1

1 BEFORE THE

2 UNITED STATES DEPARTMENT OF ENERGY PUBLIC

3 MEETING ON ENERGY CONSERVATION PROGRAM

4 FOR CONSUMER PRODUCTS:

5 TEST PROCEDURE FOR CLOTHES WASHERS

6 

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8 

9 

10 

11 

12 

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19 

20 

21 28 October 2010

22 Washington, D.C. USA

23 ___________________________________________________

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1 APPEARANCES:

2 DOUG BROOKMAN

 Moderator

3 

4 BETSY KOHL

 U.S. Department of Energy

5 1000 Independence Avenue SW

 Washington, D.C.

6 USA

7 JENNIFER CLEARY

 Director

8 Regulatory Affairs

 Association of Home Appliance Manufacturers

9 1111 Nineteenth Street NW

 Suite 402

10 Washington, D.C. 20036

 USA

11 PH 202-872-5955

 FX 202-872-9354

12 jcleary@aham.org

13 PAIGE DETRICK

 Engineering Test Lab Manager

14 Laundry Products

 BSH Home Appliances Corporation

15 100 Bosh Boulevard

 New Bern, North Carolina 28562

16 USA

 PH 252-636-4476

17 FX 252-672-4509

 paige.detrick@bshg.com

18 

 CAMILLA DUNHAM WHITEHEAD

19 Water and Energy Technology Team

 Lawrence Berkeley National Laboratory

20 218 Pine Street

 South Portland, Maine 04106

21 USA

 PH 207-228-3573

22 cdwhitehead@lbl.gov

23 

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1 ATTENDEES (Continued):

2 JASON FITZGERALD

 D&R International

3 1300 Spring Street

 Suite 500

4 Silver Spring, Maryland 20910

 USA

5 PH 301-588-9387

 FX 301-588-0854

6 jfitzgerald@drintl.com

7 MIKE GALLER

 NIST

8 100 Buren Drive

 Gaithersburg, Maryland

9 USA

 PH 301-925-6521

10 mike@nist.gov

11 J. B. HOYT

 Director

12 Regulatory Affairs and State Government Relations

 Whirlpool Corporation

13 2000 North M-63 MD 3005

 Benton Harbor, Michigan 49022

14 USA

 PH 269-923-4647

15 FX 269-923-4652

 CL 269-277-1032

16 j_b_hoyt@whirlpool.com

17 CHRISTOPHER JOHNSON

 Senior Manager

18 Standards and Compliance

 North America Standards & Environmental Affairs

19 LG Electronics USA, Inc.

 1000 Sylvan Avenue

20 Englewood Cliffs, New Jersey 07632

 USA

21 PH 201-266-2419

 CL 201-795-6552

22 chris.johnson@lge.com

23 

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1 ATTENDEES (Continued):

2 RICHARD KARNEY

 U.S. Department of Energy

3 1000 Independence Avenue SW

 Washington, D.C.

4 USA

5 KELLEY KLINE

 GE

6 Appliance Park AP 2-225

 Louisville, Kentucky 40225

7 USA

 PH 502-452-7603

8 Kelley.Kline@ge.com

9 JOANNA MAUER

 Technical Advocacy Coordinator

10 Appliance Standards Awareness Project

 529 Fourteenth Street NW

11 Suite 600

 Washington, D.C. 20045

12 USA

 PH 202-507-4034

13 jmauer@standardsASAP.org

14 MIKE McGARAGHAN

 Project Manager

15 Energy Solutions

 1610 Harrison Street

16 Oakland, California 94612

 USA

17 PH 510-482-4420 x 242

 FX 510-482-4421

18 mmcgaraghan@energy-solutions.com

19 EDWARD R. OSANN

 Natural Resources Defense Council

20 1314 Second Street

 Santa Monica, California 90401

21 USA

 PH 310-434-2300

22 FX 310-434-2399

23 

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1 ATTENDEES (Continued):

2 CHARLIE STEPHENS

 Senior Energy Codes and Standards Engineer

3 Northwest Energy Efficiency Alliance

 PH 503-688-5457

4 cstephens@neea.org

5 AMANDA STEVENS

 Program Manager

6 Energy Star Appliance Program

 Climate Protection Partnerships Division

7 U.S. Environmental Protection Agency

 1200 Pennsylvania Avenue

8 MC 62021

 Washington, D.C. 20460

9 USA

 PH 202-343-9106

10 Stevens.Amanda@epa.gov

11 JOHN I. TAYLOR

 Vice President

12 Government Relations & Communications

 LG Electronics USA, Inc.

13 1776 K Street NW

 Washington, D.C. 20006

14 USA

 PH 202-719-3490

15 FX 202-719-3492

 CL 847-828-2777

16 john.taylor@lge.com

17 JUDITH REICH

 Navigant Consulting

18 77 South Bedford Street

 Suite 400

19 Burlington, Massachusetts 01803

 USA

20 PH 781-270-0101

 DR 781-270-8313

21 FX 781-270-0418

 jreich@navigantconsulting.com

22 

23 

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1 ATTENDEES (Continued):

2 TIMOTHY SUTHERLAND

 Navigant Consulting

3 77 South Bedford Street

 Suite 400

4 Burlington, Massachusetts 01803

 USA

5 PH 781-270-0101

 DR 781-270-8375

6 FX 781-270-0418

 timothy.sutherland@navigantconsulting.com

7 

 TROY WATSON

8 Navigant Consulting

 1801 K Street NW

9 Suite 500

 Washington, D.C. 20006-1801

10 USA

 PH 202-973-2400

11 DR 202-481-8427

 FX 202-973-2401

12 troy.watson@navigantconsulting.com

13 STEPHEN WITKOWSKI

 U.S. Department of Energy

14 1000 Independence Avenue SW

 Washington D.C.

15 USA

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1 I N D E X

 Page

2 

 WELCOME

3 By Stephen Witkowski 8

4 OPENING REMARKS, INTRODUCTIONS, AND AGENDA

 REVIEW

5 By Doug Brookman 9

6 STAKEHOLDER OPENING STATEMENTS

 By Ed Osann 13

7 By Jennifer Cleary 15

8 INTRODUCTION AND REGULATORY HISTORY

 By Stephen Witkowski 16

9 

 OVERVIEW AND STANDBY MODE, OFF MODE, AND

10 ADDITIONAL ACTIVE MODE TEST PROCEDURES

 By Judith Reich 17

11 

 CLOTHES WASHER ACTIVE MODE TEST PROCEDURE

12 By Timothy Sutherland 99

13 COMPLIANCE WITH OTHER EPCA REQUIREMENTS,

 IMPACT OF PROPOSED AMENDMENTS ON ENERGYGUIDE

14 AND ENERGY STAR, AND ELIMINATION OF OBSOLETE

 CLOTHES WASHER TEST PROCEDURE

15 By Judith Reich 212

16 DISCUSSION OF OTHER ISSUES

 By Doug Brookman 224

17 

 NEXT STEPS AND CLOSING REMARKS

18 By Stephen Witkowski 224

19 

20 

21 

22 

23 

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8

1 BEFORE THE

2 UNITED STATES DEPARTMENT OF ENERGY PUBLIC

3 MEETING ON ENERGY CONSERVATION PROGRAM

4 FOR CONSUMER PRODUCTS:

5 TEST PROCEDURE FOR CLOTHES WASHERS

6 TRANSCRIPT OF PROCEEDINGS

7 MR. BROOKMAN: Okay, please take your

8 seats. We're going to begin.

9 Welcome, everyone, and good morning.

10 Stephen Witkowski, from the Department of Energy is

11 going to start with welcoming remarks.

12 WELCOME:

13 MR. WITKOWSKI: Good morning. On behalf

14 of Department of Energy I want to welcome you here

15 to this public meeting on residential clothes

16 washer test procedures.

17 We also have from DOE here today Rich

18 Karney, who's over here to the right, who has over

19 all responsibility for test procedures, and Betsy

20 Kohl from General Counsel, who's been working very

21 closely on this particular test procedure.

22 We have a lot of material to cover

23 today, so we'll try to get started right away and

24
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1 move through it. But, I do want to emphasize that

2 we strongly urge and request that if you do have

3 information, data or whatever as we go through, keep

4 track, and be sure, you know, when you get back, to

5 send us the information that you have.

6 It's a public meeting. We're here to

7 get your input, and we will look forward to it.

8 MR. BROOKMAN: Thank you.

9 Just to clarify, this is the public

10 meeting on energy conservation program for consumer

11 products, test procedure for clothes washers here

12 at the Department of Energy. Today is Thursday,

13 October twenty-eighth, and it's a beautiful day in

14 Washington, D.C.

15 We typically start these meetings with

16 introductions, so let's do that. Your name and

17 organizational affiliation.

18 And those of you sitting at the table

19 can get in the habit of making sure the little

20 green LED light is turned on when you speak.

21 (Whereupon, at 9:15 a.m. ET,

22 introductions were had.)

23 MR. BROOKMAN: Thank you. Thanks to all

24
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1 of you.

2 Glad you could join us and get an early

3 start on this. We also have folks joining us by

4 the web.

5 How, how many do we have on? Eight

6 right now.

7 I'm going to go ahead to do a very quick

8 review of the Agenda, and then launch into the

9 content. And then immediately following this

10 Agenda review there it's an opportunity for brief

11 summary remarks, opening remarks by anybody that

12 wishes to do so here in the room.

13 We're going to proceed, immediately

14 following Stakeholder Opening Statements with an

15 Introduction and, and Regulatory History. And then

16 we'll have an Overview and Standby Mode, Off Mode,

17 and Additional Active Mode Test Procedures.

18 We'll take a break about 10:30 and then

19 that review will be continued. And then continuing

20 on, Clothes Washer Active Mode Test Procedure.

21 Break for lunch around about noon and

22 return from lunch with more on the clothes washer

23 active mode test procedure, will continue that

24
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1 explanation, that presentation.

2 We'll take a break mid-afternoon,

3 probably a little later than 2:00 o'clock, as

4 reflected there, and then Clothes Washer Active

5 Mode Test Procedure Continued, and Compliance with

6 Other EPCA Requirements, Impact of Proposed

7 Amendments on EnergyGuide and ENERGY STAR, and

8 Elimination of Obsolete Clothes Washer Test

9 Procedure.

10 End up, end up the day with a discussion

11 on other issues. There is yet another opportunity

12 for individuals to raise additional comments, raise

13 additional issues that haven't been covered

14 sufficiently.

15 So, there's your opportunity there

16 again, and then some next steps and closing

17 remarks. The Agenda reflects that we're going to

18 try and finish at 3:45 today.

19 Stephen tells me that there's a lot to

20 cover, so we're going to have to stay focused to

21 get this all done timely. I'd ask for your

22 consideration.

23 Please speak one at a time. Please

24
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1 state your name for the Record each time you speak.

2 You don't need to say your affiliation

3 unless you're in the habit of doing so. But,

4 please say your name each time.

5 There will be a complete Transcript of

6 this meeting. As you can see, we have a Court

7 Reporter present.

8 That would be posted on the EERE web

9 site, and, and I'm certain a representative from

10 the Department of Energy will be telling you where

11 that's located.

12 I'm going to be queuing people as best I

13 can by name to speak. Please feel free to follow

14 on sometimes.

15 The back-and-forth is useful. And if

16 you could, keep the focus here. Turn your cell

17 phones on "Silent" mode.

18 Please limit your side-bar

19 conversations, and, as we have a lot to cover. And

20 I did, didn't say that I'm Doug Brookman from

21 Public Solutions in Baltimore.

22 So, having said that, do we have slides

23 before they do opening marks, remarks their summary

24
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1 comments, Stephen?

2 MR. WITKOWSKI: No. We're going to

3 actually follow the --

4 STAKEHOLDER OPENING STATEMENTS:

5 MR. BROOKMAN: So, then now is an

6 opportunity for individuals to make brief opening

7 remarks. Key issues and concerns?

8 Ed Osann.

9 MR. OSANN: Just a short statement here

10 at the outset. The Natural Resources Defense

11 Council strongly supports the joint recommendations

12 for new appliance energy and water efficiency

13 standards and test procedures as presented to

14 Secretary Chu by letter dated July thirtieth, 2010.

15 We also support the joint

16 recommendations specifically regarding clothes

17 washer test procedures as presented to Assistant

18 Secretary Catherine Zoi by letter dated July

19 twentieth, 2010,

20 The recent agreement covering

21 residential clothes washers and other appliances is

22 a landmark achievement offering billions of dollars

23 of savings to consumers, regulatory certainty, and

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1 reasonable timetables for manufacturers and

2 substantial reductions in energy and water

3 consumption and greenhouse gas emissions. We urge

4 this agreement to be implemented by the Department

5 as soon as possible.

6 We've come to this proceeding together

7 with AHAM and its member companies seeking several

8 improvements in the test procedure for clothes

9 washers. We welcome many of the changes proposed

10 by the Department in this NOPR, and we look forward

11 to commenting on them in more detail.

12 We remain concerned, however, that the

13 current proposal may not have removed the potential

14 for unwarranted bias in favor of large capacity

15 washers, which AHAM and efficiency advocates have

16 jointly urged under the Department to resolve in

17 this proceeding.

18 As we seek clarification and improvement

19 in the proposed rule, we are mindful of the need

20 for the Department to resolve outstanding issues

21 and finalize the test procedure rule on a timely

22 basis. Timely action here is necessary for timely

23 action to adopt the final rule for clothes washer

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1 efficiency standards upon which all projected

2 energy and water savings depend.

3 We anticipate final additional written

4 comments for the Record of this rulemaking after

5 today's public meeting.

6 MR. BROOKMAN: Thank you. And I

7 appreciate your brevity.

8 I really do, okay? Because I see you

9 have a lengthy written Statement there.

10 Other comments here at that time outset?

11 Jennifer.

12 MS. CLEARY: I think AHAM would echo

13 much of what was just stated in terms of the

14 agreement. We also would urge that it be adopted

15 as soon as possible, and also that the test

16 procedure become final in a timely manner so that

17 we have time to test it before Standards are

18 proposed.

19 MR. BROOKMAN: Thank you very much

20 that's helpful.

21 Okay, additional comments here before we

22 launch into the substantive content?

23 (Whereupon, no response was had.)

24
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1 MR. BROOKMAN: No additional comments?

2 Okay, then let's go.

3 Steve Witkowski.

4 MR. WITKOWSKI: Okay. Because we have

5 so much to cover today I'm not going to go into

6 detail on the history and, and what's gone on in

7 the past.

8 The regulatory history and the procedure

9 is all in black-and-white here, not only in the

10 presentation, but in the Federal Register Notice,

11 and it's also online. We have a great deal to

12 cover, and some issues that we know you're very

13 much concerned with, so we're going to get started

14 right away with the test procedure overview and the

15 issues.

16 MR. BROOKMAN: That I believe's Slide 7.

17 MS. REICH: I think I'm going to use one

18 of those microphones.

19 (Whereupon, at 9:21 a.m. ET, remarks

20 were made among those present, off the Record,

21 after which the following occurred:)

22 OVERVIEW AND STANDBY MODE, OFF MODE, AND ADDITIONAL

23 ACTIVE MODE TEST PROCEDURES:

24
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1 MS. REICH: Can everybody hear me? I'm

2 Judy Reich, from Navigant Consulting.

3 And as you will see when we start the

4 slides, we've organized the discussion today into

5 largely two parts, one covering the active, new

6 provisions for active mode, and additional

7 provisions for standby and off mode.

8 And then the second half, which Tim

9 Sutherland is going to be speaking on, addresses

10 the, the revisions that are being proposed to

11 address various active-mode issues.

12 Let me get to where we're starting. So,

13 so, to start off with there are a couple of just

14 basic items that we want to go through quickly.

15 The first is what exactly would be

16 products covered by this new proposed test

17 procedure. And there are existing -- There is an

18 existing definition in 10 CFR that DOE is not

19 proposing to change, and this covers all of the

20 product classes that are presently defined in the

21 Energy Conservation Standards, namely top-loading

22 compact, top-loading standard size, top-loading

23 semi-automatic, front-loading, and suds-saving

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1 clothes washers.

2 So, all of these would be considered

3 covered products for purposes of this test

4 procedure.

5 In terms of when any amended provisions

6 would become effective, once the test procedure

7 would be published in the Federal Register, after

8 30 days it, the test procedure would become

9 effective. But, it's important to note that a new

10 Appendix J-2 would not be required to be used to

11 determine compliance with the existing Standards

12 until such time; that is, until those Standards

13 would be amended to require the use of it.

14 But, in the interim, the existing J-1

15 Appendix would be used for compliance. Okay.

16 So, let's talk about the portions of

17 this, of this meeting that are addressing the

18 requirements for including standby and off-mode

19 energy use in the test procedure, as well as some

20 additional active modes that are being considered.

21 The Energy Independence and Security Act

22 of 2007, or EISA 2007, requires DOE to take into

23 consideration in test procedures any standby and

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1 off-mode energy use, using two Standards from the

2 IEC: 62301 and 62087. The latter is, relates to audio

3 and video equipment, and therefore is not

4 considered ap-, applicable.

5 It's not taken into account in this

6 rulemaking. It is important to note that the EISA

7 amendments to EPCA state specifically that DOE

8 shall consider the most current version, or the

9 current version of, of those two Standards. And,

10 therefore, for purpose of today's meeting, DOE is

11 proposing that the IEC Standard 62301, first

12 edition, the 2005 edition, is the current version.

13 This is a topic that we'll get into in,

14 in more detail in a bit. But, in terms of

15 incorporating by reference methodology and, and

16 test conditions to measure standby power now in

17 this test procedure, DOE is proposing that several

18 provisions from Section 4 and Section 5 would be

19 incorporated by reference, and they're listed here

20 below.

21 The -- And we'll talk about each one in

22 more detail, but in general I think the, more of

23 the discussion's probably going to be focused

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1 around the measurement methodology, talking about

2 procedures for testing, whether the power

3 consumption is stable or unstable.

4 Okay. So, the IEC is in the process of

5 updating 62301, which is the, their test procedure

6 for measuring standby power in appliances.

7 And originally this rulemaking had an

8 EISA deadline of June thirtieth, 2009, and DOE

9 decided, because it was, the IEC was in the process

10 of considering this new Edition 2, it delayed this

11 rulemaking to allow DOE to consider the new version

12 of it.

13 And that was expected to be released in,

14 shortly after the EISA deadline in July of 2009.

15 But, that process was delayed, and at this point

16 the IEC is stating that April, 2011, is the

17 anticipated publication date for Second Edition.

18 So, DOE decided not, decided not to wait

19 any further. It is proposing referencing the First

20 Edition of, of 62301 for the test procedures.

21 And it's doing so in order to expedite

22 the process of, of amending the test procedure to

23 include standby and off-mode power. DOE believes

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1 that the provisions that it is proposing to include

2 will largely remain the same as the Second Edition

3 is finalized, and therefore the references to them

4 would remain valid.

5 Based on our review of the most recent

6 draft versions, there was a Committee Draft for

7 Vote, or CDV version, and more recently, a Final

8 Draft International Standard, the FDIS. And we'll

9 talk about consideration of each of those in a

10 moment.

11 We would like to invite comment at this

12 point on the adequacy of using provisions from IEC

13 62301 to measure standby and off-mode power, and

14 for the suitability of incorporating those specific

15 provisions into the DOE test procedure in clothes

16 washers.

17 MR. BROOKMAN: Jennifer.

18 MS. CLEARY: Jennifer Cleary. AHAM does

19 support and recommends IEC 63201; however, not the

20 first edition.

21 We believe the FDIS should be

22 referenced. We understand you incorporate it by

23 reference, but we think there are probably other

24
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1 ways to included it in the Rule.

2 It will be, per the IEC posted

3 yesterday, that it will be published tomorrow and

4 will be out for a vote in 60 days, and will include

5 our written comments, suggestions for how you can

6 include it.

7 But we can -- You know, we've been

8 stating in several rulemakings that we can

9 continue.

10 MR. BROOKMAN: Jennifer, AHAM's been

11 participating in that, or representatives from AHAM

12 in the IEC procedures.

13 MS. CLEARY: We have, but we'll provide

14 more detail.

15 MR. WITKOWSKI: We can't go into it.

16 Thank you.

17 MR. BROOKMAN: Yes. Charlie Stephens.

18 MR. STEPHENS: Charlie Stephens.

19 One of the sections that's not

20 specifically mentioned to be adopted with us 3.2,

21 3.4, 3.5, et cetera, is the "Definition" section.

22 Is there a plan for what DOE will do when a mode is

23 specified in 5.1 and 5.3 that isn't defined because

24
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1 DOE didn't adopt a particular definition that the

2 EISA did?

3 In other words, if the definitions of

4 these modes, for instance, are not pretty much

5 identical, how will DOE look at any discrepancy

6 between the procedures that are specified based on

7 the definition of the mode that IEC has versus the

8 definition that DOE has?

9 And I'm thinking specifically, for

10 instance, in terms of something like network mode.

11 MS. REICH: Right. Yes.

12 Okay, so I want to be clear that the

13 mode definitions are not, they are drawn from the

14 draft versions. They do not incorporate them by

15 reference.

16 So, the mode definitions will be fixed

17 in the DOE test procedure. They do not change as

18 any new modes may be added to the IEC 62301

19 version.

20 And then I think the, then following

21 that I think your question would be if the

22 methodology in IEC 62301, in the provisions that

23 are incorporated by reference, change to update or

24
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1 to address new modes that may be added in IEC

2 62301, that, would they still be relevant to the

3 DOE test procedure?

4 Is that the question?

5 MR. STEPHENS: Well, my question, my

6 concern is that you, if you don't define what the

7 mode is fairly identically with what the IEC does,

8 and then later you reference test methods that

9 depend on those definitions being the same, you're,

10 you're going to have a potential inconsistency

11 there in the way things are measured, because

12 you're, you're measuring things based on the IEC

13 procedure that's based on its own definitions of

14 what that mode is.

15 And I'm just concerned that things be

16 consistent enough so that this methodology match

17 test definitions.

18 MS. REICH: Okay. The -- You know, we,

19 we are aware that at least in the FDIS version

20 there are modes that DOE, for reasons that we'll

21 discuss in a moment, is not considering to address.

22 And, and, again, it is not -- The DOE

23 test procedure would not adopt those new

24
25

1 definitions by reference. DOE is, has considered

2 that language, and has now defined the modes

3 specifically that will remain in place and that

4 will be tested according to methodology, -- At

5 least as it's been proposed. -- to the methodology in

6 the first edition.

7 (Whereupon, at 9:33 a.m. ET, Ms. Cleary

8 and Mr. Osann conferred, out of the hearing of

9 others and off the Record, during which the

10 following occurred:)

11 MS. REICH: So, there would not be any

12 disconnect between any new modes that may be

13 introduced by the IEC, or any new methodology in

14 second edition that hasn't been considered yet. At

15 this time the proposal is to use the methodology

16 in, from the first edition in, and in tandem with

17 the mode definitions, with the language that had

18 been drawn from the new version.

19 And DOE believes that there is not a

20 disconnect between the testing definitions and

21 those mode definitions.

22 MR. BROOKMAN: You can see the

23 Department has invited comment, additional comments

24
26

1 as reflected in Number 1.

2 (Whereupon, at 9:34 a.m. ET, no response

3 was had.)

4 MR. BROOKMAN: Okay.

5 MS. REICH: Okay. The, the next topic

6 is the mode definitions, what modes should be

7 incorporated into the test procedure.

8 Both the EISA amendments to EPCA and IEC

9 62301 first-edition interpretation of both of those

10 could lead to some questions as to what exactly,

11 what, what modes are, are required to be addressed;

12 whether, you know, whether they would apply in

13 certain ways to specific products, particularly

14 because these definitions were designed to be very

15 broadly applicable to various products that may

16 have different types of modes.

17 Also note that EPCA authorizes DOE to

18 amend the definitions that were provided by EISA,

19 taking into account these most current versions of

20 the IEC Standards. Upon review of both the CDV

21 version and the FDIS version, DOE expects that the,

22 any revisions to the mode definitions have largely

23 been completed, and that they will remain

24
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1 relatively unchanged in the final version of the

2 second edition.

3 Therefore, DOE has looked at that

4 language and is proposing to amend the mode

5 definitions based on the language in the FDIS,

6 adding some extra specifications to clarify how

7 they would be applied to clothes washers.

8 So, the modes that DOE is considering

9 can largely be grouped as "active," "standby," and

10 "off" modes. But, within each one of those

11 classifications there are specific functions that

12 may be classified as an active mode and/or a

13 standby mode.

14 So, DOE is proposing to clarify that

15 there can be multiple modes within each, within

16 each category, and therefore is proposing to define

17 "Active Mode," as you can see, as essentially the

18 performing of all the major functions of washing,

19 soaking, tumbling, pumping water into or out of the

20 washer.

21 Within that description, a portion of

22 that can be referred to as the "active washing

23 mode." And that is the typical wash cycle,

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1 including washing, rinsing, and spinning

2 activities.

3 In addition to that washing mode, there

4 is also a mode defined as "delay start," in which

5 the user sets the machine to wait for a specified

6 period of time before engaging the act of washing

7 mode. And DOE believes that this "Delay Start"

8 mode is part of "Active Mode" because it can't

9 persist for indefinite time, which is one of the

10 criteria for classifying it as standby mode, and it

11 also occurs prior to engaging the wash cycle.

12 So, therefore, DOE believes that it's

13 uniquely associated with washing, and, and part of

14 the active mode. Additionally, DOE is proposing

15 that "Cycle Finish Mode" be classified as an

16 "Active Mode" because it provides a status display

17 following operation in active mode, or following a

18 wash cycle.

19 And because, again, it is uniquely

20 associated with the termination of wash cycle, DOE

21 believes that it should be considered part of

22 "Active Mode." Now, there are some other functions

23 that can take place at the, at the end of a cycle

24
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1 besides just a display or indicator to the user.

