[Federal Register Volume 76, Number 4 (Thursday, January 6, 2011)]
[Rules and Regulations]
[Pages 972-1036]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2010-32118]
[[Page 971]]
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Part III
Department of Energy
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10 CFR Part 430
Energy Conservation Program for Consumer Products: Test Procedures for
Clothes Dryers and Room Air Conditioners; Final Rule
Federal Register / Vol. 76 , No. 4 / Thursday, January 6, 2011 /
Rules and Regulations
[[Page 972]]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket No. EERE-2008-BT-TP-0010]
RIN 1904-AC02
Energy Conservation Program for Consumer Products: Test
Procedures for Clothes Dryers and Room Air Conditioners
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Final rule.
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SUMMARY: The U.S. Department of Energy (DOE) amends its test procedures
for residential clothes dryers and room air conditioners under the
Energy Policy and Conservation Act (EPCA). The amendments provide for
measurement of standby mode and off mode power use by these products
and also amend the active mode test procedures for these products. For
standby and off mode energy use, these amendments incorporate into the
DOE test procedures relevant provisions from the International
Electrotechnical Commission (IEC) Standard 62301, ``Household
electrical appliances--Measurement of standby power,'' (first edition
June 2005), including language to clarify application of these
provisions for measuring standby mode and off mode power consumption in
clothes dryers and room air conditioners. In addition, DOE is adopting
definitions of modes based on the relevant provisions from IEC Standard
62301 Second Edition Committee Draft for Vote. For active mode energy
use, DOE adopts testing methods for ventless clothes dryers, test cloth
preconditioning requirements for clothes dryer energy tests, test
conditions for gas clothes dryers, test conditions for clothes dryer
drum capacity measurement, amendments to clarify current clothes dryer
usage patterns and capabilities and to update the references to
industry standards in the room air conditioner and clothes dryer test
procedures.
DATES: This rule is effective February 7, 2011. The incorporation by
reference of certain publications listed in the rule is approved by the
Director of the Federal Register on February 7, 2011.
ADDRESSES: You may review copies of all materials related to this
rulemaking at the U.S. Department of Energy, Resource Room of the
Building Technologies Program, 950 L'Enfant Plaza, SW., Suite 600,
Washington, DC, (202) 586-2945, between 9 a.m. and 4 p.m., Monday
through Friday, except Federal holidays. Please call Ms. Brenda Edwards
at the above telephone number for additional information regarding
visiting the Resource Room.
FOR FURTHER INFORMATION CONTACT: Mr. Subid Wagley, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington,
DC 20585-0121. Telephone: (202) 287-1414. E-mail:
[email protected].
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of the
General Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC
20585-0121. Telephone: (202) 586-7796. E-mail:
[email protected].
SUPPLEMENTARY INFORMATION: This final rule incorporates by reference
into part 430 the following industry standards:
(1) AHAM HLD-1-2009 (``AHAM HLD-1''), ``Household Tumble Type
Clothes Dryers,'' (2009).
Copies of AHAM HLD-1 are available from the Association of Home
Appliance Manufacturers, 1111 19th Street, NW., Suite 402, Washington,
DC 20036, (202) 872-5955, or http://www.aham.org/.
(2) ANSI/AHAM RAC-1-2008 (``ANSI/AHAM RAC-1''), ``Room Air
Conditioners,'' (2008; ANSI approved July 7, 2008).
Copies of ANSI/AHAM RAC-1 are available from the American National
Standards Institute, 11 West 42nd Street, New York, New York 10036,
(212) 642-4936, or http://webstore.ansi.org/.
(3) ANSI/ASHRAE Standard 16-1983 (``ANSI/ASHRAE 16'') (RA 2009),
(Reaffirmation of ANSI/ASHRAE Standard 16-1983 [RA 1999]), ``Method of
Testing for Rating Room Air Conditioners and Packaged Terminal Air
Conditioners,'' ASHRAE approved October 18, 1988, and reaffirmed June
20, 2009; ANSI approved October 20, 1998 and reaffirmed June 25, 2009.
Copies of ANSI/ASHRAE 16 are available from the American National
Standards Institute, 11 West 42nd Street, New York, New York 10036,
(212) 642-4936, or http://webstore.ansi.org/.
(4) International Electrotechnical Commission (IEC) Standard 62301
(``IEC 62301''), ``Household electrical appliances--Measurement of
standby power (first edition June 2005).''
Copies of IEC 62301 are available from the American National
Standards Institute, 11 West 42nd Street, New York, New York 10036,
(212) 642-4936, or http://webstore.iec.ch/.
Table of Contents
I. Background and Authority
II. Summary of the Proposal
III. Discussion
A. Products Covered by the Test Procedure Changes
B. Clothes Dryer and Room Air Conditioner Standby Mode and Off
Mode Test Procedures
1. Incorporating by Reference IEC Standard 62301 for Measuring
Standby Mode and Off Mode Power in Clothes Dryers and Room Air
Conditioners
2. Determination of Modes To Be Incorporated
3. Adding Specifications for the Test Methods and Measurements
for Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode
Testing
a. Clothes Dryers
b. Room Air Conditioners
4. Calculation of Energy Use Associated With Standby Modes and
Off Mode
a. Clothes Dryers
b. Room Air Conditioners
5. Measures of Energy Consumption
a. Clothes Dryers
b. Room Air Conditioners
C. Clothes Dryer and Room Air Conditioner Active Mode Test
Procedures
1. Correction of Text Describing Energy Factor Calculation for
Clothes Dryers
2. Automatic Cycle Termination for Clothes Dryers
3. Test Procedure for Ventless Clothes Dryers
4. Detergent Specifications for Clothes Dryer Test Cloth
Preconditioning
5. Changes To Reflect Current Usage Patterns and Capabilities
a. Clothes Dryer Number of Annual Cycles
b. Clothes Dryer Initial Remaining Moisture Content
c. Clothes Dryer Test Load Weight
d. Room Air Conditioner Annual Operating Hours
e. Room Air Conditioner Part-Load Performance
f. Room Air Conditioner Ambient Test Conditions
6. Room Air Conditioner Referenced Test Procedures
7. Clothes Dryer Referenced Test Procedure
8. Technical Correction for the Per-Cycle Gas Dryer Continuously
Burning Pilot Light Gas Energy Consumption
9. Clarification of the Gas Supply Test Conditions for Gas
Clothes Dryers
10. Other Clothes Dryer Test Procedure Issues
a. Test Cloth Specifications
b. Relative Humidity Measurement Specifications
c. Calculations of EF and CEF
d. Measurement of Kilowatt Electricity Demand
e. Clarifications to the Measurement of Drum Capacity
f. Test Procedure Language
D. Compliance With Other EPCA Requirements
1. Test Burden
2. Integration of Standby Mode and Off Mode Energy Consumption
Into the Energy Efficiency Metrics
IV. Effects of Test Procedure Revisions on Compliance With Standards
A. Standby Mode and Off Mode
[[Page 973]]
B. Active Mode--Clothes Dryers
C. Active Mode--Room Air Conditioners
V. Procedural Requirements
A. Review Under Executive Order 12866
B. Review Under the Regulatory Flexibility Act
C. Review Under the Paperwork Reduction Act of 1995
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under Section 32 of the Federal Energy Administration
Act of 1974
M. Congressional Notification
VI. Approval of the Office of the Secretary
I. Background and Authority
Title III of the Energy Policy and Conservation Act of 1975 (42
U.S.C. 6291, et seq.; ``EPCA'' or, in context, ``the Act'') sets forth
a variety of provisions designed to improve energy efficiency. Part B
of Title III, Public Law 94-163 (42 U.S.C. 6291-6309, as codified)
establishes the ``Energy Conservation Program for Consumer Products
Other Than Automobiles,'' a program covering most major household
appliances including clothes dryers and room air conditioners (all of
which are referred to below as ``covered products'').\1\ (42 U.S.C.
6291(1)-(2) and 6292(a)(2) and (8))
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\1\ All references to EPCA refer to the statute as amended
including through the Energy Independence and Security Act of 2007,
Public Law 110-140. For editorial reasons, upon codification in the
U.S. Code, Part B was re-designated Part A.
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Under the Act, this program consists essentially of four parts: (1)
Testing; (2) labeling; (3) the establishment of Federal energy
conservation standards; and (4) certification and enforcement
procedures. The Federal Trade Commission (FTC) is responsible for
labeling, and DOE implements the remainder of the program. The testing
requirements consist of test procedures that, pursuant to EPCA,
manufacturers of covered products must use as the basis for certifying
to DOE that their products comply with applicable energy conservation
standards adopted under EPCA and for representations about the
efficiency of those products. Similarly, DOE must use these test
requirements to determine whether the products comply with EPCA
standards. Under 42 U.S.C. 6293, EPCA sets forth criteria and
procedures for DOE's adoption and amendment of such test procedures.
EPCA provides that any test procedures prescribed or amended under this
section shall be reasonably designed to produce test results which
measure energy efficiency, energy use or estimated annual operating
cost of a covered product during a representative average use cycle or
period of use and shall not be unduly burdensome to conduct. (42 U.S.C.
6293(b)(3))
In any rulemaking to amend a test procedure, DOE must also
determine to what extent, if any, the proposed test procedure would
alter the measured energy efficiency of any covered product as
determined under the existing test procedure. (42 U.S.C. 6293(e)(1)) If
DOE determines that the amended test procedure would alter the measured
efficiency of a covered product, DOE must amend the applicable energy
conservation standard accordingly. In determining the amended energy
conservation standard, the Secretary shall measure, pursuant to the
amended test procedure, the energy efficiency, energy use, or water use
of a representative sample of covered products that minimally comply
with the existing standard. The average of such energy efficiency,
energy use, or water use levels determined under the amended test
procedure shall constitute the amended energy conservation standard for
the applicable covered products. (42 U.S.C. 6293(e)(2)) EPCA also
states that models of covered products in use before the date on which
the amended energy conservation standard becomes effective (or
revisions of such models that come into use after such date and have
the same energy efficiency, energy use, or water use characteristics)
that comply with the energy conservation standard applicable to such
covered products on the day before such date shall be deemed to comply
with the amended energy conservation standard. (42 U.S.C. 6293(e)(3))
EPCA also states that the Secretary's authority to amend energy
conservation standards under 42 U.S.C. 6293(e) shall not affect the
Secretary's obligation to issue final rules as described in 42 U.S.C.
6295. (42 U.S.C. 6293(e)(4))
DOE's test procedures for clothes dryers are found at 10 CFR part
430, subpart B, appendix D. DOE established its test procedure for
clothes dryers in a final rule published in the Federal Register on
September 14, 1977 (the September 1977 TP Final Rule). 42 FR 46145. On
May 19, 1981 DOE published a final rule (the May 1981 TP Final Rule) to
amend the test procedure by establishing a field-use factor for clothes
dryers with automatic termination controls, clarifying the test cloth
specifications and clothes dryer preconditioning, and making editorial
and minor technical changes. 46 FR 27324. The existing clothes dryer
test procedure incorporates by reference two industry test standards:
(1) The Association of Home Appliance Manufacturers (AHAM) Standard
HLD-1-1974, ``AHAM Performance Evaluation Procedure for Household
Tumble Type Clothes Dryers'' (AHAM Standard HLD-1-1974); and (2) AHAM
Standard HLD-2EC, ``Test Method for Measuring Energy Consumption of
Household Tumble Type Clothes Dryers'' December 1975 (AHAM Standard
HLD-2EC). The test procedure includes provisions for determining the
energy factor (EF) for clothes dryers, which is a measure of the total
energy required to dry a standard test load of laundry to a ``bone
dry'' \2\ state.
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\2\ ``Bone dry'' is defined in the DOE clothes dryer test
procedure as ``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 the load is 1
percent or less.'' (10 CFR subpart B, appendix D, section 1.2)
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DOE's test procedures for room air conditioners are found at 10 CFR
part 430, subpart B, appendix F. DOE established its room air
conditioner test procedure on June 1, 1977, and redesignated and
amended it on June 29, 1979. 42 FR 27898; 44 FR 37938. The existing
room air conditioner test procedure incorporates by reference two
industry test standards: (1) American National Standard (ANS) (since
renamed American National Standards Institute (ANSI)) Z234.1-1972,
``Room Air Conditioners;'' \3\ and (2) American Society of Heating,
Refrigerating, and Air-Conditioning Engineers (ASHRAE) Standard 16-69,
``Method of Testing for Rating Room Air Conditioners.'' \4\ The DOE
test procedure includes provisions for determining the energy
efficiency ratio (EER) of room air conditioners, which is the ratio of
the cooling capacity in British thermal units (Btu) to the power input
in watts (W).
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\3\ ANSI standards are available at http://www.ansi.org.
\4\ ASHRAE standards are available at http://www.ashrae.org.
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As currently drafted, the test procedures for the products at issue
in this rulemaking do not account for standby mode and off mode energy
consumption, except in one narrow product class. Specifically, for gas
clothes dryers with constant burning pilot lights, DOE's current test
procedure for clothes dryers addresses the standby energy use of such
pilot lights. EPCA, however, states that gas clothes dryers shall not
be equipped with a constant burning pilot for
[[Page 974]]
products manufactured on or after January 1, 1988. (42 U.S.C.
6295(g)(3)) As discussed in section III.C.8, DOE amends the clothes
dryer test procedure in today's final rule to remove any provisions for
measuring constant burning pilot lights.
EPCA directs DOE to amend its test procedures to include measures
of standby mode and off mode energy consumption. EPCA further directs
DOE to amend the test procedures to integrate such energy consumption
into a single energy descriptor for that product. If that is
technically infeasible, DOE must prescribe a separate standby mode and
off mode energy-use test procedure, if technically feasible. (42 U.S.C.
6295(gg)(2)(A)) Any such amendment must consider the most current
versions of the International Electrotechnical Commission (IEC)
Standard 62301 [``Household electrical appliances--measurement of
standby power,'' First Edition 2005-06 (IEC Standard 62301)]
5 6 and IEC Standard 62087 [``Methods of measurement for the
power consumption of audio, video, and related equipment,'' Second
Edition 2008-09]. Id.
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\5\ IEC standards are available at: http://www.iec.ch.
\6\ Multiple editions of this standard are referenced in this
final rule. Unless otherwise indicated, the terms ``IEC Standard
62301'' or ``IEC Standard 62301 First Edition'' refer to ``Household
electrical appliances--measurement of standby power,'' First Edition
2005-06.
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EPCA also provides that amendments to the test procedures to
include standby mode and off mode energy consumption will not determine
compliance with previously established standards. (U.S.C.
6295(gg)(2)(C)) The test procedure amendments regarding provisions for
standby mode and off mode in today's final rule shall become effective
30 days after the publication of the rule in the Federal Register. DOE
notes, however, that the procedures and calculations for standby mode
and off mode energy consumption need not be performed at this time to
determine compliance with the current energy conservation standards.
Manufacturers would be required to use the amended test procedures'
standby mode and off mode provisions starting on the compliance date of
any final rule establishing amended energy conservation standards for
clothes dryers and room air conditioners that address standby mode and
off mode energy consumption. In addition, starting 180 days after
publication of today's test procedure final rule, any representations
as to the standby mode and off mode energy consumption must be based
upon results generated under the applicable provisions of this test
procedure. (42 U.S.C. 6293(c)(2))
DOE published a notice of proposed rulemaking (NOPR) on December 9,
2008 (the December 2008 TP NOPR), in which it proposed a number of
revisions and additions to its test procedures for clothes dryers and
room air conditioners. These consisted largely of provisions to address
the new statutory requirement to expand test procedures to incorporate
a measure of standby mode and off mode energy consumption. 73 FR 74639.
DOE also proposed amendments to correct text describing the EF
calculation for clothes dryers and the text referencing room air
conditioner industry test standards. 73 FR 74650. The proposals in the
NOPR were addressed at a public meeting on December 17, 2008 (the
December 2008 Public Meeting). In addition, DOE invited written
comments, data, and information on the December 2008 TP NOPR through
February 23, 2009.
DOE received oral comments from interested parties at the December
2008 Public Meeting and subsequently received four written comments.
The principal test procedure issues on which interested parties
commented were: (1) Establishing multiple low power or standby modes
for both clothes dryers and room air conditioners; (2) the number of
annual hours associated with active, standby, and off modes for the
calculation of energy use; (3) considering an additional standby mode
(a ``network mode''); (4) clarifying the definitions of standby and off
mode; (5) harmonizing mode definitions and testing procedures with
international standards, in particular IEC Standard 62301 Second
Edition, Committee Draft 2 (IEC Standard 62301 CD2); and (6)
integrating of standby and off mode energy use and active mode energy
use into a single energy-use metric.
DOE determined after the December 2008 TP NOPR was published that
it would consider a revised version of IEC Standard 62301, i.e., IEC
Standard 62301 Second Edition, which at that time was expected to be
published in July 2009. DOE anticipated, based on review of drafts of
the updated IEC Standard 62301, that the revisions could include
different mode definitions. Subsequently, DOE received information that
IEC Standard 62301 Second Edition would not be published until late
2010. To allow for the consideration of standby and off mode power
consumption in the concurrent energy conservation standards rulemaking,
DOE published a SNOPR on June 29, 2010 (hereafter referred to as the
June 2010 TP SNOPR), proposing mode definitions based on the new mode
definitions from the most recent draft version of IEC Standard 62301
Second Edition which, at that time, was designated as IEC Standard
62301 Second Edition Committee Draft for Vote (IEC Standard 62301 CDV).
75 FR 37594. The IEC circulated IEC Standard 62301 CDV on August 28,
2009. IEC Standard 62301 CDV contained the most recent proposed
amendments to IEC Standard 62301, including new mode definitions, at
the time the June 2010 TP SNOPR was issued. IEC Standard 62301 CDV
revised the proposed mode definitions from previous draft versions of
IEC Standard 62301 and addressed comments received by interested
parties in response to those drafts. As a result, DOE stated in the
June 2010 TP SNOPR that the mode definitions in IEC Standard 62301 CDV
represent the best definitions available for the supporting analysis.
Id.
DOE also determined after publication of the December 2008 TP NOPR
to conduct a rulemaking to amend the active mode test procedure for
clothes dryers and room air conditioners. As part of this rulemaking,
DOE intended to address issues on which it requested comment in the
concurrent energy conservation standards rulemaking, discussed below.
In the June 2010 TP SNOPR, DOE proposed the following test procedure
amendments for the measurement of active mode energy consumption for
clothes dryers and room air conditioners: (1) Procedures for more
accurately measuring the effects of different automatic termination
technologies in clothes dryers; (2) provisions for ventless clothes
dryers, which are being considered under an amended energy conservation
standard; (3) updated detergent specifications for clothes dryer test
cloth preconditioning; (4) changes to better reflect current usage
patterns and capabilities for the covered products; (5) updated
references to external test procedures; and (6) clarifications to the
test conditions for gas clothes dryers. 75 FR 37594 (June 29, 2010).
The proposals in the SNOPR were addressed at a public meeting on
July 14, 2010 (July 2010 Public Meeting). In addition, DOE invited
written comments, data, and information on the June 2010 TP SNOPR
through August 30, 2010. DOE received oral comments from interested
parties at the July 2010 Public Meeting and subsequently received 13
written comments. The principal test procedure issues on which
interested parties commented were: (1) The consideration of the most
recent draft IEC Standard 62301 Second Edition, Final Draft
International
[[Page 975]]
Standard (IEC Standard 62301 FDIS); (2) the settings used for standby
and off mode testing; (3) the allocation of hours to different standby
and off modes; (4) the clothes dryer cycle settings selected for
automatic cycle termination testing methods; (5) the inclusion of the
cool-down period for clothes dryer automatic cycle termination tests;
(6) revisions to the water temperature for clothes dryer test load
preparation; (7) test conditions for ventless clothes dryers; (8) the
consideration of the effects of clothes dryers on HVAC energy use; (9)
the initial remaining moisture content (RMC) value for clothes dryers;
(10) the number of room air conditioner annual operating hours; and
(11) the consideration of fan-only active mode for room air
conditioners.
Test procedure amendments for the measurement of active mode energy
consumption for clothes dryers and room air conditioners will become
effective 30 days after the publication of today's final rule in the
Federal Register. In addition, DOE also notes that as of 180 days after
the publication of today's test procedure final rule, any
representations with respect to the energy use or efficiency or cost of
energy consumed of the products that are the subject of this rulemaking
must be based upon results generated under the applicable provisions of
these amended test procedures. (42 U.S.C. 6293(c)(2))
This test procedure rulemaking fulfills the 7-year review
requirement prescribed by EPCA. At least once every 7 years, the
Secretary shall review test procedures for all covered products and
amend test procedures with respect to any covered product or publish
notice in the Federal Register of any determination not to amend a test
procedure. (42 U.S.C. 6293(b)(1)(A))
DOE is also conducting a concurrent energy conservation standards
rulemaking for residential clothes dryers and room air conditioners.
For clothes dryers, EPCA establishes prescriptive standards for clothes
dryers, requiring that gas dryers manufactured on or after January 1,
1988 not be equipped with a constant burning pilot and further
requiring that DOE conduct two cycles of rulemakings to determine if
more stringent standards are justified. (42 U.S.C. 6295(g)(3) and (4))
On May 14, 1991, DOE published a final rule in the Federal Register
establishing the first set of performance standards for residential
clothes dryers (56 FR 22250); the new standards became effective on May
14, 1994. 10 CFR 430.32(h). DOE has initiated the second cycle of
clothes dryer standards rulemakings by publishing a notice of
availability of a framework document, discussed in more detail below.
72 FR 57254 (October 9, 2007).
For room air conditioners, EPCA establishes performance standards
that became effective on January 1, 1990, and directs DOE to conduct
two cycles of rulemakings to determine if more stringent standards are
justified. (42 U.S.C. 6295(c)(1) and (2)) On March 4, 1994, DOE
published a NOPR for several products, including room air conditioners.
59 FR 10464. On September 24, 1997, DOE published a final rule
establishing an updated set of performance standards, with an effective
date of October 1, 2000. 62 FR 50122; 10 CFR 40.32(b). DOE initiated
the second cycle of room air conditioner standards rulemakings
concurrent with the clothes dryer rulemaking. 72 FR 57254 (October 9,
2007).
As stated above, DOE initiated the second cycle of residential
clothes dryer and room air conditioner energy conservation standards
rulemakings by publishing a notice in the Federal Register announcing
the availability of a framework document to initiate a rulemaking to
consider amended energy conservation standards for residential clothes
dryers and room air conditioners on October 9, 2007 (hereafter the
October 2007 Framework Document). 72 FR 57254. In the October 2007
Framework Document, DOE identified specific ways in which it could
revise its test procedures for these two products and requested comment
from interested parties on whether it should adopt such revisions.
Specifically, DOE sought comment on potential amendments to the clothes
dryer test procedure to: (1) Reflect lower remaining moisture content
(RMC) \7\ in clothes loads; (2) account for fewer annual use cycles;
and (3) add the capability to test ventless clothes dryers. (Framework
Document, STD No. 1 at pp. 4-6) \8\ DOE received comments in response
to the October 2007 Framework Document that it should consider changes
to the clothes dryer test load size. For room air conditioners, DOE
requested input on potential amendments to the test procedure to: (1)
Incorporate the most recent ANSI and ASHRAE test standards; (2) reduce
the annual operating hours; and (3) measure part-load performance.
(Framework Document, STD No. 1 at pp. 6-7) DOE received comments in
response to the October 2007 Framework Document that it should consider
changes to the ambient test conditions for room air conditioners.
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\7\ RMC is the ratio of the weight of water contained by the
test load to the bone-dry weight of the test load, expressed as a
percent.
\8\ A notation in this form provides a reference for information
that is in the docket of DOE's rulemaking to develop energy
conservation standards for clothes dryers and room air conditioners
(Docket No. EERE-2007-BT-STD-0010), which is maintained in the
Resource Room of the Building Technologies Program. This notation
indicates that the statement preceding the reference was made in
DOE's Framework Document, which is document number 1 in the docket
for the clothes dryer and room air conditioner energy conservation
standards rulemaking, and appears at pages 4-6 of that document.
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EPCA directs DOE to incorporate standby and off mode energy use
into any final rule establishing or revising a standard for a covered
product adopted after July 1, 2010. (42 U.S.C. 6295(gg)(3)) DOE is
required by consent decree to publish a final rule setting forth any
revised efficiency standards for clothes dryers and room air
conditioners by June 30, 2011. As result, this final rule must
incorporate standby and off mode energy use.
II. Summary of the Proposal
In today's final rule, DOE amends its test procedures for clothes
dryers and room air conditioners to: (1) Use in the concurrent
development of energy conservation standards that address the energy
use of these products when in standby mode and off mode, as well as in
the implementation of any amended standards; (2) address the statutory
requirement to expand test procedures to incorporate measures of
standby mode and off mode power consumption; (3) adopt changes to the
water temperature for clothes dryer test load preparation; (4) expand
the clothes dryer test procedures to accommodate ventless clothes
dryers being considered for coverage under an amended energy
conservation standard; (5) adopt technical changes to better reflect
current usage patterns and capabilities for the covered products; (6)
update detergent specifications for clothes dryer test cloth
preconditioning; (7) update the references to external test procedures;
(8) clarify the test conditions for gas clothes dryers; and (9) clarify
the test conditions for clothes dryer drum capacity measurements. As
discussed in this section, DOE is not adopting the technical changes
and procedures to more accurately measure the effects of different
automatic cycle termination technologies in clothes dryers proposed in
the June 2010 TP SNOPR. The following paragraphs summarize the
amendments.
Standby and Off Mode
In today's final rule, DOE incorporates by reference into both the
clothes dryer and room air conditioner test procedures specific clauses
from IEC
[[Page 976]]
Standard 62301 regarding test conditions and test procedures for
measuring standby mode and off mode power consumption. DOE also
incorporates into each test procedure the definitions of ``active
mode,'' ``standby mode,'' and ``off mode'' based on the definitions
provided in IEC Standard 62301 CDV. Further, DOE adopts additional
language in each test procedure to clarify how clauses from IEC
Standard 62301 and the mode definitions from IEC Standard 62301 CDV are
to be applied when measuring standby mode and off mode power
consumption.\9\
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\9\ EISA 2007 directs DOE to also consider IEC Standard 62087
when amending its test procedure to include standby mode and off
mode energy consumption. See 42 U.S.C. 6295(gg)(2)(A). As explained
subsequently in this notice, because IEC Standard 62087 addresses
the methods of measuring the power consumption of audio, video, and
related equipment, it is inapplicable to the products at issue in
this rulemaking.
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For reasons discussed in section III.B.2 for clothes dryers, DOE
adopts a definition and testing procedures for a single standby mode,
rather than the multiple standby modes--``inactive'' mode, ``cycle
finished'' mode, and ``delay start'' mode--as proposed in the December
2008 TP NOPR. 73 FR 74639, 74645 (December 9, 2008). DOE also adopts
new methods to calculate clothes dryer standby mode and off mode energy
use, as well as a new measure of energy efficiency--Combined Energy
Factor (CEF)--that includes energy use in standby mode and off mode.
The standby mode and off mode amendments do not change the method to
calculate the existing clothes dryer energy efficiency metric for
active mode, the energy factor (EF).
Similarly, for reasons discussed in section III.B.2 for room air
conditioners, DOE adopts a definition and testing procedures for a
single standby mode, rather than the multiple standby modes--
``inactive'' mode, ``delay start'' mode, and ``off-cycle'' mode--as
proposed in the December 2008 TP NOPR. 73 FR 74639, 74645. DOE also
adopts new methods to calculate room air conditioner standby mode and
off mode energy use and a new measure of energy efficiency--Combined
Energy Efficiency Ratio (CEER)--that includes energy use in the standby
mode and the off mode. The standby mode and off mode amendments do not
change the method used to calculate the existing room air conditioner
energy efficiency metric for active mode, the energy efficiency ratio
(EER).
In the December 2008 TP NOPR, DOE also proposed that standby mode
and off mode testing be conducted with room-side air temperature at 74
2 degrees Fahrenheit ([deg]F), with a temperature control
setting of 79 [deg]F. 73 FR 74639, 74646. Upon further consideration,
however, DOE determined that, because the proposed test procedure would
be limited to measuring a single standby mode and an off mode, the
proposed close tolerance on ambient temperature and the proposed
temperature setting of 79 [deg]F, which were relevant only for an off-
cycle standby mode measurement, would not be required. Therefore, DOE
is not adopting those requirements for testing conditions in today's
final rule.
In the June 2010 TP SNOPR, DOE proposed that standby mode and off
mode testing for both clothes dryers and room air conditioners be
conducted at the settings that produce the highest power consumption
level, consistent with the particular mode definition under test. 75 FR
37594, 37604 (June 29, 2010). Upon further consideration, however, DOE
believes that provisions for testing in the settings that produce the
highest power consumption level would not be representative of consumer
usage. For the reasons discussed in section III.B.2, DOE believes the
provisions in section 5.2 of IEC Standard 62301 that specify the
appliance be installed and set up in accordance with manufacturers'
instructions, or if no instructions are given, the appliance be tested
at factory or ``default'' settings, is more representative of consumer
usage. Therefore, DOE amends the test procedure in today's final rule
to incorporate by reference section 5.2 of IEC Standard 62301 for
standby and off mode testing for both clothes dryers and room air
conditioners in today's final rule.
For the reasons discussed in section III.B.5, DOE revises the
estimated annual operating cost calculation for both clothes dryers and
room air conditioners (Estimated Annual Operating Cost and Annual
Energy Cost, respectively) to integrate the cost of energy use in the
standby mode and off mode.
Amendments to the Water Temperature for Clothes Dryer Test Load
Preparation
The existing DOE clothes dryer test procedure requires that the
test load be agitated in water whose temperature is 100 [deg]F 5 [deg]F. In the June 2010 TP SNOPR, DOE stated that it did not
have data indicating whether a different water temperature for clothes
dryer test load preparation would be more representative of current
consumer usage, but that if consumer usage data is made available that
indicates a 60 [deg]F 5 [deg]F water temperature is more
representative of consumer use, DOE may adopt this alternate approach.
75 FR 37594, 37615 (June 29, 2010). As discussed in section III.C.2,
DOE believes that the cold water rinse cycle is more representative of
typical consumer use based on the rinse temperature use factors in the
DOE clothes washer test procedure and the Energy Information
Administration (EIA) 2005 ``Residential Energy Consumption Survey''
(RECS) 10 11 data reporting the percentage of clothes washer
cycles for which consumers use cold water for the rinse cycle.
Therefore, DOE amends the clothes dryer test procedure in today's final
rule to change the water temperature for clothes dryer test load
preparation to 60 [deg]F 5 [deg]F. This temperature is
more representative of the clothes load temperature after a cold rinse
cycle at the end of the wash cycle.
---------------------------------------------------------------------------
\10\ U.S. Department of Energy-Energy Information
Administration. Residential Energy Consumption Survey 2005 Public
Use Data Files, 2005. Washington, DC. Available online at: http://www.eia.doe.gov/emeu/recs/.
\11\ EIA's 2005 RECS is the latest available version of this
survey.
---------------------------------------------------------------------------
Provisions for Testing Ventless Clothes Dryers
In today's final rule, DOE amends the current clothes dryer test
procedure to include provisions for testing ventless clothes dryers.
These provisions are based upon an alternate test procedure developed
by DOE and proposed in the June 2010 TP SNOPR that provide separate
definitions for a ``conventional clothes dryer'' and a ``condensing
clothes dryer.'' These provisions also qualify the requirement for an
exhaust simulator so that it would apply only to conventional clothes
dryers. Further, DOE includes in the test procedure additional language
based on provisions from European Standard EN 61121, ``Tumble dryers
for household use--Methods for measuring the performance,'' Edition 3
2005 (the EN Standard 61121). These provisions clarify the alternate
test procedure developed by DOE. EN Standard 61121 is an
internationally-accepted test standard that specifies methods for
testing ventless clothes dryers. The clarifications require that if a
ventless clothes dryer is equipped with a condensation box, the clothes
dryer shall be tested with such condensation box installed as specified
by the manufacturer. A condensation box stores condensed moisture
removed from the air exiting the drum. The box is later emptied by the
user. In addition, the clarifications also state that if the clothes
dryer stops the test cycle because the condensation box is full, the
[[Page 977]]
test is not valid because the unit would not be operating as intended
by the manufacturer to condense moisture in the air exiting the clothes
dryer drum. In such cases, the condensation box must be emptied and the
test re-run from the beginning. The clarifications also state that the
condenser heat exchanger cannot be taken out of the clothes dryer
between tests to clarify the test procedure and ensures that all
manufacturers are testing products under the same conditions. Finally,
DOE adopts clarifications that address clothes dryer preconditioning
for ventless clothes dryers, as discussed in section III.C.3.
Amendments To Reflect Current Usage Patterns and Capabilities
DOE amends the test procedure for clothes dryers to reflect current
usage patterns and capabilities. These amendments are based on DOE's
analysis of consumer usage patterns data. As proposed in the June 2010
SNOPR, DOE revises the number of annual use cycles from the 416 cycles
per year currently specified by the DOE test procedure to 283 cycles
per year for all types (that is, product classes) of clothes dryers.
This revision is based on DOE's analysis of data from the 2005 RECS for
the number of laundry loads (clothes washer cycles) washed per week and
the frequency of clothes dryer use. In addition, as proposed in the
2010 SNOPR, DOE changes the 7-pound (lb) clothes dryer test load size
specified by the current test procedure for standard-size clothes
dryers to 8.45 lb. This revision is based on the historical trends of
clothes washer tub volumes and the corresponding percentage increase in
clothes washer test load sizes (as specified by the DOE clothes washer
test procedure). DOE assumes these historical trends proportionally
impact clothes dryer load sizes. DOE believes most compact clothes
dryers are used in conjunction with compact-size clothes washers,
however, and DOE does not have any information to suggest that the tub
volume of such clothes washers has changed significantly. Therefore,
DOE is not changing the 3-lb test load size currently specified in its
clothes dryer test procedure for compact clothes dryers in today's
final rule.
In the June 2010 TP SNOPR, DOE also proposed to revise the 70-
percent initial RMC required by the test procedure to 47 percent so as
to accurately represent the condition of a laundry load after a wash
cycle. This proposal was based on analysis of shipment-weighted RMC
data for clothes washers submitted by AHAM and a distribution analysis
of RMC data for clothes washer models listed in the December 22, 2008
California Energy Commission (CEC) directory. 75 FR 37594, 37599 (June
29, 2010). In response to comments from interested parties on the June
2010 TP SNOPR, DOE determined that an initial clothes dryer RMC of 57.5
percent more accurately represents the moisture content of laundry
loads after a wash cycle for the purposes of clothes dryer testing. As
discussed in section III.5.b, this RMC is derived from the 47-percent
shipment-weighted RMC for clothes washers, but was derived without
applying an RMC correction factor as required by the DOE clothes washer
test procedure. For these reasons, DOE revises the initial clothes
dryer RMC from 70 percent to 57.5 percent in today's final rule.
Clothes Dryer Automatic Cycle Termination
In the June 2010 TP SNOPR, DOE proposed to revise its clothes dryer
test procedure to include definitions of and provisions for testing
both timer dryers and automatic termination control dryers using
methodology provided in Australia/New Zealand (AS/NZS) Standard 2442.1:
1996, ``Performance of household electrical appliances--Rotary clothes
dryers, Part 1: Energy consumption and performance'' (AS/NZS Standard
2442.1) and AS/NZS Standard 2442.2: 2000, ``Performance of household
electrical appliances--Rotary clothes dryers, Part 2: Energy labeling
requirements'' (AS/NZS Standard 2442.2). 75 FR 37594, 37598 (June 29,
2010). DOE proposed to incorporate the testing methods from these
international test standards, along with a number of clarifications, to
measure the energy consumption for both timer dryers and automatic
termination control dryers. The measurement would account for the
amount of over-drying energy consumption, that is, the energy consumed
by the clothes dryer after the load reaches an RMC of 5 percent. 75 FR
37594, 37599 (June 29, 2010).
DOE conducted testing of representative clothes dryers using the
automatic cycle termination test procedure proposed in the June 2010 TP
SNOPR; however, the test results showed that all of the clothes dryers
tested significantly over-dried the DOE test load to near bone dry. In
addition, the measured EF values were significantly lower than EF
values obtained using the existing DOE test procedure, and the test
data indicated that clothes dryers equipped with automatic termination
controls were less efficient than timer dryers. DOE believes the test
procedure amendments for automatic cycle termination proposed in the
June 2010 TP SNOPR do not adequately measure the energy consumption of
clothes dryers equipped with such systems using the test load specified
in the DOE test procedure. DOE believes that clothes dryers with
automatic termination sensing control systems, which infer the RMC of
the load from the properties of the exhaust air such as temprature and
humidity, may be designed to stop the cycle when the consumer load has
a higher RMC than the RMC obtained using the proposed automatic cycle
termination test procedure in conjunction with the existing test
load.\12\ Manufacturers have indicated, however, that test load types
and test cloth materials different than those specified in the DOE test
procedure do not produce results as repeatable as those obtained using
the test load as currenty specified. In addition, DOE presented data in
the May 1981 TP Final Rule from a field use survey conducted by AHAM as
well as an analysis conducted by the National Bureau of Standards (now
known as the National Institute of Standards and Technology (NIST)) of
field test data on automatic termination control dryers. Analysis of
this data showed that clothes dryers equipped with an automatic cycle
termination feature consume less energy than timer dryers by reducing
over-drying. 46 FR 27324 (May 19, 1981).
---------------------------------------------------------------------------
\12\ To investigate this, DOE conducted additional testing using
a test load similar to that specified in AHAM Standard HLD-1-2009,
which consists of cotton bed sheets, towels, and pillow cases. For
tests using the same automatic cycle termination settings as were
used in the testing described earlier (i.e., normal cycle setting
and highest temperature setting, the alternate test load was dried
to 1.7 to 2.2 percent final RMC, with an average RMC of 2.0 percent.
In comparison, the same clothes dryer under the same cycle settings
dried the DOE test load to 0.3 to 1.2 percent RMC, with an average
RMC of 0.7 percent. Thus, DOE concluded that the proposed automatic
cycle termination control test procedures may not stop at an
appropriate RMC when used with the current test load.
---------------------------------------------------------------------------
For the reasons discussed above, DOE believes the test procedure
amendments for automatic cycle termination proposed in the June 2010 TP
SNOPR do not adequately measure the energy consumption of clothes
dryers equipped with such systems. As a result, DOE is not adopting the
amendments for automatic cycle termination proposed in the June 2010 TP
SNOPR. 75 FR 37594, 37598-99 (June 29, 2010). If data is made available
to develop a test procedure that accurately measures the energy
consumption of clothes dryers equipped with automatic termination
controls, DOE may consider revised amendments in a future rulemaking.
[[Page 978]]
DOE received comments in response to the June 2010 TP SNOPR that it
should revise the definition of ``automatic termination control'' in
the current clothes dryer test procedure. Commenters felt the
definition should more clearly account for electronic controls by
specifying that a preferred automatic termination control setting can
also be indicated by any other visual indicator (in addition to a mark
or detent). DOE agrees this clarification should be added and is
amending the definition of ``automatic termination control'' in the
clothes dryer test procedure to include it.
DOE also received comments stating that the field-use factor for
clothes dryers with automatic cycle termination applied in the per-
cycle energy consumption calculation excludes sensing technologies that
do not meet the definitions of ``temperature sensing control'' or
``moisture sensing control,'' which are narrowly defined to require
that the control system use either a temperature sensor that monitors
the exhaust air or a moisture sensor contained within the drum. DOE
believes the definition of ``automatic termination control'' more
broadly applies to any sensing system that monitors either the dryer
load temperature or its moisture content and that this definition would
not limit the emergence of any new sensor technologies that monitor the
moisture content or temperature in other ways from applying the field
use factor for automatic cycle termination. For these reasons, DOE
amends the test procedure to specify that the field use factor applies
to clothes dryers that meet the requirements for the definitions of
``automatic termination control.''
Other Changes
For clothes dryers, DOE also revises the detergent specifications
for test cloth preconditioning to update the detergent specified in the
test procedure, eliminates an unnecessary reference to an obsolete
industry clothes dryer test standard, and amends the test conditions
for gas clothes dryers to specify the required gas supply pressure.
DOE also received comments related to clothes dryers from
interested parties on issues not addressed in the June 2010 TP SNOPR.
Commenters suggested that DOE clarify the provisions for the
measurement of drum capacity to specify that the clothes dryer's rear
drum surface be supported on a platform scale to ``prevent deflection
of the drum surface * * *'' instead of ``prevent deflection of the
dryer.'' As discussed in section III.C.10.e, DOE agrees with these
comments and adopts that provision in today's final rule. In addition,
DOE received comments in response to the June 2010 TP SNOPR that it
should expressly state the equations for EF and CEF in the test
procedure to provide optimal clarity for the regulated industry. DOE
agrees with comments that the equations for EF and CEF should be
included in 10 CFR part 430, subpart B, appendix D1 for completeness.
Therefore, DOE amends the clothes dryer test procedure in today's final
rule to include those calculations and to clarify in 10 CFR part
430.23(d)(2) and (3) that the EF and CEF must be determined in
accordance with the appropriate sections in 10 CFR part 430, subpart B,
appendix D1.
For room air conditioners, DOE updates the references in its
current room air conditioner test procedure to incorporate the most
recent ANSI and ASHRAE test standards--ANSI/AHAM RAC-1-R2008, ``Room
Air Conditioners,'' (ANSI/AHAM RAC-1-R2008) and ANSI/ASHRAE Standard
16-1983 (RA 2009) ``Method of Testing for Rating Room Air Conditioners
and Packaged Terminal Air Conditioners'' (ANSI/ASHRAE Standard 16-1983
(RA 2009)). DOE has also determined that the 750 annual operating hours
specified by the current DOE test procedure is representative of
current usage patterns, based upon its interpretation of data from the
2005 RECS. Therefore, DOE is not amending the annual usage hours
specified by the current DOE test procedure for room air conditioners.
As noted in section I, EPCA requires that DOE determine to what
extent, if any, test procedure amendments would alter the measured
energy efficiency of any covered product as determined under the
existing test procedure. (42 U.S.C. 6293(e)(1)) If DOE determines that
the amended test procedure would alter the measured efficiency of a
covered product, DOE must amend the applicable energy conservation
standard. In determining the amended energy conservation standard, DOE
must measure, pursuant to the amended test procedure, the energy
efficiency, energy use, or water use (as applicable) of a
representative sample of covered products that minimally comply with
the existing standard. (42 U.S.C. 6293(e)(2)) Under 42 U.S.C.
6295(gg)(2)(C), EPCA provides that amendments to the test procedures
that include standby mode and off mode energy consumption will not
determine compliance with previously established standards. (U.S.C.
6295(gg)(2)(C))
These amended clothes dryer and room air conditioner test
procedures are effective 30 days after the publication of today's final
rule in the Federal Register. Because the amendments to the test
procedures for measuring standby mode and off mode energy consumption
do not alter the existing measures of energy consumption or efficiency
for clothes dryers and room air conditioners, the amendments do not
affect a manufacturer's ability to comply with current energy
conservation standards. Manufacturers will not be required to use the
amended test procedures' standby mode and off mode provisions until the
mandatory compliance date of any amended clothes dryer and room air
conditioner energy conservation standards. All representations related
to standby mode and off mode energy consumption of both clothes dryers
and room air conditioners made 180 days after the publication of
today's final rule must be based upon the standby and off mode
requirements of the amended test procedures. (42 U.S.C. 6293(c)(2)) DOE
examines how each of the amendments to the active mode provisions in
its clothes dryer and room air conditioner test procedures in today's
final rule will affect the measured efficiency of products in section
IV.
III. Discussion
A. Products Covered by the Test Procedure Changes
Today's amendments to DOE's clothes dryer test procedure cover both
electric and gas clothes dryers, DOE defines a clothes dryer to mean a
cabinet-like appliance designed to dry fabrics in a tumble-type drum
with forced air circulation, with blower(s) driven by an electric
motor(s) and either gas or electricity as the heat source.
Porticos Inc. (Porticos) commented in response to the June 2010 TP
SNOPR that DOE's definition for an electric clothes dryer excludes
every possible alternative from consideration. Porticos stated that any
alternate innovative clothes dryer technology, such as microwave,
radio-frequency, vacuum, desiccant, and vapor-compression, would not
meet the current electric clothes dryer definition, and direct
comparisons would not be possible. Porticos commented that a better
definition would be ``an electrical appliance for drying clothes'' and
that any more limiting verbiage serves only to exclude new entrants
from the marketplace. (Porticos, No. 23 at p. 1) Porticos also
commented that DOE should reexamine the test procedures to remove any
explicit or implicit reference to a particular technology or
[[Page 979]]
approach to clothes drying. (Porticos, No. 23 at p. 2)
DOE notes that the definition of a clothes dryer in the CFR does
not prohibit other products (that is, those that do not fall under the
definition of a clothes dryer) from being introduced to the market. For
example, spin dryers or drying cabinets that do not use a heat source,
forced air circulation, or a tumble-type drum are currently
commercially available. Under the product definition suggested by
Porticos, DOE notes that blow dryers, fans, or heat lamps could be
considered covered products. DOE is also not aware of any commercially
available microwave, radio-frequency, vacuum, desiccant, or vapor-
compression clothes dryers. As a result, no data is available by which
DOE could develop standards for such dryers. For these reasons, DOE is
not revising the definition of a clothes dryer in today's final rule.
DOE's regulations define a room air conditioner as a consumer
product which is powered by a single-phase electric current and which
is an encased assembly designed as a unit for mounting in a window or
through the wall for the purpose of providing delivery of conditioned
air to an enclosed space. It includes a prime source of refrigeration
and may include a means for ventilating and heating. It does not
include packaged terminal air conditioners.\13\ This definition and the
amendments discussed below cover room air conditioners designed for
single- or double-hung windows with or without louvered sides and with
or without reverse cycle, as well as casement-slider and casement-only
window-type room air conditioners. DOE is not changing the definition
for room air conditioners in today's final rule.
---------------------------------------------------------------------------
\13\ DOE's regulations define a packaged terminal air
conditioner as a wall sleeve and a separate encased combination of
heating and cooling assemblies specified by the builder and intended
for mounting through the wall. It includes a prime source of
refrigeration, separable outdoor louvers, forced ventilation, and
heating availability energy.
---------------------------------------------------------------------------
B. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode
Test Procedures
1. Incorporating by Reference IEC Standard 62301 for Measuring Standby
Mode and Off Mode Power in Clothes Dryers and Room Air Conditioners
As noted in the December 2008 TP NOPR, DOE considered, pursuant to
EPCA, the most current versions of IEC Standard 62301 and IEC Standard
62087 for measuring power consumption in standby mode and off mode. (42
U.S.C. 6295(gg)(2)(A)) 73 FR 74639, 74643-44 (December 9, 2008).\14\
DOE noted that IEC Standard 62301 provides for measuring standby power
in electrical appliances, including clothes dryers and room air
conditioners, and, therefore, is applicable to the proposed amendments
to the clothes dryer and room air conditioner test procedures. 73 FR
74643-44 (December 9, 2008).
---------------------------------------------------------------------------
\14\ DOE notes that IEC Standard 62087 specifies methods of
measuring the power consumption of TV receivers, videocassette
recorders (VCRs), set top boxes, audio equipment, and multi-function
equipment for consumer use. IEC Standard 62087 does not include
measurement for the power consumption of electrical appliances such
as clothes dryers and room air conditioners. Therefore, IEC Standard
62087 is not applicable to the amendments to the clothes dryer and
room air conditioner test procedures.
---------------------------------------------------------------------------
DOE proposed in the December 2008 TP NOPR to incorporate by
reference into the DOE test procedures for clothes dryers and room air
conditioners specific clauses from IEC Standard 62301 for measuring
standby mode and off mode power: from section 4 (``General conditions
for measurements''); paragraph 4.2, ``Test room''; paragraph 4.4,
``Supply voltage waveform''; and paragraph 4.5, ``Power measurement
accuracy''; as well as from section 5 (``Measurements''); paragraph
5.1, ``General''; and paragraph 5.3, ``Procedure.'' DOE also proposed
to reference these same provisions in the DOE test procedure for room
air conditioners, as well as section 4, paragraph 4.3, ``Power
supply.'' 73 FR 74639, 74644 (December 9, 2008).
In the December 2008 TP NOPR, DOE noted that EPCA (42 U.S.C.
