Vol. 76 Thursday 

No. 4 January 6, 2011 

Part III 

Department of 

Energy 

10 CFR Part 430 

Energy Conservation Program for Consumer Products: 

Test Procedures for Clothes Dryers and Room Air 

Conditioners; Final Rule 

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NARA.EPS FR.EPS
972 Federal Register / Vol. 76, No. 4 / Thursday, January 6, 2011 / Rules and Regulations 

DEPARTMENT OF ENERGY 

10 CFR Part 430 

[Docket No. EERE–2008–BT–TP–0010] 

RIN 1904–AC02 

Energy Conservation Program for 

Consumer Products: Test Procedures 

for Clothes Dryers and Room Air 

Conditioners 

AGENCY: Office of Energy Efficiency and 

Renewable Energy, Department of 

Energy. 

ACTION: Final rule. 

SUMMARY: The U.S. Department of 

Energy (DOE) amends its test 

procedures for residential clothes dryers 

and room air conditioners under the 

Energy Policy and Conservation Act 

(EPCA). The amendments provide for 

measurement of standby mode and off 

mode power use by these products and 

also amend the active mode test 

procedures for these products. For 

standby and off mode energy use, these 

amendments incorporate into the DOE 

test procedures relevant provisions from 

the International Electrotechnical 

Commission (IEC) Standard 62301, 

‘‘Household electrical appliances— 

Measurement of standby power,’’ (first 

edition June 2005), including language 

to clarify application of these provisions 

for measuring standby mode and off 

mode power consumption in clothes 

dryers and room air conditioners. In 

addition, DOE is adopting definitions of 

modes based on the relevant provisions 

from IEC Standard 62301 Second 

Edition Committee Draft for Vote. For 

active mode energy use, DOE adopts 

testing methods for ventless clothes 

dryers, test cloth preconditioning 

requirements for clothes dryer energy 

tests, test conditions for gas clothes 

dryers, test conditions for clothes dryer 

drum capacity measurement, 

amendments to clarify current clothes 

dryer usage patterns and capabilities 

and to update the references to industry 

standards in the room air conditioner 

and clothes dryer test procedures. 

DATES: This rule is effective February 7, 

2011. The incorporation by reference of 

certain publications listed in the rule is 

approved by the Director of the Federal 

Register on February 7, 2011. 

ADDRESSES: You may review copies of 

all materials related to this rulemaking 

at the U.S. Department of Energy, 

Resource Room of the Building 

Technologies Program, 950 L’Enfant 

Plaza, SW., Suite 600, Washington, DC, 

(202) 586–2945, between 9 a.m. and 4 

p.m., Monday through Friday, except 

Federal holidays. Please call Ms. Brenda 

Edwards at the above telephone number 

for additional information regarding 

visiting the Resource Room. 

FOR FURTHER INFORMATION CONTACT: Mr. 

Subid Wagley, U.S. Department of 

Energy, Office of Energy Efficiency and 

Renewable Energy, Building 

Technologies Program, EE–2J, 1000 

Independence Avenue, SW., 

Washington, DC 20585–0121. 

Telephone: (202) 287–1414. E-mail: 

Subid.Wagley@ee.doe.gov. 

Ms. Elizabeth Kohl, U.S. Department 

of Energy, Office of the General Counsel, 

GC–71, 1000 Independence Avenue, 

SW., Washington, DC 20585–0121. 

Telephone: (202) 586–7796. E-mail: 

Elizabeth.Kohl@hq.doe.gov. 

SUPPLEMENTARY INFORMATION: This final 

rule incorporates by reference into part 

430 the following industry standards: 

(1) AHAM HLD–1–2009 (‘‘AHAM 

HLD–1’’), ‘‘Household Tumble Type 

Clothes Dryers,’’ (2009). 

Copies of AHAM HLD–1 are available 

from the Association of Home 

Appliance Manufacturers, 1111 19th 

Street, NW., Suite 402, Washington, DC 

20036, (202) 872–5955, or http:// 

www.aham.org/. 

(2) ANSI/AHAM RAC–1–2008 

(‘‘ANSI/AHAM RAC–1’’), ‘‘Room Air 

Conditioners,’’ (2008; ANSI approved 

July 7, 2008). 

Copies of ANSI/AHAM RAC–1 are 

available from the American National 

Standards Institute, 11 West 42nd 

Street, New York, New York 10036, 

(212) 642–4936, or http:// 

webstore.ansi.org/. 

(3) ANSI/ASHRAE Standard 16–1983 

(‘‘ANSI/ASHRAE 16’’) (RA 2009), 

(Reaffirmation of ANSI/ASHRAE 

Standard 16–1983 [RA 1999]), ‘‘Method 

of Testing for Rating Room Air 

Conditioners and Packaged Terminal 

Air Conditioners,’’ ASHRAE approved 

October 18, 1988, and reaffirmed June 

20, 2009; ANSI approved October 20, 

1998 and reaffirmed June 25, 2009. 

Copies of ANSI/ASHRAE 16 are 

available from the American National 

Standards Institute, 11 West 42nd 

Street, New York, New York 10036, 

(212) 642–4936, or http:// 

webstore.ansi.org/. 

(4) International Electrotechnical 

Commission (IEC) Standard 62301 (‘‘IEC 

62301’’), ‘‘Household electrical 

appliances—Measurement of standby 

power (first edition June 2005).’’ 

Copies of IEC 62301 are available 

from the American National Standards 

Institute, 11 West 42nd Street, New 

York, New York 10036, (212) 642–4936, 

or http://webstore.iec.ch/. 

Table of Contents 

I. Background and Authority 

II. Summary of the Proposal 

III. Discussion 

A. Products Covered by the Test Procedure 

Changes 

B. Clothes Dryer and Room Air Conditioner 

Standby Mode and Off Mode Test 

Procedures 

1. Incorporating by Reference IEC Standard 

62301 for Measuring Standby Mode and 

Off Mode Power in Clothes Dryers and 

Room Air Conditioners 

2. Determination of Modes To Be 

Incorporated 

3. Adding Specifications for the Test 

Methods and Measurements for Clothes 

Dryer and Room Air Conditioner 

Standby Mode and Off Mode Testing 

a. Clothes Dryers 

b. Room Air Conditioners 

4. Calculation of Energy Use Associated 

With Standby Modes and Off Mode 

a. Clothes Dryers 

b. Room Air Conditioners 

5. Measures of Energy Consumption 

a. Clothes Dryers 

b. Room Air Conditioners 

C. Clothes Dryer and Room Air Conditioner 

Active Mode Test Procedures 

1. Correction of Text Describing Energy 

Factor Calculation for Clothes Dryers 

2. Automatic Cycle Termination for 

Clothes Dryers 

3. Test Procedure for Ventless Clothes 

Dryers 

4. Detergent Specifications for Clothes 

Dryer Test Cloth Preconditioning 

5. Changes To Reflect Current Usage 

Patterns and Capabilities 

a. Clothes Dryer Number of Annual Cycles 

b. Clothes Dryer Initial Remaining 

Moisture Content 

c. Clothes Dryer Test Load Weight 

d. Room Air Conditioner Annual Operating 

Hours 

e. Room Air Conditioner Part-Load 

Performance 

f. Room Air Conditioner Ambient Test 

Conditions 

6. Room Air Conditioner Referenced Test 

Procedures 

7. Clothes Dryer Referenced Test Procedure 

8. Technical Correction for the Per-Cycle 

Gas Dryer Continuously Burning Pilot 

Light Gas Energy Consumption 

9. Clarification of the Gas Supply Test 

Conditions for Gas Clothes Dryers 

10. Other Clothes Dryer Test Procedure 

Issues 

a. Test Cloth Specifications 

b. Relative Humidity Measurement 

Specifications 

c. Calculations of EF and CEF 

d. Measurement of Kilowatt Electricity 

Demand 

e. Clarifications to the Measurement of 

Drum Capacity 

f. Test Procedure Language 

D. Compliance With Other EPCA 

Requirements 

1. Test Burden 

2. Integration of Standby Mode and Off 

Mode Energy Consumption Into the 

Energy Efficiency Metrics 

IV. Effects of Test Procedure Revisions on 

Compliance With Standards 

A. Standby Mode and Off Mode 


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Federal Register / Vol. 76, No. 4 / Thursday, January 6, 2011 / Rules and Regulations 973 

1All references to EPCA refer to the statute as 

amended including through the Energy 

Independence and Security Act of 2007, Public Law 

110–140. For editorial reasons, upon codification in 

the U.S. Code, Part B was re-designated Part A. 

2 ‘‘Bone dry’’ is defined in the DOE clothes dryer 

test procedure as ‘‘a condition of a load of test 

clothes which has been dried in a dryer at 

maximum temperature for a minimum of 10 

minutes, removed and weighed before cool down, 

and then dried again for 10-minute periods until the 

final weight change of the load is 1 percent or less.’’ 

(10 CFR subpart B, appendix D, section 1.2) 

3ANSI standards are available at http:// 

www.ansi.org. 

4ASHRAE standards are available at http:// 

www.ashrae.org. 

B. Active Mode—Clothes Dryers 

C. Active Mode—Room Air Conditioners 

V. Procedural Requirements 

A. Review Under Executive Order 12866 

B. Review Under the Regulatory Flexibility 

Act 

C. Review Under the Paperwork Reduction 

Act of 1995 

D. Review Under the National 

Environmental Policy Act of 1969 

E. Review Under Executive Order 13132 

F. Review Under Executive Order 12988 

G. Review Under the Unfunded Mandates 

Reform Act of 1995 

H. Review Under the Treasury and General 

Government Appropriations Act, 1999 

I. Review Under Executive Order 12630 

J. Review Under the Treasury and General 

Government Appropriations Act, 2001 

K. Review Under Executive Order 13211 

L. Review Under Section 32 of the Federal 

Energy Administration Act of 1974 

M. Congressional Notification 

VI. Approval of the Office of the Secretary 

I. Background and Authority 

Title III of the Energy Policy and 

Conservation Act of 1975 (42 U.S.C. 

6291, et seq.; ‘‘EPCA’’ or, in context, ‘‘the 

Act’’) sets forth a variety of provisions 

designed to improve energy efficiency. 

Part B of Title III, Public Law 94–163 

(42 U.S.C. 6291–6309, as codified) 

establishes the ‘‘Energy Conservation 

Program for Consumer Products Other 

Than Automobiles,’’ a program covering 

most major household appliances 

including clothes dryers and room air 

conditioners (all of which are referred to 

below as ‘‘covered products’’).1 (42 

U.S.C. 6291(1)–(2) and 6292(a)(2) and 

(8)) 

Under the Act, this program consists 

essentially of four parts: (1) Testing; (2) 

labeling; (3) the establishment of 

Federal energy conservation standards; 

and (4) certification and enforcement 

procedures. The Federal Trade 

Commission (FTC) is responsible for 

labeling, and DOE implements the 

remainder of the program. The testing 

requirements consist of test procedures 

that, pursuant to EPCA, manufacturers 

of covered products must use as the 

basis for certifying to DOE that their 

products comply with applicable energy 

conservation standards adopted under 

EPCA and for representations about the 

efficiency of those products. Similarly, 

DOE must use these test requirements to 

determine whether the products comply 

with EPCA standards. Under 42 U.S.C. 

6293, EPCA sets forth criteria and 

procedures for DOE’s adoption and 

amendment of such test procedures. 

EPCA provides that any test procedures 

prescribed or amended under this 

section shall be reasonably designed to 

produce test results which measure 

energy efficiency, energy use or 

estimated annual operating cost of a 

covered product during a representative 

average use cycle or period of use and 

shall not be unduly burdensome to 

conduct. (42 U.S.C. 6293(b)(3)) 

In any rulemaking to amend a test 

procedure, DOE must also determine to 

what extent, if any, the proposed test 

procedure would alter the measured 

energy efficiency of any covered 

product as determined under the 

existing test procedure. (42 U.S.C. 

6293(e)(1)) If DOE determines that the 

amended test procedure would alter the 

measured efficiency of a covered 

product, DOE must amend the 

applicable energy conservation standard 

accordingly. In determining the 

amended energy conservation standard, 

the Secretary shall measure, pursuant to 

the amended test procedure, the energy 

efficiency, energy use, or water use of a 

representative sample of covered 

products that minimally comply with 

the existing standard. The average of 

such energy efficiency, energy use, or 

water use levels determined under the 

amended test procedure shall constitute 

the amended energy conservation 

standard for the applicable covered 

products. (42 U.S.C. 6293(e)(2)) EPCA 

also states that models of covered 

products in use before the date on 

which the amended energy conservation 

standard becomes effective (or revisions 

of such models that come into use after 

such date and have the same energy 

efficiency, energy use, or water use 

characteristics) that comply with the 

energy conservation standard applicable 

to such covered products on the day 

before such date shall be deemed to 

comply with the amended energy 

conservation standard. (42 U.S.C. 

6293(e)(3)) EPCA also states that the 

Secretary’s authority to amend energy 

conservation standards under 42 U.S.C. 

6293(e) shall not affect the Secretary’s 

obligation to issue final rules as 

described in 42 U.S.C. 6295. (42 U.S.C. 

6293(e)(4)) 

DOE’s test procedures for clothes 

dryers are found at 10 CFR part 430, 

subpart B, appendix D. DOE established 

its test procedure for clothes dryers in 

a final rule published in the Federal 

Register on September 14, 1977 (the 

September 1977 TP Final Rule). 42 FR 

46145. On May 19, 1981 DOE published 

a final rule (the May 1981 TP Final 

Rule) to amend the test procedure by 

establishing a field-use factor for clothes 

dryers with automatic termination 

controls, clarifying the test cloth 

specifications and clothes dryer 

preconditioning, and making editorial 

and minor technical changes. 46 FR 

27324. The existing clothes dryer test 

procedure incorporates by reference two 

industry test standards: (1) The 

Association of Home Appliance 

Manufacturers (AHAM) Standard HLD– 

1–1974, ‘‘AHAM Performance 

Evaluation Procedure for Household 

Tumble Type Clothes Dryers’’ (AHAM 

Standard HLD–1–1974); and (2) AHAM 

Standard HLD–2EC, ‘‘Test Method for 

Measuring Energy Consumption of 

Household Tumble Type Clothes 

Dryers’’ December 1975 (AHAM 

Standard HLD–2EC). The test procedure 

includes provisions for determining the 

energy factor (EF) for clothes dryers, 

which is a measure of the total energy 

required to dry a standard test load of 

laundry to a ‘‘bone dry’’ 2 state. 

DOE’s test procedures for room air 

conditioners are found at 10 CFR part 

430, subpart B, appendix F. DOE 

established its room air conditioner test 

procedure on June 1, 1977, and 

redesignated and amended it on June 

29, 1979. 42 FR 27898; 44 FR 37938. 

The existing room air conditioner test 

procedure incorporates by reference two 

industry test standards: (1) American 

National Standard (ANS) (since 

renamed American National Standards 

Institute (ANSI)) Z234.1–1972, ‘‘Room 

Air Conditioners;’’ 3 and (2) American 

Society of Heating, Refrigerating, and 

Air-Conditioning Engineers (ASHRAE) 

Standard 16–69, ‘‘Method of Testing for 

Rating Room Air Conditioners.’’ 4 The 

DOE test procedure includes provisions 

for determining the energy efficiency 

ratio (EER) of room air conditioners, 

which is the ratio of the cooling 

capacity in British thermal units (Btu) to 

the power input in watts (W). 

As currently drafted, the test 

procedures for the products at issue in 

this rulemaking do not account for 

standby mode and off mode energy 

consumption, except in one narrow 

product class. Specifically, for gas 

clothes dryers with constant burning 

pilot lights, DOE’s current test 

procedure for clothes dryers addresses 

the standby energy use of such pilot 

lights. EPCA, however, states that gas 

clothes dryers shall not be equipped 

with a constant burning pilot for 


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5 IEC standards are available at: http:// 

www.iec.ch. 

6Multiple editions of this standard are referenced 

in this final rule. Unless otherwise indicated, the 

terms ‘‘IEC Standard 62301’’ or ‘‘IEC Standard 62301 

First Edition’’ refer to ‘‘Household electrical 

appliances—measurement of standby power,’’ First 

Edition 2005–06. 

products manufactured on or after 

January 1, 1988. (42 U.S.C. 6295(g)(3)) 

As discussed in section III.C.8, DOE 

amends the clothes dryer test procedure 

in today’s final rule to remove any 

provisions for measuring constant 

burning pilot lights. 

EPCA directs DOE to amend its test 

procedures to include measures of 

standby mode and off mode energy 

consumption. EPCA further directs DOE 

to amend the test procedures to 

integrate such energy consumption into 

a single energy descriptor for that 

product. If that is technically infeasible, 

DOE must prescribe a separate standby 

mode and off mode energy-use test 

procedure, if technically feasible. (42 

U.S.C. 6295(gg)(2)(A)) Any such 

amendment must consider the most 

current versions of the International 

Electrotechnical Commission (IEC) 

Standard 62301 [‘‘Household electrical 

appliances—measurement of standby 

power,’’ First Edition 2005–06 (IEC 

Standard 62301)] 5 6 and IEC Standard 

62087 [‘‘Methods of measurement for the 

power consumption of audio, video, and 

related equipment,’’ Second Edition 

2008–09]. Id. 

EPCA also provides that amendments 

to the test procedures to include 

standby mode and off mode energy 

consumption will not determine 

compliance with previously established 

standards. (U.S.C. 6295(gg)(2)(C)) The 

test procedure amendments regarding 

provisions for standby mode and off 

mode in today’s final rule shall become 

effective 30 days after the publication of 

the rule in the Federal Register. DOE 

notes, however, that the procedures and 

calculations for standby mode and off 

mode energy consumption need not be 

performed at this time to determine 

compliance with the current energy 

conservation standards. Manufacturers 

would be required to use the amended 

test procedures’ standby mode and off 

mode provisions starting on the 

compliance date of any final rule 

establishing amended energy 

conservation standards for clothes 

dryers and room air conditioners that 

address standby mode and off mode 

energy consumption. In addition, 

starting 180 days after publication of 

today’s test procedure final rule, any 

representations as to the standby mode 

and off mode energy consumption must 

be based upon results generated under 

the applicable provisions of this test 

procedure. (42 U.S.C. 6293(c)(2)) 

DOE published a notice of proposed 

rulemaking (NOPR) on December 9, 

2008 (the December 2008 TP NOPR), in 

which it proposed a number of revisions 

and additions to its test procedures for 

clothes dryers and room air 

conditioners. These consisted largely of 

provisions to address the new statutory 

requirement to expand test procedures 

to incorporate a measure of standby 

mode and off mode energy 

consumption. 73 FR 74639. DOE also 

proposed amendments to correct text 

describing the EF calculation for clothes 

dryers and the text referencing room air 

conditioner industry test standards. 73 

FR 74650. The proposals in the NOPR 

were addressed at a public meeting on 

December 17, 2008 (the December 2008 

Public Meeting). In addition, DOE 

invited written comments, data, and 

information on the December 2008 TP 

NOPR through February 23, 2009. 

DOE received oral comments from 

interested parties at the December 2008 

Public Meeting and subsequently 

received four written comments. The 

principal test procedure issues on 

which interested parties commented 

were: (1) Establishing multiple low 

power or standby modes for both 

clothes dryers and room air 

conditioners; (2) the number of annual 

hours associated with active, standby, 

and off modes for the calculation of 

energy use; (3) considering an 

additional standby mode (a ‘‘network 

mode’’); (4) clarifying the definitions of 

standby and off mode; (5) harmonizing 

mode definitions and testing procedures 

with international standards, in 

particular IEC Standard 62301 Second 

Edition, Committee Draft 2 (IEC 

Standard 62301 CD2); and (6) 

integrating of standby and off mode 

energy use and active mode energy use 

into a single energy-use metric. 

DOE determined after the December 

2008 TP NOPR was published that it 

would consider a revised version of IEC 

Standard 62301, i.e., IEC Standard 

62301 Second Edition, which at that 

time was expected to be published in 

July 2009. DOE anticipated, based on 

review of drafts of the updated IEC 

Standard 62301, that the revisions could 

include different mode definitions. 

Subsequently, DOE received 

information that IEC Standard 62301 

Second Edition would not be published 

until late 2010. To allow for the 

consideration of standby and off mode 

power consumption in the concurrent 

energy conservation standards 

rulemaking, DOE published a SNOPR 

on June 29, 2010 (hereafter referred to 

as the June 2010 TP SNOPR), proposing 

mode definitions based on the new 

mode definitions from the most recent 

draft version of IEC Standard 62301 

Second Edition which, at that time, was 

designated as IEC Standard 62301 

Second Edition Committee Draft for 

Vote (IEC Standard 62301 CDV). 75 FR 

37594. The IEC circulated IEC Standard 

62301 CDV on August 28, 2009. IEC 

Standard 62301 CDV contained the most 

recent proposed amendments to IEC 

Standard 62301, including new mode 

definitions, at the time the June 2010 TP 

SNOPR was issued. IEC Standard 62301 

CDV revised the proposed mode 

definitions from previous draft versions 

of IEC Standard 62301 and addressed 

comments received by interested parties 

in response to those drafts. As a result, 

DOE stated in the June 2010 TP SNOPR 

that the mode definitions in IEC 

Standard 62301 CDV represent the best 

definitions available for the supporting 

analysis. Id. 

DOE also determined after publication 

of the December 2008 TP NOPR to 

conduct a rulemaking to amend the 

active mode test procedure for clothes 

dryers and room air conditioners. As 

part of this rulemaking, DOE intended 

to address issues on which it requested 

comment in the concurrent energy 

conservation standards rulemaking, 

discussed below. In the June 2010 TP 

SNOPR, DOE proposed the following 

test procedure amendments for the 

measurement of active mode energy 

consumption for clothes dryers and 

room air conditioners: (1) Procedures for 

more accurately measuring the effects of 

different automatic termination 

technologies in clothes dryers; (2) 

provisions for ventless clothes dryers, 

which are being considered under an 

amended energy conservation standard; 

(3) updated detergent specifications for 

clothes dryer test cloth preconditioning; 

(4) changes to better reflect current 

usage patterns and capabilities for the 

covered products; (5) updated 

references to external test procedures; 

and (6) clarifications to the test 

conditions for gas clothes dryers. 75 FR 

37594 (June 29, 2010). 

The proposals in the SNOPR were 

addressed at a public meeting on July 

14, 2010 (July 2010 Public Meeting). In 

addition, DOE invited written 

comments, data, and information on the 

June 2010 TP SNOPR through August 

30, 2010. DOE received oral comments 

from interested parties at the July 2010 

Public Meeting and subsequently 

received 13 written comments. The 

principal test procedure issues on 

which interested parties commented 

were: (1) The consideration of the most 

recent draft IEC Standard 62301 Second 

Edition, Final Draft International 


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7RMC is the ratio of the weight of water 

contained by the test load to the bone-dry weight 

of the test load, expressed as a percent. 

8A notation in this form provides a reference for 

information that is in the docket of DOE’s 

rulemaking to develop energy conservation 

standards for clothes dryers and room air 

conditioners (Docket No. EERE–2007–BT–STD– 

0010), which is maintained in the Resource Room 

of the Building Technologies Program. This 

notation indicates that the statement preceding the 

reference was made in DOE’s Framework 

Document, which is document number 1 in the 

docket for the clothes dryer and room air 

conditioner energy conservation standards 

rulemaking, and appears at pages 4–6 of that 

document. 

Standard (IEC Standard 62301 FDIS); (2) 

the settings used for standby and off 

mode testing; (3) the allocation of hours 

to different standby and off modes; (4) 

the clothes dryer cycle settings selected 

for automatic cycle termination testing 

methods; (5) the inclusion of the cooldown period for clothes dryer automatic 

cycle termination tests; (6) revisions to 

the water temperature for clothes dryer 

test load preparation; (7) test conditions 

for ventless clothes dryers; (8) the 

consideration of the effects of clothes 

dryers on HVAC energy use; (9) the 

initial remaining moisture content 

(RMC) value for clothes dryers; (10) the 

number of room air conditioner annual 

operating hours; and (11) the 

consideration of fan-only active mode 

for room air conditioners. 

Test procedure amendments for the 

measurement of active mode energy 

consumption for clothes dryers and 

room air conditioners will become 

effective 30 days after the publication of 

today’s final rule in the Federal 

Register. In addition, DOE also notes 

that as of 180 days after the publication 

of today’s test procedure final rule, any 

representations with respect to the 

energy use or efficiency or cost of 

energy consumed of the products that 

are the subject of this rulemaking must 

be based upon results generated under 

the applicable provisions of these 

amended test procedures. (42 U.S.C. 

6293(c)(2)) 

This test procedure rulemaking 

fulfills the 7-year review requirement 

prescribed by EPCA. At least once every 

7 years, the Secretary shall review test 

procedures for all covered products and 

amend test procedures with respect to 

any covered product or publish notice 

in the Federal Register of any 

determination not to amend a test 

procedure. (42 U.S.C. 6293(b)(1)(A)) 

DOE is also conducting a concurrent 

energy conservation standards 

rulemaking for residential clothes dryers 

and room air conditioners. For clothes 

dryers, EPCA establishes prescriptive 

standards for clothes dryers, requiring 

that gas dryers manufactured on or after 

January 1, 1988 not be equipped with a 

constant burning pilot and further 

requiring that DOE conduct two cycles 

of rulemakings to determine if more 

stringent standards are justified. (42 

U.S.C. 6295(g)(3) and (4)) On May 14, 

1991, DOE published a final rule in the 

Federal Register establishing the first 

set of performance standards for 

residential clothes dryers (56 FR 22250); 

the new standards became effective on 

May 14, 1994. 10 CFR 430.32(h). DOE 

has initiated the second cycle of clothes 

dryer standards rulemakings by 

publishing a notice of availability of a 

framework document, discussed in 

more detail below. 72 FR 57254 

(October 9, 2007). 

For room air conditioners, EPCA 

establishes performance standards that 

became effective on January 1, 1990, 

and directs DOE to conduct two cycles 

of rulemakings to determine if more 

stringent standards are justified. (42 

U.S.C. 6295(c)(1) and (2)) On March 4, 

1994, DOE published a NOPR for 

several products, including room air 

conditioners. 59 FR 10464. On 

September 24, 1997, DOE published a 

final rule establishing an updated set of 

performance standards, with an 

effective date of October 1, 2000. 62 FR 

50122; 10 CFR 40.32(b). DOE initiated 

the second cycle of room air conditioner 

standards rulemakings concurrent with 

the clothes dryer rulemaking. 72 FR 

57254 (October 9, 2007). 

As stated above, DOE initiated the 

second cycle of residential clothes dryer 

and room air conditioner energy 

conservation standards rulemakings by 

publishing a notice in the Federal 

Register announcing the availability of 

a framework document to initiate a 

rulemaking to consider amended energy 

conservation standards for residential 

clothes dryers and room air conditioners 

on October 9, 2007 (hereafter the 

October 2007 Framework Document). 72 

FR 57254. In the October 2007 

Framework Document, DOE identified 

specific ways in which it could revise 

its test procedures for these two 

products and requested comment from 

interested parties on whether it should 

adopt such revisions. Specifically, DOE 

sought comment on potential 

amendments to the clothes dryer test 

procedure to: (1) Reflect lower 

remaining moisture content (RMC) 7 in 

clothes loads; (2) account for fewer 

annual use cycles; and (3) add the 

capability to test ventless clothes dryers. 

(Framework Document, STD No. 1 at 

pp. 4–6) 8 DOE received comments in 

response to the October 2007 

Framework Document that it should 

consider changes to the clothes dryer 

test load size. For room air conditioners, 

DOE requested input on potential 

amendments to the test procedure to: (1) 

Incorporate the most recent ANSI and 

ASHRAE test standards; (2) reduce the 

annual operating hours; and (3) measure 

part-load performance. (Framework 

Document, STD No. 1 at pp. 6–7) DOE 

received comments in response to the 

October 2007 Framework Document that 

it should consider changes to the 

ambient test conditions for room air 

conditioners. 

EPCA directs DOE to incorporate 

standby and off mode energy use into 

any final rule establishing or revising a 

standard for a covered product adopted 

after July 1, 2010. (42 U.S.C. 6295(gg)(3)) 

DOE is required by consent decree to 

publish a final rule setting forth any 

revised efficiency standards for clothes 

dryers and room air conditioners by 

June 30, 2011. As result, this final rule 

must incorporate standby and off mode 

energy use. 

II. Summary of the Proposal 

In today’s final rule, DOE amends its 

test procedures for clothes dryers and 

room air conditioners to: (1) Use in the 

concurrent development of energy 

conservation standards that address the 

energy use of these products when in 

standby mode and off mode, as well as 

in the implementation of any amended 

standards; (2) address the statutory 

requirement to expand test procedures 

to incorporate measures of standby 

mode and off mode power consumption; 

(3) adopt changes to the water 

temperature for clothes dryer test load 

preparation; (4) expand the clothes 

dryer test procedures to accommodate 

ventless clothes dryers being considered 

for coverage under an amended energy 

conservation standard; (5) adopt 

technical changes to better reflect 

current usage patterns and capabilities 

for the covered products; (6) update 

detergent specifications for clothes 

dryer test cloth preconditioning; (7) 

update the references to external test 

procedures; (8) clarify the test 

conditions for gas clothes dryers; and (9) 

clarify the test conditions for clothes 

dryer drum capacity measurements. As 

discussed in this section, DOE is not 

adopting the technical changes and 

procedures to more accurately measure 

the effects of different automatic cycle 

termination technologies in clothes 

dryers proposed in the June 2010 TP 

SNOPR. The following paragraphs 

summarize the amendments. 

Standby and Off Mode 

In today’s final rule, DOE incorporates 

by reference into both the clothes dryer 

and room air conditioner test 

procedures specific clauses from IEC 


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9EISA 2007 directs DOE to also consider IEC 

Standard 62087 when amending its test procedure 

to include standby mode and off mode energy 

consumption. See 42 U.S.C. 6295(gg)(2)(A). As 

explained subsequently in this notice, because IEC 

Standard 62087 addresses the methods of 

measuring the power consumption of audio, video, 

and related equipment, it is inapplicable to the 

products at issue in this rulemaking. 

10U.S. Department of Energy-Energy Information 

Administration. Residential Energy Consumption 

Survey 2005 Public Use Data Files, 2005. 

Washington, DC. Available online at: http:// 

www.eia.doe.gov/emeu/recs/. 

11EIA’s 2005 RECS is the latest available version 

of this survey. 

Standard 62301 regarding test 

conditions and test procedures for 

measuring standby mode and off mode 

power consumption. DOE also 

incorporates into each test procedure 

the definitions of ‘‘active mode,’’ 

‘‘standby mode,’’ and ‘‘off mode’’ based 

on the definitions provided in IEC 

Standard 62301 CDV. Further, DOE 

adopts additional language in each test 

procedure to clarify how clauses from 

IEC Standard 62301 and the mode 

definitions from IEC Standard 62301 

CDV are to be applied when measuring 

standby mode and off mode power 

consumption.9

For reasons discussed in section 

III.B.2 for clothes dryers, DOE adopts a 

definition and testing procedures for a 

single standby mode, rather than the 

multiple standby modes—‘‘inactive’’ 

mode, ‘‘cycle finished’’ mode, and ‘‘delay 

start’’ mode—as proposed in the 

December 2008 TP NOPR. 73 FR 74639, 

74645 (December 9, 2008). DOE also 

adopts new methods to calculate clothes 

dryer standby mode and off mode 

energy use, as well as a new measure of 

energy efficiency—Combined Energy 

Factor (CEF)—that includes energy use 

in standby mode and off mode. The 

standby mode and off mode 

amendments do not change the method 

to calculate the existing clothes dryer 

energy efficiency metric for active 

mode, the energy factor (EF). 

Similarly, for reasons discussed in 

section III.B.2 for room air conditioners, 

DOE adopts a definition and testing 

procedures for a single standby mode, 

rather than the multiple standby 

modes—‘‘inactive’’ mode, ‘‘delay start’’ 

mode, and ‘‘off-cycle’’ mode—as 

proposed in the December 2008 TP 

NOPR. 73 FR 74639, 74645. DOE also 

adopts new methods to calculate room 

air conditioner standby mode and off 

mode energy use and a new measure of 

energy efficiency—Combined Energy 

Efficiency Ratio (CEER)—that includes 

energy use in the standby mode and the 

off mode. The standby mode and off 

mode amendments do not change the 

method used to calculate the existing 

room air conditioner energy efficiency 

metric for active mode, the energy 

efficiency ratio (EER). 

In the December 2008 TP NOPR, DOE 

also proposed that standby mode and off 

mode testing be conducted with roomside air temperature at 74 ± 2 degrees 

Fahrenheit (°F), with a temperature 

control setting of 79 °F. 73 FR 74639, 

74646. Upon further consideration, 

however, DOE determined that, because 

the proposed test procedure would be 

limited to measuring a single standby 

mode and an off mode, the proposed 

close tolerance on ambient temperature 

and the proposed temperature setting of 

79 °F, which were relevant only for an 

off-cycle standby mode measurement, 

would not be required. Therefore, DOE 

is not adopting those requirements for 

testing conditions in today’s final rule. 

In the June 2010 TP SNOPR, DOE 

proposed that standby mode and off 

mode testing for both clothes dryers and 

room air conditioners be conducted at 

the settings that produce the highest 

power consumption level, consistent 

with the particular mode definition 

under test. 75 FR 37594, 37604 (June 29, 

2010). Upon further consideration, 

however, DOE believes that provisions 

for testing in the settings that produce 

the highest power consumption level 

would not be representative of 

consumer usage. For the reasons 

discussed in section III.B.2, DOE 

believes the provisions in section 5.2 of 

IEC Standard 62301 that specify the 

appliance be installed and set up in 

accordance with manufacturers’ 

instructions, or if no instructions are 

given, the appliance be tested at factory 

or ‘‘default’’ settings, is more 

representative of consumer usage. 

Therefore, DOE amends the test 

procedure in today’s final rule to 

incorporate by reference section 5.2 of 

IEC Standard 62301 for standby and off 

mode testing for both clothes dryers and 

room air conditioners in today’s final 

rule. 

For the reasons discussed in section 

III.B.5, DOE revises the estimated 

annual operating cost calculation for 

both clothes dryers and room air 

conditioners (Estimated Annual 

Operating Cost and Annual Energy Cost, 

respectively) to integrate the cost of 

energy use in the standby mode and off 

mode. 

Amendments to the Water Temperature 

for Clothes Dryer Test Load Preparation 

The existing DOE clothes dryer test 

procedure requires that the test load be 

agitated in water whose temperature is 

100 °F ± 5 °F. In the June 2010 TP 

SNOPR, DOE stated that it did not have 

data indicating whether a different 

water temperature for clothes dryer test 

load preparation would be more 

representative of current consumer 

usage, but that if consumer usage data 

is made available that indicates a 60 °F 

± 5 °F water temperature is more 

representative of consumer use, DOE 

may adopt this alternate approach. 75 

FR 37594, 37615 (June 29, 2010). As 

discussed in section III.C.2, DOE 

believes that the cold water rinse cycle 

is more representative of typical 

consumer use based on the rinse 

temperature use factors in the DOE 

clothes washer test procedure and the 

Energy Information Administration 

(EIA) 2005 ‘‘Residential Energy 

Consumption Survey’’ (RECS) 10 11 data 

reporting the percentage of clothes 

washer cycles for which consumers use 

cold water for the rinse cycle. Therefore, 

DOE amends the clothes dryer test 

procedure in today’s final rule to change 

the water temperature for clothes dryer 

test load preparation to 60 °F ± 5 °F. This 

temperature is more representative of 

the clothes load temperature after a cold 

rinse cycle at the end of the wash cycle. 

Provisions for Testing Ventless Clothes 

Dryers 

In today’s final rule, DOE amends the 

current clothes dryer test procedure to 

include provisions for testing ventless 

clothes dryers. These provisions are 

based upon an alternate test procedure 

developed by DOE and proposed in the 

June 2010 TP SNOPR that provide 

separate definitions for a ‘‘conventional 

clothes dryer’’ and a ‘‘condensing 

clothes dryer.’’ These provisions also 

qualify the requirement for an exhaust 

simulator so that it would apply only to 

conventional clothes dryers. Further, 

DOE includes in the test procedure 

additional language based on provisions 

from European Standard EN 61121, 

‘‘Tumble dryers for household use— 

Methods for measuring the 

performance,’’ Edition 3 2005 (the EN 

Standard 61121). These provisions 

clarify the alternate test procedure 

developed by DOE. EN Standard 61121 

is an internationally-accepted test 

standard that specifies methods for 

testing ventless clothes dryers. The 

clarifications require that if a ventless 

clothes dryer is equipped with a 

condensation box, the clothes dryer 

shall be tested with such condensation 

box installed as specified by the 

manufacturer. A condensation box 

stores condensed moisture removed 

from the air exiting the drum. The box 

is later emptied by the user. In addition, 

the clarifications also state that if the 

clothes dryer stops the test cycle 

because the condensation box is full, the 


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12To investigate this, DOE conducted additional 

testing using a test load similar to that specified in 

AHAM Standard HLD–1–2009, which consists of 

cotton bed sheets, towels, and pillow cases. For 

tests using the same automatic cycle termination 

settings as were used in the testing described earlier 

(i.e., normal cycle setting and highest temperature 

setting, the alternate test load was dried to 1.7 to 

2.2 percent final RMC, with an average RMC of 2.0 

percent. In comparison, the same clothes dryer 

under the same cycle settings dried the DOE test 

load to 0.3 to 1.2 percent RMC, with an average 

RMC of 0.7 percent. Thus, DOE concluded that the 

proposed automatic cycle termination control test 

procedures may not stop at an appropriate RMC 

when used with the current test load. 

test is not valid because the unit would 

not be operating as intended by the 

manufacturer to condense moisture in 

the air exiting the clothes dryer drum. 

In such cases, the condensation box 

must be emptied and the test re-run 

from the beginning. The clarifications 

also state that the condenser heat 

exchanger cannot be taken out of the 

clothes dryer between tests to clarify the 

test procedure and ensures that all 

manufacturers are testing products 

under the same conditions. Finally, 

DOE adopts clarifications that address 

clothes dryer preconditioning for 

ventless clothes dryers, as discussed in 

section III.C.3. 

Amendments To Reflect Current Usage 

Patterns and Capabilities 

DOE amends the test procedure for 

clothes dryers to reflect current usage 

patterns and capabilities. These 

amendments are based on DOE’s 

analysis of consumer usage patterns 

data. As proposed in the June 2010 

SNOPR, DOE revises the number of 

annual use cycles from the 416 cycles 

per year currently specified by the DOE 

test procedure to 283 cycles per year for 

all types (that is, product classes) of 

clothes dryers. This revision is based on 

DOE’s analysis of data from the 2005 

RECS for the number of laundry loads 

(clothes washer cycles) washed per 

week and the frequency of clothes dryer 

use. In addition, as proposed in the 

2010 SNOPR, DOE changes the 7-pound 

(lb) clothes dryer test load size specified 

by the current test procedure for 

standard-size clothes dryers to 8.45 lb. 

This revision is based on the historical 

trends of clothes washer tub volumes 

and the corresponding percentage 

increase in clothes washer test load 

sizes (as specified by the DOE clothes 

washer test procedure). DOE assumes 

these historical trends proportionally 

impact clothes dryer load sizes. DOE 

believes most compact clothes dryers 

are used in conjunction with compactsize clothes washers, however, and DOE 

does not have any information to 

suggest that the tub volume of such 

clothes washers has changed 

significantly. Therefore, DOE is not 

changing the 3-lb test load size currently 

specified in its clothes dryer test 

procedure for compact clothes dryers in 

today’s final rule. 

In the June 2010 TP SNOPR, DOE also 

proposed to revise the 70-percent initial 

RMC required by the test procedure to 

47 percent so as to accurately represent 

the condition of a laundry load after a 

wash cycle. This proposal was based on 

analysis of shipment-weighted RMC 

data for clothes washers submitted by 

AHAM and a distribution analysis of 

RMC data for clothes washer models 

listed in the December 22, 2008 

California Energy Commission (CEC) 

directory. 75 FR 37594, 37599 (June 29, 

2010). In response to comments from 

interested parties on the June 2010 TP 

SNOPR, DOE determined that an initial 

clothes dryer RMC of 57.5 percent more 

accurately represents the moisture 

content of laundry loads after a wash 

cycle for the purposes of clothes dryer 

testing. As discussed in section III.5.b, 

this RMC is derived from the 47-percent 

shipment-weighted RMC for clothes 

washers, but was derived without 

applying an RMC correction factor as 

required by the DOE clothes washer test 

procedure. For these reasons, DOE 

revises the initial clothes dryer RMC 

from 70 percent to 57.5 percent in 

today’s final rule. 

Clothes Dryer Automatic Cycle 

Termination 

In the June 2010 TP SNOPR, DOE 

proposed to revise its clothes dryer test 

procedure to include definitions of and 

provisions for testing both timer dryers 

and automatic termination control 

dryers using methodology provided in 

Australia/New Zealand (AS/NZS) 

Standard 2442.1: 1996, ‘‘Performance of 

household electrical appliances—Rotary 

clothes dryers, Part 1: Energy 

consumption and performance’’ (AS/ 

NZS Standard 2442.1) and AS/NZS 

Standard 2442.2: 2000, ‘‘Performance of 

household electrical appliances—Rotary 

clothes dryers, Part 2: Energy labeling 

requirements’’ (AS/NZS Standard 

2442.2). 75 FR 37594, 37598 (June 29, 

2010). DOE proposed to incorporate the 

testing methods from these international 

test standards, along with a number of 

clarifications, to measure the energy 

consumption for both timer dryers and 

automatic termination control dryers. 

The measurement would account for the 

amount of over-drying energy 

consumption, that is, the energy 

consumed by the clothes dryer after the 

load reaches an RMC of 5 percent. 75 FR 

37594, 37599 (June 29, 2010). 

DOE conducted testing of 

representative clothes dryers using the 

automatic cycle termination test 

procedure proposed in the June 2010 TP 

SNOPR; however, the test results 

showed that all of the clothes dryers 

tested significantly over-dried the DOE 

test load to near bone dry. In addition, 

the measured EF values were 

significantly lower than EF values 

obtained using the existing DOE test 

procedure, and the test data indicated 

that clothes dryers equipped with 

automatic termination controls were 

less efficient than timer dryers. DOE 

believes the test procedure amendments 

for automatic cycle termination 

proposed in the June 2010 TP SNOPR 

do not adequately measure the energy 

consumption of clothes dryers equipped 

with such systems using the test load 

specified in the DOE test procedure. 

DOE believes that clothes dryers with 

automatic termination sensing control 

systems, which infer the RMC of the 

load from the properties of the exhaust 

air such as temprature and humidity, 

may be designed to stop the cycle when 

the consumer load has a higher RMC 

than the RMC obtained using the 

proposed automatic cycle termination 

test procedure in conjunction with the 

existing test load.12 Manufacturers have 

indicated, however, that test load types 

and test cloth materials different than 

those specified in the DOE test 

procedure do not produce results as 

repeatable as those obtained using the 

test load as currenty specified. In 

addition, DOE presented data in the 

May 1981 TP Final Rule from a field use 

survey conducted by AHAM as well as 

an analysis conducted by the National 

Bureau of Standards (now known as the 

National Institute of Standards and 

Technology (NIST)) of field test data on 

automatic termination control dryers. 

Analysis of this data showed that 

clothes dryers equipped with an 

automatic cycle termination feature 

consume less energy than timer dryers 

by reducing over-drying. 46 FR 27324 

(May 19, 1981). 

For the reasons discussed above, DOE 

believes the test procedure amendments 

for automatic cycle termination 

proposed in the June 2010 TP SNOPR 

do not adequately measure the energy 

consumption of clothes dryers equipped 

with such systems. As a result, DOE is 

not adopting the amendments for 

automatic cycle termination proposed in 

the June 2010 TP SNOPR. 75 FR 37594, 

37598–99 (June 29, 2010). If data is 

made available to develop a test 

procedure that accurately measures the 

energy consumption of clothes dryers 

equipped with automatic termination 

controls, DOE may consider revised 

amendments in a future rulemaking. 


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DOE received comments in response 

to the June 2010 TP SNOPR that it 

should revise the definition of 

‘‘automatic termination control’’ in the 

current clothes dryer test procedure. 

Commenters felt the definition should 

more clearly account for electronic 

controls by specifying that a preferred 

automatic termination control setting 

can also be indicated by any other 

visual indicator (in addition to a mark 

or detent). DOE agrees this clarification 

should be added and is amending the 

definition of ‘‘automatic termination 

control’’ in the clothes dryer test 

procedure to include it. 

DOE also received comments stating 

that the field-use factor for clothes 

dryers with automatic cycle termination 

applied in the per-cycle energy 

consumption calculation excludes 

sensing technologies that do not meet 

the definitions of ‘‘temperature sensing 

control’’ or ‘‘moisture sensing control,’’ 

which are narrowly defined to require 

that the control system use either a 

temperature sensor that monitors the 

exhaust air or a moisture sensor 

contained within the drum. DOE 

believes the definition of ‘‘automatic 

termination control’’ more broadly 

applies to any sensing system that 

monitors either the dryer load 

temperature or its moisture content and 

that this definition would not limit the 

emergence of any new sensor 

technologies that monitor the moisture 

content or temperature in other ways 

from applying the field use factor for 

automatic cycle termination. For these 

reasons, DOE amends the test procedure 

to specify that the field use factor 

applies to clothes dryers that meet the 

requirements for the definitions of 

‘‘automatic termination control.’’ 

Other Changes 

For clothes dryers, DOE also revises 

the detergent specifications for test cloth 

preconditioning to update the detergent 

specified in the test procedure, 

eliminates an unnecessary reference to 

an obsolete industry clothes dryer test 

standard, and amends the test 

conditions for gas clothes dryers to 

specify the required gas supply 

pressure. 

DOE also received comments related 

to clothes dryers from interested parties 

on issues not addressed in the June 2010 

TP SNOPR. Commenters suggested that 

DOE clarify the provisions for the 

measurement of drum capacity to 

specify that the clothes dryer’s rear 

drum surface be supported on a 

platform scale to ‘‘prevent deflection of 

the drum surface * * *’’ instead of 

‘‘prevent deflection of the dryer.’’ As 

discussed in section III.C.10.e, DOE 

agrees with these comments and adopts 

that provision in today’s final rule. In 

addition, DOE received comments in 

response to the June 2010 TP SNOPR 

that it should expressly state the 

equations for EF and CEF in the test 

procedure to provide optimal clarity for 

the regulated industry. DOE agrees with 

comments that the equations for EF and 

CEF should be included in 10 CFR part 

430, subpart B, appendix D1 for 

completeness. Therefore, DOE amends 

the clothes dryer test procedure in 

today’s final rule to include those 

calculations and to clarify in 10 CFR 

part 430.23(d)(2) and (3) that the EF and 

CEF must be determined in accordance 

with the appropriate sections in 10 CFR 

part 430, subpart B, appendix D1. 

For room air conditioners, DOE 

updates the references in its current 

room air conditioner test procedure to 

incorporate the most recent ANSI and 

ASHRAE test standards—ANSI/AHAM 

RAC–1–R2008, ‘‘Room Air 

Conditioners,’’ (ANSI/AHAM RAC–1– 

R2008) and ANSI/ASHRAE Standard 

16–1983 (RA 2009) ‘‘Method of Testing 

for Rating Room Air Conditioners and 

Packaged Terminal Air Conditioners’’ 

(ANSI/ASHRAE Standard 16–1983 

(RA 2009)). DOE has also determined 

that the 750 annual operating hours 

specified by the current DOE test 

procedure is representative of current 

usage patterns, based upon its 

interpretation of data from the 2005 

RECS. Therefore, DOE is not amending 

the annual usage hours specified by the 

current DOE test procedure for room air 

conditioners. 

As noted in section I, EPCA requires 

that DOE determine to what extent, if 

any, test procedure amendments would 

alter the measured energy efficiency of 

any covered product as determined 

under the existing test procedure. 

(42 U.S.C. 6293(e)(1)) If DOE determines 

that the amended test procedure would 

alter the measured efficiency of a 

covered product, DOE must amend the 

applicable energy conservation 

standard. In determining the amended 

energy conservation standard, DOE 

must measure, pursuant to the amended 

test procedure, the energy efficiency, 

energy use, or water use (as applicable) 

of a representative sample of covered 

products that minimally comply with 

the existing standard. (42 U.S.C. 

6293(e)(2)) Under 42 U.S.C. 

6295(gg)(2)(C), EPCA provides that 

amendments to the test procedures that 

include standby mode and off mode 

energy consumption will not determine 

compliance with previously established 

standards. (U.S.C. 6295(gg)(2)(C)) 

These amended clothes dryer and 

room air conditioner test procedures are 

effective 30 days after the publication of 

today’s final rule in the Federal 

Register. Because the amendments to 

the test procedures for measuring 

standby mode and off mode energy 

consumption do not alter the existing 

measures of energy consumption or 

efficiency for clothes dryers and room 

air conditioners, the amendments do not 

affect a manufacturer’s ability to comply 

with current energy conservation 

standards. Manufacturers will not be 

required to use the amended test 

procedures’ standby mode and off mode 

provisions until the mandatory 

compliance date of any amended 

clothes dryer and room air conditioner 

energy conservation standards. All 

representations related to standby mode 

and off mode energy consumption of 

both clothes dryers and room air 

conditioners made 180 days after the 

publication of today’s final rule must be 

based upon the standby and off mode 

requirements of the amended test 

procedures. (42 U.S.C. 6293(c)(2)) DOE 

examines how each of the amendments 

to the active mode provisions in its 

clothes dryer and room air conditioner 

test procedures in today’s final rule will 

affect the measured efficiency of 

products in section IV. 

III. Discussion 

A. Products Covered by the Test 

Procedure Changes 

Today’s amendments to DOE’s clothes 

dryer test procedure cover both electric 

and gas clothes dryers, DOE defines a 

clothes dryer to mean a cabinet-like 

appliance designed to dry fabrics in a 

tumble-type drum with forced air 

circulation, with blower(s) driven by an 

electric motor(s) and either gas or 

electricity as the heat source. 

Porticos Inc. (Porticos) commented in 

response to the June 2010 TP SNOPR 

that DOE’s definition for an electric 

clothes dryer excludes every possible 

alternative from consideration. Porticos 

stated that any alternate innovative 

clothes dryer technology, such as 

microwave, radio-frequency, vacuum, 

desiccant, and vapor-compression, 

would not meet the current electric 

clothes dryer definition, and direct 

comparisons would not be possible. 

Porticos commented that a better 

definition would be ‘‘an electrical 

appliance for drying clothes’’ and that 

any more limiting verbiage serves only 

to exclude new entrants from the 

marketplace. (Porticos, No. 23 at p. 1) 

Porticos also commented that DOE 

should reexamine the test procedures to 

remove any explicit or implicit 

reference to a particular technology or 


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13 DOE’s regulations define a packaged terminal 

air conditioner as a wall sleeve and a separate 

encased combination of heating and cooling 

assemblies specified by the builder and intended 

for mounting through the wall. It includes a prime 

source of refrigeration, separable outdoor louvers, 

forced ventilation, and heating availability energy. 

14 DOE notes that IEC Standard 62087 specifies 

methods of measuring the power consumption of 

TV receivers, videocassette recorders (VCRs), set 

top boxes, audio equipment, and multi-function 

equipment for consumer use. IEC Standard 62087 

does not include measurement for the power 

consumption of electrical appliances such as 

clothes dryers and room air conditioners. Therefore, 

IEC Standard 62087 is not applicable to the 

amendments to the clothes dryer and room air 

conditioner test procedures. 

approach to clothes drying. (Porticos, 

No. 23 at p. 2) 

DOE notes that the definition of a 

clothes dryer in the CFR does not 

prohibit other products (that is, those 

that do not fall under the definition of 

a clothes dryer) from being introduced 

to the market. For example, spin dryers 

or drying cabinets that do not use a heat 

source, forced air circulation, or a 

tumble-type drum are currently 

commercially available. Under the 

product definition suggested by 

Porticos, DOE notes that blow dryers, 

fans, or heat lamps could be considered 

covered products. DOE is also not aware 

of any commercially available 

microwave, radio-frequency, vacuum, 

desiccant, or vapor-compression clothes 

dryers. As a result, no data is available 

by which DOE could develop standards 

for such dryers. For these reasons, DOE 

is not revising the definition of a clothes 

dryer in today’s final rule. 

DOE’s regulations define a room air 

conditioner as a consumer product 

which is powered by a single-phase 

electric current and which is an encased 

assembly designed as a unit for 

mounting in a window or through the 

wall for the purpose of providing 

delivery of conditioned air to an 

enclosed space. It includes a prime 

source of refrigeration and may include 

a means for ventilating and heating. It 

does not include packaged terminal air 

conditioners.13 This definition and the 

amendments discussed below cover 

room air conditioners designed for 

single- or double-hung windows with or 

without louvered sides and with or 

without reverse cycle, as well as 

casement-slider and casement-only 

window-type room air conditioners. 

DOE is not changing the definition for 

room air conditioners in today’s final 

rule. 

B. Clothes Dryer and Room Air 

Conditioner Standby Mode and Off 

Mode Test Procedures 

1. Incorporating by Reference IEC 

Standard 62301 for Measuring Standby 

Mode and Off Mode Power in Clothes 

Dryers and Room Air Conditioners 

As noted in the December 2008 TP 

NOPR, DOE considered, pursuant to 

EPCA, the most current versions of IEC 

Standard 62301 and IEC Standard 62087 

for measuring power consumption in 

standby mode and off mode. (42 U.S.C. 

6295(gg)(2)(A)) 73 FR 74639, 74643–44 

(December 9, 2008).14 DOE noted that 

IEC Standard 62301 provides for 

measuring standby power in electrical 

appliances, including clothes dryers and 

room air conditioners, and, therefore, is 

applicable to the proposed amendments 

to the clothes dryer and room air 

conditioner test procedures. 73 FR 

74643–44 (December 9, 2008). 