2 And these would be, for example, some

3 sort of periodic tumbling, or blowing some air

4 through it in order to, you know, maybe prevent

5 mold, or to just keep the clothing fresh.

6 And DOE did not propose, for the

7 purposes of the NOPR, to include those additional

8 functions as part of "Active Mode" or as part of a,

9 a, cycle finish mode because these do not represent

10 largely what most clothes washers do. It's, it's

11 somewhat of a niche function.

12 So, DOE estimates that less than, that

13 less than five percent of products on the market

14 have that capability, and that, on balance, the,

15 the energy use associated with that as a whole

16 would be so small, but it would increase

17 manufacturer test burden by lengthening the, the

18 test cycle to capture what really is a neg-,

19 negligible contribution to the annual energy use.

20 So, DOE did not propose to require

21 measurement of that function.

22 An additional mode that DOE proposes to

23 consider as part of "Active Mode" is a self-clean

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30

1 function. This is provided on many front loaders

2 and on some top loaders, and it is a function

3 specified or provided by the manufacturer as a

4 unique setting that is dedicated to maintaining the

5 machine by cleaning it or deodorizing or

6 disinfecting it.

7 And the intent is that it, it prevents

8 odors or bacteria or mildew from growing. For

9 those machines that have such a function, there's

10 typically a recommendation from the manufacturer on

11 how often to, to run the cycle.

12 It is conducted without a load in the

13 machine, and so therefore it is not a

14 clothes-washing function. But, DOE believes that

15 this should be considered part of "Active Mode"

16 because it's a function that's necessary to

17 maintain the machine, properly maintain consumer

18 utilities to allow it to perform the washing act-,

19 activity.

20 So, that was all Active Mode. The

21 second type of mode that EPCA requires addressing

22 is standby mode.

23 And DOE is proposing to define it as any

24
31

1 mode in which it's connected to power and offers

2 one or more of the functions that are listed there,

3 but, importantly, must be able to persist for an

4 indefinite time. And these would include things

5 like displays or internal sensors, as well as

6 features that are consuming power in order to

7 activate other modes.

8 And those would be timers, remote

9 switches, and the like. Additionally, DOE

10 proposes, for clarity, to amend the test procedure

11 to state that a continuous clock function doesn't

12 necessarily have to be associated with a display

13 in, on the front of the product.

14 It can be an internal function

15 associated with the control board; but, that it's

16 any, that the timer's any continuous clock function

17 that provides regularly scheduled tasks and that

18 operates on a continuous basis.

19 For clothes washers, DOE has only identified

20 one standby mode, one mode that meets this criteria

21 that is being called "Inactive Mode," and this is

22 the mode in which the display may be turned off and

23 that there is an internal sensor that can power the

24
32

1 device, the, the product back up.

2 And so also classifying that if energy

3 is consumed in the presence of a one-way remote

4 control under this definition, that would also be a

5 standby mode. So, you know, in today's discussion,

6 while DOE, in the NOPR, has only identified

7 "Inactive Mode," very clearly the definition allows

8 for multiple standby modes to be considered.

9 And, I -- Any information on such

10 additional mode, standby modes would certainly be

11 invited.

12 Finally, the third major category of

13 modes is "Off" mode. This definition is fairly

14 basic.

15 It's connected to power and is not

16 providing any active or standby function. The

17 additional classification that is offered here --

18 And this was based on some questions that have come

19 up previously. -- is that an indicator that only

20 shows the user, shows to the user that the product

21 is in "Off" mode would not be considered status

22 display for the purposes of putting it into Standby

23 Mode.

24
33

1 That would keep it within "Off" mode.

2 Additionally, if there is a mechanical, a hard

3 on/off switch on the device, on the product, if

4 that was in the "Off" position such that there was

5 no energy use being, or power being supplied to the

6 display of the control components, that, too, would

7 be considered "Off" mode, and not as had been

8 considered previously, a "Disconnected" mode, which

9 brings me to the modes that are not proposed for

10 consideration at this point.

11 There are additional modes that are

12 defined in the FDIS, namely "Network" mode and

13 "Disconnected" mode. And for the reasons that are

14 shown here, DOE is not proposing at this point to

15 incorporate them in the test procedure.

16 "Network" mode, according to the FDIS,

17 is a state in which the product is connected to the

18 power and has a network function activated, such as

19 reactivation via network command, or network

20 integrity communication. But, most notably, the

21 primary function is not for "Active" mode

22 activities; mainly for communication.

23 According to the FDIS, "Disconnected"

24
34

1 mode essentially means the, the plug is, is

2 removed; that all connection to the main power are

3 removed or interrupted. So, the latter, pretty

4 clearly there's no energy use associated with that,

5 so DOE is not considering to define that or to

6 include that as a mode in the test procedure.

7 And for reasons that DOE does not, is

8 not aware of any clothes washer currently on the

9 market that has a network function, and is unable

10 to evaluate these types of products at this point,

11 is not proposing any provisions that would measure

12 energy use in "Network" mode.

13 Welcome inputs on what you're thinking.

14 Let's see.

15 "Inactive" mode is the only standby

16 mode, and there's a list here that I'll run through

17 before we invite those comments; the determination

18 of delay start, cycle finished, and self-clean mode

19 as a part of "Active" mode.

20 The definitions of all of these, and the

21 question of whether there are any other modes that

22 haven't been considered.

23 MR. BROOKMAN: Charlie Stephens.

24
35

1 MR. STEPHENS: Charlie Stephens.

2 I guess I'll go back to, to, to "Active"

3 mode, since that's what you touched on first. I'm

4 having trouble understanding when DOE proposes to

5 define the end of the cycle, in other words, to

6 demark the line when the "Active" mode is finished

7 and the "Inactive" mode begins, without measuring

8 whatever's going on in the "Active" mode and the

9 end-of-cycle phase of a, of an active-mode cycle.

10 In other words -- In other words,

11 without measuring everything that's going on, like

12 the tumbling of the drum, which my clothes washer

13 does, or any fan power that's blowing air through

14 the thing. Is that "Inactive," or is that "Active"

15 mode?

16 MS. REICH: I think the interpretation

17 is that the end of the cycle is when the spinning

18 process at which it reaches the final RMC is

19 complete. So, if there would be additional

20 tumbling or fan actions past that, that

21 intermittently or periodically, that would be --

22 the latter would be part of a "Cycle Finished"

23 mode.

24
36

1 MR. STEPHENS: Okay. But, is "Cycle

2 Finished" mode part of the "Active" cycle?

3 MS. REICH: It is not considered part of

4 it, the "Active" washing cycle. It is a separate

5 piece of "Active" mode that DOE is considering to,

6 to measure energy use in, but it would not be part

7 of the energy test cycle.

8 MR. STEPHENS: Well, I'm trying to

9 understand if -- How are you going to measure the

10 energy in the, in the "Cycle Finished" portion of the

11 "Active" mode, to use the language that's here on

12 the paper, without measuring the energy used in the

13 tumbling and fan use?

14 MS. REICH: Well, that is, I guess, one

15 of the questions out for comment, is that for the

16 reasons that I mentioned of not many machines

17 having that feature, the periodic or intermittent

18 tumbling, that DOE does not, has not proposed that

19 any portion of the test procedures measure that

20 function, and that it would be typically, what it

21 would be doing typically would be measuring the

22 energy use of a display or a, or an indicator light

23 that simply displays to the user that the cycle is

24
37

1 complete.

2 MR. STEPHENS: How are you going to

3 measure that without measuring the energy use of

4 the tumbling that's going on at the same time?

5 MS. REICH: Well, we would certainly

6 welcome input on methodology to differentiate

7 those.

8 MR. STEPHENS: Well, I'm a little

9 concerned, because my clothes washer is now eight

10 years old. I happen to know there are thousands

11 and thousands of them just in Oregon, because we

12 ran the tax credit program for them on as many

13 years.

14 And it turns the clothes over. I can't

15 tell you how many times it does it, but I know it's

16 more than two, because I witnessed that many --

17 MS. REICH: Um-hum

18 MR. STEPHENS: -- times.

19 So, I'm, I'm, I'm just kind of a little

20 lost to understand how you're not going to credit,

21 include this. Because it uses more energy than

22 just the supply, which, of course, has got the

23 lights.

24
38

1 So, I'm still --

2 MS. REICH: Um-hum. Well, what I think

3 I'm hearing, then, is that you're recommending that

4 there be methodologies to measure that energy use

5 of the tumbling and blowing function.

6 MR. STEPHENS: Yeah. I guess I'm at a

7 loss to understand how you wouldn't, because

8 otherwise you'd be in some other mode.

9 To go on to some other mode, I'm also a

10 bit concerned that you're not going to deal with

11 the "Network" mode at all, or at least include

12 it should it become. I've had major conversations

13 with one of the major microprocessors, who have, --

14 manufacturers who happen to be nearby. And I've

15 talked to them about the processors they intend to

16 market in this market.

17 And I'm concerned about their power

18 consuming, quite frankly, because it will

19 dramatically increase the numbers that I'm seeing

20 in the published NOPR here in the standby mode --

21 MS. REICH: Um-hum.

22 MR. STEPHENS: -- unless they do

23 something to dramatically reduce their power

24
39

1 consumption. So, I'm again at a little loss to

2 understand how you would ignore a mode that would

3 multiply three to five times the standby motion as

4 it sits there waiting for the signal from the

5 electric grid, for instance.

6 MR. BROOKMAN: Steven Witkowski.

7 MR. WITKOWSKI: I think that you're

8 raising some interesting points here, and we

9 certainly are aware of technologies that may be

10 coming on line. However, you know, what we need

11 is, if there is concern, is some data and some

12 information that actually points out what's going

13 on out there.

14 It's very hard for us, when we're

15 putting a test procedure together, to say, well,

16 to, to deal with speculation, even if that

17 speculation is, is very good. And so one of the

18 main points of this meeting is to get that

19 information.

20 If you have concerns about the

21 methodology, and particularly if you have data on

22 machines or data on networking devices that are

23 already available, then we would want to see that.

24
40

1 But, until we see that, we have to go with what we

2 have right now.

3 MR. STEPHENS: I think my concern is not

4 that we can, that we can't nail down the numbers,

5 but I think if we put in place --

6 This is Charlie Stephens again.

7 If we put in place a methodology that

8 deliberately excludes the measurements of these

9 things even after they show up, I don't think it's

10 necessary actually to know how much energy they use

11 ahead of time, but I think it is necessary to at

12 least create a methodology which I think the IEC

13 methodology is attempting to do so that if there is

14 energy use going on during that period, it's

15 measured.

16 And I think that mostly it's a matter

17 of: How long do you measure, and what mode? It's

18 just a measure, measure of, of: How long is the

19 test procedure in that mode?

20 And, if that's all it is, I think

21 there's a way to set it up so that machines that

22 don't have that function, or that terminate that

23 function, and it's obvious that they do, then

24
41

1 that's the end of the test in that mode for that

2 machine.

3 MR. BROOKMAN: Okay.

4 MR. STEPHENS: So, anyway, that's where

5 I'm sitting. And we are going to go get some data,

6 but not in time for you folks to specify this by,

7 say, April of, of this coming year.

8 That's about when our data collection

9 begins. And we will have a lot of data on clothes

10 washers and clothes dryers by the time we're done,

11 but not in this time frame.

12 MR. BROOKMAN: Ed Osann.

13 MR. OSANN: Yeah, Ed Osann.

14 We have similar concerns about the

15 exclusion of these activities from, from the

16 "Active Mode" definition. And, Steve, I think it

17 almost seems as though you're jumping ahead from,

18 from the concerns about framing up the test

19 procedure to concerns about, "Well, how would we

20 know what Standard to set for, for, for this

21 component that, for the, for this standby and

22 active-mode consumption?"

23 The Joint Agreement that, that AHAM and

24
42

1 efficiency advocates have entered into does include

2 explicit commitment to seek a recognition of Smart

3 Grid functionality for major appliances, including

4 clothes washers, in the ENERGY STAR context. So,

5 the clear intention here is to, is, is, is to see

6 the commercialization, and, indeed, to speed up the

7 commercialization of machines, including clothes

8 washers that have Smart Grid functionality.

9 So, it would seem to make sense to, in

10 terms of the test procedure, at least, to frame up

11 the test procedure to be prepared to assess

12 whatever that level of, of energy consumption is

13 that's associated with that functionality.

14 MR. BROOKMAN: Good. Thank you.

15 JB.

16 MR. HOYT: JB Hoyt, Whirlpool

17 Corporation.

18 Charlie, I look forward to seeing your

19 data because we're the world's largest

20 manufacturer of appliances, and we would love to

21 have that data, because the products don't exist.

22 And maybe by April, enough products will so you can

23 go do that.

24
43

1 But, we agree in theory that the mode

2 ought to be considered, but we have no idea how to

3 measure it because there's no functionality to

4 measure at this point in time. So, "What do you

5 measure? How long do you measure it for? How do

6 you incorporate that?" are questions that can't be

7 answered.

8 MR. BROOKMAN: JB, you're referring to

9 "Network Mode"?

10 MR. HOYT: I'm referring to the "Network

11 Mode." Thank you, Doug.

12 MR. BROOKMAN: Okay.

13 MR. HOYT: And so it ought to be a

14 placeholder that says when there's sufficient

15 volume in the marketplace, it ought to be, to be

16 considered. But, until then, I don't know what we

17 would be talking.

18 So, --

19 MR. BROOKMAN: Okay. So, that data

20 would be good.

21 Jennifer.

22 MS. CLEARY: Okay. We would echo what

23 JB just stated.

24
44

1 And, of course, consistent with our

2 Agreement, we believe that the "Network Mode" may

3 be a distinctive energy user, and we need to

4 address how and where that should be measured and

5 included. You know, also I would mention that the

6 FDIS version of 62301 does have suggestions about

7 how to, how to do that.

8 MR. BROOKMAN: Okay, thank you.

9 There are several -- If you look at

10 Comment Box 2, the Department requests comment on

11 several different things there. We don't want to

12 dance lightly over this.

13 Make sure that you have addressed your

14 issues here.

15 Yes, Joanna.

16 MS. MAUER: Joanna Mauer.

17 Just a question. If a product came on

18 the market that did have network capability and was

19 always in "Network" mode, would that product be

20 considered to have no standby power consumption?

21 (Whereupon, at 9:58 a.m. ET, Ms. Detrick

22 and Mr. Hoyt conferred, out of the hearing of

23 others and off the Record, during which the

24
45

1 following occurred:)

2 MS. REICH: That's a very good question.

3 I guess it would have, the product would have to be

4 evaluated to see if there was a "Standby" function

5 that was active during that mode.

6 I can't answer without knowing the

7 details of it. But, you know, that's a very good

8 question, and a good thing to take into account.

9 MR. BROOKMAN: Charlie Stephens.

10 MR. STEPHENS: Charlie Stephens.

11 Yeah. When I was speaking about our

12 data, JB, I wasn't talking about "Standby" mode

13 data. I was talking about "Active" mode data, the

14 tumbling and fans and that sort of things.

15 When it comes to "Network" mode, that's

16 what I was talking about with my conversations with

17 the microprocessor manufacturer who intends to sell

18 this microprocessor into your market. And so

19 whether or not they succeed in that, I don't know.

20 But, I do know what their power

21 consumption is, of that power processor, right

22 now, and that's what alarms me in that case if you

23 decide to buy that processor.

24
46

1 And, if, if, as Joanna suggested, this

2 thing is in a "Network" mode all the way, and

3 "Standby Network" mode all the time, I'm very

4 concerned about the power consumption of that

5 thing, given what they've told me so far.

6 MR. BROOKMAN: JB.

7 MR. HOYT: JB Hoyt, Whirlpool.

8 I can't react to that because it's not

9 designed. When it's designed we ought to measure

10 it.

11 But, there are a variety of

12 alternatives, variety of devices, varieties of

13 functionalities. So, I don't know how you can

14 assign a test procedure around something that

15 doesn't exist yet, and so that's our concern.

16 MR. BROOKMAN: Okay, I think we're ready

17 to move off that subject. Okay.

18 Other comments on issues not yet

19 addressed in this comment?

20 MS. CLEARY: I --

21 MR. BROOKMAN: Yes, Jennifer.

22 MS. CLEARY: Jennifer Cleary.

23 And I had a question about "Self-Clean"

24
47

1 mode. Just, we understand the definition that,

2 that you proposed to be directed toward machines

3 that have a specific program cycle for self

4 cleaning.

5 Is that accurate? And it's, it looks

6 like it's a list that includes an "and" at the end,

7 and so all three of those things in the definition

8 would be required.

9 MS. REICH: Yes.

10 MS. CLEARY: Okay. Thank you.

11 MR. BROOKMAN: Okay?

12 MS. REICH: Yes.

13 MR. OSANN: Just --

14 MR. BROOKMAN: One additional comment,

15 Ed?

16 MR. OSANN: Yeah. So, that means if the

17 manufacturer recommends a particular periodic

18 sanitizing regimen, but does not have any hardware

19 or software associated with it on the machine, --

20 MS. REICH: Not --

21 MR. OSANN: -- then that cycle is not

22 going to be picked up.

23 MS. REICH: That's correct. If the

24
48

1 manufacturer simply says, "Run an extra hot cycle,"

2 we believe --

3 MR. OSANN: Right.

4 MS. REICH: -- periodically, that would

5 not be considered a dedicated self-clean function.

6 No. And that would not be addressed in

7 the, in the test procedure.

8 MR. BROOKMAN: Okay.

9 MR. OSANN: I take issue with that.

10 MR. BROOKMAN: Ed, you want to say that

11 on the Record?

12 MR. OSANN: Yeah. I think we would take

13 issue with that.

14 MR. BROOKMAN: Okay. Thank you, Ed.

15 (Whereupon, at 10:01 a.m. ET, a

16 technician conferred with Mr. Brookman, out of the

17 hearing of others and off the Record, after which

18 the following occurred:)

19 MR. BROOKMAN: Yeah, there we go.

20 THE TECHNICIAN: Good.

21 MS. REICH: The next topic is adding the

22 specifications for the measurements of the test

23 methods. And these, we delve into the specific

24
49

1 provision sections from IEC 62301 that are proposed

2 to be incorporated.

3 Paragraph 5.3.1 discusses the

4 methodology that is to be used, depending on

5 whether the power consumption is determined to be

6 either stable or, or unstable. And according to,

7 to this Standard, the, the power is determined to

8 be stable if it varies by no more than five

9 percent during a five-minute period.

10 And, if that is the case, then the power

11 is measured at the end of an additional time period

12 of at least five minutes. If the power is

13 unstable, that is, it varies by more than five

14 percent during the five-minute period, then the

15 power must be measured over at least five minutes,

16 or one or more complete operating cycles, which may

17 take several minutes or hours.

18 A MEMBER: Excuse me.

19 MS. REICH: It's important to recognize

20 that nothing within those provisions prevents a

21 manufacturer from choosing either a longer

22 stabilization period or a longer measurement

23 period.

24
50

1 It's recognized that many clothes

2 washers have displays that dim, or otherwise

3 reduce power consumption after a certain period of

4 time of user inactivity, and so DOE proposes to

5 incorporate the additional clarification from

6 Paragraph 5.1, Note 1, that says that the

7 measurement shall wait until the product drops into

8 its lower power level state.

9 DOE has tested a representative sample

10 of, of current clothes washer models and has

11 determined that this higher power state typically

12 lasts no more than ten minutes, which, however, may

13 mean that it could, there could be clothes washers

14 that wait in that higher-level state for the

15 combined ten minutes, the five-minute stabilization

16 period and five-minute measurement period that

17 would be applicable under the conditions of the,

18 of stable power.

19 So, further, DOE noted that IEC Standard

20 63201, the CDV version, provides for a 30-minute

21 stabilization period and a ten-minute measurement.

22 So, it extends the, the test period presumably to

23 account for situations like the, the powered-down

24
51

1 state.

2 And DOE believes that by providing those

3 two time periods, longer time periods, 30 minutes

4 and ten minutes, that it would allow all of the

5 products to reach their lower power state and then

6 have a, the ten-minute measurement period

7 thereafter so that it should properly measure all

8 of the so-called low-power modes, the "Inactive"

9 mode, "Cycle Finished," "Off" mode, and, further,

10 that even if some clothes washers would allow for a

11 user to change settings so that it would stay in

12 that higher power state longer, DOE doesn't believe

13 typically that consumers will do that, and is not

14 proposing any additional provisions that would

15 require the testing to be maintained at the, or to

16 prevent the default setting from being adjusted.

17 There were some significant changes that

18 were made from CDV to FDIS, notably in the

19 measurement methodology. And the FDIS states that

20 the test period shall be not less than 15 minutes

21 as long as the, the power is not cyclic.

22 And, it requires that the first five

23 minutes of the measurement are disregarded, and

24
52

1 then the ten minutes following that are evaluated

2 to determine whether the power is stable. If it

3 is not stable, the measurement period gets

4 extended, and it can be extended until, it gets

5 extended until the stability criteria are met.

6 And it's based on the first third being

7 disregarded, and the two-thirds thereafter being

8 used to determine stability. And that can be up to

9 three hours.

10 It further requires that if there is a

11 known variation in power consumption, that, that

12 the measurement must be conducted for at least an

13 hour, 60 minutes.

14 When the power is cyclic, the

15 stabilization period is ten minutes and the FDIS

16 requires that at least four cycles, four of the

17 regular cycles are used for the, the measurement,

18 -- I'm sorry. -- the stability, stabilization

19 period, and the measurement period must be at least

20 20 minutes long.

21 Because there can be, you know, multiple

22 interpretations of that methodology, and can be

23 very different from product to product, determining

24
53

1 stability and how long to conduct the measurements

2 under the FDIS methodology, DOE believes that this

3 methodology would not be as repeatable and

4 reproducible, and therefore enforceable when

5 products are measured in, from laboratory to

6 laboratory, and believes that the CDV version

7 provides a more, a more well-defined test

8 methodology to ensure those.

9 I'll certainly invite comment on that to

10 talk about default settings and methodologies that

11 can account for consumer actions that might

12 increase energy use in data on the repeatability of

13 such testing procedures.

14 MR. BROOKMAN: Jennifer?

15 MS. CLEARY: AHAM does believe that the

16 product should be tested, as default,

17 although we do question if it's part of "Active"

18 mode, as to why it's being included in this way in

19 this stabilization period.

20 MR. BROOKMAN: Okay, thank you.

21 Paige, do you want --?

22 MS. DETRICK: (Nodded no.)

23 MR. BROOKMAN: No. Okay.

24
54

1 Additional comments?

2 (Whereupon, at 10:09 a.m. ET, no

3 response was had.)

4 MR. BROOKMAN: Okay.

5 MS. REICH: Okay. Delayed start is a

6 somewhat different situation because for some

7 products the time that's displayed on, or the

8 indicator of the status of the dis-, "Delay Start"

9 mode may impact the power consumption in that mode.

10 DOE conducted tests and analyses that

11 looked at displays that have both single- and

12 two-digit displays to determine the countdown time

13 for the "Delay Start" function, and in particular

14 it looked at, for devices that have displays that,

15 that have, have multiple segments, what time could

16 be set on the display, or as the "Delay Start"

17 time, that that single time would be representative

18 of the average of all the possible combinations of

19 lit segments on the, the time indicator.

20 And what DOE determined was that the

21 display time that is representative of that average

22 would be five hours, and then proposes to require

23 the power to be monitored for an addi-, for 60

24
55

1 minutes after waiting five minutes after setting

2 the time to allow the display to stabilize.

3 And I also would like to add here that

4 consideration was made for what possible maximum

5 display types are available on the range of units

6 on the market now.

7 We request if there are any comments on

8 this methodology for measuring display mode,

9 "Delayed Start" mode power consumption.

10 MR. BROOKMAN: Jennifer.

11 MS. CLEARY: Jen Cleary.

12 I think DOE has recognized the

13 difficulty of measuring this mode. As you know,

14 you were just talking about some of the

15 difficulties.

16 And we question whether those

17 difficulties and the added test burden required to

18 measure "Delayed Start" as well as "Cycle Finished"

19 have any real benefit to the public. The

20 associated energy with those may be de minimis, and

21 when balanced with the test burden to obtain those

22 measurements separately from the rest of "Active"

23 mode, you know, I think there may be a disconnect

24
56

1 there.

2 And that's sort of a general comment

3 that we have through, through the rest of the test

4 procedure, the proposed test procedure as well.

5 And so I'll expand on that as we go along, but just

6 wanted to -- I think this is a good place to put

7 the general idea there.

8 MR. BROOKMAN: Okay. Thank you.

9 Additional comments on "Delay Start"

10 mode as referenced here?

11 (Whereupon, at 10:12 a.m. ET, no

12 response was had.)

13 MR. BROOKMAN: Okay.

14 MS. REICH: All right. In terms of the

15 test conditions that are proposed to be

16 incorporated from IEC 62301, the first is the

17 ambient temperature that be, that would be required

18 in the test room.

19 Currently for measuring the existing

20 "Active" mode measurements the DOE test procedure

21 requires the ambient temperature be fixed or be

22 specified only for water-heating clothes washers.

23 And in that case it requires 75 plus or minus five

24
57

1 degrees ambient temperature.

2 The IEC 62301 has a broader, a looser

3 specification. It allows the temperature to range

4 from 64 to 82 degrees.

5 So, so the DOE test procedure as it

6 exists is, is more, has a closer specification.

7 It's within the range allowed by IEC.

8 DOE is proposing that the test room

9 temperature specifically for "Standby" and "Off"

10 mode and these other low-power states, the "Delay

11 Start" and "Cycle Finished" mode be specified

12 according to the broader IEC definition or, or

13 allowable range, specifically, because it would

14 provide flexibility to manufacturers.

15 It would allow manufacturers to conduct

16 these new tests in the same facility that they're

17 currently testing the existing "Active" mode

18 provisions, or it could allow manufacturers to set

19 up a separate test area for the "Standby" and "Off"

20 mode that would not require as close temperature

21 control as it would for the "Active" mode.