6295(gg)(2)(A)) requires that in developing any amended test
procedures, DOE consider the most current version of IEC Standard
62301. The IEC is currently developing an updated version of this
standard, IEC Standard 62301 Second Edition. 73 FR 74639, 74644
(December 9, 2008). At the time of publication of the December 2008 TP
NOPR, however, IEC Standard 62301 was the ``current version, which DOE
was required by EPCA to consider. DOE incorporated sections from IEC
Standard 62301 in the proposed amendments to the test procedure in the
December 2008 TP NOPR. 73 FR 74639, 74644 (December 9, 2008).
DOE did not receive any objections to the proposed testing methods
and procedures referenced in IEC Standard 62301 in response to the
December 2008 TP NOPR. As a result, the June 2010 TP SNOPR did not
affect DOE's proposal in the December 2008 TP NOPR to incorporate by
reference the clauses presented above from IEC Standard 62301. 75 FR
37594, 37602 (June 29, 2010).
DOE anticipated, based on review of draft versions of IEC Standard
62301 Second Edition, that the revisions to IEC Standard 62301 could
include different mode definitions. DOE received information, however,
that IEC Standard 62301 Second Edition would not be available until
late 2010. To allow for consideration of standby and off mode power
consumption in the concurrent energy conservation standards rulemaking,
DOE proposed in the June 2010 TP SNOPR the new mode definitions from
the most recent draft version of IEC Standard 62301 Second Edition, IEC
Standard 62301 CDV. The definitions of standby mode, off mode, and
active mode in IEC Standard 62301 CDV expand upon the EPCA mode
definitions and provide additional guidance as to which functions are
associated with each mode. 75 FR 37594, 37602 (June 29, 2010). The
comments received by IEC on IEC Standard 62301 CD2, and the resulting
amended mode definitions proposed in IEC Standard 62301 CDV,
demonstrate significant participation of interested parties in the
development of definitions that represent a substantial improvement
over those in IEC Standard 62301. Id. These definitions are discussed
in detail in Section III.B.2.
In response to the June 2010 TP SNOPR, AHAM, Alliance Laundry
Systems (ALS), and Whirlpool Corporation (Whirlpool) commented in
support of referencing the most recent draft version of IEC Standard
62301 Second Edition, designated as IEC Standard 62301 FDIS, for test
methods and mode definitions rather than IEC Standard 62301 First
Edition and IEC Standard 62301 CDV. (AHAM, Public Meeting Transcript,
No. 20 at pp. 18, 26-27; AHAM, No. 27 at p. 2; ALS, No. 24 at p. 1;
Whirlpool, No. 27 at p. 1)
AHAM and Whirlpool commented that IEC Standard 62301 FDIS will soon
be formally adopted by IEC, and it contains a number of clarifications
to the definitions and test procedures not present in IEC Standard
62301 CDV. According to AHAM and Whirlpool, this will allow for optimum
international harmonization, giving clarity and consistency to the
regulated community and decreasing testing burden. (AHAM, No. 31 at p.
2; Whirlpool, No. 27 at p. 1) Additionally, AHAM commented that no
technical edits can be made to the standard after the FDIS version, so
most countries allow a legal reference to this version. (AHAM, Public
Meeting Transcript, No. 20 at pp. 14-15)
AHAM commented that IEC Standard 62031 FDIS incorporates comments
from energy efficiency advocates,
[[Page 980]]
including the addition of an uncertainty power measurement section that
would limit the possibility for different measurement results from
different test labs. (AHAM, Public Meeting Transcript, No. 20 at pp.
16, 18, 26-27) AHAM also noted that IEC Standard 62301 FDIS includes a
new sampling measurement method and an average reading measurement
method. (AHAM, Public Meeting Transcript, No. 20 at pp. 13-18) AHAM
commented that if DOE chooses not to adopt the IEC Standard 62301 FDIS,
AHAM supports the use of IEC Standard 62301 CDV as the main referenced
document. (AHAM, No. 31 at p. 2) Pacific Gas and Electric Company
(PG&E), Southern California Gas Company (SCGC), Southern California
Edison (SCE), and Natural Resources Defense Council (NRDC) (hereafter
``the California Utilities/NRDC''), stated in a jointly filed comment
that they support harmonization with international standards and
support the use of the definitions and test procedures in IEC Standard
62301 CDV. (California Utilities/NRDC, No. 33 at p. 2)
According to publicly available information, the IEC currently
anticipates that the final version of IEC Standard 62301 Second Edition
will likely be published in early 2011. Therefore, the second edition
is not available for DOE's consideration or incorporation by reference.
DOE is aware that there are significant differences between IEC
Standard 62301 First Edition and IEC Standard 62301 FDIS, which is the
latest draft version of IEC Standard 62301 Second Edition. DOE notes
that these changes in methodology were first introduced only at the IEC
Standard 62301 FDIS stage. These changes have not been the subject of
significant comment from interested parties, nor has DOE had the
opportunity to conduct a thorough analysis of those provisions.
Consequently, the merits of these latest changes have not been fully
vetted to demonstrate that they are preferable to the existing
methodological provisions in the current version of the IEC standard.
For these reasons, DOE has decided to base the test procedure
amendments (other than the mode definitions, which are discussed in
Section III.B.2) on the provisions of IEC Standard 62301 First Edition.
DOE based the mode definitions on the language from IEC Standard 62301
CDV to address specific concerns raised by interested parties, as
discussed above in this section. As discussed in section III.B.2, DOE
notes that the mode definitions in IEC Standard 62301 CDV are
essentially the same as the definitions provided in IEC Standard 62301
FDIS, with only minor editorial changes.
For the reasons discussed above and in the December 2008 NOPR and
June 2010 SNOPR, DOE amends its test procedures for clothes dryers and
room air conditioners in today's final rule to incorporate by reference
the clauses from IEC Standard 62301 First Edition and the mode
definitions from IEC Standard 62301 CDV. 73 FR 74639 (December 9,
2008); 75 FR 37594, 37602 (June 29, 2010). DOE may consider
incorporating by reference clauses from IEC Standard 62301 Second
Edition when that version has been published.
2. Determination of Modes To Be Incorporated
December 2008 TP NOPR
In the December 2008 TP NOPR, DOE proposed to incorporate into the
clothes dryer and room air conditioner test procedure the definitions
of ``active mode,'' ``standby mode,'' and ``off mode'' specified by
EPCA. 73 FR 74639, 74644 (December 9, 2008). EPCA defines ``active
mode'' as ``the condition in which an energy-using product --
(I) Is connected to a main power source;
(II) has been activated; and
(III) provides 1 or more main functions.''
(42 U.S.C. 6295(gg)(1)(A)(i))
EPCA defines ``standby mode'' as ``the condition in which an
energy-using product--
(I) Is connected to a main power source; and
(II) offers 1 or more of the following user-oriented or protective
functions:
(aa) To facilitate the activation or deactivation of other
functions (including active mode) by remote switch (including remote
control), internal sensor, or timer.
(bb) Continuous functions, including information or status displays
(including clocks) or sensor-based functions.''
(42 U.S.C. 6295(gg)(1)(A)(iii)) This definition differs from IEC
Standard 62301 First Edition, which defines standby mode as the
``lowest power consumption mode which cannot be switched off
(influenced) by the user and that may persist for an indefinite time
when an appliance is connected to the main electricity supply and used
in accordance with the manufacturer's instructions.'' The EPCA
definition permits the inclusion of multiple standby modes.
EPCA defines ``off mode'' as ``the condition in which an energy-
using product--
(I) Is connected to a main power source; and
(II) is not providing any standby mode or active mode function.''
\15\
\15\ DOE notes that some features that provide consumer utility,
such as displays and remote controls, are associated with standby
mode and not off mode. A clothes dryer or room air conditioner is
considered to be in ``off mode'' if it is plugged in to a main power
source, is not being used for an active function such as drying
clothing or providing cooling, and is consuming power for features
other than a display, controls (including a remote control), or
sensors required to reactivate it from a low power state. For
example, a clothes dryer with mechanical controls and no display or
continuously-energized moisture sensor, but that consumes power for
components such as a power supply when the unit was not activated,
would be considered to be in off mode when not providing an active
function. For room air conditioners, a unit with mechanical controls
and no display or remote control but with a power supply that
consumes energy could be considered to be in off mode while not
providing an active function.
---------------------------------------------------------------------------
(42 U.S.C. 6295(gg)(1)(A)(ii))
DOE recognized, however, that the EPCA definitions for ``active
mode,'' ``standby mode,'' and ``off mode'' were developed to be broadly
applicable for many energy-using products. For specific products with
multiple functions, these broad definitions could lead to certain
features being considered part of standby mode or off mode instead of
active mode depending on the interpretation of the meaning of ``main
functions.'' 73 FR 74639, 74644-45 (December 9, 2008). As a result, DOE
further proposed in the December 2008 TP NOPR to amend the clothes
dryer and room air conditioner test procedures to clarify the range of
main functions that would be classified as active mode functions and
clarify standby and off mode definitions as follows:
For clothes dryers--
``Active mode'' means a mode in which the clothes dryer is
performing the main function of tumbling the clothing with or without
heated or unheated forced air circulation to remove moisture from the
clothing and/or remove or prevent wrinkling of the clothing;
``Inactive mode'' means a standby mode other than delay start mode
or cycle finished mode that facilitates the activation of active mode
by remote switch (including remote control), internal sensor, or timer,
or provides continuous status display;
``Cycle finished mode'' means a standby mode that provides
continuous status display following operation in active mode;
``Delay start mode'' means a standby mode that facilitates the
activation of active mode by timer; and
[[Page 981]]
``Off mode'' means a mode in which the clothes dryer is not
performing any active or standby function. 73 FR 74645.
For room air conditioners--
``Active mode'' means a mode in which the room air conditioner is
performing the main function of cooling or heating the conditioned
space, or circulating air through activation of its fan or blower, with
or without energizing active air-cleaning components or devices such as
ultraviolet (UV) radiation, electrostatic filters, ozone generators, or
other air-cleaning devices;
``Inactive mode'' means a standby mode other than delay start mode
or off-cycle mode that facilitates the activation of active mode by
remote switch (including remote control) or internal sensor or provides
continuous status display;
``Delay start mode'' means a standby mode in which activation of an
active mode is facilitated by a timer;
``Off-cycle mode'' means a standby mode in which the room air
conditioner: (1) Has cycled off its main function by thermostat or
temperature sensor; (2) does not have its fan or blower operating; and
(3) will reactivate the main function according to the thermostat or
temperature sensor signal; and
``Off mode'' means a mode in which a room air conditioner is not
performing any active or standby function. 73 FR 74645.
June 2010 TP SNOPR and Today's Final Rule--Active Mode.
As discussed in section III.B.1, DOE proposed in the June 2010 TP
SNOPR to amend the DOE clothes dryer and room air conditioner test
procedures to define active mode as a mode that ``includes product
modes where the energy using product is connected to a mains power
source, has been activated and provides one or more main functions'' 75
FR 37594, 37603 (June 29, 2010). The definition of active mode proposed
in the June 2010 TP SNOPR is the same as the definition proposed for
the December 2008 TP NOPR, with minor editorial changes to conform with
the definition in IEC Standard 62301 CDV. 73 FR 74639, 74644 (December
9, 2008). DOE noted that IEC Standard 62301 CD2 provided additional
clarification that ``delay start mode is a one off user initiated short
duration function that is associated with an active mode.'' (IEC
Standard 62301 CD2, section 3.8) IEC Standard 62301 CDV removed this
clarification; however, in response to comments on IEC Standard 62301
CD2 that led to IEC Standard 62301 CDV, IEC states that delay start
mode is a one off function of limited duration.\16\ DOE inferred this
to mean that delay start mode would not be considered a standby mode,
although no conclusion is made as to whether it would be considered
part of active mode. 75 FR 37594, 37603 (June 29, 2010). Delay start
mode is discussed later in this section.
---------------------------------------------------------------------------
\16\ ``Compilation of comments on 59/523/CD: IEC 62301 Ed 2.0:
Household electrical appliances--Measurement of standby power.''
August 7, 2009. p. 6. IEC Standards are available online at http://www.iec.ch.
---------------------------------------------------------------------------
As discussed above in section III.B.1, the California Utilities/
NRDC commented that it supports the use of the mode definitions in IEC
Standard 62301 CDV. (California Utilities/NRDC, No. 33 at p. 2) Also
discussed above in section III.B.1, AHAM and Whirlpool supported the
use of the mode definitions in IEC Standard 62301 FDIS. (AHAM, Public
Meeting Transcript, No. 20 at p. 18; AHAM, No. 31 at p. 2; Whirlpool,
No. 27 at p. 1) DOE notes that the definition of active mode in IEC
Standard 62301 FDIS is essentially the same as the definition provided
in IEC Standard 62301 CDV, with only minor editorial changes. For the
reasons stated above, DOE is adopting in today's final rule the active
mode definition proposed in the June 2010 TP SNOPR.
In the June 2010 TP SNOPR, DOE did not change the additional
clarifications discussed above for the range of main functions that
would be classified as active mode functions, which were proposed in
the December 2008 TP NOPR. 75 FR 37594, 37603 (June 29, 2010). DOE did
not receive any comments objecting to the clarifications for the range
of main functions that would be classified as active mode functions for
each product. Therefore, for the reasons stated above, DOE adopts the
amendments to clarify the range of main functions that would be
classified as active mode functions as proposed in the December 2008 TP
NOPR. Id.
For clothes dryers, DOE also investigated in the June 2010 TP SNOPR
whether certain operating cycles providing a steam function should be
covered under active mode, and whether measurement of energy
consumption for such cycles should be incorporated into the DOE clothes
dryer test procedure. 75 FR 37594, 37603 (June 29, 2010). The current
DOE test procedure does not contain any provisions that would account
for the energy and water use of steam cycles. DOE's analysis of a
preliminary market survey of products available on the market conducted
for the June 2010 TP SNOPR suggests that, at this time, steam cycles
represent a very small fraction of overall product use nationwide. DOE
also stated that it is unaware of energy and water consumption or
consumer usage data with respect to steam. For these reasons, DOE did
not propose amendments to include measurement of steam cycles for
clothes dryers in the June 2010 TP SNOPR. Id. DOE did not receive any
comments regarding the determination to not include measurement of
steam cycles for clothes dryers. For these reasons, DOE is not amending
its clothes dryer test procedure to include measurement of steam
cycles.
June 2010 TP SNOPR and Today's Final Rule--Standby Mode
As discussed in section III.B.1, DOE proposed in the June 2010
SNOPR to amend the DOE test procedure for clothes dryers and room air
conditioners to define standby mode based on the definitions provided
in IEC Standard 62301 CDV. 75 FR 37604. DOE proposed to define standby
mode as a mode that ``includes any product modes where the energy using
product is connected to a mains power source and offers one or more of
the following user oriented or protective functions which may persist
for an indefinite time: \17\
---------------------------------------------------------------------------
\17\ The actual language for the standby mode definition in IEC
Standard 62301 CDV describes `` * * * user oriented or protective
functions which usually persist'' rather than ``* * * user oriented
or protective functions which may persist for an indefinite time.''
DOE notes, however, that section 5.1 of IEC Standard 62301 CDV
states that ``a mode is considered persistent where the power level
is constant or where there are several power levels that occur in a
regular sequence for an indefinite period of time.'' DOE believes
that the proposed language, which was originally included in IEC
Standard 62301 CD2, encompasses the possible scenarios foreseen by
section 5.1 of IEC Standard 62301 CDV without unnecessary
specificity.
---------------------------------------------------------------------------
To facilitate the activation of other modes (including
activation or deactivation of active mode) by remote switch (including
remote control), internal sensor, timer;
Continuous function: information or status displays
including clocks;
Continuous function: sensor-based functions.'' Id.
DOE also proposed an additional clarifiction that ``a timer is a
continuous clock function (which may or may not be associated with a
display) that provides regular scheduled tasks (e.g., switching) and
that operates on a continuous basis.'' Id. This defintion was developed
based on the definitions provided in IEC Standard 62301 CDV, and
expands upon the EPCA mode definitions to provide additional
clarifications as to which functions are associated with each mode.
ALS supported DOE's proposed definition of standby mode. (ALS, No.
[[Page 982]]
24 at p. 1) Whirlpool commented that DOE should reference IEC 62301
FDIS for the standby mode definition. (Whirlpool, No. 27 at p. 1) AHAM
commented that DOE should define a timer function under the standby
mode definition to exclude limited duration situations where the
appliance is in a higher power state, for example in delay start mode.
(AHAM, Public Meeting Transcript, No. 20 at pp. 35-36) DOE notes that
the definition of standby mode in IEC Standard 62301 FDIS is
essentially the same as the definition provided in IEC Standard 62301
CDV, with only minor editorial changes. DOE also notes the definition
of standby mode specifies that it must be a mode that may persist for
an indefinite time, which would exclude limited duration situations.
Therefore, DOE does not believe that any additional clarification in
the definition of standby mode is necessary. For these reasons, DOE is
adopting in today's final rule the standby mode definition proposed in
the June 2010 TP SNOPR. 75 FR 37594, 37604 (June 29, 2010).
DOE stated in the June 2010 TP SNOPR that given these proposed
definitions, delay start mode and cycle-finished mode for clothes
dryers and delay start mode and off-cycle mode for room air
conditioners are not modes that persist for an indefinite time, and
would therefore not be considered as part of a standby mode. 75 FR
37604. DOE's analysis of annual energy use in specific clothes dryer
and room air conditioner modes presented in the December 2008 TP NOPR
showed that delay start mode and cycle-finished mode for clothes
dryers, and delay start mode and off-cycle mode for room air
conditioners, each represent a negligible portion (0.1 percent or less)
of the annual energy use for those products. 73 FR 74639, 74647, 74649
(December 9, 2008). Therefore, an integrated energy efficiency metric
for either clothes dryers or room air conditioners would not be
measurably affected by the exclusion of the energy use in any of these
modes. Further, DOE stated in the June 2010 TP SNOPR that the benefit
of incorporating the energy use of these modes into the overall energy
efficiency metric is outweighed by the burden that would be placed on
the manufacturers to measure power consumption in each of these modes.
For these reasons, DOE did not propose amendments to the test
procedures to define delay start, cycle finished, and off-cycle modes
or to measure power consumption in delay start mode for either product,
cycle finished mode for clothes dryers, and off-cycle mode for room air
conditioners in the June 2010 TP SNOPR. DOE included in the proposed
clothes dryer and room air conditioner test procedures amendments in
the June 2010 TP SNOPR provisions for measuring energy consumption only
in the inactive mode and off mode. 75 FR 37594, 37604 (June 29, 2010).
The California Utilities/NRDC, AHAM, ALS, and Whirlpool agreed that
delay start and cycle finished modes for clothes dryers would not be
considered standby modes. (California Utilities/NRDC, No. 33 at p. 2;
AHAM, No. 31 at p. 3; Whirlpool, No. 27 at p. 1; ALS, No. 24 at p. 1)
AHAM and Whirlpool added that delay start and cycle finished modes
should instead be considered part of active mode. (AHAM, No. 31 at p.
3; Whirlpool, No. 27 at p. 1) Whirlpool also commented that any
function begun by the user when initiating the operating mode includes
all power consumed until the full conclusion of that operation.
(Whirlpool, No. 27 at p. 1)
DOE continues to believe that delay start, cycle finished, and off-
cycle modes for clothes dryers and room air conditioners are not modes
that persist for an indefinite time and, therefore, would not be
considered standby modes. For the reasons discussed above, DOE
continues to believe that the benefit of incorporating the energy use
of these modes into the overall energy efficiency is outweighed by the
burden that would be placed on the manufacturers to measure power
consumption in each of these modes. As discussed in section III.B.4,
however, DOE determined that the power consumption of clothes dryers
and room air conditioners operating in such modes approximates the
power levels in inactive/off modes. Therefore, DOE amends the test
procedure in today's final rule to specify that all non-active mode
hours be allocated to the inactive and off modes for both clothes
dryers and room air conditioners. Thus, the amended test procedure
accounts for the energy use in delay start, cycle finished, and off-
cycle modes. For these reasons, DOE is not adopting amendments to the
test procedures to define delay start, cycle finished, and off-cycle
modes or to measure power consumption in delay start mode for either
product, cycle finished mode for clothes dryers, and off-cycle mode for
room air conditioners.
In the June 2010 TP SNOPR, DOE noted that it received comments from
interested parties in response to the December 2008 TP NOPR that the
as-shipped factory or ``default'' settings should be used for standby
and off mode testing. 75 FR 37594, 37605 (June 29, 2010). DOE stated in
the June 2010 TP SNOPR that provisions for setting up the appliance for
standby mode and off mode testing should be specified in the test
procedure. However, DOE stated that setting up the appliance in
accordance with manufacturer's instructions or in the as-shipped
factory or ``default'' settings would allow manufacturers to ship
appliances set in a low power mode that consumers may switch out of
during typical standby or off mode use. Therefore, DOE proposed in the
June 2010 TP SNOPR that the appliance be set up with the settings that
produce the highest power consumption level, consistent with the
particular mode definition under test, for standby and off mode
testing. Id.
AHAM, Whirlpool, and ALS objected to the proposal that the clothes
dryer be set up at the highest energy consumption level consistent with
the particular standby or off mode. They felt such an approach does not
reflect consumer use, increases test burden to determine such settings,
and lacks conformity, consistency, and repeatability across
manufacturers. AHAM, Whirlpool, and ALS commented that the clothes
dryer should instead be set up in factory or ``default'' cycle
settings, and that this procedure is consistent with consumer usage and
will result in repeatable, reproducible results. AHAM and Whirlpool
stated that should there be no indicators for the default settings, the
appliance should be tested as shipped. AHAM, Whirlpool, and ALS stated
that such an approach would ensure uniformity among the different
laboratories that may run the test. They also stated that DOE's
proposal would introduce unnecessary variability into the test and add
to the test burden because manufacturers would need to run several
tests on every model to determine which cycle is the highest-energy
cycle. (AHAM, No. 31 at pp. 4-5; Whirlpool, No. 27 at p. 1; ALS, No. 24
at pp. 1-2) Whirlpool added that repeatable results are of increasing
importance for verification processes. (Whirlpool, No. 27 at p. 1)
AHAM commented that incentivizing manufacturers to ship products
with the lowest power settings is a better way to save energy than
shipping with the highest power settings, because most consumers do not
change the settings. (AHAM, Public Meeting Transcript, No. 20 at p. 56)
AHAM stated that products may have provisions for the consumer to add
or delete product functions that alter the as-shipped standby energy
mode, and that the power consumption in these user-selected modes may
exceed the power consumption in the
[[Page 983]]
lowest-power consumption mode. AHAM stated that the user must be
informed as to how to make these selections and that the selection(s)
will override the lowest-power consumption mode. According to AHAM,
testing the appliance in the factory settings or ``default'' settings
provides a clear and simple way to define standby mode and allow new
functions that may be developed to be added to the appropriate mode
without requiring the test procedure be revised. (AHAM, No. 31 at p. 3)
The California Utilities/NRDC supported DOE's proposed approach to
use the settings that produce the highest power consumption for standby
and off mode testing. They felt this approach would remove a potential
opportunity for ``gaming'' appliance testing and would ensure that the
standby mode and off mode testing would measure the highest energy-
consuming combination of modes. The California Utilities/NRDC stated
that there is no data that indicates that the factory default settings
are uniform, or that they are typically used by consumers. In addition,
the California Utilities/NRDC stated that DOE's proposed approach would
standardize the standby mode and off mode testing among manufacturers,
because how a factory default setting is used during testing may not be
consistent from manufacturer to manufacturer. (California Utilities/
NRDC, No. 33 at p. 2) Appliance Standards Awareness Project (ASAP) also
commented that using the default settings for testing would give
manufacturers an incentive to ship products in a very low-power mode
that consumers may never use because they can easily adjust the
settings. (ASAP, Public Meeting Transcript, No. 20 at p. 55)
DOE agrees with AHAM, Whirlpool, and ALS that the proposed
provisions for testing standby and off mode using the settings that
produce the highest power consumption level consistent with the
particular mode definition under test would not be representative of
consumer use. If manufacturers were to ship products in a very low-
power mode, DOE does not believe that consumers would likely modify the
settings so that the product is in the highest power settings, but
would instead use what would have been the as-shipped factory or
``default'' settings during typical standby or off mode use. DOE agrees
that, because newer products offer more consumer related features and
thus more display or settings configurations, requiring laboratories to
determine the settings that produce the highest power consumption
levels would make it more difficult to ensure that test results are
repeatable. DOE notes that section 5.2 of IEC Standard 62301,
``Selection and preparation of appliance or equipment,'' includes
provisions for installing and setting up the appliance as specified by
manufacturers instructions. Section 5.2 of IEC Standard 62301 also
specifies that if no instructions are given, the appliance shall be
tested at factory or default settings, and where there are no
indications for such settings, the appliance shall be tested as
supplied. DOE believes that section 5.2 of IEC Standard 62301 clarifies
the installation requirements for standby mode and off mode energy
consumption testing and provides additional guidance regarding
specifications for test setup that would result in a measure of standby
and off mode energy consumption that best replicates actual consumer
usage. For these reasons, DOE is incorporating by reference section 5.2
of IEC Standard 62301 for standby and off mode testing in today's final
rule.
June 2010 TP SNOPR and Today's Final Rule--Standby Mode or Active Mode,
Network Mode
For the June 2010 TP SNOPR, DOE also considered whether it should
adopt amendments for network mode. 75 FR 37594, 37605 (June 29, 2010).
Section 3.7 of IEC Standard 62301 CDV defines network mode as a mode
category that ``includes any product modes where the energy using
product is connected to a main power source and at least one network
function is activated (such as reactivation via network command or
network integrity communication) but where the primary function is not
active.'' Section 3.7 of IEC Standard 62301 CDV also provides a note
stating, ``Where a network function is provided but is not active and/
or not connected to a network, then this mode is not applicable. A
network function could become active intermittently according to a
fixed schedule or in response to a network requirement. A `network' in
this context includes communication between two or more separate
independently powered devices or pieces of equipment. A network does
not include one or more controls, which are dedicated to a single piece
of equipment. Network mode may include one or more standby functions.''
However, DOE stated in the June 2010 TP SNOPR that it is unaware of any
clothes dryers or room air conditioners currently available on the
market that incorporate a networking function. Further, DOE stated that
it is unaware of any data regarding network mode that would enable it
to determine appropriate testing procedures and mode definitions for
clothes dryers and room air conditioners. In particular, DOE stated
that it is unaware of data and methods for the appropriate
configuration of networks; whether network connection speed or the
number and type of network connections affects power consumption; or
whether wireless network devices may consume power differently when the
device is looking for a connection as opposed to when the network
connection is actually established. DOE stated that it is also unaware
of how the energy consumption for clothes dryers and room air
conditioners in a network environment might be affected by their
product design, user interaction, or network interaction. For example,
DOE is unaware of what affects might result should the network function
become active intermittently according to a fixed schedule or in
response to a network requirement. For these reasons, the proposed
amendments in the June 2010 TP SNOPR did not include network mode. Id.
AHAM commented that there are not enough products currently
available on the market from which to gather data regarding network
mode. AHAM stated that, in the event DOE decides to address network
mode, AHAM does not support including network mode in standby or off
mode. AHAM commented that network mode and the energy use associated
with ``Smart Appliances'' \18\ should be treated as a distinctive
energy use that enhances electrical grid system efficiencies that save
energy and reduce carbon emissions, adding that this is consistent with
IEC Standard 62301 FDIS. AHAM also commented that when sufficient data
exists, AHAM would be willing to work with DOE to define where and how
to address network mode. (AHAM, No. 31 at p. 4) AHAM also added that if
network mode is considered part of standby mode, it would be a major
difficulty in the development of ``Smart Appliances'' and the ``Smart
Grid.'' \19\ (AHAM, Public Meeting Transcript, No. 20 at pp. 38-39)
---------------------------------------------------------------------------
\18\ A ``Smart Appliance'' is a product equipped with network
mode capabilities.
\19\ A ``Smart Grid'' is an automated electric power system that
monitors and controls electrical grid activities and is capable of
real-time two-way digital communications between utilities and
consumers. Information on Smart Grid is available online at http://www.oe.energy.gov/smartgrid.htm.
---------------------------------------------------------------------------
Whirlpool commented that network mode will become a vital mode in
the future development of appliances capable of interacting with the
Smart Grid, but that such products do not exist today outside of
development laboratories. Whirlpool urged DOE to
[[Page 984]]
retain network mode as a separate mode as distinct from any other mode.
Whirlpool urged that no standard or test procedure be adopted for this
mode until manufacturers have sufficient quantities of Smart Grid
models in production that comprehensive testing and measurement can
take place. (Whirlpool, No. 27 at pp. 1-2)
The American Council for an Energy-Efficient Economy (ACEEE), ASAP,
and NRDC stated in a jointly filed comment (hereafter the ``Joint
Efficiency Advocates Comment'') that if network mode is a mode the
appliance would be in at all times, it should be classified as standby;
if it is an intermittent or user-activated condition, it should be
considered active mode. The Joint Efficiency Advocates Comment
suggested that DOE's definition of network mode be aligned with the IEC
definition and recommended creating a test method for network mode.
This test method would be similar to the standby test method, but
network connectivity would be enabled. The Joint Efficiency Advocates
Comment stated that units could be tested without actually connecting
to a network; simply enabling the network capabilities should be enough
to test energy consumption while in a simulated networking state. The
Joint Efficiency Advocates Comment recommended that DOE consider
incorporating network mode into energy consumption ratings as the
market for network-enabled devices developed. In the meantime, network
mode should be tested on available appliances, and that research and
analysis should be conducted on predicted or actual consumer usage in
advance of a future revision to the test procedure. (Joint Efficiency
Advocates Comment, No. 28 at p. 3)
DOE notes that, in the absence of data on the operation and
functionality of network mode, it is unable to define appropriate
testing conditions and procedures for accurately measuring the energy
use of clothes dryers and room air conditioners capable of functioning
in network mode. This lack of data also prevents DOE from evaluating
how these products will develop in the future. Also, because DOE does
not have sufficient data on the operation and functionality of network
mode, it is not making a determination as to whether network mode would
be included as part of standby or active mode. DOE may consider
amendments to the clothes dryer and room air conditioner test
procedures when products capable of functioning in network mode are in
production and commercially available. At that time, comprehensive
analysis can determine appropriate testing conditions and procedures
for accurately measuring network mode energy use.
June 2010 TP SNOPR and Today's Final Rule--Off Mode
As discussed in section III.B.1, DOE proposed in the June 2010 TP
SNOPR to amend the DOE test procedure for clothes dryers and room air
conditioners to define off mode based upon the definition in IEC
Standard 62301 CDV. DOE proposed to define off mode as a mode category
which ``includes any product modes where the energy using product is
connected to a mains power source and is not providing any standby mode
or active mode function and where the mode may persist for an
indefinite time.\20\ An indicator that only shows the user that the
product is in the off position is included within the clasification of
off mode.'' This defintion was developed based on the definitions
provided in IEC Standard 62301 CDV, and expands upon the EPCA mode
definitions to provide additional clarifications as to which functions
are associated with each mode. 75 FR 37594, 37605 (June 29, 2010).
---------------------------------------------------------------------------
\20\ As with the definition for standby mode, IEC Standard 62301
CDV qualifies off mode as one that ``* * * usually persists'' rather
than one that ``* * * may persist for an indefinite time.'' For the
same reasons as discussed for standby mode, DOE is proposing the
latter definition.
---------------------------------------------------------------------------
AHAM commented that the off mode definition proposed in the June
2010 TP SNOPR, which is based on IEC Standard 62301 CDV, is identical
to the definition included in IEC Standard 62301 FDIS. (AHAM, Public
Meeting Transcript, No. 20 at p. 41) For the reasons stated above, DOE
is adopting in today's final rule the off mode definition proposed in
the June 2010 TP SNOPR. 75 FR 37594, 37605 (June 29, 2010).
DOE also stated in the June 2010 TP SNOPR that under the proposed
mode definitions, a clothes dryer or room air conditioner equipped with
a mechanical on/off switch that can disconnect power to the display,
control components, or both would be considered as operating in the off
mode when the switch is in the ``off'' position, provided that no other
standby or active mode functions are energized. DOE also stated that an
energized LED or other indication that only shows the user the product
is in the off position would be considered part of off mode under the
proposed definition, provided that no other standby or active mode
functions were energized. If energy is consumed by the appliance in the
presence of a one-way remote control, however, the unit would be
operating in standby mode pursuant to EPCA (42 U.S.C.
6295(gg)(1)(A)(iii)). DOE clarified that the unit would be operating in
standby mode if energy is consumed in the presence of a remote control
that facilitates the activation or deactivation of other functions
(including active mode). 75 FR 37594, 37605-06 (June 29, 2010).
AHAM and Whirlpool commented that they do not support including
one-way remote control energy in the definition of standby mode. AHAM
and Whirlpool stated that although EPCA defines standby mode to include
activation by remote control, one-way remotes do not meet the intent of
the statute. AHAM and Whirlpool further commented that when a standard
remote powers a product ``off,'' the remote actually powers the product
down, not off, such that it can be turned on again via remote control,
and that this would be classified as a standby mode under the EPCA
standby mode definition. According to AHAM and Whirlpool, a one-way
remote turns the product completely off such that it cannot be turned
on again by the remote. Therefore, a one-way remote does not put the
product into a standby mode and should not be incorporated into standby
mode. (AHAM, No. 31 at p. 3; AHAM, Public Meeting Transcript, No. 20 at
pp. 32-33; Whirlpool, No. 27 at p. 1) AHAM added that there are
currently few, if any, one-way remotes in the United States. AHAM
stated that including one-way remotes in the off mode instead of in the
standby mode will encourage manufacturers to design products with one-
way remotes, which could result in decreased energy use. (AHAM, No. 31
at p. 3) AHAM also noted that a number of other governments and
organizations consider one-way remotes as exempt from standby mode
because such remotes save power. AHAM stated that DOE should take the
same approach. (AHAM, Public Meeting Transcript, No. 20 at pp. 33-34)
DOE notes the definition of standby mode proposed in the June 2010
TP SNOPR states that standby mode includes user-oriented or protective
functions to facilitate the activation of other modes (including
activation or deactivation of active mode) by remote switch (including
remote control), internal sensor, or timer. DOE believes that if the
product is consuming energy to power an infrared sensor used to receive
signals from a remote control (while not operating in the active mode),
such a function would be considered part of standby mode, regardless of
whether the remote is classified as ``one-way'' or ``two-way.'' This is
because the function to facilitate the deactivation of another mode by
[[Page 985]]
remote switch (including remote control), internal sensor, or timer is
still active. However, if a ``one-way'' remote control powers the
product down, including turning off any infrared sensors to receive
signals from a remote control, the product would be operating in the
off mode once it is powered down, given that no other standby mode
functions within the product are energized. Depending on whether the
product is capable of operating in both a standby mode and off mode or
just the off mode, the annual hours associated would be allocated as
appropriate, as discussed in section III.B.4.
DOE also notes that section 3.9 of IEC Standard 62301 CDV provides
a definition of ``disconnected mode,'' which is ``the status in which
all connections to mains power sources of the energy using product are
removed or interrupted.'' IEC Standard 62301 CDV also adds a note that
common terms such as ``unplugged'' or ``cut off from mains'' also
describe this mode and that this mode is not part of the low power mode
category. DOE believes there would be no energy use in a ``disconnected
mode'' and therefore is not adopting a definition or testing methods
for such a mode in the DOE test procedure for clothes dryers or room
air conditioners in today's final rule.
3. Adding Specifications for the Test Methods and Measurements for
Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode
Testing
DOE proposed in the December 2008 TP NOPR to establish test
procedures for measuring all standby and off modes associated with
clothes dryers and room air conditioners. 73 FR 74639, 74645 (December
9, 2008). As discussed in section III.B.2, DOE believes that the mode
identified as inactive mode in the December 2008 TP NOPR is the only
significant standby mode for clothes dryers and room air conditioners.
This section discusses product-specific clarifications of the
procedures of IEC Standard 62301 when used to measure standby and off
mode energy use for clothes dryers and room air conditioners.
a. Clothes Dryers
DOE understands that displays on clothes dryers may reduce power
consumption by automatically dimming or powering down after a certain
period of user inactivity. For those clothes dryers for which the power
input in inactive mode varies in this fashion during testing, DOE
proposed in the December 2008 TP NOPR that that the test be conducted
after the power level has dropped to its lower-power state. 73 FR
74639, 74645 (December 9, 2008).
As part of the residential clothes dryer energy conservation
standards rulemaking preliminary analyses, DOE conducted standby mode
and off mode testing on 11 representative residential clothes dryers.
All of the units with electronic controls automatically dimmed or
powered down after a period of user inactivity. Table III.1 shows the
measured duration of the higher-power state for clothes dryers in DOE's
test sample. DOE observed during this testing that the higher-power
state in inactive mode may persist for approximately 5-7 minutes of
user inactivity after the user interface display has been energized for
all products tested.
Table III.1--Clothes Dryer Standby Mode Testing: Duration of Higher-Power State
----------------------------------------------------------------------------------------------------------------
Duration of
Product class Test unit Control type Automatic power-down? higher-power
state (min)
----------------------------------------------------------------------------------------------------------------
Vented Electric, Standard.......... 1 Electromechanical.... N ............
2 Electromechanical.... N ............
3 Electronic........... Y 5
4 Electromechanical.... N ............
5 Electromechanical.... N ............
Vented Electric, Compact (120 V)... 6 Electromechanical.... N ............
Vented Gas......................... 7 Electromechanical.... N ............
8 Electronic........... Y 5
9 Electronic........... Y 5
10 Electronic........... Y 7
11 Electronic........... Y 7
----------------------------------------------------------------------------------------------------------------
Paragraph 5.3.1 of section 5.3 of IEC Standard 62301 specifies, for
products in which the power varies by not more than 5 percent from a
maximum level during a period of 5 minutes, that the user wait at least
5 minutes for the product to stabilize and then measure the power at
the end of an additional time period of not less than 5 minutes.
Paragraph 5.3.2 of IEC Standard 62301 contains provisions for measuring
average power in cases where the power is not stable. In such cases, it
requires a measurement period of no less than 5 minutes, or one or more
complete operating cycles of several minutes or hours. Based on its
testing results shown in Table III.1, however, DOE noted that some
clothes dryers may remain in the higher-power state for the duration of
a 5-minute stabilization period and 5-minute measurement period, and
then drop to the lower-power state that is more representative of
inactive mode. In contrast to IEC Standard 62301, IEC Standard 62301
CDV specifies for each testing method that the product be allowed to
stabilize for at least 30 minutes prior to a measurement period of not
less than 10 minutes. DOE stated in the June 2010 TP SNOPR that this
clarification would allow sufficient time for displays that
automatically dim or power down after a period of user inactivity to
reach the lower-power state prior to measurement. DOE stated that based
on its observation of the automatic power-down time periods during its
testing, the 30-minute stabilization and 10-minute measurement periods
provide a clearer and more consistent testing procedure than the
corresponding times specified in IEC Standard 62301. A testing
procedure using these stabilization and measurement periods would
result in representative measurements among products that may have
varying times before the power drops to a low level. 75 FR 37594, 37607
(June 29, 2010).
DOE also noted in the June 2010 TP SNOPR that allowing a test
period of ``not less than'' or ``at least'' a specified amount of time,
as provided in both IEC
[[Page 986]]
Standard 62301 and IEC Standard 62301 CDV, may result in different test
technicians testing the same product for different periods of time. To
ensure the testing procedures for standby and off mode are clear and
consistent such that different test technicians test the product using
the same procedures, DOE proposed the stabilization period be 30 to 40
minutes, and the test period be 10 minutes. Id.
ALS and AHAM supported DOE's proposal to require a stabilization
period of 30 minutes and a test period of 10 minutes for clothes
dryers. (ALS, No. 24 at p. 1; AHAM, No. 31 at p. 4) AHAM commented that
the purpose of the stabilization period is to reach a steady-state
condition with a power state that may last for an indefinite period of
time. AHAM stated that IEC Standard 62301 includes provisions to wait
to reach the lowest power state without specifying a time to allow an
accurate measurement for all products, so that all products are tested
in the same manner. AHAM noted that this will result in some power
consumption in the higher energy state not being measured, but this
amount is likely to be small due to the small amount of time products
spend in this mode. (AHAM, Public Meeting Transcript, No. 20 at pp. 45-
48) AHAM also commented that a note in section 3.4 of IEC Standard
62301 FDIS states that a transition between modes would not be
considered a mode, and that none of the 123 countries involved with the
IEC process commented on this note. (AHAM, Public Meeting Transcript,
No. 20 at pp. 48-49)
DOE agrees with AHAM's comments that any transition between modes
would not be considered a mode. Therefore, DOE does not intend to
include the measurement of energy consumption for any stabilization or
transition phases when the product is powering down to a lower-power
state. For the reasons stated above, DOE adopts in today's final rule
the requirement that the stabilization period be 30 to 40 minutes and
the test period be 10 minutes, as proposed in the June 2010 TP SNOPR.
75 FR 37594, 37607 (June 29, 2010).
DOE proposed in the December 2008 TP NOPR to adopt the test room
ambient temperature of 73.4 9 [deg]F specified by IEC
Standard 62301 for standby mode and off mode testing. 73 FR 74639,
74645-46 (December 9, 2008). This test room ambient temperature is
slightly different from the ambient temperature currently specified for
DOE's drying performance tests of clothes dryers (75 3
[deg]F). However, the proposed test room ambient temperature conditions
would permit manufacturers who opt to test active, standby, and off
modes in the same test room to use the current ambient temperature
requirements for drying tests, because the latter temperatures are
within the limits specified by IEC Standard 62301. Alternatively, the
proposed temperature specifications would allow a manufacturer who opts
to conduct standby mode and off mode testing separately from drying
tests more flexibility in ambient temperature.
In comments submitted on the June 2010 TP SNOPR, AHAM, ALS, and
Whirlpool supported the proposed test room ambient temperature for
clothes dryer standby and off mode testing. (AHAM, No. 31 at p. 4; ALS,
No. 24 at p. 1; Whirlpool, No. 27 at p. 2) For the reasons stated
above, and in the absence of any comments on this proposal, DOE adopts
the test room ambient temperature of 73.4 9 [deg]F
specified by IEC Standard 62301 for standby mode and off mode testing.
b. Room Air Conditioners
A room air conditioner with a temperature display may use varying
amounts of standby power depending on the digit(s) being displayed. DOE
proposed in the December 2008 TP NOPR to require that test room
temperature be maintained at 74 2 [deg]F, and that the
temperature control setting be 79 [deg]F. 73 FR 74639, 74646 (December
9, 2008). These conditions differ from the cooling performance testing
conditions in the current DOE room air conditioner test procedure. The
cooling performance test conditions are specified as 80 [deg]F on the
indoor side of the test chamber and 95 [deg]F on the outdoor side. In
addition, the cooling performance test conditions do not specify a
temperature control setting. DOE proposed the different test room
conditions in the December 2008 TP NOPR because such conditions would
assure a consistent display configuration, and thus a representative
power consumption, for all room air conditioners under test,
particularly during the off-cycle operation defined in the December
2008 TP NOPR as a standby mode. 73 FR 74646.
As part of the room air conditioner energy conservation standards
rulemaking preliminary analyses, DOE conducted standby mode and off
mode testing on representative room air conditioners. During its
preliminary tests, DOE determined that room air conditioner displays
among the units it tested do not provide any user information in
inactive mode. In addition, DOE determined that the displays among the
units it tested provide indication of time delay or time until start
rather than temperature when the air conditioners are in delay start
mode. As a result, DOE stated in the June 2010 TP SNOPR that the
proposed test chamber ambient conditions would be relevant only for
off-cycle mode. DOE also stated that if the test procedure were limited
to measurement of inactive mode as the single standby mode and an off
mode as discussed in section III.B.2, the proposed close tolerance on
ambient temperature would not be required. 75 FR 37594, 37608 (June 29,
2010). DOE therefore proposed in the June 2010 TP SNOPR to provide
flexibility in the room air conditioner test procedure amendments by
allowing standby mode and off mode testing either in a test chamber
used for measurement of cooling performance or in a separate test room
that meets the specified standby mode and off mode test conditions. The
proposed amendments to the room air conditioner test procedure in the
June 2010 TP SNOPR specify maintaining the indoor test conditions at
the temperature required by section 4.2 of IEC Standard 62301 if tested
in a cooling performance test chamber. The proposed amendments also
specify maintaining the room ambient test conditions at the temperature
required by section 4.2 of IEC Standard 62301 if tested in a separate
test room. Further, if the unit is tested in the cooling performance
test chamber, the proposed amendments in the June 2010 TP SNOPR allow
the manufacturer to maintain the outdoor test conditions either as
specified for the DOE cooling test procedure or according to section
4.2 of IEC Standard 62301 for standby and off mode testing. DOE also
noted that the indoor temperature conditions required by the DOE
cooling performance test procedure fall within the temperature range
specified by section 4.2 of IEC Standard 62301. Id.
AHAM supported DOE's proposed test room ambient temperature for
room air conditioner standby and off mode testing. (AHAM, No. 31 at p.
4) ASAP questioned whether DOE has conducted any testing to determine
if there are any differences in the power measurements between the two
temperature conditions. (ASAP, Public Meeting Transcript, No. 20 at p.
60) DOE is not aware of any data indicating that the ambient
temperature would affect the measured standby or off mode power. For
the reasons stated above, DOE is adopting in today's final rule the
test room ambient temperature proposed in the June 2010 TP SNOPR for
room air conditioner standby and off mode
[[Page 987]]
testing. 75 FR 37594, 37608 (June 29, 2010).
Similar to clothes dryers, DOE proposed in the December 2008 TP
NOPR (73 FR 74639, 74646 (December 9, 2008)) that standby and off modes
for room air conditioners, other than delay start mode, be tested with
a stabilization period of no less than 5 minutes and a measurement
period of no less than 5 minutes for units with stable power,
consistent with paragraph 5.3.1 of section 5.3 of IEC Standard 62301.
In cases where the power was unstable, the provisions of paragraph
5.3.2 would apply, in which the measurement period would be no less
than 5 minutes or one or more complete operating cycles. DOE stated in
the June 2010 TP SNOPR that it does not have any information or data
that would suggest that a 30-minute stabilization period followed by a
10-minute measurement period would produce more representative or
consistent standby and off mode power measurements than the times
proposed in the December 2008 TP NOPR. 75 FR 37594, 37608 (June 29,
2010).
DOE also noted, however, that allowing a test period of ``not less
than'' or ``at least'' a specified amount of time, as provided in IEC
Standard 62301, may result in different test technicians testing the
same product for different periods of time. To ensure that the testing
procedures for standby and off mode are clear and consistent, such that
different test technicians are testing the product using the same
procedures, DOE proposed in the June 2010 TP SNOPR to require that the
stabilization period be 5 to 10 minutes, and the test period be 5
minutes. 75 FR 37594, 37608 (June 29, 2010).
AHAM supported DOE's proposed stabilization period for room air
conditioners. (AHAM, No. 31 at p. 4) For the reasons stated above, DOE
adopts the requirement that the stabilization period be 5 to 10 minutes
and the test period be 5 minutes, as proposed in the June 2010 TP
SNOPR. 75 FR 37594, 37608 (June 29, 2010).
4. Calculation of Energy Use Associated With Standby Modes and Off Mode
Measurements of power consumption associated with each standby and
off mode for clothes dryers and room air conditioners are expressed in
W. The annual energy consumption in each of these modes for a clothes
dryer or room air conditioner is the product of the power consumption
in W and the time spent in that particular mode.
a. Clothes Dryers
Energy use for clothes dryers is expressed in terms of total energy
use per drying cycle. As discussed in section III.D.3, DOE has
determined that it is technically feasible to incorporate measures of
standby and off mode energy use into the overall energy-use metric. (42
U.S.C. 6295(gg)(2)(A)) Therefore, DOE has examined standby and off mode
energy consumption in terms of annual energy use apportioned on a per-
cycle basis. Energy used during a drying cycle (active mode) is
directly measured in the DOE test procedure, although adjustments are
made to the directly measured energy to account for differences between
test and field conditions.
DOE proposed in the December 2008 TP NOPR to adopt a similar
approach for measuring energy consumption during standby and off modes
for clothes dryers. Specifically, to measure energy consumption during
standby and off modes for clothes dryers, DOE proposed in the December
2008 TP NOPR to adopt the current 140 hours associated with drying
(that is, the active mode) and to associate the remaining 8,620 hours
of the year with the standby and off modes. Table III.2 presents the
comparison of the approximate wattages and annual energy use associated
with all modes that DOE proposed in the December 2008 TP NOPR. 73 FR
74639, 74647-48 (December 9, 2008).
