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 a joint comment to the

Department in response 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 a horizontal-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 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 the joint 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 Electric's concerns about a

loss in consumer utility are not valid. In addition, they requested that the

Department visit manufacturers to inspect proprietary production capability of

products that will address consumer utility concerns. The joint commenters also

 EE-RM-94-403 COMMENT 26

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.. 

SUMMARY OF LAUNDRY RULEMAKINGMEETING,'ON APRIL 27,1995 

ATTENDEES 

Eugene Margo 1 is 

Terry Thiele 

Howard ,Gell er 

Linda Grei ner 

Vi nce Anderson 

Mi ke Thompson 

Christine Ervin 

Deborah Mi 11 er 

Michael McCabe 

Marc LaFrance 

Edwa rd Po 11 oc k 

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 submi tted a joi nt 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 

effi ci ency standard for clothes washers whi ch wOllAl d requi re a hori zonta l-axi s, 

hi gh spi n, clothes washer des i gn. 

The joint commenters were concerned about the Department I s internal 

rul emaki ng schedul e. The joi nt commenters bel i eve that the 1 aundry rul emaki ng 

should be the "top" priority. They believe that the potential energy savings and 

resultant emission reductions are significant. They indicated that their 

proposa 1 woul d resul tin "twi ce" the energy savi ngs of the consensus proposal 

made by stakeho 1 ders for the refri gerator rul emaki ng. 

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 May tag who is not part of the joint commenters) has 

responded with a decision to develop a high efficiency horizontal-axis clothes 

washer. The joint commenters indicated that May tag vi rtually 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 joi nt commenters i ndi cated that General El ectri CiS concerns about a 

loss in consumer utility are not valid. In addition, they requested that the 

Department vi sit manufacturers to inspect propri etary producti on capabil ity of 

products that wi 11 address consumerutil ity concerns. The joi ntcommenters also 
believe 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 a workshop to discuss the Department's engineering

analysis. The additional schedules show the existing overall laundry rulemaking

schedule and a possible 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 a public workshop will not obtain

significant results due to confidentially problems. They want the laundry

rulemaking to be completed and celebrated, as a major 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 possibly manufacturing analyses.

The Department also indicated that any further delay in receiving 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 it would consider the joint commenters

suggestions and any decisions would be available to all stakeholders.

 EE-RM-94-403 COMMENT 26

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be 1 i eve that thi s wou1 d be an opportunity for the Department to val i date vari ous 

manufacturers confidential data submissions. 

The joi nt commenters also i ndi cated that they have been.1 obbyi ng Congress 

to support the Department I s budget for reglJ1 atory ru1 emaki ngs. 

The Department presented the attached schedu1 es whi ch show a short-term 

schedu1 e whi ch wou1 d i nc1 ude a workshop to di scuss the Department IS engi neeri ng 

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 i ndi cated that therevi sed. schedu1 e would requi re / 

internal prioriiization changes. 

The joint commenters were not happy with any of the schedu1es~ They believe 

that the schedu1 es are too 1 engthy and that a pub1 i c workshop wi 11 not obtai n 

significant resultsdue to'confidentially problems. They want the laundry 

rulemaking to be completed and celebrated, as"a major accomplishment of lithe 

fi rst term of the C1 i nton admi ni st rat ion. 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 i ndi cated that test procedure revi s i o'ns are requi red 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 i ndi cated that the short-term 

schedule shows how all of the near term work on the test procedures would be 

comp 1 eted. prior to a September 19.95 workshop. The Department i hdi cated that thi s 

'Would a'llow disclosure of test procedure decisions to the public, along with 

engineering and possibly manufacturing analyses. ' 

The Department also i ndi cated that any further del ay in recei vi ng the AHAM 

data woul d impact the ru1 emaki ng. The Department requested the joi nt commenters 

to attempt to expedite the data collection and submission to the-Department. 