22 So, comments on that topic.

23 MR. BROOKMAN: Yes, Jennifer.

24
58

1 MS. CLEARY: Yes. Jennifer Cleary.

2 AHAM believes that ambient temperature

3 should be extended beyond water-heating machines to all

4 machines. It does have significant effect on the

5 tests, and we think that the proposal should be

6 extended to all.

7 MR. BROOKMAN: Um-hum. Thank you.

8 Other comments?

9 (Whereupon, at 10:15 a.m. ET, no

10 response was had.)

11 MR. BROOKMAN: Okay.

12 MS. REICH: Actually, I'd like to

13 clarify that. When you say "extended," extended

14 for the "Active" mode measurement, for all clothes

15 washers?

16 Or extended to all tests for all clothes

17 washers?

18 MS. CLEARY: I think we can expand a

19 little bit on that in our written comments.

20 MS. REICH: Okay. Thank you.

21 MR. BROOKMAN: Okay. Thank you,

22 Jennifer.

23 MS. REICH: Oop. This -- Okay.

24
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1 Okay, then we get to the important topic

2 of calculating how much energy on an annual basis

3 is associated with each operating mode. Currently

4 the metric that is used to measure energy use for

5 clothes washers is a modified energy factor, or

6 MEF.

7 It is defined as the cubic feet of

8 clothes load capacity per total energy consumption.

9 And that is -- It's a per-cycle measurement, and it

10 in-, it covers three contributors to energy use:

11 of course, the energy that's consumed directly,

12 electrical energy consumed directly by the machine

13 during the cycle.

14 It also includes the energy that is used

15 to heat the water, any hot water that's used, and

16 it would also include this energy that's presumed

17 to be required by an accompanying clothes dryer too,

18 of a clothes dryer to eliminate the moisture from

19 that load.

20 DOE is proposing in this new test

21 procedure that additional contributions from modes

22 that may not have been measured previously, namely

23 the "Standby" and "Off" modes, and the "Cycle

24
60

1 Finished" and "Delay Start," be expressed in, on

2 the same basis; that is, on a per-cycle basis

3 rather than, for example, in an, an energy-use

4 basis.

5 And it's important to note that the

6 total energy consumption in each mode depends not

7 only on the power that it is consuming in that

8 mode, but also the time spent over the course of

9 the year in each mode that would be allocated to

10 the, the, each active washing cycle.

11 So, the first contributor to look at is

12 the "Active" washing mode. How much time per year

13 is, is allocated to just washing the clothes?

14 DOE looked at multiple sources to, to

15 determine what an average cycle time would be. It

16 varies, of course, from machine to machine,

17 depending largely on the axis of rotation, whether

18 it's a horizontal-axis or vertical-axis machine,

19 and the type of load that as being run.

20 DOE believes that calculating the, the

21 contributors to annual energy use on a single

22 average value of "Active" mode cycle time is

23 reasonable. It, it does not significantly impact

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1 the results if you do try to attribute different

2 cycle times to top-loaders and front-loaders.

3 Our analysis shows that the, the final

4 number of annual numbers that would be allocated

5 by, to the various modes would vary by less than

6 one percent. Additionally, -- And I think Tim is

7 going to talk about this more in the "Active" mode

8 section. -- based on review of the most recent

9 available studies that looked at consumer usage

10 patterns, DOE is proposing to reduce the number of

11 wash cycles that the average consumer uses during

12 the year from the current 392 there in the test

13 procedure, to 295.

14 So, at one hour per cycle, this would

15 mean that 295 hours per year would be spent in the

16 "Active" washing mode.

17 MR. BROOKMAN: I see a comment here.

18 Ed Osann.

19 MR. OSANN: A question. Is the, the

20 example that's given in the bullet on this slide --

21 (Whereupon, at 10:19 a.m. ET, Mr.

22 Witkowski and Mr. Sutherland conferred, out of the

23 hearing of others and off the Record, during which

24
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1 the following occurred:)

2 MR. OSANN: -- is this based on any

3 particular survey, or is this based on a marker to

4 say that if you had this much of a delta between

5 the two loading formats, it would have this

6 nominal effect?

7 MS. REICH: Tim, correct me if I'm

8 wrong, but I think this was based on estimates made

9 by reviewing available cycles in the, in the test

10 sample that DOE had.

11 MR. SUTHERLAND: I'm sorry, I didn't

12 hear the question. Would you repeat it?

13 MR. OSANN: Is the -- Well, stated more

14 broadly, has DOE collected data on representative

15 cycle times for active washing for top loaders and

16 front loaders?

17 MR. BROOKMAN: Thank you.

18 Tim.

19 MR. SUTHERLAND: Tim Sutherland,

20 Navigant.

21 I believe these were made, determined

22 based on the testing that was done as part of the

23 Standards Program, so, tests that would have done,

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1 been done on top loaders and front loaders in the

2 lab.

3 MR. OSANN: Okay. And this was a

4 limited number of machines.

5 As I recall, this was, you had eight or

6 ten machines that would form the basis of these

7 tests.

8 MR. SUTHERLAND: More.

9 MS. REICH: I think there was a larger

10 number, but --

11 MR. SUTHERLAND: Larger sample.

12 Probably about 20 machines or so.

13 MS. REICH: Right. It was not a

14 comprehensive sample of all the machines on the

15 market, but, you know, selected to be a

16 representative cross-section.

17 MR. OSANN: And so more specifically

18 with regard to Slide 33, did the numbers that are

19 provided in the, in the, in the bullet, the, the

20 bullet there listing the example, 45 minutes per

21 cycle for top loaders and 75 minutes per cycle for

22 front loaders, are those the actual average or

23 composite of the top loaders and front loaders that

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1 were tested in DOE batch?

2 MR. BROOKMAN: Tim, if you're uncertain,

3 maybe you could dig for that data.

4 MR. SUTHERLAND: Yeah, I'm uncertain if,

5 if that was, if 45 was the mathematical average, or

6 if that was just sort of a general average, so I'll

7 have, I'll have to check and see if I can --

8 MS. REICH: And I think I can also state

9 that there was no attempt to determine on a

10 weighted basis, you know, different cycle settings

11 that would have been selected, and weighting them

12 to obtain that 45 minutes. It -- I think it's, you

13 know, generally selected as representative, and to

14 see, given that variation, what the impact would

15 be.

16 MR. OSANN: Okay.

17 MR. SUTHERLAND: Yeah. And I think

18 that's an important part to remember, is that the,

19 the impact of whether it's 45 or 75 is, as it says

20 in the slide, the impact was rather small.

21 MR. OSANN: I understood that was the

22 point of the slide. I was, I was trying to

23 establish whether the, the numeric values that were

24
65

1 used to illustrate the point were actual averages,

2 or whether they were simply markers to, to show.

3 (Whereupon, at 10:23 a.m. ET, Mr.

4 Witkowski and Mr. Sutherland conferred, out of the

5 hearing of others and off the Record, during which

6 the following occurred:)

7 MR. BROOKMAN: Illustratively a range.

8 MR. SUTHERLAND: Okay?

9 MR. BROOKMAN: Yeah, okay. Thank you.

10 Okay, we're moving on.

11 (Whereupon, at 10:23 a.m. ET, Ms.

12 Detrick and Mr. Hoyt conferred, out of the hearing

13 of others and off the Record, during which the

14 following occurred:)

15 MS. REICH: The chart here, the, this

16 table shows how DOE is proposing to allocate energy

17 use based on measured power for the different modes

18 that it is proposing to incorporate into the

19 overall energy-use metric.

20 So, just to recap, DOE believes that

21 clothes washers consume energy in five, the, the

22 five modes listed other than the active washing

23 cycle; namely, "Delayed Start," “Cycle Finished, "Self-Clean,"

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1 "Off," and "Inactive" modes.

2 DOE is recommending this, the following

3 allocation based upon studies that were examined to

4 show typical consumer usage patterns. "Delay

5 Start" was shown to, or was estimated to be used,

6 or to exist for approximately five minutes per

7 active washing cycle, and that is intended to be a,

8 you know, a typical average, recognizing some

9 consumers don't use it at all; some do.

10 And that number is very low, obviously,

11 but it is believed to be related to the fact that

12 there is no time-of-use pricing in the United

13 States, so there is little incentive for consumers

14 to engage a delayed-start function.

15 So, if it is estimated to be five

16 minutes per cycle, the number of hours on an annual

17 basis that it would be estimated to be in "Delay

18 Start" mode would be 25.

19 Similarly, there is a low value

20 attributed to "Cycle Finished" mode, again defining

21 "Cycle Finished" simply as the status display or

22 indicator to the consumer that the cycle is

23 finished.

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1 The three minutes are estimated based on

2 the time, typical time that the clothes washers

3 wait before entering a lower power state. And so

4 that would attribute or account for 15 hours on an

5 annual basis.

6 Based on a limited sample of clothes

7 washers that DOE actually performed testing on, and

8 measurements of the duration of the self-clean

9 cycles, DOE determined an average of 1.3 hours per

10 self-clean cycle. And reviewing manufacturers'

11 recommendations in the product literature, typically

12 those are recommended to be run about once a month.

13 So, there would be twelve of those

14 cycles per year. Everything else, then, would be

15 attributable to either an "Off" mode or an

16 "Inactive" mode after you subtract out, of course,

17 the number of hours for, for "Active Washing" mode

18 and that leaves a remainder of 8,409 hours.

19 DOE conducted measurements of the

20 lower-power modes to determine what typical values

21 would be of the power consumption by which then it

22 would multiply the numb-, by the number of

23 associated annual hours to come up with annual

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1 energy use in each mode.

2 With the exception of the, the, the

3 average power in "Active Washing" mode, DOE

4 performed all of these measurements on its test

5 sample. And you can see the ranges that were found

6 to be associated with each mode.

7 The number for the power measurement

8 average power per cycle in "Active Washing" mode

9 came from a 2006 study based upon AHAM and

10 Whirlpool data. So, you can see that obviously the

11 "Active Washing" mode accounts for the lion's

12 share, and "Self-Clean" mode can be a, a relatively

13 significant contributor, up to 33 kilowatt-hours

14 , but that the "Delay Start," "Cycle Finished,"

15 "Off," and "Active" modes, particularly "Delay

16 Start" and "Cycle Finished" are very small

17 contributors on an annual basis to the energy

18 consumption of a machine.

19 MR. BROOKMAN: Ed Osann.

20 MR. OSANN: Question on the slide, just

21 to understand this. What is the -- What's the

22 basis for the three-minute estimate for "Cycle

23 Finished"?

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1 MS. REICH: That was measurements, time

2 measurements that DOE took that was the average of

3 how long after the cycle some sort of indicator to

4 the consumer persisted.

5 (Whereupon, at 10:29 a.m. ET, Ms. Cleary

6 and a member conferred, out of the hearing of

7 others and off the Record, during which the

8 following occurred:)

9 MR. OSANN: Okay. This is only the

10 indicator.

11 MS. REICH: This is not the tumbling.

12 MR. OSANN: This is only an indicator.

13 THE SPEAKER: Right. Right.

14 MR. OSANN: And this -- And is this

15 average of all machines, or, or is this just

16 machines that have a "Cycle Finished" function?

17 MS. REICH: I believe that was an

18 average of all the ones in the test sample, which I

19 --

20 MR. OSANN: So, it's those that have it

21 and those that don't, averaged together?

22 MS. REICH: Again I'm going to ask Tim

23 to correct me if I'm wrong, but I don't think there

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1 were any in DOE's test sample that did not have

2 such a function.

3 MR. SUTHERLAND: Let me just -- Tim

4 Sutherland of Navigant.

5 I believe the three minutes may actually

6 -- I don't believe it's actually an average of all

7 units on the market. I believe it's the average of

8 units that have that type of feature.

9 MS. REICH: Okay.

10 MR. SUTHERLAND: So, for example,

11 washers that only have electromechanical controls

12 would not be expected to have this type of feature,

13 so they would not have any cycle-finished activity.

14 Washers with electronic controls that

15 tend to have this type of feature, if they have it,

16 we, we saw that it usually lasted around three

17 minutes.

18 MR. BROOKMAN: Tim, were you referring

19 to a document there?

20 MR. SUTHERLAND: After -- I'm looking,

21 I'm looking at Slide 34.

22 MR. BROOKMAN: Okay. I was wondering if

23 you had some additional source, or whether this was

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1 your remembrance.

2 MR. SUTHERLAND: This is from memory.

3 MR. BROOKMAN: Okay.

4 MS. REICH: Could I, could I clarify

5 that before you go to the next question?

6 MR. BROOKMAN: Please do. Um-hum.

7 MS. REICH: That's an important point.

8 Machines that don't have the delay-start

9 capability, the hours that would have been

10 associated in the table here are allocated

11 elsewhere.

12 So, just for the purposes -- This is

13 done to evaluate the, how significant each mode is

14 as a contributor to overall energy use. But, in the

15 actual methodology, if a machine does not have a

16 "Delay Start" or "Cycle Finished" mode, then DOE

17 proposes to allocate the hours somewhere else.

18 MR. BROOKMAN: I see Tim has stepped up

19 again.

20 MR. OSANN: Could I just --

21 MR. BROOKMAN: No. Let's let Tim

22 clarify. Then I'm coming right back to you, Ed.

23 MR. SUTHERLAND: Thanks. Tim

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1 Sutherland.

2 One more thing is that we do have some

3 additional supporting slides at the end of the

4 presentation that provide a little more detail

5 about where we got those, so I recommend you --

6 MR. BROOKMAN: What slide number? At

7 the very bottom of that slide in blue?

8 MR. SUTHERLAND: The supporting slides

9 start at Slide 117, and there are approximately

10 eight slides --

11 MR. BROOKMAN: Okay.

12 MR. SUTHERLAND: -- that provide

13 additional data.

14 MR. BROOKMAN: Thanks for that.

15 Ed, do you want to continue?

16 MR. OSANN: Yeah, just to understand how

17 this is coming together, upon adoption of a test

18 procedure, if a, if a given machine has a, remains

19 in one of these modes for larger than the, the,

20 sort of the prototype here assumed, how will that

21 be reflected in the test results?

22 MS. REICH: Currently the test procedure

23 would have a fixed number of hours for all machines

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1 that have that function. There would, there would

2 be a specific time that was assumed in the test

3 procedure that the power would be multiplied by in

4 order to determine the per-cycle energy use.

5 The test cycle does not anticipate

6 changing the measurement time or the number of

7 annual hours for any individual machine.

8 MR. BROOKMAN: I saw Jennifer first.

9 MS. CLEARY: I just wanted to point here

10 to the slide and the annual energy use that's

11 consumed by delayed-cycle start or finish, I think

12 you recognize the small amount of energy that is

13 being used. And so I think this is just further

14 support for what I was stating earlier, that this

15 is such a de minimis amount of, of energy that it

16 does not add to the, the national consumption

17 figures presently as it's into the significant

18 increase in the testing burden.

19 It's, it's not an actual small increase

20 in the testing, but it's rather significant, and we

21 can provide some support for that practice.

22 MR. BROOKMAN: That would be helpful,

23 the details on that.

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1 Charlie Stephens.

2 MR. STEPHENS: Charlie Stephens.

3 And I'm still looking at the data. And

4 under "Cycle Finished," I've got a couple of

5 comments.

6 But, the range for typical power is zero

7 to 5.2. How do you know the "Cycle Finished" mode

8 when it's in it and out of it when the power

9 consumption is 0?

10 MS. REICH: The -- That's a good

11 question. I actually can't answer that one.

12 MR. STEPHENS: Well, my concern is that

13 if half the machines that were tested didn't have a

14 "End of Cycle" mode, let's just say there were 20

15 of them, and the av-, and the, and the consump-,

16 the power consumption of the ones that did, the ten

17 that did was six watts and you divide by 20, you

18 get a different number than you get if you divide

19 by ten.

20 And so I'm not sure that what we're

21 seeing here actually represents what we, what we

22 think we're seeing. The other thing is that I

23 noticed, my impression of reading the Federal

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75

1 Register Notice about where these "Cycle Finished"

2 times came from, that was, at best it was anecdotal

3 based on some Australian studies, I believe

4 primarily.

5 And in the past DOE has been rather

6 quick to dismiss data that comes, measured, metered

7 data sometimes that comes out of the, California or

8 the Northwest or wherever. I'm wondering why

9 they're so quick to adopt anecdotal data out of

10 Australia to support really what I think are

11 numbers that aren't supportable.

12 MR. BROOKMAN: Charlie, you're, you're,

13 you're questioning the numbers. Would you suggest

14 --

15 MR. STEPHENS: Cycle finished times, you

16 know, I, I, I don't think these are relevant. I

17 hate to go back to my own machine.

18 It's nothing more than anecdotal. But,

19 Whirlpool has made thousands of these things, and

20 my cycle time is way longer than that, and so

21 beyond the "Active Wash" mode.

22 MR. BROOKMAN: Do you have a solution

23 for the Department here? Can you propose --

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1 MR. STEPHENS: I think they need data.

2 I mean, there's an awful lot.

3 MR. BROOKMAN: They always want data.

4 MR. STEPHENS: If you don't have any, go

5 get that. It's the answer: Go get it.

6 There's an awful lot of arm-waving

7 going on here, I think, and I'll just point to some

8 more data. And, yes, it did come from California,

9 but a study completed last year on, for the CPUC

10 suggested that the energy consumption of clothes

11 washers, and these were average clothes washers, I

12 believe there were 115 of them in the end that had

13 good data used outside of the actual "Active Wash"

14 mode, it was equivalent of adding one wash load per

15 week.

16 I don't consider that insignificant.

17 So, there's -- What you're showing here is, is kind

18 of at cross-purposes to what people are finding in

19 the field, and I'd, I'd really like DOE to get to

20 the bottom of it.

21 MR. BROOKMAN: Okay. Thank you.

22 Yes, Kelley.

23 MR. KLINE: Hi. Kelley Kline from G.E.

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1 Just a comment on this slide that I

2 think ties together with the slide on Page 38,

3 which is the calculation of energy use per

4 operating mode. And it's on the "Self-Clean"

5 cycle.

6 We don't disagree with DOE's analysis.

7 You're basing that on twelve cycles per year now.

8 But, what we would note is we think that

9 there's, over that period of this test procedure,

10 some real potential for that to change the 12

11 cycles per year. We, we see that as really a

12 customer dissatisfier in terms of needing to do

13 that monthly.

14 So, we think that manufacturers will be

15 working to eliminate or, or, you know, reduce the

16 number of, of cycles per year that would be devoted

17 to a self-cleaning mode like that. So, I guess I

18 would just note it here.

19 But, then we get -- When we get to the

20 energy slide about calculating the energy use

21 associated with it, we would recommend DOE consider

22 something like DOE looking at, you know, more like

23 the manufacturer's use and care manual for what

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1 they recommend for self-clean cycles; maybe keying

2 off that to recognize that we think there may be

3 variability in that going forward.

4 MS. REICH: Okay.

5 MR. BROOKMAN: Good. Other comments on

6 these issues?

7 Just, just a second. I want to make

8 sure AHAM has a chance to comment if he, if he

9 wishes to comment.

10 No? All set?

11 Okay.

12 MS. REICH: Okay.

13 MR. BROOKMAN: Yes, Mike.

14 MR. McGARAGHAN: Mike McGaraghan.

15 Yeah, one quick question.

16 Mike McGaraghan, California utilities,

17 utilities.

18 You mentioned if a machine doesn't have

19 "Delayed Start" or "Cycle Finished" modes, those

20 hours would be allocated. Where?

21 I assume you mean "Off," or --

22 MS. REICH: Well, that's a great segue

23 into the next slide, anticipating this. Well, this

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1 is a bit of an eye chart, but it is showing how

2 exactly the, those annual hours are proposed to be

3 allocated.

4 And so it's kind of intuitively obvious,

5 but hard to, to put down into a table. And so,

6 hence, it looks very busy.

7 But, essentially, any hours that are not

8 attributable, or if the machine doesn't have the

9 functions, then those hours would be allocated,

10 yes, likely to, mostly to "Off" and "Inactive"

11 mode, because the number of active washing hours

12 are presumed to always remain the same, at 295.

13 So, you know, this top section here is

14 where there's no self-clean, so those 16 hours drop

15 down into the "Off" and "Inactive" mode. And it

16 just shows the, the distribution by mode of how

17 those 8,760 hours would be used to multiply by the

18 measured, the measured power consumption in each mode

19 to, to determine the annual energy use. Okay.

20 MR. BROOKMAN: Ed Osann.

21 MR. OSANN: Yeah. I just wanted to

22 reiterate a point I made briefly earlier, and that

23 is that, that we would recommend a determination of

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1 no self-clean versus self-clean be, be based upon

2 manufacturers' recommendations and not hard machine

3 features.

4 And really, also support the idea just

5 advanced by GE, that the, the number per year be

6 keyed to the manufacturers' recommendation.

7 MR. BROOKMAN: Okay.

8 MS. REICH: Aah. Now, how to allocate

9 the hours between "Inactive" and "Off" mode.

10 MR. BROOKMAN: Let me just make -- At

11 some point here he should take a break --

12 MS. REICH: Okay. Okay.

13 MR. BROOKMAN: -- whenever there's a

14 good stopping point.

15 MS. REICH: Okay. I think maybe after

16 the next request for comment.

17 MR. BROOKMAN: Okay.

18 MS. REICH: Okay. So, DOE believes

19 that, that for clothes washers, the definition of

20 "Off" mode applies to those units that have

21 electromechanical controls rather than electronic

22 controls, or it could also apply to units with

23 electronic controls but with a hard mechanical

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1 "On/Off" switch.

2 If, as is provided on many if not most

3 units with electronic controls, if there is a, a

4 push-button type of switch to activate it, that,

5 that feature would define it when it's in its

6 lowest power state, that it would be in "Standby"

7 mode as opposed to in "Off" mode.

8 DOE, DOE believes that that category,

9 the clothes washers that have electronic controls

10 but have a mechanical "Off" switch, there are

11 probably not many out there on the market, and

12 therefore the test of how to allocate the combined

13 "Inactive/Off" load hours would largely be based on

14 the type of control present on the clothes washer.

15 In particular, if it has, you know, as

16 noted, if it has electronic controls, that would

17 define it as being in "Standby" mode. If it has

18 electromechanical, it, those hours would be

19 associated with "Off" mode.

20 For those few washers that have both

21 mechanical controls and the electronic controls,

22 you know, DOE recognizes there's information out

23 there about usage patterns, how consumers would use

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1 it. And so for purposes of today's proposal, DOE

2 would allocate half of those combined hours to each

3 the, of the "Inactive" and "Off" modes.

4 MR. BROOKMAN: Joanna Mauer.

5 MS. MAUER: Joanna Mauer.

6 On that last point about how you're

7 proposing to allocate powers for those machines

8 that would have electronic controls and the

9 mechanical "On/Off" switch, it just seems to

10 present potential for gaming if, if, as you say, we

11 don't really have field data on consumer usage of

12 these switches.

13 MS. REICH: Um-hum.

14 MS. MAUER: If we did, then it would be

15 appropriate to give some kind of a credit to power use

16 in "Off" mode for those machines. But, it just

17 seems to present a situation where these switches

18 could be included, and consumers might never use

19 them.

20 They could even be almost hidden from

21 consumers, and yet half of the hours would still be

22 allocated to "Off" mode. So, just a concern.

23 MR. BROOKMAN: Okay. Thank you.

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1 Additional comments?

2 (Whereupon, at 10:44 a.m. ET, no

3 response was had.)

4 MS. REICH: So, to turn this all back

5 into how to allocate all the combined measurements

6 into the single per-cycle metric, DOE is proposing

7 that all of the “Inactive,” "Off," "Delay Start," and

8 "Cycle Finished" mode energy use would be calculated

9 by, for each of those modes, multiplying the

10 measured power in watts, and the allocated hours

11 for any mode that's present on that clothes washer.

12 Then, all of those contributors would

13 be, would be added together and expressed as a, on

14 a kilowatt-hour basis. And then in order to --

15 That's the annualized number.

16 And then in order to turn that into a

17 per-cycle measurement, it would be divided by the

18 295 annual-use cycles. For self-clean, it's a

19 little bit of a different situation because there

20 are a specific number of, discrete number of cycles

21 that are taking place over the year, which DOE has

22 estimated to be 12.

23 So, DOE proposes that if "Self-Cleaning"

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1 mode, if that mode is present, to multiply the

2 energy that's used in that cycle by, by the number,

3 the 12, being the number of cycles per year, and

4 dividing that by 295, again, to, to allocate it,

5 apportion it on a per-cycle, per-active-cycle basis.

6 I would like to point out in the Notice

7 there was an error in the, in the regular,

8 regulatory text for this particular calculation.

9 We are aware of that and will be correcting it.

10 But, the -- It does not right now do,

11 perform the, the calculation of multiplying the

12 energy used by 12 and dividing by 295.

13 MR. BROOKMAN: Ed Osann.

14 MR. OSANN: You, you mention 12

15 instances of, of self-clean per year. Why is the

16 -- Going back to Slide 35, why, why aren't the

17 number of hours for self-cleaning assigned at 16,

18 rather than 12?

19 MS. REICH: Oh, because each

20 "Self-Clean" cycle was estimated as 1.3 hours,

21 based on, on measurements of, of DOE's test sample.

22 MR. OSANN: Okay.

23 MS. REICH: DOE has considered an

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85

1 alternative approach, recognizing that in its

2 experience, in the testing that it's performed,

3 that, that the power consumption in some of these

4 modes, such as "Delay Start" and "Cycle Finished,"

5 are comparable to the power levels in "Inactive" or

6 "Off" modes, even though they are, do represent

7 unique modes.

8 The power associated with them is fairly

9 consistent among these modes, also, recognizing, as

10 has been pointed out, the annual energy

11 contribution of "Delayed Start” and “Cycle Finished" is very low.

