UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

PUBLIC MEETING

ENERGY CONSERVATION STANDARD

NOPR FOR TEST PROCEDURE FOR DISHWASHERS,

DEHUMIDIFIERS AND CONVENTIONAL COOKING PRODUCTS

U.S. Department of Energy 1000 Independence Avenue, SW Washington, DC 20585
Room 8E

- 089

Friday December 17 , 2010

Chair:

Wes Anderson Department of EnergyExecutive Court Reporters (301) 565

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Facilitator

Doug BrookmanExecutive Court Reporters (301) 565

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Participants Identified :

Mike Edwards BSH Home Appliance

Natascha Milesi

- Ferretti
NIST

Amanda Stevens
EPA E NERGY S TAR

Brice Bowley
GE Appliances

Jennifer Cleary
AHAM

Joanna Mauer Appliance Standards Awareness Project

Brian Warner BSH Home Appliance Corporation

Camilla Dunham Whitehead Lawrence Berkeley National Laboratory

Amanda Korane Lowenberger ACEEE

Meg Waltner Natural Resources Defense Council

Ryan Fogle D&R International

James Battaglia Navigant Consulting

Judith Reich Navigant Consulting

Troy Watson Navigant ConsultingExecutive Court Reporters (301) 565

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I N D E X

AGENDA ITEMS PAGE

**Welcome** 5

**Opening Remarks, Introductions**  **and Agenda Review** 6 Doug Brookman

**Stakeholder Opening Statements** Doug Brookman

**Introduction, Background and Legal Authority** 12 Wes Anderson Overview of past and current dishwasher, dehumidifier, and conventional cooking product rulemakings, including statutory authority, schedules and associated documents.

**Covered Products, Incorporation by Reference of** 16 **IEC Standard 6**  **2301 (First Edition), and**  **Determination and Classification of Operational Modes**  Judith Reich Definition of c overed products, proposed incorporation of the methodology of IEC Standard 62301 for measuring standby and off mode power consumption, and proposed mode definitions under EPCA, as amended by the
E nergy Independence and Security Act of 2007, including con sideration of IEC Standard 62301 FDIS.

**Address question s**  **from the webinar audience**

**Specifications for Text Methods and Measurements** 63 **For Standby and Off Mode Testing** Judith Reich Proposed amendments to add specificity to test methodology in IEC Standard 62301 for measuring standby and off mode power.Executive Court Reporters (301) 565

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I N D E X (Cont'd.)

AGENDA ITEMS PAGE

**Calculation of Energy Use Associated with Standby** 74 **Mode and Off Mode** Judith Reich Discussion of annual hours spent in active mode
, standby mode and off mode.

**Measures of Energy Consumption** 106 Judith Reich Proposed integrated efficiency metrics incorporating energy use in standby mode and

o f f mode.

**Compliance with other EPCA Requirements and** 117 **Impact of the Proposed Amendments on EnergyGuide** 

**a nd**  **ENERGY S**  **TAR** Judith Reich

**Conclusions and Closing Remarks Address final questions from the webinar**  **A udience**  Wes Anderson Discuss outstanding issues and make concluding

r emarks.

**Adjourn**Executive Court Reporters (301) 565

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P R O C E E D I N G S 1

9:00 a.m. 2

**WELCOME** 3

MR. BROOKMAN: So, good morning, everybody 4

and welcome. This is the U.S. Department of Energy's 5

Public Meeting on Energy Conservation Program for 6

Consumer Products : Test Procedures for Dishwashers, 7

De humidifiers and Conventional Cooking Products. 8

Today is Friday December 17 th , here at the U.S. 9

Department of Energy. My name is Doug Brookman, 10

Public Solutions in Baltimore and Wes Anderson from 11

the Department of Energy wishes to make welcoming 12

remarks. 13

MR. ANDERSON: Good morning, everyone. My 14

name is Wes Anderson. As Doug said, I'm with the 15

Department of Energy and we are here to

-- I'm here to 16

welcome you here on this cold and blustery morning. 17

For those who are out of town, this is our 18

first snow of the season and we handled it pretty 19

well. So let's hopefully that will transition to this 20

meeting and it will flow smoothly. 21

This is primarily set up to be a 22

conversation between the Department of Energy and the 23

interested parties on the subject matter . We look 24

forward to your questions. We will be posing 25Executive Court Reporters (301) 565

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questions throughout the meeting and asking for 1

comment and we will also look to hear your opinion on 2

certain things. And we will also give your our 3

insight on where we're going and how we got to wh ere 4

we are. 5

And with that, I would like to turn it back 6

over to Doug. 7

**OPENING REMARKS, INTRODUCTIONS, AND AGENDA REVIEW** 8

MR. BROOKMAN: Thank you. So glad you could 9

join us. Let's start with introductions. That's our 10

typical form. Let's start over here with Joanna. 11

MS. MAUER: Joana Mauer, Appliance Standards 12

Awareness Project. 13

MS. WALTNER: Meg Waltner, Natural Resources 14

Defense Council. 15

MS. CLEARY: Jennifer Cleary, Association 16

for Home Appliance Manufacturers. 17

MS. MILESI: Natas c ha Milesi

- Ferretti

, 18

National Institute of Standards and Technology. 19

MR. WARNER: Brian Warner, BSH Home 20

Appliance Corporation. 21

MR. EDWARDS: Mike Edwards from BSH Home 22

Appliance Corporation. 23

MR. STAS: Eric Stas, DOE General Counsel's 24

Office. 25Executive Court Reporters (301) 565

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MR. BROOKMAN: Wes int roduced himself. 1

Judy. 2

MS. REICH: Judith Reich, Navigant 3

Consulting. 4

MR. WATSON: Troy Watson, Navigant 5

Consulting. 6

MR. BATTAGLIA: James Battaglia, Navigant. 7

MR. BOWLEY: Brice Bowley, General Electric. 8

MS. STEVENS: Amanda Stevens, EPA E NERGY 9

S TAR

. 10

(Mr . Eric Jones of Energetics is the webinar 11

moderator, but did not introduce himself. We will 12

hear him interjecting throughout the presentation) 13

MR. BROOKMAN: Let me invite the two of you, 14

if you wish to, to try to sit at the table. It's up 15

to you, wherev er you would prefer to sit. 16

So glad you could join us. I'm going to run 17

through the Agenda very briefly. Immediately 18

following this agenda review there's an opportunity 19

for anybody that wishes to do so to make brief summary 20

remarks here at the outset con cerning key issues and 21

concerns that you may have. Immediately following 22

that, Wes Anderson is going to take us through a 23

background under legal authority for this proceeding. 24

And then from there we will go into the more detailed, 25Executive Court Reporters (301) 565

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substantive content of the day. 1

All of you received a packet of information 2

when you came in the door this morning, the PowerPoint 3

slides that will be presented as well as the Federal 4

Register notice. I think most of you are familiar 5

witness that the way this works. We use t he 6

PowerPoint slides as the focal point for both 7

presentation and for cuing discussion. There are 8

comment boxes interspersed throughout for that 9

purpose. 10

And after Wes ’ comments we are going to hear 11

about covered products, incorporation by reference of 12

IE C Standard 62301 (First Edition) and determination 13

and classification of operational modes. All of you 14

have a copy of this agenda, I believe. 15

We'll take a break midmorning

- ish, right 16

about 10:45 or so a nd then specifications for test 17

method s a nd measureme nts for standby and off

- mode 18

testing. 19

Immediately following that calculation of 20

energy use associated with standby mode and off mode. 21

We'll break for lunch today around about 22

noon or so and then measures of energy consumption, 23

compliance with other EPCA r equirements and impact of 24

the proposed amendments on EnergyGuide and ENERGY 25Executive Court Reporters (301) 565

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STAR. And at the end of the day today, whenever that 1

might be, there is yet another opportunity for anybody 2

that wishes to do so to make summary remarks to raise 3

any other issues that haven't been raised 4

sufficiently. So there is yet another opportunity for 5

you to do that. 6

The timing in the agenda suggests we're 7

going to adjourn today at 2:15. It's possible that 8

we'll get out of here even earlier than that. But 9

we'll just do t he timing efficiently as we go along. 10

At least that's the plan. 11

Questions and comments about the agenda? 12

(No response.) 13

MR. BROOKMAN: Then I'd ask for your 14

consideration

-- I'd ask, please, if you would, speak 15

one at a time. Please say your name for the record 16

each time you speak. You don't need to say your 17

organization affiliation every time unless you wish 18

to. There will be a complete transcript of this 19

meeting and it will be posted on the EER E website and 20

also on Regulations.gov. Is that where they 're 21

posting them now? I think. I think that they're 22

making that transition, I think. 23

I'm going to be cuing individuals to speak 24

by name. I also wish to encourage follow

- on comments 25Executive Court Reporters (301) 565

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so that we have the back and forth. Sometimes that's 1

very helpful for the Department to hear differing 2

perspectives. It informs their decision making 3

process. 4

If you could keep the focus here, please 5

turn your cell phones on silent mode, limit your 6

sidebar conversations and in order to speak you need 7

to turn on your micr ophone. The little green LED 8

button needs to be lit up. And if you could try and 9

be concise, share the airtime, that will be helpful. 10

There's a lot to be said, I'm certain. 11

Questions and comments here before we 12

proceed? 13

(No response.) 14

MR. BROOKMAN: As I understand it, we have a 15

webinar going now. The Department is trying to make 16

web access available to anybody who wishes to call in. 17

Do we have some folks? 18

Mr. Jones : Yeah, we have ten people. 19

MR. BROOKMAN: Ten folks. Well, those of 20

you who have joined us via the web, welcome. 21

In this format there is the potential for 22

those that are participating via the web to send 23

questions to our web moderator. And so if you have 24

questions as we're going along, please send them and 25Executive Court Reporters (301) 565

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we'll do the best we can t o insert them and answer 1

them during the course of the proceedings today. I 2

think that's all that we need to cover here at the 3

outset. 4

There now is an opportunity for anybody that 5

wants to, to make opening remarks summarizing issues 6

that they wish to car ry forward. Jennifer. 7

MS. CLEARY: Jennifer Cleary. First I'd 8

like to thank the Department of Energy for accepting 9

comments and hosting this meeting today. We 10

appreciate the opportunity to give our feedback. 11

However, there are a number of instances in this 12

rulemaking where DOE seems to be acting without 13

sufficient or any data. The test procedure is 14

intended to be representative of consumer use. 15

Without data showing what is representative of 16

consumer use DOE has no reasonable basis upon which to 17

act a nd under no circumstance should DOE act on its 18

own belief about consumer usage. 19

We certainly understand that DOE is in a 20

challenging position trying to carry out its statutory 21

mandate, but if there's no data available no action 22

can be taken. Acting witho ut data is unreasonable and 23

arbitrary and we will certainly provide more detailed 24

comments later today in our written comments, but felt 25Executive Court Reporters (301) 565

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that was an important sentiment to share at the 1

beginning. 2

MR. BROOKMAN: Okay. Do you have data that 3

you can help to supplement DOE's sources? 4

MS. CLEARY: We may have data on some 5

points, we don't on others. But the main concern is 6

that even if no one can provide that data, if the data 7

doesn't exist, there's no reasonable basis upon which 8

to act unless that data is collected. 9

MR. BROOKMAN: Okay. Other comments here at 10

the outset? 11

Yes, Wes Anderson 12

MR. ANDERSON: Can you at least point out 13

where you specifically think

-- 14

MR. BROOKMAN: Well, let's do it through the 15

course of the meeting. 16

MS. CLEARY: Yeah, we absolutely will today 17

and in our written comments. 18

MR. BROOKMAN: Good. Okay. That's good. 19

Other comments here at the outset? 20

(No response.) 21

MR. BROOKMAN: No additional comments, none 22

from industry. No. Okay. 23

So, Wes, then let's go through the 24

b ackground and legal authority. 25Executive Court Reporters (301) 565

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**BACKGROUND AND LEGAL AUTHORITY** 1

MR. ANDERSON: Again, welcome. My name is 2

Wes Anderson. I'm with the Department of Energy. We 3

are at the NOPR presentation for today which we 4

published the NOPR on December 2 nd of this year and 5

today's the 17 th where we're having the meeting. We'll 6

be looking for your comments and input. As Doug said, 7

there will be a transcript available of today's 8

meeting. Also available to the public will be your 9

written comments. 10

The comm ent period closes in 75 days from 11

the publication date, from December 2 nd which was 12

February the 15 t h

-- which is February the 15 th , 2011. 13

So, please make note of that. 14

DOE will review and consider all your 15

comments for the final rule publication. 16

Today we are going to cover

-- I'm just 17

going to give an overview of what we're going to talk 18

about. For products covered in the proposed 19

amendments, we're going to look at what the specific 20

products are, dishwashers, dehumidifiers, and 21

conventional cooki ng products, and the subcategories 22

within that. And we'll give a definition so it will 23

be clear what we're talking about and we can also 24

actually input on that. And we're not proposing any 25Executive Court Reporters (301) 565

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changes to definitions at this point. And we haven't 1

heard of an y concern at this point as well. 2

Then we're going to incorporate by reference 3

of how we're going to incorporate by reference the IEC 4

Standard 62301 first edition for measuring standby and 5

off mode power consumption and how it relates to those 6

three subject s and what we'll take directly from 7

publicly available information which is first edition 8

and we'll discuss what's in development with IEC's 9

final draft. 10

Part three is to determine and 11

classification of operation modes which we'll go into 12

detail on mode de finitions, talk about how DOE has 13

developed or derived these modes, or how we define 14

these modes. The difference in the modes in principal 15

between active

, standby
, and off mode and then we'll 16

apply that definition or explanation to the specifics 17

of the pr oducts and how active

, standby
, and off mode 18

affects each one. 19

We'll also talk about some other modes, the 20

more complicated modes or esoteric modes that are 21

further down the line and looking for your input on 22

that piece. 23

Section four, the specification f or the test 24

method and measurements for standby mode and off mode 25Executive Court Reporters (301) 565

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testing. We'll be talking about power stability and a 1

description of that. We'll talk about the big power 2

hogs in the equipment which will be driving some of 3

the testing procedure and we'l l talk about the testing 4

environment how the room

-- the external environment 5

in which the product will be tested and how to deal 6

with unstable power situations. And we'll talk about 7

how to deal with some of the comments and/or waivers 8

that have been brou ght up. 9

For Section five, calculation of energy use 10

associated with standby mode and off mode. There 11

we'll discuss how DOE calculates is annual energy 12

usage number, what we think these numbers are for the 13

different products. We'll point out where we need 14

your help on that and for instance for conventional 15

cooking products, we'll talk about active

, standby, 16

delay start, cycle finish, those kind of things to 17

clarify the discussion there. 18

And in Section six what we'll talk about 19

measurement measures of energ y consumption. We'll go 20

over legal justification for that and how existing 21

measures will be combined with

-- how the active, 22

standby and off mode will be combined into an annual 23

number. Where in Section 5

, we'll be specifically 24

talking about the individu al products. 25Executive Court Reporters (301) 565

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So in Chapter 7

-- in Section seven we will 1

-- compliance with other EPCA requirements which will 2

be the test burden or potential for incorporating IEC 3

62087 and where we combine for dishwashers the 4

estimated annual energy use, or the estima ted annual 5

operating costs and for dehumidifiers, the integrated 6

energy factor. And for conventional cooking products, 7

the integrated annual energy consumption number and 8

the integrated energy factor. 9

And we'll also talk about how the test 10

procedure will impact FTC's in Section 8

-- impact 11

FTC's E nergy G uide requirements and ENERGY S TAR power 12

requirements. And with that we will start with Judy

- 13

- I'll do this one as well. 14

This is where the regulatory information is 15

located in the 10 CFR 430, Subpart B, App endix C for 16

dishwashers; for conventional ranges or cooking 17

products it will be in Appendix I and for 18

dehumidifiers it's in Appendix X. All of that is in 19

Section

-- in 10 CFR Part 430, Subpart B. 20

The Energy Independence and Security Act of 21

2007 or informa lly known as EISA 2007 amended EPCA to 22

direct (ed) DOE to amend the test procedures for 23

dishwashers, dehumidifiers and conventional cooking 24

products to integrate measures of standby, off mode 25Executive Court Reporters (301) 565

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energy consumption. And the publication of the final 1

rule should be no later than March 31 st , 2011. 2

With that we'll start with the first 3

section, products covered by the proposed amendments 4

by Judy Reich. 5

**Covered Products, Incorporation by Reference of IEC** 6

**Standard 62301 (First Edition), and Determination** 7

**And Classific ation of Operational Modes**  8

MS. REICH: Good morning, everybody. I'm 9

Judith Reich from Navigant Consulting and I will be 10

talking about the proposed amendments to the test 11

procedures and covering the analysis that's supporting 12

those amendments. So to set the stage for the 13

discussion, I'll start off by reviewing the 14

definitions for products that are covered in this 15

rulemaking. And as Wes mentioned, these are codified 16

in the CFR, specifically at Part 430.2. And I won't 17

read through each one of these indivi dually, but it's 18

important to note that for dishwashers and 19

dehumidifiers these definitions broadly cover all of 20

the classes that exist currently. For dishwashers 21

that would be standard size and compact size and 22

dehumidifiers, units of varying capacity. 23

For cooking products the definition covers 24

those that are designed to cook or heat food by one or 25Executive Court Reporters (301) 565

