Request for Information for Energy Conservation Standards for Residential Clothes Dryers, Docket # EERE-2014-BT-STD-0058

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1 May 11, 2015 Ms. Brenda Edwards U.S. Department of Energy Building Technologies Office Mailstop EE-5B Energy Conservation Standards for Residential Clothes Dryers EERE 2014 BT STD Independence Avenue SW Washington, DC Re: Request for Information for Energy Conservation Standards for Residential Clothes Dryers, Docket # EERE-2014-BT-STD-0058 Dear Ms. Edwards, The Edison Electric Institute (EEI) appreciates the opportunity to submit comments on the Request for Information (RFI) for Energy Conservation Standards for Residential Clothes Dryers, which was published by the Department of Energy (DOE or Department) at 80 Fed. Reg (Mar. 27, 2015). EEI is the association that represents all U.S. investor-owned electric companies. Our members provide electricity for 220 million Americans, operate in all 50 states and the District of Columbia, and directly employ more than 500,000 workers. With more than $85 billion in annual capital expenditures, the electric power industry is responsible for millions of additional jobs. Reliable, affordable, and sustainable electricity powers the economy and enhances the lives of all Americans. Many of our members are combination gas and electric companies, and provide services for both energy types. EEI strongly supports the Department s energy conservation standards program for consumer products and certain commercial and industrial equipment. We believe that the program has been one of the most successful energy efficiency efforts ever created due to its focus on setting standards that are technically feasible and economically justified for a majority of consumers. The program s success can be largely attributed to its historical reliance on setting standard levels that ensure that customers who purchase the product save money. These comments address concerns both with the potential rulemaking for new or amended standards for electric clothes dryers specifically and the overall rulemaking process for energy conservation standards. -1-

2 Concerns with Certain Aspects of the Request for Information Use of Gap Fills for Efficiency Levels Could Undermine Technical Feasibility of New or Amended Standards: DOE published a direct final rule amending the energy conservation standards for residential clothes dryers in See 76 Fed. Reg. 22,454 (Apr. 11, 2011). These amended standards were based on a new metric, the combined energy factor (CEF), which incorporates energy use in active move, standby mode and off mode. In the RFI, DOE presents interpolated CEF values. See Tables II.7, II.8, and II.9, 80 Fed. Reg. at 16, These interpolated CEF values are based on the results of Appendix D2 tests and the nominal values from the current DOE standard that are based on Appendix D1 tests. DOE states that it is necessary to use this interpolated data to address the large gap between efficiency levels. See id. It is not clear if these CEFs can be achieved by products that are available on the market, or whether more than one manufacturer produces products at the particular gap fill efficiency. The use of interpolated data to gap fill may undermine standards that are based on this data unless DOE can demonstrate, as required by the Energy Policy and Conservation Act, that these standards are technologically feasible. See 42 U.S.C. 6295(o)(3)(B). Lack of Analysis in the RFI for Standby Electricity Values in Table II.9 Could Undermine Customer Choice and Functionality. In Table II.9, entitled Efficiency Levels Under Consideration for Ventless Electric Combination Washer/ Dryers, Efficiency Level 3 is shown as EL Watt Standby and Efficiency Level 4 is shown as EL Watt Standby. See 80 Fed. Reg. at 16,315. The RFI provided no information about how the values chosen for standby electric usage were derived. It is not clear if DOE has tested or is planning to test current models of clothes dryers for their standby or off energy usage, but EEI would like to point out that going from a baseline of 2.0 Watts or 1.5 Watts down to 0.08 Watts could have a significant impact on product utility. The particular model that only uses 0.08 Watts in standby mode may only have one display along with limited functionality that significantly reduces product utility, compared with other clothes dryers with multiple displays and more functionality and therefore more utility for consumers. In the past, DOE has been careful not to limit customer utility. For example, in the April 2011 Technical Support Document (for the 2011 Direct Final Rule), DOE highlighted results from its tests of standby power in various clothes dryer technologies: Table summarizes the power consumption measurements in standby/off mode for each of the clothes dryers in the DOE test sample for which standby power could be measured. Review of this data, along with information on design options obtained during reverse-engineering activities, resulted in DOE proposing a level of 2.0 W for baseline power consumption in standby/off mode. This value is based on a maximum measured -2-

3 input power of 1.51 W for a unit with electronic controls, and thus which provides the consumer utility of a display (emphasis added). The TSD goes on to note that the model in the DOE test sample with this standby power consumption, however, was observed to incorporate a switching power supply, which DOE identified as a design option to reduce standby power consumption. In order to define the baseline level for an assumed clothes dryer that uses a conventional power supply, DOE increased the 1.51 W by the estimated change in standby power associated with changing from a conventional to switching power supply. DOE also measured standby power of approximately 0.7 W for other clothes dryers equipped with electronic controls and displays that were observed to differ only by having fewer available cycle settings. Because DOE does not intend to restrict consumer utility associated with the number of different cycles, the baseline was chosen to allow the maximum number of settings (emphasis added). As DOE potentially moves forward with new or amended standards for residential clothes dryers, DOE should consider the fact that a higher level of standby power be allowed for Efficiency Level 4, such as 1.4 Watts, will ensure that consumer utility is not restricted as manufacturers move to comply with new standards.. If DOE Decides to Regulate Electric Heat Pump Clothes Dryers, then DOE Should Have a Full Rulemaking that Follows the July 15, 1996 Process Improvement Rule. In 1995, Congress instructed DOE to cease the promulgation of new appliance efficiency standards until it developed a format and procedures that increased the transparency of the process and which afforded greater public participation. In response to Congress instructions, DOE published the so-called Process Improvement Rule in the Federal Register on July 15, 1996, and it has been used successfully since that time. -3-

