1 | Test Procedures for Microwave Ovenseere.energy.govTest Procedure for Microwave OvensStandby Power SupplementalNotice of Proposed Rulemakingand Active Mode Public MeetingWes AndersonBuilding Technologies ProgramOffice of Energy Efficiency and Renewable EnergyU.S. Department of EnergySeptember 16, 2010The Parker Ranch installation in HawaiiIntroductionPurpose of the Test Procedure Public MeetingPresent the Department’s proposed standby and off mode testprocedures for microwave ovenSeek comment from participants on the proposed test proceduresDiscuss specific issues or questions related to the proposalDiscuss the next steps for the standby power rulemakingDiscuss steps to initiate a new active mode test procedurerulemaking for microwave ovens.2 | Test Procedures for Microwave Ovenseere.energy.govIntroductionStandby Power Test Procedure SNOPR3 | Test Procedures for Microwave Ovenseere.energy.govIntroductionSteps in the Microwave Oven Standby Power Test ProcedureNOPRSNOPRRulemakingFinalRuleNOPR issued by DOE on October 1, 2008 (NOPR Public Meeting onNovember 14, 2008)SNOPR issued by DOE on July 22,2010 (SNOPR Public Meeting today,September 16, 2010)4 | Test Procedures for Microwave Ovenseere.energy.govIntroductionSteps in the Microwave Oven Standby Power Test ProcedureNOPRSNOPRRulemakingFinalRuleComments on SNOPR from interested parties•Transcript records oral commentsfrom today’s public meeting•Written comments (comment period closes October 4, 2010)DOE reviews and considers all commentsFinal Rule Publication•In accordance with the Energy Policy and Conservation Act (EPCA), asamended by Energy Independence and Security Act of 2007 (EISA 2007), DOEis required to publish a final rule addressing standby mode and off mode energyconsumption in the test procedure formicrowave ovens by March 31, 2011.5 | Test Procedures for Microwave Ovenseere.energy.govIntroductionStandby Power Test Procedure Overview and Issues1.Products Covered by theTest Procedure Changes2.Effective Date for the Test Procedure3.Measures of Energy Consumption4.Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and OffMode Power in Microwave Ovens5.Definitions of “Active Mode”,“Standby Mode”, and “Off Mode”6.Specifications for the TestMethods and Measurements for Microwave Oven StandbyMode and Off Mode Testing7.Compliance with Other EPCA Requirements6 | Test Procedures for Microwave Ovenseere.energy.govIntroductionRegulatory HistoryThe Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.) setforth criteria and procedures for DOE’s adoption and amendment oftest procedures for covered products.Historically, DOE’s test procedure for microwave ovens appeared atappendix I to subpart B of Title 10 of the Code of Federal Regulations.That test procedure was part of an October 3, 1997, final rule that alsorevised the test procedures forother cooking products to measuretheir efficiency and energy use more accurately.•Incorporated by reference portionsof IEC Standard 705-1998 and Amendment2-1993,Methods for Measuring the Performance of Microwave Ovens forHouseholds and Similar Purposes.•Did not address measures of standby oroff mode energy use for microwaveovens.7 | Test Procedures for Microwave Ovenseere.energy.govIntroductionRegulatory History – ContinuedEISA 2007 Amendments to EPCA (42 U.S.C. 6291**et seq**.)•Directs DOE to incorporate a measure of standby andoff mode energyconsumption into its microwave oven test procedure by March 31, 2011.Microwave Oven Test Procedure Notice of Proposed Rulemaking(Issued on October 1, 2008, referred to as the October 2008 TP NOPR)•DOE proposed incorporating provisionsfrom IEC Standard 62301 into the DOEactive mode test procedure,as well as language to clarify application of theseprovisions for measuring standby mode and off mode power in microwaveovens..•Interested parties commented on, among other things, the harmonization ofmode definitions and testing procedures withthe rest of the world, in particularthe consideration of IEC Standard 62301 Second Edition.8 | Test Procedures for Microwave Ovenseere.energy.govIntroductionDetermination to Continue Test Procedure RulemakingAfter the October 2008 TP NOPR, DOE decided to allow for theconsideration of a revised version of IEC Standard 62301, which wasexpected to be published in July 2009.•Based on review of drafts of theupdated IEC Standard 62301, the revisionscould include different mode definitions.DOE later received information that IEC Standard 62301 SecondEdition is not expected to be published until late 2010.•EPCA requires DOE to establish testprocedures for standby and off mode byMarch 31, 2011.•DOE is conducting a concurrent energy conservationstandards rulemaking forstandby and off mode energy use.As a result, DOE published this SNOPR to consider the new modedefinitions from the most recent draft version of IEC Standard 62301Second Edition.•The most recent version at the timeof the SNOPR was designated as IECStandard 62301 Committee Draft for Vote (IEC Standard 62301 CDV).•Since then, the Final Draft International Standard (FDIS) was issued.9 | Test Procedures for Microwave Ovenseere.energy.govIntroductionRepeal of Regulatory Provisions for Microwave OvenCooking EfficiencyDOE repealed the regulatory provisions establishing the cookingefficiency test procedure for microwave ovens under EPCA in a finalrule published on July 22, 2010.