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more of the sources of heat which include gas, 1

electricity, and microwave energy. 2

For this rulemaking we're looking at 3

conventional cooking products. So tha t would be those 4

products that are using gas or electricity. Microwave 5

cooking products are covered in a separate ongoing 6

test procedure rulemaking. 7

Conventional cooking products are 8

disaggregated into three types. The definitions 9

include a conventional cooking top which is the 10

horizontal surface containing one or more surface 11

units with either gas flame or electric resistance 12

heating; conventional ovens consist of

-- it's a class 13

that includes ranges and ovens in which the food is 14

heated in a compartmen t either by a gas flame or 15

electric resistance heating. And a conventional range 16

is simply a combined unit that includes both a cook 17

top and one or more conventional ovens. 18

As Wes mentioned, the proposed test 19

procedure amendments would not include change s to 20

these product definitions. So although we don't have 21

a specific request here for comment, I will open it up 22

if anybody has a comment on these definitions. 23

MR. EDWARDS: How do the other, like double 24

ovens and things like that

-- 25Executive Court Reporters (301) 565

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MR. BROOKMAN: Would you say your name for 1

the record, please? 2

MR. EDWARDS: Mike Edwards, BSH Home 3

Appliances. 4

MS. REICH: Uh

- huh. 5

MR. EDWARDS: How will double ovens and 6

other combo products like that be considered? 7

MS. REICH: The test procedure al ready 8

includes provisions for multiple ovens within the same 9

product. So they're already covered. 10

MR. BROOKMAN: Yes, Ama n da. 11

MS. STEVENS: Could you speak to the 12

coverage of induction cook tops ? 13

MS. REICH: Yes, right now the test 14

procedure does not cover them. The methodology that's 15

included now utilizes an aluminum test block to 16

measure the heat transfer to it. And so, of course, 17

for an induction system, it doesn't work. There's no 18

energy imparted to it. So there has been some work 19

previously to develop methodology to accommodate that. 20

But at this point that has not been incorporated in 21

the test procedure and for the purpose of today's 22

rulemaking, the amendments were focusing on standby 23

and off

- mode energy use. So there was not an attempt 24

to ad dress the active mode portion. 25Executive Court Reporters (301) 565

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MR. BROOKMAN: Other questions on 1

definitions? Mike? 2

MR. EDWARDS: Mike Edwards, again. The 3

consumption of microwave and microwave oven 4

combinations, is that also specified in the procedure? 5

MS. REICH: Right now for act ive mode it is 6

not. There was a recent repeal final rule that was 7

issued that removed those provisions because of some 8

inherent problems with them. DOE is currently 9

considering whether to develop new active mode 10

provisions, but right now there are none. There is a 11

-- as I mentioned

-- an ongoing rulemaking that would 12

address standby and off mode energy for microwaves. 13

MR. BROOKMAN: There is a lot in these first 14

few slides here, so maybe you could just scan back 15

through and make sure you got your questi ons answered 16

before we move on. 17

(Pause.) 18

MR. ANDERSON: This is Wes Anderson, 19

Department of Energy. I think that was Judy's subtle 20

way of saying that if we could focus our questions on 21

standby and off mode at this point it would kind of 22

speed us through this process. And if you have 23

comments or questions about active mode issues, please 24

submit them. But we want to limit our conversation to 25Executive Court Reporters (301) 565

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standby and off mode. 1

MR. BROOKMAN: Additional questions? 2

MR. ANDERSON: Or how active mode relates to 3

those tw o things. 4

MR. BROOKMAN: Then let's proceed. 5

MS. REICH: The next section will discuss 6

the incorporation by reference of IEC Standard 62301, 7

specifically the first edition for the purposes of 8

measuring the standby and off

- mode energy use. 9

So the Energy Independence and Security Act 10

of 2007 or E I SA amended the Energy Policy and 11

Conservation Act to require that the test procedures 12

for certain products be amended to address the issue 13

of standby and off

- mode energy use and that DOE should 14

take into considera tion the most current versions of 15

two international standards from the International 16

Electro Technical Commission, specifically standard 17

62301 and 62087. 62301 covers standby power in 18

residential appliances. IEC 62087 addresses video and 19

audio equipment and related products. So
, it was 20

determined that that is not applicable to this 21

rulemaking. So

, the discussion today is going to 22

focus on 62301. 23

DOE is proposing to incorporate certain 24

provisions from the first edition of 62301 that are 25Executive Court Reporters (301) 565

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listed here. Th ese are conditions in methodology that 1

provide clarification or additions to the test 2

procedure to allow for measurement of standby and off

3

mode power. And you can see they generally relate to 4

test conditions, specifically test room ambient 5

conditions, th e waveform for the supply voltage and 6

the accuracy of the metering equipment used to measure 7

the power. 8

In terms of the methodology, the 9

measurements from Section 5, the reference first would 10

be to a general note on measuring the power if it 11

drops from a higher power state to a lower power 12

state ; it would be taking the measurement at the lower 13

power state. 14

Section 5.2 discusses the test set up and in 15

particular this is going to relate to default settings 16

for setting up the equipment. And finally, Sec tion 17

5.3 is the actual methodology that would be used to 18

measure standby power and this accounts for situations 19

where the power consumption is stable. And it also 20

covers situations where the product has power 21

consumption that varies over time. 22

DOE is aw are that the IEC is in the process 23

-- well into the process of updating standard 62301. 24

It is going to be

-- the next version will be labeled 25Executive Court Reporters (301) 565

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as the second edition. And based on the draft 1

versions that have been released, it is expected that 2

the second e dition is going to include some additional 3

mode definitions in addition to standby mode. In 4

particular it's likely that it will include an off

5

mode definition, network mode, and disconnected mode 6

as well as revising what the current definition is for 7

stan dby mode. 8

However, the IEC has not yet published a 9

final version of this second edition and therefore DOE 10

has made the determination that the current version 11

that's available for consideration or incorporation by 12

reference is still the first edition. 13

How ever, in order to provide the best 14

possible analysis, DOE has reviewed the two most 15

recent draft versions of the second edition and these 16

are entitled

-- the first of those was the Committee 17

Draft for Vote or CDV and then the most recent one 18

which followed that the Final Draft International 19

Standard which we'll refer to as the FDIS. 20

Because of the status of the FDIS as very 21

late in the process

, DOE anticipates that when the 22

second edition is issued that the mode definitions are 23

going to be similar to those that are included in the 24

FDIS. And so therefore DOE has considered mode 25Executive Court Reporters (301) 565

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definitions from that version in today's rulemaking. 1

And I think it 's important to clarify that it's 2

looking very narrowly at the mode definitions from 3

this draft version on the basis of substantial 4

comments and input that it has received from 5

interested parties on other similar recent 6

rulemakings. 7

Two of these covered p roducts already do 8

include some measure of standby power in the test 9

procedures, specifically dishwashers and conventional 10

cooking products. The dishwasher test procedure, the 11

provisions that are currently in place to measure 12

standby power are very simila r to what is included in 13

IEC 62301, the first edition. It's a single 14

measurement of a standby power. So it doesn't allow 15

for the possibility that there may be multiple standby 16

modes, nor does it address the situation of an off 17

mode. So DOE is proposing to amend the dishwasher 18

test procedure to include these new definitions for 19

standby
, off
, and I think that should say "active 20

mode" based on the definitions within the FDIS as well 21

as what was in the table that I first showed, the 22

testing clauses from the first edition. 23

For cooking products, there is a limited 24

measure of standby power right now in the form of the 25Executive Court Reporters (301) 565

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annual energy consumption for a clock, but no other 1

standby mode or off mode energy consumption. So, 2

again, the proposed amendments would include 3

definitions that would fully account for the 4

possibility of multiple standby modes and off mode. 5

At this point DOE would like to receive any 6

comments of the adequacy of IEC's standard 62301 for 7

measuring standby and off mode power in the three 8

cov ered products and on the suitability of 9

incorporating the specific clauses into DOE 10

regulations. 11

MR. BROOKMAN: Jennifer. 12

MS. CLEARY: Jennifer Cleary, AHAM. AHAM 13

urges DOE to reference the second edition FDIS as the 14

main document instead of the first e dition, as we've 15

commented previously, that version will soon be 16

formally adopted by IEC just as it is, you know, 17

currently in the draft, that will not change. It 18

contains a number of important clarifications that are 19

not present in the first edition or e ven in the CDV 20

version. And we think that adopting the FDIS will 21

allow for optimum international harmonization which 22

will give clarity and consistency to the regulated 23

parties and will certainly provide some more detail on 24

how we think DOE can do that and where we specifically 25Executive Court Reporters (301) 565

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think they should. 1

In addition, we do appreciate that 2

specifically with regard to the definitions in some 3

other areas that you have looked at the FDIS and 4

incorporated that. We think that's certainly an 5

improvement. But I think we need to go a little bit 6

further to address the holistic intent of the standard 7

6 2 301 (sic). 8

MR. BROOKMAN: Do you know what the 9

timetable is for the second edition? 10

MS. CLEARY: The timetable seems to be hard 11

to tie down, but, you know, very soon, we ar e hoping. 12

MR. BROOKMAN: I see. Okay. I'm wondering 13

how that fits with DOE's needs to press on with this 14

proceeding then. That's my only question. I guess 15

it's up in the air. Wes? 16

MR. ANDERSON: I would just like to remind 17

everybody that we're tryin g to get this out the door 18

published by March

-- the end of March next year. So 19

DOE is sort of limited as to what it can do for 20

nonpublic documents. 21

MR. BROOKMAN: So that is if the second 22

edition hasn't been adopted formally yet, then DOE 23

can't incorpor ate it formally by reference or 24

something like that? 25Executive Court Reporters (301) 565

- 0064 28

MR. ANDERSON: Not by reference, no. 1

MR. BROOKMAN: I see. Okay. Eric Stas. 2

MR. STAS: Eric Stas, DOE. So in your 3

comment, you know, try to be very specific. If this 4

thing isn't formally adopted y et, things that you 5

would like to see incorporated in our regulations to 6

capture the most important elements. 7

MS. CLEARY: Yeah, I will certainly do that 8

where it's possible. I think part of our comment here 9

is that it's very hard to pick and choose whic h 10

sections you use because the standard is intended to 11

be read as a whole. And so when you start to just 12

pick certain sections out that causes problems in how 13

they're interpreted because picking out, for example, 14

a definition from the FDIS and then combin ing that 15

with incorporation by reference to the first edition, 16

it doesn't really match up. And so that's really why 17

we're making the comment that perhaps the 18

interpretation of current edition should be different. 19

MR. BROOKMAN: Yeah, I was trying to 20

reme mber who was here the last time we did this 21

talking about the IEC process and how it kept

-- that 22

was a lengthy description. It just seems like it's 23

hard to cause the IEC process to accelerate. 24

MS. CLEARY: Right. But it is. And it's 25Executive Court Reporters (301) 565

- 0064 29

final right now. This draft is being voted on and 1

there are certain rules in the voting process that 2

make it fairly clear that this

-- you know, is as it 3

is. So we'll provide more detail. We don't want to 4

extend this, you know. We've made these comments 5

before. 6

MR. B ROOKMAN: Okay. So there is a request 7

for other comments on the adequacy of the IEC 8

standard. Other comments on this? 9

(No response.) 10

MR. BROOKMAN: I see no additional comments. 11

Okay. 12

MS. REICH: Okay. The next topic I will 13

cover is how these mode d efinitions are applied to the 14

products and classification of operational modes 15

within those definitions. So, EPCA, as modified by 16

EISA , provides definitions itself for active, standby 17

and off mode. And IEC standard 62301 contains an 18

additional definition for standby power. And these 19

definitions are intended to be very encompassing and 20

broadly applicable to all types of products. So that 21

can lead to multiple interpretations for a given 22

product. 23

I think we've covered in detail that this 24

second edition dr aft, FDIS version, is available. And 25Executive Court Reporters (301) 565

- 0064 30

the definitions that are within there are expected to 1

remain largely similar when a second edition comes 2

out. 3

So, again, for reasons that the draft has 4

been available for DOE to receive comment on for some 5

time now a nd DOE has received inputs from multiple 6

parties on it, DOE was considering that portion of the 7

FDIS in determining mode definitions for its amended 8

test procedures. 9

So the amendments are proposing to use the 10

definition in the FD I S as a starting point bu t provide 11

additional clarification to apply those modes 12

specifically to the dishwashers, dehumidifiers, and 13

cooking products. 14

So let me start off with the definition 15

being proposed for active mode. And that is the 16

condition in which the energy using pro duct is 17

connected to power, has been activated and provides 18

one or more main functions. 19

In a previous draft version, the Second 20

Edition Committee Draft Two, there was an addition al 21

clarification that delay start mode is a one

- off, 22

user

- initiated, short

- duration function associated 23

with active mode. And DOE noted that this 24

clarification or this note was removed in the FDIS. 25Executive Court Reporters (301) 565

- 0064 31

And the FDIS now classifies delay start as a secondary 1

function that is not part of active mode. 2

However, because delay start is o f finite 3

duration, limited duration, and it is uniquely 4

associated with the initiation of a main function, DOE 5

believes that it should indeed be considered as part 6

of active mode which is something that we'll get into 7

in a moment. 8

To clarify the definitio n of active mode for 9

dishwashers, DOE is proposing to define active mode as 10

the dishwasher is performing the main function of 11

washing, rinsing, or drying, when such a drying 12

process is included, the various dish ware and utensils 13

by chemical, mechanical and /or electrical means or is 14

involved in the functions necessary to provide those 15

main functions which would include admitting water 16

into the dishwasher or pumping water out of it. 17

To clarify what active mode means for 18

conventional cooking products, the pro posed amendment 19

would be that it is a mode in which either a 20

conventional cooking top, oven, or range is performing 21

the main function of cooking, heating, proofing, or 22

holding a cooking load by means of either the gas 23

flame or electric resistance heating. 24

For dehumidifiers the clarifications would 25Executive Court Reporters (301) 565

- 0064 32

cover three main functions, specifically removing 1

moisture from the ambient air by drawing that air 2

across a refrigerated coil. A similar process in 3

which the air is circulated with a fan, but the 4

refrigeration system isn't activated, so it's only for 5

the purpose of circulating the air. 6

And then third is a function in which if ice 7

builds up on the coil that there would be a periodic 8

activity to defrost the coil. 9

Now, for standby mode DOE is proposing to 10

define it as a mode in which the product is connected 11

to the power source and it includes one or more of the 12

following functions, and a key element to this 13

definition is that these functions may persist for an 14

indefinite time. The first function would be to 15

faci litate activation of other modes, either 16

activating or deactivating active mode , b y remote 17

switch which would include the use of remote control, 18

an internal sensor or a timer. 19

Standby mode would also include a continuous 20

function such as information or st atus displays and 21

that would include any clock or senor

- based functions 22

such as a cooking sensor. 23

DOE would also clarify that a timer doesn't 24

necessarily have to be limited to an external clock or 25Executive Court Reporters (301) 565

- 0064 33

other display that's observable by the consumer. It 1

can also be an internal timer in which the components 2

on the control board are providing switching of 3

regularly scheduled tasks, but it would be happening 4

on a continual basis. 5

So it's important to note that that standby 6

mode definition is different than wh at is in the 7

current dishwasher test procedure. That definition 8

was very similar to the one that was provided in 62301 9

first edition, that was simply a single measurement 10

that was taken at the lowest possible power state. 11

DOE proposes to retain that defi nition that's in the 12

dishwasher test procedure and rename it as a 13

simplified standby mode for the purposes of continuing 14

to still provide the appropriate metric for the 15

existing energy conservation standards until any 16

amended standards for dishwashers take effect. 17

Again, multiple modes under this new 18

proposed definition for standby can be considered and 19

a standby mode that is sort of common to all of the 20

products would be something defined as inactive mode 21

in which the product is in a mode in which it coul d be 22

activated back to active mode by remote control or an 23

internal sensor or timer, a soft power switch, for 24

example, or one that provides a continuous status 25Executive Court Reporters (301) 565

- 0064 34

display. 1

Off mode is a mode which DOE proposes to 2

define as a situation where the product is, a gain, 3

connected to power and is not providing either an 4

active or standby function. Again, off mode would be 5

a situation that may persist for indefinite time. 6

An important clarification that DOE proposes 7

to add is that if there is an indicator such as a 8

light that is provided on the product whose only 9

purpose is to show the user that the product is in an 10

off position, but is connected to power

, it would 11

still be included as an off mode. 12

Also, DOE believes that a product that is 13

equipped with a hard on/ off switch that could 14

disconnect the power to the display or control 15

components would be considered to be in off mode when 16

the switch is in the off position as long as there's 17

no other function taking place that would classify it 18

as a standby or active mod e. 19

So, DOE believes that these definitions are 20

applicable to all of the products under consideration 21

but that there are some additional modes that are 22

specific to each product that DOE looked at in detail. 23

Before I move on to those, I would like to 24

invit e comment on the proposed definitions of standby 25Executive Court Reporters (301) 565

