Building Technologies Program 

Office of Energy Efficiency and Renewable Energy 

U.S. Department of Energy

December 17, 2008

Test Procedure for 

Clothes Dryers and Room Air Conditione

Incorporation of Provisions for Addressing 

Energy Use in Standby and Off Modes 

NOPR Public Meeting

www1.eere.energy.gov/buildings/appliance_standards/residential/clothes_dryerswww1.eere.energy.gov/buildings/appliance_standards/residential/room_ac.html

EERE-2008-BT-TP-0010 COMMENT 07
Purpose of the Test Procedure NOPR Public Me

Present the Department’s proposed test procedures for clo

dryers and room air conditioners

Seek comment from participants on the proposed test proDiscuss specific issues or questions related to the proposDiscuss the next steps for the rulemaking

EERE-2008-BT-TP-0010 COMMENT 07
Final

Rule

NOPR

NOPR 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 meet• Written comments (comment period closes 75 days after pu

the Federal Register)

DOE reviews and considers all commentsFinal Rule Publication

• Final Rule will be issued by the March 31, 2009 deadline re

the Energy Independence and Security Act of 2007

Steps in the Clothes Dryer and Room Air Conditione

Procedures Rulemaking

EERE-2008-BT-TP-0010 COMMENT 07
Test Procedure Overview and Issues

1. Products Covered by the Test Procedure Changes2. Effective Date for the Amended Test Procedures3. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) fo

Standby Mode and Off Mode Power in Clothes Dryers and Room Air Cond

4. Determination of Modes to be Incorporated5. Adding Specifications for the Test Methods and Measurements for Clothe

Room Air Conditioner Standby Mode and Off Mode Testing

6. Calculation of Energy Use Associated with Standby Modes and Off Mode7. Measures of Energy Consumption8. Correction of Text Describing Energy Factor Calculation for Clothes Drye

9. Correction of Text Reference to Room Air Conditioner Test Standard

10. Compliance with Other EPCA Requirements

EERE-2008-BT-TP-0010 COMMENT 07
Workshop participants are invited to provide summary com

statements

Participants are also invited to raise their issues on the Te

Procedure NOPR for discussion today

Comments and Issues from Participants

EERE-2008-BT-TP-0010 COMMENT 07
Regulatory History

Clothes Dryer Test Procedure Final Rule. 46 FR 27324, Ma

• Established test procedure with provisions for measuring th

factor (EF)

• Currently provides for a measure of standby mode energy 

only for gas dryers, in the form of pilot energy consumption

Room Air Conditioner Test Procedure Final Rules. 42 FR 2

1, 1977; 44 FR 37938, June 29, 1979.

• Established and amended test procedure with provisions fo

the energy efficiency ratio (EER).

• Incorporated by reference:

– ANSI Z234.1-1972, “Room Air Conditioners”– ASHRAE Standard 16-69, “Method of Testing for Rating Room 

Conditioners”

• Does not currently provide for a measure of standby or off 

use.

EERE-2008-BT-TP-0010 COMMENT 07
Regulatory History – Continued

Energy Independence and Security Act of 2007 (EISA 2007

Amendments to the Energy Policy and Conservation Act (46291 et seq.)

• Directs DOE to incorporate a measure of standby- and off-

consumption into its test procedures for residential clothes room air conditioners by March 31, 2009

• Directs DOE to integrate such energy consumption into the 

descriptor. If technically infeasible, DOE must prescribe a standby mode and off mode energy use test procedure if tefeasible

• DOE must consider the most current versions of IEC Stand

and 62087.

– IEC Standard 62301, Household electrical appliances–Measurem

power, First Edition 2005-06

– IEC Standard 62087, Methods of measurement for the power con

audio, video and related equipment, First Edition 2002-03 [Not Re

EERE-2008-BT-TP-0010 COMMENT 07
Test Procedure Overview

1. Products Covered by the Test Procedure Changes2. Effective Date for the Amended Test Procedures3. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) fo

Standby Mode and Off Mode power in Clothes Dryers and Room Air Cond

4. Determination of Modes to be Incorporated5. Adding Specifications for the Test Methods and Measurements for Clothe

Room Air Conditioner Standby Mode and Off Mode Testing

6. Calculation of Energy Use Associated with Standby Modes and Off Mode7. Measures of Energy Consumption8. Correction of Text Describing Energy Factor Calculation for Clothes Drye

9. Correction of Text Reference to Room Air Conditioner Test Standard

10. Compliance with Other EPCA Requirements

EERE-2008-BT-TP-0010 COMMENT 07
Products Covered by the Test Procedure Changes – C

Dryers

The proposed test procedure amendments for clothes dryer

both gas and electric clothes dryers. 10 CFR 430.2 provides following definitions:

• “Electric clothes dryer means a cabinet-like appliance design

fabrics in a tumble-type drum with forced air circulation. The source is electricity and the drum and blower(s) are driven by electric motor(s).”

• “Gas clothes dryer means a cabinet-like appliance designed 

fabrics in a tumble-type drum with forced air circulation. The source is gas and the drum and blower(s) are driven by an emotor(s).”

The proposed amendments cover:

• Vented gas and electric clothes dryers• Vent-less clothes dryers, including combination washer/dryer

C

EERE-2008-BT-TP-0010 COMMENT 07
Products Covered by the Test Procedure Changes – R

Conditioners

10 CFR 430.2 defines “room air conditioner” as “a consume

other than a ‘packaged terminal air conditioner,’ which is poa single phase electric current and which is an encased assedesigned as a unit for mounting in a window or through the the purpose of providing delivery of conditioned air to an enspace. It includes a prime source of refrigeration and may inmeans for ventilating and heating.”

