5-i CHAPTER 5

. ENGINEERING ANALYSIS

TABLE OF CO NTENTS

5.1 INTRODUCTION

................................ ................................ ................................ ........... 5

- 1 5.2 TECHNOLOGIES UNABLE TO BE INCLUDED IN TH E ANALYSIS

..................... 5

- 2 5.3 PRODUCT CLASSES ANAL YZED

................................ ................................ .............. 5

- 2 5.4 EFFICIENCY LEVELS

................................ ................................ ................................ ... 5

- 3 5.4.1 Efficiency Metrics

................................ ................................ ................................ ............ 5

- 3 5.4.2 Appendix J1/Appendix J2 Efficiency Metric Translations

................................ .............. 5

- 5 5.4.3 Baseline Units

................................ ................................ ................................ .................. 5

- 6 5.4.4 Higher Efficiency Levels

................................ ................................ ................................ . 5

- 6 5.4.5 Maximum Technologically Feasible Efficiency Levels

................................ .................. 5

- 7 5.5 METHODOLOGY OVERVIEW

................................ ................................ .................... 5

- 7 5.5.1 AHAM Data Request

................................ ................................ ................................ ....... 5

- 7 5.5.2 Product Testing Methodology

................................ ................................ .......................... 5

- 8 5.5.3 Product Teardown Methodology

................................ ................................ ..................... 5

- 8 5.5.3.1 Selection of Units

................................ ................................ ........................... 5

- 9 5.5.3.2 Generation of Bill of Materials

................................ ................................ ...... 5

- 9 5.5.3.3 Cost Structure of the Spreadsheet Models

................................ ..................... 5

- 9 5.5.3.4 Cost Model and Definitions

................................ ................................ ......... 5

- 11 5.5.3.5 Cost Model Assumptions

................................ ................................ ............. 5

- 12 5.5.4 Manufacturer Interviews

................................ ................................ ................................ 5

- 12 5.6 ANALYSIS AND RESULTS

................................ ................................ ........................ 5

- 12 5.6.1 AHAM Data

................................ ................................ ................................ ................... 5

- 12 5.6.2 Prod uct Testing Results

................................ ................................ ................................ . 5

- 12 5.6.2.1 Active Mode Testing

................................ ................................ .................... 5

- 14 5.6.2.2 Standby Mode and Off Mode Power

................................ ........................... 5

- 18 5.6.2.3 Cleaning Performance Testing

................................ ................................ ..... 5

- 19 5.6.3 Product Teardowns

................................ ................................ ................................ ........ 5

- 33 5.6.3.1 Top

- Loading Commercial Clothes Washers

................................ ................ 5

- 33 5.6.3.2 Front

- Loading Commercial Clothes Washers

................................ ............. 5

- 36 5.6.4 Cost

- Efficiency Curves

................................ ................................ ................................ .. 5

- 40 5.6.4.1 Top

- Loading Cost

- Efficiency Curves

................................ .......................... 5

- 40 5.6.4.2 Front

- Loading Cost

- Efficiency Curves

................................ ........................ 5

- 41

LIST OF TABLES

Table 5.4.1 Revisions to the Clothes Washer Test Procedure that Significantly Affect

Efficiency Metrics

................................ ................................ ................................ 5

- 4 Table 5.4.2 Appendix J1 and Appendix J2 Efficiency Level Translations for Top

- Loading

CCWs

................................ ................................ ................................ ................... 5

- 55-ii

Tab le 5.4.3 Appendix J1 and Appendix J2 Efficiency Level Translations for Front

Loading CCWs

................................ ................................ ................................ ..... 5

- 6 Table 5.5.1 Major Manufacturing Processes

................................ ................................ ............. 5

- 10 Table 5.6.4 Top

- Loading Commercial Clothes Washer Test Unit Features

.............................. 5

- 13 Table 5.6.5 Front

- Loading Commercial Clothes Washer Test Unit Features

........................... 5

- 14 Table 5.6.6 Commercial Clothes Washer Standby Power Measurements

................................ . 5

- 19 Table 5.6.7 Production Cost Distribution for Baseline Top

- Loading CCW

.............................. 5

- 34 Table 5.6.8 Materials Cost Distribution for Baseline Top

- Loading CCW

................................ 5

- 34 Table 5.6.9 Baseline Fron t

- Load Clothes Washer Production Cost Distribution

...................... 5

- 38 Table 5.6.10 Baseline Front

- Load Clothes Washer Materials Cost Distribution

...................... 5

- 38 Table 5.6.11 Incremental Manufacturing Costs for Top

- Loading CCWs Based on MEF J2

...... 5

- 40 Table 5.6.12 Incremental Manufacturing Costs for Front

- Loading CCWs Based on MEF J2

.... 5

- 42

LIST OF FIGURE S Figure 5.5.1 Manufacturing Cost Assessment Stages

................................ ................................ 5

- 10 Figure 5.6.1 Relationship Between Equivalent MEF J2 (Appendix J2) and Rated MEF

(Appendix J1) for Top

- Loading CCWs

................................ ............................. 5

- 15 Figure 5.6.2 Relationship Between Equivalent IWF (Appendix J2) and Rated WF

(Appendix J1) for Top

- Loading CCWs

................................ ............................. 5

- 16 Figure 5.6.3 Relationship Between Equivalent MEF J2 (Appendix J2) and Rated MEF

(Appendix J1) for Front

- Loading CCWs

................................ ........................... 5

- 17 Figure 5.6.4 Relationship Between Equivalent IWF (Appendix J2) and Rated WF

(Appendix J1) for Front

- Loading CCWs

................................ ........................... 5

- 18 Figure 5.6.5 AHAM Soil/Stain Test Strip

................................ ................................ ................. 5

- 2 1 Figure 5.6.6 Total Cleaning Score vs. Appendix J2 MEF J2 Efficiency Level for Top

Loading CCWs

................................ ................................ ................................ ... 5

- 22 Figure 5.6.7 Total Cleaning Score vs. Appendi x J2 IWF Efficiency Level for Top

Loading CCWs

................................ ................................ ................................ ... 5

- 23 Figure 5.6.8 Total Cleaning Score vs. Cycle Time for Top

- Loading CCWs

............................ 5

- 23 Figure 5.6.9 Total Cleaning Score vs. Appendix J2 MEF J2 Efficiency Level for Front

Loading CCWs

................................ ................................ ................................ ... 5

- 24 Figure 5.6.10 Total Cleaning Score vs. Appendix J2 IWF Efficiency Level for Front

Loading CCWs

................................ ................................ ................................ ... 5

- 24 Figure 5.6.11 Total Cleaning Score vs. Cycle Time for Front

- Loading CCWs

........................ 5

- 25 Figure 5.6.12 Rinse Score vs. Appendix J2 MEF J2 Efficiency Level for Top

- Loading

CCWs

................................ ................................ ................................ ................. 5

- 26 Figure 5.6.13 Rinse Score vs. Appendix J2 IWF Efficiency Level for Top

- Loading

CCWs

................................ ................................ ................................ ................. 5

- 26 Figure 5.6.14 Rinse Score vs. Cycle Time for Top

- Loadin g CCWs

................................ ......... 5

- 27 Figure 5.6.15 Rinse Score vs. Appendix J2 MEF J2 Efficiency Level for Front

- Loading

CCWs

................................ ................................ ................................ ................. 5

- 28 Figure 5.6.16 Rinse Score vs. Appendix J2 IWF Efficiency Level for Front

- Loading

CCWs

................................ ................................ ................................ ................. 5

- 285-iii

Figure 5.6.17 Rinse Score vs. Cycle Time for Front

- Loading CCWs

................................ ....... 5

- 29 Figure 5.6.18 Sand Removal Score vs. Appendix J2 MEF J2 Efficiency Level for Top

Loading CCWs

................................ ................................ ................................ ... 5

- 30 Figure 5.6.19 Sand Removal Score vs. Appendix J2 IWF Efficiency Level for Top

Loading CCWs

................................ ................................ ................................ ... 5

- 31 Figure 5.6.20 Sand Removal Score vs. Appendix J2 MEF J2 Efficiency Lev el for Front

Loading CCWs

................................ ................................ ................................ ... 5

- 32 Figure 5.6.21 Sand Removal Score vs. Appendix J2 IWF Efficiency Level for Front

Loading CCWs

................................ ................................ ................................ ... 5

- 32 Figure 5.6.22 Production Cost Distribution for Baseline Top

- Loading CCW

.......................... 5

- 34 Figure 5.6.23 Baseline Top

- Load Standard Clothes Washer Materials Cost Distribution

........ 5

- 34 Figure 5.6.24 Production Cost Distribution for Efficiency Level 1 Front

- Loading

Commercial Clothes Washer

................................ ................................ ............. 5

- 38 Figure 5.6.25 Materials Cost Distribution for Efficiency Level 1 Front

- Loading

Commercial Clothes Washer

................................ ................................ ............. 5

- 38 Figure 5.6. 26 Cost

- Efficiency Curve Based on MEF J2 for Top

- Loading Commercial

Clothes Washer

................................ ................................ ................................ .. 5

- 40 Figure 5.6.27 Cost

- Efficiency Curve Based on MEF J2 for Front

- Loading Commercial

Clothes Washer

................................ ................................ ................................ .. 5

- 425-1 CHAPTER 5. ENGINEERING ANALYSIS

5.1 INTRODUCTION

After conducting the screening analysis, the U.S. Department of Energy (DOE) performed an engineering analysis based on the remaining design options

. The purpose of the engineering analysis is to establish the relationship between the manufacturing production cost (MPC) and increased levels of efficiency for each class of products. This relationship serves as the basis for cost/benefit calculations in terms of individual consumers, manufactu rers, and the nation. As part of the engineering analysis, DOE also tests a sample of products to determine how energy and water consumption varies with increased levels of efficiency.

