5-B-i

APPENDIX 5-B. DATA SUBMITTAL 

TABLE OF CONTENTS 

5-B.1 INTRODUCTION ................................................................................................. 5-B-1

5-B.2 WHIRLPOOL PROPOSED AMENDMENTS TO DOE CLOTHES DRYER 

TEST PROCEDURE ............................................................................................. 5-B-1

5-B.3 AHAM DE-IDENTIFIED CLOTHES DRYER DATA – COLLECTED 

DECEMBER 2007 FOR DOE RULEMAKING ................................................. 5-B-13

5-B.4 DOE RESIDENTIAL CLOTHES DRYER ENGINEERING ANALYSIS 

DATA REQUESTS – AHAM DATA SUBMITTAL ......................................... 5-B-15

5-B.5 DOE ROOM AIR CONDITIONER ENGINEERING ANALYSIS DATA 

REQUESTS – AHAM DATA SUBMITTAL ..................................................... 5-B-20

5-B.6 DOE DATA REQUESTS FOR RESIDENTIAL CLOTHES DRYERS AND 

ROOM AIR CONDITIONERS – AHAM DATA SUBMITTAL 01/09/2009 .... 5-B-25

LIST OF TABLES 

Table 5B.3.1 Residential Clothes Dryer Shipments (in Thousands of Units) ....................... 5-B-13

Table 5B.3.2 Residential Clothes Dryer Market Share Efficiency Data ............................... 5-B-13

Table 5B.3.3 Effect of RMC on Residential Clothes Dryer Energy Factor .......................... 5-B-14

Table 5B.4.1 Residential Clothes Dryer Shipment and Shipment-Weight Average 

Efficiency Data ........................................................................................ 5-B-15

Table 5B.4.2 Residential Clothes Dryer Market Share Efficiency Data: Vented Electric 

Standard ................................................................................................... 5-B-16

Table 5B.4.3 Residential Clothes Dryer Manufacturer Cost Data: Vented Electric 

Standard and Electric Compact 120V ...................................................... 5-B-17

Table 5B.4.4 Residential Clothes Dryer Manufacturer Cost Data: Vented Electric 

Compact 240V and Gas ........................................................................... 5-B-18

Table 5B.6.1 AHAM Weighted RMC for Front-Load and Top-Load Clothes Washer 

Units, 2000-2008...................................................................................... 5-B-25

LIST OF FIGURES 

Figure 5B.5.1 AHAM Room Air Conditioner Market Share, Shipment-Weight Efficiency 

Data, Market Share Efficiency Data Submittal ........................................ 5-B-21

Figure 5B.5.2 AHAM Room Air Conditioner Market Share Efficiency Data Submittal ...... 5-B-21

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-1

APPENDIX 5-B. DATA SUBMISSIONS 

5-B.1 INTRODUCTION 

 This appendix presents the shipments and incremental cost data submitted to the U.S. 

Department of Energy (DOE) by the interested parties in support of the engineering analysis for 

this rulemaking. This appendix presents the Whirlpool Corporation (Whirlpool) proposed 

amendments to the DOE test procedure for clothes dryers to include methods for the testing of 

condensing dryers. Information was provided for residential clothes dryers in response to data 

request sheets generated by DOE and provided to the Association of Home Appliance 

Manufacturers (AHAM). See chapter 5 of the preliminary technical support document 

(preliminary TSD) for details of the engineering analysis for which these data were used. 

5-B.2 WHIRLPOOL PROPOSED AMENDMENTS TO DOE CLOTHES DRYER 

TEST PROCEDURE 

Whirlpool submitted the following proposed amendments to the DOE clothes dryer test 

procedure to include methods for the testing of condensing dryers to DOE on Sept. 4, 2007. 

EERE-2007-BT-STD-0010 COMMENT 20.3
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Background

• Code of Federal Regulations Title 10 – Energy, 

Part 430 “Energy Conservation Program for 

Consumer Products”

• Subpart A section 430.2 states “Electric clothes 

Dryer means a cabinet like appliance designed 

to dry fabrics in a tumble-type Drum with forced 

air circulation. The heat source is electricity and 

the Drum and Blower(s) are driven by an electric 

Motor(s)”

• Appendix D to Subpart B of Part 430 – Uniform 

Test Method For Measuring The Energy 

Consumption of Clothes Dryers

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Background – cont’d

• Appendix D procedure steps which conflict for a 

condensing Dryer:

– Paragraph 2.1 of section 2, “Installation” states: Install the 

clothes Dryer in accordance with the manufacturer’s instructions. 

