1 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Test Procedures for Dishwashers, Dehumidifiers, and Conventional Cooking Products

Notice of Proposed Rulemaking Public Meeting

Wes AndersDepartment of EnergyEnergy Efficiency & REmail: wes.anderson

December 17, 2010
2 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• NOPR issued by DOE on December 2, 2010• NOPR Public Meeting today, December 17, 2010• Comments on NOPR from interested parties

– Transcript records oral comments from today’s public mee– Written comments (comment period closes 75 days after p

in the Federal Register)

• DOE reviews and considers all comments• Final Rule Publication

Steps in the Test Procedure Rulemaking

Introduction

NOPR
3 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First 

for Measuring Standby Mode and Off Mode Power Consu

3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements f

Standby Mode and Off Mode Testing

5. Calculation of Energy Use Associated with Standby Mod

Mode

6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide an

ENERGY STAR

Test Procedure Overview and Issues

Introduction
4 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• This test procedure rulemaking covers the following appe

10 CFR part 430, subpart B:

– Appendix C – Uniform Test Method for Measuring the Ene

Consumption of Dishwashers;

– Appendix I – Uniform Test Method for Measuring the Ene

Consumption of Conventional Ranges, Conventional CooConventional Ovens, and Microwave Ovens; and

– Appendix X – Uniform Test Method for measuring the Ene

Consumption of Dehumidifiers.

• The Energy Independence and Security Act of 2007 (EISA 

amendments to EPCA direct DOE to amend its test procedishwashers, dehumidifiers, and conventional cooking printegrate measures of standby and off mode energy consno later than March 31, 2011.

Regulatory Background

Introduction
5 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Test Procedure Overview and Issues

1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First 

for Measuring Standby Mode and Off Mode Power Consu

3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements f

Standby Mode and Off Mode Testing

5. Calculation of Energy Use Associated with Standby Mod

Mode

6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide an

ENERGY STAR
6 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• 10 CFR part 430.2 provides the following product definitio

– Dishwasher means a cabinet-like appliance which with the 

water and detergent, washes, rinses, and dries (when a dprocess is included) dishware, glassware, eating utensils, cooking utensils by chemical, mechanical and/or electricadischarges to the plumbing drainage system.

– Dehumidifier means a self-contained, electrically operated

mechanically refrigerated encased assembly consisting of 

1. A refrigerated surface (evaporator) that condenses moistur

atmosphere;

2. A refrigerating system, including an electric motor;3. An air-circulating fan; and4. Means for collecting or disposing of the condensate.

Products Covered by this Test Procedure Rulem

Covered Products
7 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• 10 CFR part 430.2 provides the following product definitio

– Cooking products means consumer products that are use

major household cooking appliances. They are designed theat different types of food by one or more of the following heat: gas, electricity, or microwave energy. Each product of a horizontal cooking top containing one or more surface and/or one or more heating compartments. They must be following classes: conventional ranges, conventional cookconventional ovens, microwave ovens, microwave/convenranges and other cooking products.

– Conventional cooking top means a class of kitchen ranges 

which is a household cooking appliance consisting of a hosurface containing one or more surface units which includgas flame or electric resistance heating.

Products Covered by this Test Procedure Rulem

Covered Products
8 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• 10 CFR part 430.2 provides the following product definitio

– Conventional oven means a class of kitchen ranges and o

is a household cooking appliance consisting of one or mocompartments intended for the cooking or heating of food of either a gas flame or electric resistance heating. It does portable or countertop ovens which use electric resistance the cooking or heating of food and are designed for an elesupply of approximately 120 volts.

– Conventional range means a class of kitchen ranges and 

which is a household cooking appliance consisting of a cocooking top and one or more conventional ovens.

• DOE is not proposing any amendments to these product 

Products Covered by this Test Procedure Rulem

Covered Products
9 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Test Procedure Overview and Issues

1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First 

for Measuring Standby Mode and Off Mode Power Consu

3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements f

Standby Mode and Off Mode Testing

5. Calculation of Energy Use Associated with Standby Mod

Mode

6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide an

ENERGY STAR
10 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• EISA 2007 amended EPCA to require test procedure amen

regarding standby and off mode power to take into considthe most current versions of IEC Standards 62301 and 62

– IEC Standard 62087 is not applicable to this rulemaking.

• DOE proposes to incorporate into the test procedure all a

provisions from Sections 4 and 5 of IEC Standard 62301 FEdition, as shown in the table below.

IEC Standard 62301 and IEC Standard 6208

Incorporating IEC Standard 62301

Section Paragraph

4. General conditions for measurements

4.2 Test room4.4 Supply voltage waveform4.5 Power measurement accuracy

5. Measurements 5.1 General, Note 1

5.2 Selection and preparation of appor equipment5.3 Procedure
11 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE notes that the IEC is developing an updated version of IEC 

62301 (Second Edition).

– Expected to include definitions of “off mode,” “network mode,” an

“disconnected mode,” and would revise the current First Edition d

“standby mode.”

– IEC has not yet published this version of the Standard. Therefor

available for DOE’s consideration or incorporation by reference.

• IEC Standard 62301 First Edition is the “current version” for purp

EISA 2007 amendments to EPCA.

• However, DOE has reviewed the two most recent draft versions o

Second Edition: (1) the Committee Draft for Vote (IEC Standard 6and (2) the subsequent Final Draft International Standard (IEC St62301 FDIS).

– DOE anticipates that the Second Edition will include updated mo

similar to those included in IEC Standard 62301 FDIS, and therefconsidered IEC Standard 62301 FDIS for mode definitions.

IEC Standard 62301

Incorporating IEC Standard 62301
12 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE notes the current dishwasher test procedure already 

test methods for standby power consumption that are verto the provisions in IEC Standard 62301 First Edition.

– However, these provisions do not account for multiple sta

or an off mode.

– DOE is proposing to amend the dishwasher test procedur

new definitions of standby, off, and inactive mode based oprovisions in IEC Standard 62301 FDIS, as well as the idetesting clauses from IEC Standard 62301 First Edition.

• DOE is also aware that the cooking product test procedur

for the annual energy consumption of a continuously opeclock, but no other standby mode or off mode energy con

– Therefore, DOE is proposing to adopt the clauses from IE

62301 that would fully account for standby mode and off menergy consumption in conventional cooking products.

