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 Energy
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Facilitator

Doug Brookman
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Participants Identified:

Mike Edwards

BSH Home Appliance

Natascha Milesi-Ferretti

NIST

Amanda Stevens

EPA ENERGY STAR

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 Consulting
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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 62301 (First Edition), and

Determination and Classification of Operational

Modes

Judith Reich

Definition of covered 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 

Energy Independence and Security Act of 2007, 

including consideration of IEC Standard 62301 FDIS.

Address questions 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.
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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

off mode.

Compliance with other EPCA Requirements and 117

Impact of the Proposed Amendments on EnergyGuide 

and ENERGY STAR

Judith Reich

Conclusions and Closing Remarks

Address final questions from the webinar Audience

Wes Anderson

Discuss outstanding issues and make concluding

remarks.

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

2 9:00 a.m.

3 WELCOME

4 MR. BROOKMAN: So, good morning, everybody 

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

6 Public Meeting on Energy Conservation Program for 

7 Consumer Products: Test Procedures for Dishwashers, 

8 Dehumidifiers and Conventional Cooking Products. 

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

10 Department of Energy. My name is Doug Brookman, 

11 Public Solutions in Baltimore and Wes Anderson from 

12 the Department of Energy wishes to make welcoming 

13 remarks.

14 MR. ANDERSON: Good morning, everyone. My 

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

16 Department of Energy and we are here to -- I'm here to 

17 welcome you here on this cold and blustery morning. 

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

19 first snow of the season and we handled it pretty 

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

21 meeting and it will flow smoothly.

22 This is primarily set up to be a 

23 conversation between the Department of Energy and the 

24 interested parties on the subject matter. We look 

25 forward to your questions. We will be posing 
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1 questions throughout the meeting and asking for 

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

3 certain things. And we will also give your our 

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

5 we are. 

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

7 over to Doug.

8 OPENING REMARKS, INTRODUCTIONS, AND AGENDA REVIEW

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

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

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

12 MS. MAUER: Joana Mauer, Appliance Standards 

13 Awareness Project.

14 MS. WALTNER: Meg Waltner, Natural Resources 

15 Defense Council.

16 MS. CLEARY: Jennifer Cleary, Association 

17 for Home Appliance Manufacturers.

18 MS. MILESI: Natascha Milesi-Ferretti, 

19 National Institute of Standards and Technology.

20 MR. WARNER: Brian Warner, BSH Home 

21 Appliance Corporation.

22 MR. EDWARDS: Mike Edwards from BSH Home 

23 Appliance Corporation.

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

25 Office.
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1 MR. BROOKMAN: Wes introduced himself. 

2 Judy.

3 MS. REICH: Judith Reich, Navigant 

4 Consulting.

5 MR. WATSON: Troy Watson, Navigant 

6 Consulting.

7 MR. BATTAGLIA: James Battaglia, Navigant.

8 MR. BOWLEY: Brice Bowley, General Electric.

9 MS. STEVENS: Amanda Stevens, EPA ENERGY 

10 STAR.

11 (Mr. Eric Jones of Energetics is the webinar 

12 moderator, but did not introduce himself. We will 

13 hear him interjecting throughout the presentation)

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

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

16 to you, wherever you would prefer to sit.

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

18 through the Agenda very briefly. Immediately 

19 following this agenda review there's an opportunity 

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

21 remarks here at the outset concerning key issues and 

22 concerns that you may have. Immediately following 

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

24 background under legal authority for this proceeding. 

25 And then from there we will go into the more detailed, 
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1 substantive content of the day. 

2 All of you received a packet of information 

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

4 slides that will be presented as well as the Federal 

5 Register notice. I think most of you are familiar 

6 witness that the way this works. We use the 

7 PowerPoint slides as the focal point for both 

8 presentation and for cuing discussion. There are 

9 comment boxes interspersed throughout for that 

10 purpose.

11 And after Wes’ comments we are going to hear 

12 about covered products, incorporation by reference of 

13 IEC Standard 62301 (First Edition) and determination 

14 and classification of operational modes. All of you 

15 have a copy of this agenda, I believe.

16 We'll take a break midmorning-ish, right 

17 about 10:45 or so and then specifications for test 

18 methods and measurements for standby and off-mode 

19 testing. 

20 Immediately following that calculation of 

21 energy use associated with standby mode and off mode.

22 We'll break for lunch today around about 

23 noon or so and then measures of energy consumption, 

24 compliance with other EPCA requirements and impact of 

25 the proposed amendments on EnergyGuide and ENERGY 
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1 STAR. And at the end of the day today, whenever that 

2 might be, there is yet another opportunity for anybody 

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

4 any other issues that haven't been raised 

5 sufficiently. So there is yet another opportunity for 

6 you to do that. 

7 The timing in the agenda suggests we're 

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

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

10 we'll just do the timing efficiently as we go along. 

11 At least that's the plan.

12 Questions and comments about the agenda?

13 (No response.)

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

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

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

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

18 organization affiliation every time unless you wish 

19 to. There will be a complete transcript of this 

20 meeting and it will be posted on the EERE website and 

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

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

23 making that transition, I think. 

24 I'm going to be cuing individuals to speak 

25 by name. I also wish to encourage follow-on comments 
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1 so that we have the back and forth. Sometimes that's 

2 very helpful for the Department to hear differing 

3 perspectives. It informs their decision making 

4 process. 

5 If you could keep the focus here, please 

6 turn your cell phones on silent mode, limit your 

7 sidebar conversations and in order to speak you need 

8 to turn on your microphone. The little green LED 

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

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

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

12 Questions and comments here before we 

13 proceed?

14 (No response.)

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

16 webinar going now. The Department is trying to make 

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

18 Do we have some folks?

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

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

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

22 In this format there is the potential for 

23 those that are participating via the web to send 

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

25 questions as we're going along, please send them and 
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1 we'll do the best we can to insert them and answer 

2 them during the course of the proceedings today. I 

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

4 outset.

5 There now is an opportunity for anybody that 

6 wants to, to make opening remarks summarizing issues 

7 that they wish to carry forward. Jennifer.

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

9 like to thank the Department of Energy for accepting 

10 comments and hosting this meeting today. We 

11 appreciate the opportunity to give our feedback. 

12 However, there are a number of instances in this 

13 rulemaking where DOE seems to be acting without 

14 sufficient or any data. The test procedure is 

15 intended to be representative of consumer use. 

16 Without data showing what is representative of 

17 consumer use DOE has no reasonable basis upon which to 

18 act and under no circumstance should DOE act on its 

19 own belief about consumer usage.

20 We certainly understand that DOE is in a 

21 challenging position trying to carry out its statutory 

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

23 can be taken. Acting without data is unreasonable and 

24 arbitrary and we will certainly provide more detailed 

25 comments later today in our written comments, but felt 
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1 that was an important sentiment to share at the 

2 beginning. 

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

4 you can help to supplement DOE's sources?

5 MS. CLEARY: We may have data on some 

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

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

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

9 to act unless that data is collected.

10 MR. BROOKMAN: Okay. Other comments here at 

11 the outset?

12 Yes, Wes Anderson

13 MR. ANDERSON: Can you at least point out 

14 where you specifically think --

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

16 course of the meeting.

17 MS. CLEARY: Yeah, we absolutely will today 

18 and in our written comments.

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

20 Other comments here at the outset?

21 (No response.)

22 MR. BROOKMAN: No additional comments, none 

23 from industry. No. Okay.

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

25 background and legal authority.
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1 BACKGROUND AND LEGAL AUTHORITY

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

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

4 are at the NOPR presentation for today which we 

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

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

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

8 there will be a transcript available of today's 

9 meeting. Also available to the public will be your 

10 written comments.

11 The comment period closes in 75 days from 

the publication date, from December 2nd 12 which was 

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

14 So, please make note of that.

15 DOE will review and consider all your 

16 comments for the final rule publication. 

17 Today we are going to cover -- I'm just 

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

19 about. For products covered in the proposed 

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

21 products are, dishwashers, dehumidifiers, and 

22 conventional cooking products, and the subcategories 

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

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

25 actually input on that. And we're not proposing any 
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1 changes to definitions at this point. And we haven't 

2 heard of any concern at this point as well.

3 Then we're going to incorporate by reference 

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

5 Standard 62301 first edition for measuring standby and 

6 off mode power consumption and how it relates to those 

7 three subjects and what we'll take directly from 

8 publicly available information which is first edition 

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

10 final draft.

11 Part three is to determine and 

12 classification of operation modes which we'll go into 

13 detail on mode definitions, talk about how DOE has 

14 developed or derived these modes, or how we define 

15 these modes. The difference in the modes in principal 

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

17 apply that definition or explanation to the specifics 

18 of the products and how active, standby, and off mode 

19 affects each one. 

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

21 more complicated modes or esoteric modes that are 

22 further down the line and looking for your input on 

23 that piece.

24 Section four, the specification for the test 

25 method and measurements for standby mode and off mode 
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1 testing. We'll be talking about power stability and a 

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

3 hogs in the equipment which will be driving some of 

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

5 environment how the room -- the external environment 

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

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

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

9 that have been brought up.

10 For Section five, calculation of energy use 

11 associated with standby mode and off mode. There 

12 we'll discuss how DOE calculates is annual energy 

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

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

15 your help on that and for instance for conventional 

16 cooking products, we'll talk about active, standby, 

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

18 clarify the discussion there. 

19 And in Section six what we'll talk about 

20 measurementmeasures of energy consumption. We'll go 

21 over legal justification for that and how existing 

22 measures will be combined with -- how the active, 

23 standby and off mode will be combined into an annual 

24 number. Where in Section 5, we'll be specifically 

25 talking about the individual products. 
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1 So in Chapter 7 -- in Section seven we will 

2 -- compliance with other EPCA requirements which will 

3 be the test burden or potential for incorporating IEC 

4 62087 and where we combine for dishwashers the 

5 estimated annual energy use, or the estimated annual 

6 operating costs and for dehumidifiers, the integrated 

7 energy factor. And for conventional cooking products, 

8 the integrated annual energy consumption number and 

9 the integrated energy factor.

10 And we'll also talk about how the test 

11 procedure will impact FTC's in Section 8 -- impact 

12 FTC's EnergyGuide requirements and ENERGY STAR power 

13 requirements. And with that we will start with Judy -

14 - I'll do this one as well.

15 This is where the regulatory information is 

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

17 dishwashers; for conventional ranges or cooking 

18 products it will be in Appendix I and for 

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

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

21 The Energy Independence and Security Act of 

22 2007 or informally known as EISA 2007 amended EPCA to 

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

24 dishwashers, dehumidifiers and conventional cooking 

25 products to integrate measures of standby, off mode 
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1 energy consumption. And the publication of the final 

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

3 With that we'll start with the first 

4 section, products covered by the proposed amendments 

5 by Judy Reich.

6 Covered Products, Incorporation by Reference of IEC

7 Standard 62301 (First Edition), and Determination

8 And Classification of Operational Modes

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

10 Judith Reich from Navigant Consulting and I will be 

11 talking about the proposed amendments to the test 

12 procedures and covering the analysis that's supporting 

13 those amendments. So to set the stage for the 

14 discussion, I'll start off by reviewing the 

15 definitions for products that are covered in this 

16 rulemaking. And as Wes mentioned, these are codified 

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

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

19 important to note that for dishwashers and 

20 dehumidifiers these definitions broadly cover all of 

21 the classes that exist currently. For dishwashers 

22 that would be standard size and compact size and 

23 dehumidifiers, units of varying capacity.

24 For cooking products the definition covers 

25 those that are designed to cook or heat food by one or 
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1 more of the sources of heat which include gas, 

2 electricity, and microwave energy.

3 For this rulemaking we're looking at 

4 conventional cooking products. So that would be those 

5 products that are using gas or electricity. Microwave 

6 cooking products are covered in a separate ongoing 

7 test procedure rulemaking.

8 Conventional cooking products are 

9 disaggregated into three types. The definitions 

10 include a conventional cooking top which is the 

11 horizontal surface containing one or more surface 

12 units with either gas flame or electric resistance 

13 heating; conventional ovens consist of -- it's a class 

14 that includes ranges and ovens in which the food is 

15 heated in a compartment either by a gas flame or 

16 electric resistance heating. And a conventional range 

17 is simply a combined unit that includes both a cook 

18 top and one or more conventional ovens.

19 As Wes mentioned, the proposed test 

20 procedure amendments would not include changes to 

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

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

23 if anybody has a comment on these definitions.

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

25 ovens and things like that --
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1 MR. BROOKMAN: Would you say your name for 

2 the record, please? 

3 MR. EDWARDS: Mike Edwards, BSH Home 

4 Appliances.

5 MS. REICH: Uh-huh.

6 MR. EDWARDS: How will double ovens and 

7 other combo products like that be considered?

8 MS. REICH: The test procedure already 

9 includes provisions for multiple ovens within the same 

10 product. So they're already covered. 

11 MR. BROOKMAN: Yes, Amanda.

12 MS. STEVENS: Could you speak to the 

13 coverage of induction cook tops?

14 MS. REICH: Yes, right now the test 

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

16 included now utilizes an aluminum test block to 

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

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

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

20 previously to develop methodology to accommodate that. 

21 But at this point that has not been incorporated in 

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

23 rulemaking, the amendments were focusing on standby 

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

25 to address the active mode portion.
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1 MR. BROOKMAN: Other questions on 

2 definitions? Mike?

3 MR. EDWARDS: Mike Edwards, again. The 

4 consumption of microwave and microwave oven 

5 combinations, is that also specified in the procedure?

6 MS. REICH: Right now for active mode it is 

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

8 issued that removed those provisions because of some 

9 inherent problems with them. DOE is currently 

10 considering whether to develop new active mode 

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

12 -- as I mentioned -- an ongoing rulemaking that would 

13 address standby and off mode energy for microwaves.

