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1 U.S. DEPARTMENT OF ENERGY

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3 RESIDENTIAL CLOTHES DRYER TEST PROCEDURE

4 RULEMAKING MEETING

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6 PUBLIC MEETING

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9 Thursday

10 November 13, 2014

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12 The Public Meeting met in Room 4A-104 North,

13 1000 Independence Avenue, S.W., Washington, D.C., 

14 at 9:04 a.m., Douglas Brookman, Meeting Facilitator,

15 presiding.

16 

17 PRESENT:

18 DOUGLAS BROOKMAN, Meeting Facilitator

19 BRYAN D. BERRINGER, Project Manager,

20 DOE

21 ASHLEY ARMSTRONG, DOE

22 SARAH BUTLER, Office of General Counsel, DOE
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1 ALEX KROWKA

2 JAMES BATTAGLIA, Associate Director, Energy,

3 Navigant Consulting, Inc.

4 JUDITH REICH, Associate Director, Energy,

5 Navigant Consulting, Inc.

6 CHARLIE STEPHENS, Senior Energy Codes and

7 Standards Engineer, Northwest Energy

8 Efficiency Alliance

9 NATE MOUW, Director, Regulatory Affairs, Whirlpool

10 Corp

11 JOANNA MAUER, Technical Advocacy Manager,

12 Appliance Standards Awareness Project

13 SRIRAM GOPAL, Policy Analyst

14 STEPHEN B. LEYBOURN, Regulatory/Product Engineer,

15 Association of Home Appliance Manufacturers

16 DAVID DENKENBERGER, Ph.D., Technical Specialist,

17 ECOVA

18 MANFRED STAEBLER, BSH Home Appliance Corporation

19 MELISSA FIFFER, Appliance Product Manager, U.S. EPA

20 JESSICA M. LYMAN, Associate, ICF International

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1 WEBINAR ATTENDEES ON THE RECORD:

2 CHRIS BADGER

3 EILEEN EATON

4 JONATHAN GATZKE

5 CHRISTOPHER GRANDA

6 DANIEL LAPATO

7 RENATA MORTAZAVI

8 CURT TREMEL

9 RAVEENDRAN VAIDHYANATHAN

10 CHRISTOPHER WOLD

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

2 9:04 A.M.

3 MR. BERRINGER: Hello, everybody on the

4 line. This is Bryan Berringer for the DOE. We are

5 going to be starting in a couple of minutes here. I

6 think we have got everybody here, so we will just

7 start off with Doug.

8 MR. BROOKMAN: Good morning, everyone.

9 Welcome. Glad to see you here.

10 This is the Notice of Public Meeting

11 Residential Clothes Dryers Test Procedure. Today is

12 November 13th, 2014 here at the Department of Energy

13 in Washington, D.C. My name is Doug Brookman, Public

14 Solutions, Baltimore. Good to see you. We are going

15 to start off with welcoming remarks from Bryan

16 Berringer.

17 MR. BERRINGER: Yes. Again, my name is

18 Bryan Berringer. I am with the Department of Energy.

19 I have been with the Department for about 20 years

20 and today we just want to thank everybody. Is this

21 too loud for everybody? We just want to thank

22 everybody for participating today in person and also
5

1 on the webinar. I think we have about ten people on

2 the line here on the webinar, so thank you for your

3 participation.

4 This is really kicking off the test

5 procedure rulemaking for clothes dryers, so we are

6 really looking today to get your input to talk about

7 potential changes on what we need to do to make the

8 test procedure a better test procedure today. So we

9 are really looking later on to have an open

10 discussion, round table discussion, about what's

11 going on with the clothes dryer test method. Again,

12 these test methods will be used for the energy

13 efficiency rating for Federal standards and also for

14 the ENERGY STAR program.

15 Again, are there any questions or

16 comments about what we are doing here today? Okay.

17 Why don't we go back to Doug and we'll just do some

18 introductions and review.

19 MR. BROOKMAN: We always start with

20 introductions, names and organizational affiliations.

21 There are no microphones. We'll just use our outdoor

22 voices today.
6

1 MS. BUTLER: Sarah Butler, DOE.

2 MR. STEPHENS: Charlie Stephens,

3 Northwest Energy Efficiency Alliance.

4 MS. MAUER: Joanna Mauer, Appliance

5 Standards Awareness Project.

6 MR. DENKENBERGER: David Denkenberger,

7 ECOVA, representing California Investor Owned

8 Utilities.

9 MS. FIFFER: Melissa Fiffer, EPA, ENERGY

10 STAR Appliances.

11 MS. LYMAN: Jessica Lyman, ICF

12 International in support of ENERGY STAR Appliances.

13 MR. KROWKA: Alex Krowka.

14 MR. STAEBLER: Manfred Staebler, BSH

15 Homes Appliances.

16 MR. LEYBOURN: Stephen Leybourn. I'm

17 with the Association of Home Appliance Manufacturers.

18 MR. MOUW: Nate Mouw with Whirlpool.

19 MS. REICH: Judith Reich from Navigant

20 Consulting.

21 MR. BATTAGLIA: James Battaglia from

22 Navigant.
7

1 MR. BROOKMAN: Thank you. All of you

2 received a packet of information when you came in the

3 door, I hope. There is an agenda on Page 3.

4 Immediately following this agenda review, there is an

5 opportunity for opening remarks, brief summary

6 comments here at the outset about issues that matter

7 to you. Moving from there, we will have presentation

8 and discussion on regulatory history and background,

9 and directly from there, potential test procedure

10 changes and discussion. We'll see how it goes.

11 Probably we will take a break mid-morning somewhere

12 in there around about 10:30 or so.

13 As reflected in the agenda, at the end

14 of the day, whenever we get through all this

15 material, there is yet another opportunity for

16 comment. You get another opportunity for you to

17 raise any additional issues you think have not been

18 covered sufficiently during the course of the

19 discussion this morning.

20 We welcome all of you that are joining

21 us via the web, and you're going to have an

22 opportunity to participate during the meeting today,
8

1 but the ground rules, as reflected on Page 2, I would

2 ask that each one of you please speak one at a time.

3 Please say your name for the record each time you

4 speak.

5 There will be a complete transcript of

6 this meeting. If you could be concise, share the air

7 time and turn your cell phones on silent mode.

8 Please limit sidebar conversations.

9 Webinar participants, if you would turn

10 your phone on mute, if you would raise your hand in

11 the software provided, we hope that you might be able

12 to speak in the room. Sometimes that doesn't work.

13 As I understand it, the audio is iffy today, so it

14 may not work, but we will get your comments and your

15 questions. Our web master will write them up

16 and we will include them in the discussion here.

17 And then, as I said, this meeting is

18 provided live via the internet. The webcast is made

19 available to accommodate all the stakeholders who

20 can't attend the public meeting in person, and the

21 Department of Energy makes a special request. Those

22 that are joining the meeting via the web, the
9

1 Department still wants you to submit your written

2 comments. So please do that in addition to

3 participating this morning.

4 Do you want to do the purposes of the

5 meeting?

6 MR. BERRINGER: Yes, I can do that.

7 Again, just we're on slide 5. Just the

8 purpose of the meeting, again, just is to talk about

9 potential changes to the current test procedure for

10 clothes dryers, discuss the next steps in the

11 rulemaking, invite participation to provide summary

12 comments or statements that arise for additional

13 issues and discussions.

14 And we, the comment period, we invite

15 comments that, written comments, to anything if we

16 don't get a chance to talk about it today, by

17 December 15th, we would like written comments.

18 There is also a question on the webinar,

19 are we going to talk about changes to D1 and D2?

20 Yes, we have sort of a comparison or summary slides.

21 We weren't going to go into detail on all that, but

22 really today we are looking at having an open
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1 discussion of where we need to go for the test

2 procedure test method for the future moving forward.

3 We also -- that was a question on the

4 webinar. Any other questions at this point? Okay.

5 At this point I think we are going to,

6 we have stakeholder opening remarks. I know that

7 Charlie Stephens had some opening remarks, and I know

8 Joanna from ASAP also had some opening remarks, so I

9 am going to go ahead and turn it over to, and also,

10 if we have questions on the webinar, we will invite

11 those at this time, too, for opening remarks.

12 So at this time, I will ask Charlie to

13 go ahead. You had a presentation you wanted to do

14 for us here? And we'll get that up. Very good job.

15 It's all yours.

16 MR. STEPHENS: Good morning. I'll stand

17 away from this thing just a little bit.

18 We have been doing quite a bit of

19 research at the Northwest Energy Efficiency Alliance

20 on laundry and especially dryers, have done a lot of

21 field research, have done a lot of lab research with

22 some contractor folks who have gotten very
11

1 intelligent about dryers, and what I am going to show

2 you here is mostly based on that field research and

3 what we have been doing recently to imagine what that

4 might mean for a better test procedure that's more

5 reflective of what we find in the field.

6 These are all pictures, and they're all

7 meant to be nothing more than conversation starters

8 here today. I'm not going to make any hard

9 recommendations. I'm just going to show you kind of

10 the differences that we see in the field and in our

11 data.

12 First of all, we have been working a

13 little bit in the lab, as I said, and these are some

14 of the dryers we've tested. We're testing some newer

15 technology. We're testing some regular standard type

16 dryers. Some are ENERGY STAR rated and some are not,

17 but we're testing a whole bunch of them.

18 This is using the D2 test protocol, and

19 this is the CEF ranges that we're getting. You'll

20 see down there Federal Minimum at the bottom and the

21 kind of range that you see in what we're testing.

22 Now, watch the slide shift here. Do you
12

1 want to see that again? This is what we're calling

2 the Utility CEF, which is what happens to the CEF

3 numbers when we add a test that more resembles the

4 clothing you see in the field.

5 It's an evenly weighed set of tests. It

6 actually utilizes D2 and the DOE test cloths, as well

7 as some test with heavier clothing.

8 So as you can see, the CEF ranges drop

9 pretty much across the board, though some drop a

10 little less than others, which is interesting.

11 We also are testing small loads, average

12 or medium loads and large loads and looking at the

13 differences there, and I think you may find that the

14 differences are kind of startling here, as well.

15 This is a small load of real clothing,

16 normal cotton setting, and you can see that the CEF

17 is not very good.

18 This is a large load. Do you want to

19 see that again? Small, large. So it turns out that

20 the size of the load matters a lot in terms of the

21 impact on the efficiency with which the dryer dries

22 the clothes.
13

1 I say all this because of this next

2 slide. This is a matrix from the field, from the

3 field data that we have. We got really good data

4 from 46 households out of 50, so this is what you're

5 seeing here.

6 As you can see, the load weight, this is

7 the dry weight but not the bone dry weight on the

8 left, and you can see the temperature setting on the

9 dryer, low, medium and high across the top, and you

10 can see the matrix of just what kinds of loads people

11 actually wash and you can see that the heaviest loads

12 on high heat are only 6.7 percent of the loads that

13 were done in the field.

14 The DOE load falls in that one box right

15 there on the right middle. 13.1 percent of the loads

16 were -- could be characterized that way, not very

17 many, not a very big fraction.

18 A larger fraction was medium heat in the

19 medium size range, but you can see that the medium

20 heat was kind of the largest fraction all through,

21 but you can also see that high heat on a small load

22 was very much a big fraction of the way people did
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1 their laundry.

2 This is clothes, going back to clothes

3 washer here, because we believe that some of the

4 changes we may discuss will imply changes to the

5 clothes washer test procedure, as well, this is

6 clothes washer load size versus drum volume.

7 MR. BROOKMAN: Say how you set up these

8 individuals to test --

9 MR. STEPHENS: You don't want to know.

10 They -- we made all these participants weigh their

11 laundry three times with every load for a month and

12 keep a logbook and tell us how they set their

13 equipment, whether they took stuff out, whether they

14 used dryer sheets. It's a -- the study report on

15 that my editors tell me will be done Friday, maybe

16 Monday, and I will distribute it to everybody and it

17 will also be available on our web site. It's about

18 150 pages, but it's all in there.

19 MR. BROOKMAN: Thank you.

20 MR. STEPHENS: This is from the field

21 data, as well. We assume that the clothes dryer drum

22 size kind of goes along with the clothes washer drum
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1 size. If you buy a big washer, you'll probably have

2 a big dryer to go with it most of the time. So we

3 were looking for some sort of a statistical

4 correlation between the drum size of the equipment

5 and the load size, and there it is.

6 This is the annual laundry weight versus

7 the drum size. Our conclusion is there is no

8 correlation, so that's part of the conversation, too,

9 we think.

10 Again, from the field setting, here is

11 our dryer temperature and our dryness level settings.

12 They're not quite the way the test procedure

13 specifies as present.

14 This is the air flow rates. You can see

15 the typical DOE air flow rate, which is set in the

16 test procedure, and you can see where the real air

17 flow rates came out. Our lowest air flow rate in the

18 field before we corrected it was 6 CFM.

19 There's no comment on this particular

20 product. It's a very nice product, but what we're

21 pointing out here is the way products are labeled and

22 set up for cycles. They're getting more complicated,
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1 and there are many more combinations of cycles that

2 people can chose and, quite frankly, we're not sure

3 what they will chose so a lot of our field research

4 going forward in the coming year and going on right

5 now, in fact, is going to try to get at what cycles

6 people actually end up picking to do their laundry

7 under what circumstances.

8 We're not done with our research, so --

9 but one of the biggest issues is, what cycles are

10 people actually going to pick out of the many they

11 have and for which kinds of loads and what does that

12 do to the CEF?

13 This is our further testing. We've

14 already done eight non-ENERGY STAR dryers, three

15 ENERGY STAR dryers and a gas dryer. We're

16 collaborating with PG&E in California to do this

17 work.

18 Round 2 in 2015, we haven't set up the

19 actual schedule yet. The labs are pretty busy. But

20 we're going to be testing quite a few more dryers in

21 2015 and we are going to be putting more dryers in

22 the field. We have ten in the field now that we're
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1 monitoring, getting ready to monitor.

2 So anyway, that's all I have today.

3 These are the things we think we need to be talking

4 about today.

5 MR. BROOKMAN: Thank you.

6 Let's have other opening remarks here at

7 the outset. Joanna?

8 MS. MAUER: I just wanted to first thank

9 DOE for holding this meeting today. For a long time

10 I think we thought that there wasn't much that could

11 be done to reduce clothes dryer energy use, and we

12 now know that clothes dryers represent a really large

13 potential savings opportunity, but a key step to

14 achieving significant savings from clothes dryers is

15 having a good test procedure that can serve as the

16 basis for standards, so I think the time is ripe to

17 consider amendments to the test procedure in advance

18 of the next clothes dryer standards we're looking at.

19 So thanks again for holding the meeting

20 and I look forward to the discussion today.

21 MR. BROOKMAN: Thank you. Additional

22 comments here? Dave?
18

1 MR. DENKENBERGER: Dave Denkenberger,

2 California IOUs. I'll be talking about building on

3 recent DOE work to increase the realism of the test

4 procedure and utilizing a source energy metric.

5 We applaud the DOE for investigating

6 test procedure revisions to more accurately capture

7 the real-world energy use of clothes dryers.

8 DOE has taken an incremental step

9 towards the test procedure that measures different

10 settings and load compositions. In particular, the

11 AHAM 1992 load uses realistic clothing with a

12 diversity of thickness.

13 We encourage the DOE to consider further

14 opportunities to a create test procedure that is even

15 more representative of real-world use in

16 collaboration with Northwest Energy Efficiency

17 Alliance.

18 We have developed four supplemental

19 tests to the D2 test procedure. The goal was to be

20 able to ensure the repeatability of the test

21 procedure and keep the testing burden low, better

22 matching the test procedure's real-world use and
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1 differentiating dryer energy performance.

2 Our test approach also eliminates

3 potential gaming associated with testing a single

4 cloth composition, dryer setting configuration and

5 laundry load size.

