## SUMMARY OF LAUNDRY RULEMAKING MEETING ON APRIL 27, 1995 ATTENDEES Eugene Margolis DOE/GC Terry Thiele WCI/Frigidaire Howard Geller ACEEE Linda Greiner WCI/Frigidaire Vince Anderson Whirlpool Mike Thompson Whirlpool Christine Ervin DOE Deborah Miller DOE Michael McCabe DOE Marc LaFrance DOE Edward Pollock DOE SUMMARY The visitors were representing the four organizations (the National Resources Defense Council was not present) who submitted ajoint comment to the Department inresponse to the ANOPR (Docket No. EE-RM-94-403) of November 14, 1994. The joint commenters have recommended that the Department adopt a high efficiency standard for clothes washers which would require ahorizontal-axis, high spin, clothes washer design. The joint commenters were concerned about the Department's internal rulemaking schedule. The joint commenters believe that the laundry rulemaking should be the "top" priority. They believe that the potential energy savings and resultant emission reductions are significant. They indicated that their proposal would result in "twice" the energy savings of the consensus proposal made by stakeholders for the refrigerator rulemaking. The joint commenters stated that the Department imposed aminimal standard in1991 for clothes washers to minimize the tooling impact to manufacturers and sent a strong signal to the industry that a stringent standard would be considered inthe subsequent rulemaking. They indicated that approximately 80% of the laundry market (including Maytag who isnot part of the joint commenters) has responded with adecision to develop a high efficiency horizontal-axis clothes washer. The joint commenters indicated that Maytag virtually shared the same beliefs as them, except that they want a delayed effective date for a high efficiency standard requiring ahorizontal-axis design. The joint commenters indicated that General Electric's concerns about a loss inconsumer utility are not valid. Inaddition, they requested that the Department visit manufacturers to inspect proprietary production capability of products that will address consumer utility concerns. The joint commenters also j' 

# .. SUMMARY OF LAUNDRY RULEMAKINGMEETING,'ON APRIL 

### 27,1995 ATTENDEES 

### Eugene Margo1

### is Terry Thiele Howard ,Geller Linda Greiner Vince Anderson Mike Thompson Christine Ervin Deborah Mi 11

### er Michael McCabe Marc LaFrance Edward Po11ock SUMMARY 

### DOE/GC· WCI/Frigidaire ACEEE WCI/Frigidaire Whirlpool Whirlpool DOE DOE DOE DOE DOE
The visitors were representing the four or9anizations (the National Resources Defense Counci 1 

### was not present) who submitted a joint comment to the Department in response to the ANOPR (Docket No. EE-RM-94-403) of November 14, 1994. The joint commentershave recommended that the Department adopt a high efficiency standard for clothes washers which wOllAld require a horizontal-axis, high spin, clothes washer design. The joint commenters were concerned about the Department I 

### s internal rulemaking schedule. The joint commenters believe that the 1 

### aundry rulemaking should be the "top" priority. They believe that the potential energy savings and resultant emission reductions are significant. They indicated that their proposa1 

### would resultin "twice" the energy savings of the consensus proposal made by stakeho1 

### ders for the refrigerator rulemaking. The joint commenters stated that the Department imposed a minimal standard in 1991 for clothes washers to minimize the tooling impact to manufacturers and sent a strong signal to the industry that'a stringent standard would be considered in the subsequent rulemaking. They indicated'that approximately 80% of the laundry market (including Maytag who is not part of thejoint commenters) has responded with a decision to develop a high efficiency horizontal-axis clothes washer. The joint commenters indicated that Maytag virtually shared the same beliefs as them, except that they want a delayed effective date for a high efficiency standard requiring a horizontal-axis design. The joint commenters indicated that General ElectriCiS 

