March 27, 2012

The Honorable Dr. Henry C. Kelly Assistant Secretary, Energy Efficiency and Renewable Energy U.S. Department of Energy,

Mail Station EE-10 1000 Independence Avenue, SW Washington, DC 20585

Via e-mail (henry.kelly@ee.doe.gov ) and overnight mail

Re: Petition for Waiver and A pplication for Interim Waiver concerning the measurement of water and energy used in the water softening regeneration process of Dishwashers having an Integrated Water Softener

Dear Assistant Secretary Kelly:

BSH Home Appliance Corporati on (“BSH”) hereby submits this Petition for Waiver and Application for Interi m Waiver pursuant to 10 CFR 430.27, concerning the test procedure for measuring energy consumption of

Dishwashers.

BSH is the manufacturer of household app liances bearing the brand names of Bosch, Thermador, and Gaggenau. Its appli ances include dishwashers, washing machines, clothes dryers, refrigerator-f reezers, ovens, and microwave ovens, and are sold worldwide, including in t he United States. BSH ’s United States operations are headquartered in Irvine, California. BSH’s appliances are produced in the United States and Germany.

10 CFR 430.27(a)(1) provides that any interested person may submit a petition to waive for a particular basic model any requ irement of Section 430.23, or of any appendix to this subpart, upon grounds that the basic model contains one or more design characteristics which either prevent testing of the basic model according to the prescribed test procedur es, or the prescribed test procedures may evaluate the basic model in a manner so unrepresentative of its true energy consumption characteristics, or water c onsumption characteristics as to provide materially inaccurate comparative data. Additionally, 10 CFR 430.27 (b)(2) allows any applicant of a Petition of Waiver to al so request an Interim Waiver if it can be demonstrated the likely success of the Petition for Waiver, while addressing the economic hardship and/or com petitive disadvantage that is likely to result absent

a favorable determination on the A pplication for Interim Waiver.This request for Waiver is directed to Dishwashers containing a built-in or integrated water softener, specifically addressing the energy and water used in the regeneration process of the integr ated water softener. This request is

identical to Waiver Case Number DW -005 (and a pending waiver) previously granted to BSH Home Applia nce Corporation wit h the only modification being to

add additional model numbers. Further, the water softening technology used in

these models is identical to the model s that were previously approved.

Based on the reasoning indi cated herein, BSH submit s that the testing of Dishwashers equipped with a water so ftener under the current DOE test procedure may lead to information that could be consider ed misleading to

consumers.

1. Identification of Basic Models. The Dishwasher models manufactured by BSH which contain an integrated water softener and were not included in previous Waiver applications is as

follows:

Bosch brand:

 Basic Model – SHX5ER##

2. Background The design characteristic that is unique among the abov e listed models is an integrated water softener. The primary function of a water softener is to reduce the high mineral content of “ hard” water. Hard water reduces the effectiveness of detergents leading to additional detergent usage. Hard water also causes increased water spots on dishware, resulting in the

need to use more rinse aid to counterbal ance this effect. “Hard” water can

reduce customer satisfaction with Dishwasher performance resulting in increased pre-rinsing and/or hand washin g as well as increased detergent and rinse agent usage.

The water softening process r equires water usage for both the regeneration process and to flush the system. For purposes of this Waiver request, the term “regenerati on” will include the wa ter and energy used in both the flushing and r egeneration process of the water softener. The water used in the regeneration process is in addition to the water used in the dish washing process. The wate r used in the re generation process

does not occur with each use of the Dishwasher. The frequency of the regeneration process is dependent upon an adjustable water softener setting that is controlled by the end user, and based on the home water hardness. Regeneration frequency will vary great ly depending upon the customer setting of the water softener . Data from the U.S. Geological Survey shows considerable variation in the water hardness within the U.S. and for many locations the use of a water softener is not necessary. Water hardness varies throughout the U.S. with the mean hardness of 217mg/liter or 12.6 grains/gallon (based on information provided by the U.S. Geological Survey located at http://water.usgs.gov/owq/hardnessalkalinity.html ).



### Calculations

Water Use

 Based on the DOE Energy Te st for Dishwashers, the BSH

Dishwashers listed in this waiver with an internal water softener use an average of 6.65 liters of wa ter per dish cleaning cycle.

 Based on an average U.S. water hardness of 12.6 grains/gallon,

the internal BSH Dishwasher wa ter softener system would be set

on “4”.

 Based on a BSH Dishwasher internal water softening system setting of “4” and the dishwasher usin g 6.65 liters of water per run, the water regeneration proc ess would occur every 6 th cycle.

