1 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govThe Parker Ranch installation in HawaiiTest Procedures for Dishwashers, Dehumidifiers,and Conventional Cooking ProductsNotice of Proposed RulemakingPublic MeetingWes AndersonDepartment of EnergyEnergy Efficiency & Renewable EnergyEmail: wes.anderson@ee.doe.govDecember 17, 20102 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•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 meeting– Written comments (comment period closes 75 days after publicationin theFederal Register)•DOE reviews and considers all comments•Final Rule PublicationSteps in the Test Procedure RulemakingIntroductionNOPR3 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First Edition)for Measuring Standby Mode and Off Mode Power Consumption3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements forStandby Mode and Off Mode Testing5. Calculation of Energy Use Associated with Standby Mode and OffMode6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide andENERGY STARTest Procedure Overview and IssuesIntroduction4 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•This test procedure rulemaking covers the following appendices to10 CFR part 430, subpart B:– Appendix C – Uniform Test Method for Measuring the EnergyConsumption of Dishwashers;– Appendix I – Uniform Test Method for Measuring the EnergyConsumption of Conventional Ranges, Conventional Cooking Tops,Conventional Ovens, and Microwave Ovens; and– Appendix X – Uniform Test Method for measuring the EnergyConsumption of Dehumidifiers.•The Energy Independence and Security Act of 2007 (EISA 2007)amendments to EPCA direct DOE to amend its test procedures fordishwashers, dehumidifiers, and conventional cooking products tointegrate measures of standby and off mode energy consumptionno later than March 31, 2011.Regulatory BackgroundIntroduction5 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govTest Procedure Overview and Issues1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First Edition)for Measuring Standby Mode and Off Mode Power Consumption3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements forStandby Mode and Off Mode Testing5. Calculation of Energy Use Associated with Standby Mode and OffMode6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide andENERGY STAR6 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•10 CFR part 430.2 provides the following product definitions:–Dishwashermeans a cabinet-like appliance which with the aid ofwater and detergent, washes, rinses, and dries (when a dryingprocess is included) dishware, glassware, eating utensils, and mostcooking utensils by chemical, mechanical and/or electrical means anddischarges to the plumbing drainage system.–Dehumidifiermeans a self-contained, electrically operated, andmechanically refrigerated encased assembly consisting of –1. A refrigerated surface (evaporator) that condenses moisture from theatmosphere;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 RulemakingCovered Products7 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•10 CFR part 430.2 provides the following product definitions:–Cooking productsmeans consumer products that are used as themajor household cooking appliances. They are designed to cook orheat different types of food by one or more of the following sources ofheat: gas, electricity, or microwave energy. Each product may consistof a horizontal cooking top containing one or more surface unitsand/or one or more heating compartments. They must be one of thefollowing classes: conventional ranges, conventional cooking tops,conventional ovens, microwave ovens, microwave/conventionalranges and other cooking products.–Conventional cooking topmeans a class of kitchen ranges and ovenswhich is a household cooking appliance consisting of a horizontalsurface containing one or more surface units which include either agas flame or electric resistance heating.Products Covered by this Test Procedure RulemakingCovered Products8 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•10 CFR part 430.2 provides the following product definitions:–Conventional ovenmeans a class of kitchen ranges and ovens whichis a household cooking appliance consisting of one or morecompartments intended for the cooking or heating of food by meansof either a gas flame or electric resistance heating. It does not includeportable or countertop ovens which use electric resistance heating forthe cooking or heating of food and are designed for an electricalsupply of approximately 120 volts.–Conventional rangemeans a class of kitchen ranges and ovenswhich is a household cooking appliance consisting of a conventionalcooking top and one or more conventional ovens.•DOE is not proposing any amendments to these product definitions.Products Covered by this Test Procedure RulemakingCovered Products9 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govTest Procedure Overview and Issues1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First Edition)for Measuring Standby Mode and Off Mode Power Consumption3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements forStandby Mode and Off Mode Testing5. Calculation of Energy Use Associated with Standby Mode and OffMode6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide andENERGY STAR10 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•EISA 2007 amended EPCA to require test procedure amendmentsregarding standby and off mode power to take into considerationthe most current versions ofIEC Standards 62301 and 62087.– IEC Standard 62087 is not applicable to this rulemaking.•DOE proposes to incorporate into the test procedure all applicableprovisions from Sections 4 and 5 of IEC Standard 62301 FirstEdition, as shown in the table below.IEC Standard 62301 and IEC Standard 62087Incorporating IEC Standard 62301SectionParagraph4. General conditions formeasurements4.2 Test room4.4 Supply voltage waveform4.5 Power measurement accuracy5. Measurements5.1 General, Note 15.2 Selection and preparation of applianceor equipment5.3 Procedure11 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE notes that the IEC is developingan updated version of IEC Standard62301 (Second Edition).– Expected to include definitionsof “off mode,” “network mode,” and“disconnected mode,” and would revise the current First Edition definition of“standby mode.”– IEC has not yet published this version of the Standard.Therefore it is notavailable for DOE’s considerationor incorporation by reference.•IEC Standard 62301 First Edition is the“current version” for purposes of theEISA 2007 amendments to EPCA.•However, DOE has reviewed the twomost recent draft versions of theSecond Edition: (1) the Committee Draft for Vote (IEC Standard 6230CDV)and (2) the subsequent Final Draft International Standard (IEC Standard62301 FDIS).– DOE anticipates that the Second Edition will include updated mode definitionssimilar to those included in IEC Standard 62301 FDIS, and thereforeconsidered IEC Standard 62301 FDIS for mode definitions.IEC Standard 62301Incorporating IEC Standard 6230112 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE notes the current dishwasher test procedure already includestest methods for standby power consumption that are very similarto the provisions in IEC Standard 62301 First Edition.– However, these provisions do not account for multiple standby modesor an off mode.– DOE is proposing to amend the dishwasher test procedure to includenew definitions of standby, off, and inactive mode based on theprovisions in IEC Standard 62301 FDIS, as well as the identifiedtesting clauses from IEC Standard 62301 First Edition.•DOE is also aware that the cooking product test procedure accountsfor the annual energy consumption of a continuously operatingclock, but no other standby mode or off mode energy consumption.