# Clothes Washer Rulemaking

Office of Codes and Standards P. Marc LaFrance July 13,1995

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# Clothes Washer Rulemaking

Office of Codes and Standards P. Marc LaFrance July 13, 1995 

# Clothes Washer Rulemaking

Office of Codes and Standards P. Marc LaFrance July 13 , 1995

# Background**SC~:lll1<1** round of energy conser-vat ion standards for clothes washers were initiated by the Advance Noli,e or Proposed Rulemaking published in the Federal Re2ister on November 14, ) 994. NllIl1el'Ous commenls have been received and have been added to the public record. Docket no.**I~E·RM·94-4m.** Inilitial engineering analyses of AHAM submilled data were developed by LBL and made available to Inllnufact urers. IJOE visited the five largest U.S. manufacturers (approximately 98% market share) dun'ng the last two weeks of June 1995. These site visits and today's workshop arc part of DOE's efforts to improve communications with interested panics. so Ihal DOE can obtain beller information and feedback on its preliminary analyses and assumplions. prior to publishing a proposed rule .. 

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# It . Background

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llnd o f e n e r gy co nser-vat ion standards for clothes washers were initiated by the Advance No ti , (: of Propose d Rulemaking published in the Federal Relolister on November 14, 1994. N

tlltl cl'OuS co mm e nt s hav e been re ce iv ed and have been added io the public record, Docket no . 1\1i · RM-94 -40l . Illititial engin ee rin g analyses o f AHi\M submitted data were developed by LBL and made available to 11l1lnufac turcrs. I:>O E vis ited the five larges t U . S . manufacturers (approximately 98% market share) duri'ng the last two week s of June 1995. The se sit e visits and today's worksh op are part of DOE's efforts to improve communications with interes t ed parties . SO that DOE can obtain better information and feedback on its preliminary analyses and ass umption s. pri or to publi s hin g a propos ed rule . ' 

# . Background

Sct'lllld r ound o f e n e r gy co nser-vat ion standards for clothes washers were initiated by the Advance N

nti l: e of P ro pose d Rulemaking published in the Federal Relolister on November 14, 1994. N llltl Cl'O lI S co mm e nt s ha ve been re ce iv ed and have been added io the public record, Docket no . I\Ii - RM -94 -40l . l!lititial engin ee rin g analyses of AHAM submitted data were developed by LBL and made available to 11111nufac turcrs. I:>O E vis ited the fiv e larges t U. S . manufacturers (approximately 98% market share) duri' ng the last two weeks of June 1995. These sit e visits and today's worksh op are part of DOE's efforts to improve communications with interes t ed parties. SO that DOE can obtain better information and feedback on its preliminary analyses and assumptions . pri or to publi s hin g a propos ed rule . .

# Rulemaking Schedule

• This rulemaking has been expedited ·so that DOE could be in a position to hold this workshop today. Based on information developed at this workshop, we will determine the future schedule for this rulemaking. '
• '. DOE 

## understands that the uncertainty regarding this, rulemaking is affecting the industry and will do its best to minimize this to the greatest extent possible. •

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# Rulemaking Schedule

• This rulemaking has been expedited so that DOE could be in a position to hold this workshop today. Based on information developed at this workshop, we will determine th e future schedule for this rulemaking. ' • ' . DOE 

## understands that the uncertainty regarding this , rulemaking is affecting the industry and will do itsbest to minimize this to the greatest extent possible. 

# Rulemaking Schedule

• This rulemaking has been expedited so that DOE could be in a position to hold this workshop today. Based on information developed at this workshop, we will determine th e future schedule for this rulemaking. ' • ' . DOE 

## understands that the uncertainty regarding this , rulemaking is affecting the industry and will do itsbest to minimize this to the greatest extent possible.

# Matters DOE is Considering as a Result of Site Visits General

• Most companies expressed and/or demonstrated various design concepts to achieve significant improvements in energy efficiency.

• Most companies have been or will be investing a large amount of capital to improve their production process and remain competitive.

• Companies stated that the laundry industry is extremely price sensitive due to large volume distributors. 

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# Matters DOE is Considering as a 

# Result of 

# Site Visits General
• Most companies expressed and/or demonstrated various design concepts to achieve significant improvements in energy efficiency. • Mo s t companies have been or 

## will be investing a large amount of capital to improve their production process and remain competitive. • Companies stated that the laundry industry is extremely price sensiti ve due to large volume distributors.

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# Matters DOE is Considering as a 

# Result of 

# Site Visits General
• Most companies expressed and/or demonstrated various design concepts to achieve significant improvements in energy efficiency. • Mo s t companies have been or 

## will be investing a large amount of capital to improve their production process and remain competitive. • Companies stated that the laundry industry is extremely price sensitive due to large volume distributors. 

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Base rase manufacturer cost is too low. . . • -'Base ,asc of 62% RMC is reasonable: some companies may have submitted data based on 'a smaller lesl .Ioad**ver~e~** the AI·IAM lest load (ie. 12.1 loads). •**De~il).n** oplion for reduced tublbasket annulus (clearance) cannot be combined with lower remaining l1loisliirc contcnl (RMCj options.

• Concern aboul DOE using "simple payback" verses a "time value of money payback" was expressed. nOE IISCS il simple payback because that is refened to in the legislation relative to the presumption of economic jllslification. 

# Matters DOE is Considering as a Result of Site Visits

• Analyses should address gas dryers. 

# Analysis/Assumptions

• Assuniption of zero cost savings for detergent with less wash water is valid. 