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

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

16 through and make sure you got your questions answered 

17 before we move on.

18 (Pause.)

19 MR. ANDERSON: This is Wes Anderson, 

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

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

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

23 speed us through this process. And if you have 

24 comments or questions about active mode issues, please 

25 submit them. But we want to limit our conversation to 
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1 standby and off mode.

2 MR. BROOKMAN: Additional questions?

3 MR. ANDERSON: Or how active mode relates to 

4 those two things.

5 MR. BROOKMAN: Then let's proceed.

6 MS. REICH: The next section will discuss 

7 the incorporation by reference of IEC Standard 62301, 

8 specifically the first edition for the purposes of 

9 measuring the standby and off-mode energy use.

10 So the Energy Independence and Security Act 

11 of 2007 or EISA amended the Energy Policy and 

12 Conservation Act to require that the test procedures 

13 for certain products be amended to address the issue 

14 of standby and off-mode energy use and that DOE should 

15 take into consideration the most current versions of 

16 two international standards from the International 

17 Electro Technical Commission, specifically standard 

18 62301 and 62087. 62301 covers standby power in 

19 residential appliances. IEC 62087 addresses video and 

20 audio equipment and related products. So, it was 

21 determined that that is not applicable to this 

22 rulemaking. So, the discussion today is going to 

23 focus on 62301.

24 DOE is proposing to incorporate certain 

25 provisions from the first edition of 62301 that are 
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1 listed here. These are conditions in methodology that 

2 provide clarification or additions to the test 

3 procedure to allow for measurement of standby and off4 mode power. And you can see they generally relate to 

5 test conditions, specifically test room ambient 

6 conditions, the waveform for the supply voltage and 

7 the accuracy of the metering equipment used to measure 

8 the power. 

9 In terms of the methodology, the 

10 measurements from Section 5, the reference first would 

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

12 drops from a higher power state to a lower power 

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

14 power state. 

15 Section 5.2 discusses the test set up and in 

16 particular this is going to relate to default settings 

17 for setting up the equipment. And finally, Section 

18 5.3 is the actual methodology that would be used to 

19 measure standby power and this accounts for situations 

20 where the power consumption is stable. And it also 

21 covers situations where the product has power 

22 consumption that varies over time. 

23 DOE is aware that the IEC is in the process 

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

25 It is going to be -- the next version will be labeled 
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1 as the second edition. And based on the draft 

2 versions that have been released, it is expected that 

3 the second edition is going to include some additional 

4 mode definitions in addition to standby mode. In 

5 particular it's likely that it will include an off6 mode definition, network mode, and disconnected mode

7 as well as revising what the current definition is for 

8 standby mode.

9 However, the IEC has not yet published a 

10 final version of this second edition and therefore DOE 

11 has made the determination that the current version 

12 that's available for consideration or incorporation by 

13 reference is still the first edition.

14 However, in order to provide the best 

15 possible analysis, DOE has reviewed the two most 

16 recent draft versions of the second edition and these 

17 are entitled -- the first of those was the Committee 

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

19 which followed that the Final Draft International 

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

21 Because of the status of the FDIS as very 

22 late in the process, DOE anticipates that when the 

23 second edition is issued that the mode definitions are 

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

25 FDIS. And so therefore DOE has considered mode 
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1 definitions from that version in today's rulemaking. 

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

3 looking very narrowly at the mode definitions from 

4 this draft version on the basis of substantial 

5 comments and input that it has received from 

6 interested parties on other similar recent 

7 rulemakings.

8 Two of these covered products already do 

9 include some measure of standby power in the test 

10 procedures, specifically dishwashers and conventional 

11 cooking products. The dishwasher test procedure, the 

12 provisions that are currently in place to measure 

13 standby power are very similar to what is included in 

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

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

16 for the possibility that there may be multiple standby 

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

18 mode. So DOE is proposing to amend the dishwasher 

19 test procedure to include these new definitions for 

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

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

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

23 testing clauses from the first edition.

24 For cooking products, there is a limited 

25 measure of standby power right now in the form of the 
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1 annual energy consumption for a clock, but no other 

2 standby mode or off mode energy consumption. So, 

3 again, the proposed amendments would include 

4 definitions that would fully account for the 

5 possibility of multiple standby modes and off mode.

6 At this point DOE would like to receive any 

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

8 measuring standby and off mode power in the three 

9 covered products and on the suitability of 

10 incorporating the specific clauses into DOE 

11 regulations.

12 MR. BROOKMAN: Jennifer.

13 MS. CLEARY: Jennifer Cleary, AHAM. AHAM 

14 urges DOE to reference the second edition FDIS as the 

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

16 commented previously, that version will soon be 

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

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

19 contains a number of important clarifications that are 

20 not present in the first edition or even in the CDV 

21 version. And we think that adopting the FDIS will 

22 allow for optimum international harmonization which 

23 will give clarity and consistency to the regulated 

24 parties and will certainly provide some more detail on 

25 how we think DOE can do that and where we specifically 
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1 think they should.

2 In addition, we do appreciate that 

3 specifically with regard to the definitions in some 

4 other areas that you have looked at the FDIS and 

5 incorporated that. We think that's certainly an 

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

7 further to address the holistic intent of the standard 

8 62301 (sic).

9 MR. BROOKMAN: Do you know what the 

10 timetable is for the second edition?

11 MS. CLEARY: The timetable seems to be hard 

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

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

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

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

16 it's up in the air. Wes?

17 MR. ANDERSON: I would just like to remind 

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

19 published by March -- the end of March next year. So 

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

21 nonpublic documents.

22 MR. BROOKMAN: So that is if the second 

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

24 can't incorporate it formally by reference or 

25 something like that?
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1 MR. ANDERSON: Not by reference, no.

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

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

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

5 thing isn't formally adopted yet, things that you 

6 would like to see incorporated in our regulations to 

7 capture the most important elements.

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

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

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

11 sections you use because the standard is intended to 

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

13 pick certain sections out that causes problems in how 

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

15 a definition from the FDIS and then combining that 

16 with incorporation by reference to the first edition, 

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

18 we're making the comment that perhaps the 

19 interpretation of current edition should be different.

20 MR. BROOKMAN: Yeah, I was trying to 

21 remember who was here the last time we did this 

22 talking about the IEC process and how it kept -- that 

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

24 hard to cause the IEC process to accelerate. 

25 MS. CLEARY: Right. But it is. And it's 
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1 final right now. This draft is being voted on and 

2 there are certain rules in the voting process that 

3 make it fairly clear that this -- you know, is as it 

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

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

6 before.

7 MR. BROOKMAN: Okay. So there is a request 

8 for other comments on the adequacy of the IEC 

9 standard. Other comments on this?

10 (No response.)

11 MR. BROOKMAN: I see no additional comments. 

12 Okay.

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

14 cover is how these mode definitions are applied to the 

15 products and classification of operational modes 

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

17 EISA, provides definitions itself for active, standby 

18 and off mode. And IEC standard 62301 contains an 

19 additional definition for standby power. And these 

20 definitions are intended to be very encompassing and 

21 broadly applicable to all types of products. So that 

22 can lead to multiple interpretations for a given 

23 product.

24 I think we've covered in detail that this 

25 second edition draft, FDIS version, is available. And 
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1 the definitions that are within there are expected to 

2 remain largely similar when a second edition comes 

3 out. 

4 So, again, for reasons that the draft has 

5 been available for DOE to receive comment on for some 

6 time now and DOE has received inputs from multiple 

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

8 FDIS in determining mode definitions for its amended 

9 test procedures. 

10 So the amendments are proposing to use the 

11 definition in the FDIS as a starting point but provide 

12 additional clarification to apply those modes 

13 specifically to the dishwashers, dehumidifiers, and 

14 cooking products. 

15 So let me start off with the definition 

16 being proposed for active mode. And that is the 

17 condition in which the energy using product is 

18 connected to power, has been activated and provides 

19 one or more main functions. 

20 In a previous draft version, the Second 

21 Edition Committee Draft Two, there was an additional

22 clarification that delay start mode is a one-off, 

23 user-initiated, short-duration function associated 

24 with active mode. And DOE noted that this 

25 clarification or this note was removed in the FDIS. 
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1 And the FDIS now classifies delay start as a secondary 

2 function that is not part of active mode.

3 However, because delay start is of finite 

4 duration, limited duration, and it is uniquely 

5 associated with the initiation of a main function, DOE 

6 believes that it should indeed be considered as part 

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

8 in a moment.

9 To clarify the definition of active mode for 

10 dishwashers, DOE is proposing to define active mode as 

11 the dishwasher is performing the main function of 

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

13 process is included, the various dishware and utensils 

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

15 involved in the functions necessary to provide those 

16 main functions which would include admitting water 

17 into the dishwasher or pumping water out of it.

18 To clarify what active mode means for 

19 conventional cooking products, the proposed amendment 

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

21 conventional cooking top, oven, or range is performing 

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

23 holding a cooking load by means of either the gas 

24 flame or electric resistance heating.

25 For dehumidifiers the clarifications would 
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1 cover three main functions, specifically removing 

2 moisture from the ambient air by drawing that air 

3 across a refrigerated coil. A similar process in 

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

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

6 the purpose of circulating the air.

7 And then third is a function in which if ice 

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

9 activity to defrost the coil.

10 Now, for standby mode DOE is proposing to 

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

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

13 following functions, and a key element to this 

14 definition is that these functions may persist for an 

15 indefinite time. The first function would be to 

16 facilitate activation of other modes, either 

17 activating or deactivating active mode, by remote 

18 switch which would include the use of remote control, 

19 an internal sensor or a timer.

20 Standby mode would also include a continuous 

21 function such as information or status displays and 

22 that would include any clock or senor-based functions 

23 such as a cooking sensor. 

24 DOE would also clarify that a timer doesn't 

25 necessarily have to be limited to an external clock or 
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1 other display that's observable by the consumer. It 

2 can also be an internal timer in which the components 

3 on the control board are providing switching of 

4 regularly scheduled tasks, but it would be happening 

5 on a continual basis. 

6 So it's important to note that that standby 

7 mode definition is different than what is in the 

8 current dishwasher test procedure. That definition 

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

10 first edition, that was simply a single measurement 

11 that was taken at the lowest possible power state. 

12 DOE proposes to retain that definition that's in the 

13 dishwasher test procedure and rename it as a 

14 simplified standby mode for the purposes of continuing 

15 to still provide the appropriate metric for the 

16 existing energy conservation standards until any 

17 amended standards for dishwashers take effect.

18 Again, multiple modes under this new 

19 proposed definition for standby can be considered and 

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

21 products would be something defined as inactive mode 

22 in which the product is in a mode in which it could be 

23 activated back to active mode by remote control or an 

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

25 example, or one that provides a continuous status 
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1 display.

2 Off mode is a mode which DOE proposes to 

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

4 connected to power and is not providing either an 

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

6 a situation that may persist for indefinite time. 

7 An important clarification that DOE proposes 

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

9 light that is provided on the product whose only 

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

11 off position, but is connected to power, it would 

12 still be included as an off mode.

13 Also, DOE believes that a product that is 

14 equipped with a hard on/off switch that could 

15 disconnect the power to the display or control 

16 components would be considered to be in off mode when 

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

18 no other function taking place that would classify it 

19 as a standby or active mode.

20 So, DOE believes that these definitions are 

21 applicable to all of the products under consideration 

22 but that there are some additional modes that are 

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

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

25 invite comment on the proposed definitions of standby 
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1 mode, off mode, and active mode based on the 

2 definitions within the FDIS.

3 MR. BROOKMAN: Jennifer.

4 MS. CLEARY: Jennifer Cleary. As you 

5 mentioned in your slides, DOE is proposing to define 

6 standby mode based on the FDIS version. We support 

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

8 of clarification that DOE indicate that all products 

9 will default to the standby mode as delivered from the 

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

11 comments.

12 MR. BROOKMAN: Thank you.

13 Mike.

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

15 you going to address the water-softening dishwashers 

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

17 think recent interpretations have that under active 

18 mode.

19 MS. REICH: Okay. That is not a function 

20 that is addressed for today, but we would certainly 

21 invite comment on it because we have heard that that 

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

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

24 classify that. 

25 MR. EDWARDS: Under the current route of 
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1 DOE, it appears as though they're interpreting it 

2 differently than IEC. So we would --

3 MR. BROOKMAN: Do you want to describe that 

4 now?

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

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

7 regeneration process. And others that have 

8 dishwashers with water softeners are supposed to be 

9 calculating that and submitting a waiver as well. So 

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

11 the final rule to how we deal with that.

12 MR. BROOKMAN: Did you say how IEC is 

13 addressing that?

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

15 as active mode at this point. They say -- I think 

16 there was also secondary process --

17 MR. BROOKMAN: I see.

18 MR. EDWARDS: -- separate from washing and 

19 cleaning the dishes.

20 MR. BROOKMAN: And nor is it considered in 

21 any of the other identified defined modes here.

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

23 think we would need to look at that.

24 MS. REICH: I have a question.

25 MR. BROOKMAN: Yes, go ahead.
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1 MS. REICH: Okay. I was wondering if you're 

2 aware of any methodology to measure --

3 MR. EDWARDS: Whirlpool came out with a 

4 methodology and the others applying for waiver are 

5 supposed to use something similar to that methodology.

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

7 methodology?

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

9 process of writing a waiver for us now.

10 MR. BROOKMAN: Okay.

11 MR. EDWARDS: And hopefully I am duplicating 

12 that.

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

14 you're representing who -- pardon me, Mike, who are 

15 you representing today?

16 MR. EDWARDS: BSH Home Appliances.

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

18 apologize.

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

20 have or are aware of any data on percentage of units 

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

22 -- this function is activated --

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

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

25 normally on very high-end products and it would be my 
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1 opinion that homes that buy these dishwashers normally 

2 have home water softening systems. So the frequency 

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

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

5 MR. BROOKMAN: So if they bought these units 

6 and they had home water softening units, then that 

7 capacity in the dishwasher that would be duplicative?