### concerns about a loss in consumer utility are not valid. In addition, they requested that the Department vi sit manufacturers to inspect proprietary production capability of products that wi 11 address consumerutility concerns. The jointcommenters alsobelieve that this would be an opportunity for the Department to validate various manufacturers confidential data submissions. The joint commenters also indicated that they have been lobbying Congress to support the Department's budget for regulatory rulemakings. The Department presented the attached schedules which show a short-term schedule which would include aworkshop to discuss the Department's engineering analysis. The additional schedules show the existing overall laundry rulemaking schedule and apossible revision which would shorten the rulemaking by four months. The Department indicated that the revised schedule would require internal prioritization changes. The joint commenters were not happy with any of the schedules. They believe that the schedules are too lengthy and that apublic workshop will not obtain significant results due to confidentially problems. They want the laundry rulemaking to be completed and celebrated, as amajor accomplishment of "the first term of the Clinton administration." The Department indicated that a, thorough analysis had to be conducted, especially due to the controversy surrounding this rulemaking. The Department also indicated that visits to manufacturers had merit and would be considered. The Department indicated that test procedure revisions are required for the rulemaking and that we were pleased to see an AHAM consensus on the majority of the test procedure issues. The Department also indicated that the short-term schedule shows how all of the near term work on the test procedures would be completed prior to a September 1995 workshop. The Department indicated that this would allow disclosure of test procedure decisions to the public, along with engineering and possiblymanufacturing analyses. The Department also indicated that any further delay inreceiving the AHAM data would impact the rulemaking. The Department requested the joint commenters to attempt to expedite the data collection and submission to the-Department. 

### Conclusion The Department indicated that itwould consider the joint commenters suggestions and any decisions would be available to all stakeholders. 

# ·' I

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### be1 ieve that this wou1d be an opportunity for the Department to validate various manufacturers confidential data submissions. The joint commenters also indicated that they have been.1obbying Congress to support the Department I 

### s budget for reglJ1atory ru1emakings. The Department presented the attached schedu1es which show a short-term schedu1e which wou1d inc1ude a workshop to discuss the Department IS 

### engineering analysis. the additional schedules show the existing overall laundry ru1emaking schedule and a possible revision which would shorten the ru1emaking by four months. The Department indicated that therevised. schedu1e would require / internal prioriiization changes. The joint commenters were not happy with any of the**schedu1es~** 

### They believe that the schedu1es are too 1 engthy and that a pub1 i c workshop wi 11 not obtain significant resultsdue to'confidentially problems. They want the laundry rulemaking to be completed and celebrated, as"a major accomplishment of lithe first term of the C1inton administration. II 

### The Department indicated that a. thorough analysis had to be conducted,· especially due to the controversy surr'ounding th.is ru1emaking. The Department also indicated that visits to manufacturers had·merit and would be considered. The D'epartment indicated that test procedure revis io'ns are required for the ru1emaking and that we were pleased t.o see an AHAM consensus on the majority of the test procedure issues. 

# The Department also indicated that the short-term schedule shows how all of the near term work on the test procedures would be comp1 eted.prior to a September 19.95 workshop. The Department ihdicated that this 'Would a'llow disclosure of test procedure decisions to the public, along with engineering and possiblymanufacturing analyses. ' The Department also indicated that any further delay in receiving the AHAM data would impact the ru1emaking. The Department requested thejoint commenters to attemptto expedite the data collection and submission to the-Department. 

### .Conclusion " The Department indicated that it.wou1d consider thejoint commenters suggestions and any decisions would be available to all stakeholders. .

# LAUNDRY RULEMAKING

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# TEST PROCEDURES IMMEDIATE PLANNED REVISION
- NOPR PUBLISHED 

### PUBLIC HEARING - COMMENT PERIOD/ I 

### FUTURE REVISION (FOR 1999 STANDARDS) AHAM INFORMAL WORKSHOP WITH DOE JOINT COMMENT TO DOE 2 

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# STANDARDS 3 DOE AND LBL DATA/COMMENT REVIEW