Proposed amendments cover:

• Room air conditioners designed for single- or double-hung w

– With or without louvered sides – With or without reverse cycle

• Casement-slider and casement-only window-type room air 

conditioners.

C

EERE-2008-BT-TP-0010 COMMENT 07
Test Procedure Overview

1. Products Covered by the Test Procedure Changes2. Effective Date for the Amended Test Procedures3. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) fo

Standby Mode and Off Mode power in Clothes Dryers and Room Air Cond

4. Determination of Modes to be Incorporated5. Adding Specifications for the Test Methods and Measurements for Clothe

Room Air Conditioner Standby Mode and Off Mode Testing

6. Calculation of Energy Use Associated with Standby Modes and Off Mode7. Measures of Energy Consumption8. Correction of Text Describing Energy Factor Calculation for Clothes Drye

9. Correction of Text Reference to Room Air Conditioner Test Standard

10. Compliance with Other EPCA Requirements

EERE-2008-BT-TP-0010 COMMENT 07
Effective Date for the Amended Test Procedu

The effective date of the modified clothes dryer and room 

conditioner test procedures (i.e., the date the amendments codified in the CFR) would be 30 days after the date of pubof a final rule in the Federal Register.

DOE’s regulations in the CFR would clarify that the amend

procedures and calculations for standby and off mode eneconsumption would not need to be performed to determincompliance with existing energy conservation standards.

DOE expects that this clarification would be removed in an

amended energy conservation standard rulemaking that afor standby and off mode energy consumption (currently sto be issued June 2011, with an effective date of June 2014

EERE-2008-BT-TP-0010 COMMENT 07
Test Procedure Overview

1. Products Covered by the Test Procedure Changes2. Effective Date for the Amended Test Procedures3. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) fo

Standby Mode and Off Mode power in Clothes Dryers and Room Air Cond

4. Determination of Modes to be Incorporated5. Adding Specifications for the Test Methods and Measurements for Clothe

Room Air Conditioner Standby Mode and Off Mode Testing

6. Calculation of Energy Use Associated with Standby Modes and Off Mode7. Measures of Energy Consumption8. Correction of Text Describing Energy Factor Calculation for Clothes Drye

9. Correction of Text Reference to Room Air Conditioner Test Standard

10. Compliance with Other EPCA Requirements

EERE-2008-BT-TP-0010 COMMENT 07
Incorporating by Reference IEC Standard 62301 (First 

2005-06) for Measuring Standby Mode and Off Mod

in Clothes Dryers and Room Air Conditioner

EPCA, as amended by EISA 2007, requires that amendmen

test procedure must take into consideration the most currversion of IEC Standards 62301 and 62087.

DOE determined that IEC Standard 62087 does not cover c

dryers or room air conditioners, and, therefore, was not suthe proposed amendments.

IEC Standard 62301 provides for measuring standby powe

electrical appliances, including clothes dryers and room aconditioners, and, thus, is applicable to the proposed ameto the test procedures.

Incorporating IEC 

EERE-2008-BT-TP-0010 COMMENT 07
IEC Standard 62301

DOE proposes to incorporate the same clauses from IEC S

62301 for measuring both standby mode and off mode powconsumption.

Section 4 clauses – provide conditions for: 

• Supply voltage, frequency, and waveform• Ambient room air temperature• Power measurement meter tolerances 

Section 5 clauses:

• Clarify the measurement of standby mode for units with a s

duration higher power state before a lower power state

• Provide methods for measuring standby mode and off mod

when the power measurement is either stable or unstable (over a representative cycle).

Incorporating IEC 

EERE-2008-BT-TP-0010 COMMENT 07
Incorporating IEC 

Request for Comment on the Incorporation of IEC Sta

62301

DOE seeks comment on the adequacy of IEC Standard to measure standby power for clothes dryers and room 

conditioners in general, and on the suitability of incorpthe specified provisions into DOE regulations. (Issue #

EERE-2008-BT-TP-0010 COMMENT 07
Standby Mode Definition

The EPCA requirement to consider IEC Standard 62301 pre

potential conflict in defining “standby mode.”

Paragraph 3.1 of IEC Standard 62301 defines “standby mo

“lowest power consumption mode which cannot be switch(influenced) by the user and that may persist for an indefinwhen an appliance is connected to the main electricity supused in accordance with the manufacturer’s instructions.”

EPCA defines “standby mode” as “the condition in which 

using product –

(I) is connected to a main power source; and(II) offers 1 or more of the following user-oriented or protective 

– (aa) To facilitate the activation or deactivation of other functio

active mode) by remote switch (including remote control), intetimer.

– (bb) Continuous functions, including information or status disp

clocks) or sensor-based functions.” (42 U.S.C. 6295(gg)(1)(A

Prior to EISA 2007, DOE adopted a definition for “standby 

nearly identical to that of IEC Standard 62301 in the dishwprocedure

Incorporating IEC 

EERE-2008-BT-TP-0010 COMMENT 07
Request for Comment on Standby Mode Defini

While EPCA specifies that DOE may consider the definitio

“standby mode” provided in the most current version of IEStandard 62301 in updating its test procedure, DOE propoadopt the broader, statutory definition of “standby mode” in EPCA for reasons of greater specificity and clarity, and that definition in the test procedures for clothes dryers and conditioners.

Incorporating IEC 

DOE invites comment on the differences in the definition of “mode” provided by EPCA, as amended by EISA 2007, and thdefinition provided in the current version of IEC Standard 62(Issue #2)

EERE-2008-BT-TP-0010 COMMENT 07
Other Standby Test Procedures Considere

DOE also reviewed testing conditions and testing methods 

specified in the test procedures used by countries that are considered to be international leaders in reducing standby consumption.

These countries include Japan, Korea, and Australia.All use procedures similar to those of IEC Standard 62301 

reference that standard. 