8 MR. EDWARDS: And they would just set it at 

9 zero which basically is non-energy --

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

11 control function for that feature?

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

13 basically adjust the level for water hardness on the 

14 water softener.

15 MR. BROOKMAN: Huh, interesting. Wow. 

16 (Laughter.) 

17 MR. BROOKMAN: That's really something. 

18 Okay. 

19 Do you have any additional questions?

20 MS. REICH: No, thank you.

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

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

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

24 going to look at specifically and so DOE identified 

25 these functions and considered each how they would be 
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1 classified as whether they would be an active, standby 

2 or off mode.

3 For dishwashers, it identified two 

4 additional modes, delay start mode and cycle finished

5 mode where delay start would be defined as the product 

6 would be activated by a timer and cycle finished mode 

7 is a state in which the product is providing a 

8 continuous status display following operation in an 

9 active or washing mode.

10 DOE believes that because delay start does 

11 not persist for an indefinite period that it persists 

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

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

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

15 procedure rulemaking is addressing standby mode and 

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

17 active mode portion and is not addressing the delay 

18 start mode.

19 However, cycle finished mode would be 

20 considered a standby mode. Under the proposed 

21 definitions DOE believes that the display on most 

22 dishwashers is provided indefinitely until the user 

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

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

25 definition that it may persist for an indefinite time.
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1 I invite comment at this point on the 

2 establishment of inactive mode, as we discussed 

3 previously, and cycle finished mode as standby modes 

4 for dishwashers as well a determination that delay 

5 start mode -- delay start mode, I believe that is --

6 yeah, it's actually -- it would not be a form of 

7 standby mode. And further invites comment on whether 

8 there are additional modes consistent with the active 

9 standby or off mode definitions that have not been 

10 identified and that represent significant energy use. 

11 MR. BROOKMAN: So just to clarify, the 

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

13 should be standby?

14 MS. REICH: Yes.

15 MR. BROOKMAN: Okay. Jennifer.

16 MS. CLEARY: Jennifer Cleary. AHAM agrees 

17 that delay start mode should be part of the active 

18 mode. However, we disagree that cycle finished mode 

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

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

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

22 fleshing that out for you in detail.

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

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

25 this comment box the determination that delay start 
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1 mode would not be a form of" it says here, "active 

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

3 "standby mode."

4 MS. REICH: Standby mode.

5 MR. BROOKMAN: So what is your comment?

6 MS. CLEARY: My comment is that we agree 

7 that delay start mode should be part of the active 

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

9 cycle finished mode, we believe, should also be a part 

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

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

12 MR. BROOKMAN: Yes, Joanna.

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

14 current clothes washer test procedure rulemaking that 

15 DOE is proposing that cycle finished mode for clothes 

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

17 just wondering if you could describe a little bit 

18 whether there's a difference in functionality between 

19 the two products that would --

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

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

22 of a wash cycle that there -- that clothes washers 

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

24 short period of time that the cycle is complete and 

25 then drop down into a lower power state. For a 
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1 dishwasher, observations were that a dishwasher 

2 display continues indefinitely if the user doesn't 

3 take any action. So there is a different -- they 

4 operate differently. So that leads to the different 

5 classification.

6 MR. BROOKMAN: Mike.

7 MR. EDWARDS: Mike Edwards, BSH.BSH. Are 

8 there theories on how you will calculate the time of 

9 the active mode from the control being lit?

10 MS. REICH: I will get into the discussion 

11 of annual hours that are attributed to each mode in a 

12 moment, yes.

13 MR. BROOKMAN: Additional comments? 

14 Questions?

15 (No response.)

16 MR. BROOKMAN: Okay.

17 MS. REICH: Okay. For dehumidifiers DOE 

18 identified three additional modes, operating modes. 

19 Similarly a delay start mode. There is also an off20 cycle mode and a bucket full or bucket removed mode. 

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

22 timer, the same as it was for dishwashers. For off23 cycle, this is a period in which the dehumidifier is 

24 on and is -- but has cycled off the main function by 

25 either humidistat or humidity sensor because it sensed 
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1 that the humidity level in the ambient room is at the 

2 desired set point and the dehumidifier does not have a 

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

4 sensing the humidity level and will reactivate the 

5 dehumidification process at a time when called for, 

6 according to the sensor signal, that would classify 

7 that as a standby mode.

8 The bucket full and removed mode is, you 

9 know, obviously as the moisture is being collected in 

10 a bucket, at some point it fills. And the 

11 dehumidifier has a switch that shuts the main 

12 operation off until the bucket is removed and emptied. 

13 So typically there is some sort of status display to 

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

15 barring any consumer intervention, that could persist 

16 indefinitely, DOE believes that that mode would also 

17 be a standby mode.

18 DOE invites comment on the inactive mode, 

19 off-cycle mode, and bucket full/removed mode 

20 definitions as standby modes for dehumidifiers. And 

21 the determination, again, that delay start mode could 

22 be considered as part of active mode. And further 

23 whether there are any additional modes for 

24 dehumidifiers that haven't been identified that would 

25 represent significant energy use.
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1 MR. BROOKMAN: Comments?

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

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

4 cycle finished mode and would make a comment that I 

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

6 similar to what was found on the clothes washers. 

7 Same comment as for dishwashers.

8 MR. BROOKMAN: Okay. Thank you.

9 Jennifer.

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

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

12 mode.

13 MR. BROOKMAN: Okay. 

14 (Pause.)

15 MS. REICH: Okay?

16 MR. BROOKMAN: Yes.

17 MS. REICH: Finally, for cooking products, 

18 there are three modes that DOE identified other than 

19 the ones previously discussed, including a delay start 

20 mode, a cycle finished mode, and a Sabbath mode. As 

21 we've already gone through the definitions of delay 

22 start and cycle finished. Sabbath mode is a feature 

23 that is for function that is provided for households 

24 that follow kosher practices. The primary feature in 

25 Sabbath mode is that it disables the automatic shutoff 
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1 capability. It overrides that so that food can be 

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

3 violate the stipulations that would occur on the 

4 Jewish Sabbath. 

5 So, again, delay start and cycle finished

6 modes would be proposed to be classified as shown. 

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

8 food warm or potentially even prepare it at lower 

9 temperatures, it would -- or DOE believes it would be 

10 considered part of active mode. And therefore, for 

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

12 amendments to define or measure energy consumption in 

13 that mode.

14 Again, I would like to invite comments on 

15 the establishment of inactive mode and cycle finished

16 mode as standby modes and that the determination that 

17 delay start mode and Sabbath mode would be part of 

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

19 there are any additional modes that haven't been 

20 identified and represent significant energy use, I 

21 would like to invite comment on that.

22 MR. BROOKMAN: Jennifer.

23 MS. CLEARY: Jennifer Cleary. AHAM agrees 

24 that delay start mode should be considered active mode 

25 and believes that cycle finished mode should also be 
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1 considered in the active mode and we'll provide more 

2 details in our written comments.

3 MR. BROOKMAN: Do you have a comment on 

4 Sabbath mode?

5 MS. CLEARY: Not at this time.

6 MR. BROOKMAN: Thank you.

7 Okay. 

8 MS. REICH: There are additional modes that 

9 are defined within the FDIS version of IEC 62301 that 

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

11 network mode, the FDIS defines that as any product 

12 mode where the energy-using product is connected to 

13 the main power source and at least one network 

14 function is activated such as reactivation via network 

15 command or network integrity communication, but the 

16 primary function is not active.

17 The FDIS also includes a definition for 

18 disconnected mode where essentially the main power 

19 source is removed or interrupted to the product.

20 DOE is not proposing to incorporate 

21 definitions or methodology for these modes into the 

22 covered test procedures. For network mode DOE is not 

23 aware of any products or any dishwashers, 

24 dehumidifiers, or conventional cooking products that 

25 currently have a networking function incorporated in 
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1 them and therefore is unable to determine appropriate 

2 methodology for testing energy use in that mode.

3 For disconnected mode, because there is no 

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

5 irrelevant for the purposes of measuring standby and 

6 off-mode power.

7 We certainly invite input on whether 

8 dishwashers, dehumidifiers or conventional cooking 

9 products are available with a network mode and whether 

10 definitions and testing procedures for network mode 

11 should be incorporated in the test procedures. Also, 

12 DOE invites comment on the appropriate methodologies 

13 that would be used to measure energy use in network 

14 mode for those products as well as data.

15 MR. BROOKMAN: Jennifer.

16 MS. CLEARY: Jennifer Cleary. AHAM agrees 

17 that there are currently none of these products on the 

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

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

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

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

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

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

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

25 on this topic.
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1 MR. BROOKMAN: Thank you. Joanna.

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

3 aware at the current time of any of these products 

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

5 Although certainly at least for dishwashers looking at 

6 manufacturing and marketing materials we'd certainly 

7 expect to see dishwashers come onto the market very 

8 soon with network functionality. And so we're 

9 concerned if this additional energy consumption is not 

10 captured in all the test procedure. And we certainly 

11 recognize the challenge of developing a test procedure 

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

13 a product when it's actually connected to a network. 

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

15 network capability will likely be consuming some 

16 amount of power continuously regardless of whether 

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

18 power consumption may in fact represent the majority 

19 of the energy consumption associated with the network 

20 functionality. 

21 So we encourage DOE to capture any of the 

22 standby energy consumption associated with network 

23 functionality in the inactive mode test. And I would 

24 imagine that it would be captured in the inactive test 

25 unless the network capability would actually be 
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1 disconnected somehow when the product was being 

2 tested.

3 We would also encourage DOE to establish a 

4 definition for inactive mode that is sufficiently 

5 broad so as to capture any of this standby consumption 

6 that's associated with a network functionality that a 

7 product would consume regardless of whether it's 

8 actually connected to a network.

9 MR. BROOKMAN: Okay. Thank you.

10 Jennifer.

11 MS. CLEARY: This is Jennifer. I just want 

12 to respond a little bit because I think AHAM might 

13 have a slightly different view as to if network mode 

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

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

16 mode. The network mode and the energy use associated 

17 with smart appliances would be a distinct mode and 

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

19 glad to provide more comments should that be a 

20 consideration that DOE has.

21 MR. BROOKMAN: Okay. Thank you.

22 Is network mode -- well --

23 (Laughter.) 

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

25 Okay. Additional comments on this subject?
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1 (No response.)

2 MR. BROOKMAN: Okay. 

3 Wes Anderson.

4 MR. ANDERSON: DOE is interested in AHAM 

5 giving us some of your thoughts as to how to 

6 distinguish the difference between the two or the 

7 three different modes or the various modes that we 

8 have sort of from a principles perspective, how you 

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

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

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

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

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

14 captured, why the distinction is such a concern.

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

16 understand what you're looking for so we can provide 

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

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

19 been discussing this morning?

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

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

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

23 behind that or --

24 MR. BROOKMAN: Something like a taxonomy or 

25 a hierarchy, a descriptor; right?
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1 MS. CLEARY: Uh-huh. 

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

3 went to public school.

4 (Laughter.) 

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

6 (Laughter.)

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

8 you can explain to me the difference -- where you 

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

10 of that energy usage.

11 MS. CLEARY: Yeah, we absolutely will 

12 provide that.

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

14 Thank you. Other comments on this before we 

15 move on? 

16 (No response.)

17 MR. BROOKMAN: Okay.

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

19 supposed to take a break, but I think we should 

20 probably just press on.

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

22 segment.

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

24 see if there were any questions during the break.

25 MR. BROOKMAN: Okay. 
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1 MR. ANDERSON: Do you want to go another 

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

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

4 would like to do it.

5 MR. BROOKMAN: Yesterday we did one of these 

6 meetings and Eric was able to field the questions real 

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

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

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

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

11 discussion of the actual methodology that is proposed 

12 for measuring standby mode and off-mode energy. DOE 

13 proposes test procedures for measuring the power 

14 consumption in the products in all standby and off 

15 modes. So these proposed amendments include 

16 provisions for measuring energy use in cycle finished

17 mode for dishwashers and conventional cooking products 

18 as well as off-cycle and bucket full or removed mode 

19 for dehumidifiers. 

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

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

22 is proposing to use for the measurement methodology.

23 The first is paragraph 5.3.1 that has 

24 different measurement techniques depending on whether 

25 the power consumed by the product is stable or 
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1 unstable. Pardon me. And this is not -- the 

2 stability is not referring to the power supplied to 

3 the unit. It's the power that would be consumed by 

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

5 power consumption does not vary by more than 5 percent 

6 from a maximum level during a five-minute measurement 

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

8 would sit for five minutes to stabilize and then the 

9 power could be measured at the end of an additional 

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

11 instantaneous power measurement. It does not have to 

12 be an average measurement.

13 However, if the power is unstable, meaning 

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

15 during a five-minute period, then the provision would 

16 require that power be measured for or averaged over a 

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

18 operating cycle, that one or more complete cycles be 

19 included in that measurement period. 

20 DOE wants to make clear that these 

21 provisions don't preclude manufacturers if they feel 

22 it's appropriate to test products with a longer 

23 stabilization period or a longer measurement period, 

24 these just provide the minimum values. 

25 On certain products including some 
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1 dishwasher and conventional cooking products, these 

2 products may be equipped with a feature that 

3 automatically powers down or, for example, dims a 

4 display, after a certain period of user inactivity. 

5 And for those units DOE is proposing to incorporate 

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

7 of 62301 which is that the standby and off-mode tests 

8 would be conducted after that power level has dropped 

9 to its low power state. 

10 Testing has been performed to determine how 

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

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

13 these products typically the higher power state is 

14 found to persist for less than 10 minutes of user 

15 inactivity. And DOE believes that as a result the 

16 product likely spends most of its time at the lower 

17 power state and therefore that level would be most 

18 representative of actual use. 