The primary inputs to the engineering analysis are baseline information from the market and technology assessment ( c hapter 3 of th is technical support document ( TSD ) ) and technology options from the screening analysis ( chapter 4)

. Additional inputs include cost and energy efficiency data, which DOE received from the Associati on of Home Appliance Manufacturers (AHAM)

, and which DOE qualified and supplemented through teardown analysis and manufacturer interviews

. The primary output of the engineering analysis is a set of cost

efficiency curves

. DOE typically structures its engineering analysis around one of three methodologies

, described as follows:

(1) De sign

- option approach, which provides the incremental costs of adding to a baseline model design options that will improve its efficiency;

(2) E fficiency

- level approach, w hich provides the relative costs of achieving increases in energy efficiency levels, without regard to the particular design options used to achieve such increases; and

(3) C ost

- assessment (or reverse

- engineering) approach, which provides “bottom

- up”

manu facturing cost assessments for achieving various levels of increased efficiency, based on detailed data regarding costs for parts and material, labor, shipping/packaging, and investment for models that operate at particular efficiency levels

.

DOE conduct ed the engineering analyses for the top

- loading and front

- loading product classes using a combination of the efficiency

- level approach and cost

- assessment approach

. The
cost

- assessment approach provides an accurate means for estimating a single manufacture r’s incremental manufacturing costs for achieving various levels of increased efficiency. This approach involves physically disassembling commercially available products to develop cost

efficiency relationships for each manufacturer’s product lines. Becaus e each manufacturer may choose a different path to achieve higher levels of efficiency, an efficiency

- level approach5-2

produces an industry

- wide cost

- efficiency relationship for each product class. DOE developed
cost

- efficiency relationships for the top

- load ing and front

- loading product classes by calculating the market

- weighted average of the individual cost

- efficiency relationships it developed for each manufacturer.

5.2 TECHNOLOGIES UNABLE TO BE INCLUDED IN TH E ANALYSIS
In performing the engineering analysis, DOE did not consider for analysis certain technologies that met the screening criteria, described in chapter 4 of this TSD, but were unable to be e valuated for one or more of the following reasons: (1) data are not available to evaluate the energy efficie ncy characteristics of the technology; (2) available data suggested that the efficiency benefits of the technology would be negligible; or (3) certain technologies cannot be measured according to the conditions and methods specified in the DOE clothes wash er test procedure (10 CFR 430, subpart B, appendix J 2 ; hereafter, “appendix J2” ).

As described in final rule notice , i nterested parties suggested adding temperature

differentiated pricing controls to the list of design options for consideration . Such controls would offer the potential to incentiv iz e energy savings by providing favorable vend pricing for lower

temperature wash/rinse settings. DOE’s market analysis confirmed the availability of this feature on multiple clothes washer models from multiple manufacturers. However, DOE’s current test procedure at appendix J2 uses a fixed set Temperature Use Factors (TUFs), which represent the percentage of time an end

- user would select each wash/rinse temperature selection available on the clothes washer. Bec ause the TUFs in the test procedure are fixed, a clothes washer with temperature

- differentiated pricing controls would be tested the same way as an identical clothes washer without temperature

- differentiated pricing controls. Therefore, the energy savings of this technology cannot be measured according to the conditions and methods specified in the DOE clothes washer test procedure. Accordingly, DOE did not analyze this technology option in its final rule analysis

.

5.3 PRODUCT CLASSES ANALYZED
DOE separate s com mercial clothes washers into product classes and has formulated separate energy conservation standards for each class. The criteria for separation into different product classes are: (1) type of energy used; (2) capacity; or (3) other performance

- related f eatures such as those that provide utility to the consumer, or others deemed appropriate by the Secretary that would justify the establishment of a separate energy conservation standard. (42 U.S.C. 6295 ( q) and 6316(a))

As discussed in chapter 3 of this TSD, DOE has separated commercial clothes washers into two product classes for this rulemaking: top

- loading and front

- loading.5-3

5.4 EFFICIENCY LEVELS

5.4.1 Efficiency Metrics

The energy conservation standard levels for commercial clothes washers are currently defined by two factors

— modified energy factor ( MEF ) and water factor (WF). MEF is calculated as the clothes container capacity in cubic feet divided by the sum, expressed in kilowatt

- hours (kWh), of: (1) the total weighted per

- cycle hot water energy consumption; (2) the total weighted per

- cycle machine electrical energy consumption; and (3) the per

- cycle energy consumption for removing moisture from a test lo ad. WF is calculated as the weighted per

- cycle water consumption of the cold wash/cold rinse cycle divided by the clothes container capacity in cubic feet.

The equations for calculating MEF and WF are as follows:

where:

C= Clothes container capacity ( cubic feet ) HE T = Total weighted per

- cycle hot water energy consumption (kWh) ME T = Total weighted per

- cycle machine electrical energy consumption (kWh) D E = Per

- cycle energy consumption for removal of moisture from test load ( kWh )

where:

Q T = Total w eighted per

- cycle water consumption of cold wash/cold rinse cycles ( gallons ) C = Clothes container capacity ( cu.ft. ).

On March 7, 2012, DOE published a final rule amending its test procedures for residential clothes washers ( “March 2012 final rule”)

. (77 FR 13888 ) The March 2012 final rule included minor amendments to the test procedure at 10 CFR 430, subpart B, appendix J1 and also established a ne w test procedure at appendix J2. M anufacturers of commercial clothes washers must use appendix J1 to demonstr ate compliance with the current standards established by the January 2010 final rule . The use of appendix J2 will be required to demonstrate compliance with the amended energy conservation standards published in this final rule

.

In the March 2012 final r ule, DOE incorporated standby and off mode energy use with active mode energy use into an integrated metric, integrated modified energy factor (IMEF)

, contained in the new appendix J2 test procedure. Appendix J2 also retains provisions for5-4

calculating modi fied energy factor , which DOE designates as MEF J2

. As described in greater detail in the final rule

, the amended energy standards are based on MEF J2 as measured using appendix J2.

Table 5.4

. 1 shows the major revisions included in the amended test procedure that affect the calculated efficiency metrics for commercial clothes washers

.

Table 5.4

. 1 Revisions to the Clothes Washer Test Procedure that Significantly Affect Efficiency Metrics Factors Affecting MEF Appendix J1 Appendix J2

Capacity measurement For top

- loading clothes washers: Innermost diameter of the tub cover. (Defined as “Fill Level 3” in DOE guidance document 1 ) For top

- loading clothes washers: Uppermost edge of the rotating portion, including any balance ring. (Defined as “Fill Level 2” in DOE guidance document)

Dryer energy calculation Based on Load Adjustment Factor (LAF) of 0.52 multiplied by maximum test load weight Based on weighted average load size according to existing Load Usage Factors (LUF).
Dryer Usage Factor (DUF) DUF = 0.84 DUF = 0.91 Factors Affecting WF / IWF Appendix J1 (WF) Appendix J2 (IWF)
Capacity measurement See above. See above.

Water Consumption Based on water usage of Cold Wash / Cold Rinse cycles only. Based on weighted average of water usage of all Wash / Rinse temperature combinations

The amended water efficiency standards in this final rule are based on the IWF metric, which incorporates water consumption from all the temperature cycles included as part of the energy test cycle in appendix J2. T he IWF metric provides a more representative measure of water consumption than the WF metric , since it incorporates the water usage from all the wash/rinse temperature selections included for testing rather than just the cold/cold cycle, on which WF is based . The equation for IWF is as follows:

1 DOE issued g uidance in May 2010 on what is considered the clothes contain er for purposes of measuring clothes container capacity . The guidance is available at the residential clothes washer rulemaking website, http://www1.eere.en ergy.gov/guidance/detail_search.aspx?IDQuestion=568&pid=2&spid=15-5

where:

Q T = Total weighted per

- cycle water consumption of a ll wash cycles (gallons) C = Clothes container capacity ( cu.ft. ).

Current CCW product ratings are based on MEF and WF as measured using appendix J1

. To define energy efficiency levels based on MEF J2 and I WF as measured using appendix J2, DOE first conduct ed testing on a representative sample of CCWs, spanning the entire range of available efficiency levels, to determine each model’s corresponding appendix J2 rating. DOE then established baseline and higher efficiency levels based on the appendix J2 MEF J2 a nd I WF ratings.

For convenience, throughout this TSD, DOE displays both the appendix J1 and appendix J2 ratings corresponding to each efficiency level.

5.4.2 Appendix J1/

Appendix J2 Efficiency Metric Translations

Based on the test results described in section 5.6.2 of this TSD chapter , DOE translated the appendix J1 MEF/WF efficiency levels into appendix J2 MEF J2 /IWF efficiency levels for consideration in the final rule analysis. Table 5.4

. 2 shows the resulting efficiency level translations for top

- loading CCWs. Table 5.4

. 3 shows the resulting efficiency level translations for front

- loading CCWs.