DOE proposed in the December 2008 

TP NOPR to incorporate by reference 

into the DOE test procedures for clothes 

dryers and room air conditioners 

specific clauses from IEC Standard 

62301 for measuring standby mode and 

off mode power: from section 4 

(‘‘General conditions for 

measurements’’); paragraph 4.2, ‘‘Test 

room’’; paragraph 4.4, ‘‘Supply voltage 

waveform’’; and paragraph 4.5, ‘‘Power 

measurement accuracy’’; as well as from 

section 5 (‘‘Measurements’’); paragraph 

5.1, ‘‘General’’; and paragraph 5.3, 

‘‘Procedure.’’ DOE also proposed to 

reference these same provisions in the 

DOE test procedure for room air 

conditioners, as well as section 4, 

paragraph 4.3, ‘‘Power supply.’’ 73 FR 

74639, 74644 (December 9, 2008). 

In the December 2008 TP NOPR, DOE 

noted that EPCA (42 U.S.C. 

6295(gg)(2)(A)) requires that in 

developing any amended test 

procedures, DOE consider the most 

current version of IEC Standard 62301. 

The IEC is currently developing an 

updated version of this standard, IEC 

Standard 62301 Second Edition. 73 FR 

74639, 74644 (December 9, 2008). At the 

time of publication of the December 

2008 TP NOPR, however, IEC Standard 

62301 was the ‘‘current version, which 

DOE was required by EPCA to consider. 

DOE incorporated sections from IEC 

Standard 62301 in the proposed 

amendments to the test procedure in the 

December 2008 TP NOPR. 73 FR 74639, 

74644 (December 9, 2008). 

DOE did not receive any objections to 

the proposed testing methods and 

procedures referenced in IEC Standard 

62301 in response to the December 2008 

TP NOPR. As a result, the June 2010 TP 

SNOPR did not affect DOE’s proposal in 

the December 2008 TP NOPR to 

incorporate by reference the clauses 

presented above from IEC Standard 

62301. 75 FR 37594, 37602 (June 29, 

2010). 

DOE anticipated, based on review of 

draft versions of IEC Standard 62301 

Second Edition, that the revisions to IEC 

Standard 62301 could include different 

mode definitions. DOE received 

information, however, that IEC Standard 

62301 Second Edition would not be 

available until late 2010. To allow for 

consideration of standby and off mode 

power consumption in the concurrent 

energy conservation standards 

rulemaking, DOE proposed in the June 

2010 TP SNOPR the new mode 

definitions from the most recent draft 

version of IEC Standard 62301 Second 

Edition, IEC Standard 62301 CDV. The 

definitions of standby mode, off mode, 

and active mode in IEC Standard 62301 

CDV expand upon the EPCA mode 

definitions and provide additional 

guidance as to which functions are 

associated with each mode. 75 FR 

37594, 37602 (June 29, 2010). The 

comments received by IEC on IEC 

Standard 62301 CD2, and the resulting 

amended mode definitions proposed in 

IEC Standard 62301 CDV, demonstrate 

significant participation of interested 

parties in the development of 

definitions that represent a substantial 

improvement over those in IEC 

Standard 62301. Id. These definitions 

are discussed in detail in Section III.B.2. 

In response to the June 2010 TP 

SNOPR, AHAM, Alliance Laundry 

Systems (ALS), and Whirlpool 

Corporation (Whirlpool) commented in 

support of referencing the most recent 

draft version of IEC Standard 62301 

Second Edition, designated as IEC 

Standard 62301 FDIS, for test methods 

and mode definitions rather than IEC 

Standard 62301 First Edition and IEC 

Standard 62301 CDV. (AHAM, Public 

Meeting Transcript, No. 20 at pp. 18, 

26–27; AHAM, No. 27 at p. 2; ALS, No. 

24 at p. 1; Whirlpool, No. 27 at p. 1) 

AHAM and Whirlpool commented 

that IEC Standard 62301 FDIS will soon 

be formally adopted by IEC, and it 

contains a number of clarifications to 

the definitions and test procedures not 

present in IEC Standard 62301 CDV. 

According to AHAM and Whirlpool, 

this will allow for optimum 

international harmonization, giving 

clarity and consistency to the regulated 

community and decreasing testing 

burden. (AHAM, No. 31 at p. 2; 

Whirlpool, No. 27 at p. 1) Additionally, 

AHAM commented that no technical 

edits can be made to the standard after 

the FDIS version, so most countries 

allow a legal reference to this version. 

(AHAM, Public Meeting Transcript, No. 

20 at pp. 14–15) 

AHAM commented that IEC Standard 

62031 FDIS incorporates comments 

from energy efficiency advocates, 


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15 DOE notes that some features that provide 

consumer utility, such as displays and remote 

controls, are associated with standby mode and not 

off mode. A clothes dryer or room air conditioner 

is considered to be in ‘‘off mode’’ if it is plugged 

in to a main power source, is not being used for an 

active function such as drying clothing or providing 

cooling, and is consuming power for features other 

than a display, controls (including a remote 

control), or sensors required to reactivate it from a 

low power state. For example, a clothes dryer with 

mechanical controls and no display or 

continuously-energized moisture sensor, but that 

consumes power for components such as a power 

supply when the unit was not activated, would be 

considered to be in off mode when not providing 

an active function. For room air conditioners, a unit 

with mechanical controls and no display or remote 

control but with a power supply that consumes 

energy could be considered to be in off mode while 

not providing an active function. 

including the addition of an uncertainty 

power measurement section that would 

limit the possibility for different 

measurement results from different test 

labs. (AHAM, Public Meeting 

Transcript, No. 20 at pp. 16, 18, 26–27) 

AHAM also noted that IEC Standard 

62301 FDIS includes a new sampling 

measurement method and an average 

reading measurement method. (AHAM, 

Public Meeting Transcript, No. 20 at pp. 

13–18) AHAM commented that if DOE 

chooses not to adopt the IEC Standard 

62301 FDIS, AHAM supports the use of 

IEC Standard 62301 CDV as the main 

referenced document. (AHAM, No. 31 at 

p. 2) Pacific Gas and Electric Company 

(PG&E), Southern California Gas 

Company (SCGC), Southern California 

Edison (SCE), and Natural Resources 

Defense Council (NRDC) (hereafter ‘‘the 

California Utilities/NRDC’’), stated in a 

jointly filed comment that they support 

harmonization with international 

standards and support the use of the 

definitions and test procedures in IEC 

Standard 62301 CDV. (California 

Utilities/NRDC, No. 33 at p. 2) 

According to publicly available 

information, the IEC currently 

anticipates that the final version of IEC 

Standard 62301 Second Edition will 

likely be published in early 2011. 

Therefore, the second edition is not 

available for DOE’s consideration or 

incorporation by reference. DOE is 

aware that there are significant 

differences between IEC Standard 62301 

First Edition and IEC Standard 62301 

FDIS, which is the latest draft version of 

IEC Standard 62301 Second Edition. 

DOE notes that these changes in 

methodology were first introduced only 

at the IEC Standard 62301 FDIS stage. 

These changes have not been the subject 

of significant comment from interested 

parties, nor has DOE had the 

opportunity to conduct a thorough 

analysis of those provisions. 

Consequently, the merits of these latest 

changes have not been fully vetted to 

demonstrate that they are preferable to 

the existing methodological provisions 

in the current version of the IEC 

standard. For these reasons, DOE has 

decided to base the test procedure 

amendments (other than the mode 

definitions, which are discussed in 

Section III.B.2) on the provisions of IEC 

Standard 62301 First Edition. DOE 

based the mode definitions on the 

language from IEC Standard 62301 CDV 

to address specific concerns raised by 

interested parties, as discussed above in 

this section. As discussed in section 

III.B.2, DOE notes that the mode 

definitions in IEC Standard 62301 CDV 

are essentially the same as the 

definitions provided in IEC Standard 

62301 FDIS, with only minor editorial 

changes. 

For the reasons discussed above and 

in the December 2008 NOPR and June 

2010 SNOPR, DOE amends its test 

procedures for clothes dryers and room 

air conditioners in today’s final rule to 

incorporate by reference the clauses 

from IEC Standard 62301 First Edition 

and the mode definitions from IEC 

Standard 62301 CDV. 73 FR 74639 

(December 9, 2008); 75 FR 37594, 37602 

(June 29, 2010). DOE may consider 

incorporating by reference clauses from 

IEC Standard 62301 Second Edition 

when that version has been published. 

2. Determination of Modes To Be 

Incorporated 

December 2008 TP NOPR 

In the December 2008 TP NOPR, DOE 

proposed to incorporate into the clothes 

dryer and room air conditioner test 

procedure the definitions of ‘‘active 

mode,’’ ‘‘standby mode,’’ and ‘‘off mode’’ 

specified by EPCA. 73 FR 74639, 74644 

(December 9, 2008). EPCA defines 

‘‘active mode’’ as ‘‘the condition in 

which an energy-using product — 

(I) Is connected to a main power 

source; 

(II) has been activated; and 

(III) provides 1 or more main 

functions.’’ 

(42 U.S.C. 6295(gg)(1)(A)(i)) 

EPCA defines ‘‘standby mode’’ as ‘‘the 

condition in which an energy-using 

product— 

(I) Is connected to a main power 

source; and 

(II) offers 1 or more of the following 

user-oriented or protective functions: 

(aa) To facilitate the activation or 

deactivation of other functions 

(including active mode) by remote 

switch (including remote control), 

internal sensor, or timer. 

(bb) Continuous functions, including 

information or status displays 

(including clocks) or sensor-based 

functions.’’ 

(42 U.S.C. 6295(gg)(1)(A)(iii)) This 

definition differs from IEC Standard 

62301 First Edition, which defines 

standby mode as the ‘‘lowest power 

consumption mode which cannot be 

switched off (influenced) by the user 

and that may persist for an indefinite 

time when an appliance is connected to 

the main electricity supply and used in 

accordance with the manufacturer’s 

instructions.’’ The EPCA definition 

permits the inclusion of multiple 

standby modes. 

EPCA defines ‘‘off mode’’ as ‘‘the 

condition in which an energy-using 

product— 

(I) Is connected to a main power 

source; and 

(II) is not providing any standby mode 

or active mode function.’’ 15

(42 U.S.C. 6295(gg)(1)(A)(ii)) 

DOE recognized, however, that the 

EPCA definitions for ‘‘active mode,’’ 

‘‘standby mode,’’ and ‘‘off mode’’ were 

developed to be broadly applicable for 

many energy-using products. For 

specific products with multiple 

functions, these broad definitions could 

lead to certain features being considered 

part of standby mode or off mode 

instead of active mode depending on the 

interpretation of the meaning of ‘‘main 

functions.’’ 73 FR 74639, 74644–45 

(December 9, 2008). As a result, DOE 

further proposed in the December 2008 

TP NOPR to amend the clothes dryer 

and room air conditioner test 

procedures to clarify the range of main 

functions that would be classified as 

active mode functions and clarify 

standby and off mode definitions as 

follows: 

For clothes dryers— 

‘‘Active mode’’ means a mode in 

which the clothes dryer is performing 

the main function of tumbling the 

clothing with or without heated or 

unheated forced air circulation to 

remove moisture from the clothing and/ 

or remove or prevent wrinkling of the 

clothing; 

‘‘Inactive mode’’ means a standby 

mode other than delay start mode or 

cycle finished mode that facilitates the 

activation of active mode by remote 

switch (including remote control), 

internal sensor, or timer, or provides 

continuous status display; 

‘‘Cycle finished mode’’ means a 

standby mode that provides continuous 

status display following operation in 

active mode; 

‘‘Delay start mode’’ means a standby 

mode that facilitates the activation of 

active mode by timer; and 


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16 ‘‘Compilation of comments on 59/523/CD: IEC 

62301 Ed 2.0: Household electrical appliances— 

Measurement of standby power.’’ August 7, 2009. 

p. 6. IEC Standards are available online at http:// 

www.iec.ch. 

17The actual language for the standby mode 

definition in IEC Standard 62301 CDV describes 

‘‘ * * * user oriented or protective functions which 

usually persist’’ rather than ‘‘* * * user oriented or 

protective functions which may persist for an 

indefinite time.’’ DOE notes, however, that section 

5.1 of IEC Standard 62301 CDV states that ‘‘a mode 

is considered persistent where the power level is 

constant or where there are several power levels 

that occur in a regular sequence for an indefinite 

period of time.’’ DOE believes that the proposed 

language, which was originally included in IEC 

Standard 62301 CD2, encompasses the possible 

scenarios foreseen by section 5.1 of IEC Standard 

62301 CDV without unnecessary specificity. 

‘‘Off mode’’ means a mode in which 

the clothes dryer is not performing any 

active or standby function. 73 FR 74645. 

For room air conditioners— 

‘‘Active mode’’ means a mode in 

which the room air conditioner is 

performing the main function of cooling 

or heating the conditioned space, or 

circulating air through activation of its 

fan or blower, with or without 

energizing active air-cleaning 

components or devices such as 

ultraviolet (UV) radiation, electrostatic 

filters, ozone generators, or other aircleaning devices; 

‘‘Inactive mode’’ means a standby 

mode other than delay start mode or offcycle mode that facilitates the activation 

of active mode by remote switch 

(including remote control) or internal 

sensor or provides continuous status 

display; 

‘‘Delay start mode’’ means a standby 

mode in which activation of an active 

mode is facilitated by a timer; 

‘‘Off-cycle mode’’ means a standby 

mode in which the room air 

conditioner: (1) Has cycled off its main 

function by thermostat or temperature 

sensor; (2) does not have its fan or 

blower operating; and (3) will reactivate 

the main function according to the 

thermostat or temperature sensor signal; 

and 

‘‘Off mode’’ means a mode in which a 

room air conditioner is not performing 

any active or standby function. 73 FR 

74645. 

June 2010 TP SNOPR and Today’s Final 

Rule—Active Mode. 

As discussed in section III.B.1, DOE 

proposed in the June 2010 TP SNOPR to 

amend the DOE clothes dryer and room 

air conditioner test procedures to define 

active mode as a mode that ‘‘includes 

product modes where the energy using 

product is connected to a mains power 

source, has been activated and provides 

one or more main functions’’ 75 FR 

37594, 37603 (June 29, 2010). The 

definition of active mode proposed in 

the June 2010 TP SNOPR is the same as 

the definition proposed for the 

December 2008 TP NOPR, with minor 

editorial changes to conform with the 

definition in IEC Standard 62301 CDV. 

73 FR 74639, 74644 (December 9, 2008). 

DOE noted that IEC Standard 62301 CD2 

provided additional clarification that 

‘‘delay start mode is a one off user 

initiated short duration function that is 

associated with an active mode.’’ (IEC 

Standard 62301 CD2, section 3.8) IEC 

Standard 62301 CDV removed this 

clarification; however, in response to 

comments on IEC Standard 62301 CD2 

that led to IEC Standard 62301 CDV, IEC 

states that delay start mode is a one off 

function of limited duration.16 DOE 

inferred this to mean that delay start 

mode would not be considered a 

standby mode, although no conclusion 

is made as to whether it would be 

considered part of active mode. 75 FR 

37594, 37603 (June 29, 2010). Delay 

start mode is discussed later in this 

section. 

As discussed above in section III.B.1, 

the California Utilities/NRDC 

commented that it supports the use of 

the mode definitions in IEC Standard 

62301 CDV. (California Utilities/NRDC, 

No. 33 at p. 2) Also discussed above in 

section III.B.1, AHAM and Whirlpool 

supported the use of the mode 

definitions in IEC Standard 62301 FDIS. 

(AHAM, Public Meeting Transcript, No. 

20 at p. 18; AHAM, No. 31 at p. 2; 

Whirlpool, No. 27 at p. 1) DOE notes 

that the definition of active mode in IEC 

Standard 62301 FDIS is essentially the 

same as the definition provided in IEC 

Standard 62301 CDV, with only minor 

editorial changes. For the reasons stated 

above, DOE is adopting in today’s final 

rule the active mode definition 

proposed in the June 2010 TP SNOPR. 

In the June 2010 TP SNOPR, DOE did 

not change the additional clarifications 

discussed above for the range of main 

functions that would be classified as 

active mode functions, which were 

proposed in the December 2008 TP 

NOPR. 75 FR 37594, 37603 (June 29, 

2010). DOE did not receive any 

comments objecting to the clarifications 

for the range of main functions that 

would be classified as active mode 

functions for each product. Therefore, 

for the reasons stated above, DOE adopts 

the amendments to clarify the range of 

main functions that would be classified 

as active mode functions as proposed in 

the December 2008 TP NOPR. Id. 

For clothes dryers, DOE also 

investigated in the June 2010 TP SNOPR 

whether certain operating cycles 

providing a steam function should be 

covered under active mode, and 

whether measurement of energy 

consumption for such cycles should be 

incorporated into the DOE clothes dryer 

test procedure. 75 FR 37594, 37603 

(June 29, 2010). The current DOE test 

procedure does not contain any 

provisions that would account for the 

energy and water use of steam cycles. 

DOE’s analysis of a preliminary market 

survey of products available on the 

market conducted for the June 2010 TP 

SNOPR suggests that, at this time, steam 

cycles represent a very small fraction of 

overall product use nationwide. DOE 

also stated that it is unaware of energy 

and water consumption or consumer 

usage data with respect to steam. For 

these reasons, DOE did not propose 

amendments to include measurement of 

steam cycles for clothes dryers in the 

June 2010 TP SNOPR. Id. DOE did not 

receive any comments regarding the 

determination to not include 

measurement of steam cycles for clothes 

dryers. For these reasons, DOE is not 

amending its clothes dryer test 

procedure to include measurement of 

steam cycles. 

June 2010 TP SNOPR and Today’s Final 

Rule—Standby Mode 

As discussed in section III.B.1, DOE 

proposed in the June 2010 SNOPR to 

amend the DOE test procedure for 

clothes dryers and room air conditioners 

to define standby mode based on the 

definitions provided in IEC Standard 

62301 CDV. 75 FR 37604. DOE proposed 

to define standby mode as a mode that 

‘‘includes any product modes where the 

energy using product is connected to a 

mains power source and offers one or 

more of the following user oriented or 

protective functions which may persist 

for an indefinite time: 17

• To facilitate the activation of other 

modes (including activation or 

deactivation of active mode) by remote 

switch (including remote control), 

internal sensor, timer; 

• Continuous function: information 

or status displays including clocks; 

• Continuous function: sensor-based 

functions.’’ Id. 

DOE also proposed an additional 

clarifiction that ‘‘a timer is a continuous 

clock function (which may or may not 

be associated with a display) that 

provides regular scheduled tasks (e.g., 

switching) and that operates on a 

continuous basis.’’ Id. This defintion 

was developed based on the definitions 

provided in IEC Standard 62301 CDV, 

and expands upon the EPCA mode 

definitions to provide additional 

clarifications as to which functions are 

associated with each mode. 

ALS supported DOE’s proposed 

definition of standby mode. (ALS, No. 


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24 at p. 1) Whirlpool commented that 

DOE should reference IEC 62301 FDIS 

for the standby mode definition. 

(Whirlpool, No. 27 at p. 1) AHAM 

commented that DOE should define a 

timer function under the standby mode 

definition to exclude limited duration 

situations where the appliance is in a 

higher power state, for example in delay 

start mode. (AHAM, Public Meeting 

Transcript, No. 20 at pp. 35–36) DOE 

notes that the definition of standby 

mode in IEC Standard 62301 FDIS is 

essentially the same as the definition 

provided in IEC Standard 62301 CDV, 

with only minor editorial changes. DOE 

also notes the definition of standby 

mode specifies that it must be a mode 

that may persist for an indefinite time, 

which would exclude limited duration 

situations. Therefore, DOE does not 

believe that any additional clarification 

in the definition of standby mode is 

necessary. For these reasons, DOE is 

adopting in today’s final rule the 

standby mode definition proposed in 

the June 2010 TP SNOPR. 75 FR 37594, 

37604 (June 29, 2010). 

DOE stated in the June 2010 TP 

SNOPR that given these proposed 

definitions, delay start mode and cyclefinished mode for clothes dryers and 

delay start mode and off-cycle mode for 

room air conditioners are not modes 

that persist for an indefinite time, and 

would therefore not be considered as 

part of a standby mode. 75 FR 37604. 

DOE’s analysis of annual energy use in 

specific clothes dryer and room air 

conditioner modes presented in the 

December 2008 TP NOPR showed that 

delay start mode and cycle-finished 

mode for clothes dryers, and delay start 

mode and off-cycle mode for room air 

conditioners, each represent a negligible 

portion (0.1 percent or less) of the 

annual energy use for those products. 73 

FR 74639, 74647, 74649 (December 9, 

2008). Therefore, an integrated energy 

efficiency metric for either clothes 

dryers or room air conditioners would 

not be measurably affected by the 

exclusion of the energy use in any of 

these modes. Further, DOE stated in the 

June 2010 TP SNOPR that the benefit of 

incorporating the energy use of these 

modes into the overall energy efficiency 

metric is outweighed by the burden that 

would be placed on the manufacturers 

to measure power consumption in each 

of these modes. For these reasons, DOE 

did not propose amendments to the test 

procedures to define delay start, cycle 

finished, and off-cycle modes or to 

measure power consumption in delay 

start mode for either product, cycle 

finished mode for clothes dryers, and 

off-cycle mode for room air conditioners 

in the June 2010 TP SNOPR. DOE 

included in the proposed clothes dryer 

and room air conditioner test 

procedures amendments in the June 

2010 TP SNOPR provisions for 

measuring energy consumption only in 

the inactive mode and off mode. 75 FR 

37594, 37604 (June 29, 2010). 

The California Utilities/NRDC, 

AHAM, ALS, and Whirlpool agreed that 

delay start and cycle finished modes for 

clothes dryers would not be considered 

standby modes. (California Utilities/ 

NRDC, No. 33 at p. 2; AHAM, No. 31 at 

p. 3; Whirlpool, No. 27 at p. 1; ALS, No. 

24 at p. 1) AHAM and Whirlpool added 

that delay start and cycle finished 

modes should instead be considered 

part of active mode. (AHAM, No. 31 at 

p. 3; Whirlpool, No. 27 at p. 1) 

Whirlpool also commented that any 

function begun by the user when 

initiating the operating mode includes 

all power consumed until the full 

conclusion of that operation. 

(Whirlpool, No. 27 at p. 1) 

DOE continues to believe that delay 

start, cycle finished, and off-cycle 

modes for clothes dryers and room air 

conditioners are not modes that persist 

for an indefinite time and, therefore, 

would not be considered standby 

modes. For the reasons discussed above, 

DOE continues to believe that the 

benefit of incorporating the energy use 

of these modes into the overall energy 

efficiency is outweighed by the burden 

that would be placed on the 

manufacturers to measure power 

consumption in each of these modes. As 

discussed in section III.B.4, however, 

DOE determined that the power 

consumption of clothes dryers and room 

air conditioners operating in such 

modes approximates the power levels in 

inactive/off modes. Therefore, DOE 

amends the test procedure in today’s 

final rule to specify that all non-active 

mode hours be allocated to the inactive 

and off modes for both clothes dryers 

and room air conditioners. Thus, the 

amended test procedure accounts for the 

energy use in delay start, cycle finished, 

and off-cycle modes. For these reasons, 

DOE is not adopting amendments to the 

test procedures to define delay start, 

cycle finished, and off-cycle modes or to 

measure power consumption in delay 

start mode for either product, cycle 

finished mode for clothes dryers, and 

off-cycle mode for room air 

conditioners. 

In the June 2010 TP SNOPR, DOE 

noted that it received comments from 

interested parties in response to the 

December 2008 TP NOPR that the asshipped factory or ‘‘default’’ settings 

should be used for standby and off 

mode testing. 75 FR 37594, 37605 (June 

29, 2010). DOE stated in the June 2010 

TP SNOPR that provisions for setting up 

the appliance for standby mode and off 

mode testing should be specified in the 

test procedure. However, DOE stated 

that setting up the appliance in 

accordance with manufacturer’s 

instructions or in the as-shipped factory 

or ‘‘default’’ settings would allow 

manufacturers to ship appliances set in 

a low power mode that consumers may 

switch out of during typical standby or 

off mode use. Therefore, DOE proposed 

in the June 2010 TP SNOPR that the 

appliance be set up with the settings 

that produce the highest power 

consumption level, consistent with the 

particular mode definition under test, 

for standby and off mode testing. Id. 

AHAM, Whirlpool, and ALS objected 

to the proposal that the clothes dryer be 

set up at the highest energy 

consumption level consistent with the 

particular standby or off mode. They felt 

such an approach does not reflect 

consumer use, increases test burden to 

determine such settings, and lacks 

conformity, consistency, and 

repeatability across manufacturers. 

AHAM, Whirlpool, and ALS 

commented that the clothes dryer 

should instead be set up in factory or 

‘‘default’’ cycle settings, and that this 

procedure is consistent with consumer 

usage and will result in repeatable, 

reproducible results. AHAM and 

Whirlpool stated that should there be no 

indicators for the default settings, the 

appliance should be tested as shipped. 

AHAM, Whirlpool, and ALS stated that 

such an approach would ensure 

uniformity among the different 

laboratories that may run the test. They 

also stated that DOE’s proposal would 

introduce unnecessary variability into 

the test and add to the test burden 

because manufacturers would need to 

run several tests on every model to 

determine which cycle is the highestenergy cycle. (AHAM, No. 31 at pp. 

4–5; Whirlpool, No. 27 at p. 1; ALS, No. 

24 at pp. 1–2) Whirlpool added that 

repeatable results are of increasing 

importance for verification processes. 

(Whirlpool, No. 27 at p. 1) 

AHAM commented that incentivizing 

manufacturers to ship products with the 

lowest power settings is a better way to 

save energy than shipping with the 

highest power settings, because most 

consumers do not change the settings. 

(AHAM, Public Meeting Transcript, No. 

20 at p. 56) AHAM stated that products 

may have provisions for the consumer 

to add or delete product functions that 

alter the as-shipped standby energy 

mode, and that the power consumption 

in these user-selected modes may 

exceed the power consumption in the 


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18A ‘‘Smart Appliance’’ is a product equipped 

with network mode capabilities. 

19A ‘‘Smart Grid’’ is an automated electric power 

system that monitors and controls electrical grid 

activities and is capable of real-time two-way digital 

communications between utilities and consumers. 

Information on Smart Grid is available online at 

http://www.oe.energy.gov/smartgrid.htm. 

lowest-power consumption mode. 

AHAM stated that the user must be 

informed as to how to make these 

selections and that the selection(s) will 

override the lowest-power consumption 

mode. According to AHAM, testing the 

appliance in the factory settings or 

‘‘default’’ settings provides a clear and 

simple way to define standby mode and 

allow new functions that may be 

developed to be added to the 

appropriate mode without requiring the 

test procedure be revised. (AHAM, No. 

31 at p. 3) 

The California Utilities/NRDC 

supported DOE’s proposed approach to 

use the settings that produce the highest 

power consumption for standby and off 

mode testing. They felt this approach 

would remove a potential opportunity 

for ‘‘gaming’’ appliance testing and 

would ensure that the standby mode 

and off mode testing would measure the 

highest energy-consuming combination 

of modes. The California Utilities/NRDC 

stated that there is no data that indicates 

that the factory default settings are 

uniform, or that they are typically used 

by consumers. In addition, the 

California Utilities/NRDC stated that 

DOE’s proposed approach would 

standardize the standby mode and off 

mode testing among manufacturers, 

because how a factory default setting is 

used during testing may not be 

consistent from manufacturer to 

manufacturer. (California Utilities/ 

NRDC, No. 33 at p. 2) Appliance 

Standards Awareness Project (ASAP) 

also commented that using the default 

settings for testing would give 

manufacturers an incentive to ship 

products in a very low-power mode that 

consumers may never use because they 

can easily adjust the settings. (ASAP, 

Public Meeting Transcript, No. 20 at 

p. 55) 

DOE agrees with AHAM, Whirlpool, 

and ALS that the proposed provisions 

for testing standby and off mode using 

the settings that produce the highest 

power consumption level consistent 

with the particular mode definition 

under test would not be representative 

of consumer use. If manufacturers were 

to ship products in a very low-power 

mode, DOE does not believe that 

consumers would likely modify the 

settings so that the product is in the 

highest power settings, but would 

instead use what would have been the 

as-shipped factory or ‘‘default’’ settings 

during typical standby or off mode use. 

DOE agrees that, because newer 

products offer more consumer related 

features and thus more display or 

settings configurations, requiring 

laboratories to determine the settings 

that produce the highest power 

consumption levels would make it more 

difficult to ensure that test results are 

repeatable. DOE notes that section 5.2 of 

IEC Standard 62301, ‘‘Selection and 

preparation of appliance or equipment,’’ 

includes provisions for installing and 

setting up the appliance as specified by 

manufacturers instructions. Section 5.2 

of IEC Standard 62301 also specifies 

that if no instructions are given, the 

appliance shall be tested at factory or 

default settings, and where there are no 

indications for such settings, the 

appliance shall be tested as supplied. 

DOE believes that section 5.2 of IEC 

Standard 62301 clarifies the installation 

requirements for standby mode and off 

mode energy consumption testing and 

provides additional guidance regarding 

specifications for test setup that would 

result in a measure of standby and off 

mode energy consumption that best 

replicates actual consumer usage. For 

these reasons, DOE is incorporating by 

reference section 5.2 of IEC Standard 

62301 for standby and off mode testing 

in today’s final rule. 

June 2010 TP SNOPR and Today’s Final 

Rule—Standby Mode or Active Mode, 

Network Mode 

For the June 2010 TP SNOPR, DOE 

also considered whether it should adopt 

amendments for network mode. 75 FR 

37594, 37605 (June 29, 2010). Section 

3.7 of IEC Standard 62301 CDV defines 

network mode as a mode category that 

‘‘includes any product modes where the 

energy using product is connected to a 

main power source and at least one 

network function is activated (such as 

reactivation via network command or 

network integrity communication) but 

where the primary function is not 

active.’’ Section 3.7 of IEC Standard 

62301 CDV also provides a note stating, 

‘‘Where a network function is provided 

but is not active and/or not connected 

to a network, then this mode is not 

applicable. A network function could 

become active intermittently according 

to a fixed schedule or in response to a 

network requirement. A ‘network’ in 

this context includes communication 

between two or more separate 

independently powered devices or 

pieces of equipment. A network does 

not include one or more controls, which 

are dedicated to a single piece of 

equipment. Network mode may include 

one or more standby functions.’’ 

However, DOE stated in the June 2010 

TP SNOPR that it is unaware of any 

clothes dryers or room air conditioners 

currently available on the market that 

incorporate a networking function. 

Further, DOE stated that it is unaware 

of any data regarding network mode that 

would enable it to determine 

appropriate testing procedures and 

mode definitions for clothes dryers and 

room air conditioners. In particular, 

DOE stated that it is unaware of data 

and methods for the appropriate 

configuration of networks; whether 

network connection speed or the 

number and type of network 

connections affects power consumption; 

or whether wireless network devices 

may consume power differently when 

the device is looking for a connection as 

opposed to when the network 

connection is actually established. DOE 

stated that it is also unaware of how the 

energy consumption for clothes dryers 

and room air conditioners in a network 

environment might be affected by their 

product design, user interaction, or 

network interaction. For example, DOE 

is unaware of what affects might result 

should the network function become 

active intermittently according to a 

fixed schedule or in response to a 

network requirement. For these reasons, 

the proposed amendments in the June 

2010 TP SNOPR did not include 

network mode. Id. 

AHAM commented that there are not 

enough products currently available on 

the market from which to gather data 

regarding network mode. AHAM stated 

that, in the event DOE decides to 

address network mode, AHAM does not 

support including network mode in 

standby or off mode. AHAM commented 

that network mode and the energy use 

associated with ‘‘Smart Appliances’’ 18

should be treated as a distinctive energy 

use that enhances electrical grid system 

efficiencies that save energy and reduce 

carbon emissions, adding that this is 

consistent with IEC Standard 62301 

FDIS. AHAM also commented that 

when sufficient data exists, AHAM 

would be willing to work with DOE to 

define where and how to address 

network mode. (AHAM, No. 31 at p. 4) 

AHAM also added that if network mode 

is considered part of standby mode, it 

would be a major difficulty in the 

development of ‘‘Smart Appliances’’ and 

the ‘‘Smart Grid.’’ 19 (AHAM, Public 

Meeting Transcript, No. 20 at pp. 38–39) 

Whirlpool commented that network 

mode will become a vital mode in the 

future development of appliances 

capable of interacting with the Smart 

Grid, but that such products do not exist 

today outside of development 

laboratories. Whirlpool urged DOE to 


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20As with the definition for standby mode, IEC 

Standard 62301 CDV qualifies off mode as one that 

‘‘* * * usually persists’’ rather than one that ‘‘* * * 

may persist for an indefinite time.’’ For the same 

reasons as discussed for standby mode, DOE is 

proposing the latter definition. 

retain network mode as a separate mode 

as distinct from any other mode. 

Whirlpool urged that no standard or test 

procedure be adopted for this mode 

until manufacturers have sufficient 

quantities of Smart Grid models in 

production that comprehensive testing 

and measurement can take place. 

(Whirlpool, No. 27 at pp. 1–2) 

The American Council for an EnergyEfficient Economy (ACEEE), ASAP, and 

NRDC stated in a jointly filed comment 

(hereafter the ‘‘Joint Efficiency 

Advocates Comment’’) that if network 

mode is a mode the appliance would be 

in at all times, it should be classified as 

standby; if it is an intermittent or useractivated condition, it should be 

considered active mode. The Joint 

Efficiency Advocates Comment 

suggested that DOE’s definition of 

network mode be aligned with the IEC 

definition and recommended creating a 

test method for network mode. This test 

method would be similar to the standby 

test method, but network connectivity 

would be enabled. The Joint Efficiency 

Advocates Comment stated that units 

could be tested without actually 

connecting to a network; simply 

enabling the network capabilities 

should be enough to test energy 

consumption while in a simulated 

networking state. The Joint Efficiency 

Advocates Comment recommended that 

DOE consider incorporating network 

mode into energy consumption ratings 

as the market for network-enabled 

devices developed. In the meantime, 

network mode should be tested on 

available appliances, and that research 

and analysis should be conducted on 

predicted or actual consumer usage in 

advance of a future revision to the test 

procedure. (Joint Efficiency Advocates 

Comment, No. 28 at p. 3) 

DOE notes that, in the absence of data 

on the operation and functionality of 

network mode, it is unable to define 

appropriate testing conditions and 

procedures for accurately measuring the 

energy use of clothes dryers and room 

air conditioners capable of functioning 

in network mode. This lack of data also 

prevents DOE from evaluating how 

these products will develop in the 

future. Also, because DOE does not have 

sufficient data on the operation and 

functionality of network mode, it is not 

making a determination as to whether 

network mode would be included as 

part of standby or active mode. DOE 

may consider amendments to the 

clothes dryer and room air conditioner 

test procedures when products capable 

of functioning in network mode are in 

production and commercially available. 

At that time, comprehensive analysis 

can determine appropriate testing 

conditions and procedures for 

accurately measuring network mode 

energy use. 

June 2010 TP SNOPR and Today’s Final 

Rule—Off Mode 

As discussed in section III.B.1, DOE 

proposed in the June 2010 TP SNOPR to 

amend the DOE test procedure for 

clothes dryers and room air conditioners 

to define off mode based upon the 

definition in IEC Standard 62301 CDV. 

DOE proposed to define off mode as a 

mode category which ‘‘includes any 

product modes where the energy using 

product is connected to a mains power 

source and is not providing any standby 

mode or active mode function and 

where the mode may persist for an 

indefinite time.20 An indicator that only 

shows the user that the product is in the 

off position is included within the 

clasification of off mode.’’ This defintion 

was developed based on the definitions 

provided in IEC Standard 62301 CDV, 

and expands upon the EPCA mode 

definitions to provide additional 

clarifications as to which functions are 

associated with each mode. 75 FR 

37594, 37605 (June 29, 2010). 

AHAM commented that the off mode 

definition proposed in the June 2010 TP 

SNOPR, which is based on IEC Standard 

62301 CDV, is identical to the definition 

included in IEC Standard 62301 FDIS. 

(AHAM, Public Meeting Transcript, No. 

20 at p. 41) For the reasons stated above, 

DOE is adopting in today’s final rule the 

off mode definition proposed in the 

June 2010 TP SNOPR. 75 FR 37594, 

37605 (June 29, 2010). 

DOE also stated in the June 2010 TP 

SNOPR that under the proposed mode 

definitions, a clothes dryer or room air 

conditioner equipped with a mechanical 

on/off switch that can disconnect power 

to the display, control components, or 

both would be considered as operating 

in the off mode when the switch is in 

the ‘‘off’’ position, provided that no 

other standby or active mode functions 

are energized. DOE also stated that an 

energized LED or other indication that 

only shows the user the product is in 

the off position would be considered 

part of off mode under the proposed 

definition, provided that no other 

standby or active mode functions were 

energized. If energy is consumed by the 

appliance in the presence of a one-way 

remote control, however, the unit would 

be operating in standby mode pursuant 

to EPCA (42 U.S.C. 6295(gg)(1)(A)(iii)). 

DOE clarified that the unit would be 

operating in standby mode if energy is 

consumed in the presence of a remote 

control that facilitates the activation or 

deactivation of other functions 

(including active mode). 75 FR 37594, 

37605–06 (June 29, 2010). 

AHAM and Whirlpool commented 

that they do not support including oneway remote control energy in the 

definition of standby mode. AHAM and 

Whirlpool stated that although EPCA 

defines standby mode to include 

activation by remote control, one-way 

remotes do not meet the intent of the 

statute. AHAM and Whirlpool further 

commented that when a standard 

remote powers a product ‘‘off,’’ the 

remote actually powers the product 

down, not off, such that it can be turned 

on again via remote control, and that 

this would be classified as a standby 

mode under the EPCA standby mode 

definition. According to AHAM and 

Whirlpool, a one-way remote turns the 

product completely off such that it 

cannot be turned on again by the 

remote. Therefore, a one-way remote 

does not put the product into a standby 

mode and should not be incorporated 

into standby mode. (AHAM, No. 31 at 

p. 3; AHAM, Public Meeting Transcript, 

No. 20 at pp. 32–33; Whirlpool, No. 27 

at p. 1) AHAM added that there are 

currently few, if any, one-way remotes 

in the United States. AHAM stated that 

including one-way remotes in the off 

mode instead of in the standby mode 

will encourage manufacturers to design 

products with one-way remotes, which 

could result in decreased energy use. 

(AHAM, No. 31 at p. 3) AHAM also 

noted that a number of other 

governments and organizations consider 

one-way remotes as exempt from 

standby mode because such remotes 

save power. AHAM stated that DOE 

should take the same approach. (AHAM, 

Public Meeting Transcript, No. 20 at pp. 

33–34) 

DOE notes the definition of standby 

mode proposed in the June 2010 TP 

SNOPR states that standby mode 

includes user-oriented or protective 

functions to facilitate the activation of 

other modes (including activation or 

deactivation of active mode) by remote 

switch (including remote control), 

internal sensor, or timer. DOE believes 

that if the product is consuming energy 

to power an infrared sensor used to 

receive signals from a remote control 

(while not operating in the active 

mode), such a function would be 

considered part of standby mode, 

regardless of whether the remote is 

classified as ‘‘one-way’’ or ‘‘two-way.’’ 

This is because the function to facilitate 

the deactivation of another mode by 


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remote switch (including remote 

control), internal sensor, or timer is still 

active. However, if a ‘‘one-way’’ remote 

control powers the product down, 

including turning off any infrared 

sensors to receive signals from a remote 

control, the product would be operating 

in the off mode once it is powered 

down, given that no other standby mode 

functions within the product are 

energized. Depending on whether the 

product is capable of operating in both 

a standby mode and off mode or just the 

off mode, the annual hours associated 

would be allocated as appropriate, as 

discussed in section III.B.4. 

DOE also notes that section 3.9 of IEC 

Standard 62301 CDV provides a 

definition of ‘‘disconnected mode,’’ 

which is ‘‘the status in which all 

connections to mains power sources of 

the energy using product are removed or 

interrupted.’’ IEC Standard 62301 CDV 

also adds a note that common terms 

such as ‘‘unplugged’’ or ‘‘cut off from 

mains’’ also describe this mode and that 

this mode is not part of the low power 

mode category. DOE believes there 

would be no energy use in a 

‘‘disconnected mode’’ and therefore is 

not adopting a definition or testing 

methods for such a mode in the DOE 

test procedure for clothes dryers or 

room air conditioners in today’s final 

rule. 

3. Adding Specifications for the Test 

Methods and Measurements for Clothes 

Dryer and Room Air Conditioner 

Standby Mode and Off Mode Testing 

DOE proposed in the December 2008 

TP NOPR to establish test procedures 

for measuring all standby and off modes 

associated with clothes dryers and room 

air conditioners. 73 FR 74639, 74645 

(December 9, 2008). As discussed in 

section III.B.2, DOE believes that the 

mode identified as inactive mode in the 

December 2008 TP NOPR is the only 

significant standby mode for clothes 

dryers and room air conditioners. This 

section discusses product-specific 

clarifications of the procedures of IEC 

Standard 62301 when used to measure 

standby and off mode energy use for 

clothes dryers and room air 

conditioners. 

a. Clothes Dryers 

DOE understands that displays on 

clothes dryers may reduce power 

consumption by automatically dimming 

or powering down after a certain period 

of user inactivity. For those clothes 

dryers for which the power input in 

inactive mode varies in this fashion 

during testing, DOE proposed in the 

December 2008 TP NOPR that that the 

test be conducted after the power level 

has dropped to its lower-power state. 73 

FR 74639, 74645 (December 9, 2008). 

As part of the residential clothes dryer 

energy conservation standards 

rulemaking preliminary analyses, DOE 

conducted standby mode and off mode 

testing on 11 representative residential 

clothes dryers. All of the units with 

electronic controls automatically 

dimmed or powered down after a period 

of user inactivity. Table III.1 shows the 

measured duration of the higher-power 

state for clothes dryers in DOE’s test 

sample. DOE observed during this 

testing that the higher-power state in 

inactive mode may persist for 

approximately 5–7 minutes of user 

inactivity after the user interface display 

has been energized for all products 

tested. 

TABLE III.1—CLOTHES DRYER STANDBY MODE TESTING: DURATION OF HIGHER-POWER STATE

Product class Test unit Control type Automatic 

power-down? 

Duration of 

higher-power 

state 

(min) 

Vented Electric, Standard ................................ 1 Electromechanical ............................................ N ......................

2 Electromechanical ............................................ N ......................

3 Electronic .......................................................... Y 5 

4 Electromechanical ............................................ N ......................

5 Electromechanical ............................................ N ......................

Vented Electric, Compact (120 V) .................... 6 Electromechanical ............................................ N ......................

Vented Gas ...................................................... 7 Electromechanical ............................................ N ......................

8 Electronic .......................................................... Y 5 

9 Electronic .......................................................... Y 5 

10 Electronic .......................................................... Y 7 

11 Electronic .......................................................... Y 7 

Paragraph 5.3.1 of section 5.3 of IEC 

Standard 62301 specifies, for products 

in which the power varies by not more 

than 5 percent from a maximum level 

during a period of 5 minutes, that the 

user wait at least 5 minutes for the 

product to stabilize and then measure 

the power at the end of an additional 

time period of not less than 5 minutes. 

Paragraph 5.3.2 of IEC Standard 62301 

contains provisions for measuring 

average power in cases where the power 

is not stable. In such cases, it requires 

a measurement period of no less than 5 

minutes, or one or more complete 

operating cycles of several minutes or 

hours. Based on its testing results 

shown in Table III.1, however, DOE 

noted that some clothes dryers may 

remain in the higher-power state for the 

duration of a 5-minute stabilization 

period and 5-minute measurement 

period, and then drop to the lowerpower state that is more representative 

of inactive mode. In contrast to IEC 

Standard 62301, IEC Standard 62301 

CDV specifies for each testing method 

that the product be allowed to stabilize 

for at least 30 minutes prior to a 

measurement period of not less than 10 

minutes. DOE stated in the June 2010 

TP SNOPR that this clarification would 

allow sufficient time for displays that 

automatically dim or power down after 

a period of user inactivity to reach the 

lower-power state prior to measurement. 

DOE stated that based on its observation 

of the automatic power-down time 

periods during its testing, the 30-minute 

stabilization and 10-minute 

measurement periods provide a clearer 

and more consistent testing procedure 

than the corresponding times specified 

in IEC Standard 62301. A testing 

procedure using these stabilization and 

measurement periods would result in 

representative measurements among 

products that may have varying times 

before the power drops to a low level. 

75 FR 37594, 37607 (June 29, 2010). 

DOE also noted in the June 2010 TP 

SNOPR that allowing a test period of 

‘‘not less than’’ or ‘‘at least’’ a specified 

amount of time, as provided in both IEC 


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Standard 62301 and IEC Standard 62301 

CDV, may result in different test 

technicians testing the same product for 

different periods of time. To ensure the 

testing procedures for standby and off 

mode are clear and consistent such that 

different test technicians test the 

product using the same procedures, 

DOE proposed the stabilization period 

be 30 to 40 minutes, and the test period 

be 10 minutes. Id. 

ALS and AHAM supported DOE’s 

proposal to require a stabilization 

period of 30 minutes and a test period 

of 10 minutes for clothes dryers. (ALS, 

No. 24 at p. 1; AHAM, No. 31 at p. 4) 

AHAM commented that the purpose of 

the stabilization period is to reach a 

steady-state condition with a power 

state that may last for an indefinite 

period of time. AHAM stated that IEC 

Standard 62301 includes provisions to 

wait to reach the lowest power state 

without specifying a time to allow an 

accurate measurement for all products, 

so that all products are tested in the 

same manner. AHAM noted that this 

will result in some power consumption 

in the higher energy state not being 

measured, but this amount is likely to 

be small due to the small amount of 

time products spend in this mode. 

(AHAM, Public Meeting Transcript, No. 

20 at pp. 45–48) AHAM also 

commented that a note in section 3.4 of 

IEC Standard 62301 FDIS states that a 

transition between modes would not be 

considered a mode, and that none of the 

123 countries involved with the IEC 

process commented on this note. 

(AHAM, Public Meeting Transcript, No. 

20 at pp. 48–49) 

DOE agrees with AHAM’s comments 

that any transition between modes 

would not be considered a mode. 

Therefore, DOE does not intend to 

include the measurement of energy 

consumption for any stabilization or 

transition phases when the product is 

powering down to a lower-power state. 

For the reasons stated above, DOE 

adopts in today’s final rule the 

requirement that the stabilization period 

be 30 to 40 minutes and the test period 

be 10 minutes, as proposed in the June 

2010 TP SNOPR. 75 FR 37594, 37607 

(June 29, 2010). 

DOE proposed in the December 2008 

TP NOPR to adopt the test room 

ambient temperature of 73.4 ± 9 °F 

specified by IEC Standard 62301 for 

standby mode and off mode testing. 73 

FR 74639, 74645–46 (December 9, 

2008). This test room ambient 

temperature is slightly different from 

the ambient temperature currently 

specified for DOE’s drying performance 

tests of clothes dryers (75 ± 3 °F). 

However, the proposed test room 

ambient temperature conditions would 

permit manufacturers who opt to test 

active, standby, and off modes in the 

same test room to use the current 

ambient temperature requirements for 

drying tests, because the latter 

temperatures are within the limits 

specified by IEC Standard 62301. 

Alternatively, the proposed temperature 

specifications would allow a 

manufacturer who opts to conduct 

standby mode and off mode testing 

separately from drying tests more 

flexibility in ambient temperature. 

In comments submitted on the June 

2010 TP SNOPR, AHAM, ALS, and 

Whirlpool supported the proposed test 

room ambient temperature for clothes 

dryer standby and off mode testing. 

(AHAM, No. 31 at p. 4; ALS, No. 24 at 

p. 1; Whirlpool, No. 27 at p. 2) For the 

reasons stated above, and in the absence 

of any comments on this proposal, DOE 

adopts the test room ambient 

temperature of 73.4 ± 9 °F specified by 

IEC Standard 62301 for standby mode 

and off mode testing. 

b. Room Air Conditioners 

A room air conditioner with a 

temperature display may use varying 

amounts of standby power depending 

on the digit(s) being displayed. DOE 

proposed in the December 2008 TP 

NOPR to require that test room 

temperature be maintained at 74 ± 2 °F, 

and that the temperature control setting 

be 79 °F. 73 FR 74639, 74646 (December 

9, 2008). These conditions differ from 

the cooling performance testing 

conditions in the current DOE room air 

conditioner test procedure. The cooling 

performance test conditions are 

specified as 80 °F on the indoor side of 

the test chamber and 95 °F on the 

outdoor side. In addition, the cooling 

performance test conditions do not 

specify a temperature control setting. 

DOE proposed the different test room 

conditions in the December 2008 TP 

NOPR because such conditions would 

assure a consistent display 

configuration, and thus a representative 

power consumption, for all room air 

conditioners under test, particularly 

during the off-cycle operation defined in 

the December 2008 TP NOPR as a 

standby mode. 73 FR 74646. 

As part of the room air conditioner 

energy conservation standards 

rulemaking preliminary analyses, DOE 

conducted standby mode and off mode 

testing on representative room air 

conditioners. During its preliminary 

tests, DOE determined that room air 

conditioner displays among the units it 

tested do not provide any user 

information in inactive mode. In 

addition, DOE determined that the 

displays among the units it tested 

provide indication of time delay or time 

until start rather than temperature when 

the air conditioners are in delay start 

mode. As a result, DOE stated in the 

June 2010 TP SNOPR that the proposed 

test chamber ambient conditions would 

be relevant only for off-cycle mode. DOE 

also stated that if the test procedure 

were limited to measurement of inactive 

mode as the single standby mode and an 

off mode as discussed in section III.B.2, 

the proposed close tolerance on ambient 

temperature would not be required. 75 

FR 37594, 37608 (June 29, 2010). DOE 

therefore proposed in the June 2010 TP 

SNOPR to provide flexibility in the 

room air conditioner test procedure 

amendments by allowing standby mode 

and off mode testing either in a test 

chamber used for measurement of 

cooling performance or in a separate test 

room that meets the specified standby 

mode and off mode test conditions. The 

proposed amendments to the room air 

conditioner test procedure in the June 

2010 TP SNOPR specify maintaining the 

indoor test conditions at the 

temperature required by section 4.2 of 

IEC Standard 62301 if tested in a 

cooling performance test chamber. The 

proposed amendments also specify 

maintaining the room ambient test 

conditions at the temperature required 

by section 4.2 of IEC Standard 62301 if 

tested in a separate test room. Further, 

if the unit is tested in the cooling 

performance test chamber, the proposed 

amendments in the June 2010 TP 

SNOPR allow the manufacturer to 

maintain the outdoor test conditions 

either as specified for the DOE cooling 

test procedure or according to section 

4.2 of IEC Standard 62301 for standby 

and off mode testing. DOE also noted 

that the indoor temperature conditions 

required by the DOE cooling 

performance test procedure fall within 

the temperature range specified by 

section 4.2 of IEC Standard 62301. Id. 

AHAM supported DOE’s proposed 

test room ambient temperature for room 

air conditioner standby and off mode 

testing. (AHAM, No. 31 at p. 4) ASAP 

questioned whether DOE has conducted 

any testing to determine if there are any 

differences in the power measurements 

between the two temperature 

conditions. (ASAP, Public Meeting 

Transcript, No. 20 at p. 60) DOE is not 

aware of any data indicating that the 

ambient temperature would affect the 

measured standby or off mode power. 

For the reasons stated above, DOE is 

adopting in today’s final rule the test 

room ambient temperature proposed in 

the June 2010 TP SNOPR for room air 

conditioner standby and off mode 


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testing. 75 FR 37594, 37608 (June 29, 

2010). 

Similar to clothes dryers, DOE 

proposed in the December 2008 TP 

NOPR (73 FR 74639, 74646 (December 

9, 2008)) that standby and off modes for 

room air conditioners, other than delay 

start mode, be tested with a stabilization 

period of no less than 5 minutes and a 

measurement period of no less than 5 

minutes for units with stable power, 

consistent with paragraph 5.3.1 of 

section 5.3 of IEC Standard 62301. In 

cases where the power was unstable, the 

provisions of paragraph 5.3.2 would 

apply, in which the measurement 

period would be no less than 5 minutes 

or one or more complete operating 

cycles. DOE stated in the June 2010 TP 

SNOPR that it does not have any 

information or data that would suggest 

that a 30-minute stabilization period 

followed by a 10-minute measurement 

period would produce more 

representative or consistent standby and 

off mode power measurements than the 

times proposed in the December 2008 

TP NOPR. 75 FR 37594, 37608 (June 29, 

2010). 

DOE also noted, however, that 

allowing a test period of ‘‘not less than’’ 

or ‘‘at least’’ a specified amount of time, 

as provided in IEC Standard 62301, may 

result in different test technicians 

testing the same product for different 

periods of time. To ensure that the 

testing procedures for standby and off 

mode are clear and consistent, such that 

different test technicians are testing the 

product using the same procedures, 

DOE proposed in the June 2010 TP 

SNOPR to require that the stabilization 

period be 5 to 10 minutes, and the test 

period be 5 minutes. 75 FR 37594, 

37608 (June 29, 2010). 

AHAM supported DOE’s proposed 

stabilization period for room air 

conditioners. (AHAM, No. 31 at p. 4) 

For the reasons stated above, DOE 

adopts the requirement that the 

stabilization period be 5 to 10 minutes 

and the test period be 5 minutes, as 

proposed in the June 2010 TP SNOPR. 

75 FR 37594, 37608 (June 29, 2010). 

4. Calculation of Energy Use Associated 

With Standby Modes and Off Mode 

Measurements of power consumption 

associated with each standby and off 

mode for clothes dryers and room air 

conditioners are expressed in W. The 

annual energy consumption in each of 

these modes for a clothes dryer or room 

air conditioner is the product of the 

power consumption in W and the time 

spent in that particular mode. 

a. Clothes Dryers 

Energy use for clothes dryers is 

expressed in terms of total energy use 

per drying cycle. As discussed in 

section III.D.3, DOE has determined that 

it is technically feasible to incorporate 

measures of standby and off mode 

energy use into the overall energy-use 

metric. (42 U.S.C. 6295(gg)(2)(A)) 

Therefore, DOE has examined standby 

and off mode energy consumption in 

terms of annual energy use apportioned 

on a per-cycle basis. Energy used during 

a drying cycle (active mode) is directly 

measured in the DOE test procedure, 

although adjustments are made to the 

directly measured energy to account for 

differences between test and field 

conditions. 

