### CEC Workshop

- Appliance Efficiency Regulations Comments Submittedby the Association ofHome Appliance Manufacturers 

### October 19,2000

AHAM appreciates the opportunity to offer comments on the initiative by the CEC to promulgate amendments and additions to the its appliance efficiency regulations, per AB-970 and the previously noticed Docket 98-A&B-1. AHAM submitted comments on docket 98-A&B-I dated October 7,1999, and we respectfully ask the Commission to again review and consider those comments in full prior to issuing a Proposed Rule. Forthe benefit of Commissioner Rosenfeld and others who may not be aware ofor remember AHAM's previous comments, I will reiteratejusta few ofour major concerns that are already on the docket.


### General: AHAM opposes any new requirements or exercise ofauthority which is different than federal requirements and burdens and undermines interstate commerce, which NAECA is designed in large partto protect. Federal law is clear that the center ofappliance standard activities for NAECA covered products is federal. Issues oftesting, reporting, orcompliance of these products should be dealt with at DOE or FTC. Please refer to our October 7, 1999 comments for the details ofour concerns in these areas. 

### Reporting Requirements: In general, we object to providing any information to Californiathat is not required to be provided to DOE or FTC. However, we would be glad to discuss California's interest in specific data items on a case-by-case basis. For example, the latest preliminary draft that AHAM has ofthe proposed changes to the efficiency regulations, dated July 20, 2000, indicates that CEC will require manufacturers ofrefrigerator/freezers to submit outside dimensions ofthe cabinets. This is not requiredby federal reporting and wouldresult in
an added burden that we believe is not germane to the regulations. Furthermore, the latestpreliminary draft we have also indicated that CEC would require reporting various data onkitchen ranges and ovens. DOE and FTC have decided that no standards, labeling or datareporting are required for ranges and ovens because they use little energy and there is no evidence that there is a great deal ofspread in the energy use ofthese products in the marketplace. The proposal by CEC to require data is not only preempted, but would add significant burden to manufacturers for no benefit to anyone.
Another area ofreporting proposed in the latest preliminary draft was to require a "Water Factor" and other parameters on clothes washers. Again, we urge CEC to only require parameters that are required by federal law for the same reasons stated above.
AHAM is interested in providing data to CEC on behalfofits members to assist the Commission, especially in areas where we already publish most ofthe required information in our industry certificationprogram directories such as room air conditioners and refrigeratorfreezers.

\Residential Wine Chillers: Wine Chillers were discussed at some length during proceedings for docket 98-A&B-I, resulting in a CEC staffrecommendation on the docket, dated Decembers 13,1999 as follows: "In discussions following the workshop, staffconcluded that there should be no perfonnance standard for wine chillers at this time." However, the July 20, 2000 preliminary draft indicated that CEC had changed its mind, and intended to propose standards for wine chillers. There has been much confusion as to whether these products were covered by federal or state regulation. DOE has clarified that there is no federal regulation.
AHAM agrees with staff's previous position that it is premature to establish any standards for residential wine chillers for the following reasons:
1. There is no appropriate test procedure for rating residential wine chillers. 2. There is insufficient data to establish an appropriate baseline standard. 3. Relatively speaking, there are very few units being sold, therefore the potential energy savings is insignificant. 4. Care must be taken to avoid restricting features and utilities that are essential to the proper storage ofwine and the needs ofconsumers. Therefore, AHAM recommends that a test procedure be developed first, followed by data collection to then detennine whether a standard is warranted and what an appropriate level might be

..Attached to our comments are recommendations on the test procedure, along with infonnation on the market and energy use ofthese products. Turning now to issues on the list ofitems for today's workshop, we offer the following comments: Coin-operated clothes washers: We believe more analysis should be done before establishing standards for these products. The use patterns are probably quite different than clothes washers used in the home, and therefore a special analysis is required to detennine cost effectiveness of any standards. Furthennore, the potential energy savings may not warrant the cost and hassle of establishing standards. Continuously Burning Pilot Lights: Any restrictions on energy use ofNAECA covered products, such as gas ranges, is preempted by NAECA. DOE is currently considering the issue ofpilot lights on ranges and CEC should wait for their detennination. Electricity Standby Losses: Standby losses should be looked at on a product-by-product basis, and any restrictions on NAECA covered products are preempted.
Thank you for considering ourcomments. We look forward to an ongoing constructive dialogue. f-,e3Pectfully**sUbm~tt~Y7¥:** 

