Building Technologies ProgramOffice of Energy Efficiency and Renewable EnergyU.S. Department of EnergyDecember 17, 2008Test Procedure forClothes Dryers and Room Air ConditionersIncorporation of Provisions for AddressingEnergy Use in Standby and Off ModesNOPR Public Meetingwww1.eere.energy.gov/buildings/appliance_standards/residential/clothes_dryers.htmlwww1.eere.energy.gov/buildings/appliance_standards/residential/room_ac.html2Purpose of the Test Procedure NOPR Public MeetingIntroductionPresent the Department’s proposed test procedures for clothesdryers and room air conditionersSeek comment from participants on the proposed test proceduresDiscuss specific issues or questions related to the proposalDiscuss the next steps for the rulemaking3FinalRuleIntroductionNOPRNOPR issued by DOE on December 2, 2008NOPR Public Meeting today, December 17, 2008Comments on NOPR from interested parties•Transcript records oral comments from today’s public meeting•Written comments (comment period closes 75 days after publication intheFederal Register)DOE reviews and considers all commentsFinal Rule Publication•Final Rule will be issued by the March 31, 2009 deadline required bythe Energy Independence and Security Act of 2007Steps in the Clothes Dryer and Room Air Conditioner TestProcedures Rulemaking4Test Procedure Overview and IssuesIntroduction1.Products Covered by the Test Procedure Changes2.Effective Date for the Amended Test Procedures3.Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for MeasuringStandby Mode and Off Mode Power in Clothes Dryers and Room Air Conditioners4.Determination of Modes to be Incorporated5.Adding Specifications for the Test Methods and Measurements for Clothes Dryer andRoom Air Conditioner Standby Mode and Off Mode Testing6.Calculation of Energy Use Associated with Standby Modes and Off Mode7.Measures of Energy Consumption8.Correction of Text Describing Energy Factor Calculation for Clothes Dryers9.Correction of Text Reference to Room Air Conditioner Test Standard10.Compliance with Other EPCA Requirements5Workshop participants are invited to provide summary comments orstatementsParticipants are also invited to raise their issues on the TestProcedure NOPR for discussion todayComments and Issues from ParticipantsIntroduction6Regulatory HistoryClothes Dryer Test Procedure Final Rule. 46 FR 27324, May 19, 1981.•Established test procedure with provisions for measuring the energyfactor (EF)•Currently provides for a measure of standby mode energy consumptiononly for gas dryers, in the form of pilot energy consumption.Room Air Conditioner Test Procedure Final Rules. 42 FR 27898, June1, 1977; 44 FR 37938, June 29, 1979.•Established and amended test procedure with provisions for measuringthe energy efficiency ratio (EER).•Incorporated by reference:–ANSI Z234.1-1972, “Room Air Conditioners”–ASHRAE Standard 16-69, “Method of Testing for Rating Room AirConditioners”•Does not currently provide for a measure of standby or off mode energyuse.Introduction7Regulatory History – ContinuedEnergy Independence and Security Act of 2007 (EISA 2007)Amendments to the Energy Policy and Conservation Act (42 U.S.C.6291et seq.)•Directs DOE to incorporate a measure of standby- and off-mode energyconsumption into its test procedures for residential clothes dryers androom air conditioners by March 31, 2009•Directs DOE to integrate such energy consumption into the energydescriptor. If technically infeasible, DOE must prescribe a separatestandby mode and off mode energy use test procedure if technicallyfeasible•DOE must consider the most current versions of IEC Standards 62301and 62087.–IEC Standard 62301, Household electrical appliances–Measurement of standbypower, First Edition 2005-06–IEC Standard 62087, Methods of measurement for the power consumption ofaudio, video and related equipment, First Edition 2002-03 [Not Relevant]Introduction8Test Procedure Overview1.Products Covered by the Test Procedure Changes2.Effective Date for the Amended Test Procedures3.Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for MeasuringStandby Mode and Off Mode power in Clothes Dryers and Room Air Conditioners4.Determination of Modes to be Incorporated5.Adding Specifications for the Test Methods and Measurements for Clothes Dryer andRoom Air Conditioner Standby Mode and Off Mode Testing6.Calculation of Energy Use Associated with Standby Modes and Off Mode7.Measures of Energy Consumption8.Correction of Text Describing Energy Factor Calculation for Clothes Dryers9.Correction of Text Reference to Room Air Conditioner Test Standard10.Compliance with Other EPCA Requirements9Products Covered by the Test Procedure Changes – ClothesDryersThe proposed test procedure amendments for clothes dryers coverboth gas and electric clothes dryers. 10 CFR 430.2 provides thefollowing definitions:•“Electric clothes dryer means a cabinet-like appliance designed to dryfabrics in a tumble-type drum with forced air circulation. The heatsource is electricity and the drum and blower(s) are driven by anelectric motor(s).”•“Gas clothes dryer means a cabinet-like appliance designed to dryfabrics in a tumble-type drum with forced air circulation. The heatsource is gas and the drum and blower(s) are driven by an electricmotor(s).”The proposed amendments cover:•Vented gas and electric clothes dryers•Vent-less clothes dryers, including combination washer/dryers.Covered Products10Products Covered by the Test Procedure Changes – Room AirConditioners10 CFR 430.2 defines “room air conditioner” as “a consumer product,other than a ‘packaged terminal air conditioner,’ which is powered bya single phase electric current and which is an encased assemblydesigned as a unit for mounting in a window or through the wall forthe purpose of providing delivery of conditioned air to an enclosedspace. It includes a prime source of refrigeration and may include ameans for ventilating and heating.”Proposed amendments cover:•Room air conditioners designed for single- or double-hung windows–With or without louvered sides–With or without reverse cycle•Casement-slider and casement-only window-type room airconditioners.Covered Products11Test Procedure Overview1.Products Covered by the Test Procedure Changes2.Effective Date for the Amended Test Procedures3.Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for MeasuringStandby Mode and Off Mode power in Clothes Dryers and Room Air Conditioners4.Determination of Modes to be Incorporated5.Adding Specifications for the Test Methods and Measurements for Clothes Dryer andRoom Air Conditioner Standby Mode and Off Mode Testing6.Calculation of Energy Use Associated with Standby Modes and Off Mode7.Measures of Energy Consumption8.Correction of Text Describing Energy Factor Calculation for Clothes Dryers9.Correction of Text Reference to Room Air Conditioner Test Standard10.Compliance with Other EPCA Requirements12Effective Date for the Amended Test ProceduresThe effective date of the modified clothes dryer and room airconditioner test procedures (i.e., the date the amendments arecodified in the CFR) would be 30 days after the date of publicationof a final rule in theFederal Register.DOE’s regulations in the CFR would clarify that the amendedprocedures and calculations for standby and off mode energyconsumption would not need to be performed to determinecompliance with existing energy conservation standards.DOE expects that this clarification would be removed in any new oramended energy conservation standard rulemaking that accountsfor standby and off mode energy consumption (currently scheduledto be issued June 2011, with an effective date of June 2014).Effective Date13Test Procedure Overview1.Products Covered by the Test Procedure Changes2.Effective Date for the Amended Test Procedures3.Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for MeasuringStandby Mode and Off Mode power in Clothes Dryers and Room Air Conditioners4.Determination of Modes to be Incorporated5.Adding Specifications for the Test Methods and Measurements for Clothes Dryer andRoom Air Conditioner Standby Mode and Off Mode Testing6.Calculation of Energy Use Associated with Standby Modes and Off Mode7.Measures of Energy Consumption8.Correction of Text Describing Energy Factor Calculation for Clothes Dryers9.Correction of Text Reference to Room Air Conditioner Test Standard10.Compliance with Other EPCA Requirements14Incorporating by Reference IEC Standard 62301 (First Edition,2005-06) for Measuring Standby Mode and Off Mode Powerin Clothes Dryers and Room Air ConditionersEPCA, as amended by EISA 2007, requires that amendments to thetest procedure must take into consideration the most currentversion of IEC Standards 62301 and 62087.DOE determined that IEC Standard 62087 does not cover clothesdryers or room air conditioners, and, therefore, was not suitable forthe proposed amendments.IEC Standard 62301 provides for measuring standby power inelectrical appliances, including clothes dryers and room airconditioners, and, thus, is applicable to the proposed amendmentsto the test procedures.Incorporating IEC Standard 6230115IEC Standard 62301DOE proposes to incorporate the same clauses from IEC Standard62301 for measuring both standby mode and off mode powerconsumption.Section 4 clauses – provide conditions for:•Supply voltage, frequency, and waveform•Ambient room air temperature•Power measurement meter tolerancesSection 5 clauses:•Clarify the measurement of standby mode for units with a shortduration higher power state before a lower power state•Provide methods for measuring standby mode and off mode powerwhen the power measurement is either stable or unstable (i.e., variesover a representative cycle).Incorporating IEC Standard 6230116Incorporating IEC Standard 62301Request for Comment on the Incorporation of IEC Standard62301DOE seeks comment on the adequacy of IEC Standard 62301to measure standby power for clothes dryers and room airconditioners in general, and on the suitability of incorporatingthe specified provisions into DOE regulations. (Issue #1)17Standby Mode DefinitionThe EPCA requirement to consider IEC Standard 62301 presents apotential conflict in defining “standby mode.”Paragraph 3.1 of IEC Standard 62301 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 timewhen an appliance is connected to the main electricity supply andused in accordance with the manufacturer’s instructions.”EPCA defines “standby mode” as “the condition in which an energyusing 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 (includingactive mode) by remote switch (including remote control), internal sensor, ortimer.–(bb) Continuous functions, including information or status displays (includingclocks) or sensor-based functions.” (42 U.S.C. 6295(gg)(1)(A)(iii))Prior to EISA 2007, DOE adopted a definition for “standby mode”nearly identical to that of IEC Standard 62301 in the dishwasher testprocedureIncorporating IEC Standard 6230118Request for Comment on Standby Mode DefinitionsWhile EPCA specifies that DOE may consider the definition for“standby mode” provided in the most current version of IECStandard 62301 in updating its test procedure, DOE proposes toadopt the broader, statutory definition of “standby mode” providedin EPCA for reasons of greater specificity and clarity, and to includethat definition in the test procedures for clothes dryers and room airconditioners.Incorporating IEC Standard 62301DOE invites comment on the differences in the definition of “standbymode” provided by EPCA, as amended by EISA 2007, and thedefinition provided in the current version of IEC Standard 62301.(Issue #2)19Other Standby Test Procedures ConsideredDOE also reviewed testing conditions and testing methodsspecified in the test procedures used by countries that areconsidered to be international leaders in reducing standby powerconsumption.These countries include Japan, Korea, and Australia.All use procedures similar to those of IEC Standard 62301 and/orreference that standard.Incorporating IEC Standard 6230120Updated IEC Standard 62301Incorporating IEC Standard 62301IEC is developing an updated test procedure (IEC Standard 62301Ed. 2.0) with a projected publication date of July 2009.