IEC Standard 62301 – Dishwashers and 

Conventional Cooking Products

Incorporating IEC Standard 62301
13 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Request for Comment on Incorporating IEC Standa

Incorporating IEC Standard 62301

Item 1 DOE seeks comment on the adequacy of IEC Standa

to measure standby and off mode power consumption for disdehumidifiers, and conventional cooking products, and on thof incorporating the specified provisions into DOE regulations
14 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Test Procedure Overview and Issues

1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First 

for Measuring Standby Mode and Off Mode Power Consu

3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements f

Standby Mode and Off Mode Testing

5. Calculation of Energy Use Associated with Standby Mod

Mode

6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide an

ENERGY STAR
15 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• The mode definitions provided in EPCA and in IEC Standa

First Edition could lead to multiple interpretations.

– These definitions were developed to be broadly applicabl

many energy-using products.

• EPCA authorizes DOE to amend mode definitions, consid

most current versions of IEC Standards 62301 and 62087.

• DOE expects the definitions provided in IEC Standard 623

to remain relatively unchanged in the final revised IEC Sta62301, Second Edition, and therefore considered these deas the most current when determining the mode definitionamended test procedure.

– DOE is proposing mode definitions based on the definitio

provided in IEC Standard 62301 FDIS, with added clarificspecific to dishwashers, dehumidifiers, and conventional products.

Determination and Classification of Operational 

Modes to Be Incorporated
16 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is proposing to define active mode as:

– the condition in which the energy-using product is connec

mains power source, has been activated, and provides onmain functions.

• DOE notes that IEC Standard 62301 Second Edition Comm

Draft 2 (IEC Standard 62301 CD2) provides the additional clarification that “delay start mode is a one off user initiatduration function that is associated with an active mode.”

– However, IEC 62301 FDIS does not include this note, and 

delay start as a secondary function that is not a part of ac

• DOE continues to believe that because delay start is of lim

duration and is uniquely associated with the initiation of a function, it should be considered part of active mode.

– Additional discussion of delay start is provided later.

Definitions of Modes – Active

Modes to Be Incorporated
17 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is also proposing that the following main functions b

classified as active mode for each product:

– Dishwashers – Active mode means a mode in which the 

dishwasher is performing the main function of washing, rindrying (when a drying process is included) dishware, glaseating utensils, and most cooking utensils by chemical, mand/or electrical means, or is involved in functions necessthese main functions, such as admitting water into the disor pumping water out of the dishwasher.

Definitions of Modes – Active

Modes to Be Incorporated
18 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is also proposing that the following main functions b

classified as active mode for each product:

– Conventional Cooking Products – Active mode means a m

which a conventional cooking top, conventional oven, or conventional range is performing the main function of cooheating, proofing, or holding the cooking load by means ogas flame or electric resistance heating.

– Dehumidifiers – Active mode means a mode in which a 

dehumidifier is performing the main functions of removing from ambient air by drawing moist air over a refrigerated ca fan, circulating air through activation of the fan without aof the refrigeration system, or defrosting the refrigerant co

Definitions of Modes – Active

Modes to Be Incorporated
19 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is proposing to define standby mode as:

– any mode in which the product is connected to a mains po

source and offers one or more of the following user-orientprotective functions which may persist for an indefinite tim

• To facilitate the activation of other modes (including activatio

deactivation of active mode) by remote switch (including rem

control), internal sensor, or timer;

• Continuous functions, including information or status displays 

(including clocks), or sensor-based functions.

– A timer is a continuous clock function (which may or may 

associated with a display) that provides regular scheduled (e.g., switching) and that operates on a continuous basis.

Definitions of Modes – Standby

Modes to Be Incorporated
20 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• This differs from the current definition of standby mode in 

dishwasher test procedure, based on IEC 62301 (First Edi

– DOE proposes to redefine this mode as “simplified standb

for continued use until amended conservation standards teffect.

• DOE notes that the proposed definition of standby mode 

for multiple modes to be considered standby.

• DOE is proposing to define “inactive mode” for dishwash

dehumidifiers, and conventional cooking products as a stmode that facilitates the activation of active mode by remswitch (including remote control), internal sensor, or timeprovides continuous status display.

Definitions of Modes – Standby, Inactive

Modes to Be Incorporated
21 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is proposing to define off mode as:

– A mode in which the product is connected to a mains pow

and is not providing any active mode or standby mode funwhere the mode may persist for an indefinite time.

– An indicator that shows the user only that the product is in 

position is included within the classification of off mode.

• A product equipped with a mechanical on/off switch that 

disconnect power to the display and/or control componenbe considered as operating in the off mode when the switthe “off” position, provided that no other standby or activfunctions are energized.

• DOE believes that active, standby, inactive, and off mode

proposed, are all relevant for dishwashers, dehumidifiersconventional cooking products.

– Product-specific modes are addressed in the following slid

Definitions of Modes – Off

Modes to Be Incorporated
22 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Request for Comment on the Proposed Mode Def

Modes to Be Incorporated

Item 2 DOE welcomes comment on the proposed definitions 

“standby mode,” “off mode,” and “active mode,” which are badefinitions provided in IEC Standard 62301 FDIS.
23 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is aware of two additional relevant modes for dishwa

delay start mode and cycle finished mode.

– Delay start mode is defined as a mode in which activation 

active mode is facilitated by a timer.

– Cycle finished mode is defined as a mode that provides co

status display following operation in active mode.

• Because delay start mode is not a mode that may persist 

indefinite time, DOE believes it would not be considered a standby mode and would be a form of active mode.

– DOE is not proposing amendments to the active mode tes

procedures under this rulemaking.

• Cycle finished mode would be considered a standby mod

the proposed definitions.

Dishwasher Modes

Modes to Be Incorporated
24 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Request for Comment on the Proposed

Dishwasher Mode Definitions

Modes to Be Incorporated

Item 3 DOE invites comment on the proposed establishment mode and cycle finished mode as standby modes for dishwathe determination that “delay start mode” would not be a form mode. DOE further invites comment on whether there are andishwasher modes consistent with the “active mode,” “standbor “off mode” definitions that have not been identified and repsignificant energy use.
25 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is aware of three additional relevant modes for 

dehumidifiers: delay start mode, off-cycle mode, and bucfull/removed mode.