19 DOE recognizes it's possible that this was 

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

21 fact have a longer duration, higher-power state so 

22 that they would exceed the five-minute stabilization 

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

24 DOE noted that in the CDV version of 62301 

25 it updated that specification, increased both the 
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1 stabilization period and measurement period so that 

2 now the stabilization period would be thirty (30)

3 minutes and the measurement period would be no less 

4 than 10 minutes. 

5 This was significantly changed in the FDIS 

6 revision. It establishes an overall test period of 

7 not less than 15 minutes, but provides quite detailed 

8 requirements on potential extension of that test 

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

10 not cyclic, that is power consumption varying 

11 repeatedly over a certain period of time, the first 

12 third of the period of the measurement period would be 

13 considered the stabilization period and the remaining 

14 two-thirds would be looked at to determine -- to test 

15 whether the power is stable. And that this total 

16 duration of the test period would be extended 

17 potentially continuously until those criteria reached 

18 up until a maximum of three hours.

19 For modes that vary, but don't cycle 

20 regularly, they would follow the same test procedure, 

21 but the total test period has to be at least 60 

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

23 And, finally, the FDIS has requirements that 

24 cyclic modes use an initial stabilization period of at 

25 least 10 minutes and that the power must be averaged 
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1 over at least four complete cycles. 

2 DOE considered both of those requirements, 

3 both the -- or all three, the existing methodology in 

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

5 believes that it has tentatively concluded that the 

6 CDV version for these products would lead to the most 

7 accurate, repeatable and enforceable power 

8 measurements. It would be -- it would potentially 

9 cover those situations where to ensure that the 

10 product went from the higher power state to the lower 

11 power state, but the FDIS version is so broad and is 

12 potentially open to interpretation about how long the 

13 test period should be extended that DOE believes that 

14 the provisions in the CDV that the 10 minute -- I'm 

15 sorry, the 30-minute stabilization and the 10 minute 

16 test period would be the most repeatable and 

17 enforceable, repeatable from manufacturer and test lab 

18 among each other.

19 So, the provisions are intended to allow all 

20 products to reach the lower power state, including 

21 allowing sufficient time for displays that dim to go 

22 to their lower intensity. DOE recognizes that some 

23 products can alter the display setting via user input 

24 to increase how long they stay at that higher power 

25 state. 
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1 DOE believes, however, that most consumers

2 will maintain a default setting and is not proposing 

3 any additional provisions to address a possibility 

4 that the consumer could extend that higher power 

5 state.

6 I'd like to invite any comments on the 

7 suitability of using the default settings in testing 

8 standby energy consumption and on any methodologies 

9 that it can account for consumer actions that might 

10 increase energy use and data on repeatability of these 

11 test procedures.

12 MR. BROOKMAN: Jennifer.

13 MS. CLEARY: Jennifer Cleary. Based on 

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

15 agrees that the appliance should be tested at the 

16 factory or default settings and that where there are 

17 no indications for those settings, the appliance shall 

18 be tested as shipped.

19 MR. BROOKMAN: Okay. Thank you. 

20 Other comments on default settings? And 

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

22 Let me encourage those of you that are 

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

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

25 them.
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1 MS. REICH: Okay.

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

3 now?

4 MS. REICH: I think we -- I'm fine 

5 proceeding on, if everybody else is. 

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

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

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

9 10:25, so let's take a 15-minute break which means we 

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

11 used to being in this building --

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

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

14 MR. BROOKMAN: We had a request during the 

15 break to see if we could identify those individuals 

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

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

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

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

20 Daniel Young, Dennis Pointer, Derek Dao, J. B. Hoyt, 

21 Jonathan King, Junghung Kong, Lincoln Billings, Martin 

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

23 MR. BROOKMAN: Okay. Thank you. 

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

25 And I believe we're on slide 38.
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1 MS. REICH: Actually I'd like to, before we 

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

3 for comment.

4 MR. BROOKMAN: Yes.

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

6 listed on here was a -- to request input on the 

7 measurement and stabilization periods. And I forgot 

8 to mention that previously and just wanted to provide 

9 an opportunity if anybody had inputs on that topic to 

10 allow them to speak now.

11 MR. BROOKMAN: Measurement of stabilization 

12 what?

13 MS. REICH: The measurement period and 

14 stabilization period, the 10 minutes and 30 minutes.

15 MR. BROOKMAN: So comments on that?

16 Yeah, Joanna.

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

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

19 back to the section on definitions.

20 MS. REICH: Uh-huh.

21 MS. MAUER: And specifically, DOE is 

22 proposing that for cycle finished mode that that would 

23 only include power consumption of a continuous 

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

25 guess, partly in the testing that DOE has done on 
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1 products whether you've seen additional energy2 consuming features in cycle finished mode such as a 

3 fan in an oven or have you -- are you aware of other 

4 energy-consuming features that would be present in 

5 cycle-finished mode?

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

7 range of power levels that were measured for the 

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

9 anything other than the typical display indicator 

10 lights or display graphics that were associated with 

11 that.

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

13 to adopt a broader definition for cycle-finished mode 

14 that would capture any energy consuming features that 

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

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

17 be introduced in the future just so if additional 

18 features are introduced they're captured in that cycle 

19 finished mode.

20 MR. BROOKMAN: Thank you.

21 MR. BROOKMAN: Natascha.

22 MS. MILESI-FERRETTI: Yes, Natascha Milesi23 Ferretti from NIST. I can say that leading up to the 

24 2003 rulemaking NIST tested some dishwashers and one 

25 of the products that we tested did have a fan that 
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1 would continue to run after the dishwasher had 

2 indicated that the cycle was finished -- clean.

3 MR. BROOKMAN: Thank you.

4 Okay. 

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

6 discuss the proposed amendments to address the test 

7 room conditions, specifically ambient temperature. 

8 IEC 62301 provides for an allowable range of 

9 ambient temperatures for standby and off mode testing, 

10 specifically 73.4 degrees Fahrenheit plus or minus 

11 nine degrees. All of the -- pardon me -- the 

12 dishwasher and dehumidifier test procedures include 

13 ambient temperature requirements that fall within that 

14 range. So that under the existing conditions that 

15 manufacturers are already testing to, they could, if 

16 they chose to, conduct standby and off-mode tests 

17 simultaneously with active mode tests on separate 

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

19 For conventional cooking products, those two 

20 temperature ranges overlap. The test procedure, the 

21 DOE test procedure, requires an ambient temperature of 

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

23 manufacturer was interested in conducting testing in 

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

25 order to meet both criteria that the ambient 
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1 temperature would fall between 68 and 82.4 degrees 

2 Fahrenheit.

3 We would like any input you may have on the 

4 appropriateness of these proposed ambient temperature 

5 ranges for each of the products geared towards the 

6 possibility of allowing manufacturers to conduct 

7 standby and off-mode testing either separately or in 

8 the same test room under the less stringent ambient 

9 conditions specified in IEC 62301.

10 MR. BROOKMAN: Jennifer.

11 MS. CLEARY: Jennifer Cleary. AHAM actually 

12 believes that the DOE's more stringent ambient test 

13 room temperature should be used in all cases because 

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

15 more accurate, repeatable and reproducible result. 

16 And that comment applies to dishwashers and 

17 dehumidifiers. We're still working on cooking 

18 products where the range does not entirely fall within 

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

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

21 products where the range does fall completely within 

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

23 both cases.

24 MR. BROOKMAN: Okay. Thank you.

25 Yes, Brice.
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1 MR. BOWLEY: I had a comment regarding the 

2 ambient -- actually the ambient humidity for the 

3 dehumidifiers being that if we're measuring an off4 cycle mode and if it's measured to the DOE 

5 temperature, humidity the humidifier -- dehumidifier 

6 will likely never turn off because of the humidity in 

7 the room. So there needs to be additional -- if the 

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

9 needs to be separate test conditions specified and a 

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

11 actually evaluate an off cycle.

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

13 MS. REICH: Yes.

14 MR. BROOKMAN: Okay.

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

16 Wes Anderson, Department of Energy. Where AHAM 

17 disagrees with our temperature ranges, are you are

18 still in flux with that determination, we would also 

19 request that if you could explain if given those 

20 different ranges would that show any significant 

21 additional energy expended by that appliance.

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

23 MR. BROOKMAN: I just want to make sure --

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

25 MR. BOWLEY: Yes, I did.
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1 MR. BROOKMAN: Okay. Thank you.

2 MS. REICH: Okay. Yes, and I understood --

3 I believe something similar was done for room air 

4 conditioners for exactly that same sort of reason to 

5 ensure that --

6 MR. BOWLEY: I think this is a little 

7 different situation -- oh, I understand.

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

9 the conditions -- ambient conditions were such that it 

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

11 while you were measuring it.

12 MR. BOWLEY: Okay. Thank you.

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

14 Okay. 

15 Additional comments, Mike?

16 MR. EDWARDS: Mike Edwards, BSA. In 

17 response to Wes' question, if the test was conducted 

18 at higher temperatures which would be allowed under 

19 the new proposal, it could impact the rate the food --

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

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

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

23 possibility.

24 MR. BROOKMAN: Okay.

25 MS. REICH: Maybe I can ask to clarify that. 
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1 The broader temperature range is not being proposed 

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

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

4 condition for the purpose of standby mode. Okay. 

5 MR. EDWARDS: Okay. Thanks for that 

6 clarification.

7 Specifications for Test Methods and Measurements

8 for Standby and Off Mode Testing

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

10 topic involves the power that is supplied to the unit 

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

12 voltage and frequency specifications but defers to any 

13 existing conditions in the external -- in an external 

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

15 test voltage and frequency are not so defined, the 

16 first edition states that the power supply shall be 

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

18 or minus 1 percent. 

19 The three test procedures,-- DOE test 

20 procedures, under consideration do provide 

21 specifications for the power supply, but not all of 

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

23 the current dehumidifier test procedure specifies the 

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

25 that, an allowable frequency range.
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1 And the current conventional cooking 

2 products test procedure does not specify any power 

3 supply frequency requirements at all. 

4 So for dehumidifiers DOE is proposing to add 

5 that the allowable frequency range is plus or minus 1 

6 percent and the power supply frequency would then be 

7 added to the cooking products test procedure as 60 

8 hertz plus or minus 1 percent.

9 Now we get to the situation of whether the 

10 power consumption is unstable. DOE first notes that 

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

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

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

14 is defined as a regular sequence of power states that 

15 occur over several minutes or hours, the period 

16 selected to average power or accumulate energy shall 

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

18 representative value. 

19 DOE is aware that on certain products, 

20 particularly conventional cooking products that may 

21 incorporate a clock on the display, would potentially 

22 have a regular sequence of power states if the display 

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

24 presented on the display. 

25 So DOE conducted an investigation to 
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1 determine how that power might vary over a cycle, so 

2 that additional clarification can be added to the 

3 provisions from IEC 62301. DOE tested seven 

4 conventional cooking products and it showed that that 

5 standby power, the power consumption can vary by as 

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

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

8 maximum being a time of 12:08 based upon a seven9 segment digit for each numeral in the time. 

10 So DOE realizes that this can be a 

11 significant variation in power consumption and has 

12 previously addressed this issue in the microwave oven 

13 rulemaking and which would have a similar kind of 

14 variation in clock power. And DOE conducted various 

15 tests to different methods for measuring average 

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

17 idea was to determine whether there are methodologies 

18 that balance the need for representative power 

19 measurement with the test burden that would be 

20 required of the manufacturer.

21 The gold standard is to measure over a full 

22 12-hour test period because then all possible 

23 variations in the illuminated digits and thus all of 

24 the different power levels would be captured and would 

25 be captured on a representative weighted basis. 
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1 DOE also investigated an 18-point method 

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

3 power consumption at each one of those times was 

4 measured. Eighteen represents the possible 

5 combinations or possible number of segments in the 

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

7 analysis weighted the power that was measured at each 

8 one of those points by how often that particular 

9 number of segments would be illuminated over the 12-

10 hour period.

11 And then finally DOE investigated a ten12 minute method which would average the power starting 

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

14 minutes the distribution of segments that are 

15 illuminated would be comparable to the same 

16 distribution during the full 12-hour test period. 

17 So I'm going to present the results that 

18 were obtained for the microwave oven testing because 

19 DOE believes that this represents a comparable 

20 situation for conventional cooking products.

21 The tests that DOE conducted were based on 

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

23 liquid crystal display, a light emitting-diode and a 

24 vacuum fluorescent display, VFD. 

25 And so the first column displays the average 
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1 standby watts that were measured over the full 12 

2 hours and then the two -- the two sets of columns to 

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

4 and how that varies by -- or by what percent that 

5 measurement varies from the 12-hour reference value. 

6 And it can be seen that the 18-point method comes 

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

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

9 The ten-minute method also came close. 

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

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

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

13 which the unit that was being tested was subject to 

14 power -- supplied power that was very different than 

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

16 ten-minute method produces results that are within 2 

17 percent of the results that are obtained from the 12-

18 hour methodology.

19 Because this represents a significantly 

20 lower test burden, DOE is proposing that that ten21 minute method be used in which the measurement period 

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

23 would continue until a clock time of 3:42. 

24 The test procedure additionally allows a 

25 stabilization period prior to that measurement period 
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1 because it's recognized that the very act of setting 

2 the clock display can put a product into a higher 

3 power state. The display may be illuminated brighter 

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

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

6 representative measurement. So the proposed amendment 

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

8 ten-minute stabilization period be observed and then 

9 once the clock reached 3:33, the ten-minute 

10 measurement period would commence. 

11 So, DOE believes that this methodology would 

12 supersede the measurement of clock energy consumption 

13 that's currently provided in the conventional cooking 

14 product test procedure because this ten-minute test 

15 period would account for all standby-mode and off-mode 

16 energy consumption including the clock energy 

17 consumption which would be incorporated currently into 

18 the annual energy consumption and energy factor 

19 calculations.

