1 | Test Procedure for Residential Clothes Washers eere.energy.gov The Parker Ranch installation in Hawaii Test Procedure for Residential Clothes Washers



## Notice of Proposed Rulemaking Public Meeting Stephen Witkowski Department of Energy Energy Efficiency & Renewable Energy Email: stephen.witkowski@ee.doe.gov October 28, 20102 | Test Procedure for Residential Clothes Washers eere.energy.gov • NOPR issued by DOE on September 21, 2010 • NOPR public meeting today, October 28, 2010 • Comments on NOPR from interested parties

– Transcript records oral comments from today’s public meeting

– Written comments: DOE will accept comments, data, and information regarding the NOPR no later than December 6, 2010 • DOE reviews and considers all comments • Final Rule Publication 

### Steps in the Residential Clothes Washer Test Procedure Rulemaking 

## Introduction Final Rule NOPR3 | Test Procedure for Residential Clothes Washers eere.energy.gov 1. Products Covered by This Test Procedure Change 2. Compliance Date of Proposed Test Procedure 3. Standby, Off Mode, and Additional Active Mode Test Procedures a) Incorporating by Reference of IEC Standard 62301 for Measuring Standby Mode and Off Mode Power Consumption b) Determination of Modes to Be Incorporated c) Adding Specifications for the Test Methods and Measurements for Standby Mode, Off Mode, and Additional Active Mode Testing d) Calculation of Energy Use Associated with Each Operating Mode e) Measures of Energy Efficiency 

### Test Procedure Overview and Issues 

## Introduction4 | Test Procedure for Residential Clothes Washers eere.energy.gov 4. Clothes Washer Active Mode Test Procedure a) Technologies Not Covered by the Current Clothes Washer Test Procedure b) Changes to Reflect Current Usage Patterns and Capabilities c) Test Cloth d) Other Revisions and Clarifications e) Test Procedure Performance Specifications 5. Compliance with Other EPCA Requirements 6. Impact of the Proposed Amendments on EnergyGuide and ENERGY STAR 7. Elimination of the Obsolete Clothes Washer Test Procedure 

### Test Procedure Overview and Issues 

## Introduction5 | Test Procedure for Residential Clothes Washers eere.energy.gov • A Test Procedure Final Rule on August 27, 1997 (62 FR 45508) established the current test procedure in Appendix J1.

– Since 1997, DOE has amended the Appendix J1 test procedure three times, twice substantively and once to correct the introductory note. • The Energy Independence and Security Act of 2007 (EISA 2007) Amendments to EPCA direct DOE to integrate measures of standby and off mode energy consumption into the overall energy efficiency, energy consumption, or other energy descriptor. • On August 28, 2009, DOE published an announcement in the **Federal Register**  on the availability of a framework document to initiate a energy conservation standards rulemaking for residential clothes washers. (August 2009 framework document, 74 FR 44306)

– DOE received multiple comments stating it should consider changes to the active mode test procedure, in addition to accounting for energy consumption in standby and off modes. 

### Regulatory History 

## Introduction6 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Test Procedure Overview and Issues 1. Products Covered by This Test Procedure Change 2. Compliance Date of Proposed Test Procedure 3. Standby, Off Mode, and Additional Active Mode Test Procedures a) Incorporating by Reference of IEC Standard 62301 for Measuring Standby Mode and Off Mode Power Consumption b) Determination of Modes to Be Incorporated c) Adding Specifications for the Test Methods and Measurements for Standby Mode, Off Mode, and Additional Active Mode Testing d) Calculation of Energy Use Associated with Each Operating Mode e) Measures of Energy Efficiency7 | Test Procedure for Residential Clothes Washers eere.energy.gov • 10 CFR part 430.2 defines a clothes washer as “a consumer product designed to clean clothes using a water solution of soap and/or detergent and mechanical agitation or other movement, and must be one of the following classes: automatic clothes washers, semi automatic clothes washers, and other clothes washers.”

– DOE is not proposing any amendments to this definition, or to the definitions of automatic, semi - automatic, or other clothes washers provided in 10 CFR part 430.2. • The clothes washers covered by these definitions, and by today’s proposed test procedure, include top - loading compact (less than 1.6 ft3 capacity); top - loading standard size (1.6 ft 3 or greater capacity); top- loading semi -automatic; front- loading; and suds -saving clothes washers.



### Products Covered by this Test Procedure Rulemaking 

## Covered Products8 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Test Procedure Overview and Issues 1. Products Covered by This Test Procedure Change 2. Compliance Date of Proposed Test Procedure 3. Standby, Off Mode, and Additional Active Mode Test Procedures a) Incorporating by Reference of IEC Standard 62301 for Measuring Standby Mode and Off Mode Power Consumption b) Determination of Modes to Be Incorporated c) Adding Specifications for the Test Methods and Measurements for Standby Mode, Off Mode, and Additional Active Mode Testing d) Calculation of Energy Use Associated with Each Operating Mode e) Measures of Energy Efficiency9 | Test Procedure for Residential Clothes Washers eere.energy.gov • The effective date of the proposed new clothes washer test procedure would be 30 days after publication in the Federal Register of a final rule in this test procedure rulemaking.

– DOE’s test procedure regulations codified in the CFR would clarify that the current clothes washer test procedure in Appendix J1 would be used to determine compliance with energy conservation standards until the effective date of new standards that account for the new methods and measurements in the proposed Appendix J2 test procedure. 

### Compliance Date for the Test Procedure 

## Compliance Date10 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Test Procedure Overview and Issues 1. Products Covered by This Test Procedure Change 2. Compliance Date of Proposed Test Procedure 3. Standby, Off Mode, and Additional Active Mode Test Procedures a) Incorporating by Reference of IEC Standard 62301 for Measuring Standby Mode and Off Mode Power Consumption b) Determination of Modes to Be Incorporated c) Adding Specifications for the Test Methods and Measurements for Standby Mode, Off Mode, and Additional Active Mode Testing d) Calculation of Energy Use Associated with Each Operating Mode e) Measures of Energy Efficiency11 | Test Procedure for Residential Clothes Washers eere.energy.gov • EISA 2007 amended EPCA to require test procedure amendments regarding standby and off mode power to take into consideration the most current versions of IEC Standards 62301 and 62087.

– IEC Standard 62087 is not applicable to this rulemaking. • DOE proposes to incorporate into the test procedure all applicable provisions from Sections 4 and 5 of IEC Standard 62301 First Edition.

– From section 4, “General conditions for measurements”, which establishes conditions for repeatable and precise measurements: • 4.2 – “Test room” • 4.4 – “Supply voltage waveform” • 4.5 – “Power measurement accuracy”

– From section 5, “Measurements”, which provides methods for when the power measurement is either stable or unstable: • 5.1 – “General”, Note 1 • 5.3 – “Procedure” 

### IEC Standard 62301 and IEC Standard 62087 

## Incorporating IEC Standard 6230112 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE originally delayed this rulemaking beyond the EISA 2007 deadline of June 30, 2009 to consider a revised IEC Standard 62301 (Second Edition), expected to be released July 2009. • This updated Standard has since been delayed, with an expected publication date of April 2011.

– DOE proposes referencing the current IEC Standard 62301 for test procedures to expedite the process of incorporating standby and off mode power consumption into the clothes washer test procedure.

– DOE expects the provisions it proposes to include from the current IEC Standard 62301 to remain valid after the publishing of the Second Edition, based on review of a draft version of the updated standard, IEC Standard 62301 Committee Draft for Vote (CDV) as well as the Final Draft International Standard (FDIS) version. 

### Updated IEC Standard 62301 Ed. 2.0 

## Incorporating IEC Standard 6230113 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Incorporating IEC Standard 62301 

## Incorporating IEC Standard 62301

Item 1 DOE seeks comment on the adequacy of IEC Standard 62301 to measure standby and off mode power consumption for clothes washers in general, and on the suitability of incorporating the specified provisions into DOE regulations.14 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Test Procedure Overview and Issues 1. Products Covered by This Test Procedure Change 2. Compliance Date of Proposed Test Procedure 3. Standby, Off Mode, and Additional Active Mode Test Procedures a) Incorporating by Reference of IEC Standard 62301 for Measuring Standby Mode and Off Mode Power Consumption b) Determination of Modes to Be Incorporated c) Adding Specifications for the Test Methods and Measurements for Standby Mode, Off Mode, and Additional Active Mode Testing d) Calculation of Energy Use Associated with Each Operating Mode e) Measures of Energy Efficiency15 | Test Procedure for Residential Clothes Washers eere.energy.gov • The mode definitions provided in EPCA and in IEC Standard 62301 (First Edition) could lead to multiple interpretations.

– These definitions were developed to be broadly applicable for many energy- using products. • EPCA authorizes DOE to amend mode definitions, considering the most current versions of IEC Standards 62301 and 62087. • DOE expects the definitions provided in IEC Standard 62301 FDIS will remain relatively unchanged in the final revised IEC Standard 62301, Second Edition, and therefore considered these definitions as the most current when determining the mode definitions for the amended test procedure.

– DOE is proposing mode definitions based on the definitions provided in IEC Standard 62301 FDIS, with added clarifications specific to clothes washers. 

### Mode Definitions 

## Modes to Be Incorporated16 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE is proposing to define active mode as “a mode in which the clothes washer is connected to a mains power source; has been activated; and is performing one of the main functions of washing, soaking, tumbling, agitating, rinsing, and/or removing water from the clothing, or is involved in functions necessary for these main functions, such as admitting water into the washer or pumping water out of the washer. • DOE is proposing to refer to the typical clothes washing operation (i.e., a complete wash cycle intended for washing a clothing load, including washing, rinsing, and spinning) as the **active washing mode**. • DOE is proposing to define **delay start mode** as an active mode in which activation of the active washing mode is facilitated by a timer.