•DOE determined that the microwave oven test procedure provisions to measurecooking efficiency do not produce accurate and repeatable test results.•Unaware of any test procedures thathave been developed that address theconcerns with the DOE microwave oven cooking efficiency test procedure.DOE also published a notice of a workshop on today, September 16,2010, to discuss a separate rulemaking process to establish newprovisions for measuring microwaveoven energy efficiency in active(cooking) mode.10 | Test Procedures for Microwave Ovenseere.energy.govTest Procedure Overview1.Product Covered by theTest Procedure Changes2.Effective Date for the Test Procedure3.Measures of Energy Consumption4.Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and OffMode Power in Microwave Ovens5.Definitions of “Active Mode”,“Standby Mode”, and “Off Mode”6.Specifications for the TestMethods and Measurements for Microwave Oven StandbyMode and Off Mode Testing7.Compliance with Other EPCA Requirements11 | Test Procedures for Microwave Ovenseere.energy.govCovered ProductsProducts Covered by this Test Procedure Rulemaking10 CFR 430.2 defines “microwave oven” as “a class of kitchen rangesand ovens which is a household cooking appliance consisting of acompartment designed to cook or heat food by means of microwaveenergy.”DOE stated in the October 2008 TP NOPR that the proposedamendments cover all microwave ovens for which the primary sourceof heating energy is electromagnetic (microwave) energy.•Included microwave ovens with and without thermal elements (designed forsurface browning of food).•Did not include the following:–Combination ovens - ovens consisting ofa single compartment in which microwaveenergy and one or moreother technologies, such asthermal or halogen cookingelements or convection systems,contribute to cooking the food.–Microwave/conventional range– classified by DOE regulations, has separatecompartments or components consisting of a microwave oven, a conventional oven,and a conventional cooking top.•DOE requested data on the efficiency characteristics ofcombination ovens inthe November 2007 ANOPR, but did not receive any information.12 | Test Procedures for Microwave Ovenseere.energy.govCovered ProductsProducts Covered by this Test Procedure RulemakingDOE received comments from interested parties in response to theOctober 2008 TP NOPR that the proposed definition for productscovered by this test procedure was unclear.•Sought clarification on the definition ofa “microwave oven” and “combinationoven” and whether combination ovens would be covered by the test procedure.DOE conducted a survey of microwave oven models currentlyavailable on the U.S. market, including countertop, over-the-range,and built-in configurations.•Fewer than 1 percent ofthe available models (1 out of 129) have thermalelements for grilling but no convection capability.•16 percent (21 out of 129)are combination units (microwave + convection andpossibly thermal elements).DOE does not believe that including microwave ovens with thermalelements only, with or without further specification of the function ofthe thermal elements, would substantially affect the number or scopeof covered products in this rulemaking.13 | Test Procedures for Microwave Ovenseere.energy.govCovered ProductsProducts Covered by this Test Procedure RulemakingDOE proposes to include combination microwave ovens because theywould be covered products under the regulatory definition.•Combination microwave ovens are capableof cooking or heating food by meansof microwave energy.•Preliminary analysis indicates standby and off modes for combinationmicrowave ovens are comparable tothose for microwave ovens with andwithout thermal elements only.14 | Test Procedures for Microwave Ovenseere.energy.govCovered ProductsRequest for Comment: Covered Products**DOE invites comment on the proposal to clarify the definition of a “microwave oven” provided in 10 CFR 430.2 to cover microwave** **ovens with or without thermal elements designed for surface browning of food as well as co** **mbination microwave ovens (i.e., microwave ovens that incorporate convection features and possibly** **other cooking means). DOE also welcomes comment on the proposal that the same testing procedures a** **nd calculations can be applied to each of these types of microwave ovens, and whether there are** **additional standby and off modes or other product features for each particular type of microwave oven** **that would require separate testing procedures. (Issue #1)** 15 | Test Procedures for Microwave Ovenseere.energy.govTest Procedure Overview1.Product Covered by theTest Procedure Changes2.Effective Date for the Test Procedure3.Measures of Energy Consumption4.Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and OffMode Power in Microwave Ovens5.Definitions of “Active Mode”,“Standby Mode”, and “Off Mode”6.Specifications for the TestMethods and Measurements for Microwave Oven StandbyMode and Off Mode Testing7.Compliance with Other EPCA Requirements16 | Test Procedures for Microwave Ovenseere.energy.govEffective DateEffective Date for the Test ProcedureEPCA requires that the microwave oven test procedure be amendedto incorporate measurement of standby and off mode power by March31, 2011.While DOE published a NOPR on October 17, 2008 and subsequentlya final rule on April 8, 2009 for the standards rulemaking for cookingproducts (including microwave ovens), DOE determined it appropriateto consider the revised IEC Standard 62301 Second Edition, expectedin July 2009, in determining whether to adopt energy conservationstandards for standby and off mode power consumption ofmicrowave ovens.Later received information that the revised IEC Standard 62301 wouldnot be available until late-2010.DOE determined to publish this SNOPR to consider the new modedefinitions from the language in IEC Standard 62301 CDV.17 | Test Procedures for Microwave Ovenseere.energy.govEffective DateEffective Date for the Test ProcedureThe effective date of any modified microwave oven test procedurewould be 30 days after the publication of the test procedure FinalRule.The standby and off mode provisions would not need to be used untilthe compliance date of any microwave oven energy conservationstandards for standby and off mode energy use.Clarification would also be provided that, as of 180 days afterpublication of a test procedure final rule, any representations as tothe standby mode and off mode energy consumption would need tobe based upon the applicable provisions of this test procedure.18 | Test Procedures for Microwave Ovenseere.energy.govEffective DateEffective Date for the Test ProcedureInterested parties commented in response to the October 2008 TPNOPR that DOE should harmonize the effective date for standardswith the 2013 effective date for a 1-Watt (W) standard in othercountriesDOE’s determination to consider language from the draft version ofIEC 62301 Edition 2 will result in methodology and an effective datewhich are harmonized to the extent possible with certain internationalstandby and off mode standards.19 | Test Procedures for Microwave Ovenseere.energy.govTest Procedure Overview1.Product Covered by theTest Procedure Changes2.Effective Date for the Test Procedure3.Measures of Energy Consumption4.Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and OffMode Power in Microwave Ovens5.Definitions of “Active Mode”,“Standby Mode”, and “Off Mode”6.Specifications for the TestMethods and Measurements for Microwave Oven StandbyMode and Off Mode Testing7.Compliance with Other EPCA Requirements20 | Test Procedures for Microwave Ovenseere.energy.govMeasures of Energy ConsumptionMeasures of Energy ConsumptionHistorically, DOE defined several measures of energy consumptionfor microwave ovens:•Cooking efficiency•Energy Factor (EF)•Annual energy consumptionDOE’s rulemaking analyses used EF as the energy conservationmetric.DOE does not currently have a test procedure to measure standbyand off mode energy consumption for microwave ovens.For the October 2008 TP NOPR, DOE evaluated the EF to determinewhether it could be modified tomeasure standby and off modeenergy consumption.•DOE stated that it was technically infeasible to integrate the measure ofstandby and off mode energy consumption into the measure of active modeenergy consumption because ofthe variability in thecurrent cooking efficiencymeasurement from which theactive mode EF and annual energyconsumption were derived.21 | Test Procedures for Microwave Ovenseere.energy.govMeasures of Energy ConsumptionMeasures of Energy ConsumptionEPCA requires standby mode and off mode energy consumption to beintegrated into the overall energy efficiency, energy consumption, orother energy descriptor, unless the Secretary determines that—(i)the current test procedure already fullyaccounts for and incorporates standby andoff mode energy consumption; or(ii)such an integrated test procedure is technically infeasible, in which case theSecretary shall prescribe a separatestandby and off mode energy use testprocedure, if technically feasible. (42 U.S.C. 6296(gg)(2)(A))Because the test procedure does not currently address active modeenergy use for microwave ovens, the requirement to integrate standbymode and off mode energy consumption does not apply.•DOE will consider the statutory requirement to integrate thetest procedures forstandby and off mode into an active mode test procedure,where technicallyfeasible, as any active modetest procedures are developed.22 | Test Procedures for Microwave Ovenseere.energy.govMeasures of Energy ConsumptionMeasures of Energy ConsumptionDOE addressed issues with the cooking efficiency measurement inits repeal of the active mode test procedure.•DOE believes that it is infeasible to specify a food load in the test procedure atthis time. Specification of a foodload would require additional analysis andinputs from interested parties to understand what a representative food load isand how to ensure consistency in foodproperties from test to test.•DOE is unaware of any test procedures that have beendeveloped thataddress these concerns with the DOE microwave oven cooking efficiency testprocedure.