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

21 there. Questions or comments on this before we move 

22 on?

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

24 next -- oops, sorry.

25 (No response.)
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1 MR. BROOKMAN: Okay. Then, let's just 

2 proceed.

3 MS. REICH: Okay. There is a possibility 

4 that if a methodology -- an alternative methodology 

5 from the 12-hour measurement was used, that a product 

6 could be designed or programmed so that the behavior 

7 of the display was altered when it detected the test 

8 conditions. For example, if it were the 18-point 

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

10 display could dim or it could simply, if it's the ten11 minute method, it could be dimmed between 3:33 and 

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

13 manufacturers have the option at their discretion of 

14 conducting either the full 12-hour test or this 

15 abbreviated ten-minute test or both. 

16 However, for the purposes of enforcement, 

17 DOE reserved the right to use either or both tests 

18 with the requirement that the test results between the 

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

20 within 2 percent, then the 12-hour test would be used 

21 to determine compliance.

22 We have an extraneous view on the screen 

23 here. Is it okay if I -- right there? Okay. Thanks.

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

25 that ten-minute methodology is an acceptable 
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1 alternative to the 12-hour test and DOE is requesting 

2 comment on the requirement that the results that would 

3 be obtained under this ten-minute methodology would 

4 agree within 2 percent with the 12-hour test results. 

5 And if that criteria is not appropriate, whether 

6 there's information on a more appropriate criteria.

7 MR. BROOKMAN: Jennifer.

8 MS. CLEARY: I just want to -- Jennifer 

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

10 ten-minute measurement methodology. AHAM supports 

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

12 path there. We might state though that after setting 

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

14 lowest power consumption mode may vary for each 

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

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

17 number of minutes needed to return to the power --

18 lowest power consumption mode. Each manufacturer will 

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

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

21 and we can certainly provide more detail on that in 

22 our written comments.

23 With regard to the DOE using one or both, 

24 the 12-hour method or the ten-minute method, and 

25 requiring each to be within 2 percent of each other, I 
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1 think we just have a question about enforcement -- how 

2 enforcement testing would go. So would DOE, for 

3 example, take into consideration if the manufacturer 

4 chose to use the ten-minute method and DOE chose to 

5 use the 12-hour method, would DOE be taking into 

6 account that inherent 2 percent difference when 

7 considering enforcement action? 

8 So, for example, if the results were 2 

9 percent more than the energy standard, would that be 

10 taken into account that that could be because of the 

11 difference in the methods that were used?

12 (Pause.) 

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

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

15 us and we could address that with the enforcement 

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

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

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

19 when there will be increased enforcement testing, 

20 higher energy efficiency standards, for many products, 

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

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

23 will be doing for enforcement purposes. And so I 

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

25 know, if that won't be taken into consideration 
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1 effectively that means that everyone is going to need 

2 to use the same test and that may put unnecessary 

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

4 So we would certainly say that whatever you 

5 expect the manufacturers to do during testing should 

6 be mirrored with what DOE is doing in its enforcement 

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

8 certainty and clarity for all parties involved.

9 MR. BROOKMAN: Eric Stas.

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

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

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

13 if the manufacturers are doing both a ten-minute test 

14 and a 12-hour test, your batch of testing that you 

15 submit for certification compliance purposes has to be 

16 from one test. Like either the ten-minute or the 12-

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

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

19 MS. CLEARY: Right. And I think we 

20 understood that. The question is just, if you 

21 submit10and DOE uses 12, that's where the --

22 MR. STAS: I know. 

23 (Simultaneous conversation.)

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

25 to make.
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1 MS. CLEARY: Okay. Great. Thank you.

2 MR. ANDERSON: Actually a submission should 

3 make explanation of how the test procedure was done, 

4 an explanation as to what method was used should 

5 accompany any submissions. So that would clear up a 

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

7 Energy.

8 MR. BROOKMAN: Thank you. I have received a 

9 comment from someone who is participating in the 

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

11 would like to comment that this analysis in energy 

12 consumption metric should only be valid for seven 

13 segment clock displays. Other displays may exist 

14 which have a screen of pixels where the energy 

15 consumption of the display would be dependent on 

16 factors such as the font of the numbers displayed.

17 So it's another take on how the display 

18 might be configured.

19 MS. REICH: Okay. Thank you.

20 MR. BROOKMAN: Yes, Joanna.

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

22 comment that I think the DOE proposal seems to be 

23 reasonable in terms of trying to limit manufacturer 

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

25 trying to prevent any potential gaming through the 
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1 proposal for the enforcement testing, I think it seems 

2 to balance those two concerns. And I was also 

3 wondering whether any of the manufacturers might be 

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

5 more than 10 minutes of a stabilization period. 

6 Whether that ten-minute stabilization period would be 

7 adequate or whether products would need more time?

8 MR. BROOKMAN: A moment ago Jennifer said 

9 that different products have different requirements, 

10 different -- right?

11 MS. CLEARY: Right. Which didn't 

12 necessarily mean more. 

13 MR. BROOKMAN: Yeah.

14 Okay. Let's proceed.

15 Calculation of Energy Use Associated with Standby

16 Mode and Off Mode

17 MS. REICH: The next section is fairly 

18 meaty. It is the calculation of energy use associated 

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

20 going to talk about estimates that are made for how 

21 long each product spends on an annual basis in each 

22 mode coupled with typical power levels associated with 

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

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

25 I think I want to emphasize as I'm starting 
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1 to go through this that the calculation of energy use 

2 in each mode is done to determine the relative 

3 importance of various modes. It doesn't necessarily 

4 mean because all modes are presented that DOE is 

5 proposing that all of them be necessarily measured. 

6 Okay. For dishwashers the current energy 

7 conservation standard is based on an average annual 

8 energy use. There is also an additional metric that 

9 is defined and was the basis of previous standards 

10 which is an energy factor or energy used per 

11 dishwasher cycle. Based on the requirements of EISA

12 DOE is proposing to incorporate the energy used in 

13 standby and off mode into the calculation of the 

14 estimated annual energy use. So what DOE has done in 

15 the following analysis is to determine the annual 

16 standby and off mode energy use expressed in kilowatt 

17 hours per year that could be incorporated into that 

18 existing metric.

19 As we discussed previously there is a 

20 standby power calculation currently in the dishwasher 

21 testing procedure and it results in a calculation of 

22 annual standby energy consumption. DOE is proposing 

23 to maintain the current calculation of active mode 

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

25 multiplied by the existing provision of 250 cycles per 
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1 year, and to distribute any remaining non-active, non2 washing mode hours between the appropriate standby and 

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

4 little more clear. 

5 Let's talk about active mode first. The 

6 test procedure, again, assumes that there are 250 

7 dishwasher cycles used annually and back in the early 

8 stages of the last dishwasher standards rulemaking in 

9 the advance notice of proposed rulemaking in November 

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

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

12 215 hours per year associated with that active washing 

13 mode.

14 DOE found very limited consumer --

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

16 of DOE. I might have misheard or you mean 215 --

17 MS. REICH: Did I -- I'm sorry. 

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

19 transcript --

20 MS. REICH: Okay. 200 -- okay. Yes, thank 

21 you. It's 215 hours.

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

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

24 MS. REICH: Okay.

25 MR. ANDERSON: I am losing my hearing.
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1 MS. REICH: So there was very little data 

2 that DOE was able to find on consumer usage patterns 

3 that would allow it to estimate the number of hours 

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

5 developed by the IEC that looked at a very small 

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

7 Germany and Italy and it looked at not just active 

8 mode, but also delay start and cycle finished mode. 

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

10 And the hours that were spent -- I'm sorry, the power 

11 levels in each mode for the active mode were based 

12 upon an equivalent baseline energy factor for a 

13 dishwasher under the current standards with a .65 

14 energy factor, results in a 1540 watt typical power 

15 use per cycle. So the total annual energy associated 

16 with the washing would be 331 kilowatt hours. 

17 The other power levels were those that were 

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

19 dishwashers that were subjected to standby and off 

20 mode power tests. And you can see the 1.91 for delay 

21 start watts, 1.56 watts for cycle finished and up to 

22 .69 watts for either off or inactive mode.

23 So you can see the relative contributions of 

24 each of these to the total annual energy use if these 

25 were integrated together. 
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1 Some of them are very low, almost negligible 

2 contributors to annual energy use. 

3 MR. BROOKMAN: Joanna.

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

5 quick questions. The typical power for the off and 

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

7 power consumption of all the units?

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

9 correct.

10 MS. MAUER: And for delay start and cycle 

11 finished those are average power consumption across 

12 the units that were --

13 MS. REICH: Yes. Yes. And the reason --

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

15 is provided in off and inactive because in off mode 

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

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

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

19 value.

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

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

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

23 it would be an average of the units that had it 

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

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

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

3 the different modes that you saw in the testing how 

4 much variability there was?

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

6 MS. MAUER: Okay.

7 MS. REICH: I don't have that now --

8 (Simultaneous conversation.) 

9 MS. REICH: Yes, absolutely. 

10 MS. MAUER: Okay. Thank you.

11 PARTICIPANT: You would have to ask for that 

12 directly in a written request and we could see what we 

13 could do. 

14 MS. MAUER: All right. Thank you.

15 MS. REICH: Okay. So because DOE is 

16 considering or proposing to consider delay start as 

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

18 test procedure amendments to define or measure energy 

19 consumption associated with delay start. However, 

20 because DOE recognizes that is a certain amount of 

21 annual energy use that should be captured by the test 

22 procedure and because it notes that the power levels 

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

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

25 requiring a tester to measure the power in delay start 
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1 mode, it would allocate the hours that the dishwasher 

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

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

4 bumps up the total annual hours for off and inactive 

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

6 the measurement in off and inactive mode as a proxy 

7 for the delay start energy use.

8 And for dishwashers that don't have a cycle 

9 finished mode, DOE would propose to allocate the 237 

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

11 inactive mode hours because anything then outside of 

12 the active washing mode would be considered off and 

13 inactive.

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

15 many dishwashers spend time in off mode, how many 

16 spend time in inactive mode, but it believes that 

17 because that's typically associated with a type of 

18 controller supplied on the product, if it has 

19 electromechanical controls it likely will go to off 

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

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

22 have both available, DOE estimates or has tentatively 

23 assumed that the hours would be split equally between 

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

25 each mode.
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1 The methodology that DOE is proposing to 

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

3 with the inactive, off and cycle finished modes would 

4 be to measure the wattage in the particular low-power 

5 mode and then use the allocated hours, multiply those 

6 each one by the hours that are allocated to that mode 

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

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

9 annual basis the energy associated with those modes.

10 Now, going back to -- going back to this 

11 chart DOE notes that delay start mode -- I'm sorry, 

12 cycle finished mode is a very small contributor to 

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

14 reduce test burden DOE, rather than requiring 

15 manufacturers to measure both cycle finished and off 

16 and inactive mode, DOE is proposing that it's a 

17 reasonable representation to allocate the hours in 

18 cycle finished mode to off and inactive mode. So the 

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

20 inactive mode and that would allow a single 

21 measurement to be used as a proxy for all of the non22 active hours.

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

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

25 for comment on dishwashers.
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1 MR. BROOKMAN: Let's see if there are any 

2 comments on dishwashers. Anything? Jennifer.

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

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

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

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

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

8 really representative of consumer use in the United 

9 States which is what the test procedure is designed to 

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

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

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

13 for action here is a question that we have.

14 MR. BROOKMAN: And furthermore you don't 

15 know of any additional data sources that would be 

16 targeted on the U.S.?

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

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

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

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

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

22 validity.

23 MR. BROOKMAN: Okay. Mike. 

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

25 understand that the hours that you put up there are 
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1 the actual hours that you're planning to use or would 

2 we calculate in real life usage the inactive hours?

3 MS. REICH: The test procedure is proposed 

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

5 that the numbers provided are intended to be 

6 representative of all dishwashers how much time they 

7 would spend in that mode.

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

9 more data out there. When we calculate standby power 

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

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

12 per year. So I think everything else could be 

13 inactive based on what I'm understanding.

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

15 yes.

16 MR. EDWARDS: Okay. And I think dishwasher 

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

18 cases.

19 MS. REICH: Is that information that you 

20 could provide in a comment what a typical cycle --

21 (Simultaneous conversation.) 

22 MR. EDWARDS: -- the comment, but we know 

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

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

25 MS. REICH: Okay. 
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1 MR. BROOKMAN: Yes, Joanna.

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

3 first on the proposal for allocating hours for 

4 products that have both electronic controls and a 

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

6 appropriate to allocate a portion of the total off and 

7 inactive hours to off mode for those products with 

8 mechanical switches and we would certainly like 

9 manufacturers to have an incentive to actually provide 

10 switches so that the products can be turned off. 

11 We are just a little concerned about the 

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

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

14 there certainly could be a switch placed in some --

15 placed on the product that's clearly not intended for 

16 consumer use and that therefore would never actually 

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

18 encourage DOE to just make some kind of specification 

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

20 panel or that it clearly be intended for consumer use 

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

22 off mode.

23 And then in terms of the alternative 

24 proposal to allocate all the hours to off and inactive 

25 mode and not to separately measure cycle finished 
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1 mode, I think we just want to be careful to think 

2 about not just products that are on the market 

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

4 or seven years given that the test procedures are not 

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

6 power consumption and cycle finished mode is not 

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

8 consumption in that mode and that there may be 

9 additional features that manufacturers introduce that 

10 consume additional energy that wouldn't be captured if 

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

12 seeing an example of that in clothes washers where in 

13 cycle finished mode the clothes washers are being 

14 introduced with periodic tumbling or fan energy and 

15 things like that may become more common in products. 

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

17 procedure that actually measures that energy 

18 separately.

19 MR. BROOKMAN: And James Battaglia has a 

20 comment.