- 0064 35

mode, off mode, and active mode based on the 1

definitions within the FDIS. 2

MR. BROOKMAN: Jennifer. 3

MS. CLEARY: Jennifer Cleary. As you 4

mentioned in your slides, DOE is proposing to define 5

standby mode ba sed on the FDIS version. We support 6

that definition. AHAM does propose, however, by way 7

of clarification that DOE indicate that all products 8

will default to the standby mode as delivered from the 9

factory and we'll expand on that in our written 10

comments. 11

MR. BROOKMAN: Thank you. 12

Mike. 13

MR. EDWARDS: Mike Edwards, B SH. BSH . Are 14

you going to address the water

- softening dishwashers 15

and how that applies and which mode that falls in? I 16

think recent interpretations have that under active 17

mode. 18

MS. REICH: O kay. That is not a function 19

that is addressed for today, but we would certainly 20

invite comment on it because we have heard that that 21

is a function that's somewhat newly identified as for 22

dishwashers and we'd certainly like to consider how to 23

classify that

. 24

MR. EDWARDS: Under the current route of 25Executive Court Reporters (301) 565

- 0064 36

DOE, it appears as though they're interpreting it 1

differently than IEC. So we would

-- 2

MR. BROOKMAN: Do you want to describe that 3

now? 4

MR. EDWARDS: There's a waiver now Whirlpool 5

Corporation has and they' re adding power used in the 6

regeneration process. And others that have 7

dishwashers with water softeners are supposed to be 8

calculating that and submitting a waiver as well. So 9

I think it's something that needs to be considered in 10

the final rule to how we deal with that. 11

MR. BROOKMAN: Did you say how IEC is 12

addressing that? 13

MR. EDWARDS: I don't think IEC treats that 14

as active mode at this point. They say

-- I think 15

there was also secondary process

-- 16

MR. BROOKMAN: I see. 17

MR. EDWARDS:

-- separate from washing and 18

cleaning the dishes. 19

MR. BROOKMAN: And nor is it considered in 20

any of the other identified defined modes here. 21

MR. EDWARDS: I'm not positive of that. I 22

think we would need to look at that. 23

MS. REICH: I have a question. 24

MR. BROOKMAN: Yes, go ahead. 25Executive Court Reporters (301) 565

- 0064 37

MS. REICH: Okay. I was wondering if you're 1

aware of any methodology to measure

-- 2

MR. EDWARDS: Whirlpool came out with a 3

methodology and the others applying for waiver are 4

supposed to use something similar to that methodolog y. 5

MR. BROOKMAN: So that's available, that 6

methodology? 7

MR. EDWARDS: I think so. I'm in the 8

process of writing a waiver for us now. 9

MR. BROOKMAN: Okay. 10

MR. EDWARDS: And hopefully I am duplicating 11

that. 12

MR. BROOKMAN: And John, just so we know, 13

yo u're representing who

-- pardon me, Mike, who are 14

you representing today? 15

MR. EDWARDS: BSH Home Appliances. 16

MR. BROOKMAN: Thank you. Thank you. I 17

apologize. 18

MS. REICH: I have one other request if you 19

have or are aware of any data on percentage of u nits 20

that have such a function or how often they are active 21

-- this function is activated

-- 22

MR. EDWARDS: Well, I think that's the 23

problem, in the U.S. there's limited data. They're 24

normally on very high

- end products and it would be my 25Executive Court Reporters (301) 565

- 0064 38

opinion that hom es that buy these dishwashers normally 1

have home water softening systems. So the frequency 2

of use could be very low. But I don't think there's 3

any true data currently in the U.S. on that. 4

MR. BROOKMAN: So if they bought these units 5

and they had home wa ter softening units, then that 6

capacity in the dishwasher that would be duplicative? 7

MR. EDWARDS: And the y would just set it at 8

zero which basically is non

- energy

-- 9

MR. BROOKMAN: Oh, so there would be a 10

control function for that feature? 11

MR. EDWARDS : You can adjust the level. You 12

basically adjust the level for water hardness on the 13

water softener. 14

MR. BROOKMAN: Huh, interesting. Wow. 15

(Laughter.) 16

MR. BROOKMAN: That's really something. 17

Okay. 18

Do you have any additional questions? 19

MS. REIC H: No, thank you. 20

MR. BROOKMAN: Okay. Then let's proceed. 21

MS. REICH: As I mentioned, there are some 22

addition al modes for each of the products that now I'm 23

going to look at specifically and so DOE identified 24

these functions and considered each how they would be 25Executive Court Reporters (301) 565

- 0064 39

classified as whether they would be an active, standby 1

or off mode. 2

For dishwashers

, it identified two 3

a dditional modes, delay start mode and cycle finish ed 4

mode where delay start would be defined as the product 5

would be activated by a timer and cycle finish ed mode 6

is a state in which the product is providing a 7

continuous status display following operation i n an 8

active or washing mode. 9

DOE believes that because delay start does 10

not persist for an indefinite period that it persists 11

for the length and duration that's set by the timer, 12

DOE believes it's not a standby mode, but instead 13

would be a form of active mode. And because this test 14

procedure rulemaking is addressing standby mode and 15

off mode power, it's not proposing amendments to the 16

active mode portion and is not addressing the delay 17

start mode. 18

However, cycle finish ed mode would be 19

considered a standb y mode. Under the proposed 20

definitions DOE believes that the display on most 21

dishwashers is provided indefinitely until the user 22

takes some action either by engaging an on/off switch 23

or by opening the door. So that would meet the 24

definition that it may p ersist for an indefinite time. 25Executive Court Reporters (301) 565

- 0064 40

I invite comment at this point on the 1

establishment of inactive mode, as we discussed 2

previously, and cycle finish ed mode as standby modes 3

for dishwashers as well a determination that delay 4

start mode

-- delay start mode, I believe that is

-- 5

yeah, it's actually

-- it would not be a form of 6

standby mode. And further invites comment on whether 7

there are additional modes consistent with the active 8

standby or off mode definitions that have not been 9

identified and that represent significant energy use. 10

MR. BROOKMAN: So just to clarify, the 11

comment box, the third line, the last word "active" 12

should be standby? 13

MS. REICH: Yes. 14

MR. BROOKMAN: Okay. Jennifer. 15

MS. CLEARY: Jennifer Cleary. AHAM agrees 16

that delay start mode should be part of the active 17

mode. However, we disagree that cycle finish ed mode 18

is part of standby. We think that should be part of 19

the active mode and we'll give reasons why in our 20

written comments. We're still working on, you know, 21

fleshing that out for you in detail. 22

MR. BROOKMAN: I hope I haven't confused 23

things further. In that third line where it says, "In 24

this comment box the determination that delay start 25Executive Court Reporters (301) 565

- 0064 41

mode would not be a form of" it says here, "active 1

mode" but I just confirmed with Judy, it should say 2

"standby mode." 3

MS. REICH: Standby mode. 4

MR. BROOKMAN: So what is your comment? 5

MS. CLEARY: My comment is that we agree 6

that delay start mode should be part of the active 7

mode. Sorry, maybe I reversed what I said. And that 8

cycle fini sh ed mode, we believe, should also be a part 9

of the active mode. So both AHAM believes should be 10

active mode, if that is a way to make it clear. 11

MR. BROOKMAN: Yes, Joanna. 12

MS. MAUER: Joanna Mauer. I believe in the 13

current clothes washer test procedur e rulemaking that 14

DOE is proposing that cycle finish ed mode for clothes 15

washers be considered part of active mode. And I was 16

just wondering if you could describe a little bit 17

whether there's a difference in functionality between 18

the two products that woul d

-- 19

MS. REICH: Sure. Sure. Yes. For a 20

clothes washer
, DOE's testing observed that at the end 21

of a wash cycle that there

-- that clothes washers 22

typically provide a (n) indication to the user for a 23

short period of time that the cycle is complete and 24

t hen drop down into a lower power state. For a 25Executive Court Reporters (301) 565

- 0064 42

dishwasher, observations were that a dishwasher 1

display continues indefinitely if the user doesn't 2

take any action. So there is a different

-- they 3

operate differently. So that lead s to the different 4

classif ication. 5

MR. BROOKMAN: Mike. 6

MR. EDWARDS: Mike Edwards, BSH

. BSH . Are 7

there theories on how you will calculate the time of 8

the active mode from the control being lit? 9

MS. REICH: I will get into the discussion 10

of annual hours that are attributed to ea ch mode in a 11

moment, yes. 12

MR. BROOKMAN: Additional comments? 13

Questions? 14

(No response.) 15

MR. BROOKMAN: Okay. 16

MS. REICH: Okay. For dehumidifiers DOE 17

identified three additional modes, operating modes. 18

Similarly a delay start mode. There is also an off

19

cycle mode and a bucket full or bucket removed mode. 20

Delay start, again, is activating the active mode via 21

timer, the same as it was for dishwashers. For off

22

cycle, this is a period in which the dehumidifier is 23

on and is

-- but has cycled off the mai n function by 24

either humidistat or humidity sensor because it sensed 25Executive Court Reporters (301) 565

- 0064 43

that the humidity level in the ambient room is at the 1

desired set point and the dehumidifier does not have a 2

fan or blower for operating. However, because it is 3

sensing the humidity leve l and will reactivate the 4

dehumidification process at a time when called for, 5

according to the sensor signal, that would classify 6

that as a standby mode. 7

The bucket full and removed mode is, you 8

know, obviously as the moisture is being collected in 9

a buck et, at some point it fills. And the 10

dehumidifier has a switch that shuts the main 11

operation off until the bucket is removed and emptied. 12

So typically there is some sort of status display to 13

the consumer that the bucket is full. So because, 14

barring any c onsumer intervention, that could persist 15

indefinitely, DOE believes that that mode would also 16

be a standby mode. 17

DOE invites comment on the inactive mode, 18

off

- cycle mode, and bucket full/removed mode 19

definitions as standby modes for dehumidifiers. And 20

th e determination, again, that delay start mode could 21

be considered as part of active mode. And further 22

whether there are any additional modes for 23

dehumidifiers that haven't been identified that would 24

represent significant energy use. 25Executive Court Reporters (301) 565

- 0064 44

MR. BROOKMAN: Commen ts? 1

MR. BOWLEY: Brice Bowley. As far as the 2

bucket full mode, I would consider that similarly as a 3

cycle finished mode and would make a comment that I 4

would consider that part of an active mode as well, 5

similar to what was found on the clothes washers. 6

Same comment as for dishwashers. 7

MR. BROOKMAN: Okay. Thank you. 8

Jennifer. 9

MS. CLEARY: It's Jennifer Cleary. We agree 10

about delay start mode that it should be in the active 11

mode. 12

MR. BROOKMAN: Okay. 13

(Pause.) 14

MS. REICH: Okay? 15

MR. BROOKMAN: Y es. 16

MS. REICH: Finally, for cooking products, 17

there are three modes that DOE identified other than 18

the ones previously discussed, including a delay start 19

mode, a cycle finish ed mode, and a Sabbath mode. As 20

we've already gone through the definitions of delay 21

start and cycle finish ed . Sabbath mode is a feature 22

that is for function that is provided for households 23

that follow kosher practices. The primary feature in 24

Sabbath mode is that it disables the automatic shutoff 25Executive Court Reporters (301) 565

- 0064 45

capability. It overrides that so that food can be 1

held for long periods of time so that, no, it doesn't 2

violate the stipulations that would occur on the 3

Jewish Sabbath. 4

So, again, delay start and cycle finish ed 5

modes would be proposed to be classified as shown. 6

Sabbath mode, because it's primary function is to hold 7

food warm or potentially even prepare it at lower 8

temperatures, it would

-- or DOE believes it would be 9

considered part of active mode. And therefo re, for 10

the purposes of today's rulemaking, is not proposing 11

amendments to define or measure energy consumption in 12

that mode. 13

Again, I would like to invite comments on 14

the establishment of inactive mode and cycle finish ed 15

mode as standby modes and that th e determination that 16

delay start mode and Sabbath mode would be part of 17

active mode for cooking products. And, again, if 18

there are any additional modes that haven't been 19

identified and represent significant energy use, I 20

would like to invite comment on th at. 21

MR. BROOKMAN: Jennifer. 22

MS. CLEARY: Jennifer Cleary. AHAM agrees 23

that delay start mode should be considered active mode 24

and believes that cycle finish ed mode should also be 25Executive Court Reporters (301) 565

- 0064 46

considered in the active mode and we'll provide more 1

details in our writte n comments. 2

MR. BROOKMAN: Do you have a comment on 3

Sabbath mode? 4

MS. CLEARY: Not at this time. 5

MR. BROOKMAN: Thank you. 6

Okay. 7

MS. REICH: There are additional modes that 8

are defined within the FDIS version of IEC 62301 that 9

DOE has considered also . Two of them, the first being 10

network mode, the FDIS defines that as any product 11

mode where the energy

- using product is connected to 12

the main power source and at least one network 13

function is activated such as reactivation via network 14

command or network integrity communication, but the 15

primary function is not active. 16

The FDIS also includes a definition for 17

disconnected mode where essentially the main power 18

source is removed or interrupted to the product. 19

DOE is not proposing to incorporate 20

definitions o r methodology for these modes into the 21

covered test procedures. For network mode DOE is not 22

aware of any products or any dishwashers, 23

dehumidifiers, or conventional cooking products that 24

currently have a networking function incorporated in 25Executive Court Reporters (301) 565

- 0064 47

them and theref ore is unable to determine appropriate 1

methodology for testing energy use in that mode. 2

For disconnected mode, because there is no 3

energy use at all, DOE believes that this mode is 4

irrelevant for the purposes of measuring standby and 5

off

- mode power. 6

We c ertainly invite input on whether 7

dishwashers, dehumidifiers or conventional cooking 8

products are available with a network mode and whether 9

definitions and testing procedures for network mode 10

should be incorporated in the test procedures. Also, 11

DOE invites comment on the appropriate methodologies 12

that would be used to measure energy use in network 13

mode for those products as well as data. 14

MR. BROOKMAN: Jennifer. 15

MS. CLEARY: Jennifer Cleary. AHAM agrees 16

that there are currently none of these products on the 17

market that have network mode and that there's no way 18

to gather data. There's also not a test procedure 19

currently for measuring that energy and so, you know, 20

we agree with DOE's determination not to act at this 21

time. However, you know, once data does become 22

available, we would, you know, urge you to act and we 23

will certainly be glad to provide data once we have it 24

on this topic. 25Executive Court Reporters (301) 565

- 0064 48

MR. BROOKMAN: Thank you. Joanna. 1

MS. MAUER: Joanna Mauer. So we're also not 2

aware at the current time of any of these products 3

that are on the market that have a network function. 4

Although certainly at least for dishwashers looking at 5

manufacturing and marketing materials we'd certainly 6

expect to see dishwashers come onto the market very 7

soon with network functionality. And so we're 8

concerned if this additional energy consumption is not 9

captured in all the test procedure. And we certainly 10

recognize the challenge of developing a test procedure 11

at this point in time that captures the energy use of 12

a product when it's actu ally connected to a network. 13

But we understand that it's likely that products with 14

network capability will likely be consuming some 15

amount of power continuously regardless of whether 16

they're actually connected to a network. And this 17

power consumption may in fact represent the majority 18

of the energy consumption associated with the network 19

functionality. 20

So we encourage DOE to capture any of the 21

standby energy consumption associated with network 22

functionality in the inactive mode test. And I would 23

imagi ne that it would be captured in the inactive test 24

unless the network capability would actually be 25Executive Court Reporters (301) 565

- 0064 49

disconnected somehow when the product was being 1

tested. 2

We would also encourage DOE to establish a 3

definition for inactive mode that is sufficiently 4

broad so as to capture any of this standby consumption 5

that's associated with a network functionality that a 6

product would consume regardless of whether it's 7

actually connected to a network. 8

MR. BROOKMAN: Okay. Thank you. 9

Jennifer. 10

MS. CLEARY: This is Jennif er. I just want 11

to respond a little bit because I think AHAM might 12

have a slightly different view as to if network mode 13

were to be incorporated by DOE where it should go. 14

AHAM does not support including it as a standby or off 15

mode. The network mode and the energy use associated 16

with smart appliances would be a distinct mode and 17

should be treated as such. And, you know, we would be 18

glad to provide more comments should that be a 19

consideration that DOE has. 20

MR. BROOKMAN: Okay. Thank you. 21

Is network mod e

-- well

-- 22

(Laughter.) 23

MR. BROOKMAN: I won't even go there. Okay. 24

Okay. Additional comments on this subject? 25Executive Court Reporters (301) 565

- 0064 50

(No response.) 1

MR. BROOKMAN: Okay. 2

Wes Anderson. 3

MR. ANDERSON: DOE is interested in AHAM 4

giving us some of your thoughts as to how to 5

distinguish the difference between the two or the 6

three different modes or the various modes that we 7

have sort of from a principles perspective, how you 8

look at it, all of the products, and then if you want 9

to do specific products, that's great. Th at would be 10

even better. And also, maybe if you can explain the 11

differences

-- if we choose to make it as a standby 12

and you say it should be active, but it's being 13

captured, why the distinction is such a concern. 14

MS. CLEARY: I just want to make sure I 15

u nderstand what you're looking for so we can provide 16

it for you. You're not talking with regard to network 17

mode now, you mean generally all of the modes we've 18

been discussing this morning? 19

MR. ANDERSON: Well, the first half of my 20

question was about the m odes, how you determine what's 21

what. I'm sure you have a philosophy or a principle 22

behind that or

-- 23

MR. BROOKMAN: Something like a taxonomy or 24

a hierarchy, a descriptor; right? 25Executive Court Reporters (301) 565

- 0064 51

MS. CLEARY: Uh

- huh. 1

MR. ANDERSON: He went to private school, I 2

went t o public school. 3

(Laughter.) 4

MR. BROOKMAN: No, I went to public school. 5

(Laughter.) 6

MR. ANDERSON: And my other question is, if 7

you can explain to me the difference

-- where you 8

differ with DOE, why you feel that's a better capture 9

of that energy usa ge. 10

MS. CLEARY: Yeah, we absolutely will 11

provide that. 12

MR. BROOKMAN: Good. That's good. Okay. 13

Thank you. Other comments on this before we 14

move on? 15

(No response.) 16

MR. BROOKMAN: Okay. 17

MS. REICH: I saw on the agenda we're 18

supposed to take a b reak, but I think we should 19

probably just press on. 20

MR. BROOKMAN: If we could just do one more 21

segment. 22

MR. ANDERSON: What we were going to do is 23

see if there were any questions during the break. 24

MR. BROOKMAN: Okay. 25Executive Court Reporters (301) 565

- 0064 52

MR. ANDERSON: Do you want to g o another 1

section and then take a break and then we'll see

-- 2

MS. REICH: Totally up to you, however you 3

would like to do it. 4

MR. BROOKMAN: Yesterday we did one of these 5

meetings and Eric was able to field the questions real 6

time as they came on via th e web and pass them to us 7

for consideration. So there's a section in the agenda 8

for that. We'll see if we need it. Okay. 9

MS. REICH: The next section now gets into a 10

discussion of the actual methodology that is proposed 11

for measuring standby mode and off

- mode energy. DOE 12

proposes test procedures for measuring the power 13

consumption in the products in all standby and off 14

modes. So these proposed amendments include 15

provisions for measuring energy use in cycle finish ed 16

mode for dishwashers and conventio nal cooking products 17

as well as off

- cycle and bucket ful l or remove d mode 18

for dehumidifiers. 19

So what I'm going to step through next are 20

the provisions from IEC 62301, first edition, that DOE 21

is proposing to use for the measurement methodology. 22

The firs t is paragraph 5.3.1 that has 23

different measurement techniques depending on whether 24

the power consumed by the product is stable or 25Executive Court Reporters (301) 565

