Energy Conservation Program for Consumer Products: Notice of Petition for Waiver of Whirlpool Corporation From the Department of Energy Residential Dishwasher Test Procedure, and Grant of Interim Waiver, 41167-41171 [2010-17295]
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Federal Register / Vol. 75, No. 135 / Thursday, July 15, 2010 / Notices
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[FR Doc. 2010–17285 Filed 7–14–10; 8:45 am]
BILLING CODE 6450–01–P
DEPARTMENT OF ENERGY
Office of Energy Efficiency and
Renewable Energy
[Case No. DW–004]
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Energy Conservation Program for
Consumer Products: Notice of Petition
for Waiver of Whirlpool Corporation
From the Department of Energy
Residential Dishwasher Test
Procedure, and Grant of Interim Waiver
AGENCY: Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Notice of petition for waiver,
notice of grant of interim waiver, and
request for comments.
SUMMARY: This notice announces receipt
of and publishes the Whirlpool
Corporation (Whirlpool) petition for
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waiver (hereafter, ‘‘petition’’) from
specified portions of the U.S.
Department of Energy (DOE) test
procedure for determining the energy
consumption of dishwashers. Today’s
notice also grants an interim waiver of
the dishwasher test procedure. Through
this notice, DOE also solicits comments
with respect to the Whirlpool petition.
DATES: DOE will accept comments, data,
and information with respect to the
Whirlpool petition until, but no later
than August 16, 2010.
ADDRESSES: You may submit comments,
identified by case number DW–004, by
any of the following methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• E-mail:
AS_Waiver_Requests@ee.doe.gov.
Include either the case number [Case
No. DW–004], and/or ‘‘Whirlpool
Petition’’ in the subject line of the
message.
• Mail: Ms. Brenda Edwards, U.S.
Department of Energy, Building
Technologies Program, Mailstop EE–2J/
1000 Independence Avenue, SW.,
Washington, DC 20585–0121.
Telephone: (202) 586–2945. Please
submit one signed original paper copy.
• Hand Delivery/Courier: Ms. Brenda
Edwards, U.S. Department of Energy,
Building Technologies Program, 950
L’Enfant Plaza, SW., Suite 600,
Washington, DC 20024. Please submit
one signed original paper copy.
Instructions: All submissions received
must include the agency name and case
number for this proceeding. Submit
electronic comments in WordPerfect,
Microsoft Word, Portable Document
Format (PDF), or text (American
Standard Code for Information
Interchange (ASCII)) file format and
avoid the use of special characters or
any form of encryption. Wherever
possible, include the electronic
signature of the author. DOE does not
accept telefacsimiles (faxes).
Any person submitting written
comments must also send a copy to the
petitioner, pursuant to 10 CFR
431.401(d). The contact information for
the petitioner is: Mr. J.B. Hoyt, Director,
Government Relations, Whirlpool
Corporation, 2000 M 63, Mail Drop
3005, Benton Harbor, MI 49022, Phone:
(269) 923–4647, E-mail:
j.b.hoyt@whirlpool.com.
According to 10 CFR 1004.11, any
person submitting information that he
or she believes to be confidential and
exempt by law from public disclosure
should submit two copies to DOE: One
copy of the document including all the
information believed to be confidential,
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and one copy of the document with the
information believed to be confidential
deleted. DOE will make its own
determination about the confidential
status of the information and treat it
according to its determination.
Docket: For access to the docket to
review the background documents
relevant to this matter, you may visit the
U.S. Department of Energy, 950 L’Enfant
Plaza, SW., (Resource Room of the
Building Technologies Program),
Washington, DC, 20024; (202) 586–2945,
between 9 a.m. and 4 p.m., Monday
through Friday, except Federal holidays.
Available documents include the
following items: (1) This notice; (2)
public comments received; (3) the
petition for waiver and application for
interim waiver; and (4) prior DOE
waivers and rulemakings regarding
similar dishwasher products. Please call
Ms. Brenda Edwards at the above
telephone number for additional
information regarding visiting the
Resource Room.
FOR FURTHER INFORMATION CONTACT: Dr.
Michael G. Raymond, U.S. Department
of Energy, Building Technologies
Program, Mail Stop EE–2J, Forrestal
Building, 1000 Independence Avenue,
SW., Washington, DC 20585–0121.
Telephone: (202) 586–9611. E-mail:
Michael.Raymond@ee.doe.gov.
Ms. Elizabeth Kohl, U.S. Department
of Energy, Office of the General Counsel,
Mail Stop GC–71, Forrestal Building,
1000 Independence Avenue, SW.,
Washington, DC 20585–0103.
Telephone: (202) 586–7796. E-mail:
Elizabeth.Kohl@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
I. Background and Authority
Title III of the Energy Policy and
Conservation Act (‘‘EPCA’’) sets forth a
variety of provisions concerning energy
efficiency. Part A of Title III provides for
the ‘‘Energy Conservation Program for
Consumer Products Other Than
Automobiles.’’ (42 U.S.C. 6291–6309)
Part A includes definitions, test
procedures, labeling provisions, energy
conservation standards, and the
authority to require information and
reports from manufacturers. Further,
Part A authorizes the Secretary of
Energy to prescribe test procedures that
are reasonably designed to produce
results which measure energy
efficiency, energy use, or estimated
operating costs, and that are not unduly
burdensome to conduct. (42 U.S.C.
6293(b)(3)) The test procedure for
dishwashers is contained in 10 CFR part
430, subpart B, appendix C.
The regulations set forth in 10 CFR
part 430.27 contain provisions that
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enable a person to seek a waiver from
the test procedure requirements for
covered consumer products. A waiver
will be granted by the Assistant
Secretary for Energy Efficiency and
Renewable Energy (the Assistant
Secretary) if it is determined that the
basic model for which the petition for
waiver was submitted contains one or
more design characteristics that
prevents testing of the basic model
according to the prescribed test
procedures, or if the prescribed test
procedures may evaluate the basic
model in a manner so unrepresentative
of its true energy consumption
characteristics as to provide materially
inaccurate comparative data. 10 CFR
part 430.27(l). Petitioners must include
in their petition any alternate test
procedures known to the petitioner to
evaluate the basic model in a manner
representative of its energy
consumption. 10 CFR part
430.27(b)(1)(iii). The Assistant Secretary
may grant the waiver subject to
conditions, including adherence to
alternate test procedures. 10 CFR part
430.27(l). Waivers remain in effect
pursuant to the provisions of 10 CFR
part 430.27(m).
The waiver process also allows the
Assistant Secretary to grant an interim
waiver from test procedure
requirements to manufacturers that have
petitioned DOE for a waiver of such
prescribed test procedures. 10 CFR part
430.27(a)(2) An interim waiver remains
in effect for 180 days or until DOE
issues its determination on the petition
for waiver, whichever is sooner. An
interim waiver may be extended for an
additional 180 days. 10 CFR part
430.27(h)
II. Petition for Waiver
On March 16, 2010, Whirlpool filed a
petition for waiver and application for
interim waiver from the test procedure
applicable to dishwashers set forth in 10
CFR part 430, subpart B, appendix C.