– Therefore, DOE is proposing to adopt the clauses from IEC Standard62301 that would fully account for standby mode and off modeenergy consumption in conventional cooking products.IEC Standard 62301 – Dishwashers andConventional Cooking ProductsIncorporating IEC Standard 6230113 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govRequest for Comment on Incorporating IEC Standard 62301Incorporating IEC Standard 62301Item 1DOE seeks comment on the adequacy of IEC Standard 62301to measure standby and off mode power consumption for dishwashers,dehumidifiers, and conventional cooking products, and on the suitabilityof incorporating the specified provisions into DOE regulations.14 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govTest Procedure Overview and Issues1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First Edition)for Measuring Standby Mode and Off Mode Power Consumption3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements forStandby Mode and Off Mode Testing5. Calculation of Energy Use Associated with Standby Mode and OffMode6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide andENERGY STAR15 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•The mode definitions providedin EPCA and in IEC Standard 62301First Edition could lead to multiple interpretations.– These definitions were developed to be broadly applicable formany energy-using products.•EPCA authorizes DOE to amend mode definitions, considering themost current versions of IEC Standards 62301 and 62087.•DOE expects the definitions provided in IEC Standard 62301 FDISto remain relatively unchanged in the final revised IEC Standard62301, Second Edition, and therefore considered these definitionsas the most current when determining the mode definitions for theamended test procedure.– DOE is proposing mode definitions based on the definitionsprovided in IEC Standard 62301 FDIS, with added clarificationsspecific to dishwashers, dehumidifiers, and conventional cookingproducts.Determination and Classification of Operational ModesModes to Be Incorporated16 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is proposing to define active mode as:– the condition in which the energy-using product is connected to amains power source, has been activated, and provides one or moremain functions.•DOE notes that IEC Standard 62301 Second Edition CommitteeDraft 2 (IEC Standard 62301 CD2) provides the additionalclarification that “delay start mode is a one off user initiated shortduration function that is associated with an active mode.”– However, IEC 62301 FDIS does not include this note, and classifiesdelay start as a secondary functionthat is not a part of active mode.•DOE continues to believe that because delay start is of limitedduration and is uniquely associated with the initiation of a mainfunction, it should be considered part of active mode.– Additional discussion of delay start is provided later.Definitions of Modes – ActiveModes to Be Incorporated17 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is also proposing that the following main functions beclassified as active mode for each product:–Dishwashers– Active mode means a mode in which thedishwasher is performing the main function of washing, rinsing, ordrying (when a drying process is included) dishware, glassware,eating utensils, and most cooking utensils by chemical, mechanicaland/or electrical means, or is involved in functions necessary forthese main functions, such as admitting water into the dishwasheror pumping water out of the dishwasher.Definitions of Modes – ActiveModes to Be Incorporated18 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is also proposing that the following main functions beclassified as active mode for each product:–Conventional Cooking Products– Active mode means a mode inwhich a conventional cooking top, conventional oven, orconventional range is performing the main function of cooking,heating, proofing, or holding the cooking load by means of either agas flame or electric resistance heating.–Dehumidifiers– Active mode means a mode in which adehumidifier is performing the main functions of removing moisturefrom ambient air by drawing moist air over a refrigerated coil usinga fan, circulating air through activation of the fan without activationof the refrigeration system, or defrosting the refrigerant coil.Definitions of Modes – ActiveModes to Be Incorporated19 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is proposing to define standby mode as:– any mode in which the product is connected to a mains powersource and offers one or more of the following user-oriented orprotective functions which may persist for an indefinite time:• To facilitate the activation of other modes (including activation ordeactivation of active mode) by remote switch (including remotecontrol), internal sensor, or timer;• Continuous functions, including information or status displays(including clocks), orsensor-based functions.– A timer is a continuous clock function (which may or may not beassociated with a display) that provides regular scheduled tasks(e.g., switching) and that operates on a continuous basis.Definitions of Modes – StandbyModes to Be Incorporated20 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•This differs from the current definition of standby mode in thedishwasher test procedure, based on IEC 62301 (First Edition).– DOE proposes to redefine this mode as “simplified standby mode”for continued use until amended conservation standards takeeffect.•DOE notes that the proposed definition of standby mode allowsfor multiple modes to be considered standby.•DOE is proposing to define “inactive mode” for dishwashers,dehumidifiers, and conventional cooking products as a standbymode that facilitates the activation of active mode by remoteswitch (including remote control), internal sensor, or timer, or thatprovides continuous status display.Definitions of Modes – Standby, InactiveModes to Be Incorporated21 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is proposing to define off mode as:– A mode in which the product is connected to a mains power sourceand is not providing any active mode or standby mode function, andwhere the mode may persist for an indefinite time.– An indicator that shows the user only that the product is in the offposition is included within the classification of off mode.•A product equipped with a mechanical on/off switch that candisconnect power to the display and/or control components wouldbe considered as operating in the off mode when the switch is inthe “off” position, provided that no other standby or active modefunctions are energized.•DOE believes that active, standby, inactive, and off modes, asproposed, are all relevant for dishwashers, dehumidifiers, andconventional cooking products.– Product-specific modes are addressed in the following slides.Definitions of Modes – OffModes to Be Incorporated22 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govRequest for Comment on the Proposed Mode DefinitionsModes to Be IncorporatedItem 2DOE welcomes comment onthe proposed definitions of“standby mode,” “off mode,” and “active mode,” which are based on thedefinitions provided inIEC Standard 62301 FDIS.23 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is aware of two additionalrelevant modes for dishwashers:delay start mode and cycle finished mode.– Delay start mode is defined as a mode in which activation of anactive mode is facilitated by a timer.– Cycle finished mode is defined as a mode that provides continuousstatus display following operation in active mode.•Because delay start mode is not a mode that may persist for anindefinite time, DOE believes it would not be considered a part ofstandby mode and would be a form of active mode.– DOE is not proposing amendments to the active mode testprocedures under this rulemaking.