UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

**PUBLIC MEETING**

ON

**TEST PROCEDURE SNOPR FOR** 

**RESIDENTIAL CLOTHES DRYER S**  **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 EnergyExecutive Court Reporters (301) 565

- 0064 2 **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, DOEExecutive Court Reporters (301) 565

- 0064 3 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 NRDCExecutive Court Reporters (301) 565

- 0064 4

**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

C omments 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,
Measure s 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 13 2

Active Mode: Room Air Conditioner and Dryer Referenced Test Procedures, Technical Corrections for Gas Dryers , Clarification to Dryer Gas Supply Conditions 1 5 5

Complian ce with EPCA: Requirements ; Effects of Test Procedure Revisions on Compliance with Standards 1 64Executive Court Reporters (301) 565

- 0064 5

P R O C E E D I N G S 1

9:10 a.m. 2

MR. BROOKMAN: Thank you. Rich Karney is 3

going to make welcoming remarks. 4

M R. KARNEY: I’d like to thank everybody 5

for coming for to day’s meeting on the

-- Public 6

Meeting on Test Procedures Supplemental Notice of 7

Proposed Rulemaking for Residential Clothes Dryers 8

and Room Air Conditioners . My name is Richard 9

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

recently have been reassigned from doing work on 11

Energy Star to heading up test procedure 12

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

that we’ll be discuss ing today. 14

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

out, he ard, that the airports were closed for a 16

while last night due to the heavy thunderstorms, and 17

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

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

So people will probably be filtering in as we 20

proceed on. 21

I’d like to thank everybody for coming and 22

look forward to a hearty and heartful discussion 23

this mor ning, and without controversy, of course. 24Executive Court Reporters (301) 565

- 0064 6 MR. BROOKMAN: Thank you. Let’s start by 1

doing introduc tions. I'll start over here to my 2

left. Please say y our name and organizational 3

affiliation. And for those of you sitting here at 4

the table, you can ge t in the habit of pushing the 5

button and seeing the little green LED light come 6

on. Yes, please. 7

**SELF INTRODUCTIONS** 8

MR. MANTHEI: Phil Manthei, Alliance 9

Laundry Systems. 10

MR. MESSNER: Kevin Messner with AHAM. 11

MR. MORRIS: Wayne Morris with AHAM. 12

MS. DETRICK: Paige Detrick, BSH. 13

MS. WALTNER: Meg Waltner, NRDC. 14

MS. HOWRAN: Kate Houren, NRDC. 15

MS. MAUER: Joanna Mauer, Appliance 16

Standards Awareness Project. 17

MS. LOWENBERGER: Amanda Lowenberger, The 18

American Council for an Energy

- Efficient E conomy. 19

MR. BROOKMAN: We’ll go over here. 20

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

Department of Energy. 22

MS. SULLIVAN: Meg Sullivan, DOE. 23

MR. KARNEY: Rich Karney, DOE. 24

MR. BATTAGLIA: James Battaglia, Navigant 25Executive Court Reporters (301) 565

- 0064 7 Consulting. 1

MR. BURGOS: Javier Burgo s, Navigant 2

Consulting. 3

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

MR. PARKER: Graham Parker, Pacific 5

Northwest National Laboratory. 6

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

MR. FITZGERALD: Jason Fitzgerald, D & R 8

International. 9

AGENDA REVIEW 10

MR. BROOKMAN: Thanks, everyone. Did we 11

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

Solutions in Baltimore. I think all of you received 13

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

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

presentation s lides. I think most of you, all of 16

you are familiar with the general format for this 17

meeting. We will be using these presentation slides 18

as the framework for both presentation and 19

discussion, and the Department will be seeking 20

specific comments over the course of the day. 21

I’ m going to run through the agenda very 22

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

looking at it. Immediately following this agenda 24

review, there’s going to be a brief introduction of 25Executive Court Reporters (301) 565

- 0064 8 regulatory overview segment by Margaret. Following 1

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

opportunity for anybody that wishes to do so to make 3

brief summary remarks here at the outset, issues 4

that matter to the stakeholders in the room. 5

Following that we’ll go to the 6

presentation ma terials, “Covered Products; 7

Standby/Off Mode: Incorporating by Reference IEC 8

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

continue on “Determination of Modes to be 10

Incorporated, Added Specifications to the Test 11

Method and Measurements.” 12

We’ll take a br eak mid

- morning, about 13

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

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

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

Mode: Dryer Automatic Cycle Termination.” 17

We’ll break for lunch around about noon

18

ish, and then continuin g on immediately following 19

lunch, “Active Mode: Vent

- less Dryers, Detergent 20

Specifications for Dryer Test Cloth 21

Preconditioning,” “Active Mode: Changes to Reflect 22

Consumer Usage Patterns and Capabilities,” Active 23

Mode

-- lots of Active Mo de here

-- “Active Mode: 24

Room Air Conditioner and Dryer Referenced Test 25Executive Court Reporters (301) 565

- 0064 9 Procedures, Technical Corrections for Gas Dryers, 1

Clarification to Dryer Gas Supply Conditions.” 2

And then finally, “Compliance with EPCA 3

Requirements, Effects of Test Procedure Rev isions on 4

Compliance with Standards.” 5

There’s an opportunity again at the end of 6

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

so to raise any other issues, emphasize things that 8

have not been covered sufficiently during the course 9

of the day. 10

W e intend to end today I guess around 11

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

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

to comment. 14

So that’s the plan for the day. 15

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

are familiar with t he way we typically do this. I’d 17

ask for your consideration. Please speak one at a 18

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

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

every time, but your name would be helpful. 21

There will be a comp lete transcript of 22

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

posted on the EERE website. More information 24

surrounding how you submit your comments as we go on 25Executive Court Reporters (301) 565

- 0064 10 in the day. I’m going to be cueing people by name 1

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

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

Department to hear the back and forth between 4

different perspectives. And if you can keep the 5

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

and if you need to have a sidebar conversatio n, 7

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

We’ll understand. 9

Also, if you can be concise with your 10

comments. Share the air time, that would be 11

helpful. Questions and comments here at the outset 12

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

-- 13

yes, Margaret. 14

**INTRODUCTION AND REGULATORY OVERVIEW** 15

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

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

this is the SNOPR Public Meeting for the AHAM

- 2 test 18

procedure, and just a reminder, the NOPR was 19

published December 9, 2008, and this SNOPR was 20

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

We’re interested in comments on this SNOPR 22

from all of you. Transcripts will be available and 23

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

that can be done through the AHAM

- 2 e

- mail address, 25Executive Court Reporters (301) 565

- 0064 11 or on regulations.gov, and we will review and 1

consider all of your comments. 2

Just a brief history of this regulation. 3

The final rule

-- the first final rule for clothes 4

dryers published in 1981 e stablished provisions for 5

measuring the energy factor. The first test 6

procedure for room air conditioners was published in 7

1977, which established provisions for measuring the 8

energy efficiency ratio and incorporated ANSI and 9

ASHRAE standards. 10

The EISA 2007 amended the Energy Policy 11

and Conservation Act, directing the Department of 12

Energy to incorporate standby and off mode energy 13

consumption into its test procedures for clothes 14

dryers and for room air conditioners. And the 15

clothes dryers and room air c onditioners test 16

procedure, NOPR, which was issued in 2008 proposed 17

amendments to the statutory requirements to 18

incorporate measures of standby and off mode energy 19

consumption. And we received comments regarding 20

using the IEC standard, the second edition committee 21

draft, and harmonizing with that. 22

After the 2008 test procedure and NOPR was 23

published, DOE decided to allow for consideration of 24

a revised version of the IEC standard, which was 25Executive Court Reporters (301) 565

- 0064 12 expected to be published in 2009. However, we more 1

recently foun d out that the IEC standard second 2

edition was not expected to be published until the 3

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

consideration of standby and off mode power 5

consumption for the concurrent conservation 6

standards rule making. 7

So DOE decided to publish the SNOPR, to 8

consider the new mode definitions from the most 9

recent draft version of the IEC standard, which is 10

the IEC standard 62301 committee draft for vote. 11

DOE believes that such new mode definitions 12

represent the best definition s available for the 13

analysis and support of the SNOPR. 14

The framework document to consider amended 15

energy conservation standards for residential 16

clothes dryers and room air conditioners published 17

in 2007 identifies revisions to the active mode test 18

proced ure s for covered products, and DOE decided to 19

conduct a rule making to address active mode test 20

procedures after the December 2008 NOPR was 21

published. And so active mode is also addressed in 22

this SNOPR. 23

MR. BROOKMAN: So having finished with 24

that overvi ew, let’s provide an opportunity for 25Executive Court Reporters (301) 565

- 0064 13 anybody that wishes to make brief summary remarks at 1

this point. Wayne Morris. 2

**SUMMARY REMARKS FROM PARTICIPANTS** 3

MR. MORRIS: Thank you, Doug. Wayne 4

Morris with AHAM. Meg, thank you for the 5

consideration and I’d li ke to explain a couple 6

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

member of the International Committee on 62301, and 8

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

I can appreciate the difficulties that the 10

slowness of this IEC process has prevailed on the 11

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

happened with this very long, slow process of the 13

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

would mention, holding up some regulations that are 15

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

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

or Final Draft International Standard, is due to be 18

published by the Secretariat of the IEC this Friday, 19

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

because of the time it takes to do a Fr ench 21

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

There are a number of minor, I would call 23

them, changes, but necessarily important changes in 24

the FDIS. The committee draft for both, the C D V 25Executive Court Reporters (301) 565

- 0064 14 that went out last August and votes were then 1

compiled in Fe bruary 2010, engendered a number of 2

comments, fairly substantial, technical comments. 3

That is a little bit odd to have very long and

-- 4

long series of comments come at the CDV stage. 5

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

Committee Draft st age. 7

The vote, however, was overwhelmingly in 8

favor of the CDV version, and so in technical 9

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

because there were a large number of comments, the 11

Secretariat of the IEC asked the committee to go 12

back and d eal with these changes, which, throughout 13

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

took place in February and March and that then 15

resulted in the publishing, compiling of all that in 16

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

where we are right now. 18

In sort of technical parlance, the FDIS 19

stage will go through a voting, but it is 20

perfunctory, and the only reason that somebody can 21

vote different than what they voted the last time is 22

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

don’t expect that to happen. 24

The other thing about an FDIS stage is the 25Executive Court Reporters (301) 565

- 0064 15 only thing that can be done in the FDIS stage is 1

make grammatical types of changes. You cannot 2

change anything of any substance at that stage. And 3

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

d ocument is legally able to be referenced in a 5

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

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

situation, but in most countries an FDIS stage can 8

be legally referenced as essentially the final 9

version beca use the only thing you can do is put a 10

comma or correct a spelling or something along that 11

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

FDIS stage will occur this

-- very soon, this week 13

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

e
- mail yester day. 15

I would mention that the FDIS will have a 16

number of fairly substantial, when you look through 17

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

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

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

clarifications in most cases. So for instance, the 21

test room will have a large number of changes 22

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

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

substance to what our proceedings are. Because the 25Executive Court Reporters (301) 565

- 0064 16 paragraphs that they’re a dding, for instance, deal 1

with ambient light conditions in the test room, and 2

that’s particularly important because there are some 3

appliances that are sensitive to light. They dim 4

down in a bright light circumstance, and bright 5

light in a dim light. So c onsequently, they had to 6

make provisions for that, and specify the exact 7

ambient light conditions. 8

The other thing that will be, I think will 9

be substantial and will affect the Department of 10

Energy is a fairly extensive addition of what’s 11

called the unce rtainty power measurement section. 12

And that is a very important one because it will 13

narrow down the differences that any two 14

laboratories can measure. So it will result in more 15

accurate measurements. So I do believe that it 16

would be important for the De partment to reference 17

the FDIS because it will have more accurate 18

measurement materials in it, for frequency response, 19

term averaging, power measurement, all of the 20

uncertainty activities are in here that will change 21

in the FDIS document. 22

The sampling me thod is a whole new section 23

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

how you go about dealing with multiple samples as 25Executive Court Reporters (301) 565

- 0064 17 whether they are representative of the field. And I 1

think that that again is a very important section 2

which will be of interest and of help to the 3

Department in trying to get accurate measurements. 4

Average reading methods is a whole new 5

section that will appear in this. So for that 6

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

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

im portant that the Department reference the FDIS, 9

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

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

representative on the U.S. tag through Lawrence 12

Berkley National Laboratories. And so as soon as it 13

com es out, they would have a copy and they can 14

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

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

can come directly from the Secretariat’s office in 17

Geneva if you feel you need to see it passed 18

directly from t hem for legal purposes or whatever. 19

But I think what we would encourage is 20

instead of using the CDV which still contains some 21

items in there that needed some clarification, I 22

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

blanket document that you use, and we will make 24

those comments in our written submittal to the 25Executive Court Reporters (301) 565

- 0064 18 Department at the time. 1

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

grossly characterize this, is there anything that’s 3

significantly changed that would run contrary to 4

what the Departmen t of Energy is proposing? 5

MR. MORRIS: There are some definitional 6

changes of

-- I’m sorry, Wayne Morris with AHAM

-- 7

some definitional changes in here in regard to what 8

is considered standby and off mode that probably 9

will influence some of the elements that the 10

Department has put into this SNOPR and to the slides 11

that I had a chance to see this morning. 12

MR. BROOKMAN: And were you

-- 13

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

from DOE. We were having a

-- can you repeat that? 15

You were just tal king about the standby and off mode 16

definitions? 17

MR. MORRIS: There are some changes to the 18

way the off mode and standby mode are characterized. 19

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

yes, I do believe they will influence the situation 21

with th e way that the Department has characterized 22

some of the features and the elements that are in 23

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

that it’s important changes. And particularly when 25Executive Court Reporters (301) 565

- 0064 19 you get into this area of trying to read what is an 1

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

the definition changes, very slight definitional 3

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

Department asks. 5

The other situation has to do with the 6

expansion of the mode definitions that are in the 7

De partment’s EPCA mode definitions are more clearly 8

clarified, I think, in the FDIS. 9

So without spending a huge amount of time 10

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

reference to the FDIS would be important and it 12

probably also, then, when you see i t, will want to 13

go back and reconsider some of the elements that are 14

in here, particularly as it applies to clothes 15

dryers and some of the sensory mode situation, and 16

to the room air conditioner where it refers to 17

remote control situations. Those are the ones that 18

I picked up as being most influenced by this. 19

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

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

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

how the FDIS stage document might influence these 23

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

information yet? 25Executive Court Reporters (301) 565

- 0064 20 MR. MORRIS: I would be real cautious 1

about doing that, Doug. 2

MR. BROOKMAN: Okay. 3

MR. MORRIS: The first one up is this 4

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

say I want to real ly take some time and study the 6

FDIS versus what

-- that you have in the slides on 7

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

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

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

in our written comments. 11

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

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

really a smart thing for the Department of Energy to 14

try and harmonize with the IEC. They made some 15

significant accommodations to try to make this work, 16

and they des erve a lot of credit for that, and 17

Wayne, I appreciate you referencing this and talking 18

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

continue with this process. 20

Okay, other then, comments here at the 21

outset? Brief summary remarks about issues that 22

matte r to those in the room. Yes, Kevin. 23

MR. MESSNER: Yes. Kevin Messner for the 24

AHAM. Just kind of an overview. Yes, SNOPR is very 25Executive Court Reporters (301) 565

- 0064 21 lengthy and we’re still kind of going through it in 1

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

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

not seen or not understanding, definitions, and 4

things like that. And so

-- for instance, on the 5

auto

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

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

fairly high level thr oughout the day, in trying to 8

understand this better, and trying to glean a little 9

more details. 10

MR. BROOKMAN: Okay. Thank you. Other 11

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

Battaglia. 13

**COVERED PRODUCTS; ST ANDBY/OFF MODE: INCO**  **RPORATING** 14

**BY R EFERENCE IEC 62301**  15

MR. BATTAGLIA: Hi everyone. The first 16

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

exactly what products are covered by the proposed 18

amendments to the test procedures. And the 19

definitions of covered products are provided in the 20

Code of Federal Regul ations under 10 CFR 430.2, 21

which provides definitions for both gas and electric 22

clothes dryers. And the key descriptors here would 23

be that these are appliances that utilize a tumble

24

type drum with forced air circulation, where the 25Executive Court Reporters (301) 565

- 0064 22 heat source can either b e gas or electric, depending 1

on the type of dryer under test. 2

So it is anticipated that these proposed 3

test procedure amendments would cover dryers that 4

are both conventional vented type gas and electric, 5

which would include standard size and compact siz e 6

units, and also ventless clothes dryers, which would 7

include combination washer/dryers. 8

Similarly, for room air conditioners, the 9

same s ections of the CFR provides that this product 10

is distinct from a packaged terminal air 11

conditioner, but that it is p owered by a single 12

phase electric current, and is designed for mounting 13

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

it describes the function to provide conditioned air 15

which can include not only cooling, but ventilation 16

and heating as well. 17

So ag ain, it’s anticipated that these 18

proposed amendments would cover products that are 19

ro ughly analogous with what were analyzing in the 20

energy conservation standards, and namely, that 21

these are room air conditioners that are for single 22

or double hung windows, and under that category, 23

they can either be with or without louvered sides, 24

or with or without reverse cycle to provide a 25Executive Court Reporters (301) 565

- 0064 23 heating function. 1

Additionally, the covered products would 2

also include casement mounted, a casement slider or 3

a casement only wind ow
- type room air conditioners. 4

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

into is the proposed amendments to the test 6

procedure concerning standby and off mode. 7

**STANDBY/OFF MODE: DETERMINAT**  **ION OF MODES TO BE** 8

**INCORPORATED** 9

MR. BATTAGLIA: In the December 2008 test 10

procedure NOPR, DOE had proposed to incorporate by 11

reference certain sections from IEC 62301 first 12

edition, for measuring both standby and off mode 13

power. And the parts of IEC 62301 first edition 14

that were propose d were from Section 4, relating to 15

the supply voltage, frequency and wave form; 16

secondly, the ambient room temperature conditions; 17

and finally, the power measurement meter tolerances. 18

And DOE is also proposing to incorporate 19

by reference clauses from Sect ion 5 related to the 20

testing methodology that’s used for standby and off 21

mode testing. And specifically, these clauses would 22

clarify that the measurement of standby mode is to 23

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

short duration higher power state that precedes it. 25Executive Court Reporters (301) 565

- 0064 24 For example, if a display were to automatically dim 1

or power down after a certain period of user 2

inactivity, that measurement would take place at 3

that lower power state. 4

Secondly, the IEC clauses provide a 5

technique for measurin g an average standby mode and 6

off mode power, if the measurement is either stable 7

or unstable. And for unstable power measurements, 8

it provides a description for measuring a 9

representative cycle of that power. 10

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

Qu estions? Comments surrounding this material? 12

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

comment? Please use the microphone and say your 14

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

for the record. 16

MS. TADDONIO: Christine Taddonio with t he 17

Energy Star Program. Just a quick clarification on 18

the definition of a ventless clothes dryer? That 19

does also include heat pump clothes dryers, is that 20

correct? 21

MR. BATTAGLIA: If the heat pump dryer was 22

a ventless design, yes it would

-- would incl ude 23

that. 24

MS. TADDONIO: Okay. Thank you. 25Executive Court Reporters (301) 565

- 0064 25 MR. BROOKMAN: Thank you. Other questions 1

or comments? Okay. 2

MR. BATTAGLIA: As we discussed a bit 3

earlier, the IEC is developing an updated standard

- 4

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

first noted in the NOPR had an expected publication 6

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

draft versions, we expected that the revisions would 8

include different mode definitions. 9

And as we discussed earlier, because the 10

expected publicatio n date got pushed out further and 11

from what we knew before, it was expected to be

-- 12

not be published until late 2010, DOE decided to 13

publish the SNOPR to consider the new standby/off 14

and active mode definitions from the latest draft 15

version of IEC 62301, which was designated as the 16

committee draft for vote version. And DOE believes 17

that these definitions expand upon the EPCA mode 18

definitions that were proposed in the NOPR, and 19

would provide additional guidance as to which 20

functions are associated with eac h mode. 21

So, for these reasons, DOE is proposing to 22

revise the proposed amendments to include 23

definitions of standby, off, and active modes based 24

on the provisions in IEC 62301 committee draft for 25Executive Court Reporters (301) 565

- 0064 26
vote. 1

Now, getting back to the specific clauses 2

from IEC 62301 first edition, for the testing 3

methodology that was proposed in the NOPR, DOE 4

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

opposed to the proposed test methods and procedures, 6

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

from the NOPR to incorporate those specific clauses 8

that we presented earlier. 9

So at this point, we’re inviting comments 10

on the adequacy of IEC 62301 first edition for 11

measuring standby and off mode in both clothes 12

dryers and room air conditioners, and specifically, 13

the suitability of incorporating the clauses from 14

Section 4 and 5 that we have shown here. 15

MR. BROOKMAN: You can see the question, 16

the comment box right there on the screen, so if

-- 17

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

specific as possible wit h these comments. Wayne. 19

MR. MORRIS: Wayne Morris with AHAM. I 20

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

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

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

we would hope that the second ed ition FDIS would be 24

more accurate and more up to date in almost every 25Executive Court Reporters (301) 565

- 0064 27 one of the items that you’ve got listed down below 1

there. So I think that

-- and I think that it’s 2

also

-- the latest edition has taken into account a 3

lot of comments from the energy ef ficiency advocate 4

groups and others to try and narrow the differences 5

down to allow for repeated testing to be better 6

served and to create less possibility that different 7

laboratories would get different results on this. 8

When you’re getting down into ver y, very 9

small numbers

-- I mean you’re talking about tenths 10

or hundredths of a watt

-- little differences of 11

methods of testing can mean a lot to companies and 12

to the Department. So it becomes more important to 13

have accuracy than ever before. So one of t he 14

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

MR. BROOKMAN: Thank you. Other comments 16

related to this comment box? Okay. 17

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

discussing is the mode definitions

-- modes and 19

definitions that we’re proposi ng to incorporate. 20

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

standby, and an off mode using EPCA mode 22

definitions. And DOE noted that for active mode, 23

the EPCA mode definition, which stated that the

-- 24

it’s a mode in which the product is connected to a 25Executive Court Reporters (301) 565