Whirlpool claims that water softeners
can prevent consumer behaviors that
consume additional energy and water.
Whirlpool also claims that a dishwasher
equipped with a water softener will
minimize pre-rinsing and rewashing,
and that consumers will have less
reason to periodically run their
dishwasher through a clean-up cycle.
Whirlpool also claims that the amount
of water consumed by the regeneration
operation of a water softener in a
dishwasher is very small, but that it
varies significantly depending on the
adjustment of the softener. The
regeneration operation takes place
infrequently, and the frequency is
related to the level of water hardness.
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Including this water use in the
measurement of water consumption
during an individual energy test cycle
could overstate water use by as much as
12 percent, and energy use by as much
as 6 percent, according to Whirlpool. In
view of the small amount of water
consumed during softener regeneration
and the relative infrequency of the
regeneration operation, Whirlpool is
requesting approval to measure water
consumption of dishwashers having
water softeners without including the
water consumed by the dishwasher
during softener regeneration. This is the
approach used in European Standard
EN 50242, ‘‘Electric Dishwashers for
Household Use—Methods for Measuring
the Performance.’’
III. Application for Interim Waiver
Whirlpool also requests an interim
waiver for particular basic models with
integrated water softeners. An interim
waiver may be granted if it is
determined that the applicant will
experience economic hardship if the
application for interim waiver is denied,
if it appears likely that the petition for
waiver will be granted, and/or the
Assistant Secretary determines that it
would be desirable for public policy
reasons to grant immediate relief
pending a determination of the petition
for waiver. (10 CFR part 430.27(g)).
DOE determined that Whirlpool’s
application for interim waiver does not
provide sufficient market, equipment
price, shipments, and other
manufacturer impact information to
permit DOE to evaluate the economic
hardship Whirlpool might experience
absent a favorable determination on its
application for interim waiver. DOE
understands, however, that the current
test procedure may not predict
accurately the water and energy
consumption of its line of dishwashers
with a built-in water softener. The test
procedure will only register water
consumption from softener regeneration
in a small fraction of test runs,
producing variable results. As a result,
and based on the information provided
by Whirlpool, DOE determined that the
test results may provide materially
inaccurate comparative data.
Whirlpool provided the European
Standard EN 50242, ‘‘Electric
Dishwashers for Household Use—
Methods for Measuring the
Performance,’’ as an alternate test
procedure. This standard excludes
water use due to softener regeneration
from its water use efficiency measure.
DOE notes that if water consumption of
a regeneration operation is to be
apportioned across all cycles of
operation, then manufacturers would
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need to make calculations regarding
average water hardness and average
water consumption due to regeneration
operations that are not currently
provided for or allowed by the test
procedure. DOE is considering
development of an averaging procedure
for use as an alternate test procedure in
the decision and order on the Whirlpool
waiver, and welcomes comments and
data in support of such a procedure. In
the meantime, use of EN 50242 would
provide repeatable results, but would
slightly underestimate the energy and
water use of these models. In its
petition, Whirlpool estimated that, on
average, 23 gallons/year of water and 4
kWh/year would be consumed in
softener regeneration. These values are
based on internal testing conducted by
Whirlpool. Therefore, in the interim
waiver, DOE is adding these constant
values to the energy consumption
measured by appendix C.
Based on the likelihood of granting
the petition for waiver, DOE grants
Whirlpool’s application for interim
waiver. Therefore, Whirlpool shall not
be required to test its dishwasher
models:
KitchenAid brand:
KUDE60SXSS
KUDS30SXSS
Kenmore brand:
14052K01
14053K01
14059K01
14062K01
14063K01
14069K01
according to the existing DOE test
procedure, which is found in 10 CFR
430, subpart B, appendix C, but shall be
required to test and rate such products
according to the alternate test procedure
as set forth below.
Under appendix C, the water energy
consumption, W or Wg, is calculated
based on the water consumption as set
forth in Sect. 4.3:
§ 4.3 Water consumption. Measure
the water consumption, V, expressed as
the number of gallons of water delivered
to the machine during the entire test
cycle, using a water meter as specified
in section 3.3 of this Appendix.
Where the regeneration of the water
softener depends on demand and water
hardness, and does not take place on
every cycle, Whirlpool shall measure
the water consumption of dishwashers
having water softeners without
including the water consumed by the
dishwasher during softener
regeneration. If a regeneration operation
takes place within the test, the water
consumed by the regeneration operation
shall be disregarded when declaring
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water and energy consumption, but
constant values of 23 gallons/year of
water and 4 kWh/year of energy shall be
added to the values measured by
appendix C.
IV. Summary and Request for
Comments
Through today’s notice, DOE
announces receipt of Whirlpool’s
petition for waiver from certain parts of
the test procedure that apply to
dishwashers. DOE is publishing
Whirlpool’s petition for waiver in its
entirety pursuant to 10 CFR
430.27(b)(1)(iv). The petition contains
no confidential information. The
petition includes a suggested alternate
test procedure which is to measure the
water consumption of dishwashers
having water softeners without
including the water consumed by the
dishwasher during softener
regeneration. DOE is interested in
receiving comments from interested
parties on all aspects of the petition,
including the suggested alternate test
procedure and any alternate test
procedure. Pursuant to 10 CFR
430.27(b)(1)(iv), any person submitting
written comments to DOE must also
send a copy to the petitioner, whose
contact information is included in the
ADDRESSES section above.
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Issued in Washington, DC, on July 8, 2010.
Cathy Zoi,
Assistant Secretary, Energy Efficiency and
Renewable Energy.
J.B. Hoyt
Director, Government Relations
May 26, 2010
Via e-mail (cathy.zoi@ee.doe.gov) and
Overnight Mail
The Honorable Catherine Zoi
Assistant Secretary, Energy Efficiency
and Renewable Energy
U.S. Department of Energy
Mail Station EE–10
1000 Independence Avenue SW
Washington, DC 20585
A. Re: Amended Petition For Waiver
and Application for Interim Waiver
Under 10 CFR 430.27 for
Dishwasher: With Integrated Water
Softener
Dear Assistant Secretary Zoi:
Whirlpool Corporation (Whirlpool)
respectfully submits this Amended
Petition For Waiver and Application for
Interim waiver, pursuant to 10 CFR
430.27, to the U.S. Department of
Energy (DOE) regarding the test
procedure specified in 10 CFR Part 430,
Subpt. B, App. C (Test Procedure) for
measuring the energy consumption of
dishwashers. This Petition is being
amended, pursuant to the request of the
Department, for purposes of identifying
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specific model numbers of affected
dishwashers in Section 2 (below).