Incorporating IEC 

EERE-2008-BT-TP-0010 COMMENT 07
Updated IEC Standard 62301

Incorporating IEC 

IEC is developing an updated test procedure (IEC Standar

Ed. 2.0) with a projected publication date of July 2009.

• This updated version is expected to include definitions of “o

“network-connected standby mode,” and “disconnected mowould also revise the current IEC Standard 62301 definitio“standby mode.”

DOE expects to publish the final rule for the clothes dryer 

air conditioner test procedures by March 2009.

Therefore, DOE plans to use the current version of IEC Sta

62301 in the NOPR.

Subsequent amendments to IEC Standard 62301 would be

of the DOE test procedures only if DOE amends its test prto incorporate them.

EERE-2008-BT-TP-0010 COMMENT 07
Test Procedure Overview

1. Products Covered by the Test Procedure Changes2. Effective Date for the Amended Test Procedures3. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) fo

Standby Mode and Off Mode power in Clothes Dryers and Room Air Cond

4. Determination of Modes to be Incorporated5. Adding Specifications for the Test Methods and Measurements for Clothe

Room Air Conditioner Standby Mode and Off Mode Testing

6. Calculation of Energy Use Associated with Standby Modes and Off Mode7. Measures of Energy Consumption8. Correction of Text Describing Energy Factor Calculation for Clothes Drye

9. Correction of Text Reference to Room Air Conditioner Test Standard

10. Compliance with Other EPCA Requirements

EERE-2008-BT-TP-0010 COMMENT 07
Definition of Modes

DOE plans to use the EPCA, as amended by EISA 2007, definition

mode,” “standby mode,” and “off mode.”

DOE proposes amend to the clothes dryer and room air condition

procedures to clarify the range of main functions that would be cactive mode functions and to define multiple standby modes.

“Active mode” is defined by EPCA as “the condition in which an e

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

For clothes dryers, DOE proposes that “active mode” define a mo

which the clothes dryer is performing the main function of tumbliclothing with or without heated or unheated forced air circulation moisture from the clothing and/or remove or prevent wrinkling of clothing.

For room air conditioners, DOE proposes that “active mode” defi

in which the room air conditioner is performing the main function or heating the conditioned space, or circulating air through activafan or blower, with or without energizing active air-cleaning compdevices such as ultraviolet (UV) radiation, electrostatic filters, ozogenerators, or other air-cleaning devices.

Modes to 

EERE-2008-BT-TP-0010 COMMENT 07
Definition of Modes – Continued

Modes to 

“Standby mode” is defined by EPCA as “the condition in w

energy-using product –

• (I) is connected to a main power source; and• (II) offers 1 or more of the following user-oriented or protec

functions:

– (aa) To facilitate the activation or deactivation of other functio

(including active mode) by remote switch (including remote cointernal sensor, or timer. 

– (bb) Continuous functions, including information or status disp

(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 

energy-using product –

• (I) is connected to a main power source; and• (II) is not providing any standby mode or active mode funct

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

EERE-2008-BT-TP-0010 COMMENT 07
Proposed Clothes Dryer Standby and Off Mode

“Inactive mode” – a standby mode other than delay start m

cycle finished mode that facilitates the activation of active remote switch (including remote control), internal sensor, or provides continuous status display

“Cycle finished mode” – a standby mode that provides co

status display following operation in active mode

“Delay start mode” – a standby mode that facilitates the ac

of active mode by timer

“Off mode” – a mode in which the clothes dryer is not perf

any active or standby function

Modes to 

EERE-2008-BT-TP-0010 COMMENT 07
Modes to 

Request for Comment on Clothes Dryer Standby 

DOE seeks comment on the establishment of the following specific modes for clothes dryers: inactive mode, delay start mode, and cyclmode. DOE further invites comment on the definitions proposed for modes and on the question of whether there are any modes consistthe “active mode,” “standby mode,” or “off mode” definitions under that have not been identified and that can represent significant ener(Issue #3)

EERE-2008-BT-TP-0010 COMMENT 07
Proposed Room Air Conditioner Standby and Off M

“Active mode” – a mode in which the room air conditioner 

performing the main function of cooling or heating the conspace, or circulating air through activation of its fan or bloor without energizing active air-cleaning components or dsuch as ultraviolet (UV) radiation, electrostatic filters, ozongenerators, or other air-cleaning devices

“Inactive mode” – a standby mode other than delay start m

off-cycle mode that facilitates the activation of active modremote switch (including remote control) or internal sensoprovides continuous status display

“Delay start mode” – a standby mode in which activation o

active mode is facilitated by a timer

Modes to 

EERE-2008-BT-TP-0010 COMMENT 07
Proposed Room Air Conditioner Standby and Off Mo

Continued

“Off-cycle mode” – a standby mode in which the room air 

conditioner: (1) has cycled off its main function by thermotemperature sensor; (2) does not have its fan or blower opand (3) will reactivate the main function according to the thor temperature sensor signal

• Off-cycle mode could be considered part of an active mode in wh

air conditioner is cycling its compressor on and off to maintain an room temperature.

• However, since the current test procedure treats the cooling mod

occurring only when the compressor is operating, DOE proposes mode to account for the time when the space is being conditioned compressor and fan are not operating.