The Dryer exhaust shall be restricted by adding the AHAM 

exhaust simulator described in 3.3.5 of HDL-1................

– Paragraph 2.8 of section 2, “Clothes Dryer preconditioning” 

states: Before any test cycle, operate the Dryer without a test 

load in the non-heat mode for (15) minutes or until the discharge 

air temperature is varying less than (1) degree F for (10) 

minutes, whichever is longer, in the test installation location with 

the ambient conditions within the specified test condition 

tolerances of 2.2

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-3

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Assessment

• The condensing Dryer falls within the DOE 

definition for a clothes Dryer and therefore is 

required to meet this energy standard

• Define non-exhausted and exhausted Dryers in 

the DOE standard.

• Paragraph 2.1 of section 2 should state nonexhausted Dryers are exempt from the exhaust 

requirement.

• Paragraph 2.8 of section 2, “Clothes Dryer 

preconditioning” needs to be revised to account 

for dryer preconditioning cycle differences 

between exhausted and non-exhausted Dryers

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Condensing Dryer Energy 

Results

Eurotech model EDC158

• Class “C” European energy 

rating

• (3.7) FT3

• (240) VAC @ (60) Hz

• Unit has NO Air Cycle

• (1) unit tested

• Average energy factor = (2.86) 

lbs/Kwh for (3) cold runs

• Average energy factor = 

(3.16) lbs/Kwh for (3) hot runs

• There is a (10.5) percent 

difference between “cold runs 

and hot runs

Whirlpool model AWZ9995

• Class “B” European energy 

rating

• (3.7) FT3

• (230) VAC @ (50) Hz

• Unit has an Air Cycle

• (4) units tested

• Average energy factor = (3.04) 

lbs/Kwh for (4) cold runs

• Average energy factor = 

(3.22) lbs/Kwh for (8) hot runs

• There is a (5.9) percent 

difference between “cold runs 

and hot runs

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-4

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Condensing Dryer Energy 

Results (continued)

Previous Data

• (4) unit tested

• Average energy factor = (3.04) 

lbs/Kwh for (4) cold runs

• Average energy factor = 

(3.22) lbs/Kwh for (8) hot runs

• A (5.9) percent difference 

between cold & hot runs

New Data

• (1) unit tested

• Average energy factor = (3.15) 

lbs/Kwh for (3) cold runs

• Average energy factor = (3.32) 

lbs/Kwh for (3) hot runs

• A (5.4) percent difference 

between cold & hot runs

• Average energy factor = (3.24) 

lbs/Kwh for (3) preconditioned runs with “Air” 

cycle 

• A (2.9) percent difference 

between cold & Preconditioned runs

Whirlpool model AWZ9995 with additional runs, 

see previous slide for model detail

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Temperature Results

• The Eurotech Condensing Dryer, model # 

EDC158, was thermocoupled in (5) locations

• TC#1 - Ambient air OUT of the Condenser system

• TC#2 - Ambient air INTO the Condenser system

• TC #3 - Drum inlet air after the Condenser but before the 

Heater Element

• TC #4 - Drum inlet air coming from the Heater Element 

• TC #5 - Drum outlet air leaving the Drum

• See next slide for graphical view of the 

Condensing system

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-5

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Thermocouple Locations

Condenser

(Heat Exchanger)

= Blower Fan

Ambient Air In

(cold)

Ambient Air Out

(Hot)

Heater

Element

Drum

= Thermocouple 

location

TC#2

TC#1

TC#5

TC#4

TC#3

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Temperature Data

Eurotech - Cotton Delicate Cycle

Eurotech EDC158 Condensing Dryer

Cotton Delicate Cycle

0

10

20

30

40

50

60

70

80

90

100

110

120

130

140

150

0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85

Time (minutes) Temperature (Degrees F)

Condenser, Outlet Condenser, Inlet Drum, Condenser to Element Drum, Inlet Drum, Outlet

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-6

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Temperature Data

Whirlpool - Air Cycle

Whirlpool ADZ9995 Condensing Dryer

Air Cycle after Energy Test

0

20

40

60

80

100

120

140

0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90

Time (minutes) Temperature (degrees F)

Condensing Air Outlet Condensing Air Inlet Outlet - Inlet

End of Energy Test

(15) minutes

(11) Degree differential after (15) minutes

(80) degrees F

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Preliminary Summary

• Condensing Dryer models are sold both with 

and without “Air” Cycles 

• For a condensing Dryer model with an “Air” 

cycle, the current procedure is potentially valid if 

the condensing air system is considered the 

exhaust

• What should be done with condensing Dryers 

with NO “Air” cycle?