– Delay start mode is defined the same as for dishwashers.– Off-cycle mode is defined as a mode in which a dehumidif

cycled off its main function by humidistat or humidity sensnot have its fan or blower operating, and will reactivate the function according to the humidistat or humidity sensor sig

– Bucket full/removed mode is defined as a mode in which t

dehumidifier has automatically powered off its main functidetecting when the water collection bucket is full or remov

• For the reasons discussed for dishwashers, DOE believes 

delay start mode would be considered a form of active mo

• Off-cycle and bucket full/removed modes both may persis

indefinite time and would be considered a part of standby 

Dehumidifier Modes

Modes to Be Incorporated
26 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Request for Comment on the Proposed

Dehumidifier Mode Definitions

Modes to Be Incorporated

Item 4 DOE invites comment on the proposed establishment mode, off-cycle mode, and bucket full/removed mode as stanmodes for dehumidifiers, and the determination that “delay stwould be considered a form of active mode. DOE further invcomment on whether there are any dehumidifier modes consthe “active mode,” “standby mode,” or “off mode” definitions tnot been identified and represent significant energy use.
27 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is aware of three additional relevant modes for conv

cooking products: delay start mode, cycle finished modeSabbath mode.

– Delay start mode and cycle finished mode definitions are t

as for dishwashers.

– Sabbath mode is defined as a mode in which the automat

is overridden to allow for warming of pre-cooked foods duperiods as the Jewish Sabbath.

• For the reasons discussed for dishwashers, DOE believes 

delay start mode would be considered a form of active mo

• Cycle finished mode would be considered a part of stand• DOE believes the Sabbath mode function of warming food 

be considered part of active mode, and is therefore not pramendments to define or measure energy consumption in mode.

Conventional Cooking Product Modes

Modes to Be Incorporated
28 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Request for Comment on the Proposed

Conventional Cooking Product Mode Definitio

Modes to Be Incorporated

Item 5 DOE invites comment on the proposed establishment mode and cycle finished mode as standby modes for convencooking products, and the determination that “delay start mo“Sabbath mode” would be considered forms of active mode. further invites comment on whether there are any conventionproduct modes consistent with the “active mode,” “standby m“off mode” definitions that have not been identified and represignificant energy use.
29 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• IEC Standard 62301 FDIS defines network mode as:

– “any product modes where the energy using product is co

a mains power source and at least one network function is (such as reactivation via network command or network intcommunication) but where the primary function is not activ

• IEC Standard 62301 FDIS also defines disconnected mode 

– “the status in which all connections to mains power source

energy using product are removed or interrupted.”

• The proposed amendments would not incorporate either 

modes into the covered test procedures.

– DOE is unaware of any dishwashers, dehumidifiers or con

cooking products currently incorporating a networking funappropriate methods for testing energy consumption in thi

– DOE believes that there would be no energy use in a disc

mode, therefore testing in this mode would be irrelevant.

Modes not Included – Network & Disconnect

Modes to Be Incorporated
30 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Request for Comment on Network Mode

Modes to Be Incorporated

Item 6 DOE welcomes comment on whether dishwashers, dehumidifiers, or conventional cooking products are currently that incorporate a networking function, and whether definitiontesting procedures for a network mode should be incorporateDOE test procedures. DOE also requests comment on apptesting methodologies for measuring energy consumption in mode for these products, and data on such testing methodol
31 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Test Procedure Overview and Issues

1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First 

for Measuring Standby Mode and Off Mode Power Consu

3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements f

Standby Mode and Off Mode Testing

5. Calculation of Energy Use Associated with Standby Mod

Mode

6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide an

ENERGY STAR
32 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is proposing test procedures for measuring the pow

consumption of dishwashers, dehumidifiers, and conventcooking products in all standby and off modes.

– These proposed amendments also include provisions for 

measuring energy use in cycle finished mode for dishwasconventional cooking products, and off-cycle and bucket full/removed mode for dehumidifiers.

• The following section discusses provisions DOE propose

include in its test procedures to clarify the IEC Standard 6(First Edition) methods used to measure energy consumpthese modes.

Adding Specifications for Standby Mode and Off Mo

Test Methods and Measurements
33 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• Paragraph 5.3.1 of IEC Standard 62301 contains provision

measuring power.

– If power is stable (varies by not more than 5% from a max

level during a 5 minute period), wait 5 minutes for the prodstabilize, then measure the power at the end of an additioperiod of at least 5 minutes.

– If power is unstable (varies by more than 5% from a maxim

during a 5 minute period), the power measurement shall b5 minutes, or, if there is an operating cycle, one or more coperating cycles of several minutes or hours.

• DOE notes that these provisions do not preclude manufa

from testing products with a longer stabilization period, olonger measurement period if they so choose.

Power Measurement Period

Test Methods and Measurements
34 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is aware that displays on dishwashers and conventio

cooking products may reduce power consumption by dimafter a certain period of user inactivity. 

• For these units, DOE proposes that the standby and off m

tests be conducted after the power level has dropped to ilevel, as discussed in IEC Standard 62301, paragraph 5.1, 

– DOE observed during testing of all three covered products 

typical higher-power state persists for less than 10 minute

inactivity; thus the energy consumption at the low-power lmore representative of actual use.

– It is possible that some products may remain in the higher

state for the duration of the 5-minute stabilization and 5-m

period specified in IEC Standard 62301 (First Edition).

Test Methods and Measurements

Power Measurement Period
35 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• IEC Standard 62301 Committee Draft for Vote (CDV), whic

preceded the FDIS version, updated the First Edition specifications to require a stabilization period of 30 minutto a measurement period not less than 10 minutes.

• IEC Standard 62301 FDIS further revised the test method 

establish an overall test period of not less than 15 minute

– If the mode tested is not cyclic, the first third of the period 

considered a stabilization period, and the remaining two-th

used to determine whether the power is stable. The perioextended continuously until the stability criteria are achievhours.

– Modes that are non-cyclic with varying power follow this s

procedure but with a total test period not less than 60 min

– Cyclic modes use an initial stabilization period of at least 1

minutes, with the power averaged over at least 4 complete 

Test Methods and Measurements

Power Measurement Period
36 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE considered the test methods from the First Edition, C

FDIS versions of IEC Standard 62301.