•Cycle finished mode would be considered a standby mode underthe proposed definitions.Dishwasher ModesModes to Be Incorporated24 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govRequest for Comment on the ProposedDishwasher Mode DefinitionsModes to Be IncorporatedItem 3DOE invites comment on the proposed establishment of inactivemode and cycle finished mode as standby modes for dishwashers, andthe determination that “delay start mode” would not be a form of activemode. DOE further invites comment on whether there are anydishwasher modes consistent withthe “active mode,” “standby mode,”or “off mode” definitions that have not been identified and representsignificant energy use.25 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is aware of three additional relevant modes fordehumidifiers: delay start mode, off-cycle mode, and bucketfull/removed mode.– Delay start mode is defined the same as for dishwashers.– Off-cycle mode is defined as a mode in which a dehumidifier hascycled off its main function by humidistat or humidity sensor, doesnot have its fan or blower operating, and will reactivate the mainfunction according to the humidistat or humidity sensor signal.– Bucket full/removed mode is defined as a mode in which thedehumidifier has automatically powered off its main function bydetecting when the water collection bucket is full or removed.•For the reasons discussed for dishwashers, DOE believes thatdelay start mode would be considered a form of active mode.•Off-cycle and bucket full/removed modes both may persist for anindefinite time and would be considered a part of standby mode.Dehumidifier ModesModes to Be Incorporated26 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govRequest for Comment on the ProposedDehumidifier Mode DefinitionsModes to Be IncorporatedItem 4DOE invites comment on the proposed establishment of inactivemode, off-cycle mode, and bucket full/removed mode as standbymodes for dehumidifiers, and the determination that “delay start mode”would be considered a form of active mode. DOE further invitescomment on whether there are any dehumidifier modes consistent withthe “active mode,” “standby mode,” or“off mode” definitions that havenot been identified and represent significant energy use.27 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is aware of three additional relevant modes for conventionalcooking products: delay start mode, cycle finished mode, andSabbath mode.– Delay start mode and cycle finished mode definitions are the sameas for dishwashers.– Sabbath mode is defined as a modein which the automatic shutoffis overridden to allow for warming of pre-cooked foods during suchperiods as the Jewish Sabbath.•For the reasons discussed for dishwashers, DOE believes thatdelay start mode would be considered a form of active mode.•Cycle finished mode would be considered a part of standby mode.•DOE believes the Sabbath mode function of warming food wouldbe considered part of active mode, and is therefore not proposingamendments to define or measure energy consumption in thismode.Conventional Cooking Product ModesModes to Be Incorporated28 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govRequest for Comment on the ProposedConventional Cooking Product Mode DefinitionsModes to Be IncorporatedItem 5DOE invites comment on the proposed establishment of inactivemode and cycle finished mode asstandby modes for conventionalcooking products, and the determination that “delay start mode” and“Sabbath mode” would be consideredforms of active mode. DOEfurther invites comment on whetherthere are any conventional cookingproduct modes consistent with the “active mode,” “standby mode,” or“off mode” definitions that havenot been identified and representsignificant energy use.29 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•IEC Standard 62301 FDIS defines network mode as:– “any product modes where the energyusing product is connected toa mains power source and at least one network function is activated(such as reactivation via network command or network integritycommunication) but where the primary function is not active.”•IEC Standard 62301 FDIS also defines disconnected mode as:– “the status in which all connections to mains power sources of theenergy using product are removed or interrupted.”•The proposed amendments would not incorporate either of thesemodes into the covered test procedures.– DOE is unaware of any dishwashers, dehumidifiers or conventionalcooking products currently incorporating a networking function, or ofappropriate methods for testing energy consumption in this mode.– DOE believes that there would be no energy use in a disconnectedmode, therefore testing in this mode would be irrelevant.Modes not Included – Network & DisconnectedModes to Be Incorporated30 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govRequest for Comment on Network ModeModes to Be IncorporatedItem 6DOE welcomes comment on whether dishwashers,dehumidifiers, or conventional cooking products are currently availablethat incorporate a networking function, and whether definitions andtesting procedures for a network modeshould be incorporated into theDOE test procedures. DOE also requests comment on appropriatetesting methodologies for measuringenergy consumption in a networkmode for these products, and dataon such testing methodology.31 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govTest Procedure Overview and Issues1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First Edition)for Measuring Standby Mode and Off Mode Power Consumption3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements forStandby Mode and Off Mode Testing5. Calculation of Energy Use Associated with Standby Mode and OffMode6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide andENERGY STAR32 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is proposing test procedures for measuring the powerconsumption of dishwashers, dehumidifiers, and conventionalcooking products in all standby and off modes.– These proposed amendments also include provisions formeasuring energy use in cycle finished mode for dishwashers andconventional cooking products, and off-cycle and bucketfull/removed mode for dehumidifiers.•The following section discusses provisions DOE proposes toinclude in its test procedures to clarify the IEC Standard 62301(First Edition) methods used to measure energy consumption inthese modes.Adding Specifications for Standby Mode and Off Mode TestingTest Methods and Measurements33 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•Paragraph 5.3.1 of IEC Standard 62301 contains provisions formeasuring power.– If power is stable (varies by not more than 5% from a maximumlevel during a 5 minute period), wait 5 minutes for the product tostabilize, then measure the power at the end of an additional timeperiod of at least 5 minutes.– If power is unstable (varies by more than 5% from a maximum levelduring a 5 minute period), the power measurement shall be at least5 minutes, or, if there is an operating cycle, one or more completeoperating cycles of several minutes or hours.•DOE notes that these provisions do not preclude manufacturersfrom testing products with a longer stabilization period, or alonger measurement period if they so choose.Power Measurement PeriodTest Methods and Measurements34 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is aware that displays on dishwashers and conventionalcooking products may reducepower consumption by dimmingafter a certain period of user inactivity.•For these units, DOE proposes that the standby and off modetests be conducted after the power level has dropped to its lowestlevel, as discussed in IEC Standard 62301, paragraph 5.1, note 1.– DOE observed during testing of all three covered products that thetypical higher-power state persists for less than 10 minutes ofinactivity; thus the energy consumption at the low-power level ismore representative of actual use.– It is possible that some products may remain in the higher-powerstate for the duration of the 5-minute stabilization and 5-minute testperiod specified in IEC Standard 62301 (First Edition).Test Methods and MeasurementsPower Measurement Period35 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•IEC Standard 62301 Committee Draft for Vote (CDV), whichpreceded the FDIS version, updated the First Editionspecifications to require a stabilization period of 30 minutes priorto a measurement period not less than 10 minutes.