- 0064 53

unstable. Pardon me. And this is not

-- the 1

stability is not referring to the power supplied to 2

the unit. It's the power t hat would be consumed by 3

the unit. So the definition for stability is that the 4

power consumption does not vary by more than 5 percent 5

from a maximum level during a five

- minute measurement 6

period. And if that's the case, then the product 7

would sit for fiv e minutes to stabilize and then the 8

power could be measured at the end of an additional 9

time period of at least five minutes. This can be an 10

instantaneous power measurement. It does not have to 11

be an average measurement. 12

However, if the power is unstable, meaning 13

that it varies by more than 5 percent from the maximum 14

during a five

- minute period, then the provision would 15

require that power be measured for or averaged over a 16

duration of at least five minutes. Or if there is an 17

operating cycle, that one or more complete cycles be 18

included in that measurement period. 19

DOE wants to make clear that these 20

provisions don't preclude manufacturers if they feel 21

it's appropriate to test products with a longer 22

stabilization period or a longer measurement period, 23

these just provide the minimum values. 24

On certain products including some 25Executive Court Reporters (301) 565

- 0064 54

dishwasher and conventional cooking products, these 1

products may be equipped with a feature that 2

automatically powers down or, for example, dims a 3

dis play, after a certain period of user inactivity. 4

And for those units DOE is proposing to incorporate 5

the provision that's discussed in Section 5.1 note 1 6

of 62301 which is that the standby and off

- mode tests 7

would be conducted after that power level has d ropped 8

to its low power state. 9

Testing has been performed to determine how 10

long it typically takes for a product to get into that 11

low

- power state. And so during its tests of all of 12

these products typically the higher power state is 13

found to persist for less than 10 minutes of user 14

inactivity. And DOE believes that as a result the 15

product likely spends most of its time at the lower 16

power state and therefore that level would be most 17

representative of actual use. 18

DOE recognizes it's possible that this was 19

based on its test sample, but some products may in 20

fact have a longer duration, higher

- power state so 21

that they would exceed the five

- minute stabilization 22

and five

- minute test period that's specified in 62301. 23

DOE noted that in the CDV version of 6230 1 24

it updated that specification

, increased both the 25Executive Court Reporters (301) 565

- 0064 55

stabilization period and measurement period so that 1

now the stabilization period would be thirty ( 30 ) 2

minutes and the measurement period would be no less 3

than 10 minutes. 4

This was significantly changed in the FDIS 5

revision. It establishes an overall test period of 6

not less than 15 minutes, but provides quite detailed 7

requirements on potential extension of that test 8

period. In particular, if the mode being tested is 9

not cyclic, that is power consumption varying 10

repeatedly over a certain period of time, the first 11

third of the period of the measurement period would be 12

considered the stabilization period and the remaining 13

two

- thirds would be looked at to determine

-- to test 14

whether the power is stable. An d that this total 15

duration of the test period would be extended 16

potentially continuously until those criteria reached 17

up until a maximum of three hours. 18

For modes that vary, but don't cycle 19

regularly, they would follow the same test procedure, 20

but the tot al test period has to be at least 60 21

minutes. It can't be as low as 15 minutes. 22

And, finally, the FD IS has requirements that 23

cyclic modes use an initial stabilization period of at 24

least 10 minutes and that the power must be averaged 25Executive Court Reporters (301) 565

- 0064 56

over at least four co mplete cycles. 1

DOE considered both of those requirements, 2

both the

-- or all three, the existing methodology in 3

the first edition, CDV, and the FDIS versions. DOE 4

believes that it has tentatively concluded that the 5

CDV version for these products would l ead to the most 6

accurate, repeatable and enforceable power 7

measurements. It would be

-- it would potentially 8

cover those situations where to ensure that the 9

product went from the higher power state to the lower 10

power state, but the FDIS version is so broa d and is 11

potentially open to interpretation about how long the 12

test period should be extended that DOE believes that 13

the provisions in the CDV that the 10 minute

-- I'm 14

sorry, the 30

- minute stabilization and the 10 minute 15

test period would be the most repe atable and 16

enforceable, repeatable from manufacturer and test lab 17

among each other. 18

So, the provisions are intended to allow all 19

products to reach the lower power state
, including 20

allowing sufficient time for displays that dim to go 21

to their lower intensi ty. DOE recognizes that some 22

products can alter the display setting via user input 23

to increase how long they stay at that higher power 24

state. 25Executive Court Reporters (301) 565

- 0064 57

DOE believes, however, that most consumer s 1

will maintain a default setting and is not proposing 2

any additional provisions to address a possibility 3

that the consumer could extend that higher power 4

state. 5

I'd like to invite any comments on the 6

suitability of using the default settings in testing 7

standby energy consumption and on any methodologies 8

that it can account for consumer actions that might 9

increase energy use and data on repeatability of these 10

test procedures. 11

MR. BROOKMAN: Jennifer. 12

MS. CLEARY: Jennifer Cleary. Based on 13

paragraph 5.2 of IEC 62301, the FDIS version, AHAM 14

agrees that the appliance should be tested at the 15

factory o r default settings and that where there are 16

no indications for those settings, the appliance shall 17

be tested as shipped. 18

MR. BROOKMAN: Okay. Thank you. 19

Other comments on default settings? And 20

we're okay on line; right? No questions so far. 21

Let me encourage those of you that are 22

joining us via the web, we are trying to answer 23

questions if you have them. So, feel free to ask 24

them. 25Executive Court Reporters (301) 565

- 0064 58

MS. REICH: Okay. 1

MR. BROOKMAN: Do you want to take a break 2

now? 3

MS. REICH: I think we

-- I'm fine 4

proceeding on, if everybody else is. 5

MR. ANDERSON: I think we need a break. 6

MR. BROOKMAN: Let's take a break. 7

I think let's take a break. It's now almost 8

10:25, so let's take a 15

- minute break which me ans we 9

will resume at 10:40. I think all of you that are 10

used to being in this building

-- 11

(Brief recess taken at 10:23 a.m.) 12

(Meeting resumes at 10:45 a.m.) 13

MR. BROOKMAN: We had a request during the 14

break to see if we could identify those individual s 15

that are calling in via the web. And I've asked Eric 16

to read off their names so we know who is on the line. 17

MR. JONES : Yeah, we have 13 people on the 18

webinar. We have Ashley Byrd, Phisha Condu (ph), 19

Daniel Young, Dennis Pointer, Derek D ao , J. B. Hoyt , 20

Jonathan King, Junghung Kong, Lincoln Billings, Martin 21

Vink, Max Welband, Roger Hetler, and Steve Harquist. 22

MR. BROOKMAN: Okay. Thank you. 23

So we're going to resume with Judy Reich. 24

And I believe we're on slide 38. 25Executive Court Reporters (301) 565

- 0064 59

MS. REICH: Actually I'd like to, before we 1

go to slide 38 want to step back to the last request 2

for comment. 3

MR. BROOKMAN: Yes. 4

MS. REICH: I made a note to myself that not 5

listed on here was a

-- to request input on the 6

measurement and stabilization periods. And I forgot 7

to mention that previously and just wanted to provide 8

an opportunity if anybody had inputs on that topic to 9

allow them to speak now. 10

MR. BROOKMAN : Measurement of stabilization 11

what? 12

MS. REICH: The measurement period and 13

stabilization period, the 10 minutes and 30 minutes. 14

MR. BROOKMAN: So comments on that? 15

Yeah, Joanna. 16

MS. MAUER: Joanna Mauer. I actually had a 17

-- I was wondering if I could ask a question going 18

back to the section on definitions. 19

MS. REICH: Uh

- huh. 20

MS. MAUER: And specifically, DOE is 21

pro posing that for cycle finished mode that that would 22

only include power consumption of a continuous 23

display, I believe. And I was just wondering, I 24

guess, partly in the testing that DOE has done on 25Executive Court Reporters (301) 565

- 0064 60

products whether you've seen additional energy

1

consuming f eatures in cycle finish ed mode such as a 2

fan in an oven or have you

-- are you aware of other 3

energy

- consuming features that would be present in 4

cycle

- finished mode? 5

MS. REICH: I don't believe so based on the 6

range of power levels that were measured for the 7

various products. I don't think that there were 8

anything other than the typical display indicator 9

lights or display graphics that were associated with 10

that. 11

MS. MAUER: And I think we'd encourage DOE 12

to adopt a broader definition for cycle

- finished m ode 13

that would capture any energy consuming features that 14

are present at the end of an active cycle to capture 15

anything that's either in products today or that might 16

be introduced in the future just so if additional 17

features are introduced they're captured in that cycle 18

finished mode. 19

MR. BROOKMAN: Thank you. 20

MR. BROOKMAN: Natas c ha. 21

MS. MILESI

- FERRETTI : Yes, Natas c ha Milesi

22

Ferretti from NIST. I can say that leading up to the 23

2003 rulemaking NIST tested some dishwashers and one 24

of the products that w e tested did have a fan that 25Executive Court Reporters (301) 565

- 0064 61

would continue to run after the dishwasher had 1

indicated that the cycle was finished

-- clean. 2

MR. BROOKMAN: Thank you. 3

Okay. 4

MS. REICH: Okay. Moving on now I will 5

discuss the proposed amendments to address the test 6

roo m conditions, specifically ambient temperature. 7

IEC 62301 provides for an allowable range of 8

ambient temperatures for standby and off mode testing, 9

specifically 73.4 degrees Fahrenheit plus or minus 10

nine degrees. All of the

-- pardon me

-- the 11

dishwashe r and dehumidifier test procedures include 12

ambient temperature requirements that fall within that 13

range. So that under the existing conditions that 14

manufacturers are already testing to, they could, if 15

they chose to, conduct standby and off

- mode tests 16

simu ltaneously with active mode tests on separate 17

units so that they could do it in the same test room. 18

For conventional cooking products, those two 19

temperature ranges overlap. The test procedure, the 20

DOE test procedure, requires an ambient temperature of 21

77 degrees plus or minus nine (9) degrees. So if a 22

manufacturer was interested in conducting testing in 23

the same room then they would need to ensure that in 24

order to meet both criteria that the ambient 25Executive Court Reporters (301) 565

- 0064 62

temperature would fall between 68 and 82.4 degrees 1

Fahr enheit. 2

We would like any input you may have on the 3

appropriateness of these proposed ambient temperature 4

ranges for each of the products geared towards the 5

possibility of allowing manufacturers to conduct 6

standby and off

- mode testing either separately or in 7

the same test room under the less stringent ambient 8

conditions specified in IEC 62301. 9

MR. BROOKMAN: Jennifer. 10

MS. CLEARY: Jennifer Cleary. AHAM actually 11

believes that the DOE's more stringent ambient test 12

room temperature should be used in all ca ses because 13

they fall within the IEC range and they will provide a 14

more accurate, repeatable and reproducible result. 15

And that comment applies to dishwashers and 16

dehumidifiers. We're still working on cooking 17

products where the range does not entirely fal l within 18

that IEC range. So we'll provide more comments on 19

that in our written comments. But for the other two 20

products where the range does fall completely within 21

the IEC range we think that should just be used for 22

both cases. 23

MR. BROOKMAN: Okay. Tha nk you. 24

Yes, Brice. 25Executive Court Reporters (301) 565

- 0064 63

MR. BOWLEY: I had a comment regarding the 1

ambient

-- actually the ambient humidity for the 2

dehumidifiers being that if we're measuring an off

3

cycle mode and if it's measured to the DOE 4

temperature, humidity the humidifier

-- dehumidi fier 5

will likely never turn off because of the humidity in 6

the room. So there needs to be additional

-- if the 7

off cycle were to be tested as a standby mode, there 8

needs to be separate test conditions specified and a 9

test procedure on how to set up the un it to, you know, 10

actually evaluate an off cycle. 11

MR. BROOKMAN: Okay. Did you get that? 12

MS. REICH: Yes. 13

MR. BROOKMAN: Okay. 14

MR. ANDERSON: I have a question. This is 15

Wes Anderson, Department of Energy. Where AHAM 16

disagrees with our temperature ranges, are you are 17

still in flux with that determination, we would also 18

request that if you could explain if given those 19

different ranges would that show any significant 20

additional energy expended by that appliance. 21

MS. CLEARY: Okay. We'll think about that. 22

MR. BROOKMAN: I just want to make sure

-- 23

did you finish what you had to say, Brice? 24

MR. BOWLEY: Yes, I did. 25Executive Court Reporters (301) 565

- 0064 64

MR. BROOKMAN: Okay. Thank you. 1

MS. REICH: Okay. Yes, and I understood

-- 2

I believe something similar was done for room air 3

conditio ners for exactly that same sort of reason to 4

ensure that

-- 5

MR. BOWLEY: I think this is a little 6

different situation

-- oh, I understand. 7

MS. REICH: To ensure as it's cycling off 8

the conditions

-- ambient conditions were such that it 9

would be sure to stay in the mode that you wanted it 10

while you were measuring it. 11

MR. BOWLEY: Okay. Thank you. 12

MR. BROOKMAN: Yeah. Okay. Now I got it. 13

Okay. 14

Additional comments, Mike? 15

MR. EDWARDS: Mike Edwards, BSA . In 16

response to Wes' question, if the test wa s conducted 17

at higher temperatures which would be allowed under 18

the new proposal, it could impact the rate the food

-- 19

and the rate that it falls off the dishes and the 20

sensor decisions. I don't know that it would. We 21

would have to test to determine that , but it's a 22

possibility. 23

MR. BROOKMAN: Okay. 24

MS. REICH: Maybe I can ask to clarify that. 25Executive Court Reporters (301) 565

- 0064 65

The broader temperature range is not being proposed 1

for all testing conditions. It's not being proposed 2

for active mode. So this would just allow the broader 3

c ondition for the purpose of standby mode. Okay. 4

MR. EDWARDS: Okay. Thanks for that 5

clarification. 6

**Specifications for Test Methods and Measurements** 7

**for Standby and Off Mode Testing** 8

MR. BROOKMAN: So moving on then. The next 9

topic involves the power that is supplied to the unit 10

and within IEC 62301, first edition, it contains test 11

voltage and frequency specifications but defers to any 12

existing conditions in the external

-- in an external 13

standard that would be referencing it. So, when the 14

test voltag e and frequency are not so defined, the 15

first edition states that the power supply shall be 16

115 volts plus or minus 1 percent; and 60 hertz plus 17

or minus 1 percent. 18

The three test procedures
, -- DOE test 19

procedures
, under consideration do provide 20

specifications for the power supply, but not all of 21

the detail that's provided in the first edition. So 22

the current dehumidifier test procedure specifies the 23

rated frequency, but it doesn't put a tolerance on 24

that
, an allow able frequency range. 25Executive Court Reporters (301) 565

- 0064 66

And the current conventional cooking 1

products test procedure does not specify any power 2

supply frequency requirements at all. 3

So for dehumidifiers DOE is proposing to add 4

that the allowable frequency range is plus or minus 1 5

perce nt and the power supply frequency would then be 6

added to the cooking products test procedure as 60 7

hertz plus or minus 1 percent. 8

Now we get to the situation of whether the 9

power consumption is unstable. DOE first notes that 10

it doesn't specify closely th e test method when the 11

measured power is not stable, that is the IEC 62301. 12

It states that if the power varies over a cycle, which 13

is defined as a regular sequence of power states that 14

occur over several minutes or hours, the period 15

selected to average po wer or accumulate energy shall 16

be one or more complete cycles in order to get a 17

representative value. 18

DOE is aware that on certain products, 19

particularly conventional cooking products that may 20

incorporate a clock on the display, would potentially 21

have a regular sequence of power states if the display 22

varies as a function of the time that's being 23

presented on the display. 24

So DOE conducted an investigation to 25Executive Court Reporters (301) 565

- 0064 67

determine how that power might vary over a cycle, so 1

that additional clarification can be added to the 2

provisions from IEC 62301. DOE tested seven 3

conventional cooking products and it showed that that 4

standby power, the power consumption can vary by as 5

much as 44 percent depending on the time that's being 6

displayed, the minimum being the time of 1 : 11 and the 7

maximum being a time of 12 : 08 based upon a seven

8

segment digit for each numeral in the time. 9

So DOE realizes that this can be a 10

significant variation in power consumption and has 11

previously addressed this issue in the microwave oven 12

rulemaking and which would have a similar kind of 13

variation in clock power. And DOE conducted various 14

tests to different methods for measuring average 15

standby power when the clock time is varying. And the 16

idea was to determine whether there are methodolo gies 17

that balance the need for representative power 18

measurement with the test burden that would be 19

required of the manufacturer. 20

The gold standard is to measure over a full 21

12

- hour test period because then all possible 22

variations in the illuminated digits and thus all of 23

the different power levels would be captured and would 24

be captured on a representative weighted basis. 25Executive Court Reporters (301) 565