“Off mode” – a mode in which a room air conditioner is no

performing any active or standby function

Modes to 

EERE-2008-BT-TP-0010 COMMENT 07
Modes to 

Request for Comment on Room Air Conditioner Standb

DOE seeks comment on the establishment of the following specific modes for room air conditioners: inactive mode, delay start mode, acycle mode. DOE further invites comment on the definitions proposthese modes and on the question of whether there are any modes cowith the “active mode,”, “standby mode,” or “off mode” definitions EPCA that have not been identified and that can represent significanuse. (Issue #4)

EERE-2008-BT-TP-0010 COMMENT 07
Test Procedure Overview

1. Products Covered by the Test Procedure Changes2. Effective Date for the Amended Test Procedures3. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) fo

Standby Mode and Off Mode power in Clothes Dryers and Room Air Cond

4. Determination of Modes to be Incorporated5. Adding Specifications for the Test Methods and Measurements for Clothe

Room Air Conditioner Standby Mode and Off Mode Testing

6. Calculation of Energy Use Associated with Standby Modes and Off Mode7. Measures of Energy Consumption8. Correction of Text Describing Energy Factor Calculation for Clothes Drye

9. Correction of Text Reference to Room Air Conditioner Test Standard

10. Compliance with Other EPCA Requirements

EERE-2008-BT-TP-0010 COMMENT 07
Specifications for Test Methods and Measureme

Clothes Dryers

Auto-Dimming Displays

• DOE proposes that the test be conducted after the power level ha

to its low level. 

Delay Start

• Paragraph 5.3.1 of IEC Standard 62301 instructs a test technician 

“[c]onnect the product to be tested to the metering equipment, and mode to be measured. After the product has been allowed to stableast 5 min, monitor the power consumption for not less than an a

min.”

• Power consumption during delay start mode may depend on the d

the time displayed, and/or the display indication of mode status

• DOE proposes to include in the clothes dryer test procedure a spe

the delay start time to be set at 5 hours, and for power to be moniminutes after waiting at least 5 minutes for power input to stabilize comparable and valid results.

• The 5 hour delay start time was determined by analysis of average 

illumination for different delay start times of 1- and 2-digit displaysa review of current product features.

Test Methods an

EERE-2008-BT-TP-0010 COMMENT 07
Specifications for Test Methods and Measureme

Clothes Dryers (Continued)

Test room ambient temperature

• DOE proposes to adopt the test room ambient temperature 

by IEC Standard 62301 for standby and off mode testing.

• Under these conditions, the test room ambient temperature 

73 ± 9°F, which is slightly different from the more stringent temperature range currently specified for DOE 's drying petests (75 ± 3oF).

• Manufacturers would have the option to:

– Test simultaneously for all three conditions using the current a

temperature requirements for drying tests, since these are witlimits specified by IEC Standard 62301. 

– Conduct standby and off mode testing separately from drying 

more latitude in ambient conditions.

Test Methods an

EERE-2008-BT-TP-0010 COMMENT 07
Specifications for Test Methods and Measureme

Room Air Conditioners: Delay Start

A given unit with a temperature, clock, or timer display may use v

amounts of standby power depending on the numbers being disp

Preliminary DOE testing showed that standby power for a room a

conditioner with a 2-digit display capable of displaying temperatustart time could vary by as much as 22%. 

Delay Start

• As with clothes dryers, DOE proposes to incorporate Paragraph 5

Standard 62301.

• Power consumption during delay start mode may depend on the d

the time displayed, temperature, and/or the display indication of m

• DOE proposes to include in the room air conditioner test procedur

specification for the delay start time to be set at 5 hours, and for pmonitored for 60 minutes after waiting at least 5 minutes for powestabilize to ensure comparable and valid results.

• The 5 hour delay start time was determined by analysis of average 

illumination for different delay start times of 1- and 2-digit displaysa review of current product features.

Test Methods an

EERE-2008-BT-TP-0010 COMMENT 07
Specifications for Test Methods and Measureme

Room Air Conditioners: Test Room Temperat

Some room air conditioners display actual room temperat

others display setpoint temperature.

DOE proposes to address the possibility of these different 

approaches by requiring that the test room temperature foand off mode measurements be maintained at 74 ± 2 ̊F and setpoint temperature be set at 79 ̊F.

• For these temperatures, the power consumption of any dis

whether indicating actual or setpoint temperature, represenaverage power consumption associated with the range of troom temperatures and setpoints.

• The proposed room air temperature is lower than that spec

existing DOE cooling performance tests (80 ± 0.5 ̊F) in ord

– Ensure that the compressor does not cycle on during standby 

– Represent actual conditions in which the unit would be in a st

than active mode.

• The proposed test room air temperature specification is wit

allowable range in IEC Standard 62301 (73 ± 9 ̊F), which is specified to allow measurement of many different products

Test Methods an

EERE-2008-BT-TP-0010 COMMENT 07
Test Methods an

Request for Comment on Delay Start Test Proced

DOE invites comment on the proposed clarification to IEC St62301, in which DOE would specify in the clothes dryer and rconditioner test procedures, the set delay start time, stabilizaperiod, and test duration for delay start mode power measur(Issue #5)

EERE-2008-BT-TP-0010 COMMENT 07
Test Methods an

Request for Comment on Test Room Condition

DOE invites comment on the proposed room ambient temperrange for standby mode and off mode power measurements air conditioners and clothes dryers. (Issue #6)

EERE-2008-BT-TP-0010 COMMENT 07
Test Procedure Overview

1. Products Covered by the Test Procedure Changes2. Effective Date for the Amended Test Procedures3. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) fo

Standby Mode and Off Mode power in Clothes Dryers and Room Air Cond

4. Determination of Modes to be Incorporated5. Adding Specifications for the Test Methods and Measurements for Clothe

Room Air Conditioner Standby Mode and Off Mode Testing

6. Calculation of Energy Use Associated with Standby Modes and Off Mode7. Measures of Energy Consumption8. Correction of Text Describing Energy Factor Calculation for Clothes Drye

9. Correction of Text Reference to Room Air Conditioner Test Standard

10. Compliance with Other EPCA Requirements

EERE-2008-BT-TP-0010 COMMENT 07
The current test procedure established that a gas clothes dryer is 

active drying mode 140 hours per year, and that the balance of th(8,620 hours) is the established number of hours associated with light energy consumption.