- 0064 28 main power source, has been activated, and provides 1

one or more main functions, was developed to be 2

broadly applicable to many products. So in order to 3

clarify the range of main functions, DOE had 4

proposed in the NOPR to clarify those main functions 5

for each product. 6

So DOE also proposed in the NOPR to define 7

multiple standby modes which included, for clothes 8

dryers, the inactive modes, cycle finish ed mode, and 9

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

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

mode. 12

So as we discussed a bit earlier, DOE i s 13

revising its proposed active mode, standby and off 14

mode definitions, based on the IEC 62301 committee 15

draft for vote version. Now DOE i s proposing the 16

following definition that we have here for active 17

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

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

- using 19

product is connected to a main power sourc e, has 20

been activated, and provides one or more main 21

functions.” 22

Now, the IEC committee draft for vote 23

version, which was published prior to the committee 24

draft for vote

-- I’m sorry, the committee draft 2 25Executive Court Reporters (301) 565

- 0064 29 version, which was published immediately before the 1

committee draft for vote version, provided an 2

additional clarification that delay start mode is a 3

one
- off user initiated short

- duration function that 4

would be associated with an active mode. 5

Now, DOE noted that IEC 62301, the CDV 6

version, removed t his clarification, however, IEC 7

stated in response to comments to the CD2 version, 8

which ultimately led to the CDV version, that delay 9

start mode is a one

- off function of limited 10

duration. And DOE inferred that delay start mode 11

would not be considered a s tandby mode, however no 12

conclusion was made as to whether it would be 13

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

active mode, DOE is proposing to use the same 15

clarifications that were proposed in the NOPR for 16

the range of main functions that woul d be classified 17

under this mode. 18

So again, based on the

-- 19

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

just for a moment. That

-- so anybody? Okay. 21

Okay. 22

MR. BATTAGLIA: So based on the 23

definitions in the CDV version, DOE is proposing 24

here to define s tandby mode as “Any product modes 25Executive Court Reporters (301) 565

- 0064 30 where the energy using product is using”

-- I’m 1

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

mains power source and offers one or more of the 3

following user orientated or protective functions 4

which may persist for an i ndefinite time.” And the 5

first would be to facilitate the activation of other 6

modes which includes the activation or deactivation 7

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

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

would be providing c ontinuous functions, including 10

information or status displays, or sensor

- based 11

functions.” 12

Now, DOE is also proposing to include an 13

additional clarification that a timer is a 14

continuous clock function which may or may not be 15

associated with a display, th at provides regular, 16

scheduled tasks and operates on a continuous basis. 17

Now, based on the proposed definition of 18

standby mode, delay start and cycle finish ed mode 19

for clothes dryers and delay start and off

- cycle 20

mode for room air conditioners are not mo des that 21

persist for an indefinite time, so they wouldn’t

-- 22

would therefore not be considered part of standby 23

mode. 24

DOE’s analysis of the annual energy use in 25Executive Court Reporters (301) 565

- 0064 31 specific clothes dryers and room air conditioner 1

modes that we presented in the NOPR determine d that 2

these modes each represent a negligible portion of 3

point one percent or less of the annual use

-- 4

energy use for that particular product. So 5

therefore, DOE believes an integrated efficiency 6

metric for both products would not be measurably 7

affected by either the inclusion or exclusion of the 8

energy use in any of these modes. 9

Further, DOE believes that the benefit of 10

incorporating the energy use in these modes into the 11

overall energy efficiency would be outweighed by the 12

burden that would be placed on manufacturers to 13

measure power consumption in each of these modes. 14

So for these reasons, DOE is not proposing 15

amendments to the test procedure to define or to 16

measure power consumption in each of these modes, 17

and DOE is only including in the proposed 18

a mendments, provisions for measuring energy 19

consumption in the inactive and off mode. 20

So here, again, we’re requesting comments 21

on the proposed definition of standby mode, which is 22

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

we’ll stop for that one fi rst. 24

MR. BROOKMAN: Okay. Kevin. 25Executive Court Reporters (301) 565

- 0064 32 MR. MESSNER: Kevin Messner. Two things, 1

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

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

remote control issue for RACs. One way of remote 4

control should not be pa rt of standby if it’s just

- 5

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

conditioner with a remote control, the remote 7

control doesn’t allow necessarily to interact with 8

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

apt to

-- folks would be turni ng that off, so that 10

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

And then the other issue we need to look 12

into more in our written comments is the

-- assuming 13

that a timer function is actually a clock with a 14

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

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

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

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

expansion of the clock function. 19

MR. BATTAGLIA: Would you mind commenting, 20

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

mean by a one

- way remote? Because I assume that for 22

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

sensor, infrared sensor to receive that signal from 24

the remote to shut it off, I guess. 25Executive Court Reporters (301) 565

- 0064 33 MR. MESSNER: Right, it would be one way, 1

one way from the remote to the room air conditioner 2

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

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

not necessarily obtaining signals back from the room 5

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

nothing on the room air conditioner that’s going 7

back and forth. 8

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

MR. MESSNER: No. 10

MR. BROOKMAN: Oh, okay. 11

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

MR. BROOKMAN: Okay. So that’s why yo u 13

said it that way. Okay. 14

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

clarification, these one way remotes are used, in 16

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

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

they allow a consumer, for instance, t o shut the 19

unit off in what some people call a “hard

- off” kind 20

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

room air conditioners is not listening constantly 22

for a signal, and not using significant amount of 23

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

then it would require the consumer to actually, 25Executive Court Reporters (301) 565

- 0064 34 physically get up and move across the room and push 1

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

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

room air conditioner in which it’s listening for 4

that off signal, but it’s not a two

- way 5

communication device and so the signal strength is 6

much lower. 7

Because of that, a number of other 8

organizations and governments have viewed these one

9

way remotes as essentially being exempt from the 10

standby mod e and have viewed them as being a good 11

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

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

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

the Department would do likewise. 15

As Kevin mentioned, the timer function, I 16

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

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

is a continuous clock function

-- the timer is only 19

set by the consumer on a clothes dryer when they 20

move it into a timer sequence, in o ther words, they 21

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

continuous clock function if it’s manually selected 23

by the consumer and it only lasts for a defined 24

period of time? Maybe I’m thinking of something 25Executive Court Reporters (301) 565

- 0064 35 other than what you’re thinking of. 1

MR. BATTAGLIA: Right. This is my 2

understanding of it, that it could be something like 3

a
-- some sort of timing device for a 4

microcontroller in electronic controls that keeps 5

time for that function. 6

MR. MORRIS: But according to the 7

definitions in 62301 , in any edition of 62301 that 8

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

function is not viewed as

-- as standby. 10

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

like a

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

control boards, but like a microcontr oller would 13

have like a timer chip

-- or a crystal that keeps 14

time for the microcontroller, so it would be running 15

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

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

think of for these products that it would maybe 18

apply to. 19

MR. MORRIS: Okay, but if the electronic 20

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

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

energy state in a delayed start type of function, 23

then that is a

-- of a limited duration and would 24

not be counted in this. 25Executive Court Reporters (301) 565

- 0064 36 MR. BATTAGLIA: Right, so

-- yes, if it is 1

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

would not be considered part of standby. 3

MR. MORRIS: Okay, I think the

-- for that 4

matter

-- for the reason, I think it wou ld be 5

important that the Department in the final language 6

that it uses be very careful that it delineates 7

those situations. Thank you. 8

MR. BROOKMAN: Thank you. Okay. Helpful 9

comments. Additional comments on these

-- did we 10

address the second comment box, James? 11

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

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

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

record? 15

MR. BATTAGLIA: All right, so the second 16

thing we’re inviting comment on is the establishment 17

of inactive mode as the only standby mode for both 18

clothes dryers and room air conditioners, and the 19

determination that delay start modes, cycle finish ed 20

mode, and off cycle mode for these products would 21

not be considered standby modes. And DOE is further 22

inviting comment on the proposed mode definitions 23

and on the question of whether there are any modes 24

consistent with active, standby and off mode 25Executive Court Reporters (301) 565

- 0064 37 defini tions that have not been identified and that 1

can represent a significant energy use. 2

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

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

comments on this? 5

MR. BATTAGLIA: Okay, now based on

-- 6

sorry
-- another to pic regarding the modes and 7

definitions

-- sorry, I’m on the wrong slide here

-- 8

to be incorporated into the DOE test procedure is 9

with a network mode. And DOE received comments in 10

response to the NOPR that it should consider a 11

network mode. Now, the IEC 62301 CDV version 12

includes a definition of network mode which it 13

defines as “a mode category which includes any 14

product modes where the energy

- using product is 15

connected to a main power source and at least one 16

network function is activated, such as the 17

re activation via network command, or network 18

integrity communication, but where the primary 19

function is not active.” 20

However, DOE is not aware of any clothes 21

dryers or room air conditioners currently on the 22

market that incorporate a networking function. A nd 23

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

network mode in these products which would allow it 25Executive Court Reporters (301) 565

- 0064 38 to determine appropriate test procedures and mode 1

definitions for incorporation into the DOE test 2

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

the amendments

-- the proposed amendments in the 4

SNOPR do not include a network mode. 5

And here we’re requesting comment on this, 6

on whether there are clothes dryers and room air 7

conditioners that are currently available that 8

incorporate a networking func tion, and whether 9

definitions and test procedures for this mode should 10

be incorporated into the DOE test procedure. And 11

DOE would also request comments on appropriate 12

methodologies for measuring the energy consumption 13

in this mode, and data on the results and 14

repeatability of such testing methodology. 15

MR. BROOKMAN: Kevin. 16

MR. MESSNER: Kevin Messner. Network mode 17

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

And it also

-- it’s very important to remember is 19

this is

-- has huge implications to th e development 20

of the Smart Grid and Smart Appliances, which our 21

industry is trying to move forward and trying to 22

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

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

its infancy, and we’re trying to develop those 25Executive Court Reporters (301) 565

- 0064 39 products, but having

-- network mode has to be 1

considered as a distinctive energy user that 2

enhances the whole overall electrical grid, and the 3

efficiencies that come with that, the savings of 4

energy, the line losses, the reduced carbon 5

emissions, th e reduction of peaker plants, all of 6

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

reason, network mode has to be distinctive. It 8

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

stake in the heart of the development of Smart 10

Appliances and the Smart Grid. 11

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

please, Joanna. 13

MS. MAUER: Joanna Mauer. Just a 14

clarification. So I know that definitions proposed 15

by DOE would network mode not be considered part of 16

standby? 17

MR. BATTAGLIA: We’re not proposing t o 18

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

determination. 20

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

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

of standby or other modes, would just be considered 23

then the energy use of network mode is not captured 24

anywhere in the test procedure. 25Executive Court Reporters (301) 565

- 0064 40 MR. BROOKMAN: James, can you respond to 1

that? 2

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

able to propose amendments at this time because 4

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

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

under a network mode would fall under the definition 7

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

those products are operating when they’re using that 9

network function. 10

MR. BROOKMAN: You want to restate your 11

concern, Jo anna? 12

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

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

the near future will have this network mode 15

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

suggestion for how it should be included, but the 17

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

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

use is not captured anywhere in the test procedure. 20

MR. BROOKMAN: Okay. Subid. 21

MR. WAGLEY: Subid Wagley, U S DOE. I was 22

just going to suggest that if the stakeholde rs have 23

any recommendations or suggestions or any sort of 24

information to incorporate with their comments, that 25Executive Court Reporters (301) 565

- 0064 41 we’d like to review that and, you know, look at it. 1

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

moving towards more of a balance sheet approach, 3

right, because it

-- like this, yeah. It’s getting 4

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

let’s proceed. 6

MR. BATTAGLIA: And finally, as with 7

active and standby mode definitions, DOE is 8

proposing to define off mode using the definition, 9

or ba sed on the definition in the IEC 62301 CDV as a 10

mode which includes any product modes for the 11

energy
- using product is connected to a mains power 12

source and is not providing any standby or active 13

mode function, and where that mode may persist for 14

an indefin ite time. 15

And we’re also proposing to include the 16

additional statement that an indicator that only 17

shows that the user

-- that the user that the 18

product is in the off mode position would be 19

included within the classification of off mode. 20

MR. BROOKMAN: Yes, Wayne. 21

MR. MORRIS: Wayne Morris. Just to 22

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

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

MR. BATTAGLIA: Okay. Thank you. 25Executive Court Reporters (301) 565

- 0064 42 MR. BROOKMAN: Thank you. 1

MR. BATTAGLIA: Shall we move on? 2

MR. BROOKMAN: Let’s move on. 3

**STANDBY/OFF MODE: ADDED SPECIFICATIONS**  **TO THE TEST** 4

**METHOD AND MEASUREME NTS**  5

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

get into is the added specification for the testing 7

methods and requirements for standby and off mode 8

testing. A nd these added specifications are 9

necessary because the IEC 62301 was written in a 10

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

including added specifications specific to these 12

products. 13

So starting with the test period for 14

clothes dryers, DOE un derstands that displays on 15

clothes dryers may reduce the power consumption by 16

automatically dimming or powering down after a 17

period

-- a certain period of user inactivity. So 18

for those dryers for which the power input in active 19

mode varies in this way, DO E is proposing

-- or DOE 20

proposed in the NOPR to have the test be conducted 21

after the power level drops to the lower power 22

state. 23

Now, the provisions in IEC 62301 first 24

edition that were proposed in the NOPR, state that 25Executive Court Reporters (301) 565

- 0064 43 For products in which the power is stable, which is 1

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

percent from a maximum level during a period of five 3

minutes, that we would wait at least five minutes 4

for the product to stabilize, and then measuring the 5

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

less than five minutes. 7

Now, alternatively, in cases where the 8

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

more than five percent, the IEC 62301 requires a 10

measurement period of no less than five minutes, or 11

one or more comple te operating cycles, which could 12

be several minutes or hours. 13

Now, in response to the NOPR, DOE received 14

comments that the standby and off mode test 15

procedures should specify a 30

- minute stabilization 16

period, and measurement period of at least ten 17

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

some dryers may actually remain in the higher power 19

state for the duration of the five minute 20

stabilization and five minute measurement period, 21

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

would be more representative of inactive mode. 23

And the IEC 62301 CDV version specifies 24

for each testing method that the product be allowed 25Executive Court Reporters (301) 565

- 0064 44 to stabilize for at least 30 minutes prior to a 1

measurement period of not less than ten minutes. 2

And DOE believes that this cla rification would allow 3

sufficient time for delays that automatically dim or 4

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

so before the measurement period has started. And 6

DOE believes that this provision would allow for a 7

representative measurement among products that may 8

have varying times before the power drops down to 9

its lower power state. 10

However, DOE also noted that allowing a 11

test procedure

-- or a test period

-- of not less 12

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

result in

-- in different test technicians testing 14

the same product for different periods of times. So 15

for this reason, to ensure that the testing 16

procedure for standby and off mode is clear and 17

consistent, so that different test technicians are 18

using the same procedure s, DOE is proposing to 19

require a stabilization period of 30 to 40 minutes, 20

and a test period of ten minutes. 21

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

for the record. 23

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

is energy captured during the stabilizatio n time? I 25Executive Court Reporters (301) 565

- 0064 45 didn’t hear that part. 1

MR. BATTAGLIA: The actual measured 2

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

determined from that stabilization period. It’s 4

just

-- the product is allowed to stabilize for a 5

period and then you begin the measurem ent. 6

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

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

network mode is integrated with them. So maybe we 9

can come up with something so we can measure the 10

stabilization period. That 40 minutes of energy is 11

a lo t of energy. I mean millions of dryers are out 12

there, so they could cost a lot. 13

MR. BROOKMAN: In

-- the display function 14

consumes a bunch of energy. 15

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

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

will ta ke to stabilize the situation. 18

MR. BROOKMAN: Okay. Wayne Morris. 19

MR. MORRIS: Wayne Morris with AHAM. 20

Well, I think that

-- I’m not trying to totally 21

answer your questions, but just to give you some 22

indication. The purpose of the stabilization is t o 23

try and reach the steady state situation, to arrive 24

at what is truly that definition of standby in which 25Executive Court Reporters (301) 565

- 0064 46 it says that it will be going on for an extended 1

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

believe is the definition. 3

And so there are some products, I can use 4

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

but a clothes washer, for instance, that may 6

remember a cycle setting for some period of time at 7

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

the next set of clothes into the clo thes washer to 9

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

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

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

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

or initiate the cycle, and I remembe rs the cycle. 14

That amount of energy then is essentially included 15

in the overall active mode situation of the clothes 16

washer. Same thing would occur with a dryer. 17

So the problem comes that what happens if 18

at the end of the first cycle, nobody does a sec ond 19

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

depending on the individual manufacturer how long 21

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

down into that low level that is maintained. The 23

trouble is that each manufacturer is going to be a 24

differ ent length of time. Each one’s going to have 25Executive Court Reporters (301) 565

- 0064 47 different powering functions. Some step functions 1

downward, rather than

-- so where you take that 2

measurement could be very important and could lead 3

to inaccuracies if you measured it differently. 4

That’s wh y the IEC really deals with this 5

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

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

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

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

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

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

same way. If different ones power down at different 12

levels, we’ll never have an accurate measurement 13

unless we wait some length of time. 14

Are we going to be missing som e power in 15

that? Yes, probably we will. Is it

-- you know, 16

when we consider the entire year what that amount of 17

power level is for powering that board during that 18

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

talking about micromilli watt hours of ener gy, and 20

we’re talking about products that now this test 21

procedure reduces the number of cycles per year 22

significantly, to where the amount of time spent in 23

that transitional phase is going to be miniscule, 24

and that’s what the department has mentioned in he re 25Executive Court Reporters (301) 565

- 0064 48 as well. 1

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

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

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

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

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

so mething that maybe we can measure that significant 7

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

Every manufacturer has different products. Some of 9

them may just stay in very high stage. 10

MR. BROOKMAN: Please say your name again? 11

MR. OMAR: Farhad Omar, NIST. 12

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

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

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

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

30 minutes, it’s just as Wayne said, it’s allowi ng 17

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

a 30 minutes of time after every active mode cycle 19

in the

-- in our annual energy use for standby or 20

off mode. 21

MR. BROOKMAN: Wayne Morris. 22

MR. MORRIS: Wayne Morris with AHAM. I 23

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

this IEC 62301 dealt with this in terms of a note in 25Executive Court Reporters (301) 565

- 0064 49 Section 3.4 in the FDIS, it says, “Any transition 1

that occurs between modes, either through user 2

intervention or automatically, is not considered to 3

be a mode.” 4

No w, there were no comments on that 5

situation coming from anyone anywhere in the world, 6

and there are 123 countries that had input to the 7

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

but there have been no comments to that. 9

MR. BROOKMAN: Okay. Than k you. Final 10

comments on this subject before we move on? 11

MR. BATTAGLIA: Okay. Now regarding the 12

set up for standby and off mode testing for clothes 13

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

comments that the products should be configured in 15

the factory, or default settings prior to the start 16

of testing. Now DOE believes that provisions for 17

setting up the appliance for standby and off mode 18

testing should be specified in the test procedure, 19

however, setting up the appliance in accordance with 20

manufacturers’ instructions, or in the as shipped 21

factory or default settings would allow 22

manufacturers to ship appliances set in a low power 23

mode that consumers may switch out of during typical 24

standby or off mode use. 25Executive Court Reporters (301) 565

- 0064 50 So in order to provide a clear and 1

consistent testing method, DOE is proposing that the 2

appliance be set up in the settings that produce the 3

highest power consumption level, consistent with 4

that particular mode under test for standby and off

5

mode testing. 6

MR. BROOKMAN: Kevin, yes. 7

MR. MESSNER: Just a quick comment. 8

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

at the factory default settings, otherwise, I mean 10

each consumer

-- what a consumer does on a typical

- 11

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

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

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

picture or representation across the nation. And by 15

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

are the default settings. 17

So we would encourage you to t ake another 18

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

time, probably provide more in the written comments. 20

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

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

any follow on comments, James? 23

MR. BATTAGLIA: I mean I think the problem 24

lies in what would be

-- how we would specify in the 25Executive Court Reporters (301) 565

- 0064 51 test procedure what would be the typical standby or 1

off mode, and with all the different configurations 2

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

clear and consisten t method. 4

MR. BROOKMAN: And all these different 5

manufacturers would have different default settings? 6

MR. MESSNER: Well are you saying you 7

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

Or that you wouldn’t? 9

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

now to measure it in the highest

-- the settings 11

that produce the highest power. 12

MR. MESSNER: Right, which is

-- just 13

taking the most extreme example, which isn’t 14

representative at all. 15

MR. BROOKMAN: Kevin, at this point you 16

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

your written

-- 18

MR. MESSNER: Well, it should be the 19

default settings. 20

MR. BROOKMAN: Okay. 21

MR. MESSNER: I mean, that’s the most

-- 22

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

generally what folks are doing. 24

MR. BROOKMAN: In your experience that’s 25Executive Court Reporters (301) 565

- 0064 52 what consumers typically do? 1

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

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

settings or going to the most extreme, where 4

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

it t o the most extreme setting, you know, I’m going 6

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

to open the operating manual and set all the

-- go 8

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

100 percent of the time is probably an unrealistic 10

es timate. 11

MR. BROOKMAN: Yeah. Wayne Morris. 12

MR. MORRIS: Wayne Morris with AHAM. I 13

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

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

and repeatability in these test procedures. 16

Relevance being tha t you want to try and make sure 17

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

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

going to be measuring energy the way that the 20

consumer would see it. 21

Very important that we make sure that the 22

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

manufacturer dryer A and a different manufacturer 24

dryer B, that you’re testing them the same way. And 25Executive Court Reporters (301) 565