DOE proposed in the December 2008 

TP NOPR to adopt a similar approach 

for measuring energy consumption 

during standby and off modes for 

clothes dryers. Specifically, to measure 

energy consumption during standby and 

off modes for clothes dryers, DOE 

proposed in the December 2008 TP 

NOPR to adopt the current 140 hours 

associated with drying (that is, the 

active mode) and to associate the 

remaining 8,620 hours of the year with 

the standby and off modes. Table III.2 

presents the comparison of the 

approximate wattages and annual 

energy use associated with all modes 

that DOE proposed in the December 

2008 TP NOPR. 73 FR 74639, 74647–48 

(December 9, 2008). 

TABLE III.2—DOE ESTIMATE OF ANNUAL ENERGY USE OF CLOTHES DRYER MODES

Mode Hours 

Typical 

power 

W 

Annual energy use 

kilowatthours (kWh) 

Active ................................................................................................................................................ 140 6,907 ........... 967. 

Delay Start ........................................................................................................................................ * 34 3 .................. 0.1. 

Cycle Finished .................................................................................................................................. ** 429 3 .................. 1. 

Off and Inactive ................................................................................................................................ † 8,157 0.5 to 3 ........ 4 to 24. 

* 5 minutes per cycle × 416 cycles per year. 

** 5 percent of remaining time (0.05 × (8,760 ¥ 140 ¥ 34) = 429). 

† 95 percent of remaining time (0.95 × (8,760 ¥140 ¥ 34) = 8,157). 

DOE reviewed comments from 

interested parties on the December 2008 

TP NOPR and stated in the June 2010 

TP SNOPR that under the proposed 

definitions of standby and off modes, 

the allocation of annual hours to 

inactive and off modes is appropriate. 

DOE also stated that the June 2010 TP 

SNOPR did not affect DOE’s proposal in 

the December 2008 TP NOPR for this 

allocation of hours. 75 FR 37594, 37609 

(June 29, 2010). 

In the December 2008 TP NOPR, DOE 

also proposed an alternative simplified 

methodology for allocating annual 

hours. 73 FR 74639, 74648 (December 9, 

2008). The comparison of annual energy 

use of different clothes dryer modes 

shows that delay start and cycle 

finished modes represent a negligible 

percentage of total annual energy 

consumption. In addition, for clothes 

dryers currently on the market, power 

levels in these modes are similar to 

those for off/inactive modes. Therefore, 

DOE proposed that all of the non-active 

hours (which total 8,620) would be 

allocated to the inactive and off modes. 

73 FR 74648. As discussed in section 

III.B.2, DOE determined in the June 

2010 TP SNOPR that delay start and 

cycle finished modes are not standby 

modes according to the proposed 

definitions. Because the power 

consumption of clothes dryers operating 

in such modes approximates the power 

levels in off/inactive modes, DOE stated 

in the June 2010 TP SNOPR that it 

would be more appropriate under a 

simplified approach to allocate the 

hours associated with delay start and 

cycle finished modes to off/inactive 

modes. Therefore, and because DOE did 

not propose amendments to the clothes 

dryer test procedure to measure delay 

start and cycle finished power 

consumption given the negligible power 

consumption in these modes, DOE 

proposed in the June 2010 TP SNOPR to 

maintain the estimate of 8,620 hours as 

the non-active hours that would be 

allocated to inactive and off modes for 

clothes dryers. 75 FR 37594, 37601 

(June 29, 2010). 


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ALS objected to retaining the 

allocation of clothes dryer hours 

proposed in the June 2010 TP SNOPR. 

ALS stated that the estimates were 

based on 416 cycles per year and 

supported a revision to the hours so that 

they are consistent with DOE’s proposed 

283 cycles per year and other proposed 

cycle definition changes. (ALS, No. 24 

at p. 2) DOE notes that the estimate of 

delay start mode hours developed in the 

December 2008 TP NOPR was based on 

the number of cycles per year in the 

existing test procedure (that is, 416 

cycles per year). DOE estimated in the 

December 2008 TP NOPR that 5 minutes 

per cycle are spent in delay start mode. 

73 FR 74639, 74647 (December 9, 2008). 

Under the amended test procedure in 

today’s final rule, the number of cycles 

per year is revised from 416 to 283 

cycles per year. Thus, DOE now 

estimates that clothes dryers would be 

in delay start mode approximately 24 

hours per year. DOE also notes that the 

estimate for active mode hours 

presented in the December 2008 TP 

NOPR was fixed based on the number 

of such hours specified in the existing 

test procedure (140 hours). 73 FR 

74646–7. DOE acknowledges that its 

estimate of the number of cycles per 

year has decreased. As discussed later 

in this section, DOE notes that other 

proposed amendments in today’s final 

rule, including the changes to the initial 

RMC, test load size, and specified water 

temperature for test load preparation, 

may also affect cycle time and the 

number of active mode hours per year. 

DOE is not aware, however, of any data 

indicating that the number of active 

mode hours has changed and, if so, 

what a more accurate number might be. 

Therefore, DOE is not proposing 

amendments to the number of active 

mode hours. In the December 2008 TP 

NOPR DOE estimated 5 percent of the 

remaining hours (that is, not including 

active mode hours and delay start mode 

hours) would be associated with cycle 

finished mode and 95 percent 

associated with inactive/off modes (73 

FR 74647). This would result in revised 

values of 430 hours for cycle finished 

mode and 8,166 hours for inactive/off 

modes. DOE acknowledges that the 

estimates for hours in each standby and 

off mode would change based on the 

number of annual clothes dryer cycles. 

Because DOE is not proposing to 

measure delay start and cycle finished 

modes for clothes dryers, however, and 

is instead allocating those hours to 

inactive/off modes (as discussed in 

section III.B.2), the aforementioned 

revisions to the standby and off mode 

hours would not change the total hours 

allocated to inactive/off mode because 

the number of active mode hours is 

fixed. 

ALS commented that DOE must also 

take into account the active mode cycle 

length change if DOE accepts 

commenters’ support for testing the 

complete cycle including cool-down in 

the automatic termination test cycle. 

DOE’s studies indicated that the cooldown in the automatic termination test 

cycle would be required to be tested on 

100 percent of clothes dryers on the 

market. ALS commented that the 

Whirlpool-supplied estimate presented 

in the June 2010 TP SNOPR indicates an 

active drying cycle length of 20 minutes, 

which ALS stated is far too short if cooldown period is included. (ALS, No. 24 

at p. 2) AHAM also questioned whether 

including the cool-down period would 

change the number of hours allocated to 

each mode in the calculations. (AHAM, 

Public Meeting Transcript, No. 20 at pp. 

99–100) AHAM further commented that 

it could be difficult to assign a typical 

time to cool-down mode because there 

are significant differences between 

clothes dryers in the amount of time 

spent in this mode. (AHAM, Public 

Meeting Transcript, No. 20 at pp. 100– 

101) AHAM also commented, however, 

that cycle times are very dependent on 

the initial RMC used and that reducing 

the initial RMC value and accounting 

for cool-down may end up equaling out 

to the current 140 hours. (AHAM, 

Public Meeting Transcript, No. 20 at pp. 

103–104) 

As discussed in section III.C.2, DOE is 

not adopting the amendments to the 

clothes dryer test procedure to better 

account for automatic cycle termination 

that were proposed in the June 2010 TP 

SNOPR. Therefore, DOE is not 

amending the test procedure to include 

the cool-down period as part of any 

automatic cycle termination tests. For 

this reason, DOE does not believe the 

estimates for the annual hours spent in 

each mode should be revised on the 

basis of the inclusion of a cool-down 

period. With regard to AHAM’s 

comments concerning the reduction in 

initial RMC and the effect on cycle 

times, DOE addresses how that 

amendment, along with the other 

amendments in today’s final rule, affect 

the clothes dryer cycle time later in this 

section. 

ALS objected to DOE’s proposal of 

429 hours of ‘‘cycle finished’’ mode. ALS 

commented that while clothes dryers 

may include an option alerting the user 

that the cycle has finished via an alert 

signal emitting periodically for up to an 

hour, ALS does not believe a user would 

avoid responding to the alert for an hour 

each and every cycle. According to ALS, 

most users will attend their dried 

garments within only a few minutes 

after the end of the drying cycle, 

because users want to complete their 

laundry chores as quickly as they can. 

Additionally, ALS commented that 

users would utilize this feature for only 

one third of clothes dryer cycles if cycle 

finished mode is an option. Therefore, 

ALS stated that ‘‘cycle finished mode’’ 

hours should be no more than one third 

of the ‘‘active mode’’ hours. ALS further 

suggested that DOE conduct consumer 

studies on user habits for ‘‘cycle 

finished’’ mode. (ALS, No. 24 at p. 2) 

DOE analysis suggests that a cycle 

finished mode feature (that is, a status 

display following operation in active 

mode indicating to the user that the 

cycle is complete) is activated by default 

at the end of the drying cycle for most 

clothes dryers. For this reason, DOE 

believes consumers use the cycle 

finished mode feature for more than one 

third of clothes dryer cycles. In 

addition, DOE does not have any 

consumer usage data suggesting that 

most consumers attend to their laundry 

within only a few minutes after the end 

of the drying cycle. In the absence of 

such data, DOE maintains for today’s 

final rule its estimate from the 

December 2008 TP NOPR that cycle 

finished mode represents 5 percent of 

the remaining time outside of active 

mode and delay start mode. This 

estimate was based on a household 

survey conducted in 2000 in Australia. 

73 FR 74639, 74647 (December 9, 2008). 

DOE is not aware of any other consumer 

usage data regarding cycle finished 

mode hours. DOE also notes it is not 

proposing to measure delay start and 

cycle finished modes for clothes dryers 

and is instead allocating those hours to 

inactive/off modes, as discussed in 

section III.B.2. Therefore, any revisions 

to the number of cycle finished mode 

hours would not change the total hours 

allocated to inactive/off mode. 

In the December 2008 TP NOPR, DOE 

proposed to allocate the number of 

hours for the combined off and inactive 

modes entirely to either off mode or 

standby mode, as appropriate, if only 

one of these modes is possible for the 

clothes dryer. DOE noted in the October 

2008 TP NOPR that information to guide 

allocation of the hours for clothes dryers 

that have both inactive and off modes is 

currently unavailable. DOE is aware of 

two operational scenarios: (1) A clothes 

dryer reverts to an off mode after a 

specified time in inactive mode; or 

(2) a clothes dryer stays in inactive 

mode unless the user switches the 

appliance back to off mode. DOE does 

not have information regarding the 

percentage of clothes dryers being sold 


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that fall into these categories. Because of 

this limitation, DOE proposed in the 

October 2008 TP NOPR to allocate half 

of the hours determined for off/inactive 

modes to each of the two modes. 73 FR 

74648. Because DOE did not receive any 

comments or additional data regarding 

allocation of hours in response to the 

December 2008 TP NOPR, the SNOPR 

did not affect DOE’s proposal in the 

December 2008 TP NOPR for the 

allocation of hours between inactive 

mode and off mode. 

The Joint Efficiency Advocates 

Comment suggested that DOE conduct 

research to determine how inactive and 

off mode hours are commonly divided 

up in practice for clothes dryers. The 

Comment stated that off mode usage 

may differ depending on the mode’s 

‘‘user-friendliness,’’ but that this is not 

accounted for in the current test 

procedure. According to the Joint 

Efficiency Advocates Comment, very 

few consumers would take advantage of 

a ‘‘hidden’’ feature such as a small 

switch on the back of the unit. 

Therefore, crediting 50 percent of nonactive mode hours to off mode would 

allow manufacturers to take advantage 

of the energy rating benefit simply by 

providing the off-mode option, 

regardless of how apparent or userfriendly the option was to the consumer. 

(Joint Efficiency Advocates Comment, 

No. 28 at p. 3) 

DOE is unaware of any available data 

for the allocation of those hours. DOE 

requested data on the annual hours for 

various modes, including the split 

between standby and off modes in the 

NOPR (73 FR 74639, 74654) and the 

June 2010 TP SNOPR (75 FR 37594, 

37643), but it did not receive any 

information. Therefore, in the absence 

of data indicating otherwise, DOE is 

amending the test procedure in today’s 

final rule to allocate half of the hours 

determined for off/inactive modes to 

each of the two modes, for those 

products capable of functioning in both 

modes. If data is made available that 

indicates a different allocation of hours 

between inactive and off mode, DOE 

may consider revising this allocation. 

DOE recognizes that the analysis of 

the number of annual hours allocated to 

each clothes dryer mode is based, in 

part, on the number of annual use 

cycles. As discussed in section III.C.5.a, 

DOE believes that the average number of 

annual cycles is currently 283 rather 

than the 416 cycles specified in the 

current DOE clothes dryer test 

procedure. DOE stated in the June 2010 

TP SNOPR, however, that it does not 

have any information on whether active 

mode cycle times may have changed 

accordingly. 75 FR 37594, 37610 (June 

29, 2010). It is possible that the smaller 

number of use cycles may correspond to 

the same amount of clothing being dried 

in larger load sizes and thus, 

potentially, longer drying times. In the 

absence of any data supporting this 

assumption, however, DOE proposed in 

the June 2010 TP SNOPR the same 

allocation of hours for inactive mode 

and off mode that were proposed in the 

December 2008 TP NOPR, even though 

DOE proposed fewer annual use cycles 

in the June 2010 TP SNOPR. Id. 

The California Utilities/NRDC 

generally supported DOE’s calculation 

method for standby and off mode for 

clothes dryers and method of allocation 

of yearly clothes dryer hours to standby 

and off modes proposed in the June 

2010 TP SNOPR. However, the 

California Utilities/NRDC urged DOE to 

reconsider its allocation of 140 hours to 

active mode for clothes dryers, 

particularly in light of DOE’s proposed 

adoption of 283 annual use cycles. The 

California Utilities/NRDC stated that if 

DOE assumes 140 active mode hours per 

year and 283 cycles per year, this 

translates to an average cycle time of 

about 30 minutes, but that DOE has not 

provided any data to support such an 

assumption. (California Utilities/NRDC, 

No. 33 at p. 2) 

The California Utilities/NRDC also 

stated that if DOE relies on Whirlpool’s 

value of 20 minutes per cycle, then 

under the new test procedure, the 

number of active mode hours would be 

94 hours per year (283 cycles/year × 20 

minutes/cycle). The California Utilities/ 

NRDC stated that there is also evidence 

to indicate the average length of a 

clothes dryer cycle may be higher than 

20 minutes, and that therefore the 

assumption of 140 hours should be 

adjusted upwards. The California 

Utilities/NRDC added that the report by 

Ecos Consulting (ECOS) (prepared for 

NRDC) summarizes results for four 

clothes dryers tested under a variety of 

cycles, which showed an average 

recorded cycle length of 46.5 minutes, 

corresponding to 219 annual hours 

(assuming 283 cycles per year). The 

California Utilities/NRDC noted that 

these cycles do not all represent the 

typical DOE load, but they represent a 

wide variety of potential consumer 

loads and modes of operation which 

may be indicative of in-field conditions. 

(California Utilities/NRDC, No. 33 at pp. 

2–3) The Joint Efficiency Advocates 

Comment similarly stated that according 

to the ECOS report for NRDC, the 

average cycle length is 49.5 minutes for 

clothes dryers with automatic 

termination controls, which 

corresponds to 233 hours spent in active 

mode per year. The Joint Efficiency 

Advocates Comment recommended 

basing the number of hours spent in 

active mode annually on the cycle 

length multiplied by the average 

number of cycles per year. (Joint 

Efficiency Advocates Comment, No. 28 

at p. 4) 

The Joint Efficiency Advocates 

Comment and the California Utilities/ 

NRDC both commented that DOE 

should try to obtain data from AHAM or 

manufacturers on average clothes dryer 

cycle length and average yearly hours. 

(Joint Efficiency Advocates Comment, 

No. 28 at p. 4; California Utilities/ 

NRDC, No. 33 at p. 3) The Joint 

Efficiency Advocates Comment also 

added that DOE should test a 

representative sample of clothes dryers 

to develop an accurate estimate of 

average cycle length, which could then 

be multiplied by the revised number of 

cycles per year to calculate the annual 

active mode hours. (Joint Efficiency 

Advocates Comment, No. 28 at p. 4) 

Whirlpool commented that 140 active 

mode hours is reasonably consistent 

with consumer use and practices, and 

was not opposed to the continuing with 

this known and well-understood 

estimate. (Whirlpool, No. 27 at p. 2) 

DOE first notes that it is not relying 

on the 20 minutes per cycle estimate 

provided by Whirlpool, for which the 

testing procedure is not specified, to 

estimate the annual active mode hours. 

DOE notes that the estimate of 46.5 

minutes per cycle, as suggested by the 

California Utilities/NRDC and based on 

data from the ECOS report, uses 

automatic termination cycles with 

clothes loads composed of cotton towels 

with initial RMCs ranging from 70 to 

100 percent. As discussed below in 

section III.C.5.b, DOE amends the test 

procedure to change the initial RMC to 

57.5 percent, which will result in a 

cycle time shorter than that estimated 

by the California Utilities/NRDC 

because less moisture must be removed 

during the drying cycle. DOE also notes 

that the Joint Efficiency Advocates 

Comment’s estimate of 49.5 minutes per 

cycle was also based on data from the 

ECOS report. The estimate differs from 

the California Utilities/NRDC’s estimate 

because it included data from an air dry 

cycle with a length of 120 minutes, 

which would not be appropriate for 

developing an estimate of clothes dryer 

cycle time. This is because an air dry 

cycle would not be representative of 

consumer use. Based on the amendment 

to the number of annual use cycles, DOE 

notes that the cycle length would be 

approximately 30 minutes (140 annual 

active mode hours/283 active mode 

cycles per year). DOE is unaware, 

however, of consumer usage data 


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21Multiplying by 0.75 eliminates hours 

associated with unplugged hours, assumed for half 

of the hours of the year for half of room air 

conditioners as described in the December 2008 TP 

NOPR (73 FR 74639, 74648 (Dec. 9, 2008)); 750 = 

Cooling (active mode) hours; 705 = Fan-only (active 

mode) hours. 

indicating that the annual active mode 

hours have changed. For these reasons, 

DOE is not amending the test procedure 

in today’s final rule to revise the 

number of active mode hours per year. 

In summary, DOE is amending the 

clothes dryer test procedure in today’s 

final rule to calculate clothes dryer 

energy use per cycle associated with 

inactive and off modes by: (1) 

Calculating the product of wattage and 

allocated hours for inactive and off 

modes, depending on which of these 

modes are possible; (2) summing the 

results; (3) dividing the sum by 1,000 to 

convert from watt-hours (Wh) to 

kilowatt-hours (kWh); and (4) dividing 

by 283 cycles per year. The 8,620 hours 

for off/inactive modes shall be allocated 

entirely to either off mode or inactive 

mode, as appropriate, if only one of 

these modes is possible for the clothes 

dryer. If both modes are possible, the 

hours shall be allocated to each mode 

equally as discussed in this section, and 

each shall be allocated 4,310 hours. 

b. Room Air Conditioners 

In the December 2008 TP NOPR, DOE 

stated it was not aware of reliable data 

for hours spent in different standby and 

off modes in room air conditioners. 

Therefore, DOE estimated the annual 

hours for standby and off modes and the 

relative magnitude of annual energy use 

in standby and off modes in an example 

for a representative 8,000 Btu/hour (Btu/ 

h), 9 EER unit that has delay start, offcycle, and inactive modes. 73 FR 74639, 

74648–49 (December 9, 2008). DOE’s 

estimates of annual energy use in each 

mode are shown in Table III.3. 

TABLE III.3—DOE ESTIMATE OF ANNUAL ENERGY USE OF ROOM AIR CONDITIONER MODES FOR A REPRESENTATIVE UNIT

WITH 8,000 BTU/H CAPACITY AND 9 EER 

Mode Hours 

Typical 

power 

(W) 

Annual energy use 

(kWh) 

Active Cooling ................................................................................................................................... 750 889 .............. 667. 

Delay Start ........................................................................................................................................ 90 2 .................. 0.2. 

Off-Cycle ........................................................................................................................................... 440 2 .................. 0.9. 

Off and Standby ............................................................................................................................... 4,850 0.5 to 2 ........ 2.5 to 10. 

In the December 2008 TP NOPR, DOE 

also proposed an alternative simplified 

methodology. Similar to the analysis for 

clothes dryers, comparing annual energy 

use of different room air conditioner 

modes shows that delay start and offcycle modes represent a small 

percentage of annual energy use in the 

active mode, and that the power 

consumption in those standby modes is 

distinct from but comparable to those 

for off/inactive modes. Thus, DOE 

proposed adopting an alternative 

approach allocating the non-active 

hours as if the room air conditioner has 

only the inactive standby mode. A total 

of 5,115 hours would be allocated to the 

standby and off modes (8,760 × 0.75 ¥ 

750 ¥ 705 = 5,115).21 73 FR 74639, 

74649 (December 9, 2008). For these 

reasons, and because DOE did not 

propose amendments to the room air 

conditioner test procedure to measure 

delay start and off-cycle power 

consumption given the negligible power 

consumption in these modes, DOE 

proposed in the June 2010 TP SNOPR 

allocating 5,115 non-active hours to 

inactive and off modes for room air 

conditioners. In addition, for the same 

reasons as discussed for delay start and 

cycle finished modes for clothes dryers, 

DOE stated in the June 2010 TP SNOPR 

that the delay start and off-cycle hours 

for room air conditioners should be 

allocated to inactive and off modes even 

though it has determined that delay start 

and off-cycle modes are not standby 

modes. 75 FR 37594, 37610–11 (June 29, 

2010). 

The California Utilities/NRDC 

supported DOE’s proposed calculation 

method for standby mode and off mode 

annual hours for room air conditioners. 

They added that lacking new data on 

typical room air conditioner operation 

in standby and off modes, DOE’s 

proposed method of allocating hours to 

standby and off modes is appropriate. 

(California Utilities/NRDC, No. 33 at p. 

3) 

The Joint Efficiency Advocates 

Comment and ACEEE both commented 

that the 705 fan-only mode hours 

presented in the June 2010 TP SNOPR 

should be accounted for in the energy 

consumption calculations. (Joint 

Efficiency Advocates Comment, No. 28 

at pp. 2–3; ACEEE, Public Meeting 

Transcript, No. 20 at pp. 73–74) The 

Joint Efficiency Advocates Comment 

stated that fan-only active mode could 

be tested by duplicating the existing 

cooling-mode test method with the 

exception of running the compressor. 

The Joint Efficiency Advocates 

Comment further stated that there is no 

data to support the assumption that 

consumers generally run their room air 

conditioners in fan-only mode for 705 

hours a year. Although the Joint 

Efficiency Advocates cannot find any 

data on the number of hours typically 

used in fan-only mode, they commented 

that the lack of data indicates that this 

mode is not used as commonly as 

assumed in the June 2010 TP SNOPR. 

The Joint Efficiency Advocates 

Comment stated that because of DOE’s 

allocation, their second 

recommendation is that the 705 hours 

be reallocated in such a way as to 

represent the current consumer usage of 

fan-only mode. The Joint Efficiency 

Advocates Comment also noted that due 

to the lack of data on the use of this 

mode, DOE should perform additional 

research and data collection. If no data 

collection is able to be performed, DOE 

should reallocate these hours to active 

cooling and/or inactive modes, which 

would reflect the lack of data supporting 

the average consumer use of any fanonly mode. (Joint Efficiency Advocates 

Comment, No. 28 at pp. 2–3) 

The California Utilities/NRDC stated 

that fan-only operation should be 

included in active mode, but that it is 

not clear whether fan-only mode is 

accounted for in the proposed active 

mode test procedure. The California 

Utilities/NRDC stated that if fan-only 

mode is considered a portion of active 

mode, and if energy use in fan-only 

mode is measured in the current test 

procedure, then the number of hours in 

active mode should be revised to 

include fan-only mode. The California 

Utilities/NRDC stated that if fan-only 

mode is considered separate from active 

mode, and DOE allocates a portion of 

yearly hours to fan-only mode, then 

DOE must account for the energy use in 

this mode and incorporate it into its 


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calculation of CEER. The California 

Utilities/NRDC requested that DOE 

clarify its approach towards fan-only 

mode, provide a test procedure to 

measure or otherwise account for fanonly energy use, and incorporate the 

energy use of this mode in the CEER. 

(California Utilities/NRDC, No. 33, at 

pp. 3–4) 

Earth Justice (EJ) commented that not 

measuring energy consumption when 

operating in fan-only mode would 

violate EPCA’s minimum standards for 

test procedures (42 U.S.C. § 6293(b)(3)) 

EJ commented that by proposing to 

ignore energy consumption in fan-only 

mode, DOE has proposed to ignore 

nearly half the active mode operating 

hours of room air conditioner units. EJ 

added that because fan-only mode 

accounts for such a large percentage of 

total active mode operating hours, a test 

procedure that ignores fan-only 

operation would not depict ‘‘a 

representative average use cycle or 

period of use’’ for room air conditioners. 

(EJ, No. FDMS D0039 at p. 2) 

DOE understands that a fan-only 

active mode could include two different 

kinds of modes: (1) A mode in which 

the room air conditioner does not turn 

off the fan when the thermostat 

automatically cycles the compressor off 

during cooling mode; and (2) a userselected ‘‘ventilation’’ mode that does 

not include the cooling. DOE recognizes 

that the energy use associated with fanonly mode is not insignificant. As noted 

in the December 2008 TP NOPR, 

however, DOE is not aware of any 

reliable consumer usage data for hours 

spent in different room air conditioner 

modes, including fan-only mode. 73 FR 

74639, 74648 (December 9, 2008). DOE 

requested data in the December 2008 TP 

NOPR on the estimate of hours for 

different room air conditioner modes, 

but did not receive any such data. DOE 

notes that developing a test procedure to 

accurately measure the contribution of 

fan-only active mode would require 

additional testing and analysis to 

determine appropriate testing 

conditions and measurement methods 

for both types of fan-only modes 

described above. In addition, field use 

surveys of consumer usage patterns over 

multiple cooling seasons and a climatebased load analysis to develop an 

estimate of fan-only mode hours that is 

representative of consumer use would 

need to be conducted. DOE may 

consider amendments to address fanonly active mode in a future rulemaking 

as data becomes available. DOE 

welcomes information on appropriate 

testing procedures for accurately 

measuring fan-only active mode and 

data on consumer usage habits. 

Typically, room air conditioners with 

remote control can be controlled 

whenever they are plugged in; hence, 

these units do not have provision for an 

off mode in addition to inactive mode. 

However, if a room air conditioner 

allows the user to switch off remote 

control operation, such a product would 

be capable of both off and inactive 

modes. DOE notes that information to 

guide allocation of the hours for room 

air conditioners that have both inactive 

and off modes is currently unavailable. 

For these units, DOE proposed in the 

December 2008 TP NOPR that the off/ 

inactive hours be allocated equally to 

the off and inactive modes for such a 

product. Otherwise, for units that are 

capable of operation in only off or 

inactive mode, DOE proposed that all of 

the hours be allocated to the appropriate 

mode. 73 FR 74649. In the absence of 

comments on or additional data 

regarding allocation of hours, the June 

2010 TP SNOPR did not affect DOE’s 

proposal in the December 2008 TP 

NOPR for the allocation of hours 

between inactive mode and off mode. 75 

FR 37594, 37611 (June 29, 2010). 

Similar to the comment noted above 

for clothes dryers, the Joint Efficiency 

Advocates Comment suggested that DOE 

conduct research to determine how 

consumers allocate inactive and off 

mode hours for room air conditioners. 

The Joint Efficiency Advocates 

Comment stated they are concerned that 

off-mode usage may be affected by the 

mode’s ‘‘user-friendliness,’’ but that this 

is not accounted for in the current test 

procedure. (Joint Efficiency Advocates 

Comment, No. 28 at p. 3) 

DOE requested consumer usage data 

on the split of hours between inactive 

mode and off mode if both modes are 

possible for a product but did not 

receive any data. In the absence of data 

indicating that an equal split of hours is 

not representative of consumer usage 

habits, DOE adopts in today’s final rule 

the allocation of inactive/off mode 

hours proposed in the June 2010 TP 

SNOPR. The number of hours will be 

allocated equally to the inactive and off 

modes for a product capable of both 

modes. If data are made available 

indicating a different number of hours 

spent in inactive and off modes, DOE 

may consider amending the test 

procedure. 

In summary, DOE amends the room 

air conditioner test procedure in today’s 

final rule to calculate room air 

conditioner annual energy use 

associated with inactive and off modes 

by: (1) Calculating the products of 

wattage and allocated hours for inactive 

and off modes, depending on which of 

these modes is possible; (2) summing 

the results; and (3) dividing the sum by 

1,000 to convert from Wh to kWh. The 

5,115 hours for off/inactive modes shall 

be allocated entirely to either off mode 

or inactive mode, as appropriate, if only 

one of these modes is possible for the 

room air conditioner. If both modes are 

possible, the hours shall be allocated to 

each mode equally as discussed in this 

section, and each shall be allocated 

2,557.5 hours. 

5. Measures of Energy Consumption 

The DOE test procedures for clothes 

dryers and room air conditioners 

currently provide for the calculation of 

several measures of energy 

consumption. For clothes dryers, the 

test procedure incorporates various 

measures of per-cycle energy 

consumption, including: (1) Total percycle electric dryer energy 

consumption; (2) per-cycle gas dryer 

electrical energy consumption; (3) percycle gas dryer gas energy consumption; 

and (4) total per-cycle gas dryer energy 

consumption expressed, which includes 

both the electrical and gas energy 

consumption for gas clothes dryers. 10 

CFR part 430, subpart B, appendix D, 

sections 4.1–4.6 The test procedure also 

provides an EF, which is equal to the 

clothes load in pounds divided either by 

the total per-cycle electric dryer energy 

consumption or by the total per-cycle 

gas dryer energy consumption expressed 

in kWh. 10 CFR 430.23(d) For room air 

conditioners, the test procedure 

calculates annual energy consumption 

in kWh and an EER. 10 CFR 430.23(f) 

Under 42 U.S.C. 6295(gg)(2)(A), EPCA 

directs that the test procedures for all 

covered products be amended pursuant 

to section 323 to include standby mode 

and off mode energy consumption, with 

such energy consumption integrated 

into the overall energy efficiency, 

energy consumption, or other energy 

descriptor for each covered product, 

unless DOE determines that—(i) the 

current test procedures for a covered 

product already fully account for and 

incorporate the standby mode and off 

mode energy consumption of the 

covered product; or (ii) such an 

integrated test procedure is technically 

infeasible for a particular covered 

product, in which case DOE must 

prescribe a separate standby mode and 

off mode energy-use test procedure for 

the covered product, if technically 

feasible. 

In the December 2008 TP NOPR, DOE 

explored whether the existing measures 

of energy consumption for clothes 

dryers and room air conditioners can be 

combined with standby mode and off 

mode energy use to form a single metric. 

DOE tentatively determined in the 


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December 2008 TP NOPR that it is 

technically feasible to integrate standby 

mode and off mode energy consumption 

into the overall energy consumption 

metrics for clothes dryers and room air 

conditioners. 73 FR 74639, 74650 

(December 9, 2008). For the reasons 

presented in the December 2008 TP 

NOPR, DOE proposed integrated metrics 

addressing active, standby, and off 

modes for clothes dryers and room air 

conditioners, as discussed below. 

a. Clothes Dryers 

In the December 2008 TP NOPR, DOE 

proposed to establish the following 

measures of energy consumption for 

clothes dryers that integrate energy use 

of standby and off modes with active 

mode energy use of the products. ‘‘Percycle integrated total energy 

consumption expressed in kWh’’ would 

be defined as the sum of per-cycle 

standby and off mode energy 

consumption and either total per-cycle 

electric dryer energy consumption or 

total per-cycle gas dryer energy 

consumption expressed in kWh, 

depending on which type of clothes 

dryer is involved. ‘‘Integrated energy 

factor’’ (IEF) would be defined as the 

(clothes dryer test load weight in lb)/ 

(per-cycle integrated total energy in 

kWh). 73 FR 74639, 74650 (December 9, 

2008). 

b. Room Air Conditioners 

In the December 2008 TP NOPR, DOE 

proposed to establish the following 

measures of energy consumption for 

room air conditioners that integrate 

energy use of standby and off modes 

with active mode energy use of the 

products. ‘‘Integrated annual energy 

consumption’’ would be defined as the 

sum of annual energy consumption and 

standby and off mode energy 

consumption. ‘‘Integrated energy 

efficiency ratio’’ (IEER) would be 

defined as (cooling capacity in Btu/hr × 

750 hours average time in cooling 

mode)/(integrated annual energy 

consumption × 1,000 Wh per kWh). Id. 

DOE noted in the June 2010 TP 

SNOPR that the Air-Conditioning, 

Heating and Refrigeration Institute 

(AHRI) Standard 340/360–2007, 

‘‘Performance Rating of Commercial and 

Industrial Unitary Air-Conditioning and 

Heat Pump Equipment,’’ (AHRI 

Standard 340/360) and the ASHRAE 

Standard 90.1–2007, ‘‘Energy Standard 

for Buildings Except Low-Rise 

Residential Buildings,’’ (ASHRAE 90.1) 

both published in 2007, included an 

IEER metric. This metric, also named 

‘‘Integrated Energy Efficiency Ratio,’’ is 

meant to rate the part-load performance 

of the air-conditioning equipment under 

test. 75 FR 37594, 37612 (June 29, 2010). 

Manufacturers of the equipment covered 

by these standards currently list IEER 

ratings in their product literature and in 

the AHRI certified product directory. 

This IEER metric does not integrate 

standby mode and off mode energy use, 

unlike the IEER metric that was 

proposed in the December 2008 TP 

NOPR. The IEER metric used in AHRI 

Standard 340/360 and ASHRAE 90.1 

was established prior to the IEER 

proposed in this rulemaking. Therefore, 

DOE proposed for the June 2010 TP 

SNOPR to revise the name of the 

integrated metrics incorporating standby 

mode and off mode energy use to 

‘‘combined’’ metrics for both clothes 

dryers and room air conditioners. Id. 

DOE has received no comments 

objecting to this proposal. Therefore, for 

the reasons stated above, DOE 

incorporates into the DOE test 

procedures the ‘‘per-cycle combined 

total energy consumption expressed in 

kWh’’ and ‘‘combined energy factor’’ 

(CEF) for clothes dryers and ‘‘combined 

annual energy consumption’’ and 

‘‘combined energy efficiency ratio’’ 

(CEER) for room air conditioners in 

today’s final rule as proposed in the 

June 2010 TP SNOPR. Id. 

In the June 2010 TP SNOPR, DOE did 

not propose to amend the annual energy 

cost calculations in 10 CFR 430.23 for 

clothes dryers and room air conditioners 

to include the cost of energy consumed 

in standby and off modes. The Joint 

Efficiency Advocates Comment stated 

that DOE should include standby and 

off mode energy costs in the annual 

energy cost calculation in order to better 

represent actual energy costs. The Joint 

Efficiency Advocates Comment noted 

that minimum and maximum energy 

costs prescribed for the EnergyGuide 

label will need to be revised when new 

energy conservation standards go into 

effect. They suggested that the energy 

consumed in standby and off modes 

should be able to be incorporated into 

the revised minimum and maximum 

energy costs. (Joint Efficiency Advocates 

Comment, No. 28 at p. 4) 

EPCA states that any amended test 

procedures shall be reasonably designed 

to produce test results that measure 

energy efficiency, energy use, water use, 

or estimated annual operating cost of a 

covered product. (42 U.S.C. 6293(b)(3)) 

EPCA also directs DOE to amend its test 

procedures to include measures of 

standby mode and off mode energy 

consumption and to integrate such 

energy consumption into a single energy 

descriptor for that product. If that is 

technically infeasible, DOE must 

prescribe a separate standby mode and 

off mode energy-use test procedure, if 

technically feasible. (42 U.S.C. 

6295(gg)(2)(A)) As discussed in section 

I, EPCA requires that all representations 

related to standby mode and off mode 

energy use or efficiency or cost of 

energy consumed of both clothes dryers 

and room air conditioners made 180 

days after today’s final rule be based 

upon the standby and off mode 

requirements of the amended test 

procedures. (42 U.S.C. 6293(c)(2)) 

Additionally, EPCA requires that any 

revisions to the labels for room air 

conditioners include disclosure of the 

estimated annual operating cost 

(determined in accordance with DOE’s 

test procedures prescribed under section 

6293 of EPCA), unless the Secretary 

determines that disclosure of estimated 

annual operating cost is not 

technologically feasible, or the FTC 

determines that such disclosure is not 

likely to assist consumers in making 

purchasing decisions or is not 

economically feasible. (42 U.S.C. 

6294(c)(1)) DOE understands that the 

FTC would develop any revised labeling 

requirements for referencing a revised 

annual energy cost calculation that 

integrates the cost of energy consumed 

in standby and off modes. 

For these reasons, DOE agrees with 

interested parties that the annual energy 

cost calculations in 10 CFR 430.23 for 

clothes dryers and room air conditioners 

should be amended to include the cost 

of energy consumed in standby and off 

modes. Therefore, DOE amends the 

clothes dryer test procedure to revise 

the estimated annual operating cost 

calculation to integrate standby and off 

mode energy use, and to require that the 

estimated annual operating cost be 

obtained by multiplying the average 

number of annual use cycles by the sum 

of the per-cycle active mode energy 

consumption and the per-cycle standby 

and off mode energy consumption and 

by the representative average unit cost 

of electrical energy, natural gas, or 

propane, as appropriate, in dollars per 

kWh or Btu, as provided by DOE. 

Similarly, DOE amends the room air 

conditioner test procedure to revise the 

annual energy cost calculation to 

integrate standby and off mode energy 

use, and to require that the annual 

energy cost be obtained by multiplying 

the combined annual energy 

consumption by the representative 

average unit cost of electrical energy in 

dollars per kWh, as provided by DOE. 


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22EN Standard 61121 is used by European Union 

(EU) member countries. DOE believes this test 

standard is functionally equivalent to IEC Standard 

61121, which is used by China, among other 

countries. Both test procedures contain identical 

testing methods and procedures. 

C. Clothes Dryer and Room Air 

Conditioner Active Mode Test 

Procedures 

1. Correction of Text Describing Energy 

Factor Calculation for Clothes Dryers 

DOE proposed in the December 2008 

TP NOPR to correct errors in specific 

references used in the current DOE test 

procedure. 73 FR 74639, 74650 

(December 9, 2008). In particular, the 

reference to sections 2.6.1 and 2.6.2 of 

10 CFR part 430, subpart B, appendix D 

in the calculation of EF for clothes 

dryers found at section 430.23(d)(2) 

should refer instead to sections 2.7.1 

and 2.7.2. Section 2.6 provides 

instructions for the test clothes to be 

used in energy testing of clothes dryers, 

whereas section 2.7 provides 

instructions on test loads. The EF of 

clothes dryers is measured in lb of 

clothes per kWh. Because the EF 

calculation requires the weight of the 

test load, DOE proposed in the 

December 2008 TP NOPR to correct 

these references in 10 CFR 430.23(d)(2). 

DOE did not receive any comments 

opposing this correction. Therefore, for 

the reasons stated above, DOE adopts 

the correction as proposed in the 

December 2008 TP NOPR. 

2. Automatic Cycle Termination for 

Clothes Dryers 

DOE considered amendments to the 

clothes dryer test procedure to 

accurately measure the benefits of 

automatic cycle termination. DOE 

considered industry and international 

clothes dryer test procedures and 

conducted testing and analysis to 

develop proposed amendments to the 

definitions of product types, test load 

preparation, the test measurement cycle 

and settings, and the calculation of 

results. 

October 2007 Framework Document 

In the October 2007 Framework 

Document, DOE stated that it believes 

that the clothes dryer test procedure 

may not adequately measure the 

benefits of automatic cycle termination, 

in which a sensor monitors either the 

exhaust air temperature or moisture in 

the drum to determine the length of the 

drying cycle. (Framework Document, 

STD No. 1 at p. 5) The calculation of EF 

in the current clothes dryer test includes 

a field use scaling factor applied to the 

per-cycle drying energy consumption to 

account for the over-drying energy 

consumption associated with different 

termination technologies. Gas or electric 

clothes dryers with time termination 

control (in other words, those clothes 

dryers equipped with only a timer to 

determine the end of a drying cycle) are 

assigned an field use of 1.18. Clothes 

dryers with automatic termination are 

assigned an field use of 1.04. DOE 

established the 1.18 field use factor for 

clothes dryers with time termination 

control in the September 1977 TP Final 

Rule based on analysis of data from a 

field use survey conducted by 

Oklahoma Gas and Electric Company 

involving 64 homes as well as data 

provided by AHAM on the measured 

energy consumption per-cycle under the 

DOE test procedure to account for the 

differences between the energy 

consumption measurements derived 

from laboratory test procedures and 

those obtained from actual consumer 

use. 42 FR 46145, 46146 (September 14, 

1977). DOE established the field use 

factor of 1.04 for clothes dryers with 

automatic termination in the May 1981 

TP Final Rule based on analysis of data 

from a field use survey conducted by 

AHAM involving 72 homes as well as 

an analysis conducted by NIST of field 

test data on automatic termination 

control dryers. Analysis of this data 

showed that clothes dryers equipped 

with an automatic cycle termination 

feature consume less energy than timer 

dryers by reducing over-drying. 46 FR 

27324 (May 19, 1981). Based on these 

field use factors, clothes dryers with 

automatic cycle termination control are 

determined to reduce energy 

consumption by 12 percent compared to 

a similar clothes dryer with time 

termination control, which consume 

more energy due to over- or underdrying. (Under-drying can result in 

consumers running an additional drying 

cycle.) Currently, the test procedure 

specifies a single field use factor for 

clothes dryers equipped with automatic 

termination. However, it does not 

distinguish between the type of sensing 

control system (for example, 

temperature-sensing or moisture-sensing 

controls) and the sophistication and 

accuracy of the control system. 

Consideration of Industry and 

International Clothes Dryer Test 

Procedures 

DOE proposed in the June 2010 TP 

SNOPR that the benefit of automatic 

cycle termination should be accurately 

measured to account for any over- or 

under-drying. Therefore, DOE 

considered potential amendments to the 

DOE test procedure to account for 

automatic cycle termination. For the 

June 2010 TP SNOPR, DOE investigated 

industry and international clothes dryer 

test procedures for measuring the 

effectiveness of automatic cycle 

termination and conducted limited 

testing to analyze over-drying energy 

consumption and the applicability of 

such procedures to the DOE clothes 

dryer test procedure. 75 FR 37594, 

37613 (June 29, 2010). DOE reviewed 

AHAM’s most recently update to its 

industry test standard, AHAM HLD–1– 

2009, ‘‘Household Tumble Type Clothes 

Dryers’’ (AHAM Standard HLD–1–2009). 

The update contains provisions for 

measuring the over-drying energy 

consumption for clothes dryers that use 

automatic cycle termination and 

provides separate testing procedures 

timer dryers. DOE also reviewed the 

international test standards EN Standard 

61121 22 and AS/NZS Standard 2442.1, 

both of which address methods for 

testing clothes dryers with automatic 

termination sensor technologies. 75 FR 

37594, 37613 (June 29, 2010). 

DOE stated in the June 2010 TP 

SNOPR that it believes that AHAM 

Standard HLD–1–2009 does not provide 

an appropriate method for comparing 

the amount of over-drying for a timer 

dryer to that of an automatic 

termination-sensing dryer. This is 

because the timer dryer test allows only 

for drying the test load to as low as 

4-percent RMC, whereas the automatic 

cycle termination test allows for drying 

the test load to any value below 

6-percent RMC, including lower than 

4-percent RMC. 75 FR 37613–14. If the 

automatic termination control dryer 

were to dry the test load to a value 

lower than 4-percent, the measured 

energy consumption may be greater than 

the energy consumption measured for 

the same clothes dryer using the timer 

dryer test cycle which only measures 

the energy required to dry the load to 

4-percent RMC. However, as discussed 

above in this section, DOE believes that 

automatic termination control dryers 

reduce energy consumption compared 

to timer dryers based on analysis of data 

from the AHAM field use survey and 

analysis of field test data conducted by 

NIST. 46 FR 27324 (May 19, 1981). 

DOE also stated in the June 2010 

NOPR that although EN Standard 61121 

provides test methods to use for both 

timer dryers and automatic termination 

control dryers, it does not provide any 

methodology to measure the energy 

consumed over- or under-drying the test 

load beyond a certain RMC for each type 

of clothes dryer. The provisions in EN 

Standard 61121 require the test load be 

dried to the same allowable range for 

both timer dryers and automatic 

termination dryers. According to the test 

procedures in EN Standard 61121, if the 


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test load for either a timer dryer or an 

automatic termination control dryer is 

dried to the same RMC, the clothes 

dryers consume the same amount of 

energy and would be rated as using the 

same amount of energy in real-world 

use. 75 FR 37594, 37614 (June 29, 2010). 

However, for the same reasons 

discussed above in this section, DOE 

believes that automatic termination 

control dryers reduce energy 

consumption compared to timer dryers. 

DOE stated in the June 2010 TP 

SNOPR that AS/NZS Standard 2442 

provides testing methods and 

procedures that account for the amount 

of over-drying beyond a specified RMC 

associated with automatic termination 

control dryers by measuring any 

additional energy consumed drying the 

test load beyond the specified RMC. 

DOE also stated that AS/NZS Standard 

2442 effectively takes into consideration 

the accuracy of different automatic 

termination sensor technologies by not 

providing a fixed field use factor in the 

energy consumption calculation for 

automatic cycle termination. Because 

the test procedure measures the energy 

consumed drying the test load beyond 

the specified RMC, a clothes dryer with 

an accurate automatic termination 

sensor technology that dries the clothes 

load to close to the specified RMC 

would consume less energy than a 

clothes dryer with a sensor technology 

that dries the load well beyond the 

specified RMC (that is, close to bone 

dry). DOE also stated that it believes 

that the testing methods provide an 

accurate and representative method for 

comparing the energy consumption 

between timer dryers and automatic 

termination control dryers by providing 

methods for measuring energy use that 

account for over-drying for both types of 

clothes dryers. For these reasons, DOE 

proposed to amend the DOE test 

procedure for clothes dryers to 

incorporate the individual test 

procedures for timer dryers and 

automatic termination control dryers in 

AS/NZS Standard 2442, with 

modifications as appropriate for the 

DOE test procedure. 75 FR 37594, 37615 

(June 29, 2010). 

After the June 2010 TP SNOPR was 

published, AHAM, ACEEE, NRDC, 

Alliance to Save Energy (ASE), Alliance 

for Water Efficiency (AWE), ASAP, 

Northwest Power and Conservation 

Council (NPCC), Northeast Energy 

Efficiency Partnerships (NEEP), 

Consumer Federation of America (CFA), 

and National Consumer Law Center 

(NCLC) (hereafter the ‘‘Joint Petitioners’’) 

jointly submitted the ‘‘Agreement on 

Minimum Federal Efficiency Standards, 

Smart Appliances, Federal Incentives 

and Related Matters for Specified 

Appliances,’’ (Joint Petitioners, No. 25, 

hereinafter the ‘‘Joint Petition’’) and the 

‘‘Joint Stakeholders Comments On The 

Supplementary Notice Of Proposed 

Rulemaking On Test Procedures For 

Clothes Dryers And Room Air 

Conditioners’’ (Joint Petitioners, No. 30). 

The Joint Petitioners, AHAM, the Joint 

Efficiency Advocates Comment, and the 

California Utilities/NRDC supported 

DOE’s proposal to account for the 

effectiveness of automatic termination 

controls. (Joint Petitioners, No. 25 at p. 

14; Joint Petitioners, No. 30 at p. 5; 

AHAM, No. 31 at p. 5; Joint Efficiency 

Advocates Comment, No. 28 at p. 1; 

California Utilities/NRDC, No. 33 at p. 

4) The Consumers Union (CU) 

concurred with this comment. (CU, No. 

29 at pp. 1–2, 3) The Joint Efficiency 

Advocates Comment added that data 

presented by DOE show that over-drying 

energy consumption can be significant 

(as much as 0.6 kWh per cycle). (Joint 

Efficiency Advocates Comment, No. 28 

at p. 1; California Utilities/NRDC, No. 

33 at p. 4) The Joint Petitioners and 

AHAM commented that if DOE decides 

to adopt the AS/NZS Standard 2442 as 

proposed, they request that DOE 

identify the specific sections it is 

adopting. (Joint Petitioners, No. 30 at p. 

6; AHAM, No. 31 at p. 6) 

Product Definitions 

Based on the definitions in EN 

Standard 61121 and AS/NZS Standard 

2442, DOE proposed in the June 2010 

TP SNOPR to define ‘‘timer dryer’’ as ‘‘a 

dryer which can be preset to carry out 

at least one sequence of operations to be 

terminated by a timer, but may also be 

manually controlled.’’ It also proposed 

to define ‘‘automatic termination control 

dryer’’ as ‘‘a dryer which can be preset 

to carry out at least one sequence of 

operations to be terminated by means of 

a system assessing, directly or 

indirectly, the moisture content of the 

load. An automatic termination control 

dryer with supplementary timer shall be 

tested as an automatic termination 

control dryer.’’ 75 FR 37594, 37615 (June 

29, 2010). 

AHAM suggested that the definition 

of a timer dryer may need to specify that 

it is a clothes dryer that ‘‘does not 

include any automatic termination 

function.’’ AHAM commented that 

almost any automatic termination dryer 

is also going to have a timer function 

because of consumer demands, and this 

extra explanation would make it clear 

that it refers to only a timer dryer. 

(AHAM, Public Meeting Transcript, No. 

20 at pp. 84, 85–86) AHAM also 

commented that the last sentence of the 

automatic termination dryer definition 

should be modified and used to clarify 

the timer dryer definition. (AHAM, 

Public Meeting Transcript, No. 20 at p. 

86) ALS also commented that it offers a 

product with both an automatic 

termination function and a timer 

function that uses only 

electromechanical controls. (ALS, 

Public Meeting Transcript, No. 20 at p. 

81) 

As discussed later in this section, 

DOE is not adopting in today’s final rule 

the amendments for automatic cycle 

termination proposed in the June 2010 

TP SNOPR. Therefore it is not adopting 

the definitions for timer dryer and 

automatic termination dryer presented 

above. DOE agrees, however, that the 

reference to timer dryers in the test 

procedure (in the application of field 

use factors in section 4, ‘‘Calculation of 

Derived Results From Test 

Measurements’’) should clarify that 

clothes dryers with time termination 

control systems do not include any 

automatic termination control functions. 

DOE also believes the reference to 

clothes dryers with automatic control 

systems in the application of the field 

use factors should clarify that clothes 

dryers with automatic control systems 

that also have a supplementary timer 

control receive the 1.04 field use factor. 

For these reasons, DOE amends section 

4 of the clothes dryer test procedure to 

specify that the field use factor equals 

1.18 for clothes dryers with time 

termination control systems only, 

without any automatic termination 

control functions and 1.04 for clothes 

dryers with automatic control systems 

that meet the requirements of the 

definition for automatic control systems 

in 1.4, 1.14 and 1.18, including those 

that also have a supplementary timer 

control. 

The Joint Petitioners and AHAM also 

commented that DOE should revise 

section 1.11 of 10 CFR 430 subpart B, 

appendix D. The amendment would 

more clearly account for electronic 

controls by specifying that a preferred 

automatic termination control setting 

(that is, a setting recommended by 

manufacturers) can also be indicated by 

a visual indicator (in addition to the 

mark or detent), and would read ‘‘* * * 

mark, visual indicator or detent which 

indicates a preferred * * *’’ (Joint 

Petitioners, No. 25 at p. 14; Joint 

Petitioners, No. 30 at p. 8; AHAM, No. 

31 at p. 11) DOE agrees a clarification 

should be added to the definition of 

‘‘automatic termination control’’ that a 

mark, detent, or other visual indicator 

which indicates a preferred automatic 

termination control setting must be 

present if the dryer is to be classified as 

having an automatic termination 


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23 KEMA, Inc. 2009 California Residential 

Appliance Saturation Study. 2010. California 

Energy Commission; Sacramento, CA. Publication 

number: CEC–200–2010–004–ES. For more 

information visit: http://www.energy.ca.gov/ 

appliances/rass/. 

control. Therefore, DOE amends this 

definition in today’s final rule to make 

this revision. 

NRDC commented that most new 

clothes dryers have both automatic and 

timer termination functions, so the test 

procedure should test both of these 

drying modes rather than only the 

automatic termination mode. (NRDC, 

Public Meeting Transcript, No. 20 at pp. 

86–87) The Joint Petitioners and AHAM 

commented that for clothes dryers that 

have both an automatic termination 

control cycle and a timer cycle, only the 

auto-termination cycle should be tested. 

(Joint Petitioners, No. 30 at p. 6; AHAM, 

No. 31 at p. 5) Whirlpool commented 

that testing the automatic termination 

control cycle is most appropriate, as it 

represents the vast majority of actual 

consumer use. Although the majority of 

consumers also want a timed dry cycle, 

they use it only about 10 percent of the 

time. (Whirlpool, No. 27 at p. 3) DOE is 

not aware of any consumer usage data 

indicating that timed dry cycles on a 

clothes dryer with automatic 

termination controls are used by 

consumers for a significant portion of 

their annual use cycles. In addition, as 

discussed below, DOE is not adopting in 

today’s final rule the amendments to 

better account for automatic cycle 

termination proposed in the June 2010 

TP SNOPR. For these reasons, DOE is 

not amending the test procedure to 

measure both automatic termination 

control and timed dry cycles for 

products capable of both methods. 