This Amended Petition For Waiver
and Application for Interim Waiver is
directed to dishwashers containing a
built-in or integrated water softener. 10
CFR 430.27(a)(1) provides that a
manufacturer may submit a Petition to
waive a requirement of § 430.23 upon
grounds that the basic model contains
one or more design characteristics
which either prevent testing of the basic
model according to the prescribed test
procedures, or the prescribed test
procedures may evaluate the basic
model in a manner so unrepresentative
of its true energy consumption
characteristics as to provide materially
inaccurate comparative data.
Additionally, 10 CFR 430.27(b)(2)
allows an applicant to request an
Interim Waiver if economic hardship
and/or competitive disadvantage is
likely to result absent a favorable
determination on the Application for
Interim Waiver.
For the reasons set forth below,
Whirlpool submits that the testing of
dishwashers equipped with water
softeners under the Test Procedure will
lead to results that may be materially
inaccurate and mislead consumers.
1. Petitioner.
Whirlpool Corporation is the world’s
leading manufacturer and marketer of
major home appliances, with annual
sales of approximately $17 billion in
2009, 67,000 employees, and 67
manufacturing and technology research
centers around the world. The company
markets Whirlpool, Maytag, KitchenAid,
Jenn-Air, Amana, Brastemp, Consul,
Bauknecht and other major brand names
to consumers in nearly every country
around the world.
2. Identification of Basic Models.
This Amended Petition For Waiver
and Application for Interim Waiver is
made with respect to all basic models of
dishwashers that incorporate an
integrated water softener (‘‘Basic
Models’’). The Basic Model numbers are
identified as follows:
KitchenAid brand:
KUDE60SXSS
KUDS30SXSS
Kenmore brand:
14052K01
14053K01
14059K01
14062K01
14063K01
14069K01
The design characteristic that is
common among the Basic Models is an
integrated automatic water softener
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41169
which is designed to periodically
regenerate. During the regeneration
operation water is flushed through the
water softener. The regeneration
operation occurs infrequently and
depends on the adjustment of the
softener. Water used during the
regeneration operation is in addition to
the water used by the dishwasher
during a dishwasher ‘‘normal’’ cycle.
3. Background.
A water softener reduces water
hardness. Hard water is water that has
high mineral content (in contrast with
soft water). Hard water minerals
primarily consist of calcium (Ca2+), and
magnesium (Mg2+) metal cations, and
sometimes other dissolved compounds
such as bicarbonates and sulfates. Water
hardness varies throughout the United
States. Based on information provided
by the U.S. Geological Survey, the mean
water hardness within the U.S. is 217
mg/liter (milligrams per liter), which is
the equivalent of 12.6 grains/gallon. See
https://water.usgs.gov/owq/hardnessalkalinity.html
Hard water reduces the effectiveness
of detergent leading to the need for
additional detergent. The amount of
rinse aid use is also affected by water
hardness; more rinse aid is necessary to
achieve good results with hard water.
As a result, high water hardness can
contribute to filming on dishwasher
items, leading to consumer behaviors
such as increased pre-rinsing and, in
some cases, rewashing of dishes either
by hand or by subsequent dishwasher
cycles. Further, hard water can lead to
the presence of scale build-up within
the dishwasher requiring periodic
dishwasher cleaning (clean-up).
Accordingly, systems that reduce
water hardness can prevent behaviors
that consume additional energy and
water. Specifically, a dishwasher
equipped with a water softener will
minimize pre-rinsing and rewashing.
Further, consumers will have less
reason to periodically run their
dishwasher through a clean-up cycle.
Under common water softener
technology, water passing through a
resin tank loses positively charged
calcium and magnesium ions to
negatively charged plastic beads. The
water is softened in this manner till the
plastic beads no longer can supply a
negative charge. A brine tank is
provided and holds a salt solution that
periodically flushes and regenerates the
resin tank, replacing calcium and
magnesium ions with sodium. The
water softening regeneration process
requires water for both regeneration and
for back-rinsing processes. For the
purposes of this Waiver, both water
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usages are combined and used under the
term ‘‘regeneration.’’
In a dishwasher equipped with a
consumer adjustable water softener,
water softener regeneration does not
take place during every cycle. Rather,
regeneration takes place as a function of
home water supply water hardness,
determined by a customer adjustable
dishwasher water hardness level setting.
For a conventional dishwasher in a
home with the mean water hardness of
12.6 grains per gallon, water softener
regeneration may take place
approximately every six to eight cycles.
However, regeneration may vary
significantly, depending on customer
adjusted hardness level setting. As
indicated by the U.S. Geological Survey
information, water hardness within the
U.S. varies significantly. For a
significant population of U.S.
consumers, their water hardness is such
that no water softener operation is
required.
The amount of water used for softener
regeneration, when apportioned evenly
across all dishwasher cycles, is very
small. For conventional dishwashers,
Whirlpool estimates that the typical
water use during regeneration ranges
between two to three (2–3) liters (0.5–
0.8 gallons). If this amount is
apportioned across six cycles (a
reasonable average regeneration
frequency rate), the water usage due to
regeneration is approximately 0.41
liters/cycle (0.11 gallons/cycle). Based
upon 215 dishwasher cycles per year 1,
the estimated annual water and energy
consumption, due to water softener
regeneration, will be approximately 23
gallons/year of water and 4 kWh/year,
respectively. This is less than 1.5% of
the total energy use of the average
dishwasher.
Providing a dishwasher with a water
softener is not new. Most dishwashers
manufactured and sold in European
countries contain water softeners. Under
the European Standard EN 50242
‘‘Electric Dishwashers for Household
Use—Methods for Measuring the
Performance,’’ water usage and energy
associated with water softeners is not
included.
§ 8.2.1 of EN 50242 is set forth
below:
§ 8.2.1 Regeneration operations
For dishwashers, where the
regeneration of the water softener
depends on demand and water
hardness, and does not take place on
every cycle; when calculating the
arithmetical mean value of the energy,
water consumption and time, if a
1 The annual dishwasher usage set forth in the
Test Procedure.
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regeneration operation takes place,
within the test procedure, it shall be
disregarded when declaring energy,
water and time values. (Emphasis
added)
Note: The frequency of the
regeneration operations in some
machines is not predictable and
depends on the adjustment of the
softener and the water hardness of the
water used by the laboratories.
In the test report, it shall be stated
whether regeneration(s) occurred during
the five (or more) test cycles.
European Standard EN 50242
recognizes that including the water used
during a regeneration operation would
evaluate the tested dishwasher in a
manner so unrepresentative of its true
energy consumption characteristics as to
provide materially inaccurate
comparative data. Based on the
infrequency of the regeneration
operation, including the water used
during a regeneration operation in the
measurement of water consumption
during an individual energy test cycle
could lead to overstating the water use
by as much as 12%, and overstating the
energy use by as much as 6%.2
4. Requirements Sought To Be Waived.
The Basic Models are subject to the
provisions of 10 CFR Part 430, Subpt. B,
App. C of the Test Procedure, which
specifies the calculation of water energy
consumption for non-soil-sensing and
soil-sensing dishwashers using
electrically or gas/oil heated water.
