UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY 

PUBLIC MEETING 

ON

TEST PROCEDURE SNOPR FOR 

RESIDENTIAL CLOTHES DRYERS AND ROOM AIR CONDITIONERS

U.S. Department of Energy

1000 Independence Avenue, SW

Washington, DC 20585

Room IE-24S

Wednesday

July 14, 2010

Chair:

Doug Brookman 

Department of Energy
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Participants Identified: 

Jim Battaglia

Navigant Consulting

Javier Burgos

Navigant Consulting

Paige Detrick

BSH.

Jason Fitzgerald

D&R International

Kate Houren

NRDC

Rich Karney

DOE

Betsy Kohl

DOE General Counsel

Amanda Lowenberger

The American Council for an Energy-Efficient Economy

Phil Manthei

Alliance Laundry Systems

Joanna Mauer

Appliance Standards Awareness Project

Kevin Messner

AHAM

Wayne Morris

AHAM

Farhad Omar

NIST

100 Bureau Drive

Gaithersburg, MD

Graham Parker

Pacific Northwest National Laboratory

Francine Pinto

GC, DOE
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Judith Reich

Navigant Consulting

Christine Taddonio

Energy Star 

Ryan Togle

D&R International

Meg Sullivan

DOE

Subid Wagley

U.S. Department of Energy

Meg Waltner

NRDC
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I N D E X

AGENDA ITEMS PAGE

Welcome, Mr. Karney 5

Self-Introductions 6

Agenda Review, Mr. Brookman 7

Introduction of Regulatory Overview

Ms. Sullivan 10

Comments from Participants 13

Covered Products; Standby/Off Mode: 

Incorporating by Reference IEC 62301 21

Determination of Modes to be Incorporated 23

Added Specifications to the Test Method and 

Measurements 42

Standby/Off Mode: Calculation of Energy Use, 

Measures of Energy Consumption 62

Active Mode: Dryer Automatic Cycle 

Termination 79

Active Mode: Vent-less Dryers, Detergent 

Specifications for Dryer Test Cloth 

Preconditioning 111

Active Mode: Changes to Reflect Consumer Usage 

Patterns and Capabilities 132

Active Mode: Room Air Conditioner and Dryer 

Referenced Test Procedures, Technical 

Corrections for Gas Dryers, Clarification 

to Dryer Gas Supply Conditions 155

Compliance with EPCA: Requirements; Effects 

of Test Procedure Revisions on 

Compliance with Standards 164
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1 P R O C E E D I N G S

2 9:10 a.m.

3 MR. BROOKMAN: Thank you. Rich Karney is 

4 going to make welcoming remarks. 

5 MR. KARNEY: I’d like to thank everybody 

6 for coming for today’s meeting on the -- Public 

7 Meeting on Test Procedures Supplemental Notice of 

8 Proposed Rulemaking for Residential Clothes Dryers 

9 and Room Air Conditioners. My name is Richard 

10 Karney. I’m with the U.S. Department of Energy. I 

11 recently have been reassigned from doing work on 

12 Energy Star to heading up test procedure 

13 development, and that’s obviously two of the things 

14 that we’ll be discussing today.

15 I’m sorry for the weather. I also found 

16 out, heard, that the airports were closed for a 

17 while last night due to the heavy thunderstorms, and 

18 that could be why we’re missing some people. Also, 

19 there’s a terrible delay on the subway system today. 

20 So people will probably be filtering in as we 

21 proceed on.

22 I’d like to thank everybody for coming and 

23 look forward to a hearty and heartful discussion 

24 this morning, and without controversy, of course. 
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1 MR. BROOKMAN: Thank you. Let’s start by 

2 doing introductions. I'll start over here to my 

3 left. Please say your name and organizational 

4 affiliation. And for those of you sitting here at 

5 the table, you can get in the habit of pushing the 

6 button and seeing the little green LED light come 

7 on. Yes, please.

8 SELF INTRODUCTIONS

9 MR. MANTHEI: Phil Manthei, Alliance 

10 Laundry Systems.

11 MR. MESSNER: Kevin Messner with AHAM.

12 MR. MORRIS: Wayne Morris with AHAM.

13 MS. DETRICK: Paige Detrick, BSH.

14 MS. WALTNER: Meg Waltner, NRDC.

15 MS. HOWRAN: Kate Houren, NRDC.

16 MS. MAUER: Joanna Mauer, Appliance 

17 Standards Awareness Project.

18 MS. LOWENBERGER: Amanda Lowenberger, The 

19 American Council for an Energy-Efficient Economy.

20 MR. BROOKMAN: We’ll go over here.

21 MR. WAGLEY: Subid Wagley with U.S. 

22 Department of Energy.

23 MS. SULLIVAN: Meg Sullivan, DOE.

24 MR. KARNEY: Rich Karney, DOE.

25 MR. BATTAGLIA: James Battaglia, Navigant 
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1 Consulting.

2 MR. BURGOS: Javier Burgos, Navigant 

3 Consulting.

4 MR. BROOKMAN: Thank you. In the back?

5 MR. PARKER: Graham Parker, Pacific 

6 Northwest National Laboratory.

7 MR. TOGLE: Ryan Togle, D&R International.

8 MR. FITZGERALD: Jason Fitzgerald, D&R 

9 International.

10 AGENDA REVIEW

11 MR. BROOKMAN: Thanks, everyone. Did we 

12 miss anyone? My name’s Doug Brookman from Public 

13 Solutions in Baltimore. I think all of you received 

14 a packet of information as you came in this morning. 

15 In there you’ll find the agenda, as well as the 

16 presentation slides. I think most of you, all of 

17 you are familiar with the general format for this 

18 meeting. We will be using these presentation slides 

19 as the framework for both presentation and 

20 discussion, and the Department will be seeking 

21 specific comments over the course of the day.

22 I’m going to run through the agenda very 

23 briefly, if you want to take a peek at it while I’m 

24 looking at it. Immediately following this agenda 

25 review, there’s going to be a brief introduction of 
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1 regulatory overview segment by Margaret. Following 

2 that, it’s not listed in your agenda, there’s an 

3 opportunity for anybody that wishes to do so to make 

4 brief summary remarks here at the outset, issues 

5 that matter to the stakeholders in the room.

6 Following that we’ll go to the 

7 presentation materials, “Covered Products; 

8 Standby/Off Mode: Incorporating by Reference IEC 

9 62301,” we’ll hear from James. And then he’ll 

10 continue on “Determination of Modes to be 

11 Incorporated, Added Specifications to the Test 

12 Method and Measurements.”

13 We’ll take a break mid-morning, about 

14 10:45 or so, and then James will continue with 

15 “Standby/Off Mode: Calculation of Energy Use, 

16 Measures of Energy Consumption,” and then, “Active 

17 Mode: Dryer Automatic Cycle Termination.”

18 We’ll break for lunch around about noon19 ish, and then continuing on immediately following 

20 lunch, “Active Mode: Vent-less Dryers, Detergent 

21 Specifications for Dryer Test Cloth 

22 Preconditioning,” “Active Mode: Changes to Reflect 

23 Consumer Usage Patterns and Capabilities,” Active 

24 Mode -- lots of Active Mode here -- “Active Mode: 

25 Room Air Conditioner and Dryer Referenced Test 
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1 Procedures, Technical Corrections for Gas Dryers, 

2 Clarification to Dryer Gas Supply Conditions.” 

3 And then finally, “Compliance with EPCA 

4 Requirements, Effects of Test Procedure Revisions on 

5 Compliance with Standards.”

6 There’s an opportunity again at the end of 

7 the day for any person in the room that wishes to do 

8 so to raise any other issues, emphasize things that 

9 have not been covered sufficiently during the course 

10 of the day.

11 We intend to end today I guess around 

12 three o’clock or so. We’ll go as efficiently as we 

13 can. We don’t want to diminish anybody’s capacity 

14 to comment.

15 So that’s the plan for the day. 

16 Questions? Comments on that? I think all of you 

17 are familiar with the way we typically do this. I’d 

18 ask for your consideration. Please speak one at a 

19 time. Please say your name for the record each time 

20 you speak. You don’t need to say your organization 

21 every time, but your name would be helpful.

22 There will be a complete transcript of 

23 this meeting, and it will be available. It will be 

24 posted on the EERE website. More information 

25 surrounding how you submit your comments as we go on 
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1 in the day. I’m going to be cueing people by name 

2 as best I can to speak. I wish to encourage also 

3 follow on comments. Sometimes it’s useful for the 

4 Department to hear the back and forth between 

5 different perspectives. And if you can keep the 

6 focus here, turn your cell phones on silent mode, 

7 and if you need to have a sidebar conversation, 

8 please make it brief or take it out of the room. 

9 We’ll understand.

10 Also, if you can be concise with your 

11 comments. Share the air time, that would be 

12 helpful. Questions and comments here at the outset 

13 before we begin? Okay, thank you. You want to --

14 yes, Margaret.

15 INTRODUCTION AND REGULATORY OVERVIEW

16 MS. SULLIVAN: Good morning. I’m Meg 

17 Sullivan, again, with the Department of Energy. And 

18 this is the SNOPR Public Meeting for the AHAM-2 test 

19 procedure, and just a reminder, the NOPR was 

20 published December 9, 2008, and this SNOPR was 

21 published the end of June, and today is the meeting.

22 We’re interested in comments on this SNOPR 

23 from all of you. Transcripts will be available and 

written comments need to be in by August 30th 24 , and 

25 that can be done through the AHAM-2 e-mail address, 
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1 or on regulations.gov, and we will review and 

2 consider all of your comments.

3 Just a brief history of this regulation. 

4 The final rule -- the first final rule for clothes 

5 dryers published in 1981 established provisions for 

6 measuring the energy factor. The first test 

7 procedure for room air conditioners was published in 

8 1977, which established provisions for measuring the 

9 energy efficiency ratio and incorporated ANSI and 

10 ASHRAE standards.

11 The EISA 2007 amended the Energy Policy 

12 and Conservation Act, directing the Department of 

13 Energy to incorporate standby and off mode energy 

14 consumption into its test procedures for clothes 

15 dryers and for room air conditioners. And the 

16 clothes dryers and room air conditioners test 

17 procedure, NOPR, which was issued in 2008 proposed 

18 amendments to the statutory requirements to 

19 incorporate measures of standby and off mode energy 

20 consumption. And we received comments regarding 

21 using the IEC standard, the second edition committee 

22 draft, and harmonizing with that.

23 After the 2008 test procedure and NOPR was 

24 published, DOE decided to allow for consideration of 

25 a revised version of the IEC standard, which was 
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1 expected to be published in 2009. However, we more 

2 recently found out that the IEC standard second 

3 edition was not expected to be published until the 

4 end of this year, which would not be in time for 

5 consideration of standby and off mode power 

6 consumption for the concurrent conservation 

7 standards rule making. 

8 So DOE decided to publish the SNOPR, to 

9 consider the new mode definitions from the most 

10 recent draft version of the IEC standard, which is 

11 the IEC standard 62301 committee draft for vote. 

12 DOE believes that such new mode definitions 

13 represent the best definitions available for the 

14 analysis and support of the SNOPR.

15 The framework document to consider amended 

16 energy conservation standards for residential 

17 clothes dryers and room air conditioners published 

18 in 2007 identifies revisions to the active mode test 

19 procedures for covered products, and DOE decided to 

20 conduct a rule making to address active mode test 

21 procedures after the December 2008 NOPR was 

22 published. And so active mode is also addressed in 

23 this SNOPR.

24 MR. BROOKMAN: So having finished with 

25 that overview, let’s provide an opportunity for 
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1 anybody that wishes to make brief summary remarks at 

2 this point. Wayne Morris.

3 SUMMARY REMARKS FROM PARTICIPANTS

4 MR. MORRIS: Thank you, Doug. Wayne 

5 Morris with AHAM. Meg, thank you for the 

6 consideration and I’d like to explain a couple 

7 things about the IEC 62301, if I could. I am a 

8 member of the International Committee on 62301, and 

9 serve as the U.S. tag chairman for the IEC standard. 

10 I can appreciate the difficulties that the 

11 slowness of this IEC process has prevailed on the 

12 Department, and believe me, none of us like what has 

13 happened with this very long, slow process of the 

14 situation with the IEC. And indeed, it’s also, I 

15 would mention, holding up some regulations that are 

16 occurring in Europe as well. So you’re not alone.

17 That said, I can tell you that the FDIS, 

18 or Final Draft International Standard, is due to be 

19 published by the Secretariat of the IEC this Friday, 

20 that’s what we’re hoping. It is only being held up 

21 because of the time it takes to do a French 

22 translation. I’m just telling it like it is.

23 There are a number of minor, I would call 

24 them, changes, but necessarily important changes in 

25 the FDIS. The committee draft for both, the CDV 
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1 that went out last August and votes were then 

2 compiled in February 2010, engendered a number of 

3 comments, fairly substantial, technical comments. 

4 That is a little bit odd to have very long and --

5 long series of comments come at the CDV stage. 

6 Usually those are dealt with in the CD stage, in the 

7 Committee Draft stage. 

8 The vote, however, was overwhelmingly in 

9 favor of the CDV version, and so in technical 

10 sequences this CDV was passed the way it was, but 

11 because there were a large number of comments, the 

12 Secretariat of the IEC asked the committee to go 

13 back and deal with these changes, which, throughout 

14 the spring, we did, in a series of meetings. That 

15 took place in February and March and that then 

16 resulted in the publishing, compiling of all that in 

17 April and May to get to the FDIS stage, and that’s 

18 where we are right now.

19 In sort of technical parlance, the FDIS 

20 stage will go through a voting, but it is 

21 perfunctory, and the only reason that somebody can 

22 vote different than what they voted the last time is 

23 if they have some technical reason for doing so. We 

24 don’t expect that to happen. 

25 The other thing about an FDIS stage is the 
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1 only thing that can be done in the FDIS stage is 

2 make grammatical types of changes. You cannot 

3 change anything of any substance at that stage. And 

4 so because of that, in most countries, an FDIS 

5 document is legally able to be referenced in a 

6 regulation. Now, I’m not saying that the U.S. 

7 handled that, that’s up to you all to decide in that 

8 situation, but in most countries an FDIS stage can 

9 be legally referenced as essentially the final 

10 version because the only thing you can do is put a 

11 comma or correct a spelling or something along that 

12 line. So that will happen, we believe, that the 

13 FDIS stage will occur this -- very soon, this week 

14 possibly. That was from the Secretariat. I got an 

15 e-mail yesterday.

16 I would mention that the FDIS will have a 

17 number of fairly substantial, when you look through 

18 the document and you look at the sort of the red 

19 line version, if you will, it will look as if 

20 there’s a large number of changes. They are 

21 clarifications in most cases. So for instance, the 

22 test room will have a large number of changes 

23 involving that section, however, I don’t think 

24 they’re going to involve anything that is of any 

25 substance to what our proceedings are. Because the 
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1 paragraphs that they’re adding, for instance, deal 

2 with ambient light conditions in the test room, and 

3 that’s particularly important because there are some 

4 appliances that are sensitive to light. They dim 

5 down in a bright light circumstance, and bright 

6 light in a dim light. So consequently, they had to 

7 make provisions for that, and specify the exact 

8 ambient light conditions.

9 The other thing that will be, I think will 

10 be substantial and will affect the Department of 

11 Energy is a fairly extensive addition of what’s 

12 called the uncertainty power measurement section. 

13 And that is a very important one because it will 

14 narrow down the differences that any two 

15 laboratories can measure. So it will result in more 

16 accurate measurements. So I do believe that it 

17 would be important for the Department to reference 

18 the FDIS because it will have more accurate 

19 measurement materials in it, for frequency response, 

20 term averaging, power measurement, all of the 

21 uncertainty activities are in here that will change 

22 in the FDIS document.

23 The sampling method is a whole new section 

24 that has been written in the FDIS. It deals with 

25 how you go about dealing with multiple samples as 
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1 whether they are representative of the field. And I 

2 think that that again is a very important section 

3 which will be of interest and of help to the 

4 Department in trying to get accurate measurements.

5 Average reading methods is a whole new 

6 section that will appear in this. So for that 

7 reason, and I won’t go into all of these, but for 

8 that reason and several others, I think it’s 

9 important that the Department reference the FDIS, 

10 and we would be glad to get you a copy of the FDIS 

11 as soon as it comes out. The Department does have a 

12 representative on the U.S. tag through Lawrence 

13 Berkley National Laboratories. And so as soon as it 

14 comes out, they would have a copy and they can 

15 certainly give it to you, or we can certainly make 

16 it available to you. It’s not a problem, or they 

17 can come directly from the Secretariat’s office in 

18 Geneva if you feel you need to see it passed 

19 directly from them for legal purposes or whatever. 

20 But I think what we would encourage is 

21 instead of using the CDV which still contains some 

22 items in there that needed some clarification, I 

23 think it would be important to have the FDIS be the 

24 blanket document that you use, and we will make 

25 those comments in our written submittal to the 
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1 Department at the time.

2 MR. BROOKMAN: So, Wayne, if you were to 

3 grossly characterize this, is there anything that’s 

4 significantly changed that would run contrary to 

5 what the Department of Energy is proposing?

6 MR. MORRIS: There are some definitional 

7 changes of -- I’m sorry, Wayne Morris with AHAM --

8 some definitional changes in here in regard to what 

9 is considered standby and off mode that probably 

10 will influence some of the elements that the 

11 Department has put into this SNOPR and to the slides 

12 that I had a chance to see this morning.

13 MR. BROOKMAN: And were you --

14 MS. KOHL: I’m sorry. This is Betsy Kohl 

15 from DOE. We were having a -- can you repeat that? 

16 You were just talking about the standby and off mode 

17 definitions?

18 MR. MORRIS: There are some changes to the 

19 way the off mode and standby mode are characterized. 

20 They’re slight, but they are important. And so, 

21 yes, I do believe they will influence the situation 

22 with the way that the Department has characterized 

23 some of the features and the elements that are in 

24 here. I don’t think that it’s gross, but I do think 

25 that it’s important changes. And particularly when 
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1 you get into this area of trying to read what is an 

2 off mode. Off mode becomes a very critical one, and 

3 the definition changes, very slight definitional 

4 change, but it will influence, I think, what the 

5 Department asks.

6 The other situation has to do with the 

7 expansion of the mode definitions that are in the 

8 Department’s EPCA mode definitions are more clearly 

9 clarified, I think, in the FDIS.

10 So without spending a huge amount of time 

11 here, I think there’s enough changes that the 

12 reference to the FDIS would be important and it 

13 probably also, then, when you see it, will want to 

14 go back and reconsider some of the elements that are 

15 in here, particularly as it applies to clothes 

16 dryers and some of the sensory mode situation, and 

17 to the room air conditioner where it refers to 

18 remote control situations. Those are the ones that 

19 I picked up as being most influenced by this.

20 MR. BROOKMAN: Okay. Wayne, as we’re 

21 going along today, and slide by slide, looking at 

22 the content, are you going to be able to describe 

23 how the FDIS stage document might influence these 

24 things in the DOE draft, or do you not have that 

25 information yet?
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1 MR. MORRIS: I would be real cautious 

2 about doing that, Doug. 

3 MR. BROOKMAN: Okay.

4 MR. MORRIS: The first one up is this 

5 issue of delay start, and I reviewed this and I will 

6 say I want to really take some time and study the 

7 FDIS versus what -- that you have in the slides on 

8 the CDV versus what’s going to come down in the 

9 FDIS. I just want to make sure that it doesn’t 

10 change anything. So we’ll probably have to do that 

11 in our written comments.

12 MR. BROOKMAN: So I would note that as a 

13 third party and also a tax payer, I think it’s 

14 really a smart thing for the Department of Energy to 

15 try and harmonize with the IEC. They made some 

16 significant accommodations to try to make this work, 

17 and they deserve a lot of credit for that, and 

18 Wayne, I appreciate you referencing this and talking 

19 about what’s going to make it even easier to 

20 continue with this process.

21 Okay, other then, comments here at the 

22 outset? Brief summary remarks about issues that 

23 matter to those in the room. Yes, Kevin.

24 MR. MESSNER: Yes. Kevin Messner for the 

25 AHAM. Just kind of an overview. Yes, SNOPR is very 
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1 lengthy and we’re still kind of going through it in 

2 a lot of detail. But we’ve also, in looking through 

3 it, I think there’s a lot detail that we have either 

4 not seen or not understanding, definitions, and 

5 things like that. And so -- for instance, on the 

6 auto-termination issue and others, so a lot of our 

7 comments, besides the standby issue, will be at a 

8 fairly high level throughout the day, in trying to 

9 understand this better, and trying to glean a little 

10 more details.

11 MR. BROOKMAN: Okay. Thank you. Other 

12 comments here at the outset? Okay, then, to James 

13 Battaglia.

14 COVERED PRODUCTS; STANDBY/OFF MODE: INCORPORATING 

15 BY REFERENCE IEC 62301

16 MR. BATTAGLIA: Hi everyone. The first 

17 topic that I’m going to be going through today is 

18 exactly what products are covered by the proposed 

19 amendments to the test procedures. And the 

20 definitions of covered products are provided in the 

21 Code of Federal Regulations under 10 CFR 430.2, 

22 which provides definitions for both gas and electric 

23 clothes dryers. And the key descriptors here would 

24 be that these are appliances that utilize a tumble25 type drum with forced air circulation, where the 
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1 heat source can either be gas or electric, depending 

2 on the type of dryer under test.

3 So it is anticipated that these proposed 

4 test procedure amendments would cover dryers that 

5 are both conventional vented type gas and electric, 

6 which would include standard size and compact size 

7 units, and also ventless clothes dryers, which would 

8 include combination washer/dryers.

9 Similarly, for room air conditioners, the 

10 same sections of the CFR provides that this product 

11 is distinct from a packaged terminal air 

12 conditioner, but that it is powered by a single 

13 phase electric current, and is designed for mounting 

14 in either window or through the wall, and further, 

15 it describes the function to provide conditioned air 

16 which can include not only cooling, but ventilation 

17 and heating as well.

18 So again, it’s anticipated that these 

19 proposed amendments would cover products that are 

20 roughly analogous with what were analyzing in the 

21 energy conservation standards, and namely, that 

22 these are room air conditioners that are for single 

23 or double hung windows, and under that category, 

24 they can either be with or without louvered sides, 

25 or with or without reverse cycle to provide a 
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1 heating function.

2 Additionally, the covered products would 

3 also include casement mounted, a casement slider or 

4 a casement only window-type room air conditioners.

5 So the next topic which we’re going to get 

6 into is the proposed amendments to the test 

7 procedure concerning standby and off mode.

8 STANDBY/OFF MODE: DETERMINATION OF MODES TO BE 

9 INCORPORATED

10 MR. BATTAGLIA: In the December 2008 test 

11 procedure NOPR, DOE had proposed to incorporate by 

12 reference certain sections from IEC 62301 first 

13 edition, for measuring both standby and off mode 

14 power. And the parts of IEC 62301 first edition 

15 that were proposed were from Section 4, relating to 

16 the supply voltage, frequency and waveform; 

17 secondly, the ambient room temperature conditions; 

18 and finally, the power measurement meter tolerances.

19 And DOE is also proposing to incorporate 

20 by reference clauses from Section 5 related to the 

21 testing methodology that’s used for standby and off 

22 mode testing. And specifically, these clauses would 

23 clarify that the measurement of standby mode is to 

24 be conducted at the lower power stage if there is a 

25 short duration higher power state that precedes it. 
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1 For example, if a display were to automatically dim 

2 or power down after a certain period of user 

3 inactivity, that measurement would take place at 

4 that lower power state.

5 Secondly, the IEC clauses provide a 

6 technique for measuring an average standby mode and 

7 off mode power, if the measurement is either stable 

8 or unstable. And for unstable power measurements, 

9 it provides a description for measuring a 

10 representative cycle of that power.

11 MR. BROOKMAN: Let’s pause right there. 

12 Questions? Comments surrounding this material? 

13 This is a lot of material. Okay, yes, you have a 

14 comment? Please use the microphone and say your 

15 name for the record. Right there. Yes. Your name 

16 for the record.

17 MS. TADDONIO: Christine Taddonio with the 

18 Energy Star Program. Just a quick clarification on 

19 the definition of a ventless clothes dryer? That 

20 does also include heat pump clothes dryers, is that 

21 correct?

22 MR. BATTAGLIA: If the heat pump dryer was 

23 a ventless design, yes it would -- would include 

24 that.

25 MS. TADDONIO: Okay. Thank you.
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1 MR. BROOKMAN: Thank you. Other questions 

2 or comments? Okay.

