TO: 611/2 / f2() 6Z17

COMPANY: f i P'i

TELEPHONE: _____________________ FAX: o// - 2 73- 061-Y

FROM: ILl, /-4114Jce

TELEPHONE: 2-c 2 SC- ^3

Comments: -

ci 7/ED. e xc / ((. c

e 2 i

V C

c/t/-2 C:'

,ft/ ,

/rr A1 /L/ '-1/

(C /

cñ O*

This facsimile consis al__page(s), including the cover sheet Please call the sender fany error.

EE-RM-94-230A COMMENT 19
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy

ACTION: Notice of limited reopening of the comment period.

SUMMARY: Appendix J to Subpart B of 10 C.F.R. Part 430 sets forth the test procedures

required for testing whether clothes washers comply with the existing energy conservation

standards. The Department of Energy (DOE or Department) has proposed to amend these test

procedures. The purpose of this notice is to solicit comments on possible additional amendments

which would require certain specific procedures for testing clothes washers with adaptive

(machine controlled) water fill control capability, and clothes washers with non-traditional

temperature selections.

1

EE-RM-94-230A COMMENT 19
DATES: Written comments in response to this notice must be received by [Insert date 15 days

after publication in Federa' Register].

ADDRESSES: Written comments, 10 copies, are to be submitted to: U.S. Department of

Energy, Office of Energy Efficiency and Renewable Energy, EE-43, Room 1J-018, "Test

Procedure for Clothes Washers and Reporting Requirements for Clothes Washers, Clothes

Dryers, and Dishwashers," Docket No. EE-PM-94-230A, Forrestal Building, 1000 Independence

Avenue, SW, Washington, D.C. 20585, (202)-586-7574.

Copies of the transcript of the public hearing and the public comments received on the

proposed rule, may be read or photocopied at the Department of Energy Freedom of Information

Reading Room, U.S. Department of Energy, Forrestal Building, Room 1E- 190, 1000

Independence Avenue, SW, Washington, D.C. 20585, (202) 586-6020 between the hours of 9:00

a.m. and 4:00 p.m., Monday through Friday, except Federal holidays.

FOR FURTHER INFORMATION CONTACT:

P. Marc LaFrance

U.S. Department of Energy

Energy Efficiency and Renewable Energy

Mail Station EE-43

Forrestal Building

1000 Independence Avenue, SW

Washington, D.C. 20585-0121

(202) 586-8423

2 P:\DATAE4O\EE-43\43COM4ON\LAFRkJJCE2V.fFpgOpN,OO5

EE-RM-94-230A COMMENT 19
Edward Levy, Esq.

U.S. Department of Energy

Office of General Counsel

Mail Station OC-72

Forrestal Building

1000 Independence Avenue, SW

Washington, D.C. 20585

(202)586-9507

SUPPLEMENTARY INFORMATION:

I. Introduction

II. Discussion

A. Adaptive Water Fill Control

Manual and Adaptive Water Fill Control

Multiple Adaptive Water Fill Control Settings

B. Temperature Selections

Multiple Warm Wash Temperature Combination Selections

Multiple Temperature Settings within a Temperature Combination Selection

One and Two Temperature Combination Selections

L Introduction

On March 23, 1995, the Department published a notice of proposed rulemaking to make

several amendments to the clothes washer test procedure. 60 FR 15330 (hereafter referred to as the

Notice of Proposed Rulemaking or NOPR). On July 12, 1995, a hearing on the proposed rule was

held in Washington, DC.