## "C**a.,w'\.t2.~** 1(1. Lawrence R. Wethje Vice President AHAM Engineering Services

# CEC Commissioner(s}/ StaffMeetings 10/18/00 & 

# Workshop 10/19/00 

# Comments presentedby: Paul Sikir; Director ofDesign Engineering Sub-ZeroFreezer Co., Madison WI



# • Introduction

• Are efficiency standards for wine chillers appropriate?

• Reasons for No efficiency standards on wine chillers.

• Status changes since 12/13/99 CEC summaryreport.
• ProposedNext Steps ':

# Introduction

• Appreciate the opportunitytoprovidecomments

• Sub-Zero Freezer Company; Madison WI

- Family owned company inbusiness 56 years

- Built-inhome refrigeration produced for specialty niche markets

- Sophisticatedproduct withvalue added features/performance

- California is an importantmarketto us

# Introduction

• Sub- Zero wineproductline

- Introduced to market in mid 1999; Developedbased onneed in marketplace for improvedproducts

- Provides cooling for optimum long term storage or serving temperatures

- Provides flexibility to store varying quantities ofwine at different temperatures

- Flexibility and sophistication inbottle and display arrangements

- Developedproduct with input from wine experts and product field tests throughoutthe US including California. (UC-Davis; several Californiavineyards)

- This product line provides new and exciting innovations that provide value added features/performance for the consumer and the wine itself.

# Introduction

• Wine manufacturers/ Resources

- Wine coolers builtby other smaller niche manufacturers like us

- Limitedresources that wouldbe further depletedto satisfy additional energyregulation

- Currently devoting significant manpower and financial resources to meetNAECA efficiency standards for refrigerators and freezers for upcoming 2001 standard levels

- Significant disadvantage as comparedto major appliance manufacturers who can spread the costs ofregulation over a larger number ofunits produced. Administrative burdenthat would be requiredto respondto individual states, in additionto US DOE, would clearlyhurt our ability to compete inthe marketplace.


# • Strongly urgeyou not to setenergy standards for wine coolers ·.

# Are efficiency standards for wine chillers appropriate, and ifso what should theybe? What reporting requirements are appropriate ?

• A December 13, 1999 summaryreport ofthe October14, 1999 CEC workshop (held in SanFrancisco) presented a staffconclusion "that there shouldbe no performance standard for wine chillers at this time"

• The same report stated that "consensus was reached thatmandatory reporting ofperformance ofwine chillers should continue"

• The December 13,1999 summary also stated consensus was reached that" a modifiedtestmethod shouldbe developed for wine chillers since their operatingtemperatures are different from those of conventional refrigerators" ·.

# Reasons Presented for No efficiency standards on wine chillers

• Small energy usage for wine products as a whole when compared to refrigerators/freezers.

• No applicable testprocedure exists at this time whichproperly represents the energy consumption ofwine productwhose application anduse differs significantly from a refrigerator.

• Refrigerator standard does not allow for features unique to wine product andrestricts the development ofinnovative value added features/ product for consumers andthe wine product itself. ·.,.' , . - ...