 When using the Dishwasher 215 ti mes per year (per DOE test procedure), the regeneration process would occur 35.8 times (36).

 The internal BSH water softening system uses 4.97 liters (5.0) per regeneration cycle.

 Water usage calculatio n based on above data.

o 36 x 5 = 180 liters per year (4 7.6 gallons) or .84 liters (.22 gallons) each time the dishwasher is used.



### Energy Used in kWh

 Formula W= V x T x K

o V = Weighted Average Water Usage per DOE

o T = Nominal water heater temperature rise of 39° C

o K = Specific heat of water 0.00115

 Calculated Energy use – 180 x 39 x .00115 = 8.0 kWh/yr



### Summary

 A Dishwasher built by BSH with an integrated water softener in a home with a 12.6 grain per gallon water hardness would be cycled through the water softening regener ation process approximately every 6 dish cleaning cycles. When the water used in the water softener regeneration process is apportioned evenly over all dishwasher runs, the amount of energy and water usage per cycle is very low. Based on the assump tions provided, BSH estimates the typical water used in the internal Dishwasher water softener regeneration process at .84 liters (.22 gallons) per use; furthermore, using about 8.0 kWh per year to heat this water in the home hot

water heater.Note: Contrary to current DOE direction, in BSH’s opinion

the water used in the Water So ftening regeneration process has the separate and di stinct purpose of softening water and

we do not feel that this wa ter and energy should be included in the energy usage figures for washing dishes. EN 50242 does not include the water or energy used in the water softening process in the dish washer energy consumption

calculation and BSH would su ggest adopting a similar approach as used in EN50242 w hen the test procedure is updated.

3. Requirements sought to be waived Dishwashers are subjected to test methods outlined in 10 CFR Part 430, Subpart B, App. C, Section 4.3, whic h specifies the method for the water energy calculation.

 To stay consistent with the re cently approved Dishwasher waivers for units with a water softener, BSH is requesting approval to estimate the water and energy us ed in the water softening process based on the design of the BSH Dis hwasher and the calculations and assumptions outlined above.

4. Grounds for Waiver and Interim Waiver 10 CFR 430.27 (a) (1) provides that a Petition to waive a requirement of 430.23 may be submitted upon grounds that the basic model contains one or more design characteristics which either prevent testing of the basic model according to the prescribed test procedures, or the prescribed test procedures may evaluate the bas ic model in a manner so unrepresentative of its true energy consumption characteristics as to provide materially inaccurate comparative data.

If a water softener regeneration proc ess was to occur while running an energy test, the water usage would be ov erstated. In this case, the water energy usage would be unrepresentat ive of the product providing inaccurate data resulting in a competitive disadvantage to BSH.

Granting of an Interim Waiver in this ca se is justified si nce the prescribed test procedures would potentially eval uate the basic model in a manner so unrepresentative of its true energy consumption characteristics as to provide materially inaccurate com parative data. In addition, a similar Interim Waiver and Waiver have previously been granted to BSH.

5. Manufacturers of Similar Products and Affected ManufacturersWeb based research shows that at least two other manufacturers are currently selling dishwashers with an integrated water softener, Miele Inc. and Whirlpool Corporation (Waiver Granted).

Manufacturers selling dishwashers in the United States include AGA Marvel, Arcelik A.S., ASKO Appliances , Inc., Electrolux North America, Inc., Fagor America, Inc., Fisher & Paykel Appliances, GE Appliances and Lighting, Haier America, Indesit Co mpany Sa, Kuppersbusch USA, LG Electronics USA, Miele, Inc., Sa msung Electronics Co., Viking Range Corporation and Whirl pool Corporation.

BSH will notify all companies listed above (as well as AHAM), as required by the Department’s rules, providing t hem with a copy of this Petition for

Waiver and Interim Waiver.

6. Conclusion BSH Home Appliances Corporation hereby requests approval of the Waiver petition and Interim Waiver . By granting said Waivers the Department of Energy will further ensure that water energy is measured in the same way by all Dishwasher Manuf acturer’s that have a integrated water softener. Further, BSH would reques t that these Waiv ers be in good standing until such time that the test procedure can be formally modified to account for integrated water softeners.

BSH Home Appliances certifies t hat all manufacturers of domestic

Dishwashers as listed above have been not ified by letter. Copies of these

notifications are attached.

With Best Regards,

Mike Edwards

Senior Engineer, Performance and Consumption BSH Home Appliances Corporation (FNbG) 100 Bosch Blvd., Building 102 New Bern, NC 28562-6924 mike.edwards@bshg.com www.boschappliances.com Phone (252) 636 4334 Fax (252) 636 4450