EE-RM-TP-99-500 COMMENT 14

I 1S~~::::;;i2l Barbara Twigg 

01/30/2002 02:29 PM 

Barbara Twigg 

12/19/0104:15 PM 

Dear Dishwasher Stakeholders: 

-#14 

To: Brenda Edwards-Jones/EE/DOE@DOE 

cc: 

Subject: New report on dishwasher consumer use-- and DOE request for 

informal comments 

To: Timothy-Bernadowski@VAPOWER.com, JCockbur@NRCAN.GC.CA, 

Melhc@essential.org, Dan_Barzel@ccnotes.ccity.com, 

cc: 

H Carter@Energy.commerce.state.nc.us, Natascha/castro@NIST.gov, 

Don.MDasher@BGE.com, rdupont@amp.com, gfoley@aham.org, 

glakepe@cldc.howard.edu, teckman@nwppc.org, 

Tim_feldman@NEMA.org, charlfcs@eei.org, dgoldstein@nrdc.org, 

JHardin@aarp.org, mhewett@mncee.org, bhiggens@pmihome.org, 

mhoffman@ceeformt.org, w.holmes@awwa.org, bkkalish@apga.org, 

tleland@ari.org, mmartin@energy.state.ca.us, 

Steven_nadel@aceee.org, eosann@aceee.org, mkrebs@il.net, 

jmattingly@gamanet.org, wMorris@aham.org, nemtzow@ase.org, 

bprindle@ase.org, Casamuels@mintz.com, 

mike_scott@homedepot.com, pat.stanton@state.ma.us, 

stevercm@eei.org, empainc@aol.com, douglas.smith@ferc.fed.us, 

charles.m.stephens@state.or.us, jwilson@energy.state.ca.us, 

loggias@csa.ca, hnewsome@ftc.gov, 

MichaeLc_thompson@email.whirlpool.com. nunlca@consumer.org, 

connma@consumer.org, Edward Poliock/EE/DOE@DOE, Qonnie 

Laughlin/EE/DOE@DOE, Michael McCabe/EE/DOE@DOE, 

bowman.j@adlittle.com, Regina Washington/EE/DOE@DOE, Carl 

Adams/EE/DOE@DOE, Eugene Margolis@HQMAIL@HQDOE, 

Francine Pinto@HQMAIL@HQDOE, rfoster@cee1.org 

Subject: New report on dishwasher consumer use-- and DOE request for 

informal comments 

The Department of Energy would like to inform you that having published a limited final rule for 

dishwashers on December 18, 2001, we are now focusing on developing a new test procedure for 

soil-sensing models. Attached is a report completed by Arthur D. Little (in two formats) evaluating 

available survey data on consumer dishwasher use and behavior, and a short summary of the kind of 

soil-based test procedure that we are considering for sOil-sensing models. Conventional dishwashers will 

still be tested using clean dishes. 

We plan to draft a Notice of Proposed Rulemaking by the end of January 2002 and hold a formal public 

workshop sometime next spring. However, we would very much like to have stakeholder reaction to our 

preliminary concept on an informal basis, as we continue to shape our proposal and decide on appropriate 

test values. 

We will also be posting these documents on our website: 

http://www.eren.doe.gov/buildings/codes_standardslindex.htm . 

Please e-mail any comments that you may have to me at this address, Barbara Twigg @ee.doe.gov by 

January 24, 2002. We would also be happy to meet with any of you that would like to discuss these 

issues in greater depth. My phone number is 202/586-8714. 

Thank you very much for your continued interest and participation in the dishwasher test procedure 

rulemaking process. 

Sincerely, 
EE-RM-TP-99-500 COMMENT 14

Having published on December 18, 2002, a final rule for dishwashers to improve the reliability 

of testing, change the definition of compact and standard models, and reduce the number of use 

cycles per year to 264, the Department of Energy is now working to develop a new test procedure 

for soil-sensing dishwashers. We received on December 12,2001, a report from Arthur D. Little 

evaluating available survey data on consumer dishwasher use. Based on that report, we are 

considering the following elements as part of a new test procedure proposal. It is anticipated that 

a Notice of Proposed Rulemaking, based on a soiled test method, will be published this spring. 

1. For conventional dishwashers, to maintain the current clean load test method. 

2. For soil-sensing dishwashers, to develop a soil-based test to approximate the varied soil 

loads that consumers run. Requiring that, 

• the energy consumption be measured for three soil tests of decreasing soil level to 

represent "heavy", "medium", and "light" soil loads, where the level of soil is 

determined from data on consumer dishwasher use and the method of soiling is 

bas~d on the AHAM test method. (e.g., simulating a "light" soil load with one 

AHAM soiled place setting plus eight clean place-settings and 6 clean serving 

pieces) 

• the overall energy consumption value for the dishwasher be obtained by means of 

a weighted average of the three test values, based on the percentage of time 

consumers run "heavy", "medium", and "light" soil loads. 

• the Estimated Annual Operating Cost be obtained in the same method as 

conventional dishwashers 

• both current and future soil-sensing models be tested using the soil-based test 

procedure. 

3. F or all dishwashers, to revise the estimated annual dishwasher use based on more recent 

survey results. 

4. For all dishwashers, to require the measurement of the stand-by power and incorporate 

this form of energy consumption into the annual energy use, rather than measuring and 

reporting stand-by power as a separate value.