### -

....**"~-.-,.,,--**



### .SMALL ENERGY

## USAGEFOR WINE PRODUCTS PERCENTAGE OF REFRIGERATORS SOLD IN CALIFORNIA VERSUS TOTAL USA (AHAM FIGURES) 1998 CA 0.95 MILLION REFRIGERATORS %SOLD IN CALIFORNIA 1998 US 9.7 MILLION REFRIGERATORS EQUALS 9.79% 

### APPROX.10% TOTAL WINE US MARKET IS APPROXIMATELY40,000 UNITS ANNUALLY IF WE ASSUME CALIFORNIA IS A LARGER PERCENTAGE OF UNITS SOLD IN US 1HAN 1HE 10% REFRIGERATOR SALES LETS ASSUME DOUBLE OR 20% 1HE NUMBER OF WINE UNITS 1HEN SOLD IN CALIFORNIA ANNUALLY IS 20% OF 40, 000 8000 UNITS 1HE TOTAL ENERGY IMPACTOF 1HESE 8000 UNITS IS APPROXIMATELY BASED ON 1.5 KWH/DAY @$0.101 KWH EQUALS 8000 X1.5 XO,10 = 12,000 KWH/DAY X$O, 101 KWH = $1,200 PER DAY OR 4380000 KWH/DAY $438,000 PER YEAR 1HIS REPRESENTS 1HE ENTIRE ENERGY CONSUMPTION FOR WINE 1HE ENTIRE CONSUMPTION FOR REFRIGERATORS @1,5 KWH/DAY AND $, 10/KWH EQUALS 950,000 X1.5 X 0,10 EQUALS $142,500 PER DAY OR $52,012,500 PER YEAR SO WINE REPRESENTS A PERCENTAGE OF ENERGYCONSUMPTION IN CALIFORNIA OF $1,200 0,84% LESS THAN 1% 142,500 THIS IS ALL ENERGY CONSUMPTION; IF REGULATED SAYYOU WOULD SAVE 10%OR LESS THAN $50,000 IYEAR 

### IS THIS WORTH THEEXTRA COSTANO TIMEFOR REGULATIONS ON SUCHA SMALL NUMBER/SAVINGS? , ,

### ITESTSTANDARD/pRQCEDURE (CURRENTLYNO TESTPROCEDUREIS

### AVAILABL~I ,THE DOE DOES NOTRECOGNIZEA WINE PRODUCTAS A REFRIGERA TOR OR DOES ITHAVEA STANDARD FOR THEM BASED ON ITNOTBEING 

### A REFRIGERA TOR (DEFINITION BEING DEVELOPEDATTHIS TIME) AND THE SMALL CONTRIBUTION THIS PRODUCTMAKES TO ENERGYAS JUSTDESCRIBED.
THE SUGGESTI:D STANDARD BY THE PROPOSED RULEMAKING FOR WINE UNITS SECTION 1604.2 (A) (1) IS BASED ON A DEVELOPEDI UNIQUE TO REFRIGERATOR PRODUCT USAGE STANDARD AMBIENTRANAT90F ELEVATI:D AMBIENTWAS INCORPORATI:D IN THE REFRIGERATOR CLOSED DOOR TI:STTO SIMULATI: HIGH NUMBER OF DOOR OPENINGS NOTACCOUNTI:D FOR IN A CLOSED DOOR TI:ST WINE PRODUCT HAS A VERY LOW NUMBER OF DOOR OPENINGS AS COMPARED TO A REFRIGERATOR

WINE DOOR OPENINGS SIMILAR TO A FREEZER (USES A .85 FACTOR TO ADJUST FOR THIS) 38 DEGREE ENERGYRA TlNG POINT REFRIGERATOR TI:ST IS RATING ENERGY CONSUMPTION AT 38 DEGREES F WINE PRODUCTWILL ON AVERAGE BE RUNNING AT 55 DEGREES F FOR TYPICAL USER RANGE DOWN TO LOWER FOR SERVINGI DESERTWINE TI:MPERATURES SLOPE OF THE LINE/ PRODUCTCAPACITY REFRIGERATOR STANDARDS ARE BASED ON AN EQUATION THAT IS A BEST FIT LINE (SLOPE AND INTI:RCEPl) THATWAS ESTABLISHED BY MAPPING ENERGY CONSUMPTION VERSUS PRODUCTVOLUME (CAPACITY) FOR SEVERAL MODELS OVER WIDE RANGE OF VOLUMES ENERGY= SLOPE 

