that that number is much too high. We would propose

22 based on some studies done by our members -- interna

23 studies these are -- that the number would be more 

EE-RM-94-230 COMMENT 0C
1 the order of 4 self-cleaning cycles per year for bo

2 gas and electric self-cleaning ovens.

3 In addition, we really don't see any rea

4 why there should be a difference between electric a

5 self-cleaning. They should be used approximately t

6 same number of times.

7 Paragraph 4.3 refers to combined compone

8 and states that the annual energy consumption and t

9 cooking efficiency can be summed.

10 We agree that the annual energy consumpt

11 can be summed but efficiencies cannot be summed. W

12 propose a minor wording change to take care of that

13 and it's in the testimony.

14 Paragraph 4.1.2.4 addresses annual clock

15 energy consumption and uses a symbol 8 k' to refer t

16 the number of hours in a year. 8k is normally used

17 for a heating value, and we think it causes confusi

18 to use it here. We suggest you change to another

19 symbol, just to avoid confusion.

20 In terms of the clock energy consumption

21 also, the clock energy consumption is added to the

22 oven energy consumption in the formulas. This

23 implies that the clock energy can be separated from

EE-RM-94-230 COMMENT 0C
1 the oven.

2 There are some ovens, such as electronic

3 ovens, that you cannot turn off the clock and measu

4 it separately. It's an integral part of the oven.

5 We would recommend that you change the

6 wording to indicate that it's not necessary to

7 disconnect the clock, if it's an integral part of t

8 system, because you get energy anyway when you

9 measure the oven, so it sort of makes it more

10 permissive than the way it presently stands.

11 Paragraph 3.1.1, second paragraph, has a

12 editorial error. There's a phrase that appears to 

13 missing: higher than room ambient, in about the thi

14 sentence. That phrase is used later on in the

15 paragraph correctly, and we'd suggest it be brought

16 up there, also, to correct that editorial problem.

17 In Section 3.2.1 and 3.3.5, we support t

18 Department proposal for convection mode testing,

19 because we believe it truly recognizes that

20 convection ovens are becoming a more prominent

21 cooking feature in U.S. homes.

22 Now, while AHAM firmly believes and

23 recommends the reduction of the annual energy

EE-RM-94-230 COMMENT 0C
1 consumption for electric cooktops to 157.0 kilowatt

2 hours per year, there is an inconsistency in the

3 publication of the number you have used.

4 In one case, in paragraph 4.2.2.1, you u

5 209.4 kilowatt hours per year as the annual useful

6 cooking energy output for conventional electric

7 cooktops, while in the Preamble to the test

8 procedures, Section 2.b(2), it's listed strictly as

9 209 kilowatt hours per year, so there's an

10 inconsistency there. It's a small number, but we

11 thought we'd point it out.

12 In a related issue, there's another area

13 that was brought out in our testimony presented to

14 the DOE on July 18th.

15 We think it's necessary to define a

16 separate product class for high capacity ranges and

17 ovens.

18 Without this action, these products

19 effectively would be banned if DOE elects to adopt

20 energy standards, notwithstanding AHAM's

21 recommendation to the contrary.

22 AHAM's testimony provided DOE with

23 definitions for high capacity gas ranges, cooktops,

EE-RM-94-230 COMMENT 0C
1 and ovens, and we would reiterate that we would like

2 to see those incorporated.

3 In conclusion, AHAM recommends that all 

4 the above changes be incorporated into the Appendix

5 and that DOE adopt AHAM's recommended annual useful

6 cooking energy output stated above and include thes

7 in the final test procedure.

8 We also urge DOE to review carefully AHAM

9 comments submitted on July 18th, 1994, regarding

10 proposed appliance energy conservation standards for

11 ranges, ovens, and cooktops.

12 These comments provide numerous data

13 indicating that ranges use so little energy that it

14 difficult to cost-justify any modification for the

15 purpose of saving energy -- for energy savings.

16 Finally, we believe that there should be 

17 energy standard issued for these products.

18 I will entertain any questions on ranges

19 that you may have.

20

21

22

23

EE-RM-94-230 COMMENT 0C
1 QUESTIONS AND ANSWERS

2 MS. WATSON: Steve, do you have any

3 questions?

4 MR. NABINGER: Yes. Yes, I do.

5 You said you think 11 and 7 for the cycl

6 for the ovens -- excuse me, for self-cleaning ovens 

7 - is too much, and that you believe 4 cycles; is th

8 correct?

9 MR. WEIZEORICK: Yes. We recommend a

10 number somewhere more on the order of 4. We think 

11 and 7 -- well, first, we don't see any reason why

12 they should be different, number one; and,

13 Number two: 11 and 7, with the decreasin

14 use of ranges, just seems too high.

15 I said that there are some internal

16 manufacturer studies. We haven't collected them, w

17 do not have that data, but I'm sure if you want it 

18 could try to pull it together.

19 MR. NABINGER: If you could provide it.

20 That was my question, really.

21 MR. WEIZEORICK: Okay. We don't have tha

22 information right at the moment. I will make an

23 effort to get it.

EE-RM-94-230 COMMENT 0C
1 MR. NABINGER: Thank you. I agree with 

2 that you can't sum efficiencies, so thank you for

3 that comment, and also for the symbols.

4 Do you have other definitions or symbols

5 that you find confusing, please let us know.

6 MR. WEIZEORICK: We came up with an "A".

7 We didn't have one.

8 MR. NABINGER: Okay. Now, could you

9 reiterate what your problem was or what that was on

10 your clock energy?

11 MR. NABINGER: Yeah. That's a little

12 confusing. I think if you look at the way you

13 calculate the energy consumption, you add in the

14 clock energy, and there is a section in there where

15 you actually measure the clock energy, separately, 

16 you come up with it and then you add it in.

17 In electronic oven, I guess you could

18 measure it if you turned everything else off and

19 measured it separately, but then when you ran the

20 oven, it's going to be running also, so you add it 

21 twice.

22 MR. NABINGER: Yes.

23 MR. WEIZEORICK: So the easiest way to d

EE-RM-94-230 COMMENT 0C
1 it is just somehow or other make it permissive that

2 you don't have to add it in if you haven't measured

3 it separately. Just make sure it's running.

4 MR. NABINGER: Okay. I understand.

5 The clock does not use much energy.

6 MR. WEIZEORICK: No.

7 MR. NABINGER: 2,4, 6, 8 watts. Compared

8 to the oven, it's almost insignificant.

9 MR. WEIZEORICK: Yes.

10 MR. NABINGER: But the time that the oven

11 is read is much less than what the clock is running

12 MR. WEIZEORICK: Then what the clock run

13 Yes.

14 MR. NABINGER: So do you have any proposa

15 to come up with a way to state the power, or

16 something like that, of the clock, and then take an

17 annual usage for the clock separately and add it to

18 the energy?

19 MR. WEIZEORICK: Maybe actually have to

20 back out the clock energy. I don't know. If you

21 can't turn it off, perhaps you measure it twice, and

22 it's included in your oven energy, and maybe at that

23 point, you back it out. You can measure it

EE-RM-94-230 COMMENT 0C
1 separately by turning everything else off, so it can

2 be done.

3 MR. NABINGER: All right. Thank you.

4 Thanks for pointing out the discrepancy 

5 the 209 kilowatt hours.

6 You say that DOE has been sent some

7 recommended definitions. I haven't seen those, but

8 they may be around. Can you send a copy to me?

9 MR. NABINGER: I will be glad to but they

10 are in the testimony -- the written AHAM testimony

11 presented on July 18th, 1994.

12 MR. NABINGER: All right. Thank you.

13 That's all the questions I have.

14 MS. WATSON: Questions?

15 MR. MARGOLIS: First, I would like to

16 comment that the questions I'm asking is for the

17 purpose of obtaining information and doesn't mean

18 whether we agree or disagree with some of your

19 statements here.

20 As another comment that I would like to

21 make, you're saying that NIGAS -- Northern Illinois

22 Gas Company -- study is not a manufacturer's study,

23 is an independent study, and would some way seem to

EE-RM-94-230 COMMENT 0C
1 me, if it was a manufacturer's study, there would b

2 some bias in it.

3 I'm just saying, as for me, I disagree w

4 the inference that you're making here. It doesn't

5 matter whether it's a manufacturer's study or a

6 utility study or what, the study stands on what it

7 shows and how it was done.

8 If it was a manufacturer's study, to me, 

9 carries the same weight and it's not biased at all.

10 I just wanted to make that comment.

11 MR. NABINGER: Thank you.

12 MR. MARGOLIS: Now, with regard to the

13 numbers that you are saying the useful cooking ener

14 output are, you give numbers that are considerably

15 different from the numbers that LBL has given from

16 their working a number of studies.

17 Now, my question is: Do you have the stu

18 itself that you could submit to us, so that we coul

19 see how the study was made and how it was done?

20 You're saying it's the only viable and

21 objective study that is available today. In your

22 written comments, can you tell us why that is true?

23 LBL in the Federal Register notice said

EE-RM-94-230 COMMENT 0C
1 that it obtained its data from a number of studies

2 that it looked at.

3 I would like to get information to show 

4 this study is better and should be used than the

5 other studies, or why shouldn't this study be added

6 to the other studies. And if the other studies hav

7 different values and then are averaged to obtain th

8 DOE value, that this study, then, should not be use

9 in conjunction with them and not by itself.

10 So, obviously, if it's used in conjuncti

11 it would raise the number that you have here. If

12 it's used by itself, these numbers would stand.

13 As Mr. Samuels so eloquently stated befo

14 using these numbers would show that no standard is

15 necessary. That's why the validity of NIGAS and th

16 other studies is very, very important.

17 MR. WEIZEORICK: Okay. I think I

18 understand the intent of what you're saying. In

19 effect, I believe we have provided DOE with the NIG

20 study. I will make sure that that is correct. I

21 believe it was part of our July 18th, 1994

22 testimony -- written comments, I should say.

23 MS. WATSON: The NIGAS was included and 

EE-RM-94-230 COMMENT 0C
1 used in conjunction with several --

2 MR. WEIZEORICK: Yes.

3 MR. MARGOLIS: Excuse me. Used in

4 conjunction with several --

5 MS. WATSON: Metered.

6 MR. MARGOLIS: -- LBLs to arrive at thes

7 numbers?

8 MS. WATSON: Yes.

9 MR. MARGOLIS: But you are saying that t

10 should be used by itself and not with the others, a

11 therefore, again, I ask you for reasons why your

12 statement that this is the only viable and objectiv

13 study that is available today. If you can give tha

14 to us, it's very important.

15 MR. WEIZEORICK: We will attempt to

16 elucidate on that point. I think that's enough sai

17 for now. In our final testimony, in our written

18 comments, we will add additional reasons for that

19 conclusion, much of which are already stated in our

20 previous testimony and previous comments submitted 

21 July 18th, but I will review them and make sure that

22 they become a part of this testimony also.

23 MR. MARGOLIS: From your point of view, 

EE-RM-94-230 COMMENT 0C
1 these comments, if the other study -- if you have

2 stated why the other studies are not good or should

3 not apply or have not stated that, if you can do it

4 at this time, because it's either way -- why this o

5 is good or why the others are no good.

6 MR. WEIZEORICK: Yes, we will do that.

7 MR. MARGOLIS: Again, I'm saying we're n

8 agreeing with you or disagreeing with you, but this

9 is to elicit information for us to base a conclusio

10 on.

11 MR. WEIZEORICK: I appreciate that. I

12 think it's good. It gives us some comfort that you

13 recognize also the very importance of this very bas

14 information.

15 MR. MARGOLIS: I'd like to speak for a

16 moment on the tolerance issue that you raised.

17 MR. WEIZEORICK: Okay.

18 MR. MARGOLIS: We are proposing .45 degr

19 Fahrenheit, as against what's there now of 1 degree

20 I am not familiar with this test procedur

21 as such, but in other products that your trade

22 association has an interest in, manufacturers have

23 stated to us that they believe the tolerances shoul

EE-RM-94-230 COMMENT 0C
1 be closed up because if they don't, if they are not

2 there are other manufacturers in testing that they

3 may game, as that word was used earlier, the

4 standard.

5 Here, we're trying to close up the

6 tolerance. I do not know that the purpose of closin

7 it up is that, but I would like, in your written

8 comments, if you could look at that, that this may

9 be -- and I'm not saying it is -- a loophole that

10 allows, quote, "other", unquote, manufacturers to g

11 higher efficiencies than they really deserve, becau

12 I know, with another product, that has been told to

13 me.

14 This is only one, so it might not be tha

15 but I'm not sure, and I would just like a discussion

16 on that issue.

17 Thank you very much. I have no other

18 questions.

19 MS. WATSON: Thank you.

20

21

22

23

EE-RM-94-230 COMMENT 0C
1 MS. WATSON: Onto microwave ovens with J

2 Weizeorick.

3 MR. WEIZEORICK: I'm still the same pers

4 I guess.

5 MICROWAVE OVENS

6 MR. WEIZEORICK: This testimony will

7 concern the AHAM's microwave oven council's positio

8 on the microwave oven test procedure. This will be

9 followed by testimony presented by Joe Daniels

10 concerning the annual energy consumption concerning

11 microwave ovens.

12 That testimony has been reviewed by AHAM

13 microwave oven council, and they agree with it

14 totally. So it's an AHAM position that Joy Daniels

15 will be presenting.

16 AHAM certainly applauds the DOE's efforts

17 to conceptually adopt the international standard fo

18 determining microwave oven power output.

19 However, we believe that there are some

20 problems in the process and it seems that certain

21 aspects of the international IEEC test method for

22 microwave ovens have been -- I use the word

23 "misinterpreted," and maybe it would be better to sa

EE-RM-94-230 COMMENT 0C
1 "misapplied".

2 We would urge, as a general rule, strict

3 adherence to the IEEC Standard 705, Amendment No. 2

4 Specifically, some of the things that are

5 at issue is, you propose to use a watt hour meter t

6 obtain the energy consumption in paragraph 3.2.3

7 because of start-up transients. The IEEC 705 method

8 addressed this in paragraph 12.6 when it said that

9 the filament heat-up time for magnetrons is not

10 included.

11 That's when these transients generally

12 occur, so by the time you get past that point, you'

13 not in a transient situation any longer, so a watt

14 meter certainly is adequate for power going in

15 instead of having to take watt hour meters over the

16 entire length of the test.

17 The change in the watt meter for the

18 duration of the test is very small, and we admit tha

19 there are ovens where the power will change somewhat

20 with usage, but the duration of this test is so shor

21 that that change does not come into play in this

22 instance.

23 So we would suaaest you stick with the TR

- - __ - __ - __ - - -  a - - - - - - ___ I- - ___ ____ ____

EE-RM-94-230 COMMENT 0C
i method using a watt meter instead of deviating from

2 that IEEC procedure.

3 The IEEC calculates efficiency in paragra

4 4.4.4, or I should say the DOE calculates efficiency

5 in 4.4.4, according to the IEEC method, but then

6 doesn't use it anywhere. Instead, you try to use

7 input energy versus outpoint energy to determine the

8 energy factor.

9 It makes it a little more difficult to ge

10 to, and frankly we do not support this change from

11 the IEEC procedure. We would prefer an efficiency

12 calculation using the ratio from output to input

13 power.

14 We think it probably is a small point, an

15 you come up with essentially the same answer. We

16 would urge the adoption of the 705 Standard to

17 promote consistency and standardization of testing

18 with the international community.

19 The method DOE uses to calculate the

20 microwave oven energy factor in paragraph 4.4.5 seem

21 confusing and convoluted. If the DOE test method

22 prevails, it should be modified to calculate the

23 microwave oven test power output in 4.4.2 first.

EE-RM-94-230 COMMENT 0C
1 You've got the number there, you might as well use

2 it.

3 The number can then be multiplied by time

4 T, which you don't even use, but it was used as an

5 output of the IEEC test procedure, determined in the

6 power output test and divided by the conversion

7 factor He to calculate the microwave oven test energ

8 which is then used to calculate the microwave oven

9 annual energy consumption.

