CHAPTER 4. SCREENING ANALYSIS

TABLE OF CONTENTS
4.1 INTRODUCTION

........................................................................................................... 4-1 4.2 DISCUSSION OF DESIGN OPTIONS

.......................................................................... 4-1 4.2.1 Screened-Out Design Options

.......................................................................................... 4-2 4.2.1.1 Dishwashers

................................................................................................... 4-3 4.2.1.2 Dehumidifiers

................................................................................................ 4-4 4.2.1.3 Cooking Products

........................................................................................... 4-4 4.2.1.4 Commercial Clothes Washers

........................................................................ 4-8 4.2.2 Remaining Design Options

.............................................................................................. 4-9 4.2.2.1 Dishwashers

................................................................................................... 4-9 4.2.2.2 Dehumidifiers

.............................................................................................. 4-10 4.2.2.3 Cooking Products

......................................................................................... 4-10 4.2.2.4 Commercial Clothes Washers

...................................................................... 4-12

LIST OF TABLES Table 4.2.1 Retained Design Options for Dishwashers

........................................................ 4-10 Table 4.2.2 Retained Design Opti ons for Dehumidifiers

...................................................... 4-10 Table 4.2.3 Retained Design Options for Gas Cooktops

...................................................... 4-10 Table 4.2.4 Retained Design Options for El ectric Open (Coil) Elem ent Cooktops

............. 4-11 Table 4.2.5 Retained Design Options fo r Electric Sm ooth Element Cooktops

.................... 4-11 Table 4.2.6 Retained Design Options for Gas and Electric Ovens

....................................... 4-11 Table 4.2.7 Retained Design Options for Microwave Ovens

............................................... 4-12 Table 4.2.8 Retained Design Options fo r Comm ercial Clothes Washers

............................. 4-12

4-iCHAPTER 4. SCREENING ANALYSIS

4.1 INTRODUCTION This chapter discusses the screening anal ysis conducted by the U.S. Departm ent of Energy (DOE) of the design options identified in the market and technology assessment for residential dishwashers, dehumidifiers, and c ooking products and commer cial clothes washers (Chapter 3 of the advance notice of proposedrulemaking (ANOPR) t echnical support document (TSD)). In the market and technology assessment, DOE presented an initia l list of technologies, or design options, that can be used to reduce en ergy consumption of each of the products covered in this rulemaking. The goal of the screening anal ysis is to identify any design options that will be eliminated from further consideration in the rulemaking analyses. For each product, the corresponding candidate design optio ns are assessed based on DOE analysis as well as inputs from stakeholders including manufacturers, trade organizations, and energy efficiency advocates. Design options wh ich are judged to be viable approaches for improving energy efficiency are retained as inpu ts to the subsequent engineering analysis. Design options which are not inco rporated in commercial products or in working prototypes, or that fail to meet certain criteria as to practi cability to manufacture, install and service, as to impacts on product utility or availability, or as to health or safety will be eliminated from consideration in accordance with Energy Cons ervation Program for Consumer Products: Procedures for Consideration of New or Revi sed Energy Conservation S tandards for Consumer Products . (61 FR 36974, section 4(a)(4) and 5(b)). The rationale for either screening out or retaining each design option is detailed in the following sections.

4.2 DISCUSSION OF DESIGN OPTIONS For residential dishwashers, dehumidifie rs, and commercial clothes washers, the screening criteria speci fied in section 4.1 were applied to th e design options to either retain or eliminate each technology from the engineering analysis. For cooking products, information used for appl ying the screening criteria to m ost of the design options were derived from the prev ious rulemaking’s TSD, DOE’s 1996 Technical Support Document for Residential Cooking Products (1996 TSD). The Framework Document for this rulemaking, entitled Rulemaking Framework for Commercial Clothes Washers and Residential Dishwashers, Dehu midifiers, and Cooking Products , March 15, 2006, describes which design options DOE intends to reevaluate for the engineering analysis in the current rulemaking. The approach proposed in the Framework Document for conventional cooking products is to retain the same screening results as put forth in the 1996 TSD. In addition, lowstandby-loss electronics, which DOE identified for cooking products through literature searches and stakeholder inputs, were evalua ted. It should also be noted that radiant elements for smooth cooktops, which were included as a design option in the 1996 TS D, were not included in the

