2009-11-12 Public comment supporting the regulation of microwave energy consumption

I would like to voice my support for DOE’s conclusion that regulating energy consumption by microwaves in standby mode can result in significant energy savings. I would, however, question the conclusion that it is not technically feasible to combine energy consumption figures from “cooking” mode and “standby” mode into a single metric that represents overall energy consumption. I agree with DOE that the 12 hour duration testing is appropriate for standby mode and do not question the existing testing procedure for cooking mode. My opinion, however, is that rather than using two testing procedures and coming up with two separate numbers, it would be more effective to use two testing procedures and a simple mathematic equation to come up with on overall figure that represents total energy consumption. Energy consumption in standby mode is still relatively minor, but perhaps there would be more incentive to reduce the use if that use was a figure in the overall energy consumption tally. The end goal should be to encourage manufacturers to create a true “off mode” that would eliminate all energy consumption when the appliance is not being used for cooking. I believe that creating a single numeric is an essential step toward this goal.