•This updated version is expected to include definitions of “off mode,”“network-connected standby mode,” and “disconnected mode,” andwould also revise the current IEC Standard 62301 definition of“standby mode.”DOE expects to publish the final rule for the clothes dryer and roomair conditioner test procedures by March 2009.Therefore, DOE plans to use the current version of IEC Standard62301 in the NOPR.Subsequent amendments to IEC Standard 62301 would become partof the DOE test procedures only if DOE amends its test proceduresto incorporate them.21Test Procedure Overview1.Products Covered by the Test Procedure Changes2.Effective Date for the Amended Test Procedures3.Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for MeasuringStandby Mode and Off Mode power in Clothes Dryers and Room Air Conditioners4.Determination of Modes to be Incorporated5.Adding Specifications for the Test Methods and Measurements for Clothes Dryer andRoom Air Conditioner Standby Mode and Off Mode Testing6.Calculation of Energy Use Associated with Standby Modes and Off Mode7.Measures of Energy Consumption8.Correction of Text Describing Energy Factor Calculation for Clothes Dryers9.Correction of Text Reference to Room Air Conditioner Test Standard10.Compliance with Other EPCA Requirements22Definition of ModesDOE plans to use the EPCA, as amended by EISA 2007, definitions of “activemode,” “standby mode,” and “off mode.”DOE proposes amend to the clothes dryer and room air conditioner testprocedures to clarify the range of main functions that would be classified asactive mode functions and to define multiple standby modes.“Active mode” is defined by EPCA as “the condition in which an energyusing 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))For clothes dryers, DOE proposes that “active mode” define a mode inwhich the clothes dryer is performing the main function of tumbling theclothing with or without heated or unheated forced air circulation to removemoisture from the clothing and/or remove or prevent wrinkling of theclothing.For room air conditioners, DOE proposes that “active mode” define a modein which the room air conditioner is performing the main function of coolingor heating the conditioned space, or circulating air through activation of itsfan or blower, with or without energizing active air-cleaning components ordevices such as ultraviolet (UV) radiation, electrostatic filters, ozonegenerators, or other air-cleaning devices.Modes to be Incorporated23Definition of Modes – ContinuedModes to be Incorporated“Standby mode” is defined by EPCA as “the condition in which anenergy-using product –•(I) is connected to a main power source; and•(II) offers 1 or more of the following user-oriented or protectivefunctions:–(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))“Off mode” is defined by EPCA as “the condition in which anenergy-using product –•(I) is connected to a main power source; and•(II) is not providing any standby mode or active mode function.” (42U.S.C. 6295(gg)(1)(A)(ii))24Proposed Clothes Dryer Standby and Off Modes“Inactive mode” – a standby mode other than delay start mode orcycle finished mode that facilitates the activation of active mode byremote switch (including remote control), internal sensor, or timer,or provides continuous status display“Cycle finished mode” – a standby mode that provides continuousstatus display following operation in active mode“Delay start mode” – a standby mode that facilitates the activationof active mode by timer“Off mode” – a mode in which the clothes dryer is not performingany active or standby functionModes to be Incorporated25Modes to be IncorporatedRequest for Comment on Clothes Dryer Standby ModesDOE seeks comment on the establishment of the following specific standbymodes for clothes dryers: inactive mode, delay start mode, and cycle finishedmode. DOE further invites comment on the definitions proposed for thesemodes and on the question of whether there are any modes consistent withthe “active mode,” “standby mode,” or “off mode” definitions under EPCAthat have not been identified andthat can represent significant energy use.(Issue #3)26Proposed Room Air Conditioner Standby and Off Modes“Active mode” – a mode in which the room air conditioner isperforming the main function of cooling or heating the conditionedspace, or circulating air through activation of its fan or blower, withor without energizing active air-cleaning components or devicessuch as ultraviolet (UV) radiation, electrostatic filters, ozonegenerators, or other air-cleaning devices“Inactive mode” – a standby mode other than delay start mode oroff-cycle mode that facilitates the activation of active mode byremote switch (including remote control) or internal sensor orprovides continuous status display“Delay start mode” – a standby mode in which activation of anactive mode is facilitated by a timerModes to be Incorporated27Proposed Room Air Conditioner Standby and Off Modes –Continued“Off-cycle mode” – a standby mode in which the room airconditioner: (1) has cycled off its main function by thermostat ortemperature sensor; (2) does not have its fan or blower operating;and (3) will reactivate the main function according to the thermostator temperature sensor signal•Off-cycle mode could be considered part of an active mode in which a roomair conditioner is cycling its compressor on and off to maintain an averageroom temperature.•However, since the current test procedure treats the cooling mode asoccurring only when the compressor is operating, DOE proposes the off-cyclemode to account for the time when the space is being conditioned and thecompressor and fan are not operating.“Off mode” – a mode in which a room air conditioner is notperforming any active or standby functionModes to be Incorporated28Modes to be IncorporatedRequest for Comment on Room Air Conditioner Standby ModesDOE seeks comment on the establishment of the following specific standbymodes for room air conditioners: inactive mode, delay start mode, and offcycle mode. DOE further invites comment on the definitions proposed forthese modes and on the question of whether there are any modes consistentwith the “active mode,”, “standby mode,” or “off mode” definitions underEPCA that have not been identified and that can represent significant energyuse. (Issue #4)29Test Procedure Overview1.Products Covered by the Test Procedure Changes2.Effective Date for the Amended Test Procedures3.Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for MeasuringStandby Mode and Off Mode power in Clothes Dryers and Room Air Conditioners4.Determination of Modes to be Incorporated5.Adding Specifications for the Test Methods and Measurements for Clothes Dryer andRoom Air Conditioner Standby Mode and Off Mode Testing6.Calculation of Energy Use Associated with Standby Modes and Off Mode7.Measures of Energy Consumption8.Correction of Text Describing Energy Factor Calculation for Clothes Dryers9.Correction of Text Reference to Room Air Conditioner Test Standard10.Compliance with Other EPCA Requirements30Specifications for Test Methods and Measurements –Clothes DryersAuto-Dimming Displays•DOE proposes that the test be conducted after the power level has droppedto its low level.Delay Start•Paragraph 5.3.1 of IEC Standard 62301 instructs a test technician to“[c]onnect the product to be tested to the metering equipment, and select themode to be measured. After the product has been allowed to stabilize for atleast 5 min, monitor the power consumption for not less than an additional 5min.”•Power consumption during delay start mode may depend on the delay time,the time displayed, and/or the display indication of mode status•DOE proposes to include in the clothes dryer test procedure a specification forthe delay start time to be set at 5 hours, and for power to be monitored for 60minutes after waiting at least 5 minutes for power input to stabilize to ensurecomparable and valid results.•The 5 hour delay start time was determined by analysis of average LEDillumination for different delay start times of 1- and 2-digit displays, as well asa review of current product features.Test Methods and Measurements31Specifications for Test Methods and Measurements –Clothes Dryers (Continued)Test room ambient temperature•DOE proposes to adopt the test room ambient temperature specifiedby IEC Standard 62301 for standby and off mode testing.•Under these conditions, the test room ambient temperature would be73 ± 9°F, which is slightly different from the more stringent ambienttemperature range currently specified for DOE 's drying performancetests (75 ± 3oF).•Manufacturers would have the option to:–Test simultaneously for all three conditions using the current ambienttemperature requirements for drying tests, since these are within thelimits specified by IEC Standard 62301.–Conduct standby and off mode testing separately from drying tests, withmore latitude in ambient conditions.Test Methods and Measurements32Specifications for Test Methods and Measurements –Room Air Conditioners: Delay StartA given unit with a temperature, clock, or timer display may use varyingamounts of standby power depending on the numbers being displayed.Preliminary DOE testing showed that standby power for a room airconditioner with a 2-digit display capable of displaying temperature or delaystart time could vary by as much as 22%.Delay Start•As with clothes dryers, DOE proposes to incorporate Paragraph 5.3.1 of IECStandard 62301.•Power consumption during delay start mode may depend on the delay time,the time displayed, temperature, and/or the display indication of mode status•DOE proposes to include in the room air conditioner test procedure aspecification for the delay start time to be set at 5 hours, and for power to bemonitored for 60 minutes after waiting atleast 5 minutes for power input tostabilize to ensure comparable and valid results.•The 5 hour delay start time was determined by analysis of average LEDillumination for different delay start times of 1- and 2-digit displays, as well asa review of current product features.Test Methods and Measurements33Specifications for Test Methods and Measurements –Room Air Conditioners: Test Room TemperatureSome room air conditioners display actual room temperature, whileothers display setpoint temperature.DOE proposes to address the possibility of these different displayapproaches by requiring that the test room temperature for standbyand off mode measurements be maintained at 74 ± 2 ̊F and that thesetpoint temperature be set at 79 ̊F.•For these temperatures, the power consumption of any display,whether indicating actual or setpoint temperature, represents anaverage power consumption associated with the range of typical userroom temperatures and setpoints.•The proposed room air temperature is lower than that specified in theexisting DOE cooling performance tests (80 ± 0.5 ̊F) in order to:–Ensure that the compressor does not cycle on during standby tests.–Represent actual conditions in which the unit would be in a standby ratherthan active mode.•The proposed test room air temperature specification is within theallowable range in IEC Standard 62301 (73 ± 9 ̊F), which is broadlyspecified to allow measurement of many different products.Test Methods and Measurements34Test Methods and MeasurementsRequest for Comment on Delay Start Test ProcedureDOE invites comment on theproposed clarification to IEC Standard62301, in which DOE would specify in the clothes dryer and room airconditioner test procedures, the set delay start time, stabilizationperiod, and test duration for delay start mode power measurements.(Issue #5)35Test Methods and MeasurementsRequest for Comment on Test Room ConditionsDOE invites comment on the proposed room ambient temperaturerange for standby mode and off mode power measurements for roomair conditioners and clothes dryers. (Issue #6)36Test Procedure Overview1.Products Covered by the Test Procedure Changes2.Effective Date for the Amended Test Procedures3.Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for MeasuringStandby Mode and Off Mode power in Clothes Dryers and Room Air Conditioners4.Determination of Modes to be Incorporated5.Adding Specifications for the Test Methods and Measurements for Clothes Dryer andRoom Air Conditioner Standby Mode and Off Mode Testing6.Calculation of Energy Use Associated with Standby Modes and Off Mode7.Measures of Energy Consumption8.Correction of Text Describing Energy Factor Calculation for Clothes Dryers9.Correction of Text Reference to Room Air Conditioner Test Standard10.Compliance with Other EPCA Requirements37The current test procedure established that a gas clothes dryer is in theactive drying mode 140 hours per year, and that the balance of the year(8,620 hours) is the established number of hours associated with the pilotlight energy consumption.DOE proposes to adopt the 140 hours associated with active mode and toassociate the remaining 8,620 hours of the year with standby and off modes.DOE investigated studies of dryer usage patterns which include standby andoff mode, and found only one, conducted in 2000 in Australia:•35 clothes dryers were measured with an average age of 11 years.•The daily time spent in each mode in this study averaged:–15 minutes for “drying” (active mode)–Zero time for “delay start” and “active standby” (inactive) modes–The remaining hours were split 5 percent for “end of program” (cycle finished) modeand 95 percent for “off mode”Calculation of Energy UseStandby and Off Mode Usage Patterns – Clothes Dryers38The average age of the clothes dryers in the study suggests that most ofthese dryers had electromechanical rather than electronic controls•Dryers in the study would not likely have had inactive mode or delay startmode.A different study monitored the time clothes washers in Australia and NewZealand spent in different modes, and showed that the average amount oftime spent in delay start modeper wash cycle was approximately 5 minutes.DOE believes that the results for clothes washers may be applicable forclothes dryers due to:•Similarities between the control capabilities for both types of products•Comparable consumer usage patterns when a clothing load is washed anddried.Calculation of Energy UseStandby and Off Mode Usage Patterns – Clothes Dryers(Continued)39Based on these two information sources, DOE has tentativelyconcluded that a typical modern clothes dryer spends a smallamount of time in delay start mode.•( 5 minutes/cycle) X (416 cycles/yr from DOE test procedure) = 34hours/yrThe remaining time not associated with active mode or delay startmode can be split as suggested by one of the studies•5% allocated to cycle finished mode•95% allocated to off or inactive modeCalculation of Energy UseStandby and Off Mode Usage Patterns – Clothes Dryers(Continued)40Estimate of Annual Energy Use of Clothes Dryer Modes if AllModes are PossibleCalculation of Energy UseModeHoursTypical (W)Annual Energy Use (kWh)Active140 6,90759675Delay Start 341340.1Cycle Finished 4292341Off and Inactive 8,15730.5 to 344 to 2415 minutes per cycle times 416 cycles per year.25 percent of remaining time (0.05 x (8,760 – 140 – 34)).395 percent of remaining time (0.95 x (8,760 – 140 – 34)).4The approximate range of wattages associated with the standby and offmodes are based on the referenced sources and on “Clothes DryersBackground/Issues/Standby,” presented by Robert Foster of EnergyEfficiency Strategies at the E3 White Goods Forum in Sydney, Australia, inFebruary 2007.5For a baseline EF of 3.01 for a standard electric clothes dryer:•(7 lb of clothing)/(3.01 kWh/lb) = 2.33 kWh per cycle•(2.33 kWh/cycle) x (416 cycles/year) = 967 kWh annual energy use•(967 kWh/yr) / (140 hours/yr in active mode) = 6,907 W in active mode41Estimate of Annual Hours for Clothes Dryer ModesCalculation of Energy UseModeAll ModesPossibleNo DelayStart ModeNo CycleFinishedModeNo Delay Start orCycle FinishedModesActive 140 140 140140DelayStart*340 340CycleFinished**429 431 00Off andInactive†8,157 8,189 8,586 8,620*5 minutes per cycle x 416 cycles per year.**5 percent of remaining time.†95 percent of remaining time.42Estimate of Annual Hours for Off/Inactive ModesInformation to guide the allocation of the off/inactive hours forclothes dryers that have both inactive and off modes is currentlyunavailable.Possibilities:•A clothes dryer reverts to an off mode after a specified time ininactive mode•A clothes dryer stays in inactive mode unless the user switches theappliance back to off modeDOE proposes to allocate half of the off/inactive hours to each ofthe two modes, if both are present.Calculation of Energy Use43Calculation of Energy Use Associated with Standby Modes andOff Mode – Clothes DryersDOE proposes to calculate clothes dryer energy use per cycleassociated with standby and off modes by:1.Calculating the product of wattage and allocated hours for allpossible standby and off modes2.Summing the results3.Dividing the sum by 1,000 to convert from Wh to kWh4.Dividing by 416 cycles per yearCalculation of Energy Use44Delay start and cycle finished modes represent a relatively smallnumber of hours at low power consumption levels.DOE could propose specifying hours only for off and inactivemodes to calculate energy use associated with standby and offmodes.In that case, all of the non-active hours, which total 8,620, would beallocated to the inactive and off modes.Calculation of Energy UseAlternative Approach for Calculating Energy Use Associatedwith Standby Modes and Off Mode – Clothes Dryers45Request for Comment on the Energy Use Calculation forStandby Mode and Off Mode for Clothes DryersCalculation of Energy UseDOE seeks comment on the approach for determining totalenergy use for standby mode and off mode for clothes dryers,including its accuracy and test burden. Given that individualunits may be capable of different combinations of standbymodes, DOE also invites comment and requests data on theestimates for annual hours associated with each mode,including the 140 hours specified by the current testprocedure for active mode (drying). (Issue #7)DOE also seeks comment on whether the alternative approachfor calculating standby and off mode annual energy use wouldbe representative of the standby and off mode powerconsumption of clothes dryers currently on the market.46Room Air Conditioner Unplugged TimeDOE is aware that a room air conditioner may be unplugged for acertain percentage of time, and, therefore, will not be in activemode, standby mode, or off mode.For the purposes of this analysis, DOE estimates that approximatelyhalf of room air conditioners are unplugged for half of the year.The “unplugged” time associated with these units is averaged overall units.