6 As there are a total of four

7 supplemental tests, the load we chose was more

8 challenging, including jeans. As Charlie mentioned,

9 two of the supplemental tests, one were a large load

10 and one was a small load. Then there was the third

11 test was a medium-sized load but tested on the

12 dryer's most efficient eco setting, and we feel this

13 is important because eco mode can take up to three

14 times as long to dry, and for this reason, we

15 strongly recommend reporting dryer times of all

16 tests.

17 And the fourth supplemental test is a

18 medium-sized load of realistic clothing that is run

19 using settings that dry the clothing at the fastest

20 rate.

21 To support repeatability of the test

22 procedure, we propose a weighted average of D2 and the
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1 four supplemental tests, and overall, this has better

2 repeatability than single tests.

3 While this test is not as repeatable as

4 existing D1 tests, some limited reduction in

5 repeatability is justified in order to get an

6 overall, more realistic representation of dryer

7 energy use to enable high efficiency technologies to

8 compete fairly against one another.

9 Currently, dryer manufacturers must

10 perform roughly three D2 tests. Our proposal is one

11 D2 test and four supplemental tests for a total of

12 five. While this would increase the overall number

13 of tests for a dryer, this is significantly less than

14 the number of tests required for a clothes washer.

15 We have evaluated this test procedure in

16 a variety of machines, as Charlie has mentioned, and

17 we feel this test procedure should also more

18 accurately capture the real-world savings of

19 technologies that have not yet been commercialized,

20 such as exhaust heat exchangers.

21 We also encourage DOE to enable a

22 comparison of dryers with different fuel types by
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1 incorporating the use of source energy as the metric

2 for comparing dryers.

3 Natural gas represents an interim

4 technology step, especially in new construction that

5 uses similar source energy as today's heat pumps but

6 is more cost effective and enables faster drying

7 time.

8 Alternatives to source energy

9 comparisons could be based on energy costs for

10 greenhouse gas emissions.

11 We also invite the DOE to consider an

12 integrated washer-dryer test procedure. Using the

13 same realistic clothing load we developed for dryers

14 would provide additional data on real-world washer

15 performance.

16 Furthermore, manufacturer test burdening

17 can actually be reduced because the clothing could go

18 directly from the washer to the dryer, avoiding the

19 labor intensive step of wetting the clothing for the

20 dryer to tight tolerances.

21 Also synergies between the washer and

22 dryer in terms of energy efficiency and cycle time
22

1 could be better understood.

2 To summarize, we encourage DOE to build

3 on its recent work to test dryers with a variety of

4 load sizes, settings and clothing compositions.

5 Considering source energy would also make for a more

6 fair comparison between dryer technologies.

7 Combining the washer and dryer test procedure would

8 enable even more realism.

9 We thank the DOE for having this meeting

10 and for the opportunity to speak.

11 MR. BROOKMAN: Thank you, Dave. Will

12 you submit those written comments?

13 MR. DENKENBERGER: Yes.

14 MR. BROOKMAN: Thank you. For the

15 record, thank you.

16 Other comments here at the outset,

17 opening remarks, any additional? Okay.

18 Let's proceed with the presentation

19 material. Those of you that are joining us via the

20 web, we also welcome your comments and questions as

21 we're going along today, just to be clear.

22 MR. BERRINGER: We're just going to
23

1 briefly go over some of the regulatory history and

2 background and again, there was questions about D1,

3 D2.

4 So again, just as far as history, back

5 in January 2011, D1 was created, measuring, included

6 measuring standby and off mode, defining a new energy

7 efficient metric that combined energy factor and

8 reflecting changes to consumer usage habits, which we

9 talked about a little bit today, such as the initial

10 moisture content, the number of cycles per year and

11 the test size load.

12 Then in August of 2013, there was

13 amendments to D1 to update the reference to the

14 latest IEC Standard 62301, also amended D and D1 to

15 clarify certain test conditions and created D2 to

16 measure the effects of the automatic cycle

17 termination.

18 I'm not going to read all these. I know

19 there is questions about this. This is giving

20 background, sort of comparison between D1 and D2.

21 This particular slide, most of the standby and off

22 mode was using IEC 62301. It is incorporated by
24

1 reference. The number of cycles was 283 in both

2 cases, and the reference test standard was the AHAM

3 HLD-1-2009. And the other one test load weights and

4 detergent and other things didn't really change

5 there.

6 The next slide, there was a little bit

7 of difference as far as some of the things as far as

8 the cycle and setting tests used, the RMC loads which

9 we used in the test and the cool downs, so there were

10 some changes there.

11 Are there any questions as far as

12 between D1 and D2?

13 MR. BROOKMAN: This is a good slide.

14 This is a good explanatory. This is good.

15 MS. ARMSTRONG: Ashley.

16 This is just a high-level summary.

17 Obviously, if you're running the test, you need to

18 refer to the actual language in the test procedure,

19 but this is just a high-level summary of what is in

20 D1 and D2. We don't plan to talk about D1 and D2

21 today. We're moving forward and not looking back.

22 So the purpose of today is really about what the next
25

1 step is, and as Joanna said so nicely, it is -- DOE

2 has triggered in a not so long time to start up a

3 standard rule. We have heard some feedback on the

4 dryer test procedure and we're really looking for

5 starting points and buy-in now, early in the process,

6 as we move forward with this test procedure revision

7 or at least evaluating whether there should be a test

8 procedure revision, kind of what the purpose of today

9 is.

10 MR. BERRINGER: I'll show one last slide

11 here comparing D1 and D2 again, as Ashley said, high

12 level, but again, in this particular case, there were

13 cool down and field use factors, there were some

14 changes there. There was no field use factors used

15 in D2.

16 So with that said, there really is, as

17 Ashley just reiterated, the reason for the further

18 discussion is for interested parties to have comments

19 about the clothes dryer tests that may not produce

20 results that are representative of consumer use with

21 regard to test load size, composition cycles of

22 settings for the test cycles and other provisions for
26

1 the test procedures.

2 Manufacturers have mentioned that test

3 load types and test cloth are different for those

4 specified in DOE test procedure, do not result in

5 repeatable compared to those using the test load, so

6 we do have, for consistency and for results, we have

7 used the test cloth for the dryer test, so that's

8 something we can bring up as far as it was already

9 brought up as far as opening remarks, as far as

10 discussion, and also DOE is interested in finding

11 solutions to what works for all parties which provide

12 test procedure that differentiates products on the

13 market and provides consumer information about dryer

14 usage as seen in the field and is repeatable and

15 reproducible.

16 Also, just a little bit of background.

17 We provided this as far as the notice, just the

18 recent work that was done at Oak Ridge and PNNL. We

19 have backup slides. We weren't going into detail

20 about that. The web sites are there. If you haven't

21 seen the reports or downloaded them, you can look at

22 those, but basically, characterize the current
27

1 clothes dryer performance using D1 and D2 with

2 different test loads and evaluated the current

3 automatic cycle termination sensors and potential

4 energy savings through improved sensors and control

5 strategies.

6 So and again, Oak Ridge and the PNNL

7 report are available for review and discussion. Were

8 there any comments about those particular reports in

9 general, about what was done in those studies?

10 (No response.)

11 MR. STEPHENS: It's good.

12 MR. BROOKMAN: It's good.

13 MR. STEPHENS: It's useful. It's useful

14 work.

15 MR. BROOKMAN: Thank you.

16 MR. BERRINGER: I guess we're going to

17 go ahead and move to our next and really what we are

18 looking for today is discussion.

19 Would you like to like to sit here.

20 MR. BATTAGLIA: I can come up.

21 MR. BERRINGER: I can bring it down

22 there.
28

1 MS. ARMSTRONG: This is where you guys

2 get to speak up instead of just staring at us the

3 whole time. Because really, this meeting is for you.

4 It's an opportunity for you to inform DOE's decisions

5 early on in the process, so we're going to key up

6 issues. We have some slides. If you don't see what

7 you're looking for, feel free to chime in, but you're

8 really, I mean, typically, how this works is early on

9 in the test procedure rulemaking, we'll pull a bunch

10 of units off the market and start testing. We'll do

11 investigative testing to figure out what we are, the

12 path we're going to start looking down and compare a

13 little bit a couple of different methods, a couple

14 different options.

15 This is your chance to chime in on that.

16 So we're looking for feedback at this meeting. This

17 is kind of a new way of doing things. DOE hasn't

18 typically held these types of meetings always for

19 test procedures, but since people seemed to have a

20 lot of opinions about dryers, we thought this might

21 be a good way to start off the process for this one.

22 MR. BROOKMAN: That was Ashley
29

1 Armstrong.

2 MS. ARMSTRONG: So obviously, you don't

3 have to have the same opinions. You don't have to

4 share common opinions, but we're interested in all of

5 them.

6 MR. BROOKMAN: James Battaglia.

7 MR. BATTAGLIA: Yeah. So we're going to

8 talk through, we've put together a few slides for a

9 few of the key issues that have come up in the past,

10 but by all means, bring up any other issues as we go

11 through. We have a section at the end asking for

12 anything else, so don't feel like it's limited to

13 discussing what we have put together here.

14 MR. BROOKMAN: One question here at the

15 outset, Chris Badger asks -- I think it's Badger --

16 Will the data be made available in digital format?

17 MS. ARMSTRONG: The data from the PNNL

18 and Oak Ridge studies?

19 MR. BROOKMAN: I think that's what he

20 was referring to.

21 MS. ARMSTRONG: I doubt it. I don't

22 think we had any intention of making it available. I
30

1 don't know. We hadn't gotten a request for it, so I

2 hadn't really thought about it. I mean, the report

3 have pretty detailed descriptions of the data and the

4 results so --

5 MR. BROOKMAN: Thank you, Ashley. Okay.

6 Back to James.

7 MR. BATTAGLIA: So first topic of

8 discussion was the composition of the test load, and

9 a few people have mentioned this already, but just to

10 highlight, the current provisions, the current test

11 method has 24- by 36-inch test cloth. It's made up

12 of 50/50 cotton/polyester blends, and here I guess

13 we're opening up the discussions for what

14 alternatives we should be considering.

15 We just highlighted a few that people

16 have mentioned, the AHAM 1992, which is made up of

17 towels, t-shirts, shorts and a few other components

18 and also the AHAM 2009 load, which is bed sheets,

19 pillow cases and towels.

20 And we just included a visual from a

21 NEEA report just to show on the left is the AHAM 2009

22 and on the right is the 1992 load.
31

1 MR. BROOKMAN: Let's get comments here

2 on test load composition. Do you like the current

3 composition?

4 MR. STEPHENS: By itself, no.

5 MR. BROOKMAN: You see, that's what I

6 wanted to hear.

7 MR. STEPHENS: Yeah. I think -- Charlie

8 Stephens from NEEA.

9 I think we've concluded that while the

10 current test load is not useless, it actually could

11 represent a fairly broad swath of the kinds of loads

12 that consumers actually do. They're in there. It's

13 representative.

14 But we're missing some. We're missing

15 the heavy stuff, and we'd agree that the variability

16 in those tests is higher typically from what we

17 found, but as Dave suggested, we also think that if

18 it only has a certain amount of weight in the total

19 CEF certified, then that greater amount of variability

20 for one or two of the tests is not going to result in

21 a huge variability in what's certified as a CEF.

22 But it will, we think, I think -- I'm
32

1 trying to remember my report that I just edited here.

2 I believe the difference between our field CEF and

3 the rated CEFs that we came up with after D2, this is

4 looking CEF from D2, was about 13 to 15 percent.

5 So it's not a huge discrepancy, but it

6 turns out that that's, you know, that's a quarter of

7 what it referred to rated uses in a year based on our

8 field data, so it's not a small discrepancy in terms

9 of what the annual energy use is of a dryer.

10 And so we think it ought to be

11 corrected, especially, we think, because some

12 products, some dryers, some models, may do better and

13 some cycle management, some controls, may do better

14 at drying these heavier clothes than others and we

15 would like to see those differences show up in the

16 ratings for the dryers.

17 MR. BROOKMAN: Can you be specific about

18 how you would like the load to change?

19 MR. STEPHENS: As Dave suggested, we've

20 tested four different loads using real clothing, a

21 small one, a large one, an eco mode, which is the,

22 it's either the mode that the manufacturer says is
33

1 the default energy efficient mode or it's the most

2 efficient mode available on the dryer.

3 Then we tested it with the fastest mode,

4 which tends to be just electric resistance like a

5 typical dryer with auto termination in the dryers we

6 tested. So we've tested, we've done four, four

7 different tests with real clothing to see if we can

8 find relationships among these things.

9 We're not necessarily at this point

10 prepared to say that you need to do all four, but

11 we're suggesting that somewhere in there, at least

12 two maybe of those tests could be critical as some of

13 the tests you would do, given appropriate weights in

14 a matrix of what consumers do that would result in a

15 rating that was more reflective of how the thing will

16 actually work in the field.

17 MR. BROOKMAN: Okay.

18 MR. STEPHENS: With regard to clothes

19 composition.

20 MR. BROOKMAN: We have a couple of

21 comments from individuals on line. Chris Badger

22 writes, "It will help develop a D2 baseline for
34

1 existing dryers," and Chris Wald from CLASP,

2 C-L-A-S-P, "Have you looked at the European test

3 load?"

4 MR. BATTAGLIA: So I think the

5 European --

6 MR. BROOKMAN: James Battaglia.

7 MR. BATTAGLIA: Yeah. Sorry. James

8 Battaglia. I guess the European, the IEC test

9 procedure in part uses a load composed of the AHAM

10 2009 load, I believe, and then they also have a 50/50

11 blend load, but I don't think we've looked at, DOE

12 hasn't looked at that, at least.

13 MR. STEPHENS: Well, one of the chief

14 difference, too, in the IEC load is not just the

15 composition. It's also how big it is.

16 They do essentially a sliding scale.

17 It's a formula for how large the load is, one of the

18 loads is, that you test, and the bigger the machine,

19 the larger the load of that particular fabric mix.

20 I've got a slide somewhere of that, but

21 so there are some differences in composition.

22 We, we evaluated that. I think Dave,
35

1 you guys looked at the IEC load awhile back.

2 MR. BROOKMAN: So that was Dave. That

3 was Charlie and now it's Dave. Now to Dave.

4 MR. DENKENBERGER: Yeah. So the, as we

5 said, the AHAM 2009 and IEC loads are similar, at

6 least in terms of composition.

7 They -- the cotton IEC load, that is.

8 So we think it provides some diversification from the

9 DOE load because of it being 100 percent cotton, but

10 we found that the thicknesses were very similar of

11 the three articles so it's less challenging because

12 the articles would tend to dry at the same rate and

13 that's why we thought the AHAM 1992 load was more

14 representative, because it did have a diversity of

15 thicknesses and was higher cotton content.

16 MR. BATTAGLIA: So Charlie, I just have

17 a question.

18 MR. STAEBLER: This is Manfred Staebler

19 from BSH. Like I said, I'm not a dryer specialist,

20 but I have a question concerning the test load and

21 the drum size.

22 You know, you mentioned you know in
36

1 Europe they have this kind of sliding scale. What do

2 we have here or what do we intend here? Do we have,

3 you know, this sliding scale because we have

4 different volumes of dryers, and if this is of

5 influence, if you want really to compare how

6 efficient is the dryer, would it make sense to have

7 that sliding scale of test load or do you always have

8 a fixed test load no matter what volume the dryer

9 has?

10 MR. BATTAGLIA: Yes. I guess that's one

11 of the questions we're teeing up, and based on the

12 data that Charlie presented, it looked like it wasn't

13 really much of a correlation between washer volume

14 and the size of the loads people were washing, so I

15 guess I'm throwing it back to you guys.

16 Do you think there should be a sliding

17 Scale?

18 MR. STAEBLER: Maybe I have to correct

19 myself. It's not the correlation between washer and

20 dryer. It is the correlation you have different

21 dryer sizes.

22 MS. ARMSTRONG: Yeah. I think what
37

1 James is trying to say is that in the field -- you

2 correct me if I'm wrong -- but Charlie presented that

3 if you're actually trying to emulate consumer usage,

4 there was no real correlation between the load sizes

5 that consumers put in the drum versus the sliding

6 scale or the larger size of the drum itself.