- 0064 53 if you don’t do that, if you are resetting the 1

functions inside to try and arbitrarily find 2

whatever the highest po wer setting is, that’s not 3

representative to try and compare machines across 4

this situation. 5

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

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

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

like microwave ovens and others that are under 9

consideration under the standby situation, is that 10

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

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

there is typically going to be the way that the 13

consumer is going to start ou t with that product, 14

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

a default kind of situation in which your studying 16

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

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

a condition that is comparable from one machine to 19

another across the range of all the manufacturers 20

and all the different models of clothes dryers that 21

there are. 22

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

technician that sets this up is going to be setting 24

it up a different way. Maybe some of them are going 25Executive Court Reporters (301) 565

- 0064 54 to turn five functions on, some are going to turn 1

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

the instru ction manual and say, well, that’s not 3

likely to occur, that would be something that a 4

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

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

not going to put that setting. 7

So then you get into differences of 8

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

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

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

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

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

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

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

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

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

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

methodology i s up to every test technician. 19

MR. BROOKMAN: Okay. Thank you. Anything 20

additional? Okay. Yes, please. Use the 21

microphone. Is it Kristin? 22

MS. TADDONIO: Chris Taddonio again from 23

Energy Star. Could you please comment on what the 24

difference is in energy consumption based on the 25Executive Court Reporters (301) 565

- 0064 55 lowest setting or the highest setting might be? Are 1

we talking about a large range? That would be 2

helpful, thank you. 3

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

-- 4

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

range between the lowest and highest. I assume it 6

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

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

have any data to base that on

. 9

MR. BROOKMAN: Okay. Additional comments? 10

Yes, Joanna. 11

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

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

attempting to address. If you use the default 14

settings, then manufacturers would have an incentive 15

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

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

concern is valid, so

-- there might be kind of 18

issues with using the defaults. 19

MR. BROOKMAN: The manufacturers would 20

also have an interest in having a fu nctional 21

appliance. 22

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

that there won’t be settings that consumers could 24

easily adjust. 25Executive Court Reporters (301) 565

- 0064 56 MR. BROOKMAN: Okay. Kevin. 1

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

say that

-- this is Kevin Messner. The other point 3

is if you want to incentivize manufacturers to send 4

in the higher setting so every consumer would take 5

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

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

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

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

energy use is a better way to proceed than shipping 10

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

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

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

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

lowest possible setting. 15

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

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

MR. MORRIS: Wayne Morris. Let me follow 18

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

other issue is, the inc entive to the manufacturer is 20

to have a satisfied consumer. If the consumer 21

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

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

pour through instruction manuals and so forth to 24

figure out how to turn display s on and how to get 25Executive Court Reporters (301) 565

- 0064 57 the unit into an operational mode, it’s going to be 1

one very upset consumer that is then going to call 2

the 1

- 800 line and probably not buy from that 3

manufacturer again. 4

So the incentive is for the

-- the most 5

important incentive is to have a satisfied consumer, 6

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

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

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

whole lot more incentive than any incentive to try 10

and get around a Dep artment of Energy rulemaking or 11

energy level. 12

So the incentive here is to make sure that 13

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

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

and plug it in, and have it functional almost 16

immediately, wi th a very little amount of consumer 17

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

functional state, and that is far more important 19

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

a manufacturer is going to find some arbitrary 21

extremely low level of energy state that requires 22

the consumer to have to go through gyrations to get 23

to a normal situation

-- that’s not going to happen. 24

MR. BROOKMAN: Additional comments? Okay. 25Executive Court Reporters (301) 565

- 0064 58 MR. BATTAGLIA: Now, switching over to 1

room air conditioners. For those added 2

specifications, DOE proposed in the NOPR to require 3

that the test room temperature be maintained at 74 4

plus or minus two degrees Fahrenheit, and that the 5

temperature control setting would be set to 79 6

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

DOE received a number of comments stating that the 8

proposed room temperature conditions would be a 9

testing burden. 10

Now, as part of the room air conditioner 11

standards preliminary analyses, DOE conducted some 12

standby and off mode testing on representati ve room 13

air conditioners, and during these tests, DOE 14

determined that the displays among units tested 15

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

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

providing the time delay or time remaining until 18

sta rt on the display. So DOE believes that the 19

ambient conditions that we proposed in the NOPR 20

would be relevant for only an off cycle mode. 21

So then since we’re not proposing to

-- so 22

if the test procedure is limited to measuring of a 23

single standby mode, then the proposed close 24

tolerance on the ambient temperature would not be 25Executive Court Reporters (301) 565

- 0064 59 required. So because DOE isn’t proposing in the 1

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

proposing

-- we’re revising our proposal to provide 3

more flexibility in the room tem perature conditions 4

by allowing standby and off mode testing in either a 5

test chamber used for the cooling performance test, 6

or in a separate test room that would meet the 7

temperature conditions specified in IEC 62301

. 8

Now, DOE also notes that the indoor 9

temperature conditions for the cooling performance 10

test and the cooling DOE test procedure would fall 11

within those temperature conditions specified by IEC 12

62301. 13

And here we’re requesting comments on this 14

proposed temperature range for standby and off m ode 15

power measurements for room air conditioners, and 16

also those test room conditions for clothes dryers 17

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

specifications. 19

MR. BROOKMAN: Kevin. 20

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

little

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

have clarified it. So the ambient temperature range 23

could either be the current DOE test procedure or 24

the IEC? 25Executive Court Reporters (301) 565

- 0064 60 MR. BATTAGLIA: Right, because the DOE 1

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

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

tolerance than what is in IEC 62301. 4

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

ambient temperature ranges would be

-- what you’re 6

proposing now would be what

-- so you wouldn’t have 7

to test the room air conditioner in a test chamber 8

at a certain ambient condition, and then have 9

another test chamber to retest standby, you could do 10

it all right there in the same? 11

MR. BATTAGLIA: Right. 12

MR. MESSNER: Okay. Good. 13

MR. BROOKMAN: Other comments? You can 14

see the comme nt box, there, the ambient temperature 15

range for standby mode and off mode power 16

measurements. Joanna. 17

MS. MAUER: Joanna Mauer, just a quick 18

question. Has DOE done any testing to see whether 19

there’s any significant difference in the power 20

measurements between the two temperature conditions? 21

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

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

temperature conditions. But from my experience, I 24

don’t think that it would affect the standby or off 25Executive Court Reporters (301) 565

- 0064 61 mode measurements sig nificantly. And that’s just a 1

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

at the standby at different temperatures. 3

MR. BROOKMAN: Okay? 4

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

conditioner test period, in the NOPR, DOE proposed 6

the same s tandby and off mode testing period that it 7

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

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

received comments that the standby and off mode test 10

procedures should specify a 30 minute stabilization 11

period a nd measurement period of not less than ten 12

minutes. 13

However, for room air conditioners, DOE 14

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

suggest that the stabilization period

-- 16

stabilization and measurement periods would produce 17

more representative or consistent measurements than 18

the time periods that we proposed in the NOPR. 19

Again, DOE noted that allowing a test 20

period of not less than

-- or at least a specified 21

amount of time as provided in the IEC 62301 might 22

result in different test technici ans using different 23

time periods, so for room air conditioners, to 24

provide a more clear and consistent approach, DOE is 25Executive Court Reporters (301) 565

- 0064 62 proposing to require a stabilization period of five 1

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

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

MR. BROOKMAN: Okay. 4

MR. BATTAGLIA: Now if there are no 5

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

for

-- 7

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

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

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

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

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

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

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

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

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

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

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

see you back here

-- we’ll resume at 10:45. 19

(Whereupon, the meeting was off the record for 20

an 18

- minute morning recess.) 21

MR. BROOKMAN: Let’s resume. 22

**STANDBY/OFF MODE: CA LCULATION OF ENERGY**  **USE,** 23

**MEASURES OF ENERGY C ONSUMPTION**  24

MR. BATTAGLIA: All right, so the next 25Executive Court Reporters (301) 565

- 0064 63 topic we’re going to discuss is the actual energy 1

use
-- is how the actua l energy use associated with 2

standby and off modes is calculated. 3

So starting with clothes dryers, the 4

active mode energy use is currently expressed in 5

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

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

DOE determined that it’s technically feasible to 8

incorporate standby and off mode energy use into the 9

overall metric as required by the EISA amendments to 10

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

and off mode energy consumption in terms of annu al 12

energy use apportioned on a per cycle basis, since 13

the current DOE test procedure measures the active 14

energy used during a drying cycle. 15

So, in the NOPR, DOE had proposed 16

estimates for the annual hours and approximate 17

annual energy use for all the di fferent clothes 18

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

you can see here, those values

-- the values here 20

are presented for the hours the annual energy use, 21

and also the typical wattage for each mode. 22

So DOE believes under the proposed standby 23

and off mode definitions that the allocation of 24

hours for inactive and off mode presented here are 25

appropriate, based on comments to the NOPR. So as a 26Executive Court Reporters (301) 565

- 0064 64 result, the NOPR has not changed DOE’s proposal for 1

the allocation of hours. 2

MR. BROOKMAN: Yes, Wayn e. 3

MR. MORRIS: James, could you just explain 4

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

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

“cycle finish ed ”? 7

MR. BATTAGLIA: So cycle finish ed mode 8

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

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

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

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

something like that. 13

MR. MORRIS: You might want to revise that 14

to like heat cycle finish ed

. 15

MR. BATT AGLIA: Okay. 16

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

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

order to reduce the wrinkling, but the heater turns 19

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

right? 21

MR. BATTAGLIA: No, actually it wou ld be 22

the end

-- if

-- you’re talking about like a cool 23

down period? 24

MR. MORRIS: Right. 25Executive Court Reporters (301) 565

- 0064 65 MR. BATTAGLIA: So it would be the end of 1

cycle

-- the dryer is signaling the clothes are 2

completely finished and you’re ready to take them 3

out. 4

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

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

maybe, or something on the display might tell you 7

that your clothes are ready or something. 8

MR. MORRIS: But this is saying that 429 9

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

. 10

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

-- I might be wrong on this

-- but I think we 12

proposed or estimated that a clothes dryer would 13

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

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

mode. 16

MR. MOR RIS: But that’s

-- how many cycles 17

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

MR. BATTAGLIA: 283. 19

MR. MORRIS: So this is twice

-- another 20

30 percent more hours? 21

MR. BATTAGLIA: Right. So maybe

-- 22

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

afterwards, y ou’re assuming? 24

MR. BATTAGLIA: I think that was the

-- 25Executive Court Reporters (301) 565

- 0064 66 MR. BROOKMAN: What would you suggest 1

would be an appropriate number of hours there? 2

Maybe you need to go back and

-- 3

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

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

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

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

MR. BROOKMAN: And active is 8

understandable, right? 9

MR. MORRIS: Right. 10

MR. BROOKMAN: As is delay start? 11

MR. MORRIS: And I w ould assume active in 12

this case includes both any time that the dryer is 13

accomplishing its main function. 14

MR. BATTAGLIA: Right. 15

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

cycle? 17

MR. BATTAGLIA: Right, so yes, tumbling 18

with forced air circulation, wi th or without cooling 19

-- with or without heating, sorry. 20

MR. MORRIS: And I understand delay start. 21

So what

-- what then is the cycle finish? 22

MR. BROOKMAN: Cycle finished is that when 23

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

MR. BATTAGLI A: No, it’s after the cool 25Executive Court Reporters (301) 565

- 0064 67 down, so it’s just telling you that the cycle, the 1

drying

-- your user selected cycle is complete. 2

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

would be that transitional mode

-- 4

MR. BATTAGLIA: Right. 5

MR. MORRIS : -- of 30 minutes. 6

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

had proposed that this was an actual standby mode, 8

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

earlier, we’re not proposing that cycle finish ed or 10

delay start mode would be considered under standby 11

mode. 12

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

that when you’re calculating, the cycle finished 14

mode would be 30 minutes times the number of cycles 15

per year. 16

MR. BATTAGLIA: I guess it would depend on 17

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

is showing you that the cycle is finished. 19

MR. BROOKMAN: Okay. 20

MR. MORRIS: Okay. I’ll pass. 21

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

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

you can respond to this? Wayne? 24

MR. MORRIS: Wayne Morris. I guess we 25Executive Court Reporters (301) 565

- 0064 68 would like to survey the manufacturers a little more 1

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

the opportunities are, I guess. Just intuitively, 3

though, if the cycle finish ed mode is the 4

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

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

of 30 minutes, then I don’t

-- maybe my math is 7

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

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

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

some differences in the different dryers and we need 11

-- and how long it spends

-- and so we need to 12

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

MR. BROOKMAN: Okay. It strikes me that 14

this is a heck of a lot of preci sion, because the 15

annual energy use is miniscule. Right? 16

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

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

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

difference between the 30 minute stabilization 20

period and the tim e that we’re assigning to the 21

cycle finish mode. In measuring standby power, the 22

measurement is not conducted at the termination of 23

an active mode, it is conducted independently, so 24

essentially you’re plugging the product in, and then 25Executive Court Reporters (301) 565

- 0064 69 you’re waiting for p ossibly for a display that may 1

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

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

When you actually run the dryer and complete a 4

cycle, there may be a time period that the 5

manufacturer keeps the display energ ized to say, 6

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

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

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

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

That was helpful. Yeah, Wayne. 11

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

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

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

run or
-- 15

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

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

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

that we came up with in the NOPR. 19

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

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

MS. MAUER: Joanna Mauer. I just

-- this 22

is maybe going back to something discussed earlier, 23

but just a cla rification on how delay start and 24

cycle finished are treated. So I understand that 25Executive Court Reporters (301) 565

- 0064 70 DOE is not proposing to separately

-- establish 1

these as separate modes that would have separate 2

power measurements, but are the hours allocated to 3

delay start and cycle fi nished included in standby 4

for the purposes of calculating the standby annual 5

energy use? 6

MR. BATTAGLIA: Yes, that’s correct. 7

MS. MAUER: Okay. Thank you. 8

MR. BROOKMAN: Okay. Additional comments? 9

We’re going to move on. 10

MR. BATTAGLIA: Okay, a nd this slide, 11

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

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

extra changes. So we refer to the presentation up 14

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

the mode definitions, DOE determin ed that delay 16

start and cycle finish modes for clothes dryers are 17

not standby modes according to the proposed 18

definitions, and these modes each represent a 19

negligible portion, which is point one percent or 20

less of the annual energy use, and so DOE determin ed 21

that it would be more appropriate, under a 22

simplified approach, to allocate the hours 23

associated with delay start and cycle finished modes 24

to the off and inactive. 25Executive Court Reporters (301) 565

- 0064 71 So because we’re not proposing to measure 1

delay start and cycle finish modes in the dry er test 2

procedure, DOE is proposing to maintain the estimate 3

of 8620 hours as the non

- active hours that would be 4

allocated to inactive and off mode. 5

Now, in the NOPR, DOE proposed to allocate 6

the number of hours for the combined off and 7

inactive modes en tirely to either off or standby 8

mode as appropriate if the product only has one of 9

these modes possible. And if the product has both 10

modes possible, we would distribute those hours 11

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

changing this proposa l from the NOPR for the 13

allocation of hours between inactive and off modes. 14

MR. BROOKMAN: Kevin. 15

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

trying to

-- the number of hours in a year? 17

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

MR. BATTAGLIA: Yeah. 19

MR. MORRIS: That’s where I’m

-- I can’t 20

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

8600 sounds pretty close. 22

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

hours per year. 24

MR. MORRIS: Is it 8760, so 8760 and 25Executive Court Reporters (301) 565

- 0064 72 you’re subtracting 140. 1

MR. BATTAGLIA: 140. 2

MR. MORRIS: Oh, okay, and all of

-- 3

MR. BATTAGLIA: All of those hours would 4

be allocated to inactive and off. 5

MR. MORRIS: Inactive and off. Inactive 6

is standby? Or

-- 7

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

standby mode that we’re proposing. 9

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

MR. BROOKMAN: Other comments? Okay. 11

MR. BATTAGLIA: All right. So, to 12

summarize, DOE is proposing to amend the clothes 13

dryer test procedure to calculate the dryer energy 14

use per cycle associated with the standby and off 15

modes, by first calculating the product of the 16

wattage and allocated hours for standby and off 17

mode, depending on which modes are possible, and 18

then summing the results, and then finally dividing 19

by 1000 to convert from watt hours to kilowatt hours 20

-- oh, I’m sorry

-- and finally dividing by 283 21

cycles per year to get a per cycle measurement. 22

So here we’re seeking comments on the 23

approach for determining total energy use for 24

standby and off mode for clothes dryers, including 25Executive Court Reporters (301) 565

- 0064 73 the a ccuracy and test burden. And we’re also 1

inviting comments and requesting data for the 2

estimates for the annual hours associated with each 3

mode, including the 140 hours specified by the 4

current test procedure for active mode. 5

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

set. 7

MR. BATTAGLIA: All right. So now for 8

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

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

spent in each of the different standby modes and off 11

modes for room air conditioners, so DOE es timated 12

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

relative magnitudes of the relative energy use in an 14

example of a representative 8000 BTU per hour and 9 15

EER unit that has all these modes. And these 16

proposed estimates from the NOPR are presente d here 17

in this table. 18

MS. LOWENBERGER: Amanda Lowenberger. One 19

thing that we noticed that we think is missing is 20

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

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

and we were wondering if that’s an intention 23

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

looked at. 25Executive Court Reporters (301) 565

- 0064 74 MR. BATTAGLIA: Sorry, there’s

-- 1

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

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

to your face. Try it again. 4

MS. LOWENBERGER: There are 705 fan only 5

hours that are considered active mode that are 6

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

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

intentional omission

. 9

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

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

estimates again. 12

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

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

the annual energy consumption calculations and the 15

cost estimates. 16

MR. BROOKMAN: And so we’ll all know

-- 17

where did y ou spot that? 18

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

MR. BROOKMAN: In the Federal Register 20

notice? 21

MS. LOWENBERGER: Yes. 22

MR. BROOKMAN: Okay. Thank you. 23

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

MR. BROOKMAN: Okay, thanks for that. 25Executive Court Reporters (301) 565

- 0064 75
James will check on that. 1

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

DOE determined that delay start and off cycle modes 3

are not standby modes according to the proposed 4

definitions for the SNOPR, so DOE is not proposing 5

to measure power consumption in these mo des for the 6

room air conditioners test procedure. And again, 7

there was a slight modification in the slide. So 8

for the reasons that we discussed for dryers, that 9

these modes each represent a negligible portion of 10

the annual energy use, so DOE determined t hat it 11

would be more appropriate under a simplified 12

approach to allocate the hours associated with delay 13

start and cycle finish modes to the off and inactive 14

modes. 15

So we’re proposing here to use the 16

estimate of 5115 hours as the non

- active hours that 17

wo uld be allocated to inactive and off modes for 18

room air conditioners. 19

Now, again, for units that incorporate 20

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

the hours be allocated equally and for a unit that 22

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

hours would be allocated to that mode as 24

appropriate. 25Executive Court Reporters (301) 565

- 0064 76 So again, to summarize for room air 1

conditioners, DOE is proposing to calculate the 2

annual energy use associated with standby and off 3

modes by calculating the product of the wattage and 4

allocate d hours for standby and off modes, depending 5

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

then dividing by 1000 to get to kilowatt hours. 7

So again, we’re seeking comment on 8

determining

-- the approach for determining the 9

total energy use for sta ndby and off modes for room 10

air conditioners, and also inviting comments and 11

requesting data on estimates for the annual hours 12

associated with each mode, including our estimates 13

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

here, but it’s 2190 hours tha t was presented in the 15

NOPR. 16

MR. BROOKMAN: Questions? Yes, please, 17

Christine

. 18

MS. TADDONIO: Is DOE

-- 19

MR. BROOKMAN: Christine, we want this on 20

the record. 21

MS. TADDONIO: Of course. 22

MR. BROOKMAN: Yes, thank you. 23

MS. TADDONIO: Is DOE planning to update 24

the hours, the assumptions, from 750 for active to 25Executive Court Reporters (301) 565

- 0064 77 something lower? 1

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

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

this time. 4

MR. BROOKMAN: Would you recommend tha t 5

they consider changing the number of hours? 6

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

that an updated residential energy use consumption 8

surveys, the numbers of active operating hours had 9

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

head, I th ink that was the 1995 survey, which I 11

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

but you would know better than I would. 13

MR. BROOKMAN: Okay, thanks for that. 14

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

explanation for why we’re keeping the 750 hou rs 16

later in the presentation. 17

MR. BROOKMAN: Okay. You see the comment 18

box there. Questions? Comments related to that 19

query? Okay. 20

MR. BATTAGLIA: Okay. And the last topic 21

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

proposed measures for e nergy consumption that 23

incorporate these energy consumptions. So in the 24

NOPR, DOE had proposed combined metrics addressing 25Executive Court Reporters (301) 565

- 0064 78 all the active modes, standby and off modes for both 1

clothes dryers and room air conditioners. And for 2

clothes dryers, DOE propos ed a per cycle integrated 3

total energy consumption expressed in kilowatt 4

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

and off mode energy and either the total per cycle 6

electric or gas dryer energy consumption. 7

And DOE also proposed an integrated energy 8

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

dryer test load divided by the per cycle integrated 10

total energy in kilowatt hours. 11

Now, for room air conditioners, DOE 12

proposed an integrated energy consumption which was 13

the sum of the annual ener gy consumption and the 14

standby and off mode energy consumption. And DOE 15

proposed an integrated energy ratio, defined as the 16

cooling capacity and BTU per hour times the 750 17

average hours in cooling mode divided by the 18

integrated energy consumption times 100 0 to get to 19

kilowatt hours. 20

So this proposal for the integrated 21

metrics for each product from the NOPR hasn’t 22

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

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

have for this section, before we move on to acti ve 25Executive Court Reporters (301) 565