•IEC Standard 62301 FDIS further revised the test method toestablish an overall test period of not less than 15 minutes.– If the mode tested is not cyclic, the first third of the period can beconsidered a stabilization period, and the remaining two-thirds areused to determine whether the power is stable. The period may beextended continuously until the stability criteria are achieved up to 3hours.– Modes that are non-cyclic with varying power follow this sameprocedure but with a total test period not less than 60 minutes.– Cyclic modes use an initial stabilization period of at least 10minutes, with the power averaged over at least 4 complete cycles.Test Methods and MeasurementsPower Measurement Period36 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE considered the test methods from the First Edition, CDV, andFDIS versions of IEC Standard 62301.– DOE has tentatively concluded that the specifications provided inIEC Standard 62301 CDV would lead to the most accurate,repeatable, and enforceable power measurements.•Additionally, DOE believes these specifications would allowsufficient time for displays that automatically dim or power downto reach the lower-power state prior to measurement.– Even if certain products allow for altering the display settings toincrease the time period in the high-power state, DOE believes thetypical consumer will maintain the default settings, and therefore isnot proposing additional provisions to address the possibility ofadjusting the default settings.Test Methods and MeasurementsPower Measurement Period37 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govRequest for Comment on Default SettingsItem 7DOE welcomes comment on the suitability of using the defaultsettings in testing standby energy consumption, on any methodologiesthat can account for consumer actions that might increase energy use,and data on the repeatability of such testing procedures.Test Methods and Measurements38 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is proposing that the test room ambient temperatures forstandby and off mode testing bespecified according to section 4,paragraph 4.2 of IEC Standard 62301: 73.4 °F ± 9 °F.– The current DOE active mode test procedures for dishwashers anddehumidifiers include ambient temperatures requirements fallingwithin this range, which would give manufacturers the option ofconducting standby and off mode tests simultaneously with activemode tests, on separate units.– The test procedures for conventional cooking products requireambient temperatures of 77 °F ± 9 °F.• Manufacturers may perform standbyand off mode tests simultaneouslywith active mode testing in the same room if the ambient temperaturefalls between 68 °F and 82.4 °F.Test Room Ambient TemperatureTest Methods and Measurements39 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govRequest for Comment on Test Room Ambient TemperatureItem 8DOE seeks comment on the appropriateness of the proposedmodified test room ambient temperature range for dishwashers,dehumidifiers, and conventional cooking products, which would allowmanufacturers to conduct standbyand off mode testing separately fromperformance testing under the lessstringent ambient conditionsspecified in the IEC Standard 62301.Test Methods and Measurements40 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•IEC Standard 62301 (First Edition) states that when it is referencedby an external standard, the test voltage and frequency defined bythe external standard shall be used; when the test voltage andfrequency are not defined in the external standard, 115 V ± 1% and60 Hertz (Hz) ± 1% should be used.– The current dehumidifier test procedure specifies that the ratedfrequency should be used for testing, but does not provide anallowable frequency range.– The current conventional cooking products test procedure does notspecify any power supply frequency requirements.•DOE is proposing to include an allowable frequency range of ± 1%for dehumidifiers, and a power supply frequency of 60 Hz ± 1% forconventional cooking products for standby and off mode testing.Power Supply RequirementsTest Methods and Measurements41 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE notes that IEC Standard 62301 does not closely specify thetest method when the measured power is not stable.– “if the power varies over a cycle (i.e., a regular sequence of powerstates that occur over several minutes or hours), the period selectedto average power or accumulate energy shall be one or morecomplete cycles in order to get a representative average value.”•DOE investigated the possible regular sequences of power statesfor conventional cooking productsto determine the variation inpower over a cycle, and an appropriate clarification to IEC Standard62301.– DOE tests on 7 conventional cooking products showed that standbypower consumption can vary by as much as 44 percent based on theclock display (1:11 display versus 12:08 display).Unstable Power Measurement MethodTest Methods and Measurements42 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•As part of the microwave ovens energy conservation standardrulemaking, DOE investigated three different test methods formeasuring unstable power due to clock displays.– 12-hour test period (to capture all display values)– 18-point method: measures power consumption of different displayconfigurations and then estimates the representative 12-hourconsumption based on how often eachconfiguration is used over 12hours– 10-minute method: uses a 10-minute test period with a starting clocksetting at 3:33.• DOE believes the distribution of display segments over this 10-minuteperiod would be comparable to that of a 12-hour test period.•The following table compares standby test results using the abovemethods for 11 microwave test units.Unstable Power Measurement MethodTest Methods and Measurements43 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE*Standby power measurements are scaledto normalize the supply power to 120.0volts.**For this test unit, the supply power was significantly different than 120.0 volts.Therefore, DOE believes the scaling of the measured standby power and thus thepercentage differences from the 12-hourstandby power measurements are notvalid for this test unit.Unstable Power Measurement MethodTest Methods and MeasurementsTestUnitDisplay Type12-HourMethod18-Point Method10-Minute MethodStandbyWatts*StandbyWatts*PercentDifferenceStandbyWatts*PercentDifference1LCD1.5671.552-0.99%1.5921.60%2LCD1.5711.560-0.70%1.554-1.08%3LCD1.8121.8120.03%1.801-0.61%4LCD1.4901.475-0.96%1.4920.17%5LCD1.8591.847-0.60%1.8740.84%6LCD3.7883.7980.26%3.8180.81%7LCD3.6413.6420.04%3.606-0.95%8LED1.8021.796-0.35%1.797-0.32%9LED1.8251.820-0.25%1.816-0.47%10LED3.1853.177-0.27%3.2903.28%**11VFD5.6005.6110.20%5.6070.13%44 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE observed that the 10-minute test period results varied by lessthan 2 percent from the 12-hour period for this sample of units.– Therefore, DOE is proposing a 10-minute measurement period with astarting time of 3:33 to measure standby energy use for conventionalcooking products with power consumptions that vary with the timedisplayed on the clock.• The proposed test procedure would require an initial 10-minutestabilization period followed by settingthe clock to 3:23 to allow anotherstabilization period before the 10-minute measurement period.•DOE believes with this method of measuring standby power, thetesting provisions for clock energy consumption currently in thecooking products test procedure are no longer necessary.– The 10-minute test period would account for all standby mode and offmode energy consumption, including clock energy consumption,which would be incorporated into the annual energy consumptionand EF calculations.Unstable Power Measurement MethodTest Methods and Measurements45 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE notes that both the 18-point and 10-minute approaches foraccelerated standby testing do not exclude the possibility that aproduct could be programmed to alter its behavior during such atest.