Whirlpool Comment, #17

#172000 M 63 · Mail Drop 3005 · Benton Harbor, Michigan 49022 Phone: 269/923-4647 · Fax: 269/923-4652 ·j.b.hoyt@whirlpool.com J.B. HOYT DIRECTOR, GOVERNMENT RELATIONS March 31, 2006 Secretary Samuel Bodman United States Department of Energy Building Technologies Program, Mailstop EE-2J 1000 Independence Avenue, SW Washington, DC 20585-0121 Re: Docket Number EE-RM-PET-100 Dear Secretary Bodman: Whirlpool Corporation appreciates the opportunity to comment in this matter. As one of the leading manufacturers and marketers of home appliances, we have considerable experience in the both the technological development of the products and the consumer use of them. The petition of the California Energy Commission, which seeks an exemption from Federal energy efficiency standards is flawed in several respects and should be denied by the Department. Specifically: Reduces Consumer Choice/Safe Harbor Provision The petition calls for severe limits in clothes washer water factors (WF = 8.5 in 2007, 6.0 in 2010). Top-load washers comprise some 80% of all consumer purchases. These products require a traditional rinse in order to use fabric softener (a requirement for over 50% of U.S. consumers). They also require an adequate amount of water in order to remove “chunky soils” such as sand or horse hair from clothes during the rinse process. These products typically have water factors of 12 – 13. Top-load washers cannot be designed to use a low water factor ...