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Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules
a logarithmic relationship between capacity and load size. CA IOUs, No. 8
at pp. 14 The CA IOUs presented data from a 2016 Pacific Gas and Electric Company PG&E field survey 2016
PG&E survey that recorded load size and capacity data, and showed a logarithmic relationship between load size and capacity for clothes washers with capacities from 25 ft3. In the range of 2 ft3 to approximately 5 ft3
capacity, the 2016 PG&E survey showed slightly higher average consumer load sizes than would be defined by Table 5.1 in Appendix J2 for a clothes washer of the same capacity. The CA IOUs commented that extrapolating this relationship to smaller and largercapacity clothes washers, however, would result in a smaller consumer load sizes than would be defined by Table 5.1 of the current Appendix J2. Id. The CA IOUs also commented that a similar logarithmic trend was found in an Australian clothes dryer study.30
Although the Australian study relates to residential clothes dryers, the CA IOUs asserted that the operation of clothes washers and clothes dryers are closely linked. Id. The CA IOUs commented that the 2016 PG&E survey excludes households outside of the hot-dry Southwestern region of the United States, as well as households that rely on CCWs to wash their clothes, and requested that DOE conduct a larger national survey or study existing surveys to explore the relationship between capacity and average load size before making any changes to Table 5.1
of Appendix J2 to ensure that the test procedure produces results that most represent an average use cycle. Id.
DOE appreciates the CA IOUs providing consumer usage data from the 2016 PG&E field survey. While the conclusions from this data may be instructive as a point of comparison, these data are limited in that they represent usage in a single season summer, in a single state California, and only around three wash cycles per participating household.31
Notwithstanding these limitations, the results indicate that within the range of 2 to approximately 5 ft3, which encompasses the large majority of units on the market, the load sizes defined by Appendix J2 are reasonably close to the load sizes observed in the 2016 PG&E
field study. Regarding the Australian clothes dryer study, while these data 30 Lloyd Harrington of Energy Efficient Strategies, Australia. Supporting data and corresponding presentations: eedal2017.uci.edu/wp-content/
uploads/Thursday-17-Harrington.pdf.
31 According to CA IOUs, the data represent 310
wash cycles across 105 California households. CA
IOUs, No. 8 at p. 7

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provide a point of comparison, usage patterns of Australian consumers do not necessarily represent the usage patterns of U.S. consumers. DOE is not aware of, and the CA IOUs have not provided, any data or information that would suggest that Australian usage patterns are the same as U.S. usage patterns. Further, clothes dryer load sizes may differ from clothes washer loads for reasons which may depend on region or localized customs for example, line drying clothing may be more common in hot, dry climates. DOE is not aware of, nor have the CA IOUs provided, any data to suggest how Australian dryer load sizes relate to Australian clothes washer load sizes. DOE also observes that a logarithmic trend may not represent the best characterization of the Australian data.
NEEA recommended that, if DOE
were to adopt an efficiency metric that is a function of capacity, DOE should eliminate the current average load calculation method and replace it with a fixed 7.6 lb load, which it believes would be more representative. NEEA
cited its 2014 laundry field study that found an average clothes washer load size of 7.6 lb, which NEEA
characterized as being close to the average load size of 8.5 lb that corresponds with the 2010 marketweighted average capacity of 3.5 ft3.
NEEA stated, however, that the marketweighted average capacity as of 2019
has increased to 4.4 ft3, for which Appendix J2 defines an average load size of 10.4 lb.32 NEEA, No. 12 at pp.
2224 NEEA compared this 10.4 lb average load size to three Australian field studies that found an average load size of approximately 6.6 lb. NEEA
further referenced another Australian research study conducted by Choice 33
in which consumers were instructed to fully fill the clothes container. The resulting average load size measured during the study was 8 lb, which NEEA
described as significantly less than an amount that the clothes container could hold. Id. NEEA asserted that using a fixed average load size of 7.6 lb would increase representativeness, stating that 32 NEEAs estimate of 4.4 ft3 average capacity in 2019 is based on NEEAs 2019 ENERGY STAR
Retail Products Platform data.
33 Washing machine user habits: A report on wash temperature and load size habits among CHOICE Members. 2011. Prepared for the Australian Department of Climate Change and Energy. Not publicly published, but can be made available upon request to Simon Newman, Residential Energy Efficiency Branch, Energy Security and Efficiency Division, Department of Industry, Science, Energy and Resources, PO Box 2013, Canberra, ACT 2601. 39 Personal Communication. Lloyd Harington, Energy Efficient Strategies. 17 June 2020.

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the growing inconsistency between field-measured average load size and Appendix J2-calculated average load size indicates that average load size is independent of clothes washer capacity and is relatively small. Id. NEEA also stated that using a fixed average load size would reduce test burden, since less work would be required by the laboratory to build an inventory of custom Appendix J2-defined average loads for each clothes washer capacity.
NEEA recommended that if DOE were to determine a field average load size for the United States, DOE could conduct a study similar to the referenced Choice study but with a representative group of consumers in the United States. Id.
DOE appreciates NEEA providing the consumer usage data from the 2014
laundry study. DOE does not agree with NEEAs conclusion that the 2014
laundry study confirms that the field average load size is independent of clothes container size and is relatively small. In support of its assertion, NEEA
presented data indicating that current 2019 average capacity has increased to 4.4 ft3, for which Appendix J2 defines an average load size of 10.4 lb. However, NEEA did not present any field data demonstrating average consumer load sizes for a sample of clothes washers with an average capacity of 4.4 ft3.
Therefore, no conclusions can be drawn from the 2014 laundry study regarding how consumer load sizes may have changed as average clothes washer capacity has increased from around 3.5
ft3 in 2010 to 4.4 ft3 in 2019. Regarding NEEAs summary of the three Australian field studies, DOE reiterates that the usage patterns of Australian consumers do not necessarily represent the usage patterns of U.S. consumers. DOE notes that the summaries of the Electrolux and Fisher & Paykel surveys provided by NEEA do not identify the average capacity of the clothes washers in the survey samples. Therefore, no conclusions can be drawn regarding how the average consumer load size of 6.6 lb from the surveys compares to the load size that Appendix J2 would prescribe for a U.S. clothes washer of the same size. While DOE agrees that using a fixed average load size could decrease test burden by avoiding the need to inventory different average load sizes for each possible capacity, for the reasons described above, DOE
preliminarily concludes that the data provided by NEEA do not justify using a fixed average load size across all clothes container capacities.
The Joint Commenters also encouraged DOE to consider specifying an average load size that is a constant value independent of capacity. Joint
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