– Because delay start mode may not persist for an indefinite time, it would not be considered as part of standby mode based on the proposed definition (discussed later).

– Delay start mode also only occurs prior to operation in the active washing mode, and therefore should be considered a part of active mode. 

## Modes to Be Incorporated Active Mode – Active Washing and Delay Start17 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE is proposing to define **cycle finished mode** as an active mode that provides continuous status display following operation in the active washing mode.

– Operation in cycle finished mode occurs only after operation in the active washing mode, and therefore should be considered a part of active mode. • Some clothes washers currently available offer more features in cycle finished mode than a continuous status display, such as a low - power fan to circulate air or periodic tumbling.

– These functions would use more energy than the continuous display normally associated with cycle finished mode.

– DOE is not proposing to account for these additional cycle finished functions. • DOE believes the shipment -weighted percentage of clothes washers offering these additional functions is less than 5 percent. • DOE believes measuring the energy use associated with these functions would significantly increase the test cycle duration to capture an negligible contributor to annual energy consumption. 

## Modes to Be Incorporated Active Mode – Cycle Finished18 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE is proposing to define **self -** **clean mode** as an active clothes washer operating mode that is:

– Dedicated to cleaning, deodorizing, or sanitizing the clothes washer by eliminating sources of odor, bacteria, mold, and mildew;

– Recommended to be run intermittently by the manufacturer; and

– Separate from clothes washing cycles. • DOE is proposing to consider self-clean mode as a part of the active mode because it is a function necessary for the main functions associated with washing clothes.

– A clothes washer with excessive bacteria, mildew, or odor cannot effectively wash clothes. 

## Modes to Be Incorporated Active Mode – Self- Clean19 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE is proposing to define standby mode as “any mode in which the clothes washer is connected to a mains power source and offers one or more of the following user-oriented or protective functions which may persist for an indefinite time:

– To facilitate the activation of other modes (including activation or deactivation of active mode) by remote switch (including remote control), internal sensor, or timer;

– Continuous function: information or status displays (including clocks); or sensor- based functions.”
• The proposed amendments would clarify timer is a continuous clock function (which may or may not be associated with a display) that provides regular scheduled tasks ( **e.g.** , switching) and that operates on a continuous basis.
• DOE identified only one standby mode, **inactive mode**, that facilitates the activation of active mode by remote switch (including remote control), internal sensor, or timer, or that provides continuous status display. • If any energy is consumed by the appliance in the presence of a one -way remote control, the unit would be operating in standby mode under the proposed definition.
• DOE is proposing to amend the test procedure for clothes washers to include provisions for measuring energy use in inactive mode as the measurement of standby energy use, but remains open to consideration of additional standby modes. 

### Standby Mode 

## Modes to Be Incorporated20 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE is proposing to define off mode as “any mode in which the clothes washer is connected to a mains power source and is not providing any standby mode or active mode function, and where the mode may persist for an indefinite time. An indicator that only shows the user that the product is in the off position is included within the classification of an off mode.” • A clothes washer equipped with a mechanical on/off switch that can disconnect power to the display and/or control components would be considered as operating in the off mode when the switch is in the “off” position, provided that no other standby or active mode functions are energized. 

### Off Mode 

## Modes to Be Incorporated21 | Test Procedure for Residential Clothes Washers eere.energy.gov • IEC Standard 62301 FDIS defines network mode as:

– “any product modes where the energy using product is connected to a mains power source and at least one network function is activated (such as reactivation via network command or network integrity communication) 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 the energy using product are removed or interrupted.” • DOE is not proposing to incorporate either of these modes into the clothes washer test procedure.

– DOE is unaware of any clothes washers currently incorporating a networking function (discussed further in section 4.a).

– DOE believes that there would be no energy use in a disconnected mode, therefore testing in this mode would be irrelevant. 

### Modes not Included – Network & Disconnected 

## Modes to Be Incorporated22 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on the Proposed Mode Definitions 

## Modes to Be Incorporated

Item 2 DOE invites comment on the proposed establishment of inactive mode as the only standby mode for clothes washers and the determination that “delay start mode,” “cycle finished mode,” and “self clean mode” would be considered active modes. DOE further invites comment on the proposed mode definitions, including the definition of “self- clean” mode, and on the question of whether there are any modes consistent with the “active mode,” “standby mode,” or “off mode” definitions that have not been identified in this NOPR that represent significant energy use.23 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Test Procedure Overview and Issues 1. Products Covered by This Test Procedure Change 2. Compliance Date of Proposed Test Procedure 3. Standby, Off Mode, and Additional Active Mode Test Procedures a) Incorporating by Reference of IEC Standard 62301 for Measuring Standby Mode and Off Mode Power Consumption b) Determination of Modes to Be Incorporated c) Adding Specifications for the Test Methods and Measurements for Standby Mode, Off Mode, and Additional Active Mode Testing d) Calculation of Energy Use Associated with Each Operating Mode e) Measures of Energy Efficiency24 | Test Procedure for Residential Clothes Washers eere.energy.gov • Paragraph 5.3.1 of IEC Standard 62301 provides:

– If power is stable (varies by not more than 5% during a 5 minute period), wait 5 minutes for the product to stabilize, then measure the power at the end of an additional time period of at least 5 minutes.

– If power is unstable (varies by more than 5% during a 5 minute period), the power measurement shall be at least 5 minutes, or one or more complete operating cycles of several minutes or hours. • Manufacturers may choose a longer stabilization period, or a longer measurement period. • For clothes washers with displays that reduce power consumption by dimming after a certain period of user inactivity, DOE proposes that the standby, off, and cycle finished mode tests be conducted after the power level has dropped to its lowest level (IEC Standard 62301, paragraph 5.1, note 1.)

– DOE testing suggested that the typical higher- power state persists for less than 10 minutes of inactivity.

– It is possible that some clothes washers may remain in the higher- power state for the duration of the 5 - minute stabilization and 5 - minute test period. 

### Power Measurement Period 

## Test Methods and Measurements25 | Test Procedure for Residential Clothes Washers eere.energy.gov • **IEC Standard 62301 CDV** specifies a 30- minute stabilization period and 10- minute measurement.

– DOE believes this clarification would allow sufficient time for displays that automatically dim or power down to reach the lower- power state prior to measurement, so is proposing a 30 - minute stabilization period, then a power measurement of not less than 10 minutes for inactive, off, and cycle finished modes.

– Even if certain clothes washers allow for altering the display settings to increase the time period in the high - power state, DOE believes the typical consumer will maintain the default settings, and therefore is not proposing additional provisions to address the possibility of adjusting the default settings. • **IEC Standard 62301 FDIS** specifies:

– An overall test period not less than 15 minutes if the power consumption is not cyclic. • The first 5 minutes of data are discarded, and the remaining 10 minutes are used to determine whether the power is stable. • If stability is not achieved, the total period is extended until the stability criteria are met, up to 3 hours. • Modes with known varying power consumption must be tested for not less than 60 minutes.

– For cyclic power consumption, the stabilization period is10 minutes, and must be over 4 complete cycles, followed by a measurement period of at least 20 minutes. • DOE believes the specifications in IEC Standard 62301 FDIS would not produce power consumption measurements as accurate, repeatable, and enforceable as those provided in IEC Standard 62301 CDV. 

## Test Methods and Measurements Power Measurement Period26 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Default Settings 

## Test Methods and Measurements

Item 3 DOE welcomes comment on the suitability of using the default settings in testing standby energy consumption, and on any methodologies that can account for consumer actions that might increase energy use and data on the repeatability of such testing procedures.27 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE recognizes that power consumption from delay start mode may vary depending on the delay time, the time displayed, and/or display indication of mode status. • To ensure comparable and valid results, DOE proposes that the delay start time be set at 5 hours, and for power to be monitored for 60 minutes after waiting at least 5 minutes for power input to stabilize.

– In determining this specification, DOE concluded that the average number of LEDs lit for the range of all possible delay times would be best approximated by a 60 minute test if the delay time set at 5 hours. 

### Delay Start 

## Test Methods and Measurements28 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Delay Start Mode 

## Test Methods and Measurements
Item 4 DOE seeks comment on the methodology proposed for measuring energy consumption in delay start mode.29 | Test Procedure for Residential Clothes Washers eere.energy.gov • The current DOE test procedure specifies ambient air temperature only for water- heating clothes washers, 75 ± 5oF, which is within the range specified by IEC Standard 62301 (73.4 ± 9 ° F). • DOE proposes that test room ambient temperature for standby, off, delay start and cycle finished mode testing be specified for all clothes washers according to section 4, paragraph 4.2 of IEC Standard 62301.

– The proposed specification would allow manufacturers more latitude in maintaining ambient conditions if the tests for standby, off, delay start and cycle finished modes are conducted separately from active washing mode tests. 

### Test Room Ambient Temperature 

## Test Methods and Measurements30 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Clothes Washers – Test Room Ambient Temperature 

## Test Methods and Measurements
Item 5 DOE seeks comment on the appropriateness of the proposed modified test room ambient temperature range, which would allow manufacturers to conduct standby, off, delay start and cycle finished mode testing separately from active washing mode testing, under the less stringent ambient conditions specified in the IEC Standard 62301 (73.4 ± 9oF)31 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Test Procedure Overview and Issues 1. Products Covered by This Test Procedure Change 2. Compliance Date of Proposed Test Procedure 3. Standby, Off Mode, and Additional Active Mode Test Procedures a) Incorporating by Reference of IEC Standard 62301 for Measuring Standby Mode and Off Mode Power Consumption b) Determination of Modes to Be Incorporated c) Adding Specifications for the Test Methods and Measurements for Standby Mode, Off Mode, and Additional Active Mode Testing d) Calculation of Energy Use Associated with Each Operating Mode e) Measures of Energy Efficiency32 | Test Procedure for Residential Clothes Washers eere.energy.gov • Modified Energy Factor (MEF) [ft 3 of capacity per total energy consumption per wash cycle includes: 1. machine energy consumption directly measured during the test cycles 2. nominal energy used by a water heater to heat the water supplied to the clothes washer 3. energy used by a dryer to remove the remaining moisture after a cycle. • DOE proposes that the calculation of energy consumption in the modes other than active washing mode be expressed on a per cycle basis as well to maintain consistency. • The total energy consumption in standby, off, delay start, and cycle finished modes depends on both the power level of the mode and the time spent in the mode. 