– The product could be programmed to dim or alter its display duringthe times associated with the 18 measurement points, or betweenthe display times of 3:33 and 3:42.•DOE is proposing to provide manufacturers the option ofconducting either the full 12-hour test, the 10-minute test, or both.– For the purposes of enforcement testing, DOE would reserve theright to use either test or both tests.– DOE also proposes to clarify that the results from the different testsmust be within 2 percent of each other, otherwise DOE will rely onthe 12-hour test to determine compliance.Unstable Power Measurement MethodTest Methods and Measurements46 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govRequest for Comment on Test Procedure WaiversItem 9DOE seeks comment on whether a method in which the clocktime on conventional cooking products would be set to 3:23 prior to a10-minute stabilization period, followed by a 10-minute measurementperiod commencing at 3:33 would be an acceptable alternative to themethod that DOE is proposing (i.e.,a 10-minute initial stabilizationperiod, after which the clock would be set to 3:23 and another 10-minute stabilization period providedbefore a 10-minute measurementstarting at a clock time of 3:33).DOE also requests comment on itsproposed approach requiring resultsunder the 12-hour test and the 10-minute test to be within 2 percentof each other and welcomes datawhich would show that some other range is more appropriate.Test Methods and Measurements47 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govTest Procedure Overview and Issues1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First Edition)for Measuring Standby Mode and Off Mode Power Consumption3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements forStandby Mode and Off Mode Testing5. Calculation of Energy Use Associated with Standby Mode and OffMode6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide andENERGY STAR48 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•Energy use for dishwashers is expressed as average annualenergy use and total energy used per dishwasher cycle.•DOE is proposing to incorporate standby and off mode energy useinto the calculation of estimated annual energy use as required bythe EISA 2007 amendments to EPCA.– Therefore, DOE has examined standby and off mode energyconsumption in terms of annual energy use, expressed in kWh peryear.•The current DOE test procedure already incorporates a calculationof annual standby energy consumption.– DOE proposes to maintain the current calculation of active modehours per year, based on the average wash cycle time multiplied by215 cycles per year, and to distribute the non-active mode hoursbetween the appropriate standby and off modes.Calculation of Operating Mode Energy – DishwashersCalculation of Energy Use49 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•In the November 2007 ANOPR, DOE estimated the length of atypical dishwasher cycle as one hour.– The test procedure assumes 215 dishwasher cycles per year;therefore DOE estimates 215 active mode hours per year.•Using very limited consumer usage data, DOE developed thefollowing estimates for the time allocated to the non-active modes.•The typical power values are averages based on DOE testing of14 dishwashers.– Active mode energy use estimated for 0.65 EF dishwasher.Calculation of Operating Mode Energy – DishwashersCalculation of Energy UseModeHoursTypical Power(W)Annual EnergyUse (kWh)Active2151,540331.10Delay Start261.910.05Cycle Finished2371.560.37Off and Inactive8,2820 to 0.690 to 5.7150 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•As previously discussed, DOE believes that delay start would beconsidered a part of active mode.– Therefore, DOE is not proposing to define or measure energyconsumption associated with a delay start mode.•As shown on the previous slide,the power levels in delay startmode are comparable to those of off/inactive modes.– DOE is proposing to allocate delay start mode hours to the inactiveand off modes, increasing the total time spent in these modes to8,308 hours per year.•For dishwashers without a cycle finished mode, DOE is proposingto allocate the 237 cycle finished mode hours to off/inactive mode.•DOE believes few dishwashers are capable of both off andinactive modes– If both modes are possible (electronic controls plus a mechanicaloff switch), the off/inactive hours would be split between the twomodes.Calculation of Operating Mode Energy – DishwashersCalculation of Energy Use51 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•In conclusion, DOE is proposing to calculate dishwasher annualenergy use associated with the inactive, off, and cycle finishedmodes by:1. Calculating the product of wattage and allocated hours for allpossible 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 modesshows that cycle finished mode represents a relatively smallnumber of annual hours at a low power level.– DOE could adopt a test procedure that would allocate cyclefinished mode hours to the off/inactive modes.– In that case, all non-active hours would be allocated to inactive oroff mode.Calculation of Energy UseCalculation of Operating Mode Energy – Dishwashers52 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•Energy use for dehumidifiers is expressed as energy factor (EF),which is the ratio of liters of water removed from the air per kWh.•DOE is proposing to incorporate standby and off mode energy useinto this metric based on the number of hours a typicaldehumidifier spends in each mode.– DOE found only limited data on typical dehumidifier active modeoperation from the Association of Home Appliance Manufacturers(AHAM), Arthur D. Little, ENERGY STAR, and Lawrence BerkeleyNational Laboratory.– These studies provide a range of estimates for active modeoperation, from 875 to 4,320 annual hours.•DOE is proposing 1,095 annual active mode hours based onAHAM’s mid-estimate.Calculation of Operating Mode Energy – DehumidifiersCalculation of Energy Use53 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE is aware that a dehumidifier may be unplugged for a certainpercentage of the time, and would not be in either standby or offmode.– DOE has no data regarding the typical time a dehumidifier isunplugged, however the survey data for active mode operationindicate no active mode operation from November to March, andfewer active mode hours in April.– DOE estimates that dehumidifiers would typically be unplugged forthis time period.•DOE is proposing 3,984 annual unplugged hours, based on theperiod from November to March, and half of April.•This leaves 3,681 hours to be allocated to the other operatingmodes (8,760 – 1,095 – 3,984).Calculation of Operating Mode Energy – DehumidifiersCalculation of Energy Use54 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE estimated the typical hours spent in bucket full/removed modeand delay start mode.– Bucket full/removed mode hoursbased on 25.01 – 35 pints/daycapacity (the predominant dehumidifierproduct class) operating at 1.35EF with a typical bucket size of18.7 pints, and the assumption thatconsumers will not typically empty thecollection bucketmore than onceper day.– Delay start mode hours based on 19%of products offering this feature,and estimated consumer use of this feature for50% of these units on10% of the 199 dehumidifying daysper year with an average delaysetting of 12 hours (half of the maximum delay start time typicallyavailable).*The NOPR incorrectly stated that 1.35 EF is the current Federal standard for this productclass. In fact, standards at this level will not go into effect until October 1,2012, and thecurrent standard is 1.2 EF. However, the numberof bucket full/removed hours calculated isnot affected, since the calculation of annual liters ofwater removed in thenotice is correct.Calculation of Operating Mode Energy – DehumidifiersCalculation of Energy Use55 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE estimated the typical hours spent in delay start mode andbucket full/removed mode.