4-1current rulemaking because manufacturer data provided to DOE for the 1996 TSD indicated that this technology did not demonstrat e an efficiency improvement ove r the baseline according to the DOE test procedure, and DOE is unaware of any more recent data that indicates otherwise. For microwave ovens, design options from the 1996 TSD were screened in the same m anner as in the previous rulemaking. Howe ver, three additional design options – cooking sensors, dual magnetrons, and low-standby-loss el ectronic controls – we re evaluated. DOE identified cooking sensors from product literatu re, while dual magnetrons were added based on information from the February 2006 edition of Appliance Design. DOE identified low-standbyloss electronic controls by reviewing the A ssociation of Home Appliance Manufacturers (AHAM) data for standby power. For commercial clothes washers, DOE reviewed the design options listed in Chapter 3 of the 1997 Technical Support Document for Clothes W ashers (1997 TSD). Since commercial and residential clothes washers now share the same energy efficiency testing method per EPACT 2005, section 136(f), design options that were va lid for the previous rulemaking would likely apply to the current commercial clothes washer rulemaking.
4.2.1 Screened-Out Design Options The following section details the specific designoptions that were sc reened out prior to the engineering analysis, along withthe rationale for elimination. The technologies identified in the market and technology assessment were evaluated pursuant to the criteria set out in The Energy Policy and Conservation Act, as am ended (EPCA or the Act). (42 U.S.C. 6311- 6317) EPCA provides criteria fo r prescribing new or amended standards, which will achieve the maximum impr ovement in energy efficiency the Secretary of Energy determines is technologically feasible. (42 U.S.C. 6313( a)(6)(A)) It also establishes guidelines for determining whether a standardis economically justified. (42 U.S.C. 6313(a)(6)(B)) In view of the EPCA requirements for determining whether a standard is technologically feasible and economically justified, Appendix A to subpart C of Title 10 Code of Federal Regulations Part 430 (10 CFR Part 430), Procedures, Interpretations and Policies for Consideration of New or Revised Energy C onservation Standards for Consum er Products (the Process Rule), sets forth procedures to guide DOE in the consideration and promulgation of new or revised product efficiency standards under EPCA. These procedur es elaborate on the statutory criteria provided in 42 U.S.C. 6313 and in part eliminate problematic technologies early in the process of revising an energy efficiency standard. Under the guidelines, before publishing an ANOPR, DOE eliminates from consideration technologies that presen t unacceptable problems with respect to the following four factors: (1) Technological feasibility. If it is determined that a technology has not been incorporated in commercial products or in work ing prototypes, then th at technology will not be considered further.

4-2(2) Practicability to manufacture, install, and service. If it is determined that mass production of a technology in commercial products a nd reliable installation and servicing of the technology could not be achieved on the scale necessary to serve the relevant market at the time of the effective date of the standard, then that technology will not be considered further. (3) Impacts on product utility to consumers. If a technology is determined to have significant adverse impact on the utility of the product to significant subgroups of consumers, or results in the unavailability of any covered pr oduct type with perfor mance characteristics (including reliability), features, size, capacities, and volumes that are substantially the same as products generally available in the U.S. at th e time, it will not be considered further. (4) Safety of technologies. If it is d etermined that a technology will have significant adverse impacts on health or safety, it will not be considered further. The following sections detail the design optio ns that were screened out fo r each product covered by this rulemaking and the reasons why each were eliminated.
4.2.1.1 Dishwashers For dishw ashers , DOE screened out reduced inlet- water temperature, supercritical carbon dioxide washing, and ultras onic washing technologies, fo r the reasons that follow Reduced inlet-water temperature Reduced inlet-water temperature requires th at d ishwashers tap the cold water line for their water supply. Since most dishwashers in th e U.S. tap the hot water line, this design option would require significant alteration of existing dishwasher inst allations in order to accommodate newly-purchased units incorpora ting this design option. Therefore, DOE believes that it would not be practicable to install this technology on the scale necessary to serve the relevant market at the time of the effective date of an amended standard. Supercritical carbon dioxide washing Supercritical carbon dioxide wash ing, which uses supercritica l carbon dioxide instead of conventional detergent and water to wash dishes, is currentl y being researched. Thus, DOE believes that it would not be practicable to m a nufacture, install and se rvice this technology on the scale necessary to serve the relevant market at the time of the effective date of an amended standard. Furthermore, because this technology is in the research stage, it is not yet possible to assess whether it will have any adverse impacts on equipment utility to consumers or equipment availability, or any adverse impact s on consumers' health or safety. Ultrasonic washing A dishwasher using ultrasonic waves to genera te a cleaning mist has been demonstrated. However, this model did not use ultrasonic wa ves in a standing fluid to clean dishes, and
4-3additionally relied on ion generation for further cleaning. Ultrasoni c dishwashing based upon soiled-dish immersion in a fluid which is th en excited by ultrasoni c waves has not been demonstrated. In an immersion-based ultrasoni c dishwasher, standing ultrasonic waves within the washing cavity and the for ce of bubble cavitation implosion can damage fragile dishware. The low water temperatures utilized by ultrasoni c dishwashers may also lead to a perceived decrease in consumer utility, since consumers e xpect hot water in the dishwasher to sterilize dishes. Since no manufacturer currently produceultrasonic dishwashers in the U.S., it is impossible to assess whether this design option w ould have any impacts on consumers’ health or safety, or product availability.
4.2.1.2 Dehumidifiers For dehumidifiers , all technologies meet the screening criteria.
4.2.1.3 Cooking Products For gas cooktops , DOE screen ed out catalytic burn ers, radiant gas burners, reduced excess air at burner, and reflective su rfaces for the reasons that follow. Catalytic burners DOE is not aware of any commercialized catalytic burners for gas cooktops, so DOE believes that it would not be practicable to m a nufacture, install and se rvice this technology on the scale necessary to serve the relevant market at the time of the effective date of an amended standard. Also, because this technology is in th e research stage, it is not possible to assess whether it will have any adverse impacts on eq uipment utility to consumers or equipment availability, or any adverse impact s on consumers' health or safety. Radiant gas burners In the previous rulemaking, ma nufacturers asserted that the op erating characteristics of an inf rared (IR)-jet radiant burner ar e such that it is difficult to main tain a low burner input rate for many cooktop functions. They stated that field testing for residential ranges was discontinued because test users were unable to turn down the bur ner satisfactorily. 1 Without an adequate “turn down” capability, the burner would not be able to pass the American National Standards Institute (ANSI) Z21.1-2005, Household Cooking Gas Appliances standard

