Proposed Rule: Consumer Products Energy Conservation Program: Energy Conservation Standards&#8212 Dishwashers, Dehumidifiers, Electric and Gas Kitchen Ranges and Ovens and Commercial Clothes Washers

Thursday,
November 15, 2007
Part IV
Department of
Energy
Office of Energy Efficiency and
Renewable Energy
10 CFR Parts 430 and 431

Energy Conservation Program: Energy
Conservation Standards for Certain
Consumer Products (Dishwashers,
Dehumidifiers, Electric and Gas Kitchen
Ranges and Ovens, and Microwave
Ovens) and for Certain Commercial and
Industrial Equipment (Commercial
Clothes Washers); Proposed Rule
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64432 Federal Register / Vol. 72, No. 220 / Thursday, November 15, 2007 / Proposed Rules
DEPARTMENT OF ENERGY Any comments submitted must Regarding the public meeting, Brenda
identify the ANOPR for Home Edwards-Jones, U.S. Department of
Office of Energy Efficiency and Appliance Products, and provide the Energy, Building Technologies Program,
Renewable Energy docket number EE–2006–STD–0127 Room 1J–018, 1000 Independence
and/or Regulatory Information Number Avenue, SW., Washington, DC 20585.
10 CFR Parts 430 and 431 (RIN) 1904–AB49. Comments may be Telephone: (202) 586–2945. E-mail:
[Docket No. EE–2006–STD–0127]
submitted using any of the following Brenda.Edwards-Jones@ee.doe.gov.
methods: SUPPLEMENTARY INFORMATION:
RIN 1904–AB49 • Federal eRulemaking Portal: http:// I. Introduction
www.regulations.gov. Follow the A. Purpose of the Advance Notice of
Energy Conservation Program: Energy instructions for submitting comments. Proposed Rulemaking
Conservation Standards for Certain • E-mail: home_ B. Overview of the Analyses Performed
Consumer Products (Dishwashers, appliance.rulemaking@ee.doe.gov. 1. Engineering Analysis
Dehumidifiers, Electric and Gas Include the docket number EE–2006– 2. Energy and Water Use Characterization
Kitchen Ranges and Ovens, and 3. Markups to Determine Equipment Price
STD–0127 and/or RIN 1904–AB49 in 4. Life-Cycle Cost and Payback Period
Microwave Ovens) and for Certain the subject line of the message. Analyses
Commercial and Industrial Equipment • Mail: Ms. Brenda Edwards-Jones, 5. National Impact Analysis
(Commercial Clothes Washers) U.S. Department of Energy, Building C. Authority
Technologies Program, Mailstop EE–2J, D. Background
AGENCY: Office of Energy Efficiency and
1000 Independence Avenue, SW., 1. History of Standards Rulemaking for
Renewable Energy, Department of Residential Dishwashers, Dehumidifiers,
Washington, DC 20585–0121. Please
Energy. and Cooking Products; and Commercial
submit one signed paper original.
ACTION: Advance notice of proposed • Hand Delivery/Courier: Ms. Brenda Clothes Washers
rulemaking and notice of public 2. Current Rulemaking Process
Edwards-Jones, U.S. Department of
meeting. 3. Analysis Process
Energy, Building Technologies Program, 4. Miscellaneous Rulemaking Issues
Room 1J–018, 1000 Independence a. Joint Stakeholder Recommendations
SUMMARY: The Energy Policy and
Avenue, SW., Washington, DC 20585. b. Standby Power for Dishwashers and
Conservation Act (EPCA or the Act)
Telephone: (202) 586–2945. Please Cooking Products
authorizes the Department of Energy 5. Test Procedures
submit one signed paper original.
(DOE) to establish energy conservation For detailed instructions on II. Analyses for the Four Appliance Products
standards for various consumer submitting comments and additional A. Market and Technology Assessment
products and commercial and industrial information on the rulemaking process, 1. Product Classes
equipment—including residential see section IV of this document (Public a. Dishwashers
dishwashers, dehumidifiers, and b. Dehumidifiers
Participation). c. Cooking Products
electric and gas kitchen ranges and Docket: For access to the docket to d. Commercial Clothes Washers
ovens and microwave ovens (hereafter read background documents or 2. Market Assessment
referred to as ‘‘cooking products’’), as comments received, visit the U.S. 3. Technology Assessment
well as commercial clothes washers—if Department of Energy, Forrestal a. Dishwashers
DOE determines that energy Building, Room 1J–018 (Resource Room b. Dehumidifiers
conservation standards would be of the Building Technologies Program), c. Cooking Products
technologically feasible and 1000 Independence Avenue, SW., d. Commercial Clothes Washers
economically justified, and would result B. Screening Analysis
Washington, DC, (202) 586–2945, 1. Purpose
in significant energy savings. DOE is between 9 a.m. and 4 p.m., Monday a. Technological Feasibility
publishing this advance notice of through Friday, except Federal holidays. b. Practicability To Manufacture, Install,
proposed rulemaking (ANOPR) to Please call Ms. Brenda Edwards-Jones at and Service
consider establishing energy the above telephone number for c. Adverse Impacts on Product Utility or
conservation standards for these additional information regarding Product Availability
products and to announce a public visiting the Resource Room. Please note: d. Adverse Impacts on Health or Safety
meeting to receive comments on a 2. Design Options
DOE’s Freedom of Information Reading
variety of issues. a. Dishwashers
Room (Room 1E–190 at the Forrestal b. Dehumidifiers
DATES: DOE will hold a public meeting Building) no longer houses rulemaking c. Cooking Products
on December 13, 2007, starting at 9 a.m. materials. 1. Cooktops and Ovens
in Washington, DC. DOE must receive FOR FURTHER INFORMATION CONTACT: 2. Microwave Ovens
requests to speak at the public meeting Stephen Witkowski, U.S. Department of d. Commercial Clothes Washers
no later than 4 p.m., November 29, Energy, Office of Energy Efficiency and C. Engineering Analysis
2007. DOE must receive a signed 1. Approach
Renewable Energy, Building
original and an electronic copy of 2. Technologies Unable To Be Included in
Technologies, EE–2J, 1000 the Engineering Analysis
statements to be given at the public Independence Avenue, SW., 3. Product Classes, Baseline Models, and
meeting no later than 4 p.m., December Washington, DC 20585–0121, (202) 586– Efficiency Levels Analyzed
6, 2007. 7463. E-mail: stephen.witkowski a. Dishwashers
DOE will accept comments, data, and @ee.doe.gov. b. Dehumidifiers
information regarding the ANOPR Francine Pinto or Eric Stas, U.S. c. Cooking Products
before or after the public meeting, but Department of Energy, Office of the d. Commercial Clothes Washers
no later than January 29, 2008. See General Counsel, Forrestal Building, 4. Cost-Efficiency Results
section IV, ‘‘Public Participation,’’ of a. Dishwashers
Mail Station GC–72, 1000 Independence b. Dehumidifiers
this ANOPR for details. Avenue, SW., Washington, DC, 20585. c. Cooking Products
ADDRESSES: The public meeting will be Telephone: (202) 586–9507. E-mail: d. Commercial Clothes Washers
held at the Holiday Inn Capital, 550 C Francine.Pinto@hq.doe.gov or D. Energy Use and End-Use Load
Street, SW., DC 20024. Eric.Stas@hq.doe.gov. Characterization
Federal Register / Vol. 72, No. 220 / Thursday, November 15, 2007 / Proposed Rules 64433
1. Dishwashers 1. Microwave Oven Standby Power (TSD): Energy Efficiency Standards for
2. Dehumidifiers 2. Product Classes Consumer Products and Commercial
3. Cooking Products 3. Commercial Clothes Washer Horizontal and Industrial Equipment: Residential
a. Cooktops and Ovens Axis Designs
b. Microwave Ovens 4. Compact Dishwashers Dishwashers, Dehumidifiers, And
4. Commercial Clothes Washers 5. Microwave Oven Design Options Cooking Products And Commercial
E. Markups To Determine Equipment Price 6. Technologies Unable To Be Analyzed Clothes Washers, 1 as summarized in
1. Distribution Channels and Exempted Product Classes this ANOPR (2007 TSD); and
2. Approach for Manufacturer Markups 7. Dishwasher Efficiency and Its Impact on
3. Approach for Retailer and Distributor 4. The candidate energy conservation
Cleaning Performance
Markups 8. Dehumidifier Use standard levels that DOE has developed
4. Sales Taxes 9. Commercial Clothes Washer Per-Cycle from these analyses.
5. Summary of Markups Energy Consumption
F. Rebuttable Presumption Payback Periods 10. Commercial Clothes Washer Consumer B. Overview of the Analyses Performed
G. Life-Cycle Cost and Payback Period Prices
Analyses The Energy Policy and Conservation
11. Repair and Maintenance Costs
1. Approach Taken in the Life-Cycle Cost 12. Efficiency Distributions in the Base Act (42 U.S.C. 6291 et seq.) directs DOE
Analysis Case to consider establishing or amending
2. Life-Cycle Cost Inputs 13. Commercial Clothes Washer Shipments energy conservation standards for
a. Total Installed Cost Inputs Forecasts various consumer products and
b. Operating Cost Inputs 14. Base-Case and Standards-Case commercial and industrial equipment,
c. Effective Date Forecasted Efficiencies
d. Equipment Assignment for the Base Case including the four appliance products
15. Dehumidifier Cost and Efficiency
3. Payback Period Inputs Relationships
which are the subject of this ANOPR.
4. Life-Cycle Cost and Payback Period 16. Trial Standard Levels For each of these products, DOE
Results V. Regulatory Review and Procedural conducted in-depth technical analyses
H. Shipments Analysis Requirements for this ANOPR in the following areas:
1. Shipments Model VI. Approval of the Office of the Secretary (1) Engineering, (2) energy and water
2. Data Inputs
3. Shipments Forecasts I. Introduction use characterization, (3) markups to
I. National Impact Analysis determine equipment price, (4) LCC and
1. Approach A. Purpose of the Advance Notice of PBP, (5) shipments, (6) national
2. Base Case and Standards Case Proposed Rulemaking impacts, and (7) preliminary
Forecasted Efficiencies The purpose of this ANOPR is to manufacturer impacts. The ANOPR
3. National Impact Analysis Inputs presents a discussion of the
provide interested persons with an
4. National Impact Analysis Results
J. Life-Cycle Cost Subgroup Analysis opportunity to comment on: methodologies and assumptions utilized
K. Manufacturer Impact Analysis 1. The product classes that the in these analyses. For each type of
1. Sources of Information for the Department of Energy (DOE) is planning analysis, Table I.1 identifies the sections
Manufacturer Impact Analysis to analyze in this rulemaking; in this document that contain the results
2. Industry Cash Flow Analysis 2. The analytical framework, models, of the analysis, and summarizes the
3. Manufacturer Subgroup Analysis and tools (e.g., life-cycle cost (LCC) and methodologies, key inputs, and
4. Competitive Impacts Assessment national energy savings (NES) assumptions for the analysis. DOE
5. Cumulative Regulatory Burden spreadsheets) DOE is using in
6. Preliminary Results for the Manufacturer consulted with interested parties in
performing analyses of the impacts of developing these analyses, and invites
Impact Analysis
L. Utility Impact Analysis energy conservation standards for further input from stakeholders on these
M. Employment Impact Analysis residential dishwashers, dehumidifiers, topics. Obtaining that input is the
N. Environmental Assessment cooking products, and commercial purpose of this ANOPR. Thus, it should
O. Regulatory Impact Analysis clothes washers (CCWs) (collectively be noted that the analytical results
III. Candidate Energy Conservation Standard referred to in this ANOPR as ‘‘the four presented here are subject to revision
Levels appliance products’’);
IV. Public Participation following review and input from
3. The analyses performed for the
A. Attendance at Public Meeting stakeholders and other interested
ANOPR, including in particular the
B. Procedure for Submitting Requests To parties. The final rule will contain the
results of the engineering analyses, the
Speak final analytical results.
C. Conduct of Public Meeting LCC and payback period (PBP) analyses,
D. Submission of Comments and the NES and national impact 1 To be published on the DOE Web site at:
E. Issues on Which the Department of analyses, which are presented in the http://www.eere.energy.gov/buildings/appliance
Energy Seeks Comment ANOPR Technical Support Document _standards/residential/cooking_products.html
TABLE I.1.—IN-DEPTH TECHNICAL ANALYSES CONDUCTED FOR THE ADVANCE NOTICE OF PROPOSED RULEMAKING
ANOPR section
Analysis area Methodology Key inputs Key assumptions for results
Engineering (TSD Chapter 5):

Dishwashers ................... Efficiency level approach Component cost data; Per- Analysis can be extended in Section II.C.3.
Dehumidifiers supplemented with design formance values. subsequent analyses to
option analysis. product classes and effi-
ciency levels for which the
Association of Home Appli-
ance Manufacturers
(AHAM) did not provide
data.
Cooking Products ........... ............................................... ............................................... Historical data from DOE’s
1996 analysis on residen-
tial cooking products are
still representative of cur-
rent manufacturing costs.
Commercial Clothes ............................................... ............................................... Analysis can be extended to
Washers. energy and water effi-
ciency levels for which
AHAM did not provide
data.
Energy and Water Use
Characterization
(TSD Chapter 6):
Dishwashers ................... Establish per-cycle energy Per-cycle energy and water Per-cycle water use is a di- Section II.D.1.
and water use and then use; Average annual rect function of per-cycle
multiply by annual cycles. usage of 215 cycles based energy use (based on
on DOE test procedure; AHAM data).
Variability of usage based
on Energy Information Ad-
ministration (EIA)’s Resi-
dential Energy Consump-
tion Survey (RECS).
Dehumidifiers .................. Establish daily energy use by Per-cycle energy and water Average usage of 1095 Section II.D.2.
dividing product capacity use; Average annual hours is representative of
by efficiency and then mul- usage of 1095 hours dehumidifier use.
tiply by annual hourly based on AHAM estimates;
usage. Variability of usage based
on multiple sources.
Cooking Products ........... Use recent survey data to Recent survey data from Recent survey data are indic- Section II.D.3.
estimate annual energy California and Florida—in- ative of current household
use. dicates a drop in annual cooking habits; Historical
energy use of ~40% for data from DOE’s 1996
electric and gas ranges analysis on residential
and ~15% for microwave cooking products are still
ovens relative to DOE test representative of compo-
procedure estimates; Vari- nent energy use (e.g., self-
ability of usage based on cleaning, clock, ignition).
EIA’s RECS.
Commercial Clothes Establish per-cycle energy Per-cycle energy and water Per-cycle energy use data in Section II.D.4.
Washers. and water use and then use; Average daily usage DOE’s 2000 TSD on resi-
multiply by annual cycles. of 3.4 cycles for multi-fam- dential clothes washers is
ily and 6 cycles for laun- representative of per-cycle
dromats; Variability of drying and per-cycle ma-
usage based on multiple chine energy for commer-
sources. cial washers.
Markups to Determine
Equipment Price
(TSD Chapter 7):
Dishwashers ................... Assess financial data from: Distribution channels; SEC Markups for baseline and Section II.E.
Dehumidifiers (1) U.S. Securities and Ex- reports on appliance man- more-efficient equipment
Cooking Products change Commission (SEC) ufacturers; U.S. Census are different.
Commercial Clothes reports on appliance man- Business Expenditure Sur-
Washers. ufacturers to develop man- vey; State sales taxes;
ufacturer markups and (2) Shipments to different

the U.S. Census Business States.
Expenditure Survey to de-
velop retailer and commer-
cial distributor markups.
Use markups to transform
manufacturer costs into
consumer prices.
TABLE I.1.—IN-DEPTH TECHNICAL ANALYSES CONDUCTED FOR THE ADVANCE NOTICE OF PROPOSED RULEMAKING—
Continued
ANOPR section
LCC and PBP

(TSD Chapter 8):
Dishwashers ................... Use Monte Carlo simulation Manufacturer costs; Markups Only 3% of consumers pur- II.G.4
in combination with inputs (including sales taxes); In- chase dishwashers at ex-
that are characterized with stallation costs; Annual en- isting minimum standards
probability distributions to ergy (and water) consump- (based on AHAM data);
establish a distribution of tion; Energy (and water) Standards do not impact
consumer economic im- prices and future trends; repair and maintenance
pacts (i.e., LCC savings Maintenance and repair costs; AEO2007 basis for
and PBPs) that identify the costs; Product lifetime; Dis- energy price forecasts; Av-
percent of. count rates. erage product lifetime is
12.3 years; Average dis-
count rate is 5.6%.
Dehumidifiers .................. ............................................... ............................................... Approximately 30% of con-
sumers purchase dehu-
midifiers at existing min-
imum standards (based on
AHAM data); Standards do
not impact repair and
maintenance costs; Annual
Energy Outlook (AEO)
2007 basis for energy price
forecasts; Average product
lifetime is 11 years; Aver-
age discount rate is 5.6%.
Cooking Products ........... ............................................... ............................................... For gas ranges, only 18 per-
cent of consumers pur-
chase equipment with
standing pilots; For electric
cooking products and
microwave ovens, 100 per-
cent of consumer purchase
equipment at baseline lev-
els; Average product life-
time is 19 years for electric
and gas ranges and 9
years for microwave
ovens; Standards do not
impact repair and mainte-
nance costs; AEO2007
basis for energy price fore-
casts; Average discount
rate is 5.6%.
Commercial Clothes ............................................... ............................................... Approximately 80 percent of
Washers. consumers purchase
equipment at existing min-
imum standards (based on
AHAM data); Standards do
not impact repair and
maintenance costs;
AEO2007 basis for energy
price forecasts; Average
product lifetime is 7.1 or
11.3 years depending on
product application; Dis-
count rate can be esti-
mated by company-weight-
ed average cost of capital.
Shipments (TSD Chapter 9):
TABLE I.1.—IN-DEPTH TECHNICAL ANALYSES CONDUCTED FOR THE ADVANCE NOTICE OF PROPOSED RULEMAKING—
Continued
ANOPR section
Dishwashers ................... Forecast shipments through Historical shipments (for cali- Market segments are: new II.H.3.
Dehumidifiers the use of a product stock bration purposes); Histor- construction, replacements,
Cooking Products accounting model by divid- ical product saturations; and first-time owners (ex-
Commercial Clothes ing market into seg- New construction fore- isting households without
Washers. ments—e.g., new construc- casts; Survival functions the product); Sensitivity to
tion, replacements, and (based on product life- ‘relative price’ is low.
early replacements, or first- times); Sensitivity to ‘rel- Market segments are: re-
time owners; Use in- ative price,’ i.e., sensitivity placements and first-time
creases in purchase price to the combined effect of owners; Sensitivity to ‘rel-
and savings in operating purchase price increases, ative price’ is low.
costs to forecast the im- operating cost savings, Market segments are: new
pact of standards on ship- and household income. construction, replacements,
ments. and early replacements;
Sensitivity to ‘relative price’
is low.
Market segments are: new
construction and replace-
ments; New construction
shipments driven by multi-
family housing market only;
Sensitivity to ‘relative price’
is low.
National Impacts
(TSD Chapter 10):
Dishwashers ................... Forecast national annual en- Annual forecasted shipments; Annual shipments from ship- Section II.I.4.
Dehumidifiers ergy (and water) use, na- Forecasted base case and ments model; Forecasted
Cooking Products tional annual equipment standards case effi- base case and standards
Commercial Clothes costs, and national annual ciencies; Per-unit annual case efficiencies remain
Washers. operating cost savings. energy (and water) con- frozen at levels in the year
sumption, Per-unit total in- 2012; National Energy
stalled costs; Per-unit op- Modeling System (NEMS)
erating costs; Site-to- basis for site-to-source
source conversion factors conversion factors; Dis-
for electricity and natural count rates are 3 percent
gas; Discount rates; Effec- and 7 percent real based
tive date of standard; and on Office of Management
Present year. and Budget (OMB) guide-
lines; Future costs dis-
counted to present year:
2007.
1. Engineering Analysis estimates their manufacturing cost, after in the 2007 TSD for this rulemaking, as
The engineering analysis establishes which, DOE estimates the incremental discussed below. Some stakeholders
the relationship between the cost and manufacturing costs for producing more provided comments to DOE that the
efficiency of a product DOE is efficient equipment. design options and associated efficiency
evaluating for standards. This For dishwashers, dehumidifiers, and increments were still valid for cooking
relationship serves as the basis for cost CCWs, the engineering analysis uses products other than microwave ovens.
and benefit calculations for individual industry-supplied cost-efficiency data, For microwave ovens, DOE analyzed
consumers, manufacturers, and the which are based on an efficiency-level current efficiency data to validate the
Nation. The engineering analysis approach (which calculates the relative efficiency increments specified in the
identifies representative baseline costs of achieving increases in energy 1996 technical analysis, after which it
equipment, which is the starting point efficiency levels), and cost-efficiency was determined that no changes to those
for analyzing technologies that provide curves that DOE derived based on a increments were necessary. To
energy efficiency improvements. design-option approach (which determine manufacturing cost
Baseline equipment here refers to a calculates the incremental costs of increments, DOE, with the concurrence
model or models having features and adding specific design options to a of manufacturers, used producer price
technologies typically found in baseline model). For kitchen ranges and index (PPI) data from the Bureau of
equipment currently offered for sale. ovens (including microwave ovens), Labor Statistics (BLS) to scale costs
The baseline model in each product DOE established cost-efficiency curves identified in the 1996 analysis to 2006$.
class represents the characteristics of using its 1996 Technical Support Section II.C on the engineering analysis
products in that class, and, for products Document for Residential Cooking discusses this cost-efficiency
already subject to energy conservation Products,2 updated to the present time relationship, as well as the product
standards, usually is a model that just
meets the current standard. After 2 Available online at DOE’s website: http:// appliance_standards/residential/
identifying the baseline models, DOE www.eere.energy.gov/buildings/ cooking_products_0998_r.html.
classes analyzed, the representative the distribution channels, and (3) the energy-efficiency standards with the
baseline units, and the methodology to existence and magnitude of differences LCCs of the products likely to be
be used to extend the analysis to between markups for baseline installed in the absence of standards.
product classes for which DOE did not equipment (‘‘baseline markups’’) and for DOE determines LCCs by considering:
receive data more-efficient equipment (‘‘incremental (1) Total installed cost to the purchaser
markups’’). DOE calculates both overall (which consists of manufacturer costs,
2. Energy and Water Use
baseline and overall incremental sales taxes, distribution chain markups,
Characterization
markups based on the product markups and installation cost); (2) the operating
The energy use and water at each step in the distribution channel. expenses of the product (determined by
characterization provides estimates of It defines the overall baseline markup as energy and water use, energy and water
annual energy and water consumption the ratio of consumer price (not
for the four appliance products, which prices, and repair and maintenance
including sales tax) and manufacturer costs); (3) product lifetime; and (4) a
DOE uses in the subsequent LCC and cost for baseline equipment; the overall
PBP analyses and the national impact discount rate that reflects the real
incremental markup relates the change
analysis (NIA). DOE developed energy consumer cost of capital and puts the
in the manufacturer sales price of
consumption estimates for all of the higher-efficiency models (the LCC in present value terms.
product classes analyzed in the incremental cost increase) to the change The PBP represents the number of
engineering analysis, as the basis for its in the retailer or distributor sales price. years needed to recover the increase in
energy and water use estimates. In the DOE determined manufacturer markups purchase price (including the
case of dishwashers, DOE used the through the use of U.S. Securities and incremental installation cost) of more-
annual usage (in cycles per year) Exchange Commission (SEC) reports on efficient equipment through savings in
established in its test procedure to appliance manufacturers, and used U.S. the operating cost of the product. It is
estimate the product’s annual energy Census Business Expenditure Surveys to the change in total installed cost due to
and water use. For dehumidifiers, DOE develop retailer and commercial increased efficiency divided by the
relied on industry-supplied estimates of distributor markups. DOE collected change in annual operating cost from
annual usage (in hours per year) to consumer retail prices for each of the increased efficiency.
estimate the product’s annual energy four appliance products to provide a
use. For kitchen ranges and ovens, the rough validation of its markups for 5. National Impact Analysis
2004 California Residential Appliance baseline equipment. Baseline equipment
Saturation Study (CA RASS) 3 and a is produced in large volumes, is not The NIA estimates both the national
year-long monitoring study conducted heavily laden with consumer features, energy savings (NES) and the net
in 1999 by the Florida Solar Energy and is typically competitively priced by present value (NPV) of total customer
Center (FSEC) 4 indicate that household retailers and distributors; therefore, costs and savings expected to result
cooking has continued to drop since the collected retail prices of baseline from new standards at specific
mid-1990s; DOE used these surveys as equipment are likely to reflect the actual efficiency levels (referred to as
the basis for estimating product annual cost of producing and selling candidate standard levels). In
energy use. For CCWs, DOE used minimally-compliant products. conducting the NIA, DOE calculated
industry-sponsored research to estimate Because DOE’s approach for NES and NPV for any given candidate
the product’s annual energy and water calculating baseline retail prices standard level for each of the four
use. For further details on the CCW through the use of manufacturing costs, appliance products as the difference
estimates, see section II.D.4 of this baseline markups, and sales taxes are between a base case forecast (without
ANOPR. intended to capture only the cost of new standards) and the standards case
producing minimally-compliant forecast (with standards). DOE
3. Markups to Determine Equipment
equipment, any collected baseline retail determined national annual energy
Price
prices serve as a good check on the consumption by multiplying the
DOE derives consumer prices for prices calculated through the markup number of units in use (by vintage 5) by
products based on manufacturer approach. But because more-efficient the average unit energy (and water)
markups, retailer markups (for equipment often includes non-energy consumption (also by vintage).
residential products), distributor related features, DOE cannot rely solely Cumulative energy savings are the sum
markups (for CCWs), and sales taxes. In on collected retail prices for high-
deriving these markups, DOE has of the annual NES determined over a
efficiency products to validate the
determined: (1) The distribution specified time period, which in the NIA
prices determined through its markup
channels for product sales; (2) the approach. Current retail prices for high- consisted of the range of years for which
markup associated with each party in efficiency equipment likely reflect the the forecast was made. The national
added cost of consumer amenities that NPV is the sum over time of the
3 California Energy Commission. California
have no impact on efficiency and, discounted net savings each year, which
Statewide Residential Appliance Saturation Study, therefore, mask the incremental price consists of the difference between total
June 2004. Prepared for the California Energy operating cost savings and increases in
Commission by KEMA–XENERY, Itron, and associated with features that only affect
RoperASW. Contract No. 400–04–009. http:// product efficiency. total installed costs. Critical inputs to
www.energy.ca.gov/appliances/rass/index.html. this analysis include shipments
4 Parker, D. S. Research Highlights from a Large 4. Life-Cycle Cost and Payback Period projections, retirement rates (based on
Scale Residential Monitoring Study in a Hot Analyses estimated product or equipment
Climate. Proceeding of International Symposium on

Highly Efficient Use of Energy and Reduction of its
The LCC and PBP analyses determine lifetimes), and estimates of changes in
Environmental Impact, January 2002. Japan Society the economic impact of potential shipments and retirement rates in
for the Promotion of Science Research for the standards on individual consumers. The response to changes in product or
Future Program, Osaka, Japan. JPS–RFTF97P01002: LCC is the total consumer expense for equipment costs due to standards.
pp. 108–116. Also published as FSEC–PF369–02,
Florida Solar Energy Center, Cocoa, FL. http://
a product over the life of the product.
www.fsec.ucf.edu/en/publications/html/FSEC-PF– The LCC analysis compares the LCCs of 5 The term ‘‘vintage’’ refers to the age of the unit
369–02/index.htm. products designed to meet possible in years.
C. Authority expenses for the covered products must become effective by October 1,
Part B of Title III of EPCA established which are likely to result from the 2012. (Id.) In the event that DOE fails to
the energy conservation program for imposition of the standard; publish such a final rule, the EPACT
consumer products other than 3. The total projected amount of 2005 specifies a new set of amended
automobiles, including dishwashers and energy, or as applicable, water, savings standards with an effective date of
electric and gas kitchen ranges and likely to result directly from the October 1, 2012. (Id.)
imposition of the standard; As with dishwashers, NAECA
ovens (which include microwave
4. Any lessening of the utility or the amended EPCA to establish prescriptive
ovens). (This ANOPR refers to electric
performance of the covered products standards for cooking products,
and gas kitchen ranges and ovens and
likely to result from the imposition of requiring gas ranges and ovens with an
microwave ovens collectively as
the standard; electrical supply cord that are
‘‘cooking products.’’) Amendments to
5. The impact of any lessening of manufactured on or after January 1,
EPCA in the National Appliance Energy
competition, as determined in writing 1990 not to be equipped with a constant
Conservation Act of 1987 (Pub. L. 100– burning pilot, and requiring DOE to
12; NAECA) established energy by the Attorney General, that is likely to
result from the imposition of the conduct two cycles of rulemakings for
conservation standards for dishwashers ranges and ovens to determine if the
and cooking products, as well as standard;
6. The need for national energy and standards established should be
requirements for determining whether amended. (42 U.S.C. 6295 (h)(1)–(2))
water conservation; and
these standards should be amended. DOE initially analyzed standards for
7. Other factors the Secretary of
(See 42 U.S.C. 6295(g) and (h), cooking products as part of an eight-
Energy (Secretary) considers relevant.
respectively) Subsequent amendments product standards rulemaking. It issued
(42 U.S.C. 6295(o)(2)(B)(i); 42 U.S.C.
expanded Title III of EPCA to include a notice of proposed rulemaking (NOPR)
6316(a))
additional consumer products and on March 4, 1994, proposing
certain commercial and industrial D. Background performance standards for gas and
equipment, including dehumidifiers electric residential cooking products,
1. History of Standards Rulemaking for
and CCWs. In particular, sections including microwave ovens (59 FR
Residential Dishwashers,
135(c)(4) and 136(e) of the Energy Policy 10464). In accordance with the Process
Dehumidifiers, and Cooking Products;
Act of 2005, Public Law 109–58; Rule, DOE refined its standards analysis
and Commercial Clothes Washers
(EPACT 2005) amended EPCA to for cooking products. For gas cooking
authorize DOE to consider the need to For dishwashers, NAECA amended products, DOE focused on the economic
modify the energy conservation EPCA to establish prescriptive justification for eliminating constant
standards that the Act, as amended, standards, requiring that dishwashers be burning pilots. Partially due to the
prescribed for dehumidifiers (42 U.S.C. equipped with an option to dry without difficulty of conclusively demonstrating
6295(cc)) and for CCWs (42 U.S.C. heat, and further requiring that DOE that elimination of constant burning
6313(e)), respectively. This includes conduct two cycles of rulemakings to pilots was economically justified for gas
authority for DOE to amend the water determine if more stringent standards cooking products without an electrical
efficiency standard the Act, as amended, are justified. (42 U.S.C. 6295 (g)(1) and supply cord, DOE issued a final rule on
prescribes for commercial clothes (4)) On May 14, 1991, DOE issued a September 8, 1998, that covered only
washers. final rule establishing the first set of electric cooking products, including
Before DOE prescribes any new or performance standards for dishwashers microwave ovens (63 FR 48038). The
amended standard for any of the four (56 FR 22250); the new standards final rule found that no standards were
appliance products, however, it must became effective on May 14, 1994 (10 justified for electric cooking products.
first solicit comments on a proposed CFR 430.32(f)). DOE initiated a second DOE never completed its standards
standard. Moreover, DOE must design standards rulemaking for dishwashers rulemaking for gas cooking products.
each new or amended standard for these by issuing an ANOPR on November 14, Similar to dehumidifiers, EPACT
products to achieve the maximum 1994 (59 FR 56423). However, as a 2005 included amendments to EPCA
improvement in energy efficiency that is result of the priority-setting process that added CCWs as covered equipment,
technologically feasible and outlined in its Procedures for and it also established standards for
economically justified, and such a Consideration of New or Revised Energy such equipment that is manufactured on
standard must also result in significant Conservation Standards for Consumer or after January 1, 2007. (EPACT 2005,
conservation of energy. (42 U.S.C. Products (the ‘‘Process Rule’’) (61 FR section 136(a) and (e); 42 U.S.C. 6311(1)
6295(o)(2)(A) and (o)(3); 42 U.S.C. 36974 (July 15, 1996); 10 CFR part 430, and 6313(e)) DOE has incorporated
6316(a)) To determine whether a Subpart C, Appendix A), DOE these standards into its regulations (70
proposed standard is economically suspended the standards rulemaking for FR 60407, 60416 (October 18, 2005); 10
justified, DOE must, after receiving dishwashers. CFR 431.156). EPACT 2005 also requires
comments on the proposed standard, Section 135(c)(4) of EPACT 2005 that DOE issue a final rule by January
determine whether the benefits of the added dehumidifiers as products 1, 2010, to determine whether these
standard exceed its burdens to the covered under EPCA and established standards should be amended. (EPACT
greatest extent practicable, weighing the standards for them that will become 2005, section 136(e); 42 U.S.C. 6313(e))
following seven factors: effective on October 1, 2007. (42 U.S.C.
1. The economic impact of the 6295(cc)) DOE has incorporated these 2. Current Rulemaking Process
standard on manufacturers and standards into its regulations (70 FR To initiate the current rulemaking to
consumers of products subject to the 60407, 60414 (October 18, 2005); 10 develop standards for the four appliance
standard; CFR 430.32(v)). The amendments to products, on March 15, 2006, DOE
2. The savings in operating costs EPCA also require that DOE issue a final published on its Web site the
throughout the estimated average life of rule by October 1, 2009, to determine Rulemaking Framework for Commercial
the covered products in the type (or whether these standards should be Clothes Washers and Residential
class) compared to any increase in the amended. (42 U.S.C. 6295(cc)) If Dishwashers, Dehumidifiers, and
price, initial charges, or maintenance amended standards are justified, they Cooking Products (the Framework
Document). The Framework Document proposed approaches for specifying Crystal Ball (a commercially available
describes the procedural and analytic typical annual energy and water software program) to generate a Monte
approaches DOE anticipates using to consumption for all four products; (12) Carlo simulation, which incorporates
evaluate the establishment of energy potential data sources for characterizing uncertainty and variability
conservation standards for these variability in annual energy and water considerations. The second tool (the
products. This document is available at: consumption; (13) typical distribution NIA spreadsheet tool) calculates the
http://www.eere.energy.gov/buildings/ channels and markups for all four impacts of candidate standards at
appliance_standards/pdfs/ appliance products; (14) data sources for various levels on shipments and
home_appl_framework_31506.pdf. retail prices; (15) type of approach to calculates the NES and NPV at various
DOE subsequently published a notice employ for the LCC and PBP analyses; candidate standard levels. There are five
announcing the availability of the (16) variability of forecasted energy and NIA spreadsheets, one each for the
Framework Document, inviting written water prices; (17) repair, maintenance, following products and combinations of
public comments to be submitted by and installation cost relationship to products: (1) Dishwashers, (2)
May 11, 2006, and announcing a public product efficiency; (18) product dehumidifiers, (3) cooktops and ovens,
meeting to discuss the proposed lifetimes; (19) development of consumer (4) microwave ovens, and (5) CCWs.
analytical framework for this discount rates; (20) purchase price DOE posted these spreadsheets on its
rulemaking (71 FR 15059 (March 27, impacts on product shipments; (21) Web site on December 4, 2006, for early
2006)). At the April 27, 2006 public forecasted saturation rates of stakeholder review and comment.6
meeting, DOE described the different commercial clothes washers; (22) Comments received since publication
analyses it would conduct, such as the consumer subgroups; (23) water and of the Framework Document have
LCC and PBP analyses, the methods wastewater utility impacts; and (24) helped identify issues involved in this
proposed for conducting them, and the wastewater discharge impacts. rulemaking, and have provided
relationship among the various Written comments submitted during information that has contributed to
analyses. Manufacturers, trade the Framework Document comment DOE’s proposed resolution of these
associations, environmental advocates, period elaborated on the issues raised at issues. This ANOPR quotes and
regulators, and other interested parties the meeting and also addressed other summarizes many of these public
attended the meeting. The major issues major issues, including the following: comments. A parenthetical reference at
discussed at the public meeting were: (1) Transparency of manufacturer cost the end of a quotation or paraphrase
(1) Relevance of the existing DOE test data development; (2) engineering data provides the location of the item in the
procedure for microwave ovens; (2) availability for dishwashers, kitchen public record.
baseline unit definitions for the four ranges and ovens, and CCWs; and (3)
appliance products; (3) product classes inclusion of embedded energy in 3. Analysis Process
for the four appliance products; (4) supplying water and treating Table I.2 sets forth the analyses DOE
consideration of limiting standby power wastewater. has conducted and intends to conduct
as a design option for all four appliance DOE developed two spreadsheet tools in its evaluation of standards for CCWs,
products; (5) technology options for for this rulemaking. The first tool and residential dishwashers, cooking
improving efficiency for all four calculates LCC and PBPs. There are six products, and dehumidifiers. Until
appliance products; (6) type of approach LCC spreadsheets, one each for the recently, DOE performed the
to employ for the engineering analysis; following products: (1) Dishwashers, (2) manufacturer impact analysis (MIA) in
(7) efficiency levels to consider for all dehumidifiers, (3) cooktops, (4) ovens, its entirety between the ANOPR and
four appliance products; (8) inclusion of (5) microwave ovens, and (6) CCWs. NOPR during energy conservation
a water factor for dishwashers; (9) Each of the LCC spreadsheets includes standards rulemakings. As noted in the
consideration of cleaning performance product efficiency distributions and has table, however, DOE has performed a
in setting dishwasher standards; (10) the capability to determine LCC savings preliminary MIA for this ANOPR. DOE
implications of clothes container and PBPs based on average values. The believes this change will improve the
volume on CCW efficiency; (11) spreadsheets also can be combined with rulemaking process.
TABLE I.2.—THE FOUR APPLIANCE PRODUCTS—ANALYSIS PROCESS

ANOPR NOPR Final rule
Market and technology assessment ....................................... Revised ANOPR analyses ..................................................... Revised analyses.
Screening analysis .................................................................. Life-cycle cost sub-group analysis.
Engineering analysis ............................................................... Manufacturer impact analysis.
Energy use and end-use load characterization ...................... Utility impact analysis.
Markups for equipment price determination ........................... Net national employment impacts.
Life-cycle cost and payback period analyses ......................... Environmental assessment.
Shipments analysis ................................................................. Regulatory impact analysis.
National impact analysis.
Preliminary manufacturer impact analysis.
The analyses listed in Table I.2 reflect in an effort to support groups of posted draft versions of its LCC and NIA
analyses used in the rulemaking, interested parties seeking to develop spreadsheets on its Web site. If timely
including the development of economic and present consensus new data, models, or tools that enhance
models and analytical tools. In addition, recommendations on standards, DOE the development of standards become
6 Available online at DOE’s Web site: http:// appliance_standards/residential/

