Federal Register - September 1, 2021
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Source: Federal Register
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Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules
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average-capacity RCW,86 and the maximum allowable usage of 60 test cycles per cloth,87 DOE estimates a total material cost of $5.35 per wash cycle on average across all RCWs on the market.
Using these material costs, labor rates and time estimates, DOE estimates that the reduction in burden of a single test cycle on an RCW would provide $46.99
in costs savings 88 for tests conducted at an in-house test facility. Based on discussions with manufacturers over the course of multiple rulemakings, DOE
understands that the majority of manufacturer testing is conducted at inhouse test facilities.
Based on an average CCW capacity of 3.17 ft3,89 the load sizes associated with testing an average-capacity CCW,90 and the maximum allowable usage of 60 test cycles per cloth, DOE estimates a total material cost of $4.36 per wash cycle on average across all CCWs on the market.
Using these material costs, labor rates and time estimates, DOE estimates that the reduction in burden of a single test cycle on a CCW would provide $35.59
in costs savings 91 for tests conducted at an in-house test facility.
Based on these estimates, DOE has tentatively determined that the use of proposed new Appendix J would result in a total burden reduction of 7.4 cycles per RCW on average, which results in an average saving of $348 per basic model of RCW.92 For CCWs, use of proposed new Appendix J would result in a total burden reduction of 4.3 cycles per CCW
on average, which results in an average saving of $153 per basic model of CCW.93
Based on these estimates, DOE has tentatively determined that the 86 The load sizes associated with a 4.14 ft3 clothes washer are 3.0 lb minimum, 10.0 lb average, and 17.0 lb maximum under Appendix J2; and 6.1 lb small and 13.65 lb large under proposed Appendix J, resulting in an average load size of 10.0
lb under Appendix J2 or 9.9 lb under Appendix J.
For the purpose of the calculations in this analysis, DOE used 10.0 lb to represent the average load size.
87 Section 2.7.1 of Appendix J2 specifies that each energy test cloth must not be used for more than 60 test runs after preconditioning.
88 1 $41.64 + $5.35 = $46.99.
89 DOE calculated the average CCW capacity based on the average capacity of the representative sample of CCWs presented in chapter 5 of the technical support document accompanying the December 2014 Final Rule. Available at www.regulations.gov/document/EERE-2012-BTSTD-0020-0036.
90 The load sizes associated with a 3.17 ft3 clothes washer are 3.0 lb minimum, 7.95 lb average, and 12.9 lb maximum under Appendix J2; and 5.2 lb small and 10.55 lb large under proposed Appendix J, resulting in an average load size of 7.95
lb under Appendix J2 or 7.9 lb under Appendix J.
For the purpose of the calculations in this analysis, DOE used 7.95 lb to represent the average load size.
91 0.75 $41.64 + $4.36 = $35.59.
92 7.4 $46.99 = $348.
93 4.3 $35.59 = $153.
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proposed new test procedure at Appendix J would not be unduly burdensome for manufacturers to conduct.
DOE requests comment on any aspect of the estimated testing costs and savings associated with DOEs proposed test procedures.
2. Harmonization With Industry Standards DOEs established practice is to adopt relevant industry standards as DOE test procedures unless such methodology would be unduly burdensome to conduct or would not produce test results that reflect the energy efficiency, energy use, water use as specified in EPCA or estimated operating costs of that product during a representative average use cycle or period of use.
Section 8c of Appendix A of 10 CFR
part 430 subpart C; 10 CFR 431.4. In cases where the industry standard does not meet EPCA statutory criteria for test procedures, DOE will make modifications through the rulemaking process to these standards as the DOE
test procedures.
The test procedures for clothes washers at the proposed new Appendix J and Appendix J2 and Appendix J3
incorporate by reference certain provisions of IEC Standard 62301 that provide test conditions, testing equipment, and methods for measuring standby mode and off mode power consumption. These appendices also reference AATCC test methods for qualifying new batches of test cloth, and AHAM Standard Test Detergent Formula 3 for preconditioning new test cloths. DOE is not aware of any existing industry test procedures for clothes washers that measure energy and water efficiency.
AHAM commented on the May 2020
RFI that it is about to begin development of its own clothes washer energy test procedure based on Appendix J2, which will address many of the issues DOE raised in the May 2020 RFI. AHAM, No. 5 at p. 5 For example, AHAM stated that it plans to investigate methods of reducing test burden, including through review of relevant customer usage data. AHAM, No. 5 at p. 4 AHAM suggested that DOE
eventually incorporate AHAMs test procedure by reference. AHAM, No. 5
at p. 5 AHAM invited DOE, as well as other entities that are able to contribute technical resources to the effort, to participate in the task force. Id.
The CA IOUs opposed the adoption of industry test procedures without modification without DOE conducting an independent assessment of representativeness in a public
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rulemaking to allow adequate stakeholder discussion and review. CA
IOUs, No. 8 at p. 16
DOE is aware of two clothes washer test procedures established by industry:
AHAM HLW12013 and IEC 60456.
AHAMs existing clothes washer procedure, AHAM HLW12013, does not include a procedure for measuring energy and water. IEC 60456 includes tests for water and energy use, water extraction i.e., RMC, washing performance, rinsing performance, and wool shrinkage. DOE notes several key differences between IEC 60456 and DOEs test procedure, including:
1 IEC 60456 uses manufacturerdeclared capacity or, in the absence of a declared capacity, specifies two alternative capacity measurement procedures: A table tennis ball method in which the drum is filled with table tennis balls and a water fill method, which more closely resembles DOEs capacity measurement method.
However, the water fill method for toploading clothes washers corresponds to Fill Level 1, as discussed in section III.D.6.c of this document, in contrast to DOEs currently specified Fill Level 2.
2 IEC 60456 defines two types of load materials that can be used: A 100percent cotton load, consisting of sheets, pillowcases, and towels; or a synthetics/
blends load 65-percent polyester, 35percent cotton, consistent of mens shirt and pillowcases. IEC 60456
requires a distribution in age i.e., number of cycles that have been performed for each different item type comprising the load.
3 The procedure for determining water and energy consumption section 8.6 of IEC 60456 specifies that the test load shall be subjected to performance testing, which requires operating a reference clothes washer in parallel with the unit under test; using a test load that includes stain strips used to evaluate cleaning performance;
and using detergent as specified.
4 IEC 60456 does not define the Normal cycle or energy test cycle;
rather, the procedures in IEC 60456 are generic and can be applied to any wash program or cycle selections defined by the tester.
DOE tentatively concludes that IEC
60456 does not meet EPCA statutory criteria, in that IEC 60456 would be unduly burdensome to conduct and would not produce test results that reflect the energy efficiency, energy use, water use, or estimated operating costs of a clothes washer during a representative average use cycle or period of use for a U.S. consumer.
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