### Calculation of Energy Use Associated with Each Operating Mode 

## Calculation of Energy Use33 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE proposes to allocate 1 hour per cycle for a typical active washing mode, based on four available studies.

– Average cycle times can vary based on the axis of basket rotation and type of load; however DOE is proposing one overall cycle time to simplify calculations, and because this value has a small effect on results. • For example, using 45 minutes per cycle for top - loaders and 75 minutes per cycle for front - loaders changes the final number of hours allocated to the other modes by less than 1 percent. • DOE is proposing to revise the representative number of active wash cycles per year from 392 to 295, resulting in 295 active washing mode hours per year. 

### Active Washing Mode Hours Per Year 

## Calculation of Energy Use34 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE believes clothes washers use energy in five modes other than active washing modes in which residential clothes washers use energy: (1) inactive mode, (2) cycle finished mode, (3) delay start mode, (4) off mode, and (5) self-clean mode. • Based on limited studies of the time clothes washers spend in each of these non -active washing modes, DOE testing, and manufacturer recommendations, DOE estimates the following usage for each of these modes: 

### Hours Per Year Associated with Non -Active Washing Modes 

## Calculation of Energy Use

Mode Annual Duration Estimate Basis Delay Start 25 hours 5 min per active washing cycle Cycle Finished 15 hours 3 min per active washing cycle Self- Clean 16 hours 1.3 hours per cycle, 12 cycles per year Off/Inactive 8,409 hours Remainder35 | Test Procedure for Residential Clothes Washers eere.energy.gov • Power ranges for the different non -active washing modes are based on internal DOE testing of clothes washers. The highest and lowest average powers are listed for both top- and front- loading clothes washers.

* Per- cycle energy use determined from a 2006 study that referenced data provided in 2005 by the Association of Home Appliance Manufacturers and Whirlpool Corporation. ** Remaining time = 8,760

– 295 **−** 16 **−** 25 **−** 15 = 8,409. † Includes energy consumption for water heating and moisture removal in the dryer as well as machine electrical energy consumption. † † Based on DOE testing of seven units with self - clean cycles, and 12 cycles per year. Values include energy consumption for water heating and machine electrical energy consumption . 

## Calculation of Energy Use

Mode Hours Typical Average Power (W) Annual Energy Use ( kWh) Active Washing 295* 2,230 657.9 † Self- Clean 16 75 to 2,081 1.2 to 33.3 †† Delay Start 25 1.4 to 8.9 0.04 to 0.2 Cycle Finished 15 0 to 5.2 0 to 0.08 Off and Inactive 8,409 ** 0 to 1.7 0 to 14.3 

### Estimated Annual Energy Use Associated with Each Operating Mode36 | Test Procedure for Residential Clothes Washers eere.energy.gov • Not all residential clothes washers will utilize all possible modes. • The table below shows the proposed allocation of annual hours for clothes washers offering different combinations of modes. 

## Calculation of Energy Use Hours Per Year Associated with All Operating Modes

Mode All Modes Possible No Delay Start Mode No Cycle Finished Mode No Delay Start or Cycle Finished Modes **No Self**  **- Clean Available**  Active Washing 295 295 295 295 Delay Start 25 0 25 0 Cycle Finished 15 15 0 0 Off and Inactive 8,425 8,450 8,440 8,465 **Self -** **Clean Available** Active Washing 295 295 295 295 Self- Clean 16 16 16 16 Delay Start 25 0 25 0 Cycle Finished 15 15 0 0 Off and Inactive 8,409 8,434 8,424 8,44937 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE believes that the proposed definition of off mode refers to units with mechanical rather than electronic controls, or units with electronic controls equipped with a mechanical switch to deenergize the electronic controls.

– Reactivation of the clothes washer with a pushbutton sensor would be considered to be part of standby mode. • DOE expects there are few clothes washers with electronic controls and an additional mechanical off switch.

– Therefore, the combined inactive/off mode hours would most likely be allocated fully either to inactive or off mode, depending on the controls present on the clothes washer.

– For clothes washers with both electronic controls and a mechanical off switch, DOE is proposing to allocate half of the non - active hours each to inactive and off modes. 

### Hours Per Year Associated with Inactive and Off Modes 

## Calculation of Energy Use38 | Test Procedure for Residential Clothes Washers eere.energy.gov • In conclusion, DOE is proposing to calculate residential clothes washer energy use per cycle associated with the inactive, off, delay start and cycle finished modes by: 1. Calculating the product of wattage and allocated hours for all possible inactive, off, delay start and cycle finished modes; 2. Summing the results; 3. Dividing the sum by 1,000 to convert from Wh to kWh; and 4. Dividing by the proposed 295 use cycles per year. • DOE is also proposing to calculate energy use per cycle associated with self-clean mode, if available, by: 1. Multiplying the energy use per self - clean cycle in kWh by 12; and 2. Dividing by the proposed 295 use cycles per year. 

## Calculation of Energy Use Calculation of Energy Use Associated with Each Operating Mode39 | Test Procedure for Residential Clothes Washers eere.energy.gov • The comparison of annual energy use for the different clothes washer modes indicates that delay start and cycle finished modes represent a relatively small number of hours per year at low power consumption levels.

– The power consumptions observed in cycle finished mode and delay start mode are distinct from but comparable to those for inactive mode and off mode. • As a result, DOE could adopt an approach that would allocate all hours not associated with active washing mode or self-clean mode (8,449 or 8,465 for models with and without a self-clean cycle respectively) to the off and inactive modes. 

## Calculation of Energy Use Alternative Calculation of Energy Use Associated with Each Operating Mode40 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on the Energy Use Calculation for Each Operating Mode 

## Calculation of Energy Use
Item 6 DOE seeks comment on the approach for calculating energy use for the different operating modes observed in clothes washers. DOE also invites comment and requests data on the estimates for annual hours associated with each mode, including active mode. DOE also welcomes comment on whether the alternative energy use calculation would be representative of the standby and off mode power consumption of clothes washers currently on the market.41 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Test Procedure Overview and Issues 1. Products Covered by This Test Procedure Change 2. Compliance Date of Proposed Test Procedure 3. Standby, Off Mode, and Additional Active Mode Test Procedures a) Incorporating by Reference of IEC Standard 62301 for Measuring Standby Mode and Off Mode Power Consumption b) Determination of Modes to Be Incorporated c) Adding Specifications for the Test Methods and Measurements for Standby Mode, Off Mode, and Additional Active Mode Testing d) Calculation of Energy Use Associated with Each Operating Mode e) Measures of Energy Efficiency42 | Test Procedure for Residential Clothes Washers eere.energy.gov • The test procedure provides a calculation for MEF, which determines compliance with the current Federal energy conservation standards.

– Equal to the clothes container capacity in ft 3 divided by the sum, expressed in kWh, of:

• the weighted per- cycle hot water energy consumption; • the weighted per- cycle machine electrical energy consumption; and • the per- cycle energy consumption for removing the remaining moisture from a test load in a dryer. • EPCA directs that test procedures shall be amended to include standby and off mode energy consumption in the overall energy efficiency descriptor for each covered product. 42 U.S.C. 6295(gg)(2)(A)

– DOE examined integrating standby and off mode energy consumption on a per- cycle basis. 

## Measures of Energy Efficiency Measures of Energy Efficiency43 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE proposes to establish the following measures of energy consumption for clothes washers:

– “per- cycle standby, off, delay start and cycle finished mode energy consumption,” expressed in kWh;

– “per- cycle self- clean mode energy consumption,” as applicable, expressed in kWh; and

– “integrated modified energy factor” (IMEF) as the clothes container capacity in ft 3 divided by the sum, in kWh, of:

• the total weighted per- cycle hot water energy consumption; • the total weighted per- cycle machine electrical energy consumption; • the per- cycle energy consumption for removing moisture from a test load; • the per- cycle standby, off, delay start and cycle finished mode energy consumption; • and the per- cycle self- clean mode energy consumption, as applicable. 

### Proposed New Measures of Energy Efficiency 

## Measures of Energy Efficiency44 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on the Proposed Measures of Energy Efficiency 

## Measures of Energy Efficiency
Item 7 DOE seeks comment on the proposed plan to establish new measures of energy consumption for clothes washers: “per- cycle standby, off, delay start and cycle finished mode energy consumption” expressed in kWh, and “per- cycle self- clean mode energy consumption” expressed in kWh; as well as a new integrated measure of energy efficiency : “integrated modified energy factor” expressed in ft3 

### per kWh per cycle.45 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE does not propose to amend the estimated annual operating cost calculation in 10 CFR 430.23 to include the cost of energy consumed by modes other than active washing mode because:

– DOE believes that the cost of energy consumed in self - clean, standby, off, delay start and cycle finished modes would make little difference in the estimated annual operating cost calculation; and

– The Federal Trade Commission’s (FTC’s) EnergyGuide Label for clothes washers compares the estimated annual operating cost to a range of annual operating costs of similar products. (Appendix F1 to 16 CFR part 305) An annual operating cost incorporating self- clean, standby, off, delay start and cycle finished mode energy would no longer be directly comparable to the minimum and maximum operating costs prescribed for the EnergyGuide Label. 