• European Energy Standards may address this 

condensing Dryer pre-conditioning issue and 

address other condensing Dryer test procedure 

differences between exhausted Dryers

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-7

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Other Potential Resources to 

Consider? 

• European Energy Standards may address 

the condensing Dryer pre-conditioning 

issue and other condensing Dryer test 

procedure differences between exhausted 

Dryers

• EN 61121:2005 is the latest standard for 

Dryer Energy in Europe

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EN 61121:2005 Related to 

Condensing Dryers

• Section 6.1 “General” states: 

– “ The measurements shall be carried out on a tumble 

Dryer installed and used in accordance with the 

manufacturer’s instructions, except as required by this 

standard”

– “ Where the tumble Dryer is intended for use without 

a duct (i.e. the tumble Dryer is intended to be vented 

into the room) the tumble Dryer shall be tested as 

supplied without a duct” 

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-8

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EN 61121:2005 Related to 

Condensing Dryers (continued)

• Section 6.2.3 “Resources and Ambient 

Conditions - Ambient Temperature” states:

– “The ambient temperature of the room in the 

vicinity of the Dryer shall be maintained t (23 

2) C throughout the test. The measured 

ambient temperature shall be recorded. Note: 

this can be done by leaving the machine at 

ambient conditions for at least (12) hours”

– (23) C = (73.4) F (3.6) F 

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EN 61121:2005 Related to 

Condensing Dryers (continued)

• Section 9.1 “Performance Tests - General” 

states:

– “Tumble Dryers shall be configured with or 

without a duct as specified in section 6.1.”

– “ All tests shall be started with the tumble 

Dryer at ambient temperature according to 

6.2.3.”

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-9

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EN 61121:2005 Related to 

Condensing Dryers (continued)

• Section 9.2.1 “Procedure for drying performance –

Drying Tests General” states:

– “For automatic tumble Dryers, those programmes are selected 

which aim to achieve the final moisture values given in table 3.”

– “Table 3: Dry cotton has a nominal final moisture content (0) 

percent with an allowable range for final moisture content of (-3) 

to (+3) percent.”

– “The minimum number of valid cycles shall be five. The reported 

results of the valid cycles are used for further evaluation 

according to clause 10. If the Dryer is automatically stopped 

during a cycle and the reason is that the condensation box is full 

of water, the fact is reported and the test is stopped.”

– “Note: If the manufacturer gives the option to use a condensing 

tumble Dryer both with or without condensation box, the Dryer 

should be tested with the condensation box.” 

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EN 61121:2005 Related to 

Condensing Dryers (continued)

• Section 9.2.2 “Procedure for drying performance –

Condensation Efficiency” states:

– “The condensation efficiency for a condenser tumble Dryer, shall 

be measured using the Dry Cotton programme and setting 

selected to achieve the “dry cotton” result (this means the 

equivalent timer setting for a timer Dryer) in the drying test.”

– “The mass of the test load is measured immediately before and 

after the cycle. The mass of the moisture condensed during the 

cycle and collected in the container is determined. The first 

cycle after a period of non-operation longer than (36) hours shall 

not be used for evaluation.”

– “During the time between two cycles, the door of the tumble 

Dryer shall be closed except for loading”

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-10

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EN 61121:2005 Related to 

Condensing Dryers (continued)

• Section 10.5 “Evaluation and Calculation –

Condensation Efficiency” states:

– “Efficiency of condensation, C, is determined 

according to 9.2.2 as the ratio between the water 

produced during the cycle Ww, relative to the total 

mass of water evaporated from the load”

– “ C = Ww /( Wi – Wf) is calculated for each cycle and 

expressed as percentage”

– “Efficiency of condensation is the mean value of a 

minimum of four valid cycles. Note: Due to this 

requirement the first run of a condensation efficiency 

test has normally to be discarded ”

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Whirlpool’s Condensing 

Dryer Test Procedure 

Proposal to DOE

Changes to

Appendix D to Subpart B of Part 

430, Title 10

Clothes Dryer Energy Standard

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-11

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Whirlpool’s Condensing Dryer 

Proposal to DOE

• Section 1 must incorporate definitions of an exhausted Dryer, nonexhausted Dryer, and a condensing Dryer

– An exhausted Dryer has a blower system which is intended to deliver the heated, 

moist air from the Drum cavity into a duct system external to the Dryer and this 

duct system is exhausted into the outdoors.