7 So you know, the sliding scale, does it

8 really mean consumers are going to, you know,

9 actually dry a larger load? The answer it seems to

10 be is no. And maybe a fixed size is representative

11 more of what consumers would do or a multiple,

12 multiple fixed size loads rather than the sliding

13 scale based on dryer drum capacity.

14 MR. STEPHENS: For clothes washers,

15 there is a large load that's done in addition to the

16 standard size load. In dryers, it's 8.45 pounds.

17 Our average load in the field was a little under 8

18 pounds, like just a hair under 8 pounds, not a huge

19 divergence.

20 MS. ARMSTRONG: Right. So I would say

21 that's pretty close.

22 MR. STEPHENS: But the variance was
38

1 huge, and again, more important to us was the matrix

2 of, if you compartmentalize those things into small,

3 medium and large and low, medium and high heat and

4 you look at how people do their loads, there were not

5 very many big loads on high heat.

6 There were actually far more smaller

7 loads than we were expecting. That was the big

8 surprise in our study.

9 MS. ARMSTRONG: You need to come

10 instrument my house now that I have two little

11 children and no time on my hands, and you would get

12 your high heat large loads real quickly for your data

13 set. I'll be your 51st person.

14 MR. STEPHENS: Well, we have some of

15 those.

16 MR. BROOKMAN: You should be in my

17 house, with two of us.

18 MS. ARMSTRONG: I cram it in whenever I

19 have time.

20 MR. BROOKMAN: High heat. Okay. That

21 was Charlie Stephens. Now Nathan.

22 MR. MOUW: Yes. Since we're referencing
39

1 the data in the meeting, can you tell us a little bit

2 about how it was sampled, where you tested, how you

3 selected the participants, how you --

4 MR. STEPHENS: Sure. They were, the

5 participants were drawn from the larger residential

6 building stock assessment sample, which started out

7 with 1,400 households, and then we did subsets of

8 those, and so we looked for a sample large enough to

9 give us a 90/10 confidence interval on the data, so

10 we wanted some statistical significance.

11 We have all the demographics that go

12 along with this. We had all the demographics for

13 those 1,400 households and by age and everything in

14 the demographics. So we tried to get that right.

15 The only place where we skewed the data

16 was because we wanted the data to be relevant going

17 forward for as much as possible, so we selected for

18 equipment that was 2005 or newer.

19 So 30 percent of the equipment was top

20 loading and 70 percent was front loading, so you

21 know, it's kind of a, that's kind of how it is out

22 there.
40

1 MR. MOUW: Were they in one select

2 region or were they nationwide?

3 MR. STEPHENS: They were in four states

4 in the Pacific Northwest. Dryer performance we think

5 probably will vary by portions of the region or

6 different parts of the country, so we're not

7 maintaining that it's representative country wide,

8 though in terms of demographics, we're probably not

9 too different except for select places.

10 MR. MOUW: Demographics associated

11 with --

12 MR. STEPHENS: Household size, you know,

13 and what kids wear and that sort of thing. You know,

14 sheets are sheets and towels are towels probably

15 nationwide. How many do you wash and what your

16 relative humidity is where you live and what altitude

17 you're at, that sort of thing, will vary a little

18 bit.

19 MR. MOUW: Yeah. I just want to make

20 sure we're all aware of the context of the data the

21 reference is making.

22 MR. STEPHENS: Yeah. And it was done
41

1 over a four-week period in the, kind of the shoulder

2 period between about February and the end of April in

3 these households. They kept a log.

4 We measured the clothes washer as well

5 as the dryer to make sure we could correlate load

6 versus cycle as best we could. The keeping of the

7 log made that good or bad in some households, but

8 that was kind of important, because we're discovering

9 in all of our metering now that I'm doing where I

10 always meter the washer and the dryer, we're

11 discovering there's a large discrepancy between loads

12 and cycles.

13 We measure the loads in the clothes

14 washer and we measure the cycles in the dryer, and

15 they're not at all the same. So people split loads,

16 which is the biggest thing going on from what we can

17 see.

18 MS. ARMSTRONG: Wouldn't you assume --

19 this is Ashley, and I have no good data study other

20 than my own usage, but I definitely don't dry all my

21 clothes. You know, I do hang a significant portion

22 of my clothes coming out of my washer up, so my dryer
42

1 load is different always than my washer loads.

2 MR. STEPHENS: I think we found

3 something on the order of 9 percent of washer loads

4 were not dried, but we also found that many loads

5 were -- had multiple cycles, up to four cycles for

6 the same load, ostensibly because it wasn't drying.

7 We found very little difference in the

8 dryer energy use between manually terminated or timed

9 drying and auto sensing. We -- there were a lot of

10 things.

11 We found, except in the initial part of

12 the cycle, there was, over the remainder of the

13 cycle, almost no difference between the actual heat

14 produced by the dryer and the setting between medium

15 and high heat. So they were within ten degrees. The

16 temperature was within ten degrees no matter what you

17 chose.

18 There were different cycling behaviors

19 of these things. We found that standby energy

20 consumption was very low for dryers. It was more

21 significant in clothes washers, but we think that's

22 changing.
43

1 There were a lot of things that kind of

2 startled us. The report has all the data in it.

3 We've separated it into groups so that you can see

4 the differences.

5 MR. MOUW: What was surprising, I guess,

6 as a result of this?

7 MR. BROOKMAN: Nathan, louder.

8 MR. MOUW: Okay. What were we

9 surprised about from the study?

10 MR. STEPHENS: We were surprised I think

11 first and foremost by the number of smaller loads

12 that people were actually doing. We expected people

13 would be filling the machines, and we thought there

14 might be more correlation between the size of the

15 machine and the loads that people were doing, and

16 that correlation really wasn't there.

17 The variance didn't surprise us.

18 There's a huge variance in how people do laundry and

19 load size and composition and everything else, but we

20 also were hopeful that with the right tweaks to the

21 test procedure, we could probably come out with

22 something that, on average, would result in our being
44

1 able to hit the field numbers pretty well. We think

2 we can do that, and our lab testing was aimed that

3 at.

4 MR. BROOKMAN: We have a few comments

5 from individuals joining us via the web. The first

6 is from Ravee Vaidhyanathan, who wishes to be unmuted

7 and to speak. Let's try it, Ravee, and see if it

8 works.

9 MR. VAIDHYANATHAN: Thank you. Thank

10 you for not trying to pronounce the last name.

11 Can you hear me okay?

12 MR. BROOKMAN: Yes. You sound good.

13 THE WITNESS: I have a few comments on

14 the load discussion here. One is the AHAM 1992. I

15 think probably we know that in our test load, there

16 was no way to get a consistent and standard load in

17 that configuration. I think that is saying from the

18 past experience. The loads they are applying from

19 different sources and all these in the past that is

20 fairly difficult to maintain consistency in terms of

21 characterization.

22 So that is one, one information. Then
45

1 on the AHAM 2009, it is similar to the IEC load that

2 is used today for the laundry, both washers and

3 dryers. The IEC load is pretty stable, but there

4 are, too, some concerns in terms of how the drying

5 moisture content and all the other things and how it

6 changes over time.

7 So I think basically I’m in the group the

8 washer standard looks at in IEC. I think the report

9 says, so within the group, now I wanted to

10 communicate this to the audience here, within this

11 group, there is an idea to come up with a different

12 load size which is the same as the Department of

13 Energy load, 50/50, I know planned load, but they are

14 looking into, they are looking into having not the

15 same size pieces put together but pieces that

16 normally are smaller than larger, not in combination.

17 So the main reason know why the group is

18 looking at this and also two issues. One is the cost

19 effect. The other one is notice the characteristics

20 and the moisture updates and the old release, the

21 changes over repeated use. You are trying to use a

22 test load multiple times, so today, there are some
46

1 issues and you will see 100 percent cotton loads, so

2 how we can extend the life of use of the test loads.

3 Momie load seems to be more stable, so that's why the

4 group is working on coming up with an alternate load

5 composition because it's the same as the 50/50 cotton

6 blend and loads but having different items put

7 together.

8 It's still a concept at this stage, and

9 I think that we can share some information. I can

10 check and we can share some information at this time.

11 I will say that DOE probably should at this also and

12 the consistency we are looking at the load. (Sic)

13 thank you.

14 MR. BROOKMAN: Thank you. Thank you,

15 Ravee.

16 We have some additional comments from

17 individuals joining us via the web. This one is from

18 Chris Badger who says, "Should there be alignment

19 with the clothes washer test load that incorporates

20 three separate load weights (minimum, average,

21 maximum) based on capacity of the washer/dryer?"

22 And?
47

1 MS. ARMSTRONG: Well, I'm going to turn

2 it around and I am going to argue why? I mean, it

3 seems that we've just proved that the dryer, A, that

4 there is no correlation between the load size and the

5 dryer and the drum size from the field study and then

6 B, that the load size from the washer to the dryer is

7 different.

8 Now, maybe it's a percentage difference,

9 but it is different. I'm not arguing that there

10 maybe shouldn't be multiple loads or at least

11 consideration of multiple loads for the dryer like

12 there is for the clothes washer, but identical loads

13 I think, there is, there may be a reason for them to

14 be different.

15 Now, if manufacturers for the purposes

16 of reducing burden want them to be the same, we could

17 consider something like that or -- you know. But I

18 don't think there is a strong reason technically to.

19 I haven't thought all the way through

20 it, and I'm not speaking on behalf of DOE as DOE's

21 opinion. I'm just trying to generate conversation

22 here, because everybody is staring at me.
48

1 MR. BROOKMAN: It's good, and that's

2 what this meeting is about. This is an exploratory

3 meeting. This is slightly different.

4 Jonathan Gatzke writes, "It should also

5 be noted that the AHAM 2009 load brings in a very

6 distinct and varied aging procedure for the load. 

7 This

8 mimics a more real-world mixed load."

9 Okay. So thank you for that. Chris

10 Badger I guess wishes to try and speak.

11 Chris, unmute your phone and hopefully,

12 we can hear you. We can't hear you yet.

13 MR. BADGER: Can you hear me now?

14 MR. BROOKMAN: Yes. Good. You're good.

15 MR. BADGER: Good.

16 MR. BROOKMAN: Speak.

17 We heard you and then you went away.

18 Now. Yeah. Good.

19 MR. BADGER: (Inaudible).

20 MR. BROOKMAN: It's garbled, Chris.

21 MR. BADGER: You guys hear me out there?

22 MR. STEPHENS: No.
49

1 MS. ARMSTRONG: No.

2 MR. BADGER: I think it's speaking to

3 the thing --

4 MR. STAEBLER: We can hear only alien.

5 MS. ARMSTRONG: Tell him we'll try him

6 again later, unfortunately.

7 MR. BROOKMAN: Chris, we'll have to try

8 you later or you'll need to write, send your note --

9 MS. ARMSTRONG: Yeah. Dial in the hard

10 line or --

11 MR. BROOKMAN: -- to the webmaster.

12 So that last round of commentary was

13 very helpful.

14 Dave.

15 MR. DENKENBERGER: Yes. So just to

16 comment on the aging procedure, so the DOE test

17 procedure says pre-condition the clothing and then

18 you can run it for 25 runs and you don't have to do

19 anything in the middle. You just have to bone dry it

20 every five runs.

21 But in the IEC, they actually want to

22 have the average age of the clothing to be constant,
50

1 that is, how many runs the clothes have experienced.

2 So that's what the person was referring

3 to, that you can't just start out with a run. You

4 actually have to beat it up a little with some

5 pre-runs before they're valid.

6 And just to clarify the work that we've

7 done for IOUs and NEEA, we followed the DOE

8 instructions when we used the IEC load, so we were

9 not doing this aging technique.

10 The other comment relative to the

11 discussion on the load size, to clarify, that the

12 NEEA field study was all on full-sized dryers and our

13 testing has all been on full-sized dryers and our

14 recommendations are based on that.

15 But the DOE test procedure has a

16 different load size for compact dryers, which I

17 believe are 4.4 cubic feet and smaller of a

18 three-pound load, and we just haven't investigated

19 that as much.

20 MR. BROOKMAN: Okay. Thank you.

21 Joanna?

22 MS. MAUER: This is Joanna.
51

1 I think we encourage DOE also to

2 consider a potential change to the clothes washer test

3 procedure. I think a lot of issues we're talking

4 about are relevant for both, and related to load

5 size, I mean, I think Charlie's field data suggests

6 that perhaps in the clothes washer test procedure, it

7 might make sense to consider fixed load sizes

8 independent of capacity, since that seems to better

9 represent what's going on in the field.

10 MR. BROOKMAN: Okay.

11 MR. STEPHENS: And, can I add one

12 thing --

13 MR. BROOKMAN: Charlie, please.

14 MR. STEPHENS: -- to follow up on what

15 was said a couple of comments ago?

16 What we believe from our own data is

17 that the variance of the dryer performance

18 efficiency, if you will, based on load size and the

19 literal ability of the dryer to dry a complex load of

20 stuff dwarfs the variability based on whether the

21 clothing in the heavier loads is exactly the same as

22 it was ten loads ago.
52

1 That is probably the smallest impact on

2 test results. Load size has a much larger impact, as

3 does, like I say, the ability of the dryer to manage

4 the drying process for a complex load that might be

5 large, especially.

6 MR. BROOKMAN: Manfred?

7 MR. STAEBLER: Yes. Just to understand

8 it right, we said before drum size and load size,

9 there's no correlation and we have a different load

10 for compact dryers. Why? Why don't we use the

11 compact dryer load in the large dryer, if there is no

12 influence? That would be, my question, you know?

13 And if there is, then we cannot say there is no

14 influence.

15 MR. BROOKMAN: Dave?

16 MR. DENKENBERGER: Yes. So the data

17 were based on all full-sized dryers, so we don't

18 know, if someone does have a very small dryer,

19 whether the load size would be smaller.

20 MR. STEPHENS: We would have to go find

21 some compact dryers. There are far fewer of them to

22 meter. It would have cost us probably half the cost
53

1 of the study to find them.

2 MR. STAEBLER: But when we come back, I

3 mean, to the test procedure itself, then the smaller

4 the load, the easier it would be to do the test. Why

5 should you use a bunch of clothes you don't need to

6 get the same results?

7 So my, my train of thought is, you know,

8 go to the smallest load possible, which is still

9 representative, and make the things easier than the

10 other way, you know, go to the biggest load possible,

11 you know, and you get actually the same result.

12 MR. BROOKMAN: Thank you, Manfred.

13 Charlie?

14 MR. STEPHENS: Well, we may -- Charlie

15 Stephens. We may actually get there, but we're doing

16 a lot of testing to find out whether you can actually

17 extrapolate what you get as a result in a small load

18 to a larger load.

19 It may be quite impossible to do that

20 with some products. It depends on what variance we

21 see in different products of the same size, same size

22 drum, same technology, in terms of whether it's a
54

1 heat pump or an electric resistance only or whatever

2 it is, hybrid or whatever. There may be vast

3 differences in how each of those handle a large load.

4 I don't know, but we're working on

5 finding out, and if there is a vast difference from

6 product to product, then no, you can't necessarily --

7 they might perform almost identically with a small

8 load. But you wouldn't necessarily want to

9 extrapolate that across the entire spectrum of loads

10 that it would have to deal with in order to get some

11 result.

12 We've, we've tried that with some other

13 products before, and that didn't work out too well,

14 either, so we're -- but believe me, if we can, if

15 that turns out to be possible and it will reduce

16 testing burden, you know, we're all for it.

17 MR. BROOKMAN: Another individual

18 joining us via the web, Renata Mortazavi, asks, "Why

19 don't we have the same test load and size as for the

20 washer test procedure?"

21 MS. ARMSTRONG: I think we've kind of

22 gone through that a little bit.
55

1 MR. BROOKMAN: Ashley says, yes?

2 MS. MAUER: Joanna. It seems to me like

3 the question may be, if we come up with what may

4 be a more representative load for dryers, should then

5 that be applied to washers, as well, and I think that

6 deserves some consideration.