Table 5.4

. 2 Appendix J1 and Appendix J2 Efficien cy Level Translations for Top

- Loading CCWs

Efficiency Level Efficiency Level

Source Appendix J1 Metrics Appendix J2 Metrics

MEF WF MEF J2 IWF

Baseline DOE Standard 1.60 8.5 1.15 8.9

Level 1 Gap Fill 1.70 8.4 1.35 8.8

Level 2 Maximum Available 1.85 6.9 1.55 6.95-6

Table 5.4

. 3 Appendix J1 and Appendix J2 Efficiency Level Translations for Front

- Loading CCWs

Efficiency Level Efficiency Level

Source Appendix J1 Metrics Appendix J2 Metrics

MEF WF MEF J2 IWF

Baseline DOE Standard 2.00 5.5 1.65 5.2

Level 1 CEE Tier 2 2.20 4.5 1.80 4.5

Level 2 CEE Tier 3 2.40 4.0 2.00 4.1

Level 3 Maximum Available 2.60 3.7 2.20 3.9

The following sections describe the baseline and higher efficiency levels in greater detai l.

5.4.3 Baseline Units

DOE select s baseline units as reference points for each product class

. The baseline unit in each product class represents the basic characteristics of equipment in that class

. Typically, a baseline unit is a unit that just meets current e nergy conservation standards and provides basic consumer utility. DOE use s the baseline units in the engineering analysis and the LCC and PBP analysis

. To determine energy savings an d changes in price, DOE compares each higher energy efficiency design opti on with the baseline unit

. DOE established the baseline level for the top

- loading product class based on the 1. 60 MEF and the 8.5 WF requirements specified by current Federal energy conservation standards

, which became effective for commercial clothes washers manufactured on or after January 8, 2013

. For the front

- loading product class, DOE established the baseline level based on the 2.00 MEF and 5.5 WF requirements specified by current Federal energy conservation standards.

5.4.4 Higher Efficiency L evels
For the top

- loading and front

- loading product classes, DOE considered efficiency levels higher than baseline levels based on the Consortium for Energy Efficiency (CEE) former Tier levels for commercial clothes washers. 2 The highest efficiency levels were defined by the maximum available technology that DOE could identify on the market. For the top

- loading product class, DOE added an i ntermediate “gap fill” levels between the baseline and maximum available efficiency level s.

2 CEE has historically maintained a Commercial Clothes Washer Initiative that encourages the purchase and use of energy and water efficient commercial clothes washers. Given recent changes to federal minimum efficiency standards and ENERGY STAR criteria for commercial clothes washers, the CEE Commercial Clothes Washer Specification is not currently active. As a result, publication of the associated qualifying product list is also temporarily s uspended.5-7

5.4.5 Maximum Technologically Feasible Efficiency Levels
Under EPCA, DOE is required to consider the maximum technologically feasible level (“max

- tech”) . DOE determines max

- tech levels based on technologies that are either commercially available or have been demonstrated as working prototypes. If the max

- tech design meets DOE’s screening criteria, DOE considers the design in further analysis. DOE also considers consumer utility and availability of features, which may be met by a niche product, as required by E PCA.

DOE identified the max

- tech level s for top

- loading and front

- loading commercial clothes washers based on the maximum performance of products currently on the market in the United States. D OE has observed that the max

- tech units on the market use a co mbination of reduced water volumes, reduced water temperatures, extended cycle times, high er spin speeds. DOE is not aware of any additional design options that could be used to increase the efficiency beyond the max

- tech levels without causing potential negative effects on consumer utility. Nor is DOE aware of any working prototype clothes washe rs that exceed the efficiency levels of the max

- tech units on the market in the United States. Therefore, DOE has determined that with the current state of technology for CCWs

, the “max available” efficiency levels identified for top

- loading and front

- load ing CCWs correspond to the maximum technologically feasible efficiency levels

. DOE notes, however, that further technological development in top

- loading and front

- loading clothes washer technologies could lead to higher max

- tech levels in the future.

5.5 METHO DOLOGY OVERVIEW

DOE conducted energy and water testing, cleaning and rinsing performance testing, and standby power testing on a representative sample of top

- loading and front

- loading CCWs spanning a range of efficiencies and manufacturers. The objective o f this testing was to gain insights into the relative performance differences among the CCW models available on the market. DOE conducted its testing at an independent laboratory with significant experience performing clothes washer testing. Following test ing, DOE performed detailed product teardowns and cost modeling to generate cost

- efficiency curves for each product class. Finally, DOE conducted interviews with commercial clothes washer manufacturers to better understand and explain the differences among manufacturers in baseline unit construction, design strategies for achieving higher efficiency levels, and overall cost structures.

5.5.1 AHAM Data Request
In support of this rulemaking effort, DOE requested incremental cost data from AHAM for commercial clot hes washers

. The AHAM data request is presented in Appendix 5

- A to this TSD. The data represent the average incremental production cost to improve a baseline unit to a specified efficiency level

. In addition, DOE requested shipments, shipment

- weighted aver age efficiency, and market share efficiency data

. AHAM’s data submissions are available in the docket for this rulemaking at regulations.gov.5-8

5.5.2 Product Testing Methodology
DOE conducted performance testing on a range of CCW models for the following
purposes :

 Determine equivalent MEF J2 and IWF ratings using the new appendix J2 test procedure;

 Verify performance trends that are apparent in the publicly available data;

 Develop a better understanding of the operational characteristics of CCWs; and

 Evaluate pot ential impacts on cleaning and rinsing performance as a result of higher efficiency levels.

DOE conducted testing on a representative sample of top

- loading and front

- loading CCWs spanning a range of efficiencies and manufacturers. DOE conducted its testing at an independent laboratory with significant experience performing clothes washer testing . DOE used the following test procedures for its testing:

 10 CFR 430, subpart B, Appendix J1,

 10 CFR 430, subpart B, Appendix J2

 AHAM HLW

- 1

- 2010, Performance Evaluation Procedures for Household Clothes Washers 3

Within AHAM HLW

- 1

- 2010, DOE performed the following tests:

 Soil/Stain Removal (Section 6)

 Sand Removal (Section 8)

 Rinsing Effectiveness Test (Annex E)

Section 5.6.2 provides detailed results of this testing.

5.5.3 Product Teardown Methodology

Other than obtaining detailed manufacturing costs directly from a manufacturer, the most accurate method for determining the production cost of a product is to disass emble representative units piece

- by

- piece and estimate the material, labor, and overhead costs associated with each component using a process commonly called a physical teardown. A supplementary method, called a catalog teardown, uses published manufacture r catalogs and supplementary component data to estimate the major physical differences between a product that has been physically disassembled and another similar product. DOE performed physical teardown analysis on both top

- loading and front

- loading comme rcial clothes washers. The teardown methodology is explained in the following sections.

3 Available from AHAM at http://www.aham.org/ht/d/ProductDetails/sku/4045

- 110

- 140/from/714/pid/ AHAM has since issued a revised version of this test method, HL W

- 1

- 2013.5-9 5.5.3.1 Selection of Units

DOE generally adopts the following criteria for selecting units for teardown analysis:

 The selected products should span the full range of efficiency levels for each product class under consideration;

 Within each product class, the selected products should, if possible, come from the same manufacturer and belong to the same product platform;

 The selected products should, if possible, come from manufact urers with large market shares in that product class, although the highest efficiency products are chosen irrespective of manufacturer; and

 The selected products should have non

- efficiency

- related features that are the same as, or similar to, features of o ther products in the same class and at the same efficiency level.

5.5.3.2 Generation of Bill of Materials

The end result of each teardown is a structured bill of materials (BOM), which describes each product part and its relationship to the other parts, in the est imated order of assembly. The BOMs describe each fabrication and assembly operation in detail, including the type of value

— added equipment needed ( e.g. , stamping presses, injection molding machines, spot

- welders, etc.) and the estimated cycle times associa ted with each conversion step. The result is a thorough and explicit model of the production process.

Materials in the BOM are divided between raw materials that require conversion steps to be made ready for assembly, while purchased parts are typically delivered ready for installation. The classification into raw materials or purchased parts is based on D OE’s previous industry experience, recent information in trade publications, and discussions with original equipment manufacturers (OEMs). For purchased parts, the purchase price is based on volume

- variable price quotations and detailed discussions with su ppliers.

For parts fabricated in

- house, the prices of the underlying “raw” metals ( e.g. , tube, sheet metal) are estimated on the basis of 5

- year averages to smooth out spikes in demand. Other “raw” materials such as plastic resins, insulation materials, e tc. are estimated on a current

- market basis. The costs of raw materials are based on manufacturer interviews, quotes from suppliers, secondary research, and by subscriptions to publications including the American Metals Market (AMM). 4 Past price quotes are indexed using applicable Bureau of Labor Statistics producer price index tables as well as AMM monthly data.

5.5.3.3 Cost Structure of the Spreadsheet Models

The manufacturing cost assessment methodology uses a detailed, component

- focused technique for rigorousl y calculating the manufacturing cost of a product (direct materials, direct

4 For information on American Metals Market, please visit: www.amm.com

.5-10

labor and some overhead costs). Figure 5.5

. 1 shows the three major steps in generating the manufacturing cost.

Figure 5.5

. 1 Manufacturing Cost Assessment Stages

The first step in the manufacturing cost assessment is the creation of a complete and
str uctured BOM from the disassembly of the units selected for teardown . The units are dismantled, and each part is characterized according to weight, manufacturing processes used, dimensions, material, and quantity. The BOM incorporates all materials, compone nts, and fasteners with estimates of raw material costs and purchased part costs. Assumptions on the sourcing of parts and in

- house fabrication are based on industry experience, information in trade publications, and discussions with manufacturers. Intervi ews and plant visits are conducted with manufacturers to ensure accuracy on methodology and pricing.