3 MR. BATTAGLIA: As we discussed a bit 

4 earlier, the IEC is developing an updated standard -

5 - I’m sure we all know, the second edition which DOE

6 first noted in the NOPR had an expected publication 

7 date of July 2009, and based on our review of the 

8 draft versions, we expected that the revisions would 

9 include different mode definitions. 

10 And as we discussed earlier, because the 

11 expected publication date got pushed out further and 

12 from what we knew before, it was expected to be --

13 not be published until late 2010, DOE decided to 

14 publish the SNOPR to consider the new standby/off 

15 and active mode definitions from the latest draft 

16 version of IEC 62301, which was designated as the 

17 committee draft for vote version. And DOE believes 

18 that these definitions expand upon the EPCA mode 

19 definitions that were proposed in the NOPR, and 

20 would provide additional guidance as to which 

21 functions are associated with each mode.

22 So, for these reasons, DOE is proposing to 

23 revise the proposed amendments to include 

24 definitions of standby, off, and active modes based 

25 on the provisions in IEC 62301 committee draft for 
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1 vote.

2 Now, getting back to the specific clauses 

3 from IEC 62301 first edition, for the testing 

4 methodology that was proposed in the NOPR, DOE 

5 didn’t receive any comments in response to the NOPR 

6 opposed to the proposed test methods and procedures, 

7 so therefore the SNOPR did not change DOE’s proposal 

8 from the NOPR to incorporate those specific clauses 

9 that we presented earlier.

10 So at this point, we’re inviting comments 

11 on the adequacy of IEC 62301 first edition for 

12 measuring standby and off mode in both clothes 

13 dryers and room air conditioners, and specifically, 

14 the suitability of incorporating the clauses from 

15 Section 4 and 5 that we have shown here.

16 MR. BROOKMAN: You can see the question, 

17 the comment box right there on the screen, so if --

18 I think it would be useful if you could be as 

19 specific as possible with these comments. Wayne.

20 MR. MORRIS: Wayne Morris with AHAM. I 

21 think that earlier I described this in detail, so I 

22 won’t go back through it again, but James, I think 

23 that we would object to using the first edition, and 

24 we would hope that the second edition FDIS would be 

25 more accurate and more up to date in almost every 
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1 one of the items that you’ve got listed down below 

2 there. So I think that -- and I think that it’s 

3 also -- the latest edition has taken into account a 

4 lot of comments from the energy efficiency advocate 

5 groups and others to try and narrow the differences 

6 down to allow for repeated testing to be better 

7 served and to create less possibility that different 

8 laboratories would get different results on this.

9 When you’re getting down into very, very 

10 small numbers -- I mean you’re talking about tenths 

11 or hundredths of a watt -- little differences of 

12 methods of testing can mean a lot to companies and 

13 to the Department. So it becomes more important to 

14 have accuracy than ever before. So one of the 

15 reasons why we spend a lot of time in this place.

16 MR. BROOKMAN: Thank you. Other comments 

17 related to this comment box? Okay.

18 MR. BATTAGLIA: So the next topic we’ll be 

19 discussing is the mode definitions -- modes and 

20 definitions that we’re proposing to incorporate. 

21 Now, in the NOPR, DOE proposed to define active, 

22 standby, and an off mode using EPCA mode 

23 definitions. And DOE noted that for active mode, 

24 the EPCA mode definition, which stated that the --

25 it’s a mode in which the product is connected to a 
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1 main power source, has been activated, and provides 

2 one or more main functions, was developed to be 

3 broadly applicable to many products. So in order to 

4 clarify the range of main functions, DOE had 

5 proposed in the NOPR to clarify those main functions

6 for each product.

7 So DOE also proposed in the NOPR to define 

8 multiple standby modes which included, for clothes 

9 dryers, the inactive modes, cycle finished mode, and 

10 delay start mode. And for room air conditioners, it 

11 was the inactive mode, delayed start, and off cycle 

12 mode.

13 So as we discussed a bit earlier, DOE is 

14 revising its proposed active mode, standby and off 

15 mode definitions, based on the IEC 62301 committee 

16 draft for vote version. Now DOE is proposing the 

17 following definition that we have here for active 

18 mode and that’s basically the same as we had with 

19 the EPCA definition, and it’s that “The energy-using 

20 product is connected to a main power source, has 

21 been activated, and provides one or more main 

22 functions.”

23 Now, the IEC committee draft for vote 

24 version, which was published prior to the committee 

25 draft for vote -- I’m sorry, the committee draft 2 
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1 version, which was published immediately before the 

2 committee draft for vote version, provided an 

3 additional clarification that delay start mode is a 

4 one-off user initiated short-duration function that 

5 would be associated with an active mode. 

6 Now, DOE noted that IEC 62301, the CDV 

7 version, removed this clarification, however, IEC 

8 stated in response to comments to the CD2 version, 

9 which ultimately led to the CDV version, that delay 

10 start mode is a one-off function of limited 

11 duration. And DOE inferred that delay start mode 

12 would not be considered a standby mode, however no 

13 conclusion was made as to whether it would be 

14 considered part of an active mode. In addition, for 

15 active mode, DOE is proposing to use the same 

16 clarifications that were proposed in the NOPR for 

17 the range of main functions that would be classified 

18 under this mode.

19 So again, based on the --

20 MR. BROOKMAN: I’m glad you’re pausing, 

21 just for a moment. That -- so anybody? Okay. 

22 Okay.

23 MR. BATTAGLIA: So based on the 

24 definitions in the CDV version, DOE is proposing 

25 here to define standby mode as “Any product modes 
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1 where the energy using product is using” -- I’m 

2 sorry -- “energy using product is connected to a 

3 mains power source and offers one or more of the 

4 following user orientated or protective functions 

5 which may persist for an indefinite time.” And the 

6 first would be to facilitate the activation of other 

7 modes which includes the activation or deactivation 

8 of active mode by remote switch, internal sensor, or 

9 timer. And the second part of that would be that it 

10 would be providing continuous functions, including 

11 information or status displays, or sensor-based 

12 functions.”

13 Now, DOE is also proposing to include an 

14 additional clarification that a timer is a 

15 continuous clock function which may or may not be 

16 associated with a display, that provides regular, 

17 scheduled tasks and operates on a continuous basis.

18 Now, based on the proposed definition of 

19 standby mode, delay start and cycle finished mode 

20 for clothes dryers and delay start and off-cycle 

21 mode for room air conditioners are not modes that 

22 persist for an indefinite time, so they wouldn’t --

23 would therefore not be considered part of standby 

24 mode.

25 DOE’s analysis of the annual energy use in 
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1 specific clothes dryers and room air conditioner 

2 modes that we presented in the NOPR determined that 

3 these modes each represent a negligible portion of 

4 point one percent or less of the annual use --

5 energy use for that particular product. So 

6 therefore, DOE believes an integrated efficiency 

7 metric for both products would not be measurably 

8 affected by either the inclusion or exclusion of the 

9 energy use in any of these modes.

10 Further, DOE believes that the benefit of 

11 incorporating the energy use in these modes into the 

12 overall energy efficiency would be outweighed by the 

13 burden that would be placed on manufacturers to 

14 measure power consumption in each of these modes. 

15 So for these reasons, DOE is not proposing 

16 amendments to the test procedure to define or to 

17 measure power consumption in each of these modes, 

18 and DOE is only including in the proposed 

19 amendments, provisions for measuring energy 

20 consumption in the inactive and off mode.

21 So here, again, we’re requesting comments 

22 on the proposed definition of standby mode, which is 

23 based on the CDV version of IEC 62301. I guess 

24 we’ll stop for that one first.

25 MR. BROOKMAN: Okay. Kevin.
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1 MR. MESSNER: Kevin Messner. Two things, 

2 and I’m sure there’ll be more as we delve into the 

3 details, but two things jumped out. One is on the 

4 remote control issue for RACs. One way of remote 

5 control should not be part of standby if it’s just -

6 - if you can just turn off the RAC, the room air 

7 conditioner with a remote control, the remote 

8 control doesn’t allow necessarily to interact with 

9 it, it just allows it to turn off, then you’re more 

10 apt to -- folks would be turning that off, so that 

11 should not be part of standby, we don’t believe.

12 And then the other issue we need to look 

13 into more in our written comments is the -- assuming 

14 that a timer function is actually a clock with a 

15 display. If it’s a timer function inherent in the 

16 appliance, it’s not a clock, and it seems that we 

17 need to look at that a little more and comment a 

18 little more fully on that. But that’s a bit of an 

19 expansion of the clock function.

20 MR. BATTAGLIA: Would you mind commenting, 

21 I’m sorry, I mean explain a little more what you 

22 mean by a one-way remote? Because I assume that for 

23 a room AC, with a remote you would have some sort of 

24 sensor, infrared sensor to receive that signal from 

25 the remote to shut it off, I guess.
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1 MR. MESSNER: Right, it would be one way, 

2 one way from the remote to the room air conditioner 

3 -- sorry -- one way remote, so that the remote is 

4 communicating to the room air conditioner, but it’s 

5 not necessarily obtaining signals back from the room 

6 air conditioner, so it can shut it off, but there’s 

7 nothing on the room air conditioner that’s going 

8 back and forth.

9 MR. BROOKMAN: You can turn it on, though?

10 MR. MESSNER: No.

11 MR. BROOKMAN: Oh, okay.

12 MR. MESSNER: You have to go turn it on.

13 MR. BROOKMAN: Okay. So that’s why you 

14 said it that way. Okay.

15 MR. MORRIS: Yes, this is Wayne. For 

16 clarification, these one way remotes are used, in 

17 fact, for just that reason, to try and reduce the 

18 amount of power that’s used in that function. And 

19 they allow a consumer, for instance, to shut the 

20 unit off in what some people call a “hard-off” kind 

21 of condition, so that once it’s shut off, then the 

22 room air conditioners is not listening constantly 

23 for a signal, and not using significant amount of 

24 power. It allows the consumer to turn it off and 

25 then it would require the consumer to actually, 
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1 physically get up and move across the room and push 

2 a button, if you will, an actual on/off button on 

3 the product. There is a slight bit of power in that 

4 room air conditioner in which it’s listening for 

5 that off signal, but it’s not a two-way 

6 communication device and so the signal strength is 

7 much lower.

8 Because of that, a number of other 

9 organizations and governments have viewed these one10 way remotes as essentially being exempt from the 

11 standby mode and have viewed them as being a good 

12 thing, in other words, they actually do save power. 

13 And because of that, they haven’t classified them as 

14 part of a standby function, and we would hope that 

15 the Department would do likewise.

16 As Kevin mentioned, the timer function, I 

17 guess I’m having trouble understanding, and maybe, 

18 James, you can explain to me, when you say a timer 

19 is a continuous clock function -- the timer is only 

20 set by the consumer on a clothes dryer when they 

21 move it into a timer sequence, in other words, they 

22 want to time dry. So why would this be viewed as a 

23 continuous clock function if it’s manually selected 

24 by the consumer and it only lasts for a defined 

25 period of time? Maybe I’m thinking of something 
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1 other than what you’re thinking of.

2 MR. BATTAGLIA: Right. This is my 

3 understanding of it, that it could be something like 

4 a -- some sort of timing device for a 

5 microcontroller in electronic controls that keeps 

6 time for that function.

7 MR. MORRIS: But according to the 

8 definitions in 62301, in any edition of 62301 that 

9 you go back to, something that is not a continuous 

10 function is not viewed as -- as standby.

11 MR. BATTAGLIA: Right. So if you had a, 

12 like a -- I’m not sure how familiar you are with the 

13 control boards, but like a microcontroller would 

14 have like a timer chip -- or a crystal that keeps 

15 time for the microcontroller, so it would be running 

16 at all times. It’s not like something that would be 

17 set by the user. That’s just one example that I can 

18 think of for these products that it would maybe 

19 apply to.

20 MR. MORRIS: Okay, but if the electronic 

21 board goes into a higher energy state when it is in 

22 its timer function, or if it goes into a higher 

23 energy state in a delayed start type of function, 

24 then that is a -- of a limited duration and would 

25 not be counted in this.
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1 MR. BATTAGLIA: Right, so -- yes, if it is 

2 a limited duration function, then you’re right, it 

3 would not be considered part of standby.

4 MR. MORRIS: Okay, I think the -- for that 

5 matter -- for the reason, I think it would be 

6 important that the Department in the final language 

7 that it uses be very careful that it delineates 

8 those situations. Thank you.

9 MR. BROOKMAN: Thank you. Okay. Helpful 

10 comments. Additional comments on these -- did we 

11 address the second comment box, James?

12 MR. BATTAGLIA: No, I don’t think so.

13 MR. BROOKMAN: I didn’t think we did 

14 either. Okay. Why don’t you read that into the 

15 record?

16 MR. BATTAGLIA: All right, so the second 

17 thing we’re inviting comment on is the establishment 

18 of inactive mode as the only standby mode for both 

19 clothes dryers and room air conditioners, and the 

20 determination that delay start modes, cycle finished

21 mode, and off cycle mode for these products would 

22 not be considered standby modes. And DOE is further 

23 inviting comment on the proposed mode definitions 

24 and on the question of whether there are any modes 

25 consistent with active, standby and off mode 
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1 definitions that have not been identified and that 

2 can represent a significant energy use.

3 MR. BROOKMAN: Okay. We’re not in a rush 

4 here. It’s a lot of words. Okay. No additional 

5 comments on this?

6 MR. BATTAGLIA: Okay, now based on --

7 sorry -- another topic regarding the modes and 

8 definitions -- sorry, I’m on the wrong slide here --

9 to be incorporated into the DOE test procedure is 

10 with a network mode. And DOE received comments in 

11 response to the NOPR that it should consider a 

12 network mode. Now, the IEC 62301 CDV version 

13 includes a definition of network mode which it 

14 defines as “a mode category which includes any 

15 product modes where the energy-using product is 

16 connected to a main power source and at least one 

17 network function is activated, such as the 

18 reactivation via network command, or network 

19 integrity communication, but where the primary 

20 function is not active.”

21 However, DOE is not aware of any clothes 

22 dryers or room air conditioners currently on the 

23 market that incorporate a networking function. And 

24 in addition, DOE is not aware of any data regarding 

25 network mode in these products which would allow it 
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1 to determine appropriate test procedures and mode 

2 definitions for incorporation into the DOE test 

3 procedure for both products. So, for this reason, 

4 the amendments -- the proposed amendments in the 

5 SNOPR do not include a network mode.

6 And here we’re requesting comment on this, 

7 on whether there are clothes dryers and room air 

8 conditioners that are currently available that 

9 incorporate a networking function, and whether 

10 definitions and test procedures for this mode should 

11 be incorporated into the DOE test procedure. And 

12 DOE would also request comments on appropriate 

13 methodologies for measuring the energy consumption 

14 in this mode, and data on the results and 

15 repeatability of such testing methodology.

16 MR. BROOKMAN: Kevin.

17 MR. MESSNER: Kevin Messner. Network mode 

18 is a big deal. It should not be part of standby. 

19 And it also -- it’s very important to remember is 

20 this is -- has huge implications to the development 

21 of the Smart Grid and Smart Appliances, which our 

22 industry is trying to move forward and trying to 

23 lead in that area, try to get Smart Grid going by 

24 having Smart Appliances in the home. It’s still in 

25 its infancy, and we’re trying to develop those 
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1 products, but having -- network mode has to be 

2 considered as a distinctive energy user that 

3 enhances the whole overall electrical grid, and the 

4 efficiencies that come with that, the savings of 

5 energy, the line losses, the reduced carbon 

6 emissions, the reduction of peaker plants, all of 

7 these benefits to come along with it. And for that 

8 reason, network mode has to be distinctive. It 

9 cannot be part of standby, and that would be a major 

10 stake in the heart of the development of Smart 

11 Appliances and the Smart Grid.

12 MR. BROOKMAN: Okay, thank you. Yes, 

13 please, Joanna.

14 MS. MAUER: Joanna Mauer. Just a 

15 clarification. So I know that definitions proposed 

16 by DOE would network mode not be considered part of 

17 standby?

18 MR. BATTAGLIA: We’re not proposing to 

19 include it at this time, so we haven’t yet made a 

20 determination.

21 MS. MAUER: Okay, and just to follow. I 

22 think we’d be concerned if it’s not considered part 

23 of standby or other modes, would just be considered 

24 then the energy use of network mode is not captured 

25 anywhere in the test procedure.
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1 MR. BROOKMAN: James, can you respond to 

2 that?

3 MR. BATTAGLIA: Well, I mean we’re not 

4 able to propose amendments at this time because 

5 we’re not familiar with how these products are going 

6 to work. So I guess it’s not clear if the operation 

7 under a network mode would fall under the definition 

8 of standby mode or not, it really depends on how 

9 those products are operating when they’re using that 

10 network function.

11 MR. BROOKMAN: You want to restate your 

12 concern, Joanna?

13 MS. MAUER: I think my concern is that it 

14 seems likely, as Kevin was saying, that products in 

15 the near future will have this network mode 

16 capability. And so I don’t have a specific 

17 suggestion for how it should be included, but the 

18 concern is that if say in a year or two, products 

19 are -- come out with network mode and that energy 

20 use is not captured anywhere in the test procedure.

21 MR. BROOKMAN: Okay. Subid.

22 MR. WAGLEY: Subid Wagley, US DOE. I was 

23 just going to suggest that if the stakeholders have 

24 any recommendations or suggestions or any sort of 

25 information to incorporate with their comments, that 
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1 we’d like to review that and, you know, look at it.

2 MR. BROOKMAN: Okay. It seems like we’re 

3 moving towards more of a balance sheet approach, 

4 right, because it -- like this, yeah. It’s getting 

5 more complicated, just what we need. Okay. Then 

6 let’s proceed.

7 MR. BATTAGLIA: And finally, as with 

8 active and standby mode definitions, DOE is 

9 proposing to define off mode using the definition, 

10 or based on the definition in the IEC 62301 CDV as a 

11 mode which includes any product modes for the 

12 energy-using product is connected to a mains power 

13 source and is not providing any standby or active 

14 mode function, and where that mode may persist for 

15 an indefinite time.

16 And we’re also proposing to include the 

17 additional statement that an indicator that only 

18 shows that the user -- that the user that the 

19 product is in the off mode position would be 

20 included within the classification of off mode.

21 MR. BROOKMAN: Yes, Wayne.

22 MR. MORRIS: Wayne Morris. Just to 

23 clarify, James, the definition that you read on off 

24 mode, is identical to what is in the FDIS.

25 MR. BATTAGLIA: Okay. Thank you.
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1 MR. BROOKMAN: Thank you.

2 MR. BATTAGLIA: Shall we move on?

3 MR. BROOKMAN: Let’s move on.

4 STANDBY/OFF MODE: ADDED SPECIFICATIONS TO THE TEST 

5 METHOD AND MEASUREMENTS

6 MR. BATTAGLIA: So the next topic we’ll 

7 get into is the added specification for the testing 

8 methods and requirements for standby and off mode 

9 testing. And these added specifications are 

10 necessary because the IEC 62301 was written in a 

11 general way to be applied to many products, so we’re 

12 including added specifications specific to these 

13 products.

14 So starting with the test period for 

15 clothes dryers, DOE understands that displays on 

16 clothes dryers may reduce the power consumption by 

17 automatically dimming or powering down after a 

18 period -- a certain period of user inactivity. So 

19 for those dryers for which the power input in active 

20 mode varies in this way, DOE is proposing -- or DOE 

21 proposed in the NOPR to have the test be conducted 

22 after the power level drops to the lower power 

23 state.

24 Now, the provisions in IEC 62301 first 

25 edition that were proposed in the NOPR, state that 
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1 For products in which the power is stable, which is 

2 to say that it would vary by not more than five 

3 percent from a maximum level during a period of five 

4 minutes, that we would wait at least five minutes 

5 for the product to stabilize, and then measuring the 

6 power at the end of an additional time period of not 

7 less than five minutes.

8 Now, alternatively, in cases where the 

9 power is unstable, which is to say that it varies by 

10 more than five percent, the IEC 62301 requires a 

11 measurement period of no less than five minutes, or 

12 one or more complete operating cycles, which could 

13 be several minutes or hours.

14 Now, in response to the NOPR, DOE received 

15 comments that the standby and off mode test 

16 procedures should specify a 30-minute stabilization 

17 period, and measurement period of at least ten 

18 minutes. And based on DOE’s testing, we noted that 

19 some dryers may actually remain in the higher power 

20 state for the duration of the five minute 

21 stabilization and five minute measurement period, 

22 and then finally drop to the lower power state, that 

23 would be more representative of inactive mode.

24 And the IEC 62301 CDV version specifies 

25 for each testing method that the product be allowed 
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1 to stabilize for at least 30 minutes prior to a 

2 measurement period of not less than ten minutes. 

3 And DOE believes that this clarification would allow 

4 sufficient time for delays that automatically dim or 

5 power down after a period of user inactivity, to do 

6 so before the measurement period has started. And 

7 DOE believes that this provision would allow for a 

8 representative measurement among products that may 

9 have varying times before the power drops down to 

10 its lower power state.

11 However, DOE also noted that allowing a 

12 test procedure -- or a test period -- of not less 

13 than or at least a specified amount of time, could 

14 result in -- in different test technicians testing 

15 the same product for different periods of times. So 

16 for this reason, to ensure that the testing 

17 procedure for standby and off mode is clear and 

18 consistent, so that different test technicians are 

19 using the same procedures, DOE is proposing to 

20 require a stabilization period of 30 to 40 minutes, 

21 and a test period of ten minutes.

22 MR. BROOKMAN: Yes, please. Say your name 

23 for the record.

24 MR. OMAR: I’M Farhad Omar, NIST. So how 

25 is energy captured during the stabilization time? I 
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1 didn’t hear that part.

2 MR. BATTAGLIA: The actual measured 

3 energy, standby or off mode energy wouldn’t be 

4 determined from that stabilization period. It’s 

5 just -- the product is allowed to stabilize for a 

6 period and then you begin the measurement.

7 MR. OMAR: Well, as we can see, some of 

8 these ways can consume a lot of power, especially if 

9 network mode is integrated with them. So maybe we 

10 can come up with something so we can measure the 

11 stabilization period. That 40 minutes of energy is 

12 a lot of energy. I mean millions of dryers are out 

13 there, so they could cost a lot.

14 MR. BROOKMAN: In -- the display function 

15 consumes a bunch of energy.

16 MR. OMAR: Well, not just display, but the 

17 whole thing, like the motor, whatever it is inside 

18 will take to stabilize the situation.

19 MR. BROOKMAN: Okay. Wayne Morris.

20 MR. MORRIS: Wayne Morris with AHAM. 

21 Well, I think that -- I’m not trying to totally 

22 answer your questions, but just to give you some 

23 indication. The purpose of the stabilization is to 

24 try and reach the steady state situation, to arrive 

25 at what is truly that definition of standby in which 
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1 it says that it will be going on for an extended 

2 period of time, an indefinite period of time, I 

3 believe is the definition. 

4 And so there are some products, I can use 

5 an example here because it doesn’t apply to these, 

6 but a clothes washer, for instance, that may 

7 remember a cycle setting for some period of time at 

8 the end of cycle, and it waits for you to then put 

9 the next set of clothes into the clothes washer to 

10 start the second load, for instance, and it will 

11 then prompt you to say, okay, I’m going to remember 

12 what the setting was on the first one, and then the 

13 consumer, all they have to do is push on, or power, 

14 or initiate the cycle, and I remembers the cycle. 

15 That amount of energy then is essentially included 

16 in the overall active mode situation of the clothes 

17 washer. Same thing would occur with a dryer.

18 So the problem comes that what happens if 

19 at the end of the first cycle, nobody does a second 

20 load? Well, it remains for a period of time, 

21 depending on the individual manufacturer how long 

22 they want to prompt that for, and then it powers 

23 down into that low level that is maintained. The 

24 trouble is that each manufacturer is going to be a 

25 different length of time. Each one’s going to have 
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1 different powering functions. Some step functions 

2 downward, rather than -- so where you take that 

3 measurement could be very important and could lead 

4 to inaccuracies if you measured it differently. 

5 That’s why the IEC really deals with this 

6 by saying, wait for a period of time in order to get 

7 to that. And I understand your point about the fact 

8 that there is energy being consumed in there. Yes, 

9 there is. But the problem with having to have a 

10 test procedure is we’re trying to arrive at a way 

11 that we can test every product that’s out there the 

12 same way. If different ones power down at different 

13 levels, we’ll never have an accurate measurement 

14 unless we wait some length of time.