7 MR. BROOKMAN: Renata follows on, "By

8 the logic, on the average, the same clothes go into

9 the washer go to the dryer," and so we covered some

10 of that in our earlier discussion, Renata.

11 MS. ARMSTRONG: Yeah. And I think that,

12 just to circle back, once again, I think to date,

13 and it is my opinion -- this is Ashley from DOE --

14 that not the same identical load goes from the washer

15 to the dryer for a number of different reasons, some

16 of which we've talked about earlier today.

17 So to the extent we have lessons learned

18 coming out of this meeting and things we should

19 consider for the future for clothes washers, that's

20 fine when we get to that point for clothes washers.

21 Luckily, we have this two-tiered

22 standard, so that's a little bit further out in space
56

1 for us. But when we get to that point, we can talk.

2 MR. STEPHENS: Though I think in our

3 study, 70 percent or more of the loads, of the loads,

4 were straight from the clothes washer into the dryer

5 with nothing removed.

6 MR. BROOKMAN: Thank you, Charlie.

7 MR. STEPHENS: And nothing split.

8 MR. BROOKMAN: Dave, do you want an

9 additional comment

10 here?

11 MR. DENKENBERGER: Yeah. To comment on

12 the stability of the loads, we, we've done a number

13 of loads that are 100 percent cotton, and we have

14 seen more lint production, but we actually did quite

15 a bit of work to monitor this and also do microscopy

16 to make sure that the clothing was stable, and we

17 found that it could be stable.

18 MR. BROOKMAN: Uh-huh. Okay.

19 MR. DENKENBERGER: For 25 runs.

20 MR. BROOKMAN: Maybe you're leading us

21 to the next slide, which is Alternative Fabrics.

22 We can continue.
57

1 MS. ARMSTRONG: Oh. Actually, I'm going

2 to go back for a second.

3 MR. BROOKMAN: Yes. Please do.

4 MS. ARMSTRONG: So what is the opinion

5 around the table on a single load versus multiple

6 loads?

7 MR. BROOKMAN: Nate?

8 MR. MOUW: Can I step back one step

9 further?

10 MS. ARMSTRONG: Yes. Please do.

11 MR. BROOKMAN: Nathan, please.

12 MR. MOUW: Thank you. We've been using

13 the term representative, and I guess I just want to

14 clarify amongst this group what we think that means.

15 Does that mean the inputs to the test or the output

16 from the test? What do we want to be representative.

17 MS. ARMSTRONG: You can't have it both

18 ways all the time.

19 MR. MOUW: Right. I mean, you know,

20 we're talking about representative fabrics, we're

21 talking about representative results. What is the

22 desired outcome? What is, what will this group
58

1 consider to be the desired outcome, if you had to

2 chose one?

3 MR. DENKENBERGER: Well, I think there's

4 a couple of answers on what. What is representative

5 on the output? One is matching field studies, which

6 I think is a good goal. The limitation in the field

7 studies so far, though, is that they're conventional

8 dryers. We don't have ENERGY STAR dryers or heat

9 pump dryers in the field yet.

10 So I think it's important to match what

11 consumers actually dry to have a better chance at

12 being representative of what the energy use is for

13 all technology types.

14 MR. STEPHENS: And we would agree that,

15 given the metric we have, just is pounds per kilowatt

16 hour, we would -- you know, I represent and Dave

17 represents a bunch of people who do kilowatt hours,

18 who provide those kilowatt hours and we're in the

19 business specifically at the Northwest Energy

20 Efficiency Alliance of essentially building power

21 plants or not building power plants, as the case may

22 be.
59

1 But those savings that we try to achieve

2 have to actually be there, because we're not going to

3 build a power plant because we think they are.

4 So we're actually pretty determined that

5 when we try to get people to buy one product versus

6 another product because it's more efficient, that we

7 actually can trust the rating in pounds per kilowatt

8 hour to translate to kilowatt hours.

9 So we're -- that's probably our goal, is

10 being able to understand -- we know quite a bit about

11 how many pounds of laundry our people do. We went

12 and measured it. So we got that.

13 If we can translate that to kilowatt

14 hours based on the ratings, that's what we would like

15 to achieve, you know, on average. Because, you know,

16 everything we do is pretty much on average.

17 MR. BROOKMAN: I actually wanted to ask

18 an additional question, but very briefly,

19 Christopher Wold from CLASP says,

20 "Recommendation is for DOE to test heat pump hybrid

21 clothes dryers to ensure that the new test procedure

22 works with this new tech."
60

1 Now to Ashley.

2 MS. ARMSTRONG: I don't know that Ashley

3 had anything to say.

4 MR. BROOKMAN: Well, I thought -- no.

5 You said before Nathan, you were going to ask a

6 question and take it back.

7 MS. ARMSTRONG: Oh. We'll stay with

8 Nathan's question for a minute first before we move

9 forward, but I mean, I think Nathan brings up a good

10 point. You know, if DOE can come up or this group or

11 anyone can come up with inputs that actually are

12 repeatable but give you end results that are

13 representative, what you would call more

14 representative of field use, I think that's the best

15 solution, because we would have a test procedure that

16 is repeatable and reproducible in the lab regardless

17 of whether it's actual clothes being dried or some

18 synthetic type of low composition weights, et cetera.

19 But if it gives you the results that

20 more closely match the field data that you have and

21 that you are seeking to provide the information about

22 savings to your utilities, I think that's the win.
61

1 So I don't think you necessarily have to

2 have, at least I don't think the conversation needs

3 to necessarily be limited to the fact that you need

4 to dry jeans, you need to dry towels, you need to dry

5 X number of shirts and the idea of this is what

6 people do.

7 If you could find this, you know, cloud

8 in the sky of this synthetic type of load material

9 that actually puts a more repeatable and reproducible

10 result in the lab but gives you the results you're

11 seeking, then you have a win on both sides.

12 MR. MOUW: I think -- this is Nate. I

13 think, you know, if we think about refrigerators for

14 a moment, and it's a totally different product, but

15 what we've done with the refrigerators is we've said,

16 "We're not going to open doors."

17 Well, doors are open in the field. So

18 what we did is we translated that to a different test

19 condition, a different ambient temperature and it's

20 90 degrees. And I have people asking me, "Why do we

21 test to 90 degrees? That's stupid."

22 Well, yes, it is, but that's to
62

1 translate, you know, consumer use condition to a

2 representative value that is reasonable to do in the

3 lab and is repeatable and reproducible.

4 I just wanted to, on slide 31, if we

5 could direct our attention to that for a moment, you

6 know, I guess we always say the words repeatable and

7 reproducible but we never really describe how they're

8 different.

9 And I think we have to be very clear on

10 this slide that the information on the left, the way

11 I read the report, unless somebody has some further

12 insight, I read this to be repeatability, which means

13 I take a single dryer, I test it in a lab multiple

14 times and I tell you how different those test results

15 are.

16 That is a very different thing that

17 reproducibility, which means I test that dryer in one

18 lab and I try to go to some other lab and test it

19 again, right?

20 So I look at these results for

21 repeatability, and if we were to project a

22 reproducibility for these test conditions for this
63

1 test, I'm just going to speculate it's going to be

2 double what you see here. So we have to separate

3 those two things. Looking at repeatability, you

4 know, we see going from a DOE load to a AHAM load, we

5 see a significant increase in the -- sorry. --

6 significant reduction in the repeatability, almost

7 double.

8 That's probably insignificant compared

9 to the difference in reproducibility with more real

10 loads. I think, you know, there's been a decade of

11 work going into momie cloth, and I spent ten years in

12 the lab and I remember many times where we'd sort of

13 have a crisis with momie cloth, right? We got a

14 batch of momie cloth that was different than the

15 last, and I just think, man, I can't imagine trying

16 to do real loads.

17 If we called Levi’s company and said,

18 "Hey, tell me the variation in your cloth going in

19 your jeans," it would be just outstandingly high.

20 So I think we have to balance the

21 repeatability, reproducibility with the desired

22 outcome, which I think is a representative output of
64

1 the test, not a representative input to the test.

2 I'll stop there.

3 MR. BROOKMAN: We have another follow-up

4 from Ravee --

5 MR. BERRINGER: Can I follow up on that?

6 MR. BROOKMAN: Please do.

7 MR. BERRINGER: Bryan Berringer.

8 I have done a lot of work on the momie

9 cloth in my past life, whatever, here at DOE, and

10 that is one of the things that concerns me when you

11 start looking at the jeans, towels and stuff like

12 that. Manufacturers don't track a lot. We've been

13 very specific in trying to spec the cloth down so you

14 get the more repeatability. We even have to do a

15 correction factor on that.

16 But that's what we found when you start

17 going, you know, you go, say, okay. I'm buying a

18 cotton shirt or a t-shirt or a sheet. The

19 manufacturers don't track that lot to lot or

20 variation, so that would be my biggest concern, too,

21 is you're talking about even more variability when

22 there's something that's, you know, between loads.
65

1 We found it in momie cloth, let alone

2 going to, like you say, jeans or towels and cotton.

3 That's concerning. I'm glad you brought that up.

4 MR. BROOKMAN: Ravee, who is on line,

5 says, "I agree with Ashley's comments 100 percent” and

6 let me note that it's useful to agree in addition to

7 disagreeing with the Department or anybody else in

8 the room because it provides confirmation. So

9 frequently commenters only say what they don't like

10 and they don't offer alternatives and they don't

11 agree either, so it's helpful when that happens.

12 Now, yes, Dave.

13 MR. DENKENBERGER: So to clarify how we

14 constructed our, what we used in NEEA, we did go to

15 conventional Lands’ End source, but this could be

16 turned into a specification with tighter tolerances,

17 so you could have very tight tolerance manufacturing

18 of jeans, for instance. That would remove some of

19 these concerns that I think we're talking about.

20 MS. ARMSTRONG: Just to clarify, I don't

21 know if there is enough appreciation given to the

22 extent that both the manufacturers, and now that DOE
66

1 is somewhat involved in this go-to with the actual

2 momie cloth to get it to the specifications before it

3 is even allowed to be used. There's a whole process,

4 and it's a multi-step, time-consuming process to get

5 it to a point where, yes, we have a manufacturer

6 working with us and we have things up and running

7 now, and that's not to say we are -- should stick

8 with momie cloth. I'm not necessarily asserting

9 that, but it isn't easy to do, so the more variables

10 you add in terms of jeans, towels and the more

11 things, people you have to do it, it's just not --

12 it's a very time intensive and somewhat costly

13 process.

14 So minimizing the number of variables I

15 think is something that at least DOE would be

16 interested in.

17 MR. BROOKMAN: Thank you, Ashley.

18 Charlie.

19 MR. STEPHENS: I think, though, you lose

20 sight when you have been -- when you're constructing

21 a test that has so little variance, which is what

22 everybody was after, then the cloth variance matters.
67

1 When you're -- the fact is, in the field, the way

2 people do laundry, it's highly variable. The

3 variance in the field is huge. I don't know why

4 anyone would think that you could just sort of snuff

5 that out and then expect results.

6 There are -- to match up with how things

7 actually are. The problem is when you don't do

8 things that somewhat resemble the way things really

9 are, you're disabling an awful lot of potential

10 technology and solutions and things that might

11 actually under those circumstances do a better job.

12 If the test never exposes that, then how

13 would anybody know? We find it out in the field.

14 That's how we find out, and you don't really want to

15 have to find it out in the field.

16 What I would suggest is that if you have

17 a large variability from test to test and that same

18 large variability occurs from lab to lab, then you

19 should really be looking at the variance of the

20 average that comes out of that stuff, and you may

21 find that the variance of the average is actually

22 quite small, even if the test to test variance is
68

1 quite large. Even if the lab to lab variance wanders

2 around within that large band, the variance of the

3 averages that people derive from four tests might be

4 actually quite small even though we all acknowledge

5 that, yes, there is a large variance in how the

6 machine handles that load from load to load.

7 We see it. I see it in my own

8 equipment. There are times when my washer succeeds

9 and actually managing to balance the load for the top

10 spin speed and sometimes it doesn't.

11 But you know, that's, that's the way it

12 is out there. But the average, the average probably

13 comes out pretty repeatable from month to month so

14 for me in my household and most households.

15 So I'm suggesting that large test-to16 test variance is not the end of the world, and when

17 you get into large test-to-test variance, it dwarfs

18 whatever is going on with the cloth.

19 You know, the cloth can be, you know, 8,

20 9, 10 percent different in some cases, but if you've

21 got a plus or minus 8 percent variance from test to

22 test, that cloth change is not going to be all that
69

1 serious.

2 But the averages, again, the variance of

3 the averages that you get from lab to lab might be

4 quite small, and so I would suggest that until you've

5 done the testing and until you've done the research,

6 you actually can't make any of those statements.

7 You can't actually draw any of these

8 conclusions, which is why we're investing right now

9 in trying to figure out if there is a way to

10 simplify. But we're also prepared to realize that

11 maybe there isn't a way to simplify and actually get

12 realistic numbers, and if there isn't, then we're

13 going to want to figure out the simplest, cheapest,

14 fastest way to get reasonable numbers under the

15 circumstances.

16 So I don't -- I think people are trying

17 to take what is done with the current cloth and the

18 current test procedure and the little variances that

19 they have engineered into that over the years and

20 extrapolate that into the other regime where we're

21 testing, and I don't think it's appropriate.

22 We're not necessarily going to get
70

1 different numbers than you do, and our variance in

2 the end over several tests may not be all that

3 serious, even though the band is wide.

4 MR. BROOKMAN: Okay. Thank you.

5 MS. MAUER: This is Joanna.

6 I think your example of refrigerators is

7 useful, and I think there are kind of two important

8 things that I think one is that a test procedure

9 gives a reasonable representation of energy use in

10 the case of refrigerators' kilowatt hours, but then

11 that it also provides, tells you that this

12 refrigerator is 20 percent better than this other

13 refrigerator.

14 And I think with the refrigerators, at

15 least as far as we know, I think the test procedure

16 does both of those things pretty well, and so I think

17 when we talk about dryers, I think we want to make

18 sure that a dryer test procedure does both of those

19 things well, too, that it gives a reasonable

20 representation of how many kilowatt hours an electric

21 dryer might use in the field but that it also

22 differentiates dryers appropriately.
71

1 And just I noticed one example in the, I

2 think it was the Oak Ridge study, with the two

3 electric standard dryers were with the DOE test load

4 the two dryers had the exact same energy factor, but

5 when they were tested with the AHAM 1992 load, one

6 actually had a 12 percent better energy factor than

7 the other.

8 I think that's really key that a test

9 procedure provides that kind of reasonably accurate

10 differentiation so that we ensure that the energy

11 savings that we think we're getting from a DOE

12 standard, that we're actually getting those savings

13 in the field.

14 MR. STEPHENS: That's a good example,

15 that 12 percent difference between those two dryers

16 when you shifted the test load dwarfs the difference

17 in the cloth in the AHAM '92 test load.

18 I mean, you might see a plus or minus 1

19 percent difference in the 12 percent, but it's 12

20 percent different when you change to clothing that

21 looks more like a field load.

22 MS. MAUER: This is Joanna again. I
72

1 think these differences, I think it may become even

2 more important in the future as dryer technology is

3 changing pretty rapidly. I think the more that the

4 load can represent what people are actually putting

5 in their dryer I think the better chance we have of

6 making sure that the savings that we think we're

7 getting are actually occurring in the field.

8 And on the question of variability, I

9 guess I'm hoping that any increase in variability

10 doesn't become a barrier to an improved test

11 procedure, and whether that means addressing

12 certification enforcement provisions or, you know,

13 can we figure out a way to address that without

14 minimizing the concern but also not having it be a

15 barrier.