•DOE is unaware of any research ordata on consumer usage indicating whata representative food loadwould be, or any data showing how changes to therepresentative test load would affect the measured EF or repeatability of testresults.For these reasons, DOE proposes only to establish the testprocedure for microwave ovens to address standby mode and offmode energy consumption in the SNOPR.23 | Test Procedures for Microwave Ovenseere.energy.govMeasures of Energy ConsumptionRequest for Comment: Cooking Efficiency Test Load**DOE welcomes comment on test procedures and methods for the active mode cooking efficiency that address the concerns with** **repeatability and consistency of test results. DOE also welcomes consumer usage data on representative food loads, as well as data** **indicating how changes to the test load would affect the measured** **EF and on the repeatability of such test results. DOE will consider such information in its separate rulemaking to develop new methods** **of measuring microwave oven active m ode cooking efficiency. (Issue** **#2)**24 | Test Procedures for Microwave Ovenseere.energy.govTest Procedure Overview1.Product Covered by theTest Procedure Changes2.Effective Date for the Test Procedure3.Measures of Energy Consumption4.Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and OffMode Power in Microwave Ovens5.Definitions of “Active Mode”,“Standby Mode”, and “Off Mode”6.Specifications for the TestMethods and Measurements for Microwave Oven StandbyMode and Off Mode Testing7.Compliance with Other EPCA Requirements25 | Test Procedures for Microwave Ovenseere.energy.govIncorporating IEC Standard 62301IEC Standard 62301 – Testing Methods and ProceduresDOE proposed in the December 2008 NOPR to incorporate the sameclauses from IEC Standard 62301 First Edition for measuring bothstandby mode and off mode power consumption.Section 4 clauses – provide conditions for:•Supply voltage, frequency, and waveform•Ambient room air temperature•Power measurement meter tolerancesSection 5 clauses:•Clarify the measurement of standby mode for units with a short-durationhigher power state before a lower power state•Provide methods for measuring standbymode and off mode power when thepower measurement is either stableor unstable (i.e., varies over arepresentative cycle).26 | Test Procedures for Microwave Ovenseere.energy.govIncorporating IEC Standard 62301Current Version of IEC Standard 62301Although IEC is in the process of developing IEC Standard 62301Edition 2, DOE considered IEC Standard 62301 First Edition thecurrent version under EPCA for the October 2008 NOPR and thisSNOPR.The SNOPR does not affect DOE’s proposal of the clauses fromsections 4 and 5 of IEC Standard 62301 identified in the October 2008TP NOPR.27 | Test Procedures for Microwave Ovenseere.energy.govIncorporating IEC Standard 62301IEC Standard 62301 – Testing Methods and ProceduresInterested parties commented that DOE should consider referencingparagraph 5.2 “Preparation of Appliance or Equipment” from IECStandard 62301 for test setup.•Paragraph 5.2 states that “[t]he applianceshall be tested at factory or ‘default’settings. Where there are no indicationsfor such settings, the appliance shallbe tested as supplied.”•The clause provides clarification to the installation requirements for standbyand off mode energyconsumption testing.•The clause provides additional guidanceregarding specifications for testsetup that would result in a measure of standby and off mode energyconsumption that is most representative of actual consumer usage.For these reasons, DOE is also proposing to incorporate byreference paragraph 5.2 of IEC Standard 62301.28 | Test Procedures for Microwave Ovenseere.energy.govIncorporating IEC Standard 62301IEC Standard 62301 – Electrical SupplyDOE received comments regarding the accuracy of the equipmentproviding electrical supply for testing and that DOE should adoptthe electrical supply requirements in IEC Standard 62301.•DOE believes that the electrical supply specifications in IEC Standard 62301,including voltage and frequency, are generally recognized as suitable forproducing robust standby and off modepower measurements in microwaveovens.For this reason, DOE proposes to incorporate by reference theelectrical supply requirements in paragraph 4.3 of IEC Standard6230129 | Test Procedures for Microwave Ovenseere.energy.govIncorporating IEC Standard 62301Request for Comment: Incorporation of IEC Standard62301**DOE invites comment on the adequacy of IEC Standard 62301 to measure standby mode and off mode power for microwave ovens in** **general, and on the suitability of incorporating into DOE regulations the specific provisions described previously. (Issue #3)** 30 | Test Procedures for Microwave Ovenseere.energy.govTest Procedure Overview1.Product Covered by theTest Procedure Changes2.Effective Date for the Test Procedure3.Measures of Energy Consumption4.Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and OffMode Power in Microwave Ovens5.Definitions of “Active Mode”,“Standby Mode”, and “Off Mode”6.Specifications for the TestMethods and Measurements for Microwave Oven StandbyMode and Off Mode Testing7.Compliance with Other EPCA Requirements31 | Test Procedures for Microwave Ovenseere.energy.govMode DefinitionsDefinition of ModesDOE proposed in the October 2008 TP NOPR to use the EPCAdefinitions of “active mode,” “standby mode,” and “off mode.”For reasons discussed previously, DOE decided to consider the newstandby, off, and active mode definitions from the draft version IECStandard 62301 CDV for the SNOPR.