Under the Test Procedure, the water
energy consumption, W or Wg, are
calculated based on the water
consumption as set forth in 10 CFR Part
430, Subpt. B, App. C, Sect. 4.3:
§ 4.3 Water consumption. Measure
the water consumption, V, expressed as
the number of gallons of water delivered
to the machine during the entire test
cycle, using a water meter as specified
in section 3.3 of this Appendix.
Whirlpool is requesting approval to
measure water consumption of
dishwashers having water softeners
without including the water consumed
by the dishwasher during softener
regeneration. Similar to the European
standard EN 50242, Whirlpool is
proposing that if a regeneration
operation takes place within the test
procedure, the water consumed by the
regeneration operation shall be
2 Under energy testing of a soil-sensing
dishwasher, energy consumption is derived from
normal cycle operation at a low, medium and high
soil sensor response. The 6% estimate is the
potential additional energy consumption that may
occur if a regeneration operation occurs during the
light sensor response dishwasher cycle. 10 CFR Part
430, Subpt. B, App. C, § 5.3.2.
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disregarded when declaring water and
energy consumption.
5. Grounds For Waiver and Interim
Waiver.
10 CFR 430.27(a)(1) provides that a
Petition to waive a requirement of
§ 430.23 may be submitted upon
grounds that the basic model contains
one or more design characteristics
which either prevent testing of the basic
model according to the prescribed test
procedures, or the prescribed test
procedures may evaluate the basic
model in a manner so unrepresentative
of its true energy consumption
characteristics as to provide materially
inaccurate comparative data.
As noted above, the inclusion of a
water softener in a dishwasher is likely
to lead to water and energy savings due
to enhanced effectiveness of the
dishwasher. This advance in technology
offers consumers a new benefit that
should not be discouraged by the Test
Procedure. Additionally, the amount of
water consumed by the regeneration
operation of a water softener in a
dishwasher is very small and varies
significantly depending on the
adjustment of the softener.
In view of the small amount of water
consumed during softener regeneration
and the relative infrequency of the
regeneration operation, Whirlpool is
requesting approval to measure water
consumption of dishwashers having
water softeners without including the
water consumed by the dishwasher
during softener regeneration. If this
Waiver and Interim Waiver are not
granted, there will be significant
uncertainty in the method for measuring
water consumption for dishwashers
with water softeners. If water
consumption due to water softeners is
measured during an energy cycle,
without any apportionment of this water
across all cycles, energy use for a
dishwasher could be overstated by a
significant amount. If water
consumption of a regeneration operation
is to be apportioned across all cycles of
operation, then manufacturers would
need to make calculations regarding
average water hardness and average
water consumptions due to regeneration
operations that are not currently
provided for or allowed by the Test
Procedure.
6. Justification for Whirlpool’s Interim
Waiver Application.
Granting of an Interim Waiver is
justified in this case because Whirlpool
has provided strong evidence that
demonstrates the likelihood of the
granting of the Amended Petition for
Waiver.
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Additionally, Whirlpool will suffer
significant economic hardship and
competitive disadvantage if this Interim
Waiver Application is not granted and
there are strong public policy
justifications to issue an Interim Waiver
to help promote uniform interpretation
and application of the Test Procedure to
dishwashers with water softeners. As
discussed above, if this Interim Waiver
is not granted, there will be significant
uncertainty in how to measure water
consumption for dishwashers with
water softeners. This will cause
economic hardship and competitive
disadvantage for Whirlpool. There are
long lead times and significant expenses
associated with the design and
manufacture of dishwashers.
Compliance with federally mandated
energy consumption standards and
ENERGY STAR criteria is a critical
design factor for dishwashers. Any
delay in obtaining clarity on this issue
will cause Whirlpool economic
hardship and competitive disadvantage.
srobinson on DSKHWCL6B1PROD with NOTICES
7. Manufacturers of Similar Products
and Affected Manufacturers.
We believe that at least two
dishwasher manufacturers, BSH Home
Appliances Corp. (Bosch-Siemens
Hausgerate GmbH) and Miele Inc., are
currently selling in the U.S.
dishwashers with an integrated water
softener.
The manufacturers that sell
dishwashers in the United States
include ASKO Appliances, Inc., BSH
Home Appliances Corp. (Bosch-Siemens
Hausgerate GmbH), Electrolux North
America, Inc., Fisher & Paykel
Appliances, GE Appliances and
Lighting, Haier America, Indesit
Company Sa, LG Electronics USA,
Miele, Inc., Samsung Electronics Co.,
and Viking Range Corporation. The
Association of Home Appliances
Manufacturers is also generally
interested in energy efficiency
requirements for appliances, including
dishwashers. Whirlpool will notify all
these entities as set forth in the
Department’s rules and provide them
with a version of this Amended Petition
and Application.
8. Conclusion.
Whirlpool respectfully submits that
by granting this Amended Waiver
Petition and Application for Interim
Waiver, the Department will ensure that
advancements in technology and
consumer beneficial innovations are not
hindered by regulations, and that
similar products are tested and rated for
energy consumption on a comparable
basis. This waiver should continue until
the Test Procedure can be formally
VerDate Mar<15>2010
16:53 Jul 14, 2010
Jkt 220001
amended to exclude the water and
energy consumed during a water
softener regeneration operation.
Whirlpool certifies that all
manufacturers of domestically marketed
dishwashers identified above have been
notified by letter of this Amended
Petition and application. Copies of such
letter and related certification are
attached hereto.
Sincerely,
/s/J.B. Hoyt
llllllllllllllllll
l
J.B. Hoyt
Director, Government Relations
Whirlpool Corporation
[FR Doc. 2010–17295 Filed 7–14–10; 8:45 am]
BILLING CODE 6450–01–P
ENVIRONMENTAL PROTECTION
AGENCY
[EPA–HQ–OAR–2009–0911; FRL–9176–1]
Agency Information Collection
Activities; Submission to OMB for
Review and Approval; Comment
Request; Mobile Air Conditioner
Retrofitting Program (Renewal); EPA
ICR No. 1774.05, OMB Control No.
2060–0350
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Notice.
SUMMARY: In compliance with the
Paperwork Reduction Act (PRA) (44
U.S.C. 3501 et seq.), this document
announces that an Information
Collection Request (ICR) has been
forwarded to the Office of Management
and Budget (OMB) for review and
approval. This is a request to renew an
existing approved collection. The ICR,
which is abstracted below, describes the
nature of the information collection and
its estimated burden and cost.
DATES: Additional comments may be
submitted on or before August 16, 2010.
ADDRESSES: Submit your comments,
referencing Docket ID No. EPA–HQ–
OAR–2009–0911 to (1) EPA online
using www.regulations.gov (our
preferred method), by e-mail to a-and-rdocket@epa.gov, or by mail to: EPA
Docket Center, Environmental
Protection Agency, Air and Radiation
Docket, Mail Code 28221T, 1200
Pennsylvania Ave., NW., Washington,
DC 20460, and (2) OMB by mail to:
Office of Information and Regulatory
Affairs, Office of Management and
Budget (OMB), Attention: Desk Officer
for EPA, 725 17th Street, NW.,
Washington, DC 20503.