www.eere.energy.gov/buildings/ cooking_products.html
available, DOE will incorporate them consumption and for gas cooktops via (Public Meeting Transcript, No. 5 at p.
into this rulemaking. the energy consumption of constant 64) ACEEE, the Association of Home
burning pilots, both of which are Appliance Manufacturers (AHAM), and
4. Miscellaneous Rulemaking Issues
incorporated into the EF calculation for Whirlpool stated that if DOE
a. Joint Stakeholder Recommendations their respective products. The incorporates standby power into the
The Edison Electric Institute (EEI) dishwasher test procedure includes a efficiency standard, it should do this
suggested that DOE should use a measurement of standby power, but through maximum annual energy usage
negotiated rulemaking process for standby energy use is not incorporated rather than a prescriptive standby power
residential dishwashers and cooking into calculated EF. The issue of whether level. These commenters argued that
equipment, because manufacturers to include standby power in the energy such an approach would allow
appear to want regulatory certainty for efficiency metrics for dishwashers and manufacturers flexibility in meeting the
these products. EEI suggested a separate cooking products was addressed in standard. (Public Meeting Transcript,
negotiated process for CCWs because several comments that DOE received. No. 5 at p. 125; AHAM, No. 14 at p. 8;
these products are designed for a The Alliance to Save Energy, American Whirlpool, No. 10 at p. 8) Whirlpool
different market. For dehumidifiers, EEI Council for an Energy-Efficient further commented that if standby
suggested DOE analyze the standards Economy (ACEEE), Appliance power is included in annual energy
identified in EPACT 2005 that are due Standards Awareness Project, Natural consumption, DOE should add 8.5
to become effective in 2012, and if they Resources Defense Council, and kilowatt-hours (kWh) to the standard,
are technically feasible, economically Northeast Energy Efficiency equating to one watt standby power per
justified, and will not reduce Partnerships (hereafter ‘‘Joint covered appliance over the course of a
competition, consider a negotiated Comment’’) stated that standby energy year. In addition, Whirlpool argued that
rulemaking so that standards can be use should be included in the analyses standby power should not be driven so
issued before the October 1, 2009 for all products, with the appropriate low that it impacts the adoption of
deadline mandated by EPACT 2005. metric for the standards being annual electronics that can shift start times to
(EEI, No. 7 at p. 2) 7 energy consumption rather than energy off-peak periods. (Whirlpool, No. 10 at
The Process Rule specifically factor. The Joint Comment stated that p. 8)
identifies ‘‘consensus proposals for new EPACT 2005 instructs DOE to consider
In response to the comments, we note
or revised standards as an effective standby power in its rulemaking for all
that the analysis DOE conducted for
mechanism for balancing the economic, products, and where significant, to
dishwashers does not explicitly
energy, and environmental interests include standby power in some fashion
consider design options to reduce
affected by standards. Thus, into the appropriate standard. The Joint
standby energy consumption. DOE
notwithstanding any other policy on Comment further stated that standby
conducted the engineering analysis to
selection of proposed standards, a energy use can be significant for clothes
capture the costs associated with
consensus recommendation on an washers, dishwashers, and microwave
improving EF only. The cost data
updated efficiency level submitted by a ovens. (Joint Comment, No. 9 at p. 2)
AHAM provided and the product
group that represents all interested For dishwashers, Potomac Resources
teardowns did not specifically account
parties will be proposed by DOE if it is Inc. (Potomac) commented that it would
for changes in standby power. The LCC
determined to meet the statutory be useful to address standby power
analysis, however, does account for
criteria.’’ (10 CFR Part 430, Appendix A directly through design options such as
standby power in the calculation of
to Subpart C, section 5(e)(2)). Therefore, the power supply. (Public Meeting
annual energy consumption. The LCC
DOE encourages the submittal of any Transcript, No. 5 at p. 61) 9 ACEEE, EEI,
assumes a baseline standby power draw
consensus proposals or joint stakeholder and Whirlpool Corporation (Whirlpool)
of two watts, totaling 17 kWh of annual
recommendations pertaining to any or agreed that standby power is important
energy consumption. DOE assumes this
all of the four appliance products. If the to include in the energy use
same consumption level at all EF
supporting analyses provided by the calculations, but EEI and Whirlpool
values. If technologies to decrease
group address all of the statutory criteria argued that individual system
standby power consumption are
and use valid economic assumptions components should not be regulated,
determined to be a significant source of
and analytical methods, DOE expects to instead stating that standby power
energy savings and are technologically
use these supporting analyses as the should be addressed for the system as a
feasible and economically justified, DOE
basis of a proposed rule. whole. (Public Meeting Transcript, No.
plans to consider standby power as part
5 at pp. 62, 64, and 66) ACEEE
b. Standby Power for Dishwashers and of an overall energy efficiency standard
commented that if standby energy use is
Cooking Products focusing on maximum annual energy
determined to be significant, then DOE’s
Standby power is currently usage, rather than a separate standby
analysis should include design options,
incorporated into the energy factor 8 power level, in order to allow
efficiency levels, or increased annual
(EF) for conventional ovens via the manufacturers maximum flexibility in
energy consumption to capture
measurement of clock power specifying features and design options
efficiency improvement opportunities.
while still remaining below a certain
7 A notation in the form ‘‘EEI, No. 7, p. 2’’ 9 A notation in the form ‘‘Public Meeting annual energy consumption level. As
identifies a written comment that DOE has received Transcript, No. 5 at p. 61’’ identifies an oral one approach, DOE tentatively believes
and has included in the docket of this rulemaking. comment that DOE received during the April 27, that a reduction in the two-watt baseline
This particular notation refers to a comment (1) by 2006, Framework public meeting and which was standby power level could be reflected
the Edison Electric Institute, (2) in document recorded in the public meeting transcript in the
number 7 in the docket of this rulemaking, and (3) docket for this rulemaking (Docket No. EE–2006–
in a corresponding reduction in annual
appearing on page 2 of document number 7. STD–0127), maintained in the Resource Room of energy usage, which could be modeled
8 Energy factor (EF) is a measure of the energy the Building Technologies Program. This particular for the purposes of this analysis as an
consumption required by the product under the notation refers to a comment (1) made during the equivalent change in EF. DOE seeks
conditions of the DOE test procedure. The units of public meeting, (2) recorded in document number
EF vary depending on the product. For example, the 5, which is the public meeting transcript that is
comment on the specification of annual
EF for dishwashers is expressed in cycles/kWh, filed in the docket of this rulemaking, and (3) which energy usage as the metric for
while the EF for dehumidifiers is in liters/kWh. appears on pages 61 of document number 5. dishwasher standards.
ACEEE commented during the analyzing microwave ovens to better measure their efficiency, as well as their
Framework public meeting that the use understand the utility, cost, and cost water use (68 FR 51887 (Aug. 29, 2003);
of standby power needs to be implications of reducing standby power 10 CFR part 430, Subpart B, Appendix
considered for all cooking products. consumption. Addition of a standby C). At this time, DOE does not expect to
(Public Meeting Transcript, No. 5 at p. power test to the existing test procedure make further changes to the dishwasher
91) AHAM recognized that standby would be necessary before standby test procedure.
power consumption is essentially power could be included in an EPACT 2005 amended EPCA to
already included in the test procedure efficiency standard. DOE intends to require that CCWs be rated according to
for ovens and cooktops; however, for modify the test procedure accordingly the same test procedures established for
microwave ovens, a test procedure because it believes that standby power residential clothes washers. (EPACT
revision would be required. (Public represents a significant portion of 2005, section 136(f); 42 U.S.C.
Meeting Transcript, No. 5 at p. 92) microwave oven annual energy usage. 6314(a)(8)) DOE adopted those test
AHAM also stated that manufacturers According to the DOE test procedure, procedures for CCWs in its final rule
(driven by consumer/market desires) the annual useful cooking energy output published on October 18, 2005 (70 FR
want the flexibility to produce of a microwave oven is 79.8 kWh. For 60407, 60416). EPACT 2005 also
microwave ovens with different a baseline microwave oven with an amended EPCA to specify that the U.S.
displays, and, thus, different levels of efficiency of 55.7 percent, annual energy Environmental Protection Agency (EPA)
standby power consumption, in order to consumption for cooking processes is test criteria used under the Energy Star
provide products with market 143.3 kWh. Each watt of standby power Program must serve as the basis for
differentiation. Therefore, AHAM represents an additional 8.76 kWh per DOE’s test procedure for dehumidifiers.
recommended that standby power not year, or 6 percent of the annual cooking (EPACT 2005, section 135(b); 42 U.S.C.
be considered as a separate prescriptive energy consumption. AHAM-supplied 6293(b)(13)) The Energy Star test criteria
requirement, but instead, if regulated, data demonstrated a wide variation in for dehumidifiers require that American
standby power should be incorporated existing standby power levels, with National Standards Institute (ANSI)/
in an annual energy consumption metric values ranging between 1.5 and 5.8 AHAM Standard DH–1–2003,
(AHAM, No. 17 at p. 4). Contrary to watts, such that the likely impact of a Dehumidifiers, be used to measure
these views, GE Consumer & Industrial standard would be significant. DOE will energy use during capacity-rating tests,
(GE) opposed incorporating standby conduct testing and teardown analysis and that the Canadian Standards
power into efficiency standards because in support of the test procedure NOPR Association (CAN/CSA) standard CAN/
that would result in a determination of to incorporate standby power. DOE CSA–C749–1994 (R2005), Performance
higher energy consumption under the plans to complete the test procedure of Dehumidifiers, be used to calculate
regulation for ‘‘intelligent’’ appliances. change prior to publishing the NOPR for the energy factor. DOE has adopted
(GE, No. 13 at p. 4) this standard-setting rulemaking. these test criteria, along with related
DOE added low-standby-power DOE specifically seeks data and definitions and tolerances, as its test
electronic controls as design options for stakeholder feedback on how to conduct procedure for dehumidifiers (71 FR
both standard and self-cleaning gas an analysis of standby power for 71340, 71347, 71366, 713667–68 (Dec.
ovens, as well as for both standard and microwave ovens. This is identified as 8, 2006); 10 CFR part 430, Subpart B,
self-cleaning electric ovens. However, it Issue 1 under ‘‘Issues on Which DOE Appendix X).
did not include these design options Seeks Comment’’ in section IV.E of this DOE received comments pertaining to
when setting overall efficiency levels for ANOPR. its test procedures for kitchen ranges
these products because DOE does not and ovens and CCWs. With regard to
5. Test Procedures
have efficiency improvement or kitchen ranges and ovens, Wolf
incremental cost information on them. A test procedure outlines the method
Appliance Company, LLC , an affiliate
DOE is seeking data to conduct this to determine the energy efficiency and
of Sub-Zero Freezer Company, Inc.
analysis and requests stakeholder annual energy use of products and
(Wolf), and Whirlpool suggested that
comment on this issue. equipment, and it is used as the basis
DOE modify its test procedure for
AHAM provided data on microwave for representation and determination of
compliance with energy conservation residential kitchen ranges and ovens
standby power for a sample of 21
standards. Section 7(b) of the Process because it is inadequate for measuring
microwave ovens available in the U.S.
Rule provides that DOE will propose the energy use of certain product
market. For the AHAM submission,
necessary modifications to the test characteristics and features.
standby power was tested in accordance
procedures for a product before issuing Specifically, Wolf stated that the current
with International Electrotechnical
an ANOPR concerning energy test procedure does not accurately
Commission (IEC) 62301–2005,
conservation standards for that product. measure the performance and efficiency
Household electrical appliances—
Section 7(c) of the Process Rule states of several components (such as larger
Measurement of standby power. These
that DOE will issue a final modified test burner rings, heavier burner grates, and
data show a wide range of standby
procedure prior to issuing a proposed high performance convection systems).
power use. Microwave oven standby
power consumption is understood to be rule for energy conservation standards. (Wolf, No. 6 at p. 1) Whirlpool stated
a function of the digital clock display, DOE has established test procedures that the current test procedure does not
with more complex graphical displays for each of the four appliance products measure energy consumption as a
drawing more power. AHAM did not subject to today’s notice. DOE last function of oven cavity size, does not
provide the type of oven characteristics revised its test procedures for cooking address the fundamental differences in
information which could provide more products in 1997, to make several commercial-type products 10 versus
insight into the factors affecting standby revisions to more accurately measure more traditional residential cooking
power or the costs associated with the efficiency of these products (62 FR products, and does not recognize that
reducing the standby energy 51976 (Oct. 3, 1997); 10 CFR part 430, 10 Commercial-type cooktops and ovens are
consumption. Subpart B, Appendix I). Similarly, in characterized by higher burner firing rates, larger
For the NOPR analysis, DOE is 2003, DOE revised its test procedures dimensions, and heavier components than typical
considering purchasing, testing, and for dishwashers to more accurately residential cooking products.
gas surface burner efficiency is a consumer usage patterns specific to this a. Dishwashers
function of the burner rate. Whirlpool product. For dishwashers, the size of the unit
added that the microwave oven test DOE specifically seeks data and
significantly affects the amount of
procedure does not account for the stakeholder feedback on the decision to
energy consumed due to the
variation in the product’s size and retain the existing test procedures for
corresponding amount of water heating
wattage, both of which affect microwave appliances covered under this
required. In other words, standard-sized
oven energy consumption. (Whirlpool, rulemaking other than microwave
dishwashers with relatively greater
No. 10 at p. 6) With regard to CCWs, ovens. This is identified as Issue 6
water consumption have significantly
Whirlpool noted that commercial under ‘‘Issues on Which DOE Seeks
greater energy use than compact units.
laundry practices differ from the more Comment’’ in section IV.E of this
Because standard dishwashers offer
familiar residential practices in several ANOPR.
enhanced consumer utility over
key respects (e.g., the test procedure II. Analyses for the Four Appliance compact units (i.e., the ability to wash
assumes that a modest eight-pound load Products more dishes), DOE has established the
will be used, but commercial washers following product classes, which are
typically are filled with a larger load). This section addresses the analyses
DOE has performed and intends to based on the size of the dishwasher (as
(Whirlpool, No. 10 at p. 3) specified in ANSI/AHAM Standard
perform for this rulemaking. For each
In response, DOE recognizes that product covered by this rulemaking (i.e., DW–1–2005, Dishwashers):
there may be issues with its test residential dishwashers, dehumidifiers, • Compact (capacity less than eight
procedures for measuring the energy use and cooking products, and CCWs), DOE place settings plus six serving pieces);
impacts of the cooking product will perform a set of separate analyses, and
characteristics noted by Wolf and including a market and technology • Standard (capacity equal to or
Whirlpool. However, with the exception assessment, a screening analysis, an greater than eight place settings plus six
of standby power consumption for engineering analysis, an energy use and serving pieces).
microwave ovens, DOE does not intend water use characterization, LCC and AHAM and EEI both commented that
to initiate rulemakings to modify its test PBP analyses, a shipments analysis, a the two product classes are appropriate
procedures for appliances covered by NIA, and a MIA. A separate sub-section for the analysis. (Public Meeting
this rulemaking, before finalizing addresses each type of analysis, which Transcript, No. 5 at p. 55; AHAM, No.
amended energy conservation contains a general introduction that 14 at p. 8; EEI, No. 7 at p. 3) Potomac,
standards, for the reasons that follow. describes the analysis and a discussion however, suggested that the standard
DOE intends to initiate a test procedure of related comments received from product class should be disaggregated to
modification for microwave ovens to interested parties. at least several product classes based on
include standby power consumption place-setting capacity. (Public Meeting
because the data received from AHAM A. Market and Technology Assessment Transcript, No. 5 at pp. 61–62).
indicates that standby power represents When DOE begins a standards American Rivers, Association of
a significant portion of annual energy rulemaking, it develops information that Metropolitan Water Agencies, Austin
usage and because the data shows a provides an overall picture of the Water Utility, California Urban Water
wide spread in current standby power market for the products concerned, Conservation Council, East Bay
levels. DOE does not plan a test including the nature of the product, the Municipal Utility District, and Seattle
procedure change for conventional industry structure, and market Public Utilities (hereafter ‘‘Multiple
ovens because the oven test procedure characteristics for the product. This Water Organizations’’) recommended
already measures standby power in the activity consists of both quantitative and that one or more new product classes be
form of clock power and, for standard qualitative efforts based primarily on defined in addition to compact and
gas ovens, the pilot light. For cooktops, publicly available information. The standard sizes, which would allow
DOE does not believe that standby subjects addressed in the market and flexibility for manufacturers to make
power not already captured in the test technology assessment for this smaller or larger machines. According to
procedure represents a significant rulemaking include product classes, the Multiple Water Organizations,
portion of annual energy consumption. baseline units, technologies for design consumers would then be encouraged to
Gas cooktops already measure the options, manufacturers, quantities and wash full dishwasher loads rather than
energy consumption of standing pilots, types of products sold and offered for partial or multiple loads. (Multiple
which for the baseline configuration are sale, retail market trends, industry cost Water Organizations, No. 11 at p. 2)
assumed to consume 600 kWh annually structure, and regulatory and non- DOE notes that current dishwasher
and which are in addition to the annual regulatory programs. This information models include single- and two-drawer
cooking energy consumption. In serves as resource material throughout units as well as dishwashers that
comparison, each watt of standby power the rulemaking. provide a user-selectable option for
consumes 8.76 kWh annually. For upper-or lower-rack-only washing to aid
electric cooktops, DOE does not have 1. Product Classes in running optimal load sizes.
any data on standby power In general, when evaluating and Therefore, DOE believes the current two
consumption that indicate the potential establishing energy efficiency standards, product classes offer adequate flexibility
for significant energy savings. Therefore, DOE divides covered products into in terms of dishwasher loading to
a test procedure change to measure classes by: (1) The type of energy used, maintain consumer utility and wash
standby power for cooktops would not and (2) capacity or other performance- performance for different load sizes.
be warranted. With regard to CCWs, related features that affect consumer Thus, additional product classes are not
although for efficiency rating purposes utility and efficiency. Different energy warranted.
CCWs use the residential clothes washer conservation standards may apply to
test procedure, DOE’s methods for different product classes. The following b. Dehumidifiers
characterizing the energy and water use describes and discusses the product EPACT 2005 sets energy conservation
for commercial washers (as described in classes DOE plans to use in this standards for dehumidifiers based on
section II.D.4) accounted for the rulemaking. the capacity of the unit as measured in
pints of water extracted per day. dehumidifier market as possible. In of factors such as the lack of an
(EPACT 2005, section 135(c); 42 U.S.C. total, DOE has disassembled and appropriate test procedure, the niche
6295(cc)) Specifically, for units analyzed 14 dehumidifiers to date. nature of those products, and the small
manufactured on or after October 1, Furthermore, DOE used market and amount of empirical data. Since these
2007, EPACT 2005 sets a separate technology assessment research and conditions still remain today, Whirlpool
standard for dehumidifiers in each of consulted with numerous stakeholders commented that DOE should not
the following five categories: (1) 25.00 to determine basline unit analyze these classes. (Whirlpool, No.
pints/day or less, (2) 25.01–35.00 pints/ characteristics. (Refer to Chapters 3 and 10 at p. 5) Wolf stated during the
day, (3) 35.01–54.00 pints/day, (4) 5 of the TSD for further details.) DOE Framework public meeting that product
54.01–74.99 pints/day, and (5) 75.00 intends to use EPACT 2005-compliant classes that were not analyzed in the
pints/day or more. (Id.) EPACT 2005 dehumidifiers as a baseline since prior rulemaking need to be considered
also prescribes more stringent energy manufacturers are already modifying in this standards rulemaking. (Public
conservation standards that would go any non-compliant product they have to Meeting Transcript, No. 5 at p. 84) DOE
into effect if DOE fails to issue amended meet this new minimum energy is not aware of any data upon which to
standards that apply to products efficiency level. determine the measurement of energy
manufactured on or after October 1, efficiency or energy efficiency
2012. (Id.) In prescribing these c. Cooking Products characteristics of products in these
standards, EPACT 2005 subdivides the For cooking products, DOE based its niche classes. Therefore, DOE will not
35.01–54.00 pints/day category into two product classes on energy source (i.e., conduct analyses on product classes
categories: 35.01–45.00 pints/day and gas or electric) and cooking method (i.e., that were identified but excluded in the
45.01–54.00 pints/day. Therefore, in cooktops, ovens, and microwave ovens). previous rulemaking. DOE seeks
accordance with EPACT 2005 DOE identified five categories of efficiency data and inputs to
amendments to EPCA, DOE is using the cooking products: characterize any limitations of the test
following product classes for • Gas cooktops; procedure for these product classes.
dehumidifiers: • Electric cooktops; This topic is identified as Issue 6 under
• 25.00 pints/day or less; • Gas ovens; ‘‘Issues on Which DOE Seeks Comment’’
• 25.01–35.00 pints/day; • Electric ovens; and in section IV.E of this ANOPR.
• 35.01–45.00 pints/day; • Microwave ovens. The single product class that DOE
• 45.01–54.00 pints/day; In its regulations implementing EPCA, proposes to use for gas cooktops is gas
• 54.01–74.99 pints/day; and DOE defines a ‘‘conventional range’’ as cooktops/conventional burners, in
• 75.00 pints/day or more. ‘‘a class of kitchen ranges and ovens accordance with the previous
During the Framework public meeting which is a household cooking appliance rulemaking.
and Framework comment period, consisting of a conventional cooking top AHAM commented that if DOE
stakeholders differed as to appropriate and one or more conventional ovens.’’ decides to proceed with further analysis
specifications for the product classes for 10 CFR 430.2. In this rulemaking, DOE of cooking products, DOE should
dehumidifiers. EEI asked whether a is not treating gas and electric ranges as include an additional product class for
distinction should be made between a distinct product category and is not high-performance, commercial-style
fixed and portable dehumidifers. (EEI, basing its product classes on that products. AHAM stated that the unique
No. 7 at p. 3) AHAM opposed EEI’s category. Because ranges consist of both utility and performance attributes
suggestions, expressing a preference for a cooktop and oven, any potential associated with high-performance
the product classes as identified in cooktop and oven standards would cooking products must be recognized
EPACT 2005. (Public Meeting apply to the individual components of and allowed to continue under the ‘‘safe
Transcript, No. 5 at p. 70; AHAM, No. the range. As a result, product classes harbor’’ provisions of NAECA, which
14 at p. 9) for ranges, for the purpose of standards- prevent Federal energy efficiency
While fixed and portable setting, are not warranted. standards from resulting in the
dehumidifiers offer different utility in This general approach for defining unavailability of product types, classes,
terms of ease of installation and product classes was validated in performance characteristics, and other
flexibility in location, DOE is unaware comments received after the Framework key aspects of the product that are
of any dehumidification performance public meeting. EEI stated that the currently available. (42 U.S.C. 6295
differences. Therefore, DOE has product classes are appropriate. (EEI, (o)(4)) Due to test procedure
determined that additional product No. 7 at p. 3) Wolf stated that the complexities and small market share,
classes are not warranted based on burden of considering new product AHAM recommends that DOE exempt
portability, and for the purpose of this classes since the previous rulemaking high-performance, commercial-style
rulemaking, DOE intends to maintain (including modification of existing test residential cooking products. (AHAM,
the dehumidifier product classes as procedures) is not justified by the small No. 14 at p. 2) DOE received additional
defined by EPACT 2005 (i.e., a ‘‘self- potential energy savings. (Wolf, No. 6 at comments specifically regarding
contained, electrically operated, and p. 2) commercial-type ranges. These
mechanically encased assembly’’). DOE also received comments during comments are discussed in the context
(EPACT 2005, section 135(a); 42 U.S.C. the Framework public meeting and of gas cooktops, although it should be
6291(34)) subsequent comment period questioning recognized that similar responses apply
DOE also received comments that whether DOE should consider for to the oven component of the range as
baseline unit characteristics for analysis product classes for cooking well. During the Framework public
dehumidifiers may not be possible to products with small shipment volumes. meeting, EEI suggested a need to
establish since EPACT 2005 will not Whirlpool noted that the rationale for establish the market share of
come into effect until October 1, 2007. excluding certain product classes from commercial-type ranges for this
DOE performed its engineering analysis analysis in the previous rulemaking rulemaking. (Public Meeting Transcript,
across a wide range of unit capacities (e.g., grills, griddles, induction No. 5 at p. 81) Both AHAM and Wolf
and efficiencies to capture as complete cooktops, and warming/simmering stated that commercial-type ranges
a picture of the 25–75 pints/day burners) was based upon consideration warrant a separate product class. (Public
Meeting Transcript, No. 5 at pp. 84 and commercial-style cooktops. DOE seeks According to the boiling water tests
86). Wolf further elaborated in the data and inputs regarding the energy conducted in the report, the efficiency
comment period after the Framework efficiency of commerical-type cooktops of conventional burners ranged from 42
public meeting that the unique utility as well as any limitations of the test percent to 48 percent, while the sealed
and performance attributes of procedure for this product class. This burner was rated at an efficiency of 53
commercial-type ranges (explained topic is identified as Issue 6 under percent. Commenters have not provided
below) justify a separate product class. ‘‘Issues on Which DOE Seeks Comment’’ data showing the correlation of boiling
(Wolf, No. 6 at p. 1) DOE considers in section IV.E of this ANOPR. water tests with efficiency testing
commercial-style ranges to be those Whirlpool and AHAM commented according to the DOE test procedure, as
products which incorporate gas that DOE should add sealed gas burners would render the IGRC report
cooktops with higher input rate burners as a separate product class. (Public inapplicable. Accordingly, without clear
(i.e., greater than 14,000 Btu/h) and Meeting Transcript, No. 5 at pp. 82 and indication that the performance of
heavy-duty grates that provide faster 85) Whirlpool stated that the added sealed burners is sufficiently distinct
cooking and the ability to cook larger utility of sealed burners based upon the from that of conventional open gas
quantities of food in larger cooking ease of consumer cleaning justifies this burners, DOE will retain the single
vessels. The burners are optimized for distinction. In addition, the increasing product class for gas cooktops and
the larger-scale cookware to maintain firing rates of sealed burners since the consider sealed burners as a design
high cooking performance. Similarly, previous rulemaking coupled with the option within that class.
DOE considers commercial-style ovens necessary grate height increase to The American Gas Association (AGA)
to have higher input rates (i.e., greater achieve proper combustion make sealed also proposed two product classes for
than 22,500 Btu/h) and dimensions to burners less efficient than open burners. gas cooktops, differentiated by the
accommodate larger cooking utensils or Whirlpool cited the 1983 International method of heat transfer associated with
greater quantity of food items, as well as Gas Research Conference (IGRC)11 the burners. The two product classes
features to optimize cooking report that claimed an efficiency suggested by the AGA would consist of
performance. GE stated that reduction associated with sealed direct-flame contact burners that
commercial-type products should be burners. In Whirlpool’s opinion, the provide conductive heat transfer and
exempt from regulation due to their boiling water tests upon which this other burner types that employ
unique utility and cost, but if they are conclusion was based represented an convective and radiant heat transfer.
regulated, they should be categorized inappropriate metric, and any efficiency (AGA, No. 12 at p. 2) DOE believes that
into a separate product class. (GE, No. determination for sealed burners must the method of heat transfer does not
13 at p. 2) Whirlpool commented that, be based on the DOE test procedure. For provide any unique utility, nor are there
although shipments of commercial-type these reasons, Whirlpool recommended data available that characterize
products have increased since the prior development of a separate product class substantially different performance
rulemaking, they still remain a niche for sealed burners. (Public Meeting based on heat transfer means. Thus,
product. Whirlpool shared GE’s position Transcript, No. 5 at pp. 82–83 and 88) DOE will retain a single product class
that these products should be exempt AHAM stated that gas sealed burners for gas cooktops.
For electric cooktops, DOE
from regulation, particularly since there should be considered as a separate
determined that the ease of cleaning
is a lack of efficiency data available and product class within gas cooktops
smooth elements means that they have
there is little potential for meaningful because changes are required to provide
greater utility to the consumer than coil
energy savings. (Whirlpool, No. 10 at p. appropriate amounts of primary and
elements. Because smooth elements
6) secondary air for proper combustion, typically use more energy than coil
After considering stakeholder which inherently affects energy elements, DOE has defined the
comments, DOE has tentatively decided efficiency. (AHAM, No. 14 at p. 2) following product classes for electric
to exclude high-performance, DOE has observed that there are cooktops:
commercial-style gas cooktops conflicting data on the impacts of sealed • Electric cooktop/low or high
(including the cooktop component of burners on energy efficiency wattage open (coil) elements; and
commercial-style ranges) from the measurements. In the previous • Electric cooktop/smooth elements.
energy efficiency standard due to the rulemaking, AHAM had stated that AHAM stated that if DOE decides to
lack of available data for determining sealed burners often have a lower gas proceed with further analysis of cooking
efficiency characteristics of those input rating than conventional burners products, DOE should include an
products. In addition, the test procedure due to the reduction in secondary air. additional product class for induction
for gas cooktops is based on measuring The sealed burner must obtain all of its cooktops. AHAM commented the utility
temperature rise in an aluminum block secondary air from air that is available and performance attributes associated
with a diameter dictated by the firing above the cooktop. To obtain sufficient with high-performance cooking
rate of the burner. The maximum air for proper combustion, it becomes products must be recognized and
diameter of the test block is sufficient to necessary to either raise the grate height allowed to continue under the safe
measure higher output residential-scale or to derate the burner. The IGRC report, harbor provisions of NAECA. Due to test
burners. For commercial-type burners however, states that the reduction in procedure complexities, small market
that must have larger diameter burner secondary air results in more primary share, and lack of empirical data,
rings to accomplish complete aeration to the sealed burner. The AHAM and Whirlpool recommended
combustion, however, this maximum increased primary aeration allows for a that DOE exempt induction cooktops.
test block diameter may be too small to reduced pan-to-burner separation and Whirlpool further commented that if
achieve proper heat transfer and may increased burner efficiency. induction cooktops are analyzed, they
not be representative of the dimensions must be treated as a separate product
11 J. Flood and T. Enga, ‘‘Energy Conservation
of suitable cookware. However, DOE is class, which would entail development
‘Aspects of Cooking Appliances,’’ Proceedings of
not aware of any data to determine the the 1983 International Gas Research Conference,
of a new test procedure. (Public Meeting
measurement of energy efficiency or June 13, 1983, London, UK, pp 741–54. Available Transcript, No. 5 at p. 85; AHAM, No.
energy efficiency characteristics for online at: http://www.osti.gov/energycitations. 14 at pp. 2–4; Whirlpool, No. 10 at p.
5) During the engineering analysis market share, AHAM recommended that to be considered. However, AHAM
(Chapter 5 of the TSD) DOE determined DOE exempt high-performance, conceded that the lack of efficiency data
that induction cooktops cannot be tested commercial-style products. (Public makes it impossible to determine the
according the existing test procedure, Meeting Transcript, No. 5 at pp. 85–86; appropriate product classes at this time.
and, therefore, DOE will not consider AHAM, No. 14 at pp. 2–4) DOE (AHAM, No. 14 at p. 6) Similarly,
this technology for the ANOPR analysis. recognizes that the test procedure may Whirlpool stated that, without existing
DOE seeks efficiency data and inputs to not adequately measure performance of energy consumption standards, it does
characterize any limitations of the test commercial-style ovens. The single test not have any data to formulate
procedure for induction cooktops. This block may not adequately measure the appropriate product classes for
topic is identified as Issue 6 under temperature distribution that is inherent microwave ovens, and the company
‘‘Issues on Which DOE Seeks Comment’’ with the larger cavity volumes and commented that obtaining these data
in section IV.E of this ANOPR. higher firing rates typically found in would be costly and time consuming.
For electric ovens, DOE determined these products. DOE is not aware of any (Whirlpool, No. 10 at p. 6) After the
that the type of oven-cleaning system is data upon which to determine the Framework public meeting, AHAM
a utility feature that affects performance. measurement of energy efficiency or supplied microwave oven efficiency
DOE found that standard ovens and energy efficiency characteristics for data to DOE that failed to identify any
ovens using a catalytic continuous- commercial-style ovens, so therefore correlation between efficiency and
cleaning process use roughly the same will not conduct an analysis on this either rated output power or cavity
amount of energy. On the other hand, product class at this time. DOE seeks volume. Therefore, DOE has decided not
self-cleaning ovens use a pyrolytic data and inputs regarding the energy to define product classes as a function
process that provides enhanced efficiency of commercial-type of features such as volume or wattage,
consumer utility with different overall cooktopsstyle ovens as well as any and instead will retain the single
energy consumption, as compared to limitations of the test procedure for this product class of microwave ovens with
either standard or catalytically-lined product class. This topic is identified as or without thermal elements.
ovens, due to the amount of energy used Issue 6 under ‘‘Issues on Which DOE Comments did not strongly support
during the cleaning cycle and better Seeks Comment’’ in section IV.E of this the inclusion of microwave/thermal
insulation. Thus, DOE has defined the ANOPR. ovens in the analyses. In addition,
following product classes for electric As discussed for electric ovens, several comments used the term
ovens: AHAM and Whirlpool stated that the ‘‘combination ovens’’ to refer to not only
• Electric oven/standard oven with or ‘‘catalytic line’’ descriptor for the microwave/thermal ovens but also other
without a catalytic line; and standard gas oven product class is technologies, such as halogen bulbs. EEI
• Electric oven/self-clean oven. obsolete and should be removed. While questioned whether DOE would
AHAM concurred with this approach DOE is not aware of any gas ovens consider combination ovens for future
during the Framework public meeting, currently on the market that are analysis, referring to both microwave
stating that non-self-cleaning and self- catalytically lined, it will retain the plus thermal and microwave plus
cleaning ovens should remain as current description for completeness. convection units. (Public Meeting
separate product classes. (Public Finally, microwave ovens will Transcript, No. 5 at p. 139) GE and
Meeting Transcript, No. 5 at pp. 85–86) constitute a single product class in this AHAM both commented that the DOE
AHAM and Whirlpool both commented rulemaking. DOE did not break down test procedure is inadequate to measure
that the feature of a ‘‘catalytic line’’ is this category of cooking product into combination ovens. AHAM further
obsolete and, therefore, should be further product classes. This product stated that the small market share of
removed from the non-self-cleaning class can encompass microwave ovens combination ovens should preclude
oven product class description. (Public with and without browning (thermal) them from the analysis. (Public Meeting
Meeting Transcript, No. 5 at p. 86; elements, but does not include Transcript, No. 5 at pp. 140–141). In
Whirlpool, No. 10 at pp. 9–10) While microwave ovens that incorporate comments submitted after the
DOE is not aware of any electric ovens convection systems. DOE is unaware of Framework meeting, EEI stated that,
currently on the market that are any data evaluating the efficiency depending on market share,
catalytically lined, it will retain the characteristics of microwave ovens combination ovens could impact
current description for completeness. incorporating convection systems, so baseline energy usage. Although EEI did
For gas ovens, for the same reasons as therefore this type of unit will not be not suggest including combination
for electric ovens, DOE is using the included in the analysis. DOE seeks data ovens in the analyses, it did state that
following product classes: and inputs on the performance of DOE should ensure that any standards
• Gas oven/standard oven with or microwave ovens with convection do not eliminate these products from
without a catalytic line; and systems. This topic is identified as Issue the market. (EEI, No. 7 at p. 6)
• Gas oven/self-clean oven. 6 under ‘‘Issues on Which DOE Seeks Whirlpool, however, expressed its
AHAM stated that if DOE decides to Comment’’ in section IV.E of this opinion that combination ovens should
proceed with further analysis, DOE ANOPR. not be considered a separate product
should include additional product AHAM stated during the Framework class due to variations in design and
classes for high-performance, public meeting that additional product low market share. (Whirlpool, No. 10 at
commercial-style products, which classes for microwave ovens are needed p. 6)
include commercial-style gas ovens (i.e., that would likely be a function of DOE recognizes that the microwave
with burner firing rates greater than volume and wattage, and possibly oven test procedure can only test the
22,500 Btu/h). AHAM commented that installation configuration (i.e., counter- microwave heating function of
the utility and performance attributes top versus over-the-range ovens). microwave/thermal ovens, and that it
associated with high-performance (Public Meeting Transcript, No. 5 at pp. cannot test the browning function of the
cooking products must be recognized 86–87) In comments submitted after the radiant or halogen elements. However,
and allowed to continue under the safe Framework public meeting, AHAM such browning features are typically a
harbor provisions of NAECA. Due to test reiterated these comments and added secondary function of a microwave/
procedure complexities and small that humidity sensors would also need thermal unit, with the primary cooking
being accomplished via microwave classes in analyzing and setting rulemaking. (Joint Comment, No. 9 at p.
heating. In combination units, the standards for cooking products: 5) EEI also supported DOE’s designation
convection system performs a • Gas cooktops/conventional burners; of a single commercial clothes washer
significant portion of the cooking • Electric cooktop/low or high product class. (EEI, No. 7 at p. 3) AHAM
process, and, therefore, the inability to wattage open (coil) elements; ‘‘recommends that the Department
measure performance of the convection • Electric cooktop/smooth elements; conduct its analysis using the product
component would render the test • Gas oven/standard oven with or categories currently provided for in its
procedure inadequate. DOE has no without a catalytic line; regulations.’’ (AHAM, No. 14 at p. 7)
information that demonstates a • Gas oven/self-clean oven; The Multi-Housing Laundry Association
• Electric oven/standard oven with or (MLA) deferred to its member
difference in energy performance
without a catalytic line; manufacturers’ opinions regarding a
between microwave/thermal ovens • Electric oven/self-clean oven; and
operating in microwave mode and • Microwave oven with or without single product class. (MLA, No. 8 at p.
microwave ovens. Therefore, DOE will thermal elements. 2) All manufacturers interviewed by
include microwave ovens with thermal DOE as part of the manufacturer impact
browning elements in the single product d. Commercial Clothes Washers analysis opposed the elimination of
class. As discussed above, DOE will not EPACT 2005 amendments to EPCA vertical-axis washers, which could arise
conduct an analysis at this time of placed all CCWs in one product class as an issue if a single product class is
combination microwave ovens due to a and applied a single standard for energy analyzed. (See TSD, Chapter 12.)DOE
lack of data evaluating energy efficiency efficiency and a single standard for recognizes that, by analyzing a single
or energy efficiency characteristics of water efficiency for this equipment. product class and applying a single
microwave ovens incoporating (EPACT 2005, section 136(e); 42 U.S.C. standard for energy efficiency and a
convection systems. 6313(e)) This class encompasses both single standard for water efficiency to
DOE received several comments top-loading (vertical-axis) and front- all CCWs, absent the consideration of
regarding additional product classes for loading (horizontal-axis) units. other relevant factors, the highest
cooking products not specifically During the Framework public meeting economically justified standards could
covered in the above product classes. and Framework comment period, DOE be sufficiently stringent as to possibly
For example, EEI questioned whether received comments expressing opposing cause manufacturers to cease
outdoor natural-gas-fired or propane- viewpoints regarding the use of one or production of vertical-axis washers.
fired grills are a covered product for this two product classes for CCWs. Alliance As noted above, EPCA, as amended by
analysis, and, if so, it recommended that Laundry Systems (ALS) pressed for two EPACT 2005, applies a single standard
DOE conduct an investigation into product classes, because ALS believes for energy efficiency and a single
shipments and usage patterns. (EEI, No. that in the eyes of consumers, standard for water efficiency to all
horizontal- and vertical-axis washers CCWs. The Congress enacted a single
7 at p. 5) The test procedures
can be significantly differentiated in standard for CCWs some years after DOE
established in 10 CFR Part 430, Subpart
terms of utility and cost. (Public has established five classes for
B, Appendix I are specified for kitchen
Meeting Transcript, No. 5 at p. 42) residential clothes washers, which may
ranges and ovens. Further, the test
However, the Joint Comment argued for suggest that Congress’s initial
procedures provide for estimating
a single product class, saying that assessment was that a single class
annual operating cost for conventional
consumers only want to clean their would be most reasonable when
ranges, conventional cooking tops,
clothes and, thus, make no distinction updating these standards. The statutory
conventional ovens, microwave ovens,
between washer product platforms. provisions do not, however, specifically
and microwave/conventional ranges. In
(Joint Comment, No. 9 at p. 5) The Joint prevent DOE from exercising its
response, DOE believes that the technical expertise to create separate
specification of ‘‘kitchen’’ and Comment argued that, according to
EPCA’s definition of classes found at 42 product classes subject to the same
‘‘household cooking appliance’’ in the standards, if such differentiation is
definitions of ‘‘conventional range’’ and U.S.C. 6219(a), commercial clothes
washers should be treated as one class determined to be appropriate.
‘‘conventional cooking top’’ excludes After considering the comments on
outdoor gas/propane grills. Therefore, because ‘‘the function * * * of
the Framework Document, DOE decided
DOE has decided not to include outdoor commericial clothes washers (i.e.,
to keep the single class of commercial
gas/propane grills in the present cleaning clothes) does not depend on
clothes washers for today’s ANOPR, but
analyses. the orientation of the clothes washer
remains open to the possibility of
EEI also commented after the drum axis.’’ (Joint Comment, No. 9 at p.
changing this approach if further
Framework public meeting that DOE 5) In addition, the Joint Comment
comments demonstrate that such a
should include compact cooking contended that DOE chose to maintain
change is warranted. The Joint
products such as toaster ovens in the one product class during the residential
Comment, for example, argued that the
analysis. (EEI, No. 7 at p. 3) However, clothes washer rulemaking 12 and, as a
function of clothes washers is to clean
the definition of ‘‘conventional oven’’ result, urged DOE to do the same in this
clothes and that all commercial clothes
provided in 10 CFR 430.2 states, in washers perform this function and,
12 DOE notes that the Joint Comment is incorrect.
relevant part, ‘‘It does not include therefore, should be treated as a single
DOE has established five classes of residential
portable or countertop ovens which use clothes washers, including top-loading compact, class. DOE has previously rejected this
electric resistance heating for the top-loading standard and front-loading (See 10 CFR argument. The residential clothes
cooking or heating of food and are part 430, section 430.32(g)). DOE understands how washer rulemaking history clearly
designed for an electrical supply of some stakeholders could believe there is only one
class of standard-size residential clothes washers in
demonstrated that size, the axis of
approximately 120 volts.’’ Therefore, DOE’s regulations since the value of the energy access and certain technologies (e.g.,
DOE is not including toaster ovens in efficiency standard is the same for both classes. suds savings) had consumer utility that
the present analyses because they are While the standards are the same, DOE notes they affect performance and, therefore,
not covered products. are separate in DOE’s regulations found at
430.32(g). The max tech level for the two classes are
warranted separate classes for
In sum, in this rulemaking DOE is different, because of the utility features, and are, residential products. Nevertheless, DOE
using the following eight product therefore, separate classes. has decided to maintain a single class
for CCWs in today’s ANOPR, for the interested persons to submit written outside of the United States. Many of
reasons that follow. First, other presentations of data, views, and the domestic appliance manufacturers
stakeholders did not provide any arguments as discussed in section IV.E rebrand foreign-manufactured
compelling information to support of this ANOPR. microwave products. Major microwave
proposing multiple product classes for oven manufacturers are: LG, Samsung
2. Market Assessment
CCWs, Second, even though there may Electronics America, Inc. (Samsung),
be some performance-related features on AHAM is the trade association and the Sharp Electronics Corporation
existing CCWs that might warrant representing the majority of dishwasher, (Sharp), serving 67 percent of the
multiple CCW product classes (as was dehumidifier, and cooking product domestic market. The second tier of
demonstrated in the residential clothes manufacturers. AHAM conducts market approximately 9 manufacturers serves
washer rulemaking), technologies may and consumer research studies and the remaining 33 percent of the
be available to enable top-loading units publishes a biennial Major Appliance domestic market.
to attain the same efficiency level as Fact Book. AHAM also develops and Due to mergers and acquisitions, the
front-loading units, thereby rendering maintains technical standards for home appliance industry continues to
any product class distinction various appliances to provide uniform, consolidate. While the degree of market
meaningless. repeatable procedures for measuring share concentration varies by product
In tentatively deciding to retain a specific product characteristics and type, the market shares of a few
single product class for CCWs, DOE was performance features. Other trade companies provide evidence in support
sensitive to other considerations associations relevant to this rulemaking of this characterization. According to
including the likely outcome of include the Coin Laundry Association the September 2006 issue of Appliance
requisite U.S. Department of Justice (CLA), representing the 30,000 coin Magazine, Whirlpool, GE, Frigidaire,
(DOJ) review of the potential impacts, if laundry owners globally, and the MLA, and Maytag comprise 92 percent of the
any, of efficiency standards on a trade association of operator and U.S. core appliance market share. ‘‘Core
competition, given that a large supplier companies providing appliances’’ include dishwashers,
percentage of the overall market for professional laundry services for the freezers, ranges, refrigerators, and
commercial washers is produced by one multi-housing industry. clothes washers. Whirlpool and Maytag
manufacturer that specializes in The majority of the domestic share of were allowed by the U.S. Department of
vertical-axis machines. Another CCWs is held by four major Justice (DOJ) to complete a merger on
consideration may be the potential manufacturers: ALS, the Maytag March 31, 2006, after an investigation
effect of multiple-class standards on the Corporation (Maytag), Whirlpool, and that focused primarily on residential
market shares of vertical-axis and GE. Maytag and Whirlpool merged in laundry but with consideration of
horizontal-axis machines. For example, 2006 but have continued to maintain impacts across all product lines.
if separate standards further widened both product lines to this date. Although opponents of the merger had
the first cost differences between these DOE estimates that there are asserted that the combined companies
two classes of washers, then the overall approximately 13 manufacturers of would control as much as 70 percent of
result might be a decline in the market residential dishwashers that serve the the residential laundry market and as
share of the more energy efficient domestic market. Approximately 94 much as 50 percent of the residential
horizontal-axis machines, which could percent of the market is served by four dishwasher market,14 DOJ determined
more than offset any energy savings manufacturers: AB Electrolux that the merger would not give
achieved in vertical-axis machines. (Frigidaire), GE, Maytag, and Whirlpool. Whirlpool excessive market power in
DOE notes that sections 325 (o)(4) and The merger between Whirlpool and the sale of its products and that any
327(d)(4) of EPCA require DOE to Maytag resulted in the combined attempt to raise prices would likely be
consider the availability of performance company accounting for 51 percent of unsuccessful. In support of this claim,
characteristics, features, and other the domestic market. DOJ noted: (1) Other U.S. brands,
characteristics in setting standards and DOE estimates that there are including Sears Brands LLC (Kenmore),
in considering State petitions for approximately 18 manufacturers of GE, and Frigidaire, are well established;
exemption from Federal preemption. (42 residential dehumidifiers that serve the (2) foreign manufacturers, including LG
U.S.C. 6295(o)(4) and 6297(d)(4)) The domestic market. Approximately two and Samsung, are gaining market share;
California Energy Commission (CEC) thirds of the market is represented by (3) existing U.S. manufacturers are
submitted a petition for exemption from two manufacturers: Whirlpool and LG operating below production capacity; (4)
Federal preemption by DOE’s Electronics (LG). the large home appliance retailers have
residential clothes washer standard.13 DOE estimates that there are alternatives available to resist price
One of the factors on which DOE based approximately 14 manufacturers of increase attempts; and (5) Whirlpool
its denial of the CEC petition was that cooking products (including ovens, and Maytag substantiated large cost
it would make top-loading clothes cooktops, and ranges) that serve the U.S. savings and other efficiencies that
washers unavailable in the market. (71 market. The majority of the cooking would benefit consumers. The
FR 78157) products market is represented by four Whirlpool-Maytag merger follows
Based on the discussion above, DOE companies: Frigidaire, GE, Maytag, and several other mergers and acquisitions
requests comments on clothes washer Whirlpool. GE and Whirlpool represent in the home appliance industry. For
product classes and, if DOE were to nearly three quarters of the electric example, Maytag acquired Jenn-Air
keep a single class for commercial range products market. GE represents Corporation in 1982, Magic Chef, Inc. in
clothes washers, how to consider the over a third of the gas range products 1986, and Amana Appliances in 2001.
requirements of section 325(o)(4) of market, while the combined Whirlpool Whirlpool acquired the KitchenAid
EPCA in considering Trial Standard and Maytag comprise over a quarter. division of Hobart Corporation in 1986.
Levels. DOE specifically seeks feedback The microwave oven market differs
White Consolidated Industries (WCI)
on these product classes and invites from the rest of the domestic cooking
product market in that many of the 14 P. Hussmann, ‘‘Justice to Extend Maytag-
13 DOE Docket No. EE–RM–PET–100, submitted manufacturers are foreign-owned Whirlpool Merger Review,’’ Newton Daily News
by the California Energy Commission. companies with manufacturing facilities Online (Feb. 14, 2006).
acquired the Frigidaire division of (4) kitchen remodelers. DOE determined standards when they take effect on
General Motors Corporation in 1979, that over 93 percent of residential October 1, 2007. In addition, EPACT
and AB Electrolux acquired WCI (and appliances are distributed from the 2005 requires that by October 1, 2009,
therefore Frigidaire) in 1986. See manufacturer directly to a retailer. See DOE issue a final rule for dehumidifiers
Chapter 3 of the TSD for more Chapter 3 of the TSD for more to determine whether the standards
information regarding manufacturers of information regarding distribution should be amended. (EPACT 2005,
CCWs and residential dishwashers, channels for CCWs and residential section 135(c)(4)) Further, in the event
dehumidifiers, and cooking products. dishwashers, dehumidifiers, and that DOE fails to publish a final rule
In addition, DOE considers the cooking products. requiring new standards to take effect by
possibility of small businesses being DOE considers regulatory and non- October 1, 2012, EPACT 2005 also
impacted by the promulgation of energy regulatory initiatives that affect CCWs prescribes a new set of amended
conservation standards for CCWs and and residential dishwashers, standards for dehumidifiers. (Id.)
residential dishwashers, dehumidifiers, dehumidifiers, and cooking products. Prior to the passage of EPACT 2005,
and cooking products. At this time, DOE NAECA established Federal standards the following States proposed and
is not aware of any small manufacturers, for residential dishwashers, which were adopted State-level efficiency
defined by the Small Business subsequently amended by DOE by a regulations for CCWs that are identical,
Administration as having 750 final rule published in the Federal or very similar, to EPACT 2005
employees or fewer, who produce Register on May 14, 1994. (56 FR 22250) regulations: Arizona, California,
products that fall under this rulemaking NAECA established prescriptive Connecticut, Maryland, New Jersey,
and who, therefore, would be impacted standards for gas cooking products, Oregon, Rhode Island, and Washington.
by a minimum efficiency standard. requiring gas ranges and ovens with an The EPACT 2005 energy and water use
Should any small business electrical supply cord not to be standards for CCWs preempt any State
manufacturers of the four appliance equipped with constant burning pilots, efficiency standards since they became
products be identified, DOE will study and directed DOE to conduct two cycles effective January 1, 2007.15 In addition
the potential impacts on these small of rulemakings to determine if more to the efficiency standards discussed
businesses in greater detail during the stringent standards are justified. (42 above, the State of California requires
MIA, which it will conduct as a part of U.S.C. 6295 (h)(1)–(2)) DOE issued a that commercial top-loading, semi-
the NOPR analysis. See Chapter 3 of the NOPR on March 4, 1994, proposing automatic clothes washers and
TSD for more information regarding performance standards for gas and commercial suds-saving clothes washers
small business manufacturers of CCWs electric residential cooking products, manufactured on or after January 1,
and residential dishwashers, including microwave ovens. 59 FR 2005 have an unheated rinse water
dehumidifiers, and cooking products. 10464. In accordance with its 1996 option.
Next, DOE identified distribution Process Rule, DOE refined its standards DOE reviewed several voluntary
channels for each of the products analysis of cooking products. With programs that promote energy-efficient
covered by this rulemaking. For CCWs, regard to gas cooking products, DOE CCWs, residential dishwashers,
DOE determined that the market focused on the economic justification dehumidifiers, and cooking products in
consists of laundromats, private multi- for eliminating standing pilot lights. the United States. Many programs,
family housing, and large institutions Partially due to the difficulty of including the Consortium for Energy
(e.g., military barracks, universities, and conclusively demonstrating that Efficiency (CEE), Energy Star, and the
housing authorities). Most large elimination of standing pilot lights was Federal Energy Management Program
institutions and a majority of private economically justified, DOE issued a (FEMP), establish voluntary energy
multi-family housing (between 50 and final rule on September 8, 1998, that conservation standards for these
90 percent) do not purchase clothes covered only electric cooking products, products. CEE issues voluntary
washers directly. Rather, these including microwave ovens. 63 FR specifications for CCWs and standard-
organizations lease their laundry space 48038. The final rule found that sized dishwashers under its
to a third party known as a route standards were not economically Commercial, Family-Sized Washer
operator. Route operators supply justified for electric cooking products. Initiative and Super-Efficient Home
laundry equipment and maintain DOE never completed its standards Appliance Initiative, respectively.
facilities in exchange for a percentage of rulemaking for gas cooking products. Energy Star, a voluntary labeling
the laundry revenue. Laundromats and Section 136(e) of EPACT 20005
program backed by the EPA and DOE,
some private building managers amends section 342 of EPCA, 42 U.S.C.
identifies energy efficient products
purchase or lease clothes washers 6313, to add subsection (e) for CCWs.
through a qualification process. To
directly from distributors. The main Likewise, section 135(c)(4) of EPACT
qualify, a product must exceed Federal
difference between route operators and 2005 amends section 325 of EPCA, 42
minimum standards by a specified
distributors is the length of service U.S.C. 6295, to add subsection (cc) for
amount, or if no Federal standard exists,
provided to their clients. Route dehumidifiers. New subsection 342(e),
exhibit selected energy-saving features.
operators provide ongoing support 42 U.S.C. 6313(e) establishes energy
while distributor support ends at the conservation standards for CCWs. The Energy Star program works to
point of sale. Further, it requires that DOE issue a recognize the top quartile of products on
The distribution chain for residential final rule by January 1, 2010, to the market, meaning that approximately
appliances, including dishwashers, determine whether the standards for 25 percent of products on the market
dehumidifiers, and cooking products, CCWs should be amended. New meet or exceed the Energy Star levels.
differs from commercial products, since subsection 325(cc), 42 U.S.C. 6295(cc), Energy Star specifications exist for
the majority of consumers purchase establishes energy conservation many products, including CCWs,
their appliances directly from retailers. standards for dehumidifiers based on a dishwashers, and dehumidifiers. FEMP
These retailers include: (1) Home unit’s capacity to extract moisture from 15 None of these States submitted a petition for
improvement, appliance, and the surrounding air (in pints/day). waiver to DOE, seeking to maintain their existing
department stores; (2) Internet retailers; These Federally mandated standards for efficiency standards for commercial clothes
(3) membership warehouse clubs; and dehumidifiers will be the national washers.
works to reduce the cost and consumers with multiple units of some The historical shipments data shown
environmental impact of the Federal appliances increases annually, the unit in Tables II.1, II.2, and II.3 and the
government by advancing energy shipments of most appliances are historical market saturation data shown
efficiency and water conservation, expected to increase as well. The in Table II.4 provide a better picture of
promoting the use of distributed and shipments of built-in dishwashers the market for the four appliance
renewable energy, and improving utility increased by over 76 percent from 1995 products. The market saturation data
management decisions at Federal sites. to 2005, while the shipments of portable indicate the percentage of the housing
FEMP helps Federal buyers identify and dishwashers declined 35 percent in the stock with the appliance. The data in
purchase energy efficient equipment, same time period. After a period of Table II.4 also include for each of the
including CCWs, residential decline from 1995 to 2002, shipments of given years the number of appliances in
dishwashers, and microwave ovens. See dehumidifiers increased sharply in 2003 the housing stock. Because commercial
Chapter 3 of the TSD for more
and have continued to rise through clothes washers are not a household
information regarding regulatory and
2005. Shipments of dehumidifiers appliance, market saturation data are
non-regulatory initiatives. During the
engineering analysis (Chapter 5 of the nearly doubled between 1995 and 2005. not provided. The historical shipments
TSD), efficiency levels specified by From 1995 to 2005, shipments of and market saturation data for
many of these initiatives will be electric and gas free-standing ranges and dishwashers, dehumidifiers, and
analyzed during the generation of cost- surface cooking units, electric built-in cooking products are from the 2005
efficiency curves. ranges, and microwave ovens increased, AHAM Fact Books,16 while the
DOE reviewed data collected by the while shipments of built-in gas ranges commercial clothes washer historical
U.S. Census Bureau, EPA, and AHAM to decreased. However, in real dollars, the shipments data are based on data
evaluate annual residential appliance value of shipments for the household provided to DOE by AHAM for the years
product shipment trends and the value appliance industry has declined by 2002–2005 and Appliance Magazine for
of these shipments. As the number of nearly 14 percent over the period from the years 1988–1998.17
new home starts and the percentage of 1994 to 2005.
TABLE II.1.—INDUSTRY SHIPMENTS OF DISHWASHERS AND DEHUMIDIFIERS

[Domestic and import in thousands of units]
Dishwashers
Year Dehumidifiers
Built-In Portable Total
2005 ................................................................................................................. 7,294 133 7,428 1,957

2004 ................................................................................................................. 6,953 153 7,106 1,672
2003 ................................................................................................................. 6,280 148 6,428 1,311
2002 ................................................................................................................. 6,049 158 6,207 799
2001 ................................................................................................................. 5,478 149 5,627 806
2000 ................................................................................................................. 5,663 164 5,827 975
1999 ................................................................................................................. 5,542 170 5,712 950
1998 ................................................................................................................. 4,969 175 5,144 1,031
1997 ................................................................................................................. 4,653 173 4,826 820
1996 ................................................................................................................. 4,417 189 4,606 977
1995 ................................................................................................................. 4,141 205 4,346 1,003
TABLE II.2.—INDUSTRY SHIPMENTS OF COOKING PRODUCTS

[Domestic and import in thousands of units]
Cooking products
Electric ranges Gas ranges

Year Microwave
Surface Surface
Free- Free- ovens
Built-In cooking Total Built-In cooking Total
standing standing
units units
2005 ......................................... 4,685 973 542 6,201 3,139 64 560 3,762 13,862
2004 ......................................... 4,612 963 570 6,145 3,124 67 528 3,719 15,526
2003 ......................................... 4,238 841 543 5,622 2,897 67 455 3,419 14,274
2002 ......................................... 4,030 780 528 5,338 2,781 71 416 3,268 13,311
2001 ......................................... 3,842 726 498 5,066 2,580 72 384 3,036 13,446
2000 ......................................... 3,826 706 494 5,026 2,729 70 377 3,176 12,644
1999 ......................................... 3,785 705 493 4,983 2,698 72 367 3,137 11,422
1998 ......................................... 3,481 652 506 4,639 2,543 71 336 2,950 10,365
1997 ......................................... 3,177 617 446 4,240 2,391 73 280 2,744 8,883
1996 ......................................... 3,123 614 418 4,155 2,366 72 272 2,710 8,771
1995 ......................................... 2,931 598 389 3,917 2,391 84 240 2,715 8,162
16 AHAM, 2005 Fact Book, 2005. Washington, DC. 17 ‘Statistical Review’. Appliance Magazine,
Available for purchase at: http://www.aham.org/ht/ April, 1998, 1999.

d/Store/name/FACTBOOK.
TABLE II.3.—INDUSTRY SHIPMENTS OF TABLE II.3.—INDUSTRY SHIPMENTS OF TABLE II.3.—INDUSTRY SHIPMENTS OF

