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U.S. DEPARTMENT OF ENERGY 1

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RESIDENTIAL CLOTHES DRYER TEST PROCEDURE 3

RULEMAKING MEETING 4

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PUBLIC MEETING 6

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Thursday 9

November 13, 2014 10

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The Public Meeting met in Room 4A

- 104 N orth, 12

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

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

presiding. 15

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PRESENT: 17

DOUGLAS BROOKMAN, Meeting Facilitator 18

BRYAN D. BERRINGER, Project Manager, 19

DOE 20

ASHLEY ARMSTRONG, DOE 21

SARAH BUTLER, Office of General Counsel, DOE 222

ALEX KROWKA 1

JAMES BATTAGLIA, Associate Director, Energy, 2

Navigant Consulting, Inc. 3

JUDITH REICH, Associate Director, Energy, 4

Navigant Consulting, Inc. 5

CHARLIE STEPHEN S, Senior Energy Codes and 6

Standards Engineer, Northwest Energy 7

Efficiency Alliance 8

NATE MOUW, Director, Regulatory Affairs, Whirlpool 9

Corp 10

JOANNA MAUER, Technical Advocacy Manager, 11

Appliance Standards Awareness Project 12

SRIRAM GOPAL, Policy Analyst 13

STEPHEN B. LEYBOURN, Regulatory/Product Engineer, 14

Association of Home Appliance Manufacturers 15

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

ECOVA 17

MANFRED STAEBLER, BSH Home Appliance Corporation 18

MELISSA FIFFER, Appliance P roduct Manager, U.S. EPA 19

JESSICA M. LYMAN, Associate, ICF International 20

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WEBINAR ATTENDEES ON THE RECORD: 1

