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Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules Commenters, No. 10 at pp. 45
According to the Joint Commenters, the introduction of large-capacity clothes washers to the market, combined with the structure of Table 5.1 in Appendix J2, has led to the weighted-average load size for the largest clothes washers being significantly greater than that for small clothes washers. For example, the Joint Commenters stated that the weightedaverage load size for a 6.0 ft3 clothes washer 13.68 lb is around 60 percent larger than the weighted-average load size for a 3.5 ft3 clothes washer 8.68 lb.
Id. The Joint Commenters also referenced NEEAs laundry field study, which the Joint Commenters characterized as finding no clear correlation between clothes washer capacity and load size. The Joint Commenters expressed concern that the current test procedure may not be representative of an average cycle use for large-capacity clothes washers. Id.

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As noted previously, DOE preliminary concludes that the data provided by NEEA, as referenced by the Joint Commenters, do not demonstrate that using a fixed average load size would be representative of U.S. consumer usage.
DOE also notes that the assertion made by NEEA and the Joint Commenters that consumer average load sizes are smaller than DOEs Appendix J2 load sizesconflicts with the data summarized above from the CA IOUs, which suggest consumer average load sizes for clothes washers in the range of 2 to 5 ft3 capacity that are larger than the Appendix J2 load sizes. These conflicting conclusions, combined with the noted limitations of each data set, do not provide justification for DOE to change the average load sizes in Table 5.1 of Appendix J2.

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As noted, DOE is proposing to replace the minimum, maximum, and average load sizes with two new load sizes in the proposed new Appendix J, designated as small and large. In the paragraphs that follow, DOE
explains its rationale for 1 reducing the number of load sizes from three to two, and 2 defining the two load sizes for each capacity bin.
As discussed in section III.A of this document, AHAM and GEA commented on the current test burden associated with conducting the Appendix J2 test procedure. While DOE acknowledges the theoretical possibility of Appendix J2 requiring up to 70 test cycles, DOE is not aware of any products currently or historically on the market that would require this maximum number of test cycles. In DOEs experience, in practice the number of test cycles is around 6
cycles for clothes washers with very few and basic features; around 1520 cycles for the most typical configurations on the market; and around 35 cycles for the most feature-rich models that would trigger the greatest number of required test cycles in Appendix J2.
Nevertheless, DOE seeks to find opportunities for reducing the test burden associated with its test procedures, while maintaining representative, repeatable, and reproducible test results.
One of the key contributors to the total number of required cycles is the requirement to test three load sizes for each wash/rinse temperature selection required for testing on clothes washers with automatic WFCS which represent the majority of the market. As described previously, the three load sizes were devised to approximate a normal distribution of consumer load sizes. At the time of the August 1997

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Final Rule, clothes washer control panels were not as feature-rich as current models available on the market, and DOE had not contemplated that future clothes washer models could require testing up to 35 cycles.
Given the increasing prevalence of more feature-rich clothes washer models that require a higher number of test cycles under Appendix J2, DOE is proposing to reduce test burden by reducing the number of defined load sizes for the proposed new Appendix J
from three to two for clothes washers with automatic WFCS. The following paragraphs discuss how DOE proposes to define the two load sizes for each capacity bin.
The new proposed small and large load sizes would continue to represent the same roughly normal distribution presented in the 1995 P&G data described above. The weighted-average load size using the proposed small and large load sizes would match the weighted-average load size using the current minimum, average, and maximum load sizes. As proposed, the small and large load sizes would have equal load usage factors LUFs 34 of 0.5. The small and large load sizes would represent approximately the 25th and 75th percentiles of the normal distribution, respectively. Each of these points is discussed in greater detail in the paragraphs that follow.
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Figure III.3 illustrates how the proposed new small and large load sizes would overlay with the P&G load distribution data.
34 LUFs are weighting factors that represent the percentage of wash cycles that consumers run with a given load size.

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