COMMERCIAL CLOTHES WASHERS COMMERCIAL CLOTHES WASHERS— COMMERCIAL CLOTHES WASHERS—
[Thousands of units] Continued Continued
[Thousands of units] [Thousands of units]
Year Units
Year Units Year Units
2005 ...................................... 177
2004 ...................................... 178 1998 ...................................... 265 1992 ...................................... 188
2003 ...................................... 191 1997 ...................................... 241 1991 ...................................... 193
2002 ...................................... 175 1996 ...................................... 232 1990 ...................................... 225
2001 ...................................... 194 1995 ...................................... 209 1989 ...................................... 215
2000 ...................................... 215 1994 ...................................... 205 1988 ...................................... 213
1999 ...................................... 239 1993 ...................................... 190
TABLE II.4.—APPLIANCE MARKET SATURATIONS: NUMBER OF HOUSEHOLDS WITH PRODUCT (IN MILLIONS) AND
PERCENTAGE OF U.S. HOUSEHOLDS WITH PRODUCT
1970 1982 1990 2001 2005
Product
Number Percent Number Percent Number Percent Number Percent Number Percent
Dishwashers ................................. 12 18.9 37.2 44.5 50.3 53.9 61.8 59.3 80.2 73.7
Dehumidifiers ............................... NA NA 9.2 11 15.6 16.7 14.7 14.1 20.6 18.9
Electric Ranges/Cooktops* .......... 25.8 40.6 48.4 58 58.4 62.6 69.2 66.3 71 65.3
Gas Ranges/Cooktops* ................ 36.6 57.7 35.7 42.7 36.1 38.7 39.4 37.8 42.2 39
Microwave Ovens ......................... Neg. Neg. 21.4 25.6 77.2 82.7 94.6 ** 90.7 97.2 89.3
* Cooktops not included in 1970 or 1982 data.
** Includes over-the-range and countertop microwave ovens.
During the Framework public coil-element and smooth element ovens, and clothes washers have
meeting, DOE solicited comments electric cooktops. decreased in the same time period. DOE
regarding existing databases to track DOE also evaluated import and export also developed the household appliance
CCW efficiencies. ALS commented that trends for CCWs and residential industry cost structure from publicly
the existing CEC database contains dishwashers, dehumidifiers, and available information from the U.S.
useful data and should be reviewed. cooking products as reported by the U.S. Census Bureau, the Annual Survey of
(Public Meeting Transcript, No. 5 at p. Census Bureau and AHAM, as well as Manufacturers (ASM), and the SEC 10–
44) As of March 2007, the CEC database the market saturation for dishwashers, K reports filed by publicly-owned
had 626 entries for dishwashers and 196 dehumidifiers, and cooking products manufacturers. The statistics illustrate a
entries for CCWs. This database, according to AHAM. On the whole, steady decline in the number of
however, does not specify which major appliance unit imports increased production and non-production workers
models are current, and it does not 1.8 percent in 2005 from 2004. Major in the industry.
appear to cover the entire range of appliance unit exports increased 13.5 Inventory levels, expressed both in
dishwasher models. DOE also consulted percent over the same period. In terms dollars and as a percentage of value of
the Energy Star database for residential of market saturation, while the shipments, have steadily declined since
clothes washers, dishwashers, and percentage of U.S. households with 1995 for the household appliance
dehumidifiers. DOE subsequently used electric ranges and/or cooktops and industry, according to the ASM. DOE
these data to identify units for reverse microwave ovens has decreased slightly obtained full-production-capacity
since 2001, the market saturation of utilization rates from the U.S. Census
engineering tear-downs and other
dishwashers, dehumidifiers, and gas Bureau, Survey of Plant Capacity from
analysis. Whenever possible, DOE
cooking products has increased. See 1994 to 2004. Full production capacity
investigated the design options of the
Chapter 3 of the TSD for more is defined as the maximum level of
listed appliances, which then helped
information regarding historical production an establishment could
DOE design the interview guides for the
shipments and market saturation. attain under normal operating
MIA interviews with stakeholders to
From AHAM data 1818 and the U.S. conditions. In the Survey of Plant
solicit comments about design options.
Department of Labor’s Consumer Price Capacity report, the full production
DOE used the data for residential utilization rate is a ratio of the actual
clothes washers as an additional means Index, DOE estimated average retail
prices for residential appliances, level of operations to the full production
of validation for the CCW analysis. level. The full-production-capacity
including clothes washers, dishwashers,
Natural Resources Canada (NRCan) dehumidifiers, and cooking products. utilization rate for household appliances
publishes a database of electric cooking Although prices for electric and gas in aggregate, along with the rates for
appliance performance. Although it is ranges have increased in the period cooking appliances and household
not completely representative of the from 1980 to 2005, the increase has been laundry appliances, show a decrease in
current U.S. cooking products market, at a much slower rate than the annual utilization from 1994 to 2004, although
this database covers products available rate of inflation. Prices of residential trends in subsets of that time period
in the Canadian market, which overlaps dishwashers, dehumidifiers, microwave have fluctuated. See Chapter 3 of the
with the U.S. market. Chapter 3 of the TSD for more information regarding
TSD presents data that detail the energy 18 Data submitted to DOE as part of this retail pricing, industry cost structure,
factors of standard and self-cleaning rulemaking, contained in DOE Docket No. EE– inventory levels, and production
electric ranges and ovens, along with 2006–STD–0127. capacity utilization.
3. Technology Assessment options that specifically address pre- • Washable air filters
In the technology assessment, DOE rinsing. Any design option that achieves Based on product literature research,
identifies technologies and design energy efficiency improvements without comments, and teardown analysis, DOE
options that appear to be feasible means incurring significant performance has identified compressor, heat
of improving product efficiency, and penalties will indirectly address pre- exchanger, and fan motor improvements
characterizes energy efficiency of rinsing. as the most common ways by which
residential dishwashers, dehumidifiers, DOE considered the design options manufacturers improve the energy
and cooking products, and CCWs that follow. efficiency of their dehumidifiers as
• Condenser drying measured by the DOE test procedure.
currently available in the marketplace.
• Fan/jet drying During the Framework public meeting
This assessment provides the technical • Flow-through heating and Framework comment period,
background and structure on which • Improved fill control stakeholders asked that DOE add
DOE bases its screening and engineering • Improved food filter improved control systems to the
analyses. • Improved motor efficiency dehumidifier design options list. ACEEE
a. Dishwashers • Improved spray-arm geometry and other energy efficiency advocates
• Increased insulation recommended that improved controls
DOE identified technologies to • Low-standby-loss electronic
increase the energy efficiency of (such as fuzzy logic) be added to the
controls
design option list to better control the
residential dishwashers primarily from • Microprocessor controls and fuzzy
a review of the following three sources: dehumidifier. (Public Meeting
logic, including adaptive or soil-sensing
(1) DOE’s ANOPR initiating a standards Transcript, No. 5 at p. 73; Joint
controls
rulemaking for dishwashers, published • Modified sump geometry, with and Comment, No. 9 at p. 4) DOE agrees that
on November 14, 1994 (59 FR 56423); without dual pumps such control technologies offering
(2) recent information provided by trade • Reduced inlet-water temperature potential energy savings are being
publications; and (3) design data • Supercritical carbon dioxide implemented by manufacturers, and,
identified in manufacturer product washing therefore, it added improved controls as
offerings. Except where otherwise • Ultrasonic washing a design option for dehumidifiers.
noted, design options are taken from the • Variable washing pressure and flow c. Cooking Products
1994 ANOPR. DOE derived the variable rates
DOE characterized energy efficiency DOE most recently analyzed energy
washing pressure and variable-speed
as an EF, expressed as cycles/kWh for conservation standards for cooking
drive technologies from the February
dishwashers currently on the market via products in 1996 and 1997. In the 1997
2006 edition of Appliance Magazine.
a survey of the CEC database of certified analysis, DOE analyzed only gas
DOE grouped these technologies
dishwashers.19 cooking products to determine the
together because they collectively
technical and economic feasibility of
address manufacturers’ design tradeoffs b. Dehumidifiers eliminating standing pilot lights. In its
between the mechanical soil removal
DOE has not previously conducted a prior analysis, DOE identified many
function of the water and the cycle time
comprehensive analysis of energy technologies that have the potential for
and energy associated with the
conservation standards for improving gas and electric cooking
dishwasher pump. Condenser and fan/
dehumidifiers because there are efficiency. It has considered all of these
jet drying are technologies listed in one
currently no Federal standards for these in this rulemaking. In addition, DOE
manufacturer’s product offerings. DOE
products. The first such standards identified low-standby-loss electronic
also identified supercritical carbon
become effective October 2007. To build controls as a design option for several
dioxide washing from the November
a list of possible design options, DOE cooking products, based on review of
2005 issue of Appliance Magazine. It
surveyed the marketplace for standby power data for microwave
added low-standby-loss electronic
dehumidifier design options by ovens and the potential applicability to
controls based on DOE’s analysis of
reviewing a wide assortment of product conventional cooking products as well.
controller standby power in
literature, through discovery during the Radiant elements for smooth electric
dishwashers currently on the market.
In addition to these design options, teardown analysis, during stakeholder cooktops, which were included in the
the multiple water organizations interviews, and by using its previous previous analysis, were not considered
commented that DOE should consider a room-air conditioning rulemaking as a design option for this rulemaking
two-drawer design or similar option analysis as a source for further design because manufacturer data provided to
which would improve efficiency under options. DOE identified the following DOE in the prior rulemaking indicated
partial loads. The multiple water design options as possible means to that this technology does not offer an
organizations also believe DOE should improve dehumidifier performance. efficiency improvement over the
consider any design option that would • Built-in hygrometer/humidistat baseline according to the DOE test
reduce pre-rinsing. (Multiple Water • Improved compressor efficiency procedure. DOE considered the
Organizations, No. 11 at p. 3) In • Improved condenser performance technologies that follow.
interviews with manufacturers, DOE • Improved controls For gas cooktops:
• Improved defrost methods • Catalytic burners
determined that two-drawer designs • Electronic ignition
• Improved demand-defrost controls
contain no control systems to link the • Improved evaporator performance • Insulation
operation of one drawer with another, • Improved fan and fan-motor • Radiant gas burners
so that each drawer acts in its own efficiency • Reduced excess air at burner
capacity as a compact-size dishwasher. • Improved flow-control devices • Reflective surfaces
Therefore, a two-drawer design cannot • Low-standby-loss electronic • Sealed burners
be considered as a design option. controls • Thermostatically-controlled burners
Minimizing consumer pre-rinsing For open (coil) element electric
depends on maintaining cleaning 19 Available online at: http://www.energy.ca.gov/ cooktops:
performance; there are no design appliances/appliance/excel_based_files/. • Electronic controls
• Improved contact conductance exception of cooking sensors, dual microwave oven test procedure and, as
• Insulation magnetrons, and low-standby-loss a result, there is a lack of efficiency
• Low-standby-loss electronic electronic controls. DOE identified data. (Public Meeting Transcript, No. 5
controls cooking sensors from product literature, at p. 86) Whirlpool commented that the
• Reflective surfaces while dual magnetrons were identified absence of a microwave oven energy
For smooth element electric cooktops: in the February 2006 edition of efficiency standard has resulted in a
• Electronic controls Appliance Design as a means to dearth of data on microwave ovens.
• Halogen elements decrease cooking times. DOE identified (Whirlpool, No. 10 at p. 10). ACEEE
• Induction elements low-standby-loss electronic controls by commented that, because there are very
• Low-standby-loss electronic reviewing AHAM data for standby few data on microwave ovens, the
controls power. In addition, DOE received baseline efficiency level needs to be
For gas and electric ovens: comments stating that it needed to updated from the numbers in the
• Bi-radiant oven (electric only) consider sensors and controls that previous rulemaking. (Public Meeting
• Forced convection detect completion of the cooking Transcript, No. 5 at p. 91) ACEEE
• Halogen lamp oven (electric only) process and variable power supplies further stated that the process to update
• Improved and added insulation that adjust power to the magnetron the data should include collecting as
• Improved door seals during cooking. (Public Meeting much information from manufacturers
• Low-standby-loss electronic as possible, then supplementing these
Transcript, No. 5 at p. 91; Joint
controls data with product testing. The purpose
Comment, No. 9 at p. 3) DOE did not
• No oven-door window of these test data, according to ACEEE,
receive any information regarding the
• Oven separator should be to assess the validity of the
• Pilotless ignition (gas only) energy efficiency impacts of variable
power supplies, and, therefore, will efficiency levels analyzed in the
• Radiant burner (gas only) previous rulemaking rather than to
• Reduced conduction losses limit the design option relating to
variable magnetron output to dual quantify a new cost-efficiency
• Reduced thermal mass relationship. (Public Meeting
• Reduced vent rate magnetrons. In view of the above, DOE
considered the design options that Transcript, No. 5 at pp. 142–143)
• Reflective surfaces AHAM concurred with DOE’s intention
• Steam cooking follow.
• Added insulation to conduct microwave oven efficiency
DOE received several comments that
the design options from the previous • Cooking sensors testing as part of this rulemaking
rulemaking are still relevant because • Dual magnetrons because it would take industry a
• Eliminate or improve ceramic significant amount of time to provide
there have been no major technological
stirrer cover efficiency data. AHAM suggested DOE
breakthroughs in conventional cooking • Improved fan efficiency may want to commission the National
products since that time. AHAM • Improved magnetron efficiency Institute of Standards and Technology
recommended looking at the same • Improved power supply efficiency or some other source to do an
design options because there has been • Low-standby-loss electronic independent evaluation. (Public
no change in the market other than for controls Meeting Transcript, No. 5 at p. 143) The
induction cooking, which according to • Modified wave guide Joint Comment stated that because
AHAM is so expensive it should not be • Reflective surfaces microwave oven technology has
considered. (Public Meeting Transcript, In written comments, AHAM stated changed substantially since the previous
No. 5 at p. 93) ACEEE and the Joint that DOE considered many design rulemaking, DOE should quickly collect
Comment agreed with retaining the options for microwave ovens in its 1998 current data on product performance
design options from the previous rule and that, after extensive analysis, and features from manufacturers, and
rulemaking, stating that only modest DOE determined that no design options fill in gaps where necessary.
updates are needed for conventional were technologically feasible or Manufacturers could then provide
cooking products. (Public Meeting economically justifiable. AHAM also incremental cost data at the selected
Transcript, No. 5 at p. 97; Joint stated that there have been no efficiency levels. (Joint Comment, No. 9
Comment, No. 9 at p. 3) Whirlpool technological or economic at p. 3)
stated that many of the previous design breakthroughs since the previous Stakeholders questioned which
options either are not economically determination that would change the microwave oven test procedure should
justifiable or have safety issues (Public previous conclusion. (AHAM, No. 17 at be used. he current DOE test procedure
Meeting Transcript, No. 5 at p. 94), p. 1) However, ACEEE disagreed, stating requires manufacturers to test to IEC
while Wolf commented that the cost and that there have been some significant 705–1988, Household Microwave
risk of modifying today’s well- changes in microwave oven technology Ovens—Methods for Measuring
performing products with questionable since the prior rulemaking. Thus, it Performance, and Amendment 2–1993.
design options should not be stated that the previous design options The current IEC test procedure is
underestimated. (Wolf, No. 6 at p. 2) need to be reviewed. (Public Meeting designated IEC 60705 Edition 3.2–2006.
DOE believes the aforementioned design Transcript, No. 5 at p. 97) Differences between the 1988 and
options are still relevant and has During the Framework public meeting current IEC test procedures can result in
retained them for analysis. Consumer and Framework comment period, DOE differences in measured microwave
safety is a screening criterion that DOE received comments that the lack of oven efficiency. In comments received
has applied in the screening analysis efficiency data for microwave ovens during the Framework public meeting,
(Chapter 4 of the TSD), and DOE would hinder DOE’s ability to establish Sharp asked which test procedure
assessed economic viability in the LCC efficiency levels, and that DOE should would be used to define microwave
and PBP analyses (Chapter 8 of the conduct a test program specifically to oven efficiency. (Public Meeting
TSD). obtain such efficiency data since it Transcript, No. 5 at p. 141)
For microwave ovens, in the previous would be difficult for the manufacturers Recognizing the lack of existing
rulemaking, DOE identified all of the to do so themselves. Whirlpool stated energy efficiency data, AHAM
technologies listed below, with the that manufacturers are not using the conducted a test program on 21
microwave ovens from nine • Electrolytic disassociation of water During the Framework public
manufacturers, representing a broad • Horizontal-axis design meeting, stakeholders asked DOE
spectrum of units available in the • Horizontal-axis design with whether it will address standby power
marketplace and incorporating a variety recirculation in CCWs. Potomac suggested that DOE
of capacities and features. AHAM tested • Improved fill control consider technologies that limit standby
microwave oven efficiency according to • Improved horizontal-axis-washer power in CCWs. Such design options
DOE’s test procedure and standby drum design could include improved power supplies
power according to IEC 62301–2005, • Improved water extraction to lower or other technologies that limit power
Household Electrical Appliances— remaining moisture content consumption in standby mode. (Public
• Increased motor efficiency
Measurement of Standby Power. AHAM • Low-standby-power design Meeting Transcript, No. 5 at p. 52) DOE
found no correlation between energy • Ozonated laundering recognizes the importance of studying
efficiency and rated output power or • Reduced thermal mass all aspects of power consumption by
cavity volume. Efficiencies ranged from • Spray rinse or similar water- consumer appliances. With the growing
54.8 percent to 61.8 percent. Given the reducing rinse technology trend of upgrading consumer appliances
uncertainties in the test procedure, • Steam washing to use electronic controllers, standby
resulting in large test-to-test variations, • Suds savings power has become a topic of interest
DOE considers these efficiencies to be • Thermostatically-controlled mixing across all appliance categories.
comparable to the efficiencies in the valves During the Framework public
prior rulemaking’s analysis. Standby • Tighter tub tolerance meeting, DOE solicited comments
power also showed no correlation with • Ultrasonic washing regarding existing databases to track
rated output power, varied significantly The Multiple Water Organizations CCW efficiencies. ALS commented that
from unit to unit, and ranged from 1.5 requested that DOE add the following the existing CEC database is a good
watts to 5.8 watts. The FEMP database design options: (1) Spray rinse, (2) source of information and that DOE
of microwave oven standby power nutating or other advanced agitators, (3) should review it. (Public Meeting
indicates that 90 percent of reported advanced power supplies, and (4) steam Transcript, No. 5 at p. 44) DOE
microwave ovens consume greater than cleaning. (Multiple Water subsequently used that database and
2 watts in standby mode. Organizations, No. 11 at p. 1 ) ACEEE others to identify CCWs that meet
The energy efficiency data upon requested that DOE consider more various modified energy factor (MEF)
which DOE based its analysis was water-saving design options (e.g., spray and WF levels. Whenever possible, DOE
measured according to the DOE test rinse), in addition to energy-saving investigated the design options of the
procedure, which references IEC 705– design options. (Public Meeting listed washers, which then helped DOE
1988 and Amendment 2–1993. DOE Transcript, No. 5 at p. 51) In a joint design the interview guides for the MIA
does not plan to revise the test letter, the Joint Comment requested the interviews with stakeholders to solicit
procedure to incorporate IEC 60705 addition of a spray wash design option. comments about design options.
Edition 3.2–2006, to measure the (Joint Comment, No. 9 at p. 5) Additional detail on the technology
cooking efficiency, because DOE is DOE has added advanced agitation
assessment can be found in Chapter 3 of
unaware of any efficiency comparison concepts for vertical-axis washers.
the TSD.
These agitation systems include
data that would justify such a change.
nutating plates, side-mounted mounted B. Screening Analysis
However, as discussed above, DOE is
impellers, and any other agitation
examining changes to the test procedure 1. Purpose
technology that eliminates the need for
to measure standby-power use. The purpose of the screening analysis
the traditional large and centrally-
d. Commercial Clothes Washers mounted agitator found in vertical-axis is to evaluate the design options that
DOE identified technologies to clothes washer tubs. While such improve the efficiency of a product, in
improve the energy efficiency of CCWs. agitation systems are currently only order to determine which options to
The majority of these technologies are found on high-end residential clothes consider further and which options to
described in the 1996 report entitled washers, they have the potential to be screen out because they may not be
Design Options for Clothes Washers. adapted for CCWs and can reduce the technologically feasible, may exhibit
(LBNL–47888, October 1996, Lawrence water consumption of vertical-axis practicability problems (related to
Berkeley National Laboratory) Steam clothes washers substantially. manufacture, installation, or service),
DOE has also added spray rinse as a may result in adverse impact on product
washing and improved horizontal-axis-
design option but notes that this design utility or product availability, or may
washer drum design were identified in
option may not be appropriate for the have an adverse impact on health or
the September 2005 edition of
commercial laundry market. ALS safety. DOE consults with industry,
Appliance Magazine. DOE identified the
commented that some water-reduction technical experts, and other interested
low-standby-power design option
design options (such as the ‘‘innovative parties in developing a list of design
during its engineering analysis review of
rinse technology’’ in its vertical-axis options for consideration. DOE then
all AHAM product classes. It added
models) have faced strong opposition applies the following set of screening
spray rinse and advanced agitator
from some consumers. (ALS, No. 19 at criteria to determine which design
design options in response to comments
p. 1) Whirlpool noted that commercial options are unsuitable for further
received following the Framework
customers tend to overload their consideration in the rulemaking (10 CFR
public meeting. DOE considered the
washers, which leads to unacceptable Part 430, Subpart C, Appendix A at
design options that follow.
• Adaptive control systems rinsing performance. (Whirlpool, No. 10 4(a)(4) and 5(b)).
• Added insulation at p. 3) Given that the industry has
fielded washers with rinse-water use a. Technological Feasibility
• Advanced agitation concepts for
vertical-axis machines reduction technologies (such as spray DOE will consider technologies
• Automatic fill control rinse) in the past and continues to incorporated in commercial products or
• Bubble action develop other water saving approaches, in working prototypes to be
• Direct-drive motor DOE will consider this design option. technologically feasible.
b. Practicability To Manufacture, Install, standard. Furthermore, it is also not yet sensor. It may be assumed that the
and Service possible to assess whether it will have incorporation of soil sensors to such
If mass production of a technology in any adverse impacts on equipment models offers the potential for
commercial products and reliable utility to consumers or equipment additional energy savings. DOE also
installation and servicing of the availability, or any adverse impacts on notes that there are multiple
technology could be achieved on the consumers’ health or safety. Therefore, technologies that can be used by
scale necessary to serve the relevant DOE screened out supercritical carbon themselves or to complement others to
market at the time of the effective date dioxide washing from further analysis. determine soiling levels inside a
For ultrasonic washing, high dishwasher. For example, it is possible
of the standard, then DOE will consider
frequency energy input into the wash to use a pressure sensor, rather than the
that technology practicable to
water creates cavitation bubbles that more typical turbidity sensors, to detect
manufacture, install, and service.
remove soil from the dishware via clogging of a filter to infer soil loads.
c. Adverse Impacts on Product Utility or mechanical scrubbing action. With this The maximum technologically feasible
Product Availability technology, consumer utility is (‘‘max-tech’’) dishwasher that DOE
If DOE determines a technology to decreased due to the potential for the investigated went a step further,
have significant adverse impact on the ultrasonic cleaning action to damage featuring both a turbidity and a pressure
utility of the product to significant fragile dishware and due to the sensor, implying a benefit from using
subgroups of consumers, or to result in perception that the low temperatures do both sensor technologies. Since there
the unavailability of any covered not sterilize dishes. Whirlpool also are many approaches to and levels of
product type with performance commented that ultrasonic dishwashing sophistication of soil sensing may be
characteristics (including reliability), is beyond the technological scope of taken to depending on the underlying
features, sizes, capacities, and volumes current product development. dishwasher platform, DOE will retain
that are substantially the same as (Whirlpool, No. 10 at p. 4) Since no soil sensing for further analysis.
manufacturer currently produces Whirlpool also stated that variable
products generally available in the U.S.
ultrasonic dishwashers, it is impossible washing pressures and flow rates and
at the time, it will not consider this
to assess whether this design option condenser drying are beyond the
technology further.
would have any impacts on consumer technological scope of current product
d. Adverse Impacts on Health or Safety health or safety, or product availability. development, and therefore DOE should
If DOE determines that a technology Therefore, DOE screened out ultrasonic eliminate them from further analysis.
will have significant adverse impacts on dishwashing from further analysis. In (Whirlpool, No. 10 at p. 4) AHAM stated
health or safety, it will not consider this comments submitted after the without elaboration that condenser
technology further. Framework public meeting, AHAM drying should be eliminated from the
agreed that DOE should eliminate analysis. (AHAM, No. 14 at p. 8) In
2. Design Options ultrasonic dishwashing. (AHAM, No. 14 reviewing current dishwasher models,
a. Dishwashers at p. 8) Table II.5 lists the dishwasher DOE noted multiple instances in which
design options that DOE has retained for manufacturer specifications indicate
For dishwashers, DOE screened out variable washing pressures and flow
reduced inlet-water temperature, analysis.
rates. For example, such a strategy may
supercritical carbon dioxide washing, include alternating wash water to the
and ultrasonic washing technologies, for
TABLE II.5.—RETAINED DESIGN
OPTIONS FOR DISHWASHERS top and bottom racks. In addition, DOE
the reasons that follow. is aware of at least one dishwasher
Reduced inlet-water temperature platform on the market with true
requires that dishwashers tap the cold 1. Condenser drying.
2. Fan/jet drying. condensation drying, in which
water line for the water supply, which 3. Flow-through heating. relatively cool ambient air is drawn
would require significant alteration of 4. Improved fill control. across the outside of the stainless steel
existing dishwasher installations in 5. Improved food filter. dishwasher cavity, providing a surface
order to accommodate newly-purchased 6. Improved motor efficiency. on which moisture from the hotter
units incorporating this design option. 7. Improved spray-arm geometry. dishware can condense. Since variable
Whirlpool commented that such a 8. Increased insulation. washing pressures and flow rates and
retrofit of existing residential plumbing 9. Low-standby-loss electronic controls.
10. Microprocessor controls and fuzzy logic, condenser drying are already in wide
necessary to accommodate a reduced distribution, DOE will retain these
including adaptive or soil-sensing controls.
inlet-water temperature design would be 11. Modified sump geometry, with and with- design options for further analysis.
costly, and, therefore, DOE should out dual pumps. AHAM also requested that DOE
eliminate this design option. 12. Variable washing pressures and flow replace the term ‘‘fan/jet drying’’ with
(Whirlpool, No. 10 at p. 4) DOE agrees rates. the term ‘‘fan-assist drying’’ and clarify
that this design option does not meet the term ‘‘flow-through heating.’’
the screening criterion of practicability According to Whirlpool, soil sensors (AHAM, No. 14 at p. 8) DOE believes
to install. Therefore, DOE screened out have contributed to significant that the change to fan-assist drying is
reduced inlet-water temperature from dishwasher water and energy savings. appropriate, and will designate the
further analysis. AHAM supported this However, Whirlpool is unaware of any design option in further analyses
decision. (AHAM, No. 14 at p. 8) further technological breakthroughs accordingly.
Supercritical carbon dioxide washing, which would dramatically change the ‘‘Flow-through heating’’ is
in which supercritical carbon dioxide energy consumption of dishwashers. differentiated from conventional
dissolves grease from the dishware Approximately 90 percent of dishwasher heating by the positioning
instead of conventional detergent and dishwashers are currently Energy Star- of the heating element. Conventional
water, is in the research stage, so DOE qualified. (Whirlpool, No. 10 at p. 1) dishwasher heaters use a tubular
believes it would not be practicable to DOE has noted that many dishwashers electric resistance element positioned
manufacture, install, and service at the are able to meet Energy Star inside the dishwasher cavity, above the
time of the effective date of an amended requirements without the use of a soil sump, where it is exposed to the wash
and rinse water. Flow-through heaters health or safety. Therefore, DOE has TABLE II.7.—RETAINED DESIGN OP-
pass the water through a metallic tube decided to exclude catalytic burners TIONS FOR GAS COOKTOPS—Con-
around which a resistive heating from further analysis. tinued
element is wrapped. Consequently, less In the previous rulemaking,
water is typically required in the manufacturers concluded that infrared 3. Sealed burners.
dishwasher sump for flow-through jet-impingement radiant gas burners 4. Thermostatically-controlled burners.
heaters since they form an integrated would not be able to comply with the
part of the water flow path and do not ANSI Standard Z21.1–2005, Household The Joint Comment agreed with the
require high levels of standing water Cooking Gas Appliances. Field testing inclusion of electronic ignition for gas
above the sump, as do tubular heating had shown that users were unable to ranges, and thereby for gas cooktops and
elements. Therefore, the potential exists turn down the burner satisfactorily, ovens. They stated that earlier analysis
for dishwashers using flow-through which indicated a potential health and found significant, cost-effective savings
heating to have reduced water and safety risk. More recently, a silicon achieved by eliminating pilot lights.
energy consumption. carbide radiant burner has been tested (Joint Comment, No. 9 at p. 3)
to the Japanese Industrial Standard (JIS) For electric open (coil) cooktops, DOE
b. Dehumidifiers screened out reflective surfaces, for the
S 2103–1996, Gas Burning Appliances
For dehumidifiers, all technologies for Domestic Use, but there is no data reasons that follow.
meet the screening criteria. to evaluate whether this burner would In the previous rulemaking,
Table II.6 lists the dehumidifier conform to the ANSI standard since it manufacturers reported adverse impacts
design options that DOE has retained for is not commercially available in the U.S. on consumer utility due to the
analysis. Due to potential impacts on consumer requirement for regular and careful
health and safety, DOE screened out cleaning of reflective surfaces, and this
TABLE II.6.—RETAINED DESIGN radiant gas burners from further concern remains at present.
OPTIONS FOR DEHUMIDIFIERS analysis. Furthermore, because this technology
has still not been commercialized, DOE
Reduced excess air at the burner has
1. Built-in hygrometer/humidistat. cannot assess its impacts on consumer
not been definitively shown to increase
2. Improved compressor efficiency. health and safety or equipment
efficiency. Also, because the technology
3. Improved condenser performance. availability. Therefore, DOE screened
has not been commercialized, DOE
4. Improved controls. out reflective surfaces from further
5. Improved defrost methods.
believes it would not be practicable to
analysis for electric coil cooktops.
6. Improved demand-defrost controls. manufacture, install, and service at the
Table II.8 lists the electric open (coil)
7. Improved evaporator performance. time of the effective date of an amended
cooktop design options that DOE has
8. Improved fan and fan-motor efficiency. standard. In addition, DOE cannot
retained for analysis.
9. Improved flow-control devices. assess adverse impacts on consumers’
10. Low-standby-loss electronic controls. utility, health, or safety or equipment
11. Washable air filters. TABLE II.8.—RETAINED DESIGN OP-
availability for this technology. Further,
TIONS FOR ELECTRIC OPEN (COIL)
Whirlpool suggests there are
c. Cooking Products. combustion-related issues with reducing ELEMENT COOKTOPS
For cooking products, Whirlpool excess air. (Public Meeting Transcript,
No. 5 at p. 94) DOE agrees that reducing 1. Electronic controls.
commented that DOE should eliminate 2. Improved contact conductance.
from this analysis all design options that excess air at the burner increases the 3. Insulation.
DOE eliminated in the previous possibility of adverse conditions such as 4. Low-standby-loss electronic controls.
rulemaking for reasons of feasibility, poor flame quality and elevated carbon
cost, and/or consumer safety. monoxide levels, which would suggest For electric smooth cooktops, all
(Whirlpool, No. 10 at pp. 5–7) DOE will adverse impacts on consumers’ utility, technologies meet the screening criteria.
evaluate each design option again, and health, and safety. For these reasons, Table II.9 lists the electric smooth
only will eliminate from further DOE screened out reduced excess air at cooktop design options that DOE has
consideration those technologies that the burner from further analysis. retained for analysis.
fail to meet one or more of the screening In the previous rulemaking,
criteria. manufacturers reported adverse impacts TABLE II.9.—RETAINED DESIGN OP-
on consumer utility due to the TIONS FOR ELECTRIC SMOOTH ELE-
1. Cooktops and Ovens requirement for regular and careful MENT COOKTOPS
For gas cooktops, DOE screened out cleaning of reflective surfaces, and this
catalytic burners, radiant gas burners, concern remains at present. In addition, 1. Electronic controls.
reduced excess air at burner, and since this technology has still not been 2. Halogen elements.
reflective surfaces for the reasons that commercialized, DOE cannot assess the 3. Induction elements.
follow. impacts on consumer health and safety 4. Low-standby-loss electronic controls.
DOE is not aware of any or equipment availability. Therefore,
commercialized catalytic burners for gas DOE screened out reflective surfaces for For ovens, DOE screened out added
cooktops. Therefore, DOE believes they gas cooktops from further analysis. insulation, bi-radiant oven, halogen
would not be practicable to Table II.7 lists the gas cooktop design lamp oven, no oven door window, oven
manufacture, install, and service at the options that DOE has retained for separator, reduced thermal mass, and
time of the effective date of an amended analysis. reflective surfaces, for the reasons that
standard. Also, because this technology follow.
is in the research stage, it is not possible TABLE II.7.—RETAINED DESIGN Although some analyses have shown
to assess whether it will have any OPTIONS FOR GAS COOKTOPS reduced energy consumption by
adverse impacts on equipment utility to increasing the thickness of the
consumers or equipment availability, or 1. Electronic ignition. insulation in the oven cabinet walls and
any adverse impacts on consumers’ 2. Insulation. doors from two inches to four inches,
consumer utility would be negatively An oven separator has been the oven, led DOE to eliminate this
impacted by the necessary reduction in researched but has never been put into technology from further analysis.
cavity volume to maintain the same production. Manufacturers stated during Table II.10 lists the gas and electric
oven footprint and overall cabinet the previous rulemaking that a separator oven design options that DOE has
volume. Therefore, DOE screened out could not be economically designed for retained for analysis.
added insulation. The improved conventional gas ovens. The use of a
insulation design option, however, will separator in electric ovens would TABLE II.10.—RETAINED DESIGN OP-
be retained, because insulation with a require the installation of an additional TIONS FOR GAS AND ELECTRIC
higher density (i.e., greater insulating element and a non-conventional control OVENS
value) does not require additional space system. Manufacturers also stated that it
and thus would not impact oven cavity would be difficult to obtain 1. Forced convection.
size. Underwriters Laboratory and AGA 2. Improved door seals.
The last working prototype of a bi- approvals and meet existing ANSI 3. Improved insulation.
radiant oven known to DOE was tested standards because of the effect the 4. Low-standby-loss electronic controls.
in the 1970s. The technology requires a separator would have on safety and 5. Pilotless ignition (gas only).
performance. Manufacturers also stated 6. Radiant burner (gas only).
low-emissivity cavity, electronic
7. Reduced conduction losses.
controls, and highly absorptive cooking that consumer acceptance would 8. Reduced vent rate.
utensils. The need for specialized probably be low because appliances 9. Steam cooking.
cookware and cavity maintenance issues such as microwave and toaster ovens
negatively impact consumer utility. already exist to cook small loads. In The Joint Comment recommended
Therefore, DOE screened out bi-radiant addition, the separator would have to be that DOE study the energy used by
ovens from further analysis. designed to be ‘‘fool-proof’’ to prevent ignition devices in gas ovens. (Joint
While GE currently markets a line of consumers from accidentally installing Comment, No. 9 at p. 3) DOE will
electric ovens that incorporates halogen it incorrectly. With regard to energy use, include the gas energy consumption of
elements along with conventional the additional metal added to the oven pilot lights and electrical energy
resistance heating elements, microwave by the separator (increased thermal consumption of pilotless ignition in the
heating, and, optionally, a convection mass) might result in increased energy engineering analysis (see Chapter 5 of
system, DOE is not aware of any ovens losses, although data provided by the TSD).
that utilize halogen lamps alone as the AHAM indicated an increase in
heating element, and no data were efficiency of approximately 0.82 2. Microwave Ovens
found or submitted to demonstrate how percentage points in an electric oven. For microwave ovens, all technologies
efficiently halogen elements alone However, the anticipated negative meet the screening criteria.
perform relative to conventional ovens. impacts on consumer utility and safety, Table II.11 lists the microwave oven
DOE believes that it would not be along with practicability to design options that DOE has retained for
practicable to manufacture, install, and manufacture, resulted in DOE screening analysis.
service halogen lamps for use in out the oven separator from further
consumer cooking products on the scale analysis. Whirlpool expressed support TABLE II.11.—RETAINED DESIGN
necessary to serve the relevant market at for elimination of this design option, OPTIONS FOR MICROWAVE OVENS
the time of the standard’s effective date. mentioning consumer safety as one of
Therefore, DOE screened out halogen many issues. (Public Meeting 1. Added insulation.
lamp ovens. Transcript, No. 5 at p. 95) For example, 2. Cooking sensors.
The previous rulemaking’s analysis safety issues could arise in a gas oven 3. Dual magnetrons.
reported a small annual energy savings if the separator is incorrectly installed, 4. Eliminate or improve ceramic stirrer cover.
resulting in improper burner operation. 5. Improved fan efficiency.
associated with no oven door window, 6. Improved magnetron efficiency.
but that consumer practices of opening In the previous rulemaking, 7. Improved power supply efficiency.
the door to inspect the food while manufacturers commented that a 8. Low-standby-loss electronic controls.
cooking could negate any benefit. EEI thermal mass reduction in ovens was 9. Modified wave guide.
commented during the Framework not possible without compromising 10. Reflective surfaces.
public meeting that DOE should structural integrity (during both use and
eliminate the no oven door window transportation) and increasing heat AHAM submitted written comments
design option due to the potential losses. Although tests by the Gas on the microwave oven design options.
impact on utility and safety, and it is Research Institute (GRI) showed a small For improved fan efficiency, AHAM
likely that the technology is not a efficiency improvement, the issues of commented that, since the fan accounts
feasible option for most ovens. EEI also structural integrity and associated for less than 2 percent of the total
suggested evaluating double-pane or consumer product safety led DOE to energy consumption in the microwave
similar oven door windows. (Public eliminate thermal mass reduction from oven, a high efficiency fan would
Meeting Transcript, No. 5 at p. 94; EEI, further analysis. improve energy factor by less than 0.5
No. 7 at p. 6) DOE agrees that reduced Manufacturers stated in the previous percent. Therefore, AHAM argued that
consumer utility along with decreased rulemaking that reflective surfaces efficient fans are not economically
safety due to the additional door degrade throughout the life of the oven, justified. (AHAM, No. 17 at pp. 2–3)
openings justify elimination of this particularly for self-cleaning ovens, and However, AHAM did not provide any
design option from further analysis. In GRI reported tests that showed this data that supported their conclusion of
addition, DOE addresses the efficiency design option can actually result in a a lack of economic justification.
impact of double-pane or other highly decrease of energy efficiency. The Therefore, DOE will consider improved
insulated oven door windows by means uncertainty in energy savings, coupled fan efficiency in its analysis.
of the reduced conduction losses design with a lack of sophistication in the According to AHAM, considerable
option, which has been retained for technology in terms of maintaining the effort has already been expended to
further analysis. reflective surfaces over the lifetime of optimize magnetron efficiency.
Manufacturers’ specifications indicate regarding which design options found would be practicable to manufacture,
that typical efficiency is about 73 in residential clothes washers would be install, and service on the scale
percent with only a plus or minus 2 applicable to CCWs. However, multiple necessary to serve the relevant market at
percentage point variance. Thus, AHAM manufacturers of CCWs cautioned that the time of the effective date of an
argued that there is little opportunity to CCWs are not just slightly modified amended standard. For these reasons,
improve microwave energy efficiency extensions of their residential product DOE screened out the bubble action
for manufacturers using magnetrons. lines, and, thus, some design options design option.
(AHAM, No. 17 at p. 3) A literature currently found on their residential DOE is not considering electrolytic
review that DOE performed, however, lines may not be applicable for disassociation of water and ozonated
determined that oscillation efficiencies commercial use. laundering because these technologies
of up to 78 percent have been reported. In addition, ALS requested that DOE are at the research stage. Therefore, DOE
DOE has decided to retain improved recognize the unique environment in believes that it would not be practicable
magnetron efficiency for analysis, which CCWs operate and how that to manufacture, install, and service
because this design option: (1) Is precludes the implementation of several either technology on the scale necessary
technologically feasible; (2) is design options found in the residential to serve the relevant market at the time
practicable to manufacture, install, and market. Such options could be of the effective date of an amended
service; (3) does not result in loss of incompatible with the requirements standard. Also, because these
product utility or product availability; regarding ruggedness, reliability, and technologies are in the research stage, it
and (4) does not have adverse impacts performance routinely demanded in a is not possible to assess whether they
on health or safety. commercial setting. (Public Meeting will have any adverse impacts on
AHAM commented that there are two Transcript, No. 5 at p. 43) For example, equipment utility to consumers or
types of high-voltage power supplies Whirlpool stated that design options equipment availability, or any adverse
used in microwave ovens, as described such as spray rinse have not performed impacts on consumers’ health or safety.
below. The most common type is the adequately in commercial settings due Therefore, DOE screened out electrolytic
inductive capacitance transformer, to the routine problem of overloading by disassociation of water and ozonated
which has an efficiency of about 82 consumers. Commenters also asserted laundering as design options for
percent. More expensive inverter-based that inadequate rinsing performance improving the energy efficiency of
power supplies are about 84 percent typically leads consumers to re-run CCWs.
efficient. Higher efficiency general loads, thereby increasing water and Reduced thermal mass has not been
purpose transformers do not have stable energy consumption. incorporated into clothes washers, so
enough output power for microwave Whirlpool, ALS, and AHAM DOE believes that it would not be
oven application. AHAM stated that, requested that the following design practicable to manufacture, install, and
among the units tested, there was no options be removed from consideration: service this technology on the scale
correlation between power supply type Bubble action, electrolytic necessary to serve the relevant market at
and cooking efficiency. AHAM also disassociation of water, ozonated the time of the effective date of an
does not believe there is a cost-effective laundering, reduced thermal mass, suds amended standard. Also, because this
opportunity for improving the efficiency saving, ultrasonic washing, and technology has not been incorporated
of the power supply. (AHAM, No. 17 at horizontal-axis design. Whirlpool and into clothes washers, it is not possible
p. 3) However, AHAM did not submit AHAM additionally requested that to assess whether it will have any
any data demonstrating a lack of steam washing be removed from adverse impacts on equipment utility to
correlation between power supply type consideration. Whirlpool stated that all consumers or equipment availability, or
and cooking efficiency or refuting of the aforementioned design options any adverse impacts on consumers’
economic justification. Therefore, DOE were removed from consideration health or safety. Therefore, DOE
will consider improved power supply during the recent residential clothes screened out reduced thermal mass as a
efficiency in its analysis, during which washer rulemaking and, therefore, design option for improving the energy
it will assess economic viability. should be removed from consideration efficiency of CCWs.
For reflective surfaces, AHAM during this rulemaking as well. ALS Suds-saving residential clothes
commented that manufacturers are provided a similar rationale for the washers, in which wash water is stored
already using surface finishes to design options it requested to be for subsequent reuse, were previously
optimize efficiency. Also, AHAM stated excluded. AHAM further requested that commercially available, but required an
that proper oven cavity design would the improved horizontal-axis-washer adjacent washtub to store suds in
obviate the need to add any metallic drum design option be removed. between wash cycles. Due to these
plates inside the cavity to match the (Whirlpool, No. 10 at p. 3; Public installation requirements, DOE believes
highest oscillation impedance of the Meeting Transcript, No. 5 at p. 49; that suds saving clothes washers would
magnetron. (AHAM, No. 17 at p. 2) AHAM, No. 14 at p. 7) be impractical to install in many
Testing by manufacturers, however, has In light of the available information, locations. Suds-saving clothes washers
shown that a high-grade stainless steel DOE subsequently screened out bubble reduce consumer utility by requiring
or reflective material steel coating can action, electrolytic disassociation of consumers to occupy space adjacent to
improve efficiency by 0.5 percent over water, ozonated laundering, reduced the washer with an additional washtub.
painted cold-rolled steel. Since DOE is thermal mass, suds saving, and In a commercial setting, this may limit
aware of data demonstrating efficiency ultrasonic washing from further the number of clothes washers that may
improvement as a function of surface analysis, for the reasons that follow. be installed. Consumers must also wash
reflectivity, DOE will retain reflective Although bubble washing has been clothes sequentially to fully capture the
surfaces for analysis. incorporated into commercial products, energy saving benefits of suds saving.
production is extremely limited and Delays between wash cycles allow the
d. Commercial Clothes Washers further commercialization would saved water to cool, reducing wash
During the Framework public meeting require manufacturers to develop performance and energy savings.
and Framework comment period, DOE entirely new platforms. Therefore, DOE Finally, suds-saving clothes washers can
solicited comments from stakeholders does not believe that this technology carry over heavy soiling between
clothing loads, reducing wash TABLE II.12.—RETAINED DESIGN OP- is due to past input from stakeholders
performance as well. Therefore, DOE TIONS FOR COMMERCIAL CLOTHES who were concerned about the
will not consider suds saving as a WASHERS—Continued possibility of double-counting the
design option for improving the energy energy-efficiency benefits of various
efficiency of commercial clothes 8. Improved fill control. design options. While the efficiency-
washers. 9. Improved horizontal-axis-washer drum de- level approach has the benefit of being
Ultrasonic washing promotes sign. absolute (each appliance has a tested
mechanical soil removal through the 10. Improved water extraction to lower re- efficiency and derivable manufacturing
maining moisture content.
introduction of ultrasonic vibrations 11. Increased motor efficiency.
cost), it depends on the appliance
into the wash tub. This technology has 12. Low-standby-power design. actually having an efficiency test that
been demonstrated in clothes washers, 13. Spray rinse or similar water-reducing manufacturers report. For product
but the ultrasonic clothes washer did rinse technology. classes where there are no published
not adequately remove soil from the 14. Steam washing. efficiencies, a design-option approach
clothes. Thus, ultrasonic clothes 15. Thermostatically-controlled mixing valves. remains the best alternative to an
washing would reduce consumer utility 16. Tighter tub tolerance. efficiency-level approach.
by not adequately washing clothes. In 1. Approach
addition, bubble cavitations caused by In general, for more detail on how
standing ultrasonic waves could DOE developed all of the technology DOE solicited comments during the
potentially damage some fragile clothing options discussed above and the process Framework public meeting and
or clothing fasteners, further reducing for screening these options, refer to the subsequent comment period on the
consumer utility. Since no technology and screening section possible approaches to the engineering
manufacturers currently produce (Chapter 4) of the TSD. analysis. ALS and AHAM stated during
ultrasonic clothes washers, it is C. Engineering Analysis the Framework public meeting that they
impossible to assess whether it will support the efficiency-level approach
In the engineering analysis DOE generally, and ACEEE commented that
have any impacts on consumers’ health evaluates a range of product efficiency
or safety, or product availability. For the efficiency-level approach should be
levels and their associated verified with the design-option
these reasons, DOE screened out manufacturing costs. The purpose of the
ultrasonic washing as a design option approach, recognizing that there is
analysis is to estimate the incremental variation in how manufacturers
for improving the energy efficiency of manufacturer selling prices for a
CCWs. implement design options. (Public
product that would result from Meeting Transcript, No. 5 at pp. 65, 73
In the comment period following the
achieving increased efficiency levels, and 107–110) AHAM commented that
Framework public meeting, EEI
above the level of the baseline model, in manufacturers will use different design
suggested that at least one major
each product class. The engineering options to achieve higher efficiency
detergent manufacturer has formulated a
analysis considers technologies and levels. (Public Meeting Transcript, No. 5
cold-water detergent, capable of
design option combinations not at p. 55) AHAM stated that the design-
washing all types of clothes in cold
eliminated in the screening analysis. option approach has validity only for
water. According to EEI, such detergents
The LCC analysis uses the cost- cooking products, but can serve as a
promise significant energy savings since
efficiency relationships developed in means of cross-checking the analysis for
they could eliminate the need for heated
the engineering analysis. the other products. (Public Meeting
water in CCWs. (EEI, No. 7 at p. 4) DOE typically structures its
While cold-water detergents show Transcript, No. 5 at p. 110) Whirlpool,
engineering analysis around one of three GE, and AHAM stated that DOE should
promise, the present clothes washer test methodologies. These are: (1) The
procedure does not recognize the analyze CCWs, dishwashers, and
design-option approach, which dehumidifiers with the efficiency-level
potential energy benefits of such calculates the incremental costs of approach, while using a design-option
detergents. DOE will consider possible adding specific design options to a approach for cooking products.
future amendments to the test procedure baseline model; (2) the efficiency-level (Whirlpool, No. 10 at pp. 4 and 7; GE,
to account for cold-water detergents. approach, which calculates the relative No. 13 at p. 3; AHAM, No 14 at pp. 4–
Thus, in the context of the present costs of achieving increases in energy 9)
rulemaking, DOE will not analyze the efficiency levels, without regard to the In comments submitted during the
potential impact of cold-water particular design options used to comment period after the Framework
detergents. achieve such increases; and/or (3) the public meeting, the Joint Comment
Table II.12 lists the CCW design
reverse engineering or cost-assessment disagreed with using the efficiency-level
options that DOE has retained for
approach, which involves a ‘‘bottom- approach as the primary means to
analysis. For further review of the
up’’ manufacturing cost assessment estimate efficiency costs. The Joint
retained design options, please see
based on a detailed bill of materials Comment stated that the design-option
Chapter 3 of the TSD. approach is very important and should
derived from teardowns of the product
being analyzed. Deciding which be included for all products as a
TABLE II.12.—RETAINED DESIGN OP- methodology to use for the engineering complement to and validation of
TIONS FOR COMMERCIAL CLOTHES analysis depends on the product, the manufacturer estimates. The Joint
WASHERS design options under study, and any Comment stated that manufacturers
historical data that DOE can draw on. have historically estimated higher costs
1. Adaptive control systems. Traditionally, DOE used a design- during the rulemaking stage, as
2. Added insulation. approach for all of its cost-benefit compared to the actual costs when the
3. Advanced agitation concepts for vertical-
axis machines.
analyses. However, in more recent standards take effect. In addition, the
4. Automatic water fill control. rulemakings, DOE has shifted to using design-option approach allows
5. Direct-drive motor. an efficiency-level approach that may or interactions between design options to
6. Horizontal-axis design. may not be supplemented with a factor into the analysis to take advantage
7. Horizontal-axis design with recirculation. reverse-engineering analysis. The shift of synergies between measures and to
avoid double-counting of energy product classes for which industry- available to evaluate consumer usage of
savings. The Joint Comment also supplied curves were not provided. The a product incorporating the technology,
expressed the need for DOE to make methodology DOE used to perform the and, therefore the test procedure
detailed manufacturing cost data efficiency-level and design-option conditions and methods may not be
publicly available, while maintaining analyses is described in further detail in applicable; (2) data are not available to
manufacturers’ confidentiality to protect the engineering analysis (Chapter 5 of evaluate the energy efficiency
their competitive positions. They the TSD). characteristics of the technology; and (3)
described manufacturer cost estimates The Joint Comment recommended available data suggest that the efficiency
as a ‘‘black box’’ for other stakeholders. that the computation of manufacturing benefits of the technology are negligible.
(Joint Comment, No. 9 at pp. 1–2) costs also take into account the effect of In the first two cases, DOE is unable to
DOE conducted the engineering market forces by using the simple adequately assess how these
analysis for this rulemaking using an average of the lowest cost estimate and technologies impact annual energy
efficiency-level approach supplemented the weighted-average cost. The Joint consumption. Although it did not
by a design-option approach for CCWs, Comment stated that manufacturers consider these technologies further in
dishwashers, and dehumidifiers. DOE with below-average costs will determine the ANOPR analyses, DOE specifically
based this analysis on detailed market prices, since higher-priced seeks data and inputs on consumer
incremental cost data primarily manufacturers will need to ‘‘sharpen usage, performance characteristics, and
supplied by AHAM. DOE supplemented their pencils’’ to reduce costs in order representative test methods and
these industry-supplied data with its to maintain market share. Additionally, conditions to extend the analyses to
own design-option analysis by the Joint Comment stated that these technologies and to evaluate the
performing limited product efficiency manufacturers should ensure that their test procedures for the NOPR. This is
testing and physical teardown analysis cost estimates reflect mass production, identified as Issue 6 under ‘‘Issues on
of several dishwashers and since efficiency standards will make Which DOE Seeks Comment’’ in section
dehumidifiers, and by conducting today’s niche products commodity IV.E of this ANOPR.
manufacturer interviews for all three products in the future. (Joint Comment,
For technologies that lack consumer
products. The teardown analysis used No. 9 at p. 2) In response, we note that
usage details (including operating
the reverse engineering approach and DOE conducted its analysis using the
conditions, duration, and frequency),
resulted in the production of detailed average costs provided by industry,
DOE believes that the existing test
bills of materials for dishwashers and because DOE believes these are the most
dehumidifiers. procedures may specify conditions and
representative of manufacturer costs.
For cooking products, DOE conducted methods that are not representative of
The AHAM-supplied average cost by
the engineering analysis for this actual usage. DOE further believes that
efficiency level is shipment-weighted,
rulemaking using the design-option even if data were available to amend the
which thus represents the most likely
approach, under which it identifies test procedure, such changes could be
average cost for the industry to make an
incremental increases in manufacturer extensive enough to require total
incremental efficiency change. The
selling prices for each design option or revision, which in turn could warrant
limited DOE reverse-engineering
combination of design options. As the creation of a separate product class
analysis based on two dishwasher
discussed in section I.B.1 of this for that technology in the event that the
platforms that span an efficiency range
ANOPR, DOE based much of this test procedure changes indicated unique
from 0.58 to 1.11 EF also largely agreed
analysis on cost and efficiency utility. For example, many
with the AHAM-supplied average
information supplied in the previous dehumidifiers feature a built-in relative
incremental cost data. The effects of
rulemaking’s analysis, with costs humidity (RH) sensor, or hygrometer,
mass production were captured in the
updated to reflect current pricing. DOE and most (including all units upon
cost estimates and reflected in the
supplemented this analysis with new which DOE conducted reverse-
production volume estimates that
data that AHAM supplied for engineering) feature a built-in
AHAM provided, as well as in the
microwave ovens. humidistat, a device that allows the
production volumes used in DOE’s cost
In summary, DOE used an efficiency- consumer to set the desired RH level for
modeling.
level approach supported by a design- the room. When the humidity near the
The methodology DOE used to
option approach for CCWs, dehumidifier drops below the user-
perform the efficiency-level and design-
dishwashers, and dehumidifiers, and a defined or pre-set value, the
option analyses and reverse engineering
design-option approach for cooking dehumidifier automatically shuts off.
are described in further detail in the
products. Stakeholders were supportive This sensor-controlled system
engineering analysis chapter (Chapter 5)
of this approach for cooking products. presumably saves energy by avoiding
of the TSD.20
For CCWs, dishwashers, and running the dehumidifier when the RH
dehumidifiers, DOE supplemented the 2. Technologies Unable To Be Included is such that further dehumidification
industry-supplied data with in the ANOPR Analysis would be neither effective nor desirable.
consultation with outside experts and In performing the engineering However, there is no industry consensus
further review of publicly available cost analysis, DOE did not consider for on patterns in ambient conditions and
and performance information. The analysis certain technologies that met usage. If such parameters were known to
supplemental design-option analysis the screening criteria but were unable to DOE, the test procedure, which
(which included the reverse be further evaluated for one or more of currently specifies constant ambient
engineering) allowed for validation of the following reasons: (1) Data are not temperature and humidity, would need
the efficiency-level data, transparency to be revised to measure energy savings

in assumptions and results, and the 20 The engineering analysis does not take into associated with these technologies.
ability to perform independent analyses account future increases in manufacturing Therefore, the built-in hygrometer/
for verification. In addition, the efficiency which would affect the cost-efficiency humidistat design option was not
relationship, due to the inherently speculative
supplemental design-option analysis nature of such an inquiry. Accordingly, this
considered for further analysis. Similar
allowed DOE to generate analytically- analysis is based on extant products and exclusions based on lack of information
derived cost-efficiency curves for manufacturing processes. on representative consumer usage were
made for several other design options. modified waveguides, or added For the purpose of today’s ANOPR,
For dehumidifiers, these included insulation. (AHAM, No. 17 at pp. 2–3) DOE considers the highest candidate
improved controls, improved flow- Similarly, DOE is unaware of any data standard levels, identified in section
control devices, and low-standby-loss that indicates a measurable energy II.C.3 below, to be the maximum
controls. For cooking products, these efficiency impact of insulation in gas technologically feasible level. DOE
included thermostatically-controlled gas and electric coil cooktops. DOE will be notes that in some cases the highest
cooktop burners, electronic controls for reevaluating microwave oven design efficiency level was identified based on
electric cooktops, cooking sensors for options through reverse-engineering, a review of available product literature
microwave ovens, and steam cooking for and will update the design options and for products commercially available
electric ovens. efficiency levels as necessary for the (i.e., commercial clothes washers and
Furthermore, certain technologies NOPR. For commercial clothes washers, dehumidifiers). For cooking products,
cannot be measured according to the DOE removed improved drum designs the maximum levels identified in
conditions and methods specified in the for horizontal-axis clothes washers. section II.C.3.c are based on data
existing test procedure. For example, Because DOE intends to focus on the developed from the design option
induction cooktops require technologies with measurable impact on analysis in the previous rulemaking.
ferromagnetic cookware in order to efficiency, design options with (For more information, see the market
transfer energy to the food contents. The negligible energy savings have been and technology assessment (Chapter 3)
test block specified in the DOE test eliminated from further consideration. and engineering analysis (Chapter 5) of
procedure is aluminum and thus is For further information on these the TSD.) Because DOE is required to
unable to measure the efficiency of design options, refer to the market and determine the maximum technologically
induction cooktops. Although DOE is technology assessment chapter (Chapter feasible energy efficiency level(s) in any
aware of a NIST study that suggests 3) and engineering analysis chapter notice of proposed rulemaking (42
induction cooktops provide an (Chapter 5) of the TSD. U.S.C. 6295 (p)(2)), DOE seeks comment
efficiency improvement over baseline on the highest energy efficiency levels
electric smooth cooktops, DOE did not 3. Product Classes, Baseline Models, identified in today’s ANOPR for the
consider this design option further in and Efficiency Levels Analyzed purpose of determining appropriate
the ANOPR analysis because of the DOE conducted the engineering maximum technologically feasible
unresolved nature of the NIST data. analysis on the single product class for energy efficiency levels in the proposed
DOE seeks input from stakeholders on CCWs and on all product classes for rule.
whether the NIST data warrants further cooking products. For dishwashers,
study for the NOPR. Similarly, for a. Dishwashers
DOE identified baseline models and
dehumidifiers DOE excluded improved For dishwashers, the energy
efficiency levels for the standard-sized conservation standards are expressed as
defrost measures and washable air dishwasher product class. It then scaled
filters. Low-standby-loss electronic a minimum EF, which is a function of
these standard dishwasher efficiency cycles per kWh. In this rulemaking,
controls were not analyzed for electric
levels by the ratio of the current DOE is using baseline models that have
cooktops, microwave ovens, and
minimum efficiency standards for the following efficiencies, which are the
commercial clothes washer because,
standard-versus-compact product current minimum standards for compact
even though DOE considers consumer
classes to obtain the efficiency levels for and standard capacity dishwashers (10
usage of these products to be well-
compact-sized machines. For CFR 430.32(f)):
defined, the current test procedures do
dehumidifiers, DOE conducted the • Compact = 0.62 EF
not measure standby power. For
engineering analysis on product classes • Standard = 0.46 EF
microwave ovens specifically, for
for which it received incremental cost For standard dishwasher efficiency
reasons described in section I.D.4.b,
DOE is considering amending the test data, with the expectation that the levels, DOE used the Energy Star
procedure to incorporate a measurement analysis results will be extended to the criteria, CEE Tier 1 and 2 levels, and the
of standby power consumption. Other remaining product classes in subsequent current maximum technology that is
cooking product technologies that do analyses. commercially available. DOE also added
not have energy benefits captured by the For each product class, DOE selected two levels to fill the gap between CEE
test procedures include radiant burners a baseline model as a reference point, Tier 2 and the current maximum
for gas ovens. As mentioned above, DOE against which to measure changes technology that is commercially
specifically seeks data and inputs on resulting from energy conservation available. DOE achieved scaling for
representative test methods and standards. The baseline model in each compact dishwashers by using the ratio
conditions to extend the analyses to product class represents the basic of current standard levels for standard
these technologies and to evaluate the characteristics of products in that class. size versus compact size units, although
test procedures for the NOPR. This is Typically, it is a model that just meets it determined the max-tech level by a
identified as Issue 6 under ‘‘Issues on current required energy conservation review of technology in the current
Which DOE Seeks Comment’’ in section standards. Energy Star database of certified
IV.E of this ANOPR. Tables II.13 through II.20 provide all dishwashers. Table II.13 lists the levels
Available data suggest that some of of the efficiency levels DOE analyzed in DOE analyzed for compact and standard
the design options would result in such the engineering analysis and the dishwashers:
small energy savings as to be negligible. reference source of each level for each
For example, according to AHAM, dual of the four appliance product classes TABLE II.13.—EFFICIENCY LEVELS FOR
magnetrons in microwave ovens do not analyzed. Many of these efficiency RESIDENTIAL DISHWASHERS
improve energy efficiency due to the levels correspond to those set by energy
added losses associated with two efficiency programs or organizations, Energy Factor,
magnetron heaters. AHAM also including the DOE and EPA Energy Star (cycles/kWh)
Efficiency levels
commented that are no significant Program, and the CEE. DOE calculated Compact Standard
energy savings opportunities associated other levels from existing levels to fill
with improved ceramic stirrers, in gaps. Baseline .................... 0.62 0.46
TABLE II.13.—EFFICIENCY LEVELS FOR In light of the above, DOE believes energy consumption. The Multiple
RESIDENTIAL DISHWASHERS—Con- that setting the baseline at the current Water Organizations recommended
tinued Federal standard appropriately analyzes assigning a water factor to each
entry-level dishwashers, and, thus, we proposed dishwasher efficiency level,
Energy Factor, are retaining an engineering baseline EF and substantiating the relationship
Efficiency levels (cycles/kWh) of 0.46 for standard-sized dishwashers. between energy and water consumption.
As will be discussed in section II.G.2.d, They stated that water consumption is
Compact Standard because some consumers already not so tightly correlated with energy
1 ................................ 0.78 0.58
purchase products with efficiencies consumption as to obviate the need for
2 ................................ 0.84 0.62 greater than the baseline levels, the LCC a separately stated WF. They referred
3 ................................ 0.88 0.65 and PBP analysis considers the DOE to databases maintained by NRCan
4 ................................ 0.92 0.68 distribution of products currently sold. and the Oregon Department of Energy
5 ................................ 1.01 0.72 This is done to accurately estimate the for data on dishwasher energy and water
6 ................................ 1.08 0.80 percentage of consumers that would be consumption. (Public Meeting
7 ................................ 1.74 1.11 affected by a particular standard level Transcript, No. 5 at p. 63; Joint
and to prevent overstating the benefits Comment, No. 9 at pp. 3–4; Multiple
DOE has specified the current Federal to consumers of increased minimum Water Organizations, No. 11 at p. 3)
dishwasher standard as the baseline efficiency standards. Also, as will be DOE notes that it does not have
unit efficiency level, recognizing that a discussed in section II.I.2, the resulting statutory authority to prescribe a water
significant percentage of dishwashers on shipment-weighted efficiency (SWEF) consumption standard for dishwashers.
the market meet or exceed Energy Star that is determined from the distribution The City of Seattle suggested that DOE
levels. Whirlpool agreed with this of products currently sold, as well as base the efficiency metric on energy and
approach, commenting that this baseline historical SWEFs, are accounted for in water use per place setting, rather than
efficiency level maintains a necessary the NIA. an EF according to the two product
entry-level product. It noted that raising Whirlpool commented that, of the classes. (Public Meeting Transcript, No.
the baseline efficiency above the efficiency levels suggested in the 5 at p. 58) In response, we note that the
standard could make entry-level Framework Document, efficiency levels current test procedure does not have
dishwashers unaffordable to low-end up to an EF of 0.68 are reasonable, while any provision for defining efficiency as
consumers, thus driving down market the ‘‘gap fill’’ levels are arbitrary and the a function of the number of place
penetration of dishwashers and max-tech level is taken from an settings a dishwasher can clean, and,
increasing hand-washing and the extremely expensive, niche machine therefore, DOE is currently unable to
associated water and energy from a manufacturer with negligible define an efficiency metric on this basis.
consumption. Whirlpool also market share. (Whirlpool, No. 10 at p. 4) Whirlpool commented that cleaning
commented that market-pull programs ACEEE and the Joint Comment performance must be taken into
such as Energy Star are responsible for recommended including an efficiency consideration at higher efficiency levels,
higher efficiency units on the market. level for standard dishwashers between and it stated that, at the max-tech level,
(Public Meeting Transcript, No. 5 at pp. the 0.68 and 0.75 EF levels. They cleaning performance would be highly
59–60 and 66–67; Whirlpool, No. 10 at suggested an EF of 0.71 or 0.72 since suspect. (Public Meeting Transcript, No.
p. 8) there are three manufacturers with 5 at p. 123) DOE notes that while there
models currently at 0.72 EF. (Public is no provision in the current DOE test
Northwest Power and Conservation Meeting Transcript, No. 5 at p. 124;
Council (NWPCC), however, procedure for measuring cleaning
Joint Comment, No. 9 at p. 4) DOE performance, interviews conducted by
commented that the baseline EF may selected a 0.72 EF dishwasher as one of
need to be raised above the current DOE with manufacturers indicated that
its teardown units on the basis of its the manufacturers are unwilling to
Federal standard. (Public Meeting highest level of design option
Transcript, No. 5 at p. 57) Other compromise cleaning performance to
combinations for a given platform. achieve higher energy efficiency at the
stakeholders agreed. For example, Additionally, AHAM stated that some
Potomac commented that the baseline expense of market share. Manufacturer
efficiency levels exceed the point for concerns over the potential loss of
EF should represent a shipment- which AHAM members can provide
weighted average (likely to be between consumer utility at higher standard
meaningful cost-efficiency data. levels are discussed in Chapter 12, MIA,
0.46 and 0.58), which was the Energy (AHAM, No. 14 at p. 8) Thus, AHAM’s
Star level in effect at the time of the of the TSD.
aggregated manufacturer data were
Framework public meeting. (Public limited to a maximum EF of 0.72. DOE b. Dehumidifiers
Meeting Transcript, No. 5 at pp. 123– included this efficiency level in its For dehumidifiers, each energy
124) ACEEE commented that, since over analysis because one of the platforms efficiency level is expressed as a
80 percent of the market meets the upon which DOE performed the reverse- minimum EF, which is a function of
current Energy Star level, that level engineering analysis included a model liters per kWh. In this rulemaking, DOE
might be appropriate as the baseline. at an EF of 0.72 as its highest efficiency is using baseline models that have the
(Public Meeting Transcript, No. 5 at p. version. DOE extended its analysis to following efficiencies, which are the
124) After the Framework public include EF up to the max-tech level of current minimum standards for this
meeting, the Multiple Water 1.11 because this unit represented the product (EPACT 2005, section 135(c)(4);
Organizations stated that the baseline high end of an additional product 42 U.S.C. 6295(cc); 70 FR 60407, 60414,
should be above the current Federal platform that DOE reverse-engineered. (October 18, 2005); 10 CFR 430.32(v)):
standard, and that using the standard as The Joint Comment, Multiple Water • 25.00 pints/day or less = 1.00 EF
the baseline would distort the analyses Organizations, and Austin Water Utility • 25.01–35.00 pints/day = 1.20 EF
by making higher efficiency levels (AWU) commented that DOE should • 35.01–45.00 pints/day = 1.30 EF
appear more costly and burdensome to conduct an analysis to determine • 54.01–74.99 pints/day = 1.50 EF
achieve than they really are. (Multiple whether it should define a standard for DOE combined two product classes
Water Organizations, No. 11 at p. 3) water consumption in addition to defined by EPACT 2005—25.00 pints/
day or less and 25.01–35.00 pints/day— p. 4 ; EEI, No. 7 at pp. 3 and 5) Whirlpool also commented that the
to form a single product class of 0–35.00 Whirlpool recommended defining efficiency standards described by the EF
pints/day for this analysis, due to the ‘‘small’’ as <25 pints/day, ‘‘medium’’ as level of 1.50 may not be attainable and
similar aggregation of data by AHAM in 35–45 pints/day, and ‘‘large’’ as 75+ should be reduced to an EF of 1.45.
its manufacturer cost data submittal. pints/day capacity. (Whirlpool, No. 10 Whirlpool stated that an EF of 1.50
EPACT 2005 also defines two other at p. 5) AHAM recommended that DOE would make dehumidifiers so expensive
product classes, 45.01–54.00 pints/day analyze separately each capacity range that consumers would forgo them and
and 75.00 pints/day or more, which mentioned in the Framework Document, live with damp, unhealthy basements
DOE did not analyze since AHAM did because component availability, instead. Thus, Whirlpool argued that an
not provide data for them. For purposes compressor efficiencies, and other even higher EF level would not be
of conducting the NIA, DOE believes factors vary widely. (AHAM, No. 14 at economically justified, and it
that the results from the product classes p. 9) As discussed above, DOE recommended that DOE drop the max-
analyzed can be extended to the two performed a complete analysis for the tech level EF of 1.74. (Whirlpool, No. 10
statutorily-set product classes for which product classes for which AHAM at p. 5)
AHAM data (or comparable data) are supplied data, and extended the results
unavailable. This approach is believed to the remaining product classes in Based on comments received, DOE
to be valid due to chassis and subsequent analyses. analyzed three product classes (0–35.00
component similarities among the DOE received numerous comments pints/day, 35.01–45.00 pints/day, and
product classes, with primary from stakeholders regarding the 54.01–74.99 pints/day) and five
differences due to scaling. DOE’s appropriateness of the dehumidifier efficiency levels for each product class.
approach for extending the results to the energy efficiency levels under review in The levels DOE analyzed are set forth in
omitted product classes is discussed the Framework Document. AHAM Table II.14. DOE also reviewed the
further in section II.I.3 of this ANOPR. stated concerns regarding the max-tech efficiency levels proposed in the
DOE seeks comment on this approach to and some of the intermediate efficiency Framework Document using available
extend the engineering analysis to levels, recommending that DOE databases, stakeholder interviews, and
product classes for which a complete eliminate the EF level of 1.74 for the 35– insights from the reverse engineering
analysis was not performed. 45 pints/day product category and efforts. As discussed above, through its
In the Framework public meeting and replace it with an EF level of 1.45–1.50, tear-down analysis, DOE found
during the Framework comment period, which AHAM argued is more dehumidifiers with energy efficiency
DOE received comments on the representative of max-tech in that levels at the highest candidate standard
dehumidifier engineering analysis capacity range. (Public Meeting level identified in section III of today’s
approach. All stakeholders agreed that Transcript, No. 5 at pp. 72 and 129; notice. Therefore, DOE believes that the
DOE should analyze multiple product AHAM, No. 14 at p. 9) EEI questioned efficiency levels defined in the
classes to capture the particular some of the max-tech levels set for the Framework Document are representative
efficiency characteristics of varying lower capacity ranges. (Public Meeting of currently available models, and,
capacity levels. Instead of extrapolating Transcript, No. 5 at p. 126) Referring to therefore, we have retained them for
from one capacity platform, multiple Table 5.3 in the Framework Document, further analysis. DOE seeks comment on
stakeholders recommended analyzing a Whirlpool commented that the industry the highest energy efficiency levels
minimum of three capacities (small, considers an EF of 1.4 for 35–45 pints/ identified in today’s ANOPR for the
medium, and large) to serve as a day as the de facto baseline efficiency purpose of determining appropriate
baseline. (Public Meeting Transcript, standard. Thus, Whirlpool stated that maximum technologically feasible
No. 5 at pp. 70 and 126–128; AHAM, DOE should drop the EF levels of 1.35 energy efficiency levels in the proposed
No. 14 at p. 9; Joint Comment, No. 9 at and below for this product class. rule.
TABLE II.14.—EFFICIENCY LEVELS FOR RESIDENTIAL DEHUMIDIFIERS