10 This would be, if you read through that

11 carefully, a more understandable logic on how to

12 reach the values and the conclusions.

13 I've served as the Secretary of the IEEC

14 Microwave Oven Standard Subcommittee since 1970, and

15 during these past 25 years, I have participated in

16 the advances of the state of the art of microwave

17 oven measurement.

18 The U.S. has been the leader in the

19 development of this test method, which is used by th

20 microwave oven industry throughout the world. This

21 is one industry, at least, and one area in the

22 appliance industry where we have successfully applie

23 an international standard.

EE-RM-94-230 COMMENT 0C
1 The IEEC standard represents the state of

2 the art as it exists today throughout the world.

3 However, DOE must be aware that the IEEC standard i

4 a living document.

5 It will continually undergo changes and

6 modifications as the state of the art for analyzing

7 and evaluating these products advances. These are

8 relatively new products. They've only been around

9 for 30 or 40 years.

10 Even now, I can advise you that as a resu

11 of a recent meeting of the IEEC Standards Group in

12 Zurich, Switzerland, held last April. There are som

13 changes being processed through the International

14 Standards Systems to this test method. These change

15 will appear in final form, probably in the next two

16 or three years.

17 While they are not radical changes and th

18 don't substantially alter the test method, they will

19 make the test easier to conduct and are expected to

20 improve the repeatability.

21 Manufacturers throughout the world will b

22 gaining experience with these new changes over the

23 next several years, so that when they are finally

EE-RM-94-230 COMMENT 0C
1 published in final form, there will be test methods

2 that have been tried and are expected.

3 Therefore, it's important that DOE keep

4 abreast of the activities of this International

5 Standards Group and propose changes to the DOE

6 microwave oven test procedure to keep it consistent

7 with these advances.

8 In addition, AHAM also would like to rev

9 AHAM's final comments on DOE's Notice of Proposed

10 Rulemaking on Energy Consumption Standards for

11 Microwave Ovens.

12 These comments recommended the adoption 

13 a number of different classes of microwave ovens.

14 I've listed five there in the testimony, which are

15 the five that we recommended.

16 The adoption of these classes is absolut

17 necessary in order to prevent products with proven

18 utility from being banned from the marketplace if D

19 elects to adopt energy standards, notwithstanding

20 AHAM's recommendation to the contrary.

21 This matter is intrinsically related to 

22 DOE test procedure for microwave ovens because the 

23 percent efficiency used by DOE to calculate the

EE-RM-94-230 COMMENT 0C
1 annual useful cooking energy reflects an average

2 efficiency of all of these classes.

3 So, therefore, you need to go back and t

4 a look at each class individually and the data

5 assigned to that class if energy consumption

6 standards are to be established.

7 We make this recommendation while we

8 continue to support the position that energy

9 standards for these products are not necessary

10 because microwave ovens consume a relatively small

11 amount of energy and that it's difficult, if not

12 possible, to cost justify any energy standard for

13 these products.

14 Thank you, and I'll entertain any comment

15 MS. WATSON: Thank you.

16 QUESTIONS AND ANSWERS

17 MS. WATSON: Steve, do you have any

18 questions or comments?

19 MR. NABINGER: Yes, I do have a couple

20 questions and comments.

21 One is, that it talks about strict

22 adherence to the IEC 705, but the 705, at times, is

23 unclear. For example, power measurements. When do

EE-RM-94-230 COMMENT 0C
1 you measure the power? It says: When the current i

2 reached, 90 percent of its minimum at the maximum h

3 been reached.

4 Then, through some tests, we've seen in

5 particularly microwave ovens, that the power can

6 change as much as 3.5 and 5 percent. Now if you

7 would use the higher number for power as the input

8 power or the lower, you!re going to have a big

9 difference in efficiency. I say "big," I mean your

10 efficiency will vary from test to test, depending. o

11 what you use as much as plus or minus 5 percent,

12 especially if you have a power meter that only has 

13 5 percent accuracy rating, which today you can easi

14 get 1 percent meters and they are relatively

15 inexpensive.

16 MR. WEIZEORICK: Well, my comment is -- 

17 I have a question. You say you're seeing 3-1/2 to 

18 percent change in power input?

19 MR. NABINGER: Into the microwave.

20 MR. WEIZEORICK: Power input to the

21 microwave. During the duration of the test?

22 MR. NABINGER: During the duration of the

23 test. ves. - -- -I z -- -

EE-RM-94-230 COMMENT 0C
1 MR. WEIZEORICK: I think that's extremely

2 high. Look at your voltage variation.

3 MR. NABINGER: The voltage is specified a

4 needs to be 120, plus or minus 1 volt.

5 MR. WEIZEORICK: Yes. I'd look and see 

6 you don't have -- if you have regulated voltage to

7 the point where you're maintaining that voltage

8 throughout the test, because we don't -- over the 6

9 second duration of the test, we have no reports of

10 anything close to that kind of a change, at this

11 point in time.

12 We'll look at it again, as well, but our

13 indications are that a power reading taken midway

14 through the test is as good a reading as you're goin

15 to get anywhere.

16 Now, I'd really like to visit your lab an

17 witness some of these tests. It would be helpful fo

18 me to see how you're doing it, because our indicatio

19 is that certainly the power reading is very

20 consistent throughout the test, and if you take a

21 reading midway through the test, it's as good a

22 reading as you can possibly get.

23 It's a lot easier to do than having to

EE-RM-94-230 COMMENT 0C
1 record the watt hour reading at the start of the te

2 and the watt hour reading at the finish of the test

3 particularly if it's a moving target, because you

4 have to eliminate the filament heat-up time, which 

5 the first couple of seconds that you turn the oven

6 on.

7 You have to make sure that you cut it of

8 at the right point.

9 MR. NABINGER: Thank you.

10 About the filament heat-up time, how lon

11 is that time? It seems to measure between .5 to as

12 much as 2 seconds, at times.

13 MR. WEIZEORICK: It can go as long as th

14 seconds in some ovens, yeah.

15 MR. NABINGER: That's about 4 percent of

16 the time, and yet my comment would be, if that's 4

17 percent of the time, I'm not sure how much that

18 affects the energy consumption, if you use power to

19 calculate efficiency, what the difference would be?

20 Do you have numbers on it?

21 MR. WEIZEORICK: No, I don't. I don't ha

22 any.numbers on that.

23 MR. NABINGER: All right.

EE-RM-94-230 COMMENT 0C
1 Am I correct in saying that your point in

2 having the different classes of microwaves is that 

3 or is your point that you need to have the different

4 classes?

5 MR. WEIZEORICK: Oh, yes.

6 MR. NABINGER: And in each class, there

7 should be a different energy consumption factor?

8 MR. WEIZEORICK: Yes. If you're going to

9 have energy standards, you need different standards

10 for each class, and I guess the relationship there 

11 that you took -- we provided data for each of these

12 product classes, and that data was lumped together,

13 and you come up with the 54 percent efficiency.

14 The 54 percent efficiency was then used t

15 calculate the annual energy use.

16 That annual energy use is now being appli

17 to all classes of products. Now, I'm not sure that

18 accurate. I just question it.

19 MR. NABINGER: I understand. Thank you.

20 I have no further questions.

21 MS. WATSON: I have a question.

22 You had stated that you did not support

23 this change from the IEC in respect to the energy

EE-RM-94-230 COMMENT 0C
1 fact, whereas the energy factor -- we are deviating

2 from the IEC, we are simply stating, to use the wat

3 hour meter, do the IEC, but what is the energy fact

4 from using the watt hour meter?

5 I did not have that intent to merge the

6 two, it was just an additional step.

7 MR. WEIZEORICK: Yes. It seemed to us t

8 there was a force fit to force the energy factor

9 calculation into an energy calculation when it's mu

10 easier to do it on a power basis.

11 Power output over power input gives you

12 efficiency.

13 Energy input over energy output gives you

14 efficiency -- both of them are energy factors, and

15 both come up with the same number. It just seemed

16 like there was a force fit to move it over to energy

17 when power seemed to fall out very nicely.

18 It won't change the number. If the test 

19 done accurately and correctly, the energy factor

20 should be the same.

21 MS. WATSON: I had another comment.

22 I don't understand your opposition to not

23 using a watt hour meter, in addition with using a

EE-RM-94-230 COMMENT 0C
watt meter also.

MR. WEIZEORICK: Well, the watt meter gi

you the instantaneous power, obviously, and all we'

saying is that a watt hour meter you've got to reco

the whole time, and you're getting into an energy

situation. It's an energy situation versus a power

situation.

Advertising microwave ovens is done on t

basis of power output of the microwave ovens so we

concentrate on power.

MS. WATSON: In our test procedure, we h

to concentrate on energy.

MR. WEIZEORICK: But, see, you make the

conversion later on.

MS. WATSON: Yes, you can.

MR. WEIZEORICK: It doesn't matter where

you make the conversion. You make it very early.

We're just suggesting we'd like to see it made late

MS. WATSON: Okay. Thank you.

MR. MARGOLIS: I just want to reiterate

Ms. Watson's comment.

You had said we do not support this chang

from the IEC procedure which determines efficiency b

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EE-RM-94-230 COMMENT 0C
1 calculating the ratio of output to input power. As

2 she had said, we are not changing it. We are just

3 adding another measure. So we are not changing the

4 IEC procedure, and that's what I wish to point out 

5 you.

6 My other comment is that DOE is keeping

7 abreast of the activities of the group that's meeti

8 or that met in Zurich. We will, once we get these

9 test procedures in place, if modification to these

10 are made by the trade, we will then consider if the

11 are pertinent enough or important enough to amend t

12 test procedures because we do have the guiding post

13 that we should use -- manufacturers or trade

14 association standards or test procedures, to the be

15 of our ability. And that's what we are trying to d

16 So if these, which are the IEC test

17 procedures, are then put in place and further

18 amendments occur, we will, of course, if they are

19 pertinent go out with amendments to the then current

20 test procedure to add them.

21 MR. WEIZEORICK: In response to that, I

22 would just like to make further comment that my

23 testimony said I was the Secretary of the IEC

EE-RM-94-230 COMMENT 0C
1 Subcommittee on Standards for the past 25 years. I

2 am the only Secretary of that Committee. That

3 Committee was formed when I was appointed. I am we

4 aware of what goes on there.

5 That is the U.S. industry procedure. We 

6 not have another procedure. We elected, back in

7 1970, not to write our own procedure but to use the

8 international standard and to put our efforts into

9 make that standard the best standard in the world,

10 and that's the way we've done it.

11 MR. MARGOLIS: And this amendment is to 

12 those standards in place.

13 MR. WEIZEORICK: Yes.

14 MS. WATSON: Steve.

15 MR. NABINGER: Yes. I had a question ab

16 the IEC. You made a statement that the state of ar

17 is continually changing and the IEC wants to keep up

18 with the state of the art.

19 It's known now that induction type

20 meters -- that we have new meters and are more state

21 of the art than induction type. I mean, meters are

22 meters. You have a 1 percent accuracy, then that

23 stands as it is. It doesn't matter what the meter

EE-RM-94-230 COMMENT 0C
is.

It says you must use an induction type

meter in the IEC standard, and it also comments that

it should be 5 percent accuracy. Is there any work

going on to look into changing that to a tighter --

MR. WEIZEORICK: No. I think I've stated

that there are some changes coming, and I think

you'll see it in that area.

MR. NABINGER: Okay. Thank you.

One other question just for my own

information. It talks about potable water now.

Distilled water is potable water, and I don't know

that that's what each lab uses, and I don't know how

much potable water varies.

I talked to a chemist and he said that th

mineral content of potable water considers

significantly across the United States, and he

thought that there might be some factor involved

there with a different mineral content.

If one sample of water were used in some

place where the mineral content was high and someone

else used distilled water, the outcome could be

skewed and get different results.

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EE-RM-94-230 COMMENT 0C
1 Has anybody ever looked into that?

2 MR. NABINGER: Yes. Years ago the IEC ha

3 used distilled water with salt in it, a certain

4 measure of salt, in order to try to standardize the

5 water. We ran into more problems with salt than we

6 ever ran into with using plain potable water, tap

7 water and, for that reason, we elected on a worldwid

8 basis to go to potable water.

9 We couldn't find significant differences 

10 power output measures as a result of differences in

11 mineral content.

12 We did find considerable differences in 

13 use of salt, although I think -- and that was at 24

14 megahertz frequencies.

15 If you go to the 915 megahertz, you've go

16 a totally different system and, fortunately, that

17 system really isn't used very much in household

18 microwave ovens today. It was back in the '70s, but

19 it is not anymore.

20 So all microwave ovens today are 2450

21 megahertz, and the water quality difference does not

22 seem to affect the output.

23 MR. NABINGER: Are all microwaves rated a

EE-RM-94-230 COMMENT 0C
1 120 volts? In other words, the IEC standard says t

2 test it at the rate voltage, whereas DOE's proposed

3 rule states 120 volts on occasion.

4 MR. WEIZEORICK: Obviously, you have

5 different ratings, and most of them are 230 volts,

6 because they use a 230 volt, 50 hertz system.

7 All microwave ovens -- I shouldn't say a

8 we've got some combination ovens that might be at

9 240.

10 MR. NABINGER: So would the numbers be

11 recorded or would you use the 115 volts with the 24

12 MR. WEIZEORICK: I'm going to have to ch

13 on that. I don't know if the microwave portion of 

14 combination oven operates at 230 or not. That would

15 require a different magnetron, and I suspect it may

16 be still operating at the 120 system, but I'll have

17 to check on that. It's a good question.

18 MS. WATSON: Thank you.

19 I'd like to call the next speaker.

20 State your name and who you represent,

21 please.

22

23

EE-RM-94-230 COMMENT 0C
1 JOY WEIS DANIEL

2 AHAM

3 MS. DANIELS: I'm Joy Weis Daniel, the

4 product development manager of the appliance divisio

5 of Sharp Electronics Corporation, which is located 

6 Mahwah, New Jersey..

7 Currently, Sharp is the No. 1 seller of

8 home use microwave ovens, however, today I am here o

9 behalf of AHAM and the microwave oven industry.

10 In the March 23, 1993 DOE CFR Part 430,

11 there was a quote that I would like to read:

12 "DOE is proposing to change the annual

13 useful cooking energy from 34.2 kilowatt hours per

14 year to 77.3 kilowatt hours per year. This revision

15 to the annual useful cooking earning reflects curren

16 U.S. microwave oven cooking usage," end of quote.

17 This figure translates to input of 143.2

18 kilowatt hours per year for a microwave oven. Now,

19 we choose to believe that this revision, down from

20 your previously suggested 270 kilowatt hours to 143.

21 kilowatt hours, is the result of the additional

22 studies you were able to procure, as well as our

23 testimony on behalf of the microwave industry during

EE-RM-94-230 COMMENT 0C
1 last year's proceedings.

2 However, we again have carefully reviewed

3 the latest findings and believe that there is ample

4 evidence to encourage you to rethink your conclusio

5 The following remarks will address four

6 areas.

7 Conditional demand analysis;

8 Metered studies and their relationship t

9 accepted energy consumption percentages for microwa

10 ovens.

11 First: Conditional demand analysis,

12 otherwise known as CDA, is an application of linear

13 regression analysis which uses as variables the

14 customer's total annual use of electricity and othe

15 variables characteristic of specific customers.

16 CDA end use consumption can be estimated

17 from survey and billing data.

18 It sounds good, but is it? One would

19 certainly suspect the validity of such a method for

20 microwave ovens when one reads in the literature som

21 of the quotes. In my written comments, there are 8

22 quotes, I will just choose three.

23 The CDA methodology can give seriously

EE-RM-94-230 COMMENT 0C
1 biased estimates of appliance end-use electricity

2 consumption if the assumptions of the underlying

3 regression model are not fully satisfied.