•New mode definitions expand uponthe EPCA mode definitions•Provides additional guidance as to whichfunctions are associated with eachmode.For these reasons, DOE is proposing standby, off, and active modedefinitions based on the definitions provided in IEC Standard 62301CDV.The proposed mode definitions remained substantively the same forIEC Standard 62301 FDIS.32 | Test Procedures for Microwave Ovenseere.energy.govMode DefinitionsDefinition of Modes – Standby ModeDOE is proposing the following definition of standby mode.•“Standby mode” means any product modes where the energy using product isconnected to a mains power source andoffers one or more of the followinguser oriented or protective functionswhich may persist foran indefinite time:–To facilitate the activation of other modes (including activation ordeactivation of active mode) by remoteswitch (including remote control),internal sensor, or timer;–Continuous functions, including information or status displays (includingclocks) or sensor-based functions.•Additional clarification that a timer isa continuous clock function (which mayor may not be associated with a display) that provides regular scheduledtasks (e.g., switching) and thatoperates on a continuous basis.DOE is not proposing that standby power be measured at “thelowest power state selectable by the user”, as recommended byAHAM, because this would potentially conflict with the requirementto test at “factory or ‘default” settings” in paragraph 5.2 of IECStandard 62301.33 | Test Procedures for Microwave Ovenseere.energy.govMode DefinitionsDefinition of Modes – Off ModeDOE is proposing the following definition of off mode.•“Off mode” means a mode which includes any product modes where theenergy using product isconnected to a mains power source and is notproviding any standby mode or active mode function andwhere the modemay persist for an indefinite time. An indicator that only shows the user thatthe product is in the off position is included within the classification of an offmode.34 | Test Procedures for Microwave Ovenseere.energy.govMode DefinitionsDefinition of Modes – On/Off SwitchDOE considered the issue of whether a microwave oven that isplugged in but not consuming energy due to the presence of anon/off switch would be in disconnected mode or off mode.DOE first reviewed the discussion provided in annex A of IECStandard 62301 CDV, which is informative only.•Section A.2 states that disconnectedmode is included as a mode definitionbecause many products areremoved by users from mains power sources forsubstantial periods of time. DOE interprets this condition to refer to the powercord being unplugged from the power source.•Section A.2 further states that “[a] product may have several off modes or itmay have no off mode. Switches on products that are labelled as power,on/off or standby may not reflect the mode classification based on the actualfunctions active in that mode.”–This statement is not definitive regarding howto treat the presence of a power oron/off switch.–However, DOE infers it to mean thatproducts equipped withsuch switches canoperate in off or standbymode(s), depending on whatcomponents may remainenergized with the switchin the “off” position.35 | Test Procedures for Microwave Ovenseere.energy.govMode DefinitionsDefinition of Modes – On/Off SwitchIn considering section A.2 in total, DOE concludes thatdisconnected mode for microwave ovens would be associated onlywith the removal of the power cord from the power source.Based on this review, DOE tentatively concludes that zero energyconsumption due to activation of an on/off switch would beindicative of off mode rather than disconnected mode.•This conclusion is a revision of DOE’s determination proposed in the October2008 TP NOPR.•Classification of an on/off switch as operating in off modein the absence ofother energy use associatedwith standby mode would encouragemanufacturers to provide such an energy-saving feature,36 | Test Procedures for Microwave Ovenseere.energy.govMode DefinitionsDefinition of Modes – Active ModeDOE is proposing the following definition of active mode.•“Active mode” means a mode whichincludes product modes where theenergy using product “isconnected to a mains power source, has beenactivated and provides one or moremain functions”, with the additionalclarification that “delay start mode isa one off user initiated short durationfunction that is associated with an active mode.”37 | Test Procedures for Microwave Ovenseere.energy.govMode DefinitionsDefinition of Modes – Active ModeIEC Standard 62301 CD2, provided additional clarification that“delay start mode is a one off user initiated short duration functionthat is associated with an active mode.”IEC Standard 62301 CDV eliminated this clarification.•In response to comments on IECStandard 62301 CD2 that led to IECStandard 62301 CDV, IEC states that delaystart mode is a one off functionof limited duration.