### Annual Energy Cost Calculation 

## Measures of Energy Efficiency46 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on the Proposed Approach to Not Amend Annual Energy Cost 

## Measures of Energy Efficiency

Item 8 DOE seeks comment on the tentative decision to maintain the existing annual energy cost calculation set forth in 10 CFR 430.23, which does not include self- clean, standby, off, delay start or cycle finished mode energy consumption. One alternative way of incorporating energy consumption in self- clean, standby, off, delay start, or cycle finished mode into the annual energy cost calculation would be to add the per- cycle energy consumption from these mode to the total per- cycle energy consumption in the annual operating cost calculations in 10 CFR 430.23 (j)(1)(i) and (ii).47 | Test Procedure for Residential Clothes Washers eere.energy.gov 4. Clothes Washer Active Mode Test Procedure a) Technologies Not Covered by the Current Clothes Washer Test Procedure b) Changes to Reflect Current Usage Patterns and Capabilities c) Test Cloth d) Other Revisions and Clarifications e) Test Procedure Performance Specifications 5. Compliance with Other EPCA Requirements 6. Impact of the Proposed Amendments on EnergyGuide and ENERGY STAR 7. Elimination of the Obsolete Clothes Washer Test Procedure 

### Test Procedure Overview48 | Test Procedure for Residential Clothes Washers eere.energy.gov • Many clothes washers available on the market offer a steam wash cycle, which is claimed to offer enhanced cleaning performance.

– The current test procedure contains no provisions for measuring energy and water consumption during a steam wash cycle. • In response to comments received on the August 2009 framework document, DOE is proposing to include specifications for measuring energy and water consumption during a steam wash cycle. • DOE is proposing to include a test section for steam wash cycles, and to include the energy and water consumption from steam wash cycles in the final calculations for the energy and water use metrics. 

### Steam Wash Cycles 

## Technologies Not Currently Covered49 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE is proposing to measure energy and water consumption of a steam wash cycle with the hottest wash temperature.

– DOE, therefore, is proposing to also update the temperature use factors provided in Table 4.1.1 of the test procedure to include a steam wash use factor for clothes washers offering this feature. • DOE lacks data on consumer usage of steam wash cycles, but believes the inclusion of a steam wash cycle would decrease the number of extra hot cycles a consumer would run, and would leave the hot, warm, and cold temperature use factors unchanged.

– DOE believes extra hot and steam cycles would be reserved for the most heavily soiled loads, with steam cycles selected somewhat less frequently.

– DOE is proposing 0.02 as the use factor for steam wash cycles, and to decrease the extra hot use factors by 0.02 (from 0.05 to 0.03 or 0.14 to 0.12). 

### Steam Wash Cycles 

## Technologies Not Currently Covered50 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Steam Wash Cycles 

## Technologies Not Currently Covered
Item 9 DOE requests comment on the proposed inclusion of the energy and water consumption of a steam wash cycle to the clothes washer test procedure, including the associated use factor. DOE also requests any data available regarding consumer use of steam wash cycles.51 | Test Procedure for Residential Clothes Washers eere.energy.gov • Many clothes washers currently on the market offer a self-clean cycle.

– Self- clean cycles may require high water temperatures and greater volumes of water than a normal cycle, potentially consuming a substantial amount of energy. • DOE is proposing to define a self-clean mode as an active clothes washer operating mode that is:

– Dedicated to cleaning, deodorizing, or sanitizing the clothes washer by eliminating sources of odor, bacteria, mold, and mildew;

– Recommended to be run intermittently by the manufacturer; and

– Separate from clothes washing cycles. • DOE is proposing to include energy and water consumption during self-clean cycles into the overall efficiency metrics.

– This would also benefit clothes washer designs that address mold and odor issues without the need for periodic self - clean cycles. 

### Self- Clean Cycles 

## Technologies Not Currently Covered52 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE is proposing to calculate the per-cycle energy and water consumption from self-clean cycles by:

– measuring the hot and cold water consumption and the electrical energy consumption for a self clean cycle;

– calculating the total energy consumption (water heating plus electrical energy consumption) and water consumption during a self clean cycle;

– multiplying the self- clean cycle energy and water consumption by the number of self- clean cycles per year (12)*; and

– dividing by the proposed 295 active washing cycles per year.* • This approach apportions the annual energy and water use in self- clean mode to each annual active washing mode cycle. • If a clothes washer is designed to address mold and odor problems without the need for periodic self-clean cycles, the per-cycle self-clean energy and water consumption will be zero. * The last two steps of this calculation for the water consumption were inadvertently not included in the NOPR. DOE intends to correct this omission in the final rule. 

### Self- Clean Cycles 

## Technologies Not Currently Covered53 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Self- Clean Cycles 

## Technologies Not Currently Covered
Item 10 DOE requests comment on self- clean cycles for clothes washers, including the proposed definition, inclusion of self- clean cycle energy and water use into the IMEF and IWF calculations, and on whether any relevant data are available regarding availability and consumer use of self- clean cycles.54 | Test Procedure for Residential Clothes Washers eere.energy.gov • Adaptive control technologies can adjust wash parameters based on the size, fabric mix, and soil level of a wash load.

– The current test procedure accounts for adaptive fill control, but no other adaptive controls. • DOE received multiple comments in response to the August 2009 framework document stating that adaptive controls are already widely used in residential clothes washers.

– DOE is not aware of any residential clothes washers that currently incorporate soil sensing systems.

– DOE is only aware of clothes washers that currently use adaptive controls to adjust to measured or inferred load size and fabric mix. • DOE lacks data on the distribution of load sizes and fabric mixes that are representative of typical consumer usage. • DOE is not proposing to account for adaptive controls, other than adaptive fill control, in the test procedure. 

### Adaptive Control Technologies 

## Technologies Not Currently Covered55 | Test Procedure for Residential Clothes Washers eere.energy.gov • Demand response technology enables an appliance to shift its activity based on interaction with the electric grid, utilities, or user programming.

– Appliances that can communicate though any network would be considered to have a network mode according to IEC Standard 62301 CDV. • At this time, DOE is unaware of any clothes washers currently available on the market that incorporate a networking function. • Therefore, DOE is not proposing to amend the clothes washer test procedure to include energy consumption in a network mode, or to quantify any benefits that may arise from peak load shedding through communication with a “smart grid.”

– Once clothes washers offering these features and the appropriate data and testing methodologies become available, these provisions could be incorporated through amendments to the test procedure. 

### Demand Response Technology 

## Technologies Not Currently Covered56 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Adaptive Controls and Demand Response Technology 

## Technologies Not Currently Covered

Item 11 DOE requests comment on whether any clothes washers are currently available on the market offering soil - sensing adaptive controls or demand response features. DOE also requests information on load size and fabric content, the possible use of a soiled test load to determine energy and water use in the presence of soil - sensing adaptive controls, appropriate methodologies for measuring energy consumption in a network mode, and on the repeatability of such testing.57 | Test Procedure for Residential Clothes Washers eere.energy.gov 4. Clothes Washer Active Mode Test Procedure a) Technologies Not Covered by the Current Clothes Washer Test Procedure b) Changes to Reflect Current Usage Patterns and Capabilities c) Test Cloth d) Other Revisions and Clarifications e) Test Procedure Performance Specifications 5. Compliance with Other EPCA Requirements 6. Impact of the Proposed Amendments on EnergyGuide and ENERGY STAR 7. Elimination of the Obsolete Clothes Washer Test Procedure 

### Test Procedure Overview58 | Test Procedure for Residential Clothes Washers eere.energy.gov • In the January 2001 Final Rule, 66 FR 3315, DOE estimated the representative number of annual wash cycles per clothes washer as 392.

– Comments were received in response to the August 2009 framework document in support of updating this value.

– This value is not used in the current test procedure calculations for MEF or WF. • DOE considered three data sources when determining if an updated representative number of annual wash cycles is warranted:

– the EIA’s 2005 Residential Energy Consumption Survey (2005 RECS);

– the California Energy Commission’s 2004 California Residential Appliance Saturation Survey (California RASS); and

– a data submittal from Procter and Gamble (P&G). • DOE estimated the following average annual use cycles from each of these data sources:

– 295 cycles per year from the 2005 RECS data;

– 283 cycles per year from the California RASS; and

– 308 cycles per year from the P&G data submittal. 

### Annual Cycles 

## Current Usage Patterns and Capabilities59 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE is proposing to update the representative number of annual use cycles to 295, based on the 2005 RECS data.

– DOE believes the 2005 RECS data are most representative of consumer use throughout the country.

– The California RASS only reflects the usage patterns of consumers in one state.

– Analysis of the P&G submittal showed that the data set contained fewer single - person households and more multiple - person households than indicated in the latest sampling by the U.S. Census Bureau and the American Housing Survey.

– Overall, the relatively small variation among the three data sources supports DOE’s conclusion that 295 cycles per year is a reasonable estimate of actual consumer use. 

### Representative Annual Cycles 

## Current Usage Patterns and Capabilities60 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Annual Cycles 

## Current Usage Patterns and Capabilities
Item 12 DOE welcomes comment on the appropriateness of the proposed 295 clothes washer cycles per year, and on the validity of using the 2005 RECS to establish this estimate. DOE also seeks any additional data available on this issue.61 | Test Procedure for Residential Clothes Washers eere.energy.gov • Table 5.1 of the current test procedure (Test Load Sizes) specifies test load sizes for clothes washer container volumes up to 3.8 ft 3 .

– DOE is aware that multiple clothes washers available on the market have container volumes exceeding 3.8 ft 3 .

