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Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules
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optional cycle modifiers. Joint Commenters, No. 10 at p. 4
Samsung suggested that DOE amend section 2.8 of Appendix J2 to note that at test load sizes Max and Min for manual and automatic water control systems, the corresponding water fill setting should require the use of any user-selectable options to change water level in order to reflect real-world minimum and maximum fill levels.
Samsung, No. 6 at p. 3
DOE is not aware of any consumer usage data concerning the use of optional cycle modifiers, nor did interested parties provide any such data.
Although DOE maintains that the growing presence of such features may be indicative of an increase in consumer usage of these features, DOE lacks consumer usage data that would be required to incorporate the testing of such features in the test procedure.
Therefore, DOE is not proposing to change the current requirement to use the manufacturer default settings for optional cycle modifiers.
In response to Samsungs comment, DOE notes that in section 3.2.7 of Appendix J2, wash water fill levels are excluded from the list of cycle options for which the manufacturer default settings must be used. Selecting the most or least energy intensive water fill setting as required in section 3.2.6.2.2 for clothes washers with useradjustable automatic WFCS would therefore require changing an optional cycle modifier from its default position if doing so would provide the most or least energy intensive result.
Finally, as discussed in section III.D.4
of this document, DOE is proposing in the proposed new Appendix J to require measuring RMC on each tested cycle using the default spin settings for each cycle. Consistent with this proposal, DOE is proposing to remove spin speeds on wash cycles used to determine RMC from the list of cycle settings that are excluded from the requirement to use the manufacturer default settings in section 3.2.4
Manufacturer default settings of the proposed new Appendix J.
DOE requests comment on maintaining the current requirement to use the manufacturer default settings for optional cycle modifiers.
10. Clothes Washers With Connected Functionality DOE is aware of several connected RCW models currently on the market, from at least four major manufacturers.
85 FR 31065, 31068. These products offer optional wireless network connectivity to enable features such as remote monitoring and control via
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smartphone, as well as certain demand response features 50 available through partnerships with a small number of local electric utilities. Id. In addition, connected features are available via certain external communication modules for CCWs. Id. However, DOE is not aware of any CCW models currently on the market that incorporate connected features directly into the unit. Id.
As noted previously, section 3.2.7 of Appendix J2 specifies using the manufacturer default settings for any cycle selections except temperature selection, wash water fill level, or spin speed. Furthermore, section 3.9.1 of Appendix J2 specifies performing the combined low-power mode testing without changing any control panel settings used for the active mode wash cycle. With regard to the measurement of network mode energy use specifically, DOE stated in the March 2012 Final Rule that DOE cannot thoroughly evaluate these IEC Standard 62301 Second Edition network mode provisions, as would be required to justify their incorporation into DOEs test procedures at this time. 77 FR
13887, 13899. DOE notes that although an individual appliance may consume a relatively small amount of power in network mode, the potential exists for energy-related benefits that more than offset this additional power consumption if the appliance can be controlled by the smart grid to consume power during non-peak periods. 85 FR 31065, 31068.
If connected features on a clothes washer affect its inactive mode power consumption in the as-shipped configuration e.g., by energizing a wireless communication chip on the circuit board by default, such impact would be measured by the current test procedure provisions in section 3.9 of Appendix J2 for measuring combined low-power mode power. Whereas, if the inactive mode power consumption is not affected unless the consumer actively enables the connected functionality on the unit, any incremental inactive mode power consumption resulting from the connected features would not be measured by the current test procedure, because the test procedure does not include instructions for activating any such features before performing the lowpower mode measurement. Similarly, any incremental energy consumption in 50 Demand response features refers to product functionality that can be controlled by the smart grid to improve the overall operation of the electrical grid, for example by reducing energy consumption during peak periods and/or shifting power consumption to off-peak periods.

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active mode, or any other modes of operation impacted by the products connected features, would not be measured as part of the current DOE test procedure, because the test cycle requirements in section 3.2.7 of Appendix J2 do not include instructions for activating any such features before performing the active mode test cycles.
In the May 2020 RFI, DOE requested feedback on its characterization of connected RCWs, and any CCWs, currently on the market. Id. Specifically, DOE requested input on the types of features or functionality enabled by connected clothes washers that exist on the market or that are under development. Id. DOE also sought comment on adding a clarifying provision that would require testing to be conducted with any network functionality turned off, or without measuring or reporting the energy use of the clothes washer in network mode. Id.
DOE also requested data on the percentage of users purchasing connected RCWs who activate the connected capabilities, and, for those users, the percentage of the time when the connected functionality of the RCW
is activated and using additional energy.
Id.
The CA IOUs recommended that network-capable RCWs be tested with connected functions activated to capture the energy use associated with these functions, especially as connected clothes washers become more prevalent.
The CA IOUs commented that while network capabilities may use a small amount of power compared to the active washing cycle, these features often operate year-round and could potentially consume a significant amount of energy annually. CA IOUs, No. 8 at pp. 1213 The CA IOUs added that capturing the energy consumption associated with connected features should not hinder their continued development. Id.
The Joint Commenters recommended that DOE incorporate a measurement of network mode power consumption to provide consumers with information about any additional energy consumption associated with connected features. The Joint Commenters stated that, although it asserts that DOE is concerned about impeding innovation, the power consumption associated with network mode may be accounted for in energy conservation standards so as not to hinder the availability of models with connected features. Joint Commenters, No. 10 at p. 2
NEEA recommended that DOE
develop a method for measuring standby mode energy use of clothes washers with connected functionality,
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