CHRIS BADGER 2

EILEEN EATON 3

JONATHAN GATZKE 4

CHRISTOPHER GRANDA 5

DANIEL LAPATO 6

RENATA MORTAZAVI 7

CURT TREMEL 8

RAVEENDRAN VAIDHYANATHAN 9

CHRISTOPHER WOLD 10

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

9:04 A.M. 2

MR. BERRINGER: Hello, everybody on the 3

line. This is Bryan B erringer for the DOE. We are 4

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

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

start off with Doug. 7

MR. BROOKMAN: Good morning, everyone. 8

Welcome. Glad to see you here. 9

This is the Notice of Public Meeting 10

Residential Clothes Dryers Test Procedure. Today is 11

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

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

Solutions, Baltimore. Good to see y ou. We are going 14

to start off with welcoming remarks from Bryan 15

Berringer. 16

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

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

I have been with the Department for about 20 years 19

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

too loud for everybody? We just want to thank 21

everybody for participating today in person and also 225

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

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

participation. 3

This is really kicking off the test 4

procedure rulemaking for clothes dryers, so we are 5

really looking today to get your input to talk about 6

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

test procedure a better t est procedure today. So we 8

are really looking later on to have an open 9

discussion, round table discussion, about what's 10

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

these test methods will be used for the energy 12

efficiency rating for Federal standards and also for 13

the ENERGY STAR program. 14

Again, are there any questions or 15

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

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

introductions a nd review. 18

MR. BROOKMAN: We always start with 19

introductions, names and organizational affiliations. 20

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

voices today. 226

MS. BUTLER: Sarah Butler, DOE. 1

MR. STEPHENS: Charlie Stephens, 2

Northwest Energy Efficiency Alliance. 3

MS. MAUER: Joanna Mauer, Appliance 4

Standards Awareness Project. 5

MR. DENKENBERGER: David Denkenberger, 6

ECOVA, representing California Investor Owned 7

U tilities. 8

MS. FIFFER: Melissa Fiffer, EPA, ENERGY 9

STAR Appliances. 10

MS. LYMAN: Jessica Lyman, ICF 11

International in support of ENERGY STAR Appliances. 12

MR. KROWKA: Alex Krowka. 13

MR. STAEBLER: Manfred Staebler, BSH 14

Homes Appliances. 15

MR. LEYBOURN: Stephen Leybourn. I'm 16

with the Association of Home Appliance Manufacturers. 17

MR. MOUW: Nate Mouw with Whirlpool. 18

MS. REICH: Judith Reich from Navigant 19

Consulting. 20

MR. BATTAGLIA: James Battaglia from 21

Navigant. 227

MR. BROOKMAN: Thank you. All of you 1

received a packet of information when you came in the 2

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

Immediately following this agenda review, there is an 4

opportunity for opening remarks, brief summary 5

comments here at the outset about issues that matter 6

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

and discussion on regulatory history a nd background, 8

and directly from there, potential test procedure 9

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

Probably we will take a break mid

- morning somewhere 11

in there around about 10:30 or so. 12

As reflected in the agenda, at th e end 13

of the day, whenever we get through all this 14

material, there is yet another opportunity for 15

comment. You get another opportunity for you to 16

raise any additional issues you think have not been 17

covered sufficiently during the course of the 18

discussion this morning. 19

We welcome all of you that are joining 20

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

opportunity to participate during the meeting today, 228

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

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

Please say your name for the record each time you 3

speak. 4

There will be a complete transcript of 5

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

time and turn your cell phones on silent mode. 7

Please limit sidebar conversations. 8

Webinar participants, if you would turn 9

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

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

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

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

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

questions. Our web master will write them up 15

and we will include them in the discussion here. 16

And then, as I said, this meeting is 17

provided live via the internet. The webcast is made 18

available to accommodate all the stakeholders who 19

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

Department of Energy makes a special request. Those 21

that are joining the meeting via th e web, the 229

Department still wants you to submit your written 1

comments. So please do that in addition to 2

participating this morning. 3

Do you want to do the purposes of the 4

meeting? 5

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

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

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

potential changes to the current test procedure for 9

clothes dryers, discuss the next steps in the 10

rulemaking, invite participation to provide summary 11

comments or statements that arise for additional 12

issues and discussions. 13

And we, the comment period, we invite 14

comments that, written comments, to anything if we 15

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

December 15th, we would like written comments. 17

There is also a question on the webinar, 18

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

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

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

really today we are looking at having an open 2210

discussion of where we need to go for the test 1

procedure test method for the future moving forward. 2

We also

-- that was a question on the 3

webinar. Any other questions at this po int? Okay. 4

At this point I think we are going to, 5

we have stakeholder opening remarks. I know that 6

Charlie Stephens had some opening remarks, and I know 7

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

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

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

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

So at this time, I will ask Charlie to 12

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

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

It's all yours. 15

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

away from this thing just a little bit. 17

We have been doing quite a bit of 18

research at the Northwest Energy Efficiency Alliance 19

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

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

some contractor folks who have gotten very 2211

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

you here is mostly based on that field rese arch and 2

what we have been doing recently to imagine what that 3

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

reflective of what we find in the field. 5

These are all pictures, and they're all 6

meant to be nothing more than conversa tion starters 7

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

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

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

data. 11

First of all, we have been working a 12

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

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

technology. We're testing some regular standard type 15

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

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

Th is is using the D2 test protocol, and 18

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

see down there Federal Minimum at the bottom and the 20

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

Now, watch the slide shift here. Do you 2212

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

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

numbers when we add a test that more resembles the 3

clothing you see in the field. 4

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

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

as some test with heavier clothing. 7

So as you can see, the CEF ranges drop 8

pretty much across the board, though some drop a 9

little less than others, which is interesting. 10

We also are testing small loads, average 11

or medium loads and large loads and looking at the 12

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

differences are kind of startling here, as well. 14

This is a small load of real cloth ing, 15

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

is not very good. 17

This is a large load. Do you want to 18

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

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

impact on the efficiency with which the dryer dries 21

the clothes. 2213

I say all this because of this next 1

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

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

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

seeing here. 5

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

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

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

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

can see the mat rix of just what kinds of loads people 10

actually wash and you can see that the heaviest loads 11

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

were done in the field. 13

The DOE load falls in that one box right 14

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

were

-- could be characterized that way, not very 16

many, not a very big fraction. 17

A larger fraction was medium heat in the 18

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

heat was kind of the largest fraction all through, 20

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

was very much a big fraction of the way people did 2214

their laundry. 1

This is clothes, going back to clothes 2

washer here, because we belie ve that some of the 3

changes we may discuss will imply changes to the 4

clothes washer test procedure, as well, this is 5

clothes washer load size versus drum volume. 6

MR. BROOKMAN: Say how you set up these 7

individuals to test

-- 8

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

They

-- we made all these participants weigh their 10

laundry three times with every load for a month and 11

keep a logbook and tell us how they set their 12

equipment, whether they took stuff out, whether they 13

used dryer sheets. It's a

-- the study report on 14

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

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

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

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

MR. BROOKMAN: Thank you. 19

MR. STEPHENS: This is from the field 20

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

size kind of goes along with the clothes washer drum 2215

size. If you buy a big washer, you'll probably have 1

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

were looking for some sort of a statistical 3

correlation between the drum size of the equipment 4

and the load size, and there it is. 5

This is the annual laundry weight versus 6

the drum size. Our conclusion is there is no 7

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

we think. 9

Again, from the field setting, here is 10

our dryer temperature and our dryness level settings. 11

They're not quite the way the test pro cedure 12

specifies as present. 13

This is the air flow rates. You can see 14

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

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

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

field before we corrected it was 6 CFM. 18

There's no comment on this particular 19

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

pointing out here is the way products are labeled and 21

set up for cycles. They're getting more complicated, 2216

a nd there are many more combinations of cycles that 1

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

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

going forward in the coming year and going on right 4

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

people actually end up picking to do their laundry 6

under what circumstances. 7

We're not done with our research, so

-- 8

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

people actually going to pick out of the many they 10

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

do to the CEF? 12

This is our further testing. We've 13

already done eight non

- ENERGY STAR dryers, three 14

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

collaborating with PG&E in Californ ia to do this 16

work. 17

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

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

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

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

the field. We have ten in the field now that we're 2217

monitoring, getting ready to monitor. 1

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

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

about today. 4

MR. BROOKMAN: Thank you. 5

Let 's have other opening remarks here at 6

the outset. Joanna? 7

MS. MAUER: I just wanted to first thank 8

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

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

be done to reduce clothes d ryer energy use, and we 11

now know that clothes dryers represent a really large 12

potential savings opportunity, but a key step to 13

achieving significant savings from clothes dryers is 14

having a good test procedure that can serve as the 15

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

consider amendments to the test procedure in advance 17

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

So thanks again for holding the meeting 19

and I look forward to the discussi on today. 20

MR. BROOKMAN: Thank you. Additional 21

comments here? Dave? 2218

MR. DENKENBERGER: Dave Denkenberger, 1

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

recent DOE work to increase the realism of the test 3

proced ure and utilizing a source energy metric. 4

We applaud the DOE for investigating 5

test procedure revisions to more accurately capture 6

the real

- world energy use of clothes dryers. 7

DOE has taken an incremental step 8

towards th e test procedure that measures different 9

settings and load compositions. In particular, the 10

AHAM 1992 load uses realistic clothing with a 11

diversity of thickness. 12

We encourage the DOE to consider further 13

opportunities to a create tes t procedure that is even 14

more representative of real

- world use in 15

collaboration with Northwest Energy Efficiency 16

Alliance. 17

We have developed four supplemental 18

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

able to ensure the repeatability of the test 20

procedure and keep the testing burden low, better 21

matching the test procedure's real

- world use and 2219

differentiating dryer energy performance. 1

Our test approach also eliminates 2

potential g aming associated with testing a single 3

cloth composition, dryer setting configuration and 4

laundry load size. 5

As there are a total of four 6

supplemental tests, the load we chose was more 7

challenging, including jeans. As Charlie mentio ned, 8

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

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

test was a medium

- sized load but tested on the 11

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

is important because eco mode can ta ke up to three 13

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

strongly recommend reporting dryer times of all 15

tests. 16

And the fourth supplemental test is a 17

medium

- sized load of realistic clothing that is run 18

using settings that dry t he clothing at the fastest 19

rate. 20

To support repeatability of the test 21

procedure, we propose a weighted average of D2 and the 2220

four supplemental tests, and overall, this has better 1

repeatability than single tests. 2

While this test is not as repeatable as 3

existing D1 tests, some limited reduction in 4

repeatability is justified in order to get an 5

overall, more realistic representation of dryer 6

energy use to enable high efficiency technologies to 7

compete fairly against one another. 8

Currently, dryer manufacturers must 9

perform roughly three D2 tests. Our proposal is one 10

D2 test and four supplemental tests for a total of 11

five. While this would increase the overall number 12

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

the number of tests required for a clothes washer. 14

We have evaluated this test procedure in 15

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

we feel this test procedure should also more 17

accurately capture the real

- world savings of 18

technologies that have not yet been commercialized, 19

such as exhaust heat exchangers. 20

We also encourage DOE to enable a 21

comparison of dryers with different fuel types by 2221

incorporati ng the use of source energy as the metric 1

for comparing dryers. 2

Natural gas represents an interim 3

technology step, especially in new construction that 4

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

is more cost effective and en ables faster drying 6

time. 7

Alternatives to source energy 8

comparisons could be based on energy costs for 9

greenhouse gas emissions. 10

We also invite the DOE to consider an 11

integrated washer

- dryer test procedure. Using the 12

same realistic clothing load we developed for dryers 13

would provide additional data on real

- world washer 14

performance. 15

Furthermore, manufacturer test burdening 16

can actually be reduced because the clothing could go 17

directly from the w asher to the dryer, avoiding the 18

labor intensive step of wetting the clothing for the 19

dryer to tight tolerances. 20

Also synergies between the washer and 21

dryer in terms of energy efficiency and cycle time 2222

could be better understood. 1

To summarize, we encourage DOE to build 2

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

load sizes, settings and clothing compositions. 4

Considering source energy would also make for a more 5

fair comparison between dryer technologies. 6

Combining the washer and dryer test procedure would 7

enable even more realism. 8

We thank the DOE for having this meeting 9

and for the opportunity to speak. 10

MR. BROOKMAN: Thank you, Dave. Will 11

you submit those written c omments? 12

MR. DENKENBERGER: Yes. 13

MR. BROOKMAN: Thank you. For the 14

record, thank you. 15

Other comments here at the outset, 16

opening remarks, any additional? Okay. 17

Let's proceed with the present ation 18

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

web, we also welcome your comments and questions as 20

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

MR. BERRINGER: We're just going to 2223

briefly go over some of the regulatory history and 1

background and again, there was questions about D1, 2

D2. 3

So again, just as far as history, back 4

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

measuring standby and off mode, defining a new energy 6

efficient metric that combined energy factor and 7

reflecting changes to consumer usage habits, which we 8

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

moisture content, the number of cycles per year and 10

the test size lo ad. 11

Then in August of 2013, there was 12