. Although a silicon carbide radiant burner has been tested to the Japanese Industrial Standard, it is also not known how e ither type of radiant burner would perform under DOE test conditions. Since DOE lacks rele vant test data to evaluate potential impacts on consumers’ health and safety, this design optio n was not analyzed for gas cooktops.

4-4Reduced excess air at burner For the 1996 TSD, the Gas Research Inst itute (G RI, now known as the Gas Technology Institute) submitted a report which analyzed th is design option and was submitted as a comment to the notice of proposed rulemaking (NOPR) in the previous rulemaking 2 . GRI concluded that the efficiency increase of this design option was not measurable at that time. They pointed out that the burner described by DOE di d not exist on the market and thus there were no designs that could be evaluated. DOE is unaware of any changes to that situation. GRI also noted that use of this design option may cause a safety issue due to the possibility of increased carbon monoxide (CO) production.
Reduced excess air at the burner has not b een co mmercialized, and DOE believes that it would not be practicable to manufacture, inst all and service this technology on the scale necessary to serve the relevant market at the time of the effective date of an amended standard. Also, because this technology is undeveloped, it is not possible to assess whether it will have any adverse impacts on equipment util ity to consumers or equipment availability, or any adverse impacts on consumers' health or safety. . Reflective surfaces As reported in the 1996 TSD, ma nufacturers stated that any in crease in ef ficiency due to a reflective surface could easily be negated if the consumer fails to regularly clean the surface or uses an abrasive pad to clean the surface. Ther efore, it would be necessary to replace reflective pans periodically at a high replacement cost. Also, because this technology has not been commercialized, it is not possible to assess whether it will have any other adverse impacts on equipment utility to consumers or equipment availability or any adverse impacts on consumers’ health or safety.
For electric open (coil) cooktops , D OE screened out reflective surfaces, for the reasons that follow. Reflective surfaces As reported in the 1996 TSD, ma nufacturers stated that any in crease in ef ficiency due to a reflective surface could easily be negated if the consumer fails to regularly clean the surface or uses an abrasive pad to clean the surface. Ther efore, it would be necessary to replace reflective pans periodically at a high replacement cost. Also, because this technology has not been commercialized, it is not possible to assess whether it will have any other adverse impacts on equipment utility to consumers orequipment availability, or a ny adverse impacts on consumers’ health or safety.
For electric smooth coo ktops , all technologies meet the screening criteria.
For ovens , DOE screened out added insulation, bi-radiant oven, halogen lam p oven, no oven door window, oven separator, reduced thermal mass, and reflective surfaces, for the reasons