4 If DOE determines to regulate electric heat pump clothes dryers or clothes dryers using microwave heating technology, they would be new products that have never been covered by DOE regulations before. Accordingly, any efficiency standards for these products should be subject to all of the procedures set forth in the Process Improvement Rule. Any process that skips over the essential intermediate steps such as the Proposed/Final Determination of Coverage, Framework Document, and the Advanced Notice of Proposed Rulemaking will have the effect of limiting public input, openness, and transparency. If DOE Decides to Regulate Electric Heat Pump Clothes Dryers, then Traditional Electric Resistance Clothes Dryers, Heat Pump Clothes Dryers, and Microwave Heating Clothes Dryers (if on the Market) Should be Different Product Classes with Separate Efficiency Requirements Electric resistance clothes dryers and heat pump clothes dryers are distinct products with different characteristics that require different product classes. Some of the key differences are: -Space requirements/constraints. Based on information found in installation and owner s manuals, heat pump clothes dryers require more space and clearance than electric resistance clothes dryers. Also, they may not be applicable for installation near other home appliances. Information was downloaded from the following web sites: /WED99HEDW/ When the dryer is fitted beneath a work surface, allow 30cm~50cm [11.8 to 19.7 inches] space at either side of the dryer and at the back of the dryer to allow air to exit the rear grille. This air flow is critical for condensation of water during the drying process. Below are the ventilation / closet requirements for one model of heat pump clothes dryer: -4-

5 Do not install the Heat pump dryer next to the high-temperature appliance like refrigerator, oven or stove etc. which can cause bad drying performance and duration, and adversely affect the proper functioning of the compressor. The Heat pump dryer gives the best work with the room temperature (23 ). Avoid installing the product around the place with the heat. The warm air venting from the rear side of the dryer must be well ventilated. If not, this can bring on problems. Therefore, in certain space-constrained residential applications, consumers will not be able to use heat pump clothes dryers, and should not be required to as a result of DOE regulations. -Maintenance issues. Heat pump clothes dryers have specific maintenance requirements due to its technology. Below are highlights from the manufacturer manuals: A heat pump dryer s condenser removes moisture from the air during the drying process, resulting in water that needs to be drained. If installation of a drain for the water is not feasible, a water tank will need to be emptied after each dryer load. Many manufacturers sell a device that allows a heat pump dryer to use the clothes washer drain to remove the water. Depending on the configuration of the dryer and the clothes washer drain, these devices may not work in some situations. The cooling fan screen is located on the back lower right of the dryer. Pull dryer away from wall and vacuum cooling fan screen with brush attachment. -5-

6 IMPORTANT: Clean cooling fan screen monthly, or as needed. A blocked screen will increase drying time. Vacuum the front ventilation grille 3-4 times a year to make sure there is no build up of lint or dirt that may cause improper air flow. -Operational / Energy Use considerations. The high CEF values for heat pump clothes dryers are based on the selection of the most energy efficient option available on these units. However, manufacturers publish the following statements: Use Up To 53% Less Energy Every Time You Dry* *When used with the setting Low Temp Dry + with the EcoHybrid option based on EPA statistics for typical dryer energy consumption (emphasis added) Eco is the default option for all cycles, which allows you to increase your energy savings by using a lower heat level. This will increase dry times. NOTE: Energy savings may vary across loads and cycles. (emphasis added) The heat pump dryer s heating phase is longer than in traditional dryers. If possible, do not open the dryer door during the process as heat can escape from the drum and can make longer drying times. Heat pump clothes dryers always offer the option of traditional drying, typically known as the speed option. It should be noted that the use of the most efficient option increases drying time significantly, as shown in the following charts: -6-

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8 There are consumers that may not want to wait over 3 hours for their clothes to dry, and will likely choose the speed setting on their clothes dryer. Assuming that all consumers will always use the eco setting will overstate the energy savings associated with heat pump clothes dryers. Any potential required CEF for heat pump clothes dryers should consider that a significant percentage of clothes drying will be in the speed or non-heat pump drying mode. In addition, for certain electric utility smart grid and demand response programs, electric resistance clothes dryers will offer more operational flexibility and more flexible responses. Under certain programs, clothes dryers may be required to switch on or off their heating elements within a matter of minutes or seconds. Heat pump clothes dryers, since they contain compressors, would not be appropriate for such programs, to prevent compressor short cycling that could damage the compressor. Therefore, if DOE decides to regulate electric heat pump clothes dryers, then DOE should create a separate product class for these products, for the reasons discussed in this letter. Customer Choice Must Be Preserved--Appliance Efficiency Standards Should Not Eliminate Entire Classes of Appliances EEI would like to reiterate the position of many electric utility CEO s in a letter written to then Energy Secretary Chu in October 2010: Appliances that have unique characteristics regarding their consumer applications should always be available for purchase. For example, electric resistance water heaters and non-condensing gas water heaters should be a separate class from electric heat pump water heaters and condensing gas water heaters due to issues such as space limitations, air circulation needs, noise factors, installation costs, safety and consumer comfort. -8-

9 Thank you for your review and consideration of our comments. Please contact Steve Rosenstock ( , if you have any questions about EEI s comments. Respectfully submitted, Steve Rosenstock, P.E. Senior Manager, Energy Solutions cc: Rick Tempchin, EEI Emily Fisher, Esq., EEI -9-