FOR FURTHER INFORMATION CONTACT:
Yaidi Cancel, Stratospheric Protection
PO 00000
Frm 00033
Fmt 4703
Sfmt 4703
41171
Division, Office of Air and Radiation,
Mail Code 6205J, Environmental
Protection Agency, 1200 Pennsylvania
Ave., NW., Washington, DC 20460;
telephone number: (202) 343–9512; fax
number: (202) 343–2338; e-mail address:
Cancel.Yaidi@epa.gov.
SUPPLEMENTARY INFORMATION: EPA has
submitted the following ICR to OMB for
review and approval according to the
procedures prescribed in 5 CFR 1320.12.
On February 22, 2010 (75 FR 7584), EPA
sought comments on this ICR pursuant
to 5 CFR 1320.8(d). EPA received no
comments. Any additional comments on
this ICR should be submitted to EPA
and OMB within 30 days of this notice.
EPA has established a public docket
for this ICR under Docket ID No. EPA–
HQ–OAR–2009–0911, which is
available for online viewing at https://
www.regulations.gov, or in person
viewing at the Air Docket in the EPA
Docket Center (EPA/DC), EPA West,
Room 3334, 1301 Constitution Ave.,
NW., Washington, DC. The EPA/DC
Public Reading Room is open from 8:30
a.m. to 4:30 p.m., Monday through
Friday, excluding legal holidays. The
telephone number for the Reading Room
is 202–566–1744, and the telephone
number for the Air Docket is 202–566–
1742.
Use EPA’s electronic docket and
comment system at https://
www.regulations.gov, to submit or view
public comments, access the index
listing of the contents of the docket, and
to access those documents in the docket
that are available electronically. Once in
the system, select ‘‘docket search,’’ then
key in the docket ID number identified
above. Please note that EPA’s policy is
that public comments, whether
submitted electronically or in paper,
will be made available for public
viewing at https://www.regulations.gov
as EPA receives them and without
change, unless the comment contains
copyrighted material, confidential
business information (CBI), or other
information whose public disclosure is
restricted by statute. For further
information about the electronic docket,
go to https://www.regulations.gov.
Title: Mobile Air Conditioner
Retrofitting Program (Renewal)
ICR numbers: EPA ICR No. 1774.05,
OMB Control No. 2060–0350.
ICR Status: This ICR is scheduled to
expire on July 31, 2010. Under OMB
regulations, the Agency may continue to
conduct or sponsor the collection of
information while this submission is
pending at OMB. An Agency may not
conduct or sponsor, and a person is not
required to respond to, a collection of
information, unless it displays a
E:\FR\FM\15JYN1.SGM
15JYN1
Agencies
[Federal Register Volume 75, Number 135 (Thursday, July 15, 2010)]
[Notices]
[Pages 41167-41171]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-17295]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
Office of Energy Efficiency and Renewable Energy
[Case No. DW-004]
Energy Conservation Program for Consumer Products: Notice of
Petition for Waiver of Whirlpool Corporation From the Department of
Energy Residential Dishwasher Test Procedure, and Grant of Interim
Waiver
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of petition for waiver, notice of grant of interim
waiver, and request for comments.
-----------------------------------------------------------------------
SUMMARY: This notice announces receipt of and publishes the Whirlpool
Corporation (Whirlpool) petition for waiver (hereafter, ``petition'')
from specified portions of the U.S. Department of Energy (DOE) test
procedure for determining the energy consumption of dishwashers.
Today's notice also grants an interim waiver of the dishwasher test
procedure. Through this notice, DOE also solicits comments with respect
to the Whirlpool petition.
DATES: DOE will accept comments, data, and information with respect to
the Whirlpool petition until, but no later than August 16, 2010.
ADDRESSES: You may submit comments, identified by case number DW-004,
by any of the following methods:
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail: AS_Waiver_Requests@ee.doe.gov. Include either
the case number [Case No. DW-004], and/or ``Whirlpool Petition'' in the
subject line of the message.
Mail: Ms. Brenda Edwards, U.S. Department of Energy,
Building Technologies Program, Mailstop EE-2J/1000 Independence Avenue,
SW., Washington, DC 20585-0121. Telephone: (202) 586-2945. Please
submit one signed original paper copy.
Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department
of Energy, Building Technologies Program, 950 L'Enfant Plaza, SW.,
Suite 600, Washington, DC 20024. Please submit one signed original
paper copy.
Instructions: All submissions received must include the agency name
and case number for this proceeding. Submit electronic comments in
WordPerfect, Microsoft Word, Portable Document Format (PDF), or text
(American Standard Code for Information Interchange (ASCII)) file
format and avoid the use of special characters or any form of
encryption. Wherever possible, include the electronic signature of the
author. DOE does not accept telefacsimiles (faxes).
Any person submitting written comments must also send a copy to the
petitioner, pursuant to 10 CFR 431.401(d). The contact information for
the petitioner is: Mr. J.B. Hoyt, Director, Government Relations,
Whirlpool Corporation, 2000 M 63, Mail Drop 3005, Benton Harbor, MI
49022, Phone: (269) 923-4647, E-mail: j.b.hoyt@whirlpool.com.
According to 10 CFR 1004.11, any person submitting information that
he or she believes to be confidential and exempt by law from public
disclosure should submit two copies to DOE: One copy of the document
including all the information believed to be confidential, and one copy
of the document with the information believed to be confidential
deleted. DOE will make its own determination about the confidential
status of the information and treat it according to its determination.
Docket: For access to the docket to review the background documents
relevant to this matter, you may visit the U.S. Department of Energy,
950 L'Enfant Plaza, SW., (Resource Room of the Building Technologies
Program), Washington, DC, 20024; (202) 586-2945, between 9 a.m. and 4
p.m., Monday through Friday, except Federal holidays. Available
documents include the following items: (1) This notice; (2) public
comments received; (3) the petition for waiver and application for
interim waiver; and (4) prior DOE waivers and rulemakings regarding
similar dishwasher products. Please call Ms. Brenda Edwards at the
above telephone number for additional information regarding visiting
the Resource Room.
FOR FURTHER INFORMATION CONTACT: Dr. Michael G. Raymond, U.S.
Department of Energy, Building Technologies Program, Mail Stop EE-2J,
Forrestal Building, 1000 Independence Avenue, SW., Washington, DC
20585-0121. Telephone: (202) 586-9611. E-mail:
Michael.Raymond@ee.doe.gov.