12 So, DOE proposed an alternative method

13 in which the "Inactive" and "Off-Mode" power levels

14 would be used as a proxy for the "Delayed Start"

15 and "Cycled Finished" power, and therefore DOE

16 would only require measurement in the "Off" and

17 "Inactive" modes, and then allocate the hours that

18 would have been in "Cycle Finished" and "Delayed

19 Start" to "Inactive" and "Off" modes.

20 So, DOE believes that the final annual

21 energy use would still be representative, but it

22 would reduce, it would represent a, a lower test

23 burden. So, DOE would appreciate any comments on

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1 calculating the energy use in the different modes,

2 including the estimates of, of annual hours, and

3 certainly would welcome any thoughts on this

4 alternative approach to, to, to only require

5 measurement of the "Off" and "Inactive" modes.

6 MR. BROOKMAN: Ed Osann.

7 MR. OSANN: Just so that, that we

8 understand this correctly, the alternative approach

9 essentially would be to disregard the

10 characteristics of "Delay Start" and "Cycle

11 Finished." So, the, the, under the alternative

12 approach, what's a, what's measured is simply

13 "Active" mode and everything else.

14 MS. REICH: It's, it's not that it

15 disregards the characteristics. It says it is

16 based on the observation that, that in many cases

17 the "Delay Start" and "Cycle Finished" power levels,

18 even though they may represent different functions

19 being activated on the machine, the power being

20 measured is comparable to "Inactive" or "Off" mode,

21 and therefore the energy use can be accounted for

22 in the test procedure by simply making one

23 representative measurement of power, and, and

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1 computing the total energy use on all hours that

2 would have comprised the three modes.

3 It is not neglecting energy in "Delay

4 Start" or "Cycle Finished." It's, it's lumping it

5 together with "Inactive" mode, saying that the

6 energy, energy use that would be measured would be

7 representative of all three of the modes, but would

8 not require individual measurements of the three

9 modes to obtain.

10 (Whereupon, two members conferred, out

11 of the hearing of others and off the Record, during

12 which the following occurred:)

13 MR. OSANN: So, the distinctive

14 functionalities of, of, of given models that would

15 fall into these other two mode categories really

16 would not be, would not be assessed and, and

17 factored into?

18 MS. REICH: Under the alternative approach.

19 Yes, Ed. Thank you.

20 MR. BROOKMAN: Jennifer?

21 MS. CLEARY: Jen Cleary.

22 AHAM supports the alternative because of

23 what we spoke of before, that these do represent

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1 such a small amount of energy.

2 MR. BROOKMAN: Okay. Thank you.

3 Charlie.

4 MR. STEPHENS: My impression at the

5 moment is we might support the alternative approach

6 provided that the, the "Active Wash" mode is

7 defined for each machine as tested as including any

8 end-of-cycle mode. In other words, the "Inactive"

9 mode, which you are purporting to count here as

10 whatever hours are left over at the end of the

11 active cycle, which would include end-of-cycle

12 because you've already included end-of-cycle as

13 part of the active mode.

14 MS. REICH: Um-hum. Okay?

15 MR. STEPHENS: So, each machine that

16 includes the machine that can go for as long as ten

17 hours that you found tumbling.

18 MR. BROOKMAN: Okay?

19 MS. REICH: Okay. Any information you

20 have in defining that end would be very much

21 appreciated.

22 I'm not sure if there are machines that

23 can continue that function indefinitely, but, you

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1 know, any, any data or information to support how

2 DOE could define the end of the cycle would be, be,

3 would be appreciated.

4 MR. BROOKMAN: You see the comments box

5 there. Any additional comments on these proceeding

6 slides?

7 Okay, let's take a break.

8 (Whereupon, at 10:53 a.m. ET, those

9 present took a brief recess and returned at 11:13

10 a.m. ET, after which the following occurred:)

11 MR. BROOKMAN: So, let's resume. And

12 we're on Slide 42, and back with Judith Reich.

13 MS. REICH: Okay. The last topic that

14 I'm going to be covering, at least at this point in

15 the presentation, the current metric in the test

16 procedure is the MEF. And this is one of the

17 metrics which is defined as an Energy Conservation

18 Standard metric.

19 It is the basis of the current

20 Standards, and it is equal to, again, the capacity

21 of the washer divided by the existing total energy

22 use in kilowatt hours.

23 Right now it's the weighted per-cycle

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1 energy required to heat the water, the weighted

2 per-cycle electrical energy that goes into the

3 machine, and the per-cycle energy consumption that

4 is assumed to be required to remove whatever

5 moisture is left in the test cloth at the end of

6 the clothes washer cycle by drying it.

7 EPCA now requires that "Standby" and

8 "Off" mode energy use be integrated into an overall

9 energy efficiency descriptor unless or if it is

10 technically feasible to do so. And so DOE examined

11 whether that would be possible, to integrate it,

12 "Standby" and "Off" mode energy use on the

13 per-cycle basis.

14 DOE believes that it can be incorporated

15 into a new metric named "integrated modified energy

16 factor" by calculating a measure, or by calculating

17 adding in two additional measures of energy use.

18 The first would be a per-cycle

19 measurement that incorporates all of the energy use

20 attributable to "Standby," "Off," "Delay Start,"

21 and "Cycle Finished" mode. And then the second

22 contributor, new contributor would be a per-cycle

23 self-clean energy consumption.

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1 So, simply to get the integrated MEF,

2 IMEF would be the same type of methodology where

3 you simply sum together all the contributors in

4 terms of, of kilowatt hours, and use that in the

5 denominator with capaci-, the, the capacity

6 measurement in the numerator.

7 DOE would like to receive comment on

8 whether this is an appropriate approach, and

9 whether IMEF is an appropriate metric to use. I

10 saw Ed first.

11 MR. OSANN: Ed Osann.

12 Can, can you spread light on the basic

13 decision that DOE has made in this proposal to, to

14 maintain a, a metric that's expressed per cycle

15 rather than per year? The dishwasher Standard, in

16 contrast, is a, is a, expressed in energy

17 consumption per year.

18 And what's, what does DOE see as the

19 relevance in converting us back to and maintaining

20 a per-cycle metric?

21 MS. REICH: Well, I want to comment that

22 the existing dishwashing Standards are based on an

23 annual energy-use metric, not a per-cycle

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1 measurement --

2 MR. OSANN: Right.

3 MS. REICH: -- so that when DOE

4 considers integrating energy use there, there's an

5 existing annual-use metric that's the basis of the

6 Standards.

7 Right now the basis of Standards for

8 clothes washers is a per-cycle measurement, and DOE

9 considered retaining that for the purposes of, of

10 rolling in "Standby" and "Off" mode energy use.

11 MR. OSANN: Well, was there any

12 consideration by DOE in, in moving to an annual

13 energy, energy consumption metric?

14 And what were the, what might the

15 considerations have been?

16 MR. WITKOWSKI: Well, I think I'll let

17 --

18 MR. BROOKMAN: Steven Witkowski.

19 MR. WITKOWSKI: Well, really, this is

20 not a policy discussion here, and what we're

21 putting forward is what we consider to be the best

22 approach based on the input we received, and

23 methodologies that we received.

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1 And, you know, we're certainly willing

2 to accept comments or points, points of view, but I

3 don't think it's appropriate to get into internal

4 discussions other than what was presented at the

5 public meeting. This is not a policy discussion.

6 MS. REICH: I think if there is

7 information available that would suggest that one

8 metric is better than the other, we certainly invite

9 any comments we can. We can, absolutely.

10 And throughout the whole process we have

11 invited that.

12 MR. BROOKMAN: Okay. Thank you.

13 Jennifer.

14 MS. CLEARY: I think -- Jennifer Cleary.

15 We would reiterate that the "Delayed

16 Start" and "Cycle Finished" are de minimis, and, in

17 terms of their energy consumption, and thus should

18 not be included here.

19 MR. BROOKMAN: Additional comments on

20 this subject? I'm going to keep pressing this

21 along

22 We have a lot to cover.

23 MS. REICH: Okay. Finally, DOE is not

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1 proposing or did not propose in the NOPR to amend

2 the annual operating cost calculation that's

3 currently provided in 10 CFR 430.23; DOE is not

4 proposing to amend it to account for the cost of

5 energy consumed in anything other than the "Active

6 Washing" mode.

7 And the reasons were, for this rulemaking, the

8 determination was that right now the Energy Guide

9 label provides a comparison of the cost for a given

10 clothes washer model to a range of an operating

11 cost for, for other similar products. And so if

12 the annual operating cost measure were changed,

13 then, then this would no longer allow a direct

14 comparison within the range that's provided on the

15 Energy Guide label.

16 And, additionally, DOE believes that

17 the, the, the incremental cost of the energy that

18 would be now measured for "Self-Clean," "Standby,"

19 "Off," "Delay Start," and “Cycle Finished" modes are

20 small contributors to the annual operating cost

21 calculation, and so, therefore, because it's

22 negligible and because of the potential impact on

23 the Energy Guide label, DOE did not propose

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1 amending that cost calculation.

2 MR. BROOKMAN: JB.

3 MR. HOYT: You see the question on my

4 face.

5 MR. BROOKMAN: Yes.

6 MR. HOYT: Let me see if, if I

7 understand this. You're saying we should measure

8 these things, but then we don't report them on

9 Energy Guide tag, is that what I'm understanding.

10 MS. REICH: Well, it would be measured

11 for the purposes of calculating an integrated MEF

12 as required under EISA. It's a statutory

13 requirement.

14 But, DOE did, did propose not to change

15 the cost calculation because of the effects on a

16 program outside of DOE at the Federal Trade

17 Commission.

18 MR. HOYT: I'm just -- I find those in

19 violent conflict with one another, and will comment

20 on it further in our written comments. But that's,

21 just is inconsistent.

22 MR. BROOKMAN: Okay, thank you.

23 Joanna.

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1 MS. MAUER: Joanna Mauer.

2 I'm -- I don't know a lot about the

3 Energy Guide label, but I'm a little confused by the

4 statement, because when the new clothes washer

5 Standards go into effect, I'd imagine the, these

6 minimum and maximum operating costs would have to

7 be revised to take the new Standards into account.

8 And so seems like when that happens, the

9 Energy Guide label can, I mean, it has to be

10 revised anyway, I imagine, so I assume, I assume

11 that these additional annual operating costs could

12 be incorporated at that point.

13 I think we just generally support

14 incorporating all the energy use if it's intended

15 to actually represent the annual energy cost of the

16 product, which would include these other modes as

17 well.

18 MR. BROOKMAN: Okay. Other comments?

19 Ed Osann.

20 MR. OSANN: The, the top bullet in this

21 slide says "Active washing mode." Is that

22 particularly to parse out "Active" mode to only

23 the, just the, the wash mode piece?

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1 MS. REICH: Well, it's, it's referring

2 to the existing calculation. The existing

3 calculation is based on the energy use just for the

4 "Wash" mode that's currently part of the metric.

5 MR. OSANN: Okay. So, it doesn't

6 include the pre and post part of the "Active"

7 cycle?

8 MS. REICH: That's correct. Yes.

9 MR. BROOKMAN: Charlie Stephens.

10 MR. STEPHENS: Charlie Stephens.

11 Could I ask you how you define the end

12 of the active washing mode?

13 MS. REICH: That's a topic that we are

14 looking for information on. We don't have,

15 currently have a definition for it.

16 This is based on the existing

17 methodology to measure MEF. This has not been a

18 topic that has been raised before, so we certainly

19 appreciate any information you have on that.

20 MR. STEPHENS: Guess I want to know,

21 then, how manufacturers are, are measuring this

22 now. How do they know when to stop measuring?

23 MS. REICH: I suppose you'd have to ask

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1 the manufacturers.

2 MR. BROOKMAN: But, just so I guess that

3 if, if that was available, if that information was

4 available, that would be useful for the

5 Department's purposes.

6 Charlie.

7 MR. STEPHENS: I'm sorry. I find this a

8 little mind boggling that people can't answer that

9 question.

10 But, okay.

11 MR. BROOKMAN: Maybe in written

12 comments, Charlie.

13 Mike, you have a comment?

14 MR. McGARAGHAN: Yeah, Mike McGaraghan,

15 California utilities.

16 Just a big-picture question that I might

17 be missing something. What does the annual energy

18 cost have to do with the test procedure?

19 How does that factor in?

20 MS. REICH: Because Section 430.23 is

21 part of DOE's test procedures for covered products.

22 It's -- There are calculations provided there, as

23 well as in Appendix J-1 and proposed J-2 that apply

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1 to clothes washers.

2 MR. BROOKMAN: Additional comments?

3 (Whereupon, at 11:25 a.m. ET, no

4 response was had.)

5 MS. REICH: I guess we've covered that

6 one.

7 MR. BROOKMAN: Um-hum.

8 MS. REICH: Okay. At this point I'm

9 going to turn the presentation over to my

10 colleague, Tim Sutherland.

11 MR. BROOKMAN: Do you want to use the

12 microphone up there from the podium, or the

13 hand-held?

14 MR. SUTHERLAND: You might go in case I

15 move from the podium.

16 MR. BROOKMAN: Higher. Good.

17 MR. SUTHERLAND: How's that?

18 MR. BROOKMAN: Yeah. Yeah.

19 MR. SUTHERLAND: Good?

20 MR. BROOKMAN: Just slide --

21 CLOTHES WASHER ACTIVE MODE TEST PROCEDURE:

22 MR. SUTHERLAND: Okay. Hi, everyone.

23 Just to reintroduce myself, I'm Tim

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1 Sutherland with Navigant, part of the Clothes

2 Washer Rulemaking Team. I'm going to go through

3 the "Active" mode portion of the test procedure.

4 And I think we're supposed to break for

5 lunch somewhere around Part B here, so I guess

6 we'll see how far we can get through B before we

7 take your lunch break.

8 MR. BROOKMAN: Our target is to quit

9 rather about 12:30.

10 MR. SUTHERLAND: Okay. All right.

11 So, first we'll get started with

12 technologies that are not covered by the current

13 J-1 test procedure. So, currently J-1 does not

14 cover steam wash cycles.

15 DOE is aware of numerous washers on the

16 market that offer steam wash cycle, and these are

17 seen, for the most part on front loaders.

18 In response to comments in the

19 framework, though, DOE is proposing to include

20 specifications for measuring both water and energy

21 consumption during the steam wash cycles, and DOE's

22 proposing to include a separate section describing

23 the measurement for the steam wash cycles, and to

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1 also include the energy and water consumption

2 values from that cycle in the final calculations.

3 So, DOE is proposing, for washers that

4 have steam cycles, to measure the energy and water

5 consumption of the steam wash cycle using the

6 hottest wash temperature. And along with this,

7 DOE's, therefore, proposing to update the Table

8 4.1.1, which has the temperature use factors.

9 DOE lacks con-, data on consumer usage

10 of the steam cycles, but believes that the

11 inclusion of the steam cycle would decrease the

12 number of extra-hot cycles that can, that the

13 consumer would run.

14 DOE believes that the extra-hot and

15 steam cycles are likely to be reserved for the most

16 heavily soiled loads, with steam cycle selected

17 somewhat less frequently. And so based on this,

18 DOE is proposing to use a temperature use factor of

19 0.02 for the steam-wash cycles, and the extra-hot

20 use factor would be decreased by 0.02.

21 So, extra-hot would go from either .05,

22 would go from .05 to .03, or from .04 down to .02,

23 depending on which set of temperature use factors

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1 apply. So, DOE requests comment on the proposed

2 inclusion of energy and water consumption of steam

3 wash cycles, including the associated use factor.

4 And DOE also requests any data available

5 regarding consumer usage patterns for steam wash

6 cycles.

7 MR. BROOKMAN: JB.

8 MR. HOYT: JB Hoyt, Whirlpool.

9 Tim, on Slide 4 you say many clothes

10 washers on the market offer such a feature. Do you

11 have a definition of "many"?

12 Do you have a percentage?

13 MR. SUTHERLAND: No, I do not have a, a

14 numerical percentage, so -- .

15 MR. HOYT: Neither do I. So, I was

16 hoping that you had one.

17 But, you're saying many do, but

18 "many" is not defined, and you lack consumer data, but

19 you're going to use a two-percent factor for it.

20 MR. SUTHERLAND: That's right.

21 MR. HOYT: Okay. Thank you.

22 MR. WITKOWSKI: Excuse me. Actually

23 what we're asking for --

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1 MR. BROOKMAN: Steven Witkowski.

2 MR. WITKOWSKI: Steven Witkowski.

3 Actually what we're asking for is you

4 have any data that would either support or negate.

5 MR. HOYT: JB Hoyt, Whirlpool.

6 We'll attempt to do so, Steve.

7 MR. WITKOWSKI: Thank you.

8 MR. BROOKMAN: Yes. Please.

9 MR. JOHNSON: Chris Johnson, LG

10 Electronics.

11 To follow-up on JB Hoyt's point is that

12 it's difficult to do this without a definition of

13 what "steam" is. I mean, there's, there's

14 manufacturers in this room that disagree on what is

15 steam.

16 So, without, without a (sic) agreed-upon

17 measurable definition of what "steam" is, how do

18 you know what the water and energy factor of steam

19 is going to be if manufacturers don't even know

20 what steam is? Or, they know what their technology

21 is, but if we can't agree, then how does, how is

22 the DOE going to come up with a, with a definition?

23 MR. BROOKMAN: Kelley Kline.

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1 MR. JOHNSON: That's why this is

2 problematic.

3 MR. BROOKMAN: Thanks, Chris.

4 Kelley?

5 MS. Kline: No, that was what I was

6 going to reiterate, which, Chris's point, that

7 that's what was going to be the point as well, that

8 there needs to be a pretty definitive definition of

9 what is a steam cycle.

10 MR. BROOKMAN: Uh-huh. If, if, if there

11 was that kind of definition, then would you be able

12 to comment knowledgeably on these, these figures

13 here on the bottom of Slide 49, these factors?

14 MS. KLINE: I'm not sure. I'm not sure

15 we would.

16 I'd have to check with -- I'd have to

17 check with others, others at G.E. But, I know, I

18 know just looking at it they thought the critical

19 piece was having a, a real definition around it.

20 MR. BROOKMAN: Um-hum.

21 Other comments?

22 MR. SUTHERLAND: All right. So, we'll

23 talk about self-clean cycles now.

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1 Many clothes washers currently on the

2 market offer a "Self-Clean" cycle. DOE observes this

3 on almost all front loaders; not, not quite all,

4 but almost all, and is starting to see it now on some

5 of the higher-efficiency top-loaders.

6 And Judith went through the, our

7 definition of what's defined as a self-cleaning

8 mode earlier, so I won't go through that again.

9 But, DOE is proposing to include the energy and

10 water consumption that occurs during the

11 "Self-Clean" cycle into the overall efficiency

12 metrics.

13 Also, something to note is that this

14 would benefit clothes washers designs that have

15 ways of addressing mold and odor issues without

16 requiring periodic "Self-Clean" cycles.

17 So, we've, we've discussed this already,

18 but just to review quickly the way that this, that

19 DOE is proposing to incorporate this would be to

20 measure the energy and water consumption of a

21 self-cleaning cycle with no load, multiply that by

22 12, and divide by 295.

23 This effectively apportions the annual

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1 energy and water use of the self-clean cycles among

2 all of the 295 active cycles. And, again, just to

3 note that for the, in the, in the NOPR as

4 published, this step has, was inadvertently

5 omitted.

6 So, that will be corrected in the final

7 version of the test procedure. The -- And by that,

8 I mean the multiplying by 12, then dividing by 295.

9 So, DOE is requesting comment on the

10 self-cleaning cycles for clothes washers, including

11 the proposed definition, the inclusion of the

12 energy and water use of, in IMEF and IWF

13 calculations, and whether there's any relevant data

14 available regarding consumer use of these cycles.

15 MR. BROOKMAN: Ed Osann.

16 MR. OSANN: Just a clarification.

17 You've mentioned that the omission, the omission

18 was in the, the regulatory text? Because this was

19 discussed in the narrative text of the --

20 MR. SUTHERLAND: That's right. The, the

21 omission is in the, the, in the part of the NOPR

22 which is the, the text of the J-2 test procedure.

23 MR. OSANN: The body of the --

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1 MR. SUTHERLAND: Right. It's in the

2 part -- It's in the water-consuming part where it

3 describes how to calculate the water consumption

4 for the self-cleaning cycles.

5 MR. BROOKMAN: You see the comment box

6 there. Comment on self-clean cycles, including

7 proposed definition, inclusion of self-clean cycle

8 energy and water use into the IMEF and IWF

9 calculations, and any other relevant data.

10 Kelley?

11 MS. Kline: Kelley Kline, G.E.

12 I just wanted to reiterate the comment

13 we made earlier about the 12 cycles per year.

14 MR. BROOKMAN: Okay, thank you.

15 Okay.

16 MR. SUTHERLAND: All right. Talk about

17 adaptive control technologies.

18 In general, adaptive control

19 technologies are technologies that can adjust the

20 wash parameters based on load size, fabric mix, the

21 soil level, other, other wash parameters.

22 Currently the J-, J-1 test procedure

23 accounts for adaptive fill control, but no other

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1 adaptive controls. DOE did receive comments in

2 response to the framework document stating that

3 adapt-, adaptive controls are already widely used

4 in clothes washers, but DOE's not aware of any

5 residential clothes washers that use, that

6 incorporate soil-sensing systems.

7 DOE's only aware of clothes washers that

8 use adaptive controls to adjust the fill level, and

9 so DOE lacks data on any other type of adaptive

10 controls that, that may or may not be out there.

11 So, because of that, DOE's not proposing

12 to account for any other adaptive controls other

13 than adaptive fill control in the J-2 test

14 procedure.

15 The demand response technology, we talked

16 about this. This is a Smart Grid feature.

17 Again, I won't reiterate the definition,

18 but at this time DOE's unaware of any clothes

19 washers that currently contain any demand response

20 technologies, and so, therefore, DOE's not

21 proposing to amend the test procedure to include

22 the energy consumption in "Network" mode.

23 Once clothes washers offering these

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1 features and appropriate data and testing

2 methodologies have become available, DOE will, can

3 consider incorporating these amendments into the

4 test procedure.

5 So, I’ll pause here and request comment

6 on whether there are any other clothes, or any

7 clothes washers on the market that offer adaptive

8 controls other than soil sensing, or -- I'm sorry.

9 DOE requests comment on whether there

10 are any washers currently available that do offer

11 soil sensing as well as demand response features.

12 MR. BROOKMAN: Jennifer.

13 MS. CLEARY: AHAM agrees that at the

14 current time there is not sufficient data regarding

15 demand response. However, when it does become

16 available we believe it should be addressed, and we

17 would be glad to provide data once we have it,

18 pursuant to your request.

19 MR. BROOKMAN: Thank you.

20 MR. SUTHERLAND: All right.

21 MR. BROOKMAN: Ed Osann.

22 MR. OSANN: Ed Osann.

23 I think we would reiterate the point

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1 made earlier that, that there needs to be some

2 anticipation of, of the near-term commercialization

3 of, of clothes washers with networking

4 functionality, and at a minimum, some sort of

5 placeholder be established within the context of

6 this version of the test procedure to anticipate

7 that.

8 MR. BROOKMAN: Thank you.

9 Okay.

10 MR. SUTHERLAND: All right. Thanks.

11 So, we'll jump into Part B here, talking

12 about changes that reflect current usage patterns

13 and capabilities of washers. All right.

14 The first -- Again, we've talked about

15 this a little bit as well, the number of annual

16 cycles.

17 Previously DOE has estimated the number of

18 annual cycles as 392, and we, DOE received comments

19 supporting the updating of this value. Currently

20 this value is not actually used in the, in the

21 calculations for MEF or water factor in the J-1

22 test procedure.

23 However, as we've discussed, it will

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1 factor into the J-2 test procedure, specifically as

2 part of the calculation for self-cleaning energy.

3 So, DOE considered these three data sources to,

4 when determining how to update this number.

5 The EIA's 2005 residential energy

6 consumption survey, or RECS, the 2004 California,

7 California Residential Appliance Saturation Survey, RASS, and

8 a data submittal from Procter & Gamble -- And you

9 can see the number of annual use cycles was 295

10 from RECS, 283 from RASS, and 308 from P&G.

11 So, just a little more detail about how

12 DOE looked at these. So, DOE believes that the

13 RECS data is the most representative of, of

14 consumers throughout the country.

15 The California RASS data is only for

16 consumers in that one State. Sim-, or separately

17 the P&G data submittal, the data set used for that

18 had fewer single-person households than suggested

19 by the most recent Census survey, so we believe, or

20 DOE believes that that may slightly overestimate

21 the number of cycles.

22 And so, based on this, DOE concluded

23 that 295 cycles per year is a reasonable estimate

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1 of actual consumer use. And DOE welcomes comment

2 on the proposal to use 295 clothes-washer cycles

3 per year.

4 MR. BROOKMAN: Ed Osann.

5 MR. OSANN: Was there a date provided on

6 the P&G submittal?

7 MR. SUTHERLAND: I've -- Off the top of

8 my head, I, I'm not sure.

9 MR. BROOKMAN: Charlie Stephens.

10 MR. STEPHENS: Yeah, I think, Ed, it was

11 about the same time as the RECS. I think it was

12 about 2005, if I'm not mistaken.

13 MR. BROOKMAN: Mike, do you know?

14 MR. LAW: I believe it was about that

15 time, also.

16 MR. BROOKMAN: Okay.

17 Charlie Stephens.

18 MR. STEPHENS: Charlie Stephens.

19 MR. BROOKMAN: Which, to say that Mike

20 from NIST, did you just comment there? Say your

21 name for the Record.

22 MR. LAW: Sure. Michael Law. Michael

23 Law, from NIST.

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1 MR. BROOKMAN: Thank you. Thank you.