4 The widest range of unit energy consumpt

5 values in almost every end use comes from condition

6 demand studies where estimates frequently vary by a

7 much of a factor of 5 or 10 within the same end use

8 Finally, the last quote:

9 CDA appears to produce significantly

10 different mean estimates more frequently than other

11 methods. Perhaps due to the sensitivity of CDA

12 results to the specification of the underlying

13 regression model in variables.

14 Let's take a look now at some studies of

15 the conditional demand analysis so that you can be

16 very clear about why I'm concerned about them. The

17 studies are listed in the bibliography. There are 

18 citations, there are some here, but let's take a

19 look.

20 The Sierra Pacific Power, has a kilowatt

21 hour recommendation of 203, with a standard deviatio

22 of 182.

23 Or thev used. in that same studv. a randn

- _ . --- r - __ -- - - - - -. r - -- 

EE-RM-94-230 COMMENT 0C
1 coefficient regression in which the final is 284 wi

2 a standard deviation of 142. That's pretty, pretty

3 wide standard deviation.

4 Or look at the range on residential end 

5 consumption done in 1989. A range of 162 to 687 or

6 in the utility estimate study, a range of 96 to 980

7 That's a terribly wide range.

8 If you looked at all of these, you would

9 get an average conditional demand of 256. Just kin

10 of tuck that into your memory for a few minutes.

11 Now let's take a look at another subject

12 that's the end-use metering. As I told you last

13 year, I believe that that is the only true way of

14 determining actual microwave oven usage because it 

15 the way that you determine what is actually cooked

16 with the microwave oven.

17 Yes, I am aware that end-use studies done

18 by metering are costly and are usually only complete

19 with a small sample of consumers. Last year, you ma

20 recall, I was only able to uncover one of them.

21 However, I still believe, as upheld by the

22 literature, that this is the best way.

23 There are six quotes in my report, I will

EE-RM-94-230 COMMENT 0C
1 only mention three.

2 One: With careful sampling,

3 instrumentation, quality control, and data analysis,

4 the direct metering approach can give unbiased

5 estimates of the average end-use consumption of the

6 target appliances.

7 Two: These findings confirm the importan

8 of direct metering of end-use electricity

9 consumption; and,

10 Three: These results confirm the importan

11 of EIP's direct metering approach for collecting

12 unbiased and reliable end-use energy consumption.

13 Let's take look now at what the literatur

14 shows us about end-use metering studies.

15 The first one was the first one that I

16 mentioned last year, the Sierra Pacific study of 77

17 kilowatt hours.

18 We would, in addition, be able to find al

19 the rest of these, including the three that were

20 reported in the LBL's baseline data.

21 Notice what happens when you segregate th

22 end-use metering studies.

23 Now, this is certainly a wider universe,

EE-RM-94-230 COMMENT 0C
1 and yet the range on this universe is as low as 68 

2 a high of 114.

3 A pretty narrow range when you consider 

4 range that we just talked about under the condition

5 demand analysis.

6 If you take all of these together, you g

7 an averaged metered study of 91.4. That certainly

8 seems to me to be far more accurate than what we ha

9 talked about earlier.

10 The third area which I believe you need 

11 revisit is the study of baseline data for the

12 residential sector and development of a residential

13 forecasting database, which was completed in May 19

14 and is supported by the assistant secretary for

15 energy efficiency and renewable energy.

16 Now, I was really excited to have this s

17 to me by Jack Weizeorick, because my assumption,

18 before I read it and maybe even as I started to read

19 it, that this work should be totally accurate.

20 Well, let's take a look at some of the

21 conclusions: On page 111 of the study, we read the

22 following:

23 Quote. "The UECs for cookina in the - I --- - -- I - -- - -- -

EE-RM-94-230 COMMENT 0C
1 residential forecasting data base are 130 kilowatt

2 hours per year for microwave ovens."

3 Well, that was pretty good, but can you

4 tell me why the DOE didn't use the 130 kilowatt hou

5 figure from the study, which you supported, rather

6 than the 143.2, which is listed in the Federal

7 Register?

8 The total for cooking in a home where

9 electricity is used for cooking would be 945 kilowa

10 hours for all the cooking.

11 The study relates that cooking accounts 

12 about 7 percent of residential electricity

13 consumption. Well, that sounded okay, but let's ta

14 that a little further.

15 Given these conclusions that 945 would

16 represent 7 percent of the residential electricity

17 consumption, it would be determined that the averag

18 household where electricity was used for cooking,

19 would have an annual electricity consumption of

20 13,500.

21 Well, is this correct? A search of all o

22 the studies found the following estimated residentia

23 electric consumption. One was 9383, all the way up

EE-RM-94-230 COMMENT 0C
1 to 10,967, which gives an average consumption of

2 10,200.

3 Now, obviously, LBL's estimate is 32

4 percent more than that. I guess my question is, how

5 can you accept assumptions, based on something that

6 can't be justified when you look into the literatur

7 Now, if you use LBL's assumption of the 

8 percent power and the microwave energy usage, and y

9 use the 10,200, then that would reduce LBL's 130

10 kilowatt hours per year to 111 kilowatt hours year,

11 and I would like to use that 111, which you will se

12 The 7 percent electricity used for cookin

13 that LBL uses, certainly disagrees with your very ow

14 household energy consumption and expenditures, which

15 I showed you last year, that says there is .7 percen

16 for a microwave oven and 3.8 for the ranges in the

17 oven, which would give you a total of 4.5 percent.

18 Now, in that 4.5 percent -- I realize thi

19 figure is from 1987; we heard Jack say there's less

20 use, probably, of ranges and ovens and perhaps

21 slightly more use for a microwave oven, but even

22 given the fact that this might change within the.4.5

23 percent, even if this went up to 1 percent of the

EE-RM-94-230 COMMENT 0C
1 microwave oven, that's only 100 kilowatt hours per

2 year.

3 I can find no evidence to show that ther

4 has been an increase in cooking, which would

5 translate into an increase in electric consumption,

6 to go somewhere between 4-1/2 and 7. I don't know

7 how to do that.

8 I can find myriads of studies that show

9 there is a decline in cooking because there are mor

10 women working, because there are busier households,

11 and certainly because of the wider availability of

12 prepared foods, which simply need to be reheated.

13 Now, the amount of electricity used by

14 microwave ovens is so small that certainly it seems

15 to microwave industry that it doesn't want, nor wou

16 it be cost-beneficial to have an energy standard fo

17 microwave ovens.

18 In summary, then, what is it that we, th

19 microwave oven industry want?

20 Well, one, we would like you not to use

21 conditional demand analysis for determining microwa

22 oven usage until the underlying assumptions used in

23 their regression analysis, are realistic. LBL did

EE-RM-94-230 COMMENT 0C
1 use them in their study.

2 No. 2: We really encourage and want you 

3 use the end-use metering studies, particularly since

4 their number of studies available has increased and

5 the results are very, very similar.

6 No. 3: We would ask you to reevaluate the

7 \LBL baseline study more carefully so that all of the

8 assumptions are logical and are confirmed with other

9 known data sources.

10 And, finally: We would ask that you accep

11 AHAM's original figure that 100 kilowatt hours per

12 year be used for microwave ovens. Please recall tha

13 the end-use metered studies average 91.4 kilowatt

14 hours.

15 Please recall that even if we said that 

16 percent of the energy that's used by the microwave

17 oven, that's around 100.2 kilowatt hours per year,

18 and if we used the 111 kilowatt hours based on a

19 reasonable total household usage, rather than the

20 130, which was based on extremely high household

21 usage from the LBL study, then the averaging would b

22 101.2 kilowatt hours per year.

23 We appreciate the opportunity to discuss

EE-RM-94-230 COMMENT 0C
1 our concerns and hopefully your willingness to revie

2 and revise the figure of 143.2 kilowatt hours per

3 year, to the 100 kilowatt hours per year for

4 microwave ovens.

5 Finally, to paraphrase Marcia Clark: The

6 microwave oven industry rests.

7 Thank you.

8 MS. WATSON: Steve, do you have any

9 questions?

10 MR. NABINGER: I have no questions.

11 Brian.

12 Bryan.

13 MS. WATSON: I have a comment.

14 QUESTIONS AND ANSWERS

15 MS. WATSON: What conditional demand

16 analysis are you referring to the LBL use?

17 MS. DANIEL: They mentioned in this study

18 and you'll see it listed in here, they had several

19 studies that they included in their analysis of the

20 130.

21 If you look in the Appendix, it reiterate

22 each one of them.

23 MS. WATSON: Do you have any of the

EE-RM-94-230 COMMENT 0C
1 reports?

2 MS. DANIEL: Yes, the one that you

3 provided, the LBL. The full study reiterates them.

4 I can give you page and number. I don't have it wi

5 me right now, but that's where I got it.

6 MS. WATSON: Okay. I also have a

7 discrepancy with your average. The three reporting

8 and baseline.

9 MS. DANIEL: Yes. You'll find that in th

10 study.

11 MS. WATSON: Well, the 1990 -- the first

12 three were three that I thought were included.

13 MS. DANIEL: No. These three, the 1994,

14 are three reported in the baseline figure, and they

15 use '96 as their figure. That's in the LBL study,

16 the published study.

17 MS. WATSON: The published. Okay.

18 MS. DANIEL: It's in the published study

19 It's, I think, three different ones.

20 MS. WATSON: I understand what you're

21 saying now.

22 MS. DANIEL: It's in a chart where they d

23 conditional demand analysis in one column; the

EE-RM-94-230 COMMENT 0C
1 engineering report, which there are none, for

2 microwave ovens, there's an end-use metering study,

3 and a utilities efficiency study, which I did not

4 address.

5 MS. WATSON: In the Federal Register, we

6 noted that we used the first three studies that

7 you've noted here. I just wanted to make sure that

8 you understood that.

9 MS. DANIEL: Right. But you came up with

10 143.2, and considering that LBL had used conditiona

11 demand analysis, I request that you take those

12 figures out.

13 MS. WATSON: Okay.

14 MR. MARGOLIS: I was wondering if you cou

15 explain paragraph 2 on page 1, where you say that D

16 is proposing to change the annual useful cooking

17 energy from 34.2 to 77.3 kilowatt hours per year.

18 What number are you saying that it should

19 be?

20 MS. DANIEL: The 143.2 is the 77.3 with t

21 54 percent efficiency; it's the same number. In

22 there, you're talking about annual useful cooking

23 energy, and I was referring to the input to the

EE-RM-94-230 COMMENT 0C
1 microwave oven, which you have used the 54 percent

2 efficiency.

3 MR. MARGOLIS: I see. That's all.

4 MS. WATSON: Thank you.

5 Will someone be speaking for Dennis Wilso

6 today?

7 MR. WEIZEORICK: I incorporated his

8 testimony with mine.

9 MS. WATSON: Okay. We'll do one more

10 speaker for clothes washer.

11 Chuck Samuels, will you be speaking for

12 clothes washers?

13 MR. SAMUELS: Sure.

14 MS. WATSON: Okay.

15 MR. SAMUELS: What is your intention, to 

16 a lunch break after I speak or to continue?

17 MS. WATSON: Approximately how long will

18 Curt Riechman's presentation be?

19 MR. RIECHMAN: About 10 minutes.

20 MR. SAMUELS: 10 minutes.

21 MS. WATSON: 10 minutes. WE'd like to

22 include you in and then break for lunch.

23 MR. STILWELL: It is in a different order

EE-RM-94-230 COMMENT 0C
1 I think I was going to be first. I had 30 minutes

2 allowed.

3 MS. WATSON: Your name is?

4 MR. SAMUELS: Dick Stilwell.

5 MR. MARGOLIS: Excuse me. How long do yo

6 think this clothes washer presentation will be?

7 MR. SAMUELS: I believe we could complete

8 this all within an hour, and although obviously we'

9 in your hands, we would prefer just to proceed. We

10 think we could wrap this up.

11 MS. WATSON: Okay. That's fine, then.

12 We can take a five-minute break.

13 [Recess]

14

15

16

17

18

19

20

21

22

23

EE-RM-94-230 COMMENT 0C
1 MS. WATSON: Can we please start the

2 hearing. We are going to reconvene.

3 I would like to ask, if there are any

4 unscheduled speakers to please go to the registrati

5 desk and you'll see a blank card. Fill out your na

6 and the company that your represent.

7 I would like to reconvene with clothes

8 washers with Charles Samuels.

9 MR. SAMUELS: Thank you very much.

10 CLOTHES WASHERS

11 CHARLES SAMUELS

12 MR. SAMUELS: I just wanted to make two 

13 three comments.

14 The first thing is that the revision of 

15 clothes washer test procedure is a complicated

16 situation because we have several factors in play.

17 We have an ongoing rulemaking, we have th

18 fact that technology is changing, and we have the

19 fact that we want to make some changes on an interim

20 basis and then make some changes on a longer-term

21 basis.

22 The interaction between all of these

23 elements is very complicated, and we compliment DOE

EE-RM-94-230 COMMENT 0C
1 on the way that you are attempting to juggle this.

2 Marc LaFrance, in particular, is doing an excellent

3 job in trying to understand the substantive issues

4 and try and deal with questions of process and

5 timing.

6 The second point I want to make is that w

7 will be presenting testimony today on behalf of AHAM

8 with respect to interim and sort of long-term or

9 final or full test procedures.

10 AHAM has no position, however, on the

11 energy conservation standards that might be proposed

12 It's important that the two not be

13 confused. So, therefore, although the industry as a

14 whole is supporting methods to measure RMC, AHAM is

15 not taking any position on whether RMC should be

16 included, ultimately, in standards, whether or not

17 it's legally justified or justified as a matter of

18 policy. I just want to make that distinction.

19 The other thing I want to say, our

20 testimony today, as I mentioned, will be on both the

21 interim and the final or full test procedure. We

22 recognize and support that the interim test

23 procedure, as you have proposed, with whatever

EE-RM-94-230 COMMENT 0C
1 revisions we might recommend, should go into effect

2 fairly quickly, and that the final or full test

3 procedure should not go into effect until the

4 effective date of a new standard.

5 However, we think that it's very

6 important -- and I think that you agree with this -

7 any proposal for a full revision to the test

8 procedure be dealt with by DOE now, in the process 

9 this rule making, so that the materials we have

10 previously supplied to you and that we're, in effect

11 supplying to you in this hearing as a proposal for 

12 final test procedure, should be publicly

13 disseminated, how ever you feel appropriate now.

14 Comments on it should be made on it in th

15 course of this proceeding, even if that means that

16 you feel it might be useful to publish some

17 additional material in the Federal Register and

18 perhaps extend the comment period. We leave that up

19 to you.

20 But, in any case, what you want to do is 

21 integrate the test procedure rulemaking so that

22 industry and all other interested parties, and there

23 are other interested parties, will know as soon as

EE-RM-94-230 COMMENT 0C
1 possible what you think the final test procedure wil

2 be that will apply to products that are manufactured

3 under new standards with as much lead time notice

4 about that as possible and, of course, that that te

5 procedure will be available for people to use when

6 they make their comments on what energy standards f

7 these products should be.

8 So those are just the preliminary points 

9 wanted to make before our technical people make thei

10 comments. Does anyone have any questions or comment

11 about that?

12 MR. LaFRANCE: Not at this point. Thank

13 you for your remarks we'll talk more from the

14 technical issues when Jack comes up and all the

15 others. Thanks.

16 DICK STILWELL

17 MR. STILWELL: My name is Dick Stilwell. 

18 am director of design and material evaluation at

19 Maytag and research and development, and also

20 chairman of AHAM Laundry Task Force Group.

21 Since we have already submitted the

22 completed test procedure to DOE, I'm going to confin

23 my remarks today to some of the background and hit

EE-RM-94-230 COMMENT 0C
1 some of the high spots and the highlights of the

2 major changes in the test procedure.

3 Obviously, to go into this test procedure

4 in detail at this time would take a better part of 

5 day, maybe more than a day, so we'll hit the high

6 spots.

