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Federal Register / Vol. 86, No. 194 / Tuesday, October 12, 2021 / Rules and Regulations initiated, and manually terminated, set at their lowest energy usage positions when adjustment is provided.
In the December 2019 NOPR, DOE
acknowledged that some consumers will use connected functions if offered on a product; however, connected products are in the early stages of development and meaningful data on consumer use for connected functions or display screens are currently unavailable. 84 FR
70842, 70856. DOE stated that it does not want to limit innovation or hinder manufacturers from offering these functions to consumers or impede the ability to provide potential utility that these functions may offer. Id.
Additionally, DOE noted that connected functions vary by model, and that further specifying a test to reflect the energy consumption of the various connected functions would likely introduce test variability and increase test burden. Id. For these reasons, DOE
did not propose any amendments to the existing test procedure approach to address connected functions. Id.
In the December 2019 NOPR, DOE did propose to remove sections 2.10 of Appendix A and 2.8 of Appendix B, which state that products that have a communication module for demand response functions that is located within the cabinet shall be tested with the communication module in the configuration set at the factory just before shipping, which would result in such communication modules being set to their lowest energy usage positions off. 84 FR 70842, 7085670857. This proposal was intended to maintain consistency between the specifications for demand response functions and other features not required for maintaining compartment temperatures per AHAM HRF12016. Id.
In response to the December 2019
NOPR, the Joint Commenters encouraged DOE to investigate the energy consumption of display screens and connected functions and how consumers use these functions so that they can be captured in the test procedure in the future. The Joint Commenters stated that DOE should maintain the existing approach of testing demand-response function communication modules in the asshipped configuration and adopt a similar approach for other consumeraccessible functions. The Joint Commenters claimed that with the amendment proposed in the December 2019 NOPR, manufacturers may ship products with demand-response function communication modules in a position other than off, and yet that energy use would not be captured in the products rating. The Joint Commenters
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stated that consumers could unknowingly end up paying more to operate the product without receiving any benefit from the added functionality e.g., if the consumers electric utility does not offer any demand response program. The Joint Commenters added that by encouraging but not requiring manufacturers to ship modules in the off position, the existing approach does not impede innovation, and that the same would apply for other consumeraccessible functions such as display screens. Joint Commenters, No. 22, p.
23
NEEA recommended that DOE
include network power consumption and connected function modes in the test procedures by connecting the appliance to a network for testing as recommended for normal use by the supplier where such smart functions are provided. According to NEEA, network connected devices with display panels are increasing in usage. Data presented by NEEA showed that 75% of the ENERGY STAR refrigerator sales from 2015 to 2019 are bottom-mount and 9.9% of those have connected capability. NEEA stated that connected appliances offer energy savings opportunities and opportunities for grid interaction to reduce the demand on the grid. NEEA, No. 26, p. 6
The CA IOUs opposed DOEs proposal to set connected functionality to the off position during testing and instead recommended a method of incorporating the energy usage into the test procedures because the active-mode power mode of smart functions may meaningfully add to the units overall electrical load. The CA IOUs did not agree that that measurement and disclosure of smart devices could limit innovation. The CA IOUs referred to BSHs comment on the June 2017 RFI 32
as evidence that a method could be developed with low test burden and thus encouraged DOE to reconsider incorporating a method to measure networked functionality and, at the very 32 In response to the June 2017 RFI, BSH
commented that display screens consume energy in normal use and that energy is not captured during the existing test procedure. BSH supported including some portion of the energy consumed by these features in the energy test, if they do not add burden to the test procedure. BSH noted that Appendix A refers to products with demandresponse capability and recommends that the test procedure instead refer to all connected products.
BSH stated that connected communication modules consume a small amount of energy and can be easily captured during the energy test. BSH
recommended testing with the communication module in the on position but not connected, consistent with the European energy test. BSH, No.
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least, test products in their as-shipped mode. CA IOUs, No. 23, p. 3
CEC supported the comments from the CA IOUs and recommended that standby mode and off mode of connected devices be measured, stating that such measurements are required under EPCA. According to the CA IOUs, DOE provided insufficient rationale excluding the measurement of energy consumption associated with connected functions in the test procedures. CEC, No. 20, p. 4 The CA IOUs supported alignment with the California Energy Commissions Low Power Modes Roadmap, based on IEC Standard 62301:2011, which identifies data collection procedures for standby power draw of several products. The CA IOUs recommended that DOE should: 1
Collect data on power draw of smart functions in all operational modes, 2
isolate the power required for network connectivity in various covered smart appliances, 3 incorporate standby and off-mode energy usage into the standard metrics. The CA IOUs predicted that growth will not only occur among smart device functions for higher end products where they currently exist, but across the market, pushed in part by California Senate Bill No. 49: Clean Power, Smart Power. CA IOUs, No. 23, pp. 34
At the December 2019 NOPR Public Meeting, NRDC stated that testing connected functions in the off positionand assuming their component energy consumption is 0
kWh/yris not representative of actual consumer usage, and thus opposed DOEs proposed amendment. NRDC, Public Meeting Transcript, No. 11, pp.
78 & 89
AHAM commented that it is too soon to address display screens and connected functions given the currently limited market penetration. AHAM
supported DOEs proposal to have these functions tested in their lowest energy use positions to avoid stifling innovation and reduce cumulative regulatory burden. AHAM also suggested that DOE could incorporate by reference HRF12019, which requires that devices with communication modules be tested with the device on but not connected to any communication network. AHAM
asserted that this approach would not impact measured energy use. AHAM, No. 18, pp. 1011 Whirlpool agreed that the test procedure should not be amended for features like door-in-door designs, display screens, and connected features at this time. Whirlpool, No. 19, p. 1 Both Whirlpool and Sub Zero supported AHAMs recommendation to incorporate by reference HRF12019.

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