– DOE has tentatively concluded that the specifications prov

IEC Standard 62301 CDV would lead to the most accuraterepeatable, and enforceable power measurements.

• Additionally, DOE believes these specifications would allo

sufficient time for displays that automatically dim or poweto reach the lower-power state prior to measurement.

– Even if certain products allow for altering the display settin

increase the time period in the high-power state, DOE beltypical consumer will maintain the default settings, and thenot proposing additional provisions to address the possibi

adjusting the default settings.

Test Methods and Measurements

Power Measurement Period
37 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Request for Comment on Default Settings

Item 7 DOE welcomes comment on the suitability of using th

settings in testing standby energy consumption, on any meththat can account for consumer actions that might increase enand data on the repeatability of such testing procedures.

Test Methods and Measurements
38 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is proposing that the test room ambient temperature

standby and off mode testing be specified according to sparagraph 4.2 of IEC Standard 62301: 73.4 °F ± 9 °F. 

– The current DOE active mode test procedures for dishwas

dehumidifiers include ambient temperatures requirements within this range, which would give manufacturers the optconducting standby and off mode tests simultaneously witmode tests, on separate units.

– The test procedures for conventional cooking products req

ambient temperatures of 77 °F ± 9 °F.

• Manufacturers may perform standby and off mode tests simu

with active mode testing in the same room if the ambient temfalls between 68 °F and 82.4 °F.

Test Room Ambient Temperature

Test Methods and Measurements
39 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Request for Comment on Test Room Ambient Tem

Item 8 DOE seeks comment on the appropriateness of the pmodified test room ambient temperature range for dishwashedehumidifiers, and conventional cooking products, which womanufacturers to conduct standby and off mode testing sepaperformance testing under the less stringent ambient conditiospecified in the IEC Standard 62301.

Test Methods and Measurements
40 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• IEC Standard 62301 (First Edition) states that when it is re

by an external standard, the test voltage and frequency dthe external standard shall be used; when the test voltage frequency are not defined in the external standard, 115 V 60 Hertz (Hz) ± 1% should be used.

– The current dehumidifier test procedure specifies that the 

frequency should be used for testing, but does not provide allowable frequency range.

– The current conventional cooking products test procedure 

specify any power supply frequency requirements.

• DOE is proposing to include an allowable frequency rang

for dehumidifiers, and a power supply frequency of 60 Hz conventional cooking products for standby and off mode 

Power Supply Requirements

Test Methods and Measurements
41 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE notes that IEC Standard 62301 does not closely spec

test method when the measured power is not stable.

– “if the power varies over a cycle (i.e., a regular sequence 

states that occur over several minutes or hours), the perioto average power or accumulate energy shall be one or mcomplete cycles in order to get a representative average v

• DOE investigated the possible regular sequences of powe

for conventional cooking products to determine the variapower over a cycle, and an appropriate clarification to IEC 62301.

– DOE tests on 7 conventional cooking products showed th

power consumption can vary by as much as 44 percent baclock display (1:11 display versus 12:08 display).

Unstable Power Measurement Method

Test Methods and Measurements
42 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• As part of the microwave ovens energy conservation stan

rulemaking, DOE investigated three different test methodmeasuring unstable power due to clock displays.

– 12-hour test period (to capture all display values)– 18-point method: measures power consumption of differen

configurations and then estimates the representative 12-hconsumption based on how often each configuration is ushours

– 10-minute method: uses a 10-minute test period with a sta

setting at 3:33.

• DOE believes the distribution of display segments over this 1

period would be comparable to that of a 12-hour test period.

• The following table compares standby test results using t

methods for 11 microwave test units.

Unstable Power Measurement Method

Test Methods and Measurements
43 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE*Standby power measurements are scaled to normalize the supply power 

volts.

**For this test unit, the supply power was significantly different than 120.0 

Therefore, DOE believes the scaling of the measured standby power percentage differences from the 12-hour standby power measuremenvalid for this test unit.

Unstable Power Measurement Method

Test Methods and Measurements

Test 

Unit Display Type

12-Hour 

Method 18-Point Method 10-Minute 

Standby

Watts*

Standby

Watts*

Percent

Difference

Standby

Watts*

1 LCD 1.567 1.552 -0.99% 1.592 2 LCD 1.571 1.560 -0.70% 1.554 3 LCD 1.812 1.812 0.03% 1.801 4 LCD 1.490 1.475 -0.96% 1.492 5 LCD 1.859 1.847 -0.60% 1.874 6 LCD 3.788 3.798 0.26% 3.818 7 LCD 3.641 3.642 0.04% 3.606 8 LED 1.802 1.796 -0.35% 1.797 9 LED 1.825 1.820 -0.25% 1.816 

10 LED 3.185 3.177 -0.27% 3.290 11 VFD 5.600 5.611 0.20% 5.607 
44 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE observed that the 10-minute test period results varie

than 2 percent from the 12-hour period for this sample of 

– Therefore, DOE is proposing a 10-minute measurement p

starting time of 3:33 to measure standby energy use for cocooking products with power consumptions that vary with displayed on the clock. 

• The proposed test procedure would require an initial 10-minu

stabilization period followed by setting the clock to 3:23 to alstabilization period before the 10-minute measurement perio

• DOE believes with this method of measuring standby pow

testing provisions for clock energy consumption currentlcooking products test procedure are no longer necessary

– The 10-minute test period would account for all standby m

mode energy consumption, including clock energy consumwhich would be incorporated into the annual energy consuand EF calculations.

Unstable Power Measurement Method

Test Methods and Measurements
45 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE notes that both the 18-point and 10-minute approach

accelerated standby testing do not exclude the possibility product could be programmed to alter its behavior during test.

– The product could be programmed to dim or alter its displ

the times associated with the 18 measurement points, or bthe display times of 3:33 and 3:42.

• DOE is proposing to provide manufacturers the option of 

conducting either the full 12-hour test, the 10-minute test

– For the purposes of enforcement testing, DOE would rese

right to use either test or both tests.

– DOE also proposes to clarify that the results from the diffe

must be within 2 percent of each other, otherwise DOE withe 12-hour test to determine compliance.