2 Thank you.

3 Charlie Stephens.

4 MR. STEPHENS: I'm looking at the survey

5 instrument for RECS, and when it comes to

6 clothes-washer cycles, we didn't find that the

7 range of response offered was very credible. That

8 -- I think there were only three ranges offered and

9 there's such a varied range between the responses,

10 allowed I think, you know, five to ten loads per

11 week, there's a big difference between nine and six

12 when we start talking about this.

13 But, there's no way to know from the

14 RECS survey responses what the number is. There's

15 such a huge gap in there that, quite frankly, we

16 don't find the RECS data very credible just because

17 the survey was designed badly for that metric.

18 However, the P&G data was backed up

19 rather well by the recent California data, which I

20 think was something on the order of 310 annual

21 cycles. So, it's, it's very close to what P&G

22 found.

23 And I think overall we find the P&G data

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1 to be more credible than either the RECS data or

2 the California RASS data, which we agree had a, a, a

3 misaligned household size in its sample.

4 MR. SUTHERLAND: Okay.

5 MR. BROOKMAN: So, Charlie, would you

6 comment specifically on the number here, 295?

7 MR. STEPHENS: We think, as I said, we

8 think the P&G would be closer to what we like,

9 which would be 308.

10 MR. BROOKMAN: Thank you. Just want to

11 be specific.

12 MR. SUTHERLAND: And DOE would welcome

13 any additional data such as the CPUC, which, you

14 know, --

15 MR. STEPHENS: That was delivered in

16 August, so I think that's available.

17 MR. BROOKMAN: Steven Witkowski.

18 MR. WITKOWSKI: Also we would welcome,

19 if there's any question or concern about the data,

20 the problems and methodologies that you have with

21 it so we could examine those in light of how we

22 examine them.

23 MR. BROOKMAN: Thank you.

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1 Joanna.

2 MS. MAUER: Joanna Mauer.

3 I was just wondering whether the

4 proposed 295 cycles per year matches up with the

5 proposed number of cycles in the dryer test

6 procedure, accounting for the dryer use factor.

7 MR. SUTHERLAND: I'll have to turn that

8 over to Judy.

9 Does the number of -- Does the 295

10 cycles proposed here match up with the number of

11 cycles in the dryer, the proposed dryer test

12 procedure?

13 MR. BROOKMAN: Judy Reich.

14 MS. REICH: Judy Reich.

15 Yes, I believe that if -- I know the

16 dryer number of cycles were not based on the 293.

17 They're -- I think the proposed value is 273.

18 And I think that's intended to account

19 for about an 80- or 84-percent usage factor. So,

20 so I think it's close.

21 I, I can't say for sure, but I think

22 it's, it's based on a number that's in the 340

23 range rather than the existing number.

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1 MR. SUTHERLAND: Thanks.

2 MR. BROOKMAN: Ed Osann.

3 MR. OSANN: Yeah. Apologies if I missed

4 it and it was in the Federal Register Notice, but

5 the slide refers to a data submittal from Procter &

6 Gamble.

7 Is there a more specific cite for that?

8 And, and in what proceeding was that entered into

9 the public domain?

10 MR. SUTHERLAND: Judy, do you have any

11 recollection of that?

12 MS. REICH: No. I think we'll have to

13 get back to you on that on the cite.

14 MR. SUTHERLAND: Yeah.

15 MR. BROOKMAN: Okay.

16 MR. OSANN: Was it a submittal to DOE?

17 Can, can you tell us that?

18 MS. REICH: I believe it was.

19 MR. BROOKMAN: So, Judy says she

20 believes it was a submittal to DOE.

21 But, you can check on that.

22 MS. REICH: Yes.

23 MR. BROOKMAN: Thank you. Okay, we're

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1 going to keep going.

2 MR. SUTHERLAND: Okay, thanks.

3 All right, test load size

4 specifications. So, currently in J-1 it's Table

5 5.1 giving the specifics, the test load sizes as a

6 function of clothes container volume.

7 And the table goes up to 3.8 cubic feet.

8 DOE is aware of numerous clothes washers available

9 on the market that have volumes that exceed this

10 level, and multiple stakeholders commented that

11 this table needs to be updated.

12 In the past, DOE has granted an interim

13 test procedure Waiver to Whirlpool for three

14 clothes washer models that had capacities greater

15 than 3.8 cubic feet, and this test procedure

16 concerns the linear relationship between the next

17 test, test load size and the container volume to

18 include containers of 3.8 to 3.9 feet.

19 Additionally, DOE's aware of only

20 limited data regarding typical clothes washer load

21 sizes. That leads into this part of the

22 discussion.

23 The one 2003 P&G study showed an

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1 average load of 7.2 pounds for top loaders, 8.4

2 pounds for front loaders. And this would

3 correspond to the, the 2.7-cubic-foot bin and the

4 2.3-cubic-foot bins.

5 And these numbers look to be pretty

6 compatible with the shipment-weighted average

7 capacity reported in the 2005 AHAM Fact Book, which

8 is, is 3.05 cubic feet. So, those numbers looked

9 to be pretty reasonable.

10 Separately, AHAM data shows that from

11 '90-, 1993 to 2005, tub capacities have increased

12 by about 14 percent. And RECS data indicate that

13 the number of cycles per year during that same time

14 period has decreased by a similar amount, by

15 roughly 17 percent.

16 So, this leads to the conclusion that if

17 you assume that households continue to wash the

18 same volume of clothes each year, that the average

19 load size is increasing with capacity. So, this

20 limited data suggests that the current values in

21 the test loads size table are appropriate, and that

22 extending that linear relationship between test

23 load size and container capacity is valid.

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1 And so DOE is proposing to extend Table

2 5.1 to include volumes up to six cubic feet. And

3 DOE welcomes comment on the proposed test load

4 sizes, on whether the linear relationship between

5 test load size and container volume is

6 representative of actual consumer use.

7 And, as always, DOE invites any relevant

8 data on this topic.

9 MR. BROOKMAN: Kelley.

10 MS. KLINE: Kelley Kline, from GE.

11 Yeah, we would support this. We think

12 it's necessary to reflect the current market

13 reality, and we just note that there's been, DOE

14 has granted additional interim Waivers going up to

15 4.4 cubic feet, including one to G.E. a few months

16 ago.

17 MR. BROOKMAN: Okay. Thank you.

18 Ed Osann.

19 MR. OSANN: Ed Osann.

20 While, while much of the, the material

21 here on Slides 61, 62 is, is sort of intuitively

22 understandable, and we're, we're not in a position

23 to, to disagree with the, the notion that average

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1 load size increases with capacity, we would point

2 out that there, there does still seem to be a

3 potential concern here for bias in the test

4 procedure towards larger-capacity machines due to

5 the fact that the, the average load does not

6 increase proportionately with the machine capacity.

7 The way the, the, the, the average loads

8 are, the relationship between the three loads is

9 constructed, the -- And, and, and I would point out

10 also that the average load does dominate the

11 results of the test procedure because of the usage

12 factor, the maximum load is, is the maximum load.

13 So, that tracks the, tracks the increase

14 in the machine capacity directly. The minimum load

15 is a specific number that doesn't move.

16 So, it does not track the machine

17 capacity directly, and the average load is, is

18 anchored by that minimum load to the extent that

19 it's, it's, it's not a fixed percentage of total

20 capacity, but it's the difference between the, the

21 minimum and the maximum.

22 So, the average load under the current

23 test procedure, and as, as DOE would propose to

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1 extend it, the average load shrinks as a percentage

2 of machine volume as the machine volume increases.

3 So, for smaller-capacity machines, the average load

4 may be, may represent 65 percent of capacity, and a

5 larger-capacity machine, the average load may

6 represent 54 percent of capacity because of,

7 because that, because it's anchored to a specific

8 minimum load that does not change.

9 So, this is a concern. We think this is

10 the, this is probably the basis of, of, of

11 potential for bias towards large-capacity machines.

12 This would suggest that as consumers

13 move up the, the, the scale in terms of their

14 purchases of, of clothes washers, they buy a larger

15 machine and, and use, and, and, and, and leave more

16 capacity unused, relatively speaking.

17 And we're not sure that there's really

18 any data to support, to support that.

19 MR. BROOKMAN: So, you question the

20 linear relationship that is positive here.

21 MR. OSANN: Yeah. I mean, it may be

22 linear, but it's not proportionate.

23 MR. BROOKMAN: Okay. So, that --

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1 Certainly the Department would really welcome data

2 on that, your, your, your, your viewpoints on that.

3 Judy.

4 MS. REICH: Judy Reich, from Navigant.

5 I would also invite comment on whether

6 the concern is with the fixed minimum load size or

7 with the calculation of the average load size as

8 the mid-point between the maximum and minimum. Is

9 it in --

10 MR. OSANN: Right.

11 MR. BROOKMAN: Humm. Thank you.

12 Yes, Chris.

13 MR. JOHNSON: Chris Johnson, LG

14 Electronics.

15 We just also support DOE's proposal, and

16 we agree with GE's comments.

17 MR. BROOKMAN: Thank you.

18 Jennifer.

19 MS. CLEARY: Jen Cleary.

20 I just have a question. I mean, we

21 support the table, and we have a question about

22 whether it was intentional that the values in

23 the table don't exactly match to the AHAM proposal.

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1 And if it wasn't intentional, we're just

2 curious to know why.

3 MR. SUTHERLAND: Judy, does, did you

4 want to comment on that?

5 MS. REICH: Judy Reich.

6 There were some very slight differences

7 that were introduced based on conversion factors

8 from pounds to kilograms, and where the rounding

9 takes place. I'd also like to point out that there

10 was no intentional message implied by the

11 formatting in the Federal Register Notice that

12 dropped off trailing decimal zeros in the, the

13 decimal places.

14 Those should all be expressed to two

15 significant digits, the load sizes.

16 MS. CLEARY: Thank you.

17 MR. WITKOWSKI: And just one other thing

18 to note. Some of the heading, some of the headings

19 were printed incorrectly, so those were, clerical

20 errors will be fixed for the Final Rule.

21 MR. BROOKMAN: Mike, do you want to

22 comment?

23 MR. LAW: Yeah. Mike Law with the

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1 California utilities.

2 Mostly just wanted to echo Ed's comments

3 a moment ago that we're concerned that the, the

4 calculation could include some bias towards large

5 machines, and encourage DOE to look into that

6 further, especially the, the anchor at three pounds

7 per load.

8 And, unfortunately, we're not aware of

9 data at this time, but that is something that we'll

10 consider trying to gather at some point in the

11 future, although it's unlikely that we'll have

12 anything in time for this rulemaking. So, --

13 MR. BROOKMAN: Okay.

14 MR. LAW: -- we encourage DOE to look

15 into that issue.

16 MR. BROOKMAN: Yes. Please say your

17 name for the Record.

18 MR. KANG (phonetic): John Kang

19 (phonetic).

20 I look, I looked in that customer can

21 reduce number of, by using bigger drum for loads

22 per year, by using bigger drum. So, I think the

23 number wash size per year should be different by --

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1 MR. BROOKMAN: Did you say who you're

2 representing?

3 MR.KANG: LG Electronics.

4 MR. SUTHERLAND: And otherwise --

5 MR. KANG: And also test tub size in

6 Table 5.1 should be the same for all the, all the

7 size of, size of the machine.

8 MR. SUTHERLAND: I just wanted to

9 clarify. So, for -- for the first part, and also

10 the second part.

11 So, do you mean that the maximum test

12 load size, you're saying, should be the same for,

13 for all washers?

14 MR. KANG: Yes. Right.

15 MR. SUTHERLAND: Regardless of size.

16 And then what was your first point, again? I had a

17 clarifying question on that.

18 MR. KANG: The number of wash cycle per

19 year should be depreciated by the volume.

20 MR. SUTHERLAND: So, so -- Okay.

21 MR. BROOKMAN: Okay.

22 Yeah, Chris.

23 MR. JOHNSON: Chris Johnson, LG. LG.

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1 I can clarify what we're saying, what

2 the container capacity -- The volume is different

3 for the, if the, if the large capacity, large

4 container -- If you have different sizes, then the

5 cycles are different.

6 MR. BROOKMAN: Right.

7 MR. JOHNSON: So, what we're saying, to

8 make it really accurate is, you know, you make a

9 distinction between the size and the volume of the

10 container, because the larger of the container, the

11 larger the volume, the less the cycles.

12 I think I've got that right.

13 (To Mr. Kang): Is that correct?

14 MR. BROOKMAN: Thanks, Chris.

15 MR. JOHNSON: I'm not the engineer, so

16 --

17 MR. BROOKMAN: Okay. Okay.

18 MR. SUTHERLAND: All right?

19 MR. BROOKMAN: Yeah.

20 MR. SUTHERLAND: Okay. Just move along.

21 MR. BROOKMAN: Ed?

22 MR. OSANN: I just wanted to add one

23 final point, and that is to the extent that the

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1 current table and the, the, the method for

2 fashioning the average load size and the minimum

3 load size has the potential for bias towards,

4 towards larger machines, I would just point out

5 that this phenomenon will be, will be even more

6 significant as the table is expanded to accommodate

7 even larger machines with, within the scope of the

8 test procedure.

9 MR. BROOKMAN: Steve Witkowski.

10 MR. WITKOWSKI: I think we've heard a

11 number of concerns here about the methodology that

12 was used, and perhaps that we make our

13 calculations and possibility for, you know, future

14 compliance issues.

15 It would really help, if you disagree

16 with the methodology, and it's not just a matter of

17 the data, it's also a matter of what's included in

18 the calculations, what weighting factors, if any,

19 should be used, that, besides just general

20 concerns, if you have alternative methods of

21 performing these calculations, please make us aware

22 of them, because we definitely will look at them

23 and we'll take them into consideration.

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1 But, it's difficult to just say, "Yes,

2 we understand the concern." If you give us

3 something that is substantive, you know, that

4 reflects your concern, then we can act upon it.

5 MR. BROOKMAN: Thank you.

6 Yes, Mike, from NIST.

7 MR. GALLER: Hi. Mike Galler.

8 I want to comment on the number of

9 cycles per year per volume of the clothes

10 container. It seems like the machines you push

11 that have the higher volume to wash may not be a

12 representative, and it seems like this would be

13 something that would be good to see more consumer

14 usage on to see if there was actually a difference

15 in use on that, and how big a difference it is.

16 MR. BROOKMAN: Mike, your comment, is it

17 based on, on some analysis, or your experience, or

18 can you say?

19 MR. GALLER: We're guessing that people

20 who need to do more laundry are going to buy the

21 bigger machines.

22 MR. BROOKMAN: Okay. Thank you.

23 MR. GALLER: And this may be, this data

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1 could be -- I say it deserves another look, and

2 that if anybody else has any other consumer use

3 data, that would be good to submit it.

4 MR. BROOKMAN: Okay. Thanks.

5 Okay.

6 MR. SUTHERLAND: Okay. So we move on

7 and talk about the load size use factors.

8 These are the factors that specify the

9 fraction of all cycles run with minimum, average,

10 and maximum loads. DOE received comments

11 suggesting that DOE should validate the use factors

12 from the, from the test procedure.

13 However, DOE is not aware of any recent

14 data that characterizes such load patterns, and so,

15 therefore, DOE is not proposing to update the load

16 size of these factors currently used in the test

17 procedure.

18 And, of course, DOE welcomes input and

19 data on consumer selection of sizes.

20 Temperature use factor: So, as prev-,

21 as we've previously stated, DOE is proposing to

22 amend the temperature use factors, which I'll just

23 call the TUFs in the clothes washer test procedures

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1 to account for steam wash cycles. And DOE also

2 investigated whether the other TUFs in the test

3 procedure are valid.

4 So, RECS, 2005 RECS and the California

5 RASS both provide some data for "Hot," "Warm," and

6 "Cold" settings, but no extra information on the

7 extra-hot cycles or steam-wash cycles. The 2005

8 RECS questionnaire on-, asked respondents only for

9 the water temperature selections that they use,

10 usually use.

11 And, therefore, DOE thinks that that

12 data may not account for cycles that are used less

13 frequently, such as the "Hot" wash cycle. The RASS

14 questionnaire asks for the number of wash loads per

15 week at each temperature, and therefore likely does

16 capture the "Hot" washes.

17 But, that survey only represents

18 consumers in one State. So, the following table

19 summarizes the TUFs as determined from the two

20 surveys and compared to the current test procedure

21 values.

22 Current test procedure values are on the

23 left. RECS is in, in, in the middle, and the RASS

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1 are on the right. So, DOE, DOE believes that the

2 comparison of these TUFs shows that the current

3 values in the J-1 test procedure are a reasonable

4 estimate of current consumer use, and therefore is

5 not proposing to amend the existing TUFs for

6 clothes washers that don't have a, a "Steam-Wash"

7 cycle.

8 And I know we've -- I thought we had a

9 comment box there, but, okay. Actually, let's,

10 let's ask for comments on that.

11 That way we can move on to the, to the

12 one that's after this.

13 MR. BROOKMAN: Yes. Charlie Stephens.

14 MR. STEPHENS: Charlie Stephens.

15 I can't speak to the exact numbers, but

16 my sense of the most recent California data would

17 support the current test procedure TUFs that you're

18 using, so --

19 MR. BROOKMAN: Thank you. Okay.

20 Other comments on these temperature-use

21 factors?

22 MR. SUTHERLAND: We're going to talk

23 about the warm rinse one in a little more detail in

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1 the next few slides.

2 MR. BROOKMAN: Let's proceed, then.

3 MR. SUTHERLAND: Okay. So, for the

4 temperature use factor for the warm rinse.

5 So, DOE notes that it recently received

6 consumer usage survey from a single manufacturer

7 for a clothes washer model that does not offer the

8 warm rinse cycle as part of it, the normal cycle

9 that's recommended for cottons. This data for this

10 washer indicated that users used the cycle roughly

11 1.6 percent of the time, and that that would

12 correspond to, to .016.

13 But, DOE does, does not believe that

14 this conclusion necessarily applies to all

15 consumers and all types of residential clothes

16 washer models, so DOE's not proposing a revision to

17 the warm rinse temperature use factor at this time.

18 However, DOE does remain open to a

19 consideration of warm rinse, and welcomes any data

20 that can be provided regarding --

21 MR. BROOKMAN: Chris.

22 MR. JOHNSON: Chris Johnson, LG

23 Electronics.

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1 You know, one of the consumer use of

2 this is the percentage of detergents that's

3 purchased by consumers that you use in cold water.

4 So, if you knew that, let's say, for instance, 85

5 percent of the detergent that was purchased in the

6 U.S. was cold, cold-water detergent, then that

7 ought to tell you, you know, that warm rinse is

8 probably a very, very, very low factor, and

9 probably, even though this is another data, it

10 does, nevertheless, represent just one manufacturer.

11 But, if you, if you use other, other

12 evidence of laundry purchasing and, and use in, in

13 the U.S. not related directly to the performance of

14 the machine, that would, that would give you some,

15 some indication.

16 MR. BROOKMAN: Okay. Thank you.

17 J.B. Hoyt.

18 MR. HOYT: JB Hoyt, at Whirlpool.

19 Has the Department done any analysis of

20 the machines on the marketplace to understand what

21 the presence is of warm rinse cycles?

22 MR. SUTHERLAND: I don't believe the

23 Department has done any sort of comprehensive

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1 survey of that specific feature. No, that, not

2 that I'm aware of.

3 MR. HOYT: The reason I ask is because I

4 would suggest that if you did, the, the data would

5 show that the 27 percent is current, quite out of

6 line with current water practices. And we'll

7 endeavor to provide more detail in our written

8 remarks.

9 MR. RICHARD: Doug?

10 MR. BROOKMAN: Yes, Rich.

11 MR. RICHARD: I'd like to add to JB's

12 comments by inviting all manufacturers to provide

13 some sort of manufacturers to, to basically confirm

14 that the washing warm rinse cycle is no longer

15 available on 28 percent of these machines, as in

16 the current test procedure.

17 MR. BROOKMAN: Okay.

18 Kelley.

19 MS. KLINE: Just to reiterate that,

20 we'll also work on providing the data, but our

21 conclusion is really the same, that it's actually

22 very rare.

23 MR. BROOKMAN: Okay.

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1 MR. SUTHERLAND: Okay. Okay, thanks.

2 So, I will talk about, now, the warm

3 rinse methodology. So, in the current J-1 test

4 procedure, the way the warm rinse is factored in is

5 by applying a temperature use factor of .27 to the

6 incremental energy that's consumed in the "Warm"

7 cycle as compared to the energy used in the

8 "Warm/Cold" cycle.

9 So, the incremental energy only applies

10 to that part of the, the rinse cycle that uses

11 additional energy, hot-water energy. This is, can,

12 can be problematic for some clothes washers.

13 It's not entirely clear when the wash

14 cycle ends and when the rinse cycle begins, because

15 DOE is aware of some clothes washers that do

16 multiple fill and rinse cycles or events in a

17 single cycle occurring in varying sequences.

18 So, to simplify the warm rinse

19 measurements, DOE's proposing to account for the

20 energy and water consumption over an entire

21 "Warm/Warm" cycle the same way that energy and

22 water consumption would be measured for any of the

23 other temperature combinations.

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1 And DOE believes that this is

2 appropriate, because most clothes washers currently

3 available allow users to select a warm rinse within

4 a warm wash. So, on the, on the machines that

5 offer warm rinse, and DOE believes that it's pretty

6 much always paired with a warm wash.

7 So, DOE proposes to eliminate the

8 incremental use factor currently attributed to warm

9 rinse, and DOE believes that, assuming the warm

10 rinse would still apply, DOE's proposing to apply

11 that to the entire portion of the "Warm/Warm"

12 cycle.

13 Subsequently, DOE proposes to reduce the

14 "Warm/Cold" temperature use factor from, from .49

15 to .22 to reflect that difference. Clothes washers

16 that don't offer a warm rinse would still use the

17 "Warm/Cold" temperature use factor of .49.

18 DOE believes that this revised

19 methodology for incorporating warm rinse does not

20 change the intent of the test procedure. Overall,

21 the warm wash and warm rinse temperature selections

22 are receiving the same weight in the final

23 calculations.

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1 Another issue regarding warm rinses, DOE

2 recognizes that not all clothes washers offer a

3 warm rinse in the normal cycle that's recommended

4 for cottons and linens. So, if a

5 warm-wash/warm-rinse cycle is available in

6 any other wash cycle setting that has agitation,

7 spin speeds and wash times that are largely similar

8 to the normal cycle, then the "Warm/Warm" cycle

9 should be tested using the wash cycle that best

10 reflects typical consumer use.

11 As a result of this, the calculated MEFs

12 for these types of clothes washers could differ

13 under the proposed method compared to the current

14 method in J-1 because in J-1 the warm wash portion

15 would be conducted under the normal cycle, but

16 according to this proposed definition the warm, if

17 the "Warm/Warm" occurs in a cycle outside of the

18 normal cycle, those parameters may differ, and thus

19 that would affect the MEF calculation.

20 So, DOE expects to analyze the potential

21 effects of this proposed methodology on MEF, and

22 plans to incorporate any such effects that it

23 observed into the amended Standards for IMEF,

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1 Integrated Modified Energy Factor.

2 Let's, let's pause for questions on

3 that, because that's, that's a pretty big topic.

4 MR. BROOKMAN: Yeah, good.

5 Comments on these slides regarding warm

6 rinse methodology?

7 (Whereupon, at 12:12 p.m. ET, no

8 response was had.)

9 MR. BROOKMAN: No comments.

10 MR. SUTHERLAND: Okay. So, the clothes

11 dryer usage factor, DOE investigated whether the

12 dryer usage factor of .84 in the J-1 test

13 procedures still reflects current usage factors.

14 And dryer usage factor is used to

15 calculate the drying energy consumption. So 2005

16 RECS and 2004 RASS both include data on clothes

17 washer and clothes dryer use.

18 The data, the data from those is shown

19 here for RECS. It's .95 for households that have

20 both a washer and a dryer, .95 for all households

21 that have a washer.

22 And for RASS it's .86 for

23 households that have a washer and dryer, and .76

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1 for households that just have a washer.

2 So, DOE, DOE is proposing a dryer usage

3 factor of .91 based on the 2005 RECS data for all

4 households with a clothes washer, and DOE is

5 proposing to use the 2005 RECS data in order to

6 maintain consistency with the data source that was

7 used for the number of annual cycles.

8 For the load adjustment factor, this,

9 the, the load adjustment factor represents the

10 ratio of the typical consumer load size to the

11 maximum-number test load, maximum, maximum test

12 load size. It's used in the calculation of energy

13 required to remove moisture from the test load.

14 DOE lacks information that would warrant

15 adjusting this volume or changing from the, a fixed

16 value. So, therefore, DOE's not proposing to

17 change the load adjustment factor from the current,

18 currently in the clothes test procedure.

19 So, at this point we'll request comments

20 on the validity of using the proposed temperature

21 use factors. Additionally, DOE seeks comment on

22 proposed revision of warm rinse measurements, and

23 the methodology that goes along with that.

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1 And, DOE also welcomes comments

2 regarding the proposed load adjustment factor to be

3 used in the RMC calculation. And, as always,

4 stakeholders may submit any additional relevant

5 data regarding these use factors.

6 MR. BROOKMAN: So, dryer, clothes dryer

7 use factors, load adjustment factor, comments on

8 those?

9 (Whereupon, at 12:14 p.m. ET, no

10 response was had.)

11 MR. BROOKMAN: Nothing additional? I'm

12 going to suggest we pause now for lunch.

13 It's 12:15. I think we're pretty much

14 on schedule.

15 We may be even just a tad ahead of

16 schedule.

17 (Whereupon, at 12:15 p.m. ET, those

18 present took a brief recess and returned at 1:22

19 p.m. ET. Mr. Taylor was not present. The

20 following occurred:)

21 MR. BROOKMAN: Okay, let's resume.

22 MR. WITKOWSKI: Okay.

23 MR. BROOKMAN: We are going to pick up

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1 where we left off, which, I believe, is Slide 74.