•Typical power values for the non-active modes are based on DOEtesting of 13 dehumidifiers.– Active mode typical power based on the analysis in the November2007 ANOPR.•The following table shows the estimated time spent in each mode,and the associated annual energy use.Calculation of Operating Mode Energy – DehumidifiersCalculation of Energy UseModeHoursTypical Power(W)Annual EnergyUse (kWh)Active1,095493540Delay Start231.540.04Bucket Full/Removed6571.631.07Off-Cycle/Inactive/Off3,0010 to 1.040 to 3.1256 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•As previously discussed, DOE believes that delay start would beconsidered a part of active mode.– Therefore, DOE is not proposing to define or measure energyconsumption associated with a delay start mode.•As shown on the previous slide,the power levels in delay startmode are comparable to those of off-cycle/inactive/off modes.– DOE is proposing to allocate delay start mode hours to the offcycle, inactive, and off modes, increasing the total time spent inthese modes to 3,024 hours per year.•DOE is aware that most dehumidifiers will not be capable ofoperating 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 modehours be split evenly among which of these modes is possible for acertain dehumidifier model.Calculation of Operating Mode Energy – DehumidifiersCalculation of Energy Use57 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•In summary, DOE is proposing to calculate dehumidifier annualenergy use associated with standby and off modes by:1. Calculating the product of wattage and allocated hours for allpossible 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 modesshows that dehumidifiers currently on the market have bucketfull/removed power levels that are comparable to those for offcycle/inactive/off modes.– DOE could adopt a test procedure that would allocate bucketfull/removed mode hours to the off-cycle/inactive/off modes.– In that case, all non-active hours would be allocated to offcycle/inactive/off modes.Calculation of Energy UseCalculation of Operating Mode Energy – Dehumidifiers58 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•Energy use for conventional cooking products is expressed asenergy factor (EF), which is the ratio of annual cooking energyoutput to the annual energy input.•DOE is proposing to incorporate standby and off mode energyconsumption into this metric, as required by EISA 2007.– DOE analyzed data on the usage patterns and power consumptionin these modes on an annual basis for each product class ofconventional cooking products.Calculation of Operating Mode Energy –Conventional Cooking ProductsCalculation of Energy Use59 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE investigated the typical operating time and energyconsumption associated with inactive, Sabbath, delay start, cyclefinished, off, and active modes for conventional ovens.•The typical times spent in each mode are based on limitedavailable consumer use data, and DOE’s best estimates.•Typical power values are based on DOE testing of 12 conventionalovens; active mode typical power is based on a baselineefficiency model electric self-cleaning oven.Calculation of Operating Mode Energy – Conventional OvensCalculation of Energy UseModeHoursTypical Power(W)Annual EnergyUse (kWh)Active211810171.0Sabbath8.97.590.068Delay Start615.350.33Cycle Finished181.750.032Off/Inactive8,461.10 to 3.800 to 32.1560 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•As previously discussed, DOE is not proposing to define ormeasure energy consumption for delay start mode or Sabbathmode.– DOE is proposing to allocate the delay start mode hours to theinactive and off modes (for a total of 8,522.1 hours), and to allocatethe Sabbath mode hours to active mode (for a total of 219.9 hours).•For conventional ovens without acycle finished mode, DOE isproposing to allocate the cycle finished mode hours to off/inactivemode.•DOE believes few conventional ovens are capable of both off andinactive modes– If both modes are possible (electronic controls plus a mechanicaloff switch), the off/inactive hours would be split between the twomodes.Calculation of Energy UseCalculation of Operating Mode Energy – Conventional Ovens61 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•In summary, DOE is proposing to calculate conventional ovenannual energy use associated with standby and off modes by:1. Calculating the product of wattage and allocated hours for allpossible 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 modesshows that conventional ovens currently on the market have cyclefinished power levels that are comparable to those for off/inactivemodes.– DOE could adopt a test procedure that would allocate cyclefinished mode hours to the off/inactive modes.– In that case, all non-active hours would be allocated to off/inactivemodes.Calculation of Energy UseCalculation of Operating Mode Energy – Conventional Ovens62 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE investigated the typical operating time and energyconsumption associated with inactive, Sabbath, off, and activemodes for conventional cooktops.•The typical times spent in these modes are based on limitedconsumer usage data, and DOE’s estimates.•Typical power values are based on DOE testing of 8 conventionalcooktops; active mode typical power is based on a baselineefficiency model electric smooth cooktop.Calculation of Operating Mode Energy – Conventional CooktopsCalculation of Energy UseModeHoursTypicalPower (W)Annual EnergyUse (kWh)Active211608128.2Sabbath2.11520.33Off/Inactive8,546.90 to 3.130 to 26.7363 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•As previously discussed, DOE is not proposing to define ormeasure energy consumption for Sabbath mode.– Sabbath mode hours would be allocated to the active mode.•DOE believes few conventional cooktops are capable of both offand inactive modes– If both modes are possible (electronic controls plus a mechanicaloff switch), the off/inactive hours would be split between the twomodes.•In summary, DOE is proposing to calculate conventional ovenannual energy use associated with standby and off modes by:1. Calculating the product of wattage and allocated hours for allpossible standby and off modes;2. Summing the results; and3. Dividing the sum by 1,000 to convert from Wh to kWh.Calculation of Energy UseCalculation of Operating Mode Energy – Conventional Cooktops64 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE investigated the typical operating time and energyconsumption associated with inactive, Sabbath, delay start, cyclefinished, off, and active modes for conventional ranges.•The typical times spent in each mode are based on limitedavailable consumer use data, and DOE’s best estimates.•Typical power values are based on DOE testing of 21 conventionalranges; active mode typical power is based on the sum of thetypical power levels for conventional ovens and cooktops.Calculation of Operating Mode Energy – Conventional RangesCalculation of Energy UseModeHoursTypical Power(W)Annual EnergyUse (kWh)Active422709299.2Sabbath8.83.720.033Delay Start502.950.148Cycle Finished182.520.045Off/Inactive8,261.20 to 2.680 to 22.1465 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•As previously discussed, DOE is not proposing to define ormeasure energy consumption for delay start mode or Sabbathmode.– DOE is proposing to allocate the delay start mode hours to theinactive and off modes, and to allocate the Sabbath mode hours toactive mode.•For conventional ranges without a cycle finished mode, DOE isproposing to allocate the cycle finished mode hours to off/inactivemode.