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of the
General Counsel, Mail Stop GC-71, Forrestal Building, 1000 Independence
Avenue, SW., Washington, DC 20585-0103. Telephone: (202) 586-7796. E-
mail: Elizabeth.Kohl@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
I. Background and Authority
Title III of the Energy Policy and Conservation Act (``EPCA'') sets
forth a variety of provisions concerning energy efficiency. Part A of
Title III provides for the ``Energy Conservation Program for Consumer
Products Other Than Automobiles.'' (42 U.S.C. 6291-6309) Part A
includes definitions, test procedures, labeling provisions, energy
conservation standards, and the authority to require information and
reports from manufacturers. Further, Part A authorizes the Secretary of
Energy to prescribe test procedures that are reasonably designed to
produce results which measure energy efficiency, energy use, or
estimated operating costs, and that are not unduly burdensome to
conduct. (42 U.S.C. 6293(b)(3)) The test procedure for dishwashers is
contained in 10 CFR part 430, subpart B, appendix C.
The regulations set forth in 10 CFR part 430.27 contain provisions
that
[[Page 41168]]
enable a person to seek a waiver from the test procedure requirements
for covered consumer products. A waiver will be granted by the
Assistant Secretary for Energy Efficiency and Renewable Energy (the
Assistant Secretary) if it is determined that the basic model for which
the petition for waiver was submitted contains one or more design
characteristics that prevents testing of the basic model according to
the prescribed test procedures, or if the prescribed test procedures
may evaluate the basic model in a manner so unrepresentative of its
true energy consumption characteristics as to provide materially
inaccurate comparative data. 10 CFR part 430.27(l). Petitioners must
include in their petition any alternate test procedures known to the
petitioner to evaluate the basic model in a manner representative of
its energy consumption. 10 CFR part 430.27(b)(1)(iii). The Assistant
Secretary may grant the waiver subject to conditions, including
adherence to alternate test procedures. 10 CFR part 430.27(l). Waivers
remain in effect pursuant to the provisions of 10 CFR part 430.27(m).
The waiver process also allows the Assistant Secretary to grant an
interim waiver from test procedure requirements to manufacturers that
have petitioned DOE for a waiver of such prescribed test procedures. 10
CFR part 430.27(a)(2) An interim waiver remains in effect for 180 days
or until DOE issues its determination on the petition for waiver,
whichever is sooner. An interim waiver may be extended for an
additional 180 days. 10 CFR part 430.27(h)
II. Petition for Waiver
On March 16, 2010, Whirlpool filed a petition for waiver and
application for interim waiver from the test procedure applicable to
dishwashers set forth in 10 CFR part 430, subpart B, appendix C.
Whirlpool claims that water softeners can prevent consumer behaviors
that consume additional energy and water. Whirlpool also claims that a
dishwasher equipped with a water softener will minimize pre-rinsing and
rewashing, and that consumers will have less reason to periodically run
their dishwasher through a clean-up cycle.
Whirlpool also claims that the amount of water consumed by the
regeneration operation of a water softener in a dishwasher is very
small, but that it varies significantly depending on the adjustment of
the softener. The regeneration operation takes place infrequently, and
the frequency is related to the level of water hardness. Including this
water use in the measurement of water consumption during an individual
energy test cycle could overstate water use by as much as 12 percent,
and energy use by as much as 6 percent, according to Whirlpool. In view
of the small amount of water consumed during softener regeneration and
the relative infrequency of the regeneration operation, Whirlpool is
requesting approval to measure water consumption of dishwashers having
water softeners without including the water consumed by the dishwasher
during softener regeneration. This is the approach used in European
Standard EN 50242, ``Electric Dishwashers for Household Use--Methods
for Measuring the Performance.''
III. Application for Interim Waiver
Whirlpool also requests an interim waiver for particular basic
models with integrated water softeners. An interim waiver may be
granted if it is determined that the applicant will experience economic
hardship if the application for interim waiver is denied, if it appears
likely that the petition for waiver will be granted, and/or the
Assistant Secretary determines that it would be desirable for public
policy reasons to grant immediate relief pending a determination of the
petition for waiver. (10 CFR part 430.27(g)).
DOE determined that Whirlpool's application for interim waiver does
not provide sufficient market, equipment price, shipments, and other
manufacturer impact information to permit DOE to evaluate the economic
hardship Whirlpool might experience absent a favorable determination on
its application for interim waiver. DOE understands, however, that the
current test procedure may not predict accurately the water and energy
consumption of its line of dishwashers with a built-in water softener.
The test procedure will only register water consumption from softener
regeneration in a small fraction of test runs, producing variable
results. As a result, and based on the information provided by
Whirlpool, DOE determined that the test results may provide materially
inaccurate comparative data.
Whirlpool provided the European Standard EN 50242, ``Electric
Dishwashers for Household Use--Methods for Measuring the Performance,''
as an alternate test procedure. This standard excludes water use due to
softener regeneration from its water use efficiency measure. DOE notes
that if water consumption of a regeneration operation is to be
apportioned across all cycles of operation, then manufacturers would
need to make calculations regarding average water hardness and average
water consumption due to regeneration operations that are not currently
provided for or allowed by the test procedure. DOE is considering
development of an averaging procedure for use as an alternate test
procedure in the decision and order on the Whirlpool waiver, and
welcomes comments and data in support of such a procedure. In the
meantime, use of EN 50242 would provide repeatable results, but would
slightly underestimate the energy and water use of these models. In its
petition, Whirlpool estimated that, on average, 23 gallons/year of
water and 4 kWh/year would be consumed in softener regeneration. These
values are based on internal testing conducted by Whirlpool. Therefore,
in the interim waiver, DOE is adding these constant values to the
energy consumption measured by appendix C.
Based on the likelihood of granting the petition for waiver, DOE
grants Whirlpool's application for interim waiver. Therefore, Whirlpool
shall not be required to test its dishwasher models:
KitchenAid brand:
KUDE60SXSS
KUDS30SXSS
Kenmore brand:
14052K01
14053K01
14059K01
14062K01
14063K01
14069K01
according to the existing DOE test procedure, which is found in 10 CFR
430, subpart B, appendix C, but shall be required to test and rate such
products according to the alternate test procedure as set forth below.
Under appendix C, the water energy consumption, W or Wg, is
calculated based on the water consumption as set forth in Sect. 4.3:
Sec. 4.3 Water consumption. Measure the water consumption, V,
expressed as the number of gallons of water delivered to the machine
during the entire test cycle, using a water meter as specified in
section 3.3 of this Appendix.
Where the regeneration of the water softener depends on demand and
water hardness, and does not take place on every cycle, Whirlpool shall
measure the water consumption of dishwashers having water softeners
without including the water consumed by the dishwasher during softener
regeneration. If a regeneration operation takes place within the test,
the water consumed by the regeneration operation shall be disregarded
when declaring
[[Page 41169]]
water and energy consumption, but constant values of 23 gallons/year of
water and 4 kWh/year of energy shall be added to the values measured by
appendix C.
IV. Summary and Request for Comments
Through today's notice, DOE announces receipt of Whirlpool's
petition for waiver from certain parts of the test procedure that apply
to dishwashers. DOE is publishing Whirlpool's petition for waiver in
its entirety pursuant to 10 CFR 430.27(b)(1)(iv). The petition contains
no confidential information. The petition includes a suggested
alternate test procedure which is to measure the water consumption of
dishwashers having water softeners without including the water consumed
by the dishwasher during softener regeneration. DOE is interested in
receiving comments from interested parties on all aspects of the
petition, including the suggested alternate test procedure and any
alternate test procedure. Pursuant to 10 CFR 430.27(b)(1)(iv), any
person submitting written comments to DOE must also send a copy to the
petitioner, whose contact information is included in the ADDRESSES
section above.