2 And Timothy Sutherland is presenting.

3 MR. SUTHERLAND: Thanks. Tim Sutherland

4 with Navigant.

5 So, we left off, we're still talking

6 about the active-mode test procedure provisions,

7 and so now we're going to talk about provisions

8 related to the test cloth.

9 MR. BROOKMAN: I see Ed has a comment,

10 and, before you go on, Tim. And I'm just, I'm

11 going to hand out now these.

12 The Department of Energy has created

13 photocopies of the business cards of those that

14 registered today, so let's just pass these out for

15 those in the room.

16 Ed, can you take these and pass them

17 down? Thank you.

18 And, Ed Osann has a question.

19 MR. OSANN: Yeah. Before we moved on, I

20 had a question on the last slide that was up before

21 the break, --

22 MR. SUTHERLAND: Sure.

23 MR. OSANN: -- and that was 72, the load

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1 adjustment factors.

2 MR. SUTHERLAND: Um-hum.

3 MR. OSANN: This is load adjustment

4 factor for the purposes of the RMC computation, I

5 believe.

6 MR. SUTHERLAND: Yes. That's right.

7 MR. OSANN: And we had raised, raised a

8 question about this in the framework comments. And

9 it, it doesn't -- Seems, though, there's a

10 particular response here to the concerns we raised

11 at the framework stage.

12 It's just not at all clear where, why

13 this load adjustment factor used to scale the

14 calculated energy consump-, for actual consumer

15 usage is different from the more generally

16 applicable factors applied to usage, minimum,

17 average, and maximum load size.

18 What -- It just seems conceptually

19 inconsistent to have two different approaches with

20 two different numeric outcomes for essentially the

21 same task relating to trying to gauge actual

22 consumer usage.

23 MR. SUTHERLAND: So, correct me if I'm

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1 wrong, Judy, but the load adjustment factor, it's

2 used in the RMC calculation. And the RMC, you, you

3 run the RMC test with a max test load.

4 However, there's a recognition that most

5 consumers aren't always going to use the max test

6 load. So, the load adjustment factor is a factor

7 that's applied to that to represent a more

8 representative load size than a consumer will

9 likely use.

10 MR. OSANN: But, hasn't DOE, elsewhere

11 in the test procedure, identified very specific

12 proportions of the maximum, the minimum, and the

13 average load size?

14 MR. SUTHERLAND: Well -- Oh, Judy, do

15 you have, do you have a comment or response?

16 MS. REICH: Yes. This is Judy Reich.

17 I think there's potential for some

18 confusion because we use the term "average." In

19 the Table 5.1, those are intended to represent the

20 maximum, minimum, and, ”average” size based on

21 the available space within that machine, the

22 capacity of the machine.

23 But, that's not necessarily how

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1 consumers actually use the product. And so the

2 load adjustment factor is to get at the consumer

3 usage for a machine with that particular available

4 capacity.

5 MR. BROOKMAN: Go ahead, Ed.

6 MR. OSANN: But, there is a, there is a

7 frequency that is assigned to average, minimum, and

8 maximum. I believe it's something like 78, 12, and

9 14, --

10 MR. SUTHERLAND: Right.

11 MR. OSANN: -- or roughly those, those

12 proportions.

13 There's a weighting factor for assigning

14 the frequency of use for average, minimum, and

15 maximum loads.

16 MS. REICH: So, is your comment that you

17 would --

18 MR. OSANN: Why, why would, why would

19 this be -- Why would you have a single, a single

20 adjustment factor here, when you've got simply a

21 different approach to respond to the same issue

22 elsewhere in the test procedure?

23 MS. REICH: Well, in terms of needing a

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1 single value -- that is in order to scale the RMC

2 measurement, which needs to be scaled by one value

3 that could represent or could be developed from the

4 weighted values for the minimum/maximum, and

5 average elsewhere.

6 And so I guess maybe my question is,

7 would you, are you advocating that DOE combine

8 those three values used elsewhere to define the

9 LAF? Is that what you're recommending in --

10 MR. OSANN: That may be one way to

11 approach it, yeah. It just seems like this is a, a

12 different approach, and not mutually consistent.

13 It's possible that, that you could still

14 come with one number, but it would be based on the

15 distribution of the three values elsewhere. But

16 here it just seems to be completely different, you

17 know, derived from some completely different field

18 study, or something done, you know, 15 or 20 years

19 ago and, and carried forward.

20 And it just seems inconsistent,

21 internally inconsistent.

22 MR. BROOKMAN: But -- Charlie Stephens.

23 MR. STEPHENS: Charlie Stephens.

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1 I'm trying to understand what you end up

2 with here after the application of the LAF. Are

3 you simply calculating the, indirectly here the

4 amount of moisture to be removed by the clothes

5 dryer by reducing the size of the load and its,

6 therefore, moisture loading, but at a constant RMC

7 value?

8 MR. SUTHERLAND: The, the -- Where the

9 load adjustment factor used, is used is in the

10 calculation of determining the energy required to

11 remove the, the moisture from the cloth. And part

12 of that is the factors in the RMC value, which is

13 a, a, a fixed value for that washer.

14 So it's 40 percent or 45 percent or

15 whatever that washer has to be. But, that RMC

16 measurement was made using a max test load.

17 So, in estimating the dryer energy

18 consumption, you, you want to use a more

19 representative test load in doing that. And so

20 that's why this factor is applied to RMC.

21 I'm not sure if that answers your

22 question.

23 MR. STEPHENS: Well, I guess, no, it

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1 doesn't. I'm trying to understand what you're

2 scaling.

3 What, what are you, what, what number do

4 you multiply the LAF times? What is it you're

5 multiplying here?

6 MR. SUTHERLAND: It's, it's --

7 MS. REICH: If you don't have that, Tim,

8 --

9 This is Judy.

10 -- I have it.

11 MR. BROOKMAN: Yeah. Into the

12 microphone, Judy.

13 MS. REICH: Okay. It's Judy Reich.

14 Section 4.3.

15 MR. BROOKMAN: And it's in a table in

16 the Federal Register Notice.

17 MS. REICH: It is a section of the

18 Federal Register language in the Federal Register,

19 Volume 75, Page 57593. So, the load adjustment

20 factor's multiplied by the maximum test load

21 weight, and it's multiplied by the difference

22 between the measured RMC and the nominal

23 end-of-drying cycle RMC, which is four percent.

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1 It is also multiplied by the nominal

2 energy required to remove moisture from a, -- Let's

3 see. -- to, from clothes.

4 It's a factor of half a kilowatt hour per

5 pound multiplied by the dryer usage factor. So,

6 it's, by changing the LAF, it scales the per-cycle

7 energy consumption for removing moisture

8 proportionately with, with the load adjustment.

9 MR. SUTHERLAND: So, if you do -- If you

10 did not apply this factor, your dryer energy

11 consumption would be a measure of how much energy

12 was required to remove the water from a maximum

13 test load size. So, by applying this factor, it

14 brings that down to the amount of energy required

15 to remove moisture from a more representative load

16 size.

17 MR. BROOKMAN: Ed.

18 MR. OSANN: Yeah, I just wanted to, for

19 the Record, I just wanted to clarify, because I was

20 going from memory a moment ago. The load usage

21 factors are 12 percent maximum, 74 percent average,

22 and 14 percent minimum.

23 And I can see how for the, in, in

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1 Section 4.3 it may be convenient to reduce this to

2 a single number, a single value, the, the LAF, for

3 conversion, but I don't see how an LAF of .52 is

4 consistent with distribution of the load use

5 factors that are used elsewhere.

6 MR. BROOKMAN: Okay.

7 MS. REICH: Um-hum.

8 MR. BROOKMAN: Okay. Charlie.

9 MR. STEPHENS: Charlie Stephens.

10 And I'll say, yeah, it occurs to me,

11 too, that it doesn't really take into account,

12 unfortunately, the notion that the remaining

13 moisture content is probably different for

14 different load sizes. But, I guess we've elected

15 not to do that.

16 MR. BROOKMAN: Additional comments on,

17 on this slide, that load adjustment factor? Paige,

18 um-hum.

19 MS. DETRICK: Just to respond to the

20 last comment, -- This the Paige, from BHS.

21 Arguably the fact that the single factor

22 doesn't perhaps cover, and need to be some careful

23 math to figure out if it will jive with the LAFs or

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1 not, but arguably that already is taking into

2 account the difference between RMCs based on the

3 different load size that could occur.

4 MR. BROOKMAN: Okay.

5 Yes, Mike.

6 MR. JOHNSON: Mike, with the California

7 utilities.

8 I just wanted to echo that it does seem

9 to us to be an inconsistency as well between the

10 LUFs and the LAFs. And, granted, this might not be

11 the especially careful amount that you were

12 reaching to have, but just a quick calculation

13 here.

14 If LAF is a ratio of typical consumer

15 load size to maximum load size, that's a ratio that

16 changes dramatically based on maximum load size in,

17 in the other part of the test procedure. So, for a

18 small, small washer, we're talking about 75, 70

19 percent, and for larger washers, it's, that ratio

20 is closer to 55, 50 percent.

21 And so in the load-adjustment-factor

22 portion of the test procedure, that's a constant

23 value. So, --

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1 MR. SUTHERLAND: Well, I think, again,

2 there's a difference between the word "average" as

3 it's -- When you were just doing those

4 calculations, I'm assuming you were doing them

5 based on Table, the table of min., average, and max

6 values.

7 So, that average there is just the, the

8 physical average of the size, which is subtly

9 different than the average for representative

10 consumer load size. So, essentially, the .52 load

11 adjustment factor means that, given a washer of any

12 size, a consumer will tend to fill it 52 percent of

13 the way.

14 That, that's how that can be

15 interpreted.

16 MR. JOHNSON: Agreed. And that's

17 precisely the subtle difference that seems to be an

18 inconsistency.

19 MR. BROOKMAN: Okay. Okay, I think

20 we've covered this now, if you want to go ahead.

21 MS. MAUER: Joanna Mauer.

22 I just want clarification. So, you're

23 suggesting that the average load size values that

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1 depend on capacity are not intended to represent

2 consumer usage?

3 MR. SUTHERLAND: They are not based on

4 -- The determination of what those values are is

5 simply just a mathematical determination of what

6 the midpoint of the, of that drum size is, which

7 may not necessarily -- That average value may not

8 necessarily be THE typical value that a consumer

9 uses.

10 MS. MAUER: Okay. I just -- A little

11 surprising, because I, test procedures are

12 generally supposed to represent consumer usage, I

13 believe, by the Statute. So, --

14 MR. SUTHERLAND: Well, the consumer

15 usage of whether they run a small, medium, large,

16 that's taken into account with the load usage

17 factors of 12 percent for, 14 percent for minimum

18 load, 74 percent for average load, and 12 percent

19 for max load. So, that's where the -- That's how

20 the, the three different load sizes get adjusted to

21 account for actual consumer behavior.

22 MR. BROOKMAN: Charlie.

23 MR. STEPHENS: Charlie Stephens.

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1 But, that doesn't carry through to your

2 estimation of remaining moisture; is that what

3 you're saying?

4 MR. SUTHERLAND: Correct.

5 MR. STEPHENS: So, in the calculation of

6 dryer, or, excuse me, clothes washer energy

7 consumption, we do take those weights into account.

8 But, when we actually take for, and the account for

9 the energy used in the dryer, we don't; true?

10 MR. SUTHERLAND: True. True.

11 MR. BROOKMAN: Okay. Final comments?

12 (Whereupon, at 1:38 p.m. ET, no response

13 was had.)

14 MR. BROOKMAN: That was about as -- That

15 was -- Let's move on.

16 MR. SUTHERLAND: All right.

17 MR. WITKOWSKI: Don't conclude. Just

18 move on.

19 MR. SUTHERLAND: Okay. So, on to, to

20 the test cloth issues.

21 So, talking about RMC, it's the ratio

22 of, of the weight of water absorbed by the test

23 cloth after an energy test cycle has been completed

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1 to the, the, the bone-dry weight of that cloth.

2 And the characteristics of the cloth can affect the

3 absorbency of the cloth.

4 And test procedure tries to minimize and

5 account for the differences between cloths that

6 come from different lots. AHAM submitted some

7 comments in response to the framework document that

8 included revised tolerances for the size and weight

9 of the test cloth, and these tightening tolerances

10 DOE believes could improve the consistency in the

11 RMC results from, from lot to lot in the test

12 cloth.

13 And so DOE believes that the AHAM

14 proposal represents the industry's consensus in

15 trying to limit the uncertainty in the test

16 procedure through the variation in test cloth

17 properties, and therefore DOE is proposing to

18 include these changes in the test procedure.

19 One of the other issues related to test

20 cloth is the, the fact that the, the current test

21 procedure uses extractor tests with G forces up to

22 500 G to determine the correlation curves that are

23 used to correlate each separate lot of test cloths.

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1 However, DOE is aware of clothes washers on the

2 market that achieve G forces even higher than 500

3 Gs, and so, therefore, DOE's proposing to include

4 an additional set of, of extractor tests at 650 Gs,

5 as well as requiring the 500 G extractions for all

6 clothes washers currently in J-1.

7 The 500 G does not necessarily apply to

8 all clothes washers. So, the table shown here

9 shows what the proposed standard RMC values would

10 be for the extractor tests as proposed, and that is

11 based on the AHAM-submitted data.

12 Some additional issues: DOE's also

13 proposing to specify a test cloth handling

14 procedure to ensure consistent results from the

15 extractions, extractor testing, proposing to update

16 some of the information about the manufacturer of

17 the extractor, some more specific

18 requirements on the bone-dryer, specifying that

19 it be able to heat the test cloth to over 210

20 degrees Fahrenheit.

21 And the current J-1 test procedure

22 includes some redundant sections regarding test

23 cloth specifications and preconditioning. So, DOE

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1 is proposing to remove these redundant sections in

2 J-2, and move any of the relevant nonredundant

3 information from, from those sections into the

4 appropriate sections in J-2.

5 So, DOE requests comment and data

6 regarding the proposed updated test cloth

7 specifications and correlation procedure.

8 MR. BROOKMAN: No additional comment.

9 (Whereupon, at 1:41 p.m. ET, no response

10 was had.)

11 MR. SUTHERLAND: All right. Must be.

12 And just some other provisions and

13 clarifications. Capacity measurement is the next

14 sort of big topic.

15 So, the current clothes-washer test

16 procedure requires measuring the entire volume

17 which a dry clothes load could occupy within the

18 clothes container during washer operation. And in

19 the current procedure this is done by filling the

20 clothes container with water to its uppermost

21 edge, and determining the volume based on the

22 weight of the water.

23 In the current J-1 procedure, the term

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1 "uppermost edge" is not well-defined, and it may

2 not always represent the volume which a dry clothes

3 load could truly occupy. DOE, as part of the

4 framework document, received multiple comments that

5 supported revising the definition of the capacity

6 measurement.

7 One of the things DOE considered were

8 other measurement records, such as the IEC 60456

9 method. But, DOE believes that, that some of these

10 methods would create unnecessary test burdens for

11 manufacturers.

12 So, DOE conducted capacity tests on a

13 small sample of washers and found that some of the

14 rated capacities -- and by "rated" I mean the values

15 that would be reported in either the ENERGY STAR

16 database or the CEC database.

17 Some of those values varied from DOE's

18 test measurements by as much as 0.5 cubic feet.

19 And so what this suggests is just that the ratings,

20 the capacity ratings are being based upon multiple

21 interpretations of what's defined as the uppermost

22 edge of the clothes container.

23 And DOE is striving to provide an

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1 Accurate, representative, and repeatable definition

2 of the uppermost edge of the clothes container that

3 can be applied uniformly. So, the current

4 definition of the clothes container is the

5 compartment within the clothes washer that holds

6 the clothes during the operation of the machine.

7 DOE believes that this should include,

8 that this part of the definition should include the

9 requirement that the clothing remain within the

10 clothes container throughout the entire operating

11 cycle, and additionally, that the clothes washer

12 should maintain basic functionality.

13 Dry clothing, for example, could fit

14 into certain fill volumes, but that may lead to

15 poor wash performance and poor machine operation

16 during a cycle.

17 So, for top, for vertical-axis or

18 top-loading clothes washers, DO-, DOE believes that

19 the top of the rotating portion of the clothes

20 container should be the highest horizontal plane

21 that a clothes load could occupy. And we have some

22 pictures on the next slide to clarify what we mean

23 here.

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1 For top-loaders, this would include a

2 balance ring as part of the clothes container, so

3 it would be, if the clothes container has a balance

4 ring, essentially the top of the balance ring.

5 DOE believes that clothes, it, while

6 it's true that clothes could be loaded in the space

7 above the tub cover, this volume should be excluded

8 because these clothes would likely wash poorly.

9 And for front loaders, DOE believes that

10 when the door seal that is in, the, the seal that

11 is in contact with the door during operation

12 determines the highest horizontal plane that a

13 clothes load can occupy.

14 And, remember. For front loaders it's

15 tilted on its back horizontally to make, to make

16 that measurement.

17 Also, just to note, DOE did consider

18 specifying the, the inner surface of the door as

19 the uppermost edge, but determined that this method

20 was not repeatable. And, of course, for both

21 vertical- and horizontal-axis washers, any volume

22 within the clothes container that a clothing load

23 cannot occupy during operation would be excluded.

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1 So, for example, for front loaders, if

2 the door protrudes into that space, which it does

3 on most models, that, that volume should be

4 excluded from the capacity measurement.

5 And so here's a diagram that illustrates

6 what DOE means by the top of the rotating portion

7 of the clothes container. You can see the proposed

8 fill level would be the top edge of the balance

9 ring.

10 DOE notes that this proposed fill level

11 differs from the guidance that is currently posted

12 on the clothes washer test procedure, clothes

13 washer rulemaking web site. The current guidance

14 that is posted there applies to the J-1 test

15 procedure and refers to a, a different point.

16 So, this is -- What's being proposed for

17 J-2 is a new fill level, as shown here. Similarly,

18 here are some diagrams showing horizontal-axis as

19 well as a top-loading horizontal-axis clothes

20 washer.

21 This diagram shows what the correct fill

22 volumes should be as proposed.

23 So, DOE welcomes comment on whether the

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1 proposed method for measuring capacity will provide

2 for a representative measurement of volume that a,

3 dry clothes could occupy within the clothes

4 container during operation, and on whether any

5 other valid measurement method is available.

6 MR. BROOKMAN: Ed Osann.

7 MR. OSANN: Question regarding the

8 points made on 80-, Slide Number 82 and 84 relating

9 to horizontal-axis machines. There's a (sic)

10 explanatory bullet that says DOE also considered

11 the inner surface --

12 MR. SUTHERLAND: That's right.

13 MR. OSANN: -- of the closed door.

14 This is on Slide 82.

15 MR. SUTHERLAND: Um-hum. Yes.

16 MR. OSANN: DOE also considered the

17 inner surface of the closed door as the uppermost

18 edge, but determined this method was not

19 repeatable. And then when you look at the graphic

20 on 84, Slide 84, the door shape is taken into

21 account in terms of, of the proposed fill volume.

22 How do those two things fit together?

23 MR. SUTHERLAND: Sure.

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1 MR. OSANN: What was it that was not

2 repeatable about using the inner surface of the

3 closed door in this context of 82, but it works for

4 Slide 84?

5 MR. SUTHERLAND: Well, so, just to

6 clarify, the, the, the thing that was considered,

7 the inner surface of the, of the door would be

8 this, this lower level here. If that was to be

9 considered the top of the clothes container, you

10 would fill, you would fill water up and essentially

11 keep, keep closing the door until you filled the

12 water up to a point where the water just hits the

13 level of that door.

14 What DOE found was that there's

15 adjustment that has to be made, and it's not a

16 completely consistent, repeatable method because

17 you have to fill it up, close it, see if it's

18 touching. If it's not, fill it up more, close it,

19 see if it's touching.

20 And because the shape of the door is not

21 as pictured, -- It's usually not a straight,

22 completely flat surface. -- there is just, it can

23 differ from person to person in how they interpret,

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1 "Okay, are we at the point where we should stop?"

2 (Whereupon, at 1:51 p.m. ET, Mr. Johnson

3 entered the room, after which the following

4 occurred:)

5 MR. SUTHERLAND: So, that's what we mean

6 when we say that the results were not repeatable.

7 When you fill the fill volume up to the proposed

8 level, which extends all the way up to the part

9 where the door and the seal meet, you allev-, you

10 eliminate any guessing of what happens to be

11 done down at this level at the base of the door.

12 So, you essentially just fill it up to

13 the top, close the door, and, and any water that

14 would be removed as, as you close that door gets

15 excluded. But, what you have in there is your

16 volume, and this ends up being a much more

17 consistent, repeatable result than using the first

18 method.

19 MR. OSANN: So, do tub capacity and fill

20 volume, are those separately designated in the test

21 procedure? Do they serve two different functions?

22 MR. SUTHERLAND: The -- That refers to

23 the same. They were -- It's referring to the same

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1 thing.

2 The, the fill, the fill volume here is

3 the tub capacity; is what, is what you measure as

4 the tub capacity.

5 MR. BROOKMAN: Judy Reich.

6 MS. REICH: Also wanted to point out

7 there is a small but important difference between

8 the measurements made the two different ways. In

9 the first case, when you fill only to the inner

10 surface of the door, you're excluding that small,

11 annular gap around the projection of the door.

12 And that's an area that, during

13 operation, clothes can occupy. So, the method

14 that's being proposed takes that additional volume

15 into account that wouldn't be included if you only

16 filled to the, the first point where the water

17 touches the, the dry surface.

18 MR. OSANN: Just to follow up, then, for

19 purposes of measuring the, the capacity of an

20 H-axis machine, will it be the level of the door

21 seal in contact with the door, with the door open,

22 or with the door -- Do you have to have the door

23 closed and the tub filled to get the actual

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1 capacity?

2 MR. SUTHERLAND: Through testing in the

3 lab you would have to have the door closed.

4 MR. OSANN: And is that clear from the

5 test procedure spec?

6 MR. SUTHERLAND: Well, the test

7 procedure states that any shape or any part that

8 would occupy volume that clothes could not occupy

9 must be excluded from the measure.

10 MR. OSANN: Oh, okay.

11 MR. SUTHERLAND: So, unless in your lab

12 you had a way of filling it up all the way and, and

13 somehow analytically subtracting out the, the

14 volume of the door or something from a practical

15 standpoint in the lab, you would, you would close

16 the door.

17 MR. OSANN: And, and fill it.

18 MR. SUTHERLAND: Yes. Okay.

19 MR. BROOKMAN: Okay. Keep going.

20 Do you want -- Yes, Jennifer.

21 MS. CLEARY: Yeah, I think AHAM has some

22 questions about -- I know you said this was

23 intended to change the draft of the guidance for

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1 capacity on clothes washers that relates to J-1.

2 What about, is it intended -- I mean, that guidance

3 is now final?

4 MR. SUTHERLAND: Yeah. So, yes, that,

5 that guidance has now been finalized.

6 MS. CLEARY: And how does that relate to

7 the final, or how is it intended for to the final.

8 MR. SUTHERLAND: So, the, the final

9 guidance that's on the web site is guidance that

10 applies to the J-1 test procedure. And for top

11 loaders, the level that is the correct level is

12 the, the innermost radius of the top stationary tub

13 cover.

14 So, this note was just to differentiate

15 the fact that this new proposed fill level, which

16 is the top of the balance ring, which is lower than

17 what we're using for J-1. That was supposed to

18 emphasize that point.

19 MS. CLEARY: Okay. I can -- You know,

20 I'll be checking with my members to comment about

21 that, but I think we do have some questions about

22 whether this is more clear than that guidance.

23 You know, it does -- You know, I know

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1 that your goal is to get an accurate representative

2 repeatable definition that much's ours as well.

3 We thought that the guidance was clear

4 and has been providing good results, and so we're a

5 little uncertain as to why so much work went into

6 that. And then the language came out, and now the

7 language seems to be less clear.

8 So, we'll propose way that's, we think

9 should fix that look and the differences.

10 MR. BROOKMAN: All right. Good.

11 Good. I saw both JB and Kelley.

12 MR. HOYT: Just to further Jen's

13 comment, I mean, you fully changed the guidance

14 that we spent all spring and summer working out

15 what's clear and understandable. What's the reason

16 for that change?

17 MR. SUTHERLAND: I mean, in general the

18 reason for the change is to provide a result that

19 is more consistent, more repeatable, and will

20 provide the same accurate measurement, irrespective

21 of which lab is conducting the measurement or which

22 manufacturer is conducting the measurement.

23 MR. HOYT: So, you're saying that the

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1 guidance that was just issued three months ago does

2 not do that?

3 MR. SUTHERLAND: The guidance that was

4 issued three months ago is consistent with some of

5 the other language in the J-1 test procedure. So,

6 the, the, the language in the J-1 test procedure,

7 it, today's proposed fill level would not be

8 consistent with some of the language in the J-1

9 test procedure.

10 So, this -- DOE believes that the,

11 today's proposed measurement represents the most

12 accurate, most repeatable, most easily defined

13 point at which to make the measurement.

14 MS. REICH: This is Judith Reich.

15 I -- You know, we certainly recognize

16 and appreciate all the work that went into

17 developing the guidance. And the purpose was that

18 the J-1 provisions for capacity were not very

19 specific.

20 They -- Those provisions weren't

21 necessarily, at this point, what DOE would think is

22 the best approach. But, within the context of the

23 language that was already within J-1, how to

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169

1 narrow, more narrowly define it and have it

2 interpreted on a consistent basis.

3 But, for J-2, the possibility was

4 available to consider: Was that, in fact, really

5 the best way altogether to be measuring capacity?

6 MR. BROOKMAN: Kelley.

7 MS. KLINE: Kelley Kline.

8 Could you help me understand what in J-2

9 would be inconsistent with the guidance that was

10 proposed?