The proposed amendments to the test procedure were based on the same factual foundation

as the existing test procedure and energy conservation standards for clothes washers, so that the

existing energy conservation standard would not have to be adjusted. The Department believes,

3

EE-RM-94-230A COMMENT 19
however, that the existing test procedure currently overstates the average annual energy

consumption for clothes washers because of changes in consumer habits since the current test

procedure was adopted.1 The Department had planned on initiating an additional clothes washer test

procedure rulemaking, at a later date, which would take into account current consumer habits, and

would be used as the basis for considering revision of the clothes washer energy conservation

standards.2

In response to the NOPR, the Association of Home Appliance Manufacturers (AHAM)

submitted comments asking DOE to adopt an additional new test procedure, based on current

consumer habits, which would be used in considering revision of the clothes washer energy

conservation standards, and would take effect when new standards take effect. On April 22, 1996,

the Department proposed such a new clothes washer test procedure, Appendix Ji, as well as certain

additional revisions to the currently applicable test procedure in Appendix J to Subpart B of 10

C.F.R. Part 430. 61 FR 17589 (hereafter referred to as the Supplemental Notice of Proposed

Rulemaking or Supplemental NOPR). The Department proposed to issue a final rule with Iwo test

procedures, to be codified in Appendices "J" and 'Ji" to Subpart B of 10 C.F.R. Part 430. Appendix

"J" would be a revision of the current test procedure, would be consistent with the existing

standards, and would become effective 30 days after issuance of the final rule. Appendix "Ji",

generally based on AHAM's suggested test procedures, would be used in the analysis and review of

1 Proctor & Gamble data indicates a decrease in the use of hot water and the iiumber of cycles per year over time.

2 The second round of clothes washer Standards rulemaking was initiated by the publication of an Advance Notice of Proposed Rulemaking

(ANOPR). (59 FR 56423, Novamber 14, 1994.)

4 P\DATA\E&.4O\EE4343COMMONLAFRANCECWFPROPN.OO5

EE-RM-94-230A COMMENT 19
possible revised efficiency standards, and would apply to any revised standards. Upon adoption of

any revised standards, the Department would amend its regulations to replace Appendix "F' with

Appendix "Ji ."

However, since the publication of the NOPR and the Supplemental NOPR, additional issues

have arisen regarding the Appendix J test procedure. The purpose of today's notice is to obtain

public comment on options the Department is considering for resolving these issues. se issues

arose in the context of interim waivers from the DOE clothes washer test procedure granted by DOE

with respect to clothes washer features that are not covered by the current test procedure. On April

6, 1996, the Department granted General Electric Appliances (GEA) an Interim Waiver (CW-004)

for its3 clothes washer that has multiple warm wash temperature selections, various temperature

settings within each temperature selection, multiple adaptive water fill control settings, and a manual

water fill control option. 61 FR 18129. On Sepiember 6, 1996, the Department granted GEA an

Interim Waiver (CW-005) for its clothes washer that has only two wash/rinse temperature selections.

61 FR 47115. The Department is considering inclusion in the Appendix J test procedure of test

provisions that address these features, and solicits comments only on the issues of whether and how

such features should be addressed in Appendix J.

GEAs clothes wasbeT is actually manufactured by Fisher & Paykel Limited from New Zealand.

5 P:\DATAEE-4OEE-4343COMMON\LAFRANCECWrpROpN.OO5

EE-RM-94-230A COMMENT 19
11. Discussion

A. Adaptive Water Fill Control

The amount of energy that a clothes washer consumes is almost entirely a function of

whether it uses heated or unheated water, and of the temperature and amount of any heated water it

us. Adaptive water fill control in a clothes washer is a control scheme which automatically

determines, without operator intervention, the amount of water used to wash a particular load of

clothing, based on the size of that clothing load. In the NOPR, the Department proposed to amend

Appendix J to include test provisions for adaptive water fill control4 schemes, but proposed no

alteration of the existing test procedures for manual water fill control.5

Manual and Adaptive Water Fill Control

The GEA clothes washer that is the subject of Interim Waiver CW-004, cited above, has both

manual and adaptive water fill control capability. However, neither the current Appendix J test

procedure, nor the proposed amendments to Appendix 1, sets forth a procedure that applies to a

clothes washer that has both of these features. In the upplementa1 NOPR, the Department

proposed that Appendix Ji provide that such machmes be tested in both the manual and adaptive

water fill modes, and that test results be prorated based on the assumption that each mode is used 50

In the NOPR, the terminology used was "machine-controlled water fill," although the Department plans to adopt language used

in the Supplemental NOPR "adaptive water fill controL"

In Appendix I, two types of manual fill control are defined, "sensor filled" and "Limed filled."