DOE proposes to adopt the 140 hours associated with active mod

associate the remaining 8,620 hours of the year with standby and 

DOE investigated studies of dryer usage patterns which include s

off 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 fi

and 95 percent for “off mode”

Calculatio

Standby and Off Mode Usage Patterns – Clothes D

EERE-2008-BT-TP-0010 COMMENT 07
The average age of the clothes dryers in the study suggests that 

these dryers had electromechanical rather than electronic contro

• Dryers in the study would not likely have had inactive mode or del

mode.

A different study monitored the time clothes washers in Australia 

Zealand spent in different modes, and showed that the average amtime spent in delay start mode per wash cycle was approximately 

DOE believes that the results for clothes washers may be applica

clothes dryers due to:

• Similarities between the control capabilities for both types of produ• Comparable consumer usage patterns when a clothing load is wa

dried.

Calculatio

Standby and Off Mode Usage Patterns – Clothes D

(Continued)

EERE-2008-BT-TP-0010 COMMENT 07
Based on these two information sources, DOE has tentativ

concluded that a typical modern clothes dryer spends a smamount of time in delay start mode.

• ( 5 minutes/cycle) X (416 cycles/yr from DOE test procedu

hours/yr

The remaining time not associated with active mode or de

mode can be split as suggested by one of the studies

• 5% allocated to cycle finished mode • 95% allocated to off or inactive mode

Calculatio

Standby and Off Mode Usage Patterns – Clothes D

(Continued)

EERE-2008-BT-TP-0010 COMMENT 07
Estimate of Annual Energy Use of Clothes Dryer Mod

Modes are Possible

Calculatio

Mode Hours Typical (W) Annual Energy Us

Active 140 6,907

5 967

5

Delay Start 341 3

4 0.1

Cycle Finished 429

2

3

4

1

Off and Inactive 8,157

3 0.5 to 3

4 4 to 24

1 5 minutes per cycle times 416 cycles per year.2 5 percent of remaining time (0.05 x (8,760 – 140 – 34)).3 95 percent of remaining time (0.95 x (8,760 – 140 – 34)).4 The approximate range of wattages associated with the standby and off 

modes are based on the referenced sources and on “Clothes Dryers Background/Issues/Standby,” presented by Robert Foster of Energy Efficiency Strategies at the E3 White Goods Forum in Sydney, AustraliaFebruary 2007.

5 For 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 mode

EERE-2008-BT-TP-0010 COMMENT 07
Estimate of Annual Hours for Clothes Dryer Mod

Calculatio

Mode

All Modes 

Possible

No Delay 

Start Mode

No Cycle 

Finished

Mode

No Delay 

Cycle Fi

Mod

Active 140 140 140 14DelayStart* 34 0 34

0

CycleFinished** 429 431 0

0

Off and Inactive

† 8,157 8,189 8,586 8,62

* 5 minutes per cycle x 416 cycles per year.**5 percent of remaining time.† 95 percent of remaining time.

EERE-2008-BT-TP-0010 COMMENT 07
Estimate of Annual Hours for Off/Inactive Mode

Information to guide the allocation of the off/inactive hours 

clothes dryers that have both inactive and off modes is cuunavailable.

Possibilities:

• A clothes dryer reverts to an off mode after a specified time 

inactive mode

• A clothes dryer stays in inactive mode unless the user swit

appliance back to off mode

DOE proposes to allocate half of the off/inactive hours to e

the two modes, if both are present.

Calculatio

EERE-2008-BT-TP-0010 COMMENT 07
Calculation of Energy Use Associated with Standby Mo

Off Mode – Clothes Dryers

DOE proposes to calculate clothes dryer energy use per c

associated with standby and off modes by: 

1. Calculating the product of wattage and allocated hours for 

possible standby and off modes

2. Summing the results3. Dividing the sum by 1,000 to convert from Wh to kWh4. Dividing by 416 cycles per year

Calculatio

EERE-2008-BT-TP-0010 COMMENT 07
Delay start and cycle finished modes represent a relatively 

number of hours at low power consumption levels.

DOE could propose specifying hours only for off and inact

modes to calculate energy use associated with standby anmodes.

In that case, all of the non-active hours, which total 8,620, 

allocated to the inactive and off modes. 

Calculatio

Alternative Approach for Calculating Energy Use Ass

with Standby Modes and Off Mode – Clothes Dry

EERE-2008-BT-TP-0010 COMMENT 07
Request for Comment on the Energy Use Calcula

Standby Mode and Off Mode for Clothes Drye

Calculatio

DOE seeks comment on the approach for determining energy use for standby mode and off mode for clothes including its accuracy and test burden. Given that indunits may be capable of different combinations of stanmodes, DOE also invites comment and requests data oestimates for annual hours associated with each modeincluding the 140 hours specified by the current test procedure for active mode (drying). (Issue #7)DOE also seeks comment on whether the alternative afor calculating standby and off mode annual energy usbe representative of the standby and off mode power consumption of clothes dryers currently on the marke

EERE-2008-BT-TP-0010 COMMENT 07
Room Air Conditioner Unplugged Time

DOE is aware that a room air conditioner may be unplugge

certain percentage of time, and, therefore, will not be in acmode, standby mode, or off mode.

For the purposes of this analysis, DOE estimates that app

half of room air conditioners are unplugged for half of the 

The “unplugged” time associated with these units is avera

all units. 

• (1⁄2 of all room air conditioners) x (1⁄2 x 8,760 annual hours) 

average annual unplugged hours.