- 0064 68

DOE also investigated an 18

- point method 1

where 18 different times were set on the clock and the 2

power consumption at each one of those times was 3

measured. Eighteen represents the possible 4

combinations or possible number of segments in the 5

time display that can be illuminated. And so DOE's 6

analysis weighted the power that was measured at each 7

one of those points by how often that partic ular 8

number of segments would be illuminated over the 12

- 9

hour period. 10

And then finally DOE investigated a ten

11

minute method which would average the power starting 12

with a starting clock time of 3:33 because for that 10 13

minutes the distribution of segments that are 14

illuminated would be comparable to the same 15

distribution during the full 12

- hour test period. 16

So I'm going to present the results that 17

were obtained for the microwave oven testing because 18

DOE believes that this represents a comparable 19

situation for conventional cooking products. 20

The tests that DOE conducted were based on 21

11 units that had three different types of displays, a 22

liquid crystal display, a light emitting

- diode and a 23

vacuum fluorescent display, VFD. 24

And so the first column displays the average 25Executive Court Reporters (301) 565

- 0064 69

standby watts that were measured over the full 12 1

hours and then the two

-- the two sets of columns to 2

the right of that show both the power that's measured 3

and how that varies by

-- or by what percent that 4

measurement varies from the 12

- hour r eference value. 5

And it can be seen that the 18

- point method comes 6

quite close. It's less than 1 percent variation among 7

all of the units from what was measured over 12 hours. 8

The ten

- minute method also came close. 9

There is one data point that you can see on the lower 10

right that was somewhat out of line, but DOE believes 11

that's not representative. It was a condition in 12

which the unit that was being tested was subject to 13

power

-- supplied power that was very different than 14

120 volts. So discounting th at, DOE observes that the 15

ten

- minute method produces results that are within 2 16

percent of the results that are obtained from the 12

- 17

hour methodology. 18

Because this represents a significantly 19

lower test burden, DOE is proposing that that ten

20

minute method b e used in which the measurement period 21

would occur when the clock was displaying 3:33 and 22

would continue until a clock time of 3:42

. 23

The test procedure additionally allows a 24

stabilization period prior to that measurement period 25Executive Court Reporters (301) 565

- 0064 70

because it's recognized t hat the very act of setting 1

the clock display can put a product into a higher 2

power state. The display may be illuminated brighter 3

and so that if you didn't wait for it to drop to the 4

dimmer or lower power state, it wouldn't be a 5

representative measuremen t. So the proposed amendment 6

would actually require the time to be set to 3:23, a 7

ten

- minute stabilization period be observed and then 8

once the clock reached 3:33, the ten

- minute 9

measurement period would commence. 10

So, DOE believes that this methodology would 11

supersede the measurement of clock energy consumption 12

that's currently provided in the conventional cooking 13

product test procedure because this ten

- minute test 14

period would account for all standby

- mode and off

- mode 15

energy consumption including the c lock energy 16

consumption which would be incorporated currently into 17

the annual energy consumption and energy factor 18

calculations. 19

MR. BROOKMAN: I think we'll just pause 20

there. Questions or comments on this before we move 21

on? 22

MS. REICH: Actually, I thin k that's the 23

next

-- oops, sorry. 24

(No response.) 25Executive Court Reporters (301) 565

- 0064 71

MR. BROOKMAN: Okay. Then, let's just 1

proceed. 2

MS. REICH: Okay. There is a possibility 3

that if a methodology

-- an alternative methodology 4

from the 12

- hour measurement was used, that a product 5

could be designed or programmed so that the behavior 6

of the display was altered when it detected the test 7

conditions. For example, if it were the 18

- point 8

measurement, it could, at those 18 specific times the 9

display could dim or it could simply, if it's the ten

10

minute method, it could be dimmed between 3:33 and 11

3:42. So for that reason DOE is proposing that 12

manufacturers have the option at their discretion of 13

conducting either the full 12

- hour test or this 14

abbreviated ten

- minute test or both. 15

However, for the purposes of enforcement, 16

DOE reserved the right to use either or both tests 17

with the requirement that the test results between the 18

two must agree within 2 percent. If they don't agree 19

within 2 percent, then the 12

- hour test would be used 20

to determine com pliance. 21

We have an extraneous view on the screen 22

here. Is it okay if I

-- right there? Okay. Thanks. 23

So, again, we're seeking comment on whether 24

that ten

- minute methodology is an acceptable 25Executive Court Reporters (301) 565

- 0064 72

alternative to the 12

- hour test and DOE is requesting 1

commen t on the requirement that the results that would 2

be obtained under this ten

- minute methodology would 3

agree within 2 percent with the 12

- hour test results. 4

And if that criteria is not appropriate, whether 5

there's information on a more appropriate criteria. 6

MR. BROOKMAN: Jennifer. 7

MS. CLEARY: I just want to

-- Jennifer 8

Cleary. I just want to start with comments on the 9

ten

- minute measurement methodology. AHAM supports 10

that. I think, you know, DOE is going on the right 11

path there. We might state thoug h that after setting 12

the clock, the time that it takes to go back to the 13

lowest power consumption mode may vary for each 14

product just based on product design. And so it may 15

make more sense to set the clock to 3:33 minus the 16

number of minutes needed to ret urn to the power

-- 17

lowest power consumption mode. Each manufacturer will 18

readily be able to know how much time that is for 19

their unit. And so that may be a preferable method 20

and we can certainly provide more detail on that in 21

our written comments. 22

With regard to the DOE using one or both, 23

the 12

- hour method or the ten

- minute method, and 24

requiring each to be within 2 percent of each other, I 25Executive Court Reporters (301) 565

- 0064 73

think we just have a question about enforcement

-- how 1

enforcement testing would go. So would DOE, for 2

example, t ake into consideration if the manufacturer 3

chose to use the ten

- minute method and DOE chose to 4

use the 12

- hour method, would DOE be taking into 5

account that inherent 2 percent difference when 6

considering enforcement action? 7

So, for example, if the result s were 2 8

percent more than the energy standard, would that be 9

taken into account that that could be because of the 10

difference in the methods that were used? 11

(Pause.) 12

MR. ANDERSON: This is Wes with DOE. That's 13

a question you might want to go ahead and pose it to 14

us and we could address that with the enforcement 15

committee and let them see where they stand on that. 16

MS. CLEARY: Okay. I think it's really 17

critical because as we are entering, you know, a time 18

when there will be increased enforcement testin g, 19

higher energy efficiency standards, for many products, 20

it's important that the regulated industry is able to 21

be as precise as possible and able to match what DOE 22

will be doing for enforcement purposes. And so I 23

think clarity on that point is essential. And, you 24

know, if that won't be taken into consideration 25Executive Court Reporters (301) 565

- 0064 74

effectively that means that everyone is going to need 1

to use the same test and that may put unnecessary 2

burden, costs, et cetera, on these tests. 3

So we would certainly say that whatever you 4

expect the manufacturers to do during testing should 5

be mirrored with what DOE is doing in its enforcement 6

testing and that's, you know, provide the most 7

certainty and clarity for all parties involved. 8

MR. BROOKMAN: Eric Stas. 9

MR. STAS: Eric Stas, DOE. Thanks for that 10

comment. But I wanted to point out one thing that the 11

enforcement folks, you know, wanted to stress is that 12

if the manufacturers are doing both a ten

- minute test 13

and a 12

- hour test, your batch of testing that you 14

submit for certification compliance purposes has to be 15

from one test. Like either the ten

- minute or the 12

- 16

hour, that there shouldn't be mixing and matching of 17

units from the two tests for the results you submit. 18

MS. CLEARY: Right. And I think we 19

understood that. The questio n is just, if you 20

submit 10 and DOE uses 12, that's where the

-- 21

MR. STAS: I know. 22

(Simultaneous conversation.) 23

MR. STAS: That's a separate point I wanted 24

to make. 25Executive Court Reporters (301) 565

- 0064 75

MS. CLEARY: Okay. Great. Thank you. 1

MR. ANDERSON: Actually a submission should 2

m ake explanation of how the test procedure was done, 3

an explanation as to what method was used should 4

accompany any submissions. So that would clear up a 5

lot of questions. This is Wes with the Department of 6

Energy. 7

MR. BROOKMAN: Thank you. I have recei ved a 8

comment from someone who is participating in the 9

webinar and this is from Max Wilband, "LG Electronics 10

would like to comment that this analysis in energy 11

consumption metric should only be valid for seven 12

segment clock displays. Other displays may ex ist 13

which have a screen of pixels where the energy 14

consumption of the display would be dependent on 15

factors such as the font of the numbers displayed. 16

So it's another take on how the display 17

might be configured. 18

MS. REICH: Okay. Thank you. 19

MR. BROOKMA N: Yes, Joanna. 20

MS. MAUER: Joanna Mauer. I think I'll just 21

comment that I think the DOE proposal seems to be 22

reasonable in terms of trying to limit manufacturer 23

test burden, but also in the same time, you know, 24

trying to prevent any potential gaming th rough the 25Executive Court Reporters (301) 565

- 0064 76

proposal for the enforcement testing, I think it seems 1

to balance those two concerns. And I was also 2

wondering whether any of the manufacturers might be 3

able to comment on whether or why a product might need 4

more than 10 minutes of a stabilizati on period. 5

Whether that ten

- minute stabilization period would be 6

adequate or whether products would need more time? 7

MR. BROOKMAN: A moment ago Jennifer said 8

that different products have different requirements, 9

different

-- right? 10

MS. CLEARY: Right. W hich didn't 11

necessarily mean more. 12

MR. BROOKMAN: Yeah. 13

Okay. Let's proceed. 14

**Calculation of Energy Use Associated with Standby** 15

**Mode and Off Mode** 16

MS. REICH: The next section is fairly 17

meaty. It is the calculation of energy use associated 18

with standb y and off mode. And in this section I'm 19

going to talk about estimates that are made for how 20

long each product spends on an annual basis in each 21

mode coupled with typical power levels associated with 22

that mode. How that then contributes to all of the 23

energy use that the product uses on an annual basis. 24

I think I want to emphasize as I'm starting 25Executive Court Reporters (301) 565

- 0064 77

to go through this that the calculation of energy use 1

in each mode is done to determine the relative 2

importance of various modes. It doesn't necessarily 3

mean because all modes are presented that DOE is 4

proposing that all of them be necessarily measured. 5

Okay. For dishwashers the current energy 6

conservation standard is based on an average annual 7

energy use. There is also an additional metric that 8

is defined and was the basis of previous standards 9

which is an energy factor or energy used per 10

dishwasher cycle. Based on the requirements of EISA 11

DOE is proposing to incorporate the energy used in 12

standby and off mode into the calculation of the 13

estimated annual energy use. So wh at DOE has done in 14

the following analysis is to determine the annual 15

standby and off mode energy use expressed in kilowatt 16

hours per year that could be incorporated into that 17

existing metric. 18

As we discussed previously there is a 19

standby power calculation currently in the dishwasher 20

testing procedure and it results in a calculation of 21

annual standby energy consumption. DOE is proposing 22

to maintain the current calculation of active mode 23

hours per year, based on average wash cycle time, 24

multiplied by the ex isting provision of 250 cycles per 25Executive Court Reporters (301) 565

- 0064 78

year, and to distribute any remaining non

- active, non

1

washing mode hours between the appropriate standby and 2

off modes. And I think maybe this will help make it a 3

little more clear. 4

Let's talk about active mode first. The 5

test procedure, again, assumes that there are 250 6

dishwasher cycles used annually and back in the early 7

stages of the last dishwasher standards rulemaking in 8

the advance notice of proposed rulemaking in November 9

of 2007, DOE estimated that a typical cycle time for a 10

dishwasher is one hour. So, therefore there would be 11

215 hours per year associated with that active washing 12

mode. 13

DOE found very limited consumer

-- 14

MR. ANDERSON: Excuse me, Judy, this is Wes 15

of DOE. I might have misheard or you mean 215

-- 16

MS. REICH: Did I

-- I'm sorry. 17

MR. ANDERSON: I just want to, for the 18

transcript

-- 19

MS. REICH: Okay. 200

-- okay. Yes, thank 20

you. It's 215 hours. 21

MR. ANDERSON: I might have heard 250. I 22

don't know. I'm not sure. 23

MS. REICH: Okay. 24

MR. ANDERSON: I am losing my hearing. 25Executive Court Reporters (301) 565

- 0064 79

MS. REICH: So there was very little data 1

that DOE was able to find on consumer usage patterns 2

that would allow it to estimate the number of hours 3

spent in the other modes. There was a study or data 4

developed by the IEC that looked at a very small 5

sample. I think it was 79 households in the UK and 6

Germany and Italy and it looked at not just active 7

mode, but also delay start and cyc le finished mode. 8

And so some of these estimates were based upon that. 9

And the hours that were spent

-- I'm sorry, the power 10

levels in each mode for the active mode were based 11

upon an equivalent baseline energy factor for a 12

dishwasher under the current s tandards with a .65 13

energy factor, results in a 1540 watt typical power 14

use per cycle. So the total annual energy associated 15

with the washing would be 331 kilowatt hours. 16

The other power levels were those that were 17

measured in DOE's test sample. There were 14 18

dishwashers that were subjected to standby and off 19

mode power tests. And you can see the 1.9 1 for delay 20

start watts, 1.56 watts for cycle finish ed and up to 21

.69 watts for either off or inactive mode. 22

So you can see the relative contributions of 23

e ach of these to the total annual energ y use if these 24

were integrated together. 25Executive Court Reporters (301) 565

- 0064 80

Some of them are very low, almost negligible 1

contributors to annual energy use. 2

MR. BROOKMAN: Joanna. 3

MS. MAUER: Joanna Mauer. Just a couple of 4

quick questions. The t ypical power for the off and 5

inactive mode, is the .69 watts, is that the maximum 6

power consumption of all the units? 7

MS. REICH: In the test sample; yes, 8

correct. 9

MS. MAUER: And for delay start and cycle 10

finish ed those are average power consumption acr oss 11

the units that were

-- 12

MS. REICH: Yes. Yes. And the reason

-- 13

actually, maybe I had better verify this. The range 14

is provided in off and inactive because in off mode 15

the unit could have zero watts. And I believe that 16

the .69 may be an average of those that went into 17

inactive mode. I don't think that it was the maximum 18

value. 19

PARTICIPANT: It's not the full range, yeah. 20

MS. REICH: That's right. So the .69 would 21

be comparable for those units that are in active mode, 22

it would be an average of t he units that had it 23

similarly to what's done with delay start and cycle 24

finished. 25Executive Court Reporters (301) 565

- 0064 81

MS. MAUER: Okay. And then is it possible 1

to comment at all on the range of measured values for 2

the different modes that you saw in the testing how 3

much variability there was? 4

MS. REICH: We do have that data available. 5

MS. MAUER: Okay. 6

MS. REICH: I don't have that now

-- 7

(Simultaneous conversation.) 8

MS. REICH: Yes, absolutely. 9

MS. MAUER: Okay. Thank you. 10

PARTICIPANT: You would have to ask for that 11

directl y in a written request and we could see what we 12

could do. 13

MS. MAUER: All right. Thank you. 14

MS. REICH: Okay. So because DOE is 15

considering or proposing to consider delay start as 16

part of active mode, it is not proposing with these 17

test procedure amendments to define or measure energy 18

consumption associated with delay start. However, 19

because DO E recognizes that is a certain amount of 20

annual energy use that should be captured by the test 21

procedure and because it notes that the power levels 22

in delay start are comparable to those in the off and 23

inactive mode, DOE is proposing that although it's not 24

requiring a tester to measure the power in delay start 25Executive Court Reporters (301) 565