Energy factor (liters/kWh)
0–35.00 35.01–45.00 54.01–74.99

Efficiency levels (pints/day) (pints/day) (pints/day)
Baseline ....................................................................................................................................... 1.20 1.30 1.50

1 ................................................................................................................................................... 1.25 1.35 1.55
2 ................................................................................................................................................... 1.30 1.40 1.60
3 ................................................................................................................................................... 1.35 1.45 1.65
4 ................................................................................................................................................... 1.40 1.50 1.70
5 ................................................................................................................................................... 1.45 1.74 1.80
c. Cooking Products the ratio of the annual useful cooking • Electric cooktops, open (coil)
energy output of the residential cooking elements = 0.737 EF
For residential cooking products appliance (i.e., the energy conveyed to • Electric cooktops, smooth elements
(except for the prescriptive standard for the item being heated) to its total annual = 0.742 EF
gas products), there are no existing energy consumption. In accordance • Gas cooktops, conventional burners
minimum energy conservation with the previous rulemaking for = 0.156 EF
standards, as previous analyses failed to residential cooking products, DOE has • Electric ovens, standard with or
determine economic justification for without a catalytic line = 0.107 EF
selected the following baseline EFs for
them. The DOE test procedure uses an
the product classes DOE is using in this • Electric ovens, self-clean = 0.096 EF
EF to rate the efficiency of cooking • Gas ovens, standard with or without
rulemaking:
products. The EF for these products is a catalytic line = 0.030 EF
• Gas ovens, self-clean = 0.054 EF will not analyze commercial-type ranges without a catalytic line, the baseline
• Microwave ovens = 0.557 EF (the type of appliances normally efficiency level assumes that the
During the Framework public incorporating high-input-rate burners) product is equipped with standing pilot
meeting, Whirlpool suggested that DOE as a separate product class. lights and the first standards efficiency
might need to update baseline efficiency During the Framework public level corresponds to the elimination of
levels to reflect changes in current oven meeting, the AWU questioned whether standing pilot lights. However, because
cavity volumes. DOE has defined baseline units would be equipped with the cleaning cycle of gas self-clean
baseline volumes for gas and electric standing pilot ignition systems, while ovens requires electrical energy use,
non-self cleaning and self-cleaning Whirlpool stated that self-cleaning EPCA in effect requires that such ovens
ovens as 3.9 cubic feet in accordance ovens do not have standing pilot lights. currently be equipped with a non-
with the previous rulemaking. (Public Meeting Transcript, No. 5 at p. standing pilot ignition system because a
Whirlpool believes this volume is too 136 and 138) In comments received after standing pilot light ignition system is
small to be representative of current the Framework public meeting, EEI disallowed if there is an electrical cord
ovens. At the Framework public stated that gas pilot lights contribute to provided on the product. Therefore, the
meeting, Whirlpool stated that, since the significant standby energy losses. baseline efficiency level for these ovens
mid-1990s, oven volumes have According to EEI calculations, gas assumes they lack a standing pilot light,
increased due to consumer usage cooktop pilot lights (assuming 8000 as do all of the efficiency levels DOE
patterns and consumer demand. As a hours of standby) account for 18.72 analyzed for this rulemaking. Further,
result, Whirlpool stated that a more therms of the total annual baseline the first standards efficiency level is not
representative baseline volume would energy consumption of 33 therms, or based on elimination of a standing pilot,
be five cubic feet. (Public Meeting 56.7 percent. Similarly, of the 29.6 but rather on the addition of the forced
Transcript, No. 5 at pp. 90 and 132) therms annual baseline energy convection design option. For
DOE has retained the 3.9 cubic feet consumption for standard gas ovens, EEI microwave ovens, DOE used the
volume to define the efficiency standard attributes 14.0 therms, or 47.3 percent, efficiency levels corresponding to those
at baseline because there are a large to the pilot light. (EEI, No. 7 at p. 5) in the previous rulemaking, after first
number of ovens on the market sized for Conversely, AGA disputed DOE’s determining that these levels are
a 27-inch built-in installation which presumption of significant energy representative of the range of
incorporate this cavity volume. The savings associated with the elimination efficiencies of currently-available
analysis accounts for larger oven cavity of standing pilot lights. AGA argued that products. Tables II.15 through II.19 set
volumes by scaling the efficiency it is likely that less that 20 percent of forth the levels DOE analyzed for
standard according to linear functions. gas ranges currently have pilot ignition, cooking products. For open coil-type
DOE defined these scaling functions for and therefore potential energy savings and smooth electric cooktops, only a
gas and electric standard and self- will be less than the 0.06 quads over 30 single standards efficiency level is
cleaning ovens based on oven volume, years that DOE had estimated in the analyzed because design options
since it is recognized that efficiency is prior rulemaking. AGA concluded that associated with higher efficiency levels
affected by thermal mass and vent rates pilot ignition cooking appliances are a were either screened out, as described
that are functions of volume. The niche product with unique utility, and in section II.B.2.c.1, or eliminated from
scaling functions consist of linear their elimination would result in equity the analysis for the reasons described in
equations relating EF to volume, which issues to consumers for whom installing section II.C.2. For gas and electric
are described in greater detail in the electrical service adjacent to the range ovens, the efficiency levels reported in
TSD. DOE believes the slopes and hookup is not economically justified. Tables II.17 and II.18 are slightly
intercepts of these equations from the (AGA, No. 12 at pp. 2–3) DOE has different than those identified in the
previous rulemaking to still be valid. structured the analysis for standing pilot previous rulemaking’s analysis. Refer to
Whirlpool agreed that oven efficiency is igntion systems as a design option Chapter 5 of the TSD for an explanation
a function of volume, and stated that the associated with the baseline of the cause for these slight differences
relationship is similar for gas and configurations because DOE has in the oven efficiency levels.
electric ovens. However, Whirlpool determined that cooktops incorporating
commented that DOE should review the such ignition systems do not provide TABLE II.15.—EFFICIENCY LEVELS FOR
linear equations from the previous unique utility. Power outages are not RESIDENTIAL GAS COOKTOPS
rulemaking. (Public Meeting Transcript, frequent and long enough for residential
No. 5 at pp. 90, 133, and 138) DOE has electricity customers to consider Conventional burners
not identified any technological changes operation during a lack of electric power
that would impact the efficiency- a significant utility. Between 90 and 93 Cooking ef- Energy fac-
Efficiency levels ficiency tor
volume relationship, and, therefore, we percent of such customers experience
are retaining the equations as defined. no electricity outages longer than four Baseline ............ 0.399 0.156
Whirlpool also suggested that baseline hours per year.21 1 ........................ 0.399 0.399
efficiency levels might need to account To analyze the cost-efficiency 2 ........................ 0.420 0.420
for sealed burners and high-input-rate relationships for each of the classes of
burners as separate product classes. cooking products, DOE retained the Whirlpool and GE both commented
(Public Meeting Transcript, No. 5 at p. efficiency levels from the previous that gas cooktop efficiencies should
131) As discussed previously, DOE rulemaking for residential cooking scale with burner size, in a similar
determined that sealed burners do not products. For gas cooktops/conventional manner as the relationship between
warrant a separate product class due to burners and gas standard ovens with or oven efficiency and volume. (Public
insufficient evidence that the Meeting Transcript, No. 5 at pp. 134–
performance of sealed burners is 21 A. P. Sanghvi, Cost-Benefit Analysis of Power 135) The test procedure, however,
distinct from that of conventional open System Reliability: Determination of Interruption currently contains provisions for testing
Costs. Prepared by RCG/Hagler Bailly, Inc.,
gas burners. Therefore, DOE analyzed a Arlington, VA for Electric Power Research Institute,
gas cooktop burners with different size
single product class for gas cooktops. Palo Alto, CA, EL–6791. Vol. 2, p. 3–3 and Vol. 3, test blocks, depending on maximum
Given the lack of empirical data, DOE p. 3–3. Available online at http://www.epri.com. burner firing rate. Because the test
procedure already accounts for burner efficiency levels without a scaling

size, DOE will retain the existing function for burner size.
TABLE II.16.—EFFICIENCY LEVELS FOR RESIDENTIAL ELECTRIC COOKTOPS

Open (coil) elements Smooth elements
Efficiency levels
Cooking efficiency Energy factor Cooking efficiency Energy factor
Baseline .......................................... 0.737 .............................................. 0.737 0.742 .............................................. 0.742

1 ...................................................... 0.769 (max-tech) ............................ 0.769 0.753 (max-tech) ............................ 0.753
DOE received a comment from electric cooktops listed in Table II.16 are technology. (Public Meeting Transcript,
Whirlpool that the efficiency levels for representative of currently available No. 5 at p. 137)
TABLE II.17.—EFFICIENCY LEVELS FOR RESIDENTIAL GAS OVENS

Standard oven Self-cleaning oven
Efficiency levels
Baseline .......................................... 0.059 .............................................. 0.0298 0.071 .............................................. 0.0540

1 ...................................................... 0.058 (globar ignition) .................... 0.0536 0.088 .............................................. 0.0625
2 ...................................................... 0.061 .............................................. 0.0566 0.088 .............................................. 0.0627
3 ...................................................... 0.062 .............................................. 0.0572 0.089 (max-tech) ............................ 0.0632
4 ...................................................... 0.065 .............................................. 0.0593 ........................................................ ........................
5 ...................................................... 0.065 .............................................. 0.0596 ........................................................ ........................
6 ...................................................... 0.066 (max-tech) ............................ 0.0600 ........................................................ ........................
1a(1) ................................................ 0.058 .............................................. 0.0583 ........................................................ ........................
Note: Efficiency levels 1 and 1a correspond to designs that are utilized for the same purpose—eliminate the need for a standing pilot—but the
technologies for each design are different. Efficiency level 1 is a hot surface ignition device while efficiency level 1a is a spark ignition device. Ef-
ficiency level 1a is presented at the end of the table because efficiency levels 2 through 6 are derived from efficiency level 1.
TABLE II.18.—EFFICIENCY LEVELS FOR RESIDENTIAL ELECTRIC OVENS

Standard oven Self-cleaning oven
Efficiency levels
Baseline .......................................... 0.122 .............................................. 0.1066 0.138 .............................................. 0.1099

1 ...................................................... 0.128 .............................................. 0.1113 0.138 .............................................. 0.1102
2 ...................................................... 0.134 .............................................. 0.1163 0.142 (max-tech) ............................ 0.1123
3 ...................................................... 0.137 .............................................. 0.1181 ........................................................ ........................
4 ...................................................... 0.140 .............................................. 0.1206 ........................................................ ........................
5 ...................................................... 0.141 (max-tech) ............................ 0.1209 ........................................................ ........................
TABLE II.19.—EFFICIENCY LEVELS FOR manufacturers select higher wattage conservation standards: A minimum
RESIDENTIAL MICROWAVE OVENS lamps for product differentiation. MEF of 1.26 and a maximum WF of 9.5.
Manufacturers also may focus on (EPACT 2005, section 136(e); 42 U.S.C.
Energy fac- features that optimize cooking 6313(e); see also 70 FR 60416 (Oct. 18,
Efficiency levels tor performance, such as mode stirrers, that 2005), adding 10 CFR 431.156) In this
may also be accompanied by small rulemaking, DOE is using a baseline
Baseline .................................... 0.557 increases in energy consumption.
1 ................................................ 0.586 (AHAM, No. 17 at p. 2) DOE recognizes model that has those efficiencies.
2 ................................................ 0.588
that manufacturers may choose to As indicated previously for CCWs,
3 ................................................ 0.597 EPCA mandates that DOE determine
4 (max-tech) ............................. 0.602
incorporate features that enhance
product differentiation at the expense of both a minimum MEF and a maximum
energy consumption. For a given energy WF. For the purposes of analyzing the
AHAM noted that many microwave efficiency level, manufacturers must cost-efficiency relationships for this
oven design features impact energy weigh the appropriate combination of product, DOE based some of the
efficiency, and that the choice of design options and other features to efficiency levels on the MEF and WF
features may be dictated by marketplace meet the energy consumption specifications prescribed by the Energy
demands. For example, higher wattage requirement set forth in the relevant Star program and the CEE Commercial
cavity lamps produce a brightly efficiency standard. Clothes Washer Initiative, and the
illuminated cavity interior, but maximum levels that are currently

increasing the lamp wattage by only 10 d. Commercial Clothes Washers
commercially available. These levels are
watts could lower efficiency by about For all CCWs, EPCA establishes the set forth in the Table II.20:
0.5 percent. Even so, some following energy and water
TABLE II.20.—EFFICIENCY LEVELS FOR COMMERCIAL CLOTHES WASHERS

Modified Energy Water Factor
Efficiency levels Factor (ft 3/kWh) (gallons/ft 3)
Baseline ............................................................................................................................................................... 1.26 9.5

1 ........................................................................................................................................................................... 1.42 9.5
2 ........................................................................................................................................................................... 1.60 8.5
3 ........................................................................................................................................................................... 1.72 8.0
4 ........................................................................................................................................................................... 1.80 7.5
5 ........................................................................................................................................................................... 2.00 5.5
6 (max-tech) ......................................................................................................................................................... 2.20 5.1
In the Framework public meeting and petition’s WF breakpoint of 6.0.22 In addition to comments regarding the
during the Framework comment period, (Public Meeting Transcript, No. 5 at p. appropriateness of the max-tech level,
DOE received comments regarding how 118) The Joint Comment and the DOE received further comments
some energy efficiency levels under Multiple Water Organizations requested regarding adding more efficiency levels
consideration for CCWs could eliminate a gap-fill level between the 1.8 MEF and to the CCW analysis during the
vertical-axis clothes washers. GE stated the 2.79 MEF max-tech efficiency levels Framework public meeting and through
concerns regarding proposed standards at 2.0 MEF/5.5 WF as per CEE Tier 3B, subsequent written comments. ALS
levels for CCWs. GE commented that or 2.0 MEF/6.0 WF. (Joint Comment, No. agreed with analyzing all proposed
low WFs may not be attainable with 9 at p. 5; Multiple Water Organizations, effiency levels with the exception of
vertical-axis clothes washers, thereby No. 11 at p. 1) As shown in Table II.20, max-tech, which ALS rejected because
eliminating this low-cost platform from DOE is evaluating a level of 2.0 MEF of the hybrid origin of the MEF and WF,
the CCW market, which in turn could combined with a 5.5 WF. and because DOE derived these levels
DOE received numerous comments from residential clothes washer data.
lead to a decline in the number of regarding the appropriateness of the
clothes washers available in multi- (Public Meeting Transcript, No. 5 at pp.
max-tech level defined in the CCW 117–118) Multiple Water Organizations
family housing due to increased costs. section of the Framework Document.
GE urged DOE to consider the consumer recommended that DOE adopt step-like
AHAM objected to the hybrid approach incremental increases in both MEF and
utility of vertical-axis clothes washers, of choosing the MEF from one washer WF for each efficiency level. (Multiple
and it further argued that some model while choosing a WF from Water Organizations, No. 11 at p. 2)
proposed standards levels may not be another, as this does not represent an During the Framework comment
attainable even with horizontal-axis actual CCW. (Public Meeting Transcript, period, DOE received multiple
clothes washers. (Public Meeting No. 5 at p. 46) AHAM subsequently comments regarding the applicability of
Transcript, No. 5 at p. 45; GE, No. 13 at recommended the elimination of this residential clothes washer efficiency
p. 3) Whirlpool argued that a WF below efficiency level. (AHAM, No. 14 at p. 7) levels in a commerical setting. Both
9.5 could render a top-loading CCW According to Whirlpool, this max-tech Whirlpool and GE submitted that the
incapable of washing clothes properly level was particularly objectionable efficiency levels achieved by residential
and that NAECA would not allow the because of the hybrid origin of the MEF clothes washers are not representative of
elimination of a product class. and WF. (Public Meeting Transcript, No. levels achievable by commercial
(Whirlpool, No. 10 at p. 7) In response 5 at p. 118) Some stakeholders products, which experience harder and
to these comments, DOE notes that it countered that the hybrid approach is a more frequent use than residential
placed all CCWs in one product class reasonable way to estimate what could products. (Whirlpool, No. 10 at p. 9; GE,
pursuant to EPACT 2005 (see discussion be attainable but that the economics of No. 13 at p. 3) AHAM stated that the
of product class definition for CCWs in such a CCW would probably preclude efficiency levels set forth in the
section II.A.1.d of this ANOPR), which such a standards level. (Public Meeting Framework Document are not
applies a single standard for energy Transcript, No. 5 at p. 121; Joint appropriate and recommended that DOE
efficiency and a single standard for Comment, No. 9 at p. 5) EEI and consider the different nature of CCWs.
multiple stakeholders also suggested (AHAM, No. 14 at p. 7) DOE recognizes
water efficiency to all of the CCWs.
that, if DOE were to reject the hybrid that current product offerings in the
(EPACT 2005, section 136(e); 42 U.S.C.
approach, DOE could instead consider a commercial laundry market do not
6313(e)) Thus, as discussed in II.C.3.d max-tech level of 2.48 MEF and 3.5 WF,
above, DOE is treating commercial include products at each efficiency level
since that represents an actual clothes
clothes washers as a single class that for which DOE is performing an
washer. (EEI, No. 7 at p. 6; Multiple
encompasses both top- and front- analysis. DOE notes, however, that
Water Organizations, No. 11 at p. 2) In
loading units. products exist that meet all the levels
response to these comments, DOE
specified, so manufacturing cost data
Several stakeholders requested that subsequently altered the Framework
are available to assess CCWs that meet
DOE consider additional efficiency Document exploratory efficiency levels
or exceed the levels specified. Since the
levels for the CCW rulemaking. For to include a max-tech level where it
standards are minimum performance
example, ACEEE requested that DOE took the MEF and WF from an existing
standards, not presciptive standards,
clothes washer.
evaluate a 2.0 MEF and 5.5 WF level, these levels do not represent
since multiple clothes washer models 22 DOE published a Federal Register notice on predetermined technologies and are
with this efficiency level are on the February 6, 2006 acknowledging receipt of and therefore not tied to the residential or
market. (Public Meeting Transcript, No. summarizing the California Energy Commission’s commercial markets.
5 at p. 51; Public Meeting Transcript, Petition for Exemption from Federal Preemption of DOE also received comments
No. 5 at p. 121) Potomac recommended California’s Water Conservation Standards for
Residential Clothes Washers (71 FR 6022) (Docket regarding data requests for the CCW
that DOE consider the CEC waiver No. EE–RM–PET–100). engineering analysis. Whirlpool stated
that data for the baseline level are possible. DOE withheld from three products and the independent
readily available, and that data for some publication whatever data could not be generation of similar curves for
higher efficiency levels are also aggregated to maintain confidentiality. dishwashers and dehumidifiers. DOE
available. (Whirlpool, No. 10 at p. 9) Additional detail on the product based these curves on testing and
According to Whirlpool, the low volume classes, baseline models, and efficiency reverse engineering activities, which
of the U.S. CCW market, the limited levels can be found in Chapter 5 of the resulted in the generation of a detailed
scope of products, and the small TSD. bill of materials for each product.
number of manufacturers complicates For cooking products, DOE retained
4. Cost-Efficiency Results
the task of establishing manufacturing the cost data at each efficiency level that
cost data in a way that does not lead to DOE reports the results of the it had defined in the previous
the disclosure of confidential engineering analysis as cost-efficiency rulemaking’s analysis, updated by
information. (Whirlpool, No. 10 at p. 12) data (or ‘‘curves’’) in the form of scaling incremental manufacturing costs
The Multiple Water Organizations incremental manufacturing costs versus by the PPI from 1990 (the reference year
requested that DOE work closely with EF (or MEF and WF for CCWs). These in the prior analysis) to 2006. In
manufacturers to obtain and make data form the basis for subsequent addition, for microwave ovens, DOE
manufacturing cost data available before analyses in the ANOPR. DOE received received efficiency test data submitted
the ANOPR is published. (Multiple industry-aggregated curves for CCWs, by AHAM. The following table
Water Organizations, No. 11 at p. 2) dishwashers, and dehumidifiers from summarizes the data that DOE’s
DOE worked with AHAM and AHAM. DOE validated these data engineering analysis used to generate
stakeholders to obtain as much data as through manufacturer interviews for all the cost-efficiency results.
TABLE II.21.—ENGINEERING ANALYSIS METHODS

Products
Method Cooking Commercial
Dishwashers Dehumidifiers
products clothes washers
AHAM Data .............................................................................................. √ √ √ √

Review of Past TSD ................................................................................ √ .......................... .......................... √
Product Teardown ................................................................................... .......................... √ √ ..........................
Product Testing ........................................................................................ .......................... √ .......................... ..........................
Manufacturer Interviews .......................................................................... .......................... √ √ √
a. Dishwashers spanning the efficiency range 0.58–0.72 reverse-engineering sample size had
For dishwashers, AHAM provided EF). A comparison of AHAM’s and been larger, it is reasonable to assume
manufacturing cost data up to an DOE’s costs indicates that DOE’s cost that the range of incremental costs by
efficiency level of 0.72 EF. DOE estimates are somewhat lower that the efficiency level would have broadened.
supplemented AHAM’s efficiency-level AHAM average costs, but above the As a result, DOE feels that the AHAM
cost data submittal with cost AHAM minimum. submission is reasonable and reflective
information generated from the The purpose of comparing DOE’s and of the gamut of dishwasher platforms
efficiency testing and teardown of AHAM’s results was to assess the and their inherent efficiencies on the
currently-available dishwashers. DOE reasonableness of AHAM’s data market today.
conducted efficiency testing of six submission, and DOE believes this has Standard dishwasher cost-efficiency
dishwashers, representing a range of EFs been demonstrated. DOE’s teardown results are shown in Table II.22. DOE
across two different product platforms. sample size was very small and could was unable to obtain incremental
Beyond the measurements required to not be expected to adequately capture manufacturing cost information for
measure the performance according to the variability of all products in the compact dishwashers. Accordingly,
the DOE test procedure, the testing marketplace. Another reason why DOE’s DOE particularly seeks stakeholder
consisted of multi-submetering to record results are lower than AHAM’s average feedback on how it can extend the
disaggregated energy consumption is the influence of product platforms. results of the analysis for the standard-
associated with various design options. DOE’s teardown analysis and class dishwashers to compact
The EFs of the washers tested were 0.58, manufacturer interviews confirmed that dishwashers. This is identified as Issue
0.64, 0.68, 0.78, 0.93, and 1.11. upgrading components can only raise 4 under ‘‘Issues on Which DOE Seeks
In addition to efficiency testing, DOE EF to a certain point and that overall Comment’’ in section IV.E of this
performed reverse engineering on the system architecture limits EF. The ANOPR.
six units tested, as well as on an platform which DOE reverse-engineered
additional dishwasher with an EF of is among the most efficient available TABLE II.22.—INCREMENTAL MANUFAC-
0.72. This last dishwasher was not yet from large-volume manufacturers (with TURING COST FOR RESIDENTIAL
available on the market at the time of an EF that spans the range of 0.58 to STANDARD DISHWASHERS
testing but was released for high-volume 0.72). Thus, it is reasonable to assume
manufacturing three weeks later. To that starting from a lower efficiency Standard
validate the AHAM data and supply platform will result in larger
Energy factor Incremental
incremental cost information above the incremental costs. The results of the (cycles/kWh) cost
0.72 EF level, DOE tore down the seven testing and teardown analysis, including
dishwashers (three high-efficiency the list of design options identified and Baseline ................................ ........................
dishwashers that shared the same basic other observations, can be further 0.58 ....................................... $4.01
platform and four other washers reviewed in Chapter 5 of the TSD. If the 0.62 ....................................... 7.38
TABLE II.22.—INCREMENTAL MANUFAC- from its member companies and because fewer than three manufacturers
TURING COST FOR RESIDENTIAL submitted them to DOE. DOE validated produce units in these categories.
STANDARD DISHWASHERS—Contin- AHAM’s efficiency-level cost data Therefore cost-efficiency curves were
ued submittal with a design-options-based/ only generated for the following product
reverse engineering analysis, tearing classes: 0 to 35.00 pints/day, 35.01 to
Standard down 14 dehumidifiers representing a 45.00 pints/day, and 54.01 to 74.99
range of capacities and efficiencies. In pints/day. Results of the reverse
Energy factor Incremental generating the cost-efficiency results,
(cycles/kWh) cost engineering analysis for the product
DOE combined the first two product classes analyzed were in good
0.65 ....................................... 14.00 classes proposed by EPACT 2005, 25.00 agreement with the AHAM data. The
0.68 ....................................... 30.35 pints/day or less and 25.01–35.00 pints/ following table shows the dehumidifier
0.72 ....................................... 71.38 day, because some manufacturers did cost-efficiency results. AHAM provided
0.80 ....................................... 129.28 not have shipments in the 25.01 to 35.00
1.11 ....................................... 180.66 pints/day category. To prevent
all of the data for the three product
classes analyzed, except the value for an
disclosure of sensitive information, EF of 1.74 in the 35.01 to 45.00 product
b. Dehumidifiers AHAM did not provide data for the class, which DOE extrapolated from the
For dehumidifiers, AHAM collected EPACT 2005 categories 45.01–54.00 AHAM data.
incremental manufacturing cost data pints/day and 75 pints/day and greater
TABLE II.23.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL DEHUMIDIFIERS

Product class, Energy factor Incremental
pints/day (L/kWh) cost
0 to 35.00 ..................................................................................................................... Baseline .................................................... ........................

1.25 ........................................................... $3.12
1.30 ........................................................... 4.92
1.35 ........................................................... 10.41
1.40 ........................................................... 18.80
1.45 ........................................................... 25.61
35.01 to 45.00 .............................................................................................................. Baseline .................................................... ........................
1.35 ........................................................... 6.11
1.40 ........................................................... 14.47
1.45 ........................................................... 22.68
1.50 ........................................................... 32.84
1.74 ........................................................... 74.72
54.01 to 74.99 .............................................................................................................. Baseline .................................................... ........................
1.55 ........................................................... 4.18
1.60 ........................................................... 8.00
1.65 ........................................................... 12.36
1.70 ........................................................... 23.18
1.80 ........................................................... 33.94
c. Cooking Products from the previous rulemaking’s analysis, stakeholder comments. Tables II.24
For conventional cooking products, scaling the incremental manufacturing through II.30 and Table II.32 detail the
DOE derived the cost-efficiency curves costs by the PPI in accordance with cost-efficiency results.
TABLE II.24.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL GAS COOKTOPS

Incremental
Level Efficiency level source EF cost
0 ............. Baseline ............................................................................................................................................... 0.156 ........................

1 ............. 0 + Electronic Ignition .......................................................................................................................... 0.399 $12.06
2 ............. 1 + Sealed Burners ............................................................................................................................. 0.420 32.06
TABLE II.25.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC COIL COOKTOPS

Incremental
0 ............. Baseline ............................................................................................................................................... 0.737 ........................

1 ............. 0 + Improved Contact Conductance ................................................................................................... 0.769 $2.28
TABLE II.26.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC SMOOTH COOKTOPS

Incremental
0 ............. Baseline ............................................................................................................................................... 0.742 ........................

1 ............. 0 + Halogen Lamp Element ................................................................................................................ 0.753 $89.09
TABLE II.27.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL GAS STANDARD OVENS

Incremental
0 ............. Baseline ............................................................................................................................................... 0.0298 ........................

1 ............. 0 + Electric Globar Ignition .................................................................................................................. 0.0536 $12.06
2 ............. 1 + Improved Insulation ....................................................................................................................... 0.0566 15.64
3 ............. 2 + Improved Door Seals .................................................................................................................... 0.0572 16.72
4 ............. 3 + Forced Convection ........................................................................................................................ 0.0593 38.86
5 ............. 4 + Reduced Vent Rate ...................................................................................................................... 0.0596 40.48
6 ............. 5 + Reduced Conduction Losses ........................................................................................................ 0.0600 44.11
1a ........... 0 + Electronic Spark Ignition ............................................................................................................... 0.0583 15.00
TABLE II.28.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL GAS SELF-CLEANING OVENS

Incremental
0 ............. Baseline ............................................................................................................................................... 0.0540 ........................

1 ............. 0 + Forced Convection ........................................................................................................................ 0.0625 $11.01
TABLE II.29.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC STANDARD OVENS

Incremental
0 ............. Baseline ............................................................................................................................................... 0.1066 ........................

1 ............. 0 + Reduced Vent Rate ...................................................................................................................... 0.1113 $1.63
2 ............. 1 + Improved Insulation ....................................................................................................................... 0.1163 4.84
TABLE II.30.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC SELF-CLEANING OVENS

Incremental
0 ............. Baseline ............................................................................................................................................... 0.1099 ........................

1 ............. 0 + Reduced Conduction Losses ........................................................................................................ 0.1102 $4.37
For conventional ovens, the linear and intercepts of these relationships. because certain design options have
relationships for EF versus volume The table does not show values for been screened out in the current
allow scaling of the efficiency levels to every oven efficiency level because the analysis.
cavity volumes other than the baseline previous rulemaking did not analyze
volume. Table II.31 shows the slopes data at every efficiency level, and
TABLE II.31.—SLOPES AND INTERCEPTS FOR OVEN ENERGY FACTOR VERSUS VOLUME RELATIONSHIP
Intercepts, Electric Intercepts, Gas
Level Slope = –0.0157 Slope = –0.0073
Standard Self-Clean Standard Self-Clean
0 ....................................................................................................................... ........................ 0.1632 0.0865 0.0865

1 ....................................................................................................................... 0.1752 ........................ 0.0895 ........................
2 ....................................................................................................................... 0.1802 ........................ ........................ ........................
TABLE II.31.—SLOPES AND INTERCEPTS FOR OVEN ENERGY FACTOR VERSUS VOLUME RELATIONSHIP—Continued
Intercepts, Electric Intercepts, Gas
Level Slope = –0.0157 Slope = –0.0073
Standard Self-Clean Standard Self-Clean
3 ....................................................................................................................... 0.1822 ........................ 0.0935 ........................

Note: EF = (Slope x Volume) + Intercept where Volume is expressed in cubic feet.
For microwave ovens, the design result in a lowering of the energy that DOE is considering the addition of
options and efficiency levels DOE consumption of non-cooking features standby power measurement to the test
analyzed are those identified in the (e.g., standby power), even though the procedure, as identified as Issue 1 under
previous rulemaking, with incremental test procedure currently does not ‘‘Issues on Which DOE Seeks Comment’’
manufacturing costs scaled by the PPI. account for such usage in EF. This is in section IV.E of this ANOPR. The table
DOE specifically seeks stakeholder identified as Issue 5 under ‘‘Issues on below shows the cost-efficiency results
feedback on the approach of analyzing Which DOE Seeks Comment’’ in section for microwave ovens.
additional design options that would IV.E of this ANOPR. It should be noted
TABLE II.32.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL MICROWAVE OVENS

Incremental
0 ............. Baseline ............................................................................................................................................... 0.557 ........................

1 ............. 0 + More Efficient Power Supply ........................................................................................................ 0.586 $8.68
2 ............. 1 + More Efficient Fan ......................................................................................................................... 0.588 17.95
3 ............. 2 + More Efficient Magnetron .............................................................................................................. 0.597 32.53
4 ............. 3 + Reflective Surfaces ....................................................................................................................... 0.602 51.11
d. Commercial Clothes Washers technology. Thus, since DOE believes is small, and the presence of an Energy
For CCWs, DOE derived the cost- vertical-axis CCWs cannot perform Star program deters manufacturers from
efficiency curves from AHAM- satisfactorily at these efficiency levels, offering CCWs that have efficiencies that
submitted data. Due to limited data DOE assumes that all units sold at lie between the baseline and Energy Star
collected, AHAM supplied cost data efficiency level 2 and higher will be efficiency levels, as such units would be
only at 1.42 MEF/9.5 WF and 2.0 MEF/ horizontal-axis CCWs and likely, more more costly than a baseline unit yet not
5.5 WF. Based on a survey of CCWs efficient than required. In determining be eligible for rebates from utilities.
currently sold, it is DOE’s the incremental costs associated with Since all manufacturers currently
understanding that all products sold these efficiency levels, DOE notes that, produce horizontal-axis CCWs in the
which meet an efficiency level of 1.6 like dishwashers, CCWs are platform- range of 2.0 MEF/5.5 WF, no platform
EF/8.5 MEF or greater are based on a driven products where a given platform change would be required to the
horizontal axis platform. Furthermore, achieves an inherent efficiency based on existing horizontal-axis CCW lines to
based on interviews with manufacturers design and an optimized control
meet any efficiency level up to and
of CCWs, it is DOE’s understanding that strategy. This inherent efficiency can be
including 2.0 MEF/5.5 WF.23 During
energy and water efficient vertical-axis- further enhanced via design option
improvements that the control strategy interviews with DOE, manufacturers
based designs currently sold in the provided estimates of the cost increment
residential market are not being can incorporate. However, a
manufacturer may also choose to offer a to meet 2.2 MEF/5.1 WF, ranging from
considered for market introduction into
range of product efficiencies and $316 to $450. DOE notes that $316 is the
the commercial laundry sector. Such
designs include spray rinse and non- redesign existing products to offer a manufacturing cost increment provided
agitator vertical-axis clothes washers less-efficient unit for marketing or other by AHAM to take a CCW from a baseline
that replace the agitator with an reasons. The per-unit cost of redesigning efficiency level of 1.26 MEF/9.5 WF to
impeller, nutating plate, or other a product to reduce the efficiency is a level of 2.0 MEF/5.5 WF. Thus, DOE
alternative manipulator. Manufacturers typically low, though a manufacturer expects that the incremental costs
commented during interviews that such will have to pay an up-front cost to between 1.60 MEF/8.5 WF and 2.2 MEF/
designs are not appropriate for the develop the new controller, pay for 5.1 WF would be constant at the same
heavy-duty demands of commercial certifications, etc. Thus, there is a value as those provided by AHAM for
laundry applications. disincentive to develop less-efficient
Notwithstanding the lack of units (i.e., ones that marginally meet the 23 DOE recognizes, however, that changes to the
manufacturing data for CCWs at several standard) unless the market is large horizontal-axis CCW lines may be needed to meet
efficiency levels, the information enough to have the scale to support higher production volumes. Any investment to the
gathered from the market research and multiple price points based in part on horizontal-axis CCW production lines to
accommodate higher sales volumes were not
manufacturer interviews suggests that energy efficiency.
captured in this analysis. For a qualitative
CCWs cannot attain satisfactory Thus, it is not surprising that the discussion of capital expenditures required for such
cleaning performance at or above CCW market currently does not offer a a product conversion, see the preliminary
efficiency level 2 (1.6 MEF and 8.5 WF) wide range of efficiencies for a given manufacturer impact analysis chapter (Chapter 12)
without the use of horizontal-axis axis of rotation. The scale of the market of the TSD.
the level 2.0 MEF/5.5 WF. For further Residential Energy Consumption Survey water use and, in turn, the per-cycle
information, see Chapter 5 of the TSD. (RECS) and other sources (which are water-heating energy consumption
DOE specifically seeks feedback on described below for each product) to using DOE test procedure equations.
the validity of this approach. DOE seeks establish a range of energy (and water) DOE analyzed the energy and water
information about lower-cost use for the four appliance products. use for candidate standard levels
alternatives to horizontal-axis designs ranging from 0.58 EF to 1.11 EF for
1. Dishwashers
for levels greater than 1.42 MEF/9.5 WF standard-sized dishwashers. Because
and lower than 2.0 MEF/5.5 WF. DOE relied on the information in the Whirlpool does not produce products
Additionally, DOE seeks information DOE test procedure to establish the
with efficiencies higher than 0.68 EF,
that would enable it to change the typical annual energy and water
Whirlpool commented that it cannot
energy and water features of the 2.0 consumption of dishwashers. 10 CFR
provide energy and water consumption
MEF/5.5 WF level to allow for Part 430, Subpart B, Appendix C. In
data for efficiency levels 0.72 EF, 0.80
manufacturer cost differentiation at the particular, DOE determined the annual
EF, and 1.11 EF. (Whirlpool, No. 10 at
lower (and the higher) levels. DOE is energy and water consumption of
pp. 9 and 12) However, based on the
also interested in receiving comment on dishwashers by multiplying the per-
relationship between aggregate per-cycle
how to weigh the impacts of a market- cycle energy and water use by the
energy use (which can be deduced from
shift from vertical-axis technologies to number of cycles per year, consistent
the dishwasher EF) and water use,
horizontal-axis technologies. These with the DOE test procedure.
Dishwasher per-cycle energy which AHAM provided, DOE was able
issues are identified as Issue 3 under to estimate the energy use and water use
‘‘Issues on Which DOE Seeks Comment’’ consumption consists of three
components: (1) Water-heating energy; of dishwashers at all candidate standard
in section IV.E of this ANOPR. levels. Table II.34 shows the candidate
The following table shows the (2) machine energy; and (3) drying
energy. The machine energy consists of standard levels for standard-sized
preliminary commercial clothes washer dishwashers and their corresponding
cost-efficiency results. the motor energy (for water pumping
and food disposal) and booster heater per-cycle energy and water use.
TABLE II.33.—INCREMENTAL MANUFAC- energy. The DOE test procedure Per-cycle energy use is disaggregated
provides equations to calculate the total into two general categories: (1) Water
TURING COST FOR COMMERCIAL
per-cycle dishwasher energy heating; and (2) machine (e.g., motor
CLOTHES WASHERS consumption. energy for pumping) and dish drying
The largest component of dishwasher from an electrical heating element. DOE
Efficiency levels Incremental
(MEF/WF) cost energy consumption is water-heating estimated the per-cycle energy use by
energy use, which is directly dependent taking the inverse of the EF. It estimated
Baseline ................................ ........................ on water use. AHAM stated that it was the per-cycle water consumption based
1.42/9.5 ................................. $74.73 not possible to provide either on the relationship between energy and
1.60/8.5 ................................. 316.35 disaggregated per-cycle energy use or water use. DOE estimated the per-cycle
1.72/8.0 ................................. 316.35 water use data by standard level water-heating energy consumption by
1.80/7.5 ................................. 316.35
2.00/5.5 ................................. 316.35 because, for any given standard level, assuming the use of an electric water
2.20/5.1 ................................. 316.35 the disaggregated energy use heater and multiplying the per-cycle
components and water use can vary water consumption by an assumed
Additional detail on the cost- greatly depending on dishwasher temperature rise of 70 °F (21 °C) and a
efficiency results can be found in design. (AHAM, No. 14 at p. 8) specific heat of water of 0.0024 kWh/gal
Chapter 5 of the TSD. However, AHAM did provide data × °F (4.186 joule/gram × °C). The per-
showing how aggregate per-cycle energy cycle machine and drying energy were
D. Energy Use and Water Use use and per-cycle water use has changed determined by DOE by subtracting the
Characterization over time since 1993. An analysis of the water-heating energy consumption from
The purpose of the energy use submitted AHAM data demonstrated the total energy consumption. The table
characterization, which DOE performed that the relationship between energy below provides the standby power,
for the four appliance products covered and water use is nearly linear. This which DOE assumed to be two watts.
in the ANOPR, is to help assess the correlation is largely due to the energy EEI questioned the degree to which
energy-savings potential of different required to heat water to the test consumers use the ‘‘heated dry’’ option
product efficiencies. The purpose of the procedure inlet temperature of 120 °F to dry dishes instead of air-drying. (EEI,
water use characterization, performed (49 °C) that most dishwashers use. The No. 7 at p. 5) For purposes of
only for CCWs and residential energy required to heat the inlet water developing the per-cycle energy use and
dishwashers, is to help assess the water- to 120 °F (49 °C) usually represents the water use data shown below in Table
savings potential of more efficient largest proportion of the overall per- II.34, DOE based the amount of time that
products. DOE relied on existing test cycle energy usage. Therefore, by the heated dry option is used on the
procedures, as well as the Energy knowing the aggregate per-cycle energy DOE test procedure (i.e., 50 percent of
Information Administration (EIA)’s use, DOE determined the per-cycle the dishwasher cycles).
TABLE II.34.—STANDARD DISHWASHERS: PER-CYCLE ENERGY AND WATER USE BY CANDIDATE STANDARD LEVEL
Energy Use Components
Candidate Standard Level EF Energy Use Water Use Standby
Water Machine +
Heating Drying
cycles/kWh kWh/cycle gal/cycle kWh/cycle kWh/cycle kW
Baseline ............................................................... 0.46 2.17 8.16 1.37 0.80 0.002

1 ........................................................................... 0.58 1.72 6.07 1.02 0.70 0.002
2 ........................................................................... 0.62 1.61 5.56 0.93 0.68 0.002
3 ........................................................................... 0.65 1.54 5.21 0.88 0.66 0.002
4 ........................................................................... 0.68 1.47 4.90 0.82 0.65 0.002
5 ........................................................................... 0.72 1.39 4.52 0.76 0.63 0.002
6 ........................................................................... 0.80 1.25 3.87 0.65 0.60 0.002
7 ........................................................................... 1.11 0.90 2.25 0.38 0.52 0.002
DOE determined the average annual reviewed EIA’s 2001 RECS data, which component in a very large and complex
energy and water consumption by includes the annual usage of households survey instrument dealing with all
multiplying the per-cycle energy and with dishwashers. Of the more than aspects of home energy use. (Joint
water consumption by the number of 4,800 households in RECS, almost 2,500 Comment, No. 9 at p. 4) The Multiple
cycles per year. In 2003, DOE revised its have dishwashers. However, the Water Organizations also urged DOE to
test procedure for dishwashers to more average-use value for dishwashers is 180 retain the use of 215 cycles per year in
accurately establish their efficiency and cycles per year, with minimum and the analysis. (Multiple Water
energy and water use. The 2003 test maximum values of 26 and 500 cycles Organizations, No. 11 at p. 3) Whirlpool
procedure amendments included a per year, respectively. The Joint also stated that DOE should retain the
reduction in the average use cycles per Comment argued that DOE should use of 215 cycles per year in its analysis.
year, from 264 to 215 cycles per year.24 continue to use 215 cycles per year in (Whirlpool, No. 10 at p. 9) Because the
Arthur D. Little (ADL) conducted a its analysis of dishwashers. The ADL survey is a much more
comprehensive analysis of dishwasher organizations maintained that any comprehensive and larger survey than
usage in 2001 that revealed that estimate derived from the EIA’s 2001 the survey performed for RECS, DOE
dishwashers are used, on average, 215 RECS is not nearly as robust as the chose an average usage of 215 cycles per
cycles per year. This usage pattern is estimate derived from the work year as the most representative value for
currently used to establish the annual conducted by ADL to revise the average dishwasher use.
energy consumption of dishwashers dishwasher test procedure. For example, Therefore, the annual energy and
with the DOE test procedure. the Joint Comment stated that RECS water consumption shown in Table II.35
In the context of the present represents a much smaller sample than reflect an annual usage of 215 cycles per
rulemaking, DOE analyzed additional the one ADL used (about 2,500 year. The annual water-heating energy
sources to determine whether the households versus 26,000 households) consumption reflects the use of either
number of dishwasher cycles per year and that the questions pertaining to an electric, gas-fired, or oil-fired water
has changed. For example, DOE dishwashers in RECS are just one heater.
TABLE II.35.—STANDARD DISHWASHERS: ANNUAL ENERGY AND WATER USE BY CANDIDATE STANDARD LEVEL
Energy factor Annual energy use
Water heating*
Candidate standard level
cycle/kWh Oil
Electric Gas
kWh/year MMBtu/year MMBtu/year
Baseline ............................................................... 0.46 295 1.34 1.24 190 1.8

1 ........................................................................... 0.58 219 1.00 0.92 168 1.3
2 ........................................................................... 0.62 201 0.91 0.85 163 1.2
3 ........................................................................... 0.65 188 0.86 0.79 160 1.1
4 ........................................................................... 0.68 177 0.80 0.74 156 1.1
5 ........................................................................... 0.72 163 0.74 0.69 153 1.0
6 ........................................................................... 0.80 140 0.64 0.59 146 0.8
7 ........................................................................... 1.11 81 0.37 0.34 129 0.5
* Electric, gas-fired, and oil-fired water heating based on water heater efficiencies of 100 percent for electric, 75 percent for gas, and 81 per-
cent for oil.
† Standby annual energy use based on a dishwasher cycle length of one hour. Thus, Standby hours = 8766 hours¥215 × 1 hour = 8551
hours.
Whirlpool and EEI stated that DOE washing when establishing dishwasher account for pre-washing in estimating
must account for the effects of pre- energy use. EEI stated that DOE should the baseline energy use of dishwashers.
24 68 FR 51887 (August 29, 2003).
Whirlpool stated that increasing the the LCC and PBP analyses. Additional buckets are full, and the organization
efficiency of dishwashers too far may detail on the energy and water use argued that such feature reduces use,
result in wash performance being characterization of dishwashers can be because it is assumed that consumers do
compromised, thereby forcing found in Chapter 6 of the TSD. not regularly empty the bucket. (AHAM,
consumers to pre-wash more and No. 14 at p. 10; Whirlpool, No. 10 at p.
2. Dehumidifiers
resulting in increased energy and water 9) Because the AHAM data were
consumption. (Whirlpool, No. 10 at p. 2; The ANSI/AHAM Standard DH–1– developed based on the experience of
EEI, No. 7 at p. 5) EEI also stated that 2003, ‘‘Dehumidifiers,’’ for energy manufacturers, DOE believes that the
the analysis should capture the effects consumption measurements during AHAM data are the most representative
of reduced household cooking product capacity-rating tests, and CAN/CSA– of actual use. Therefore, DOE relied on
usage on dishwasher usage. (EEI, No. 7 C749–94, ‘‘Performance of the data AHAM provided, but DOE did
at p. 3) Because DOE could not identify Dehumidifiers,’’ for energy factor consider other sources of data for
sources of data showing whether the calculations, that DOE codified under estimating annual energy consumption.
amount of pre-washing is impacted by EPCA in a final rule for dehumidifiers In comparison with AHAM’s
dishwasher efficiency, DOE conducted provide a method for determining the recommendation that DOE use 1,095
its analysis by assuming that hand- or product’s rated efficiency in liters/ operating hours per year as the norm,
pre-washing habits are not affected by kWh—but provide no method for other literature sources from ADL,
product efficiency. But because establishing annual energy consumption Energy Star, and LBNL, provide higher
increased diswasher energy efficiency (71 FR 71340 (December 8, 2006); 10 use values of 1,620, 2,851, and 4,320
may require future designs to utlize less CFR 430.23(z)). DOE determined the hours/year, respectively. Therefore,
water, DOE recognizes the possibility annual energy consumption of although DOE relied on AHAM’s
that more efficient dishwashers may dehumidifiers by first dividing the estimate of 1,095 hours to calculate a
degrade wash performance. Therefore, capacity (in pints per day) by the unit dehumidifier’s average energy
DOE seeks feedback on whether more efficiency (in liters per kWh) and then consumption, DOE used the higher use
efficient dishwasher designs will lead to multiplying it by the usage in hours per values from the above sources to
increased hand- or pre-washing and, if year. demonstrate how they would impact
so, what increase in energy and water Both AHAM and Whirlpool annual energy consumption.
use can be expected. This is identified commented on the difficulty of DOE specifically seeks feedback on
as Issue 7 under ‘‘Issues on Which DOE determining the energy consumption of whether AHAM’s estimate of 1,095
Seeks Comment’’ in section IV.E of this dehumidifiers. Whirlpool stated that hours per year is representative, on
ANOPR. Considering the effects of energy consumption varies considerably average, of dehumidifier use. This is
reduced household cooking product use depending on geographic location and identified as Issue 8 under ‘‘Issues on
on dishwasher usage, and because that average energy consumption is Which DOE Seeks Comment’’ in section
DOE’s dishwasher use assumptions are likely lower than the energy use DOE IV.E of this ANOPR.
based on relatively recent survey data suggested in its Framework Document. For the six product classes of
collected by ADL, DOE believes that any In consultation with manufacturers and dehumidifiers, DOE calculated the
impacts from reduced cooking are others familiar with that type of baseline annual energy consumption
captured in the updated use value of product, AHAM estimated that (i.e., the consumption corresponding to
215 cycles per year. dehumidifier use is between 875 and the standards for each product class that
As previously stated, of the more than 1,315 hours per year, and it take effect in 2007), based on the annual
4,800 households in RECS, almost 2,500 recommended that DOE use the mid- use assumptions presented in Table
have dishwashers. As will be described point (1,095 hours) as the norm (with II.36 below. As shown in the table, the
later in section II.G on the LCC and PBP sensitivity analyses at 875 and 1,315 calculated annual energy use has an
analysis, DOE used the RECS household hours/year). AHAM also stated that extensive range based on the capacity
samples with their associated baseline many dehumidifiers shut off and efficiency of the dehumidifier and
annual energy consumption to conduct automatically once their condensation the hours of operation.
TABLE II.36.—DEHUMIDIFIER ANNUAL ENERGY CONSUMPTION DERIVED FROM HOURLY USE

Product class Average size EF Annual energy use (kWh/year)
AHAM Energy LBNL-

Pints/day Pints/day Liters/day Liters/kWh ADL Star high
Low Mid High
≤25.00 ........................................ 20.0 9.5 1.0 345 432 519 639 1124 1703
25.01–35.00 ............................... 30.0 14.2 1.2 431 540 648 798 1405 2129
35.01–45.00 ............................... 40.0 18.9 1.3 531 664 798 983 1730 2621
45.01–54.00 ............................... 50.0 23.7 1.3 664 830 997 1228 2162 3276
54.01–74.99 ............................... 64.5 30.5 1.5 742 928 1115 1373 2417 3662
≥75.00 ........................................ 85.0 40.2 2.25 652 816 979 1207 2123 3218
Table II.37 presents the annual energy estimated the annual energy annual energy consumption for
consumption by candidate standard consumption of electric and gas cooktops and ovens by candidate
level for the predominant dehumidifier ranges.25 The studies that covered the standard level. Tables II.38 through II.40
product class, 25.0–35.00 pints/day. The time period of 1977–1992 showed a show the annual energy consumption by
annual energy consumption reflects an steady decline in the annual energy candidate standard level for the electric
annual use corresponding to AHAM’s consumption. Based on these studies, coil, electric smooth, and gas cooktop
mid-estimate of annual hourly operation DOE published revisions to its test product classes, respectively. Tables
(i.e., 1,095 hours per year). Refer to procedure as a final rule in 1997, which II.41 through II.44 show the annual
Chapter 6 of the TSD for the annual included a reduction in the annual energy consumption by candidate
energy consumption by candidate useful cooking energy output and a standard level for the electric standard,
standard level for the other five reduction in the number of self-cleaning electric self-cleaning, gas standard, and
dehumidifier product classes. oven cycles per year.26 The annual gas self-cleaning oven product classes,
useful cooking energy output relates the respectively. For gas standard ovens
TABLE II.37 25.01.—35.00 PINTS/DAY energy factor of the cooking appliance to (Table II.43), candidate standard level 1
DEHUMIDIFIERS: ANNUAL ENERGY the annual energy consumption. (globar or hot surface ignition) and
USE BY CANDIDATE STANDARD Therefore, the lower the annual useful candidate standard level 1a (spark
LEVEL cooking energy output, the lower the ignition) are addressed separately
annual energy consumption of the because the technologies have different
Efficiency Annual cooking appliance. energy use characteristics. Although
Candidate energy use Whirlpool and EEI stated that the both technologies are used for the same
standard level annual energy consumption of cooking
liters/kWh kWh/year purpose (i.e., to eliminate the need for
products is very likely lower than it was a standing pilot), hot surface ignition
Baseline ........ 1.20 540 in the mid-1990s due to changes in uses a significant amount of electrical
1 .................... 1.25 518 consumer eating habits (i.e., people energy while spark ignition uses a
2 .................... 1.30 498 eating out more often). (Whirlpool, No. negligible amount of electricity. The use
3 .................... 1.35 480 10 at p. 10; EEI, No. 7 at p. 3) Based on of a globar ignition device is the
4 .................... 1.40 463 more recent studies of cooking annual technology most commonly used to
5 .................... 1.45 447 energy use, DOE confirmed that cooking
eliminate the need for a standing pilot
energy consumption has continued to in gas ovens. Therefore, in the case of
Unlike dishwashers, RECS does not decline since the mid-1990s. Research gas standard ovens, efficiency levels two
have any data that indicate the use or results from the 2004 California through six follow efficiency level ‘1’
annual energy consumption of Residential Appliance Saturation Study (globar ignition) rather than level ‘1a’
dehumidifiers. Therefore, DOE did not (CA RASS) 27 and the Florida Solar (spark ignition), and in the case of gas
use RECS to determine the variability of Energy Center (FSEC) 28 show that the
annual energy consumption. Rather, self-cleaning ovens, the baseline
annual energy consumption for most efficiency level is based on the use of a
DOE relied exclusively on the data that electric and gas cooktops and ovens is
AHAM provided (see Table II.37) to globar ignition device. For more details
roughly 40 percent less than the energy on how DOE developed the annual
characterize the variability in annual use during the mid-1990s.
energy consumption. As discussed energy consumption for each product
Based on the more recent annual class, refer to Chapter 6 of the TSD.
previously, DOE used AHAM’s estimate energy use data, DOE established the
of 1,095 hours to calculate the average
annual energy consumption. To 25 U.S. Department of Energy-Office of Codes and
TABLE II.38.—ELECTRIC COIL
characterize the variability of use, DOE Standards. Technical Support Document for COOKTOPS: ANNUAL ENERGY CON-
used a triangular probability Residential Cooking Products, Volume 2: Potential SUMPTION BY CANDIDATE STANDARD
distribution that had an average value of Impact of Alternative Efficiency Levels for
Residential Cooking Products, April, 1996. Prepared
LEVEL
1,095 hours per year, ranging from a for the U.S. DOE by Lawrence Berkeley National
minimum value of 875 hours to a Laboratory, Berkeley, CA. Appendix A. Available Annual energy
maximum value of 1,315 hours. As will online at: http://www.eere.energy.gov/buildings/ Candidate Energy consumption
appliance_standards/residential/ standard level factor
be described later in section II.G on the kWh/year
cooking_products_0998_r.html.
LCC and PBP analysis, DOE employed 26 62 FR 51976 (Oct. 3, 1997).
use variability in calculating annual 27 California Energy Commission. California Baseline ............ 0.737 128.2
energy consumption when it conducted Statewide Residential Appliance Saturation Study, 1 ........................ 0.769 122.9
the LCC and PBP analyses. Additional June 2004. (Prepared for the CEC by KEMA–
detail on the energy use characterization XNERGY, Itron, and RoperASW. Contract No. 400–
04–009). Available online at: http:// TABLE II.39.—ELECTRIC SMOOTH
of dehumidifiers can be found in
Chapter 6 of the TSD.
www.energy.ca.gov/appliances/rass/index.html. COOKTOPS: ANNUAL ENERGY CON-
28 Parker, D. S. Research Highlights from a Large
SUMPTION BY CANDIDATE STANDARD
3. Cooking Products Scale Residential Monitoring Study in a Hot
Climate. Proceedings of International Symposium LEVEL
a. Cooktops and Ovens on Highly Efficient Use of Energy and Reduction of
its Environmental Impact, January 2002. Japan Annual energy
The annual energy consumption of Society for the Promotion of Science Research for Candidate Energy consumption
electric and gas ranges (i.e., cooktops standard level factor
the Future Program, Osaka, Japan. JPS-

and ovens) has been in continual RFTF97P01002: pp. 108–116. Also published as kWh/year
FSEC–PF369–02, Florida Solar Energy Center,
decline since the late 1970s. DOE’s prior Cocoa, FL. Available online at: http:// Baseline ............ 0.742 128.2
rulemaking on residential cooking www.fsec.ucf.edu/en/publications/html/FSEC–PF– 1 ........................ 0.753 126.3
products identified several studies that 369–02/index.htm
TABLE II.40.—GAS COOKTOPS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL

Cooking Cooking Pilot Total
Candidate standard level Energy factor efficiency
(percent) MMBtu/year MMBtu/year MMBtu/year
Baseline ............................................................................... 0.156 39.9 0.72 2.01 2.74

1 ........................................................................................... 0.399 39.9 0.72 ........................ 0.72
2 ........................................................................................... 0.420 42.0 0.69 ........................ 0.69
TABLE II.41.—ELECTRIC STANDARD OVENS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL
Cooking Cooking Clock Total
(percent) kWh/year kWh/year kWh/year
Baseline ......................................................................................... 0.1066 12.2 132.4 34.2 166.5

1 ..................................................................................................... 0.1113 12.8 125.9 34.2 160.1
2 ..................................................................................................... 0.1163 13.4 119.7 34.2 153.9
3 ..................................................................................................... 0.1181 13.7 117.6 34.2 151.8
4 ..................................................................................................... 0.1206 14.0 70.7 34.2 149.0
5 ..................................................................................................... 0.1209 14.1 70.6 34.2 148.6
TABLE II.42.—ELECTRIC SELF-CLEANING OVENS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL
Cooking effi- Cooking Self-clean Clock Total
Candidate standard level Energy factor ciency
(percent) kWh/year kWh/year kWh/year kWh/year
Baseline ............................................................... 0.1099 13.8 116.6 21.1 33.3 171.0

1 ........................................................................... 0.1102 13.8 116.2 21.1 33.3 170.6
2 ........................................................................... 0.1123 14.2 113.5 21.1 33.3 167.9
TABLE II.43.—GAS STANDARD OVENS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL
Cooking Cooking Ignition Total
Energy
Candidate standard level efficiency
factor (percent) MMBtu/yr kWh/yr MMBtu/yr kWh/yr MMBtu/yr kWh/yr
Baseline ........................................... 0.0298 5.9 0.82 .................. 1.01 .................. 1.83 0.0
1* ...................................................... 0.0536 5.8 0.84 .................. .................. 21.1 0.84 21.1
2 ....................................................... 0.0566 6.1 0.80 .................. .................. 21.1 0.80 21.1
3 ....................................................... 0.0572 6.2 0.79 .................. .................. 21.1 0.79 21.1
4 ....................................................... 0.0593 6.5 0.75 1.8 .................. 21.1 0.75 22.9
5 ....................................................... 0.0596 6.5 0.75 1.8 .................. 21.1 0.75 22.9
6 ....................................................... 0.0600 6.6 0.74 1.8 .................. 21.1 0.74 22.9
1a* .................................................... 0.0583 5.8 0.84 .................. .................. .................. 0.84 0.0
* Candidate standard levels 1 and 1a correspond to designs that are utilized for the same purpose—eliminate the need for a standing pilot—
but the technologies for each design are different. Candidate standard level 1 is a hot surface ignition device while candidate standard level 1a is
a spark ignition device. Candidate standard level 1a is presented at the end of the table because candidate standard levels 2 through 6 are de-
rived from candidate standard level 1.
TABLE II.44.—GAS SELF-CLEANING OVENS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL
Cooking Cooking Self-clean Ignition Clock Total
Candidate Energy effc’y
standard level factor (percent) MMBtu/yr kWh/yr MMBtu/yr kWh/yr kWh/yr kWh/yr MMBtu/yr kWh/yr
Baseline ............. 0.0540 7.1 0.68 .................... 0.17 0.7 21.1 31.5 0.86 53.3
1 ........................ 0.0625 8.8 0.56 1.8 0.17 0.7 21.1 31.5 0.73 55.1
2 ........................ 0.0627 8.8 0.55 1.8 0.17 0.7 21.1 31.5 0.73 55.1
3 ........................ 0.0632 8.9 0.55 1.8 0.17 0.7 21.1 31.5 0.72 55.1
DOE used 2001 RECS data to establish cooktops; 1,159 household records have records have self-cleaning ovens. The
the variability of annual cooking energy standard ovens, and 1,601 household above totals represent cooktops and
consumption for cooktops and ovens. records have self-cleaning ovens. With ovens in households either as a stand-
RECS indicates which households in the regard to gas cooking products, 1,597 alone unit or as part of a range.
survey of 4,822 households use electric household records have cooktops either Although RECS does not provide the
and gas ranges, ovens, and cooktops. in electric ranges or as stand-alone annual energy consumption of the
With regard to electric cooking units; 959 household records have cooking product for each household
products, 2,895 household records have standard ovens, and 494 household record, it does provide the frequency of
cooking use. Thus, DOE used the
frequency of use to define the variability LCC and PBP analyses, DOE used the that more than doubled the test
of the annual energy consumption. RECS household samples with their procedure’s original value from the late
Conducting the analysis in this manner associated baseline annual energy 1970s (62 FR 51976 (October 3, 1997)).
captured the observed variability in consumption to conduct the LCC and The annual useful cooking energy
annual energy consumption while PBP analyses. output relates the energy factor of the
maintaining the average annual energy microwave oven to the annual energy
b. Microwave Ovens
consumption shown above in Tables consumption. Therefore, the higher the
II.38 through II.44. To determine the After an increase since the late 1970s, annual useful cooking energy output,
variability of cooking product energy the annual energy consumption of the higher the annual energy
consumption, DOE first equated the microwave ovens has remained consumption.
weighted-average cooking frequency relatively steady since the late 1980s.
from RECS with the average energy use DOE’s previous rulemaking on A more recent study from the 2004
values reported in Tables II.38 through residential cooking products identified CA RASS is roughly in line with the
II.44. DOE then varied the annual studies that estimated the annual energy average result from the previous studies
energy consumption for each RECS consumption of microwave ovens.29 showing that annual energy
household based on its reported cooking With the exception of one study based consumption has declined 15 percent
frequency. on the use of conditional demand since the mid-1990s. Based on the CA
For more details on cooking frequency analysis,30 the studies, which covered RASS study, DOE established the
variability and its impact on the the time period 1988–1994, showed that annual energy consumption for
variability of annual energy annual energy consumption was no microwave ovens by candidate standard
consumption, as well as additional more than 200 kWh/year. Based on level as shown in Table II.45. For more
detail on the energy use characterization these studies, DOE published revisions details on how DOE developed the
of kitchen ranges and ovens, refer to to its test procedure as a final rule in annual energy consumption for
Chapter 6 of the TSD. As will be 1997 that included an increase in the microwave ovens, refer to Chapter 6 of
described later in section II.G on the annual useful cooking energy output the TSD.
TABLE II.45.—MICROWAVE OVENS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL

Cooking Total
(percent) kWh/year
Baseline ....................................................................................................................................... 0.557 55.7 131.0

1 ................................................................................................................................................... 0.586 58.6 124.5
2 ................................................................................................................................................... 0.588 58.8 124.1
3 ................................................................................................................................................... 0.597 59.7 122.2
4 ................................................................................................................................................... 0.602 60.2 121.2
In its Framework Document, DOE it did for cooktops and ovens, DOE used Table II.45. DOE then varied the annual
requested energy use data for the RECS to establish microwave oven use energy consumption for each RECS
individual components of the variability. The 2001 RECS indicates household based on its reported cooking
microwave oven (e.g., magnetron that 4,149 of the 4,822 households in frequency.
filament, magnetron power supply, and the survey use microwave ovens. For more details on cooking frequency
fan and motor). Sharp stated that the Similar to electric and gas cooktops and variability and its impact on the
measurement methods in the DOE test ovens, although RECS does not provide variability of annual energy
procedure require the establishment of the annual energy consumption of consumption, as well as additional
only the total input power of the oven microwave ovens for each household detail on the energy use characterization
and not the input power associated with record, it does provide the frequency of of microwave ovens, refer to Chapter 6
individual components. Therefore, cooking use. Thus, DOE used the of the TSD. As will be described later in
Sharp argued that if the oven is being frequency of microwave use to define section II.G on the LCC and PBP
tested in accordance with the DOE test the variability of the annual energy analyses, DOE used the RECS household
procedure, disaggregated energy use consumption. Conducting the analysis samples with their associated baseline
data is neither apposite nor readily in this manner captured the observed annual energy consumption to conduct
available. (Public Meeting Transcript, variability in annual energy the LCC and PBP analyses.
No. 5 at p. 108) DOE agrees that its test consumption while maintaining the
average annual energy consumption 4. Commercial Clothes Washers
procedure only requires the
measurement of total energy use, so, for shown above in Table II.45. To DOE determined the annual energy
purposes of this analysis, DOE has determine the variability of cooking and water consumption of CCWs by
decided to only consider the total product energy consumption, DOE first multiplying the per-cycle energy and
energy consumption of the product. equated the weighted-average cooking water use by the number of cycles per
With regard to the variability of frequency from RECS with the average year. CCW per-cycle energy
annual cooking energy consumption, as energy use values reported above in consumption has three components: (1)
29 U.S. Department of Energy—Office of Codes online at: http://www.eere.energy.gov/buildings/ Alto, CA. CU–6487. Available online at: http://
and Standards. Technical Support Document for appliance_standards/residential/cooking_products my.epri.com/portal/server.pt?space=Community
Residential Cooking Products, Volume 2: Potential _0998_r.html Page&cached=true&parent
Impact of Alternative Efficiency Levels for 30 Electric Power Research Institute. Residential name=ObjMgr&parentid=2&control=Set
Residential Cooking Products, April, 1996. Prepared
End-Use Energy Consumption: A Survey of Community&CommunityID=221&PageIDquery
for the U.S. DOE by Lawrence Berkeley National
Laboratory, Berkeley, CA. Appendix A. Available Conditional Demand Estimates, October 1989. Palo ComId=0
Water-heating energy; (2) machine provided or identified on how capacity water-heating energy use by first
energy; and (3) drying energy. The may change with increased efficiency. determining the total per-cycle energy
machine energy is comprised of the Therefore, DOE maintained a constant use (the clothes container volume
motor energy for turning an agitator or capacity in its analysis of annual energy divided by the MEF) and then
rotating a drum. consumption by candidate standard subtracting from it the per-cycle clothes-
The test procedures DOE recently level. However, DOE invites additional drying and machine energy.
codified at 10 CFR 431.154 are based on comments and data regarding the
measuring the performance of DOE specifically seeks stakeholder
relationship between CCW capacity and
residential clothes washers, and, efficiency. feedback on whether the residential
therefore, the cycles-per-year values EEI requested clarification as to clothes washer per-cycle energy
only indirectly reflect CCW usage whether the energy consumption consumption values for clothes-drying
through comparison with their analysis for CCWs would capture and machine use taken from its 2000
residential counterparts (71 FR 71340). reduced dryer energy consumption as a TSD are representative of CCWs. This is
However, both ALS and EEI stated that result of higher clothes washer identified as Issue 9 under ‘‘Issues on
CCW use is highly variable. ALS stated efficiencies. (Pubic Meeting Transcript, Which DOE Seeks Comment’’ in section
that CCW use varies based on the No. 5 at p. 154) In response, we note IV.E of this ANOPR.
clothes washer market (e.g., laundry and that CCWs are rated with an MEF, and EEI commented that detergents
multi-housing). ALS recommended inherent in the determination of the formulated for cold-water washes are
contacting the MLA, the CLA, and route MEF is the energy required to dry now available. Because no hot water
operators to obtain relevant use data. clothes. Therefore, DOE did capture the will be required if these detergents are
(Public Meeting Transcript, No. 5 at pp. impact of higher efficiencies on dryer used, the baseline energy consumption
156–157; EEI, No. 7 at p. 6) As energy use. will be impacted. (EEI, No. 7 at p. 4)
discussed in more detail below, DOE Table II.46 shows the candidate
However, DOE cannot assume that
has relied on several studies including standard levels for CCWs and their
consumers will routinely use cold-water
research sponsored by the MLA and the corresponding per-cycle energy and
detergents. Thus, although cold-water
CLA (trade associations representing the water use. DOE determined the per-
cycle clothes-drying energy use by first detergents may be available, DOE
commercial laundry industry) to
establishing the remaining moisture determined the water-heating energy
establish typical use cycles for CCWs.
As shown in Table II.46, DOE content (RMC) based on the relationship use using the specifications set forth in
analyzed the energy and water use for between RMC and the MEF, and then the DOE test procedure. The per-cycle
specific candidate standard levels for using the DOE test procedure equation water-heating energy use in Table II.46
CCWs. GE commented that because that determines the per-cycle energy below depicts the use of an electric
clothes container volume (capacity) may consumption for the removal of water heater and a 2.8 ft3 clothes
change with product efficiency, DOE moisture. DOE took the per-cycle container volume. DOE determined the
should not use a constant capacity when machine energy use from its 2000 TSD per-cycle hot water use by dividing the
determining the energy and water for residential clothes washers.31 In the per-cycle water-heating energy use by a
consumption of CCWs. GE suggested 2000 TSD, for MEFs up to 1.40, machine temperature rise of 75 °F (21 °C) and a
that DOE evaluate energy consumption energy is 0.133 kWh/cycle. For MEFs specific heat of 0.0024 kWh/gal × °F
on a per-cubic-foot basis. (Public greater than 1.40, machine energy is (4.186 joule/gram × °C). DOE
Meeting Transcript, No. 5 at p. 158) 0.114 kWh/cycle. With the per-cycle determined the total water use by
DOE agrees that capacity does impact clothes-drying and machine energy multiplying the WF by the clothes
product efficiency, but no data were known, DOE determined the per-cycle container volume.
TABLE II.46.—COMMERCIAL CLOTHES WASHERS: PER-CYCLE ENERGY AND WATER USE BY CANDIDATE STANDARD LEVEL
Energy use Water use
MEF WF
Candidate standard RMC Machine Dryer Water Heat Hot Total
level (percent)
cu.ft./kWh/cyc gal/cu.ft. kWh/cyc kWh/cyc kWh/cyc gal/cyc gal/cyc
Baseline ................... 1.26 9.50 53.7 0.133 1.27 0.82 4.5 26.6
1 ............................... 1.42 9.50 51.2 0.133 1.21 0.63 3.5 26.6
2 ............................... 1.60 8.50 48.4 0.114 1.13 0.50 2.8 23.8
3 ............................... 1.72 8.00 46.5 0.114 1.09 0.43 2.4 22.4
4 ............................... 1.80 7.50 45.3 0.114 1.06 0.39 2.1 21.0
5 ............................... 2.00 5.50 42.2 0.114 0.98 0.31 1.7 15.4
6 ............................... 2.20 5.10 39.0 0.114 0.90 0.26 1.5 14.3
DOE determined the average annual laundromats, DOE focused only on Relative to multi-family buildings and
energy and water consumption for these two building applications to laundromats, these other applications
CCWs by multiplying the per-cycle determine the appropriate number of are a small segment of the market.
energy and water consumption by the CCW cycles per year. Other applications Therefore, DOE believes it is not critical
number of cycles per year. Because the include lodging establishments (e.g., to the analysis to accurately characterize
predominant applications of CCWs are hotels and motels), in-patient health CCW usage for these applications. As
in multi-family buildings and care facilities, and nursing homes. mentioned above, DOE relied on several
31 U.S. Department of Energy. Final Rule Clothes Washers, December 2000. Washington, DC. appliance_standards/residential/
Technical Support Document (TSD): Energy Chapter 4, Table 4.1. Available online at: http:// clothes_washers.html.
Efficiency Standards for Consumer Products: www.eere.energy.gov/buildings/
studies including research sponsored by showed a variation between three to buildings and 6 cycles per day for
the MLA and the CLA to establish eight cycles per day.33 laundromats. For details on the studies
typical use cycles for CCWs. Of the Tables II.47 and II.48 show the annual reviewed by DOE to develop the average
studies on CCW usage, seven focused on energy and water consumption for use cycles of CCWs, refer to Chapter 6
multi-family buildings demonstrating multi-family buildings and of the TSD. In the tables below, the
that usage ranged from one to almost laundromats, respectively. The energy annual water-heating and clothes-drying
eleven cycles per day.32 The sparse data and water consumption values provided energy consumption reflects the use of
for laundromats from three studies below are based on average use cycles both an electric or a gas water heater
of 3.4 cycles per day for multi-family and dryer.
TABLE II.47.—COMMERCIAL CLOTHES WASHERS, MULTI-FAMILY APPLICATION: ANNUAL ENERGY AND WATER USE BY
EFFICIENCY LEVEL
Annual energy use
Candidate MEF WF Water heating Drying Annual water use
standard level Machine
Electric Gas Electric Gas
cu.ft./kWh/cyc gal/cu.ft. kWh/yr MMBtu/yr kWh/yr MMBtu/yr kWh/yr 1000 gal/year
Baseline ........... 1.26 9.50 1020 4.64 1583 6.05 166 33.1
1 ....................... 1.42 9.50 788 3.58 1503 5.74 166 33.1
2 ....................... 1.60 8.50 625 2.84 1414 5.40 142 29.7
3 ....................... 1.72 8.00 532 2.42 1354 5.18 142 27.9
4 ....................... 1.80 7.50 482 2.19 1315 5.02 142 26.2
5 ....................... 2.00 5.50 387 1.76 1215 4.64 142 19.2
6 ....................... 2.20 5.10 328 1.49 1116 4.26 142 17.8
TABLE II.48.—COMMERCIAL CLOTHES WASHERS, LAUNDROMAT APPLICATION: ANNUAL ENERGY AND WATER USE BY
CANDIDATE STANDARD LEVEL
Annual Energy Use
Candidate MEF WF Water heating Drying Annual water use
standard level Machine
Electric Gas Electric Gas
cu.ft./kWh/cyc gal/cu.ft. kWh/yr MMBtu/yr kWh/yr MMBtu/yr kWh/yr 1000 gal/year
Baseline ........... 1.26 9.50 1793 8.16 2782 10.63 291 58.3
1 ....................... 1.42 9.50 1385 6.30 2642 10.10 291 58.3
2 ....................... 1.60 8.50 1098 4.99 2485 9.50 250 52.1
3 ....................... 1.72 8.00 935 4.25 2380 9.10 250 49.1
4 ....................... 1.80 7.50 847 3.85 2310 8.83 250 46.0
5 ....................... 2.00 5.50 680 3.10 2136 8.16 250 33.7
6 ....................... 2.20 5.10 576 2.62 1961 7.49 250 31.3
DOE determined the variability in laundromats, DOE used a triangular for multi-family and laundromat
annual energy and water consumption distribution that ranged from three to applications when it conducted the LCC
based on usage data from the several eight cycles per day and skewed it to and PBP analyses. Additional detail on
CCW studies cited above. The studies yield an average value of six cycles per the energy and water use
DOE identified provided eight average day. This range was based solely on data characterization of CCWs can be found
use values for multi-family buildings from the CLA. Of the three studies that in Chapter 6 of the TSD.
ranging from a low of 1.5 cycles per day DOE used to establish usage, only the
E. Markups To Determine Equipment
to a high of 6.4 cycles per day. For CLA study provided a range. Because
Price
laundromats, the low and high values the two other studies, one from
are three and eight cycles per day, Equipoise Consulting and the other from This section explains how DOE
respectively. DOE weighted the usage CEE, provided an average use of six developed the markups to equipment
from each study to vary the annual cycles per day, DOE skewed the prices that it used to derive total
energy and water consumption of CCWs triangular distribution to yield an installed cost for the four appliance
when it conducted the LCC and PBP average value of six cycles per day. products (see Chapter 7 of the TSD). The
analyses. To reflect the usage patterns As will be described later in section total installed cost is the sum of the
reported in the various studies, DOE II.G on the LCC and PBP analyses, DOE consumer equipment price and the
weighted the use studies equally for used the usage variability to vary the installation cost. DOE multiplied the
multi-family applications. For annual energy and water consumption manufacturing costs developed from the
32 The seven studies were conducted or California Edison (2000); (4) MLA (2002); (5) 33 The three studies were conducted or
commissioned by the following organizations: (1) Wisconsin Focus on Energy (2004); (6) Equipoise commissioned by the following organizations: (1)
City of Toronto (1999); (2) Federal Energy Consulting (2004); and (7) CEE. Equipoise Counsulting (2004); (2) CEE; and (3) the
Management Program (2000); (3),Southern CLA.
engineering analysis by the supply- lodging establishments, and health care Expenditure Survey (BES).36 DOE
chain markups it developed (along with facilities). For these three market areas, organized the financial data into balance
sales taxes) to arrive at the consumer the CEE data indicate that an sheets that break down cost components
equipment prices, and added to them overwhelming majority of CCWs are incurred by firms that sell the products.
the installation costs to arrive at the sold through either distributors or route DOE developed baseline and
final, installed prices for baseline operators. Consistent with ALS’s incremental markups to transform the
products, as well as higher-efficiency comment, the CEE data show that manufacturer sales price into a
products. laundromats generally purchase their consumer equipment price. DOE used
equipment through distributors, the baseline markups, which cover all of
1. Distribution Channels a retailer’s or distributor’s costs, to
whereas multi-family housing and large
Before it could develop markups, DOE institutions generally lease their determine the sales price of baseline
needed to identify distribution channels equipment from route operators. models (equipment sold under existing
(i.e., how the product is distributed from Because the CEE data do not indicate market conditions). The baseline
the manufacturer to the consumer). that national accounts are a significant markup relates the manufacturer sales
AHAM’s 2003 Fact Book shows that distribution channel, DOE did not price to the retailer sales price (in the
over 93 percent of residential appliances consider them in its analysis. Thus, for case of residential products) or
(including dishwashers, dehumidifiers, purposes of developing the markups for distributor sales price (in the case of
and cooking products) are distributed CCWs, DOE based its calculations on CCWs). Incremental markups cover only
from the manufacturer directly to a the distribution channel that involves those costs that scale with a change in
retailer. Thus, DOE analyzed markups only distributors. DOE estimated that the manufacturer’s sales price.
for residential dishwasher, the markups and the resulting consumer Incremental markups are coefficients
dehumidifier, and cooking product sales equipment prices for the distribution that relate the change in the
on the premise that these appliances are channel involving distributors would be manufacturer sales price of higher
sold based on a manufacturer-to-retailer representative of the prices paid by efficiency models (equipment sold
distribution channel. Wolf commented consumers acquiring their equipment under market conditions with new
that for commercial-style cooking from route operators. efficiency standards) to the change in
products, distributors are also involved DOE specifically seeks feedback on the retailer or distributor sales price.
in the distribution of the equipment. whether determining CCW consumer DOE used financial data from the
(Public Meeting Transcript, No. 5 at p. prices based solely on the distribution BES, in the ‘‘Household Appliance
177). For its analysis of cooking channel that includes distributors will Stores’’ category, to calculate markups
products, DOE designated commercial- result in representative equipment used by retailers that apply to
style equipment as a separate product prices for all CCW consumers. This is residential dishwashers, cooking
class that was exempted from the identified as Issue 10 under ‘‘Issues on products, and dehumidifiers. It used
analysis due to the lack of available data Which DOE Seeks Comment’’ in section financial data from the BES for the
for determining efficiency IV.E of this ANOPR. category ‘‘Machinery, Equipment, and
characteristics. Therefore, DOE did not Supplies Merchant Wholesalers’’ to
consider the distribution channels for 2. Approach for Manufacturer Markups calculate markups used by distributors
commercial-style equipment. DOE developed an average for CCWs. Using these markups, DOE
For CCWs, the consumer is usually a manufacturer markup by examining the generated retail prices for each potential
commercial establishment. EEI and ALS annual Securities and Exchange standard level, assuming that each level
both commented on the distribution Commission (SEC) 10–K reports filed by would represent a new minimum
channels for this product. EEI stated four publicly-traded manufacturers efficiency standard.
that national accounts may be primarily engaged in appliance For CCWs, DOE undertook efforts to
applicable if users (e.g., hotels) are manufacturing and whose combined validate the retail prices that it
purchasing units in bulk from dealers. product range includes residential generated through the use of distributor
ALS stated that the distribution dishwashers, dehumidifiers, and markups. Both the Seattle Public
channels DOE identified during its cooking products and commercial Utilities (SPU) and ALS suggested
Framework workshop were correct and clothes washers.35 The four sources for establishing the retail price
added that laundromat owners generally manufacturers represent a nearly 50 of CCWs. SPU stated that it may have
go through distributors to purchase their percent market share for core relevant data that it obtained through
clothes washers, whereas multi-housing appliances. Because these companies one of its rebate incentive programs.
owners generally go through route are typically diversified, producing a ALS suggested that DOE contact the
operators. (Public Meeting Transcript, range of different appliances, an MLA, route operators, and property
No. 5 at pp. 175–176). industry average markup was assumed owners. (Public Meeting Transcription,
DOE developed the distribution by DOE to be representative for the No. 5 at pp. 174 and 176) DOE contacted
channels for this analysis of CCWs after manufacture of each type of appliance. several national distributors of
reviewing data that CEE developed.34 DOE evaluated markups for the years commercial laundry equipment to
The CEE data indicate that the relevant between 2002 and 2005, inclusive. collect CCW retail price data. DOE also
portions of the commercial, family-sized identified a few company Web sites that
clothes washer market can be divided 3. Approach for Retailer and Distributor
Markups provided retail price information. DOE
into three areas: (1) Laundromats; (2) did obtain the price data offered by
private multi-family housing; and (3) DOE based the retailer markups (for SPU, but because all of the data
large institutions (e.g., military barracks, residential products) and distributor corresponded to high-efficiency, front-
universities, housing authorities, markups (for CCWs) on financial data
from the U.S. Census Business 36 U.S. Census Bureau. 1997 Economic Census,
34 Consortium for Energy Efficiency, Commercial Business Expense Survey, Retail Trade, Household
Family-Sized Washers: An Initiative Description of 35 Security Exchange Commission, SEC 10–K Appliance Stores and Merchant Wholesalers,
the Consortium for Energy Efficiency, 1998. Reports, Various dates, 2002–2005, Security Machinery, Equipment, and Supplies, 1997.
Available online at: http://www.cee1.org/com/cwsh/ Exchange Commission. Available online at: http:// Washington, DC Available online at: http://
cwsh-main.php3 www.sec.gov/ www.census.gov/csd/bes/bes97.htm
loading, horizontal-axis washers, the increment for achieving CCW distribution channel and the overall
data were not useful for identifying the efficiencies in the range of 1.72 to 2.20 baseline and incremental markups, as
price differential between baseline and MEF were reasonable. Chapter 3 of the well as sales taxes. AHAM questioned
more-efficient products. With the price TSD provides details on DOE’s CCW what the typical overall markup is for
data it did collect, DOE attempted to retail price data collection effort. home appliances and stated that, for
develop a retail price-versus-efficiency 4. Sales Taxes residential clothes washers, a prior
curve. However, most of the price data standards rulemaking analysis
collected from distributors and Web The sales tax component of the DOE
established an overall markup of
sites did not provide the necessary mark-up analysis represents State and
local sales taxes that are applied to the approximately 2.0. (Public Meeting
information to establish the efficiency of Transcript, No. 5 at p. 177) As shown
consumer appliance price. It is a
these commercial clothes washers. in Table II.49, the overall baseline
multiplicative factor that increases the
Therefore, DOE was only able to markup is approximately 2.0 for all
consumer appliance price. DOE derived
establish the retail price differential State and local taxes from data provided products, almost the same as the
between a typical top-loading, vertical- by the Sales Tax Clearinghouse.37 These markup DOE used in its residential
axis machine and a front-loading, data represent weighted averages that clothes washer standard rulemaking.
horizontal-axis machine. The retail include county and city rates. DOE then The overall incremental markup, which
price difference (approximately $500) is derived population-weighted average DOE applied to an incremental change
very close to the retail price DOE tax values for each Census division and in manufacturing costs to develop an
generated through the use of markups. large State. incremental change in retail price, is
Therefore, for the price difference approximately 1.60. Additional detail
between a typical top-loading machine 5. Summary of Markups
on markups can be found in Chapter 7
and a typical front-loading machine, Table II.49 summarizes each product’s of the TSD.
DOE confirmed that its retail price markups at each stage in the
TABLE II.49.—SUMMARY OF MARKUPS

Dishwashers Dehumidifiers Cooking products Commercial clothes washers
Markup
Baseline Incr. Baseline Incr. Baseline Incr. Baseline Incr.
Manufacturer ...................................... 1.26 1.26 1.26 1.26
Retailer ............................................... 1.45 1.15 1.45 1.15 1.45 1.15
Distributor ........................................... 1.43 1.18
Sales Tax ........................................... 1.068 1.065 1.069* 1.068
Overall ................................................ 1.95 1.55 1.95 1.54 1.95 1.55 1.93 1.59
• Represents average of all seven product classes of cooking products.
F. Rebuttable Presumption Payback under the applicable test procedure information into account when
Periods * * * ’’ (42 U.S.C. 6295(o)(2)(B)(iii) and determining whether a standard is
6316(a)) economically justified. (42 U.S.C.
A more energy efficient device will To evaluate the rebuttable 6295(o)(2)(B)(iii))
usually cost more to buy than a device presumption, DOE estimated the Inputs to the PBP calculation are the
of standard energy efficiency. However, additional cost of purchasing a more first seven inputs shown in Table II.57
the more efficient device will usually efficient, standard-compliant product, found in section II.G.2 of this ANOPR.
cost less to operate due to reductions in and compared this cost to the value of The rebuttable PBPs differ from the
operating costs (i.e., lower energy bills). the energy saved during the first year of other PBPs calculated in the LCC
The PBP is the time (usually expressed operation of the product. DOE analysis, in that the calculation of
in years) it takes to recover the understands that the increased cost of rebuttable PBP uses discrete values
additional installed cost of the more purchasing a standard-compliant (rather than distributions) for inputs.
efficient device (i.e., the incremental product includes the cost of installing Other than the use of single-point
cost) through energy cost savings. EPCA the product for use by the purchaser. values, the most notable difference
establishes a rebuttable presumption DOE calculated the rebuttable between the distribution PBP and the
that a standard for any of the four presumption PBP (rebuttable PBP), as rebuttable PBP is the latter’s reliance on
appliance products is economically the ratio of the value of the increased the DOE test procedure to determine a
justified ‘‘[i]f the Secretary finds that the installed price above the baseline product’s annual energy (and water)
additional cost to the consumer of efficiency level to the first year’s energy consumption. The distribution PBP is
purchasing a product complying with cost savings. When this PBP is less than based on the annual energy and water
an energy conservation standard level three years, the rebuttable presumption consumption data described in section
will be less than three times the value is satisfied. When this PBP is equal to II.D, which are characterized with a
of the energy * * * savings during the or more than three years, the rebuttable range of values as opposed to the
first year that the consumer will receive presumption is not satisfied. In such discrete single-point value that is used
as a result of the standard, as calculated case, the Secretary must take such for the rebuttable PBP.
37 Sales Tax Clearinghouse, Inc. State sales tax rates, 2006. Available online at: http://thestc.com/
rates along with combined average city and county STrates.com.
For dishwashers, DOE based the Because the distribution PBPs are based based on residential use to comply with
annual energy and water consumption on more recent data that more the requirements of EPCA, namely, to
values that it used to determine the accurately reflects the current energy calculate the rebuttable PBP under the
rebuttable PBP on the number of cycles consumption of cooking products, the applicable test procedure. DOE
per year specified in the DOE test distribution PBPs are more reflective of understands that the distribution PBP,
procedure. The number of cycles from actual PBPs than the rebuttable PBPs. which is based on commercial use,
the DOE test procedure, 215 cycles per For CCWs, DOE based the annual reflects the actual PBP of CCW.
year, is equal to the average number of energy and water consumption values DOE calculated rebuttable PBPs for
cycles that DOE used in its each standard level relative to the
that it used to determine the rebuttable
determination of distribution PBPs. distribution of product efficiencies that
PBP on the number of cycles per year
Thus, on average, the rebuttable PBP for were used for the base case. Section
specified in the DOE test procedure. The
dishwashers is virtually the same as the II.G.2.d of this ANOPR provides details
CCW test procedure cites the residential
average distribution PBP. on the base case efficiency distributions
For dehumidifiers, the DOE test clothes washer test procedure to
establish efficiency ratings as well as for each of the four appliance products.
procedure does not provide a method
for determining the product’s annual annual energy and water consumption. Tables II.50 through II.56 show the
energy consumption. As a result, the As a result, the annual number of use nationally-averaged, rebuttable PBPs
DOE test procedure does not offer a cycles, 392 cycles per year, for calculated for all product classes and
basis for determining the rebuttable determining the annual energy and candidate standard levels for each
PBP. Therefore, for its determination of water consumption of CCWs, is considered product.
rebuttable PBP, DOE decided to use the representative of residential use, not
same average operational use estimate of commercial use. Because residential use TABLE II.50.—STANDARD-SIZED DISH-
1,095 hours that it used in its is significantly lower than the average WASHERS: REBUTTABLE PAYBACK
determination of distribution PBPs. usage for commercial applications— PERIODS
Thus, the rebuttable PBP for 1,241 cycles per year in multi-family
dehumidifiers is virtually the same as buildings and 2,190 cycles per year in Candidate standard PBP
laundromats—the average annual EF
the average distribution PBP. level years
For cooking products, DOE energy and water consumption DOE
determined the rebuttable PBP based on used to determine rebuttable PBP is Baseline ........................ 0.46 ..............
DOE test-procedure-derived annual significantly less than the consumption 1 .................................... 0.58 0.7
energy consumption values which are, expected to be associated with actual 2 .................................... 0.62 2.1
on average, greater than the annual usage. As a result, the rebuttable PBP is 3 .................................... 0.65 4.6
significantly longer than the distribution 4 .................................... 0.68 9.5
energy use that DOE used to determine
5 .................................... 0.72 17.9
the distribution PBPs. Thus, the PBPs for both multi-family and
6 .................................... 0.80 21.8
rebuttable PBPs for cooking products are laundromat applications. To emphasize, 7 .................................... 1.11 16.6
shorter than the distribution PBPs. DOE calculated the rebuttable PBPs
TABLE II.51.—DEHUMIDIFIERS: REBUTTABLE PAYBACK PERIODS

0–35.00 pints/day* 35.01–45.00 pints/day 54.01–74.99 pints/day
Candidate Stand- EF PBP years Level EF PBP years Level EF PBP years
ard Level
Baseline ................ 1.20 .................. Baseline ................ 1.30 .................. Baseline ................ 1.50 ..................
1 ............................ 1.25 2.4 1 ............................ 1.35 4.0 1 ............................ 1.55 2.3
2 ............................ 1.30 1.7 2 ............................ 1.40 5.5 2 ............................ 1.60 2.2
3 ............................ 1.35 3.0 3 ............................ 1.45 5.8 3 ............................ 1.65 2.6
4 ............................ 1.40 4.3 4 ............................ 1.50 6.5 4 ............................ 1.70 4.7
5 ............................ 1.45 5.7 5 ............................ 1.74 8.0 5 ............................ 1.80 4.2
* PBP based on the annual energy consumption and operating cost associated with the 25.01–35.00 pints/day class.
TABLE II.52.—COOKTOPS: REBUTTABLE PAYBACK PERIODS

Electric coil Electric smooth Gas
Candidate standard PBP PBP PBP

EF Level EF Level EF
level years years years
Baseline ................ 0.737 .................. Baseline ................ 0.742 .................. Baseline ................ 0.156
1 ............................ 0.769 3.7 1 ............................ 0.753 410 1 ............................ 0.399 1.3
2 ............................ 0.420 34
TABLE II.53. OVENS: REBUTTABLE PAYBACK PERIODS

Electric standard Electric self-clean Gas standard Gas self-clean
Candidate PBP PBP PBP PBP

EF Level EF Level EF Level EF
standard level years years years years
Baseline ........ 0.1066 ............ Baseline ........ 0.1099 ............ Baseline ........ 0.0298 ............ Baseline ........ 0.0540 ............
TABLE II.53. OVENS: REBUTTABLE PAYBACK PERIODS—Continued

Electric standard Electric self-clean Gas standard Gas self-clean
Candidate PBP PBP PBP PBP

EF Level EF Level EF Level EF
standard level years years years years
1 .................... 0.1113 2.2 1 .................... 0.1102 88.6 1* .................. 0.0536 4.2 1 .................... 0.0625 6.5
2 .................... 0.1163 3.3 2 .................... 0.1123 120.2 2 .................... 0.0566 4.8 2 .................... 0.0627 8.8
3 .................... 0.1181 5.1 ....................... ............ ............ 3 .................... 0.0572 5.2 3 .................... 0.0632 9.0
4 .................... 0.1206 24.0 ....................... ............ ............ 4 .................... 0.0593 20.0 ....................... ............ ............
5 .................... 0.1209 25.2 ....................... ............ ............ 5 .................... 0.0596 20.3 ....................... ............ ............
6 .................... 0.0600 21.4 ....................... ............ ............
1a* ................ 0.0583 1.4 ....................... ............ ............
* For gas standard ovens, candidate standard levels 1 and 1a correspond to designs that are utilized for the same purpose—eliminate the
need for a standing pilot—but the technologies for each design are different. Candidate standard level 1 is a hot surface ignition device while
candidate standard level 1a is a spark ignition device. Candidate standard level 1a is presented at the end of the table because candidate stand-
ard levels 2 through 6 are derived from candidate standard level 1.
TABLE II.54.—MICROWAVE OVENS: energy consumption under the DOE test commercial consumer to recover the
REBUTTABLE PAYBACK PERIODS procedure. Therefore, in the LCC and assumed higher purchase expense of
PBP analyses described in the following more energy efficient equipment
PBP section, DOE evaluated the candidate through lower operating costs. Similar
Candidate standard level EF years standard levels for the considered to the LCC, the PBP is based on the total
products using conditions that reflect installed cost and the operating
Baseline ............................ 0.557 ............
normal use of the equipment. expenses. However, unlike in the LCC,
1 ........................................ 0.586 18.9
2 ........................................ 0.588 36.8 While DOE has examined the DOE considers only the first year’s
3 ........................................ 0.597 52.5 rebuttable presumption PBPs, DOE does operating expenses in the calculation of
4 ........................................ 0.602 73.9 not expect to determine the economic the PBP. Because the PBP does not
justification for any of the standard account for changes in operating
levels analyzed based on the ANOPR expense over time or the time value of
TABLE II.55.—COMMERCIAL CLOTHES rebuttable presumption analysis. DOE’s money, it is also referred to as a simple
WASHERS, MULTI-FAMILY APPLICA- decision on standard levels will take PBP. DOE utilizes the simple PBP
TION: REBUTTABLE PAYBACK PERI- into account the more detailed analysis because of its simplicity, transparency,
ODS of the economic impacts of increased and clarity. The simple PBP is a good
efficiency pursuant to section approximation of more complex metrics
Candidate stand- PBP 325(o)(2)(B)(i) of EPCA. (42 U.S.C. that are based on operating expenses
MEF WF
ard level years that do not change significantly from
6295(o)(2)(B)(i))
Baseline ............ 1.26 9.50 ............ year to year. For purposes of capturing
G. Life-Cycle Cost and Payback Period the annual change in operating
1 ........................ 1.42 9.50 24.0 Analyses
2 ........................ 1.60 8.50 34.2 expenses, DOE uses the LCC which
3 ........................ 1.72 8.00 25.6 The LCC and PBP analyses determine accounts for the lifetime operating
4 ........................ 1.80 7.50 21.2 the economic impact of potential expenses of the product. For more detail
5 ........................ 2.00 5.50 13.6 standards on consumers. The effects of on the LCC and PBP analyses, refer to
6 ........................ 2.20 5.10 9.6 Chapter 8 of the TSD.
standards on individual consumers—or
commercial consumers in the case of
1. Approach
TABLE II.56.—COMMERCIAL CLOTHES CCWs—include changes in operating
WASHERS, LAUNDROMAT APPLICA- expenses (usually lower) and changes in During the Framework workshop,
TION: REBUTTABLE PAYBACK PERI- total installed cost (usually higher). DOE DOE considered conducting the LCC
ODS
analyzed the net effect of these changes and PBP analyses using an approach
for the four appliance products, first, by that characterized inputs to the analysis
Candidate stand- PBP calculating the changes in consumers’ with average values and handling any
MEF WF LCCs likely to result from candidate uncertainties or variability in the inputs
ard level years
standard levels as compared to a base through the use of scenarios that
Baseline ............ 1.26 9.50 ............ case (no new standards). The LCC analyzed the effect of high and low
1 ........................ 1.42 9.50 29.8 calculation considers total installed cost values on the results. In recent
2 ........................ 1.60 8.50 39.1
(which includes manufacturer selling standards rulemakings for other
3 ........................ 1.72 8.00 29.1
4 ........................ 1.80 7.50 24.0 price, sales taxes, distribution channel products (e.g., residential furnaces and
5 ........................ 2.00 5.50 15.0 markups, and installation cost), boilers and distribution transformers),
6 ........................ 2.20 5.10 10.7 operating expenses (energy, repair, and DOE conducted the LCC and PBP
maintenance costs), equipment lifetime, analyses by modeling both the
Some of the candidate standard levels and discount rate. DOE performed the uncertainty and variability in the inputs
appear to satisfy the rebuttable LCC analysis from the perspective of the using Monte Carlo simulation and
presumption test, but others do not. consumer of each product. probability distributions. Although
However, PBPs calculated based on DOE also analyzed the effect of more extensive than the aforementioned
energy consumption in actual field changes in operating expenses and approach based on the use of average
conditions are generally more accurate installed costs by calculating the PBP of inputs, the Monte Carlo approach
than, and may differ significantly from, potential standards relative to a base provides additional information,
the PBPs calculated under the rebuttable case. The PBP estimates the amount of specifically the percentage of consumers
presumption test, which are based on time it would take the individual or benefiting from and being burdened by
a prospective standard. The Joint units that collects statistical information ADL, and for cooking products, studies
Comment supported DOE’s retention of on the consumption of and expenditures from the 2004 CA RASS and the FSEC).
Monte Carlo-based LCC and PBP for energy in housing units along with Therefore, to emphasize, DOE used
analyses for this rulemaking, as long as data on energy-related characteristics of RECS to establish the variability in
the additional work required to perform the housing units and occupants. The annual energy use of dishwashers and
the analyses over a simpler approach is 2001 RECS consists of for 4,822 housing cooking products, not the average
not extensive. The Joint Comment stated units and was constructed by EIA to be consumption. For dehumidifiers, DOE
that the Monte Carlo approach provides a national representation of the used RECS to establish only the
useful information on the percentage of household population in the U.S. Of the variability in electricity pricing. By
consumers benefiting from and being household sub-samples used in the LCC using RECS, DOE was able to assign a
burdened by an efficiency standard. and PBP analysis, only two (for unique annual energy use and/or energy
(Joint Comment, No. 9 at p. 3) EEI and dehumidifiers and gas self-cleaning price to each household in the sample.
NWPCC also urged DOE to retain the ovens) have a size which is less than 20 Due to the large sample of households
Monte Carlo approach due to the percent of the total 2001 RECS housing considered in the LCC and PBP
additional information it provides over unit size. Even so, the potential errors analyses, the range of annual energy use
a simpler analysis. (EEI, No. 7 at p. 5; associated with these smaller sub- and/or energy prices is quite large.
Public Meeting Transcription, No. 5 at sample sizes are not anticipated to be so Thus, although the annual energy use
p. 228) DOE agrees with the comments large as to affect the validity of the and/or energy pricing are not uncertain
that the benefits of conducting the LCC results. Specifically, the standard error for any particular household, their
and PBP with a Monte Carlo approach of a sample of size ’n’ is the sample’s variability across all households
outweigh the extra effort it takes to standard deviation divided by the contributes to the range of LCCs and
implement it. Therefore, DOE developed square root of ’n’. For the full 2001 PBPs calculated for any particular
its LCC and PBP spreadsheet models RECS sample the associated standard candidate standard level.
incorporating both Monte Carlo error is the sample’s standard deviation
simulation and probability distributions multiplied by 1.5 percent. For the For CCWs, DOE was unable to
by using Microsoft Excel spreadsheets dehumidifier and gas self-cleaning oven develop a consumer sample, since
combined with Crystal Ball (a sub-samples, the associated standard neither RECS nor EIA’s Commercial
commercially available add-in program). error is the sub-sample’s standard Building Energy Consumption Survey
In addition to characterizing several deviation multiplied by 4.5 percent. (CBECS) provide the necessary data to
of the inputs to the analysis with Although the standard error of the sub- develop one. As a result, DOE was not
probability distributions, in the case of samples is three times the size of the able to use a consumer sample to
residential dishwashers, dehumidifiers, entire 2001 RECS, it is still less than five establish the variability in energy use
and cooking products, DOE also percent. DOE believes a standard error (and water use) and energy pricing (and
developed a sample of individual of less than five percent is still small water pricing) for CCWs. Instead, DOE
households that use each of the enough to yield meaningful results. established the variability and
appliances. The household sample sizes Therefore, DOE believes the results uncertainty in energy and water use for
for these residential products are: 2,476 generated from the household samples CCWs by defining the uncertainty and
household records from dishwashers; for dishwashers, dehumidifiers, and variability in the use (cycles per day) of
578 for dehumidifiers; 2,895 for electric cooking products are representative of the equipment. The variability and
cooktops; 1,159 for electric standard U.S. households using these appliances. uncertainty in energy and water pricing
ovens; 1,601 for electric self-cleaning For dishwashers and cooking are characterized by regional differences
ovens; 1,597 for gas cooktops; 959 for products, DOE used EIA’s 2001 RECS to in energy and water prices.
gas standard ovens; and 494 for gas self- establish the variability in annual 2. Life-Cycle Cost Inputs
cleaning ovens. By developing energy use and energy pricing. (DOE
household samples, DOE was able to also established the variability of annual For each efficiency level analyzed, the
perform the LCC and PBP calculations water use and water pricing for LCC analysis requires input data for the
for each household to account for the dishwashers using the 2001 RECS.) total installed cost of the equipment, the
variability in energy (and water) Note, as discussed previously in section operating cost, and the discount rate.
consumption and/or energy price II.D on the energy and water use of the Table II.57 summarizes the inputs and
associated with each household. DOE four appliance products, DOE key assumptions DOE used to calculate
used EIA’s 2001 RECS to develop characterized the average energy use of the customer economic impacts of
household samples for each of the above dishwashers and cooking products on various candidate standard levels for
three sets of products. The 2001 RECS relatively recent studies (for each product. A more detailed
is a national sample survey of housing dishwashers, a 2001 study performed by discussion of the inputs follows.
TABLE II.57.—SUMMARY OF INPUTS AND KEY ASSUMPTIONS USED IN THE LIFE-CYCLE COST ANALYSES
Input Description
Baseline Manufacturer Cost ........... The baseline manufacturer cost is the cost incurred by the manufacturer to produce equipment meeting
existing minimum efficiency standards.
Standard-Level Manufacturer Cost Standard-level manufacturer cost increases are the incremental change in manufacturer cost associated
Increases. with producing equipment at a standard level.