• (8,760 annual hours) – (2,190 annual unplugged hours) = 6

average annual plugged-in hours

Calculatio

EERE-2008-BT-TP-0010 COMMENT 07
Room Air Conditioner Cooling Season

The prime cooling season is estimated to last 90 days a ye

hours).

During this time, it is estimated that room air conditioners 

750 hours in cooling mode, according to the current test p

Calculatio

EERE-2008-BT-TP-0010 COMMENT 07
Standby and Off Mode Usage Patterns – Room Air Con

DOE estimates that 10 percent of room air conditioners that have 

start mode function will use this function for 10 hours a day durincooling season. 

• (90 days) x (10 hr/day) x (10 % of units using delay start mode) = 

hours in delay start mode

• (2,160 cooling season hours) – (750 annual cooling mode hours) – 

delay start mode hours) = 1,320 remaining cooling season hours

DOE assumes that these remaining cooling season hours divide e

whichever of the following modes are present:

• Fan-only mode (an active mode in which the compressor shuts do

operating in constant-fan mode or user selection of fan-only opera

• Off-cycle mode• Inactive mode (and/or off mode for units that have such capability

Calculatio

EERE-2008-BT-TP-0010 COMMENT 07
Standby and Off Mode Usage Patterns – Room 

Conditioners (Continued)

The cooling season inactive and/or off mode hours are summed w

additional inactive and/or off mode hours when the unit is pluggeoutside of the cooling season.

• (6,570 total annual plugged-in hours) - (2,160 cooling season hou

annual 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 

cooling mode and delay start mode) = 440 annual hours per additional cooling season

– (440 annual inactive/off mode hours during cooling season) + (4,410 a

inactive/off mode hours outside of cooling season) = 4,850 annual inachours

Calculatio

EERE-2008-BT-TP-0010 COMMENT 07
Annual Energy Use of Room Air Conditioner Modes 

Representative Unit with 8,000 Btu/hr Capacity and 9 E

Modes are Possible

Calculatio

Mode Hours Typical (W)

Annual Ener

(kWh)

Active Cooling 750 8891 667

Delay Start 90 2

2 0.2

Off-Cycle 440 2

2 0.9

Off/Inactive 4,850 0.5 to 4

2 2.5 to 2

1 (8,000 Btu/hr) / (9 Btu/hr/W) = 889 W2 Estimates based on DOE measurements of 12 representative units and 

reported for window/wall and portable air-conditioners in “Standby ProdProfile 2004/06”, published by the National Appliance and Equipment EEfficiency Committee of Australia in June 2004. Test results demonstrasomewhat wider range of off/inactive power consumption than was repoin the NOPR.

EERE-2008-BT-TP-0010 COMMENT 07
Calculatio

* 10% of units will use delay start for 10 hours/day during the 90-day cool

season. The 90-day cooling season represents 2,160 hours.

** (2,160 cooling season hours – 750 cooling mode hours - delay start mo

divided by the number of these three modes which are present (fan-onland off/inactive). Off and inactive modes are treated as one, and also iof the 4,410 plugged in hours outside of the cooling season.

Estimate of Annual Hours for Room Air Conditioner 

Mode

All Modes 

Possible

No Delay 

Start Mode

No OffCycle Mode No Delay 

Off-Cyc

Active,Cooling 750 750 750 7Active, FanOnly** 440 470 660 7Delay Start* 90 0 90 

Off-Cycle** 440 470 0 

Off and Inactive** 4,850 4,880 5,070 5,1

EERE-2008-BT-TP-0010 COMMENT 07
DOE is unaware of any room air conditioners that incorpo

off and inactive modes.

• Typically, room air conditioners with remote control can be 

whenever they are plugged in; hence, these units do not inoff mode.

If a room air conditioner allows the user to switch off remo

operation, such a product would be capable of both inactivmode.

• For these units, DOE proposes that the plugged-in non-act

be allocated equally to the inactive and off modes.

Calculatio

Estimate of Annual Hours for Off/Inactive Mo

EERE-2008-BT-TP-0010 COMMENT 07
Calculation of Energy Use Associated with Standby Mo

Off Mode – Room Air Conditioners

DOE proposes to calculate room air conditioner annual en

associated with standby and off modes by: 

1. Calculating the products of wattage and allocated hours fo

possible standby and off modes

2. Summing the results3. Dividing the sum by 1,000 to convert from Wh to kWh

Calculatio

EERE-2008-BT-TP-0010 COMMENT 07
Delay start and off-cycle modes represent a relatively sma

of hours at low power consumption levels.

DOE could propose specifying hours only for off and inact

modes to calculate energy use associated with standby anmodes.

In that case, all of the non-active hours, which total 5,115, 

allocated to the inactive and off modes. 

Calculatio

Alternative Approach for Calculating Energy Use Ass

with Standby Modes and Off Mode – Room Air Condi

EERE-2008-BT-TP-0010 COMMENT 07
Request for Comment on the Energy Use Calcula

Standby Mode and Off Mode for Room Air Condi

Calculatio

DOE seeks comment on the approach for determining energy use for standby mode and off mode for room aconditioners including its accuracy and test burden. Gthat individual units may be capable of different combiof standby modes, DOE also invites comment and requdata on the estimates for annual hours associated with mode, including the estimate of “unplugged” time. (IssDOE also seeks comment on whether the alternative apfor calculating standby and off mode annual energy usbe representative of the standby and off mode power consumption of room air conditioners currently on the 

EERE-2008-BT-TP-0010 COMMENT 07
Test Procedure Overview

1. Products Covered by the Test Procedure Changes2. Effective Date for the Amended Test Procedures3. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) fo