Issued in Washington, DC, on July 8, 2010.
Cathy Zoi,
Assistant Secretary, Energy Efficiency and Renewable Energy.
J.B. Hoyt
Director, Government Relations
May 26, 2010
Via e-mail (cathy.zoi@ee.doe.gov) and Overnight Mail
The Honorable Catherine Zoi
Assistant Secretary, Energy Efficiency and Renewable Energy
U.S. Department of Energy
Mail Station EE-10
1000 Independence Avenue SW
Washington, DC 20585
A. Re: Amended Petition For Waiver and Application for Interim Waiver
Under 10 CFR 430.27 for Dishwasher: With Integrated Water Softener
Dear Assistant Secretary Zoi:
Whirlpool Corporation (Whirlpool) respectfully submits this Amended
Petition For Waiver and Application for Interim waiver, pursuant to 10
CFR 430.27, to the U.S. Department of Energy (DOE) regarding the test
procedure specified in 10 CFR Part 430, Subpt. B, App. C (Test
Procedure) for measuring the energy consumption of dishwashers. This
Petition is being amended, pursuant to the request of the Department,
for purposes of identifying specific model numbers of affected
dishwashers in Section 2 (below).
This Amended Petition For Waiver and Application for Interim Waiver
is directed to dishwashers containing a built-in or integrated water
softener. 10 CFR 430.27(a)(1) provides that a manufacturer may submit a
Petition to waive a requirement of Sec. 430.23 upon grounds that the
basic model contains one or more design characteristics which either
prevent testing of the basic model according to the prescribed test
procedures, or the prescribed test procedures may evaluate the basic
model in a manner so unrepresentative of its true energy consumption
characteristics as to provide materially inaccurate comparative data.
Additionally, 10 CFR 430.27(b)(2) allows an applicant to request an
Interim Waiver if economic hardship and/or competitive disadvantage is
likely to result absent a favorable determination on the Application
for Interim Waiver.
For the reasons set forth below, Whirlpool submits that the testing
of dishwashers equipped with water softeners under the Test Procedure
will lead to results that may be materially inaccurate and mislead
consumers.
1. Petitioner.
Whirlpool Corporation is the world's leading manufacturer and
marketer of major home appliances, with annual sales of approximately
$17 billion in 2009, 67,000 employees, and 67 manufacturing and
technology research centers around the world. The company markets
Whirlpool, Maytag, KitchenAid, Jenn-Air, Amana, Brastemp, Consul,
Bauknecht and other major brand names to consumers in nearly every
country around the world.
2. Identification of Basic Models.
This Amended Petition For Waiver and Application for Interim Waiver
is made with respect to all basic models of dishwashers that
incorporate an integrated water softener (``Basic Models''). The Basic
Model numbers are identified as follows:
KitchenAid brand:
KUDE60SXSS
KUDS30SXSS
Kenmore brand:
14052K01
14053K01
14059K01
14062K01
14063K01
14069K01
The design characteristic that is common among the Basic Models is
an integrated automatic water softener which is designed to
periodically regenerate. During the regeneration operation water is
flushed through the water softener. The regeneration operation occurs
infrequently and depends on the adjustment of the softener. Water used
during the regeneration operation is in addition to the water used by
the dishwasher during a dishwasher ``normal'' cycle.
3. Background.
A water softener reduces water hardness. Hard water is water that
has high mineral content (in contrast with soft water). Hard water
minerals primarily consist of calcium (Ca\2+\), and magnesium (Mg\2+\)
metal cations, and sometimes other dissolved compounds such as
bicarbonates and sulfates. Water hardness varies throughout the United
States. Based on information provided by the U.S. Geological Survey,
the mean water hardness within the U.S. is 217 mg/liter (milligrams per
liter), which is the equivalent of 12.6 grains/gallon. See https://water.usgs.gov/owq/hardness-alkalinity.html
Hard water reduces the effectiveness of detergent leading to the
need for additional detergent. The amount of rinse aid use is also
affected by water hardness; more rinse aid is necessary to achieve good
results with hard water. As a result, high water hardness can
contribute to filming on dishwasher items, leading to consumer
behaviors such as increased pre-rinsing and, in some cases, rewashing
of dishes either by hand or by subsequent dishwasher cycles. Further,
hard water can lead to the presence of scale build-up within the
dishwasher requiring periodic dishwasher cleaning (clean-up).
Accordingly, systems that reduce water hardness can prevent
behaviors that consume additional energy and water. Specifically, a
dishwasher equipped with a water softener will minimize pre-rinsing and
rewashing. Further, consumers will have less reason to periodically run
their dishwasher through a clean-up cycle.
Under common water softener technology, water passing through a
resin tank loses positively charged calcium and magnesium ions to
negatively charged plastic beads. The water is softened in this manner
till the plastic beads no longer can supply a negative charge. A brine
tank is provided and holds a salt solution that periodically flushes
and regenerates the resin tank, replacing calcium and magnesium ions
with sodium. The water softening regeneration process requires water
for both regeneration and for back-rinsing processes. For the purposes
of this Waiver, both water
[[Page 41170]]
usages are combined and used under the term ``regeneration.''
In a dishwasher equipped with a consumer adjustable water softener,
water softener regeneration does not take place during every cycle.
Rather, regeneration takes place as a function of home water supply
water hardness, determined by a customer adjustable dishwasher water
hardness level setting. For a conventional dishwasher in a home with
the mean water hardness of 12.6 grains per gallon, water softener
regeneration may take place approximately every six to eight cycles.
However, regeneration may vary significantly, depending on customer
adjusted hardness level setting. As indicated by the U.S. Geological
Survey information, water hardness within the U.S. varies
significantly. For a significant population of U.S. consumers, their
water hardness is such that no water softener operation is required.
The amount of water used for softener regeneration, when
apportioned evenly across all dishwasher cycles, is very small. For
conventional dishwashers, Whirlpool estimates that the typical water
use during regeneration ranges between two to three (2-3) liters (0.5-
0.8 gallons). If this amount is apportioned across six cycles (a
reasonable average regeneration frequency rate), the water usage due to
regeneration is approximately 0.41 liters/cycle (0.11 gallons/cycle).
Based upon 215 dishwasher cycles per year \1\, the estimated annual
water and energy consumption, due to water softener regeneration, will
be approximately 23 gallons/year of water and 4 kWh/year, respectively.
This is less than 1.5% of the total energy use of the average
dishwasher.
---------------------------------------------------------------------------
\1\ The annual dishwasher usage set forth in the Test Procedure.