_ ENGINEERING ANALYSIS BY LBL

### DOE ANALYSIS REVIEWANALYSIS REVIEW BY STAKEHOLDERS 

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NOTES: 1) PROPOSED TEST PROCEDURE WILL NOT CHANGE ENERGY CONSUMPTION OF CLOTHES WASHERSTO REFLECT CURRENT CONSUMERS'HABITS, THIS 16 A RESULT OFAN INDUSTRY CONSENSUS IN 1993. THE PROPOSED TEST PROCEDURE ADDS PROVISIONS FOR INNOVATIVE CLOTHES WASHER DESIGNS ( IE. HIGH SPIN SPEED, AUTOMATIC FILL CONTROL ETC.) AND MISCELLANEOUS CORRECTIONS/IMPROVEMENTS . 2) AHAM HAS REACHED A CONCENSUS ON A NEW TEST PROCEDURE FOR THE FUTURE STANDARDS EXCEPT FOR A PROVISION TO HANDLE REMAINING MOISTURE CONTENT. AHAM WILL SUBMIT A JOINT COMMENT IN RESPONSE TO THE STANDARDS ANOPR DOCKET AND THE TEST PROCEDURE NOPR DOCKET. THIS TEST PROCEDURE WILL REDUCE THE ENERGY CONSUMPTION BY APPROXIMATELY 30% AND WILL BEUSED FOR THE RULEMAKING ANALYSIS. 3).;THE ADVANCE NOTICE OF PROPOSED RULEMAKING WAS PUBLISHED NOVEMBER 14, 1996, AND THE COMMMENT PERIOD ENDED JANUARY 30, 1995. 4) WORKSHOP AGENDA WILL RELATE PRIMARILY TO THE ANALYSIS FOR THE STANDARDS, ALTHOUGH THE CONTROVERSIAL ISSUE OF HOW TO HANDLE DRYER ENERGY SAVINGS ASA RESULT OF HIGHER SPIN SPEED WILL BE DISCUSSED AS WELL. THE WORKSHOP WILL ADDRESS ISSUES SUCH AS, BASE CASE COST, AVERAGE MANUFACTURER MARK-UP, SEWAGE AND WATER COST, PRODUCT LIFE, HOT WATER HEATER EFFICIENCIES, AND DESIGN OPTION SPECIFIC-CHARACTERISTICS (IE. ENf:RGY EFFICIENCY INCREASE, COST, LIFE CYCLE COST, PAYBACK ETC.). 

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'1 NOTES: 1) PROPOSED TEST PROCEDURE WILL NOT CHANGE ENERGY CONSUMPTION OF CLOTHES WASHERSTO REFLECT CURRENT 'CONSUMERS' HABITS, THIS IS A RESULT OF AN INDUSTRY CONSENSUS IN 1993. THE PROPOSED TEST PROCEDURE ADDS PROVISIONS FOR INNOVATIVE CLOTHES WASHER DESIGNS ( IE. HIGH SPIN SPEED, AUTOMATIC FILL CONTROL ETC.) AND MISCELLANEOUS CORRECTIONS/IMPROVEMENTS. , 2) AH,AM HAS REACHED A CONCENSUS ON A NEW TEST**PROCEDUR~** FOR THE FUTURE STANDARDS EXCEPT FOR A PROVISION TO HANDLE REMAINING MOISTURE <;ONTENT. AHAM WILL SUBMIT A JOINT COMMENT IN RESI'ONSE TO THE STANDARDS ANOPR DOCKET AND THE TEST PROCEDURE NOPR DOCKET. THIS TEST PROCEDURE WILL REDUCE THE ENERGY CONSUMPTION BY APPROXIMATELY 30% AND WILL BE USED FOR THE RULEMAKING ANALYSIS. . . 3).'THE ADVANCE N.OTlCE OF PROPOSED RULEMAKING WAS PUBLISHED NOVEMBER 14, 1995, AND THE COMMMENT PERIOD ENDED JANUARY 30, 1995. 4) WORKSHOP AGENDA WILL RELATE PRIMA!IILY TO THE ANALYSIS. FOR THE STANIIARDS, ALTHciUGH THE CONTROVERSIAL ISSUE OF HOW TO HANDLE DRYER ENERGY SAVINGS AS A RESULT OF HIGHER SPIN SPEED WILL BE DISCUSSED AS Well. THE WORKSHOP WilL ADDRESS ISSUES SUCH AS, BASE CASE COST, AVERAGE MANUFACTURER MARK·UP, SEWAGE AND WATER COST, PRODUCT LIFE, HOT WATER HEATER EFFICIENCIES,.AND DESIGN OPTION**SPECIFIC'CHARACTERISTI~S** (IE: ENJRGY EFF'ICIENCY INCREASE, COST, LIFE CYCLE COST, PAYBACK ETC.).' .**.~** ,t

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