– Multiple stakeholders commented in response to the August 2009 framework document in support of expanding Table 5.1 to include larger capacities. • On August 22, 2006, DOE granted an interim test procedure waiver to Whirlpool for three clothes washer models with container capacities greater than 3.8 cubic feet. 71 FR 48913.

– The alternate test procedure extended the linear relationship between maximum test load size and container volume in Table 5.1 to include container volumes of 3.8 to 3.9 ft 3 . • DOE is aware of only limited data regarding typical clothes washer load sizes. 

### Test Load Size Specifications 

## Current Usage Patterns and Capabilities62 | Test Procedure for Residential Clothes Washers eere.energy.gov • One 2003 P&G study showed an average load size of 7.2 lbs for top- loading, and 8.4 lbs for front- loading clothes washers.

– These load sizes correspond to the average test loads for the 2.7 to 2.8 ft 3 and 3.3 to 3.4 ft 3 capacity bins.

– These capacities are consistent with the shipment - weighted average capacity of 3.05 ft 3 from the 2005 AHAM Factbook . • From 1993 to 2005, AHAM data show tub capacities have increased by 14 percent, while RECS data show the number of cycles per year has decreased by 17 percent.

– Assuming that households continue to wash the same volume of clothes each year, the average load size increases with capacity. • The limited data suggest that the current values in the test load size table are appropriate, and extending the linear relationship between test load size and container capacity is valid.

– DOE proposes to extend Table 5.1 to include volumes up to 6.0 ft 3 . 

### Test Load Size Specifications 

## Current Usage Patterns and Capabilities63 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Test Load Size Specifications 

## Current Usage Patterns and Capabilities
Item 13 DOE welcomes comment on the proposed test load sizes, and on whether the linear relationship between test load size and clothes washer container volume is representative of actual consumer use. DOE invites any relevant data on this topic.64 | Test Procedure for Residential Clothes Washers eere.energy.gov • Load size use factors specify the fraction of all cycles run with minimum, average, and maximum load sizes. • DOE received comments in response to the August 2009 Framework Document stating that DOE should validate the use factors for minimum, average, and maximum loads based on more recent consumer use data. • DOE is not aware of recent data characterizing such usage patterns. • Therefore, DOE is not proposing to update the load size use factors currently in the test procedure.

– DOE welcomes input and data on consumer selection of load sizes. 

### Load Size Use Factors 

## Current Usage Patterns and Capabilities65 | Test Procedure for Residential Clothes Washers eere.energy.gov • As previously stated, DOE is proposing to amend the TUFs in the clothes washer test procedure to account for steam wash cycles. • DOE also investigated whether the other TUFs in the test procedure are valid.

– The 2005 RECS and California RASS both provide some data for hot, warm, and cold settings, but no information on extra hot or steam wash cycles.

– The 2005 RECS questionnaire also asks respondents only for the water temperature selections usually used for the wash and rinse cycles, which may not account for the less -frequent use of the hot wash cycle.

– The California RASS questionnaire asks for the number of wash loads per week at each temperature, and therefore likely captures hot washes, but only represents consumer use in one state. 

### Temperature Use Factors 

## Current Usage Patterns and Capabilities66 | Test Procedure for Residential Clothes Washers eere.energy.gov • The following table shows the TUFs as determined from the two surveys in addition to the current test procedure values:

*This value equals the sum of warm and hot rinse temperatures shown by the 2005 RECS data • DOE believes the comparison of these TUFs shows that the values currently in the test procedure are a reasonable estimate of current consumer use.

– DOE is therefore not proposing to amend the existing wash setting TUFs for clothes washers that are not equipped with steam wash cycles. 

### Temperature Use Factors 

## Current Usage Patterns and Capabilities
Temperature Setting TUF, Current Test Procedure TUF, 2005 RECS TUF, 2004 California RASS Hot Wash 0.14 0.062 0.20 Warm Wash 0.49 0.54 0.41 Cold Wash 0.37 0.40 0.39 Warm Rinse 0.27 0.20* N/A67 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE notes that it has recently received consumer usage survey data from a manufacturer for a clothes washer model with no warm rinse option on the cycle recommended for cotton clothes and a default cold rinse on all other cycles.

– The data indicate that users participating in the survey used warm rinse for 1.6 percent of all cycles. • DOE does not believe that this conclusion necessarily applies to all consumers and residential clothes washer models, and is not proposing a revision to the warm rinse TUF at this time.

– DOE remains open to considering a revision to the warm rinse TUF and welcomes further data regarding consumer usage of warm rinse. • DOE is, however, proposing to amend the methods for measuring warm rinse energy and water consumption. 

### Temperature Use Factors – Warm Rinse 

## Current Usage Patterns and Capabilities68 | Test Procedure for Residential Clothes Washers eere.energy.gov • The current test procedure accounts for warm rinses by determining the water heating energy consumption of a warm rinse, and applying a use factor of 0.27.

– The measurements occur only for the rinse portion of the cycle.

– For some clothes washers, it is not entirely clear when the wash cycle ends and the rinse begins due to multiple fill and drain events occurring in various sequences. • To simplify the warm rinse measurements, DOE is proposing to account for energy and water consumption over an entire warm wash/warm rinse cycle.

– DOE believes that measuring energy and water consumption over a complete warm wash/warm rinse cycle is appropriate because most clothes washers currently available allow users to select a warm rinse only with a warm wash cycle. 

### Warm Rinse Methodology 

## Current Usage Patterns and Capabilities69 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE is therefore proposing to eliminate the incremental use factor currently attributed to warm rinse.

– DOE believes that the warm rinse TUF of 0.27 would still apply as the TUF for a warm wash/warm rinse cycle. • For clothes washers offering a warm rinse, DOE is proposing to reduce the warm wash/cold rinse TUF from 0.49 to 0.22.

– DOE would specify that clothes washers not offering a warm rinse would have a warm wash/cold rinse TUF of 0.49. • DOE believes this revised methodology for incorporating warm rinse cycles would not change the intent of the test procedure.

– DOE is not proposing to amend the TUFs for temperature selections other than warm wash.

– Overall, the warm wash and warm rinse temperature selections would receive the same weight in the final calculations. 

### Warm Rinse Methodology 

## Current Usage Patterns and Capabilities70 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE recognizes that not all clothes washers offer a warm rinse selection under the cycle setting recommended for washing cotton or linen clothes (typically the “Normal” setting).

– If a warm wash/warm rinse cycle is available in any other wash cycle setting that uses agitation/tumble operation, spin speed(s), wash times and rinse times that are largely similar to the “Normal” cycle, the warm wash/warm rinse cycle would be tested using the wash cycle setting that would best reflect typical consumer use. • As a result, the calculated MEFs for these types of clothes washers could differ under the proposed method.

– The proposed method would account for the entire warm wash/warm rinse outside of the “Normal” cycle setting. • DOE expects to analyze potential effects of the proposed methodology on MEF, and to incorporate any such effects, as appropriate, into any amended standards. 

### Warm Rinse Methodology 

## Current Usage Patterns and Capabilities71 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE investigated whether the dryer use factor (DUF) of 0.84 in the clothes washer test procedure reflects current consumer usage.

– The DUF is used to calculate clothes drying energy consumption. • The 2005 RECS and 2004 California RASS include data on both clothes washer and clothes dryer use.

– Analysis of the RECS data showed that for households with both a clothes washer and dryer, the DUF was 0.95; for all households with a clothes washer, the DUF was 0.91.

– Analysis of the California RASS showed for households with both a washer and dryer, the DUF was 0.86; for all households with a clothes washer, the DUF was 0.76. • DOE is proposing a DUF of 0.91, based on the 2005 RECS data.

– DOE is proposing to use the 2005 RECS data to maintain consistency with the data source for the number of annual cycles. 

### Clothes Dryer Use Factor 

## Current Usage Patterns and Capabilities72 | Test Procedure for Residential Clothes Washers eere.energy.gov • The load adjustment factor (LAF) represents the ratio of typical consumer load size to maximum test load size. • LAF is used in the calculation of the energy required to remove moisture from the test load.

– The RMC value in the calculation is only based on tests using the maximum test load, so the LAF is used to scale the calculated energy consumption for actual consumer usage. • DOE lacks information warranting adjusting this value or changing it from a fixed value to one that varies as a function of average load size.

– Therefore, DOE is not proposing to amend the LAF currently in the clothes washer test procedure. 

### Load Adjustment Factor 

## Current Usage Patterns and Capabilities73 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Use Factors 

## Current Usage Patterns and Capabilities
Item 14 DOE requests comment on the validity of the proposed use factors for temperature, load size, and dryer use, and of the data sources used to estimate these values. Additionally, DOE seeks comment on the proposed revision to the warm rinse measurements, including the validity of the proposed warm wash/warm rinse TUF of 0.27. DOE also welcomes comment regarding the proposed load adjustment factor to be used in the RMC calculation. Stakeholders may submit any additional relevant data regarding these use factors.74 | Test Procedure for Residential Clothes Washers eere.energy.gov 4. Clothes Washer Active Mode Test Procedure a) Technologies Not Covered by the Current Clothes Washer Test Procedure b) Changes to Reflect Current Usage Patterns and Capabilities c) Test Cloth d) Other Revisions and Clarifications e) Test Procedure Performance Specifications 5. Compliance with Other EPCA Requirements 6. Impact of the Proposed Amendments on EnergyGuide and ENERGY STAR 7. Elimination of the Obsolete Clothes Washer Test Procedure 

### Test Procedure Overview75 | Test Procedure for Residential Clothes Washers eere.energy.gov • RMC is the ratio of the weight of water absorbed by the test cloth after an energy test cycle to the initial weight of the bone dry test cloth, multiplied by 100 percent.

– Characteristics of the test cloth can affect absorbency, so the test procedure aims to account for differences between test cloth production lots. • AHAM submitted comments in response to the August 2009 framework document, which included revised tolerances for the size and weight of the test cloth.