Table III.2--DOE Estimate of Annual Energy Use of Clothes Dryer Modes
----------------------------------------------------------------------------------------------------------------
Annual energy use kilowatt-
Mode Hours Typical power W hours (kWh)
----------------------------------------------------------------------------------------------------------------
Active................................. 140 6,907...................... 967.
Delay Start............................ * 34 3.......................... 0.1.
Cycle Finished......................... ** 429 3.......................... 1.
Off and Inactive....................... [dagger] 8,157 0.5 to 3................... 4 to 24.
----------------------------------------------------------------------------------------------------------------
* 5 minutes per cycle x 416 cycles per year.
** 5 percent of remaining time (0.05 x (8,760 - 140 - 34) = 429).
[dagger] 95 percent of remaining time (0.95 x (8,760 -140 - 34) = 8,157).
DOE reviewed comments from interested parties on the December 2008
TP NOPR and stated in the June 2010 TP SNOPR that under the proposed
definitions of standby and off modes, the allocation of annual hours to
inactive and off modes is appropriate. DOE also stated that the June
2010 TP SNOPR did not affect DOE's proposal in the December 2008 TP
NOPR for this allocation of hours. 75 FR 37594, 37609 (June 29, 2010).
In the December 2008 TP NOPR, DOE also proposed an alternative
simplified methodology for allocating annual hours. 73 FR 74639, 74648
(December 9, 2008). The comparison of annual energy use of different
clothes dryer modes shows that delay start and cycle finished modes
represent a negligible percentage of total annual energy consumption.
In addition, for clothes dryers currently on the market, power levels
in these modes are similar to those for off/inactive modes. Therefore,
DOE proposed that all of the non-active hours (which total 8,620) would
be allocated to the inactive and off modes. 73 FR 74648. As discussed
in section III.B.2, DOE determined in the June 2010 TP SNOPR that delay
start and cycle finished modes are not standby modes according to the
proposed definitions. Because the power consumption of clothes dryers
operating in such modes approximates the power levels in off/inactive
modes, DOE stated in the June 2010 TP SNOPR that it would be more
appropriate under a simplified approach to allocate the hours
associated with delay start and cycle finished modes to off/inactive
modes. Therefore, and because DOE did not propose amendments to the
clothes dryer test procedure to measure delay start and cycle finished
power consumption given the negligible power consumption in these
modes, DOE proposed in the June 2010 TP SNOPR to maintain the estimate
of 8,620 hours as the non-active hours that would be allocated to
inactive and off modes for clothes dryers. 75 FR 37594, 37601 (June 29,
2010).
[[Page 988]]
ALS objected to retaining the allocation of clothes dryer hours
proposed in the June 2010 TP SNOPR. ALS stated that the estimates were
based on 416 cycles per year and supported a revision to the hours so
that they are consistent with DOE's proposed 283 cycles per year and
other proposed cycle definition changes. (ALS, No. 24 at p. 2) DOE
notes that the estimate of delay start mode hours developed in the
December 2008 TP NOPR was based on the number of cycles per year in the
existing test procedure (that is, 416 cycles per year). DOE estimated
in the December 2008 TP NOPR that 5 minutes per cycle are spent in
delay start mode. 73 FR 74639, 74647 (December 9, 2008). Under the
amended test procedure in today's final rule, the number of cycles per
year is revised from 416 to 283 cycles per year. Thus, DOE now
estimates that clothes dryers would be in delay start mode
approximately 24 hours per year. DOE also notes that the estimate for
active mode hours presented in the December 2008 TP NOPR was fixed
based on the number of such hours specified in the existing test
procedure (140 hours). 73 FR 74646-7. DOE acknowledges that its
estimate of the number of cycles per year has decreased. As discussed
later in this section, DOE notes that other proposed amendments in
today's final rule, including the changes to the initial RMC, test load
size, and specified water temperature for test load preparation, may
also affect cycle time and the number of active mode hours per year.
DOE is not aware, however, of any data indicating that the number of
active mode hours has changed and, if so, what a more accurate number
might be. Therefore, DOE is not proposing amendments to the number of
active mode hours. In the December 2008 TP NOPR DOE estimated 5 percent
of the remaining hours (that is, not including active mode hours and
delay start mode hours) would be associated with cycle finished mode
and 95 percent associated with inactive/off modes (73 FR 74647). This
would result in revised values of 430 hours for cycle finished mode and
8,166 hours for inactive/off modes. DOE acknowledges that the estimates
for hours in each standby and off mode would change based on the number
of annual clothes dryer cycles. Because DOE is not proposing to measure
delay start and cycle finished modes for clothes dryers, however, and
is instead allocating those hours to inactive/off modes (as discussed
in section III.B.2), the aforementioned revisions to the standby and
off mode hours would not change the total hours allocated to inactive/
off mode because the number of active mode hours is fixed.
ALS commented that DOE must also take into account the active mode
cycle length change if DOE accepts commenters' support for testing the
complete cycle including cool-down in the automatic termination test
cycle. DOE's studies indicated that the cool-down in the automatic
termination test cycle would be required to be tested on 100 percent of
clothes dryers on the market. ALS commented that the Whirlpool-supplied
estimate presented in the June 2010 TP SNOPR indicates an active drying
cycle length of 20 minutes, which ALS stated is far too short if cool-
down period is included. (ALS, No. 24 at p. 2) AHAM also questioned
whether including the cool-down period would change the number of hours
allocated to each mode in the calculations. (AHAM, Public Meeting
Transcript, No. 20 at pp. 99-100) AHAM further commented that it could
be difficult to assign a typical time to cool-down mode because there
are significant differences between clothes dryers in the amount of
time spent in this mode. (AHAM, Public Meeting Transcript, No. 20 at
pp. 100-101) AHAM also commented, however, that cycle times are very
dependent on the initial RMC used and that reducing the initial RMC
value and accounting for cool-down may end up equaling out to the
current 140 hours. (AHAM, Public Meeting Transcript, No. 20 at pp. 103-
104)
As discussed in section III.C.2, DOE is not adopting the amendments
to the clothes dryer test procedure to better account for automatic
cycle termination that were proposed in the June 2010 TP SNOPR.
Therefore, DOE is not amending the test procedure to include the cool-
down period as part of any automatic cycle termination tests. For this
reason, DOE does not believe the estimates for the annual hours spent
in each mode should be revised on the basis of the inclusion of a cool-
down period. With regard to AHAM's comments concerning the reduction in
initial RMC and the effect on cycle times, DOE addresses how that
amendment, along with the other amendments in today's final rule,
affect the clothes dryer cycle time later in this section.
ALS objected to DOE's proposal of 429 hours of ``cycle finished''
mode. ALS commented that while clothes dryers may include an option
alerting the user that the cycle has finished via an alert signal
emitting periodically for up to an hour, ALS does not believe a user
would avoid responding to the alert for an hour each and every cycle.
According to ALS, most users will attend their dried garments within
only a few minutes after the end of the drying cycle, because users
want to complete their laundry chores as quickly as they can.
Additionally, ALS commented that users would utilize this feature for
only one third of clothes dryer cycles if cycle finished mode is an
option. Therefore, ALS stated that ``cycle finished mode'' hours should
be no more than one third of the ``active mode'' hours. ALS further
suggested that DOE conduct consumer studies on user habits for ``cycle
finished'' mode. (ALS, No. 24 at p. 2)
DOE analysis suggests that a cycle finished mode feature (that is,
a status display following operation in active mode indicating to the
user that the cycle is complete) is activated by default at the end of
the drying cycle for most clothes dryers. For this reason, DOE believes
consumers use the cycle finished mode feature for more than one third
of clothes dryer cycles. In addition, DOE does not have any consumer
usage data suggesting that most consumers attend to their laundry
within only a few minutes after the end of the drying cycle. In the
absence of such data, DOE maintains for today's final rule its estimate
from the December 2008 TP NOPR that cycle finished mode represents 5
percent of the remaining time outside of active mode and delay start
mode. This estimate was based on a household survey conducted in 2000
in Australia. 73 FR 74639, 74647 (December 9, 2008). DOE is not aware
of any other consumer usage data regarding cycle finished mode hours.
DOE also notes it is not proposing to measure delay start and cycle
finished modes for clothes dryers and is instead allocating those hours
to inactive/off modes, as discussed in section III.B.2. Therefore, any
revisions to the number of cycle finished mode hours would not change
the total hours allocated to inactive/off mode.
In the December 2008 TP NOPR, DOE proposed to allocate the number
of hours for the combined off and inactive modes entirely to either off
mode or standby mode, as appropriate, if only one of these modes is
possible for the clothes dryer. DOE noted in the October 2008 TP NOPR
that information to guide allocation of the hours for clothes dryers
that have both inactive and off modes is currently unavailable. DOE is
aware of two operational scenarios: (1) A clothes dryer reverts to an
off mode after a specified time in inactive mode; or (2) a clothes
dryer stays in inactive mode unless the user switches the appliance
back to off mode. DOE does not have information regarding the
percentage of clothes dryers being sold
[[Page 989]]
that fall into these categories. Because of this limitation, DOE
proposed in the October 2008 TP NOPR to allocate half of the hours
determined for off/inactive modes to each of the two modes. 73 FR
74648. Because DOE did not receive any comments or additional data
regarding allocation of hours in response to the December 2008 TP NOPR,
the SNOPR did not affect DOE's proposal in the December 2008 TP NOPR
for the allocation of hours between inactive mode and off mode.
The Joint Efficiency Advocates Comment suggested that DOE conduct
research to determine how inactive and off mode hours are commonly
divided up in practice for clothes dryers. The Comment stated that off
mode usage may differ depending on the mode's ``user-friendliness,''
but that this is not accounted for in the current test procedure.
According to the Joint Efficiency Advocates Comment, very few consumers
would take advantage of a ``hidden'' feature such as a small switch on
the back of the unit. Therefore, crediting 50 percent of non-active
mode hours to off mode would allow manufacturers to take advantage of
the energy rating benefit simply by providing the off-mode option,
regardless of how apparent or user-friendly the option was to the
consumer. (Joint Efficiency Advocates Comment, No. 28 at p. 3)
DOE is unaware of any available data for the allocation of those
hours. DOE requested data on the annual hours for various modes,
including the split between standby and off modes in the NOPR (73 FR
74639, 74654) and the June 2010 TP SNOPR (75 FR 37594, 37643), but it
did not receive any information. Therefore, in the absence of data
indicating otherwise, DOE is amending the test procedure in today's
final rule to allocate half of the hours determined for off/inactive
modes to each of the two modes, for those products capable of
functioning in both modes. If data is made available that indicates a
different allocation of hours between inactive and off mode, DOE may
consider revising this allocation.
DOE recognizes that the analysis of the number of annual hours
allocated to each clothes dryer mode is based, in part, on the number
of annual use cycles. As discussed in section III.C.5.a, DOE believes
that the average number of annual cycles is currently 283 rather than
the 416 cycles specified in the current DOE clothes dryer test
procedure. DOE stated in the June 2010 TP SNOPR, however, that it does
not have any information on whether active mode cycle times may have
changed accordingly. 75 FR 37594, 37610 (June 29, 2010). It is possible
that the smaller number of use cycles may correspond to the same amount
of clothing being dried in larger load sizes and thus, potentially,
longer drying times. In the absence of any data supporting this
assumption, however, DOE proposed in the June 2010 TP SNOPR the same
allocation of hours for inactive mode and off mode that were proposed
in the December 2008 TP NOPR, even though DOE proposed fewer annual use
cycles in the June 2010 TP SNOPR. Id.
The California Utilities/NRDC generally supported DOE's calculation
method for standby and off mode for clothes dryers and method of
allocation of yearly clothes dryer hours to standby and off modes
proposed in the June 2010 TP SNOPR. However, the California Utilities/
NRDC urged DOE to reconsider its allocation of 140 hours to active mode
for clothes dryers, particularly in light of DOE's proposed adoption of
283 annual use cycles. The California Utilities/NRDC stated that if DOE
assumes 140 active mode hours per year and 283 cycles per year, this
translates to an average cycle time of about 30 minutes, but that DOE
has not provided any data to support such an assumption. (California
Utilities/NRDC, No. 33 at p. 2)
The California Utilities/NRDC also stated that if DOE relies on
Whirlpool's value of 20 minutes per cycle, then under the new test
procedure, the number of active mode hours would be 94 hours per year
(283 cycles/year x 20 minutes/cycle). The California Utilities/NRDC
stated that there is also evidence to indicate the average length of a
clothes dryer cycle may be higher than 20 minutes, and that therefore
the assumption of 140 hours should be adjusted upwards. The California
Utilities/NRDC added that the report by Ecos Consulting (ECOS)
(prepared for NRDC) summarizes results for four clothes dryers tested
under a variety of cycles, which showed an average recorded cycle
length of 46.5 minutes, corresponding to 219 annual hours (assuming 283
cycles per year). The California Utilities/NRDC noted that these cycles
do not all represent the typical DOE load, but they represent a wide
variety of potential consumer loads and modes of operation which may be
indicative of in-field conditions. (California Utilities/NRDC, No. 33
at pp. 2-3) The Joint Efficiency Advocates Comment similarly stated
that according to the ECOS report for NRDC, the average cycle length is
49.5 minutes for clothes dryers with automatic termination controls,
which corresponds to 233 hours spent in active mode per year. The Joint
Efficiency Advocates Comment recommended basing the number of hours
spent in active mode annually on the cycle length multiplied by the
average number of cycles per year. (Joint Efficiency Advocates Comment,
No. 28 at p. 4)
The Joint Efficiency Advocates Comment and the California
Utilities/NRDC both commented that DOE should try to obtain data from
AHAM or manufacturers on average clothes dryer cycle length and average
yearly hours. (Joint Efficiency Advocates Comment, No. 28 at p. 4;
California Utilities/NRDC, No. 33 at p. 3) The Joint Efficiency
Advocates Comment also added that DOE should test a representative
sample of clothes dryers to develop an accurate estimate of average
cycle length, which could then be multiplied by the revised number of
cycles per year to calculate the annual active mode hours. (Joint
Efficiency Advocates Comment, No. 28 at p. 4)
Whirlpool commented that 140 active mode hours is reasonably
consistent with consumer use and practices, and was not opposed to the
continuing with this known and well-understood estimate. (Whirlpool,
No. 27 at p. 2)
DOE first notes that it is not relying on the 20 minutes per cycle
estimate provided by Whirlpool, for which the testing procedure is not
specified, to estimate the annual active mode hours. DOE notes that the
estimate of 46.5 minutes per cycle, as suggested by the California
Utilities/NRDC and based on data from the ECOS report, uses automatic
termination cycles with clothes loads composed of cotton towels with
initial RMCs ranging from 70 to 100 percent. As discussed below in
section III.C.5.b, DOE amends the test procedure to change the initial
RMC to 57.5 percent, which will result in a cycle time shorter than
that estimated by the California Utilities/NRDC because less moisture
must be removed during the drying cycle. DOE also notes that the Joint
Efficiency Advocates Comment's estimate of 49.5 minutes per cycle was
also based on data from the ECOS report. The estimate differs from the
California Utilities/NRDC's estimate because it included data from an
air dry cycle with a length of 120 minutes, which would not be
appropriate for developing an estimate of clothes dryer cycle time.
This is because an air dry cycle would not be representative of
consumer use. Based on the amendment to the number of annual use
cycles, DOE notes that the cycle length would be approximately 30
minutes (140 annual active mode hours/283 active mode cycles per year).
DOE is unaware, however, of consumer usage data
[[Page 990]]
indicating that the annual active mode hours have changed. For these
reasons, DOE is not amending the test procedure in today's final rule
to revise the number of active mode hours per year.
In summary, DOE is amending the clothes dryer test procedure in
today's final rule to calculate clothes dryer energy use per cycle
associated with inactive and off modes by: (1) Calculating the product
of wattage and allocated hours for inactive and off modes, depending on
which of these modes are possible; (2) summing the results; (3)
dividing the sum by 1,000 to convert from watt-hours (Wh) to kilowatt-
hours (kWh); and (4) dividing by 283 cycles per year. The 8,620 hours
for off/inactive modes shall be allocated entirely to either off mode
or inactive mode, as appropriate, if only one of these modes is
possible for the clothes dryer. If both modes are possible, the hours
shall be allocated to each mode equally as discussed in this section,
and each shall be allocated 4,310 hours.
b. Room Air Conditioners
In the December 2008 TP NOPR, DOE stated it was not aware of
reliable data for hours spent in different standby and off modes in
room air conditioners. Therefore, DOE estimated the annual hours for
standby and off modes and the relative magnitude of annual energy use
in standby and off modes in an example for a representative 8,000 Btu/
hour (Btu/h), 9 EER unit that has delay start, off-cycle, and inactive
modes. 73 FR 74639, 74648-49 (December 9, 2008). DOE's estimates of
annual energy use in each mode are shown in Table III.3.
Table III.3--DOE Estimate of Annual Energy Use of Room Air Conditioner Modes for a Representative Unit With
8,000 Btu/h Capacity and 9 EER
----------------------------------------------------------------------------------------------------------------
Mode Hours Typical power (W) Annual energy use (kWh)
----------------------------------------------------------------------------------------------------------------
Active Cooling......................... 750 889........................ 667.
Delay Start............................ 90 2.......................... 0.2.
Off-Cycle.............................. 440 2.......................... 0.9.
Off and Standby........................ 4,850 0.5 to 2................... 2.5 to 10.
----------------------------------------------------------------------------------------------------------------
In the December 2008 TP NOPR, DOE also proposed an alternative
simplified methodology. Similar to the analysis for clothes dryers,
comparing annual energy use of different room air conditioner modes
shows that delay start and off-cycle modes represent a small percentage
of annual energy use in the active mode, and that the power consumption
in those standby modes is distinct from but comparable to those for
off/inactive modes. Thus, DOE proposed adopting an alternative approach
allocating the non-active hours as if the room air conditioner has only
the inactive standby mode. A total of 5,115 hours would be allocated to
the standby and off modes (8,760 x 0.75 - 750 - 705 = 5,115).\21\ 73 FR
74639, 74649 (December 9, 2008). For these reasons, and because DOE did
not propose amendments to the room air conditioner test procedure to
measure delay start and off-cycle power consumption given the
negligible power consumption in these modes, DOE proposed in the June
2010 TP SNOPR allocating 5,115 non-active hours to inactive and off
modes for room air conditioners. In addition, for the same reasons as
discussed for delay start and cycle finished modes for clothes dryers,
DOE stated in the June 2010 TP SNOPR that the delay start and off-cycle
hours for room air conditioners should be allocated to inactive and off
modes even though it has determined that delay start and off-cycle
modes are not standby modes. 75 FR 37594, 37610-11 (June 29, 2010).
---------------------------------------------------------------------------
\21\ Multiplying by 0.75 eliminates hours associated with
unplugged hours, assumed for half of the hours of the year for half
of room air conditioners as described in the December 2008 TP NOPR
(73 FR 74639, 74648 (Dec. 9, 2008)); 750 = Cooling (active mode)
hours; 705 = Fan-only (active mode) hours.
---------------------------------------------------------------------------
The California Utilities/NRDC supported DOE's proposed calculation
method for standby mode and off mode annual hours for room air
conditioners. They added that lacking new data on typical room air
conditioner operation in standby and off modes, DOE's proposed method
of allocating hours to standby and off modes is appropriate.
(California Utilities/NRDC, No. 33 at p. 3)
The Joint Efficiency Advocates Comment and ACEEE both commented
that the 705 fan-only mode hours presented in the June 2010 TP SNOPR
should be accounted for in the energy consumption calculations. (Joint
Efficiency Advocates Comment, No. 28 at pp. 2-3; ACEEE, Public Meeting
Transcript, No. 20 at pp. 73-74) The Joint Efficiency Advocates Comment
stated that fan-only active mode could be tested by duplicating the
existing cooling-mode test method with the exception of running the
compressor. The Joint Efficiency Advocates Comment further stated that
there is no data to support the assumption that consumers generally run
their room air conditioners in fan-only mode for 705 hours a year.
Although the Joint Efficiency Advocates cannot find any data on the
number of hours typically used in fan-only mode, they commented that
the lack of data indicates that this mode is not used as commonly as
assumed in the June 2010 TP SNOPR. The Joint Efficiency Advocates
Comment stated that because of DOE's allocation, their second
recommendation is that the 705 hours be reallocated in such a way as to
represent the current consumer usage of fan-only mode. The Joint
Efficiency Advocates Comment also noted that due to the lack of data on
the use of this mode, DOE should perform additional research and data
collection. If no data collection is able to be performed, DOE should
reallocate these hours to active cooling and/or inactive modes, which
would reflect the lack of data supporting the average consumer use of
any fan-only mode. (Joint Efficiency Advocates Comment, No. 28 at pp.
2-3)
The California Utilities/NRDC stated that fan-only operation should
be included in active mode, but that it is not clear whether fan-only
mode is accounted for in the proposed active mode test procedure. The
California Utilities/NRDC stated that if fan-only mode is considered a
portion of active mode, and if energy use in fan-only mode is measured
in the current test procedure, then the number of hours in active mode
should be revised to include fan-only mode. The California Utilities/
NRDC stated that if fan-only mode is considered separate from active
mode, and DOE allocates a portion of yearly hours to fan-only mode,
then DOE must account for the energy use in this mode and incorporate
it into its
[[Page 991]]
calculation of CEER. The California Utilities/NRDC requested that DOE
clarify its approach towards fan-only mode, provide a test procedure to
measure or otherwise account for fan-only energy use, and incorporate
the energy use of this mode in the CEER. (California Utilities/NRDC,
No. 33, at pp. 3-4)
Earth Justice (EJ) commented that not measuring energy consumption
when operating in fan[hyphen]only mode would violate EPCA's minimum
standards for test procedures (42 U.S.C. Sec. 6293(b)(3)) EJ commented
that by proposing to ignore energy consumption in fan[hyphen]only mode,
DOE has proposed to ignore nearly half the active mode operating hours
of room air conditioner units. EJ added that because fan[hyphen]only
mode accounts for such a large percentage of total active mode
operating hours, a test procedure that ignores fan[hyphen]only
operation would not depict ``a representative average use cycle or
period of use'' for room air conditioners. (EJ, No. FDMS D0039 at p. 2)
DOE understands that a fan-only active mode could include two
different kinds of modes: (1) A mode in which the room air conditioner
does not turn off the fan when the thermostat automatically cycles the
compressor off during cooling mode; and (2) a user-selected
``ventilation'' mode that does not include the cooling. DOE recognizes
that the energy use associated with fan-only mode is not insignificant.
As noted in the December 2008 TP NOPR, however, DOE is not aware of any
reliable consumer usage data for hours spent in different room air
conditioner modes, including fan-only mode. 73 FR 74639, 74648
(December 9, 2008). DOE requested data in the December 2008 TP NOPR on
the estimate of hours for different room air conditioner modes, but did
not receive any such data. DOE notes that developing a test procedure
to accurately measure the contribution of fan-only active mode would
require additional testing and analysis to determine appropriate
testing conditions and measurement methods for both types of fan-only
modes described above. In addition, field use surveys of consumer usage
patterns over multiple cooling seasons and a climate-based load
analysis to develop an estimate of fan-only mode hours that is
representative of consumer use would need to be conducted. DOE may
consider amendments to address fan-only active mode in a future
rulemaking as data becomes available. DOE welcomes information on
appropriate testing procedures for accurately measuring fan-only active
mode and data on consumer usage habits.
Typically, room air conditioners with remote control can be
controlled whenever they are plugged in; hence, these units do not have
provision for an off mode in addition to inactive mode. However, if a
room air conditioner allows the user to switch off remote control
operation, such a product would be capable of both off and inactive
modes. DOE notes that information to guide allocation of the hours for
room air conditioners that have both inactive and off modes is
currently unavailable. For these units, DOE proposed in the December
2008 TP NOPR that the off/inactive hours be allocated equally to the
off and inactive modes for such a product. Otherwise, for units that
are capable of operation in only off or inactive mode, DOE proposed
that all of the hours be allocated to the appropriate mode. 73 FR
74649. In the absence of comments on or additional data regarding
allocation of hours, the June 2010 TP SNOPR did not affect DOE's
proposal in the December 2008 TP NOPR for the allocation of hours
between inactive mode and off mode. 75 FR 37594, 37611 (June 29, 2010).
Similar to the comment noted above for clothes dryers, the Joint
Efficiency Advocates Comment suggested that DOE conduct research to
determine how consumers allocate inactive and off mode hours for room
air conditioners. The Joint Efficiency Advocates Comment stated they
are concerned that off-mode usage may be affected by the mode's ``user-
friendliness,'' but that this is not accounted for in the current test
procedure. (Joint Efficiency Advocates Comment, No. 28 at p. 3)
DOE requested consumer usage data on the split of hours between
inactive mode and off mode if both modes are possible for a product but
did not receive any data. In the absence of data indicating that an
equal split of hours is not representative of consumer usage habits,
DOE adopts in today's final rule the allocation of inactive/off mode
hours proposed in the June 2010 TP SNOPR. The number of hours will be
allocated equally to the inactive and off modes for a product capable
of both modes. If data are made available indicating a different number
of hours spent in inactive and off modes, DOE may consider amending the
test procedure.
In summary, DOE amends the room air conditioner test procedure in
today's final rule to calculate room air conditioner annual energy use
associated with inactive and off modes by: (1) Calculating the products
of wattage and allocated hours for inactive and off modes, depending on
which of these modes is possible; (2) summing the results; and (3)
dividing the sum by 1,000 to convert from Wh to kWh. The 5,115 hours
for off/inactive modes shall be allocated entirely to either off mode
or inactive mode, as appropriate, if only one of these modes is
possible for the room air conditioner. If both modes are possible, the
hours shall be allocated to each mode equally as discussed in this
section, and each shall be allocated 2,557.5 hours.
5. Measures of Energy Consumption
The DOE test procedures for clothes dryers and room air
conditioners currently provide for the calculation of several measures
of energy consumption. For clothes dryers, the test procedure
incorporates various measures of per-cycle energy consumption,
including: (1) Total per-cycle electric dryer energy consumption; (2)
per-cycle gas dryer electrical energy consumption; (3) per-cycle gas
dryer gas energy consumption; and (4) total per-cycle gas dryer energy
consumption expressed, which includes both the electrical and gas
energy consumption for gas clothes dryers. 10 CFR part 430, subpart B,
appendix D, sections 4.1-4.6 The test procedure also provides an EF,
which is equal to the clothes load in pounds divided either by the
total per-cycle electric dryer energy consumption or by the total per-
cycle gas dryer energy consumption expressed in kWh. 10 CFR 430.23(d)
For room air conditioners, the test procedure calculates annual energy
consumption in kWh and an EER. 10 CFR 430.23(f)
Under 42 U.S.C. 6295(gg)(2)(A), EPCA directs that the test
procedures for all covered products be amended pursuant to section 323
to include standby mode and off mode energy consumption, with such
energy consumption integrated into the overall energy efficiency,
energy consumption, or other energy descriptor for each covered
product, unless DOE determines that--(i) the current test procedures
for a covered product already fully account for and incorporate the
standby mode and off mode energy consumption of the covered product; or
(ii) such an integrated test procedure is technically infeasible for a
particular covered product, in which case DOE must prescribe a separate
standby mode and off mode energy-use test procedure for the covered
product, if technically feasible.
In the December 2008 TP NOPR, DOE explored whether the existing
measures of energy consumption for clothes dryers and room air
conditioners can be combined with standby mode and off mode energy use
to form a single metric. DOE tentatively determined in the
[[Page 992]]
December 2008 TP NOPR that it is technically feasible to integrate
standby mode and off mode energy consumption into the overall energy
consumption metrics for clothes dryers and room air conditioners. 73 FR
74639, 74650 (December 9, 2008). For the reasons presented in the
December 2008 TP NOPR, DOE proposed integrated metrics addressing
active, standby, and off modes for clothes dryers and room air
conditioners, as discussed below.
a. Clothes Dryers
In the December 2008 TP NOPR, DOE proposed to establish the
following measures of energy consumption for clothes dryers that
integrate energy use of standby and off modes with active mode energy
use of the products. ``Per-cycle integrated total energy consumption
expressed in kWh'' would be defined as the sum of per-cycle standby and
off mode energy consumption and either total per-cycle electric dryer
energy consumption or total per-cycle gas dryer energy consumption
expressed in kWh, depending on which type of clothes dryer is involved.
``Integrated energy factor'' (IEF) would be defined as the (clothes
dryer test load weight in lb)/(per-cycle integrated total energy in
kWh). 73 FR 74639, 74650 (December 9, 2008).
b. Room Air Conditioners
In the December 2008 TP NOPR, DOE proposed to establish the
following measures of energy consumption for room air conditioners that
integrate energy use of standby and off modes with active mode energy
use of the products. ``Integrated annual energy consumption'' would be
defined as the sum of annual energy consumption and standby and off
mode energy consumption. ``Integrated energy efficiency ratio'' (IEER)
would be defined as (cooling capacity in Btu/hr x 750 hours average
time in cooling mode)/(integrated annual energy consumption x 1,000 Wh
per kWh). Id.
DOE noted in the June 2010 TP SNOPR that the Air-Conditioning,
Heating and Refrigeration Institute (AHRI) Standard 340/360-2007,
``Performance Rating of Commercial and Industrial Unitary Air-
Conditioning and Heat Pump Equipment,'' (AHRI Standard 340/360) and the
ASHRAE Standard 90.1-2007, ``Energy Standard for Buildings Except Low-
Rise Residential Buildings,'' (ASHRAE 90.1) both published in 2007,
included an IEER metric. This metric, also named ``Integrated Energy
Efficiency Ratio,'' is meant to rate the part-load performance of the
air-conditioning equipment under test. 75 FR 37594, 37612 (June 29,
2010). Manufacturers of the equipment covered by these standards
currently list IEER ratings in their product literature and in the AHRI
certified product directory. This IEER metric does not integrate
standby mode and off mode energy use, unlike the IEER metric that was
proposed in the December 2008 TP NOPR. The IEER metric used in AHRI
Standard 340/360 and ASHRAE 90.1 was established prior to the IEER
proposed in this rulemaking. Therefore, DOE proposed for the June 2010
TP SNOPR to revise the name of the integrated metrics incorporating
standby mode and off mode energy use to ``combined'' metrics for both
clothes dryers and room air conditioners. Id.
DOE has received no comments objecting to this proposal. Therefore,
for the reasons stated above, DOE incorporates into the DOE test
procedures the ``per-cycle combined total energy consumption expressed
in kWh'' and ``combined energy factor'' (CEF) for clothes dryers and
``combined annual energy consumption'' and ``combined energy efficiency
ratio'' (CEER) for room air conditioners in today's final rule as
proposed in the June 2010 TP SNOPR. Id.
In the June 2010 TP SNOPR, DOE did not propose to amend the annual
energy cost calculations in 10 CFR 430.23 for clothes dryers and room
air conditioners to include the cost of energy consumed in standby and
off modes. The Joint Efficiency Advocates Comment stated that DOE
should include standby and off mode energy costs in the annual energy
cost calculation in order to better represent actual energy costs. The
Joint Efficiency Advocates Comment noted that minimum and maximum
energy costs prescribed for the EnergyGuide label will need to be
revised when new energy conservation standards go into effect. They
suggested that the energy consumed in standby and off modes should be
able to be incorporated into the revised minimum and maximum energy
costs. (Joint Efficiency Advocates Comment, No. 28 at p. 4)
EPCA states that any amended test procedures shall be reasonably
designed to produce test results that measure energy efficiency, energy
use, water use, or estimated annual operating cost of a covered
product. (42 U.S.C. 6293(b)(3)) EPCA also directs DOE to amend its test
procedures to include measures of standby mode and off mode energy
consumption and to integrate such energy consumption into a single
energy descriptor for that product. If that is technically infeasible,
DOE must prescribe a separate standby mode and off mode energy-use test
procedure, if technically feasible. (42 U.S.C. 6295(gg)(2)(A)) As
discussed in section I, EPCA requires that all representations related
to standby mode and off mode energy use or efficiency or cost of energy
consumed of both clothes dryers and room air conditioners made 180 days
after today's final rule be based upon the standby and off mode
requirements of the amended test procedures. (42 U.S.C. 6293(c)(2))
Additionally, EPCA requires that any revisions to the labels for room
air conditioners include disclosure of the estimated annual operating
cost (determined in accordance with DOE's test procedures prescribed
under section 6293 of EPCA), unless the Secretary determines that
disclosure of estimated annual operating cost is not technologically
feasible, or the FTC determines that such disclosure is not likely to
assist consumers in making purchasing decisions or is not economically
feasible. (42 U.S.C. 6294(c)(1)) DOE understands that the FTC would
develop any revised labeling requirements for referencing a revised
annual energy cost calculation that integrates the cost of energy
consumed in standby and off modes.
For these reasons, DOE agrees with interested parties that the
annual energy cost calculations in 10 CFR 430.23 for clothes dryers and
room air conditioners should be amended to include the cost of energy
consumed in standby and off modes. Therefore, DOE amends the clothes
dryer test procedure to revise the estimated annual operating cost
calculation to integrate standby and off mode energy use, and to
require that the estimated annual operating cost be obtained by
multiplying the average number of annual use cycles by the sum of the
per-cycle active mode energy consumption and the per-cycle standby and
off mode energy consumption and by the representative average unit cost
of electrical energy, natural gas, or propane, as appropriate, in
dollars per kWh or Btu, as provided by DOE. Similarly, DOE amends the
room air conditioner test procedure to revise the annual energy cost
calculation to integrate standby and off mode energy use, and to
require that the annual energy cost be obtained by multiplying the
combined annual energy consumption by the representative average unit
cost of electrical energy in dollars per kWh, as provided by DOE.
[[Page 993]]
C. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures
1. Correction of Text Describing Energy Factor Calculation for Clothes
Dryers
DOE proposed in the December 2008 TP NOPR to correct errors in
specific references used in the current DOE test procedure. 73 FR
74639, 74650 (December 9, 2008). In particular, the reference to
sections 2.6.1 and 2.6.2 of 10 CFR part 430, subpart B, appendix D in
the calculation of EF for clothes dryers found at section 430.23(d)(2)
should refer instead to sections 2.7.1 and 2.7.2. Section 2.6 provides
instructions for the test clothes to be used in energy testing of
clothes dryers, whereas section 2.7 provides instructions on test
loads. The EF of clothes dryers is measured in lb of clothes per kWh.
Because the EF calculation requires the weight of the test load, DOE
proposed in the December 2008 TP NOPR to correct these references in 10
CFR 430.23(d)(2). DOE did not receive any comments opposing this
correction. Therefore, for the reasons stated above, DOE adopts the
correction as proposed in the December 2008 TP NOPR.
2. Automatic Cycle Termination for Clothes Dryers
DOE considered amendments to the clothes dryer test procedure to
accurately measure the benefits of automatic cycle termination. DOE
considered industry and international clothes dryer test procedures and
conducted testing and analysis to develop proposed amendments to the
definitions of product types, test load preparation, the test
measurement cycle and settings, and the calculation of results.
October 2007 Framework Document
In the October 2007 Framework Document, DOE stated that it believes
that the clothes dryer test procedure may not adequately measure the
benefits of automatic cycle termination, in which a sensor monitors
either the exhaust air temperature or moisture in the drum to determine
the length of the drying cycle. (Framework Document, STD No. 1 at p. 5)
The calculation of EF in the current clothes dryer test includes a
field use scaling factor applied to the per-cycle drying energy
consumption to account for the over-drying energy consumption
associated with different termination technologies. Gas or electric
clothes dryers with time termination control (in other words, those
clothes dryers equipped with only a timer to determine the end of a
drying cycle) are assigned an field use of 1.18. Clothes dryers with
automatic termination are assigned an field use of 1.04. DOE
established the 1.18 field use factor for clothes dryers with time
termination control in the September 1977 TP Final Rule based on
analysis of data from a field use survey conducted by Oklahoma Gas and
Electric Company involving 64 homes as well as data provided by AHAM on
the measured energy consumption per-cycle under the DOE test procedure
to account for the differences between the energy consumption
measurements derived from laboratory test procedures and those obtained
from actual consumer use. 42 FR 46145, 46146 (September 14, 1977). DOE
established the field use factor of 1.04 for clothes dryers with
automatic termination in the May 1981 TP Final Rule based on analysis
of data from a field use survey conducted by AHAM involving 72 homes as
well as an analysis conducted by NIST of field test data on automatic
termination control dryers. Analysis of this data showed that clothes
dryers equipped with an automatic cycle termination feature consume
less energy than timer dryers by reducing over-drying. 46 FR 27324 (May
19, 1981). Based on these field use factors, clothes dryers with
automatic cycle termination control are determined to reduce energy
consumption by 12 percent compared to a similar clothes dryer with time
termination control, which consume more energy due to over- or under-
drying. (Under-drying can result in consumers running an additional
drying cycle.) Currently, the test procedure specifies a single field
use factor for clothes dryers equipped with automatic termination.
However, it does not distinguish between the type of sensing control
system (for example, temperature-sensing or moisture-sensing controls)
and the sophistication and accuracy of the control system.
Consideration of Industry and International Clothes Dryer Test
Procedures
DOE proposed in the June 2010 TP SNOPR that the benefit of
automatic cycle termination should be accurately measured to account
for any over- or under-drying. Therefore, DOE considered potential
amendments to the DOE test procedure to account for automatic cycle
termination. For the June 2010 TP SNOPR, DOE investigated industry and
international clothes dryer test procedures for measuring the
effectiveness of automatic cycle termination and conducted limited
testing to analyze over-drying energy consumption and the applicability
of such procedures to the DOE clothes dryer test procedure. 75 FR
37594, 37613 (June 29, 2010). DOE reviewed AHAM's most recently update
to its industry test standard, AHAM HLD-1-2009, ``Household Tumble Type
Clothes Dryers'' (AHAM Standard HLD-1-2009). The update contains
provisions for measuring the over-drying energy consumption for clothes
dryers that use automatic cycle termination and provides separate
testing procedures timer dryers. DOE also reviewed the international
test standards EN Standard 61121 \22\ and AS/NZS Standard 2442.1, both
of which address methods for testing clothes dryers with automatic
termination sensor technologies. 75 FR 37594, 37613 (June 29, 2010).
---------------------------------------------------------------------------
\22\ EN Standard 61121 is used by European Union (EU) member
countries. DOE believes this test standard is functionally
equivalent to IEC Standard 61121, which is used by China, among
other countries. Both test procedures contain identical testing
methods and procedures.
---------------------------------------------------------------------------
DOE stated in the June 2010 TP SNOPR that it believes that AHAM
Standard HLD-1-2009 does not provide an appropriate method for
comparing the amount of over-drying for a timer dryer to that of an
automatic termination-sensing dryer. This is because the timer dryer
test allows only for drying the test load to as low as 4-percent RMC,
whereas the automatic cycle termination test allows for drying the test
load to any value below 6-percent RMC, including lower than 4-percent
RMC. 75 FR 37613-14. If the automatic termination control dryer were to
dry the test load to a value lower than 4-percent, the measured energy
consumption may be greater than the energy consumption measured for the
same clothes dryer using the timer dryer test cycle which only measures
the energy required to dry the load to 4-percent RMC. However, as
discussed above in this section, DOE believes that automatic
termination control dryers reduce energy consumption compared to timer
dryers based on analysis of data from the AHAM field use survey and
analysis of field test data conducted by NIST. 46 FR 27324 (May 19,
1981).
DOE also stated in the June 2010 NOPR that although EN Standard
61121 provides test methods to use for both timer dryers and automatic
termination control dryers, it does not provide any methodology to
measure the energy consumed over- or under-drying the test load beyond
a certain RMC for each type of clothes dryer. The provisions in EN
Standard 61121 require the test load be dried to the same allowable
range for both timer dryers and automatic termination dryers. According
to the test procedures in EN Standard 61121, if the
[[Page 994]]
test load for either a timer dryer or an automatic termination control
dryer is dried to the same RMC, the clothes dryers consume the same
amount of energy and would be rated as using the same amount of energy
in real-world use. 75 FR 37594, 37614 (June 29, 2010). However, for the
same reasons discussed above in this section, DOE believes that
automatic termination control dryers reduce energy consumption compared
to timer dryers.
DOE stated in the June 2010 TP SNOPR that AS/NZS Standard 2442
provides testing methods and procedures that account for the amount of
over-drying beyond a specified RMC associated with automatic
termination control dryers by measuring any additional energy consumed
drying the test load beyond the specified RMC. DOE also stated that AS/
NZS Standard 2442 effectively takes into consideration the accuracy of
different automatic termination sensor technologies by not providing a
fixed field use factor in the energy consumption calculation for
automatic cycle termination. Because the test procedure measures the
energy consumed drying the test load beyond the specified RMC, a
clothes dryer with an accurate automatic termination sensor technology
that dries the clothes load to close to the specified RMC would consume
less energy than a clothes dryer with a sensor technology that dries
the load well beyond the specified RMC (that is, close to bone dry).
DOE also stated that it believes that the testing methods provide an
accurate and representative method for comparing the energy consumption
between timer dryers and automatic termination control dryers by
providing methods for measuring energy use that account for over-drying
for both types of clothes dryers. For these reasons, DOE proposed to
amend the DOE test procedure for clothes dryers to incorporate the
individual test procedures for timer dryers and automatic termination
control dryers in AS/NZS Standard 2442, with modifications as
appropriate for the DOE test procedure. 75 FR 37594, 37615 (June 29,
2010).
After the June 2010 TP SNOPR was published, AHAM, ACEEE, NRDC,
Alliance to Save Energy (ASE), Alliance for Water Efficiency (AWE),
ASAP, Northwest Power and Conservation Council (NPCC), Northeast Energy
Efficiency Partnerships (NEEP), Consumer Federation of America (CFA),
and National Consumer Law Center (NCLC) (hereafter the ``Joint
Petitioners'') jointly submitted the ``Agreement on Minimum Federal
Efficiency Standards, Smart Appliances, Federal Incentives and Related
Matters for Specified Appliances,'' (Joint Petitioners, No. 25,
hereinafter the ``Joint Petition'') and the ``Joint Stakeholders
Comments On The Supplementary Notice Of Proposed Rulemaking On Test
Procedures For Clothes Dryers And Room Air Conditioners'' (Joint
Petitioners, No. 30). The Joint Petitioners, AHAM, the Joint Efficiency
Advocates Comment, and the California Utilities/NRDC supported DOE's
proposal to account for the effectiveness of automatic termination
controls. (Joint Petitioners, No. 25 at p. 14; Joint Petitioners, No.
30 at p. 5; AHAM, No. 31 at p. 5; Joint Efficiency Advocates Comment,
No. 28 at p. 1; California Utilities/NRDC, No. 33 at p. 4) The
Consumers Union (CU) concurred with this comment. (CU, No. 29 at pp. 1-
2, 3) The Joint Efficiency Advocates Comment added that data presented
by DOE show that over-drying energy consumption can be significant (as
much as 0.6 kWh per cycle). (Joint Efficiency Advocates Comment, No. 28
at p. 1; California Utilities/NRDC, No. 33 at p. 4) The Joint
Petitioners and AHAM commented that if DOE decides to adopt the AS/NZS
Standard 2442 as proposed, they request that DOE identify the specific
sections it is adopting. (Joint Petitioners, No. 30 at p. 6; AHAM, No.
31 at p. 6)
Product Definitions
Based on the definitions in EN Standard 61121 and AS/NZS Standard
2442, DOE proposed in the June 2010 TP SNOPR to define ``timer dryer''
as ``a dryer which can be preset to carry out at least one sequence of
operations to be terminated by a timer, but may also be manually
controlled.'' It also proposed to define ``automatic termination
control dryer'' as ``a dryer which can be preset to carry out at least
one sequence of operations to be terminated by means of a system
assessing, directly or indirectly, the moisture content of the load. An
automatic termination control dryer with supplementary timer shall be
tested as an automatic termination control dryer.'' 75 FR 37594, 37615
(June 29, 2010).
AHAM suggested that the definition of a timer dryer may need to
specify that it is a clothes dryer that ``does not include any
automatic termination function.'' AHAM commented that almost any
automatic termination dryer is also going to have a timer function
because of consumer demands, and this extra explanation would make it
clear that it refers to only a timer dryer. (AHAM, Public Meeting
Transcript, No. 20 at pp. 84, 85-86) AHAM also commented that the last
sentence of the automatic termination dryer definition should be
modified and used to clarify the timer dryer definition. (AHAM, Public
Meeting Transcript, No. 20 at p. 86) ALS also commented that it offers
a product with both an automatic termination function and a timer
function that uses only electromechanical controls. (ALS, Public
Meeting Transcript, No. 20 at p. 81)
As discussed later in this section, DOE is not adopting in today's
final rule the amendments for automatic cycle termination proposed in
the June 2010 TP SNOPR. Therefore it is not adopting the definitions
for timer dryer and automatic termination dryer presented above. DOE
agrees, however, that the reference to timer dryers in the test
procedure (in the application of field use factors in section 4,
``Calculation of Derived Results From Test Measurements'') should
clarify that clothes dryers with time termination control systems do
not include any automatic termination control functions. DOE also
believes the reference to clothes dryers with automatic control systems
in the application of the field use factors should clarify that clothes
dryers with automatic control systems that also have a supplementary
timer control receive the 1.04 field use factor. For these reasons, DOE
amends section 4 of the clothes dryer test procedure to specify that
the field use factor equals 1.18 for clothes dryers with time
termination control systems only, without any automatic termination
control functions and 1.04 for clothes dryers with automatic control
systems that meet the requirements of the definition for automatic
control systems in 1.4, 1.14 and 1.18, including those that also have a
supplementary timer control.
The Joint Petitioners and AHAM also commented that DOE should
revise section 1.11 of 10 CFR 430 subpart B, appendix D. The amendment
would more clearly account for electronic controls by specifying that a
preferred automatic termination control setting (that is, a setting
recommended by manufacturers) can also be indicated by a visual
indicator (in addition to the mark or detent), and would read ``* * *
mark, visual indicator or detent which indicates a preferred * * *''
(Joint Petitioners, No. 25 at p. 14; Joint Petitioners, No. 30 at p. 8;
AHAM, No. 31 at p. 11) DOE agrees a clarification should be added to
the definition of ``automatic termination control'' that a mark,
detent, or other visual indicator which indicates a preferred automatic
termination control setting must be present if the dryer is to be
classified as having an automatic termination
[[Page 995]]
control. Therefore, DOE amends this definition in today's final rule to
make this revision.
NRDC commented that most new clothes dryers have both automatic and
timer termination functions, so the test procedure should test both of
these drying modes rather than only the automatic termination mode.
(NRDC, Public Meeting Transcript, No. 20 at pp. 86-87) The Joint
Petitioners and AHAM commented that for clothes dryers that have both
an automatic termination control cycle and a timer cycle, only the
auto-termination cycle should be tested. (Joint Petitioners, No. 30 at
p. 6; AHAM, No. 31 at p. 5) Whirlpool commented that testing the
automatic termination control cycle is most appropriate, as it
represents the vast majority of actual consumer use. Although the
majority of consumers also want a timed dry cycle, they use it only
about 10 percent of the time. (Whirlpool, No. 27 at p. 3) DOE is not
aware of any consumer usage data indicating that timed dry cycles on a
clothes dryer with automatic termination controls are used by consumers
for a significant portion of their annual use cycles. In addition, as
discussed below, DOE is not adopting in today's final rule the
amendments to better account for automatic cycle termination proposed
in the June 2010 TP SNOPR. For these reasons, DOE is not amending the
test procedure to measure both automatic termination control and timed
dry cycles for products capable of both methods.
Test Load Preparation
In the June 2010 TP SNOPR, DOE proposed to amend sections 2.7.1,
``Compact size dryer load,'' and 2.7.2, ``Standard size dryer load'' of
the DOE test procedure for clothes dryers, which contain provisions for
test load preparation. The amendment would add at the end of both
sections the following requirement: ``Make a final mass adjustment,
such that the moisture content is 47 percent 0.33 percent
by adding water uniformly to the load in a very fine spray.'' 75 FR
37594, 37615 (June 29, 2010). The 0.33 percent allowable
RMC range is equivalent to the allowable range specified in AS/NZS
Standard 2442.1 (190 percent 0.02 kg of the bone dry
weight) for a 7-lb test load. DOE believes the specified range produces
repeatable EF measurements. Allowing a larger allowable range in RMC
would increase the range in the moisture required to be dried during
the test cycle and result in increased variability in the measured EF.