•Suggests that IEC does not consider itas part of standby mode, although noconclusion is made as to whether it would be considered part of active modeeither.DOE is tentatively proposing to consider delay start mode as partof active mode because it is a condition of finite duration that isuser-initiated and uniquelyassociated with a cooking cycle.DOE also determined that cooking or warming of food would beconsidered active mode functions as well.38 | Test Procedures for Microwave Ovenseere.energy.govMode DefinitionsRequest for Comment: Definition of Modes**DOE seeks comment on its proposed definitions of standby mode, off mode, and active mode, which are based on the language in IEC** **Standard 62301 CDV. DOE also seeks comment on specific functions that would be classified as standby, off, and active modes. (Issue #4)** 39 | Test Procedures for Microwave Ovenseere.energy.govTest Procedure Overview1.Product Covered by theTest Procedure Changes2.Effective Date for the Test Procedure3.Measures of Energy Consumption4.Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and OffMode Power in Microwave Ovens5.Definitions of “Active Mode”,“Standby Mode”, and “Off Mode”6.Specifications for the TestMethods and Measurements for Microwave Oven StandbyMode and Off Mode Testing7.Compliance with Other EPCA Requirements40 | Test Procedures for Microwave Ovenseere.energy.govTest Methods and MeasurementsAdding Specifications for Test Methods andMeasurements for Standby and Off Mode TestingDOE noted in the October 2008 TP NOPR that IEC Standard 62301does not specify closely the test method for measuring the powerconsumption in cases in which the measured power is not stable.•Section 5.3.2 states that “[i]f the power varies over a cycle (i.e., a regularsequence of power states that occurover several minutes or hours), theperiod selected to average power or accumulate energy shall be one or morecomplete cycles in order to get a representative average value.”For the October 2008 TP NOPR, DOE investigated clarifyinglanguage that would provide accurate and repeatable testmeasurements.•DOE’s testing of standby power led it topropose the test period in cases inwhich the power is notstable as “a 12-hour ± 30-second period.”41 | Test Procedures for Microwave Ovenseere.energy.govTest Methods and MeasurementsAlternate Methods to Reduce Test Burden for Unstable PowerDOE also investigated test methods to determine standby powerover a shorter period than 12 hours.•An 18-point method was evaluated inthe November 2007 standards ANOPR:–Standby power consumptionand line voltage are measuredas the clock is cycledthrough all the possible digit combinations (in terms of active elements).–Regression analysisis performed to quantify theimpact of the number of litelements (by digit) and voltage on power consumption.–Results are then integratedacross the number of minutes that each active elementcombination is “on” throughthe course of the 12 hours.–Results were within 1 to 2 percent of the 12-hour test results.•For the SNOPR, DOE also investigated a single 10-minute measurementperiod with a starting clock time of 3:33.–The proportion of time thateach possible number of segments ina 7-segment LEDdisplay that are lit over the 10-minute time period from 3:33to 3:42 is representativeof the distributionof lit segments overa 12-hour periodwith an arbitrary startingtime.–Suggests that the 10-minutetest period starting at3:33 would produce averagestandby power measurements that arecomparable to average standby powermeasured over 12 hours.42 | Test Procedures for Microwave Ovenseere.energy.govTest Methods and MeasurementsComparison of Measurement Methods for Unstable PowerDOE conducted limited testing of 11 microwave ovens :TestUnitDisplayType12-Hour Method18-PointMethod10-Minute MethodStandby Watts*Standby Watts*% DifferenceStandby Watts*% Difference1LCD1.5671.552-0.99%1.5921.60%2LCD1.5711.560-0.70%1.554-1.08%3LCD1.8121.8120.03%1.801-0.61%4LCD1.4901.475-0.96%1.4920.17%5LCD1.8591.847-0.60%1.8740.84%6LCD3.7883.7980.26%3.8180.81%7LCD3.6413.6420.04%3.606-0.95%8LED1.8021.796-0.35%1.797-0.32%9LED1.8251.820-0.25%1.816-0.47%10LED3.1853.177-0.27%3.2903.28%**11VFD5.6005.6110.20%5.6070.13%*Standby power normalized to 120V supply power.** For this test, supply power was significantly different than 120V, so DOE doesnot believe this %difference is valid.Because data for the 10-minute method agrees with the 12-hour data within 2%, DOEis proposing, for microwave ovens for which standby power consumption is notstable, the clock display shall be set at3:33 at the conclusion of the stabilizationperiod and the test period shall be 10 minutes.43 | Test Procedures for Microwave Ovenseere.energy.govTest Methods and MeasurementsRequest for Comment: Test Cycle**DOE seeks comment on its proposed clarification to IEC Standard 62301, in which DOE specifies a test period of 10 minutes with an** **initial clock display time of 3:33 for microwave ovens for which the** **measured power is not stable, and the test burden associated with such testing requirements. (Issue #5)** 44 | Test Procedures for Microwave Ovenseere.energy.govTest Methods and MeasurementsRepresentative MeasurementsBoth the 18-point and 10-minute approaches for acceleratedstandby testing offer the possibility that a microwave oven could beprogrammed to alter its behavior when such a test is detected inorder to minimize measured standby power consumption.