Unstable Power Measurement Method

Test Methods and Measurements
46 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Request for Comment on Test Procedure Waiv

Item 9 DOE seeks comment on whether a method in which ttime on conventional cooking products would be set to 3:23 p10-minute stabilization period, followed by a 10-minute measperiod commencing at 3:33 would be an acceptable alternatimethod that DOE is proposing (i.e., a 10-minute initial stabilizperiod, after which the clock would be set to 3:23 and anotheminute stabilization period provided before a 10-minute measstarting at a clock time of 3:33). DOE also requests commenproposed approach requiring results under the 12-hour test aminute test to be within 2 percent of each other and welcomewhich would show that some other range is more appropriate

Test Methods and Measurements
47 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Test Procedure Overview and Issues

1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First 

for Measuring Standby Mode and Off Mode Power Consu

3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements f

Standby Mode and Off Mode Testing

5. Calculation of Energy Use Associated with Standby Mod

Mode

6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide an

ENERGY STAR
48 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• Energy use for dishwashers is expressed as average ann

energy use and total energy used per dishwasher cycle.

• DOE is proposing to incorporate standby and off mode en

into the calculation of estimated annual energy use as reqthe EISA 2007 amendments to EPCA.

– Therefore, DOE has examined standby and off mode ene

consumption in terms of annual energy use, expressed in year.

• The current DOE test procedure already incorporates a ca

of annual standby energy consumption.

– DOE proposes to maintain the current calculation of active 

hours per year, based on the average wash cycle time mu215 cycles per year, and to distribute the non-active mode between the appropriate standby and off modes.

Calculation of Operating Mode Energy – Dishwa

Calculation of Energy Use
49 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• In the November 2007 ANOPR, DOE estimated the length 

typical dishwasher cycle as one hour.

– The test procedure assumes 215 dishwasher cycles per y

therefore DOE estimates 215 active mode hours per year

• Using very limited consumer usage data, DOE developed 

following estimates for the time allocated to the non-activ

• The typical power values are averages based on DOE tes

14 dishwashers.

– Active mode energy use estimated for 0.65 EF dishwashe

Calculation of Operating Mode Energy – Dishwa

Calculation of Energy Use

Mode Hours Typical Power (W) Annual 

Use (k

Active 215 1,540 331

Delay Start 26 1.91 0.0

Cycle Finished 237 1.56 0.3

Off and Inactive 8,282 0 to 0.69 0 to 5
50 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• As previously discussed, DOE believes that delay start w

considered a part of active mode.

– Therefore, DOE is not proposing to define or measure ene

consumption associated with a delay start mode.

• As shown on the previous slide, the power levels in delay 

mode are comparable to those of off/inactive modes.

– DOE is proposing to allocate delay start mode hours to th

and off modes, increasing the total time spent in these mo8,308 hours per year.

• For dishwashers without a cycle finished mode, DOE is p

to allocate the 237 cycle finished mode hours to off/inacti

• DOE believes few dishwashers are capable of both off an

inactive modes

– If both modes are possible (electronic controls plus a mec

off switch), the off/inactive hours would be split between thmodes.

Calculation of Operating Mode Energy – Dishwa

Calculation of Energy Use
51 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• In conclusion, DOE is proposing to calculate dishwasher 

energy use associated with the inactive, off, and cycle finmodes by:

1. Calculating the product of wattage and allocated hours fo

possible inactive, off, and cycle finished modes;

2. Summing the results; and3. Dividing the sum by 1,000 to convert from Wh to kWh.

• The comparison of annual energy use for the different mo

shows that cycle finished mode represents a relatively smnumber of annual hours at a low power level.

– DOE could adopt a test procedure that would allocate cyc

finished mode hours to the off/inactive modes.

– In that case, all non-active hours would be allocated to in

off mode.

Calculation of Energy Use

Calculation of Operating Mode Energy – Dishwa
52 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• Energy use for dehumidifiers is expressed as energy fact

which is the ratio of liters of water removed from the air p

• DOE is proposing to incorporate standby and off mode en

into this metric based on the number of hours a typical dehumidifier spends in each mode.

– DOE found only limited data on typical dehumidifier active 

operation from the Association of Home Appliance Manufa(AHAM), Arthur D. Little, ENERGY STAR, and Lawrence National Laboratory.

– These studies provide a range of estimates for active mod

operation, from 875 to 4,320 annual hours.

• DOE is proposing 1,095 annual active mode hours based 

AHAM’s mid-estimate.

Calculation of Operating Mode Energy – Dehumi

Calculation of Energy Use
53 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE is aware that a dehumidifier may be unplugged for a 

percentage of the time, and would not be in either standbmode.

– DOE has no data regarding the typical time a dehumidifie

unplugged, however the survey data for active mode operindicate no active mode operation from November to Marcfewer active mode hours in April.

– DOE estimates that dehumidifiers would typically be unplu

this time period.

• DOE is proposing 3,984 annual unplugged hours, based o

period from November to March, and half of April.

• This leaves 3,681 hours to be allocated to the other opera

modes (8,760 – 1,095 – 3,984). 

Calculation of Operating Mode Energy – Dehumi

Calculation of Energy Use
54 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE estimated the typical hours spent in bucket full/remove

and delay start mode.

– Bucket full/removed mode hours based on 25.01 – 35 pints/d

capacity (the predominant dehumidifier product class) operatEF with a typical bucket size of 18.7 pints, and the assumptioconsumers will not typically empty the collection bucket more 

per day.

– Delay start mode hours based on 19% of products offering th

and estimated consumer use of this feature for 50% of these 

10% of the 199 dehumidifying days per year with an average 

setting of 12 hours (half of the maximum delay start time typiavailable).

* The NOPR incorrectly stated that 1.35 EF is the current Federal standard for this p

class. In fact, standards at this level will not go into effect until October 1, 2012current standard is 1.2 EF. However, the number of bucket full/removed hours not affected, since the calculation of annual liters of water removed in the notice 

Calculation of Operating Mode Energy – Dehumi

Calculation of Energy Use
55 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE estimated the typical hours spent in delay start mod

bucket full/removed mode.

• Typical power values for the non-active modes are based 

testing of 13 dehumidifiers.

– Active mode typical power based on the analysis in the No

2007 ANOPR.

• The following table shows the estimated time spent in eac

and the associated annual energy use.