15 Are we going to be missing some power in 

16 that? Yes, probably we will. Is it -- you know, 

17 when we consider the entire year what that amount of 

18 power level is for powering that board during that 

19 transitional period of time, I think that we’re 

20 talking about micromilli watt hours of energy, and 

21 we’re talking about products that now this test 

22 procedure reduces the number of cycles per year 

23 significantly, to where the amount of time spent in 

24 that transitional phase is going to be miniscule, 

25 and that’s what the department has mentioned in here 
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1 as well.

2 MR. OMAR: Thank you. I know that’s true 

3 but also active mode is defined as a forced ... cycle, 

4 so you determine right off so the time, like ten 

5 minutes, I think that’s the period, then we have 

6 some energy loss there, so can we come up with 

7 something that maybe we can measure that significant 

8 30 minutes of energy? Because we just don’t know. 

9 Every manufacturer has different products. Some of 

10 them may just stay in very high stage.

11 MR. BROOKMAN: Please say your name again?

12 MR. OMAR: Farhad Omar, NIST.

13 MR. BROOKMAN: Thank you. Okay, thank you. 

14 Do you have anything to say about this, James?

15 MR. BATTAGLIA: I mean, I might just add 

16 that we’re not exactly proposing to exclude the full 

17 30 minutes, it’s just as Wayne said, it’s allowing 

18 the product to stabilize. So we’re not like missing 

19 a 30 minutes of time after every active mode cycle 

20 in the -- in our annual energy use for standby or 

21 off mode.

22 MR. BROOKMAN: Wayne Morris.

23 MR. MORRIS: Wayne Morris with AHAM. I 

24 understand where you’re coming from, but because of 

25 this IEC 62301 dealt with this in terms of a note in 
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1 Section 3.4 in the FDIS, it says, “Any transition 

2 that occurs between modes, either through user 

3 intervention or automatically, is not considered to 

4 be a mode.” 

5 Now, there were no comments on that 

6 situation coming from anyone anywhere in the world, 

7 and there are 123 countries that had input to the 

8 IEC process. So, I understand what you’re saying, 

9 but there have been no comments to that.

10 MR. BROOKMAN: Okay. Thank you. Final 

11 comments on this subject before we move on?

12 MR. BATTAGLIA: Okay. Now regarding the 

13 set up for standby and off mode testing for clothes 

14 dryers. In response to the NOPR, DOE also received 

15 comments that the products should be configured in 

16 the factory, or default settings prior to the start 

17 of testing. Now DOE believes that provisions for 

18 setting up the appliance for standby and off mode 

19 testing should be specified in the test procedure, 

20 however, setting up the appliance in accordance with 

21 manufacturers’ instructions, or in the as shipped 

22 factory or default settings would allow 

23 manufacturers to ship appliances set in a low power 

24 mode that consumers may switch out of during typical 

25 standby or off mode use.
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1 So in order to provide a clear and

2 consistent testing method, DOE is proposing that the 

3 appliance be set up in the settings that produce the 

4 highest power consumption level, consistent with 

5 that particular mode under test for standby and off6 mode testing.

7 MR. BROOKMAN: Kevin, yes.

8 MR. MESSNER: Just a quick comment. 

9 That’s an important issue for us, that it should be 

10 at the factory default settings, otherwise, I mean 

11 each consumer -- what a consumer does on a typical -

12 - how they, when they take it out of the box and how 

13 they’re going to change things, or if they are going 

14 to change things, not sure how you get an accurate 

15 picture or representation across the nation. And by 

16 and large, people pick the box out, maybe, and those 

17 are the default settings. 

18 So we would encourage you to take another 

19 look at that. That’s all we have to say at this 

20 time, probably provide more in the written comments.

21 MR. BROOKMAN: I’m reading this the second 

22 time. I thought that was confusing. Do you have 

23 any follow on comments, James?

24 MR. BATTAGLIA: I mean I think the problem 

25 lies in what would be -- how we would specify in the 
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1 test procedure what would be the typical standby or 

2 off mode, and with all the different configurations 

3 that a dryer could be in, we had to come up with a 

4 clear and consistent method.

5 MR. BROOKMAN: And all these different 

6 manufacturers would have different default settings?

7 MR. MESSNER: Well are you saying you 

8 would go to the default setting as out of the box? 

9 Or that you wouldn’t?

10 MR. BATTAGLIA: No, we’re proposing right 

11 now to measure it in the highest -- the settings 

12 that produce the highest power.

13 MR. MESSNER: Right, which is -- just 

14 taking the most extreme example, which isn’t 

15 representative at all.

16 MR. BROOKMAN: Kevin, at this point you 

17 don’t have any specifics but you’ll provide them in 

18 your written --

19 MR. MESSNER: Well, it should be the 

20 default settings.

21 MR. BROOKMAN: Okay.

22 MR. MESSNER: I mean, that’s the most --

23 take it out of the box and install it, that’s 

24 generally what folks are doing.

25 MR. BROOKMAN: In your experience that’s 
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1 what consumers typically do?

2 MR. MESSNER: Well, if you’re looking at 

3 trying to figure out, it’s either the default 

4 settings or going to the most extreme, where 

5 everyone’s going to take it out of the box and set 

6 it to the most extreme setting, you know, I’m going 

7 to run all the stuff that’s on there and I’m going 

8 to open the operating manual and set all the -- go 

9 in and do all the codes and everything. I mean that 

10 100 percent of the time is probably an unrealistic 

11 estimate.

12 MR. BROOKMAN: Yeah. Wayne Morris.

13 MR. MORRIS: Wayne Morris with AHAM. I 

14 echo Kevin’s comments in here. The objective here, 

15 in our mind is to make sure that you have relevance 

16 and repeatability in these test procedures. 

17 Relevance being that you want to try and make sure 

18 that you’re doing it the way that it’s going to be 

19 seen by the consumer in their home. And so we’re 

20 going to be measuring energy the way that the 

21 consumer would see it.

22 Very important that we make sure that the 

23 -- that it’s repeatable, that is, when you test 

24 manufacturer dryer A and a different manufacturer 

25 dryer B, that you’re testing them the same way. And 
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1 if you don’t do that, if you are resetting the 

2 functions inside to try and arbitrarily find 

3 whatever the highest power setting is, that’s not 

4 representative to try and compare machines across 

5 this situation.

6 Now we grant you that it’s not easy to 

7 come up with this. But the best method we have 

8 found of doing this, and we’ve studied it for things 

9 like microwave ovens and others that are under 

10 consideration under the standby situation, is that 

11 you do it the way that the consumer receives it, 

12 plugs it in, and whatever power setting that it’s in 

13 there is typically going to be the way that the 

14 consumer is going to start out with that product, 

15 and probably return to each and every time. So it’s 

16 a default kind of situation in which your studying 

17 it down to the way the consumer is going to most 

18 likely use it, and thereby it’s going to also be in 

19 a condition that is comparable from one machine to 

20 another across the range of all the manufacturers 

21 and all the different models of clothes dryers that 

22 there are.

23 If you don’t do it this way, then each 

24 technician that sets this up is going to be setting 

25 it up a different way. Maybe some of them are going 
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1 to turn five functions on, some are going to turn 

2 four functions on. Maybe some are going to look at 

3 the instruction manual and say, well, that’s not 

4 likely to occur, that would be something that a 

5 consumer would only do like once upon a blue moon, 

6 in clean cycle or something like that, so no, I’m 

7 not going to put that setting.

8 So then you get into differences of

9 whether the manufacturer’s test lab and the DOE’s 

10 test lab, and a reference test lab are going to ever 

11 be all doing it the same way. This allows you, by 

12 doing it this way, everybody’s going to do it the 

13 same way. And I think that’s extremely valuable, 

14 especially if we get into the need to .. zone, and 

15 Energy Star also, it’s for verification of energy 

16 numbers. We’ve got to be very concerned that 

17 whatever we do, we do it absolutely the same way 

18 each time. And this would allow it. Any other 

19 methodology is up to every test technician.

20 MR. BROOKMAN: Okay. Thank you. Anything 

21 additional? Okay. Yes, please. Use the 

22 microphone. Is it Kristin?

23 MS. TADDONIO: Chris Taddonio again from 

24 Energy Star. Could you please comment on what the 

25 difference is in energy consumption based on the 
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1 lowest setting or the highest setting might be? Are 

2 we talking about a large range? That would be 

3 helpful, thank you.

4 MR. BATTAGLIA: I mean I don’t have any --

5 we don’t have any data at this time, looking at the 

6 range between the lowest and highest. I assume it 

7 wouldn’t be a huge number, maybe between a watt or 

8 so, but that’s just a guess at this point. I don’t 

9 have any data to base that on.

10 MR. BROOKMAN: Okay. Additional comments? 

11 Yes, Joanna.

12 MS. MAUER: Joanna Mauer. I’d just like 

13 to say that I think it’s a valid concern that DOE’s 

14 attempting to address. If you use the default 

15 settings, then manufacturers would have an incentive 

16 to ship the product in a very low power mode that 

17 consumers may end up never using. So I think the 

18 concern is valid, so -- there might be kind of 

19 issues with using the defaults.

20 MR. BROOKMAN: The manufacturers would 

21 also have an interest in having a functional 

22 appliance.

23 MS. MAUER: Right, but it doesn’t mean 

24 that there won’t be settings that consumers could 

25 easily adjust.
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1 MR. BROOKMAN: Okay. Kevin.

2 MR. MESSNER: Well, I was just going to 

3 say that -- this is Kevin Messner. The other point 

4 is if you want to incentivize manufacturers to send 

5 in the higher setting so every consumer would take 

6 it out of the box and use the most energy, that 

7 doesn’t seem like it’s achieving it. I mean it 

8 seems that if we’re trying to save energy, shipping 

9 it so the consumer is more apt to use the lowest 

10 energy use is a better way to proceed than shipping 

11 it where it’s in the highest energy use. Most 

12 people don’t ever change it, they just plug it in. 

13 So it would seem to be more advantageous, if you’re 

14 trying to save energy, to go to ship it in the 

15 lowest possible setting.

16 MR. BROOKMAN: Do you want to follow on, 

17 Joanna? No? Kevin. Pardon me, Wayne.

18 MR. MORRIS: Wayne Morris. Let me follow 

19 up with that as well, what Kevin said. And the 

20 other issue is, the incentive to the manufacturer is 

21 to have a satisfied consumer. If the consumer 

22 doesn’t know how to operate the product, or they 

23 take a product out of the box and it takes them to 

24 pour through instruction manuals and so forth to 

25 figure out how to turn displays on and how to get 
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1 the unit into an operational mode, it’s going to be 

2 one very upset consumer that is then going to call 

3 the 1-800 line and probably not buy from that 

4 manufacturer again.

5 So the incentive is for the -- the most 

6 important incentive is to have a satisfied consumer, 

7 because, a, they’re going to return the product, or 

8 b, the consumer is not going to buy from that brand 

9 and that manufacturer again. That is, believe me, a 

10 whole lot more incentive than any incentive to try 

11 and get around a Department of Energy rulemaking or 

12 energy level.

13 So the incentive here is to make sure that 

14 you ship the product in a way that the consumer can 

15 pull it out of the box, if you will, or uncrate it, 

16 and plug it in, and have it functional almost 

17 immediately, with a very little amount of consumer 

18 interface to that situation. So it’s got to be in a 

19 functional state, and that is far more important 

20 than anything else. And I think that to think that 

21 a manufacturer is going to find some arbitrary 

22 extremely low level of energy state that requires 

23 the consumer to have to go through gyrations to get 

24 to a normal situation -- that’s not going to happen.

25 MR. BROOKMAN: Additional comments? Okay.
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1 MR. BATTAGLIA: Now, switching over to 

2 room air conditioners. For those added 

3 specifications, DOE proposed in the NOPR to require 

4 that the test room temperature be maintained at 74 

5 plus or minus two degrees Fahrenheit, and that the 

6 temperature control setting would be set to 79 

7 degrees Fahrenheit. Now, in response to the NOPR, 

8 DOE received a number of comments stating that the 

9 proposed room temperature conditions would be a 

10 testing burden. 

11 Now, as part of the room air conditioner 

12 standards preliminary analyses, DOE conducted some 

13 standby and off mode testing on representative room 

14 air conditioners, and during these tests, DOE 

15 determined that the displays among units tested 

16 don’t provide any user information in inactive mode, 

17 and in addition, for delay start mode, they’d be 

18 providing the time delay or time remaining until 

19 start on the display. So DOE believes that the 

20 ambient conditions that we proposed in the NOPR 

21 would be relevant for only an off cycle mode.

22 So then since we’re not proposing to -- so 

23 if the test procedure is limited to measuring of a 

24 single standby mode, then the proposed close 

25 tolerance on the ambient temperature would not be 
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1 required. So because DOE isn’t proposing in the 

2 SNOPR to measure or define off cycle mode, we’re 

3 proposing -- we’re revising our proposal to provide 

4 more flexibility in the room temperature conditions 

5 by allowing standby and off mode testing in either a 

6 test chamber used for the cooling performance test, 

7 or in a separate test room that would meet the 

8 temperature conditions specified in IEC 62301.

9 Now, DOE also notes that the indoor

10 temperature conditions for the cooling performance 

11 test and the cooling DOE test procedure would fall 

12 within those temperature conditions specified by IEC 

13 62301.

14 And here we’re requesting comments on this 

15 proposed temperature range for standby and off mode 

16 power measurements for room air conditioners, and 

17 also those test room conditions for clothes dryers 

18 which was also the same. It was that the IEC 62301 

19 specifications.

20 MR. BROOKMAN: Kevin.

21 MR. MESSNER: Kevin Messner. Okay, just a 

22 little -- was confusing for us. I think you might 

23 have clarified it. So the ambient temperature range 

24 could either be the current DOE test procedure or 

25 the IEC?
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1 MR. BATTAGLIA: Right, because the DOE 

2 test procedure is within that IEC range. So if you 

3 follow the DOE test procedure, you’d be in a tighter 

4 tolerance than what is in IEC 62301.

5 MR. MESSNER: Okay, so it would be the 

6 ambient temperature ranges would be -- what you’re 

7 proposing now would be what -- so you wouldn’t have 

8 to test the room air conditioner in a test chamber 

9 at a certain ambient condition, and then have 

10 another test chamber to retest standby, you could do 

11 it all right there in the same?

12 MR. BATTAGLIA: Right.

13 MR. MESSNER: Okay. Good.

14 MR. BROOKMAN: Other comments? You can 

15 see the comment box, there, the ambient temperature 

16 range for standby mode and off mode power 

17 measurements. Joanna.

18 MS. MAUER: Joanna Mauer, just a quick 

19 question. Has DOE done any testing to see whether 

20 there’s any significant difference in the power 

21 measurements between the two temperature conditions?

22 MR. BATTAGLIA: No, I don’t think we have 

23 data looking at the, like the min/max range of 

24 temperature conditions. But from my experience, I 

25 don’t think that it would affect the standby or off 
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1 mode measurements significantly. And that’s just a 

2 guess on my part. Again, we don’t have data looking 

3 at the standby at different temperatures.

4 MR. BROOKMAN: Okay? 

5 MR. BATTAGLIA: Okay, so for the room air 

6 conditioner test period, in the NOPR, DOE proposed 

7 the same standby and off mode testing period that it 

8 did for dryers, and those are the IEC first edition 

9 test periods. And again, similar to dryers, we 

10 received comments that the standby and off mode test 

11 procedures should specify a 30 minute stabilization 

12 period and measurement period of not less than ten 

13 minutes.

14 However, for room air conditioners, DOE 

15 isn't aware of any information or data that would 

16 suggest that the stabilization period --

17 stabilization and measurement periods would produce 

18 more representative or consistent measurements than 

19 the time periods that we proposed in the NOPR. 

20 Again, DOE noted that allowing a test 

21 period of not less than -- or at least a specified 

22 amount of time as provided in the IEC 62301 might 

23 result in different test technicians using different 

24 time periods, so for room air conditioners, to 

25 provide a more clear and consistent approach, DOE is 
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1 proposing to require a stabilization period of five 

2 to ten minutes, and a test period of five minutes. 

3 Sorry, I wasn’t on the right slide there.

4 MR. BROOKMAN: Okay.

5 MR. BATTAGLIA: Now if there are no 

6 comments on that, I think we have a scheduled break 

7 for --

8 MR. BROOKMAN: Yeah, let’s do that. Thank 

9 you. I wasn’t quite sure where we were in the 

10 agenda, to be frank. It’s 10:30. Let’s take a 

11 break. We’ve made good progress. Good comments all 

12 the way around this morning. We’ll continue that 

13 when we return at 10:45. Please wear your badges in 

14 the building. There are rest rooms at both ends of 

15 the hall, and they’re stacked up and down in the 

16 building. So if you’re going to go get coffee, go 

17 quickly. There’s one on the ground floor directly 

18 beneath us on the other side of the hall, and we’ll 

19 see you back here -- we’ll resume at 10:45.

20 (Whereupon, the meeting was off the record for 

21 an 18-minute morning recess.)

22 MR. BROOKMAN: Let’s resume.

23 STANDBY/OFF MODE: CALCULATION OF ENERGY USE, 

24 MEASURES OF ENERGY CONSUMPTION

25 MR. BATTAGLIA: All right, so the next 
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1 topic we’re going to discuss is the actual energy 

2 use -- is how the actual energy use associated with 

3 standby and off modes is calculated.

4 So starting with clothes dryers, the 

5 active mode energy use is currently expressed in 

6 terms of total energy use per drying cycle. And as 

7 we’ll get into it a bit later in the presentation,

8 DOE determined that it’s technically feasible to 

9 incorporate standby and off mode energy use into the 

10 overall metric as required by the EISA amendments to 

11 EPCA. So as a result of this, DOE examined standby 

12 and off mode energy consumption in terms of annual 

13 energy use apportioned on a per cycle basis, since 

14 the current DOE test procedure measures the active 

15 energy used during a drying cycle. 

16 So, in the NOPR, DOE had proposed 

17 estimates for the annual hours and approximate 

18 annual energy use for all the different clothes 

19 dryer modes that were proposed in the NOPR, and as 

20 you can see here, those values -- the values here 

21 are presented for the hours the annual energy use, 

22 and also the typical wattage for each mode.

23 So DOE believes under the proposed standby

24 and off mode definitions that the allocation of 

25 hours for inactive and off mode presented here are 

26 appropriate, based on comments to the NOPR. So as a 
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1 result, the NOPR has not changed DOE’s proposal for 

2 the allocation of hours.

3 MR. BROOKMAN: Yes, Wayne.

4 MR. MORRIS: James, could you just explain 

5 maybe a little bit here. I think I understand what 

6 delay start is, but what do you mean by the term 

7 “cycle finished”?

8 MR. BATTAGLIA: So cycle finished mode 

9 would be like a sort of a signal at the end, when 

10 the dryer cycle is completed, so it might have like 

11 a beeping or just like a display that says end of 

12 cycle, or cycle, or your clothes are ready, or 

13 something like that.

14 MR. MORRIS: You might want to revise that 

15 to like heat cycle finished.

16 MR. BATTAGLIA: Okay.

17 MR. MORRIS: The full cycle isn’t finished 

18 until the clothes are, in fact, cooled down, in 

19 order to reduce the wrinkling, but the heater turns 

20 off at some point, and I think that’s what you mean, 

21 right?

22 MR. BATTAGLIA: No, actually it would be 

23 the end -- if -- you’re talking about like a cool 

24 down period?

25 MR. MORRIS: Right.
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1 MR. BATTAGLIA: So it would be the end of

2 cycle -- the dryer is signaling the clothes are 

3 completely finished and you’re ready to take them 

4 out.

5 MR. BROOKMAN: It’s that beep at the end.

6 MR. BATTAGLIA: Yeah, there’s like a beep, 

7 maybe, or something on the display might tell you 

8 that your clothes are ready or something.

9 MR. MORRIS: But this is saying that 429 

10 hours are spent in that mode. I don’t understand.

11 MR. BATTAGLIA: So I think in the NOPR we 

12 -- I might be wrong on this -- but I think we 

13 proposed or estimated that a clothes dryer would 

14 spend like an hour in this mode, say, before the 

15 user comes and opens up the dryer to shut off that 

16 mode.

17 MR. MORRIS: But that’s -- how many cycles 

18 are in the dryers now, in the NOPR? 280?

19 MR. BATTAGLIA: 283.

20 MR. MORRIS: So this is twice -- another 

21 30 percent more hours?

22 MR. BATTAGLIA: Right. So maybe --

23 MR. MORRIS: And it’s up for an hour 

24 afterwards, you’re assuming?

25 MR. BATTAGLIA: I think that was the --
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1 MR. BROOKMAN: What would you suggest 

2 would be an appropriate number of hours there? 

3 Maybe you need to go back and --

4 MR. MORRIS: This is Wayne. I still don’t 

5 -- I guess maybe I’m dense today. I still don’t 

6 understand what this is, so it would be hard for us 

7 to give you a number until we understand what it is.

8 MR. BROOKMAN: And active is 

9 understandable, right?

10 MR. MORRIS: Right.

11 MR. BROOKMAN: As is delay start?

12 MR. MORRIS: And I would assume active in 

13 this case includes both any time that the dryer is 

14 accomplishing its main function.

15 MR. BATTAGLIA: Right.

16 MR. MORRIS: It is drying and/or cool down 

17 cycle?

18 MR. BATTAGLIA: Right, so yes, tumbling 

19 with forced air circulation, with or without cooling 

20 -- with or without heating, sorry.

21 MR. MORRIS: And I understand delay start. 

22 So what -- what then is the cycle finish?

23 MR. BROOKMAN: Cycle finished is that when 

24 -- has the drum stopped and it’s just cooling down?

25 MR. BATTAGLIA: No, it’s after the cool 
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1 down, so it’s just telling you that the cycle, the 

2 drying -- your user selected cycle is complete.

3 MR. MORRIS: Well, it would seem that that 

4 would be that transitional mode --

5 MR. BATTAGLIA: Right.

6 MR. MORRIS: -- of 30 minutes.

7 MR. BATTAGLIA: Right. So in the NOPR we 

8 had proposed that this was an actual standby mode, 

9 but as we’ll get into, or as I think I mentioned 

10 earlier, we’re not proposing that cycle finished or 

11 delay start mode would be considered under standby 

12 mode.

13 MR. MORRIS: So it would seem, though, 

14 that when you’re calculating, the cycle finished 

15 mode would be 30 minutes times the number of cycles 

16 per year.

17 MR. BATTAGLIA: I guess it would depend on 

18 the time of the display or whatever is how long that 

19 is showing you that the cycle is finished.

20 MR. BROOKMAN: Okay.

21 MR. MORRIS: Okay. I’ll pass.

22 MR. BROOKMAN: So I’m just thinking that

23 in your comments, are you now in a position where 

24 you can respond to this? Wayne?

25 MR. MORRIS: Wayne Morris. I guess we 
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1 would like to survey the manufacturers a little more 

2 to find out what they consider this to be and what 

3 the opportunities are, I guess. Just intuitively, 

4 though, if the cycle finished mode is the 

5 transitional time to the off mode, then by what you 

6 just said in a few slides ago, that up to a maximum 

7 of 30 minutes, then I don’t -- maybe my math is 

8 maybe different, but it would seem to be 283 divide 

9 by two, and that would be your number of hours in 

10 cycle finish mode, but maybe not. Maybe there are 

11 some differences in the different dryers and we need 

12 -- and how long it spends -- and so we need to 

13 survey and get back to you in our written comments.

14 MR. BROOKMAN: Okay. It strikes me that 

15 this is a heck of a lot of precision, because the 

16 annual energy use is miniscule. Right?

17 MR. BATTAGLIA: Judy, you had a comment?

18 MS. REICH: Hi. Judy Reich. Perhaps I 

19 can shed a little bit of light on why there’s a 

20 difference between the 30 minute stabilization 

21 period and the time that we’re assigning to the 

22 cycle finish mode. In measuring standby power, the 

23 measurement is not conducted at the termination of 

24 an active mode, it is conducted independently, so 

25 essentially you’re plugging the product in, and then 
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1 you’re waiting for possibly for a display that may 

2 be activated to go into a power down mode, and 

3 that’s the 30 minute cycle, 30 minute time period. 

4 When you actually run the dryer and complete a 

5 cycle, there may be a time period that the 

6 manufacturer keeps the display energized to say, 

7 we’ve finished, and that may be different than the 

8 time period where it’s just sitting static and you 

9 wait for it to go into the power down mode.