7 This started back in February of '93.

8 There was a meeting held at NIST with all of the

9 major U.S. manufacturers and other stakeholders. I

10 think of the detergent manufacturers were present a

11 suppliers to the appliance industry were present.

12 This meeting was prompted, basically, by

13 two factors. One was the fact that DOE had

14 recognized the need for an update. The test

15 procedure that we were using was developed over 20

16 years ago and there have been a lot of changes in

17 consumer habits and practices since that period of

18 time.

19 The other reason was that there was a nee

20 expressed by, I believe it was Steve Nadel of ACEEE

21 for formulas that could be used for the utility

22 industry in determining rebates and that would

23 include, of course, water consumption.

EE-RM-94-230 COMMENT 0C
1 One of the other factors I think that he

2 was interested in was improved extractions, some way

3 of factoring that in, a test procedure for that.

4 As a result of that meeting, basically, a

5 task force was organized that included all major U.S

6 manufacturers, plus Asko and Miele.

7 The goals of the task force, which weren

8 all developed right away but some goals were added a

9 developments dictated, obviously was to update

10 temperature use factors with the latest consumer

11 data.

12 As I indicated earlier, there have been a

13 lot of changes over 20 years, and the changes

14 basically were away from the use of hot water, towar

15 the use of cold water, and so that the old test

16 procedure really significantly overstated the energy

17 consumption of washing machines.

18 There were a couple of other reasons that

19 it overstated it. I think one was an error in one o

20 the calculations and another reason was the fact tha

21 hot water assumption was higher than actual hot wate

22 usage is today.

23 One of our other aoals was to clarify

EE-RM-94-230 COMMENT 0C
1 language and errors that were subject to

2 interpretation, and we were also trying to make the

3 test procedure more friendly toward any new energy

4 saving technologies.

5 I think looking down the road we could se

6 the potential for a succession of petitions for

7 waiver of test procedure, for electronic controls or

8 new energy saving technologies that might emerge tha

9 weren't adequately handled by the test procedure.

10 One of our other goals was to tie the

11 washing and drying process together through the use

12 of remaining moisture content. Obviously, extractio

13 is a major factor in overall energy consumption, and

14 we developed a test procedure and then it ties these

15 two things together.

16 Our last goal was to simplify the test

17 procedure and, frankly, we failed badly on that one.

18 It's gotten more complicated than simpler.

19 I did want to mention that this was a ver

20 significant effort by the industry. We spent a lot

21 of hours and a lot of dollars.

22 This was a major effort to totally redo

23 this test procedure. We did this basically at a tim

EE-RM-94-230 COMMENT 0C
1 when most all of us were in the midst of very

2 engineering-intensive activities in our won facility

3 so it was a major effort. A lot of us put a lot of

4 hours in.

5 During this process, we held two workshop

6 with all interested parties invited. They didn't

7 always attend but they were invited.

8 The second workshop, we reviewed the test

9 procedure to that date and time in great detail, lin

10 by line, and during this whole process, there was a

11 lot of coordination and discussions back and forth

12 with DOE and NIST during the development of this tes

13 procedure.

14 The most important thing is that, althoug

15 most of us in the industry can't agree on anything

16 else, we have agreed on the test procedure as it is

17 submitted to DOE. There is unanimous consensus on

18 that.

19 I'll hit some of the highlights of the

20 changes -- major changes -- in the test procedure.

.21 We hope we have gotten rid of some of the

22 ambiguity and the language. We've used language and

23 termination and technology that we hope will leave

EE-RM-94-230 COMMENT 0C
1 less room for multiple interpretations.

2 We also, obviously, updated temperature u

3 factors. This is based on the latest Proctor &

4 Gamble survey data.

5 We've also changed the hot water

6 temperature assumption. I think that's gone from 1

7 to 135 degrees.

8 We have included a procedure for washers

9 with adaptive fill controls. Obviously, one of the

10 areas for potential energy savings is controlling th

11 amount of water that's used in the machine, since

12 most of the energy that washers use is the energy

13 required to heat the water that goes into it.

14 We know that consumers are notoriously po

15 judges of load size. They'll put in a medium load

16 and fill it clear up with water. So there's a

17 potential for energy savings there.

18 We have also included a procedure for the

19 European type machines, most of which have only a

20 cold tap water connection and heat the water

21 internally. We have developed a procedure for

22 evaluating the energy consumption of those machines.

23 We are also running most of our tests wit

EE-RM-94-230 COMMENT 0C
1 test loads, and those test load sizes are based on

2 wash basket capacity.

3 We have also included a formula for wate

4 consumption. This formula does not enter in the

5 energy calculation in any way but is there primaril

6 just for the use of utilities for any rebate purpos

7 it might have.

8 The remaining moisture content is a very

9 important number because that is the connection

10 between the washer and the dryer. That- number is

11 used to determine the dryer energy, which is a majo

12 factor then in the modified energy factor, which we

13 are suggesting be used from now on.

14 The modified energy factor includes tota

15 washer energy and total dry energy and is based on

16 capacity.

17 MR. MARGOLIS: Excuse me.

18 MR. STILWELL: Yes.

19 MR. MARGOLIS: You have developed this

20 modified energy factor which includes drying energy

21 MR. STILWELL: Yes.

22 MR. MARGOLIS: But I heard Mr. Samuels sa

23 that AHAM is noncommittal on whether or not it

EE-RM-94-230 COMMENT 0C
1 supports or doesn't support a standard being based o

2 this.

3 MR. STILWELL: That's correct.

4 MR. MARGOLIS: My question is, why do we

5 have it? I mean, if you don't support it, then why

6 did you come to a test procedure for it, which would

7 then base a standard on it. Since you have a test

8 procedure, then you could base a standard on it.

9 MR. STILWELL: That's true. This is just 

10 procedure, and this procedure allows for the use of

11 washer extraction to be factored on. We're not

12 suggesting that it be factored in or not factored in

13 the test procedure does allow for it.

14 MR. MARGOLIS: And you're saying everyone

15 all manufacturers, the environmentalists, and the

16 trade association, AHAM, support the test procedure?

17 MR. STILWELL: That's correct.

18 MR. MARGOLIS: Okay.

19 MR. STILWELL: Then we anticipate there a

20 probably going to be some types of controls or some

21 machines that are going to be so different that this

22 test procedure will not.adequately measure the energ

23 consumption of those units, so we have developed a

EE-RM-94-230 COMMENT 0C
1 standardized field test procedure for those systems.

2 It's there, then, if any manufacturer fee

3 that the test procedure does not adequately measure

4 their washer, they can use a field test, to then use

5 that information to pursue a waiver of test

6 procedure.

7 That is essentially the changes.

8 Of course, I did want to mention that the

9 modified energy factor is very different from the

10 energy factor- number that we have today. The two

11 numbers are not comparable, so obviously any new

12 standard that is to be developed should be developed

13 using this new test procedure.

14 Questions?

15 QUESTIONS AND ANSWERS

16 MR. NABINGER: I have no questions.

17 MS. WATSON: Questions?

18 MR. STILWELL: I was just reminded that w

19 cannot say that all of the environmentalists support

20 this. We don't know of any objection to it, but, by

21 the same token, they have not told us that they all

22 support it either.

23 MR. MARGOLIS: ACEEE and NRDC, have been

EE-RM-94-230 COMMENT 0C
1 consulted?

2 MR. STILWELL: They were invited to the

3 workshop but they did not come.

4 MR. LaFRANCE: And they have been provide

5 a copy last week and are presently reviewing it and

6 will provide comment by the end of the comment

7 period.

8 MS. WATSON: Marc, any comments?

9 MR. LaFRANCE: I have a couple of comment

10 First of all, I would like to thank AHAM

11 for initiating this effort. It has really been

12 helpful to move ahead with the future test procedure

13 for the use of next round of standards.

14 I guess I have several technology

15 questions, and I'm not really sure at what point in

16 time I should ask them, because I know you have

17 several presenters coming up here.

18 Do you think I should wait until the end 

19 your presentations to call the questions? Right now

20 would be a good time to go over a few things.

21 Since you talked about the MEF equation, 

22 notice that you're using a .83 with a DUF -- a dry

23 utilization factor. TNG has recommended 84.4.

EE-RM-94-230 COMMENT 0C
1 MR. STILWELL: That's correct.

2 MR. LaFRANCE: I was wondering if you

3 provide the basis for the .83.

4 MR. STILWELL: I think we probably need 

5 caucus on that but I'm guessing that we would

6 probably go along with .84.

7 MR. LaFRANCE: Okay. Also, on the tufs

8 (ph), that's been a point of contention, I guess, t

9 some extent over several revisions; the last revisi

10 or the final version that was presented to us, is

11 very close to the original that was presented to us

12 At that point in time, the basis was like

13 P&G data for 1992 and 1993.

14 We're curious if that's still the same

15 basis or was it done on a different type of

16 regression or something, because I know there was

17 quite a lot of work done on that effort.

18 MR. STILWELL: I'm not sure I can answer

19 that right off the top of my head.

20 AUDIENCE: I will be talking about that,

21 Marc, in my testimony.

22 MR. LaFRANCE: Okay.

23 Also, you've .

recommended that we adopt,

EE-RM-94-230 COMMENT 0C
1 several things. You said several elements of your

2 new proposed test procedure into the DOE proposed

3 test procedure referred to as the interim test

4 procedure.

5 MR. STILWELL: Yes.

6 MR. LaFRANCE: It appears that some of t

7 comments relate to test burdens, for example, getti

8 rid of the ranges for the scale and things like tha

9 Is that the primary purpose for something like that

10 to produce ambiguity in the test procedure --

11 existing interim test procedure? Not the existing,

12 but the proposed interim test procedure?

13 MR. STILWELL: Yes. When we developed th

14 new test procedure, we tried to develop it in all

15 areas, including the definitions and also in the te

16 equipment used and the tolerances, and we thought

17 this would also be a good time to lift that section

18 out and put it right into the interim test procedure

19 just kind of make an orderly transition then.

20 MR. LaFRANCE: Okay. I guess one thing

21 that w have proposed in the interim test procedure 

22 a means of testing an automatic water-filled

23 controlled clothes washer or a machine-controlled

EE-RM-94-230 COMMENT 0C
1 clothes washer.

2 I notice that that is not one of your

3 recommendations for adoption into the interim. In

4 other words, your version of the adaptive water5 filled controlled feature or provision in the test

6 procedure.

7 The initial remarks from Chuck said that

8 you support everything else in the existing DOE

9 procedure.

10 So if that were to be the case, then I

11 believe AHAM is saying that you agree with the

12 Department's version of the automatic fill control

13 provision versus the AHAM provision that has been

14 proposed?

15 Because I believe that the Department may

16 give too large of a credit in what we propose versus

17 what has been developed by AHAM.

18 MR. STILWELL: Our position -- our indust

19 position -- is basically that there was no consensus

20 within the industry on using this adaptive control

21 test procedure at this time.

22 When we developed the new test procedure 

23 proposed, the new test procedure anticipated that

EE-RM-94-230 COMMENT 0C
1 this would be put into effect sometime in the future

2 this adaptive fill control, and there was not

3 agreement within the industry to go ahead and pick

4 that particular one out and put it in the interim

5 test procedure. It was a matter of timing.

6 MR. LaFRANCE: Right. Possibly, if AHAM

7 could elaborate on that particular point or its

8 members provide individual comments relative to what

9 we should adopt for the interim. In other words,

10 right now, we've proposed a means of testing those

11 types of machines because it's an improve in energy

12 efficiency, and we want to encourage that, obviously

13 So if we could get comment from the membe

14 as well as AHAM, if it's something that AHAM really

15 can't provide us because of the situation.

16 Let's see.

17 Also, maybe you all could give some

18 elaboration on the Department proposed a consumption

19 factor, and the AHAM test procedure provides a means

20 of testing the total consumption.

21 But in a marketplace with varying capacit

22 sizes, it'll just show.the total amount of water

23 that's consumed by that particular machine, and won'

EE-RM-94-230 COMMENT 0C
1 put it on an equal basis, which is what the factor

2 was supposed to do.

3 We'd be interested in getting some comme

4 relative to what's the advantage of not having a

5 consumption factor versus having a consumption

6 factor.

7 I guess, also, AHAM is proposing to chan

8 the method of measuring the capacity in the interim

9 test procedure.

10 It's. pretty much the same thing, except 

11 Department proposed two versions, one which would

12 address front loader type of machines and one that

13 address top loader machines.

14 Basically, the clothes washer would have 

15 be turned on its side versus standing there at its

16 normal duration.

17 Is that something that you feel is

18 intuitive to the person running the test or they hav

19 to turn it over, otherwise, you can't fill it up?

20 MR. STILWELL: Right. Yes.

21 MR. LaFRANCE: It's just a simple thing

22 where it's self-explanatory?

23 MR. STILWELL: We assume that everybody

EE-RM-94-230 COMMENT 0C
1 will be able to figure out how to measure the volum

2 of one, whether it's vertical or horizontal.

3 MR. LaFRANCE: All right. One thing abo

4 the capacity, I guess, is a concern, which wasn't

5 presented in the Proposed Rule, but is something th

6 we've learned about that we're a little concerned

7 about.

8 That is, on a top loader, conventional,

9 vertical axis machine, there is the tub ring, I gue

10 you'd call it. I'm not sure if there's a terminolo

11 within the industry of what you call that. And

12 there's the basket that comes up, and then you have

13 the ring on top.

14 Right now, to measure the capacity, the

15 industry is going to the uppermost limit for the te

16 procedures, which says, right at the top, and that

17 amount of space for the ring varies by model. It

18 could be maybe a half an inch to as much as three

19 inches.

20 MR. STILWELL: Yes.

21 MR. LaFRANCE: That is kind of a concern

22 because the definition -- I shouldn't say definition

23 but the measure of testing -- specified that

EE-RM-94-230 COMMENT 0C
1 something close to the usable space for the clothing

2 and it seems to me that that ring space wouldn't

3 really be usable space on the clothing because it's

4 not even the basket part.

5 That seems to be that that could provide 

6 larger credit to that type of test.

7 MR. STILWELL: That's correct.

8 MR. LaFRANCE: It's a concern to us, and 

9 AHAM could provide comment on that, or its members,

10 we would appreciate that as well.

11 MR. STILWELL: I'd like to comment on tha

12 We did try to tackle that situation early

13 on, and one of our suggestions was to move the

14 maximum fill level as the usable volume of the

15 washer.

16 However, in thinking towards the future,

17 there's the possibility that people may be able to

18 figure out how to wash in a vertical axis washer wit

19 very small amounts of water. In this case, that kin

20 of a measurement would penalize them, so we didn't g

21 that direction.

22 About the only way we could come up with 

23 the one that we're using now, realizing that it's no

EE-RM-94-230 COMMENT 0C
1 totally accurate but it's the best we could do.

2 MR. LaFRANCE: Wouldn't there be a way to

3 possibly define it by saying to the uppermost portio

4 of the basket, not including any type of ring

5 surface, or something like that, that would at least

6 keep it down to that lower surface within the basket

7 We all know the water level may change

8 within the basket itself, which could drop it below

9 the top portion, but that seems to be the space or

10 the clothing. Is there any way that that could

11 possibly be defined?

12 Because, right now, depending on the

13 thickness of that ring, there could be a pretty larg

14 disparity as to the measurement of the volume, the

15 usable volume versus that test method.

16 MR. STILWELL: Well, we can certainly

17 revisit that and discuss it again, see if there is 

18 more accurate way of doing it. As I say, the first

19 time we went through this, we couldn't come up with

20 one that everybody would agree to. We can take

21 another look at it.

22 MR. LaFRANCE: All right. I guess the la

23 question I have deals with the warm wash.

EE-RM-94-230 COMMENT 0C
1 The proposed test procedure calculates th

2 warm wash energy consumption versus testing for

3 uniformly distributed temperature selections.

4 MR. STILWELL: Yes.

5 MR. LaFRANCE: It also says that you must

6 test for non-uniformly distributed temperature

7 selections. I guess the problem I have is that ther

8 is not a definition as to what is uniformly

9 distributed.