21 MR. BATTAGLIA: James Battaglia (off 

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

23 want to clarify something that Judy said. For the 

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

25 number for dishwashers, it's based on the average 
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1 measured cycle length for the active mode. So you 

2 subtract the active mode hours that you measured from 

3 the total number of hours per year to get the number 

4 of standby hours.

5 MS. REICH: Okay.

6 MR. BROOKMAN: Thank you.

7 MS. REICH: Thank you. 

8 MR. BROOKMAN: Okay. Good.

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

10 the current metric used for the standards is an energy 

11 factor which is the ratio of the amount of moisture 

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

13 DOE is proposing to incorporate the energy used in 

14 standby and off mode into this metric based on the 

15 number of hours that a typical dehumidifier spends in 

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

17 limited data available on usage patterns. There were 

18 several studies looked at that ranged from, I think 

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

20 These studies provide a range of estimates on an 

21 annual basis for active mode operation, anywhere from 

22 875 to 4,320.

23 DOE is proposing to use, as the basis of 

24 this analysis, the information that was developed by 

25 AHAM. And it had a range of estimates and DOE is 
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1 considering the midrange to probably be the most 

2 representative. And DOE is proposing to use that 

3 dataset because this was developed in consultation 

4 with manufacturers and so DOE believes that they 

5 probably understand in lieu of actual field study 

6 measurements, but the manufacturers probably have the 

7 best understanding of how these products are actually 

8 used. 

9 So on the basis of the AHAM data, DOE 

10 proposes that 1,095 annual hours be attributed to 

11 active mode. 

12 However, unlike some other products,

13 dehumidifiers can actually spend some time unplugged a 

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

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

16 off mode. There is no information that DOE could 

17 locate on how much time a dehumidifier typically 

18 spends unplugged, but the various surveys that were 

19 mentioned on the last page indicated that there is no 

20 active mode operation in the months of November to 

21 March and that there are few active mode hours of 

22 operation in April.

23 So for that reason DOE assumes that in the 

24 November to March timeframe that they are unplugged 

25 for the entire time and that for half of April a 
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1 dehumidifier would be unplugged leading to a total of 

2 3,984 hours that are just removed from the calculation 

3 because there's no energy use at all.

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

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

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

7 allocated to things other than active mode, to 

8 operating modes other than active mode. 

9 So, DOE examined or estimated the typical 

10 hours that a dehumidifier would spend in the bucket11 full or removed mode and in delay start mode. The 

12 bucket-full/removed mode hours were based on a product 

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

14 removal which is based on the distribution of 

15 shipments, that this is the predominant dehumidifier 

16 product class and that the analysis was based on an 

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

18 standard. That standard will not go into effect until 

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

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

21 affected because the hours are based on how much --

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

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

24 DOE examined various products and came up 

25 with a calculated average of 18.7 pints as the typical 
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1 bucket size in that product class and also made the 

2 assumption that consumers are not likely to empty a 

3 dehumidifier bucket more than once per day. 

4 For delay start mode hours, DOE's 

5 observation in its research was that 19 percent of 

6 products offer this feature and with the lack of 

7 consumer usage data made a preliminary estimate that 

8 half of these units would have consumers using that 

9 feature and that for those consumers that did use 

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

11 times of the days that dehumidification is called for. 

12 Further, because the maximum delay start on 

13 products with that capability was found to be 24 

14 hours, DOE made a preliminary estimate that the 

15 average time that consumers would select when they 

16 chose to operate with delay start would be half of 

17 that, would be a 12-hour delay.

18 With those assumptions DOE was able to 

19 estimate the typical hours spent in the delay start in 

20 bucket full or removed mode and therefore would 

21 allocate the remaining hours to the off-cycle or 

22 inactive mode; the remaining hours that are not 

23 unplugged or active mode. The delay start, bucket 

24 full and removed mode in off cycle or inactive mode 

25 hours -- I'm sorry, not hours, power, those levels 
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1 were based upon DOE measurement of a test sample of 13 

2 dehumidifiers; and the active mode typical power for 

3 this product class was derived from the analysis that 

4 was completed for the last standards rulemaking for 

5 dehumidifiers. And the information for that is in the 

6 2007 ANOPR.

7 So based on that, on the far right-hand side 

8 we see the annual energy use associated with each 

9 mode. Again, you can observe that the active mode is 

10 by far larger than any of the other non-active modes. 

11 And similarly to what was discussed for dishwashers 

12 because delay start mode is being assumed to be part 

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

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

15 consumption, the power levels there are comparable to 

16 the value in the off-cycle, inactive, and off mode and 

17 therefore DOE is again allowing those or proposing 

18 those hours to be allocated into the off-cycle, 

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

20 start energy use.

21 Okay. And that would bump up the hours for 

22 the off-cycle, inactive, and off modes to 3,024. 

23 Because not all dehumidifiers have the same 

24 capabilities, they don't all -- they aren't all able 

25 to operate in the off-cycle, inactive and off mode and 
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1 for the same reason before as the dishwashers, the 

2 lack of any further information on how to divide them,

3 DOE is proposing to divide them evenly if a 

4 dehumidifier has the capability for operating in two 

5 or three of those modes.

6 The methodology for calculating the annual 

7 energy use associated with standby and off modes is 

8 the same as was presented for dishwashers, which is 

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

10 the allocated hours would be multiplied together. All 

11 of those contributors for the different possible modes 

12 would be summed and that would be expressed in 

13 kilowatt hours per year. 

14 DOE, again, to offer the possibility of 

15 reduced test burden is considering an alternative 

16 approach in which the off-cycle, inactive, and off 

17 modes would be the only modes measured and that the 

18 hours for bucket full and removed mode would be rolled 

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

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

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

22 comments here. Brice.

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

24 all, I appreciate you looking at reducing test burden 

25 with all the standby modes. One, the bucket full, I 
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1 wanted to make a comment on that. Having the 

2 opportunity to pull many units from the field and look 

3 at -- basically look at them for reliability one of 

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

5 about 50 percent of the units were actually connected 

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

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

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

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

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

11 how to do that.

12 MR. BOWLEY: Yeah.

13 (Laughter.) 

14 MR. BOWLEY: But anyway, of the hours 

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

16 actually closer -- you know, assuming all the other 

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

18 what you had calculated, based on that.

19 MR. BROOKMAN: Okay.

20 MS. REICH: Okay. Thank you.

21 MR. BROOKMAN: Good. 

22 (Simultaneous conversation.) 

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

24 yes.

25 MR. BROOKMAN: That's good. Okay. 
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1 Other comments? Jennifer.

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

3 here that I made in the beginning of our meeting 

4 today. Certainly understand that DOE is trying to 

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

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

7 from page 75307 of the Federal Register. 

8 "DOE is not aware of any reliable consumer 

9 usage data on the number of hours per year 

10 dehumidifiers spend in delay start and bucket full or 

11 removed mode. In the absence of such data DOE 

12 estimated the time spent on these modes in the manner 

13 described below." And then the manner described below 

14 consists of a series of unsupported estimations as I, 

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

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

17 DOE should not be acting and cannot act without that 

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

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

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

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

22 described, and that’s very problematic.

23 MR. BROOKMAN: Okay. 

24 MR. ANDERSON: This is Wes with the 

25 Department of Energy -- Wes Anderson with the 
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1 Department of Energy. Given that that's -- the data 

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

3 input from manufacturers who we thought would have 

4 this information, we -- and given that we are required 

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

6 either look at our -- the way we determine our number, 

7 maybe -- do we need to explain that in more detail how 

8 we determined these -- how we came to our assumption? 

9 Because it's -- you know, would that be satisfactory? 

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

11 your comment?

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

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

14 comments. And certainly if we have anything to share 

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

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

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

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

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

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

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

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

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

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

25 that there is no data and to refrain from taking an 
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1 arbitrary action.

2 MR. ANDERSON: Well, I would argue against 

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

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

5 numbers and we base it on test -- an experiment. So, 

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

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

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

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

10 that out for public comment, then manufacturers can 

11 comment on if it were not going in the right 

12 direction.

13 MR. BROOKMAN: Eric Stas.

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

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

16 on data from AHAM itself?

17 MS. REICH: There are quite a few 

18 assumptions that were DOE estimates. Because --

19 specifically because there was no data available.

20 MR. STAS: And that factors into this and 

21 the data is from AHAM; correct?

22 MS. REICH: Some data is, yes.

23 MS. CLEARY: And I wasn't actually 

24 referencing that. And the portion I read was a 

25 separate issue that wasn't based on any data.
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1 MR. BROOKMAN: Okay. Okay. So additional 

2 comments on this segment?

3 Yes, Joanna.

4 MS. MAUER: Judy, could you just describe --

5 maybe you described this earlier, but what inactive 

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

7 function is or when a dehumidifier is in inactive 

8 mode?

9 MS. REICH: That would be if -- if it is 

10 just sitting with a display on, maybe an indicator 

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

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

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

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

15 be simply activated.

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

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

18 in that or do manufacturer have any comments on 

19 whether they'd be in --

20 MR. BROOKMAN: Brice.

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

22 unclear on the inactive for dehumidifiers as well. To 

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

24 no external remotes that I'm aware of for 

25 dehumidifiers. If there was an external remote there 
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1 might be an inactive, but as it is, if it's plugged in 

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

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

4 really don't --

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

6 MR. BOWLEY: Yes.

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

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

9 shows you the bucket -- or red light that shows the 

10 bucket is full.

11 MR. BOWLEY: Yes, usually. 

12 MR. BROOKMAN: Yeah.

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

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

15 mean, I understand DOE has studied it and apparently 

16 they have modes they would classify as inactive, but 

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

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

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

20 plugged in. It would either be operating in active 

21 mode or in off cycle mode.

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

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

24 MS. REICH: Okay.

25 MR. BROOKMAN: James.
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1 MR. BATTAGLIA: James Battaglia. I think we 

2 saw -- in our test sample we saw a few dehumidifiers 

3 with remote controls.

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

5 basically a dehumidifier with a remote control. It 

6 would be inactive.

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

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

9 fit that definition, but that's the --

10 (Simultaneous conversation.) 

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

12 looked at --

13 MR. BATTAGLIA: Right. 

14 MR. BOWLEY: Okay.

15 MR. BROOKMAN: Okay. Other comments on 

16 these dehumidifier issues?

17 (No response.)

18 MR. BROOKMAN: Wes is suggesting we take a 

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

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

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

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

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

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

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

2 (Meeting resumes at 11:55 a.m.)

3 MR. BROOKMAN: We're going to try and keep 

4 going right along here. For those of you that are 

5 listening via the web, the room here at the Forrestal 

6 Building is probably 68 degrees or in that general 

7 range. It's a little nippy in here. And we're trying 

8 to boost the heat. So those of you that are comfy in 

9 your offices or at home --

10 So let's resume and we're going back to Judy 

11 Reich.

12 MS. REICH: Okay. So we have finished with 

13 dishwashers and dehumidifiers. The final products are 

14 conventional cooking products. So they are not the 

15 subject of energy conservation standards at this time. 

16 But historically in analyzing them, the metric that's 

17 been used and has been defined in the test procedure

18 is energy factor, which is the ratio of annual cooking 

19 energy output to the annual energy input. And DOE is 

20 proposing to maintain this metric incorporating 

21 standby and off mode energy use into it rather than an 

22 annual energy use metric.

23 So, we'll talk about the usage patterns and 

24 power consumption in these modes that DOE looked at on 

25 an annual basis, but recognized that it's going to be 
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1 rolled in essentially on a per-cycle basis.

2 Ah, let's see, for conventional ovens, DOE 

3 investigated the typical time and energy consumption 

4 associated with active mode as well as the other modes 

5 that have been identified, namely the Sabbath mode, 

6 delay start mode, cycle finished mode, and off and 

7 inactive mode. Again, very limited data on usage 

8 patterns. For Sabbath mode, DOE was able to 

9 determine, able to locate some survey data that was 

10 developed by the United Jewish Communities on the 

11 number of U.S. households that keep a kosher home and 

12 on that basis as well as determining the number of 

13 hours that somebody who followed kosher practices 

14 would be using that feature, came up with an average 

15 of 8.9 hours that a typical oven spends in Sabbath 

16 mode.

17 For delay start mode, this was an area where 

18 DOE did not have information at all but assumes that 

19 for those products that have it, that 50 percent of 

20 consumers use it for 5 percent of cycles. And that 

21 they would program it for typically a 12-hour day. 

22 This is a preliminary estimate based on half of the 

23 maximum delay start time that's possible. 

24 And, just, you know, sort of as a reality 

25 check DOE notes that 12 hours is roughly the time that 
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1 would be between if somebody were setting up a cooking 

2 process in the morning for dinner being available when 

3 they came home. 

4 Cycle finished mode is purely a DOE 

5 estimate. It was assumed to be five minutes per 

6 cooking cycle. Typically, I think, you know, people 

7 don't leave food for hours in the oven when they're 

8 done. So DOE estimated five minutes. And so you can 

9 see for delay start and cycle finished mode they wind 

10 up with 61 annual hours and cycle finished mode was 

11 18. That left 8,461 in off and inactive mode because 

12 subtracting out 211 hours that were assumed from the 

13 previous standards analysis to be associated with 

14 active mode. 

15 DOE determined typical power levels by 

16 testing 12 conventional ovens. For active mode that 

17 was based on measurements for a baseline efficiency, 

18 electric self-cleaning oven. The annual energy use on 

19 the far right-hand side shows very small contributions 

20 from Sabbath mode, delay start mode, and cycle 

21 finished mode and still relatively small from off and 

22 inactive.

23 Actually I want to correct myself. I made a 

24 note here. The 211 hours comes from RECS data, the 

25 Residential Energy Consumption Survey from 2005. And 
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1 that data indicates that 211 hours are spent in active 

2 cooking mode.