11 MR. SUTHERLAND: It's more -- It's not a

12 matter of consistency. It's the, that the guidance

13 is different.

14 So, in J-2, when you, when you perform a

15 J-2 test you would only fill the container up to

16 the top of the balance ring.

17 MR. KLINE: No, I understand. But, I

18 thought -- I've -- I, I might have just

19 misunderstood, but I thought you said that you,

20 that you needed to change from the guidance to this

21 new proposed method because of inconsistencies with

22 what would now be J-2.

23 MR. SUTHERLAND: Well, I think the

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1 language in J-1 was sufficiently vague that the,

2 this, the, the, the tub cover fill level was what

3 the group sort of determined --

4 (Whereupon, at 2:00 p.m. ET, Mr.

5 Witkowski and Ms. Kline conferred, out of the

6 hearing of others and off the Record, during which

7 the following occurred:)

8 MR. SUTHERLAND: -- or DOE would

9 determine from all the inputs from everyone who

10 worked on that, that was, that was the way of

11 clarifying the language in J-1.

12 MS. KLINE: So, it's not really that

13 there was an inconsistency. It's just that you're

14 changing the definition, right?

15 I mean, it's a changed interpretation.

16 It's not that it's inconsistent with some of the

17 other provisions of J-, of what would then be J-2.

18 MR. SUTHERLAND: It's --

19 MR. BROOKMAN: Paige?

20 MS. DETRICK: I --

21 MR. JOHNSON: It's another

22 interpretation.

23 MS. KLINE: It's not another

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1 inconsistency.

2 MS. DETRICK: At this point.

3 MR. JOHNSON: It was vague, but there

4 was a lot of different interpretations of where, in

5 J-1 of where the fill level should stop.

6 MR. BROOKMAN: That was Mike from NIST.

7 Now to Steve Witkowski.

8 MR. WITKOWSKI: Yeah. What we felt was

9 that in J-1, you know, we had a lot of problems

10 with vague language. And the purpose of the

11 guidance was to try to fix those problems.

12 However, we now have a new test

13 procedure. We feel that this, these definitions

14 are the most appropriate and the best to give an

15 accurate measurement within this new test

16 procedure.

17 It's not that we're saying that J-, you

18 know, that the guidance is bad. It's good for the

19 old test procedure.

20 We do not feel that it was the best

21 method to use for this test procedure, the new test

22 procedure. And, of course, we're also asking for

23 your input.

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1 We had to fix, you know, something that

2 we felt, and I think everyone here believed was

3 vague. And we did that with the guidance.

4 But, the idea of the new test procedure

5 was to have the best proced-, the best test

6 procedure we could. We're not tying it to the old

7 one.

8 MR. BROOKMAN: Chris.

9 MR. JOHNSON: Chris Johnson, LG.

10 Our, our, I guess our interpretation and

11 our understanding of the final draft, final

12 interpretation was that that was the interpretation

13 of the test method for determining where the

14 clothes, the clothes container capacity. And so

15 that, that interpretation was used as, to clarify

16 what was not, what volume was, was supposed to be

17 excluded and what volume was supposed to be

18 included, based on the fact of where clothes could

19 fill in the container.

20 So, that doesn't change. Only, only the

21 fill level changes on this, right?

22 I mean, you're not saying that now

23 clothes previously under the old guidance could go

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1 up to here, but now they can really go up to here

2 (demonstrating). Is that what we're saying?

3 Or, is it just really a matter of the

4 fill level for the test? That's, that's, that's

5 sort of it, what I'm seeing here, which, which sort

6 of negates the, the logic of clothes levels can

7 only be, I mean, the fill level for clothes can

8 only be what it is, given the same container.

9 And I think I'm more confused now than I

10 was before.

11 MR. BROOKMAN: Any other comments on

12 this?

13 Ed, let's -- I want to hear from other

14 manufacturers first.

15 J.B.

16 MR. HOYT: J.B. Hoyt, Whirlpool, again.

17 I've failed, in reading, or in this

18 discussion, to understand how this improves the

19 outcome from the outcome that's been heavily

20 reworked -- And it's, it's, it's a fundamental

21 shift with the design period. -- to be justified

22 at this time.

23 So, I remain mystified and would love to

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1 have a clarification at some point if that does

2 exist.

3 MR. BROOKMAN: Uh-huh.

4 Jennifer, I was going to attempt -- Go

5 ahead, Jennifer. Go ahead.

6 MS. CLEARY: Okay. Jennifer Cleary.

7 You know, AHAM agrees. This is not

8 clear.

9 And certainly the figures here may help

10 to give us an understanding of what, the words

11 we're trying to say, so we'll comment on, on the

12 words and these figures, regardless of what the,

13 the outcome is for the Final Rule. We would

14 certainly request that figures be included.

15 They were greatly helpful in the

16 guidance, and to, to clarify, clarify any, you

17 know, interpretations.

18 (Whereupon, at 2:04 p.m. ET, Mr. Johnson

19 and Mr. Kau conferred, out of the hearing of others

20 and off the Record, during which the following

21 occurred:)

22 MS. CLEARY: And I think they would be

23 very helpful for the future as well. So, you know,

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1 we'll comment, again, on, on the actual content of

2 the proposal, but regardless, figures should be

3 included.

4 MR. BROOKMAN: Okay, Ed.

5 MR. OSANN: Ed Osann.

6 We would, we would, we would support

7 that recommendation that the Final Rule include the

8 graphics. It appears that the, that the difference

9 actually is pretty clear with, at least with regard

10 to vertical-axis machines.

11 This proposal seems to limit capacity to

12 -- And I think it says explicitly. -- the, the --

13 A SPECTATOR: The balance ring.

14 MR. OSANN: Yeah. -- the balance ring.

15 And the previous revised guidance that

16 people are referring to would seem to allow for

17 capacity above that level, some sort of very flat

18 cylinder that would represent some additional

19 volume above that. And it appears that the

20 rationale is that not only because of the

21 replicability, but at some point loading beyond

22 that would lead to poor wash performance.

23 MR. BROOKMAN: We're spending a lot of

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1 time on this. Let me see if I've got this.

2 For the horizontal-axis, if you look

3 at Slide 84, those doors are either slightly convex

4 or slightly concave, right? So, if you're going to

5 be doing the test based on the actual touch of the

6 door into the water, then you could see whether it

7 was just barely touching, or going up along that

8 convex or concave line; that there could be quite a

9 bit of potential for error there.

10 And that's what they're trying to

11 correct here, is that not? Isn't that --

12 Restating, isn't that it?

13 A PANELIST: Well, it wouldn't otherwise

14 make --

15 MR. SUTHERLAND: Well, that was the

16 front loader. But I think there's a whole separate

17 set of issues for the top loader.

18 MR. WITKOWSKI: Yeah, those are two

19 different issues.

20 MR. BROOKMAN: I know that. I'm hoping

21 that we can summarize this, any additional

22 comments.

23 Charlie.

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1 MR. STEPHENS: Yeah, Charlie Stephens.

2 I think our interpretation of the old

3 definitions in J-1 were that it was very

4 unfortunate language, and the guidance was, was

5 desperately needed to deal with what we call

6 "unfortunate language."

7 We're kind of enthusiastic about the

8 possibility of getting rid of the unfortunate

9 language and going with something better if we can

10 that needs more guidance. And if that's what we

11 end up with here, we're all in favor.

12 MR. BROOKMAN: Chris.

13 MR. JOHNSON: Chris Johnson, LG.

14 After looking at the vertical diagram

15 for vertical axis I'd like to propose a change if

16 we could. On graphic, on the third picture,

17 indicate that that's the balance ring.

18 And also under the explanation, it would

19 be more clear if you said the guidance sets the top

20 cover as the maximum fill, whereas the new guidance

21 sets the balance ring as the maximum fill. And

22 whether it's the top or middle or -- Is that

23 correct?

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1 This is the balance ring, whereas the

2 other was tub cover. Is that correct?

3 MR. SUTHERLAND: That's correct.

4 MR. JOHNSON: Okay. If that could be

5 clarified in this diagram and this was in the Rule,

6 that would be great.

7 MR. SUTHERLAND: Okay.

8 MR. BROOKMAN: Okay. That's good.

9 That's specific.

10 J.B.

11 MR. HOYT: If I may raise a question on

12 the front loaders, let the top-loader issue go.

13 What I'm -- It's been a while since I

14 read this. I didn't hear any mention of, of

15 shipping bolts in place to maintain the basket in a

16 use position.

17 Is that included in the actual language?

18 MR. SUTHERLAND: I --

19 MR. HOYT: Because that's, that's,

20 that's been a point of contention in the

21 front-load, --

22 MR. SUTHERLAND: Yes.

23 MR. HOYT: -- which, again, the guidance

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1 clarified. And I don't believe I've seen it here.

2 Maybe I'm missing it.

3 MR. SUTHERLAND: Yes.

4 MR. BROOKMAN: While they're -- J.B.,

5 while they're looking, repeat the question. I --

6 MR. HOYT: J.B., of Whirlpool.

7 The question: Does the new J-2 language

8 include explanation of shipping bolts being in

9 place to prevent sagging of the basket when, when

10 the machine is tipped on its back?

11 MR. BROOKMAN: Thank you.

12 Paige.

13 MS. DETRICK: This the Paige, from BSH.

14 Just to repeat, transportation fixation, we can get

15 in all kinds of other arguments about which ones

16 count as far as bolts.

17 MR. SUTHERLAND: Okay. So, I believe

18 the answer to the question is, "No." The -- As, as

19 proposed in the NOPR, the J-2 language does not

20 include mention of, of the shipping bolts.

21 (Whereupon, at 2:09 p.m. ET, Ms. Detrick

22 and Mr. Hoyt conferred, out of the hearing of

23 others and off the Record, after which the

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1 following occurred:)

2 MR. HOYT: We would specifically urge

3 that that oversight be looked at and remedied,

4 because it will create a problem as we had

5 previously.

6 MR. BROOKMAN: They need to be included.

7 Is that your point, J.B.?

8 MR. HOYT: Yes, sir.

9 MR. BROOKMAN: Thank you.

10 Okay. So, are we ready to move on now?

11 (Whereupon, at 2:09 p.m. ET, no response

12 was had.)

13 MR. BROOKMAN: Yes, I think so.

14 (Whereupon, at 2:09 p.m. ET, Mr.

15 Witkowski and a technician conferred, out of the

16 hearing of others and off the Record, during which

17 the following occurred:)

18 MR. SUTHERLAND: To talk about the new

19 measure of water consumption for the J-2 procedure,

20 in the J-1 procedure the calculation of water

21 factor was derived only from the water that was

22 consumed during the “Cold/Cold" cycle. Water that

23 was consumed during all the other cycles was not

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1 factored into that.

2 And DOE felt that this presents an

3 opportunity to bias the test procedure results by

4 setting the "Cold/Cold" water consumption very low,

5 but using more water during the higher-temperature

6 wash cycles.

7 So, to produce more representative

8 values of water consumption, DOE is proposing a new

9 integrated water consumption factor, or IWF. And

10 this would include water consumption from all the

11 energy test cycles, including the "Self-Clean"

12 cycle within the calculation of I-, IWF.

13 And so the total weighted per-cycle

14 water consumption would include the total water

15 consumption for each active-mode energy test cycle,

16 multiplied by the temperature use factor and load

17 usage factor. And it would also add in the

18 "Self-Clean," "Self-Clean" cycle water consumption

19 multiplied by 12, divided by 295.

20 And this then produces an IWF that

21 equals the total weighted per-cycle water consumption

22 divided by the clothes container volume. DOE

23 believes that this proposed IWF metric will not

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1 substantially increase manufacturers' test burden

2 because, in practice, manufacturers likely record

3 the data on cold-water consumption for all the

4 different wash levels even though it's not required

5 by the current J-1 test procedure.

6 So, we'll take comment on that. DOE

7 welcomes comment on the proposal to establish a new

8 integrated measure of water consumption, integrated

9 water consumption water factor expressed in gallons

10 per cubic foot.

11 DOE requests comment on the validity of

12 including water consumption of all test cycles,

13 including "Self-Clean."

14 And, DOE also requests comment on

15 whether the IWF calculation would result in a

16 significant test burden.

17 MR. BROOKMAN: Ed Osann.

18 MR. OSANN: Ed Osann.

19 Conceptually this makes a lot of, lot of

20 sense and we appreciate DOE's desire to avoid

21 potential bias. Has this, has this been applied?

22 Do you have any results from your own

23 group of test machines that you used for the, for

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1 the, for the standards evaluation? Do you know --

2 MR. SUTHERLAND: DOE is, --

3 MR. OSANN: -- how this would crosswalk?

4 MR. SUTHERLAND: -- is currently

5 evaluating that as part of the Standards rulemaking

6 process.

7 MR. OSANN: So, we don't know yet? Is

8 that the answer?

9 MR. SUTHERLAND: So, we -- Yeah. So, we

10 don't know yet, but we will. But, DOE will soon.

11 MR. OSANN: Okay.

12 MR. BROOKMAN: Additional comments on

13 integrated water consumption factor? Okay.

14 Oh, wait.

15 Paige.

16 MS. DETRICK: Paige, from BSH.

17 Just a question for clarification.

18 Starts out talking about hot-water consumption

19 being measured but not used in water factor, but

20 then the proposal seems to be including cold water

21 from all different cycles.

22 So, I'm lost whether we're also putting

23 the water from hot water in here. Maybe it's clear

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1 in the equation, but in the text it's not clear to

2 me exactly what all is included.

3 MR. BROOKMAN: Judy Reich.

4 MS. REICH: To the -- Paige, --

5 Judith Reich.

6 Well, it's -- Let's see. Starting at --

7 MS. KOHL: It starts right here.

8 MS. REICH: Five-seven-five-nine-two of

9 the Federal Register document. There are a series

10 of sections that are calculating total

11 weighted-per-cycle water consumption for various

12 energy test cycles.

13 And those, then, are summed in Section

14 4.2.16, which is the integrated water consumption

15 number. There, --

16 MR. SUTHERLAND: And --

17 MS. REICH: There are -- I'm sorry.

18 There are two contributors.

19 There's a total weighted-per-cycle water

20 consumption for all wash cycles, and then a

21 per-cycle self-cleaning water consumption. And

22 within the total-weighted-per-cycle water

23 consumption for all washing cycles would be the

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1 individual energy test cycle contributions.

2 MR. SUTHERLAND: Yeah. And it's both

3 hot and cold water that go into that. And, yeah.

4 MR. BROOKMAN: Paige? Okay?

5 MS. DETRICK: Yeah. Looking at that

6 seems to be all from each, hot and cold from each.

7 MR. BROOKMAN: Okay.

8 MR. SUTHERLAND: And then, just to

9 reiterate, it would be Section 4.2.14 where the

10 multiplying by 12 and dividing by, dividing by 295

11 would be added.

12 MR. BROOKMAN: We're moving on to energy

13 test cycle.

14 MR. SUTHERLAND: Energy test cycles,

15 currently defined -- I don't think I'm going to

16 read the whole screen, but it's currently defined

17 in the J-1 test procedure. There's a Part A, which

18 refers to the, the normal cycles, cycles

19 recommended for cotton, and then there's a Part B

20 which refers to a set of wash/rinse temperatures that are

21 cycles that are available on the model but not

22 available on the normal cycle.

23 And any cycles under A, A or B should be

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1 applied to the, the energy test cycle. So, DOE

2 believes that some manufacturers may use only Part

3 A of this definition to determine the energy test

4 cycle and the corresponding temperature and fill

5 levels to be tested.

6 Now, as I mentioned, many machines

7 provide a normal cycle setting when, which, which

8 applies to Part A. Over -- Many normal cycles

9 limit wash and rinse temperature selection.

10 So, for example, if you want an

11 extra-hot cycle, you might have to switch out of

12 "Normal" and switch to some other cycle to get that

13 temperature selection. Certain manufacturers may

14 only test the temperature settings available in the

15 "Normal" cycle, despite being able to access these

16 other wash temperatures by switching out of the

17 "Normal" cycle.

18 And DOE feels that by doing so, this

19 neglects the Part B of the "energy test cycle"

20 definition. So, DOE, in proposing the "energy test

21 cycle" definition for J-2, notes that the

22 requirement to test different cycle settings, if

23 such testing contributes to an accurate

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1 representation of energy consumption, this has led

2 to some confusion, and therefore is proposing to

3 clarify Part B.

4 And the clarifying part of Part B is

5 that if the cycle described in A, so, in other

6 words, if the "Normal" cycle does not include all

7 the wash/rinse temperature settings available in

8 the washer, then the energy test shall also include

9 portions of the cycles offering these machine

10 temperature settings with agitation or tumble

11 operation, spin speeds, wash times, and rinse times

12 that are largely comparable to those of the

13 "Normal" cycle.

14 Any cycle under A or B that satisfies

15 this criteria shall include default agitation,

16 tumbling, soil, spin speeds, wash times. So, it's,

17 it's the first part of this definition that DOE's

18 adding to clarify.

19 MR. BROOKMAN: Let, let's just pause and

20 let them read it.

21 MR. SUTHERLAND: Sure.

22 MR. BROOKMAN: Yeah, let's take 30

23 seconds just to read the paragraph. Give everyone

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1 a chance to take a peek at it.

2 Okay. Paige.

3 MS. DETRICK: This is Paige from BSH.

4 Two comments. First, I think we need to

5 be very careful.

6 We're change -- Trading the words in the

7 old Standard will contribute to an accurate

8 orientation so now the words are largely comparable

9 in both cases. These are largely open for

10 interpretation and will cause discussion,

11 negotiation, differences in opinion.

12 Second, the, the part of this at the

13 end, "Any cycle under A or B, blah-blah-blah, where

14 we have to look at agitation, tumble, agitation,

15 soil level, spin speed, wash times, rinse times, et

16 cetera, we come back to, to two facts about this.

17 One, we get into the same situation as

18 was discussed on Slide 68 with warm rinse where:

19 How do we pick out which piece to add to which

20 cycle to add to which piece of which cycle to

21 assemble this mythical cycle?

22 That's an energy case. And the second

23 is: We are making a mythical cycle.

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1 This is not a cycle a customer could

2 ever make where they have the choice of longer

3 rinsing, longer heating, the highest soil level.

4 Can't be assembled by the customer in most cases.

5 You're taking little pieces of different

6 programs and scrunching them together. And this

7 is, is not going to represent actual consumer use

8 anyway.

9 MR. SUTHERLAND: I think there -- It

10 sounds like there might be actually confusion as to

11 what the, the intent of this last sentence is. And

12 the, the, the intent of, of that last sentence is,

13 is not to say that, that you need to test every

14 single combination like you were saying, the, the

15 high, the high spin, the high soil, the high

16 whatever.

17 The intent of that is to say that if

18 you, if you are choosing a selection under Part B,

19 you should include the default settings for

20 agitation, soil level, spin speed, and wash time

21 and rinse time. So, if -- So, if you're, if

22 you're, if you're running the extra-hot cycle and

23 the only way to get that is on the, the "Whites"

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1 cycle, you would switch to "Whites," select "Extra

2 Hot," and you would use the default settings for

3 all of these other parameters.

4 So, that's the intent of that last part

5 of, of the definition there.

6 MS. DETRICK: This is Paige again. But,

7 in the earlier part of the Standard it basically

8 says that if I have something that is more

9 energy-consuming as a little piece of any, -- Again

10 we come back to comparable RHA, comparable cycle.

11 -- that I have to go run that cycle.

12 So, I could have three or four, let's

13 say, programs that are, quote, largely comparable

14 now. How do I decide which one gets measured?

15 One might be different spin speed. That

16 makes it different.

17 One might be different agitation time.

18 That makes it different.

19 And so -- And we could end up with a

20 real mess. And I think you need to take out words

21 like "largely comparable" that are going to get us

22 in trouble.

23 MR. BROOKMAN: Thank you.

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1 Additional comments on this, this slide,

2 energy test cycle?

3 (Whereupon, at 2:22 p.m. ET, no response

4 was had.)

5 MR. BROOKMAN: We've got one more

6 document to finish off on 92.

7 MR. SUTHERLAND: Sure. So, DOE notes

8 that it has issued this -- Says "draft guidance,"

9 but the guidance has been finalized.

10 So, it's, should say "final guidance"

11 available on the rulemaking web site which

12 interprets the current for J-1. That definition is

13 consistent with this draft guidance.

14 Finally, DOE also notes that it's, has

15 received data from manufacturers indicating that

16 cycles may vary from the “Cotton/Linen” cycle by means

17 of a lower spin speed, which would thus result in a

18 higher RMC, and therefore would not be largely

19 comparable to the "Cotton" or "Linen" cycle.

20 And I think, yes, DOE requests comment

21 on the proposed definition of the "energy test

22 cycle."

23 MR. BROOKMAN: Charlie.

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1 MR. STEPHENS: Charlie Stephens.

2 I'm taking from the, this definition,

3 then, that you've excluded by definition all

4 measurement of energy that occurs in the "Delayed

5 Start" or "End of Cycle" mode of operation.

6 MR. SUTHERLAND: Any measurements that

7 would occur for that sort of thing would be covered

8 in the, the "Standby" mode measurements.

9 MR. STEPHENS: Now you've actually

10 excluded them from the "Standby" or "Inactive"

11 mode. They're part of the "Active" mode.

12 MR. BROOKMAN: Judy Reich.

13 MS. REICH: It's not that -- We have not

14 excluded them. We have separate provisions.

15 They are "Active" mode, portions of

16 "Active" mode, but they are measured separately.

17 MR. STEPHENS: So, so, that isn't part

18 of the energy test cycle.

19 MR. WITKOWSKI: If you think --

20 MS. REICH: That's correct.

21 MR. SUTHERLAND: That's correct.

22 MR. BROOKMAN: Stephen, do you want --

23 MR. WITKOWSKI: No, that's --

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1 MR. BROOKMAN: Okay.

2 Additional comments on these energy test

3 cycle slides?

4 Yes, Paige.

5 MS. DETRICK: Is Paige, BSH.

6 One small elaboration on the bottom of

7 Page 9, but known RMC could change. But, for

8 example, rinse times or cycles could be different.

9 That makes it “not largely

10 comparable.”

11 MR. SUTHERLAND: Okay. So, Doug, we

12 have been scheduled for a break.

13 So, unless there's any more comments, I

14 don't know if you want to take a quick break, or --

15 MR. BROOKMAN: Yeah, let's take a short

16 break. Ten minutes. It's 2:25.

17 (Whereupon, at 2:25 p.m. ET, those

18 present took a brief recess and returned at 2:34

19 p.m. ET, after which the following occurred:)

20 MR. BROOKMAN: Okay, let's, let's

21 resume. Please take your seats.

22 Back to Timothy Sutherland.

23 MR. SUTHERLAND: Okay. Oops.

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1 There we go. Okay.

2 So, the next topic we'll discuss will be

3 the detergent specifications for the, the test

4 cloth preconditioning. The current J-1 procedure

5 specifies AHAM Standard Detergent 2-A, which is no

6 longer produced.

7 So, DOE has conducted tests using the

8 current AHAM standard test detergent, which is

9 Formula 3, but found that the current dosage

10 requirements may, may no longer be appropriate for

11 this new formula. So, one of the suppliers of the

12 test materials provides dosing instructions of 27

13 grams plus four grams per pound of test cloth for

14 Formula 3.

15 And this is the same dosage used in the

16 AHAM clothes dryer test standard. So, therefore,

17 DOE is proposing to amend the test-cloth

18 preconditioning procedure with this amount of

19 dosing for the AHAM Formula 3 detergent.

20 MR. BROOKMAN: And we have a comment box

21 on that. So, comments on this proposal?

22 Yes.

23 MS. CLEARY: We support it. AHAM

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1 supports --

2 MR. BROOKMAN: AHAM supports it. Thank

3 you, Jennifer.

4 Any other comments from anyone else?

5 (Whereupon, at 2:36 p.m. ET, no response

6 was had.)

7 MR. BROOKMAN: Okay.

8 MR. SUTHERLAND: Okay.

9 MR. BROOKMAN: Good.

10 MR. SUTHERLAND: Next we'll talk about

11 the clothes washer that's used for the

12 preconditioning of test cloths. The test procedure

13 requires that the test cloth be preconditioned in

14 the clothes washer for which a max water level can

15 be set, for which the load can be washed for ten

16 minutes, and for which the wash temperature can be

17 controlled to 135 plus or minus five degrees

18 Fahrenheit.

19 Multiple manufacturers have expressed

20 concern that there are currently few clothes

21 washers commercially available capable of meeting

22 these requirements. In addition, a more stringent

23 Energy Conservation Standard may eliminate such

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1 clothes washers from the market entirely.

2 So, DOE is seeking information regarding

3 an alternative specification for the clothes washer

4 to be used for the test-cloth preconditioning that

5 would allow for the use of more recent models. And

6 we'll pause for the test cloth input.

7 MR. BROOKMAN: Jennifer.

8 MS. CLEARY: Jennifer Cleary.

9 Just, I guess, wondering a little bit if

10 you could expand upon exactly what you might be

11 looking for here, or what the difficulty is. I

12 know you said manufacturers had expressed concern,

13 and, and I'm sure I can talk to them a little bit

14 more to understand their concerns.

15 But, trying to get at, with, what would

16 your end goal here be so that we can help you?

17 MR. SUTHERLAND: Well, I think the

18 primary concern is that the test procedure is very

19 specific that the preconditioning washer must have,

20 must provide these three levels of functionality.

21 And I think the concern is that, one,

22 one of which is due to increasing Standards, but

23 there, there is less, fewer and fewer models

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1 available that can do all three of these.

2 (Whereupon, at 2:38 p.m. ET, Ms. Detrick

3 and Mr. Hoyt conferred, out of the hearing of

4 others and off the Record during which the

5 following occurred:)

6 MR. SUTHERLAND: And so what, what do we

7 do when the day comes when there are no, no washers

8 available that can perform these three functions?

