RE: Docket Number EERE–2019–BT–STD–0039/RIN 1904–AF60: Direct Final Rule for Energy Conservation Standards for Dishwashers We strongly support the standards in the DFR.

The standards in the DFR reflect the joint recommendation that we submitted to DOE in September 2023 with the Association of Home Appliance Manufacturers (AHAM),1 which was supported by States and additional utilities.2 The standards for dishwashers were part of a package of recommendations for six products (refrigerators/freezers, miscellaneous refrigeration products, residential clothes washers,. [...] On a national level, the standards will save 0.31 quadrillion Btus of energy and 240 billion gallons of water over 30 years of shipments and cut carbon dioxide emissions by 9.5 million metric tons.3 Furthermore, most consumers will see no price increase as a result of the standards in the DFR; DOE’s analysis shows that most dishwashers sold today that do not meet the new standards could be modifie. [...] Furthermore, both the test procedure used today for dishwashers (Appendix C1) and the amended test procedure (Appendix C2) capture energy and water consumption only on the “normal cycle”; manufacturers will continue to be able to offer short cycle options, which will not be impacted by the standards in the DFR. [...] There is no evidence that the frequency of behaviors such as pre-rinsing, handwashing, or running multiple cycles has increased over time or will increase in the future as a result of the standards in the DFR. [...] DOE established an assumed annual number of cycles per year of 215 in 2003 for the purposes of the dishwasher test procedure based on data from several sources including the 1997 Residential Energy Consumption Survey (RECS).13 DOE recently updated the number of cycles per year to 185 based on the 2015 RECS.