Following the development of a detailed BOM, the major manufacturing processes are identified and developed for the spreadsheet model. Some typical process es are listed in Table 5.5

. 1

.
Table 5.5

. 1 Major Manufacturing Processes

Fabrication Finishing Assembly/Joining Quality Control Fixturing Stamping/Pressing Brake Forming Cutting and Shearing Insulating Turret Punch Tube Forming Enameling Washing

Powder Coating De

- burring Polishing Refrigerant Charging Adhesive Bonding

Spot Welding Seam Welding Packaging Inspecting &

Testing

Fabrication process cycle times for each part made in

- house are estimated and entered into the BOM. Based on estimated assembly and fabrication time requirements, the labor content of each appliance can be estimated.

Cycle requirements for fabrication steps are similarly aggregated by fabrication machine type while accounting for dedicated vs. non

- dedicated machinery and/or change

- over times (die swaps in a press, for example). Once the cost estimate for each teardown unit are finalized, a detailed summary is prepared for relevant components, subassemblies and processes. The BOM thus details all aspects of unit costs: material, labor, and overhead.5-11

Design options used in units subject to teardown are noted in the summa ry sheet of each cost model and are cost

- estimated individually. Thus, various implementations of design options can be accommodated, ranging from assemblies that are entirely purchased to units that are made entirely from raw materials. Hybrid assemblies, consisting of purchased parts and parts made on site are thus also accommodated.

5.5.3.4 Cost Model and Definitions
The cost model is based on production activities and divides factory costs into the following categories:

 Materials: Purchased parts ( i.e. , motor s, valves, etc .), raw materials, ( i.e. , cold rolled steel, copper tube, etc .), and indirect materials that are used for processing and fabrication.

 Labor: Fabrication, assembly, indirect, and supervisor labor. Fabrication and assembly labor cost are burdened with benefits and supervisory costs.

 Overhead: Equipment, tooling, and building depreciation, as well as utilities, equipment and tooling maintenance, insurance, and property taxes.

Cost Definitions Because there are many different accounting sys tems and methods to monitor costs, DOE defined the above terms as follows:

 Direct material: Purchased parts (out

- sourced) plus manufactured parts (made in

- house from raw materials).

 Indirect material: Material used during manufacturing ( e.g. , welding rods , adhesives).

 Fabrication labor: Labor associated with in

- house piece manufacturing.

 Assembly labor: Labor associated with final assembly.

 Supervisory labor: Labor associated with fabrication and assembly basis. Assigned on a span basis (x number of employ ees per supervisor) that depends on the industry.

 Indirect labor: Labor costs that scale with fabrication and assembly labor. These included the cost of technicians, manufacturing engineering support, stocking, etc . that are proportional to all other labor

.

 Equipment depreciation: Money allocated to pay for initial equipment installation and replacement as the production equipment is amortized. All depreciation is assigned in a linear fashion and affected equipment life depends on the type of equipment.

 To oling depreciation: Cost for initial tooling (including non

- recurring engineering and debugging of the tools) and tooling replacement as it wears out or is rendered obsolete.

 Building depreciation: Money allocated to pay for the building space and the conv eyors that feed and/or make up the assembly line.

 Utilities: Electricity, gas, telephones, etc.

 Maintenance: Annual money spent on maintaining tooling and equipment.

 Insurance: Appropriated as a function of unit cost.

 Property Tax: Appropriated as a functi on of unit cost.5-12 5.5.3.5 Cost Model Assumptions
As discussed in the previous section, assumptions about manufacturer practices and cost structure played an important role in estimating the final product cost. In converting physical information about the product i nto cost information, DOE reconstructed manufacturing processes for each component using internal expertise and knowledge of the methods used by the industry. Site visits allowed DOE to confirm its cost model assumptions through direct observation of the

m anufacturing plant, as well as through manufacturer interviews, reviews of current Bureau of Labor Statistics data, etc.

5.5.4 Manufacturer Interviews

DOE understands that there is variability among manufacturers in baseline units, design strategies , and cost structures

. To be tter understand and explain these variances, DOE conducted manufacturer interviews

. These confidential interviews provided a deeper understanding of the various combinations of technologies used to increase residential clothes washer efficiency, and their associated manufacturing costs

. Sample questions asked during the interviews are contained in a ppendix 12A

. During the interviews, DOE also gathered information about the capital expenditures required to increase the efficiency of the baseline units to various efficiency levels ( i.e.
, conversion capital expenditures by efficiency or energy

- use level)

. The interviews provided information about the size and the nature of the capital investments

. DOE also requested information about the d epreciation method used to expense the conversion capital. The manufacturer impact analysis in c hapter 12 includes a discussion of this information obtained during manufacturer interviews.

5.6 ANALYSIS AND RESULTS

5.6.1 AHAM Data

In its data submittal to DOE, AHAM stated that it has not collected incremental cost data from CCW manufacturers and therefore cannot provide that data to DOE.

5.6.2 Product Testing Results

DOE tested a total of 10 commercial clothes washer models in support of this rulemaking: five top

- loading and five f ront

- loading units. DOE also conducted teardowns on these 10 clothes washer models. D OE selected clothes washer models for testing and teardowns that spanned the range of product efficiencies available on the market. Table 5.6

. 1 lists the major features of the top

- loading CCWs observed at each efficiency level. Table 5.6

. 2 lists the major features of front

- loading CCWs observed at each efficiency level. The efficiency levels listed in these tables correspond to the levels shown above in Table 5.4

. 2 and Table 5.4

. 3

. Note that for5-13

top

- loading Units #2 and #3, the Efficiency Level changes depending on whether Appendix J1 or Appendix J2 is used. The next section below provides further details regarding the test result differences between Appendix J1 and A ppendix J2.

Table 5.6

. 1 Top

- Load ing Commercial Clothes Washer Test Unit Features

Feature Unit #1 Unit # 2 Unit #3 Unit # 4 Unit #5 Appendix J2 Efficiency Level ( MEF J2 /IWF) Baseline (1.15/8.9) Baseline

(1.15/8.9) Level 1

(1.35/8.8) Level 1

(1.35/8.8) Level 2

(1.55/6.9) Appendix J1Efficiency Level ( MEF

/WF) Baseline

( 1.60 /8.5) Level 1

( 1. 7 0 /8.4) Baseline

(1.15/8.9) Level 1

( 1. 7 0 /8.4) Level 2

( 1.85 /6.9) Efficiency Level WF (Appendix J2 IWF) [gal/ ft 3 ] 8.5 (8.9) 8.4 (8.8) 8.5 (8.9) 8.4 (8.8) 6.9 (6.9)

Rated Drum Capacity (ft 3 ) 3.5 3.3 3.3 3.3 2.9

R emaining Moisture Content (%) 50.8% 48.1% 49.5% 48.0% 47.2%

Control Panel Type No vend display Vend

price display + advanced features 1 No vend

display Vend

price display No vend

display

Payment System Type None (“push to start”) Coin box Coin box Coin box Coin slide

Advanced Auditing or Remote Communication Features No Yes No No No

Water Fill Control Manual Manual Automatic Fixed Automatic

Fixed Automatic

Adaptive

Agitator Type Standard Standard Standard Standard Low

Profile
Internal Heater No No No No No
1. Advanced features may include dynamic or cycle

- based pricing controls, built

- in logging capabilities, and remote auditing features.5-14

Table 5.6

. 2 Front

- Load ing Commercial Clothes Washer Test Unit Features

Feature Unit #1 Unit # 2 Unit #3 Unit # 4 Unit #5 Appendix J2 Efficiency Level ( MEF J2 /IWF) Level 1 (1.80/4.5) Level 1

(1.80/4.5) Level 2

(2.00/4.1) Level 2

(2.00/4.1) Level 3

(2.20/3.9) Appendix J1 Efficiency Level ( MEF

/WF) Level 1

(2.20/4.5) Level 1

(2.20/4.5) Level 2

(2.40/4.0) Level 2

(2.40/4.0) Level 3

(2.60/3.7) Rated Drum Capacity (ft 3 ) 2.8 3.1 2.8 3.1 3.6

R emaining Moisture Content (%) 39.6% 37.9% 39.6% 35.5% 33.4%

Control Panel Type Vend price display + advanced features 1 Vend

price display Vend

price display + advanced features 1 Vend

price display No vend

display

Payment System Type Coin box Coin box Coin box Coin box None (“push to start”) Advanced Auditing or Remote Communication Features Yes No Yes No No

Water Fill Control Automatic Adaptive Automatic

Adaptive Automatic

Adaptive Automatic

Adaptive Automatic

Adaptive
Internal Heater No No No No No
1. Advanced features may include dynamic or cycle

- based pricing controls, built

- in logging capabilities, and remote auditing features.

5.6.2.1 Active Mode Testing
DOE conducted testing on a representative sample of five top

- loading and five front

loading CCWs using both appendix J1 and appendix J2. DOE used the results from these tests to determine each model’s appendix J2 MEF J2 /IWF ratings in relation to its appendix J1 MEF/WF ratings. These relationships were then used to develop the equivalent Appendix J2 va lues for each Appendix J1 efficiency level shown in Table 5.4

. 2 and Table 5.4

. 3

. The DOE test procedure consists of running different load sizes of preconditioned test cloth in the clothes washer at various tem perature settings. For all clothes washers, the minimum test load is 3 pounds of test cloth. Average and maximum load sizes are specified based on the clothes washer capacity. During the energy test cycles, the total kWh of electric energy consumed by the clothes washer is measured, in addition to the cold and hot water consumption.5-15

The measurements also include the “bone dry” 5 weight of the test load and the weight immediately after the completion of certain energy test cycles for the R emaining Moisture Co ntent (R MC ) calculation.