amendments to D1 to update the reference to the 13

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

clarify certain test conditions and created D2 to 15

measure the effects of the automatic cycle 16

termination. 17

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

there is questions about this. This is giving 19

background, sort of comparison between D1 and D2. 20

This particular slide, most of the standby and off 21

mode was using IEC 62301. It i s incorporated by 2224

reference. The number of cycles was 283 in both 1

cases, and the reference test standard was the AHAM 2

HLD

- 1

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

detergent and other things didn't really change 4

there. 5

The next slide, there was a little bit 6

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

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

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

some changes there. 10

Are there any questions as far as 11

between D1 and D2? 12

MR. BROOKMAN: This is a good slide. 13

This is a good explanatory. This is good. 14

MS. ARMSTRONG: Ashley. 15

This is just a high

- level summary. 16

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

refer to the actual language in the test procedure, 18

but this is just a high

- level summary of what is in 19

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

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

S o the purpose of today is really about what the next 2225

step is, and as Joanna said so nicely, it is

-- DOE 1

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

standard rule. We have heard some feedback on the 3

dryer test procedure and we're really look ing for 4

starting points and buy

- in now, early in the process, 5

as we move forward with this test procedure revision 6

or at least evaluating whether there should be a test 7

procedure revision, kind of what the purpose of today 8

is. 9

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

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

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

cool down and field use factors, there were some 13

changes there. There was no field use factors used 14

in D2. 15

So with that said, there really is, as 16

Ashley just reiterated, the reason for the further 17

discussion is for interested parties to have comments 18

about the clothes dryer tests that may not produce 19

results that are representati ve of consumer use with 20

regard to test load size, composition cycles of 21

settings for the test cycles and other provisions for 2226

the test procedures. 1

Manufacturers have mentioned that test 2

load types and test cloth are different for tho se 3

specified in DOE test procedure, do not result in 4

repeatable compared to those using the test load, so 5

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

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

something we can bring up as far as i t was already 8

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

discussion, and also DOE is interested in finding 10

solutions to what works for all parties which provide 11

test procedure that differentiates products on the 12

market and provides consumer information about dryer 13

usage as seen in the field and is repeatable and 14

reproducible. 15

Also, just a little bit of background. 16

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

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

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

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

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

those, but basically, characterize the current 2227

clothes dryer performance using D1 and D2 with 1

different test loads and evaluated the current 2

automatic cycle termination sensors and potential 3

energy savings through improved sensors and control 4

strategies. 5

So and again, Oak Ridge and the PNNL 6

report are available for review a nd discussion. Were 7

there any comments about those particular reports in 8

general, about what was done in those studies? 9

(No response.) 10

MR. STEPHENS: It's good. 11

MR. BROOKMAN: It's good. 12

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

work. 14

MR. BROOKMAN: Thank you. 15

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

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

looking for today is discussion. 18

Would you l ike to like to sit here. 19

MR. BATTAGLIA: I can come up. 20

MR. BERRINGER: I can bring it down 21

there. 2228

MS. ARMSTRONG: This is where you guys 1

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

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

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

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

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

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

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

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

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

investigative testing to figure out what we are, the 11

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

little bit a couple of different methods, a couple 13

different options. 14

This is your chance to chime in on that. 15

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

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

typically held these types of meetings always for 18

test procedures, but since people seemed to have a 19

lot of opinions about dryers, we thought this might 20

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

MR. BROOKMAN: That was Ashley 2229

Armstrong. 1

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

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

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

them. 5

MR. BROOKMAN: James Battaglia. 6

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

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

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

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

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

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

discussing what we have put together here. 13

MR. BROOKMAN: One question here at the 14

outset, Chris Badger asks

-- I think it's Badger

-- 15

Will the data be made available in digital format? 16

MS. ARMSTRONG: The data from the PNNL 17

and Oak Ridge studies? 18

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

was referring t o. 20

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

think we had any intention of making it available. I 2230

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

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

have pretty detailed descriptions of the data and the 3

results so

-- 4

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

Back to James. 6

MR. BATTAGLIA: So first topic of 7

discussion was the composition of the test load, and 8

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

highlight, the current provisions, the current test 10

method has 24

- by 36

- inch test cloth. It's made up 11

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

we're opening up the discussions for what 13

alternatives we should be considerin g. 14

We just highlighted a few that people 15

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

towels, t

- shirts, shorts and a few other components 17

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

pillow cases and towels. 19

And we just included a visual from a 20

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

and on the right is the 1992 load. 2231

MR. BROOKMAN: Let's get comments here 1

on test load composition. Do you like the current 2

co mposition? 3

MR. STEPHENS: By itself, no. 4

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

wanted to hear. 6

MR. STEPHENS: Yeah. I think

-- Charlie 7

Stephens from NEEA. 8

I think we've concluded that while t he 9

current test load is not useless, it actually could 10

represent a fairly broad swath of the kinds of loads 11

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

representative. 13

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

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

in those tests is higher typically from what we 16

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

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

CEF certified, then that greater amount of variability 19

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

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

But it will, we think, I think

-- I'm 2232

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

I believe the difference between our fiel d CEF and 2

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

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

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

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

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

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

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

And so we think it ought to be 10

corrected, especially, we think, because some 11

pr oducts, some dryers, some models, may do better and 12

some cycle management, some controls, may do better 13

at drying these heavier clothes than others and we 14

would like to see those differences show up in the 15

ratings for the dryers. 16

MR. BROOKMAN: Can you be specific about 17

how you would like the load to change? 18

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

tested four different loads using real clothing, a 20

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

it's either th e mode that the manufacturer says is 2233

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

efficient mode available on the dryer. 2

Then we tested it with the fastest mode, 3

which tends to be just electric resistance like a 4

typical dryer w ith auto termination in the dryers we 5

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

different tests with real clothing to see if we can 7

find relationships among these things. 8

We're not necessarily at this point 9

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

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

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

the tests you would do, given appropriate weights in 13

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

rating that was more reflective of how the thing will 15

actually work in the field. 16

MR. BROOKMAN: Okay. 17

MR. STEPHENS: With regard to clothes 18

composition. 19

MR. BROOKMAN: We have a couple of 20

comments from individuals on line. Chris Badger 21

writes, "It will help develop a D2 baseline for 2234

existing dryers," and Chris Wald from CLASP, 1

C

- L

- A

- S

- P, "Have you looked at the European test 2

load?" 3

MR. BATTAGLIA: So I think the 4

European

-- 5

MR. BROOKMAN: James Battaglia. 6

MR. BATTAGLIA: Yeah. Sorry. James 7

Battaglia. I guess the European, the IEC test 8

procedure in part uses a load composed of the AHAM 9

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

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

hasn't looked at that, at least. 12

MR. STEPHENS: Well, one of the chief 13

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

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

They do ess entially a sliding scale. 16

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

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

the larger the load of that particular fabric mix. 19

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

so there are some differences in composition. 21

We, we evaluated that. I think Dave, 2235

you guys looked at the IEC load awhile back. 1

MR. BROOKMAN: So that was Dave. That 2

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

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

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

least in terms of composition. 6

They

-- the cotton IEC load, that is. 7

So we think it provides some diversification from the 8

DOE load bec ause of it being 100 percent cotton, but 9

we found that the thicknesses were very similar of 10

the three articles so it's less challenging because 11

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

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

representative, because it did have a diversity of 14

thicknesses and was higher cotton content. 15

MR. BATTAGLIA: So Charlie, I just have 16

a question. 17

MR. STAEBLER: This is Manfred Staebler 18

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

but I have a question concerning the test load and 20

the drum size. 21

You know, you mentioned you know in 2236

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

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

you know, this sliding scale because we have 3

different volumes of dryers, and if this is of 4

influence, if you want really to compare how 5

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

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

a fixed test load no matter what volume the dryer 8

has? 9

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

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

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

really much of a correlation b etween washer volume 13

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

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

Do you think there should be a sliding 16

Scale? 17

MR. STAEBLER: Maybe I have to correct 18

myself. It's not th e correlation between washer and 19

dryer. It is the correlation you have different 20

dryer sizes. 21

MS. ARMSTRONG: Yeah. I think what 2237

James is trying to say is that in the field

-- you 1

correct me if I'm wrong

-- but Charlie presented th at 2

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

there was no real correlation between the load sizes 4

that consumers put in the drum versus the sliding 5

scale or the larger size of the drum itself. 6

So you know, the sliding scal e, does it 7

really mean consumers are going to, you know, 8

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

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

more of what consumers would do or a multiple, 11

multiple fixed size loads rather than the sliding 12

scale based on dryer drum capacity. 13

MR. STEPHENS: For clothes washers, 14

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

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

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

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

divergence. 19

MS. ARMSTRONG: Right. So I would say 20

that's pretty close. 21

MR. STEPHENS: But the variance was 2238

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

of, if you compartmentalize those things into small, 2

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

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

very many big loads on high heat. 5

There were actually far more smaller 6

loads than we were expecting. That was the big 7

surprise in our study. 8

MS. ARMSTRONG: You need to come 9

instrument my house now that I have two little 10

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

your high heat large loads real quickly for your data 12

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

MR. STEPHENS: Well, we have some of 14

those. 15

MR. BROOKMAN: You should be in my 16

house, with two of us. 17

M S. ARMSTRONG: I cram it in whenever I 18

have time. 19

MR. BROOKMAN: High heat. Okay. That 20

was Charlie Stephens. Now Nathan. 21

MR. MOUW: Yes. Since we're referencing 2239

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

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

selected the participants, how you

-- 3

MR. STEPHENS: Sure. They were, the 4

participants were drawn from the larger residential 5

building stock assessment sample, which started out 6

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

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

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

we wanted some statistical significance. 10

We have all the demographics that go 11

along with this. We had all the demographics for 12

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

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

The only place where we skewed the data 15

was because we wanted the data to be releva nt going 16

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

equipment that was 2005 or newer. 18

So 30 percent of the equipment was top 19

loading and 70 percent was front loading, so you 20

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

there. 2240

MR. MOUW: Were they in one select 1

region or were they nationwide? 2

MR. STEPHENS: They were in four states 3

in the Pacific Northwest. Dryer performance we think 4

probably will vary by portions of the region or 5

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

maintaining that it's representative country wide, 7

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

too different except for select places. 9

MR. MOUW: Demographics associated 10

with

-- 11

MR. STEPHENS: Household size, you know, 12

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

sheets are sheets and towels are towels probably 14

nationwide. How many do you wash and what your 15

relative humidity is where you live and w hat altitude 16

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

bit. 18

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

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

reference is making. 21

MR. STEPHENS: Yeah. And it was done 2241

over a four

- week period in the, kind of the shoulder 1

period between about February and the end of April in 2

these households. They kept a log. 3

We measured the clothes washer as well 4

as the dryer to make sure we could correlate load 5

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

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

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

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

always meter the washer and the dryer, we'r e 10

discovering there's a large discrepancy between loads 11

and cycles. 12

We measure the loads in the clothes 13

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

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

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

see. 17

MS. ARMSTRONG: Wouldn't you assume

-- 18

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

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

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

of my clothes coming out of my washer up, so my dryer 2242

load is different always than my washer loads. 1

MR. STEPHENS: I think we found 2

something on the order of 9 percent of washer loads 3

were not dried, but we al so found that many loads 4

were

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

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

We found very little difference in the 7

dryer energy use between manually terminated or timed 8

drying and a uto sensing. We

-- there were a lot of 9

things. 10

We found, except in the initial part of 11

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

cycle, almost no difference between the actual heat 13

produced by the dryer and the setting between medium 14

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

temperature was within ten degrees no matter what you 16

chose. 17

There were different cycling behaviors 18

of these things. We found that standby energy 19

consumption was very low for dryers. It was more 20

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

changing. 2243

There were a lot of things that kind of 1

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

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

the differences. 4

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

as a result of this? 6

MR. BROOKMAN: Nathan, louder. 7

