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Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules
un-tested, and potentially more energyintensive mode, in order to access the spin speed they intend to use. Samsung suggested that for such units, DOE
consider requiring an additional test at another temperature setting where the spin speed is selectable. Samsung, No.
6 at pp. 23
NEEA commented that it was not aware of any units with spin speeds that are available only on certain temperature selections, but asserted that Appendix J2s current RMC test does not represent the range of RMCs expected in the field, even when maximum and minimum speeds are tested as specified in Appendix J2.
NEEA presented RMC data from its testing of three top-selling clothes washer models, which demonstrated a difference in RMC of 0.31.1 percentage points between maximum and minimum speed.42 NEEA, No. 12 at p.
5 NEEA described laboratory testing it conducted to isolate and measure variables that affect RMC: testing was performed on 12 top-selling RCW
models including six front-loading and five top-loading, representing over five manufacturers, and spanning the range of efficiencies available on the market;
two CCWs were tested as well. NEEA
at No. 12, pp. 213 NEEA stated its testing was performed according to the DOE Appendix J2 procedure, except that the RMC was calculated for all test runs performed; an encoder noninvasively measured revolutions per minute during test runs; and some tests were performed at different load sizes or using different cycle selections. Based on its data, NEEA stated that the current Appendix J2 RMC test does not represent the RMC of an average clothes washer cycle. NEEA asserted that the RMC test procedure prescribed in Appendix J2 represents a best-case scenario for RMC conditionsevery other test that NEEA performed at alternate temperatures, load sizes, and cycle types increased the RMC value relative to the Appendix J2-tested value.
Id. NEEA commented that, according to its testing, the primary difference in RMC for a given clothes washer was due to programmed spin differences such as spin time, and not differences in load size. Id. NEEAs stated that its test data show that among all the clothes washers tested, spin time was, on average, 7
minutes longer using the Cold Wash/
Cold Rinse temperature selection with the maximum spin selection than when 42 DOE notes that in NEEAs comment, this range was cited as 0.30.9, but the data in the table presented by NEEA displayed a range of 0.31.1
percentage points between the RMCs at maximum and minimum speed.

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using the Warm Wash/Cold Rinse temperature selection with the default spin selection. These differences resulted in an RMC difference of an average of 10 percentage points. Id.
NEEA recommended that DOE measure RMC at the default spin setting for each temperature selection and load size, and average those RMC values using TUFs and LUFs. NEEA stated that this approach will reduce test burden by removing the need for a separate test run exclusively for measuring RMC, increase representativeness by capturing RMC for all load sizes and water temperatures, and potentially result in significant energy savings for clothes dryers in the future. Id.
The Joint Commenters and CA IOUs supported NEEAs comments and urged DOE to amend the test procedure to measure RMC for all load sizes and temperature selections, and to weight the measurements using LUFs and TUFs because doing so would improve the representativeness of the test procedure.
Joint Commenters, No. 10 at pp. 12;
CA IOUs, No. 8 at pp. 67 The Joint Commenters stated that the current test procedure is likely significantly underestimating drying energy use and is leading to inaccurate efficiency ratings. Joint Commenters, No. 10 at p.
1 DOE is proposing an amended method for measuring RMC in the proposed new Appendix J that would require measuring RMC on each of the energy test cycles using the default spin settings, and determining the final RMC
by weighting the individual RMC
measurements using the same TUFs and LUFs that apply to the water and energy measurements. DOE notes that this proposal is largely consistent with the approach recommended by NEEA and supported by the Joint Commenters and CA IOUs.
DOE tentatively concludes based on its test observations as described above and the test results presented by NEEA
that the current method of measuring RMC may no longer produce test results that measure energy and water use during a representative average use cycle or period of use, particularly as the prevalence of clothes washers with complex electronic controls continues to increase in the market. On a clothes washer with basic controls e.g., in which the available spin settings are the same regardless of what wash/rinse temperature is selected, measuring RMC using only the Cold/Cold cycle would be expected to provide RMC
results that are equally representative of the other available wash/rinse temperatures, which as noted comprise the majority of consumer cycle
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selections. However, on a clothes washers in which the selection of wash/
rinse temperature affects which spin settings are available to be selected, measuring RMC using only the Cold/
Cold cycle may not necessarily provide results that measure energy and water use during a representative average use cycle or period of use i.e., across the range of wash/rinse temperature options selected by consumers, as represented by the temperature use factors.
The data presented by NEEA
illustrates how, on average, the spin portion of the cycle on the setting used to measure RMC i.e., the maximum spin setting on the Cold Wash/Cold Rinse temperature setting may not be representative of the spin characteristics and resulting RMC measurement of other temperature selections comprising the energy test cycle. Specifically, the data presented by NEEA suggest that the specific cycle configuration from which RMC is measured is programed with a longer spin time than other temperature settings available to the consumer, resulting in a significantly better RMC
measurement than would be experienced by the consumer on the majority of wash cycles performed.
The proposed update to the RMC
measurement would provide a more representative measure of RMC than the current test procedures because RMC
would be measured on all of the energy test cycles rather than only the Cold Wash/Cold Rinse cycles, which represent only 37 percent of consumer cycles and may not share the same RMC
performance as the other 63 percent of consumer cycles.43
Regarding Samsungs suggestion to require an additional RMC test at a different temperature setting that would provide the spin speed that is unavailable on the Cold setting, DOE
tentatively concludes that its proposed approach would provide a more representative measure of RMC by capturing RMC across all the temperature settings within the energy test cycle.
Because RMC directly affects drying energy, which is a large component in the calculation of IMEF, it is important that the RMC value be representative of all test cycles. DOEs proposal would make the RMC calculation consistent with how hot water energy, electrical energy, and water usage are calculated, i.e., by testing multiple load sizes and temperatures and averaging these values using LUFs and TUFs.
43 37% is the TUF for the Cold Wash/Cold Rinse temperature selection as specified in Table 4.1.1 of Appendix J2.

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