The Department of Energy has recently granted several requests for waivers establishing an alternative test procedure for certain large-capacity residential clothes washer models. We have now received follow-up questions about the proper application of these waivers. Since these questions affect multiple manufacturers and the public, we have decided the proper course is to invite interested parties to submit views on the proper application of these waivers to existing clothes washer models and units by Tuesday, December 7th.
The Department’s current test procedure for residential clothes washers includes a table indicating the test load size to be used based on the size of the clothes washer container. See 10 C.F.R. Pt. 430, Subpt. B, App. J1, Table 5.1. That table, however, does not specify the test load size for clothes washers with capacities larger than 3.8 cubic feet.
Several clothes washer manufacturers have petitioned for a waiver from DOE’s test procedure for clothes washer models with clothes container capacities in excess of 3.8 cubic feet. In 2006, the Department first granted an interim waiver to Whirlpool for certain large-capacity clothes washers. More recently, the Department granted interim waivers for certain large-capacity models to Samsung, General Electric, and LG as well as a permanent waiver to Whirlpool. In each case, the Department set forth an alternative test procedure to be used for the models covered by the waiver – namely, an alternative table with extrapolated test load values for capacities up to 6 cubic feet. As DOE explained in granting LG’s interim waiver request, “testing a basic model with a capacity larger than 3.8 cubic feet using the current procedure could evaluate the basic model in a manner so unrepresentative of its true energy consumption as to provide materially inaccurate comparative data.”
The Department has now been asked at what point companies who have been granted a waiver are required to re-test, re-rate, and recertify models covered by the waiver using the alternative test procedure. We have also been asked how these companies should apply the waivers to already manufactured units at various points along the distribution chain. Unlike most test procedure waivers, which are issued to parties who simply cannot use the existing test procedure, this group of waivers implicates multiple manufacturers who, prior to receiving a waiver, have used either the current or an alternative test procedure when testing their existing large-capacity clothes washer models. In addition, there may be other manufacturers who have not yet sought a waiver for large-capacity clothes washer models and may or may not do so – creating concerns about consistency and equity.
In light of these unique circumstances, the Department seeks to implement the waivers in a way that leads to representative efficiency ratings that are comparable across manufacturers and models, while mitigating, to the extent possible, transition costs and marketplace disparities for those who have sought and obtained waivers from the Department. Thus, to inform the decision-making process and to help the Department reach an appropriate and equitable resolution, we are inviting interested parties to answer the questions above (and provide any other views) on the proper implementation of these waivers for large-capacity clothes washers.
We request that interested parties submit their views via email to GC_comments@hq.doe.gov. All submissions, as well as the Department’s ultimate conclusions, will be made public.