•DOE believes few conventional ranges are capable of both off andinactive modes– If both modes are possible (electronic controls plus a mechanicaloff switch), the off/inactive hours would be split between the twomodes.Calculation of Energy UseCalculation of Operating Mode Energy – Conventional Ranges66 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•In summary, DOE is proposing to calculate conventional rangeannual energy use associated with standby and off modes by:1. Calculating the product of wattage and allocated hours for allpossible 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 modesshows that conventional ranges currently on the market havecycle finished power levels that are comparable to those foroff/inactive modes.– DOE could adopt a test procedure that would allocate cyclefinished mode hours to the off/inactive modes.– In that case, all non-active hours would be allocated to off/inactivemodes.Calculation of Energy UseCalculation of Operating Mode Energy – Conventional Ranges67 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govRequest for Comment on Energy Use CalculationsItem 10DOE invites comment on the approach for calculating totalenergy use for standby mode andoff mode for dishwashers,dehumidifiers, and conventional cooking products. DOE also invitescomment on the allocation of annualhours and test burden, as well asthe alternative methodology for allocation of annual hours for eachproduct.Calculation of Energy Use68 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govTest Procedure Overview and Issues1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First Edition)for Measuring Standby Mode and Off Mode Power Consumption3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements forStandby Mode and Off Mode Testing5. Calculation of Energy Use Associated with Standby Mode and OffMode6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide andENERGY STAR69 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•EPCA directs that test procedures shall be amended to includestandby and off mode energy consumption in the overall energyefficiency descriptor for each covered product. 42 U.S.C.6295(gg)(2)(A)– DOE examined whether the existing measures of energyconsumption for dishwashers, dehumidifiers, and conventionalcooking products can be combined with standby mode and offmode energy use to form a single metric.– DOE notes that the dishwasher and conventional cooking producttest procedures already incorporate some form of standby powerconsumption into the overall efficiency metrics (standby power fordishwashers, and clock power for conventional cooking products).•The following slides discuss howthe existing measures of energyconsumption will be combined withstandby and off mode energyuse for each product.Measures of Energy ConsumptionMeasures of Energy Consumption70 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE notes that the current dishwasher test procedure includes ameasure of standby power into the overall energy efficiencydescriptor, the estimated annual energy use (EAEU).– DOE also notes that the standby mode and off mode energy use isof a magnitude that it would materially affect that standard-settingprocess without overwhelming the effects of differing levels ofactive mode energy use.•DOE is proposing amendments to the test procedure that wouldfully account for standby mode and off mode energyconsumption for dishwashers.•The proposed amendments would require measuring anadditional standby mode (cycle finished mode), as well as offmode, and would revise the definition of standby mode in theexisting test procedure.Measures of Energy ConsumptionMeasures of Energy Consumption – Dishwashers71 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•The inactive, off , and cycle finished modes measured under theproposed test procedure may result in energy consumption levelsslightly higher than the current test procedure.– The proposed amendments would clarify that provisions related tothe new measures of energy consumption in standby mode and offmode would not be required to be used by manufacturers until thecompliance date of any amended dishwasher standardsaddressing standby mode and off mode energy use.•DOE is also proposing to amend the estimated annual operatingcost calculation to incorporate the revised standby and off modeenergy consumption.•DOE is not proposing to amend the calculation of EF in thecurrent dishwasher test procedure.•DOE is also proposing to include rounding instructions for thefinal values of EF, EAEU, and water consumption per cycle.Measures of Energy ConsumptionMeasures of Energy Consumption – Dishwashers72 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•The DOE dehumidifier test procedure only accounts for activemode energy consumption in the calculation of EF.– EF is calculated based on the liters of water removed from the airper kWh consumed, over a 24-hour test cycle.– As with dishwashers, the standby mode and off mode energy useis of a magnitude that it would materially affect that standardsetting process without overwhelming the effects of differing levelsof active mode energy use.•DOE is proposing to incorporate standby and off mode energyuse into a new overall efficiency metric for dehumidifiers, theintegrated energy factor (IEF).– The energy use would be allocated based on the ratio of annualactive mode hours to annual standby and off mode hours.Measures of Energy ConsumptionMeasures of Energy Consumption – Dehumidifiers73 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•The formula for calculating IEF is shown below.IEF = LW/ (Eactive+ ((ETSO× 24) / hactive))Where:LW= water removed from the air during dehumidifier energy factor test,in liters.Eactive= active mode energy consumption over the active mode testcycle, in kWh.ETSO= standby mode and off mode annual energy consumption, inkWh per year (determined as the standby and off mode measuredpower multiplied by the standby and off mode hours per year).24 = hours per day.hactive= annual active mode hours, 1,095.•DOE is proposing to round the final IEF value to two decimalplaces.Measures of Energy ConsumptionMeasures of Energy Consumption – Dehumidifiers74 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•The DOE test procedures for conventional cooking productsprovide calculations for various energy consumptions and EF.– Including: test energy consumption, annual cooking energyconsumption, annual pilot light energy consumption, annual selfcleaning energy consumption, annual clock energy consumption,and total annual energy consumption.•There are no current performance-based energy conservationstandards for conventional cooking products.– DOE’s rulemaking analyses have used EF as the relevant energyconservation metric.•Because these test procedures already account for narrow formsof energy use, DOE believes including standby and off modeenergy consumption would result in a meaningful metric.Measures of Energy ConsumptionMeasures of Energy Consumption –Conventional Cooking Products75 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•For conventional ovens, DOE proposes:– Electric ovens – “Integrated annual energy consumption” as thesum of the annual standby and off mode energy consumption, andthe annual primary cooking and self-cleaning energy consumption.– Gas ovens – “Integrated annual electrical energy consumption” asthe sum of the annual standby and off mode energy consumption,and the annual secondary cooking and self-cleaning energyconsumption.– “Integrated Energy Factor” (IEF) –• Electric ovens – annual useful cooking energy outputdivided by theintegrated annual energy consumption.• Gas ovens – annual useful cooking energy output divided by the sumof the annual gas energy consumption and the integrated annualelectrical energy consumption.– DOE proposes similar metrics for multiple conventional ovens.Measures of Energy ConsumptionMeasures of Energy Consumption – Conventional Ovens76 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•For conventional cooktops, DOE proposes:– Electric cooktops – “Integrated annual energy consumption” as theannual standby and off mode energyconsumption plus the annualuseful cooking energy output divided by the conventional cooktopcooking efficiency.