Federal Register - October 8, 2021
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Source: Federal Register
Federal Register / Vol. 86, No. 193 / Friday, October 8, 2021 / Rules and Regulations
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proposed to move the rounding instructions from its previous location embedded within paragraph d1iiB
to the higher-level paragraph at paragraph d1ii.
AHAM and GEA supported DOEs proposal to specify the rounding requirements of all numeric reported values for clothes dryers. Additionally, AHAM and GEA requested that DOE
clarify the rounding requirements for scale weight measurements. AHAM
recommended the rounding of scale weight values to the nearest whole number digit, asserting the absence of such a specification in conjunction with the required minimum scale resolution may result in an unacceptable range of variation.43 These commenters stated that rounding to the nearest whole number for FMC is acceptable based on the current state of the clothes dryer test procedure, the measurement error, and laboratory capabilities. AHAM, No. 33
at pp. 910, 12; GEA, No. 37 at p. 2
GEA asserted that rounding to the nearest whole number for moisture content resolves the instrumentation resolution issue and is in keeping with ASTMs best practice guidance. GEA, No. 37 at p. 2 AHAM reported that its members have noted that there is inherent measurement variation compounded tolerance that can cause a theoretical FMC of 2 percent to be reported as high as 3 percent.44 AHAM
recommended a resolution for scales of at least 0.005 pounds with a maximum error of no greater than 0.1 percent of any measured value. AHAM also recommended specifying the same scale be used for bone-dry weight, IMC, and FMC measurements. AHAM suggested that this change would not add cost to the test as it expects laboratories already have instrumentation capable of this resolution. AHAM, No. 33 at pp. 910, 12 As discussed in section III.C.4 of this document, GEA supported all requests for tighter tolerances in the AHAM comments. GEA agreed that the 43 Section 2.4.1 of appendices D1 and D2 specify that the weighing scale for test cloth shall have a range of 0 to a maximum of 60 pounds with a resolution of at least 0.2 ounces, and a maximum error no greater than 0.3 percent of any measured value within the range of 3 to 15 pounds. AHAM
suggested that applying this allowable error to the weight of the bone-dry test cloth and test cloth after the test cycle, with a measured FMC of 2 percent, could in fact be as high as 2.4 percent or as low as 1.6 percent. AHAM suggested that rounding FMC
would eliminate the need to resolve issues with scale resolution that result in potentially misreporting FMC.
44 AHAM applied the maximum allowable measurement error of 0.3 percent to the bone-dry test cloth weight and final test cloth weight measurements. AHAM stated that a final FMC value of 2 percent could yield a measurement between 1.4
percent and 2.6 percent, given the allowable measurement error of 0.3 percent.
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current test procedure allows for tolerance stacking issues that introduce variability in the DOE verification process and reported that the suggested tolerances would not increase test burden or cost. GEA, No. 37 at p. 2
DOE proposed rounding requirements in the July 2019 NOPR, which implicate the weighing scale resolution,45 as noted by the comments received, in ensuring repeatable and reproducible test results.
DOE acknowledges that, in the absence of revised scale resolution requirements, hypothetically a variation as described by AHAM could occur. However, under current testing practice this is not occurring. Based on interactions with testing laboratories, DOE is aware that, in general, test laboratories are currently measuring test load weight using instrumentation with a scale resolution of 0.001 pounds and a maximum error of no greater than 0.1 the value suggested by AHAM percent of any measured value. This level of precision addresses the issue of compounded tolerance by effectively bounding a 2percent FMC measurement between a range of 1.82.2 percent rather than 1.4
2.6 percent. Accordingly, instead of addressing AHAM and GEAs concern through further rounding amendments, DOE is addressing the issue by codifying the current practice to ensure that the issue as described by commenters does not occur in the future. Also, rounding to the nearest whole number for FMC as suggested by these commenters would reduce the stringency of the requirement, given that an FMC of 2.4 percent could be rounded down to 2 percent, effectively raising the FMC requirement to be less than 2.5
percent as opposed to the prior requirement of 2 percent. For these reasons, DOE is not amending FMC
rounding requirements at this time.
Instead, DOE is amending the scale tolerance and maximum error requirements to align with the current capabilities of test laboratories, thereby codifying this level of precision and addressing the issues of compounding tolerance raised by commenters.
Specifically, DOE is amending the scale resolution requirements to be 0.001
pounds with a maximum error of no greater than 0.1 percent of any measured value in section 2.4.1 of both appendix D1 and appendix D2.
DOE received no comments pertaining to the other specific rounding requirements proposed in the July 2019
NOPR. DOE is adopting all proposed rounding requirement changes from the 45 Rounding requirements relate to the number of significant digits of the measured value, which are dictated by the resolution of the weighing scale.
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July 2019 NOPR in the newly added 10
CFR 429.21c.
5. Optional Usage of Appendix D1 or Appendix D2
As discussed, manufacturers must use either appendix D1 or appendix D2 to demonstrate compliance with the applicable energy conservation standards, and must use a single appendix for all representations, including certifications of compliance.46
The current efficiency standards are based on appendix D1. Appendix D1
tests timed drying cycles, and accounts for clothes dryers with automatic termination controls by applying a higher field use factor to units that have this feature. Appendix D2 tests normal automatic termination cycles.
NEEA, the California IOUs, NRDC, CEE, Energy Solutions, and Samsung recommended that DOE require testing under appendix D2 only, and delete appendix D1. NEEA commented that ENERGY STAR has now labeled 286
clothes dryer models from 18 different manufacturers with appendix D2 test procedure data, with an Environmental Protection Agency EPA estimated ENERGY STAR model market penetration of 35 percent. NEEA further commented that DOE reports that 269
unique models 43.5 percent in its CCMS database were tested according to appendix D2 and 350 unique models 56.5 percent were tested under appendix D1. The California IOUs, NEEA, and Samsung asserted that manufacturers have had sufficient time to adapt to appendix D2. These commenters suggested that the intention of having both appendix D1 and appendix D2 available for manufacturers was to ease the transition to the more representative automatic cycle termination test of appendix D2, and now that the appendix D2 test procedure has been adopted by ENERGY STAR and is commonly used, there no longer appears a need to test a model to appendix D1. NRDC, No. 35
at pp. 12; CEE, No. 27 at pp. 13;
California IOUs, No. 29 at pp. 1619;
Energy Solutions, Public Meeting Transcript, No. 23 at p. 56; Samsung, No. 36 at p. 2; NEEA, No. 38 at pp. 3
9, 18
The California IOUs, CEE, NRDC, and NEEA further asserted that appendix D1
artificially inflates the efficiency performance of units with poorly functioning automatic cycle termination features, since it applies a uniform field 46 ENERGY STAR certification requires testing using appendix D2. The ENERGY STAR clothes dryer specification can be found at www.energystar.gov/products/appliances/clothes_
dryers/partners.
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