6

EE-RM-94-230A COMMENT 19
percent of the time. This methodology is used in Interim Waiver CW-004 granted to GEA. The

Department has not received any negative comment regarding this methodology, and is considering

adoption of this approach for the Appendix' J test procedure. The Department welcomes comments

oti this issue.

Multiple Adaptive Water Fill Control Settings

The GEA clothes washer c vered by Interim Waiver CW-004, also permits adjustment of the

"sensitivity," or relative water fill amounts, for the adaptive water fill control feature. This feature

allows a consumer to fine tune the adaptive water fill control system, and permits use of different

amounts of water for a given amount of clothing being washed. The test method provided to GEA

in Interim Waiver CW-004, requires the two extreme "sensitivities," which provide the most and

least energy intensive results, to be tested. Then these two results, or associated energy consumption

values, are averaged to determine the adaptive water fill control energy consumption value. As

mentioned above, the adaptive water fill control result is then prorated with the manual water fill

control result. The Department has not received any negative comment regarding this methodology

and is considering adoption of this approach for the Appendix J test procedure. The Department

welcomes comments on this issue.

7 P:\DATAEE4O\EE4343COMMON\LAFRANCFCWFPROPN.OO5

EE-RM-94-230A COMMENT 19
B. Temperature Selections

Currently, and as proposed, Appendix J allows for the testing of three basic wash

temperatures, cold, wann, and hot, in several combinations with two rinse temperatures, cold and

warm. The test procedures set forth percentages, called temperature use factors (TIJFs), that

represent the proportion of the time that each combination of wash and rinse temperatures is used.

The test procedures have a set 'fTUFs that applies to each clothes washer that is equipped with

either three, four, five or six discrete temperature combination selections (TCSs) (wash/rinse offering

to a consumer). Clothes washers with these TCSs represent the majority of the market. However,

new clothes washers, such as the GEA clothes washers, have new temperature combinations which

are not explicitly covered by the Appendix J test procedure.

Multiple Warm Wash Temperature Combination Selections

The GEA clothes washer covered by Interim Waiver CW-004 has three different warm wash

selections, each of which has a cold rinse. The warm wash temperatures of these three TCSs are

equally spaced by temperature, so that the temperature of the median warm wash is at the mid-point

between the temperatures of the warmest warm wash and the coolest warm wash The test

methodology provided to GEA in the Interim Waiver required that only the median warm wash TCS

be tested. The above and below median warm wash TCSs were not to be tested. The Department

did not receive any negative comment regarding this methodology.

8 P:\DATA\EE-4O\EE-4343COMMONLAFRANcE\CWFPROPN.OO5

EE-RM-94-230A COMMENT 19
The Department is considering adoption of a similar approach in Appendix J. In addition, the

Department is also considering adoption of additional provisions to address two other situations

where clothes washers have multiple warm wash TCSs. First, similar to the clothes washer covered

by Interim Waiver CW-004, a clothes washer could have a median warm wash selection and two or

more pairs (one selection above and the other below the median) of additional warm selections, with

the two selections in each pair being an equal distance (by temperature) from the median. The

Department contemplates that in such a situon, as under Interim Waiver CW-004, a manufacturer

should have to test only the median warm wash TCS. Second, unlike the clothes washer covered by

Interim Waiver CW-004, a clothes washer could have multiple warm wash TCSs that are not

equidistant from a median warm wash TCS. The Department is considering incorporation into

Appendix J of a requirement that, in such a situation, a manufacturer would test the TCS with the

warm wash temperature that is the next higher selection above the actual mean selection, or above a

theoretical mean warm wash TCS if an actual mean selection does not exist. The Department seeks

comments regarding these issues.

