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Federal Register / Vol. 86, No. 146 / Tuesday, August 3, 2021 / Proposed Rules reported to DOE nor used in determining compliance with the applicable energy conservation standard. Id. Aside from an alternative approach of generally subtracting the energy use of the network functions from the standby mode energy
measurement, DOE did not propose a specific test method or calculation for disaggregating energy use from a connected function from standby energy use in those instances in which the connected function cannot be disabled per manufacturers instructions. DOE

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held a public meeting via a webinar to present the proposed amendments and provide stakeholders an opportunity to comment.6
DOE received comments in response to the November 2019 NOPR from the interested parties listed in Table I.1.

TABLE I.1WRITTEN COMMENTS RECEIVED IN RESPONSE TO NOVEMBER 2019 NOPR
Organizations
Reference in this SNOPR

Association of Home Appliance Manufacturers
California Investor Owned Utilities Pacific Gas and Electric Company, San Diego Gas and Electric, and Southern California Edison.
Natural Resources Defense Council, Appliance Standards Awareness Project, American Council for an Energy-Efficient Economy, National Consumer Law Center, Consumer Federation of America, Northwest Energy Efficiency Alliance.
Whirlpool Corporation

AHAM
CA IOUs

Trade Association.
Utility Association.

Joint Commenters

Efficiency Organizations.

Whirlpool

Manufacturer.

A parenthetical reference at the end of a comment quotation or paraphrase provides the location of the item in the public record.7 This SNOPR addresses only those comments relevant to the proposals laid out in this document; all other relevant comments will be addressed in a future test procedure final rule for microwave ovens.
II. Synopsis of the Notice of Proposed Rulemaking In this SNOPR, DOE revises its November 2019 NOPR proposal for testing microwave ovens with a connected function and specifies explicitly that if the manufacturers user manual does not provide a means for disabling the network function, the microwave oven is tested with the network function in the factory default setting or in the as-shipped condition.
DOE has tentatively determined that this approach to testing microwave ovens with a connected function would not impact the measured standby energy use of a microwave oven nor impact the cost of testing. Discussion of DOEs proposed actions are addressed in detail in section III of this SNOPR.

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III. Discussion A. Connected Functions As stated, the energy conservation standard for microwave ovens at 10 CFR
430.23i and the test procedure at Appendix I address standby mode and off mode energy use only. In establishing the standby energy test procedures for dishwashers, dehumidifiers, and conventional cooking products, DOE explicitly stated that it was not including the energy use associated with a connected function 6 The transcript of the public meeting is available at www.regulations.gov/document?D=EERE-2017BT-TP-0024-0011.

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based on the lack of data on their functionality, but that DOE may consider addressing such energy use as data becomes available. 77 FR 65942, 65954 Oct. 31, 2012. DOEs most recent test procedure for microwave ovens did not address network functionality. 81 FR 91418 Dec. 16, 2016.
Section 2.1.3 of Appendix I generally specifies that a microwave oven must be installed in accordance with paragraph 5.2 of IEC Standard 62301, Household electrical appliancesMeasurement of standby power, Edition 2.0, 201101
IEC Standard 62301 Second Edition, which states that the product must be prepared and setup in accordance with manufacturers instructions, and if no instructions for use are available, then factory or default settings must be used, or if such settings are not indicated, the product must be tested as supplied.
DOE recognizes that there may be some confusion as to how the direction in section 2.1.3 applies to connected functions. In order to minimize potential confusion, DOE proposed to include explicit instruction in Appendix I to disable a connected function, if present. 84 FR 61836, 61843.
AHAM and Whirlpool expressed support for disabling connected features during testing. AHAM, No. 15 at p. 4;
Whirlpool, No. 16 at p. 1 AHAM stated that connected functionalities, consumers usage, and understanding of such features are still developing, and that regulating such features could stifle innovation, increase regulatory burden, and prevent manufacturers from including them. AHAM, No. 15 at p. 4
AHAM further commented that connected features can add energy
saving benefits to consumers, increase energy efficiency of the grid, help utilities increase demand response, and facilitate renewable energy sources;
however, because connected products are still in early stages of development with limited market penetration, no meaningful data on consumer use is available yet. AHAM, No. 15 at p. 4
CA IOUs disagreed with excluding the energy use from connected functions, stating that connected functions could qualify under EPCAs definition of standby mode by remotely facilitating the activation or deactivation of functions, including active mode. CA
IOUs, No. 14 at p. 1 CA IOUs further suggested that DOE consider California Energy Commissions CECs low power mode data collection requirements, as well as low power requirements by the European Union EU and other jurisdictions, when investigating how to regulate connected functions power consumption. CA
IOUs, No. 14 at p. 2
The Joint Commenters opposed excluding the energy use from connected functions, stating that this approach would deny consumers accurate information about microwave ovens energy usage. Joint Commenters, No. 13 at p. 3 The Joint Commenters stated that a growing number of connected features are being added to products, and that their energy consumption can vary widely. The Joint Commenters cited Natural Resources Defense Council research data showing a wide variation in the standby mode energy consumption of connected functions on televisions, ranging from 1
watt W on some models to 20 W on others. Joint Commenters, No. 13 at pp.

7 The parenthetical reference provides a reference for information located in the docket of DOEs rulemaking for the test procedure for microwave ovens. Docket No. EERE2017BTTP0024,
which is maintained at www.regulations.gov. The references are arranged as follows: commenter name, comment docket ID number, page of that document.

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