•Example: a microwave oven could be programmed to turn off its cookingsensors and/or dim its display only during the display timesassociated withthe 18 measurement points or between display times 3:33 and 3:42.The microwave oven test procedure is designed to provide ameasurement consistent with representative average consumer useof the product, even if the testconditions and/or procedures maynot themselves all be representative of average consumer use.DOE’s proposed language:•Makes explicit in the regulatory textthe Department’s long held interpretationthat the purpose of the test procedureis to measure representative use; and•Proposes a specific mechanism—thewaiver process—as a mandatoryrequirement for all products for which the test procedurewould not properlycapture the energy consumption during representative use.45 | Test Procedures for Microwave Ovenseere.energy.govTest Methods and MeasurementsRequest for Comment: Test Procedure Waivers forProducts for which Test Measurements are notRepresentative**DOE seeks comment on the proposed language requiring petition for** **waivers to address products equipped with controls or other features** **that modify the operation of energy using components during the energy test. DOE seeks comment on whether more specific definition** **could or should be provided to define either the product** **characteristics that would make the test procedure unsuitable for use or to define representative average use. (Issue #6)** 46 | Test Procedures for Microwave Ovenseere.energy.govTest Methods and MeasurementsTesting BurdenDOE believes the proposed test procedure would not substantiallyadd to manufacturer test burden because:•The number of units to be tested according to the sampling requirements in10 CFR 430.24(i) is reasonable.•A 5-minute stabilization period and a 5-minute or 10-minute test timedepending on whether the standby power consumption is stable or unstable,is reasonable.•It would allow manufacturers that conduct testing on the production line inorder to assure product quality to continue to do so.47 | Test Procedures for Microwave Ovenseere.energy.govTest Procedure Overview1.Product Covered by theTest Procedure Changes2.Effective Date for the Test Procedure3.Measures of Energy Consumption4.Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and OffMode Power in Microwave Ovens5.Definitions of “Active Mode”,“Standby Mode”, and “Off Mode”6.Specifications for the TestMethods and Measurements for Microwave Oven StandbyMode and Off Mode Testing7.Compliance with Other EPCA Requirements48 | Test Procedures for Microwave Ovenseere.energy.govCompliance with Other EPCARequirementsTest BurdenSection 323(b)(3) of EPCA requires thatany prescribed or amended test proceduresshall be reasonably designed to producetest results which measure energyefficiency, energy use or estimated annual operating cost during a representativeaverage use cycle or period of use and shall not be unduly burdensome to conduct.(42 U.S.C. 6293(b)(3))DOE tentatively concluded in the October 2008 TP NOPR that proposedamendments for measuring standby andoff mode power would satisfy thisrequirement.•Would produce standby and off mode power measurements that are representativefor cases when the power is stable and unstable.•Would incorporate a test standard that is widely used and accepted internationally tomeasure standby and off modepower (IEC Standard 62301).•Would not require manufacturers to make major investments in test facilities and newequipment and would not unduly burdensome to conduct.For similar reasons, DOE concludesfor this SNOPR that the proposedamendments would satisfy the EPCA requirement.•In addition, this SNOPR proposes a significantly shortertest duration than the 12hours that was proposed in the October 2008 TP NOPR.49 | Test Procedures for Microwave Ovenseere.energy.govClosingHow to Submit Comments...Public Meeting– oral comments will be captured in the transcript and becomepart of the public record.Written comments– SNOPR comment period open until October 4, 2010Reference docket #: EERE-2008-BT-TP-0011 and/or RIN #: 1904-AB78Email:MicroOven-2008-TP-0011@ee.doe.govMail: Mrs. Brenda EdwardsU.S.Department of EnergyBuilding Technologies Program1000 Independence Avenue, SW, Mailstop EE-2JWashington, DC 20585-0121Courier: Mrs. Brenda EdwardsU.S.Department of EnergyBuilding Technologies Program950 L'Enfant Plaza, 6th FloorWashington, DC 20024Telephone: (202) 586-294550 | Test Procedures for Microwave Ovenseere.energy.govIntroductionActive Mode Test Procedure Provisions51 | Test Procedures for Microwave Ovenseere.energy.govIntroductionRepeal Final RuleDOE published a final rule on July 22, 2010, which repealed themicrowave oven test procedure provisions for cooking efficiency andenergy factor (active mode).•DOE determined that the provisions did not produceaccurate and repeatabletest results.