3 Because DOE proposes to define delay start 

4 mode and Sabbath mode as part of active mode and not 

5 standby or off mode, it is not proposing to measure 

6 the energy consumption in either of them, but instead 

7 would allocate the hours that a product would spend in 

8 those modes to the inactive and off mode in the case 

9 of delay start and into the active mode hours for 

10 Sabbath mode.

11 For those units that don't have any cycle 

12 finished mode, DOE would roll those hours into the off 

13 and inactive mode also. For the same reason that 

14 we've already talked about that it's unlikely that a 

15 product would have capability for both off and 

16 inactive mode, because that's typically associated 

17 with the type of controls it has, but if it has 

18 electronic controls and a mechanical on/off switch, 

19 both modes are possible and DOE proposes to evenly 

20 divide the off and inactive mode hours between the two 

21 modes.

22 I won't talk about that same methodology as 

23 has already been discussed several times, but how to 

24 come up with the annual energy use, and that, again, 

25 as an alternative for reducing the test requirements 
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1 that because of the relative -- relatively comparable 

2 power levels in cycle finished mode to those in off 

3 and inactive mode that the cycle finished mode hours 

4 could be rolled in so that only a single off and 

5 inactive mode measurement would need to be made. 

6 (Pause.) 

7 MS. REICH: That was it for ovens.

8 For cook tops it's a similar situation as 

9 for ovens. Although, interestingly, the Sabbath mode 

10 is a little different for cook tops because the 

11 allowable or required functionality in Sabbath mode is 

12 different. So you will see the typical power is much 

13 higher. And that's because for a cook top the 

14 requirement is that the controls, that the heating 

15 elements or burner cannot be adjusted up or down 

16 during the Sabbath period. So it requires for Sabbath 

17 compliant products that they be set at some low level 

18 that is -- you know, a consumer would feel safe 

19 leaving it on continuously. And so DOE estimated that 

20 that power level would be approximately 25 percent of 

21 the typical power during a normal cooking process.

22 But even so, even with that higher power 

23 level, because of the very small percentage of U.S. 

24 households that do observe the kosher practices that 

25 on average the annual energy use associated with 
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1 Sabbath mode is still quite small.

2 Also want to point out that DOE is not aware 

3 of any delay start or cycle finished mode for cook 

4 tops.

5 DOE believes that the Sabbath mode is part 

6 of an active mode and so is proposing to allocate the 

7 Sabbath mode hours into active mode hours. And for 

8 the same reasons we've heard that if it has the 

9 capability for both off and inactive mode it would --

10 DOE proposes to split those hours evenly. And, again, 

11 going through and calculating an annual energy use 

12 associated with off and inactive modes.

13 And, by the way, in the next section I'll 

14 discuss the calculations that are made that would 

15 actually integrate an annual energy use into the 

16 energy factor for a cooking product.

17 And finally, for conventional ranges, these 

18 are essentially because they have an oven and a cook 

19 top together, much of this information would be 

20 comparable to the two products. The only difference 

21 or the only thing I would want to point out is, again, 

22 for Sabbath mode, because of the inherent difficulties 

23 or greater difficulty in using a cook top as opposed 

24 to an oven during a Sabbath period that it's likely 

25 that a consumer with a range that had a Sabbath mode 
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1 function in the oven would use that for the cooking 

2 process.

3 Here the typical powers were based on DOE 

4 tests of 21 conventional ranges and that the active 

5 mode power is simply assumed to be the sum of the oven 

6 power and the cook top power, the typical levels.

7 So, again, delay start and Sabbath mode 

8 hours would be allocated appropriately to either the 

9 inactive off mode for delay start and active mode for 

10 Sabbath hours. And, again a methodology for units 

11 without cycle finished mode, those hours would just go 

12 into off and inactive mode. And if they have the 

13 capability for both off and inactive, the hours would 

14 be split evenly.

15 And, finally, I apologize for the 

16 repetition, but this is the same methodology to 

17 calculate from the measured watts what the annual 

18 energy use in kilowatt hours would be for each mode 

19 and then adding them up. And then the possibility of 

20 an alternative approach, a more streamlined approach 

21 that would put all of the cycle finished mode hours 

22 into off and inactive so that a single measurement 

23 would only be necessary.

24 So, I think we've already commented on 

25 dishwashers and dehumidifiers. Any similar comments 
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1 on cooking products referring to the allocation of 

2 annual hours and test burden as well as the 

3 alternative methodology to allocate annual hours in 

4 each mode?

5 MR. BROOKMAN: Jennifer.

6 MS. CLEARY: Thanks. This would just be 

7 another area where we would point to a lack of data in 

8 many areas and I think that you drew them out here and 

9 we'll cull out specific ones in our written comments. 

10 But the comments continue in this area as well.

11 MR. BROOKMAN: Okay. Thank you.

12 Joanna.

13 MS. MAUER: Joanna Mauer. Just to reiterate 

14 a couple of general comments. For all products I 

15 think the case where you have electronic controls plus 

16 a mechanical on/off switch, we just encourage DOE to 

17 make some kind of specification regarding the 

18 placement of that mechanical switch. We would also 

19 encourage DOE to develop a test procedure that 

20 actually measures the energy use in all the different 

21 modes that have been identified such as cycle finished

22 mode just to avoid any potential loopholes in the 

23 future where some nontrivial energy-consuming feature 

24 wouldn't be captured in the test procedure. 

25 I also had kind of a general question 
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1 regarding how the hours were estimated for delay start 

2 and cycle finished mode. Are those hours -- or does 

3 that estimate of hours include products that don't 

4 have, for example, cycle finished mode so that it's 

5 kind of a weighted average that includes products that 

6 by definition have zero hours in cycle finished mode, 

7 for example?

8 MS. REICH: No, the estimate is intended to 

9 be for those products that have that capability. And 

10 if the product doesn't have it, the hours would be put 

11 into the off and inactive mode.

12 MS. MAUER: Okay. And I think that's an 

13 appropriate methodology. It sounded to me in the 

14 Federal Register notice that it may have included all 

15 products, but I can -- I'll look at that again --

16 MS. REICH: We can confirm that.

17 (Simultaneous conversation.)

18 MR. BROOKMAN: So then final comments on 

19 this because we're going to move on.

20 (No response.)

21 MR. BROOKMAN: Measures of energy 

22 consumption.

23 Measures of Energy Consumption

24 MS. REICH: Okay. So the regulatory 

25 requirement is that the test procedures shall be 
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1 amended to include standby and off-mode energy 

2 consumption into the overall energy efficiency 

3 descriptor for each covered product. And this is what 

4 EISA amended EPCA to require.

5 So DOE, for each of these products, examined 

6 the existing measures of energy consumption to see 

7 whether standby and off-mode power could be integrated 

8 into the existing metric to form a single combined or 

9 integrated metric. And in doing so DOE first notes 

10 that the test procedures for dishwashers and cooking 

11 products already incorporate at least some form of 

12 standby power into the existing metric. For 

13 dishwashers there is a standby power measurement and 

14 for conventional cooking products there is a 

15 requirement to measure clock power. So, that provides 

16 evidence that those metrics can be expressed as an 

17 integrated metric once all standby and off-mode power 

18 is accounted for. 

19 So to detail that, for dishwashers, the 

20 measure of standby power is already included in the 

21 efficiency descriptor that's the basis of the current 

22 standard which is estimated annual energy use or EAEU. 

23 And DOE notes that the magnitude of standby and off24 mode energy use is such that integrating it would be 

25 measurable in changes in standby power, it would 
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1 produce a measurable difference in EAEU so, therefore, 

2 would factor into any standard setting process, but is 

3 not so great that it would overwhelm the effect of 

4 variations in active energy -- active-mode energy use, 

5 how that would contribute to the EAEU.

6 So, therefore, DOE believes that an 

7 integrated metric is technically feasible and is 

8 proposing amendments that would fully account for 

9 standby-mode and off-mode energy consumption.

10 So the proposed amendments would require 

11 measuring an addition standby mode beyond the standby 

12 mode that would currently be defined, the cycle 

13 finished mode, and would require the measurement of 

14 off mode. And it would also revise the existing 

15 definition of standby mode.

16 So these three additional modes, the 

17 inactive, off, and cycle finished modes may result in 

18 energy consumption levels slightly higher than what 

19 the current test procedure would result in. But the 

20 proposed amendments would clarify that this new 

21 measure would not be required to be used by 

22 manufacturers to determine compliance with existing 

23 energy conservation standards and would not be 

24 required for that purpose until the dishwasher 

25 standards are updated to take into account the 
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1 effective -- whoops -- of standby and off-mode energy 

2 use.

3 There is also an estimated annual operating 

4 cost calculation in the CFR and DOE is proposing to 

5 adjust that also for the additional cost associated 

6 with standby and off-mode energy use.

7 Because energy factor is not currently used 

8 as the basis of any standards, DOE is not proposing to 

9 amend the calculation of EF so leaving that metric as 

10 is.

11 And finally, for reasons that -- really more 

12 for clarification and to ensure consistency when these 

13 measurements are made, DOE is proposing to ensure that 

14 all the rounding instructions are provided for the 

15 final values of energy factor, EAEU, and water 

16 consumption in the test procedure. 

17 Question?

18 MR. BROOKMAN: Yes, Amanda.

19 MS. STEVENS: Stevens. Could you just very 

20 briefly -- I know we're trying to move on -- clarify 

21 what the rounding instructions are? 

22 MS. REICH: Let's see, for EAEU it would 

23 require that the value be rounded to the nearest 

24 kilowatt hour, for water consumption it's gallons per 

25 cycle to the first decimal place, and energy factor I 
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1 think that's two decimal places. 

2 MS. STEVENS: Clarify when the rounding 

3 should occur? I'm asking for a point of clarification 

4 because ENERGY STAR also included some rounding 

5 clarifications and I just want to make sure that we're 

6 --

7 MS. REICH: It's the final calculation.

8 MS. STEVENS: The final calculation. Okay. 

9 All right. Thank you.

10 MS. REICH: Now, for dehumidifiers, the test 

11 procedure currently does not have any measure of 

12 standby or off-mode power. It's only looking at 

13 active-mode energy use when calculating energy factor. 

14 This is, again, liters of water removed per kilowatt 

15 hour and it is on the basis of a 24-hour test cycle. 

16 The measurements and estimates that DOE has made lead 

17 it to conclude that the -- that rolling in the standby 

18 and off-mode energy use is technically feasible 

19 because it is a significant enough value to have a 

20 noticeable impact on the standard metric, but it's not 

21 so great that rolling it in would essentially wash out 

22 all the effects of efficiency in active mode.

23 So DOE is proposing to create a new 

24 integrated metric -- integrated energy factor, IEF, in 

25 which the energy use in standby power would be 
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1 allocated. The annual energy use in standby power 

2 would be allocated to those associated with a 24-hour 

3 period that the test cycle covers.

4 And this is the equation that is proposed, 

5 just to make that a little clearer, IEF is the liters 

6 of water removed during the test divided by the sum of 

7 the active mode energy use during that 24 hours and 

8 then the energy use -- the annual energy use in 

9 standby and off mode that is scaled by the period of 

10 24 hours which is the test cycle divided by the total 

11 number of active mode hours.

12 And for rounding instructions DOE is 

13 proposing that that final IEF value be rounded to two 

14 decimal places. 

15 For conventional cooking products, there are 

16 -- within the energy consumption measure and energy

17 factor calculation there are various types of energy 

18 consumption that are measured and calculated. They're 

19 listed here, test energy consumption, annual cooking 

20 energy consumption, the annual energy associated with 

21 pilot lights which in 2012 will become zero, annual 

22 self-cleaning energy consumption for ovens and for 

23 ovens also annual clock energy consumption and all of 

24 those get rolled up into a total annual energy 

25 consumption.
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1 As I mentioned previously, there is no 

2 performance-based standard for cooking products, 

3 conventional cooking products. There is a 

4 prescriptive preclusion of standing gas pilots. But 

5 historically DOE has used energy factor as the basis 

6 of its analysis for potential standards, so DOE 

7 considered rolling any standby and off-mode use into 

8 that energy factor metric.

9 And because already, for example, in the 

10 pilot energy consumption and the clock energy 

11 consumption, these are forms of standby power, DOE 

12 believes it's meaningful to incorporate other types of 

13 standby and off-mode energy use into it. So it's 

14 proposing integrated metrics.

15 For conventional ovens, the integrated 

16 annual energy consumption would be the sum of the 

17 contribution from standby and off mode as well as the 

18 primary cooking energy use and annual self-cleaning 

19 energy consumption.

20 For gas ovens, this would be the same thing 

21 with the addition of annual secondary cooking energy 

22 which I believe is the electrical energy associated 

23 with the cooking process in addition to the gas 

24 primary cooking energy.

25 The integrated energy factor then for ovens 
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1 would be the annual useful cooking output, that's the 

2 energy that's used to -- that's delivered to the food 

3 load, divided by this integrated annual energy 

4 consumption. 

5 For gas ovens, because it has both the gas 

6 portion and the electrical portion, the annual use for 

7 cooking energy output would be divided by the sum of 

8 the gas and the electric energy consumptions. 

9 And I think this was a question that was 

10 posed earlier, how to handle multiple conventional 

11 ovens and similar metrics are being provided for the 

12 case where there's, say, a double oven.

13 Conventional ranges, it's simply the sum of 

14 the two components. So integrated annual energy 

15 consumption would be the integrated annual energy 

16 consumption for the cook top plus the one for the 

17 oven. Plus the overall range standby mode and off18 mode energy consumption. It too would have an 

19 integrated energy factor. It's defined as the annual 

20 useful cooking output divided by the sum of the 

21 integrated annual energy consumption for the two 

22 components.

