1

BEFORE THE 1

UNITED STATES DEPARTMENT OF ENERGY PUBLIC 2

MEETING ON ENERGY CONSERVATION PROGRAM 3

FOR CONSUMER PRODUCTS: 4

TEST PROCEDURE FOR CLOTHES WASHERS 5

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28 October 2010 21

Washington, D.C. USA 22

___________________________________________________ 23

242

APPEARANCES: 1

DOUG BROOKMAN 2

Moderator

3

BETSY KOHL 4

U.S. Department of Energy

1000 Independence Avenue SW 5

Washington, D.C.

USA 6

JENNIFER CLEARY 7

Director

Regulatory Affairs 8

Association of Home Appliance Manufacturers

1111 Nineteenth Street NW 9

Suite 402

Washington, D.C. 20036 10

USA

PH 202

- 872

- 5955 11

FX 202

- 87 2

- 9354

jcleary@aham.org 12

PAIGE DETRICK 13

Engineering Test Lab Manager

Laundry Products 14

BSH Home Appliances Corporation

100 Bosh Boulevard 15

New Bern, North Carolina 28562

USA 16

PH 252

- 636

- 4476

FX 252

- 672

- 4509 17

paige.detrick@bshg.com

18

CAMILLA DUNHAM WHITEHEAD

Water and Energy Technology Team 19

Lawrence Berkeley National Laboratory

218 Pine Street 20

South Portland, Maine 04106

USA 21

PH 207

- 228

- 3573

cdwhitehead@lbl.gov 22

23

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ATTENDEES (Continued): 1

JASON FITZGERALD 2

D& R International

1300 Spring Street 3

Suite 500

Silver Spring, Maryland 20910 4

USA

PH 301

- 588

- 9387 5

FX 301

- 588

- 0854

jfitzgerald@drintl.com 6

MIKE GALLER 7

NIST

100 Buren Drive 8

Gaithersburg, Maryland

USA 9

PH 301

- 925

- 6521

mike@ni st.gov 10

J. B. HOYT 11

Director

Regulatory Affairs and State Government Relations 12

Whirlpool Corporation

2000 North M

- 63 MD 3005 13

Benton Harbor, Michigan 49022

USA 14

PH 269

- 923

- 4647

FX 269

- 923

- 4652 15

CL 269

- 277

- 1032

j_b_hoyt@whirlpool.com 16

CHRISTOPHER JOHNSON 17

Senior Manager

Standards and Compliance 18

North America Standards & Environmental Affairs

LG Electronics USA, Inc. 19

1000 Sylvan Avenue

Englewood Cliffs, New Jersey 07632 20

USA

PH 201

- 266

- 2419 21

CL 201

- 795

- 6552

chris.johnson@lge.com 22

23

244

ATTENDEES (Continued): 1

RICHARD KARNEY 2

U.S. Department of Energy

1000 Independence Avenue SW 3

Washington, D.C.

USA 4

KELLEY KLINE 5

GE

Appliance Park AP 2

- 225 6

Louisville, Kentucky 40225

USA 7

PH 502

- 452

- 7603

Kelley.Kline@ge.com 8

JOANNA MAUER 9

Technical Advocacy Coordinator

Appliance Standards Awareness Project 10

529 Fourteenth Street NW

Suite 600 11

Washington, D.C. 20045

USA 12

PH 202

- 507

- 4034

jmauer@standardsASAP.org 13

M IKE McGARAGHAN 14

Project Manager

Energy Solutions 15

1610 Harrison Street

Oakland, California 94612 16

USA

PH 510

- 482

- 4420 x 242 17

FX 510

- 482

- 4421

mmcgaraghan@energy

- solutions.com 18

EDWARD R. OSANN 19

Natural Resources Defense Council

1314 Second Street 20

Santa Monica, California 90401

USA 21

PH 310

- 434

- 2300

FX 310

- 434

- 2399 22

23

245

ATTENDEES (Continued): 1

CHARLIE STEPHENS 2

Senior Energy Codes and Standards Engineer

Northwest Energy Efficiency Alliance 3

PH 503

- 688

- 5457

cstephens@neea.org 4

AMANDA STEVENS 5

Program Manager

Energy Star Appliance Program 6

Climate Protection Partnerships Division

U.S. Environmental Protection Agency 7

1200 Pennsylvania Avenue

MC 62021 8

Washington, D.C. 20460

USA 9

PH 202

- 343

- 9106

Stevens.Amanda@epa.gov 10

JOHN I. TAYLOR 11

Vice President

Government Relations & Communications 12

LG Electronics USA, Inc.

1776 K Street NW 13

Washington, D.C. 20006

USA 14

PH 202

- 719

- 3490

FX 202

- 719

- 3492 15

CL 847

- 828

- 27 77

john.taylor@lge.com 16

JUDITH REICH 17

Navigant Consulting

77 South Bedford Street 18

Suite 400

Burlington, Massachusetts 01803 19

USA

PH 781

- 270

- 0101 20

DR 781

- 270

- 8313

FX 781

- 270

- 0418 21

jreich@navigantconsulting.com

22

23

246

ATTENDEES (Continued): 1

TIMOTHY SUTHERLAND 2

Navigant Consulting

77 South Bedford Street 3

Suite 400

Burlington, Massachusetts 01803 4

USA

PH 781

- 270

- 0101 5

DR 781

- 270

- 8375

FX 781

- 270

- 0418 6

timothy.sutherland@navigantconsulting.com

7

TROY WATSON

Navigant Consulting 8

1801 K Street NW

Suite 500 9

Washington, D.C. 20006

- 1801

USA 10

PH 202

- 973

- 2400

DR 202

- 481

- 8427 11

FX 202

- 973

- 2401

troy.watson@navigantconsulting.com 12

STEPHEN WITKOWSKI 13

U.S. Department of Energy

100 0 Independence Avenue SW 14

Washington D.C.

USA 15

16

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18

19

20

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247

I N D E X 1

Page

2

WELCOME

By Stephen Witkowski 8 3

OPENING REMARKS, INTRODUCTIONS, AND AGENDA 4

REVIEW

By Doug Brookman 9 5

STAKEHOLDER OPENING STATEMENTS 6

By Ed Osann 13

By Jennifer Cleary 15 7

INTRODUCTIO N AND REGULATORY HISTORY 8

By Stephen Witkowski 16

9

OVERVIEW AND STANDBY MODE, OFF MODE, AND

ADDITIONAL ACTIVE MODE TEST PROCEDURES 10

By Judith Reich 17

11

CLOTHES WASHER ACTIVE MODE TEST PRO CEDURE

By Timothy Sutherland 99 12

COMPLIANCE WITH OTHER EPCA REQUIREMENTS, 13

IMPACT OF PROPOSED AMENDMENTS ON ENERGYGUIDE

AND ENERGY STAR, AND ELIMINATION OF OBSOLETE 14

CLOTHES WASHER TEST PROCEDURE

By Judith Reich 212 15

DISCUSSION OF OTHER ISSUES 16

By Doug Brookman 224

17

NEXT STEPS AND CLOSING REMARKS

By Stephen Witkowski 224 18

19

20

21

22

23

248

BEFORE THE 1

UNITED STATES DEPARTMENT OF ENERGY PUBLIC 2

MEETING ON ENERGY CONSERVATION PROGRAM 3

FOR CONSUMER PRODUCTS: 4

TEST PROCEDURE FOR CLOTHES WASHERS 5

TRANSCRIPT OF PROCEEDINGS 6

MR . BROOKMAN: Okay, please take your 7

seats. We're going to begin. 8

Welcome, everyone, and good morning. 9

Stephen Witkowski, from the Department of Energy is 10

going to start with welcoming remarks. 11

WELCOME: 12

MR. WITKOWSKI: Good morning. On behalf 13

of Department of Energy I want to welcome you here 14

to this public meeting on residential clothes 15

washer test procedures. 16

We also have from DOE here today Rich 17

Karney , who's over h ere to the right, who has over 18

all responsibility for test procedures, and Betsy 19

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

closely on this particular test procedure. 21

We have a lot of material to cover 22

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

249

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

we strongly urge and request that if you do have 2

information

, data or whatever as we go through, keep 3

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

send us the information that you have. 5

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

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

MR. BROOKMAN: Thank you. 8

Just to clarify, this is the public 9

meeting on energy con servation program for consumer 10

products, test procedure for clothes washers here 11

at the Department of Energy. Today is Thursday, 12

October twenty

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

Washington, D.C. 14

We typically start these meetings wi th 15

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

organizational affiliation. 17

And those of you sitting at the table 18

can get in the habit of making sure the little 19

green LED light is turned on when you speak. 20

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

introductions were had.) 22

MR. BROOKMAN: Thank you. Thanks to all 23

2410

of you. 1

Glad you could join us and get an early 2

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

the web. 4

How, how many do we have on? Eight 5

right now. 6

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

review of the Agenda, and then launch into the 8

content. And then immediately following this 9

Agenda review there it's an opportunity for brief 10

summary remarks, opening remarks by anybody that 11

wishes to do so here in the room. 12

We're going to proceed, immediately 13

following Stakeholder Opening Statements with an 14

Introduction and, and Regulatory History. And then 15

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

and Additional Active Mode Test Procedures. 17

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

that review will be continued. And then continuing 19

on, Clothes Washer Active Mode Test Procedure. 20

Break for lunch around about noon and 21

return from lunch with more on the clothes washer 22

active mode test procedure, will continue that 23

2411

explanation, that presentation. 1

We'll take a break mid

- afternoon, 2

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

reflected there, and then C lothes W asher A ctive 4

M ode T est P rocedure C ontinued, and Compliance with 5

Other EPCA Requirements, Impact of Proposed 6

Amendments on EnergyGuide and ENERGY STAR, and 7

Elimination of Obsolete Clothes Washer Test 8

Procedure. 9

End up, end up the day with a discussion 10

on other issues. There is yet another opportunity 11

for individuals to raise additional comments, raise 12

additional issues that haven't be en covered 13

sufficiently. 14

So, there's your opportunity there 15

again, and then some next steps and closing 16

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

try and finish at 3:45 today. 18

Stephen tells me that there's a lot to 19

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

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

consideration. 22

Please speak one at a time. Please 23

2412

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

You don't need to sa y your affiliation 2

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

please say your name each time. 4

There will be a complete Transcript of 5

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

Reporter present. 7

That would be posted on the EERE web 8

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

the Department of Energy will be telling you where 10

that's located. 11

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

can by name to speak. Ple ase feel free to follow 13

on sometimes. 14

The back

- and

- forth is useful. And if 15

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

phones on "Silent" mode. 17

Please limit your side

- bar 18

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

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

Public Solutions in Baltimore. 21

So, having said that, do we have slides 22

before they do opening marks, remarks their summary 23

2413

comments, Stephen? 1

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

actually follow the

-- 3

STAKEHOLDER OPENING STATEMENTS: 4

MR. BROOKMAN: So, then now is an 5

opportunity for individuals to make brief opening 6

remarks. Key issues and concerns? 7

Ed Osann. 8

MR. OSANN: Just a short statement here 9

at the outset. The Natural Resources Defense 10

Council strongly supports the joint recommendations 11

for new appliance energy and water efficiency 12

standards and test procedures as presented to 13

Secretary Chu by letter dated July thirtieth, 2010. 14

We also support the joint 15

recommendations specifically regarding clothes 16

washer test procedures as presented to Assistant 17

Secretary Ca therine Zoi by letter dated July 18

twentieth, 2010, 19

The recent agreement covering 20

residential clothes washers and other appliances is 21

a landmark achievement offering billions of dollars 22

of savings to consumers, regulatory certainty , and 23

2414

reasonable timetables for manufacturers and 1

substantial reductions in energy and water 2

consumption and greenhouse gas emissions. We urge 3

this agreement to be implemented by the Department 4

as soon as possible. 5

We've come to this p roceeding together 6

with AHAM and its member companies seeking several 7

improvements in the test procedure for clothes 8

washers. We welcome many of the changes proposed 9

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

to commenting on them in mo re detail. 11

We remain concerned, however, that the 12

current proposal may not have removed the potential 13

for unwarranted bias in favor of large capacity 14

washers, which AHAM and efficiency advocates have 15

jointly urged under the Department to resolve in 16

this proceeding. 17

As we seek clarification and improvement 18

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

for the Department to resolve outstanding issues 20

and finalize the test procedure rule on a timely 21

basis. Timely action here is necessary for timely 22

action to adopt the final rule for clothes washer 23

2415

efficiency standards upon which all projected 1

energy and water savings depend. 2

We anticipate final additional written 3

comments for the Record of this rulemaking after 4

today's public meeting. 5

MR. BROOKMAN: Thank you. And I 6

appreciate your brevity. 7

I really do, okay? Because I see you 8

have a lengthy written Statement there. 9

Other comments here at that time outset? 10

Jennifer. 11

MS. CLEARY: I think AHAM would echo 12

much of what was just stated in terms of the 13

agreement. We also would urge that it be adopted 14

as soon as possible, and also that the test 15

procedure become final in a timely manner so that 16

we have time to test it before Standards are 17

proposed. 18

MR. BROOKMAN: Thank you very much 19

that's helpful. 20

Okay, additional comments here before we 21

launch into the substantive content? 22

(Whereupon, no response was had.) 23

2416

MR. BROOKMAN: No additional comments? 1

Okay, then let's go. 2

Steve Witkowski. 3

MR. WITKOWSKI: Okay. Because we have 4

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

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

the past. 7

The regulatory history and the procedure 8

is all in black

- and

- white here, not onl y in the 9

presentation, but in the Federal Register Notice, 10

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

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

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

right away with the test procedure overvi ew and the 14

issues. 15

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

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

of those microphones. 18

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

were made among those present, off the Record, 20

after which the following occurred:) 21

OVERVIEW AND STANDBY MODE, OFF MODE, AND ADDITIONAL 22

ACTIVE MODE TEST PROCEDURES: 23

2417

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

Judy Reich, from Navigant Consulting. 2

And as you will see when we start the 3

slides, we've organized the discussion today into 4

largely two parts, one covering the active, new 5

provisions for active mode, and additional 6

provisions for standby and off mode. 7

And then the second half, which Tim 8

Sutherland is going to be speaking on, addresses 9

the, the revisions that are being proposed to 10

address various active

- mode issues. 11

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

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

basic items that we want to go through quickly. 14

The first is what exactly would be 15

products covered by this new proposed test 16

procedure. And there are existing

-- There is an 17

existing definition in 10 CFR that DOE is not 18

proposing to change, and this covers all of the 19

product classes that are presently defined in the 20

Energy Conservation Standards, namely top

- loading 21

compact, top

- loading standard size, top

- loading 22

semi

- automatic, front

- loading, and suds

- sav ing 23

2418

clothes washers. 1

So, all of these would be considered 2

covered products for purposes of this test 3

procedure. 4

In terms of when any amended provisions 5

would become effective, once the test procedure 6

would be published in the Federal Register, after 7

30 days it, the test procedure would become 8

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

Appendix J

- 2 would not be required to be used to 10

determine compliance with the existing Standards 11

u ntil such time; that is, until those Standards 12

would be amended to require the use of it. 13

But, in the interim, the existing J

- 1 14

Appendix would be used for compliance. Okay. 15

So, let's talk about the portions of 16

this, of th is meeting that are addressing the 17

requirements for including standby and off

- mode 18

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

additional active modes that are being considered. 20

The Energy Independence and Security Act 21

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

consideration in test procedures an y standby and 23

2419

off

- mode energy use

, using two Standards from the 1

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

and video equipment, and therefore is not 3

considered ap

- , applicable. 4

It's not taken into account in this 5

rulemaking. It is important to note that the EISA 6

amendments to EPCA state specifically that DOE 7

shall consider the most current version, or the 8

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

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

proposing that the IEC Standard 62301, first 11

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

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

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

incorporating by reference methodology and, and 15

test conditions to measure standby power now in 16

this test procedure, DOE is proposing that several 17

provisions from Section 4 and Section 5 would be 18

incor porated by reference, and they're listed here 19

below. 20

The

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

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

the discussion's probably going to be focused 23

2420

around the measurement methodology, talking a bout 1

procedures for testing, whether the power 2

consumption is stable or unstable. 3

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

updating 62301, which is the, their test procedure 5

for measuring standby power in appliances. 6

And originally this rulemaking had an 7

EISA deadline of June thirtieth, 2009, and DOE 8

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

of considering this new Edition 2, it delayed this 10

rulemaking to allow DOE to consider the new version 11

of it. 12

And that was expected to be released in, 13

shortly after the EISA deadline in July of 2009. 14

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

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

anticipated publication date for Second Edition. 17

So, DOE decided not, decided not to wait 18

any further. It is proposing referencing the First 19

Edition of, of 62301 for the test procedures. 20

And it's doing so in order to expedite 21

the process of, of amending the test procedu re to 22

include standby and off

- mode power. DOE believes 23

2421

that the provisions that it is proposing to include 1

will largely remain the same as the Second Edition 2

is finalized, and therefore the references to them 3

would remain valid. 4

B ased on our review of the most recent 5

draft versions, there was a Committee Draft for 6

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

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

talk about consideration of each of those in a 9

moment. 10

We would like to invite comment at this 11

point on the adequacy of using provisions from IEC 12

62301 to measure standby and off

- mode power, and 13

for the suitability of incorporating those specific 14

provisions into the DOE test procedure in cloth es 15

washers. 16

MR. BROOKMAN: Jennifer. 17

MS. CLEARY: Jennifer Cleary. AHAM does 18

support and recommends IEC 63201; however, not the 19

first edition. 20

We believe the FDIS should be 21

referenced. We understand you incorporate it by 22

reference, but we think there are probably other 23

2422

ways to included it in the Rule. 1

It will be, per the IEC posted 2

yesterday, that it will be published tomorrow and 3

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

our written comments, suggestions for how you can 5

include it. 6

But we can

-- You know, we've been 7

stating in several rulemakings that we can 8

continue. 9

MR. BROOKMAN: Jennifer, AHAM's been 10

participating in that, or representatives from AHAM 11

in the IEC procedures. 12

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

more detail. 14

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

Thank you. 16

MR. BROOKMAN: Yes. Charlie S tephens. 17

MR. STEPHENS: Charlie Stephens. 18

One of the sections that's not 19

specifically mentioned to be adopted with us 3.2, 20

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

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

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

2423

DOE didn't adopt a particular definition that the 1

EISA did? 2

In other words, if the definitions of 3

these modes, for instance, are not pretty much 4

identical, how will DOE look at any discrepancy 5

between the procedures that are specified based on 6

the definition of the mode that IEC has versus the 7

definition that DOE has? 8

And I'm th inking specifically, for 9

instance, in terms of something like network mode. 10

MS. REICH: Right. Yes. 11

Okay, so I want to be clear that the 12

mode definitions are not, they are drawn from the 13

draft versions. They do not incor porate them by 14

reference. 15

So, the mode definitions will be fixed 16

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

any new modes may be added to the IEC 62301 18

version. 19

And then I think the, then following 20

that I think your question would be if the 21

methodology in IEC 62301, in the provisions that 22

are incorporated by reference, change to update or 23

2424

to address new modes that may be added in IEC 1

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

DOE test procedure? 3

Is that the question? 4

MR. STEPHENS: Well, my question, my 5

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

mode is fairly identically with what the IEC does, 7

and then later you reference test methods that 8

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

you're going to have a potential inconsistency 10

there in the way things are measured, because 11

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

procedure that's based on its own definitions of 13

w hat that mode is. 14

And I'm just concerned that things be 15

consistent enough so that this methodology match 16

test definitions. 17

MS. REICH: Okay. The

-- You know, we, 18

we are aware that at least in the FDIS version 19

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

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

And, and, again, it is not

-- The DOE 22

test procedure would not adopt those new 23

2425

definitions by reference. DOE is, has considered 1

t hat language, and has now defined the modes 2

specifically that will remain in place and that 3

will be tested according to methodology,

-- At 4

least as it's been proposed.

-- to the methodology in 5

the first edition. 6

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

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

others and off the Record, during which the 9

following occurred:) 10

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

disconnect between any new modes that may be 12

introduced by the IEC, or any new methodology in 13

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

this time the proposal is to use the methodology 15

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

the mode definitions, with the language that h ad 17

been drawn from the new version. 18

And DOE believes that there is not a 19

disconnect between the testing definitions and 20

those mode definitions. 21

MR. BROOKMAN: You can see the 22

Department has invited comment, additional co mments 23

2426

as reflected in Number 1. 1

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

was had.) 3

MR. BROOKMAN: Okay. 4

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

is the mode definitions, what modes should be 6

incorporated in to the test procedure. 7

Both the EISA amendments to EPCA and IEC 8

62301 first

- edition interpretation of both of those 9

could lead to some questions as to what exactly, 10

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

whether, you know , whether they would apply in 12

certain ways to specific products, particularly 13

because these definitions were designed to be very 14

broadly applicable to various products that may 15

have different types of modes. 16

Also note that EPCA author izes DOE to 17

amend the definitions that were provided by EISA, 18

taking into account these most current versions of 19

the IEC Standards. Upon review of both the CDV 20

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

any revisions to the mode definitions have largely 22

been completed, and that they will remain 23

2427

relatively unchanged in the final version of the 1

second edition. 2

Therefore, DOE has looked at that 3

language and is proposing to amend the mode 4

definitions based on the language in the FDIS, 5

adding some extra specifications to clarify how 6

they would be applied to clothes washers. 7

So, the modes that DOE is considering 8

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

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

classifications there are specific functions that 11

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

standby mode. 13

So, DOE is proposing to clarify that 14

there can be multiple modes within each, with in 15

each category, and therefore is proposing to define 16

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

performing of all the major functions of washing, 18

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

washer. 20

Within that descr iption, a portion of 21

that can be referred to as the "active washing 22

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

2428

including washing, rinsing, and spinning 1

activities. 2

In addition to that washing mode, there 3

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

the user sets the machine to wait for a specified 5

period of time before engaging the act of washing 6

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

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

persist for indefinite time, which is one of the 9

criteria for classifying it as standby mode, and it 10

also occurs prior to engaging the wash cycle. 11

So, therefore, DOE believes that it's 12

uniquely associated with washing, and, and part of 13

the active mode. Additionally, DOE is proposing 14

that "Cycle Finish Mode" be classified as an 15

"Active Mode" because it provides a status display 16

following operation in active mode, or following a 17

wash cycle. 18

And because, again, it is uniquely 19

associated with the termination of wash cycle, DOE 20

believes that it should be considered part of 21

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

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

2429

besides just a display or indicator to the user. 1

And these would be, for example, some 2

sort of periodic tumbling, or blowing some air 3

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

mold, or to just keep the clothing fresh. 5

And DOE did not propose, for the 6

purposes of the NOPR, to include those additional 7

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

a, cycle finish mode because these do not represent 9

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

somewhat of a niche function. 11

So, DOE estimates that less than, that 12

less than five percent of products on the market 13

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

the energy use associated with that as a whole 15

would be so sma ll, but it would increase 16

manufacturer test burden by lengthening the, the 17

test cycle to capture what really is a neg

- , 18

negligible contribution to the annual energy use. 19

So, DOE did not propose to require 20

measurement of that function. 21

An additional mode that DOE proposes to 22

consider as part of "Active Mode" is a self

- clean 23

2430

function. This is provided on many front loaders 1

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

specified or provided by the manufacturer as a 3

unique setting that is dedicated to maintaining the 4

machine by cleaning it or deodorizing or 5

disinfecting it. 6

And the intent is that it, it prevents 7

odors or bacteria or mildew from growing. For 8

those machines that have such a fun ction, there's 9

typically a recommendation from the manufacturer on 10

how often to, to run the cycle. 11

It is conducted without a load in the 12

machine, and so therefore it is not a 13

clothes

- washing function. But, DOE believes that 14

this should be considered part of "Active Mode" 15

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

maintain the machine, properly maintain consumer 17

utilities to allow it to perform the washing act

- , 18

activity. 19

So, that was all Active Mode. The 20

second type of mode that EPCA requires addressing 21

is standby mode. 22

And DOE is proposing to define it as any 23

2431

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

one or more of the function s that are listed there, 2

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

indefinite time. And these would include things 4

like displays or internal sensors, as well as 5

features that are consuming power in order to 6

activate other modes. 7

And those would be timers, remote 8

switches, and the like. Additionally, DOE 9

proposes, for clarity, to amend the test procedure 10

to state that a continuous clock function doesn't 11

necessarily have to be associated with a display 12

in, on the fro nt of the product. 13

It can be an internal function 14

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

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

that provides regularly scheduled tasks and that 17

operates on a continuous basis. 18

For c lothes washers, DOE has only identified 19

one standby mode, one mode that meets this criteria 20

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

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

that there is an internal sensor th at can power the 23

2432

device, the, the product back up. 1

And so also classifying that if energy 2

is consumed in the presence of a one

- way remote 3

control under this definition, that would also be a 4

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

while DOE, in the NOPR, has only identified 6

"Inactive Mode," very clearly the definition allows 7

for multiple standby modes to be considered. 8

And, I

-- Any information on such 9

additional mode, standby modes would certainly be 10

invited. 11

Finally, the third major category of 12

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

basic. 14

It's connected to power and is not 15

providing any active or standby function. The 16

additional classification that is o ffered here

-- 17

And this was based on some questions that have come 18

up previously.