Calculation of Operating Mode Energy – Dehumi

Calculation of Energy Use

Mode Hours Typical Power (W) Annua

Use 

Active 1,095 493 5

Delay Start 23 1.54 0

Bucket Full/Removed 657 1.63 1

Off-Cycle/Inactive/Off 3,001 0 to 1.04 0 to 
56 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• As previously discussed, DOE believes that delay start w

considered a part of active mode.

– Therefore, DOE is not proposing to define or measure ene

consumption associated with a delay start mode.

• As shown on the previous slide, the power levels in delay 

mode are comparable to those of off-cycle/inactive/off mo

– DOE is proposing to allocate delay start mode hours to th

cycle, inactive, and off modes, increasing the total time spthese modes to 3,024 hours per year.

• DOE is aware that most dehumidifiers will not be capable 

operating in all of the non-active modes.

– DOE is not aware of consumer use data for these modes.– DOE is proposing that the total off-cycle, inactive, and off 

hours be split evenly among which of these modes is posscertain dehumidifier model.

Calculation of Operating Mode Energy – Dehumi

Calculation of Energy Use
57 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• In summary, DOE is proposing to calculate dehumidifier a

energy use associated with standby and off modes by:

1. Calculating the product of wattage and allocated hours fo

possible standby and off modes;

2. Summing the results; and3. Dividing the sum by 1,000 to convert from Wh to kWh.

• The comparison of annual energy use for the different mo

shows that dehumidifiers currently on the market have bufull/removed power levels that are comparable to those focycle/inactive/off modes.

– DOE could adopt a test procedure that would allocate buc

full/removed mode hours to the off-cycle/inactive/off mode

– In that case, all non-active hours would be allocated to of

cycle/inactive/off modes.

Calculation of Energy Use

Calculation of Operating Mode Energy – Dehumi
58 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• Energy use for conventional cooking products is express

energy factor (EF), which is the ratio of annual cooking enoutput to the annual energy input.

• DOE is proposing to incorporate standby and off mode en

consumption into this metric, as required by EISA 2007.

– DOE analyzed data on the usage patterns and power con

in these modes on an annual basis for each product class conventional cooking products.

Calculation of Operating Mode Energy –

Conventional Cooking Products

Calculation of Energy Use
59 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE investigated the typical operating time and energy 

consumption associated with inactive, Sabbath, delay stafinished, off, and active modes for conventional ovens.

• The typical times spent in each mode are based on limited 

available consumer use data, and DOE’s best estimates.

• Typical power values are based on DOE testing of 12 con

ovens; active mode typical power is based on a baseline efficiency model electric self-cleaning oven.

Calculation of Operating Mode Energy – Convention

Calculation of Energy Use

Mode Hours Typical Power (W) Annual En

Use (kW

Active 211 810 171.0

Sabbath 8.9 7.59 0.068

Delay Start 61 5.35 0.33

Cycle Finished 18 1.75 0.032

Off/Inactive 8,461.1 0 to 3.80 0 to 32.
60 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• As previously discussed, DOE is not proposing to define 

measure energy consumption for delay start mode or Sabmode.

– DOE is proposing to allocate the delay start mode hours t

inactive and off modes (for a total of 8,522.1 hours), and tthe Sabbath mode hours to active mode (for a total of 219

• For conventional ovens without a cycle finished mode, DO

proposing to allocate the cycle finished mode hours to ofmode.

• DOE believes few conventional ovens are capable of both 

inactive modes

– If both modes are possible (electronic controls plus a mec

off switch), the off/inactive hours would be split between thmodes.

Calculation of Energy Use

Calculation of Operating Mode Energy – Convention
61 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• In summary, DOE is proposing to calculate conventional 

annual energy use associated with standby and off mode

1. Calculating the product of wattage and allocated hours fo

possible standby and off modes;

2. Summing the results; and3. Dividing the sum by 1,000 to convert from Wh to kWh.

• The comparison of annual energy use for the different mo

shows that conventional ovens currently on the market hfinished power levels that are comparable to those for offmodes.

– DOE could adopt a test procedure that would allocate cyc

finished mode hours to the off/inactive modes.

– In that case, all non-active hours would be allocated to of

modes.

Calculation of Energy Use

Calculation of Operating Mode Energy – Convention
62 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE investigated the typical operating time and energy 

consumption associated with inactive, Sabbath, off, and amodes for conventional cooktops.

• The typical times spent in these modes are based on limit

consumer usage data, and DOE’s estimates.

• Typical power values are based on DOE testing of 8 conv

cooktops; active mode typical power is based on a baseliefficiency model electric smooth cooktop.

Calculation of Operating Mode Energy – Conventiona

Calculation of Energy Use

Mode Hours Typical Power (W) Annual Ener

Use (kWh)

Active 211 608 128.2

Sabbath 2.1 152 0.33

Off/Inactive 8,546.9 0 to 3.13 0 to 26.73
63 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• As previously discussed, DOE is not proposing to define 

measure energy consumption for Sabbath mode.

– Sabbath mode hours would be allocated to the active mod

• DOE believes few conventional cooktops are capable of b

and inactive modes

– If both modes are possible (electronic controls plus a mec

off switch), the off/inactive hours would be split between thmodes.

• In summary, DOE is proposing to calculate conventional 

annual energy use associated with standby and off mode

1. Calculating the product of wattage and allocated hours for 

possible standby and off modes;

2. Summing the results; and3. Dividing the sum by 1,000 to convert from Wh to kWh.

Calculation of Energy Use

Calculation of Operating Mode Energy – Conventiona
64 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE investigated the typical operating time and energy 

consumption associated with inactive, Sabbath, delay stafinished, off, and active modes for conventional ranges.

• The typical times spent in each mode are based on limited 

available consumer use data, and DOE’s best estimates.

• Typical power values are based on DOE testing of 21 con

ranges; active mode typical power is based on the sum otypical power levels for conventional ovens and cooktops

Calculation of Operating Mode Energy – Convention

Calculation of Energy Use

Mode Hours Typical Power (W) Annual Ene

Use (kW

Active 422 709 299.2

Sabbath 8.8 3.72 0.033

Delay Start 50 2.95 0.148

Cycle Finished 18 2.52 0.045

Off/Inactive 8,261.2 0 to 2.68 0 to 22.1
65 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• As previously discussed, DOE is not proposing to define 

measure energy consumption for delay start mode or Sabmode.

