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Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules hot water energy consumption using gas-heated or oil-heated water, for product labeling requirements.63 This equation includes a multiplication factor e, representing the nominal gas or oil water heater efficiency, defined as 0.75. These water-heating energy equations estimate the energy required by the household water heater to heat the hot water used by the clothes washer. Per-cycle hot water energy consumption is one of the four energy components in the IMEF metric.
In the May 2020 RFI, DOE requested input on whether any updates were warranted to the water heater efficiency values implied in section 4.1.2 and provided in section 4.1.4 of Appendix J2. 85 FR 31065, 31079.
The CA IOUs recommended that DOE
update the gas and oil efficiency factor in section 4.1.4 of Appendix J2, and include a new efficiency factor for electric water heaters in the rest of section 4.1 of Appendix J2, to account for heat losses in the hot water distribution system. CA IOUs, No. 8 at p. 15
The CA IOUs did not provide specific recommendations or data that could be used to justify updating the gas and oil efficiency factor, or for a new efficiency factor to account for any heat losses in the hot water distribution system. DOE
is unaware of any nationally representative data regarding heat losses in residential water distribution systems.
In the absence of such data, DOE is not proposing any changes to the assumed water heater efficiency factors in the clothes washer test procedure.
DOE requests comment on maintaining the current water heater efficiency assumptions.

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7. Commercial Clothes Washer Usage As mentioned in section I of this document, CCWs are included in the list of covered equipment for which DOE
is authorized to establish and amend energy conservation standards and test procedures. 42 U.S.C. 63111H
EPCA requires the test procedures for CCWs to be the same as those established for RCWs. 42 U.S.C.
6314a8
The CA IOUs recommended that DOE
include CCW use patterns when determining the number of average use cycles, annual loads of laundry, and LUF values. CA IOUs, No. 8 at pp. 8
9, 1214 The CA IOUs stated that according to Table HC3.4 of the 2015
RECS data, 17.6 percent of respondents 63 The Federal Trade Commissions EnergyGuide label for RCWs includes the estimated annual operating cost using natural gas water heating.

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rely on CCWs to wash their clothing.
The CA IOUs commented that, due to the exclusion of CCW usage data, DOEs analysis undercounts the average annual use cycles. Id. The CA IOUs cited an ENERGY STAR case study at an apartment building in Maryland that reported 1,138 cycles per CCW per year, with each CCW servicing more than 19
apartments.64 According to the CA
IOUs, this implies that the RECS annual cycle use analysis provided by DOE in the September 2010 NOPR represents an undercounting of the average annual use cycles due to a lack of representation of CCWs. Id.
The CA IOUs also suggested that DOE
develop a DEF for CCWs that is different than the DEF for RCWs. CA IOUs, No.
8 at p. 11 The CA IOUs recommended that DOE calculate this DEF by investigating any changes to market share distribution of consumer clothes dryers since the 2011 clothes dryer standards rulemaking, and by incorporating energy use and market share implications for CCWs. Id.
NEEA, the CA IOUs, and the Joint Commenters recommended that DOE
require standby/low power mode testing for CCWs, and that low-power mode energy consumption should be incorporated into the energy efficiency metric for CCWs. NEEA, No. 12 at p.
18; Joint Commenters, No. 10 at p. 2; CA
IOUs, No. 8 at p. 13 NEEA reported data from its test program that showed CCWs have an average standby power of 6.4 watts compared to 0.5 watts for RCWs. NEEA stated that although CCWs have more active wash cycles than RCWs, CCWs still spend a significant amount of time in low power mode.
According to NEEA, low-power mode energy use in CCWs can be reduced cost-effectively in a variety of ways.
NEEA, No. 12 at p. 18 The CA IOUs further commented that transitioning CCWs efficiency metric to IMEF could align with the California Energy Commissions Low Power Modes Roadmap.65 CA IOUs, No. 8 at p. 13
NEEAs standby power data for CCWs falls within with the range of test results described by DOE in the December 2014
Final Rule. As part of its market assessment and engineering analysis for the December 2014 Final Rule, DOE
performed an in-depth evaluation of the standby and off mode power characteristics of a representative 64 The apartment building included 14 clothes washers for 272 apartments. www.energystar.gov/ia/
products/appliances/clotheswash/508_
ColesvilleTowers.pdf.
65 Additional information can be found at the California Energy Commissions Low-Power Mode docket: efiling.energy.ca.gov/Lists/
DocketLog.aspx?docketnumber=17-AAER-12.

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sample of CCWs spanning a wide range of display types, payment systems, and communication features. 79 FR 74492, 74501. DOE observed that manufacturers offer a variety of display and payment functionalities that can be selected independently from the basic model. The standby power associated with these different display and payment functionalities varies from 0.88
to 11.77 watts. Id. The lowest standby power levels are associated with models having no vend price display and no coin or card payment options often referred to as push-to-start models.
These models are typically used in small multi-family housing facilities offering free laundry, or in other commercial applications not requiring fare payment. Such models are not suitable for coin-operated laundry or most other multi-family housing facilities. Id. The highest standby power levels are associated with models having a digital vend price display, coin or debit card payment system, and advanced features such as dynamic or cycle-based pricing controls, built-in logging capabilities, and remote auditing features. These models are typically used in coin-operated laundries located in competitive markets. Id.
In the December 2014 Final Rule, DOE determined not to include lowpower mode energy in the CCW energy efficiency metric. Id. DOE determined that promulgating an amended standard that included low-power mode energy could enable backsliding and that the IMEF metric would not provide a useful means for differentiating the active mode characteristics of different CCW
models. Id. Because of the wide variations in standby power, CCWs with significantly different active mode ratings could have similar IMEF ratings depending on their control panel functionalities, and vice versa. This would diminish the usefulness of the IMEF metric as a means for differentiating the active mode characteristics of different CCW models.
Id.
Moreover, as noted, EPCA requires the test procedures for CCWs to be the same as those established for RCWs. 42
U.S.C. 6314a8 Creating load, temperature, or dryer usage factors specific to CCWs within the RCW test procedure would effectively create a separate test procedure for CCWs because the LUF, TUF, DUF, and DEF
values are integral to the calculations of per-cycle energy and water use, on which the regulated metrics for RCWs and CCWs are based.
Regarding annual use cycles, DOE
notes that in calculating national energy
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