-- is that an indicator that only 19

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

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

display for the purposes of putting it into Standby 22

Mode. 23

2433

That would keep it within "Off" mode. 1

Additionally, if there is a mechanical, a hard 2

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

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

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

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

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

considered previously, a "Disconnected" mode, which 8

brings me to the modes that are n ot proposed for 9

consideration at this point. 10

There are additional modes that are 11

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

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

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

inc orporate them in the test procedure. 15

"Network" mode, according to the FDIS, 16

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

power and has a network function activated, such as 18

reactivation via network command, or network 19

integrity communication. But, most notably, the 20

primary function is not for "Active" mode 21

activities; mainly for communication. 22

According to the FDIS, "Disconnected" 23

2434

mode essentially means the, the plug is, is 1

removed; that all connection to the main power are 2

removed or interrupted. So, the latter, pretty 3

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

so DOE is not considering to define that or to 5

include that as a mode in the test procedure. 6

And for reasons that DOE does not, is 7

not aware of any clothes washer currently on the 8

market that has a network function, and is unable 9

to evaluate these types of products at this point, 10

is not proposing any provisions that would measu re 11

energy use in "Network" mode. 12

Welcome inputs on what you're thinking. 13

Let's see. 14

"Inactive" mode is the only standby 15

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

before we invite those comments; the determinati on 17

of delay start, cycle finished, and self

- clean mode 18

as a part of "Active" mode. 19

The definitions of all of these, and the 20

question of whether there are any other modes that 21

haven't been considered. 22

MR. BROOKMAN: Charlie Stephens. 23

2435

MR. STEPHENS: Charlie Stephens. 1

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

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

having trouble understanding when DOE proposes to 4

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

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

and the "Inactive" mode begins, without measuring 7

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

end

- of

- cycle phase of a, of an active

- mode cycle. 9

In other words

-- In other words, 10

without measuring everything that's going on, like 11

the tumbling of the drum, which my clothes washer 12

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

the thing. Is that "Inactive," or is that "Acti ve" 14

mode? 15

MS. REICH: I think the interpretation 16

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

process at which it reaches the final RMC is 18

complete. So, if there would be additional 19

tumbling or fan actions past that, that 20

in termittently or periodically, that would be

-- 21

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

mode. 23

2436

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

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

MS. REICH: It is not considered part of 3

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

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

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

of the energy test cycle. 7

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

understand if

-- Ho w are you going to measure the 9

energy in the, in the "Cycle Finish ed " portion of the 10

"Active" mode

, to use the language that's here on 11

the paper, without measuring the energy used in the 12

tumbling and fan use? 13

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

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

reasons that I mentioned of not many machines 16

having that feature, the periodic or intermittent 17

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

any portion of the test procedures measure that 19

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

would be doing typically would be measuring the 21

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

that simply displays to the user that the cycle is 23

2437

complete. 1

MR. STEPHENS: How are you going to 2

measure that without measuring the energy use of 3

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

MS. REICH: Well, we would certainly 5

welcome input on methodology to differentiate 6

those. 7

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

concerned, because my clothe s washer is now eight 9

years old. I happen to know there are thousands 10

and thousands of them just in Orego n, because we 11

ran the tax credit program for them on as many 12

years. 13

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

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

more than two, because I witnessed that many

-- 16

MS. REICH: Um

- hum 17

MR. STEPHENS:

-- time s

. 18

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

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

include this. Because it uses more energy than 21

just the supply, which, o f course, has got the 22

lights. 23

2438

So, I'm still

-- 1

MS. REICH: Um

- hum. Well, what I think 2

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

there be methodologies to measure that energy use 4

of the tumbling and blowing fu nction. 5

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

loss to understand how you wouldn't, because 7

otherwise you'd be in some other mode. 8

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

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

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

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

with one of the major microprocessors, who have,

-- 13

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

talked to them about the processors they intend t o 15

market in this market. 16

And I'm concerned about their power 17

consuming, quite frankly, because it will 18

dramatically increase the numbers that I'm seeing 19

in the published NOPR here in the standby mode

-- 20

MS. REICH: Um

- hum. 21

MR. STEPHENS:

-- unless they do 22

something to dramatically reduce their power 23

2439

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

understand how you would ignore a mode that would 2

multiply three to five times the standby motion as 3

it sits there waiting for the signal from the 4

electric grid, for instance. 5

MR. BROOKMAN: Steven Witkowski. 6

MR. WITKOWSKI: I think that you're 7

raising some interesting points here, and we 8

certainly are aware of technologies that may be 9

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

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

information that actually points out what's going 12

on out there. 13

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

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

to, to deal with speculation, even if that 16

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

main points of this meeting is to get that 18

information. 19

If yo u have concerns about the 20

methodology, and particularly if you have data on 21

machines or data on networking devices that are 22

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

2440

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

have right now. 2

MR. STEPHENS: I think my concern is not 3

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

but I think if we put in place

-- 5

This is Charlie Stephens again. 6

If we put in place a methodology that 7

deliberately excludes the measurements of these 8

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

necessary actually to know how much energy they use 10

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

least create a methodology which I think the I EC 12

methodology is attempting to do so that if there is 13

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

measured. 15

And I think that mostly it's a matter 16

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

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

test procedure in that mode? 19

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

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

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

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

2441

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

machine. 2

MR. BROOKMAN: Okay. 3

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

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

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

say, April of, of this coming year. 7

That's about when our data collection 8

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

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

but not in this time frame. 11

MR. BROOKMAN: Ed Osann. 12

MR. OSANN: Yeah, Ed Osann. 13

We have similar concerns about the 14

exclusion of these activities from, from the 15

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

almost seems as though yo u're jumping ahead from, 17

from the concerns about framing up the test 18

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

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

component that, for the, for this standby and 21

active

- mode consumption?" 22

The Joint Agreement that, that AHAM and 23

2442

efficiency advocates have entered into does include 1

explicit commitment to seek a recognition of Smart 2

Grid functionality for major appliances, including 3

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

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

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

commercialization of machines, including clothes 7

washers that have Smart Grid functionality. 8

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

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

the test procedure to be prepared to assess 11

whatever that level of, of energy consumption is 12

that's associated with that functionality. 13

MR. BROOKMAN: Good. Thank you. 14

JB. 15

MR. HOYT: JB Hoyt, Whirlpool 16

Corporation. 17

Charlie, I look forward to seeing your 18

data because we're the world's largest 19

manufacturer of appliances, and we would love to 20

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

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

go do that. 23

2443

But, we agree in theory that the mode 1

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

measure it because there's n o functionality to 3

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

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

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

answered. 7

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

"Network Mode" ? 9

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

Mode." Thank you, Doug. 11

MR. BROOKMAN: Okay. 12

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

placeholder that says when there's sufficient 14

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

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

would be talking. 17

So,

-- 18

MR. BROOKMAN: Okay. So, that data 19

would be good. 20

Jennifer. 21

MS. CLEARY: Okay. We would echo what 22

JB just stated. 23

2444

And, of course, consistent with our 1

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

be a distinctive energy user, and we need to 3

address how and where that should be measured and 4

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

FDIS version of 6 2 301 does have suggestions about 6

how to, how to do that. 7

MR. BROOKMAN: Okay, thank you. 8

There are several

-- If you look at 9

Comment Box 2, the Department requests comment on 10

several dif ferent things there. We don't want to 11

dance lightly over this. 12

Make sure that you have addressed your 13

issues here. 14

Yes, Joanna. 15

MS. MAUER: Joanna Mauer. 16

Just a question. If a product came on 17

the market that did have network capability and was 18

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

considered to have no standby power consumption? 20

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

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

others and off the Record, during which the 23

2445

following occurred:) 1

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

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

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

that was active during that mode. 5

I can't answer without knowing the 6

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

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

MR. BROOKMAN: Charlie Stephens. 9

MR. STE PHENS: Charl ie Stephens. 10

Yeah. When I was speaking about our 11

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

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

tumbling and fans and that sort of things. 14

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

what I was talking about with my conversations with 16

the microprocessor manufacturer who intends to sell 17

this microprocessor into your market. And so 18

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

But, I do know what their power 20

consumption is

, of that power processor

, right 21

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

decide to buy that processor. 23

2446

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

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

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

concerned about the power consumption of that 4

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

MR. BROOKMAN: JB. 6

MR. HOYT: JB Hoyt, Whirlpool. 7

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

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

it. 10

But, there are a variety of 11

alternatives, variety of devices, varieties of 12

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

ass ign a test procedure around something that 14

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

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

to move off that subject. Okay. 17

Other comments on issues not yet 18

addressed in this comment? 19

MS. CLEARY: I

-- 20

MR. BROOKMAN: Yes, Jennifer. 21

MS. CLEARY: Jennifer Cleary. 22

And I had a question about "Self

- Clean" 23

2447

mode. Just, we understand the definition that, 1

that you proposed to be dire cted toward machines 2

that have a specific program cycle for self 3

cleaning. 4

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

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

and so all three of those things in the definition 7

would be require d. 8

MS. REICH: Yes. 9

MS. CLEARY: Okay. Thank you. 10

MR. BROOKMAN: Okay? 11

MS. REICH: Yes. 12

MR. OSANN: Just

-- 13

MR. BROOKMAN: One additional comment, 14

Ed? 15

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

manufacturer recommends a particular periodic 17

sanitizing regimen, but does not have any hardware 18

or software associated with it on the machine,

-- 19

MS. REICH: Not

-- 20

M R. OSANN:

-- then that cycle is not 21

going to be picked up. 22

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

2448

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

we believe

-- 2

MR. OSANN: Right. 3

MS. REICH:

-- periodicall y, that would 4

not be considered a dedicated self

- clean function. 5

No. And that would not be addressed in 6

the, in the test procedure. 7

MR. BROOKMAN: Okay. 8

MR. OSANN: I take issue with that. 9

MR. BR OOKMAN: Ed, you want to say that 10

on the Record? 11

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

issue with that. 13

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

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

technician conferred with Mr. Brookman, out of the 16

hearing of others and off the Record, after which 17

the following occurred:) 18

MR. BROOKMAN: Yeah, there we go. 19

THE TECHNICIAN: Good. 20

MS. REICH: The next topic is adding the 21

specifications for the measurements of the test 22

methods. And these, we delve into the specific 23

2449

provision sections from I E C 62301 that are proposed 1

to be incorporated. 2

Paragraph 5.3.1 discusses the 3

methodology that is to be used, d epending on 4

whether the power consumption is determined to be 5

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

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

be stable if it varies by no more than five 8

percent during a five

- minute period. 9

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

is measured at the end of an additional time period 11

of at least five minutes. If the power is 12

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

percent during the five

- minute period, then the 14

powe r must be measured over at least five minutes, 15

or one or more complete operating cycles, which may 16

take several minutes or hours. 17

A MEMBER: Excuse me. 18

MS. REICH: It's important to recognize 19

that nothing within those prov isions prevents a 20

manufacturer from choosing either a longer 21

stabilization period or a longer measurement 22

period. 23

2450

It's recognized that many clothes 1

washers have displays that dim , or otherwise 2

reduce power consumption after a certain period of 3

time of user inactivity, and so DOE proposes to 4

incorporate the additional clarification from 5

Paragraph 5.1, Note 1, that says that the 6

measurement shall wait until the product drops into 7

its l ower power level state. 8

DOE has tested a representative sample 9

of, of current clothes washer models and has 10

determined that this higher power state typically 11

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

mean that it could, there could be clothes washers 13

that wait in that higher

- level state for the 14

combined ten minutes, the five

- minute stabilization 15

period and five

- minute measurement period that 16

would be applicable under the conditions of the, 17

of stable power. 18

So, further, DOE noted that IEC Standard 19

63201 , the CDV version, provides for a 30

- minute 20

stabilization period and a ten

- minute measurement. 21

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

account for situations lik e the, the power ed

- down 23

2451

state. 1

And DOE believes that by providing those 2

two time periods, longer time periods, 30 minutes 3

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

products to reach their lower power state and then 5

have a, the ten

- minute measurement period 6

thereafter so that it should properly measure all 7

of the so

- called low

- power modes, the "Inactive" 8

mode, "Cycle Finish ed ," "Off" mode, and, further, 9

that even if some clothes washers would allow for a 10

u ser to change settings so that it would stay in 11

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

typically that consumers will do that, and is not 13

proposing any additional provisions that would 14

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

prevent the default setting from being adjusted. 16

There were some significant changes that 17

were made from CDV to FDIS, notably in the 18

measurement methodology. And the FDIS states that 19

the test period shall be not less than 15 minutes 20

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

And, it requires that the first five 22

minutes of the measurement are disregarded, and 23

2452

then the ten minutes following that are evaluated 1

to determine whether the power is stable. If it 2

is not stable, the measurement period gets 3

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

extended until the stability criteria are met

. 5

And it's based on the first third being 6

disregarded, and the two

- thirds thereafter being 7

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

three hours. 9

It further requires that if there is a 10

known variation in power consumption, that, that 11

the measurement must be conducted for at least an 12

hour, 60 minutes. 13

When the power is cyclic, the 14

stabilization period is ten minutes and the FDIS 15

requires that at least four cycles, four of the 16

regular cycles are used for the, the measurement, 17

-- I'm sorry.

-- the stability, stabilization 18

period, and the mea surement period must be at least 19

20 minutes long. 20

Because there can be, you know, multiple 21

interpretations of that methodology, and can be 22

very different from product to product, determining 23

2453

stability and how long to conduct the meas urements 1

under the FDIS methodology, DOE believes that this 2

methodology would not be as repeatable and 3

reproducible, and therefore enforceable when 4

products are measured in, from laboratory to 5

laboratory, and believes that the CDV version 6

provi des a more, a more well

- defined test 7

methodology to ensure those. 8

I'll certainly invite comment on that to 9

talk about default settings and methodologies that 10

can account for consumer actions that might 11

increase energy use in data on t he repeatability of 12

such testing procedures. 13

MR. BROOKMAN: Jennifer? 14

MS. CLEARY: AHAM does believe that the 15

product should be tested, as default, 16

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

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

this stabilization period. 19

MR. BROOKMAN: Okay, thank you. 20

Paige, do you want

-- ? 21

MS. DETRICK: (Nodded no.) 22

MR. BROOKMAN: No. Okay. 23

2454

Additional comments? 1

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

response was had.) 3

MR. BROOKMAN: Okay. 4

MS. REICH: Okay. Delayed start is a 5

somewhat different situation because for some 6

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

indicator of the status of the dis

- , "Delay Start" 8

mode may impact the power consumption in that mode. 9

DOE conducted tests and analyses that 10

looked at displays that have both single

- and 11

two

- digit displays to determine the countdown time 12

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

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

that have, have multiple segments, what time could 15

be set on the display, or as the "Delay Star t" 16

time, that that single time would be representative 17

of the average of all the possible combinations of 18

lit segments on the, the time indicator. 19

And what DOE determined was that the 20

display time that is representative of that average 21

would be five hours, and then proposes to require 22

the power to be monitored for an addi

- , for 60 23

2455

minutes after waiting five minutes after setting 1

the time to allow the display to stabilize. 2

And I also would like to add here that 3

consideration was made for what possible maximum 4

display types are available on the range of units 5

on the market now. 6

We request if there are any comments on 7

this methodology for measu ring display mode, 8

"Delayed Start" mode power consumption. 9

MR. BROOKMAN: Jennifer. 10

MS. CLEARY: Jen Cleary. 11

I think DOE has recognized the 12

difficulty of measuring this mode. As you know, 13

you were just talki ng about some of the 14

difficulties. 15

And we question whether those 16

difficulties and the added test burden required to 17

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

have any real benefit to the public. The 19

associated energy with those may be d e minim i s, and 20

when balanced with the test burden to obtain those 21

measurements separately from the rest of "Active" 22

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

2456

there. 1

And that's sort of a general comment 2

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

procedure, the proposed test procedure as well. 4

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

wanted to

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

the general idea there. 7

MR. BROO KMAN: Okay. Thank you. 8

Additional comments on "Delay Start" 9

mode as referenced here? 10

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

response was had.) 12

MR. BROOKMAN: Okay. 13

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

test conditions that are proposed to be 15

incorporated from IEC 62301, the first is the 16

ambient temperature that be, that would be required 17

in the test room. 18

Currently for measuring the existing 19

"Active" mode measurements the DOE test procedure 20

requires the ambient temperature be fixed or be 21

specified only for water

- heating clothes washers. 22

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

2457

degrees ambient temperature. 1

The IEC 62301 has a broader, a looser 2

specification. It allows the temperature to range 3

from 64 to 82 degrees. 4

So, so the DOE test procedure as it 5

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

It's within the range allowed by IEC. 7

DOE is proposing that the test room 8

temperature specifically for "Standby" and "Off" 9

mode and these other low

- power states, the "Delay 10

Start" and "Cycle Finish ed " mode be specified 11

according to the broader IEC definition or, or 12

allo wable range, specifically, because it would 13

provide flexibility to manufacturers. 14

It would allow manufacturers to conduct 15

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

currently testing the existing "Active" mode 17

provisions, or it could allow manufacturers to set 18

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

mode that would not require as close temperature 20

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

S o, comments on that topic. 22

MR. BROOKMAN: Yes, Jennifer. 23

2458

MS. CLEARY: Yes. Jennifer Cleary. 1

AHAM believes that ambient temperature 2

should be extended beyond water

- heating machines to all 3

machines. It does have significant effect on th e 4

tests, and we think that the proposal should be 5

extended to all. 6

MR. BROOKMAN: Um

- hum. Thank you. 7

Other comments? 8

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

response was had.) 10

MR. BROOKMAN: Okay. 11

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

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

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

washers? 15

Or extended to all tests for all clothes 16

washers? 17

MS. CLEARY: I think we can expand a 18

little bit on that in our written comments. 19

MS. REICH: Okay. Thank you. 20

MR. BROOKMAN: Okay. Thank you, 21

Jennifer. 22

MS. REICH: Oop. This

-- Okay. 23

2459

Okay, then we get to t he important topic 1

of calculating how much energy on an annual basis 2

is associated with each operating mode. Currently 3

the metric that is used to measure energy use for 4

clothes washers is a modified energy factor, or 5

MEF. 6

It is def ined as the cubic feet of 7

clothes load capacity per total energy consumption. 8

And that is

-- It's a per

- cycle measurement, and it 9

in

- , it covers three contributors to energy use: 10

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

electrical energy c onsumed directly by the machine 12

during the cycle. 13

It also includes the energy that is used 14

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

it would also include this energy that's presumed 16

to be required by an accompanying clothes dryer to o , 17

of a clothes dryer to eliminate the moisture from 18

that load. 19

DOE is proposing in this new test 20

procedure that additional contributions from modes 21

that may not have been measured previously, namely 22

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

2460

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

the same basis; that is, on a per

- cycle basis 2

rather than, for example, in an, an energy

- use 3

basi s. 4

And it's important to note that the 5

total energy consumption in each mode depends not 6

only on the power that it is consuming in that 7

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

the year in each mode that would be allocated to 9

the, the, each active washing cycle. 10

So, the first contributor to look at is 11

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

is, is allocated to just washing the clothes? 13

DOE looked at multiple sources to, to 14

determin e what an average cycle time would be. It 15

varies, of course, from machine to machine, 16

depending largely on the axis of rotation, whether 17

it's a horizontal

- axis or vertical

- axis machine, 18

and the type of load that as being run. 19

DOE believes that calculating the, the 20

contributors to annual energy use on a single 21

average value of "Active" mode cycle time is 22

reasonable. It, it does not significantly impact 23

2461

the results if you do try to attribute different 1

cy cle times to top

- loaders and front

- loaders. 2

Our analysis shows that the, the final 3

number of annual numbers that would be allocated 4

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

one percent. Additionally,

-- And I think Tim is 6

goi ng to talk about this more in the "Active" mode 7

section.