•(1⁄2 of all room air conditioners) x (1⁄2 x 8,760 annual hours) = 2,190average annual unplugged hours.•(8,760 annual hours) – (2,190 annual unplugged hours) = 6,570average annual plugged-in hoursCalculation of Energy Use47Room Air Conditioner Cooling SeasonThe prime cooling season is estimated to last 90 days a year (2,160hours).During this time, it is estimated that room air conditioners spend750 hours in cooling mode, according to the current test procedure.Calculation of Energy Use48Standby and Off Mode Usage Patterns – Room Air ConditionersDOE estimates that 10 percent of room air conditioners that have a delaystart mode function will use this function for 10 hours a day during thecooling season.•(90 days) x (10 hr/day) x (10 % of units using delay start mode) = 90 annualhours in delay start mode•(2,160 cooling season hours) – (750 annual cooling mode hours) – (90 annualdelay start mode hours) = 1,320 remaining cooling season hoursDOE assumes that these remaining cooling season hours divide equally intowhichever of the following modes are present:•Fan-only mode (an active mode in which the compressor shuts down whenoperating in constant-fan mode or user selection of fan-only operation)•Off-cycle mode•Inactive mode (and/or off mode for units that have such capability)Calculation of Energy Use49Standby and Off Mode Usage Patterns – Room AirConditioners (Continued)The cooling season inactive and/or off mode hours are summed with theadditional inactive and/or off mode hours when the unit is plugged inoutside of the cooling season.•(6,570 total annual plugged-in hours) - (2,160 cooling season hours) = 4,410annual inactive/off mode hours outside of cooling season•For the example where all standby modes are present:–(1,320 remaining cooling season hours) / (3 possible modes in addition to activecooling mode and delay start mode) = 440 annual hours per additional mode duringcooling season–(440 annual inactive/off mode hours during cooling season) + (4,410 annualinactive/off mode hours outside of cooling season) = 4,850 annual inactive/off modehoursCalculation of Energy Use50Annual Energy Use of Room Air Conditioner Modes for aRepresentative Unit with 8,000 Btu/hr Capacity and 9 EER, if AllModes are PossibleCalculation of Energy UseModeHoursTypical (W)Annual Energy Use(kWh)Active Cooling 750 8891667Delay Start 90 220.2Off-Cycle 440 220.9Off/Inactive 4,850 0.5 to 422.5 to 201(8,000 Btu/hr) / (9 Btu/hr/W) = 889 W2Estimates based on DOE measurements of 12 representative units and datareported for window/wall and portable air-conditioners in “Standby ProductProfile 2004/06”, published by the National Appliance and Equipment EnergyEfficiency Committee of Australia in June 2004. Test results demonstratedsomewhat wider range of off/inactive power consumption than was reportedin the NOPR.51Calculation of Energy Use* 10% of units will use delay start for 10 hours/day during the 90-day coolingseason. The 90-day cooling season represents 2,160 hours.** (2,160 cooling season hours – 750 cooling mode hours - delay start mode hours)divided by the number of these three modes which are present (fan-only, off-cycle,and off/inactive). Off and inactive modes are treated as one, and also include allof the 4,410 plugged in hours outside of the cooling season.Estimate of Annual Hours for Room Air Conditioner ModesModeAll ModesPossibleNo DelayStart ModeNo OffCycle ModeNo Delay Start orOff-Cycle ModesActive,Cooling750 750 750750Active, FanOnly**440 470 660705Delay Start* 90 0900Off-Cycle** 440 47000Off andInactive**4,850 4,880 5,0705,11552DOE is unaware of any room air conditioners that incorporate bothoff and inactive modes.•Typically, room air conditioners with remote control can be controlledwhenever they are plugged in; hence, these units do not include anoff mode.If a room air conditioner allows the user to switch off remote controloperation, such a product would be capable of both inactive and offmode.•For these units, DOE proposes that the plugged-in non-active hoursbe allocated equally to the inactive and off modes.Calculation of Energy UseEstimate of Annual Hours for Off/Inactive Modes53Calculation of Energy Use Associated with Standby Modes andOff Mode – Room Air ConditionersDOE proposes to calculate room air conditioner annual energy useassociated with standby and off modes by:1.Calculating the products of wattage and allocated hours for allpossible standby and off modes2.Summing the results3.Dividing the sum by 1,000 to convert from Wh to kWhCalculation of Energy Use54Delay start and off-cycle modes represent a relatively small numberof hours at low power consumption levels.DOE could propose specifying hours only for off and inactivemodes to calculate energy use associated with standby and offmodes.In that case, all of the non-active hours, which total 5,115, would beallocated to the inactive and off modes.Calculation of Energy UseAlternative Approach for Calculating Energy Use Associatedwith Standby Modes and Off Mode – Room Air Conditioners55Request for Comment on the Energy Use Calculation forStandby Mode and Off Mode for Room Air ConditionersCalculation of Energy UseDOE seeks comment on the approach for determining totalenergy use for standby mode and off mode for room airconditioners including its accuracy and test burden. Giventhat individual units may be capable of different combinationsof standby modes, DOE also invites comment and requestsdata on the estimates for annual hours associated with eachmode, including the estimate of “unplugged” time. (Issue #8)DOE also seeks comment on whether the alternative approachfor calculating standby and off mode annual energy use wouldbe representative of the standby and off mode powerconsumption of room air conditioners currently on the market.56Test Procedure Overview1.Products Covered by the Test Procedure Changes2.Effective Date for the Amended Test Procedures3.Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for MeasuringStandby Mode and Off Mode power in Clothes Dryers and Room Air Conditioners4.Determination of Modes to be Incorporated5.Adding Specifications for the Test Methods and Measurements for Clothes Dryer andRoom Air Conditioner Standby Mode and Off Mode Testing6.Calculation of Energy Use Associated with Standby Modes and Off Mode7.Measures of Energy Consumption8.Correction of Text Describing Energy Factor Calculation for Clothes Dryers9.Correction of Text Reference to Room Air Conditioner Test Standard10.Compliance with Other EPCA Requirements57Measures of Energy ConsumptionDOE test procedures for clothes dryers and room air conditioners currentlyprovide for the calculation of several measures of energy consumption.•Clothes Dryers–Total per-cycle electric dryer energy consumption–Per-cycle gas dryer electrical energy consumption–Per-cycle gas dryer gas energy consumption–Per-cycle gas dryer continuously burning pilot light gas energy consumption–Total per-cycle gas dryer gas energy consumption expressed in Btu and kWh–EF (equal to the clothes load in pounds divided by either the total per-cycle electricdryer energy consumption or by the total per-cycle gas dryer energy consumptionexpressed in kWh)•Room Air Conditioners–Annual energy consumption in kWh–EERMeasures of Energy Consumption58Measures of Energy ConsumptionSection 325(gg)(2)(A) of EPCA, requiresamendments to the test procedureto include standby mode and off mode energy consumption “with suchenergy consumption integrated into the overall energy efficiency, energyconsumption, or other energy descriptor for each covered product, unlessthe Secretary determines that—(i) the current test procedures for a covered product already fully account for andincorporate standby mode and off mode energy consumption of the coveredproduct; or(ii) such an integrated test procedure is technically infeasible for a coveredproduct, in which case the Secretary shall prescribe a separate standbymode and off mode energy use test procedure for the covered product, iftechnically feasible.” (42 U.S.C. 6296(gg)(2)(A))DOE explored whether the existing measures ofenergy consumption forclothes dryers and room air conditioners can be combined with standbymode and off mode energy use to form a single metric.Measures of Energy Consumption59Measures of Energy ConsumptionDOE notes that certain test procedures do combine a measure ofcycle efficiency and standby energy use to derive an overall energyefficiency measure.•When the difference in energy use between the primary function ofthose products and the standby power is so large that the standbypower has little impact on the overall measure of energy efficiency,as is the case for clothes dryers and room air conditioners, thecombined measure of energy efficiency is a meaningful measure.Therefore, DOE is proposing a combined metric addressing active,standby, and off modes for both clothes dryers and room airconditioners.Measures of Energy Consumption60Measures of Energy Consumption – Clothes DryersDOE proposes to establish the following integrated measures ofenergy consumption:•“Per-cycle integrated total energy consumption expressed in kWh” =–(per-cycle standby and off mode energy consumption) + (total per-cycleelectric dryer energy consumption) for electric dryers–(per-cycle standby and off mode energy consumption) + (total per-cyclegas dryer energy consumption expressed in kWh) for gas dryers•“Integrated energy factor” (IEF) = (clothes dryer test load weight inlb) / (per-cycle integrated total energy in kWh)Measures of Energy Consumption61Measures of Energy Consumption – Room Air ConditionersDOE proposes to establish the following integrated measures ofenergy consumption:•“Integrated annual energy consumption” = (annual energyconsumption) + (standby and off mode energy consumption)•“Integrated energy efficiency ratio” (IEER) = (cooling capacity inBtu/hr) x (750 annual cooling mode hours) / (integrated annualenergy consumption x 1,000 Wh per kWh)Measures of Energy Consumption62Measures of Energy ConsumptionRequest for Comment on the New Integrated Measures ofEnergy Consumption and Energy EfficiencyDOE invites comment on the proposed plan to establish newintegrated measures of energy consumption and energyefficiency for clothes dryers and room air conditioners: “percycle integrated total energy consumption expressed inkilowatt-hours” and “integrated energy factor” for clothesdryers; and “integrated annual energy consumption” and“integrated energy efficiency ratio” for room air conditioners.(Issue #9)63Test Procedure Overview1.Products Covered by the Test Procedure Changes2.Effective Date for the Amended Test Procedures3.Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for MeasuringStandby Mode and Off Mode power in Clothes Dryers and Room Air Conditioners4.Determination of Modes to be Incorporated5.Adding Specifications for the Test Methods and Measurements for Clothes Dryer andRoom Air Conditioner Standby Mode and Off Mode Testing6.Calculation of Energy Use Associated with Standby Modes and Off Mode7.Measures of Energy Consumption8.Correction of Text Describing Energy Factor Calculation for Clothes Dryers9.Correction of Text Reference to Room Air Conditioner Test Standard10.Compliance with Other EPCA Requirements64Correction of Text Describing Energy Factor Calculation forClothes DryersThe reference to sections 2.6.1 and 2.6.2 of 10 CFR part 430, subpartB, appendix D in the calculation of EF for clothes dryers found atsection 430.23(d)(2) is incorrect.•Sections 2.7.1 and 2.7.2 should be referenced instead.•Section 2.6 provides instructions for the test cloths to be used inenergy testing of clothes dryers, whereas section 2.7 providesinstructions on test loads.Since the EF calculation requires the weight of the test load, DOEproposes to correct these references in 10 CFR 430.23(d)(2).Correction of Clothes Dryer Text65Test Procedure Overview1.Products Covered by the Test Procedure Changes2.Effective Date for the Amended Test Procedures3.Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for MeasuringStandby Mode and Off Mode power in Clothes Dryers and Room Air Conditioners4.Determination of Modes to be Incorporated5.Adding Specifications for the Test Methods and Measurements for Clothes Dryer andRoom Air Conditioner Standby Mode and Off Mode Testing6.Calculation of Energy Use Associated with Standby Modes and Off Mode7.Measures of Energy Consumption8.Correction of Text Describing Energy Factor Calculation for Clothes Dryers9.Correction of Text Reference to Room Air Conditioner Test Standard10.Compliance with Other EPCA Requirements66Correction of Text Reference to Room Air Conditioner TestStandardThe room air conditioner test procedure currently referencesASHRAE Standard 16-69, “Method of Testing for Rating Room AirConditioners.”The text in 10 CFR part 430, subpart B, appendix F, section 1,however, incorrectly identifies ASHRAE as “American Society ofHeating, Refrigerating and Air Conditioning in Engineers.”•The actual name of the referenced organization is “American Societyof Heating, Refrigerating and Air-Conditioning Engineers.”DOE proposes to correct this reference in 10 CFR part 430, subpartB, appendix F, section 1.Correction of Room Air Conditioner Text67Test Procedure Overview1.Products Covered by the Test Procedure Changes2.Effective Date for the Amended Test Procedures3.Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for MeasuringStandby Mode and Off Mode power in Clothes Dryers and Room Air Conditioners4.Determination of Modes to be Incorporated5.Adding Specifications for the Test Methods and Measurements for Clothes Dryer andRoom Air Conditioner Standby Mode and Off Mode Testing6.Calculation of Energy Use Associated with Standby Modes and Off Mode7.Measures of Energy Consumption8.Correction of Text Describing Energy Factor Calculation for Clothes Dryers9.Correction of Text Reference to Room Air Conditioner Test Standard10.Compliance with Other EPCA Requirements68Test BurdenSection 323(b)(3) of EPCA requires that “[a]ny test procedures prescribed oramended under this section shall be reasonably designed to produce testresults which measure energy efficiency, energy use . . . or estimated annualoperating cost of a covered product during a representative average usecycle or period of use . . . and shall not be unduly burdensome to conduct.”(42 U.S.C. 6293(b)(3))DOE has tentatively concluded that amending the relevant DOE testprocedures to incorporate clauses regarding test conditions and methodsfound in IEC Standard 62301, along with the proposed modifications, wouldsatisfy this requirement.•IEC Standard 62301 is widely used and accepted internationally to measurepower in standby and off mode.•Based on DOE's testing and analysis of IEC Standard 62301, DOEdetermined that the proposed amendments to the test procedures wouldproduce standby and off mode average power consumption measurementsthat are representative of an average use cycle, both when the measuredpower is stable and unstable (i.e., when power varies by more than 5 percentduring 5 minutes).•The proposed test methods and equipment are not substantially differentfrom, or can be even less burdensome to implement than, the current DOEtest procedures for measuring the products’ energy consumption.•Manufacturers would not be required to make significant investments in newfacilities and equipment.Compliance with Other EPCA Requirements69Potential Incorporation of IEC Standard 62087Section 325(gg)(2)(A) of EPCA directs DOE to consider IECStandard 62087 when amending test procedures to include standbymode and off mode power measurements.DOE reviewed IEC Standard 62087 “Methods of measurement forthe power consumption of audio, video, and related equipment”(Second Edition 2008-09) and determined that it would not beapplicable to measuring power consumption of electrical appliancessuch as clothes dryers and room air conditioners.Therefore, DOE has determined that referencing IEC Standard 62087is not necessary for the proposed amendments to the testprocedures that are the subject of this rulemaking.Compliance with Other EPCA Requirements70Integration of Standby Mode and Off Mode Energy Consumptioninto the Energy Efficiency MetricsSection 325(gg)(2)(A) requires that standby mode and off modeenergy consumption be “integrated into the overall energyefficiency, energy consumption, or other energy descriptor for eachcovered product” unless the current test procedures already fullyaccount for the standby mode and off mode energy consumption orif such an integrated test procedure is technically infeasible. (42U.S.C. 6295(gg)(2)(A))•Clothes Dryers – DOE is proposing to incorporate the standby and offmode energy consumption into a “per-cycle integrated total energyconsumption expressed in kilowatt-hours” and into an IEF.•Room Air Conditioners - DOE is proposing to incorporate the standbyand off mode energy consumption into a metric for “integrated annualenergy consumption” and into an IEER.Compliance with Other EPCA Requirements71Integration of Standby Mode and Off Mode Energy Consumptioninto the Energy Efficiency MetricsEPCA provides that test procedure amendments adopted to complywith the new EPCA requirements for standby and off mode energyconsumption will not determine compliance with previouslyestablished standards. (42 U.S.C. 6295(gg)(2)(C))The proposed test procedure amendments pertaining to standbymode and off mode energy consumption would not apply to, andwould have no impact, on existing standards.•Existing energy standards for clothes dryers and room airconditioners, which are based on EF and EER, respectively, wouldnot be altered by today's proposal.The test procedures’ provisions for standby/off mode would berequired to be used for demonstrating compliance with DOE’senergy conservation standards upon the effective date of asubsequent standards rulemaking for clothes dryers and room airconditioners that account for standby mode and off mode powerconsumption.Compliance with Other EPCA Requirements72How to Submit Comments...Public Meeting– oral comments will be captured in the transcript and becomepart of the public record.Written comments– NOPR comment period open until 75 days afterpublication in theFederal RegisterReference docket #: EERE-2008-BT-TP-0010 and/or RIN #: 1904-AB76Email: AHAM2-2008-TP-0010@hq.doe.govMail: Mrs. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program1000 Independence Avenue, SW, Mailstop EE-2JWashington, DC 20585-0121Courier: Mrs. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program950 L'Enfant Plaza, 6th FloorWashington, DC 20024Telephone: (202) 586-2945Closing