- 0064 79 mode. 1

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

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

clarification of

-- it’s just a summary statement 4

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

comments here before we move on? Okay. 6

**ACTIVE MODE: DRY**  **ER AUTOMATIC CYCLE T ERMINATION**  7

MR. BATTAGLIA: Now, switching over a bit 8

to the topics that are related to active mode for 9

both products, and started with the automatic cycle 10

termination for dryers. In the October 2007 11

framework document for the drye r, energy 12

conservation standards rulemaking, DOE stated that 13

the clothes dryers test procedure may not adequately 14

measure the benefits of automatic cycle termination, 15

which is when

-- in which a sensor monitors either 16

the exhaust air temperature or moistur e in the drum 17

to determine the length of the drying cycle. 18

Currently the DOE test procedure provides 19

a single credit for the enhanced performance of 20

clothes dryers equipped with automatic cycle 21

termination, defined in terms of a field use scaling 22

factor which is applied to the per cycle drying 23

energy consumption. So for gas and electric clothes 24

dryers with time termination control, which is to 25Executive Court Reporters (301) 565

- 0064 80 say those dryers that are equipped with only a timer 1

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

a fiel d use factor of 1.18, whereas dryers, 3

automatic termination control dryers are assi gned a 4

field use factor of 1.04. So these automatic 5

termination control dryers would receive a 12 6

percent credit, as compared to a comparable dryer 7

with time termination co ntrol. 8

So the DOE test procedure does not 9

distinguish between the type of sensing technology 10

for automatic termination controls, for example, if 11

it uses temperature sensing or moisture sensing 12

controls, and the sophistication or accuracy of that 13

control system. 14

MR. BROOKMAN: Wayne Morris. 15

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

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

you referring to a dryer there that has no automatic 18

termination whatsoever in the dryer? 19

MR. BATTAGLIA: No, it would s till have

-- 20

it could still have a temperature sensor that would 21

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

any dryers on the market that just have time 23

termination control. So even with like an 24

electromechanical control, you could still use like 25Executive Court Reporters (301) 565

- 0064 81

a temperature cutoff to shorten the drying cycle. 1

MR. MORRIS: Okay, so

-- I’m having 2

trouble with understanding the calculation of these 3

factors. So the field use scaling factor is used 4

then and applied to the per cycle drying energy 5

consumption. If a dryer has both a timer function 6

and a automatic termination function, then

-- how 7

does the Department or the manufacturer calculate 8

the energy consumption? 9

MR. BATTAGLIA: I believe right now it 10

would just receive the credit for automatic 11

termination. 12

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

here. 14

MR. BROOKMAN: Phil Manthei. 15

MR. MANTHEI: Phil Manthei, Appliance 16

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

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

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

electromechanical timer. We don’t have any 20

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

the automatic termination cycle, which you use 22

during the test cycle for the minimum standard, you 23

get the credit. 24

MR. MESSNER: You get the credit versus 25Executive Court Reporters (301) 565

- 0064 82 what? Versus a dryer that

-- I’m sorry this is 1

Kevin Messner. 2

MR. MANTHEI: I suppose if there was a 3

clothes dryers on the market that had only timed 4

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

PARTICIPANT: You’d use the 1.9. 6

MR. M ORRIS: But then

-- this is Wayne 7

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

are no such dryers that have timed termination only. 9

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

aware, that’s correct. 11

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

timer FU fact or ever come into play? 13

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

but we’re not prohibiting dryers with just timer 15

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

did

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

out, it would get that 1.18 field use f actor. 18

MR. MORRIS: Okay, so

-- I get it now, 19

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

Sorry. 21

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

- 22

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

on this. Okay. 24

MR. BATTAGLIA: Okay. So DOE investi gated 25Executive Court Reporters (301) 565

- 0064 83 other clothes dryers test standards from industry 1

and also internationally for measuring the 2

effectiveness of automatic cycle termination for 3

clothes dryers. Now, DOE noted that AHAM recently 4

published an update to its industry test standard, 5

which is AHAM HLD

- 1

- 2009, which contains provisions 6

for measuring the overdrying energy consumption for 7

automatic termination dryers. And DOE also noted 8

that the European standard EN 61121 and the 9

Australia

- New Zealand standard 2442 also provide 10

methods for tes ting automatic termination control 11

dryers. 12

So DOE first reviewed both AHAM HLD

- 1

- 2009 13

and EN standard 61121 and determined that these 14

standards did not provide an appropriate method for 15

comparing the energy consumption of overdrying for a 16

timer dryer to that of an automatic termination 17

sensored dryer. Now next, DOE reviewed the 18

Australia

- New Zealand standard and we believe that 19

it provides testing methods and procedures which 20

account for the amount of overdrying associated with 21

automatic termination con trol dryers beyond a 22

specified RMC, and it effectively takes into 23

consideration the accuracy of different sensor 24

technologies. And DOE also believes the testing 25Executive Court Reporters (301) 565

- 0064 84 methods provide an accurate and representative 1

method for comparing the energy consumption bet ween 2

the two types of dryers. 3

So for these reasons, DOE proposed

-- is 4

proposing to amend the DOE test procedure for dryers 5

to incorporate individual test procedures for timer 6

dryers and automatic termination control dryers 7

based on the provisions in the Australia

- New Zealand 8

standard 2442 with modifications as appropriate for 9

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

of those changes in the next few slides. 11

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

a moment. Yes, please. Wayne. 13

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

clarification purposes, though, I’m wondering if 15

that definition of timer dryer doesn’t need to 16

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

automatic termination function. 18

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

in a minute. 20

MR. MORRIS: Okay. Sorry. 21

MR. BROOKMAN: Other comments? Okay, 22

let’s keep going. 23

MR. BATTAGLIA: Okay, so based on the 24

provisions in the Australia

- New Zealand standard, 25Executive Court Reporters (301) 565

- 0064 85 DOE is proposing to define a timer dryer as a dryer 1

which can be preset to carry out at least one 2

sequence of operations to be terminated by a timer, 3

but may also be manually controlled. And DOE is 4

proposing to define automatic termination control 5

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

least one sequence of operations to be terminated by 7

means of a system assessing, directly or indirectly, 8

the moisture content of the load, with an additional 9

note that the automatic

-- an automatic termination 10

control dryer with a supplementary timer shall be 11

tested as an a utomatic termination control dryer. 12

MR. MORRIS: This is Wayne. Now my 13

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

it be appropriate to have something in the timer 15

dryer definition that says “but does not include any 16

automatic termination func tion”? I mean so that 17

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

reading this, especially somebody maybe that isn’t 19

as skilled in understanding our test procedures, 20

fixes on almost any automatic termination dryer is 21

going to also have a timer dryer f unction, because 22

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

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

on there. I think just we ought to consider putting 25Executive Court Reporters (301) 565

- 0064 86 something in there to add to that definition to 1

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

MR. MESSNER: I assume that the last 3

sentence that you have on the automatic termination 4

should be modified and placed

-- I mean clarified 5

and automatic termination, you should clarify it in 6

the timer. 7

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

suggest in your written comments the actual language 9

on that

-- 10

MR. BROOKMAN: That last comment from 11

Kevin. Thank you. Yes, please. 12

MS. WALTNER: Meg Waltner from NRDC. Just 13

a point of clarification. So if something is 14

designated as an aut omatic termination control 15

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

timed modes? 17

MR. BATTAGLIA: That would be correct, 18

yes. 19

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

having looked into this further, that you maybe 21

would want to test both t ypes of dry modes, because 22

it seems that most new dryers have both types of 23

modes, and that would effect that. 24

MR. BROOKMAN: Thank you. 25Executive Court Reporters (301) 565

- 0064 87 MR. BATTAGLIA: And if you have any data 1

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

or the energy between those two

-- 3

MR. BROOKMAN: Among those two loads? 4

MR. BATTAGLIA: If you tested as the timer 5

or
-- both timer and automatic termination control 6

dryers, that would be helpful. 7

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

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

further information on that in comments. 10

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

MR. MESSNER: I have one. 12

MR. BROOKMAN: Yes, Kevin. 13

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

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

overall, on this whole automatic termination test 16

procedure, is there

-- I’m having trouble

-- what is 17

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

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

components, but is there actual test procedure 20

written somewhere in the SNOPR that actually says 21

here it is, that I didn’t catch? 22

MR. BATTAGLIA: Yes, so it’s in the 23

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

- 24

MR. MESSNER: After all the definitions 25Executive Court Reporters (301) 565

- 0064 88 and everything? 1

MR. BATTAGLIA: It should have the entire 2

proposed test procedure in there. 3

MR. MESSNER: Okay. 4

MR. BATTAGLIA: So it lays out the 5

procedures for timer and automatic termination 6

control dryer s. 7

MR. MESSNER: All right. Thank you. 8

MR. BROOKMAN: Wayne. 9

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

read through the pages in the SNOPR that deal with 11

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

the

-- within the SNOPR, and our manufacturers are 13

having a very difficult time actually following that 14

to actually create a test in a test laborat ory. I 15

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

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

written in a way that a laboratory

-- you could hand 18

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

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

functions from the IEC and from the Australia

- New 21

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

amalgam of testing situations that’s making it 23

extremely difficult. 24

Our comment will be in our written 25Executive Court Reporters (301) 565

- 0064 89 comments as well, which is this needs to b e taken 1

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

other places that are actually doing testing and try 3

to simulate this in the Department’s laboratory. 4

MR. BROOKMAN: So can you be specific? 5

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

-- 6

tha t is more of an applied sort of

-- yes? 7

MR. MORRIS: Yes. 8

MR. BROOKMAN: Okay. I’m just 9

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

Okay. Other comments on this? 11

MR. BATTAGLIA: Okay. So for the test 12

load preparation, with regard to those sections in 13

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

requirements that the moisture content for the test 15

load for dampening and extracting water from the 16

test load would first be between 42 and 47 percent 17

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

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

the DOE test procedure. 20

This step would serve as initial 21

preparation step prior to the next requirement, 22

which would require that making final mass 23

adjustments so that the moisture content is 47 24

percent, plus or minus .33 percent, by adding water 25Executive Court Reporters (301) 565

- 0064 90 uniformly to the load in a very fine spray. And 1

this range was proposed based on the allowable range 2

specified in the Australia

- New Zealand standard, 3

which specifies 190 percent, plus or minus .02 4

kilograms of the bone dry weight. 5

Now DOE believes that these proposed 6

amendments would improve the repeatability and help 7

reduce the variation from test to test, and would 8

also allow for a more representative comparison 9

between timer and automatic term ination control 10

dryers. 11

MR. BROOKMAN: Okay. Go ahead. 12

MR. BATTAGLIA: Now DOE also notes that 13

Section 2.7 of the existing dryer test procedure 14

regarding test load preparation, requires that the 15

test load be agitated in water whose temperature is 16

100 degrees, plus or minus five degrees Fahrenheit. 17

Now DOE recognizes that some residential clothes 18

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

the wash cycle, which the current DOE washer test 20

procedure specifies 60 degrees, however DOE does not 21

have any data whether

-- indicating whether a 22

different water temperature for the clothes dryers 23

test load preparation would be more representative 24

of consumer usage habits. 25Executive Court Reporters (301) 565

- 0064 91 So for this reason we’re not proposing any 1

changes to the water temperature for th e clothes 2

dryers test preparation at this time. However, if 3

consumer usage data is made available that indicates 4

a 60 degree water temperature is more representative 5

of consumer usage, DOE may adopt an alternate 6

approach, specifying 60 degrees for this. 7

MR. BROOKMAN: Wayne

-- pardon me, Phil. 8

MR. MANTHEI: Phil Manthei, Alliance 9

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

that the loads going into the dryer are cooler than 11

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

you’d have to try to understand what adjustment 13

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

using more energy because the load is cooler than it 15

would be at 100 degrees. 16

MR. BATTAGLIA: Yes, so that’s another

-- 17

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

that because we’re not aware of

-- or we don’t have 19

data at this time showing the changes on measured 20

efficiency, as compared to the existing test 21

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

on this water temperature, and whether it should be 23

changed b ased on what would be representative of 24

consumer usage habits. 25Executive Court Reporters (301) 565

- 0064 92 MR. BROOKMAN: Just to see if there are 1

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

is Page 54. 3

MR. WAGLEY: I

-- this is Subid Wagley, 4

DOE. We would update these slides before w e post 5

them on line after this. 6

MR. BROOKMAN: Yes. 7

MR. WAGLEY: We made some last minute 8

changes before it went to the print. 9

MR. BROOKMAN: Okay, thank you. No 10

comments? Okay. 11

MR. BATTAGLIA: All right. So DOE also 12

proposes to amend Section 3 .3 of the DOE test 13

procedure regarding the test cycle to include 14

testing procedures specific to each type of dryer, 15

and these amendments are based on the provisions in 16

the Australia

- New Zealand standard. 17

So for timer dryers, DOE is proposing that 18

the clo thes dryer would be operated at the maximum 19

temperature setting, and if equipped with a timer, 20

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

dried to five to six percent RMC without the dryer 22

advancing into any cool down period, and resetting 23

the ti mer as necessary. And then the test procedure 24

would be repeated until the RMC of the test load is 25Executive Court Reporters (301) 565

- 0064 93 four to five percent. 1

Now for the test cycle for automatic 2

termination control dryers, DOE is proposing that a 3

normal cycle be selected for the test cycle to be 4

most representative of consumer usage. Now, in 5

addition, where the drying temperature can be chosen 6

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

maximum. And DOE is also proposing that when the 8

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

the drying cycle, which is to say that immediately 10

before the cool down period begins, the dryer shall 11

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

five percent, the test would be considered invalid 13

and a new run would be conducted using the hi ghest 14

drying level setting. And any test cycle in which 15

the final RMC is five percent or less would be 16

considered valid. 17

And lastly, DOE is also proposing that for 18

automatic termination control dryer s, the cycle 19

setting selected shall be recorded for the test. 20

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

your name the first time through. 22

MS. DETRICK: Paige Detrick. 23

MR. BROOKMAN: Paige, thank you. 24

MS. DETRICK: Paige Detrick, BSH. We have 25Executive Court Reporters (301) 565

- 0064 94 honestly great concern with the word “normal 1

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

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

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

“normal,” and everyone will have different feelings 5

which is normal, and therefore test to test 6

reproducibility, test lab to test lab 7

reproducibility becomes very dangerous. 8

MR. BROOKMAN: What would you suggest as a 9

substitute or alteration? Or elimination? What is 10

the remedy here? 11

MS. DETRICK: I think, honestly, we 12

probably need to talk to the community and bring 13

back a written comments proposal. 14

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

MR. MORRIS: Yes, I would concur with 16

Paige. I think we’ve successfully now transitioned 17

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

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

think that

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

this, especially

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

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

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

this is the normal cycle . So to try and

-- we’ve 24

transitioned in clothes washers to naming the type 25Executive Court Reporters (301) 565

- 0064 95 of fabric, for instance, maybe there’s another way 1

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

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

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

particular cycle that we could use that’s 5

representative of at least the largest majority of 6

consumer usage. 7

We also might suggest that the Department 8

contact some of the manufacturers of dryer

-- what 9

would you call them, dryer usage materials that are 10

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

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

survey data from consumers as to what the usage 13

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

common usage program is. Som ething that is 15

relatively widespread among the dryer community that 16

we could use and get away from this terminology of 17

normal. Thanks. 18

MR. BROOKMAN: Thank you. Meg? 19

MS. WALTNER: Meg Waltner from NRDC. I 20

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

despite the issues with the normal setting 22

definition, why you chose normal instead of sort of 23

the maximum dry setting where you use the maximum 24

time in the timed dry. 25Executive Court Reporters (301) 565

- 0064 96 MR. BATTAGLIA: We chose the normal 1

setting based on the dryers. We conducted o ur own 2

testing of the dryers that we had used the normal 3

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

because it would overdry the test load to near bone

5

dry, so it wasn’t really reflective of trying to 6

achieve an RMC of five, like five percent whi ch we 7

assume would be what a typical consumer would use. 8

So I think the highest dryness level setting is 9

geared towards achieving a bone dry state for the 10

clothes. 11

MS. WALTNER: No follow up comment at this 12

time. 13

MR. BROOKMAN: Okay. Thank you. Kevin

. 14

MR. MESSNER: Well, so the test procedure 15

is supposed to be representative of use across the 16

nation. Not necessarily what the peak is, just 17

representative of what it is. So

-- and that’s

-- 18

you use the highest setting for everything that’s

-- 19

you’re s aying is representative of the highest load, 20

so maybe that’s where

-- 21

MR. BROOKMAN: Okay? Other? 22

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

there is at least two ways to terminate the drying 24

cycle during the drying test, and first would be 25Executive Court Reporters (301) 565

- 0064 97 terminatio n before the cool down period, and second, 1

termination at the end of the selected test cycle, 2

which would include the cool down period. So DOE 3

notes that the Australia

- New Zealand standard 2442 4

and the AHAM standard both terminate before the cool 5

down per iod, and the EN standard 61121 specifies 6

that the cycle be run until completion, which would 7

include the cool down period. 8

And as we discussed, DOE is proposing for 9

the SNOPR that the test cycle for automatic 10

termination control dryers would not includ e the 11

cool down phase, and these proposed amendments are 12

based on the Australia

- New Zealand standard, because 13

it provides a more representative comparison between 14

the energy consumption between automatic termination 15

control dryers and timer dryers than did EN 61121, 16

and in addition, the proposed amendments would 17

harmonize with the international standard and also 18

with the industry standard. 19

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

go ahead. 21

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

advocate of running th e whole cycle through the cool 23

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

all, the technician has to guess when to try and 25Executive Court Reporters (301) 565

- 0064 98 pull the load to measure, and so if you take that 1

away, that simplifies the test procedure. 2

MR. BROOKMAN: Paige. 3

MS. DET RICK: Paige, BSH. The BSH opinion 4

is also that including the cool down is advantageous 5

for both repeatability of the test and simplicity of 6

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

a possibility to make better use of the consumed 8

energy by us ing that cool down period to continue to 9

reach the actual target RMC. 10

MR. BROOKMAN: Okay. Thank you. 11

MR. BATTAGLIA: And then that basically 12

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

we’re considering the alternate method in EN 61121 14

to inclu de the cool down period, noting that, like 15

Paige said, it could provide the potential for more 16

efficient controls. 17

MR. BROOKMAN: Okay. 18

MR. BATTAGLIA: So here we’re welcoming 19

comments on whether the cool down period

-- or 20

further comments, I guess

-- on whether the cool 21

down period should be included for automatic 22

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

welcoming data quantifying how including the cool 24

down period in the test cycle would affect the 25Executive Court Reporters (301) 565

- 0064 99 measured efficiency of clothes dryers as co mpared to 1

the existing test procedure, per that EPCA 2

requirement, and in particular for units that are 3

minimally compliant with the current energy 4

conservation standards. 5

MR. BROOKMAN: Yes, Joanna. 6

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

that the c ool down period should be included. I 8

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

we’d encourage all engineering options to be 10

available. 11

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

helpful. Yes. Wayne. 13

MR. MORRIS: Wayne Morris. Just a 14

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

do all of your calculations of hours need to be 16

reset? 17

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

that right now. 19

MR. BROOKMAN: Explain your logic to us. 20

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

the number of cycle hours per year that we just 22

covered back in

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

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

were spent in this, I believe it was 140 hours, is 25Executive Court Reporters (301) 565

- 0064 100 that right? It’s on slide 38. So if now you 1

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

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

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

Sort of just makes sense. 5

MR. BATTAGLIA: Okay, and if you have 6

data, I guess like typical

-- how long the cool down 7

peri od would be, or anything that would be helpful, 8

or if you have a suggested number. 9

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

be a little difficult because there may be 11

differences in dryers, significant differences in 12

dryers in terms of the amount of t ime spent in cool 13

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

number of hours

-- because this becomes pretty 15

critical. I mean whatever hours

-- therefore in 16

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

you’re adjustments have got to be ma de in order to 18

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

-- I mean I’m

-- cool down modes have been around 20

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

Department elected, even in the original test 22

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

a simple situation that it’s pretty difficult to 24

find an exact number that represents the amount of 25Executive Court Reporters (301) 565

- 0064 101 time spent in there. At one time it was probably 1

less important. Now it becomes critically important 2

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

hours spent in this, then become a larger percentage 4

of the whole. 5

MR. BROOKMAN: Okay. Thank you. Other 6

comments? Okay. 7

MR. BATTAGLIA: Now, regarding Section 4 8

of the DOE test procedure , which is concerned with 9

the calculation of derived results from the test 10

measurements, DOE is proposing for timer dryers, 11

using the results from the proposed test cycle, 12

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

final RMC tests to interpolate the value of the per 14

cycle energy consumption required to dry the test 15

load to exactly five percent RMC. And then you 16

would be placing that 1.18 field use factor on

-- to 17

add overdrying energy consumption. 18

DOE isn’t aware of any data that would 19

suggest that the 1.18 field use factor for timer 20

dryers is inac curate and not currently 21

representative of consumer usage, and so DOE is not 22

proposing to change this value at this time. 23

However, we recognize that the field use factor was 24

set in 1981 when the dryer test procedure was first 25Executive Court Reporters (301) 565