-- based on review of the most recent 8

available studies that looked at consumer usage 9

patterns, DOE is proposing to reduce the number of 10

wash cycles that the average consumer uses during 11

t he year from the current 392 there in the test 12

procedure, to 295. 13

So, at one hour per cycle, this would 14

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

"Active" washing mode. 16

MR. BROOKMAN: I see a comment here. 17

Ed Osann. 18

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

example that's given in the bullet on this slide

-- 20

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

Witkowski and Mr. Sutherland conferred, out of the 22

hearing of others and off the Record, during which 23

2462

the following occurred:) 1

MR. OSANN:

-- is this based on any 2

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

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

the two loading formats , it would have this 5

nominal effect? 6

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

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

by reviewing available cycles in the, in the test 9

sample that DOE had. 10

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

hear the question. Would you repeat it? 12

MR. OSANN: Is the

-- Well, stated more 13

broadly, has DOE collected data on representative 14

cycle times for active washing for top loaders and 15

front loaders? 16

MR. BROOKMAN: Thank you. 17

Tim. 18

MR. SUTHERLAND: Tim Sutherland, 19

Navigant. 20

I believe these were made, determined 21

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

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

2463

been done on top loaders and front loaders in the 1

lab. 2

MR. OSANN: Okay. And this was a 3

limited number of machines. 4

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

ten machines that would form the basis of these 6

tests. 7

MR. SUTHERLAND: More. 8

MS. REICH: I think there was a larger 9

number, but

-- 10

MR. SUTHERLAND: Larger sample. 11

Probably about 20 machines or so. 12

MS. REICH: Right. It was not a 13

comprehensive samp le of all the machines on the 14

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

representative cross

- section. 16

MR. OSANN: And so more specifically 17

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

provided in the, in the, in the bullet, the, th e 19

bullet there listing the example, 45 minutes per 20

cycle for top loaders and 75 minutes per cycle for 21

front loaders, are those the actual average or 22

composite of the top loaders and front loaders that 23

2464

were tested in DOE batch? 1

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

maybe you could dig for that data. 3

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

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

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

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

-- 7

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

that there was no attempt to determine on a 9

weighted basis, you know, different cycle settings 10

that would have been selected, and weighting them 11

to obtain that 45 minutes. It

-- I think it's, you 12

know, generally selected as representative, and to 13

see, given that variation, what the impact would 14

be. 15

MR. OSANN: Okay. 16

MR. SUTHERLAND: Yeah. And I think 17

that's a n important part to remember, is that the, 18

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

in the slide, the impact was rather small. 20

MR. OSANN: I understood that was the 21

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

establish wheth er the, the numeric values that were 23

2465

used to illustrate the point were actual averages, 1

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

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

Witkowski and Mr. Sutherland conferred, out of the 4

hearing of others and off the Record, during which 5

the following occurred:) 6

MR. BROOKMAN: Illustratively a range. 7

MR. SUTHERLAND: Okay? 8

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

Okay, we're moving on. 10

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

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

of others and off the Record, during which the 13

following occurred:) 14

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

table shows how DOE is proposing to al locate energy 16

use based on measured power for the different modes 17

that it is proposing to incorporate into the 18

overall energy

- use metric. 19

So, just to recap, DOE believes that 20

clothes washers consume energy in five, the, the 21

five modes listed other than the active washing 22

cycle; namely, "Delayed Start

, " “C ycle Finished , "Self

- Clean," 23

2466

"Off," and "Inactive" mode s

. 1

DOE is recommending this, the following 2

allocation based upon studies that were examined to 3

show typical consumer usage patterns. "Delay 4

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

or to exist for approximately five minutes per 6

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

you know, a typical average, recognizing some 8

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

And that number is very low, obviously, 10

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

there is no time

- of

- use pricing in the United 12

States, so there is little incentive for consumers 13

to engage a delayed

- start function. 14

So, if it is estimated to be five 15

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

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

Start" mode would be 25. 18

Similarly, there is a low value 19

at tributed to "Cycle Finish ed " mode, again defining 20

"Cycle Finish ed " simply as the status display or 21

indicator to the consumer that the cycle is 22

finished. 23

2467

The three minutes are estimated based on 1

the time, typical time that the clothes washers 2

wait before entering a lower power state. And so 3

that would attribute or account for 15 hours on an 4

annual basis. 5

Based on a limited sample of clothes 6

washers that DOE actually perfor med testing on, and 7

measurements of the duration of the self

- clean 8

cycles, DOE determined an average of 1.3 hours per 9

self

- clean cycle. And reviewing manufacturers' 10

recommendation s in the product literature, typically 11

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

So, there would be twelve of those 13

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

attributable to either an "Off" mode or an 15

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

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

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

DOE conducted measurements of the 19

lower

- power modes to determine what typical values 20

would be of the power consumption by which then it 21

w ould multiply the numb

- , by the number of 22

associated annual hours to come up with annual 23

2468

energy use in each mode. 1

With the exception of the, the, the 2

average power in "Active Washing" mode, DOE 3

performed all of these measurements on its test 4

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

to be associated with each mode. 6

The number for the power measurement 7

average power per cycle in "Active Washing" mode 8

came from a 2 006 study based upon AHAM and 9

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

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

share, and "Self

- Clean" mode can be a, a relatively 12

significant contributor, up to 33 kilowatt

- hours 13

, but that the "D elay Start," "Cycle Finish ed ," 14

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

Start" and "Cycle Finish ed " are very small 16

contributors on an annual basis to the energy 17

consumption of a machine. 18

MR. BROOKMAN: Ed Osann. 19

MR . OSANN: Question on the slide, just 20

to understand this. What is the

-- What's the 21

basis for the three

- minute estimate for "Cycle 22

Finished"? 23

2469

MS. REICH: That was measurements, time 1

measurements that DOE took that was the average of 2

how long after the cycle some sort of indicator to 3

the consumer persisted. 4

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

and a member conferred, out of the hearing of 6

others and off the Record, during which the 7

following occurred:) 8

MR. OSANN: Okay. This is only the 9

indicator. 10

MS. REICH: This is not the tumbling. 11

MR. OSANN: This is only an indicator. 12

THE SPEAKER: Right. Right. 13

MR. OSANN: And this

-- And is this 14

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

machines that have a "Cycle Finished" function? 16

MS. REICH: I believe that was an 17

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

-- 19

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

and those that don't, averaged together? 21

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

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

2470

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

s uch a function. 2

MR. SUTHERLAND: Let me just

-- Tim 3

Sutherland of Navigant. 4

I believe the three minutes may actually 5

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

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

units that have that type of feature. 8

MS. REICH: Okay. 9

MR. SUTHERLAND: So, for example, 10

washers that only have electromechanical controls 11

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

so they would not have any cyc le

- finished activity. 13

Washers with electronic controls that 14

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

we, we saw that it usually lasted around three 16

minutes. 17

MR. BROOKMAN: Tim, were you referring 18

to a document there? 19

MR. SUTHERLAND: After

-- I'm looking, 20

I'm looking at Slide 34. 21

MR. BROOKMAN: Okay. I was wondering if 22

you had some additional source, or whether this was 23

2471

your remembrance. 1

MR. SUTHE RLAND: This is from memory. 2

MR. BROOKMAN: Okay. 3

MS. REICH: Could I, could I clarify 4

that before you go to the next question? 5

MR. BROOKMAN: Please do. Um

- hum. 6

MS. REICH: That's an important poi nt. 7

Machines that don't have the delay

- start 8

capability, the hours that would have been 9

associated in the table here are allocated 10

elsewhere. 11

So, just for the purposes

-- This is 12

done to evaluate the, how significant each mode is 13

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

actual methodology, if a machine does not have a 15

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

proposes to allocate the hours somewhere else. 17

MR. BROOKMAN: I see Tim has stepped up 18

again. 19

MR. OSANN: Could I just

-- 20

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

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

MR. SUTHERLAND: Thanks. Tim 23

2472

Sutherland. 1

One more thing is that we do have some 2

additional supporting slides at the end of the 3

presentation that provide a little more detail 4

about where we got those, so I recommend you

-- 5

MR. BROOKMAN: What slide number? At 6

t he very bottom of that slide in blue? 7

MR. SUTHERLAND: The supporting slides 8

start at Slide 117, and there are approximately 9

eight slides

-- 10

MR. BROOKMAN: Okay. 11

MR. SUTHERLAND:

-- that provide 12

additional da ta. 13

MR. BROOKMAN: Thanks for that. 14

Ed, do you want to continue? 15

MR. OSANN: Yeah, just to understand how 16

this is coming together, upon adoption of a test 17

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

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

sort of the prototype here assumed, how will that 20

be reflected in the test results? 21

MS. REICH: Currently the test procedure 22

would have a fixed number of hours for all machines 23

2473

that have that function. There would, there would 1

be a specific time that was assumed in the test 2

procedure that the power would be multiplied by in 3

order to determine the per

- cycle energy use. 4

The test cycle does not anticipate 5

ch anging the measurement time or the number of 6

annual hours for any individual machine. 7

MR. BROOKMAN: I saw Jennifer first. 8

MS. CLEARY: I just wanted to point here 9

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

consumed by delayed

- cycle start or finish, I think 11

you recognize the small amount of energy that is 12

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

support for what I was stating earlier, that this 14

is such a d e minim i s amount of, of energy that it 15

does not add to the, the national consumption 16

figures presently as it's into the significant 17

increase in the testing burden. 18

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

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

can provide some support for that practice. 21

MR. BROOKMAN: That would be helpful, 22

the details on that. 23

2474

Charlie Stephens. 1

MR. STEPHENS: Charlie Stephens. 2

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

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

comments. 5

But, the range for typical power is zero 6

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

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

consumption is 0? 9

MS. REICH: The

-- That's a good 10

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

MR. STEPHENS: Well, my concern is that 12

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

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

of them, and the av

- , and the, and the consump

- , 15

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

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

get a different number than you get if you divide 18

by ten. 19

And so I'm not sure that w hat we're 20

seeing here actually represents what we, what we 21

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

noticed, my impression of reading the Federal 23

2475

Register Notice about where these "Cycle Finish ed " 1

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

based on some Australian studies, I believe 3

primarily. 4

And in the past DOE has been rather 5

quick to dismiss data that comes, measured, metered 6

data sometimes that comes out of the, California or 7

the Northwest or wherever. I'm wondering why 8

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

Australia to support really what I think are 10

numbers that aren't supportable. 11

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

you're questioning the numbers. Would you suggest 13

-- 14

MR. STEPHENS: Cycle finish ed times, you 15

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

hate to go back to my own machine. 17

It's nothing more than anecdotal. But, 18

Whirlpool has made thousands of these things, and 19

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

beyond the "Active Wash" mode. 21

MR. BROOKMAN: Do you have a solution 22

for the Department here? Can you propose

-- 23

2476

MR. STEPHE NS: I think they need data. 1

I mean, there's an awful lot. 2

MR. BROOKMAN: They always want data. 3

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

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

There's an awful lot of arm

- wavi ng 6

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

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

but a study completed last year on, for the CP U C 9

suggested that the energy consumption of clothes 10

washers, and these were average clothes wa shers, I 11

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

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

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

week. 15

I don't consider that insignificant. 16

So, there's

-- What you're showing here is, is kind 17

of at cross

- purposes to what people are finding in 18

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

the bottom of it. 20

MR. BROOKMAN: Okay. Thank you. 21

Yes, Kelley. 22

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

2477

Just a comment on this slide that I 1

think ties together with the slide on Page 38, 2

which is the calculation of energy use per 3

operating mode. And it's on the "Self

- Clean" 4

cycle. 5

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

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

But, what we would note is we think that 8

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

some real potential for that to change the 12 10

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

customer dissatisfier in terms of needing to do 12

that monthly. 13

So, we think that manufacturers will be 14

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

number of, of cycles per year tha t would be devoted 16

to a self

- cleaning mode like that. So, I guess I 17

would just note it here. 18

But, then we get

-- When we get to the 19

energy slide about calculating the energy use 20

associated with it, we would recommend DOE consider 21

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

the manufacturer's use and care manual for what 23

2478

they recommend for self

- clean cycles; maybe keying 1

off that to recognize that we think there may be 2

variability in that going forward. 3

MS. REICH: Okay. 4

MR. BROOKMAN: Good. Other comments on 5

these issues? 6

Just, just a second. I want to make 7

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

wishes to comment. 9

No? All set? 10

Ok ay. 11

MS. REICH: Okay. 12

MR. BROOKMAN: Yes, Mike. 13

MR. McGARAGHAN: Mike McGaraghan. 14

Yeah, one quick question. 15

Mike McGaraghan, California utilities, 16

utilities. 17

You mentione d if a machine doesn't have 18

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

hours would be allocated. Where? 20

I assume you mean "Off," or

-- 21

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

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

2479

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

exactly the, those annual hours are proposed to be 2

allocated. 3

And so it's kind of intuitively obvious, 4

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

hence, it looks very busy. 6

But, essentially, any hours that are not 7

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

functions, then those hours would be allocated, 9

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

mode, because the nu mber of active washing hours 11

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

So, you know, this top section here is 13

where there's no self

- clean, so those 16 hours drop 14

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

just shows the, t he distribution by mode of how 16

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

measured, the measured power consumption in each mode 18

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

MR. BROOKMAN: Ed Osann. 20

MR. OSANN: Ye ah. I just wanted to 21

reiterate a point I made briefly earlier, and that 22

is that, that we would recommend a determination of 23

2480

no self

- clean versus self

- clean be, be based upon 1

manufacturers' recommendations and not hard machine 2

features. 3

And really, also support the idea just 4

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

keyed to the manufacturers' recommendation. 6

MR. BROOKMAN: Okay. 7

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

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

MR. BROOKMAN: Let me just make

-- At 10

some point here he should take a break

-- 11

MS. REICH: Okay. Okay. 12

MR. BROOKMAN:

-- whenever there's a 13

good stopping point. 14

MS. REICH: Okay. I think maybe after 15

the next request for comment. 16

MR. BROOKMAN: Okay. 17

MS. REICH: Okay. So, DOE believes 18

that, that for clothes washers, the definition of 19

"Off" mode applies to those unit s that have 20

electromechanical controls rather than electronic 21

controls, or it could also apply to units with 22

electronic controls but with a hard mechanical 23

2481

"On/Off" switch. 1

If, as is provided on many if not most 2

units with electron ic controls, if there is a, a 3

push

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

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

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

mode as opposed to in "Off" mode. 7

DOE, DOE believes that that category, 8

the clothes washers that have electronic controls 9

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

probably not many out there on the market, and 11

therefore the test of how to allocate the combined 12

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

the type of control present on the clothes washer. 14

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

noted, if it has electronic controls, that would 16

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

electromechanical, it, those hours would be 18

associated with "Off" mode. 19

For those few washers that have both 20

mechanical controls and the electronic controls, 21

you know, DOE recognizes there's information out 22

there about usage p atterns, how consumers would use 23

2482

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

would allocate half of those combined hours to each 2

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

MR. BROOKMAN: Joanna Mauer. 4

MS. MAUER: Joann a Mauer. 5

On that last point about how you're 6

proposing to allocate powers for those machines 7

that would have electronic controls and the 8

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

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

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

these switches. 12

MS. REICH: Um

- hum. 13

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

appropriate to give some kind of a credit to power u s e 15

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

seems to present a situation where these switches 17

could be included, and consumers might never use 18

them. 19

They could even be almost hidden from 20

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

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

MR. BROOKMAN: Okay. Thank you. 23

2483

Additional comments? 1

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

response was had.) 3

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

into how to allocate all the combined measurements 5

into the single per

- cycle metric, DOE is proposing 6

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

"Cycle Finish ed " mode energy use would be calculated 8

by, for each of those modes, multiply ing the 9

measured power in watts, and the allocated hours 10

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

Then, all of those contributors would 12

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

a kilowatt

- hour basis. And then in order to

-- 14

That's the annualized number. 15

And then in order to turn that into a 16

per

- cycle measurement, it would be divided by the 17

295 annual

- use cycles. For self

- clean, it's a 18

little bit of a different situation because there 19

are a specific number of, discrete number of cycles 20

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

estimated to be 12. 22

So, DOE proposes that if "Self

- Cleaning" 23

2484

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

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

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

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

ap portion it on a per

- cycle, per

- active

- cycle basis. 5

I would like to point out in th e Notice 6

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

regulatory text for this particular calculation. 8

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

But, the

-- It does not right now do, 10

perform the, the calculation of multiplying the 11

energy used by 12 and dividing by 295. 12

MR. BROOKMAN: Ed Osann. 13

MR. OSANN: You, you mention 12 14

instances of, of self

- clean per year. Why is the 15

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

number of hours for self

- c leaning assigned at 16, 17

rather than 12? 18

MS. REICH: Oh, because each 19

"Self

- Clean" cycle was estimated as 1.3 hours, 20

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

MR. OSANN: Okay. 22

MS. REICH: DOE has considered an 23

2485

alternative approach, recognizing that in its 1

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

that, that the power consumption in some of these 3

modes, such as "Delay Start" and "Cycle Finish ed ," 4

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

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

unique modes. 7

The power associated with them is fairly 8

consistent among these modes, also, recognizing, as 9

has been pointed out, the annual energy 10

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

So, DOE proposed an alternative method 12

in which the "Inactive" and "Off

- Mode" power levels 13

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

and "Cycled F inished" power, and therefore DOE 15

would only require measurement in the "Off" and 16

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

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

Start" to "Inactive" and "Off" mode s

. 19

So, DOE believ es that the final annual 20

energy use would still be representative, but it 21

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

burden. So, DOE would appreciate any comments on 23

2486

calculating the energy use in the different modes, 1

including the estimat es of, of annual hours, and 2

certainly would welcome any thoughts on this 3

alternative approach to, to, to only require 4

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

MR. BROOKMAN: Ed Osann. 6

MR. OSANN: Just so that, that w e 7

understand this correctly, the alternative approach 8

essentially would be to disregard the 9

characteristics of "Delay Start" and "Cycle 10

Finish ed ." So, the, the, under the alternative 11

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

"Active" mode and everything else. 13

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

disregards the characteristics. It says it is 15

based on the observation that, that in many cases 16

the "Delay Start" and "Cycle Finish ed " power level s , 17

even though they may represent different functions 18

being activated on the machine, the power being 19

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

and therefore the energy use can be accounted for 21

in the test procedure by simply making one 22

representative measurement of power, and, and 23

2487

computing the total energy use on all hours that 1

would have comprised the three modes. 2

It is not neglecting energy in "Delay 3

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

together wi th "Inactive" mode, saying that the 5

energy, energy use that would be measured would be 6

representative of all three of the modes, but would 7

not require individual measurements of the three 8

modes to obtain. 9

(Whereupon, two members confe rred, out 10

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

which the following occurred:) 12

MR. OSANN: So, the distinct ive 13

functionalities of, of, of given models that would 14

fall into these other two mode categories really 15

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

factored into? 17

MS. REICH: Under the alternative approach

. 18

Yes, Ed. Thank you. 19

MR. BROOKMAN: Jennifer? 20

MS. CLEARY: Jen Cleary. 21

AHAM supports the a lternative because of 22

what we spoke of before, that these do represent 23

2488

such a small amount of energy. 1

MR. BROOKMAN: Okay. Thank you. 2

Charlie. 3

MR. STEPHENS: My impression at the 4

moment is we might support the alternative approach 5

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

defined for each machine as tested as including any 7

end

- of

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

mode, which you are purporting to count here as 9

whatever hours are left o ver at the end of the 10

active cycle, which would include end

- of

- cycle 11

because you've already included end

- of

- cycle as 12

part of the active mode. 13

MS. REICH: Um

- hum. Okay? 14

MR. STEPHENS: So, each machine that 15

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

hours that you found tumbling. 17

MR. BROOKMAN: Okay? 18

MS. REICH: Okay. Any information you 19

have in defining that end would be very much 20

appreciated. 21

I'm not sure if there are machines that 22

can continue that function indefinitely, but, you 23

2489

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

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

would be appreciated. 3

MR. B ROOKMAN: You see the comments box 4

there. Any additional comments on these proceeding 5

slides? 6

Okay, let's take a break. 7

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

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

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

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

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

MS. REICH: Okay. The last topic that 13

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

the presentat ion, the current metric in the test 15

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

metrics which is defined as an Energy Conservation 17

Standard metric. 18

It is the basis of the current 19

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

of the washer divided by the existing total energy 21

use in kilowatt hours. 22

Right now it's the weighted per

- cycle 23

2490

energy required to heat the water, the weighted 1

per

- cycle electrical energy that goes into the 2

machine, and the per

- cycle energy consumption that 3

is assumed to be required to remove whatever 4

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

the clothes washer cycle by drying it. 6

EPCA now requires that "Standby" and 7

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

energy efficiency descriptor unless or if it is 9

technically feasible to do so. And so DOE examined 10

whether that would be possible, to integrate it, 11

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

per

- cycle basis. 13

DOE believes that it can be incorporated 14

into a new metric named "integrated modified energy 15

factor" by calculating a measure, or by calculating 16

adding in two additional measures of energy use. 17

The first would be a per

- cycle 18

measurement that incorporates all of the energy use 19

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

and "Cycle Finish ed " mode. And then the second 21

contributor, new contributor would be a per

- cycle 22

self

- clean energy consump tion. 23

2491

So, simply to get the integrated MEF, 1

IMEF would be the same type of methodology where 2

you simply sum together all the contributors in 3

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

denominator with capaci

- , the, the capacity 5

measurement in the numerator. 6

DOE would like to receive comment on 7

whether this is an appropriate approach, and 8

whether IMEF is an appropriate metric to use. I 9

saw Ed first. 10

MR. OSANN: Ed Osann. 11

Can, can you spread light on the basic 12

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

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

rather than per year? The dishwasher Standard, in 15

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

c onsumption per year. 17

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

relevance in converting us back to and maintaining 19

a per

- cycle metric? 20

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

the existing dishwashing Standards are based on an 22

annual energy

- use metric, not a per

- cycle 23

2492

measurement

-- 1

MR. OSANN: Right. 2

MS. REICH:

-- so that when DOE 3

considers integrating energy use there, there's an 4

existing annual

- use metric that's the basis of the 5

Standard s. 6

Right now the basis of Standards for 7

clothes washers is a per

- cycle measurement, and DOE 8

considered retaining that for the purposes of, of 9

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

MR. OSANN: Well, was there any 11

consideration by DOE in, in moving to an annual 12

energy, energy consumption metric? 13

And what were the, what might the 14

considerations have been? 15

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

-- 17

MR. BROOKMAN: Steven Witkowski. 18

MR. WITKOWSKI: Well, really, this is 19

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

putting forward is what we consider to be the best 21

approach based on the input we received, and 22

methodologies that we received. 23

2493

And, you know, we're certainly willing 1

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

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

discussions other than what was presented at the 4

public meeting. This is not a policy discussion. 5

MS. REICH: I think if there is 6

information available that would suggest that one 7

metric is better than the other, we certainly invite 8

any comments we can. We can, absolutely. 9

And throughout the whole process we have 10

invite d that. 11

MR. BROOKMAN: Okay. Thank you. 12

Jennifer. 13

MS. CLEARY: I think

-- Jennifer Cleary. 14

We would reiterate that the "Delayed 15

Start" and "Cycle Finished" are d e minim i s, and, in 16

terms of their energy consumption, and thus should 17

not be included here. 18

MR. BROOKMAN: Additional comments on 19

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

along 21

We have a lot to cover. 22

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

2494

proposing or did not propose in the NOPR to amend 1

the annual operating cost calculation that's 2

currently provided in 10 CFR 430. 2 3; DOE is not 3

proposing to amend it to account for the cost of 4

energy consumed in anything othe r than the "Active 5

Washing" mode. 6

And the reasons were, for this rulemaking, the 7

determination was that right now the Energy Guide 8

label provides a comparison of the cost for a given 9

clothes washer model to a range of an operating 10

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

the annual operating cost measure were changed, 12

then, then this would no longer allow a direct 13

comparison within the range that's provided on the 14

Energy Guide label. 15

And, additionally , DOE believes that 16

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

would be now measured for "Self

- Clean," "Standby," 18

"Off," "Delay Start

, " and “C ycle Finish ed " modes are 19

small contributors to the annual operating cost 20

calculation, and so, the refore, because it's 21

negligible and because of the potential impact on 22

the Energy Guide label, DOE did not propose 23

2495

amending that cost calculation. 1

MR. BROOKMAN: JB. 2

MR. HOYT: You see the question on my 3

face. 4

MR. BROOKMAN: Yes. 5

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

understand this. You're saying we should measure 7

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

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

MS. REICH: Well, it would be measured 10

for the purposes of calculating an integrated MEF 11

as required under EISA. It's a statutory 12

requirement. 13

But, DOE did, did propose not to change 14

the cost calculation because of the effects on a 15

program o utside of DOE at the Federal Trade 16

Commission. 17

MR. HOYT: I'm just

-- I find those in 18

violent conflict with one another, and will comment 19

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

just is inconsistent. 21

MR. BROO KMAN: Okay, thank you. 22

Joanna. 23

2496

MS. MAUER: Joanna Mauer. 1

I'm

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

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

statement, because when the new clothes washer 4

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

minimum and maximum operating costs would have to 6

be revised to take the new Standards into account. 7

And so seems like when that happens, the 8

Energy Guide label can, I mean, it has to b e 9

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

that these additional annual operating costs could 11

be incorporated at that point. 12

I think we just generally support 13

incorporating all the energy use if it's intended 14

to actually rep resent the annual energy cost of the 15

product, which would include these other modes as 16

well. 17

MR. BROOKMAN: Okay. Other comments? 18

Ed Osann. 19

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

slide says "Active washing mode." Is that 21

particularly to parse out "Active" mode to only 22

the, just the, the wash mode piece? 23

2497

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

to the existing calculation. The existing 2

calculation is based on the energy use just for the 3

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

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

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

cycle? 7

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

MR. BROOKMAN: Charlie Stephens. 9

MR. STEPHENS: Charlie Ste ph ens. 10

Could I ask you how you define the end 11

of the active washing mode? 12

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

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

currently have a definiti on for it. 15

This is based on the existing 16

methodology to measure M E F. This has not been a 17

topic that has been raised before, so we certainly 18

appreciate any information you have on that. 19

MR. STEPHENS: Guess I want to know, 20

then, how manufacturers are, are measuring this 21

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

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

2498

the manufacturers. 1

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

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

available, that would be useful for the 4

Department's purposes. 5

Charlie. 6

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

little mind boggling that people can't answer that 8

que stion. 9

But, okay. 10

MR. BROOKMAN: Maybe in written 11

comments, Charlie. 12

Mike, you have a comment? 13

MR. McGARAGHAN: Yeah, Mike McGaraghan, 14

California utilities. 15

Just a big

- picture question that I might 16

be missing something. What does the annual energy 17

cost have to do with the test procedure? 18

How does that factor in? 19

MS. REICH: Because Section 430. 2 3 is 20

part of DOE's test procedures for covered pro ducts. 21

It's

-- There are calculations provided there, as 22

well as in Appendix J

- 1 and proposed J

- 2 that apply 23

2499

to clothes washers. 1

MR. BROOKMAN: Additional comments? 2

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

response was had.) 4

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

one. 6

MR. BROOKMAN: Um

- hum. 7

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

going to turn the presentation over to my 9

colleague, Tim Sutherland. 10

MR. BROOKMAN: Do you w ant to use the 11

microphone up there from the podium, or the 12

hand

- held? 13

MR. SUTHERLAND: You might go in case I 14

move from the podium. 15

MR. BROOKMAN: Higher. Good. 16

MR. SUTHERLAND: How's that? 17

MR. BROOKMAN: Yeah. Yeah. 18

MR. SUTHERLAND: Good? 19

MR. BROOKMAN: Just slide

-- 20

CLOTHES WASHER ACTIVE MODE TEST PROCEDURE: 21

MR. SUTHERLAND: Okay. Hi, everyone. 22

Just to reintroduce myself, I'm Tim 23

24100

Sutherland with Navigant, part of the Clothes 1

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

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

And I think we're supposed to break for 4

lunch somewhere around Part B here, so I guess 5

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

take your lunch break. 7

MR. BROOKMAN: Our target is to quit 8

rather about 12:30. 9

MR. SUTHERLAND: Okay. All right. 10

So, first we'll get started with 11

technologies that are not covered by the current 12

J

- 1 test procedure. So, currently J

- 1 does not 13

cover steam wash cycles. 14

DOE is aware of numerous washers on the 15

market that offer steam wash cycle, and these are 16

seen, for the most part on front l oaders. 17

In response to comments in the 18

framework, though, DOE is proposing to include 19

specifications for measuring both water and energy 20

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

proposing to include a separate section descr ibing 22

the measurement for the steam wash cycles, and to 23

24101

also include the energy and water consumption 1

values from that cycle in the final calculations. 2

So, DOE is proposing, for washers that 3

have steam cycles, to measure the energy and water 4

consumption of the steam wash cycle using the 5

hottest wash temperature. And along with this, 6

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

4.1.1, which has the temperature use factors. 8

DOE lacks con

- , data on consumer usage 9

of the steam cycles, but believes that the 10

inclusion of the steam cycle would decrease the 11

number of extra

- hot cycles that can, that the 12

consumer would run. 13

DOE believes that the extra

- hot and 14

steam cycles are likely to be reserved for the most 15

heavily soiled loads, with steam cycle selected 16

somewhat less frequently. And so based on this, 17

DOE is proposing to use a temperature use factor of 18

0.02 for the steam

- wash cycles, and the extra

- hot 19

use factor would be decreased by 0.02. 20

So, extra

- hot would go from either .05, 21

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

, 22

depending on which set of temperature use factors 23

24102

apply. So, DOE requests comment on the proposed 1

inclusion of energy and water consumption of steam 2

wash cycles, including the associated use factor. 3

And DOE also requests any data available 4

regarding consumer usage patterns for steam wash 5

cycles. 6

MR. BROOKMAN: JB. 7

MR. HOYT: JB Hoyt, Whirlpool. 8

Tim, on Slide 4 you say many clothes 9

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

have a definition of "many"? 11

Do you have a percentage? 12

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

numerical percentage, so

--

. 14

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

hoping that you had one. 16

But, you're saying many do, but 17

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

you're going to use a two

- percent factor for it. 19

MR. SUTHERLAND: That's right. 20

MR. HOYT: Okay. Thank you. 21

MR. WITKOWSKI: Excuse me. Actually 22

what we're as king for

-- 23

24103

MR. BROOKMAN: Steven Witkowski. 1

MR. WITKOWSKI: Steven Witkowski. 2

Actually what we're asking for is you 3

have any data that would either support or negate. 4

MR. HOYT: JB Hoyt, Whirlpool

. 5

We'll attempt to do so, Steve. 6

MR. WITKOWSKI: Thank you. 7

MR. BROOKMAN: Yes. Please. 8

MR. JOHNSON: Chris Johnson, LG 9

Electronics. 10

To follow

- up on JB Hoyt's point is that 11

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

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

manufacturers in this room that disagree on what is 14

steam. 15

So, without, without a (sic) agreed

- upon 16

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

you know what the water and energy factor of steam 18

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

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

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

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

MR. BROOKMAN: Kelley Kline. 23

24104

MR. JOHNSON: That's why this is 1

problematic. 2

MR. BROOKMAN: Thanks, Chris. 3

Kelley? 4

MS . Kline: N o, that was what I was 5

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

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

there needs to be a pretty definitive definition of 8

what is a steam cycle. 9

MR. BROOKMAN: Uh

- huh. If, if, if th ere 10

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

to comment knowledgeably on these, these figures 12

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

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

we would. 15

I'd have to check with

-- I'd have to 16

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

know just looking at it they thought the critical 18

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

MR. BROOKMAN: Um

- hum. 20

Other comments? 21

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

talk about self

- clean cycles now. 23

24105

Many clothes washers currently on the 1

market offer a "Self

- Clean" cycle. DOE observes this 2

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

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

of the higher

- efficiency top

- loaders. 5

And Judith went through the, our 6

definition of what's defined as a self

- cleaning 7

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

But, DOE is proposing to include the energy and 9

water consumption that occurs during the 10

"Self

- Clean" cycle into the overall efficiency 11

metrics. 12

Also, something to note is that this 13

would benefit clothes washers designs that have 14

ways of addressing mold and odor issues without 15

requiring periodic "Self

- Clean" cycles. 16

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

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

DOE is proposing to incorporate this would be to 19

mea sure the energy and water consumption of a 20

self

- cleaning cycle with no load, multiply that by 21

12, and divide by 295. 22

This effectively apportions the annual 23

24106

energy and water use of the self

- clean cycles among 1

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

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

published, this step has, was inadvertently 4

omitted. 5

So, that will be corrected in the final 6

version of the test procedure. The

-- And by that, 7

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

So, DOE is requesting comment on the 9

self

- cleaning cycles for clothes washers, including 10

the proposed definition, the inclusion of the 11

energy and water use of, in IMEF and IWF 12

calculations, and whether there's any relevant data 13

available regarding consumer use of these cycles. 14

MR. BROOKMAN: Ed Osann. 15

MR. OSANN: Just a clarification. 16

You've mentioned that the omission, the omission 17

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

discussed in the narrative text of the

-- 19

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

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

which is the, the text of the J

- 2 test procedure. 22

MR. OSANN: The body of the

-- 23

24107

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

part

-- It's in the water

- consuming part where it 2

describes how to calculate the water consumption 3

for the self

- cleaning cycles. 4

MR. BROOKMAN: You see the comment box 5

there. Comment on self

- clean cycles, including 6

proposed definition, inclusion of self

- clean cycle 7

energy and water use into the IMEF and IWF 8

calculations, and any other relevant data. 9

Kelley? 10

M S . Kline: Kelley Kline, G.E. 11

I just wanted to reiterate the comment 12

we made earlier about the 12 cycles per year. 13

MR. BROOKMAN: Okay, thank you. 14

Okay. 15

MR. SUTHERLAND: All right. Talk about 16

adaptive control technologies. 17

In general, adaptive control 18

technologies are technologies that can adjust the 19

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

soil level, other, other wash parameters. 21

Currently the J

- , J

- 1 test procedure 22

accounts for adaptive fill control, but no other 23

24108

adaptive controls. DOE did receive comments in 1

response to the framework document stating that 2

adapt

- , adaptive controls a re already widely used 3

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

residential clothes washers that use, that 5

incorporate soil

- sensing systems. 6

DOE's only aware of clothes washers that 7

use adaptive controls to adjust the fill level, and 8

so DOE lacks data on any other type of adaptive 9

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

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

to account for any other adaptive controls o ther 12

than adaptive fill control in the J

- 2 test 13

procedure. 14

The demand response technology, we talked 15

about this. This is a S mart Grid feature. 16

Again, I won't reiterate the definition, 17

but at this time DOE's unaware of a ny clothes 18

washers that currently contain any demand response 19

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

proposing to amend the test procedure to include 21

the energy consumption in "Network" mode. 22

Once clothes washers offering these 23

24109

features and appropriate data and testing 1

methodologies have become available, DOE will, can 2

consider incorporating these amendments into the 3

test procedure. 4

So, I’ll pause here and request comment 5

on whether there are any other clot hes, or any 6

clothes washers on the market that offer adaptive 7

controls other than soil sensing, or

-- I'm sorry. 8

DOE requests comment on whether there 9

are any washers currently available that do offer 10

soil sensing as well as demand response features. 11

MR. BROOKMAN: Jennifer. 12

MS. CLEARY: AHAM agrees that at the 13

current time there is not sufficient data regarding 14

demand response. However, when it does become 15

available we believe it should be addressed, and we 16

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

pursuant to your request. 18

MR. BROOKMAN: Thank you. 19

MR. SUTHERLAND: All right. 20

MR. BROOKMAN: Ed Osann. 21

MR. OSANN: Ed Osann. 22

I think we would reiterate the point 23

24110

made earlier that, that there needs to be some 1

anticipation of, of the near

- term commercialization 2

of, of clothes washers with networking 3

functionality, and at a mi nimum, some sort of 4

placeholder be established within the context of 5

this version of the test procedure to anticipate 6

that. 7

MR. BROOKMAN: Thank you. 8

Okay. 9

MR. SUTHERLAND: All right. Thanks. 10

S o, we'll jump into Part B here, talking 11

about changes that reflect current usage patterns 12

and capabilities of washers. All right. 13

The first

-- Again, we've talked about 14

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

cycles. 16

Previously DOE has estimated the number of 17

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

supporting the updating of this value. Currently 19

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

calculations for M EF or water factor in the J

- 1 21

test procedure. 22

However, as we've discussed, it will 23

24111

factor into the J

- 2 test procedure, specifically as 1

part of the calculation for self

- cleaning energy. 2

So, DOE considered these three data sources to, 3

when determining how to upda te this number. 4

The EIA's 2005 residential energy 5

consumption survey, or RECS, the 2004 California, 6

California Residential Appliance Saturation Survey, RAS S , and 7

a data submittal from Proct e r & Gamble

-- And you 8

can see the number of annual use cycles was 295 9

from RECS, 283 from RAS S , and 308 from P&G. 10

So, just a little more detail about how 11

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

RECS data is the most representative of, of 13

consumer s throughout the country. 14

The California RAS S data is only for 15

consumers in that one State. Sim

- , or separately 16

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

had fewer single

- person households than suggested 18

by the most recent C ensus survey, so we believe, or 19

DOE believes that that may slightly overestimate 20

the number of cycles. 21

And so, based on this, DOE concluded 22

that 295 cycles per year is a reasonable estimate 23

24112

of actual consumer use. And DOE welcomes comment 1

on the proposal to use 295 clothes

- washer cycles 2

per year. 3

MR. BROOKMAN: Ed Osann. 4

MR. OSANN: Was there a date provided on 5

the P&G submittal? 6

MR. SUTHERLA ND: I've

-- Off the top of 7

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

MR. BROOKMAN: Charlie Stephens. 9

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

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

about 2005, if I'm not mistaken. 12

MR. BROOKMAN: Mike, do you know? 13

MR. LAW: I believe it was about that 14

time, also. 15

MR. BROOKMAN: Okay. 16

Charlie Stephens. 17

MR. STEPHENS: Charlie Stephens. 18

MR. BROOKMAN: Which, to s ay that Mike 19

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

name for the Record. 21

MR. LAW: Sure. Michael Law. Michael 22

Law, from NIST. 23

24113

MR. BROOKMAN: Thank you. Thank you. 1

Thank you. 2

Charlie Stephens. 3

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

instrument for RECS, and when it comes to 5

clothes

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

range of response offered was very credible. That 7

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

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

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

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

when we start talking about this. 12

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

RECS surv ey responses what the number is. There's 14

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

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

the survey was designed badly for that metric. 17

However, the P&G data was backed up 18

rather w ell by the recent California data, which I 19

think was something on the order of 310 annual 20

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

found. 22

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

24114

to be more credible than either the RECS data or 1

the California RAS S data, which we agree had a, a, a 2

misaligned household size in its sample. 3

MR. SUTHERLAND: Okay. 4

MR. BROOKMAN: So, Charlie, would you 5

comment specifically on the number here, 295? 6

MR. ST EPHENS: We think, as I said, we 7

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

which would be 308. 9

MR. BROOKMAN: Thank you. Just want to 10

be specific. 11

MR. SUTHERLAND: And DOE would welcome 12

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

know,

-- 14

MR. STEPHENS: That was delivered in 15

August, so I think that's available. 16

MR. BROOKMAN: Steven Witkowski. 17

MR. WITKOWSKI: Also we would welcome, 18

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

the problems and methodologies that you have with 20

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

examine them. 22

MR. BROOKMAN: Thank you. 23

24115

Joanna. 1

MS. MAUER: Joanna Mauer. 2

I was just wondering whether the 3

proposed 295 cycles per year matches up with the 4

proposed number of cycles in the dryer test 5

procedure, accounting for the dryer use factor. 6

MR. SUTH ERLAND: I'll have to turn that 7

over to Judy. 8

Does the number of

-- Does the 295 9

cycles proposed here match up with the number of 10

cycles in the dryer, the proposed dryer test 11

procedure? 12

MR. BROOKMAN: Judy Reich. 13

MS. REICH: Judy Reich. 14

Yes, I believe that if

-- I know the 15

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

They're

-- I think the proposed value is 273. 17

And I think that's intended to account 18

for about an 80

- or 84

- percent usage factor. So, 19

so I think it's close. 20

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

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

range rather than the existing number. 23

24116

MR. SUTHERLAND: Thanks

. 1

MR. BROOKMAN: Ed Osann. 2

MR. OSANN: Yeah. Apologies if I missed 3

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

the slide refers to a data submittal from Procter & 5

Gamble. 6

Is there a more specific cite for that? 7

And, and in what proceeding was that entered into 8

the public domain? 9

MR. SUTHERLAND: Judy, do you have any 10

recollection of that? 11

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

get back to you on that on the cite. 13

MR. SUTHERLAND: Yeah. 14

MR. BROOKMAN: Okay. 15

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

Can, can you tell us that? 17

MS. REICH: I believe it was. 18

MR. BROOKMAN: So, Judy says she 19

believes it was a submittal to DOE. 20

But, you can check on that. 21

MS. REICH: Yes. 22

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

24117

going to keep going. 1

MR. SUTHERLAND: Okay, thanks. 2

All right, test load size 3

specifications. So, currently in J

- 1 it's Table 4

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

function of clothes container volume. 6

And the table goes up to 3.8 cubic feet. 7

DOE is aware of numerous clothes washers available 8

on the market that have volumes that exceed this 9

level, and multiple stakeholders commented that 10

this table needs to be updated. 11

In the past , DOE has granted an interim 12

test procedure Waiver to Whir lpool for three 13

clothes washer models that had capacities greater 14

than 3.8 cubic feet, and this test procedure 15

concerns the linear relationship between the next 16

test, test load size and the container volume to 17

include containers of 3.8 to 3.9 fee t. 18

Additionally, DOE's aware of only 19

limited data regarding typical clothes washer load 20

sizes. That leads into this part of the 21

discussion. 22

T he one 2003 P&G study showed an 23

24118

average load of 7.2 pounds for top loader s , 8 .4 1

pounds for front loaders. And this would 2

correspond to the, the 2.7

- cubic

- foot bin and the 3

2.3

- cubic

- foot bins. 4

And these numbers look to be pretty 5

compatible with the shipment

- weighted average 6

capacity reported in the 2005 AHAM F act B ook, which 7

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

to be pretty reasonable. 9

Separately, AHAM data shows that from 10

'90

- , 1993 to 2005, tub capacities have increased 11

by about 14 perce nt. And RECS data indicate that 12

the number of cycles per year during that same time 13

period has decreased by a similar amount, by 14

roughly 17 percent. 15

So, this leads to the conclusion that if 16

you assume that households continue to wash the 17

same volume of clothes each year, that the average 18

load size is increasing with capacity. So, this 19

limited data suggests that the current values in 20

the test loads size table are appropriate, and th at 21

extending that linear relationship between test 22

load size and container capacity is valid. 23

24119

And so DOE is proposing to extend Table 1

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

DOE welcomes comment on the proposed test load 3

sizes, on whether the linear relationship between 4

test load size and container volume is 5

representative of actual consumer use. 6

And, as always, DOE invites any relevant 7

data on this topic. 8

MR. BROOKMAN: Kelley. 9

MS

. KLINE : Kelley Kline, from GE. 10

Yeah, we would support this. We think 11

it's necessary to reflect the current market 12

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

has granted additional interim Waivers going up to 14

4 .4 cubic feet, including one to G.E. a few months 15

ago. 16

MR. BROOKMAN: Okay. Thank you. 17

Ed Osann. 18

MR. OSANN: Ed Osann. 19

While, while much of the, the material 20

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

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

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

24120

load size increases with capacity, we would point 1

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

potential concern here for bias in t he test 3

procedure towards larger

- capacity machines due to 4

the fact that the, the average load does not 5

increase proportionately with the machine capacity. 6

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

are, the relationship between the thre e loads is 8

constructed, the

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

also that the average load does dominate the 10

results of the test procedure because of the usage 11

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

So, that tracks the, tracks the increase 13

in the machine capacity directly. The minimum load 14

is a specific number that doesn't move. 15

So, it does not track the machine 16

capacity directly, and the average load is, is 17

anchor ed by that minimum load to the extent that 18

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

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

minimum and the maximum. 21

So, the average load under the current 22

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

24121

extend it, the average load shrinks as a percentage 1

of machine volume as the machine volume increases. 2

So, for smaller

- capacity machine s , the average load 3

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

larger

- capacity m achine, the average load may 5

represent 54 percent of capacity because of, 6

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

minimum load that does not change. 8

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

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

potential for bias towards large

- capacity machines. 11

This would suggest that as consumers 12

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

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

machine and, and use, and, and, and, a nd leave more 15

capacity unused, relatively speaking. 16

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

any data to support, to support that. 18

MR. BROOKMAN: So, you question the 19

linear relationship that is positive here. 20

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

linear, but it's not proportionate. 22

MR. BROOKMAN: Okay. So, that

-- 23

24122

Certainly the Department would really welcome data 1

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

Judy. 3

MS. REICH: Judy Reich, from Navigant. 4

I would also invite comment on whether 5

the concern is with the fixed minimum load size or 6

with the calculation of the average load size as 7

the mid

- point between the maximum a nd minimum. Is 8

it in

-- 9

MR. OSANN: Right. 10

MR. BROOKMAN: Humm. Thank you. 11

Yes, Chris. 12

MR. JOHNSON: Chris Johnson, LG 13

Electronics. 14

We just also support DOE's proposal, and 15

we agree with GE's comments. 16

MR. BROOKMAN: Thank you. 17

Jennifer. 18

MS. CLEARY: Jen Cleary. 19

I just have a question. I mean, we 20

support the table, and we have a question about 21

whether it was intentional that the values in 22

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

24123

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

curious to know why. 2

MR. SUTHERLAND: Judy, does, did you 3

want to comment on tha t? 4

MS. REICH: Judy Reich. 5

There were some very slight differences 6

that were introduced based on conversion factors 7

from pounds to kilograms, and where the rounding 8

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

was no intentional message implied by the 10

formatting in the Federal Register Notice that 11

dropped off trailing decimal zeros in the, the 12

decimal places. 13

Those should all be expressed to two 14

significant digits, the load sizes. 15

MS. CLEARY: Thank you. 16

MR. WITKOWSKI: And just one other thing 17

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

were printed incorrectly, so those were, clerical 19

errors will be fixed for the Final Rule. 20

MR. BROOKMAN : Mike, do you want to 21

comment? 22

MR. LAW: Yeah. Mike Law with the 23

24124

California utilities. 1

Mostly just wanted to echo Ed's comments 2

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

calculation could include some bias towards large 4

machines, and encourage DOE to look into that 5

further, especially the, the anchor at three pounds 6

per load. 7

And, unfortunately, we're not aware of 8

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

consider trying to gather at some point in the 10

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

anything in time for this rulemaking. So,

-- 12

MR. BROOKMAN: Okay. 13

MR. LAW :