4-5that follow. Added insulation Although some analyses indicated energy c onsumption could be reduced by increasing the thickness of the insulation inthe cabinet walls and doors from 2 inches to 4 inches, consum er utility would be negatively impacted, since the oven cavity volume would have to be reduced to maintain standardized exterior dimensions. Th e reduced oven cavity volu me would limit the size of large items which could be cooked in the ove n. For this reason, this design option was not analyzed. However, it should be noted that improved insulation, consisting of higher-density insulation with the baseline 2-inch thickness, wa s still analyzed for standard gas and electric ovens. This higher-density insula tion is already used for self-clean gas and electric ovens. Bi-radiant oven (electric only) The 1996 TSD assumed that 3 major conditions would have to be m et in order to consider the bi-radiant oven as a viable design option. These included the use of low-emissivity cavity lining materials, electronic controls, and highly-absorptive baking a nd roasting utensils. While electronic controls are currently in widesp read use in electric ovens, cavity maintenance issues and the requirement for specialized cookware negatively impact consumer utility. In addition, there is currently no such product on th e market and the last working prototype known to DOE was tested in the 1970s. Halogen lamp oven (electric only) While GE Consumer & Industrial (GE) curren tly m arkets a line of electric ovens that incorporates halogen elements along with conve ntional resistance heati ng elements, microwave heating, and optionally, a convection system, DOE is not aware of any ovens that utilize halogen lamps alone as the heating element, and no data were found or submitted to demonstrate how efficiently halogen elements alone perform relati ve to conventional ovens. DOE believes that it would not be practicable to manuf acture, install and service halogen lamps for use in consumer cooking products on the scale necessary to serve the relevant market at the time of the standard’s effective date. No oven door window GRI issued a topical report 3 which discussed this desi gn option in the previous rulemaking. The report was submitted as a written comment to the associated NOPR. GRI’s experimental tests showed a small savings in an nual energy usage (increase in efficiency) for both the standard and self-clean ovens by eliminating the door window. However, GRI reported there could actually be a net energy loss due to c onsumer practices, which would be a function of the number of times a consumer would open the door to inspect the food while cooking. With 4 door openings per test (per the DOE test proced ure), a standard oven would realize a net energy savings of 34 kBtu/yr. For a self-clean oven ther e is a net energy loss of 3 kBtu/yr. The report also stated there would be reducedconsumer utility and the possibi lity of failure of delicate food