MR. MOUW: Okay. What were we 8

surprised about from the study? 9

MR. STEPHENS: We were surprised I think 10

first and foremost by the number of smaller loads 11

that people were actually doing. We expected people 12

would be filling the machines, and we thought there 13

might be more correlation between the size of th e 14

machine and the loads that people were doing, and 15

that correlation really wasn't there. 16

The variance didn't surprise us. 17

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

load size and composition and everything else, but we 19

a lso were hopeful that with the right tweaks to the 20

test procedure, we could probably come out with 21

something that, on average, would result in our being 2244

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

we can do that, and our lab testing was ai med that 2

at. 3

MR. BROOKMAN: We have a few comments 4

from individuals joining us via the web. The first 5

is from Ravee Vaidhyanathan, who wishes to be unmuted 6

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

works. 8

MR. VAIDHYANATHAN: Thank you. Thank 9

you for not trying to pronounce the last name. 10

Can you hear me okay? 11

MR. BROOKMAN: Yes. You sound good. 12

THE WITNESS: I have a few comments on 13

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

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

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

that configuration. I think that is saying from the 17

past experience. The loads they are applying fr om 18

different sources and all these in the past that is 19

fairly difficult to maintain consistency in terms of 20

characterization. 21

So that is one, one information. Then 2245

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

is used today for the laundry, both washers and 2

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

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

moisture content and all the other things and how it 5

changes over time. 6

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

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

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

communicate this to the audience here, within this 10

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

load size which is the same as the Department of 12

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

looking into, they are looking into having not the 14

same size pieces put together but pieces that 15

normally are smaller than larger, not in combination. 16

So the main reason know why the group is 17

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

effect. The other one is notice the characteristics 19

and the moisture updates and the old release, the 20

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

test load multiple times, so today, there are some 2246

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

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

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

group is working o n coming up with an alternate load 4

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

blend and loads but having different items put 6

together. 7

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

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

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

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

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

thank you. 13

MR. BROOKMAN: Thank you. Thank you, 14

Ravee. 15

We have some additional comments from 16

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

Chris Badger who says, "Should there be alignment 18

with the clothes washer test load that incorporates 19

three separate load weights (minimum, average, 20

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

And? 2247

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

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

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

there is no correlat ion between the load size and the 4

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

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

different. 7

Now, maybe it's a percentage difference, 8

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

maybe shouldn't be multiple loads or at least 10

consideration of multiple loads for the dryer like 11

there is for the clothes washer, but identical loads 12

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

be different. 14

Now, if manufacturers for the purposes 15

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

consider something like that or

-- you know. But I 17

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

I haven't thought all the way through 19

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

opinion. I'm just trying to generate conversation 21

here, because everybody is staring at me. 2248

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

what this meeting is about. This is an exploratory 2

m eeting. This is slightly different. 3

Jonathan Gatzke writes, "It should also 4

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

distinct and varied aging procedure for the load. 6

This 7

mimics a more real

- world mixed load." 8

Okay. So thank you for that. Chris 9

Badger I guess wishes to try and speak. 10

Chris, unmute your phone and hopefully, 11

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

MR. BADGER: Can you hear me now? 13

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

MR. BADGER: Good. 15

MR. BROOKMAN: Speak. 16

We heard you and then you went away. 17

Now. Yeah. Good. 18

MR. BADGER: (Inaudible). 19

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

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

MR. STEPHENS: No. 2249

MS. ARMSTRONG: No. 1

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

the thing

-- 3

MR. STAEBLER: We can hear only alien. 4

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

again later, unfortunately. 6

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

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

-- 8

MS. ARMSTRONG: Yeah. Dial in the hard 9

line or

-- 10

MR. BROOKMAN:

-- to the webmaster. 11

So that last round of commentary was 12

very helpful. 13

Dave. 14

MR. DENKENBERGER: Yes. So just to 15

comment on t he aging procedure, so the DOE test 16

procedure says pre

- condition the clothing and then 17

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

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

every five runs. 20

But in the IEC, they ac tually want to 21

have the average age of the clothing to be constant, 2250

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

So that's what the person was referring 2

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

actually have to beat it up a little with some 4

pre

- runs before they're valid. 5

And just to clarify the work that we've 6

done for IOUs and NEEA, we followed the DOE 7

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

not doing this aging technique. 9

The other comment relative to the 10

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

NEEA field study was all on full

- sized dryers and our 12

testing has all been on full

- sized dryers and our 13

recommendations are based on that. 14

But the DOE test procedure has a 15

different load size for compact dryers, which I 16

believe are 4.4 cubic feet and smaller of a 17

three

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

that as much. 19

MR. BROOKMAN: Okay. Thank you. 20

Joanna? 21

MS. MAUER: This is Joanna. 2251

I think we encourage DOE also to 1

consider a potential change to the clothes washer test 2

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

about are relevant for both, an d related to load 4

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

that perhaps in the clothes washer test procedure, it 6

might make sense to consider fixed load sizes 7

independent of capacity, since that seems to better 8

represent what's going o n in the field. 9

MR. BROOKMAN: Okay. 10

MR. STEPHENS: And, can I add one 11

thing

-- 12

MR. BROOKMAN: Charlie, please. 13

MR. STEPHENS:

-- to follow up on what 14

was said a couple of comments ago? 15

What we believe from our own data is 16

that the variance of the dryer performance 17

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

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

stuff dwarfs the variability based on whether the 20

c lothing in the heavier loads is exactly the same as 21

it was ten loads ago. 2252

That is probably the smallest impact on 1

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

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

the drying p rocess for a complex load that might be 4

large, especially. 5

MR. BROOKMAN: Manfred? 6

MR. STAEBLER: Yes. Just to understand 7

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

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

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

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

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

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

influence. 14

MR. BROOKMAN: Dave? 15

MR. DENKENBERGER: Yes. So the data 16

were based on all full

- sized dryers, so we don't 17

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

whether the load size would be smaller. 19

MR. STEPHENS: We would have to go find 20

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

meter. It would have cost us probably half the cost 2253

of the study to find them. 1

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

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

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

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

get the same results? 6

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

go to the smallest load possible, which is still 8

representative, and make the things easier than the 9

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

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

MR. BROOKMAN: Thank you, Manfred. 12

Charlie? 13

MR. STEPHENS: Well, we may

-- Charlie 14

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

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

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

to a larg er load. 18

It may be quite impossible to do that 19

with some products. It depends on what variance we 20

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

drum, same technology, in terms of whether it's a 2254

heat pump or an electric resis tance only or whatever 1

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

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

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

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

product to product, the n no, you can't necessarily

-- 6

they might perform almost identically with a small 7

load. But you wouldn't necessarily want to 8

extrapolate that across the entire spectrum of loads 9

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

result. 11

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

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

either, so we're

-- but believe me, if we can, if 14

that turns out to be possible and it will reduce 15

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

MR. BROOKMAN: Another individual 17

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

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

washer test procedure?" 20

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

gone through that a little bit. 2255

MR. BROOKMAN: Ashley says, yes? 1

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

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

be a more representative load for dryers, should then 4

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

deserves some consideration. 6

MR. BROOKMAN: Renata follows on, "By 7

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

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

of that in our e arlier discussion, Renata. 10

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

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

and it is my opinion

-- this is Ashley from DOE

-- 13

that not the same identical load goes from the washer 14

to the dry er for a number of different reasons, some 15

of which we've talked about earlier today. 16

So to the extent we have lessons learned 17

coming out of this meeting and things we should 18

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

fine w hen we get to that point for clothes washers. 20

Luckily, we have this two

- tiered 21

standard, so that's a little bit further out in space 2256

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

MR. STEPHENS: Though I think in our 2

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

were straight from the clothes washer into the dryer 4

with nothing removed. 5

MR. BROOKMAN: Thank you, Charlie. 6

MR. STEPHENS: And nothing split. 7

MR. BROOKMAN: Dave, do you want an 8

additional comment 9

here? 10

MR. DENKENBERGER: Yeah. To comment on 11

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

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

seen more lin t production, but we actually did quite 14

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

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

found that it could be stable. 17

MR. BROOKMAN: Uh

- huh. Okay. 18

MR. DENKENBERGER : For 25 runs. 19

MR. BROOKMAN: Maybe you're leading us 20

to the next slide, which is Alternative Fabrics. 21

We can continue. 2257

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

to go back for a second. 2

MR. B ROOKMAN: Yes. Please do. 3

MS. ARMSTRONG: So what is the opinion 4

around the table on a single load versus multiple 5

loads? 6

MR. BROOKMAN: Nate? 7

MR. MOUW: Can I step back one step 8

further? 9

M S. ARMSTRONG: Yes. Please do. 10

MR. BROOKMAN: Nathan, please. 11

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

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

clarify amongst this group what we think that means. 14

Does tha t mean the inputs to the test or the output 15

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

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

ways all the time. 18

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

we're talking about represe ntative fabrics, we're 20

talking about representative results. What is the 21

desired outcome? What is, what will this group 2258

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

chose one? 2

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

a coupl e of answers on what. What is representative 4

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

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

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

dryers. We don't have ENERGY STAR dryers o r heat 8

pump dryers in the field yet. 9

So I think it's important to match what 10

consumers actually dry to have a better chance at 11

being representative of what the energy use is for 12

all technology types. 13

MR. STEPHENS: And we would agree that, 14

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

hour, we would

-- you know, I represent and Dave 16

represents a bunch of people who do kilowatt hours, 17

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

business specifical ly at the Northwest Energy 19

Efficiency Alliance of essentially building power 20

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

be. 2259

But those savings that we try to achieve 1

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

build a power plant because we think they are. 3

So we're actually pretty determined that 4

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

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

actually can trust the rating in pounds per kilowatt 7

hour to translate to kilowatt hours. 8

So we're

-- that's probably our goal, is 9

being able to understand

-- we know quite a bit about 10

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

and measured it. So we got that. 12

If we can translate that to kilowatt 13

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

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

everything we do is pretty much on average. 16

MR. BROOKMAN: I actually wanted t o ask 17

an additional question, but very briefly, 18

Christopher Wold from CLASP says, 19

"Recommendation is for DOE to test heat pump hybrid 20

clothes dryers to ensure that the new test procedure 21

works with this new tech." 2260

Now to Ashley. 1

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

had anything to say. 3

MR. BROOKMAN: Well, I thought

-- no. 4

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

question and take it back. 6

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

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

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

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

anyone can come up with inputs that a ctually are 11

repeatable but give you end results that are 12

representative, what you would call more 13

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

solution, because we would have a test procedure that 15

is repeatable and reproducible in the lab regardless 16

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

synthetic type of low composition weights, et cetera. 18

But if it gives you the results that 19

more closely match the field data that you have and 20

that you are seeking to pro vide the information about 21

savings to your utilities, I think that's the win. 2261

So I don't think you necessarily have to 1

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

to necessarily be limited to the fact that you need 3

to dry jea ns, you need to dry towels, you need to dry 4

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

people do. 6

If you could find this, you know, cloud 7

in the sky of this synthetic type of load material 8

that actually puts a more repeatable an d reproducible 9

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

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

MR. MOUW: I think

-- this is Nate. I 12

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

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

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

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

Well, doors are open in the field. So 17

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

condition, a different ambient temperature and it's 19

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

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

Well, yes, it is, but that's to 2262

translate, you know, consumer use condition to a 1

represent ative value that is reasonable to do in the 2

lab and is repeatable and reproducible. 3

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

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

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

reprod ucible but we never really describe how they're 7

different. 8

And I think we have to be very clear on 9

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

I read the report, unless somebody has some further 11

insight, I read this to be re peatability, which means 12

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

times and I tell you how different those test results 14

are. 15

That is a very different thing that 16

reproducibility, which means I test that dryer in one 17

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

again, right? 19

So I look at these results for 20

repeatability, and if we were to project a 21

reproducibility for these test conditions for this 2263

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

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

those two things. Looking at repeatability, you 3

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

see a significant increase in the

-- sorry.