– These proposed tightened tolerances could only improve consistency in the RMC results from lot -to - lot of test cloth. • DOE believes that the AHAM proposal represents the industry’s consensus on limiting uncertainty in the test procedure due to variations in test cloth properties, and is proposing to include these changes in the test procedure. 

### Test Cloth Issues 

## Test Cloth76 | Test Procedure for Residential Clothes Washers eere.energy.gov • The current test procedure uses extractor tests with g -forces up to 500 g in determining the RMC correlation curve for test cloth lots.

– However, DOE is aware of clothes washers on the market that achieve g -forces higher than 500 g. • DOE is therefore proposing to include an additional set of extraction tests at 650 g, and to require the 500 g extraction for all clothes washers. • The proposed standard RMC values for the proposed extractor tests are shown below, based on AHAM -submitted data. 

### Test Cloth Issues 

## Test Cloth

g - Force RMC percentage Warm soak Cold soak 15 min. spin 4 min. spin 15 min. spin 4 min. spin 100 45.9 49.9 49.7 52.8 200 35.7 40.4 37.9 43.1 350 29.6 33.1 30.7 35.8 500 24.2 28.7 25.5 30.0 650 23.0 26.4 24.1 28.077 | Test Procedure for Residential Clothes Washers eere.energy.gov • Based on additional comments, DOE is proposing:

– To specify a test cloth handling procedure to ensure consistent results from the extractor testing;

– To update the extractor manufacturer from Bock Engineered Products to North Star Engineered Products, Inc; and

– To require a bone dryer capable of heating the test cloth to over 210 oF (99 oC). • The current test procedure also contains redundant sections regarding test cloth specifications and preconditioning.

– DOE is proposing to remove these redundant sections, and to move any relevant non - redundant information from these sections to the appropriate sections. 

### Test Cloth Issues 

## Test Cloth78 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Test Cloth Issues Item 15 DOE requests comment and data regarding the proposed updated test cloth specifications and correlation procedure. 

## Test Cloth79 | Test Procedure for Residential Clothes Washers eere.energy.gov 4. Clothes Washer Active Mode Test Procedure a) Technologies Not Covered by the Current Clothes Washer Test Procedure b) Changes to Reflect Current Usage Patterns and Capabilities c) Test Cloth d) Other Revisions and Clarifications e) Test Procedure Performance Specifications 5. Compliance with Other EPCA Requirements 6. Impact of the Proposed Amendments on EnergyGuide and ENERGY STAR 7. Elimination of the Obsolete Clothes Washer Test Procedure 

### Test Procedure Overview80 | Test Procedure for Residential Clothes Washers eere.energy.gov • The current clothes washer test procedure requires measuring “the entire volume which a dry clothes load could occupy within the clothes container during washer operation.”

– This is done by filling the clothes container with water “to its uppermost edge,” and determining the volume based on the added weight of water. • The “uppermost edge” is not well - defined, and may not always represent a volume which a dry clothes load could occupy.

– DOE believes the remainder of the method provides for an accurate measurement of capacity. • DOE received multiple comments in support of revising the capacity measurement method.

– DOE considered other measurement methods, such as IEC Standard 60456, but believes these would create unnecessary test burden on manufacturers. 

### Clothes Washer Capacity Measurement Method 

## Other Revisions and Clarifications81 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE conducted capacity tests on a small sample of clothes washers, and found that most rated capacities varied from DOE’s test measurements, by as much as 0.5 ft 3 .

– This suggests that the ratings are based on multiple interpretations of the uppermost edge of the clothes container.

– DOE seeks to provide an accurate, representative, and repeatable definition of the uppermost edge of the clothes container. • The current definition of the clothes container is “the compartment within the clothes washer that holds the clothes during the operation of the machine.”

– DOE believes this should include the requirement that the clothing remain within the clothes container for an entire operating cycle.

– Additionally, the clothes washer should maintain basic functionality. • Dry clothing could fit in certain fill volumes which would lead to poor washing performance and machine operation during a cycle. 

### Clothes Washer Capacity Measurement Method 

## Other Revisions and Clarifications82 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE believes the top of the rotating portion of the clothes container for a vertical -axis clothes washer would be the highest horizontal plane that a clothes load could occupy.

– This would include a balance ring as part of the clothes container.

– Clothes could be loaded in the space above the tub cover, but this volume is excluded because these clothes would likely wash poorly. • DOE believes the door seal in contact with the door during operation would determine the highest horizontal plane that a clothes load could occupy for a horizontal -axis clothes washer.

– DOE also considered the inner surface of the clothes door as the uppermost edge, but determined this method was not repeatable. • For both vertical - and horizontal -axis clothes washers, any volume within the clothes container that a clothing load could not occupy during operation should be excluded from the measurement. 

### Clothes Washer Capacity Measurement Method 

## Other Revisions and Clarifications83 | Test Procedure for Residential Clothes Washers eere.energy.gov • The following diagram shows the proposed fill level clarification for vertical -axis clothes washers.

• DOE notes that the proposed fill level differs from the draft guidance for the current test procedure, which is posted on the residential clothes washers rulemaking website.

– The draft guidance sets the tub cover as the maximum fill level. 

### Clothes Washer Capacity Measurement Method 

## Other Revisions and Clarifications84 | Test Procedure for Residential Clothes Washers eere.energy.gov • The following diagrams show the proposed fill volumes for front and top- loading horizontal -axis clothes washers. 

### Clothes Washer Capacity Measurement Method 

## Other Revisions and Clarifications85 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on the Capacity Measurement Method 

## Other Revisions and Clarifications
Item 16 DOE welcomes comment on whether the proposed method for measuring clothes container capacity provides for a representative measurement of the volume that a dry clothes load could occupy within the clothes container during washer operation, and on whether any other valid measurement method is available.86 | Test Procedure for Residential Clothes Washers eere.energy.gov • The calculation of WF currently in the test procedure is derived from only the water consumed during the cold wash/cold rinse cycle.

– Hot water consumption is measured for all cycles, but only used to determine water heating energy consumption.

– This presents an opportunity to bias the test procedure results by setting cold wash water consumption very low, while using more water during the higher temperature wash cycles. • To produce more representative values of water consumption, DOE is proposing a new integrated water consumption factor (IWF).

– DOE is proposing to include water consumption from all energy test cycles, including self- clean cycles, into the calculation of IWF. 

### New Measure of Water Consumption 

## Other Revisions and Clarifications87 | Test Procedure for Residential Clothes Washers eere.energy.gov • The total weighted per-cycle water consumption would equal:

– The total water consumption for each active mode energy test cycle multiplied by its TUF and load usage factor.

– Plus the self- clean cycle water consumption, multiplied by 12 self clean cycles per year, divided by 295 annual use cycles; • IWF would then equal the total weighted per-cycle water consumption divided by the clothes container volume. • DOE believes the proposed IWF metric will not substantially increase manufacturers’ test burden.

– Doe believes that in practice, manufacturers likely record the data for cold water consumption at all wash temperatures even though it is not required by the current test procedure. 

### New Measure of Water Consumption 

## Other Revisions and Clarifications88 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on the Integrated Water Consumption Factor 

## Other Revisions and Clarifications

Item 17 DOE welcomes comment on the proposal to establish a new integrated measure of water consumption for clothes washers, “integrated water consumption factor,” expressed in gallons per cubic foot. DOE requests comment on the validity of including water consumption from all test cycles, including self- clean cycles, into the proposed calculation of IWF. DOE also requests comment on whether the IWF calculation would result in a significant test burden.89 | Test Procedure for Residential Clothes Washers eere.energy.gov • The energy test cycle is currently defined as:

– “(A) the cycle recommended by the manufacturer for washing cotton or linen clothes, and includes all wash/rinse temperature selections and water levels offered in that cycle, and

– (B) for each other wash/rinse temperature selection or water level available on that basic model, the portion(s) of other cycle(s) with that temperature selection or water level that, when tested pursuant to these test procedures, will contribute to an accurate representation of the energy consumption of the basic model as used by consumers.

– Any cycles under (A) or (B) shall include the agitation/tumble operation, spin speed(s), wash times, and rinse times applicable to that cycle, including water heating time for water heating clothes washers.” 

### Energy Test Cycle 

## Other Revisions and Clarifications90 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE believes that some manufacturers may use only part A of this definition to determine the energy test cycle and the corresponding temperature and fill levels to be tested.

– Many machines provide a “normal” cycle setting, or some equivalent, to be used for washing cotton or linen items, satisfying part A of the energy cycle definition.

– However, many normal cycles limit the wash and rinse temperature selections; for example, they may offer cold and warm wash temperatures, but not hot, extra hot or a warm rinse.

– Certain manufacturers may only test the temperature settings available to the normal wash cycle, despite being able to access other wash temperature selections by switching out of the normal cycle.

– Doing so may neglect part B of the energy test cycle definition. 

### Energy Test Cycle 

## Other Revisions and Clarifications91 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE notes that the requirement to test different cycle settings “if such testing contributes to an accurate representation of energy consumption as used by consumers” has led to some confusion, and is therefore proposing to add clarification to part B of the energy test cycle definition as follows:

– “...(B) if the cycle described in (A) does not include all wash/rinse temperature settings available on the clothes washer, and required for testing as described in this test procedure, the energy test shall also include the portions of a cycle setting offering these wash/rinse temperature settings with agitation/tumble operation, spin speed(s), wash times, and rinse times that are largely comparable to those for the cycle recommended by the manufacturer for washing cotton or linen clothes. Any cycle under (A) or (B) shall include the default agitation/tumble operation, soil level, spin speed(s), wash times, and rinse times applicable to that cycle, including water heating time for water heating clothes washers.” 