Markups and Sales Tax .................. Markups and sales tax convert the manufacturer cost to a consumer equipment price.
Installation Cost .............................. The installation cost is the cost to the consumer of installing the equipment and represents all costs re-
quired to install the equipment other than the marked-up consumer equipment price. The installation cost
includes labor, overhead, and any miscellaneous materials and parts.
TABLE II.57.—SUMMARY OF INPUTS AND KEY ASSUMPTIONS USED IN THE LIFE-CYCLE COST ANALYSES—Continued
Input Description
Annual Energy (and Water) Con- The annual energy consumption is the site energy use associated with operating the equipment. The an-
sumption. nual water consumption, which is applicable to dishwashers and CCWs, is the site water use associated
with operating the equipment. The annual energy (and water) consumption vary with the product effi-
ciency.
Energy and Water Prices ................ Energy and water prices are the prices paid by consumers for energy (i.e., electricity, gas, or oil) and
water. Multiplying the annual energy and water consumption by the energy and water prices yields the
annual energy cost and water cost, respectively.
Repair and Maintenance Costs ...... Repair costs are associated with repairing or replacing components that have failed. Maintenance costs
are associated with maintaining the operation of the equipment.
Energy and Water Price Trends ..... DOE uses energy and water price trends to forecast energy and water prices into the future and, along
with the product lifetime and discount rate, to establish the lifetime energy and water costs.
Product Lifetime .............................. The product lifetime is the age at which the equipment is retired from service.
Discount Rate ................................. The discount rate is the rate at which DOE discounts future expenditures to establish their present value.
a. Total Installed Cost Inputs line to be plumbed to the dishwasher in require the installation of an electrical
The inputs to calculate total installed addition to the hot water line, this outlet in the kitchen to bring electrical
cost are as follows. ‘‘Baseline design would incur greater installation service to the product. DOE used data
manufacturer cost’’ is the cost incurred costs than a baseline dishwasher. from RS Means to estimate the
by the manufacturer to produce (Public Meeting Transcript, No. 5 at p. installation cost of an electrical outlet.
equipment meeting existing minimum 204) DOE agrees with Whirlpool, but in For CCWs, GE stated that because
efficiency standards. ‘‘Standard-level its development of the manufacturing CCWs are more difficult to install than
manufacturer cost increases’’ are the cost-versus-efficiency relationship, DOE typical residential clothes washers, the
change in manufacturer cost associated did not believe that any of the standard installation costs associated with
with producing equipment to meet a levels would require a reduction in inlet residential washers should not be used
particular energy efficiency level (i.e., water temperature. Thus, DOE did not as a basis for establishing CCW
the incremental cost). Markups and alter its decision to keep the installation installation costs. (Public Meeting
sales tax convert the manufacturer cost cost constant for more efficient designs. Transcript, No. 5 at p. 46) DOE agrees
to a consumer equipment price. The For cooktops and ovens, DOE based with GE and based its installation cost
installation cost is the cost to the its installation cost for baseline for baseline equipment on the nationally
consumer of installing the equipment equipment on the nationally representative average costs associated
and represents all costs required to representative average cost associated with the installation of a four-cycle,
install the equipment other than the with the installation of 30-inch, free- coin operating CCW as provided by RS
marked-up consumer equipment price. standing cooking ranges as provided by Means. DOE determined that
Thus, the total installed cost equals the RS Means. DOE estimated that the costs installation costs would not be impacted
consumer equipment price plus the of installing a range are also by increased standard levels because
installation cost. For a complete representative of the costs of installing none of the CCWs currently on the
discussion on manufacturer costs refer either a cooktop or an oven. However, market differ from each other in terms
back to section II.C in this ANOPR. For Whirlpool suggested that DOE should of installation requirements despite
details on markups and sales taxes, refer assess whether more efficient cooking existing variations in their level of
back to section II.E in this ANOPR. products incur increased installation efficiency. All CCW have similar
More specifically, installation costs costs. (Whirlpool, No. 10 at p. 10) As a connections for electrical power,
include labor, overhead, and any basis for assessing whether installation incoming water, and drains. In addition
miscellaneous materials and parts. DOE costs vary with product efficiency, DOE to these basic connections, CCW may
determined installation costs for used its own supplemental analysis to require some additional cabling for
dishwashers, cooktops and ovens, and the previous rulemaking’s TSD. In the vending systems and monitoring.
CCWs based on data in the RS Means supplemental analysis, DOE determined However, neither vending systems nor
Plumbing Cost Data, 2005.38 RS Means that only gas cooktops and ovens with system monitoring enhances CCW
provides estimates on the labor required electronic ignition devices would incur energy efficiency.
to install each of above three products. added installation costs.39 Because DOE Lastly, for dehumidifiers and
For dishwashers, DOE based its did not receive any information to the microwave ovens, DOE determined that
installation cost for baseline equipment contrary, DOE retained this there are no costs associated with the
on the nationally representative average determination for its current analysis. installation of these products as a
cost associated with the installation of For gas cooktops and ovens, the function of energy efficiency. Both types
a four-or-more-cycle dishwasher as previous analysis estimated, as an upper of products only require an available
provided by RS Means. In addition, bound, that 20 percent of households outlet to begin operating. Some
DOE determined that installation costs using gas cooktops and ovens that do dehumidifiers may require some
would not be impacted by increased not require electricity to operate would additional work to allow condensate to
standard levels. In reference to a design drain directly into a drain. However,
requiring a reduction in the inlet water 39 U.S. Department of Energy. Technical Support this product functionality is not related
temperature, Whirlpool stated that Document Energy Conservation Standards for to energy efficiency—it simply relieves
because it would require a cold water
Consumer Products Cooking Products, the user from having to drain the
Supplemental Chapter 4—Life Cycle Cost and condensate bucket from time to time.
Payback Periods, Washington, DC. Available online
38 RS Means. Plumbing Cost Data, 28th Edition, at: http://www.eere.energy.gov/buildings/
Additional details on the
2005. Kingston, MA. p. 97. Available online for appliance_standards/residential/cooking_ development of installation costs can be
purchase at: http://www.remeans.com/. products_0998_r.html. found in Chapter 8 of the TSD.
b. Operating Cost Inputs (Northeast, South, Midwest, and West). to that for residential price, except that
The operating cost inputs are as Using these energy and water price data, DOE used commercial sector data.
follows. Annual energy consumption is DOE analyzed their variability at the DOE estimated residential and
the site energy use associated with regional level for each of the four commercial natural gas prices in each of
operating an appliance product. Annual appliance products. the 13 geographic areas based on data
For the three residential products (i.e., from the EIA publication Natural Gas
water consumption, which is applicable
dishwashers, dehumidifiers, and Monthly.40 This publication includes a
to dishwashers and CCWs, is the site
cooking products), DOE used 2001 compilation of monthly natural gas
water use associated with operating an
RECS data to develop a sample of delivery volumes and average consumer
appliance product. Energy and water
individual households that use each of prices by State, for residential,
prices are the prices paid by consumers
the appliances. By developing commercial, and industrial customers.
for energy (i.e., electricity, gas, or oil)
household samples, DOE was able to Specifically, DOE used the complete
and water. DOE used energy and water
perform the LCC and PBP calculations annual data for 2005 to calculate an
price trends to forecast energy and water
for each household to account for the average summer and winter price for
prices into the future. Multiplying the
regional variability in energy and water each area. It calculated seasonal prices
annual energy and water consumption
prices associated with each household. because, for some end uses, seasonal
by the energy and water prices yields variation in energy consumption is
the annual energy cost and water cost, Because households use either electric,
gas, or oil water heaters, DOE had to significant. DOE defined summer as the
respectively. Repair costs are associated months May through September, with
with repairing or replacing components develop residential electricity, natural
gas, and oil prices for its analysis of all other months defined as winter. DOE
that have failed. Maintenance costs are calculated an average natural gas price
associated with maintaining the dishwashers. For dehumidifiers, DOE
used only residential electricity prices by first calculating the summer and
operation of the equipment. The winter prices for each State, using a
product lifetime is the age at which the because this product runs strictly using
electricity. Since cooking products simple average over the appropriate
equipment is retired from service. The months, and then calculating a regional
discount rate is the rate at which DOE consist of electric and gas equipment,
DOE had to use both residential price by weighting each State in a region
discounted future expenditures to by its population. This method differs
establish their present value. The inputs electricity and natural gas prices in its
analysis. from the method used to calculate
for estimating annual energy (and water) electricity prices, because EIA does not
consumption are discussed in section For CCWs, DOE was unable to
provide consumer-level or utility-level
II.D. develop a consumer sample, since
data on gas consumption and prices.
With regard to energy prices, DOE neither RECS nor EIA’s CBECS provide
The calculation methodology of an
derived average prices for 13 geographic the necessary data to develop one. Thus,
average commercial natural gas price is
areas consisting of the nine U.S. Census DOE characterized energy and water
identical to that for residential price,
divisions, with four large States (New price regional variability with
except that DOE used commercial sector
York, Florida, Texas, and California) probability distributions. It based the data.
treated separately. For Census divisions probability associated with each DOE estimated residential oil prices
containing one of these large States, regional energy and water price on the in each of the 13 geographic areas based
DOE calculated the regional average population weight of each region. on data from EIA’s Petroleum
values leaving out data for the large Because commercial laundry Navigator.41 From this Web site,
State—for example, the Pacific region establishments use either electric or gas available data include a compilation of
average does not include California, and water heaters and dryers, DOE monthly oil delivery volumes and
the West South Central does not include developed both commercial electricity average consumer prices by State, for
Texas. EEI stated that DOE should use and natural gas prices for its analysis of residential, commercial, and industrial
commercial energy prices to conduct the CCWs. customers. Specifically, DOE used the
LCC and PBP analyses of CCWs and DOE estimated residential and complete annual data for 2005 to
residential prices to conduct the commercial electricity prices for each of calculate an average oil price. It first
analyses for the residential products. the 13 geographic areas based on data calculated the prices for each State
(EEI, No. 7 at p. 4) DOE agreed with from EIA Form 861, Annual Electric using simple averages and then
EEI’s suggestion, and as described Power Industry Report. These data are calculated a regional price, weighting
below, DOE developed residential published annually and include annual each State in a region by its population.
energy prices for its analysis of electricity sales in kWh, revenues from DOE obtained residential water and
dishwashers, dehumidifiers, and electricity sales, and number of wastewater price data from the 2004
cooking products, and commercial consumers, for the residential, Water and Wastewater Rate Survey
energy prices for CCWs. commercial, and industrial sectors, for conducted by Raftelis Financial
With regard to water prices, DOE every utility serving final consumers. Consultants and the American Water
derived average prices for the four DOE calculated an average residential Works Association.42 The survey covers
Census regions. As described below, electricity price by first estimating an approximately 300 water utilities and
DOE used survey data survey covering average residential price for each
approximately 300 water utilities and utility—by dividing the residential 40 DOE-Energy Information Administration,
200 wastewater utilities to develop revenues by residential sales—and then Natural Gas Monthly, available online at: http://
www.eia.doe.gov/oil_gas/natural_gas/
water and wastewater prices. Because a calculating a regional average price by
data_publications/natural_gas_monthly/ngm.htm.
sample of 200–300 utilities is not large weighting each utility with customers in 41 DOE Energy Information Administration,
enough to calculate regional prices for a region by the number of residential Petroleum Navigator, available online at: http://
all U.S. Census divisions and large consumers served in that region. The tonto.eia.doe.gov/dnav/pet/pet_pri_top.asp.
42 Raftelis Financial Consultants, Inc. 2004 RFC/
States (for comparison, DOE used calculation methodology uses recently
AWWA Water and Wastewater Rate Survey, 2004.
electricity price data form more than available EIA data from 2004. The Charlotte, NC, Kansas City, MO, and Pasadena, CA.
3000 utilities), DOE calculated regional calculation methodology of an average Available online at: http://www.raftelis.com/
values at the Census region level commercial electricity price is identical ratessurvey.html.
200 wastewater utilities, with each current EIA energy price forecasts are of competitive energy prices to simulate
industry analyzed separately. The water too low and will likely be revised the delay from the time suppliers
survey includes, for each utility, the upwards over the next few years. The experience cost changes to the time
cost to consumers of purchasing a given Joint Comment requested that DOE use consumers experience price changes as
volume of water. In this case, the data the latest available price forecasts from a result of the length of fixed-price
include a division of the total consumer EIA to conduct their analyses. (Joint contracts for standard-offer service (i.e.,
cost into fixed and volumetric charges. Comment, No. 9 at p. 2) To estimate rates typically provided by regulated
Pacific Gas & Electric Company (PG&E) future energy prices, DOE used EIA’s utilities) and competitive retail service.
suggested that DOE determine the Annual Energy Outlook (AEO) 2007, National Consumer Law Council
marginal price of water and wastewater containing the latest available price (NCLC) asked how DOE will account for
for its analysis. PG&E claimed that the forecasts from EIA.43 To arrive at prices the variability in future electricity prices
marginal cost of improving wastewater in future years, DOE multiplied the in the analyses. (Public Meeting
treatment plants to comply with State average prices described in the Transcript, No. 5 at p. 188) In response,
and Federal regulations is very high. preceding section by the forecast of we note that DOE addressed future
Because higher marginal costs translate annual average price changes in AEO variability in electricity prices by
into higher marginal prices, PG&E states 2007. Because AEO 2007 forecasts incorporating three separate projections
that the marginal price would be a more prices to 2030, DOE followed past from AEO 2007 into the spreadsheet
accurate representation of the economic guidelines provided to the Federal models for calculating LCC and PBP: (1)
savings due to reduced water Energy Management Program (FEMP) by Reference Case; (2) Low Economic
consumption. (Public Meeting EIA and used the average rate of change Growth Case; and (3) High Economic
Transcript, No. 5 at p. 190) As PG&E during 2020–2030 for electricity and the Growth Case. These three cases reflect
suggested, DOE calculated only the average rate of change during 2015– the uncertainty of economic growth in
volumetric charge to determine water 2020 for natural gas and oil to estimate the forecast period. The high and low
prices, since only this charge would be the price trends after 2030. More recent growth cases show the projected effects
affected by a change in water guidelines to FEMP suggest that a 10- of alternative growth assumptions on
consumption. Including the fixed charge year rather than a 15-year historical time energy markets.
in the average water price would lead to period be used to extrapolate natural gas To estimate the future trend for water
a slightly higher water price. For and oil prices. DOE intends to use the and wastewater prices, DOE used data
wastewater utilities, the format is more recent guidelines to extrapolate on the historic trend in the national
similar, but the cost refers to the cost of gas and oil prices for the NOPR. For the water price index (U.S. city average)
treating a given volume of wastewater. analyses to be conducted for the NOPR from 1970 through 2005 provided by the
EEI stated that price of water and and Final Rule, DOE intends to update Bureau of Labor Statistics. DOE
wastewater is highly variable depending its energy price forecasts at those stages extrapolated a future trend based on the
on consumer use or volume and of the rulemaking based on the latest linear growth over the 1970–2005 time
geographic location. (Public Meeting available AEO. period.
Transcript, No. 5 at p. 192) DOE agrees NWPCC commented that energy rate For further details on DOE’s method
with EEI in determining regional water caps will be coming off in the next few for forecasting energy and water prices,
and wastewater prices. However, a years for many States in the U.S. and see Chapter 8 of the TSD.
sample of 200–300 utilities is not large With respect to repair and
asked whether EIA’s energy price
enough to calculate regional prices for maintenance costs, DOE assumed that
forecasts take this into account. (Public
all U.S. Census divisions and large small, incremental changes in products
Meeting Transcript, No. 5 at p. 193) In
States (for comparison, the EIA Form related to efficiency result in either no
response, we note that EIA conducts an or only very small changes in repair and
861 data include more than 3,000 annual review of changes in energy
utilities). For this reason, DOE maintenance costs, as compared to
prices by supply region and State in baseline products. DOE acknowledges
calculated regional values at the Census- developing its AEO. In estimating future
region level (Northeast, South, Midwest, there is a greater probability that
energy prices, EIA determines which equipment with efficiencies that are
and West). DOE calculated average per- regions of the country are regulated (i.e.,
unit-volume prices by first calculating significantly greater than the baseline
with rate caps) and which are will incur some level of increased repair
the per-unit-volume price for each competitive or will become competitive
utility by dividing the total volumetric and maintenance costs because such
soon (i.e., without rate caps). In past equipment is more likely to incorporate
cost by the volume delivered, then AEOs, EIA assumed that prices in fully
calculating a State-level average price by technologies that are not widely
competitive regions would reflect spot available.
weighting each utility in a given State market prices and would be passed on
by the number of consumers it serves On this point, Whirlpool stated that,
to consumers immediately. EIA expects in general, more-efficient products use
(either residential or commercial), and
that the end of price reductions and more sophisticated components and
finally arriving at a regional average by
caps in many States will push controls, thereby increasing repair and
combining the State-level averages,
competitive regions closer to that maintenance costs. (Whirlpool, No. 10
weighting each by the population of that
representation of competition; however, at p. 10) Whirlpool also stated, in regard
State. This third step helps reduce any
EIA anticipates that most customers in to cooking products, that repair and
bias in the sample that may occur due
fully competitive regions will not maintenance costs for more-efficient
to relative under-sampling of large
experience price changes immediately products will be higher than these types
States.
For further details of the methodology in response to changes in market of costs for current baseline products.
that DOE used for deriving energy and generation costs. Consequently, for AEO For example, Whirlpool cited two
water prices, see Chapter 8 of the TSD. 2007, EIA built lags into the calculation design options—bi-radiant ovens and
In terms of trends, DOE used price 43 U.S. Department of Energy-Energy Information
electronic controls—as technologies that
forecasts by the EIA to estimate the Administration. Annual Energy Outlook 2007 with
would incur higher repair and
trends in natural gas, oil, and electricity Projections to 2030, February, 2007. Washington, maintenance costs. Whirlpool suggested
prices. The Joint Comment stated that DC. DOE/EIA–0383 (2007). that DOE should obtain data on repair
and maintenance costs during the machines. It suggested that the best household equity and debt to calculate
course of its data collection for the sources for CCW product lifetime data discount rates for residential products.45
engineering analysis (similar comment are the MLA and route operators. The SCF defines the shares of various
provided by AHAM). (Whirlpool, No. 10 (Public Meeting Transcript, No. 5 at p. equity and debt classes held by U.S.
at p. 10; Public Meeting Transcript, No. 206) households, thereby allowing DOE to
5 at pp. 199–200; AHAM, No. 14 at p. To estimate the lifetime for each properly weight the equity and debt
5) With respect to CCWs, ALS stated product covered by this rulemaking, holdings to derive residential discount
that repair and maintenance costs for DOE used only primary sources of data. rates. EEI commented that because
front-loading washers are much higher For example, the Federal government’s interest rates have been rising since
than for top-loading washers. (Public Energy Star Web site 44 provides lifetime 2003, making the cost of capital higher
Meeting Transcript, No. 5 at p. 201) estimates for dishwashers and for residential and commercial
DOE requested that manufacturers and dehumidifiers, but the estimates are consumers, DOE should take into
other stakeholders provide information actually based on data from Appliance account the most recent financial data
regarding appropriate repair and Magazine. Because, in this case, when developing discount rates. (EEI,
maintenance costs if stakeholders Appliance Magazine is the primary No. 7 at p. 4) As described below, DOE
believe such estimates are necessary. source of data, DOE did not use the used the most recent data available,
However, DOE did not receive any Energy Star Web site as a primary including data from the SCF to establish
input, and, therefore, did not include source to estimate product lifetimes. appropriate residential discount rates,
any changes in repair and maintenance DOE used a variety of sources to and data from Damodaran Online to
costs for products more efficient than establish the lifetime of each of the establish commercial discount rates.46
baseline products in this ANOPR. considered products, including New equipment is often purchased as
DOE specifically seeks feedback on its Appliance Magazine. Using the primary part of the purchase of a home, which
assumption that increases in product sources of data, DOE characterized is almost always financed with a
energy efficiency would not have a product lifetimes with uniform mortgage loan. DOE estimated discount
significant impact on the repair and probability distributions ranging from a rates for new-housing equipment using
maintenance costs for the four appliance minimum to a maximum value. the effective real (after-inflation)
products covered by this rulemaking. Microwave ovens were the exception, mortgage rate for homebuyers. This rate
This is identified as Issue 11 under since DOE used a triangular probability corresponds to the interest rate after
‘‘Issues on Which DOE Seeks Comment’’ distribution for these products instead. deduction of mortgage interest for
in section IV.E of this ANOPR. DOE determined the average product income tax purposes and after adjusting
With regard to appliance product lifetime by calculating the average value for inflation. The data sources DOE used
lifetimes, DOE received several from the applicable primary sources of for mortgage interest rates are the SCFs
comments on the appropriate sources data. To establish the minimum and in 1989, 1992, 1995, 1998, 2001, and
for establishing their length. For maximum product lifetime, DOE 2004. After adjusting for inflation and
dishwashers, ACEEE stated that some generally used the high and low values interest tax deduction, effective real
sources indicate that dishwasher from these sources for each of the four interest rates on mortgages across the six
lifetime is 14 years, while Whirlpool appliance products. See Chapter 8 of the surveys averaged 3.2 percent.
commented that Appliance Magazine’s TSD for more details. For residential replacement
estimate of nine years for dishwasher To establish discount rates for the equipment, DOE’s approach for deriving
lifetime is reasonable and the most residential products (i.e., dishwashers, discount rate involved identifying all
representative of actual consumer dehumidifiers, and cooking products), possible debt or asset classes that might
behavior. (Public Meeting Transcript, DOE derived estimates of the finance be used to purchase replacement
No. 5 at p. 206; Whirlpool, No. 10 at p cost of purchasing the considered equipment, including household assets
10) For dehumidifiers, the Joint products. Following financial theory, that might be affected indirectly. DOE
Comment estimated a product lifetime the finance cost of raising funds to did not include debt from primary
of 15 years based on discussions with purchase appliances can be interpreted mortgages and equity of assets
manufacturers and other sources. The as: (1) The financial cost of any debt considered non-liquid (such as
Joint Comment stated that Appliance incurred to purchase equipment, or (2) retirement accounts), since these would
Magazine generally provides shorter the opportunity cost of any equity used likely not be affected by replacement
lifetimes as compared to other sources. to purchase equipment. For the equipment purchases. DOE estimated
In contrast, Whirlpool commented that residential products, the purchase of the average shares of the various debt
Appliance Magazine’s estimate of eight equipment for new homes entails and equity classes in the average U.S.
years for dehumidifier lifetime is different finance costs for consumers household equity and debt portfolios
reasonable and the most consistent with than the purchase of replacement using SCF data for 1989, 1992, 1995,
actual consumer behavior. (Joint equipment. Thus, DOE used different 1998, 2001, and 2004. DOE used the
Comment, No. 9 at p. 5; Whirlpool, No. discount rates for new construction and mean share of each class across the six
10 at p 10) For cooking products, both replacement installations. NCLC sample years as a basis for estimating
AHAM and Whirlpool stated that the questioned how DOE would evaluate the effective financing rate for
best source for cooking product the cost of household equity and debt to replacement equipment. DOE estimated
lifetimes is Appliance Magazine, as they develop discount rates for residential
believe it provides estimated lifetimes products. (Public Meeting Transcript, 45 The Federal Reserve Board. 1989, 1992, 1995,
which are consistent with actual 1998, 2001, 2004 Survey of Consumer Finances,
No. 5 at p. 196) As described below,
1989, 1992, 1995, 1998, 2001, 2004. Available

consumer behavior. (AHAM, No. 14 at DOE used the Federal Reserve Board’s online at: http://www.federalreserve.gov/pubs/oss/
p. 5; Whirlpool, No. 10 at p. 10) Finally, Survey of Consumer Finances (SCF) for oss2/scfindex.html.
for CCWs, ALS stated that because the years 1989, 1992, 1995, 1998, 2001, 46 Damodaran Online is a widely used source of
CCWs are typically used more often information about company debt and equity
and 2004 as the basis for using financing for most types of firms, and was the
than residential clothes washers, CCW source of data for this analysis on educational
lifetime will be significantly shorter 44 Energy Star Web site: http:// services, hotels, and real estate investment trusts.
than the lifetime of residential www.energystar.gov/. See http://pages.stern.nyu.edu/adamodar/.
interest or return rates associated with respective shares of equity and debt c. Effective Date
each type of equity and debt using SCF financing for each of the sectors that The effective date is the future date
data and other sources. The mean real purchase CCWs. It calculated the real when a new standard becomes effective.
effective rate across all types of WACC by adjusting the cost of capital Based on DOE’s implementation report
household debt and equity, weighted by by the expected rate of inflation. To for energy conservation standards
the shares of each class, is 5.6 percent. obtain an average discount rate value, activities submitted under Section 141
For CCWs, DOE derived the discount DOE used additional data from the CEE of EPACT 2005, a final rule for the four
rate from the cost of capital of publicly- on the number of CCWs in use in appliance products being considered for
traded firms in the sectors that purchase various sectors. Weighting each sector this standards rulemaking is scheduled
CCWs. These companies typically by its market share, DOE estimated the for completion in March 2009. The
finance equipment purchases through
average discount rate for companies that effective date of any new energy
debt and equity capital. DOE estimated
purchase CCWs to be 5.7 percent, using efficiency standards for these products
the cost of capital of these firms as the
weighted average of the cost of equity an inflation rate of 2.5 percent (the will be three years after the final rule is
financing and the cost of debt financing. average of inflation rates over the 2001– published in the Federal Register (i.e.,
The costs of debt and equity financing 2005 time period). For further details on March 2012). DOE calculated the LCC
are usually obtainable from publicly DOE’s method for estimating discount for all consumers as if they each would
available data concerning the major rates, see Chapter 8 of the TSD. purchase a new piece of equipment in
types of companies in the sectors that One additional issue pertaining to the the year the standard takes effect.
purchase CCWs. Damodaran Online is a LCC operating cost inputs concerns the d. Equipment Assignment for the Base
widely used source of information about potential ‘‘split incentives’’ that exist in Case
company debt and equity financing for the CCW market. Several organizations For purposes of conducting the LCC
most types of firms, and it was the commented that under a split incentive analysis, DOE analyzed candidate
source of data for this analysis on situation, the party purchasing more- standard levels relative to a baseline
educational services, hotels, and real efficient and more-expensive equipment
estate investment trusts. Since efficiency level. However, some
may not realize the operating cost consumers already purchase products
Damodaran Online does not include savings from the more-efficient
data for firms in the personal services with efficiencies greater than the
equipment. For example, commenters baseline levels. Thus, to accurately
sector (Standard Industrial asserted that under new energy
Classification 7200), DOE used data estimate the percentage of consumers
efficiency standards, route operators that would be affected by a particular
from Ibbotson’s Associates 47 for this
would incur the burden of higher standard level, DOE took into account
sector.
DOE estimated the cost of equity purchase prices due to more-efficient the distribution of product efficiencies
using the capital asset pricing model equipment; property owners would currently in the marketplace. In other
(CAPM). The CAPM assumes that the realize the benefits of operating cost words, DOE conducted the analysis by
cost of equity for a particular company savings, and end-users may incur the taking into account the full breadth of
is proportional to the systematic risk burden of increased costs to use the product efficiencies that consumers
faced by that company, where high risk washers. (Public Meeting Transcript, already purchase under the base case
is associated with a high cost of equity No. 5 at p. 239; EEI, No. 7 at p. 4; MLA, (i.e., the case without new energy
and low risk is associated with a low No. 8 at p. 2; Whirlpool, No. 10 at p. 13; efficiency standards).
cost of equity. The systematic risk facing Multiple Water Organizations, No. 11 at DOE’s approach for conducting the
a firm is determined by several p. 2) In its LCC and PBP analyses, DOE LCC analysis for residential products
variables: (1) The risk coefficient of the did not explicitly consider the potential (i.e., dishwashers, dehumidifiers,
firm; (2) the expected return on risk-free of split incentives in the CCW market, cooking products) relied on developing
assets; and (3) the equity risk premium because it believes that the probability samples of households that use each of
(ERP). The risk coefficient of the firm of such a split incentive was very low. the products. DOE used a Monte Carlo
indicates the risk associated with that The actual consumers of this product simulation technique to perform the
firm relative to the price variability in (primarily property-owners of multi- LCC calculations on the households in
the stock market. The expected return the sample. Using the current
family buildings and laundromats)
on risk-free assets is defined by the distribution of product efficiencies, DOE
realize both the burden of increased
yield on long-term government bonds. assigned each household in the sample
purchase prices and the benefit of
The ERP represents the difference a specific product efficiency. Because it
reduced operating cost savings. Any
between the expected stock market performed the LCC calculations on a
split incentive that would occur for end- household-by-household basis, DOE
return and the risk-free rate.
The cost of debt financing is the users in the form of increased vending based the LCC for a particular standard
interest rate paid on money borrowed by prices is likely to be very low due to the level on the efficiency of the product in
a company. The cost of debt is estimated competitive nature of the market. For the given household. For example, if a
by adding a risk adjustment factor to the example, if end-users feel as though household was assigned a product
risk-free rate. This risk adjustment factor they are paying excessively high prices efficiency that is greater than or equal to
depends on the variability of stock to use a service, they will seek out the efficiency of the standard level
returns represented by standard cheaper options to obtain the service, under consideration, the LCC
deviations in stock prices. thereby forcing providers to adjust their calculation would reveal that this
DOE estimated the weighted-average prices in accordance with what is a household is not impacted by an
cost of capital (WACC) using the reasonable return on their investment. increase in product efficiency that is
Due to the checks and balances that equal to the standard level.
47 Ibbotson Associates is a leading authority on
occur in the marketplace, DOE believes For dishwashers, DOE characterized
asset allocation with expertise in capital market it is unnecessary to explicitly account
expectations and portfolio implementation. See
base case market shares based on data
Ibbotson’s Associates Statistics for SIC 72, available for the possible inequities to end-users that AHAM provided that show the
online at: http://www.ibbotson.com that may arise from a split incentive. distribution of standard-sized
dishwasher efficiencies sold in 2005. TABLE II.58.—STANDARD-SIZED DISH- class. Without any data provided by
Table II.58 presents the market shares of WASHERS: BASE CASE MARKET either AHAM or manufacturers or
the candidate standard levels in the base SHARES—Continued available from other sources, DOE
case for standard-sized dishwashers. assumed that the market shares for the
The market shares in Table II.58 combined 0–35.00 pints/day class were
Market
Candidate standard
represent the products that households level EF share
equivalent to the market shares for the
would have been anticipated to (percent)
closest product class—the 35.01–45.00
purchase in the year 2012 in the absence
5 ............................ 0.72 0.2 pint/day product class. For purposes of
of new standards. 6 ............................ 0.80 0.2 conducting the NIA, DOE estimated that
7 ............................ 1.11 0.2 the market share data for the 35.01–
TABLE II.58.—STANDARD-SIZED DISH- 45.00 pints/day and 54.01–74.99 pints/
* Intermediate efficiency level.
WASHERS: BASE CASE MARKET day classes could be used to
SHARES For dehumidifiers, DOE characterized characterize the base case market shares
base case market shares based on data
for the 45.01–54.00 pints/day and 75
Market that AHAM provided that show the
distribution of dehumidifier efficiencies pints/day and greater product classes,
Candidate standard EF share
level respectively. Table II.59 presents the
(percent) in 2005 for two of the six product
classes: 35.01–45.00 pints/day and market shares of the efficiency levels in
Baseline ................ 0.46 3.0 the base case for the three classes of
* ............................ 0.50 2.0
54.01–74.99 pints/day. Because DOE
* ............................ 0.54 2.0 conducted the engineering and LCC and dehumidifiers that DOE used to conduct
PBP analyses on the combined product the LCC analysis. The market shares in
1 ............................ 0.58 43.0
* ............................ 0.60 17.0 class of 0–35.00 pints/day product class Table II.59 represent the equipment that
2 ............................ 0.62 22.0 as well as these two classes, DOE had households would have been
3 ............................ 0.65 8.0 to estimate the market share data for the anticipated to purchase in the year 2012
4 ............................ 0.68 2.5 combined 0–35.00 pints/day product in the absence of new standards.
TABLE II.59.—DEHUMIDIFIERS: BASE CASE MARKET SHARES

0–35.00 pints/day 35.01–45.00 pints/day 54.01–74.99 pints/day
Market Market Market

Level EF share Level EF share Level EF share
(percent) (percent) (percent)
Baseline ................ 1.20 27 Baseline ................ 1.30 27 Baseline ................ 1.50 31

1 ............................ 1.25 35 1 ............................ 1.35 35 1 ............................ 1.55 0
2 ............................ 1.30 0 2 ............................ 1.40 0 2 ............................ 1.60 57
3 ............................ 1.35 0 3 ............................ 1.45 0 3 ............................ 1.65 12
4 ............................ 1.40 38 4 ............................ 1.50 38 4 ............................ 1.70 0
5 ............................ 1.45 0 5 ............................ 1.74 0 5 ............................ 1.80 0
Because DOE currently does not efficiency levels. For gas cooktops and presents the market shares of the
regulate cooking product efficiency with gas standard ovens, data are available, efficiency levels in the base case for gas
an energy efficiency descriptor, very both from DOE’s previous rulemaking cooktops and gas standard ovens. In the
little is known regarding the analysis and the Appliance Recycling table, candidate standard level 1
distribution of product efficiencies that Information Center, to indicate the represents products without standing
consumers in the United States historical percentage of products pilot light ignition systems. The market
currently purchase. Therefore, for all shipped with standing pilots. Therefore, shares in Table II.60 represent the
electric cooking products, including DOE was able to estimate the percentage equipment that households would have
microwave ovens, and gas self-cleaning of the gas cooktop and gas standard been anticipated to purchase in the year
ovens, DOE estimated that 100 percent oven market that is still sold with 2012 in the absence of new energy
of the market existed at the baseline standing pilot lights. Table II.60 conservation standards.
TABLE II.60.—GAS COOKTOPS AND GAS STANDARD OVENS: BASE CASE MARKET SHARES
Gas cooktops Gas standard ovens
Market share Market share

Candidate standard level EF Candidate standard level EF
(percent) (percent)
Baseline ............................................ 0.156 6.8 Baseline ............................................ 0.0298 17.6

1 ........................................................ 0.399 93.2 1* ...................................................... 0.0536 82.4
2 ........................................................ 0.420 0 2 ........................................................ 0.0566 0
3 ........................................................ 0.0572 0
4 ........................................................ 0.0593 0
5 ........................................................ 0.0596 0
6 ........................................................ 0.0600 0
TABLE II.60.—GAS COOKTOPS AND GAS STANDARD OVENS: BASE CASE MARKET SHARES—Continued
Gas cooktops Gas standard ovens
Market share Market share

Candidate standard level EF Candidate standard level EF
(percent) (percent)
1a* .................................................... 0.0583 0

* Forgas standard ovens, candidate standard levels 1 and 1a correspond to designs that are utilized for the same purpose—eliminate the need
for a standing pilot—but the technologies for each design are different. Candidate standard level 1 is a hot surface ignition device while can-
didate standard level 1a is a spark ignition device. Candidate standard level 1a is presented at the end of the table because candidate standard
levels 2 through 6 are derived from candidate standard level 1.
For CCWs, DOE was unable to simulation, it evaluated each standard levels in the base case for standard-sized
develop a consumer sample. However, it level analyzed against the distribution dishwashers. The market shares in
took into account the base case mix of of product efficiencies in the base case. Table II.61 represent the products that
CCW efficiencies by characterizing the DOE derived its base case market households would have been
current mix of product efficiencies as a share data for CCWs based on shipment- anticipated to purchase in the year 2012
probability distribution. In other words, weighted efficiency data that AHAM in the absence of new energy
as DOE performed the Monte Carlo provided. Table II.61 presents the conservation standards.
market shares of the candidate standard
TABLE II.61.—COMMERCIAL CLOTHES WASHERS: BASE CASE MARKET SHARES

Market share
Level MEF WF (percent)
Baseline ....................................................................................................................................... 1.26 9.50 79.7

1 ................................................................................................................................................... 1.42 9.50 0.0
2 ................................................................................................................................................... 1.60 8.50 0.0
3 ................................................................................................................................................... 1.72 8.00 0.0
4 ................................................................................................................................................... 1.80 7.50 0.0
5 ................................................................................................................................................... 2.00 5.50 20.3
6 ................................................................................................................................................... 2.20 5.10 0.0
For more details on how DOE equipment to the customer for each impacts, and PBPs with their
developed the base case product efficiency level and the annual (first- corresponding probability of occurrence
efficiency distributions for the four year) operating expenditures for each are presented in Chapter 8 of the TSD.
appliance products in the LCC analysis, efficiency level. The PBP calculation Table II.62 shows the LCC and PBP
refer to Chapter 8 of the TSD. uses the same inputs as the LCC
DOE specifically seeks feedback on its results for standard-sized dishwashers.
analysis, except that energy (and water)
methodology and data sources for For example, candidate standard level 3
price trends and discount rates are not
developing the base case product needed. The calculation needs energy (0.65 EF) shows an average LCC savings
efficiency distributions for the four prices only for the year in which a new of $17. Note that for standard level 3,
appliance products. This is identified as standard is expected to take effect, in 10.6 percent of the housing units in
Issue 12 under ‘‘Issues on Which DOE this case the year 2012. 2012 are shown to have already
Seeks Comment’’ in section IV.E of this purchased a dishwasher at standard
ANOPR. 4. Life-Cycle Cost and Payback Period level 3 in the base case and, thus, have
Results zero savings due to the standard. If one
3. Payback Period Inputs DOE calculated the LCC and PBP compares the LCC of the baseline at 0.46
As described above, the PBP is the results relative to the base case forecast EF ($1124) to the standards case at 0.65
amount of time it takes the consumer to for each product class. As mentioned EF ($1025), then the difference in the
recover the additional installed cost of above, the base case consists of the LCCs is $99. However, since the base
more-efficient equipment through projected pattern of equipment case includes a significant number of
energy (and water) cost savings, as purchases that would occur in the households that are not impacted by the
compared to baseline equipment. absence of new efficiency standards. standard, the average savings over all of
Simple payback period does not take The following tables (Table II.62
the households is actually $17, not $99.
into account changes in operating through Table II.75) present the findings
expense over time or the time value of from the LCC and PBP analyses DOE With regard to the PBPs shown below,
money. Payback periods are expressed performed for this ANOPR. DOE DOE determined the median and
in years. Payback periods greater than determined the values at each candidate average values by excluding the
the life of the product mean that the standard level by excluding the percentage of households not impacted
increased total installed cost is not percentage of households not impacted by the standard. For example, in the
recovered in reduced operating by the standard (i.e., those who, in base case of standard level 3, 10.6 percent of
expenses. case, already purchase a unit at or above the households did not factor into the
The inputs to the calculation of the the given efficiency level). Figures calculation of the median and average
PBP are the total installed cost of the showing the distribution of LCCs, LCC PBP.
TABLE II.62.—STANDARD-SIZED DISHWASHERS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS

Life-cycle cost Life-cycle cost savings Payback period
Can- (years)
didate Households with
EF Average Average
standard Average Average
installed operating
level LCC savings Net cost No impact Net benefit Median Average
price cost (percent) (percent) (percent)
Baseline 0.46 $700 $424 $1,124

1 ........... 0.58 706 339 1,045 $4 0.1 92.8 7.1 0.9 1.5
2 ........... 0.62 712 318 1,029 13 11.3 32.8 56.0 2.8 5.1
3 ........... 0.65 722 303 1,025 17 32.6 10.6 56.8 5.9 10.9
4 ........... 0.68 747 291 1,038 5 58.6 3.1 38.4 11.9 22.2
5 ........... 0.72 811 275 1,086 ¥43 82.9 0.6 16.5 22.5 42.3
6 ........... 0.80 900 249 1,149 ¥106 90.1 0.4 9.5 28.3 51.5
7 ........... 1.11 980 183 1,162 ¥119 83.3 0.3 16.4 21.9 39.3
Tables II.63, II.64, and II.65 show the thus, have zero savings due to the regard to the PBPs shown below, DOE
LCC and PBP results for dehumidifiers. standard. If one compares the LCC of the determined the median and average
For example, in the case of the 35.01– base case at 1.30 EF ($676) to the values by excluding the percentage of
45.00 pints/day class, candidate standards case at 1.45 EF ($657), then households not impacted by the
standard level 3 (1.45 EF) shows an the difference in the LCCs is $19. standard. For example, in the case of
average LCC savings of $8. Note that for However, since the base case includes a standard level 3 for the 35.01–45.00
standard level 3, 38.2 percent of the significant number of households that pints/day class, 38.2 percent of the
housing units in 2012 are shown to have are not impacted by the standard, the households did not factor into the
already purchased a dehumidifier at average savings over all of the calculation of the median and average
standard level 3 in the base case and, households is actually $8, not $19. With PBP.
TABLE II.63.—DEHUMIDIFIERS, 0–35.00 PINTS/DAY: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Life-cycle cost * Life-cycle cost savings * Payback period
Can- (years) *
didate Efficiency Households with
Average Average
standard liters/kWh Average Average
installed operating
Baseline 1.20 $137 $422 $558 .................. .................. .................. .................. .................. ..................
1 ........... 1.25 142 405 546 $3 0.0 73.1 26.9 2.6 2.5
2 ........... 1.30 142 389 533 11 0.0 38.4 61.6 1.7 1.8
3 ........... 1.35 153 375 528 15 0.2 38.4 61.4 3.2 3.1
4 ........... 1.40 166 361 527 15 5.5 38.4 56.2 4.6 4.5
5 ........... 1.45 176 349 525 17 25.9 0.0 74.1 5.7 5.9
* LCC, LCC savings, and PBP based on the annual energy consumption and operating cost associated with the 25.01–35.00 pints/day product
class.
TABLE II.64.—DEHUMIDIFIERS, 35.01–45.00 PINTS/DAY: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Can- (years)
Average Average
installed operating
Baseline 1.30 $157 $519 $676 .................. .................. .................. .................. .................. ..................
1 ........... 1.35 167 500 666 $3 1.5 73.1 25.5 4.4 4.2
2 ........... 1.40 167 482 661 6 15.2 38.2 46.6 5.9 5.8
3 ........... 1.45 192 465 657 8 17.5 38.2 44.3 6.2 6.1
4 ........... 1.50 208 450 658 8 22.7 38.2 39.1 7.0 6.8
5 ........... 1.74 272 388 660 5 54.1 0.0 45.9 8.5 8.3
TABLE II.65.—DEHUMIDIFIERS, 54.01–74.99 PINTS/DAY: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS

Can- (years)
Average Average
installed operating
Baseline 1.50 $189 $725 $914 .................. .................. .................. .................. .................. ..................
TABLE II.65.—DEHUMIDIFIERS, 54.01–74.99 PINTS/DAY: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS—Continued
Can- (years)
Average Average
installed operating
1 ........... 1.55 195 702 897 $5 0.0 68.5 31.5 2.5 2.4
2 ........... 1.60 195 680 881 10 0.0 68.5 31.5 2.4 2.4
3 ........... 1.65 208 659 867 22 0.0 12.3 87.7 2.8 2.7
4 ........... 1.70 224 640 864 25 14.1 0.0 85.9 4.8 4.9
5 ........... 1.80 241 604 845 44 7.8 0.0 92.2 4.4 4.4
Tables II.66, II.67, and II.68 show the base case and, thus, have zero savings With regard to the PBPs shown below,
LCC and PBP results for cooktops. For due to the standard. If one compares the DOE determined the median and
example, in the case of gas cooktops, LCC of the baseline at 0.106 EF ($716) average values by excluding the
candidate standard level 1 (pilotless to the standards case at 0.399 EF ($435), percentage of households not impacted
ignition with an efficiency of 0.399 EF) then the difference in the LCCs is $281. by the standard. For example, in the
shows an average LCC savings of $19. However, since the base case includes a case of standard level 1 for gas cooktops,
Note that for standard level 1, 93.4 significant number of households that 93.4 percent of the households did not
percent of the housing units in 2012 are are not impacted by the standard, the factor into the calculation of the median
shown to have already purchased a gas average savings over all of the and average PBP.
cooktop with pilotless ignition in the households is actually $19, not $281.
TABLE II.66.—ELECTRIC COIL COOKTOPS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Can- (years)
didate EF Average Average Households with
installed operating
level LCC savings Median Average
price cost Net cost No impact Net benefit
Baseline 0.737 $251 $150 $401 .................. .................. .................. .................. .................. ..................
1 ........... 0.769 255 144 399 $3 35.0% 0.0% 65.0% 8.1 18.6
TABLE II.67.—ELECTRIC SMOOTH COOKTOPS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Can- (years)
didate EF Average Average Households with
installed operating
level LCC savings Median Average
price cost Net cost No impact Net benefit
Baseline 0.742 $288 $150 $438 .................. .................. .................. .................. .................. ..................
1 ........... 0.753 528 148 676 ¥$238 100.0% 0.0% 0.0% 1,685.2 4,266.3
TABLE II.68.—GAS COOKTOPS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS

Can- (years)
EF Average Average
installed operating
Baseline 0.106 $289 $428 $716 .................. .................. .................. .................. .................. ..................
1 ........... 0.399 322 113 435 $19 0.0 93.4 6.7 1.3 1.4
2 ........... 0.420 351 107 458 ¥5 93.2 0.0 6.8 75.3 195.1
Tables II.69 through II.72 show the standard oven with pilotless ignition in the standard, the average savings over
LCC and PBP results for ovens. For the base case and, thus, have zero all of the households is actually $16, not
example, in the case of gas standard savings due to the standard. If one $94. With regard to the PBPs shown
ovens, candidate standard level 1 compares the LCC of the base case at below, DOE determined the median and
(pilotless ignition with an efficiency of 0.030 EF ($697) to the standards case at average values by excluding the
0.058 EF) shows an average LCC savings 0.058 EF ($603), then the difference in percentage of households not impacted
of $16. Note that for standard level 1, 83 the LCCs is $94. However, since the by the standard. For example, in the
percent of the housing units in 2012 are base case includes a significant number case of standard level 1 for gas standard
shown to have already purchased a gas of households that are not impacted by ovens, 83 percent of the households did
not factor into the calculation of the are due to outliers in the distribution of excessively long PBPs produce an
median and average PBP. Also of note results. The Monte Carlo simulation for average PBP that is very long. Therefore,
regarding PBPs, the large difference in electric self-cleaning ovens and in these cases, the median PBP is a more
the average and median values for standard level 5 for gas ovens yielded a representative value to gauge the length
electric self-cleaning ovens and few results with PBPs in excess of one of the PBP.
standard level 5 for gas standard ovens million years. A limited number of
TABLE II.69.—ELECTRIC STANDARD OVENS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Can- (years)
EF Average Average
installed operating
Baseline 0.1066 $392 $189 $581 .................. .................. .................. .................. .................. ..................
1 ........... 0.1113 395 182 576 $5 38.3 0.0 61.8 6.0 45.6
2 ........... 0.1163 399 175 574 7 46.5 0.0 53.5 9.1 68.7
3 ........... 0.1181 405 172 577 4 54.5 0.0 45.5 13.8 103.9
4 ........... 0.1206 462 169 631 ¥50 96.4 0.0 3.6 65.5 493.6
5 ........... 0.1209 467 169 636 ¥55 97.1 0.0 2.9 68.7 517.9
TABLE II.70.—ELECTRIC SELF-CLEANING OVENS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Can- (years)
EF Average Average
installed operating
level LCC savings Net cost No impact No benefit Median Average
Baseline 0.1099 $463 $200 $663 .................. .................. .................. .................. .................. ..................
1 ........... 0.1102 469 199 669 ¥$88 74.6 0.0 25.4 196.7 1,071.7
2 ........... 0.1123 527 196 723 ¥142 81.9 0.0 18.1 266.7 1,453.0
TABLE II.71.—GAS STANDARD OVENS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Can- (years)
EF Average Average
installed operating
Baseline 0.0298 $409 $288 $697 .................. .................. .................. .................. .................. ..................
1* .......... 0.0536 442 162 603 $16 0.0 83.0 17.0 3.3 3.4
2 ........... 0.0566 447 154 601 18 46.1 0.0 53.9 8.4 136.1
3 ........... 0.0572 448 153 601 18 47.9 0.0 52.1 9.4 152.3
4 ........... 0.0593 481 149 630 ¥11 77.4 0.0 22.6 27.2 460.1
5 ........... 0.0596 483 148 632 ¥12 77.9 0.0 22.1 27.9 1,907.4
6 ........... 0.0600 488 148 636 ¥17 79.5 0.0 20.5 30.1 426.3
1a* ........ 0.0583 446 134 580 39 0.0 0.0 100.0 2.2 2.2
*Candidate standard levels 1 and 1a correspond to designs that are utilized for the same purpose—eliminate the need for a standing pilot—but
the technologies for each design are different. Candidate standard level 1 is a hot surface ignition device while candidate standard level 1a is a
spark ignition device. Candidate standard level 1a is presented at the end of the table because candidate standard levels 2 through 6 are de-
rived from candidate standard level 1.
TABLE II.72.—GAS SELF-CLEANING OVENS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Can- (years)
EF Average Average
installed operating
Baseline 0.0540 $529 $200 $729 .................. .................. .................. .................. .................. ..................
1 ........... 0.0625 545 183 727 $1 58.3 0.0 41.7 11.8 158.0
2 ........... 0.0627 551 182 733 ¥5 67.3 0.0 32.7 16.1 235.3
3 ........... 0.0632 553 182 734 ¥6 68.4 0.0 31.6 16.7 149.0
Table II.73 shows the LCC and PBP (0.602 EF) shows an average LCC cost PBPs for standard level 4 are 132.2 and
results for microwave ovens. For increase of $68. The median and average 327.5 years, respectively.
example, candidate standard level 4
TABLE II.73.—MICROWAVE OVENS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS

Can- (years)
EF Average Average
installed operating
Baseline 0.557 $219 $89 $308 .................. .................. .................. .................. .................. ..................
1 ........... 0.586 232 84 316 ¥8 93.0 0.0 7.0 33.9 84.0
2 ........... 0.588 246 84 329 ¥21 98.6 0.0 1.4 65.8 163.1
3 ........... 0.597 267 83 349 ¥41 99.6 0.0 0.4 93.9 232.5
4 ........... 0.602 294 82 376 ¥68 99.9 0.0 0.1 132.2 327.5
Tables II.74 and II.75 show the LCC thus, have zero savings due to the $509. With regard to the PBPs shown
and PBP results for both product standard. If one compares the LCC of the below, DOE determined the median and
applications of CCWs. For example, in base case at 1.26 MEF/9.50 WF ($3303) average values by excluding the
the case of the multi-family application, to the standards case at 2.00 MEF/5.50 percentage of households not impacted
candidate standard level 5 (2.00 MEF/ WF ($2794), then the difference in the by the standard. For example, in the
5.50 WF) shows an average LCC savings LCCs is $509. However, since the base case of standard level 5, 20.9 percent of
of $404. Note that for standard level 5, case includes a significant number of the consumers did not factor into the
20.9 percent of consumers in 2012 are consumers that are not impacted by the calculation of the median and average
assumed to already be using a CCW in standard, the average savings over all of PBP.
the base case at standard level 5 and, the consumers is actually $404, not
TABLE II.74.—COMMERCIAL CLOTHES WASHERS, MULTI-FAMILY APPLICATION: LIFE-CYCLE COST AND PAYBACK PERIOD
RESULTS
(years)
Candidate standard Households with
MEF/WF Average Average
level Average Average
installed operating LCC savings Net cost No impact Net benefit Median Average
Baseline ...................... 1.26/9.50 $722 $2,581 $3,303 .............. .................. .................. .................. .............. ..............
1 ................................. 1.42/9.50 840 2,454 3,294 7 42.0 20.9 37.1 8.4 8.9
2 ................................. 1.60/8.50 1,224 2,189 3,413 ¥86 61.5 20.9 17.6 11.9 12.8
3 ................................. 1.72/8.00 1,224 2,053 3,277 21 43.3 20.9 35.9 8.8 9.5
4 ................................. 1.80/7.50 1,224 1,943 3,167 109 30.4 20.9 48.8 7.3 7.9
5 ................................. 2.00/5.50 1,224 1,571 2,794 404 9.3 20.9 69.9 4.6 5.1
6 ................................. 2.20/5.10 1,224 1,446 2,670 529 6.3 0.0 93.7 3.8 3.6
TABLE II.75.—COMMERCIAL CLOTHES WASHERS, LAUNDROMAT APPLICATION: LIFE-CYCLE COST AND PAYBACK PERIOD
RESULTS
(years)
Candidate standard Households with
MEF/WF Average Average
level Average Average
installed operating LCC savings Net cost No impact Net benefit Median Average
Baseline ...................... 1.26/9.50 $722 $2,772 $3,494 .............. .................. .................. .................. .............. ..............
1 ................................. 1.42/9.50 840 2,647 3,487 5 35.9 20.9 43.2 5.3 5.6
2 ................................. 1.60/8.50 1,224 2,354 3,577 ¥66 61.5 20.9 17.7 6.9 7.3
3 ................................. 1.72/8.00 1,224 2,207 3,431 50 29.2 20.9 50.0 5.1 5.4
4 ................................. 1.80/7.50 1,224 2,085 3,308 147 13.6 20.9 65.5 4.3 4.5
5 ................................. 2.00/5.50 1,224 1,661 2,885 482 0.7 20.9 78.5 2.7 2.8
6 ................................. 2.20/5.10 1,224 1,532 2,755 612 0.2 0.0 99.8 2.2 2.0
DOE presents these findings to results for these analyses. See Chapter 8 H. Shipments Analysis
facilitate stakeholder review of the LCC of the TSD for additional detail on the
and PBP analyses. DOE seeks LCC and PBP analyses. This section presents DOE’s
information and comments relevant to shipments analysis, which is an input
the assumptions, methodology, and into the NIA (section II.I). DOE will also
use shipments estimates as input to the households acquiring the equipment for 1998) using commercial laundry
MIA, which is discussed in section II.K. the first time); and CCWs (retired units quantity index data from the U.S.
DOE will undertake the MIA after the not replaced). Census Bureau.48 For purposes of
ANOPR is published, and will report With regard to the market of existing calibrating its Shipments Model, DOE
the MIA findings in the NOPR. households purchasing dehumidifiers, attributed this drop to non-replacements
As indicated above and in the Whirlpool commented that shipments to (i.e., a portion of CCWs that were retired
discussion below of the NIA, for each existing households that do not already from service over the period 1999–2005
product, DOE has developed a base case own a dehumidifier are likely very low were not replaced). Because DOE tied its
forecast to depict what would happen to for two reasons. First, Whirlpool stated CCW shipments estimates to forecasts of
energy and water use, and to consumer that historical data indicate that annual new multi-family construction as
costs for purchase and operation of the dehumidifier shipments have been provided by EIA’s AEO 2007, and
product, if DOE does not adopt new relatively constant, and second, the because AEO 2007 forecasts modest
energy conservation standards. To most significant new housing growth growth in multi-family construction
evaluate the impacts of such new has been in the Southern and Western starts, DOE’s Shipments Model
standards, DOE compares these base regions of the U.S. where central air projected that shipments would recover
case forecasts to forecasts of what would conditioning (as opposed to and gradually increase after the drop
happen if DOE adopts new standards at dehumidifiers) is used to condition the witnessed over the 1999–2005 period.
various higher efficiency levels. One space. (Whirlpool, No. 10 at p. 12) Due to the dramatic drop in
element of both types of forecasts is Contrary to Whirlpool’s claim, based on shipments seen in the historical data,
product shipments. In determining the historical data, DOE found that DOE specifically seeks feedback on its
base case, DOE considered historical shipments have more than doubled assumptions regarding the shipments
shipments, the mix of efficiencies sold since 1990, with an increase of nearly forecasts for CCWs. This is identified as
in the absence of standards, and how 50 percent over the 2003–2005 time Issue 13 under ‘‘Issues on Which DOE
that mix might change over time. period. In allocating shipments to Seeks Comment’’ in section IV.E of this
existing households with a ANOPR.
1. Shipments Model
dehumidifier, DOE used the historical In principle, each market segment and
DOE estimated shipments for each of data to estimate which portion of the each product class responds differently
the four appliance products using a shipments went to these existing to both the base case demographic and
separate Shipments Model. households. DOE first determined that economic trends and to the
Furthermore, in the case of cooking portion of the shipments that served as implementation of standards.
products, DOE developed two separate replacements and then allocated the Furthermore, retirements, early
Shipments Models—one for cooktops remaining portion to existing replacements, and efficiency trends are
and ovens and another for microwave households without a dehumidifier. As dynamic and can vary among product
ovens. Therefore, DOE developed a total a result of this calculation, DOE classes. Rather than simply
of five separate Shipments Models (i.e., estimated that 0.6 percent of existing extrapolating a current shipments trend,
two for cooking products and one each households without a dehumidifier the base case shipments analysis uses
for dishwashers, dehumidifiers, and would annually purchase this product driver input variables, such as
CCWs). Each Shipments Model was over the period 2005–2042. construction forecasts and product
calibrated against historical shipments. With regard to the estimation of lifetime distributions, to forecast sales
For purposes of estimating the impacts forecasted commercial clothes washer in each market segment.
of prospective candidate standard levels shipments, ALS stated that the market DOE’s Shipments Models take an
on product shipments, each Shipments for CCWs is already saturated and may accounting approach, by tracking
Model accounts for the combined effects decline in the future. ALS believes that market shares of each product class, the
of changes in purchase price, annual the trend in multi-housing is to install vintage of units in the existing stock,
operating cost, and household income in-apartment washers rather than and expected construction trends. The
on the consumer purchase decision. provide common area commercial
In overview, each Shipments Model Models estimate shipments due to
laundry. Both ALS and MLA stated that replacements using sales in previous
considers specific market segments, the approximately 200,000 to 230,000
results for which are then aggregated to years and assumptions about the life of
commercial washers are shipped per the equipment. Therefore, estimated
estimate total product shipments. In the year. Whirlpool stated that a saturation-
case of all of the four appliance sales due to replacements in a given
based Shipments Model could be year are equal to the total stock of the
products (with the exception of developed to forecast shipments.
dehumidifiers), DOE accounted for at appliance minus the sum of the
However, because historical industry
least two market segments: (1) New appliances sold in previous years that
shipments have been constant,
construction and (2) existing buildings still remain in the stock. DOE must
Whirlpool suggested that DOE either
(i.e., replacing failed equipment). For determine the useful service life of the
hold future product saturations constant
dehumidifiers, DOE did not consider appliance to determine how long the
or allow them to decline. (Public
the new construction market since this appliance is likely to remain in stock.
Meeting Transcript, No. 5 at pp. 213 and
product, unlike most major household 219; MLA, No. 8 at p. 1; Whirlpool, No. 2. Data Inputs
appliances, is not standard equipment 10 at p. 12) As discussed above, shipments are
for new households. Instead, in addition DOE confirmed that over the period of driven primarily by two market
to accounting for replacements, DOE 1988–1998, annual shipments of clothes
accounted for the market of existing washers stayed roughly in the range 48 U.S. Department of Commerce-Bureau of
households acquiring new between 200,000 to 230,000 units per Economic Analysis. Industry Economic Accounts,
dehumidifiers for the first time. year. But based on data provided by Gross-Domestic-Product-(GDP)-by-Industry-Data,
Furthermore, for the following products, AHAM, shipments dropped to 1998– NAICS data: GDPbyInd_SHIP_NAICS and
SIC Data: GDPhyind_SHIP_SIC, Commercial
DOE accounted for a third market approximately 180,000 units for the year Laundry Quantity Index Data, NAICS code 333312.
segment: Cooking products (early 2005. DOE confirmed this shipments Washington, DC. Available online at: http://
replacements); dishwashers (existing drop (from a peak of 265,000 units in preview.bea.gov/industry/gdpbyind_data.htm.
segments: (1) New construction and (2) the overall dehumidifier market against historical shipments. In its
replacements. saturation. (Public Meeting Transcript, calibrations, which entailed estimating
New housing forecasts and market No. 5 at p. 220) In response, we note which portion of shipments are
saturation data comprised the two that DOE’s Shipments Model for replacements, DOE used the product
primary inputs for DOE’s estimates of dehumidifiers takes into consideration lifetimes that it established for the LCC
new construction shipments. ‘‘New saturation data pertaining only to analysis (refer to section II.G.2.b for
housing’’ includes newly-constructed dehumidifiers manufactured as more details). DOE found that the
single-family and multi-family units independent units. Although growth in product lifetimes provided reasonable
(referred to as ‘‘new housing central space-conditioning systems with estimates of overall shipments for each
completions’’) and mobile home fully-integrated dehumidifying of the products.
placements. As noted above for CCWs, equipment may have an impact on
3. Shipments Forecasts
DOE’s Shipments Model used only forecasted dehumidifier shipments,
newly-constructed multi-family units, DOE was unable to obtain any data that Table II.76 shows the results of the
as DOE estimated shipments are driven indicate the growth of these systems and shipments analysis for the base case for
solely by multi-family construction their impact on the overall dehumidifier each of the products. Of the products
starts. For new housing completions and market. listed in Table II.76, dehumidifiers, gas
mobile home placements, DOE used In general, DOE estimated cooktops and ovens, and electric
actual data through 2005, and adopted replacements using product retirement cooktops and ovens are comprised of
the projections from EIA’s AEO 2007 for functions that it developed from several product classes. Specifically,
the period of 2006–2030.49 To product lifetimes. For all of the four dehumidifiers consist of six product
determine new construction shipments appliance products (with the exception classes; gas cooktops and ovens consist
for each of the four appliance products of microwave ovens), DOE based the of three classes, and electric cooktops
(except dehumidifiers), DOE used retirement function on a uniform and ovens consist of four classes. For
forecasts of housing starts coupled with probability distribution for the product each of these products (with each
the product market saturation data for lifetime. The Shipments Models assume product consisting of more than one
new housing. DOE used the 2001 RECS that no units are retired below a product class, except CCW) DOE’s
to establish dishwasher and cooktop minimum product lifetime and that all analysis estimated the aggregate
market saturations for new housing. For units are retired before exceeding a shipments. Once it had established the
commercial clothes washers, DOE relied maximum product lifetime. NWPCC aggregate shipments estimate, DOE then
on the new construction market noted that DOE should calibrate the allocated the shipments to each product
saturation data from CEE.50 Shipments Models to historical class based on historical market share
In the specific case of dehumidifiers, shipments data to ensure that the data. Chapter 9 of the TSD provides
EEI stated that DOE should account for estimates of product lifetimes are details on the product class market
the market saturation of dehumidifying reasonable. (Public Meeting Transcript, shares for dehumidifiers, gas cooktops
equipment integrated into central space- No. 5 at p. 215) As noted previously, and ovens, and electric cooktops and
conditioning systems when evaluating DOE calibrated each Shipments Model ovens.
TABLE II.76.—FORECASTED SHIPMENTS FOR HOME APPLIANCES, 2012–2042, BASE CASE (MILLION UNITS)
Product 2012 2015 2020 2025 2030 2035 2040 2042 Cumulative
Dishwashers ............................................. 8.12 8.73 9.62 10.36 11.17 11.76 12.28 12.48 328
Dehumidifiers ........................................... 1.82 1.99 2.39 2.65 2.98 3.30 3.59 3.71 86
Gas cooktops and ovens ......................... 3.80 3.82 4.05 4.26 4.43 4.57 4.75 4.82 133
Electric cooktops and ovens .................... 6.24 6.41 7.03 7.52 7.88 8.26 8.72 8.91 235
Microwave ovens ..................................... 16.11 15.41 17.54 17.67 19.61 20.01 21.50 21.53 578
Commercial clothes washers ................... 0.24 0.24 0.27 0.29 0.32 0.34 0.37 0.38 9.4
To estimate the combined effects on DOE summarized from the literature shipments and a decline in appliance
product shipments from increases in suggests that the demand for appliances purchase price and operating costs over
equipment purchase price and decreases is price inelastic. the time period. Household income has
in equipment operating costs due to DOE did not find enough equipment also risen during this time. DOE
new efficiency standards, DOE purchase price and operating cost data combined the available economic
conducted a literature review and a to perform a complex analysis of information into one variable, termed
statistical analysis on a limited set of dynamic changes in the appliance the ‘‘relative price,’’ which is the sum of
appliance price, efficiency, and market. Rather, DOE used purchase the purchase price and the present value
shipments data. price and efficiency data specific to of operating cost savings divided by
In the literature, DOE found only a residential refrigerators, clothes household income, and used this
few studies of appliance markets that washers, and dishwashers over the variable to conduct a regression
are relevant to this rulemaking analysis, period 1980–2002 to evaluate broad analysis. DOE’s regression analysis
suggested that the relative price
and identified no studies that use time- market trends and to conduct simple
series of equipment price and shipments regression analyses. These data indicate elasticity of demand, averaged over the
data after 1980. The information that that there has been a rise in appliance three appliances, is ¥0.34. For example,
49 49 U.S. Department of Energy-Energy Available online at: http://www.eia.doe.gov/oiaf/ the Consortium for Energy Efficiency, 1998. Boston,
Information Administration. Annual Energy aeo/index.html MA. Available online at: http://www.cee1.org/com/
Outlook 2007 with Projections to 2030, February, 50 Consortium for Energy Efficiency. Commercial
cwsh/cwsh-main.php3.
2007. Washington, DC. DOE/EIA–0383 (2007). Family-Sized Washers: An Initiative Description of
for a relative price increase of 10 PG&E commented that consumers will the estimate of shipments and the
percent, shipments decrease by 3.4 replace failed equipment regardless of quantity of units in service that DOE
percent. Note that because the relative the increased purchase price due to derived from the Shipments Model.
price elasticity incorporates the impacts efficiency standards. (Public Meeting With regard to the estimation of NES,
from three effects (i.e., purchase price, Transcript, No. 5 at p. 224) In its because more-efficient units of a
operating cost, and household income), regression analysis of appliance product gradually replace less efficient
the impact from any single effect is purchase price, efficiency, and ones, the per-unit energy consumption
mitigated by changes from the other two shipments data, DOE did not attempt to of the products in service gradually
effects. The relative price elasticity of quantify the shipments impacts to decreases in the standards case relative
¥0.34 is consistent with estimates in separate markets (i.e., new construction to the base case. To estimate the
the literature. Nevertheless, DOE and replacements). Because DOE’s resulting total energy savings for each
stresses that the measure is based on a regression analysis focused on the candidate efficiency level, DOE first
small data set, using simple statistical impacts to aggregate shipments, it calculated the national site-energy
analysis. More important, the measure is applied the sensitivity to purchase consumption for each of the four
based on the premise that economic price, operating cost, and household appliance products for each year,
variables (including purchase price, income equally to all markets. DOE beginning with the expected effective
operating costs, and household income) believes this level of precision is date of the standards (2012), for the base
explain most of the trend in appliances sufficient for capturing the effect that case forecast and each standards case
per household in the U.S. since 1980. these three factors have on overall forecast. (Site energy is the energy
Changes in appliance quality and product shipments. directly consumed by the units of the
consumer preferences may have Additional detail on the shipments product in operation.) Second, DOE
occurred during this period, but DOE analysis can be found in Chapter 9 of determined the annual site-energy
did not account for them in this the TSD. savings, consisting of the difference in
analysis. Despite these uncertainties, site-energy consumption between the
I. National Impact Analysis
DOE believes that its estimate of the base case and the standards case. Third,
The NIA assesses cumulative NES and DOE converted the annual site-energy
relative price elasticity of demand
the cumulative national economic savings into the annual amount of
provides a reasonable assessment of the
impacts of candidate standards levels. energy saved at the source of electricity
impact that purchase price, operating
The analysis measures economic generation or of natural gas production
cost, and household income have on
impacts using the NPV metric, which (the source energy) using site-to-source
product shipments.
represents the net present value (i.e., conversion factors. Finally, DOE
Because DOE’s forecasts of shipments future amounts discounted to the summed the annual source-energy
and national impacts due to standards is present) of total customer costs and savings from 2012 to 2042 to calculate
over a 30-year time period, savings expected to result from new the total NES for that period. DOE
consideration must be given as to how standards at specific efficiency levels. performed these calculations for each
the relative price elasticity is affected For a given candidate standard level, candidate standard level.
once a new standard takes effect. DOE DOE calculated both the NPV and the To estimate NPV, DOE calculated the
considers the relative price elasticity of NES as the difference between a base net impact each year as the difference
¥0.34 to be a short-run value. DOE was case forecast and the standards case. A between total operating cost savings
unable to identify sources specific to summary of this analysis is provided (including gas and/or electricity and
household durable goods, such as below, but additional detail on the NIA water, repair, and maintenance cost
appliances, to indicate how short-run for the four appliance products may be savings) and increases in total installed
and long-run price elasticities differ. found in Chapter 10 of the TSD. costs (which consist of the incremental
Therefore, to estimate how the relative DOE determined national annual increase in manufacturer selling price,
price elasticity changes over time, DOE energy consumption as the product of sales taxes, distribution chain markups,
relied on a study pertaining to the annual energy consumption per unit and installation cost). DOE calculated
automobiles showing that the and the number of units of each vintage. the NPV of each candidate standard
automobile price elasticity of demand This approach accounts for differences level over the life of the equipment,
changes in the years following a in per-unit energy consumption from using the following three steps. First,
purchase price change.51 With year to year. Cumulative energy savings DOE determined the difference between
increasing years after the purchase price are the sum of the annual NES the equipment costs under the
change, the price elasticity becomes determined over a specified time period. candidate standard level case and the
more inelastic until it reaches a terminal DOE calculated net economic savings base case, to get the net equipment cost
value around the tenth year after the each year as the difference between total increase resulting from the candidate
price change. For its shipments analysis, operating cost savings and increases in standard level. Second, DOE determined
DOE incorporated a relative price total installed costs. Cumulative savings the difference between the base case
elasticity change that resulted in a are the sum of the annual NPV operating costs and the candidate
terminal value of approximately one- determined over a specified time period. standard level operating costs, to get the
third (¥0.11) of the short-run elasticity net operating cost savings resulting from
(¥0.34). In other words, consumer 1. Approach the candidate standard level. Third,
purchase decisions, in time, become less Over time, in the standards case, DOE determined the difference between
sensitive to the initial change in the more-efficient products gradually the net operating cost savings and the
product’s relative price. replace less efficient products. This net equipment cost increase to get the
affects the calculation of the NES and net savings (or expense) for each year.
51 S. Hymans. Consumer Durable Spending: NPV, which are both a function of the DOE then discounted the annual net
Explanation and Prediction, Brookings Papers on total number of units in use and their savings (or expenses) to the year 2006
Economic Activity, 1971. Vol. 1971, No. 1, pp. 234–
239. Available for purchase online at: http://links.
efficiencies, and, thus, are dependent on for products bought in or before 2042
jstor.org/sici?sici=0007–2303(1970)1970%3A2% annual shipments and the lifetime of a and summed the discounted values to
3C173%3ACDSEAP%3E2.0.CO%3B2-S. product. Both calculations start by using provide the NPV of a candidate standard
level. An NPV greater than zero shows key inputs to the calculation of the NES efficiencies may change without
net savings (i.e., the candidate standard and NPV are dependent on the historical information. DOE did forecast
level would reduce customer estimated efficiencies, they are of great the market share of gas standard ranges
expenditures relative to the base case in importance to the analysis. In the case equipped with standing pilot lights to
present value terms). An NPV that is of the NES, the per-unit annual energy estimate the impact of eliminating
less than zero indicates that the (and water) consumption is a direct standing pilot lights for gas cooktops
candidate standard level would result in function of product efficiency. With and gas standard ovens.
a net increase in customer expenditures regard to the NPV, two inputs (the per- In the case of dishwashers, historical
in present value terms. unit total installed cost and the per-unit data show that shipment-weighted
Another aspect of the NIA is the annual operating cost), both depend on efficiencies have grown at an average
consideration of market-pull or efficiency. The per-unit total installed annual rate of approximately two
voluntary programs that promote the cost is a direct function of efficiency percent since 1980. As discussed earlier,
adoption of more-efficient equipment. while the per-unit annual operating some of this efficiency gain during the
PG&E stated that market-pull programs cost, because it is a direct function of 1990s is likely attributable to the Energy
do not necessarily diminish the impact the per-unit energy (and water) Star program. However, historical data
of mandatory efficiency standards. consumption, is indirectly dependent also show that the consumer dishwasher
Whirlpool stated that the effectiveness on product efficiency. retail price has dropped considerably
of one type of market-pull program As first discussed in section II.G.2.d (almost 50 percent) over the same time
(Energy Star) could be diminished if on the development of base case period. Because the per-unit installed
mandatory standards are set efficiencies, for each of the four cost (or consumer retail price) is tied to
prematurely. Whirlpool argued that appliance products, DOE, using data efficiency, using an efficiency growth of
existing product efficiencies are provided by AHAM, based its two percent per year would be expected
approaching Energy Star levels, thereby development of the product efficiencies to result in ever-increasing dishwasher
diminishing the effectiveness of the in the base case on the assignment of retail prices over time. However, since
program if mandatory standards are set equipment efficiencies in the year 2005. forecasting an increasing retail price is
too high. (Public Meeting Transcript, The year 2005 is the latest year for counter to the historical data, DOE
No. 5 at p. 223; Whirlpool, No. 10 at p. which AHAM provided product believes that the most plausible
11) In response, DOE notes that for some efficiency data. In other words, DOE assumption is that dishwasher
products, market-pull programs (e.g., determined the distribution of product efficiencies will remain frozen at the
Energy Star) have likely increased the efficiencies currently in the marketplace
2012 efficiency level until the end of the
share of energy-efficient equipment both to develop a shipment-weighted energy
forecast period.
prior to and after the implementation efficiency for the year 2005. For
date of any new standards. For example, dehumidifiers, it is important to For its determination of standards-
in the case of dishwashers, the reiterate that DOE estimated that the case forecasted efficiencies, DOE used a
shipment-weighted efficiency has product efficiencies in the base case for ‘‘roll-up’’ scenario to establish the
increased at an average annul rate of the 25.00 pints/day and less, 25.01– shipment-weighted efficiency for the
approximately 2.5 percent since 35.00 pints/day, and the 45.01–54.00 year that standards would become
mandatory efficiency standards came pints/day product classes were effective (i.e., 2012). DOE believed that
into effect in 1994. The Energy Star equivalent to those developed for the product efficiencies in the base case,
program, which came into effect for 35.01–45.00 pints/day class. DOE also which did not meet the standard level
dishwashers in 1996, was likely estimated the base case product under consideration, would ‘‘roll-up’’ to
responsible for at least some of the gain efficiencies developed for the 54.01– meet the new standard level. Also, DOE
in dishwasher efficiency. Although DOE 74.99 product class could be applied to believed that all product efficiencies in
recognizes that market-pull programs the 75.00 pints/day and greater product the base case that were above the
such as Energy Star play a factor in class. standard level under consideration
increasing the energy efficiency of Using the shipment-weighted would not be affected. Using the
appliances, DOE was not able to obtain efficiency for the year 2005 as a starting shipment-weighted efficiency in the
information that quantified precisely point, DOE developed base case year 2012 as a starting point, DOE
how such programs affect equipment forecasted efficiencies based on developed standards case forecasted
efficiencies on a national basis. estimates of future efficiency growth. efficiencies. For all of the four appliance
Consequently, DOE did not explicitly For the period spanning 2005–2012 products, DOE made the same estimates
incorporate the impact of market-based (2012 being the estimated effective date regarding forecasted standards-case
initiatives that may be implemented in of a new standard), DOE estimated that efficiencies as for the base case, namely,
the future into the analysis. there would be no growth in shipment- that forecasted efficiencies remained
weighted efficiency (i.e., no change in frozen at the 2012 efficiency level until
2. Base Case and Standards Case the distribution of product efficiencies). the end of the forecast period. By
Forecasted Efficiencies With the exception of dishwashers maintaining the same growth rate for
A key component of DOE’s estimates (discussed below), because there are no forecasted efficiencies in the standards
of NES and NPV are the energy historical data to indicate how product case as in the base case (i.e., zero
efficiencies that it forecasts over time for efficiencies have changed over time, growth), DOE retained a constant
the base case (without new standards) DOE estimated that forecasted efficiency difference or gap between the
and each of the standards cases. The efficiencies would remain frozen at the two cases over the length of the forecast
forecasted efficiencies represent the 2012 efficiency level until the end of the period. Although frozen trends may not
annual shipment-weighted energy forecast period (30 years after the reflect what happens to base case and
efficiency of the products under effective date (i.e., 2042)). Although standards case product efficiencies in
consideration over the forecast period DOE recognizes the possibility that the future, DOE believes that
(i.e., from the estimated effective date of product efficiencies may change over maintaining a frozen efficiency
a new standard to 30 years after the time, DOE is not in a position to difference between the base case and
standard becomes effective). Because speculate as to how these product standards case provides a reasonable
estimate of the impact that standards energy and water consumption spreadsheet models keep track of the
have on product efficiency. associated with these consumers number of units shipped each year. DOE
DOE specifically seeks feedback on its switching to hand washing. Based on believes that the products have an
estimates of forecasted base-case and the results of two recent European increasing probability of retiring as they
standards-case efficiencies and its view studies, DOE estimated that hand age.
of how standards impact product washing would use 140 percent more The national energy consumption is
efficiency distributions in the year that energy and 350 percent more water than the product of the annual energy
standards take effect. This is identified dishwashing.52 53 consumption per unit and the number
as Issue 14 under ‘‘Issues on Which In the case of electric and gas cooking of units of each vintage. This calculation
DOE Seeks Comment’’ in section IV.E of products, because the housing market is accounts for differences in unit energy
this ANOPR. fully saturated (i.e., all households have consumption from year to year.
cooking appliances), available The site-to-source conversion factor is
3. National Impact Analysis Inputs the multiplicative factor DOE uses for
information suggested that standards
The inputs for the determination of would neither impact shipments nor converting site energy consumption into
NES are annual energy (and water) cause shifts in electric and gas cooking primary or source energy consumption.
consumption per unit, shipments, product market shares. Therefore, DOE’s In the analysis for today’s ANOPR, DOE
equipment stock, national annual standards case shipments for electric used annual site-to-source conversion
energy consumption, and site-to-source and gas cooking products were identical factors based on the version of the
conversion factors. to its base case shipments. National Energy Modeling System
Because the annual energy (and With regard to CCWs, MLA stated (NEMS) that corresponds to EIA’s AEO
water) consumption per unit are directly some apartment builders would install 2006.54 These conversion factors take
dependent on efficiency, DOE used the in-apartment washers (i.e., washers for into account natural gas losses from
SWEFs associated with the base case each apartment unit) rather than pipeline leakage and natural gas used
and each standards case, in combination common-area washers if the increase in for pumping energy and transportation
with the annual energy (and water use) CCW purchase prices caused by fuel. For electricity, the conversion
data, to estimate the shipment-weighted standards is too high. MLA commented factors vary over time due to projected
average annual per-unit energy (and that a market switch from common-area changes in generation sources (i.e., the
water) consumption under the base case washers to in-apartment washers would power plant types projected to provide
and standards cases. result in increased energy and water electricity to the country). DOE
The NIA uses forecasted shipments consumption, since consumers would estimated that conversion factors remain
for the base case and all standards cases. tend to use their in-apartment washers constant at 2030 values throughout the
As noted earlier, the increased total more frequently. (MLA, No. 8 at p. 3) remainder of the forecast. EEI stated that
installed cost of more-efficient DOE did account for the drop in CCW mandated increases in renewable energy
equipment causes some customers to shipments caused by standards, but did use throughout the country will affect
forego equipment purchases. not factor in that builders may install the overall efficiency of electricity
Consequently, shipments forecasted more in-apartment washers when faced generation, thereby resulting in less
under the standards cases are lower with higher CCW purchase prices. primary energy being saved from energy
than under the base case. For Rather, because there is a significant savings realized at the site. (EEI, No. 7
dehumidifiers and microwave ovens, to used CCW market, DOE believes that at p. 4) In response, we note that AEO
avoid the inclusion of savings due to establishments that forgo the purchase 2006 provided a review of renewable
displaced shipments, DOE used the of a CCW due to standards would energy programs that were in effect in
standards-case shipments projection instead purchase a used clothes washer 23 States at the end of 2005. Therefore,
and the standards-case stock to calculate with an efficiency equal to the baseline it is anticipated that the site-to-source
the annual energy consumption in the level (i.e., 1.26 MEF/9.5 WF). DOE conversion factors that DOE used in its
base case. However, in the case of believes that the option of purchasing analysis capture the effects of renewable
dishwashers and CCWs, because DOE used CCWs is more likely, as used energy use.
explicitly accounted for the energy and CCWs are a less expensive option to The Joint Comment stated that the
water consumption of the displaced builders than installing in-apartment NIA for dishwashers and CCWs should
shipments, DOE maintained the use of washers. include energy saved as a result of
the base-case shipments to determine An extensive description of the reduced water use, including water
the annual energy consumption in the methodology for conducting and savings in power generation, water
base case. generating the shipments forecasts for pumping (particularly in the West),
In the case of dishwashers, Whirlpool each of the four appliance products can water treatment, and sewage treatment.
and AHAM commented that an increase be found in Chapter 9 of the TSD. (Joint Comment, No. 9 at pp. 3 and 5)
in purchase price due to standards may The equipment stock in a given year Multiple Water Organizations also
result in some consumers foregoing is the number of products shipped and stated that DOE should account for the
dishwasher purchases. Any consumers installed from earlier years and which embedded energy in water supply and
who had to switch to hand washing survive in the given year. The NIA wastewater treatment when establishing
would increase their energy and water the energy savings due to increases in
consumption, since dishwashing is 52 R. Stamminger, Badura, R., Broil, G., Dorr, S.,
more energy and water efficient than and Elschendroich, A., A European Comparison of 54 For the standards rulemakings, DOE will
hand washing. (Whirlpool, No. 10 at p. Cleaning Dishes by Hand, 2004. University of Bonn, generally use the same economic growth and
Germany. Available online at: http:// development assumptions that underlie the most
10; AHAM, No. 14 at p. 9) DOE agrees www.landtechnik.uni-bonn.de/ifl_research/ current AEO published by EIA. For its
with Whirlpool and AHAM. DOE ifl_research_project.php?sec=HT&no=1. determination of site-to-source conversion factors,
envisioned in its analysis that 53 Market Transformation Programme—Briefing DOE used the version of NEMS corresponding to
consumers foregoing the purchase of a Note. BNW16: A comparison of washing up by hand AEO 2006 for the ANOPR due to the unavailability
with a domestic dishwasher, February 13, 2006. of the AEO 2007 version at the time DOE conducted
new unit due to an increase in the Market Transformation Programme, United the NIA. For its analyses for the NOPR and final
efficiency standard would hand wash Kingdom. Available online at: http:// rule, DOE is committed to using the latest available
their dishes, and accounted for the www.mtprog.com/. version of NEMS.
dishwasher and CCW efficiency. of product efficiency. Because the per- include water and wastewater prices in
(Multiple Water Organizations, No. 11 at unit total annual installed cost is the analysis. (Public Meeting Transcript,
p. 2) To include the energy required for directly dependent on efficiency, DOE No. 5 at p. 231) In response, we note
treatment and delivery of water in the used the base case and standards case that DOE determined the per-unit
NIA would require the development of SWEFs in combination with the total annual operating cost savings by taking
new analytical tools. As just noted installed costs to estimate the shipment- the per-unit annual energy (and water)
above, DOE currently takes savings in weighted average annual per-unit total consumption savings developed for
site energy consumption and uses EIA’s installed cost under the base case and each product and multiplying it by the
NEMS to calculate source energy standards cases. appropriate energy (and water) price. As
savings at the generation plant, using As first discussed in the engineering described previously, DOE forecasted
site-to-source conversion factors from analysis for dehumidifiers (see section the per-unit annual energy (and water)
NEMS that take into account the II.C.2.b), total installed cost and consumption for the base case and each
economic interactions between the efficiency relationships were defined for standards case for all four appliance
energy sector and the rest of the a subset of the six product classes. products by freezing the consumption at
economy. Proper accounting of Therefore, for purposes of conducting levels estimated for the year 2012. DOE
embedded energy impacts at a national the NIA for dehumidifiers, DOE applied forecasted energy prices based on EIA’s
scale, including the embedded energy the cost-efficiency data that were AEO 2007. DOE forecasted water prices
due to water savings, would require a developed for this product class subset based on trends in the national water
new version of NEMS that analyzes to those classes for which no cost- price index as provided by the BLS.55
spending and energy use in dozens, if efficiency relationships were developed. The total annual installed cost
not hundreds, of economic sectors. In Specifically, DOE applied the costs increase is equal to the annual change
addition, this version of NEMS would developed for the combined 0–35.00 in the per-unit total installed cost
need to account for shifts in spending pints/day class to the two individual (difference between base case and
between these various sectors to account classes that comprise the combined
standards case) multiplied by the
for the marginal embedded energy class—25.00 pints/day and less and
shipments forecasted in the standards
differences between these sectors. DOE 25.01–35.00 pints/day. Further, DOE
case. As with the calculation of the NES,
currently does not have access to such applied the costs developed for the
DOE did not calculate total annual
a tool, nor does it have the capability to 35.01–45.00 pints/day and 54.01–74.99
installed costs using base case
accurately estimate the source energy pints/day product classes to the 45.01–
shipments. Rather, to avoid the
savings impacts of decreased water or 54.00 pints/day and 75.00 pints/day and
inclusion of savings due to displaced
wastewater consumption and greater product classes, respectively. In
shipments in the case of dehumidifiers
expenditures. There are activites being its application of total installed costs to
and microwave ovens, DOE used the
conducted or initiated by the U.S. those product classes where no cost data
standards case shipments projection
Geological Survey (USGS), EPA, and were developed, DOE did not
interpolate or extrapolate the cost data and, in turn, the standards case stock, to
DOE to study water and wastewater
to account for product efficiency calculate the costs. In the case of
issues. The USGS compiles national
differences between the classes. For dishwashers, DOE believes that any
water data but not at the utility level.
example, DOE utilized the exact same consumers foregoing the purchase of a
The EPA is sponsoring the WaterSense
total installed costs that were developed new unit due to standards would shift
Program and programs to promote
for the baseline and standard levels for to hand washing. In the case of CCWs,
energy efficiency in water and
the 35.01–45.00 pints/day product class DOE believes that any drop in
wastewater treatment. Finally, DOE is in
the midst of a National Energy-Water to characterize the baseline and shipments caused by standards would
Roadmap Program that it initiated in standard level total installed costs for result in the purchase of used machines.
2005, as requested in congressional the 45.01–54.00 pints/day product class. Electric and gas cooking products are
appropriations in FY 2005. However, Chapter 10 of the ANOPR provides the notable exception. For electric and
none of these activites has yet provided additional details on DOE’s approach gas cooking products, because the
the necessary sources of data or tools to for estimating the total installed costs market is fully saturated, DOE believed
allow calculation of the embedded for the dehumidifier product classes. that standards would neither impact
energy in water. Although DOE cannot DOE specifically seeks feedback on its shipments nor cause shifts in electric
yet determine the embedded energy in approach for characterizing the total and gas cooking product market shares.
water savings, both the LCC and PBP installed costs for those dehumidifier Therefore, for electric and gas cooking
analyses and the NIA do include the product classes in which DOE was not products, DOE used the base case
economic savings from decreased water able to develop cost-efficiency shipments to determine costs for all
and wastewater charges. Such economic relationships. This is identified as Issue standards cases.
savings should include the economic 15 under ‘‘Issues on Which DOE Seeks The total annual operating cost
value of any energy savings that may be Comment’’ in section IV.E of this savings are equal to the change in the
included in the provision of consumer ANOPR. annual operating costs (difference
water and wastewater services. The annual operating cost savings per between base case and standards case)
The inputs to the NPV calculation are unit includes changes in the energy, per unit multiplied by the shipments
total installed cost per unit, annual water, repair, and maintenance costs. forecasted in the standards case. As
operating cost savings per unit, total DOE believed there would be no noted above for the calculation of total
annual installed cost increases, total increase in maintenance and repair annual installed costs, DOE did not
annual operating cost savings, discount costs due to standards for the four
factor, present value of increased appliance products. Therefore, for each 55 U.S. Department of Labor—Bureau of Labor
installed costs, and present value of of the products, DOE determined the Statistics. Consumer Price Indexes, Item: Water and
operating cost savings. per-unit annual operating cost savings sewerage maintenance, Series Id:
CUUR0000SEHG01, U.S. city average (not
For each of the four appliance based only on the energy (and water) seasonally adjusted), 2006. Washington, DC.
products, the NPV calculation uses the cost savings due to a standard efficiency Available online at: http://www.bls.gov/cpi/
total installed cost per unit as a function level. EEI suggested that DOE should home.htm#data.
necessarily calculate operating cost cost increase in each year (i.e., the (2012) to the time when the last unit
savings using the base case shipments. difference between the standards case installed in 2042 is retired from service.
DOE multiplies monetary values in and base case), discounted to the Savings are decreases in operating costs
future years by the discount factor to present, and summed for the time associated with the higher energy
determine the present value. DOE period over which DOE is considering efficiency of equipment purchased in
estimated national impacts using both a the installation of equipment (i.e., from the standards case compared to the base
three-percent and a seven-percent real the effective date of standards, 2012, to case. Total annual operating cost
discount rate as the average real rate of the year 2042). The increase in total savings is the savings per unit
return on private investment in the U.S. installed cost refers to both the multiplied by the number of units of
economy. DOE uses these discount rates incremental equipment cost and the each vintage surviving in a particular
in accordance with guidance provided incremental installation cost associated year. Equipment consumes energy over
by the Office of Management and with the higher energy efficiency of its entire lifetime, and for units
Budget (OMB) to Federal agencies on equipment purchased in the standards purchased in 2042, the consumption
the development of regulatory analysis
case compared to the base case. includes energy consumed until the unit
(OMB Circular A–4 (Sept. 17, 2003),
The present value of operating cost is retired from service.
particularly section E, ‘‘Identifying and
Measuring Benefits and Costs’’). For the savings is the annual operating cost Table II.77 summarizes the NES and
sake of these analyses, DOE defines the savings (i.e., the difference between the NPV inputs to the NIA spreadsheet
present year as 2007. base case and standards case), model. For each input, the table gives a
The present value of increased discounted to the present, and summed brief description of the data source. For
installed costs is the annual installed over the period from the effective date details, see Chapter 10 of the TSD.
TABLE II.77.—NATIONAL ENERGY SAVINGS AND NET PRESENT VALUE INPUTS

Input Data description
Shipments ........................................................... Annual shipments from Shipments Model. (See Chapter 9 of the TSD for more details.)
Effective Date of Standard ................................. 2012.
Base-Case Forecasted Efficiencies .................... Shipment-weighted efficiency (SWEF) determined in the year 2005 for each of the four appli-
ance products. SWEF held constant over forecast period of 2005–2042. (See Chapter 10 of
the TSD for more details.)
Standards-Case Efficiencies ............................... ‘‘Roll-up’’ scenario used for determining SWEF in the year 2012 for each standards case and
for each of the four appliance products. SWEF held constant over forecast period of 2012–
2042. (See Chapter 10 of the TSD for more details.)
Annual Energy Consumption per Unit ................ Annual weighted-average values are a function of SWEF. (See Chapter 10 of the TSD for
more details.)
Total Installed Cost per Unit ............................... Annual weighted-average values are a function of SWEF. (See Chapter 10 of the TSD for
more details.)
Energy and Water Cost per Unit ........................ Annual weighted-average values are a function of the annual energy consumption per unit and
energy (and water) prices. (For more details on energy and water prices, see Chapter 8 of
the TSD.)
Repair Cost and Maintenance Cost per Unit ..... No changes in repair and maintenance cost due to standards.
Escalation of Energy and Water Prices ............. Energy Prices: 2007 EIA AEO forecasts (to 2030) and extrapolation to 2042. (See Chapter 8
of the TSD for more details.) Water Prices: Linear extrapolation of historical trend in national
water price index. (See Chapter 8 of the TSD for more details.)
Energy Site-to-Source Conversion ..................... Conversion varies yearly and is generated by DOE/EIA’s NEMS* program (a time-series con-
version factor; includes electric generation, transmission, and distribution losses).
Discount Rate ..................................................... 3 and 7 percent real.
Present Year ....................................................... Future expenses are discounted to year 2007.
* Chapter 13 on the utility impact analysis and the environmental assessment report of the TSD provide more details on NEMS.
4. National Impact Analysis Results as primary energy savings in quads. Chapter 10 of the TSD provides
National water savings (NWS) results discounted NES and NWS results based
Below are the NES results (and are expressed in billions of gallons. DOE on discount rates of three and seven
national water savings results for based the inputs to the NIA spreadsheet percent.
dishwashers and CCWs) for the model on weighted-average values, Table II.78 shows the NES and NWS
candidate standard levels analyzed for yielding results that are discrete point results for the candidate standard levels
the four appliance products. NES results values, rather than a distribution of analyzed for standard-sized
are cumulative to 2042 and are shown values as in the LCC and PBP analyses. dishwashers.
TABLE II.78.—DISHWASHERS: CUMULATIVE NATIONAL ENERGY SAVINGS AND NATIONAL WATER SAVINGS RESULTS
NES NWS
Candidate standard level EF
quads billion gallons
1 ................................................................................................................................................... 0.46 0.09 72

2 ................................................................................................................................................... 0.58 0.35 271
3 ................................................................................................................................................... 0.62 0.61 458
4 ................................................................................................................................................... 0.65 0.86 595
5 ................................................................................................................................................... 0.72 1.11 659
6 ................................................................................................................................................... 0.80 1.54 808
TABLE II.78.—DISHWASHERS: CUMULATIVE NATIONAL ENERGY SAVINGS AND NATIONAL WATER SAVINGS RESULTS—
Continued
NES NWS
Candidate standard level EF quads billion gallons
7 ................................................................................................................................................... 1.11 2.77 1611
Table II.79 shows the NES results for

the candidate standard levels analyzed
for dehumidifiers.
TABLE II.79.—DEHUMIDIFIERS: CUMULATIVE NATIONAL ENERGY SAVINGS RESULTS

≤ 25.00 25.01–35.00 35.01–45.00 45.01–54.00 54.01–74.99 ≤ 75.00 ALL
Candidate
standard level NES NES NES NES NES NES * NES
EF EF EF EF EF EF
quads quads quads quads quads quads quads
1 ....................... 1.10 0.01 1.25 0.01 1.35 0.01 1.45 0.01 1.55 0.01 2.38 0.00 0.04
2 ....................... 1.20 0.02 1.30 0.02 1.40 0.02 1.50 0.02 1.60 0.02 2.50 0.00 0.11
3 ....................... 1.25 0.02 1.35 0.04 1.45 0.04 1.55 0.04 1.65 0.05 2.55 0.00 0.18
4 ....................... 1.30 0.02 1.40 0.05 1.50 0.05 1.60 0.05 1.70 0.07 2.60 0.00 0.25
5 ....................... 1.38 0.03 1.45 0.06 1.74 0.13 2.02 0.18 1.80 0.12 2.75 0.00 0.53
* NES greater than zero but less than 0.005 quads.
Tables II.80 and II.81 show the NES analyzed for cooktops and ovens,
results for the candidate standard levels respectively.
TABLE II.80.—COOKTOPS: CUMULATIVE NATIONAL ENERGY SAVINGS RESULTS

Candidate standard level NES NES NES
EF EF EF
quads quads quads
1 ............................................................................................................... 0.769 0.04 0.753 0.02 0.399 0.10

2 ............................................................................................................... ................ ................ ................ ................ 0.420 0.15
TABLE II.81.—OVENS: CUMULATIVE NATIONAL ENERGY SAVINGS RESULTS

Elec standard Elec self-clean Gas standard Gas self-clean
Candidate standard level NES NES NES NES
EF EF EF EF
quads quads quads quads
1 * ..................................................................... 0.1113 0.03 0.1102 0.01 0.0536 0.04 0.0625 0.09

2 ....................................................................... 0.1163 0.05 0.1123 0.04 0.0566 0.07 0.0627 0.09
3 ....................................................................... 0.1181 0.06 ................ ................ 0.0572 0.08 0.0632 0.10
4 ....................................................................... 0.1206 0.07 ................ ................ 0.0593 0.09 ................ ................
5 ....................................................................... 0.1209 0.08 ................ ................ 0.0596 0.09 ................ ................
6 ....................................................................... ................ ................ ................ ................ 0.0600 0.10 ................ ................
1a * ................................................................... ................ ................ ................ ................ 0.0583 0.13 ................ ................
Table II.82 shows the NES results for

for microwave ovens.
TABLE II.82.—MICROWAVE OVENS: CUMULATIVE NATIONAL ENERGY SAVINGS RESULTS

NES
Candidate standard level EF quads
1 ............................................................................................................................................................................... 0.586 0.19
TABLE II.82.—MICROWAVE OVENS: CUMULATIVE NATIONAL ENERGY SAVINGS RESULTS—Continued

NES
Candidate standard level EF quads
2 ............................................................................................................................................................................... 0.588 0.20

3 ............................................................................................................................................................................... 0.597 0.25
4 ............................................................................................................................................................................... 0.602 0.26
Table II.83 shows the NES and NWS

results for the candidate standard levels
analyzed for CCWs.
TABLE II.83.—COMMERCIAL CLOTHES WASHERS: CUMULATIVE NATIONAL ENERGY SAVINGS AND NATIONAL WATER
SAVINGS RESULTS
NES NWS
Candidate standard level MEF/WF quads billion gallons
1 ................................................................................................................................................... 1.42/9.50 0.12 0

2 ................................................................................................................................................... 1.60/8.50 0.21 233
3 ................................................................................................................................................... 1.72/8.00 0.26 350
4 ................................................................................................................................................... 1.80/7.50 0.30 466
5 ................................................................................................................................................... 2.00/5.50 0.36 933
6 ................................................................................................................................................... 2.20/5.10 0.43 1050
Below are the NPV results for the impact of standards (i.e., from the energy and must be maintained over its
candidate standard levels considered for effective date of standards (2012) to the entire lifetime. For units purchased in
the product classes of each of the four year 2042). 2042, the operating cost includes energy
appliance products. Results are Savings are decreases in operating and water consumed until the last unit
cumulative and are shown as the costs (including energy and water) is retired from service.
discounted value of these savings in associated with the higher energy The tables below show the NPV
dollar terms. The present value of efficiency of equipment purchased in results for the candidate standard levels
increased total installed costs is the total the standards case compared to the base analyzed for each of the four appliance
installed cost increase (i.e., the case. Total operating cost savings are the products, based on discount rates of
difference between the standards case savings per unit multiplied by the three and seven percent.
and base case), discounted to the number of units of each vintage (i.e., the Table II.84 shows the NPV results for
present, and summed over the time year of manufacture) surviving in a the candidate standard levels analyzed
period in which DOE evaluates the particular year. Equipment consumes for standard-sized dishwashers.
TABLE II.84.—DISHWASHERS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON SEVEN-PERCENT AND THREE-
PERCENT DISCOUNT RATES
NPV
Candidate standard level EF 7% Discount 3% Discount

rate rate
billion 2006$ billion 2006$
1 ................................................................................................................................................... 0.46 0.38 0.94

2 ................................................................................................................................................... 0.58 1.29 3.29
3 ................................................................................................................................................... 0.62 1.73 4.72
4 ................................................................................................................................................... 0.65 0.90 3.61
5 ................................................................................................................................................... 0.72 ¥2.75 ¥2.94
6 ................................................................................................................................................... 0.80 ¥7.25 ¥10.77
7 ................................................................................................................................................... 1.11 ¥7.28 ¥8.16
Tables II.85 and II.86 show the NPV

results for the candidate standard levels
analyzed for dehumidifiers.
TABLE II.85.—DEHUMIDIFIERS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON A SEVEN-PERCENT DISCOUNT
RATE
≤ 25.00 25.01–35.00 35.01–45.00 45.01–54.00 54.01–74.99 ≥75.00 ALL
Candidate NPV NPV NPV NPV NPV NPV * NPV

standard level @ 7% @ 7% @ 7% @ 7% @ 7% @ 7% @ 7%
EF EF EF EF EF EF
billion billion billion billion billion billion billion
2006$ 2006$ 2006$ 2006$ 2006$ 2006$ 2006$
1 ....................... 1.10 0.01 1.25 0.02 1.35 0.01 1.45 0.01 1.55 0.02 2.38 0.00 0.08
2 ....................... 1.20 0.05 1.30 0.06 1.40 0.03 1.50 0.03 1.60 0.05 2.50 0.00 0.21
3 ....................... 1.25 0.05 1.35 0.07 1.45 0.04 1.55 0.04 1.65 0.10 2.55 0.00 0.31
4 ....................... 1.30 0.04 1.40 0.07 1.50 0.03 1.60 0.04 1.70 0.11 2.60 0.00 0.31
5 ....................... 1.38 0.05 1.45 0.08 1.74 0.00 2.02 0.21 1.80 0.19 2.75 0.00 0.54
* NPV greater than zero but less than $0.005 billlion.
TABLE II.86.—DEHUMIDIFIERS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON A THREE-PERCENT DISCOUNT
RATE
≤ 25.00 25.01–35.00 35.01–45.00 45.01–54.00 54.01–74.99 ≥75.00 ALL
Candidate NPV NPV NPV NPV NPV NPV * NPV

standard level @ 3% @ 3% @ 3% @ 3% @ 7% @ 3% @ 3%
EF EF EF EF EF EF
billion billion billion billion billion billion billion
2006$ 2006$ 2006$ 2006$ 2006$ 2006$ 2006$
1 ....................... 1.10 0.04 1.25 0.04 1.35 0.04 1.45 0.04 1.55 0.06 2.38 0.00 0.22
2 ....................... 1.20 0.11 1.30 0.14 1.40 0.09 1.50 0.09 1.60 0.12 2.50 0.01 0.57
3 ....................... 1.25 0.13 1.35 0.20 1.45 0.13 1.55 0.14 1.65 0.27 2.55 0.01 0.87
4 ....................... 1.30 0.12 1.40 0.21 1.50 0.14 1.60 0.16 1.70 0.32 2.60 0.01 0.96
5 ....................... 1.38 0.15 1.45 0.25 1.74 0.19 2.02 0.66 1.80 0.55 2.75 0.01 1.81
Tables II.87 and II.88 show the NPV analyzed for cooktops and ovens,
results for the candidate standard levels respectively.
TABLE II.87.—COOKTOPS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON SEVEN-PERCENT AND THREE-PERCENT
DISCOUNT RATES
Candidate standard NPV @ NPV @ NPV @ NPV @ NPV @ NPV @
level EF 7% billion 3% billion EF 7% billion 3% billion EF 7% billion 3% billion
2006$ 2006$ 2006$ 2006$ 2006$ 2006$
1 ................................. 0.769 0.05 0.18 0.753 ¥7.48 ¥14.28 0.399 0.29 0.67
2 ................................. .................. .................. .................. .................. .................. .................. 0.420 ¥0.65 ¥0.98
TABLE II.88.—OVENS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON SEVEN-PERCENT AND THREE-PERCENT
DISCOUNT RATES
Elec standard Elec self-clean Gas standard Gas self-clean
NPV NPV NPV NPV NPV 2 NPV NPV 2 NPV 2

Candidate standard level @ 7% @ 3% @ 7% @ 3% @ 7% @ 35 @ 7% @ 3%
EF EF EF EF
billion billion billion billion billion billion billion billion
2006$ 2006$ 2006$ 2006$ 2006$ 2006$ 2006$ 2006$
1 * ..................................... 0.1113 0.06 0.17 0.1102 ¥0.28 ¥0.53 0.0536 0.10 0.24 0.0625 ¥0.01 0.18
2 ....................................... 0.1163 0.08 0.27 0.1123 ¥2.87 ¥5.41 0.0566 0.11 0.34 0.0627 ¥0.12 0.02
3 ....................................... 0.1181 0.03 0.19 ............ ............ ............ 0.0572 0.11 0.34 0.0632 ¥0.14 ¥0.05
4 ....................................... 0.1206 ¥0.81 ¥1.39 ............ ............ ............ 0.0593 ¥0.33 ¥0.45 ............ ............ ............
5 ....................................... 0.1209 ¥0.88 ¥1.52 ............ ............ ............ 0.0596 ¥0.36 ¥0.50 ............ ............ ............
6 ....................................... ............ ............ ............ ............ ............ ............ 0.0600 ¥0.42 ¥0.62 ............ ............ ............
1a * ................................... ............ ............ ............ ............ ............ ............ 0.0583 0.35 0.92 ............ ............ ............
Tables II.89 shows the NPV results for

for microwave ovens.
TABLE II.89.—MICROWAVE OVENS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON SEVEN-PERCENT AND THREE-
PERCENT DISCOUNT RATES
NPV
Candidate standard level EF 7% Discount 3% Discount

rate rate
1 ................................................................................................................................................... 0.586 ¥1.40 ¥2.48

2 ................................................................................................................................................... 0.588 ¥3.52 ¥6.51
3 ................................................................................................................................................... 0.597 ¥6.58 ¥12.28
4 ................................................................................................................................................... 0.602 ¥10.35 ¥19.40
Table II.90 shows the NPV results for

for CCWs.
TABLE II.90.—COMMERCIAL CLOTHES WASHERS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON SEVEN-
PERCENT AND THREE-PERCENT DISCOUNT RATES
NPV
Candidate standard level MEF/WF 7% Discount 3% Discount

rate rate
1 ................................................................................................................................................... 1.42/9.50 0.04 0.20

2 ................................................................................................................................................... 1.60/8.50 ¥0.09 0.22
3 ................................................................................................................................................... 1.72/8.00 0.23 0.99
4 ................................................................................................................................................... 1.80/7.50 0.49 1.64
5 ................................................................................................................................................... 2.00/5.50 1.41 3.87
6 ................................................................................................................................................... 2.20/5.10 1.77 4.74
J. Life-Cycle Cost Subgroup Analysis DOE will determine the effect on income and senior subgroups. It stated
customer subgroups using the LCC that low-income consumers are more
The LCC subgroup analysis evaluates spreadsheet model. NWPCC stated that likely to use CCWs, and that seniors
impacts of standards on identifiable the Monte Carlo approach, if tend to use dishwashers and cooking
groups of customers, such as different implemented in the LCC and PBP products less frequently than the overall
population groups of consumers or analyses, can be used to conduct the population. (EEE, No. 7 at p. 6) For
different business types, which may be subgroup analysis. NWPCC stated that CCWs, ALS stated that DOE should
disproportionately affected by any the Monte Carlo approach is suitable for consider low-income consumers and
national energy efficiency standard identifying different subgroups, such as senior citizens, especially if standards
level. In the NOPR phase of this regional subgroups, that may be cause an increase in vending prices.
rulemaking, DOE will analyze the LCCs impacted differently by standards. ALS stated that the resulting increase in
and PBPs for customers that fall into (Public Meeting Transcript, No. 5 at p. vending price would lead to less
such groups. The analysis will 235) As described in section II.G on the available disposable income for low-
determine whether any particular group LCC and PBP analyses, DOE used a income and senior consumers to use
of consumers would be adversely Monte Carlo approach to conduct the commercial laundry. MLA expressed
affected by any of the trial standard LCC and PBP analyses. The spreadsheet the same concerns, but only for low-
levels. model it used for the LCC analysis, income consumers. (Public Meeting
Also, DOE plans to examine which incorporates the use of Monte Transcript, No. 5 at p. 237; MLA, No. 8
variations in energy prices and energy Carlo sampling, can be used with at p. 2)
use that might affect the NPV of a different data inputs. The standard LCC GE and PG&E suggested that DOE
standard for customer sub-populations. analysis includes various customer consider regional subgroups. GE stated
To the extent possible, DOE will obtain types that use the four appliance that regional subgroups for dishwashers
estimates of the variability of each input products. DOE can analyze the LCC for and cooking products would be
parameter and consider this variability any subgroup, such as low-income appropriate because the regional
in the calculation of customer impacts. consumers, by using the LCC saturations for both sets of products
Variations in energy use for a particular spreadsheet model and sampling only vary significantly. (Public Meeting
product depend on a number of factors, that subgroup. Details of this model are Transcript, No. 5 at pp. 240–241) PG&E
such as climate and type of user. DOE explained in section II.G. stated that DOE should consider
plans to perform sensitivity analyses to DOE received several comments as to regional subgroups for dehumidifiers.
consider how differences in energy use which subgroups it should analyze. EEI (Public Meeting Transcript, No. 5 at p.
will affect subgroups of customers. suggested that DOE consider low- 237) Lastly, the EPA thought it would be
prudent to consider subgroups that are DOE conducts the MIA in three publications, etc. DOE subsequently
not served by water and sewer service phases. In Phase I, DOE creates an solicits comments and suggestions on
providers, but by wells and septic industry profile to characterize the these estimates during the interviews.
systems. EPA believes that these industry, and conducts a preliminary DOE asks interview participants to
consumers use less water than the MIA to identify important issues that identify any confidential information
overall population. (Public Meeting require consideration. Results of the that they have provided, either orally or
Transcript, No. 5 at p. 234) Phase I analysis are presented in in writing. DOE considers all
DOE intends to analyze the impacts of Chapter 12 of the TSD. In Phase II, DOE information collected, as appropriate, in
candidate standards on low-income and prepares an industry cash flow model its decision-making process. However,
senior subgroups. DOE also will and an interview questionnaire to guide DOE does not make confidential
evaluate whether regional variations are subsequent discussions. In Phase III, information available in the public
significant enough to warrant an DOE interviews manufacturers, and record. DOE also asks participants to
analysis of regional subgroups for assesses the impacts of standards both identify all information that they wish
dishwashers, dehumidifiers, and quantitatively and qualitatively. It to have included in the public record,
cooking products. In its analysis of assesses industry and subgroup cash but that they do not want to have
dishwashers and CCWs, DOE will also flow and net present value through use associated with their interview or
consider evaluating those consumer of the Government Regulatory Impact company; DOE incorporates such
subgroups not served by water and Model (GRIM). DOE then assesses information into the public record, but
sewer. In its analysis of subgroups, DOE impacts on competition, manufacturing reports it without attribution.
will be especially sensitive to purchase capacity, employment, and regulatory Finally, DOE collates the completed
price increases (‘‘first-cost’’ increases) to burden based on manufacturer interview questionnaires and prepares a
avoid negative impacts on identifiable interview feedback and discussions. summary of the major issues. For more
population groups such as low-income Results of the Phase II and Phase III detail on the methodology used in the
households (in the case of residential analyses are presented in the NOPR MIA, refer to Chapter 12 of the TSD.
products) or small businesses with low TSD. 2. Industry Cash Flow Analysis
annual revenues (in the case of CCWs), 1. Sources of Information for the The industry cash flow analysis relies
which may not be able to afford a Manufacturer Impact Analysis primarily on the GRIM, which helps
significant increase in product or Many of the analyses described above identify the effects of various efficiency
equipment prices. provide important inputs to the MIA. regulations and other regulations on
K. Manufacturer Impact Analysis Such inputs include manufacturing manufacturers. The basic structure of
costs and prices from the engineering the GRIM is a standard annual cash flow
The purpose of the MIA is to identify analysis, retail price forecasts, and analysis that uses price and volume
the likely impacts of energy shipments forecasts. DOE supplements information as an input, builds on
conservation standards on this information with company financial fundamental base cost information, and
manufacturers. DOE has begun and will data and other information gathered accepts a set of regulatory conditions as
continue to conduct this analysis with during interviews with manufacturers. changes in costs and investments. DOE
input from manufacturers and other As discussed below, this interview uses the GRIM to analyze the financial
interested parties. DOE will process plays a key role in the MIA impacts of more stringent energy
subsequently apply a similar because it allows interested parties to conservation standards on the industry.
methodology to its evaluation of privately express their views on The GRIM analysis uses several
standards. During the MIA, DOE will important issues. To preserve factors to determine annual cash flows
consider financial impacts and a wide confidentiality, DOE aggregates these from a new standard: (1) Annual
range of quantitative and qualitative perspectives across manufacturers, expected revenues; (2) manufacturer
industry impacts that might occur creating a combined opinion or estimate costs including cost of goods sold; (3)
following the adoption of a standard. for use in its analyses. This process depreciation; (4) research and
For example, if DOE adopts a particular enables DOE to incorporate sensitive development; (5) selling, general, and
standard level, it could require changes information from manufacturers in the administrative expenses; (6) taxes; and
to manufacturing practices. DOE will rulemaking process without specifying (7) conversion capital expenditures.
identify and understand these impacts precisely which manufacturer provided DOE compares the results against base
through interviews with manufacturers a certain set of data. case projections that involve no new
and other stakeholders during the NOPR DOE conducts detailed interviews standards. The financial impact of new
stage of its analysis. with manufacturers to gain insight into standards is the difference between the
Recently, DOE announced changes to the range of potential impacts of two sets of discounted annual cash
the MIA format through a report issued standards. During the interviews, DOE flows. For more information on the
to Congress on January 31, 2006 (as typically solicits both quantitative and industry cash flow analysis, refer to
required by section 141 of EPACT 2005), qualitative information on the potential Chapter 12 of the TSD.
entitled ‘‘Energy Conservation impacts of efficiency levels on sales,
Standards Activities.’’ Previously, DOE direct employment, capital assets, and 3. Manufacturer Subgroup Analysis
did not report any MIA results during industrial competitiveness. DOE prefers Industry cost estimates are not
the ANOPR phase of energy an interactive interview process, rather adequate to assess differential impacts
conservation standards rulemakings; than a written response to a among subgroups of manufacturers. For
however, under this new format, DOE questionnaire, because it helps clarify example, small and niche
has collected, evaluated, and reported responses and identify additional manufacturers, or manufacturers whose
some preliminary information and data issues. Before each interview, DOE cost structure differs significantly from
in section II.K.6 of this ANOPR. For circulates a draft document showing its the industry average, could experience a
further information on the MIA process, estimates of financial parameters based disproportionate impact due to
the analysis, and the results, please refer on publicly available information, such standards changes. Because DOE cannot
to Chapter 12 of the TSD. as filings with the SEC, articles in trade consider the impact on every firm
individually, the results of the industry manufacturers selling outside the U.S. of this rulemaking to get feedback on its
characterization are typically used to market.) analysis and results.
group manufacturers exhibiting similar DOE will study the potential impacts During the course of the preliminary
characteristics. of these cumulative burdens in greater MIA, DOE interviewed manufacturers
During MIA interviews, DOE detail during the MIA conducted during representing over 80 percent of
discusses the potential subgroups and the NOPR phase. domestic dishwasher sales, 66 percent
subgroup members it has identified for of domestic dehumidifier sales, and
6. Preliminary Results for the practically 100 percent of CCW sales.
the analysis. DOE encourages the
Manufacturer Impact Analysis DOE used these same interviews to
manufacturers to recommend subgroups
or characteristics that are appropriate DOE conducted a preliminary review the engineering analysis cost and
for the subgroup analysis. For more evaluation of the impact of potential performance data contained in chapter 5
detail on the manufacturer subgroup new regulations for the products to be of the TSD. However, during the course
analysis, refer to Chapter 12 of the TSD. covered by this rulemaking on of the MIA interviews, focus of the
manufacturer financial performance, discussion was shifted from technology-
4. Competitive Impacts Assessment related topics to business-related topics.
manufacturing capacity and
Another factor which DOE must employment levels, and product utility DOE’s objective was to become familiar
consider in standard setting is whether and innovation. A primary focus was to with each company’s particular market
a new standard is likely to reduce identify the cumulative burden that approach and financial structure, and its
industry competition, and the Attorney industry faces from the overlapping concerns and issues related to new
General must determine the impacts, if effect of new or recent energy efficiency standards. Most of the
any, of reduced competition. DOE conservation standards and/or other information received from these
makes a determined effort to gather and regulatory action affecting the same meetings is protected by non-disclosure
report firm-specific financial product or industry. agreements and resides with DOE’s
information and impacts. In particular, The primary sources of information contractors. Before each visit, DOE
the competitive impacts assessment for this analysis were telephone provided company representatives with
focuses on the impacts of new energy interviews with manufacturers of an interview guide that included the
efficiency standards on smaller dishwashers, dehumidifiers, and CCWs topics that DOE hoped to cover. The
manufacturers. DOE bases this carried out during the first quarter of FY topics included:
assessment on manufacturing cost data 2007. To maintain confidentiality, DOE • Key issues—the most important
and on information collected from did not identify the individual things to consider in setting new
interviews with manufacturers. Hence, manufacturers that disclosed standards from the perspective of
manufacturer interviews also focus on information. Instead, the evaluation manufacturers;
gathering information to help assess only reports aggregated information and • Product mix—effects of potential
asymmetrical cost increases to some does not disclose sensitive information standard levels on a manufacturer’s
manufacturers, increased proportions of or identify company-specific product mix;
fixed costs that could increase business information. For the preliminary MIA, • Profitability—insights into market
risks, and potential barriers to market DOE conducted interviews with forces which could affect a
entry (e.g., proprietary technologies). manufacturers primarily to identify key manufacturer’s profitability;
• Conversion costs—estimates of
issues and gain insights into the
5. Cumulative Regulatory Burden costs required to meet new standards;
qualitative impacts of energy • Manufacturing capacity and
DOE recognizes and seeks to mitigate conservation standards. For each employment levels—decisions to
the overlapping effects on product, DOE used an interview guide upgrade, remodel, or relocate existing
manufacturers of new or revised DOE to gather responses from multiple facilities and resulting changes in
standards and other regulatory actions manufacturers on several issues. All the employment patterns resulting from
affecting the same equipment. Thus, interview guides covered the same new energy efficiency standards;
DOE analyzes and considers the impact general topic areas, but DOE adapted • Market share and industry
on manufacturers of multiple, product- them, as appropriate, to address each consolidation—changes to competitive
specific regulatory actions. product category. (Copies of the dynamics of the marketplace and the
Based on its own research and interview guides for CCW, possible consequences for consumers;
discussions with manufacturers, DOE dehumidifier, and dishwasher • Product utility and innovation—
has identified several regulations manufacturers are contained in effect of standards on product utility
relevant to dishwasher, dehumidifier, Appendix B of the TSD.) and innovation; and
cooking product, and CCW However, DOE did not interview • Cumulative burden—assessment of
manufacturers, including existing or cooking product manufacturers at this the level and timing of investments
new standards, the phase-out of stage due to feedback from stakeholders manufacturers are expecting to incur as
hydrochlorofluorocarbon refrigerants, such as AHAM and several cooking a result of other regulations.
the prohibition of phosphate-containing product manufacturers, suggesting that Additionally, DOE often introduced,
detergents in some jurisdictions, DOE limit its efforts to updating the entertained, and discussed other topics
standards for other products made by extensive 1996 cooking product during the course of the interviews,
dishwasher, dehumidifier, cooking technical analysis; these stakeholders such as the impact of various design
product, and CCW manufacturers, reasoned that such an update would options on energy efficiency, how
including State standards, and foreign properly represent prices, design testing standards and usage patterns
energy conservation standards. options, and manufacturer issues for vary by market, and performance issues.
(Although foreign standards do not products covered by the present Perhaps the most important aspect of
directly affect products entering the rulemaking. Thus, DOE updated the the preliminary MIA was the
U.S., they do impact manufacturer 1996 cooking products analysis and opportunity it created for DOE to
operations, in that they represent plans to interview manufacturers of identify key manufacturer issues early
additional business expenses for cooking products during the NOPR stage in the development of new standards.
During the interviews, DOE engaged the of the EIA’s NEMS.56 EIA uses NEMS to percent per year, compared with 2.9
manufacturers in a discussion of their produce its AEO. NEMS produces a percent per year in the reference case
perception of the key issues in the widely recognized reference case and 2.2 percent per year in the low-
rulemaking. DOE then added these key forecast for the United States and is growth case. As part of varying supply-
issues to the list of questions and topics available in the public domain. DOE side growth determinants in these cases,
explored during the interviews. will use a variant known as NEMS- AEO 2007 also varies the forecasted
The concerns that rose to the level of Building Technologies (BT) to provide energy prices for all three economic
key issues in the opinion of dishwasher key inputs to the analysis. growth cases. Different economic
The use of NEMS for the utility growth cases affect the rate of growth of
manufacturers included: (1) The
impact analysis offers several electricity demand.
potential elimination of entry-level advantages. As the official DOE energy
dishwashers from the market; (2) a The electric utility industry analysis
forecasting model, NEMS relies on a set will consist of NEMS–BT forecasts for
possible reduction in dishwasher of premises that are transparent and
washing performance; (3) the increased generation, installed capacity, sales, and
have received wide exposure and prices. The gas utility industry analysis
likelihood of consumers hand washing commentary. NEMS allows an estimate
and pre-rinsing dishes; and (4) the will consist of NEMS–BT forecasts of
of the interactions between the various sales and prices. The NEMS–BT
potential relocation of production energy supply and demand sectors and
facilities overseas. provides reference case load shapes for
the economy as a whole. The utility several end uses, including residential
The key issues expressed by impact analysis will determine the dishwashing and cooking, but does not
dehumidifier manufacturers included: changes for electric utilities in installed
provide load shapes 57 specifically for
(1) The ability to pass cost increases on capacity and in generation by fuel type
dehumidifiers and CCWs. Because most
to consumers; (2) increased pressure produced by each candidate standard
of the energy consumed by clothes
from foreign competition; and (3) the level, as well as changes in gas and
washers is expended on water heating,
ability to maintain Energy Star product electricity sales to the commercial sector
DOE intends to use NEMS–BT’s
offerings. (for CCWs) and the consumer sector (for
commercial water-heating load shapes
The key issues for CCW residential dishwashers, dehumidifiers,
to characterize CCWs. For
manufacturers included: (1) The risk of and cooking products). (Because
dehumidifiers, because this end use is
eliminating vertical-axis washers from dehumidifiers neither operate on gas
operated in a similar manner to air-
the market; (2) reduced product nor rely on water heated by gas,
standards for this product do not affect conditioning equipment, DOE intends to
shipments due to a move away from use NEMS–BT residential space-cooling
central laundry facilities to in-unit gas sales.)
DOE plans to conduct the utility load shapes to characterize it. For
residential laundry and prolonging the electrical end uses, NEMS–BT uses
impact analysis as a variant of the
life of existing equipment; (3) reduced predicted growth in demand for each
NEMS used to produce the AEO 2007,
cleaning performance of some energy- end use to build up a projection of the
applying the same basic set of premises.
saving design options; (4) the possible total electrical system load growth for
For example, the utility impact analysis
relocation of production facilities each region, which it uses in turn to
uses the operating characteristics (e.g.,
outside the country; and (5) the predict the necessary additions to
energy conversion efficiency, emissions
potential for industry consolidation capacity. For both electrical and gas end
rates) of future electricity generating
and/or the elimination of the low- uses, NEMS–BT accounts for the
plants and the prospects for natural gas
volume manufacturer. implementation of efficiency standards
supply as specified in the AEO reference
For more preliminary results for the case. by decrementing the appropriate
MIA, such as other impacts on financial DOE will also explore deviations from reference case load shape. DOE will
performance, impacts on product utility some of the AEO 2007 reference case determine the size of the decrement
and performance, and additional details premises to represent alternative using data for the per-unit energy
on the impacts of cumulative regulatory futures. Two alternative scenarios use savings developed in the LCC and PBP
burden, refer to Chapter 12 of the TSD. the high- and low-economic-growth analyses (see Chapter 8 of the TSD) and
cases of AEO 2007. (The reference case the forecast of shipments developed for
L. Utility Impact Analysis the NIA (see Chapter 9 of the TSD). For
corresponds to medium growth.) The
high-economic-growth case uses higher more information on the utility impact
The utility impact analysis estimates
projected growth rates for population, analysis, refer to Chapter 13 of the TSD.
the effects on the utility industry of
reduced energy consumption due to labor force, and labor productivity, EEI commented that an accurate
improved appliance efficiency. The resulting in lower predicted inflation assessment of electric utility impacts
analysis compares modeling results for and interest rates relative to the requires an evaluation of the type of
the base case with results for each reference case. The opposite is true for load of the appliance (i.e., whether the
candidate standards case. For each of the low-growth case. Starting in 2012, load is primarily during system peak
the four appliance products, the the high-growth case predicts growth in demand or off-peak). (Public Meeting
analysis will consist of forecasted per capita gross domestic product of 3.4 Transcript, No. 5 at p. 264) In response,
differences between the base and we note that in 2001, EIA conducted a
standards cases for electricity
56 For more information on NEMS, please refer to review of its end-use load shapes and
the U.S. Department of Energy, Energy Information updated them to better reflect actual end
generation, installed capacity, sales, and Administration documentation. A useful summary
prices. For CCWs, as well as residential use behavior.58 As a result, DOE has
is National Energy Modeling System: An Overview