Standby Mode and Off Mode power in Clothes Dryers and Room Air Cond

4. Determination of Modes to be Incorporated5. Adding Specifications for the Test Methods and Measurements for Clothe

Room Air Conditioner Standby Mode and Off Mode Testing

6. Calculation of Energy Use Associated with Standby Modes and Off Mode7. Measures of Energy Consumption8. Correction of Text Describing Energy Factor Calculation for Clothes Drye

9. Correction of Text Reference to Room Air Conditioner Test Standard

10. Compliance with Other EPCA Requirements

EERE-2008-BT-TP-0010 COMMENT 07
Measures of Energy Consumption

DOE test procedures for clothes dryers and room air conditioners 

provide for the calculation of several measures of energy consum

• 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 consu

– Total per-cycle gas dryer gas energy consumption expressed in Btu a

– EF (equal to the clothes load in pounds divided by either the total per-

dryer energy consumption or by the total per-cycle gas dryer energy cexpressed in kWh)

• Room Air Conditioners 

– Annual energy consumption in kWh – EER

Measures of Ener

EERE-2008-BT-TP-0010 COMMENT 07
Measures of Energy Consumption

Section 325(gg)(2)(A) of EPCA, requires amendments to the test p

to include standby mode and off mode energy consumption “with energy consumption integrated into the overall energy efficiency, consumption, or other energy descriptor for each covered producthe Secretary determines that—

(i) the current test procedures for a covered product already fully acco

incorporate standby mode and off mode energy consumption of tproduct; or 

(ii) such an integrated test procedure is technically infeasible for a cov

product, in which case the Secretary shall prescribe a separate stmode and off mode energy use test procedure for the covered pr

technically feasible.” (42 U.S.C. 6296(gg)(2)(A)) 

DOE explored whether the existing measures of energy consump

clothes dryers and room air conditioners can be combined with smode and off mode energy use to form a single metric.

Measures of Ener

EERE-2008-BT-TP-0010 COMMENT 07
Measures of Energy Consumption

DOE notes that certain test procedures do combine a mea

cycle efficiency and standby energy use to derive an overaefficiency measure. 

• When the difference in energy use between the primary fu

those products and the standby power is so large that the power has little impact on the overall measure of energy eas is the case for clothes dryers and room air conditionerscombined measure of energy efficiency is a meaningful m

Therefore, DOE is proposing a combined metric addressin

standby, and off modes for both clothes dryers and room conditioners.

Measures of Ener

EERE-2008-BT-TP-0010 COMMENT 07
Measures of Energy Consumption – Clothes Drye

DOE proposes to establish the following integrated measu

energy consumption:

• “Per-cycle integrated total energy consumption expressed 

– (per-cycle standby and off mode energy consumption) + (tota

electric dryer energy consumption) for electric dryers

– (per-cycle standby and off mode energy consumption) + (tota

gas dryer energy consumption expressed in kWh) for gas dry

• “Integrated energy factor” (IEF) = (clothes dryer test load 

lb) / (per-cycle integrated total energy in kWh)

Measures of Ener

EERE-2008-BT-TP-0010 COMMENT 07
Measures of Energy Consumption – Room Air Condi

DOE proposes to establish the following integrated measu

energy consumption:

• “Integrated annual energy consumption” = (annual energy 

consumption) + (standby and off mode energy consumptio

• “Integrated energy efficiency ratio” (IEER) = (cooling capa

Btu/hr) x (750 annual cooling mode hours) / (integrated anenergy consumption x 1,000 Wh per kWh)

Measures of Ener

EERE-2008-BT-TP-0010 COMMENT 07
Measures of Ener

Request for Comment on the New Integrated Measu

Energy Consumption and Energy Efficiency

DOE invites comment on the proposed plan to establisintegrated measures of energy consumption and energefficiency for clothes dryers and room air conditionerscycle integrated total energy consumption expressed ikilowatt-hours” and “integrated energy factor” for clotdryers; and “integrated annual energy consumption” a“integrated energy efficiency ratio” for room air condit(Issue #9)

EERE-2008-BT-TP-0010 COMMENT 07
Test Procedure Overview

1. Products Covered by the Test Procedure Changes2. Effective Date for the Amended Test Procedures3. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) fo

Standby Mode and Off Mode power in Clothes Dryers and Room Air Cond

4. Determination of Modes to be Incorporated5. Adding Specifications for the Test Methods and Measurements for Clothe

Room Air Conditioner Standby Mode and Off Mode Testing

6. Calculation of Energy Use Associated with Standby Modes and Off Mode7. Measures of Energy Consumption8. Correction of Text Describing Energy Factor Calculation for Clothes Drye

9. Correction of Text Reference to Room Air Conditioner Test Standard

10. Compliance with Other EPCA Requirements

EERE-2008-BT-TP-0010 COMMENT 07
Correction of Text Describing Energy Factor Calculat

Clothes Dryers

The reference to sections 2.6.1 and 2.6.2 of 10 CFR part 43

B, appendix D in the calculation of EF for clothes dryers fosection 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 us

energy testing of clothes dryers, whereas section 2.7 proviinstructions on test loads.

Since the EF calculation requires the weight of the test loa

proposes to correct these references in 10 CFR 430.23(d)(2

Correction of C

EERE-2008-BT-TP-0010 COMMENT 07
Test Procedure Overview

1. Products Covered by the Test Procedure Changes2. Effective Date for the Amended Test Procedures3. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) fo

Standby Mode and Off Mode power in Clothes Dryers and Room Air Cond

4. Determination of Modes to be Incorporated5. Adding Specifications for the Test Methods and Measurements for Clothe

Room Air Conditioner Standby Mode and Off Mode Testing

6. Calculation of Energy Use Associated with Standby Modes and Off Mode7. Measures of Energy Consumption8. Correction of Text Describing Energy Factor Calculation for Clothes Drye

9. Correction of Text Reference to Room Air Conditioner Test Standard

10. Compliance with Other EPCA Requirements

EERE-2008-BT-TP-0010 COMMENT 07
Correction of Text Reference to Room Air Conditione

Standard

The room air conditioner test procedure currently referenc

ASHRAE Standard 16-69, “Method of Testing for Rating RoConditioners.”