23 MR. ANDERSON: Excuse me, Judy. This is Wes 

24 from the Department of Energy. We are now -- we 

25 skipped ahead to slide 74, for those on line, so you 
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1 can just --

2 MS. REICH: I'm sorry, did I miss --

3 MR. BROOKMAN: Maybe you missed 76.

4 MR. ANDERSON: Oh, I'm sorry, we're on 76. 

5 (Simultaneous conversation.)

6 MS. REICH: Okay. I apologize. Okay. 

7 MR. BROOKMAN: So we're on slide 76.

8 MS. REICH: Okay. Let me retrace then. So 

9 for conventional cook tops the integrated annual 

10 energy consumption is the annual standby energy use 

11 plus the useful cooking energy output divided by the 

12 cooking efficiency. That's how the cooking portion of 

13 the annual energy consumption is obtained.

14 For gas cook tops, it's the same approach 

15 with standby and off mode energy use in the numerator 

16 and -- I'm sorry, being summed with the annual 

17 consumption for gas consumption for cooking and the 

18 annual energy consumption of the gas standing pilot 

19 for the time being.

20 Okay. For integrated energy factor, for 

21 electric cook tops, it's the useful cooking energy 

22 output divided by the integrated annual energy 

23 consumption and that's the same actually for electric 

24 and gas. 

25 MR. BROOKMAN: And I think you've gotten 
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1 most of 77 covered. So maybe you can just summarize 

2 that.

3 MS. REICH: Okay. It's basically for 

4 conventional ranges. It's just the sum of the two 

5 parts, the cook top and the oven.

6 MR. BROOKMAN: Right.

7 MS. REICH: So, in addition to creating 

8 these new integrated energy factor measures DOE is 

9 proposing to update to amend the annual energy cost 

10 calculations to include the cost associated with the 

11 standby and off mode energy use.

12 In terms of rounding instructions, again, 

13 the annual operating cost would be rounded to the 

14 nearest dollar and the rounding requirements for IEF 

15 would be to three significant digits. 

16 DOE would invite comment on these integrated 

17 energy factor metrics for dehumidifiers and 

18 conventional cooking products. Also invites comments 

19 on the proposed amendments to modify estimated annual 

20 energy use and estimate annual operating cost metrics 

21 for dishwashers, and actually it's also costs for 

22 cooking products, and to incorporated the revised 

23 measurements of standby mode and off mode energy 

24 consumption.

25 MR. BROOKMAN: Comments here? Joanna.
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1 MS. MAUER: In terms of the integrated 

2 metric for conventional cooking products, I'm trying 

3 to think about how this relates or is similar to the 

4 situation with microwaves. And my understanding is 

5 that for both conventional cooking products and 

6 microwaves DOE analysis in the past has shown that 

7 there's maybe not significant energy savings, 

8 potential or not cost effective savings potential for 

9 active mode energy use. But now we have a rulemaking 

10 for standby energy for microwaves and so we're going 

11 to have a separate standby metric for microwaves. And 

12 so I guess my question is, if we have an integrated 

13 metric for conventional cooking products, does that 

14 eliminate the possibility in the future of a standard 

15 for standby energy use for conventional cooking 

16 products?

17 MS. REICH: The statutory requirement is 

18 that the metric must be integrated if it's technically 

19 feasible. And for microwave ovens the active mode 

20 portion was eliminated on the basis of inherent 

21 problems in the measurement. It was not the separate 

22 metric for standby power is not being proposed because 

23 there are no opportunities to improve active mode 

24 efficiency. It's that the portion, if it were 

25 integrated the active mode portion was fundamentally 
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1 flawed and was removed. So there is no metric to roll 

2 it into anymore. So therefore it must be a separate 

3 prescriptive requirement. So it's not the same 

4 situation with the cooking products, and, again, it's 

5 this EISA requirement that a single metric must be 

6 defined unless it's technically infeasible to do so.

7 MR. BROOKMAN: Additional comments on this 

8 series of measures?

9 (No response.)

10 Compliance with Other EPCA Requirements and

11 Impact of the proposed Amendment on EnergyGuide

12 and ENERGY STAR

13 MS. REICH: Okay. Getting towards the end 

14 here. The next section discusses compliance with 

15 other EPCA requirements.

16 We've hit on this quite a bit in terms of 

17 test burden in discussing the methodology and there is 

18 a requirement under EPCA that any test procedures 

19 prescribed or amended under this section shall be 

20 reasonably designed to produce test results which 

21 measure energy efficiency, energy use, or estimated 

22 annual operating cost of a covered product during a 

23 representative average use cycle or period of use and 

24 shall not be unduly burdensome to conduct.

25 In sum DOE believes that the proposed 
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1 amendment satisfied this requirement. First of all it

2 believes it's representative, the IEC Standard 62301 

3 is an international standard used to measure standby 

4 power and off-mode power. And DOE believes it will 

5 produce power consumption measurements that are 

6 representative of an average use cycle. DOE also 

7 believes that the test methods and associated 

8 equipment would not require manufacturers to make 

9 major changes and major investments in their 

10 facilities or purchase -- or extensive investments in 

11 new equipment in order to make the measurements.

12 EPCA also directs DOE to consider IEC 62087, 

13 “Methods of measurement for power consumption of 

14 audio/video and related equipment.” But this is 

15 basically just not applicable to the products that are 

16 considered today. So DOE has fulfilled the 

17 requirement to consider it, but has determined it's 

18 inapplicable.

19 And here is the section of EPCA as amended 

20 by EISA that requires this single metric, if it's 

21 technically feasible. It says it must be integrated 

22 into the overall energy efficiency, energy 

23 consumption, or other energy descriptor for each 

24 covered product, unless a test procedure already 

25 accounts, fully accounts for standby mode and off-mode 
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1 energy use or if such an integrated method is 

2 technically infeasible. So for the reasons that in 

3 each case there's either already measures of standby 

4 and energy use there, or because -- and/or because the 

5 magnitude of the energy use that would be newly 

6 measured is measurable with an integrated metric but 

7 doesn't overwhelm the existing active mode metric, DOE 

8 believes that in all cases it's technically feasible 

9 to define single integrated metrics.

10 And these would be for dishwashers, the EAEU 

11 and the estimated annual operating costs and for 

12 dishwasher -- or dehumidifiers, integrated energy 

13 factor, and conventional cooking products, an 

14 integrated annual energy consumption and integrated 

15 energy factor.

16 EPCA requires that DOE consider how the 

17 amendments to the test procedure would affect 

18 compliance with existing standards. Although the 

19 revisions to the dishwasher test procedure, because 

20 that already includes a measure of standby power, 

21 there would be some slight revision to the calculation 

22 of EAEU, DOE doesn't believe that that would be 

23 significant. And also the fact DOE would provide 

24 clarifying language that the new provisions would not 

25 be required to determine compliance until new 
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1 dishwasher standards became effective.

2 For dehumidifiers an entirely new metric is 

3 being defined, the IEF, and energy factor which is the 

4 basis of the existing standards would not be affected. 

5 Therefore, the test procedure amendment would have no 

6 effect on compliance.

7 And then finally for cooking products there 

8 are no standards -- performance standards for them and 

9 so the definition of integrated metrics has no effect. 

10 There's nothing for it to affect.

11 MR. BROOKMAN: Yes, Natascha.

12 MS. MILESI: I have a clarifying question. 

13 With regard to the delay of compliance, I understand 

14 for EAEU, but what about EAOC; is that also delayed 

15 reporting of the costs that include standby?

16 MS. REICH: I believe that would be 

17 similarly delayed because it would be based on the 

18 provisions that would be calculating EAEU.

19 MS. MILESI: But it would not affect the 

20 standard? It would not affect the product's 

21 qualification or meeting the minimum energy 

22 requirements?

23 MS. REICH: That's right. Yes. Well, that 

24 would be based on EAEU, the compliance requirement and 

25 so that new calculation would not be required until 
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1 such time as a new standard. And that was why DOE was 

2 proposing to keep the existing standby power 

3 methodology under a new name in the test procedures 

4 specifically because that portion will be used until 

5 the new standards come into effect.

6 MR. BROOKMAN: Amanda.

7 MS. STEVENS: I've got a question. As I was 

8 looking at the Federal Register notice and the test 

procedure, for dishwashers I saw a date of May 31st 9 , 

10 2011, so there's different sets of calculations for 

11 product manufactured before then and then on or after 

12 that date and I just wasn't sure, what's that date in 

13 reference to?

14 MS. REICH: Yeah, that's a very good 

question. May 31st 15 --

MS. STEVENS: It says, may 31st 16 , 2011, 

17 because I thought it would be a new standard --

18 (Simultaneous conversation.) 

19 MS. STEVENS: Yeah, so in the Federal 

20 Register notice it's 75321 so if you go down to the 

21 dishwasher section there, for the calculations that 

22 kind of sets forth two kinds of calculations broke out 

23 by that date which didn't --

24 PARTICIPANT: (Off microphone.) Can you give 

25 me the page number?
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1 MS. STEVENS: Yes, sorry, it's 75321.

2 MR. BROOKMAN: Well, let's let them take a 

3 peek and see if they can come up with the answer while 

4 we're taking other questions or comments. Eric.

5 MR. STAS: We have to check into this, but 

6 one thing that might have happened was when the 

7 document got sent to the Federal Register perhaps they 

8 accidentally inserted a date when they should have 

9 been saying some date before the final rule for test 

10 procedures get finalized and after, or something. So 

11 I'm not sure if these dates belong in here yet.

12 MS. STEVENS: Okay. Okay.

13 MR. STAS: That's one possible thing.

14 MS. STEVENS: Okay.

15 MR. STAS: And Judy, I was going to ask you, 

16 I think we talked about this before, for some of these 

17 cost calculations --

18 MS. REICH: Uh-huh.

19 MR. STAS: -- whether that was something 

20 that we said was going to be reported. You know, I 

21 agree about the part about not be used for standards 

22 compliance purposes, but we were saying other purposes 

23 that the costs might be reported, is that --

24 (Simultaneous conversation.)

25 MS. REICH: I thought they were subject to 
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1 the same time requirements that whatever date that the 

2 annual energy use gets updated so would the annual 

3 operating costs. Because, you know, there's a desire 

4 to have them -- those two metrics be meaningful in 

5 comparison to each other.

6 MR. STAS: I think we need to go back and 

7 check what's in here on that point.

8 MS. REICH: Okay.

9 MR. STAS: But it's definitely the case for 

10 the standards compliance purposes.

11 MR. BROOKMAN: Other questions on this 

12 segment?

13 (No response.)

14 MS. REICH: Okay. All right. The last 

15 section is the impact of the proposed amendment on 

16 EnergyGuide and ENERGY STAR.

17 So, for EnergyGuide, this is a program that 

18 is administered by the Federal Trade Commission. And 

19 for dishwashers because the EAEU and EAOC and water 

20 consumption would not be modified until the new date 

21 of standards, the relative metrics that are used for 

22 both EnergGuide and ENERGY STAR wouldn't be impacted 

23 at all at this time.

24 For dehumidifiers there is no EnergyGuide 

25 labeling program currently and the ENERGY STAR 
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1 certification or qualification requirements are based 

2 on energy factor which is left alone in the amended 

3 test procedure. So that would be unaffected.

4 For conventional cooking products, there is 

5 no EnergyGuide or ENERGY STAR requirements, so, again, 

6 no impact.

7 MR. BROOKMAN: Okay.

8 MS. REICH: And that wraps up the 

9 discussion.

10 MR. BROOKMAN: That's all the presentation 

11 material. And Judy has put up there the closing slide 

12 that references the numbers that are relevant. I'm 

13 going to return to Wes to closing in just a moment. 

14 But as we promised at the outset, now is an 

15 opportunity for anybody that wants to do so, to make 

16 closing remarks to describe other issues that haven't 

17 been covered fully in the course of the proceeding 

18 today. Yes, James.

19 MR. BATTAGLIA: I just want to confirm what 

20 Eric was saying about that May 31 date, it should have 

21 been 180 days after the publication of the final rule. 

22 And I guess the Federal Register just entered it in --

23 MR. BROOKMAN: They just inserted something.

24 MR. BATTAGLIA: 180 days after publication

25 of the NOPR, I guess.
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1 MR. BROOKMAN: Okay. Thanks for that, 

2 James.

3 Yeah. Okay. Closing remarks, final 

4 comments on today's meeting?

5 (No response.)

6 MR. BROOKMAN: I see none. And so from my 

7 perspective I'll thank everybody that joined from the 

8 web. 

9 I hope this was constructive and useful for 

10 you. I hope you were able to follow okay. And back 

11 to Wes for closing remarks.

12 Conclusions and Closing Remarks

13 MR. ANDERSON: I would like to also thank 

14 you guys for helping us out with the new webinar 

15 process. Although we only got one question, we look 

16 forward to doing this more often and maybe more 

17 interactively down the road. 

18 Again, thank you for coming out in cold 

19 conditions outside, as well as in, and braving the 

20 environmental conditions here.

21 To submit your comments, remember our 

comment period ends on February 15th 22 and remember 

23 that's pretty much something like 45 days from 

24 publication. So, generally DOE has -- I mean, we 

25 accept comments at any time and we would like to 
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reiterate that comment period ends on February 15th 1 . 

2 We would be less likely -- the later you are, the less 

3 likely your comments would affect the final rule.

4 You can submit your information to Brenda 

5 Edwards as it is stated on slide 86 by mail or courier 

6 or at the e-mail address. And please put -- and also 

7 when you submit your comments reference the docket 

8 number and/or the RIN. That's all I have. 

9 Do you have any other comments?

10 (No response.)

11 MR. ANDERSON: So I officially close this 

12 discussion and I look forward for your comments.

13 Thank you very much. Goodbye.

14 MR. BROOKMAN: Thanks to all who 

15 participated.

16 (Whereupon, at 12:40 p.m., the meeting was 

17 adjourned.)

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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 party to the above proceedings.

Wendy Greene

 Official Reporter

Dated: January 20, 2011