Figure 5.6

. 1 shows a plot of the equivalent MEF J2 values (using appendix J2) associated with the rated MEF values (using appendix J1) for each of the top

- loading CCWs in the test sample. For reference, the pl ot also indicates the associated efficiency levels used for the rulemaking analysis, based on appendix J2 MEF J2 ratings.

Figure 5.6

. 1 Relationship Between Equivalent MEF J2 (Appendix J2) and Rated MEF (Appendix J1) for Top

- Loading CCWs

Figure 5.6

. 1 shows that top

- loading clothes washers with manual water fill controls have lower relative appendix J2 MEF J2 ratings compared to similarly

- rated units (bas ed on appendix J1) with automatic water fill controls. 6 As a result, some manual water fill units that would have been considered higher

- efficiency models under appendix J1 ratings are considered baseline models under appendix J2 ratings.

The primary driv er of the lower relative efficiency ratings under appendix J2 for units with manual water fill controls is the amended calculation of drying energy in section 4.3 of

5 “Bone dry” means a condition of a load of test clothes which has been dried in a dryer at maximum temperature for a minimum of 10 minutes, removed and weighed before cool down, and then dried again for 10

- minute periods until the final weight change of th e load is 1 percent or less.

6 The term “automatic” water fill used here refers to water fill control systems that determine the water fill level without requiring user intervention or actions. This includes “adaptive” water fill control systems and “fixed ” water fill control systems, available on some commercial clothes washers, that provide a fixed water level for all load sizes and no water fill selector or water fill control settings available to the user.5-16

appendix J2. In appendix J2, the drying energy is calculated using the weighted average lo ad size, with the weightings corresponding to the Load Usage Factors (LUF) for manual water fill machines. Whereas, in section 4.3 of appendix J1, the drying energy is calculated using an adjusted load size equal to 0.52 x Maximum Load Size. The calculated drying energy using appendix J2 is a greater quantity than under appendix J1; thus resulting in a lower MEF J2 value. For units with adaptive fill controls, the difference between the weighted average load size in appendix J2 and the adjusted load size in appendix J1 is much less; therefore, the difference in drying energy is not as pronounced as with manual water fill units.

Figure 5.6

. 2 shows a plot of the equivalent IWF values (using appendix J2) associated with the rated WF values (using appendix J1) for each of the top

- loading CCWs in the test sample. For reference, the plot also indicates the associated efficiency levels used for the rulemaking analysis, based on appendix J2 IWF ratings.

Figure 5.6

. 2 Relationship Between Equivalent IWF (Appendix J2) and Rated WF (Appendix J1) for Top

- Loading CCWs

Figure 5.6

. 3 shows a plot of the equivalent MEF J2 values (using appendix J2) associated with the rated MEF values (using appendix J1) for each of the front

- loading CCWs in the test sample. For reference, the plot also indicates the associated efficiency levels used for the rulemaking analysis, based on appendix J2 MEF J2 ratings.5-17

Figure 5.6

. 3 Relationship Between Equivalent MEF J2 (Appendix J2) and Rated MEF (Appendix J1) for Front

- Loading CCWs

DOE is not aware of any front

- loading CCWs on the market with a rating of 2.00 MEF, which corresponds to the current minimum s tandard level. As a result, DOE used data from the prior CCW rulemaking to represent the 2.00 MEF level, indicated in Figure 5.6

. 3 as a “virtual model.” To calculate the equivalent appendix J2 MEF J2 for the virtual model, DOE assumed that a model with a 2.00 MEF rating under appendix J1 would have the same measured capacity, machine electrical, and hot water heating energy under appendix J2. The only change would be the drying energy calculation, as described above.

Figure 5.6

. 4 shows a plot of the equivalent IWF values (using appendix J2) associated with the rated WF values (using appendix J1) for each of the front

- loading CCWs in the test sample. For reference, the plot also indicates the associated efficiency levels used for t he rulemaking analysis, based on appendix J2 IWF ratings.5-18

Figure 5.6

. 4 Relationship Between Equivalent IWF (Appendix J2) and Rated WF (Appendix J1) for Front

- Loading CCWs

5.6.2.2 Standby Mode and Off Mode Power
The amended energy standards established by this final rule are based on MEF J2 , which does not incorporate standby and off mode power. As part of its investigational testing, however, DOE measured standby and off mode power for all 10 clothes washers sele cted in the test sample, using the methodology provided in Appendix J2, which references International Electrotechnical Commission (IEC) Standard 62301 Second Edition.

CCW manufacturers offer a variety of display and payment functionalities that can be

s elected independent of the basic model selected. The standby power associated with these different display and payment functionalities varies widely. The lowest standby power levels are associated with models having no vend price display and no coin or ca rd payment options (often referred to as “push

- to

- start” models). These models are typically used in multi

- family housing facilities offering free laundry, or in other commercial applications not requiring fare payment. Such models are not suitable for coi n

- operated laundry or most multi

- family housing facilities. The highest standby power levels are associated with models having a digital vend price display, coin or debit card payment system, and advanced features such as dynamic or cycle

- based pricing con trols, built

- in logging capabilities, and remote auditing features. These models are typically used in coin

- operated laundries located in competitive markets.

The results of the standby and off mode measurements are shown in Table 5.6

. 3 below.5-19

Table 5.6

. 3 Commercial Clothes Washer Standby Power Measurements

Product Class Rated

MEF (ft 3 /kWh) Control Panel Type Payment System Type Power

Consumpti

on (W)

Top

Loading 1.60 No vend display Push

- to

- start 2.84

1.65 No vend display Coin slot 5.44

1.70 Vend price only Coin slot 10.21

1.75 Vend price display + advanced features 1 Coin slot 11.77

1.85 No vend display Coin slide 0.88

Front

Loading 2.24 Vend price display + advanced features 1 Coin slot 11.60

2.24 Vend price only Coin slot 7.10

2.46 Vend price display + advanced features 1 Coin slot 11.30

2.49 Vend price only Coin slot 7.70

2.60 Vend price only Push

- to

- start 5.80

1. Advanced features may include dynamic or cycle

- based pricing controls, built

- in logging capabilities, and remote auditing features.

5.6.2.3 Cleaning Performance Testing
To investigate potential impacts on cleaning performance, rinsing performance, and solid particle removal, DOE performed additional testing on each model using AHAM’s HLW

- 1

- 2010 test method: Performance Evaluation Procedures for Household Clothes Washers (hereafter, “AHAM HLW

- 1

- 2 010”). Specifically, DOE performed the soil/stain removal, rinsing effectiveness, and sand removal tests provided in HLW

- 1

- 2010. For each clothes washer, DOE tested the maximum load size specified in appendix J2, rounded to the nearest pound, using the

war m wash/cold rinse cycle. DOE believes that the maximum load size is particularly relevant to commercial clothes washer owners and operators because end

- users often overload the machines in order to limit their total laundry cost

.

DOE consulted with a num ber of manufacturers who indicated that AHAM HLW

- 1

- 2010 would be the most appropriate test method to determine relative cleaning performance across different commercial clothes washer models. DOE recognizes that AHAM HLW

- 1

- 2010 is typically used to measure the performance of residential clothes washers, but given the similarities in physical construction, DOE believes the test procedure is also appropriate for commercial clothes washers covered by DOE standards . DOE also acknowledges that the commercial clo thes washer industry has not agreed upon acceptable ranges of performance characteristic s. DOE also recognizes that the tests described below were conducted using a single5-20

load size and wash/rinse temperature, and that such results may not provide a complete characterization of each model’s performance. Therefore, for these reasons, the test results provided below should be considered informative in nature and used for relat ive comparison purposes only.

Cleaning Performance
DO E performed the Soil/Stain Removal test within section 6 of AHAM HLW

- 1

- 2010 to measure relative cleaning performance among the CCW test sample units. AHAM HLW

- 1

- 2010 states that the purpose of the Soil /Stain Removal test is to evaluate the performance of household clothes washers in removing representative soils and stains from fabric. For each clothes washer, DOE tested the maximum load size specified in appendix J2, rounded to the nearest pound, and

u sed the warm wash/cold rinse cycle.

The AHAM HLW

- 1

- 2010 Soil/Stain Removal test consists of running a wash cycle with

user

- defined test load size and machine settings , using AHAM base load materials

, a defined number of soil/stain strips , and a defined q uantity of powdered AHAM detergent . The AHAM base load materials consist of 100% cotton sheets, towels, and pillowcases. The soil/stain strips consist of square test fabric swatches measuring 4.7 in. x 4.7 in., carrying five different types of standard sta ins in addition to a sixth unstained swatch . The swatches are attached to each other, forming a test strip with the different stains in the following order:

1. Unsoiled 2. Pigment/sebum 3. Carbon black/mineral oil. 4. Blood. 5. Chocolate and milk. 6. Red wine

Figure 5.6

. 5 shows the soil/stain strips, including typical packaging material. The photo includes a printed copy of the AHAM HLW

- 1

- 2010 test procedure for scale.5-21 Figure 5.6

. 5 AHAM Soil/Stain Test Strip

Multiple stain strips are attached to individual towels comprising the test load. AHAM HLW

- 1

- 2010 defines the number of test strips based on the total load size. Three replications of the Soil/Stain Removal test are performed on each clothes washer, using fresh soil/stain strips for each replication.

