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Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules
khammond on DSKJM1Z7X2PROD with PROPOSALS3

2. Inverting the Water Metric As described previously, IWF is calculated in section 4.2.13 of Appendix J2 as the total weighted per-cycle water consumption in gallons for all wash cycles divided by the capacity of the clothes container in ft3. Unlike the IMEF metric, in which a higher number indicates more efficient performance, a lower IWF value indicates more efficient performance.
In the May 2020 RFI, DOE requested feedback on whether to consider any changes to the water efficiency metric defined in the test procedure to maintain consistency with any changes to the capacity metric or for any other purpose, including those described for the energy efficiency metric, and whether it would be appropriate to invert the existing calculation such that a higher value of IWF would represent more efficient performance. 85 FR
31065, 31080.
The CA IOUs supported inverting the IWF and WF metrics to better align with the IMEF and MEF metrics. CA IOUs, No. 8 at p. 6 Additionally, the CA IOUs recommended that DOE should consider changing the name of the updated metrics in order to alert customers and relevant stakeholders of the implications of the change. Id.
DOE is proposing to invert the water metric, in conjunction with replacing the capacity term with weighted-average load size, as described in the previous section. By inverting the metric, a higher value would represent more efficient performance, consistent with the energy efficiency metrics. In addition, by inverting the metric, the proposed WER metric would represent the ratio of the useful output of services to the water use of the product, consistent with EPCAs definition of energy efficiency as described.
DOE is proposing to define WER in the proposed new Appendix J as the quotient of the weighted-average load size in lb divided by the total weighted per-cycle water consumption for all wash cycles in gallons.
DOE requests comment on its proposal to invert the water efficiency metric and calculate the newly defined WER metric as the quotient of the weighted-average load size divided by the total weighted per-cycle water consumption for all wash cycles.
3. Annual Energy Use The annual energy consumption of an RCW tested according to Appendix J2 is calculated as part of the estimated annual operating cost calculations at 10

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CFR 430.23j1iiA and B.52 In each equation, annual energy consumption is calculated by multiplying the per-cycle energy consumption 53 by the representative average RCW use of 295
cycles per year.54 The annual operating cost is provided to the consumer on the Federal Trade Commission FTC
EnergyGuide label for RCWs.
DOE considered whether to make changes to the method for calculating annual energy use so that the calculation more directly reflects annual energy use during a representative average use cycle. DOE also considered whether changes to the overall calculation methodology would improve the usefulness of the information presented to the consumer on the product label.
According to the current calculation methodology, all clothes washers are assumed to be used for 295 cycles per year, while the per-cycle energy reflects a weighted-average load size based on the clothes washer capacity. Therefore, the annual energy calculation reflects an annual volume of laundered clothing that scales with clothes washer capacity.
For example, the current annual energy calculation methodology is based on an annual laundry volume of 2,258 pounds for a 3.0-ft3 RCW and 4,036 pounds for a 6.0-ft3 RCW. 85 FR 31065, 31081.
Under the current annual energy calculation methodology, the information presented on the product label would indicate that a largercapacity RCW would use significantly more annual energy than a smallercapacity model with the same IMEF
rating. This is because the largercapacity RCWs label would be based on a significantly larger amount of annual laundry than the smaller-capacity model, as illustrated above. Whereas, if compared on the basis of an equivalent volume of laundered clothing, both RCWs could be expected to use the same amount of annual energy since they have the same IMEF efficiency rating. This potential disparity may limit the ability of an individual consumer to use the information presented on the product label to compare the differences in expected energy use among RCW models with the 52 Part A provides the calculation when electrically heated water is used. Part B provides the calculation when gas-heated or oil-heated water is used.
53 These equations include the machine electrical energy consumption, hot water energy consumption, and combined low-power mode energy consumption; they exclude the energy consumption for removal of moisture from the test load i.e., the drying energy.
54 See section III.G.1 of this document for DOEs proposal to modify the representative average clothes washer use per year.

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same rated energy efficiency but different capacities.
When DOE originally developed the annual energy calculation methodology at 10 CFR 430.23j1i, the test procedure accommodated clothes washers with capacities up to 3.8 ft3.55
An increasingly wide range of RCW
capacities are available on the market, ranging from less than 1.0 ft3 to greater than 6.0 ft3. As the range of capacities increases, the effect of capacity on the represented annual energy cost becomes more pronounced.
Given the increasingly wide range of RCW capacities available on the market, and the significant changes over time in estimated annual RCW cycles, DOE
considered whether any changes are warranted for the annual energy and annual water calculations to ensure that the results continue to reflect representative average use for all clothes washer sizes, to harmonize with any changes to other metrics within the DOE
test procedures, and to continue to provide useful comparative information to consumers. 85 FR 31065, 31081. DOE
described two examples in the May 2020 RFI:
Revising the annual energy and annual water calculation methodology from being based on a fixed number of annual cycles to a fixed number of annual pounds of clothing.
Varying the annual number of wash cycles based on clothes washer capacity, rather than a fixed number of annual cycles for all clothes washers. Id.
In the May 2020 RFI, DOE requested data and information regarding whether and how the annual number of wash cycles varies as a function of clothes washer capacity. Id. DOE also requested feedback on whether DOE should consider any changes to the annual energy or annual water calculation methodology and the burden associated with these potential changes. Id.
NEEA recommended that DOE change the annual energy metric to use an average number of pounds of textiles washed annually instead of using an average number of cycles per year.
NEEA stated that its research found that neither number of cycles nor load size scales with capacity, suggesting that this change would provide a more effective comparison of clothes washers with different capacities. NEEA, No. 12 at p.
25
The CA IOUs supported DOEs current method of basing annual energy calculations on a fixed number of wash cycles per year, rather than using a fixed amount of clothing washed per year.
55 The maximum capacity in the original load size table in Appendix J11997 was 3.8 ft3.

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