DOE also proposed that the procedure for dampening and extracting water
from the test load specified in the current test procedure be changed.
The test procedure would be changed to require that the moisture
content of the test load be between 42 and 47 percent of the bone-dry
weight of the test load, and would serve as an initial preparation step
prior to the final mass adjustments to obtain a test load with an RMC
of 47 percent proposed above in this paragraph. DOE noted that it
proposed to use a nominal initial RMC of 47 percent based on the
proposed amendment to change the initial RMC from 70 percent to 47
percent, as discussed in section III.C.5.b. DOE noted in the June 2010
TP SNOPR that if it does not adopt this proposed amendment to change
the nominal initial RMC, it would instead propose an amendment stating
to first prepare the test load to 65- to 70-percent RMC and make
adjustments to the moisture content to get 70-percent
0.33-percent initial RMC. 75 FR 37594, 37615 (June 29, 2010). DOE did
not receive any comments on this alternate proposal.
In the June 2010 TP SNOPR, DOE noted that section 2.7 of the
existing clothes dryer test procedure regarding test load preparation
requires that the test load be agitated in water whose temperature is
100 [deg] F 5 [deg] F. DOE recognizes that some
residential clothes washers may use a default cold rinse cycle at the
end of the wash cycle, which sections 2.6.1.2.1 and 2.6.3.1 of the
current DOE clothes washer test procedure specify to be 60 [deg] F
5 [deg] F. DOE stated in the June 2010 TP SNOPR that it
does not have any data indicating whether a different water temperature
for clothes dryer test load preparation would be more representative of
current consumer usage habits, but that if consumer usage data is made
available that indicates a 60 [deg] F 5[deg] F water
temperature is more representative of consumer usage, DOE may adopt an
alternate approach specifying a 60 [deg] F 5 [deg] F water
temperature for test load preparation in section 2.7 of the DOE clothes
dryer test procedure. In addition, DOE stated that it is unaware of how
changes to the water temperature for clothes dryer test load
preparation would affect the measured efficiency as compared to the
existing test procedure. Id.
ALS, the California Utilities/NRDC, and the Joint Efficiency
Advocates Comment all stated that the water temperature for clothes
dryer test load preparation should be changed to be representative of
existing national consumer usage. (ALS, No. 24 at p. 4; California
Utilities/NRDC, No. 33 at p. 5; Joint Efficiency Advocates Comment, No.
28 at pp. 1-2)
ALS commented that the water temperature for clothes dryer test
load preparation has been lowered in response to clothes washer energy
conservation standard changes. Manufacturers have eliminated most warm
rinses and offer the user the option of using all cold rinses. ALS
stated that it is reasonable to assume that today, most clothes loads
placed in a clothes dryer are from clothes washers that use cold rinse.
Therefore, ALS supported revising the clothes dryer test procedure to
utilize the 60 [deg] F 5 [deg] F water temperature
specified in the DOE clothes washer test procedure for the cold water
supply for the preparation of the clothes dryer test load. (ALS, No. 24
at p. 4; ALS, Public Meeting Transcript, No. 20 at p. 91)
The California Utilities/NRDC also stated that lower rinse
temperatures may be more representative of consumer habits based on
both anecdotal evidence and consumer data. The California Utilities/
NRDC stated that 2003 California Residential Appliance Saturation
Survey (RASS) \23\ provides data on general consumer preferences on
cold, warm, and hot wash cycles (no data was available for rinse
cycles). The data show there is a general trend among consumers to
prefer warm and cold wash cycles over hot cycles. Data cited by the
California Utilities/NRDC from the 2003 California RASS on this topic
are presented in Table III.4. According to the California Utilities/
NRDC, although the data do not specify cycle temperatures or final
rinse temperatures, the data may indicate a consumer preference for
cooler wash and rinse cycles. The California Utilities/NRDC also stated
that a 60 [deg] F 5 [deg] F preparation temperature would
be better aligned and harmonize with the cool rinse temperature
specified by the clothes washer test procedure. (California Utilities/
NRDC, No. 33 at pp. 5-6)
---------------------------------------------------------------------------
\23\ KEMA, Inc. 2009 California Residential Appliance Saturation
Study. 2010. California Energy Commission; Sacramento, CA.
Publication number: CEC-200-2010-004-ES. For more information visit:
http://www.energy.ca.gov/appliances/rass/.
[[Page 996]]
Table III.4--2003 California RASS Survey Data on Clothes Washer Cycle Selections (Provided in Comments by the
California Utilities/NRDC)
----------------------------------------------------------------------------------------------------------------
Cold wash Warm wash Hot wash
cycles cycles cycles
----------------------------------------------------------------------------------------------------------------
Cycles per Week (weighted average).............................. 1.80 2.32 0.94
Cycles per Year (weighted average).............................. 93.7 120.8 49.0
Percent of Cycles Chosen........................................ 36 46 19
----------------------------------------------------------------------------------------------------------------
The Joint Efficiency Advocates Comment stated that the 2005 RECS
gathered information about the rinse water temperature that consumers
usually use. The Joint Efficiency Advocates Comment noted that, of
respondents that used a clothes washer in their home, 78.5 percent said
they used cold water for the rinse cycle. The Joint Efficiency
Advocates Comment also noted that in the current clothes washer test
procedure, temperature use factors indicate that warm rinse is assumed
to be used only 27 percent of the time. The Joint Efficiency Advocates
Comment stated that anecdotal evidence shows that that some clothes
washers are now being manufactured without a warm rinse option. In
addition, detergent manufacturers support consumers' increasing use of
cold wash and cold rinse temperatures, as evidenced by the recent
introduction of detergents specifically optimized for these conditions.
The Joint Efficiency Advocates Comment encouraged DOE to change the
water temperature for test load preparation to reflect these consumer
usage indicators. The Joint Efficiency Advocates Comment also stated
that, at the very least, the test procedure should align with the
temperatures used in the clothes washer test procedure. According to
the Joint Efficiency Advocates Comment, the washer test procedure
assumes that a cold rinse is used the majority of the time. Therefore,
alignment could be achieved by requiring a cold rinse (60 [deg]F 5 [deg]F) be used for the clothes dryer test load preparation.
(Joint Efficiency Advocates Comment, No. 28 at pp. 1-2)
Whirlpool commented that the current load temperature is well
documented and well understood by manufacturers and independent test
laboratories. Whirlpool stated that any migration to a different
temperature would require time consuming ``round-robin'' testing to
determine the impact that such a new temperature would have on the EF
calculation. Whirlpool commented that such testing is not compatible
with DOE's timeframe for this rulemaking nor would it add value
proportional to the burden required to reformulate EF. (Whirlpool, No.
27 at pp. 2-3)
ALS commented that it does not have any data quantifying what
impact a different test load temperature would have on the clothes
dryer efficiency test results. ALS stated it is reasonable to expect
that a colder temperature test load being placed in a dryer will
require additional energy to achieve evaporation for the moisture from
the clothes. ALS suggested that DOE test existing clothes dryers to
assess the impact of the load preparation water temperature change from
100 [deg]F to 60 [deg]F. (ALS, No. 24 at p. 4; ALS; Public Meeting
Transcript, No. 20 at p. 91) The Joint Efficiency Advocates Comment
stated that the water temperature adjustment would likely have an
effect on measured dryer energy use. This is because warmer rinse
water, and hence higher initial load temperature, may result in faster
drying times and lower energy use, especially if the dryer is equipped
with moisture sensor technology. (Joint Efficiency Advocates Comment,
No. 28 at p. 2)
DOE analyzed 2005 RECS data on the rinse water temperatures
selected by consumers for clothes washer cycles. The usage data for
consumers that use a clothes washer in the home, presented below in
Table III.5, shows that 80 percent of wash cycles per year use a cold
rinse.
Table III.5--2005 RECS Consumer Usage Data on Clothes Washer Rinse
Cycles Temperature Selections
------------------------------------------------------------------------
Average Average
cycles per usage
year factor
------------------------------------------------------------------------
Hot Rinse..................................... 5.176 0.018
Warm Rinse.................................... 53.638 0.182
Cold Rinse.................................... 235.711 0.800
------------------------------------------------------------------------
Because the DOE clothes washer test procedure assumes a warm rinse
temperature use factor of 27 percent, and the 2005 RECS data shows that
80 percent of clothes washer cycles use cold water for the rinse cycle,
DOE believes that the cold water rinse cycle is more representative of
typical consumer use. (DOE also notes that it sought comment on the
warm rinse temperature use factor in the recent proposal to amend the
test procedure for residential clothes washers because it received
consumer usage survey data from a manufacturer which indicate that, for
one clothes washer model with no cold rinse option on the cycle
recommended for cotton clothes and a default cold rinse on all other
cycles, users participating in the survey reported using warm rinse for
1.6 percent of all cycles. 75 FR 57556, 57571 (Sept. 21, 2010)) For
this reason, DOE amends the clothes dryer test procedure to change the
water temperature for clothes dryer test load preparation to 60 [deg]F
5 [deg]F.
DOE tested 13 representative clothes dryers to evaluate the
repeatability and reproducibility of this amendment to the water
temperature for clothes dryer test load preparation. DOE tested these
units according to the current DOE clothes dryer test procedure, except
that the water temperature for clothes dryer test load preparation was
changed to 60[deg] 5 [deg]F. For the ventless clothes
dryer test units, DOE used the proposed testing method for ventless
dryers presented in section III.C.3. As shown below in Table III.6, the
test-to-test variation in measured EF with 60 [deg]F 5
[deg]F test load water temperature ranged from 0 percent to 4.1
percent, with an average of 1.5 percent. Therefore, DOE believes that
the amendments to the water temperature for clothes dryer test load
preparation produce repeatable test results.
[[Page 997]]
Table III.6--DOE Repeatability Testing for 60[deg] 5 [deg]F Water Temperature for Test Load
Preparation
----------------------------------------------------------------------------------------------------------------
EF lb/kWh
Test unit --------------------------------------- Test-to-test
Test 1 Test 2 Test 3 variation %
----------------------------------------------------------------------------------------------------------------
Vented Electric Standard:
Unit 1.............................................. 3.00 3.00 3.00 0.0
Unit 2.............................................. 3.01 3.07 3.06 2.0
Unit 3.............................................. 3.10 3.10 3.09 0.3
Unit 5.............................................. 3.18 3.17 ........... 0.3
Unit 6.............................................. 3.04 2.92 ........... 4.1
Vented Gas:
Unit 7.............................................. 2.74 2.70 ........... 1.5
Unit 9.............................................. 2.68 2.61 ........... 2.7
Unit 10............................................. 2.81 2.73 ........... 2.9
Unit 11............................................. 2.77 2.78 2.82 1.8
Vented Electric Compact (240V):
Unit 12............................................. 2.95 2.94 ........... 0.3
Unit 13............................................. 2.86 2.84 2.82 1.4
Ventless Electric Compact (240V):
Unit 15............................................. 2.22 2.23 ........... 0.5
Ventless Electric Combo Washer-Dryer:
Unit 16............................................. 1.94 1.98 1.96 2.1
----------------------------------------------------------------------------------------------------------------
Test Cycle
In the June 2010 TP SNOPR, DOE also proposed to amend section 3.3,
``Test cycle,'' in the DOE test procedure for clothes dryers to include
testing procedures specific to timed dryers and dryers with automatic
termination controls.
For timer dryers, the clothes dryer would be operated at the
maximum temperature setting and, if equipped with a timer, at the
maximum time setting. The load would be dried to 5-6 percent RMC
without the dryer advancing into cool-down. The timer would be reset if
necessary. If the load is not dried to within the specified range, the
test would not be considered valid. The procedure would then be
repeated, but instead the test load would be dried to 4-5 percent RMC.
As discussed later in this section, DOE proposed to use the results
from the two proposed tests cycles (corresponding to 5-6 and 4-5
percent final RMCs) to interpolate the value of the per-cycle energy
consumption required to dry the test load to exactly 5-percent RMC. 75
FR 37594, 37615 (June 29, 2010). DOE requested comment in the June 2010
TP SNOPR on whether using the maximum temperature setting is
representative of current consumer usage habits. DOE also requested
comment on whether multiple temperature settings should be evaluated
and averaged, and if so, how testing multiple temperature settings
would affect the measured efficiency as compared to the existing DOE
clothes dryer test procedure. That procedure measures the clothes dryer
only at the maximum temperature setting. Id.
AHAM stated that DOE should not adopt amendments to the temperature
setting provisions in the current test procedure because there is no
justification or evidence to support such a change. (AHAM, No. 31 at p.
6) Whirlpool commented that testing and averaging multiple cycles and
settings, while perhaps more reflective of consumer behavior, would
dramatically increase the test burden on manufacturers, and that the
substantial increase in cost would not be justified by a better result.
Whirlpool added that testing and averaging of multiple cycles and
settings would introduce opportunities for error and circumvention
while reducing repeatability and consistency. (Whirlpool, No. 27 at p.
3) ALS also supported setting the temperature at the ``maximum''
temperature setting option available on the dryer. (ALS, No. 24 at p.
5) DOE agrees that the benefit of testing multiple temperature settings
would be outweighed by the burden on manufacturers to test multiple
settings. In addition, DOE agrees that including requirements to test
multiple settings could potentially create problems with developing a
consistent test procedure that covers all products. This is because
various manufacturers offer different settings on their clothes dryers,
and test technicians would be required to determine the appropriate
settings for testing. For these reasons, DOE is not amending the test
procedure in today's final rule to require the testing of multiple
temperature settings and averaging results.
ALS stated that, for clothes dryers with only a timed dry cycle,
the time should be set at the maximum setting. ALS commented that it
has no data regarding what time setting consumers utilize most often.
ALS believes, however, that consumers using a timed dry cycle tend to
select a maximum amount of time to be assured that their load is dry at
end of the cycle. (ALS, No. 24 at p. 4) ALS also commented that the
``full time cycle including cool-down period'' should be included for
timer dryers as well as for automatic cycle termination dryers.
According to ALS, the benefits for timer dryers are as follows: (1)
Test accuracy is improved because it avoids the variability of
technician judgment on when to stop the test; (2) burden is reduced on
manufacturers and test labs, because no interpolation or test ``re-
run'' is required; and (3) all the energy consumed in a dryer cycle is
accounted for, and is representative of the manner in which consumers
utilize the dryer in their homes. (ALS, No. 24 at p. 5)
DOE does not have any data indicating that the maximum time setting
would be most representative of consumer usage habits. In addition,
some manufacturers offer a wide range of timed dry settings for
different types of loads, and these may require varying periods to dry.
Therefore, using the maximum time setting could result in energy
consumption that may not be representative of consumer use. DOE also
does not believe it would be appropriate to include the cool-down
period as part of the time dry test cycle because the current clothes
dryer test procedure requires a timed dry cycle using the maximum time
setting and maximum temperature setting and drying the load to a
specified RMC, at which point the test cycle is stopped. DOE believes
that to specify a timed dry cycle that includes the cool-down
[[Page 998]]
period to achieve a target final RMC would add significant testing
burden on test technicians to determine the appropriate time setting.
It would also be very difficult to ensure that testing results are
repeatable and reproducible because different timed dry cycle lengths,
and thus different lengths of cool-down period, may be selected to dry
a test load to the same final RMC. For these reasons, DOE is not
amending the timed dry test cycle to include the cool-down period in
today's final rule.
For dryers with automatic termination controls, as discussed in the
June 2010 TP SNOPR, DOE tested a representative gas clothes dryer to
evaluate test methods for automatic termination control dryers as part
of the energy conservation standards rulemaking preliminary analyses.
DOE conducted this additional testing to determine the effects of
proposed amendments that would require the selection of program
settings that provide the maximum drying temperature and maximum
dryness level (that is, lowest final RMC). Table III.7 below shows the
results from this testing compared to the results of testing the same
gas clothes dryer according to the current DOE test procedure. 75 FR
37594, 37615-16 (June 29, 2010).
Table III.7--DOE Automatic Cycle Termination Test Results
----------------------------------------------------------------------------------------------------------------
Per-cycle energy
Initial RMC (%) Test Final RMC % consumption kWh
----------------------------------------------------------------------------------------------------------------
70........................................ Automatic Cycle Termination. 0.6 3.018
Current DOE................. * 3.3 * 2.462
56........................................ Automatic Cycle Termination. 0.6 2.559
Current DOE................. * 3.7 * 2.001
47........................................ Automatic Cycle Termination. 0.5 2.252
Current DOE................. * 3.4 * 1.754
----------------------------------------------------------------------------------------------------------------
* Current DOE test procedure normalizes the per-cycle energy consumption equation to represent the energy
consumption required to dry the test load to 4-percent RMC. In addition, the current DOE test procedure
multiplies the per-cycle energy consumption by a fixed field-use factor of 1.04 to account for energy
consumption due to over-drying.
DOE noted that for all of the test runs, using the maximum
temperature and dryness level settings resulted in the test load being
dried to near bone dry (0.4-percent to 0.7-percent RMC). Using the data
of the estimated RMC of the test load measured continuously during the
test cycle, DOE also observed that for all of the test runs, the
estimated RMC of the test load was below 1 percent by the time the
heater began cycling on/off.\24\ The increased amount of over-drying
resulted in per-cycle energy consumption that was higher than the value
obtained using the current DOE test procedure, which uses a fixed field
use factor to account for over-drying energy consumption. DOE stated
that different manufacturers may target different final RMCs for their
highest dryness level setting. Based on analysis of the test results
for this gas clothes dryer unit, DOE stated that the highest dryness
level setting may be intended to dry the clothes load to near bone dry,
beyond the target RMC of the DOE test procedure, and would not be
appropriate for the proposed test cycle. For this reason, DOE did not
propose that the highest dryness level be specified for the test cycle.
DOE stated in the June 2010 TP SNOPR that a ``normal'' drying program
would be more representative of consumer usage habits and would more
likely dry the clothes load to the target range specified in the DOE
clothes dryer test procedure. 75 FR 37616.
---------------------------------------------------------------------------
\24\ Towards the end of an automatic termination cycle, a
clothes dryer heater generally turns on and off multiple times to
limit the amount of heat applied to the air entering the drum.
---------------------------------------------------------------------------
Based on the results of this additional testing, DOE proposed in
the June 2010 TP SNOPR an approach in which, for automatic termination
control dryers, a ``normal'' program would be selected for the test
cycle to be most representative of consumer usage. Where the drying
temperature can be chosen independently of the program, it would be set
to the maximum to provide a clear and consistent method. DOE notes that
``medium'' or ``low'' temperature settings may not be consistent among
different manufacturers. When the heater switches off for the final
time at the end of the drying cycle (that is, immediately before the
cool-down period begins) the dryer would be stopped. If the final RMC
is greater than 5 percent, the tests would be invalid and a new run
shall be conducted using the highest dryness level setting. Any test
cycle in which the final RMC is 5 percent or less would be considered
valid. DOE also proposed that for automatic termination control dryers,
the cycle setting selected for the test be recorded. This would include
settings such as the drying mode, dryness level, and temperature level.
DOE also requested comment on whether multiple cycles and settings
should be tested and how the results from those multiple tests should
be evaluated. Id.
Bosch and Siemens Home Appliance Group (BSH) expressed concern over
using the phrase ``normal program'' because no manufacturer offers a
program called ``normal,'' and the term ``normal'' is ambiguous. BSH
added that it would be very difficult to achieve reproducibility from
test lab to test lab. (BSH, Public Meeting Transcript, No. 20 at pp.
93-94) AHAM agreed with BSH regarding the use of ``normal'' program,
noting that clothes washers have transitioned from a normal cycle to
specifying settings based on fabric type. (AHAM, Public Meeting
Transcript, No. 20 at pp. 94-95) AHAM also recommended that DOE contact
manufacturers of dryer usage materials, such as fabric softeners, who
may have some survey data regarding usage factors or the most commonly
selected program to avoid the terminology of ``normal program.'' (AHAM,
Public Meeting Transcript, No. 20 at p. 95) ALS supported revising the
``test cycle'' definition to account for the fact that most dryers no
longer utilize the term ``normal cycle'' on their controls. ALS
supported using the same test cycle definition the DOE clothes washer
test procedure utilizes--``the cycle recommended by the manufacturer
for washing cotton or linen clothes''--but modified to specify ``for
drying'' instead of ``for washing.'' (ALS, No. 24 at p. 4)
ALS commented that it supports testing only one cycle (the cycle
recommended by the manufacturer for drying cotton and linen clothes)
for the following reasons: (1) Manufacturers provide other cycles for
consumers, but many of these other cycles are used infrequently because
consumers tend to utilize a favorite cycle such as an automatic
termination cycle, or a default cycle that they can easily initiate and
[[Page 999]]
that doesn't require further manipulation; (2) it would be difficult if
not impossible to develop any data or a consensus for the weighting
factors to apply to the other cycles if multiple cycles were tested;
(3) the burden on manufacturers and test labs to test multiple cycles
out-weighs any benefit; and (4) the test cycle for cotton and linen
clothes, at maximum temperature setting, will assess one of the most
energy-intensive cycles on clothes dryers, so there is no need to
further complicate the test procedure to assess if other cycles are
more energy intensive. (ALS, No. 24 at p. 5) ALS also commented that
dryers with automatic cycle termination should have the temperature for
the test set at the ``maximum'' temperature setting option available on
the dryer. This is because the test cycle should be ``the cycle
recommended by the manufacturer for drying cotton and linen clothes''
and as such would normally be a high-temperature heat setting. (ALS,
No. 24 at p. 5) Whirlpool stated that consumers dry a variety of
fabrics using a variety of clothes dryer cycles. While no one cycle
reflects this diverse consumer behavior, performing the energy test at
the maximum temperature on the normal cycle is a straightforward means
of representing the highest-cost consumer use of the product. Whirlpool
commented that, because of the well-established history with this
approach, a change in the test procedure to test multiple cycles would
not be warranted. Whirlpool further stated that any change would
require extensive round-robin testing to determine the impact of the
new test temperatures on the EF calculation. (Whirlpool, No. 27 at p.
3)
The California Utilities/NRDC stated that DOE's proposal to test a
``normal'' drying program is reasonably appropriate. The California
Utilities/NRDC stated that they lack additional consumer information on
typical cycles and settings, and being aware of a potentially large
testing burden of many different types of dryer tests, they support
DOE's proposal to test at ``normal'' or ``default'' operation.
(California Utilities/NRDC, No. 33 at p. 4) The California Utilities/
NRDC noted that manufacturers expressed concern regarding the use of
the term ``normal'' cycle, so it is important that this term be
clarified or defined to prevent a possible loophole in the test
procedure. The California Utilities/NRDC suggested that DOE collect
data from manufacturers concerning the conditions of operation for a
``normal'' dryer cycle to confirm that such cycles are reasonably
consistent among manufacturers. Alternatively, DOE could use that data
to define a range of operating conditions for a normal cycle, or
request that manufacturers suggest such a definition. (California
Utilities/NRDC, No. 33 at p. 4)
Evaluation of Proposed Amendments for Automatic Cycle Termination
As discussed above, DOE conducted testing to evaluate the proposed
amendments to the clothes dryer test procedure. As part of this
testing, DOE tested nine clothes dryers as specified by the amendments
to the test procedure for automatic cycle termination proposed in the
June 2010 TP SNOPR. The testing consisted of running the dryer on a
``normal'' automatic termination setting and stopping the dryer when
the heater switches off for the final time (immediately before the
cool-down period begins). Three identical tests were conducted for each
clothes dryer unit, and the results were averaged. The results of this
testing, presented below in Table III.8, showed that the tested clothes
dryers had a measured EF between 12.4 percent and 38.8 percent lower
than the EF measured according to the current DOE clothes dryer test
procedure. DOE also noted that all of tested units dried the test load
to final RMCs well below the target RMC of 5 percent, ranging from 0.4
percent to 1.4 percent RMC, with an average of 0.8 percent. DOE also
noted that even if the field use factor of 1.18 for a timer dryer is
applied to the measured EF for a clothes dryer equipped with automatic
cycle termination using the current DOE clothes dryer test procedure,
this EF would still be more than the EF measured under the automatic
cycle termination test procedure amendments proposed in the June 2010
TP SNOPR. (Applying the field use factor in this way adds the fixed
estimate of over-drying energy consumption associated with time
termination control dryers.)
Table III.8--DOE Clothes Dryer Automatic Cycle Termination Tests
--------------------------------------------------------------------------------------------------------------------------------------------------------
Current DOE test Proposed automatic cycle termination test procedure
Current DOE test procedure w/ -------------------------------------------------------
Test unit procedure EF lb/ modified field
kWh * use factor **EF EF lb/kWh Percent change Final RMC (%)
lb/kWh
--------------------------------------------------------------------------------------------------------------------------------------------------------
Vented Electric Standard:
Unit 3................................................ 3.20 2.82 2.59 - 19.1 1.0
Unit 4................................................ 3.28 2.89 2.59 - 21.2 0.6
Vented Gas:
Unit 8................................................ 2.83 2.50 2.42 - 14.5 0.4
Unit 9................................................ 2.85 2.51 2.38 - 16.3 0.9
Unit 11............................................... 2.98 2.63 2.40 - 19.5 0.9
Vented Electric Compact 240V:
Unit 12............................................... 3.19 2.81 2.64 - 17.3 0.5
Unit 13............................................... 2.93 2.59 2.27 - 22.7 1.4
Vented Electric Compact 120V:
Unit 14............................................... 3.23 2.85 1.98 - 38.8 0.7
Ventless Electric Compact 240V:
Unit 15............................................... 2.37 2.09 2.07 - 12.4 1.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Tests use the appropriate field use factor of 1.04 for clothes dryers with automatic termination.
** Field use factor changed from the nominal 1.04 for clothes dryers with automatic termination to 1.18, which is nominally for timer dryers.
[[Page 1000]]
These results showed significantly higher measured energy use for
clothes dryers tested under the DOE test procedure with the proposed
automatic cycle termination amendments. DOE evaluated possible reasons
for this difference, and concluded that given the test load specified
in the current DOE test procedure,\25\ the proposed automatic cycle
termination control procedures may not adequately measure clothes dryer
performance. As discussed above in this section, DOE believes that,
although automatic termination control dryers may be measured as having
a lower efficiency than a comparable dryer with only time termination
control if tested according to the proposed test procedure, automatic
termination control dryers may in fact be drying the clothing to
approximately 5-percent RMC in real world use. DOE believes that
automatic termination control dryers reduce energy consumption (by
reducing over-drying) compared to timer dryers based on analysis of the
AHAM field use survey and analysis of field test data conducted by
NIST. 46 FR 27324 (May 19, 1981).
---------------------------------------------------------------------------
\25\ The DOE clothes dryer test load is comprised of 22 in x 34
in pieces of 50/50 cotton/polyester-blend cloth.
---------------------------------------------------------------------------
For these reasons, DOE believes the test procedure amendments for
automatic cycle termination proposed in the June 2010 TP SNOPR do not
adequately measure the energy consumption of clothes dryers equipped
with such systems. Therefore, DOE is not adopting in today's final rule
the amendments for automatic cycle termination proposed in the June
2010 TP SNOPR. 75 FR 37594, 37616 (June 29, 2010). If data is made
available to develop a test procedure that accurately measures the
energy consumption of clothes dryers equipped with automatic
termination controls, DOE may consider revised amendments in a future
rulemaking.
ALS commented that an automatic cycle termination-equipped dryer
that produces a final RMC of greater than 5 percent should be required
to have additional test cycle runs. The insufficiently dried load would
be placed back into the dryer for an extra cycle, and the extra-cycle
energy added to the first test cycle results, until the final RMC is 5
percent or less. ALS commented that this extra cycle energy would be a
significant penalty and incentive to keep manufacturers from creating
automatic cycle termination systems that essentially tried to achieve a
low energy consumption value while not achieving consumer-acceptable
final RMC levels. ALS also believes that this method represents what
consumers tend do when a load is not sufficiently dried at the end of
the cycle--put the load back into the dryer and run another dry cycle
on the same setting. (ALS, No. 24 at p. 3) The California Utilities/
NRDC supported DOE's proposal to require a re-test at the ``highest
energy consuming setting'' in the case of a dryer failing to reach 5-
percent RMC or less under a normal drying program. (California
Utilities/NRDC, No. 33 at p. 4)
For the reasons discussed above, DOE is not adopting in today's
final rule the amendments proposed in the June 2010 TP SNOPR to better
account for automatic cycle termination. Therefore, additional
specifications for such an approach are not relevant.
Dry Clothes Load Testing
CU commented that an additional test using a dry clothes load
should be included as part of the test procedure to assess how well a
sensor detects that a clothes load has been dried to terminate the
cycle. CU commented that it tested products using a 12-lb dry clothes
load (less than 5 percent initial RMC) of mixed cottons with the dryer
at normal/cotton, highest heat, and maximum dryness level settings. CU
observed notable differences in the performance of different types of
dryers (that is, those with thermostatic control and those with
moisture sensors). CU noted that units with moisture sensors stopped
within a reasonable time, but units with just a thermostat continued
running, sometimes 20 times longer than a dryer with a moisture sensor.
CU noted that one dryer with the moisture sensor ran an average of 3
minutes before shutting off, and in 3 tests, it averaged 162 Wh per
test. Another dryer with a thermostat ran for an average of about 60
minutes, and in 3 tests, it averaged 2,335 Wh per test. In addition, CU
observed significant variation among dryers with moisture sensors and
those with thermostats, and stated it should not be assumed that these
results represent performance for all dryers of either type. (CU, No.
29 at pp. 2-3)
DOE does not believe running a dry clothes load would be
representative of consumer usage. It also does not believe that the
amount of time a clothes dryer operates with such a clothes load would
necessarily be representative of the effectiveness of a sensor system
in detecting final RMC for an initially damp clothes load. Further, DOE
is not aware of how an energy efficiency metric would be established
that considers the energy consumption of a dry clothes load test cycle.
Therefore, DOE is not adopting any provisions for measuring the energy
consumption of a dry clothes load test cycle in today's final rule.
Evaluation of Automatic Termination Technologies
DOE noted in the June 2010 TP SNOPR that it conducted preliminary
automatic cycle termination tests to analyze the various automatic
termination technologies found in DOE's sample of selected dryers. DOE
selected the AHAM 8-lb test load \26\ instead of the 7-lb load
specified in the DOE test procedure for standard-size clothes dryers.
It did so to lengthen the test cycle times and better evaluate the
function of the dryer controls as the test load approached low RMCs.
DOE also noted that the independent test lab conducting the clothes
dryer tests used a data acquisition system to monitor estimated RMC of
the test load continuously during the test cycle. The automatic
termination tests conducted by DOE consisted of running the test cycle
in a user-programmable automatic termination mode and allowing the
dryer to self-terminate the drying cycle using the various automatic
termination sensor technologies. DOE monitored the energy consumption
and estimated RMC of the test load during the test cycle from the
starting time at 70-percent initial RMC to the time when the heater
last cycled off (that is, immediately before the cool-down period). The
specific focus was on analyzing the amount of over-drying energy
consumed drying the test load to less than 5-percent RMC.\27\ 75 FR
37594, 37617 (June 29, 2010).
---------------------------------------------------------------------------
\26\ The AHAM 8-lb test load is made up of the following mixed
cotton items, which are intended to represent clothes items
regularly laundered: 2 sheets, 1 table cloth, 2 shirts, 3 bath
towels, 2 ``T'' shirts, 2 pillow cases, 3 shorts, 1 wash cloth, 2
handkerchiefs.
\27\ As noted in the June 2010 TP SNOPR, DOE applied a
correction factor to the test data to account for the fact that the
automatic cycle termination tests used the AHAM 8-lb test load
instead of the DOE 7-lb test load.
---------------------------------------------------------------------------
Figure III.1 shows the over-drying energy consumption versus the
final RMC for a number of different units tested, and, in some cases,
different cycle settings.\28\ The data show that over-drying the test
load to lower final RMCs requires higher energy consumption, with a
slightly exponential trend likely because it becomes more difficult to
remove the final small amounts of moisture remaining in the test load.
DOE noted in the June 2010 TP SNOPR that it did not observe any
relationship between the type of automatic cycle termination
[[Page 1001]]
sensor technology used and the amount of over-drying. DOE also noted,
however, that these tests were conducted using different testing
methods than the methods proposed in the June 2010 TP SNOPR (that is,
various automatic cycle termination settings). Therefore, DOE was
unable to determine whether one type of sensor technology is more
accurate, and thus more effective at preventing over-drying. 75 FR
37618.
---------------------------------------------------------------------------
\28\ DOE noted that some of the tested units stopped the test
cycle at or higher than 5-percent RMC, thereby not producing over-
drying.
[GRAPHIC] [TIFF OMITTED] TR06JA11.084
Porticos commented that DOE considered only two possible methods
for automatic cycle termination (moisture and temperature sensing).
Porticos commented that these may be the only practical alternatives in
a vented, forced-convection tumble dryer, but that alternate drying
technologies may enable alternate methods of determining when the
drying cycle should be terminated. Ignoring this possibility penalizes
any appliance that attempts to deploy a different technology.
(Porticos, No. 23 at p. 1)
DOE agrees that the test procedure should not exclude alternate
sensing technologies used for automatic cycle termination controls. DOE
notes section 3.5 of the test procedure, ``Test for automatic
termination field use factor credits,'' specifies that the field use
factor for automatic cycle termination would apply only to clothes
dryers that meet the requirements for the definitions of ``temperature
sensing control'' or ``moisture sensing control.'' The test procedure
defines ``temperature sensing control'' a system that monitors the
exhaust air temperature to automatically terminate the dryer cycle. The
test procedure also defines ``moisture sensing control'' as a system
that uses a moisture sensing element within the drum that monitors the
amount of moisture in the clothes to automatically terminate the dryer
cycle. DOE also notes the test procedure defines ``automatic
termination control'' as a control system with a sensor that monitors
either the dryer load temperature or its moisture content and with a
controller that automatically terminates the drying process. DOE
believes that this definition would not limit the emergence of any new
sensor technologies that monitor the moisture content or temperature in
other ways from applying the field use factor for automatic cycle
termination. For these reasons, DOE amends section 3.5 of the test
procedure to specify that the field use factor applies to clothes
dryers that meet the requirements for the definitions of ``automatic
termination control.''
Target Final RMC
DOE also noted in the June 2010 TP SNOPR that AS/NZS Standard 2442
specifies the maximum allowable final RMC for automatic termination
control dryers as 6 percent. DOE, however, stated that it is unaware of
any data indicating that a final RMC of 6 percent would be
representative of current consumer usage habits. DOE also noted that
using 5-percent RMC, as proposed in today's June 2010 TP SNOPR, would
remain within the range specified by the current DOE test procedure,
which specifies 2.5- to 5-percent final RMC. Id.
The Joint Petitioners and AHAM commented that a final RMC of 5
percent is appropriate. (Joint Petitioners, No. 30 at p. 6; AHAM, No.
31 at p. 6)) ALS stated that the test load final RMC should be no
greater than 5 percent. ALS stated that if the test cycle continued to
measure all of the energy including cool-down, manufacturers
[[Page 1002]]
would adopt their own methods to ensure that they do not over-dry the
test load. (ALS, No. 24 at p. 3) As discussed above, DOE is not
adopting the amendments to better account for automatic cycle
termination proposed in the June 2010 TP SNOPR. For these reasons, DOE
is not amending the test procedure to revise the final RMC.
Cool-Down Period
DOE also noted in the June 2010 TP SNOPR that there are at least
two ways to terminate the drying cycle during the test: (1) Termination
before cool-down, or (2) termination at the end of the selected test
cycle, including cool-down. 75 FR 37594, 37616 (June 29, 2010). Section
4.2 of AS/NZS Standard 2442.1 requires that, for automatic termination
control dryers, the programmed test cycle be run until immediately
before the cool-down period begins. Similarly, section 4.5.1 of AHAM-
HLD-1-2009 requires that the automatic termination control dryer test
cycle not be permitted to advance into the cool-down period.
Alternatively, section 9.2.1 of EN Standard 61121 requires that the
selected test cycle program be allowed to run until completion,
including the cool-down period. In the June 2010 TP SNOPR, DOE proposed
amendments for automatic cycle termination based on the provisions in
AS/NZS Standard 2442 because it provides a more representative
comparison of the energy consumption between automatic termination
control dryers and timer dryers than EN Standard 61121. In addition,
the proposed amendments to stop the test cycle immediately before the
cool-down period would harmonize DOE test methods with AS/NZS Standard
2442 and AHAM-HLD-1-2009. Id. DOE stated, however, that it was
considering the alternative method of section 9.2.1 of EN Standard
61121. DOE recognizes that manufacturers may design products to use the
residual heat during the cool-down period (that is, immediately after
the heater has switched off for the final time) to continue to dry the
clothes load while slowly spinning the drum to achieve a desired
RMC.\29\ DOE recognizes that including the cool-down period may make it
possible for some manufacturers to design dryers that attain the
desired RMC with lower total energy consumption. DOE noted that this
potential for energy efficiency improvement would not be captured by
the test methods proposed in the June 2010 TP SNOPR. To capture this
real-world energy savings potential associated with the additional
drying using residual heat during the cool-down period, DOE stated in
the June 2010 TP SNOPR that it could adopt an alternate approach to
include the measurement of the cool-down period as part of the proposed
automatic cycle termination test methodology. Under this alternate
approach, section 3.3.2 of the test procedure for automatic termination
control dryers, instead of specifying that ``when the heater switches
off for the final time, immediately before the cool-down period begins,
stop the dryer,'' would specify to ``run the clothes dryer until the
programmed cycle has terminated.'' DOE also noted that inclusion of the
cool-down period under the proposed test method would not affect the
ability to compare energy consumption test results between automatic
termination control dryers and timer dryers in DOE's clothes dryer test
procedure. DOE further stated in the June 2010 TP SNOPR that it is
unaware of data showing the effects of including the cool-down period
on the measured efficiency as compared to the existing test procedure.
75 FR 37616-17.
---------------------------------------------------------------------------
\29\ The clothes dryer would also consume energy to spin the
drum during the cool-down period that is currently not accounted for
by the DOE test procedure.
---------------------------------------------------------------------------
The Joint Petitioners, AHAM, Whirlpool and ALS commented that,
although they generally promote harmonization with international
standards, they do not agree that AS/NSZ Standard 2442 provides the
best methods and procedures to account for the amount of over-drying
associated with automatic termination control dryers beyond a specified
RMC. The Joint Petitioners, AHAM, Whirlpool, ALS, the California
Utilities/NRDC, and EJ commented that the test procedure should measure
the full cycle, including cool-down period, which is more
representative of consumer usage because it includes all of the energy
use in a cycle. The Joint Petitioners, AHAM, Whirlpool and ALS stated
that such an approach is reproducible and repeatable because it does
not require any ``guesswork'' as to when the cool-down will begin. The
approach is also less burdensome because it does not require the
manufacturers to determine the point immediately before cool-down for
each model. (Joint Petitioners, No. 30 at p. 5; AHAM, No. 31 at p. 5;
Whirlpool, No. 27 at pp. 2, 3; ALS, No. 24 at p. 3; ALS, Public Meeting
Transcript, No. 20 at pp. 97-98; California Utilities/NRDC, No. 33 at
pp. 4-5; EJ, No. FDMS D0039 at pp. 1-2)
ALS also commented that the ``default'' cool-down should be set if
the dryer has selectable cool-down time period options. (ALS, No. 24 at
p. 6) AHAM commented that the ``as-shipped'' (that is, ``default'')
cool-down settings should be included in active mode because this
approach is more representative of actual consumer usage. (AHAM, No. 31
at p. 6)
The Joint Efficiency Advocates Comment stated that excluding the
cool-down period results in a portion of the energy consumed by a
drying cycle not being measured by the test procedure. In addition, the
Joint Efficiency Advocates Comment stated that including the cool-down
period could provide manufacturers with an additional option for
reducing energy consumption. (Joint Efficiency Advocates, No. 28 at p.
3) ALS and BSH supported including the cool-down period in the test
procedure. They feel manufacturers may optimize the point where the
heating is stopped and the residual heat in the load is used during
cool-down to complete the drying process to achieve consumer-accepted
final moisture retention levels, while avoiding ``over drying'' loads
and potentially wasting energy. (ALS, No. 24 at p. 3; BSH, Public
Meeting Transcript, No. 20 at p. 98) EJ commented that a test procedure
that ignores the additional drying functionality provided by
cool[hyphen]down mode reduces manufacturers' incentive to provide this
energy[hyphen]saving feature. (EJ, No. FDMS D0039 at pp. 1-2)
Whirlpool requested that DOE complete further analysis to adjust EF
within the test procedure to account for the inclusion of the cool-down
portion of the cycle. Whirlpool stated that failure to adjust the EF
requirements will inadvertently result in requirements becoming too
stringent. Whirlpool commented that it can infer that the cool-down
portion of the cycle consumes little energy when compared to the drying
portion as it is relatively short and uses only motor energy, not
heating element energy. (Whirlpool, No. 27 at pp. 2, 3) Whirlpool also
commented that the additional energy consumed during cool-down period
does not follow linear relationship with the RMC of the test load.
Whirlpool stated that it does not have sufficient data to fully address
how this would be reflected in total energy consumption. Whirlpool
commented that if DOE were to make a specific request to AHAM for such
data, Whirlpool would be willing to gather and supply information to
AHAM for aggregation and submittal to DOE. (Whirlpool, No. 27 at p. 5)
ALS commented that it has no data to submit to DOE at this time on how
the proposed added cool-down period energy consumption would impact the
measured energy efficiency of existing
[[Page 1003]]
clothes dryers, and suggested that DOE conduct tests to determine the
impact. (ALS, No. 24 at p. 6) The California Utilities/NRDC similarly
commented that they do not have specific data on the impacts this cool-
down period has on dryer per-cycle energy use and calculated EF.
However, they stated that although the impacts may be small, DOE
should, for the purposes of completeness and reproducibility, consider
including the energy use of the cool-down portion of the cycle into the
active mode test procedure. The California Utilities/NRDC stated that
DOE should revise the energy conservation standards to reflect this
test procedure change. (California Utilities/NRDC, No. 33 at pp. 4-5)
As discussed above, DOE is not adopting the amendments to better
account for automatic cycle termination proposed in the June 2010 TP
SNOPR. For this reason, DOE is not amending the test procedure to
include the cool-down period for automatic termination test cycles. If
DOE considers potential amendments for automatic cycle termination in a
future rulemaking, it may consider provisions that account for the
cool-down period.
Calculation of Revised Results From Automatic Cycle Termination Test
Measurements
In the June 2010 TP SNOPR, DOE also proposed to revise section 4,
``Calculation of Derived Results from Test Measurements,'' of the DOE
test procedure. DOE proposed to revise the field use factors in the
current DOE test procedure to more appropriately account for automatic
termination control dryers' over-drying energy consumption. DOE
proposed that a field use factor of 1.0 (instead of the 1.04 currently
provided) would be specified for automatic termination control clothes
dryers, so that any over-drying energy consumption would be added
directly to the drying energy consumption to decrement EF. If the
proposed test methods were used, an automatic termination control dryer
that is able minimize over-drying by drying the test load to close to
5-percent RMC would achieve a higher measured efficiency than if it
over-dried the test load to an RMC of less than 5 percent. The lower
amount of energy consumed over-drying the test load would be included
in the per-cycle energy consumption, and would result in a reduction in
the measured EF. For timer dryers, DOE proposed to use the per-cycle
energy consumption measurements from the two proposed tests cycles
discussed above in this section (corresponding to 5-6 and 4-5 percent
final RMCs) to interpolate the value of the per-cycle energy
consumption required to dry the test load to exactly 5-percent RMC. The
1.18 field use factor in the current DOE test procedure would then be
applied to account for the over-drying energy consumption of timer
dryers. 75 FR 37594, 37617 (June 29, 2010).
As discussed above in this section, DOE noted in the September 1977
TP Final Rule that the 1.18 field use factor in the calculation of EF
for timer dryers was based on analysis of data from a field use survey
conducted by Oklahoma Gas and Electric Company involving 64 homes as
well as data provided by AHAM on the measured energy consumption per-
cycle under the DOE test procedure to account for the differences
between the values derived from the laboratory test procedures and
those obtained from actual consumer use. 42 FR 46145, 46146 (September
14, 1977). DOE stated in the June 2010 TP SNOPR that it was unaware of
any data or studies indicating the 1.18 field use factor for timer
dryers used to account for over- or under-drying test loads in real-
world use is inaccurate and not currently representative of consumer
usage. For this reason, DOE did not propose to revise the 1.18 field
use factor for timer dryers in the June 2010 TP SNOPR but requested
data and comment on whether this value is appropriate. Id.
AHAM, the Joint Petitioners, the California Utilities/NRDC, and ALS
supported DOE's proposal to change the field use factor from 1.04 to
1.0 for automatic termination control dryers and not revise the 1.18
field use factor for timer dryers. (AHAM, No. 31 at p. 6; Joint
Petitioners, No. 30 at p. 6; California Utilities/NRDC, No. 33 at p. 5;
ALS, No. 24 at p. 3)
As discussed above, DOE is not adopting in today's final rule the
amendments to better account for automatic cycle termination proposed
in the June 2010 TP SNOPR. For the reasons stated above, DOE is not
amending the test procedure in today's final rule to include the
revisions to the energy use calculations or the field use factors
proposed in the June 2010 TP SNOPR. If DOE considers potential
amendments for automatic cycler termination in a future rulemaking, it
may consider such revisions to the energy use calculations and field
use factors.
3. Test Procedure for Ventless Clothes Dryers
DOE noted in the October 2007 Framework Document that a potential
limitation of the clothes dryer test procedure had been identified for
ventless dryers, which include condensing clothes dryers and
combination washer/dryers. (Framework Document, STD No. 1 at p. 5)
Ventless clothes dryers do not vent exhaust air to the outside as a
conventional clothes dryer does. Instead, they typically use ambient
air in a heat exchanger to cool the hot, humid air inside the
appliance, thereby condensing out the moisture. Alternatively, cold
water can be used in the heat exchanger to condense the moisture from
the air in the drum.\30\ In either case, the dry air exiting the drum
is reheated and recirculated in a closed loop. Thus, rather than
moisture-laden exhaust air that vents outside, ventless clothes dryers
produce a wastewater stream that can be either collected in an included
water container or discharged down the household drain. The process of
condensing out the moisture in the recirculated air results in higher
energy consumption than a conventional clothes dryer, however, and it
can significantly increase the ambient room temperature.
---------------------------------------------------------------------------
\30\ This is a typical approach for combination washer/dryers,
which wash and dry a load in the same drum.
---------------------------------------------------------------------------
Manufacturers of condensing clothes dryers have, in the past,
applied for waivers from the DOE test procedure for these products on
the basis that the test procedure did not contain provisions for
ventless clothes dryers. See, e.g., 74 FR 66334 (December 15, 2009); 75
FR 13122 (Mar. 18, 2010). The current test procedure requires using an
exhaust restrictor to simulate the backpressure effects of a vent tube
in an installed condition. Condenser dryers do not have exhaust vents
because they recirculate rather than exhaust the process air.
In the October 2007 Framework Document, DOE stated that it intended
to analyze ventless clothes dryers as a separate product class,
recognizing the unique utility that ventless clothes dryers offers to
consumers. That utility is the ability to be installed in conditions in
which vented clothes dryers would be precluded due to venting
restrictions. DOE considered two product classes for ventless clothes
dryers: (1) Ventless electric compact (240V) clothes dryers; and (2)
electric combination washer/dryers.
In this final test procedure rule, DOE adopts amendments to measure
the energy use of ventless clothes dryers, as discussed in more detail
below.
[[Page 1004]]
Effects of Clothes Dryers on HVAC Energy Use
In response to the October 2007 Framework Document, DOE received
comments from AHAM that the energy calculations for ventless clothes
dryers should take a more ``holistic'' approach than those for vented
clothes dryers. That is because ventless clothes dryers can have an
effect on energy use oustide of their system (that is, impacts on HVAC
loads). 75 FR 37594, 37620-21 (June 29, 2010). EPCA requires that any
test procedures prescribed or amended under this section be reasonably
designed to produce test results that measure energy efficiency, energy
use, water use, or estimated annual operating cost of a covered product
during a representative average use cycle or period of use. (42 U.S.C.