– A non-exhausted Dryer is intended to be used without an external duct system 

and has no provision to connect to such a duct system. 

– A condensing Dryer is a non-exhausted tumble Dryer in which the air used for 

the drying process is dehumidified by using room ambient air for cooling. The 

blower system used for circulating room ambient air is independent of the heated 

moist air from the Drum cavity.

• Paragraph 2.1 of Section 2 must be updated to include non-exhausted 

Dryers

– Where the tumble Dryer is defined as a non-exhausted Dryer and is intended for 

use without a duct. The tumble Dryer shall be tested as supplied without a duct.

– Where the tumble Dryer is defined as an exhausted Dryer and is intended for use 

with a duct The Dryer exhaust shall be restricted by adding the AHAM exhaust 

simulator described in 3.3.5 of HDL-1................

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Whirlpool’s Condensing Dryer 

Proposal for DOE (continued)

• To align with the European energy procedure, 

Paragraph 2.8 of section 2 should incorporate 

the following condensing Dryer pre-conditioning 

cycle

– For condensing Dryers, the Dryer steady state 

temperature must be equal to ambient room 

temperature according to 2.2 before the start of all 

test runs. Note: this can be done by leaving the 

machine at ambient room conditions for at least (12) 

hours between tests but not more than (36) hours 

between tests

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-12

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Whirlpool’s Condensing Dryer 

Proposal to DOE (continued)

• To align with the European energy procedure and for consistency in 

results (per Luise Christmann of Whirlpool Schorndorf), the U.S. 

energy procedure should incorporate the following condensing Dryer 

test procedure steps

– If the manufacturer gives the option to use a condensing tumble Dryer 

both with or without condensation box, the Dryer shall be tested with the 

condensation box

– If the Dryer is automatically stopped during a cycle and the reason is 

that the condensation box is full of water, the test is stopped, and the 

run is invalid

– During the time between two cycles, the door of the tumble Dryer shall 

be closed except for loading

– The first cycle after a period of non-operation longer than (36) hours 

shall not be used for evaluation

– Results from the first test run on an unused (dry) condensing Dryer are 

invalid and cannot be used for the energy efficiency calculations

– The Condenser unit of the Dryer must remain in place and not be taken 

out of the Dryer for any reason between tests.

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-13

5-B.3 AHAM DE-IDENTIFIED CLOTHES DRYER DATA – COLLECTED 

DECEMBER 2007 FOR DOE RULEMAKING 

 AHAM supplied shipments, market share efficiency data, and data on the effects of 

remaining moisture content (RMC) on residential clothes dryer energy factor, representing the 

aggregated inputs from manufacturers which produce the significant majority of residential 

clothes dryers. Table 5-B.3.1 through Table 5-B.3.3 reproduces the tables of clothes dryer data 

submitted to DOE by AHAM. 

Table 5-B.3.1 Residential Clothes Dryer Shipments (in Thousands of Units) 

Year

Clothes Dryers

Electric Standard 

Electric

Compact 

Electric Gas Total

2006 6,360 6,246 114 1,614 7,974

2005 6,408 6,330 78 1,707 8,115

2004 6,262 6,159 103 1,660 7,922

2003 5,718 5,622 96 1,616 7,334

2002 5,402 1,490 6,892

2001 5,117 1,384 6,501

2000 5,095 1,480 6,575

1999 4,865 1,444 6,309

1998 4,482 1,307 5,789

1997 4,115 1,195 5,310

1996 3,947 1,193 5,140

1995 3,823 1,169 4,992

1994 3,838 1,239 5,077

1993 3,674 1,156 4,830

* Original version of Table 5-B.3.1 was sent on April 11, 2008, but was revised on Aug. 20, 2008 (shown above). 

** AHAM Note: Compact Electric shipments are not available prior to 2003. Standard electric shipments are 

determined from the difference in overall electric shipments and compact electric shipments. 