## 01) + INTI:RCEPT A ENERGY EQUATION FOR WINE PRODUCTWOULD ALSO NEED TO BE DEVELOPED. MODEL LINE UP IN VOLUMES IS BECOMING A WIDER RANGE (SMALL UNDERCOUNTI:R UNITS TO LARGE UPRIGHT UNITS) AND THE APPROPRIATI: SLOPE AND INTI:RCEPTWOULD BE REQUIRED; CANT JUST ASSUME THE EXISTING SLOPE OF THE REFRIGERATOR STANDARD NEED ONE THAT IS CORRECT I FAIR ACROSS WINE VOLUME LINE IS 

### THIS WORTH THE EXTRA COSTAND TIMEFOR REGULA TlONS ON SUCHA SMALL NUMBER/SAVINGS? 

# ·.**r-----<·~<~-·** 

## --.--..**~.-<**

## ..**~~----- .<~~** 

## ...-.--------<.-.-.<--..-.--....------<--

..------...------. i

## REFRIGERATOR STANDARD DOESNOTALLOWFOR FEA TURES UNIQUETO WINEPRODUCT 

# i USEOFAGLASS DOOR

. I 

## M ULTIPLETEMPERATUREZONESIINDEPENDENT CONTROLS USE BYCONSUMEROF ILLUMINATION LIGHTING WHEN DOORCLOSED (LIKE DISPLAY CASES) NEW INNOVATIONSARE B8NG USEDTHAT AREVALUEADDED FEATURES TOTHECONSUMER ANDTHEWINE ITSB.F.

THIS IS ADEVB.OPING PRODUCT ANDTHIS DEVB.OPMENT ANDASSOCIATED INNOVATIONS SHOULD NOT BEOVERLY RESTRICTED BY INAPPROPRIATETEST I

## ENERGYSTANDARDS

TO PERFORM THIS WORKAFFECTS SMALLER NICHECOMPANIES LIKE USWHICH ICAN NOT STRESS ENOUGHAREALREADY DEDICATING MAJOR RESOURCES TO COMPLYWITHTHE 2001 REFRIGERATOR/FREEZERSTANDARDS. 

# ..

## •

# Status changes since 12/13/99 CEC summary report

On September 6, GrayDavis, Governor ofCalifornia, signed into law the California Energy Security and ReliabilityAct of2000 (AB 970). Among other things, this Actgives sweeping direction to the California Energy Commission (CEC) to adoptbothbuilding and appliance energy efficiency standards.

- Adopt and Implementupdated and cost-effective standards

... to ensure the maximum feasible reduction in wasteful, uneconomic, inefficient, or unnecessary consumption ofenergy.


## • CEC staffhasnowtakenpositionthat wine coolers are already Californiaregulated. (using the federal refrigerator testprocedure)

• Wine cooler manufacturers and AHAM are now confused; 

## Why this change in position by CEC stafffrom consensus we had at 10/14/99

## workshop?

- AHAM/ Manufacturers have started discussions for development ofa test procedure for appropriateperformance datareporting on wine coolers to the CEC
as was agreed to at workshop.

• The small energy savings associated with any energy regulation on wine chillers does not seem to fit the criteria associated with the CaliforniaEnergy Security and Reliability Act of2000 and the use ofan inappropriate testprocedure (Refrigerator) greatly impacts the development of innovative / value added wine products and mis-represents the energy consumption ofwine products whose application anduse differs significantly from a refrigerator. 

# ..

# Proposed Next Steps

• Continue to follow the previous consensus that hadbeenreached betweenthe manufacturers/ AHAM and CEC staffduring 10/14/99 workshop (12/13/99 SummaryReport) 

# Se

- Continue the discussion and development ofan appropriate modified

# A-~o.ch€.cI:::; test procedurewith wine manufacturers thatis in progress.

- Performance dataperthis modified testprocedure would be reported to CEC and tracked as the wine product/designs/technology maturewith innovative and new productdesigns.

- No energyperformance standard equations/levels should be established atthis time.