-- we encourage DOE to look 14

into that issue. 15

MR. BROOKMAN: Yes. Please say your 16

name for the Record. 17

MR. KANG (phonetic): John Ka ng 18

(phonetic). 19

I look, I looked in that customer can 20

reduce number of, by using bigger drum for loads 21

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

number wash size per year should be different by

-- 23

24125

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

representing? 2

MR. KANG : LG Electronics. 3

MR. SUTHERLAND: And otherwise

-- 4

MR. KANG : And also test tub size in 5

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

size of, size of the machine. 7

MR. SUTHERLAND: I just wanted to 8

clarify. So, for

-- for the first part, and also 9

the second part. 10

So, do you mean that the maximum test 11

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

for all washers? 13

MR. KANG : Yes. Right. 14

MR. SUTHER LAND: Regardless of size. 15

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

clarifying question on that. 17

MR. KANG : The number of wash cycle per 18

year should be depreciated by the volume. 19

MR. SUTHERLAND: So, so

-- Okay. 20

MR. BROOKMAN: Okay. 21

Yeah, Chris. 22

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

24126

I can clarify what we're saying, what 1

the container capacity

-- The volume is different 2

for the, if the, if the large capa city, large 3

container

-- If you have different sizes, then the 4

cycles are different. 5

MR. BROOKMAN: Right. 6

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

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

distinction between the size and the volume of the 9

container, because the larger of the container, the 10

larger the volume, the less the cycles. 11

I think I've got that right. 12

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

MR. BROOKMAN: Thanks, Chris. 14

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

-- 16

MR. BROOKMAN: Okay. Okay. 17

MR. SUTHERLAND: All right? 18

MR. BROOKMAN: Yeah. 19

MR. SUTHERLAND: Okay . Just move along. 20

MR. BROOKMAN: Ed? 21

MR. OSANN: I just wanted to add one 22

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

24127

current table and the, the, the method for 1

fashioning the average load size and the minimum 2

loa d size has the potential for bias towards, 3

towards larger machines, I would just point out 4

that this phenomenon will be, will be even more 5

significant as the table is expanded to accommodate 6

even larger machines with, within the scope of the 7

test procedure. 8

MR. BROOKMAN: Steve Witkowski. 9

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

number of concerns here about the methodology that 11

was used, and perhaps that we make our 12

calculations and possibility for, you know, future 13

compliance issues. 14

It would really help, if you disagree 15

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

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

the calculations, what weighting factors, if any, 18

should be used, that, besides just general 19

concerns, if you have alternative methods of 20

performing these calculations, please make us aware 21

of them, because we definitely will look at them 22

and we'll take them into consideration. 23

24128

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

we understand the concern." If you give us 2

something that is substantive, you know, that 3

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

MR. BROOKMAN: Thank you. 5

Yes, Mike, from NIST. 6

MR. GALLER: Hi. Mike Galler. 7

I want to comment on the number of 8

cycles per year per volume of the clothes 9

container. It seems like the machines you push 10

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

representative, and it seems like this would be 12

something that would be good to see more consumer 13

usage on to see if there was actually a difference 14

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

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

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

can you say? 18

MR. GALLER: We're guessing that people 19

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

bigger machines. 21

MR. BROOKMAN: Okay. Thank you. 22

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

24129

could be

-- I say it deserves another look, and 1

that if anybody else has any other consumer use 2

data, that would be good to submit it. 3

MR. BROOKMAN: Okay. Thanks. 4

Okay. 5

MR. SUTHERLAND: Okay. So we move on 6

and talk about the load size use factors. 7

These are the factors that specify the 8

fraction of all cycles run with minimum, average, 9

and maximum loads. DOE received comments 10

suggestin g that DOE should validate the use factors 11

from the, from the test procedure. 12

However, DOE is not aware of any recent 13

data that characterizes such load patterns, and so, 14

therefore, DOE is not proposing to update the load 15

size of these factors currently used in the test 16

procedure. 17

And, of course, DOE welcomes input and 18

data on consumer selection of sizes. 19

Temperature use factor: So, as prev

- , 20

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

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

call the TUFs in the clothes washer test procedures 23

24130

to account for steam wash cycles. And DOE also 1

investigated whether the other TUFs in the test 2

procedure are valid. 3

So, RECS, 2005 RECS and the California 4

RAS S both provide some data for "Hot," "Warm," and 5

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

extra

- hot cycles or steam

- wash cycles. The 2005 7

RECS questionnaire on

- , asked respondents only for 8

the water temperature selections that they use, 9

usually use. 10

And, therefore, DOE thinks that that 11

data may not account for cycles that are used less 12

frequently, such as the "Hot" wa sh cycle. The RAS S 13

questionnaire asks for the number of wash loads per 14

week at each temperature, and therefore likely does 15

capture the "Hot" washes. 16

But, that survey only represents 17

consumers in one State. So, the following table 18

summarizes the TUFs as determined from the two 19

surveys and compared to the current test procedure 20

values. 21

Current test procedure values are on the 22

left. RECS is in, in, in the middle, and the RAS S 23

24131

are on the right. So, DOE, DOE bel ieves that the 1

comparison of these TUFs shows that the current 2

values in the J

- 1 test procedure are a reasonable 3

estimate of current consumer use, and therefore is 4

not proposing to amend the existing TUFs for 5

clothes washers that don't have a, a "Steam

- Wash" 6

cycle. 7

And I know we've

-- I thought we had a 8

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

let's ask for comments on that. 10

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

one that's after this. 12

MR. BROOKMAN: Yes. Charlie Stephens. 13

MR. STEPHENS: Charlie Ste ph ens. 14

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

my sense of the most recent California data would 16

support the current test procedure TUFs that you 're 17

using, so

-- 18

MR. BROOKMAN: Thank you. Okay. 19

Other comments on these temperature

- use 20

factors? 21

MR. SUTHERLAND: We're going to talk 22

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

24132

the next few slides. 1

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

MR. SUTHERLAND: Okay. So, for the 3

temperature use factor for the warm rinse. 4

So, DOE notes that it recently received 5

consumer usage survey from a sin gle manufacturer 6

for a clothes washer model that does not offer the 7

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

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

washer indicated that users used the cycle roughly 10

1.6 percent of the time, a nd that that would 11

correspond to, to .016

. 12

But, DOE does, does not believe that 13

this conclusion necessarily applies to all 14

consumers and all types of residential clothes 15

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

the warm rinse temperature use factor at this time. 17

However, DOE does remain open to a 18

consideration of warm rinse, and welcomes any data 19

that can be provided regarding

-- 20

MR. BROOKMAN: Chris. 21

MR. JOHNSON: Chris Johnson, LG 22

Electronics. 23

24133

You know, one of the consumer use of 1

this is the percentage of detergents that's 2

purchased by consumers that you use in cold water. 3

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

percent of the det ergent that was purchased in the 5

U.S. was cold, cold

- water detergent, then that 6

ought to tell you, you know, that warm rinse is 7

probably a very, very, very low factor, and 8

probably, even though this is another data, it 9

does, nevertheless , represe nt just one manufacturer. 10

But, if you, if you use other, other 11

evidence of laundry purchasing and, and use in, in 12

the U.S. not related directly to the performance of 13

the machine, that would, that would give you some, 14

some indication. 15

MR. BROOKMAN: Okay. Thank you. 16

J.B. Hoyt. 17

MR. HOYT: JB Hoyt, at Whirlpool. 18

Has the Department done any analysis of 19

the machines on the marketplace to understand what 20

the presence is of warm rinse cycles? 21

MR. SUTHERLAND: I don't believe the 22

Department has done any sort of comprehensive 23

24134

survey of that specific feature. No, that, not 1

that I'm aware of. 2

MR. HOYT: The reason I ask is because I 3

would suggest that if you did, the, the data would 4

show that the 27 percent is current, quite out of 5

line with current water practices. And we'll 6

endeavor to provide more detail in our written 7

remarks. 8

MR. RICHARD: Doug? 9

MR. BROOKMAN: Yes, Rich. 10

MR. RICHARD: I'd like to add to JB's 11

comments by inviting all manufacturers to provide 12

some sort of manufacturers to, to basically confirm 13

that the washing warm rinse cycle is no longer 14

availa ble on 28 percent of these machines, as in 15

the current test procedure. 16

MR. BROOKMAN: Okay. 17

Kelley. 18

M S

. KLINE : Just to reiterate that, 19

we'll also work on providing the data, but our 20

conclusion is really the same, that it's actually 21

very rare. 22

MR. BROOKMAN: Okay. 23

24135

MR. SUTHERLAND: Okay. Okay, thanks. 1

So, I will talk about, now, the warm 2

rinse methodology. So, in the current J

- 1 test 3

procedure, the way the warm rinse is factored in is 4

by applying a temperature use factor of .27 to the 5

incremental energy that's consumed in the "Warm" 6

cycle as compared to the energy used in the 7

"Warm/Cold" cycle. 8

So, the increment al energy only applies 9

to that part of the, the rinse cycle that uses 10

additional energy, hot

- water energy. This is, can, 11

can be problematic for some clothes washers. 12

It's not entirely clear when the wash 13

cycle ends and when the rinse cycle begins, because 14

DOE is aware of some clothes washers that do 15

multiple fill and rinse cycles or events in a 16

single cycle occurring in varying sequences. 17

So, to simplify the warm rinse 18

measurements, DOE's proposing to account for the 19

energy and water consumption over an entire 20

"Warm/Warm" cycle the same way that energy and 21

water consumption would be measured for any of the 22

other temperature combinations. 23

24136

And DOE believes that this is 1

appropriate, because most clothes washers currently 2

available allow users to select a warm rinse within 3

a warm wash. So, on the, on the machines that 4

offer warm rinse, and DOE believes that it's pretty 5

much always paired wi th a warm wash. 6

So, DOE proposes to eliminate the 7

incremental use factor currently attributed to warm 8

rinse, and DOE believes that, assuming the warm 9

rinse would still apply, DOE's proposing to apply 10

that to the entire portion of the "Warm/Warm" 11

cycle. 12

Subsequently, DOE proposes to reduce the 13

"Warm/Cold" temperature use factor from, from .49 14

to .22 to reflect that difference. Clothes washers 15

that don't offer a warm rinse would still use the 16

"Warm/Cold" temperature use factor of .49. 17

DOE believes that this revised 18

methodology for incorporating warm rinse does not 19

change the intent of the test procedure. Overall, 20

the warm wash and warm rinse temperature sele ctions 21

are receiving the same weight in the final 22

calculations. 23

24137

Another issue regarding warm rinses, DOE 1

recognizes that not all clothes washers offer a 2

warm rinse in the normal cycle that's recommended 3

for cottons and linens. So, if a 4

warm

- wash / warm

- rinse cycle is available in 5

any other wash cycle setting that has agitation, 6

spin speeds and wash times that are largely similar 7

to the normal cycle, then the "Warm/Warm" cycle 8

should be tested using the wash cycle that best 9

reflects typical consumer use. 10

As a result of this, the calculated MEFs 11

for these types of clothes washers could differ 12

under the proposed method compared to the current 13

method in J

- 1 because in J

- 1 the warm wash portion 14

would be conducted under the normal cycle, but 15

according to this proposed definition the warm, if 16

the "Warm/Warm" occurs in a cycle outside of the 17

normal cycle, those parameters may differ, and thus 18

that would affect the MEF calculation. 19

So, DOE expects to analyze the potential 20

effects of this proposed methodology on MEF, and 21

plans to incorporate any such effects that it 22

observed into the amended Standards for IMEF, 23

24138

Integrated Modified Energy Factor. 1

Le t's, let's pause for questions on 2

that, because that's, that's a pretty big topic. 3

MR. BROOKMAN: Yeah, good. 4

Comments on these slides regarding warm 5

rinse methodology? 6

(Whereupon, at 12:12 p.m. ET, no 7

respon se was had.) 8

MR. BROOKMAN: No comments. 9

MR. SUTHERLAND: Okay. So, the clothes 10

dryer usage factor, DOE investigated whether the 11

dryer usage factor of .84 in the J

- 1 test 12

procedures still reflects current usage factors. 13

And dryer usage factor is used to 14

calculate the drying energy consumption. So 2005 15

RECS and 2004 RAS S both include data on clothes 16

washer and clothes dryer use. 17

The data, the data from those is shown 18

here for RECS. It's .95 for households that have 19

both a washer and a dryer, .95 for all households 20

that have a washer. 21

And for RAS S it's .86 for 22

households that have a washer and dryer, and .76 23

24139

for households that just have a wash er. 1

So, DOE, DOE is proposing a dryer usage 2

factor of .91 based on the 2005 RECS data for all 3

households with a clothes washer, and DOE is 4

proposing to use the 2005 RECS data in order to 5

maintain consistency with the data source that was 6

used for the number of annual cycles. 7

For the load adjustment factor, this, 8

the, the load adjustment factor represents the 9

ratio of the typical consumer load size to the 10

maximum

- number test load, maximum, maximum test 11

load size. It's used in the calculation of energy 12

required to remove moisture from the test load. 13

DOE lacks information that would warrant 14

adjusting this volume or changing from the, a fixed 15

value. So, therefore, DOE's not proposing to 16

change the load adjustment factor from the current, 17

currently in the clothes test procedure. 18

So, at this point we'll request comments 19

on the validity of using the proposed temperature 20

use factors. Additionally, DOE seeks comment on 21

proposed revision of warm rinse measurements, and 22

the methodology that goes along with that. 23

24140

And, DOE also welcomes comments 1

regarding the proposed load adjustment factor to be 2

used in the R M C calculation. And, as always, 3

stakeholders may submit any additional relevant 4

data regarding these use factors. 5

MR. BROOKMAN: So, dryer, clothes dryer 6

use factors, load adjustment factor, comments on 7

those? 8

(Whereupon, at 12:14 p.m. ET, no 9

respons e was had.) 10

MR. BROOKMAN: Nothing additional? I'm 11

going to suggest we pause now for lunch. 12

It's 12:15. I think we're pretty much 13

on schedule. 14

We may be even just a tad ahead of 15

schedule. 16

(Whe reupon, at 12:15 p.m. ET, those 17

present took a brief recess and returned at 1:22 18

p.m. ET. Mr. Taylor was not present. The 19

following occurred:) 20

MR. BROOKMAN: Okay, let's resume. 21

MR. WITKOWSKI: Okay. 22

MR. BR OOKMAN: We are going to pick up 23

24141

where we left off, which, I believe, is Slide 74. 1

And Timothy Sutherland is presenting. 2

MR. SUTHERLAND: Thanks. Tim Sutherland 3

with Navigant. 4

So, we left off, we're still talking 5

about the active

- mode test procedure provisions, 6

and so now we're going to talk about provisions 7

related to the test cloth

. 8

MR. BROOKMAN: I see Ed has a comment, 9

and, before you go on, Tim. And I'm just, I'm 10

going to hand out now these. 11

The Department of Energy has created 12

photocopies of the business cards of those that 13

registered today, so let's just pass these out for 14

those in the room. 15

Ed, can you take these and pass them 16

down? Thank you. 17

And, Ed Osann has a question. 18

MR. OSANN: Yeah. Before we moved on, I 19

had a question on the last slide that was up before 20

the break,

-- 21

MR. SUTHERLAND: Sure. 22

MR. OSANN:

-- and that was 72, the load 23

24142

adjustment factors. 1

MR. SUTHERLAND: Um

- hum. 2

MR. OSANN: This is load adjustment 3

factor for the purposes of the RMC computation, I 4

believe. 5

MR. SUTHERLAND: Yes. That's right. 6

MR. OSANN: And we had raised, raised a 7

question about this in the framework comments. And 8

it, it doesn't

-- Seems, though, there's a 9

particular response here to the concerns we raised 10

at the framework stage. 11

It's just not at all clear where, why 12

this load adjustment factor used to scale the 13

calculated energy consump

- , for actual consumer 14

usage is different from the more generally 15

applicable factors applied to usage, minimum, 16

average, an d maximum load size. 17

What

-- It just seems conceptually 18

inconsistent to have two different approaches with 19

two different numeric outcomes for essentially the 20

same task relating to trying to gauge actual 21

consumer usage. 22

M R. SUTHERLAND: So, correct me if I'm 23

24143

wrong, Judy, but the load adjustment factor, it's 1

used in the RMC calculation. And the RMC, you, you 2

run the RMC test with a max test load. 3

However, there's a recognition that most 4

consumers are n't always going to use the max test 5

load. So, the load adjustment factor is a factor 6

that's applied to that to represent a more 7

representative load size than a consumer will 8

likely use. 9

MR. OSANN: But, hasn't DOE, elsewhere 10

in th e test procedure, identified very specific 11

proportions of the maximum, the minimum, and the 12

average load size? 13

MR. SUTHERLAND: Well

-- Oh, Judy, do 14

you have, do you have a comment or response? 15

MS. REICH: Yes. This is Judy Reich. 16

I think there's potential for some 17

confusion because we use the term "average." In 18

the Table 5.1, those are intended to represent the 19

maximum, minimum, and, ” average ” size based on 20

the available space within that machine, the 21

capacity of the machine. 22

But, that's not necessarily how 23

24144

consumers actually use the product. And so the 1

load adjustment factor is to get at the consumer 2

usage for a machine with that pa rticular available 3

capacity. 4

MR. BROOKMAN: Go ahead, Ed. 5

MR. OSANN: But, there is a, there is a 6

frequency that is assigned to average, minimum, and 7

maximum. I believe it's something like 78, 12, and 8

14,

-- 9

MR. SUTHERLAND: Right. 10

MR. OSANN:

-- or roughly those, those 11

proportions. 12

There's a weighting factor for assigning 13

the frequency of use for average, minimum, and 14

maximum loads. 15

MS. REICH: So, is your co mment that you 16

would

-- 17

MR. OSANN: Why, why would, why would 18

this be

-- Why would you have a single, a single 19

adjustment factor here, when you've got simply a 20

different approach to respond to the same issue 21

elsewhere in the test procedure? 22

MS. REICH: Well, in terms of needing a 23

24145

single value

-- that is in order to scale the RMC 1

measurement, which needs to be scaled by one value 2

that could represent or could be developed from the 3

weigh ted values for the minimum / maximum, and 4

average elsewhere. 5

And so I guess maybe my question is, 6

would you, are you advocating that DOE combine 7

those three values used elsewhere to define the 8

LAF? Is that what you're recommending in

-- 9

MR. OSANN: That may be one way to 10

approach it, yeah. It just seems like this is a, a 11

different approach, and not mutually consistent. 12

It's possible that, that you could still 13

come with one number, but it would be based on the 14

distribution of the three values elsewhere. But 15

here it just seems to be completely different, you 16

know, derived from some completely different field 17

study, or something done, you know, 15 or 20 years 18

ago and, and carried forward. 19

And it just seems inconsistent, 20

internally inconsistent. 21

MR. BROOKMAN: But

-- Charlie Stephens. 22

MR. STEPHENS: Charlie Ste ph ens. 23

24146

I'm trying to understand wha t you end up 1

with here after the application of the L AF. Are 2

you simply calculating the, indirectly here the 3

amount of moisture to be removed by the clothes 4

dryer by reducing the size of the load and its, 5

therefore, moisture loading, but at a constant RMC 6

value? 7

MR. SUTHERLAND: The, the

-- Where the 8

load adjustment factor used, is used is in the 9

calculation of determining the energy required to 10

remove the, the moisture from the clot h. And part 11

of that is the factors in the R M C value, which is 12

a, a, a fixed value for that washer. 13

So it's 40 percent or 45 percent or 14

whatever that washer has to be. But, that R M C 15

measurement was made using a max test load. 16

So, in estimating the dryer energy 17

consumption, you, you want to use a more 18

representative test load in doing that. And so 19

that's why this factor is applied to R M C. 20

I'm not sure if that answers your 21

question. 22

MR. STEPHENS: Well, I guess, no, it 23

24147

doesn't. I'm trying to understand what you're 1

scaling. 2

What, what are you, what, what number do 3

you multiply the L AF times? What is it you're 4

multiplying here? 5

MR. SUTHERLAND: It's, it's

-- 6

MS. REICH: If you don't have that, Tim, 7

-- 8

This is Judy. 9

-- I have it. 10

MR. BROOKMAN: Yeah. Into the 11

microphone, Judy. 12

MS. REICH: Okay. It's Judy Reich. 13

Section 4.3. 14

MR. BROOKMAN: And it's in a table in 15

the Federal Register Notice. 16

MS. REICH: It is a section of the 17

Federal Register language in the Federal Regi ster, 18

Volume 75, Page 57593. So, the load adjustment 19

factor's multiplied by the maximum test load 20

weight, and it's multiplied by the difference 21

between the measured RMC and the nominal 22

end

- of

- drying cycle RMC, which is four percent. 23

24148

It is also multiplied by the nominal 1

energy required to remove moisture from a,

-- Let's 2

see.