Table 5-B.3.2 Residential Clothes Dryer Market Share Efficiency Data 

Vented Electric Standard Vented Gas

EF Range, 

lb/kWh

Market Share 

for 2005 (%)

Market Share 

for 2006 (%)

EF Range, 

lb/kWh

Market Share 

for 2005 (%)

Market Share 

for 2006 (%)

3.01-3.09 26 33 2.67-2.74 25 28

3.10-3.29 74 67 2.75-2.84 42 44

3.20-3.29 >2.85 32 27

>3.29

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-14

Table 5-B.3.3 Effect of RMC on Residential Clothes Dryer Energy Factor 

RMC into Dryer 

(%) Baseline 

Test Target Actual Model

1

70

70 3.1

2 70.08 3.08

3 70.08 2.99

4 70.24 3.11

5 70.33 3.08

6 70.17 3.07

7 69.7 3.07

8 71.6 3.27

9 70.5 3.03

10 70.9 3.13

11 70 3.04

12

56

56 3.77

13 55.99 3.73

14 55.99 3.85

15 55.99 3.74

16 58.43 3.73

17 58.58 3.8

18 58.58 3.82

19 55.4 3.8

20 55.8 3.78

21 55.7 3.83

22 56 3.59

Target RMC into Dryer 70 56 

Average RMC into Dryer 70.3 56.6 

Average EF 3.09 3.77 

Standard Deviation 0.07 0.07 

Percent EF Change 22% 

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-15

5-B.4 DOE RESIDENTIAL CLOTHES DRYER ENGINEERING ANALYSIS 

DATA REQUESTS – AHAM DATA SUBMITTAL 

 AHAM supplied shipments, average energy and water use, and incremental cost data to 

DOE, representing the aggregated inputs from manufacturers which produce the significant 

majority of residential clothes dryers. Table 5-B.4.1 through Table 5-B.4.4 reproduces the tables 

of residential clothes dryer data submitted to DOE by AHAM in response to DOE’s engineering 

analysis data request (See appendix 5A). 

Table 5-B.4.1 Residential Clothes Dryer Shipment and Shipment-Weight Average 

Efficiency Data 

Year

Shipments, Domestic + Imports

(Thousands of Units)

Shipment-Weighted Average Efficiency

(EF, cycles/kWh)

Vented Vent-less Vented

Electric

Gas

Electric Electric

Gas

All 

Electric Standard

All 

Compact

Compact 

240 V Combo Standard

Compact 

120 V

Compact 

240 V

1993 3,674 1,156

1994 3,838 1,239

1995 3,823 1,169

1996 3,947 1,193

1997 4,115 1,195

1998 4,482 1,307

1999 4,865 1,444

2000 5,095 1,480

2001 5,117 1,384

2002 5,402 1,490

2003 5,718 5,622 96 1,616

2004 6,262 6,159 103 1,660

2005 6,408 6,330 78 1,707 3.10 2.70

2006 6,360 6,246 114 1,614 3.10 2.70

Comments to Table 5-B.4.1 from AHAM:

1. Shipments are from AHAM Fact Book. AHAM only collects shipment data on Standard 

Electric and Standard Gas vented residential clothes dryers. These are shown as All 

Electric and Gas. 

2. Members provided information on compact shipments, but this is a small market and 

aggregated data for both compact classes is not available. Therefore, compact shipments 

include shipments of both 120V and 240V vented residential dryers after 2003. These 

values are slightly different than those provided in August 2008, as I had not incorporated 

both classes into the total. 

3. The Standard column shows the difference between the aggregated member-supplied 

compact shipments (120V and 240V) and the All Electric published in the AHAM Fact 

Book. The source of and breakdown of the shipment information is slightly different, but 

we believe it is consistent. 

4. Aggregated shipment weighted average efficiencies are only available for 2005 and 2006 

for Standard Electric and Gas dryers. We did not receive enough input to provide data for 

years earlier than 2005 or for compact vented units. 

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-16

Table 5-B.4.2 Residential Clothes Dryer Market Share Efficiency Data: Vented Electric 

Standard 

Vented Electric Standard Vented Gas

EF Range, 

lb/kWh

Market Share 

for 2005 (%)

Market Share 

for 2006 (%)

EF Range, 

lb/kWh

Market Share 

for 2005 (%)

Market Share 

for 2006 (%)

3.01-3.09 

(Baseline = 3.01) 26 33 2.67-2.74 (Baseline = 2.67) 25 28

3.10-3.29 74 67 2.75-2.84 42 44

3.20-3.29 >2.85 32 27

>3.29

* AHAM Note: Total Market Share percentages should equal 100%. 