- 0064 82

mode, it would allocate the hours that the dishwasher 1

would spend in delay start mode to the hours that are 2

accounted for in the inactive and off modes. So that 3

bumps up the total annual hours for of f and inactive 4

mode to 8,308. And so what it's doing is it's using 5

the measurement in off and inactive mode as a proxy 6

for the delay start energy use. 7

And for dishwashers that don't have a cycle 8

finish ed mode, DOE would propose to allocate the 237 9

hours associated with that mode to, again, the off and 10

inactive mode hours because anything then outside of 11

the active washing mode would be considered off and 12

inactive. 13

DOE doesn't have a lot of information on how 14

many dishwashers spend time in off mode, how m any 15

spend time in inactive mode, but it believes that 16

because that's typically associated with a type of 17

controller supplied on the product, if it has 18

electromechanical controls it likely will go to off 19

mode. If it has electronic controls, it would likely 20

go to inactive mode. But if there are products that 21

have both available, DOE estimates or has tentatively 22

assumed that the hours would be split equally between 23

the two. So it would divide those hours in half for 24

each mode. 25Executive Court Reporters (301) 565

- 0064 83

The methodology that DOE is p roposing to 1

come up with the annual energy use that's associated 2

with the inactive, off and cycle finish ed modes would 3

be to measure the wattage in the particular low

- power 4

mode and then use the allocated hours
, multiply those 5

each one by the hours that ar e allocated to that mode 6

and then add up the results and make sure it's 7

expressed in kilowatt hours. And so that gives on an 8

annual basis the energy associated with those modes. 9

Now, going back to

-- going back to this 10

chart DOE notes that delay start mo de

-- I'm sorry, 11

cycle finished mode is a very small contributor to 12

annual energy use. And so, again, to potentially 13

reduce test burden DOE, rather than requiring 14

manufacturers to measure both cycle finished and off 15

and inactive mode, DOE is proposing tha t it's a 16

reasonable representation to allocate the hours in 17

cycle finish ed mode to off and inactive mode. So the 18

only measurement that would be made would be in off or 19

inactive mode and that would allow a single 20

measurement to be used as a proxy for all o f the non

21

active hours. 22

I'm at this point going to move on to 23

dehumidifiers. I don't know if we want to stop here 24

for comment on dishwashers. 25Executive Court Reporters (301) 565

- 0064 84

MR. BROOKMAN: Let's see if there are any 1

comments on dishwashers. Anything? Jennifer. 2

MS. CLEARY: I think this is one area where 3

we start to get into questions about the data that DOE 4

is relying on. And here at least there is some data 5

with the IEC study that was used to allocate hours. 6

But I think it's questionable whether that data is 7

really representative of consumer use in the United 8

States which is what the test procedure is designed to 9

representative of. You know, products may not be the 10

same, for example. So, you know, it's something and 11

that's better than nothing, but really how valid is it 12

for acti on here is a question that we have. 13

MR. BROOKMAN: And furthermore you don't 14

know of any additional data sources that would be 15

targeted on the U.S.? 16

MS. CLEARY: Not at this time. You know, 17

we'll certainly look into it. We, of course, want to 18

help DOE where we can to provide data if we can. But, 19

again, DOE, if there is no data, in here at least 20

there's something, but, again, we question its 21

validity. 22

MR. BROOKMAN: Okay. Mike. 23

MR. EDWARDS: This is Mike Edwards. Did I 24

understand that the hours th at you put up there are 25Executive Court Reporters (301) 565

- 0064 85

the actual hours that you're planning to use or would 1

we calculate in real life usage the inactive hours? 2

MS. REICH: The test procedure is proposed 3

that the hours would be fixed in the test procedure, 4

that the numbers provided are intended to be 5

representative of all dishwashers how much time they 6

would spend in that mode. 7

MR. EDWARDS: I would think that there's 8

more data out there. When we calculate standby power 9

now, we do it by measuring the number of active hours, 10

the cycle time and then it's multiplied by 215 cycles 11

per year. So I think everything else could be 12

inactive based on what I'm understanding. 13

MS. REICH: That's the alternative approach, 14

yes. 15

MR. EDWARDS: Okay. And I think dishwasher 16

cycle times are longer than one hour now, in most 17

cases. 18

MS. REICH: Is that information that you 19

could provide in a comment what a typical cycle

-- 20

(Simultaneous conversation.) 21

MR. EDWARDS:

-- the comment, but we know 22

cycle times are getting longer. I don't know if I 23

could t ell you what the cycle times are at this point. 24

MS. REICH: Okay. 25Executive Court Reporters (301) 565

- 0064 86

MR. BROOKMAN: Yes, Joanna. 1

MS. MAUER: Joanna Mauer. I guess a comment 2

first on the proposal for allocating hours for 3

products that have both electronic controls and a 4

mechanical on/o ff switch. I think it's definitely 5

appropriate to allocate a portion of the total off and 6

inactive hours to off mode for those products with 7

mechanical switches and we would certainly like 8

manufacturers to have an incentive to actually provide 9

switches so that the products can be turned off. 10

We are just a little concerned about the 11

potential for gaming if there's no specification as to 12

where that switch needs to be placed, or, you know, 13

there certainly could be a switch placed in some

-- 14

placed on the pr oduct that's clearly not intended for 15

consumer use and that therefore would never actually 16

be in the off position. So I think that we would 17

encourage DOE to just make some kind of specification 18

as to the placement of that switch either on a front 19

panel or that it clearly be intended for consumer use 20

in order for half of those hours to be allocated to 21

off mode. 22

And then in terms of the alternative 23

proposal to allocate all the h ours to off and inactive 24

mode and not to separately measure cycle finished 25Executive Court Reporters (301) 565

- 0064 87

mode, I think we just want to be careful to think 1

about not just products that are on the market 2

currently, but what may be introduced in the next five 3

or seven years given that the test procedures are not 4

revised very often. And our concern is that if the 5

powe r consumption and cycle finish ed mode is not 6

measured, then there's no incentive to reduce power 7

consumption in that mode and that there may be 8

additional features that manufacturers introduce that 9

consume additional energy that wouldn't be captured if 10

tha t energy consumption isn't measured. I think we're 11

seeing an example of that in clothes washers where in 12

cycle finish ed mode the clothes washers are being 13

introduced with periodic tumbling or fan energy and 14

things like that may become more common in produ cts. 15

So I think we'd encourage DOE to develop a test 16

procedure that actually measures that energy 17

separately. 18

MR. BROOKMAN: And James Battaglia has a 19

comment. 20

MR. BATTAGLIA: James Battaglia (off 21

microphone). Oh, sorry. James Battaglia. I just 22

want t o clarify something that Judy said. For the 23

derivation of the standby hours it's not a fixed 24

number for dishwashers, it's based on the average 25Executive Court Reporters (301) 565

- 0064 88

measured cycle length for the active mode. So you 1

subtract the active mode hours that you measured from 2

the tot al number of hours per year to get the number 3

of standby hours. 4

MS. REICH: Okay. 5

MR. BROOKMAN: Thank you. 6

MS. REICH: Thank you. 7

MR. BROOKMAN: Okay. Good. 8

MS. REICH: Let's see, for dehumidifiers, 9

the current metric used for the standards is an energy 10

factor which is the ratio of the amount of moisture 11

removed from the air per kilowatt hour of energy use. 12

DOE is proposing to incorporate the energy used in 13

s tandby and off mode into this metric based on the 14

number of hours that a typical dehumidifier spends in 15

each mode. And, again, this was a case where there is 16

limited data available on usage patterns. There were 17

several studies looked at that ranged from, I think 18

the earliest was 1998, and the most recent was 2006. 19

These studies provide a range of estimates on an 20

annual basis for active mode operation, anywhere from 21

875 to 4,320. 22

DOE is proposing to use, as the basis of 23

this analysis, the information tha t was developed by 24

AHAM. And it had a range of estimates and DOE is 25Executive Court Reporters (301) 565

- 0064 89

considering the midrange to probably be the most 1

representative. And DOE is proposing to use that 2

dataset because this was developed in consultation 3

with manufacturers and so DOE believe s that they 4

probably understand in lieu of actual field study 5

measurements, but the manufacturers probably have the 6

best understanding of how these products are actually 7

used. 8

So on the basis of the AHAM data, DOE 9

proposes that 1,095 annual hours be att ributed to 10

active mode. 11

However, unlike some other products

, 12

dehumidifiers can actually spend some time unplugged a 13

percentage of the year. And so therefore there's no 14

energy used at all. They would not be in standby or 15

off mode. There is no informat ion that DOE could 16

locate on how much time a dehumidifier typically 17

spends unplugged, but the various surveys that were 18

mentioned on the last page indicated that there is no 19

active mode operation in the months of November to 20

March and that there are few ac tive mode hours of 21

operation in April. 22

So for that reason DOE assumes that in the 23

November to March timeframe that they are unplugged 24

for the entire time and that for half of April a 25Executive Court Reporters (301) 565

- 0064 90

dehumidifier would be unplugged leading to a total of 1

3,984 hours that a re just removed from the calculation 2

because there's no energy use at all. 3

So, since there are 8,760 hours per year, 4

subtracting out the 1,095 active mode hours and 3,984 5

unplugged hours leaves that 3,681 hours that would be 6

allocated to things other than active mode

, to 7

operating modes other than active mode. 8

So, DOE examined or estimated the typical 9

hours that a dehumidifier would spend in the bucket

10

full or removed mode and in delay start mode. The 11

bucket

- full/removed mode hours were based on a produ ct 12

that had a 25 to 35 pint per day capacity for moisture 13

removal which is based on the distribution of 14

shipments

, that this is the predominant dehumidifier 15

product class and that the analysis was based on an 16

energy factor of 1.35 which is not in fact the current 17

standard. That standard will not go into effect until 18

October of 2012. So the explanation is a little off. 19

But the number of hours that are calculated aren't 20

affected because the hours are based on how much

-- 21

what moisture is removed and that's not impacted by 22

whether it's a 1.2 or 1.35 energy factor. 23

DOE examined various products and came up 24

with a calculated average of 18.7 pints as the typical 25Executive Court Reporters (301) 565

- 0064 91

bucket size in that product class and also made the 1

assumption that consumers are not likely to emp ty a 2

dehumidifier bucket more than once per day. 3

For delay start mode hours, DOE's 4

observation in its research was that 19 percent of 5

products offer this feature and with the lack of 6

consumer usage data made a preliminary estimate that 7

half of these uni ts would have consumers using that 8

feature and that for those consumers that did use 9

delay start mode, they'd use it for 10 percent of the 10

times of the days that dehumidification is called for. 11

Further
, because the maximum delay start on 12

products with t hat capability was found to be 24 13

hours, DOE made a preliminary estimate that the 14

average time that consumers would select when they 15

chose to operate with delay start would be half of 16

that, would be a 12

- hour delay. 17

With those assumptions DOE was able to 18

estimate the typical hours spent in the delay start in 19

bucket full or removed mode and therefore would 20

allocate the remaining hours to the off

- cycle or 21

inactive mode; the remaining hours that are not 22

unplugged or active mode. The delay start, bucket 23

full and removed mode in off cycle or inactive mode 24

hours

-- I'm sorry, not hours, power, those levels 25Executive Court Reporters (301) 565

- 0064 92

were based upon DOE measurement of a test sample of 13 1

dehumidifiers; and the active mode typical power for 2

this product class was derived from the analysis t hat 3

was completed for the last standards rulemaking for 4

dehumidifiers. And the information for that is in the 5

2007 ANOPR. 6

So based on that, on the far right

- hand side 7

we see the annual energy use associated with each 8

mode. Again, you can observe that th e active mode is 9

by far larger than any of the other non

- active modes. 10

And similarly to what was discussed for dishwashers 11

because delay start mode is being assumed to be part 12

of active mode, DOE is not proposing to require that 13

mode to be measured. But, again, the power 14

consumption, the power levels there are comparable to 15

the value in the off

- cycle, inactive, and off mode and 16

therefore DOE is again allowing those or proposing 17

those hours to be allocated into the off

- cycle, 18

inactive and off mode again as a proxy for that delay 19

start energy use. 20

Okay. And that would bump up the hours for 21

the off

- cycle
, inactive

, and off modes to 3,024. 22

Because not all dehumidifiers have the same 23

capabilities

, they don't all

-- they aren't all able 24

to operate in the off

- cycle, inactive and off mode and 25Executive Court Reporters (301) 565

- 0064 93

for the same reason before as the dishwashers, the 1

lack of any further information on how to divide them

, 2

DOE is proposing to divide them evenly if a 3

dehumidifie r has the capability for operating in two 4

or three of those modes. 5

The methodology for calculating the annual 6

energy use associated with standby and off modes is 7

the same as was presented for dishwashers

, which is 8

that the watts measured in the standby or off mode and 9

the allocated hours would be multiplied together. All 10

of those contributors for the different possible modes 11

would be summed and that would be expressed in 12

kilowatt hours per year. 13

DOE, again, to offer the possibility of 14

reduced test burd en is considering an alternative 15

approach in which the off

- cycle, inactive, and off 16

modes would be the only modes measured and that the 17

hours for bucket full and removed mode would be rolled 18

up into the first set. So everything other than the 19

active mode hours would be allocated to that last set. 20

MR. BROOKMAN: So let's pause and take 21

comments here. Brice. 22

MR. BOWLEY: Yes, Brice Bowley. First of 23

all, I appreciate you looking at reducing test burden 24

with all the standby modes. One, the bucket full, I 25Executive Court Reporters (301) 565

- 0064 94

wanted to make a comment on that. Having the 1

opportunity to pull many units from the field and look 2

at

-- basically look at them for reliability one of 3

the things we found that we had not expected was that 4

about 50 percent of the units were actually conne cted 5

to a drain. So when they're connected to a drain, 6

there's no bucket full or bucket removed, they operate 7

continuously. So I had not expected it to be as high 8

as 50 percent, but that is actually what we had found. 9

MR. BROOKMAN: At the break can you tell me 10

how to do that. 11

MR. BOWLEY: Yeah. 12

(Laughter.) 13

MR. BOWLEY: But anyway, of the hours 14

allocated, based on that 50 percent, I think it's 15

actually closer

-- you know, assuming all the other 16

calculations are correct, I would say it's half of 17

what you had calculated, based on that. 18

MR. BROOKMAN: Okay. 19

MS. REICH: Okay. Thank you. 20

MR. BROOKMAN: Good. 21

(Simultaneous conversation.) 22

MR. BOWLEY: I can provide that in writing, 23

yes. 24

MR. BROOKMAN: That's good. Okay. 25Executive Court Reporters (301) 565

- 0064 95

Other comments? Jennifer. 1

MS. CLEARY: I'd like to echo the comments 2

here that I made in the beginning of our meeting 3

today. Certainly understand that DOE is trying to 4

carry out its statutory mandate, but it still needs to 5

act on a reasonable basis. And I just want t o read 6

from page 75307 of the Federal Register. 7

" DOE is not aware of any reliable consumer 8

usage data on the number of hours per year 9

dehumidifiers spend in delay start and bucket full or 10

remove d mode. In the absence of such data DOE 11

estimated the time spent on these modes in the manner 12

described below." And then the manner described below 13

consists of a series of unsupported estimations as I, 14

you know, think we saw in the slides. So this really 15

-- there's no data for all of these points here. And 16

DOE should not be acting and cannot act without that 17

data. It's arbitrary and unreasonable to do so. So, 18

you know, you asked me to point out a specific 19

situation, I think that this may be one of the more 20

glaring places where there's no data for what I just 21

d escribed, and that’s very problematic. 22

MR. BROOKMAN: Okay. 23

MR. ANDERSON: This is Wes with the 24

Department of Energy

-- Wes Anderson with the 25Executive Court Reporters (301) 565

- 0064 96

Department of Energy. Given that that's

-- the data 1

issue is stated as a problem and we have asked for 2

input fro m manufacturer s who we thought would have 3

this information, we

-- and given that we are required 4

legally to establish a standard, I'm asking AHAM to 5

either look at our

-- the way we determine our number, 6

maybe

-- do we need to explain that in more detail h ow 7

we determined these

-- how we came to our assumption? 8

Because it's

-- you know, would that be satisfactory? 9

Or do we just have to have a myriad of data to satisfy 10

your comment? 11

MS. CLEARY: I think that there needs to be 12

data. And we'll provide more detail in our written 13

comments. And certainly if we have anything to share 14

we will. I mean, we aren't going to criticize if 15

there's some way that we can help, we absolutely will. 16

But if DOE doesn't get the data that it seeks, that 17

doesn't give it the fr eedom to estimate. And, you 18

know, it should attempt to collect the data itself or 19

to ask others who might have it. You know, for 20

example, if the manufacturers don't have it, there may 21

be other third parties who have it. And, of course, 22

we would look for that as well and provide it to you 23

where we can. Or the other option is to recognize 24

that there is no data and to refrain from taking an 25Executive Court Reporters (301) 565

- 0064 97

arbitrary action. 1

MR. ANDERSON: Well, I would argue against 2

that it's arbitrary. I mean, we have a test procedure 3

- - a testing method that we use to come up with these 4

numbers and we base it on test

-- an experiment. So, 5

I mean, it's not like we just kind of say, okay, this 6

is kind of this and this is kind of that. So I would 7

like to reiterate would DOE's explanation of how it 8

derived

-- it came up with these numbers and we put 9

that out for public comment, then manufacturers can 10

comment on if it were not going in the right 11

direction. 12

MR. BROOKMAN: Eric Stas. 13

MR. STAS: Yeah, and I would add from the 14

slides that Judy put up aren't the assumptions based 15

on data from AHAM itself? 16

MS. REICH: There are quite a few 17

assumptions that were DOE estimates. Because

-- 18

specifically because there was no data available. 19

MR. STAS: And that factors into this and 20

the data is from AH AM; correct? 21

MS. REICH: Some data is, yes. 22

MS. CLEARY: And I wasn't actually 23

referencing that. And the portion I read was a 24

separate issue that wasn't based on any data. 25Executive Court Reporters (301) 565

- 0064 98

MR. BROOKMAN: Okay. Okay. So additional 1

comments on this segment? 2

Yes, Joanna. 3

MS. MAUER: Judy, could you just describe

-- 4

maybe you described this earlier, but what inactive 5

mode refers to for a dehumidifier or kind of what the 6

function is or when a dehumidifier is in inactive 7

mode? 8

MS. REICH: That would be if

-- if it is 9

just sitting with a display on, maybe an indicator 10

light on, it is not at a point where it would be

-- 11

that it would have a dehumidification level set, or a 12

humidity target set, so that it would be either active 13

or off cycle. It would be plugged in, but it wou ldn't 14

be simply activated. 15

MS. MAUER: And do you have any sense of 16

whether that's common in the field for products to be 17

in that or do manufacturer have any comments on 18

whether they'd be in

-- 19

MR. BROOKMAN: Brice. 20

MR. BOWLEY: Well, I guess I'm a litt le 21

unclear on the inactive for dehumidifiers as well. To 22

me there seems to more of an off mode which if there's 23

no external remotes that I'm aware of for 24

dehumidifiers. If there was an external remote there 25Executive Court Reporters (301) 565

