CHAPTER 4. SCREENING ANALYSIS 

TABLE OF CONTENTS 

4.1 INTRODUCTION ........................................................................................................... 4-1
 

4.2 DISCUSSION OF TECHNOLOGY OPTIONS.............................................................. 4-1
 

4.2.1 Screened-Out Technology Options.................................................................................. 4-2
 

4.2.2 Remaining Design Options.............................................................................................. 4-4
 

LIST OF TABLES 

Table 4.2.1 Retained Design Options for Commercial Clothes Washers............................... 4-4
 

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EERE-2006-STD-0127 COMMENT 66.2
CHAPTER 4. SCREENING ANALYSIS 

4.1 INTRODUCTION 

This chapter discusses the screening analysis conducted by the U.S. Department of 

Energy (DOE) of the technology options identified in the market and technology assessment for 

commercial clothes washers (CCWs) (chapter 3 of the supplemental notice of proposed 

rulemaking (SNOPR) technical support document (TSD)). In the market and technology 

assessment, DOE presented an initial list of technology options, that can be used to reduce 

energy consumption of CCWs. The goal of the screening analysis is to identify any technologies 

that will be eliminated from further consideration in the rulemaking analyses. As described in 

section 1.3 of chapter 1 of this TSD, DOE is continuing the rulemaking for energy conservation 

standards for microwave oven standby power, and analyses related to these products will be 

published in a separate TSD. In addition, DOE issued a final rule adopting energy conservation 

standards for conventional cooking products (i.e., cooktops and ovens) and microwave oven 

energy factor (EF), and details of the analyses for these products are contained in the 

corresponding final rule TSD. 

The candidate technology options are assessed based on DOE analysis as well as inputs 

from stakeholders including manufacturers, trade organizations, and energy efficiency advocates. 

Technology options that are judged to be viable approaches for improving energy efficiency are 

retained as inputs to the subsequent engineering analysis, and are designated as design options. 

Technology options that are not incorporated in commercial equipment or in working prototypes, 

or that fail to meet certain criteria as to practicability to manufacture, install and service, as to 

impacts on equipment utility or availability, or as to health or safety will be eliminated from 

consideration in accordance with Energy Conservation Program for Consumer Products: 

Procedures for Consideration of New or Revised Energy Conservation Standards for Consumer 

Products. 61 FR 36974 (July 15, 1996). The rationale for either screening out or retaining each 

technology option is detailed in the following sections. 

4.2 DISCUSSION OF TECHNOLOGY OPTIONS 

For CCWs, the screening criteria specified in section 4.1 were applied to the technology 

options to either retain or eliminate each technology from the engineering analysis. DOE derived 

these by reviewing the technology options for residential clothes washers listed in chapter 3 of 

the 1997 Technical Support Document for Clothes Washers (1997 TSD). DOE believes that 

these technology options would likely apply to the current CCW rulemaking because the Energy 

Policy Act of 2005 (EPACT 2005) (Pub. L. 109-58) amended the Energy Policy and 

Conservation Act (EPCA or the Act) of 1975 (42 U.S.C. 6291 et seq.) to require that CCWs be 

rated with the same test procedure established for residential clothes washers. (42 U.S.C. 

6314(a)(8)) 

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EERE-2006-STD-0127 COMMENT 66.2
4.2.1 Screened-Out Technology Options 

The following section details the specific technology options that were screened out prior 

to the engineering analysis, along with the rationale for elimination. 

The technologies identified in the market and technology assessment were evaluated 

pursuant to the criteria set out in EPCA. (42 U.S.C. 6311-6317) EPCA provides criteria for 

prescribing new or amended standards, which will achieve the maximum improvement in energy 

efficiency the Secretary of Energy determines is technologically feasible. (42 U.S.C. 

6313(a)(6)(A)) It also establishes guidelines for determining whether a standard is economically 

justified. (42 U.S.C. 6313(a)(6)(B)) In view of the EPCA requirements for determining whether 

a standard is technologically feasible and economically justified, appendix A to subpart C of 

Title 10 Code of Federal Regulations part 430 (10 CFR part 430), Procedures, Interpretations 

and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer 

Products (the Process Rule), sets forth procedures to guide DOE in the consideration and 

promulgation of new or revised product energy conservation standards under EPCA. These 

procedures elaborate on the statutory criteria provided in 42 U.S.C. 6313 and in part eliminate 

problematic technologies early in the process of revising an energy conservation standard. Under 

the guidelines, before publishing an ANOPR, DOE eliminates from consideration technologies 

that present unacceptable problems with respect to the following four factors: 

(1) Technological feasibility. If it is determined that a technology has not been 

incorporated in commercial equipment or in working prototypes, then that technology will not be 

considered further. 