6293(b)(3)) DOE stated in the June 2010 TP SNOPR that accounting for
the impacts of ventless clothes dryers on HVAC loads and thus on the
energy use of a household would be inconsistent with the EPCA
requirement that a test procedure measure the energy use of a covered
product. DOE also noted that, while the test procedure for heat pump
water heaters does not account for impacts to HVAC loads, DOE
considered the effects of heat pump water heaters on house heating
loads as part of the energy-use characterization in the rulemaking to
establish energy conservation standards rulemaking for water heaters.
For these reasons, DOE did not propose to amend its clothes dryer test
procedure to account for the ambient space conditioning impacts in the
June 2010 TP SNOPR, but stated that it would consider such impacts as
part of the concurrent energy conservation standards rulemaking. 75 FR
37594, 37621 (June 29, 2010).
In response to the June 2010 TP SNOPR, the California Utilities/
NRDC commented that DOE should consider HVAC impacts as part of the
concurrent energy conservation standards rulemaking. They added that
the ECOS report showed that space conditioning impacts due to clothes
dryer intake air may be significant. (California Utilities/NRDC, No. 33
at pp. 8-9) The California Utilities/NRDC and the Super Efficient Dryer
Initiative (SEDI) noted that the actual impacts will depend on many
factors, such as climate, season, and location of the clothes dryer
within the home. They stated DOE should thoroughly assess this aspect
of clothes dryer operation and research opportunities for energy
reduction. (California Utilities/NRDC, No. 33 at p. 9; SEDI, No. 34 at
p. 2)
Porticos commented that the HVAC load from a vented clothes dryer
is much higher than that of other household appliances. According to
Porticos, a vented clothes dryer induces air infiltration equal to the
exhaust airflow (up to 160 cubic feet per minute (cfm)), enough to
completely empty a 1200 cubic foot (ft\3\) home of all its conditioned
air in 1 hour. (Porticos, No. 23 at p. 2) Porticos and SEDI both
commented that there would be significant HVAC savings associated with
switching from vented to ventless clothes dryers. (Porticos, No. 23 at
p. 2; SEDI, No. 34 at p. 2) SEDI added that vented clothes dryers
operate by drawing supply air from the volume of conditioned space
within a house. The supply air is heated and used to dry the clothes.
The air is then exhausted from the home. SEDI stated this process
wastes both the heating energy put into that air by the dryer itself,
but also the heating or cooling energy put into that air earlier by the
home's HVAC system. (SEDI, No. 34 at p. 2) Porticos also added that
ventless dryers tend to directly heat the living space rather than
inducing air infiltration. (Porticos, No. 23 at p. 2) The California
Utilities/NRDC commented that HVAC impacts may be mitigated through
increased use of ventless dryers, or other technologies for vented
dryers, such as an outside air intake port, which could provide a
location to fit an intake air vent. The California Utilities/NRDC
stated that it is important that DOE gather data on the HVAC impacts of
clothes dryers to accurately assess the costs and savings impacts of
such technologies. (California Utilities/NRDC, No. 33 at p. 9)
The California Utilities/NRDC commented that the test procedure
would be a simple and convenient means for manufacturers to submit
useful data to DOE on clothes dryer operation that impacts HVAC loads
(namely intake air). Data on intake air could be gathered by requiring
the measurement of intake air via a small sensor in the airstream
during the test. The California Utilities/NRDC added that this
information would be a valuable indication of the amount of airflow
caused by clothes dryers, and could form the basis for subsequent DOE
analysis. (California Utilities/NRDC, No. 33 at p. 9) Porticos
recommended the following modifications to the test procedure to
evaluate the effects of the clothes dryer on building energy
consumption:
1. Directly measure the exhaust airflow (defined as zero for
ventless appliances);
2. Directly measure the ambient heat-load represented by the
appliance during operation (DOE might define this as zero for vented
appliances);
3. Calculate the overall HVAC burden due to heat-burden and induced
infiltration; and
4. Optionally, modify this figure to account for variations due to
regional usage (a vented dryer might work quite well in a moderate
climate, but less-so in colder climates). (Porticos, No. 23 at p. 2)
Porticos added that there is a precedent for addressing impacts
external to the clothes dryer because existing DOE test procedures
penalize clothes washers which do a poor job of spin-drying clothes,
thus placing an excessive burden on the clothes dryer. Id.
SEDI commented that both the current and proposed clothes dryer
test procedures ignore the HVAC impact of vented dryers, and will not
provide DOE, or SEDI and other energy efficiency program providers,
with the information necessary to estimate HVAC savings. SEDI commented
that ideally, testing for all clothes dryers would include measurement
of the energy content of the air expelled from the home during the
drying cycle, which would be added to the energy directly consumed by
the dryer itself. (SEDI, No. 34 at p. 2) SEDI supported the recommended
modifications for measuring HVAC impacts submitted by Porticos. SEDI
also recognized, however, that it may be extremely difficult to develop
HVAC energy consumption algorithms for residential clothes dryers that
are applicable across the United States. SEDI also recognized that
pursuing this comprehensive approach could move DOE away from
harmonization with international standards. SEDI commented that, at a
minimum, DOE should adopt at least modifications 1 and 2 suggested by
Porticos, presented above, but with the following change: ``1. Directly
measure the exhaust air volume (defined as zero for ventless
appliances) during the entire drying cycle.'' SEDI commented that this
change would enable the energy use of clothes dryers that have
different rates of venting at different points during the drying cycle.
In addition, if the volume of air vented by a clothes dryer from a home
is measured, the HVAC impacts of that clothes dryer on the home could
be estimated. (SEDI, No. 34 at p. 2)
DOE reiterates that accounting for the effects of clothes dryers on
HVAC energy use is inconsistent with the EPCA requirement that a test
procedure measure the energy efficiency, energy
[[Page 1005]]
use, or estimated annual operating cost of a covered product. (42
U.S.C. 6293(b)(3)) DOE acknowledges its clothes washer test procedure
measures the RMC at the end of the wash cycle, but notes that in this
case, the test procedure accounts directly for the additional energy
use of a clothes washer to remove moisture from a clothes load. For
these reasons, DOE is not revising the test procedure to account for
HVAC energy use in today's final rule.\31\
---------------------------------------------------------------------------
\31\ DOE further notes that to accurately evaluate the HVAC
impacts of clothes dryers it would need to determine the amount of
heating and cooling being performed by the HVAC system, which would
vary by region and time of year. In addition, to determine the
amount of induced infiltration and heat-load caused by a clothes
dryer, DOE would need to develop provisions for accurate and
repeatable measurements, including: test equipment tolerances,
position of measurement devices in either the exhaust or other
locations, and determination of representative household air leakage
rates. Such additional testing provisions for measuring the HVAC
impacts would also increase the testing burden on manufacturers.
---------------------------------------------------------------------------
The Joint Petitioners commented that DOE should create a ventless
clothes dryer test procedure to define a baseline energy consumption
level for this new product category. Such a procedure would include
combination washer/dryers. (Joint Petitioners, No. 25 at p. 14; Joint
Petitioners, No. 30 at p. 6) ALS also supported the addition of test
procedures for ventless clothes dryers. (ALS, No. 24 at p. 6) SEDI also
noted the importance of expanding the test procedure to accommodate
ventless clothes dryers, such as the energy efficient heat pump clothes
dryers now gaining market share in Europe. SEDI stated that DOE should
develop a ventless clothes dryer test procedure as soon as possible,
while taking care not to inadvertently discourage efforts to increase
the energy efficiency of clothes dryers in North America. (SEDI, No. 34
at p. 2)
Ventless Clothes Dryer Test Procedure Amendments
In the June 2010 TP SNOPR, DOE examined an alternate test procedure
for ventless clothes dryers that provided definitions for
``conventional clothes dryers'' and ``condensing clothes dryers'' and
would require the exhaust simulator to be used only for vented clothes
dryers. DOE conducted limited tests of ventless clothes dryers at an
independent testing laboratory according to those amendments. DOE
conducted three tests per unit on one ventless electric compact (240V)
clothes dryer and one ventless combination washer/dryer. Table III.9
shows the test results. DOE observed no variation in EF from test to
test of the proposed test procedure for the ventless electric compact
(240V) dryer, and less than 2-percent variation in EF test-to-test for
the ventless combination washer/dryer. Based on this testing, DOE
stated in the June 2010 TP SNOPR that the alternate testing procedures
appear to produce repeatable results. 75 FR 37594, 37621 (June 29,
2010).
Table III.9--Data From DOE Testing of Ventless Clothes Dryers for the
June 2010 TP SNOPR
------------------------------------------------------------------------
EF (lb/kWh)
-------------------------------
Ventless
Test run electric Ventless
compact (240 combination
V) washer/dryer
------------------------------------------------------------------------
1....................................... 2.37 1.95
2....................................... 2.37 1.96
3....................................... 2.37 1.93
------------------------------------------------------------------------
DOE also investigated testing conditions and methods for ventless
or condensing clothes dryers specified in international test standards,
including those used in Europe, China, Australia, and New Zealand. Id.
DOE evaluated EN Standard 61121, and identified as relevant the
test procedures for condensing (ventless) clothes dryers, as well as
certain test conditions that affect all clothes dryers. In particular,
DOE noted that section 3 of EN Standard 61121, ``Definitions and
symbols,'' provides definitions for ``air vented tumble dryer'' and
``condenser tumble dryer.'' DOE noted that section 6 of EN Standard
61121, ``General,'' provides general conditions for measurements for
both types of dryers, in particular for installation without an exhaust
duct, as well as ambient temperature conditions. DOE noted that section
9 of EN Standard 61121, ``Performance tests,'' provides the test
procedures for performance tests for both types of dryers. DOE noted in
the June 2010 TP SNOPR these test procedures provide greater
specificity than the alternate test procedure discussed above. 75 FR
37621-22.
DOE also evaluated AS/NZS Standard 2442.1, which specifically
includes condenser clothes dryers and the dryer function of combination
washer/dryers. DOE noted that AS/NZS Standard 2442.1 provides
definitions for vented and condenser clothes dryers that are
essentially the same as those provided in EN Standard 61121. DOE also
noted that AS/NZS Standard 2442.1 provides exhaust conditions for
installation that are very similar to those provided in EN Standard
61121. 75 FR 37622.
In the June 2010 TP SNOPR, DOE also considered comments that
Whirlpool submitted as part of the residential clothes dryer and room
air conditioner energy conservation standards rulemaking, providing
amendments to the DOE test procedure for clothes dryers to include
methods for the testing of condensing dryers.\32\ These suggested
amendments were largely based on EN Standard 61121. DOE noted that
Whirlpool suggested definitions for ``exhausted'' clothes dryers,
``non-exhausted'' clothes dryers, and ``condensing'' clothes dryers.
Whirlpool also suggested provisions for the installation conditions for
ventless clothes dryers, in particular for installation without an
exhaust simulator. Whirlpool also suggested provisions for ventless
clothes dryers for pre-conditioning, conditions for a condensation box
and the condenser unit, as well as test measurement methods for
ventless clothes dryers. 75 FR 37622-23.
---------------------------------------------------------------------------
\32\ Whirlpool, 2007. ``U.S Department of Energy Test Procedure
Change for Condensing Clothes Dryers.'' September 4, 2007. Docket
No. EE-2007-BT-STD-0010, Comment Number 13.
---------------------------------------------------------------------------
DOE reviewed the definitions in EN Standard 61121 (section 3), AS/
NZS Standard 2442.1 (section 1.4), and Whirlpool's proposed amendments
to the DOE test procedure. DOE concluded that the proposed definitions
of ``conventional clothes dryer'' and ``condensing clothes dryer'' are
essentially the same as the international test standards definitions.
DOE proposed to define ``conventional clothes dryer'' as ``a clothes
dryer that exhausts the evaporated moisture from the cabinet.'' It
proposed to define ``ventless clothes dryer'' as ``a clothes dryer that
uses a closed-loop system with an internal condenser to remove the
evaporated moisture from the heated air. The moist air is not
discharged from the cabinet.'' DOE proposed to use the term
``ventless'' to reflect the actual consumer utility (that is, no
external vent required) instead of ``condensing'' because of the
possibility that vented dryers that also condense are also available on
the market. 75 FR 37623. AHAM and ALS commented in support of the
proposed definitions. (AHAM, No. 31 at p. 6; ALS, No. 24 at p. 6)
Whirlpool commented that it supports substituting ``ventless'' for
``condensing''. (Whirlpool, No. 27 at p. 3) For the reasons stated
above, DOE adopts the definitions of ``conventional clothes dryer'' and
``ventless clothes dryer'' proposed in the June 2010 TP SNOPR.
DOE evaluated the installation conditions detailed in EN Standard
61121 (section 6.1), AS/NZS Standard 2442.1 (section 3.4), and
Whirlpool's
[[Page 1006]]
proposed amendments to the DOE test procedure. DOE stated in the June
2010 TP SNOPR that the proposed amendments for the exhaust duct
installation requirements, with clarifications added, are appropriate
for testing ventless clothes dryers. 75 FR 37594, 37623 (June 29,
2010). DOE noted the proposed exhaust duct installation conditions
remove the requirement for installing an exhaust simulator for a
clothes dryer without an exhaust duct (that is, a ventless clothes
dryer). The international test standards noted above also require that
a clothes dryer without an exhaust duct be tested as such. Those
standards, however, also provide additional conditions for a clothes
dryer with an optional exhaust duct, stating that such a clothes dryer
should be tested without the duct installed. DOE believes these
installation conditions provide additional clarity and cover all
possible clothes dryer configurations, as well as harmonizes with
international test standards. Therefore, DOE proposed in the June 2010
TP SNOPR to amend section 2.1 of the DOE test procedure for clothes
dryers, which covers installation conditions. The amendments qualify
the requirement for an exhaust simulator so that it would apply only to
conventional clothes dryers. The amendments added the clarification
that ventless clothes dryers be tested without the exhaust simulator
installed and, if a dryer is designed to operate with an optional
exhaust duct, the dryer shall be tested without the duct installed. Id.
AHAM, Whirlpool, and ALS supported the proposed exhaust duct
installation conditions. (AHAM, No. 31 at p. 7; Whirlpool, No. 27 at p.
3; ALS, No. 24 at p. 6) In the absence of comments objecting to this
proposal, DOE adopts the exhaust duct installation conditions proposed
in the June 2010 TP SNOPR.
DOE also believes the provisions in EN Standard 61121 regarding a
condensation box provides additional clarity that the test procedures
are intended to cover all possible ventless clothes dryer
configurations. For this reason, DOE proposed in the June 2010 TP SNOPR
to revise section 2.1, ``Installation,'' of the DOE test procedure for
clothes dryers. The revision would add this requirement to the
installation conditions: ``if a manufacturer gives the option to use a
ventless clothes dryer with or without a condensation box, the clothes
dryer shall be tested with the condensation box installed.'' In
addition, DOE proposed to amend the testing cycle measurement in
section 3.3 to add that if the dryer automatically stops during a cycle
because the condensation box is full of water, the test is stopped, and
the test run is invalid. This requirement would ensure efficiency is
measured consistently. 75 FR 37594, 37623 (June 29, 2010).
AHAM and Whirlpool both supported the proposed change to section
2.1 of the DOE test procedure. (AHAM, No. 31 at p. 7; Whirlpool, No. 27
at p. 3) For the reasons stated above, and in the absence of comments
objecting to this proposal, DOE adopts in today's final rule the
revisions to section 2.1, Installation of the DOE clothes dryer test
procedure regarding a condensation box as proposed in the June 2010 TP
SNOPR. 75 FR 37594, 37623 (June 29, 2010).
AHAM also commented that DOE should clarify that if the
condensation box is full and the test is invalid, the re-testing should
be conducted under the same installation conditions as the original
test. Those conditions should be those provided in the manufacturer's
use and care guide so that the test is representative of actual
consumer use. (AHAM, No. 31 at p. 8) Whirlpool similarly recommended
adding, for clarity, that if the condensation box is full and the test
is invalid, that the box is to be emptied and the test re-run from the
beginning. (Whirlpool, No. 27 at p. 4) DOE agrees that additional
provisions should be included to clarify the procedure for retesting
when the condensation box is full of water and the test is considered
valid. DOE believes that Whirlpool's suggested revision provided
explicit instructions as to the procedure for re-running the test
cycle. For these reasons, DOE amends section 3.3 of the DOE clothes
dryer test procedure to add that ``if the dryer automatically stops
during a cycle and because the condensation box is full of water, the
test is stopped and the test run is invalid, in which case the
condensation box shall be emptied and the test re-run from the
beginning.''
Also regarding installation conditions, DOE believes that
Whirlpool's proposal to add a requirement that the condenser unit of
the clothes dryer must remain in place and not be taken out of the
clothes dryer for any reason between tests would clarify the test
procedure and ensures that all manufacturers are testing products under
the same conditions. For this reason, DOE proposed in the June 2010 TP
SNOPR to add in section 2.1 of the DOE clothes dryer test procedure the
provision that the condenser unit of the dryer must remain in place and
not be taken out of the dryer between tests. 75 FR 37594, 37623 (June
29, 2010).
In the June 2010 TP SNOPR, Whirlpool supported the proposed
amendment to require that the condenser unit remain in place and not be
removed between tests, adding that this is for purposes of
repeatability. Whirlpool commented that, if needed, the condenser unit
should be cleaned prior to the first test run so it does not need to be
cleaned during the test procedure. (Whirlpool, No. 27 at p. 4) ALS also
commented in support of DOE's proposed amendments regarding the
condenser unit. (ALS, No. 24 at p. 6) AHAM stated that there is no
rationale for the proposed amendment requiring the condenser unit to
remain in place and not be taken out of the clothes dryer for any
reason between tests. AHAM commented that DOE should not include that
provision. However, if it is included, it needs to be clarified. For
example, the test procedure should state how many test runs are
required. (AHAM, No. 31 at p. 7)
DOE agrees that the condenser unit may be cleaned prior to the
first test run. DOE also believes that requiring the condenser unit to
remain in place between tests ensures repeatability. As discussed later
in this section, DOE is not amending the test procedure to require
multiple test cycles. Because multiple test cycles may be necessary
under certain conditions, however, such as a requirement that if the
condensation box is full and must be emptied, the test would be re-run
from the beginning. For these reasons, DOE amends section 2.1 of the
clothes dryer test procedure regarding installation to add the
provision the condenser unit of the dryer must remain in place and not
be taken out of the dryer between tests, as proposed in the June 2010
TP SNOPR. 75 FR 37594, 37623 (June 29, 2010).
DOE stated in the June 2010 TP SNOPR that the methodology in the
current DOE test procedure for conventional (vented) clothes dryers can
be applied to ventless clothes dryers, with a number of clarifications
added. Based on starting test conditions detailed in EN Standard 61121
(section 9.1) and Whirlpool's proposed amendments, DOE proposed to
revise section 2.8 to provide a consistent and repeatable approach for
ventless clothes dryers. 75 FR 37594, 37623 (June 29, 2010). DOE noted
that this section, which addresses clothes dryer preconditioning,
currently requires that before any test cycle is initiated the clothes
dryer must be operated without a test load in the non-heat mode for 15
minutes or until the discharge air temperature varies less than 1
[deg]F during a period of 10 minutes, whichever is longer. Because a
ventless clothes dryer
[[Page 1007]]
does not have discharge air for which the temperature can be measured,
DOE proposed in the June 2010 TP SNOPR to revise this section. The
revision would require that, for ventless clothes dryers, the steady-
state temperature must be equal to the ambient room temperature
specified by section 2.2 of the existing DOE clothes dryer test
procedure before the start of all test runs. This could be done by
leaving the machine at ambient room conditions for at least 12 hours
but not more than 36 hours between tests. DOE also proposed to revise
section 2.8, ``Test loads,'' of the DOE clothes dryer test procedure to
add a qualification to the procedure for pre-conditioning that it
applies only to vented clothes dryers. Id.
AHAM commented at the public meeting that DOE should remove the
clause specifying a maximum time between tests because it did not have
supporting information to define a maximum time between tests. (AHAM,
Public Meeting Transcript, No. 20 at p. 120) AHAM later provided
written comments revising these initial statements. It stated it
supported the revisions to section 2.8 of the DOE test procedure
proposed in the June 2010 TP SNOPR, including the specification that
steady-state temperature for ventless clothes dryers may be achieved by
leaving the machine at ambient room temperature between tests for at
least 12 hours, but not more than 36 hours. (AHAM, No. 31 at pp. 7-8)
Whirlpool and ALS also supported the revisions to section 2.8 of the
DOE test procedure proposed in the June 2010 TP SNOPR. (Whirlpool, No.
27 at p. 4, ALS, No. 24 at p. 6) BSH questioned what method or
procedure might be used to get the clothes dryer back to a testable
state after a 36-hour break in testing. BSH also commented that,
occasionally, there are breaks in testing that are longer than a day
and a half; some breaks may last weeks. (BSH, Public Meeting
Transcript, No. 20 at p. 119) DOE is not aware of any data providing a
rationale for this 36-hour maximum time limit for leaving the machine
at ambient room temperature between tests to achieve steady-state
temperature. As a result, DOE amends section 2.8 of the clothes dryer
test procedure regarding clothes dryer preconditioning to include the
revisions proposed in the June 2010 TP SNOPR, as presented above, but
without the 36-hour maximum time limit for leaving the machine at room
ambient conditions for ventless clothes dryer preconditioning.
AHAM also commented that DOE should to insert the word ``machine''
before temperature when describing the machine steady-state
requirements for ventless clothes dryers. (AHAM, Public Meeting
Transcript, No. 20 at pp. 117-118) AHAM stated that for a manufacturer
running back-to-back tests, waiting 12 hours between tests is a
significant test burden. AHAM suggested replacing the word ``can'' with
``may'' regarding the 12-hour requirement to allow manufacturers to
reach the ambient room temperature by some other means of cooling the
machine, such as a fan or portable air conditioner. (AHAM, Public
Meeting Transcript, No. 20 at p. 118) BSH commented that because
ventless clothes dryers do not discharge air there needs to be a method
for determining steady state other than monitoring the discharge air
temperature. (BSH, Public Meeting Transcript, No. 20 at pp. 129-130)
DOE agrees with AHAM's comments and accepts the clarifications that
the steady-state ``machine'' temperature must be equal to ambient room
temperature. It also agrees that an additional note should clarify that
this ``may'' be done by leaving the machine at ambient room conditions
for at least 12 hours between tests. Thus, using other means to achieve
a steady-state machine temperature would be acceptable under the test
procedure provisions. In response to the comments by BSH, DOE believes
that the steady-state ``machine'' temperature clarifies that the
temperature of the actual machine itself should be monitored. For these
reasons, DOE adopts the amendments to section 2.8 of the DOE clothes
dryer test procedure for clothes dryer preconditioning proposed in the
June 2010 TP SNOPR, with the additional clarifications discussed above.
Relatedly, DOE stated in the June 2010 TP SNOPR that it agrees with
the provisions in section 9.2.2 of EN Standard 61121 and Whirlpool's
proposed amendments. These specify that the first cycle after a period
of non-operation longer than 36 hours shall not be used for evaluation,
and that, between test cycles, the door of the clothes dryer shall be
closed except for loading (and unloading). DOE noted that the first
requirement makes the first test run on an unused (dry) ventless
clothes dryer invalid, and the results from it could not be used for
the energy efficiency calculations. DOE proposed in the June 2010 TP
SNOPR to incorporate these provisions into section 3.3 of the DOE
clothes dryer test procedure. 75 FR 37594, 37623-24 (June 29, 2010).
AHAM, Whirlpool, and ALS commented in support of the proposed
requirements that after 36 hours of non-operation, the first test run
is not valid and that the door remain closed between tests except for
loading and unloading. They felt these requirements would enhance
repeatability. (AHAM, No. 31 at p. 8; Whirlpool, No. 27 at p. 4; ALS,
No. 24 at p. 6) DOE is not aware of any data providing a rationale for
why the first test run after a period of non-operation of 36 hours
would not be valid. As a result, DOE is not adopting amendments that
specify the first cycle after a period of non-operation longer than 36
hours shall not be used for evaluation. In the absence of comments
objecting to the latter proposal, DOE adopts the amendment to the
clothes dryer test procedure that, between test cycles, the door of the
tumble dryer shall be closed except for loading (and unloading), as
proposed in the June 2010 TP SNOPR. 75 FR 37594, 37623-24 (June 29,
2010).
DOE noted in the June 2010 TP SNOPR that section 9.2.1 of EN
Standard 61121 requires that at least five valid test cycles be
performed and the results averaged. DOE's clothes dryer test procedure
does not specify multiple test cycles to obtain the representative EF,
and DOE is not aware of data suggesting that test-to-test variation is
sufficient to warrant a requirement for more than one test cycle.
Therefore, DOE did not propose amendments addressing the number of
valid test cycles in the June 2010 TP SNOPR. 75 FR 37624.
ALS supported DOE's recommendation to require only one test cycle
for a valid clothes dryer test because there is no evidence that
additional tests are warranted, and additional tests would add burden
to manufacturers and test labs, without any corresponding benefit.
(ALS, No. 24 at p. 6) ALS further commented that if condensing clothes
dryers have a genuine need to run additional test cycles, ALS could
support such a requirement limited to condensing clothes dryers only.
(ALS, No. 24 at p. 6) AHAM supported a requirement for more than one
clothes dryer test cycle, but stated that the number of test cycles
should not be so high as to create a test burden. AHAM stated that it
would offer to assist DOE in determining the appropriate number of
cycles. AHAM commented that increasing the number of test cycles would
increase the repeatability and reproducibility of the test. AHAM stated
that the age of the test cloth during any given test was a source of
inherent variability that could be accounted for by introducing a
standard deviation into the related energy use calculations. AHAM
[[Page 1008]]
commented that accounting for variability is especially critical as
regulatory bodies move toward requiring third-party verification, as
the various test labs must be capable of reproducing results. (AHAM,
No. 31 at p. 8) Whirlpool recommended that each unit or model be tested
three times and the results averaged to account for test-to-test
variation. (Whirlpool, No. 27 at p. 4) The California Utilities/NRDC
also commented that it would be more accurate, and good practice, to
require multiple clothes dryer tests, but that they cannot provide any
data at this time to indicate that doing so would greatly reduce test-
to-test variation. (California Utilities/NRDC, No. 33 at p. 4)
As discussed above, DOE is not aware of any data indicating that
the test-to-test variation is sufficient to warrant a requirement for
more than one test cycle and the averaging of results. DOE is also
unaware of any data suggesting that variability in the age of the test
cloth increases the test-to-test variation of measured results for the
clothes dryer test procedure. In addition, DOE conducted limited
testing to evaluate the repeatability and reproducibility of the
amended test procedure in today's final rule. As shown below in Table
III.10, the test-to-test variation ranged from 0 percent to 2.7
percent, with an average of 0.9 percent. For these reasons, DOE is not
amending the test procedure in today's final rule to require multiple
test cycles. DOE would be open to considering such amendments in a
future rulemaking if such data is made available showing that test-to-
test variation is large enough to warrant multiple test cycles.
Table III.10--DOE Repeatability Testing for Amended Clothes Dryer Test Procedure
----------------------------------------------------------------------------------------------------------------
Average EF lb/kWh
Test unit ------------------------------------------------ Test-to-test
Test 1 Test 2 Test 3 variation %
----------------------------------------------------------------------------------------------------------------
Vented Electric Standard:
Unit 1...................................... 3.67 3.70 3.71 1.1
Unit 2...................................... 3.77 3.77 .............. 0.0
Unit 3...................................... 3.84 3.81 .............. 0.8
Unit 4...................................... 3.92 3.92 .............. 0.0
Unit 5...................................... 4.01 3.95 3.93 2.0
Unit 6...................................... 3.74 3.71 3.71 0.8
Vented Gas:
Unit 7...................................... 3.36 3.36 .............. 0.0
Unit 8...................................... 3.38 3.42 .............. 1.2
Unit 9...................................... 3.47 3.38 .............. 2.7
Unit 11..................................... 3.52 3.49 .............. 0.9
Vented Electric Compact (240V):
Unit 13..................................... 3.36 3.35 3.35 0.3
Vented Electric Compact (120V):
Unit 14..................................... 3.74 3.74 .............. 0.0
Ventless Electric Compact (240V):
Unit 15..................................... 2.71 2.66 2.70 1.9
Ventless Electric Combo Washer-Dryer:
Unit 16..................................... 2.26 2.27 .............. 0.4
Unit 17..................................... 2.76 2.74 2.78 1.5
----------------------------------------------------------------------------------------------------------------
BSH commented that if DOE is proposing single tests rather than
multiple tests with results averaged, many of the multiple test
requirements, such as those for not removing a condenser or specifying
a time period between tests, are irrelevant. BSH commented that if DOE
decides to require multiple tests, it must define a set of test runs,
and the condenser must be allowed to be removed and cleaned. Otherwise,
the total number of test runs on a particular clothes dryer would be
limited. (BSH, Public Meeting Transcript, No. 20 at p. 122) ACEEE
commented that it is possible that if only one test cycle is required
and the unit fails that test, more tests would need to be run on that
unit. Therefore, provisions concerning multiple cycles would be needed.
(ACEEE, Public Meeting Transcript, No. 20 at pp. 122-123) AHAM
commented that the DOE test procedure does not have particular
requirements for multiple test cycles, but in the general CFR there are
requirements for the manufacturer to obtain repeatable and verifiable
results. AHAM commented that DOE does not want to specify a minimum
number of tests required, but a manufacturer may need to modify the
condenser if they want or need to run multiple tests. (AHAM, Public
Meeting Transcript, No. 20 at pp. 123-124) BSH further commented that
if a manufacturer decides it is only comfortable running 5 or 10 tests,
it would be reasonable to leave the condenser in place for that number
of tests. (BSH, Public Meeting Transcript, No. 20 at p. 124)
As discussed above, multiple test runs may be necessary in cases
when a test run is considered invalid, such as when the drying cycle
stops because the condensation box is full of water and the test must
be re-run. Because there are cases in which multiple test cycles may be
required, DOE adopts the amendments discussed above related to multiple
test requirements (that is, that the condenser not be removed and that
the door be kept closed between tests).
DOE did not propose to measure the water consumption of ventless
clothes dryers in the June 2010 TP SNOPR. 75 FR 37594, 37624 (June 29,
2010). ALS objected to DOE's proposal to not measure the water
consumption of ventless ``condensing'' clothes dryers. ALS believes
that if all clothes washers are required to meet strict standards
regarding the amount of water consumed in a product that requires water
to provide consumers with adequate utility, then a condensing clothes
dryer must account for its water consumption as well. ALS commented
that DOE needs to at least require that water consumption be measured
and reported so that data is available for any future consideration of
minimum standards for the water consumption of a condensing clothes
dryer. (ALS, No. 24 at p. 6) General Electric (GE) commented that it
does not have data on how much water is consumed by
[[Page 1009]]
ventless clothes dryers that utilize an external water source to
condense moisture from the dryer steam air. GE believes, however, that
water consumption could be easily measured by placing a calibrated flow
meter on the water source. GE believes it would not be burdensome to
perform the measurement and that such measurements would provide a more
meaningful, robust measure of water use. (GE, No. 32 at p. 1) Whirlpool
commented that it is not aware of any ventless clothes dryers in the
United States that utilize water in the condensing process, and that
should such products exist, their market share would be so small as to
be immeasurable. Whirlpool commented that it does not believe that
measuring water consumption is relevant or necessary. (Whirlpool, No.
27 at p. 4)
DOE notes that EPCA allows the establishment of water use metrics,
but only for certain products. EPCA defines ``energy conservation
standard'' in relevant part as:
(A) A performance standard which prescribes a minimum level of
energy efficiency or a maximum quantity of energy use, or, in the case
of showerheads, faucets, water closets, and urinals, water use, for a
covered product, determined in accordance with test procedures
prescribed under section 6293 of this title; (42 U.S.C. 6291(6)(A))
In addition, DOE regulates the water use of clothes washers based on
the water conservation standards set by Congress in 42 U.S.C.
6295(g)(9).
Clothes dryers do not belong to the group of products specified by
EPCA for which DOE can set a water use standard. As a result, DOE is
not amending the clothes dryer test procedure in today's final rule to
establish a water use metric or to include a requirement to measure the
water consumption for ventless condensing clothes dryers.
DOE also stated that the results from DOE's tests at an independent
laboratory are representative of the repeatability of results that
would be observed using the testing procedures proposed in the June
2010 TP SNOPR. 75 FR 37594, 37624 (June 29, 2010). Although DOE's tests
were conducted using the alternate test procedure that provided
separate definitions for a ``conventional clothes dryer'' and a
``condensing clothes dryer'' and that simply required use of the
exhaust simulator only for vented clothes dryers, DOE stated that the
additional clarifications proposed in the June 2010 TP SNOPR would not
significantly affect these testing results because they do not affect
the the test cycle measurement method. Therefore, DOE stated that the
amendments to the test procedure for ventless clothes dryers proposed
in the June 2010 TP SNOPR would produce accurate and repeatable
measurements of EF. Id.
To further support its assertion, after issuance of the June 2010
TP SNOPR, DOE conducted three identical tests on one ventless electric
compact (240V) clothes dryer and two identical tests on one ventless
electric combination washer/dryer to evaluate the repeatability of the
proposed test procedure for ventless clothes dryers. Testing results,
presented in Table III.11, showed 0.8-percent and 3.5-percent variation
in EF from test to test for the ventless electric compact (240V) and
ventless electric combination washer-dryer, respectively. The test-to-
test variation shown below is comparable to the test-to-test variation
shown in Table III.10 (conducted according to the alternate test
procedure that provided separate definitions for a ``conventional
clothes dryer'' and a ``condensing clothes dryer'' and that simply
required use of the exhaust simulator only for vented clothes dryers).
The slightly greater test-to-test variation observed in Table III.11
may be attributed to other test procedure tolerances, such as the
allowable ranges in ambient temperature and relative humidity. DOE
continues to believe that the amendments adopting in today's final rule
for ventless clothes dryers produce accurate and repeatable
measurements of EF.
Table III.11--DOE Repeatability Testing for Ventless Clothes Dryer Amendments
----------------------------------------------------------------------------------------------------------------
EF lb/kWh
Test unit ------------------------------------------------ Test-to-test
Test 1 Test 2 Test 3 variation %
----------------------------------------------------------------------------------------------------------------
Ventless Electric Compact (240V) (Unit 15)...... 2.36 2.38 2.37 0.8
Ventless Electric Combo Washer-Dryer (Unit 16).. 2.05 1.98 .............. 3.5
----------------------------------------------------------------------------------------------------------------
4. Detergent Specifications for Clothes Dryer Test Cloth
Preconditioning
Section 2.6.3 of the current DOE clothes dryer test procedure
specifies that the test cloth be preconditioned by performing a 10-
minute wash cycle in a standard clothes washer using AHAM Standard Test
Detergent IIA. 10 CFR part 430, subpart B, appendix D, section 2.6.3.
This detergent is obsolete and no longer available from AHAM or other
suppliers. The current AHAM standard detergent is identified as AHAM
standard test detergent Formula 3. Because AHAM Standard detergent IIA
is no longer available to manufacturers, DOE proposed in the June 2010
TP SNOPR to amend section 2.6.3 of the clothes dryer test procedure to
specify the use of AHAM standard test detergent Formula 3 in test cloth
preconditioning. 75 FR 37594, 37624 (June 29, 2010).
Clothes washer tests that DOE conducted with AHAM standard test
detergent Formula 3 suggest the dosage specified in section 2.6.3(2) of
the DOE clothes dryer test procedure for AHAM Standard detergent IIA
(6.0 grams (g) per gallon of water) may no longer be appropriate. This
is because at the end of clothes washer test cloth preconditioning,
which specifies the same dosage, undissolved clumps of detergent were
observed in the cloth load. Further, DOE conducted extractor tests that
indicate that detergent dosage impacts RMC measurements by as much as
several percent.
AHAM's clothes dryer test procedure, AHAM HLD-1-2009, specifies a
standard test detergent Formula 3 dosage of 27 g + 4.0 g/lb of base
test load for test cloth pre-treatment. For DOE's clothes dryer test
cloth preconditioning, the current test procedure specifies that
clothes washer water fill level be set to the maximum level, regardless
of test load size. In the June 2010 TP SNOPR, DOE proposed to amend the
test load size for standard-size clothes dryers to 8.45 lb
.085 lb (see section III.C.5.c.), which would result in a detergent
dosage of AHAM standard test detergent Formula 3 of 60.8 g. DOE stated
that the detergent concentration should be set by the pounds of test
cloth in this standard-size test load because this load is more closely
matched to the maximum water fill level than is the compact-size test
load (3.0 lb .03 lb). For preconditioning a compact-size
test load, DOE proposed that the same
[[Page 1010]]
detergent dosage be specified because the water fill level would remain
the same as for the larger load, resulting in the same concentration of
the water/detergent mixture. 75 FR 37594, 37624 (June 29, 2010).
To address the problems associated with the current dosage
specification in the DOE clothes dryer test procedure, DOE proposed in
the June 2010 TP SNOPR to amend section 2.6.3 of the clothes dryer test
procedure. The amendment would require 60.8 g of AHAM standard test
detergent Formula 3 be used to precondition test cloth. Id.
AHAM, Whirlpool, and ALS supported DOE's proposed detergent
specifications. (AHAM, No. 31 at p. 8; Whirlpool, No. 27 at p. 4; ALS,
No. 24 at p. 6) Whirlpool also strongly recommended that the test cloth
be preconditioned in the same way when used in tests for both clothes
washers and clothes dryers. This would enable test cloth with common
characteristics to be interchanged between the two products, which
would result in increased repeatability. (Whirlpool, No. 27 at p. 4)
For the reasons stated above and in the absence of comments objecting
to this proposal, DOE amends its clothes dryer test procedure in
today's final rule to revise the detergent specifications for test
cloth preconditioning as proposed in the June 2010 TP SNOPR. 75 FR
37594, 37624 (June 29, 2010). DOE will address detergent specifications
for test cloth preconditioning for the clothes washer test procedure in
the test procedure rulemaking for that product.
5. Changes To Reflect Current Usage Patterns and Capabilities
a. Clothes Dryer Number of Annual Cycles
As noted above, DOE most recently amended its test procedure for
residential clothes dryers in a final rule published in the Federal
Register on May 19, 1981. 46 FR 27324. Although DOE has updated its
test procedure for residential clothes washers since that time,\33\ it
has not updated its residential clothes dryer test procedure. In the
revised residential clothes washer test procedure, the average number
of annual use cycles was revised to reflect current (at the time)
consumer use patterns. DOE noted in the October 2007 Framework Document
that the average number of clothes dryer use cycles assumed in the
revised clothes washer test procedure is different from the number of
use cycles in the clothes dryer test procedure. (Framework Document,
STD No. 1 at p. 4)
---------------------------------------------------------------------------
\33\ See 62 FR 45484, 45498 (Aug. 27, 1997).
---------------------------------------------------------------------------
In the June 2010 TP SNOPR, DOE reviewed available data to determine
the number of annual clothes dryer use cycles so that it could amend
its test procedure to accurately reflect current consumer usage habits.
DOE reviewed the 2004 California Statewide RASS, which surveyed
appliance product usage patterns, including clothes dryers.\34\ The
study surveyed 7,686 households between 2002 and 2003, asking the
question ``how many loads of clothes do you dry in your clothes dryer
during a typical week?'' For the 6,790 of these households that said
they owned a clothes dryer, average usage was 4.69 loads per week, or
approximately 244 loads per year. Because this study provides only a
limited dataset, however, DOE stated in the June 2010 TP SNOPR that it
did not intend to rely only on this data to determine an appropriate
number of annual use cycles for the clothes dryer test procedure. 75 FR
37594, 37625 (June 29, 2010).
---------------------------------------------------------------------------
\34\ KEMA, Inc. op. cit. p. 118. For more information visit:
http://www.energy.ca.gov/appliances/rass/.
---------------------------------------------------------------------------
In the June 2010 TP SNOPR, DOE also reviewed data from the 2005
RECS to determine the annual usage of clothes dryers. RECS is a
national sample survey of housing units that collects statistical
information on the consumption of and expenditures for energy in
housing units along with data on energy-related characteristics of the
housing units and occupants. RECS provides enough information to
establish the type (that is, product class) of clothes dryer used in
each household, the age of the product, and an estimate of the
household's annual energy consumption attributable to clothes dryers.
DOE estimated the number of clothes dryer cycles per year for each
sample home using data given by RECS on the number of laundry loads
(clothes washer cycles) washed per week and the frequency of clothes
dryer use. Based on its analysis of RECS data, DOE estimated the
clothes dryer usage factor (the percentage of washer loads dried in a
clothes dryer) to be 91 percent and the calculated average usage to be
283 cycles per year for all product classes of clothes dryers. DOE also
noted that the RECS data shows that the number of clothes washer and
clothes dryer cycles has been decreasing steadily for a number of years
to the extent that a historical trend has been established. Because
this dataset is more extensive than that of the RASS, DOE believes
these numbers are more representative of annual usage patterns.
Therefore, DOE proposed in the June 2010 TP SNOPR to amend the number
of annual use cycles in its test procedure to 283 cycles for all
product classes of clothes dryers. 75 FR 37594, 37625 (June 29, 2010).
AHAM supported DOE's proposal to amend the number of annual use
cycles to 283 cycles for all product classes of clothes dryers. AHAM
stated, however, that it continues to oppose using 2005 RECS data to
support this change without verification of the RECS estimates. AHAM
commented that the results from a recent survey by Procter & Gamble
(P&G) indicated that 5.2 to 5.35 loads per household with a clothes
dryer are dried per week, or 279 clothes dryer loads per year. AHAM
noted this number is similar to that derived from the 2005 RECS data
and therefore, it supported the change in the number of clothes dryer
annual use cycles to 283. (AHAM, No. 31 at p. 8; AHAM, Public Meeting
Transcript, No. 20 at p. 137)
The California Utilities/NRDC, the Joint Petitioners, Whirlpool,
and ALS also commented in support of DOE's proposal of 283 annual use
cycles. (California Utilities/NRDC, No. 33 at p. 5; Joint Petitioners,
No. 30 at p. 7; Whirlpool, No. 27 at p. 4; ALS, No. 24 at p. 7) The
California Utilities/NRDC noted that the California 2005 RASS, which
indicates a weighted-average for California of 235 annual use cycles is
fairly consistent with DOE's number and with the overall trend of
decreasing yearly use cycles. (California Utilities/NRDC, No. 33 at p.
5) Whirlpool also noted that in its April 26, 2010 comments that it
recommended 288 cycles per year, which is essentially consistent with
DOE's recommendation of 283 cycles per year. (Whirlpool, No. 27 at p.
4)
DOE notes there is close agreement between the estimates provided
by interested parties and DOE's estimate based on the data reviewed by
DOE, and there were no comments objecting to its proposal. Therefore,
DOE amends the clothes dryer test procedure to change the number of
annual use cycles to 283 cycles for all product classes of clothes
dryers.
b. Clothes Dryer Initial Remaining Moisture Content
In the revised residential clothes washer test procedure, a new
parameter, the RMC of the test cloth, was introduced. 68 FR 62198,
62199 (October 31, 2003). The clothes washer RMC is the ratio of the
weight of water contained within the test load at the completion of the
clothes washer energy test cycle to the bone-dry weight of the
[[Page 1011]]
test load, expressed as a percent. Correspondingly, the initial RMC of
a clothes load being dried is a function of RMC at the end of a clothes
washer cycle. The current DOE clothes dryer test procedure specifies an
initial RMC of 70 3.5 percent. Similar to the discussion
above of the average number of use cycles per year, the RMC of typical
clothes loads in the residential clothes washer test procedure should
be consistent with values defined in the clothes dryer test procedure.
For the reasons explained below, however, DOE believes that the initial
RMC in the clothes dryer test procedure may not reflect typical RMCs of
actual clothes dryer loads.
DOE notes that the revision to the clothes washer test procedure
changed the clothes washer energy conservation standards metric to a
modified energy factor (MEF). This established a method for measuring
the RMC for clothes washers. This RMC is then used to estimate the
energy required by a clothes dryer to dry the clothes load. This
estimate is then factored in to the calculation of MEF to account for
clothes washers that reduce the estimated energy required to dry the
clothes load in a clothes dryer. (10 CFR part 430, subpart B, appendix
J1, section 4.3) Since the clothes dryer test procedure was last
amended in 1981 (46 FR 27324 (May 19, 1981)), average clothes washer
RMC has decreased due to the introduction of higher efficiency models
with higher final spin speeds. Therefore, while clothes dryer energy
use has decreased with the lower RMC, clothes washer energy use has
increased somewhat to achieve the higher spin speeds. This energy use
is accounted for in the residential clothes washer energy conservation
standards rulemaking. In the clothes washer test procedure final rule
published in the Federal Register on January 12, 2001, DOE estimated
RMCs at specific efficiency levels. 66 FR 3314. For the residential
clothes washer standard which became effective January 1, 2007 (1.26
MEF), DOE estimated a weighted-average RMC of 56 percent.
As discussed in section I, the EF for clothes dryers is determined
by measuring the total energy required to dry a standard test load of
laundry to a ``bone dry'' state. If today's clothes dryer loads have
initial RMCs lower than the nominal 70 percent specified in the
existing DOE clothes dryer test procedure, revisions to the test
procedure to reflect more realistic (that is, lower) RMCs would result
in the current EF rating increasing for a given clothes dryer. This is
because the clothes dryer would have less water to remove.
As part of the preliminary analyses for the residential clothes
dryer energy conservation standards rulemaking, DOE used a distribution
of values for models listed in the December 12, 2008 CEC product
database to estimate the RMC of clothes washers. For products for which
the RMC was listed, DOE noted in the June 2010 TP SNOPR that the RMC
values ranged from 30 percent to 61 percent, with an average of 46
percent. 75 FR 37594, 37626 (June 29, 2010).
As part of the October 2007 Framework Document, DOE requested data
from AHAM showing the shipments of residential clothes washers for
which RMC was reported, along with shipment-weighted RMC (See Table
III.12). These data sets, each including disaggregated data for front-
loading and top-loading clothes washers, as well as reported overall
values for all units, provide insight into what initial clothes dryer
RMC would be most representative of current residential clothes
washers. As noted above, however, AHAM indicated that the data contain
only shipments for which the RMC was reported, and thus the total will
not be equal to actual shipments reported for 2000-2008. The data
indicate that RMC has been decreasing consistently, from about 54
percent in 2000 to 47 percent in 2008. The data also suggest that the
initial RMC of nominally 70 percent in the DOE clothes dryer test
procedure is greater than the current shipment-weighted residential
clothes washer average RMC.
Table III.12--AHAM Shipment-Weighted Clothes Washer RMC Data Submittal \35\
----------------------------------------------------------------------------------------------------------------
Clothes washer shipments for which Shipment-weighted RMC (%)
RMC was reported --------------------------------------
Year ---------------------------------------
Front- Front- Top-loading Total
loading Top-loading Total loading
----------------------------------------------------------------------------------------------------------------
2000.............................. 232,714 686,440 919,154 43.6 57.4 53.9
2001.............................. 235,989 473,629 709,618 41.3 57.7 52.2
2002.............................. 280,667 529,265 809,932 41.5 58.1 52.3
2003.............................. 351,411 1,676,877 2,028,288 43.1 54.5 52.5
2004.............................. 1,179,813 5,270,285 6,450,098 42.2 52.8 50.9
2005.............................. 1,563,108 5,394,511 6,957,619 40.8 52.7 50.1
2006.............................. 1,851,218 5,628,279 7,479,497 39.3 51.4 48.4
2007.............................. 1,973,825 5,371,142 7,344,967 38.3 51.4 47.8
2008.............................. 2,043,024 4,492,059 6,535,083 38.1 51.0 47.0
----------------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------
\35\ AHAM, 2009. AHAM Weighted RMC for Front Load and Top Load
Units, 2000-2008--DOE Clothes Dryer Rulemaking, Secondary Data
Request. July 7, 2009. Docket No. EE-2007-BT-STD-0010, Comment
Number 18.