dishwashers and cooking products, the 2003, DOE/EIA–0581(2003), March 2003. DOE/EIA
57 The ‘‘load shape’’ defines how the product uses
analysis also will examine differences in approves use of the name NEMS to describe only
an official version of the model without any energy on an hourly basis over the course of the
sales of natural gas. modification to code or data. Because this analysis day.
To estimate these effects of proposed entails some minor code modifications and the 58 Alternative Sectoral Load Shapes for NEMS,
model is run under various policy scenarios that are Department of Energy—Energy Information
standards on the electric and gas utility variations on DOE/EIA assumptions, in this Administration, Washington, DC, August 2001.
industries, DOE intends to use a variant analysis, DOE refers to it by the name NEMS–BT. Continued
confidence that the NEMS–BT provides function of end-use energy savings, it general economy as a result of increased
a good representation of the type of does not currently have the capability of spending driven by the increased
loads exhibited by its end uses. calculating similar results for water and equipment prices and reduced spending
With regard to gas utility impacts, the wastewater utilities. The water utility on energy.
AGA commented that NEMS–BT does sector is more complicated than either DOE expects new standards for the
not address these impacts in a the electric utility or gas utility sectors, four appliance products to increase the
meaningful way. AGA suggested that with a high degree of geographic total installed cost of equipment, which
DOE should conduct a workshop on variability produced by a large diversity includes manufacturer selling price,
proposed modeling approaches to of water resource availability, sales taxes, distribution chain markups,
analyzing gas utility impacts. (AGA, No. institutional history, and regulatory and installation cost. DOE also expects
12 at p. 3) As noted above, NEMS–BT context. DOE currently does not have the new standards to decrease energy
allows for the determination of changes access to tools that analyze water utility consumption, and thus expenditures on
in gas sales due to efficiency standards. impacts. There are activites being energy. Over time, increased total
Therefore, DOE’s gas utility impact conducted or initiated by the USGS, installed cost is paid back through
analysis goes no further than assessing EPA, and DOE to study water and energy savings. The savings in energy
the impact on gas sales. wastewater issues. However, these expenditures may be spent on new
Since the AEO 2007 version of NEMS activites have yet to provide the commercial investment and other items.
forecasts only to the year 2030, DOE necessary sources of data or tools to Using an input/output model of the
would be required to extrapolate results enable a water utility impact analysis U.S. economy, this analysis seeks to
for such forecasts to 2042. DOE comparable to what can be done on estimate the effects on different sectors
conducts an extrapolation to 2042 to be electric and gas utilities using NEMS. and the net impact on jobs. DOE will
consistent with the analysis period Therefore, conducting a credible water estimate national employment impacts
being used by DOE in the NIA. and wastewater utility analysis is for major sectors of the U.S. economy in
However, DOE has determined that it beyond DOE’s existing analysis the NOPR, using public and
will not be feasible to extend the capabilities. commercially available data sources and
forecast period of NEMS–BT for the software. DOE will make all methods
purposes of this analysis, in part M. Employment Impact Analysis
and documentation available for review
because EIA does not have an approved The Process Rule includes in the TSD for the NOPR.
method for extrapolation of many employment impacts among the factors In overview, DOE developed Impact
outputs beyond 2030. While it might to be considered in selecting a proposed of Sector Energy Technologies (ImSET),
seem reasonable in general to make standard, and it provides guidance for a spreadsheet model of the U.S.
simple linear extrapolations of results, consideration of the impact (both direct economy that focuses on 188 sectors
in practice this is not advisable because and indirect) of candidate standard most relevant to industrial, commercial,
outputs could be contradictory. For levels on employment. The Process Rule and residential building energy use.59
example, changes in the fuel mix states a general presumption against any ImSET is a special-purpose version of
implied by extrapolations of those candidate standard level that would the U.S. Benchmark National Input-
outputs could be inconsistent with the directly cause plant closures or Output (I–O) model, which has been
extrapolation of marginal emissions significant loss of domestic designed to estimate the national
factors. An analysis of various trends is employment, unless specifically employment and income effects of
not necessary and would involve a great identified expected benefits of the energy saving technologies that are
deal of uncertainty. Therefore, for all standard would outweigh the adverse deployed by DOE’s Office of Energy
extrapolations beyond 2030, DOE effects. See the Process Rule, 10 CFR Efficiency and Renewable Energy. In
intends to use simple replications of Part 430, Subpart C, Appendix A, comparison with the previous versions
year 2030 results. While these may seem sections 4(d)(7)(ii) and (vi), and of the model used in earlier
unreasonable in some instances, in this 5(e)(3)(i)(B). rulemakings, this version allows for
way results are guaranteed to be DOE estimates the impacts of
more complete and automated analysis
consistent. As with the AEO reference standards on employment for
of the essential features of energy
case in general, the implicit premise is equipment manufacturers, relevant
efficiency investments in buildings,
that the regulatory environment does service industries, energy suppliers, and
industry, transportation, and the electric
not deviate from the current known the economy in general. Both indirect
power sectors. The ImSET software
situation during the extrapolation and direct employment impacts are
includes a computer-based I–O model
period. Only changes that have been covered. Direct employment impacts
with structural coefficients to
announced with date-certain would result if standards led to a change
characterize economic flows among the
introduction are included in NEMS–BT. in the number of employees at the
188 sectors. ImSET’s national economic
Both EEI and SPU stated that DOE factories that produce the four appliance
I–O structure is based on the 1997
should factor impacts to water and products and related supply and service
Benchmark U.S. table (Lawson, et al.
wastewater utilities into the utility firms. Direct impact estimates are
2002),60 specially aggregated to 188
impact analysis. SPU claimed that, in covered in the MIA.
Indirect employment impacts are sectors.
some areas of the country, water is Standards for the four appliance
becoming a limited commodity and impacts on the national economy other
than in the manufacturing sector being products may reduce energy
should be assessed in the context of a
utility impact analysis. (EEI, No. 7 at p. regulated. Indirect impacts may result
59 Roop, J.M., M.J. Scott, and R.W. Schultz. 2005.
6; Public Meeting Transcript, No. 5 at p. both from expenditures shifting among ImSET: Impact of Sector Energy Technologies.
263) Although NEMS–BT provides goods (substitution effect) and changes PNNL–15273. Pacific Northwest National
estimates of changes in electrical utility in income that lead to a change in Laboratory, Richland, WA.
60 Lawson, Ann M., Kurt S. Bersani, Mahnaz
infrastructure requirements as a overall expenditure levels (income
Fahim-Nader, and Jiemin Guo. 2002. ‘‘Benchmark
effect). DOE defines indirect Input-Output Accounts of the U. S. Economy,
Available online at: http://www.onlocationinc.com/ employment impacts from standards as 1997,’’ Survey of Current Business, December, pp.
LoadShapesAlternative2001.pdf. net jobs created or eliminated in the 19–117.
expenditures and increase equipment tracks is CO2. Therefore, the carbon rulemaking as an incremental policy
prices in the commercial sector. These discussed in this analysis is only in the impact (i.e., a standard for the product
expenditure changes are likely to reduce form of CO2. For each of the trial under evaluation) on the AEO 2007
commercial and energy sector standard levels, DOE will calculate total forecast, applying the same basic set of
employment. At the same time, these undiscounted and discounted power assumptions used in AEO 2007. For
equipment standards may increase plant emissions using NEMS–BT, and example, the emissions characteristics
commercial sector investment, and will use other methods to calculate site of an electricity generating plant will be
increase employment in other sectors of emissions. exactly those used in AEO 2007. Also,
the economy. DOE designed the Although DOE plans to consider only forecasts conducted with NEMS–BT
employment impact analysis to estimate SO2, NOX, mercury, and CO2 in its consider the supply-side and demand-
the year-to-year net employment effect environmental assessment, there are side effects on the electric utility
of these different expenditure flows. other air pollutants which are of industry. Thus, DOE’s analysis will
Although DOE intends to use ImSET concern. Specifically, the Clean Air Act account for any factors affecting the type
for its analysis of employment impacts, requires EPA to set National Ambient of electricity generation and, in turn, the
it welcomes input on other tools and Air Quality Standards for the following type and amount of airborne emissions
factors it might consider. For more six common air pollutants, also know as generated by the utility industry.
information on the employment impact ‘‘criteria pollutants’’: (1) Ozone, (2) The NEMS–BT model tracks carbon
analysis, refer to Chapter 14 of the TSD. particulate matter (PM), (3) carbon emissions with a specialized carbon
monoxide (CO), (4) nitrogen dioxide, (5) emissions estimation subroutine,
N. Environmental Assessment
SO2, and (6) lead. 62 EPA recently added producing reasonably accurate results
The primary environmental effect of mercury to this list. But none of the due to the broad coverage of all sectors
energy conservation standards for the ‘‘criteria pollutants’’ not considered in and inclusion of interactive effects. Past
four appliance products would be the environmental assessment (i.e., experience with carbon results from
reduced power plant emissions ozone, PM, CO, and lead) are driven NEMS suggests that emissions estimates
resulting from reduced consumption of significantly by either electric utility are somewhat lower than emissions
electricity. DOE will assess these power plants or fuel-fired appliances. based on simple average factors. One of
environmental effects by using NEMS– Therefore, DOE does not intend on the reasons for this divergence is that
BT to provide key inputs to its analysis. addressing them in the environmental NEMS tends to predict that conservation
The environmental assessment produces assessment. In the case of ozone and displaces generating capacity in future
results in a manner similar to those PM, other pollutants are precursors to years. On the whole, NEMS–BT
provided in the AEO. In addition to their formation, and atmospheric provides carbon emissions results of
electrical power, the operation of three conditions are the driver behind their reasonable accuracy, at a level
of the four appliance products—CCWs, formation. Also, SO2 and NOX, are the consistent with other Federal published
dishwashers, and cooking products— primary precursors to ozone and PM, results.
also requires use of fossil fuels, and respectively, and will already be NEMS–BT also reports SO2, NOX, and
results in emissions of carbon dioxide addressed by the environmental mercury, which DOE has reported in
(CO2), nitrogen oxides (NOX), and sulfur assessment. In the case of CO, electric past analyses. The Clean Air Act
dioxide (SO2) at the sites where the utilities and fuel-fired appliances are Amendments of 1990 set an SO2
appliances are installed. Southern not significant sources. For electric emissions cap on all power
California Gas Company (SoCal Gas) power plants, almost all carbon generation.63 The attainment of this
and PG&E questioned how DOE will emissions come out in the form of CO2 aggregate limit, however, is flexible
evaluate the emissions from gas-fired as the combustion process is lean among generators of emissions, due to
appliances. (Public Meeting Transcript, enough not to yield CO in significant the availability of emissions allowances
No. 5 at pp. 271–272) In response, we amounts. For fuel-fired appliances, and tradable permits. Although NEMS
note that NEMS–BT provides no means proper appliance maintenance, includes a module for SO2 allowance
for estimating such site emissions. installation, and use can prevent trading and delivers a forecast of SO2
Therefore, DOE will calculate, and the dangerous levels of CO. A well-designed allowance prices, accurate simulation of
environmental assessment will include, and properly functioning heating or SO2 trading implies that the effect of
separate estimates of the effect of the cooking appliance should not produce efficiency standards on physical
proposed standard on site emissions of
toxic or lethal levels of CO, as, most emissions will be zero because
CO2, NOX, and SO2, based on simple
often, CO poisoning occurs in the home emissions will always be at or near the
emissions factors derived from the
as a result of malfunctioning appliances. ceiling. However, there may be an SO2
literature.61
The intent of the environmental Finally, with regard to lead, the ban on benefit from energy conservation, in the
assessment is to provide emissions the use of leaded gasoline has resulted form of a lower SO2 allowance price.
results estimates and to properly in a dramatic decrease in lead emissions Since the impact of any one standard on
quantify and consider the since the mid-1970s. Today, industrial the allowance price is likely small and
environmental effects of all new Federal processes (not electric utilities), highly uncertain, DOE does not plan to
rules. The portion of the environmental particularly primary and secondary lead monetize any potential SO2 benefit.
assessment that will be produced by smelters and battery manufacturers, are NEMS–BT also has an algorithm for
NEMS–BT considers only three responsible for most of lead emissions estimating NOX emissions from power
pollutants, SO2, NOX, and mercury, and and all violations of the lead air quality generation. The impact of these
emissions, however, will be affected by
one other emission (carbon). The only standards.

form of carbon the NEMS–BT model As to power plant emissions, DOE the Clean Air Interstate Rule (CAIR),
will conduct each environmental which the EPA published on May 12,
61 U.S. Environmental Protection Agency. assessment performed as part of this 2005. CAIR will permanently cap
Compilation of Air Pollutant Emission Factors, AP–
42, Fifth Edition, Volume 1: Stationary Point and 62 U.S. Environmental Protection Agency. Six 63 See 40 CFR part 50. (See also U.S.
Area Sources. 1998. Available online at: http:// Common Air Pollutants. Washington, DC. Available Environmental Protection Agency Web site at:
www. epa.gov/ttn/chief/ap42.html. online at: http://www.epa.gov/air/urbanair/. http://www.epa.gov/air/caa/).
emissions of NOX in 28 eastern States The Joint Comment stated that DOE DOE will identify and seek to mitigate
and the District of Columbia. 70 FR should evaluate mercury and particulate the overlapping effects on
25162 (May 12, 2005). As with SO2 emissions as part of the environmental manufacturers of new or revised DOE
emissions, a cap on NOX emissions assessment due to their impact on standards and other regulatory actions
means that equipment efficiency public health. (Joint Comment, No. 9 at affecting the same products. Through
standards may have no physical effect p. 3) In response, as noted above, manufacturer interviews and literature
on these emissions. When NOX NEMS–BT accounts for the most recent searches, DOE will compile information
emissions are subject to emissions caps, regulations pertaining to power plant on burdens from existing and
DOE’s emissions reduction estimate mercury emissions and expects that impending regulations affecting the four
corresponds to incremental changes in standards will not have any physical
appliance products covered under this
the prices of emissions allowances in effect on the level of these emissions.
rulemaking. DOE also seeks input from
cap-and-trade emissions markets rather With regard to particulates, these
than physical emissions reductions. emissions are a special case because stakeholders about relevant regulations
Therefore, while the emissions cap may they arise not only from direct whose impacts it should consider.
mean that physical emissions emissions, but also from complex The regulatory impact analysis also
reductions will not result from atmospheric chemical reactions that will address the potential for non-
standards, standards could produce an result from NOX and SO2 emissions. regulatory approaches to supplant or
economic benefit in the form of lower Because of the highly complex and augment energy conservation standards
prices for emissions allowance credits. uncertain relationship between to improve the efficiency of the four
However, as with SO2 allowance prices, particulate emissions and particulate appliance products. One such potential
DOE does not plan to monetize this concentrations that impact air quality, non-regulatory program is tax credits. In
benefit because the impact on the NOX DOE does not plan on reporting assessing the potential impacts from tax
allowance price from any single energy particulate emissions. credits, EEI suggested that DOE should
conservation standard is likely small Potomac and SPU urged DOE to
evaluate the long-term effects on market
and highly uncertain. evaluate wastewater discharge impacts
transformation to more-efficient
EEI stated that new rules pertaining to due to increased efficiency standards.
power plant SO2 and NOX emissions (Public Meeting Transcript, No. 5 at p. products from short-term (e.g., two-year)
will limit the impact that standards can 269) DOE plans to conduct a separate tax credits. (Public Meeting Transcript,
have on reducing these emissions. (EEI, analysis of wastewater discharge No. 5 at p. 278) AHAM stated that
No. 7 at p. 4) As noted above, NEMS– impacts as part of the environmental recent Federal tax credits for
BT accounts for the most recent assessment. DOE intends to derive a dishwashers will have an effect on
regulations pertaining to power plant simple national aggregate estimate of improving overall product efficiency
SO2 and NOX emissions and expects wastewater discharge impacts from and that DOE should consider such
that appliance efficiency standards will proposed energy conservation effect as part of analyzing the impact of
not have any physical effect on these standards, based on estimates of tax credits. (Public Meeting Transcript,
emissions. consumer water savings. It will first No. 5 at p. 277) In response, we noted
With regard to mercury emissions, provide a simple estimate of the fraction that the NOPR will include a complete
NEMS has an algorithm for estimating of water savings that result in decreased quantitative analysis of alternatives to
these emissions from power generation. wastewater discharges. Then, by the proposed energy conservation
However, the impact on mercury applying this discharge fraction to the standards (including tax credits), and
emissions will be affected by the Clean water savings estimate, DOE can DOE will use the most recent
Air Mercury Rule (CAMR), which the provide an approximate wastewater information available to make its
EPA published on May 18, 2005. 70 FR discharge savings estimate. assessments. DOE will use the NES
28606. CAMR will permanently cap The results for the environmental spreadsheet model (as discussed in
emissions of mercury for new and assessment are similar to a complete
existing coal-fired plants in all States. section II.I, ‘‘National Impact Analysis’’)
NEMS run as published in the AEO to calculate the NES and NPV for the
As with SO2 and NOX emissions, a cap 2007. These results include power
on mercury emissions means that alternatives to the proposed
sector emissions for SO2, NOX, and
appliance efficiency standards may have conservation standards. For more
carbon in five-year forecasted
no physical effect on these emissions. increments extrapolated to 2042. The information on the regulatory impact
When mercury emissions are subject to outcome of the analysis for each analysis, refer to the regulatory impact
emissions caps, DOE’s emissions candidate standard level is reported as analysis report in the TSD.
reduction estimate corresponds to a deviation from the AEO 2007 III. Candidate Energy Conservation
incremental changes in the prices of reference (base) case. Standard Levels
emissions allowances in cap-and-trade For more detail on the environmental
emissions markets rather than physical assessment, refer to the environmental The Process Rule states that DOE will
emissions reductions. Therefore, while assessment report in the TSD. specify candidate standard levels in the
the emissions cap may mean that ANOPR, but will not propose a
physical emissions reductions will not O. Regulatory Impact Analysis
particular standard. 10 CFR Part 430,
result from standards, standards could DOE will prepare a draft regulatory Subpart C, Appendix A, section
produce an economic benefit in the impact analysis in compliance with
4(c)(1)(i). Section II.I.4, ‘‘National
form of lower prices for emissions Executive Order 12866, ‘‘Regulatory
Impact Analysis Results’’ identifies the

allowance credits. However, as with SO2 Planning and Review,’’ which will be
and NOX allowance prices, DOE does candidate standard levels for each of the
subject to review by OMB’s Office of
not plan to monetize this benefit Information and Regulatory Affairs four appliance products. Tables III.1
because the impact on the mercury (OIRA). 58 FR 51735 (October 4, 1993). through III.4 repeat the candidate
allowance price from any single energy As part of the regulatory impact standard levels for each of the four
conservation standard is likely small analysis, and as discussed in section appliance products.
and highly uncertain. II.K, ‘‘Manufacturer Impact Analysis,’’
TABLE III.1.—STANDARD DISH- TABLE III.1.—STANDARD DISH- TABLE III.1.—STANDARD DISH-

WASHERS: CANDIDATE STANDARD WASHERS: CANDIDATE STANDARD WASHERS: CANDIDATE STANDARD
LEVELS LEVELS—Continued LEVELS—Continued
Candidate standard level Energy factor Candidate standard level Energy factor Candidate standard level Energy factor
1 ............................................ 0.46 4 ............................................ 0.65 7 ............................................ 1.11

2 ............................................ 0.58 5 ............................................ 0.72
3 ............................................ 0.62 6 ............................................ 0.80
TABLE III.2.—DEHUMIDIFIERS: CANDIDATE STANDARD LEVELS

≤25.00 25.01–35.00 35.01–45.00 45.01–54.00 54.01–74.99 ≥75.00
Candidate standard level
EF EF EF EF EF EF
1 ............................................................... 1.10 1.25 1.35 1.45 1.55 2.38

2 ............................................................... 1.20 1.30 1.40 1.50 1.60 2.50
3 ............................................................... 1.25 1.35 1.45 1.55 1.65 2.55
4 ............................................................... 1.30 1.40 1.50 1.60 1.70 2.60
5 ............................................................... 1.38 1.45 1.74 2.02 1.80 2.75
TABLE III.3.—COOKING PRODUCTS: CANDIDATE STANDARD LEVELS

Cooktops Ovens Microwave
ovens
Elec coil Elec smooth Gas Elec stand- Elec self- Gas stand- Gas self-
Candidate standard level ard clean ard clean
EF
EF EF EF EF EF EF EF
1* ...................................... 0.769 0.752 0.399 0.1113 0.1102 0.0536 0.0625 0.586

2 ....................................... .................... .................... 0.420 0.1163 0.1123 0.0566 0.0627 0.588
3 ....................................... .................... .................... .................... 0.1181 .................... 0.0572 0.0632 0.597
4 ....................................... .................... .................... .................... 0.1206 .................... 0.0593 .................... 0.602
5 ....................................... .................... .................... .................... 0.1209 .................... 0.0596 .................... ....................
6 ....................................... .................... .................... .................... .................... .................... 0.0600 .................... ....................
1a* .................................... .................... .................... .................... .................... .................... 0.0583 .................... ....................
* For gas standard ovens, candidate standard levels 1 and 1a correspond to designs that are utilized for the same purpose—eliminate the need
for a standing pilot-but the technologies for each design are different. Candidate standard level 1 is a hot surface ignition device while candidate
standard level 1a is a spark ignition device. Candidate standard level 1a is presented at the end of the table because candidate standard levels
2 through 6 are derived from candidate standard level 1.
TABLE III.4.—COMMERCIAL CLOTHES date (e.g., an effective date two years level from each of the six classes that
WASHERS: CANDIDATE STANDARD after the publication of the final rule); or has the minimum LCC.
LEVELS • A larger increase in the efficiency DOE will also attempt to limit the
level at a later effective date.
For the NOPR, DOE will develop trial number of TSLs considered for the
Modified en- NOPR by dropping from consideration
Candidate standard level ergy factor/ standard levels (TSL) from the above
water factor candidate standard levels for each of the candidate standard levels that do not
four appliance products. DOE will exhibit significantly different economic
1 ............................................ 1.42/9.50 consider several criteria in developing and/or engineering characteristics from
2 ............................................ 1.60/8.50 the TSLs, including, but not limited to, candidate standard levels already
3 ............................................ 1.72/8.00 which candidate standard level has the selected as a TSL. For example, in the
4 ............................................ 1.80/7.50 minimum LCC, maximum NPV, and case of dishwashers, the candidate
5 ............................................ 2.00/5.50 maximum technologically feasible standard level with the minimum LCC
6 ............................................ 2.20/5.10 efficiency. From the list of TSLs is candidate standard level 3 with an EF
developed, DOE will select one as its of 0.65. If the sole consideration for
DOE will review the public input it proposed standard for the NOPR, while selecting TSLs was LCC, DOE would
receives in response to this ANOPR and explaining the other TSLs considered likely drop candidate standard level 4
will update the analyses appropriately and the reasons for their elimination in with an EF of 0.68 as its LCC savings are
for each product class before issuing the deciding upon the level ultimately lower and not significantly different
NOPR. In addition, DOE will consider proposed. than the value for candidate standard
For a given product consisting of
any comments it receives on the level 3.
several product classes (e.g.,
candidate standard levels set forth
dehumidifiers and cooking products), DOE specifically seeks feedback on

above for the four appliance products, the criteria it should use for basing the
DOE will develop each TSL so that it is
and on whether alternative levels would comprised of candidate standard levels selection of TSLs. This is identified as
satisfy EPCA criteria for DOE adoption from each class that exhibit similar Issue 16 under ‘‘Issues on Which DOE
of standards, for example: characteristics. For example, in the case Seeks Comment’’ in section IV.E of this
• A moderate increase in the of dehumidifiers, one of the TSLs will ANOPR.
efficiency level at an earlier effective likely consist of the candidate standard
IV. Public Participation of presentations and to establish the be identified by the docket number EE–
procedures governing the conduct of the 2006–STD–0127 and/or RIN 1904–
A. Attendance at Public Meeting
public meeting. After the public AB49, and whenever possible carry the
The time, date, and location of the meeting, interested parties may submit electronic signature of the author.
public meeting are set forth in the DATES further comments on the proceedings Absent an electronic signature,
and ADDRESSES sections at the beginning and any other aspect of the rulemaking comments submitted electronically
of this document. Anyone who wishes until the end of the comment period. must be followed and authenticated by
to attend the public meeting must notify The public meeting will be conducted submitting the signed original paper
Ms. Brenda Edwards-Jones at (202) 586– in an informal, conference style. DOE document. DOE will not accept any
2945. will present summaries of comments telefacsimiles (faxes).
B. Procedure for Submitting Requests to received before the public meeting, Under 10 CFR 1004.11, any person
Speak allow time for presentations by submitting information that he or she
participants, and encourage all believes to be confidential and exempt
Any person who has an interest in interested parties to share their views on by law from public disclosure should
today’s notice, or who is a issues affecting this rulemaking. Each submit two copies. One copy of the
representative of a group or class of participant will be allowed to make a document shall include all the
persons that has an interest in these prepared general statement (within time information believed to be confidential,
issues, may request an opportunity to limits determined by DOE) before the and the other copy of the document
make an oral presentation at the public discussion of specific topics. DOE will shall have the information believed to
meeting. Please hand-deliver requests to permit other participants to comment be confidential deleted. DOE will make
speak to the address shown under the briefly on any general statements. its own determination about the
heading ‘‘Hand Delivery/Courier’’ in the At the end of all prepared statements confidential status of the information
ADDRESSES section of this notice, on a topic, DOE will permit participants and treat it according to its
between 9 a.m. and 4 p.m., Monday to clarify their statements briefly and determination.
through Friday, except Federal holidays. comment on statements made by others. Factors of interest to DOE when
Requests also may be sent by mail, to Participants should be prepared to evaluating requests to treat submitted
the address shown under the heading answer questions by DOE and by other information as confidential include: (1)
‘‘Postal Mail’’ in the ADDRESSES section participants concerning these issues. A description of the items; (2) whether
of this notice, or by e-mail to DOE representatives may also ask and why such items are customarily
Brenda.Edwards-Jones@ee.doe.gov. questions of participants concerning treated as confidential within the
Persons requesting to speak should other matters relevant to the public industry; (3) whether the information is
briefly describe the nature of their meeting. The official conducting the generally known by, or available from,
interest in this rulemaking and provide public meeting will accept additional other sources; (4) whether the
a telephone number for contact. DOE comments or questions from those information has previously been made
asks each person selected to be heard to attending, as time permits. The available to others without obligation
submit a copy of his or her statement at presiding official will announce any concerning its confidentiality; (5) an
least two weeks before the public further procedural rules or modification explanation of the competitive injury to
meeting, either by hand delivery, mail, of the above procedures that may be the submitting person which would
or e-mail as described in the preceding needed for proper conduct of the public result from public disclosure; (6) when
paragraph. Please include an electronic meeting. such information might lose its
copy of your statement, on a computer DOE will make the entire record of confidential character due to the
diskette or CD when delivery is by mail this proposed rulemaking, including the passage of time; and (7) why disclosure
or hand delivery. Electronic copies must transcript from the public meeting, of the information would be contrary to
be in WordPerfect, Microsoft Word, available for inspection at the U.S. the public interest.
Portable Document Format (PDF), or Department of Energy, Forrestal
text in American Standard Code for Building, Room 1J–018 (Resource Room E. Issues on Which the Department of
Information Interchange (ASCII) file of the Building Technologies Program), Energy Seeks Comment
format. At its discretion, DOE may 1000 Independence Avenue, SW, DOE is interested in receiving
permit any person who cannot supply Washington, DC, (202) 586–9127, comments on all aspects of this ANOPR.
an advance copy of his or her statement between 9 a.m. and 4 p.m., Monday DOE especially invites comments or
to participate, if that person has made through Friday, except Federal holidays. data to improve DOE’s analysis,
alternative arrangements with the Any person may buy a copy of the including data or information that will
Building Technologies Program. In such transcript from the transcribing reporter. respond to the following questions or
situations, the request to give an oral concerns addressed in this ANOPR:
D. Submission of Comments
presentation should ask for alternative
DOE will accept comments, data, and 1. Microwave Oven Standby Power
arrangements.
information regarding all aspects of this For the NOPR, DOE is considering
C. Conduct of Public Meeting ANOPR before or after the public purchasing, testing, and analyzing
DOE will designate a DOE official to meeting, but no later than January 29, microwave ovens to better understand
preside at the public meeting and may 2008. Please submit comments, data, the utility, cost, and cost implications of
also use a professional facilitator to aid and information electronically to the reducing standby power consumption.
discussion. The meeting will not be a following e-mail address: Addition of a standby power test to the
judicial or evidentiary-type public home_appliance. existing test procedure would be

hearing, but DOE will conduct it in rulemaking@ee.doe.gov. Submit necessary before standby power could
accordance with 5 U.S.C. 553 and electronic comments in WordPerfect, be included in an efficiency standard.
section 336 of EPCA. (42 U.S.C. 6306) A Microsoft Word, PDF, or text (ASCII) file DOE is considering this approach for
court reporter will be present to record format and avoid the use of special microwave ovens because data provided
the transcript of the proceedings. DOE characters or any form of encryption. by AHAM suggests that there is an
reserves the right to schedule the order Comments in electronic format should opportunity for significant energy
savings via the reduction of standby feedback on the approach of analyzing (See section II.D.2 of this ANOPR for
power levels. Therefore, DOE requests additional design options that would further details.)
data and stakeholder feedback on how result in a lowering of the energy
9. Commercial Clothes Washer Per-
to conduct an analysis of standby power consumption of non-cooking features
Cycle Energy Consumption
for microwave ovens. (See section (e.g., standby power), even though the
I.D.4.b of this ANOPR for further existing test procedure currently does DOE determined the per-cycle clothes
details.) not account for such usage in EF. (See drying energy use and the per-cycle
section II.C.3 of this ANOPR for further machine energy use for CCWs from data
2. Product Classes details.) in its 2000 TSD for residential clothes
In accordance with EPCA section washers. DOE requests feedback on
325(p)(1)(A), DOE identified the 6. Technologies Unable to be Analyzed whether these per-cycle energy use
equipment classes covered under this and Exempted Product Classes characteristics for residential clothes
rulemaking. (42 U.S.C. 6295(p)(1)(A)) There are a number of technologies washers are also representative of CCW
Pursuant to EPCA section 325(p)(1)(B), which DOE was unable to analyze for energy use. (See section II.D.4 of this
DOE requests comments on these this ANOPR. Design options associated ANOPR for further details.)
equipment classes and invites interested with these technologies for
dehumidifiers, cooking products, and 10. Commercial Clothes Washer
persons to submit written presentations
CCWs, while passing the screening Consumer Prices
of data, views, and arguments. (42
U.S.C. 6295(p)(1)(B)) (See section II.A.1 analysis, were eliminated from further DOE identified two distribution
of this ANOPR for further details.) consideration prior to the ANOPR channels for CCWs to establish their
engineering analysis. In addition, price to consumers. One channel
3. Commercial Clothes Washer certain product classes were exempted involved distributors that typically sell
Horizontal-Axis Designs on a similar lack of efficiency data. DOE to Laundromats, and the other channel
The information available for CCWs requests stakeholder input on (1) energy involved route operators that typically
suggests that an efficiency of 1.6 MEF efficiency data for technologies and sell or lease to multi-family building
and 8.5 WF will be based on horizontal- product classes for which such data property owners. For purposes of
axis technology. As such, it appears that does not exist; and (2) potential developing the markups and consumer
the incremental costs between 1.60 limitations of existing test procedures. equipment prices for CCWs, DOE based
MEF/8.5 WF and 2.2 MEF/5.1 WF will The latter may include such issues as its calculations solely on a distribution
be constant at the same value as those representative usage patterns, ambient channel that involves distributors. DOE
provided by AHAM for the level 2.0 conditions, and test equipment. (See believed that the markups and the
MEF/5.5 WF. DOE particularly seeks sections II.A.1 and II.C.2 of this ANOPR resulting consumer equipment prices
comment on the validity of such an for further details.) determined for this distribution channel
approach. DOE also seeks information also would be representative of the
7. Dishwasher Efficiency and its Impact
about lower-cost alternatives to prices paid by consumers acquiring
on Cleaning Performance
horizontal-axis designs for levels greater their equipment from route operators.
than 1.42 MEF/9.5 WF and lower than DOE was not able to identify sources DOE requests feedback on its views
2.0 MEF/5.5 WF. Additionally, DOE of data showing whether the amount of regarding its development of consumer
seeks information that would allow it to pre-washing is impacted by dishwasher prices for CCWs. (See section II.E.1 of
change the energy and water features of efficiency. Therefore, DOE believes that, this ANOPR for further details.)
the 2.0 MEF/5.5 WF level to allow for to date, hand-washing or pre-washing
habits have not been affected by product 11. Repair and Maintenance Costs
manufacturer cost differentiation at the
lower (and the higher) levels. efficiency. Because increased diswasher Primarily because it did not receive
Furthermore, DOE seeks comment on energy efficiency may require future any specific data on the impacts that
how to evaluate potential shifts from designs to utlize less water, DOE standards might have on repair and
vertical-axis technologies to horizontal- recognizes the possibility that more maintenance costs, DOE did not include
axis. (See section II.C.4.d of this ANOPR efficient dishwashers may degrade wash any changes in repair and maintenance
for further details.) performance. Therefore, DOE seeks costs due to standards for any of the
feedback on whether more efficient four appliance products. DOE requests
4. Compact Dishwashers dishwasher designs will affect cleaning feedback on its understanding of repair
DOE was unable to obtain incremental performance, leading to increased hand- and maintenance costs. (See section
manufacturing cost information for washing or pre-washing and, if so, what II.G.2.b of this ANOPR for further
compact dishwashers. Therefore, DOE increase in energy and water use can be details.)
did not analyze compact dishwashers expected. (See section II.D.1 of this
12. Efficiency Distributions in the Base
for this ANOPR but expects to set ANOPR for further details.)
Case
standards for them. DOE requests
8. Dehumidifier Use To accurately estimate the percentage
feedback on how it can extend the
results of the analysis for the standard DOE identified several sources of data of consumers that would be affected by
class to compact dishwashers. (See for estimating the annual use of a particular energy conservation
section II.C.4 of this ANOPR for further dehumidifiers. However, DOE gave standard level, DOE took into account
details.) more weight to data that AHAM the distribution of product efficiencies
provided because they were developed currently in the marketplace. In other
5. Microwave Oven Design Options based on the experience of words, DOE conducted its LCC and PBP
For microwave ovens, the design manufacturers. It appears that AHAM’s analyses by considering the full breadth
options and efficiency levels that DOE average estimate of 1,095 operating of product efficiencies that consumers
analyzed are those identified in the hours per year is the most representative purchase under the base case (i.e., the
previous rulemaking’s analysis, with of actual use. DOE requests feedback on case without new energy efficiency
incremental manufacturing costs scaled whether 1,095 hours per year best standards) to account for those
by the PPI. DOE requests stakeholder represents the use of dehumidifiers. consumers who already purchase more
efficient products. DOE developed base Specifically, DOE applied the costs significance of that problem, to enable
case efficiency distributions for each of developed for the combined 0–35.00 assessment of whether any new
the four appliance products based on a pints/day class to the two individual regulation is warranted. (Executive
combination of data sources and classes that comprised the combined Order 12866, section 1(b)(1)). DOE
estimates. DOE requests feedback on the class—25.00 pints/day and less and presumes that a perfectly functioning
data sources and estimates it used for 25.01–35.00 pints/day. Further, DOE market would result in efficiency levels
developing its base case product applied the costs developed for the that maximize benefits to all affected
efficiency distributions. (See section 35.01–45.00 pints/day and 54.01–74.99 persons. Consequently, without a
II.G.2.d of this ANOPR for further pints/day product classes to the 45.01– market failure or other specific problem,
details.) 54.00 pints/day and 75.00 pints/day and a regulation would not be expected to
greater product classes, respectively. In result in net benefits to consumers and
13. Commercial Clothes Washer
its application of total installed costs to the nation. However, DOE also notes
Shipments Forecasts
those product classes where no cost data that whether it establishes standards for
Based on historical data, CCW were developed, DOE did not these products is determined by the
shipments dropped significantly interpolate or extrapolate the cost data statutory criteria expressed in EPCA.
between 1998 and 2005. Because DOE to account for product efficiency Even in the absence of a market failure
tied forecasted shipments to the growth differences between the classes. For or other specific problem, DOE
in new multi-family construction, DOE example, DOE utilized the exact same nonetheless may be required to establish
forecasted a continued increase in total installed costs that were developed standards under existing law.
clothes washer shipments over the for the baseline and standard levels for DOE’s preliminary analysis for
analysis period (i.e., 2012–2042). the 35.01–45.00 pints/day product class dishwashers, dehumidifiers, some gas
However, due to the dramatic drop in to characterize the baseline and cooking products, and commercial
shipments seen in the historical data, standard level total installed costs for clothes washers explicitly accounts for
DOE is uncertain as to whether the 45.01–54.00 pints/day product class. the percentage of consumers that
shipments will continue to increase and DOE requests feedback on its approach already purchase more efficient
requests feedback on the bases for its for characterizing the total installed equipment and takes these consumers
shipments forecasts for CCWs. (See costs for those dehumidifier product into account when determining the
section II.H.1 of this ANOPR for further classes in which it was not able to national energy savings associated with
details.) develop cost-efficiency relationships. various candidate standard levels. The
14. Base-Case and Standards-Case (See section II.I.3 of this ANOPR for preliminary analysis suggests that
further details.) accounting for the market value of
Forecasted Efficiencies
energy savings alone (i.e., excluding any
Because key inputs to the calculation 16. Trial Standard Levels possible ‘‘externality’’ benefits such as
of the NES and NPV are dependent on For the NOPR, DOE will develop trial those noted below) would produce
the estimated efficiencies under the base standard levels (TSL) from the enough benefits to yield net benefits
case (without standards) and the candidate standard levels for each of the across a wide array of products and
standards case (with standards), four appliance products. DOE will circumstances. With the exception of
forecasted efficiencies are of great consider several criteria in developing electric and some gas cooking products,
importance to the analysis. DOE the TSLs, including, but not limited to, these results quantify the percentage of
forecasted base-case and standards-case which candidate standard level has the consumers that do purchase more
efficiencies, believing they remained minimum LCC, maximum NPV, and efficient products. DOE requests
frozen throughout the analysis period maximum technologically feasible additional data (including the
(i.e., 2012–2042). DOE used a ‘‘roll-up’’ efficiency. From the list of TSLs percentage of consumers purchasing
scenario to establish the shipment- developed, DOE will select one as its more efficient cooking products and the
weighted efficiency for the year that proposed standard for the NOPR. DOE extent to which consumers of all
standards are estimated to become requests feedback on the criteria it product types will continue to purchase
effective (i.e., 2012). Under a roll-up should use for basing the selection of more efficient equipment), for testing
scenario, DOE believed that product TSLs. (See section III of this ANOPR for the existence and extent of these
efficiencies in the base case that did not further details.) consumer actions.
meet the standard level under DOE believes that there is a lack of
V. Regulatory Review and Procedural
consideration would roll up to meet the consumer information and/or
Requirements
new standard level. DOE requests information processing capability about
feedback on its methodologies for both DOE submitted this ANOPR for energy efficiency opportunities in the
forecasting efficiencies and estimating review to OMB under Executive Order home appliance market. If this is in fact
the impact that standards have on 12866, ‘‘Regulatory Planning and the case, DOE would expect the energy
product efficiencies. (See section II.I.2 Review.’’ 58 FR 51735 (October 4, 1993). efficiency for home appliances to be
of this ANOPR for further details.) If DOE later proposes energy randomly distributed across key
conservation standards for any of the variables such as energy prices and
15. Dehumidifier Cost and Efficiency four appliance products, and if the usage levels. Although, with the
Relationships proposed rule constitutes a significant exception of cooking products, DOE has
DOE defined total installed cost and regulatory action, DOE would prepare already identified the percentage of
efficiency relationships for a subset of and submit to OMB for review the consumers that already purchase more
the six dehumidifier product classes, assessment of costs and benefits efficient products, DOE does not
For purposes of conducting its NIA, required by section 6(a)(3) of the correlate the consumer’s usage pattern
DOE applied the cost-efficiency data Executive Order. The Executive Order and energy price with the efficiency of
that were developed for these product requires agencies to identify the specific the purchased product. Therefore, DOE
classes to those classes for which DOE market failure or other specific problem seeks data on the efficiency levels of
was unable to develop cost-efficiency that it intends to address that warrants existing home appliances in use by how
relationships due to lack of data. new agency action, as well as assess the often it is utilized (e.g., how many times
or hours the product is used) and its costs are problems, one would expect to clothes washers who also pay for their
associated energy price (and/or find certain outcomes with respect to energy and water consumption to
geographic region of the country). DOE appliance energy efficiency. For purchase machines that exhibit higher
plans to use these data to test the extent example, other things equal, one would energy efficiency and lower water usage
to which purchasers of this equipment not expect to see higher rents for compared to machines whose owners do
behave as if they are unaware of the apartments with high-efficiency not pay for the energy and water usage,
costs associated with their energy appliances. Conversely, if there were other things equal. To test for this form
consumption. Also, DOE seeks comment symmetric information, one would of market failure, DOE needs data on
on additional knowledge of the Federal expect appliances with higher energy energy efficiency and water
Energy Star program, and the program’s efficiency in rental units where the rent consumption of such units and whether
potential as a resource for increasing includes utilities compared to those the owner of the equipment is also the
knowledge of the availability and where the renter pays the utility bills operator. DOE is also interested in other
benefits of energy efficient appliances in separately. Similarly, for single-family potential tests of market failure and data
the home appliance consumer market. homes, one would expect higher energy that would enable such tests.
A related issue is the problem of efficiency levels for replacement units In addition, various other analyses
asymmetric information (one party to a than appliances installed in new and procedures may apply to such
transaction has more and better construction. Within the new future rulemaking action, including
information than the other) and/or high construction market, one would expect those required by the National
transactions costs (costs of gathering to see appliances with higher energy Environmental Policy Act (Pub. L. 91–
information and effecting exchanges of efficiency levels in custom-built homes 190, 42 U.S.C. 4321 et seq.); the
goods and services). In the case of (where the buyer has more say in Unfunded Mandates Reform Act of 1995
appliances, in many instances the party appliance choices) than in comparable (Pub. L. 104–4); the Paperwork
responsible for the appliance purchase homes built in large-scale Reduction Act (44 U.S.C. 3501 et seq.);
may not be the one who pays the cost developments. the Regulatory Flexibility Act (5 U.S.C.
to operate it. For example, home Of course, there are likely to be 601 et seq.); and certain Executive
builders in large-scale developments certain ‘‘external’’ benefits resulting Orders.
often make decisions about appliances from the improved efficiency of units The draft of today’s action and any
without input from home buyers, nor do that are not captured by the users of other documents submitted to OMB for
they offer options to upgrade them. such equipment. These include both review are part of the rulemaking record
Also, apartment owners normally make environmental and energy security- and are available for public review at
decisions about appliances, but it may related externalities that are not already the U.S. Department of Energy, Forrestal
be the renters who pay the utility bills. reflected in energy prices, such as Building, Room 1J–018, (Resource Room
If there were no transactions costs, it reduced emissions of greenhouse gases of the Building Technologies Program),
would be in the home builders’ and and reduced use of natural gas and oil 1000 Independence Avenue, SW.,
apartment owners’ interest to install for electricity generation. DOE invites Washington, DC, (202) 586–9127,
appliances the buyers and renters would comments on the weight that should be between 9 a.m. and 4 p.m., Monday
choose on their own. For example, a given to these factors in DOE’s through Friday, except Federal holidays.
renter who knowingly faces higher determination of the maximum
utility bills from low-efficiency efficiency level at which the total VI. Approval of the Office of the
appliances would be willing to pay less benefits are likely to exceed the total Secretary
in rent, and the apartment owner would costs resulting from a DOE standard. The Secretary of Energy has approved
indirectly bear the higher utility cost. As previously stated, DOE generally
publication of today’s ANOPR.
However, this information is not seeks data that might enable it to
costless, and it may not be in the conduct tests of market failure for Issued in Washington, DC, on September
interest of the renter to take the time to products under consideration for 17, 2007.
develop it, or, in the case of the landlord standard-setting. For example, given Alexander A. Karsner,
who installs a high-efficiency appliance, adequate data, there are ways to test for Assistant Secretary, Energy Efficiency and
to convey that information to the renter. the extent of market failure for Renewable Energy.
To the extent that asymmetric commercial clothes washers. One would [FR Doc. E7–22040 Filed 11–14–07; 8:45 am]
information and/or high transactions expect the owners of commercial BILLING CODE 6450–01–P

Proposed Rule: Consumer Products Energy Conservation Program: Energy Conservation Standards&#8212 Dishwashers, Dehumidifiers, Electric and Gas Kitchen Ranges and Ovens and Commercial Clothes Washers

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Thursday,

November 15, 2007

10 CFR Parts 430 and 431

Engineering (TSD Chapter 5):

ufacturer markups and (2) Shipments to different

LCC and PBP

Climate. Proceeding of International Symposium on

369–02/index.htm. products designed to meet possible in years.

TABLE I.2.—THE FOUR APPLIANCE PRODUCTS—ANALYSIS PROCESS

6 Available online at DOE’s Web site: http:// appliance_standards/residential/

TABLE II.1.—INDUSTRY SHIPMENTS OF DISHWASHERS AND DEHUMIDIFIERS

2005 ................................................................................................................. 7,294 133 7,428 1,957

TABLE II.2.—INDUSTRY SHIPMENTS OF COOKING PRODUCTS

Electric ranges Gas ranges

Available for purchase at: http://www.aham.org/ht/ April, 1998, 1999.

TABLE II.3.—INDUSTRY SHIPMENTS OF TABLE II.3.—INDUSTRY SHIPMENTS OF TABLE II.3.—INDUSTRY SHIPMENTS OF

the efficiency-level data, transparency to be revised to measure energy savings

TABLE II.14.—EFFICIENCY LEVELS FOR RESIDENTIAL DEHUMIDIFIERS

0–35.00 35.01–45.00 54.01–74.99

Baseline ....................................................................................................................................... 1.20 1.30 1.50

procedure already accounts for burner efficiency levels without a scaling

TABLE II.16.—EFFICIENCY LEVELS FOR RESIDENTIAL ELECTRIC COOKTOPS

Baseline .......................................... 0.737 .............................................. 0.737 0.742 .............................................. 0.742

TABLE II.17.—EFFICIENCY LEVELS FOR RESIDENTIAL GAS OVENS

Baseline .......................................... 0.059 .............................................. 0.0298 0.071 .............................................. 0.0540

TABLE II.18.—EFFICIENCY LEVELS FOR RESIDENTIAL ELECTRIC OVENS

Baseline .......................................... 0.122 .............................................. 0.1066 0.138 .............................................. 0.1099

illuminated cavity interior, but maximum levels that are currently

TABLE II.20.—EFFICIENCY LEVELS FOR COMMERCIAL CLOTHES WASHERS

Baseline ............................................................................................................................................................... 1.26 9.5

TABLE II.21.—ENGINEERING ANALYSIS METHODS

AHAM Data .............................................................................................. √ √ √ √

TABLE II.23.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL DEHUMIDIFIERS

0 to 35.00 ..................................................................................................................... Baseline .................................................... ........................

TABLE II.24.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL GAS COOKTOPS

0 ............. Baseline ............................................................................................................................................... 0.156 ........................

TABLE II.25.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC COIL COOKTOPS

0 ............. Baseline ............................................................................................................................................... 0.737 ........................

1 ............. 0 + Improved Contact Conductance ................................................................................................... 0.769 $2.28

TABLE II.26.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC SMOOTH COOKTOPS

0 ............. Baseline ............................................................................................................................................... 0.742 ........................

TABLE II.27.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL GAS STANDARD OVENS

0 ............. Baseline ............................................................................................................................................... 0.0298 ........................

TABLE II.28.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL GAS SELF-CLEANING OVENS

0 ............. Baseline ............................................................................................................................................... 0.0540 ........................

TABLE II.29.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC STANDARD OVENS

0 ............. Baseline ............................................................................................................................................... 0.1066 ........................

TABLE II.30.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC SELF-CLEANING OVENS

0 ............. Baseline ............................................................................................................................................... 0.1099 ........................

Level Slope = –0.0157 Slope = –0.0073

Standard Self-Clean Standard Self-Clean

0 ....................................................................................................................... ........................ 0.1632 0.0865 0.0865

Level Slope = –0.0157 Slope = –0.0073

Standard Self-Clean Standard Self-Clean

3 ....................................................................................................................... 0.1822 ........................ 0.0935 ........................

TABLE II.32.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL MICROWAVE OVENS

0 ............. Baseline ............................................................................................................................................... 0.557 ........................

cycles/kWh kWh/cycle gal/cycle kWh/cycle kWh/cycle kW

Baseline ............................................................... 0.46 2.17 8.16 1.37 0.80 0.002

Baseline ............................................................... 0.46 295 1.34 1.24 190 1.8

24 68 FR 51887 (August 29, 2003).

TABLE II.36.—DEHUMIDIFIER ANNUAL ENERGY CONSUMPTION DERIVED FROM HOURLY USE

AHAM Energy LBNL-