- 0064 99

might be an inactive, but as it is, if it's plu gged in 1

-- well if it's plugged in and turned on, then it's 2

either in active mode or it's cycling off. So I 3

really don't

-- 4

MR. BROOKMAN: Like when the bucket is full. 5

MR. BOWLEY: Yes. 6

MR. BROOKMAN: But there's still a little 7

LED light

-- there's a little green light that kind of 8

shows you the bucket

-- or red light that shows the 9

bucket is full. 10

MR. BOWLEY: Yes, usually. 11

MR. BROOKMAN: Yeah. 12

MR. BOWLEY: But as far as the inactive, I 13

don't know exactly what that would be on the dehum. I 14

mean , I understand DOE has studied it and apparently 15

they have modes they would classify as inactive, but 16

I'm really not aware of what that would be. 17

MS. REICH: Okay. So I think what I'm 18

hearing is that you would allocate hours when it's 19

plugged in. It w ould either be operating in active 20

mode or in off cycle mode. 21

MR. BOWLEY: If it's plugged in and turned 22

on it's either in active or off cycle. 23

MS. REICH: Okay. 24

MR. BROOKMAN: James. 25Executive Court Reporters (301) 565

- 0064 100

MR. BATTAGLIA: James Battaglia. I think we 1

saw

-- in our test samp le we saw a few dehumidifiers 2

with remote controls. 3

MR. BOWLEY: So there is some. So it's 4

basically a dehumidifier with a remo t e control. It 5

would be inactive. 6

MR. BATTAGLIA: Yeah, that's one case that 7

we saw. I mean, there might be other cases that still 8

fit that definition, but that's the

-- 9

(Simultaneous conversation.) 10

MR. BOWLEY: But as far as the products you 11

looked at

-- 12

MR. BATTAGLIA: Right. 13

MR. BOWLEY: Okay. 14

MR. BROOKMAN: Okay. Other comments on 15

these dehumidifier issues? 16

(No r esponse.) 17

MR. BROOKMAN: Wes is suggesting we take a 18

very short break just to stand up and move around for 19

five minutes. This is rather dense material. We're 20

going to keep going for a while. We have about almost 21

20 page of additional stuff to go throug h, maybe 15. 22

So let's just break for five minutes. Don't go far. 23

It's chilly, move around a little bit and we'll resume 24

shortly. 25Executive Court Reporters (301) 565

- 0064 101

(Brief recess taken at 11:49 a.m.) 1

(Meeting resumes at 11:55 a.m.) 2

MR. BROOKMAN: We're going to try and keep 3

going right along here. For those of you that are 4

listening via the web, the room here at the Forrestal 5

Building is probably 68 degrees or in that general 6

range. It's a little nippy in here. And we're trying 7

to boost the heat. So those of you that are comfy in 8

yo ur offices or at home

-- 9

So let's resume and we're going back to Judy 10

Reich. 11

MS. REICH: Okay. So we have finished with 12

dishwasher s and dehumidifiers. The final product s are 13

conventional cooking products. So they are not the 14

subject of energy conserv ation standards at this time

. 15

B ut historically in analyzing them, the metric that's 16

been used and has been defined i n the test procedure 17

i s energy factor
, which is the ratio of annual cooking 18

energy output to the annual energy input . And DOE is 19

proposing to maintain this metric incorporating 20

standby and off mode energy use into it rather than an 21

annual energy use metric. 22

So, we'll talk about the usage patterns and 23

power consumption in these modes that DOE looked at on 24

an annual basis, but recognized that it's going to be 25Executive Court Reporters (301) 565

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rolled in essentially on a per

- cycle basis. 1

Ah, let's see, for conventional ovens

, DOE 2

investigated the typical time and energy consumption 3

associated with active mode as well as the other modes 4

that have been identified, namely the Sabb ath mode, 5

delay start mode, cycle finish ed mode, and off and 6

inactive mode. Again, very limited data on usage 7

patterns. For Sabbath mode
, DOE was able to 8

determine, able to locate some survey data that was 9

developed by the United Jewish Communities on th e 10

number of U.S. households that keep a kosher home and 11

on that basis as well as determining the number of 12

hours that somebody who followed kosher practices 13

would be using that feature

, came up with an average 14

of 8.9 hours that a typical oven spends in Sabbath 15

mode. 16

For delay start mode, this was an area where 17

DOE did not have information at all b ut assumes that 18

for those products that have it, that 50 percent of 19

consumers use it for 5 percent of cycles. And that 20

they would program it for typically a 12

- hour day. 21

This is a preliminary estimate based on half of the 22

maximum delay start time that's possible. 23

And, just, you know, sort of as a reality 24

check DOE notes that 12 hours is rou ghly the time that 25Executive Court Reporters (301) 565

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would be between if somebody were setting up a cooking 1

process in the morning for dinner being available when 2

they came home. 3

Cycle finish ed mode is purely a DOE 4

estimate. It was assumed to be five minutes per 5

cooking cycle. Typical ly, I think, you know, people 6

don't leave food for hours in the oven when they're 7

done. So DOE estimated five minutes. And so you can 8

see for delay start and cycle finish ed mode they wind 9

up with 61 annual hours and cycle finish ed mode was 10

18. That left 8,461 in off and inactive mode because 11

subtracting out 211 hours that were assumed from the 12

previous standards analysis to be associated with 13

active mode. 14

DOE determined typical power levels by 15

testing 12 conventional ovens. For active mode that 16

was based on measurements for a baseline efficiency, 17

electric self

- cleaning oven. The annual energy use on 18

the far right

- hand side shows very small contributions 19

from Sabbath mode, delay start mode, and cycle 20

finish ed mode and still relatively small from off and 21

inactive. 22

Actually I want to correct myself. I made a 23

note here. The 211 hours comes from RECS data, the 24

Residential Energy Consumption Survey from 2005. And 25Executive Court Reporters (301) 565

- 0064 104

that data indicates that 211 hours are spent in active 1

cooking mode. 2

Because DOE proposes to define delay start 3

mode and Sabbath mode as part of active mode and not 4

standby or off mode, it is not proposing to measure 5

the energy consumption in either of them, but instead 6

would allocate the hours that a product would spend in 7

those modes to the inactive and off mode in the case 8

of delay start and into the active mode hours for 9

Sabbath mode. 10

For those units that don't have any cycle 11

finished mode, DOE would roll those hours into the off 12

and inactive mode also. For the same reason that 13

we've alre ady talked about that it's unlikely that a 14

product would have capability for both off and 15

inactive mode, because that's typically associated 16

with the type of controls it has, but if it has 17

electronic controls and a mechanical on/off switch, 18

both modes are possible and DOE proposes to evenly 19

divide the off and inactive mode hours between the two 20

modes. 21

I won't talk about that same methodology as 22

has already been discussed several times, but how to 23

come up with the annual energy use, and that, again, 24

as an a lternative for reducing the test requirements 25Executive Court Reporters (301) 565

- 0064 105

that because of the relative

-- relatively comparable 1

power levels in cycle finish ed mode to those in off 2

and inactive mode that the cycle finish ed mode hours 3

could be rolled in so that only a single off and 4

in active mode measurement would need to be made. 5

(Pause.) 6

MS. REICH: That was it for ovens. 7

For cook tops it's a similar situation as 8

for ovens. Although, interestingly, the Sabbath mode 9

is a little different for cook tops because the 10

allowable or req uired functionality in Sabbath mode is 11

different. So you will see the typical power is much 12

higher. And that's because for a cook top the 13

requirement is that the controls

, that the heating 14

elements or burner cannot be adjusted up or down 15

during the Sabba th period. So it requires for Sabbath 16

compliant products that they be set at some low level 17

that is

-- you know, a consumer would feel safe 18

leaving it on continuously. And so DOE estimated that 19

that power level would be approximately 25 percent of 20

the ty pical power during a normal cooking process. 21

But even so, even with that higher power 22

level, because of the very small percentage of U.S. 23

households that do observe the kosher practices that 24

on average the annual energy use associated with 25Executive Court Reporters (301) 565

- 0064 106

Sabbath mode is still quite small. 1

Also want to point out that DOE is not aware 2

of any delay start or cycle finish ed mode for cook 3

tops. 4

DOE believes that the Sabbath mode is part 5

of an active mode and so is proposing to allocate the 6

Sabbath mode hours into active mode hours. And for 7

the same reasons we've heard that if it has the 8

capability for both off and inactive mode it would

-- 9

DOE proposes to split those hours evenly. And, again, 10

going through and calculating an annual energy use 11

associated with off and inactiv e modes. 12

And, by the way, in the next section I'll 13

discuss the calculations that are made that would 14

actually integrate an annual energy use into the 15

energy factor for a cooking product. 16

And finally, for conventional ranges, these 17

are essentially because they have an oven and a cook 18

top together, much of this information would be 19

comparable to the two products. The only difference 20

or the only thing I would want to point out is, again, 21

for Sabbath mode, because of the inherent difficulties 22

or greater diff icult y in using a cook top as opposed 23

to an oven during a Sabbath period that it's likely 24

that a consumer with a range that had a Sabbath mode 25Executive Court Reporters (301) 565

- 0064 107

function in the oven would use that for the cooking 1

process. 2

Here the typical powers were based on DOE 3

tests of 21 conventional ranges and that the active 4

mode power is simply assumed to be the sum of the oven 5

power and the cook top power, the typical levels. 6

So, again, delay start and Sabbath mode 7

hours would be allocated appropriately to either the 8

inactive off m ode for delay start and active mode for 9

Sabbath hours. And, again a methodology for units 10

without cycle finish ed mode, those hours would just go 11

into off and inactive mode. And if they have the 12

capability for both off and inactive, the hours would 13

be spl it evenly. 14

And, finally, I apologize for the 15

repetition, but this is the same methodology to 16

calculate from the measured watts what the annual 17

energy use in kilowatt hours would be for each mode 18

and then adding them up. And then the possibility of 19

an alt ernative approach, a more streamlined approach 20

that would put all of the cycle finished mode hours 21

into off and inactive so that a single measurement 22

would only be necessary. 23

So, I think we've already commented on 24

dishwashers and dehumidifiers. Any simil ar comments 25Executive Court Reporters (301) 565

- 0064 108

on cooking products referring to the allocation of 1

annual hours and test burden as well as the 2

alternative methodology to allocate annual hours in 3

each mode? 4

MR. BROOKMAN: Jennifer. 5

MS. CLEARY: Thanks. This would just be 6

another area where we would point to a lack of data in 7

many areas and I think that you drew them out here and 8

we'll cull out specific ones in our written comments. 9

But the comments continue in this area as well. 10

MR. BROOKMAN: Okay. Thank you. 11

Joanna. 12

MS. MAUER: Joann a Mauer. Just to reiterate 13

a couple of general comments. For all products I 14

think the case where you have electronic controls plus 15

a mechanical on/off switch, we just encourage DOE to 16

make some kind of specification regarding the 17

placement of that mechan ical switch. We would also 18

encourage DOE to develop a test procedure that 19

actually measures the energy use in all the different 20

modes that have been identified such as cycle finish ed 21

mode just to avoid any potential loopholes in the 22

future where some nont rivial energy

- consuming feature 23

wouldn't be captured in the test procedure. 24

I also had kind of a general question 25Executive Court Reporters (301) 565

- 0064 109

regarding how the hours were estimated for delay start 1

and cycle finish ed mode. Are those hours

-- or does 2

that estimate of hours include products that don't 3

have, for example, cycle finish ed mode so that it's 4

kind of a weighted average that includes products that 5

by definition have zero hours in cycle finish ed mode, 6

for example? 7

MS. REICH: No, the estimate is intended to 8

be for those prod ucts that have that capability. And 9

if the product doesn't have it, the hours would be put 10

into the off and inactive mode. 11

MS. MAUER: Okay. And I think that's an 12

appropriate methodology. It sounded to me in the 13

Federal Register notice that it may have included all 14

products, but I can

-- I'll look at that again

-- 15

MS. REICH: We can confirm that. 16

(Simultaneous conversation.) 17

MR. BROOKMAN: So then final comments on 18

this because we're going to move on. 19

(No response.) 20

MR. BROOKMAN: Measures of energy 21

consumption. 22

**Measures of Energy Consumption** 23

MS. REICH: Okay. So the regulatory 24

requirement is that the test procedures shall be 25Executive Court Reporters (301) 565

- 0064 110

amended to include standby and off

- mode energy 1

consumption into the overall energy efficiency 2

descriptor for each covered product. And this is what 3

EISA amended EPCA to require. 4

So DOE, for each of these products, examined 5

the existing measures of energy consumption to see 6

whether standby and off

- mode power could be integrated 7

into the existing metric to form a single combined or 8

integrated metric. And in doing so DOE first notes 9

that the test procedures for dishwashers and cooking 10

products already incor porate at least some form of 11

standby power into the existing metric. For 12

dishwashers there is a standby power measurement and 13

for conventional cooking products there is a 14

requirement to measure clock power. So, that provides 15

evidence that those metrics c an be expressed as an 16

integrated metric once all standby and off

- mode power 17

is accounted for. 18

So to detail that, for dishwashers, the 19

measure of standby power is already included in the 20

efficiency descriptor that's the basis of the current 21

standard whic h is estimated annual energy use or EAEU. 22

And DOE notes that the magnitude of standby and off

23

mode energy use is such that integrating it would be 24

measurable in changes in standby power, it would 25Executive Court Reporters (301) 565

- 0064 111

produce a measurable difference in EA E U s o, therefore, 1

woul d factor into any standard setting process, but is 2

not so great that it would overwhelm the effect of 3

variations in active energy

-- active

- mode energy use, 4

how that would contribute to the EAEU. 5

So, therefore, DOE believes that an 6

integrated metric is te chnically feasible and is 7

proposing amendments that would fully account for 8

standby

- mode and off

- mode energy consumption. 9

So the proposed amendments would require 10

measuring an addition standby mode beyond the standby 11

mode that would currently be defined, the cycle 12

finish ed mode, and would require the measurement of 13

off mode. And it would also revise the existing 14

definition of standby mode. 15

So these three additional modes, the 16

inactive, off, and cycle finish ed modes may result in 17

energy consumption levels slightly higher than what 18

the current test procedure would result in. But the 19

proposed amendments would clarify that this new 20

measure would not be required to be used by 21

manufacturers to determine compliance with existing 22

energy conservation standards an d would not be 23

required for that purpose until the dishwasher 24

standards are updated to take into account the 25Executive Court Reporters (301) 565

- 0064 112

effective

-- whoops

-- of standby and off

- mode energy 1

use. 2

There is also an estimated annual operating 3

cost calculation in the CFR and DOE is prop osing to 4

adjust that also for the additional cost associated 5

with standby and off

- mode energy use. 6

Because energy factor is not currently used 7

as the basis of any standards, DOE is not proposing to 8

amend the calculation of EF so leaving that metric as 9

is. 10

And finally, for reasons that

-- really more 11

for clarification and to ensure consistency when these 12

measurements are made, DOE is proposing to ensure that 13

all the rounding instructions are provided for the 14

final values of energy factor

, EAEU , and water 15

consumption in the test procedure. 16

Question? 17

MR. BROOKMAN: Yes, Amanda. 18

MS. STEVENS: Stevens. Could you just very 19

briefly

-- I know we're trying to move on

-- clarify 20

what the rounding instructions are? 21

MS. REICH: Let's see, for EAEU it would 22

req uire that the value be rounded to the nearest 23

kilowatt hour, for water consumption it's gallons per 24

cycle to the first decimal place, and energy factor I 25Executive Court Reporters (301) 565

- 0064 113

think that's two decimal places. 1

MS. STEVENS: Clarify when the rounding 2

should occur? I'm asking f or a point of clarification 3

because E NERGY STAR also included some rounding 4

clarifications and I just want to make sure that we're 5

-- 6

MS. REICH: It's the final calculation. 7

MS. STEVENS: The final calculation. Okay. 8

All right. Thank you. 9

MS. REIC H: Now, for dehumidifiers, the test 10

procedure currently does not have any measure of 11

standby or off

- mode power. It's only looking at 12

active

- mode energy use when calculating energy factor. 13

This is, again, liters of water removed per kilowatt 14

hour and it is on the basis of a 24

- hour test cycle. 15

The measurements and estimates that DOE has made lead 16

it to conclude that the

-- that rolling in the standby 17

and off

- mode energy use is technically feasible 18

because it is a significant enough value to have a 19

notice able impact on the standard metric, but it's not 20

so great that rolling it in would essentially wash out 21

all the effects of efficiency in active mode. 22

So DOE is proposing to create a new 23

integrated metric

-- integrated energy factor, IEF, in 24

which the ener gy use in standby power would be 25Executive Court Reporters (301) 565