Comments to Table 5-B.4.2 from AHAM:

1. To maintain confidentiality, market share between EF of 3.20 and 3.29 have been 

incorporated into the EF range between 3.10 and 3.19. 

2. To maintain confidentiality, market share for EF > 2.94 have been incorporated into EF 

> 2.85. 

3. We were not able to obtain sufficient data for Vented compact 120V and 240V. 

4. We have provided data for both 2005 and 2006. 

5. Values have not changed from original submission. 

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-17

Table 5-B.4.3 Residential Clothes Dryer Manufacturer Cost Data: Vented Electric Standard and Electric Compact 120V 

Product Class  Vented Electric Standard Vented Electric Compact 120V

Efficiency Level 1 2 3 1 2 3

EF (lb/KWh) 3.10 3.16 3.39 - - 3.79

Design Options

Average Incremental Costs ($ Per Unit)

Material 9 42 140

Labor 2 11 45

Overhead# 2 4 12

Minimum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Maximum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Conversion Capital Expenditures ($, Millions)

Building CAPX 0.25 9.02 50.18

Tooling/ Equipment CAPX 5.25 37.68 118.93

One-Time Product Conversion Expenses ($, Millions)

R&D 3.62 15.87 58.97

Marketing

+Manufacturer respondents should suggest the design option or design option combinations that they believe should be associated with each efficiency level. 

++ DOE was unable to obtain data for any clothes dryers with efficiencies between the standard level of EF = 3.13 and the max available level of EF = 3.79. Therefore, manufacturer respondents should 

suggest representative intermediate efficiency levels. 

# Depreciation on the conversion capital expenditure should NOT be included in the incremental overhead. 

* Incremental costs per unit should be reported relative to the baseline unit’s cost. The baseline unit complies with the current federal standard for residential clothes dryers. 

Comments on Table 5-B.4.3 from AHAM:

1. Shaded cells indicate that AHAM did not receive enough input to aggregate incremental cost data. No data are available for 

vented electric compact 120V, minimum/maximum incremental costs or marketing expenses. 

2. Values are shipment weighted. 

3. AHAM members provided the incremental cost to obtain the requested EF. To determine these costs, design options would 

have been considered, but these were not shared with AHAM. AHAM recommends that DOE talk to manufacturers 

individually to further understand the design options available for reaching these efficiency targets. 

EERE-2007-BT-STD-0010 COMMENT 20.3
5-B-18

Table 5-B.4.4 Residential Clothes Dryer Manufacturer Cost Data: Vented Electric Compact 240V and Gas 

Product Class  Vented Electric Compact 240 V Vented Gas

Efficiency Level 1 2 3 1 2 3

EF (lb/KWh) 2.98 3.09 3.2 2.75 2.85 3.44

Design Options

Average Incremental Costs ($ Per Unit)*

Material 20 60 81

Labor 2 6 32

Overhead# 2 4 12

Minimum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Maximum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Conversion Capital Expenditures ($, Millions)

Building CAPX 0.46 29.83

Tooling/ Equipment CAPX 2.62 37.24 16.15

One-Time Product Conversion Expenses ($, Millions)

R&D 2.99 15.46 12.91

Marketing

# Depreciation on the conversion capital expenditure should NOT be included in the incremental overhead. 

* Incremental costs per unit should be reported relative to the baseline unit’s cost. The baseline unit complies with the current federal standard for residential clothes dryers. The Average Incremental 

Cost should be reported as a shipment weighted average value. The Minimum and Maximum Incremental Costs presumably reflect the costs associated with changes to different product platforms. 

Other Information: 

1. What depreciation method would your company use to depreciate the conversion capital expenditures? _______________________________________________. 

Direct material – Costs of raw materials including scrap that can be traced to final or end products. Direct material costs do not include indirect material costs which are attributed to supplies that may 

be used in the production process but are not assigned to final products (e.g., lubricating oil for production machinery). 

Direct labor – The earnings of workers who assemble parts into a finished good for operate machines in the production process. Direct labor includes the fringe benefits of direct laborers such as group 

health care, as well as overtime pay. Direct labor does not include indirect labor which is defined as the earnings of employees who do not work directly in assembling a product, such as supervisors, 

janitors, stockroom personnel, inspectors, and forklift operators. 