-- to, from clothes. 3

It's a factor of half a kilowatt hour per 4

pound multiplied by the dryer usage factor. So, 5

it's, by changing the LA F, it scales the per

- cycle 6

energy consumption for removing moisture 7

proportionately with, with the load adjustment. 8

MR. SUTHERLAND: So, if you do

-- If you 9

did not apply this factor, your dryer energy 10

consumption would be a measure o f how much energy 11

was required to remove the water from a maximum 12

test load size. So, by applying this factor, it 13

brings that down to the amount of energy required 14

to remove moisture from a more representative load 15

size. 16

MR. BROOKMAN: Ed. 17

MR. OSANN: Yeah, I just wanted to, for 18

the Record, I just wanted to clarify, because I was 19

going from memory a moment ago. The load usage 20

factors are 12 percent maximum, 74 percent average, 21

and 14 pe rcent minimum. 22

And I can see how for the, in, in 23

24149

Section 4.3 it may be convenient to reduce this to 1

a single number, a single value, the, the LAF, for 2

conversion, but I don't see how an LAF of .52 is 3

consistent with distribution of the load use 4

factors that are used elsewhere. 5

MR. BROOKMAN: Okay. 6

MS. REICH: Um

- hum. 7

MR. BROOKMAN: Okay. Charlie. 8

MR. STEPHENS: Charlie Stephens. 9

And I'll say, yeah, it occurs to me, 10

too, that it doesn't really take into account, 11

unfortunately, the notion that the remaining 12

moisture content is probably different for 13

different load sizes. But, I guess we've elected 14

not to do that. 15

MR. BROOKMAN: Additional comments on, 16

on this slide, that load adjustment factor? Paige, 17

um

- hum. 18

MS. DETRICK: Just to respond to the 19

last comment,

-- This the Paige, from B HS. 20

Arguably the fact that the single factor 21

doesn't perhaps cover, and need to be some careful 22

math to figure out if it will jive with the LAFs or 23

24150

not, but arguably that already is taking into 1

account the difference between R M Cs based o n the 2

different load size that could occur. 3

MR. BROOKMAN: Okay. 4

Yes, Mike. 5

MR. JOHNSON: Mike, with the California 6

utilities. 7

I just wanted to echo that it does seem 8

to us to be an inconsistenc y as well between the 9

LUFs and the LAFs. And, granted, this might not be 10

the especially careful amount that you were 11

reaching to have, but just a quick calculation 12

here. 13

If LAF is a ratio of typical consumer 14

load size to maximum lo ad size, that's a ratio that 15

changes dramatically based on maximum load size in, 16

in the other part of the test procedure. So, for a 17

small, small washer, we're talking about 75, 70 18

percent, and for larger washers, it's, that ratio 19

is closer to 55 , 50 percent. 20

And so in the load

- adjustment

- factor 21

portion of the test procedure, that's a constant 22

value. So,

-- 23

24151

MR. SUTHERLAND: Well, I think, again, 1

there's a difference between the word "average" as 2

it's

-- When you were just doing those 3

calculations, I'm assuming you were doing them 4

based on Table, the table of min., average, and max 5

values. 6

So, that average there is just the, the 7

physical average of the size, which is subtly 8

different than the average for representative 9

consumer load size. So, essentially, the .52 load 10

adjustment factor means that, given a washer of any 11

size, a consumer will tend to fill it 52 percent of 12

the way. 13

That, that's how that can be 14

interpreted. 15

MR. JOHNSON: Agreed. And that's 16

precisely the subtle difference that seems to be an 17

inconsistency. 18

MR. BROOKMAN: Okay. Okay, I think 19

we've covered this now, if you want to go ahead. 20

MS. MAUER: Joanna Mauer. 21

I just want clarification. So, you're 22

suggesting that the average load size values that 23

24152

depend on capacity are not intended to represent 1

consumer usage? 2

MR. SUTHERLAND: They are not based on 3

-- The determination of what those values are is 4

simply just a mathematical determination of what 5

the midpoint of the, of that drum size is, which 6

may not necessarily

-- That average value may not 7

necessarily be THE typical value that a consumer 8

uses. 9

MS. MAUER: Okay. I just

-- A little 10

surprising, because I, test procedures are 11

generally supposed to represent consumer usage, I 12

believe, by the Statute. So,

-- 13

MR. SUTHERLAND: Well, the consumer 14

usage of whe ther they run a small, medium, large, 15

that's taken into account with the load usage 16

factors of 12 percent for, 14 percent for minimum 17

load, 74 percent for average load, and 12 percent 18

for max load. So, that's where the

-- That's how 19

the, the thr ee different load sizes get adjusted to 20

account for actual consumer behavior. 21

MR. BROOKMAN: Charlie. 22

MR. STEPHENS: Charlie Stephens. 23

24153

But, that doesn't carry through to your 1

estimation of remaining moisture; is that what 2

you're saying? 3

MR. SUTHERLAND: Correct. 4

MR. STEPHENS: So, in the calculation of 5

dryer, or, excuse me, clothes washer energy 6

consumption, we do take those weights into acco unt. 7

But, when we actually take for, and the account for 8

the energy used in the dryer, we don't; true? 9

MR. SUTHERLAND: True. True. 10

MR. BROOKMAN: Okay. Final comments? 11

(Whereupon, at 1:38 p.m. ET, no response 12

was had.) 13

MR. BROOKMAN: That was about as

-- That 14

was

-- Let's move on. 15

MR. SUTHERLAND: All right. 16

MR. WITKOWSKI: Don't conclude. Just 17

move on. 18

MR. SUTHERLAND: Okay. So, on to, to 19

the test cloth issues. 20

So, talking about R M C, it's the ratio 21

of, of the weight of water absorbed by the test 22

cloth after an energy test cycle has been completed 23

24154

to the, the, the bone

- dry weight of that cloth. 1

And the characteristics of the cloth can affect the 2

absorbency of the cloth. 3

And test procedure tries to minimize and 4

account for the differences between cloths that 5

come from different lots. AHAM submitted som e 6

comments in response to the framework document that 7

included revised tolerances for the size and weight 8

of the test cloth, and these tightening tolerances 9

DOE believes could improve the consistency in the 10

R M C results from, from lot to lot in th e test 11

cloth. 12

And so DOE believes that the AHAM 13

proposal represents the industry's consensus in 14

trying to limit the uncertain t y in the test 15

procedure through the variation in test cloth 16

properties, and therefore DOE is proposing to 17

include these changes in the test procedure. 18

One of the other issues related to test 19

cloth is the, the fact that the, the current test 20

procedure uses extractor tests with G forces up to 21

500 G to determine the correlation curves that are 22

used to correlate each separate lot of test cloths. 23

24155

However, DOE is aware of clothes washers on the 1

market that achieve G forces even higher than 500 2

Gs, and so, therefore, DOE's proposing to in clude 3

an additional set of, of extractor tests at 650 Gs, 4

as well as requiring the 500 G extractions for all 5

clothes washers currently in J

- 1. 6

The 500 G does not necessarily apply to 7

all clothes washers. So, the table shown here 8

sh ows what the proposed standard R M C values would 9

be for the extractor tests as proposed, and that is 10

based on the AHAM

- submitted data. 11

Some additional issues: DOE's also 12

proposing to specify a test cloth handling 13

procedure to ensure c onsistent results from the 14

extractions, extractor testing, proposing to update 15

some of the information about the manufacturer of 16

the extractor, some more specific 17

requirements on the bone

- dry er , specifying that 18

it be able to heat the test cloth to over 210 19

degrees Fahrenheit. 20

And the current J

- 1 test procedure 21

includes some redundant sections regarding test 22

cloth specifications and preconditioning. So, DOE 23

24156

is proposing to remove these re dundant sections in 1

J

- 2, and move any of the relevant nonredundant 2

information from, from those sections into the 3

appropriate sections in J

- 2. 4

So, DOE requests comment and data 5

regarding the proposed updated test cloth 6

specification s and correlation procedure. 7

MR. BROOKMAN: No additional comment. 8

(Whereupon, at 1:41 p.m. ET, no response 9

was had.) 10

MR. SUTHERLAND: All right. Must be. 11

And just some other provisions and 12

clari fications. Capacity measurement is the next 13

sort of big topic. 14

So, the current clothes

- washer test 15

procedure requires measuring the entire volume 16

which a dry clothes load could occupy within the 17

clothes container during washer operation. And in 18

the current procedure this is done by filling the 19

clothes container with water to its uppermost 20

edge, and determining the volume based on the 21

weight of the water. 22

In the current J

- 1 procedure, the term 23

24157

"uppermost edge" is not well

- defined, and it may 1

not always represent the volume which a dry clothes 2

load could truly occupy. DOE, as part of the 3

framework document, received multiple comments that 4

supported revising the definition of the capacity 5

measurement. 6

One of the things DOE considered were 7

other measurement records, such as the I E C 60456 8

method. But, DOE believes that, that some of these 9

methods would create unnecessa ry test burdens for 10

manufacturers. 11

So, DOE conducted capacity tests on a 12

small sample of washers and found that some of the 13

rated capacities

-- a nd by "rated" I mean the values 14

that would be reported in either the ENERGY STAR 15

databa se or the C E C database. 16

Some of those values varied from DOE's 17

test measurements by as much as 0.5 cubic feet. 18

And so what this suggests is just that the ratings, 19

the capacity ratings are being based upon multiple 20

interpretations of w hat's defined as the uppermost 21

edge of the clothes container. 22

And DOE is striving to provide an 23

24158

A ccurate

, representative

, and repeatable definition 1

of the uppermost edge of the clothes container that 2

can be applied uniformly. So, th e current 3

definition of the clothes container is the 4

compartment within the clothes washer that holds 5

the clothes during the operation of the machine. 6

DOE believes that this should include, 7

that this part of the definition should include the 8

requirement that the clothing remain within the 9

clothes container throughout the entire operating 10

cycle, and additionally, that the clothes washer 11

should maintain basic functionality. 12

Dry clothing, for example, could fit 13

into certain fill volumes, but that may lead to 14

poor wash performance and poor machine operation 15

during a cycle. 16

So, for top, for vertical

- axis or 17

top

- loading clothes washers, DO

- , DO E believes that 18

the top of the rotating portion of the clothes 19

container should be the highest horizontal plane 20

that a clothes load could occupy. And we have some 21

pictures on the next slide to clarify what we mean 22

here. 23

24159

For top

- lo aders, this would include a 1

balance ring as part of the clothes container, so 2

it would be, if the clothes container has a balance 3

ring, essentially the top of the balance ring. 4

DOE believes that clothes, it, while 5

it's true that cloth es could be loaded in the space 6

above the tub cover, this volume should be excluded 7

because these clothes would likely wash poorly. 8

And for front loaders, DOE believes that 9

when the door seal that is in, the, the seal that 10

is in contact with the door during operation 11

determines the highest horizontal plane that a 12

clothes load can occupy. 13

And, remember. For front loaders it's 14

tilted on its back horizontally to make, to make 15

that measurement. 16

Also, just to note, DOE did consider 17

specifying the, the inner surface of the door as 18

the uppermost edge, but determined that this method 19

was not repeatable. And, of course, for both 20

vertical

- and horizontal

- axis washers, any volume 21

within the clothes container that a clothing load 22

cannot occupy during operation would be excluded. 23

24160

So, for example, for front loaders, if 1

the door protrudes into that space, which it does 2

on most models, that, that volume should be 3

exclude d from the capacity measurement. 4

And so here's a diagram that illustrates 5

what DOE means by the top of the rotating portion 6

of the clothes container. You can see the proposed 7

fill level would be the top edge of the balance 8

ring. 9

DOE notes that this proposed fill level 10

differs from the guidance that is currently posted 11

on the clothes washer test procedure, clothes 12

washer rulemaking web site. The current guidance 13

that is posted there applies to the J

- 1 test 14

procedure and refers to a, a different point. 15

So, this is

-- What's being proposed for 16

J

- 2 is a new fill level, as shown here. Similarly, 17

here are some diagrams showing horizontal

- ax i s as 18

well as a top

- loading horizontal

- axis clothes 19

washer. 20

This diagram shows what the correct fill 21

volumes should be as proposed. 22

So, DOE welcomes comment on whether the 23

24161

proposed method for measuring capacity will provide 1

for a representative measurement of volume that a, 2

dry clothes could occupy within the clothes 3

container during operation, and on whether any 4

other valid measurement method is available. 5

MR. BROOKMAN: Ed Osann. 6

MR. OSANN: Question regarding the 7

points made on 80

- , Slide Number 82 and 84 relating 8

to horizontal

- axis machines. There's a (sic) 9

explanatory bullet that says DOE also considered 10

the inner surface

-- 11

MR. SUTHERLAND: That's right. 12

MR. OSANN:

-- of the closed door. 13

This is on Slide 82. 14

MR. SUTHERLAND: Um

- hum. Yes. 15

MR. OSANN: DOE also considered the 16

inner surface of the closed door as the uppermost 17

edge, but determined this method was not 18

repeatable. And then when you look at the graph ic 19

on 84, Slide 84, the door shape is taken into 20

account in terms of, of the proposed fill volume. 21

How do those two things fit together? 22

MR. SUTHERLAND: Sure. 23

24162

MR. OSANN: What was it that was not 1

repeatable about using the inner surface of the 2

closed door in this context of 82, but it works for 3

Slide 84? 4

MR. SUTHERLAND: Well, so, just to 5

clarify, the, the, the thing that was considered, 6

the inner surface of the, of the door would be 7

this, this lower level here. If that was to be 8

considered the top of the clothes container, you 9

would fill, you would fill water up and essentially 10

keep, keep closing the door until you filled the 11

water up to a point where the water just hits the 12

level of that door. 13

What DOE found was that there's 14

adjustment that has to be made, and it's not a 15

completely consistent, repeatable method because 16

you have to fill it up, close it, s ee if it's 17

touching. If it's not, fill it up more, close it, 18

see if it's touching. 19

And because the shape of the door is not 20

as pictured,

-- It's usually not a straight, 21

completely flat surface.

-- there is just, it can 22

differ from person to person in how they interpret, 23

24163

"Okay, are we at the point where we should stop ?" 1

(Whereupon, at 1:51 p.m. ET, Mr. Johnson 2

entered the room, after which the following 3

occurred:) 4

MR. SUTHERLAND: So, that's what we mean 5

when we say that the results were not repeatable. 6

When you fill the fill volume up to the proposed 7

level, which extends all the way up to the part 8

where the door and the seal meet, you allev

- , you 9

eliminate any guessing of what happens to be 10

done down at this level at the base of the door. 11

So, you essentially just fill it up to 12

the top, close the door, and, and any water that 13

would be removed as, as you close that door gets 14

excluded. But, what you have in there is your 15

volume , and this ends up being a much more 16

consistent, repeatable result than using the first 17

method. 18

MR. OSANN: So, do tub capacity and fill 19

volume, are those separately designated i n the test 20

procedure? Do they serve two different functions? 21

MR. SUTHERLAND: The

-- That refers to 22

the same. They were

-- It's referring to the same 23

24164

thing. 1

The, the fill, the fill volume here is 2

the tub capacity; is what, is what you measure as 3

the tub capacity. 4

MR. BROOKMAN: Judy Reich. 5

MS. REICH: Also wanted to point out 6

there is a small but important difference between 7

the measurements made the two different wa y s. In 8

the first case, when you fill only to the inner 9

surface of the door, you're excluding that small, 10

annular gap around the projection of the door. 11

And that's an area that, during 12

opera tion, clothes can occupy. So, the method 13

that's being proposed takes that additional volume 14

into account that wouldn't be included if you only 15

filled to the, the first point where the water 16

touches the, the dry surface. 17

MR. OSANN: J ust to follow up, then, for 18

purposes of measuring the, the capacity of an 19

H

- axis machine, will it be the level of the door 20

seal in contact with the door, with the door open, 21

or with the door

-- Do you have to have the door 22

closed and the tub fill ed to get the actual 23

24165

capacity? 1

MR. SUTHERLAND: Through testing in the 2

lab you would have to have the door closed. 3

MR. OSANN: And is that clear from the 4

test procedure spec? 5

MR. SUTHERLAND: Well, the test 6

procedure states that any shape or any part that 7

would occupy volume that clothes could not occupy 8

must be excluded from the measure. 9

MR. OSANN: Oh, okay. 10

MR. SUTHERLAND: So, unless in your lab 11

you had a way of filling it up all the way and, and 12

somehow analytically subtracting out the, the 13

volume of the door or something from a practical 14

standpoint in the lab, you would, you would close 15

the door. 16

MR. OSANN: And, and fill it. 17

MR. SUTHERLAND: Yes. Okay. 18

MR. BROOKMAN: Okay. Keep going. 19

Do you want

-- Yes, Jennifer. 20

MS. CLEARY: Yeah, I think AHAM has some 21

questions about

-- I know you said this was 22

intended to change the draft of the guidance for 23

24166

capacity on clothes washers that relates to J

- 1. 1

What about, is it intended

-- I mean, that guidance 2

is now final? 3

MR. SUTHERLAND: Yeah. So, yes, that, 4

that guidance has now been finalized. 5

MS. CLEARY: And how does that relate to 6

the final, or how is it intended for to the final. 7

MR. SUTHERLAND: So, the, the final 8

guidance that's on the web site is guidance that 9

applies to the J

- 1 test procedure. And for t op 10

loaders, the level that is the correct level is 11

the, the innermost radius of the top stationary tub 12

cover. 13

So, this note was just to differentiate 14

the fact that this new proposed fill level, which 15

is the top of the balance ring, which is lower than 16

what we're using for J

- 1. That was supposed to 17

emphasize that point. 18

MS. CLEARY: Okay. I can

-- You know, 19

I'll be checking with my members to comment about 20

that, but I think we do have some questions about 21

whether this is more clear than that guidance. 22

You know, it does

-- You know, I know 23

24167

that your goal is to get an accurate representative 1

repeatable definition that much's ours as well. 2

We thought that the guidance was cle ar 3

and has been providing good results, and so we're a 4

little uncertain as to why so much work went into 5

that. And then the language came out, and now the 6

language seems to be less clear. 7

So, we'll propose way that's, we think 8

shou ld fix that look and the differences. 9

MR. BROOKMAN: All right. Good. 10

Good. I saw both JB and Kelley. 11

MR. HOYT: Just to further Jen's 12

comment, I mean, you fully changed the guidance 13

that we spent all spring and summer working out 14

what's clear and understandable. What's the reason 15

for that change? 16

MR. SUTHERLAND: I mean, in general the 17

reason for the change is to provide a result that 18

is more consistent, more repeatable, and will 19

prov ide the same accurate measurement, irrespective 20

of which lab is conducting the measurement or which 21

manufacturer is conducting the measurement. 22

MR. HOYT: So, you're saying that the 23

24168

guidance that was just issued three months ago does 1

not do that? 2

MR. SUTHERLAND: The guidance that was 3

issued three months ago is consistent with some of 4

the other language in the J

- 1 test procedure. So, 5

the, the, the language in the J

- 1 test procedure, 6

it, today's proposed fill level would not be 7

consistent with some of the language in the J

- 1 8

test procedure. 9

So, this

-- DOE believes that the, 10

today's proposed measurement represents the most 11

accurate, most repeatable, most easily defined 12

point at which to make the measurement. 13

MS. REICH: This is Judith Reich. 14

I

-- You know, we certainly recognize 15

and appreciate all the work that went into 16

developing the guidance. And the purpose was that 17

the J

- 1 provisions for capacity were not very 18

specific. 19

They

-- Those provisions weren't 20

necessarily, at this point, what DOE would think is 21

the best approach. But, within the context of the 22

language that was already within J

- 1, how to 23

24169

narrow, more narrowly define it and have it 1

interpreted on a consistent basis. 2

But, for J

- 2, the possibility was 3

available to consider: Was that, in fact, really 4

the best way altogether to be measuring capacity? 5

MR. BROOKMAN: Kelley. 6

MS . KLINE: Kelley Kline. 7

Could you help me understand what in J

- 2 8

would be inconsistent with the guidance that was 9

proposed? 10

MR. SUTHERLAND: It's more

-- It's not a 11

matt er of consistency. It's the, that the guidance 12

is different. 13

So, in J

- 2, when you, when you perform a 14

J

- 2 test you would only fill the container up to 15

the top of the balance ring. 16

MR. KLINE: No, I understand. But, I 17

t hought

-- I've

-- I, I might have just 18

misunderstood, but I thought you said that you, 19

that you needed to change from the guidance to this 20

new proposed method because of inconsistencies with 21

what would now be J

- 2. 22

MR. SUTHERLAND: Wel l, I think the 23

24170

language in J

- 1 was sufficiently vague that the, 1

this, the, the, the tub cover fill level was what 2

the group sort of determined

-- 3

(Whereupon, at 2:00 p.m. ET, Mr. 4

Witkowski and Ms . Kline conferred, out of the 5

hearing of others and off the Record, during which 6

the following occurred:) 7

MR. SUTHERLAND:

-- or DOE would 8

determine from all the inputs from everyone who 9

worked on that, that was, that was the way of 10

clarifying the language in J

- 1. 11

MS . KLINE: So, it's not really that 12

there was an inconsistency. It's just that you're 13

changing the definition, right? 14

I mean, it's a changed interpretation. 15

It's not that it's inconsiste nt with some of the 16

other provisions of J

- , of what would then be J

- 2. 17

MR. SUTHERLAND: It's

-- 18

MR. BROOKMAN: Paige? 19

MS. DETRICK: I

-- 20

MR. JOHNSON: It's another 21

interpretation. 22

MS . KLINE: It's not another 23

24171

inconsistency. 1

MS. DETRICK: At this point. 2

MR. JOHNSON: It was vague, but there 3

was a lot of different interpretations of where, in 4

J

- 1 of where the fill level should stop. 5

MR. B ROOKMAN: That was Mike from NIST. 6

Now to Steve Witkowski. 7

MR. WITKOWSKI: Yeah. What we felt was 8

that in J

- 1, you know, we had a lot of problems 9

with vague language. And the purpose of the 10

guidance was to try to fix those problems. 11

However, we now have a new test 12

procedure. We feel that this, these definitions 13

are the most appropriate and the best to give an 14

accurate measurement within this new test 15

procedure. 16

It's not that we're saying that J

- , you 17

know, that the guidance is bad. It's good for the 18

old test procedure. 19

We do not feel that it was the best 20

method to use for this test procedure, the new test 21

procedure. And, of c ourse, we're also asking for 22

your input. 23

24172

We had to fix, you know, something that 1

we felt, and I think everyone here believed was 2

vague. And we did that with the guidance. 3

But, the idea of the new test procedure 4

was to have the best proced

- , the best test 5

procedure we could. We're not tying it to the old 6

one. 7

MR. BROOKMAN: Chris. 8

MR. JOHNSON: Chris Johnson, LG. 9

Our, our, I guess our interpretation and 10

our unders tanding of the final draft, final 11

interpretation was that that was the interpretation 12

of the test method for determining where the 13

clothes, the clothes container capacity. And so 14

that, that interpretation was used as, to clarify 15

what was not, wh at volume was, was supposed to be 16

excluded and what volume was supposed to be 17

included, based on the fact of where clothes could 18

fill in the container. 19

So, that doesn't change. Only, only the 20

fill level changes on this, right? 21

I mean, you're not saying that now 22

clothes previously under the old guidance could go 23

24173

up to here, but now they can really go up to here 1

(demonstrating). Is that what we're saying? 2

Or, is it just really a matter of the 3

fill level for the test? That's, that's, that's 4

sort of it, what I'm seeing here, which, which sort 5

of negates the, the logic of clothes levels can 6

only be, I mean, the fill level for clothes can 7

only be what it is, given the same container. 8

And I think I'm more confused now than I 9

was before. 10

MR. BROOKMAN: Any other comments on 11

this? 12

Ed, let's

-- I want to hear from other 13

manufacturers first. 14

J.B. 15

MR. HOYT: J.B. Hoyt, Wh irlpool, again. 16

I've failed, in reading, or in this 17

discussion, to understand how this improves the 18

outcome from the outcome that's been heavily 19

reworked

-- And it's, it's, it's a fundamental 20

shift with the design period.

-- to be ju stified 21

at this time. 22

So, I remain mystified and would love to 23

24174

have a clarification at some point if that does 1

exist. 2

MR. BROOKMAN: Uh

- huh. 3

Jennifer, I was going to attempt

-- Go 4

ahead, Jennifer. Go ahead. 5

MS. CLEARY: Okay. Jennifer Cleary. 6

You know, AHAM agrees. This is not 7

clear. 8

And certainly the figures here may help 9

to give us an understanding of what, the words 10

we're tryin g to say, so we'll comment on, on the 11

words and these figures, regardless of what the, 12

the outcome is for the Final Rule. We would 13

certainly request that figures be included. 14

They were greatly helpful in the 15

guidance, and to, to clar ify, clarify any, you 16

know, interpretations. 17

(Whereupon, at 2:04 p.m. ET, Mr. Johnson 18

and Mr. Kau conferred, out of the hearing of others 19

and off the Record, during which the following 20

occurred:) 21

MS. CLEARY: And I think they would be 22

very helpful for the future as well. So, you know, 23

24175

we'll comment, again, on, on the actual content of 1

the proposal, but regardless, figures should be 2

included. 3

MR. BROOKMAN: Okay, Ed. 4

MR. OSANN: Ed Osa nn. 5

We would, we would, we would support 6

that recommendation that the Final Rule include the 7

graphics. It appears that the, that the difference 8

actually is pretty clear with, at least with regard 9

to vertical

- axis machines. 10

This proposal seems to limit capacity to 11

-- And I think it says explicitly.

-- the, the

-- 12

A SPECTATOR: The balance ring. 13

MR. OSANN: Yeah.