The text in 10 CFR part 430, subpart B, appendix F, section 

however, incorrectly identifies ASHRAE as “American SocHeating, Refrigerating and Air Conditioning in Engineers.”

• The actual name of the referenced organization is “Americ

of Heating, Refrigerating and Air-Conditioning Engineers.”

DOE proposes to correct this reference in 10 CFR part 430

B, appendix F, section 1.

Correction of Room Air 

EERE-2008-BT-TP-0010 COMMENT 07
Test Procedure Overview

1. Products Covered by the Test Procedure Changes2. Effective Date for the Amended Test Procedures3. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) fo

Standby Mode and Off Mode power in Clothes Dryers and Room Air Cond

4. Determination of Modes to be Incorporated5. Adding Specifications for the Test Methods and Measurements for Clothe

Room Air Conditioner Standby Mode and Off Mode Testing

6. Calculation of Energy Use Associated with Standby Modes and Off Mode7. Measures of Energy Consumption8. Correction of Text Describing Energy Factor Calculation for Clothes Drye

9. Correction of Text Reference to Room Air Conditioner Test Standard

10. Compliance with Other EPCA Requirements

EERE-2008-BT-TP-0010 COMMENT 07
Test Burden

Section 323(b)(3) of EPCA requires that “[a]ny test procedures pr

amended under this section shall be reasonably designed to prodresults which measure energy efficiency, energy use . . . or estimoperating cost of a covered product during a representative averacycle or period of use . . . and shall not be unduly burdensome to (42 U.S.C. 6293(b)(3))

DOE has tentatively concluded that amending the relevant DOE te

procedures to incorporate clauses regarding test conditions and found in IEC Standard 62301, along with the proposed modificatiosatisfy this requirement.

• IEC Standard 62301 is widely used and accepted internationally to 

power in standby and off mode.

• Based on DOE's testing and analysis of IEC Standard 62301, DO

determined that the proposed amendments to the test procedures produce standby and off mode average power consumption measthat are representative of an average use cycle, both when the mepower is stable and unstable (i.e., when power varies by more thaduring 5 minutes). 

• The proposed test methods and equipment are not substantially d

from, or can be even less burdensome to implement than, the curtest procedures for measuring the products’ energy consumption.

• Manufacturers would not be required to make significant investme

facilities and equipment.

Compliance with Other EPC

EERE-2008-BT-TP-0010 COMMENT 07
Potential Incorporation of IEC Standard 620

Section 325(gg)(2)(A) of EPCA directs DOE to consider IEC 

Standard 62087 when amending test procedures to include mode and off mode power measurements. 

DOE reviewed IEC Standard 62087 “Methods of measurem

the power consumption of audio, video, and related equip(Second Edition 2008-09) and determined that it would not applicable to measuring power consumption of electrical asuch as clothes dryers and room air conditioners.

Therefore, DOE has determined that referencing IEC Stand

is not necessary for the proposed amendments to the test procedures that are the subject of this rulemaking.

Compliance with Other EPC

EERE-2008-BT-TP-0010 COMMENT 07
Integration of Standby Mode and Off Mode Energy Cons

into the Energy Efficiency Metrics

Section 325(gg)(2)(A) requires that standby mode and off m

energy consumption be “integrated into the overall energy efficiency, energy consumption, or other energy descriptocovered product” unless the current test procedures alreaaccount for the standby mode and off mode energy consuif such an integrated test procedure is technically infeasibU.S.C. 6295(gg)(2)(A))

• Clothes Dryers – DOE is proposing to incorporate the stan

mode energy consumption into a “per-cycle integrated totaconsumption expressed in kilowatt-hours” and into an IEF.

• Room Air Conditioners - DOE is proposing to incorporate t

and off mode energy consumption into a metric for “integraenergy consumption” and into an IEER.

Compliance with Other EPC

EERE-2008-BT-TP-0010 COMMENT 07
Integration of Standby Mode and Off Mode Energy Cons

into the Energy Efficiency Metrics

EPCA provides that test procedure amendments adopted t

with the new EPCA requirements for standby and off mode consumption will not determine compliance with previousestablished standards. (42 U.S.C. 6295(gg)(2)(C))

The proposed test procedure amendments pertaining to st

mode and off mode energy consumption would not apply would have no impact, on existing standards.

• Existing energy standards for clothes dryers and room air 

conditioners, which are based on EF and EER, respectivelnot be altered by today's proposal.

The test procedures’ provisions for standby/off mode wou

required to be used for demonstrating compliance with DOenergy conservation standards upon the effective date of subsequent standards rulemaking for clothes dryers and rconditioners that account for standby mode and off mode consumption.

Compliance with Other EPC

EERE-2008-BT-TP-0010 COMMENT 07
How to Submit Comments...

 Public Meeting – oral comments will be captured in the transcript 

part of the public record.

 Written comments – NOPR comment period open until 75 days a

publication in the Federal RegisterReference docket #: EERE-2008-BT-TP-0010 and/or RIN #: 1904

Email: AHAM2-2008-TP-0010@hq.doe.gov Mail: Mrs. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program1000 Independence Avenue, SW, Mailstop EE-2J

Washington, DC 20585-0121

Courier: Mrs. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program950 L'Enfant Plaza, 6th Floor

Washington, DC 20024Telephone: (202) 586-2945

EERE-2008-BT-TP-0010 COMMENT 07