- 0064 102 established, and it could not be

-- it may not be 1

representative of current consumer usage patterns. 2

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

suggesting whether this value would be appropriate. 4

MR. BROOKMAN: I guess the manufacturers 5

are not ready to comment on that one? Ok ay. 6

MS. PINTO: Excuse me, Doug? 7

MR. BROOKMAN: Yes, please. Francine. 8

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

last comment, you’re name is Wayne? 10

MR. MORRIS: Yes. 11

MS. PINTO: That Wayne made about the 12

hours, I’m wondering what other stakehold ers think. 13

Because you mentioned that you thought we should 14

measure the cool down, and whether we link up with 15

the proper number of hours is something we have to 16

look into, but if we can’t, what do you all think? 17

MS. MAUER: Joanna Mauer. I would 18

actua lly say that I think it would be very helpful 19

if AHAM had any data, not specifically on the cool 20

down hours, but on the total cycle hours because I 21

don’t

-- I’m not sure that the 140 hours has been 22

updated or is based actually on cycle hours. So if 23

we had some estimate of the length of a total cycle 24

on average, and now we have a new value for cycles 25Executive Court Reporters (301) 565

- 0064 103 per year, we could

-- I think DOE could figure out 1

whether that 140 hours should be adjusted or not. 2

So I guess I would say, to me the more important 3

question is the total cycle length as opposed to the 4

cool down time. 5

MR. BROOKMAN: Wayne Morris. 6

MR. MORRIS: It’s a very valid point, both 7

of you. Some of this also depends very much on what 8

is the initial RMC that we’re going to use. Because 9

if we’re usin g 70 or 72 percent or something in that 10

range for an initial RMC, then it takes longer to 11

get that normal load to actual automatic 12

termination, than if we’re starting at 47 percent, 13

for instance. And if we’re going to use that, we 14

may end up at the same p lace. In other words, by 15

reducing the RMC, then down to 47, and looking at 16

including a cool down, you may actually end up 17

equaling out at 140 hours, or roughly, let’s say 30 18

minutes or something like that, per cycle, now that 19

we’ve reduced the number of c ycles. 20

So I think that at some point we may be 21

going through a fairly extensive exercise just to 22

get back to the number that we actually have. But 23

your point is well taken, and we’ll ask the 24

manufacturers if we can look at some average amount 25Executive Court Reporters (301) 565

- 0064 104 here, or whether that would be appropriate even, to 1

look at, and we’ll try to cover that in our written 2

comments. 3

MR. BROOKMAN: Judy Reich. 4

MS. REICH: Yes, I just also wanted to add 5

to that, for the NOPR, that Whirlpool had supplied 6

estimates of

-- verifying the 140 hours and that 7

corresponded to 20 minutes per cycle, which I 8

assume, based on that timeframe, is only looking at 9

the original definition of active mode and did not 10

include any cool down period. 11

MR. BROOKMAN: Okay. Thank you. Data. 12

Okay. So any additional comments on this? 13

MR. BATTAGLIA: Now, in the calculation of 14

results for automatic termination control dryer s, 15

DOE is proposing to revise the field use factor 16

credits to more appropriately account for the 17

automatic termination control drye r overdrying 18

energy consumption. So automatic termination 19

control dryers would receive a field use factor of 20

one, instead of the 1.04 currently provided, and any 21

overdrying energy consumption measured during the 22

test cycle would be added to the drying ene rgy 23

consumption, to basically decrement that energy 24

factor. 25Executive Court Reporters (301) 565

- 0064 105 Based on these test methods an automatic 1

termination control dryer that is able to dry the 2

test load to exactly five percent RMC, and thus 3

eliminate overdrying, would result in a higher 4

measured efficiency than if it overdried to an RMC 5

less than five percent. And I think that’s a slight 6

modification to this slide that you have in your 7

packet. 8

MR. BROOKMAN: So up here this may be

-- 9

can you point to what’s different? 10

MR. BATTAGLIA: Right , so it’s just that 11

we’re

-- that last

-- that second bullet on the

-- 12

the second sub

- bullet to the first main bullet is 13

slightly different wording. 14

MR. BROOKMAN: Okay. Kevin. 15

MR. MESSNER: Yeah, I’m just still

-- I’m 16

not steeped in the details of th e test procedure, so 17

maybe that’s why I’m missing something. Could you 18

try to explain it again. 19

MR. BATTAGLIA: Right, so if you dried

-- 20

if your automatic termination control setting dried 21

to exactly five percent RMC, you’d have a higher 22

efficiency tha n a dryer that overdries it to lower 23

than five percent. 24

MR. MESSNER: Got that, but then so that 25Executive Court Reporters (301) 565

- 0064 106 is your

-- how does that

-- I guess I’m getting 1

lost. How does that factor into the calculation? 2

MR. BATTAGLIA: So when you run the test, 3

you allow it to run until completion. 4

MR. MESSNER: So you don’t have to check 5

and run it again? 6

MR. BATTAGLIA: Right. 7

MR. MESSNER: All right. 8

MR. BROOKMAN: Wayne Morris. 9

MR. MORRIS: Wayne Morris with AHAM. 10

Maybe I’m missing something here but my slide and 11

your slide look like they’re identical and I got 12

this off the internet this morning. 13

MR. BATTAGLIA: Okay, maybe it’s been 14

updated since, but

-- okay. 15

MR. MORRIS: So I just want to make sure 16

I’m dealing with the same

-- 17

MR. BATTAGLIA: Sorry, I thought that was. 18

MR. MORRIS: Okay. 19

MR. BROOKMAN: That’s it? Yeah. Hang on, 20

just a second. Yes. Paige. 21

MS. DETRICK: Yes, just a comment on maybe 22

specifically the word “exactly five percent” but 23

also in hearing that exactly, if the procedure is 24

written as I see it, that anything greater than five 25Executive Court Reporters (301) 565

- 0064 107 percent is an invalid test, then it must target ever 1

so slightly dryer than five percent because, just 2

like any other method measurement in the world, you 3

will not be exactly every time. I’ve not going to 4

get five

-- 5

PARTICIPANT: Five or less. 6

MR. BROOKMAN: Right. Okay. Other 7

comments on this slide here? 8

MR. BATTAGLIA: Oh, and there’s just one 9

last

-- second part of that slide. We’re 10

considering the requirement to look at the effects 11

on the measured efficiency, DOE estimated, based on 12

limited testing, that a baseline dryer would 13

possibly overdry the test load to below five percent 14

such that the energy consumption measured efficiency 15

would be equivalent to that measured by the existing 16

DOE tes t procedure. So we’re not proposing any 17

changes to the current energy conservation standards 18

at this time. 19

And here we’re inviting comments on the 20

adequacy of Australia

- New Zealand standard 2442, 21

along with the proposed definitions and 22

clarifications to measure energy consumption for a 23

timer and automatic termination control clothes 24

dryers to account for overdrying energy consumption. 25Executive Court Reporters (301) 565

- 0064 108 Maybe we’ll stop at that one first. 1

MR. BROOKMAN: James, were you 2

anticipating comments here? Did we cover this? 3

MR. BATTAGLIA: Well, I guess we can read 4

through the whole thing, then. 5

MR. BROOKMAN: Yes. 6

MR. BATTAGLIA: Next, DOE is inviting 7

comment on whether the proposed field use factor 8

credits for automatic termination control dryers, 9

along with the revise d calculations for the per 10

cycle energy consumption are appropriate. Also 11

requesting comment on whether final RMC of five 12

percent is appropriate, and if not, what would be a 13

representative value. And also welcoming data from 14

dryers tested according to th is procedure, and 15

particularly for units that are minimally compliant 16

with current energy conservation standards, as well 17

as data showing whether one sensor technology is 18

more accurate and reduces overdrying than another. 19

MR. BROOKMAN: You can see the c omment 20

boxes. Please take a peek at them. So this takes 21

you through issue nine. Let’s proceed to the next 22

slide and see if there are any comments there. 23

MR. BATTAGLIA: Okay, and for this we’re 24

also inviting comment on whether the maximum 25Executive Court Reporters (301) 565

- 0064 109 temperature setting for timer dryers is 1

representative of consumer usage habits, and we’re 2

inviting comments on whether the proposed cycles and 3

settings for the automatic termination control dryer 4

tests are representative of current consumer usage, 5

habits and requesti ng comments on whether multiple 6

cycles and settings should be tested and how results 7

from those tests of multiple cycles should be 8

evaluated. And if so, how testing multiple cycles

- 9

- cycles and settings will affect the measured 10

efficiency as compared to the existing DOE test 11

procedure. 12

MR. BROOKMAN: No comments? Okay. 13

MR. BATTAGLIA: Okay, and I think the 14

agenda says lunch here. 15

MR. BROOKMAN: Guess so. I think we’re 16

just perfect almost. It’s lunch time, and this is 17

really well planned. We’re m aking really good 18

progress. This material is rather dense. Get some 19

protein with your lunch. Balance the carbs and the 20

proteins. 21

MS. SULLIVAN: How long we going? 22

MR. BROOKMAN: We will

-- how long today? 23

MS. SULLIVAN: Yes. 24

MR. BROOKMAN: Wel l, so far we’re on 25Executive Court Reporters (301) 565

- 0064 110 schedule, and the way they’ve timed it so far, they 1

anticipate we’ll go until three o’clock. 2

This room will be locked, so you can leave 3

your stuff here. It’s now five ‘til 12, let’s 4

resume at one o’clock, here in this room. And thank 5

you for a good day

-- a good start on the day I 6

should say. Please wear your badges in the 7

building, otherwise someone might escort you to a 8

locked room. Everybody knows where the cafeteria 9

is, right? 10

So thanks for a good start to the day, 11

we’ll res ume at one. At one. 12

(Whereupon, at 11:55 a .m., the meet ing in 13

the above captioned matter was adjourned for lunch 14

recess , to reconvene at 1:00 p .m.) 15

16

17

18

19

20

21

22

23

24

25Executive Court Reporters (301) 565

- 0064 111 1

A F T E R N O O N S E S S I O N 2

1:08 p.m. 3

MR. BROOKMAN: We're going to pick up 4

where we left off. And we're back with James. 5

**Active Mode: Vent**

**- less Dryers, Detergent**  6

Specifications for Dryer Test Cloth Preconditioning 7

MR. BATTAGLIA: All right. So, the first 8

topic which we are going to discuss now is the test 9

procedure for ve nt

- less clothes dryers. And in the 10

October 2007 framework document, DOE noted that the 11

potential limitation in the dryer test procedure was 12

identified for vent

- less dryers and manufacturers 13

had commented that the current test procedure is 14

unable to test t his type of dryer. And the 15

limitation lies in the fact that the test procedure 16

requires the use of an exhaust restrictor to 17

simulate the back pressure effects of a vent tube in 18

an installed condition. And vent

- less clothes 19

dryers do not exhaust air to th e outside as a 20

conventional clothes dryer would do. 21

So, manufacturers of vent

- less condensing 22

dryers have in the past applied for waivers from the 23

DOE test procedure for these products on the basis 24

that the test procedure can't

-- doesn't have 25

provisions for testing these type of dryers. One 26

such

-- one of these waivers was filed by LG 27Executive Court Reporters (301) 565

- 0064 112 Electronics for its vent

- less dryer. On August 23 rd
, 1

2006, DOE published the LG petition for waiver, and 2

as part of that notice, DOE presented an alternate 3

test procedure for vent

- less dryers to address the 4

potential limitations of the test procedure. 5

So as part of this alternate test 6

procedure it consisted of adding a separate 7

definition for conventional clothes dryers which are 8

vented and condensing clothes dryers whic h are a 9

vent

- less design. 10

And further the alternate test procedure 11

qualified the requirement for an exhaust simulator 12

so that it would only apply to conventional clothes 13

dryers. 14

Now, DOE first examined the alternate test 15

procedures presented in that LG p etition for waiver 16

conducting a limited number of tests on vent

- less 17

dryers at an independent laboratory. And DOE tested 18

one vent

- less electric compact, and one vent

- less 19
electric combo washer/dryer. And the results showed 20

for the vent

- less electric comp act we didn't observe 21

any variation in EF

-- in energy factor from test to 22
test. And for the combo washer/dryers we observed 23

less than 2 percent variation in the EF from test to 24

test. 25

So based on this limited testing, we 26

believe that the proposed

-- or the alternate test 27

procedure produces repeatable results. 28Executive Court Reporters (301) 565

- 0064 113 MR. BROOKMAN: Wayne, please. 1

MR. MORRIS: How many units and about how 2

many tests were you running? 3

MR. BATTAGLIA: These tests were conducted 4

as part of the energy conservation standards 5

rulema king and we tested one vent

- less compact 240 6

volt dryer, and one vent

- less combination 7
washer/dryer. And for each dryer we conducted three 8

identical tests. 9

MR. MORRIS: Thanks. 10

MR. BROOKMAN: Other comments on these? 11

Yes. 12

MR. MESSNER: We agree that there should 13

be a test procedure for vent

- less and we just need 14

to review and maybe we can get into a little more 15

details on exactly what the standard

-- what the 16

test procedure is. 17

MR. BATTAGLIA: Okay. 18

MR. BROOKMAN: Okay. Thank you, Kevin. 19

MR. BAT TAGLIA: Okay. So as part of its 20

review of alternate test procedures for vent

- less 21

dryers DOE also looked at testing conditions and 22

methods in test standards used internationally. 23

As far as those go, DOE is aware of the 24

two standards here, the EN Stand ard 61121 and the 25

Australia Standard 2442. 26

DOE also considered comments submitted by 27

Whirlpool as part of the standards rulemaking in 28Executive Court Reporters (301) 565

- 0064 1 14 which they provided possible amendments to the DOE 1

test procedure for vent

- less dryers. And those were 2

largely based on the provisions in EN Standard 3

61121. 4

And based on DOE's evaluation we believe 5

that EN Standard 61121 includes relevant test 6

procedures for vent

- less or condensing dryers and 7

that these procedures provide greater specificity 8

than the alternate test procedu re presented in the 9

LG petition for waiver. 10

So getting into these proposed amendments, 11

based on the definitions in the LG petition for 12

waiver the EN Standard 61121 and the Australia, New 13

Zealand standard and Whirlpool's proposed 14

amendments, all of those h ad very similar 15

definitions and based on those were proposing to 16

define a conventional clothes dryer as a clothes 17

dryer that exhausts the evaporated moisture from the 18

cabinet and a vent

- less dryer as a clothes dryer 19

that uses a closed loop system with an i nternal 20

condenser to remove the evaporated moisture from the 21

heated air and also noting that the moist air is not 22

discharged from the cabinet. 23

MR. BROOKMAN: Yes, Paige? 24

MS. DETRICK: I'm curious if you could 25

shed some light on why the evaporated moistur es 26

cannot be discharged from the cabinet, for example, 27

drained from the appliance into the conventional 28Executive Court Reporters (301) 565

- 0064 115 sewer line? 1

MR. BATTAGLIA: Well, I think what we're 2

getting at here is just that it wouldn't be vented 3

to the outside. I think what you're talking ab out 4

is if you condense the moisture during the process 5

and drain it out with a pump. So that that would be 6

a part of a vent

- less design. 7

MS. DETRICK: Got it. Sorry, misheard 8

you. 9

MR. BROOKMAN: Other comments on these 10

issues? 11

(No response.) 12

MR. BATT AGLIA: So for the proposed 13

insulation conditions, DOE is proposing based on the 14

LG petition or all of these, the different sources 15

that the insulation conditions would qualify the 16

requirement for an exhaust simulator so that it 17

would only apply to convent ional clothes dryers 18

which is to say those dryers with a vent. 19

And also a clarification would be added 20

that vent

- less dryers be tested without the exhaust 21

simulator installed and if a dryer is designed to 22

operate with an optional exhaust duct, the dryer 23

w ould be tested without the duct installed. And DOE 24

believes that these insulation conditions would 25

provide additional clarity and cover all possible 26

dryer configurations as well as provide 27

harmonization with international standards. 28Executive Court Reporters (301) 565

- 0064 116 Okay. So DOE also be lieves that the 1

provisions

-- I'm sorry

-- in EN Standard 61121 2

regarding condensation box also provide additional 3

clarity to cover all possible configurations. So 4

for this reason DOE is proposing for the insulation 5

conditions that if a manufacturer gives the option 6

to use a vent

- less dryer with or without a 7

condensation box, the dryer would be tested with the 8

condensation box installed. 9

In addition, DOE is also proposing for the 10

cycle measurement in Section 3.3 of the DOE test 11

procedure that if the dryer is automatically stopped 12

during a cycle and the reason is that the 13

condensation box is full of water, the test would be 14

stopped and the test run would be considered valid. 15

And, again, that's to ensure consistent results for 16

the measured efficiency. 17

An d, finally, regarding the insulation 18

conditions, DOE is proposing, based on Whirlpool's 19

proposal to add that a condenser unit of the dryer 20

must remain in place and not be taken out of the 21

dryer for any reason between tests. And, again, 22

that's for addition al clarification and to ensure 23

that all manufacturers are testing using the same 24

methods. 25

(Pause.) 26

MR. BATTAGLIA: Okay. Now, currently 27

Section 2.8 of the DOE test procedure which is 28Executive Court Reporters (301) 565

- 0064 117 concerned with clothes dryer preconditioning 1

requires that before any test cycle is initiated the 2

clothes dryer must be operated without a test load 3

in the non

- heat mode for 15 minutes or until the 4

discharge air temperature varies less than 1 degree 5

Fahrenheit during a period of ten minutes, whichever 6

is longer. 7

Vent

- less clothes dryers do not have a 8

discharge air for which the temperature can be 9

measured. So as a result DOE is proposing, based on 10

EN 61121 to revise a section to require that for 11

vent

- less dryers the steady

- state temperature must 12

be equal to the ambient roo m temperature before the 13

start of all tests. With a note that this can be 14

done by leaving the machine at ambient room 15

conditions for at least 12 hours, but not more than 16

36 hours between tests. And one thing I'd just like 17

to add here is that we're also r equesting comment on 18

whether this upper limit of 36 hours is appropriate. 19

MR. BROOKMAN: Yes, Wayne. 20

MR. MORRIS: I guess I'm struggling with 21

this one just a little bit, James, this last 22

statement. This steady

- state temperature, 23

temperature of what? Of the machine? 24

MR. BATTAGLIA: Yes, that would be 25

correct. 26

MR. MORRIS: So maybe we ought to insert 27

the word "machine" temperature or "machine" in front 28Executive Court Reporters (301) 565

- 0064 118 of temperature. 1

MR. BATTAGLIA: Okay. 2

MR. MORRIS: And if a manufacturer needs 3

to run multiple te sts in a back

- to

- back kind of 4

situation, it seems like it would be a pretty 5

significant test burden to have to wait at least 12 6

hours. If they have a way of cooling the machine, 7

you know, typically in a lot of laboratories that 8

I'm familiar with, you can use like a fan or a 9

portable air conditioner or something like that to 10

cool the machine in between cycles to get it back. 11

As long as you're back at ambient, does it matter 12

why the time? 13

MR. BATTAGLIA: That's correct. So this 14

isn't requiring 12 hours, i t's just saying that you 15

could achieve that. If you can verify that the 16

ambient

-- or the temperature of the unit is at the 17

ambient room temperature, then that would meet this 18

requirement. 19

MR. MORRIS: So in other words, emphasis 20

on the word "can"? 21

MR. BATTAGLIA: Right. 22

MR. MORRIS: You could do it that way, may 23

be

-- may be done, maybe that's a better word than 24

can. May, second word, be done by leaving the 25

machine

-- 26

MR. BROOKMAN: Or any other method that 27

would take it back to ambient. 28Executive Court Reporters (301) 565

- 0064 119 MR. MORRI S: Exactly. 1

MR. BROOKMAN: Yeah. Good heavens, I'm 2

having flashbacks to legislatures. 3

Betsy, stop me. 4

MS. DETRICK: I'm curious what is 5

suggested as the way to get a dryer back to, let's 6

say, testable state if it has sat in the ambient 7

condition 36 hours? Because clearly we occasionally 8

have breaks between tests that can be more than two 9

and a half or a day and a half, whatever. 10

MR. BROOKMAN: And, yes, you came up with 11

36 as a matter of practicality? 12

MR. BATTAGLIA: Well, that was based on 13

the pr ovisions in the EN Statement 61121. And 14

that's why we're also requesting comment on whether 15

that 36

- hour upper limit is actually necessary. 16

MS. DETRICK: Right. And I'm not asking 17

about the number of hours, but what is the step to 18

make the dryer testabl e again? 19

MR. BATTAGLIA: I'm not sure I understand. 20

MS. DETRICK: It says I can't leave it in 21

ambient conditions for more than 36 hours between 22

tests. 23

MR. BATTAGLIA: Oh, right. 24

MS. DETRICK: Sometimes a dryer is going 25

to sit even weeks and need to be tested again. 26

MR. BATTAGLIA: Right. So I think the way 27

EN 61121 was written was you would run a test cycle 28Executive Court Reporters (301) 565