16 MS. ARMSTRONG: Would you agree that an

17 approach like we have with refrigerators -- I mean, I

18 think what -- the caution here is that we want people

19 to be open minded to an approach like we, if we can

20 find a way like we did in refrigerators, whether it

21 be with a synthetic load or something else, some new

22 idea that you don't have yet but could be out there,
73

1 if we were to find a way, in an ideal scenario,

2 that's what we would be going for, because it allows

3 you to get your end result but it also allows us to

4 keep the variability somewhat in check.

5 Because like you said, I mean, the

6 untold thing in the room, and I'm surprised one of

7 you two hasn't said it yet, but it is the looming

8 enforcement, right? It is that, after this, we go

9 through this procedure, you guys will want us to go

10 through standards, and as soon as we go through

11 standards, you will want us to enforce those

12 standards. Variability matters a lot for that. You

13 know, I will acknowledge it.

14 So, you know, and Charlie, I'm not going

15 to go test like 50 dryers in order to find something

16 and use -- in order to find something potentially

17 noncompliant. That's just not how our provisions

18 work.

19 And could we down the road address

20 certification enforcement provisions? Sure. I mean,

21 that's not necessarily an issue. But with the large

22 variability comes significant changes to those
74

1 standards tendencies and so on and so on.

2 And so I don't necessarily, I think we

3 should open-minded on both sides.

4 MR. BROOKMAN: Manfred.

5 MR. STAEBLER: It's Manfred again. I

6 agree also with Nathan and Ashley. From the test

7 procedure, we have to acknowledge it is a lab

8 procedure. It's a lab environment, and I don't want

9 variability. I want to be as close as possible, you

10 know, and repeatable.

11 I use the example with miles per hour on

12 automobiles. It's probably a different way if you

13 live in the mountains what your car uses or if you

14 live in a flat area and never have a mountain, but

15 still, you have a measurement of miles per hour, what

16 is it under a lab condition?

17 And I think the same thing we have to do

18 here with the dryers, also. It's a lab condition and

19 it has to be repeatable. When you want to draw now

20 conclusions about your utilities and about the power

21 use, I think it's quite different in the Northwest

22 than in the Southeast, because you might have
75

1 different clothes, you have different climate, you

2 have -- whatever. So you must use, you know, kind of

3 factor what does your current location differ from

4 that lab environment?

5 My point is also we have to reduce this

6 variability in the lab, and it's a lab test

7 procedure. And if you find a better way of keeping

8 the variability down, that's where we should go and

9 close is one thing.

10 MR. BROOKMAN: Chris? Go ahead, Nathan.

11 MR. MOUW: This is Nate. I just wanted

12 to, again, in the slides, on slide 30, I think

13 there's a good, another good picture and there's a

14 comment that was in the report that's not here, but I

15 don't have the word for word but I'm going to try to

16 repeat what I thought I saw.

17 If you look at energy factor, and this

18 is back to, I think, Joanna where you were going, is,

19 you know, does the test procedure adequately

20 differentiate between models, right?

21 I mean, it has to be able to say model A

22 is better than model B if model A truly is better
76

1 than model B, right? I mean, that's the goal, and I

2 think this plot does a pretty good job of showing

3 across, on the top, the energy factor, across the

4 AHAM 1992, the AHAM 2009 and the DOE, in general, if

5 you look at that plot, the orange is always on the

6 top, right? And the green is always on the bottom.

7 What that means is the orange model,

8 whatever it is here, the EC1, was always rated the

9 best with any of the loads and the green model was

10 always rated the worst.

11 The silver model was always rated right

12 in the middle, the blue model was second best, and

13 the red was second worst, and I guess to add to this,

14 I think these are individual data points, right?

15 These aren't averages of tests, which means if you

16 took three tests for each of these dots that you see,

17 it's probably going to look even cleaner at

18 predicting which is the best and which is the worst.

19 So I think this data, anyway, shows

20 regardless of the load, right, we are able to

21 differentiate between models, and the comment that's

22 made in the report, it says, one of the summary bullet
77

1 points says the DOE load is a good predictor of

2 performance of the other loads, as well, and that's a

3 fantastic point, right? Because it's a load that's

4 repeatable, but also, this report says it's predict,

5 it can predict the results of the load, as well.

6 That's fantastic. That's a good result.

7 MR. STEPHENS: Except that I'm seeing

8 that there is quite a difference of the impact of the

9 loads on different models. On some of them, like the

10 compact one, the orange one at the top, there's

11 almost no impact.

12 But if you look at the standard one, the

13 standard dryers, the blue and the silver, one of them

14 has a pretty small impact. It goes from 3.19 to 2.96

15 with a 2009 load to 3.15. That's not a huge range.

16 But look at the one right above it. It

17 goes from 3.19 to 3.16 to 3.52. That's a huge

18 change, and in some of them, it's not nearly as

19 large.

20 MR. MOUW: I agree, Charlie. What we

21 have to consider, though, is these, I believe, are

22 individual data points. They're not averages, right?
78

1 So if there's a standard deviation of 4

2 percent, if you do the math, these points could go up

3 or down, you know, a standard deviation of 3 percent

4 plus or minus 6 percent, so 12 percent expected range

5 in those numbers, and if you just put a bar on top of

6 that point and then drew the range which you expect

7 just test-to-test variation, I'm sure that would, you

8 know, I think that would resolve some of the

9 concerns. We at least need to look at that.

10 These are individual data points, right?

11 They're not good predictors at what the average would

12 be, as I think you were saying earlier.

13 MR. STEPHENS: Well, we're trying to do

14 at least three tests for every one so that we get that

15 variability, we start to see what it looks like, but

16 again, unless you've done the testing, you really

17 don't know.

18 MR. DENKENBERGER: Yes, and this is

19 Dave. We have found that changing the load

20 composition can change the order of the efficiency of

21 dryers.

22 So in this case, you've pointed out that
79

1 if you can get the rank order right, at least that's

2 the first order of prediction and that's good, but

3 that's not, that's not guaranteed.

4 MS. ARMSTRONG: But I don't think it's

5 ever going to be guaranteed, either, so I think

6 you're going off of a false conclusion, because I can

7 change a method, and it can be a better method and

8 there may be some design out there that in some way

9 it will switch. That's happened. We've seen it.

10 You know, I'm glad to hear Joanna thinks

11 our refrigerator test procedure is great, but with

12 the new refrigerator test procedure that came in,

13 something switched. I mean, that's just what

14 happens. I don't think there is an end result game

15 so that, I mean, you're never going to have a rank

16 order that's identical that doesn't switch, and I

17 think if that's our end game, you know, I'm not sure

18 that's reasonable, a reasonable outcome.

19 Now, that's not to say we have it right

20 here and there's not a better way to do it, but I

21 think it's fair to say that for a majority of dryers

22 out there, that the rank order stays the same. Sure,
80

1 some switch, and maybe we can get closer to less

2 switching, but there's always going to be designs out

3 there that switch rank order for whatever reason.

4 That's going to happen, period.

5 MR. STEPHENS: We agree.

6 MR. BROOKMAN: Charlie Stephens.

7 MR. STEPHENS: We agree --

8 MS. ARMSTRONG: I mean, that's the --

9 MR. STEPHENS: We agree, but if the

10 difference comes from this load of clothing in the

11 test procedure that is only representative of half of

12 the clothes that people actually wash, and then when

13 you actually change the test procedure to include

14 clothes that they actually wash or something like

15 that and they switch rank order, that's fine with us.

16 We would like to see that switch in rank order,

17 because the change came from a better reflection of

18 reality.

19 MS. ARMSTRONG: And like I said, I mean,

20 I think we could get to steps where maybe there are

21 things in the test procedure that could be done

22 differently to get to the end result of -- what I
81

1 think you're asking for is more representative of

2 field use.

3 Now, what that means for the inputs, I

4 don't know. But if you get to more representative

5 field use, my point is just that, you know, dryers

6 will change rank order, period, I mean, with whatever

7 test procedure you're going to use.

8 You're not going to have --

9 MR. DENKENBERGER: So -- this is Dave.

10 So the question is, are we getting the rank order of

11 what happens in the field? And we're saying by using

12 the more realistic clothing.

13 MS. ARMSTRONG: I can give you a

14 different rank order if I go test dryers in the

15 Southeast. What is your rank order for the field? I

16 mean, I guess that's what I'm trying to say. I

17 appreciate all the field studies and I think that's

18 helpful data, but we have to also understand that

19 it's limited in what it's telling us.

20 I could get a different rank order. So

21 what exactly are we going for? What is it that we're

22 chasing? Depending on where you're taking those
82

1 field studies, what your population looks like -- and

2 Charlie, I'm not saying that your population is not

3 representative. I'm just saying you can get a

4 different rank order, so to tell the Department,

5 "Ashley, you should come up with a test procedure

6 that gets a rank order just like this data set," I

7 don't think that's a reasonable ask.

8 MR. MOUW: I think the other thing --

9 this is Nate -- the other thing you have to recognize

10 on the market is, first of all, I would say this:

11 Manufacturers, if you looked at rated values out

12 in the field, you're going to see bundling in rated

13 values, right?

14 So if BSH has a dryer that's rated at

15 whatever, 900, and Whirlpool has one that's rated at

16 that's tested, tested at 900, ours is tested at 880,

17 that doesn't mean you're going to see how it's

18 rating, right?

19 Because there is general bundling of

20 rating. What we have to think about is, what level

21 of precision do we need in the test procedure to be

22 able to assign a value to that test? Given that,
83

1 what impact will that really have on consumers when

2 they actually go to purchase a dryer, okay?

3 I think what we want to do is have a

4 system that results in ratings that consumers can use

5 to influence purchasing decisions, but if there's

6 bundling of rated values, you haven't achieved any

7 value by doing so.

8 MR. STEPHENS: I would point at the

9 slide, as long as it's up there, and suggest that

10 when you see changes in the actual ratings of that

11 magnitude, then whatever it is you're changing in

12 those tests has a pretty significant impact on the

13 performance of the machine.

14 And if you haven't, somehow -- if the

15 ratings of the machine come out like they are on the

16 right-hand side, they are not reflective of what that

17 thing actually is doing in the field. In the case of

18 the electric compact, EC1, closer, you know? But in

19 terms of EC2, GS1, those things aren't that close.

20 When you see 15 percent differences, that's, that's

21 too large.

22 MS. ARMSTRONG: Well, what load do you
84

1 think is representative of, more representative, of

2 the field in that graph?

3 Because if you argue it's the '92 load,

4 the 3.19 and the 3.15 are pretty close.

5 MR. STEPHENS: It's the one with towels.

6 MR. DENKENBERGER: The '92.

7 MS. ARMSTRONG: So that's the '92, so

8 really, you're arguing that the 3.15 and the 3.19 in

9 the silver line are pretty close.

10 MR. STEPHENS: Some are.

11 MS. ARMSTRONG: Well, some are and some

12 are further off. I'm just saying, it goes both ways.

13 MR. STEPHENS: Yeah. The 3.14 and 2.94

14 aren't that close.

15 MR. BATTAGLIA: Again, part of that

16 could be due to the test-to-test variations.

17 MR. STEPHENS: Well, that's true, but,

18 and again, until you see the data you don't know.

19 These numbers could change rather dramatically. I

20 would suggest to you that the ones on the right may

21 not change much, but the ones on the left might.

22 MR. BROOKMAN: Christopher Granda has
85

1 been patient. This comment came in probably 20

2 minutes ago: "I think one of the most important

3 things to come out of the NEEA field testing is the

4 range in variance in load size and initial RMC. The

5 test procedure should be designed to measure dryer

6 performance under a realistic range of conditions,"

7 and he continues, "NEEA's field test data is, as

8 presented by Charlie Stephens, profound implications

9 for the test procedure. The approach to the test

10 procedure may need to be fundamentally rethought to

11 reflect the high variance in load size and initial

12 RMC."

13 And then Chris Badger asks a question

14 for Ravee, and then Badger asks a question for Ravee,

15 and Ravee, you wish to speak, so maybe you're in the

16 queue ready to respond to this.

17 "Does the IEC test currently use an

18 average of multiple runs, (3?) To address

19 repeatability and reproducibility? If this is closer

20 to the AHAM 2009 load, wouldn't this suggest an

21 approach?"

22 That's Chris Badger asking Ravee and any
86

1 other, anyone else who wishes to comment.

2 But Ravee, if you can unmute your phone,

3 let's see if we can hear from you.

4 MR. VAIDHYANATHAN: Can you hear me?

5 MR. BROOKMAN: Yes. Good.

6 MR. VAIDHYANATHAN: Okay. I think the

7 by the use multiple runs (sic), they use around five,

8 five test runs on the average if you, again, I think

9 that's one, one question. So is it five test runs.

10 How's that?

11 MR. BROOKMAN: And then you had an

12 additional comment?

13 MR. VAIDHYANATHAN: Yeah. I think I

14 also have a comment on the chart. When we were

15 looking into the EF and how it changes based on the

16 load size, I think once additional, I think a lot of

17 variation could be related to terminate (sic). I

18 think that is related to by the orange shown in the

19 chart below. One approach maybe to look at the data

20 (sic) curve. You can actually determine the (sic)

21 CEF and the CEF at the target RMC level, so if

22 you use that, then you will have much better
87

1 understanding of how the load size may impact the

2 CEF.

3 I think there are two things are getting

4 mixed up here. The only (sic) load size. One

5 approach might be to understand what is the expected

6 target RMC.

7 MR. BROOKMAN: Okay. Are we going to

8 move on in the slide presentation material?

9 MS. ARMSTRONG: Sure.

10 MR. BROOKMAN: Yeah. Let's do that. I

11 think we were about to discuss alternative fabrics.

12 James.

13 MR. BATTAGLIA: Yes. So I mean, this is

14 sort of going along with what we've been talking.

15 We're open to considering alternative fabrics that

16 can sort of simulate the moisture retention

17 properties of cotton or more real loads but can

18 produce more repeatable results, and we've looked at

19 just a few, talked to textile experts. Like rayon

20 has higher water absorption properties, but it's only

21 a semi-synthetic material.

22 So we're opening the floor to any other
88

1 materials that we should be considering, again, along

2 with what Nate has been saying, producing a result

3 that is representative but can also be repeated.

4 MS. MAUER: This is Joanna. I think

5 investigating this sounds like a very useful

6 activity, and I guess it would be great if, when DOE

7 does conduct testing, if it would be possible to

8 include this load that has been developed by NEEA and

9 IOUs.

10 I think that would just help us if we

11 see the results from perhaps some alternative fabric.

12 We can compare that to this load that's

13 representative of some, some loads that are done in

14 the field. I think that will just help us determine

15 some alternative materials that seem reasonable, seem

16 like a fairly good predictor of what we might see in

17 the field.

18 MS. ARMSTRONG: We'll consider that.

19 MR. BROOKMAN: I was wondering if the

20 manufacturers have any thoughts on alternative

21 fabric.

22 MR. MOUW: We don't. We just don't. We
89

1 certainly would be willing to work on it and discuss

2 it, you know, work on what might be a good

3 alternative, but I just, I didn't come prepared to

4 answer that.

5 MR. BATTAGLIA: Certainly, consider it,

6 and

7 bring it back your teams.

8 MR. BROOKMAN: I'm recalling that Ashley

9 was talking a moment about the rigor that's applied

10 to current test fabrics.

11 MS. ARMSTRONG: I think we're looking

12 for any suggestions at this point that anyone would

13 have to inform us even before we start, so if anyone

14 has any further consideration.

15 MR. BROOKMAN: Charlie Stephens.

16 MR. STEPHENS: Yeah. I think we just,

17 we're saying that the test load has a significant

18 impact on the performance of the dryer. I mean, I

19 don't think anybody will dispute that.

20 The question is, is it important to take

21 that into account? But I don't think it's in

22 question that it has a significant impact.
90

1 The other things that has a significant

2 impact is the size of the load, and that, they

3 interact potentially, depending on the dryer,

4 especially.

5 So we have some big factors that are not

6 taken into account, and we have evidence based on the

7 field data that the current ratings, CEF ratings, do

8 not accurately, when translated into kilowatt hours,

9 reflect how much energy dryers use.