(2) Practicability to manufacture, install, and service. If it is determined that mass 

production of a technology in commercial equipment and reliable installation and servicing of 

the technology could not be achieved on the scale necessary to serve the relevant market at the 

time of the effective date of the standard, then that technology will not be considered further. 

(3) Impacts on equipment utility to consumers. If a technology is determined to have 

significant adverse impact on the utility of the equipment to significant subgroups of consumers, 

or results in the unavailability of any covered equipment type with performance characteristics 

(including reliability), features, size, capacities, and volumes that are substantially the same as 

equipment generally available in the United States at the time, it will not be considered further. 

(4) Safety of technologies. If it is determined that a technology will have significant 

adverse impacts on health or safety, it will not be considered further. 

Based on these factors, DOE screened out bubble action, electric disassociation of water, 

ozonated laundering, reduced thermal mass, suds saving, and ultrasonic washing for the reasons 

that follow. 

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EERE-2006-STD-0127 COMMENT 66.2
Bubble action 

Although bubble washing has been incorporated into commercial equipment, production 

is extremely limited and further commercialization would require manufacturers to develop 

entirely new platforms. Therefore, DOE does not believe that this technology would be 

practicable to manufacture, install, and service on the scale necessary to serve the relevant 

market at the time of the effective date of an amended standard. 

Electric disassociation of water 

Electric disassociation of water is in the research stage, so DOE believes that it would not 

be practicable to manufacture, install and service this technology on the scale necessary to serve 

the relevant market at the time of the effective date of an amended standard. Also, because this 

technology is in the research stage, it is not possible to assess whether it will have any adverse 

impacts on equipment utility to consumers or equipment availability, or any adverse impacts on 

consumers' health or safety. 

Ozonated laundering 

Ozonated laundering is in the research stage, so DOE believes that it would not be 

practicable to manufacture, install and service this technology on the scale necessary to serve the 

relevant market at the time of the effective date of an amended standard. Also, because this 

technology is in the research stage, it is not possible to assess whether it will have any adverse 

impacts on equipment utility to consumers or equipment availability, or any adverse impacts on 

consumers' health or safety. 

Reduced thermal mass 

Reduced thermal mass has not been incorporated into commercial equipment, so DOE 

believes that it would not be practicable to manufacture, install and service this technology on 

the scale necessary to serve the relevant market at the time of the effective date of an amended 

standard. Also, because this technology has not been incorporated into clothes washers, it is not 

possible to assess whether it will have any adverse impacts on equipment utility to consumers or 

equipment availability, or any adverse impacts on consumers' health or safety. 

Suds saving 

Suds-saving residential clothes washers were previously commercially available, but 

required an adjacent wash tub to store suds in between wash cycles. Due to these installation 

requirements, DOE believes that suds-saving clothes washers would be impractical to install in 

many locations. Suds-saving clothes washers reduce consumer utility by requiring consumers to 

occupy space adjacent to the washer with an additional washtub. In a commercial setting, this 

may limit the number of clothes washers that may be installed. In order to fully capture the 

energy saving benefits of suds saving, consumers must wash multiple loads of laundry 

sequentially. Delays between washing cycles allow the saved water to cool, reducing wash 

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performance and energy savings. Finally, suds-saving washers can carry over heavy soiling 

between clothing loads, reducing wash performance as well. Therefore, DOE will not consider 

suds saving as a technology option for improving the energy efficiency of commercial clothes 

washers. 

Ultrasonic washing 

Ultrasonic washing has been demonstrated in clothes washers, but the ultrasonic clothes 

washer did not adequately remove soil from the clothes. Ultrasonic clothes washing would 

therefore reduce consumer utility by not adequately washing clothes. In addition, bubble 

cavitations caused by standing ultrasonic waves could potentially damage some fragile clothing 

or clothing fasteners, further reducing consumer utility. Since no manufacturers currently 

produce ultrasonic clothes washers, it is impossible to assess whether it will have any impacts on 

consumer’s health or safety, or equipment availability. 

4.2.2 Remaining Design Options 

Table 4.2.1 lists the technology options for CCWs that were retained by DOE and 

subsequently designated as design options. Each of these technologies will be evaluated further 

in the subsequent engineering analysis. 

Table 4.2.1 Retained Design Options for Commercial Clothes Washers 

1. Adaptive control systems 

2. Added insulation 

3. Advanced agitation concepts for top-loading machines 

4. Automatic water fill control 

5. Direct-drive motor 

6. Front-loading design with recirculation 

7. Improved fill control 

8. Improved front-loading-washer drum design 

9. Improved water extraction to lower remaining moisture content 

10. Increased motor efficiency 

11. Low-standby-power electronic controls 

12. Spray rinse or similar water-reducing rinse technology 

13. Steam washing 

14. Thermostatically controlled mixing valves 

15. Tighter tub tolerance 

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