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Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules
AHAM stated that DOE does not need to change the energy efficiency or water efficiency metrics. AHAM, No. 5 at p.
16
The CA IOUs recommended changing IWF and IMEF to eliminate their relationship to capacity. The CA IOUs stated that by normalizing with the capacity of a clothes washer, the current metrics create a built-in bias towards larger-capacity machines, as the minimumand average-sized test loads are not purely scaled with the clothes washers capacity. The CA IOUS stated that this leads to larger-capacity clothes washers washing a smaller fraction of clothing compared to their capacity. The CA IOUs commented that in order to remove this bias, IMEF and IWF should be normalized with the weightedaverage load size of clothing washed e.g., IMEF would be measured in lb/
kWh/cycle instead of ft3/kWh/cycle.
CA IOUs, No. 8 at p. 5 The CA IOUs stated that this amendment would create a more representative performance metric of an average clothes washer use cycle and would also improve alignment with the clothes dryer performance metric. Id.
The Joint Commenters encouraged DOE to consider basing efficiency metrics on pounds of clothes washed instead of capacity of the clothes washer. According to the Joint Commenters, basing efficiency metrics on clothes washer capacity creates a bias towards large-capacity clothes washers, since weighted-average load size is much greater for large-capacity clothes washers than it is for smallcapacity clothes washers. The Joint Commenters encouraged DOE to instead consider alternative efficiency metrics based on the LUF-weighted-average load size for a given clothes washer capacity.
Joint Commenters, No. 10 at p. 5
NEEA commented that the current DOE test procedure allows largercapacity clothes washers to use more energy and water per pound of textiles washed than smaller-capacity clothes washers with the same IMEF ratings.
NEEA has also observed that IMEF
generally increases with capacity in the most recent models to come into the market. NEEA stated that due to the increase in average clothes washer capacity from 3.5 ft3 to 4.4 ft3, this issue is becoming more prevalent. NEEA, No.
12 at pp. 1317 NEEA conducted testing under conditions that it characterized as more realistic than DOE
test conditions and summarized the results as demonstrating that on a lb/
kWh basis, larger-capacity clothes washers perform less efficiently than
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smaller-capacity clothes washers.51
Based on these results, NEEA concluded that large-capacity clothes washers may use more energy than small-capacity clothes washers when operating with typical load sizes and wash temperatures. Id. NEEA recommended that, to better address the efficiency of the largest-capacity clothes washers in the market, DOE should consider adopting an alternative energy efficiency metric such as pounds of textile per kWh, which would be based on the LUF-weighted load size, and the LUF-weighted and TUF-weighted energy use per cycle. NEEA also recommended that DOE consider developing an energy conservation standard that is a function of capacity, so that larger-capacity clothes washers would need to meet higher IMEF and lower IWF levels than smaller clothes washers. Id. NEEA noted that this would be similar to the way standards for refrigerators, room air conditioners, and water heaters are a function of adjusted volume, cooling capacity, and storage volume, respectively. NEEA
calculated that making these changes could result in 12 quads of energy savings over a 30-year period associated with increased efficiency of largecapacity clothes washers. Id.
As noted throughout the discussion previously, under Appendix J2, energy use the denominator of the IMEF and MEF equations scales with weightedaverage load size, whereas capacity the numerator of the IMEF and MEF
equations scales with maximum load size. This provides an inherent numerical advantage to large-capacity clothes washers that is disproportionate to the efficiency advantage that can be achieved through economies of scale associated with washing larger loads.
This advantage means that a largercapacity clothes washer consumes more energy to wash a pound of clothes than a smaller-capacity clothes washer with the same IMEF rating. This relationship applies similarly to water efficiency through the IWF equation. As noted in the comments summarized previously, this disproportionate benefit increases as average clothes washer capacity increases over time. To avoid providing bias for large-capacity clothes washers, DOE is proposing to change the energy and water efficiency metrics in the proposed new Appendix J by replacing the capacity term with the weightedaverage load size, in pounds. Under this proposed change, energy and water use would scale proportionally with 51 NEEA stated that that it considers these data to be preliminary and that additional testing would provide more clarity.

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weighted-average load size in the IMEF, MEF, and IWF formulas and thus eliminate the efficiency bias currently provided to large-capacity clothes washers.
EPCA defines energy efficiency as the ratio of the useful output of services from a consumer product to the energy use of such product. 42 U.S.C.
62915; 42 U.S.C. 63113 In the current efficiency metrics, clothes washer capacity is used to represent the measure of useful output. DOE has tentatively determined that clothing load size i.e., the weight of clothes cleaned, expressed as the weightedaverage load size, may better represent the useful output of a clothes washer.
Were DOE to finalize the proposed metric change, changes to the energy conservation standards would be addressed in an energy conservation standards rulemaking.
DOE requests comment on its proposal to replace the capacity term with weighted-average load size in the energy efficiency metrics and the water efficiency metric in the proposed new Appendix J.
In addition, DOE is proposing to rename the efficiency metrics to avoid any confusion between the proposed new metrics and the existing metrics.
DOE is proposing to designate energy efficiency ratio EER as the energy efficiency metric for RCWs replacing IMEF; active-mode energy efficiency ratio AEER as the energy efficiency metric for CCWs replacing MEFJ2; and water efficiency ratio WER as the water efficiency metric for both RCWs and CCWs replacing IWF. As proposed, EER would be calculated as the quotient of the weighted-average load size in lb divided by the total clothes washer energy consumption in kWh per cycle; and AEER would be calculated as the quotient of the weighted-average load size in lb divided by the total clothes washer energy consumption in kWh per cycle not including the combined low-power mode energy consumption. Section III.E.2 of this document describes how WER would be calculated.
DOE is also proposing to establish provisions in 10 CFR 430.23j to specify the procedure for determining EER and WER for RCWs, and in 10 CFR 431.154
to specify the procedure for determining AEER and WER for CCWs.
DOE requests comment on its proposed names for the proposed new efficiency metrics: Energy efficiency ratio EER, active-mode energy efficiency ratio AEER, and water efficiency ratio WER.

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