CFA joined Appliance Standards Awareness Project (ASAP), American Council for an Energy-Efficient Economy (ACEEE), and the Natural Resources Defense Council (NRDC) in responding to the notice of data availability (NODA) for residential clothes washer standards. We support DOE’s approach presented in the NODA to develop a more robust translation of clothes washer energy and water usage metrics. Specifically, we support the approach of developing translations and resulting efficiency levels based on adjusted remaining moisture content (RMC). DOE’s preliminary analysis for RCWs suggests that drying energy usage represents 75-83% of total energy usage.2 Thus, changes in drying energy estimates, calculated from measured RMC, can have a significant impact on overall energy usage and resulting efficiency ratings.