---------------------------------------------------------------------------
Based on its analysis of the shipment-weighted RMC data submitted
by AHAM, as well as its own review of the CEC residential clothes
washer database, DOE stated in the June 2010 TP SNOPR that an initial
RMC of 47 percent is representative of current residential clothes
dryer initial test load characteristics. Therefore, DOE proposed to
amend section 2.7, ``Test loads,'' of the clothes dryer test procedure
to require the initial RMC be changed from 70 3.5 percent
to 47 percent. DOE further proposed to eliminate the 3.5
percent allowable range in RMC. This is because the proposed amendments
to the DOE clothes dryer test procedure for automatic cycle
termination, detailed in section III.C.2, would require that the test
load be initially prepared to between 42- and 47-percent RMC. The
proposed amendments would also require final adjustments be made to the
RMC to achieve 47-percent 0.33-percent RMC to account for
over-drying energy consumption. 75 FR 37594, 37627 (June 29, 2010).
In the June 2010 TP SNOPR, DOE proposed that if it does not adopt
the proposed amendments for testing automatic cycle termination, but
adopts only these aforementioned proposed
[[Page 1012]]
amendments to change the initial RMC, it could specify an initial RMC
of 47 3.5 percent. In that case, the tolerance of 3.5 percent on the nominal initial RMC, as currently specified
in DOE's test procedure, would allow the same flexibility in test cloth
preparation as is currently allowed. 75 FR 37594, 37627 (June 29,
2010).
DOE also noted in the June 2010 TP SNOPR that the current test
procedure contains a provision in the calculation of per-cycle energy
consumption intended to normalize EF by the reduction in RMC over the
course of the drying cycle. A scaling factor of 66 is applied,
representative of the percentage change from the nominal initial RMC of
70 percent to the nominal ending RMC of 4 percent. DOE noted, however,
that the proposed changes to account for automatic cycle termination,
as presented above in section III.C.2, would require amending the
calculations for the per-cycle energy consumption to remove the need
for this scaling factor. Therefore, DOE did not propose to amend the
scaling factor in the June 2010 TP SNOPR. 75 FR 37594, 37627 (June 29,
2010). DOE proposed that if it does not adopt the proposed amendments
for testing automatic cycle termination, but adopts only these
aforementioned proposed amendments to change the initial RMC, it could
change the scaling factor to 43 to reflect a starting RMC of 47
percent. Id.
AHAM, the California Utilities/NRDC, and the Joint Petitioners all
supported an initial RMC of 47 percent. (AHAM, No. 31 at p. 9;
California Utilities/NRDC, No. 33 at p. 5; Joint Petitioners, No. 30,
at p. 7) AHAM provided data to support this approach in their April 26,
2010 comments. (AHAM, No. 31 at p. 9) Whirlpool also commented that
DOE's proposal of 47 1 percent RMC is consistent with its
recommendation from its April 26, 2010 comments. (Whirlpool, No. 27 at
p. 4)
ALS objected to DOE's proposal to utilize 47-percent initial RMC.
ALS commented that the current clothes dryer test procedure uses
``raw'' non-correction factored RMC values, unlike the values DOE used
to arrive at the national average of 47-percent RMC. The data DOE used
was based on shipment-weighted average clothes washer data supplied by
AHAM that had a correction factor applied to account for extraction.
(ALS, No. 24 at p. 7; ALS, Public Meeting Transcript, No. 20 at p. 141)
ALS commented that DOE should be using raw RMC values from the clothes
washer, because the current clothes dryer test uses raw values and
there is a significant difference between ``raw'' RMC values and
``correction-factored'' RMC values. ALS stated that it conducted tests
on front-load washers (both its own and those of its competition) that
resulted in raw RMC values of around 50 percent, compared to the 41-
percent RMC derived when the correction factor is applied. This is a
difference of 9 RMC percentage points, which is a 18-percent relative
difference. ALS added that it is apparent that if ``raw'' values of
washer RMC were analyzed by DOE, the national average would be closer
to 53-55 percent. ALS acknowledged that no database exists of ``raw''
shipment-weighted average RMC values for clothes washers. ALS suggested
DOE perform limited clothes washer tests to confirm the ALS results
regarding the ``raw'' versus ``correction-factored'' RMC values, and
adjust the proposed 47-percent value to align more closely to the ALS-
suggested value of 53 percent. (ALS, No. 24 at p. 7) ALS also commented
that manufacturers prefer to utilize their own production front-loading
clothes washers to prepare test loads per the DOE clothes dryer test
procedure. However, they would find it more difficult to achieve DOE's
proposed 47-percent RMC when the front-loader in their labs can only
achieve raw values at 50-percent RMC in default DOE test program
cycles. (ALS, No. 24 at p. 7) ALS did not recommend adding in
correction factors to the clothes dryer test procedure to raise the
initial RMC higher to reflect the uncorrected value. (ALS, Public
Meeting Transcript, No. 20 at p. 143)
DOE first notes that it proposed an initial RMC of 47 percent
3.5 percent, not 1 percent as commented by
Whirlpool. DOE agrees with ALS that the clothes dryer test procedure
should be using a ``raw'' uncorrected RMC value and not the corrected
RMC values in the data submitted by AHAM. DOE understands that in the
clothes washer test procedure, an RMC correction factor curve is
applied to account for the different extraction rates of different test
cloth lots in order to calculate a corrected RMC value. The correction
factor curve uses the following equation: RMCcorrected = A x
RMCmeasured + B, where RMCmeasured is the
measured RMC after the clothes washer spin cycle and A and B are
coefficients based on extraction testing using a linear least-squares
fit to relate the standard RMC to the measured extraction RMC value.
(The standard RMC is provided in table 2.6.6.1 of the clothes washer
test procedure.) DOE notes that in 2008, the latest year for which
shipment-weighted average corrected RMC values were provided in the
AHAM data, the most recent test cloth lot was lot 16. DOE acknowledges,
however, that manufacturers and testing labs were likely using previous
test cloth lots for the RMC values reported in the AHAM data. For this
reason, DOE estimated the 2008 uncorrected RMC value by using the RMC
correction factor curves from lots 12 through 16 and averaging the
results. As shown in Table III.13, the results showed an average
uncorrected RMC value of 57.5 percent.
Table III.13--DOE Clothes Washer Test Procedure Test Cloth Lot RMC Correction Factor Data
----------------------------------------------------------------------------------------------------------------
2008 Shipment-
weighted
Lot Coefficient A Coefficient B average
uncorrected RMC
(percent)
----------------------------------------------------------------------------------------------------------------
2008 Shipment- 12 0.7165 0.0505 65.5
Weighted 13 0.8828 0.0015 53.2
Average 14 0.8970 0.0014 52.4
Corrected RMC 15 0.89904 -0.04284 52.3
= 47.0% 16 0.73478 0.03174 63.9
Average ............... ............... 57.5
----------------------------------------------------------------------------------------------------------------
To validate this estimate, DOE examined the uncorrected RMC data
from tests of 17 residential clothes washer (9 front-loading and 8 top-
loading units) it conducted for the residential clothes washer energy
conservation standards rulemaking preliminary analyses. The results
from DOE's testing are shown below in Table III.14. Taking the average
RMC for each product class (that is, front-loading and top-loading) and
weighting the average
[[Page 1013]]
RMCs by the shipments for each product class resulted in a shipment-
weighted average uncorrected RMC of 58.1 percent, which is in close
agreement with the 57.5-percent uncorrected RMC estimated by DOE using
the RMC correction factor curves.
Table III.14--DOE Clothes Washer Testing Uncorrected RMC Results
------------------------------------------------------------------------
Uncorrected
Test unit RMC %
------------------------------------------------------------------------
Front-Loading Clothes Washers (2008 Shipments =
3,022,077):
Unit 1................................................ 43.7
Unit 2................................................ 58.9
Unit 3................................................ 55.9
Unit 4................................................ 49.3
Unit 5................................................ 49.5
Unit 6................................................ 38.5
Unit 7................................................ 50.7
Unit 8................................................ 45.3
Unit 9................................................ 45.4
Top-Loading Clothes Washers (2008 Shipments =
5,269,625):
Unit 10............................................... 67.7
Unit 11............................................... 94.3
Unit 12............................................... 48.4
Unit 13............................................... 60.5
Unit 14............................................... 65.2
Unit 15............................................... 67.1
Unit 16............................................... 54.2
Unit 17............................................... 50.3
Shipment-Weighted Average............................. 58.1
------------------------------------------------------------------------
DOE estimated the uncorrected RMC value using shipment-weighted
average corrected RMC data submitted by AHAM and the RMC correction
factor curves for test cloth lots 12 through 16. Based on that
estimate, DOE believes an initial RMC of 57.5 percent more accurately
represents the moisture content of a load entering the clothes dryer
after the wash cycle for the purposes of clothes dryer testing. As a
result, DOE amends the clothes dryer test procedure in today's final
rule to change the initial RMC to 57.5 percent 3.5
percent. In addition, DOE changes the scaling factor in the calculation
of the per-cycle energy consumption that is intended to normalize EF by
the reduction in RMC over the course of the drying cycle from a value
of 66 to 53.5 (That value is the difference of 57.5-percent initial RMC
minus 4-percent nominal final RMC).
DOE tested 13 representative clothes dryers to evaluate the affect
of this amendment to the initial RMC for clothes dryer test load
preparation on test repeatability. DOE tested these units according to
the current DOE clothes dryer test procedure, except that the initial
RMC was changed to 57.5 percent 3.5 percent. For the
ventless clothes dryer test units, DOE additionally used the proposed
testing method for ventless dryers presented in section III.C.3. As
shown below in Table III.15, the test-to-test variation ranged from 0.3
percent to 1.8 percent, with an average of 0.9 percent. For this
reason, DOE believes that the amendments to the initial RMC for clothes
dryer test load preparation produce repeatable test results.
Table III.15--DOE Repeatability Testing for 57.5 Percent Initial RMC
----------------------------------------------------------------------------------------------------------------
Average EF lb/kWh Test-to-
Test unit --------------------------------- test
Test 1 Test 2 Test 3 variation %
----------------------------------------------------------------------------------------------------------------
Vented Electric Standard:
Unit 1........................................................ 3.68 3.67 ......... 0.3
Unit 3........................................................ 3.84 3.81 3.82 0.8
Unit 4........................................................ 3.79 3.80 3.78 0.5
Unit 5........................................................ 3.93 3.88 3.92 1.3
Unit 6........................................................ 3.70 3.71 ......... 0.3
Vented Gas:
Unit 7........................................................ 3.32 3.32 3.31 0.3
Unit 8........................................................ 3.41 3.44 ......... 0.9
Unit 9........................................................ 3.23 3.21 3.25 1.2
Unit 10....................................................... 3.27 3.31 3.28 1.2
Unit 11....................................................... 3.38 3.41 3.43 1.5
Vented Electric Compact (240V):
Unit 12....................................................... 3.61 3.62 3.61 0.3
Unit 13....................................................... 3.46 3.48 3.42 1.8
Ventless Electric Combo Washer-Dryer:
Unit 16....................................................... 2.35 2.31 2.34 1.7
----------------------------------------------------------------------------------------------------------------
c. Clothes Dryer Test Load Weight
The current DOE clothes dryer test procedure requires a 7.00 lb
.07 lb test load for standard-size clothes dryers and a
3.00 lb .03 lb test load for compact-size clothes dryers.
In response to comments it received on the October 2007 Framework
Document, DOE investigated in the June 2010 TP SNOPR whether the
average test load weight for standard-size clothes dryers is valid for
use in light of the capacities of the current generation of clothes
washer. 75 FR 37594, 37631 (June 29, 2010).
DOE contacted detergent manufacturers to obtain data on average
residential clothes washer load sizes. P&G conducted an internal study
in 2003 on household laundry habits on a representative set of the
population across the United States, from which P&G provided relevant
summary data to DOE for this rulemaking. The clothes washer load weight
data, based on a sample size of 3367 loads of laundry from a total of
510 respondents, showed that the average load size for top-loading and
front-loading clothes washers was 7.2 lb and 8.4 lb, respectively.
(P&G, No. 15 at p. 1) Based on the average shipment-weighted market
share for top-loading and front-loading clothes washers between 2000
and 2008 from data submitted by AHAM (shown in Table III.12), the
shipment-weighted average clothes washer load size would be
approximately 7.5 lb. DOE stated in the June 2010 TP SNOPR, however,
that clothes washer capacities were likely to have increased since the
survey was conducted in 2003. Therefore, DOE factored into its analysis
these capacity changes to estimate a more current
[[Page 1014]]
average load size. 75 FR 37594, 37631 (June 29, 2010).
Table III.16 shows the trends of the shipment-weighted average tub
volume for residential clothes washers from 1981 to 2008, based on data
from the AHAM Trends in Energy Efficiency 2008. The shipment-weighted
average tub volume has increased from 2.52 ft\3\ in 1981 to 3.22 ft\3\
in 2008.
Table III.16--Residential Clothes Washer Shipment-Weighted Average Tub
Volume Trends \36\
------------------------------------------------------------------------
Shipment-
weighted
Year average tub % Change
volume since 1990
(ft3)
------------------------------------------------------------------------
1981.......................................... 2.52 ...........
1990.......................................... 2.63 ...........
1991.......................................... 2.72 3.4
1992.......................................... 2.71 3.0
1993.......................................... 2.71 3.0
1994.......................................... 2.69 2.3
1995.......................................... 2.72 3.4
1996.......................................... 2.80 6.5
1997.......................................... 2.83 7.6
1998.......................................... 2.85 8.4
1999.......................................... 2.89 9.9
2000.......................................... 2.92 11.0
2001.......................................... 2.96 12.5
2002.......................................... 2.96 12.5
2003.......................................... 3.01 14.4
2004.......................................... 3.05 16.0
2005.......................................... 3.08 17.2
2006.......................................... 3.13 19.2
2007.......................................... 3.16 20.3
2008.......................................... 3.22 22.4
------------------------------------------------------------------------
Section 2.7, ``Test Load Sizes,'' in the DOE clothes washer test
procedure provides the minimum, maximum, and average test load size
requirements for the clothes washer test, which are based on the
clothes container capacity. Table III.17 shows the minimum, maximum,
and average test load sizes for 2.52 ft\3\ and 3.22 ft\3\ container
capacities according to Table 5.1 in the DOE clothes washer test
procedure.
---------------------------------------------------------------------------
\36\ Association of Home Appliance Manufacturers, Trends in
Energy Efficiency 2008. p. 3. Washington, DC. Available at: http://www.aham.org/ht/d/Store.
Table III.17--DOE Clothes Washer Test Load Size Requirements (From Table
5.1 of 10 CFR 430 Subpart B, Appendix J1)
------------------------------------------------------------------------
Minimum Maximum Average
Container volume ft3 load lb. load lb. load lb.
------------------------------------------------------------------------
>= 2.50 to < 2.60...................... 3.00 10.50 6.75
>= 3.20 to < 3.30...................... 3.00 13.30 8.15
------------------------------------------------------------------------
DOE notes that the average load size in the clothes washer test
procedure increases by about 21 percent when the container volume
increases in capacity, which DOE believes is the degree to which
container volume impacts clothes dryer load sizes. Applying this ratio
of average clothes washer test load sizes to the clothes dryer test
load size would result in an increase from 7.00 lb to 8.45 lb for
standard-size clothes dryers currently available. For these reasons,
DOE proposed to amend the clothes dryer test load size to 8.45 lb for
standard-size clothes dryers in the June 2010 TP SNOPR. 75 FR 37594,
37632 (June 29, 2010). DOE proposed to amend the test load size based
on the change in average load size for clothes washers rather than the
maximum load size because data from the 2005 RECS indicates that not
all clothes that are washed are machine dried. Therefore, DOE believes
that average clothes washer load size would be more representative of
clothes dryer load size. DOE also proposed to maintain the 1-percent
tolerance in load sizes specified by the current DOE test procedure for
standard-size clothes dryers (8.45 lb .085 lb). Id.
ALS commented that the clothes dryer test procedure amendments are
related to the clothes washer test procedure. It stated that if there
are any changes to the clothes washer test procedure in an upcoming
rulemaking, especially to the average load size or the load size chart,
the effect of those changes on the clothes dryer test procedure must be
considered. (ALS, Public Meeting Transcript, No. 20 at p. 171) DOE
recently published a NOPR proposing amendments to the test procedure
for clothes washers and welcomes comments on that proposal as stated in
the NOPR. 75 FR 57556 (September 21, 2010). Because DOE has not
published a final rule amending the clothes washer test procedure,
however, the issue of how any such amendments might influence
conditions for the final amended clothes dryer test procedure is not
relevant at this time. DOE may consider this issue in a future
rulemaking.
AHAM, Whirlpool, ALS, the California Utilities/NRDC, and the Joint
Petitioners commented in support of the proposed amendment to change
the clothes dryer load size to 8.45 0.085 lb for standard-
size clothes dryers. (AHAM, No. 31 at p. 9; Whirlpool, No. 27 at p. 5,
ALS, No. 24 at p. 7, California Utilities/NRDC, No. 33 at p. 5, Joint
Petitioners, No. 30 at p. 7) For the reasons stated above and in the
absence of comment objecting to this proposal, DOE amends the clothes
dryer test procedure in today's final rule to change the clothes dryer
load size to 8.45 0.085 lb for standard-size clothes
dryers.
DOE stated in the June 2010 TP SNOPR that most compact clothes
dryers are used with compact-size clothes washers, and that DOE does
not have any information to suggest that the tub volume of such clothes
washers has changed significantly. Therefore, DOE did not propose to
change the 3-lb test load size currently specified in the test
procedure for compact clothes dryers in the June 2010 TP SNOPR. DOE
sought data on the historical trends of compact-size clothes washer
average tub volumes or any other data that would suggest a change in
the clothes dryer test load size for compact clothes dryers.
AHAM and the Joint Petitioners commented in support of maintaining
the 3-lb load size for compact clothes dryers until there is sufficient
data upon which to base a change. (AHAM, No. 31
[[Page 1015]]
at p. 9; Joint Petitioners, No. 30 at p. 7) For these reasons, DOE is
not amending the test procedure to change the load size for compact
clothes dryers.
DOE tested 8 representative clothes dryers to evaluate the affect
of this amendment to the test load weight for standard-size clothes
dryers on test repeatability. DOE tested these units according to the
current DOE clothes dryer test procedure, except that the test load
size was changed to 8.45 lb .085 lbs for standard-size
clothes dryers. As shown below in Table III.18, the test-to-test
variation ranged from 0.0 percent to 2.9 percent, with an average of
1.6 percent. For this reason, DOE believes that the amendments to the
test load weight in the clothes dryer test procedure produce repeatable
test results.
Table III.18--DOE Repeatability Testing for 8.45 lb .085 lb
Test Load for Standard-Size Clothes Dryers
------------------------------------------------------------------------
Average EF lb/kWh Test-to-
Test unit ---------------------- test
Test 1 Test 2 variation %
------------------------------------------------------------------------
Vented Electric Standard:
Unit 1........................... 3.13 3.13 0.0
Unit 4........................... 3.20 3.27 2.2
Unit 6........................... 3.53 3.47 1.7
Unit 7........................... 3.33 3.34 0.3
Unit 8........................... 3.18 3.09 2.9
Vented Gas:
Unit 10.......................... 2.85 2.86 0.4
Unit 11.......................... 2.96 2.89 2.4
Unit 13.......................... 2.81 2.73 2.9
------------------------------------------------------------------------
d. Room Air Conditioner Annual Operating Hours
The DOE test procedure currently assumes room air conditioners have
an average annual use of 750 hours. DOE's technical support document
from September 1997, issued in support of the most recent room air
conditioner energy conservation standards rulemaking, shows that the
average annual operational hours are closer to 500 hours.\37\ That
average would yield approximately 33-percent lower annual energy
consumption than the annual energy consumption determined using the 750
operational hours assumed in the current test procedure.
---------------------------------------------------------------------------
\37\ U.S. Department of Energy--Office of Energy Efficiency and
Renewable Energy, Technical Support Document for Energy Conservation
Standards for Room Air Conditioners. September 1997. Chapter 1,
section 1.5. Washington, DC. http://www.eere.energy.gov/buildings/appliance_standards/residential/room_ac.html.
---------------------------------------------------------------------------
DOE acknowledged the uncertainty regarding room air conditioner
usage patterns and investigated the annual hours of usage from a range
of information sources to develop an updated estimate of annual
operating hours for the June 2010 TP SNOPR. 75 FR 37594, 37633 (June
29, 2010). DOE's investigation revealed a lack of metered and survey
data for the operating hours of individual room air conditioners. DOE
found that estimates of the annual operating hours of use were often
based on regional climatic data rather than actual room air conditioner
use. DOE did find two sources of survey data on room air conditioner
use in the EIA's 2005 RECS (and previous versions) and the CEC
California Statewide RASS. The CEC survey contained only aggregated
residential data, which limited any analysis pertaining to the annual
operating hours. EIA's 2005 RECS provides extensive data on individual
residences, while providing a more expansive and representative sample
of households. Thus, DOE continued its analysis using EIA's 2005 RECS.
Id.
The 2005 RECS provides enough information to establish the type
(that is, product class) of room air conditioner used in each
household, the age of the product, and an estimate of the household's
annual energy consumption attributable to the room air conditioner.
Using this data, DOE developed an estimate of the annual hours of use
of a room air conditioner in a household. This estimate was used to
calculate a weighted national average of room air conditioner usage
hours. The data in the 2005 RECS indicates that the estimated room air
conditioner average annual usage is 810 hours. DOE noted in the June
2010 TP SNOPR that this number of hours is higher than the current 750
hours specified in the test procedure. It is also significantly higher
than the approximately 500 hours suggested by the previous energy
conservation standard rulemaking analysis. Id.
An investigation of the 2005 cooling season covered by RECS
indicates that there were roughly 12-percent more cooling degree days
(CDD) in 2005 than the 30-year 1971 to 2000 average.\38\ The Annual
Energy Outlook projections of CDD for the future suggest that the
higher level of CDD will continue.\39\ Hence, the predictions of annual
hours based on the 2005 RECS can be considered representative of future
usage. Further, DOE stated in the June 2010 TP SNOPR, however, it does
not consider the increase of 60 hours from 750 hours to 810 hours to be
significant. This is because that increase does not exceed the
uncertainty level associated with the RECS-based approach for
estimation of this value. Hence, DOE did not propose a change in the
annual operating hours used in the test procedure in the June 2010 TP
SNOPR. 75 FR 37594, 37633 (June 29, 2010).
---------------------------------------------------------------------------
\38\ CDD is a sum of the difference between ambient temperature
in [deg]F and 65 [deg]F for every hour of the year that the ambient
temperature is higher than 65 [deg]F for a given location, divided
by 24 to convert from hours to days; DOE used data on CDD from the
National Solar Radiation Database (NSRDB). National Renewable Energy
Laboratory, National Solar Radiation Database 1991-2005 Update:
User's Manual, 2007. Golden, CO. Available online at: http://www.nrel.gov/docs/fy07osti/41364.pdf.
\39\ Energy Information Administration, 2006 State Energy
Consumption, Price, and Expenditure Estimates (SEDS),
2006. Washington, DC. Available online at: http://www.eia.doe.gov/emeu/states/_seds.html.
---------------------------------------------------------------------------
AHAM commented that it strongly opposes relying on the RECS data.
(AHAM, No. 31 at pp. 9-10) AHAM stated that it is becoming more
difficult to get survey data on room air conditioners as more people
rely on central air conditioning and because room air conditioners are
being used more for space cooling or assistance cooling rather than
primary cooling. AHAM also commented that consumers tend to buy room
air conditioners that are oversized for the cooling space, resulting in
fewer use-hours than if they had purchased a unit that was sized
appropriately. (AHAM, Public Meeting Transcript, No. 20 at pp. 151-152)
AHAM believes data are available, and that DOE should use such data for
its
[[Page 1016]]
analysis. (AHAM, Public Meeting Transcript, No. 20 at pp. 152-154) AHAM
also supported maintaining the current 750 annual operating hours used
in the test procedure for room air conditioners until or unless
additional reliable surveys or testing are completed that determine a
more representative number of use hours for room air conditioners
exists. (AHAM, No. 31 at pp. 9-10; AHAM, Public Meeting Transcript, No.
20 at p. 150) The California Utilities/NRDC also supported DOE's
allocation of 750 hours per year to active cooling, adding that this
allocation seems reasonable given available data. However, the
California Utilities/NRDC stated that DOE may need to revise this
allocation in light of its proposed treatment of fan-only energy.
(California Utilities/NRDC, No. 33 at p. 4)
DOE understands the uncertainties associated with RECS data, but
believes that the estimates using such data generally support
maintaining the current 750 annual operating hours. As discussed in
section III.B.4, DOE is not amending the test procedure in today's
final rule to account for fan-only active mode energy use, but may
consider amendments to address fan-only active mode in a future
rulemaking as data become available. For these reasons, DOE maintains
the current 750 annual operating hours used in the test procedure for
room air conditioners. DOE may consider revising this number of annual
operating hours if data are made available indicating that a change in
this value is warranted.
e. Room Air Conditioner Part-Load Performance
DOE noted in the October 2007 Framework Document that the current
DOE room air conditioner test procedure measures full-load performance
and does not assess energy savings associated with technologies that
improve part-load performance. DOE concluded in the June 2010 TP SNOPR
that widespread use of part-load technology in room air conditioners is
not likely to be stimulated by the development of a part-load metric at
this time, and therefore, the significant effort required to develop an
accurate part-load metric is not likely to be warranted by the expected
minimal energy savings. 75 FR 37594, 37633-34 (June 29, 2010). A part-
load metric would measure efficiency of a product when operating at
conditions other than maximum capacity, with outdoor or indoor
conditions cooler than currently used in the DOE active mode energy
test, or both. In field use of room air conditioners using currently
available technologies, when enough cooling is provided to the space,
any number of events can occur to prevent over-cooling. For example,
the user may turn off the unit or adjust fan speed; or the controls
might turn off the compressor, turn off both the compressor and the
fan, or reduce fan speed. Delivery of cooling might be done more
efficiently with part-load technologies, such as a compressor that can
adjust its capacity rather than cycling on and off, but sufficient
information is not available at this time regarding use of room air
conditioner features to assess whether those alternative technologies
would be cost effective. DOE notes that the key design changes that
improve full-load efficiency also improve part-load efficiency, so the
existing EER metric is already a strong indication of product
efficiency over a wide range of conditions. DOE concludes that
development of an additional test for part load, or a change of the
room air conditioner metric to a part-load metric is not supported by
the information available to DOE at this time. Therefore, DOE did not
consider amendments to its room air conditioner test procedure to
measure part-load performance in the June 2010 TP SNOPR. 75 FR 37594,
37634 (June 29, 2010). For these reasons and in the absence of comments
objecting to this determination, DOE is not amending its room air
conditioner test procedure to measure part-load performance at this
time. DOE may amend the test procedure to account for part-load
performance in a future rulemaking if information becomes available on
part-load technologies that are likely to result in significant energy
savings during actual use by consumers.
f. Room Air Conditioner Ambient Test Conditions
DOE also considered whether the ambient test conditions in its test
procedure for room air conditioners are representative of typical
installations. DOE noted in the June 2010 TP SNOPR that it received a
comment in response to the October 2007 Framework Document that
recommended increasing the ambient temperature of the DOE energy test
procedure from 95 [deg]F to 115 [deg]F. The commenters stated that room
air conditioners are generally operated when the outdoor temperatures
are the highest, and that they are often located on the south or west
side of residences where the sun can shine on them during operation. 75
FR 37594, 37634 (June 29, 2010). DOE stated that it did not receive
further information to support the specification of the higher
temperature, and, therefore, did not consider an amendment to the
ambient test conditions specified in the room air conditioner test
procedure in the June 2010 TP SNOPR. Id.
AHAM supported maintaining the current specifications regarding
ambient test conditions for room air conditioners. (AHAM, No. 31 at p.
10; AHAM, Public Meeting Transcript, No. 20 at p. 155) In the absence
of data to support a change to the ambient test conditions, DOE is not
amending the ambient test conditions specified in the room air
conditioner test procedure.
6. Room Air Conditioner Referenced Test Procedures
The room air conditioner test procedure cites two test standards:
(1) ANS Z234.1-1972 and (2) ASHRAE Standard 16-69. Both the ANS (since
renamed ANSI) and ASHRAE standards have been updated since DOE last
revised its room air conditioner test procedure. The current standards
are ANSI/AHAM RAC-1-R2008 and ANSI/ASHRAE Standard 16-1983 (RA 2009),
respectively. Because it is likely that any manufacturer rating it
products is using the most recent test standards, DOE suggested in the
October 2007 Framework Document that it consider updating its test
procedure to incorporate by reference the most recent test standards.
In the June 2010 TP SNOPR, DOE reviewed the differences between the
test standards currently referenced by the DOE test procedure and the
latest versions of these standards to determine if amendments to
reference the latest ANSI and ASHRAE test standards are appropriate.
DOE noted the sections that would be referenced in ANSI/AHAM RAC-1-
R2008 by the DOE test procedure do not introduce any new changes in the
measurement of cooling capacity or power input. DOE also noted the
sections that would be referenced in ANSI/ASHRAE Standard 16-1983 (RA
2009) by the DOE test procedure would introduce changes to the
determination of capacity, four new temperature measurements, and
changes to the test tolerances. In particular, DOE noted in the June
2010 TP SNOPR that section 6.1.3 of ANSI/ASHRAE Standard 16-1983 (RA
2009) introduces a correction factor based on the test room condition's
deviation from the standard barometric pressure of 29.92 inches (in.)
of mercury (Hg) (101 kilopascal (kPa)). Section 6.1.3 of ANSI/ASHRAE
Standard 16-1983 (RA 2009) states that the cooling capacity may be
increased 0.8 percent for each in. Hg below 29.92 in. Hg (0.24 percent
for each kPa below 101 kPa). DOE noted the capacity correction factor
provides manufacturers with more
[[Page 1017]]
flexibility in the test room conditions while normalizing results to
standard conditions. On November 26, 2010, 75 FR 72739, DOE published
notice of a petition submitted by AHAM concerning use of the proposed
correction factor for room air conditioner testing. While DOE seeks
comment on the petition until December 27, 2010, DOE believes that the
correction factor resolves the issues presented in the AHAM petition.
DOE also noted the referenced section numbers from the old and current
test standards are identical. 75 FR 37594, 37634-35 (June 29, 2010).
DOE determined that incorporation by reference of these updated
versions provides more accurate and repeatable measurements of capacity
while providing greater flexibility to manufacturers in selecting
equipment and facilities, and does not add any significant testing
burden because the time required for testing would not change.
Furthermore, these revisions would not impact the measurement of EER
for this equipment because the methodology used for this measurement is
the same. DOE also stated that it believes that manufacturers may
already be using these updated standards in their testing. Therefore,
DOE proposed amending the DOE test procedure to reference the relevant
sections of ANSI/AHAM RAC-1-R2008 and ANSI/ASHRAE Standard 16-1983 (RA
2009). 75 FR 37634-35.
AHAM agreed that DOE should reference the latest standards for room
air conditioners. (AHAM, No. 31 at p. 10) For the reasons stated above
and in the absence of comments objecting to amending the DOE test
procedure to reference the relevant sections of ANSI/AHAM RAC-1-R2008
and ANSI/ASHRAE Standard 16-1983 (RA 2009), DOE adopts these
amendments.
7. Clothes Dryer Referenced Test Procedure
The DOE clothes dryer test procedure currently references the
industry test standard AHAM Standard HLD-1-1974. Specifically, the DOE
clothes dryer test procedure requires that the clothes dryer under test
add the AHAM exhaust simulator described in section 3.3.5 of AHAM
Standard HLD-1-1974. The AHAM test standard has been updated since DOE
established its clothes dryer test procedure. The current standard is
designated as AHAM Standard HLD-1-2009. Because it is likely that any
manufacturer rating it products is using the most recent test standard,
DOE considered potential amendments to its clothes dryer test procedure
to reference AHAM Standard HLD-1-2009 in the June 2010 TP SNOPR. DOE
noted that section 3.3.5.1 of AHAM Standard HLD-1-2009 regarding
exhausting conditions provides the same requirements for the exhaust
simulator as required by AHAM Standard HLD-1-1974. For this reason, DOE
proposed to amend the DOE test procedure to reference AHAM Standard
HLD-1-2009. DOE stated that because the requirements for the exhaust
simulator would be the same, the proposed amendments would not affect
the EF rating of residential clothes dryers and would not require that
the existing energy conservation standards for these products be
revised. 75 FR 37594, 37636 (June 29, 2010).
AHAM, Whirlpool, and ALS commented in support of updating the test
procedure to reference AHAM standard HLD-1-2009. (AHAM, No. 31 at p.
10, AHAM, Public Meeting Transcript, No. 20 at p. 158, Whirlpool, No.
27 at p. 5, ALS, No. 24 at p. 8) For these reasons and in the absence
of comments objecting to amending the DOE test procedure to reference
AHAM Standard HLD-1-2009, DOE adopts these amendments in today's final
rule.
DOE also acknowledges that AHAM Standard HLD-1-2009 allows for the
optional use of a modified exhaust simulator, which is included as a
more convenient option than the exhaust simulator originally specified
for testing vented clothes dryers. The requirements for the modified
exhaust simulator are presented in section 3.3.5.2 of AHAM Standard
HLD-1-2009. The test standard notes that only limited testing has been
done to compare results using the two exhaust simulators, and that
users are invited to submit results and comments for both options.
Because this modified exhaust simulator is recent, and limited data
exist to compare the effects of using different exhaust simulators, DOE
stated in the June 2010 TP SNOPR that it will continue to require the
standard exhaust simulator currently referenced by the DOE clothes
dryer test procedure. 75 FR 37594, 37636 (June 29, 2010). However, DOE
requested data from manufacturers comparing the effects of the two
exhaust simulators on the drying efficiency using the DOE test
procedure. DOE also invited comment on whether the test procedure
should be amended to allow for the optional modified exhaust simulator.
AHAM commented that there may be more data available concerning the
modified exhaust simulator, which gained ANSI approval in 2009. (AHAM,
Public Meeting Transcript, No. 20 at pp. 159-160) AHAM stated that DOE
should allow for the optional use of a modified exhaust simulator. AHAM
added that the AHAM Standard HLD-1-2009 was developed after an
extensive standards-making process, which fully vetted issues related
to optional use of a modified exhaust simulator, and as such there is
no reason for DOE to deviate from that standard. (AHAM, No. 31 at p.
10).
DOE is not aware of any data comparing the effects of the two
exhaust simulators on the drying efficiency using the DOE test
procedure. DOE notes that it requested such data in the June 2010 TP
SNOPR, but did not receive any data. In the absence of such data, DOE
will continue to require the standard exhaust simulator currently
referenced by the DOE clothes dryer test procedure. If data are made
available showing that the test results using the modified exhaust
simulator produce repeatable results, as well as comparing the effects
of the different exhaust simulators on the measured EF, DOE may
consider such revisions to its clothes dryer test procedure in a future
rulemaking.
Section 1.8 in the ``Definitions'' section of the DOE clothes dryer
test procedure also references an obsolete AHAM clothes dryer test
standard, AHAM Standard HLD-2EC. No provisions of this test standard
are currently used in DOE's test procedure, and DOE therefore proposed
to remove this reference in the June 2010 TP SNOPR. 75 FR 37594, 37636
(June 29, 2010). AHAM and Whirlpool both commented in support of
removing the reference to AHAM Standard HLD-2EC. (AHAM, No. 31 at p.
10, Whirlpool, No. 27 at p. 5) For this reason and in the absence of
comments objecting to this proposal, DOE amends the test procedure to
remove this reference.
8. Technical Correction for the Per-Cycle Gas Dryer Continuously
Burning Pilot Light Gas Energy Consumption
The equation provided under section 4.4 Per-cycle gas dryer
continuously burning pilot light gas energy consumption of the current
DOE clothes dryer test procedure contains a technical error in the
equation for calculation of the per-cycle gas dryer continuously
burning pilot light gas energy consumption (Eup), in Btus
per cycle. Eup is the product of the following three
factors: (A) The cubic feet of gas consumed by the gas pilot in hour;
(B) the total number of hours per year the pilot is consuming gas while
the clothes dryer is not operating in active mode (8,760 total hours
per year minus 140 hours per year the clothes dryer operates in active
mode) divided by the representative average number of
[[Page 1018]]
clothes dryer cycles in a year (416); and (C) the corrected gas heat
value. Part (B) of this equation is currently incorrect, reading (8760
- 140/416) and missing the appropriate parentheses. The equation should
correctly subtract the total number of hours per year the pilot is
consuming gas while the clothes dryer is not operating in active mode
from the number of hours per year the clothes dryer operates in active
mode, before dividing by the average number of clothes dryer cycles in
a year. The equation should read ((8760 - 140)/416) to correctly
calculate the per-cycle gas dryer continuously burning pilot light gas
energy consumption. Therefore, DOE proposed in the June 2010 TP SNOPR
to amend the equation to correctly calculate the per-cycle gas dryer
continuously burning pilot light gas energy consumption. 75 FR 37594,
37636 (June 29, 2010).
AHAM and Whirlpool supported the technical correction to the per-
cycle gas dryer continuously burning pilot light gas energy consumption
calculation. (AHAM, No. 31 at p. 10; Whirlpool, No. 27 at p. 5) ALS
commented that it supported DOE's proposed technical correction.
However, ALS believes this an unnecessary addition to the test
procedure. ALS believes the proper way to address the issue is to
revise the minimum energy conservation standard during its current
standards rulemaking to add back into the minimum standard the design
prescription banning constant burning pilot lights. ALS noted that the
original 1987 standard included the design prescription, but it was
removed in the first review of the standard effective May 14, 1994
because it was perceived that the revised minimum standard of 1994
would continue to effectively eliminate continuously burning pilot
lights. ALS noted that no clothes dryer with continuously burning gas
pilot lights exists on the market at this time. Therefore, it is a
wasted effort to add text to the test procedure for something that does
not exist and can be more effectively dealt with by a simple revision
to the clothes dryer minimum standard. (ALS, No. 24 at p. 8) AHAM also
commented that it is not aware of any clothes dryer on the market that
uses a constant burning pilot light, and doubts any such dryers will be
introduced soon. (AHAM, Public Meeting Transcript, No. 20 at p. 162)
As discussed in section I, EPCA establishes prescriptive standards
for clothes dryers, requiring that gas dryers manufactured on or after
January 1, 1988 not be equipped with a constant burning pilot (42
U.S.C. 6295(g)(3)). Because constant burning pilot lights are precluded
by EPCA, DOE agrees with ALS that any provisions for measuring constant
burning pilot light energy use in gas clothes dryers are no longer
necessary. As a result, DOE amends the clothes dryer test procedure to
remove all provisions for measuring the constant burning pilot light
energy use.
9. Clarification of Gas Supply Test Conditions for Gas Clothes Dryers
Section 2.3.2.1 and 2.3.2.2 of the DOE clothes dryer test procedure
specifies maintaining ``the gas supply to the clothes dryer at a normal
inlet test pressure immediately ahead of all controls at'' 7 to 10
inches of water column for natural gas or 11 to 13 inches of water
column for propane gas. DOE believes that the references to ``normal
inlet test pressure'' in sections 2.3.2.1 and 2.3.2.2 of its clothes
dryer test procedure may be confusing because the term ``normal'' is
not defined. DOE believes that such language is not necessary because
the gas supply pressure immediately ahead of all controls is explicitly
stated. Therefore, DOE proposed in the June 2010 TP SNOPR to revise the
test pressure conditions in sections 2.3.2.1 and 2.3.2.2 of the DOE
clothes dryer test procedure to specify maintaining ``the gas supply to
the clothes dryer immediately ahead of all controls at a pressure of''
7 to 10 inches of water column for natural gas and 11 to 13 inches of
water column for propane gas. 75 FR 37594, 37636 (June 29, 2010). AHAM,
Whirlpool, and ALS supported DOE's proposed clarification. (AHAM, No.
31 at pp. 10-11; Whirlpool, No. 27 at p. 5; ALS, No. 24 at p. 8) For
these reasons and in the absence of comments objecting to this
proposal, DOE amends its clothes dryer test procedure to revise the
test pressure conditions as discussed above.
DOE also believes the specifications for a gas pressure regulator
in sections 2.3.2.1 and 2.3.2.2 of its clothes dryer test procedure
should clarify that the outlet pressure for a clothes dryer equipped
with a pressure regulator for which the manufacturer specifies an
outlet pressure should be approximately that recommended by the
manufacturer. DOE proposed in the June 2010 TP SNOPR to make these
minor revisions these sections. 75 FR 37594, 37636 (June 29, 2010). In
the absence of comments objecting to this proposal, DOE is amending its
clothes dryer test procedure to revise the test pressure conditions for
clothes dryers equipped with a gas pressure regulator as discussed
above.
10. Other Clothes Dryer Active Mode Issues
DOE received a number of comments on issues related to the active
mode for clothes dryers not identified in the June 2010 TP SNOPR. The
following sections discuss each of these issues.
a. Test Cloth Specifications
ALS commented in response to the June 2010 TP SNOPR that DOE should
consider if the number of test runs allowed on test cloth after pre-
conditioning should be equal to the number of allowable runs for
clothes washer test cloth. ALS commented that, currently, the clothes
dryer test cloth can be used for only 25 test runs, while the clothes
washer test cloth is allowed to be used for 60 test runs. (ALS, No. 24
at p. 6) Whirlpool commented that both the clothes washer and clothes
dryer test procedures should be modified to allow for 50 cycles of test
cloth use, because this would be easier to manage and reduce the cost
of cloth used in clothes dryers. Whirlpool commented that beyond 50
wash cycles, the load-to-load variability increases significantly,
adversely impacting repeatability. (Whirlpool, No. 27 at p. 6) DOE is
not aware of any data showing the repeatability of clothes dryer test
results for test cloth after 25 runs. DOE is also not aware of any data
indicating that the wear on test cloth from a drying cycle is
equivalent to that of a washing cycle. Thus, there is no evidence that
warrants changing the test procedures to specify the same number of
allowable test runs on clothes washer and clothes dryer test cloths.
For these reasons, DOE is not amending the clothes dryer test procedure
in today's final rule to change the number of test runs allowed on
clothes dryer test cloth.
Whirlpool commented that the lot-to-lot test cloth correction
factors used in the clothes washer test procedure are not used in the
clothes dryer test procedure. Whirlpool stated that it is increasingly
the case that clothes dryer test results are not repeatable across test
cloth lots. Whirlpool stated its research suggests that adding the
washer correction factors to the clothes dryer test procedure would
substantially address this problem. (Whirlpool, No. 27 at p. 6) DOE is
not aware of any data indicating variations in test results across
different test cloth lots is significant enough to warrant amending the
clothes dryer test procedure to include correction factors. In
addition, DOE notes that the clothes washer RMC correction factor is
based on extractor testing (spinning water out of the clothes load).
Extractor testing can have
[[Page 1019]]
very different moisture removal characteristics than the applied heated
air and slower tumbling to evaporate moisture during a clothes dryer
cycle. DOE is not aware of any data indicating that the same correction
factor from the clothes washer test procedure can be applied to the
clothes dryer test procedure. For these reasons, DOE is not amending
the clothes dryer test procedure to include a lot-to-lot test cloth
correction factor in today's final rule. If data is made available
documenting such lot-to-lot variation as well as validating that the
RMC correction factor in the clothes washer test procedure can be
applied to the clothes dryer test procedure, DOE may consider such
amendments.
b. Relative Humidity Measurement Specifications
ALS commented that section 2.4.4 Dry & Wet Bulb Psychrometer of the
DOE clothes dryer test procedure should be updated. ALS stated that DOE
may want to remove any reference to a dry and wet bulb psychrometer,
because electronic digital sensors exist that directly report the
relative humidity and test labs should be allowed to utilize them. ALS
commented that DOE needs to research humidity measurement electronic
digital sensors and propose new limits for their accuracy and
reporting. (ALS, No. 24 at p. 9)
DOE notes section 2.2.4 specifies that the dry and wet bulb
psychrometer shall have an error no greater than 1 [deg]F.
DOE acknowledges that the dry and wet bulb psychrometer specifications
for determining the relative humidity were developed in 1981 when the
clothes dryer test procedure was last amended. Since that time, more
advanced digital equipment has been developed for measuring relative
humidity. DOE also acknowledges that the DOE test procedure for central
air conditioners and heat pumps specifies the allowable error in the
measurement of wet bulb temperature for determining the psychrometric
state of air (the wet bulb temperature sensor must be accurate within
0.2 [deg]F). That test procedure also specifies the
allowable error for an alternative option of directly measuring the
relative humidity (such a meter must be accurate to within
0.7 nominal percent relative humidity). 10 CFR part 430, subpart B,
appendix M, Sec. 2.5.6 DOE is not aware of data or information on how
the allowable dry and wet bulb psychrometer measurement error of no
greater than 1 [deg]F would translate to measurement error
specifications for relative humidity measurement equipment that could
be used to determine an appropriate allowable error for the DOE clothes
dryer test procedure. For these reasons, DOE is not adopting amendments
to the dry bulb and wet bulb psychrometer specifications for
determining the relative humidity. If data are made available
indicating an appropriate range for the allowable error for relative
humidity measurement equipment, however, DOE may consider amendments to
the clothes dryer test procedure.
c. Calculations of EF and CEF
ALS commented that DOE needs to add the calculation for the EF, the
newly proposed IEF,\40\ or both to the clothes dryer test procedure.
According to ALS, the clothes washer test procedure displays the
calculation for the minimum energy efficiency descriptor (the modified
energy factor). ALS stated the clothes dryer test procedure should
likewise show how to calculate the value of clothes dryer minimum
energy efficiency descriptor EF and/or IEF. (ALS, No. 24 at p. 9) AHAM
also requested that DOE expressly state the equation for EF in the test
procedure to provide optimal clarity for the regulated industry. (AHAM,
No. 31 at p. 11)
---------------------------------------------------------------------------
\40\ DOE proposed to use the term Integrated Energy Factor (IEF)
in the December 2008 TP NOPR. 73 FR 74639, 74650 (December 9, 2008).
However, in the June 2010 TP SNOPR, DOE proposed to revise the name
of the metric to Combined Energy Factor (CEF). 75 FR 37594, 37612
(June 29, 2010).
---------------------------------------------------------------------------
DOE notes that the calculation for EF (and the proposed CEF) for
clothes dryers can be found at 10 CFR 430.23(d). However, DOE
acknowledges that other test procedures in the appendices of 10 CFR
part 430, subpart B also include the calculations of the energy
efficiency metric. For example, the clothes washer test procedure (10
CFR part 430, subpart B, appendix J1) includes the calculation, as
noted by ALS. Including such calculations would help test technicians
find the proper calculation for EF and CEF. For these reasons, DOE
believes that the calculation for EF and CEF should be included in 10
CFR part 430, subpart B, appendix D1. Therefore, DOE amends the clothes
dryer test procedure in today's final rule to include those
calculations. DOE also amends 10 CFR part 430.23(d)(2) and (3) in
today's final rule to clarify that the EF and CEF are to be determined
in accordance with the appropriate sections in 10 CFR part 430, subpart
B, appendix D1.
d. Measurement of Kilowatt Electricity Demand
SEDI recommended that kW electricity demand, in addition to kWh
energy consumption, also be measured during the test procedure. SEDI
added that different clothes dryer technologies can have very different
electricity demand profiles. Typical electric clothes dryers available
in North America today have powerful heating elements and may
significantly contribute to system peak demand. SEDI commented that a
more efficient clothes dryer with a lower contribution to peak demand
may be even more cost-effective from perspective of electric utilities.
(SEDI, No. 34 at p. 3) As discussed previously, EPCA provides that any
test procedures prescribed or amended under this section shall be
reasonably designed to produce test results which measure energy
efficiency, energy use, water use, or estimated annual operating cost
of a covered product during a representative average use cycle or
period of use. (42 U.S.C. 6293(b)(3)) DOE believes that measuring the
electricity demand profile of a clothes dryer to account for designs
options that may reduce utility peak load demand would be inconsistent
with the EPCA requirement for a test procedure to measure the energy
use of a product. For this reason, DOE is not amending the clothes
dryer test procedure to measure the electricity demand profile of a
clothes dryer to account for the peak load demand of a clothes dryer.
e. Clarifications to the Measurement of Drum Capacity
The Joint Petitioners and AHAM commented that DOE should clarify
section 3.1 of the clothes dryer test procedure regarding the
measurement of drum capacity. The clarification would specify that the
clothes dryer's rear drum surface be supported on a platform scale to
``prevent deflection of the drum surface * * *'' instead of ``prevent
deflection of the dryer.'' (Joint Petitioners, No. 25 at p. 14; Joint
Petitioners, No. 30 at p. 8; AHAM, No. 31 at p. 11) DOE agrees with the
comments that the reference to deflection of the ``dryer'' is unclear
and should be clarified to specify that the clothes dryer's rear drum
surface should be supported on a platform scale to prevent deflection
of the drum surface. For this reason, DOE amends the clothes dryer test
procedure to reflect this change.
f. Test Procedure Language
AHAM commented that manufacturers are having a difficult
[[Page 1020]]
time using the proposed test procedure because it is not written in a
way that can be easily followed when running a test. AHAM commented
that the extraneous portions derived from the IEC and Australia/New
Zealand procedures create a confusing amalgam of testing situations
that makes the procedure extremely difficult to conduct. AHAM stated
that the test procedure itself needs to be evaluated, and they would
like to see a more sequenced and applicable test procedure. (AHAM,
Public Meeting Transcript, No. 20 at pp. 88-89, 126-127) AHAM commented
that the AHAM HLD-1 committee will likely consider whether the test
procedure amendments should be added as modifications to AHAM HLD-1,
which is written in the test procedure format. AHAM stated that it
would be helpful for DOE to identify explicitly how the proposed
changes to the DOE test procedure could be reflected in AHAM HLD-1.