Test Load Preparation 

In the June 2010 TP SNOPR, DOE 

proposed to amend sections 2.7.1, 

‘‘Compact size dryer load,’’ and 2.7.2, 

‘‘Standard size dryer load’’ of the DOE 

test procedure for clothes dryers, which 

contain provisions for test load 

preparation. The amendment would add 

at the end of both sections the following 

requirement: ‘‘Make a final mass 

adjustment, such that the moisture 

content is 47 percent ± 0.33 percent by 

adding water uniformly to the load in a 

very fine spray.’’ 75 FR 37594, 37615 

(June 29, 2010). The ± 0.33 percent 

allowable RMC range is equivalent to 

the allowable range specified in AS/ 

NZS Standard 2442.1 (190 percent 

± 0.02 kg of the bone dry weight) for a 

7-lb test load. DOE believes the 

specified range produces repeatable EF 

measurements. Allowing a larger 

allowable range in RMC would increase 

the range in the moisture required to be 

dried during the test cycle and result in 

increased variability in the measured 

EF. DOE also proposed that the 

procedure for dampening and extracting 

water from the test load specified in the 

current test procedure be changed. The 

test procedure would be changed to 

require that the moisture content of the 

test load be between 42 and 47 percent 

of the bone-dry weight of the test load, 

and would serve as an initial 

preparation step prior to the final mass 

adjustments to obtain a test load with an 

RMC of 47 percent proposed above in 

this paragraph. DOE noted that it 

proposed to use a nominal initial RMC 

of 47 percent based on the proposed 

amendment to change the initial RMC 

from 70 percent to 47 percent, as 

discussed in section III.C.5.b. DOE 

noted in the June 2010 TP SNOPR that 

if it does not adopt this proposed 

amendment to change the nominal 

initial RMC, it would instead propose 

an amendment stating to first prepare 

the test load to 65- to 70-percent RMC 

and make adjustments to the moisture 

content to get 70-percent ± 0.33-percent 

initial RMC. 75 FR 37594, 37615 (June 

29, 2010). DOE did not receive any 

comments on this alternate proposal. 

In the June 2010 TP SNOPR, DOE 

noted that section 2.7 of the existing 

clothes dryer test procedure regarding 

test load preparation requires that the 

test load be agitated in water whose 

temperature is 100 ° F ± 5 ° F. DOE 

recognizes that some residential clothes 

washers may use a default cold rinse 

cycle at the end of the wash cycle, 

which sections 2.6.1.2.1 and 2.6.3.1 of 

the current DOE clothes washer test 

procedure specify to be 60 ° F ± 5 ° F. 

DOE stated in the June 2010 TP SNOPR 

that it does not have any data indicating 

whether a different water temperature 

for clothes dryer test load preparation 

would be more representative of current 

consumer usage habits, but that if 

consumer usage data is made available 

that indicates a 60 ° F ± 5° F water 

temperature is more representative of 

consumer usage, DOE may adopt an 

alternate approach specifying a 60 ° F 

± 5 ° F water temperature for test load 

preparation in section 2.7 of the DOE 

clothes dryer test procedure. In 

addition, DOE stated that it is unaware 

of how changes to the water temperature 

for clothes dryer test load preparation 

would affect the measured efficiency as 

compared to the existing test procedure. 

Id. 

ALS, the California Utilities/NRDC, 

and the Joint Efficiency Advocates 

Comment all stated that the water 

temperature for clothes dryer test load 

preparation should be changed to be 

representative of existing national 

consumer usage. (ALS, No. 24 at p. 4; 

California Utilities/NRDC, No. 33 at p. 

5; Joint Efficiency Advocates Comment, 

No. 28 at pp. 1–2) 

ALS commented that the water 

temperature for clothes dryer test load 

preparation has been lowered in 

response to clothes washer energy 

conservation standard changes. 

Manufacturers have eliminated most 

warm rinses and offer the user the 

option of using all cold rinses. ALS 

stated that it is reasonable to assume 

that today, most clothes loads placed in 

a clothes dryer are from clothes washers 

that use cold rinse. Therefore, ALS 

supported revising the clothes dryer test 

procedure to utilize the 60 ° F ± 5 ° F 

water temperature specified in the DOE 

clothes washer test procedure for the 

cold water supply for the preparation of 

the clothes dryer test load. (ALS, No. 24 

at p. 4; ALS, Public Meeting Transcript, 

No. 20 at p. 91) 

The California Utilities/NRDC also 

stated that lower rinse temperatures 

may be more representative of consumer 

habits based on both anecdotal evidence 

and consumer data. The California 

Utilities/NRDC stated that 2003 

California Residential Appliance 

Saturation Survey (RASS) 23 provides 

data on general consumer preferences 

on cold, warm, and hot wash cycles (no 

data was available for rinse cycles). The 

data show there is a general trend 

among consumers to prefer warm and 

cold wash cycles over hot cycles. Data 

cited by the California Utilities/NRDC 

from the 2003 California RASS on this 

topic are presented in Table III.4. 

According to the California Utilities/ 

NRDC, although the data do not specify 

cycle temperatures or final rinse 

temperatures, the data may indicate a 

consumer preference for cooler wash 

and rinse cycles. The California 

Utilities/NRDC also stated that a 60 ° F 

± 5 ° F preparation temperature would 

be better aligned and harmonize with 

the cool rinse temperature specified by 

the clothes washer test procedure. 

(California Utilities/NRDC, No. 33 at pp. 

5–6) 


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TABLE III.4—2003 CALIFORNIA RASS SURVEY DATA ON CLOTHES WASHER CYCLE SELECTIONS (PROVIDED IN

COMMENTS BY THE CALIFORNIA UTILITIES/NRDC) 

Cold wash 

cycles 

Warm wash 

cycles 

Hot wash 

cycles 

Cycles per Week (weighted average) ................................................................................... 1 .80 2 .32 0 .94 

Cycles per Year (weighted average) ..................................................................................... 93 .7 120 .8 49 .0 

Percent of Cycles Chosen ..................................................................................................... 36 46 19 

The Joint Efficiency Advocates 

Comment stated that the 2005 RECS 

gathered information about the rinse 

water temperature that consumers 

usually use. The Joint Efficiency 

Advocates Comment noted that, of 

respondents that used a clothes washer 

in their home, 78.5 percent said they 

used cold water for the rinse cycle. The 

Joint Efficiency Advocates Comment 

also noted that in the current clothes 

washer test procedure, temperature use 

factors indicate that warm rinse is 

assumed to be used only 27 percent of 

the time. The Joint Efficiency Advocates 

Comment stated that anecdotal evidence 

shows that that some clothes washers 

are now being manufactured without a 

warm rinse option. In addition, 

detergent manufacturers support 

consumers’ increasing use of cold wash 

and cold rinse temperatures, as 

evidenced by the recent introduction of 

detergents specifically optimized for 

these conditions. The Joint Efficiency 

Advocates Comment encouraged DOE to 

change the water temperature for test 

load preparation to reflect these 

consumer usage indicators. The Joint 

Efficiency Advocates Comment also 

stated that, at the very least, the test 

procedure should align with the 

temperatures used in the clothes washer 

test procedure. According to the Joint 

Efficiency Advocates Comment, the 

washer test procedure assumes that a 

cold rinse is used the majority of the 

time. Therefore, alignment could be 

achieved by requiring a cold rinse (60 °F 

± 5 °F) be used for the clothes dryer test 

load preparation. (Joint Efficiency 

Advocates Comment, No. 28 at pp. 1–2) 

Whirlpool commented that the 

current load temperature is well 

documented and well understood by 

manufacturers and independent test 

laboratories. Whirlpool stated that any 

migration to a different temperature 

would require time consuming ‘‘roundrobin’’ testing to determine the impact 

that such a new temperature would 

have on the EF calculation. Whirlpool 

commented that such testing is not 

compatible with DOE’s timeframe for 

this rulemaking nor would it add value 

proportional to the burden required to 

reformulate EF. (Whirlpool, No. 27 at 

pp. 2–3) 

ALS commented that it does not have 

any data quantifying what impact a 

different test load temperature would 

have on the clothes dryer efficiency test 

results. ALS stated it is reasonable to 

expect that a colder temperature test 

load being placed in a dryer will require 

additional energy to achieve 

evaporation for the moisture from the 

clothes. ALS suggested that DOE test 

existing clothes dryers to assess the 

impact of the load preparation water 

temperature change from 100 °F to 60 

°F. (ALS, No. 24 at p. 4; ALS; Public 

Meeting Transcript, No. 20 at p. 91) The 

Joint Efficiency Advocates Comment 

stated that the water temperature 

adjustment would likely have an effect 

on measured dryer energy use. This is 

because warmer rinse water, and hence 

higher initial load temperature, may 

result in faster drying times and lower 

energy use, especially if the dryer is 

equipped with moisture sensor 

technology. (Joint Efficiency Advocates 

Comment, No. 28 at p. 2) 

DOE analyzed 2005 RECS data on the 

rinse water temperatures selected by 

consumers for clothes washer cycles. 

The usage data for consumers that use 

a clothes washer in the home, presented 

below in Table III.5, shows that 80 

percent of wash cycles per year use a 

cold rinse. 

TABLE III.5—2005 RECS CONSUMER

USAGE DATA ON CLOTHES WASHER

RINSE CYCLES TEMPERATURE SELECTIONS

Average 

cycles per 

year 

Average 

usage factor 

Hot Rinse .......... 5 .176 0 .018 

Warm Rinse ...... 53 .638 0 .182 

Cold Rinse ........ 235 .711 0 .800 

Because the DOE clothes washer test 

procedure assumes a warm rinse 

temperature use factor of 27 percent, 

and the 2005 RECS data shows that 80 

percent of clothes washer cycles use 

cold water for the rinse cycle, DOE 

believes that the cold water rinse cycle 

is more representative of typical 

consumer use. (DOE also notes that it 

sought comment on the warm rinse 

temperature use factor in the recent 

proposal to amend the test procedure for 

residential clothes washers because it 

received consumer usage survey data 

from a manufacturer which indicate 

that, for one clothes washer model with 

no cold rinse option on the cycle 

recommended for cotton clothes and a 

default cold rinse on all other cycles, 

users participating in the survey 

reported using warm rinse for 1.6 

percent of all cycles. 75 FR 57556, 

57571 (Sept. 21, 2010)) For this reason, 

DOE amends the clothes dryer test 

procedure to change the water 

temperature for clothes dryer test load 

preparation to 60 °F ± 5 °F. 

DOE tested 13 representative clothes 

dryers to evaluate the repeatability and 

reproducibility of this amendment to 

the water temperature for clothes dryer 

test load preparation. DOE tested these 

units according to the current DOE 

clothes dryer test procedure, except that 

the water temperature for clothes dryer 

test load preparation was changed to 60° 

± 5 °F. For the ventless clothes dryer test 

units, DOE used the proposed testing 

method for ventless dryers presented in 

section III.C.3. As shown below in Table 

III.6, the test-to-test variation in 

measured EF with 60 °F ± 5 °F test load 

water temperature ranged from 0 

percent to 4.1 percent, with an average 

of 1.5 percent. Therefore, DOE believes 

that the amendments to the water 

temperature for clothes dryer test load 

preparation produce repeatable test 

results. 


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TABLE III.6—DOE REPEATABILITY TESTING FOR 60° ± 5 °F WATER TEMPERATURE FOR TEST LOAD PREPARATION

Test unit 

EF lb/kWh Test-to-test 

variation % Test 1 Test 2 Test 3 

Vented Electric Standard: 

Unit 1 .................................................................................................................. 3 .00 3 .00 3 .00 0 .0 

Unit 2 .................................................................................................................. 3 .01 3 .07 3 .06 2 .0 

Unit 3 .................................................................................................................. 3 .10 3 .10 3 .09 0 .3 

Unit 5 .................................................................................................................. 3 .18 3 .17 .................... 0 .3 

Unit 6 .................................................................................................................. 3 .04 2 .92 .................... 4 .1 

Vented Gas: 

Unit 7 .................................................................................................................. 2 .74 2 .70 .................... 1 .5 

Unit 9 .................................................................................................................. 2 .68 2 .61 .................... 2 .7 

Unit 10 ................................................................................................................ 2 .81 2 .73 .................... 2 .9 

Unit 11 ................................................................................................................ 2 .77 2 .78 2 .82 1 .8 

Vented Electric Compact (240V): 

Unit 12 ................................................................................................................ 2 .95 2 .94 .................... 0 .3 

Unit 13 ................................................................................................................ 2 .86 2 .84 2 .82 1 .4 

Ventless Electric Compact (240V): 

Unit 15 ................................................................................................................ 2 .22 2 .23 .................... 0 .5 

Ventless Electric Combo Washer-Dryer: 

Unit 16 ................................................................................................................ 1 .94 1 .98 1 .96 2 .1 

Test Cycle 

In the June 2010 TP SNOPR, DOE also 

proposed to amend section 3.3, ‘‘Test 

cycle,’’ in the DOE test procedure for 

clothes dryers to include testing 

procedures specific to timed dryers and 

dryers with automatic termination 

controls. 

For timer dryers, the clothes dryer 

would be operated at the maximum 

temperature setting and, if equipped 

with a timer, at the maximum time 

setting. The load would be dried to 

5–6 percent RMC without the dryer 

advancing into cool-down. The timer 

would be reset if necessary. If the load 

is not dried to within the specified 

range, the test would not be considered 

valid. The procedure would then be 

repeated, but instead the test load 

would be dried to 4–5 percent RMC. As 

discussed later in this section, DOE 

proposed to use the results from the two 

proposed tests cycles (corresponding to 

5–6 and 4–5 percent final RMCs) to 

interpolate the value of the per-cycle 

energy consumption required to dry the 

test load to exactly 5-percent RMC. 75 

FR 37594, 37615 (June 29, 2010). DOE 

requested comment in the June 2010 TP 

SNOPR on whether using the maximum 

temperature setting is representative of 

current consumer usage habits. DOE 

also requested comment on whether 

multiple temperature settings should be 

evaluated and averaged, and if so, how 

testing multiple temperature settings 

would affect the measured efficiency as 

compared to the existing DOE clothes 

dryer test procedure. That procedure 

measures the clothes dryer only at the 

maximum temperature setting. Id. 

AHAM stated that DOE should not 

adopt amendments to the temperature 

setting provisions in the current test 

procedure because there is no 

justification or evidence to support such 

a change. (AHAM, No. 31 at p. 6) 

Whirlpool commented that testing and 

averaging multiple cycles and settings, 

while perhaps more reflective of 

consumer behavior, would dramatically 

increase the test burden on 

manufacturers, and that the substantial 

increase in cost would not be justified 

by a better result. Whirlpool added that 

testing and averaging of multiple cycles 

and settings would introduce 

opportunities for error and 

circumvention while reducing 

repeatability and consistency. 

(Whirlpool, No. 27 at p. 3) ALS also 

supported setting the temperature at the 

‘‘maximum’’ temperature setting option 

available on the dryer. (ALS, No. 24 at 

p. 5) DOE agrees that the benefit of 

testing multiple temperature settings 

would be outweighed by the burden on 

manufacturers to test multiple settings. 

In addition, DOE agrees that including 

requirements to test multiple settings 

could potentially create problems with 

developing a consistent test procedure 

that covers all products. This is because 

various manufacturers offer different 

settings on their clothes dryers, and test 

technicians would be required to 

determine the appropriate settings for 

testing. For these reasons, DOE is not 

amending the test procedure in today’s 

final rule to require the testing of 

multiple temperature settings and 

averaging results. 

ALS stated that, for clothes dryers 

with only a timed dry cycle, the time 

should be set at the maximum setting. 

ALS commented that it has no data 

regarding what time setting consumers 

utilize most often. ALS believes, 

however, that consumers using a timed 

dry cycle tend to select a maximum 

amount of time to be assured that their 

load is dry at end of the cycle. (ALS, No. 

24 at p. 4) ALS also commented that the 

‘‘full time cycle including cool-down 

period’’ should be included for timer 

dryers as well as for automatic cycle 

termination dryers. According to ALS, 

the benefits for timer dryers are as 

follows: (1) Test accuracy is improved 

because it avoids the variability of 

technician judgment on when to stop 

the test; (2) burden is reduced on 

manufacturers and test labs, because no 

interpolation or test ‘‘re-run’’ is required; 

and (3) all the energy consumed in a 

dryer cycle is accounted for, and is 

representative of the manner in which 

consumers utilize the dryer in their 

homes. (ALS, No. 24 at p. 5) 

DOE does not have any data 

indicating that the maximum time 

setting would be most representative of 

consumer usage habits. In addition, 

some manufacturers offer a wide range 

of timed dry settings for different types 

of loads, and these may require varying 

periods to dry. Therefore, using the 

maximum time setting could result in 

energy consumption that may not be 

representative of consumer use. DOE 

also does not believe it would be 

appropriate to include the cool-down 

period as part of the time dry test cycle 

because the current clothes dryer test 

procedure requires a timed dry cycle 

using the maximum time setting and 

maximum temperature setting and 

drying the load to a specified RMC, at 

which point the test cycle is stopped. 

DOE believes that to specify a timed dry 

cycle that includes the cool-down 


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24Towards the end of an automatic termination 

cycle, a clothes dryer heater generally turns on and 

off multiple times to limit the amount of heat 

applied to the air entering the drum. 

period to achieve a target final RMC 

would add significant testing burden on 

test technicians to determine the 

appropriate time setting. It would also 

be very difficult to ensure that testing 

results are repeatable and reproducible 

because different timed dry cycle 

lengths, and thus different lengths of 

cool-down period, may be selected to 

dry a test load to the same final RMC. 

For these reasons, DOE is not amending 

the timed dry test cycle to include the 

cool-down period in today’s final rule. 

For dryers with automatic termination 

controls, as discussed in the June 2010 

TP SNOPR, DOE tested a representative 

gas clothes dryer to evaluate test 

methods for automatic termination 

control dryers as part of the energy 

conservation standards rulemaking 

preliminary analyses. DOE conducted 

this additional testing to determine the 

effects of proposed amendments that 

would require the selection of program 

settings that provide the maximum 

drying temperature and maximum 

dryness level (that is, lowest final RMC). 

Table III.7 below shows the results from 

this testing compared to the results of 

testing the same gas clothes dryer 

according to the current DOE test 

procedure. 75 FR 37594, 37615–16 (June 

29, 2010). 

TABLE III.7—DOE AUTOMATIC CYCLE TERMINATION TEST RESULTS

Initial RMC 

(%) Test Final RMC % 

Per-cycle energy 

consumption 

kWh 

70 ................................................ Automatic Cycle Termination ......................................................... 0.6 3.018 

Current DOE ................................................................................... * 3.3 * 2.462 

56 ................................................ Automatic Cycle Termination ......................................................... 0.6 2.559 

Current DOE ................................................................................... * 3.7 * 2.001 

47 ................................................ Automatic Cycle Termination ......................................................... 0.5 2.252 

Current DOE ................................................................................... * 3.4 * 1.754 

* Current DOE test procedure normalizes the per-cycle energy consumption equation to represent the energy consumption required to dry the 

test load to 4-percent RMC. In addition, the current DOE test procedure multiplies the per-cycle energy consumption by a fixed field-use factor of 

1.04 to account for energy consumption due to over-drying. 

DOE noted that for all of the test runs, 

using the maximum temperature and 

dryness level settings resulted in the test 

load being dried to near bone dry (0.4- 

percent to 0.7-percent RMC). Using the 

data of the estimated RMC of the test 

load measured continuously during the 

test cycle, DOE also observed that for all 

of the test runs, the estimated RMC of 

the test load was below 1 percent by the 

time the heater began cycling on/off.24

The increased amount of over-drying 

resulted in per-cycle energy 

consumption that was higher than the 

value obtained using the current DOE 

test procedure, which uses a fixed field 

use factor to account for over-drying 

energy consumption. DOE stated that 

different manufacturers may target 

different final RMCs for their highest 

dryness level setting. Based on analysis 

of the test results for this gas clothes 

dryer unit, DOE stated that the highest 

dryness level setting may be intended to 

dry the clothes load to near bone dry, 

beyond the target RMC of the DOE test 

procedure, and would not be 

appropriate for the proposed test cycle. 

For this reason, DOE did not propose 

that the highest dryness level be 

specified for the test cycle. DOE stated 

in the June 2010 TP SNOPR that a 

‘‘normal’’ drying program would be more 

representative of consumer usage habits 

and would more likely dry the clothes 

load to the target range specified in the 

DOE clothes dryer test procedure. 75 FR 

37616. 

Based on the results of this additional 

testing, DOE proposed in the June 2010 

TP SNOPR an approach in which, for 

automatic termination control dryers, a 

‘‘normal’’ program would be selected for 

the test cycle to be most representative 

of consumer usage. Where the drying 

temperature can be chosen 

independently of the program, it would 

be set to the maximum to provide a 

clear and consistent method. DOE notes 

that ‘‘medium’’ or ‘‘low’’ temperature 

settings may not be consistent among 

different manufacturers. When the 

heater switches off for the final time at 

the end of the drying cycle (that is, 

immediately before the cool-down 

period begins) the dryer would be 

stopped. If the final RMC is greater than 

5 percent, the tests would be invalid 

and a new run shall be conducted using 

the highest dryness level setting. Any 

test cycle in which the final RMC is 5 

percent or less would be considered 

valid. DOE also proposed that for 

automatic termination control dryers, 

the cycle setting selected for the test be 

recorded. This would include settings 

such as the drying mode, dryness level, 

and temperature level. DOE also 

requested comment on whether 

multiple cycles and settings should be 

tested and how the results from those 

multiple tests should be evaluated. Id. 

Bosch and Siemens Home Appliance 

Group (BSH) expressed concern over 

using the phrase ‘‘normal program’’ 

because no manufacturer offers a 

program called ‘‘normal,’’ and the term 

‘‘normal’’ is ambiguous. BSH added that 

it would be very difficult to achieve 

reproducibility from test lab to test lab. 

(BSH, Public Meeting Transcript, No. 20 

at pp. 93–94) AHAM agreed with BSH 

regarding the use of ‘‘normal’’ program, 

noting that clothes washers have 

transitioned from a normal cycle to 

specifying settings based on fabric type. 

(AHAM, Public Meeting Transcript, No. 

20 at pp. 94–95) AHAM also 

recommended that DOE contact 

manufacturers of dryer usage materials, 

such as fabric softeners, who may have 

some survey data regarding usage 

factors or the most commonly selected 

program to avoid the terminology of 

‘‘normal program.’’ (AHAM, Public 

Meeting Transcript, No. 20 at p. 95) ALS 

supported revising the ‘‘test cycle’’ 

definition to account for the fact that 

most dryers no longer utilize the term 

‘‘normal cycle’’ on their controls. ALS 

supported using the same test cycle 

definition the DOE clothes washer test 

procedure utilizes—‘‘the cycle 

recommended by the manufacturer for 

washing cotton or linen clothes’’—but 

modified to specify ‘‘for drying’’ instead 

of ‘‘for washing.’’ (ALS, No. 24 at p. 4) 

ALS commented that it supports 

testing only one cycle (the cycle 

recommended by the manufacturer for 

drying cotton and linen clothes) for the 

following reasons: (1) Manufacturers 

provide other cycles for consumers, but 

many of these other cycles are used 

infrequently because consumers tend to 

utilize a favorite cycle such as an 

automatic termination cycle, or a default 

cycle that they can easily initiate and 


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that doesn’t require further 

manipulation; (2) it would be difficult if 

not impossible to develop any data or a 

consensus for the weighting factors to 

apply to the other cycles if multiple 

cycles were tested; (3) the burden on 

manufacturers and test labs to test 

multiple cycles out-weighs any benefit; 

and (4) the test cycle for cotton and 

linen clothes, at maximum temperature 

setting, will assess one of the most 

energy-intensive cycles on clothes 

dryers, so there is no need to further 

complicate the test procedure to assess 

if other cycles are more energy 

intensive. (ALS, No. 24 at p. 5) ALS also 

commented that dryers with automatic 

cycle termination should have the 

temperature for the test set at the 

‘‘maximum’’ temperature setting option 

available on the dryer. This is because 

the test cycle should be ‘‘the cycle 

recommended by the manufacturer for 

drying cotton and linen clothes’’ and as 

such would normally be a hightemperature heat setting. (ALS, No. 24 at 

p. 5) Whirlpool stated that consumers 

dry a variety of fabrics using a variety 

of clothes dryer cycles. While no one 

cycle reflects this diverse consumer 

behavior, performing the energy test at 

the maximum temperature on the 

normal cycle is a straightforward means 

of representing the highest-cost 

consumer use of the product. Whirlpool 

commented that, because of the wellestablished history with this approach, 

a change in the test procedure to test 

multiple cycles would not be warranted. 

Whirlpool further stated that any change 

would require extensive round-robin 

testing to determine the impact of the 

new test temperatures on the EF 

calculation. (Whirlpool, No. 27 at p. 3) 

The California Utilities/NRDC stated 

that DOE’s proposal to test a ‘‘normal’’ 

drying program is reasonably 

appropriate. The California Utilities/ 

NRDC stated that they lack additional 

consumer information on typical cycles 

and settings, and being aware of a 

potentially large testing burden of many 

different types of dryer tests, they 

support DOE’s proposal to test at 

‘‘normal’’ or ‘‘default’’ operation. 

(California Utilities/NRDC, No. 33 at p. 

4) The California Utilities/NRDC noted 

that manufacturers expressed concern 

regarding the use of the term ‘‘normal’’ 

cycle, so it is important that this term 

be clarified or defined to prevent a 

possible loophole in the test procedure. 

The California Utilities/NRDC suggested 

that DOE collect data from 

manufacturers concerning the 

conditions of operation for a ‘‘normal’’ 

dryer cycle to confirm that such cycles 

are reasonably consistent among 

manufacturers. Alternatively, DOE 

could use that data to define a range of 

operating conditions for a normal cycle, 

or request that manufacturers suggest 

such a definition. (California Utilities/ 

NRDC, No. 33 at p. 4) 

Evaluation of Proposed Amendments for 

Automatic Cycle Termination 

As discussed above, DOE conducted 

testing to evaluate the proposed 

amendments to the clothes dryer test 

procedure. As part of this testing, DOE 

tested nine clothes dryers as specified 

by the amendments to the test 

procedure for automatic cycle 

termination proposed in the June 2010 

TP SNOPR. The testing consisted of 

running the dryer on a ‘‘normal’’ 

automatic termination setting and 

stopping the dryer when the heater 

switches off for the final time 

(immediately before the cool-down 

period begins). Three identical tests 

were conducted for each clothes dryer 

unit, and the results were averaged. The 

results of this testing, presented below 

in Table III.8, showed that the tested 

clothes dryers had a measured EF 

between 12.4 percent and 38.8 percent 

lower than the EF measured according 

to the current DOE clothes dryer test 

procedure. DOE also noted that all of 

tested units dried the test load to final 

RMCs well below the target RMC of 5 

percent, ranging from 0.4 percent to 1.4 

percent RMC, with an average of 0.8 

percent. DOE also noted that even if the 

field use factor of 1.18 for a timer dryer 

is applied to the measured EF for a 

clothes dryer equipped with automatic 

cycle termination using the current DOE 

clothes dryer test procedure, this EF 

would still be more than the EF 

measured under the automatic cycle 

termination test procedure amendments 

proposed in the June 2010 TP SNOPR. 

(Applying the field use factor in this 

way adds the fixed estimate of overdrying energy consumption associated 

with time termination control dryers.) 

TABLE III.8—DOE CLOTHES DRYER AUTOMATIC CYCLE TERMINATION TESTS

Test unit 

Current DOE test 

procedure EF 

lb/kWh * 

Current DOE 

test procedure 

w/modified field 

use factor **EF 

lb/kWh 

Proposed automatic cycle termination test procedure 

EF 

lb/kWh Percent change Final RMC (%) 

Vented Electric Standard: 

Unit 3 ................................................ 3 .20 2 .82 2 .59 ¥ 19 .1 1.0 

Unit 4 ................................................ 3 .28 2 .89 2 .59 ¥ 21 .2 0.6 

Vented Gas: 

Unit 8 ................................................ 2 .83 2 .50 2 .42 ¥ 14 .5 0.4 

Unit 9 ................................................ 2 .85 2 .51 2 .38 ¥ 16 .3 0.9 

Unit 11 .............................................. 2 .98 2 .63 2 .40 ¥ 19 .5 0.9 

Vented Electric Compact 240V: 

Unit 12 .............................................. 3 .19 2 .81 2 .64 ¥ 17 .3 0.5 

Unit 13 .............................................. 2 .93 2 .59 2 .27 ¥ 22 .7 1.4 

Vented Electric Compact 120V: 

Unit 14 .............................................. 3 .23 2 .85 1 .98 ¥ 38 .8 0.7 

Ventless Electric Compact 240V: 

Unit 15 .............................................. 2 .37 2 .09 2 .07 ¥ 12 .4 1.1 

* Tests use the appropriate field use factor of 1.04 for clothes dryers with automatic termination. 

** Field use factor changed from the nominal 1.04 for clothes dryers with automatic termination to 1.18, which is nominally for timer dryers. 


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25The DOE clothes dryer test load is comprised 

of 22 in x 34 in pieces of 50/50 cotton/polyesterblend cloth. 

26The AHAM 8-lb test load is made up of the 

following mixed cotton items, which are intended 

to represent clothes items regularly laundered: 2 

sheets, 1 table cloth, 2 shirts, 3 bath towels, 2 ‘‘T’’ 

shirts, 2 pillow cases, 3 shorts, 1 wash cloth, 2 

handkerchiefs. 

27As noted in the June 2010 TP SNOPR, DOE 

applied a correction factor to the test data to 

account for the fact that the automatic cycle 

termination tests used the AHAM 8-lb test load 

instead of the DOE 7-lb test load. 

28 DOE noted that some of the tested units 

stopped the test cycle at or higher than 5-percent 

RMC, thereby not producing over-drying. 

These results showed significantly 

higher measured energy use for clothes 

dryers tested under the DOE test 

procedure with the proposed automatic 

cycle termination amendments. DOE 

evaluated possible reasons for this 

difference, and concluded that given the 

test load specified in the current DOE 

test procedure,25 the proposed 

automatic cycle termination control 

procedures may not adequately measure 

clothes dryer performance. As discussed 

above in this section, DOE believes that, 

although automatic termination control 

dryers may be measured as having a 

lower efficiency than a comparable 

dryer with only time termination 

control if tested according to the 

proposed test procedure, automatic 

termination control dryers may in fact 

be drying the clothing to approximately 

5-percent RMC in real world use. DOE 

believes that automatic termination 

control dryers reduce energy 

consumption (by reducing over-drying) 

compared to timer dryers based on 

analysis of the AHAM field use survey 

and analysis of field test data conducted 

by NIST. 46 FR 27324 (May 19, 1981). 

For these reasons, DOE believes the 

test procedure amendments for 

automatic cycle termination proposed in 

the June 2010 TP SNOPR do not 

adequately measure the energy 

consumption of clothes dryers equipped 

with such systems. Therefore, DOE is 

not adopting in today’s final rule the 

amendments for automatic cycle 

termination proposed in the June 2010 

TP SNOPR. 75 FR 37594, 37616 (June 

29, 2010). If data is made available to 

develop a test procedure that accurately 

measures the energy consumption of 

clothes dryers equipped with automatic 

termination controls, DOE may consider 

revised amendments in a future 

rulemaking. 

ALS commented that an automatic 

cycle termination-equipped dryer that 

produces a final RMC of greater than 5 

percent should be required to have 

additional test cycle runs. The 

insufficiently dried load would be 

placed back into the dryer for an extra 

cycle, and the extra-cycle energy added 

to the first test cycle results, until the 

final RMC is 5 percent or less. ALS 

commented that this extra cycle energy 

would be a significant penalty and 

incentive to keep manufacturers from 

creating automatic cycle termination 

systems that essentially tried to achieve 

a low energy consumption value while 

not achieving consumer-acceptable final 

RMC levels. ALS also believes that this 

method represents what consumers tend 

do when a load is not sufficiently dried 

at the end of the cycle—put the load 

back into the dryer and run another dry 

cycle on the same setting. (ALS, No. 24 

at p. 3) The California Utilities/NRDC 

supported DOE’s proposal to require a 

re-test at the ‘‘highest energy consuming 

setting’’ in the case of a dryer failing to 

reach 5-percent RMC or less under a 

normal drying program. (California 

Utilities/NRDC, No. 33 at p. 4) 

For the reasons discussed above, DOE 

is not adopting in today’s final rule the 

amendments proposed in the June 2010 

TP SNOPR to better account for 

automatic cycle termination. Therefore, 

additional specifications for such an 

approach are not relevant. 

Dry Clothes Load Testing 

CU commented that an additional test 

using a dry clothes load should be 

included as part of the test procedure to 

assess how well a sensor detects that a 

clothes load has been dried to terminate 

the cycle. CU commented that it tested 

products using a 12-lb dry clothes load 

(less than 5 percent initial RMC) of 

mixed cottons with the dryer at normal/ 

cotton, highest heat, and maximum 

dryness level settings. CU observed 

notable differences in the performance 

of different types of dryers (that is, those 

with thermostatic control and those 

with moisture sensors). CU noted that 

units with moisture sensors stopped 

within a reasonable time, but units with 

just a thermostat continued running, 

sometimes 20 times longer than a dryer 

with a moisture sensor. CU noted that 

one dryer with the moisture sensor ran 

an average of 3 minutes before shutting 

off, and in 3 tests, it averaged 162 Wh 

per test. Another dryer with a 

thermostat ran for an average of about 

60 minutes, and in 3 tests, it averaged 

2,335 Wh per test. In addition, CU 

observed significant variation among 

dryers with moisture sensors and those 

with thermostats, and stated it should 

not be assumed that these results 

represent performance for all dryers of 

either type. (CU, No. 29 at pp. 2–3) 

DOE does not believe running a dry 

clothes load would be representative of 

consumer usage. It also does not believe 

that the amount of time a clothes dryer 

operates with such a clothes load would 

necessarily be representative of the 

effectiveness of a sensor system in 

detecting final RMC for an initially 

damp clothes load. Further, DOE is not 

aware of how an energy efficiency 

metric would be established that 

considers the energy consumption of a 

dry clothes load test cycle. Therefore, 

DOE is not adopting any provisions for 

measuring the energy consumption of a 

dry clothes load test cycle in today’s 

final rule. 

Evaluation of Automatic Termination 

Technologies 

DOE noted in the June 2010 TP 

SNOPR that it conducted preliminary 

automatic cycle termination tests to 

analyze the various automatic 

termination technologies found in 

DOE’s sample of selected dryers. DOE 

selected the AHAM 8-lb test load 26

instead of the 7-lb load specified in the 

DOE test procedure for standard-size 

clothes dryers. It did so to lengthen the 

test cycle times and better evaluate the 

function of the dryer controls as the test 

load approached low RMCs. DOE also 

noted that the independent test lab 

conducting the clothes dryer tests used 

a data acquisition system to monitor 

estimated RMC of the test load 

continuously during the test cycle. The 

automatic termination tests conducted 

by DOE consisted of running the test 

cycle in a user-programmable automatic 

termination mode and allowing the 

dryer to self-terminate the drying cycle 

using the various automatic termination 

sensor technologies. DOE monitored the 

energy consumption and estimated RMC 

of the test load during the test cycle 

from the starting time at 70-percent 

initial RMC to the time when the heater 

last cycled off (that is, immediately 

before the cool-down period). The 

specific focus was on analyzing the 

amount of over-drying energy consumed 

drying the test load to less than 

5-percent RMC.27 75 FR 37594, 37617 

(June 29, 2010). 

Figure III.1 shows the over-drying 

energy consumption versus the final 

RMC for a number of different units 

tested, and, in some cases, different 

cycle settings.28 The data show that 

over-drying the test load to lower final 

RMCs requires higher energy 

consumption, with a slightly 

exponential trend likely because it 

becomes more difficult to remove the 

final small amounts of moisture 

remaining in the test load. DOE noted in 

the June 2010 TP SNOPR that it did not 

observe any relationship between the 

type of automatic cycle termination 


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sensor technology used and the amount 

of over-drying. DOE also noted, 

however, that these tests were 

conducted using different testing 

methods than the methods proposed in 

the June 2010 TP SNOPR (that is, 

various automatic cycle termination 

settings). Therefore, DOE was unable to 

determine whether one type of sensor 

technology is more accurate, and thus 

more effective at preventing overdrying. 75 FR 37618. 

Porticos commented that DOE 

considered only two possible methods 

for automatic cycle termination 

(moisture and temperature sensing). 

Porticos commented that these may be 

the only practical alternatives in a 

vented, forced-convection tumble dryer, 

but that alternate drying technologies 

may enable alternate methods of 

determining when the drying cycle 

should be terminated. Ignoring this 

possibility penalizes any appliance that 

attempts to deploy a different 

technology. (Porticos, No. 23 at p. 1) 

DOE agrees that the test procedure 

should not exclude alternate sensing 

technologies used for automatic cycle 

termination controls. DOE notes section 

3.5 of the test procedure, ‘‘Test for 

automatic termination field use factor 

credits,’’ specifies that the field use 

factor for automatic cycle termination 

would apply only to clothes dryers that 

meet the requirements for the 

definitions of ‘‘temperature sensing 

control’’ or ‘‘moisture sensing control.’’ 

The test procedure defines ‘‘temperature 

sensing control’’ a system that monitors 

the exhaust air temperature to 

automatically terminate the dryer cycle. 

The test procedure also defines 

‘‘moisture sensing control’’ as a system 

that uses a moisture sensing element 

within the drum that monitors the 

amount of moisture in the clothes to 

automatically terminate the dryer cycle. 

DOE also notes the test procedure 

defines ‘‘automatic termination control’’ 

as a control system with a sensor that 

monitors either the dryer load 

temperature or its moisture content and 

with a controller that automatically 

terminates the drying process. DOE 

believes that this definition would not 

limit the emergence of any new sensor 

technologies that monitor the moisture 

content or temperature in other ways 

from applying the field use factor for 

automatic cycle termination. For these 

reasons, DOE amends section 3.5 of the 

test procedure to specify that the field 

use factor applies to clothes dryers that 

meet the requirements for the 

definitions of ‘‘automatic termination 

control.’’ 

Target Final RMC 

DOE also noted in the June 2010 TP 

SNOPR that AS/NZS Standard 2442 

specifies the maximum allowable final 

RMC for automatic termination control 

dryers as 6 percent. DOE, however, 

stated that it is unaware of any data 

indicating that a final RMC of 6 percent 

would be representative of current 

consumer usage habits. DOE also noted 

that using 5-percent RMC, as proposed 

in today’s June 2010 TP SNOPR, would 

remain within the range specified by the 

current DOE test procedure, which 

specifies 2.5- to 5-percent final RMC. Id. 

The Joint Petitioners and AHAM 

commented that a final RMC of 5 

percent is appropriate. (Joint Petitioners, 

No. 30 at p. 6; AHAM, No. 31 at p. 6)) 

ALS stated that the test load final RMC 

should be no greater than 5 percent. 

ALS stated that if the test cycle 

continued to measure all of the energy 

including cool-down, manufacturers 


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29The clothes dryer would also consume energy 

to spin the drum during the cool-down period that 

is currently not accounted for by the DOE test 

procedure. 

would adopt their own methods to 

ensure that they do not over-dry the test 

load. (ALS, No. 24 at p. 3) As discussed 

above, DOE is not adopting the 

amendments to better account for 

automatic cycle termination proposed in 

the June 2010 TP SNOPR. For these 

reasons, DOE is not amending the test 

procedure to revise the final RMC. 

Cool-Down Period 

DOE also noted in the June 2010 TP 

SNOPR that there are at least two ways 

to terminate the drying cycle during the 

test: (1) Termination before cool-down, 

or (2) termination at the end of the 

selected test cycle, including cooldown. 75 FR 37594, 37616 (June 29, 

2010). Section 4.2 of AS/NZS Standard 

2442.1 requires that, for automatic 

termination control dryers, the 

programmed test cycle be run until 

immediately before the cool-down 

period begins. Similarly, section 4.5.1 of 

AHAM–HLD–1–2009 requires that the 

automatic termination control dryer test 

cycle not be permitted to advance into 

the cool-down period. Alternatively, 

section 9.2.1 of EN Standard 61121 

requires that the selected test cycle 

program be allowed to run until 

completion, including the cool-down 

period. In the June 2010 TP SNOPR, 

DOE proposed amendments for 

automatic cycle termination based on 

the provisions in AS/NZS Standard 

2442 because it provides a more 

representative comparison of the energy 

consumption between automatic 

termination control dryers and timer 

dryers than EN Standard 61121. In 

addition, the proposed amendments to 

stop the test cycle immediately before 

the cool-down period would harmonize 

DOE test methods with AS/NZS 

Standard 2442 and AHAM–HLD–1– 

2009. Id. DOE stated, however, that it 

was considering the alternative method 

of section 9.2.1 of EN Standard 61121. 

DOE recognizes that manufacturers may 

design products to use the residual heat 

during the cool-down period (that is, 

immediately after the heater has 

switched off for the final time) to 

continue to dry the clothes load while 

slowly spinning the drum to achieve a 

desired RMC.29 DOE recognizes that 

including the cool-down period may 

make it possible for some manufacturers 

to design dryers that attain the desired 

RMC with lower total energy 

consumption. DOE noted that this 

potential for energy efficiency 

improvement would not be captured by 

the test methods proposed in the June 

2010 TP SNOPR. To capture this realworld energy savings potential 

associated with the additional drying 

using residual heat during the cooldown period, DOE stated in the June 

2010 TP SNOPR that it could adopt an 

alternate approach to include the 

measurement of the cool-down period 

as part of the proposed automatic cycle 

termination test methodology. Under 

this alternate approach, section 3.3.2 of 

the test procedure for automatic 

termination control dryers, instead of 

specifying that ‘‘when the heater 

switches off for the final time, 

immediately before the cool-down 

period begins, stop the dryer,’’ would 

specify to ‘‘run the clothes dryer until 

the programmed cycle has terminated.’’ 

DOE also noted that inclusion of the 

cool-down period under the proposed 

test method would not affect the ability 

to compare energy consumption test 

results between automatic termination 

control dryers and timer dryers in DOE’s 

clothes dryer test procedure. DOE 

further stated in the June 2010 TP 

SNOPR that it is unaware of data 

showing the effects of including the 

cool-down period on the measured 

efficiency as compared to the existing 

test procedure. 75 FR 37616–17. 

The Joint Petitioners, AHAM, 

Whirlpool and ALS commented that, 

although they generally promote 

harmonization with international 

standards, they do not agree that AS/ 

NSZ Standard 2442 provides the best 

methods and procedures to account for 

the amount of over-drying associated 

with automatic termination control 

dryers beyond a specified RMC. The 

Joint Petitioners, AHAM, Whirlpool, 

ALS, the California Utilities/NRDC, and 

EJ commented that the test procedure 

should measure the full cycle, including 

cool-down period, which is more 

representative of consumer usage 

because it includes all of the energy use 

in a cycle. The Joint Petitioners, AHAM, 

Whirlpool and ALS stated that such an 

approach is reproducible and repeatable 

because it does not require any 

‘‘guesswork’’ as to when the cool-down 

will begin. The approach is also less 

burdensome because it does not require 

the manufacturers to determine the 

point immediately before cool-down for 

each model. (Joint Petitioners, No. 30 at 

p. 5; AHAM, No. 31 at p. 5; Whirlpool, 

No. 27 at pp. 2, 3; ALS, No. 24 at p. 3; 

ALS, Public Meeting Transcript, No. 20 

at pp. 97–98; California Utilities/NRDC, 

No. 33 at pp. 4–5; EJ, No. FDMS D0039 

at pp. 1–2) 

ALS also commented that the 

‘‘default’’ cool-down should be set if the 

dryer has selectable cool-down time 

period options. (ALS, No. 24 at p. 6) 

AHAM commented that the ‘‘asshipped’’ (that is, ‘‘default’’) cool-down 

settings should be included in active 

mode because this approach is more 

representative of actual consumer usage. 

(AHAM, No. 31 at p. 6) 

The Joint Efficiency Advocates 

Comment stated that excluding the cooldown period results in a portion of the 

energy consumed by a drying cycle not 

being measured by the test procedure. In 

addition, the Joint Efficiency Advocates 

Comment stated that including the cooldown period could provide 

manufacturers with an additional option 

for reducing energy consumption. (Joint 

Efficiency Advocates, No. 28 at p. 3) 

ALS and BSH supported including the 

cool-down period in the test procedure. 

They feel manufacturers may optimize 

the point where the heating is stopped 

and the residual heat in the load is used 

during cool-down to complete the 

drying process to achieve consumeraccepted final moisture retention levels, 

while avoiding ‘‘over drying’’ loads and 

potentially wasting energy. (ALS, No. 24 

at p. 3; BSH, Public Meeting Transcript, 

No. 20 at p. 98) EJ commented that a test 

procedure that ignores the additional 

drying functionality provided by 

cool-down mode reduces 

manufacturers’ incentive to provide this 

energy-saving feature. (EJ, No. FDMS 

D0039 at pp. 1–2) 

Whirlpool requested that DOE 

complete further analysis to adjust EF 

within the test procedure to account for 

the inclusion of the cool-down portion 

of the cycle. Whirlpool stated that 

failure to adjust the EF requirements 

will inadvertently result in 

requirements becoming too stringent. 

Whirlpool commented that it can infer 

that the cool-down portion of the cycle 

consumes little energy when compared 

to the drying portion as it is relatively 

short and uses only motor energy, not 

heating element energy. (Whirlpool, No. 

27 at pp. 2, 3) Whirlpool also 

commented that the additional energy 

consumed during cool-down period 

does not follow linear relationship with 

the RMC of the test load. Whirlpool 

stated that it does not have sufficient 

data to fully address how this would be 

reflected in total energy consumption. 

Whirlpool commented that if DOE were 

to make a specific request to AHAM for 

such data, Whirlpool would be willing 

to gather and supply information to 

AHAM for aggregation and submittal to 

DOE. (Whirlpool, No. 27 at p. 5) ALS 

commented that it has no data to submit 

to DOE at this time on how the 

proposed added cool-down period 

energy consumption would impact the 

measured energy efficiency of existing 


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30This is a typical approach for combination 

washer/dryers, which wash and dry a load in the 

same drum. 

clothes dryers, and suggested that DOE 

conduct tests to determine the impact. 

(ALS, No. 24 at p. 6) The California 

Utilities/NRDC similarly commented 

that they do not have specific data on 

the impacts this cool-down period has 

on dryer per-cycle energy use and 

calculated EF. However, they stated that 

although the impacts may be small, DOE 

should, for the purposes of 

completeness and reproducibility, 

consider including the energy use of the 

cool-down portion of the cycle into the 

active mode test procedure. The 

California Utilities/NRDC stated that 

DOE should revise the energy 

conservation standards to reflect this 

test procedure change. (California 

Utilities/NRDC, No. 33 at pp. 4–5) 

As discussed above, DOE is not 

adopting the amendments to better 

account for automatic cycle termination 

proposed in the June 2010 TP SNOPR. 

For this reason, DOE is not amending 

the test procedure to include the cooldown period for automatic termination 

test cycles. If DOE considers potential 

amendments for automatic cycle 

termination in a future rulemaking, it 

may consider provisions that account 

for the cool-down period. 

Calculation of Revised Results From 

Automatic Cycle Termination Test 

Measurements 

In the June 2010 TP SNOPR, DOE also 

proposed to revise section 4, 

‘‘Calculation of Derived Results from 

Test Measurements,’’ of the DOE test 

procedure. DOE proposed to revise the 

field use factors in the current DOE test 

procedure to more appropriately 

account for automatic termination 

control dryers’ over-drying energy 

consumption. DOE proposed that a field 

use factor of 1.0 (instead of the 1.04 

currently provided) would be specified 

for automatic termination control 

clothes dryers, so that any over-drying 

energy consumption would be added 

directly to the drying energy 

consumption to decrement EF. If the 

proposed test methods were used, an 

automatic termination control dryer that 

is able minimize over-drying by drying 

the test load to close to 5-percent RMC 

would achieve a higher measured 

efficiency than if it over-dried the test 

load to an RMC of less than 5 percent. 

The lower amount of energy consumed 

over-drying the test load would be 

included in the per-cycle energy 

consumption, and would result in a 

reduction in the measured EF. For timer 

dryers, DOE proposed to use the percycle energy consumption 

measurements from the two proposed 

tests cycles discussed above in this 

section (corresponding to 5–6 and 4–5 

percent final RMCs) to interpolate the 

value of the per-cycle energy 

consumption required to dry the test 

load to exactly 5-percent RMC. The 1.18 

field use factor in the current DOE test 

procedure would then be applied to 

account for the over-drying energy 

consumption of timer dryers. 75 FR 

37594, 37617 (June 29, 2010). 

As discussed above in this section, 

DOE noted in the September 1977 TP 

Final Rule that the 1.18 field use factor 

in the calculation of EF for timer dryers 

was based on analysis of data from a 

field use survey conducted by 

Oklahoma Gas and Electric Company 

involving 64 homes as well as data 

provided by AHAM on the measured 

energy consumption per-cycle under the 

DOE test procedure to account for the 

differences between the values derived 

from the laboratory test procedures and 

those obtained from actual consumer 

use. 42 FR 46145, 46146 (September 14, 

1977). DOE stated in the June 2010 TP 

SNOPR that it was unaware of any data 

or studies indicating the 1.18 field use 

factor for timer dryers used to account 

for over- or under-drying test loads in 

real-world use is inaccurate and not 

currently representative of consumer 

usage. For this reason, DOE did not 

propose to revise the 1.18 field use 

factor for timer dryers in the June 2010 

TP SNOPR but requested data and 

comment on whether this value is 

appropriate. Id. 

AHAM, the Joint Petitioners, the 

California Utilities/NRDC, and ALS 

supported DOE’s proposal to change the 

field use factor from 1.04 to 1.0 for 

automatic termination control dryers 

and not revise the 1.18 field use factor 

for timer dryers. (AHAM, No. 31 at p. 

6; Joint Petitioners, No. 30 at p. 6; 

California Utilities/NRDC, No. 33 at p. 

5; ALS, No. 24 at p. 3) 

As discussed above, DOE is not 

adopting in today’s final rule the 

amendments to better account for 

automatic cycle termination proposed in 

the June 2010 TP SNOPR. For the 

reasons stated above, DOE is not 

amending the test procedure in today’s 

final rule to include the revisions to the 

energy use calculations or the field use 

factors proposed in the June 2010 TP 

SNOPR. If DOE considers potential 

amendments for automatic cycler 

termination in a future rulemaking, it 

may consider such revisions to the 

energy use calculations and field use 

factors. 

3. Test Procedure for Ventless Clothes 

Dryers 

DOE noted in the October 2007 

Framework Document that a potential 

limitation of the clothes dryer test 

procedure had been identified for 

ventless dryers, which include 

condensing clothes dryers and 

combination washer/dryers. 

(Framework Document, STD No. 1 at p. 

5) Ventless clothes dryers do not vent 

exhaust air to the outside as a 

conventional clothes dryer does. 

Instead, they typically use ambient air 

in a heat exchanger to cool the hot, 

humid air inside the appliance, thereby 

condensing out the moisture. 

Alternatively, cold water can be used in 

the heat exchanger to condense the 

moisture from the air in the drum.30 In 

either case, the dry air exiting the drum 

is reheated and recirculated in a closed 

loop. Thus, rather than moisture-laden 

exhaust air that vents outside, ventless 

clothes dryers produce a wastewater 

stream that can be either collected in an 

included water container or discharged 

down the household drain. The process 

of condensing out the moisture in the 

recirculated air results in higher energy 

consumption than a conventional 

clothes dryer, however, and it can 

significantly increase the ambient room 

temperature. 

Manufacturers of condensing clothes 

dryers have, in the past, applied for 

waivers from the DOE test procedure for 

these products on the basis that the test 

procedure did not contain provisions for 

ventless clothes dryers. See, e.g., 74 FR 

66334 (December 15, 2009); 75 FR 

13122 (Mar. 18, 2010). The current test 

procedure requires using an exhaust 

restrictor to simulate the backpressure 

effects of a vent tube in an installed 

condition. Condenser dryers do not 

have exhaust vents because they 

recirculate rather than exhaust the 

process air. 

In the October 2007 Framework 

Document, DOE stated that it intended 

to analyze ventless clothes dryers as a 

separate product class, recognizing the 

unique utility that ventless clothes 

dryers offers to consumers. That utility 

is the ability to be installed in 

conditions in which vented clothes 

dryers would be precluded due to 

venting restrictions. DOE considered 

two product classes for ventless clothes 

dryers: (1) Ventless electric compact 

(240V) clothes dryers; and (2) electric 

combination washer/dryers. 

In this final test procedure rule, DOE 

adopts amendments to measure the 

energy use of ventless clothes dryers, as 

discussed in more detail below. 


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Effects of Clothes Dryers on HVAC 

Energy Use 

In response to the October 2007 

Framework Document, DOE received 

comments from AHAM that the energy 

calculations for ventless clothes dryers 

should take a more ‘‘holistic’’ approach 

than those for vented clothes dryers. 

That is because ventless clothes dryers 

can have an effect on energy use oustide 

of their system (that is, impacts on 

HVAC loads). 75 FR 37594, 37620–21 

(June 29, 2010). EPCA requires that any 

test procedures prescribed or amended 

under this section be reasonably 

designed to produce test results that 

measure energy efficiency, energy use, 

water use, or estimated annual operating 

cost of a covered product during a 

representative average use cycle or 

period of use. (42 U.S.C. 6293(b)(3)) 

DOE stated in the June 2010 TP SNOPR 

that accounting for the impacts of 

ventless clothes dryers on HVAC loads 

and thus on the energy use of a 

household would be inconsistent with 

the EPCA requirement that a test 

procedure measure the energy use of a 

covered product. DOE also noted that, 

while the test procedure for heat pump 

water heaters does not account for 

impacts to HVAC loads, DOE 

considered the effects of heat pump 

water heaters on house heating loads as 

part of the energy-use characterization 

in the rulemaking to establish energy 

conservation standards rulemaking for 

water heaters. For these reasons, DOE 

did not propose to amend its clothes 

dryer test procedure to account for the 

ambient space conditioning impacts in 

the June 2010 TP SNOPR, but stated that 

it would consider such impacts as part 

of the concurrent energy conservation 

standards rulemaking. 75 FR 37594, 

37621 (June 29, 2010). 