10 So, for example, if you have a machine th

11 has 60 degree cold and 135 degree hot, and if the

12 uniformly distributed machine would have 97.5 degree

13 warmth, what's the tolerance on that 97.5?

14 MR. STILWELL: Well, the intermediate

15 temperature doesn't have to be a fixed number. It

16 can be any number in between, as long as the number

17 on the other side of warm is also spaced equally.

18 MR. LaFRANCE: Right. So, in other words

19 if the cold was 70 and the hot was not 125, in other

20 words, that's uniformly distributed no matter where

21 you are in that range, so wherever the cold is and

22 the hot is, the warm would be between thorn two?

23 MR. STILWELL: Not necessarily.

EE-RM-94-230 COMMENT 0C
1 MR. LaFRANCE: Okay. I guess I need to g

2 further explanation on that.

3 MR. STILWELL: No. For example, if you h

4 135 degree hot and you had 95 degree warm, you might

5 have an intermediate temperature that was 105, and

6 that would be 10 degrees above warm. You might have

7 one that was 85, it would be 10 degrees below warm.

8 They would be equally distributed, but th

9 wouldn't be halfway between, necessarily, between

10 warm and hot and warm and cold.

11 MR. LaFRANCE: Okay. Well, I guess that

12 explains my concern about how would we define

13 uniformly distributed as a concern.

14 Also, since the calculation is bsed on 

15 135, because you're basically testing the hot, and

16 everything you're calculating for warm is based on

17 what the hot temperature is.

18 If you're looking at a range of warms tha

19 are below or above the medium from cold to hot, then

20 you could have a problem. I guess it needs to be

21 defined better.

22 Also, the procedure goes on to say if it

23 not uniformly distributed, you need to te-t all of

EE-RM-94-230 COMMENT 0C
1 them.

2 I believe there are machines today -- I'm

3 not sure about this, and hopefully you can clarify

4 that -- that have infinite temperature selections.

5 So in that scenario, and it was not uniformly

6 distributed, for example.

7 MR. STILWELL: Well, if they were infinit

8 they would be uniformly distributed.

9 MR. LaFRANCE: No matter what it would be

10 Okay. So that would cover that scenario.

11 MR. STILWELL: Right.

12 MR. LaFRANCE; All right. Just getting

13 back to that point then, uniformly distributed, if

14 that could be defined, I think it could be somewhat

15 of a problem, at least from a test point.

16 The manufacturer knows it's uniformly

17 distributed, but the person testing it, if it was an

18 independent lab or whatever else, we'd need to know

19 Okay. That's all. Thank you very much.

20 MR. STILWELL: Okay.

21 MS. WATSON: Gene, any comments?

22 MR. MARGOLIS: Yes. We've proposed amend

23 test procedures, and AHAM came back with comments on

EE-RM-94-230 COMMENT 0C
1 our proposal, which we'll call the interim, and then

2 came back with a test procedure to cover the time

3 when amended standards would go into place.

4 My concern or question -- and I would hav

5 to -- it's not necessary for you to comment on now,

6 but if you wish, of course, you may -- but in your

7 written comments, to give us your reasons why you

8 think we can go final with this final test procedure

9 when we had not proposed it, but that you have come

10 back in this hearing with comments on a new final

11 test procedure.

12 MR. STILWELL: I'm not sure I understand

13 that question. Are you saying that we --

14 MR. MARGOLIS: It's more directed to

15 Mr. Samuels. That you have given DOE comments on ou

16 proposed test procedure for a completely new test

17 procedure to go into effect '99 or some --

18 MR. STILWELL: Whenever a new standard go

19 into effect.

20 MR. MARGOLIS: Yes, something like that.

21 We did not propose that. We made a

22 proposal which we are proposing now to be the

23 interim. I'm asking, would you give us your

EE-RM-94-230 COMMENT 0C
1 thoughts. I'm not'disagreeing with you. I just nee

2 to elicit information why we can go, say, final with

3 the so-called final test procedures and not have to

4 repropose them.

5 MR. SAMUELS: Let me just respond to that

6 now and I can respond to it further in writing if yo

7 want.

8 What our problem is is that when this

9 enterprise between DOE and NIST and AHAM began, it

10 looked like there was enough time to do the interim

11 test procedure and then the so-called final test

12 procedure and do them in separate rulemakings.

13 What's now happened is the time is moving

14 now and collapsing, and the two activities are

15 running into each other, so it's desirable to do the

16 all once, even though the final test procedure won't

17 be in effect until final standards go in effect.

18 We recognize; of course, that you didn't

19 publish what we've now proposed, and that's why I

20 suggested to you that you might want to do that.

21 I leave it up to you whether you need to

22 call it a reproposal or just simply say this materia

23 was presented to us, and we now want the public also

EE-RM-94-230 COMMENT 0C
1 to comment on this, and then you can extend the

2 comment period, for some period of time, given the

3 opportunity to do that.

4 What we discourage you from doing, becaus

5 we know that it will create a significant time lag,

6 is to start a whole new rulemaking.

7 So for you to have a comfort level, you

8 need to go out in the Federal Register again, that's

9 fine. We've tried to help you out by circulating ou

10 test procedure to all people that we know that are

11 interested, but obviously it could be other people

12 that are interested.

13 I think the easiest thing for you to do 

14 to republish, with any commentary you might want to

15 put on it, what we've given you in the Federal

16 Register, immediately extend the comment period a fe

17 weeks and keep it all in the same rule making and

18 then you won't have any problem, or you could call i

19 an amended proposed rule or whatever you want to do.

20 So that's what we're trying to deal with

21 here. We're trying to balance the need to get this

22 completed and public and, of course, with your need

23 to follow proper procedure, but I don't think there

EE-RM-94-230 COMMENT 0C
1 should be any problem in doing that if you follow my

2 suggestion or some variation on it.

3 MR. MARGOLIS: Thank you very much.

4 MS. WATSON: Jim, did you have any

5 questions for Mr. Stilwell?

6 MR. KAO: Couple questions.

7 In connection with Marc's question about

8 the uniformly distributed temperature, in a non9 uniformity is the temperature control. If that test

10 all of the intermediate, seems to me that's not --

11 you know, would that be 10 intermediate or 20

12 intermediate?

13 MR. STILWELL: Whatever they are. Whatev

14 they are. If they're not uniformly distributed,

15 right. I mean, there could be a machine that could

16 have 3, it could have 10, I suppose. Unlikely, but

17 it could. If it had that many and they weren't

18 evenly distributed, then you would have to check the

19 all.

20 MR. KAO: But non-uniformly, any could

21 occur.

22 MR. STILWELL: Yes. They're non-uniforml

23 distributed throughout the range of cold to hot.

EE-RM-94-230 COMMENT 0C
1 MR. KAO: The second question is about 

2 moisture removal, the remaining moisture.

3 You have a minus 4 percent. Was that

4 because of the last 4 percent energy you put in to

5 remove it? You're moving the energy, is really kee

6 the thing up.

7 MR. STILWELL: Yes. That's about the

8 natural moisture content of most fabrics, is about 

9 percent, especially cotton fabrics, right.

10 MR. KAO: Do you have any kind of a pass 

11 something?

12 MR. STILWELL: Yes.

13 MR. SAMUELS: It's the way the dryer tes

14 is done.

15 MR. KAO: My last point is, in the paper

16 you sent to AHAM to recommend that certain sections

17 be point in this rulemaking, that's not really

18 complete. Some of the sections really ought to be

19 in, if we fully incorporate that procedure, so it's

20 not completely numbers on sections.

21 MR. SAMUELS: No.

22 MR. STILWELL: That'll be addressed by th

23 next speaker, regarding the interim test procedurre.

EE-RM-94-230 COMMENT 0C
1

1 MR. KAO: Thank you.

2 MS. WATSON: Thank you.

3 MR. STILWELL: Thank you.

4 MS. WATSON: Will the next speaker come

5 forth, please.

6 CURT REICHMAN

7 AHAM

8 MR. REICHMAN: Hello. My name is Curt

9 Reichman. I'm manager in laundry technology for

10 Whirlpool Corporation. I am a member of the AHAM

11 laundry test procedure task force, and I am speaking

12 today on behalf of AHAM.

13 My comments are going to be directed to t

14 interim test procedure for the clothes-washers.

15 Rather than spending a lot of time discussing

16 definitions, what I'd like to do is focus on five

17 major changes that AHAM is proposing, and comments

18 concerning the definitions and some of the other

19 areas will be included in written comments by AHAM

20 that will be submitted by the August 31st deadline.

21 The five topics I'd like to discuss today

22 are clothes container capacity, remaining moisture

23 content, test loads, modified energy factor, and non

EE-RM-94-230 COMMENT 0C
1 conventional wash systems.

2 These proposals are very similar to the

3 AHAM test procedures submitted to the DOE and

4 Mr. Dick Stilwell spoke of earlier.

5 Number one: Clothes container capacity.

6 AHAM recommends that the DOE adopt the

7 measurement method as proposed. In the AHAM state

8 procedure, the only real change would be that we

9 would have to change the energy test cycle, as we

10 refer to it, as the normal cycle, as what is

11 currently referred to in the DOE test procedure.

12 The benefits the of the AHAM procedure

13 would be, if no reference to the clothes container

14 opening position, whether it's on the side or front

15 or top, or at an angle, we think it's intuitive to

16 the manufacturers how to measure that.

17 It requires that all parts be in place th

18 are recommended for use in the normal cycle, and tha

19 includes agitators or baffles or, for instance, some

20 units may have what we call a plugged door, that

21 would take up space in the clothes container, and

22 those should all be in place.

23

EE-RM-94-230 COMMENT 0C
1 It also provides water temperature for th

2 measurement of the volume and density that is

3 associated with that water temperature.

4 The next topic: Remaining moisture conten

5 AHAM recommends that the remaining moistu

6 content be measured using the AHAM proposed method.

7 If testing with warm rinse is desired, temperature

8 use factor for the warm rinse should be set between

9 21 and 33 percent, as in the AHAM proposed procedure

10 There was not consensus as among AHAM

11 members as to what that should be, and so that's the

12 reason for the range.

13 The benefits of the AHAM proposed procedu

14 are a standalone procedure. It's very simple to go

15 in and identify where you're measuring RMC and how

16 this is to be measured.

17 It requires only one load size per testin

18 so we don't have a three-pound load and a 7-pound

19 load to test, we just have one test load to go to.

20 The loads are based on the machine

21 capacity. RMC can be compared across the different

22 sizes of the products.

23 Test loads: AHAM recommends that a test

EE-RM-94-230 COMMENT 0C
1 load be implemented for use with the remaining

2 moisture content procedures and calculation of the

3 modified energy factor. The load varies based upon

4 the volume of the clothes container capacity.

5 As you can see, the table goes up in volu

6 increments of .1 cubic foot, and there's a load

7 associated with that. The load is based upon some

8 calculations based on P&G data.

9 The modified energy fact: AHAM is proposi

10 a revised modified energy factor, where the dryer

11 energy is tied to the capacity of the washer. This

12 is necessary so units with equivalent energy factors

13 remaining moisture contents, but different volumes

14 will produce relatively equivalent modified energy

15 factors.

16 As you can see, the first two examples

17 there, both have an energy factor of 2 and an RMC of

18 60 percent, but the capacity is different, and you

19 come up with two significantly different modified

20 energy factors.

21 If you're using the same amount of energy

22 based on capacity and you come up with the same RMC,

23 they should be roughly the same.

EE-RM-94-230 COMMENT 0C
1 The AHAM proposed, I have three examples

2 there; again, two that vary by quite a bit, and one

3 also shows variation within the range on the load

4 chart, so as you go through the calculations there,

5 you end up with modified energy factor numbers that

6 come out very close to each other.

7 MR. MARGOLIS: Could I ask you a question

8 now on this modified energy factor?

9 MR. REICHMAN: Sure.

10 MR. MARGOLIS: Is the clothes washer tied

11 in with a certain clothes dryer?

12 MR. REICHMAN: No. We have a standard

13 factor that was used for clothes dryer energy.

14 Factor in the equation that takes into consideration

15 kind of an average dryer and what it ta!es an averag

16 dryer to remove moisture from the clothes lead, so

17 it's not tied to any specific dryer combination of

18 washer-dryers.

19 MR. MARGOLIS: Then what in the clothes

20 washer, would it be a higher spin speed, th!t would

21 be the thing that we're concerned with to crt more

22 water out of the clothes?

23 MR. REICHMAN: There are sever?1 things

EE-RM-94-230 COMMENT 0C
1 that impact the remaining moisture content. It coul

2 be temperature of the rinse, it could be spin speed,

3 it could be the diameter of the basket, it could be

4 length of time in spin, so there are several

5 different methods to impact the remaining moisture

6 content.

7 MR. MARGOLIS: Thank you.

8 MR. RtICHMAN: A' couple of other factors

9 that AHAM included in the calculation for the MEF is

10 a load adjustment factor, which basically uses a

11 multiplication factor times the size of clothes load

12 in the load chart, to bring that down to more of an

13 average size load.

14 Also, a dryer utilization factor, which

15 takes into consideration the amount of clothes that

16 are washed in the washer but do not go into .a dryer

17 for dryer. Not all clothes, loads go into a dryer fo

18 drying, and not all articles out of one wash load ma

19 go into the dryer for drying.

20 The last topic is the nonconventional was

21 system testing. It is likely that there will be new

22 technology in the washer industry before a totally

23 new test procedure is adopted. Therefore, AHAM is

EE-RM-94-230 COMMENT 0C
proposing that the nonconventional wash system

consumption test be added.

This would be the basis for a test

procedure waiver, should a manufacture wish to pursu

that.

That concludes my presentation. We feel

that these things can be added to the interim test

procedure without impacting the current standards an

requiring changes to the current standard.

MS. WATSON: Thank you.

QUESTIONS AND ANSWERS

MS. WATSON: Did you have any questions o

statements, Steve?

MR. NABINGER: I have no questions.

MS. WATSON: Brian.

MR. DOUGHERTY: No.

MS. WATSON: Bryan.

MR. BERRINGER: No.

MS. WATSON: Marc.

MR. LaFRANCE: Yes, I have a few question

One part of your proposed test procedure

references the AHAM test detergent for

preconditioning. For the Department to do that, we'

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23

EE-RM-94-230 COMMENT 0C
1 have to incorporate the records, which has similarly

2 been done before in other test procedures.

3 Also, AHAM has a procedure for

4 preconditioning on the test part, and would AHAM

5 support the Department adopting the AHAM procedure

6 from doing that, instead of defining the detergent?

7 I mean, right now, we'd have to incorpora

8 the AHAM test detergent by reference, which is part

9 of the preconditioning.

10 Does AHAM recommend that we incorporate 

11 preconditioning or support us referencing the

12 preconditioning test procedure?

13 MR. REICHMAN: I don't have an answer for

14 that. That was not a top of discussion, and so we

15 would have to go back and take a look at that.

16 MR. LaFRANCE: If someone could provide 

17 written comment, I'd appreciate it.

18 Also, at the workshop you had in February

19 you provided reference material which was relative t

20 many issues that have been discussed today and that

21 are a part of your proposed test procedure. However

22 your proposed test procedure has changed from that

23 point in time, and that workshop reference material

EE-RM-94-230 COMMENT 0C
1 is not part of this docket because it was prior to

2 being incorporated.

3 So if you could provide all of the

4 pertinent reference material in your final comments

5 it would be helpful.

6 For example, you referred to the

7 calculations for the test load, and I know that's on

8 of the sheets that you had and you include that.

9 You talked about the nonconventional test

10 methods which you proposed field testing -- you

11 establish the field testing requirements which would

12 be used for a waiver commission.

13 I guess we would also be interested in

14 hearing AHAM's position on if we actually use that

15 procedure, the manufacturer conducted the field

16 testing, submitted a waiver based on that testing,

17 and was granted the waiver for that particular model

18 or models involved.