9 How should we revise the specifications for the

10 washers that, to be, that needs to be used for the

11 test-cloth preconditioning?

12 MR. BROOKMAN: Charlie.

13 MR. STEPHENS: Charlie Stephens.

14 Are the reasons for those conditions

15 being set in the first place totally lost in

16 history, or, or can we understand what they were

17 all about?

18 MR. SUTHERLAND: That is a very good

19 question. I fear that they may be lost to history,

20 but that -- DOE could go back and try and

21 investigate that.

22 MR. BROOKMAN: Where's Bryan when we

23 need him, right?

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1 Stephen Witkowski?

2 MR. WITKOWSKI: Yeah. I think we also

3 would be open to discussions concerning those three

4 factors, too.

5 The idea here is to try to come up with

6 a machine that we hope -- And, again, we're just

7 trying to adapt for future contingencies. -- that

8 will provide a, a, a good test-cloth wash.

9 (Whereupon, at 2:39 p.m. ET, Mr. Johnson

10 and Mr. Kang conferred, out of the hearing of others

11 and off the Record, during which the following

12 occurred:)

13 MR. WITKOWSKI: So, I don't think it's

14 so much that these three factors, the numbers there

15 are that essential. If there are reasons why you

16 don't think there are, and you have other numbers,

17 let us know.

18 But, the concern really is that if we

19 follow these three values there may not be a

20 machine available in the future that will meet

21 them.

22 MR. BROOKMAN: Paige.

23 MS. DETRICK: A point of clarification

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1 on this one. The maximum water level being able to

2 be set is somewhat of a, again, a general

3 statement.

4 This is certainly -- For example, I can

5 make my own custom program in-house to have a

6 machine to do this, but I've set as to what we

7 consider our maximum level. There is no, as far as

8 I've found, no definition of how many liters or

9 gallons is that, and therefore I am uncertain why

10 this is considered obsolete, but can certainly

11 support clarification further.

12 MR. BROOKMAN: Paige, what would you

13 suggest that they do?

14 MR. WITKOWSKI: May I comment here?

15 MR. BROOKMAN: Yes. Stephen, please.

16 MR. WITKOWSKI: I think the fundamental

17 concept here -- Let's not try to think about the

18 numbers so much. -- is we feel, DOE feels that we

19 need good washing parameters for test-cloth

20 preconditioning.

21 So, I don't think it's so much, so

22 important to get, you know, tied up into the, you

23 know, the details here, as to agreement that, yes,

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1 we need good preconditioned test cloth. And what's

2 the best way to wash it so that, that we'll be able

3 to continue to use this method in the future?

4 In other words, I don't want to get -- I

5 don't think we need to get into a long discussion

6 concerning these particular values and numbers.

7 MS. DETRICK: Um-hum. Um-hum.

8 MR. BROOKMAN: Okay.

9 Charlie.

10 MR. STEPHENS: I'm wondering if they

11 weren't trying to sort of induce the maximum

12 shrinkage of the test cloth with the hottest water.

13 I mean, 135, plus or minus five, is from the old

14 days, which is what potentially a water heater

15 would, on many occasions, deliver if you didn't

16 control the temperature of the hot water in the

17 clothes washer.

18 These days, if you're trying to control

19 how hot "hot" is, which you generally do, even if

20 the water heater's delivering that temperature, the

21 clothes washer probably won't. But, the -- I'm

22 just wondering if I could, if people could

23 understand why, you know, what is, what constitutes

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1 a good test-cloth preconditioning.

2 MR. SUTHERLAND: Someone --

3 MR. STEPHENS: Maybe then he'd, they

4 would know how to deliver it.

5 MR. SUTHERLAND: I do know one of the

6 issues is as the test cloth itself is, when it

7 first gets delivered, it may have residue from the

8 factory, or other oils and stuff from the, from the

9 machinery from the mill where it gets shipped. So,

10 the preconditioning is, one of the goals of the

11 preconditioning is to get rid of any residue that

12 might be there so that you're just left with pure,

13 fresh cloth that doesn't have any other chemicals

14 on it.

15 MR. BROOKMAN: Other thoughts on this

16 preconditioning?

17 (Whereupon, at 2:43 p.m. ET, no response

18 was had.)

19 MR. SUTHERLAND: All right. Water

20 supply pressure.

21 The test procedure currently states that

22 the static water pressure at the hot and cold inlet

23 connection of the washer shall be maintained at 35

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1 psi during the test. DOE believes that this

2 description is ambiguous as to whether the nominal

3 35 psi pressure is to be established under no-flow

4 conditions and allowed to drop during water flow,

5 or whether it is to be maintained continuously

6 under all flow conditions.

7 And, additionally, there's no

8 specification for where this pressure measurement

9 should be taken. DOE has conducted a test on a

10 small sample of front-loading and top-loading

11 washers to determine the effects of differing

12 supply tem-, pressures, and tests were conducted at

13 10, 20, and 35 psi.

14 And DOE found that under, that these

15 difference in pressures resulted in water

16 consumption values that varied by ten to 30

17 percent. Additionally, the test data suggests that

18 a water supply pressure of 20 psi under flow

19 conditions would result in the most consistent

20 results.

21 DOE also believes that 20 psi may

22 represent the typical static pressure under flow

23 conditions that would result from a 35 psi supply

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1 pressure at no-flow conditions, and that, and that

2 this scenario might be more representative of water

3 supply conditions typically found in the

4 residential setting.

5 However, there are other DOE test

6 procedures that more closely specify the 35 psi

7 requirement as applying under flow conditions. For

8 example, the dishwasher test procedure.

9 And, so, therefore, DOE's not proposing

10 to amend the water supply pressure requirements at

11 this time, but seeks more information on this

12 topic. So, do you --

13 MR. BROOKMAN: Charlie. Charlie.

14 MR. STEPHENS: Charlie Stephens.

15 We've, we've done some, a lot of

16 investigation on this in the Northwest over the

17 years, and you're really operating at what we

18 consider to be the very bottom of the range of, of

19 pressures that are even allowed by the American

20 Waterworks Association and others for system

21 pressures.

22 I kind of agree. Based on what my

23 understanding is of, of your relationship between

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1 flow and static, that seems pretty reasonable, 35

2 and 20.

3 But, those are at the very bottom. I

4 mean, the, the, the City of Portland is a little

5 high, but, you know, we operate under 75 psi static

6 and about 50 psi flow.

7 And that's throttled substantially.

8 But, I'm not suggesting that you go there.

9 But, I think your, the 35 psi flow

10 conditions that you see for the dishwasher is

11 probably also reasonable for the clothes washer

12 flow; not static.

13 MR. BROOKMAN: Flow. Okay.

14 Ed Osann.

15 MR. OSANN: Yeah. Ed Osann.

16 I don't think Portland is, is especially

17 unusual in that, in that respect. I agree that,

18 that, with the previous comment that, that 20 psi

19 is really the, the very low end of acceptable range

20 of DOE mes-, for, for, for public water service.

21 And it, it appears as though DOE has

22 identified a problem here, and, and not proposed to

23 do anything about it. With this wide range of, of

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1 potential performance based on, on water supply

2 pressure, it would seem that this test procedure

3 should make some, should clearly be adjusted to, to

4 remedy that great deal of uncertainty that, that

5 results from this.

6 We are inclined to support 35 psi

7 flowing as the requirement, and we'll make that

8 comment for the Record.

9 MR. BROOKMAN: All right. Do the, do

10 the manufacturers, DOE, AHAM, have any comment at

11 this time?

12 Jennifer.

13 MS. CLEARY: We're still -- I'm still

14 looking into it with some members, and we'll

15 provide comments in our written comments.

16 MR. BROOKMAN: Okay, then we're moving

17 on.

18 MR. SUTHERLAND: Okay. Getting close.

19 Additional original clarifications.

20 These are -- Here are some proposed revisions that

21 will not subsequently change the test procedure.

22 One is to incorporate the oil-repellancy

23 test and the dimensional change test as materials

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1 incorporated by reference. Another is to clarify

2 RMC for clothes washers with options that result in

3 different RMC values.

4 Another is to correct an error in the

5 equation in Section 1.5.4 for calculating the hot

6 water energy when gas or oil, for gas- or

7 oil-heated water. And, finally, remove the current

8 Section 4.5, which provides for the calculation of

9 energy factor.

10 That was a metric used pre-Conservation

11 Standards before January first, 2004, and it's no

12 longer used. So, I think that's, there's not a

13 question box there, but in case there's any

14 comments, let's just ask for any.

15 MR. BROOKMAN: Additional revisions and

16 clarifications, 101?

17 (Whereupon, at 2:49 p.m. ET, no response

18 was had.)

19 MR. BROOKMAN: I see none. Okay.

20 Oh, Ed Osann.

21 MR. OSANN: Ed Osann.

22 One of, at least one of these items is,

23 is to correct an error in the equation. That's,

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1 that's in the existing Rule, the existing test

2 procedure?

3 MS. REICH: Um-hum.

4 MR. SUTHERLAND: I believe so; yes.

5 MR. BROOKMAN: The third bulleted item

6 there, huh?

7 MR. SUTHERLAND: Yes. That's to correct

8 an error that's in the J-1 test procedure.

9 MR. OSANN: Okay. I was going to

10 suggest that, because a couple of, of, of errors

11 have been identified in the text of the, of the

12 proposed Rule, whether, without undue effort on the

13 part of DOE or the consultants, whether it would be

14 possible to post, sometime between now and the end

15 of the comment period, a, simply a corrected

16 Proposal, without getting into the substantive

17 discussion that we've had here today, but where

18 you've identified that the Proposal itself has

19 errors in it, whether you could put up a corrected

20 Proposal that would be available for --

21 MR. BROOKMAN: With like highlights or

22 the association --

23 MR. SUTHERLAND: Or --

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1 MR. WITKOWSKI: Or -- Excuse me. Or --

2 MR. BROOKMAN: Stephen Witkowski.

3 MR. WITKOWSKI: -- would be a listing of

4 the errors, and, and basically where, pointers

5 where in the proposal --

6 MR. OSANN: A single errata sheet.

7 MR. WITKOWSKI: Right. Because they

8 would be there and it would tell you exactly where

9 they are.

10 MR. BROOKMAN: Okay. That would be

11 helpful.

12 MR. OSANN: Yeah.

13 MR. BROOKMAN: Joanna Mauer.

14 MS. MAUER: Would you just explain the

15 second bullet point, the clarifications?

16 MR. SUTHERLAND: I mean, if you don't

17 mind, let me just take a look so I can recall what

18 the, what the error is.

19 So, Judy, correct me if I'm mistaken

20 here. I believe the -- If you look at Section

21 3.8.4 in J-1 as compared to J-2, it's the sub-,

22 sub-RMC equals .75 times the, the RMC from max

23 extraction, plus .25 times the RMC from the min

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1 extraction.

2 And it's the sub-, the subscript text on

3 those RMC values that has been clarified. Yeah,

4 it's the -- The subscript has been clarified so

5 that it's clear which, which part of the RMC

6 calculation it's referring to.

7 MR. BROOKMAN: Judy, yes.

8 MS. REICH: Yes. It attempts to use

9 nomenclature that's consistent with the, with other

10 subscripts so that it just clarifies what those

11 RMCs refer to.

12 It doesn't change the calculation at

13 all. It just -- You can see on, in J-2, instead of

14 calling them "min" and "max" extraction, it uses

15 the nomenclature of first describing it as max to,

16 to demonstrate that it, it was maximum test load,

17 and then adds that each one of those is tested as

18 the max extraction and the min extraction.

19 So, it's just making it clear what those

20 values refer to.

21 MR. BROOKMAN: Okay.

22 MR. SUTHERLAND: Okay. So, I think that

23 wraps it up for the -- Almost.

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1 Not quite. Not quite wraps it up for --

2 One more section.

3 So, test procedure performance

4 specifications. The current DOE procedure does not

5 include any provisions for evaluating the wash

6 quality of the clothes washer.

7 And the intent of the test procedure is

8 simply just to determine water and energy

9 consumption, regardless of how good the clothes

10 washer washes clothes. So, DOE received multiple

11 comments that supported adding performance measures

12 to the test procedure.

13 Multiple commenters stated that the

14 increasing efficiency requirements could start to

15 limit the ability of the clothes washer to clean

16 laundry as expected by consumers. And some of

17 these comments referenced other Standards that do

18 include wash performance, such as there's the AHAM

19 HLW-1 Standard.

20 There's IEC 60456. DOE considered these

21 comments, and recognizes the benefits of

22 characterizing washer performance, but is not

23 proposing to incorporate measures of wash

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1 performance into the washer test procedure at this

2 time.

3 And this bullet point that's listed here

4 describes one of the reasons from a statutory

5 standpoint. EPCA states that test procedures shall

6 be designed to produce test results that measure

7 energy efficiency, energy use, or estimated annual

8 operation costs.

9 And there's no mention there of, of

10 appliance performance.

11 So, now we're at the end. So, let's,

12 let's just ask for comment on this Part 2.

13 MR. BROOKMAN: Paige.

14 MS. DETRICK: Paige, from BHS.

15 BHS strongly supports looking at, and

16 encourages addressing issues of capacity versus

17 volume that is facing both other calculations on

18 what quantity of laundry can successfully be washed

19 rather than the physical size of the drum.

20 MR. BROOKMAN: Thank you.

21 Other comments?

22 MR. SUTHERLAND: Okay. All right.

23 So, now we'll go into the last part of

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1 the discussion here, and hand it back over to Judy

2 Reich.

3 COMPLIANCE WITH OTHER EPCA REQUIREMENTS, IMPACT OF

4 PROPOSED AMENDMENTS ON ENERGYGUIDE AND ENERGY STAR,

5 AND ELIMINATION OF OBSOLETE CLOTHES WASHER TEST

6 PROCEDURE:

7 MS. REICH: This is Judith Reich. And

8 now that Tim has done all the heavy lifting, I'll

9 be going through the remainder of the presentation,

10 the first being compliance with other EPCA

11 requirements.

12 Specifically, as Tim just noted, there

13 are provisions within EPCA that describe that the

14 test procedures must produce repeatable

15 measurements reasonably designed to produce results

16 that measure energy efficiency, energy use, or

17 annual operating costs during a representive average

18 use cycle or period of use, and shall not be unduly

19 burdensome to conduct.

20 So, there are really two elements of, to

21 this requirement that were addressed separately in

22 the bullets below, the first being: Is it, in

23 fact, a reasonable and repeatable measure?

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1 And DOE believes that for the new

2 provisions for "Standby," "Off" mode, "Delay

3 Start," "Cycle Finished," that because it's, the

4 provisions are based off an, an internationally

5 recognized Standard that measures these modes, this

6 power consumption, that the use of that is

7 recognized as a reasonable approach.

8 The second portion about unduly, not being

9 unduly burdensome, the proposed test, the test

10 methods and the equipment required to measure these

11 modes DOE does not believe require any major

12 investment, either for the equipment to perform the

13 measurement, or for the facilities in which to do

14 them.

15 In fact, the provisions would allow

16 manufacturers to continue to test in the same

17 facilities that already exist for active-mode

18 testing. For the amendments relating to the

19 "Active" washing-mode portion of the test

20 procedure, in terms of the investments that are

21 required, the additions are largely the measurement

22 of several new cycles within the definition of the

23 energy test cycle.

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1 So, so, manufacturers would be required

2 to pretty much make the some types of measurement,

3 therefore not requiring any investments or

4 equipment purchases.

5 But, there would, in fact, be, for those

6 machines that have these features, such as "Steam"

7 or "Self-Clean," --

8 (Whereupon, at 2:59 p.m. ET, Ms. Detrick

9 and Mr. Hoyt conferred, out of the hearing of

10 others and off the Record, during which the

11 following occurred:)

12 MS. REICH: -- that these, the presence

13 of these cycle settings would result in an overall

14 test duration that is somewhat longer to account

15 for those extra cycles.

16 DOE estimates that, at most, that would

17 be about a 25-percent increase in test duration in

18 additional provisions of EPCA.

19 MR. BROOKMAN: Yes. J.B. has a comment.

20 MR. HOYT: Judy, let's, for a second,

21 take your 25-percent figure, which we may want to

22 debate, but we won't today. So, you're suggesting

23 that that 25 percent is reasonable, and that

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1 manufacturers would have another 25 percent

2 additional capacity without further investment?

3 Is that what I'm understanding?

4 MS. REICH: Well, DOE's initial belief

5 is that we would certainly have additional input.

6 MR. BROOKMAN: Jennifer.

7 MS. CLEARY: I think we would also ask

8 you to compare that increase, which, to an already

9 long test, to the additional energy consumption

10 which is going to be, be measured, which we

11 determined earlier today was de minimis. And that's

12 really what we're comparing, is this increase,

13 significant increase in tests.

14 And this is more than just the cost of

15 the facility as depicted in one of these slides,

16 but also time, as J.B. just raised. And we think

17 in a comparison there's a disconnection here.

18 MR. BROOKMAN: Yes, Chris.

19 MR. JOHNSON: Chris Johnson, LG.

20 I'm just wondering either, in EPCA or

21 anywhere else, has there ever been a determination

22 of what constitutes "unduly burdensome to conduct"

23 in terms of testing? Because we can probably come

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1 up with a long list.

2 But, in all seriousness, is, is -- I

3 mean, how does that threshold get evaluated when

4 you're doing, especially some things like that are

5 in this test procedure, where the value of even

6 testing it, and the, and the energy consumption of,

7 of what's being tested is, is minimal at best?

8 So, I'm just wondering, what is, what

9 is, what is "unduly burdensome to conduct"? Does

10 that mean, you know, a large financial increase in

11 testing for manufacturers?

12 Does it mean -- What, what does it mean?

13 And then that, that, that, that determination, if

14 there is one, or if there has been one, then that

15 plays in exactly to what, what J.B. was talking

16 about in terms of, you know, well, you have to do a

17 little bit more, but it's only 25 percent more, so

18 that's probably not an additional burden.

19 Well, maybe; maybe not. So, --

20 MS. REICH: You know, I think the, the

21 rulemaking process is designed for DOE to hear from

22 all interested parties what constitutes "test

23 burden," and, and at what point it does become

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1 unduly burdensome. And, you know, at this point

2 it's information-gathering.

3 DOE evaluates it. Interpretations of

4 the statutory requirements are, you know, made by

5 General Counsel.

6 So, it's really hearing all inputs

7 possible, and, and evaluating them from there.

8 MR. BROOKMAN: Okay.

9 Ed Osann.

10 MR. OSANN: Ed Osann.

11 Has -- In getting to this 25-percent

12 time, 25-percent increase, you must have some sense

13 of it, the causality of this. Where -- What is it

14 that's contributing to this, the additional length

15 of time for, for testing?

16 Is that in the Record that, where, where

17 we think that, where you think the -- What's the

18 attribution of the --

19 (Whereupon, at 3:08 p.m. ET, Mr. Johnson

20 and Mr. Kau conferred, out of the hearing of others

21 and off the Record, during which the following

22 occurred:)

23 MS. REICH: Well, as noted here, that

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1 the largest contributor is the addition of

2 potential new test cycles that would need to be

3 measured. So, in addition to an extra-hot

4 wash/cold cycle, there would be a "Steam" cycle.

5 If you need to measure a self-cleaning

6 cycle, that would be added in as well. So, those

7 form the bulk of the additional time required.

8 MR. OSANN: Those, those are, of course,

9 for machines that have that --

10 MS. REICH: Exactly.

11 MR. OSANN: -- feature or functionality,

12 and those recommended by the manufacturers.

13 MS. REICH: Um-hum.

14 MR. OSANN: And those that don't would

15 not that have that.

16 MS. REICH: That's correct.

17 MR. OSANN: So, this is a -- Twenty-five

18 percent is -- Is this 25 percent for a machine that

19 might have these features, or is this a 25-percent

20 increase in the total tests time for a

21 manufacturer's typical offering?

22 MS. REICH: That estimate was based on

23 if the machine had all of the requirements, new

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1 cycles that needed to be tested.

2 MR. OSANN: So, one particular model

3 with extra features would have --

4 MS. REICH: It's an upper limit.

5 MR. OSANN: Okay, it's an upper -- Thank

6 you.

7 MR. BROOKMAN: Okay, we're going to move

8 on.

9 MS. REICH: Okay. Okay, the EISA

10 amendments to EPCA also require that "Standby" mode

11 and "Off" mode energy consumption is integrated

12 into the overall energy descriptor if it's

13 technically feasible.

14 And so for the reasons we already

15 discussed, DOE is proposing to incorporate

16 "Standby" and "Off" mode energy use into the

17 clothes washer per-cycle metrics in addition to

18 the "Delay Start" and "Cycle Finished" mode

19 contributors.

20 There will -- As proposed, there would

21 be a new measure of the first cycles of "Delayed

22 Start" and "Cycle Mode" to energy consumption and

23 an integrated modified energy factor metric.

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1 Therefore, DOE believes that that meets the, the

2 requirement of, of that particular section, section

3 of EPCA.

4 Okay, EPCA also requires that any test

5 procedure amendments that do incorporate measures

6 of "Standby" and "Off" mode energy use shall not be

7 used to determine compliance with existing energy

8 conservation standards. In this case, DOE is

9 proposing to implement an entirely new test

10 procedure in Appendix J-2, and leaving Appendix J-1

11 in place, with the clarification that Appendix J-2

12 is not going to be required to be used by

13 manufacturers until the effective date of any new

14 clothes washer Standards.

15 Therefore, quite obviously, it would not

16 affect the ability to determine compliance with,

17 with the existing Standards. One final note on

18 this is that commercial clothes washers are

19 required, and I believe it's by Statute, to use the

20 residential clothes washer test procedure, which

21 means that it's using Appendix J-1 to test them.

22 If J-2 were to be applied to commercial

23 clothes washers, it, DOE believes that the impacts

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1 would be limited, because there are still measures

2 of MEF and WF.

3 However, that -- Some of the

4 calculations that go into them would be changed in

5 J-2, and this includes changes to the test load

6 size, the, the temperature use factor, dryer use

7 factor, test cloth, capacity, and so forth.

8 So, there would be some changes to a

9 measured energy and water efficiency of a

10 particular commercial clothes washer if Appendix

11 J-2 is applied to, to commercial clothes washers.

12 As noted here, though, the largest

13 contributors would be the capacity measurement and

14 the use factors. So, that is a topic that DOE

15 would welcome input on; how these proposed

16 amendments in Appendix J-2 would affect commercial

17 clothes washers.

18 MR. BROOKMAN: No additional comments on

19 the impact on commercial clothes washers?

20 (Whereupon, at 3:08 p.m. ET, no response

21 was had.)

22 MR. BROOKMAN: Okay, I see none, Judy.

23 MS. REICH: Okay. We're looking at

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1 impacts on the EnergyGuide and ENERGY STAR

2 programs.

3 DOE considered how an amended test

4 procedure would affect the EnergyGuide

5 requirements, and since Appendix J-2 doesn't

6 include provisions that would change the annual

7 operating cost metric, there, under this proposal

8 there would be no impact at all on the EnergyGuide

9 labeling.

10 ENERGY STAR, on the other hand, is based

11 on MEF and water factor. So, if those calculations

12 are changed, as they would be somewhat affected by

13 the proposed amendments, that could impact the

14 determination of whether a model could qualify or

15 not for the ENERGY STAR Program.

16 However, DOE notes that because these,

17 this new Appendix J-2 would not be required until a

18 compliance date of any new clothes washer energy

19 conservation Standards, DOE would analyze those

20 impacts on ENERGY STAR as part of that rulemaking.

21 Any comments on that?

22 And here's a very tricky topic, the

23 elimination of the obsolete Appendix J. Appendix

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1 J, the original test procedure, only applies to

2 clothes washers manufactured before January 1,

3 2004; so, therefore, is obsolete and not necessary.

4 So, Appendix J-1 is applicable to all

5 clothes washers currently on the market. DOE is

6 proposing to eliminate Appendix J, and retain

7 Appendix J-1 as it's currently labeled, rather than

8 renaming it "Appendix J," so that if there are any

9 other references to it, that those could remain in

10 place.

11 This is an approach DOE has taken for

12 other test procedures, and therefore is proposing

13 to go just with the J-1 and, and new J-2.

14 MR. BROOKMAN: Any comments on that?

15 (Whereupon, at 3:11 p.m. ET, no response

16 was had.)

17 MR. BROOKMAN: Okay, I see no additional

18 comments.

19 MS. REICH: No additional comments.

20 Well.

21 MR. BROOKMAN: So, now is an opportunity

22 for anybody that wishes to do so to make final

23 remarks, summary remarks, raise any additional

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1 issues that need to be raised at this time.

2 (Whereupon, at 3:11 p.m. ET, no response

3 was had.)

4 MR. BROOKMAN: No additional comments.

5 Okay.

6 Well, thanks to all of you. We covered

7 a lot of ground, I think very efficiently today.

8 I especially appreciate everybody being

9 so forthcoming with their thoughts and comments,

10 and I'll turn it back to Stephen Witkowski.

11 MR. WITKOWSKI: Well, again I want to

12 thank all of you for coming today and

13 participating, and I really want to emphasize the,

14 the importance of data and suggestions,

15 submissions. If you feel that there are changes to

16 the methodology, methodologies that we've outlined,

17 and please submit those.

18 If you have issues with them, please

19 submit those. Again, data, if you have it, we

20 would love to see, to see it.

21 And also, if there are general questions

22 in terms of if you feel that the answers that we

23 gave today, you know, need further clarification,

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1 please submit those questions, also. We're open to

2 all input, and we would be, we would look forward

3 to it.

4 And please try to ensure that the, it

5 arrives within the comment period. And other than

6 that, DOE thanks you very much for your attendance.

7 MR. BROOKMAN: Thank you.

8 (Whereupon, at 3:12 p.m. ET, the above

9 Public Meeting was concluded.)

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