# • Attend andparticipate in 10/19/00 workshop

• Request and conduct additional meetings with commissioners and!or staffas required.

• Thanks to everyone for yourtime and consideration.

### Section 1604. TestMethods for Specific Appliances. (a) Refrigerators,Refrigerator-Freezers, and Freezers. (1) 

### The test methods for refrigerators, refrigerator-freezers, and freezers are shown in Table A-I. (2) When arefrigerator, refrigerator-freezer, or freezer canbeoperated using either alternating current electricity or one ormore other sources ofprimarypower,the test shallbeperformed using alternating current electricity only.
TableA-I Refrigerator, Refrigerator-Freezer, and FreezerTestMethods**~- ~**  

### -71.ppliam:e

-- . - -- - "**"~** -"**""~----"~-TestM1!Ihod ~"**  .. ,.. "**~** 

### Federally-regulated consumerproducts 10 CFRSections 430.23(a) (2000) and 

### 430.23(b) (2000), as applicable Wine chillers that are consumerproducts 10 CFRSection 430.23(a) (2000) Freezers that are consumerproducts 10 CFR Section 430.23(b) (2000) Refrigeratingbottled orcanned beverage ANSIIASHRAE 32.1-1997 Vending machines Commercial refrigerators, commercial refrigerator- ANSIIASHRAE 117-1992, with the freezers, and commercial freezers controls adjusted to obtain the following product temperatures: 

### Type InitialProduct Maximum Product Temperature in of Temperature in 

### OF Refrigeratorcompartment 38 ± 1 40 Freezercompartment 0±1 2 Wine chiller 45 ± 1 Norequirement Ice cream cabinet -5 ± 1 0 (b) Room AirConditioners,RoomAirConditioningHeatPumps,Packaged TerminalAir 

### Conditioners, and PackagedTerminalHeatPumps. Thetest methods for room air

### conditioners,
room air

### conditioningheatpumps, packagedterminal air

### conditioners, and packagedterminalheat pumps are showninTableB-1.

us;e £:Xf!ST"/N& 

### 'T£sf /,Poocr.q;QIAr«.0 c • '-' ·n

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### Ao'V~fV\rv,,;t--v' W li." Yt/r/l..o' SIZ77711/6S. riC.£

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### _-r«.S'\1rJ 6 ,Q \...L S;-r A'"0 AR....<J 1'2 fL. 

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# -PI. 430, Subpl. B, App. A 1 being tested is to be maintained during the test. Unless the area is obstructed by shields or baffles, the gradient is to be maintained from 2 inches (5.1 em) above the floor or supporting platform to a height one foot (30.S em) above the unit under test. Defrost controls are to be operative and the anti-sweat heater switch is to be "on" during one test and "off" during a second test. Other exceptions are noted in 2.3, 2.4, and 5.1 below.

2.3 Conditions for automatic defrost re- frigerator-freezers. For automatic defrost refrigerator-freezers, the freezer compartments shall not be loaded with any frozen food packages. Cylindrical metallic masses of dimensions 1.12 ±O.2S inches (2.9±O.S em) in diameter and height shall be attached in good thermal contact with each temperature sen· sor within the refrigerated compartments. All temperature measuring sensor masses shall be supported by nonthermally conduc· tive supports in such a manner that there will be at least one inch (2.5 cm) of air space separating the thermal mass from contact with any surface. In case ofinterference with hardware at the sensor locations specified in section 5.1, the sensors shall be placed at the nearest adjacent location such that there will be a one inch air space separating the sensor mass from the hardware.

2.4 Conditions for all.refrigerators. There shall be no load in the freezer compartment during the test.

2.5 Steady State Condition. Steady state conditions exist if the temperature measure· ments in all measured compartments taken at four minute intervals or less during a sta· bilization period are not changing at a rate greater than 0.0420 F. (0.0230 C.) per hour as determined by the applicable condition of A or B.