AHAM added that manufacturers could test on a version of AHAM HLD-1
that incorporated the changes DOE identified and report what changes to
test results have taken place. AHAM commented that it would also assist
the AHAM HLD-1 committee in processing the changes because it is
unlikely that the AHAM HLD-1 committee will want to run tests that are
different from the DOE test procedure. (AHAM, Public Meeting
Transcript, No. 20 at pp. 127-129)
DOE notes that its proposed clothes dryer test procedure is similar
in structure to many other DOE test procedures, and DOE is not aware of
the particular sections of the test procedure language that may be
confusing or difficult to interpret. DOE also notes that it is not
adopting the amendments to more accurately account for automatic cycle
termination based on the provisions in AS/NZS Standard 2442, as
discussed in section III.C.2. For these reasons, DOE does not believe
that the test procedure needs to be restructured or re-written and is
not including any additional revisions to the test procedure language.
D. Compliance With Other EPCA Requirements
1. Test Burden
Standby Mode and Off Mode
Section 323(b)(3) of EPCA requires that any test procedures
prescribed or amended under this section shall be reasonably designed
to produce test results which measure energy efficiency, energy use or
estimated annual operating cost of a covered product during a
representative average use cycle or period of use and shall not be
unduly burdensome to conduct. (42 U.S.C. 6293(b)(3))
For the proposed amendments to measure standby and off mode energy
use, DOE tentatively concluded in the December 2008 TP NOPR that
amending the relevant test procedures to incorporate clauses regarding
test conditions and methods found in IEC Standard 62301 for measuring
standby mode and off mode power consumption, along with the proposed
clarifications and text corrections, would satisfy this requirement
because the test methods and equipment that the amendments would
require are not substantially different from the test methods and
equipment in the current DOE test procedures for measuring the products
energy consumption. Therefore, DOE stated the proposed test procedures
would not require manufacturers to make major investments in test
facilities and new equipment. 73 FR 74639, 74650 (December 9, 2008).
In the June 2010 TP SNOPR, DOE did not propose amendments to
measure delay start and cycle finished modes in the clothes dryer test
procedure. DOE instead proposed a simplified methodology in which the
energy use associated with delay start and cycle finished modes,
although determined to not be energy use in a standby mode, would be
approximately represented by the measured energy in inactive and off
modes. Therefore, because the proposal in the June 2010 TP SNOPR was
less burdensome than the December 2008 TP NOPR proposal, DOE
tentatively concluded that the proposed amendments to the clothes dryer
test procedures for measuring standby and off modes adopted in June
2010 TP SNOPR are not unduly burdensome. 75 FR 37594, 37637 (June 29,
2010).
DOE proposed in the June 2010 TP SNOPR to provide manufacturers
flexibility in setting the ambient conditions for standby mode and off
mode testing for the room air conditioner test procedure. The proposed
amendments to the room air conditioner test procedure specify
maintaining the indoor test conditions at the temperature required by
section 4.2 of IEC Standard 62301. Further, if the unit is tested in
the cooling performance test chamber, the proposed amendments allow the
manufacturer to maintain the outdoor test conditions either as
specified for the DOE cooling test procedure or according to section
4.2 of IEC Standard 62301. Implementing those two specifications would
mean that manufacturers would not have to build another facility to run
the standby and off mode tests. In addition, DOE did not propose
amendments that would specify measurement of energy use in delay start
or off-cycle modes to the room air conditioner test procedure. DOE
instead proposed a simplified methodology in which the energy use
associated with delay start and off-cycle modes, although determined to
not be energy use in a standby mode, would be approximately represented
by the measured energy in inactive and off modes. For these reasons,
DOE tentatively concluded that the test conditions proposed in the June
2010 TP SNOPR are not unduly burdensome and would result in
representative standby mode and off mode energy consumption
measurements. 75 FR 37594, 37637 (June 29, 2010).
As discussed in section III.B.2, AHAM, Whirlpool, and ALS commented
that the requirement proposed in the June 2010 TP SNOPR to conduct
standby and off mode testing for clothes dryers and room air
conditioners in the settings that produce the highest power consumption
level would result in extra test burden. This is because manufacturers
will need to run several tests on every model in order to determine
which cycle is the highest energy cycle (AHAM, No. 31 at pp. 4-5;
Whirlpool, No. 27 at p. 1; ALS, No. 24 at pp. 1-2) DOE is not adopting
the provisions for conducing standby and off mode testing in the
settings that produce the highest power consumption level in today's
final rule. DOE is instead incorporating by reference section 5.2 of
IEC Standard 62301, which requires that the appliance be installed and
set up in accordance with manufacturers instructions; if no
instructions are given, then the appliance shall be tested at factory
or ``default'' settings; and where there are no indications for such
settings, the appliance shall be tested as supplied. DOE believes that
such provisions would not require manufacturers to run several tests on
every model to determine the appropriate mode, and therefore would not
represent a testing burden.
For the reasons stated above and in the absence of additional
comments, DOE concludes that the standby and off mode testing
conditions for clothes dryers and room air conditioners adopted in
today's final rule are not unduly burdensome, yet still produce
representative standby mode and off mode energy consumption
measurements.
Active Mode
In the June 2010 TP SNOPR, DOE noted that the proposed amendments
to
[[Page 1021]]
its test procedure for clothes dryers to test automatic termination
control dryers are based upon an international testing standard used to
determine compliance with energy conservation standards for clothes
dryers in Australia. A number of manufacturers that sell clothes dryers
in the United States also sell clothes dryers in Australia, and
therefore likely already test clothes dryers according to this test
standard. DOE stated the proposed amendments would not require testing
methods and equipment that are substantially different from the test
methods and equipment in the current DOE test procedures. Therefore,
manufacturers would not be required to make a major investment in test
facilities and new equipment. 75 FR 37594, 37637 (June 29, 2010). As
discussed in section III.C.2, DOE is not adopting in today's final rule
the amendments for automatic cycle termination proposed in the June
2010 TP SNOPR.
In the June 2010 TP SNOPR, DOE also noted that the proposed
amendments to its test procedure for residential clothes dryers to test
ventless clothes dryers are based on an international test standard
used throughout the EU to determine compliance with energy conservation
standards. A number of manufacturers that sell clothes dryers in the
United States also sell clothes dryers in the EU, and therefore likely
already test clothes dryers according to this test standard. DOE stated
the proposed amendments would not require testing methods and equipment
that are substantially different from the test methods and equipment in
the current DOE clothes dryer test procedure. 75 FR 37594, 37637 (June
29, 2010).
DOE noted that its proposed amendments to the clothes dryer test
procedure to reflect current usage patterns and capabilities in the
June 2010 TP SNOPR do not substantially change the testing procedures
and methods. DOE noted that its proposed amendments to change the
number of annual use cycles affects only the calculation of the
estimated annual operating cost. The number of annual use cycles does
not impact the testing procedures because the value is only used in the
calculation of results. DOE also noted that the proposed amendments to
change the initial RMC from 70 percent to 47 percent are intended to
reflect current clothes loads after a wash cycle. DOE believes that
such a change would likely require only a moderately longer spin time
during test load preparation to achieve the proper lower moisture
content. Finally, DOE noted that the proposed amendment to change the
test load size for standard-size clothes dryers from 7.00 lb .07 lb to 8.45 lb .085 lb would not significantly
impact the testing procedures because it only affects the amount of
test cloth required to be used for the test cycle. The amendment also
would not require manufacturers to make any significant new investment
in test facilities and equipment. DOE stated in the June 2010 TP SNOPR
that these proposed amendments to the DOE clothes dryer test procedure
would produce test results that measure energy use of clothes dryers
during a representative average use cycle. 75 FR 37594, 37637 (June 29,
2010).
DOE noted in the June 2010 TP SNOPR that the proposed amendments to
update the references to external standards in the DOE room air
conditioner test procedure are based on the availability of revised
standards representing current industry practices and methods. The
proposed amendments to reference ANSI/AHAM RAC-1-R2008 do not introduce
any new changes in the measurement of cooling capacity or power input.
The proposed amendments to reference ANSI/ASHRAE Standard 16-69 would
introduce four new temperature measurements, provide increased test
tolerances, and allow additional flexibility in the methodology for
measuring capacity. DOE notes the four new temperature measurements
would be measured simultaneously with the other measurements already
required by the test procedure, and therefore would not require
additional time to conduct the test. DOE stated in the June 2010 TP
SNOPR that these proposed amendments would not require manufacturers to
make any significant new investment in test facilities and equipment,
nor require significant changes in the testing methodology. 75 FR
37594, 37637 (June 29, 2010).
For the reasons noted above, DOE tentatively concluded that the
amendments to the active mode test procedures would produce
representative test results for both residential clothes dryers and
room air conditioners, and that testing under the test procedures would
not be unduly burdensome to conduct. 75 FR 37594, 37638 (June 29,
2010).
ALS commented that there could be a test burden associated with the
revised initial RMC requirements. ALS stated that it might not be able
to achieve the 47 percent RMC proposed in the June 2010 TP SNOPR in one
of their residential clothes washers due to the disconnect between the
actual RMC and the corrected RMC values. (ALS, Public Meeting
Transcript, No. 20 at pp. 166-167) AHAM commented that extracting
moisture to the 47 percent RMC level would cause test cloth to
deteriorate more quickly. Also, extracting moisture to the 47 percent
RMC level would cause other problems. For example, to achieve the level
it would be necessary to use an extractor, which would require spending
significant sums of money. (AHAM, Public Meeting Transcript, No. 20 at
pp. 167-168)
DOE notes that the tests conducted for the June 2010 TP SNOPR at an
independent test lab prepared the clothes dryer test cloth with an RMC
of 47 percent using a commercially available clothes washer. For the
reasons discussed in section III.C.5.b, however, DOE adopts an initial
RMC of 57.5 percent 3.5 percent for the clothes dryer test
procedure in today's final rule. As a result, DOE believes that there
would be no significant test burden associated with reaching this
higher initial RMC value.
For the reasons stated above and in the absence of additional
comments, DOE concludes that the amendments to the active mode test
procedures in today's final rule would produce representative test
results for both residential clothes dryers and room air conditioners,
and that testing under the test procedures would not be unduly
burdensome to conduct.
2. Integration of Standby Mode and Off Mode Energy Consumption Into the
Efficiency Metrics
Section 325(gg)(2)(A) requires that standby mode and off mode
energy consumption be ``integrated into the overall energy efficiency,
energy consumption, or other energy descriptor for each covered
product'' unless the current test procedures already fully account for
the standby mode and off mode energy consumption or if such an
integrated test procedure is technically infeasible. (42 U.S.C.
6295(gg)(2)(A)) For clothes dryers, today's final rule does not affect
DOE's proposal in the December 2008 TP NOPR to incorporate the standby
and off mode energy consumption into a ``per-cycle combined total
energy consumption expressed in kilowatt-hours'' and into an CEF, as
discussed in section III.B.5 of this notice. For room air conditioners,
today's final rule does not affect DOE's proposal in the December 2008
TP NOPR to incorporate the standby and off mode energy consumption into
a metric for ``combined annual energy consumption'' and into an CEER,
as discussed in section III.B.5. In addition, DOE is amending the
clothes dryer and room air conditioner test procedures in
[[Page 1022]]
today's final rule to incorporate standby and off mode energy
consumption into the annual energy cost calculations, as discussed in
section III.B.5.
IV. Effects of Test Procedure Revisions on Compliance With Standards
As noted in section I, DOE must determine to what extent, if any,
the proposed test procedures would alter the measured energy efficiency
of covered products as determined under the existing test procedures.
If DOE determines that an amended test procedure would alter the
measured efficiency of a covered product, DOE must amend the applicable
energy conservation standard during the rulemaking carried out with
respect to such test procedure. (42 U.S.C. 6293(e))
A. Standby Mode and Off Mode
As noted in section II, EPCA provides that amendments to the test
procedures to include standby mode and off mode energy consumption will
not determine compliance with previously established standards. (U.S.C.
6295(gg)(2)(C)) Because the proposed amended test procedures for
standby mode and off mode energy consumption would not alter existing
measures of energy consumption or efficiency for active mode, these
amendments would not affect a manufacturer's ability to demonstrate
compliance with previously established standards.
B. Active Mode--Clothes Dryers
DOE reviewed the amendments to the DOE clothes dryer active mode
test procedure to evaluate the effects on the measured EF. The
following sections discuss DOE's evaluation of each active mode
amendment individually, as well as DOE's evaluation of the fully
amended test procedure.
Automatic Cycle Termination
In the June 2010 TP SNOPR, DOE analyzed how the proposed changes to
the DOE clothes dryer test procedure for automatic cycle termination
controls discussed above in section III.C.2 would affect the measured
EF of residential clothes dryers, as required by EPCA. 75 FR 37594,
37618 (June 29, 2010). As part of DOE's preliminary analyses for the
energy conservation standards rulemaking for clothes dryers, DOE
concluded that virtually all clothes dryers currently available on the
U.S. market that are covered under the current energy conservation
standards are equipped with some form of automatic cycle termination
sensing. Therefore, DOE analyzed in the June 2010 TP SNOPR how the
proposed changes to the clothes dryer test procedure for automatic
termination control dryers would affect the measured EF of residential
clothes dryers with such a feature. 75 FR 37594, 37618 (June 29, 2010).
DOE noted in the June 2010 TP SNOPR that the proposed amendment to
change the field use factor from 1.04 to 1.0 for automatic termination
control dryers would result in a 4-percent increase in EF for a dryer
that has an automatic cycle termination setting capable of drying the
test load to 5-percent RMC. In addition, DOE noted the proposed target
final RMC of 5 percent or lower would result in an increase in EF of
about 2.4 percent (assuming a starting RMC of 47 percent). This is as
compared to the current DOE test procedure, which uses a correction
factor in order to determine the energy consumption required to dry the
test load to a final RMC of 4 percent. DOE also stated in the June 2010
TP SNOPR that a clothes dryer that is only minimally compliant with
current energy conservation standards would likely use a less accurate
automatic termination control system. DOE stated that such a dryer
would possibly over-dry the test load below 5-percent RMC such that the
energy consumption and measured EF would be equivalent to that measured
by the existing DOE clothes dryer test procedure. As a result, DOE
stated that it does not believe that any changes to the current energy
conservation standards as a result of the proposed amendments to the
test procedure to account for automatic cycle termination would be
warranted. 75 FR 37619-20. Because DOE did not have data regarding how
the proposed changes to the clothes dryer test procedure for automatic
termination control dryers would affect the measured EF of residential
clothes dryers with such a feature, however, DOE requested comment on
this tentative conclusion in the June 2010 TP SNOPR. Id.
The Joint Petitioners and AHAM commented that if the full cycle
test (including cool-down) is adopted, DOE must also revise the
relevant energy conservation standards to reflect the new test
procedure, ensuring no change in the stringency of the standards for
clothes dryers with effective automatic termination controls, as per
section 323 of EPCA. The Joint Petitioners and AHAM stated that,
specifically, the procedures in section 323(e)(2) should be used, with
the clarification that for the purposes of establishing a
representative sample of products, DOE should choose a sample of
minimally compliant clothes dryers that automatically terminate the
drying cycle at no less than 4-percent RMC. The Joint Petitioners and
AHAM also stated that there will be additional energy savings by
improving the effectiveness of automatic termination controls. (Joint
Petitioners, No. 30 at p. 6; AHAM, No. 31 at pp. 30-31)
The California Utilities/NRDC commented that they are very
concerned with DOE's proposal to not revise the current energy
conservation standard levels as a result of its analysis of the test
procedure amendments to account for automatic cycle termination. They
are also concerned about DOE's interpretation of the definition of a
``minimally compliant'' clothes dryer in the June 2010 TP SNOPR. The
California Utilities/NRDC noted that clothes dryers with less accurate
automatic termination controls may actually over-dry beyond the
specified RMC in the field. They also stated that clothes dryers with
less accurate automatic termination controls will not exhibit
equivalent energy consumption and measured EF under the new test
procedure; should not be used as a basis for DOE's analysis; and should
not be considered automatically compliant under the new test procedure.
(California Utilities/NRDC, No. 33 at pp. 6-7)
The California Utilities/NRDC further stated that clothes dryers
with operational automatic cycle termination controls will dry the
clothes to an appropriate range of RMC without over-drying (between
2.5- and 5-percent RMC). They also stated that such clothes dryers
should have about the same measured per-cycle energy use under both the
current and proposed test procedures. The California Utilities/NRDC
stated, however, that by changing the calculation for per-cycle energy
use, and changing the field use factor to 1.0, the calculated final
per-cycle energy use for automatic termination control dryers will
decrease. The California Utilities/NRDC stated that the new test
procedure would make these clothes dryers with operational controls
appear to be more efficient and have a higher EF than under the current
test procedure. The EF for these clothes dryers would increase by 4-
percent through the change in the field use factor alone. The
California Utilities/NRDC stated that, based on their calculations, all
clothes dryers that dry to between 2.5- and 5-percent RMC would have a
higher measured EF. They stated that the energy conservation standards
should be revised to reflect this measured higher EF. The California
Utilities/NRDC commented that for dryers with less accurate automatic
termination controls, EF would decrease because of
[[Page 1023]]
the over-drying energy consumption mesaured using the the new test
procedure. The California Utilities/NRDC stated that adjustments to EF
would be required to account for the new test procedure, per-cycle
energy use calculation, and change in the field use factor. (California
Utilities/NRDC, No. 33 at pp. 7-8)
The California Utilities/NRDC stated they are concerned that by not
changing the clothes dryer standards accordingly DOE's current approach
may qualify as backsliding prohibited by EPCA's ``anti-backsliding''
provision. The California Utilities/NRDC stated that under DOE's
proposed approach, many compliant clothes dryers could test with lower
per-cycle energy use and higher EF, than currently. By not adjusting
the maximum allowable energy use (and minimum allowable EF) for such
dryers, DOE risks effectively weakening the standard. (California
Utilities/NRDC, No. 33 at p. 8) The California Utilities/NRDC proposed
that DOE adjust its proposed candidate standard levels to a level
consistent with the performance of a selection of dryers that are
``minimally compliant'' under both the current and proposed test
procedure. The California Utilities/NRDC also recommended that when DOE
selects a representative sample of minimally compliant clothes dryers,
it choose models that automatically terminate at between 2.5- and 5-
percent RMC. They explained that this approach would remove clothes
dryers with less accurate automatic termination controls that comply
under the current testing procedure and ensure that new standards are
appropriately adjusted, so that the standard is not overly weak. Id.
As discussed in section III.C.2, DOE is not adopting the amendments
to better account for automatic cycle termination proposed in the June
2010 TP SNOPR. For this reason, DOE is not revising the energy
conservation standards based on the amendments for automatic cycle
termination proposed in the June 2010 TP SNOPR. If DOE considers
potential amendments for automatic cycle termination in a future
rulemaking, it will consider any necessary revisions to the energy
conservation standards.
Water Temperature for Clothes Dryer Test Load Preparation
DOE tested the 17 clothes dryers to evaluate the effects on
measured EF to change the water temperature for clothes dryer test load
preparation from 100 [deg]F 5 [deg]F to 60 [deg]F 5 [deg]F, as discussed in section III.C.2. DOE tested these
units according to the current DOE clothes dryer test procedure, first
with a water temperature for clothes dryer test load preparation of 100
[deg]F 5 [deg]F, and then with a water temperature of 60
[deg]F 5 [deg]F. For the ventless clothes dryer test
units, DOE additionally used the proposed testing method for ventless
dryers presented in section III.C.3. For each water temperature, DOE
conducted up to three tests for each test unit and the results were
averaged. Table IV.1 below shows the results from this testing, which
indicate that, on average, measured EF decreases by about 2.9 percent
when the water temperature for clothes dryer test load preparation is
reduced from 100 [deg]F 5 [deg]F to 60 [deg]F
5 [deg]F. DOE also notes the variation in the percentage change in EF
from model to model due to the change in water temperature may also be
due to other test condition tolerances in the test procedure, such as
the specified ranges for ambient temperature and relative humidity.
Table IV.1 DOE Test Results To Evaluate the Effects of Changes to the
Water Temperature for Clothes Dryer Test Load Preparation
------------------------------------------------------------------------
Average EF lb/kWh
--------------------------------
100[deg] 5 minus> 5 % Change
[deg]F Water [deg]F Water
temp temp
------------------------------------------------------------------------
Vented Electric Standard:
Unit 1................... 3.07 3.00 -2.2
Unit 2................... 3.14 3.05 -3.1
Unit 3................... 3.20 3.10 -3.2
Unit 4................... 3.28 3.22 -1.9
Unit 5................... 3.24 3.17 -2.0
Unit 6................... 3.12 2.98 -4.6
Vented Gas:
Unit 7................... 2.78 2.72 -2.4
Unit 8................... 2.83 2.92 3.1
Unit 9................... 2.85 2.64 -7.2
Unit 10.................. 2.80 2.69 -3.7
Unit 11.................. 2.98 2.79 -6.4
Vented Electric Compact
(240V):.................
Unit 12.................. 3.19 2.95 -7.7
Unit 13.................. 2.93 2.84 -3.2
Vented Electric Compact
(120V):
Unit 14.................. 3.23 3.11 -4.0
Ventless Electric Compact
(240V):
Unit 15.................. 2.37 2.22 -6.1
Ventless Electric Combo
Washer-Dryer:
Unit 16.................. 2.01 1.96 -4.0
Unit 17.................. 2.50 2.60 3.8
------------------------------------------------------------------------
Test Procedure for Ventless Clothes Dryers
The amendments for ventless clothes dryers are applicable to
products not covered under the current DOE test procedure. For this
reason, the amendments in today's final rule for ventless clothes
dryers discussed in section III.C.3 would not affect the existing EF
ratings of residential clothes dryers. Therefore, no change to the
current clothes dryer energy conservation standards would be required.
(42 U.S.C. 6293(e))
[[Page 1024]]
Detergent Specifications for Clothes Dryer Test Cloth Preconditioning
DOE stated in the June 2010 TP SNOPR that it is unaware of any data
indicating that changes to the detergent specifications for test cloth
preconditioning discussed in section III.C.4 would affect efficiency
measurements. DOE stated that the proposed amendments in the June 2010
TP SNOPR changing the detergent specifications for test cloth
preconditioning would not affect the EF rating of residential clothes
dryers and would not require the existing energy conservation standards
for these products to be revised because DOE is not aware of any data
indicating the changes to the detergent formula affects the ability of
the clothes dryer to remove moisture from the clothes load during the
drying cycle. For the reasons stated above and in the absence of
comments objecting to this determination, DOE continues to believe that
the change to the detergent specifications would not affect the EF
rating of clothes dryers.
Clothes Dryer Number of Annual Cycles
The amendments for the number of annual use cycles, discussed in
section III.C.5.a, affect only the estimated annual operating cost for
all clothes dryers. The EF rating for clothes dryers is expressed in
terms of the total energy use per drying cycle. Because the EF rating
is measured on a per-cycle basis, the number of annual use cycles is
not used in the calculation. For this reason, DOE stated in the June
2010 TP SNOPR that the proposed amendments to change the number of
clothes dryer annual use cycles would not affect the EF rating of
residential clothes dryers. Therefore, the proposed amendments would
not require the existing energy conservation standards for these
products to be revised.
Whirlpool commented that the change in the number of annual use
cycles has a linear effect ((416-283)/416 = 32 percent), and therefore
the clothes dryer would be rated as consuming 32 percent less energy
under the proposed under the proposed test procedure. (Whirlpool, No.
27 at p. 5) The California Utilities/NRDC supported DOE's proposed
revisions to the energy conservation standards to account for changes
to the cycles per year. (California Utilities/NRDC, No. 33 at p. 6) DOE
first notes it did not propose any revisions to the energy conservation
standards to account for changes to the number of clothes dryer cycles
per year. DOE notes that the current energy conservation standards for
clothes dryers are based on EF and that changes to the number of annual
use cycles does not affect EF for clothes dryers. As a result, DOE
continues to believe that the amendments to change the number of
clothes dryer annual use cycles would not affect the EF rating of
residential clothes dryers. Therefore, the amendments would not require
the existing energy conservation standards for these products to be
revised.
Clothes Dryer Initial Remaining Moisture Content
In the June 2010 TP SNOPR, DOE evaluated how the amendments to the
clothes dryer initial RMC discussed in section III.C.5.b affect the
measured EF. DOE estimated, based on results of testing conducted at an
independent testing laboratory, that the measured EF increases by 41
percent when the initial RMC is reduced to 47 percent. DOE stated that
if the proposed amendments to change the initial RMC from 70 percent
3.5 percent to 47 percent 3.5 percent were
implemented, current energy conservation standards in terms of EF for
vented clothes dryer product classes would need to increase by 41
percent. 75 FR 37594, 37631 (June 29, 2010).
The California Utilities/NRDC supported DOE's proposed revisions to
the energy conservation standards to account for changes in the initial
RMC. (California Utilities/NRDC, No. 33 at p. 6) Whirlpool commented
that the change in RMC is not linear, but that it does not have
sufficient data to fully address how this would be reflected in total
energy consumption. Whirlpool recommended that further study regarding
the impact of changing the RMC on the energy factor be undertaken.
Whirlpool added that if DOE were to make a specific request to AHAM for
such data, Whirlpool would be willing to gather and supply information
to AHAM for aggregation and submittal to DOE. (Whirlpool, No. 27 at pp
4, 5) The Joint Petitioners and AHAM both supported increasing EF for
vented clothes dryer product classes to account for the change in
initial RMC. The Joint Petitioners and AHAM also stated that they do
not currently have data to quantify the increase, but upon DOE request
would gather data to determine an appropriate increase. (Joint
Petitioners, No. 30 at p. 7; AHAM, No. 31 at p. 9) The California
Utilities/NRDC supported DOE's proposed revisions to the energy
conservation standards to account for changes in test load weight,
initial RMC, and cycles per year. (California Utilities/NRDC, No. 33 at
p. 6) ALS supported the manner in which DOE has analyzed the impact of
its proposed revisions to the test procedure on the minimum standard.
ALS requested the analysis be conducted using a methodology consistent
with the ALS proposal of an initial RMC of 53 percent. (ALS, No. 24 at
p. 8)
After issuance of the June 2010 TP SNOPR, DOE conducted additional
clothes dryer testing on 17 representative clothes dryers to evaluate
the effects of the proposed amendment to change the initial RMC from 70
percent 3.5 percent to 57.5 percent 3.5
percent for the measured efficiency. DOE tested these units according
to the current DOE clothes dryer test procedure with an initial RMC of
70 percent 3.5 percent and with an initial RMC of 57.5
percent 3.5 percent. For the ventless clothes dryer test
units, DOE additionally used the proposed testing method for ventless
dryers presented in section III.C.3. For each initial RMC, DOE
conducted up to three tests for each test unit and the results were
averaged Table IV.2 below shows the results from the tests. The results
indicate that, on average, EF increases by about 17.1 percent when the
initial RMC is changed from 70 percent 3.5 percent to 57.5
percent 3.5 percent.
Table IV.2--DOE Test Results To Evaluate the Effects of Changes to the
Initial RMC
------------------------------------------------------------------------
Average EF lb/kWh
--------------------------------
Test unit 70% 3.5% minus> 3.5%
RMC RMC
------------------------------------------------------------------------
Vented Electric Standard:
Unit 1................... 3.07 3.67 19.8
Unit 2................... 3.14 3.62 15.1
Unit 3................... 3.20 3.83 19.6
Unit 4................... 3.28 3.79 15.5
[[Page 1025]]
Unit 5................... 3.24 3.91 20.9
Unit 6................... 3.12 3.70 18.7
Vented Gas:
Unit 7................... 2.78 3.32 19.1
Unit 8................... 2.83 3.43 20.9
Unit 9................... 2.85 3.23 13.3
Unit 10.................. 2.80 3.29 17.5
Unit 11.................. 2.98 3.40 14.2
Vented Electric Compact
(240V):
Unit 12.................. 3.19 3.61 13.2
Unit 13.................. 2.93 3.45 17.7
Vented Electric Compact
(120V):
Unit 14.................. 3.23 4.08 26.1
Ventless Electric Compact
(240V):
Unit 15.................. 2.37 2.74 15.9
Ventless Electric Combo
Washer-Dryer:
Unit 16.................. 2.01 2.33 15.8
Unit 17.................. 2.50 2.70 8.0
------------------------------------------------------------------------
Clothes Dryer Test Load Weight
As noted previously, EF for clothes dryers is the bone-dry test
load weight divided by the clothes dryer energy consumption per cycle.
DOE notes that the proposed amendments to the test load size, discussed
in section III.C.5.c, would increase both the bone-dry test load weight
and the energy consumption per cycle. For example, for a test in which
the nominal RMC of the test load is reduced from an initial 70 percent
to a final 4 percent, an 8.45-lb test load would require about 5.6 lb
of water to be removed during the drying cycle. However, a 7-lb. test
load would require only 4.6 lb. of water to be removed. DOE also notes
that as lower nominal RMCs are reached at the end of the test cycle,
the rate and efficiency of water removal from the load would be higher
for the larger test load. This is because there would simply be more
water in the load, hence making it easier to remove.
In the June 2010 TP SNOPR, DOE reviewed research on the effects of
changing the load size on the measured efficiency to determine a
quantifiable estimate of the change in the measured EF. 75 FR 37594,
37632 (June 29, 2010). NIST conducted testing to investigate the
effects of changing the clothes dryer load size on the measured
efficiency of a vented electric standard clothes dryer with a capacity
of 6.3 ft\3\.\41\ NIST tested the clothes dryer according to the DOE
clothes dryer test procedure, except the test load size varied from 2-
15 lb. Table IV.3 presents the results of the NIST testing, which shows
an increase in EF when the load size was increased in 7-9 lb. range,
which for the purpose of analysis corresponds to the 7-8.45 lb. range.
---------------------------------------------------------------------------
\41\ J. Y. Kao. Energy Test Results of a Conventional Clothes
Dryer and a Condensing Clothes Dryer. pp. 11-21 1999. International
Appliance Technical Conference, 49th. Proceedings. May 4-6,, 1998.
Table IV.3--NIST Vented Electric Standard Clothes Dryer Variable Test Load Data
----------------------------------------------------------------------------------------------------------------
Test Number 1 2 3 4 5 6 7 8
----------------------------------------------------------------------------------------------------------------
Room Temperature, [deg]F........ 74.1 74.4 73.8 73.3 73.8 74.1 74.4 74.4
Room Humidity, %................ 40 38 38 33 42 38 40 36
Nominal Bone-Dry Weight, lb..... 2 3 5 7 9 11 13 15
Measured Bone-Dry Test Load 1.99 2.99 4.99 7.00 8.99 10.98 13.01 15.01
Weight, lb.....................
Measured Dry Test Load Weight, 2.05 3.06 5.17 7.99 9.11 11.56 13.57 15.71
lb.............................
Measured Wet Test Load Weight, 3.40 5.10 8.50 11.89 15.34 18.98 22.04 25.56
lb.............................
Measured Energy Consumption, kWh 0.953 1.159 1.593 2.112 2.667 3.250 3.796 4.384
Initial RMC, %.................. 70.30 70.67 70.52 69.99 70.67 72.81 69.35 70.34
Final RMC, %.................... 2.84 2.48 3.73 2.88 1.28 5.27 4.29 4.67
Per-Cycle Energy Consumption, 0.970 1.167 1.637 2.160 2.638 3.303 4.005 4.582
kWh............................
EF, lb/kWh...................... 2.06 2.56 3.04 3.24 3.41 3.33 3.25 3.27
Percentage Change in EF Compared -36.6 -20.9 -6.0 0.0 5.2 2.7 0.3 1.1
to 7-lb Test, %................
----------------------------------------------------------------------------------------------------------------
In the June 2010 TP SNOPR, DOE estimated the percentage change in
EF for an 8.45-lb test load by linearly interpolating the results for
the 7-lb and 9-lb tests. Estimates based on this method showed the EF
increase by about 3.8 percent when the test load size increased from 7
lb. to 8.45 lb. DOE stated that this percentage change in EF can be
applied to all vented standard-size clothes dryer product classes
because the moisture removal mechanisms are comparable among them. For
these reasons, DOE stated that if the proposed amendments to increase
the test load size to 8.45 .085 lb for standard-size
clothes dryers were implemented, the current energy conservation
standards in terms of EF for vented standard-size clothes dryer product
classes would need to be
[[Page 1026]]
increased by 3.8 percent. 75 FR 37594, 37632 (June 29, 2010).
The California Utilities/NRDC supported DOE's proposed revisions to
the energy conservation standards to account for changes to the test
load weight. (California Utilities/NRDC, No. 33 at p. 6) Whirlpool
commented that the change in load size is not linear, but that it does
not have sufficient data to fully address how this would be reflected
in total energy consumption. Whirlpool commented that if DOE were to
make a specific request to AHAM for such data, Whirlpool would be
willing to gather and supply information to AHAM for aggregation and
submittal to DOE. (Whirlpool, No. 27 at p. 5) The Joint Petitioners and
AHAM supported DOE's proposal to revise the relevant energy
conservation standards to reflect the new test load weight. The Joint
Petitioners and AHAM stated they do not currently have data that would
support a specific test load weight, but upon DOE request would gather
such data. (Joint Petitioners, No. 30 at p. 7; AHAM, No. 31 at p. 9)
DOE conducted additional clothes dryer testing after issuance of
the June 2010 TP SNOPR on 11 representative standard size clothes
dryers to evaluate the effects of the proposed amendment to increase
the test load size for standard-size clothes dryers on the measured
efficiency. DOE tested these units according to the current DOE clothes
dryer test procedure with a 7.00 .07 lb load and at the
increased test load size of 8.45 .085 lb for standard-size
clothes dryers. For the ventless clothes dryer test units, DOE
additionally used the proposed testing method for ventless dryers
presented in section III.C.3. For each test load weight, DOE conducted
up to three tests for each test unit and the results were averaged.
Table IV.4 below shows the results from this testing, which indicate
that, on average, measured EF increases by about 2.6 percent when the
test load weight is increased to 8.45 .085 lb for
standard-size clothes dryers. DOE believes the 2.6 percent increase in
measured EF represents a more accurate estimate than the 3.8 percent
increase because the 2.6 percent increase in measured EF is based on
more extensive testing on a representative sample of clothes dryers.
Table IV.4--DOE Test Results To Evaluate the Effects of Changes to Test
Load Weight for Standard-Size Clothes Dryers
------------------------------------------------------------------------
Average EF lb/kWh
-------------------------------- Percent
Test unit 7.00 .07 lb minus> .085 lb
------------------------------------------------------------------------
Vented Electric Standard:
Unit 1................... 3.07 3.13 2.0
Unit 2................... 3.14 3.21 2.1
Unit 3................... 3.20 3.28 2.5
Unit 4................... 3.28 3.50 6.7
Unit 5................... 3.24 3.34 3.1
Unit 6................... 3.12 3.13 0.4
Vented Gas:
Unit 7................... 2.78 2.85 2.5
Unit 8................... 2.83 2.93 3.3
Unit 9................... 2.85 3.00 5.2
Unit 10.................. 2.80 2.77 -0.9
Unit 11.................. 2.98 3.02 1.5
------------------------------------------------------------------------
All Active Mode Amendments
DOE also analyzed how the fully amended test procedure would affect
the measured EF as compared to the existing test procedure. In the June
2010 TP SNOPR, DOE tested and analyzed minimally compliant clothes
dryers, and reviewed available research. DOE found that the proposed
amendments to the initial RMC would increase the measured EF of
minimally compliant clothes dryers by 41 percent, while the proposed
amendments to the test load size for standard-size clothes dryers would
increase the measured EF for standard-size dryers by 3.8 percent. DOE
also found that because of the proposed amendments in the June 2010 TP
SNOPR, the measured EF of minimally compliant clothes dryers would
increase by about 41 percent for compact-size clothes dryers and about
46 percent for standard-size clothes dryers (determined multiplying the
41 percent increase for the decrease in the initial RMC by the 3.8
percent increase for the increase in test load size for standard-size
clothes dryers). 75 FR 37594, 37638 (June 29, 2010).
The Joint Petitioners stated that the final rule amending the
clothes dryer test procedure should also amend the standards in their
Joint Petition. The standards in the Joint Petition would be amended
according to the procedures in section 323(e)(2), except that to
establish a representative sample of products, DOE shall choose a
sample of minimally compliant clothes dryers that automatically
terminate the drying cycle at no less than 4 percent RMC. (Joint
Petitioners, No. 25 at p. 6) In conducting the analysis under 42 U.S.C.
6293(3)(2) for the current clothes dryer energy conservation standards,
DOE notes that as discussed in section I, EPCA requires that in
determining the amended energy conservation standard, DOE must measure,
pursuant to the amended test procedure, the energy efficiency, energy
use, or water use of a representative sample of covered products that
minimally comply with the existing standard and that the average of
such energy efficiency, energy use, or water use levels determined
under the amended test procedure shall constitute the amended energy
conservation standard for the applicable covered products. (42 U.S.C.
6293(e)(2)) DOE notes that EPCA requires testing of a representative
sample of minimally compliant products, and that the measurement of
only clothes dryers that automatically terminate the drying cycle at no
less than 4 percent RMC would not constitute a representative sample.
In addition, for the reasons discussed in section III.C.2, DOE is not
adopting in today's final rule the amendments for automatic cycle
termination proposed in the June 2010 TP SNOPR. For these reasons, DOE
does not intend to consider such limitations for product testing to
determine the effects of the amended test procedure on the measured
efficiency.
DOE conducted clothes dryer testing on a sample of 17
representative clothes dryers after issuance of the June 2010
[[Page 1027]]
TP SNOPR to evaluate the effects of all of the amendments on the
clothes dryer test procedure on the measured EF. DOE tested these units
according to the amended clothes dryer test procedure in today's final
rule. DOE conducted up to three tests for each test unit and the
results were averaged. The results from this testing are shown in Table
IV.5. For vented electric standard-size clothes dryers, the measured EF
increases by an average of about 20.1 percent as a result of the
amendments to the test procedure in today's final rule. For vented gas
clothes dryers, the measured EF increased by an average of about 19.8
percent. For vented electric compact-size 120V and 240V clothes dryers,
the measured EF increased by an average of about 15.6 and 12.8 percent,
respectively. For ventless electric compact 240V clothes dryers and
ventless electric combination washer/dryers, the measured EF increased
by an average of about 13.6 and 11.4 percent, respectively. DOE notes
that the increase in measured EF is greater for the standard-size
products (that is, for vented electric standard-size and vented gas
clothes dryers) than for compact-size products due to the additional
amendments that specify increased test load sizes for standard-size
products. These measured increases in EF are different from the values
presented in the June 2010 TP SNOPR, and shown above in this section.
This is because the initial RMC was changed from 47 percent to 57.5
percent and the change to the water temperature specified for test load
preparation. These values are also based on more extensive testing on a
representative sample of clothes dryers.
Table IV.5--DOE Test Results To Evaluate the Effects of the Test
Procedure Amendments on Measured EF
------------------------------------------------------------------------
Average EF lb/kWh
-------------------------------- Percent
Test unit Current test Amended test change
procedure procedure
------------------------------------------------------------------------
Vented Electric Standard:
Unit 1................... 3.07 3.69 20.4
Unit 2................... 3.14 3.77 19.5
Unit 3................... 3.20 3.83 19.6
Unit 4................... 3.28 3.92 19.4
Unit 5................... 3.24 3.96 22.5
Unit 6................... 3.12 3.72 19.1
Vented Gas:
Unit 7................... 2.78 3.36 20.6
Unit 8................... 2.83 3.40 19.9
Unit 9................... 2.85 3.42 20.2
Unit 10.................. 2.80 3.37 20.5
Unit 11.................. 2.98 3.50 17.6
Vented Electric Compact
(240V):
Unit 12.................. 3.19 3.56 11.4
Unit 13.................. 2.93 3.35 14.2
Vented Electric Compact
(120V):
Unit 14.................. 3.23 3.74 15.6
Ventless Electric Compact
(240V):
Unit 15.................. 2.37 2.69 13.6
Ventless Electric Combo
Washer-Dryer:
Unit 16.................. 2.01 2.27 12.5
Unit 17.................. 2.50 2.76 10.3
------------------------------------------------------------------------
Table IV.6 shows how the current energy conservation standards
would be affected by the amendments to the DOE clothes dryer test
procedure. DOE will consider such changes in the concurrent energy
conservation standards rulemaking for clothes dryers and room air
conditioners.
Table IV.6--Energy Factor of a Minimally Compliant Clothes Dryer With
the Current and Proposed Amended Test Procedure
------------------------------------------------------------------------
Energy factor lb/kWh
-------------------------
Proposed
Product class Current amended
test test
procedure procedure
------------------------------------------------------------------------
1. Electric, Standard (4.4 ft\3\ or greater 3.01 3.62
capacity)....................................
2. Electric, Compact (120 v) (less than 4.4 3.13 3.62
ft\3\ capacity)..............................
3. Electric, Compact (240 v) (less than 4.4 2.90 3.27
ft\3\ capacity)..............................
4. Gas........................................ 2.67 3.20
------------------------------------------------------------------------
Because the clothes dryer test procedure amendments for active mode
would substantially change the existing EF metric, DOE has decided to
create a new appendix D1 in 10 CFR 430 subpart B. This appendix
contains a clothes dryer test procedure that manufacturers would be
required to use on the mandatory compliance date of any
[[Page 1028]]
amended clothes dryer energy conservation standards. DOE is required by
consent decree to publish the final rule for any amended clothes dryer
energy conservation standards rulemaking by June 30, 2011, and the
compliance date of any amended standards is expected to be 3 years
later. Manufacturers must continue to use appendix D to subpart B of
part 430 for clothes dryers until compliance with any amended energy
conservation standards at 10 CFR 430.32(h) is required, at which point
use of the procedures at appendix D1 will be required.
C. Active Mode--Room Air Conditioners
As discussed in section III.C.6, DOE amends the room air
conditioner test procedure in today's final rule to update the
references to the industry test standards, ANSI/AHAM RAC-1-R2008 and
ANSI/ASHRAE Standard 16-1983 (RA 2009). These amendments provide more
accurate and repeatable measurements of capacity while providing
greater flexibility to manufacturers in selecting equipment and
facilities but do not impact the measurement of EER. Because DOE's
review of the room air conditioner test procedure amendments
tentatively concluded that the measured EER would not be affected,
manufacturers must continue to use appendix F to measure room air
conditioner active mode energy use. Manufacturers would not be required
to use the proposed provisions for standby mode and off mode energy use
(specifically, sections 2.2, 3.2, 4.2, and 5.3) until the mandatory
compliance date of any amended room air conditioner energy conservation
standards.
The Joint Petitioners proposed that the final rule amending the
room air conditioner test procedure must also amend the standards in
the Joint Petition according to the procedures in section 323(e)(2).
(Joint Petitioners, No. 25 at p. 7) As noted above, DOE believes that
the amendments to the room air conditioner test procedure in today's
final rule would not affect the measured efficiency of covered
products, and DOE is not aware of any data indicating otherwise. For
these reasons, DOE continues to believe that revisions to the energy
conservation standards for room air conditioners are not warranted.
All representations related to standby mode and off mode energy
consumption of both clothes dryers and room air conditioners made 180
days after the publication of today's test procedure final rule in the
Federal Register and before the compliance date of amended energy
conservation standards must be based upon the standby mode and off mode
requirements of the amended test procedures. The requirements are
specified in appendix D1 for clothes dryers, and in amended appendix F
for room air conditioners.
V. Procedural Requirements
A. Review Under Executive Order 12866
The Office of Management and Budget has determined that test
procedure rulemakings do not constitute ``significant regulatory
actions'' under section 3(f) of Executive Order 12866, Regulatory
Planning and Review, 58 FR 51735 (Oct. 4, 1993). Accordingly, this
proposed action was not subject to review under the Executive Order by
the Office of Information and Regulatory Affairs (OIRA) in the Office
of Management and Budget (OMB).
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis for any rule
that by law must be proposed for public comment, unless the agency
certifies that the rule, if promulgated, will not have a significant
economic impact on a substantial number of small entities. As required
by Executive Order 13272, ``Proper Consideration of Small Entities in
Agency Rulemaking,'' 67 FR 53461 (Aug. 16, 2002), DOE published
procedures and policies on February 19, 2003 to ensure that the
potential impacts of its rules on small entities are properly
considered during the rulemaking process. 68 FR 7990. DOE's procedures
and policies may be viewed on the Office of the General Counsel's Web
site (http://www.gc.doe.gov).
DOE reviewed today's final rule under the provisions of the
Regulatory Flexibility Act and the procedures and policies published on
February 19, 2003. This final rule prescribes amendments to test
procedures that will be used to test compliance with energy
conservation standards for clothes dryers and room air conditioners
that are described in detail elsewhere in the preamble. DOE certifies
that this final rule will not have a significant impact on a
substantial number of small entities. The factual basis for this
certification is as follows.
The Small Business Administration (SBA) considers an entity to be a
small business if, together with its affiliates, it employs less than a
threshold number of workers specified in 13 CFR part 121. The
thresholds set forth in these regulations are based on size standards
and codes established by the North American Industry Classification
System (NAICS).\42\ The threshold number for NAICS classification for
335224, ``Household Laundry Equipment Manufacturing,'' which includes
clothes dryer manufacturers, is 1,000 employees. Additionally, the
threshold number for NAICS classification for 335415, ``Air-
Conditioning and Warm Air Heating Equipment and Commercial and
Industrial Refrigeration Equipment Manufacturing,'' which includes room
air conditioner manufacturers, is 750 employees.
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\42\ For more information visit: http://www.sba.gov/.
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Most of the manufacturers supplying clothes dryers and room air
conditioners are large multinational corporations. As part of the
energy conservation standards rulemaking for residential clothes dryers
and room air conditioners, DOE requested comment on whether there are
any manufacturer subgroups, including potential small businesses, that
it should consider for its analyses. DOE did not receive any comments
regarding whether there are any residential clothes dryer or room air
conditioner manufacturers that would be considered small businesses.
DOE then conducted a more focused inquiry of the companies that could
be small business manufacturers of products covered by this rulemaking.
During its market survey, DOE used all available public information to
identify potential small manufacturers. DOE's research included the
AHAM membership directory, product databases (the AHRI, AHAM, CEC, and
ENERGY STAR databases), individual company websites, and the SBA
dynamic small business search \43\ to find potential small business
manufacturers. DOE also asked interested parties and industry
representatives if they were aware of any other small business
manufacturers during manufacturer interviews conducted and at DOE
public meetings for the energy conservation standards rulemakings. DOE
also contacted various companies, as necessary, to determine whether
they met the SBA's definition of a small business manufacturer of
covered residential clothes dryers or room air conditioners. DOE
screened out companies that did not offer products covered by this
rulemaking, did not meet the definition of a ``small business,'' or are
foreign owned and operated.
---------------------------------------------------------------------------
\43\ A searchable database of certified small businesses is
available online at: http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm.
---------------------------------------------------------------------------
DOE initially identified at least 14 manufacturers of residential
clothes
[[Page 1029]]
dryers that sold products in the United States. DOE determined that 13
of these companies exceeded the SBA's maximum number of employees or
foreign-owned and operated. Thus, DOE identified only one potential
small business manufacturer of residential clothes dryers but could not
locate this manufacturer on the dynamic small business search on the
SBA website. In addition, upon further review, DOE does not believe
that the small business is a clothes dryer manufacturer. While the
manufacturer has developed a highly efficient technology that, while
not yet commercially available, could be used by other manufacturers to
increase the efficiency of clothes dryers, it does not produce clothes
dryers. Because the company plans to produce only a technology for
clothes dryers that is not yet commercially available, this potential
small business manufacturer has no market share of the residential
clothes dryer market.