19 What does AHAM believe to be the procedur

20 for incorporating the intent of that waiver into the

21 test procedure, or is it AHAM's position that we

22 would have many waivers that would exist for an

23 indefinite amount of time? In other words, what

EE-RM-94-230 COMMENT 0C
1 would be the next step to incorporate those potentia

2 waivers into the final test procedure, or a new

3 version of the test procedure?

4 MR. REICHMAN: Probably very much the sam

5 as what you're doing right now with the current wate

6 heating clothes washers and trying to incorporate

7 them into the test procedure as more changes become

8 necessary.

9 MR. LaFRANCE: I guess my concern is if

10 Manufacturer A had a certain type of adaptive

11 controlled machine and Manufacturer B had a differen

12 type, and in the field they both performed

13 differently where you really couldn't correlate som

14 kind of fudge factor or something; I mean, it might

15 be to early to discuss that.

16 Now, do you have any thoughts as to how w

17 would attempt to incorporate those waivers based on

18 these non-conventional testing -- or non-conventiona

19 machines, I should say.

20 MR. REICHMAN: Okay.

21 MR. LaFRANCE: One last thing: With your

22 moderate energy factor, it address the remaining

23 moisture content and includes it with the other

EE-RM-94-230 COMMENT 0C
1 energy.

2 Now, there has been some concern about

3 having a lower RMC, let's say, on a new machine.

4 That could be selectable -- consumer selectable. Fo

5 example, a consumer may wish to have a lower RMC on

6 certain types of fabrics and not on other ones. Lik

7 maybe they wouldn't want a lower RMC on delicates,

8 for example.

9 Is that something that should be consider

10 into the equation, the possible percentage? In othe

11 words, how often a lower RMC will be used, if it's

12 selectable?

13 MR. REICHMAN: I believe in the test

14 procedure that was submitted, we recommend whatever

15 is specified for cottons and linens.

16 MR. LaFRANCE: Okay. So, basically,

17 whatever is recommended by the manufacturer's

18 literature is what will be tested?

19 MR. REICHMAN: Correct.

20 MR. LaFRANCE: Okay. If it was selectabl

21 is that something the manufacturer would usually

22 recommend at a particular speed or for that type of

23 fabric?

EE-RM-94-230 COMMENT 0C
1 MR. REICHMAN: I would assume that that

2 would be referenced in the literature, similar to

3 what the normal cycle is recommended for cottons and

4 linens.

5 MR. LaFRANCE: All right. Thank you.

6 That's all I have.

7 MS. WATSON: Gene.

8 MR. MARGOLIS: No further questions.

9 MS. WATSON: Jim.

10 MR. KAO: I have one question. On the te

11 completion, it doesn't make any difference with the

12 nonwater-heating washers or water-heating washers.

13 We did some testing for low load. It could make a

14 difference, for instance, 10 degree, room

15 temperature.

16 The difference may be over 3 percent

17 different than energy consumption.

18 Do you have any to set the condition for

19 the room capacity or the washer precondition so that

20 everybody for the water-heating washers will be

21 testing at the same.

22 MR. REICHMAN: Ambient room conditions?

23 MR. KAO: Either ambient or the washer.

EE-RM-94-230 COMMENT 0C
1 MR. REICHMAN: We were not aware that it

2 made that much difference. We did not include

3 anything like that. We would be interested in seein

4 the data, and I think we could include something lik

5 that.

6 MS. WATSON: Thank you.

7 Next speaker, please.

8 EARL JONES

9 MR. JONES: Good morning, Ms. Watson and

10 Panel members. My name is Earl Jones. I'm senior

11 counsel with GE Appliances. We are testifying --

12 myself and Larry Hawkins -- here this morning.

13 I want to address I guess what I call

14 policy questions regarding the test procedure which

15 you all are proposing, and then AHAM's comments on

16 that, and then go beyond that to talk about some of

17 the issues regarding the technology as they're

18 implicated by the test procedures and certain other

19 issues. Those will be addressed by Mr. Hawkins.

20 We're both up here together because, rath

21 than displaying some of my total ignorance on some o

22 the issues, I'm going to turn to him, should that be

23 necessary.

EE-RM-94-230 COMMENT 0C
1 First: GE Appliances, as a member of AHAM

2 supports the testimony, which you've heard this

3 morning, regarding the changes to the interim test

4 procedure, which AHAM suggests, and we also, of

5 course, support the ultimate adoption of the test

6 procedure as proposed by AHAM.

7 Just want to emphasize the point, as was

8 done by Dick Stilwell, the competitive pressures

9 affecting this particular segment of the industry,

10 I'm sure you all are very familiar with them, but

11 notwithstanding that, we have managed to pull

12 together to draft what we consider to be a very good

13 product. On that basis alone, it should command

14 particular attention from DOE.

15 It, of course, recognizes the fact that

16 there have been significant changes in consumer usa

17 patterns over the last 20 years. It also makes

18 provision for adaptive controls when that day

19 arrives, when those kind of controls are introduced

20 into our products, the efficiency benefits of which

21 I'm sure we all understand.

22 We also want to echo and to support

23 Chuck Samuels' comments regarding, if you will, a

EE-RM-94-230 COMMENT 0C
1 single-step process as being the best way to approac

2 the test procedure issue, to his point whether that

3 some kind of a supplemental notice in the Federal

4 Register, advising persons the opportunity to commen

5 on the AHAM draft or whether it's a reproposal of th

6 test procedure with your proposed rule, with somehow

7 the AHAM draft attached as an appendix to something

8 whatever is the appropriate procedure.

9 The notion of doing this once and for all

10 getting it over with now; giving us all as much

11 notice as possible, as we begin to pull together our

12 product plans, going forward, just on the notice, if

13 we want to talk about different level efficiency, an

14 that's governmental efficiency, and certainly

15 efficiency of resources in industry, taking the time

16 to deal with this process, we would appreciate doing

17 it once and not having to do it two times.

18 On another issue, on the question of -- a

19 I think, Mr. LaFrance, you may have raised this

20 question -- why other aspects of the AHAM draft

21 proposal are not suggested by AHAM to be incorporate

22 into the interim test procedure. Again, as you

23 appreciated, there are reasons why we have been

EE-RM-94-230 COMMENT 0C
1 unable to agree upon that.

2 I want to just state clearly, from GE's

3 point of view, we are opposed to incorporation of an

4 provisions from the AHAM draft into the interim test

5 procedure, other than those which the industry has

6 agreed upon.

7 The reasons for this, I think, are severa

8 Again, from my limited acquaintance with the whole

9 issue of energy efficiency standards and test

10 procedures, I know that this industry, or at least

11 some members of this industry, have been very badly

12 burned by the way certain aspects of test procedures

13 affecting washers has been handled by DOE over the

14 years, the most recent example of which was this

15 whole question of warm water rinse lockout.

16 I think DOE should be very carefully and

17 trod very carefully when they have an opportunity to

18 impact the competitive situation.

19 We believe that adopting the AHAM draft, 

20 time if you will or in anticipation for the new

21 standard which is being worked on, is the best way t

22 guarantee a level playing field, to reduce the

23 opportunity for competitive gamesmanship, as we have

EE-RM-94-230 COMMENT 0C
1 seen too much of in the past.

2 Again, it provides adequate notice to all

3 of the parties as to where we are going. If someone

4 wants to make a proposal regarding one aspect of

5 that, we all have notice of that and opportunity to

6 comment.

7 I think that's very, very important. To 

8 certain extent, the credibility of this Department,

9 this section, and the ability of the industry to wor

10 together with you all to resolve some of these issue

11 is dependent upon our being able to understand what

12 going on and not to be surprised.

13 On that basis alone, we believe that ther

14 should be no incorporation beyond what's being

15 suggested.

16 I'd like to go on just for a moment now

17 before Mr. Hawkins comments on some of the more

18 technologically critical portions of this rule to

19 address the issue of RMC.

20 Mr. Margolis, one of the questions you

21 asked was why is AHAM proposing an NEF factor, which

22 we're not suggesting that a standard be based on

23 that. Of course, DOE, in its interim proposal, made

EE-RM-94-230 COMMENT 0C
1 that suggestion. We had simply taken that, if I

2 understand correctly, AHAM has, and refined it. If

3 you're going to do it, do it the right way, and

4 that's what the industry is suggesting.

5 We do believe, though, that in adopting 

6 test procedure and certainly looking beyond that to 

7 standard, that the statute under which these

8 activities are being conducted, does not permit DOE

9 to adopt the standard which requires attainment of

10 any level of RMC.

11 So, although GE supports the idea that D

12 may facilitate the measurement of RMC, for whatever

13 purpose, including by the way, attaining a standard

14 level, DOE may not require, in that standard, that

15 any level of RMC be reached, and that's true becaus

16 achieving a certain level of RMC, obviously, requir

17 the consumption of increased energy in the washer,

18 and I think it's sort of ironic or contradictory fo

19 the Department to require the use of more energy an

20 achieving less energy, when the less energy is bein

21 consumed in a different product.

22 Of course, the statute requires its

23 standard to be set for each product, so you may not

EE-RM-94-230 COMMENT 0C
then, by requiring a minimum level of RMC in the

washer, in effect anticipate or compensate for the

failure, to set a standard for the dryer, since the

law requires you to set standards by products.

Of course, we believe the facts alone wil

show that no standard is justified for dryer, and we

don't have to, in effect, concede on that point in

order to have you all not do something which is

inappropriate for dryers.

Those are the points I wanted to make.

Again, Mr. Hawkins will address the question about

the technology involved and the other aspects of the

test procedure.

MR. LaFRANCE: Could I ask one question

before we move on here?

MR. JONES: Sure, as long as they're with

my --.

QUESTIONS AND ANSWERS

MR. LaFRANCE: Okay. In regards to not

adopting anything else that hasn't already been

proposed by AHAM in the interim test procedure, I

guess I still have concerns about one particular

issue; that is, the automatic fill control provision

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EE-RM-94-230 COMMENT 0C
1 that the Department proposed in the March 23rd

2 notice.

3 In that equation, the Department proposed

4 testing at a 3 pound and 7 pound load. I believe

5 Curt just explained the advantages for the future

6 procedure, that you only test one load, for example

7 I'm sorry, that might have been for the

8 RMC. I'm sorry.

9 But for the automatic fill control, we

10 proposed testing the minimum and maximum test loads

11 that are presently used for front loader machines,

12 3 pounds and 7 pounds.

13 The AHAM proposed test procedure for the

14 future uses the -- I believe it prorates between the

15 maximum average and minimum test loads.

16 So if you take the shift weighted average

17 clothes washer for capacity of approximately 2.9

18 cubic feet, and you were to run the DOE test versus

19 the AHAM proposed test, the AHAM procedure would use

20 a 27 percent larger load on average than the DOE tes

21 procedure.

22 So the DOE test procedure would provide a

23 larger credit than probably is actually justified fo

EE-RM-94-230 COMMENT 0C
1 that type of machine versus the AHAM test procedure.

2 So, obviously, you said you do support th

3 addition of any additional provisions into the

4 existing test procedure. Then could you please

5 provide comment on the DOE proposed provision for

6 automatic fill control and whether you think that's

7 acceptable or reasonable, considering it does use a

8 smaller test load than the AHAM proposed test

9 procedure.

10 MR. JONES: I suspect that you went beyon

11 my canton. If you want us to comment on that,

12 certainly after the fact we will do that. I don't

13 know, Larry, whether you want to comment on it now.

14 If you can, let's do so; otherwise, we'll submit it

15 later.

16 MR. HAWKINS: Yes, I can add one comment,

17 Marc. Our position is primarily based upon the

18 concept more than the mechanics of how it's executed

19 the concept of it and the advanced technology being 

20 machine control fill or an adaptive fill, more than

21 the AHAM versus the DOE process.

22 If we were to say which process we suppor

23 we support the one that we participated in and

EE-RM-94-230 COMMENT 0C
1 developed with AHAM as a procedure. The question is

2 the timeliness of adoption.

3 MR. LaFRANCE: I guess the purpose of

4 today's hearing and one of the provisions is to adop

5 a means of testing automatic water filled controlled

6 machines. The Department is aware of companies that

7 have those machines on the market today, that we

8 actually have issued a waiver to one of the companie

9 for that particular design feature.

10 So we realize the need to provide that

11 provision into the test procedures, and that was the

12 purpose of, one of the purposes of, today's proposed

13 rule, was to provide that provision for energy

14 efficient clothes washers that have automatic or

15 water-filled controlled capability.

16 It seems as if we have proposed it, it's

17 something we do want to adopt because there's a need

18 for it, and if we're going to adopt something, then

19 obviously we want to adopt the best method of testin

20 that.

21 If you could provide comment as to whethe

22 the -- or I think you just did -- that the AHAM

23 procedure is better than the DOE proposed procedure;

EE-RM-94-230 COMMENT 0C
1 and, frankly, I have to agree with you, I think it 

2 as well.

3 So if you could possibly look back, from 

4 individual company's standpoint or from an AHAM

5 standpoint and address that particular subject

6 because, at this point in time, AHAM is not endorsin

7 that particular provision of their procedure into ou

8 procedure, but yet our proposal still stands, at th

9 point in time, and we haven't heard any negative

10 comment to it.

11 I guess we need to get that clarified.

12 That's all.

13 MR. JONES: We'll attempt to do that. I

14 would only add, by the way, that the fact that the

15 waiver process does exist, we would hope it would

16 satisfy whatever needs there are.

17 In other words, our proposal or our

18 position here hopefully doesn't stand in the way of

19 people getting credit for what they are due. Our

20 issue is a more limited one than that.

21 But, again, we may go back, if we can, an

22 take a look and specifically address what's in the

23 interim procedure and comment.

EE-RM-94-230 COMMENT 0C
1 MR. LaFRANCE: Right now, we have a waive

2 that is in effect for that particular design feature

3 If we are required by the statute to resolve that

4 into a final test procedure, that's what we're

5 attempting in parts of these rulemaking.

6 So it's just a concern, and like I said,

7 you will address it, and I appreciate that. Thank

8 you.

9 MR. JONES: Yes.

10 MR. MARGOLIS: When you address that, we

11 would have to put into the final test procedure, of

12 say the interim final test procedure, and also the

13 final test procedure the granting of the waiver, so

14 that it could be tested by any manufacturer.

15 We can't leave off that because we did

16 grant the waiver, and therefore part of the

17 regulations are that once we grant a waiver we then

18 have to hold a -- since the waiver is only granted t

19 a manufacturer, another manufacturer using the same

20 device, say, has to come in for a waiver.

21 So that's why in the test procedure we ha

22 to then publish procedures that would allow for any

23 manufacturer to do what the waiver was granted for.

EE-RM-94-230 COMMENT 0C
1 MR. HAWKINS: Okay. We'll address that.

2 MS. WATSON: Jim.

3 MR. KAO: No.

4 MR. HAWKINS: Are there any other

5 questions? If not, I'll start on my part of the

6 presentation.

7 MR. JONES: Thanks, Larry.

8 LARRY HAWKINS

9 MR. HAWKINS: I have some charts I want t

10 talk from. One of the questions that you asked a

11 minute ago, Marc -- incidentally, I'm Larry Hawkins.

12 I'm a senior engineer with the General Electric

13 Company, and I'm speaking on our behalf.

14 You asked a question about how we arrived

15 at the temperature usage factor values that are in

16 the AHAM recommended new test procedures. This char

17 addresses that question.

18 MR. MARGOLIS: Can you give to the court

19 reporter a copy of these charts so that they could b

20 put into the testimony.

21 MR. HAWKINS: Yes.

22 Table 1 [see following page], shown at th

23 top of this chart, represents the temperature usage

EE-RM-94-230 COMMENT 0C
Exhibit B

AHAM Temperature Usage Factors (TUF's)

AHAM's Test Procedure TUF's

P&G's raw data, Table 2 below, was used to determine the wash and rinse temperature usage trends and forecast values 

the year 1999. The forecasted value for the warm rinse TUF was 12.6% was normalized based on the agreed upon warm

rinse option model mix.

