CFA and other advocates submitted comments to DOE’s in response to the release of the preliminary technical support document for residential clothes washers. DOE’s preliminary analysis shows that amended efficiency standards for residential clothes washers could net nearly 3 quads of energy savings and would be cost-effective for purchasers. We support DOE’s overall approach to this rulemaking analysis but believe there are several issues that should be addressed. First, we encourage DOE to investigate the correlation between capacity and efficiency for the new proposed energy and water usage metrics. Second, we believe that DOE is underestimating both water heating and drying energy usage. Third, we encourage DOE to analyze higher efficiency levels (ELs) for the top-loading, compact product class. Finally, we encourage DOE to more rigorously model market shifts under standards implementations.