Multiple Temperature Settings within a Temperature Combination Selection

The GEA clothes washer covered by Interim Waiver CW-004 also has multiple temperature

settings, i.e., a range of temperatures from which a consumer, can make a setting within a specific

TCS. Section 3.2.2.2 of the current test procedure requires that the "hottest setting available" be

used for testing the hot wash TCS. In Interim Waiver CW-004, the Department provided a test

methodology to GEA for its clothes washer which requires that the hottest temperature setting

9 P:DATA\OEE-43\43COMMON\LAFRANCE'CWrPROPN.OO5

EE-RM-94-230A COMMENT 19
within a hot, warm or cold TCS be tested.

This approach is similar to the Department's proposal in the NOPR for addressing similar

TCSs that are labeled so as to appear to the consumer to be virtually identical. Tn essence, the

similarly labeled TCSs are two temperature settings for one basic TCS. For example on a single

clothes washer, one cold wash/cold rinse TCS may be labeled "cold/cold," with a wash temperature

that is never heated, and another can be labeled "auto cohl'#'old" with a wash temperature that uses

some hot water. The Department's NOPR proposes that the hottest of these two selections be used

for test results. The Department believes this proposal is consistent with the industry's basic

interpretation of the test procedure. The Department believes this issue is essentially the same as the

multiple temperature setting issue regarding the GEA clothes washer. The Department did not

receive any negative comment regarding the NOPR's provision for similarly labeled TCSs.

However, the Department did receive negative comment from Fisher & Paykel Limited

(Fisher and Paykel)6 in response to the Interim Waiver CW-004 granted to GEA. Fisher & Paykel is

concerned that the test methodology that requires testing at the hottest temperature setting available

within a TCS is inconsistent with the test methodology regarding multiple warm wash TCSs,

discussed above. The two approaches may appear to be inconsistent, but the Department believes

they would establish the best solution given the treatment of multiple warm TCSs in Interim Waiver

CW-004 and the proposal in the NOPR for similarly labeled TCSs. One of the Department's goals in

proposing to amend the Appendix J test procedure is to see that the test procedure does not affect

6 Fisher & Paykel Limited is the manufacturer of the clothes washer that GEA is petitioning for a waiver.

10 PDATA\EE-4O\EE-43\43COMMON\LAFRANCE\CWFPROPN.OO5

EE-RM-94-230A COMMENT 19
the energy rating of any model that must meet the current minimum elficiency standard. In addition,

to the extent possible, the Department wants to ensure that all models are tested and rated on a

comparable basis. Therefore, the Department is considering adoption of provisions for Appendix J

that would require, for each TCS tested, that the test be conducted at the hottest setting available for

that TCS. The Department welcomes comments on this issue.

One and Two Temperature Combination Selections

The GEA clothes washers that are the subject of Interim Waiver CW-005, cited above, have

only two wash/rinse TCSs. One selection has a cold wash and a cold rinse, while the other has a

heated wash and a cold rinse. In the Interim Waiver granted to GEA, the Department provided a

TLJF of 15 percent for the cold/cold selection in these clothes washers, which is the same TUF value

as is contained in the current test procedure for the cold/cold selection for three, four, five, and six

TCS clothes washers. The heated TCS addressed in Interim Waiver CW-005 had the remaining

percentage, or a Tt.JF of 85 percent. The Department did not receive any negative comments

regarding these proration factors. The Department is considering adoption of the same TUF values

for Appendix J.

In addition, the Department proposes to specify that a clothes washer with only one TCS

would be tested at that TCS 100 percent of the time. The Department plans to adopt the following

tables for Appendix J:

11 P:\DATA4O\EE43\43COMMONLAFRANCEcWJ'PkopN.OO5

EE-RM-94-230A COMMENT 19
One temperature selection (n=1)

The Department welcomes comments regarding these issues.

List of Subjects in 10 CFR Part 430

Administrative Practice and Procedure, Energy Conservation, Household Appliances.

Issued in Washington, D.C., Nove er 4 ]f996.

• 1Wsr7L

Christine A. Ervin

Assistant Secretary

• Energy Efficiency and Renewable Energy

12 P:DATA\EE-4O\EE-43\43COMMON\LAFRANCE\CWrpROpN.OO5

Two temperature selection (n=2)

EE-RM-94-230A COMMENT 19