10 And yes, there is a large variance in

11 that, but on average, they don't, and the average of

12 a lot of other things in the data is actually pretty

13 close to some of the test procedure average.

14 Our load, our average load, for

15 instance, was not all that far off of DOE's average,

16 you know, load, the 8.45 pounds. So you know, some

17 things are actually pretty close.

18 But when the result in the field in

19 terms of energy use, which is a lot of what we care

20 about, that and, please, let's not diminish what we

21 were talking about earlier, the model-to-model

22 variation of the impact of the test on different
91

1 models in different ways so that we get the right

2 range order of these things.

3 That's important to us, too. So it's

4 not just the overall energy use. So, but when you

5 have some things that line up pretty well but the

6 outcome in the end does not, then you have a problem.

7 And we need to -- there may be multiple things we can

8 do to fix it, but we have to at least acknowledge the

9 problem.

10 MR. BROOKMAN: Okay. Dave.

11 MR. DENKENBERGER: Dave. So I think the

12 example of refrigerators is actually an interesting

13 one,

14 because even though running it at 90 degrees

15 Fahrenheit can reproduce the field energy use fairly

16 well, what we found is that the variable speed drive

17 fridges, I believe DOE predicted a 2 percent energy

18 savings where we were predicting more like 20 percent

19 energy savings.

20 So that's an example of a specific

21 technology. You have to load it at multiple points

22 to see the energy savings. So I think that actually
92

1 gives --

2 MS. ARMSTRONG: That's not a function of

3 the 90-degree test, I'm sure.

4 MR. DENKENBERGER: But it's a --

5 MS. ARMSTRONG: It's something

6 different.

7 MR. DENKENBERGER: Right, a single test

8 position, whereas if you open the --

9 MS. ARMSTRONG: But you're making

10 different points.

11 MR. DENKENBERGER: -- if you put in

12 food, if you open the door, then you're testing at

13 different loadings, and then you actually see the

14 advantage of that particular technology. So I think

15 we need to think about that. In the terms of dryers,

16 we want to load the dryers with a small load and a

17 large load.

18 MS. ARMSTRONG: But that's part load

19 operation. It has nothing to do with the 90 degrees.

20 You could say the same thing --

21 MR. MOUW: At 90 degrees, that's full

22 load.
93

1 MR. DENKENBERGER: 90-degree door

2 opening is to -- sorry -- it's to simulate door

3 opening.

4 MS. ARMSTRONG: Right.

5 MR. MOUW: That's the only purpose.

6 MS. ARMSTRONG: Exactly. You could

7 still do full load.

8 MR. MOUW: You can try opening doors or

9 just increase the ambient temperature on the outside

10 of the fridge. That's -- so there's a study done --

11 I wasn't doing this work at the time, but there's a

12 study done to translate, you know, the gradation

13 number of door openings and my home with two kids,

14 right, to get a result that's reasonable.

15 So they increased the ambient

16 temperature to do that. That was a real, practical

17 translation of real world to something that's

18 reasonable to normal lab, so that's the best way.

19 MR. STEPHENS: But we -- we have -- the

20 dryer test procedure has the same problems that many

21 others do: There are, the heat pump test procedure

22 doesn't apply well at all to the way a variable
94

1 capacity heat pump works in the field. I mean, the

2 results are astoundingly different.

3 The heat pump water heaters, the water

4 heater test procedure at 67 and a half degrees

5 doesn't apply to three-quarters of the installations,

6 where the heat pump water heaters we have are in

7 houses. The performance is radically different.

8 So you know, the fact is that as

9 technology changes and as things move along,

10 eventually the test procedure just doesn't provide an

11 understanding of how these new technologies and how

12 these new controls and how these new machines

13 actually work in the real world and when that

14 happens, you need to step back and start looking at

15 the test procedure again.

16 MR. BROOKMAN: Yes. Manfred.

17 MR. STAEBLER: This is Manfred from BSH

18 again.

19 I mean, I come from refrigeration, too.

20 That's why I can talk about refrigeration but not

21 about dryers. But you know, you have many different

22 types of refrigerators, and therefore we have DOE
95

1 product classes, which take into account the

2 differences, and maybe now, if you have in the future

3 different dryers, maybe you need different product

4 class for different technologies. Could be. I'm not

5 sure, but in the refrigerators we did it because if

6 you have through-the-door ice, it's a different, it's

7 a different product class than if you have just a

8 single door refrigerator, just to think about

9 variances in the products themselves.

10 MR. BROOKMAN: Are we going to --

11 MS. MAUER: May I just say, we don't

12 want to think about product classes in terms of

13 technologies, but in terms of the utility that is

14 provided.

15 MR. STAEBLER: Utility provided, right.

16 MR. BROOKMAN: Dave.

17 MR. DENKENBERGER: Yes. So getting to

18 the difference in repeatability of the load, I think

19 we -- one way of illustrating how different a

20 realistic load is from the DOE load is the thickness

21 of the cloth is all the same in the DOE load, and we

22 have some graphs that show the thickness of the cloth
96

1 of these more realistic loads.

2 They can vary a factor of five. That

3 is, like the jeans can be five times thicker than the

4 thin articles.

5 And this is really important when you're

6 measuring automatic termination, because many dryers

7 will have moisture strips on the front of the drum

8 and you're not sure what part of the load -- I mean,

9 it's just testing the front of the load, basically,

10 and if it's touching thick articles, it's measuring a

11 different moisture content than if it's touching the

12 thin articles.

13 So that's something that really matters

14 now that we are measuring automatic termination, to

15 get that first thickness of jeans. And that, that

16 difference, that factor of 5, is so much larger than

17 what the difference you would get by buying jeans

18 from one provider to another. You're still getting

19 jeans versus thin underwear. You're still getting

20 the majority of the effect, even if the result is not

21 quite as repeatable.

22 MR. BROOKMAN: We have a few comments on
97

1 line, and then I'm going to suggest we move on to the

2 next segment here. Christopher Granda says, "The

3 uses that the test procedure will be put to,

4 compliance with minimum efficiency, ENERGY STAR, and

5 utility energy efficiency programs all require an

6 absolute measure of energy efficiency, not just a

7 ranking relative to other models."

8 And Curt from Tremel or -- pardon me --

9 Curt Tremel from UL, try and unmute your phone, and

10 hopefully, we can hear you in the room.

11 MR. TREMEL: Yes. Can you hear me?

12 MR. BROOKMAN: Yes. Good.

13 MR. TREMEL: So I guess a couple

14 comments. One is on load size and that one, I see

15 that the question as far as why don't we use multiple

16 load sizes in with the clothes washer, and the intent

17 of the clothes washer needing multiple load sizes is

18 because all of the clothes washers are sensing the

19 load and that affects the amount of water that is

20 consumed, so that end result affects the energy

21 consumption.

22 For clothes dryers at this time, there
98

1 is not that load sensing, so I see that one load size

2 accurately, accurately compares multiple load dryers

3 in terms of energy efficiency. So that's, I guess

4 that's my comment from the load side.

5 As far as load type, I do see that is

6 there's a gradiance of option of a possible solution

7 as far as getting the best of both worlds, and that

8 would be utilizing the momie cloth load strictly for

9 energy consumption and determining if it meets the

10 minimum standards, whether that's for DOE ENERGY STAR

11 or whatever, but what would be the option -- and

12 that's repeatable and reproducible so that we can be

13 consistent in having a meeting of minimum energy

14 standards.

15 But in terms of what consumers are

16 actually using, would it be possible to use a real

17 life load that is representative as a performance

18 metric, similar to what is used for other categories,

19 such as clothes washers and dishwashers now and so

20 that can evaluate the real life performance of the

21 dryer as the consumers are using it and also provide

22 a representative energy metric that utilities can
99

1 with use in terms of advising power plants or

2 providing rebates, but unfortunately, as we've

3 discussed, that load size would have more variability

4 but you're not necessarily using that to meet the

5 minimum standards and confirm that the product is

6 matching up with what it needs.

7 So I guess those are my comments and

8 trying to see, is that a possible solution to I guess

9 meet the needs of both things.

10 Unfortunately, there is an additional

11 test burden, but I think that would provide, the

12 additional test burden, would provide benefits to

13 multiple stakeholders.

14 MR. BROOKMAN: Thank you.

15 I think we're going to move on to test

16 cycle settings, program, temperature and dryness

17 settings. James Battaglia.

18 MR. BATTAGLIA: Just to highlight a few

19 of the points from the current test methods, so for

20 automatic termination dryers, a lot of you are

21 familiar, but it uses the normal cycle program,

22 maximum drying temperature setting and normal or
100

1 medium dryness level, and any other optional settings

2 that don't affect those particular settings are

3 tested in as-shipped condition.

4 And then for timer dryers, it uses the

5 maximum temp setting and, if it's equipped with a

6 timer, the maximum time setting.

7 And again, any other optional cycles

8 that don't affect those are tested in as-shipped

9 condition, and if there is no separate temperature

10 setting, the maximum time setting was used for the

11 test cycle.

12 So again here we're just teeing up the

13 question, particularly on the cycle settings, what

14 iterations or combinations of cycle settings

15 stakeholders are interested in considering.

16 The cycle program settings, they're at

17 temperature and dryness settings and any other

18 optional options, like Charlie highlighted the eco

19 mode. Again, this is a diagram that Charlie

20 included in his just showing from the NEEA field

21 study the percentage breakdown of the various cycles.

22 I'm not sure if it's the latest data.
101

1 MR. STEPHENS: Pretty close. It didn't

2 shift.

3 MR. DENKENBERGER: This is Dave. So I

4 can comment on the supplemental test that we've

5 developed. For the small and large loads, we've

6 recommended the medium temperature, because that is

7 the most common in the NEEA field study.

8 For the medium size load on the fastest,

9 that usually corresponds to a high temperature, often

10 heavy duty, and then for the eco, that usually

11 corresponds to a low temperature. So these tests as

12 a whole explore the full, not the full range, but a

13 much better range of how the dryers are operating.

14 As for the dryness settings, we follow

15 the DOE to start with normal dryness, but if you

16 don't meet the final remaining moisture content, then

17 you would switch to the most dry.

18 And are we talking later about final RMC

19 specifically?

20 MR. BATTAGLIA: Yes. That's one of my

21 next slides. I might as well just tee up the last

22 one.
102

1 MR. STEPHENS: We can talk about it all.

2 MR. BATTAGLIA: Well, they're sort of

3 interrelated.

4 MS. ARMSTRONG: They are. They are.

5 MR. STEPHENS: There is more to talk

6 about here.

7 MR. BATTAGLIA: Well, let's start with

8 this first.

9 MS. ARMSTRONG: I mean, what do we think

10 about multiple settings, testing in multiple

11 settings, doing some type of weighted average of

12 multiple settings?

13 MR. BROOKMAN: Charlie.

14 MR. STEPHENS: Well, we're struggling

15 with this right now as we test new products, because

16 the settings that we're getting, we don't understand

17 what they mean. I mean, and I say that --

18 MS. ARMSTRONG: Welcome to clothes

19 washers.

20 MR. STEPHENS: Well, we don't understand

21 what they mean when you actually run the machine with

22 -- you know, actually have to test it and find out
103

1 what happens.

2 We have one dryer that we tested a

3 little while back that has eco normal and normal with

4 eco. And we said what? You know, how are you going

5 to pick those?

6 So we found out that eco normal left you

7 no choice at all. It was the lowest temperature

8 setting, and it took three hours or something-plus to

9 dry a normal load. I think that was a DOE D2 test

10 load.

11 So we said, Well, that's probably not

12 one that too many people use. So we tried normal

13 with eco, and that one seemed to have a more normal

14 result in terms of its length of cycle and energy use

15 and it was slower than fast dry or normal without

16 eco.

17 So the problem is, there's a

18 proliferation of settings, and you've got one set --

19 you know, on the slide I show there's a knob that

20 has, you know, normal, heavy duty, that sort of like

21 gross selection like you see on most dryers today.

22 But then there's buttons that are
104

1 essentially like fast eco and balanced or -- there's

2 modifiers. And so you start doing permutations and

3 combinations of those things, and of course, all the

4 lights change every time you do that telling you what

5 you're getting.

6 We have no idea right now what people in

7 homes doing laundry will actually use for what kinds

8 of loads, and we're not sure how people will respond

9 to different machines and different manuals that say,

10 Use this for that.

11 We also know that at least one of the

12 machines we got, and we suspect it will be typical,

13 come shipped with the eco mode selected but it

14 doesn't revert to that. It, you know, after the

15 first load, it reverts to whatever you used last,

16 essentially. So it doesn't -- we're not sure that

17 anybody should put any weight on that just because it

18 was shipped that way.

19 So we're -- there's going to be some

20 real problems here we see with all of these newer

21 machines with electronic controls as to what

22 comprises a setting that is, that would have, you
105

1 know, weights approximating some of what you're

2 seeing on the screen there, 50 percent, 30 percent,

3 13 percent. We don't think consumers doing laundry

4 will chose more than four or five modes, periods.

5 They'll figure out which four or five work for them

6 for whatever loads they do and that's what they'll

7 use. We just don't know which ones they are, and

8 it's going to be really hard to define in the test, I

9 think, what they are or what they should be, if you

10 can figure it out.

11 So we may be left to consider testing at

12 extremes and doing some sort of weighting scheme that

13 most often gives you an average result that works.

14 We don't know. That's why we're putting all these

15 things in houses and letting people use them and

16 recording what they do and what they use what

17 percentage of the time for what kinds of loads, and

18 we'll try to get some handle on this.

19 But that's only half the problem. The

20 bigger part of the problem is defining in the test

21 procedure what those are.

22 MS. ARMSTRONG: I think one part of the
106

1 question -- this is Ashley from DOE. One part of the

2 question that remains unanswered from my perspective

3 is and simply because I haven't actually run the

4 tests on every single option out there, especially

5 for those dryers that may have like 20-plus options

6 like the fancy new dryer in my house. But does it

7 matter?

8 MR. STEPHENS: Well, should we run a

9 test with less dry selected? I would argue, looking

10 at that graph on the screen up there, no, you

11 shouldn't.

12 MS. ARMSTRONG: Well, I'm more saying,

13 you know, if you were to run every single discrete

14 cycle option there was, yes, between super high heat

15 and eco mode for three hours, you would see a

16 significant difference.

17 But for some of them, it may not matter.

18 You may not get an end result that's all that

19 different, and so that would argue, who cares?

20 MR. STEPHENS: Who is going to tell you

21 that is there no difference?

22 MS. ARMSTRONG: Well, you would have to
107

1 test. You're right. You'd have to test the

2 character, the delta.

3 As I said, I don't know the answer. I'm

4 pretty there's people around the table that may know

5 the answer. (Laughter.)

6 MR. STEPHENS: Well, there's other

7 problems, too, because just a little anecdote here,

8 we recently were testing a hybrid dryer that behaved

9 very strangely and couldn't seem to terminate at less

10 than 10 percent RMC, and looking at the power traces

11 on it, it was like what is this thing doing?

12 We notified the factory, and within

13 hours, we got a response and they say, "Oh, well,

14 that was a mistake. That's an engineering problem.

15 We know how to fix it. We'll ship you another one

16 tomorrow."

17 So it took them 24 hours or less to

18 figure out the problem, change how the machine

19 behaved and send us a new one. And we're quite

20 certain that at least one dryer out there that's WiFi

21 enabled could probably have those things changed at

22 any time in its service life. So to be honest with
108

1 you --

2 MS. ARMSTRONG: That's a whole different

3 issue, but --

4 MR. STEPHENS: Well, it is, but it bears

5 on what is a cycle.

6 MR. BROOKMAN: But that was a fancy one,

7 a new one with all kinds of electronic controls?

8 MR. STEPHENS: Well, increasing numbers

9 of dryers have electronic controls. They're

10 electronic to some extent.

11 MR. BROOKMAN: Just curious.

12 Okay. Other comments here? This is

13 useful. I'm not sure we've covered all of these four

14 bulleted points sufficiently.