– DOE is proposing to allocate the delay start mode hours t

inactive and off modes, and to allocate the Sabbath mode active mode.

• For conventional ranges without a cycle finished mode, D

proposing to allocate the cycle finished mode hours to ofmode.

• DOE believes few conventional ranges are capable of bot

inactive modes

– If both modes are possible (electronic controls plus a mec

off switch), the off/inactive hours would be split between thmodes.

Calculation of Energy Use

Calculation of Operating Mode Energy – Convention
66 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• In summary, DOE is proposing to calculate conventional 

annual energy use associated with standby and off mode

1. Calculating the product of wattage and allocated hours fo

possible standby and off modes;

2. Summing the results; and3. Dividing the sum by 1,000 to convert from Wh to kWh.

• The comparison of annual energy use for the different mo

shows that conventional ranges currently on the market hcycle finished power levels that are comparable to those off/inactive modes.

– DOE could adopt a test procedure that would allocate cyc

finished mode hours to the off/inactive modes.

– In that case, all non-active hours would be allocated to of

modes.

Calculation of Energy Use

Calculation of Operating Mode Energy – Convention
67 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Request for Comment on Energy Use Calculat

Item 10 DOE invites comment on the approach for calculatinenergy use for standby mode and off mode for dishwashers, dehumidifiers, and conventional cooking products. DOE also comment on the allocation of annual hours and test burden, the alternative methodology for allocation of annual hours for product.

Calculation of Energy Use
68 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Test Procedure Overview and Issues

1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First 

for Measuring Standby Mode and Off Mode Power Consu

3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements f

Standby Mode and Off Mode Testing

5. Calculation of Energy Use Associated with Standby Mod

Mode

6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide an

ENERGY STAR
69 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• EPCA directs that test procedures shall be amended to in

standby and off mode energy consumption in the overall efficiency descriptor for each covered product. 42 U.S.C. 6295(gg)(2)(A) 

– DOE examined whether the existing measures of energy 

consumption for dishwashers, dehumidifiers, and convencooking products can be combined with standby mode anmode energy use to form a single metric.

– DOE notes that the dishwasher and conventional cooking 

test procedures already incorporate some form of standbconsumption into the overall efficiency metrics (standby pdishwashers, and clock power for conventional cooking p

• The following slides discuss how the existing measures 

consumption will be combined with standby and off moduse for each product.

Measures of Energy Consumption

Measures of Energy Consumption
70 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE notes that the current dishwasher test procedure in

measure of standby power into the overall energy efficiendescriptor, the estimated annual energy use (EAEU).

– DOE also notes that the standby mode and off mode ene

of a magnitude that it would materially affect that standardprocess without overwhelming the effects of differing leveactive mode energy use.

• DOE is proposing amendments to the test procedure tha

fully account for standby mode and off mode energy consumption for dishwashers.

• The proposed amendments would require measuring an 

additional standby mode (cycle finished mode), as well amode, and would revise the definition of standby mode in existing test procedure.

Measures of Energy Consumption

Measures of Energy Consumption – Dishwash
71 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• The inactive, off , and cycle finished modes measured un

proposed test procedure may result in energy consumptslightly higher than the current test procedure.

– The proposed amendments would clarify that provisions r

the new measures of energy consumption in standby modmode would not be required to be used by manufacturers compliance date of any amended dishwasher standards addressing standby mode and off mode energy use.

• DOE is also proposing to amend the estimated annual op

cost calculation to incorporate the revised standby and oenergy consumption.

• DOE is not proposing to amend the calculation of EF in t

current dishwasher test procedure.

• DOE is also proposing to include rounding instructions f

final values of EF, EAEU, and water consumption per cyc

Measures of Energy Consumption

Measures of Energy Consumption – Dishwash
72 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• The DOE dehumidifier test procedure only accounts for a

mode energy consumption in the calculation of EF.

– EF is calculated based on the liters of water removed from 

per kWh consumed, over a 24-hour test cycle.

– As with dishwashers, the standby mode and off mode ene

is of a magnitude that it would materially affect that standsetting process without overwhelming the effects of differof active mode energy use. 

• DOE is proposing to incorporate standby and off mode e

use into a new overall efficiency metric for dehumidifiersintegrated energy factor (IEF).

– The energy use would be allocated based on the ratio of 

active mode hours to annual standby and off mode hours

Measures of Energy Consumption

Measures of Energy Consumption – Dehumidi
73 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• The formula for calculating IEF is shown below.

IEF = L

W / (Eactive + ((ETSO × 24) / hactive))

Where:

L

W = water removed from the air during dehumidifier energy f

in liters.Eactive = active mode energy consumption over the active modcycle, in kWh.ETSO = standby mode and off mode annual energy consumpti

kWh per year (determined as the standby and off mode measpower multiplied by the standby and off mode hours per year24 = hours per day.hactive = annual active mode hours, 1,095.

• DOE is proposing to round the final IEF value to two deci

places.

Measures of Energy Consumption

Measures of Energy Consumption – Dehumidi
74 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• The DOE test procedures for conventional cooking produ

provide calculations for various energy consumptions an

– Including: test energy consumption, annual cooking energ

consumption, annual pilot light energy consumption, annu

cleaning energy consumption, annual clock energy consuand total annual energy consumption.

• There are no current performance-based energy conserv

standards for conventional cooking products.

– DOE’s rulemaking analyses have used EF as the relevan

conservation metric.

• Because these test procedures already account for narro

of energy use, DOE believes including standby and off menergy consumption would result in a meaningful metric

Measures of Energy Consumption

Measures of Energy Consumption –

Conventional Cooking Products
75 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• For conventional ovens, DOE proposes:

– Electric ovens – “Integrated annual energy consumption” 

sum of the annual standby and off mode energy consumpthe annual primary cooking and self-cleaning energy cons

– Gas ovens – “Integrated annual electrical energy consum

the sum of the annual standby and off mode energy cons

and the annual secondary cooking and self-cleaning enerconsumption.

– “Integrated Energy Factor” (IEF) –

• Electric ovens – annual useful cooking energy output divide

integrated annual energy consumption.