10 MR. BROOKMAN: I see. Thank you, Judy. 

11 That was helpful. Yeah, Wayne.

12 MR. MORRIS: This is Wayne Morris. Okay, 

13 then to get that 429 from the 34 hours of delay 

14 start, is that based on a survey that you all have 

15 run or --

16 MR. BATTAGLIA: No, in the NOPR we noted 

17 that we’re not aware of any consumer usage data to 

18 give us a precise number, so this is the estimate 

19 that we came up with in the NOPR.

20 MR. BROOKMAN: Okay. Thanks. So that was 

21 -- I think we’re starting to get that. Joanna.

22 MS. MAUER: Joanna Mauer. I just -- this 

23 is maybe going back to something discussed earlier, 

24 but just a clarification on how delay start and 

25 cycle finished are treated. So I understand that 
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1 DOE is not proposing to separately -- establish 

2 these as separate modes that would have separate 

3 power measurements, but are the hours allocated to 

4 delay start and cycle finished included in standby 

5 for the purposes of calculating the standby annual 

6 energy use?

7 MR. BATTAGLIA: Yes, that’s correct.

8 MS. MAUER: Okay. Thank you.

9 MR. BROOKMAN: Okay. Additional comments? 

10 We’re going to move on.

11 MR. BATTAGLIA: Okay, and this slide, 

12 there’s actually a change from the slide that got 

13 printed out. When these got printed out we had made 

14 extra changes. So we refer to the presentation up 

15 here. So as we discussed earlier, when we discussed 

16 the mode definitions, DOE determined that delay 

17 start and cycle finish modes for clothes dryers are 

18 not standby modes according to the proposed 

19 definitions, and these modes each represent a 

20 negligible portion, which is point one percent or 

21 less of the annual energy use, and so DOE determined 

22 that it would be more appropriate, under a 

23 simplified approach, to allocate the hours 

24 associated with delay start and cycle finished modes 

25 to the off and inactive.
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1 So because we’re not proposing to measure 

2 delay start and cycle finish modes in the dryer test 

3 procedure, DOE is proposing to maintain the estimate 

4 of 8620 hours as the non-active hours that would be 

5 allocated to inactive and off mode.

6 Now, in the NOPR, DOE proposed to allocate 

7 the number of hours for the combined off and 

8 inactive modes entirely to either off or standby 

9 mode as appropriate if the product only has one of 

10 these modes possible. And if the product has both 

11 modes possible, we would distribute those hours 

12 equally between the two modes. And the SNOPR is not 

13 changing this proposal from the NOPR for the 

14 allocation of hours between inactive and off modes.

15 MR. BROOKMAN: Kevin.

16 MR. MESSNER: I just had a question, just 

17 trying to -- the number of hours in a year?

18 MS. REICH: Yeah it would be over 1000.

19 MR. BATTAGLIA: Yeah.

20 MR. MORRIS: That’s where I’m -- I can’t 

21 remember how many hours in a year off the top, but 

22 8600 sounds pretty close.

23 MR. BATTAGLIA: Right, I think it’s 8760 

24 hours per year.

25 MR. MORRIS: Is it 8760, so 8760 and 
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1 you’re subtracting 140.

2 MR. BATTAGLIA: 140.

3 MR. MORRIS: Oh, okay, and all of --

4 MR. BATTAGLIA: All of those hours would 

5 be allocated to inactive and off.

6 MR. MORRIS: Inactive and off. Inactive 

7 is standby? Or --

8 MR. BATTAGLIA: Right, that’s the only 

9 standby mode that we’re proposing.

10 MR. MORRIS: Okay. Got you. Thank you.

11 MR. BROOKMAN: Other comments? Okay.

12 MR. BATTAGLIA: All right. So, to 

13 summarize, DOE is proposing to amend the clothes 

14 dryer test procedure to calculate the dryer energy 

15 use per cycle associated with the standby and off 

16 modes, by first calculating the product of the 

17 wattage and allocated hours for standby and off 

18 mode, depending on which modes are possible, and 

19 then summing the results, and then finally dividing 

20 by 1000 to convert from watt hours to kilowatt hours 

21 -- oh, I’m sorry -- and finally dividing by 283 

22 cycles per year to get a per cycle measurement.

23 So here we’re seeking comments on the 

24 approach for determining total energy use for 

25 standby and off mode for clothes dryers, including 
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1 the accuracy and test burden. And we’re also 

2 inviting comments and requesting data for the 

3 estimates for the annual hours associated with each 

4 mode, including the 140 hours specified by the 

5 current test procedure for active mode.

6 MR. BROOKMAN: Comments? No? We’re all 

7 set.

8 MR. BATTAGLIA: All right. So now for 

9 room air conditioners, in the NOPR, DOE noted that 

10 it wasn’t aware of any reliable data for the hours 

11 spent in each of the different standby modes and off 

12 modes for room air conditioners, so DOE estimated 

13 the annual hours for standby and off modes, and the 

14 relative magnitudes of the relative energy use in an 

15 example of a representative 8000 BTU per hour and 9 

16 EER unit that has all these modes. And these 

17 proposed estimates from the NOPR are presented here 

18 in this table.

19 MS. LOWENBERGER: Amanda Lowenberger. One 

20 thing that we noticed that we think is missing is 

21 there’s reference to 705 fan only active mode hours, 

22 that’s not included in this table or in the SNOPR, 

23 and we were wondering if that’s an intention 

24 omission or if that’s something that needs to be 

25 looked at.
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1 MR. BATTAGLIA: Sorry, there’s --

2 MR. BROOKMAN: And I also had a hard time 

3 hearing you, so if you can put the mike right close 

4 to your face. Try it again.

5 MS. LOWENBERGER: There are 705 fan only 

6 hours that are considered active mode that are 

7 referenced in the SNOPR but not used in any of the 

8 calculations, and we’re wondering if that was an 

9 intentional omission.

10 MR. BATTAGLIA: I’ll have to get back with 

11 you on that. I’ll have to take a look at those 

12 estimates again.

13 MS. LOWENBERGER: Yeah, we’d appreciate it 

14 if you’d look at that, and include those hours in 

15 the annual energy consumption calculations and the 

16 cost estimates.

17 MR. BROOKMAN: And so we’ll all know --

18 where did you spot that?

19 MS. LOWENBERGER: That’s in a footnote.

20 MR. BROOKMAN: In the Federal Register

21 notice?

22 MS. LOWENBERGER: Yes.

23 MR. BROOKMAN: Okay. Thank you.

24 MS. LOWENBERGER: Yes, it’s on Page 37610.

25 MR. BROOKMAN: Okay, thanks for that. 
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1 James will check on that.

2 MR. BATTAGLIA: So again, as with dryers, 

3 DOE determined that delay start and off cycle modes 

4 are not standby modes according to the proposed 

5 definitions for the SNOPR, so DOE is not proposing 

6 to measure power consumption in these modes for the 

7 room air conditioners test procedure. And again, 

8 there was a slight modification in the slide. So 

9 for the reasons that we discussed for dryers, that 

10 these modes each represent a negligible portion of 

11 the annual energy use, so DOE determined that it 

12 would be more appropriate under a simplified 

13 approach to allocate the hours associated with delay 

14 start and cycle finish modes to the off and inactive 

15 modes.

16 So we’re proposing here to use the 

17 estimate of 5115 hours as the non-active hours that 

18 would be allocated to inactive and off modes for 

19 room air conditioners.

20 Now, again, for units that incorporate 

21 both off and inactive modes, we’re proposing that 

22 the hours be allocated equally and for a unit that 

23 would have only one of these modes, that the full 

24 hours would be allocated to that mode as 

25 appropriate.
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1 So again, to summarize for room air 

2 conditioners, DOE is proposing to calculate the 

3 annual energy use associated with standby and off 

4 modes by calculating the product of the wattage and 

5 allocated hours for standby and off modes, depending 

6 on which mode is possible, summing the results, and 

7 then dividing by 1000 to get to kilowatt hours. 

8 So again, we’re seeking comment on 

9 determining -- the approach for determining the 

10 total energy use for standby and off modes for room 

11 air conditioners, and also inviting comments and 

12 requesting data on estimates for the annual hours 

13 associated with each mode, including our estimates 

14 for unplugged hours, which we didn’t have listed 

15 here, but it’s 2190 hours that was presented in the 

16 NOPR.

17 MR. BROOKMAN: Questions? Yes, please, 

18 Christine.

19 MS. TADDONIO: Is DOE --

20 MR. BROOKMAN: Christine, we want this on 

21 the record.

22 MS. TADDONIO: Of course.

23 MR. BROOKMAN: Yes, thank you.

24 MS. TADDONIO: Is DOE planning to update 

25 the hours, the assumptions, from 750 for active to 
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1 something lower?

2 MR. BATTAGLIA: We’ll get into that later, 

3 but we’re not proposing a change to that number at 

4 this time.

5 MR. BROOKMAN: Would you recommend that 

6 they consider changing the number of hours?

7 MS. TADDONIO: Well, I believe I just read 

8 that an updated residential energy use consumption 

9 surveys, the numbers of active operating hours had 

10 been lower, closer to around 500. Off the top of my 

11 head, I think that was the 1995 survey, which I 

12 believe was even more up to date than the 750 hour, 

13 but you would know better than I would.

14 MR. BROOKMAN: Okay, thanks for that.

15 MR. BATTAGLIA: And we’ll get into the 

16 explanation for why we’re keeping the 750 hours 

17 later in the presentation.

18 MR. BROOKMAN: Okay. You see the comment 

19 box there. Questions? Comments related to that 

20 query? Okay.

21 MR. BATTAGLIA: Okay. And the last topic 

22 for standby and off modes which we’ll discuss is the 

23 proposed measures for energy consumption that 

24 incorporate these energy consumptions. So in the 

25 NOPR, DOE had proposed combined metrics addressing 
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1 all the active modes, standby and off modes for both 

2 clothes dryers and room air conditioners. And for 

3 clothes dryers, DOE proposed a per cycle integrated 

4 total energy consumption expressed in kilowatt 

5 hours, which was defined as the sum of the per cycle 

6 and off mode energy and either the total per cycle 

7 electric or gas dryer energy consumption.

8 And DOE also proposed an integrated energy 

9 factor, which is the weight of the clothes, the 

10 dryer test load divided by the per cycle integrated 

11 total energy in kilowatt hours.

12 Now, for room air conditioners, DOE 

13 proposed an integrated energy consumption which was 

14 the sum of the annual energy consumption and the 

15 standby and off mode energy consumption. And DOE 

16 proposed an integrated energy ratio, defined as the 

17 cooling capacity and BTU per hour times the 750 

18 average hours in cooling mode divided by the 

19 integrated energy consumption times 1000 to get to 

20 kilowatt hours.

21 So this proposal for the integrated 

22 metrics for each product from the NOPR hasn’t 

23 changed for the SNOPR. Now, again, we made a 

24 modification to the slide deck, so this is all we 

25 have for this section, before we move on to active 
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1 mode.

2 MR. BROOKMAN: I see. Okay. So that last 

3 bullet is an addition that I guess it’s just a 

4 clarification of -- it’s just a summary statement 

5 surrounding the first three bullets, I think. So, 

6 comments here before we move on? Okay.

7 ACTIVE MODE: DRYER AUTOMATIC CYCLE TERMINATION

8 MR. BATTAGLIA: Now, switching over a bit 

9 to the topics that are related to active mode for 

10 both products, and started with the automatic cycle 

11 termination for dryers. In the October 2007 

12 framework document for the dryer, energy 

13 conservation standards rulemaking, DOE stated that 

14 the clothes dryers test procedure may not adequately 

15 measure the benefits of automatic cycle termination, 

16 which is when -- in which a sensor monitors either 

17 the exhaust air temperature or moisture in the drum 

18 to determine the length of the drying cycle.

19 Currently the DOE test procedure provides 

20 a single credit for the enhanced performance of 

21 clothes dryers equipped with automatic cycle 

22 termination, defined in terms of a field use scaling 

23 factor which is applied to the per cycle drying 

24 energy consumption. So for gas and electric clothes 

25 dryers with time termination control, which is to 
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1 say those dryers that are equipped with only a timer 

2 to determine the end of a drying cycle, are assigned 

3 a field use factor of 1.18, whereas dryers, 

4 automatic termination control dryers are assigned a 

5 field use factor of 1.04. So these automatic 

6 termination control dryers would receive a 12 

7 percent credit, as compared to a comparable dryer 

8 with time termination control.

9 So the DOE test procedure does not 

10 distinguish between the type of sensing technology 

11 for automatic termination controls, for example, if 

12 it uses temperature sensing or moisture sensing 

13 controls, and the sophistication or accuracy of that 

14 control system.

15 MR. BROOKMAN: Wayne Morris.

16 MR. MORRIS: James, I wonder if you could 

17 tell me, in terms of the timer control dryer, are 

18 you referring to a dryer there that has no automatic 

19 termination whatsoever in the dryer?

20 MR. BATTAGLIA: No, it would still have --

21 it could still have a temperature sensor that would 

22 modify the drying time. Because I’m not aware of 

23 any dryers on the market that just have time 

24 termination control. So even with like an 

25 electromechanical control, you could still use like 
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1 a temperature cutoff to shorten the drying cycle.

2 MR. MORRIS: Okay, so -- I’m having 

3 trouble with understanding the calculation of these 

4 factors. So the field use scaling factor is used 

5 then and applied to the per cycle drying energy 

6 consumption. If a dryer has both a timer function 

7 and a automatic termination function, then -- how 

8 does the Department or the manufacturer calculate 

9 the energy consumption?

10 MR. BATTAGLIA: I believe right now it 

11 would just receive the credit for automatic 

12 termination.

13 MR. MORRIS: Okay. I’m missing something 

14 here.

15 MR. BROOKMAN: Phil Manthei.

16 MR. MANTHEI: Phil Manthei, Appliance 

17 Laundry Systems. Yes, like our product has both. 

18 It has an actual timer, timed cycle, plus it has the 

19 automatic termination cycle, but yet it’s still an 

20 electromechanical timer. We don’t have any 

21 electronics on our design. So yes, because it has 

22 the automatic termination cycle, which you use 

23 during the test cycle for the minimum standard, you 

24 get the credit.

25 MR. MESSNER: You get the credit versus 
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1 what? Versus a dryer that -- I’m sorry this is 

2 Kevin Messner.

3 MR. MANTHEI: I suppose if there was a 

4 clothes dryers on the market that had only timed 

5 cycle and didn’t have also an automatic cycle.

6 PARTICIPANT: You’d use the 1.9.

7 MR. MORRIS: But then -- this is Wayne 

8 Morris again. I’m understanding James to say there 

9 are no such dryers that have timed termination only.

10 MR. BATTAGLIA: That, as far as we’re 

11 aware, that’s correct.

12 MR. MORRIS: So when, if any, does the 

13 timer FU factor ever come into play?

14 MR. BATTAGLIA: Right now, it wouldn’t, 

15 but we’re not prohibiting dryers with just timer 

16 controls to go on the market. So if a timer dryer 

17 did -- so if a dryer with only timer controls came 

18 out, it would get that 1.18 field use factor.

19 MR. MORRIS: Okay, so -- I get it now, 

20 thanks. Sorry. Okay, so -- I get it now, thanks. 

21 Sorry.

22 MR. BROOKMAN: No, that’s good. We want -

23 - that’s good. This is good. Additional comments 

24 on this. Okay.

25 MR. BATTAGLIA: Okay. So DOE investigated 
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1 other clothes dryers test standards from industry 

2 and also internationally for measuring the 

3 effectiveness of automatic cycle termination for 

4 clothes dryers. Now, DOE noted that AHAM recently 

5 published an update to its industry test standard, 

6 which is AHAM HLD-1-2009, which contains provisions 

7 for measuring the overdrying energy consumption for 

8 automatic termination dryers. And DOE also noted 

9 that the European standard EN 61121 and the 

10 Australia-New Zealand standard 2442 also provide 

11 methods for testing automatic termination control 

12 dryers.

13 So DOE first reviewed both AHAM HLD-1-2009 

14 and EN standard 61121 and determined that these 

15 standards did not provide an appropriate method for 

16 comparing the energy consumption of overdrying for a 

17 timer dryer to that of an automatic termination 

18 sensored dryer. Now next, DOE reviewed the 

19 Australia-New Zealand standard and we believe that 

20 it provides testing methods and procedures which 

21 account for the amount of overdrying associated with 

22 automatic termination control dryers beyond a 

23 specified RMC, and it effectively takes into 

24 consideration the accuracy of different sensor 

25 technologies. And DOE also believes the testing 
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1 methods provide an accurate and representative 

2 method for comparing the energy consumption between 

3 the two types of dryers.

4 So for these reasons, DOE proposed -- is 

5 proposing to amend the DOE test procedure for dryers 

6 to incorporate individual test procedures for timer 

7 dryers and automatic termination control dryers 

8 based on the provisions in the Australia-New Zealand 

9 standard 2442 with modifications as appropriate for 

10 the DOE test procedure. And we’ll go through each 

11 of those changes in the next few slides.

12 MR. BROOKMAN: Let’s just pause there for 

13 a moment. Yes, please. Wayne.

14 MR. MORRIS: Wayne Morris. I guess, for 

15 clarification purposes, though, I’m wondering if 

16 that definition of timer dryer doesn’t need to 

17 specify that it is as dryer that does not have any 

18 automatic termination function.

19 MR. BATTAGLIA: Yeah, we’ll get into that 

20 in a minute.

21 MR. MORRIS: Okay. Sorry.

22 MR. BROOKMAN: Other comments? Okay, 

23 let’s keep going.

24 MR. BATTAGLIA: Okay, so based on the 

25 provisions in the Australia-New Zealand standard, 
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1 DOE is proposing to define a timer dryer as a dryer 

2 which can be preset to carry out at least one 

3 sequence of operations to be terminated by a timer, 

4 but may also be manually controlled. And DOE is 

5 proposing to define automatic termination control 

6 dryer as a dryer which can be preset to carry out at 

7 least one sequence of operations to be terminated by 

8 means of a system assessing, directly or indirectly, 

9 the moisture content of the load, with an additional 

10 note that the automatic -- an automatic termination 

11 control dryer with a supplementary timer shall be 

12 tested as an automatic termination control dryer.

13 MR. MORRIS: This is Wayne. Now my 

14 question. Can you answer that for me please? Would 

15 it be appropriate to have something in the timer 

16 dryer definition that says “but does not include any 

17 automatic termination function”? I mean so that 

18 it’s real clear, because otherwise, if somebody 

19 reading this, especially somebody maybe that isn’t 

20 as skilled in understanding our test procedures, 

21 fixes on almost any automatic termination dryer is 

22 going to also have a timer dryer function, because 

23 that’s what the consumer demands, even though they 

24 probably don’t ever use it. But they want to see it 

25 on there. I think just we ought to consider putting 
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1 something in there to add to that definition to 

2 explain that we’re dealing with only a timer dryer.

3 MR. MESSNER: I assume that the last 

4 sentence that you have on the automatic termination 

5 should be modified and placed -- I mean clarified 

6 and automatic termination, you should clarify it in 

7 the timer.

8 MR. BATTAGLIA: Okay, and if you want to 

9 suggest in your written comments the actual language 

10 on that--

11 MR. BROOKMAN: That last comment from 

12 Kevin. Thank you. Yes, please.

13 MS. WALTNER: Meg Waltner from NRDC. Just 

14 a point of clarification. So if something is 

15 designated as an automatic termination control 

16 dryer, does that mean it’s never tested in the just 

17 timed modes?

18 MR. BATTAGLIA: That would be correct, 

19 yes.

20 MS. WALTNER: It would seem to me, without 

21 having looked into this further, that you maybe 

22 would want to test both types of dry modes, because 

23 it seems that most new dryers have both types of 

24 modes, and that would effect that.

25 MR. BROOKMAN: Thank you.
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1 MR. BATTAGLIA: And if you have any data 

2 to distribute, of how you would distribute the time, 

3 or the energy between those two --

4 MR. BROOKMAN: Among those two loads?

5 MR. BATTAGLIA: If you tested as the timer 

6 or -- both timer and automatic termination control 

7 dryers, that would be helpful.

8 MS. WALTNER: I don’t think I have any 

9 data, but I’ll try to see if I can submit some 

10 further information on that in comments.

11 MR. BROOKMAN: Thank you, Meg. Okay.

12 MR. MESSNER: I have one.

13 MR. BROOKMAN: Yes, Kevin.

14 MR. MESSNER: I’m making sure I’m saying 

15 it the right place, I guess so, looking ahead. Just 

16 overall, on this whole automatic termination test 

17 procedure, is there -- I’m having trouble -- what is 

18 the test procedure? I mean it’s citing a lot of 

19 different ones, and seems like it’s bringing in 

20 components, but is there actual test procedure 

21 written somewhere in the SNOPR that actually says 

22 here it is, that I didn’t catch?

23 MR. BATTAGLIA: Yes, so it’s in the 

24 notice, if you look at the very end, it actually -

25 MR. MESSNER: After all the definitions 
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1 and everything?

2 MR. BATTAGLIA: It should have the entire 

3 proposed test procedure in there.

4 MR. MESSNER: Okay. 

5 MR. BATTAGLIA: So it lays out the 

6 procedures for timer and automatic termination 

7 control dryers.

8 MR. MESSNER: All right. Thank you.

9 MR. BROOKMAN: Wayne.

10 MR. MORRIS: James, I think that we’ve 

11 read through the pages in the SNOPR that deal with 

12 the actual test procedure, it’s the latter pages in 

13 the -- within the SNOPR, and our manufacturers are 

14 having a very difficult time actually following that 

15 to actually create a test in a test laboratory. I 

16 mean we see what it says on paper, but when you go 

17 to actually set up a test procedure, this is not 

18 written in a way that a laboratory -- you could hand 

19 to a laboratory and say go ahead and do this test. 

20 I mean, now that we’ve added in all these extraneous 

21 functions from the IEC and from the Australia-New 

22 Zealand standard, we’ve got a cobbled up sort of 

23 amalgam of testing situations that’s making it 

24 extremely difficult.

25 Our comment will be in our written 
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1 comments as well, which is this needs to be taken 

2 back to some of the people, maybe at Navigant or 

3 other places that are actually doing testing and try 

4 to simulate this in the Department’s laboratory.

5 MR. BROOKMAN: So can you be specific? 

6 You’d like to see sequencing? You’d like to see --

7 that is more of an applied sort of -- yes?

8 MR. MORRIS: Yes.

9 MR. BROOKMAN: Okay. I’m just 

10 anticipating. Thanks for that. Meg, you all set? 

11 Okay. Other comments on this?

12 MR. BATTAGLIA: Okay. So for the test 

13 load preparation, with regard to those sections in 

14 the DOE test procedure, DOE is proposing to add the 

15 requirements that the moisture content for the test 

16 load for dampening and extracting water from the 

17 test load would first be between 42 and 47 percent 

18 of the bone dry weight. And as we’ll discuss later, 

19 this is a change from the current 70% initial RMC in 

20 the DOE test procedure.

21 This step would serve as initial 

22 preparation step prior to the next requirement, 

23 which would require that making final mass 

24 adjustments so that the moisture content is 47 

25 percent, plus or minus .33 percent, by adding water 
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1 uniformly to the load in a very fine spray. And 

2 this range was proposed based on the allowable range 

3 specified in the Australia-New Zealand standard, 

4 which specifies 190 percent, plus or minus .02

5 kilograms of the bone dry weight.

6 Now DOE believes that these proposed 

7 amendments would improve the repeatability and help 

8 reduce the variation from test to test, and would 

9 also allow for a more representative comparison 

10 between timer and automatic termination control 

11 dryers.

12 MR. BROOKMAN: Okay. Go ahead.

13 MR. BATTAGLIA: Now DOE also notes that 

14 Section 2.7 of the existing dryer test procedure 

15 regarding test load preparation, requires that the 

16 test load be agitated in water whose temperature is 

17 100 degrees, plus or minus five degrees Fahrenheit. 

18 Now DOE recognizes that some residential clothes 

19 washers may use a default cold rinse at the end of 

20 the wash cycle, which the current DOE washer test 

21 procedure specifies 60 degrees, however DOE does not 

22 have any data whether -- indicating whether a 

23 different water temperature for the clothes dryers 

24 test load preparation would be more representative 

25 of consumer usage habits. 
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1 So for this reason we’re not proposing any 

2 changes to the water temperature for the clothes 

3 dryers test preparation at this time. However, if 

4 consumer usage data is made available that indicates 

5 a 60 degree water temperature is more representative 

6 of consumer usage, DOE may adopt an alternate 

7 approach, specifying 60 degrees for this.