Overhead – Factory overhead excluding depreciation. Factory overhead includes indirect labor, downtime, set-up costs, indirect material, expendable tools, maintenance, property taxes, insurance on 

assets, and utility costs. Factory overhead does not include selling, general, and administrative costs (SG&A); research and development (R&D); interest; or profit (accounted for by DOE separately). 

Full Production Cost = Direct Material + Direct Labor + Overhead (factory) + Depreciation 

Full Cost of Product = Full Production Cost + Non-production Costs (SG&A, R&D, interest, and profit)

EERE-2007-BT-STD-0010 COMMENT 20.3
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Comments on Table 5-B.4.4 from AHAM:

1. Shaded cells indicate that AHAM did not receive enough input to aggregate incremental 

cost data. No data are available for vented electric compact 240V, minimum/maximum 

incremental costs or marketing expenses or Building CAPX for EF 3.02 vented gas. 

2. Values are shipment weighted. 

3. AHAM members provided the incremental cost to obtain the requested EF. To determine 

these costs, design options would have been considered, but these were not shared with 

AHAM. AHAM recommends that DOE talk to manufacturers individually to further 

understand the design options available for reaching these efficiency targets. 

4. One respondent stated that design options were not available to reach an EF of 3.02 on 

vented gas dryers, therefore, no incremental cost data were provided. Values shown are 

calculated without this respondent – but weighted basis is different. While all members 

use straight-line depreciation, AHAM was not able to obtain a consistent response on the 

years used in the calculation. 

EERE-2007-BT-STD-0010 COMMENT 20.3
5B-20

5-B.5 DOE ROOM AIR CONDITIONER ENGINEERING ANALYSIS DATA 

REQUESTS – AHAM DATA SUBMITTAL 

 AHAM supplied market share data, shipment-weighted efficiency data, and market share 

efficiency data to DOE, representing the aggregated inputs from manufacturers which produce 

the significant majority room air conditioners. Figure 5-B.5.1 through Figure 5-B.5.2 reproduces 

Table A2-1 through Table A2-6 of the room air conditioner data submitted to DOE by AHAM in 

response to DOE’s engineering analysis data request (See appendix 5A). 

EERE-2007-BT-STD-0010 COMMENT 20.3
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Figure 5-B.5.1 AHAM Room Air Conditioner Market Share, Shipment-Weight Efficiency Data, Market Share Efficiency Data 

Submittal 

Figure 5-B.5.2 AHAM Room Air Conditioner Market Share Efficiency Data Submittal 

EERE-2007-BT-STD-0010 COMMENT 20.3
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EERE-2007-BT-STD-0010 COMMENT 20.3
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Comments on Figure 5-B.5.1 and Figure 5-B.5.2 from AHAM:

Comments on Table A2-1: 

1. Shipment data by product class is not available prior to 2005. Only overall shipments of 

room air conditioners are available. 

2. Shipments for units without reverse cycle and without louvered sides were combined, as 

there were not sufficient data for each capacity range to maintain confidentiality. 

3. Shipments for units with RC and without LS are combined, as are shipments for units 

with RC and with LS in 2006, as there were not sufficient data for each capacity range to 

report and maintain confidentiality. 

4. No data can be provided for with RC and with/without LS in 2007. 

Comments on Table A2-2: 

1. As noted above, shipment data by product class is not available prior to 2005; therefore, 

no shipment-weighted EER information can be provided for these years. 

2. A double asterisk (**) indicates that AHAM cannot provide data for these capacity 

ranges and or product classes since there is not enough data. 

Comments on Tables A2-3 through A2-5: 

1. In several cases, efficiency bins were combined to provide as much information as 

possible, while maintaining confidentiality. 

2. When efficiency bins could not be combined, no data are provided. This is indicated by a 

double asterisk (**). 

Additional Comments from AHAM on Tables A2-7 through A2-10 in DOE’s Engineering 

Analysis Data Request: 

Comments on Tables A2-7 through A2-8: 

AHAM was not able to obtain room air conditioner incremental cost data from members 

for aggregation. In addition, many of our members purchase and sell their brands through OEMs, 

and do not have access to this type of cost information. 

Comments on Table A2-9: 

While AHAM collected data on Portable Air Conditioner shipments, we do not feel our 

information is representative of actual shipments. We are currently assuming that PAC 

shipments are roughly 10 percent of RAC shipments. Shipment values received were 

substantially lower than this estimate. We will begin collecting PAC shipment data in 2009. 