After a single wash cycle replication is performed, the soil/stain test strips are removed from the base load and measured using a tristimulus c olorimeter

. The unsoiled swatches are removed and used for the Rinsing Effectiveness test, as described in the next section of this chapter. The reflectance values of each stain swatch are measured; higher reflectance represents better stain removal. For each stain type , the reflectance va lues measured from all soil/stain test strip s are averaged to produce an average reflectance score, y w lab for each stain. For each stain type, an Individual Cleaning Score, CS i , is obtained, expressed as:

w here for each soil/stain:
y max lot = post

- wa sh reflectance as determined by the strip manufacturer using the calibration wash treatment defined in Annex A.A.7.1 of HLW

- 1

- 2010;
y w lab = post

- wash reflec tance as measured by laboratory.

CS i is determined for each stain type after each wash cycle repl ication. After the three replications have been performed, the three CS i scores for each stain type are averaged, to produce a mean CS i score for each stain type. A Total Cleaning Score, CS t , is then determined by averaging the mean CS i scores for all five stain types and multiplying by 100:5-22

The Total Cleaning Score represents cleaning performance as a percentage of that achieved by a reference “maximum” wash cycle determined by the calibration wash treatment performed by the stain strip m anufacturer. The Total Cleaning Score may be less than or greater than 100%. A higher Total Cleaning Score represents better cleaning performance.

Top

- Loading Results Figure 5.6

. 6 shows the Total Cleaning Score for each top

- loading CCW included in the test sample as a function of each washer’s appendix J2 MEF J2 efficiency level. Figure 5.6

. 7 shows the Total Cleaning Score for each top

- loading CCW as a function of each washer’s appendix J2 IWF efficiency level. As shown in both figure s , some of the higher

- efficiency clothes washers in the test sample actually achieve better Total Cleaning Scores than the baseline models. The amended standard in this final rule correspond s to Efficiency Level 1 (1.35 MEF J2 / 8.8 I WF).

Figure 5.6

. 6 Total Cleaning Score vs. Appendix J2 MEF J2 Efficiency Level for Top

Loading CCWs5-23

Figure 5.6

. 7 Total Cleaning Score vs. Appendix J2 IWF Efficiency Level for Top

- Loading CCWs

Figure 5.6

. 8 shows the Total Cleaning Score for each top

- loading CCW as a function of each washer’s cycle time, as measured during the AHAM HLW

- 1

- 2010 t est. DOE notes that these cycle times may not correspond to the same cycle times when conducting the DOE appendix J2 test procedure, due to differences in the base load material that may affect any adaptive control strategies used throughout the wash cycle . However, DOE believes that the cycle times shown in the figure are likely to be representative of consumer usage in a coin

operated laundry or multi

- family housing laundry setting. As shown in the figure, one of the CCW models at Efficiency Level 1 achie ves a better cleaning performance score than baseline models, at a cycle time of just under 30 minutes.

Figure 5.6

. 8 Total Cleaning Score vs. Cycle Time for Top

- Loading CCWs5-24

Front

- Loading Results Figure 5.6

. 9 shows the Total Cleaning Score for each front

- loading CCW included in the test sample as a function of each washer’s appendix J2 MEF J2 efficiency level. Figure 5.6

. 10 shows the Total Cleaning Score f or each front

- loading CCW as a function of each washer’s appendix J2 IWF efficiency level

. DOE notes that one Level 2 clothes washer achieves equivalent or better performance than both Level 1 clothes washer s

. The amended standard in this final rule corres ponds to Efficiency Level 2 (2.00 MEF J2 / 4.1 IWF).

Figure 5.6

. 9 Total Cleaning Score vs. Appendix J2 MEF J2 Efficiency Level for Front

Loading CCWs

Figure 5.6

. 10 Total Cleaning Score vs. Appendix J2 IWF Efficiency Level for Front

Loading CCWs5-25

F igure 5.6

. 11 shows the Total Cleaning Score for each front

- loading CCW as a function of each washer’s cycle time, as me asured during the AHAM HLW

- 1

- 2010 test. As shown in the figure, cycle times for Efficiency Level 2 clothes washers range from around 31 minutes to just over 36 minutes. The range of cycle times for the Level 1 models is approximately 31 to 34 minutes.

F igure 5.6

. 11 Total Cleaning Score vs. Cycle Time for Front

- Loading CCWs

Rinsing Performance The AHAM Rinsing Effectiveness test consists of measuring the concentration of detergent remaining in the unstained swatches after performing the Soil/Stain Removal tests described in the previous section. This is accomplished by measuring the UV absorbance at the wavelength particular to LAS (surfactant), a key ingredient of the detergent with a known linear relationship to the quantity of detergent mixture. Using a concentration vs. a bsorbance curve developed as part of this procedure, the absorbance values are then converted into detergent concentrations, which together with test solution weight data, yields detergent quantities.

After a single wash cycle replication is performed, the unsoiled test strips are removed and each strip is placed into an individual bottle with 100ml distilled water. After all the test strips have been bottled, they are placed on a laboratory shaker for 20 minutes. Following that, samples of the fluid from each bottle are then collected and measured in a UV spectrophotometer. The measured values are translated into detergent concentrations using the detergent concentration curves developed at the beginning of the procedure. The detergent concentration is then used to determine the amount of detergent recovered per gram of swatch5-26

material. The final Rinse Score is then calculated as the amount of detergent, in grams, remaining in a pound of test load. A lower Rinse Score represents better rinsing performance.

Top

- Loading Results Figure 5.6

. 12 shows the Rinse Score for each top

- loading CCW included in the test sample as a function of each washer’s appendix J2 MEF J2 efficiency level. Figure 5.6

. 13 shows the Rinse Score for each top

- loading CCW as a function of each washer’s appendix J2 IWF efficiency level. DOE notes that the highest

- efficiency washer at Efficiency Level 2 achieves a rinse score within the range of rinse scores achieved by the baseline models. The amended standard in this final rule corresponds to Efficiency Level 1 (1.35 MEF J2 / 8.8 IWF).

Figure 5.6

. 12 Rinse Score vs. Appen dix J2 MEF J2 Efficiency Level for Top

- Loading CCWs

Figure 5.6

. 13 Rinse Score vs. Appendix J2 IWF Efficiency Level for Top

- Loading CCWs5-27

Figure 5.6

. 14 shows the Rinse Score for each top

- loading CCW as a function of each washer’s cycle time, as measured d uring the AHAM HLW

- 1

- 2010 test.

Figure 5.6

. 14 Rinse Score vs. Cycle Time for Top

- Loading CCWs

Front

- Loading Results Figure 5.6

. 15 shows the Rinse Score for each front

- loading CCW included in the test sample as a function of each washer’s appendix J2 MEF J2 efficiency level. Figure 5.6

. 16 shows the Rinse Score for each front

- loading CCW as a function of each washer’s appendix J2 IWF efficiency level. DOE notes that one of the Level 2 models achieves the lowest (best) Rinse Score of the entire test sample, at around 0.8. The amended standard level established by this final rule correspond s to Efficiency Level 2

.5-28

Figure 5.6

. 15 Rinse Score vs. Appendix J2 MEF J2 Efficiency Level for Front

- Loading CCWs

Figure 5.6

. 16 Rinse Score vs. Appendix J2 IWF Efficiency Level for Front

- Loading CCWs

Figure 5.6

. 17 shows the Rinse Score for each front

- loading CCW as a function of each washer’s cycle time, as measured during the AHAM HLW

- 1

- 2010 test.5-29 Figure 5.6

. 17 Rinse Score vs. Cycle Time for Front

- Loading CCWs

Sand Removal Performance
DO E performed the Sand Removal test within section 8 of AHAM HLW

- 1

- 2010, the purpose of which is to evaluate the ability of a clothes washers to remove insoluble and heavier

than

- water soils from clothes and the system. For each clothes washer, DOE tested the maximum load size specified in appendix J2, rounded to the nearest pound, and used the warm wash/cold rinse cycle. The Sand Removal test is performed separately from the Soil/Stain Removal and Rinsing Effectiveness tests. Three repl ications of the test are performed.

The AHAM HLW

- 1

- 2010 Sand Removal test consists of running a wash cycle with user

defined test load size and machine settings, using AHAM base load materials, a defined quantity of powdered AHAM detergent, and 50 grams of sand added to the load. During the wash cycle, sand is collected through a filter placed at the end of the clothes washer drain hose. Upon completion of the wash cycle, the test load is removed and any sand particles remaining in the clothing load are c aptured and measured. The Sand Remaining score, SR, is calculated as the quantity of sand remaining in the load (in grams) divided by the amount of sand added to the load (50 grams). A lower SR score represents better sand removal performance

. During tes ting, some sand may remain trapped in the clothes washer after each replication. Therefore, after each replication, “cleanup cycles” with no load are performed to flush out any sand remaining inside the washer. However, in some cases, despite running multi ple cleanup cycles, not all the sand was accounted for after each replication of the test. Therefore, the second and third replications of each test may contain sand carried over from prior5-30

tests. DOE notes that because of these uncertainties, it is import ant to look at the SR scores from the three replications individually, rather than averaging them together.

Top

- Loading Results Figure 5.6

. 18 shows the Sand Removal Score for each top

- loading CCW included in the test sample as a fun ction of each washer’s appendix J2 MEF J2 efficiency level. Figure 5.6

. 19 shows the Sand Removal Score for each top

- loading CCW as a function of each washer’s appendix J2 IWF efficiency level. As shown in both figures, current baseline clothes washers achieve a minimum sand removal score of 2%; Level 1 washers achieve a minimum score of around 4%, and Level 2 washers achieve a minimum score of 6%. The upper bound of the range is around 16% at all efficiency levels. The a mended standard level established by this final rule corresponds to Efficiency Level 1.