8 MR. BROOKMAN: Wayne -- pardon me, Phil.

9 MR. MANTHEI: Phil Manthei, Alliance 

10 Laundry Systems. I would say it’s highly reasonable 

11 that the loads going into the dryer are cooler than 

12 the 100 degree water, but I would think also then 

13 you’d have to try to understand what adjustment 

14 you’d make to the minimum standard, because you’d be 

15 using more energy because the load is cooler than it 

16 would be at 100 degrees.

17 MR. BATTAGLIA: Yes, so that’s another --

18 for the next slide, we’re requesting comments on 

19 that because we’re not aware of -- or we don’t have 

20 data at this time showing the changes on measured 

21 efficiency, as compared to the existing test 

22 procedure. So, again, here we’re inviting comments 

23 on this water temperature, and whether it should be 

24 changed based on what would be representative of 

25 consumer usage habits.
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1 MR. BROOKMAN: Just to see if there are 

2 any comments on this comment box? In your slides it 

3 is Page 54.

4 MR. WAGLEY: I -- this is Subid Wagley, 

5 DOE. We would update these slides before we post 

6 them on line after this.

7 MR. BROOKMAN: Yes.

8 MR. WAGLEY: We made some last minute 

9 changes before it went to the print.

10 MR. BROOKMAN: Okay, thank you. No 

11 comments? Okay.

12 MR. BATTAGLIA: All right. So DOE also 

13 proposes to amend Section 3.3 of the DOE test 

14 procedure regarding the test cycle to include 

15 testing procedures specific to each type of dryer, 

16 and these amendments are based on the provisions in 

17 the Australia-New Zealand standard.

18 So for timer dryers, DOE is proposing that 

19 the clothes dryer would be operated at the maximum 

20 temperature setting, and if equipped with a timer, 

21 at the maximum time setting. The load would then be 

22 dried to five to six percent RMC without the dryer 

23 advancing into any cool down period, and resetting 

24 the timer as necessary. And then the test procedure 

25 would be repeated until the RMC of the test load is 
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1 four to five percent.

2 Now for the test cycle for automatic 

3 termination control dryers, DOE is proposing that a 

4 normal cycle be selected for the test cycle to be 

5 most representative of consumer usage. Now, in 

6 addition, where the drying temperature can be chosen 

7 independently of the program, it shall be set to the 

8 maximum. And DOE is also proposing that when the 

9 heater switches off for the final time at the end of 

10 the drying cycle, which is to say that immediately 

11 before the cool down period begins, the dryer shall 

12 be stopped. Now if the final RMC is greater than 

13 five percent, the test would be considered invalid 

14 and a new run would be conducted using the highest 

15 drying level setting. And any test cycle in which 

16 the final RMC is five percent or less would be 

17 considered valid. 

18 And lastly, DOE is also proposing that for 

19 automatic termination control dryers, the cycle 

20 setting selected shall be recorded for the test.

21 MR. BROOKMAN: I apologize, I didn’t get 

22 your name the first time through.

23 MS. DETRICK: Paige Detrick.

24 MR. BROOKMAN: Paige, thank you.

25 MS. DETRICK: Paige Detrick, BSH. We have 
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1 honestly great concern with the word “normal 

2 program.” We feel this is going to put us back into 

3 the kind of discussions we’ve seen in other places 

4 in the standards, where no one has a program called 

5 “normal,” and everyone will have different feelings 

6 which is normal, and therefore test to test 

7 reproducibility, test lab to test lab 

8 reproducibility becomes very dangerous.

9 MR. BROOKMAN: What would you suggest as a 

10 substitute or alteration? Or elimination? What is 

11 the remedy here?

12 MS. DETRICK: I think, honestly, we 

13 probably need to talk to the community and bring 

14 back a written comments proposal.

15 MR. BROOKMAN: Okay, thank you. Wayne.

16 MR. MORRIS: Yes, I would concur with 

17 Paige. I think we’ve successfully now transitioned 

18 in the Department away from using the term “normal” 

19 on clothes washers. Only took us 20 years, and so I 

20 think that -- I don’t want to see us go backwards on 

21 this, especially -- you know, I’m only an infrequent 

22 user of a clothes dryer, but I haven’t yet seen one 

23 that’s out there that has somewhere written on it, 

24 this is the normal cycle. So to try and -- we’ve 

25 transitioned in clothes washers to naming the type 
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1 of fabric, for instance, maybe there’s another way 

2 we can do this or combination. We’d like to survey 

3 our members and see if there isn’t some better 

4 terminology that we could use, or a suggestion for a 

5 particular cycle that we could use that’s 

6 representative of at least the largest majority of 

7 consumer usage.

8 We also might suggest that the Department 

9 contact some of the manufacturers of dryer -- what 

10 would you call them, dryer usage materials that are 

11 used in, for instance, the fabric softener type of 

12 products that are used in dryers, they may have some 

13 survey data from consumers as to what the usage 

14 factor is on that type of thing, or what the most 

15 common usage program is. Something that is 

16 relatively widespread among the dryer community that 

17 we could use and get away from this terminology of 

18 normal. Thanks.

19 MR. BROOKMAN: Thank you. Meg?

20 MS. WALTNER: Meg Waltner from NRDC. I 

21 just have a question. I’m curious why you chose, 

22 despite the issues with the normal setting 

23 definition, why you chose normal instead of sort of 

24 the maximum dry setting where you use the maximum 

25 time in the timed dry.
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1 MR. BATTAGLIA: We chose the normal 

2 setting based on the dryers. We conducted our own 

3 testing of the dryers that we had used the normal 

4 cycle, and we didn’t use the highest dryness setting 

5 because it would overdry the test load to near bone6 dry, so it wasn’t really reflective of trying to 

7 achieve an RMC of five, like five percent which we 

8 assume would be what a typical consumer would use. 

9 So I think the highest dryness level setting is 

10 geared towards achieving a bone dry state for the 

11 clothes.

12 MS. WALTNER: No follow up comment at this 

13 time.

14 MR. BROOKMAN: Okay. Thank you. Kevin.

15 MR. MESSNER: Well, so the test procedure 

16 is supposed to be representative of use across the 

17 nation. Not necessarily what the peak is, just 

18 representative of what it is. So -- and that’s --

19 you use the highest setting for everything that’s --

20 you’re saying is representative of the highest load, 

21 so maybe that’s where --

22 MR. BROOKMAN: Okay? Other?

23 MR. BATTAGLIA: Okay. Now, DOE notes that 

24 there is at least two ways to terminate the drying 

25 cycle during the drying test, and first would be 
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1 termination before the cool down period, and second, 

2 termination at the end of the selected test cycle, 

3 which would include the cool down period. So DOE 

4 notes that the Australia-New Zealand standard 2442 

5 and the AHAM standard both terminate before the cool 

6 down period, and the EN standard 61121 specifies 

7 that the cycle be run until completion, which would 

8 include the cool down period. 

9 And as we discussed, DOE is proposing for 

10 the SNOPR that the test cycle for automatic 

11 termination control dryers would not include the 

12 cool down phase, and these proposed amendments are 

13 based on the Australia-New Zealand standard, because 

14 it provides a more representative comparison between 

15 the energy consumption between automatic termination 

16 control dryers and timer dryers than did EN 61121, 

17 and in addition, the proposed amendments would 

18 harmonize with the international standard and also 

19 with the industry standard.

20 MR. BROOKMAN: Any comment in here? Phil, 

21 go ahead.

22 MR. MANTHEI: All right, I guess I’m an 

23 advocate of running the whole cycle through the cool 

24 down period. You know, it’s difficult, first of 

25 all, the technician has to guess when to try and 
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1 pull the load to measure, and so if you take that 

2 away, that simplifies the test procedure. 

3 MR. BROOKMAN: Paige.

4 MS. DETRICK: Paige, BSH. The BSH opinion 

5 is also that including the cool down is advantageous 

6 for both repeatability of the test and simplicity of 

7 the method, but also as noted in the SNOPR, there is 

8 a possibility to make better use of the consumed 

9 energy by using that cool down period to continue to 

10 reach the actual target RMC.

11 MR. BROOKMAN: Okay. Thank you. 

12 MR. BATTAGLIA: And then that basically 

13 summarizing what’s on the next slide, which is 

14 we’re considering the alternate method in EN 61121 

15 to include the cool down period, noting that, like 

16 Paige said, it could provide the potential for more 

17 efficient controls.

18 MR. BROOKMAN: Okay.

19 MR. BATTAGLIA: So here we’re welcoming 

20 comments on whether the cool down period -- or 

21 further comments, I guess -- on whether the cool 

22 down period should be included for automatic 

23 termination control dryers, and in addition, we’re 

24 welcoming data quantifying how including the cool 

25 down period in the test cycle would affect the 
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1 measured efficiency of clothes dryers as compared to 

2 the existing test procedure, per that EPCA 

3 requirement, and in particular for units that are 

4 minimally compliant with the current energy 

5 conservation standards.

6 MR. BROOKMAN: Yes, Joanna.

7 MS. MAUER: Joanna Mauer. We’d also agree 

8 that the cool down period should be included. I 

9 mean, the idea is to measure a complete cycle and 

10 we’d encourage all engineering options to be 

11 available.

12 MR. BROOKMAN: Okay, thank you. That’s 

13 helpful. Yes. Wayne.

14 MR. MORRIS: Wayne Morris. Just a 

15 question. If you include the cool down cycle, then 

16 do all of your calculations of hours need to be 

17 reset?

18 MR. BATTAGLIA: I’m not sure I can answer 

19 that right now.

20 MR. BROOKMAN: Explain your logic to us.

21 MR. MORRIS: Well, I’m assuming that now 

22 the number of cycle hours per year that we just 

23 covered back in -- I can’t find the exact page, but 

24 you know, the actual mode hours or the hours that 

25 were spent in this, I believe it was 140 hours, is 
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1 that right? It’s on slide 38. So if now you 

2 include the cool down cycle, then I’m just assuming 

3 that then you’re going to have to readjust in order 

4 to get to the proper 8760 hours per year. Right? 

5 Sort of just makes sense.

6 MR. BATTAGLIA: Okay, and if you have 

7 data, I guess like typical -- how long the cool down 

8 period would be, or anything that would be helpful, 

9 or if you have a suggested number.

10 MR. MORRIS: I think that’s where it could 

11 be a little difficult because there may be 

12 differences in dryers, significant differences in 

13 dryers in terms of the amount of time spent in cool 

14 down, and therefore, trying to come up with an exact 

15 number of hours -- because this becomes pretty 

16 critical. I mean whatever hours -- therefore in 

17 active mode, you’re not in inactive mode, and so now 

18 you’re adjustments have got to be made in order to 

19 keep to the same, and so I think this could be where 

20 -- I mean I’m -- cool down modes have been around 

21 for a few dozen years, and it could be why the 

22 Department elected, even in the original test 

23 procedure not to include the cool down mode, is just 

24 a simple situation that it’s pretty difficult to 

25 find an exact number that represents the amount of 
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1 time spent in there. At one time it was probably 

2 less important. Now it becomes critically important 

3 as the number of cycles is reduced, the number of 

4 hours spent in this, then become a larger percentage 

5 of the whole.

6 MR. BROOKMAN: Okay. Thank you. Other 

7 comments? Okay.

8 MR. BATTAGLIA: Now, regarding Section 4 

9 of the DOE test procedure, which is concerned with 

10 the calculation of derived results from the test 

11 measurements, DOE is proposing for timer dryers, 

12 using the results from the proposed test cycle, 

13 which are the five to six and four to five percent 

14 final RMC tests to interpolate the value of the per 

15 cycle energy consumption required to dry the test 

16 load to exactly five percent RMC. And then you 

17 would be placing that 1.18 field use factor on -- to 

18 add overdrying energy consumption.

19 DOE isn’t aware of any data that would 

20 suggest that the 1.18 field use factor for timer 

21 dryers is inaccurate and not currently 

22 representative of consumer usage, and so DOE is not 

23 proposing to change this value at this time. 

24 However, we recognize that the field use factor was 

25 set in 1981 when the dryer test procedure was first 
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1 established, and it could not be -- it may not be 

2 representative of current consumer usage patterns. 

3 And so I guess DOE is open to comment and data 

4 suggesting whether this value would be appropriate.

5 MR. BROOKMAN: I guess the manufacturers 

6 are not ready to comment on that one? Okay.

7 MS. PINTO: Excuse me, Doug?

8 MR. BROOKMAN: Yes, please. Francine.

9 MS. PINTO: Francine Pinto, GC. On that 

10 last comment, you’re name is Wayne?

11 MR. MORRIS: Yes.

12 MS. PINTO: That Wayne made about the 

13 hours, I’m wondering what other stakeholders think. 

14 Because you mentioned that you thought we should 

15 measure the cool down, and whether we link up with 

16 the proper number of hours is something we have to 

17 look into, but if we can’t, what do you all think?

18 MS. MAUER: Joanna Mauer. I would 

19 actually say that I think it would be very helpful 

20 if AHAM had any data, not specifically on the cool 

21 down hours, but on the total cycle hours because I 

22 don’t -- I’m not sure that the 140 hours has been 

23 updated or is based actually on cycle hours. So if 

24 we had some estimate of the length of a total cycle 

25 on average, and now we have a new value for cycles 
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1 per year, we could -- I think DOE could figure out 

2 whether that 140 hours should be adjusted or not. 

3 So I guess I would say, to me the more important 

4 question is the total cycle length as opposed to the 

5 cool down time.

6 MR. BROOKMAN: Wayne Morris.

7 MR. MORRIS: It’s a very valid point, both 

8 of you. Some of this also depends very much on what 

9 is the initial RMC that we’re going to use. Because 

10 if we’re using 70 or 72 percent or something in that 

11 range for an initial RMC, then it takes longer to 

12 get that normal load to actual automatic 

13 termination, than if we’re starting at 47 percent, 

14 for instance. And if we’re going to use that, we 

15 may end up at the same place. In other words, by 

16 reducing the RMC, then down to 47, and looking at 

17 including a cool down, you may actually end up 

18 equaling out at 140 hours, or roughly, let’s say 30 

19 minutes or something like that, per cycle, now that 

20 we’ve reduced the number of cycles. 

21 So I think that at some point we may be 

22 going through a fairly extensive exercise just to 

23 get back to the number that we actually have. But 

24 your point is well taken, and we’ll ask the 

25 manufacturers if we can look at some average amount 
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1 here, or whether that would be appropriate even, to 

2 look at, and we’ll try to cover that in our written 

3 comments.

4 MR. BROOKMAN: Judy Reich.

5 MS. REICH: Yes, I just also wanted to add 

6 to that, for the NOPR, that Whirlpool had supplied 

7 estimates of -- verifying the 140 hours and that 

8 corresponded to 20 minutes per cycle, which I 

9 assume, based on that timeframe, is only looking at 

10 the original definition of active mode and did not 

11 include any cool down period.

12 MR. BROOKMAN: Okay. Thank you. Data. 

13 Okay. So any additional comments on this?

14 MR. BATTAGLIA: Now, in the calculation of 

15 results for automatic termination control dryers, 

16 DOE is proposing to revise the field use factor 

17 credits to more appropriately account for the 

18 automatic termination control dryer overdrying 

19 energy consumption. So automatic termination 

20 control dryers would receive a field use factor of 

21 one, instead of the 1.04 currently provided, and any 

22 overdrying energy consumption measured during the 

23 test cycle would be added to the drying energy 

24 consumption, to basically decrement that energy 

25 factor.
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1 Based on these test methods an automatic 

2 termination control dryer that is able to dry the 

3 test load to exactly five percent RMC, and thus 

4 eliminate overdrying, would result in a higher 

5 measured efficiency than if it overdried to an RMC 

6 less than five percent. And I think that’s a slight 

7 modification to this slide that you have in your 

8 packet. 

9 MR. BROOKMAN: So up here this may be --

10 can you point to what’s different?

11 MR. BATTAGLIA: Right, so it’s just that 

12 we’re -- that last -- that second bullet on the --

13 the second sub-bullet to the first main bullet is 

14 slightly different wording.

15 MR. BROOKMAN: Okay. Kevin.

16 MR. MESSNER: Yeah, I’m just still -- I’m 

17 not steeped in the details of the test procedure, so 

18 maybe that’s why I’m missing something. Could you 

19 try to explain it again.

20 MR. BATTAGLIA: Right, so if you dried --

21 if your automatic termination control setting dried 

22 to exactly five percent RMC, you’d have a higher 

23 efficiency than a dryer that overdries it to lower 

24 than five percent.

25 MR. MESSNER: Got that, but then so that 
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1 is your -- how does that -- I guess I’m getting 

2 lost. How does that factor into the calculation?

3 MR. BATTAGLIA: So when you run the test, 

4 you allow it to run until completion. 

5 MR. MESSNER: So you don’t have to check 

6 and run it again?

7 MR. BATTAGLIA: Right.

8 MR. MESSNER: All right.

9 MR. BROOKMAN: Wayne Morris.

10 MR. MORRIS: Wayne Morris with AHAM. 

11 Maybe I’m missing something here but my slide and 

12 your slide look like they’re identical and I got 

13 this off the internet this morning.

14 MR. BATTAGLIA: Okay, maybe it’s been 

15 updated since, but -- okay.

16 MR. MORRIS: So I just want to make sure 

17 I’m dealing with the same --

18 MR. BATTAGLIA: Sorry, I thought that was.

19 MR. MORRIS: Okay.

20 MR. BROOKMAN: That’s it? Yeah. Hang on, 

21 just a second. Yes. Paige.

22 MS. DETRICK: Yes, just a comment on maybe 

23 specifically the word “exactly five percent” but 

24 also in hearing that exactly, if the procedure is

25 written as I see it, that anything greater than five 
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1 percent is an invalid test, then it must target ever 

2 so slightly dryer than five percent because, just 

3 like any other method measurement in the world, you 

4 will not be exactly every time. I’ve not going to 

5 get five --

6 PARTICIPANT: Five or less.

7 MR. BROOKMAN: Right. Okay. Other 

8 comments on this slide here?

9 MR. BATTAGLIA: Oh, and there’s just one 

10 last -- second part of that slide. We’re 

11 considering the requirement to look at the effects 

12 on the measured efficiency, DOE estimated, based on 

13 limited testing, that a baseline dryer would 

14 possibly overdry the test load to below five percent 

15 such that the energy consumption measured efficiency 

16 would be equivalent to that measured by the existing 

17 DOE test procedure. So we’re not proposing any 

18 changes to the current energy conservation standards 

19 at this time. 

20 And here we’re inviting comments on the 

21 adequacy of Australia-New Zealand standard 2442, 

22 along with the proposed definitions and 

23 clarifications to measure energy consumption for a 

24 timer and automatic termination control clothes 

25 dryers to account for overdrying energy consumption. 
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1 Maybe we’ll stop at that one first.

2 MR. BROOKMAN: James, were you 

3 anticipating comments here? Did we cover this?

4 MR. BATTAGLIA: Well, I guess we can read 

5 through the whole thing, then.

6 MR. BROOKMAN: Yes.

7 MR. BATTAGLIA: Next, DOE is inviting 

8 comment on whether the proposed field use factor 

9 credits for automatic termination control dryers, 

10 along with the revised calculations for the per 

11 cycle energy consumption are appropriate. Also 

12 requesting comment on whether final RMC of five 

13 percent is appropriate, and if not, what would be a 

14 representative value. And also welcoming data from 

15 dryers tested according to this procedure, and 

16 particularly for units that are minimally compliant 

17 with current energy conservation standards, as well 

18 as data showing whether one sensor technology is 

19 more accurate and reduces overdrying than another.

20 MR. BROOKMAN: You can see the comment 

21 boxes. Please take a peek at them. So this takes 

22 you through issue nine. Let’s proceed to the next 

23 slide and see if there are any comments there.

24 MR. BATTAGLIA: Okay, and for this we’re 

25 also inviting comment on whether the maximum 
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1 temperature setting for timer dryers is 

2 representative of consumer usage habits, and we’re 

3 inviting comments on whether the proposed cycles and 

4 settings for the automatic termination control dryer 

5 tests are representative of current consumer usage, 

6 habits and requesting comments on whether multiple 

7 cycles and settings should be tested and how results 

8 from those tests of multiple cycles should be 

9 evaluated. And if so, how testing multiple cycles -

10 - cycles and settings will affect the measured 

11 efficiency as compared to the existing DOE test 

12 procedure.

13 MR. BROOKMAN: No comments? Okay.

14 MR. BATTAGLIA: Okay, and I think the 

15 agenda says lunch here.

16 MR. BROOKMAN: Guess so. I think we’re 

17 just perfect almost. It’s lunch time, and this is 

18 really well planned. We’re making really good 

19 progress. This material is rather dense. Get some 

20 protein with your lunch. Balance the carbs and the 

21 proteins. 

22 MS. SULLIVAN: How long we going?

23 MR. BROOKMAN: We will -- how long today?

24 MS. SULLIVAN: Yes.

25 MR. BROOKMAN: Well, so far we’re on 
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1 schedule, and the way they’ve timed it so far, they 

2 anticipate we’ll go until three o’clock.

3 This room will be locked, so you can leave 

4 your stuff here. It’s now five ‘til 12, let’s 

5 resume at one o’clock, here in this room. And thank

6 you for a good day -- a good start on the day I 

7 should say. Please wear your badges in the 

8 building, otherwise someone might escort you to a 

9 locked room. Everybody knows where the cafeteria 

10 is, right? 

11 So thanks for a good start to the day, 

12 we’ll resume at one. At one.

13 (Whereupon, at 11:55 a.m., the meeting in 

14 the above captioned matter was adjourned for lunch 

15 recess, to reconvene at 1:00 p.m.)

16

17

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20

21

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23

24

25
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1

2 A F T E R N O O N S E S S I O N 

3 1:08 p.m.

4 MR. BROOKMAN: We're going to pick up 

5 where we left off. And we're back with James.

6 Active Mode: Vent-less Dryers, Detergent 

7 Specifications for Dryer Test Cloth Preconditioning 

8 MR. BATTAGLIA: All right. So, the first 

9 topic which we are going to discuss now is the test 

10 procedure for vent-less clothes dryers. And in the 

11 October 2007 framework document, DOE noted that the 

12 potential limitation in the dryer test procedure was 

13 identified for vent-less dryers and manufacturers 

14 had commented that the current test procedure is 

15 unable to test this type of dryer. And the 

16 limitation lies in the fact that the test procedure 

17 requires the use of an exhaust restrictor to 

18 simulate the back pressure effects of a vent tube in 

19 an installed condition. And vent-less clothes 

20 dryers do not exhaust air to the outside as a 

21 conventional clothes dryer would do.

22 So, manufacturers of vent-less condensing 

23 dryers have in the past applied for waivers from the 

24 DOE test procedure for these products on the basis 

25 that the test procedure can't -- doesn't have 

26 provisions for testing these type of dryers. One 

27 such -- one of these waivers was filed by LG 
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Electronics for its vent-less dryer. On August 23rd 1 , 

2 2006, DOE published the LG petition for waiver, and 

3 as part of that notice, DOE presented an alternate 

4 test procedure for vent-less dryers to address the 

5 potential limitations of the test procedure. 

6 So as part of this alternate test 

7 procedure it consisted of adding a separate 

8 definition for conventional clothes dryers which are 

9 vented and condensing clothes dryers which are a 

10 vent-less design.

11 And further the alternate test procedure 

12 qualified the requirement for an exhaust simulator 

13 so that it would only apply to conventional clothes 

14 dryers.

15 Now, DOE first examined the alternate test 

16 procedures presented in that LG petition for waiver 

17 conducting a limited number of tests on vent-less 

18 dryers at an independent laboratory. And DOE tested 

19 one vent-less electric compact, and one vent-less 

20 electric combo washer/dryer. And the results showed 

21 for the vent-less electric compact we didn't observe 

22 any variation in EF -- in energy factor from test to 

23 test. And for the combo washer/dryers we observed 

24 less than 2 percent variation in the EF from test to 

25 test.

26 So based on this limited testing, we 

27 believe that the proposed -- or the alternate test 

28 procedure produces repeatable results.
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1 MR. BROOKMAN: Wayne, please.

2 MR. MORRIS: How many units and about how 

3 many tests were you running?

4 MR. BATTAGLIA: These tests were conducted 

5 as part of the energy conservation standards 

6 rulemaking and we tested one vent-less compact 240 

7 volt dryer, and one vent-less combination 

8 washer/dryer. And for each dryer we conducted three 

9 identical tests.