.Conclusion " 

The Department i ndi cated that it .wou1 d consi der the joi nt commenters 

suggestions and any decisions would be available to all stakeholders. . 
LAUNDRY RULEMAKING

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I EE-RM-94-403 COMMENT 26

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LAUNDRY RULEMAKING,

SHORT-TERM SiEDULE

Activit Name Feb '95 Mar '95 Apr '95 May '95 Jun '95 Jul '95 Aug '95 Sept '95

Activity Name . _c__iv__y _ _ _ _ __a_ _ __2_1_912_12 19 12 1__ 5 11 231 30711a1412 6 141ll 121 2 401 9 1162 301 611 12 02 131101124

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 -

STANDARDS 3

DOE AND LBL DATA/COMMENT REVIEW _

ENGINEERING ANALYSIS BY LBLDOE ANALYSIS REVIEWANALYSIS REVIEW BY STAKEHOLDERS

WORKSHOP WITH STAKEHOLDERS 4- ___

NOTES:

1) PROPOSED TEST PROCEDURE WILL NOT CHANGE ENERGY CONSUMPTION OF CLOTHES WASHERSTO REFLECT CURRENT CONSUMERS'HABITS, THIS 16 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) 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 BE USED 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 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-CHARACTERISTICS (IE.

ENf:RGY EFFICIENCY INCREASE, COST, LIFE CYCLE COST, PAYBACK ETC.).

 EE-RM-94-403 COMMENT 26

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. LAU NO R.Y R U LE~j\KING, 

SHORT·TERMS~EDULE 

Activity -Name Feb '951' Mar '95 Apr '95 May '95 1 Jun '95 Jul'95 I ( Aug '95 1 Sept '95 . 

5 .121j:26 5 12192€ 2 91€233C 714212E 4 111a2~ 2 91€233C 61~2C21 3101/24' 

TEST PROCEDURES 

IMMEDIATE PLANNED REVISION 1 

NOPR PUBLISHED 

PUBLIC HEARING 

COMMENT· PERiOD I It"""": 

FUTURE REVISION (FOR 1999 STANDARDS) 

AHAM INFORMAL WORKSHOP WITH DOE. 

JOINT COMMENT TO DOE 2 

STANDARDS3 

DOE AND LBL DATA/COMMENT REVIEW 0-

I~ 

ENG.INEERIN'G ANALYSIS BY LBL s- ,. - DOE ANAL Y$IS REVIEW A rI 

ANALYSIS REVIEW BY STAKEHOLDERS -:7 

! 'I I 

WORKSHOP WITH STAKEHOLDERS 4 . , I 

'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.).' . 

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LAUNDRY RULEMAKING,

OYERALL SCHEDULE

1994 __1995_ 1996 '1997

___ _Activity Name _ j. Fourth First .Secondl Third Fourth 'First Second Third Fourth First Second Third

ANOPR PUBLICATION

ENGINEERING ANALYSIS .7 .

WORKSHOP ' '

MANUFACTURING/UTILITY ANALYSIS.

ETC., TECHNICAL SUPPORT DOC.. i. 7

NOTICE DEVELOPMENT. ;.

NOPR PUBLICATION .

FINAL RULE

Fourth First Second Third Fourth First Second Third Fourth First Second Third

 EE-RM-94-403 COMMENT 26

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Activity Name 

ANOPR PUBLICATION 

ENGINEERING ANALYSIS 

WORKSHOP 

MANUFACTURING/UTILITY ANALYSIS 

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NOTIC~ DEVELOPM~NT 

NOPR PUBLICATION 

FINAL RULE 

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LAUNDRY RULEMAKIN,~, 

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LAUNDRY RULEMAKING,

OVERALL SCHEDULE (possible revision)

A ,1994 ! . 1995 1996 1997

Activity Name' 'Activity Name Fourth First Second Third Fourth First Second Third Fourth First Second Third

ANOPR PUBLICATION

ENGINEERING ANALYSIS j N

WORKSHOP

MANUFACTURING/UTILITY ANALYSIS

ETC., TECHNICAL SUPPORT DOC. -

NOTICE DEVELOPMENT

NOPR PUBLICATION

FINAL RULE .

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ENGINEERING ANALYSIS 

WORKSHOP 

MANUFACTURING/UTILITY ANALYSIS 

ETC., TECHNICAL SUPPORT DOC. 

NOTICE DEVELOPMENT 

NOPR PUBLICATION 

FINAL RULE 

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1994 

"Fourth 

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LAUNDRY RULEMAKING, 

OVERALL SCHEDU~E (possible revision) 

1995 1996 1997 

First Second Third Fourth First Second Third Fourth First Second Third 

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