•DOE was unaware of any test proceduresthat have been developed to addressthese concerns.52 | Test Procedures for Microwave Ovenseere.energy.govIntroductionSteps in a Potential Microwave Oven Active Mode TestProcedure RulemakingNOPRFinalRuleComments on initiating a NOPR from interested parties•Transcript records oral commentsfrom today’s public meeting•Written commentsDOE reviews and considers all commentsDOE will consider developing a new active mode microwave oven testprocedure by proposing amendments in a NOPR.53 | Test Procedures for Microwave Ovenseere.energy.govBackgroundPrevious Active Mode ProvisionsThe active mode provisions incorporated portions of IEC Standard 705-1998 andAmendment 2-1993, “Methods for Measuring the Performance of Microwave Ovens forHouseholds and Similar Purposes” (IEC Standard 705).•IEC Standard 705 has been declared obsolete by IEC.The current IEC test procedure is IEC Standard 60705-2006, “Household microwaveovens―Methods of measuring performance” (IEC Standard 60705).As part of energy conservation standards rulemaking for microwave ovens, DOE andAHAM tested microwave ovens to both IEC Standard 705 and IEC Standard 60705:•DOE tested 32 microwave ovens•AHAM tested 21 microwave ovens•Results:–DOE observed significant variability in the cooking efficiencymeasurements from both methods.–DOE was unable to ascertainwhy similarly designed, equipped, and constructed microwaveovens shows varying efficiencies.54 | Test Procedures for Microwave Ovenseere.energy.govBackgroundComparison of IEC 705 and IEC 60705Fundamentally, the two testprocedures are very similar:•Cool water outside test vessel to 10 ̊C below room temperature, then pour/weigh1 kg into the testvessel.•Cooking efficiency test is runat 100 percent of MWO output.•Heat water sample to room temperature and recordtime and input power during heating.Current DOE Efficiency Test (IEC 705-1988 and Amendment 2-1993)•Excludes filament heating power requirements•Has tighter ambient temperature requirements (+/- 2 ̊C vs. +/- 5 ̊C)•Has tighter final temperature requirements (Tambient+/- 1 ̊C vs. 20 +/- 2 ̊C)Current IEC Test Procedure (IEC 60705-2006)•Test supplanted IEC 705; IECconsiders IEC 705 obsolete.•Energy consumption measurement includes filament heat-uptime, which lowers efficiency by 1-2%.•Requires rounding outputpower to nearest 50W and efficiencyto the nearest whole number, whichmore than triples therange of efficiency and power outputcalculations compared to IEC705.•Test procedure doesnot specify how to determine the filament heat-up time, which createsuncertainty in the power output calculations.•Test procedure does notspecify the requirements for accuracy of temperature and timemeasurements.55 | Test Procedures for Microwave Ovenseere.energy.govBackgroundComparison of IEC 705 and IEC 60705Based on limited testing, the datafrom IEC705-1988 and Amendment 2 - 1993is more consistent.Three tests per MWO, 12 MWOs testedRounding of output power per IEC60705 roughly quadruples test-to-testvariability.Test Unit#Rated P owerOutput(W)Test to TeIEC 705-1988st Efficiency RRoundedIEC 60705Raw IEC60705ange (%)DOE17001.463.570.56DOE6DOE58008000.060.43.453.330.960.70DOE99000.485.001.66DOE22DOE19DOE15DOE211,1001,1001,1001,1000.710.470.770.213.573.453.391.670.500.200.530.76DOE27DOE291,2001,2001.070.921.670.001.050.87DOE301,2500.671.790.82DOE321,3001.245.172.14 Test-to-Test Range (%)6543210IEC 60705 Non-Rounded Test-to-Test Results RangeIEC 60705 Rounded Test-to-Test Results Range1 6 5 9 22 19 15 21 27 29 30 32DOE Test Unit #56 | Test Procedures for Microwave Ovenseere.energy.govActive Mode MethodologyOther Test Procedures for Measuring Energy Efficiency inMicrowave Ovens.IEC Standard 60705 Ed. 4.0 b: 2010Canada: CAN/CSA C388-M89 (R2007), “Energy Consumption Test Methods forHousehold Microwave Ovens”Australia: AS/NZS 2895.1: 2007, “Performance of household electrical appliances –Microwave ovens – Methods for measuring the performance of microwave ovens forhousehold and similar purposes”Japan: JIS C 9250: 1992/Amendment 1: 2007, “Microwave Ovens”Korea: KS C 9313-95, “Microwave Ovens”China: GB/T 18800-2008: Household microwave oven – Methods for measuringperformanceChina: CCEC/T09-2006, “Microwave Ovens”Brazil: RESP/012,“Microwave Ovens”Chile: NCh 2642: 2001, “Microwave Ovens”Others?57 | Test Procedures for Microwave Ovenseere.energy.govActive Mode MethodologyRequest for Comment: Active Mode Methods**DOE seeks comment on issues associated with the current microwave oven test procedure and whether any test methods are** **currently available to address these concerns.**58 | Test Procedures for Microwave Ovenseere.energy.govClosingHow to Submit Comments...Public Meeting– oral comments will be captured in the transcript and becomepart of the public record.Written comments– Reference docket #: EERE-2010-BT-TP-0023 and/orRIN #: 1904-AC26Email:MWO-2010-TP-0023@ee.doe.govMail: Mrs. Brenda EdwardsU.S.Department of EnergyBuilding Technologies Program1000 Independence Avenue, SW, Mailstop EE-2JWashington, DC 20585-0121Courier: Mrs. Brenda EdwardsU.S.Department of EnergyBuilding Technologies Program950 L'Enfant Plaza, 6th FloorWashington, DC 20024Telephone: (202) 586-294559 | Test Procedures for Microwave Ovenseere.energy.gov