In response to the June 2010 TP 

SNOPR, the California Utilities/NRDC 

commented that DOE should consider 

HVAC impacts as part of the concurrent 

energy conservation standards 

rulemaking. They added that the ECOS 

report showed that space conditioning 

impacts due to clothes dryer intake air 

may be significant. (California Utilities/ 

NRDC, No. 33 at pp. 8–9) The California 

Utilities/NRDC and the Super Efficient 

Dryer Initiative (SEDI) noted that the 

actual impacts will depend on many 

factors, such as climate, season, and 

location of the clothes dryer within the 

home. They stated DOE should 

thoroughly assess this aspect of clothes 

dryer operation and research 

opportunities for energy reduction. 

(California Utilities/NRDC, No. 33 at p. 

9; SEDI, No. 34 at p. 2) 

Porticos commented that the HVAC 

load from a vented clothes dryer is 

much higher than that of other 

household appliances. According to 

Porticos, a vented clothes dryer induces 

air infiltration equal to the exhaust 

airflow (up to 160 cubic feet per minute 

(cfm)), enough to completely empty a 

1200 cubic foot (ft3) home of all its 

conditioned air in 1 hour. (Porticos, No. 

23 at p. 2) Porticos and SEDI both 

commented that there would be 

significant HVAC savings associated 

with switching from vented to ventless 

clothes dryers. (Porticos, No. 23 at p. 2; 

SEDI, No. 34 at p. 2) SEDI added that 

vented clothes dryers operate by 

drawing supply air from the volume of 

conditioned space within a house. The 

supply air is heated and used to dry the 

clothes. The air is then exhausted from 

the home. SEDI stated this process 

wastes both the heating energy put into 

that air by the dryer itself, but also the 

heating or cooling energy put into that 

air earlier by the home’s HVAC system. 

(SEDI, No. 34 at p. 2) Porticos also 

added that ventless dryers tend to 

directly heat the living space rather than 

inducing air infiltration. (Porticos, No. 

23 at p. 2) The California Utilities/NRDC 

commented that HVAC impacts may be 

mitigated through increased use of 

ventless dryers, or other technologies for 

vented dryers, such as an outside air 

intake port, which could provide a 

location to fit an intake air vent. The 

California Utilities/NRDC stated that it 

is important that DOE gather data on the 

HVAC impacts of clothes dryers to 

accurately assess the costs and savings 

impacts of such technologies. 

(California Utilities/NRDC, No. 33 at p. 

9) 

The California Utilities/NRDC 

commented that the test procedure 

would be a simple and convenient 

means for manufacturers to submit 

useful data to DOE on clothes dryer 

operation that impacts HVAC loads 

(namely intake air). Data on intake air 

could be gathered by requiring the 

measurement of intake air via a small 

sensor in the airstream during the test. 

The California Utilities/NRDC added 

that this information would be a 

valuable indication of the amount of 

airflow caused by clothes dryers, and 

could form the basis for subsequent 

DOE analysis. (California Utilities/ 

NRDC, No. 33 at p. 9) Porticos 

recommended the following 

modifications to the test procedure to 

evaluate the effects of the clothes dryer 

on building energy consumption: 

1. Directly measure the exhaust 

airflow (defined as zero for ventless 

appliances); 

2. Directly measure the ambient heatload represented by the appliance 

during operation (DOE might define this 

as zero for vented appliances); 

3. Calculate the overall HVAC burden 

due to heat-burden and induced 

infiltration; and 

4. Optionally, modify this figure to 

account for variations due to regional 

usage (a vented dryer might work quite 

well in a moderate climate, but less-so 

in colder climates). (Porticos, No. 23 at 

p. 2) 

Porticos added that there is a 

precedent for addressing impacts 

external to the clothes dryer because 

existing DOE test procedures penalize 

clothes washers which do a poor job of 

spin-drying clothes, thus placing an 

excessive burden on the clothes dryer. 

Id. 

SEDI commented that both the current 

and proposed clothes dryer test 

procedures ignore the HVAC impact of 

vented dryers, and will not provide 

DOE, or SEDI and other energy 

efficiency program providers, with the 

information necessary to estimate HVAC 

savings. SEDI commented that ideally, 

testing for all clothes dryers would 

include measurement of the energy 

content of the air expelled from the 

home during the drying cycle, which 

would be added to the energy directly 

consumed by the dryer itself. (SEDI, No. 

34 at p. 2) SEDI supported the 

recommended modifications for 

measuring HVAC impacts submitted by 

Porticos. SEDI also recognized, 

however, that it may be extremely 

difficult to develop HVAC energy 

consumption algorithms for residential 

clothes dryers that are applicable across 

the United States. SEDI also recognized 

that pursuing this comprehensive 

approach could move DOE away from 

harmonization with international 

standards. SEDI commented that, at a 

minimum, DOE should adopt at least 

modifications 1 and 2 suggested by 

Porticos, presented above, but with the 

following change: ‘‘1. Directly measure 

the exhaust air volume (defined as zero 

for ventless appliances) during the 

entire drying cycle.’’ SEDI commented 

that this change would enable the 

energy use of clothes dryers that have 

different rates of venting at different 

points during the drying cycle. In 

addition, if the volume of air vented by 

a clothes dryer from a home is 

measured, the HVAC impacts of that 

clothes dryer on the home could be 

estimated. (SEDI, No. 34 at p. 2) 

DOE reiterates that accounting for the 

effects of clothes dryers on HVAC 

energy use is inconsistent with the 

EPCA requirement that a test procedure 

measure the energy efficiency, energy 


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31 DOE further notes that to accurately evaluate 

the HVAC impacts of clothes dryers it would need 

to determine the amount of heating and cooling 

being performed by the HVAC system, which would 

vary by region and time of year. In addition, to 

determine the amount of induced infiltration and 

heat-load caused by a clothes dryer, DOE would 

need to develop provisions for accurate and 

repeatable measurements, including: test equipment 

tolerances, position of measurement devices in 

either the exhaust or other locations, and 

determination of representative household air 

leakage rates. Such additional testing provisions for 

measuring the HVAC impacts would also increase 

the testing burden on manufacturers. 

32Whirlpool, 2007. ‘‘U.S Department of Energy 

Test Procedure Change for Condensing Clothes 

Dryers.’’ September 4, 2007. Docket No. EE–2007– 

BT–STD–0010, Comment Number 13. 

use, or estimated annual operating cost 

of a covered product. (42 U.S.C. 

6293(b)(3)) DOE acknowledges its 

clothes washer test procedure measures 

the RMC at the end of the wash cycle, 

but notes that in this case, the test 

procedure accounts directly for the 

additional energy use of a clothes 

washer to remove moisture from a 

clothes load. For these reasons, DOE is 

not revising the test procedure to 

account for HVAC energy use in today’s 

final rule.31

The Joint Petitioners commented that 

DOE should create a ventless clothes 

dryer test procedure to define a baseline 

energy consumption level for this new 

product category. Such a procedure 

would include combination washer/ 

dryers. (Joint Petitioners, No. 25 at p. 14; 

Joint Petitioners, No. 30 at p. 6) ALS 

also supported the addition of test 

procedures for ventless clothes dryers. 

(ALS, No. 24 at p. 6) SEDI also noted the 

importance of expanding the test 

procedure to accommodate ventless 

clothes dryers, such as the energy 

efficient heat pump clothes dryers now 

gaining market share in Europe. SEDI 

stated that DOE should develop a 

ventless clothes dryer test procedure as 

soon as possible, while taking care not 

to inadvertently discourage efforts to 

increase the energy efficiency of clothes 

dryers in North America. (SEDI, No. 34 

at p. 2) 

Ventless Clothes Dryer Test Procedure 

Amendments 

In the June 2010 TP SNOPR, DOE 

examined an alternate test procedure for 

ventless clothes dryers that provided 

definitions for ‘‘conventional clothes 

dryers’’ and ‘‘condensing clothes dryers’’ 

and would require the exhaust 

simulator to be used only for vented 

clothes dryers. DOE conducted limited 

tests of ventless clothes dryers at an 

independent testing laboratory 

according to those amendments. DOE 

conducted three tests per unit on one 

ventless electric compact (240V) clothes 

dryer and one ventless combination 

washer/dryer. Table III.9 shows the test 

results. DOE observed no variation in EF 

from test to test of the proposed test 

procedure for the ventless electric 

compact (240V) dryer, and less than 2- 

percent variation in EF test-to-test for 

the ventless combination washer/dryer. 

Based on this testing, DOE stated in the 

June 2010 TP SNOPR that the alternate 

testing procedures appear to produce 

repeatable results. 75 FR 37594, 37621 

(June 29, 2010). 

TABLE III.9—DATA FROM DOE TESTING OF VENTLESS CLOTHES DRYERS

FOR THE JUNE 2010 TP SNOPR 

Test run 

EF (lb/kWh) 

Ventless 

electric 

compact 

(240 V) 

Ventless 

combination 

washer/dryer 

1 ................ 2.37 1.95 

2 ................ 2.37 1.96 

3 ................ 2.37 1.93 

DOE also investigated testing 

conditions and methods for ventless or 

condensing clothes dryers specified in 

international test standards, including 

those used in Europe, China, Australia, 

and New Zealand. Id. 

DOE evaluated EN Standard 61121, 

and identified as relevant the test 

procedures for condensing (ventless) 

clothes dryers, as well as certain test 

conditions that affect all clothes dryers. 

In particular, DOE noted that section 3 

of EN Standard 61121, ‘‘Definitions and 

symbols,’’ provides definitions for ‘‘air 

vented tumble dryer’’ and ‘‘condenser 

tumble dryer.’’ DOE noted that section 6 

of EN Standard 61121, ‘‘General,’’ 

provides general conditions for 

measurements for both types of dryers, 

in particular for installation without an 

exhaust duct, as well as ambient 

temperature conditions. DOE noted that 

section 9 of EN Standard 61121, 

‘‘Performance tests,’’ provides the test 

procedures for performance tests for 

both types of dryers. DOE noted in the 

June 2010 TP SNOPR these test 

procedures provide greater specificity 

than the alternate test procedure 

discussed above. 75 FR 37621–22. 

DOE also evaluated AS/NZS Standard 

2442.1, which specifically includes 

condenser clothes dryers and the dryer 

function of combination washer/dryers. 

DOE noted that AS/NZS Standard 

2442.1 provides definitions for vented 

and condenser clothes dryers that are 

essentially the same as those provided 

in EN Standard 61121. DOE also noted 

that AS/NZS Standard 2442.1 provides 

exhaust conditions for installation that 

are very similar to those provided in EN 

Standard 61121. 75 FR 37622. 

In the June 2010 TP SNOPR, DOE also 

considered comments that Whirlpool 

submitted as part of the residential 

clothes dryer and room air conditioner 

energy conservation standards 

rulemaking, providing amendments to 

the DOE test procedure for clothes 

dryers to include methods for the testing 

of condensing dryers.32 These suggested 

amendments were largely based on EN 

Standard 61121. DOE noted that 

Whirlpool suggested definitions for 

‘‘exhausted’’ clothes dryers, ‘‘nonexhausted’’ clothes dryers, and 

‘‘condensing’’ clothes dryers. Whirlpool 

also suggested provisions for the 

installation conditions for ventless 

clothes dryers, in particular for 

installation without an exhaust 

simulator. Whirlpool also suggested 

provisions for ventless clothes dryers for 

pre-conditioning, conditions for a 

condensation box and the condenser 

unit, as well as test measurement 

methods for ventless clothes dryers. 75 

FR 37622–23. 

DOE reviewed the definitions in EN 

Standard 61121 (section 3), AS/NZS 

Standard 2442.1 (section 1.4), and 

Whirlpool’s proposed amendments to 

the DOE test procedure. DOE concluded 

that the proposed definitions of 

‘‘conventional clothes dryer’’ and 

‘‘condensing clothes dryer’’ are 

essentially the same as the international 

test standards definitions. DOE 

proposed to define ‘‘conventional 

clothes dryer’’ as ‘‘a clothes dryer that 

exhausts the evaporated moisture from 

the cabinet.’’ It proposed to define 

‘‘ventless clothes dryer’’ as ‘‘a clothes 

dryer that uses a closed-loop system 

with an internal condenser to remove 

the evaporated moisture from the heated 

air. The moist air is not discharged from 

the cabinet.’’ DOE proposed to use the 

term ‘‘ventless’’ to reflect the actual 

consumer utility (that is, no external 

vent required) instead of ‘‘condensing’’ 

because of the possibility that vented 

dryers that also condense are also 

available on the market. 75 FR 37623. 

AHAM and ALS commented in support 

of the proposed definitions. (AHAM, 

No. 31 at p. 6; ALS, No. 24 at p. 6) 

Whirlpool commented that it supports 

substituting ‘‘ventless’’ for ‘‘condensing’’. 

(Whirlpool, No. 27 at p. 3) For the 

reasons stated above, DOE adopts the 

definitions of ‘‘conventional clothes 

dryer’’ and ‘‘ventless clothes dryer’’ 

proposed in the June 2010 TP SNOPR. 

DOE evaluated the installation 

conditions detailed in EN Standard 

61121 (section 6.1), AS/NZS Standard 

2442.1 (section 3.4), and Whirlpool’s 


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proposed amendments to the DOE test 

procedure. DOE stated in the June 2010 

TP SNOPR that the proposed 

amendments for the exhaust duct 

installation requirements, with 

clarifications added, are appropriate for 

testing ventless clothes dryers. 75 FR 

37594, 37623 (June 29, 2010). DOE 

noted the proposed exhaust duct 

installation conditions remove the 

requirement for installing an exhaust 

simulator for a clothes dryer without an 

exhaust duct (that is, a ventless clothes 

dryer). The international test standards 

noted above also require that a clothes 

dryer without an exhaust duct be tested 

as such. Those standards, however, also 

provide additional conditions for a 

clothes dryer with an optional exhaust 

duct, stating that such a clothes dryer 

should be tested without the duct 

installed. DOE believes these 

installation conditions provide 

additional clarity and cover all possible 

clothes dryer configurations, as well as 

harmonizes with international test 

standards. Therefore, DOE proposed in 

the June 2010 TP SNOPR to amend 

section 2.1 of the DOE test procedure for 

clothes dryers, which covers installation 

conditions. The amendments qualify the 

requirement for an exhaust simulator so 

that it would apply only to conventional 

clothes dryers. The amendments added 

the clarification that ventless clothes 

dryers be tested without the exhaust 

simulator installed and, if a dryer is 

designed to operate with an optional 

exhaust duct, the dryer shall be tested 

without the duct installed. Id. AHAM, 

Whirlpool, and ALS supported the 

proposed exhaust duct installation 

conditions. (AHAM, No. 31 at p. 7; 

Whirlpool, No. 27 at p. 3; ALS, No. 24 

at p. 6) In the absence of comments 

objecting to this proposal, DOE adopts 

the exhaust duct installation conditions 

proposed in the June 2010 TP SNOPR. 

DOE also believes the provisions in 

EN Standard 61121 regarding a 

condensation box provides additional 

clarity that the test procedures are 

intended to cover all possible ventless 

clothes dryer configurations. For this 

reason, DOE proposed in the June 2010 

TP SNOPR to revise section 2.1, 

‘‘Installation,’’ of the DOE test procedure 

for clothes dryers. The revision would 

add this requirement to the installation 

conditions: ‘‘if a manufacturer gives the 

option to use a ventless clothes dryer 

with or without a condensation box, the 

clothes dryer shall be tested with the 

condensation box installed.’’ In 

addition, DOE proposed to amend the 

testing cycle measurement in section 3.3 

to add that if the dryer automatically 

stops during a cycle because the 

condensation box is full of water, the 

test is stopped, and the test run is 

invalid. This requirement would ensure 

efficiency is measured consistently. 75 

FR 37594, 37623 (June 29, 2010). 

AHAM and Whirlpool both supported 

the proposed change to section 2.1 of 

the DOE test procedure. (AHAM, No. 31 

at p. 7; Whirlpool, No. 27 at p. 3) For 

the reasons stated above, and in the 

absence of comments objecting to this 

proposal, DOE adopts in today’s final 

rule the revisions to section 2.1, 

Installation of the DOE clothes dryer test 

procedure regarding a condensation box 

as proposed in the June 2010 TP 

SNOPR. 75 FR 37594, 37623 (June 29, 

2010). 

AHAM also commented that DOE 

should clarify that if the condensation 

box is full and the test is invalid, the retesting should be conducted under the 

same installation conditions as the 

original test. Those conditions should 

be those provided in the manufacturer’s 

use and care guide so that the test is 

representative of actual consumer use. 

(AHAM, No. 31 at p. 8) Whirlpool 

similarly recommended adding, for 

clarity, that if the condensation box is 

full and the test is invalid, that the box 

is to be emptied and the test re-run from 

the beginning. (Whirlpool, No. 27 at p. 

4) DOE agrees that additional provisions 

should be included to clarify the 

procedure for retesting when the 

condensation box is full of water and 

the test is considered valid. DOE 

believes that Whirlpool’s suggested 

revision provided explicit instructions 

as to the procedure for re-running the 

test cycle. For these reasons, DOE 

amends section 3.3 of the DOE clothes 

dryer test procedure to add that ‘‘if the 

dryer automatically stops during a cycle 

and because the condensation box is full 

of water, the test is stopped and the test 

run is invalid, in which case the 

condensation box shall be emptied and 

the test re-run from the beginning.’’ 

Also regarding installation conditions, 

DOE believes that Whirlpool’s proposal 

to add a requirement that the condenser 

unit of the clothes dryer must remain in 

place and not be taken out of the clothes 

dryer for any reason between tests 

would clarify the test procedure and 

ensures that all manufacturers are 

testing products under the same 

conditions. For this reason, DOE 

proposed in the June 2010 TP SNOPR to 

add in section 2.1 of the DOE clothes 

dryer test procedure the provision that 

the condenser unit of the dryer must 

remain in place and not be taken out of 

the dryer between tests. 75 FR 37594, 

37623 (June 29, 2010). 

In the June 2010 TP SNOPR, 

Whirlpool supported the proposed 

amendment to require that the 

condenser unit remain in place and not 

be removed between tests, adding that 

this is for purposes of repeatability. 

Whirlpool commented that, if needed, 

the condenser unit should be cleaned 

prior to the first test run so it does not 

need to be cleaned during the test 

procedure. (Whirlpool, No. 27 at p. 4) 

ALS also commented in support of 

DOE’s proposed amendments regarding 

the condenser unit. (ALS, No. 24 at p. 

6) AHAM stated that there is no 

rationale for the proposed amendment 

requiring the condenser unit to remain 

in place and not be taken out of the 

clothes dryer for any reason between 

tests. AHAM commented that DOE 

should not include that provision. 

However, if it is included, it needs to be 

clarified. For example, the test 

procedure should state how many test 

runs are required. (AHAM, No. 31 at p. 

7) 

DOE agrees that the condenser unit 

may be cleaned prior to the first test 

run. DOE also believes that requiring the 

condenser unit to remain in place 

between tests ensures repeatability. As 

discussed later in this section, DOE is 

not amending the test procedure to 

require multiple test cycles. Because 

multiple test cycles may be necessary 

under certain conditions, however, such 

as a requirement that if the 

condensation box is full and must be 

emptied, the test would be re-run from 

the beginning. For these reasons, DOE 

amends section 2.1 of the clothes dryer 

test procedure regarding installation to 

add the provision the condenser unit of 

the dryer must remain in place and not 

be taken out of the dryer between tests, 

as proposed in the June 2010 TP 

SNOPR. 75 FR 37594, 37623 (June 29, 

2010). 

DOE stated in the June 2010 TP 

SNOPR that the methodology in the 

current DOE test procedure for 

conventional (vented) clothes dryers can 

be applied to ventless clothes dryers, 

with a number of clarifications added. 

Based on starting test conditions 

detailed in EN Standard 61121 (section 

9.1) and Whirlpool’s proposed 

amendments, DOE proposed to revise 

section 2.8 to provide a consistent and 

repeatable approach for ventless clothes 

dryers. 75 FR 37594, 37623 (June 29, 

2010). DOE noted that this section, 

which addresses clothes dryer 

preconditioning, currently requires that 

before any test cycle is initiated the 

clothes dryer must be operated without 

a test load in the non-heat mode for 15 

minutes or until the discharge air 

temperature varies less than 1 °F during 

a period of 10 minutes, whichever is 

longer. Because a ventless clothes dryer 


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does not have discharge air for which 

the temperature can be measured, DOE 

proposed in the June 2010 TP SNOPR to 

revise this section. The revision would 

require that, for ventless clothes dryers, 

the steady-state temperature must be 

equal to the ambient room temperature 

specified by section 2.2 of the existing 

DOE clothes dryer test procedure before 

the start of all test runs. This could be 

done by leaving the machine at ambient 

room conditions for at least 12 hours but 

not more than 36 hours between tests. 

DOE also proposed to revise section 2.8, 

‘‘Test loads,’’ of the DOE clothes dryer 

test procedure to add a qualification to 

the procedure for pre-conditioning that 

it applies only to vented clothes dryers. 

Id. 

AHAM commented at the public 

meeting that DOE should remove the 

clause specifying a maximum time 

between tests because it did not have 

supporting information to define a 

maximum time between tests. (AHAM, 

Public Meeting Transcript, No. 20 at p. 

120) AHAM later provided written 

comments revising these initial 

statements. It stated it supported the 

revisions to section 2.8 of the DOE test 

procedure proposed in the June 2010 TP 

SNOPR, including the specification that 

steady-state temperature for ventless 

clothes dryers may be achieved by 

leaving the machine at ambient room 

temperature between tests for at least 12 

hours, but not more than 36 hours. 

(AHAM, No. 31 at pp. 7–8) Whirlpool 

and ALS also supported the revisions to 

section 2.8 of the DOE test procedure 

proposed in the June 2010 TP SNOPR. 

(Whirlpool, No. 27 at p. 4, ALS, No. 24 

at p. 6) BSH questioned what method or 

procedure might be used to get the 

clothes dryer back to a testable state 

after a 36-hour break in testing. BSH 

also commented that, occasionally, 

there are breaks in testing that are longer 

than a day and a half; some breaks may 

last weeks. (BSH, Public Meeting 

Transcript, No. 20 at p. 119) DOE is not 

aware of any data providing a rationale 

for this 36-hour maximum time limit for 

leaving the machine at ambient room 

temperature between tests to achieve 

steady-state temperature. As a result, 

DOE amends section 2.8 of the clothes 

dryer test procedure regarding clothes 

dryer preconditioning to include the 

revisions proposed in the June 2010 TP 

SNOPR, as presented above, but without 

the 36-hour maximum time limit for 

leaving the machine at room ambient 

conditions for ventless clothes dryer 

preconditioning. 

AHAM also commented that DOE 

should to insert the word ‘‘machine’’ 

before temperature when describing the 

machine steady-state requirements for 

ventless clothes dryers. (AHAM, Public 

Meeting Transcript, No. 20 at pp. 117– 

118) AHAM stated that for a 

manufacturer running back-to-back 

tests, waiting 12 hours between tests is 

a significant test burden. AHAM 

suggested replacing the word ‘‘can’’ with 

‘‘may’’ regarding the 12-hour 

requirement to allow manufacturers to 

reach the ambient room temperature by 

some other means of cooling the 

machine, such as a fan or portable air 

conditioner. (AHAM, Public Meeting 

Transcript, No. 20 at p. 118) BSH 

commented that because ventless 

clothes dryers do not discharge air there 

needs to be a method for determining 

steady state other than monitoring the 

discharge air temperature. (BSH, Public 

Meeting Transcript, No. 20 at pp. 129– 

130) 

DOE agrees with AHAM’s comments 

and accepts the clarifications that the 

steady-state ‘‘machine’’ temperature 

must be equal to ambient room 

temperature. It also agrees that an 

additional note should clarify that this 

‘‘may’’ be done by leaving the machine 

at ambient room conditions for at least 

12 hours between tests. Thus, using 

other means to achieve a steady-state 

machine temperature would be 

acceptable under the test procedure 

provisions. In response to the comments 

by BSH, DOE believes that the steadystate ‘‘machine’’ temperature clarifies 

that the temperature of the actual 

machine itself should be monitored. For 

these reasons, DOE adopts the 

amendments to section 2.8 of the DOE 

clothes dryer test procedure for clothes 

dryer preconditioning proposed in the 

June 2010 TP SNOPR, with the 

additional clarifications discussed 

above. 

Relatedly, DOE stated in the June 

2010 TP SNOPR that it agrees with the 

provisions in section 9.2.2 of EN 

Standard 61121 and Whirlpool’s 

proposed amendments. These specify 

that the first cycle after a period of nonoperation longer than 36 hours shall not 

be used for evaluation, and that, 

between test cycles, the door of the 

clothes dryer shall be closed except for 

loading (and unloading). DOE noted that 

the first requirement makes the first test 

run on an unused (dry) ventless clothes 

dryer invalid, and the results from it 

could not be used for the energy 

efficiency calculations. DOE proposed 

in the June 2010 TP SNOPR to 

incorporate these provisions into 

section 3.3 of the DOE clothes dryer test 

procedure. 75 FR 37594, 37623–24 (June 

29, 2010). 

AHAM, Whirlpool, and ALS 

commented in support of the proposed 

requirements that after 36 hours of nonoperation, the first test run is not valid 

and that the door remain closed 

between tests except for loading and 

unloading. They felt these requirements 

would enhance repeatability. (AHAM, 

No. 31 at p. 8; Whirlpool, No. 27 at 

p. 4; ALS, No. 24 at p. 6) DOE is not 

aware of any data providing a rationale 

for why the first test run after a period 

of non-operation of 36 hours would not 

be valid. As a result, DOE is not 

adopting amendments that specify the 

first cycle after a period of nonoperation longer than 36 hours shall not 

be used for evaluation. In the absence of 

comments objecting to the latter 

proposal, DOE adopts the amendment to 

the clothes dryer test procedure that, 

between test cycles, the door of the 

tumble dryer shall be closed except for 

loading (and unloading), as proposed in 

the June 2010 TP SNOPR. 75 FR 37594, 

37623–24 (June 29, 2010). 

DOE noted in the June 2010 TP 

SNOPR that section 9.2.1 of EN 

Standard 61121 requires that at least 

five valid test cycles be performed and 

the results averaged. DOE’s clothes 

dryer test procedure does not specify 

multiple test cycles to obtain the 

representative EF, and DOE is not aware 

of data suggesting that test-to-test 

variation is sufficient to warrant a 

requirement for more than one test 

cycle. Therefore, DOE did not propose 

amendments addressing the number of 

valid test cycles in the June 2010 TP 

SNOPR. 75 FR 37624. 

ALS supported DOE’s 

recommendation to require only one test 

cycle for a valid clothes dryer test 

because there is no evidence that 

additional tests are warranted, and 

additional tests would add burden to 

manufacturers and test labs, without 

any corresponding benefit. (ALS, No. 24 

at p. 6) ALS further commented that if 

condensing clothes dryers have a 

genuine need to run additional test 

cycles, ALS could support such a 

requirement limited to condensing 

clothes dryers only. (ALS, No. 24 at p. 

6) AHAM supported a requirement for 

more than one clothes dryer test cycle, 

but stated that the number of test cycles 

should not be so high as to create a test 

burden. AHAM stated that it would 

offer to assist DOE in determining the 

appropriate number of cycles. AHAM 

commented that increasing the number 

of test cycles would increase the 

repeatability and reproducibility of the 

test. AHAM stated that the age of the 

test cloth during any given test was a 

source of inherent variability that could 

be accounted for by introducing a 

standard deviation into the related 

energy use calculations. AHAM 


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commented that accounting for 

variability is especially critical as 

regulatory bodies move toward 

requiring third-party verification, as the 

various test labs must be capable of 

reproducing results. (AHAM, No. 31 at 

p. 8) Whirlpool recommended that each 

unit or model be tested three times and 

the results averaged to account for testto-test variation. (Whirlpool, No. 27 at 

p. 4) The California Utilities/NRDC also 

commented that it would be more 

accurate, and good practice, to require 

multiple clothes dryer tests, but that 

they cannot provide any data at this 

time to indicate that doing so would 

greatly reduce test-to-test variation. 

(California Utilities/NRDC, No. 33 at 

p. 4) 

As discussed above, DOE is not aware 

of any data indicating that the test-totest variation is sufficient to warrant a 

requirement for more than one test cycle 

and the averaging of results. DOE is also 

unaware of any data suggesting that 

variability in the age of the test cloth 

increases the test-to-test variation of 

measured results for the clothes dryer 

test procedure. In addition, DOE 

conducted limited testing to evaluate 

the repeatability and reproducibility of 

the amended test procedure in today’s 

final rule. As shown below in Table 

III.10, the test-to-test variation ranged 

from 0 percent to 2.7 percent, with an 

average of 0.9 percent. For these 

reasons, DOE is not amending the test 

procedure in today’s final rule to require 

multiple test cycles. DOE would be 

open to considering such amendments 

in a future rulemaking if such data is 

made available showing that test-to-test 

variation is large enough to warrant 

multiple test cycles. 

TABLE III.10—DOE REPEATABILITY TESTING FOR AMENDED CLOTHES DRYER TEST PROCEDURE

Test unit 

Average EF lb/kWh Test-to-test 

variation 

Test 1 Test 2 Test 3 % 

Vented Electric Standard: 

Unit 1 ........................................................................................................ 3.67 3.70 3.71 1.1 

Unit 2 ........................................................................................................ 3.77 3.77 ........................ 0.0 

Unit 3 ........................................................................................................ 3.84 3.81 ........................ 0.8 

Unit 4 ........................................................................................................ 3.92 3.92 ........................ 0.0 

Unit 5 ........................................................................................................ 4.01 3.95 3.93 2.0 

Unit 6 ........................................................................................................ 3.74 3.71 3.71 0.8 

Vented Gas: 

Unit 7 ........................................................................................................ 3.36 3.36 ........................ 0.0 

Unit 8 ........................................................................................................ 3.38 3.42 ........................ 1.2 

Unit 9 ........................................................................................................ 3.47 3.38 ........................ 2.7 

Unit 11 ...................................................................................................... 3.52 3.49 ........................ 0.9 

Vented Electric Compact (240V): 

Unit 13 ...................................................................................................... 3.36 3.35 3.35 0.3

Vented Electric Compact (120V): 

Unit 14 ...................................................................................................... 3.74 3.74 ........................ 0.0 

Ventless Electric Compact (240V): 

Unit 15 ...................................................................................................... 2.71 2.66 2.70 1.9

Ventless Electric Combo Washer-Dryer: 

Unit 16 ...................................................................................................... 2.26 2.27 ........................ 0.4 

Unit 17 ...................................................................................................... 2.76 2.74 2.78 1.5

BSH commented that if DOE is 

proposing single tests rather than 

multiple tests with results averaged, 

many of the multiple test requirements, 

such as those for not removing a 

condenser or specifying a time period 

between tests, are irrelevant. BSH 

commented that if DOE decides to 

require multiple tests, it must define a 

set of test runs, and the condenser must 

be allowed to be removed and cleaned. 

Otherwise, the total number of test runs 

on a particular clothes dryer would be 

limited. (BSH, Public Meeting 

Transcript, No. 20 at p. 122) ACEEE 

commented that it is possible that if 

only one test cycle is required and the 

unit fails that test, more tests would 

need to be run on that unit. Therefore, 

provisions concerning multiple cycles 

would be needed. (ACEEE, Public 

Meeting Transcript, No. 20 at pp. 122– 

123) AHAM commented that the DOE 

test procedure does not have particular 

requirements for multiple test cycles, 

but in the general CFR there are 

requirements for the manufacturer to 

obtain repeatable and verifiable results. 

AHAM commented that DOE does not 

want to specify a minimum number of 

tests required, but a manufacturer may 

need to modify the condenser if they 

want or need to run multiple tests. 

(AHAM, Public Meeting Transcript, No. 

20 at pp. 123–124) BSH further 

commented that if a manufacturer 

decides it is only comfortable running 5 

or 10 tests, it would be reasonable to 

leave the condenser in place for that 

number of tests. (BSH, Public Meeting 

Transcript, No. 20 at p. 124) 

As discussed above, multiple test runs 

may be necessary in cases when a test 

run is considered invalid, such as when 

the drying cycle stops because the 

condensation box is full of water and 

the test must be re-run. Because there 

are cases in which multiple test cycles 

may be required, DOE adopts the 

amendments discussed above related to 

multiple test requirements (that is, that 

the condenser not be removed and that 

the door be kept closed between tests). 

DOE did not propose to measure the 

water consumption of ventless clothes 

dryers in the June 2010 TP SNOPR. 75 

FR 37594, 37624 (June 29, 2010). ALS 

objected to DOE’s proposal to not 

measure the water consumption of 

ventless ‘‘condensing’’ clothes dryers. 

ALS believes that if all clothes washers 

are required to meet strict standards 

regarding the amount of water 

consumed in a product that requires 

water to provide consumers with 

adequate utility, then a condensing 

clothes dryer must account for its water 

consumption as well. ALS commented 

that DOE needs to at least require that 

water consumption be measured and 

reported so that data is available for any 

future consideration of minimum 

standards for the water consumption of 

a condensing clothes dryer. (ALS, No. 

24 at p. 6) General Electric (GE) 

commented that it does not have data on 

how much water is consumed by 


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ventless clothes dryers that utilize an 

external water source to condense 

moisture from the dryer steam air. GE 

believes, however, that water 

consumption could be easily measured 

by placing a calibrated flow meter on 

the water source. GE believes it would 

not be burdensome to perform the 

measurement and that such 

measurements would provide a more 

meaningful, robust measure of water 

use. (GE, No. 32 at p. 1) Whirlpool 

commented that it is not aware of any 

ventless clothes dryers in the United 

States that utilize water in the 

condensing process, and that should 

such products exist, their market share 

would be so small as to be 

immeasurable. Whirlpool commented 

that it does not believe that measuring 

water consumption is relevant or 

necessary. (Whirlpool, No. 27 at p. 4) 

DOE notes that EPCA allows the 

establishment of water use metrics, but 

only for certain products. EPCA defines 

‘‘energy conservation standard’’ in 

relevant part as: 

(A) A performance standard which 

prescribes a minimum level of energy 

efficiency or a maximum quantity of 

energy use, or, in the case of 

showerheads, faucets, water closets, and 

urinals, water use, for a covered 

product, determined in accordance with 

test procedures prescribed under section 

6293 of this title; (42 U.S.C. 6291(6)(A)) 

In addition, DOE regulates the water use 

of clothes washers based on the water 

conservation standards set by Congress 

in 42 U.S.C. 6295(g)(9). 

Clothes dryers do not belong to the 

group of products specified by EPCA for 

which DOE can set a water use 

standard. As a result, DOE is not 

amending the clothes dryer test 

procedure in today’s final rule to 

establish a water use metric or to 

include a requirement to measure the 

water consumption for ventless 

condensing clothes dryers. 

DOE also stated that the results from 

DOE’s tests at an independent 

laboratory are representative of the 

repeatability of results that would be 

observed using the testing procedures 

proposed in the June 2010 TP SNOPR. 

75 FR 37594, 37624 (June 29, 2010). 

Although DOE’s tests were conducted 

using the alternate test procedure that 

provided separate definitions for a 

‘‘conventional clothes dryer’’ and a 

‘‘condensing clothes dryer’’ and that 

simply required use of the exhaust 

simulator only for vented clothes dryers, 

DOE stated that the additional 

clarifications proposed in the June 2010 

TP SNOPR would not significantly 

affect these testing results because they 

do not affect the the test cycle 

measurement method. Therefore, DOE 

stated that the amendments to the test 

procedure for ventless clothes dryers 

proposed in the June 2010 TP SNOPR 

would produce accurate and repeatable 

measurements of EF. Id. 

To further support its assertion, after 

issuance of the June 2010 TP SNOPR, 

DOE conducted three identical tests on 

one ventless electric compact (240V) 

clothes dryer and two identical tests on 

one ventless electric combination 

washer/dryer to evaluate the 

repeatability of the proposed test 

procedure for ventless clothes dryers. 

Testing results, presented in Table 

III.11, showed 0.8-percent and 3.5- 

percent variation in EF from test to test 

for the ventless electric compact (240V) 

and ventless electric combination 

washer-dryer, respectively. The test-totest variation shown below is 

comparable to the test-to-test variation 

shown in Table III.10 (conducted 

according to the alternate test procedure 

that provided separate definitions for a 

‘‘conventional clothes dryer’’ and a 

‘‘condensing clothes dryer’’ and that 

simply required use of the exhaust 

simulator only for vented clothes 

dryers). The slightly greater test-to-test 

variation observed in Table III.11 may 

be attributed to other test procedure 

tolerances, such as the allowable ranges 

in ambient temperature and relative 

humidity. DOE continues to believe that 

the amendments adopting in today’s 

final rule for ventless clothes dryers 

produce accurate and repeatable 

measurements of EF. 

TABLE III.11—DOE REPEATABILITY TESTING FOR VENTLESS CLOTHES DRYER AMENDMENTS

Test unit 

EF lb/kWh Test-to-test 

variation 

Test 1 Test 2 Test 3 % 

Ventless Electric Compact (240V) (Unit 15) .................................................... 2.36 2.38 2.37 0.8 

Ventless Electric Combo Washer-Dryer (Unit 16) ........................................... 2.05 1.98 ........................ 3.5 

4. Detergent Specifications for Clothes 

Dryer Test Cloth Preconditioning 

Section 2.6.3 of the current DOE 

clothes dryer test procedure specifies 

that the test cloth be preconditioned by 

performing a 10-minute wash cycle in a 

standard clothes washer using AHAM 

Standard Test Detergent IIA. 10 CFR 

part 430, subpart B, appendix D, section 

2.6.3. This detergent is obsolete and no 

longer available from AHAM or other 

suppliers. The current AHAM standard 

detergent is identified as AHAM 

standard test detergent Formula 3. 

Because AHAM Standard detergent IIA 

is no longer available to manufacturers, 

DOE proposed in the June 2010 TP 

SNOPR to amend section 2.6.3 of the 

clothes dryer test procedure to specify 

the use of AHAM standard test 

detergent Formula 3 in test cloth 

preconditioning. 75 FR 37594, 37624 

(June 29, 2010). 

Clothes washer tests that DOE 

conducted with AHAM standard test 

detergent Formula 3 suggest the dosage 

specified in section 2.6.3(2) of the DOE 

clothes dryer test procedure for AHAM 

Standard detergent IIA (6.0 grams (g) per 

gallon of water) may no longer be 

appropriate. This is because at the end 

of clothes washer test cloth 

preconditioning, which specifies the 

same dosage, undissolved clumps of 

detergent were observed in the cloth 

load. Further, DOE conducted extractor 

tests that indicate that detergent dosage 

impacts RMC measurements by as much 

as several percent. 

AHAM’s clothes dryer test procedure, 

AHAM HLD–1–2009, specifies a 

standard test detergent Formula 3 

dosage of 27 g + 4.0 g/lb of base test load 

for test cloth pre-treatment. For DOE’s 

clothes dryer test cloth preconditioning, 

the current test procedure specifies that 

clothes washer water fill level be set to 

the maximum level, regardless of test 

load size. In the June 2010 TP SNOPR, 

DOE proposed to amend the test load 

size for standard-size clothes dryers to 

8.45 lb ± .085 lb (see section III.C.5.c.), 

which would result in a detergent 

dosage of AHAM standard test detergent 

Formula 3 of 60.8 g. DOE stated that the 

detergent concentration should be set by 

the pounds of test cloth in this standardsize test load because this load is more 

closely matched to the maximum water 

fill level than is the compact-size test 

load (3.0 lb ± .03 lb). For 

preconditioning a compact-size test 

load, DOE proposed that the same 


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33See 62 FR 45484, 45498 (Aug. 27, 1997). 

34 KEMA, Inc. op. cit. p. 118. For more 

information visit: http://www.energy.ca.gov/

appliances/rass/. 

detergent dosage be specified because 

the water fill level would remain the 

same as for the larger load, resulting in 

the same concentration of the water/ 

detergent mixture. 75 FR 37594, 37624 

(June 29, 2010). 

To address the problems associated 

with the current dosage specification in 

the DOE clothes dryer test procedure, 

DOE proposed in the June 2010 TP 

SNOPR to amend section 2.6.3 of the 

clothes dryer test procedure. The 

amendment would require 60.8 g of 

AHAM standard test detergent Formula 

3 be used to precondition test cloth. Id. 

AHAM, Whirlpool, and ALS 

supported DOE’s proposed detergent 

specifications. (AHAM, No. 31 at p. 8; 

Whirlpool, No. 27 at p. 4; ALS, No. 24 

at p. 6) Whirlpool also strongly 

recommended that the test cloth be 

preconditioned in the same way when 

used in tests for both clothes washers 

and clothes dryers. This would enable 

test cloth with common characteristics 

to be interchanged between the two 

products, which would result in 

increased repeatability. (Whirlpool, No. 

27 at p. 4) For the reasons stated above 

and in the absence of comments 

objecting to this proposal, DOE amends 

its clothes dryer test procedure in 

today’s final rule to revise the detergent 

specifications for test cloth 

preconditioning as proposed in the June 

2010 TP SNOPR. 75 FR 37594, 37624 

(June 29, 2010). DOE will address 

detergent specifications for test cloth 

preconditioning for the clothes washer 

test procedure in the test procedure 

rulemaking for that product. 

5. Changes To Reflect Current Usage 

Patterns and Capabilities 

a. Clothes Dryer Number of Annual 

Cycles 

As noted above, DOE most recently 

amended its test procedure for 

residential clothes dryers in a final rule 

published in the Federal Register on 

May 19, 1981. 46 FR 27324. Although 

DOE has updated its test procedure for 

residential clothes washers since that 

time,33 it has not updated its residential 

clothes dryer test procedure. In the 

revised residential clothes washer test 

procedure, the average number of 

annual use cycles was revised to reflect 

current (at the time) consumer use 

patterns. DOE noted in the October 2007 

Framework Document that the average 

number of clothes dryer use cycles 

assumed in the revised clothes washer 

test procedure is different from the 

number of use cycles in the clothes 

dryer test procedure. (Framework 

Document, STD No. 1 at p. 4) 

In the June 2010 TP SNOPR, DOE 

reviewed available data to determine the 

number of annual clothes dryer use 

cycles so that it could amend its test 

procedure to accurately reflect current 

consumer usage habits. DOE reviewed 

the 2004 California Statewide RASS, 

which surveyed appliance product 

usage patterns, including clothes 

dryers.34 The study surveyed 7,686 

households between 2002 and 2003, 

asking the question ‘‘how many loads of 

clothes do you dry in your clothes dryer 

during a typical week?’’ For the 6,790 of 

these households that said they owned 

a clothes dryer, average usage was 4.69 

loads per week, or approximately 244 

loads per year. Because this study 

provides only a limited dataset, 

however, DOE stated in the June 2010 

TP SNOPR that it did not intend to rely 

only on this data to determine an 

appropriate number of annual use 

cycles for the clothes dryer test 

procedure. 75 FR 37594, 37625 (June 29, 

2010). 

In the June 2010 TP SNOPR, DOE also 

reviewed data from the 2005 RECS to 

determine the annual usage of clothes 

dryers. RECS is a national sample 

survey of housing units that collects 

statistical information on the 

consumption of and expenditures for 

energy in housing units along with data 

on energy-related characteristics of the 

housing units and occupants. RECS 

provides enough information to 

establish the type (that is, product class) 

of clothes dryer used in each household, 

the age of the product, and an estimate 

of the household’s annual energy 

consumption attributable to clothes 

dryers. DOE estimated the number of 

clothes dryer cycles per year for each 

sample home using data given by RECS 

on the number of laundry loads (clothes 

washer cycles) washed per week and the 

frequency of clothes dryer use. Based on 

its analysis of RECS data, DOE 

estimated the clothes dryer usage factor 

(the percentage of washer loads dried in 

a clothes dryer) to be 91 percent and the 

calculated average usage to be 283 

cycles per year for all product classes of 

clothes dryers. DOE also noted that the 

RECS data shows that the number of 

clothes washer and clothes dryer cycles 

has been decreasing steadily for a 

number of years to the extent that a 

historical trend has been established. 

Because this dataset is more extensive 

than that of the RASS, DOE believes 

these numbers are more representative 

of annual usage patterns. Therefore, 

DOE proposed in the June 2010 TP 

SNOPR to amend the number of annual 

use cycles in its test procedure to 283 

cycles for all product classes of clothes 

dryers. 75 FR 37594, 37625 (June 29, 

2010). 

AHAM supported DOE’s proposal to 

amend the number of annual use cycles 

to 283 cycles for all product classes of 

clothes dryers. AHAM stated, however, 

that it continues to oppose using 2005 

RECS data to support this change 

without verification of the RECS 

estimates. AHAM commented that the 

results from a recent survey by Procter 

& Gamble (P&G) indicated that 5.2 to 

5.35 loads per household with a clothes 

dryer are dried per week, or 279 clothes 

dryer loads per year. AHAM noted this 

number is similar to that derived from 

the 2005 RECS data and therefore, it 

supported the change in the number of 

clothes dryer annual use cycles to 283. 

(AHAM, No. 31 at p. 8; AHAM, Public 

Meeting Transcript, No. 20 at p. 137) 

The California Utilities/NRDC, the 

Joint Petitioners, Whirlpool, and ALS 

also commented in support of DOE’s 

proposal of 283 annual use cycles. 

(California Utilities/NRDC, No. 33 at p. 

5; Joint Petitioners, No. 30 at p. 7; 

Whirlpool, No. 27 at p. 4; ALS, No. 24 

at p. 7) The California Utilities/NRDC 

noted that the California 2005 RASS, 

which indicates a weighted-average for 

California of 235 annual use cycles is 

fairly consistent with DOE’s number 

and with the overall trend of decreasing 

yearly use cycles. (California Utilities/ 

NRDC, No. 33 at 

p. 5) Whirlpool also noted that in its 

April 26, 2010 comments that it 

recommended 288 cycles per year, 

which is essentially consistent with 

DOE’s recommendation of 283 cycles 

per year. (Whirlpool, No. 27 at p. 4) 

DOE notes there is close agreement 

between the estimates provided by 

interested parties and DOE’s estimate 

based on the data reviewed by DOE, and 

there were no comments objecting to its 

proposal. Therefore, DOE amends the 

clothes dryer test procedure to change 

the number of annual use cycles to 283 

cycles for all product classes of clothes 

dryers. 

b. Clothes Dryer Initial Remaining 

Moisture Content 

In the revised residential clothes 

washer test procedure, a new parameter, 

the RMC of the test cloth, was 

introduced. 68 FR 62198, 62199 

(October 31, 2003). The clothes washer 

RMC is the ratio of the weight of water 

contained within the test load at the 

completion of the clothes washer energy 

test cycle to the bone-dry weight of the 


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35AHAM, 2009. AHAM Weighted RMC for Front 

Load and Top Load Units, 2000–2008—DOE 

Clothes Dryer Rulemaking, Secondary Data 

Request. July 7, 2009. Docket No. EE–2007–BT– 

STD–0010, Comment Number 18. 

test load, expressed as a percent. 

Correspondingly, the initial RMC of a 

clothes load being dried is a function of 

RMC at the end of a clothes washer 

cycle. The current DOE clothes dryer 

test procedure specifies an initial RMC 

of 70 ± 3.5 percent. Similar to the 

discussion above of the average number 

of use cycles per year, the RMC of 

typical clothes loads in the residential 

clothes washer test procedure should be 

consistent with values defined in the 

clothes dryer test procedure. For the 

reasons explained below, however, DOE 

believes that the initial RMC in the 

clothes dryer test procedure may not 

reflect typical RMCs of actual clothes 

dryer loads. 

DOE notes that the revision to the 

clothes washer test procedure changed 

the clothes washer energy conservation 

standards metric to a modified energy 

factor (MEF). This established a method 

for measuring the RMC for clothes 

washers. This RMC is then used to 

estimate the energy required by a 

clothes dryer to dry the clothes load. 

This estimate is then factored in to the 

calculation of MEF to account for 

clothes washers that reduce the 

estimated energy required to dry the 

clothes load in a clothes dryer. (10 CFR 

part 430, subpart B, appendix J1, section 

4.3) Since the clothes dryer test 

procedure was last amended in 1981 

(46 FR 27324 (May 19, 1981)), average 

clothes washer RMC has decreased due 

to the introduction of higher efficiency 

models with higher final spin speeds. 

Therefore, while clothes dryer energy 

use has decreased with the lower RMC, 

clothes washer energy use has increased 

somewhat to achieve the higher spin 

speeds. This energy use is accounted for 

in the residential clothes washer energy 

conservation standards rulemaking. In 

the clothes washer test procedure final 

rule published in the Federal Register 

on January 12, 2001, DOE estimated 

RMCs at specific efficiency levels. 66 FR 

3314. For the residential clothes washer 

standard which became effective 

January 1, 2007 (1.26 MEF), DOE 

estimated a weighted-average RMC of 56 

percent. 

As discussed in section I, the EF for 

clothes dryers is determined by 

measuring the total energy required to 

dry a standard test load of laundry to a 

‘‘bone dry’’ state. If today’s clothes dryer 

loads have initial RMCs lower than the 

nominal 70 percent specified in the 

existing DOE clothes dryer test 

procedure, revisions to the test 

procedure to reflect more realistic (that 

is, lower) RMCs would result in the 

current EF rating increasing for a given 

clothes dryer. This is because the 

clothes dryer would have less water to 

remove. 

As part of the preliminary analyses for 

the residential clothes dryer energy 

conservation standards rulemaking, 

DOE used a distribution of values for 

models listed in the December 12, 2008 

CEC product database to estimate the 

RMC of clothes washers. For products 

for which the RMC was listed, DOE 

noted in the June 2010 TP SNOPR that 

the RMC values ranged from 30 percent 

to 61 percent, with an average of 46 

percent. 75 FR 37594, 37626 (June 29, 

2010). 

As part of the October 2007 

Framework Document, DOE requested 

data from AHAM showing the 

shipments of residential clothes washers 

for which RMC was reported, along with 

shipment-weighted RMC (See Table 

III.12). These data sets, each including 

disaggregated data for front-loading and 

top-loading clothes washers, as well as 

reported overall values for all units, 

provide insight into what initial clothes 

dryer RMC would be most 

representative of current residential 

clothes washers. As noted above, 

however, AHAM indicated that the data 

contain only shipments for which the 

RMC was reported, and thus the total 

will not be equal to actual shipments 

reported for 2000–2008. The data 

indicate that RMC has been decreasing 

consistently, from about 54 percent in 

2000 to 47 percent in 2008. The data 

also suggest that the initial RMC of 

nominally 70 percent in the DOE 

clothes dryer test procedure is greater 

than the current shipment-weighted 

residential clothes washer average RMC. 

TABLE III.12—AHAM SHIPMENT-WEIGHTED CLOTHES WASHER RMC DATA SUBMITTAL 35

Year 

Clothes washer shipments for which RMC 

was reported 

Shipment-weighted RMC 

(%) 

Frontloading Top-loading Total Frontloading Top-loading Total 

2000 ................................................................................. 232,714 686,440 919,154 43.6 57.4 53.9 

2001 ................................................................................. 235,989 473,629 709,618 41.3 57.7 52.2 

2002 ................................................................................. 280,667 529,265 809,932 41.5 58.1 52.3 

2003 ................................................................................. 351,411 1,676,877 2,028,288 43.1 54.5 52.5

2004 ................................................................................. 1,179,813 5,270,285 6,450,098 42.2 52.8 50.9 

2005 ................................................................................. 1,563,108 5,394,511 6,957,619 40.8 52.7 50.1 

2006 ................................................................................. 1,851,218 5,628,279 7,479,497 39.3 51.4 48.4 

2007 ................................................................................. 1,973,825 5,371,142 7,344,967 38.3 51.4 47.8 

2008 ................................................................................. 2,043,024 4,492,059 6,535,083 38.1 51.0 47.0 

Based on its analysis of the shipmentweighted RMC data submitted by 

AHAM, as well as its own review of the 

CEC residential clothes washer 

database, DOE stated in the June 2010 

TP SNOPR that an initial RMC of 47 

percent is representative of current 

residential clothes dryer initial test load 

characteristics. Therefore, DOE 

proposed to amend section 2.7, ‘‘Test 

loads,’’ of the clothes dryer test 

procedure to require the initial RMC be 

changed from 70 ± 3.5 percent to 47 

percent. DOE further proposed to 

eliminate the ± 3.5 percent allowable 

range in RMC. This is because the 

proposed amendments to the DOE 

clothes dryer test procedure for 

automatic cycle termination, detailed in 

section III.C.2, would require that the 

test load be initially prepared to 

between 42- and 47-percent RMC. The 

proposed amendments would also 

require final adjustments be made to the 

RMC to achieve 47-percent ± 0.33- 

percent RMC to account for over-drying 

energy consumption. 75 FR 37594, 

37627 (June 29, 2010). 

In the June 2010 TP SNOPR, DOE 

proposed that if it does not adopt the 

proposed amendments for testing 

automatic cycle termination, but adopts 

only these aforementioned proposed 


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amendments to change the initial RMC, 

it could specify an initial RMC of 47 ± 

3.5 percent. In that case, the tolerance 

of ± 3.5 percent on the nominal initial 

RMC, as currently specified in DOE’s 

test procedure, would allow the same 

flexibility in test cloth preparation as is 

currently allowed. 75 FR 37594, 37627 

(June 29, 2010). 

DOE also noted in the June 2010 TP 

SNOPR that the current test procedure 

contains a provision in the calculation 

of per-cycle energy consumption 

intended to normalize EF by the 

reduction in RMC over the course of the 

drying cycle. A scaling factor of 66 is 

applied, representative of the percentage 

change from the nominal initial RMC of 

70 percent to the nominal ending RMC 

of 4 percent. DOE noted, however, that 

the proposed changes to account for 

automatic cycle termination, as 

presented above in section III.C.2, 

would require amending the 

calculations for the per-cycle energy 

consumption to remove the need for this 

scaling factor. Therefore, DOE did not 

propose to amend the scaling factor in 

the June 2010 TP SNOPR. 75 FR 37594, 

37627 (June 29, 2010). DOE proposed 

that if it does not adopt the proposed 

amendments for testing automatic cycle 

termination, but adopts only these 

aforementioned proposed amendments 

to change the initial RMC, it could 

change the scaling factor to 43 to reflect 

a starting RMC of 47 percent. Id. 