- 0064 114

allocated. The annual energy use in standby power 1

would be allocated to those associated with a 24

- hour 2

period that the test cycle covers. 3

And this is the equation that is proposed, 4

just to make that a little clearer, IEF is the liters 5

of water removed during the test divided by the sum of 6

the active mode energy use during that 24 hours and 7

then the energy use

-- the annual energy use in 8

standby and off mode that is scaled by the period of 9

24 hours which is the test cycle divided by the total 10

number of active mode hours. 11

And for rounding instructions DOE is 12

proposing that that final IEF value be rounded to two 13

decimal places. 14

For conventional cooking products, there are 15

-- within the energy consumption measure and energy 16

factor calculation there are various types of energy 17

consumption that are measured and calculated. They're 18

listed here, test energy consumption, annual cooking 19

energy consumption, the annual energy associated with 20

pilot light s which in 2012 will become z ero, annual 21

self

- cleaning energy consumption for ovens and for 22

ovens also annual clock energy consumption and all of 23

those get rolled up into a total annual energy 24

consumption. 25Executive Court Reporters (301) 565

- 0064 115

As I mentioned previously, there is no 1

performance

- based standard for cooking products, 2

conventional cooking products. There is a 3

prescriptive preclusion of standing gas pilots. But 4

historically DOE has used energy factor as the basis 5

of its analysis for potential standards, so DOE 6

considered rolling any standby and off

- mode use i nto 7

that energy factor metric. 8

And because already, for example, in the 9

pilot energy consumption and the clock energy 10

consumption, these are forms of standby power, DOE 11

believes it's meaningful to incorporate other types of 12

standby and off

- mode energy use into it. So it's 13

proposing integrated metrics. 14

For conventional ovens, the integrated 15

annual energy consumption would be the sum of the 16

contribution from standby and off mode as well as the 17

primary cooking energy use and annual self

- cleaning 18

energy cons umption. 19

For gas ovens, this would be the same thing 20

with the addition of annual secondary cooking energy 21

which I believe is the electrical energy associated 22

with the cooking process in addition to the gas 23

primary cooking energy. 24

The integrated energy fa ctor then for ovens 25Executive Court Reporters (301) 565

- 0064 116

would be the annual useful cooking output, that's the 1

energy that's used to

-- that's delivered to the food 2

load, divided by this integrated annual energy 3

consumption. 4

For gas ovens, because it has both the gas 5

portion and the electri cal portion, the annual use for 6

cooking energy output would be divided by the sum of 7

the gas and the electric energy consumptions. 8

And I think this was a question that was 9

posed earlier, how to handle multiple conventional 10

ovens and similar metrics are b eing provided for the 11

case where there's, say, a double oven. 12

Conventional ranges, it's simply the sum of 13

the two components. So integrated annual energy 14

consumption would be the integrated annual energy 15

consumption for the cook top plus the one for the 16

o ven. Plus the overall range standby mode and off

17

mode energy consumption. It too would have an 18

integrated energy factor. It's defined as the annual 19

useful cooking output divided by the sum of the 20

integrated annual energy consumption for the two 21

componen ts. 22

MR. ANDERSON: Excuse me, Judy. This is Wes 23

from the Department of Energy. We are now

-- we 24

skipped ahead to slide 74, for those on line, so you 25Executive Court Reporters (301) 565

- 0064 117

can just

-- 1

MS. REICH: I'm sorry, did I miss

-- 2

MR. BROOKMAN: Maybe you missed 76. 3

MR. ANDERSON: Oh, I'm sorry, we're on 76. 4

(Simultaneous conversation.) 5

MS. REICH: Okay. I apologize. Okay. 6

MR. BROOKMAN: So we're on slide 76. 7

MS. REICH: Okay. Let me retrace then. So 8

for conventional cook tops the integrated annual 9

energy consumption is the annua l standby energy use 10

plus the useful cooking energy output divided by the 11

cooking efficiency. That's how the cooking portion of 12

the annual energy consumption is obtained. 13

For gas cook tops, it's the same approach 14

with standby and off mode energy use in th e numerator 15

and

-- I'm sorry, being summed with the annual 16

consumption for gas consumption for cooking and the 17

annual energy consumption of the gas standing pilot 18

for the time being. 19

Okay. For integrated energy factor, for 20

electric cook tops, it's the use ful cooking energy 21

output divided by the integrated annual energy 22

consumption and that's the same actually for electric 23

and gas. 24

MR. BROOKMAN: And I think you've gotten 25Executive Court Reporters (301) 565

- 0064 118

most of 77 covered. So maybe you can just summarize 1

that. 2

MS. REICH: Okay. It's ba sically for 3

conventional ranges. It's just the sum of the two 4

parts, the cook top and the oven. 5

MR. BROOKMAN: Right. 6

MS. REICH: So, in addition to creating 7

these new integrated energy factor measure s DOE is 8

proposing to update to amend the annual energy cost 9

calculations to include the cost associated with the 10

standby and off mode energy use. 11

In terms of rounding instructions, again, 12

the annual operating cost would be rounded to the 13

nearest dollar and the rounding requirements for IEF 14

would be to three s ignificant digits. 15

DOE would invite comment on these integrated 16

energy factor metrics for dehumidifiers and 17

conventional cooking products. Also invites comments 18

on the proposed amendments to modify estimated annual 19

energy use and estimate annual operatin g cost metrics 20

for dishwashers, and actually it's also costs for 21

cooking products, and to incorporated the revised 22

measurements of standby mode and off mode energy 23

consumption. 24

MR. BROOKMAN: Comments here? Joanna. 25Executive Court Reporters (301) 565

- 0064 119

MS. MAUER: In terms of the integrated 1

m etric for conventional cooking products, I'm trying 2

to think about how this relates or is similar to the 3

situation with microwaves. And my understanding is 4

that for both conventional cooking products and 5

microwaves DOE analysis in the past has shown that 6

there's maybe not significant energy savings, 7

potential or not cost effective savings potential for 8

active mode energy use. But now we have a rulemaking 9

for standby energy for microwaves and so we're going 10

to have a separate standby metric for microwaves. And 11

so I guess my question is, if we have an integrated 12

metric for conventional cooking products, does that 13

eliminate the possibility in the future of a standard 14

for standby energy use for conventional cooking 15

products? 16

MS. REICH: The statutory requirem ent is 17

that the metric must be integrated if it's technically 18

feasible. And for microwave ovens the active mode 19

portion was eliminated on the basis of inherent 20

problems in the measurement. It was not the separate 21

metric for standby power is not being pro posed because 22

there are no opportunities to improve active mode 23

efficiency. It's that the portion, if it were 24

integrated the active mode portion was fundamentally 25Executive Court Reporters (301) 565

- 0064 120

flawed and was removed. So there is no metric to roll 1

it into anymore. So therefore it mus t be a separate 2

prescriptive requirement. So it's not the same 3

situation with the cooking products, and, again, it's 4

this EISA requirement that a single metric must be 5

defined unless it's technically infeasible to do so. 6

MR. BROOKMAN: Additional comments on this 7

series of measures? 8

(No response.) 9

**Compliance with Other EPCA Requirements and** 10

**Impact of the proposed Amendment on EnergyGuide** 11

**and ENERGY STAR** 12

MS. REICH: Okay. Getting towards the end 13

here. The next section discusses compliance with 14

other EPCA requirements

. 15

We've hit on this quite a bit in terms of 16

test burden in discussing the methodology and there is 17

a requirement under EPCA that any test procedures 18

prescribed or amended under this section shall be 19

reasonably designed to produce test results which 20

measure e nergy efficiency, energy use, or estimated 21

annual operating cost of a covered product during a 22

representative average use cycle or period of use and 23

shall not be unduly burdensome to conduct. 24

In sum DOE believes that the proposed 25Executive Court Reporters (301) 565

- 0064 121

amendment satisfied this r equirement. First of all it 1

believes it's representative, the IEC Standard 62301 2

is an international standard used to measure standby 3

power and off

- mode power. And DOE believes it will 4

produce power consumption measurements that are 5

representative of an average use cycle. DOE also 6

believes that the test methods and associated 7

equipment would not require manufacturers to make 8

major changes and major investments in their 9

facilities or purchase

-- or extensive investments in 10

new equipment in order to make t he measurements. 11

EPCA also directs DOE to consider IEC 62087, 12

“Methods of measurement for power consumption of 13

audio/video and related equipment. ” But this is 14

basically just not applicable to the products that are 15

considered today. So DOE has fulfilled t he 16

requirement to consider it, but has determined it's 17

inapplicable. 18

And here is the section of EPCA as amended 19

by EISA that requires this single metric, if it's 20

technically feasible. It says it must be integrated 21

into the overall energy efficiency, energ y 22

consumption, or other energy descriptor for each 23

covered product, unless a test procedure already 24

accounts, fully accounts for standby mode and off

- mode 25Executive Court Reporters (301) 565

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energy use or if such an integrated method is 1

technically infeasible. So for the reasons that in 2

eac h case there's either already measures of standby 3

and energy use there, or because

-- and/or because the 4

magnitude of the energy use that would be newly 5

measured is measurable with an integrated metric but 6

doesn't overwhelm the existing active mode metric

, DOE 7

believes that in all cases it's technically feasible 8

to define single integrated metrics. 9

And these would be for dishwashers, the EAEU 10

and the estimated annual operating costs and for 11

dishwasher

-- or dehumidifiers

, integrated energy 12

factor, and conve ntional cooking products

, an 13

integrated annual energy consumption and integrated 14

energy factor. 15

EPCA requires that DOE consider how the 16

amendments to the test procedure would affect 17

compliance with existing standards. Although the 18

revisions to the dishwas her test procedure, because 19

that already includes a measure of standby power, 20

there would be some slight revision to the calculation 21

of EA E U, DOE doesn't believe that that would be 22

significant. And also the fact DOE would provide 23

clarifying language that the new provisions would not 24

be required to determine compliance until new 25Executive Court Reporters (301) 565

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dishwasher standards became effective. 1

For dehumidifiers an entirely new metric is 2

being defined, the IEF

, and energy factor which is the 3

basis of the existing standards would not b e affected. 4

Therefore, the test procedure amendment would have no 5

effect on compliance. 6

And then finally for cooking products there 7

are no standards

-- performance standards for them and 8

so the definition of integrated metrics has no effect. 9

There's noth ing for it to affect. 10

MR. BROOKMAN: Yes, Natas c ha. 11

MS. MILESI: I have a clarifying question. 12

With regard to the delay of compliance, I understand 13

for EAEU, but what about EAOC; is that also delayed 14

reporting of the costs that include standby? 15

MS. REICH: I believe that would be 16

similarly delayed because it would be based on the 17

provisions that would be calculating EAEU. 18

MS. MILESI: But it would not affect the 19

standard? It would not affect the product's 20

qualification or meeting the minimum energy 21

requir ements? 22

MS. REICH: That's right. Yes. Well, that 23

would be based on EAEU, the compliance requirement and 24

so that new calculation would not be required until 25Executive Court Reporters (301) 565

- 0064 124

such time as a new standard. And that was why DOE was 1

proposing to keep the existing standby pow er 2

methodology under a new name in the test procedures 3

specifically because that portion will be used until 4

the new standards come into effect. 5

MR. BROOKMAN: Amanda. 6

MS. STEVENS: I've got a question. As I was 7

looking at the Federal Register notice and t he test 8

procedure, for dishwashers I saw a date of May 31 st

, 9

2011, so there's different sets of calculations for 10

product manufactured before then and then on or after 11

that date and I just wasn't sure, what's that date in 12

reference to? 13

MS. REICH: Yeah, tha t's a very good 14

question. May 31 st

-- 15

MS. STEVENS: It says, may 31 st , 2011, 16

because I thought it would be a new standard

-- 17

(Simultaneous conversation.) 18

MS. STEVENS: Yeah, so in the Federal 19

Register notice it's 75321 so if you go down to the 20

dishwashe r section there, for the calculations that 21

kind of sets forth two kinds of calculations broke out 22

by that date which didn't

-- 23

PARTICIPANT: (Off microphone.) Can you give 24

me the page number? 25Executive Court Reporters (301) 565

- 0064 125

MS. STEVENS: Yes, sorry, it's 75321. 1

MR. BROOKMAN: Well, let's let them take a 2

peek and see if they can come up with the answer while 3

we're taking other questions or comments. Eric. 4

MR. STAS: We have to check into this, but 5

one thing that might have happened was when the 6

document got sent to the Federal Register perhaps they 7

accidentally inserted a date when they should have 8

been saying some date before the final rule for test 9

procedures get finalized and after, or something. So 10

I'm not sure if these dates belong in here yet. 11

MS. STEVENS: Okay. Okay. 12

MR. STAS: That's one possible thing. 13

MS. STEVENS: Okay. 14

MR. STAS: And Judy, I was going to ask you, 15

I think we talked about this before, for some of these 16

cost calculations

-- 17

MS. REICH: Uh

- huh. 18

MR. STAS:

-- whether that was someth ing 19

that we said was going to be reported. You know, I 20

agree about the part about not be used for standards 21

compliance purposes, but we were saying other purposes 22

that the costs might be reported, is that

-- 23

(Simultaneous conversation.) 24

MS. REICH: I t hought they were subject to 25Executive Court Reporters (301) 565

- 0064 126

the same time requirements that whatever date that the 1

annual energy use gets updated so would the annual 2

operating costs. Because, you know, there's a desire 3

to have them

-- those two metrics be meaningful in 4

comparison to eac h other. 5

MR. STAS: I think we need to go back and 6

check what's in here on that point. 7

MS. REICH: Okay. 8

MR. STAS: But it's definitely the case for 9

the standards compliance purposes. 10

MR. BROOKMAN: Other questions on this 11

segment? 12

(No response.) 13

MS. REICH: Okay. All right. The last 14

section is the impact of the proposed amendment on 15

EnergyGuide and ENERGY STAR. 16

So, for EnergyGuide, this is a program that 17

is administered by the Federal Trade Commission. And 18

for dishwashers because the EAEU and EA OC and water 19

consumption would not be modified until the new date 20

of standards, the relative metrics that are used for 21

both EnergGuide and ENERGY STAR wouldn't be impacted 22

at all at this time. 23

For dehumidifiers there is no EnergyGuide 24

labeling program cur rently and the ENERGY STAR 25Executive Court Reporters (301) 565

- 0064 127

certification or qualification requirements are based 1

on energy factor which is left alone in the amended 2

test procedure. So that would be unaffected. 3

For conventional cooking products, there is 4

no EnergyGuide or ENERGY STAR re quirements, so, again, 5

no impact. 6

MR. BROOKMAN: Okay. 7

MS. REICH: And that wraps up the 8

discussion. 9

MR. BROOKMAN: That's all the presentation 10

material. And Judy has put up there the closing slide 11

that references the numbers that are relevant. I'm 12

go ing to return to Wes to closing in just a moment. 13

But as we promised at the outset, now is an 14

opportunity for anybody that wants to do so, to make 15

closing remarks to describe other issues that haven't 16

been covered fully in the course of the proceeding 17

tod ay. Yes, James. 18

MR. BATTAGLIA: I just want to confirm what 19

Eric was saying about that May 31 date, it should have 20

been 180 days after the publication of the final rule. 21

And I guess the Federal Register just entered it in

-- 22

MR. BROOKMAN: They just i nserted something. 23

MR. BATTAGLIA: 180 days after publi cation 24

of the NOPR, I guess. 25Executive Court Reporters (301) 565

- 0064 128

MR. BROOKMAN: Okay. Thanks for that, 1

James. 2

Yeah. Okay. Closing remarks, final 3

comments on today's meeting? 4

(No response.) 5

MR. BROOKMAN: I see none. And so from my 6

perspective I'll thank everybody that joined from the 7

web. 8

I hope this was constructive and useful for 9

you. I hope you were able to follow okay. And back 10

to Wes for closing remarks. 11

**Conclusions and Closing Remarks**  12

MR. ANDERSON: I would like to also thank 13

you guys for helping us out with the new webinar 14

process. Although we only got one question, we look 15

forward to doing this more often and maybe more 16

interactively down the road. 17

Again, thank you for com ing out in cold 18

conditions outside

, as well as in

, and braving the 19

environmental conditions here. 20

To submit your comments, remember our 21

comment period ends on February 15 th and remember 22

that's pretty much something like 45 days from 23

publication. So, gener ally DOE has

-- I mean, we 24

accept comments at any time and we would like to 25Executive Court Reporters (301) 565

- 0064 129

reiterate that comment period ends on February 15 th

. 1

We would be less likely

-- the later you are, the less 2

likely your comments would affect the final rule. 3

You can submit your i nformation to Brenda 4

Edwards as it is stated on slide 86 by mail or courier 5

or at the e

- mail address. And please put

-- and also 6

when you submit your comments reference the docket 7

number and/or the RIN . That's all I have. 8

Do you have any other comments ? 9

(No response.) 10

MR. ANDERSON: So I officially close this 11

discussion and I look forward for your comments. 12

Thank you very much. Goodbye. 13

MR. BROOKMAN: Thanks to all who 14

participated. 15

(Whereupon, at 12:40 p.m., the meeting was 16

adjourned.) 17

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25Executive Court Reporters (301) 565

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**REPORTER'S CERTIFICATE**

This is to certify that the attached

proceedings before:

**U.S. DEPARTMENT OF ENERGY**

In the Matter of:

**ENERGY CONSERVATION STANDARD NOPR FOR TEST PROCEDURE FOR DISHWASHERS,**  **DEHUMIDIFIERS AND CONVENTIONAL COOKING PRODUCTS** 

Were held as herein appears and that this is

the original transcript thereof for the file of the

Department, Commission, Board, Administrative Law Judge

or the Agency.

Further, I am neither counsel for or related

to any par ty to the above proceedings.



### Wendy Greene Official Reporter

Dated: January 20, 2011