For room air conditioners, DOE initially identified at least 11
manufacturers of room air conditioners that sold products in the United
States. DOE determined that 10 of these were large or foreign-owned and
operated. In addition, DOE subsequently determined that the one room
air conditioner manufacturer that was previously designated as a small
business manufacturer now exceeds SBA's employment threshold for
consideration as a small business under the appropriate NAICS code
specified above.
DOE received no comments on the certification, and comments on the
testing burden are discussed elsewhere in the preamble and did not
result in changes to the certification. For these reasons, DOE
certifies that the amendments in today's final rule will not have a
significant economic impact on a substantial number of small entities.
Based on the above, DOE has not prepared a regulatory flexibility
analysis for this rulemaking. DOE transmitted the certification and
supporting statement of factual basis to the Chief Counsel for Advocacy
of the SBA for review under 5 U.S.C. 605(b).
C. Review Under the Paperwork Reduction Act of 1995
Manufacturers of clothes dryers and room air conditioners must
certify to DOE that their products comply with any applicable energy
conservation standard. In certifying compliance, manufacturers must
test their products according to the DOE test procedures for clothes
dryers and room air conditioners, including any amendments adopted for
those test procedures. DOE has proposed regulations for the
certification and recordkeeping requirements for all covered consumer
products and commercial equipment, including clothes dryers and room
air conditioners. 75 FR 56796 (Sept. 16, 2010). The collection-of-
information requirement for the certification and recordkeeping is
subject to review and approval by OMB under the Paperwork Reduction Act
(PRA). This requirement has been submitted to OMB for approval. Public
reporting burden for the certification is estimated to average 20 hours
per response, including the time for reviewing instructions, searching
existing data sources, gathering and maintaining the data needed, and
completing and reviewing the collection of information.
Public comment is sought regarding: Whether this proposed
collection of information is necessary for the proper performance of
the functions of the agency, including whether the information shall
have practical utility; the accuracy of the burden estimate; ways to
enhance the quality, utility, and clarity of the information to be
collected; and ways to minimize the burden of the collection of
information, including through the use of automated collection
techniques or other forms of information technology. Send comments on
these or any other aspects of the collection of information to Subid
Wagley at the ADDRESSES above, and e-mail to [email protected].
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
D. Review Under the National Environmental Policy Act of 1969
In this final rule, DOE is adopting test procedure amendments that
it expects will be used to develop and implement future energy
conservation standards for clothes dryers and room air conditioners.
DOE has determined that this rule falls into a class of actions that
are categorically excluded from review under the National Environmental
Policy Act of 1969 (42 U.S.C. 4321 et seq.) and DOE's implementing
regulations at 10 CFR part 1021. Specifically, this rule amends an
existing rule without changing its environmental effect, and,
therefore, is covered by the Categorical Exclusion in 10 CFR part 1021,
subpart D, paragraph A5, which applies because this rule establishes
revisions to existing test procedures that will not affect the amount,
quality, or distribution of energy usage, and, therefore, will not
result in any environmental impacts. Accordingly, neither an
environmental assessment nor an environmental impact statement is
required.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism,'' imposes certain requirements
on agencies formulating and implementing policies or regulations that
preempt State law or that have Federalism implications. 64 FR 43255
(August 10, 1999). The Executive Order requires agencies to examine the
constitutional and statutory authority supporting any action that would
limit the policymaking discretion of the States, and to carefully
assess the necessity for such actions. The Executive Order also
requires agencies to have an accountable process to ensure meaningful
and timely input by State and local officials in the development of
regulatory policies that have Federalism implications. On March 14,
2000, DOE published a statement of policy describing the
intergovernmental consultation process that it will follow in
developing such regulations. 65 FR 13735. DOE examined this final rule
and determined that it will not preempt State law and will not have a
substantial direct effect on the States, on the relationship between
the national government and the States, or on the distribution of power
and responsibilities among the various levels of government. EPCA
governs and prescribes Federal preemption of State regulations as to
energy conservation for the products that are the subject of today's
final rule. States can petition DOE for exemption from such preemption
to the extent, and based on criteria, set forth in EPCA. (42 U.S.C.
6297(d)) Therefore, Executive Order 13132 requires no further action.
F. Review Under Executive Order 12988
Regarding the review of existing regulations and the promulgation
of new regulations, section 3(a) of Executive Order 12988, ``Civil
Justice Reform,'' 61 FR 4729 (Feb. 7, 1996), imposes on Federal
agencies the general duty to adhere to the following requirements: (1)
Eliminate drafting errors and ambiguity; (2) write regulations to
minimize litigation; (3) provide a clear legal standard for affected
conduct rather than a general standard; and (4) promote simplification
and burden reduction. Section 3(b) of Executive Order 12988
specifically requires that Executive agencies make
[[Page 1030]]
every reasonable effort to ensure that the regulation specifies the
following: (1) The preemptive effect, if any; (2) any effect on
existing Federal law or regulation; (3) a clear legal standard for
affected conduct while promoting simplification and burden reduction;
(4) the retroactive effect, if any; (5) definitions of key terms; and
(6) other important issues affecting clarity and general draftsmanship
under any guidelines issued by the Attorney General. Section 3(c) of
Executive Order 12988 requires Executive agencies to review regulations
in light of applicable standards in sections 3(a) and 3(b) to determine
whether they are met or whether it is unreasonable to meet one or more
of them. DOE has completed the required review and determined that, to
the extent permitted by law, this final rule meets the relevant
standards of Executive Order 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) (Pub.
L. 104-4; 2 U.S.C. 1501 et seq.) requires each Federal agency to assess
the effects of Federal regulatory actions on State, local, and Tribal
governments and the private sector. For a proposed regulatory action
likely to result in a rule that may cause the expenditure by State,
local, and Tribal governments, in the aggregate, or by the private
sector of $100 million or more in any one year (adjusted annually for
inflation), section 202 of UMRA requires a Federal agency to publish
estimates of the resulting costs, benefits, and other effects on the
national economy. (2 U.S.C. 1532(a),(b)) UMRA also requires a Federal
agency to develop an effective process to permit timely input by
elected officers of State, local, and Tribal governments on a proposed
``significant intergovernmental mandate,'' and requires an agency plan
for giving notice and opportunity for timely input to potentially
affected small governments before establishing any requirements that
might significantly or uniquely affect such governments. On March 18,
1997, DOE published a statement of policy on its process for
intergovernmental consultation under UMRA. 62 FR 12820. (The policy is
also available at http://www.gc.doe.gov). DOE reviewed today's final
rule under the statutory requirements and its policy and determined
that the rule contains neither an intergovernmental mandate nor a
mandate that may result in an expenditure of $100 million or more in
any year, so these requirements do not apply.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
Today's final rule will not have any impact on the autonomy or
integrity of the family as an institution. Accordingly, DOE has
concluded that it is not necessary to prepare a Family Policymaking
Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive Order 12630, ``Governmental
Actions and Interference with Constitutionally Protected Property
Rights,'' 53 FR 8859 (March 18, 1988), that this regulation will not
result in any takings that might require compensation under the Fifth
Amendment to the U.S. Constitution.
J. Review Under the Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516 note) provides for agencies to review most
disseminations of information to the public under guidelines
established by each agency pursuant to general guidelines issued by
OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22, 2002), and
DOE's guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has
reviewed today's final rule under OMB and DOE guidelines and has
concluded that it is consistent with applicable policies in those
guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use,'' 66 FR 28355
(May 22, 2001), requires Federal agencies to prepare and submit to OIRA
a Statement of Energy Effects for any proposed significant energy
action. A ``significant energy action'' is defined as any action by an
agency that promulgates or is expected to lead to promulgation of a
final rule, and that: (1) Is a significant regulatory action under
Executive Order 12866, or any successor order; and (2) is likely to
have a significant adverse effect on the supply, distribution, or use
of energy; or (3) is designated by the Administrator of OIRA as a
significant energy action. For any proposed significant energy action,
the agency must give a detailed statement of any adverse effects on
energy supply, distribution, or use if the proposal is implemented, and
of reasonable alternatives to the action and their expected benefits on
energy supply, distribution, and use. Today's regulatory action to
establish amended test procedures for clothes dryers and room air
conditioners is not a significant regulatory action under Executive
Order 12866. It has likewise not been designated as a significant
energy action by the Administrator of OIRA. Moreover, it will not have
a significant adverse effect on the supply, distribution, or use of
energy. Therefore, it is not a significant energy action, and,
accordingly, DOE has not prepared a Statement of Energy Effects.
L. Review Under Section 32 of the Federal Energy Administration Act of
1974
Under section 301 of the DOE Organization Act (Pub. L. 95-91; 42
U.S.C. 7101 et seq.), DOE must comply with section 32 of the Federal
Energy Administration Act of 1974, as amended by the Federal Energy
Administration Authorization Act of 1977 (FEAA). (15 U.S.C. 788)
Section 32 essentially provides in part that, where a proposed rule
authorizes or requires use of commercial standards, the rulemaking must
inform the public of the use and background of such standards. In
addition, section 32(c) requires DOE to consult with the Attorney
General and the Chairman of the Federal Trade Commission (FTC)
concerning the impact of the commercial or industry standards on
competition.
The amendments to the test procedures in today's final rule
incorporate testing methods contained in the commercial standard, IEC
Standard 62301. Specifically DOE is incorporating from section 4,
(``General conditions for measurements''), paragraph 4.2, ``Test
room,'' paragraph 4.3, ``Power supply,'' paragraph 4.4, ``Supply
voltage waveform,'' and paragraph 4.5, ``Power measurement accuracy,''
and from section 5 (``Measurements''), paragraph 5.1, ``General,''
paragraph 5.2, ``Selection and preparation of appliance or equipment,''
and paragraph 5.3, ``Procedure'' of IEC Standard 62301. DOE has
evaluated this standard and is unable to conclude whether it fully
complies with the requirements of section 32(b) of the FEAA (that is,
whether it was developed in a manner that fully provides for public
participation, comment, and review.) DOE has consulted with the
Attorney General and the Chairman of the FTC about the impact on
competition of using the methods contained in this standard, and
neither
[[Page 1031]]
recommended against incorporation of these standards.
M. Congressional Notification
As required by 5 U.S.C. 801, DOE will report to Congress on the
promulgation of today's rule before its effective date. The report will
state that it has been determined that the rule is not a ``major rule''
as defined by 5 U.S.C. 801(2).
VI. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of today's final
rule.
List of Subjects in 10 CFR Part 430
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Imports,
Incorporation by reference, Intergovernmental relations, Small
businesses.
Issued in Washington, DC, on December 15, 2010.
Cathy Zoi,
Assistant Secretary, Energy Efficiency and Renewable Energy.
0
For the reasons stated in the preamble, part 430 of chapter II of title
10, of the Code of Federal Regulations, is amended as set forth below:
PART 430--ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS
0
1. The authority citation for part 430 continues to read as follows:
Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note.
0
2. Section 430.3 is amended by:
0
a. Redesignating paragraphs (e)(1) through (e)(9) as (e)(2) through
(e)(10).
0
b. Adding a new paragraph (e)(1).
0
c. Removing the word ``Standard'' from paragraph (g)(3).
0
d. Redesignating paragraphs (g)(1), (2), and (3) as paragraphs (g)(3),
(1), and (4), respectively.
0
e. Adding new paragraphs (g)(2) and (5).
0
d. Removing in paragraph (1)(1), ``Appendix N to Subpart B'', and
adding in its place, ``Appendix D1, Appendix F and Appendix N to
Subpart B''.
The additions read as follows:
Sec. 430.3 Materials incorporated by reference.
* * * * *
(e) * * *
(1) ANSI/ASHRAE Standard 16-1983 (``ANSI/ASHRAE 16'') (RA 2009),
(Reaffirmation of ANSI/ASHRAE Standard 16-1983 [RA 1999]), Method of
Testing for Rating Room Air Conditioners and Packaged Terminal Air
Conditioners, ASHRAE approved October 18, 1988, and reaffirmed June 20,
2009. ANSI approved October 20, 1998 and reaffirmed June 25, 2009. IBR
approved for Appendix F to Subpart B.
* * * * *
(g) * * *
(2) AHAM HLD-1-2009 (``AHAM HLD-1''), Household Tumble Type Clothes
Dryers, (2009), IBR approved for Appendix D1 to Subpart B.
* * * * *
(5) ANSI/AHAM RAC-1-2008 (``ANSI/AHAM RAC-1''), Room Air
Conditioners, (2008; ANSI approved July 7, 2008), IBR approved for
Appendix F to Subpart B.
* * * * *
0
3. Section 430.23 is amended by revising paragraphs (d) and (f) to read
as follows:
Sec. 430.23 Test procedures for the measurement of energy and water
consumption.
* * * * *
(d) Clothes dryers. (1) The estimated annual operating cost for
clothes dryers shall be--
(i) For an electric clothes dryer, the product of the following
three factors:
(A) The representative average-use cycle of 283 cycles per year,
(B) The per-cycle combined total energy consumption in kilowatt-
hours per-cycle, determined according to 4.6 of appendix D1 to this
subpart, and
(C) The representative average unit cost of electrical energy in
dollars per kilowatt-hour as provided by the Secretary, the resulting
product then being rounded off to the nearest dollar per year, and
(ii) For a gas clothes dryer, the product of the representative
average-use cycle of 283 cycles per year times the sum of:
(A) The product of the per-cycle gas dryer electric energy
consumption in kilowatt-hours per cycle, determined according to 4.2 of
appendix D1 to this subpart, times the representative average unit cost
of electrical energy in dollars per kilowatt-hour as provided by the
Secretary plus,
(B) The product of the per-cycle gas dryer gas energy consumption,
in Btus per cycle, determined according to 4.3 of appendix D1 to this
subpart, times the representative average unit cost for natural gas or
propane, as appropriate, in dollars per Btu as provided by the
Secretary, the resulting product then being rounded off to the nearest
dollar per year plus,
(C) The product of the per-cycle standby mode and off mode energy
consumption in kilowatt-hours per cycle, determined according to 4.5 of
appendix D1 to this subpart, times the representative average unit cost
of electrical energy in dollars per kilowatt-hour as provided by the
Secretary.
(2) The energy factor, expressed in pounds of clothes per kilowatt-
hour, for clothes dryers shall be either the quotient of a 3-pound
bone-dry test load for compact dryers, as defined by 2.7.1 of appendix
D to this subpart before the date that appendix D1 becomes mandatory,
or the quotient of a 7-pound bone-dry test load for standard dryers, as
defined by 2.7.2 of appendix D to this subpart before the date that
appendix D1 becomes mandatory, as applicable, divided by the clothes
dryer energy consumption per cycle, as determined according to 4.1 for
electric clothes dryers and 4.6 for gas clothes dryers of appendix D to
this subpart before the date that appendix D1 becomes mandatory, the
resulting quotient then being rounded off to the nearest hundredth
(.01). Upon the date that appendix D1 to this subpart becomes
mandatory, the energy factor is determined in accordance with 4.7 of
appendix D1, the result then being rounded off to the nearest hundredth
(.01).
(3) Upon the date that appendix D1 to this subpart becomes
mandatory, the combined energy factor is determined in accordance with
4.8 of appendix D1, the result then being rounded off to the nearest
hundredth (.01).
(4) Other useful measures of energy consumption for clothes dryers
shall be those measures of energy consumption for clothes dryers which
the Secretary determines are likely to assist consumers in making
purchasing decisions and which are derived from the application of
appendix D to this subpart before the date that appendix D1 becomes
mandatory and appendix D1 upon the date that appendix D1 to this
subpart becomes mandatory.
* * * * *
(f) Room air conditioners. (1) The estimated annual operating cost
for room air conditioners, expressed in dollars per year, shall be
determined by multiplying the following three factors:
(i) The combined annual energy consumption for room air
conditioners, expressed in kilowatt-hours per year, as determined in
accordance with paragraph (f)(4) of this section, and
(ii) A representative average unit cost of electrical energy in
dollars per kilowatt-hour as provided by the Secretary, the resulting
product then being rounded off to the nearest dollar per year.
[[Page 1032]]
(2) The energy efficiency ratio for room air conditioners,
expressed in Btus per watt-hour, shall be the quotient of:
(i) The cooling capacity in Btus per hour as determined in
accordance with 5.1 of appendix F to this subpart divided by:
(ii) The electrical input power in watts as determined in
accordance with 5.2 of appendix F to this subpart, the resulting
quotient then being rounded off to the nearest 0.1 Btu per watt-hour.
(3) The average annual energy consumption for room air
conditioners, expressed in kilowatt-hours per year, shall be determined
by multiplying together the following two factors:
(i) Electrical input power in kilowatts as determined in accordance
with 5.2 of appendix F to this subpart, and
(ii) The representative average-use cycle of 750 hours of
compressor operation per year, the resulting product then being rounded
off to the nearest kilowatt-hour per year.
(4) The combined annual energy consumption for room air
conditioners, expressed in kilowatt-hours per year, shall be the sum
of:
(i) The average annual energy consumption as determined in
accordance with paragraph (f)(4) of this section, and
(ii) The standby mode and off mode energy consumption, as
determined in accordance with 5.3 of appendix F to this subpart, the
resulting sum then being rounded off to the nearest kilowatt-hour per
year.
(5) The combined energy efficiency ratio for room air conditioners,
expressed in Btu's per watt-hour, shall be the quotient of:
(i) The cooling capacity in Btus per hour as determined in
accordance with 5.1 of appendix F to this subpart multiplied by the
representative average-use cycle of 750 hours of compressor operation
per year, divided by
(ii) The combined annual energy consumption as determined in
accordance with paragraph (f)(4) of this section multiplied by a
conversion factor of 1,000 to convert kilowatt-hours to watt-hours, the
resulting quotient then being rounded off to the nearest 0.1 Btu per
watt-hour.
* * * * *
0
4. Appendix D to subpart B of part 430 is amended by adding
introductory note to read as follows:
Appendix D to Subpart B of Part 430-Uniform Test Method for Measuring
the Energy Consumption of Clothes Dryers
Note: Manufacturers must continue to use appendix D to subpart B
of part 430 until the energy conservation standards for clothes
dryers at 10 CFR 430.32(h) are amended to require mandatory
compliance using appendix D1.
* * * * *
0
5. Appendix D1 is added to subpart B of part 430 to read as follows:
Appendix D1 to Subpart B of Part 430-Uniform Test Method for Measuring
the Energy Consumption of Clothes Dryers
Note: Appendix D1 to subpart B of part 430 is informational
only. Manufacturers must continue to use appendix D to subpart B of
part 430 until compliance with any amended energy conservation
standards for clothes dryers at 10 CFR 430.32(h) is required, at
which time manufacturers must use appendix D1.
1. Definitions
1.1 ``Active mode'' means a mode in which the clothes dryer is
connected to a main power source, has been activated and is
performing the main function of tumbling the clothing with or
without heated or unheated forced air circulation to remove moisture
from the clothing, remove wrinkles or prevent wrinkling of the
clothing, or both.
1.2 ``AHAM'' means the Association of Home Appliance
Manufacturers.
1.3 ``AHAM HLD-1'' means the test standard published by the
Association of Home Appliance Manufacturers, titled ``Household
Tumble Type Clothes Dryers'' (2009), AHAM HLD-1-2009 (incorporated
by reference; see Sec. 430.3).
1.4 ``Automatic termination control'' means a dryer control
system with a sensor which monitors either the dryer load
temperature or its moisture content and with a controller which
automatically terminates the drying process. A mark, detent, or
other visual indicator or detent which indicates a preferred
automatic termination control setting must be present if the dryer
is to be classified as having an ``automatic termination control.''
A mark is a visible single control setting on one or more dryer
controls.
1.5 ``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 the
load is 1 percent or less.
1.6 ``Compact'' or ``compact size'' means a clothes dryer with a
drum capacity of less than 4.4 cubic feet.
1.7 ``Conventional clothes dryer'' means a clothes dryer that
exhausts the evaporated moisture from the cabinet.
1.8 ``Cool down'' means that portion of the clothes drying cycle
when the added gas or electric heat is terminated and the clothes
continue to tumble and dry within the drum.
1.9 ``Cycle'' means a sequence of operation of a clothes dryer
which performs a clothes drying operation, and may include
variations or combinations of the functions of heating, tumbling,
and drying.
1.10 ``Drum capacity'' means the volume of the drying drum in
cubic feet.
1.11 ``IEC 62301'' means the test standard published by the
International Electrotechnical Commission (``IEC''), titled
``Household electrical appliances-Measurement of standby power,''
Publication 62301 (first edition June 2005) (incorporated by
reference; see Sec. 430.3).
1.12 ``Inactive mode'' means a standby mode that facilitates the
activation of active mode by remote switch (including remote
control), internal sensor, or timer, or that provides continuous
status display.
1.13 ``Moisture content'' means the ratio of the weight of water
contained by the test load to the bone-dry weight of the test load,
expressed as a percent.
1.14 ``Moisture sensing control'' means a system which utilizes
a moisture sensing element within the dryer drum that monitors the
amount of moisture in the clothes and automatically terminates the
dryer cycle.
1.15 ``Off mode'' means a mode in which the clothes dryer is
connected to a main power source and is not providing any active or
standby mode function, and where the mode may persist for an
indefinite time. An indicator that only shows the user that the
product is in the off position is included within the classification
of an off mode.
1.16 ``Standard size'' means a clothes dryer with a drum
capacity of 4.4 cubic feet or greater.
1.17 ``Standby mode'' means any product modes where the energy
using product is connected to a main power source and offers one or
more of the following user-oriented or protective functions which
may persist for an indefinite time:
(a) To facilitate the activation of other modes (including
activation or deactivation of active mode) by remote switch
(including remote control), internal sensor, or timer.
(b) Continuous functions, including information or status
displays (including clocks) or sensor-based functions. A timer is a
continuous clock function (which may or may not be associated with a
display) that provides regular scheduled tasks (e.g., switching) and
that operates on a continuous basis.
1.18 ``Temperature sensing control'' means a system which
monitors dryer exhaust air temperature and automatically terminates
the dryer cycle.
1.19 ``Ventless clothes dryer'' means a clothes dryer that uses
a closed-loop system with an internal condenser to remove the
evaporated moisture from the heated air. The moist air is not
discharged from the cabinet.
2. Testing Conditions
2.1 Installation. Install the clothes dryer in accordance with
manufacturer's instructions. For conventional clothes dryers, as
defined in 1.7, the dryer exhaust shall be restricted by adding the
AHAM exhaust simulator described in 3.3.5.1 of AHAM HLD-1
(incorporated by reference; see Sec. 430.3). For ventless clothes
dryers, as defined in 1.19, the dryer shall be tested without the
AHAM exhaust simulator. Where the manufacturer gives the option to
use the dryer both with and without a duct, the dryer shall be
tested without the exhaust simulator. All external joints should be
taped to avoid air leakage. If the manufacturer gives the
[[Page 1033]]
option to use a ventless clothes dryer, as defined in 1.19, with or
without a condensation box, the dryer shall be tested with the
condensation box installed. For ventless clothes dryers, the
condenser unit of the dryer must remain in place and not be taken
out of the dryer for any reason between tests. For drying testing,
disconnect all console lights or other lighting systems on the
clothes dryer which do not consume more than 10 watts during the
clothes dryer test cycle. For standby and off mode testing, the
clothes dryer shall also be installed in accordance with section 5,
paragraph 5.2 of IEC 62301 (incorporated by reference; see Sec.
430.3). For standby and off mode testing, do not disconnect console
lights or other lighting systems.
2.2 Ambient temperature and humidity.
2.2.1 For drying testing, maintain the room ambient air
temperature at 75 3 [deg] F and the room relative
humidity at 50 10 percent relative humidity.
2.2.2 For standby and off mode testing, maintain room ambient
air temperature conditions as specified in section 4, paragraph 4.2
of IEC 62301 (incorporated by reference; see Sec. 430.3).
2.3 Energy supply.
2.3.1 Electrical supply. Maintain the electrical supply at the
clothes dryer terminal block within 1 percent of 120/240 or 120/208Y
or 120 volts as applicable to the particular terminal block wiring
system and within 1 percent of the nameplate frequency as specified
by the manufacturer. If the dryer has a dual voltage conversion
capability, conduct the test at the highest voltage specified by the
manufacturer.
2.3.1.1 Supply voltage waveform. For the clothes dryer standby
mode and off mode testing, maintain the electrical supply voltage
waveform indicated in section 4, paragraph 4.4 of IEC 62301
(incorporated by reference; see Sec. 430.3).
2.3.2 Gas supply.
2.3.2.1 Natural gas. Maintain the gas supply to the clothes
dryer immediately ahead of all controls at a pressure of 7 to 10
inches of water column. If the clothes dryer is equipped with a gas
appliance pressure regulator for which the manufacturer specifies an
outlet pressure, the regulator outlet pressure shall be
approximately that recommended by the manufacturer. The hourly Btu
rating of the burner shall be maintained within 5
percent of the rating specified by the manufacturer. The natural gas
supplied should have a heating value of approximately 1,025 Btus per
standard cubic foot. The actual heating value, Hn2, in
Btus per standard cubic foot, for the natural gas to be used in the
test shall be obtained either from measurements made by the
manufacturer conducting the test using a standard continuous flow
calorimeter as described in 2.4.6 or by the purchase of bottled
natural gas whose Btu rating is certified to be at least as accurate
a rating as could be obtained from measurements with a standard
continuous flow calorimeter as described in 2.4.6.
2.3.2.2 Propane gas. Maintain the gas supply to the clothes
dryer immediately ahead of all controls at a pressure of 11 to 13
inches of water column. If the clothes dryer is equipped with a gas
appliance pressure regulator for which the manufacturer specifies an
outlet pressure, the regulator outlet pressure shall be
approximately that recommended by the manufacturer. The hourly Btu
rating of the burner shall be maintained within 5
percent of the rating specified by the manufacturer. The propane gas
supplied should have a heating value of approximately 2,500 Btus per
standard cubic foot. The actual heating value, Hp, in
Btus per standard cubic foot, for the propane gas to be used in the
test shall be obtained either from measurements made by the
manufacturer conducting the test using a standard continuous flow
calorimeter as described in 2.4.6 or by the purchase of bottled gas
whose Btu rating is certified to be at least as accurate a rating as
could be obtained from measurement with a standard continuous
calorimeter as described in 2.4.6.
2.4 Instrumentation. Perform all test measurements using the
following instruments as appropriate.
2.4.1 Weighing scale for test cloth. The scale shall have a
range of 0 to a maximum of 30 pounds with a resolution of at least
0.2 ounces and a maximum error no greater than 0.3 percent of any
measured value within the range of 3 to 15 pounds.
2.4.1.2 Weighing scale for drum capacity measurements. The scale
should have a range of 0 to a maximum of 500 pounds with resolution
of 0.50 pounds and a maximum error no greater than 0.5 percent of
the measured value.
2.4.2 Kilowatt-hour meter. The kilowatt-hour meter shall have a
resolution of 0.001 kilowatt-hours and a maximum error no greater
than 0.5 percent of the measured value.
2.4.3 Gas meter. The gas meter shall have a resolution of 0.001
cubic feet and a maximum error no greater than 0.5 percent of the
measured value.
2.4.4 Dry and wet bulb psychrometer. The dry and wet bulb
psychrometer shall have an error no greater than 1
[deg]F.
2.4.5 Temperature. The temperature sensor shall have an error no
greater than 1 [deg]F.
2.4.6 Standard Continuous Flow Calorimeter. The calorimeter
shall have an operating range of 750 to 3,500 Btu per cubic feet.
The maximum error of the basic calorimeter shall be no greater than
0.2 percent of the actual heating value of the gas used in the test.
The indicator readout shall have a maximum error no greater than 0.5
percent of the measured value within the operating range and a
resolution of 0.2 percent of the full-scale reading of the indicator
instrument.
2.4.7 Standby mode and off mode watt meter. The watt meter used
to measure standby mode and off mode power consumption of the
clothes dryer shall have the resolution specified in section 4,
paragraph 4.5 of IEC 62301 (incorporated by reference; see Sec.
430.3). The watt meter shall also be able to record a ``true''
average power as specified in section 5, paragraph 5.3.2(a) of IEC
62301.
2.5 Lint trap. Clean the lint trap thoroughly before each test
run.
2.6 Test Clothes.
2.6.1 Energy test cloth. The energy test cloth shall be clean
and consist of the following:
(a) Pure finished bleached cloth, made with a momie or granite
weave, which is a blended fabric of 50-percent cotton and 50-percent
polyester and weighs within +10 percent of 5.75 ounces per square
yard after test cloth preconditioning, and has 65 ends on the warp
and 57 picks on the fill. The individual warp and fill yarns are a
blend of 50-percent cotton and 50-percent polyester fibers.
(b) Cloth material that is 24 inches by 36 inches and has been
hemmed to 22 inches by 34 inches before washing. The maximum
shrinkage after five washes shall not be more than 4 percent on the
length and width.
(c) The number of test runs on the same energy test cloth shall
not exceed 25 runs.
2.6.2 Energy stuffer cloths. The energy stuffer cloths shall be
made from energy test cloth material, and shall consist of pieces of
material that are 12 inches by 12 inches and have been hemmed to 10
inches by 10 inches before washing. The maximum shrinkage after five
washes shall not be more than 4 percent on the length and width. The
number of test runs on the same energy stuffer cloth shall not
exceed 25 runs after test cloth preconditioning.
2.6.3 Test Cloth Preconditioning.
A new test cloth load and energy stuffer cloths shall be treated
as follows:
(1) Bone dry the load to a weight change of 1
percent, or less, as prescribed in section 1.5.
(2) Place the test cloth load in a standard clothes washer set
at the maximum water fill level. Wash the load for 10 minutes in
soft water (17 parts per million hardness or less), using 60.8 grams
of AHAM standard test detergent Formula 3. Wash water temperature is
to be controlled at 140 [deg] 5 [deg]F (60 [deg] 2.7 [deg]C). Rinse water temperature is to be controlled at
100 [deg] 5 [deg]F (37.7 2.7 [deg]C).
(3) Rinse the load again at the same water temperature.
(4) Bone dry the load as prescribed in section 1.5 and weigh the
load.
(5) This procedure is repeated until there is a weight change of
1 percent or less.
(6) A final cycle is to be a hot water wash with no detergent,
followed by two warm water rinses.
2.7 Test loads.
2.7.1 Compact size dryer load. Prepare a bone-dry test load of
energy cloths which weighs 3.00 pounds .03 pounds.
Adjustments to the test load to achieve the proper weight can be
made by the use of energy stuffer cloths, with no more than five
stuffer cloths per load. Dampen the load by agitating it in water
whose temperature is 60 [deg]F 5 [deg]F and consists of
0 to 17 parts per million hardness for approximately 2 minutes in
order to saturate the fabric. Then, extract water from the wet test
load by spinning the load until the moisture content of the load is
between 54.0-61.0 percent of the bone-dry weight of the test load.
2.7.2 Standard size dryer load. Prepare a bone-dry test load of
energy cloths which weighs 8.45 pounds .085 pounds.
[[Page 1034]]
Adjustments to the test load to achieve the proper weight can be
made by the use of energy stuffer cloths, with no more than five
stuffer cloths per load. Dampen the load by agitating it in water
whose temperature is 60 [deg]F 5 [deg]F and consists of
0 to 17 parts per million hardness for approximately 2 minutes in
order to saturate the fabric. Then, extract water from the wet test
load by spinning the load until the moisture content of the load is
between 54.0-61.0 percent of the bone-dry weight of the test load.
2.7.3 Method of loading. Load the energy test cloths by grasping
them in the center, shaking them to hang loosely, and then dropping
them in the dryer at random.
2.8 Clothes dryer preconditioning.
2.8.1 Conventional clothes dryers. For conventional clothes
dryers, before any test cycle, operate the dryer without a test load
in the non-heat mode for 15 minutes or until the discharge air
temperature is varying less than 1 [deg]F for 10 minutes--whichever
is longer--in the test installation location with the ambient
conditions within the specified test condition tolerances of 2.2.
2.8.2 Ventless clothes dryers. For ventless clothes dryers,
before any test cycle, the steady-state machine temperature must be
equal to ambient room temperature described in 2.2.1. This may be
done by leaving the machine at ambient room conditions for at least
12 hours between tests.
3. Test Procedures and Measurements
3.1 Drum Capacity. Measure the drum capacity by sealing all
openings in the drum except the loading port with a plastic bag, and
ensuring that all corners and depressions are filled and that there
are no extrusions of the plastic bag through the opening in the
drum. Support the dryer's rear drum surface on a platform scale to
prevent deflection of the drum surface, and record the weight of the
empty dryer. Fill the drum with water to a level determined by the
intersection of the door plane and the loading port. Record the
temperature of the water and then the weight of the dryer with the
added water and then determine the mass of the water in pounds. Add
or subtract the appropriate volume depending on whether or not the
plastic bag protrudes into the drum interior. The drum capacity is
calculated as follows:
C = w/d
C = capacity in cubic feet.
w = weight of water in pounds.
d = density of water at the measured temperature in pounds per cubic
feet.
3.2 Dryer Loading. Load the dryer as specified in 2.7.
3.3 Test cycle Operate the clothes dryer at the maximum
temperature setting and, if equipped with a timer, at the maximum
time setting and dry the load until the moisture content of the test
load is between 2.5 and 5 percent of the bone-dry weight of the test
load, but do not permit the dryer to advance into cool down. If
required, reset the timer or automatic dry control. If the dryer
automatically stops during a cycle because the condensation box is
full of water, the test is stopped, and the test run is invalid, in
which case the condensation box shall be emptied and the test re-run
from the beginning. For ventless dryers, as defined in 1.19, during
the time between two cycles, the door of the dryer shall be closed
except for loading (and unloading).
3.4 Data recording. Record for each test cycle:
3.4.1 Bone-dry weight of the test load described in 2.7.
3.4.2 Moisture content of the wet test load before the test, as
described in 2.7.
3.4.3 Moisture content of the dry test load obtained after the
test described in 3.3.
3.4.4 Test room conditions, temperature, and percent relative
humidity described in 2.2.1.
3.4.5 For electric dryers--the total kilowatt-hours of electric
energy, Et, consumed during the test described in 3.3.
3.4.6 For gas dryers:
3.4.6.1 Total kilowatt-hours of electrical energy,
Ete, consumed during the test described in 3.3.
3.4.6.2 Cubic feet of gas per cycle, Etg, consumed
during the test described in 3.3.
3.4.6.3 Correct the gas heating value, GEF, as measured in
2.3.2.1 and 2.3.2.2, to standard pressure and temperature conditions
in accordance with U.S. Bureau of Standards, circular C417, 1938.
3.5 Test for automatic termination field use factor. The field
use factor for automatic termination can be claimed for those dryers
which meet the requirements for automatic termination control,
defined in 1.4.
3.6 Standby mode and off mode power. Establish the testing
conditions set forth in Section 2 ``Testing Conditions'' of this
appendix, omitting the requirement to disconnect all console light
or other lighting systems on the clothes dryer that do not consume
more than 10 watts during the clothes dryer test cycle in section
2.1. If the clothes dryer waits in a higher power state at the start
of standby mode or off mode before dropping to a lower power state,
as discussed in section 5, paragraph 5.1, note 1 of IEC 62301
(incorporated by reference; see Sec. 430.3),wait until the clothes
dryer passes into the lower power state before starting the
measurement. Follow the test procedure specified in section 5,
paragraph 5.3 of IEC 62301 for testing in each possible mode as
described in 3.6.1 and 3.6.2, except allow the product to stabilize
for 30 to 40 minutes and use an energy use measurement period of 10
minutes. For units in which power varies over a cycle, as described
in section 5, paragraph 5.3.2 of IEC 62301, use the average power
approach described in paragraph 5.3.2(a) of IEC 62301, except allow
the product to stabilize for 30 to 40 minutes and use an energy use
measurement period not less than 10 minutes.
3.6.1 If a clothes dryer has an inactive mode, as defined in
1.12, measure and record the average inactive mode power of the
clothes dryer, PIA, in watts.
3.6.2 If a clothes dryer has an off mode, as defined in 1.15,
measure and record the average off mode power of the clothes dryer,
POFF, in watts.
4. Calculation of Derived Results From Test Measurements
4.1 Total Per-cycle electric dryer energy consumption. Calculate
the total electric dryer energy consumption per cycle,
Ece, expressed in kilowatt-hours per cycle and defined
as:
Ece = [53.5/(Ww-Wd)] x
Ett x field use,
Where:
53.5 = an experimentally established value for the percent reduction
in the moisture content of the test load during a laboratory test
cycle expressed as a percent.
field use = field use factor.
= 1.18 for clothes dryers with time termination control systems only
without any automatic termination control functions.
= 1.04 clothes dryers with automatic control systems that meet the
requirements of the definition for automatic control systems in 1.4,
1.14 and 1.18, including those that also have a supplementary timer
control, or that may also be manually controlled.
Ww = the moisture content of the wet test load as
recorded in 3.4.2.
Wd = the moisture content of the dry test load as
recorded in 3.4.3.
4.2 Per-cycle gas dryer electrical energy consumption. Calculate
the gas dryer electrical energy consumption per cycle, Ege,
expressed in kilowatt-hours per cycle and defined as:
Ege = [53.5/(Ww-Wd)] x Ete
x field use,
Where:
Ete = the energy recorded in 3.4.6.1 field use, 53.5,
Ww, Wd as defined in 4.1.
4.3 Per-cycle gas dryer gas energy consumption. Calculate the gas
dryer gas energy consumption per cycle, Ege. expressed in
Btus per cycle as defined as:
Egg = [53.5/(Ww - Wd)] x
Etg x field use x GEF
Where:
Etg = the energy recorded in 3.4.6.2
GEF = corrected gas heat value (Btu per cubic feet) as defined in
3.4.6.3, field use, 53.5, Ww, Wd as defined in
4.1.
4.4 Total per-cycle gas dryer energy consumption expressed in
kilowatt-hours. Calculate the total gas dryer energy consumption per
cycle, Ecg, expressed in kilowatt-hours per cycle and
defined as:
Ecg = Ege + (Egg/3412 Btu/kWh)
Where:
Ege as defined in 4.2
Egg as defined in 4.3
4.5 Per-cycle standby mode and off mode energy consumption.
Calculate the dryer inactive mode and off mode energy consumption per
cycle, ETSO, expressed in kWh per cycle and defined as:
ETSO = [(PIA x SIA) + (POFF
x SOFF)] x K/283
Where:
PIA = dryer inactive mode power, in watts, as measured in
section 3.6.1;
[[Page 1035]]
POFF = dryer off mode power, in watts, as measured in
section 3.6.2.
If the clothes dryer has both inactive mode and off mode,
SIA and SOFF both equal 8,620 / 2 = 4,310,
where 8,620 is the total inactive and off mode annual hours;
If the clothes dryer has an inactive mode but no off mode, the
inactive mode annual hours, SIA, is equal to 8,620 and
the off mode annual hours, SOFF, is equal to 0;
If the clothes dryer has an off mode but no inactive mode,
SIA is equal to 0 and SOFF is equal to 8,620
Where:
K = 0.001 kWh/Wh conversion factor for watt-hours to kilowatt-hours;
and
283 = representative average number of clothes dryer cycles in a
year.
4.6 Per-cycle combined total energy consumption expressed in
kilowatt-hours. Calculate the per-cycle combined total energy
consumption, ECC, expressed in kilowatt-hours per cycle and
defined for an electric clothes dryer as:
ECC = Ece + ETSO
Where:
Ece = the energy recorded in 4.1, and
ETSO = the energy recorded in 4.7, and defined for a gas
clothes dryer as:
ECC = Ecg + ETSO
Where:
Ecg = the energy recorded in 4.4, and
ETSO = the energy recorded in 4.7.
4.7 Energy Factor in pounds per kilowatt-hour. Calculate the energy
factor, EF, expressed in pounds per kilowatt-hour and defined for an
electric clothes dryer as:
EF = Wbonedry/Ece
Where:
Wbonedry = the bone dry test load weight recorded in
3.4.1, and
Ece = the energy recorded in 4.1, and
and defined for a gas clothes dryer as:
EF = Wbonedry/Ecg
Where:
Wbonedry = the bone dry test load weight recorded in
3.4.1, and
Ecg = the energy recorded in 4.4,
4.8 Combined Energy Factor in pounds per kilowatt-hour. Calculate
the combined energy factor, CEF, expressed in pounds per kilowatt-hour
and defined as:
CEF = Wbonedry/ECC
Where:
Wbonedry = the bone dry test load weight 3.4.1, and
ECC = the energy recorded in 4.6
0
6. Appendix F to subpart B of part 430 is revised to read as follows:
Appendix F to Subpart B of Part 430-Uniform Test Method for Measuring
the Energy Consumption of Room Air Conditioners
Note: Manufacturers are not required to use the test procedures
and calculations that refer to standby mode and off mode energy
consumption, (specifically, sections 2.2, 3.2, 4.2, and 5.3 of this
appendix F) until the compliance date of any amended energy
conservation standards for room air conditioners at 10 CFR
430.32(b).
1. Definitions.
1.1 ``Active mode'' means a mode in which the room air
conditioner is connected to a mains power source, has been activated
and is performing the main function of cooling or heating the
conditioned space, or circulating air through activation of its fan
or blower, with or without energizing active air-cleaning components
or devices such as ultraviolet (UV) radiation, electrostatic
filters, ozone generators, or other air-cleaning devices.
1.2 ``ANSI/AHAM RAC-1'' means the test standard published
jointly by the American National Standards Institute and the
Association of Home Appliance Manufacturers, titled ``Room Air
Conditioners,'' Standard RAC-1-2008 (incorporated by reference; see
Sec. 430.3).
1.3 ``ANSI/ASHRAE 16'' means the test standard published jointly
by the American National Standards Institute and the American
Society of Heating, Refrigerating, and Air-Conditioning Engineers
titled ``Method of Testing for Rating Room Air Conditioners and
Packaged Terminal Air Conditioners,'' Standard 16-1983 (RA 2009)
(incorporated by reference; see Sec. 430.3).
1.4 ``IEC 62301'' means the test standard published by the
International Electrotechnical Commission, (``IEC''), titled
``Household electrical appliances--Measurement of standby power,''
Publication 62301 (first edition June 2005), (incorporated by
reference; see Sec. 430.3).
1.5 ``Inactive mode'' means a standby mode that facilitates the
activation of active mode by remote switch (including remote
control) or internal sensor or which provides continuous status
display.
1.6 ``Off mode'' means a mode in which a room air conditioner is
connected to a mains power source and is not providing any active or
standby mode function and where the mode may persist for an
indefinite time. An indicator that only shows the user that the
product is in the off position is included within the clasification
of an off mode.
1.7 ``Standby mode'' means any product modes where the where the
energy using product is connected to a mains power source and offers
one or more of the following user oriented or protective functions
which may persist for an indefinite time:
(a) To facilitate the activation of other modes (including
activation or deactivation of active mode) by remote switch
(including remote control), internal sensor, or timer.
(b) Continuous functions, including information or status
displays (including clocks) or sensor-based functions. A timer is a
continuous clock function (which may or may not be associated with a
display) that provides regular scheduled tasks (e.g., switching) and
that operates on a continuous basis.
2. Test methods.
2.1 Cooling. The test method for testing room air conditioners
in cooling mode shall consist of application of the methods and
conditions in ANSI/AHAM RAC-1 sections 4, 5, 6.1, and 6.5
(incorporated by reference; see Sec. 430.3), and in ANSI/ASHRAE 16
(incorporated by reference; see Sec. 430.3).
2.2 Standby and off modes. The method for testing room air
conditioners in standby and off modes shall consist of application
of the methods and conditions in IEC 62301 (incorporated by
reference; see Sec. 430.3), as modified by the requirements of this
standard. The testing may be conducted in test facilities used for
testing cooling performance. If testing is not conducted in such a
facility, the test facility shall comply with IEC 62301 section 4.2.
3. Test conditions.
3.1 Cooling mode. Establish the test conditions described in
sections 4 and 5 of ANSI/AHAM RAC-1 (incorporated by reference; see
Sec. 430.3) and in accordance with ANSI/ASHRAE 16 (incorporated by
reference; see Sec. 430.3).
3.2 Standby and off modes.
3.2.1 Test room conditions. Maintain the indoor test conditions
as required by section 4.2 of IEC 62301 (incorporated by reference;
see Sec. 430.3). If the standby and off mode testing is conducted
in a facility that is also used for testing cooling performance,
maintain the outdoor test conditions either as required by section
4.2 of IEC 62301 or as described in section 3.1. If the unit is
equipped with an outdoor air ventilation damper, close this damper
during testing.
3.2.2 Power supply. Maintain power supply conditions specified
in section 4.3 of IEC 62301 (incorporated by reference; see Sec.
430.3). Use room air conditioner nameplate voltage and frequency as
the basis for power supply conditions. Maintain power supply voltage
waveform according to the requirements of section 4.4 of IEC 62301.
3.2.3 Watt meter. The watt meter used to measure standby mode
and off mode power consumption of the room air conditioner shall
have the resolution specified in section 4, paragraph 4.5 of IEC
62301 (incorporated by reference; see Sec. 430.3). The watt meter
shall also be able to record a ``true'' average power specified in
section 5, paragraph 5.3.2(a) of IEC 62301.
4. Measurements.
4.1 Cooling mode. Measure the quantities delineated in section 5
of ANSI/AHAM RAC-1 (incorporated by reference; see Sec. 430.3).
4.2 Standby and off modes. Establish the testing conditions set
forth in section 3.2. Prior to the initiation of the test
measurements, the room air conditioner shall also be installed in
accordance with section 5, paragraph 5.2 of IEC 62301 (incorporated
by reference; see Sec. 430.3). For room air conditioners that drop
from a higher power state to a lower power state as discussed in
section 5, paragraph 5.1, note 1 of IEC 62301, allow sufficient time
for the room air conditioner to reach the lower power state before
proceeding with the test measurement.
[[Page 1036]]
Follow the test procedure specified in section 5, paragraph 5.3 of
IEC 62301 for testing in each possible mode as described in 4.2.1
and 4.2.2, except allow the product to stabilize for 5 to 10 minutes
and use an energy use measurement period of 5 minutes. For units in
which power varies over a cycle, as described in section 5,
paragraph 5.3.2 of IEC 62301, use the average power approach in
paragraph 5.3.2(a).
4.2.1 If a room air conditioner has an inactive mode, as defined
in 1.5, measure and record the average inactive mode power of the
room air conditioner, PIA, in watts.
4.2.2 If a room air conditioner has an off mode, as defined in
1.6, measure and record the average off mode power of the room air
conditioner, POFF, in watts.
5. Calculations.
5.1 Calculate the cooling capacity (expressed in Btu/hr) as
required in section 6.1 of ANSI/AHAM RAC-1 (incorporated by
reference; see Sec. 430.3) and in accordance with ANSI/ASHRAE 16
(incorporated by reference; see Sec. 430.3).
5.2 Determine the electrical power input (expressed in watts) as
required by section 6.5 of ANSI/AHAM RAC-1 (incorporated by
reference; see Sec. 430.3) and in accordance with ANSI/ASHRAE 16
(incorporated by reference; see Sec. 430.3).
5.3 Standby mode and off mode annual energy consumption.
Calculate the standby mode and off mode annual energy consumption
for room air conditioners, ETSO, expressed in kilowatt-
hours per year, according to the following:
ETSO = [(PIA x SIA) +
(POFF x SOFF)] x K
Where:
PIA= room air conditioner inactive mode power, in watts,
as measured in section 4.2.1
POFF = room air conditioner off mode power, in watts, as
measured in section 4.2.2.
If the room air conditioner has both inactive mode and off mode,
SIA and SOFF both equal 5,115 / 2 = 2,557.5,
where 5,115 is the total inactive and off mode annual hours;
If the room air conditioner has an inactive mode but no off mode,
the inactive mode annual hours, SIA, is equal to 5,115
and the off mode annual hours, SOFF, is equal to 0;
If the room air conditioner has an off mode but no inactive mode,
SIA is equal to 0 and SOFF is equal to
STOT;
K = 0.001 kWh/Wh conversion factor for watt-hours to kilowatt-hours.
[FR Doc. 2010-32118 Filed 1-5-11; 8:45 am]
BILLING CODE 6450-01-P