# Matters DOE is Considering as a Result of Site Visits

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# Analysis/Assumptions

•**c~ r.** **n** o pti o n f or r edu ce d tublb as ke t annulu s (cl earanc e) cannot be combined with lower remainin g mo is ture co nte nt ( RM C) o pti o ns .



### . . • " !l ast! ,as e o f 62 % RM C is reas onabl e: so me co mpanies may have submitted data based on ' a smaller t es t . I o ad ve rses th e AI ·IAM t es t load (i e . 12 . 1 lo ads ) . • An alyses sho uld address g as dryer s . • Ass ul11pti o n o f ze r o cos t s aving s f o r de te rge nt with les s wa s h water is valid . • B ase case manufac ture r cos t is too l ow . • Co nce m abo llt D OE us in g "s impl e payback" ve rses a " time value of money payback" was expressed. n OE uscs a s impl e pa yIJ ac k hccaus e that is r e f e ll" ed to in the legislation relative to the presumption of eco no mi c j us tifi cat io n . 

# Matters DOE is Considering as a Result of Site Visits

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# Analysis/Assumptions

•**c~ir. n**  op lion for r ed uced tublbasket annu lu s (clearanc e) cannot be combined with lower remaining moislure co nte nt (RMC) opti o ns . •**lla ~e**  ,ase of 62 % RM C is reasonable: so me co mpanies may have submitted data based on ' a smaller t es l . load verses the AI ·IAM test load ( ie . 12 . 1 loads) . • Anal yses sho uld address gas dryer s . • As s ulllpti o n of zero cos t sav ing s for de te rge nt with les s wa s h water is valid , Ba sc case manufa c ture r cost is too l ow . • Co nce rn abo ul DOE us in g "s imple payback" verses a " time value of money payback" was expressed. n OE II SCS a s impl e pa y ba ck beca us e that is r e fen · e d to in the legislation relative to the presumption of eco nomic jllstification .

## • Loading access and capacity concerns of horizontal-axis washers can be overcome by design char·acteristics. However, concern about actual load size capability still exists. 

# Matters DOE is Considering as a Result of Site Visits

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## • Initial purchase price of horizontal-axis clothes washers may be significantly higher on a percentage basis. Can this impact be assessed by means other than the traditional consumer and manufacturer impact models? 

# Consumer Impact of New Washers • Based on the predominant view of manufacturers, we believe that the wash performance and fabric care of horizontal-axis washers will be maintained verses current clothes washers. Thermal inertia {::oncerns can be overcome by prewash/pretreatment for**he~vily·** 

## soiled loads. Chemical energy can be used to make up loss in mechanical or thermal energy. 

# Matters DOE is Considering as a Result of Site Visits Consumer Impact of New Washers • Based on the predominant view of manufacturers, we believe that the wash performance and fabric care of horizontal-axis washers will be maintained verses current clothes washers. Thermal inertia**~oncerns** 

## can be overcome by prewash/pretreatment for**he~vily .**  

## soiled loads . Chemical energy can ' be used to make up loss in mechanical or thermal energy. • Loading access and capacity concerns of horizontal-axis washers can be overcome by design**ch~u acteristics.**  

## However, concern about actual load size capability still exists. • Initial purchase price of horizontal-axis clothes washers may be significantly higher on a percentage basis. Can this impact be assessed by means other than the traditional consumer and manufacturer impact models? 

# Matters DOE is Considering as a Result of Site Visits Consumer Impact 

# of New Washers • Based on the predominant view of manufacturers, we believe that the wash performance and fabric care of horizontal-axis washers will be maintained verses current clothes washers. Thermal inertia**~oncerns** 

## can be overcome by prewash/pretreatment for**he~vily** 

## soiled loads . Chemical energy can ' be used to make up loss in mechanical or thermal energy. • Loading access and capacity concerns of horizontal-axis washers can be overcome by design**ch~u acteristics** **.** 

## However, concern about actual load size capability still exists . • Initial purchase price of horizontal-axis clothes washers may be significantly higher on a percentage basis. Can this impact be assessed by means other than the traditional consumer and manufacturer impact models?

# Potential Energy Savings 

# of Vertical-axis Clothes Washers

• What are the potential energy savings using ,automatic fill "control?
• What are the potential energy savings using adaptive control (ie. load soil sensing)?
• Are there other technologies that can obtain significant energy savings? 

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# Potential Energy Savings 

# of Vertical-axis Clothes Washers

• What are the potential energy savings using . automatic fill " control? • What are the potential energy savings using adaptive control (ie. load soil sensing)? • Are there other technologies that can obtain significant energy savings?**.~.,** 

# Potential Energy Savings 

# o. f Vertical-axis Clothes Washers

• What are the potential energy savings using . automatic fill 'control? • What are the potential energy savings using adaptive control (ie. load soil sensing)? • Are there other technologies that can obtain significant energy savings?**.~.,**

# Request for Additional' Manufacturer In,put

• LBL has sent out Manufacturer Impact Analysis su rveys and has not received any responses and only has been asked a few questions.

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# • For the Analysis to be thorough, data must be, submitted. 

# Request for Additional · Manufacturer In. put

• LBL has sent out Manufacturer Impact Analysis su rveys and has not received any responses and only has been asked a few questions.

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# • For the Analysis to be thorough, data must be · submitted. 

# Request for Additional · Manufacturer In. put

• LBL has sent out Manufacturer Impact Analysis su rveys and has not received any responses and only has been asked a few questions.

, 

# • For the Analysis to be thorough, data must be · submitted.