- 0064 120 and then I think the provisions in EN 61121 say that 1

that first cycle is invalid. So you would have to 2

wait until you're reaching the steady

- sta te room 3

temperature again before you can run a valid cycle. 4

So I guess you would have to run one test cycle 5

before you could actually start your actual test 6

cycle. 7

MR. BROOKMAN: Wayne. 8

MR. MORRIS: I'm sure our esteemed 9

colleagues who sit in the EN 611 21 could explain to 10

us why that is the case, but lacking an 11

understanding to that, I guess I'm of the opinion 12

that if you want to have a minimum number, if you're 13

doing this by just, sort of ambient cooling and you 14

want to have a minimum number of at least 12 hours, 15

I can understand that. But I don't understand the 16

maximum. And I think I would encourage the 17

Department to think about taking that last clause 18

out. 19

And if you ran your test on Friday and 20

your second test wasn't until Monday, so what? 21

MR. BRO OKMAN: So, just remove reference 22

to the 36

- hours. 23

MR. BATTAGLIA: Okay. And the last bullet 24

on this slide is just

-- 25

MR. BROOKMAN: Let's see if there are any 26

other comments on this from anybody else? 27

MR. BATTAGLIA: Sure. 28Executive Court Reporters (301) 565

- 0064 121 (No response.) 1

MR. BROOKMAN: It seems like a practical 2

sort of a thing. If there's a downside, we should 3

know about it now. 4

Okay. 5

MR. BATTAGLIA: Okay. And, finally, DOE 6

is proposing to add a qualification of the existing 7

preconditioning procedure that it would apply to 8

vented clothes dryers. 9

So regarding the test cycle measurement EN 10

61121 and the Whirlpool proposal specify, I think we 11

talked about this, that the first cycle after a 12

period of non

- operation for longer than 36 hours 13

would not be used for evaluation. A nd that between 14

tests that the door of the tumble dryer shall be 15

closed except for loading and unloading. And DOE 16

proposed SNOPR provisions to the DOE test procedure 17

to provide a clear and repeatable testing procedure. 18

Also regarding the test cycle EN 61 121 19

requires that at least five valid test cycles be 20

performed and the results of those are then 21

averaged. However, DOE's clothes dryer test 22

procedure currently does not specify multiple test 23

cycles to obtain a representative EF and DOE is not 24

aware of an y data suggesting that the test to test 25

variation would warrant more than one test cycle. 26

So DOE is not proposing to address the number of 27

valid test cycles at this time. 28Executive Court Reporters (301) 565

- 0064 122 MR. BROOKMAN: Paige. 1

MS. DETRICK: Just to reconcile, slide 69 2

talks about the c ondenser unit not being removed 3

between tests and then also on 70 we just talked a 4

lot about things that cannot be done between tests. 5

If indeed there will be single test validity rather 6

than multiple tests to get an average value, then I 7

think a lot of t hose things are simply irrelevant. 8

MR. BATTAGLIA: Right. And those were 9

based on the requirement for the

-- if you tested 10

after a period of 36 hours of sitting there you 11

would have to wait again. So that's what that was 12

based on. 13

MS. DETRICK: But spe cifically looking at 14

the condenser unit being removed or replaced, if we 15

say single test runs are a valid data point unto 16

themselves rather than being average test data, then 17

this requirement is irrelevant. Otherwise we need 18

to say how many test runs is a set and that a 19

condenser could be, for example, removed and cleaned 20

or else I have to, you know, limit the total number 21

of test runs on a particular dryer period in its 22

life, or something. 23

MR. BROOKMAN: Yes. Let me see? 24

MS. LOWENBERGER: Amanda Lowenb erger. 25

MR. BROOKMAN: Amanda, thank you. 26

MS. LOWENBERGER: Just to respond to your 27

point, I think it's possible that even if only one 28Executive Court Reporters (301) 565

- 0064 123 test cycle is required that if that test cycle 1

fails, there could be instances where you would need 2

multiple tests run. So that provision could still 3

be useful. 4

MR. BROOKMAN: Wayne? 5

MR. MORRIS: Wayne Morris. I believe not 6

in the particular clothes dryer test procedure, but 7

in the general requirements in CFR 430, there are 8

requirements for a manufacturer obtaining repe atable 9

and verifiable results that put the requirement back 10

on the manufacturer if they feel that they need to 11

run multiples in order

-- I think

-- and it's been a 12

while since I read that, but I'm pretty sure that 13

there are procedures in there that deal wi th running 14

multiple and averaging and how you go about arriving 15

at the number that you're going to then present to 16

the Department or to Energy Star and that type of 17

thing. 18

So I think that there could be instances 19

where a manufacturer is going to run multi ple 20

cycles. I understand that in this particular 21

situation James is suggesting that the Department 22

doesn't want to specify a minimum number. I think 23

that's what you're really getting at. It doesn't 24

want to specify a minimum number of multiple or 25

minimum number of test cycles to obtain a 26

representative yield. But that's up to the 27

manufacturer to do that. 28Executive Court Reporters (301) 565

- 0064 124 And I think that that may be where Paige's 1

point about the test cycle on a condenser unit that 2

the manufacturer has got to be able to do some 3

modificat ions between the tests if they happen to 4

want to run or need to run multiple cycles. 5

MS. DETRICK: This is Paige. Yeah, this 6

speaks about the condenser itself and if a test run, 7

let's say I in my laboratory decide I'm only 8

comfortable if I run ten runs or five runs, or 9

whatever, it's very reasonable to leave the 10

condenser in place for that period of time. 11

MR. BROOKMAN: I didn't understand how you 12

reconciled that, but I think you did. Did you get 13

that? 14

MR. BATTAGLIA: So I think from what I 15

understand that manufacturers can run multiple tests 16

to verify that their measurements are correct. So 17

in that case these conditions would apply. 18

MR. BROOKMAN: Yes. Okay. Good. Thanks. 19

Okay. Let's proceed. 20

MR. BATTAGLIA: Okay. So here I think 21

we're inviti ng comments on the adequacy of the 22

proposed definitions and insulation conditions for 23

vent

- less dryers which are based on the LG petition 24

for waiver and DOE is further inviting clarification 25

-- or comments on the proposed clarifications to the 26

insulation c onditions, condensation boxes, and dry 27

preconditioning and testing conditions based on the 28Executive Court Reporters (301) 565

- 0064 125 EN 61121 and Whirlpool's proposed amendments. 1

I think we discussed some of that a bit. 2

But if anybody has more

-- 3

MR. BROOKMAN: So any addition comments 4

based o n what's been said already to respond to 5

these comment boxes? Wayne? 6

MR. MORRIS: Wayne Morris with AHAM. So, 7

James, are these

-- all the amendments then are 8

included in the SNOPR pages in the end where they 9

already

-- 10

MR. BATTAGLIA: Yes. 11

MR. MORRIS: So is there a way to trace 12

back and know which modifications are based on the 13

LG petition and which ones are based on the EN 14

standard and which ones are based on the Whirlpool? 15

MR. BATTAGLIA: Yes, it should say in the 16

actual preamble of the SNO PR. We should explain for 17

each proposed amendment where it's coming from. 18

MR. MORRIS: Yeah, I think I remember 19

reading that, but I guess I didn't see that then 20

carried forward in the latter pages. 21

MR. BATTAGLIA: Right. So the latter

-- 22

the pages you' re referring to at the very end of the 23

SNOPR? Yes, so we wouldn't write in the actual test 24

procedure

-- 25

MR. MORRIS: No, you wouldn't. I know 26

that. But do you have it somewhere, a descriptor 27

that explains which paragraphs and sections in here 28Executive Court Reporters (301) 565

- 0064 126
came out of which? 1

MR. BATTAGLIA: Oh, like from that actual 2

version of the test procedure? No, we don't have 3

that right now. 4

MR. MORRIS: Thanks. 5

MR. BROOKMAN: Subid? 6

MR. WAGLEY: No, Subid Wagley, DOE. I 7

guess what DOE is requesting is for data and any 8

information to measure that proposal. So I guess 9

again we'll probably have some sort of addition 10

information to supplement what we're proposing here. 11

MR. MORRIS: This is Wayne Morris again. 12

Valid requests, Subid. But the problem is and we 13

come back to the comment that we made earlier, is 14

that in its present form the test procedure that's 15

in the back is not at a place where we can go to a 16

laboratory, even the manufacturer's laboratory and 17

say run this. And that's what's causing us 18

problems. We have tr ied. A number of our 19

manufacturers have tried recreating these tests in 20

their laboratory, and from what is described there 21

they're having trouble doing it. So I think that as 22

these procedures get more and more cobbled together 23

from different sources they don't read like a test 24

procedure any longer. They read like definitions 25

and legal statements rather than like a test 26

procedure for a test lab to actually follow. And so 27

I think that's where we're beginning to have 28Executive Court Reporters (301) 565

- 0064 127 difficulty actually verifying some of t he requests 1

that are made. 2

MR. BROOKMAN: Wayne, I'm kind of at a 3

loss for whose principal job it is to kind of

-- you 4

want this array; right? You want this sequence and 5

values. 6

MR. MORRIS: Yes. 7

MR. BROOKMAN: And I don't know whose

-- 8

is that somethi ng that would typically fall to the 9

DOE or AHAM or the manufacturer? 10

MR. MORRIS: Well, I guess I would suggest 11

that at some point in time what might occur and this 12

is supposition is that AHAM HLD

- 1 committee will 13

likely take these changes back and consid er 14

modification

-- consider them as requested 15

modifications to HLD

- 1. Which is written in the 16

test procedure format. But we're in this middle 17

ground now. We have sort of a legalized document 18

from the Department. We don't have an HLD test 19

procedure yet and perfectly understandable, the 20

Department is asking us to go back to the laboratory 21

and run the tests and we're kind of in one of the 22

chicken and egg situations here. 23

So, I don't know whether maybe Navigant 24

can assist us in trying to piece together a draft. 25

I mean, I think that that would be one of the things 26

that would be helpful would be if Navigant could 27

take HLD

- 1 and do a track change suggestion of what 28Executive Court Reporters (301) 565

- 0064 128 would be the changes that the Department would 1

suggest to HLD

- 1 in order to conform exactly w hat 2

you're talking about. Not just in this section for 3

vent

- less, but also all the other sections. Take 4

that as a submission that would come in to the HLD

- 1 5

committee and then from that track change document 6

we could run tests, we could verify levels, an d we 7

could report back to the Department actual changes 8

that have taken place. You know, what w as the 9

before and what was the after. And that would also 10

assist HLD

- 1 in a faster means to process that. And 11

then at that point we would have a test procedur e, 12

you know, we would have to do some verification 13

between the Department and between Navigant and 14

others that they changes that they made are in 15

keeping. And I know I'm speaking for an AHAM 16

committee here which is very dangerous. But I think 17

it's a fair statement that don't

-- (inaudible)

-- 18

on the committee

-- Phil. I doubt very seriously if 19

the HLD

- 1 committee is going to be wanting to run 20

tests that are different than the Department of 21

Energy tests. 22

So, I would think that that would be a way 23

that we could resolve this. Do you see what I mean? 24

I think that would resolve it and I think it would 25

resolve it relatively rapidly. Probably could be 26

done in 30 days or less. And then we could have a 27

document that we could then go into a laboratory and 28Executive Court Reporters (301) 565

- 0064 129

sa y, okay, here do this. And I mean, Navigant 1

already knows what the changes are. I mean, I think 2

they could put it into a test procedure language and 3

you guys now employ testing people and test 4

procedure people at Navigant. So I think that it 5

would be po ssible. A suggestion. 6

MR. BROOKMAN: DOE would still need to do 7

its whatever level of approval; right? 8

Okay. Thank you for that idea. 9

Additional comments on this? Paige, do 10

you want to get in here? 11

MS. DETRICK: Just one quick technical 12

comment, det ailed comment that I just noticed. You 13

reference Section 2.8 for clothes dryer 14

preconditioning within the vent

- less clothes dryer. 15

It recommends running the dryer until discharged air 16

is a certain temperature relative to ambient. There 17

is no discharged air in a vent

- less dryer by 18

definition, so we need a different preconditioning 19

method. 20

MR. BATTAGLIA: Sorry, that would apply 21

specifically to vented dryers. And then that would 22

be qualified in the test procedure. That that 23

procedure for the discharge a ir would be

-- 24

(Simultaneous conversation.) 25

MS. DETRICK: Okay. Then we come back to 26

the problem of how do we say that the condensing for 27

vent

- free dryer is at ambient conditions when we go 28Executive Court Reporters (301) 565

- 0064 130 from test one

-- well, let's say valid test one to 1

test two t o test three and so on. How do we prove 2

it? There's no way in here to prove it. 3

MR. BROOKMAN: Would you suggest a way? 4

MS. DETRICK: I can look into it. 5

MR. BROOKMAN: Okay, Paige. Okay. 6

We are going to move on. 7

MR. BATTAGLIA: And the last topic 8

regarding vent

- less dryers is the water consumption. 9

DOE's review of this issue showed that only vent

10
less combo washer/dryers use water to condense 11

moisture in the air exiting the drum for products on 12

the U.S. market. 13

Now, as part of DOE's energy testing for 14

clothes dryers, we measured the water consumption by 15

a vent

- less combination washer/dryer according to 16

the alternate test procedure in the LG petition for 17

waiver by conducting, again, three tests for that 18

single co mbo washer/dryer that we had. Our results 19

showed that the unit consumed on average 3.2 gallons 20

of cold water per cycle. 21
Now, combination washer/dryers represent a 22

very small niche of the U.S. clothes dryer market 23

and therefore DOE believe that the bene fit of 24

measuring the water used for vent

- less dryers would 25

be outweighed by the burden that we placed on 26

manufacturers to measure water consumption. So for 27

this reason DOE is now proposing to amend the DOE 28Executive Court Reporters (301) 565

- 0064 131 test procedure to include a requirement to measur e 1

water consumption for vent

- less condensing clothes 2

dryers. And here we're requesting comments and data 3

on water consumption for vent

- less dryers and 4

whether water consumption should be included in the 5

DOE test procedure. 6

MR. BROOKMAN: No comments? Ok ay. 7

MR. BATTAGLIA: All right. The next topic 8

we're discussing is the detergent specifications for 9

clothes dryer test cloth preconditioning. And the 10

current test procedure requires that the test cloth 11

be preconditioned by performing a ten

- minute wash 12

cy cle in a standard clothes washer using the AHAM 13

standard detergent formula 2A. 14

Now, DOE notes that this detergent is 15

obsolete and no longer supplied by AHAM or other 16

suppliers and that the current AHAM detergent is 17

formula 3. So because formula 2A is no longer 18

available, DOE is proposing to amend the test 19

procedure for test cloth preconditioning to require 20

the use of the detergent, AHAM detergent formula 3. 21

Now, DOE notes that AHAM ’s clothes dryer 22

test standard, HLD

- 1

- 2009 specifies a standard 23

detergent formula three dosage of 27 grams plus four 24

grams per pound of base test load for test cloth 25

pretreatment. And as we'll discuss a bit later in 26

the SNOPR DOE is also proposing to change the load 27

size to 8.45 pounds. So based on this the detergent 28Executive Court Reporters (301) 565

- 0064 132 dosage f or the formula three would be 60.8 grams. 1

So, DOE believes that the detergent 2

concentration should be set by the pounds of test 3

cloth in the standard size test load because the 4

load is more closely matched to the maximum water 5

fill level than is the compa ct size test load which 6

is three pounds. 7

So here DOE is proposing to require 60.8 8

grams of AHAM detergent formula three for test cloth 9

preconditioning. And we're also requesting further 10

information on appropriate detergent concentrations 11

and we welcome d ata showing the effects of the 12

detergent specifications for test cloth 13

preconditioning on the measured EF for dryers. 14

MR. BROOKMAN: No comments here? 15

(No response.) 16

MR. BROOKMAN: Okay. 17

**Active Mode: Changes to Reflect Consumer Usage** 18

Patterns and Cap abilities 19

MR. BATTAGLIA: And the next topic is a 20

few different issues, but it's the changes to 21

reflect the current usage patterns and capabilities 22

and we'll be going through those individually. 23

So first for clothes dryers for the number 24

of annual use cy cles, in the 2007 framework document 25

for the standards rulemaking DOE noted that the 26

average number of dryer use cycles assumed in the 27

washer test procedure was inconsistent with the use 28Executive Court Reporters (301) 565

- 0064 133 cycles in the dryer test procedure. 1

Now, in the case of washer annu al use 2

cycles DOE published the final rule for the washer 3

test procedure in 1997 revising the washer use 4

cycles from 416 to 392 per year which DOE determined 5

to be more representative of consumer usage. And 6

based on the washer test procedure which assumes 7

that 84 percent of all clothes washer loads are 8

dried in the clothes dryer, the annual usage pattern 9

for clothes dryers would be calculated to be 329 10

cycles per year. 11

Now, in contrast the DOE test procedure 12

currently specifies 416 cycles per year. So as a 13

result DOE decided to review available data and 14

investigate a proper value for this dryer use 15

cycles. And DOE first looked at the 2004 California 16

statewide residential appliance saturation study or 17

RASS which included a survey of dryer usage 18

patterns. Now, the study surveyed over 7,500 19

households between 2002 and 2003 asking a question 20

of how many loads of clothes do you dry in your 21

dryer during a typical week. So for the 6,790 22

households that said that they own a clothes dryer 23

the average usage was 4 .69 loads per week or 24

approximately 244 loads per year. 25

However, because the study provided only a 26

limited dataset, DOE decided not to rely on this 27

data to determine an appropriate number of use 28Executive Court Reporters (301) 565

- 0064 134 cycles. 1

So next DOE reviewed the EIA's 2005 2

residential ene rgy consumption survey which is a 3

national sample survey of housing units. And for 4

each sample home, using the data provided in RECS 5

for the number of laundry loads, which is to say 6

washer cycles, that are washed per week and also the 7

frequency of clothes dryer use, DOE was able to 8

estimate the number of dryer cycles per year for 9

each sample house. And as a result of this 10

analysis, DOE estimated the average usage to be 283 11

dryer cycles per year. 12

So based on this data DOE is proposing to 13

revise the dryer use cycles per year to 283 and here 14

we're requesting comment on that change. 15

MR. BROOKMAN: Wayne. 16

MR. MORRIS: James, just to clarify. I 17

don't have an opinion on this, I just want to be 18

sure I understand how you got to 283. So you're 19

using 392 times 8 4 percent; is that

-- 20

MR. BATTAGLIA: No, well, we used the data 21

from RECS which gave us usage for clothes washers 22

washer cycles per year and then

-- 23

MR. MORRIS: Which is what? 24

MR. BATTAGLIA: I don't have that number 25

off the top of my head. I can p robably look it up 26

for you. 27

MR. MORRIS: Okay. So you used 2005 RECS? 28Executive Court Reporters (301) 565

- 0064 135 MR. BATTAGLIA: No. 1

MR. MORRIS: No, I don't think so, no. 2

Because the clothes washer is coming down too. The 3

current clothes washer test procedure is 392; right? 4

Okay. And that was set in the year 2000? 5

PARTICIPANT: (Off microphone.) Based on 6

'96, '97. 7

MR. MORRIS: So it was based on '96 or 8

'97. 9

MR. BATTAGLIA: '97, I think. '97 the 10

final rule. 11

MR. MORRIS: So we need to

-- can you get 12

us some information on what RECS says in terms of 13

number of cycles of clothes washers? 14

MR. BATTAGLIA: Yes. 15

MR. MORRIS: And then

-- 16

MR. BATTAGLIA: And then from that we

-- 17

the RECS also provided data on how often you use a 18

dryer, so

-- 19

MR. MORRIS: Percentage. 20

MR. BATTAGLIA: Right

. 21

MR. MORRIS: And percentage of loads that 22

a consumer put from a clothes washer into a clothes 23

dryer? 24

MR. BATTAGLIA: Right. 25

MR. MORRIS: I think that's the way they 26

asked it? 27

MR. BATTAGLIA: Yes, I think so. 28Executive Court Reporters (301) 565

- 0064 136 MR. MORRIS: Okay. 1

MR. BATTAGLIA: Yes, that's correct. 2

MR. BROOKMAN: And that calculation is how 3

you came to 283? 4

MR. BATTAGLIA: Yes. 5

MR. BROOKMAN: Okay. 6

MR. BATTAGLIA: I think if you want a 7

detailed analysis it could be included in the 8

standards rulemaking TSD. And that was where th at 9

number was derived. So it should be in one of the 10

TS D chapters. 11

MR. BROOKMAN: Kevin? 12

MR. MESSNER: Yes, this is Kevin Messner. 13

Just a general comment on RECS. We'll keep 14

following up on that, we have just general issues 15

with RECS. 16

MR. BATTAGLIA: And if you have better 17

data, we would welcome that. 18

MR. MESSNER: Okay. 19

MR. BROOKMAN: Does AHAN

-- do you try and 20

pull this kind of data from your members? 21

MR. MESSNER: No. I'm not aware of it. 22

MR. MORRIS: This is Wayne Morris. No, we 23

don't

-- AHAM does not pull data from

-- and this 24

would not be from our members, this would be from 25

consumers. This would be conducting several 26

thousand households in a demographically based 27

survey. 28Executive Court Reporters (301) 565

- 0064 137 MR. BROOKMAN: But would your members, 1

would they be wanting to assess loads per year. 2

Maybe Proctor and Gamble are

-- 3

MR. MORRIS: And that's what our comments 4

that we delivered to the Department back in April 5

26 th when AHAM delivered its comments it suggested 6

that we could look at such sources as those from the 7

de tergent and/or you know dryer material consumer 8

product manufacturers such as Proctor and Gamble or 9

-- 10

MR. BROOKMAN: Well, in any event, just 11

to reiterate, if you all have data if you can find 12

it, the Department would really appreciate that. 13

MR. MORRI S: Proctor and Gamble indicated 14

in the most recent survey that they released, I 15

believe, after the Department that the average 16

consumer dries 5.2

-- 5.35 loads per week or 278 17

loads per year. And, you know, that's in this case 18

the value estimated by RECS , I believe, was 279. 19

MR. BATTAGLIA: 283. 20

MR. MORRIS: Or 283. 21

MR. BROOKMAN: Pretty close. 22

MR. MORRIS: You can use the factor

-- 23

MR. BROOKMAN: It's pretty close. 24

MR. MORRIS: It's pretty close. 25

MR. BROOKMAN: Yeah, okay. 26

MR. MORRIS: You know , I think our 27

comments in April were the Department needed to 28Executive Court Reporters (301) 565