10 MR. MORRIS: Thanks.

11 MR. BROOKMAN: Other comments on these? 

12 Yes.

13 MR. MESSNER: We agree that there should 

14 be a test procedure for vent-less and we just need 

15 to review and maybe we can get into a little more 

16 details on exactly what the standard -- what the 

17 test procedure is.

18 MR. BATTAGLIA: Okay. 

19 MR. BROOKMAN: Okay. Thank you, Kevin. 

20 MR. BATTAGLIA: Okay. So as part of its 

21 review of alternate test procedures for vent-less 

22 dryers DOE also looked at testing conditions and 

23 methods in test standards used internationally. 

24 As far as those go, DOE is aware of the 

25 two standards here, the EN Standard 61121 and the 

26 Australia Standard 2442.

27 DOE also considered comments submitted by 

28 Whirlpool as part of the standards rulemaking in 
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1 which they provided possible amendments to the DOE 

2 test procedure for vent-less dryers. And those were 

3 largely based on the provisions in EN Standard 

4 61121.

5 And based on DOE's evaluation we believe 

6 that EN Standard 61121 includes relevant test 

7 procedures for vent-less or condensing dryers and 

8 that these procedures provide greater specificity 

9 than the alternate test procedure presented in the 

10 LG petition for waiver.

11 So getting into these proposed amendments, 

12 based on the definitions in the LG petition for 

13 waiver the EN Standard 61121 and the Australia, New 

14 Zealand standard and Whirlpool's proposed 

15 amendments, all of those had very similar 

16 definitions and based on those were proposing to 

17 define a conventional clothes dryer as a clothes 

18 dryer that exhausts the evaporated moisture from the 

19 cabinet and a vent-less dryer as a clothes dryer 

20 that uses a closed loop system with an internal 

21 condenser to remove the evaporated moisture from the 

22 heated air and also noting that the moist air is not 

23 discharged from the cabinet.

24 MR. BROOKMAN: Yes, Paige?

25 MS. DETRICK: I'm curious if you could 

26 shed some light on why the evaporated moistures 

27 cannot be discharged from the cabinet, for example, 

28 drained from the appliance into the conventional 
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1 sewer line?

2 MR. BATTAGLIA: Well, I think what we're 

3 getting at here is just that it wouldn't be vented 

4 to the outside. I think what you're talking about 

5 is if you condense the moisture during the process 

6 and drain it out with a pump. So that that would be 

7 a part of a vent-less design.

8 MS. DETRICK: Got it. Sorry, misheard 

9 you.

10 MR. BROOKMAN: Other comments on these 

11 issues?

12 (No response.)

13 MR. BATTAGLIA: So for the proposed 

14 insulation conditions, DOE is proposing based on the 

15 LG petition or all of these, the different sources 

16 that the insulation conditions would qualify the 

17 requirement for an exhaust simulator so that it 

18 would only apply to conventional clothes dryers 

19 which is to say those dryers with a vent.

20 And also a clarification would be added 

21 that vent-less dryers be tested without the exhaust 

22 simulator installed and if a dryer is designed to 

23 operate with an optional exhaust duct, the dryer 

24 would be tested without the duct installed. And DOE 

25 believes that these insulation conditions would 

26 provide additional clarity and cover all possible 

27 dryer configurations as well as provide 

28 harmonization with international standards.
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1 Okay. So DOE also believes that the 

2 provisions -- I'm sorry -- in EN Standard 61121 

3 regarding condensation box also provide additional 

4 clarity to cover all possible configurations. So 

5 for this reason DOE is proposing for the insulation 

6 conditions that if a manufacturer gives the option 

7 to use a vent-less dryer with or without a 

8 condensation box, the dryer would be tested with the 

9 condensation box installed.

10 In addition, DOE is also proposing for the 

11 cycle measurement in Section 3.3 of the DOE test 

12 procedure that if the dryer is automatically stopped 

13 during a cycle and the reason is that the 

14 condensation box is full of water, the test would be 

15 stopped and the test run would be considered valid. 

16 And, again, that's to ensure consistent results for 

17 the measured efficiency. 

18 And, finally, regarding the insulation 

19 conditions, DOE is proposing, based on Whirlpool's 

20 proposal to add that a condenser unit of the dryer 

21 must remain in place and not be taken out of the 

22 dryer for any reason between tests. And, again, 

23 that's for additional clarification and to ensure 

24 that all manufacturers are testing using the same 

25 methods.

26 (Pause.) 

27 MR. BATTAGLIA: Okay. Now, currently 

28 Section 2.8 of the DOE test procedure which is 
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1 concerned with clothes dryer preconditioning 

2 requires that before any test cycle is initiated the 

3 clothes dryer must be operated without a test load 

4 in the non-heat mode for 15 minutes or until the 

5 discharge air temperature varies less than 1 degree 

6 Fahrenheit during a period of ten minutes, whichever 

7 is longer.

8 Vent-less clothes dryers do not have a 

9 discharge air for which the temperature can be 

10 measured. So as a result DOE is proposing, based on 

11 EN 61121 to revise a section to require that for 

12 vent-less dryers the steady-state temperature must 

13 be equal to the ambient room temperature before the 

14 start of all tests. With a note that this can be 

15 done by leaving the machine at ambient room 

16 conditions for at least 12 hours, but not more than 

17 36 hours between tests. And one thing I'd just like 

18 to add here is that we're also requesting comment on 

19 whether this upper limit of 36 hours is appropriate. 

20 MR. BROOKMAN: Yes, Wayne.

21 MR. MORRIS: I guess I'm struggling with 

22 this one just a little bit, James, this last 

23 statement. This steady-state temperature, 

24 temperature of what? Of the machine?

25 MR. BATTAGLIA: Yes, that would be 

26 correct. 

27 MR. MORRIS: So maybe we ought to insert 

28 the word "machine" temperature or "machine" in front 
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1 of temperature.

2 MR. BATTAGLIA: Okay.

3 MR. MORRIS: And if a manufacturer needs 

4 to run multiple tests in a back-to-back kind of 

5 situation, it seems like it would be a pretty 

6 significant test burden to have to wait at least 12 

7 hours. If they have a way of cooling the machine, 

8 you know, typically in a lot of laboratories that 

9 I'm familiar with, you can use like a fan or a 

10 portable air conditioner or something like that to 

11 cool the machine in between cycles to get it back. 

12 As long as you're back at ambient, does it matter 

13 why the time?

14 MR. BATTAGLIA: That's correct. So this 

15 isn't requiring 12 hours, it's just saying that you 

16 could achieve that. If you can verify that the 

17 ambient -- or the temperature of the unit is at the 

18 ambient room temperature, then that would meet this 

19 requirement. 

20 MR. MORRIS: So in other words, emphasis 

21 on the word "can"?

22 MR. BATTAGLIA: Right.

23 MR. MORRIS: You could do it that way, may 

24 be -- may be done, maybe that's a better word than 

25 can. May, second word, be done by leaving the 

26 machine --

27 MR. BROOKMAN: Or any other method that 

28 would take it back to ambient.
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1 MR. MORRIS: Exactly.

2 MR. BROOKMAN: Yeah. Good heavens, I'm 

3 having flashbacks to legislatures.

4 Betsy, stop me. 

5 MS. DETRICK: I'm curious what is 

6 suggested as the way to get a dryer back to, let's 

7 say, testable state if it has sat in the ambient 

8 condition 36 hours? Because clearly we occasionally 

9 have breaks between tests that can be more than two 

10 and a half or a day and a half, whatever.

11 MR. BROOKMAN: And, yes, you came up with 

12 36 as a matter of practicality?

13 MR. BATTAGLIA: Well, that was based on 

14 the provisions in the EN Statement 61121. And 

15 that's why we're also requesting comment on whether 

16 that 36-hour upper limit is actually necessary.

17 MS. DETRICK: Right. And I'm not asking 

18 about the number of hours, but what is the step to 

19 make the dryer testable again?

20 MR. BATTAGLIA: I'm not sure I understand.

21 MS. DETRICK: It says I can't leave it in 

22 ambient conditions for more than 36 hours between 

23 tests.

24 MR. BATTAGLIA: Oh, right.

25 MS. DETRICK: Sometimes a dryer is going 

26 to sit even weeks and need to be tested again.

27 MR. BATTAGLIA: Right. So I think the way 

28 EN 61121 was written was you would run a test cycle 
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1 and then I think the provisions in EN 61121 say that 

2 that first cycle is invalid. So you would have to 

3 wait until you're reaching the steady-state room 

4 temperature again before you can run a valid cycle. 

5 So I guess you would have to run one test cycle 

6 before you could actually start your actual test 

7 cycle.

8 MR. BROOKMAN: Wayne.

9 MR. MORRIS: I'm sure our esteemed 

10 colleagues who sit in the EN 61121 could explain to 

11 us why that is the case, but lacking an 

12 understanding to that, I guess I'm of the opinion 

13 that if you want to have a minimum number, if you're 

14 doing this by just, sort of ambient cooling and you 

15 want to have a minimum number of at least 12 hours, 

16 I can understand that. But I don't understand the 

17 maximum. And I think I would encourage the 

18 Department to think about taking that last clause 

19 out.

20 And if you ran your test on Friday and 

21 your second test wasn't until Monday, so what?

22 MR. BROOKMAN: So, just remove reference 

23 to the 36-hours.

24 MR. BATTAGLIA: Okay. And the last bullet 

25 on this slide is just --

26 MR. BROOKMAN: Let's see if there are any 

27 other comments on this from anybody else?

28 MR. BATTAGLIA: Sure.
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1 (No response.)

2 MR. BROOKMAN: It seems like a practical 

3 sort of a thing. If there's a downside, we should 

4 know about it now.

5 Okay. 

6 MR. BATTAGLIA: Okay. And, finally, DOE 

7 is proposing to add a qualification of the existing 

8 preconditioning procedure that it would apply to 

9 vented clothes dryers.

10 So regarding the test cycle measurement EN 

11 61121 and the Whirlpool proposal specify, I think we 

12 talked about this, that the first cycle after a 

13 period of non-operation for longer than 36 hours 

14 would not be used for evaluation. And that between 

15 tests that the door of the tumble dryer shall be 

16 closed except for loading and unloading. And DOE 

17 proposed SNOPR provisions to the DOE test procedure 

18 to provide a clear and repeatable testing procedure.

19 Also regarding the test cycle EN 61121 

20 requires that at least five valid test cycles be 

21 performed and the results of those are then 

22 averaged. However, DOE's clothes dryer test 

23 procedure currently does not specify multiple test 

24 cycles to obtain a representative EF and DOE is not 

25 aware of any data suggesting that the test to test 

26 variation would warrant more than one test cycle. 

27 So DOE is not proposing to address the number of 

28 valid test cycles at this time.
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1 MR. BROOKMAN: Paige.

2 MS. DETRICK: Just to reconcile, slide 69 

3 talks about the condenser unit not being removed 

4 between tests and then also on 70 we just talked a 

5 lot about things that cannot be done between tests. 

6 If indeed there will be single test validity rather 

7 than multiple tests to get an average value, then I 

8 think a lot of those things are simply irrelevant.

9 MR. BATTAGLIA: Right. And those were 

10 based on the requirement for the -- if you tested 

11 after a period of 36 hours of sitting there you 

12 would have to wait again. So that's what that was 

13 based on.

14 MS. DETRICK: But specifically looking at 

15 the condenser unit being removed or replaced, if we 

16 say single test runs are a valid data point unto 

17 themselves rather than being average test data, then 

18 this requirement is irrelevant. Otherwise we need 

19 to say how many test runs is a set and that a 

20 condenser could be, for example, removed and cleaned 

21 or else I have to, you know, limit the total number 

22 of test runs on a particular dryer period in its 

23 life, or something.

24 MR. BROOKMAN: Yes. Let me see?

25 MS. LOWENBERGER: Amanda Lowenberger.

26 MR. BROOKMAN: Amanda, thank you.

27 MS. LOWENBERGER: Just to respond to your 

28 point, I think it's possible that even if only one 
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1 test cycle is required that if that test cycle 

2 fails, there could be instances where you would need 

3 multiple tests run. So that provision could still 

4 be useful.

5 MR. BROOKMAN: Wayne?

6 MR. MORRIS: Wayne Morris. I believe not 

7 in the particular clothes dryer test procedure, but 

8 in the general requirements in CFR 430, there are 

9 requirements for a manufacturer obtaining repeatable 

10 and verifiable results that put the requirement back 

11 on the manufacturer if they feel that they need to 

12 run multiples in order -- I think -- and it's been a 

13 while since I read that, but I'm pretty sure that 

14 there are procedures in there that deal with running 

15 multiple and averaging and how you go about arriving 

16 at the number that you're going to then present to 

17 the Department or to Energy Star and that type of 

18 thing.

19 So I think that there could be instances 

20 where a manufacturer is going to run multiple 

21 cycles. I understand that in this particular 

22 situation James is suggesting that the Department 

23 doesn't want to specify a minimum number. I think 

24 that's what you're really getting at. It doesn't 

25 want to specify a minimum number of multiple or 

26 minimum number of test cycles to obtain a 

27 representative yield. But that's up to the 

28 manufacturer to do that.
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1 And I think that that may be where Paige's 

2 point about the test cycle on a condenser unit that 

3 the manufacturer has got to be able to do some 

4 modifications between the tests if they happen to 

5 want to run or need to run multiple cycles. 

6 MS. DETRICK: This is Paige. Yeah, this 

7 speaks about the condenser itself and if a test run, 

8 let's say I in my laboratory decide I'm only 

9 comfortable if I run ten runs or five runs, or 

10 whatever, it's very reasonable to leave the 

11 condenser in place for that period of time.

12 MR. BROOKMAN: I didn't understand how you 

13 reconciled that, but I think you did. Did you get 

14 that?

15 MR. BATTAGLIA: So I think from what I 

16 understand that manufacturers can run multiple tests 

17 to verify that their measurements are correct. So 

18 in that case these conditions would apply.

19 MR. BROOKMAN: Yes. Okay. Good. Thanks.

20 Okay. Let's proceed.

21 MR. BATTAGLIA: Okay. So here I think 

22 we're inviting comments on the adequacy of the 

23 proposed definitions and insulation conditions for 

24 vent-less dryers which are based on the LG petition 

25 for waiver and DOE is further inviting clarification 

26 -- or comments on the proposed clarifications to the 

27 insulation conditions, condensation boxes, and dry 

28 preconditioning and testing conditions based on the 
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1 EN 61121 and Whirlpool's proposed amendments.

2 I think we discussed some of that a bit. 

3 But if anybody has more --

4 MR. BROOKMAN: So any addition comments 

5 based on what's been said already to respond to 

6 these comment boxes? Wayne?

7 MR. MORRIS: Wayne Morris with AHAM. So, 

8 James, are these -- all the amendments then are 

9 included in the SNOPR pages in the end where they 

10 already --

11 MR. BATTAGLIA: Yes.

12 MR. MORRIS: So is there a way to trace 

13 back and know which modifications are based on the 

14 LG petition and which ones are based on the EN 

15 standard and which ones are based on the Whirlpool?

16 MR. BATTAGLIA: Yes, it should say in the 

17 actual preamble of the SNOPR. We should explain for 

18 each proposed amendment where it's coming from.

19 MR. MORRIS: Yeah, I think I remember 

20 reading that, but I guess I didn't see that then 

21 carried forward in the latter pages.

22 MR. BATTAGLIA: Right. So the latter --

23 the pages you're referring to at the very end of the 

24 SNOPR? Yes, so we wouldn't write in the actual test 

25 procedure --

26 MR. MORRIS: No, you wouldn't. I know 

27 that. But do you have it somewhere, a descriptor 

28 that explains which paragraphs and sections in here 
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1 came out of which?

2 MR. BATTAGLIA: Oh, like from that actual 

3 version of the test procedure? No, we don't have 

4 that right now. 

5 MR. MORRIS: Thanks.

6 MR. BROOKMAN: Subid?

7 MR. WAGLEY: No, Subid Wagley, DOE. I 

8 guess what DOE is requesting is for data and any 

9 information to measure that proposal. So I guess 

10 again we'll probably have some sort of addition 

11 information to supplement what we're proposing here.

12 MR. MORRIS: This is Wayne Morris again. 

13 Valid requests, Subid. But the problem is and we 

14 come back to the comment that we made earlier, is 

15 that in its present form the test procedure that's 

16 in the back is not at a place where we can go to a 

17 laboratory, even the manufacturer's laboratory and 

18 say run this. And that's what's causing us 

19 problems. We have tried. A number of our 

20 manufacturers have tried recreating these tests in 

21 their laboratory, and from what is described there 

22 they're having trouble doing it. So I think that as 

23 these procedures get more and more cobbled together 

24 from different sources they don't read like a test 

25 procedure any longer. They read like definitions 

26 and legal statements rather than like a test 

27 procedure for a test lab to actually follow. And so 

28 I think that's where we're beginning to have 
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1 difficulty actually verifying some of the requests 

2 that are made.

3 MR. BROOKMAN: Wayne, I'm kind of at a 

4 loss for whose principal job it is to kind of -- you 

5 want this array; right? You want this sequence and 

6 values.

7 MR. MORRIS: Yes.

8 MR. BROOKMAN: And I don't know whose --

9 is that something that would typically fall to the 

10 DOE or AHAM or the manufacturer?

11 MR. MORRIS: Well, I guess I would suggest 

12 that at some point in time what might occur and this 

13 is supposition is that AHAM HLD-1 committee will 

14 likely take these changes back and consider 

15 modification -- consider them as requested 

16 modifications to HLD-1. Which is written in the 

17 test procedure format. But we're in this middle 

18 ground now. We have sort of a legalized document 

19 from the Department. We don't have an HLD test 

20 procedure yet and perfectly understandable, the 

21 Department is asking us to go back to the laboratory 

22 and run the tests and we're kind of in one of the 

23 chicken and egg situations here. 

24 So, I don't know whether maybe Navigant 

25 can assist us in trying to piece together a draft. 

26 I mean, I think that that would be one of the things 

27 that would be helpful would be if Navigant could 

28 take HLD-1 and do a track change suggestion of what 
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1 would be the changes that the Department would 

2 suggest to HLD-1 in order to conform exactly what 

3 you're talking about. Not just in this section for 

4 vent-less, but also all the other sections. Take 

5 that as a submission that would come in to the HLD-1 

6 committee and then from that track change document 

7 we could run tests, we could verify levels, and we 

8 could report back to the Department actual changes 

9 that have taken place. You know, what was the 

10 before and what was the after. And that would also 

11 assist HLD-1 in a faster means to process that. And 

12 then at that point we would have a test procedure, 

13 you know, we would have to do some verification 

14 between the Department and between Navigant and 

15 others that they changes that they made are in 

16 keeping. And I know I'm speaking for an AHAM 

17 committee here which is very dangerous. But I think 

18 it's a fair statement that don't -- (inaudible) --

19 on the committee -- Phil. I doubt very seriously if 

20 the HLD-1 committee is going to be wanting to run 

21 tests that are different than the Department of 

22 Energy tests. 

23 So, I would think that that would be a way 

24 that we could resolve this. Do you see what I mean? 

25 I think that would resolve it and I think it would 

26 resolve it relatively rapidly. Probably could be 

27 done in 30 days or less. And then we could have a 

28 document that we could then go into a laboratory and 
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1 say, okay, here do this. And I mean, Navigant 

2 already knows what the changes are. I mean, I think 

3 they could put it into a test procedure language and 

4 you guys now employ testing people and test 

5 procedure people at Navigant. So I think that it 

6 would be possible. A suggestion.

7 MR. BROOKMAN: DOE would still need to do 

8 its whatever level of approval; right?

9 Okay. Thank you for that idea.

10 Additional comments on this? Paige, do 

11 you want to get in here?

12 MS. DETRICK: Just one quick technical 

13 comment, detailed comment that I just noticed. You 

14 reference Section 2.8 for clothes dryer 

15 preconditioning within the vent-less clothes dryer. 

16 It recommends running the dryer until discharged air 

17 is a certain temperature relative to ambient. There 

18 is no discharged air in a vent-less dryer by 

19 definition, so we need a different preconditioning 

20 method.

21 MR. BATTAGLIA: Sorry, that would apply 

22 specifically to vented dryers. And then that would 

23 be qualified in the test procedure. That that 

24 procedure for the discharge air would be --

25 (Simultaneous conversation.) 

26 MS. DETRICK: Okay. Then we come back to 

27 the problem of how do we say that the condensing for 

28 vent-free dryer is at ambient conditions when we go 
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1 from test one -- well, let's say valid test one to 

2 test two to test three and so on. How do we prove 

3 it? There's no way in here to prove it.

4 MR. BROOKMAN: Would you suggest a way?

5 MS. DETRICK: I can look into it.

6 MR. BROOKMAN: Okay, Paige. Okay. 

7 We are going to move on.

8 MR. BATTAGLIA: And the last topic 

9 regarding vent-less dryers is the water consumption. 

10 DOE's review of this issue showed that only vent11 less combo washer/dryers use water to condense 

12 moisture in the air exiting the drum for products on 

13 the U.S. market. 

14 Now, as part of DOE's energy testing for 

15 clothes dryers, we measured the water consumption by 

16 a vent-less combination washer/dryer according to 

17 the alternate test procedure in the LG petition for 

18 waiver by conducting, again, three tests for that 

19 single combo washer/dryer that we had. Our results 

20 showed that the unit consumed on average 3.2 gallons 

21 of cold water per cycle. 

22 Now, combination washer/dryers represent a 

23 very small niche of the U.S. clothes dryer market 

24 and therefore DOE believe that the benefit of 

25 measuring the water used for vent-less dryers would 

26 be outweighed by the burden that we placed on 

27 manufacturers to measure water consumption. So for 

28 this reason DOE is now proposing to amend the DOE 
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1 test procedure to include a requirement to measure 

2 water consumption for vent-less condensing clothes 

3 dryers. And here we're requesting comments and data 

4 on water consumption for vent-less dryers and 

5 whether water consumption should be included in the 

6 DOE test procedure.

7 MR. BROOKMAN: No comments? Okay.

8 MR. BATTAGLIA: All right. The next topic 

9 we're discussing is the detergent specifications for 

10 clothes dryer test cloth preconditioning. And the 

11 current test procedure requires that the test cloth 

12 be preconditioned by performing a ten-minute wash 

13 cycle in a standard clothes washer using the AHAM 

14 standard detergent formula 2A. 

15 Now, DOE notes that this detergent is 

16 obsolete and no longer supplied by AHAM or other 

17 suppliers and that the current AHAM detergent is 

18 formula 3. So because formula 2A is no longer 

19 available, DOE is proposing to amend the test 

20 procedure for test cloth preconditioning to require 

21 the use of the detergent, AHAM detergent formula 3.

22 Now, DOE notes that AHAM’s clothes dryer 

23 test standard, HLD-1-2009 specifies a standard 

24 detergent formula three dosage of 27 grams plus four 

25 grams per pound of base test load for test cloth 

26 pretreatment. And as we'll discuss a bit later in 

27 the SNOPR DOE is also proposing to change the load 

28 size to 8.45 pounds. So based on this the detergent 
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1 dosage for the formula three would be 60.8 grams.

2 So, DOE believes that the detergent 

3 concentration should be set by the pounds of test 

4 cloth in the standard size test load because the 

5 load is more closely matched to the maximum water 

6 fill level than is the compact size test load which 

7 is three pounds.

8 So here DOE is proposing to require 60.8 

9 grams of AHAM detergent formula three for test cloth 

10 preconditioning. And we're also requesting further 

11 information on appropriate detergent concentrations 

12 and we welcome data showing the effects of the 

13 detergent specifications for test cloth 

14 preconditioning on the measured EF for dryers.

15 MR. BROOKMAN: No comments here?

16 (No response.) 

17 MR. BROOKMAN: Okay. 

18 Active Mode: Changes to Reflect Consumer Usage 

19 Patterns and Capabilities 

20 MR. BATTAGLIA: And the next topic is a 

21 few different issues, but it's the changes to 

22 reflect the current usage patterns and capabilities 

23 and we'll be going through those individually.

24 So first for clothes dryers for the number 

25 of annual use cycles, in the 2007 framework document 

26 for the standards rulemaking DOE noted that the 

27 average number of dryer use cycles assumed in the 

28 washer test procedure was inconsistent with the use 
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1 cycles in the dryer test procedure. 