-- the balance ring. 14

And the previous revised guidance that 15

people are referring to would seem to allow for 16

capacity above that level, some sort of very flat 17

cylinder that would represent some additional 18

volume above that. And it appears that the 19

rationale is that not only because of the 20

replicabi lity, but at some point loading beyond 21

that would lead to poor wash performance. 22

MR. BROOKMAN: We're spending a lot of 23

24176

time on this. Let me see if I've got this. 1

For the horizontal

- axis, if you look 2

at Slide 84, those doors are either slightly convex 3

or slightly concave, right? So, if you're going to 4

be doing the test based on the actual touch of the 5

door into the water, then you could see whether it 6

was just barely touching, or going up al ong that 7

convex or concave line; that there could be quite a 8

bit of potential for error there. 9

And that's what they're trying to 10

correct here, is that not? Isn't that

-- 11

Restating, isn't that it? 12

A PANELIST: Well, it wouldn't otherwise 13

make

-- 14

MR. SUTHERLAND: Well, that was the 15

front loader. But I think there's a whole separate 16

set of issues for the top loader. 17

MR. WITKOWSKI: Yeah, those are two 18

different issues. 19

MR. BROOKMAN: I know that. I'm hoping 20

that we can summarize this, any additional 21

comments. 22

Charlie. 23

24177

MR. STEPHENS: Yeah, Charlie Stephens. 1

I think our interpretation of the o ld 2

definitions in J

- 1 were that it was very 3

unfortunate language, and the guidance was, was 4

desperately needed to deal with what we call 5

"unfortunate language." 6

We're kind of enthusiastic about the 7

possibility of getting rid of the unfortunate 8

language and going with something better if we can 9

that needs more guidance. And if that's what we 10

end up with here, we're all in favor. 11

MR. BROOKMAN: Chris. 12

MR. JOHNSON: Chris Johnson, LG. 13

Aft er looking at the vertical diagram 14

for vertical axis I'd like to propose a change if 15

we could. On graphic, on the third picture, 16

indicate that that's the balance ring. 17

And also under the explanation, it would 18

be more clear if you said the guidance sets the top 19

cover as the maximum fill, whereas the new guidance 20

sets the balance ring as the maximum fill. And 21

whether it's the top or middle or

-- Is that 22

correct? 23

24178

This is the balance ring, whereas the 1

other was tub cover. Is that correct? 2

MR. SUTHERLAND: That's correct. 3

MR. JOHNSON: Okay. If that could be 4

clarified in this diagram and this was in the Rule, 5

that would be great. 6

MR. SUTHERLAND: Okay. 7

MR. BROOKMAN: Okay. That's good. 8

That's specific. 9

J.B. 10

MR. HOYT: If I may raise a question on 11

the front loaders, let the top

- loader issue go. 12

What I'm

-- It 's been a while since I 13

read this. I didn't hear any mention of, of 14

shipping bolts in place to maintain the basket in a 15

use position. 16

Is that included in the actual language? 17

MR. SUTHERLAND: I

-- 18

MR. HOYT: Because that's, that's, 19

that's been a point of contention in the 20

front

- load,

-- 21

MR. SUTHERLAND: Yes. 22

MR. HOYT:

-- which, again, the guidance 23

24179

clarified. And I don't believe I've seen it here. 1

Maybe I'm missing it. 2

MR. SUTHERLAND: Yes. 3

MR. BROOKMAN: While they're

-- J.B., 4

while they're looking, repeat the question. I

-- 5

MR. HOYT: J.B., of Whirlpool. 6

The question: Does the new J

- 2 language 7

include explan ation of shipping bolts being in 8

place to prevent sagging of the basket when, when 9

the machine is tipped on its back? 10

MR. BROOKMAN: Thank you. 11

Paige. 12

MS. DETRICK: This the Paige, from BSH. 13

Just to repeat, t ransportation fixation, we can get 14

in all kinds of other arguments about which ones 15

count as far as bolts. 16

MR. SUTHERLAND: Okay. So, I believe 17

the answer to the question is, "No." The

-- As, as 18

proposed in the NOPR, the J

- 2 languag e does not 19

include mention of, of the shipping bolts. 20

(Whereupon, at 2:09 p.m. ET, Ms. Detrick 21

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

others and off the Record, after which the 23

24180

following occurred:) 1

MR. HOYT: We would specifically urge 2

that that oversight be looked at and remedied, 3

because it will create a problem as we had 4

previously. 5

MR. BROOKMAN: They need to be included. 6

Is that your point, J.B.? 7

MR. HOYT: Yes, sir. 8

MR. BROOKMAN: Thank you. 9

Okay. So, are we ready to move on now? 10

(Whereupon, at 2:09 p.m. ET, no response 11

was had.) 12

MR. BROOKMAN: Yes, I think so. 13

(Whereupon, at 2:09 p.m. ET, Mr. 14

Witkowski and a technician conferred, out of the 15

hearing of others and off the Record, during which 16

the following occurred:) 17

MR. SUTHERLAND: To talk about the new 18

measure of water consumption for the J

- 2 procedure, 19

in the J

- 1 procedu re the calculation of water 20

factor was derived only from the water that was 21

consumed during the “C old / Cold" cycle. Water that 22

was consumed during all the other cycles was not 23

24181

factored into that. 1

And DOE felt that this presents an 2

opportunity to bias the test procedure results by 3

setting the "Cold/Cold" water consum ption very low, 4

but using more water during the higher

- temperature 5

wash cycles. 6

So, to produce more representative 7

values of water consumption, DOE is proposing a new 8

integrated water consumption factor, or IWF. And 9

this would include water consumption from all the 10

energy test cycles, including the "Self

- Clean" 11

cycle within the calculation of I

- , IWF. 12

And so the total weighted per

- cycle 13

water consumption would include the total water 14

consumption for each active

- mode energy test cycle, 15

multiplied by the temperature use factor and load 16

usage factor. And it would also add in the 17

"S elf

- Clean," "Self

- Clean" cycle water consumption 18

multiplied by 12, divided by 295. 19

And this then produces an IWF that 20

equals the total weighted per

- cycle water consum ption 21

divided by the clothes container volume. DOE 22

believes that th is proposed IWF metric will not 23

24182

substantially increase manufacturers' test burden 1

because, in practice, manufacturers likely record 2

the data on cold

- water consumption for all the 3

different wash levels even though it's not required 4

by the current J

- 1 test procedure. 5

So, we'll take comment on that. DOE 6

welcomes comment on the proposal to establish a new 7

integrated measure of water consumption, integrated 8

water consumption water factor expressed in gallons 9

per cubic foot. 10

DOE requests comment on the validity of 11

including water consum ption of all test cycles, 12

including "Self

- Clean." 13

And, DOE also requests comment on 14

whether the IWF calculation would result in a 15

significant test burden. 16

MR. BROOKMAN: Ed Osann. 17

MR. OSANN: Ed Osann. 18

Conceptually this makes a lot of, lot of 19

sense and we appreciate DOE's desire to avoid 20

potential bias. Has this, has this been applied? 21

Do you have any results from your own 22

group of test machines that you used for the, for 23

24183

the, for the standards evaluation? Do you know

-- 1

MR. SUTHERLAND: DOE is,

-- 2

MR. OSANN:

-- how this would crosswalk? 3

MR. SUTHERLAND:

-- is currently 4

evaluating that as part of the Standards rulemaking 5

process. 6

MR. OSANN: So, we don't know yet? Is 7

that the answer? 8

MR. SUTHERLAND: So, we

-- Yeah. So, we 9

don't know yet, but we will. But, DOE will soon. 10

MR. OSANN: Okay. 11

MR. BROOKMAN: Additional comments on 12

integrated water consumption factor? Okay. 13

Oh, wait. 14

Paige. 15

MS. DETRICK: Paige, from BSH. 16

Just a question for clarification. 17

Starts out talking about hot

- water consumption 18

being measured but not used in water factor, but 19

then the proposal seems to be including cold water 20

from all different cycles. 21

So, I'm lost whether we're also putting 22

the water from hot water in here. Maybe it's clear 23

24184

in the equation, but in the text it's not clear to 1

me exactly what all is included. 2

MR. BROOKMAN: Judy Reich. 3

MS. REICH: To the

-- Paige,

-- 4

Judith Reich. 5

Well, it's

-- Let's see. Starting at

-- 6

MS. KOHL : It starts right here. 7

MS. REICH: Five

- seven

- five

- nine

- two of 8

the Federal Register doc ument. There are a series 9

of sections that are calculating total 10

weighted

- per

- cycle water consumption for various 11

energy test cycles. 12

And those, then, are summed in Section 13

4.2.16, which is the integrated water consumption 14

number. There,

-- 15

MR. SUTHERLAND: And

-- 16

MS. REICH: There are

-- I'm sorry. 17

There are two contributors. 18

There's a total weighted

- per

- cycle water 19

consumption for all wash cycles, and then a 20

per

- cycle self

- cleaning water consumption. And 21

within the total

- weighted

- per

- cycle water 22

consumption for all washing cycles would be the 23

24185

individual energy test cycl e contributions. 1

MR. SUTHERLAND: Yeah. And it's both 2

hot and cold water that go into that. And, yeah. 3

MR. BROOKMAN: Paige? Okay? 4

MS. DETRICK: Yeah. Looking at that 5

seems to be all from each, hot and cold from each. 6

MR. BROOKMAN: Okay. 7

MR. SUTH ERLAND: And then, just to 8

reiterate, it would be Section 4.2.14 where the 9

multiplying by 12 and dividing by, dividing by 295 10

would be added. 11

MR. BROOKMAN: We're moving on to energy 12

test cycle. 13

MR. SUTHERLAND: Energy t est cycles, 14

currently defined

-- I don't think I'm going to 15

read the whole screen, but it's currently defined 16

in the J

- 1 test procedure. There's a Part A, which 17

refers to the, the normal cycles, cycles 18

recommended for cotton, and then there's a Part B 19

which refers to a set of wash/rinse temperatures that are 20

cycles that are available on the model but not 21

available on the normal cycle. 22

And any cycles under A, A or B should be 23

24186

applied to the, the energy test cycle. So, DOE 1

believes that some manufacturers may use only Part 2

A of this definition to determine the energy test 3

cycle and the corresponding temperature and fill 4

levels to be tested. 5

Now, as I mentioned, many machines 6

provide a normal cycle setting when, which, which 7

applies to Part A. Over

-- Many normal cycles 8

limit wash and rinse temperature selection. 9

So, for example, if you want an 10

extra

- hot cycle, you might have to switch out of 11

"Normal" a nd switch to some other cycle to get that 12

temperature selection. Certain manufacturers may 13

only test the temperature settings available in the 14

"Normal" cycle, despite being able to access these 15

other wash temperatures by switching out of the 16

"No rmal" cycle. 17

And DOE feels that by doing so, this 18

neglects the Part B of the "energy test cycle" 19

definition. So, DOE, in proposing the "energy test 20

cycle" definition for J

- 2, notes that the 21

requirement to test different cycle setting s, if 22

such testing contributes to an accurate 23

24187

representation of energy consumption, this has led 1

to some confusion, and therefore is proposing to 2

clarify Part B. 3

And the clarifying part of Part B is 4

that if the cycle described in A , so, in other 5

words, if the "Normal" cycle does not include all 6

the wash/rinse temperature settings available in 7

the washer, then the energy test shall also include 8

portions of the cycles offering these machine 9

temperature settings with agitatio n or tumble 10

operation, spin speeds, wash times, and rinse times 11

that are largely comparable to those of the 12

"Normal" cycle. 13

Any cycle under A or B that satisfies 14

this criteria shall include default agitation, 15

tumbling, soil, spin speeds, wash times. So, it's, 16

it's the first part of this definition that DOE's 17

adding to clarify. 18

MR. BROOKMAN: Let, let's just pause and 19

let them read it. 20

MR. SUTHERLAND: Sure. 21

MR. BROOKMAN: Yeah, let's take 30 22

seconds just to read the paragraph. Give everyone 23

24188

a chance to take a peek at it. 1

Okay. Paige. 2

MS. DETRICK: This is Paige from BSH. 3

Two comments. First, I think we need to 4

be very careful. 5

We're change

-- Trading the words in the 6

old Standard will contribute to an accurate 7

orientation so now the words are largely comparable 8

in both cases. These are largely open for 9

interpretation and will cause discuss ion, 10

negotiation, differences in opinion. 11

Second, the, the part of this at the 12

end, "Any cycle under A or B, blah

- blah

- blah, where 13

we have to look at agitation, tumble, agitation, 14

soil level, spin speed, wash times, rinse times, et 15

cetera, we come back to, to two facts about this. 16

One, we get into the same situation as 17

was discussed on Slide 68 with warm rinse where: 18

How do we pick out which piece to add to which 19

cycle to add to which piece of which cycle to 20

a ssemble this mythical cycle? 21

That's an energy case. And the second 22

is: We are making a mythical cycle. 23

24189

This is not a cycle a customer could 1

ever make where they have the choice of longer 2

rinsing, longer heating, the hig hest soil level. 3

Can't be assembled by the customer in most cases. 4

You're taking little pieces of different 5

programs and scrunching them together. And this 6

is, is not going to represent actual consumer use 7

anyway. 8

MR. S UTHERLAND: I think there

-- It 9

sounds like there might be actually confusion as to 10

what the, the intent of this last sentence is. And 11

the, the, the intent of, of that last sentence is, 12

is not to say that, that you need to test every 13

single comb ination like you were saying, the, the 14

high, the high spin, the high soil, the high 15

whatever. 16

The intent of that is to say that if 17

you, if you are choosing a selection under Part B, 18

you should include the default settings for 19

agitation, soil level, spin speed, and wash time 20

and rinse time. So, if

-- So, if you're, if 21

you're, if you're running the extra

- hot cycle and 22

the only way to get that is on the, the "Whites" 23

24190

cycle, you would switch to "Whites," select "Extra 1

Hot," and you would use the default settings for 2

all of these other parameters. 3

So, that's the intent of that last part 4

of, of the definition there. 5

MS. DETRICK: This is Paige again. But, 6

in the earlier part of the Sta ndard it basically 7

says that if I have something that is more 8

energy

- consuming as a little piece of any,

-- Again 9

we come back to comparable RHA, comparable cycle. 10

-- that I have to go run that cycle. 11

So, I could have three or four, l et's 12

say, programs that are, quote, largely comparable 13

now. How do I decide which one gets measured? 14

One might be different spin speed. That 15

makes it different. 16

One might be different agitation time. 17

That makes it diff erent. 18

And so

-- And we could end up with a 19

real mess. And I think you need to take out words 20

like "largely comparable" that are going to get us 21

in trouble. 22

MR. BROOKMAN: Thank you. 23

24191

Additional comments on this, this slide, 1

energy test cycle? 2

(Whereupon, at 2:22 p.m. ET, no response 3

was had.) 4

MR. BROOKMAN: We've got one more 5

document to finish off on 92. 6

MR. SUTHERLAND: Sure. So, DOE notes 7

that it has issued this

-- Says "draft guidance," 8

but the guidance has been finalized. 9

So, it's, should say "final guidance" 10

available on the rulemaking web site which 11

interprets the current for J

- 1. That definition is 12

consistent w ith this draft guidance. 13

Finally, DOE also notes that it's, has 14

received data from manufacturers indicating that 15

cycles may vary from the “C otton /Linen” cycle by means 16

of a lower spin speed, which would thus result in a 17

higher R M C, and therefore would not be largely 18

comparable to the "Cotton" or "Linen" cycle. 19

And I think, yes, DOE requests comment 20

on the proposed definition of the "energy test 21

cycle." 22

MR. BROOKMAN: Charlie. 23

24192

MR. STEPH ENS: Charlie Stephens. 1

I'm taking from the, this definition, 2

then, that you've excluded by definition all 3

measurement of energy that occurs in the "Delayed 4

Start" or "End of Cycle" mode of operation. 5

MR. SUTHERLAND: Any measurements that 6

would occur for that sort of thing would be covered 7

in the, the "Standby" mode measurements. 8

MR. STEPHENS: Now you've actually 9

excluded them from the "Standby" or "Inactive" 10

mode. They're part of the "Active" mode. 11

MR. BROOKMAN: Judy Reich. 12

MS. REICH: It's not that

-- We have not 13

excluded them. We have separate provisions. 14

They are "Active" mode, portions of 15

"Active" mode, but they are measured separately. 16

MR. STEPHENS: So, so, that isn't part 17

of the energy test cycle. 18

MR. WITKOWSKI: If you think

-- 19

MS. REICH: That's correct. 20

MR. SUTHERLAND: That's correct. 21

MR. BROOKMAN: Stephen, do you want

- - 22

MR. WITKOWSKI: No, that's

-- 23

24193

MR. BROOKMAN: Okay. 1

Additional comments on these energy test 2

cycle slides? 3

Yes, Paige. 4

MS. DETRICK: Is Paige, BSH. 5

One small elaboratio n on the bottom of 6

Page 9, but known R M C could change. But, for 7

example, rinse times or cycles could be different. 8

That makes it “ not largely 9

comparable. ” 10

MR. SUTHERLAND: Okay. So, Doug, we 11

have been scheduled for a b reak. 12

So, unless there's any more comments, I 13

don't know if you want to take a quick break, or

-- 14

MR. BROOKMAN: Yeah, let's take a short 15

break. Ten minutes. It's 2:25. 16

(Whereupon, at 2:25 p.m. ET, those 17

present took a brief recess and returned at 2:34 18

p.m. ET, after which the following occurred:) 19

MR. BROOKMAN: Okay, let's, let's 20

resume. Please take your seats. 21

Back to Timothy Sutherland. 22

MR. SUTHERLAND: O kay. Oops. 23

24194

There we go. Okay. 1

So, the next topic we'll discuss will be 2

the detergent specifications for the, the test 3

cloth preconditioning. The current J

- 1 procedure 4

specifies AHAM Standard Detergent 2

- A, which is no 5

longer produced. 6

So, DOE has conducted tests using the 7

current AHAM standard test detergent, which is 8

Formula 3, but found that the current dosage 9

requirements may, may no longer be appropriate for 10

this new formula. So, one of the suppliers of the 11

test materials provides dosing instructions of 27 12

grams plus four grams per pound of test cloth for 13

Formula 3. 14

And this is the same dosage used in the 15

AHAM clothes dryer test standard. So, therefore, 16

DOE is proposi ng to amend the test

- cloth 17

preconditioning procedure with this amount of 18

dosing for the AHAM Formula 3 detergent. 19

MR. BROOKMAN: And we have a comment box 20

on that. So, comments on this proposal? 21

Yes. 22

MS. CLEARY: We support it. AHAM 23

24195

supports

-- 1

MR. BROOKMAN: AHAM supports it. Thank 2

you, Jennifer. 3

Any other comments from anyone else? 4

(Whereupon, at 2:36 p.m. ET, no response 5

was had.) 6

MR. BROOKMAN: Okay. 7

MR. SUTHERLAND: Okay. 8

MR. BROOKMAN: Good. 9

MR. SUTHERLAND: Next we'll talk about 10

the clothes washer that's used for the 11

preconditioning of test cloths. The test procedure 12

req uires that the test cloth be preconditioned in 13

the clothes washer for which a max water level can 14

be set, for which the load can be washed for ten 15

minutes, and for which the wash temperature can be 16

controlled to 135 plus or minus five degrees 17

Fahrenheit. 18

Multiple manufacturers have expressed 19

concern that there are currently few clothes 20

washers commercially available capable of meeting 21

these requirements. In addition, a more stringent 22

Energy Conservation Standard may eliminate such 23

24196

clothes washers from the market entirely. 1

So, DOE is seeking information regarding 2

an alternative specification for the clothes washer 3

to be used for the test

- cloth preconditioning that 4

would allow for the use of more recent models. And 5

we'll pause for the test cloth input. 6

MR. BROOKMAN: Jennifer. 7

MS. CLEARY: Jennifer Cleary. 8

Just, I guess, wondering a little bit if 9

you could expand upon exactly what you might be 10

looking for here, or what the difficulty is. I 11

know you said manufacturers had expressed concern, 12

and, and I'm sure I can talk to them a little bit 13

more to understand their concerns. 14

But, trying to get at, with, what would 15

your end goal here be so that we can help you? 16

MR. SUTHERLAND: Well, I think the 17

primary concern is that the test procedure is very 18

specific that the preconditioning washer must have, 19

must provide these three levels of functionality. 20

And I think the concern is that, one, 21

one of which is due to increasing Standards, but 22

there, there is less, fewer and fewer models 23

24197

available that can do all three of these. 1

(Whereupon, at 2:38 p.m. ET, Ms. Detrick 2

and Mr. Hoyt conferred, out of the hearing of 3

others and off the Record during which the 4

following occurred:) 5

MR. SUTHERLAND: And so what, what do we 6

do when the day comes when there are no, no washers 7

available that can perform these three functions? 8

How should we revise the specifications for the 9

washers that, to be, that needs to be used for the 10

test

- cloth preconditioning ? 11

MR. BROOKMAN: Charlie. 12

MR. STEPHENS: Charlie Stephens. 13

Are the reasons for those conditions 14

being set in the first place totally lost in 15

history, or, or can we understand what they were 16

all about? 17

MR. SUTHERLAND: That is a very g ood 18

question. I fear that they may be lost to history, 19

but that

-- DOE could go back and try and 20

investigate that. 21

MR. BROOKMAN: Where's Bryan when we 22

need him, right? 23

24198

Stephen Witkowski? 1

MR. WITKOWSKI: Yeah. I think we also 2

would be open to discussions concerning those three 3

factors, too. 4

The idea here is to try to come up with 5

a machine that we hope

-- And, again, we're just 6

trying to adapt for future contingencies.

-- that 7

wil l provide a, a, a good test

- cloth wash. 8

(Whereupon, at 2:39 p.m. ET, Mr. Johnson 9

and Mr. Kang conferred, out of the hearing of others 10

and off the Record, during which the following 11

occurred:) 12

MR. WITKOWSKI: So, I don't think it's 13

so much that these three factors, the numbers there 14

are that essential. If there are reasons why you 15

don't think there are, and you have other numbers, 16

let us know. 17

But, the concer n really is that if we 18

follow these three values there may not be a 19

machine available in the future that will meet 20

them. 21

MR. BROOKMAN: Paige. 22

MS. DETRICK: A point of clarification 23

24199

on this one. The maximum water level being able to 1

be set is somewhat of a, again, a general 2

statement. 3

This is certainly

-- For example, I can 4

make my own custom program in

- house to have a 5

machine to do this, but I've set as to what we 6

consider our maximum level. Th ere is no, as far as 7

I've found, no definition of how many liters or 8

gallons is that, and therefore I am uncertain why 9

this is considered obsolete, but can certainly 10

support clarification further. 11

MR. BROOKMAN: Paige, what would you 12

suggest that they do? 13

MR. WITKOWSKI: May I comment here? 14

MR. BROOKMAN: Yes. Stephen, please. 15

MR. WITKOWSKI: I think the fundamental 16

concept here

-- Let's not try to think about the 17

numbers so much.

