Way to make the assumption I'm running small loads on Powerblast (Pots and Pans Cycle).
This isn't a normal occurrence for us. Typically the machine is run full. This was an urgent situation where we were doing a lot of cooking for the day ahead and needed everything.
12- 20 gallons of water are for heavy soils. Light wash cycles have always used less even before energy regs.
The Whirlpool power clean module's light was cycle did not even need 6 gallons, it just used 4.8 gallons of water.
If people are running small or lightly soiled loads on normal or heavy wash that would be their doing, the rest of us don't and should not be punished with energy regs that won't stop a loony person from placing two forks on soak and scour.
I always overlap. I can get twice the dishes in my Maytag and KitchenAid dishwashers as Tony. He'll say it's full. I'll go rearrange and say it isn't. I know where the water is going and what needs to go where. I put skillets in the top racks and he won't.