4-6items (e.g., soufflés), as well as decreased safety without the window due to increased risk of burns from additional door openings while the oven is in use. Oven separator
U.S. manufacturers stated in the previous rulem aking that the use of an oven separator has been researched but has never been put in to production because of problems it would cause both manufacturers and consumers. With regard to conventional gas ovens, manufacturers stated that the separator could not be economically designed for improved efficiency, though an acceptable design for gas convection ovens might be possible. With regard to electric ovens, manufacturers asserted that the separator would require the instal lation of an additional element and a non-conventional oven-control system. Manufacturers also stated thatit would be difficult to obtain Underwriters Laboratory (UL) and Am erican Gas Associati on (AGA) approvals and meet existing ANSI standards because of the e ffect the separator would have on safety and performance. Manufacturers further stated th at consumer acceptance would probably be low because appliances such as micr owave and toaster ovens already ex ist to cook small loads. In addition, the separator would have to be designed to be “fool-proof” to prevent consumers from accidentally installing it incorrectly. With regard to energy use, the additional metal added to the oven by the separator (increased thermal mass) might result in increased energy losses, although data provided by AHAM indicated an increase in efficiency of approximately 0.82 percentage points in an electric oven. However, the anti cipated negative impacts on consumer utility and safety, along with practicabil ity to manufacture, resulted in DOE screening out the oven separator from further analysis. Reduced thermal mass Manufacturers commented in the 1996 TSD th at therm al mass reduction was not possible for then-manufactured electric and gas ovens. They stated that the oven walls must provide strong enough support to hold racks when baking heavy items (i.e., turkeys or large roasts). Oven metal gauges could not be reduced any further without risking crack ing and greater heat losses. 4 DOE believes this situation is still the case incurrent ovens. Due to issues of structural integrity during use and transportation as well as the issue of consumer product safety, this design option was not analyzed. Reflective surfaces Manufacturers stated in the pr evious rulem aking that it has been very difficult to obtain satisfactory cooking performance with reflective su rfaces. The reflective ma terials degrade after the first baking function and continue to degr ade through the life of th e product. This is especially true of self -cleaning ovens as the self-cleaning process damages the reflective walls and negates any possible energy savings. 5
GRI 6 performed tests on this design option wh ich resulted in a decrease in energy efficiency. The reflective surface interfered withthe convective currents and the thermostat, thus fooling the thermostat into cycling. They reported that increased reflectance from the chrome4-7plated inner surface of the oven cau sed repeated thermostat cycling, that “might have contributed to the higher energy consumption” which re sulted in a 12.61 percen t decrease in energy efficiency. Arthur D. Little Inc. (ADL) 7 also commented that the reflected radiation was different from the normal radiation emitted by the oven cavities in use at the time. Based on these studies, it is uncertain whethe r, or how much, energy savings is realizable with this design option. A smarte r controller for the oven seems to be a reasonable fix for the problem. However, there is a general lack of sophistication in the technology in terms of maintaining clean, reflective surf aces over the lifetime of the product. For these reasons, this design option was not analyzed.
For microw ave ovens , all technologies meet the screening criteria.
4.2.1.4 Commercial Clothes Washers For commercial clothes w ashers , DOE screened out bubble action, electric disassociation of water, ozonate d laundering, reduced thermal ma ss, suds saving, and ultrasonic washing for the reasons that follow. Bubble action Although bubble washing has been incorporatedinto comm ercial pr oducts, production is extremely limited and further co mmercialization would require ma nufacturers to develop entirely new platforms. Therefore, DOE does not believ e that this technology w ould be practicable to manufacture, install, and service on the scale necessary to serve the relevant market at the time of the effective date of an amended standard. Electric disassociation of water Electric disassociation of water is in the rese arch stage, so D OE be lieves that it would not be practicable to manufacture, in stall and service this technology on the scale necessary to serve the relevant market at the time of the effective date of an amended standard. Also, because this technology is in the research stage, it is not possi ble to assess whether it will have any adverse impacts on equipment utility to consumers or equi pment availability, or any adverse impacts on consumers' health or safety. Ozonated laundering Ozonated laundering is in the research stag e, so DOE believes that it would not be practicab le to manufacture, instal l and service this tec hnology on the scale necessary to serve the relevant market at the time of the effective date of an amended standard. Also, because this technology is in the research stage, it is not possi ble to assess whether it will have any adverse impacts on equipment utility to consumers or equi pment availability, or any adverse impacts on consumers' health or safety.

4-8Reduced thermal mass Reduced thermal mass has not been incorpor ated into comm ercial products, so DOE believes that it would not be practicable to ma nufacture, install and se rvice this technology on the scale necessary to serve the relevant market at the time of the effective date of an amended standard. Also, because this technology has not been incorporated into clothes washers, it is not possible to assess whether it will have any advers e impacts on equipment utility to consumers or equipment availability, or any adverse imp acts on consumers' health or safety. Suds saving Suds-saving residential clothes washers we re p reviously commercially available, but required an adjacent wash tub to store suds in between wash cycles. Due to these installation requirements, DOE believes that suds-saving clothe s washers would be impractical to install in many locations. Suds-saving clothes washers reduce consumer utility by requiring consumers to occupy space adjacent to the washer with an additional washtub. In a commercial setting, this may limit the number of clothes washers that may be installed. In order to fully capture the energy saving benefits of suds saving, c onsumers must wash multiple loads of laundry sequentially. Delays between washing cycles allow the saved water to cool, reducing wash performance and energy savings. Finally, suds -saving washers can carry over heavy soiling between clothing loads, reducing wash performance as well. Therefore, DOE will not consider suds saving as a design option for improving th e energy efficiency of commercial clothes washers. Ultrasonic washing Ultrasonic washing has been demonstrated in clothes washers, but the ultrasonic clothes washer did not adequately rem ove soil from the clothes. Ultrasonic clothes washing would therefore reduce consumer utility by not adequately washing clothes. In addition, bubble cavitations caused by standing ultrasonic waves c ould potentially damage some fragile clothing or clothing fasteners, further reducing consumer utility. Si nce no manufacturers currently produce ultrasonic clothes washers, it is impossibl e to assess whether it will have any impacts on consumer’s health or safety, or product availability.
4.2.2 Remaining Design Options The following sections list the design options for each product covered by this rulem aking that were retained by DOE. Each of these technologies will be evaluated further in the subsequent engineering analysis.
4.2.2.1 Dishwashers For dishw ashers , DOE will consider the following design options for further analysis.