Table 1: AHAM Sim )lified Temperature Usage Factors'

Temperature Selection Wash Cycle Rinse Cycle'

L_ Hot 14 -

Warm 47 1 21

Cold . 39 79

P&G Raw Data

The following table is a presentation of the P&G information data used in the analysis, except for the 1975 data. It is

consistent with data 3P&G gave to DOE previously.

Selection Year

75 78 81 82 83 84 85 86 87 88 89 90 91 92 93 94

HotWash 27 23 21 19 19 19 19 18 '17 17 19 18 16 16 14 16

WarmWash 50 51 52 52 54 53 53 55 57 56 51 51 49 51 50 48

ColdWash 23 26 27 29 27 28 28 27 26 27 30 31 35 33 36 36

Warm/HotRinse- 38 32 30 27 30 27 27 24 24 26 22 23 21 20 18

Cold/CoolRinse - 62 68 70 73 70 73 73 76 76 74 78 77 79 80 82

Warm Rinse Selection

Warm rinse data yielded a mean value of 12.6% with a 95% confidence interval of (9.7 to 15.5).

Regression Fit to Warm Rinse Data

40

T

e

m

P

c

r

a

t

r

*

35

30

25

20

15

10

70 75 S0 S5 90 95

Year

100

* 'AHA.M's Test Procedure Taskforce provided the updated TUF's as part of DOE Clothes Washer Test Procedures Rev #8.

2 The AHAM Taskforce reached agreement on the wash TUF's as shown; however, the rinse TUF is presented in Rev #8 changes as a range from 21% to 33%.

GEA performed the data analysis and it was our recommendation to the Taskforce that the appropriate value to be used is 21%.

' Comparison of data provided to GEA by both P&G and DOE is found to be in agreement for years 1987 through 1994. 1975 data did not match and was not u

in the analysis. The data for years 1978 through 1986 was not in the earlier data provided to DOE.

EE-RM-94-230 COMMENT 0C
1 factors that is in the AHAM procedure for hot wash,

2 warm wash, cold wash, warm rinse and cold rinse.

3 The raw data came from Proctor & Gamble.

4 The analysis technique of analyzing the data to come

5 up with these proposed temperature usage factor

6 numbers was consistent for both wash and rinse

7 cycles.

8 The raw data is shown in the table, and 

9 like to note that I did check our data against the

10 data that DOE provided us earlier.

11 I found that our data is consistent with

12 the data that DOE has, with the exception that 1975

13 numbers did not agree, and also with the exceptions

14 that our data contains values, information for the

15 years 1978 through 1986, which was not inclusive in

16 the data that DOE had.

17 Regarding the 1975 year, where we did not

18 have agreement, we did not use that data nor did we

19 use 1978 data in our analysis, primarily because it

20 was not sequential in nature. There were years of

21 separation.

22 Starting with 1981, going forward, we had

23 one-year separation points. We used that data in ou

EE-RM-94-230 COMMENT 0C
1 analysis.

2 When we analyzed the data, we did it usin

3 several statistical techniques. We used regression

4 analysis, we used regression analysis that was both

5 linear and nonlinear. Nonlinear making the more

6 sense because it would then not have usage factors

7 going below zero.

8 However, we also looked at the data and

9 found that there is a factor called auto correlation

10 that exists within the data.

11 Auto correlation means, as we see often 

12 time series data, that any one year's value is

13 related to the previous years of data. There is a

14 relationship that exists.

15 A common technique for removing that auto

16 correlation is to take the differences of the years,

17 from one year to another to another. For instance,

18 taking the 1982 data, subtracting away 1981 data, an

19 coming up with an incremental change for that one20 year increment.

21 We did that process for the years 1981

22 through '84, averaged those values, and then

23 projected out to 1999, using those averages to exten

EE-RM-94-230 COMMENT 0C
1 the data.

2 In the process of doing it, we were able 

3 eliminate the auto correlation, as I have mentioned

4 and also it provides us the ability to do confidenc

5 interval bounding of the data.

6 For all of the data that was presented,

7 AHAM agreed with us on the wash cycle data. We did

8 not reach agreement on the warm rinse cycle data.

9 But I want to restate that the analysis techniques

10 were the same for all the sets of data.

11 There was a question as to whether we ha

12 used the mixed ratio of units of available in the

13 marketplace, which offered a warm rinse selection,

14 versus those available in the marketplace, which it

15 did not use a warm rinse selection. Our data said

16 that's a 60 percent ratio.

17 As you can note, I took the warm rinse

18 number of 12.6, divided it by the 60 percent to com

19 up with the 21 percent recommended number. So I

20 believe it's consistent with the earlier ways that 

21 in the AHAM group agreed with how to treat the warm

22 rinse.

23 As far as market mix ratio and the warm

EE-RM-94-230 COMMENT 0C
1 rinse data itself, it's consistent in technique to

2 how we analyze the wash data, and we propose it's th

3 appropriate number to use.

4 We believe that extrapolation out to 99 

5 this manner is also the proper way to treat the dat

6 since it follows the prevailing trend, over the

7 period from '81 to '94, to stop it short in either

8 '94 or '95, as previously proposed by DOE.

9 We'd presume that the prevailing trend

10 stops at that point in time and no change would occ

11 from '94 through '99. We do not believe that that 

12 the better way to treat the data. We believe that

13 the appropriate way would be to follow the trend.

14 MR. JONES: I might note, by the way,

15 Mr. Margolis, that the written comments, which we d

16 submit and you all should have received last week,

17 has two exhibits, and this chart is an exhibit to

18 those written comments.

19 MR. LaFRANCE: Actually, that was one of 

20 questions. The top chart, you're saying, should be

21 reflected in the test of the final testing

22 procedure, which was provided to us last week.

23 I believe we have a difference, because t

EE-RM-94-230 COMMENT 0C
final procedure that came to us shows 14, 50 and 36;

not 39, not 47. So there's a little bit of concern

here.

MR. HAWKINS: That has to be an error.

That's not what we agreed to.

Jack, can you help on that one?

MR. JONES: While he's researching that, 

believe, unless someone here would like to say

differently, that we, as a body, agree to the 14, 47

39 numbers, that are presented to the AHAM group, an

we were in disagreement on the warm rinse number.

The changes to the test procedure should

have reflected 14, 47, and 39.

Would you like for me to wait for Jack to

pull his notes or go on with the next chart, or do

you have other questions, Marc?

MR. LaFRANCE: Well, let me say that the

final version that I received, they were the numbers

that you agreed to, and I want to get the basis of

that, and here you're providing the basis but they'r

just numbers.

I think these numbers here are much close

to the linear regression to the year 1994, '95,

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

EE-RM-94-230 COMMENT 0C
1 versus projecting into '99. They were very, very

2 close, within two percentage points, for the warm

3 versus hot.

4 Now, here, we get a larger variation vers

5 the NIST regression, and it's because of the

6 projection to the year '99.

7 MR. JONES: That's correct.

8 MR. LaFRANCE: I guess we'll address that

9 Obviously, we've had a concern about that, and that

10 still our position.

11 AUDIENCE: Jack, according to our notes,

12 Larry is correct.

13 MR. JONES: Larry is correct. Yes, yes.

14 These were the prior ones. Thank you.

15 Would you make a note of that, Marc, that

16 these are the correct numbers.

17 MR. LaFRANCE: Right.

18 MR. JONES: You realize, as Larry said, w

19 are only speaking for AHAM respecting the medical

20 column.

21 MR. HAWKINS: And we're speaking for

22 ourselves respecting the warm rinse column, or the

23 rinse cycle factors. 

~ .... ..... -- -

EE-RM-94-230 COMMENT 0C
1 MR. LaFRANCE: Since you're talking about

2 the rinse column, I know that the final version has 

3 range for the warm rinse.

4 MR. HAWKINS: Yes, sir.

5 MR. LaFRANCE: Okay. Obviously, AHAM is

6 supporting the range and various companies support

7 one number or the other, and you've just expressed

8 that you support this particular number, the 21.

9 Now, I would imagine that there are

10 companies that support the 33 percent.

11 Through AHAM, or obviously from General

12 Electric, you've just provided the rationale for 21.

13 So if AHAM could provide the rationale, or maybe not

14 AHAM but other companies provide the rationale for

15 the 33, we would appreciate that so we can assess

16 both numbers or any number in between.

17 MR. HAWKINS: I had as a backup chart;

18 again, just in case there is confusion, I think most

19 people in doing any data analysis is familiar with

20 regression techniques. I'm not sure that everyone

21 followed the differencing technique.

22 This chart, which we will leave for the

23 record, reflects how that is done. The hot wash

EE-RM-94-230 COMMENT 0C
1 column, you see the raw data from P&G. The next

2 column over says Year to Year. It's where the

3 prevailing year is subtracted from the previous year

4 and carried down to an average, and then that averag

5 is used to incrementally project into the future,

6 1994 data being 16 percent, had .5 percent subtracte

7 away to get 15.5 and so forth. We will leave this

8 for the record. That supports the Summary chart.

9 MR. LaFRANCE: Okay, great.

10 Also, are you aware of when P&G's summary

11 will be complete for 1995, when that will be

12 available? Because, here, you have a projection for

13 '95, and it's just curious to see what the actual

14 results will be for '95.

15 MR. HAWKINS: Can I get some help, Ron?

16 MR. JACOBSON: We are moving to running

17 this data on a two-year basis. I believe there will

18 be no data for '95, there will be for '96.

19 MR. LaFRANCE: I'm sorry to hear that.

20 Thank you.

21 MR. JONES: Everybody has cost concerns.

22 MR. HAWKINS: Okay. If I may, I'd like t

23 shift gears to another topic you talked about, and 

EE-RM-94-230 COMMENT 0C
E.d ± QCONSUMER TEMPERATURE

USAGE DATA ANALYSIS

USING DIFFERENCING TO ELIMINATEAUTOCORRELATION

SURVEY Hot Wash Warm Wash Cold Wash Warm Rinse

YEAR DATA YR to YR DATA YR to YR DATA YR to YR DATA YR to YR

1975 27 __50 __23

1978 23 51 26 38

1981 21 -2.00 52 1.00 27 1.00 32 -2.00

1982 19 -2.00 52 0.00 29 2.00 30 -3.00

1983 19 0.00 54 2.00 27 -2.00 27 3.00

1984 19 0.00' 53 -1.00 28 1.00 30 -3.00

'1985 19 0.00 53 0.00 28 0.00 27 0.00

1986 18 -1.00 55 2.00 27 -1.00 27 -3.00

1987 17 -1.00 57 2.00 26 -1.00 24 0.00

1988 17 0.00 56 -1.00 27 1.00 24 2.00

1989 19 2.00 51 -5.00 30 3.00 26 -4.00

1990 18 -1.00 51 0.00 31 1.00 22 1.00

1991- 16 -2.00 49 -2.00 35 4.00 23 -2.00

1992 16 0.00 51 2.00 33 -2.00 21 -1.00

1993 14 -2.00 50 -1.00 36 3.00 20 -2.00

1994 16 2.00 48 -2.00 36 0.00 18 -1.08

1995 15.50 47.79 36.71 13.69

1996 15.00 47.57 37.43 13.69

1997 14.50 47.36 38.14 13.69

1998 14.00 47.14 38.86 13.69

1999 13.50 _46.93 _39.57 12.62

YR to YR Averages: -0.50 -0.21 I 0.71

Normalize Wann Rinse based on Market Mix

12.62/0.60 = 21.03 IA

0.71

TABLE-5.XLS

EE-RM-94-230 COMMENT 0C
1 believe the Curt Reichman also talked about, from a

2 question asked. This talks about RMC.

3 We believe that based upon the desire to

4 develop a linkage between clothes washer energy

5 consumption and RMC measurements of the load coming

6 out of the washer, we would like to present and

7 discuss some of the design parameters alternatives

8 for reaching lower RMC numbers and also state what w

9 feel to be some concerns with some of the methods

10 used.

11 As this chart presents, we know of at lea

12 4 parameters that are available to us as design

13 alternates for decreasing the RMC value, one being t

14 increase the spin speed, which most people are aware

15 of; another is to increase the spin time.

16 We also are aware that increasing the loa

17 size and/or increasing the basket diameter to

18 increase capacity will reduce the RMC.

19 We have data that says there is a

20 relationship between increasing rinse temperature an

21 decreasing RMC.

22 When we look at spin speed, we see that

23 there are limitations there with conventional dry

EE-RM-94-230 COMMENT 0C
t·FJ- 2

PARAMETERS AFFECTING R.M.C. |

U

ON1 40

Spin Speed

* 55% to 50% with traditional drive

system ... 600 rpm to 660 rpm

* 50% to 40% will require drive sys/

tub/basket redesign.with OOB

control to achieve high spin speed.

· Below 40%° is.unknown territory

including clothes damage potential

Spin Time ----

* Incremental improvement

with timer change.

* Consumer dissatisfaction

if time is extended too long.

* Diminishing returns limits

any significant improvement.

* Opportunity for electronics?

Load Size -.-

* Larger capacity basket

provides improvement

* Bigger diameter basket also

improves water extraction.

* Increased wrinkling likely.

Rinse Temp---

* Biggest wild card to us.

* TradeofFs between EC

and RMC possible.

* Exact characteristics

and interactions with

other factors must be

studied.

* Impact of higher spin speeds on clothing damage is big unknown ... issue raise at recent

HL Technology Conference, including AHAM, SDA, & AATCC .. no one had experience.

* P&G also stated same clothing damage concern, wrinkling issues,etc in their ANOPR comments.

* High spin speed in foreign products usually done only forshort time periods and regl benefits

achieving real low water extraction (below 45%) are not being experienced.

* Wrinkling & clothes care issues dictate consumer selectable spin speed options...will require

discounting RMC credit. .LLH 7/1019

@3

U

0

.U

*

LsasmsearacacreBs8ase,

*

EE-RM-94-230 COMMENT 0C
1

1 systems that you can more than likely get in the 50

2 to 55 percent range and not go much below there

3 without design modifications.

4 Some of these design modifications have

5 significant implications to the washer design itself

6 meaning that we would have to redesign the drive

7 transmission to a basket system and possibly provide

8 an out of balance device to protect consumer and

9 washer against the higher spin speeds.

10 We have noted that from the data that we'

11 collected, that we know of no one getting below 40

12 percent; have not really seen data below 45, but we

13 think that's in a territory that is really unknown

14 what it would take to get there from a spin speed or

15 the implications that would be inherent in trying to

16 get there through spin speed.

17 Spin time is possible. It has diminishin

18 returns, it also has customer dissatisfaction issues

19 If you go too long in cycle time to try to achieve

20 lower RMCs, so while some opportunity, it's limited.

21 You could use electronics to get the

22 optimum out of it but there's cost associated with

23 that.

EE-RM-94-230 COMMENT 0C
1 Load size and basket capacity will lead t

2 lower RMCs, but there's also issues there with

3 wrinkling and other clothes care concerns.

4 To us, anyway, we're not sure of the true

5 relationship between rinse temperature and extractio

6 levels; how far you can go with that, how much

7 penalty you would pay, or warm water rinse, to raise

8 the rinse temperature. So it may provide benefits

9 and lower RMC, but not provide true energy saving

10 benefits.

11 In summary, we'd like to say that the

12 impact of higher spin speeds on clothing, damage and

13 clothing issues is an issue to us. It's also an

14 issue that we don't believe there's many people in

15 the field that it can address.

16 We know for sure that it was asked at a

17 recent conference, including AHAM, soap detergent

18 manufacturers, and the textile manufacturers. No one

19 at that conference could provide any concrete data o

20 information to help in that understanding.

21 We are aware that Proctor & Gamble also h

22 reflected similar kind of concerns in their comments

23 earlier this year.