- 0064 138 verify this to a better methodology than just RECS. 1

MR. BROOKMAN: Yeah. Okay. 2

So you can see the comment box there. Any 3

addition comment on that number? And we also talked 4

about the meth odology, so let's now move on. 5

MR. BATTAGLIA: Okay. So the next issue 6

of current consumer usage patter n s is the dryer 7

initial remaining moisture content. And if you're 8

not familiar with RMC, it's the ratio of the weight 9

of water contained by the test l oad at the 10

completion of the washer test cycle to the bone dry 11

weight of the test load expressed as a percent. 12

Correspondingly, the initial RMC of a 13

clothes load being dried as a function of RMC at the 14

end of a washer cycle and the current DOE test 15

proced ure specifies an initial RMC of 70 plus or 16

minus five

-- 3.5 percent. Now, as with the average 17

use cycles the RMC of typical clothes loads in the 18

residential washer test procedure needs to be or 19

should be consistent with values defined in the 20

clothes drye r test procedure. And DOE believes that 21

the initial RMC in the dryer test procedure may not 22

reflect typical RMCs of actual clothes dryer loads. 23

Now, since the time that the dryer test 24

procedure was established in 1981, the average 25

washer RMC has decrease d due to the higher 26

efficiency models with higher final spin speeds. 27

And for the residential clothes washer 28Executive Court Reporters (301) 565

- 0064 139 standard, which became effective in 2007, DOE 1

estimated a weighted average RMC of 56 percent. 2

Now, as part of the preliminary analysis 3

for the re sidential clothes dryer standards 4

rulemaking DOE estimated the RMC of clothes washers 5

using a distribution of values for models listed in 6

the December 2008 CEC product database. And for 7

products for which the RMC was listed DOE observed a 8

range of RMC val ues between 30 and 61 percent with 9

an average of 46 percent. 10

Now, after the October 2007 framework 11

document AHAM provided data showing the shipments of 12

residential clothes washers for which the RMC was 13

reported along with the shipment weighted RMC. And 14

as you can see on the graph on this slide, this 15

shows the data that AHAM provided and it's the 16

aggregated data for all washers including front and 17

top loading. And it shows that the RMC has been 18

decreasing consistently from about 54 percent in the 19

year 20 00 to 47 percent in 2008. And it suggests 20

that the 70 percent in the DOE test procedure is 21

probably greater than current shipment weighted 22

residential clothes washer RMCs. 23

So, based on the shipment weighted RMC 24

data submitted by AHAM and DOE's review of the CEC 25

product database DOE believes that initial RMC of 47 26

percent is representative of current residential 27

dryer initial test load characteristics. So 28Executive Court Reporters (301) 565

- 0064 140 therefore DOE is proposing to make this change from 1

70 percent RMC to 47 percent. 2

Now, in examining the EPCA requirement to 3

determine the effects of the proposed amendments on 4

measured efficiency based on DOE's testing conducted 5

in an independent lab DOE estimated a 41 percent 6

increase in EF resulting from switching from 70 7

percent to 47 percent initial RMC. And DOE will 8

consider addressing this change in the concurrent 9

standards rulemaking for residential dryers. 10

So here we're requesting comment on this 11

proposed amendment to change the RMC and that's 12

based on the shipment weighted RMC of clothes 13

washer s shown in the data submitted by AHAM. And 14

further we welcome data and comments indicating an 15

appropriate initial RMC and how that initial RMC 16

would affect the measured energy factor of clothes 17

dryers, and in particular for units that are 18

minimally compli ant with the current standards. 19

MR. BROOKMAN: Phil Manthei. 20

MR. MANTHEI: Phil Manthei, Alliance 21

Laundry Systems. I think there is somewhat of a 22

disconnect here. You're using the AHAM submitted 23

data for RMC but from clothes washers. But you have 24

to r emember that data has been

-- a correction 25

factor has been applied to that data for the test 26

load that is used. In the dryer test procedure 27

you're using the raw data uncorrected. So you are 28Executive Court Reporters (301) 565

- 0064 141 going to have, actually, a curve that's going to be 1

higher than this red line. And so you should not be 2

proposing an RMC of 47 percent, it should be 3

something higher than that. 4

MR. BROOKMAN: Would you say how much 5

higher? 6

MR. MANTHEI: Well, this presents a 7

problem for the Department because you're going to 8

have to come up with some numbers. And that's going 9

to have to be done by doing some testing of product 10

to see, you know, what the

-- and this is not of the 11

dryer, but of the clothes washer

-- clothes washers 12

to see what the uncorrected or noncorrected RMCs 13

ar e. Don't confuse extraction characteristics of 14

moisture with evaporation characteristics in the 15

dryer. The dryer

-- you're testing how well it 16

evaporates an amount of clothes. And you have to 17

start with the moisture that's in the clothes load. 18

Now, the number in the test

-- you're 19

going to be using the same test cloths that the 20

washer is using. And that's going to vary, of 21

course, just like in the washer test. However it 22

varies in the washer test only for extraction. But 23

I think it needs to start out at the uncorrected 24

value of, say, 56 percent or 53 percent, whatever 25

the raw number is from that test towel load not a 26

correction factor RMC. 27

MR. BATTAGLIA: I'm not sure. What is the 28Executive Court Reporters (301) 565

- 0064 142 correction that the washer does this? 1

MR. MANTHEI: Okay. Okay. Because when 2

this test procedure for clothes washers started it 3

used an initial test load, I think it was

-- you 4

have to go way back in time in 1993 or '94 time 5

period when the first test cloth was used and was 6

gone through the extractor phase to determin e how 7

well it released moisture in the extraction at 8

various RPMs. And there was a curve that was 9

presented. Well, anyway, different batches of test 10

cloth performed differently. And so it was 11

recognized after about three or four years and me, 12

my company was the one to raise the issue back in 13

1997, that there had to be something done and there 14

was a big group of people along with NIFs, the DOE, 15

and Navigant, and at that time ADL, Arthur D. 16

Little, that prepared a method to arrive at a 17

correlation between the original test cloth and 18

other batches of test cloth that are produced and 19

how well it releases the moisture. 20

So, again, all these values that have been 21

reported here by AHAM are correction factored values 22

going back to that original test lot. But the 23

actual test loads that are going to be used are not 24

going to be corrected by X number of percent. 25

They're going to be the moisture that's in that 26

load. And I think you're starting out at too low of 27

a moisture content. 28Executive Court Reporters (301) 565

- 0064 143 MR. WAGLEY: This is Subid from DO E. 1

Shall we expect written comments from you? It would 2

help us guide through

-- 3

MR. MANTHEI: Yes. Yes. 4

MR. WAGLEY:

-- you know, that information 5

-- 6

MR. MANTHEI: Like I said, I don't know 7

how to change this curve other than to say you have 8

to d o some testing on clothes washers and see what 9

the uncorrected values are for maybe various lots of 10

test cloth. Because over all of these years various 11

lots of test cloth were used by manufacturers. And 12

maybe when you get all said and done it's just goin g 13

to be easy to say, okay, instead of 47 percent it 14

should be 5 percent higher than that. I don't know. 15

MR. MESSNER: (Off microphone.) Test 16

loads as test lot changes then you have to do 17

correction factor to try to make it

-- 18

MR. MANTHEI: Yeah, I wou ldn't want to say 19

let's put correction factor calculations into the 20

dryer test, I think that would make it too 21

complicated. Just raise this number higher because 22

you're using uncorrection factored cloth values in 23

the dryer test procedure. 24

MR. BROOKMAN: Okay. 25

MR. BATTAGLIA: The last topic for clothes 26

dryers regarding consumer usage is regarding the 27

test load weight. And for this the current DOE 28Executive Court Reporters (301) 565

- 0064 144 procedure currently specifies a seven pound load for 1

standard size dryers and a three pound load for 2

cont act

- sized dryers. Now, in response to comments 3

to the October 2007 framework document DOE 4

investigated whether the average load size for 5

standard capacity dryers is consistent with the 6

current generation of washer capacities. 7

Now, as part of this, DOE co ntacted 8

detergent manufacturers to obtain data and Proctor 9

and Gamble had conducted an internal study in 2003 10

on household laundry habits on a representative set 11

of population across the U.S. and from this Proctor 12

and Gamble provided DOE with a select summ ary data 13

from the study. 14

And the data showed that the test load 15

weight which was based on a sample size of 3,367 16

loads of laundry from a total of 510 respondents, it 17

showed that the average load size for top loading 18

and front loading washers was 7.2 and 8 .4 pounds 19

respectively. 20

Now, based on the average shipment 21

weighted market share for top loading and front 22

loading washers from the data provided by AHAM the 23

shipment weighted average clothes washer size would 24

be approximately 7.5 pounds using this data. 25

However, DOE recognizes that washer capacities were 26

likely to have increased since the time that the 27

study was conducted in 2003 and therefore DOE 28Executive Court Reporters (301) 565

- 0064 145 continued its analysis to factor in the more recent 1

changes of the clothes washer capacities. 2

And here on t his graph, it shows the 3

trends in the shipment weighted average tub volume 4

for residential clothes washers between 1981 and 5

2008 based on data from AHAM's report, the Trends in 6

Energy Efficiency 2008. And the data shows that the 7

average tub volume has inc reased from 2.5 cubic feet 8

in 1981 to 3.22 cubic feet in 2008 which is a 22.4 9

percent increase. 10

Now, Section 2.7 regarding test load sizes 11

of the DOE washer test procedure provides the 12

minimum, maximum, and average test load size 13

requirements for the wash er test procedure which is 14

determined based on the clothes container capacity. 15

So this table here is an excerpt from that table and 16

shows the values for the test load sizes for the 17

2.52 and 3.22 cubic feet container capacities. And 18

DOE notes that the ave rage load size in the washer 19

test procedure increased by about 21 percent with 20

the associated increase in capacity shown in the 21

AHAM data which DOE believes would proportionately 22

impact the clothes dryer load sizes. So applying 23

this ratio of the average c lothes washer test sizes 24

to the clothes dryer test load sizes would result in 25

an increase from 7 pounds to 8.45 pounds for 26

standard sized dryers. 27

So based on this data DOE is proposing to 28Executive Court Reporters (301) 565

- 0064 146 amend the dryer test load size to 8.45 pounds plus 1

or minus .085 po unds for standard sized dryers. 2

Now, DOE believes that most compact 3

clothes dryers are used in conjunction with compact

4

sized washers and DOE does not have any information 5

to suggest the tub volume for such washers has 6

change significantly. So therefore we are not 7

proposing to change the three pound test load size 8

currently as specified for compact

- sized clothes 9

dryers. 10

Now, again, looking at that EPCA 11

requirement to determine the effects on the measured 12

efficiency, in order to determine a quantifiable 13

e stimate of the change in measured efficiency the 14

DOE looked at data from a report by NIST which 15

conducted testing to investigate the effects of 16

changing clothes dryer load size on the measured 17

efficiency for a vented electric standard size 18

clothes dryer. 19

Now, using this data DOE estimated the 20

percentage change in EF for an 8.45 pound test load 21

by linearly interpolating the results for the 7

- 22

pound and nine

- pound tests from the NIST data. And 23

the resulting increase would be a 3.8 percent 24

increase from this test load size change. 25

So here we're requesting comment on this 26

proposed amendment to change the dryer test load 27

size for compact

-- or for standard

- sized dryers to 28Executive Court Reporters (301) 565

- 0064 147 8.45 pounds plus or minus .085 pounds. And we're 1

also welcoming data on washer and dryer test load

-- 2

whoops

-- on washer and dryer test load sizes 3

representative of current consumer usage habits for 4

both compact and standard

- size units. And we're 5

further requesting data on how any changes to the 6

test load size would affect the measured energ y 7

factor of clothes dryers and in particular for those 8

that are minimally compliant with the current 9

standards. 10

MR. BROOKMAN: Wayne. 11

MR. MORRIS: Yeah, Wayne Morris with AHAM. 12

So, James, help me here if I understand this. I 13

thought I had read earlier also in the SNOPR that 14

the Department was not suggesting that the energy 15

factor for clothes dryers would be impacted by the 16

changes to the test procedure; did I read that 17

correctly? 18

MR. BATTAGLIA: No, it's for the test load 19

weight we're projecting a chan ge in the EF and 20

that's that 3.8 percent. We looked at each proposed 21

amendment individually to determine the effects on 22

the measured efficiency. 23

MR. MORRIS: Okay. So the Department is 24

suggesting an increase of 3.8 percent in the energy 25

factor overall? 26

MR. BATTAGLIA: Right. Due to this 27

specific proposed amendment. 28Executive Court Reporters (301) 565

- 0064 148 MR. MORRIS: Just to this? 1

MR. BATTAGLIA: Right. 2

MR. MORRIS: Are there then adjustments

-- 3

I guess from now on today we're going to be talking 4

about room air conditioners, aren't we? Do we come 5

back and do clothes dryers again? I mean, I guess 6

we do. 7

MR. BATTAGLIA: We touch upon clothes 8

dryers a little later, I think. And we will have a 9

section at the end to look at the

-- or to discuss 10

the effects of the measured or the proposed changes 11

on the measured efficiency for the total proposed 12

test procedure. 13

MR. MORRIS: Okay. Okay. Thanks, James. 14

MR. BATTAGLIA: Are there no other 15

comments on this? 16

(No response.) 17

MR. BATTAGLIA: Now, switching over to 18

room air conditioners. The current DOE room air 19

conditioner test procedure assumes an average annual 20

use of 750 hours. Now, DOE's technical support 21

document from September of 1997, which was issued in 22

support of the most recent room air conditioner 23

energy conservation standards sh owed that the 24

average annual operational hours are closer to 500 25

hours. Now, DOE's investigation of this issue 26

showed a lack of metered and surveyed data for the 27

operating hours of identification room air 28Executive Court Reporters (301) 565

- 0064 149 conditioners. However, DOE did find two sources o f 1

survey data for room air conditioners, for room air 2

conditioner use in the EIA's 2005 RECS and the CEC 3

California statewide RASS. 4

Now, the CEC RASS survey contained only 5

aggregated residential data which limited any 6

analysis pertaining to the annual o perating hours. 7

And the relevance of this data was also limited by 8

it only having a regional scope. 9

Now, the EIA's 2005 RECS provided more 10

extensive data on individual residences while 11

providing a more expansive and representative sample 12

of households. So DOE decided to continue its 13

analysis using the 2005 RECS. 14

So using the RECS data DOE was able to 15

develop a household sample for the annual hours of 16

use of a room air conditioner which was then used to 17

calculate a weighted national average of room a ir 18

conditioner usage hours. This data indicated that 19

the estimated room air conditioner average annual 20

usage is approximately 810 hours. However, DOE does 21

not consider this increase of 60 hours from 750 to 22

810 hours to be significant because it does not 23

exceed the uncertainty level that's associated with 24

RECS' base data, the RECS based approach for 25

estimates of this value. So therefore DOE is not 26

proposing a change in the annual operating hours in 27

the test procedure at this time. So here we're 28Executive Court Reporters (301) 565

- 0064 150 requestin g comment on this issue of the

-- 1

MR. BROOKMAN: Kevin. 2

MR. MESSNER: Yeah, thanks. Again, we 3

think RECS has got issues. And also however we 4

think the 750, just stick with the 750 annual usage 5

at this point. 6

MR. BROOKMAN: Your other issues with 7

RECS , to the extent possible you'll address them in 8

your written comments? 9

MR. MESSNER: Yeah, again. We've already 10

-- we've already commented in numerous ways about 11

the issues we have with RECS. 12

MR. WAGLEY: Subid Wagley from DOE. Is 13

there any other sourc e that you would like to 14

recommend since there are issues that you said with 15

RECS that are valid at this point to reference for 16

us? 17

MR. MESSNER: I can't give you, I don't 18

have any, I don't know of any right now. That 19

doesn't mean

-- I have to go back an d check in all 20

of the written comments. 21

MR. WAGLEY: We'll just wait. 22

MR. BROOKMAN: Okay. Thank you. 23

Other comments? 24

In particular if you don't think sticking 25

with 750 is a good idea, now is the time to say it? 26

Please. Your name? 27

MR. BURGOS: Hi, I'm Javier Burgos from 28Executive Court Reporters (301) 565

- 0064 151 Navigant Consulting. I just wanted to mention that 1

you've also asked for comments on this before, in 2

particular for the standards rulemaking for DOE. So 3

some of this has already been commented on before 4

and you have received some s uggestions. Any more 5

suggestions would also be greatly appreciated. 6

MR. BROOKMAN: Okay. Thank you. 7

Yes, Wayne. 8

MR. MORRIS: Wayne Morris with AHAM. I 9

think that our issues that we have gone into 10

excruciating detail with about the present 11

constructi on of RECS stand for themselves. But I 12

think that what is necessary to understand with 13

regard to room conditioners are that the percentage 14

of homes that have room air conditions is declining 15

as more and more people that need air conditioning 16

can use centr al air conditioning and so it begins to 17

get more and more difficult to get survey work on 18

room air conditioners. They also are beginning to 19

use more and more in a cooling space cooling or 20

assistance cooling kind of sequence within homes 21

rather than as pri mary cooling in many situations 22

and consequently that becomes another issue with 23

trying to get data. I mean, are you trying to cool 24

the air or how much are you trying to cool? Are you 25

assisting your central air conditioning or other air 26

conditioning by d oing this or are you using it as 27

your primary means. So any survey that is going to 28Executive Court Reporters (301) 565

- 0064 152 be done has got to be very carefully done on room 1

air conditioners. 2

Size loading of a room air conditioner is 3

absolutely critical and consumers

-- there's a long, 4

long h istory of commentary that consumers buy too 5

large an air conditioner for the space that they 6

need and thereby cause themselves problems in 7

accordance with using it. It freezes up the 8

compressor or they over cool, or they don't use it 9

properly, it doesn't extract the moisture. Because 10

moisture extraction is probably the most important 11

job that any air conditioning system has secondary 12

to actually reducing the temperature. 13

So then when you get into this, then when 14

you ask somebody that has too large an air 15

conditioner that they now have put into a relatively 16

small room how often they use it, are they 17

responding on the number of hours that they actually 18

are using it or the number of hours that they should 19

have used it if they had the right size unit. And 20

th is becomes part of the problem with getting this 21

kind of data. 22

We understand and sympathize with the 23

Department trying to do this, but the problems with 24

RECS are so deep that we've got to find a better way 25

of doing this. Now, I know that the Department has 26

come up with some alternatives. They've had some 27

suggestions about doing some survey work using 28Executive Court Reporters (301) 565

- 0064 153 college student dormitories on refrigerators and, 1

you know, a selected group of hotels in California, 2

or something along that line, but I think that we've 3

got to seriously look at trying to get good solid 4

data on which we can make these kind of 5

determinations rather than just sort of, oh, by the 6

way estimates. 7

Are there some power line communication 8

type of information that's out there that's 9

available to us? PNNL did some survey work years 10

ago on street estimates of use of material. Now, 11

granted, that is a demographic or geographic area 12

that may not be repres entative of the entire United 13

States, moisture not withstanding, although Spokane 14

might be a good example or San Antonio. But, you 15

know, we do have to figure out how we can get to 16

this kind of data. It's not going to be easy and 17

it's probably not going t o be cheap. But we do, for 18

all of these appliances, we have a responsibility to 19

get better data than where we are at today. And I 20

hope that the Department would convene some meetings 21

or discussions or whatever about specifically on the 22

issue of how to ge t to solid data. Because every 23

one of these rulemakings is dependent upon this, it 24

doesn't matter what product it is. And I don't care 25

if it's even light ballasts or televisions, it's 26

important that we have the right data to do this. 27

And we don't now. And so, you know, in absence of 28Executive Court Reporters (301) 565

- 0064 154 better data, probably better off, as Kevin said, 1

looking at 750. But we do encourage, even though 2

saying that, we encourage the Department to find 3

another way. 4

MR. BROOKMAN: Thank you. 5

We're going to keep moving on here. 6

MR. BATTAGLIA: Okay. Now for part load 7

performance. DOE noted in the October 2007 8

framework document that the current DOE test 9

procedure measures only full load performance and it 10

is not able to assess energy savings associated with 11

technologies that improve part load performance. 12

Now, DOE does not plan to consider 13

amendments to its room air conditioner test 14

procedure to measure part load performance because 15

DOE has concluded that widespread use of part

- load 16

technologies in room air conditioners wou ld probably 17

not be stimulated by the development of a part

- load 18

metric and hence the significant effort of 19

development of an accurate part

- load metric is 20

likely not warranted by the expected minimal energy 21

savings. 22

Now, DOE also considered whether the 23

amb ient temperature conditions in the room air 24

conditioner test procedure are representative of 25

typical installations. And DOE had received 26

comments in response to the framework document that 27

the ambient temperature should be increased from 95 28Executive Court Reporters (301) 565

- 0064 155

-- that should say degrees Fahrenheit to 115 degrees 1

Fahrenheit. However, DOE did not receive further 2

information to support the specification of the 3

higher temperature. And therefore, DOE is not 4

considering an amendment to the ambient temperature 5

conditions in the ro om air conditioner test 6

procedure. So, here we're inviting comment and data 7

indicating a representative ambient temperature 8

condition and also requesting data on how any 9

changes to these conditions would affect the 10

measured efficiency. 11

MR. BROOKMAN: Kev in? 12

MR. MESSNER: Kevin Messner. AHAM 13

supports the current test condition at 95. 14

MR. BROOKMAN: Thank you. 15

**Active Mode: Room Air conditioners and Dryer** 16

Referenced Test Procedures, Technical Correction for 17
Gas Dryers, Clarification to Dryer Gas Supply 18

C onditions 19

MR. BATTAGLIA: Okay. The next topic will 20

be the room air conditioner referenced test 21

procedure. 22

Now the current DOE test procedure for 23

room air conditioners references two test standards 24

that are shown here, the American National Standard 25

Z23 4.1 which was established in 1972 and the ASHRAE 26

Standard, 16

- 69 which was established in 1969. Now, 27

both the ANSI and ASHRAE test standards have since 28Executive Court Reporters (301) 565