Figure 5.6

. 18 Sand Removal Score vs. Appendix J2 MEF J2 Efficiency Level for Top

Loading CCWs5-31

Figure 5.6

. 19 Sand Removal Score vs. Appendix J2 IWF Efficiency Level for Top

- Loading CCWs

Figure 5. 6

. 20 shows the Sand Removal Score for each front

- loading CCW included in the test sample as a function of each washer’s appendix J2 MEF J2 efficiency level. Figure 5.6

. 21 shows the Sand Removal Sco re for each front

- loading CCW as a functi on of each washer’s appendix J2 IWF efficiency level. As shown in both figures, current Level 1 clothes washers achieve sand removal score s ranging from 7

- 17%; Level 2 washers achieve score s ranging from 5

- 10%; and Level 3 washers achieve scores ranging f rom 12

- 14%. The amended standard level established by this final rule corresponds t o Efficiency Level 2

.5-32

Figure 5. 6

. 20 Sand Removal Score vs. Appendix J2 MEF J2 Efficiency Level for Front

Loading CCWs

Figure 5.6

. 21 Sand Removal Score vs. Appendix J2 IWF Efficiency Level for Front

Loading CCWs5-33

5.6.3 Product Teardown s As part of its reverse

- engineering process, DOE conducted teardowns of commercial clothes was hers to identify design features and corresponding manufacturing costs that are associated with successively higher efficiency levels. The clothes washer teardown analysis perform ed for this analysis included five top

- loading and five front

- loading models. Details of the teardown results are as follows.

5.6.3.1 Top

- Loading Commercial Clothes Washers

Top

- Loading Baseline Construction (1.15 MEF J2 / 8.9 IWF) The baseline top

- loading CCW is equipped with electro nic controls that allow the user to select specific cycle settings , including wash /rinse temperature and load size. Temperature is controlled using a thermal cutout on the water inlet assembly, which consists of two solenoid valves. The load size selector switch determines the fill level for a wash c ycle, w hich is controlled by a pressure switch. Between 2

- 4 load size selections may be available on baseline unit s

.

The motor is typically a 1⁄2

- horsepower permanent split capacito r (PSC) motor which drives the drum and the agitator . On some baseline models, thi s motor also drives the drain pump by reversing direction

, while other manufacturers opt to include a dedicated drain pump instead. The baseline wash basket consists of either a n enameled steel or stainless steel cylinder with a circular plate attached to the bottom to form a drum. From the center of the bottom plate a smaller cylinder rises to guide the drive shaft into the agitator and to center the wash basket inside the tub

. Snapped onto the top rim of the drum is a plastic balance ring, which is partially filled with a saline solution. Covering the balance ring is a p lastic cover

, often referred to as the tub cover

. The outer wrapper of the baseline unit consists of stamped metal panels which may be made of pre

- painted steel or coated post

- fabri cation with powder

- coat paint

. Th e top panel houses the lid , which is a smaller stamped piece of sheet metal on hinges. One of these hinges triggers a limit switch that cuts power to the motor when the lid is opened

. The top panel and lid are typically ena meled to provide greater scratch resistance

. Based upon product teardowns, DOE developed the following baseline production and materials cost distributions for a typical top

- loading CCW

. Table 5.6

. 4 and Figure 5.6

. 22 show the baseline production cost distributions; and Table 5.6

. 5 and Figure 5.6

. 23 show the baseline materials cost distribution. Depending on the manufacturer and the production volume, the depreciation c osts may vary from those shown in the figures, which assume a “green

- field” site.5-34

Table 5.6

. 4 Production Cost Distribution for Baseline Top

- Loading CCW

Cost Category Total Cost ($201 3 )

Figure 5.6

. 22 Production Cost Distribution for Baseline Top

- Load ing CCW Raw Materials $75.39

Purchased Parts $164.29 Assy Labor Cost $18.49

Fab Labor Cost $28.16

Indirect Labor Cost $2.43 Supervision Cost $16.20 Tooling Dep. Cost $60.55

Indirect Process Costs $26.34 Equipment Dep. Cost $51.05 Building Dep. Cost $21.60

Maintenance $53.48 Utility Cost $5.49 Property Tax $4.71

Insurance $4.23

Total $53 2.4 0

Table 5.6

. 5 Materials Cost Distribution for Baseline Top

- Load ing CCW

Sub

- Assembly Total Materials Cost ($201 3 )

Figure 5.6

. 23 Baseline Top

- Load Standard Clothes

Washer Materials Cost Distribution Motor/Pump/Capacitor $62.22 Control Assy $38.65

Gear Box/Transm ission $30.54

Tub/Drum $29.40 Outer Wrapper $25.42 Suspension $15.93 Door Assy $10.65

Main Wiring Harness $10.09 Packaging $9.87 Water Temp. Mgmt. $3.98 Final Assy $2.93

Total $239.685-35

Construction at Higher Efficiency Levels Based on the design options retained from the screening analysis (see chapter 4 of this TSD), the reverse

- engineering analyses, and discussions with manufacturers, DOE developed manufacturing costs associated with various design features necessary to achieve higher efficiencies. The following are the design changes DOE believes would be necessary to me et each higher efficiency level, which were subsequently modeled to obtain incremental manufacturing cost estimates.

Top

- Loading Efficiency Level 1 (1.35 MEF J2 / 3.8 IWF) Based on characteristics of units selected for teardown and based on discussions wit h manufacturers, DOE research suggests that Efficiency Level (EL) 1 is typically achieved in top

loading commercial clothes washers through the following changes:

1. Automatic Water Fill Control Through its observations and discussions with manufacturers, D OE believes that in moving from the baseline level to EL 1, manufacturers would likely replace manual water fill controls, in which the end

- user selects the fill level, with automatic water fill controls, in which the machine automatically selects the wate r fill level. The test procedure assumes a different set of Load Usage Factors (LUF) for manual and automatic water fill machines. For manual water fill machines, the LUF for the maximum load size is 72% (with the minimum load size TUF as 28%), whereas for automatic water fill machines, the maximum load size LUF is 12% (with the average load size TUF as 74%, and minimum load size TUF as 14%).

2. Reduced Hot Water Temperatures DOE believes that in addition to using automatic water fill controls, manufacturers may slightly reduce the temperature of the hot and warm water settings compared to the baseline unit.

Top

- Loading Efficiency Level 2 (1.55 MEF J2 / 6.9 IWF) DOE research suggests that manufacturers would likely significantly change the design platform of a top

- loading commercial clothes washer to reach EL 2. A CCW at EL 2 is likely to employ the same features as one at EL 1

, and would incorporate the following additional features:

1. Improved Fill Level Control Manufacturers would likely improve the automatic fill control at EL2, which would include more accurate water level sensors and a more sophisticated control scheme for determining optimal wash water levels. The impro ved pressure sensor and control logic would allow the clothes washer to more accurately d etermine the load size based on the measured volume of water introduced to the clothes container and the transient water pressure measured at the bottom of the tub, wh ich is affected by the load size. These controls would reduce excess water consumption by filling the wash basket with the minimum volume of water needed to soak the load.5-36

2. Improved Water Flow Control At EL 2, manufacturers would likely use a combination of electronically controlled thermistors and solenoid valves to achieve more precise water flow control. The thermistors sense the internal water temperatures, and the control system actively adjusts the solenoid valves to maintain the desired internal was h temperature.

3. Spray Rinse Manufacturers would likely employ a spray rinse at EL 2. Spray rinse significantly decreases the volume of water used during the rinse cycle. The clothes washers at the baseline level and EL 1 typically use a deep rinse, during which the tub is filled with water to a level in which the clothes are submerged, agitated, and then drained to remove soap suds. A spray rinse uses high

- pressure jets of water to rinse the load while the basket is spinning, without requiring the clothes to be immersed.

4. Increased Capacity At EL2, m anufacturers would likely increase capacity slightly by around 0.2 cubic feet above the capacity of the baseline and EL1 units

.

5. Low

- Profile Agitator Design DOE believes manufacturers would likely move to a low

- profile agitator design at EL 2

. The low

- profile agitator design consists of a rotating flat plate at the bottom of the wash basket, compared to the standard agitator, which is a finned cylinder that rises axially into the wash basket. The low

- profile agitator is designed to manually agitate the clothing using less water than a tradit ional agitator in a washer with deep water fills

.

6. Improved motor efficiency At EL2, manufacturers are likely to use a more efficient motor and transmission system that red uces the machine electrical energy consumption by almost 50%.

5.6.3.2 Front

- Loading Commercial Clothes Washer s

Front

- Loading Baseline Construction (1.65 MEF J2 / 5.5 IWF) DOE is unaware of any front

- loading commercial clothes washers currently available on the market that are at or above the baseline efficiency level but do not meet EL 1 . For this
reason, DOE established the baseline construction for a front

- loading clothes washer at EL 1

.

Front

- Loading Efficiency Level 1 Construction (1. 80 MEF J2 / 4 .5 IWF)
The EL1 front

- loading commercial c lothes washer is equipped with basic electronic controls that allow the user to select specific cycle sett ings , including wash cycle and wash/rinse temperature. Typically up to four wash t emperature selections are offered, and the temperature is controlled using two water inlet solenoid valves combined with a third solenoid to control the flow of the mixed water. From the inlet solenoid assembly, the water flows through a detergent5-37

di spenser tray before entering the wash basket. The water fill level for a wash cycle is automatically controlled using a pressure switch.