AHAM, the California Utilities/NRDC, 

and the Joint Petitioners all supported 

an initial RMC of 47 percent. (AHAM, 

No. 31 at p. 9; California Utilities/ 

NRDC, No. 33 at p. 5; Joint Petitioners, 

No. 30, at p. 7) AHAM provided data to 

support this approach in their April 26, 

2010 comments. (AHAM, No. 31 at p. 9) 

Whirlpool also commented that DOE’s 

proposal of 47 ± 1 percent RMC is 

consistent with its recommendation 

from its April 26, 2010 comments. 

(Whirlpool, No. 27 at p. 4) 

ALS objected to DOE’s proposal to 

utilize 47-percent initial RMC. ALS 

commented that the current clothes 

dryer test procedure uses ‘‘raw’’ noncorrection factored RMC values, unlike 

the values DOE used to arrive at the 

national average of 47-percent RMC. 

The data DOE used was based on 

shipment-weighted average clothes 

washer data supplied by AHAM that 

had a correction factor applied to 

account for extraction. (ALS, No. 24 at 

p. 7; ALS, Public Meeting Transcript, 

No. 20 at p. 141) ALS commented that 

DOE should be using raw RMC values 

from the clothes washer, because the 

current clothes dryer test uses raw 

values and there is a significant 

difference between ‘‘raw’’ RMC values 

and ‘‘correction-factored’’ RMC values. 

ALS stated that it conducted tests on 

front-load washers (both its own and 

those of its competition) that resulted in 

raw RMC values of around 50 percent, 

compared to the 41-percent RMC 

derived when the correction factor is 

applied. This is a difference of 9 RMC 

percentage points, which is a 18-percent 

relative difference. ALS added that it is 

apparent that if ‘‘raw’’ values of washer 

RMC were analyzed by DOE, the 

national average would be closer to 53– 

55 percent. ALS acknowledged that no 

database exists of ‘‘raw’’ shipmentweighted average RMC values for 

clothes washers. ALS suggested DOE 

perform limited clothes washer tests to 

confirm the ALS results regarding the 

‘‘raw’’ versus ‘‘correction-factored’’ RMC 

values, and adjust the proposed 47- 

percent value to align more closely to 

the ALS-suggested value of 53 percent. 

(ALS, No. 24 at p. 7) ALS also 

commented that manufacturers prefer to 

utilize their own production frontloading clothes washers to prepare test 

loads per the DOE clothes dryer test 

procedure. However, they would find it 

more difficult to achieve DOE’s 

proposed 47-percent RMC when the 

front-loader in their labs can only 

achieve raw values at 50-percent RMC 

in default DOE test program cycles. 

(ALS, No. 24 at p. 7) ALS did not 

recommend adding in correction factors 

to the clothes dryer test procedure to 

raise the initial RMC higher to reflect 

the uncorrected value. (ALS, Public 

Meeting Transcript, No. 20 at p. 143) 

DOE first notes that it proposed an 

initial RMC of 47 percent ± 3.5 percent, 

not ±1 percent as commented by 

Whirlpool. DOE agrees with ALS that 

the clothes dryer test procedure should 

be using a ‘‘raw’’ uncorrected RMC value 

and not the corrected RMC values in the 

data submitted by AHAM. DOE 

understands that in the clothes washer 

test procedure, an RMC correction factor 

curve is applied to account for the 

different extraction rates of different test 

cloth lots in order to calculate a 

corrected RMC value. The correction 

factor curve uses the following equation: 

RMCcorrected = A × RMCmeasured + B, where 

RMCmeasured is the measured RMC after 

the clothes washer spin cycle and A and 

B are coefficients based on extraction 

testing using a linear least-squares fit to 

relate the standard RMC to the 

measured extraction RMC value. (The 

standard RMC is provided in table 

2.6.6.1 of the clothes washer test 

procedure.) DOE notes that in 2008, the 

latest year for which shipment-weighted 

average corrected RMC values were 

provided in the AHAM data, the most 

recent test cloth lot was lot 16. DOE 

acknowledges, however, that 

manufacturers and testing labs were 

likely using previous test cloth lots for 

the RMC values reported in the AHAM 

data. For this reason, DOE estimated the 

2008 uncorrected RMC value by using 

the RMC correction factor curves from 

lots 12 through 16 and averaging the 

results. As shown in Table III.13, the 

results showed an average uncorrected 

RMC value of 57.5 percent. 

TABLE III.13—DOE CLOTHES WASHER TEST PROCEDURE TEST CLOTH LOT RMC CORRECTION FACTOR DATA

Lot # Coefficient A Coefficient B 

2008 Shipment-weighted 

average uncorrected RMC 

(percent) 

2008 Shipment- 12 0.7165 0.0505 65.5 

Weighted 13 0.8828 0.0015 53.2 

Average 14 0.8970 0.0014 52.4 

Corrected RMC 15 0.89904 -0.04284 52.3 

= 47.0% 16 0.73478 0.03174 63.9 

Average ............................................. ............................................. 57.5 

To validate this estimate, DOE 

examined the uncorrected RMC data 

from tests of 17 residential clothes 

washer (9 front-loading and 8 toploading units) it conducted for the 

residential clothes washer energy 

conservation standards rulemaking 

preliminary analyses. The results from 

DOE’s testing are shown below in Table 

III.14. Taking the average RMC for each 

product class (that is, front-loading and 

top-loading) and weighting the average 


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RMCs by the shipments for each 

product class resulted in a shipmentweighted average uncorrected RMC of 

58.1 percent, which is in close 

agreement with the 57.5-percent 

uncorrected RMC estimated by DOE 

using the RMC correction factor curves. 

TABLE III.14—DOE CLOTHES WASHER

TESTING UNCORRECTED RMC RESULTS

Test unit Uncorrected 

RMC % 

Front-Loading Clothes Washers (2008 Shipments = 

3,022,077): 

Unit 1 ................................. 43.7 

Unit 2 ................................. 58.9 

Unit 3 ................................. 55.9 

Unit 4 ................................. 49.3 

Unit 5 ................................. 49.5 

Unit 6 ................................. 38.5 

Unit 7 ................................. 50.7 

Unit 8 ................................. 45.3 

Unit 9 ................................. 45.4 

Top-Loading Clothes Washers (2008 Shipments = 

5,269,625): 

Unit 10 ............................... 67.7 

TABLE III.14—DOE CLOTHES WASHER

TESTING UNCORRECTED RMC RESULTS—Continued 

Test unit Uncorrected 

RMC % 

Unit 11 ............................... 94.3 

Unit 12 ............................... 48.4 

Unit 13 ............................... 60.5 

Unit 14 ............................... 65.2 

Unit 15 ............................... 67.1 

Unit 16 ............................... 54.2 

Unit 17 ............................... 50.3 

Shipment-Weighted Average ................................. 58.1 

DOE estimated the uncorrected RMC 

value using shipment-weighted average 

corrected RMC data submitted by 

AHAM and the RMC correction factor 

curves for test cloth lots 12 through 16. 

Based on that estimate, DOE believes an 

initial RMC of 57.5 percent more 

accurately represents the moisture 

content of a load entering the clothes 

dryer after the wash cycle for the 

purposes of clothes dryer testing. As a 

result, DOE amends the clothes dryer 

test procedure in today’s final rule to 

change the initial RMC to 57.5 percent 

± 3.5 percent. In addition, DOE changes 

the scaling factor in the calculation of 

the per-cycle energy consumption that 

is intended to normalize EF by the 

reduction in RMC over the course of the 

drying cycle from a value of 66 to 53.5 

(That value is the difference of 57.5- 

percent initial RMC minus 4-percent 

nominal final RMC). 

DOE tested 13 representative clothes 

dryers to evaluate the affect of this 

amendment to the initial RMC for 

clothes dryer test load preparation on 

test repeatability. DOE tested these units 

according to the current DOE clothes 

dryer test procedure, except that the 

initial RMC was changed to 57.5 percent 

± 3.5 percent. For the ventless clothes 

dryer test units, DOE additionally used 

the proposed testing method for ventless 

dryers presented in section III.C.3. As 

shown below in Table III.15, the test-totest variation ranged from 0.3 percent to 

1.8 percent, with an average of 0.9 

percent. For this reason, DOE believes 

that the amendments to the initial RMC 

for clothes dryer test load preparation 

produce repeatable test results. 

TABLE III.15—DOE REPEATABILITY TESTING FOR 57.5 PERCENT INITIAL RMC 

Test unit 

Average EF lb/kWh Test-to-test 

variation % Test 1 Test 2 Test 3 

Vented Electric Standard: 

Unit 1 .................................................................................................................................... 3.68 3.67 ................ 0.3 

Unit 3 .................................................................................................................................... 3.84 3.81 3.82 0.8 

Unit 4 .................................................................................................................................... 3.79 3.80 3.78 0.5 

Unit 5 .................................................................................................................................... 3.93 3.88 3.92 1.3 

Unit 6 .................................................................................................................................... 3.70 3.71 ................ 0.3 

Vented Gas: 

Unit 7 .................................................................................................................................... 3.32 3.32 3.31 0.3 

Unit 8 .................................................................................................................................... 3.41 3.44 ................ 0.9 

Unit 9 .................................................................................................................................... 3.23 3.21 3.25 1.2 

Unit 10 .................................................................................................................................. 3.27 3.31 3.28 1.2 

Unit 11 .................................................................................................................................. 3.38 3.41 3.43 1.5 

Vented Electric Compact (240V): 

Unit 12 .................................................................................................................................. 3.61 3.62 3.61 0.3 

Unit 13 .................................................................................................................................. 3.46 3.48 3.42 1.8 

Ventless Electric Combo Washer-Dryer: 

Unit 16 .................................................................................................................................. 2.35 2.31 2.34 1.7 

c. Clothes Dryer Test Load Weight 

The current DOE clothes dryer test 

procedure requires a 7.00 lb ± .07 lb test 

load for standard-size clothes dryers and 

a 3.00 lb ± .03 lb test load for compactsize clothes dryers. In response to 

comments it received on the October 

2007 Framework Document, DOE 

investigated in the June 2010 TP SNOPR 

whether the average test load weight for 

standard-size clothes dryers is valid for 

use in light of the capacities of the 

current generation of clothes washer. 75 

FR 37594, 37631 (June 29, 2010). 

DOE contacted detergent 

manufacturers to obtain data on average 

residential clothes washer load sizes. 

P&G conducted an internal study in 

2003 on household laundry habits on a 

representative set of the population 

across the United States, from which 

P&G provided relevant summary data to 

DOE for this rulemaking. The clothes 

washer load weight data, based on a 

sample size of 3367 loads of laundry 

from a total of 510 respondents, showed 

that the average load size for top-loading 

and front-loading clothes washers was 

7.2 lb and 8.4 lb, respectively. (P&G, No. 

15 at p. 1) Based on the average 

shipment-weighted market share for 

top-loading and front-loading clothes 

washers between 2000 and 2008 from 

data submitted by AHAM (shown in 

Table III.12), the shipment-weighted 

average clothes washer load size would 

be approximately 7.5 lb. DOE stated in 

the June 2010 TP SNOPR, however, that 

clothes washer capacities were likely to 

have increased since the survey was 

conducted in 2003. Therefore, DOE 

factored into its analysis these capacity 

changes to estimate a more current 


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36Association of Home Appliance Manufacturers, 

Trends in Energy Efficiency 2008. p. 3. Washington, 

DC. Available at: http://www.aham.org/ht/d/Store. 

average load size. 75 FR 37594, 37631 

(June 29, 2010). 

Table III.16 shows the trends of the 

shipment-weighted average tub volume 

for residential clothes washers from 

1981 to 2008, based on data from the 

AHAM Trends in Energy Efficiency 

2008. The shipment-weighted average 

tub volume has increased from 2.52 ft3

in 1981 to 3.22 ft3 in 2008. 

TABLE III.16—RESIDENTIAL CLOTHES

WASHER SHIPMENT-WEIGHTED AVERAGE TUB VOLUME TRENDS 36

Year 

Shipmentweighted 

average tub 

volume (ft3) 

% Change 

since 1990 

1981 .................. 2.52 ....................

1990 .................. 2.63 ....................

1991 .................. 2.72 3.4 

1992 .................. 2.71 3.0 

TABLE III.16—RESIDENTIAL CLOTHES

WASHER SHIPMENT-WEIGHTED AVERAGE TUB VOLUME TRENDS 36— 

Continued 

Year 

Shipmentweighted 

average tub 

volume (ft3) 

% Change 

since 1990 

1993 .................. 2.71 3.0 

1994 .................. 2.69 2.3 

1995 .................. 2.72 3.4 

1996 .................. 2.80 6.5 

1997 .................. 2.83 7.6 

1998 .................. 2.85 8.4 

1999 .................. 2.89 9.9 

2000 .................. 2.92 11.0 

2001 .................. 2.96 12.5 

2002 .................. 2.96 12.5 

2003 .................. 3.01 14.4 

2004 .................. 3.05 16.0 

2005 .................. 3.08 17.2 

2006 .................. 3.13 19.2 

2007 .................. 3.16 20.3 

TABLE III.16—RESIDENTIAL CLOTHES

WASHER SHIPMENT-WEIGHTED AVERAGE TUB VOLUME TRENDS 36— 

Continued 

Year 

Shipmentweighted 

average tub 

volume (ft3) 

% Change 

since 1990 

2008 .................. 3.22 22.4 

Section 2.7, ‘‘Test Load Sizes,’’ in the 

DOE clothes washer test procedure 

provides the minimum, maximum, and 

average test load size requirements for 

the clothes washer test, which are based 

on the clothes container capacity. Table 

III.17 shows the minimum, maximum, 

and average test load sizes for 2.52 ft3

and 3.22 ft3 container capacities 

according to Table 5.1 in the DOE 

clothes washer test procedure. 

TABLE III.17—DOE CLOTHES WASHER TEST LOAD SIZE REQUIREMENTS (FROM TABLE 5.1 OF 10 CFR 430 SUBPART B, 

APPENDIX J1) 

Container volume ft3 Minimum 

load lb. 

Maximum 

load lb. 

Average 

load lb. 

≥ 2.50 to < 2.60 ................................................................................................................................................... 3.00 10.50 6.75 

≥ 3.20 to < 3.30 ................................................................................................................................................... 3.00 13.30 8.15 

DOE notes that the average load size 

in the clothes washer test procedure 

increases by about 21 percent when the 

container volume increases in capacity, 

which DOE believes is the degree to 

which container volume impacts clothes 

dryer load sizes. Applying this ratio of 

average clothes washer test load sizes to 

the clothes dryer test load size would 

result in an increase from 7.00 lb to 8.45 

lb for standard-size clothes dryers 

currently available. For these reasons, 

DOE proposed to amend the clothes 

dryer test load size to 8.45 lb for 

standard-size clothes dryers in the June 

2010 TP SNOPR. 75 FR 37594, 37632 

(June 29, 2010). DOE proposed to amend 

the test load size based on the change 

in average load size for clothes washers 

rather than the maximum load size 

because data from the 2005 RECS 

indicates that not all clothes that are 

washed are machine dried. Therefore, 

DOE believes that average clothes 

washer load size would be more 

representative of clothes dryer load size. 

DOE also proposed to maintain the 1- 

percent tolerance in load sizes specified 

by the current DOE test procedure for 

standard-size clothes dryers (8.45 lb ± 

.085 lb). Id. 

ALS commented that the clothes 

dryer test procedure amendments are 

related to the clothes washer test 

procedure. It stated that if there are any 

changes to the clothes washer test 

procedure in an upcoming rulemaking, 

especially to the average load size or the 

load size chart, the effect of those 

changes on the clothes dryer test 

procedure must be considered. (ALS, 

Public Meeting Transcript, No. 20 at p. 

171) DOE recently published a NOPR 

proposing amendments to the test 

procedure for clothes washers and 

welcomes comments on that proposal as 

stated in the NOPR. 75 FR 57556 

(September 21, 2010). Because DOE has 

not published a final rule amending the 

clothes washer test procedure, however, 

the issue of how any such amendments 

might influence conditions for the final 

amended clothes dryer test procedure is 

not relevant at this time. DOE may 

consider this issue in a future 

rulemaking. 

AHAM, Whirlpool, ALS, the 

California Utilities/NRDC, and the Joint 

Petitioners commented in support of the 

proposed amendment to change the 

clothes dryer load size to 8.45 ± 0.085 

lb for standard-size clothes dryers. 

(AHAM, No. 31 at p. 9; Whirlpool, No. 

27 at p. 5, ALS, No. 24 at p. 7, California 

Utilities/NRDC, No. 33 at p. 5, Joint 

Petitioners, No. 30 at p. 7) For the 

reasons stated above and in the absence 

of comment objecting to this proposal, 

DOE amends the clothes dryer test 

procedure in today’s final rule to change 

the clothes dryer load size to 8.45 ± 

0.085 lb for standard-size clothes dryers. 

DOE stated in the June 2010 TP 

SNOPR that most compact clothes 

dryers are used with compact-size 

clothes washers, and that DOE does not 

have any information to suggest that the 

tub volume of such clothes washers has 

changed significantly. Therefore, DOE 

did not propose to change the 3-lb test 

load size currently specified in the test 

procedure for compact clothes dryers in 

the June 2010 TP SNOPR. DOE sought 

data on the historical trends of compactsize clothes washer average tub volumes 

or any other data that would suggest a 

change in the clothes dryer test load size 

for compact clothes dryers. 

AHAM and the Joint Petitioners 

commented in support of maintaining 

the 3-lb load size for compact clothes 

dryers until there is sufficient data upon 

which to base a change. (AHAM, No. 31 


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37U.S. Department of Energy—Office of Energy 

Efficiency and Renewable Energy, Technical 

Support Document for Energy Conservation 

Standards for Room Air Conditioners. September 

1997. Chapter 1, section 1.5. Washington, DC. 

http://www.eere.energy.gov/buildings/appliance_

standards/residential/room_ac.html. 

38CDD is a sum of the difference between 

ambient temperature in °F and 65 °F for every hour 

of the year that the ambient temperature is higher 

than 65 °F for a given location, divided by 24 to 

convert from hours to days; DOE used data on CDD 

from the National Solar Radiation Database 

(NSRDB). National Renewable Energy Laboratory, 

National Solar Radiation Database 1991–2005 

Update: User’s Manual, 2007. Golden, CO. 

Available online at: http://www.nrel.gov/docs/ 

fy07osti/41364.pdf. 

39Energy Information Administration, 2006 State 

Energy Consumption, Price, and Expenditure 

Estimates (SEDS), 

2006. Washington, DC. Available online at: http:// 

www.eia.doe.gov/emeu/states/_seds.html. 

at p. 9; Joint Petitioners, No. 30 at p. 7) 

For these reasons, DOE is not amending 

the test procedure to change the load 

size for compact clothes dryers. 

DOE tested 8 representative clothes 

dryers to evaluate the affect of this 

amendment to the test load weight for 

standard-size clothes dryers on test 

repeatability. DOE tested these units 

according to the current DOE clothes 

dryer test procedure, except that the test 

load size was changed to 8.45 lb ± .085 

lbs for standard-size clothes dryers. As 

shown below in Table III.18, the test-totest variation ranged from 0.0 percent to 

2.9 percent, with an average of 1.6 

percent. For this reason, DOE believes 

that the amendments to the test load 

weight in the clothes dryer test 

procedure produce repeatable test 

results. 

TABLE III.18—DOE REPEATABILITY TESTING FOR 8.45 LB ± .085 LB TEST LOAD FOR STANDARD-SIZE CLOTHES DRYERS

Test unit 

Average EF lb/kWh Test-to-test 

variation % Test 1 Test 2 

Vented Electric Standard: 

Unit 1 ........................................................................................................................................................ 3.13 3.13 0.0 

Unit 4 ........................................................................................................................................................ 3.20 3.27 2.2 

Unit 6 ........................................................................................................................................................ 3.53 3.47 1.7 

Unit 7 ........................................................................................................................................................ 3.33 3.34 0.3 

Unit 8 ........................................................................................................................................................ 3.18 3.09 2.9 

Vented Gas: 

Unit 10 ...................................................................................................................................................... 2.85 2.86 0.4 

Unit 11 ...................................................................................................................................................... 2.96 2.89 2.4 

Unit 13 ...................................................................................................................................................... 2.81 2.73 2.9 

d. Room Air Conditioner Annual 

Operating Hours 

The DOE test procedure currently 

assumes room air conditioners have an 

average annual use of 750 hours. DOE’s 

technical support document from 

September 1997, issued in support of 

the most recent room air conditioner 

energy conservation standards 

rulemaking, shows that the average 

annual operational hours are closer to 

500 hours.37 That average would yield 

approximately 33-percent lower annual 

energy consumption than the annual 

energy consumption determined using 

the 750 operational hours assumed in 

the current test procedure. 

DOE acknowledged the uncertainty 

regarding room air conditioner usage 

patterns and investigated the annual 

hours of usage from a range of 

information sources to develop an 

updated estimate of annual operating 

hours for the June 2010 TP SNOPR. 75 

FR 37594, 37633 (June 29, 2010). DOE’s 

investigation revealed a lack of metered 

and survey data for the operating hours 

of individual room air conditioners. 

DOE found that estimates of the annual 

operating hours of use were often based 

on regional climatic data rather than 

actual room air conditioner use. DOE 

did find two sources of survey data on 

room air conditioner use in the EIA’s 

2005 RECS (and previous versions) and 

the CEC California Statewide RASS. The 

CEC survey contained only aggregated 

residential data, which limited any 

analysis pertaining to the annual 

operating hours. EIA’s 2005 RECS 

provides extensive data on individual 

residences, while providing a more 

expansive and representative sample of 

households. Thus, DOE continued its 

analysis using EIA’s 2005 RECS. Id. 

The 2005 RECS provides enough 

information to establish the type (that is, 

product class) of room air conditioner 

used in each household, the age of the 

product, and an estimate of the 

household’s annual energy consumption 

attributable to the room air conditioner. 

Using this data, DOE developed an 

estimate of the annual hours of use of 

a room air conditioner in a household. 

This estimate was used to calculate a 

weighted national average of room air 

conditioner usage hours. The data in the 

2005 RECS indicates that the estimated 

room air conditioner average annual 

usage is 810 hours. DOE noted in the 

June 2010 TP SNOPR that this number 

of hours is higher than the current 750 

hours specified in the test procedure. It 

is also significantly higher than the 

approximately 500 hours suggested by 

the previous energy conservation 

standard rulemaking analysis. Id. 

An investigation of the 2005 cooling 

season covered by RECS indicates that 

there were roughly 12-percent more 

cooling degree days (CDD) in 2005 than 

the 30-year 1971 to 2000 average.38 The 

Annual Energy Outlook projections of 

CDD for the future suggest that the 

higher level of CDD will continue.39

Hence, the predictions of annual hours 

based on the 2005 RECS can be 

considered representative of future 

usage. Further, DOE stated in the June 

2010 TP SNOPR, however, it does not 

consider the increase of 60 hours from 

750 hours to 810 hours to be significant. 

This is because that increase does not 

exceed the uncertainty level associated 

with the RECS-based approach for 

estimation of this value. Hence, DOE 

did not propose a change in the annual 

operating hours used in the test 

procedure in the June 2010 TP SNOPR. 

75 FR 37594, 37633 (June 29, 2010). 

AHAM commented that it strongly 

opposes relying on the RECS data. 

(AHAM, No. 31 at pp. 9–10) AHAM 

stated that it is becoming more difficult 

to get survey data on room air 

conditioners as more people rely on 

central air conditioning and because 

room air conditioners are being used 

more for space cooling or assistance 

cooling rather than primary cooling. 

AHAM also commented that consumers 

tend to buy room air conditioners that 

are oversized for the cooling space, 

resulting in fewer use-hours than if they 

had purchased a unit that was sized 

appropriately. (AHAM, Public Meeting 

Transcript, No. 20 at pp. 151–152) 

AHAM believes data are available, and 

that DOE should use such data for its 


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analysis. (AHAM, Public Meeting 

Transcript, No. 20 at pp. 152–154) 

AHAM also supported maintaining the 

current 750 annual operating hours used 

in the test procedure for room air 

conditioners until or unless additional 

reliable surveys or testing are completed 

that determine a more representative 

number of use hours for room air 

conditioners exists. (AHAM, No. 31 at 

pp. 9–10; AHAM, Public Meeting 

Transcript, No. 20 at p. 150) The 

California Utilities/NRDC also 

supported DOE’s allocation of 750 hours 

per year to active cooling, adding that 

this allocation seems reasonable given 

available data. However, the California 

Utilities/NRDC stated that DOE may 

need to revise this allocation in light of 

its proposed treatment of fan-only 

energy. (California Utilities/NRDC, No. 

33 at p. 4) 

DOE understands the uncertainties 

associated with RECS data, but believes 

that the estimates using such data 

generally support maintaining the 

current 750 annual operating hours. As 

discussed in section III.B.4, DOE is not 

amending the test procedure in today’s 

final rule to account for fan-only active 

mode energy use, but may consider 

amendments to address fan-only active 

mode in a future rulemaking as data 

become available. For these reasons, 

DOE maintains the current 750 annual 

operating hours used in the test 

procedure for room air conditioners. 

DOE may consider revising this number 

of annual operating hours if data are 

made available indicating that a change 

in this value is warranted. 

e. Room Air Conditioner Part-Load 

Performance 

DOE noted in the October 2007 

Framework Document that the current 

DOE room air conditioner test 

procedure measures full-load 

performance and does not assess energy 

savings associated with technologies 

that improve part-load performance. 

DOE concluded in the June 2010 TP 

SNOPR that widespread use of part-load 

technology in room air conditioners is 

not likely to be stimulated by the 

development of a part-load metric at 

this time, and therefore, the significant 

effort required to develop an accurate 

part-load metric is not likely to be 

warranted by the expected minimal 

energy savings. 75 FR 37594, 37633–34 

(June 29, 2010). A part-load metric 

would measure efficiency of a product 

when operating at conditions other than 

maximum capacity, with outdoor or 

indoor conditions cooler than currently 

used in the DOE active mode energy 

test, or both. In field use of room air 

conditioners using currently available 

technologies, when enough cooling is 

provided to the space, any number of 

events can occur to prevent overcooling. For example, the user may turn 

off the unit or adjust fan speed; or the 

controls might turn off the compressor, 

turn off both the compressor and the 

fan, or reduce fan speed. Delivery of 

cooling might be done more efficiently 

with part-load technologies, such as a 

compressor that can adjust its capacity 

rather than cycling on and off, but 

sufficient information is not available at 

this time regarding use of room air 

conditioner features to assess whether 

those alternative technologies would be 

cost effective. DOE notes that the key 

design changes that improve full-load 

efficiency also improve part-load 

efficiency, so the existing EER metric is 

already a strong indication of product 

efficiency over a wide range of 

conditions. DOE concludes that 

development of an additional test for 

part load, or a change of the room air 

conditioner metric to a part-load metric 

is not supported by the information 

available to DOE at this time. Therefore, 

DOE did not consider amendments to its 

room air conditioner test procedure to 

measure part-load performance in the 

June 2010 TP SNOPR. 75 FR 37594, 

37634 (June 29, 2010). For these reasons 

and in the absence of comments 

objecting to this determination, DOE is 

not amending its room air conditioner 

test procedure to measure part-load 

performance at this time. DOE may 

amend the test procedure to account for 

part-load performance in a future 

rulemaking if information becomes 

available on part-load technologies that 

are likely to result in significant energy 

savings during actual use by consumers. 

f. Room Air Conditioner Ambient Test 

Conditions 

DOE also considered whether the 

ambient test conditions in its test 

procedure for room air conditioners are 

representative of typical installations. 

DOE noted in the June 2010 TP SNOPR 

that it received a comment in response 

to the October 2007 Framework 

Document that recommended increasing 

the ambient temperature of the DOE 

energy test procedure from 95 °F to 

115 °F. The commenters stated that 

room air conditioners are generally 

operated when the outdoor 

temperatures are the highest, and that 

they are often located on the south or 

west side of residences where the sun 

can shine on them during operation. 75 

FR 37594, 37634 (June 29, 2010). DOE 

stated that it did not receive further 

information to support the specification 

of the higher temperature, and, 

therefore, did not consider an 

amendment to the ambient test 

conditions specified in the room air 

conditioner test procedure in the June 

2010 TP SNOPR. Id. 

AHAM supported maintaining the 

current specifications regarding ambient 

test conditions for room air 

conditioners. (AHAM, No. 31 at p. 10; 

AHAM, Public Meeting Transcript, No. 

20 at p. 155) In the absence of data to 

support a change to the ambient test 

conditions, DOE is not amending the 

ambient test conditions specified in the 

room air conditioner test procedure. 

6. Room Air Conditioner Referenced 

Test Procedures 

The room air conditioner test 

procedure cites two test standards: (1) 

ANS Z234.1–1972 and (2) ASHRAE 

Standard 16–69. Both the ANS (since 

renamed ANSI) and ASHRAE standards 

have been updated since DOE last 

revised its room air conditioner test 

procedure. The current standards are 

ANSI/AHAM RAC–1–R2008 and ANSI/ 

ASHRAE Standard 16–1983 (RA 2009), 

respectively. Because it is likely that 

any manufacturer rating it products is 

using the most recent test standards, 

DOE suggested in the October 2007 

Framework Document that it consider 

updating its test procedure to 

incorporate by reference the most recent 

test standards. 

In the June 2010 TP SNOPR, DOE 

reviewed the differences between the 

test standards currently referenced by 

the DOE test procedure and the latest 

versions of these standards to determine 

if amendments to reference the latest 

ANSI and ASHRAE test standards are 

appropriate. DOE noted the sections that 

would be referenced in ANSI/AHAM 

RAC–1–R2008 by the DOE test 

procedure do not introduce any new 

changes in the measurement of cooling 

capacity or power input. DOE also noted 

the sections that would be referenced in 

ANSI/ASHRAE Standard 16–1983 (RA 

2009) by the DOE test procedure would 

introduce changes to the determination 

of capacity, four new temperature 

measurements, and changes to the test 

tolerances. In particular, DOE noted in 

the June 2010 TP SNOPR that section 

6.1.3 of ANSI/ASHRAE Standard 16– 

1983 (RA 2009) introduces a correction 

factor based on the test room condition’s 

deviation from the standard barometric 

pressure of 29.92 inches (in.) of mercury 

(Hg) (101 kilopascal (kPa)). Section 6.1.3 

of ANSI/ASHRAE Standard 16–1983 

(RA 2009) states that the cooling 

capacity may be increased 0.8 percent 

for each in. Hg below 29.92 in. Hg (0.24 

percent for each kPa below 101 kPa). 

DOE noted the capacity correction factor 

provides manufacturers with more 


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flexibility in the test room conditions 

while normalizing results to standard 

conditions. On November 26, 2010, 75 

FR 72739, DOE published notice of a 

petition submitted by AHAM 

concerning use of the proposed 

correction factor for room air 

conditioner testing. While DOE seeks 

comment on the petition until December 

27, 2010, DOE believes that the 

correction factor resolves the issues 

presented in the AHAM petition. DOE 

also noted the referenced section 

numbers from the old and current test 

standards are identical. 75 FR 37594, 

37634–35 (June 29, 2010). 

DOE determined that incorporation by 

reference of these updated versions 

provides more accurate and repeatable 

measurements of capacity while 

providing greater flexibility to 

manufacturers in selecting equipment 

and facilities, and does not add any 

significant testing burden because the 

time required for testing would not 

change. Furthermore, these revisions 

would not impact the measurement of 

EER for this equipment because the 

methodology used for this measurement 

is the same. DOE also stated that it 

believes that manufacturers may already 

be using these updated standards in 

their testing. Therefore, DOE proposed 

amending the DOE test procedure to 

reference the relevant sections of ANSI/ 

AHAM RAC–1–R2008 and ANSI/ 

ASHRAE Standard 16–1983 (RA 2009). 

75 FR 37634–35. 

AHAM agreed that DOE should 

reference the latest standards for room 

air conditioners. (AHAM, No. 31 at p. 

10) For the reasons stated above and in 

the absence of comments objecting to 

amending the DOE test procedure to 

reference the relevant sections of ANSI/ 

AHAM RAC–1–R2008 and ANSI/ 

ASHRAE Standard 16–1983 (RA 2009), 

DOE adopts these amendments. 

7. Clothes Dryer Referenced Test 

Procedure 

The DOE clothes dryer test procedure 

currently references the industry test 

standard AHAM Standard HLD–1–1974. 

Specifically, the DOE clothes dryer test 

procedure requires that the clothes 

dryer under test add the AHAM exhaust 

simulator described in section 3.3.5 of 

AHAM Standard HLD–1–1974. The 

AHAM test standard has been updated 

since DOE established its clothes dryer 

test procedure. The current standard is 

designated as AHAM Standard HLD–1– 

2009. Because it is likely that any 

manufacturer rating it products is using 

the most recent test standard, DOE 

considered potential amendments to its 

clothes dryer test procedure to reference 

AHAM Standard HLD–1–2009 in the 

June 2010 TP SNOPR. DOE noted that 

section 3.3.5.1 of AHAM Standard 

HLD–1–2009 regarding exhausting 

conditions provides the same 

requirements for the exhaust simulator 

as required by AHAM Standard HLD–1– 

1974. For this reason, DOE proposed to 

amend the DOE test procedure to 

reference AHAM Standard HLD–1– 

2009. DOE stated that because the 

requirements for the exhaust simulator 

would be the same, the proposed 

amendments would not affect the EF 

rating of residential clothes dryers and 

would not require that the existing 

energy conservation standards for these 

products be revised. 75 FR 37594, 37636 

(June 29, 2010). 

AHAM, Whirlpool, and ALS 

commented in support of updating the 

test procedure to reference AHAM 

standard HLD–1–2009. (AHAM, No. 31 

at p. 10, AHAM, Public Meeting 

Transcript, No. 20 at p. 158, Whirlpool, 

No. 27 at p. 5, ALS, No. 24 at p. 8) For 

these reasons and in the absence of 

comments objecting to amending the 

DOE test procedure to reference AHAM 

Standard HLD–1–2009, DOE adopts 

these amendments in today’s final rule. 

DOE also acknowledges that AHAM 

Standard HLD–1–2009 allows for the 

optional use of a modified exhaust 

simulator, which is included as a more 

convenient option than the exhaust 

simulator originally specified for testing 

vented clothes dryers. The requirements 

for the modified exhaust simulator are 

presented in section 3.3.5.2 of AHAM 

Standard HLD–1–2009. The test 

standard notes that only limited testing 

has been done to compare results using 

the two exhaust simulators, and that 

users are invited to submit results and 

comments for both options. Because this 

modified exhaust simulator is recent, 

and limited data exist to compare the 

effects of using different exhaust 

simulators, DOE stated in the June 2010 

TP SNOPR that it will continue to 

require the standard exhaust simulator 

currently referenced by the DOE clothes 

dryer test procedure. 75 FR 37594, 

37636 (June 29, 2010). However, DOE 

requested data from manufacturers 

comparing the effects of the two exhaust 

simulators on the drying efficiency 

using the DOE test procedure. DOE also 

invited comment on whether the test 

procedure should be amended to allow 

for the optional modified exhaust 

simulator. 

AHAM commented that there may be 

more data available concerning the 

modified exhaust simulator, which 

gained ANSI approval in 2009. (AHAM, 

Public Meeting Transcript, No. 20 at pp. 

159–160) AHAM stated that DOE should 

allow for the optional use of a modified 

exhaust simulator. AHAM added that 

the AHAM Standard HLD–1–2009 was 

developed after an extensive standardsmaking process, which fully vetted 

issues related to optional use of a 

modified exhaust simulator, and as such 

there is no reason for DOE to deviate 

from that standard. (AHAM, No. 31 at p. 

10). 

DOE is not aware of any data 

comparing the effects of the two exhaust 

simulators on the drying efficiency 

using the DOE test procedure. DOE 

notes that it requested such data in the 

June 2010 TP SNOPR, but did not 

receive any data. In the absence of such 

data, DOE will continue to require the 

standard exhaust simulator currently 

referenced by the DOE clothes dryer test 

procedure. If data are made available 

showing that the test results using the 

modified exhaust simulator produce 

repeatable results, as well as comparing 

the effects of the different exhaust 

simulators on the measured EF, DOE 

may consider such revisions to its 

clothes dryer test procedure in a future 

rulemaking. 

Section 1.8 in the ‘‘Definitions’’ 

section of the DOE clothes dryer test 

procedure also references an obsolete 

AHAM clothes dryer test standard, 

AHAM Standard HLD–2EC. No 

provisions of this test standard are 

currently used in DOE’s test procedure, 

and DOE therefore proposed to remove 

this reference in the June 2010 TP 

SNOPR. 75 FR 37594, 37636 (June 29, 

2010). AHAM and Whirlpool both 

commented in support of removing the 

reference to AHAM Standard HLD–2EC. 

(AHAM, No. 31 at p. 10, Whirlpool, No. 

27 at p. 5) For this reason and in the 

absence of comments objecting to this 

proposal, DOE amends the test 

procedure to remove this reference. 

8. Technical Correction for the PerCycle Gas Dryer Continuously Burning 

Pilot Light Gas Energy Consumption 

The equation provided under section 

4.4 Per-cycle gas dryer continuously 

burning pilot light gas energy 

consumption of the current DOE clothes 

dryer test procedure contains a 

technical error in the equation for 

calculation of the per-cycle gas dryer 

continuously burning pilot light gas 

energy consumption (Eup), in Btus per 

cycle. Eup is the product of the following 

three factors: (A) The cubic feet of gas 

consumed by the gas pilot in hour; (B) 

the total number of hours per year the 

pilot is consuming gas while the clothes 

dryer is not operating in active mode 

(8,760 total hours per year minus 140 

hours per year the clothes dryer 

operates in active mode) divided by the 

representative average number of 


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clothes dryer cycles in a year (416); and 

(C) the corrected gas heat value. Part (B) 

of this equation is currently incorrect, 

reading (8760 ¥ 140/416) and missing 

the appropriate parentheses. The 

equation should correctly subtract the 

total number of hours per year the pilot 

is consuming gas while the clothes 

dryer is not operating in active mode 

from the number of hours per year the 

clothes dryer operates in active mode, 

before dividing by the average number 

of clothes dryer cycles in a year. The 

equation should read ((8760 ¥ 140)/ 

416) to correctly calculate the per-cycle 

gas dryer continuously burning pilot 

light gas energy consumption. 

Therefore, DOE proposed in the June 

2010 TP SNOPR to amend the equation 

to correctly calculate the per-cycle gas 

dryer continuously burning pilot light 

gas energy consumption. 75 FR 37594, 

37636 (June 29, 2010). 

AHAM and Whirlpool supported the 

technical correction to the per-cycle gas 

dryer continuously burning pilot light 

gas energy consumption calculation. 

(AHAM, No. 31 at p. 10; Whirlpool, No. 

27 at p. 5) ALS commented that it 

supported DOE’s proposed technical 

correction. However, ALS believes this 

an unnecessary addition to the test 

procedure. ALS believes the proper way 

to address the issue is to revise the 

minimum energy conservation standard 

during its current standards rulemaking 

to add back into the minimum standard 

the design prescription banning 

constant burning pilot lights. ALS noted 

that the original 1987 standard included 

the design prescription, but it was 

removed in the first review of the 

standard effective May 14, 1994 because 

it was perceived that the revised 

minimum standard of 1994 would 

continue to effectively eliminate 

continuously burning pilot lights. ALS 

noted that no clothes dryer with 

continuously burning gas pilot lights 

exists on the market at this time. 

Therefore, it is a wasted effort to add 

text to the test procedure for something 

that does not exist and can be more 

effectively dealt with by a simple 

revision to the clothes dryer minimum 

standard. (ALS, No. 24 at p. 8) AHAM 

also commented that it is not aware of 

any clothes dryer on the market that 

uses a constant burning pilot light, and 

doubts any such dryers will be 

introduced soon. (AHAM, Public 

Meeting Transcript, No. 20 at p. 162) 

As discussed in section I, EPCA 

establishes prescriptive standards for 

clothes dryers, requiring that gas dryers 

manufactured on or after January 1, 

1988 not be equipped with a constant 

burning pilot (42 U.S.C. 6295(g)(3)). 

Because constant burning pilot lights 

are precluded by EPCA, DOE agrees 

with ALS that any provisions for 

measuring constant burning pilot light 

energy use in gas clothes dryers are no 

longer necessary. As a result, DOE 

amends the clothes dryer test procedure 

to remove all provisions for measuring 

the constant burning pilot light energy 

use. 

9. Clarification of Gas Supply Test 

Conditions for Gas Clothes Dryers 

Section 2.3.2.1 and 2.3.2.2 of the DOE 

clothes dryer test procedure specifies 

maintaining ‘‘the gas supply to the 

clothes dryer at a normal inlet test 

pressure immediately ahead of all 

controls at’’ 7 to 10 inches of water 

column for natural gas or 11 to 13 

inches of water column for propane gas. 

DOE believes that the references to 

‘‘normal inlet test pressure’’ in sections 

2.3.2.1 and 2.3.2.2 of its clothes dryer 

test procedure may be confusing 

because the term ‘‘normal’’ is not 

defined. DOE believes that such 

language is not necessary because the 

gas supply pressure immediately ahead 

of all controls is explicitly stated. 

Therefore, DOE proposed in the June 

2010 TP SNOPR to revise the test 

pressure conditions in sections 2.3.2.1 

and 2.3.2.2 of the DOE clothes dryer test 

procedure to specify maintaining ‘‘the 

gas supply to the clothes dryer 

immediately ahead of all controls at a 

pressure of’’ 7 to 10 inches of water 

column for natural gas and 11 to 13 

inches of water column for propane gas. 

75 FR 37594, 37636 (June 29, 2010). 

AHAM, Whirlpool, and ALS supported 

DOE’s proposed clarification. (AHAM, 

No. 31 at pp. 10–11; Whirlpool, No. 27 

at p. 5; ALS, No. 24 at p. 8) For these 

reasons and in the absence of comments 

objecting to this proposal, DOE amends 

its clothes dryer test procedure to revise 

the test pressure conditions as discussed 

above. 

DOE also believes the specifications 

for a gas pressure regulator in sections 

2.3.2.1 and 2.3.2.2 of its clothes dryer 

test procedure should clarify that the 

outlet pressure for a clothes dryer 

equipped with a pressure regulator for 

which the manufacturer specifies an 

outlet pressure should be approximately 

that recommended by the manufacturer. 

DOE proposed in the June 2010 TP 

SNOPR to make these minor revisions 

these sections. 75 FR 37594, 37636 (June 

29, 2010). In the absence of comments 

objecting to this proposal, DOE is 

amending its clothes dryer test 

procedure to revise the test pressure 

conditions for clothes dryers equipped 

with a gas pressure regulator as 

discussed above. 

10. Other Clothes Dryer Active Mode 

Issues 

DOE received a number of comments 

on issues related to the active mode for 

clothes dryers not identified in the June 

2010 TP SNOPR. The following sections 

discuss each of these issues. 

a. Test Cloth Specifications 

ALS commented in response to the 

June 2010 TP SNOPR that DOE should 

consider if the number of test runs 

allowed on test cloth after preconditioning should be equal to the 

number of allowable runs for clothes 

washer test cloth. ALS commented that, 

currently, the clothes dryer test cloth 

can be used for only 25 test runs, while 

the clothes washer test cloth is allowed 

to be used for 60 test runs. (ALS, No. 24 

at p. 6) Whirlpool commented that both 

the clothes washer and clothes dryer 

test procedures should be modified to 

allow for 50 cycles of test cloth use, 

because this would be easier to manage 

and reduce the cost of cloth used in 

clothes dryers. Whirlpool commented 

that beyond 50 wash cycles, the load-toload variability increases significantly, 

adversely impacting repeatability. 

(Whirlpool, No. 27 at p. 6) DOE is not 

aware of any data showing the 

repeatability of clothes dryer test results 

for test cloth after 25 runs. DOE is also 

not aware of any data indicating that the 

wear on test cloth from a drying cycle 

is equivalent to that of a washing cycle. 

Thus, there is no evidence that warrants 

changing the test procedures to specify 

the same number of allowable test runs 

on clothes washer and clothes dryer test 

cloths. For these reasons, DOE is not 

amending the clothes dryer test 

procedure in today’s final rule to change 

the number of test runs allowed on 

clothes dryer test cloth. 

Whirlpool commented that the lot-tolot test cloth correction factors used in 

the clothes washer test procedure are 

not used in the clothes dryer test 

procedure. Whirlpool stated that it is 

increasingly the case that clothes dryer 

test results are not repeatable across test 

cloth lots. Whirlpool stated its research 

suggests that adding the washer 

correction factors to the clothes dryer 

test procedure would substantially 

address this problem. (Whirlpool, No. 

27 at p. 6) DOE is not aware of any data 

indicating variations in test results 

across different test cloth lots is 

significant enough to warrant amending 

the clothes dryer test procedure to 

include correction factors. In addition, 

DOE notes that the clothes washer RMC 

correction factor is based on extractor 

testing (spinning water out of the 

clothes load). Extractor testing can have 


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40 DOE proposed to use the term Integrated 

Energy Factor (IEF) in the December 2008 TP 

NOPR. 73 FR 74639, 74650 (December 9, 2008). 

However, in the June 2010 TP SNOPR, DOE 

proposed to revise the name of the metric to 

Combined Energy Factor (CEF). 75 FR 37594, 37612 

(June 29, 2010). 

very different moisture removal 

characteristics than the applied heated 

air and slower tumbling to evaporate 

moisture during a clothes dryer cycle. 

DOE is not aware of any data indicating 

that the same correction factor from the 

clothes washer test procedure can be 

applied to the clothes dryer test 

procedure. For these reasons, DOE is not 

amending the clothes dryer test 

procedure to include a lot-to-lot test 

cloth correction factor in today’s final 

rule. If data is made available 

documenting such lot-to-lot variation as 

well as validating that the RMC 

correction factor in the clothes washer 

test procedure can be applied to the 

clothes dryer test procedure, DOE may 

consider such amendments. 

b. Relative Humidity Measurement 

Specifications 

ALS commented that section 2.4.4 

Dry & Wet Bulb Psychrometer of the 

DOE clothes dryer test procedure should 

be updated. ALS stated that DOE may 

want to remove any reference to a dry 

and wet bulb psychrometer, because 

electronic digital sensors exist that 

directly report the relative humidity and 

test labs should be allowed to utilize 

them. ALS commented that DOE needs 

to research humidity measurement 

electronic digital sensors and propose 

new limits for their accuracy and 

reporting. (ALS, No. 24 at p. 9) 

DOE notes section 2.2.4 specifies that 

the dry and wet bulb psychrometer shall 

have an error no greater than ± 1 °F. 

DOE acknowledges that the dry and wet 

bulb psychrometer specifications for 

determining the relative humidity were 

developed in 1981 when the clothes 

dryer test procedure was last amended. 

Since that time, more advanced digital 

equipment has been developed for 

measuring relative humidity. DOE also 

acknowledges that the DOE test 

procedure for central air conditioners 

and heat pumps specifies the allowable 

error in the measurement of wet bulb 

temperature for determining the 

psychrometric state of air (the wet bulb 

temperature sensor must be accurate 

within ± 0.2 °F). That test procedure 

also specifies the allowable error for an 

alternative option of directly measuring 

the relative humidity (such a meter 

must be accurate to within ± 0.7 

nominal percent relative humidity). 10 

CFR part 430, subpart B, appendix M, 

§ 2.5.6 DOE is not aware of data or 

information on how the allowable dry 

and wet bulb psychrometer 

measurement error of no greater than ± 

1 °F would translate to measurement 

error specifications for relative humidity 

measurement equipment that could be 

used to determine an appropriate 

allowable error for the DOE clothes 

dryer test procedure. For these reasons, 

DOE is not adopting amendments to the 

dry bulb and wet bulb psychrometer 

specifications for determining the 

relative humidity. If data are made 

available indicating an appropriate 

range for the allowable error for relative 

humidity measurement equipment, 

however, DOE may consider 

amendments to the clothes dryer test 

procedure. 

c. Calculations of EF and CEF 

ALS commented that DOE needs to 

add the calculation for the EF, the 

newly proposed IEF,40 or both to the 

clothes dryer test procedure. According 

to ALS, the clothes washer test 

procedure displays the calculation for 

the minimum energy efficiency 

descriptor (the modified energy factor). 

ALS stated the clothes dryer test 

procedure should likewise show how to 

calculate the value of clothes dryer 

minimum energy efficiency descriptor 

EF and/or IEF. (ALS, No. 24 at p. 9) 

AHAM also requested that DOE 

expressly state the equation for EF in 

the test procedure to provide optimal 

clarity for the regulated industry. 

(AHAM, No. 31 at p. 11) 

DOE notes that the calculation for EF 

(and the proposed CEF) for clothes 

dryers can be found at 10 CFR 

430.23(d). However, DOE acknowledges 

that other test procedures in the 

appendices of 10 CFR part 430, subpart 

B also include the calculations of the 

energy efficiency metric. For example, 

the clothes washer test procedure (10 

CFR part 430, subpart B, appendix J1) 

includes the calculation, as noted by 

ALS. Including such calculations would 

help test technicians find the proper 

calculation for EF and CEF. For these 

reasons, DOE believes that the 

calculation for EF and CEF should be 

included in 10 CFR part 430, subpart B, 

appendix D1. Therefore, DOE amends 

the clothes dryer test procedure in 

today’s final rule to include those 

calculations. DOE also amends 10 CFR 

part 430.23(d)(2) and (3) in today’s final 

rule to clarify that the EF and CEF are 

to be determined in accordance with the 

appropriate sections in 10 CFR part 430, 

subpart B, appendix D1. 

d. Measurement of Kilowatt Electricity 

Demand 

SEDI recommended that kW 

electricity demand, in addition to kWh 

energy consumption, also be measured 

during the test procedure. SEDI added 

that different clothes dryer technologies 

can have very different electricity 

demand profiles. Typical electric 

clothes dryers available in North 

America today have powerful heating 

elements and may significantly 

contribute to system peak demand. SEDI 

commented that a more efficient clothes 

dryer with a lower contribution to peak 

demand may be even more cost-effective 

from perspective of electric utilities. 

(SEDI, No. 34 at p. 3) As discussed 

previously, EPCA provides that any test 

procedures prescribed or amended 

under this section shall be reasonably 

designed to produce test results which 

measure energy efficiency, energy use, 

water use, or estimated annual operating 

cost of a covered product during a 

representative average use cycle or 

period of use. (42 U.S.C. 6293(b)(3)) 

DOE believes that measuring the 

electricity demand profile of a clothes 

dryer to account for designs options that 

may reduce utility peak load demand 

would be inconsistent with the EPCA 

requirement for a test procedure to 

measure the energy use of a product. For 

this reason, DOE is not amending the 

clothes dryer test procedure to measure 

the electricity demand profile of a 

clothes dryer to account for the peak 

load demand of a clothes dryer. 

e. Clarifications to the Measurement of 

Drum Capacity 

The Joint Petitioners and AHAM 

commented that DOE should clarify 

section 3.1 of the clothes dryer test 

procedure regarding the measurement of 

drum capacity. The clarification would 

specify that the clothes dryer’s rear 

drum surface be supported on a 

platform scale to ‘‘prevent deflection of 

the drum surface * * *’’ instead of 

‘‘prevent deflection of the dryer.’’ (Joint 

Petitioners, No. 25 at p. 14; Joint 

Petitioners, No. 30 at p. 8; AHAM, No. 

31 at p. 11) DOE agrees with the 

comments that the reference to 

deflection of the ‘‘dryer’’ is unclear and 

should be clarified to specify that the 

clothes dryer’s rear drum surface should 

be supported on a platform scale to 

prevent deflection of the drum surface. 

For this reason, DOE amends the clothes 

dryer test procedure to reflect this 

change. 

f. Test Procedure Language 

AHAM commented that 

manufacturers are having a difficult 


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time using the proposed test procedure 

because it is not written in a way that 

can be easily followed when running a 

test. AHAM commented that the 

extraneous portions derived from the 

IEC and Australia/New Zealand 

procedures create a confusing amalgam 

of testing situations that makes the 

procedure extremely difficult to 

conduct. AHAM stated that the test 

procedure itself needs to be evaluated, 

and they would like to see a more 

sequenced and applicable test 

procedure. (AHAM, Public Meeting 

Transcript, No. 20 at pp. 88–89, 126– 

127) AHAM commented that the AHAM 

HLD–1 committee will likely consider 

whether the test procedure amendments 

should be added as modifications to 

AHAM HLD–1, which is written in the 

test procedure format. AHAM stated 

that it would be helpful for DOE to 

identify explicitly how the proposed 

changes to the DOE test procedure could 

be reflected in AHAM HLD–1. AHAM 

added that manufacturers could test on 

a version of AHAM HLD–1 that 

incorporated the changes DOE 

identified and report what changes to 

test results have taken place. AHAM 

commented that it would also assist the 

AHAM HLD–1 committee in processing 

the changes because it is unlikely that 

the AHAM HLD–1 committee will want 

to run tests that are different from the 

DOE test procedure. (AHAM, Public 

Meeting Transcript, No. 20 at pp. 127– 

129) 

DOE notes that its proposed clothes 

dryer test procedure is similar in 

structure to many other DOE test 

procedures, and DOE is not aware of the 

particular sections of the test procedure 

language that may be confusing or 

difficult to interpret. DOE also notes 

that it is not adopting the amendments 

to more accurately account for 

automatic cycle termination based on 

the provisions in AS/NZS Standard 

2442, as discussed in section III.C.2. For 

these reasons, DOE does not believe that 

the test procedure needs to be 

restructured or re-written and is not 

including any additional revisions to 

the test procedure language. 