2 Now, in the case of washer annual use 

3 cycles DOE published the final rule for the washer 

4 test procedure in 1997 revising the washer use 

5 cycles from 416 to 392 per year which DOE determined 

6 to be more representative of consumer usage. And 

7 based on the washer test procedure which assumes

8 that 84 percent of all clothes washer loads are 

9 dried in the clothes dryer, the annual usage pattern 

10 for clothes dryers would be calculated to be 329 

11 cycles per year.

12 Now, in contrast the DOE test procedure 

13 currently specifies 416 cycles per year. So as a 

14 result DOE decided to review available data and 

15 investigate a proper value for this dryer use 

16 cycles. And DOE first looked at the 2004 California 

17 statewide residential appliance saturation study or 

18 RASS which included a survey of dryer usage 

19 patterns. Now, the study surveyed over 7,500 

20 households between 2002 and 2003 asking a question 

21 of how many loads of clothes do you dry in your 

22 dryer during a typical week. So for the 6,790 

23 households that said that they own a clothes dryer 

24 the average usage was 4.69 loads per week or 

25 approximately 244 loads per year.

26 However, because the study provided only a 

27 limited dataset, DOE decided not to rely on this 

28 data to determine an appropriate number of use 
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1 cycles.

2 So next DOE reviewed the EIA's 2005 

3 residential energy consumption survey which is a 

4 national sample survey of housing units. And for 

5 each sample home, using the data provided in RECS 

6 for the number of laundry loads, which is to say 

7 washer cycles, that are washed per week and also the 

8 frequency of clothes dryer use, DOE was able to 

9 estimate the number of dryer cycles per year for 

10 each sample house. And as a result of this 

11 analysis, DOE estimated the average usage to be 283 

12 dryer cycles per year.

13 So based on this data DOE is proposing to 

14 revise the dryer use cycles per year to 283 and here 

15 we're requesting comment on that change.

16 MR. BROOKMAN: Wayne.

17 MR. MORRIS: James, just to clarify. I 

18 don't have an opinion on this, I just want to be 

19 sure I understand how you got to 283. So you're 

20 using 392 times 84 percent; is that --

21 MR. BATTAGLIA: No, well, we used the data 

22 from RECS which gave us usage for clothes washers 

23 washer cycles per year and then --

24 MR. MORRIS: Which is what?

25 MR. BATTAGLIA: I don't have that number 

26 off the top of my head. I can probably look it up 

27 for you.

28 MR. MORRIS: Okay. So you used 2005 RECS?
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1 MR. BATTAGLIA: No.

2 MR. MORRIS: No, I don't think so, no. 

3 Because the clothes washer is coming down too. The 

4 current clothes washer test procedure is 392; right? 

5 Okay. And that was set in the year 2000?

6 PARTICIPANT: (Off microphone.) Based on 

7 '96, '97.

8 MR. MORRIS: So it was based on '96 or 

9 '97.

10 MR. BATTAGLIA: '97, I think. '97 the 

11 final rule.

12 MR. MORRIS: So we need to -- can you get 

13 us some information on what RECS says in terms of 

14 number of cycles of clothes washers?

15 MR. BATTAGLIA: Yes. 

16 MR. MORRIS: And then --

17 MR. BATTAGLIA: And then from that we --

18 the RECS also provided data on how often you use a 

19 dryer, so --

20 MR. MORRIS: Percentage.

21 MR. BATTAGLIA: Right.

22 MR. MORRIS: And percentage of loads that 

23 a consumer put from a clothes washer into a clothes 

24 dryer?

25 MR. BATTAGLIA: Right.

26 MR. MORRIS: I think that's the way they 

27 asked it?

28 MR. BATTAGLIA: Yes, I think so.
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1 MR. MORRIS: Okay.

2 MR. BATTAGLIA: Yes, that's correct.

3 MR. BROOKMAN: And that calculation is how 

4 you came to 283?

5 MR. BATTAGLIA: Yes.

6 MR. BROOKMAN: Okay. 

7 MR. BATTAGLIA: I think if you want a 

8 detailed analysis it could be included in the 

9 standards rulemaking TSD. And that was where that 

10 number was derived. So it should be in one of the 

11 TSD chapters.

12 MR. BROOKMAN: Kevin?

13 MR. MESSNER: Yes, this is Kevin Messner. 

14 Just a general comment on RECS. We'll keep 

15 following up on that, we have just general issues 

16 with RECS.

17 MR. BATTAGLIA: And if you have better 

18 data, we would welcome that.

19 MR. MESSNER: Okay. 

20 MR. BROOKMAN: Does AHAN -- do you try and 

21 pull this kind of data from your members?

22 MR. MESSNER: No. I'm not aware of it.

23 MR. MORRIS: This is Wayne Morris. No, we 

24 don't -- AHAM does not pull data from -- and this 

25 would not be from our members, this would be from 

26 consumers. This would be conducting several 

27 thousand households in a demographically based 

28 survey.
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1 MR. BROOKMAN: But would your members, 

2 would they be wanting to assess loads per year. 

3 Maybe Proctor and Gamble are --

4 MR. MORRIS: And that's what our comments 

5 that we delivered to the Department back in April 

26th 6 when AHAM delivered its comments it suggested 

7 that we could look at such sources as those from the 

8 detergent and/or you know dryer material consumer 

9 product manufacturers such as Proctor and Gamble or 

10 --

11 MR. BROOKMAN: Well, in any event, just 

12 to reiterate, if you all have data if you can find 

13 it, the Department would really appreciate that.

14 MR. MORRIS: Proctor and Gamble indicated 

15 in the most recent survey that they released, I 

16 believe, after the Department that the average 

17 consumer dries 5.2 -- 5.35 loads per week or 278 

18 loads per year. And, you know, that's in this case 

19 the value estimated by RECS, I believe, was 279.

20 MR. BATTAGLIA: 283.

21 MR. MORRIS: Or 283.

22 MR. BROOKMAN: Pretty close. 

23 MR. MORRIS: You can use the factor --

24 MR. BROOKMAN: It's pretty close.

25 MR. MORRIS: It's pretty close.

26 MR. BROOKMAN: Yeah, okay.

27 MR. MORRIS: You know, I think our 

28 comments in April were the Department needed to 
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1 verify this to a better methodology than just RECS.

2 MR. BROOKMAN: Yeah. Okay. 

3 So you can see the comment box there. Any 

4 addition comment on that number? And we also talked 

5 about the methodology, so let's now move on.

6 MR. BATTAGLIA: Okay. So the next issue 

7 of current consumer usage patterns is the dryer 

8 initial remaining moisture content. And if you're 

9 not familiar with RMC, it's the ratio of the weight 

10 of water contained by the test load at the 

11 completion of the washer test cycle to the bone dry 

12 weight of the test load expressed as a percent.

13 Correspondingly, the initial RMC of a 

14 clothes load being dried as a function of RMC at the 

15 end of a washer cycle and the current DOE test 

16 procedure specifies an initial RMC of 70 plus or 

17 minus five -- 3.5 percent. Now, as with the average 

18 use cycles the RMC of typical clothes loads in the 

19 residential washer test procedure needs to be or 

20 should be consistent with values defined in the 

21 clothes dryer test procedure. And DOE believes that 

22 the initial RMC in the dryer test procedure may not 

23 reflect typical RMCs of actual clothes dryer loads.

24 Now, since the time that the dryer test 

25 procedure was established in 1981, the average 

26 washer RMC has decreased due to the higher 

27 efficiency models with higher final spin speeds.

28 And for the residential clothes washer 
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1 standard, which became effective in 2007, DOE 

2 estimated a weighted average RMC of 56 percent. 

3 Now, as part of the preliminary analysis 

4 for the residential clothes dryer standards 

5 rulemaking DOE estimated the RMC of clothes washers 

6 using a distribution of values for models listed in 

7 the December 2008 CEC product database. And for 

8 products for which the RMC was listed DOE observed a 

9 range of RMC values between 30 and 61 percent with 

10 an average of 46 percent. 

11 Now, after the October 2007 framework 

12 document AHAM provided data showing the shipments of 

13 residential clothes washers for which the RMC was 

14 reported along with the shipment weighted RMC. And 

15 as you can see on the graph on this slide, this 

16 shows the data that AHAM provided and it's the 

17 aggregated data for all washers including front and 

18 top loading. And it shows that the RMC has been 

19 decreasing consistently from about 54 percent in the 

20 year 2000 to 47 percent in 2008. And it suggests 

21 that the 70 percent in the DOE test procedure is 

22 probably greater than current shipment weighted 

23 residential clothes washer RMCs.

24 So, based on the shipment weighted RMC 

25 data submitted by AHAM and DOE's review of the CEC 

26 product database DOE believes that initial RMC of 47 

27 percent is representative of current residential 

28 dryer initial test load characteristics. So 
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1 therefore DOE is proposing to make this change from 

2 70 percent RMC to 47 percent.

3 Now, in examining the EPCA requirement to 

4 determine the effects of the proposed amendments on 

5 measured efficiency based on DOE's testing conducted 

6 in an independent lab DOE estimated a 41 percent 

7 increase in EF resulting from switching from 70 

8 percent to 47 percent initial RMC. And DOE will 

9 consider addressing this change in the concurrent 

10 standards rulemaking for residential dryers.

11 So here we're requesting comment on this 

12 proposed amendment to change the RMC and that's 

13 based on the shipment weighted RMC of clothes 

14 washers shown in the data submitted by AHAM. And 

15 further we welcome data and comments indicating an 

16 appropriate initial RMC and how that initial RMC 

17 would affect the measured energy factor of clothes 

18 dryers, and in particular for units that are 

19 minimally compliant with the current standards.

20 MR. BROOKMAN: Phil Manthei.

21 MR. MANTHEI: Phil Manthei, Alliance 

22 Laundry Systems. I think there is somewhat of a 

23 disconnect here. You're using the AHAM submitted 

24 data for RMC but from clothes washers. But you have 

25 to remember that data has been -- a correction 

26 factor has been applied to that data for the test 

27 load that is used. In the dryer test procedure 

28 you're using the raw data uncorrected. So you are 
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1 going to have, actually, a curve that's going to be 

2 higher than this red line. And so you should not be 

3 proposing an RMC of 47 percent, it should be 

4 something higher than that. 

5 MR. BROOKMAN: Would you say how much 

6 higher?

7 MR. MANTHEI: Well, this presents a 

8 problem for the Department because you're going to 

9 have to come up with some numbers. And that's going 

10 to have to be done by doing some testing of product 

11 to see, you know, what the -- and this is not of the 

12 dryer, but of the clothes washer -- clothes washers 

13 to see what the uncorrected or noncorrected RMCs 

14 are. Don't confuse extraction characteristics of 

15 moisture with evaporation characteristics in the 

16 dryer. The dryer -- you're testing how well it 

17 evaporates an amount of clothes. And you have to 

18 start with the moisture that's in the clothes load. 

19 Now, the number in the test -- you're 

20 going to be using the same test cloths that the 

21 washer is using. And that's going to vary, of 

22 course, just like in the washer test. However it 

23 varies in the washer test only for extraction. But 

24 I think it needs to start out at the uncorrected 

25 value of, say, 56 percent or 53 percent, whatever 

26 the raw number is from that test towel load not a 

27 correction factor RMC.

28 MR. BATTAGLIA: I'm not sure. What is the 
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1 correction that the washer does this?

2 MR. MANTHEI: Okay. Okay. Because when 

3 this test procedure for clothes washers started it 

4 used an initial test load, I think it was -- you 

5 have to go way back in time in 1993 or '94 time 

6 period when the first test cloth was used and was 

7 gone through the extractor phase to determine how 

8 well it released moisture in the extraction at 

9 various RPMs. And there was a curve that was 

10 presented. Well, anyway, different batches of test 

11 cloth performed differently. And so it was 

12 recognized after about three or four years and me, 

13 my company was the one to raise the issue back in 

14 1997, that there had to be something done and there 

15 was a big group of people along with NIFs, the DOE, 

16 and Navigant, and at that time ADL, Arthur D. 

17 Little, that prepared a method to arrive at a 

18 correlation between the original test cloth and 

19 other batches of test cloth that are produced and 

20 how well it releases the moisture.

21 So, again, all these values that have been 

22 reported here by AHAM are correction factored values 

23 going back to that original test lot. But the

24 actual test loads that are going to be used are not 

25 going to be corrected by X number of percent. 

26 They're going to be the moisture that's in that 

27 load. And I think you're starting out at too low of 

28 a moisture content.
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1 MR. WAGLEY: This is Subid from DOE. 

2 Shall we expect written comments from you? It would 

3 help us guide through --

4 MR. MANTHEI: Yes. Yes. 

5 MR. WAGLEY: -- you know, that information 

6 --

7 MR. MANTHEI: Like I said, I don't know 

8 how to change this curve other than to say you have 

9 to do some testing on clothes washers and see what 

10 the uncorrected values are for maybe various lots of 

11 test cloth. Because over all of these years various 

12 lots of test cloth were used by manufacturers. And 

13 maybe when you get all said and done it's just going 

14 to be easy to say, okay, instead of 47 percent it 

15 should be 5 percent higher than that. I don't know.

16 MR. MESSNER: (Off microphone.) Test 

17 loads as test lot changes then you have to do 

18 correction factor to try to make it --

19 MR. MANTHEI: Yeah, I wouldn't want to say 

20 let's put correction factor calculations into the 

21 dryer test, I think that would make it too 

22 complicated. Just raise this number higher because 

23 you're using uncorrection factored cloth values in 

24 the dryer test procedure. 

25 MR. BROOKMAN: Okay. 

26 MR. BATTAGLIA: The last topic for clothes 

27 dryers regarding consumer usage is regarding the 

28 test load weight. And for this the current DOE 
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1 procedure currently specifies a seven pound load for 

2 standard size dryers and a three pound load for 

3 contact-sized dryers. Now, in response to comments 

4 to the October 2007 framework document DOE 

5 investigated whether the average load size for 

6 standard capacity dryers is consistent with the 

7 current generation of washer capacities.

8 Now, as part of this, DOE contacted 

9 detergent manufacturers to obtain data and Proctor 

10 and Gamble had conducted an internal study in 2003 

11 on household laundry habits on a representative set 

12 of population across the U.S. and from this Proctor 

13 and Gamble provided DOE with a select summary data 

14 from the study.

15 And the data showed that the test load 

16 weight which was based on a sample size of 3,367 

17 loads of laundry from a total of 510 respondents, it 

18 showed that the average load size for top loading 

19 and front loading washers was 7.2 and 8.4 pounds 

20 respectively.

21 Now, based on the average shipment 

22 weighted market share for top loading and front 

23 loading washers from the data provided by AHAM the 

24 shipment weighted average clothes washer size would 

25 be approximately 7.5 pounds using this data. 

26 However, DOE recognizes that washer capacities were 

27 likely to have increased since the time that the 

28 study was conducted in 2003 and therefore DOE 
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1 continued its analysis to factor in the more recent 

2 changes of the clothes washer capacities.

3 And here on this graph, it shows the 

4 trends in the shipment weighted average tub volume 

5 for residential clothes washers between 1981 and 

6 2008 based on data from AHAM's report, the Trends in 

7 Energy Efficiency 2008. And the data shows that the 

8 average tub volume has increased from 2.5 cubic feet 

9 in 1981 to 3.22 cubic feet in 2008 which is a 22.4 

10 percent increase.

11 Now, Section 2.7 regarding test load sizes 

12 of the DOE washer test procedure provides the 

13 minimum, maximum, and average test load size 

14 requirements for the washer test procedure which is 

15 determined based on the clothes container capacity. 

16 So this table here is an excerpt from that table and 

17 shows the values for the test load sizes for the 

18 2.52 and 3.22 cubic feet container capacities. And 

19 DOE notes that the average load size in the washer 

20 test procedure increased by about 21 percent with 

21 the associated increase in capacity shown in the 

22 AHAM data which DOE believes would proportionately 

23 impact the clothes dryer load sizes. So applying 

24 this ratio of the average clothes washer test sizes 

25 to the clothes dryer test load sizes would result in 

26 an increase from 7 pounds to 8.45 pounds for 

27 standard sized dryers.

28 So based on this data DOE is proposing to 
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1 amend the dryer test load size to 8.45 pounds plus 

2 or minus .085 pounds for standard sized dryers.

3 Now, DOE believes that most compact 

4 clothes dryers are used in conjunction with compact5 sized washers and DOE does not have any information 

6 to suggest the tub volume for such washers has 

7 change significantly. So therefore we are not 

8 proposing to change the three pound test load size 

9 currently as specified for compact-sized clothes 

10 dryers.

11 Now, again, looking at that EPCA 

12 requirement to determine the effects on the measured 

13 efficiency, in order to determine a quantifiable 

14 estimate of the change in measured efficiency the 

15 DOE looked at data from a report by NIST which 

16 conducted testing to investigate the effects of 

17 changing clothes dryer load size on the measured 

18 efficiency for a vented electric standard size 

19 clothes dryer.

20 Now, using this data DOE estimated the 

21 percentage change in EF for an 8.45 pound test load 

22 by linearly interpolating the results for the 7-

23 pound and nine-pound tests from the NIST data. And 

24 the resulting increase would be a 3.8 percent 

25 increase from this test load size change.

26 So here we're requesting comment on this 

27 proposed amendment to change the dryer test load 

28 size for compact -- or for standard-sized dryers to 
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1 8.45 pounds plus or minus .085 pounds. And we're 

2 also welcoming data on washer and dryer test load --

3 whoops -- on washer and dryer test load sizes 

4 representative of current consumer usage habits for 

5 both compact and standard-size units. And we're 

6 further requesting data on how any changes to the 

7 test load size would affect the measured energy 

8 factor of clothes dryers and in particular for those 

9 that are minimally compliant with the current 

10 standards.

11 MR. BROOKMAN: Wayne.

12 MR. MORRIS: Yeah, Wayne Morris with AHAM. 

13 So, James, help me here if I understand this. I 

14 thought I had read earlier also in the SNOPR that 

15 the Department was not suggesting that the energy 

16 factor for clothes dryers would be impacted by the 

17 changes to the test procedure; did I read that 

18 correctly?

19 MR. BATTAGLIA: No, it's for the test load 

20 weight we're projecting a change in the EF and 

21 that's that 3.8 percent. We looked at each proposed 

22 amendment individually to determine the effects on 

23 the measured efficiency.

24 MR. MORRIS: Okay. So the Department is 

25 suggesting an increase of 3.8 percent in the energy 

26 factor overall?

27 MR. BATTAGLIA: Right. Due to this 

28 specific proposed amendment.
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1 MR. MORRIS: Just to this?

2 MR. BATTAGLIA: Right. 

3 MR. MORRIS: Are there then adjustments --

4 I guess from now on today we're going to be talking 

5 about room air conditioners, aren't we? Do we come 

6 back and do clothes dryers again? I mean, I guess 

7 we do.

8 MR. BATTAGLIA: We touch upon clothes 

9 dryers a little later, I think. And we will have a 

10 section at the end to look at the -- or to discuss 

11 the effects of the measured or the proposed changes 

12 on the measured efficiency for the total proposed 

13 test procedure. 

14 MR. MORRIS: Okay. Okay. Thanks, James.

15 MR. BATTAGLIA: Are there no other 

16 comments on this?

17 (No response.) 

18 MR. BATTAGLIA: Now, switching over to 

19 room air conditioners. The current DOE room air 

20 conditioner test procedure assumes an average annual 

21 use of 750 hours. Now, DOE's technical support 

22 document from September of 1997, which was issued in 

23 support of the most recent room air conditioner 

24 energy conservation standards showed that the 

25 average annual operational hours are closer to 500 

26 hours. Now, DOE's investigation of this issue 

27 showed a lack of metered and surveyed data for the 

28 operating hours of identification room air 
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1 conditioners. However, DOE did find two sources of 

2 survey data for room air conditioners, for room air 

3 conditioner use in the EIA's 2005 RECS and the CEC 

4 California statewide RASS. 

5 Now, the CEC RASS survey contained only 

6 aggregated residential data which limited any 

7 analysis pertaining to the annual operating hours. 

8 And the relevance of this data was also limited by 

9 it only having a regional scope. 

10 Now, the EIA's 2005 RECS provided more 

11 extensive data on individual residences while 

12 providing a more expansive and representative sample 

13 of households. So DOE decided to continue its 

14 analysis using the 2005 RECS. 

15 So using the RECS data DOE was able to 

16 develop a household sample for the annual hours of 

17 use of a room air conditioner which was then used to 

18 calculate a weighted national average of room air 

19 conditioner usage hours. This data indicated that 

20 the estimated room air conditioner average annual 

21 usage is approximately 810 hours. However, DOE does 

22 not consider this increase of 60 hours from 750 to 

23 810 hours to be significant because it does not 

24 exceed the uncertainty level that's associated with 

25 RECS' base data, the RECS based approach for 

26 estimates of this value. So therefore DOE is not 

27 proposing a change in the annual operating hours in 

28 the test procedure at this time. So here we're 
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1 requesting comment on this issue of the --

2 MR. BROOKMAN: Kevin.

3 MR. MESSNER: Yeah, thanks. Again, we 

4 think RECS has got issues. And also however we 

5 think the 750, just stick with the 750 annual usage 

6 at this point.

7 MR. BROOKMAN: Your other issues with 

8 RECS, to the extent possible you'll address them in 

9 your written comments?

10 MR. MESSNER: Yeah, again. We've already 

11 -- we've already commented in numerous ways about 

12 the issues we have with RECS.

13 MR. WAGLEY: Subid Wagley from DOE. Is 

14 there any other source that you would like to 

15 recommend since there are issues that you said with 

16 RECS that are valid at this point to reference for 

17 us?

18 MR. MESSNER: I can't give you, I don't 

19 have any, I don't know of any right now. That 

20 doesn't mean -- I have to go back and check in all 

21 of the written comments.

22 MR. WAGLEY: We'll just wait.

23 MR. BROOKMAN: Okay. Thank you.

24 Other comments?

25 In particular if you don't think sticking 

26 with 750 is a good idea, now is the time to say it?

27 Please. Your name?

28 MR. BURGOS: Hi, I'm Javier Burgos from 
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1 Navigant Consulting. I just wanted to mention that 

2 you've also asked for comments on this before, in 

3 particular for the standards rulemaking for DOE. So 

4 some of this has already been commented on before 

5 and you have received some suggestions. Any more 

6 suggestions would also be greatly appreciated.

7 MR. BROOKMAN: Okay. Thank you. 

8 Yes, Wayne.

9 MR. MORRIS: Wayne Morris with AHAM. I 

10 think that our issues that we have gone into 

11 excruciating detail with about the present 

12 construction of RECS stand for themselves. But I 

13 think that what is necessary to understand with 

14 regard to room conditioners are that the percentage 

15 of homes that have room air conditions is declining 

16 as more and more people that need air conditioning 

17 can use central air conditioning and so it begins to 

18 get more and more difficult to get survey work on 

19 room air conditioners. They also are beginning to 

20 use more and more in a cooling space cooling or 

21 assistance cooling kind of sequence within homes 

22 rather than as primary cooling in many situations 

23 and consequently that becomes another issue with 

24 trying to get data. I mean, are you trying to cool 

25 the air or how much are you trying to cool? Are you 

26 assisting your central air conditioning or other air 

27 conditioning by doing this or are you using it as 

28 your primary means. So any survey that is going to 
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1 be done has got to be very carefully done on room 

2 air conditioners. 

3 Size loading of a room air conditioner is 

4 absolutely critical and consumers -- there's a long, 

5 long history of commentary that consumers buy too 

6 large an air conditioner for the space that they 

7 need and thereby cause themselves problems in 

8 accordance with using it. It freezes up the 

9 compressor or they over cool, or they don't use it 

10 properly, it doesn't extract the moisture. Because 

11 moisture extraction is probably the most important 

12 job that any air conditioning system has secondary 

13 to actually reducing the temperature.

14 So then when you get into this, then when 

15 you ask somebody that has too large an air

16 conditioner that they now have put into a relatively 

17 small room how often they use it, are they 

18 responding on the number of hours that they actually 

19 are using it or the number of hours that they should 

20 have used it if they had the right size unit. And 

21 this becomes part of the problem with getting this 

22 kind of data. 

23 We understand and sympathize with the 

24 Department trying to do this, but the problems with 

25 RECS are so deep that we've got to find a better way 

26 of doing this. Now, I know that the Department has 

27 come up with some alternatives. They've had some 

28 suggestions about doing some survey work using 
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1 college student dormitories on refrigerators and, 

2 you know, a selected group of hotels in California, 

3 or something along that line, but I think that we've

4 got to seriously look at trying to get good solid 

5 data on which we can make these kind of 

6 determinations rather than just sort of, oh, by the 

7 way estimates. 