---------------------------------------------------------------------------
Providing a dishwasher with a water softener is not new. Most
dishwashers manufactured and sold in European countries contain water
softeners. Under the European Standard EN 50242 ``Electric Dishwashers
for Household Use--Methods for Measuring the Performance,'' water usage
and energy associated with water softeners is not included.
Sec. 8.2.1 of EN 50242 is set forth below:
Sec. 8.2.1 Regeneration operations
For dishwashers, where the regeneration of the water softener
depends on demand and water hardness, and does not take place on every
cycle; when calculating the arithmetical mean value of the energy,
water consumption and time, if a regeneration operation takes place,
within the test procedure, it shall be disregarded when declaring
energy, water and time values. (Emphasis added)
Note: The frequency of the regeneration operations in some machines
is not predictable and depends on the adjustment of the softener and
the water hardness of the water used by the laboratories.
In the test report, it shall be stated whether regeneration(s)
occurred during the five (or more) test cycles.
European Standard EN 50242 recognizes that including the water used
during a regeneration operation would evaluate the tested dishwasher in
a manner so unrepresentative of its true energy consumption
characteristics as to provide materially inaccurate comparative data.
Based on the infrequency of the regeneration operation, including the
water used during a regeneration operation in the measurement of water
consumption during an individual energy test cycle could lead to
overstating the water use by as much as 12%, and overstating the energy
use by as much as 6%.\2\
---------------------------------------------------------------------------
\2\ Under energy testing of a soil-sensing dishwasher, energy
consumption is derived from normal cycle operation at a low, medium
and high soil sensor response. The 6% estimate is the potential
additional energy consumption that may occur if a regeneration
operation occurs during the light sensor response dishwasher cycle.
10 CFR Part 430, Subpt. B, App. C, Sec. 5.3.2.
---------------------------------------------------------------------------
4. Requirements Sought To Be Waived.
The Basic Models are subject to the provisions of 10 CFR Part 430,
Subpt. B, App. C of the Test Procedure, which specifies the calculation
of water energy consumption for non-soil-sensing and soil-sensing
dishwashers using electrically or gas/oil heated water. Under the Test
Procedure, the water energy consumption, W or Wg, are calculated based
on the water consumption as set forth in 10 CFR Part 430, Subpt. B,
App. C, Sect. 4.3:
Sec. 4.3 Water consumption. Measure the water consumption, V,
expressed as the number of gallons of water delivered to the machine
during the entire test cycle, using a water meter as specified in
section 3.3 of this Appendix.
Whirlpool is requesting approval to measure water consumption of
dishwashers having water softeners without including the water consumed
by the dishwasher during softener regeneration. Similar to the European
standard EN 50242, Whirlpool is proposing that if a regeneration
operation takes place within the test procedure, the water consumed by
the regeneration operation shall be disregarded when declaring water
and energy consumption.
5. Grounds For Waiver and Interim Waiver.
10 CFR 430.27(a)(1) provides that a Petition to waive a requirement
of Sec. 430.23 may be submitted upon grounds that the basic model
contains one or more design characteristics which either prevent
testing of the basic model according to the prescribed test procedures,
or the prescribed test procedures may evaluate the basic model in a
manner so unrepresentative of its true energy consumption
characteristics as to provide materially inaccurate comparative data.
As noted above, the inclusion of a water softener in a dishwasher
is likely to lead to water and energy savings due to enhanced
effectiveness of the dishwasher. This advance in technology offers
consumers a new benefit that should not be discouraged by the Test
Procedure. Additionally, the amount of water consumed by the
regeneration operation of a water softener in a dishwasher is very
small and varies significantly depending on the adjustment of the
softener.
In view of the small amount of water consumed during softener
regeneration and the relative infrequency of the regeneration
operation, Whirlpool is requesting approval to measure water
consumption of dishwashers having water softeners without including the
water consumed by the dishwasher during softener regeneration. If this
Waiver and Interim Waiver are not granted, there will be significant
uncertainty in the method for measuring water consumption for
dishwashers with water softeners. If water consumption due to water
softeners is measured during an energy cycle, without any apportionment
of this water across all cycles, energy use for a dishwasher could be
overstated by a significant amount. If water consumption of a
regeneration operation is to be apportioned across all cycles of
operation, then manufacturers would need to make calculations regarding
average water hardness and average water consumptions due to
regeneration operations that are not currently provided for or allowed
by the Test Procedure.
6. Justification for Whirlpool's Interim Waiver Application.
Granting of an Interim Waiver is justified in this case because
Whirlpool has provided strong evidence that demonstrates the likelihood
of the granting of the Amended Petition for Waiver.
[[Page 41171]]
Additionally, Whirlpool will suffer significant economic hardship
and competitive disadvantage if this Interim Waiver Application is not
granted and there are strong public policy justifications to issue an
Interim Waiver to help promote uniform interpretation and application
of the Test Procedure to dishwashers with water softeners. As discussed
above, if this Interim Waiver is not granted, there will be significant
uncertainty in how to measure water consumption for dishwashers with
water softeners. This will cause economic hardship and competitive
disadvantage for Whirlpool. There are long lead times and significant
expenses associated with the design and manufacture of dishwashers.
Compliance with federally mandated energy consumption standards and
ENERGY STAR criteria is a critical design factor for dishwashers. Any
delay in obtaining clarity on this issue will cause Whirlpool economic
hardship and competitive disadvantage.
7. Manufacturers of Similar Products and Affected Manufacturers.
We believe that at least two dishwasher manufacturers, BSH Home
Appliances Corp. (Bosch-Siemens Hausgerate GmbH) and Miele Inc., are
currently selling in the U.S. dishwashers with an integrated water
softener.
The manufacturers that sell dishwashers in the United States
include ASKO Appliances, Inc., BSH Home Appliances Corp. (Bosch-Siemens
Hausgerate GmbH), Electrolux North America, Inc., Fisher & Paykel
Appliances, GE Appliances and Lighting, Haier America, Indesit Company
Sa, LG Electronics USA, Miele, Inc., Samsung Electronics Co., and
Viking Range Corporation. The Association of Home Appliances
Manufacturers is also generally interested in energy efficiency
requirements for appliances, including dishwashers. Whirlpool will
notify all these entities as set forth in the Department's rules and
provide them with a version of this Amended Petition and Application.
8. Conclusion.
Whirlpool respectfully submits that by granting this Amended Waiver
Petition and Application for Interim Waiver, the Department will ensure
that advancements in technology and consumer beneficial innovations are
not hindered by regulations, and that similar products are tested and
rated for energy consumption on a comparable basis. This waiver should
continue until the Test Procedure can be formally amended to exclude
the water and energy consumed during a water softener regeneration
operation.
Whirlpool certifies that all manufacturers of domestically marketed
dishwashers identified above have been notified by letter of this
Amended Petition and application. Copies of such letter and related
certification are attached hereto.
Sincerely,
/s/J.B. Hoyt
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J.B. Hoyt
Director, Government Relations
Whirlpool Corporation
[FR Doc. 2010-17295 Filed 7-14-10; 8:45 am]
BILLING CODE 6450-01-P