EE-RM-94-230 COMMENT 0C
1 We think that when you look at all of the

2 potential issues from a clothes care consumer

3 satisfaction level that, at least in the interim, we

4 as manufacturers don't foresee that we would be able

5 to come forward with some of these options,

6 especially spin speed, without offering a consumer a

7 switch to deselect high spin speed, and we believe

8 that would require some discounting of the RMC

9 credit.

10 That was not discussed with AHAM, that I'

11 aware of, or with any AHAM group. That's our

12 position that if you had a switch, you'd have to

13 provide some kind of a discounting credit for RMC.

14 MR. JONES: These are sort of cautionary

15 points, Marc, I think, because what is implicit in

16 the request for information on the standard and the

17 way the test procedure is sort of laid out, is that

18 RMC is like a panacea. I guess our only point here

19 is that we should not assume that industry is capabl

20 and that consumers will be willing to accept ever

21 increasing, or rather lower RMC numbers, and until

22 those issues are resolved .for DOE to proceed on the

23 assumption that we can get there, is a great risk.

EE-RM-94-230 COMMENT 0C
1 MR. LaFRANCE: Could you elaborate on

2 Mr. Reichman's statement relative to the option? I

3 believe, to paraphrase what he said, was something 

4 do with, the manufacturer would recommend a certain

5 say, spin speed or RMC, and you mentioned the

6 selectable.

7 Obviously, these other parameters would b

8 maybe you could control the time and the spin speed

9 by one knob that would say lower RMC, or whatever yo

10 would label it on the machine.

11 Mr. Reichman had mentioned that that woul

12 be something that the literature would recommend,

13 that a particular setting be used, and that's what's

14 being recommended for the MEF test. That would be o

15 the energy test, like for cotton and linen.

16 So if a machine -- and this is

17 hypothetically speaking now -- were to have some typ

18 of knob that said lower arm, which included time and

19 speed, then is that something that you would normall

20 put in your literature?

21 In other words, if you could, maybe in yo

22 written comments, explain the differences between hi

23 statements and your statements as to the concern

EE-RM-94-230 COMMENT 0C
1 about whether we should have some type of factor for

2 the selectable RMC provision.

3 MR. HAWKINS: Okay. We can follow-up in

4 our comments on that, but we do believe that, with

5 the limited knowledge that we have now of the

6 clothing issues associated, especially when you're

7 trying to get to the kinds of RMCs, like in some of

8 the design options, we foresee that, yes, there woul

9 be clothing damage issues that to provide consumer

10 satisfactory performance, we would have words in the

11 use and care advising them when and how to use them

12 and an option to bypass them. We can provide more

13 data.

14 MR. LaFRANCE: You also provided here the

15 chart showing the load size, how RMC decreases with

16 larger load size. I guess that's somewhat of a

17 concern because the AHAM presentation said that, I

18 guess probably from a manufacturer standpoint, that

19 to test the RMC level with one load being the maximu

20 load, and it does reduce test burden.

21 But if you could provide some type of

22 empirical data on this that would show, that would

23 quantify, the slope of that line, because if it's a

EE-RM-94-230 COMMENT 0C
1 minimum amount -- it does decrease but it's

2 minimal -- then maybe the concern for test burden

3 would certainly outweigh the need for additional

4 testing, but if the credit it significant -- I

5 shouldn't say credit, but if the RMC level increases

6 with the smaller load size, then possibly the tests

7 should be conducted with an average size load, which

8 is reflective of consumers' wash habits, they

9 traditionally use average more than maximum.

10 So, in other words, possibly the MEF for

11 AHAM might be providing too big of a credit if that

12 slope is large. If you have any information to back

13 up, to provide that point, even on a confidential

14 basis, we would be interested in receiving it, as

15 well as AHAM data or other manufacturers.

16 If they have any information at all, to

17 define what the slope of that line is, we would

18 appreciate it.

19 MR. HAWKINS: Okay. Any other questions 

20 comments?

21 [No response.]

22 MR. HAWKINS: I have one final chart to g

23 throuah.

EE-RM-94-230 COMMENT 0C
1

1 Let me say at the outset that this is aga

2 a GPA chart, and this has not had review within the

3 industry. That is Exhibit A in our comments

4 submitted earlier to yourselves.

5 We are proposing that, with the Table 5.1

6 that's in the AHAM test procedures, that sets out an

7 increasing or decreasing, as you would, load size

8 based upon capacity of the washer, that it also

9 provides the utility to now talk about the total

10 cycles per year on a capacity basis as well.

11 This chart speaks to that subject. It's

12 one way of looking at how you might go about doing

13 that.

14 The way the column was created on this

15 chart was to take the P&G data, which we had

16 available to us; the average load size data, the

17 average cycles per year data, to mathematically then

18 calculate a total pounds of laundry washed per year

19 on the average for standard size washers.

20 Then using the average load size from

21 Table 5.1 of the test procedures, to come up with th

22. adjusted annual cycle that is shown on this chart.

23 So that instead of calculating the energy

EE-RM-94-230 COMMENT 0C
Exhibit A

TABLE 5.1 TEST LOADS and ADJUSTED ANNUAL CYCLES

-V

DEFINITIONS:

1. P&G Average Load size (AL): Regular washers = 5.7 lbs

Laree washers = 6.7 Ibs

Combined average = 6.2 Ibs

2. P&G Average number of wash Cycles per year (AC): 392

3. Average Pounds of Laundry (APL) per year: APL = (AL*AC) = 2430

4. Average Load Size (ALS) is shown in Table 5.1 above

5. Adjusted Average number of Cycles per year (AAC): AAC = APL / ALS

This is the annual number of laundry cycles per year, after adjustments

are made for washer capacity. This value is used to calculate the annual

cost of operation.

TABLE-5.XLS

Test Load Sizes

Minimum Maximum Average 4

3.0 3.0 3.00

3.0 3.5 3.25

3.0 3.9 3.45

3.0 4.3 3.65

3.0 4.7 3.85

3.0 5.1 4.05

3.0 5.5 4.25

3.0 5.9 4.45

3.0 6.4 4.70

3.0 6.8 4.90

3.0 7.2 5.10

3.0 7.6 5.30

3.0 8.0 5.50

3.0 8.4 5.70

3.0 8.8 5.90

3.0 9.2 6.10

3.0 9.6 6.30

3.0 10 6.50

3.0 10.5 6.75

3.0 10.9 6.95

3.0 11.3 7.15

3.0 11.7 7.35

3.0 12.1 7.55

3.0 12.5 7.75

3.0 12.9 7.95

3.0 13.3 8.15

3.0 13.7 8.35

3.0 14.1 8.55

3.0 14.6 8.80

3.0 15 9.00

3.0 15.4 9.20

EE-RM-94-230 COMMENT 0C
1 consumption to product in a manner that we do now,

2 using a fixed 392 cycles per year, it would reflect

3 what we believe is the real usage pattern that large

4 machines will do fewer loads, smaller machines will

5 do more loads, to do the effectively same amount of

6 laundry.

7 MR. LaFRANCE: Could you explain how this

8 would be produced, what type of application you woul

9 use this for? Would it be for a standard analysis 

10 would it be for the labeling?

11 I believe the FTC is in the process of

12 getting away from dollar labels and providing

13 efficiency labels.

14 MR. HAWKINS: Okay. This was intended to

15 be a replacement for the 392 cycles that's used to

16 calculate the label value, to try to at least put al

17 units on a level playing field from the annual cost

18 of operation.

19 MR. LaFRANCE: Right. So even if it's no

20 used by FTC, at least you're proposing to put it in

21 the test procedure, so that if anybody wants to

22 calculate how much energy it's going to cost me to

23 run this particular washing machine, you would have 

EE-RM-94-230 COMMENT 0C
Extrapolation

Time

Time

EE-RM-94-230 COMMENT 0C
1 provision to do that, based on capacity?

2 MR. HAWKINS: That is correct.

3 MR. LaFRANCE: But from a standard analys

4 standpoint, it wouldn't really matter, because we're

5 using a ship weighted average in a certain number of

6 cycles, and if you were to increase the capacity and

7 decrease the cycles, or vice versa, it would still

8 come up with the same amount of average, annual

9 consumption, or average cost per year, I should say.

10 So from an analysis standpoint, I don't

11 think it matters and possibly from an FTC standpoint

12 it might not matter, however, you're making the

13 presentation that if somebody wants to look at the

14 actual cost to run a particular washing machine, the

15 there should be a provision made for the capacity?

16 MR. HAWKINS: That's correct.

17 MR. LaFRANCE: Okay.

18 MR. JONES: Just as DOE is facilitating

19 other, if you will, external uses of its data, this

20 is the one that we would suggest as well; whether

21 it's water, whether it's RMC, whether it's some othe

22 purpose. If you all are going to be the keepers of

23 information as it relates to appliances, then make i

EE-RM-94-230 COMMENT 0C
1 complete and have it useful for all people for all

2 purposes.

3 MR. HAWKINS: Thank you.

4 MR. LaFRANCE: Thank you.

;5 MS. WATSON: Gene, do you have any

6 questions?

7 MR. MARGOLIS: No questions.

8 MS. WATSON: Jim.

9 MR. KAO: I just have one comment about t

10 numbers. I guess we have different opinions. we

11 don't agree that they should be projected five years

12 from--.

13 MR. HAWKINS: Okay.

14 MR. JONES: I guess I'd like to ask a

15 question. What's the basis of your disagreement? I

16 mean, it's all well and good to say you disagree, bu

17 what's the basis of your disagreement? At least --

18 MR. KAO: It just won't project beyond th

19 data you have.

20 MR. JONES: You're saying that as a matte

21 of statistical validity, one never does that or you

22 don't do that?

23 MR. KAO: Yes. People prolected $50 7 barr

EE-RM-94-230 COMMENT 0C
1 oil some years ago, never got to that.

2 MR. JONES: So you believe it's more

3 appropriate, then, to assume that in 1999 we'll be

4 exactly where we are in 1994?

5 MR. KAO: Well, use whatever data we have

6 or you have.

7 MR. HAWKINS: Yes. We would propose that

8 in fact, when you want to acknowledge it, you're

9 going to be extrapolating one form or another, and

10 that's represented by this chart here.

11 If you stop the data in 1994 and you talk

12 about 1999, then you are, in fact, extrapolating the

13 hockey stick curve. You're extrapolating that it's

14 going to stay the 'same right on out through time.

15 If you follow the technique that we are

16 proposing, then you would do it like the curve on th

17 right and it projects following the trend that's bee

18 established from a long period of time, '81 through

19 '94, as continuing on.

20 We would suggest that the error in where

21 you would wind up would be less with the right

22 process than it would be with the left.

23 MR. KAO: I understand your point, but if

EE-RM-94-230 COMMENT 0C
1 you keep the same reasoning, you may have a negative

2 project in the future.

3 MR. JONES: We made provisions for exactl

4 that, to discount that possibility. I think that wa

5 explained before. Maybe we ought to go back through

6 that again if that point wasn't adequately understoo

7 or made.

8 MR. HAWKINS: Yes. We looked at using

9 nonlinear regression to see where that point would

10 be, as well as linear regression, as well as a

11 differencing method. In fact, we found close

12 agreement among the three techniques.

13 We chose to use a differing method becaus

14 it was statistically more valid to eliminate the aut

15 correlation.

16 MR. JONES: Is there another method which

17 DOE suggests, or NIST suggests, is more appropriate,

18 or is it just that you don't believe in

19 extrapolation; extrapolation other than continuity?

20 MR. LaFRANCE: I think we received your

21 comments and we need to consider them, and we also

22 will consider other people's comments on this

23 particular point.

EE-RM-94-230 COMMENT 0C
1 I guess, what are some of the reasons why

2 the temperatures have come down over time? I would

3 imagine that they have to do with developments with

4 detergent and also on consumer preference.

5 But, now, consumers use hot water for mos

6 soiled loads. For example, diapers. Now, there's a

7 fixed number of diapers, and maybe fluctuates more

8 from population or whatever, but basically there's a

9 fixed amount of soiled loads. Is it really going to

10 continue on that same exact slope?

11 I'm not a statistician, so I really can't

12 answer this question, obviously, but I guess if we

13 could learn more about what are the reasons why the

14 temperatures have come down, and if we could make

15 some type of subjective opinion as to whether those

16 type of things will continue; in other words, if it

17 based on detergent advancement, then possibly we

18 could learn from the detergent manufacturers if they

19 expect that to continue, or if it's based on the

20 types of fabric that's available in the marketplace,

21 more use of permanent press versus other types of

22 things. I don't know.

23 But if we learn more about that, maybe we

EE-RM-94-230 COMMENT 0C
1 could, in addition to looking at it from a purely

2 analytical standpoint, being the projection or

3 nonprojection, maybe there's somebody else that coul

4 give us additional information that could maybe have

5 more merit versus the other.

6 MR. HAWKINS: Yes, possibly.

7 MR. JONES: That's a valid point. In fac

8 we assume that the detergent manufacturers are as

9 good as they have been to date, and they will

10 continue their advances in use of cold water toleran

11 detergents, increasing use of liquids; that fabrics

12 become more and more cold water friendly.

13 The use of natural dyes is increasing, an

14 therefore the need for more clothes care, as usually

15 the case with cold water.

16 I'm not sure that there's a fixed number 

17 diapers, Marc. I have a feeling that that number is

18 actually declining, and people go for plastic, I'm

19 sure. Some of our P&G friends would support that,

20 too, for other reasons.

21 But, again, and I appreciate Mr. Kao's

22 point, that you can't project forever, but a valid

23 statistical analysis can take these things into

EE-RM-94-230 COMMENT 0C
1 account and begin possibly to flatten that curve out

2 somewhat, so it doesn't get to zero.

3 That's an issue, I guess, for the

4 statisticians, but there should be doubt about the

5 fact that that is technically possible to be done,

6 and that's where the design station. If you all

7 believe in design, as I understand your design

8 options to say, then I would suggest you take a look

9 at this more appropriate approach.

10 We'll put this in the record, too.

11 Can I ask you all if it would be

12 appropriate to continue the same exhibit numbers, so

13 if submitted A and B, we just number these C, D, and

14 E, or does it matter?

15 MR. LaFRANCE: That would be fine.

16 MR. JONES: Thank you.

17 MR. LaFRANCE: Thank you.

18 MS. WATSON: Thank you.

19 MR. JONES: Thank you.

20 MS. WATSON: There has not been any

21 unscheduled speakers.

22 Are there any rebuttal statements?

23 [No response.]

EE-RM-94-230 COMMENT 0C
1 Are there any other questions?

2 MR. ANDERSON: I'd just like to make one

3 comment.

4 MS. WATSON: Could you come forward and

5 state your name and who you represent.

6 MR. ANDERSON: Vince Anderson from

7 Whirlpool. Just a brief comment in response to one

8 of the things that my peers from GE commented on, a

9 far as the consumer selection of spin speed issue,

10 that is addressed in the AHAM test procedure,

11 paragraph 2.1.1, where it's stated in there that the

12 test procedure would be to use the energy test cycle

13 consistent with comments that Curt had made.

14 So I guess there's somewhat of a

15 discrepancy there, if GE supports the proposed AHAM

16 test procedure as it's written, and that includes

17 Section 2.1.1.

18 On the other hand, if they think there

19 ought to be a factor in there for the selection of a

20 higher or lower spin speed, that's an inconsistency

21 there.

22 I would just like to point out that the

23 position that Curt stated is consistent with the AHA

EE-RM-94-230 COMMENT 0C
1 test procedure.

2 That's it.

3 MS. WATSON: Thank you.

4 Are there any more statements to make abo

5 any other products?

6 [No response.]

7 MS. WATSON: I would like to take this ti

8 to thank you again for coming and making your

9 statements. They will be fully evaluated in

10 establishing our final rule.

11 I would like to ask that each of you that

12 spoke, if you haven't, leave a copy of your statemen

13 and any presentations on the vugraph that you

14 presented today.

15 Did any other member panel have closing

16 remarks?

17 [No response.]

18 Okay. This hearing is closed.

19 (Whereupon, the hearing was closed.)

20

21

22

23

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