Clothes Washer Rulemaking

Office of Codes and Standards

P. Marc LaFrance

July 13,1995

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 EE-RM-94-403 COMMENT 39

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-vation 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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 EE-RM-94-403 COMMENT 39

. Background 

SC('lIIld rOllnd of energy conser-vat ion standards for clothes washers were initiated by the Advance 

Noti, (: of Proposed Rulemaking published in the Federal Relolister on November 14, 1994. 

Ntlltlcl'OuS comments have been received and have been added io the public record, Docket no. 

1\1i· R M-94-40l. 

Illititial engineering analyses of AHi\M submitted data were developed by LBL and made available to 

11l1lnufacturcrs. 

I:>OE visited the five largest U.S. manufacturers (approximately 98% market share) duri'ng the last two 

weeks of June 1995. 

These site visits and today's workshop are part of DOE's efforts to improve communications with 

interested parties. SO that DOE can obtain better information and feedback on its preliminary analyses 

and assumptions. prior to publishing a proposed rule. ' 

. Background 

Sct'lllld round of energy conser-vat ion standards for clothes washers were initiated by the Advance 

Nntil:e of Proposed Rulemaking published in the Federal Relolister on November 14, 1994. 

N llltlCl'OlIS comments have been received and have been added io the public record, Docket no. 

I\Ii-RM-94-40l. 

l!lititial engineering analyses of AHAM submitted data were developed by LBL and made available to 

11111nufacturcrs. 

I:>OE visited the five largest U.S. manufacturers (approximately 98% market share) duri'ng the last two 

weeks of June 1995. 

These site visits and today's workshop are part of DOE's efforts to improve communications with 

interested parties. SO that DOE can obtain better information and feedback on its preliminary analyses 

and assumptions. prior to publishing a proposed 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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 EE-RM-94-403 COMMENT 39

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 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 

the 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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 EE-RM-94-403 COMMENT 39

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 

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. 

• 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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Base rase manufacturer cost is too low.

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• -'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.

 EE-RM-94-403 COMMENT 39

Matters DOE is Considering 

as a Result of Site Visits . " 

Analysis/Assumptions 

• c~ r. n option for reduced tublbasket annulus (clearance) cannot be combined with lower remaining 

moisture content (RMC) options. 

. . • " !last! ,ase of 62% RMC is reasonable: some companies may have submitted data based on 'a smaller 

test .Ioad verses the AI·IAM test load (ie. 12.1 loads). 

• Analyses should address gas dryers. 

• Assul11ption of ze ro cost savings for detergent with less wash water is valid. 

• Base case manufacturer cost is too low. 

• Concem abollt DOE using "simple payback" verses a "time value of money payback" was expressed. 

n OE uscs a simple payIJack hccause that is refell"ed to in the legislation relative to the presumption of 

economic j ustification. 

Matters DOE is Considering 

as a Result of Site Visits . .. 

Analysis/Assumptions 

• c~ir. n oplion for reduced tublbasket annulus (clearance) cannot be combined with lower remaining 

moislure content (RMC) options. 

• lla ~e ,ase of 62% RM C is reasonable: some companies may have submitted data based on 'a smaller 

tesl .load verses the AI·IAM test load (ie. 12.1 loads). 

• Analyses should address gas dryers. 

• Assulllption of zero cost savings for detergent with less wash water is valid, 

Basc case manufacturer cost is too low. 

• Conce rn aboul DOE using "simple payback" verses a "time value of money payback" was expressed. 

n OE IISCS a simple payback because that is refen·ed to in the legislation relative to the presumption of 

economic 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.

 EE-RM-94-403 COMMENT 39

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~uacteristics. 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~uacteristics . 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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 EE-RM-94-403 COMMENT 39

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 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? 

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Request for Additional'

Manufacturer In,put

• LBL has sent out Manufacturer Impact Analysis

surveys 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.

 EE-RM-94-403 COMMENT 39

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. 

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.