The internal tub/drum assembly of the baseline front

- load ing clothes washer is supported by three or four suspension legs attached to a sturdy metal base plate

. Two springs attached to the upper sides of the outer wrapper may also support the tub/drum assembly from above. The tub/drum assembly consists of an internal rotating basket and a stainless steel or plastic outer wash tub. The basket is made of a stainless steel cylinder with an attached front ring and back plate

. Attached to the back plate is a cast aluminum connector piece that secures the drive shaft. Molded into the back half of the tub is a ca st iron hub that houses two bearings, which guide the drive shaft. A variable speed motor powers the drive shaft using a drive belt and drive wheel. The motor is attached to the back base plate.

The outer wrapper of the baseline unit typically consists o f individual side, back, and top panels made of stamped cold

- rolled steel ( CRS) that are clinched together

. The front panel

, which is a smaller stamped piece of CRS , houses the door assembly . A large piece of tempered glass with a plastic frame and hand le make up the door assembly, which is attached to the front panel by a hinge. A door latch inside the front panel locks the door shut during the wash cycle. Attached to the front of the internal wash tub is a door seal gasket. This is a flexible ring that extends forward from the wash tub to create a water

- tight seal when the door is shut.

Based on product teardowns, DOE developed the following baseline pro duction and materials cost distributions for a typical front

- loading CCW. Table 5.6

. 6 and Figure 5.6

. 24 show the total cost distribution, and Table 5.6

. 7 and Figure 5.6

. 25 show the material s cost distribution

. Depending on the manufacturer and the production volume, the depreciation costs may vary from those shown in the figures, which assume a green

- field site.5-38

Table 5.6

. 6 Baseline Front

- Load Clothes Washer Production Cost Distribution

Cost Category Total Cost ($201 3 )

Figure 5.6

. 24 Production Cost Distribution for Efficiency Level 1 Front

- Loading Commercial Clothes Washer Purchased Parts $153.98

Raw Materials $287.88 Assy Labor Cost $29.01

Indirect Labor Cost $40.84

Fab Labor Cost $3.63 Supervision Cost $24.25 Tooling Dep. Cost $74.38

Indirect Process Costs $52.54 Equipment Dep. Cost $64.12 Building Dep. Cost $10.93 Utility Costs $78.97 Property Tax $9.51

Maintenance Costs $7.47

Insurance Costs $6.70

Total $8 44.23

Table 5.6

. 7 Baseline Front

- Load Clothes Washer Materials Cost Distribution

Sub

- Assembly Total Materials Cost ($201 3 )

Figure 5.6

. 25 Materials Cost Distribution for

Efficiency Level 1 Front

- Loading Commercial Clothes

Washer Tub/Drum $142.46 Control Assy $106.61 Motor/Pump/Capacitor $59.62 Outer Wrapper $53.51 Door Assy $19.76 Main Wiring Harness $16.45 Packaging $15.33

Water Temp Mgmt. $13.45 Suspension $10.87 Final Assy $3.81

Total $ 4 41

. 865-39

C onstruction at Higher Efficiency Levels Based on the design options retained from the screening analysis (see chapter 4 of this TSD), the reverse

- engineering analyses, and discussions with manufacturers, DOE developed manufacturing costs associated with various design features necessary to achieve higher efficiencies. The following are the design changes DOE believes would be necessary to meet each higher efficiency level, which were subsequently modeled to obtain incre mental manufacturing cost estimates.

Front

- Loading Efficiency Level 2 (2.00 MEF J2 / 4.1 IWF) Based on characteristics of units selected for teardown and based on discussions with manufacturers, DOE research suggests that EL2 is typically achieved in front

- loading commercial clothes washers through the following changes:

1. Reduced Hot Water Temperatures DOE believes that manufacturers may reduce the temperature of the hot and warm water settings compared to the EL1 unit.

2. Improved Fill Level Control DOE believes manufacturers would use reduced water fill levels compared to the EL2 unit. The reduction in water fill levels would be achieved through changes to the overall control strategy; no hardware changes would be implemented.

Front

- Loading Efficiency L evel 3 (2.20 MEF J2 / 3.9 IWF) DOE research suggests that manufacturers would likely significantly change the design platform of a front

- loading commercial clothes washer to reach EL 3 . A CCW at EL 3 is likely to employ the same features as one at EL 1

, an d would incorporate the following additional features:

1. Increased Capacity At EL2, manufacturers would likely increase capacity by around 0.6 cubic feet above the capacity of the EL1and EL2 units.

2. Direct Drive Motor Manufacturers would likely use a dire ct drive motor on their front

- loading clothes washers at EL 3. This would replace the standard variable

- speed motor, drive belt, and drive wheel used on the clothes washers at lower efficiency levels.

3. Increased Maximum Spin Speed Manufacturers would like ly increase the maximum spin speed for a front

- loading clothes washer at EL 3. DOE believes the spin speed would be roughly 100 RPM higher than the spin speed at EL 1 and EL 2.5-40

4. Modified Control Scheme DOE believes that some manufacturers would likely ad just control parameters to improve efficiency at EL 3. Through its active mode testing, DOE observed that longer spin cycles and lower wash temperature set

- points correspond to lower RMC values and less hot water consumption, respectively. Neither of these changes is associated with any physical design change to the clothes washer, but they may impact consumer utility

.

5.6.4 Cost

- Efficiency Curves
Based upon product teardowns and cost modeling, DOE developed the following cost

efficiency relationships for top

- loading and front

- loading commercial clothes washers.

5.6.4.1 Top

- Loading Cost

- Efficiency Curves
For top

- load ing commercial clothes washers , DOE developed incremental manufacturing costs by tearing down units , and creating a cost model at each efficiency leve l. DOE started with the baseline unit cost model , and at each higher efficiency level

, added in the observed changes associated with improving efficiency . By doing this, DOE excluded the costs of any non

efficiency related components from the more efficien t units. The more efficient units are generally sold at a higher price point, and sometimes incl ude more complex control panels, payment options, or other user interface features that are not necessarily efficiency

- related. Table 5.6

. 8 and Figure 5.6

. 26 show the incremental manufacturing costs from DOE’s rev erse

engineering analysis

.

Table 5.6

. 8 Incremental Manufacturing Costs for Top

- Loading CCWs Based on MEF J2

Appendix J2 Efficiency Level Incremental

Costs ($201 3 )

Figure 5.6

. 26 Cost

- Efficiency Curve Based on MEF J2 for

Top

- Loading Commercial Clothes Washer Baseline (1.15 MEF J2 / 8.9 IWF) -

EL 1 (1.35 MEF J2 / 8.8 IWF) $0.00

EL 2 (1.55 MEF J2 / 6.9 IWF) $3 9.635-41

Table 5.6

. 8 and Figure 5.6

. 26 show that the incremental cost to achieve EL1 is $0. This is consistent with information gained through product testing and through manufacturer interviews. As described above, the design options used to achieve EL1 are control

- based strategies that do not require any additional hardware costs.

The incremental cost to achieve EL2 is much more significant at $3 9.63 . As described above, a more significant design platform change is required to achieve EL2, resulting in additional hardware costs over the EL1 design.

DOE is confident in its estimates of the incremental costs for the units it torn down. However, DOE is aware that these values are only representative of the small number of units torn down, and do not necessarily characterize the en tire top

- loading commercial clothes washer market nor the expected typical costs at the time of the effective date of new standards

.

5.6.4.2 Front

- Loading Cost

- Efficiency Curves

For front

- loa ding commercial c lothes washers, DOE tore down units at all efficiency l evels

, except for the baseline level because DOE is unaware of any front

- loading CCWs available at that level.

DOE observed that manufacturers each have unique EL1 unit s depending on their segment of the market

. To account for this, DOE developed incremental cost curves for each

ma nufacturer according to their respective product offerings . For a manufacturer only producing front

- loading CCWs at higher efficiency levels, the incremental cost s associated with the efficiency levels below that manufact urer’s baseline is assumed to be zero. A single cost

efficiency curve was then calculated from a market share

- weighted average of the individual

curves. The DOE incremental costs shown in Table 5.6

. 9 and Figure 5.6

. 27 show the market share

- weighted average of the incremental cost curves

.5-42

Table 5.6

. 9 Incremental Manufacturing Costs for Front

- Loading CCWs Based on MEF J2 Appendix J2 Efficiency Level Incremental

Costs ($201 3 )

Figure 5.6

. 27 Cost

- Efficiency Curve Based on MEF J2 for

Front

- Loading Commercial Clothes Washer Baseline (1.6 5 MEF J2 / 5.2 IWF) -

EL 1 (1. 80 MEF J2 / 4.5 IWF) -

EL 2 ( 2.00 MEF J2 / 4.1 IWF) $0. 63

EL 3 ( 2.20 MEF J2 / 3.9 IWF) $19. 61

Table 5.6

. 9 and Figure 5.6

. 27 show that the incremental cost to achieve EL1 is $0, and the cost to achieve EL2 is relatively small at $0. 63 . This is consistent with information gained through product testing and through manufacturer interviews. As described above, the design options used to achieve EL1 and EL2 are largely control

- based strategies that do not require any additional hardware costs.

The incremental cost to achieve EL3 is more significant at $19. 61 . As described above, a more significant design platform change is required to achieve EL 3, resulting in additional hardware costs over the EL2 design.

DOE is confident in its estimates of the incremental costs for the units it torn down. However, DOE is aware that these values are only representative of the small number of units torn down, and do not necessarily characterize the entire front

- loading commercial clothes washer market nor the expected typical costs at the time of the effective date of new standards.