15 MR. DENKENBERGER: This is Dave. If you

16 could go back to the other slide that explains the

17 other -- yeah -- first full bullet but then the

18 fourth sub-bullet, Any other optional cycle settings

19 that do not affect the program, temperature or

20 dryness settings shall be tested in the as-shipped

21 positions, so we've been interpreting this as an eco

22 button even though it really does affect how the
109

1 dryer, you know, probably what its temperature is

2 inside, it's not explicitly labeled as a temperature

3 or cycle setting.

4 So we've interpreted this to say, if the

5 dryer comes with an eco button on, then that's the

6 as-shipped position, so that's how we run the DOE

7 test.

8 But as Charlie pointed out, if the dryer

9 doesn't keep that default, then we're not sure how

10 much the consumers will use it, so when we've tested

11 the small and the large loads, we have not kept the

12 eco button pressed.

13 But we're open to, if a dryer were to

14 default back to eco after two hours or whatever, then

15 we could see that more consumers would end up using

16 it and then it probably deserves to be tested in more

17 runs. So that's just -- happy to hear manufacturers'

18 feedback on that.

19 MR. BATTAGLIA: Of course.

20 MR. MOUW: Of course, and I think

21 Manfred would say the same thing, we study our

22 consumers all the time. We have whole groups of
110

1 people that we full-time study, consumers and their

2 usage.

3 We do very similar studies nationwide,

4 where we'll put -- you know, some in homes, and we'll

5 instrument those units and collect gobs and gobs and

6 gobs of data.

7 That's something we do constantly, and I

8 think all manufacturers that care about their

9 consumers are doing the same things.

10 I think what we find is that changing

11 consumer behavior can be a different thing. What we

12 find is that consumers are for the most part using

13 the normal cycle. And to the extent that we

14 collaborate a little more and talk about whether or

15 not doing multiple cycles like this will increase the

16 value and representativeness of the test procedure,

17 there may be some information that we would be

18 willing to share in that regard.

19 But I mean, in general, consumers do

20 what's easy, what they're used to, and that's hitting

21 the normal button.

22 It's funny. Charlie, you mentioned the
111

1 use and care guide. If we could just get consumers

2 to read the use and guide, that would be a victory.

3 I mean, it really would be.

4 MR. STEPHENS: I think they use it for

5 troubleshooting.

6 MR. MOUW: Or fire starters, one of the

7 two. The point is, you know, consumers use the

8 normal cycle for the most part.

9 MR. STEPHENS: I think so.

10 MR. MOUW: So you know, is there value

11 in looking at other cycles? Perhaps, but I think the

12 value in the market I think would be fairly small.

13 MR. STEPHENS: It's certainly, I think,

14 is what should be used for the current DOE test load

15 and probably on normal dry.

16 I mean, the D2 test procedure I think as

17 far as it goes does okay with that. I think we

18 should be using medium heat rather than high heat.

19 I think if you were to start

20 entertaining shifting loads and actually doing some

21 testing with a heavier load, different settings might

22 be in order, like more dry, for instance. It might
112

1 actually consistently take more dry to actually get

2 the RMC, the final RMC, under 5 percent, for

3 instance.

4 So and the final RMC might be a little

5 bit different than the final RMC for the momie

6 cloths.

7 Two more things that came out of our

8 study from data, we found, oddly enough, that the

9 washer cycle time and the dryer cycle time on average

10 were within a minute or two of each other at just a

11 minute or two under an hour. So they were really

12 quite well matched. That was a bit of a surprise.

13 The RMCs that we were getting were a

14 little higher, even in -- and there was quite a

15 difference between the cohort -- we divided the

16 cohorts of the dryers when the test procedure

17 changed, so 2005 to 2009 and then 2010 and newer.

18 And there actually was a notable difference in what

19 we saw in those two cohorts in terms of the

20 performance in the laundry area.

21 So RMC, everything else, so --

22 MR. DENKENBERGER: You're talking about
113

1 initial.

2 MR. STEPHENS: Initial, yeah.

3 MR. DENKENBERGER: For the dryer.

4 MR. STEPHENS: Right. Yes. Yeah. The

5 average initial RMC was a little higher than D2, 62

6 percent or -- I think, but not, not hugely. But,

7 again, it's a Delta. You're going from 57 plus or

8 minus down to 2 to 5.

9 Well, if you're starting at 62, that

10 Delta gets notably larger, and there's a significant

11 amount of energy actually used for that extra 5

12 percent RMC.

13 MR. BROOKMAN: Joanna.

14 MS. MAUER: This is Joanna. As dryer

15 technology is changing, it just seems to me like it

16 may be important to somehow try to capture the range

17 of performance, and I guess I'd be concerned, you

18 know, if we're only testing at the normal setting,

19 you know, in the example that Charlie gave of if a

20 dryer shifted in eco mode but as soon as the consumer

21 selects, you know, says there is a fast mode or

22 something they can select and then after that the
114

1 default is that new mode, then we're not capturing at

2 all the, how that dryer is actually performing in the

3 field.

4 So giving, I mean, it makes sense to me

5 that most consumers are choosing the normal setting,

6 but it also seems to me like, given the huge range of

7 settings, that it would be good to somehow capture

8 performance across settings so we can ensure that

9 dryers are performing well, not just on the single

10 setting but across the range.

11 MR. BROOKMAN: Jonathan Gatzke has a

12 comment from on line. He says, "After the guidelines

13 are set, how about allowing the manufacturer to set

14 the energy cycle? The energy cycle would then be

15 marked on the machine's control on a

16 consumer/removable label and in the manual itself.

17 This is how Australia runs G-E-M-S, GEMS energy

18 registration."

19 MR. STEPHENS: Repeat that again.

20 MR. BROOKMAN: The last part or the

21 whole thing?

22 MR. STEPHENS: The first part.
115

1 MR. BROOKMAN: "After the guidelines are

2 set, how about allowing the manufacturer to set the

3 energy cycle. The energy cycle would then be marked

4 on the machine's control on a consumer/removable

5 label and in the manual itself. This is how

6 Australia runs GEMS energy registration."

7 MR. STEPHENS: So when they say energy

8 cycle, they mean the cycle that was tested?

9 MS. REICH: They declare what the cycle

10 is tested under, make that available to the consumer.

11 MR. STEPHENS: And that's what they're

12 referring to there as the end of use cycle?

13 MR. DENKENBERGER: So they're almost

14 defining normal cycle. They're saying this, is, you

15 know, in our particular case, it would be, this is

16 the normal cycle that you tested to. When said you

17 couldn't figure out what, you know, can't figure what

18 that normal -- because it usually doesn't say normal

19 cycle on a dial when you're using the machine.

20 MR. STEPHENS: Well, it does on that one

21 slide of mine. If you'll see, there's a knob and

22 normal is right at the top, top center, so -- but
116

1 then there's also three modifier buttons to modify

2 any number of those other settings and so you can get

3 permutations and combinations.

4 And then occasionally you can also

5 modify some of the individual things like

6 temperature, dryness, those sorts of things.

7 There are defaults, and I think we've

8 discovered, one of the things we've discovered in the

9 field is that most of the time people don't mess with

10 the defaults. When they select a cycle, they usually

11 leave it for most of the defaults.

12 The only one that some people I think

13 have figured out is that certain loads don't dry as

14 easily as others, so they're likely to use more dry

15 to make sure that it gets dry.

16 MR. BROOKMAN: Let's go to the other

17 test procedure issue and see if anything else needs

18 to be described here. For example, have you talked

19 about RMC yet? I think, Dave, you had a comment on

20 RMC?

21 MR. DENKENBERGER: Yeah. Well, so there

22 are two, that from the dryer's perspective, there's
117

1 the initial moisture content and then final. So

2 we've been talking a little bit about initial.

3 One, as Charlie noted, we've been seeing

4 in the field a little higher than 57.5 percent, and

5 we could get this if the washer test procedure were

6 tested with more realistic clothing or at least

7 cotton clothing, because it's more difficult to spin

8 the water out.

9 So then like if we had a load that was

10 the momie load and a load that was more cotton, we

11 probably would be able to reproduce the field values

12 better.

13 And then on the other end is the final

14 RMC and to clarify the testing that was done, I

15 believe. So the DOE now is 2 percent, but with the

16 AHAM 2009 and the AHAM 1992, the target was 5

17 percent.

18 And when we were doing the testing, we

19 did consult with manufacturers and settled on a goal

20 of 4 percent RMC that would be acceptable to most

21 consumers, and it depends on the dryer. Sometimes

22 you do need to go to very dry. Sometimes normal
118

1 dryness was sufficient.

2 But then on the fastest test, we did

3 decide to do only 2 percent RMC, recognizing that

4 some consumers want the laundry very dry.

5 Now, some dryers can still meet that on

6 normal dryness. We decided not to dictate using very

7 dry. If the dryer got it to 2 percent RMC with

8 realistic clothing on normal dryness, that's fine,

9 but if it didn't, it would have to go to very dry.

10 MR. STEPHENS: I think the RMCs are

11 somewhat load dependent. It's possible that we

12 haven't got the data yet. I'm working on funding

13 some work to get the data, that 57 and a half percent

14 for the test load is actually a little high because

15 it's just the nature of the cloth.

16 It may be a reasonable number if it's

17 the only testing you're doing, you know? Again, it's

18 like the 90 degree refrigerator testing. If you're

19 only going to use one test and one test load, well,

20 maybe it's important to start it at a higher RMC

21 because that will push the drying energy a little up

22 toward what it would be with real clothing.
119

1 I could see where that might be the

2 case, but I think some of the lighter loads that are

3 eight and a half pounds going through the system,

4 actually a lot of clothes washers deliver lower RMCs

5 than that.

6 And so again, if you only have one load,

7 maybe that's an appropriate number, but if you're

8 doing multiple loads, it might actually be

9 appropriate to have a different starting RMC for each

10 fabric type, higher for real clothing and lower for

11 the lighter-weight clothing, and 57 and a half might

12 be kind of in the middle of where you'd want those

13 two numbers to be.

14 Test load weight, at least one of them,

15 I would point out again that the CEF numbers that

16 we're getting for our small load, which is like four

17 pounds plus or minus in the real clothing --

18 MR. DENKENBERGER: Yes, 4.2.

19 MR. STEPHENS: -- 4.2 pounds, the CEF

20 numbers are literally one-half of what they are with

21 a large load of the same clothing.

22 So that's a big deal when you're getting
120

1 half the numbers. That's a huge difference, and so

2 the 8.45 pounds may be an appropriate load to run and

3 get a number from, but I think it's also appropriate

4 to look at how a dryer will handle a small load,

5 because a lot of loads are smaller than that. A lot

6 of loads are smaller than that.

7 And who's to say that there won't be a

8 clothes dryer out there that in some manner or

9 another figures out how big the load is and adapts

10 its behavior to that. It may be that clothes washers

11 are not the only things that can adapt to load size.

12 So I think we should at least

13 potentially use a point there that has some weight

14 for a smaller load.

15 Cycles per year, our cycles per year

16 were a little higher. They ranged. I think the

17 different analyses gave us different numbers

18 depending on what was a cycle and what was a load.

19 Touch-up cycles were always, were

20 sometimes hard to identify. But we think the dryer

21 cycles is a lot higher than that, but if you're

22 actually just, if what you really mean is loads,
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1 maybe with as many cycles as it takes to dry the

2 load, it's somewhere between 300 and 310.

3 So it's not radically different than

4 this.

5 We did find a radically different number

6 of on-mode hours, active on-mode hours, versus

7 stand-by off-mode hours, significant difference

8 there. So, and that's in the reported.

9 MR. BROOKMAN: I though you said

10 earlier, though, that the standby power --

11 MR. STEPHENS: Standby was small at the

12 moment. However, we think that's changing everywhere

13 we look, and I've got data on standby, actually

14 network standby, in some cases, which is alarming to

15 me.

16 Some of it's not network standby, it's

17 just alarming standby. But, so we think that that

18 needs to be defined.

19 Other test provisions, the last bullet

20 there, we think network standby needs to be defined

21 and it needs to be tested, because there's an awful

22 lot of network standby going on every year that
122

1 wasn't there the year before in a lot of products,

2 including these.

3 So we've already got a couple of those

4 products in hand. We just don't know what they're

5 going to do and what they're going to be asked to do

6 and who's going to control them using what systems

7 and under what conditions.

8 And so anyway, it needs to be tested,

9 we're quite sure.

10 MR. BROOKMAN: Dave, do you have a

11 comment here?

12 MR. DENKENBERGER: Yes, Dave. So for

13 the dryers not explicitly sensing the load size, even

14 if they don't explicitly sense it, that they still

15 can behave very differently. We generally see in a

16 small load that the heater is not on as much, so this

17 would make sense even with a very simple dryer that's

18 just measuring the temperature of the exhaust air.

19 If there isn't as much wet clothing in there, you'll

20 get to your maximum exhaust temperature quickly and

21 you'll have to turn the heater off.

22 The other thing is more sophisticated
123

1 dryers. TIAX (sic) performed a research study on

2 modulating gas dryers that could vary the heat

3 output, and they found significantly greater energy

4 savings with the small loads because they could

5 taylor the heat output to the load size.

6 So that's a good reason to test the

7 multiple sizes.

8 MR. BROOKMAN: We have a comment from

9 Eileen Eaton, Consortium for Energy Efficiency, and

10 her comment is, "Have you determined consumer

11 accepted final RMC? I ask because I'm curious if

12 similar studies could be conducted to determine

13 consumer acceptance regarding dry time."

14 MR. STEPHENS: Well, we consulted with a

15 number of manufacturers about what they knew about

16 this in order for us to kind of get a sense of where

17 the boundaries were, and I don't think we disagreed

18 with what we were told. I think it's 5 percent or

19 less with some people actually wanting these things

20 to be practically bone dry and other people,

21 depending on the fabric sometimes, they would accept

22 a little bit more than that.
124

1 But we don't believe that RMCs greater

2 than 5 percent at the end of the cycle are going to

3 be very acceptable unless they actually wanted that.

4 MR. BROOKMAN: Dave?

5 MR. DENKENBERGER: Yeah. So we did

6 investigate this also with limited, not statistically

7 representative sample of people feeling the clothing

8 and saying whether they're dry, and an important

9 issue here is about the diversity of thickness of

10 clothing.

11 And I saw that the -- I don't know if it

12 was PNNL or Oak Ridge did some studies of the --

13 weighing the individual articles of clothing and

14 finding what the remaining moisture content is, and

15 we think -- we've done some of that, as well. We

16 think that's a good idea, because it can, depending

17 on the consumer, if the jeans are still wet, they may

18 put everything back in and continue to dry for

19 another ten minutes.

20 And so it's very important, and to get

21 that diversity of thickness, and so that means that

22 if you, if you bring the entire load down to 5
125

1 percent RMC, it could be that the jeans are still 10

2 percent RMC and feel wet.

3 So that's important to look at.

4 MR. BROOKMAN: Okay. This list on 22 is

5 kind of a summary of remaining issues, so let's see

6 if we have other comments here to address.

7 MR. STEPHENS: Oh. Eileen, nobody

8 answered Eileen's question about duration of study of

9 cycle, and we are concerned about that and I know the

10 manufacturers are, too.

11 So our study showed that most people

12 doing laundry probably didn't have a reason to be

13 concerned about that because the washer cycle time

14 was virtually identical to the dryer cycle time,

15 right around an hour, and that was unsurprising to

16 us, and we think most people are probably pretty

17 happy with that.

18 When they're almost equal and it's

19 around an hour, we didn't find anybody who had a

20 problem with that in our study. But I think it would

21 actually, when we start seeing longer cycle times

22 based on other technologies that are more efficient,
126

1 for instance, when they get their efficiency by

2 extending the cycle a little longer, we probably

3 should do some of those studies.

4 MR. BROOKMAN: Dave.

5 MR. DENKENBERGER: Yeah, and I should

6 clarify that all these final RMCs are based on bone

7 dry weight, where as IEC does not define it by the

8 bone dry weight. They define it by the weight of the

9 clothing that has been calibrated with a certain

10 relative humidity, so we have really careful how

11 we're quantifying this.