-- 5

significant reduction in the repeatability, almost 6

double. 7

That's probably insignificant compared 8

to the difference in reproducibility with more real 9

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

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

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

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

batch of momie cloth that was different than the 14

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

to do real loads. 16

If we called Levi’s company and said, 17

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

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

So I think we have to balance the 20

repeatability, reproducibility with the desired 21

outcome, which I think is a representative output of 2264

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

I'll stop there. 2

MR. BROOKMAN: We have another follow

- up 3

from Ravee

-- 4

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

MR. BROOKMAN: Please do. 6

MR. BERRINGER: Bryan Berringer. 7

I have done a lot of work on the momie 8

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

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

start looking at the jeans, towels and stuff l ike 11

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

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

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

correction factor on that. 15

But that's what we found when you start 16

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

cotton shirt or a t

- shirt or a sheet. The 18

manufacturers don't track that lot to lot or 19

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

is you're talking about even more variability when 21

there's something that's, you know, between loads. 2265

We found it in momie cloth, let alone 1

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

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

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

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

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

disagreeing with the Department or anybody else in 7

the room because it provides confirmation. So 8

frequently commenters only say what they don't like 9

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

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

Now, yes, Dave. 12

MR. DENKENBERGER: So to clarify how we 13

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

conventional Lands’ End source, but this could be 15

turned into a specification with tighter tolerances, 16

so you could have very tight tolerance manufacturing 17

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

these concerns that I think we're talki ng about. 19

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

know if there is enough appreciation given to the 21

extent that both the manufacturers, and now that DOE 2266

is somewhat involved in this go

- to with the actual 1

momie cloth to get it to the specifications before it 2

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

and it's a multi

- step, time

- consuming process to get 4

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

working with us and we have things up and running 6

now, and that' s not to say we are

-- should stick 7

with momie cloth. I'm not necessarily asserting 8

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

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

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

-- 11

it's a ver y time intensive and somewhat costly 12

process. 13

So minimizing the number of variables I 14

think is something that at least DOE would be 15

interested in. 16

MR. BROOKMAN: Thank you, Ashley. 17

Charlie. 18

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

sight when you have been

-- when you're constructing 20

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

everybody was after, then the cloth variance matters. 2267

When you're

-- the fact is, in the field, the way 1

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

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

anyone would think that you could just sort of snuff 4

that out and then expect results. 5

There are

-- to match up with how things 6

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

things that somewhat resemble the way things really 8

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

technology and solutions and things that might 10

actually under those circumstances do a better job. 11

If the test never exposes that, then how 12

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

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

have to find it out in the field. 15

What I would suggest is that if you have 16

a large variability from test to test and that same 17

large variability occurs from lab to lab, then you 18

should really be looking at the variance of the 19

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

find that the variance of the average is actually 21

qui te small, even if the test to test variance is 2268

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

around within that large band, the variance of the 2

averages that people derive from four tests might be 3

actually quite small even though we all ack nowledge 4

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

machine handles that load from load to load. 6

We see it. I see it in my own 7

equipment. There are times when my washer succeeds 8

and actually managing to balance the load for the top 9

spin speed and sometimes it doesn't. 10

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

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

comes out pretty repeatable from month to month s o 13

for me in my household and most households. 14

So I'm suggesting that large test

- to

15

test variance is not the end of the world, and when 16

you get into large test

- to

- test variance, it dwarfs 17

whatever is going on with the cloth. 18

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

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

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

test, that cloth change is not going to be all that 2269

serious. 1

But the averages, a gain, the variance of 2

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

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

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

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

You can't actually draw any of these 7

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

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

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

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

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

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

fastest way to get reasonable numbers under the 14

circumstances. 15

So I don't

-- I think people are trying 16

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

current test procedure and the little variances that 18

they have engineered into that over the years and 19

extrapolate that into the other regime where we're 20

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

We're not necessarily going to get 2270

different numbers than you do, and our variance in 1

the end over several tests may not be all that 2

serious, even though the band is wide. 3

MR. BROOKMAN: Okay. Thank you. 4

MS. MAUER: This is Joanna. 5

I think your example of refrigerators is 6

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

things that I think one is that a test procedure 8

gives a reasonable representation of energy use in 9

the cas e of refrigerators' kilowatt hours, but then 10

that it also provides, tells you that this 11

refrigerator is 20 percent better than this other 12

refrigerator. 13

And I think with the refrigerators, at 14

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

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

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

sure that a dryer test procedure does both of those 18

things well, too, that it gives a reasonable 19

representation of how many kilowatt hours an electric 20

dryer might use in the field but that it also 21

differentiates dryers appropriately. 2271

And just I noticed one example in the, I 1

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

electr ic standard dryers were with the DOE test load 3

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

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

actually had a 12 percent better energy factor than 6

the other. 7

I think that's real ly key that a test 8

procedure provides that kind of reasonably accurate 9

differentiation so that we ensure that the energy 10

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

standard, that we're actually getting those savings 12

in the field. 13

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

that 12 percent difference between those two dryers 15

when you shifted the test load dwarfs the difference 16

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

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

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

percent different when you change to clothing that 20

looks more like a field load. 21

MS. MAUER: This is Joanna again. I 2272

think these differences, I think it may become even 1

more important in th e future as dryer technology is 2

changing pretty rapidly. I think the more that the 3

load can represent what people are actually putting 4

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

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

getting are actually occurring in the field. 7

And on the question of variability, I 8

guess I'm hoping that any increase in variability 9

doesn't become a barrier to an improved test 10

procedure, and whether that means addressing 11

certific ation enforcement provisions or, you know, 12

can we figure out a way to address that without 13

minimizing the concern but also not having it be a 14

barrier. 15

MS. ARMSTRONG: Would you agree that an 16

approach like we have with refrigerators

- - I mean, I 17

think what

-- the caution here is that we want people 18

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

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

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

idea that you don't hav e yet but could be out there, 2273

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

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

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

keep the variability somewhat in check. 4

Because li ke you said, I mean, the 5

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

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

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

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

through standards , and as soon as we go through 10

standards, you will want us to enforce those 11

standards. Variability matters a lot for that. You 12

know, I will acknowledge it. 13

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

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

and use

-- in order to find something potentially 16

noncompliant. That's just not how our provisions 17

work. 18

And could we down the road address 19

certification enforcement provisions? Sure. I mean, 20

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

variability comes significant changes to those 2274

standards tendencies and so on and so on. 1

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

should open

- minded on both sides. 3

MR. BROOKMAN: Manfred. 4

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

agree also with Nathan and Ashley. From the test 6

procedure, we have to acknowledge it is a lab 7

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

variabil ity. I want to be as close as possible, you 9

know, and repeatable. 10

I use the example with miles per hour on 11

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

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

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

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

is it under a lab condition? 16

And I think the same thing we have to do 17

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

it has to be repeatable. W hen you want to draw now 19

conclusions about your utilities and about the power 20

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

than in the Southeast, because you might have 2275

different clothes, you have different climate, you 1

have

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

factor what does your current location differ from 3

that lab environment? 4

My point is also we have to reduce this 5

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

procedure. And if y ou find a better way of keeping 7

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

close is one thing. 9

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

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

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

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

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

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

repeat what I thought I saw. 16

If you look at energy factor, and this 17

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

you know, does the test procedure adequately 19

differentiate between models, right? 20

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

is better than model B if model A truly is better 2276

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

think this plot does a pretty good job of showing 2

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

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

you look at that plot, the orange is alwa ys on the 5

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

What that means is the orange model, 7

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

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

always rated the worst. 10

The silver model was always rated right 11

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

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

I think these are individual data points, right? 14

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

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

it's probably going to look even cleaner at 17

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

So I think this data, anyway, shows 19

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

differentiate between models, and the comment that's 21

made in the report, it says, one of the summary bullet 2277

points says the DOE load is a good predictor of 1

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

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

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

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

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

MR. STEPHENS: Except that I'm seeing 7

that there is quite a di fference of the impact of the 8

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

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

almost no impact. 11

But if you look at the standard one, the 12

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

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

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

But look at the one right above it. It 16

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

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

large. 19

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

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

individual data points. They're not averages, right? 2278

So if there's a standard deviation of 4 1

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

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

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

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

that point and then drew the range which you expect 6

just test

- to

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

know, I think that would resolve some of the 8

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

These are individual data points, ri ght? 10

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

be, as I think you were saying earlier. 12

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

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

variability, we start to see what it lo oks like, but 15

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

don't know. 17

MR. DENKENBERGER: Yes, and this is 18

Dave. We have found that changing the load 19

composition can change the order of the efficiency of 20

dryers. 21

So in this case, you've pointed out that 2279

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

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

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

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

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

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

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

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

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

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

our refrigerator test procedure is great, but with 11

the new refrigerator test procedure that came in, 12

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

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

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

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

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

that's reasonable, a reasonable outcome. 18

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

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

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

out there, that the rank order stays the same. Sure, 2280

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

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

there that switch rank order for whatever reason. 3

That's going to happen, period. 4

MR. STEPHENS: We agree. 5

MR. BROOKMAN: Charlie Stephens. 6

MR. STEPHENS: We agree

-- 7

MS. ARMSTRONG: I mean, that's the

-- 8

MR. STEPHENS: We agree, but if the 9

difference comes from this load of clothing in the 10

test procedure that is only representative of half of 11

the clothes that people actually wash, an d then when 12

you actually change the test procedure to include 13

clothes that they actually wash or something like 14

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

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

because the change came from a b etter reflection of 17

reality. 18

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

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

things in the test procedure that could be done 21

differently to get to the end result of

-- what I 2281

think you'r e asking for is more representative of 1

field use. 2

Now, what that means for the inputs, I 3

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

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

will change rank order, period, I mean, wi th whatever 6

test procedure you're going to use. 7

You're not going to have

-- 8

MR. DENKENBERGER: So

-- this is Dave. 9

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

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

the more realistic clothing. 12

MS. ARMSTRONG: I can give you a 13

different rank order if I go test dryers in the 14

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

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

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

helpful data, but we have to also understand that 18

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

I could get a different rank order. So 20

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

chasing? Depending on where you're taking those 2282

field studies, what your population looks like

-- and 1

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

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

different rank order, so to tell the Depart ment, 4

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

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

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

MR. MOUW: I think the other thing

-- 8

this is Nate

-- the other thing you have to recogni ze 9

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

Manufacturers, if you looked at rated values out 11

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

values, right? 13

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

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

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

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

rating, right? 18

Because there is general bundling of 19

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

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

able to assign a value to that test? Given that, 2283

what impact will that really have on consumers when 1

they actually go to purchase a dryer, okay? 2

I think what we want to do is have a 3

system that results in ratings that consumers can use 4

to influence purchasing decisions, but if there's 5

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

value by doing so. 7

MR. STEPHENS: I would point at the 8

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

when you see changes in the actual ratings of that 10

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

those tests has a pretty significant impact on the 12

performance of the machine. 13

And if you haven't, s omehow

-- if the 14

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

right

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

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

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

terms of EC2, G S1, those things aren't that close. 19

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

too large. 21

MS. ARMSTRONG: Well, what load do you 2284

think is representative of, more representative, of 1

the field in that graph? 2

Bec ause if you argue it's the '92 load, 3

the 3.19 and the 3.15 are pretty close. 4

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

MR. DENKENBERGER: The '92. 6

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

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

the silver line are pretty close. 9

MR. STEPHENS: Some are. 10

MS. ARMSTRONG: Well, some are and some 11

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

MR. STEPHENS: Yeah. The 3.14 and 2.94 13

aren't that close. 14

MR. BATTAGLIA: Again, part of that 15

could be due to the test

- to

- test variations. 16

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

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

These numbers could change rather dramatically. I 19

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

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

MR. BROOKMAN: Christopher Granda has 2285

been patient. This comment came in probably 20 1

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

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

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

test procedure should be designed to measure dryer 5

performance under a realis tic range of conditions," 6

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

presented by Charlie Stephens, profound implications 8

for the test procedure. The approach to the test 9

procedure may need to be fundamentally rethought to 10

reflect the high variance in load size and initial 11

RMC." 12

And then Chris Badger asks a question 13

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

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

queue ready to respond to this. 16

"Does the IEC test currently use an 17

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

repeatability and reproducibility? If this is closer 19

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

approach?" 21

That's Chris Badger asking Ravee and any 2286

other, anyone else who wishes to comment. 1

But Ravee, if you can unmute your phone, 2

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

MR. VAIDHYANATHAN: Can you hear me? 4

MR. BROOKMAN: Yes. Good. 5

MR. VAIDHYANATHAN: Okay. I think the 6

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

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

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

How's that? 10

MR. BROOKMAN: And then you had an 11

additional comment? 12

MR. VAIDHYANATHAN: Yeah. I think I 13

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

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

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

varia tion could be related to terminate (sic). I 17

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

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

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

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

you use that, then you will have much better 2287

understanding of how the load size may impact the 1

CEF. 2

I think there are two things are getting 3

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

approach might be to understand what is the expected 5

target RMC. 6

MR. BROOKMAN: Okay. Are we going to 7

move on in the slide presentation material? 8

MS. ARMSTRONG: Sure. 9

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

think we were about to discuss alternat ive fabrics. 11

James. 12

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

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

We're open to considering alternative fabrics that 15

can sort of simulate the moisture retention 16

properties o f cotton or more real loads but can 17

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

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

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

a semi

- synthetic material. 21

So we're ope ning the floor to any other 2288

materials that we should be considering, again, along 1

with what Nate has been saying, producing a result 2

that is representative but can also be repeated. 3

MS. MAUER: This is Joanna. I think 4

investigating this sounds like a very useful 5

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

does conduct testing, if it would be possible to 7

include this load that has been developed by NEEA and 8

IOUs. 9

I think that would just help us if we 10

see the results from perhaps some alternative fabric. 11

We can compare that to this load that's 12

representative of some, some loads that are done in 13

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

some alternative materials that seem reasonable , seem 15

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

the field. 17

MS. ARMSTRONG: We'll consider that. 18

MR. BROOKMAN: I was wondering if the 19

manufacturers have any thoughts on alternative 20

fabric. 21

MR . MOUW: We don't. We just don't. We 2289

certainly would be willing to work on it and discuss 1

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

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

answer that. 4

MR. BATTAGLIA: Certainly, conside r it, 5

and 6

bring it back your teams. 7

MR. BROOKMAN: I'm recalling that Ashley 8

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

to current test fabrics. 10

MS. ARMSTRONG: I think we're looking 11

for any suggestions at t his point that anyone would 12

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

has any further consideration. 14

MR. BROOKMAN: Charlie Stephens. 15

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

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

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

don't think anybody will dispute that. 19

The question is, is it important to take 20

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

ques tion that it has a significant impact. 2290

The other things that has a significant 1

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

interact potentially, depending on the dryer, 3

especially. 4

So we have some big factors that are not 5

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

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

not accurately, when translated into kilowatt hours, 8

reflect how much energy dryers use. 9

And yes, there is a large varian ce in 10

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

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

close to some of the test procedure average. 13

Our load, our average load, for 14

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

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

things are actually pretty close. 17

But when the result in the field in 18

terms of energy use, which is a lot of what we care 19

about, that and, please, let's not diminish what we 20

were talking about earlier, the model

- to

- model 21

variation of the impact of the test on different 2291

models in different ways so that we get the right 1

range order of these things. 2

That 's important to us, too. So it's 3

not just the overall energy use. So, but when you 4

have some things that line up pretty well but the 5

outcome in the end does not, then you have a problem. 6

And we need to

-- there may be multiple things we can 7

do to fix it, but we have to at least acknowledge the 8

problem. 9

MR. BROOKMAN: Okay. Dave. 10

MR. DENKENBERGER: Dave. So I think the 11

example of refrigerators is actually an interesting 12

one, 13

because even though running it a t 90 degrees 14

Fahrenheit can reproduce the field energy use fairly 15

well, what we found is that the variable speed drive 16

fridges, I believe DOE predicted a 2 percent energy 17

savings where we were predicting more like 20 percent 18

energy savings. 19

So that's an example of a specific 20

technology. You have to load it at multiple points 21

to see the energy savings. So I think that actually 2292

gives

-- 1

MS. ARMSTRONG: That's not a function of 2

the 90

- degree test, I'm sure. 3

MR. DENKENBERGER: But it's a

-- 4

MS. ARMSTRONG: It's something 5

different. 6

MR. DENKENBERGER: Right, a single test 7

position, whereas if you open the

-- 8

MS. ARMSTRONG: But you're making 9

different points. 10

MR. DENKENBERGER:

-- if you put in 11

food, if you open the door, then you're testing at 12

different loadings, and then you actually see the 13

advantage of that particular technology. So I think 14

we need to think about that. In the terms of dryers, 15

we want to load the dryers with a small load and a 16

large load. 17

MS. ARMSTRONG: But that's part load 18

operation. It has nothing to do with the 90 degrees. 19

You could say the same thing

-- 20

M R. MOUW: At 90 degrees, that's full 21

load. 2293

MR. DENKENBERGER: 90

- degree door 1

opening is to

-- sorry

-- it's to simulate door 2

opening. 3

MS. ARMSTRONG: Right. 4

MR. MOUW: That's the only purpose. 5

MS. ARMSTRONG: Exactly. You could 6

still do full load. 7

MR. MOUW: You can try opening doors or 8

just increase the ambient temperature on the outside 9

of the fridge. That's

-- so there's a study done

-- 10

I wasn't doing this work at the time, but there's a 11

study done to translate, you know, the gradation 12

number of door openings and my home with two kids, 13

right, to get a result that's reasonable. 14

So they increased the ambient 15

temperature to do that. That was a real, practical 16

translation of real world to something that's 17

reasonable to normal lab, so that's the best way. 18

MR. STEPHENS: But we

-- we have

-- the 19

dryer test procedure has the same problems th at many 20

others do: There are, the heat pump test procedure 21

doesn't apply well at all to the way a variable 2294

capacity heat pump works in the field. I mean, the 1

results are astoundingly different. 2

The heat pump water heaters, the wate r 3

heater test procedure at 67 and a half degrees 4

doesn't apply to three

- quarters of the installations, 5

where the heat pump water heaters we have are in 6

houses. The performance is radically different. 7

So you know, the fact is that as 8

technology changes and as things move along, 9

eventually the test procedure just doesn't provide an 10

understanding of how these new technologies and how 11

these new controls and how these new machines 12

actually work in the real world and when that 13

happens, you need to step back and start looking at 14

the test procedure again. 15

MR. BROOKMAN: Yes. Manfred. 16

MR. STAEBLER: This is Manfred from BSH 17

again. 18

I mean, I come from refrigeration, too. 19

That's why I can talk about refrigeration but not 20

about dryers. But you know, you have many different 21

types of refrigerators, and therefore we have DOE 2295

product classes, which take into account the 1

differences, and maybe now, if you have in the f uture 2

different dryers, maybe you need different product 3

class for different technologies. Could be. I'm not 4

sure, but in the refrigerators we did it because if 5

you have through

- the

- door ice, it's a different, it's 6

a different product class tha n if you have just a 7

single door refrigerator, just to think about 8

variances in the products themselves. 9

MR. BROOKMAN: Are we going to

-- 10

MS. MAUER: May I just say, we don't 11

want to think about product classes in terms of 12

technologies, but in terms of the utility that is 13

provided. 14

MR. STAEBLER: Utility provided, right. 15

MR. BROOKMAN: Dave. 16

MR. DENKENBERGER: Yes. So getting to 17

the difference in repeatability of the lo ad, I think 18

we

-- one way of illustrating how different a 19

realistic load is from the DOE load is the thickness 20

of the cloth is all the same in the DOE load, and we 21

have some graphs that show the thickness of the cloth 2296

of these more realistic load s. 1

They can vary a factor of five. That 2

is, like the jeans can be five times thicker than the 3

thin articles. 4

And this is really important when you're 5

measuring automatic termination, because many dryers 6

will have moisture strips on the front of the drum 7

and you're not sure what part of the load

-- I mean, 8

it's just testing the front of the load, basically, 9

and if it's touching thick articles, it's measuring a 10

different moisture content than if i t's touching the 11

thin articles. 12

So that's something that really matters 13

now that we are measuring automatic termination, to 14

get that first thickness of jeans. And that, that 15

difference, that factor of 5, is so much larger than 16

wha t the difference you would get by buying jeans 17

from one provider to another. You're still getting 18

jeans versus thin underwear. You're still getting 19

the majority of the effect, even if the result is not 20

quite as repeatable. 21

MR. BROO KMAN: We have a few comments on 2297

line, and then I'm going to suggest we move on to the 1

next segment here. Christopher Granda says, "The 2

uses that the test procedure will be put to, 3

compliance with minimum efficiency, ENERGY STAR, and 4

utility ene rgy efficiency programs all require an 5

absolute measure of energy efficiency, not just a 6

ranking relative to other models." 7

And Curt from Tremel or

-- pardon me

-- 8

Curt Tremel from UL, try and unmute your phone, and 9

hopefully, we can hear you in the room. 10

MR. TREMEL: Yes. Can you hear me? 11

MR. BROOKMAN: Yes. Good. 12

MR. TREMEL: So I guess a couple 13

comments. One is on load size and that one, I see 14

that the question as far as why don't we use multiple 15

load sizes in with the clothes washer, and the intent 16

of the clothes washer needing multiple load sizes is 17

because all of the clothes washers are sensing the 18

load and that affects the amount o f water that is 19

consumed, so that end result affects the energy 20

consumption. 21

For clothes dryers at this time, there 2298

is not that load sensing, so I see that one load size 1

accurately, accurately compares multiple load dryers 2

in terms of energy efficiency. So that's, I guess 3

that's my comment from the load side. 4

As far as load type, I do see that is 5

there's a gradiance of option of a possible solution 6

as far as getting the best of both worlds, and that 7

would be utilizing the momie cloth load strictly for 8

energy consumption and determining if it meets the 9

minimum standards, whether that's for DOE ENERGY STAR 10

or whatever, but what would be the option

-- and 11

that's repeatable and reproducible so that we can be 12

consistent in having a meeting of minimum energy 13

standards. 14

But in terms of what consumers are 15

actually using, would it be possible to use a real 16

life load that is representative as a performance 17

metric, similar to what is used for other categories, 18

such as clothes washers and dishwashers now and so 19

that can evaluate the real life performance of the 20

dryer as the consumers are using it and also provide 21

a representative energy metric that utilities can 2299

with use in terms of advising power plants or 1

providing rebates, but unfortunately, as we've 2

discussed, that load size would have more variability 3

but you're not necessarily using that to meet the 4

minimum standards and confirm that the product is 5

matching up with what it needs. 6

So I guess those are my comments and 7

trying to see, is that a possible solution to I guess 8

meet the needs of both things. 9

Unfortunately, there is an additional 10

test burden, but I think that would provide, the 11

additional test burden, would provide benefits to 12

multiple stakeholders. 13

MR. BROOKMAN: Thank you. 14

I think we're going to move on to test 15

cycle settings, program, temperature and dryness 16

setting s. James Battaglia. 17

MR. BATTAGLIA: Just to highlight a few 18

of the points from the current test methods, so for 19

automatic termination dryers, a lot of you are 20

familiar, but it uses the normal cycle program, 21

maximum drying temperatur e setting and normal or 22100

medium dryness level, and any other optional settings 1

that don't affect those particular settings are 2

tested in as

- shipped condition. 3

And then for timer dryers, it uses the 4

maximum temp setting and, if it's eq uipped with a 5

timer, the maximum time setting. 6

And again, any other optional cycles 7

that don't affect those are tested in as

- shipped 8

condition, and if there is no separate temperature 9

setting, the maximum time setting was used for the 10

test cycle. 11

So again here we're just teeing up the 12

question, particularly on the cycle settings, what 13

iterations or combinations of cycle settings 14

stakeholders are interested in co nsidering. 15

The cycle program settings, they're at 16

temperature and dryness settings and any other 17

optional options, like Charlie highlighted the eco 18

mode. Again, this is a diagram that Charlie 19

included in his just showing from the NE EA field 20

study the percentage breakdown of the various cycles. 21

I'm not sure if it's the latest data. 22101

MR. STEPHENS: Pretty close. It didn't 1

shift. 2

MR. DENKENBERGER: This is Dave. So I 3

can comment on the supplemental test that we've 4

developed. For the small and large loads, we've 5

recommended the medium temperature, because that is 6

the most common in the NEEA field study. 7

For the medium size load on the fastest, 8

that usually corresponds to a hig h temperature, often 9

heavy duty, and then for the eco, that usually 10

corresponds to a low temperature. So these tests as 11

a whole explore the full, not the full range, but a 12

much better range of how the dryers are operating. 13

As for the dryness settings, we follow 14

the DOE to start with normal dryness, but if you 15

don't meet the final remaining moisture content, then 16

you would switch to the most dry. 17

And are we talking later about final RMC 18

s pecifically? 19

MR. BATTAGLIA: Yes. That's one of my 20

next slides. I might as well just tee up the last 21

one. 22102

MR. STEPHENS: We can talk about it all. 1

MR. BATTAGLIA: Well, they're sort of 2

interrelated. 3

MS. ARMSTRONG: They are. They are. 4

MR. STEPHENS: There is more to talk 5

about here. 6

MR. BATTAGLIA: Well, let's start with 7

this first. 8

MS. ARMSTRONG: I mean, what do we think 9

about multiple s ettings, testing in multiple 10

settings, doing some type of weighted average of 11

multiple settings? 12

MR. BROOKMAN: Charlie. 13

MR. STEPHENS: Well, we're struggling 14

with this right now as we test new products, because 15

the se ttings that we're getting, we don't understand 16

what they mean. I mean, and I say that

-- 17

MS. ARMSTRONG: Welcome to clothes 18

washers. 19

MR. STEPHENS: Well, we don't understand 20

what they mean when you actually run the machine with 21

-- you know, actually have to test it and find out 22103

what happens. 1

We have one dryer that we tested a 2

little while back that has eco normal and normal with 3

eco. And we said what? You know, how are you going 4

to pick those? 5

So we found out that eco normal left you 6

no choice at all. It was the lowest temperature 7

setting, and it took three hours or something

- plus to 8

dry a normal load. I think that was a DOE D 2 test 9

load. 10

So we said, Well, that's probably not 11

one that too many people use. So we tried normal 12

with eco, and that one seemed to have a more normal 13

result in terms of its length of cycle and energy use 14

and it was slower than f ast dry or normal without 15

eco. 16

So the problem is, there's a 17

proliferation of settings, and you've got one set

-- 18

you know, on the slide I show there's a knob that 19

has, you know, normal, heavy duty, that sort of like 20

gross selection like you see on most dryers today. 21

But then there's buttons that are 22104

essentially like fast eco and balanced or

-- there's 1

modifiers. And so you start doing permutations and 2

combinations of those things, and of course, all the 3

light s change every time you do that telling you what 4

you're getting. 5

We have no idea right now what people in 6

homes doing laundry will actually use for what kinds 7

of loads, and we're not sure how people will respond 8

to different machines and different manuals that say, 9

Use this for that. 10

We also know that at least one of the 11

machines we got, and we suspect it will be typical, 12

come shipped with the eco mode selected but it 13

doesn't revert to tha t. It, you know, after the 14

first load, it reverts to whatever you used last, 15

essentially. So it doesn't

-- we're not sure that 16

anybody should put any weight on that just because it 17

was shipped that way. 18

So we're

-- there's going to be some 19

real problems here we see with all of these newer 20

machines with electronic controls as to what 21

comprises a setting that is, that would have, you 22105

know, weights approximating some of what you're 1

seeing on the screen there, 50 percent, 30 p ercent, 2

13 percent. We don't think consumers doing laundry 3

will chose more than four or five modes, periods. 4

They'll figure out which four or five work for them 5

for whatever loads they do and that's what they'll 6

use. We just don't know which on es they are, and 7

it's going to be really hard to define in the test, I 8

think, what they are or what they should be, if you 9

can figure it out. 10

So we may be left to consider testing at 11

extremes and doing some sort of weighting scheme t hat 12

most often gives you an average result that works. 13

We don't know. That's why we're putting all these 14

things in houses and letting people use them and 15

recording what they do and what they use what 16

percentage of the time for what kinds of loads, and 17

we'll try to get some handle on this. 18

But that's only half the problem. The 19

bigger part of the problem is defining in the test 20

procedure what those are. 21

MS. ARMSTRON G: I think one part of the 22106

question

-- this is Ashley from DOE. One part of the 1

question that remains unanswered from my perspective 2

is and simply because I haven't actually run the 3

tests on every single option out there, especially 4

for those d ryers that may have like 20

- plus options 5

like the fancy new dryer in my house. But does it 6

matter? 7

MR. STEPHENS: Well, should we run a 8

test with less dry selected? I would argue, looking 9

at that graph on the screen up there, no, y ou 10

shouldn't. 11

MS. ARMSTRONG: Well, I'm more saying, 12

you know, if you were to run every single discrete 13

cycle option there was, yes, between super high heat 14

and eco mode for three hours, you would see a 15

significant difference. 16

But for some of them, it may not matter. 17

You may not get an end result that's all that 18

different, and so that would argue, who cares? 19

MR. STEPHENS: Who is going to tell you 20

that is there no difference? 21

MS. ARMSTRONG: Well, you would have to 22107

test. You're right. You'd have to test the 1

character, the delta. 2

As I said, I don't know the answer. I'm 3

pretty there's people around the table that may know 4

the answer. (Laughte r.) 5

MR. STEPHENS: Well, there's other 6

problems, too, because just a little anecdote here, 7

we recently were testing a hybrid dryer that behaved 8

very strangely and couldn't seem to terminate at less 9

than 10 percent RMC, and looking at the power traces 10

on it, it was like what is this thing doing? 11

We notified the factory, and within 12

hours, we got a response and they say, "Oh, well, 13

that was a mistake. That's an engineering problem. 14

We know how to fix it. We'll sh ip you another one 15

tomorrow." 16

So it took them 24 hours or less to 17

figure out the problem, change how the machine 18

behaved and send us a new one. And we're quite 19

certain that at least one dryer out there that's WiFi 20

enabled could pr obably have those things changed at 21

any time in its service life. So to be honest with 22108

you

-- 1

MS. ARMSTRONG: That's a whole different 2

issue, but

-- 3

MR. STEPHENS: Well, it is, but it bears 4

on what is a cycle. 5

MR. BROOKMAN: But that was a fancy one, 6

a new one with all kinds of electronic controls? 7

MR. STEPHENS: Well, increasing numbers 8

of dryers have electronic controls. They're 9

electronic to some extent. 10

MR. BROOKMAN: Just curious. 11

Okay. Other comments here? This is 12

useful. I'm not sure we've covered all of these four 13

bulleted points sufficiently. 14

MR. DENKENBERGER: This is Dave. If you 15

could go back to the other slide that explains the 16

other

-- yeah

-- first full bullet but then the 17

fourth sub

- bullet, Any other optional cycle settings 18

that do not affect the program, temperature or 19

dryness settings shall be tested in the as

- shipped 20

positions, so we've been int erpreting this as an eco 21

button even though it really does affect how the 22109

dryer, you know, probably what its temperature is 1

inside, it's not explicitly labeled as a temperature 2

or cycle setting. 3

So we've interpreted this to say, if t he 4

dryer comes with an eco button on, then that's the 5

as

- shipped position, so that's how we run the DOE 6

test. 7

But as Charlie pointed out, if the dryer 8

doesn't keep that default, then we're not sure how 9

much the consumers will use i t, so when we've tested 10

the small and the large loads, we have not kept the 11

eco button pressed. 12

But we're open to, if a dryer were to 13

default back to eco after two hours or whatever, then 14

we could see that more consumers would end up using 15

it and then it probably deserves to be tested in more 16

runs. So that's just

-- happy to hear manufacturers' 17

feedback on that. 18

MR. BATTAGLIA: Of course. 19

MR. MOUW: Of course, and I think 20

Manfred would say the same thing, we study our 21

consumers all the time. We have whole groups of 22110

people that we full

- time study, consumers and their 1

usage. 2

We do very similar studies nationwide, 3

where we'll put

-- you know, some in homes, and we'll 4

instrument those units and collect gobs and gobs and 5

gobs of data. 6

That's something we do constantly, and I 7

think all manufacturers that care about their 8

consumers are doing the same things. 9

I think what we find is that changing 10

consumer behavior can be a different thing. What we 11

find is that consumers are for the most part using 12

the normal cycle. And to the extent that we 13

collaborate a little more and talk about whether o r 14

not doing multiple cycles like this will increase the 15

value and representativeness of the test procedure, 16

there may be some information that we would be 17

willing to share in that regard. 18

But I mean, in general, consumers do 19

what's easy, what they're used to, and that's hitting 20

the normal button. 21

It's funny. Charlie, you mentioned the 22111

use and care guide. If we could just get consumers 1

to read the use and guide, that would be a victory. 2

I mean, it rea lly would be. 3

MR. STEPHENS: I think they use it for 4

troubleshooting. 5

MR. MOUW: Or fire starters, one of the 6

two. The point is, you know, consumers use the 7

normal cycle for the most part. 8

MR. STEPHENS: I think so. 9

MR. MOUW: So you know, is there value 10

in looking at other cycles? Perhaps, but I think the 11

value in the market I think would be fairly small. 12

MR. STEPHENS: It's certainly, I think, 13

is what should be used f or the current DOE test load 14

and probably on normal dry. 15

I mean, the D2 test procedure I think as 16

far as it goes does okay with that. I think we 17

should be using medium heat rather than high heat. 18

I think if you were to start 19

entertaining shifting loads and actually doing some 20