### Energy Test Cycle 

## Other Revisions and Clarifications92 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE notes that it has issued draft guidance available on the residential clothes washers rulemaking website to interpret the current definition of the energy test cycle.

– The proposed definition is consistent with the draft guidance.

– This guidance states that the energy test cycle should include the temperature options on the cycle most comparable to the cycle recommended for washing cotton or linen clothes if these temperature selections are not available on the cotton or linen cycle. • DOE also notes that it has received data from a manufacturer indicating that cycles may vary from the cotton or linen cycle by means of lower spin speed and resulting in a higher RMC, and therefore would not be largely comparable to the cotton or linen cycle. 

### Energy Test Cycle 

## Other Revisions and Clarifications93 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on the Energy Test Cycle Definition 

## Other Revisions and Clarifications
Item 18 DOE requests comment on the proposed definition of the energy test cycle, and on how manufacturers currently address wash and rinse temperature selection under the current definition. DOE also requests comment on the selection cycles to be included in the energy test cycle under section 1.7(B) of the test procedure to definitively account for temperature options available only outside the normal cycle.94 | Test Procedure for Residential Clothes Washers eere.energy.gov • The current test procedure specifies test cloth preconditioning using AHAM Standard detergent IIA, which is no longer available. • DOE conducted tests using AHAM standard test detergent Formula 3, and found the current dosage requirements (6.0 grams per gallon of water) may no longer be appropriate.

– Undissolved detergent was found in the preconditioned test load. • One supplier of standard test materials, SDL Atlas, provides dosing instructions of 27.0 g + 4.0 g per pound of cloth load with AHAM standard test detergent Formula 3.

– In addition, AHAM’s clothes dryer test standard, AHAM HLD - 1 - 2009, specifies this dosage for test cloth pre -treatment. • DOE is therefore proposing to amend the test cloth preconditioning procedure to use AHAM standard test detergent Formula 3 with dosing of 27.0 g + 4.0 g per pound of cloth load. 

### Detergent Specifications for Test Cloth Preconditioning 

## Other Revisions and Clarifications95 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Preconditioning Detergent 

## Other Revisions and Clarifications

Item 19 DOE welcomes comment on the proposed updated detergent formulation and associated dosage for test cloth preconditioning.96 | Test Procedure for Residential Clothes Washers eere.energy.gov • Section 2.6.3.1 of the test procedure requires that test cloth be preconditioned using a clothes washer for which:

– a maximum water level can be set;

– the load can be washed for 10 minutes; and

– the wash temperature can be controlled to 135 oF ± 5 oF (57.2 oC ± 2.8 oC). • Multiple manufacturers expressed concern that there are currently few clothes washers commercially available capable of meeting these requirements.

– Additionally, more stringent energy conservation standards may eliminate such clothes washer models from the market entirely. • DOE seeks information regarding an alternative specification for the clothes washer to be used for preconditioning that would allow for the use of more recent models. 

### Clothes Washer for Test Cloth Preconditioning 

## Other Revisions and Clarifications97 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Preconditioning Clothes Washer 

## Other Revisions and Clarifications
Item 20 DOE requests comment on the clothes washer used in test cloth preconditioning, including whether clothes washers currently meeting the specifications may be rendered obsolete by potential new residential clothes washer energy conservation standards.98 | Test Procedure for Residential Clothes Washers eere.energy.gov • Section 2.4 of the test procedure states “[t]he static water pressure at the hot and cold water inlet connection of the clothes washer shall be maintained at 35 pounds per square inch gauge (psig) ... during the test.”

– DOE believes this description is ambiguous as to whether the nominal 35 psig pressure is to be set under non -flow conditions and allowed to drop during flow, or whether it is to be maintained continuously under all flow conditions.

– Additionally, there is no specification for where the measurement is to be taken. • DOE conducted tests on a small sample of front- and top- loading clothes washers to determine the effects of different water supply pressures on the test results. 

### Test Procedure Water Supply Pressure 

## Other Revisions and Clarifications99 | Test Procedure for Residential Clothes Washers eere.energy.gov • Tests at 10, 20, and 35 psig water supply pressure under flow conditions resulted in total water consumption values varying by 10 to 30 percent.

– The test data suggest that a water supply pressure of 20 psig under flow conditions results in the most consistent results.

– DOE also believes that 20 psig may represent typical static pressure under flow conditions that would result from 35 psig supply pressure at non -flow conditions, and that these conditions may be more representative of water supply conditions that would be found in typical residential settings. • However, other DOE test procedures more closely specify the 35 psig requirement applying under flow conditions (dishwashers). • Therefore, DOE is not proposing to amend the water supply pressure requirements at this time, but seeks more information on the topic. 

### Test Procedure Water Supply Pressure 

## Other Revisions and Clarifications100 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on the Water Supply Pressure 

## Other Revisions and Clarifications
Item 21 DOE seeks information about the conditions under which clothes washers are currently tested, and invites comment on the appropriate specification of the water supply pressure.101 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE is proposing the following revisions that will not substantively change the test procedure:

– To include the oil repellency test and dimensional change test references in 10 CFR 430.3, “Materials Incorporated by Reference;”

– To clarify the RMC calculations in section 3.8.4 for clothes washers with options that result in different RMC values;

– To correct an error in the equation in section 4.1.4 for calculating the total per- cycle hot water energy consumption for gas - or oil heated water; and

– To remove the current section 4.5, which provides for the calculation of energy factor (EF). • EF was the energy efficiency metric used to establish energy conservation standards for clothes washers manufactured before January 1, 2004. It is no longer used.



### Additional Revisions and Clarifications 

## Other Revisions and Clarifications102 | Test Procedure for Residential Clothes Washers eere.energy.gov 4. Clothes Washer Active Mode Test Procedure a) Technologies Not Covered by the Current Clothes Washer Test Procedure b) Changes to Reflect Current Usage Patterns and Capabilities c) Test Cloth d) Other Revisions and Clarifications e) Test Procedure Performance Specifications 5. Compliance with Other EPCA Requirements 6. Impact of the Proposed Amendments on EnergyGuide and ENERGY STAR 7. Elimination of the Obsolete Clothes Washer Test Procedure 

### Test Procedure Overview103 | Test Procedure for Residential Clothes Washers eere.energy.gov • The current DOE test procedure does not include any provisions for evaluating the wash quality of a clothes washer.

– The intent is to determine water and energy consumption, regardless of a clothes washer’s wash capabilities. • DOE received multiple comments in support of adding performance measures to the test procedure.

– Multiple commenters stated that increasing energy and water efficiency requirements could limit the ability of a clothes washer to clean laundry as expected.

– The comments referenced other standards that include a measure of wash performance, such as AHAM HLW- 1 and IEC Standard 60456, “Clothes washing machines for household use – Methods for measuring the performance.” 

### Test Procedure Performance Specifications 

## Performance Specifications104 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE considered these comments and recognizes the benefits of characterizing washer performance, but is not proposing to incorporate measures of wash performance into the clothes washer test procedure.

– EPCA states “[a]ny test procedures prescribed or amended under this section shall be reasonably designed to produce test results which measure energy efficiency, energy use . . . or estimated annual operation cost . . .” (42 U.S.C. 6293(b)(3)) 

### Test Procedure Performance Specifications 

## Performance Specifications105 | Test Procedure for Residential Clothes Washers eere.energy.gov 4. Clothes Washer Active Mode Test Procedure a) Technologies Not Covered by the Current Clothes Washer Test Procedure b) Changes to Reflect Current Usage Patterns and Capabilities c) Test Cloth d) Other Revisions and Clarifications e) Test Procedure Performance Specifications 5. Compliance with Other EPCA Requirements 6. Impact of the Proposed Amendments on EnergyGuide and ENERGY STAR 7. Elimination of the Obsolete Clothes Washer Test Procedure 

### Test Procedure Overview106 | Test Procedure for Residential Clothes Washers eere.energy.gov • EPCA requires that “[a]ny test procedures prescribed or amended under this section shall be reasonably designed to produce test results which measure energy efficiency, energy use . . . or estimated annual operating cost of a covered product during a representative average use cycle or period of use . . . and shall not be unduly burdensome to conduct.” (42 U.S.C. 6293(b)(3)) • DOE believes the proposed amendments regarding standby, off, delay start, and cycle finished mode energy consumption satisfy this requirement because:

– IEC Standard 62301 is internationally accepted to measure power in standby and off mode, and will produce power consumption measurements that are representative of an average use cycle .

– The proposed test methods and associated equipment would not require manufacturers to make a major investment in test facilities and new equipment. 

### Test Burden 

## Compliance with Other EPCA Requirements107 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE believes the amendments to the active washing mode portion of the test procedure would also satisfy this EPCA requirement.

– The amendments would require manufacturers to make the same measurements as specified by the current test procedure, and would likely not require additional investment or equipment purchases.

– The proposed additional test cycles would increase the total time required to test a clothes washer offering these cycle settings, however these cycles would likely increase the total test time only by approximately 25 percent. 

### Test Burden 

## Compliance with Other EPCA Requirements108 | Test Procedure for Residential Clothes Washers eere.energy.gov • Section 325(gg)(2)(A) of EPCA requires that standby mode and off mode energy consumption be “integrated into the overall energy efficiency, energy consumption, or other energy descriptor for each covered product” unless the current test procedures already fully account for the standby mode and off mode energy consumption, or if such an integrated test procedure is technically infeasible. (42 U.S.C. 6295(gg)(2)(A))

– As previously discussed, DOE is proposing to incorporate the clothes washer standby and off mode energy consumption, in addition to delay start and cycle finished mode energy consumption, into a “per- cycle standby, off, delay start and cycle finished mode energy consumption”, expressed in kWh, and into an integrated modified energy factor (IMEF), expressed in ft 3 per kWh per cycle, which satisfies this EPCA requirement. 