A. The average of the measurements dur· ing a two hour period if no cycling occurs or during a number ofcomplete repetitive com· pressor cycles·through a period of no less than two hours is compare to the average over an equivalent time period with three hours elapsed between the two measurement periods.

B. If A above cannot be used. the average of the measurements during a number of complete repetitive compressor cycles through a period of no less than two hours and including the last complete cycle prior to a defrost period, or if no cycling occurs, the average of the measurements during the last two hours prior to a defrost period; are compared to the same averaging period prior to the following defrost period. 3. Test Control Settings 3.1 Model with no user operable tempera· ture control. A test shall be performed dur· ing which the compartment temperatures and energy use shall be measured. A second test shall be performed with the temperature 10 CFR Ch. II (1-1-97 Edition)
control electrically short circuited to cause the compressor to run continuously.

3.2 Model with user operable temperature**~** control. Testing shall be performed in ac·
...**~~_--­** cordance with one of the following sections using the standardized temperatures of: All-refrigerator: 380 F. (3.30 C.) fresh food

compartment temperature Refrigerator: 150 F. (-9.40 C.) freezer com·

partment temperature Refrigerator·freezer: 5° F. (- 15° C., freezer

compartment temperature Variable defrost control models: 5°F (-15°C) freezer compartment temperature and 38±2°F fresh food compartment tempera· ture during steady·state conditions with no door·openings. If both settings cannot be ob· tained, then test with the fresh food com· partment temperature at 38±2"F and the freezer compartment as close to SOF as possible.

3.2.1 A first test shall be performed with all compartment temperature controls set at their median position midway between their warmest and coldest settings. Knob detents shall be mechanically defeated if necessary to attain a median setting. A second test shall be performed with all controls set at ei· ther their warmest or their coldest setting (not electrically or mechanically bypassed). whichever is appropriate. to attempt to achieve compartment temperatures measured during the two tests which bound (i.e., one is above and one is below) the standard· ized temperature for the type of product being tested. If the compartment tempera· tures measured during these two tests bound the appropriate standardized temperature. then these test results shall be used to determine energy consumption. If the compart· ment temperature measured with all con· trois set at their coldest setting is above the standardized temperature, a third test shall be performed with all controls set at their warmest setting and the result of this test shall be used with the result of the test per· formed with all controls set at their coldest setting to detennine energy consumption. If the compartment temperature measured with all controls set at their warmest setting is below the standardized temperature: and the fresh food compartment temperature is below 450 F. (7.22 0 C.) in the case of are· frigerator or a refrigerator.freezer. excluding an aU-refrigerator, then the result of this test alone will be used to determine energy consumption.

3.2.2 Alternatively. a first test may be performed with all temperature controls set at their warmest setting. If the compart· ment temperature is below the appropriate standardized temperature, and the fresh food compartment temperature is below 45" F. (7.22" C.) in the case of a refrigerator or are· frigerator·freezer, excluding an all·refrig· erator, then the result of this test alone will 124OCT-19-1000 09:37AM FROM-SUB ZERO DESIGN ENG,

Pt. 430, Subpt. B, App. B1 being tested has a variable defrost control the previsions of4.1.2.2. shall apply.

4.1.2.1 Long-time Automatic: Defrost. If**~he** model being teseed has a long-1:ime automat!.c elefrost system, 'the tese Ume period may consist of twO parts. A first part would be the same as the test for a unit having no**def~r.** provisions (section 4.1.1). The second part would**sta..~** when a aefrost period is initiated during a compressor "on" cycle and terminate at the second curn "::m" of t..'1.e compressor motor or after tou!" hours, which· ever comes first.

"'.1.2.2 Variable defrost controL If the model being tested has a variable defrost control system. the test shall consist of three parts. Two part.$ shall be the same as the test for long-time automatic aefrost in accordance with section 4.1.2.1 above. The third. part: is the optional teSt to d.etermine the time between defrosts (5.2.1.3). The iliird part is used by manufacwrers that choose not. to accept the default value of F of 0.20, ta calculate CT.