testing with a heavier load, different settings might 21

be in order, like more dry, for instance. It might 22112

actually consistently take more dry to actually get 1

the RMC, the final RMC, under 5 percent, for 2

instance. 3

So and the final RMC might be a little 4

bit different than the final RMC for the momie 5

cloths. 6

Two more things that came out of our 7

study from data, we found, oddly enough, that the 8

washer cycle time and the dryer cycle time on average 9

were within a minute or two of each other at just a 10

minute or two under an hour. So they were really 11

quite well matched. That was a bit of a surprise. 12

The RMCs that we were gett ing were a 13

little higher, even in

-- and there was quite a 14

difference between the cohort

-- we divided the 15

cohorts of the dryers when the test procedure 16

changed, so 2005 to 2009 and then 2010 and newer. 17

And there actually was a notable difference in what 18

we saw in those two cohorts in terms of the 19

performance in the laundry area. 20

So RMC, everything else, so

-- 21

MR. DENKENBERGER: You're talking about 22113

initial. 1

MR. STEPHENS: Initial, yeah. 2

MR. DENKENBERGER: For the dryer. 3

MR. STEPHENS: Right. Yes. Yeah. The 4

average initial RMC was a little higher than D2, 62 5

percent or

-- I think, but not, not hugely. But, 6

again, it's a Delta. You're going from 57 plus or 7

minus down to 2 to 5. 8

Well, if you're starting at 62, that 9

Delta gets notably larger, and there's a significant 10

amount of energy actually used for that extra 5 11

percent RMC. 12

MR. BROOKMAN: Joanna. 13

MS. MAUER: This is Joanna. As dryer 14

technology is changing, it just seems to me like it 15

may be important to somehow try to capture the range 16

of performance, and I guess I'd be concerned, you 17

know, if we're only testing at the norma l setting, 18

you know, in the example that Charlie gave of if a 19

dryer shifted in eco mode but as soon as the consumer 20

selects, you know, says there is a fast mode or 21

something they can select and then after that the 22114

default is that new mode, then w e're not capturing at 1

all the, how that dryer is actually performing in the 2

field. 3

So giving, I mean, it makes sense to me 4

that most consumers are choosing the normal setting, 5

but it also seems to me like, given the huge range of 6

s ettings, that it would be good to somehow capture 7

performance across settings so we can ensure that 8

dryers are performing well, not just on the single 9

setting but across the range. 10

MR. BROOKMAN: Jonathan Gatzke has a 11

comment from on line. He says, "After the guidelines 12

are set, how about allowing the manufacturer to set 13

the energy cycle? The energy cycle would then be 14

marked on the machine's control on a 15

consumer/removable label and in the manual itself. 16

This is how Austr alia runs G

- E

- M

- S, GEMS energy 17

registration." 18

MR. STEPHENS: Repeat that again. 19

MR. BROOKMAN: The last part or the 20

whole thing? 21

MR. STEPHENS: The first part. 22115

MR. BROOKMAN: "After the guidelines are 1

set, how about allowing the manufacturer to set the 2

energy cycle. The energy cycle would then be marked 3

on the machine's control on a consumer/removable 4

label and in the manual itself. This is how 5

Australia runs GEMS energy registration." 6

MR. STEPHENS: So when they say energy 7

cycle, they mean the cycle that was tested? 8

MS. REICH: They declare what the cycle 9

is tested under, make that available to the cons umer. 10

MR. STEPHENS: And that's what they're 11

referring to there as the end of use cycle? 12

MR. DENKENBERGER: So they're almost 13

defining normal cycle. They're saying this, is, you 14

know, in our particular case, it would be , this is 15

the normal cycle that you tested to. When said you 16

couldn't figure out what, you know, can't figure what 17

that normal

-- because it usually doesn't say normal 18

cycle on a dial when you're using the machine. 19

MR. STEPHENS: We ll, it does on that one 20

slide of mine. If you'll see, there's a knob and 21

normal is right at the top, top center, so

-- but 22116

then there's also three modifier buttons to modify 1

any number of those other settings and so you can get 2

permutations and combinations. 3

And then occasionally you can also 4

modify some of the individual things like 5

temperature, dryness, those sorts of things. 6

There are defaults, and I think we've 7

discovered, one of the things we've discovered in the 8

field is that most of the time people don't mess with 9

the defaults. When they select a cycle, they usually 10

leave it for most of the defaults. 11

The only one that some people I thin k 12

have figured out is that certain loads don't dry as 13

easily as others, so they're likely to use more dry 14

to make sure that it gets dry. 15

MR. BROOKMAN: Let's go to the other 16

test procedure issue and see if anything else needs 17

to be described here. For example, have you talked 18

about RMC yet? I think, Dave, you had a comment on 19

RMC? 20

MR. DENKENBERGER: Yeah. Well, so there 21

are two, that from the dryer's perspective, there's 22117

the initial moisture content and the n final. So 1

we've been talking a little bit about initial. 2

One, as Charlie noted, we've been seeing 3

in the field a little higher than 57.5 percent, and 4

we could get this if the washer test procedure were 5

tested with more realistic c lothing or at least 6

cotton clothing, because it's more difficult to spin 7

the water out. 8

So then like if we had a load that was 9

the momie load and a load that was more cotton, we 10

probably would be able to reproduce the field values 11

better. 12

And then on the other end is the final 13

RMC and to clarify the testing that was done, I 14

believe. So the DOE now is 2 percent, but with the 15

AHAM 2009 and the AHAM 1992, the target was 5 16

percent. 17

And when we were doing the testing, we 18

did consult with manufacturers and settled on a goal 19

of 4 percent RMC that would be acceptable to most 20

consumers, and it depends on the dryer. Sometimes 21

you do need to go to very dry. Sometime s normal 22118

dryness was sufficient. 1

But then on the fastest test, we did 2

decide to do only 2 percent RMC, recognizing that 3

some consumers want the laundry very dry. 4

Now, some dryers can still meet that on 5

normal dryness. We decided not to dictate using very 6

dry. If the dryer got it to 2 percent RMC with 7

realistic clothing on normal dryness, that's fine, 8

but if it didn't, it would have to go to very dry. 9

MR. STEPHENS: I think the RMCs are 10

somewhat load dependent. It's possible that we 11

haven't got the data yet. I'm working on funding 12

some work to get the data, that 57 and a half percent 13

for the test load is actually a little high because 14

it's just the nature of the cloth. 15

It may be a reasonable number if it's 16

the only testing you're doing, you know? Again, it's 17

like the 90 degree refrigerator testing. If you're 18

only going to use one test and one test load, well, 19

maybe it's important to start it at a higher RMC 20

because that will push the drying energy a little up 21

toward what it would be with real clothing. 22119

I could see where that might be the 1

case, but I think some of the lighter loads that are 2

eight and a half pounds going through the syste m, 3

actually a lot of clothes washers deliver lower RMCs 4

than that. 5

And so again, if you only have one load, 6

maybe that's an appropriate number, but if you're 7

doing multiple loads, it might actually be 8

appropriate to have a differen t starting RMC for each 9

fabric type, higher for real clothing and lower for 10

the lighter

- weight clothing, and 57 and a half might 11

be kind of in the middle of where you'd want those 12

two numbers to be. 13

Test load weight, at least one of them, 14

I would point out again that the CEF numbers that 15

we're getting for our small load, which is like four 16

pounds plus or minus in the real clothing

-- 17

MR. DENKENBERGER: Yes, 4.2. 18

MR. STEPHENS:

-- 4.2 pounds, the CEF 19

numbers are literally one

- half of what they are with 20

a large load of the same clothing. 21

So that's a big deal when you're getting 22120

half the numbers. That's a huge difference, and so 1

the 8.45 pounds may be an appropriate load to run a nd 2

get a number from, but I think it's also appropriate 3

to look at how a dryer will handle a small load, 4

because a lot of loads are smaller than that. A lot 5

of loads are smaller than that. 6

And who's to say that there won't be a 7

clothes dryer out there that in some manner or 8

another figures out how big the load is and adapts 9

its behavior to that. It may be that clothes washers 10

are not the only things that can adapt to load size. 11

So I think we should at leas t 12

potentially use a point there that has some weight 13

for a smaller load. 14

Cycles per year, our cycles per year 15

were a little higher. They ranged. I think the 16

different analyses gave us different numbers 17

depending on what was a cyc le and what was a load. 18

Touch

- up cycles were always, were 19

sometimes hard to identify. But we think the dryer 20

cycles is a lot higher than that, but if you're 21

actually just, if what you really mean is loads, 22121

maybe with as many cycles as it takes to dry the 1

load, it's somewhere between 300 and 310. 2

So it's not radically different than 3

this. 4

We did find a radically different number 5

of on

- mode hours, active on

- mode hours, versus 6

stand

- by off

- mode hour s, significant difference 7

there. So, and that's in the reported. 8

MR. BROOKMAN: I though you said 9

earlier, though, that the standby power

-- 10

MR. STEPHENS: Standby was small at the 11

moment. However, we think that's chan ging everywhere 12

we look, and I've got data on standby, actually 13

network standby, in some cases, which is alarming to 14

me. 15

Some of it's not network standby, it's 16

just alarming standby. But, so we think that that 17

needs to be defined. 18

Other test provisions, the last bullet 19

there, we think network standby needs to be defined 20

and it needs to be tested, because there's an awful 21

lot of network standby going on every year that 22122

wasn't there the year before in a lot of products, 1

including these. 2

So we've already got a couple of those 3

products in hand. We just don't know what they're 4

going to do and what they're going to be asked to do 5

and who's going to c ontrol them using what systems 6

and under what conditions. 7

And so anyway, it needs to be tested, 8

we're quite sure. 9

MR. BROOKMAN: Dave, do you have a 10

comment here? 11

MR. DENKENBERGER: Yes, Dave. So for 12

th e dryers not explicitly sensing the load size, even 13

if they don't explicitly sense it, that they still 14

can behave very differently. We generally see in a 15

small load that the heater is not on as much, so this 16

would make sense even with a very simpl e dryer that's 17

just measuring the temperature of the exhaust air. 18

If there isn't as much wet clothing in there, you'll 19

get to your maximum exhaust temperature quickly and 20

you'll have to turn the heater off. 21

The other thing is more sophisticated 22123

dryers. TIAX (sic) performed a research study on 1

modulating gas dryers that could vary the heat 2

output, and they found significantly greater energy 3

savings with the small loads because they coul d 4

taylor the heat output to the load size. 5

So that's a good reason to test the 6

multiple sizes. 7

MR. BROOKMAN: We have a comment from 8

Eileen Eaton, Consortium for Energy Efficiency, and 9

her comment is, "Have you determi ned consumer 10

accepted final RMC? I ask because I'm curious if 11

similar studies could be conducted to determine 12

consumer acceptance regarding dry time." 13

MR. STEPHENS: Well, we consulted with a 14

number of manufacturers about what they knew about 15

this in order for us to kind of get a sense of where 16

the boundaries were, and I don't think we disagreed 17

with what we were told. I think it's 5 percent or 18

less with some people actually wanting these things 19

to be practically bone dry and other people, 20

depending on the fabric sometimes, they would accept 21

a little bit more than that. 22124

But we don't believe that RMCs greater 1

than 5 percent at the end of the cycle are going to 2

be very acceptable unless they actually wa nted that. 3

MR. BROOKMAN: Dave? 4

MR. DENKENBERGER: Yeah. So we did 5

investigate this also with limited, not statistically 6

representative sample of people feeling the clothing 7

and saying whether they're dry, and an important 8

issue here is about the diversity of thickness of 9

clothing. 10

And I saw that the

-- I don't know if it 11

was PNNL or Oak Ridge did some studies of the

-- 12

weighing the individual articles of clothing and 13

finding what the remaining moisture content is, and 14

we think

-- we've done some of that, as well. We 15

think that's a good idea, because it can, depending 16

on the consumer, if the jeans are still wet, they may 17

put everything back i n and continue to dry for 18

another ten minutes. 19

And so it's very important, and to get 20

that diversity of thickness, and so that means that 21

if you, if you bring the entire load down to 5 22125

percent RMC, it could be that the jeans are stil l 10 1

percent RMC and feel wet. 2

So that's important to look at. 3

MR. BROOKMAN: Okay. This list on 22 is 4

kind of a summary of remaining issues, so let's see 5

if we have other comments here to address. 6

MR. ST EPHENS: Oh. Eileen, nobody 7

answered Eileen's question about duration of study of 8

cycle, and we are concerned about that and I know the 9

manufacturers are, too. 10

So our study showed that most people 11

doing laundry probably didn't have a reason to be 12

concerned about that because the washer cycle time 13

was virtually identical to the dryer cycle time, 14

right around an hour, and that was unsurprising to 15

us, and we think most people are probably pretty 16

happy with that. 17

When they're almost equal and it's 18

around an hour, we didn't find anybody who had a 19

problem with that in our study. But I think it would 20

actually, when we start seeing longer cycle times 21

based on other technologies that are more eff icient, 22126

for instance, when they get their efficiency by 1

extending the cycle a little longer, we probably 2

should do some of those studies. 3

MR. BROOKMAN: Dave. 4

MR. DENKENBERGER: Yeah, and I should 5

clarify that all thes e final RMCs are based on bone 6

dry weight, where as IEC does not define it by the 7

bone dry weight. They define it by the weight of the 8

clothing that has been calibrated with a certain 9

relative humidity, so we have really careful how 10

we're quanti fying this. 11

And that makes a complication in the 12

field studies, because you would think that the 13

clothing going into the washer is dry. Well, it's 14

dry but it's not bone dry, so we have to make a 15

correction for that to get to the bon e dry weight. 16

MR. STEPHENS: Yeah. And that's, note 17

that in the report. There is a correction when we're 18

talking about comparing ratings and field ratings. 19

There is a correction in there to get back to 20

something approximating bone dry weight to start with 21

because the consumers just weighed their clothes. 22127

They were not bone dry. 1

MR. BROOKMAN: We have a comment, 2

request for a comment, from Ravee. Ravee, unmute 3

your phone. Let's hear from you. 4

RAVEE: Sorry. Can you hear me okay? 5

MR. BROOKMAN: Yes. 6

RAVEE: Okay. I think the comment has 7

been all based on the targets in the RMC levels. 8

They normally can be (inaudible) or they can b e 5 9

percent and 2 percent. 10

Again, the question is, how do we know 11

what is the consumer's, you know, acceptable in RMC? 12

Also, I think looking at RMC, it is a 13

known fact that the items which are dried and kept in 14

the roo m conditions could take moisture up to 8 15

percent. This is up in the 8 percent range. So the 16

question is that, do we need to overdry, using more 17

RMC? 18

But then obviously, the clothes are out, 19

hang in the closet and they take some moi sture from 20

the air. So what would be the right level and then 21

equal an IEC target in retention is hopefully around 22128

8 percent. Because the test condition is different. 1

They start, you know, humidity pretest laundry which 2

is around 8 percent, so then they end up like 3

equivalent like zero percent because equalized to 8 4

percent then you do bone dry. 5

So the question is, are there 6

differences between D1 and D2? What is the right 7

level? And should we really need more dry and then 8

the users actually end up having more moisture when 9

the laundry is left in the room. 10

MR. BROOKMAN: Okay. 11

MR. DENKENBERGER: I think that's a good 12

point, but the ques tion is, what do consumers do now? 13

There's a separate question of whether we could 14

convince them that they don't need to overdry their 15

clothing if it was just going to suck in more 16

moisture from the room. 17

MR. BROOKMAN: You need to t alk to my 18

spouse. 19

MS. ARMSTRONG: I don't think that's 20

necessarily a responsibility of the test procedure. 21

MR. BROOKMAN: I think we're moving 22129

towards closure here. And maybe, are there any final 1

comments on this segm ent and then maybe we'll move to 2

closing comments. I think we've pretty much covered 3

it at this point. 4

So then moving then to closing remarks, 5

any other issues that people, individuals, wish to 6

raise as we move towards the end of th is meeting? 7

Charlie? 8

MR. STEPHENS: I want to add one thing, 9

and that is, we really are, whether DOE opens the 10

discussion soon or not, thinking about the 11

implications for the clothes washer test procedure, 12

as well, because of the nature of some of the changes 13

we're focused on, like the test load. 14

So we're also trying to think about that 15

even though we're focused for now on the dryer. 16

MR. BROOKMAN: Okay. Thank you. 17

MS. REICH: I have a question to 18

actually throw out, now that you mention clothes 19

washer. 20

So a lot of what we're talking about 21

today heads more in the direction of the clothes 22130

washer, the complexity of the clothes washer tes t 1

procedure with a matrix and many test cycles. 2

What are people's thought on the test 3

burden? What is an acceptable test burden for a 4

dryer test procedure? 5

MR. DENKENBERGER: Well, could we have 6

someone comment on the test burden of the washers, 7

how many cycles that is? 8

And also, we should mention there is an 9

issue of how much you have to test a single unit and 10

then the additional unit. Could someone comment on 11

that? 12

MR. MOUW: Wh at do you mean? 13

MR. DENKENBERGER: As in, I'm most 14

familiar with the dryer test procedure, whereas the 15

test procedure says to test it once, but then you 16

have to test multiple units in the same model and 17

show the variability, yeah, fo r certification. 18

So how does that work in washers? How 19

many cycles does that end up being? 20

MS. REICH: I can comment on that one. 21

It's a lot. It's a minimum of like 12 or 14

-- 22131

MR. STEPHENS: A dozen and maybe as many 1

as 16 or more? 2

MS. REICH: Oh, no. More than. 3

MR. STEPHENS:

-- depending on the 4

results. 5

MS. REICH: Yes. It's a very 6

significant burden. 7

MR. DENKENBERGER: And how many units 8

does that end up being on? 9

MS. ARMSTRONG: Two or more. 10

MR. MOUW: Two or more. Typically, more 11

than two. 12

MR. DENKENBERGER: So I think that sets 13

the context t hat there is a significant number of 14

tests for washers, and on the dryer side, the testing 15

burden has been less but now it looks like washers 16

have gotten much more efficient and there are more 17

energy savings opportunities in dryers. So we feel 18

t hat some increase in testing burden to get more 19

realistic energy savings estimate is justified. 20

MR. STEPHENS: Though if we can find 21

ways to minimize it, we certainly should. 22132

MR. MOUW: And I think

-- This is Nate. 1

I thi nk it goes back to, again, what's the desired 2

outcome, the output or the input, right? I mean, I 3

think what I'm hearing from utilities is they want a 4

realistic estimate of what's going to be seen in the 5

field. What's actually going to be the energy 6

consumed in the field; is that an accurate

-- 7

MR. STEPHENS: That's one of two. The 8

other one is because we assume and we've seen 9

evidence that some are better at this than others, 10

some dryers do a better job than others, my clients, 11

my funders, also want to know, which are the better 12

ones reliably so that they can use the ratings to 13

tell, to help people identify which ones are the more 14

efficient ones. 15

MS. ARMSTRONG: Sure. 16

MR. STEPHENS: Reliably. So it's has to 17

-- it's not just the field conditions. They have to 18

appropriately differentiate the performance of the 19

various technologies and models out there. 20

MR. BROOKMAN: A comment from Chris 21

Badger, "Some manufacturers are stating that by 22133

reducing the power (temperature) and better stability 1

of temperatures, they are getting more consistent 2

drying of all the clothes in the dryer. Are we 3

forcing dryness to overdry and waste energy 4

unnecessar ily?" 5

MR. STEPHENS: Dave, what was the drying 6

time when it was just air dry, four hours and 7

something? 8

MR. DENKENBERGER: Yeah. Yeah. So

-- 9

MR. STEPHENS: Huge CEF. I think the 10

CEF was over 8 or someth ing. 11

MR. DENKENBERGER: Yes. Roughly double 12

conventional drying. 13

MR. STEPHENS: But I think we were 14

concerned about lint production. 15

MR. BROOKMAN: You're beating up those 16

clothes, so

-- 17

MR. STEPHENS: Well, yeah. I mean, you 18

know, you tumble them for four and a half hours, low 19

temperature, super efficient, but the clothes may 20

suffer. So I think there's some sort of a happy 21

medium there somewhere. 22134

MR . DENKENBERGER: Yeah. And related to 1

that, there's also, the dryer is bringing in, well, 2

bringing in air from the room but then exhausting it 3

outside, which has to be replaced. So we have 4

investigated a little bit on what the heating, 5

ventilat ing and air conditioning impacts with the 6

dryer are and we understand that they are very 7

climate dependent but we think that a simple test 8

procedure revision would just measure the air flow 9

rate of a dryer so that utilities or whatever could 10

take that information into account if they wanted to. 11

MR. BROOKMAN: Chris Badger makes an 12

additional request for review. He asks, "Request 13

that DOE also review product categories to reflect 14

the market introduction of standard sized ventl ess 15

dryers in North America." 16

MS. ARMSTRONG: That is outside the 17

scope of the test procedure. 18

MR. STEPHENS: Outside the scope of the 19

test procedure. 20

MS. ARMSTRONG: When it's appropriate. 21

MR. STEPHENS: Product classes is 22135

outside the scope of the test procedure? 1

MS. ARMSTRONG: No. I mean, the test 2

procedure should be able to characterize the 3

performance of products on the market period, across 4

the boa rd. 5

But we don't necessarily design a test 6

procedure for product classes, right? Product 7

classes are more something that, you know, with the 8

impact of consumer utility and how that affects the 9

performance of a unit would be consider ed different. 10

MR. STEPHENS: You would, but I would 11

argue that some water heaters belong in a different 12

product class, for instance, a split system water 13

heater, and the test procedure wouldn't be the same, 14

either. 15

MS. ARMSTRONG: I mean, the test 16

procedure for some water heaters, since you want to 17

bring up that example, I mean, we have, depending on 18

the capacity of the water heater, depending on the 19

input rate, depending on flow rates, we have 20

different bucke ts. Those aren't products classes in 21

our standards, but we accurately change how they are 22136

tested to better reflect the way they are used in the 1

field. 2

So I don't think it's a product class 3

issue. I think the dryer test procedure sh ould be 4

able to accurately test all the products out there, 5

the different technologies out there and how they're 6

-- and be representative of how they are used. 7

MR. STEPHENS: True, but you just 8

changed the water heater test procedure to change the 9

test conditions for the different product classes. 10

MS. ARMSTRONG: It's not just product 11

classes. I did far more than that. 12

MR. STEPHENS: Well, I know, but we're 13

talking about product classes and what gets tested 14

how, and I think there is a ventless dryer class with 15

a separate standard but I'm not familiar right now 16

with why it's in its own class. 17

MS. ARMSTRONG: I guess that would be 18

discuss ion for the

-- 19

MR. STEPHENS: It's my impression that 20

previously, all the ventless dryers were typically 21

condensing dryers. 22137

MS. ARMSTRONG: Exactly. 1

MR. BROOKMAN: Dave. 2

MR. STEPHENS: And tha t continues to be 3

true. 4

MR. DENKENBERGER: The other thing I'd 5

like to bring up for discussion is something I 6

mentioned in the opening statement, which is looking 7

more holistically at the energy use of dryers rather 8

than just site energy. 9

So, for example, in natural gas dryers, 10

they actually turn out to be less efficient on a site 11

energy basis due to the fact that the energy value is 12

the higher heating value, so it's not able to count 13

the condensing the moisture from the combustion, 14

whereas if you look at a source energy perspective, 15

the natural gas dryers are much more efficient than 16

convention electric resistance dryers. I would just 17

like to open that up for discussion. 18

MR. BROOKMAN: Okay. Thank you. 19

Additional comments on that point? 20

MR. STEPHENS: Our funders would 21

strongly disagree with that. 22138

MS. ARMSTRONG: It's Definitely a point 1

of contention. 2

MR. STEP HENS: Especially the ones that 3

get 100 percent of their power from a hydro dam. 4

MR. BROOKMAN: Hydro. Yeah. 5

MR. DENKENBERGER: Sure. So it depends 6

on your source of electricity, but if we look, at 7

least doing some cal culation or recognition of source 8

energy, and it could be on energy costs or it could 9

be on CO2 emissions, in which case, if you're 10

hydropower, then electric dryers do look better than 11

natural gas but at least some recognition of that 12

rather than strictly using site energy we think would 13

be valuable. 14

MS. ARMSTRONG: I think this was just a 15

little bit broader than the scope of the dryer test 16

procedure specifically. It has come up more broadly 17

from a variety of different stak eholders that have a 18

variety of different opinions. DOE has issued its 19

opinion with regard to full FFC cycle and how it will 20

consider it, so I would say go there. That's not 21

something

-- 22139

MR. DENKENBERGER: Could you summarize 1

the opinion? 2

MS. ARMSTRONG: I'll point you to the 3

right direction. It's easier that way. 4

MR. BROOKMAN: Final comments. 5

MS. ARMSTRONG: It is long, and it was 6

carefully worded so I would prefer not. 7

MR. BROOKMAN: Additional comments here 8

as we move towards closing out and maybe we could go 9

to the final slide. 10

MR. STEPHENS: I have a question. 11

MR. BROOKMAN: Yes, Charlie. 12

MR. STEPHENS: PNNL and ORNL have done 13

some work. Are there plans for them to do any more 14

work? 15

MS. ARMSTRONG: I don't know. Not right 16

now. I think there is plans to do more work. As far 17

as where it's going to be done, unsure yet in terms 18

of next steps. 19

With this effort, what exact testing 20

we'll do, where we'll do it, which labs will conduct 21

them, we have worked with them on going now for other 22140

types of research products. 1

MR. STEPHENS: Okay. I'll just say that 2

we're going to continue our field research and our 3

lab research, and all of the data will be made 4

available as soon as it becomes available. It's all 5

downloadable from our web site, including the data 6

itself from the field study, and we'll try to do that 7

with everything we do. We'll put up the electronic 8

data on the site. I'll make sure it gets shipped to 9

the individuals around the table here who are 10

directly interested in it. But all of our data w ill 11

public. 12

MR. BROOKMAN: Okay. Thank you, 13

Charlie. 14

Daniel Lapato says, "What about 15

co

- labeling appliances with source and site?" 16

MS. ARMSTRONG: So I would say labeling 17

for most residential appliances , the best answer to 18

the question is, the labeling for most residential 19

appliances resides under the authority of the Federal 20

Trade Commission, so to the extent you have 21

suggestions about how products should be labeled, 22141

especially with regard to certain residential 1

appliances, you need to to direct your attention 2

there. 3

MR. BROOKMAN: Okay. Thank you. 4

Yes, David. 5

MR. DENKENBERGER: Related to follow

- up 6

work, could you give an idea of schedule, ho w this 7

might progress? When do you need data next? 8

MR. STEPHENS: When do you need data? I 9

mean, I know you want it as soon as you can get it. 10

MS. ARMSTRONG: We always need data. 11

Today. Today. As soon as possible. 12

MR. STEPHENS: When is it too late or 13

when is it likely to be too late? 14

MS. ARMSTRONG: So the comment period 15

date is until December officially for this. 16

Obviously, to the extent you want to inform our test 17

plan or wha t type of investigative testing, that's 18

when we would be taking input for that, by that date. 19

If you have data that suggests we should 20

be testing a certain way or should investigate a 21

certain thing or want to make a case, that's when y ou 22142

would do it. 1

You are welcome to submit ideas anywhere 2

along the process. I don't know exactly our next 3

step. Obviously, at some point it will be a proposed 4

rule. Likely it will not be

-- it will probably be a 5

year from now, a s our normal processes are about two 6

to two and a half years long, depending on the topic. 7

MR. STEPHENS: So by the end of 2015 8

would be

-- 9

MS. ARMSTRONG: I'm doing this 10

completely ad hoc, but the end of 2015, beginning of 11

2016 maybe. 12

MR. STEPHENS: That's helpful. That's 13

helpful for us for scheduling our research and our 14

budgets so that's good. Thank you. 15

MS. ARMSTRONG: Obviously, we make 16

decisions well in advance of that date, b ut yes. 17

MR. STEPHENS: Okay. 18

MR. BROOKMAN: Closing remarks? Okay. 19

MR. BERRINGER: We have got the last 20

slide up here. As we talked about, the transcript 21

will be made part of the docket, so it will be 22143

available. 1

Also, the slides will also be a part of 2

the docket for today's meeting. Again, we ask that 3

written comments be submitted by December 15, and you 4

have the e

- mail address. If you want to mail them, 5

you have Brenda Edward s' address at the Department of 6

Energy as far as that, and also, if you're going to 7

courier the comments, then also you can send those to 8

Brenda at the information here. 9

At this time we just want to thank 10

everybody for their particip ation today and I thought 11

it was a good discussion. Thank you, everybody. 12

MR. STEPHENS: Thanks for having the 13

meeting. Very helpful. 14

(Thereupon, at 11:32 a.m., the meeting 15

was concluded.) 16

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REPORTER’S CERTIFICATE 1

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I, LU ANNE DAWSON KIRKLAND, do hereby certify that 3

the within transcript is a true and accurate record of the 4

proceedings in the above

- entitled matter. 5

I further certify that I am not a relative, 6

employee, attorney or counsel of any of the parties to 7

this action and that I am in no way interested in the 8

outcome of this matter. 9

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___________________________ 12

LU ANNE DAWS ON KIRKLAND 13

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