12 And that makes a complication in the

13 field studies, because you would think that the

14 clothing going into the washer is dry. Well, it's

15 dry but it's not bone dry, so we have to make a

16 correction for that to get to the bone dry weight.

17 MR. STEPHENS: Yeah. And that's, note

18 that in the report. There is a correction when we're

19 talking about comparing ratings and field ratings.

20 There is a correction in there to get back to

21 something approximating bone dry weight to start with

22 because the consumers just weighed their clothes.
127

1 They were not bone dry.

2 MR. BROOKMAN: We have a comment,

3 request for a comment, from Ravee. Ravee, unmute

4 your phone. Let's hear from you.

5 RAVEE: Sorry. Can you hear me okay?

6 MR. BROOKMAN: Yes.

7 RAVEE: Okay. I think the comment has

8 been all based on the targets in the RMC levels.

9 They normally can be (inaudible) or they can be 5

10 percent and 2 percent.

11 Again, the question is, how do we know

12 what is the consumer's, you know, acceptable in RMC?

13 Also, I think looking at RMC, it is a

14 known fact that the items which are dried and kept in

15 the room conditions could take moisture up to 8

16 percent. This is up in the 8 percent range. So the

17 question is that, do we need to overdry, using more

18 RMC?

19 But then obviously, the clothes are out,

20 hang in the closet and they take some moisture from

21 the air. So what would be the right level and then

22 equal an IEC target in retention is hopefully around
128

1 8 percent. Because the test condition is different.

2 They start, you know, humidity pretest laundry which

3 is around 8 percent, so then they end up like

4 equivalent like zero percent because equalized to 8

5 percent then you do bone dry.

6 So the question is, are there

7 differences between D1 and D2? What is the right

8 level? And should we really need more dry and then

9 the users actually end up having more moisture when

10 the laundry is left in the room.

11 MR. BROOKMAN: Okay.

12 MR. DENKENBERGER: I think that's a good

13 point, but the question is, what do consumers do now?

14 There's a separate question of whether we could

15 convince them that they don't need to overdry their

16 clothing if it was just going to suck in more

17 moisture from the room.

18 MR. BROOKMAN: You need to talk to my

19 spouse.

20 MS. ARMSTRONG: I don't think that's

21 necessarily a responsibility of the test procedure.

22 MR. BROOKMAN: I think we're moving
129

1 towards closure here. And maybe, are there any final

2 comments on this segment and then maybe we'll move to

3 closing comments. I think we've pretty much covered

4 it at this point.

5 So then moving then to closing remarks,

6 any other issues that people, individuals, wish to

7 raise as we move towards the end of this meeting?

8 Charlie?

9 MR. STEPHENS: I want to add one thing,

10 and that is, we really are, whether DOE opens the

11 discussion soon or not, thinking about the

12 implications for the clothes washer test procedure,

13 as well, because of the nature of some of the changes

14 we're focused on, like the test load.

15 So we're also trying to think about that

16 even though we're focused for now on the dryer.

17 MR. BROOKMAN: Okay. Thank you.

18 MS. REICH: I have a question to

19 actually throw out, now that you mention clothes

20 washer.

21 So a lot of what we're talking about

22 today heads more in the direction of the clothes
130

1 washer, the complexity of the clothes washer test

2 procedure with a matrix and many test cycles.

3 What are people's thought on the test

4 burden? What is an acceptable test burden for a

5 dryer test procedure?

6 MR. DENKENBERGER: Well, could we have

7 someone comment on the test burden of the washers,

8 how many cycles that is?

9 And also, we should mention there is an

10 issue of how much you have to test a single unit and

11 then the additional unit. Could someone comment on

12 that?

13 MR. MOUW: What do you mean?

14 MR. DENKENBERGER: As in, I'm most

15 familiar with the dryer test procedure, whereas the

16 test procedure says to test it once, but then you

17 have to test multiple units in the same model and

18 show the variability, yeah, for certification.

19 So how does that work in washers? How

20 many cycles does that end up being?

21 MS. REICH: I can comment on that one.

22 It's a lot. It's a minimum of like 12 or 14 --
131

1 MR. STEPHENS: A dozen and maybe as many

2 as 16 or more?

3 MS. REICH: Oh, no. More than.

4 MR. STEPHENS: -- depending on the

5 results.

6 MS. REICH: Yes. It's a very

7 significant burden.

8 MR. DENKENBERGER: And how many units

9 does that end up being on?

10 MS. ARMSTRONG: Two or more.

11 MR. MOUW: Two or more. Typically, more

12 than two.

13 MR. DENKENBERGER: So I think that sets

14 the context that there is a significant number of

15 tests for washers, and on the dryer side, the testing

16 burden has been less but now it looks like washers

17 have gotten much more efficient and there are more

18 energy savings opportunities in dryers. So we feel

19 that some increase in testing burden to get more

20 realistic energy savings estimate is justified.

21 MR. STEPHENS: Though if we can find

22 ways to minimize it, we certainly should.
132

1 MR. MOUW: And I think -- This is Nate.

2 I think it goes back to, again, what's the desired

3 outcome, the output or the input, right? I mean, I

4 think what I'm hearing from utilities is they want a

5 realistic estimate of what's going to be seen in the

6 field. What's actually going to be the energy

7 consumed in the field; is that an accurate --

8 MR. STEPHENS: That's one of two. The

9 other one is because we assume and we've seen

10 evidence that some are better at this than others,

11 some dryers do a better job than others, my clients,

12 my funders, also want to know, which are the better

13 ones reliably so that they can use the ratings to

14 tell, to help people identify which ones are the more

15 efficient ones.

16 MS. ARMSTRONG: Sure.

17 MR. STEPHENS: Reliably. So it's has to

18 -- it's not just the field conditions. They have to

19 appropriately differentiate the performance of the

20 various technologies and models out there.

21 MR. BROOKMAN: A comment from Chris

22 Badger, "Some manufacturers are stating that by
133

1 reducing the power (temperature) and better stability

2 of temperatures, they are getting more consistent

3 drying of all the clothes in the dryer. Are we

4 forcing dryness to overdry and waste energy

5 unnecessarily?"

6 MR. STEPHENS: Dave, what was the drying

7 time when it was just air dry, four hours and

8 something?

9 MR. DENKENBERGER: Yeah. Yeah. So --

10 MR. STEPHENS: Huge CEF. I think the

11 CEF was over 8 or something.

12 MR. DENKENBERGER: Yes. Roughly double

13 conventional drying.

14 MR. STEPHENS: But I think we were

15 concerned about lint production.

16 MR. BROOKMAN: You're beating up those

17 clothes, so --

18 MR. STEPHENS: Well, yeah. I mean, you

19 know, you tumble them for four and a half hours, low

20 temperature, super efficient, but the clothes may

21 suffer. So I think there's some sort of a happy

22 medium there somewhere.
134

1 MR. DENKENBERGER: Yeah. And related to

2 that, there's also, the dryer is bringing in, well,

3 bringing in air from the room but then exhausting it

4 outside, which has to be replaced. So we have

5 investigated a little bit on what the heating,

6 ventilating and air conditioning impacts with the

7 dryer are and we understand that they are very

8 climate dependent but we think that a simple test

9 procedure revision would just measure the air flow

10 rate of a dryer so that utilities or whatever could

11 take that information into account if they wanted to.

12 MR. BROOKMAN: Chris Badger makes an

13 additional request for review. He asks, "Request

14 that DOE also review product categories to reflect

15 the market introduction of standard sized ventless

16 dryers in North America."

17 MS. ARMSTRONG: That is outside the

18 scope of the test procedure.

19 MR. STEPHENS: Outside the scope of the

20 test procedure.

21 MS. ARMSTRONG: When it's appropriate.

22 MR. STEPHENS: Product classes is
135

1 outside the scope of the test procedure?

2 MS. ARMSTRONG: No. I mean, the test

3 procedure should be able to characterize the

4 performance of products on the market period, across

5 the board.

6 But we don't necessarily design a test

7 procedure for product classes, right? Product

8 classes are more something that, you know, with the

9 impact of consumer utility and how that affects the

10 performance of a unit would be considered different.

11 MR. STEPHENS: You would, but I would

12 argue that some water heaters belong in a different

13 product class, for instance, a split system water

14 heater, and the test procedure wouldn't be the same,

15 either.

16 MS. ARMSTRONG: I mean, the test

17 procedure for some water heaters, since you want to

18 bring up that example, I mean, we have, depending on

19 the capacity of the water heater, depending on the

20 input rate, depending on flow rates, we have

21 different buckets. Those aren't products classes in

22 our standards, but we accurately change how they are
136

1 tested to better reflect the way they are used in the

2 field.

3 So I don't think it's a product class

4 issue. I think the dryer test procedure should be

5 able to accurately test all the products out there,

6 the different technologies out there and how they're

7 -- and be representative of how they are used.

8 MR. STEPHENS: True, but you just

9 changed the water heater test procedure to change the

10 test conditions for the different product classes.

11 MS. ARMSTRONG: It's not just product

12 classes. I did far more than that.

13 MR. STEPHENS: Well, I know, but we're

14 talking about product classes and what gets tested

15 how, and I think there is a ventless dryer class with

16 a separate standard but I'm not familiar right now

17 with why it's in its own class.

18 MS. ARMSTRONG: I guess that would be

19 discussion for the --

20 MR. STEPHENS: It's my impression that

21 previously, all the ventless dryers were typically

22 condensing dryers.
137

1 MS. ARMSTRONG: Exactly.

2 MR. BROOKMAN: Dave.

3 MR. STEPHENS: And that continues to be

4 true.

5 MR. DENKENBERGER: The other thing I'd

6 like to bring up for discussion is something I

7 mentioned in the opening statement, which is looking

8 more holistically at the energy use of dryers rather

9 than just site energy.

10 So, for example, in natural gas dryers,

11 they actually turn out to be less efficient on a site

12 energy basis due to the fact that the energy value is

13 the higher heating value, so it's not able to count

14 the condensing the moisture from the combustion,

15 whereas if you look at a source energy perspective,

16 the natural gas dryers are much more efficient than

17 convention electric resistance dryers. I would just

18 like to open that up for discussion.

19 MR. BROOKMAN: Okay. Thank you.

20 Additional comments on that point?

21 MR. STEPHENS: Our funders would

22 strongly disagree with that.
138

1 MS. ARMSTRONG: It's Definitely a point

2 of contention.

3 MR. STEPHENS: Especially the ones that

4 get 100 percent of their power from a hydro dam.

5 MR. BROOKMAN: Hydro. Yeah.

6 MR. DENKENBERGER: Sure. So it depends

7 on your source of electricity, but if we look, at

8 least doing some calculation or recognition of source

9 energy, and it could be on energy costs or it could

10 be on CO2 emissions, in which case, if you're

11 hydropower, then electric dryers do look better than

12 natural gas but at least some recognition of that

13 rather than strictly using site energy we think would

14 be valuable.

15 MS. ARMSTRONG: I think this was just a

16 little bit broader than the scope of the dryer test

17 procedure specifically. It has come up more broadly

18 from a variety of different stakeholders that have a

19 variety of different opinions. DOE has issued its

20 opinion with regard to full FFC cycle and how it will

21 consider it, so I would say go there. That's not

22 something --
139

1 MR. DENKENBERGER: Could you summarize

2 the opinion?

3 MS. ARMSTRONG: I'll point you to the

4 right direction. It's easier that way.

5 MR. BROOKMAN: Final comments.

6 MS. ARMSTRONG: It is long, and it was

7 carefully worded so I would prefer not.

8 MR. BROOKMAN: Additional comments here

9 as we move towards closing out and maybe we could go

10 to the final slide.

11 MR. STEPHENS: I have a question.

12 MR. BROOKMAN: Yes, Charlie.

13 MR. STEPHENS: PNNL and ORNL have done

14 some work. Are there plans for them to do any more

15 work?

16 MS. ARMSTRONG: I don't know. Not right

17 now. I think there is plans to do more work. As far

18 as where it's going to be done, unsure yet in terms

19 of next steps.

20 With this effort, what exact testing

21 we'll do, where we'll do it, which labs will conduct

22 them, we have worked with them on going now for other
140

1 types of research products.

2 MR. STEPHENS: Okay. I'll just say that

3 we're going to continue our field research and our

4 lab research, and all of the data will be made

5 available as soon as it becomes available. It's all

6 downloadable from our web site, including the data

7 itself from the field study, and we'll try to do that

8 with everything we do. We'll put up the electronic

9 data on the site. I'll make sure it gets shipped to

10 the individuals around the table here who are

11 directly interested in it. But all of our data will

12 public.

13 MR. BROOKMAN: Okay. Thank you,

14 Charlie.

15 Daniel Lapato says, "What about

16 co-labeling appliances with source and site?"

17 MS. ARMSTRONG: So I would say labeling

18 for most residential appliances, the best answer to

19 the question is, the labeling for most residential

20 appliances resides under the authority of the Federal

21 Trade Commission, so to the extent you have

22 suggestions about how products should be labeled,
141

1 especially with regard to certain residential

2 appliances, you need to to direct your attention

3 there.

4 MR. BROOKMAN: Okay. Thank you.

5 Yes, David.

6 MR. DENKENBERGER: Related to follow-up

7 work, could you give an idea of schedule, how this

8 might progress? When do you need data next?

9 MR. STEPHENS: When do you need data? I

10 mean, I know you want it as soon as you can get it.

11 MS. ARMSTRONG: We always need data.

12 Today. Today. As soon as possible.

13 MR. STEPHENS: When is it too late or

14 when is it likely to be too late?

15 MS. ARMSTRONG: So the comment period

16 date is until December officially for this.

17 Obviously, to the extent you want to inform our test

18 plan or what type of investigative testing, that's

19 when we would be taking input for that, by that date.

20 If you have data that suggests we should

21 be testing a certain way or should investigate a

22 certain thing or want to make a case, that's when you
142

1 would do it.

2 You are welcome to submit ideas anywhere

3 along the process. I don't know exactly our next

4 step. Obviously, at some point it will be a proposed

5 rule. Likely it will not be -- it will probably be a

6 year from now, as our normal processes are about two

7 to two and a half years long, depending on the topic.

8 MR. STEPHENS: So by the end of 2015

9 would be --

10 MS. ARMSTRONG: I'm doing this

11 completely ad hoc, but the end of 2015, beginning of

12 2016 maybe.

13 MR. STEPHENS: That's helpful. That's

14 helpful for us for scheduling our research and our

15 budgets so that's good. Thank you.

16 MS. ARMSTRONG: Obviously, we make

17 decisions well in advance of that date, but yes.

18 MR. STEPHENS: Okay.

19 MR. BROOKMAN: Closing remarks? Okay.

20 MR. BERRINGER: We have got the last

21 slide up here. As we talked about, the transcript

22 will be made part of the docket, so it will be
143

1 available.

2 Also, the slides will also be a part of

3 the docket for today's meeting. Again, we ask that

4 written comments be submitted by December 15, and you

5 have the e-mail address. If you want to mail them,

6 you have Brenda Edwards' address at the Department of

7 Energy as far as that, and also, if you're going to

8 courier the comments, then also you can send those to

9 Brenda at the information here.

10 At this time we just want to thank

11 everybody for their participation today and I thought

12 it was a good discussion. Thank you, everybody.

13 MR. STEPHENS: Thanks for having the

14 meeting. Very helpful.

15 (Thereupon, at 11:32 a.m., the meeting

16 was concluded.)

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1 REPORTER’S CERTIFICATE

2 

3 I, LU ANNE DAWSON KIRKLAND, do hereby certify that

4 the within transcript is a true and accurate record of the 

5 proceedings in the above-entitled matter.

6 I further certify that I am not a relative, 

7 employee, attorney or counsel of any of the parties to 

8 this action and that I am in no way interested in the 

9 outcome of this matter.

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12 ___________________________

13 LU ANNE DAWSON KIRKLAND

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