EERE-2007-BT-STD-0010 COMMENT 20.3
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Comments on Table A2-10: 

AHAM does not feel it is appropriate to provide capacity values for Portable Air 

Conditioners at this time. There is not currently a standard that measures “true” PAC capacity –

as the procedures currently being used for testing are not designed for small, residential units. 

AHAM has developed a Portable Air Conditioner standard (AHAM PAC-1), which is in its final 

stages of approval. In January 2009, AHAM will commence a PAC certification program, in 

which capacities will be reported and verified for both single and dual ducted units. These data 

will be available on a public website. 

EERE-2007-BT-STD-0010 COMMENT 20.3
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5-B.6 DOE DATA REQUESTS FOR RESIDENTIAL CLOTHES DRYERS AND 

ROOM AIR CONDITIONERS – AHAM DATA SUBMITTAL 01/09/2009 

 AHAM submitted the following data and responses to DOE on Jan. 9, 2009 in response 

to DOE’s data request (See appendix 5A).

Data Requests for Standards Rulemaking for Residential Clothes 

Dryers and Room Air-Conditioners – 01/09/2009 

Clothes Dryers 

1. Shipment-weighted average remaining moisture content (RMC) over time for residential 

clothes washers for top-loading units, front-loading units, and combined. 

The file attached below [reproduced in Table 5-B.6.1] summarizes total shipments for 

front-loading and top-loading units from 2002 through 2008. Shipment-weighted RMC 

values are also shown for the front-load and top-load configurations. Note that the total 

shipments shown in this table were the shipments used to calculate the weighted RMC 

values. These shipments will be lower than those typically reported, as members did not 

provide RMC values for all units. 

Table 5-B.6.1 AHAM Weighted RMC for Front-Load and Top-Load Clothes Washer Units, 2000-2008 

Year

Clothes Washer Shipments for Which 

RMC was Reported Shipment-Weighted RMC (%)

FrontLoadingTopLoading Total FrontLoadingTopLoading Overall

2000 232,714 686,440 919,154 43.6 57.4 53.9

2001 235,989 473,629 709,618 41.3 57.7 52.2

2002 280,667 529,265 809,932 41.5 58.1 52.3

2003 351,411 1,676,877 2,028,288 43.1 54.5 52.5

2004 1,179,813 5,270,285 6,450,098 42.2 52.8 50.9

2005 1,563,108 5,394,511 6,957,619 40.8 52.7 50.1

2006 1,851,218 15,528,279 17,379,497 39.3 51.8 50.5

2007 1,973,825 15,271,142 17,244,967 38.3 51.8 50.2

2008 2,043,024 4,492,059 6,535,083 38.1 51.0 47.0

* Original version of Table 5-B.6.1 was sent on Jan. 9, 2009, but was revised on July 7, 2009 (shown above). 

2. Data regarding consumer usage patterns for residential clothes dryers- the # of annual use 

cycles. Preferably the number of dryer use cycles independent of wash cycles. If not, then 

the percent of loads washed that are machine dried. 

AHAM does not collect data on patterns of residential clothes dryer use. Confidential 

industry data suggests that DOE’s proposed value of 329 cycles per year is more 

representative than the current 416 cycles per year, but still on the high end. While dated, 

1997 information from Natural Resources Canada (NRCan) on winter dryer use (5.8 

EERE-2007-BT-STD-0010 COMMENT 20.3
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loads per week; 302 cycles per year) is a realistic value for the United States.

(http://www.oee.nrcan.gc.ca/publications/infosource/pub/energy_use/sheu_e/sheu_5.cfm)

. 

3. Has AHAM made any progress on the development of a clothes dryer test procedure 

which tests dryer operation using automatic termination? 

AHAM HLD-1 is currently undergoing revision. We expect the standard to be finalized 

in 2nd quarter 2009. The revised standard addresses automatic termination by terminating 

the test immediately prior to the start of the cool down period. Timer-dryers are set to a 

specific time. Heat and total energy are both measured.

4. Is AHAM developing test methodology for condensing dryers? 

AHAM is not currently developing a test methodology for condensing dryers. There is an 

IEC standard for this technology; however, we expect that it would need to be modified 

for use in the U.S. (effect on HVAC is one area of concern). 

Room Air Conditioners 

1. Data regarding consumer usage patterns – room air-conditioner annual hours of 

operation. 

AHAM does not collect data on consumer usage patterns of room air conditioners or 

hours of operation. 

EERE-2007-BT-STD-0010 COMMENT 20.3