-- is we feel, DOE feels that we 18

need good washing parameters for test

- cloth 19

preconditioning. 20

So, I don't think it's so much, so 21

important to get, you know, tied up into the, you 22

know, the details here, as to agree ment that, yes, 23

24200

we need good preconditioned test cloth. And what's 1

the best way to wash it so that, that we'll be able 2

to continue to use this method in the future? 3

In other words, I don't want to get

-- I 4

don't think we need to get into a long discussion 5

concerning these particular values and numbers. 6

MS. DETRICK: Um

- hum. Um

- hum. 7

MR. BROOKMAN: Okay. 8

Charlie. 9

MR. STEPHENS: I'm wondering if they 10

weren't trying to sort of induce the maximum 11

shrinkage of the test cloth with the hottest water. 12

I mean, 135, plus or minus five, is from the old 13

days, which is what potentially a water heater 14

would, on many occasions, deliver if you didn't 15

control the temperature of the hot water in the 16

clothes washer. 17

These days, if you're trying to control 18

how hot "hot" is, which you generally do, even if 19

the water heater's delivering that temperature, the 20

clothes washer probably won't. But, the

-- I'm 21

just wondering if I could, if people could 22

understand why, you know, what is, what constitutes 23

24201

a good test

- cloth preconditioning. 1

MR. SUTHERLAND: Someone

-- 2

MR. STEPHENS: Maybe then he'd, they 3

would know how to delive r it. 4

MR. SUTHERLAND: I do know one of the 5

issues is as the test cloth itself is, when it 6

first gets delivered, it may have residue from the 7

factory, or other oils and stuff from the, from the 8

machinery from the mill where it gets sh ipped. So, 9

the preconditioning is, one of the goals of the 10

preconditioning is to get rid of any residue that 11

might be there so that you're just left with pure, 12

fresh cloth that doesn't have any other chemicals 13

on it. 14

MR. BROOKMAN: Other thoughts on this 15

preconditioning? 16

(Whereupon, at 2:43 p.m. ET, no response 17

was had.) 18

MR. SUTHERLAND: All right. Water 19

supply pressure. 20

The test procedure currently states that 21

the static water pressure at the hot and cold inlet 22

connection of the washer shall be maintained at 35 23

24202

psi during the test. DOE believes that this 1

description is ambiguous as to whether the nominal 2

35 psi pressure is to be established under no

- flow 3

conditions and allowed to drop during water flow, 4

or whether it is to be maintained continuously 5

under all flow conditions. 6

And, additionally, there's no 7

specification for where thi s pressure measurement 8

should be taken. DOE has conducted a test on a 9

small sample of front

- loading and top

- loading 10

washers to determine the effects of differing 11

supply tem

- , pressures, and tests were conducted at 12

10, 20, and 35 psi. 13

And DOE found that under, that these 14

difference in pressures resulted in water 15

consumption values that varied by ten to 30 16

percent. Additionally, the test data suggests that 17

a water supply pressure of 20 psi under flow 18

conditions would result in the most consistent 19

results. 20

DOE also believes that 20 psi may 21

represent the typical static pressure under flow 22

conditions that would result from a 35 psi supply 23

24203

pressure at no

- flow conditions, and that, and that 1

this scenario might be more representative of water 2

supply conditions typically found in the 3

residential setting. 4

However, there are other DOE test 5

procedures that more closely specify the 35 psi 6

requirement as applying under flow conditions. For 7

example, the dishwasher test procedure. 8

And, so, therefore, DOE's not proposing 9

to amend the water supply pressure requirements at 10

this time, but seeks more information on this 11

topic. So, do you

-- 12

MR. BROOKMAN: Charli e. Charlie. 13

MR. STEPHENS: Charlie Stephens. 14

We've, we've done some, a lot of 15

investigation on this in the Northwest over the 16

years, and you're really operating at what we 17

consider to be the very bottom of the range of, of 18

pressures that are even allowed by the American 19

Waterworks Association and others for system 20

pressures. 21

I kind of agree. Based on what my 22

understanding is of, of your relationship between 23

24204

flow and static, that seems pretty reasonable, 35 1

and 20. 2

But, those are at the very bottom. I 3

mean, the, the, the City of Portland is a little 4

high, but, you know, we operate under 75 psi static 5

and about 50 psi flow. 6

And that's throttled substantially. 7

But, I'm not suggesting that you go there. 8

But, I think your, the 35 psi flow 9

conditions that you see for the dishwasher is 10

probably also reasonable for the clothes washer 11

flow; not static. 12

MR. BROOKMAN: Flow. Okay. 13

Ed Osann. 14

MR. OSANN: Yeah. Ed Osann. 15

I don't think Portland is, is especially 16

unusual in that, in that respect. I agree that, 17

that, with the prev ious comment that, that 20 psi 18

is really the, the very low end of acceptable range 19

of DOE mes

- , for, for, for public water service. 20

And it, it appears as though DOE has 21

identified a problem here, and, and not proposed to 22

do anything a bout it. With this wide range of, of 23

24205

potential performance based on, on water supply 1

pressure, it would seem that this test procedure 2

should make some, should clearly be adjusted to, to 3

remedy that great deal of uncertainty that, that 4

results f rom this. 5

We are inclined to support 35 psi 6

flowing as the requirement, and we'll make that 7

comment for the Record. 8

MR. BROOKMAN: All right. Do the, do 9

the manufacturers, DOE, AHAM, have any comment at 10

this time? 11

Jennifer. 12

MS. CLEARY: We're still

-- I'm still 13

looking into it with some members, and we'll 14

provide comments in our written comments. 15

MR. BROOKMAN: Okay, then we're moving 16

on. 17

MR. SUTHERLAND: Okay. Getting close. 18

Additional original clarifications. 19

These are

-- Here are some proposed revisions that 20

will not subsequently change the test procedure. 21

One is to incorporate the oil

- repel lancy 22

test and the dimensional change test as materials 23

24206

incorporated by reference. Another is to clarify 1

R M C for clothes washers with options that result in 2

different R M C values. 3

Another is to correct an error in the 4

equation in S ection 1.5.4 for calculating the hot 5

water energy when gas or oil, for gas

- or 6

oil

- heated water. And, finally, remove the current 7

Section 4.5, which provides for the calculation of 8

energy factor. 9

That was a metric used pre

- Conservati on 10

Standards before January first, 2004, and it's no 11

longer used. So, I think that's, there's not a 12

question box there, but in case there's any 13

comments, let's just ask for any. 14

MR. BROOKMAN: Additional revisions and 15

clarification s, 101? 16

(Whereupon, at 2:49 p.m. ET, no response 17

was had.) 18

MR. BROOKMAN: I see none. Okay. 19

Oh, Ed Osann. 20

MR. OSANN: Ed Osann. 21

One of, at least one of these items is, 22

is to correct an error in the equation. That's, 23

24207

that's in the existing Rule, the existing test 1

procedure? 2

MS. REICH: Um

- hum. 3

MR. SUTHERLAND: I believe so; yes. 4

MR. BROOKMAN: The third bulleted item 5

the re, huh? 6

MR. SUTHERLAND: Yes. That's to correct 7

an error that's in the J

- 1 test procedure. 8

MR. OSANN: Okay. I was going to 9

suggest that, because a couple of, of, of errors 10

have been identified in the text of the, of th e 11

proposed Rule, whether, without undue effort on the 12

part of DOE or the consultants, whether it would be 13

possible to post, sometime between now and the end 14

of the comment period, a, simply a corrected 15

Proposal, without getting into the substantive 16

discussion that we've had here today, but where 17

you've identified that the Proposal itself has 18

errors in it, whether you could put up a corrected 19

Proposal that would be available for

-- 20

MR. BROOKMAN: With like highlights or 21

the association

-- 22

MR. SUTHERLAND: Or

-- 23

24208

MR. WITKOWSKI: Or

-- Excuse me. Or

-- 1

MR. BROOKMAN: Stephen Witkowski. 2

MR. WITKOWSKI:

-- would be a listing of 3

the errors, and, and basically where, pointers 4

where in the proposal

-- 5

MR. OSANN: A single errata sheet. 6

MR. WITKOWSKI: Right. Because they 7

would be there and it would tell you exactly where 8

they are. 9

M R. BROOKMAN: Okay. That would be 10

helpful. 11

MR. OSANN: Yeah. 12

MR. BROOKMAN: Joanna Mauer. 13

MS. MAUER: Would you just explain the 14

second bullet point, the clarifications? 15

MR. SUTHERLAND: I mean, if you don't 16

mind, let me just take a look so I can recall what 17

the, what the error is. 18

So, Judy, correct me if I'm mistaken 19

here. I believe the

-- If you look at Section 20

3.8 .4 in J

- 1 as compared to J

- 2, it's the sub

- , 21

sub

- R M C equa ls .75 times the, the R M C from max 22

extraction, plus .25 times the R M C from the min 23

24209

extraction. 1

And it's the sub

- , the subscript text on 2

those R M C values that has been clarified. Yeah, 3

it's the

-- The subscript has been clarified so 4

that it's clear which, which part of the R M C 5

calculation it's referring to. 6

MR. BROOKMAN: Judy, yes. 7

MS. REICH: Yes. It attempts to use 8

nomenclature that's consistent with the, with other 9

subscripts so that it just clarifies what those 10

R M Cs refer to. 11

It doesn't change the calculation at 12

all. It just

-- You can see on, in J

- 2, instead of 13

calling them "min" and "max" extraction, it uses 14

the nomenclature of first descr ibing it as max to, 15

to demonstrate that it, it was maximum test load, 16

and then adds that each one of those is tested as 17

the max extraction and the min extraction. 18

So, it's just making it clear what those 19

values refer to. 20

MR. BROOKMAN: Okay. 21

MR. SUTHERLAND: Okay. So, I think that 22

wraps it up for the

-- Almost. 23

24210

Not quite. Not quite wraps it up for

-- 1

One more section. 2

So, test procedure performance 3

specifications. The cu rrent DOE procedure does not 4

include any provisions for evaluating the wash 5

quality of the clothes washer. 6

And the intent of the test procedure is 7

simply just to determine water and energy 8

consumption, regardless of how good the cloth es 9

washer washes clothes. So, DOE received multiple 10

comments that supported adding performance measures 11

to the test procedure. 12

Multiple commenters stated that the 13

increasing efficiency requirements could start to 14

limit the ability of the clothes washer to clean 15

laundry as expected by consumers. And some of 16

these comments referenced other Standards that do 17

include wash performance, such as there's the AHAM 18

HLW

- 1 Standard. 19

There's IEC 60456. DOE considered these 20

comments, and recognizes the benefits of 21

characterizing washer performance, but is not 22

proposing to incorporate measures of wash 23

24211

performance into the washer test procedure at this 1

time. 2

And this bullet point t hat's listed here 3

describes one of the reasons from a statutory 4

standpoint. EPCA states that test procedures shall 5

be designed to produce test results that measure 6

energy efficiency, energy use, or estimated annual 7

operation costs. 8

And there's no mention there of, of 9

appliance performance. 10

So, now we're at the end. So, let's, 11

let's just ask for comment on this Part 2. 12

MR. BROOKMAN: Paige. 13

MS. DETRICK: Paige, from BHS. 14

BHS strongly supports looking at, and 15

encourages addressing issues of capacity versus 16

volume that is facing both other calculations on 17

what quantity of laundry can successfully be washed 18

rather than the physical size of the drum. 19

MR. BROOKMAN: Thank you. 20

Other comments? 21

MR. SUTHERLAND: Okay. All right. 22

So, now we'll go into the last part of 23

242 12

the discussion here, and hand it back over to Judy 1

Reich. 2

COMPLIANCE WITH OTH ER EPCA REQUIREMENTS, IMPACT OF 3

PROPOSED AMENDMENTS ON ENERGYGUIDE AND ENERGY STAR, 4

AND ELIMINATION OF OBSOLETE CLOTHES WASHER TEST 5

PROCEDURE: 6

MS. REICH: This is Judith Reich. And 7

now that Tim has done all the heavy lifting, I'll 8

be going through the remainder of the presentation, 9

the first being compliance with other EPCA 10

requirements. 11

Specifically, as Tim just noted, there 12

are provisions within EPCA that describe that the 13

test procedures must produce repeata ble 14

measurements reasonably designed to produce results 15

that measure energy efficiency, energy use, or 16

annual operating costs during a represent ive average 17

use cycle or period of use, and shall not be unduly 18

burdensome to conduct. 19

S o, there are really two elements of, to 20

this requirement that were addressed separately in 21

the bullets below, the first being: Is it, in 22

fact, a reasonable and repeatable measure? 23

24213

And DOE believes that for the new 1

provisions for "Standby," "Off" mode, "Delay 2

Start," "Cycle Finish ed ," that because it's, the 3

provisions are based off an, an internationally 4

recognized Standard that measures these modes, this 5

power consumption, that the use of that is 6

recogni zed as a reasonable approach. 7

The second portion about unduly, not be ing 8

unduly burdensome, the proposed test, the test 9

methods and the equipment required to measure these 10

modes DOE does not believe require any major 11

investment, eithe r for the equipment to perform the 12

measurement, or for the facilities in which to do 13

them. 14

In fact, the provisions would allow 15

manufacturers to continue to test in the same 16

facilities that already exist for active

- mode 17

testing. For the amendments relating to the 18

"Active" washing

- mode portion of the test 19

procedure, in terms of the investments that are 20

required, the additions are largely the measurement 21

of several new cycles within the definition of the 22

energy test cycle. 23

24214

So, so, manufacturers would be required 1

to pretty much make the some types of measurement, 2

therefore not requiring any investments or 3

equipment purchases. 4

But, there would, in fact, be, for those 5

machines that have these features, such as "Steam" 6

or "Self

- Clean,"

-- 7

(Whereupon, at 2:59 p.m. ET, Ms. Detrick 8

and Mr. Hoyt conferred, out of the hearing of 9

others and off the Record, during which the 10

following occurred:) 11

MS. REICH:

-- that these, the presence 12

of these cycle settings would result in an overall 13

test duration that is somewhat longer to account 14

for those extra cycles. 15

DOE estimates that, at most, that would 16

be about a 25

- percent inc rease in test duration in 17

additional provision s of EPCA. 18

MR. BROOKMAN: Yes. J.B. has a comment. 19

MR. HOYT: Judy, let's, for a second, 20

take your 25

- percent figure, which we may want to 21

debate, but we won't today. So, you're suggesting 22

that that 25 percent is reasonable, and that 23

24215

manufacturers would have another 25 percent 1

additional capacity without further investment? 2

Is that what I'm understanding? 3

MS. REICH: Well, DOE's initial belief 4

is that we would certainly have additional input. 5

MR. BROOKMAN: Jennifer. 6

MS. CLEARY: I think we would also ask 7

you to compare that increase, which, to an already 8

long test, to the additional energy consumption 9

which is going to be, be measured, which we 10

determined earlier today was d e minim i s. And that's 11

really what we're comparing, is this increase, 12

significant increase in tests. 13

And this is more than just the cost of 14

the facility as depicted in one of these slides, 15

but also time, as J.B. just raised. And we think 16

in a comparison there's a disconnection here. 17

MR. BROOKMAN: Yes, Chris. 18

MR. JOHNSON: Chris Johnson, LG. 19

I'm just wondering either, in EPCA or 20

anywhere else, has there ever been a determination 21

of what constitutes "unduly burdensome to conduct" 22

in terms of testing? Because we can probably come 23

24216

up wit h a long list. 1

But, in all seriousness, is, is

-- I 2

mean, how does that threshold get evaluated when 3

you're doing, especially some things like that are 4

in this test procedure, where the value of even 5

testing it, and the, and the energ y consumption of, 6

of what's being tested is, is minimal at best? 7

So, I'm just wondering, what is, what 8

is, what is "unduly burdensome to conduct"? Does 9

that mean, you know, a large financial increase in 10

testing for manufacturers? 11

Does it mean

-- What, what does it mean? 12

And then that, that, that, that determination, if 13

there is one, or if there has been one, then that 14

plays in exactly to what, what J.B. was talking 15

about in terms of, you know, well, you have to do a 16

little bit more, but it's only 25 percent more, so 17

that's probably not an additional burden. 18

Well, maybe; maybe not. So,

-- 19

MS. REICH: You know, I think the, the 20

rulemaking process is designed for DOE to hear from 21

all interested parties what constitutes "test 22

burden," and, and at what point it does become 23

24217

unduly burdensome. And, you know, at this point 1

it's information

- gathering. 2

DOE evalu ates it. Interpretations of 3

the statutory requirements are, you know, made by 4

General Counsel. 5

So, it's really hearing all inputs 6

possible, and, and evaluating them from there. 7

MR. BROOKMAN: Okay. 8

Ed Osann. 9

MR. OSANN: Ed Osann. 10

Has

-- In getting to this 25

- percent 11

time, 25

- percent increase, you must have some sense 12

of it, the causality of this. Where

-- What is it 13

that's contributing to this, the additional length 14

of tim e for, for testing? 15

Is that in the Record that, where, where 16

we think that, where you think the

-- What's the 17

attribution of the

-- 18

(Whereupon, at 3:08 p.m. ET, Mr. Johnson 19

and Mr. Kau conferred, out of the hearing of othe rs 20

and off the Record, during which the following 21

occurred:) 22

MS. REICH: Well, as noted here, that 23

24218

the largest contributor is the addition of 1

potential new test cycles that would need to be 2

measured. So, in addition to an extra

- hot 3

wash/cold cycle, there would be a "Steam" cycle. 4

If you need to measure a self

- cleaning 5

cycle, that would be added in as well. So, those 6

form the bulk of the additional time required. 7

MR. OSANN: Those, those are, of course, 8

for machines that have that

-- 9

MS. REICH: Exactly. 10

MR. OSANN:

-- feature or functionality, 11

and those recommended by the manufacturers. 12

MS. REICH: Um

- hum. 13

MR. OSANN: And those that don't would 14

not that have that. 15

MS. REICH: That's correct. 16

MR. OSANN: So, this is a

-- Twenty

- five 17

percent is

-- Is this 25 percent for a machine that 18

might have these features, or is this a 25

- percent 19

increase in the total tests time for a 20

manufacturer's typical offering? 21

MS. REICH: That estimate was based on 22

if the machine had all of the requirements, new 23

24219

cycles that needed to be tested. 1

MR. OSANN: So, one particular model 2

with extra features would have

-- 3

MS. REICH: It's an upper limit. 4

MR. OSANN: Okay, it's an upper

-- Thank 5

you. 6

MR. BROOKMAN: Okay, we're going to move 7

on. 8

MS. REICH: Okay. Okay, the EISA 9

amendments to EPCA also require that "Standby" mode 10

and "Off" mode energy consumption is integrated 11

into the overall energy descriptor if it's 12

technically feasible. 13

And so for the reaso ns we already 14

discussed, DOE is proposing to incorporate 15

"Standby" and "Off" mode energy use into the 16

clothes washer per

- cycle metrics in addition to 17

the "Delay Start" and "Cycle Finished" mode 18

contributors. 19

There will

-- As propose d, there would 20

be a new measure of the first cycles of "Delayed 21

Start" and "Cycle Mode" to energy consumption and 22

an integrated modified energy factor metric. 23

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Therefore, DOE believes that that meets the, the 1

requirement of, of that particular se ction, section 2

of EPCA. 3

Okay, EPCA also requires that any test 4

procedure amendments that do incorporate measures 5

of "Standby" and "Off" mode energy use shall not be 6

used to determine compliance with existing energy 7

conservation standards. In this case, DOE is 8

proposing to implement an entirely new test 9

procedure in Appendix J

- 2, and leaving Appendix J

- 1 10

in place, with the clarification that Appendix J

- 2 11

is not going to be required to be used by 12

manufactu rers until the effective date of any new 13

clothes washer Standards. 14

Therefore, quite obviously, it would not 15

affect the ability to determine compliance with, 16

with the existing Standards. One final note on 17

this is that commercial cloth es washers are 18

required, and I believe it's by Statute, to use the 19

residential clothes washer test procedure, which 20

means that it's using Appendix J

- 1 to test them. 21

If J

- 2 were to be applied to commercial 22

clothes washers, it, DOE beli eves that the impacts 23

24221

would be limited, because there are still measures 1

of MEF and WF. 2

However, that

-- Some of the 3

calculations that go into them would be changed in 4

J

- 2, and this includes changes to the test load 5

size, the, the temperature use factor, dryer use 6

factor, test cloth, capacity, and so forth. 7

So, there would be some changes to a 8

measured energy and water efficiency of a 9

particular commercial clothes washer if Appendix 10

J

- 2 is appl ied to, to commercial clothes washers. 11

As noted here, though, the largest 12

contributors would be the capacity measurement and 13

the use factors. So, that is a topic that DOE 14

would welcome input on; how these proposed 15

amendments in Appendix J

- 2 would affect commercial 16

clothes washers. 17

MR. BROOKMAN: No additional comments on 18

the impact on commercial clothes washers? 19

(Whereupon, at 3:08 p.m. ET, no response 20

was had.) 21

MR. BROOKMAN: Okay, I see none, Judy. 22

MS. REICH: Okay. We're looking at 23

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impacts on the EnergyGuide and ENERGY STAR 1

programs. 2

DOE considered how an amended test 3

procedure would affect the EnergyGuide 4

requirements, and sin ce Appendix J

- 2 doesn't 5

include provisions that would change the annual 6

operating cost metric, there, under this proposal 7

there would be no impact at all on the EnergyGuide 8

labeling. 9

ENERGY STAR, on the other hand, is based 10

on MEF a nd water factor. So, if those calculations 11

are changed, as they would be somewhat affected by 12

the proposed amendments, that could impact the 13

determination of whether a model could qualify or 14

not for the ENERGY STAR Program. 15

However, DOE notes that because these, 16

this new Appendix J

- 2 would not be required until a 17

compliance date of any new clothes washer energy 18

conservation Standards, DOE would analyze those 19

impacts on ENERGY STAR a s part of that rulemaking. 20

Any comments on that? 21

And here's a very tricky topic, the 22

elimination of the obsolete Appendix J. Appendix 23

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J, the original test procedure, only applies to 1

clothes washers manufactured before January 1, 2

2004; so, therefore, is obsolete and not necessary. 3

So, Appendix J

- 1 is applicable to all 4

clothes washers currently on the market. DOE is 5

proposing to eliminate Appendix J, and retain 6

Appendix J

- 1 as it's currently labeled, rather th an 7

renaming it "Appendix J," so that if there are any 8

other references to it, that those could remain in 9

place. 10

This is an approach DOE has taken for 11

other test procedures, and therefore is proposing 12

to go just with the J

- 1 and, and new J

- 2. 13

MR. BROOKMAN: Any comments on that? 14

(Whereupon, at 3:11 p.m. ET, no response 15

was had.) 16

MR. BROOKMAN: Okay, I see no additional 17

comments. 18

MS. REICH: No additional comments. 19

Well. 20

MR. BROOKMAN: So, now is an opportunity 21

for anybody that wishes to do so to make final 22

remarks, summary remarks, raise any additional 23

24224

issues that need to be raised at this time. 1

(Whereupon, at 3:11 p.m. ET, no response 2

was had.) 3

MR. BROOKMAN: No additional comments. 4

Okay. 5

Well, thanks to all of you. We covered 6

a lot of ground, I think very efficiently today. 7

I especially appreciate everybody being 8

so forthcoming with th eir thoughts and comments, 9

and I'll turn it back to Stephen Witkowski. 10

MR. WITKOWSKI: Well, again I want to 11

thank all of you for coming today and 12

participating, and I really want to emphasize the, 13

the importance of data and suggestio ns, 14

submissions. If you feel that there are changes to 15

the methodology, methodologies that we've outlined, 16

and please submit those. 17

If you have issues with them, please 18

submit those. Again, data, if you have it, we 19

would love to s ee, to see it. 20

And also, if there are general questions 21

in terms of if you feel that the answers that we 22

gave today, you know, need further clarification, 23

24225

please submit those questions, also. We're open to 1

all input, and we would be, we would look forward 2

to it. 3

And please try to ensure that the, it 4

arrives within the comment period. And other than 5

that, DOE thanks you very much for your attendance. 6

MR. BROOKMAN: Thank you. 7

(Whereupon, at 3:12 p.m. ET, the above 8

Public Meeting was concluded.) 9

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