D. Compliance With Other EPCA 

Requirements 

1. Test Burden 

Standby Mode and Off Mode 

Section 323(b)(3) of EPCA requires 

that any test procedures prescribed or 

amended under this section shall be 

reasonably designed to produce test 

results which measure energy 

efficiency, energy use or estimated 

annual operating cost of a covered 

product during a representative average 

use cycle or period of use and shall not 

be unduly burdensome to conduct. (42 

U.S.C. 6293(b)(3)) 

For the proposed amendments to 

measure standby and off mode energy 

use, DOE tentatively concluded in the 

December 2008 TP NOPR that amending 

the relevant test procedures to 

incorporate clauses regarding test 

conditions and methods found in IEC 

Standard 62301 for measuring standby 

mode and off mode power consumption, 

along with the proposed clarifications 

and text corrections, would satisfy this 

requirement because the test methods 

and equipment that the amendments 

would require are not substantially 

different from the test methods and 

equipment in the current DOE test 

procedures for measuring the products 

energy consumption. Therefore, DOE 

stated the proposed test procedures 

would not require manufacturers to 

make major investments in test facilities 

and new equipment. 73 FR 74639, 

74650 (December 9, 2008). 

In the June 2010 TP SNOPR, DOE did 

not propose amendments to measure 

delay start and cycle finished modes in 

the clothes dryer test procedure. DOE 

instead proposed a simplified 

methodology in which the energy use 

associated with delay start and cycle 

finished modes, although determined to 

not be energy use in a standby mode, 

would be approximately represented by 

the measured energy in inactive and off 

modes. Therefore, because the proposal 

in the June 2010 TP SNOPR was less 

burdensome than the December 2008 TP 

NOPR proposal, DOE tentatively 

concluded that the proposed 

amendments to the clothes dryer test 

procedures for measuring standby and 

off modes adopted in June 2010 TP 

SNOPR are not unduly burdensome. 75 

FR 37594, 37637 (June 29, 2010). 

DOE proposed in the June 2010 TP 

SNOPR to provide manufacturers 

flexibility in setting the ambient 

conditions for standby mode and off 

mode testing for the room air 

conditioner test procedure. The 

proposed amendments to the room air 

conditioner test procedure specify 

maintaining the indoor test conditions 

at the temperature required by section 

4.2 of IEC Standard 62301. Further, if 

the unit is tested in the cooling 

performance test chamber, the proposed 

amendments allow the manufacturer to 

maintain the outdoor test conditions 

either as specified for the DOE cooling 

test procedure or according to section 

4.2 of IEC Standard 62301. 

Implementing those two specifications 

would mean that manufacturers would 

not have to build another facility to run 

the standby and off mode tests. In 

addition, DOE did not propose 

amendments that would specify 

measurement of energy use in delay 

start or off-cycle modes to the room air 

conditioner test procedure. DOE instead 

proposed a simplified methodology in 

which the energy use associated with 

delay start and off-cycle modes, 

although determined to not be energy 

use in a standby mode, would be 

approximately represented by the 

measured energy in inactive and off 

modes. For these reasons, DOE 

tentatively concluded that the test 

conditions proposed in the June 2010 

TP SNOPR are not unduly burdensome 

and would result in representative 

standby mode and off mode energy 

consumption measurements. 75 FR 

37594, 37637 (June 29, 2010). 

As discussed in section III.B.2, 

AHAM, Whirlpool, and ALS 

commented that the requirement 

proposed in the June 2010 TP SNOPR to 

conduct standby and off mode testing 

for clothes dryers and room air 

conditioners in the settings that produce 

the highest power consumption level 

would result in extra test burden. This 

is because manufacturers will need to 

run several tests on every model in 

order to determine which cycle is the 

highest energy cycle (AHAM, No. 31 at 

pp. 4–5; Whirlpool, No. 27 at p. 1; ALS, 

No. 24 at pp. 1–2) DOE is not adopting 

the provisions for conducing standby 

and off mode testing in the settings that 

produce the highest power consumption 

level in today’s final rule. DOE is 

instead incorporating by reference 

section 5.2 of IEC Standard 62301, 

which requires that the appliance be 

installed and set up in accordance with 

manufacturers instructions; if no 

instructions are given, then the 

appliance shall be tested at factory or 

‘‘default’’ settings; and where there are 

no indications for such settings, the 

appliance shall be tested as supplied. 

DOE believes that such provisions 

would not require manufacturers to run 

several tests on every model to 

determine the appropriate mode, and 

therefore would not represent a testing 

burden. 

For the reasons stated above and in 

the absence of additional comments, 

DOE concludes that the standby and off 

mode testing conditions for clothes 

dryers and room air conditioners 

adopted in today’s final rule are not 

unduly burdensome, yet still produce 

representative standby mode and off 

mode energy consumption 

measurements. 

Active Mode 

In the June 2010 TP SNOPR, DOE 

noted that the proposed amendments to 


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its test procedure for clothes dryers to 

test automatic termination control 

dryers are based upon an international 

testing standard used to determine 

compliance with energy conservation 

standards for clothes dryers in 

Australia. A number of manufacturers 

that sell clothes dryers in the United 

States also sell clothes dryers in 

Australia, and therefore likely already 

test clothes dryers according to this test 

standard. DOE stated the proposed 

amendments would not require testing 

methods and equipment that are 

substantially different from the test 

methods and equipment in the current 

DOE test procedures. Therefore, 

manufacturers would not be required to 

make a major investment in test 

facilities and new equipment. 75 FR 

37594, 37637 (June 29, 2010). As 

discussed in section III.C.2, DOE is not 

adopting in today’s final rule the 

amendments for automatic cycle 

termination proposed in the June 2010 

TP SNOPR. 

In the June 2010 TP SNOPR, DOE also 

noted that the proposed amendments to 

its test procedure for residential clothes 

dryers to test ventless clothes dryers are 

based on an international test standard 

used throughout the EU to determine 

compliance with energy conservation 

standards. A number of manufacturers 

that sell clothes dryers in the United 

States also sell clothes dryers in the EU, 

and therefore likely already test clothes 

dryers according to this test standard. 

DOE stated the proposed amendments 

would not require testing methods and 

equipment that are substantially 

different from the test methods and 

equipment in the current DOE clothes 

dryer test procedure. 75 FR 37594, 

37637 (June 29, 2010). 

DOE noted that its proposed 

amendments to the clothes dryer test 

procedure to reflect current usage 

patterns and capabilities in the June 

2010 TP SNOPR do not substantially 

change the testing procedures and 

methods. DOE noted that its proposed 

amendments to change the number of 

annual use cycles affects only the 

calculation of the estimated annual 

operating cost. The number of annual 

use cycles does not impact the testing 

procedures because the value is only 

used in the calculation of results. DOE 

also noted that the proposed 

amendments to change the initial RMC 

from 70 percent to 47 percent are 

intended to reflect current clothes loads 

after a wash cycle. DOE believes that 

such a change would likely require only 

a moderately longer spin time during 

test load preparation to achieve the 

proper lower moisture content. Finally, 

DOE noted that the proposed 

amendment to change the test load size 

for standard-size clothes dryers from 

7.00 lb ± .07 lb to 8.45 lb ± .085 lb 

would not significantly impact the 

testing procedures because it only 

affects the amount of test cloth required 

to be used for the test cycle. The 

amendment also would not require 

manufacturers to make any significant 

new investment in test facilities and 

equipment. DOE stated in the June 2010 

TP SNOPR that these proposed 

amendments to the DOE clothes dryer 

test procedure would produce test 

results that measure energy use of 

clothes dryers during a representative 

average use cycle. 75 FR 37594, 37637 

(June 29, 2010). 

DOE noted in the June 2010 TP 

SNOPR that the proposed amendments 

to update the references to external 

standards in the DOE room air 

conditioner test procedure are based on 

the availability of revised standards 

representing current industry practices 

and methods. The proposed 

amendments to reference ANSI/AHAM 

RAC–1–R2008 do not introduce any 

new changes in the measurement of 

cooling capacity or power input. The 

proposed amendments to reference 

ANSI/ASHRAE Standard 16–69 would 

introduce four new temperature 

measurements, provide increased test 

tolerances, and allow additional 

flexibility in the methodology for 

measuring capacity. DOE notes the four 

new temperature measurements would 

be measured simultaneously with the 

other measurements already required by 

the test procedure, and therefore would 

not require additional time to conduct 

the test. DOE stated in the June 2010 TP 

SNOPR that these proposed 

amendments would not require 

manufacturers to make any significant 

new investment in test facilities and 

equipment, nor require significant 

changes in the testing methodology. 75 

FR 37594, 37637 (June 29, 2010). 

For the reasons noted above, DOE 

tentatively concluded that the 

amendments to the active mode test 

procedures would produce 

representative test results for both 

residential clothes dryers and room air 

conditioners, and that testing under the 

test procedures would not be unduly 

burdensome to conduct. 75 FR 37594, 

37638 (June 29, 2010). 

ALS commented that there could be a 

test burden associated with the revised 

initial RMC requirements. ALS stated 

that it might not be able to achieve the 

47 percent RMC proposed in the June 

2010 TP SNOPR in one of their 

residential clothes washers due to the 

disconnect between the actual RMC and 

the corrected RMC values. (ALS, Public 

Meeting Transcript, No. 20 at pp. 166– 

167) AHAM commented that extracting 

moisture to the 47 percent RMC level 

would cause test cloth to deteriorate 

more quickly. Also, extracting moisture 

to the 47 percent RMC level would 

cause other problems. For example, to 

achieve the level it would be necessary 

to use an extractor, which would require 

spending significant sums of money. 

(AHAM, Public Meeting Transcript, No. 

20 at pp. 167–168) 

DOE notes that the tests conducted for 

the June 2010 TP SNOPR at an 

independent test lab prepared the 

clothes dryer test cloth with an RMC of 

47 percent using a commercially 

available clothes washer. For the 

reasons discussed in section III.C.5.b, 

however, DOE adopts an initial RMC of 

57.5 percent ± 3.5 percent for the 

clothes dryer test procedure in today’s 

final rule. As a result, DOE believes that 

there would be no significant test 

burden associated with reaching this 

higher initial RMC value. 

For the reasons stated above and in 

the absence of additional comments, 

DOE concludes that the amendments to 

the active mode test procedures in 

today’s final rule would produce 

representative test results for both 

residential clothes dryers and room air 

conditioners, and that testing under the 

test procedures would not be unduly 

burdensome to conduct. 

2. Integration of Standby Mode and Off 

Mode Energy Consumption Into the 

Efficiency Metrics 

Section 325(gg)(2)(A) requires that 

standby mode and off mode energy 

consumption be ‘‘integrated into the 

overall energy efficiency, energy 

consumption, or other energy descriptor 

for each covered product’’ unless the 

current test procedures already fully 

account for the standby mode and off 

mode energy consumption or if such an 

integrated test procedure is technically 

infeasible. (42 U.S.C. 6295(gg)(2)(A)) For 

clothes dryers, today’s final rule does 

not affect DOE’s proposal in the 

December 2008 TP NOPR to incorporate 

the standby and off mode energy 

consumption into a ‘‘per-cycle combined 

total energy consumption expressed in 

kilowatt-hours’’ and into an CEF, as 

discussed in section III.B.5 of this 

notice. For room air conditioners, 

today’s final rule does not affect DOE’s 

proposal in the December 2008 TP 

NOPR to incorporate the standby and off 

mode energy consumption into a metric 

for ‘‘combined annual energy 

consumption’’ and into an CEER, as 

discussed in section III.B.5. In addition, 

DOE is amending the clothes dryer and 

room air conditioner test procedures in 


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today’s final rule to incorporate standby 

and off mode energy consumption into 

the annual energy cost calculations, as 

discussed in section III.B.5. 

IV. Effects of Test Procedure Revisions 

on Compliance With Standards 

As noted in section I, DOE must 

determine to what extent, if any, the 

proposed test procedures would alter 

the measured energy efficiency of 

covered products as determined under 

the existing test procedures. If DOE 

determines that an amended test 

procedure would alter the measured 

efficiency of a covered product, DOE 

must amend the applicable energy 

conservation standard during the 

rulemaking carried out with respect to 

such test procedure. (42 U.S.C. 6293(e)) 

A. Standby Mode and Off Mode 

As noted in section II, EPCA provides 

that amendments to the test procedures 

to include standby mode and off mode 

energy consumption will not determine 

compliance with previously established 

standards. (U.S.C. 6295(gg)(2)(C)) 

Because the proposed amended test 

procedures for standby mode and off 

mode energy consumption would not 

alter existing measures of energy 

consumption or efficiency for active 

mode, these amendments would not 

affect a manufacturer’s ability to 

demonstrate compliance with 

previously established standards. 

B. Active Mode—Clothes Dryers 

DOE reviewed the amendments to the 

DOE clothes dryer active mode test 

procedure to evaluate the effects on the 

measured EF. The following sections 

discuss DOE’s evaluation of each active 

mode amendment individually, as well 

as DOE’s evaluation of the fully 

amended test procedure. 

Automatic Cycle Termination 

In the June 2010 TP SNOPR, DOE 

analyzed how the proposed changes to 

the DOE clothes dryer test procedure for 

automatic cycle termination controls 

discussed above in section III.C.2 would 

affect the measured EF of residential 

clothes dryers, as required by EPCA. 75 

FR 37594, 37618 (June 29, 2010). As 

part of DOE’s preliminary analyses for 

the energy conservation standards 

rulemaking for clothes dryers, DOE 

concluded that virtually all clothes 

dryers currently available on the U.S. 

market that are covered under the 

current energy conservation standards 

are equipped with some form of 

automatic cycle termination sensing. 

Therefore, DOE analyzed in the June 

2010 TP SNOPR how the proposed 

changes to the clothes dryer test 

procedure for automatic termination 

control dryers would affect the 

measured EF of residential clothes 

dryers with such a feature. 75 FR 37594, 

37618 (June 29, 2010). 

DOE noted in the June 2010 TP 

SNOPR that the proposed amendment to 

change the field use factor from 1.04 to 

1.0 for automatic termination control 

dryers would result in a 4-percent 

increase in EF for a dryer that has an 

automatic cycle termination setting 

capable of drying the test load to 5- 

percent RMC. In addition, DOE noted 

the proposed target final RMC of 5 

percent or lower would result in an 

increase in EF of about 2.4 percent 

(assuming a starting RMC of 47 percent). 

This is as compared to the current DOE 

test procedure, which uses a correction 

factor in order to determine the energy 

consumption required to dry the test 

load to a final RMC of 4 percent. DOE 

also stated in the June 2010 TP SNOPR 

that a clothes dryer that is only 

minimally compliant with current 

energy conservation standards would 

likely use a less accurate automatic 

termination control system. DOE stated 

that such a dryer would possibly overdry the test load below 5-percent RMC 

such that the energy consumption and 

measured EF would be equivalent to 

that measured by the existing DOE 

clothes dryer test procedure. As a result, 

DOE stated that it does not believe that 

any changes to the current energy 

conservation standards as a result of the 

proposed amendments to the test 

procedure to account for automatic 

cycle termination would be warranted. 

75 FR 37619–20. Because DOE did not 

have data regarding how the proposed 

changes to the clothes dryer test 

procedure for automatic termination 

control dryers would affect the 

measured EF of residential clothes 

dryers with such a feature, however, 

DOE requested comment on this 

tentative conclusion in the June 2010 TP 

SNOPR. Id. 

The Joint Petitioners and AHAM 

commented that if the full cycle test 

(including cool-down) is adopted, DOE 

must also revise the relevant energy 

conservation standards to reflect the 

new test procedure, ensuring no change 

in the stringency of the standards for 

clothes dryers with effective automatic 

termination controls, as per section 323 

of EPCA. The Joint Petitioners and 

AHAM stated that, specifically, the 

procedures in section 323(e)(2) should 

be used, with the clarification that for 

the purposes of establishing a 

representative sample of products, DOE 

should choose a sample of minimally 

compliant clothes dryers that 

automatically terminate the drying cycle 

at no less than 4-percent RMC. The Joint 

Petitioners and AHAM also stated that 

there will be additional energy savings 

by improving the effectiveness of 

automatic termination controls. (Joint 

Petitioners, No. 30 at p. 6; AHAM, No. 

31 at pp. 30–31) 

The California Utilities/NRDC 

commented that they are very 

concerned with DOE’s proposal to not 

revise the current energy conservation 

standard levels as a result of its analysis 

of the test procedure amendments to 

account for automatic cycle termination. 

They are also concerned about DOE’s 

interpretation of the definition of a 

‘‘minimally compliant’’ clothes dryer in 

the June 2010 TP SNOPR. The 

California Utilities/NRDC noted that 

clothes dryers with less accurate 

automatic termination controls may 

actually over-dry beyond the specified 

RMC in the field. They also stated that 

clothes dryers with less accurate 

automatic termination controls will not 

exhibit equivalent energy consumption 

and measured EF under the new test 

procedure; should not be used as a basis 

for DOE’s analysis; and should not be 

considered automatically compliant 

under the new test procedure. 

(California Utilities/NRDC, No. 33 at pp. 

6–7) 

The California Utilities/NRDC further 

stated that clothes dryers with 

operational automatic cycle termination 

controls will dry the clothes to an 

appropriate range of RMC without overdrying (between 2.5- and 5-percent 

RMC). They also stated that such clothes 

dryers should have about the same 

measured per-cycle energy use under 

both the current and proposed test 

procedures. The California Utilities/ 

NRDC stated, however, that by changing 

the calculation for per-cycle energy use, 

and changing the field use factor to 1.0, 

the calculated final per-cycle energy use 

for automatic termination control dryers 

will decrease. The California Utilities/ 

NRDC stated that the new test procedure 

would make these clothes dryers with 

operational controls appear to be more 

efficient and have a higher EF than 

under the current test procedure. The 

EF for these clothes dryers would 

increase by 4-percent through the 

change in the field use factor alone. The 

California Utilities/NRDC stated that, 

based on their calculations, all clothes 

dryers that dry to between 2.5- and 

5-percent RMC would have a higher 

measured EF. They stated that the 

energy conservation standards should 

be revised to reflect this measured 

higher EF. The California Utilities/ 

NRDC commented that for dryers with 

less accurate automatic termination 

controls, EF would decrease because of 


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the over-drying energy consumption 

mesaured using the the new test 

procedure. The California Utilities/ 

NRDC stated that adjustments to EF 

would be required to account for the 

new test procedure, per-cycle energy 

use calculation, and change in the field 

use factor. (California Utilities/NRDC, 

No. 33 at pp. 7–8) 

The California Utilities/NRDC stated 

they are concerned that by not changing 

the clothes dryer standards accordingly 

DOE’s current approach may qualify as 

backsliding prohibited by EPCA’s ‘‘antibacksliding’’ provision. The California 

Utilities/NRDC stated that under DOE’s 

proposed approach, many compliant 

clothes dryers could test with lower percycle energy use and higher EF, than 

currently. By not adjusting the 

maximum allowable energy use (and 

minimum allowable EF) for such dryers, 

DOE risks effectively weakening the 

standard. (California Utilities/NRDC, 

No. 33 at p. 8) The California Utilities/ 

NRDC proposed that DOE adjust its 

proposed candidate standard levels to a 

level consistent with the performance of 

a selection of dryers that are ‘‘minimally 

compliant’’ under both the current and 

proposed test procedure. The California 

Utilities/NRDC also recommended that 

when DOE selects a representative 

sample of minimally compliant clothes 

dryers, it choose models that 

automatically terminate at between 2.5- 

and 5-percent RMC. They explained that 

this approach would remove clothes 

dryers with less accurate automatic 

termination controls that comply under 

the current testing procedure and ensure 

that new standards are appropriately 

adjusted, so that the standard is not 

overly weak. Id. 

As discussed in section III.C.2, DOE is 

not adopting the amendments to better 

account for automatic cycle termination 

proposed in the June 2010 TP SNOPR. 

For this reason, DOE is not revising the 

energy conservation standards based on 

the amendments for automatic cycle 

termination proposed in the June 2010 

TP SNOPR. If DOE considers potential 

amendments for automatic cycle 

termination in a future rulemaking, it 

will consider any necessary revisions to 

the energy conservation standards. 

Water Temperature for Clothes Dryer 

Test Load Preparation 

DOE tested the 17 clothes dryers to 

evaluate the effects on measured EF to 

change the water temperature for 

clothes dryer test load preparation from 

100 °F ± 5 °F to 60 °F ± 5 °F, as 

discussed in section III.C.2. DOE tested 

these units according to the current DOE 

clothes dryer test procedure, first with 

a water temperature for clothes dryer 

test load preparation of 100 °F ± 5 °F, 

and then with a water temperature of 60 

°F ± 5 °F. For the ventless clothes dryer 

test units, DOE additionally used the 

proposed testing method for ventless 

dryers presented in section III.C.3. For 

each water temperature, DOE conducted 

up to three tests for each test unit and 

the results were averaged. Table IV.1 

below shows the results from this 

testing, which indicate that, on average, 

measured EF decreases by about 2.9 

percent when the water temperature for 

clothes dryer test load preparation is 

reduced from 100 °F ± 5 °F to 60 °F ± 

5 °F. DOE also notes the variation in the 

percentage change in EF from model to 

model due to the change in water 

temperature may also be due to other 

test condition tolerances in the test 

procedure, such as the specified ranges 

for ambient temperature and relative 

humidity. 

TABLE IV.1 DOE TEST RESULTS TO EVALUATE THE EFFECTS OF CHANGES TO THE WATER TEMPERATURE FOR CLOTHES

DRYER TEST LOAD PREPARATION

Test unit 

Average EF lb/kWh 

% 

100° ± 5 °F Change 

Water temp 

60° ± 5 °F 

Water temp 

Vented Electric Standard: 

Unit 1 ............................................................................................................................................ 3.07 3.00 ¥2.2 

Unit 2 ............................................................................................................................................ 3.14 3.05 ¥3.1 

Unit 3 ............................................................................................................................................ 3.20 3.10 ¥3.2 

Unit 4 ............................................................................................................................................ 3.28 3.22 -1.9 

Unit 5 ............................................................................................................................................ 3.24 3.17 ¥2.0 

Unit 6 ............................................................................................................................................ 3.12 2.98 ¥4.6 

Vented Gas: 

Unit 7 ............................................................................................................................................ 2.78 2.72 ¥2.4 

Unit 8 ............................................................................................................................................ 2.83 2.92 3.1 

Unit 9 ............................................................................................................................................ 2.85 2.64 ¥7.2 

Unit 10 .......................................................................................................................................... 2.80 2.69 ¥3.7 

Unit 11 .......................................................................................................................................... 2.98 2.79 ¥6.4 

Vented Electric Compact (240V):.

Unit 12 .......................................................................................................................................... 3.19 2.95 ¥7.7 

Unit 13 .......................................................................................................................................... 2.93 2.84 ¥3.2 

Vented Electric Compact (120V): 

Unit 14 .......................................................................................................................................... 3.23 3.11 ¥4.0 

Ventless Electric Compact (240V): 

Unit 15 .......................................................................................................................................... 2.37 2.22 ¥6.1 

Ventless Electric Combo Washer-Dryer: 

Unit 16 .......................................................................................................................................... 2.01 1.96 ¥4.0 

Unit 17 .......................................................................................................................................... 2.50 2.60 3.8 

Test Procedure for Ventless Clothes 

Dryers 

The amendments for ventless clothes 

dryers are applicable to products not 

covered under the current DOE test 

procedure. For this reason, the 

amendments in today’s final rule for 

ventless clothes dryers discussed in 

section III.C.3 would not affect the 

existing EF ratings of residential clothes 

dryers. Therefore, no change to the 

current clothes dryer energy 

conservation standards would be 

required. (42 U.S.C. 6293(e)) 


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Detergent Specifications for Clothes 

Dryer Test Cloth Preconditioning 

DOE stated in the June 2010 TP 

SNOPR that it is unaware of any data 

indicating that changes to the detergent 

specifications for test cloth 

preconditioning discussed in section 

III.C.4 would affect efficiency 

measurements. DOE stated that the 

proposed amendments in the June 2010 

TP SNOPR changing the detergent 

specifications for test cloth 

preconditioning would not affect the EF 

rating of residential clothes dryers and 

would not require the existing energy 

conservation standards for these 

products to be revised because DOE is 

not aware of any data indicating the 

changes to the detergent formula affects 

the ability of the clothes dryer to remove 

moisture from the clothes load during 

the drying cycle. For the reasons stated 

above and in the absence of comments 

objecting to this determination, DOE 

continues to believe that the change to 

the detergent specifications would not 

affect the EF rating of clothes dryers. 

Clothes Dryer Number of Annual Cycles 

The amendments for the number of 

annual use cycles, discussed in section 

III.C.5.a, affect only the estimated 

annual operating cost for all clothes 

dryers. The EF rating for clothes dryers 

is expressed in terms of the total energy 

use per drying cycle. Because the EF 

rating is measured on a per-cycle basis, 

the number of annual use cycles is not 

used in the calculation. For this reason, 

DOE stated in the June 2010 TP SNOPR 

that the proposed amendments to 

change the number of clothes dryer 

annual use cycles would not affect the 

EF rating of residential clothes dryers. 

Therefore, the proposed amendments 

would not require the existing energy 

conservation standards for these 

products to be revised. 

Whirlpool commented that the change 

in the number of annual use cycles has 

a linear effect ((416–283)/416 = 32 

percent), and therefore the clothes dryer 

would be rated as consuming 32 percent 

less energy under the proposed under 

the proposed test procedure. 

(Whirlpool, No. 27 at p. 5) The 

California Utilities/NRDC supported 

DOE’s proposed revisions to the energy 

conservation standards to account for 

changes to the cycles per year. 

(California Utilities/NRDC, No. 33 at p. 

6) DOE first notes it did not propose any 

revisions to the energy conservation 

standards to account for changes to the 

number of clothes dryer cycles per year. 

DOE notes that the current energy 

conservation standards for clothes 

dryers are based on EF and that changes 

to the number of annual use cycles does 

not affect EF for clothes dryers. As a 

result, DOE continues to believe that the 

amendments to change the number of 

clothes dryer annual use cycles would 

not affect the EF rating of residential 

clothes dryers. Therefore, the 

amendments would not require the 

existing energy conservation standards 

for these products to be revised. 

Clothes Dryer Initial Remaining 

Moisture Content 

In the June 2010 TP SNOPR, DOE 

evaluated how the amendments to the 

clothes dryer initial RMC discussed in 

section III.C.5.b affect the measured EF. 

DOE estimated, based on results of 

testing conducted at an independent 

testing laboratory, that the measured EF 

increases by 41 percent when the initial 

RMC is reduced to 47 percent. DOE 

stated that if the proposed amendments 

to change the initial RMC from 70 

percent ± 3.5 percent to 47 percent ± 3.5 

percent were implemented, current 

energy conservation standards in terms 

of EF for vented clothes dryer product 

classes would need to increase by 41 

percent. 75 FR 37594, 37631 (June 29, 

2010). 

The California Utilities/NRDC 

supported DOE’s proposed revisions to 

the energy conservation standards to 

account for changes in the initial RMC. 

(California Utilities/NRDC, No. 33 at p. 

6) Whirlpool commented that the 

change in RMC is not linear, but that it 

does not have sufficient data to fully 

address how this would be reflected in 

total energy consumption. Whirlpool 

recommended that further study 

regarding the impact of changing the 

RMC on the energy factor be 

undertaken. Whirlpool added that if 

DOE were to make a specific request to 

AHAM for such data, Whirlpool would 

be willing to gather and supply 

information to AHAM for aggregation 

and submittal to DOE. (Whirlpool, No. 

27 at pp 4, 5) The Joint Petitioners and 

AHAM both supported increasing EF for 

vented clothes dryer product classes to 

account for the change in initial RMC. 

The Joint Petitioners and AHAM also 

stated that they do not currently have 

data to quantify the increase, but upon 

DOE request would gather data to 

determine an appropriate increase. 

(Joint Petitioners, No. 30 at p. 7; AHAM, 

No. 31 at p. 9) The California Utilities/ 

NRDC supported DOE’s proposed 

revisions to the energy conservation 

standards to account for changes in test 

load weight, initial RMC, and cycles per 

year. (California Utilities/NRDC, No. 33 

at p. 6) ALS supported the manner in 

which DOE has analyzed the impact of 

its proposed revisions to the test 

procedure on the minimum standard. 

ALS requested the analysis be 

conducted using a methodology 

consistent with the ALS proposal of an 

initial RMC of 53 percent. (ALS, No. 24 

at p. 8) 

After issuance of the June 2010 TP 

SNOPR, DOE conducted additional 

clothes dryer testing on 17 

representative clothes dryers to evaluate 

the effects of the proposed amendment 

to change the initial RMC from 70 

percent ± 3.5 percent to 57.5 percent ± 

3.5 percent for the measured efficiency. 

DOE tested these units according to the 

current DOE clothes dryer test 

procedure with an initial RMC of 70 

percent ± 3.5 percent and with an initial 

RMC of 57.5 percent ± 3.5 percent. For 

the ventless clothes dryer test units, 

DOE additionally used the proposed 

testing method for ventless dryers 

presented in section III.C.3. For each 

initial RMC, DOE conducted up to three 

tests for each test unit and the results 

were averaged Table IV.2 below shows 

the results from the tests. The results 

indicate that, on average, EF increases 

by about 17.1 percent when the initial 

RMC is changed from 70 percent ± 3.5 

percent to 57.5 percent ± 3.5 percent. 

TABLE IV.2—DOE TEST RESULTS TO EVALUATE THE EFFECTS OF CHANGES TO THE INITIAL RMC 

Test unit 

Average EF lb/kWh 

% 

70% ± 3.5% Change 

RMC 

57.5% ± 3.5% 

RMC 

Vented Electric Standard: 

Unit 1 ............................................................................................................................................ 3.07 3.67 19.8 

Unit 2 ............................................................................................................................................ 3.14 3.62 15.1 

Unit 3 ............................................................................................................................................ 3.20 3.83 19.6 

Unit 4 ............................................................................................................................................ 3.28 3.79 15.5 


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41 J. Y. Kao. Energy Test Results of a Conventional 

Clothes Dryer and a Condensing Clothes Dryer. pp. 

11–21 1999. International Appliance Technical 

Conference, 49th. Proceedings. May 4–6,, 1998. 

TABLE IV.2—DOE TEST RESULTS TO EVALUATE THE EFFECTS OF CHANGES TO THE INITIAL RMC—Continued 

Test unit 

Average EF lb/kWh 

% 

70% ± 3.5% Change 

RMC 

57.5% ± 3.5% 

RMC 

Unit 5 ............................................................................................................................................ 3.24 3.91 20.9 

Unit 6 ............................................................................................................................................ 3.12 3.70 18.7 

Vented Gas: 

Unit 7 ............................................................................................................................................ 2.78 3.32 19.1 

Unit 8 ............................................................................................................................................ 2.83 3.43 20.9 

Unit 9 ............................................................................................................................................ 2.85 3.23 13.3 

Unit 10 .......................................................................................................................................... 2.80 3.29 17.5 

Unit 11 .......................................................................................................................................... 2.98 3.40 14.2 

Vented Electric Compact (240V): 

Unit 12 .......................................................................................................................................... 3.19 3.61 13.2 

Unit 13 .......................................................................................................................................... 2.93 3.45 17.7 

Vented Electric Compact (120V): 

Unit 14 .......................................................................................................................................... 3.23 4.08 26.1 

Ventless Electric Compact (240V): 

Unit 15 .......................................................................................................................................... 2.37 2.74 15.9 

Ventless Electric Combo Washer-Dryer: 

Unit 16 .......................................................................................................................................... 2.01 2.33 15.8 

Unit 17 .......................................................................................................................................... 2.50 2.70 8.0 

Clothes Dryer Test Load Weight 

As noted previously, EF for clothes 

dryers is the bone-dry test load weight 

divided by the clothes dryer energy 

consumption per cycle. DOE notes that 

the proposed amendments to the test 

load size, discussed in section III.C.5.c, 

would increase both the bone-dry test 

load weight and the energy 

consumption per cycle. For example, for 

a test in which the nominal RMC of the 

test load is reduced from an initial 70 

percent to a final 4 percent, an 8.45-lb 

test load would require about 5.6 lb of 

water to be removed during the drying 

cycle. However, a 7-lb. test load would 

require only 4.6 lb. of water to be 

removed. DOE also notes that as lower 

nominal RMCs are reached at the end of 

the test cycle, the rate and efficiency of 

water removal from the load would be 

higher for the larger test load. This is 

because there would simply be more 

water in the load, hence making it easier 

to remove. 

In the June 2010 TP SNOPR, DOE 

reviewed research on the effects of 

changing the load size on the measured 

efficiency to determine a quantifiable 

estimate of the change in the measured 

EF. 75 FR 37594, 37632 (June 29, 2010). 

NIST conducted testing to investigate 

the effects of changing the clothes dryer 

load size on the measured efficiency of 

a vented electric standard clothes dryer 

with a capacity of 6.3 ft3.41 NIST tested 

the clothes dryer according to the DOE 

clothes dryer test procedure, except the 

test load size varied from 2–15 lb. Table 

IV.3 presents the results of the NIST 

testing, which shows an increase in EF 

when the load size was increased in 7– 

9 lb. range, which for the purpose of 

analysis corresponds to the 7–8.45 lb. 

range. 

TABLE IV.3—NIST VENTED ELECTRIC STANDARD CLOTHES DRYER VARIABLE TEST LOAD DATA

Test Number 1 2 3 4 5 6 7 8 

Room Temperature, °F .................................................... 74 .1 74 .4 73 .8 73 .3 73 .8 74 .1 74 .4 74 .4 

Room Humidity, % ........................................................... 40 38 38 33 42 38 40 36 

Nominal Bone-Dry Weight, lb .......................................... 2 3 5 7 9 11 13 15 

Measured Bone-Dry Test Load Weight, lb ...................... 1 .99 2 .99 4 .99 7 .00 8 .99 10 .98 13 .01 15 .01 

Measured Dry Test Load Weight, lb ................................ 2 .05 3 .06 5 .17 7 .99 9 .11 11 .56 13 .57 15 .71 

Measured Wet Test Load Weight, lb ............................... 3 .40 5 .10 8 .50 11 .89 15 .34 18 .98 22 .04 25 .56 

Measured Energy Consumption, kWh ............................. 0 .953 1 .159 1 .593 2 .112 2 .667 3 .250 3 .796 4 .384 

Initial RMC, % .................................................................. 70 .30 70 .67 70 .52 69 .99 70 .67 72 .81 69 .35 70 .34 

Final RMC, % ................................................................... 2 .84 2 .48 3 .73 2 .88 1 .28 5 .27 4 .29 4 .67 

Per-Cycle Energy Consumption, kWh ............................. 0 .970 1 .167 1 .637 2 .160 2 .638 3 .303 4 .005 4 .582 

EF, lb/kWh ....................................................................... 2 .06 2 .56 3 .04 3 .24 3 .41 3 .33 3 .25 3 .27 

Percentage Change in EF Compared to 7-lb Test, % .... ¥36 .6 ¥20 .9 ¥6 .0 0 .0 5 .2 2 .7 0 .3 1 .1 

In the June 2010 TP SNOPR, DOE 

estimated the percentage change in EF 

for an 8.45-lb test load by linearly 

interpolating the results for the 7-lb and 

9-lb tests. Estimates based on this 

method showed the EF increase by 

about 3.8 percent when the test load 

size increased from 7 lb. to 8.45 lb. DOE 

stated that this percentage change in EF 

can be applied to all vented standardsize clothes dryer product classes 

because the moisture removal 

mechanisms are comparable among 

them. For these reasons, DOE stated that 

if the proposed amendments to increase 

the test load size to 8.45 ± .085 lb for 

standard-size clothes dryers were 

implemented, the current energy 

conservation standards in terms of EF 

for vented standard-size clothes dryer 

product classes would need to be 


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increased by 3.8 percent. 75 FR 37594, 

37632 (June 29, 2010). 

The California Utilities/NRDC 

supported DOE’s proposed revisions to 

the energy conservation standards to 

account for changes to the test load 

weight. (California Utilities/NRDC, No. 

33 at p. 6) Whirlpool commented that 

the change in load size is not linear, but 

that it does not have sufficient data to 

fully address how this would be 

reflected in total energy consumption. 

Whirlpool commented that if DOE were 

to make a specific request to AHAM for 

such data, Whirlpool would be willing 

to gather and supply information to 

AHAM for aggregation and submittal to 

DOE. (Whirlpool, No. 27 at p. 5) The 

Joint Petitioners and AHAM supported 

DOE’s proposal to revise the relevant 

energy conservation standards to reflect 

the new test load weight. The Joint 

Petitioners and AHAM stated they do 

not currently have data that would 

support a specific test load weight, but 

upon DOE request would gather such 

data. (Joint Petitioners, No. 30 at p. 7; 

AHAM, No. 31 at p. 9) 

DOE conducted additional clothes 

dryer testing after issuance of the June 

2010 TP SNOPR on 11 representative 

standard size clothes dryers to evaluate 

the effects of the proposed amendment 

to increase the test load size for 

standard-size clothes dryers on the 

measured efficiency. DOE tested these 

units according to the current DOE 

clothes dryer test procedure with a 7.00 

± .07 lb load and at the increased test 

load size of 8.45 ± .085 lb for standardsize clothes dryers. For the ventless 

clothes dryer test units, DOE 

additionally used the proposed testing 

method for ventless dryers presented in 

section III.C.3. For each test load weight, 

DOE conducted up to three tests for 

each test unit and the results were 

averaged. Table IV.4 below shows the 

results from this testing, which indicate 

that, on average, measured EF increases 

by about 2.6 percent when the test load 

weight is increased to 8.45 ± .085 lb for 

standard-size clothes dryers. DOE 

believes the 2.6 percent increase in 

measured EF represents a more accurate 

estimate than the 3.8 percent increase 

because the 2.6 percent increase in 

measured EF is based on more extensive 

testing on a representative sample of 

clothes dryers. 

TABLE IV.4—DOE TEST RESULTS TO EVALUATE THE EFFECTS OF CHANGES TO TEST LOAD WEIGHT FOR STANDARD-SIZE

CLOTHES DRYERS

Test unit 

Average EF lb/kWh Percent 

change 7.00 ± .07 lb 8.45 ± .085 lb 

Vented Electric Standard: 

Unit 1 ............................................................................................................................................ 3.07 3.13 2.0 

Unit 2 ............................................................................................................................................ 3.14 3.21 2.1 

Unit 3 ............................................................................................................................................ 3.20 3.28 2.5 

Unit 4 ............................................................................................................................................ 3.28 3.50 6.7 

Unit 5 ............................................................................................................................................ 3.24 3.34 3.1 

Unit 6 ............................................................................................................................................ 3.12 3.13 0.4 

Vented Gas: 

Unit 7 ............................................................................................................................................ 2.78 2.85 2.5 

Unit 8 ............................................................................................................................................ 2.83 2.93 3.3 

Unit 9 ............................................................................................................................................ 2.85 3.00 5.2 

Unit 10 .......................................................................................................................................... 2.80 2.77 ¥0.9 

Unit 11 .......................................................................................................................................... 2.98 3.02 1.5 

All Active Mode Amendments 

DOE also analyzed how the fully 

amended test procedure would affect 

the measured EF as compared to the 

existing test procedure. In the June 2010 

TP SNOPR, DOE tested and analyzed 

minimally compliant clothes dryers, 

and reviewed available research. DOE 

found that the proposed amendments to 

the initial RMC would increase the 

measured EF of minimally compliant 

clothes dryers by 41 percent, while the 

proposed amendments to the test load 

size for standard-size clothes dryers 

would increase the measured EF for 

standard-size dryers by 3.8 percent. 

DOE also found that because of the 

proposed amendments in the June 2010 

TP SNOPR, the measured EF of 

minimally compliant clothes dryers 

would increase by about 41 percent for 

compact-size clothes dryers and about 

46 percent for standard-size clothes 

dryers (determined multiplying the 41 

percent increase for the decrease in the 

initial RMC by the 3.8 percent increase 

for the increase in test load size for 

standard-size clothes dryers). 75 FR 

37594, 37638 (June 29, 2010). 

The Joint Petitioners stated that the 

final rule amending the clothes dryer 

test procedure should also amend the 

standards in their Joint Petition. The 

standards in the Joint Petition would be 

amended according to the procedures in 

section 323(e)(2), except that to 

establish a representative sample of 

products, DOE shall choose a sample of 

minimally compliant clothes dryers that 

automatically terminate the drying cycle 

at no less than 4 percent RMC. (Joint 

Petitioners, No. 25 at p. 6) In conducting 

the analysis under 42 U.S.C. 6293(3)(2) 

for the current clothes dryer energy 

conservation standards, DOE notes that 

as discussed in section I, EPCA requires 

that in determining the amended energy 

conservation standard, DOE must 

measure, pursuant to the amended test 

procedure, the energy efficiency, energy 

use, or water use of a representative 

sample of covered products that 

minimally comply with the existing 

standard and that the average of such 

energy efficiency, energy use, or water 

use levels determined under the 

amended test procedure shall constitute 

the amended energy conservation 

standard for the applicable covered 

products. (42 U.S.C. 6293(e)(2)) DOE 

notes that EPCA requires testing of a 

representative sample of minimally 

compliant products, and that the 

measurement of only clothes dryers that 

automatically terminate the drying cycle 

at no less than 4 percent RMC would 

not constitute a representative sample. 

In addition, for the reasons discussed in 

section III.C.2, DOE is not adopting in 

today’s final rule the amendments for 

automatic cycle termination proposed in 

the June 2010 TP SNOPR. For these 

reasons, DOE does not intend to 

consider such limitations for product 

testing to determine the effects of the 

amended test procedure on the 

measured efficiency. 

DOE conducted clothes dryer testing 

on a sample of 17 representative clothes 

dryers after issuance of the June 2010 


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TP SNOPR to evaluate the effects of all 

of the amendments on the clothes dryer 

test procedure on the measured EF. DOE 

tested these units according to the 

amended clothes dryer test procedure in 

today’s final rule. DOE conducted up to 

three tests for each test unit and the 

results were averaged. The results from 

this testing are shown in Table IV.5. For 

vented electric standard-size clothes 

dryers, the measured EF increases by an 

average of about 20.1 percent as a result 

of the amendments to the test procedure 

in today’s final rule. For vented gas 

clothes dryers, the measured EF 

increased by an average of about 19.8 

percent. For vented electric compactsize 120V and 240V clothes dryers, the 

measured EF increased by an average of 

about 15.6 and 12.8 percent, 

respectively. For ventless electric 

compact 240V clothes dryers and 

ventless electric combination washer/ 

dryers, the measured EF increased by an 

average of about 13.6 and 11.4 percent, 

respectively. DOE notes that the 

increase in measured EF is greater for 

the standard-size products (that is, for 

vented electric standard-size and vented 

gas clothes dryers) than for compact-size 

products due to the additional 

amendments that specify increased test 

load sizes for standard-size products. 

These measured increases in EF are 

different from the values presented in 

the June 2010 TP SNOPR, and shown 

above in this section. This is because 

the initial RMC was changed from 47 

percent to 57.5 percent and the change 

to the water temperature specified for 

test load preparation. These values are 

also based on more extensive testing on 

a representative sample of clothes 

dryers. 

TABLE IV.5—DOE TEST RESULTS TO EVALUATE THE EFFECTS OF THE TEST PROCEDURE AMENDMENTS ON MEASURED

EF 

Test unit 

Average EF lb/kWh 

Percent 

Current test change 

procedure 

Amended test 

procedure 

Vented Electric Standard: 

Unit 1 ............................................................................................................................................ 3.07 3.69 20.4 

Unit 2 ............................................................................................................................................ 3.14 3.77 19.5 

Unit 3 ............................................................................................................................................ 3.20 3.83 19.6 

Unit 4 ............................................................................................................................................ 3.28 3.92 19.4 

Unit 5 ............................................................................................................................................ 3.24 3.96 22.5 

Unit 6 ............................................................................................................................................ 3.12 3.72 19.1 

Vented Gas: 

Unit 7 ............................................................................................................................................ 2.78 3.36 20.6 

Unit 8 ............................................................................................................................................ 2.83 3.40 19.9 

Unit 9 ............................................................................................................................................ 2.85 3.42 20.2 

Unit 10 .......................................................................................................................................... 2.80 3.37 20.5 

Unit 11 .......................................................................................................................................... 2.98 3.50 17.6 

Vented Electric Compact (240V): 

Unit 12 .......................................................................................................................................... 3.19 3.56 11.4 

Unit 13 .......................................................................................................................................... 2.93 3.35 14.2 

Vented Electric Compact (120V): 

Unit 14 .......................................................................................................................................... 3.23 3.74 15.6 

Ventless Electric Compact (240V): 

Unit 15 .......................................................................................................................................... 2.37 2.69 13.6 

Ventless Electric Combo Washer-Dryer: 

Unit 16 .......................................................................................................................................... 2.01 2.27 12.5 

Unit 17 .......................................................................................................................................... 2.50 2.76 10.3 

Table IV.6 shows how the current 

energy conservation standards would be 

affected by the amendments to the DOE 

clothes dryer test procedure. DOE will 

consider such changes in the concurrent 

energy conservation standards 

rulemaking for clothes dryers and room 

air conditioners. 

TABLE IV.6—ENERGY FACTOR OF A MINIMALLY COMPLIANT CLOTHES DRYER WITH THE CURRENT AND PROPOSED

AMENDED TEST PROCEDURE

Product class 

Energy factor lb/kWh 

Current test 

procedure 

Proposed 

amended 

test 

procedure 

1. Electric, Standard (4.4 ft3 or greater capacity) ........................................................................................................... 3.01 3.62 

2. Electric, Compact (120 v) (less than 4.4 ft3 capacity) ................................................................................................ 3.13 3.62 

3. Electric, Compact (240 v) (less than 4.4 ft3 capacity) ................................................................................................ 2.90 3.27 

4. Gas .............................................................................................................................................................................. 2.67 3.20 

Because the clothes dryer test 

procedure amendments for active mode 

would substantially change the existing 

EF metric, DOE has decided to create a 

new appendix D1 in 10 CFR 430 subpart 

B. This appendix contains a clothes 

dryer test procedure that manufacturers 

would be required to use on the 

mandatory compliance date of any 


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42For more information visit: http:// 

www.sba.gov/. 

43A searchable database of certified small 

businesses is available online at: http:// 

dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm. 

amended clothes dryer energy 

conservation standards. DOE is required 

by consent decree to publish the final 

rule for any amended clothes dryer 

energy conservation standards 

rulemaking by June 30, 2011, and the 

compliance date of any amended 

standards is expected to be 3 years later. 

Manufacturers must continue to use 

appendix D to subpart B of part 430 for 

clothes dryers until compliance with 

any amended energy conservation 

standards at 10 CFR 430.32(h) is 

required, at which point use of the 

procedures at appendix D1 will be 

required. 

C. Active Mode—Room Air Conditioners 

As discussed in section III.C.6, DOE 

amends the room air conditioner test 

procedure in today’s final rule to update 

the references to the industry test 

standards, ANSI/AHAM RAC–1–R2008 

and ANSI/ASHRAE Standard 16–1983 

(RA 2009). These amendments provide 

more accurate and repeatable 

measurements of capacity while 

providing greater flexibility to 

manufacturers in selecting equipment 

and facilities but do not impact the 

measurement of EER. Because DOE’s 

review of the room air conditioner test 

procedure amendments tentatively 

concluded that the measured EER 

would not be affected, manufacturers 

must continue to use appendix F to 

measure room air conditioner active 

mode energy use. Manufacturers would 

not be required to use the proposed 

provisions for standby mode and off 

mode energy use (specifically, sections 

2.2, 3.2, 4.2, and 5.3) until the 

mandatory compliance date of any 

amended room air conditioner energy 

conservation standards. 

The Joint Petitioners proposed that 

the final rule amending the room air 

conditioner test procedure must also 

amend the standards in the Joint 

Petition according to the procedures in 

section 323(e)(2). (Joint Petitioners, No. 

25 at p. 7) As noted above, DOE believes 

that the amendments to the room air 

conditioner test procedure in today’s 

final rule would not affect the measured 

efficiency of covered products, and DOE 

is not aware of any data indicating 

otherwise. For these reasons, DOE 

continues to believe that revisions to the 

energy conservation standards for room 

air conditioners are not warranted. 

All representations related to standby 

mode and off mode energy consumption 

of both clothes dryers and room air 

conditioners made 180 days after the 

publication of today’s test procedure 

final rule in the Federal Register and 

before the compliance date of amended 

energy conservation standards must be 

based upon the standby mode and off 

mode requirements of the amended test 

procedures. The requirements are 

specified in appendix D1 for clothes 

dryers, and in amended appendix F for 

room air conditioners. 

V. Procedural Requirements 

A. Review Under Executive Order 12866 

The Office of Management and Budget 

has determined that test procedure 

rulemakings do not constitute 

‘‘significant regulatory actions’’ under 

section 3(f) of Executive Order 12866, 

Regulatory Planning and Review, 58 FR 

51735 (Oct. 4, 1993). Accordingly, this 

proposed action was not subject to 

review under the Executive Order by the 

Office of Information and Regulatory 

Affairs (OIRA) in the Office of 

Management and Budget (OMB). 

B. Review Under the Regulatory 

Flexibility Act 

The Regulatory Flexibility Act (5 

U.S.C. 601 et seq.) requires preparation 

of an initial regulatory flexibility 

analysis for any rule that by law must 

be proposed for public comment, unless 

the agency certifies that the rule, if 

promulgated, will not have a significant 

economic impact on a substantial 

number of small entities. As required by 

Executive Order 13272, ‘‘Proper 

Consideration of Small Entities in 

Agency Rulemaking,’’ 67 FR 53461 (Aug. 

16, 2002), DOE published procedures 

and policies on February 19, 2003 to 

ensure that the potential impacts of its 

rules on small entities are properly 

considered during the rulemaking 

process. 68 FR 7990. DOE’s procedures 

and policies may be viewed on the 

Office of the General Counsel’s Web site 

(http://www.gc.doe.gov). 

DOE reviewed today’s final rule under 

the provisions of the Regulatory 

Flexibility Act and the procedures and 

policies published on February 19, 

2003. This final rule prescribes 

amendments to test procedures that will 

be used to test compliance with energy 

conservation standards for clothes 

dryers and room air conditioners that 

are described in detail elsewhere in the 

preamble. DOE certifies that this final 

rule will not have a significant impact 

on a substantial number of small 

entities. The factual basis for this 

certification is as follows. 

The Small Business Administration 

(SBA) considers an entity to be a small 

business if, together with its affiliates, it 

employs less than a threshold number of 

workers specified in 13 CFR part 121. 

The thresholds set forth in these 

regulations are based on size standards 

and codes established by the North 

American Industry Classification 

System (NAICS).42 The threshold 

number for NAICS classification for 

335224, ‘‘Household Laundry 

Equipment Manufacturing,’’ which 

includes clothes dryer manufacturers, is 

1,000 employees. Additionally, the 

threshold number for NAICS 

classification for 335415, ‘‘AirConditioning and Warm Air Heating 

Equipment and Commercial and 

Industrial Refrigeration Equipment 

Manufacturing,’’ which includes room 

air conditioner manufacturers, is 750 

employees. 

Most of the manufacturers supplying 

clothes dryers and room air conditioners 

are large multinational corporations. As 

part of the energy conservation 

standards rulemaking for residential 

clothes dryers and room air 

conditioners, DOE requested comment 

on whether there are any manufacturer 

subgroups, including potential small 

businesses, that it should consider for 

its analyses. DOE did not receive any 

comments regarding whether there are 

any residential clothes dryer or room air 

conditioner manufacturers that would 

be considered small businesses. DOE 

then conducted a more focused inquiry 

of the companies that could be small 

business manufacturers of products 

covered by this rulemaking. During its 

market survey, DOE used all available 

public information to identify potential 

small manufacturers. DOE’s research 

included the AHAM membership 

directory, product databases (the AHRI, 

AHAM, CEC, and ENERGY STAR 

databases), individual company 

websites, and the SBA dynamic small 

business search 43 to find potential small 

business manufacturers. DOE also asked 

interested parties and industry 

representatives if they were aware of 

any other small business manufacturers 

during manufacturer interviews 

conducted and at DOE public meetings 

for the energy conservation standards 

rulemakings. DOE also contacted 

various companies, as necessary, to 

determine whether they met the SBA’s 

definition of a small business 

manufacturer of covered residential 

clothes dryers or room air conditioners. 

DOE screened out companies that did 

not offer products covered by this 

rulemaking, did not meet the definition 

of a ‘‘small business,’’ or are foreign 

owned and operated. 

DOE initially identified at least 14 

manufacturers of residential clothes 


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dryers that sold products in the United 

States. DOE determined that 13 of these 

companies exceeded the SBA’s 

maximum number of employees or 

foreign-owned and operated. Thus, DOE 

identified only one potential small 

business manufacturer of residential 

clothes dryers but could not locate this 

manufacturer on the dynamic small 

business search on the SBA website. In 

addition, upon further review, DOE 

does not believe that the small business 

is a clothes dryer manufacturer. While 

the manufacturer has developed a 

highly efficient technology that, while 

not yet commercially available, could be 

used by other manufacturers to increase 

the efficiency of clothes dryers, it does 

not produce clothes dryers. Because the 

company plans to produce only a 

technology for clothes dryers that is not 

yet commercially available, this 

potential small business manufacturer 

has no market share of the residential 

clothes dryer market. 

For room air conditioners, DOE 

initially identified at least 11 

manufacturers of room air conditioners 

that sold products in the United States. 

DOE determined that 10 of these were 

large or foreign-owned and operated. In 

addition, DOE subsequently determined 

that the one room air conditioner 

manufacturer that was previously 

designated as a small business 

manufacturer now exceeds SBA’s 

employment threshold for consideration 

as a small business under the 

appropriate NAICS code specified 

above. 

DOE received no comments on the 

certification, and comments on the 

testing burden are discussed elsewhere 

in the preamble and did not result in 

changes to the certification. For these 

reasons, DOE certifies that the 

amendments in today’s final rule will 

not have a significant economic impact 

on a substantial number of small 

entities. 