### Integration of Standby and Off Mode Energy Consumption 

## Compliance with Other EPCA Requirements109 | Test Procedure for Residential Clothes Washers eere.energy.gov • EPCA also requires that test procedure amendments incorporating standby and off mode energy consumption will not determine compliance with previously established standards. (42 U.S.C. 6295(gg)(2)(C))

– Because DOE is proposing to adopt the amendments as a new appendix J2 to 10 CFR part 430 subpart B that manufacturers would not be required to use until the compliance date of amended energy conservation standards for residential clothes washers, the proposed test procedure amendments pertaining to standby mode and off mode energy consumption would not apply to, and would have no effect on, existing standards. 

### Impact of Test Procedure Amendments on Existing Standards 

## Compliance with Other EPCA Requirements110 | Test Procedure for Residential Clothes Washers eere.energy.gov • The test procedure in appendix J1 of subpart B of 10 CFR 430 is also used to test commercial clothes washers. • If DOE were to apply the proposed new appendix J2 to commercial clothes washers, the impacts would be limited to the proposed amendments associated with active washing mode because commercial clothes washer standards are based on MEF and WF.

– These include the proposed changes to the test load size specifications, TUFs, DUF, test cloth, capacity measurement, detergent, and water supply pressure.

– These changes would have some affect on the measured energy and water efficiencies of commercial clothes washers, mostly from the changes to the capacity measurement and use factors. 

### Impact on Commercial Clothes Washers 

## Compliance with Other EPCA Requirements111 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Request for Comment on Commercial Clothes Washer Impact

Item 22 DOE welcomes inputs on the effects of the proposed amendments in appendix J2 on the measured energy and water efficiencies of commercial clothes washers. 

## Compliance with Other EPCA Requirements112 | Test Procedure for Residential Clothes Washers eere.energy.gov 4. Clothes Washer Active Mode Test Procedure a) Technologies Not Covered by the Current Clothes Washer Test Procedure b) Changes to Reflect Current Usage Patterns and Capabilities c) Test Cloth d) Other Revisions and Clarifications e) Test Procedure Performance Specifications 5. Compliance with Other EPCA Requirements 6. Impact of the Proposed Amendments on EnergyGuide and ENERGY STAR 7. Elimination of the Obsolete Clothes Washer Test Procedure 

### Test Procedure Overview113 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE considered potential impacts of the proposed test procedure amendments to the FTC EnergyGuide requirements, and determined that there will be no impact.

– The primary indication of energy use provided in the EnergyGuide label for clothes washers is annual energy cost, which would not be changed by the proposed amendments. • The ENERGY STAR program for clothes washers is based on MEF and WF.

– The calculations of WF and MEF would be slightly affected by the proposed amendments, however, these calculations would not be required until the compliance date of any amended energy conservation standards.

– DOE would analyze any potential impacts of the proposed test procedure as part of the current energy conservation standards rulemaking. 

### Impact on EnergyGuide and ENERGY STAR 

## Impact of the Proposed Amendments114 | Test Procedure for Residential Clothes Washers eere.energy.gov 4. Clothes Washer Active Mode Test Procedure a) Technologies Not Covered by the Current Clothes Washer Test Procedure b) Changes to Reflect Current Usage Patterns and Capabilities c) Test Cloth d) Other Revisions and Clarifications e) Test Procedure Performance Specifications 5. Compliance with Other EPCA Requirements 6. Impact of the Proposed Amendments on EnergyGuide and ENERGY STAR 7. Elimination of the Obsolete Clothes Washer Test Procedure 

### Test Procedure Overview115 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE proposes to delete appendix J to subpart B of 10 CFR part 430 along with all references to appendix J in 10 CFR part 430.23.

– Appendix J only applies to clothes washers manufactured before January 1, 2004 and is therefore now obsolete. • Appendix J1 to subpart B of 10 CFR part 430 provides applicable test procedures for all clothes washers currently available on the market. • DOE proposes to maintain the current naming of appendix J1, rather than renaming it as appendix J, to simplify the changes required.

– DOE has previously used this approach to retaining later versions of appendices to subpart B of 10 CFR 430 when deleting the original version. 

### Elimination of the Obsolete Clothes Washer Test Procedure 

## Elimination of Appendix J116 | Test Procedure for Residential Clothes Washers eere.energy.gov 

##  Public Meeting – oral comments will be captured in the transcript and become part of the public record. 

##  Written comments – NOPR comment period open until 75 days after publication in the Federal Register Reference docket #: EERE - 2010 - BT-TP - 0021 and/or RIN #: 1904 -AC08

Email: RES - CW- 2010 -TP - 0021@ee.doe.gov Mail: Mrs. Brenda Edwards U.S. Department of Energy Building Technologies Program 1000 Independence Avenue, SW, Mailstop EE - 2J Washington, DC 20585 - 0121 Courier: Mrs. Brenda Edwards U.S. Department of Energy Building Technologies Program 950 L'Enfant Plaza, 6th Floor Washington, DC 20024 Telephone: (202) 586 - 2945 

### How to Submit Comments... 

## Closing117 | Test Procedure for Residential Clothes Washers eere.energy.gov 

### Support Slides118 | Test Procedure for Residential Clothes Washers eere.energy.gov • One household survey conducted by the National Appliance and Equipment Energy Efficiency Committee (NAEEEC) in Australia in 2000, for example, measured different modes for 61 clothes washers with an average age of 9 years.

– The daily time spent in each mode in this study averaged 1 hour for washing (active washing mode), zero time for delay start and “active standby” (inactive mode) modes, and the remaining time split 20 percent for “end of program” mode (cycle finished mode) and 80 percent for off mode. Self - clean mode was not explicitly addressed. 

### Hours Per Year Associated with Non -Active Washing Modes 

## Calculation of Energy Use119 | Test Procedure for Residential Clothes Washers eere.energy.gov • The average age of the clothes washers in the study suggests that many had electromechanical rather than electronic controls, and thus would not likely have been capable of inactive mode.

– Hence, DOE does not infer from those results that more modern clothes washers spend negligible time in inactive mode. • DOE believes that because current clothes washer models offer both mechanical and electronic controls, the time apportioned to off mode in this study would actually be split between off mode and inactive mode. • Implementation of a delayed start feature appears to be marketspecific.

– Markets with a long history of residential time - of - day electricity pricing are more likely to have appliances with delayed start features than in markets where household electricity prices are constant. 

### Hours Per Year Associated with Non -Active Washing Modes 

## Calculation of Energy Use120 | Test Procedure for Residential Clothes Washers eere.energy.gov • The clothes washers in the NAEEEC study would have been less likely to have a delay start mode because differential power pricing is a relatively recent development in the Australian residential power market.

– Thus, the findings in the Australian clothes washer study regarding delayed start are inconclusive regarding current models of clothes washers. • To help address this uncertainty, DOE examined an Australian study on clothes washers conducted in 2005, which noted a small number of hours associated with delay start mode.

– The study monitored time spent in different modes using dataloggers on clothes washers in Australia and New Zealand.

– It showed that the average amount of time spent in delay start mode per wash cycle was approximately 5 minutes. 

### Hours Per Year Associated with Non -Active Washing Modes 

## Calculation of Energy Use121 | Test Procedure for Residential Clothes Washers eere.energy.gov • DOE expects similar low usage patterns of delayed start functionality for clothes washers in U.S. households, as noted in the 2005 Australian survey. • DOE research suggests that most U.S. residential electricity customers have fixed - rate electricity pricing ( **i.e.,** the cost of electricity does not change with time of day, day of week, or time of year).

– However, the adoption of delayed start functionality could rise in the United States as more electric utilities offer variable - rate pricing plans to residential customers that encourage shifting electricity consumption to off - peak hours. 

### Hours Per Year Associated with Non -Active Washing Modes 

## Calculation of Energy Use122 | Test Procedure for Residential Clothes Washers eere.energy.gov • Based on these two studies, DOE concludes that a typical modern clothes washer spends a small amount of time in delay start mode. • Using an estimated 5 minutes per cycle and the proposed representative 295 cycles per year, the total annual amount of time spent in delay start mode is 25 hours. • The NAEEEC study suggests allocating the remaining time as follows:

– 20 percent allocated to cycle finished mode; and

– 80 percent allocated to off and/or inactive mode for clothes washers that have the capability of operating in both modes. 

### Hours Per Year Associated with Non -Active Washing Modes 

## Calculation of Energy Use123 | Test Procedure for Residential Clothes Washers eere.energy.gov • However, internal DOE testing of multiple clothes washers showed that the actual time spent in a cycle finished mode is very short.

– Most units with a cycle finished mode spent less than 5 minutes in this mode before switching to off/inactive mode.

– Some models even had no cycle finished mode, and immediately reverted to off/inactive mode after completion of the active mode. • Based on these results, DOE is proposing to allocate 3 minutes per cycle to cycle finished mode, resulting in an average of 15 hours per year. 

### Hours Per Year Associated with Non -Active Washing Modes 

## Calculation of Energy Use124 | Test Procedure for Residential Clothes Washers eere.energy.gov • In addition, DOE is aware that some clothes washers offer self-clean cycles that are not accounted for in the proposed 295 per year.

– DOE tested seven machines offering a self - clean cycle, and found an average cycle time of 1.3 hours.

– Based on an estimated average manufacturer recommendation of 12 self- clean cycles per year, DOE is proposing 16 self - clean hours per year. • In summary, DOE is proposing to allocate 295 hours per year to active washing mode, 16 hours per year to self-clean mode (if applicable), 25 hours per year to delay start mode, 15 hours per year to cycle finished mode, and the remainder to off and/or inactive mode. 

### Hours Per Year Associated with Non -Active Washing Modes 

## Calculation of Energy Use