- 0064 156 been updated since the time that the DOE room air 1

conditioner test procedure was last revised. And 2

tho se current standards are shown here, the 3

ANSI/AHAM RSE1

- R2008 and ANSI/ASHRAE Standard 16

- 4

1983 which was reaffirmed in 2009. 5

Now, does suggested in the October 2007 6

framework document to consider updating the test 7

procedure references to the most recent v ersions and 8

DOE reviewed the difference between

-- the 9

differences between the older test standards and the 10

current versions of those standards to determine if 11

proposing amendments would be appropriate. 12

Now, DOE first notes that the sections 13

that would b e referenced in ANSI/AHAM RAC1

- R2008 do 14

not introduce any new changes in the measurement of 15

cooling capacity or power input. And DOE also notes 16

that the sections that will be referenced in 17

ANSI/ASHRAE 16

- 1983 would introduce changes to the 18

determination o f capacity four temperature 19

measurements

-- four new temperature measurements 20

and changes to the test tolerances. 21

So DOE is proposing to amend the test 22

procedure to reference the relevant sections of 23

these two updated standards. Now, based on DOE's 24

rev iew of these standards DOE believes that these 25

new standards provide more accurate and repeatable 26

measurements of capacity while providing a greater 27

flexibility to manufacturers in selecting equipment 28Executive Court Reporters (301) 565

- 0064 157 and facilities and do not add any significant 1

testing b urden. So we are inviting comments on this 2

proposed amendment to update the references to the 3

most recent versions of those standards. 4

MR. BROOKMAN: No comments from anyone? 5

(No response.) 6

MR. BROOKMAN: Okay. 7

MR. BATTAGLIA: Now for the clothes drye r 8

referenced test procedure the clothes dryer test 9

procedure currently references the industry standard 10

AHAM HLD

- 1

- 1974 and specifically requires that the 11

clothes dryer under test be restricted by adding the 12

AHAM exhaust simulator described in Section 3.3. 5 of 13

that standard. 14

Now, DOE received information that this 15

AHAM test standard has since been updated and the 16

current version is AHAM

- HLD

- 1

- 2009. And DOE noted 17

that the Section 3.3.5.1 of the revised AHAM 18

standard regarding the exhausting conditions 19

pro vides the same requirements for the exhaust 20

simulator as required by the existing DOE test 21

procedure. So for this reason DOE is just proposing 22

to amend the reference to the most recent version to 23

reference that appropriate section. 24

Now, DOE also recogniz es that the AHAM

25

HLD

- 1

- 2009 allows for the use of an optional 26

modified exhaust simulator which is included as a 27

more convenient option than the exhaust simulator 28Executive Court Reporters (301) 565

- 0064 158 originally specified for vented dryers. However, 1

the AHAM test standard also notes that only limited 2

testing has been done to compare the results using 3

the two different exhaust simulators and the users 4

are invited to submit results and comments for both 5

options. 6

So because the modified exhaust simulator 7

is still new and limited data exists to compare the 8

effects using the different simulators DOE is 9

continuing to require the standard exhaust simulator 10

currently specified. 11

Now, on a slightly different note in the 12

definition section of the DOE test procedures, 13

Section 1.8 references an obsolet e AHAM standard 14

HLD

- 2EC for which there is no provisions currently 15

in the DOE test procedures. So we're proposing to 16

just remove that reference. 17

MR. BROOKMAN: Kevin. 18

MR. MESSNER: Kevin Messner with AHAM. I 19

am shocked to hear

-- for the record that's tongue 20

in cheek

-- that we support the updating to the most 21

recent AHAM standards. 22

MR. BROOKMAN: Thank you. So on the 23

following slide you can see the comment box, you can 24

all read it there for yourselves, and comments on 25

slide 102? 26

(No response.) 27

MR. BROOKMAN: Okay. 28Executive Court Reporters (301) 565

- 0064 159 MR. BATTAGLIA: Now the next topic is a 1

technical direction for the gas dryer

-- 2

MR. BROOKMAN: No, excuse me. Wayne? 3

MR. MORRIS: Excuse me, James, slide 4

behind you and I'm sorry about that. But in 5

reference to slide, I guess i t's one oh

-- I guess 6

it's 100? 7

MR. BATTAGLIA: Yeah. This is 101 now. 8

MR. MORRIS: Your numbers are a little 9

different than mine. 10

MR. BATTAGLIA: Right. 11

MR. MORRIS: Where you said that because 12

of only limited testing had been done on the 13

modified ex haust simulator, of course, that was like 14

a year and a half ago or two years ago when the 15

standard went through. I mean, it finally achieves 16

ANSI approval in 2009, but it was done probably two 17

or three years ago. There may be some additional 18

testing by n ow that's been done on this and we'll 19

try and see if we can find out if some of our member 20

companies have used the modified exhaust simulator 21

and we'll submit that with our written comments. 22

But, you know, if we can come up with some 23

additional data to sh ow the comparison between the 24

two items that the Department will be open to using 25

the modified exhaust simulator rather than sticking 26

with the old one in situations. We'll take that on 27

as an activity that we do for the written comments. 28Executive Court Reporters (301) 565

- 0064 160 Thanks. 1

MR. BROO KMAN: Thank you. 2

MR. BATTAGLIA: Okay. SO the next is the 3

technical correction. And for this the equation in 4

the current DOE test procedure contains a technical 5

error for the calculation of the p er cycle gas dryer 6

continuously burning pilot light gas e nergy 7

consumption which is expressed in the BTUs per 8

cycle. 9

Now, that equation should correctly 10

subtract the active mode hours per years from the 11

total hours per year to give the number of non

12

active mode hours per year that the pilot is 13

consuming gas b efore dividing by the average number 14

of dryer cycles in a year. And it should read, as 15

we have shown here, there's a parenthesis missing in 16

there, so we're proposing to revise this equation 17

and seeking comment on that. 18

MR. BROOKMAN: Phil Manthei. 19

MR. M ANTHEI: Phil Manthei, Alliance 20

Laundry Systems. My mind recalls that the minimum 21

standard, I thought, EPC A NACA has a minimum 22

standard and it's got a design prescriptive. In 23

that the design prescriptive says you cannot have a 24

pilot light. 25

MR. BATTAGL IA: That was the previous 26

standard. The current standard is a performance 27

standard. So presumably if you had a high enough 28Executive Court Reporters (301) 565

- 0064 161 efficiency unit, I don't know why you would, but you 1

could presumably use a burning pilot light. 2

MR. MANTHEI: Really. Did that

-- that 3

never got

-- that didn't get carried over? 4

MR. BATTAGLIA: That's not how

-- 5

MR. BROOKMAN: Does anyone from the 6

Department want to comment on how that put back in? 7

MR. MANTHEI: Yeah. I'm absolutely

-- I 8

mean, I don't think there is anybody t hat has one. 9

And that's why I even question whether it should 10

even be in the test procedure. 11

MR. BROOKMAN: Judy Reich? 12

MS. REICH: It's my understanding that the 13

current performance standard is sufficiently high 14

that it effectively precluded any consta nt pilot 15

lights so that the prescriptive design requirement 16

was eliminated. If there were some way to achieve 17

that and still have a pilot light, that would be 18

considered acceptable. But effectively there's 19

nothing on the market anymore that can meet this 20

standard with a pilot. 21

MR. BROOKMAN: Okay. Wayne Morris. 22

MR. MORRIS: Maybe I'm missing something 23

on a slide. Yeah, the slide you've got up there on 24

the screen now. Should that 416 be 416? 25

MR. BATTAGLIA: Oh, sorry. Yeah, that 26

would be changed to 283. My apologies. 27

MR. MORRIS: Oh, thanks. 283. In both 28Executive Court Reporters (301) 565

- 0064 162 places? 1

MR. BATTAGLIA: Right. 2

MR. MORRIS: We are sort of dealing with 3

buggy whips because, as Judy said, I don't think 4

there's anybody on the market with a constant 5

burning pilot light drye r and I seriously doubt that 6

anybody is going to come out with one tomorrow. So, 7

you know it is a little bit silly to be doing, but 8

we need to for accuracy of the regs. 9

MR. BROOKMAN: Right. Thanks for that 10

confirmation. 11

MR. BATTAGLIA: Okay. And the next topic 12

is a clarification to the gas supply test conditions 13

for gas dryers. So DOE is proposing a clarification 14

to Sections 2.3.2.1 and 2 of the current DOE test 15

procedures which specify maintaining the gas supply 16

to the clothes dryer to normal in let pressure 17

immediately ahead of all controls at seven to ten 18

inches of water column for natural gas and 11 to 13 19

inches of water column for propane gas. 20

Now, DOE believes that the reference to 21

the normal inlet test pressure in these sections 22

which are p rovided to specify natural gas and 23

propane supply pressure conditions may be confusing 24

as to what is meant by the term "normal." And DOE 25

believes that such language is not necessary because 26

the gas supply pressure immediately ahead of all 27

controls is expl icitly stated with these values. So 28Executive Court Reporters (301) 565

- 0064 163 DOE is proposing to modify the language as you can 1

see here. 2

MR. BROOKMAN: No comments? 3

(No response.) 4

MR. BROOKMAN: No comments. 5

MR. BATTAGLIA: Okay. 6

MR. BROOKMAN: Before you move on, I'm 7

going to suggest th at we all just stand up and 8

stretch for a minute. Let's just do that. Don't go 9

anywhere. 10

(Pause.) 11

MR. BROOKMAN: Okay. While James is 12

getting to the right slide I'm going to hand out

-- 13

Brenda Edwards made a copy of those of you that 14

provided a busi ness card as you registered to enter 15

today, so we'll hand those around. And, James, you 16

can proceed. 17

MR. BATTAGLIA: Okay. So DOE also 18

believes that the specifications for the gas 19

pressure regulator in these same sections should 20

clarify that the outlet pressure for a dryer with a 21

pressure regulator for which the manufacturer 22

specifies an outlet pressure should be approximately 23

that recommended by the manufacturer. So for this 24

DOE is proposing to make these minor revisions to 25

the language in these secti ons to clarify the outlet 26

pressure conditions for a dryer equipped with a gas 27

pressure regulator. And, again, we are here 28Executive Court Reporters (301) 565

- 0064 164 requesting comments on these proposed clarifications 1

to the language for specifying natural gas and 2

propane supply pressure condition s for testing gas 3

dryers. 4

MR. BROOKMAN: That's okay? Yeah. I'm 5

looking over here at you guys? That's yes. 6

Okay. 7

**Compliance with EPCA; Requirements; Effects of Test** 8

Procedure Revisions on Compliance with Standards 9

MR. BATTAGLIA: All right. Now, ge tting 10

into the compliance with some other EPCA 11

requirements. This is mainly regarding the test 12

burden and EPCA basically requires that any amended 13

test procedure must produce test results which 14

measure energy efficiency use or other metric of a 15

covered pr oduct during the representing of average 16

use cycle or period of use and must not be unduly 17

burdensome to conduct. 18

Now, in the December 2008 test procedure 19

NOPR DOE tentatively concluded that the proposed 20

amendments for a standby and off mode for both 21

prod ucts would satisfy this requirement. 22

Now, for the proposed amendments for 23

standby and off mode in the SNOPR would not require 24

measurement of delay start and cycle finish modes 25

for dryers and delay start and off

- cycle mode for 26

room air conditioners and in stead would use a 27

simplified approach in which the hours are allocated 28Executive Court Reporters (301) 565

- 0064 165 to inactive and off modes. 1

Also for room air conditioners DOE had 2

received comments in response to the December 2008 3

test procedure NOPR that the proposed ambient 4

conditions

-- tempera ture conditions would increase 5

testing burden. And as we discussed earlier for the 6

NOPR, DOE is now proposing to provide manufacturers 7

with more flexibility in setting the ambient 8

conditions for standby and off

- mode testing. 9

Now, DOE tentatively conclude s that the 10

testing conditions for standby and off

- mode proposed 11

in the SNOPR for both products are not unduly 12

burdensome. 13

Now, for active mode, the proposed 14

amendments to the DOE test procedure for clothes 15

dryers to test automatic termination control drye rs 16

and vent

- less dryers are based on the international 17

testing standards that we presented which are used 18

to determine compliance with energy conservation 19

standards for dryers in Australia, New Zealand, and 20

also the European Union for the EN standard. 21

A nd DOE notes that a number of 22

manufacturers that sell dryers in the U.S. also sell 23

dryers in these countries and therefore likely are 24

already testing dryers according to this test 25

standard. So DOE believes that the proposed 26

amendments would not require te sting methods and 27

equipment that are substantially different from the 28Executive Court Reporters (301) 565

- 0064 166 testing methods and equipment in the current DOE 1

test procedure and therefore would not require 2

manufacturers to make a major investment in test 3

facilities and in new equipment. 4

And als o for DOE's proposed amendments to 5

reflect current consumer usage patterns and 6

capabilities, those amendments do not substantially 7

change the test procedures and methods such that 8

they would be burdensome to conduct. 9

Now, for room air condition active mod e. 10

The proposed amendments to update the references to 11

the external standards in the DOE room air 12

conditioners test procedure are based on revised 13

standards representing current industry practices 14

and methods. So these proposed amendments would not 15

requi re manufacturers to make any significant 16

investments in test facilities and equipment. Nor 17

require significant changes in testing methodology. 18

MR. BROOKMAN: So let's just

-- do we have 19

comments on any of those preceding slides? There 20

are four slides to tal there related to test burden, 21

standby off mode, clothes dryer active mode, and 22

room air conditioner active mode. Comments on any 23

of those? 24

Phil Manthei? 25

MR. MANTHEI: Maybe the only thing was 26

regarding my comments about the initial RMC that I 27

made t hat we should look at whether we should be 28Executive Court Reporters (301) 565

- 0064 167 using 47 percent or something different that is a 1

higher number because RMC is based on a corrected

-- 2

MR. BROOKMAN: Right. 3

MR. MANTHEI:

-- factored test cloth in 4

the washer and the test procedure for the dryer is 5

not going to use that corrected factor. 6

The reason it could become a burden is, 7

okay, we'd like to use, you know, our home

- style 8

clothes washer to extract the load to use in the 9

dryer test procedure. However, a clothes washer is 10

going to necessa rily get the load down in the dryer 11

to 47 percent. 12

MR. BROOKMAN: No. 13

MR. MANTHEI: So here's where the issue 14

is. Okay. 15

MR. BROOKMAN: Okay. That made it clear. 16

MR. MANTHEI: Now, obviously we make 17

commercial clothes washers that, you know, can 18

extr act at a much higher, you know, RPM or whatever 19

and we can still get there. It wouldn't be 20

impossible, but you get my point, we still have a 21

disconnect between RMC and the dryer test procedure 22

and what values were submitted from the clothes 23

washer test pr ocedure. 24

MR. BROOKMAN: Okay. Wayne? 25

MR. MORRIS: Phil, also if you begin 26

extracting that test cloth down to 47 percent, 27

you're going to actually deteriorate that test cloth 28Executive Court Reporters (301) 565

- 0064 168 at a faster rate, aren't you? I mean, you're going 1

to cause other problems as sociated with trying to do 2

that. I mean, you're going to use an extractor, I 3

guess. But now you're talking about some fairly 4

significant amounts of money to spend on it. 5

MR. MANTHEI: I’m not sure that it would 6

be significant, but I don't have any infor mation on 7

that. 8

MR. BROOKMAN: Okay. 9

Compliance with EPCA; Requirements; Effects of Test 10

Procedure Revisions on Compliance with Standards 11

MR. BATTAGLIA: Okay. Now touching on the 12

effects of the test procedure revisions on 13

compliance with standards. And we have discussed 14

this a little bit in the individual sections about 15

the EPCA requirement to determine to what extent the 16

proposed test procedures would alter the measured 17

efficiency as compared to the existing test 18

procedure. And if DOE determines th at it would in 19

fact alter the measured efficiency of a covered 20

product, DOE must amend the applicable energy 21

conservation standard. 22

Now for standby and off

- mode, EPCA 23

requires that these amendments will not determine 24

compliance with previously established standards. 25

So for the clothes dryer active mode, for 26

the proposed amendments DOE believes that there are 27

revisions to the initial RMC and the standard size 28Executive Court Reporters (301) 565

- 0064 169 dryer test load would affect the energy factor as 1

compared to the existing test procedure. And ba sed 2

upon DOE's testing and analysis of a minimally 3

compliant dryers and review of available research, 4

DOE believes that the proposed amendments to the 5

initial RMC would increase the measured energy 6

factor by 41 percent and the test load change would 7

increa se the measured energy factor by 3.8 percent. 8

So based on the total proposed amendments, 9

the measured energy factor of minimally compliant 10

dryers would increase by about 41 percent for 11

compact clothes dryers and about 46 percent for 12

standard sized dryers . And here you can see in the 13

data what these changes would look like for each 14

product class. And DOE will consider these changes 15

in the concurrent energy conservation standards 16

rulemaking for dryers and room air conditioners. 17

MR. BROOKMAN: Let's just pause it there 18

for a second. Give them a chance to look at it. 19

(Pause.) 20

MR. BROOKMAN: We're on the table. Looks 21

good. Okay. 22

MR. BATTAGLIA: Okay. Now, because the 23

proposed clothes dryer test procedure amendments for 24

active mode would substantiall y change the existing 25

energy factor metric DOE has tentatively decided to 26

create a new Appendix D1 in the 10 CFR 430, Subpart 27

B for the proposed amendments. And Appendix D1 28Executive Court Reporters (301) 565

- 0064 170 would contain a clothes dryer test procedure that 1

manufacturers would be required to use on the 2

mandatory compliance state of amended dryer energy 3

conservation standards. And manufacturers would 4

continue to use Appendix D until the energy 5

conservation standards are amended. And at that 6

time testing would be conducted according to 7

Appe ndix D1. 8

Now, for room air conditioners based on 9

DOE's review of the proposed amendments DOE has 10

tentatively concluded that the proposed amendments 11

would not affect the measured EER of room air 12

conditioners. SO here we're inviting comment on how 13

the prop osed amendments for dryers and room air 14

conditioners will affect the measured efficiency of 15

covered products. DOE is seeking data showing how 16

each of these proposed amendments would affect the 17

measured EF or EER of minimally compliant dryers and 18

room air conditioners. 19

MR. BROOKMAN: Wayne? 20

MR. MORRIS: James, just help me on the 21

room air conditioner on that slide. You're not 22

proposing any change to the EER on RACS. We are 23

including now the standby measurement? 24

MR. BATTAGLIA: Right. And that would be 25

separate. This is just looking at the active mode. 26

MR. MORRIS: Okay. Just for the active 27

mode EER? 28Executive Court Reporters (301) 565

- 0064 171 MR. BATTAGLIA: Right. 1

MR. MORRIS: Not the IEER or whatever? 2

MR. BATTAGLIA: Right. So the EPCA 3

specifies that the IEER wouldn't be used to 4

determi ne compliance with the existing standard. 5

MR. MORRIS: Okay. Okay. I see. Okay. 6

Thanks. 7

MR. BROOKMAN: Phil. 8

MR. MANTHEI: Phil Manthei, Alliance 9

Laundry Systems. The only thing we have to remember 10

here is on the clothes dryer we're connecting some 11

dots back to the clothes washer test procedure. I 12

know there's going to be a separate rulemaking on 13

that coming up . If we start making changes to 14

anything especially like that average load size and 15

the average load size chart or something and the 16

washer that we keep

-- you know, whatever we change 17

there has got to come back over to here. 18

MR. BROOKMAN: Okay. Other comments on 19

this slide, this series of slides? I think that's 20

the last of the slides. There are back

- up slides as 21

well for your reference. So thanks, James. That 22

was well done. 23

Now is an opportunity for anybody that 24

wishes to do so to make closing rem arks, summary 25

remarks regarding issues that matter to you that you 26

think perhaps were not covered sufficiently during 27

the course of this meeting today. 28Executive Court Reporters (301) 565

- 0064 172 (No response.) 1

MR. BROOKMAN: Okay. I see none. Then 2

I'll turn it back to our DOE host and hostess. 3

**Closing Remarks** 4

MS. SULLIVAN: Okay. Well, thank you all 5

so much for coming. And I'm looking forward to 6

reading your comments and seeing any data that you 7

guys can submit, that would be especially helpful. 8

Just a reminder, the comment period closes 9

Aug ust 30 th , and you can submit comments either to 10

the e

- mail that's up there, or by post to Brenda 11

Edwards, or on Regulations.gov. 12

So, again, thank you. I hope nobody gets 13

too wet on their way home. 14

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MR. BROOKMAN: Thank you. Save travels. 20

Please take just a moment to fill out the evaluation 21

form. 22

Thanks for a very productive day. 23

(Whereupon, at 2:43 p.m., the meeting was 24

adjourned.) 25

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27Executive Court Reporters (301) 565

- 0064 173 1

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**REPORTER'S CERTIFICATE** 18

19

This is to certify that the attached proceedings 20

before: 21

U.S. DEPARTMENT OF ENERGY 22

In the Matter of: 23

PUBLIC MEETING **TEST PROCEDURE SNOPR FOR**  24 25 **RESIDENTIAL CLOTHES DRYER S**  **AND ROOM AIR CONDITIONERS** 26Executive Court Reporters (301) 565

- 0064 174 1 Were held as herein appears and that this is the 2

original transcript thereof for the file of the 3

Department, Commission, Board, Administrative Law 4

Judge or the Agency. 5

Further, I am neither counsel for or related to 6

any party to the above proceedings. 7

8

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### Debbi Derr 11 Official Reporter 12 13 Dated: July 15, 2010 14