4.1.2.3 Variable defrost: control optional test. .I\.fter**steady~state** conditions with no door-openings are achieved in accordance with seetion 3.3 above, the test is eontinued using the above datly door-opening sequence until stabilized operation is achieved. Stabilization is defined as a minimum of three consecutive defrost cycles with times between defrost that will allow the calculation of a Mean Time Between Defrosts (MTBDl) that satisfies the statistical relationship of 90 percent conf1dence, The test is repeated on at least one more unit ofthe model and Wltil the Mean Time Between Defrosts for the multiple unit test (MTBD2) satisfies the statistical relationship. Ifthe time becween defrosts 1$ greater than 96 hours (compressor "on" time) and this defrost period can be repeated on a second unit. the test may be terminated at SS hours (en and the absolute time value used for MTBD for each unit. 5. TestMeasunmencs. 5.1 Temperature Measurements. Temperature measurements shall be made at the 10· cations prescribed. in Figure 1-2 of HRF-1- 1919 and shall be accurate to Within to,S'" F. (0.3'" C.) oftrue value.

5.1.1 Measured Temperature. The meas.- ured t.emperature is to be the average of all sensor temperature readings taken at a particular time. Measurements shall be taken at regular intervals not to exceed four minutes.

5.1.2 Compartment**Tempera~e_** The compartment temperature for each test period shall be an average of the measured tempe:-atures taken during a complete eycle or sever-al complete cycles of the compressor motor (one compressor cycle 15 one complete motor "on" and one comple:.e motor "off" period). For long-time automatiC defrost: models. compartment temperature shall be that: measured in the first part.ofthe test pe6082716464 T-442 P 002/003

10 CfR Ch. II (1-1-97 Edition)
::-lod specified 1n 4.1.1. For models equipped with variable defrost controls, compartment temperatures shall be those measured in the first part of the test period spec!.fled in 4.1.2.2.

5.1.2.1 The nt..:mber of complete compressor motor cycles over which the measured t.emperatures 1n a compartment are to be averaged to detennine compartment temperature shall be equal to the number of minutes between measured. temperature readings rounded up to the next whole minute or a number of complete cycles over a time period. exceeding one hour, One of the cycles shall be the last complete compressor motorcycles during the testperiod.

5.1.2,2 Ifno compressor motor cyclIng oc- curs, the compartment temperature shall be the average of the measured temperawres taken during the last thirty-twa minutes af the test period.

5.1.2.3 If incomplete cycling occurs (less than one cycle) the compartment umpera- cure shall be the average of all readings taken ciuring the last three hours of the last complete "on" partod,

5.2 EnergyMeasurements: 5.2.1 Per-day Energy Consumption. The energy consumption in kilowatt-hours per day for each test pertod shall be the energy expended. during the test period as specified in section 4,1 adju.seed. to a 24 hour period.

The adjustment shall be determined as follows:

5.2.1.1 Nonautomadc and automatic defrost models. The energy consumption in kilowatt-hours per day shall be calculated equivalent to: ET-{EPx!44OxK}!T where ET-test cycle energy expended in kllowa«- hau

...s per day, EP_energy expended in k1lowatt-hours during the test period, T_length of time of the test period In minutes. 1440-conversion factor to acuust "to a 24 hour period 1n minut.8s per day. and K

..correetion factor of 0.7 for chest freezers and 0;85 for upright freezers to adjust for average household usage, dimensionless. 5.2.1.2 Long-time Automatic Defrost, If the twO oa.-c :est method is used, the energy consump-tiOn 1n kllowat"t-hours per day shall bl! calculated equivalent to: ET

...{l440xKx£PlITl)

... ((EP2

- (EPlxT2I Tl))xKx!21CT) where ET, 1440, and K are defined 1n 5.2.1.1 EPl_energy expended Ln**kilowat.t~hours** during 1:he first parr: of metest. EP2=energy expended in kUOWatt-hours during the second part ofthe teSt. CT_Defrost timer run time in hours reqUired to cause it to go through a complete cycle, to the nearest tenth hour per cycle, 130 F-034