4-9Table 4.2.1 Retained Design Options for Dishwashers 1. Condenser drying 2. Fan/jet drying 3. Flow-through heating 4. Improved fill control 5. Improved food filter 6. Improved motor efficiency 7. Improved spray-arm geometry 8. Increased insulation 9. Low-standby-loss electronic controls 10. Microprocessor controls and fuzzy logic, including adaptive or soilsensing controls 11. Modified sump geometry, with and without dual pumps 12. Variable washing pressures and flow rates
4.2.2.2 Dehumidifiers For dehumidifiers , DOE will consider the following de sign options for further analysis.

Table 4.2.2 Retained Design Opt ions for Dehumidifiers

1. Built-in hygrometer/humidistat 2. Improved compressor efficiency 3. Improved condenser performance 4. Improved controls 5. Improved defrost methods 6. Improved demand-defrost controls 7. Improved evaporator performance 8. Improved fan and fan-motor efficiency 9. Improved flow-control devices 10. Low-standby-loss electronic controls 11. Washable air filters
4.2.2.3 Cooking Products For gas cooktops , DOE retained the technologies lis ted below for further analysis.

Table 4.2.3 Retained Design Options for Gas Cooktops

1. Electronic ignition 2. Insulation 3. Sealed burners 4. Thermostatically-controlled burners

4-10For electric open (coil) cooktops , DOE will consider the following design options for further analysis. Table 4.2.4 Retained Design Optio ns for Electri c Open (Coil) Element Cooktops

1. Electronic controls 2. Improved contact conductance 3. Insulation 4. Low-standby-loss electronic controls
For electric smooth coo ktops , DOE will analyze the following design options.

Table 4.2.5 Retained Design Options for El ectric Smooth Element Co oktops

1. Electronic controls 2. Halogen elements 3. Induction elements 4. Low-standby-loss electronic controls
For gas and electric ovens , DOE retained th e following tech nologies for further analysis.

Table 4.2.6 Retained Design Options for Gas and Electric Ovens

1. Forced convection 2. Improved door seals 3. Improved insulation 4. Low-standby-loss electronic controls 5. Pilotless ignition (gas only) 6. Radiant burner (gas only) 7. Reduced conduction losses 8. Reduced vent rate 9. Steam cooking
For microw ave ovens , DOE retained the technologies listed below for further analysis.

4-11Table 4.2.7 Retained Design Options for Microwave Ovens 1. Added insulation 2. Cooking sensors 3. Dual magnetrons 4. Eliminate or improve ceramic stirrer cover 5. Improved fan efficiency 6. Improved magnetron efficiency 7. Improved power supply efficiency 8. Low-standby-loss electronic controls 9. Modified wave guide 10. Reflective surfaces
4.2.2.4 Commercial Clothes Washers For commercial clothes w ashers , DOE will consider the following design options for further analysis. Table 4.2.8 Retained Design Optio ns for Commercial Clothes Washers

1. Adaptive control systems 2. Added insulation 3. Advanced agitation concepts for vertical-axis machines 4. Automatic water fill control 5. Direct-drive motor 6. Horizontal-axis design 7. Horizontal-axis design with recirculation 8. Improved fill control 9. Improved horizontal-axis-washer drum design 10. Improved water extraction to lowe r rem aining moisture content 11. Increased motor efficiency 12. Low-standby-power design 13. Spray rinse or similar water -reducing rinse technology 14. Steam washing 15. Thermostatically-controlled mixing valves 16. Tighter tub tolerance

4-12REFERENCES

1 U.S. Department of Energy (U.S. DOE). 1998. Technical Support Docum ent: Energy Conservation Standards for C onsumer Products: Cooking Products , Washington, DC, September, 1998.

2 Gas Research Institute (GRI). 1994. Topical Report: Techni cal Input to NAECA Rulemaking for Gas-Fired Ranges . Prepared by Battelle, Columbus, OH, American Gas Association Laboratories, Clev eland, OH, and Arthur D. Little, Ca mbridge, MA for Gas Appliance Technology Center, Chicago, IL . Comment No. 001 to NOPR, GRI-94/0195, July 1994.

3 Ibid.

4 U.S. DOE. 1998. Op. cit.

5 U.S. DOE. 1998

. Op. cit.

6 GRI. 1994. Op. cit.

7 Arthur D. Little Inc. (ADL). 1994. Electric Oven and Cooktop Data Analysis . Prepared by ADL, Cambridge, MA, for Association of Home Appliance Manufacturers, Reference 47066, submitted as comments No. 001 to the Notice of Proposed Rulemaking, July 15, 1994.

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