8 Are there some power line communication 

9 type of information that's out there that's 

10 available to us? PNNL did some survey work years 

11 ago on street estimates of use of material. Now, 

12 granted, that is a demographic or geographic area 

13 that may not be representative of the entire United 

14 States, moisture not withstanding, although Spokane 

15 might be a good example or San Antonio. But, you 

16 know, we do have to figure out how we can get to 

17 this kind of data. It's not going to be easy and 

18 it's probably not going to be cheap. But we do, for 

19 all of these appliances, we have a responsibility to 

20 get better data than where we are at today. And I 

21 hope that the Department would convene some meetings 

22 or discussions or whatever about specifically on the 

23 issue of how to get to solid data. Because every 

24 one of these rulemakings is dependent upon this, it 

25 doesn't matter what product it is. And I don't care 

26 if it's even light ballasts or televisions, it's 

27 important that we have the right data to do this. 

28 And we don't now. And so, you know, in absence of 
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1 better data, probably better off, as Kevin said, 

2 looking at 750. But we do encourage, even though 

3 saying that, we encourage the Department to find 

4 another way.

5 MR. BROOKMAN: Thank you.

6 We're going to keep moving on here.

7 MR. BATTAGLIA: Okay. Now for part load 

8 performance. DOE noted in the October 2007 

9 framework document that the current DOE test 

10 procedure measures only full load performance and it 

11 is not able to assess energy savings associated with 

12 technologies that improve part load performance. 

13 Now, DOE does not plan to consider 

14 amendments to its room air conditioner test 

15 procedure to measure part load performance because 

16 DOE has concluded that widespread use of part-load 

17 technologies in room air conditioners would probably 

18 not be stimulated by the development of a part-load 

19 metric and hence the significant effort of 

20 development of an accurate part-load metric is 

21 likely not warranted by the expected minimal energy 

22 savings.

23 Now, DOE also considered whether the 

24 ambient temperature conditions in the room air 

25 conditioner test procedure are representative of 

26 typical installations. And DOE had received 

27 comments in response to the framework document that 

28 the ambient temperature should be increased from 95 
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1 -- that should say degrees Fahrenheit to 115 degrees 

2 Fahrenheit. However, DOE did not receive further 

3 information to support the specification of the 

4 higher temperature. And therefore, DOE is not 

5 considering an amendment to the ambient temperature 

6 conditions in the room air conditioner test 

7 procedure. So, here we're inviting comment and data 

8 indicating a representative ambient temperature 

9 condition and also requesting data on how any 

10 changes to these conditions would affect the 

11 measured efficiency.

12 MR. BROOKMAN: Kevin?

13 MR. MESSNER: Kevin Messner. AHAM 

14 supports the current test condition at 95.

15 MR. BROOKMAN: Thank you.

16 Active Mode: Room Air conditioners and Dryer 

17 Referenced Test Procedures, Technical Correction for 

18 Gas Dryers, Clarification to Dryer Gas Supply 

19 Conditions 

20 MR. BATTAGLIA: Okay. The next topic will 

21 be the room air conditioner referenced test 

22 procedure.

23 Now the current DOE test procedure for 

24 room air conditioners references two test standards 

25 that are shown here, the American National Standard 

26 Z234.1 which was established in 1972 and the ASHRAE 

27 Standard, 16-69 which was established in 1969. Now, 

28 both the ANSI and ASHRAE test standards have since 
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1 been updated since the time that the DOE room air 

2 conditioner test procedure was last revised. And 

3 those current standards are shown here, the 

4 ANSI/AHAM RSE1-R2008 and ANSI/ASHRAE Standard 16-

5 1983 which was reaffirmed in 2009.

6 Now, does suggested in the October 2007 

7 framework document to consider updating the test 

8 procedure references to the most recent versions and 

9 DOE reviewed the difference between -- the 

10 differences between the older test standards and the 

11 current versions of those standards to determine if 

12 proposing amendments would be appropriate. 

13 Now, DOE first notes that the sections 

14 that would be referenced in ANSI/AHAM RAC1-R2008 do 

15 not introduce any new changes in the measurement of 

16 cooling capacity or power input. And DOE also notes 

17 that the sections that will be referenced in 

18 ANSI/ASHRAE 16-1983 would introduce changes to the 

19 determination of capacity four temperature 

20 measurements -- four new temperature measurements 

21 and changes to the test tolerances. 

22 So DOE is proposing to amend the test 

23 procedure to reference the relevant sections of 

24 these two updated standards. Now, based on DOE's 

25 review of these standards DOE believes that these 

26 new standards provide more accurate and repeatable 

27 measurements of capacity while providing a greater 

28 flexibility to manufacturers in selecting equipment 
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1 and facilities and do not add any significant 

2 testing burden. So we are inviting comments on this 

3 proposed amendment to update the references to the 

4 most recent versions of those standards.

5 MR. BROOKMAN: No comments from anyone?

6 (No response.)

7 MR. BROOKMAN: Okay.

8 MR. BATTAGLIA: Now for the clothes dryer 

9 referenced test procedure the clothes dryer test 

10 procedure currently references the industry standard 

11 AHAM HLD-1-1974 and specifically requires that the 

12 clothes dryer under test be restricted by adding the 

13 AHAM exhaust simulator described in Section 3.3.5 of 

14 that standard. 

15 Now, DOE received information that this 

16 AHAM test standard has since been updated and the 

17 current version is AHAM-HLD-1-2009. And DOE noted 

18 that the Section 3.3.5.1 of the revised AHAM 

19 standard regarding the exhausting conditions 

20 provides the same requirements for the exhaust 

21 simulator as required by the existing DOE test 

22 procedure. So for this reason DOE is just proposing 

23 to amend the reference to the most recent version to 

24 reference that appropriate section.

25 Now, DOE also recognizes that the AHAM26 HLD-1-2009 allows for the use of an optional 

27 modified exhaust simulator which is included as a 

28 more convenient option than the exhaust simulator 
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1 originally specified for vented dryers. However, 

2 the AHAM test standard also notes that only limited 

3 testing has been done to compare the results using 

4 the two different exhaust simulators and the users 

5 are invited to submit results and comments for both 

6 options. 

7 So because the modified exhaust simulator 

8 is still new and limited data exists to compare the 

9 effects using the different simulators DOE is 

10 continuing to require the standard exhaust simulator 

11 currently specified. 

12 Now, on a slightly different note in the 

13 definition section of the DOE test procedures, 

14 Section 1.8 references an obsolete AHAM standard 

15 HLD-2EC for which there is no provisions currently 

16 in the DOE test procedures. So we're proposing to 

17 just remove that reference.

18 MR. BROOKMAN: Kevin.

19 MR. MESSNER: Kevin Messner with AHAM. I 

20 am shocked to hear -- for the record that's tongue 

21 in cheek -- that we support the updating to the most 

22 recent AHAM standards.

23 MR. BROOKMAN: Thank you. So on the 

24 following slide you can see the comment box, you can 

25 all read it there for yourselves, and comments on 

26 slide 102?

27 (No response.) 

28 MR. BROOKMAN: Okay. 
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1 MR. BATTAGLIA: Now the next topic is a 

2 technical direction for the gas dryer --

3 MR. BROOKMAN: No, excuse me. Wayne?

4 MR. MORRIS: Excuse me, James, slide 

5 behind you and I'm sorry about that. But in 

6 reference to slide, I guess it's one oh -- I guess 

7 it's 100?

8 MR. BATTAGLIA: Yeah. This is 101 now.

9 MR. MORRIS: Your numbers are a little 

10 different than mine.

11 MR. BATTAGLIA: Right.

12 MR. MORRIS: Where you said that because 

13 of only limited testing had been done on the 

14 modified exhaust simulator, of course, that was like 

15 a year and a half ago or two years ago when the 

16 standard went through. I mean, it finally achieves 

17 ANSI approval in 2009, but it was done probably two 

18 or three years ago. There may be some additional 

19 testing by now that's been done on this and we'll 

20 try and see if we can find out if some of our member 

21 companies have used the modified exhaust simulator 

22 and we'll submit that with our written comments. 

23 But, you know, if we can come up with some 

24 additional data to show the comparison between the 

25 two items that the Department will be open to using 

26 the modified exhaust simulator rather than sticking 

27 with the old one in situations. We'll take that on 

28 as an activity that we do for the written comments. 
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1 Thanks.

2 MR. BROOKMAN: Thank you.

3 MR. BATTAGLIA: Okay. SO the next is the 

4 technical correction. And for this the equation in 

5 the current DOE test procedure contains a technical 

6 error for the calculation of the per cycle gas dryer 

7 continuously burning pilot light gas energy 

8 consumption which is expressed in the BTUs per 

9 cycle. 

10 Now, that equation should correctly 

11 subtract the active mode hours per years from the 

12 total hours per year to give the number of non13 active mode hours per year that the pilot is 

14 consuming gas before dividing by the average number 

15 of dryer cycles in a year. And it should read, as 

16 we have shown here, there's a parenthesis missing in 

17 there, so we're proposing to revise this equation 

18 and seeking comment on that.

19 MR. BROOKMAN: Phil Manthei.

20 MR. MANTHEI: Phil Manthei, Alliance 

21 Laundry Systems. My mind recalls that the minimum 

22 standard, I thought, EPCA NACA has a minimum 

23 standard and it's got a design prescriptive. In 

24 that the design prescriptive says you cannot have a 

25 pilot light. 

26 MR. BATTAGLIA: That was the previous 

27 standard. The current standard is a performance 

28 standard. So presumably if you had a high enough 
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1 efficiency unit, I don't know why you would, but you 

2 could presumably use a burning pilot light.

3 MR. MANTHEI: Really. Did that -- that 

4 never got -- that didn't get carried over?

5 MR. BATTAGLIA: That's not how --

6 MR. BROOKMAN: Does anyone from the 

7 Department want to comment on how that put back in?

8 MR. MANTHEI: Yeah. I'm absolutely -- I 

9 mean, I don't think there is anybody that has one. 

10 And that's why I even question whether it should 

11 even be in the test procedure.

12 MR. BROOKMAN: Judy Reich?

13 MS. REICH: It's my understanding that the 

14 current performance standard is sufficiently high 

15 that it effectively precluded any constant pilot 

16 lights so that the prescriptive design requirement 

17 was eliminated. If there were some way to achieve 

18 that and still have a pilot light, that would be 

19 considered acceptable. But effectively there's 

20 nothing on the market anymore that can meet this

21 standard with a pilot.

22 MR. BROOKMAN: Okay. Wayne Morris.

23 MR. MORRIS: Maybe I'm missing something 

24 on a slide. Yeah, the slide you've got up there on 

25 the screen now. Should that 416 be 416?

26 MR. BATTAGLIA: Oh, sorry. Yeah, that 

27 would be changed to 283. My apologies. 

28 MR. MORRIS: Oh, thanks. 283. In both 
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1 places?

2 MR. BATTAGLIA: Right. 

3 MR. MORRIS: We are sort of dealing with 

4 buggy whips because, as Judy said, I don't think 

5 there's anybody on the market with a constant 

6 burning pilot light dryer and I seriously doubt that 

7 anybody is going to come out with one tomorrow. So, 

8 you know it is a little bit silly to be doing, but 

9 we need to for accuracy of the regs. 

10 MR. BROOKMAN: Right. Thanks for that 

11 confirmation.

12 MR. BATTAGLIA: Okay. And the next topic 

13 is a clarification to the gas supply test conditions 

14 for gas dryers. So DOE is proposing a clarification 

15 to Sections 2.3.2.1 and 2 of the current DOE test 

16 procedures which specify maintaining the gas supply 

17 to the clothes dryer to normal inlet pressure 

18 immediately ahead of all controls at seven to ten 

19 inches of water column for natural gas and 11 to 13 

20 inches of water column for propane gas.

21 Now, DOE believes that the reference to 

22 the normal inlet test pressure in these sections 

23 which are provided to specify natural gas and 

24 propane supply pressure conditions may be confusing 

25 as to what is meant by the term "normal." And DOE 

26 believes that such language is not necessary because 

27 the gas supply pressure immediately ahead of all 

28 controls is explicitly stated with these values. So 
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1 DOE is proposing to modify the language as you can 

2 see here.

3 MR. BROOKMAN: No comments? 

4 (No response.)

5 MR. BROOKMAN: No comments.

6 MR. BATTAGLIA: Okay.

7 MR. BROOKMAN: Before you move on, I'm 

8 going to suggest that we all just stand up and 

9 stretch for a minute. Let's just do that. Don't go 

10 anywhere. 

11 (Pause.) 

12 MR. BROOKMAN: Okay. While James is 

13 getting to the right slide I'm going to hand out --

14 Brenda Edwards made a copy of those of you that 

15 provided a business card as you registered to enter 

16 today, so we'll hand those around. And, James, you 

17 can proceed. 

18 MR. BATTAGLIA: Okay. So DOE also 

19 believes that the specifications for the gas 

20 pressure regulator in these same sections should 

21 clarify that the outlet pressure for a dryer with a 

22 pressure regulator for which the manufacturer 

23 specifies an outlet pressure should be approximately 

24 that recommended by the manufacturer. So for this 

25 DOE is proposing to make these minor revisions to 

26 the language in these sections to clarify the outlet 

27 pressure conditions for a dryer equipped with a gas 

28 pressure regulator. And, again, we are here 
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1 requesting comments on these proposed clarifications 

2 to the language for specifying natural gas and 

3 propane supply pressure conditions for testing gas 

4 dryers.

5 MR. BROOKMAN: That's okay? Yeah. I'm 

6 looking over here at you guys? That's yes.

7 Okay.

8 Compliance with EPCA; Requirements; Effects of Test 

9 Procedure Revisions on Compliance with Standards 

10 MR. BATTAGLIA: All right. Now, getting 

11 into the compliance with some other EPCA 

12 requirements. This is mainly regarding the test 

13 burden and EPCA basically requires that any amended 

14 test procedure must produce test results which 

15 measure energy efficiency use or other metric of a 

16 covered product during the representing of average 

17 use cycle or period of use and must not be unduly 

18 burdensome to conduct.

19 Now, in the December 2008 test procedure 

20 NOPR DOE tentatively concluded that the proposed 

21 amendments for a standby and off mode for both 

22 products would satisfy this requirement. 

23 Now, for the proposed amendments for 

24 standby and off mode in the SNOPR would not require 

25 measurement of delay start and cycle finish modes 

26 for dryers and delay start and off-cycle mode for 

27 room air conditioners and instead would use a 

28 simplified approach in which the hours are allocated 
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1 to inactive and off modes.

2 Also for room air conditioners DOE had 

3 received comments in response to the December 2008 

4 test procedure NOPR that the proposed ambient 

5 conditions -- temperature conditions would increase 

6 testing burden. And as we discussed earlier for the 

7 NOPR, DOE is now proposing to provide manufacturers 

8 with more flexibility in setting the ambient 

9 conditions for standby and off-mode testing.

10 Now, DOE tentatively concludes that the 

11 testing conditions for standby and off-mode proposed 

12 in the SNOPR for both products are not unduly 

13 burdensome.

14 Now, for active mode, the proposed 

15 amendments to the DOE test procedure for clothes 

16 dryers to test automatic termination control dryers 

17 and vent-less dryers are based on the international 

18 testing standards that we presented which are used 

19 to determine compliance with energy conservation 

20 standards for dryers in Australia, New Zealand, and 

21 also the European Union for the EN standard. 

22 And DOE notes that a number of 

23 manufacturers that sell dryers in the U.S. also sell 

24 dryers in these countries and therefore likely are 

25 already testing dryers according to this test 

26 standard. So DOE believes that the proposed 

27 amendments would not require testing methods and 

28 equipment that are substantially different from the 
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1 testing methods and equipment in the current DOE 

2 test procedure and therefore would not require 

3 manufacturers to make a major investment in test 

4 facilities and in new equipment.

5 And also for DOE's proposed amendments to 

6 reflect current consumer usage patterns and 

7 capabilities, those amendments do not substantially 

8 change the test procedures and methods such that 

9 they would be burdensome to conduct.

10 Now, for room air condition active mode. 

11 The proposed amendments to update the references to 

12 the external standards in the DOE room air 

13 conditioners test procedure are based on revised 

14 standards representing current industry practices 

15 and methods. So these proposed amendments would not 

16 require manufacturers to make any significant 

17 investments in test facilities and equipment. Nor 

18 require significant changes in testing methodology.

19 MR. BROOKMAN: So let's just -- do we have 

20 comments on any of those preceding slides? There 

21 are four slides total there related to test burden, 

22 standby off mode, clothes dryer active mode, and 

23 room air conditioner active mode. Comments on any 

24 of those?

25 Phil Manthei?

26 MR. MANTHEI: Maybe the only thing was 

27 regarding my comments about the initial RMC that I 

28 made that we should look at whether we should be 
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1 using 47 percent or something different that is a 

2 higher number because RMC is based on a corrected --

3 MR. BROOKMAN: Right.

4 MR. MANTHEI: -- factored test cloth in 

5 the washer and the test procedure for the dryer is 

6 not going to use that corrected factor.

7 The reason it could become a burden is, 

8 okay, we'd like to use, you know, our home-style 

9 clothes washer to extract the load to use in the 

10 dryer test procedure. However, a clothes washer is 

11 going to necessarily get the load down in the dryer 

12 to 47 percent.

13 MR. BROOKMAN: No.

14 MR. MANTHEI: So here's where the issue 

15 is. Okay. 

16 MR. BROOKMAN: Okay. That made it clear.

17 MR. MANTHEI: Now, obviously we make 

18 commercial clothes washers that, you know, can 

19 extract at a much higher, you know, RPM or whatever 

20 and we can still get there. It wouldn't be 

21 impossible, but you get my point, we still have a 

22 disconnect between RMC and the dryer test procedure 

23 and what values were submitted from the clothes 

24 washer test procedure. 

25 MR. BROOKMAN: Okay. Wayne?

26 MR. MORRIS: Phil, also if you begin 

27 extracting that test cloth down to 47 percent, 

28 you're going to actually deteriorate that test cloth 
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1 at a faster rate, aren't you? I mean, you're going 

2 to cause other problems associated with trying to do 

3 that. I mean, you're going to use an extractor, I 

4 guess. But now you're talking about some fairly 

5 significant amounts of money to spend on it.

6 MR. MANTHEI: I’m not sure that it would 

7 be significant, but I don't have any information on 

8 that.

9 MR. BROOKMAN: Okay. 

10 Compliance with EPCA; Requirements; Effects of Test 

11 Procedure Revisions on Compliance with Standards 

12 MR. BATTAGLIA: Okay. Now touching on the 

13 effects of the test procedure revisions on 

14 compliance with standards. And we have discussed 

15 this a little bit in the individual sections about 

16 the EPCA requirement to determine to what extent the 

17 proposed test procedures would alter the measured 

18 efficiency as compared to the existing test 

19 procedure. And if DOE determines that it would in 

20 fact alter the measured efficiency of a covered 

21 product, DOE must amend the applicable energy 

22 conservation standard.

23 Now for standby and off-mode, EPCA 

24 requires that these amendments will not determine 

25 compliance with previously established standards.

26 So for the clothes dryer active mode, for 

27 the proposed amendments DOE believes that there are 

28 revisions to the initial RMC and the standard size 
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1 dryer test load would affect the energy factor as 

2 compared to the existing test procedure. And based 

3 upon DOE's testing and analysis of a minimally 

4 compliant dryers and review of available research, 

5 DOE believes that the proposed amendments to the 

6 initial RMC would increase the measured energy 

7 factor by 41 percent and the test load change would 

8 increase the measured energy factor by 3.8 percent. 

9 So based on the total proposed amendments, 

10 the measured energy factor of minimally compliant 

11 dryers would increase by about 41 percent for 

12 compact clothes dryers and about 46 percent for 

13 standard sized dryers. And here you can see in the 

14 data what these changes would look like for each 

15 product class. And DOE will consider these changes 

16 in the concurrent energy conservation standards 

17 rulemaking for dryers and room air conditioners.

18 MR. BROOKMAN: Let's just pause it there 

19 for a second. Give them a chance to look at it.

20 (Pause.)

21 MR. BROOKMAN: We're on the table. Looks 

22 good. Okay. 

23 MR. BATTAGLIA: Okay. Now, because the 

24 proposed clothes dryer test procedure amendments for 

25 active mode would substantially change the existing 

26 energy factor metric DOE has tentatively decided to 

27 create a new Appendix D1 in the 10 CFR 430, Subpart 

28 B for the proposed amendments. And Appendix D1 
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1 would contain a clothes dryer test procedure that 

2 manufacturers would be required to use on the 

3 mandatory compliance state of amended dryer energy 

4 conservation standards. And manufacturers would 

5 continue to use Appendix D until the energy 

6 conservation standards are amended. And at that 

7 time testing would be conducted according to 

8 Appendix D1.

9 Now, for room air conditioners based on 

10 DOE's review of the proposed amendments DOE has 

11 tentatively concluded that the proposed amendments 

12 would not affect the measured EER of room air 

13 conditioners. SO here we're inviting comment on how 

14 the proposed amendments for dryers and room air 

15 conditioners will affect the measured efficiency of 

16 covered products. DOE is seeking data showing how 

17 each of these proposed amendments would affect the 

18 measured EF or EER of minimally compliant dryers and 

19 room air conditioners.

20 MR. BROOKMAN: Wayne?

21 MR. MORRIS: James, just help me on the 

22 room air conditioner on that slide. You're not 

23 proposing any change to the EER on RACS. We are 

24 including now the standby measurement?

25 MR. BATTAGLIA: Right. And that would be

26 separate. This is just looking at the active mode.

27 MR. MORRIS: Okay. Just for the active 

28 mode EER?
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1 MR. BATTAGLIA: Right.

2 MR. MORRIS: Not the IEER or whatever?

3 MR. BATTAGLIA: Right. So the EPCA 

4 specifies that the IEER wouldn't be used to 

5 determine compliance with the existing standard. 

6 MR. MORRIS: Okay. Okay. I see. Okay. 

7 Thanks.

8 MR. BROOKMAN: Phil.

9 MR. MANTHEI: Phil Manthei, Alliance 

10 Laundry Systems. The only thing we have to remember 

11 here is on the clothes dryer we're connecting some 

12 dots back to the clothes washer test procedure. I 

13 know there's going to be a separate rulemaking on 

14 that coming up. If we start making changes to 

15 anything especially like that average load size and 

16 the average load size chart or something and the 

17 washer that we keep -- you know, whatever we change 

18 there has got to come back over to here.

19 MR. BROOKMAN: Okay. Other comments on 

20 this slide, this series of slides? I think that's 

21 the last of the slides. There are back-up slides as 

22 well for your reference. So thanks, James. That 

23 was well done.

24 Now is an opportunity for anybody that 

25 wishes to do so to make closing remarks, summary 

26 remarks regarding issues that matter to you that you 

27 think perhaps were not covered sufficiently during 

28 the course of this meeting today.
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1 (No response.)

2 MR. BROOKMAN: Okay. I see none. Then 

3 I'll turn it back to our DOE host and hostess.

4 Closing Remarks

5 MS. SULLIVAN: Okay. Well, thank you all 

6 so much for coming. And I'm looking forward to 

7 reading your comments and seeing any data that you 

8 guys can submit, that would be especially helpful.

9 Just a reminder, the comment period closes 

August 30th 10 , and you can submit comments either to 

11 the e-mail that's up there, or by post to Brenda 

12 Edwards, or on Regulations.gov. 

13 So, again, thank you. I hope nobody gets 

14 too wet on their way home.

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20 MR. BROOKMAN: Thank you. Save travels. 

21 Please take just a moment to fill out the evaluation 

22 form.

23 Thanks for a very productive day.

24 (Whereupon, at 2:43 p.m., the meeting was 

25 adjourned.)

26

27
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18 REPORTER'S CERTIFICATE

19

20 This is to certify that the attached proceedings 

21 before:

22 U.S. DEPARTMENT OF ENERGY 

23 In the Matter of:

24 PUBLIC MEETING TEST PROCEDURE SNOPR FOR

25

26 RESIDENTIAL CLOTHES DRYERS AND ROOM AIR CONDITIONERS

 
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1

2 Were held as herein appears and that this is the 

3 original transcript thereof for the file of the 

4 Department, Commission, Board, Administrative Law 

5 Judge or the Agency.

6 Further, I am neither counsel for or related to 

7 any party to the above proceedings.

8

9

10

11 Debbi Derr 

12 Official Reporter

13

14 Dated: July 15, 2010