Based on the above, DOE has not 

prepared a regulatory flexibility analysis 

for this rulemaking. DOE transmitted 

the certification and supporting 

statement of factual basis to the Chief 

Counsel for Advocacy of the SBA for 

review under 5 U.S.C. 605(b). 

C. Review Under the Paperwork 

Reduction Act of 1995 

Manufacturers of clothes dryers and 

room air conditioners must certify to 

DOE that their products comply with 

any applicable energy conservation 

standard. In certifying compliance, 

manufacturers must test their products 

according to the DOE test procedures for 

clothes dryers and room air 

conditioners, including any 

amendments adopted for those test 

procedures. DOE has proposed 

regulations for the certification and 

recordkeeping requirements for all 

covered consumer products and 

commercial equipment, including 

clothes dryers and room air 

conditioners. 75 FR 56796 (Sept. 16, 

2010). The collection-of-information 

requirement for the certification and 

recordkeeping is subject to review and 

approval by OMB under the Paperwork 

Reduction Act (PRA). This requirement 

has been submitted to OMB for 

approval. Public reporting burden for 

the certification is estimated to average 

20 hours per response, including the 

time for reviewing instructions, 

searching existing data sources, 

gathering and maintaining the data 

needed, and completing and reviewing 

the collection of information. 

Public comment is sought regarding: 

Whether this proposed collection of 

information is necessary for the proper 

performance of the functions of the 

agency, including whether the 

information shall have practical utility; 

the accuracy of the burden estimate; 

ways to enhance the quality, utility, and 

clarity of the information to be 

collected; and ways to minimize the 

burden of the collection of information, 

including through the use of automated 

collection techniques or other forms of 

information technology. Send comments 

on these or any other aspects of the 

collection of information to Subid 

Wagley at the ADDRESSES above, and 

e-mail to 

Christine_J._Kymn@omb.eop.gov. 

Notwithstanding any other provision 

of the law, no person is required to 

respond to, nor shall any person be 

subject to a penalty for failure to comply 

with, a collection of information subject 

to the requirements of the PRA, unless 

that collection of information displays a 

currently valid OMB Control Number. 

D. Review Under the National 

Environmental Policy Act of 1969 

In this final rule, DOE is adopting test 

procedure amendments that it expects 

will be used to develop and implement 

future energy conservation standards for 

clothes dryers and room air 

conditioners. DOE has determined that 

this rule falls into a class of actions that 

are categorically excluded from review 

under the National Environmental 

Policy Act of 1969 (42 U.S.C. 4321 et 

seq.) and DOE’s implementing 

regulations at 10 CFR part 1021. 

Specifically, this rule amends an 

existing rule without changing its 

environmental effect, and, therefore, is 

covered by the Categorical Exclusion in 

10 CFR part 1021, subpart D, paragraph 

A5, which applies because this rule 

establishes revisions to existing test 

procedures that will not affect the 

amount, quality, or distribution of 

energy usage, and, therefore, will not 

result in any environmental impacts. 

Accordingly, neither an environmental 

assessment nor an environmental 

impact statement is required. 

E. Review Under Executive Order 13132 

Executive Order 13132, ‘‘Federalism,’’ 

imposes certain requirements on 

agencies formulating and implementing 

policies or regulations that preempt 

State law or that have Federalism 

implications. 64 FR 43255 (August 10, 

1999). The Executive Order requires 

agencies to examine the constitutional 

and statutory authority supporting any 

action that would limit the 

policymaking discretion of the States, 

and to carefully assess the necessity for 

such actions. The Executive Order also 

requires agencies to have an accountable 

process to ensure meaningful and timely 

input by State and local officials in the 

development of regulatory policies that 

have Federalism implications. On 

March 14, 2000, DOE published a 

statement of policy describing the 

intergovernmental consultation process 

that it will follow in developing such 

regulations. 65 FR 13735. DOE 

examined this final rule and determined 

that it will not preempt State law and 

will not have a substantial direct effect 

on the States, on the relationship 

between the national government and 

the States, or on the distribution of 

power and responsibilities among the 

various levels of government. EPCA 

governs and prescribes Federal 

preemption of State regulations as to 

energy conservation for the products 

that are the subject of today’s final rule. 

States can petition DOE for exemption 

from such preemption to the extent, and 

based on criteria, set forth in EPCA. (42 

U.S.C. 6297(d)) Therefore, Executive 

Order 13132 requires no further action. 

F. Review Under Executive Order 12988 

Regarding the review of existing 

regulations and the promulgation of 

new regulations, section 3(a) of 

Executive Order 12988, ‘‘Civil Justice 

Reform,’’ 61 FR 4729 (Feb. 7, 1996), 

imposes on Federal agencies the general 

duty to adhere to the following 

requirements: (1) Eliminate drafting 

errors and ambiguity; (2) write 

regulations to minimize litigation; 

(3) provide a clear legal standard for 

affected conduct rather than a general 

standard; and (4) promote simplification 

and burden reduction. Section 3(b) of 

Executive Order 12988 specifically 

requires that Executive agencies make 


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every reasonable effort to ensure that the 

regulation specifies the following: (1) 

The preemptive effect, if any; (2) any 

effect on existing Federal law or 

regulation; (3) a clear legal standard for 

affected conduct while promoting 

simplification and burden reduction; 

(4) the retroactive effect, if any; (5) 

definitions of key terms; and (6) other 

important issues affecting clarity and 

general draftsmanship under any 

guidelines issued by the Attorney 

General. Section 3(c) of Executive Order 

12988 requires Executive agencies to 

review regulations in light of applicable 

standards in sections 3(a) and 3(b) to 

determine whether they are met or 

whether it is unreasonable to meet one 

or more of them. DOE has completed the 

required review and determined that, to 

the extent permitted by law, this final 

rule meets the relevant standards of 

Executive Order 12988. 

G. Review Under the Unfunded 

Mandates Reform Act of 1995 

Title II of the Unfunded Mandates 

Reform Act of 1995 (UMRA) (Pub. L. 

104–4; 2 U.S.C. 1501 et seq.) requires 

each Federal agency to assess the effects 

of Federal regulatory actions on State, 

local, and Tribal governments and the 

private sector. For a proposed regulatory 

action likely to result in a rule that may 

cause the expenditure by State, local, 

and Tribal governments, in the 

aggregate, or by the private sector of 

$100 million or more in any one year 

(adjusted annually for inflation), section 

202 of UMRA requires a Federal agency 

to publish estimates of the resulting 

costs, benefits, and other effects on the 

national economy. (2 U.S.C. 1532(a),(b)) 

UMRA also requires a Federal agency to 

develop an effective process to permit 

timely input by elected officers of State, 

local, and Tribal governments on a 

proposed ‘‘significant intergovernmental 

mandate,’’ and requires an agency plan 

for giving notice and opportunity for 

timely input to potentially affected 

small governments before establishing 

any requirements that might 

significantly or uniquely affect such 

governments. On March 18, 1997, DOE 

published a statement of policy on its 

process for intergovernmental 

consultation under UMRA. 62 FR 

12820. (The policy is also available at 

http://www.gc.doe.gov). DOE reviewed 

today’s final rule under the statutory 

requirements and its policy and 

determined that the rule contains 

neither an intergovernmental mandate 

nor a mandate that may result in an 

expenditure of $100 million or more in 

any year, so these requirements do not 

apply. 

H. Review Under the Treasury and 

General Government Appropriations 

Act, 1999 

Section 654 of the Treasury and 

General Government Appropriations 

Act, 1999 (Pub. L. 105–277) requires 

Federal agencies to issue a Family 

Policymaking Assessment for any rule 

that may affect family well-being. 

Today’s final rule will not have any 

impact on the autonomy or integrity of 

the family as an institution. 

Accordingly, DOE has concluded that it 

is not necessary to prepare a Family 

Policymaking Assessment. 

I. Review Under Executive Order 12630 

DOE has determined, under Executive 

Order 12630, ‘‘Governmental Actions 

and Interference with Constitutionally 

Protected Property Rights,’’ 53 FR 8859 

(March 18, 1988), that this regulation 

will not result in any takings that might 

require compensation under the Fifth 

Amendment to the U.S. Constitution. 

J. Review Under the Treasury and 

General Government Appropriations 

Act, 2001 

Section 515 of the Treasury and 

General Government Appropriations 

Act, 2001 (44 U.S.C. 3516 note) provides 

for agencies to review most 

disseminations of information to the 

public under guidelines established by 

each agency pursuant to general 

guidelines issued by OMB. OMB’s 

guidelines were published at 67 FR 

8452 (Feb. 22, 2002), and DOE’s 

guidelines were published at 67 FR 

62446 (Oct. 7, 2002). DOE has reviewed 

today’s final rule under OMB and DOE 

guidelines and has concluded that it is 

consistent with applicable policies in 

those guidelines. 

K. Review Under Executive Order 13211 

Executive Order 13211, ‘‘Actions 

Concerning Regulations That 

Significantly Affect Energy Supply, 

Distribution, or Use,’’ 66 FR 28355 (May 

22, 2001), requires Federal agencies to 

prepare and submit to OIRA a Statement 

of Energy Effects for any proposed 

significant energy action. A ‘‘significant 

energy action’’ is defined as any action 

by an agency that promulgates or is 

expected to lead to promulgation of a 

final rule, and that: (1) Is a significant 

regulatory action under Executive Order 

12866, or any successor order; and (2) 

is likely to have a significant adverse 

effect on the supply, distribution, or use 

of energy; or (3) is designated by the 

Administrator of OIRA as a significant 

energy action. For any proposed 

significant energy action, the agency 

must give a detailed statement of any 

adverse effects on energy supply, 

distribution, or use if the proposal is 

implemented, and of reasonable 

alternatives to the action and their 

expected benefits on energy supply, 

distribution, and use. Today’s regulatory 

action to establish amended test 

procedures for clothes dryers and room 

air conditioners is not a significant 

regulatory action under Executive Order 

12866. It has likewise not been 

designated as a significant energy action 

by the Administrator of OIRA. 

Moreover, it will not have a significant 

adverse effect on the supply, 

distribution, or use of energy. Therefore, 

it is not a significant energy action, and, 

accordingly, DOE has not prepared a 

Statement of Energy Effects. 

L. Review Under Section 32 of the 

Federal Energy Administration Act of 

1974 

Under section 301 of the DOE 

Organization Act (Pub. L. 95–91; 42 

U.S.C. 7101 et seq.), DOE must comply 

with section 32 of the Federal Energy 

Administration Act of 1974, as amended 

by the Federal Energy Administration 

Authorization Act of 1977 (FEAA). (15 

U.S.C. 788) Section 32 essentially 

provides in part that, where a proposed 

rule authorizes or requires use of 

commercial standards, the rulemaking 

must inform the public of the use and 

background of such standards. In 

addition, section 32(c) requires DOE to 

consult with the Attorney General and 

the Chairman of the Federal Trade 

Commission (FTC) concerning the 

impact of the commercial or industry 

standards on competition. 

The amendments to the test 

procedures in today’s final rule 

incorporate testing methods contained 

in the commercial standard, IEC 

Standard 62301. Specifically DOE is 

incorporating from section 4, (‘‘General 

conditions for measurements’’), 

paragraph 4.2, ‘‘Test room,’’ paragraph 

4.3, ‘‘Power supply,’’ paragraph 4.4, 

‘‘Supply voltage waveform,’’ and 

paragraph 4.5, ‘‘Power measurement 

accuracy,’’ and from section 5 

(‘‘Measurements’’), paragraph 5.1, 

‘‘General,’’ paragraph 5.2, ‘‘Selection and 

preparation of appliance or equipment,’’ 

and paragraph 5.3, ‘‘Procedure’’ of IEC 

Standard 62301. DOE has evaluated this 

standard and is unable to conclude 

whether it fully complies with the 

requirements of section 32(b) of the 

FEAA (that is, whether it was developed 

in a manner that fully provides for 

public participation, comment, and 

review.) DOE has consulted with the 

Attorney General and the Chairman of 

the FTC about the impact on 

competition of using the methods 

contained in this standard, and neither 


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recommended against incorporation of 

these standards. 

M. Congressional Notification 

As required by 5 U.S.C. 801, DOE will 

report to Congress on the promulgation 

of today’s rule before its effective date. 

The report will state that it has been 

determined that the rule is not a ‘‘major 

rule’’ as defined by 5 U.S.C. 801(2). 

VI. Approval of the Office of the 

Secretary 

The Secretary of Energy has approved 

publication of today’s final rule. 

List of Subjects in 10 CFR Part 430 

Administrative practice and 

procedure, Confidential business 

information, Energy conservation, 

Household appliances, Imports, 

Incorporation by reference, 

Intergovernmental relations, Small 

businesses. 

Issued in Washington, DC, on December 

15, 2010. 

Cathy Zoi, 

Assistant Secretary, Energy Efficiency and 

Renewable Energy. 

■ For the reasons stated in the preamble, 

part 430 of chapter II of title 10, of the 

Code of Federal Regulations, is 

amended as set forth below: 

PART 430—ENERGY CONSERVATION 

PROGRAM FOR CONSUMER 

PRODUCTS 

■ 1. The authority citation for part 430 

continues to read as follows: 

Authority: 42 U.S.C. 6291–6309; 28 U.S.C. 

2461 note. 

■ 2. Section 430.3 is amended by: 

■ a. Redesignating paragraphs (e)(1) 

through (e)(9) as (e)(2) through (e)(10). 

■ b. Adding a new paragraph (e)(1). 

■ c. Removing the word ‘‘Standard’’ from 

paragraph (g)(3). 

■ d. Redesignating paragraphs (g)(1), (2), 

and (3) as paragraphs (g)(3), (1), and (4), 

respectively. 

■ e. Adding new paragraphs (g)(2) and 

(5). 

■ d. Removing in paragraph (1)(1), 

‘‘Appendix N to Subpart B’’, and adding 

in its place, ‘‘Appendix D1, Appendix F 

and Appendix N to Subpart B’’. 

The additions read as follows: 

§ 430.3 Materials incorporated by 

reference. 

* * * * * 

(e) * * * 

(1) ANSI/ASHRAE Standard 16–1983 

(‘‘ANSI/ASHRAE 16’’) (RA 2009), 

(Reaffirmation of ANSI/ASHRAE 

Standard 16–1983 [RA 1999]), Method 

of Testing for Rating Room Air 

Conditioners and Packaged Terminal 

Air Conditioners, ASHRAE approved 

October 18, 1988, and reaffirmed June 

20, 2009. ANSI approved October 20, 

1998 and reaffirmed June 25, 2009. IBR 

approved for Appendix F to Subpart B. 

* * * * * 

(g) * * * 

(2) AHAM HLD–1–2009 (‘‘AHAM 

HLD–1’’), Household Tumble Type 

Clothes Dryers, (2009), IBR approved for 

Appendix D1 to Subpart B. 

* * * * * 

(5) ANSI/AHAM RAC–1–2008 

(‘‘ANSI/AHAM RAC–1’’), Room Air 

Conditioners, (2008; ANSI approved 

July 7, 2008), IBR approved for 

Appendix F to Subpart B. 

* * * * * 

■ 3. Section 430.23 is amended by 

revising paragraphs (d) and (f) to read as 

follows: 

§ 430.23 Test procedures for the 

measurement of energy and water 

consumption. 

* * * * * 

(d) Clothes dryers. (1) The estimated 

annual operating cost for clothes dryers 

shall be— 

(i) For an electric clothes dryer, the 

product of the following three factors: 

(A) The representative average-use 

cycle of 283 cycles per year, 

(B) The per-cycle combined total 

energy consumption in kilowatt-hours 

per-cycle, determined according to 4.6 

of appendix D1 to this subpart, and 

(C) The representative average unit 

cost of electrical energy in dollars per 

kilowatt-hour as provided by the 

Secretary, the resulting product then 

being rounded off to the nearest dollar 

per year, and 

(ii) For a gas clothes dryer, the 

product of the representative averageuse cycle of 283 cycles per year times 

the sum of: 

(A) The product of the per-cycle gas 

dryer electric energy consumption in 

kilowatt-hours per cycle, determined 

according to 4.2 of appendix D1 to this 

subpart, times the representative 

average unit cost of electrical energy in 

dollars per kilowatt-hour as provided by 

the Secretary plus, 

(B) The product of the per-cycle gas 

dryer gas energy consumption, in Btus 

per cycle, determined according to 4.3 

of appendix D1 to this subpart, times 

the representative average unit cost for 

natural gas or propane, as appropriate, 

in dollars per Btu as provided by the 

Secretary, the resulting product then 

being rounded off to the nearest dollar 

per year plus, 

(C) The product of the per-cycle 

standby mode and off mode energy 

consumption in kilowatt-hours per 

cycle, determined according to 4.5 of 

appendix D1 to this subpart, times the 

representative average unit cost of 

electrical energy in dollars per kilowatthour as provided by the Secretary. 

(2) The energy factor, expressed in 

pounds of clothes per kilowatt-hour, for 

clothes dryers shall be either the 

quotient of a 3-pound bone-dry test load 

for compact dryers, as defined by 2.7.1 

of appendix D to this subpart before the 

date that appendix D1 becomes 

mandatory, or the quotient of a 7-pound 

bone-dry test load for standard dryers, 

as defined by 2.7.2 of appendix D to this 

subpart before the date that appendix 

D1 becomes mandatory, as applicable, 

divided by the clothes dryer energy 

consumption per cycle, as determined 

according to 4.1 for electric clothes 

dryers and 4.6 for gas clothes dryers of 

appendix D to this subpart before the 

date that appendix D1 becomes 

mandatory, the resulting quotient then 

being rounded off to the nearest 

hundredth (.01). Upon the date that 

appendix D1 to this subpart becomes 

mandatory, the energy factor is 

determined in accordance with 4.7 of 

appendix D1, the result then being 

rounded off to the nearest hundredth 

(.01). 

(3) Upon the date that appendix D1 to 

this subpart becomes mandatory, the 

combined energy factor is determined in 

accordance with 4.8 of appendix D1, the 

result then being rounded off to the 

nearest hundredth (.01). 

(4) Other useful measures of energy 

consumption for clothes dryers shall be 

those measures of energy consumption 

for clothes dryers which the Secretary 

determines are likely to assist 

consumers in making purchasing 

decisions and which are derived from 

the application of appendix D to this 

subpart before the date that appendix 

D1 becomes mandatory and appendix 

D1 upon the date that appendix D1 to 

this subpart becomes mandatory. 

* * * * * 

(f) Room air conditioners. (1) The 

estimated annual operating cost for 

room air conditioners, expressed in 

dollars per year, shall be determined by 

multiplying the following three factors: 

(i) The combined annual energy 

consumption for room air conditioners, 

expressed in kilowatt-hours per year, as 

determined in accordance with 

paragraph (f)(4) of this section, and 

(ii) A representative average unit cost 

of electrical energy in dollars per 

kilowatt-hour as provided by the 

Secretary, the resulting product then 

being rounded off to the nearest dollar 

per year. 


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(2) The energy efficiency ratio for 

room air conditioners, expressed in Btus 

per watt-hour, shall be the quotient of: 

(i) The cooling capacity in Btus per 

hour as determined in accordance with 

5.1 of appendix F to this subpart 

divided by: 

(ii) The electrical input power in 

watts as determined in accordance with 

5.2 of appendix F to this subpart, the 

resulting quotient then being rounded 

off to the nearest 0.1 Btu per watt-hour. 

(3) The average annual energy 

consumption for room air conditioners, 

expressed in kilowatt-hours per year, 

shall be determined by multiplying 

together the following two factors: 

(i) Electrical input power in kilowatts 

as determined in accordance with 5.2 of 

appendix F to this subpart, and 

(ii) The representative average-use 

cycle of 750 hours of compressor 

operation per year, the resulting product 

then being rounded off to the nearest 

kilowatt-hour per year. 

(4) The combined annual energy 

consumption for room air conditioners, 

expressed in kilowatt-hours per year, 

shall be the sum of: 

(i) The average annual energy 

consumption as determined in 

accordance with paragraph (f)(4) of this 

section, and 

(ii) The standby mode and off mode 

energy consumption, as determined in 

accordance with 5.3 of appendix F to 

this subpart, the resulting sum then 

being rounded off to the nearest 

kilowatt-hour per year. 

(5) The combined energy efficiency 

ratio for room air conditioners, 

expressed in Btu’s per watt-hour, shall 

be the quotient of: 

(i) The cooling capacity in Btus per 

hour as determined in accordance with 

5.1 of appendix F to this subpart 

multiplied by the representative 

average-use cycle of 750 hours of 

compressor operation per year, divided 

by 

(ii) The combined annual energy 

consumption as determined in 

accordance with paragraph (f)(4) of this 

section multiplied by a conversion 

factor of 1,000 to convert kilowatt-hours 

to watt-hours, the resulting quotient 

then being rounded off to the nearest 0.1 

Btu per watt-hour. 

* * * * * 

■ 4. Appendix D to subpart B of part 430 

is amended by adding introductory note 

to read as follows: 

Appendix D to Subpart B of Part 430– 

Uniform Test Method for Measuring the 

Energy Consumption of Clothes Dryers 

Note: Manufacturers must continue to use 

appendix D to subpart B of part 430 until the 

energy conservation standards for clothes 

dryers at 10 CFR 430.32(h) are amended to 

require mandatory compliance using 

appendix D1. 

* * * * * 

■ 5. Appendix D1 is added to subpart B 

of part 430 to read as follows: 

Appendix D1 to Subpart B of Part 430– 

Uniform Test Method for Measuring the 

Energy Consumption of Clothes Dryers 

Note: Appendix D1 to subpart B of part 430 

is informational only. Manufacturers must 

continue to use appendix D to subpart B of 

part 430 until compliance with any amended 

energy conservation standards for clothes 

dryers at 10 CFR 430.32(h) is required, at 

which time manufacturers must use 

appendix D1. 

1. Definitions 

1.1 ‘‘Active mode’’ means a mode in 

which the clothes dryer is connected to a 

main power source, has been activated and 

is performing the main function of tumbling 

the clothing with or without heated or 

unheated forced air circulation to remove 

moisture from the clothing, remove wrinkles 

or prevent wrinkling of the clothing, or both. 

1.2 ‘‘AHAM’’ means the Association of 

Home Appliance Manufacturers. 

1.3 ‘‘AHAM HLD–1’’ means the test 

standard published by the Association of 

Home Appliance Manufacturers, titled 

‘‘Household Tumble Type Clothes Dryers’’ 

(2009), AHAM HLD–1–2009 (incorporated by 

reference; see § 430.3). 

1.4 ‘‘Automatic termination control’’ 

means a dryer control system with a sensor 

which monitors either the dryer load 

temperature or its moisture content and with 

a controller which automatically terminates 

the drying process. A mark, detent, or other 

visual indicator or detent which indicates a 

preferred automatic termination control 

setting must be present if the dryer is to be 

classified as having an ‘‘automatic 

termination control.’’ A mark is a visible 

single control setting on one or more dryer 

controls. 

1.5 ‘‘Bone dry’’ means a condition of a 

load of test clothes which has been dried in 

a dryer at maximum temperature for a 

minimum of 10 minutes, removed, and 

weighed before cool down, and then dried 

again for 10-minute periods until the final 

weight change of the load is 1 percent or less. 

1.6 ‘‘Compact’’ or ‘‘compact size’’ means a 

clothes dryer with a drum capacity of less 

than 4.4 cubic feet. 

1.7 ‘‘Conventional clothes dryer’’ means a 

clothes dryer that exhausts the evaporated 

moisture from the cabinet. 

1.8 ‘‘Cool down’’ means that portion of 

the clothes drying cycle when the added gas 

or electric heat is terminated and the clothes 

continue to tumble and dry within the drum. 

1.9 ‘‘Cycle’’ means a sequence of 

operation of a clothes dryer which performs 

a clothes drying operation, and may include 

variations or combinations of the functions of 

heating, tumbling, and drying. 

1.10 ‘‘Drum capacity’’ means the volume 

of the drying drum in cubic feet. 

1.11 ‘‘IEC 62301’’ means the test standard 

published by the International 

Electrotechnical Commission (‘‘IEC’’), titled 

‘‘Household electrical appliances– 

Measurement of standby power,’’ Publication 

62301 (first edition June 2005) (incorporated 

by reference; see § 430.3). 

1.12 ‘‘Inactive mode’’ means a standby 

mode that facilitates the activation of active 

mode by remote switch (including remote 

control), internal sensor, or timer, or that 

provides continuous status display. 

1.13 ‘‘Moisture content’’ means the ratio 

of the weight of water contained by the test 

load to the bone-dry weight of the test load, 

expressed as a percent. 

1.14 ‘‘Moisture sensing control’’ means a 

system which utilizes a moisture sensing 

element within the dryer drum that monitors 

the amount of moisture in the clothes and 

automatically terminates the dryer cycle. 

1.15 ‘‘Off mode’’ means a mode in which 

the clothes dryer is connected to a main 

power source and is not providing any active 

or standby mode function, and where the 

mode may persist for an indefinite time. An 

indicator that only shows the user that the 

product is in the off position is included 

within the classification of an off mode. 

1.16 ‘‘Standard size’’ means a clothes 

dryer with a drum capacity of 4.4 cubic feet 

or greater. 

1.17 ‘‘Standby mode’’ means any product 

modes where the energy using product is 

connected to a main power source and offers 

one or more of the following user-oriented or 

protective functions which may persist for an 

indefinite time: 

(a) To facilitate the activation of other 

modes (including activation or deactivation 

of active mode) by remote switch (including 

remote control), internal sensor, or timer. 

(b) Continuous functions, including 

information or status displays (including 

clocks) or sensor-based functions. A timer is 

a continuous clock function (which may or 

may not be associated with a display) that 

provides regular scheduled tasks (e.g., 

switching) and that operates on a continuous 

basis. 

1.18 ‘‘Temperature sensing control’’ 

means a system which monitors dryer 

exhaust air temperature and automatically 

terminates the dryer cycle. 

1.19 ‘‘Ventless clothes dryer’’ means a 

clothes dryer that uses a closed-loop system 

with an internal condenser to remove the 

evaporated moisture from the heated air. The 

moist air is not discharged from the cabinet. 

2. Testing Conditions 

2.1 Installation. Install the clothes dryer 

in accordance with manufacturer’s 

instructions. For conventional clothes dryers, 

as defined in 1.7, the dryer exhaust shall be 

restricted by adding the AHAM exhaust 

simulator described in 3.3.5.1 of AHAM 

HLD–1 (incorporated by reference; see 

§ 430.3). For ventless clothes dryers, as 

defined in 1.19, the dryer shall be tested 

without the AHAM exhaust simulator. Where 

the manufacturer gives the option to use the 

dryer both with and without a duct, the dryer 

shall be tested without the exhaust simulator. 

All external joints should be taped to avoid 

air leakage. If the manufacturer gives the 


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option to use a ventless clothes dryer, as 

defined in 1.19, with or without a 

condensation box, the dryer shall be tested 

with the condensation box installed. For 

ventless clothes dryers, the condenser unit of 

the dryer must remain in place and not be 

taken out of the dryer for any reason between 

tests. For drying testing, disconnect all 

console lights or other lighting systems on 

the clothes dryer which do not consume 

more than 10 watts during the clothes dryer 

test cycle. For standby and off mode testing, 

the clothes dryer shall also be installed in 

accordance with section 5, paragraph 5.2 of 

IEC 62301 (incorporated by reference; see 

§ 430.3). For standby and off mode testing, do 

not disconnect console lights or other 

lighting systems. 

2.2 Ambient temperature and humidity. 

2.2.1 For drying testing, maintain the 

room ambient air temperature at 75 ± 3 ° F 

and the room relative humidity at 50 ± 10 

percent relative humidity. 

2.2.2 For standby and off mode testing, 

maintain room ambient air temperature 

conditions as specified in section 4, 

paragraph 4.2 of IEC 62301 (incorporated by 

reference; see § 430.3). 

2.3 Energy supply. 

2.3.1 Electrical supply. Maintain the 

electrical supply at the clothes dryer terminal 

block within 1 percent of 

120/240 or 120/208Y or 120 volts as 

applicable to the particular terminal block 

wiring system and within 1 percent of the 

nameplate frequency as specified by the 

manufacturer. If the dryer has a dual voltage 

conversion capability, conduct the test at the 

highest voltage specified by the 

manufacturer. 

2.3.1.1 Supply voltage waveform. For the 

clothes dryer standby mode and off mode 

testing, maintain the electrical supply voltage 

waveform indicated in section 4, paragraph 

4.4 of IEC 62301 (incorporated by reference; 

see § 430.3). 

2.3.2 Gas supply. 

2.3.2.1 Natural gas. Maintain the gas 

supply to the clothes dryer immediately 

ahead of all controls at a pressure of 7 to 10 

inches of water column. If the clothes dryer 

is equipped with a gas appliance pressure 

regulator for which the manufacturer 

specifies an outlet pressure, the regulator 

outlet pressure shall be approximately that 

recommended by the manufacturer. The 

hourly Btu rating of the burner shall be 

maintained within ± 5 percent of the rating 

specified by the manufacturer. The natural 

gas supplied should have a heating value of 

approximately 1,025 Btus per standard cubic 

foot. The actual heating value, Hn2, in Btus 

per standard cubic foot, for the natural gas to 

be used in the test shall be obtained either 

from measurements made by the 

manufacturer conducting the test using a 

standard continuous flow calorimeter as 

described in 2.4.6 or by the purchase of 

bottled natural gas whose Btu rating is 

certified to be at least as accurate a rating as 

could be obtained from measurements with 

a standard continuous flow calorimeter as 

described in 2.4.6. 

2.3.2.2 Propane gas. Maintain the gas 

supply to the clothes dryer immediately 

ahead of all controls at a pressure of 11 to 

13 inches of water column. If the clothes 

dryer is equipped with a gas appliance 

pressure regulator for which the 

manufacturer specifies an outlet pressure, the 

regulator outlet pressure shall be 

approximately that recommended by the 

manufacturer. The hourly Btu rating of the 

burner shall be maintained within ± 5 percent 

of the rating specified by the manufacturer. 

The propane gas supplied should have a 

heating value of approximately 2,500 Btus 

per standard cubic foot. The actual heating 

value, Hp, in Btus per standard cubic foot, for 

the propane gas to be used in the test shall 

be obtained either from measurements made 

by the manufacturer conducting the test 

using a standard continuous flow calorimeter 

as described in 2.4.6 or by the purchase of 

bottled gas whose Btu rating is certified to be 

at least as accurate a rating as could be 

obtained from measurement with a standard 

continuous calorimeter as described in 2.4.6. 

2.4 Instrumentation. Perform all test 

measurements using the following 

instruments as appropriate. 

2.4.1 Weighing scale for test cloth. The 

scale shall have a range of 0 to a maximum 

of 30 pounds with a resolution of at least 0.2 

ounces and a maximum error no greater than 

0.3 percent of any measured value within the 

range of 3 to 15 pounds. 

2.4.1.2 Weighing scale for drum capacity 

measurements. The scale should have a range 

of 0 to a maximum of 500 pounds with 

resolution of 0.50 pounds and a maximum 

error no greater than 0.5 percent of the 

measured value. 

2.4.2 Kilowatt-hour meter. The kilowatthour meter shall have a resolution of 0.001 

kilowatt-hours and a maximum error no 

greater than 0.5 percent of the measured 

value. 

2.4.3 Gas meter. The gas meter shall have 

a resolution of 0.001 cubic feet and a 

maximum error no greater than 0.5 percent 

of the measured value. 

2.4.4 Dry and wet bulb psychrometer. The 

dry and wet bulb psychrometer shall have an 

error no greater than ± 1 °F. 

2.4.5 Temperature. The temperature 

sensor shall have an error no greater than 

± 1 °F. 

2.4.6 Standard Continuous Flow 

Calorimeter. The calorimeter shall have an 

operating range of 750 to 3,500 Btu per cubic 

feet. The maximum error of the basic 

calorimeter shall be no greater than 0.2 

percent of the actual heating value of the gas 

used in the test. The indicator readout shall 

have a maximum error no greater than 0.5 

percent of the measured value within the 

operating range and a resolution of 0.2 

percent of the full-scale reading of the 

indicator instrument. 

2.4.7 Standby mode and off mode watt 

meter. The watt meter used to measure 

standby mode and off mode power 

consumption of the clothes dryer shall have 

the resolution specified in section 4, 

paragraph 4.5 of IEC 62301 (incorporated by 

reference; see § 430.3). The watt meter shall 

also be able to record a ‘‘true’’ average power 

as specified in section 5, paragraph 5.3.2(a) 

of IEC 62301. 

2.5 Lint trap. Clean the lint trap 

thoroughly before each test run. 

2.6 Test Clothes. 

2.6.1 Energy test cloth. The energy test 

cloth shall be clean and consist of the 

following: 

(a) Pure finished bleached cloth, made 

with a momie or granite weave, which is a 

blended fabric of 50-percent cotton and 50- 

percent polyester and weighs within +10 

percent of 5.75 ounces per square yard after 

test cloth preconditioning, and has 65 ends 

on the warp and 57 picks on the fill. The 

individual warp and fill yarns are a blend of 

50-percent cotton and 50-percent polyester 

fibers. 

(b) Cloth material that is 24 inches by 36 

inches and has been hemmed to 22 inches by 

34 inches before washing. The maximum 

shrinkage after five washes shall not be more 

than 4 percent on the length and width. 

(c) The number of test runs on the same 

energy test cloth shall not exceed 25 runs. 

2.6.2 Energy stuffer cloths. The energy 

stuffer cloths shall be made from energy test 

cloth material, and shall consist of pieces of 

material that are 12 inches by 12 inches and 

have been hemmed to 10 inches by 10 inches 

before washing. The maximum shrinkage 

after five washes shall not be more than 4 

percent on the length and width. The number 

of test runs on the same energy stuffer cloth 

shall not exceed 25 runs after test cloth 

preconditioning. 

2.6.3 Test Cloth Preconditioning. 

A new test cloth load and energy stuffer 

cloths shall be treated as follows: 

(1) Bone dry the load to a weight change 

of ± 1 percent, or less, as prescribed in 

section 1.5. 

(2) Place the test cloth load in a standard 

clothes washer set at the maximum water fill 

level. Wash the load for 10 minutes in soft 

water (17 parts per million hardness or less), 

using 60.8 grams of AHAM standard test 

detergent Formula 3. Wash water 

temperature is to be controlled at 140 ° ± 5 

°F (60 ° ± 2.7 °C). Rinse water temperature 

is to be controlled at 100 ° ± 5 °F (37.7 ± 2.7 

°C). 

(3) Rinse the load again at the same water 

temperature. 

(4) Bone dry the load as prescribed in 

section 1.5 and weigh the load. 

(5) This procedure is repeated until there 

is a weight change of 1 percent or less. 

(6) A final cycle is to be a hot water wash 

with no detergent, followed by two warm 

water rinses. 

2.7 Test loads. 

2.7.1 Compact size dryer load. Prepare a 

bone-dry test load of energy cloths which 

weighs 3.00 pounds ± .03 pounds. 

Adjustments to the test load to achieve the 

proper weight can be made by the use of 

energy stuffer cloths, with no more than five 

stuffer cloths per load. Dampen the load by 

agitating it in water whose temperature is 

60 °F ± 5 °F and consists of 0 to 17 parts per 

million hardness for approximately 2 

minutes in order to saturate the fabric. Then, 

extract water from the wet test load by 

spinning the load until the moisture content 

of the load is between 54.0–61.0 percent of 

the bone-dry weight of the test load. 

2.7.2 Standard size dryer load. Prepare a 

bone-dry test load of energy cloths which 

weighs 8.45 pounds ± .085 pounds. 


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Adjustments to the test load to achieve the 

proper weight can be made by the use of 

energy stuffer cloths, with no more than five 

stuffer cloths per load. Dampen the load by 

agitating it in water whose temperature is 

60 °F ± 5 °F and consists of 0 to 17 parts per 

million hardness for approximately 2 

minutes in order to saturate the fabric. Then, 

extract water from the wet test load by 

spinning the load until the moisture content 

of the load is between 54.0–61.0 percent of 

the bone-dry weight of the test load. 

2.7.3 Method of loading. Load the energy 

test cloths by grasping them in the center, 

shaking them to hang loosely, and then 

dropping them in the dryer at random. 

2.8 Clothes dryer preconditioning. 

2.8.1 Conventional clothes dryers. For 

conventional clothes dryers, before any test 

cycle, operate the dryer without a test load 

in the non-heat mode for 15 minutes or until 

the discharge air temperature is varying less 

than 1 °F for 10 minutes—whichever is 

longer—in the test installation location with 

the ambient conditions within the specified 

test condition tolerances of 2.2. 

2.8.2 Ventless clothes dryers. For ventless 

clothes dryers, before any test cycle, the 

steady-state machine temperature must be 

equal to ambient room temperature described 

in 2.2.1. This may be done by leaving the 

machine at ambient room conditions for at 

least 12 hours between tests. 

3. Test Procedures and Measurements 

3.1 Drum Capacity. Measure the drum 

capacity by sealing all openings in the drum 

except the loading port with a plastic bag, 

and ensuring that all corners and depressions 

are filled and that there are no extrusions of 

the plastic bag through the opening in the 

drum. Support the dryer’s rear drum surface 

on a platform scale to prevent deflection of 

the drum surface, and record the weight of 

the empty dryer. Fill the drum with water to 

a level determined by the intersection of the 

door plane and the loading port. Record the 

temperature of the water and then the weight 

of the dryer with the added water and then 

determine the mass of the water in pounds. 

Add or subtract the appropriate volume 

depending on whether or not the plastic bag 

protrudes into the drum interior. The drum 

capacity is calculated as follows: 

C = w/d 

C = capacity in cubic feet. 

w = weight of water in pounds. 

d = density of water at the measured 

temperature in pounds per cubic feet. 

3.2 Dryer Loading. Load the dryer as 

specified in 2.7. 

3.3 Test cycle Operate the clothes dryer at 

the maximum temperature setting and, if 

equipped with a timer, at the maximum time 

setting and dry the load until the moisture 

content of the test load is between 2.5 and 

5 percent of the bone-dry weight of the test 

load, but do not permit the dryer to advance 

into cool down. If required, reset the timer 

or automatic dry control. If the dryer 

automatically stops during a cycle because 

the condensation box is full of water, the test 

is stopped, and the test run is invalid, in 

which case the condensation box shall be 

emptied and the test re-run from the 

beginning. For ventless dryers, as defined in 

1.19, during the time between two cycles, the 

door of the dryer shall be closed except for 

loading (and unloading). 

3.4 Data recording. Record for each test 

cycle: 

3.4.1 Bone-dry weight of the test load 

described in 2.7. 

3.4.2 Moisture content of the wet test 

load before the test, as described in 2.7. 

3.4.3 Moisture content of the dry test load 

obtained after the test described in 3.3. 

3.4.4 Test room conditions, temperature, 

and percent relative humidity described in 

2.2.1. 

3.4.5 For electric dryers—the total 

kilowatt-hours of electric energy, Et, 

consumed during the test described in 3.3. 

3.4.6 For gas dryers: 

3.4.6.1 Total kilowatt-hours of electrical 

energy, Ete, consumed during the test 

described in 3.3. 

3.4.6.2 Cubic feet of gas per cycle, Etg, 

consumed during the test described in 3.3. 

3.4.6.3 Correct the gas heating value, 

GEF, as measured in 2.3.2.1 and 2.3.2.2, to 

standard pressure and temperature 

conditions in accordance with U.S. Bureau of 

Standards, circular C417, 1938. 

3.5 Test for automatic termination field 

use factor. The field use factor for automatic 

termination can be claimed for those dryers 

which meet the requirements for automatic 

termination control, defined in 1.4. 

3.6 Standby mode and off mode power. 

Establish the testing conditions set forth in 

Section 2 ‘‘Testing Conditions’’ of this 

appendix, omitting the requirement to 

disconnect all console light or other lighting 

systems on the clothes dryer that do not 

consume more than 10 watts during the 

clothes dryer test cycle in section 2.1. If the 

clothes dryer waits in a higher power state 

at the start of standby mode or off mode 

before dropping to a lower power state, as 

discussed in section 5, paragraph 5.1, note 1 

of IEC 62301 (incorporated by reference; see 

§ 430.3),wait until the clothes dryer passes 

into the lower power state before starting the 

measurement. Follow the test procedure 

specified in section 5, paragraph 5.3 of IEC 

62301 for testing in each possible mode as 

described in 3.6.1 and 3.6.2, except allow the 

product to stabilize for 30 to 40 minutes and 

use an energy use measurement period of 

10 minutes. For units in which power varies 

over a cycle, as described in section 5, 

paragraph 5.3.2 of IEC 62301, use the average 

power approach described in paragraph 

5.3.2(a) of IEC 62301, except allow the 

product to stabilize for 30 to 40 minutes and 

use an energy use measurement period not 

less than 10 minutes. 

3.6.1 If a clothes dryer has an inactive 

mode, as defined in 1.12, measure and record 

the average inactive mode power of the 

clothes dryer, PIA, in watts. 

3.6.2 If a clothes dryer has an off mode, 

as defined in 1.15, measure and record the 

average off mode power of the clothes dryer, 

POFF, in watts. 

4. Calculation of Derived Results From Test 

Measurements 

4.1 Total Per-cycle electric dryer energy 

consumption. Calculate the total electric 

dryer energy consumption per cycle, Ece,

expressed in kilowatt-hours per cycle and 

defined as: 

Ece = [53.5/(Ww¥Wd)] × Ett × field use, 

Where: 

53.5 = an experimentally established value 

for the percent reduction in the moisture 

content of the test load during a 

laboratory test cycle expressed as a 

percent. 

field use = field use factor. 

= 1.18 for clothes dryers with time 

termination control systems only 

without any automatic termination 

control functions. 

= 1.04 clothes dryers with automatic control 

systems that meet the requirements of 

the definition for automatic control 

systems in 1.4, 1.14 and 1.18, including 

those that also have a supplementary 

timer control, or that may also be 

manually controlled. 

Ww = the moisture content of the wet test 

load as recorded in 3.4.2. 

Wd = the moisture content of the dry test load 

as recorded in 3.4.3. 

4.2 Per-cycle gas dryer electrical 

energy consumption. Calculate the gas 

dryer electrical energy consumption per 

cycle, Ege, expressed in kilowatt-hours 

per cycle and defined as: 

Ege = [53.5/(Ww¥Wd)] × Ete × field use, 

Where: 

Ete = the energy recorded in 3.4.6.1 field use, 

53.5, Ww, Wd as defined in 4.1. 

4.3 Per-cycle gas dryer gas energy 

consumption. Calculate the gas dryer 

gas energy consumption per cycle, Ege.

expressed in Btus per cycle as defined 

as: 

Egg = [53.5/(Ww ¥ Wd)] × Etg × field use 

× GEF 

Where: 

Etg = the energy recorded in 3.4.6.2 

GEF = corrected gas heat value (Btu per cubic 

feet) as defined in 3.4.6.3, field use, 53.5, 

Ww, Wd as defined in 4.1. 

4.4 Total per-cycle gas dryer energy 

consumption expressed in kilowatthours. Calculate the total gas dryer 

energy consumption per cycle, Ecg, 

expressed in kilowatt-hours per cycle 

and defined as: 

Ecg = Ege + (Egg/3412 Btu/kWh) 

Where: 

Ege as defined in 4.2 

Egg as defined in 4.3 

4.5 Per-cycle standby mode and off 

mode energy consumption. Calculate 

the dryer inactive mode and off mode 

energy consumption per cycle, ETSO, 

expressed in kWh per cycle and defined 

as: 

ETSO = [(PIA × SIA) + (POFF × SOFF)] × K/ 

283 

Where: 

PIA = dryer inactive mode power, in watts, as 

measured in section 3.6.1; 


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POFF = dryer off mode power, in watts, as 

measured in section 3.6.2. 

If the clothes dryer has both inactive mode 

and off mode, SIA and SOFF both equal 

8,620 ÷ 2 = 4,310, where 8,620 is the 

total inactive and off mode annual hours; 

If the clothes dryer has an inactive mode but 

no off mode, the inactive mode annual 

hours, SIA, is equal to 8,620 and the off 

mode annual hours, SOFF, is equal to 0; 

If the clothes dryer has an off mode but no 

inactive mode, SIA is equal to 0 and SOFF

is equal to 8,620 

Where: 

K = 0.001 kWh/Wh conversion factor for 

watt-hours to kilowatt-hours; and 

283 = representative average number of 

clothes dryer cycles in a year. 

4.6 Per-cycle combined total energy 

consumption expressed in kilowatthours. Calculate the per-cycle combined 

total energy consumption, ECC,

expressed in kilowatt-hours per cycle 

and defined for an electric clothes dryer 

as: 

ECC = Ece + ETSO

Where: 

Ece = the energy recorded in 4.1, and 

ETSO = the energy recorded in 4.7, and 

defined for a gas clothes dryer as: 

ECC = Ecg + ETSO

Where: 

Ecg = the energy recorded in 4.4, and 

ETSO = the energy recorded in 4.7. 

4.7 Energy Factor in pounds per 

kilowatt-hour. Calculate the energy 

factor, EF, expressed in pounds per 

kilowatt-hour and defined for an electric 

clothes dryer as: 

EF = Wbonedry/Ece

Where: 

Wbonedry = the bone dry test load weight 

recorded in 3.4.1, and 

Ece = the energy recorded in 4.1, and 

and defined for a gas clothes dryer as: 

EF = Wbonedry/Ecg

Where: 

Wbonedry = the bone dry test load weight 

recorded in 3.4.1, and 

Ecg = the energy recorded in 4.4, 

4.8 Combined Energy Factor in 

pounds per kilowatt-hour. Calculate the 

combined energy factor, CEF, expressed 

in pounds per kilowatt-hour and 

defined as: 

CEF = Wbonedry/ECC

Where: 

Wbonedry = the bone dry test load weight 3.4.1, 

and 

ECC = the energy recorded in 4.6 

■ 6. Appendix F to subpart B of part 430 

is revised to read as follows: 

Appendix F to Subpart B of Part 430– 

Uniform Test Method for Measuring the 

Energy Consumption of Room Air 

Conditioners 

Note: Manufacturers are not required to use 

the test procedures and calculations that refer 

to standby mode and off mode energy 

consumption, (specifically, sections 2.2, 3.2, 

4.2, and 5.3 of this appendix F) until the 

compliance date of any amended energy 

conservation standards for room air 

conditioners at 10 CFR 430.32(b). 

1. Definitions. 

1.1 ‘‘Active mode’’ means a mode in 

which the room air conditioner is connected 

to a mains power source, has been activated 

and is performing the main function of 

cooling or heating the conditioned space, or 

circulating air through activation of its fan or 

blower, with or without energizing active aircleaning components or devices such as 

ultraviolet (UV) radiation, electrostatic filters, 

ozone generators, or other air-cleaning 

devices. 

1.2 ‘‘ANSI/AHAM RAC–1’’ means the test 

standard published jointly by the American 

National Standards Institute and the 

Association of Home Appliance 

Manufacturers, titled ‘‘Room Air 

Conditioners,’’ Standard RAC–1–2008 

(incorporated by reference; see § 430.3). 

1.3 ‘‘ANSI/ASHRAE 16’’ means the test 

standard published jointly by the American 

National Standards Institute and the 

American Society of Heating, Refrigerating, 

and Air-Conditioning Engineers titled 

‘‘Method of Testing for Rating Room Air 

Conditioners and Packaged Terminal Air 

Conditioners,’’ Standard 16–1983 (RA 2009) 

(incorporated by reference; see § 430.3). 

1.4 ‘‘IEC 62301’’ means the test standard 

published by the International 

Electrotechnical Commission, (‘‘IEC’’), titled 

‘‘Household electrical appliances— 

Measurement of standby power,’’ Publication 

62301 (first edition June 2005), (incorporated 

by reference; see § 430.3). 

1.5 ‘‘Inactive mode’’ means a standby 

mode that facilitates the activation of active 

mode by remote switch (including remote 

control) or internal sensor or which provides 

continuous status display. 

1.6 ‘‘Off mode’’ means a mode in which 

a room air conditioner is connected to a 

mains power source and is not providing any 

active or standby mode function and where 

the mode may persist for an indefinite time. 

An indicator that only shows the user that 

the product is in the off position is included 

within the clasification of an off mode. 

1.7 ‘‘Standby mode’’ means any product 

modes where the where the energy using 

product is connected to a mains power 

source and offers one or more of the 

following user oriented or protective 

functions which may persist for an indefinite 

time: 

(a) To facilitate the activation of other 

modes (including activation or deactivation 

of active mode) by remote switch (including 

remote control), internal sensor, or timer. 

(b) Continuous functions, including 

information or status displays (including 

clocks) or sensor-based functions. A timer is 

a continuous clock function (which may or 

may not be associated with a display) that 

provides regular scheduled tasks (e.g., 

switching) and that operates on a continuous 

basis. 

2. Test methods. 

2.1 Cooling. The test method for testing 

room air conditioners in cooling mode shall 

consist of application of the methods and 

conditions in ANSI/AHAM RAC–1 sections 

4, 5, 6.1, and 6.5 (incorporated by reference; 

see § 430.3), and in ANSI/ASHRAE 16 

(incorporated by reference; see § 430.3). 

2.2 Standby and off modes. The method 

for testing room air conditioners in standby 

and off modes shall consist of application of 

the methods and conditions in IEC 62301 

(incorporated by reference; see § 430.3), as 

modified by the requirements of this 

standard. The testing may be conducted in 

test facilities used for testing cooling 

performance. If testing is not conducted in 

such a facility, the test facility shall comply 

with IEC 62301 section 4.2. 

3. Test conditions. 

3.1 Cooling mode. Establish the test 

conditions described in sections 4 and 5 of 

ANSI/AHAM RAC–1 (incorporated by 

reference; see § 430.3) and in accordance 

with ANSI/ASHRAE 16 (incorporated by 

reference; see § 430.3). 

3.2 Standby and off modes. 

3.2.1 Test room conditions. Maintain the 

indoor test conditions as required by section 

4.2 of IEC 62301 (incorporated by reference; 

see § 430.3). If the standby and off mode 

testing is conducted in a facility that is also 

used for testing cooling performance, 

maintain the outdoor test conditions either as 

required by section 4.2 of IEC 62301 or as 

described in section 3.1. If the unit is 

equipped with an outdoor air ventilation 

damper, close this damper during testing. 

3.2.2 Power supply. Maintain power 

supply conditions specified in section 4.3 of 

IEC 62301 (incorporated by reference; see 

§ 430.3). Use room air conditioner nameplate 

voltage and frequency as the basis for power 

supply conditions. Maintain power supply 

voltage waveform according to the 

requirements of section 4.4 of IEC 62301. 

3.2.3 Watt meter. The watt meter used to 

measure standby mode and off mode power 

consumption of the room air conditioner 

shall have the resolution specified in section 

4, paragraph 4.5 of IEC 62301 (incorporated 

by reference; see § 430.3). The watt meter 

shall also be able to record a ‘‘true’’ average 

power specified in section 5, paragraph 

5.3.2(a) of IEC 62301. 

4. Measurements. 

4.1 Cooling mode. Measure the quantities 

delineated in section 5 of ANSI/AHAM RAC– 

1 (incorporated by reference; see § 430.3). 

4.2 Standby and off modes. Establish the 

testing conditions set forth in section 3.2. 

Prior to the initiation of the test 

measurements, the room air conditioner shall 

also be installed in accordance with section 

5, paragraph 5.2 of IEC 62301 (incorporated 

by reference; see § 430.3). For room air 

conditioners that drop from a higher power 

state to a lower power state as discussed in 

section 5, paragraph 5.1, note 1 of IEC 62301, 

allow sufficient time for the room air 

conditioner to reach the lower power state 

before proceeding with the test measurement. 


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Follow the test procedure specified in section 

5, paragraph 5.3 of IEC 62301 for testing in 

each possible mode as described in 4.2.1 and 

4.2.2, except allow the product to stabilize 

for 5 to 10 minutes and use an energy use 

measurement period of 5 minutes. For units 

in which power varies over a cycle, as 

described in section 5, paragraph 5.3.2 of IEC 

62301, use the average power approach in 

paragraph 5.3.2(a). 

4.2.1 If a room air conditioner has an 

inactive mode, as defined in 1.5, measure 

and record the average inactive mode power 

of the room air conditioner, PIA, in watts. 

4.2.2 If a room air conditioner has an off 

mode, as defined in 1.6, measure and record 

the average off mode power of the room air 

conditioner, POFF, in watts. 

5. Calculations. 

5.1 Calculate the cooling capacity 

(expressed in Btu/hr) as required in section 

6.1 of ANSI/AHAM RAC–1 (incorporated by 

reference; see § 430.3) and in accordance 

with ANSI/ASHRAE 16 (incorporated by 

reference; see § 430.3). 

5.2 Determine the electrical power input 

(expressed in watts) as required by section 

6.5 of ANSI/AHAM RAC–1 (incorporated by 

reference; see § 430.3) and in accordance 

with ANSI/ASHRAE 16 (incorporated by 

reference; see § 430.3). 

5.3 Standby mode and off mode annual 

energy consumption. Calculate the standby 

mode and off mode annual energy 

consumption for room air conditioners, ETSO, 

expressed in kilowatt-hours per year, 

according to the following: 

ETSO = [(PIA × SIA) + (POFF × SOFF)] × K 

Where: 

PIA= room air conditioner inactive mode 

power, in watts, as measured in section 

4.2.1 

POFF = room air conditioner off mode power, 

in watts, as measured in section 4.2.2. 

If the room air conditioner has both inactive 

mode and off mode, SIA and SOFF both 

equal 5,115 ÷ 2 = 2,557.5, where 5,115 

is the total inactive and off mode annual 

hours; 

If the room air conditioner has an inactive 

mode but no off mode, the inactive mode 

annual hours, SIA, is equal to 5,115 and 

the off mode annual hours, SOFF, is equal 

to 0; 

If the room air conditioner has an off mode 

but no inactive mode, SIA is equal to 0 

and SOFF is equal to STOT; 

K = 0.001 kWh/Wh conversion factor for 

watt-hours to kilowatt-hours. 

[FR Doc. 2010–32118 Filed 1–5–11; 8:45 am] 

BILLING CODE 6450–01–P 


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