– Gas cooktops – “Integrated annual electrical energy consumption”as the sum of the annual standby and off mode energyconsumption, the annual energy consumption for cooking, and theannual energy consumption of the gas standing pilot light.– “Integrated Energy Factor” (IEF) –• Electric cooktops – annual usefulcooking energy output divided by theintegrated annual energy consumption.• Gas cooktops – annual useful cooking energy outputdivided by theintegrated annual energy consumption.Measures of Energy ConsumptionMeasures of Energy Consumption – Conventional Cooktops77 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•For conventional ranges, DOE proposes:– “Integrated annual energy consumption” as the sum of the annualcooking energy consumption of each of its components (oven andcooktop) plus the conventionalrange annual standby mode and offmode energy consumption.– “Integrated Energy Factor” (IEF) as the sum of the annual usefulcooking energy output of each component divided by the sum ofthe integrated annual energy consumption of each component.•For all conventional cooking products, DOE is proposing toamend the annual energy cost calculations in 10 CFR part 430.23.•DOE also proposes to maintain the instructions for rounding theannual operating cost to the nearest dollar, and to includeinstructions for rounding the final IEF values to three significantdigits.Measures of Energy ConsumptionMeasures of Energy Consumption – Conventional Ranges78 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govRequest for Comment on Energy Use CalculationsItem 11DOE invites comment on the proposed plan to establish new“integrated energy factor” metricsfor dehumidifiers and conventionalcooking products. DOE also invites comment on the proposedamendments to modify the existing “estimated annual energy use” and“estimated annual operating cost” metrics for dishwashers toincorporate the revised measurements of standby mode and off modeenergy consumption.Measures of Energy Consumption79 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govTest Procedure Overview and Issues1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First Edition)for Measuring Standby Mode and Off Mode Power Consumption3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements forStandby Mode and Off Mode Testing5. Calculation of Energy Use Associated with Standby Mode and OffMode6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide andENERGY STAR80 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•EPCA requires that “[a]ny test procedures prescribed or amendedunder this section shall be reasonably designed to produce testresults which measure energy efficiency, energy use . . . orestimated annual operating cost of a covered product during arepresentative average use cycle or period of use . . . and shall notbe unduly burdensome to conduct.” (42 U.S.C. 6293(b)(3))•DOE believes the proposed amendments regarding standby and offmode energy consumption satisfy this requirement because:– IEC Standard 62301 is internationally accepted to measure power instandby and off mode, and will produce power consumptionmeasurements that are representative of an average use cycle.– The proposed test methods and associated equipment would notrequire manufacturers to make a major investment in test facilitiesand new equipment.Test BurdenCompliance with Other EPCARequirements81 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•EPCA also directs DOE to consider IEC Standard 62087 “Methodsof measurement for the power consumption of audio, video, andrelated equipment” when amending test procedures to includestandby mode and off mode power measurements.– As previously discussed, DOE determined that this standard is notapplicable to measuring power consumption of electrical appliancessuch as dishwashers, dehumidifiers, and conventional cookingproducts.Potential Incorporation of IEC Standard 62087Compliance with Other EPCARequirements82 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•Section 325(gg)(2)(A) of EPCA requires that standby mode and offmode energy consumption be “integrated into the overall energyefficiency, energy consumption, or other energy descriptor foreach covered product” unless the current test procedures alreadyfully account for the standby mode and off mode energyconsumption, or if such an integrated test procedure is technicallyinfeasible. (42 U.S.C. 6295(gg)(2)(A))•DOE proposes to incorporate standby and off mode power:– For dishwashers, into the “estimated annual energy use (EAEU)”and “estimated annual operating cost (EAOC).”– For dehumidifiers, into the new “integrated energy factor.”– For conventional cooking products, into an “integrated annualenergy consumption” and an “integrated energy factor.”Integration of Standby and Off Mode Energy ConsumptionCompliance with Other EPCARequirements83 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•EPCA also requires that test procedure amendmentsincorporating standby and off mode energy consumption will notdetermine compliance with previously established standards. (42U.S.C. 6295(gg)(2)(C))– As previously discussed, DOE expects the EAEU and EAOC fordishwashers would not be significantly affected by the proposedamendments.• Additionally, the proposed amendmentswould clarify that they are notrequired to determine compliance with the current energy conservationstandard.– For dehumidifiers, the existing standards are based on EF, whichwill not be altered by the proposed amendments for calculating theIEF.– There are no current performance-based Federal energyconservation standards for conventional cooking products(including energy use in the standby and off modes).Impact of Test Procedure Amendments on Existing StandardsCompliance with Other EPCARequirements84 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govTest Procedure Overview and Issues1. Products Covered by The Proposed Amendments2. Incorporation by Reference of IEC Standard 62301 (First Edition)for Measuring Standby Mode and Off Mode Power Consumption3. Determination and Classification of Operational Modes4. Specifications for the Test Methods and Measurements forStandby Mode and Off Mode Testing5. Calculation of Energy Use Associated with Standby Mode and OffMode6. Measures of Energy Consumption7. Compliance with Other EPCA Requirements8. Impact of the Proposed Amendments on EnergyGuide andENERGY STAR85 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.gov•DOE considered potential impacts of the proposed test procedureamendments to the FTC EnergyGuide requirements and to theENERGY STAR program requirements, and determined that therewill be no impact.– For dishwashers, DOE concluded that the relevant metrics, EAEU,EAOC, and water consumption, would not be affected by theproposed amendments.– For dehumidifiers, there are currently no EnergyGuide labelingrequirements, and the ENERGY STAR program is based on EF,which would not be affected by the proposed amendments.– For conventional cooking products, there are currently no FTCEnergyGuide or ENERGY STAR requirements.Impact on EnergyGuide and ENERGY STARImpact of the Proposed Amendments86 | Test Procedure for Dishwashers, Dehumidifiers, and Conventional Cooking Productseere.energy.govPublic Meeting– oral comments will be captured in the transcript andbecome part of the public record.Written comments– NOPR comment period open until 75 days afterpublication in theFederal RegisterReference docket #: EERE-2010-BT-TP-0039 and/or RIN #: 1904-AC27Email:Res-DW-Dehumid-CookingProd-2010-TP-0039@ee.doe.govMail: Mrs. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program1000 Independence Avenue, SW, Mailstop EE-2JWashington, DC 20585-0121Courier: Mrs. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program950 L'Enfant Plaza, 6th FloorWashington, DC 20024Telephone: (202) 586-2945How to Submit Comments...Closing