• Gas ovens – annual useful cooking energy output divided by 

of the annual gas energy consumption and the integrated anelectrical energy consumption.

– DOE proposes similar metrics for multiple conventional o

Measures of Energy Consumption

Measures of Energy Consumption – Conventiona
76 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• For conventional cooktops, DOE proposes:

– Electric cooktops – “Integrated annual energy consumptio

annual standby and off mode energy consumption plus thuseful cooking energy output divided by the conventional cooking efficiency.

– Gas cooktops – “Integrated annual electrical energy cons

as the sum of the annual standby and off mode energy consumption, the annual energy consumption for cookingannual energy consumption of the gas standing pilot light

– “Integrated Energy Factor” (IEF) –

• Electric cooktops – annual useful cooking energy output div

integrated annual energy consumption.

• Gas cooktops – annual useful cooking energy output divided 

integrated annual energy consumption.

Measures of Energy Consumption

Measures of Energy Consumption – Conventional C
77 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• For conventional ranges, DOE proposes:

– “Integrated annual energy consumption” as the sum of th

cooking energy consumption of each of its components (ocooktop) plus the conventional range annual standby modmode energy consumption.

– “Integrated Energy Factor” (IEF) as the sum of the annua

cooking energy output of each component divided by the the integrated annual energy consumption of each compo

• For all conventional cooking products, DOE is proposing 

amend the annual energy cost calculations in 10 CFR par

• DOE also proposes to maintain the instructions for round

annual operating cost to the nearest dollar, and to includinstructions for rounding the final IEF values to three sigdigits.

Measures of Energy Consumption

Measures of Energy Consumption – Conventional 
78 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Request for Comment on Energy Use Calculat

Item 11 DOE invites comment on the proposed plan to estab“integrated energy factor” metrics for dehumidifiers and convcooking products. DOE also invites comment on the proposeamendments to modify the existing “estimated annual energy “estimated annual operating cost” metrics for dishwashers to incorporate the revised measurements of standby mode and energy consumption.

Measures of Energy Consumption
79 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Test Procedure Overview and Issues

1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First 

for Measuring Standby Mode and Off Mode Power Consu

3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements f

Standby Mode and Off Mode Testing

5. Calculation of Energy Use Associated with Standby Mod

Mode

6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide an

ENERGY STAR
80 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• EPCA requires that “[a]ny test procedures prescribed or a

under this section shall be reasonably designed to produresults which measure energy efficiency, energy use . . . oestimated annual operating cost of a covered product durrepresentative average use cycle or period of use . . . and be unduly burdensome to conduct.” (42 U.S.C. 6293(b)(3)

• DOE believes the proposed amendments regarding stand

mode energy consumption satisfy this requirement becau

– IEC Standard 62301 is internationally accepted to measur

standby and off mode, and will produce power consumptiomeasurements that are representative of an average use 

– The proposed test methods and associated equipment wo

require manufacturers to make a major investment in test and new equipment.

Test Burden

Compliance with Other EPCA Requirements
81 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• EPCA also directs DOE to consider IEC Standard 62087 “

of measurement for the power consumption of audio, viderelated equipment” when amending test procedures to instandby mode and off mode power measurements.

– As previously discussed, DOE determined that this standa

applicable to measuring power consumption of electrical asuch as dishwashers, dehumidifiers, and conventional cooproducts.

Potential Incorporation of IEC Standard 620

Compliance with Other EPCA Requirements
82 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• Section 325(gg)(2)(A) of EPCA requires that standby mod

mode energy consumption be “integrated into the overall efficiency, energy consumption, or other energy descriptoeach covered product” unless the current test procedures fully account for the standby mode and off mode energy consumption, or if such an integrated test procedure is te

infeasible. (42 U.S.C. 6295(gg)(2)(A))

• DOE proposes to incorporate standby and off mode powe

– For dishwashers, into the “estimated annual energy use (E

and “estimated annual operating cost (EAOC).”

– For dehumidifiers, into the new “integrated energy factor.”– For conventional cooking products, into an “integrated ann

energy consumption” and an “integrated energy factor.”

Integration of Standby and Off Mode Energy Cons

Compliance with Other EPCA Requirements
83 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• EPCA also requires that test procedure amendments 

incorporating standby and off mode energy consumption determine compliance with previously established standaU.S.C. 6295(gg)(2)(C))

– As previously discussed, DOE expects the EAEU and EA

dishwashers would not be significantly affected by the proamendments.

• Additionally, the proposed amendments would clarify that the

required to determine compliance with the current energy costandard.

– For dehumidifiers, the existing standards are based on EF

will not be altered by the proposed amendments for calcuIEF.

– There are no current performance-based Federal energy 

conservation standards for conventional cooking products (including energy use in the standby and off modes).

Impact of Test Procedure Amendments on Existing 

Compliance with Other EPCA Requirements
84 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

Test Procedure Overview and Issues

1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First 

for Measuring Standby Mode and Off Mode Power Consu

3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements f

Standby Mode and Off Mode Testing

5. Calculation of Energy Use Associated with Standby Mod

Mode

6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide an

ENERGY STAR
85 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

• DOE considered potential impacts of the proposed test p

amendments to the FTC EnergyGuide requirements and tENERGY STAR program requirements, and determined thwill be no impact.

– For dishwashers, DOE concluded that the relevant metric

EAOC, and water consumption, would not be affected by proposed amendments.

– For dehumidifiers, there are currently no EnergyGuide lab

requirements, and the ENERGY STAR program is based which would not be affected by the proposed amendment

– For conventional cooking products, there are currently no 

EnergyGuide or ENERGY STAR requirements.

Impact on EnergyGuide and ENERGY STAR

Impact of the Proposed Amendments
86 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Products 

 Public Meeting – oral comments will be captured in the transcrip

become part of the public record.

 Written comments – NOPR comment period open until 75 days 

publication in the Federal RegisterReference docket #: EERE-2010-BT-TP-0039 and/or RIN #: 190

Email: Res-DW-Dehumid-CookingProd-2010-TP-0039@ee

Mail: Mrs. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program1000 Independence Avenue, SW, Mailstop EE-2J

Washington, DC 20585-0121

Courier: Mrs. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program950 L'Enfant Plaza, 6th Floor

Washington, DC 20024Telephone: (202) 586-2945

How to Submit Comments...

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